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              "
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                                       EPA-305-B-97-006
                                             September 1997
              Inspection Tool for
       the Hazardous Organic NESHAP
                    (HON)

    Volume I: Overview of Emission Points,
   Control Technologies, and HON Provisions
       U.S. Environmental Protection Agency
Chemical, Commercial Services, and Municipal Division
             Washington, D.C. 20460

-------


-------
Volume I & II
DISCLAIMER

The statements in this document are intended solely as guidance. This document is not intended, nor can
it be relied on, to create any rights enforceable by any party in litigation with the United States.  EPA and
State officials may decide to follow the guidance provided in this document, or to act at variance with the
guidance, based on analysis of specific site circumstances.  This guidance may be revised without public
notice to reflect changes in EPA's policy.

Mention of trade names or commercial products in this document or associated references does not
constitute an endorsement or recommendation for use.
For additional copies of this inspection tool (EPA-305-B-97-006) orders can be placed via the U.S. Mail,
telephone, fax, or online from the National Center for Environmental Publications and Information (NCEPI)
at:

                                    NCEPI
                                    P.O. Box 42419
                                    Cincinnati, OH 45243
                                    telephone:  (800)490-9198
                                    fax:  (513)489-8695
                                    on-line:  www.epa.gov/ncepihom/index.html
Photo credits for cover photography by S.C. Delaney, U.S. EPA.  Cover photograph courtesy of Vista
Chemical Company, Baltimore, Maryland
                                                                                   September 1997

-------
Volume I & II
Inspection Tool for the Hazardous Organic NESHAP (HON)
                                   TABLE OF CONTENTS
                                          VOLUME I
                        OVERVIEW OF EMISSION POINTS, CONTROL
                         TECHNOLOGIES, AND HON PROVISIONS
Section                                                                            Bage

1.0    BACKGROUND AND PURPOSE OF THIS DOCUMENT 	  1-1

2.0    OVERVIEW OF THE HAZARDOUS ORGANIC NESHAP	  -3
       2.1     Subpart F	  -3
       2.2    Subpart G	  -3
       2.3    Subpart H	  -7
       2.4    Subpart I	  -8
       2.5    General Reporting  	  -8
              2.5.1   Initial Notification	  -8
              2.5.2   Implementation Plan	  -9
              2.5.3   Notification Of Compliance Status	  -9
              2.5.4   Periodic Reports 	  1-10
              2.5.5   Other Reports 	  1-10
       2.6    Use Of Continuous Monitoring To Determine Compliance  	  1-10

3.0    APPLICABILITY OF THE RULE	  1-12
       3.1    Identification Of Socmi Process Units 	  1-12
       3.2    Determination Of The Hon Source	  1-13
       3.3    Determination Of New Source Vs. Existing Source	  1-14
              3.3.1   New Sources	  1-14
              3.3.2   Existing Sources	  1-15
              3.3.3   Other Process Changes 	  1-15
              3.3.4   Compliance Dates	  1-16

4.0    GENERAL PROVISIONS APPLICABLE TO THE HON	  1-18
       4.1    Applicability and Definitions 	  1-18
       4.2    Prohibited Activities and Circumvention	  1-18
       4.3    Construction and Reconstruction	  1-19
       4.4    Compliance with Standards and Maintenance Requirements	  1-19
       4.5    Performance Testing Requirements	  I-20
       4.6    Monitoring Requirements	  I-20
       4.7    Notification Requirements  	 1-21
       4.8    Recordkeeping and Reporting Requirements  	 1-21
       4.9    Control Device Requirements  	 I-22
       4.10   Availability of Information and Confidentiality	 I-22

 5.0    DESCRIPTION OF EMISSION POINT	 I-23
       5.1    Process Vents 	 '-23
       5.2    Transfer Operations	 I-25
       5.3    Storage Vessels	 I-25
              5.3.1   Fixed-Roof Storage Vessel	 I-30
              5.3.2  Floating Roof Storage Vessel	 1-31
                                            IV
                                                                               September 1997

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Volume I & II
Section
                                                                                           Page
                      5.3.2.1  External Floating Roof Vessel  	 l_32
                      5.3.2.2  Internal Floating Roof Vessel	 l_32
                      5.3.2.3  External Floating Roof Vessel Converted to an Internal Floating
                              Roof Vessel  	 l_33
        5.4     Wastewater 	         l_33
               5.4.1   Individual Drain Systems	[[[ l_35
               5.4.2   Manholes	!!!!!! I-35
               5.4.3   Trenches	      l_3g
               5.4.4   Sumps	      l_3g
               5.4.5   Junction Boxes  	          l_3g
               5.4.6   Lift Stations	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'" I-36
               5.4.7   Weirs	       l_3g
               5.4.8   Oil-Water Separators	 (.37
               5.4.9   Equalization Basins	    (.37
               5.4.10  Treatment Tanks	 l_37
               5.4.11  Biological Treatment Basins  	       l_37
               5.4.12  Clarifiers  	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'. I-37
               5.4.13  Surface Impoundments	'.'.'.'.'. I-38
               5.4.14  Containers	        l_33
        5.5     References	        ^_3g

6       Description Of Emission Control Technologies	      (.39
        6.1     Combustion Control Devices  	     l_39
               6.1.1   Thermal Incinerators	 l_40
               6.1.2   Catalytic Incinerators	"' ] (.4-1
               6.1.3   Industrial Boilers And Process Heaters	[\\[ I-42
               6.1.4   Flares   	      l_42
               6.1.5   Halogenated Streams	                l_44
        6.2     Product Recovery And Recapture Devices 	 I-44
               6.2.1   Condensers	       l_44
               6.2.2   Adsorption	        l_45
               6.2.3   Absorption	."_               (.45
        6.3     Control Techniques Specific To Transfer Operations	[ 1.43
               6.3.1   Vapor Collection System	,                1.43
               6.3.2   Vapor Balancing  	     l_49
               6.3.3   Route To A Process Or Fuel Gas System  	"....'.'.'.'.'.'.'.'.'. 1-51
        6.4     Control Techniques Specific To Storage Vessels	'.'.'.'.'.'. 1-51
               6.4.1   Fixed-roof Vessels 	'.'.'.'.'.'.'.'. 1-51
               6.4.2   Floating Roof Vessels	'.'.'.'.'.'. 1-51
               6.4.3   Route To A Process Or Fuel Gas System  	'" \ 1.52
        6.5     Control Techniques Specific To Wastewater	   1-52
                                                                                    September 1997

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Volume I & II
                                                  Inspection Tool for the Hazardous Organic NESHAP (HON)
Section
                                     TABLE OF CONTENTS
                                     VOLUME I (Continued)
                        OVERVIEW OF EMISSION POINTS, CONTROL
                          TECHNOLOGIES, AND HON PROVISIONS
                                                                                       Page
               6.5.1   Waste Management Units	 I-52
                      6.5.1.1  Controls For Process Drains 	 '-53
                      6.5.1.2 Controls For Junction Boxes, Manholes, Trenches, Weirs, Sumps,
                             And Lift Stations	 I-53
                      6.5.1.3 Controls For Wastewater Tanks And Oil-water Separators	 I-56
                      6.5.1.4 Containers 	 !-57
               6.5.2   Treatment Processes  	 I"57
                      6.5.2.1 Steam Stripping 	 I-57
                      6.5.2.2 Biological Treatment	 '-59
               6.6     References 	 !-60

 7      The Provisions	 '"61
        7.1     Process Vent Provisions	 I"61
               7.1.1   Process Vent Definition	 I'61
               7.1.2   Process Vent Group Determination  	 1-61
               7.1.3   Process Vent Control Requirements	 I-62
               7.1.4   Process Vent Testing, Monitoring, Recordkeeping, And Reporting 	 I-63
        7.2    Transfer Operations Provisions	 l"7^
               7.2.1   Transfer Operations Definition   	 !-76
               7.2.2   Transfer Operations Group Determination 	 l-76
               7.2.3   Transfer Operation Control Requirements 	 I-77
               7.2.4   Transfer Operations Testing, Monitoring, Recordkeeping, And Reporting ... I-78
        7.3    Storage Vessel Provisions	 I"82
               7.3.1   Storage Vessel Definition 	• • • • •  '-89
               7.3.2   Storage Vessel Group Determination	  1-89
               7.3.3   Storage Vessel Control Requirements  	  I-89
               7.3.4   Storage Vessel Testing, Monitoring, Recordkeeping, And Reporting	  I-90
        7.4    Wastewater Provisions	  '"98
               7.4.1   Wastewater Definition	  '-98
               7.4.2   Sourcewide 1 Mg/yr Exemption	 1-104
               7.4.3   Process Wastewater Group Determination	 1-104
               7.4.4   Process Wastewater Control Requirements	 1-105
                      7.4.4.1 Waste Management Units 	 1-105
                      7.4.4.2 Treatment Processes	 1-109
                      7.4.4.3 Closed-vent Systems And Control Devices	 1-113
                      7.4.4.4 Residuals Management	 1-113
               7.4.5  Process Wastewater Testing, Monitoring, Recordkeeping And Reporting .. 1-114
               7.4.6  Process Water Control Requirements	 1-114
               7.4.7  Heat Exchange Systems And Cooling  Water Management Requirements  . M22
               7.4.8  Maintenance Wastewater Management Requirements  	 1-124
                                              VI
                                                                                   September 1997

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Volume I & I!
                                 LIST OF TABLES'
                                              _
                    OVERVIEW OF EMISSION   iNTS. COi
                                                                      Page

2-1    ORGANIZATION OF HON  	 ,.4

3-1    COMPLIANCE DATES FOR EXISTING, NEW, AND RECONSTRUCTED SOURCES	 1-17

5-1    COMMON COMPONENTS OF WASTEWATER COLLECTION SYSTEMS
      AND TREATMENT PROCESSES  	 l_35

7-1    PROCESS VENTS INITIAL PERFORMANCE TEST AND RECORDKEEPING AND
      REPORTING FOR COMPLIANCE DETERMINATION	 I-64

7-2    INITIAL GROUP DETERMINATION AND RECORDKEEPING AND REPORTING
      REQUIREMENTS FOR GROUP 2 PROCESS VENTS 	 |_67

7-3    MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS
      VENTS COMPLYING WITH 98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A
      LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE	 I-69

7-4    MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS
      VENTS MAINTAINING A TRE INDEX VALUE >1.0 AND <;4.0	 1-73

7-5    TRANSFER RACK INITIAL PERFORMANCE TEST AND RECORDKEEPING AND
      REPORTING FOR COMPLIANCE DETERMINATION	 (.79

7-6    MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR TRANSFER
      OPERATIONS COMPLYING WITH 98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A
      LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE	 1-83

7-7    PERIODIC INSPECTION, MEASUREMENT, RECORDKEEPING, AND REPORTING
      REQUIREMENTS FOR STORAGE VESSELS EQUIPPED WITH AN INTERNAL FLOATING
      ROOF VESSEL, AN EXTERNAL FLOATING ROOF, OR AN EXTERNAL FLOATING ROOF
      VESSEL CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL 	 1-91

7-8    PERIODIC AND CONTINUOUS MONITORING, INSPECTION, RECORDKEEPING AND
      REPORTING REQUIREMENTS FOR STORAGE VESSELS EQUIPPED WITH A CLOSED
      VENT SYSTEM AND CONTROL DEVICE	 |.99

7-9    WASTEWATER TANK EMISSION CONTROL REQUIREMENTS	  1-106

7-10   CONTAINER EMISSION CONTROL REQUIREMENTS 	  1-108

7-11   PROCESS WASTEWATER COMPLIANCE OPTIONS FOR NEW SOURCES	  1-111
                                   vn
                                                                 September 1997

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Volume I & II
Inspection Tool for the Hazardous Organic NESHAP (HON)
Table
                           LIST OF TABLES (Continued)
                                   VOLUME I
                    OVERVIEW OF EMISSION POINTS, CONTROL
                     TECHNOLOGIES, AND HON PROVISIONS
                                                                      Page
7-12   PROCESS WASTEWATER COMPLIANCE OPTIONS FOR EXISTING SOURCES	 1-112

7-13   INSPECTION AND MONITORING REQUIREMENTS FOR WASTE MANAGEMENT
      UNITS	 '-115

7-14   MONITORING REQUIREMENTS FOR TREATMENT PROCESSES 	 1-117

7-15   MONITORING REQUIREMENTS FOR CONTROL DEVICES	 1-118

7-16   PERIODIC REPORTING REQUIREMENTS FOR CONTROL DEVICES USED TO COMPLY
      WITH §§63.133-63.139	 '-120

7-17   CONTROL REQUIREMENTS FOR ITEMS OF EQUIPMENT THAT MEET THE
      CRITERIA OF §63.149 OF SUBPART G	-	 1-123
                                     Vlll
                                                                  September 1997

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 Volume I & I
 Figure



 5-1


 5-2



 5-3



 5-4


 5-5


 5-6


 5-7


 5-8


 5-9


 5-10


 5-11


 6-1


 6-2


 6-3


 6-4


 6-5


 6-6


 6-7


6-8


6-9
 Examples of Reactor-related Vents	                   l_24
 Potential VOC and HAP Emission Points for an Atmospheric (Nonvacuum) Distillation
 Column 	
                                                                                   I-26
 Potential VOC and HAP Emission Points for a Vacuum Distillation Column
 Using a Vacuum Pump	              l_27


 Submerged Fill Pipe  	                   l_28


 Bottom Loading	                          , 2o


 Tank Truck Bottom Loading	              l_2g


 Tank Truck Top Loading	                     ,3Q


 Fixed Roof Tank with Closed-Vent System and Control Device	 I-30

 Floating Roof Tank	                    l_31


 External Floating Roof Tank  	                  (_32


 Internal Floating Roof Tank	                  ,_33


 Discrete Burner, Thermal Incinerator  	         l_40


 Catalytic Incinerator	                            ,_41


 Steam-Assisted Elevated Flare System  	               l_43


 Schematic Diagram of a Shell and Tube Surface Condenser	     l_44


 Two-Stage Regenerative Adsorption System	             l_46


 Packed Tower Absorption Process	                 l_47


Tank Truck Loading with Vapor Recovery  	              l^.8


Dual Arm Loading Rack	                 l_4g


Vapor Balancing System	                       1.50
                                                                                  September 1997

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                                                                                       I
Volume I & II
                                          Inspection Tool for the Hazardous Organic NESHAP (HON)
                           LIST OF FIGURES (Continued)
                                     VOLUME I
                    OVERVIEW OF EMISSION POINTS, CONTROL
                      TECHNOLOGIES, AND HON PROVISIONS
Figure
                                                                          Page
6-10  Types of Drains	 '"54

6-11  Closed Drain System	 '"55

6-12  Drain System Junction Box	 ''56

6-13  Continuous Steam Stripper System  	 '-58
                                        x
                                                                      September 1997

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 Volume I & II
Section
1.0    How to Use the Checklists
2.0
                                                                                          Page
                                                                                         ..11-1
        Preparing for the Inspection 	                |(_3
 3.0    Applicability of the HON  	                    ,,_5
 4.0    Emission Point Applicability and Assignment of Emission Points to the Chemical
        Manufacturing Process Units  	                    U_11
 5.0    Process Vents	
                                                                                          II-26
6.0
7.0
8.0
        Transfer Operations	                             ..
        Storage Vessels  	
        Wastewater	
                                                                                         II-37
                                                                                         11-61
 9.0     Closed-Vent Systems and Control Equipment Requiring Leak Detection	H-86
 10.0    Control Device and Recovery Device Checklists 	           H.91
 11.0    Compliance Timeline and Reporting Checklists  	     H_118

APPENDICES
Appendix A:    Code of Federal Regulations Citations
Appendix B:    Comparison of HON Process Vent Provisions with Distillation, Air Oxidation, and Reactors
               NSrO
Appendix C:    Example Calculation of TRE Index Value
Appendix D:    Information on Wastewater to be Submitted with Notification of Compliance Status
Appendix E:    Conversion Factors
                                                                                   September 1997

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                                           Inspection Tool for the Hazardous Organic NESHAP (HON)
                                 LIST OF TABLES
                                     VOLUME II
                             INSPECTION CHECKLIST
Table

3-1

3-2

3-3

3-4

3-5

4-1

4-2

4-3

4-4

4-5

4-6

4-7

 4-8

 4-9

 4-10

 4-11

 4-12

 5-1

 5-2

 5-3

 6-1

 6-2
Applicability of the HON  [[[ "-5

Determination of Primary Product and Applicability for Flexible Operation Units  ............ II-7

Determination of the Primary Product ............................................. "-8

Determination of Applicability of Existing and New Source Requirements ................. H-9

Identification of CMPU's Subject to the HON ...................................... IMO

Applicability Checklistfor Process Vents  ......................................... IM2

Assignment of Distillation Units ................................................. ""1 3

Identification of Process Vents Subject to the Hon .................................. "-15

Applicability Checklist for Transfer Operations  ..................................... H"16

 Assignment of Transfer Racks ................................................. l1"17

 Identification of Transfer Racks, Loading Arms, or Loading Hoses Subject to the Hon ...... 11-18

 Applicability Checklist for Storage Vessels  ........................................ U'19

 Assignment of Storage Vessels ................................................ ll'20

 Identification of Storage Vessels Subject To the Hon  ............................... H-22

 Applicability Checklistfor Process and Maintenance Wastewater  ...................... N-23

 Applicability Checklistfor Equipment Handling Process Water ......................... H-24

 Identification of Process and Maintenance Wastewater Streams Subject to the Hon ........ II-25

 Group Determination Checklist for Process Vents  .................................. H-27

 Roadmap to the Checklists for Group 1 Process Vents .............................. H-28
  Group 2 Process Vents
                                                                                   "~30
  Group Determination Checklist for Transfer Operations	"-32

  Roadmap to the Checklists for Group 1 Transfer Racks	"-33
                                        xu

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 Volume I & II
 Table

 6-3

 6-4

 7-1

 7-2

 7-3

 7-4

 7-5

 7-6


 7-7


 7-8


 8-1

 8-2

 8-3

 8-4

 8-5

 8-6

8-7

9-1


9-2
                                                                                  Page

 Group 1 and Group 2 Transfer Racks	                                             n oc
                                             	ll-OO

 Routing the Emissions from a Group 1 Transfer Rack to a Process or Fuel Gas System	li-36

 Group Determination Checklist for Storage Vessels	             H_38

 Roadmap to the Checklists for Group 1 Storage Vessels   	         H_40

 Group 1 and Group 2 Storage Vessels	                 H_41

 Compliance Checklist for Group 1 Storage Vessels with External Floating Roofs	||-42

 Compliance Checklist for Group 1 Storage Vessels with Internal Floating Roofs	||-48

 Compliance Checklist for Group 1 Storage Vessels with an External Floating Roof
 Converted To an Internal Floating Roof 	              ^
Compliance Checklist for Group 1 Storage Vessels Equipped with a Closed-vent
System and Control Device	
                                                                                   I-58
Compliance Checklist for Group 1 Storage Vessel Emissions Routed to a
Process or Fuel Gas System  	                  U_60

Group Determination Check for Process Wastewater Streams	H_62

Roadmap for the Checklists for Waste Management Units	   H_63

Compliance Checklist for Waste Management Units  	  H_67

Compliance Checklist for Treatment Processes	              H_74

Compliance Checklist for Heat Exchange Systems Requiring Leak Detection	||-78

Roadmap to the  Checklist for Items of Equipment Handling In-Process Liquid Streams	11-81

Compliance Checklist for Items of Equipment Handling In-Process Liquid Streams  	II-85

Compliance Checklist for Bypass Provisions for Vent, Closed-Vent,
Vapor Collection, and Vapor Balancing Systems 	'.	     n_87

Compliance Checklist for Closed-Vent, Vapor Collection, And Vapor Balancing
Systems, and Covers, Enclosures, And Fixed Roofs	       H_8g
                                             xui
                                                                                  September 1997

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Volume I & II
                                                  Inspection Tool for the Hazardous Organic NESHAP (HON)
                                 LIST OF TABLES (Continued)
                                            VOLUME II
                                    INSPECTION CHECKLIST
Table

10-1   Compliance Checklist for Flares	H-92

10-2   Compliance Checklist for Thermal Incinerators	H-93

10-3   Compliance Checklist for Catalytic Incinerators 	H-96
 10-4    Compliance Checklist for a Boiler or Process Heater With a Design Heat Input
        Capacity less than 44 Megawatts and the Vent Stream Is Not Introduced with
        the Primary Fuel  	
II-99
 10-5   Compliance Checklist for a Boiler or Process Heater with a Design Heat Input
        Capacity Greater than 44 Megawatts 	11-102

 10-6   Compliance Checklist for a Carbon Adsorber Used as a Control or Recovery Device	11-103

 10-7   Compliance Checklist for an Absorber Used as a Control or Recovery Device	11-106

 10-8   Compliance Checklist for a Condenser Used as a Control or Recovery Device	11-109

 10-9   Compliance Checklist for a Control or Recovery Device Not Specifically Listed  	11-112

 10-10  Compliance Checklist for Combusted Halogenated Vent Streams Using a Scrubber  	11-115

 11-1   Checklist for the Initial Notification   	

 11-2   Checklistfor Implementation Data   	

 11-3   Checklist for the Notification of Compliance Status	

 11-4   Checklist for Periodic Reports	"-128

 11-5   Checklistfor a Request of Compliance Extension 	H-131

 11-6   Checklist for Request to Use Alternative Monitoring or Recordkeeping Procedures  	11-132

 11-7   Checklist for Start-up, Shutdown and Malfunction Plan  	H-134

 11-8   Checklistfor Start-up, Shutdown and Malfunction Reports	 11-135

 11-9   Checklistfor Initial Notifications by New or Reconstructed Major Affected Sources	11-136

 11-10 Checklist for Source Construction and Reconstruction Permit Applications	11-137
                                              xiv
                                                                                   September 1997

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Volume I &
                                             Inspection Tool for the Hazardous Organic NESHAP (HON)
                                   LIST OF FIGURES

                                       VOLUME II    .


                                INSPECTION CHECKLlSfliii
                               ___j	,      ;i.  ••"^•"irrniHiHHf
Figure



11-1   HON Compliance Timeline
Page



11-119
                                        xv
                                                                         September 1997

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Volume I
                                          Overview of Emission Points. Control Technologies, and HON Provisions
       IthJnrinSH f Ctihn t0°lJS consistent with the Promulgated hazardous organic national emission
       standard for hazardous air pollutants (hazardous organic NESHAP, or HON) The final rule was

       K?FR ooioS8 ^t6'3.' ReqlSter °" April 22' 1"4 (59 FR 19402) and June 6, 1994
       (59 FR 29196) with final revisions published on September 20, 1994 (59 FR 48175); January 27,

           i (61 FR 31435), December 5, 1996 (61 FR 64572), and January 17, 1997 ^F^"^!)20'

       Section 112 of the Clean Air Act directed the U. S. Environmental Protection Agency (EPA) to set
       national emission standards for hazardous air pollutants (NESHAP). Section 112(b) lists 188
       hazardous fr poliutants (HAP's). Section 112 also required the EPA to publish a Hst of categories
       of sources that emit HAP's and to develop regulations for these source categories The synthette
       oraamc chem,ca| manufacturing industry (SOCMI) was subsequently listed as a souroe^category
      The hazardous organic NESHAP (HON) regulates emissions of 111 of the 188 listed organic

      ^ni/rJ   THCML '? fditi0n'the H°N alS° "StS 21 specific """Pounds that are poTycyclic
      organic matter. The regulation can be found in the Code of Federal Regulations (40 CFR Part 63)
      in Subparts F, G, and H. Subpart F contains provisions for determininglpplicabiS/ of the HON^
      definitions, and general procedures for testing, compliance, reporting, Ld recordkeeping The
      specific control monitoring, reporting, and recordkeeping requirements are stated in Subpart G for
      process vents transfer operations, storage vessels, and wastewater streams, and in Subpart H
      for equipment leak emissions. Subpart I provides the applicability criteria for non-SOCMI
       r°eS             the neg°tiated regulation for ^"ipment leaks and requires compliance with
                                        Volume I. Overview of -Emission Points, Control Terhn,
                                        ProviBinas
gje
                                          LHQH
 The purpose of this document is
 to assist federal, state, and local
 regulatory personnel with
 enforcement of the process vent,
 transfer operation, storage
 vessel, and wastewater
 provisions of Subpart G. The
 emissions averaging provisions of
 Subpart G and the equipment
 leak provisions of Subpart H are
 not included. For equipment
 leaks, refer to Inspection Manual:
 Federal Equipment Leak Regulations for the Chemical Manufacturing Industry (EPA-305-B-96-
 005)  Because the process vents provisions of the HON are similar to new source performance
 standards (NSPS) for SOCMI air oxidation reactors and distillation operations, this ScSSl
 also be useful for enforcement of those NSPS. While this document does not describe the NSPS
ihe NSPS3" ^^             ^ differences between the HON P™** vents provisions and
                                        1.0
                                        2.0
                                        3.0
                                        4.0
                                        5.0
                                        6,0
Background and Purpose of This Document	           yt
Overview of the HON  	               	  I
Applicability of tee Rute. .,...„.._"""	""""Viz
General Provisions Applicable to the HON  ..!	MS
Description of Emission Point	.,,.,,     ""''"
Description of Emission Control Technologies'
The Prqyis.ior)5
                     °rganized in *»° volumes- Volu™ I Contains descriptions of the background
                on em,ss,on points and control technologies. These descriptions cover process vents,
                                                                                 September 1997

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                                   Overview of Emission Points, Control Technologies, and HON Provisions
                                   •••^i^^i^^*^*^

transfer operations, storage vessels, and wastewater provisions.  Within Volume I, there are
sections on an overview of the HON, applicability of the rule, descriptions of emission points,
descriptions of emission control technologies, and descriptions of the relevant provisions.
Volume II contains checklists to assist the inspector during the actual inspection.

Five appendices are included in this document. Appendix A lists Code of Federal Regulations
citations for the HON, the NESHAP General Provisions, test methods required by the HON, and
the air oxidation and distillation NSPS. This will allow inspectors to easily locate the complete text
of these rules  Appendix B contains a comparison of the HON process vents provisions with
those in the NSPS for distillation, air oxidation, and reactors. Appendix C illustrates the
calculation of total resource effectiveness (TRE) index value for process vents. The TRE index
value is used to determine whether process vent emissions must be controlled.  Appendix  D lists
the information on wastewater that must be reported in the Notification of Compliance Status.
Appendix E has a conversion table for all exemptions, cutoffs, and other numbers referenced in
the rule.  The table gives english units for all of these values.
                                                                                 September 1997

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Volume I
                          2.0 OVERVIEW OF THf
                                     ORGANIC NESI
        The HON regulates emissions from five kinds of emission points at SOCMI sources: (1) process
        vents, (2) transfer operations, (3) storage vessels, (4) air emissions from wastewater streams and
        wastewater collection and treatment operations, and (5) equipment leaks. The organization of the
        regulation is shown in Table 2-1.
2.1  SUBPARTF
        Section 63.100 contains provisions to determine which chemical manufacturing processes at a
        plant are subject to the HON. Table 1 of Subpart F contains a list of SOCMI chemicals, and
        Table 2 of Subpart F contains a list of organic HAP's regulated by the HON.  In general, if a
        process both (1) produces one of the listed SOCMI chemicals and (2) either uses as a reactant or
        produces a listed organic HAP in
        the process, then that process is
        subject to the HON. Section 63.100
        contains additional details for
        determining applicability in
        situations where a process makes
        multiple products. If a  chemical
        manufacturing process is subject to
        the HON, then the emission points
        associated with that process are
        regulated. Details on how to
        determine which storage vessels,
        transfer racks, and distillation units
        are part of a chemical
        manufacturing process are also
        contained in §63.100.
Section 2.Q Overview of the Hazardous nmanfo MPSHAP
2.1
2.2
2,3
2.4
2.5
2.6
Subpart F ,,.<., + .->..,,<<.,,,..,,, + , , v (> , , , „

SubpartH ...,..*,..,.,., 	 f,.. .
Subp&rti 	 ,.„ 	 ^ 	
Generaf Reporting , 	
2,5.1 initial Notification 	 	
2,5.2 implementation Plan , , . . , 	
2,5.3 Notification Of Compliance Status
2.5.4 Periodic Reports ..>.„,,„,,.« 4 ., + < t ,
2f5.& Other Reports . + ,.,..,>,,...,>..,,, + .,,. H . , + y t ,
Use Of Continuous Monitoring To Determine Compliance . , , ,
< !-$
f-S
1"7

* ( B
E-B

[ 9
MO
MO
MO
       Definitions of terms used in Subparts F, G, and H are contained in §63.101. Sections 63.102 and
       63.103 contain general standards, compliance, recordkeeping, and reporting provisions and
       override certain portions of the NESHAP General Provisions (40 CFR 63, Subpart A). These
       sections specify general performance test conditions, require records to be maintained for
       5 years, and clarify where reports required under Subparts G and H are to be sent.
       Section 63.104 contains requirements for heat exchange systems and §63.105 contains
       requirements for maintenance wastewater.

2.2    SUBPART G

       Subpart G contains the standard for process vents, transfer operations, storage vessels, and
       wastewater. It includes emissions averaging provisions. The first section of Subpart G (§63.110)
       contains applicability provisions that clarify potential overlaps between the HON and other
       subparts that regulate process vents, transfer operations, storage vessels, wastewater, and
       equipment leaks. The second section (§63.111) contains definitions.

       Section 63.112 provides an equation representing a site-specific allowable overall emission limit
       for each source. The "source" is the combination of all emission points subject to the HON at a
                                                 1-3
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Volume I
                                          Overview of Emission Points, Control Technologies, and HON Provisions
                                 TABLE 2-1. ORGANIZATION OF HON
         Section
         Number3
                              Title of Section
         Subpart F - National Emission Standards for Organic Hazardous Air Pollutants from the
         Synthetic Organic Chemical Manufacturing Industry
          63.100    Applicability and designation of source.
          63.101    Definitions.
          63.102    General standards.
          63.103    General compliance, reporting, and recordkeeping provisions.
          63.104    Heat exchange system requirements.
          63.105    Maintenance wastewater requirements.
          63.106    Delegation of authority.
         Subpart G - National Emission Standards for Organic Hazardous Air Pollutants from
         Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels,
         Transfer Operations,  and Wastewater.
          63.110
          63.111
          63.112
          63.113
          63.114
          63.115

          63.116

          63.117

          63.118
          63.119
          63.120
          63.121
          63.122
          63.123
          63.124
          63.125
          63.126
          63.127
          63.128
          63.129

          63.130
Applicability.
Definitions.
Emission standard.
Process vent provisions.
Process vent provisions - monitoring requirements.
Process vent provisions - methods and procedures for process vent group
determination.
Process vent provisions - performance test methods and procedures to determine
compliance.
Process vents provisions - reporting and recordkeeping requirements for group
and TRE determinations and performance tests.
Process vents provisions - periodic reporting and recordkeeping requirements.
Storage vessel provisions - reference control.
Storage vessel provisions - procedures to determine compliance.
Storage vessel provisions - alternative means of emission limitation.
Storage vessel provisions - reporting.
Storage vessel provisions - recordkeeping.
Reserved.
Reserved.
Transfer operations provisions - reference control technology.
Transfer operations provisions - monitoring requirements.
Transfer operations provisions - test methods and procedures.
Transfer operations provisions - reporting and recordkeeping for performance tests
and notification of compliance status.
Transfer operations provisions - periodic recordkeeping and reporting.
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                                          Overview of Emission Points. Control Technologies, and HON Provisions
                             TABLE 2-1. ORGANIZATION OF HON
          63.131
          63.132
          63.133
          63.134
          63.135
          63.136
          63.137
          63.138


          63.139
         63.140
         63.141
         63.142
         63.143
         63.144


         63.145

         63.146
         63.147
         63.148
         63.149

         63.150
         63.151
         63.152
       Subpart H
       Equipment
        63.160
        63.161
        63.162
        63.163
        63.164
        63.165
        63.166
  Reserved.
  Process wastewater provisions - general.
  Process wastewater provisions - wastewater tanks.
  Process wastewater provisions - surface impoundments.
  Process wastewater provisions - containers.
  Process wastewater provisions - individual drain systems.
  Process wastewater provisions - oil-water separators.
  Process wastewater provisions - (performance standards for treatment processes
  managing Group 1 wastewater streams and/or residuals removed from Group 1
  wastewater streams).                                                 M
  Process wastewater provisions - control devices.
  Process wastewater provisions - delay of repair.
  Reserved.
  Reserved.
  Process wastewater provisions - inspections and monitoring of operations.
  Process wastewater provisions - test methods and procedures for applicability and
  Group I/Group 2 determinations (determining which wastewater streams require
  control^.
  Process wastewater provisions - test methods and procedures to determine
 compliance.
 Process wastewater provisions - reporting.
 Process wastewater provisions - recordkeeping.
 Leak inspection provisions.
 Emissions averaging provisions.
 Initial Notification.
 General reporting and continuous records.
•- National Emission Standards for Organic Hazardous Air Pollutants for
 LG3KS.
 Applicability and designation of sources.
 Definitions.
 Standards: General.
 Standards: Pumps in light liquid service.
 Standards: Compressors.
 Standards: Pressure relief devices in gas/vapor service.
 Standards: Sampling connection systems.
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                                  Overview of Emission Points. Control Technologies, and HON Provisions
                     TABLE 2-1. ORGANIZATION OF HON
 Section
 Number3
•MH^l»^—"^
  63.167
  63.168
  63.169
                                        Title of Section
          Standards: Open-ended valves or lines.
          Standards: Valves in gas/vapor service and in light liquid service.
          Standards: Pumps, valves, connectors, and agitators in heavy liquid service;
          instrumentation systems; and pressure relief devices in liquid service.
63.170    Standards: Surge control vessels and bottoms receivers.
63.171    Standards: Delay of repair.
63.172    Standards: Closed-vent systems and control devices.
63.173    Standards: Agitators in gas/vapor service and in light liquid service.
63.174    Standards: Connectors in gas/vapor service and in light liquid service.
63.175    Quality improvement program for valves.
63.176    Quality improvement program for pumps.
63.177   Alternative means of emission limitation:  General.
63.178   Alternative means of emission limitation:  Batch  processes.
 63.179    Alternative means of emission limitation:  Enclosed-vented process units.
 63.180    Test methods and procedures.
 63.181    Recordkeeping requirements.
 63.182    Reporting requirements.
Subpart I -- National Emission Standards for Organic Hazardous Air Pollutants for
Certain  Processes Subject to the Negotiated Regulation for Equipment Leaks.
   63.190
   63.191
   63.192
   63.193
           Applicability and designation of source.
           Definitions.
           Standard.
           Delegation of Authority.
 a Section numbers of 40 CFR Part 63.
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Volume I                                     Overview of Emission Points. Control Technologies, and HON Provisions


        plant site (contiguous area under common control).  The standard requires sources to meet the
        allowable emission limit; however, the equation in §63.112 is not used to determine compliance
        with the standard, and source owners or operators are not required to calculate their allowable
        emission limit. As provided in §63.112(c), the owner or operator of an existing source must
        demonstrate compliance using one of two approaches:  the  point-by-point compliance approach
        or the emissions averaging approach.  As provided in §63.112(d), the owner or operator of a new
        source must demonstrate compliance using the point-by-point approach.  Emissions averaging is
        not allowed for new sources.

        Under the point-by-point approach, the owner or operator would apply control to each "Group 1"
        emission point. A Group 1 emission point is a  point which meets the control applicability criteria,
        and the owner or operator must reduce emissions to specified levels; whereas a Group 2
        emission point is one that does not meet the criteria  and no  emission reduction is required. These
        Group 1  and Group 2 emission points are defined in §63.111.  Owners or operators selecting the
        point-by-point compliance approach must comply with the process vent provisions in §63.113
        through §63.118, the storage vessel provisions in §63.119 through §63.123, the transfer operation
        provisions in §63.126 through §63.130, and the wastewater  provisions in §63.132 through
        §63.149. These sections include applicability criteria, emission limits, equipment and work
        practice standards, testing, monitoring, recordkeeping, and reporting provisions. The specific
        criteria for Group 1/Group 2 determinations and required control levels for process vents, transfer
        operations, storage vessels, and wastewater streams are  listed in Section 7 of this volume.

        Under the emissions averaging approach, an owner or operator may elect to control different
        groups of emission points within the source to different levels than specified in §63.113 through
        §63.147  and §63.149, as long as the overall emissions do not  exceed the overall allowable
        emission level.  An owner or operator can choose not to control a Group 1 emission point (or to
        control the emission point with a less effective control technique) if the owner or operator over-
        controls another emission point within the source. Emission "debits" (in Mg of HAP emissions) are
        generated for each Group  1 emission point that is uncontrolled or under-controlled. Emission
        "credits"  (also in Mg) are generated for over-controlled points.  Credits can be generated if a
        Group 2  point is controlled, or if a Group 1 point is controlled by a distinct technology that EPA
        approves as having a greater efficiency than the level of control required for Group 1 points.
        Credits have to equal or exceed debits for a source to be in compliance. Section 63.150 of the
        rule contains additional emission averaging requirements  and detailed equations for calculating
        debits and credits. The preamble of the final rule (April 22,1994, 59 FR 19402) describes, in more
        detail, the emissions averaging requirements.

2.3  SUBPARTH

        Subpart H contains the standard for equipment leaks. Equipment regulated includes pumps,
        compressors, agitators, pressure relief devices, sampling  connection systems, open-ended valves
        or lines, valves, connectors, surge control vessels, bottoms receivers, and instrumentation
        systems  in organic HAP service. A piece of equipment  is  in  organic HAP service if it contains or
        contacts a fluid that is at least 5 percent organic HAP by weight.  The applicability of Subpart H
        and definitions are contained in §63.160 and §63.161, respectively.  Sections 63.162 through
        63.179 contain the standards for the various kinds of equipment and alternative means of
        emission limitation. These include leak detection and repair provisions and other control
        requirements. Sections 63.180 through 63.182 contain  test methods and procedures, and
        reporting and recordkeeping provisions.
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Volume I                          	Overview of Emission Points, Control Technologies, and HON Provisions
2.4 SUBPART I

        Subpart 1 provides the applicability criteria for the non-SOCMI processes subject to the negotiated
        regulation for equipment leaks. Regulated equipment is the same as that for Subpart H: pumps,
        compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves
        or lines, valves, connectors, surge control vessels, bottoms receivers, and instrumentation
        systems in organic HAP service. The applicability criteria for Subpart I and the definitions are
        specified in §63.190 and §63.191,  respectively.  Section 63.192 contains the standard which
        requires compliance with Subpart H.

2.5 GENERAL REPORTING

        Sections 63.151 (Initial Notification) and 63.152 (General Reporting) of Subpart G require sources
        to submit the following five types of reports:

               1.      Initial Notification,
               2.      Implementation Plan (for new sources if an operating permit application has not
                       been submitted),
               3.      Notification of Compliance Status,
               4.      Periodic Reports,  and
               5.      other reports.

        Sources subject to the HON are also subject to the NESHAP General Provisions (40 CFR Part 63
        Subpart A), which include additional reporting requirements. Table 3 of Subpart F of the HON
        identifies which parts of the General Provisions apply to HON sources and Section 4 of this report
        outlines the requirements of the General Provisions as they apply to the HON.

        Records of reported  information and other information necessary to document compliance with
        the regulation are required to be kept for 5 years. A few records pertaining to equipment design
        would be kept for the life of the equipment.

2.5.1  Initial Notification

        The purpose of the Initial Notification is to establish an early dialogue between the source and the
        regulatory agency, allowing both to plan for compliance activities.  The notice is due August 20,
        1994 for existing sources.  For a new source with an initial startup on or after July 21,1994, the
        application for approval of construction or reconstruction required by §63.5(d) of subpart A must
        be submitted instead of the Initial Notification.  This application is due as soon as practicable
        before commencement of construction or reconstruction but no earlier than July 21,1994.

        For a new source with an initial startup before July 21,1994, the Initial Notification is due on
        July 21,1994 but the application described in §63.5(d) of subpart A is not required.

        The notification must list the chemical manufacturing processes at the source that are subject to
        Subpart G, and which provisions-may apply (e.g., process vents, transfer operations, storage
        vessel, and/or wastewater provisions).  A detailed identification of emission points is not required.
        The Initial Notification must include a statement of whether the source can achieve compliance by
        the specified compliance date, but a request for a compliance extension may be submitted later
        (by 120 days before the compliance date - see Section 3.3.4 for a description of the compliance
                                                  T R
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        dates). Section 11 of Volume II of this document has a checklist of items required in the Initial
        Notification.

2.5.2 Implementation Plan

        The Implementation Plan details how the source plans to comply with Subpart G. The plan
        identifies Group 1 and Group 2 emission points, and specifies the control technique that will be
        applied to each Group 1 emission point.  Implementation Plans are only required for new sources
        that have not submitted an operating permit application or for emission points to be included in an
        emissions average. An operating permit application would contain all of the information required
        in the Implementation Plan, therefore, it would be redundant to require sources to submit both.

        For points included in emission averages, existing sources must submit the Implementation Plan
        18 months prior to the compliance date;  for emission points not included in an emissions average
       the Implementation Plan is due 12 months prior to the compliance date. For a new source with an
       initial startup on or after July 21,1994, the Implementation Plan must be submitted with the
       application for approval of construction or reconstruction (i.e., as soon as practical before
       commencement of construction or reconstruction but no earlier than July 21,1994).

       For a new source with an initial startup before July 21,1994, the Implementation Plan was due


2.5.3  Notification of Compliance Status

       The Notification of Compliance Status must be submitted within 150 days after the source's
       compliance date.  The date of compliance for existing sources is 3 years after the date of
       promulgation.  The date of compliance for new sources is the date of promulgation or the startup
       date, whichever is later. The Notification of Compliance Status contains the information
       necessary to demonstrate that compliance has  been achieved, such as the results of performance
       tests for process vent and transfer control devices, process vents TRE determinations  and
       monitoring system performance evaluations.

       Sources with a large number of emission points are likely to submit results of multiple
       performance tests. For each test method used for a particular kind of emission point (e g  a
       process vent), one complete test report must be submitted. For additional tests performed for the
       same kind of emission point using the same method, the results must be submitted  but the
       complete test reports may be kept at the  plant.

       Another type of information to be included in the Notification of Compliance Status is the specific
       range for each  monitored parameter for each emission point, and the rationale for why this ranqe
       indicates proper operation of the control device. (If this range has already been established in the
       operating permit, it need not be repeated  in the Notification of Compliance Status)  As an
       example, for a process vent controlled by an incinerator, the notification would  include the site-
       specific minimum firebox temperature that will ensure proper operation of the incinerator and the
       data and rationale to support this minimum temperature.

       Section 11 of Volume II of this document has a checklist of items required in  the Notification of
       Compliance Status.
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                                          Overview of Emission Points, Control Technologies, and HON Provisions
2.5.4 Periodic Reports

        Periodic Reports are required to demonstrate that the standards continue to be met and that
        control devices are operated and maintained properly. Generally, Periodic Reports will be
        submitted semiannually. However, if monitoring data are insufficient, or if monitoring results show
        that the parameter values for an emission point are outside the established range for more than
        the excused number of days specified in §63.152, the Administrator (or delegated regulatory
        authority) may request that the owner or operator submit quarterly reports for that emission point.
        After 1 year, the source can return to semiannual reporting, unless the regulatory authority
        requests continuation  of quarterly reports.

        Periodic Reports specify periods when the daily average values of continuously monitored
        parameters are outside the ranges established in the Notification of Compliance Status or
        operating permit. For some kinds of emission points and controls, periodic (e.g., monthly,
        quarterly, or annual) inspections or measurements are required instead of continuous monitoring.
        Records that such inspections or measurements were done must be kept; results are included in
        Periodic Reports only if a problem is found. Periodic reports may also include information on
        startups, shutdowns, and malfunctions if any occurred during the reporting period. Details of the
        Information required are specified in §63.10(d)(5) of Subpart A.

        The first periodic report is due no later than 8 months after the date the notification of compliance
        status is due. All other semiannual reports are due no later than 60 days after the end of each
        6 month period. Quarterly reports, if required, are due 60 days after the end of each quarter.
        Section 11 of Volume II of this document has a checklist of items required in the periodic reports.

 2.5.5  Other Reports

        There are a very limited number of other reports. Where possible, Subpart G is structured to
        allow all information to be reported in the semiannual (or quarterly) Periodic Reports. However, in
        a few cases it is necessary for the source to provide information to the regulatory authority shortly
        before or after a specific event. For example, for storage vessels, notification prior to internal tank
        inspections is required to allow the regulatory authority the opportunity to have an observer
        present.  The semi-annual start-up, shutdown, and malfunction reports may be submitted on the
        same schedule as the Periodic Reports.

 2.6 USE OF CONTINUOUS MONITORING TO DETERMINE COMPLIANCE

        This section summarizes the basic approaches for determining compliance for Group 1  emission
        points where continuous monitoring is required.  As described in Section 7 of this document,
        performance tests and continuous monitoring of control device operating parameters are required
        for most kinds of devices used to control Group 1 emission points. For wastewater streams, it is
         necessary to have monitoring information on the treatment processes (e.g., steam stripper) as
        well as on the control device receiving the gas stream vented from the treatment process or waste
         management unit. Compliance with the 98 percent reduction or 20 ppmv outlet concentration
         requirement is determined by performance testing.  Results of the tests are reported in  the
         Notification of Compliance Status.  Continuous parameter monitoring results are not used to
         determine compliance with the percent reduction or emission limit; however, monitoring results
         are used to determine compliance with operating requirements.
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        Each source must establish site-specific ranges for monitored parameters that will demonstrate
        proper operation of each control device for which continuous monitoring is required. These site-
        specific ranges can be set through performance testing supplemented by engineering
        assessments and manufacturers' recommendations (the performance test is not required to be
        conducted over the entire range of permitted parameter values).  The justification for the site-
        specific range is included in the operating permit application or Notification of Compliance Status.
        The ranges are then incorporated in the sources' operating permit. Each source must
        continuously monitor and record the operating parameter(s) for each control device and report
        any daily average value of an operating parameter that is outside the established range as well as
        any days when insufficient monitoring data are collected. These  excursions are reported in the
        quarterly or semiannual reports described  in Section 2.5.4. If, during a reporting period, a
        monitored operating parameter is outside the established range or insufficient data are collected
        for more than the number of days specified in §63.152(c) of Subpart G, this is considered a
        violation of the operating permit requirements.

        An owner or operator may request approval to use alternatives to continuous operating parameter
        monitoring, as allowed by §63.151 (g) of Subpart G. Continuous monitoring is not required for
        storage vessels or for some treatment processes for wastewater streams. The compliance
        determination approaches for storage and  wastewater are described in Sections 7.3.4 and 7.4.5
        of this document, respectively.
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Overview of Emission Points, Control Technologies, and HON Provisions
                               3.0 APPLICABILITY OF THE RULE
       In determining the applicability of the HON, the first step is to determine whether the facility is a
       major source for Hazardous Air Pollutants (HAP's). The second step is to determine which
       chemical manufacturing process units (CMPU's) at a plant site are subject to the HON. The third
       step is to identify the equipment within those CMPU's subject to the HON. Next, the source must
       be designated as a new source or an existing source. The final step in determining the
       applicability of the rule is to determine which emission points within the CMPU satisfy the HON
       definitions of process vent, storage vessel, transfer rack, and wastewater stream. This chapter
       will explain in more detail the first four steps. The sources Title V permit application and Title V
       permit will address much of the material concerning applicability of the HON to the source. The
       final step of determining applicability to specific emission points is addressed in Section 7.

3.1  IDENTIFICATION OF SOCMI PROCESS UNITS

       For the HON to apply to a plant site, it has to be a major HAP source as defined in Section 112(a)
       of the Act, i.e., any stationary source or group of stationary sources located within a contiguous
       area and under common control that emits or has the potential  to emit, considering controls, in the
       aggregate, 10 tons per year (tpy) or more of any hazardous air pollutant or 25 tpy or more of any
       combination of hazardous air pollutants. For the HON to apply to a CMPU, the CMPU must meet
       three criteria. First, the CMPU must be a SOCMI unit, which means a SOCMI chemical in Table 1
       of Subpart F is the primary product  made in the unit.  Second, organic HAP's regulated by the
       HON, which are listed in Table 2 of  Subpart F, have to be used as a reactant or manufactured in
       the CMPU.  Finally, the plant site where the CMPU is located has to be a major HAP source.
                                             Section 3.O Applicability of th& Rule
                                             3,1
                                             3,2
                                             3.3
          Identification Of Socmi Process Units >,*,< + ,.,»..
          Determination Of The Hon Source  .,,,,,,».,,..
          Determination Of New Source Vs. Existing Source
          3.3,1   New Sources	,.,,.,.,.,
          3.3.2   Ekisting Sources	
          3,3.3   other Process Changes	
          3,3,4   Compliance Dates	,	v
Identification of the primary product
of a CMPU may not be obvious.  In
the chemical manufacturing industry,
most facilities consist of integrated
operations involving some
combination of refinery processes,
SOCMI processes, polymers and
resins processes, agricultural
chemical production, pharmaceutical     ^_____	
production, and specialty chemical          ~~~~~~~
production. Thus, a CMPU may
produce multiple chemicals including valuable co-products and materials that will be used as
reactants for downstream units.  Also, some CMPU's are designed and operated as flexible
operation units, that is, the  equipment is used to make different chemicals at different times during
the year. Determining applicability of a rule and what equipment is subject to the rule is complex
and requires detailed information about the facility and its operations.

To address this complexity, the rule includes procedures for determining the primary product of a
CMPU. The rule also exempts certain units and equipment from all requirements.  Specifically,
the HON does not apply to the following processes:
t-12
1-13
W
144
US
MS
1-16
                       Research and development facilities, even if they are located at the same plant
                       site as the CMPU that is subject to the HON;
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                                                         P°'ntS| Contr0' Technologies. and HON Provisions
                      Petroleum refining and ethylene process units, even if they supply feedstocks that
                  .    are SOCMI chemicals to CMPU's that are subject to the HON;

                      CMPU's located in coke by-product recovery plants; and

                      Solvent reclamation, recovery, or recycling operations at hazardous waste
                      treatment, storage, and disposal facilities (TSDF) that are not part of a SOCMI
                      unit.

       Table 3-1 of Volume II is a checklist for determining whether a CMPU is subject to the HON
       Table 3-2 of Volume II contains questions for determining the primary product and applicability for
       flexible operation units in particular. Table 3-3 of Volume II addresses determination of primary
       product in all other cases.
3.2  DETERMINATION OF THE HON SOURCE
wilhi^OCMI
                                                               °f th6 foll°Wing emissi°n P°ints
                     Process vents;

                     Storage vessels;

                     Transfer racks;

                     Wastewater and the associated treatment residuals; and

                     Pumps, compressors, agitators, pressure relief devices, sampling connection
                     systems, open-ended valves or lines, valves, connectors, instrumentation
                     systems, surge control vessels, and bottoms receivers (equipment leaks).

              '  o!nts-n em'SSi0n P°intS are exemPted from the rule.  The HON does not apply to the


                     Equipment that is located with a CMPU subject to the HON but does not contain
                     organic HAP's;

                     Vents from CMPU's that are designed and operated as batch operations;

                     Stormwater from segregated sewers;

                     Water from fire-fighting and deluge systems in segregated sewers;

                     Spills;

                     Water from safety showers;

                     Water from testing of deluge systems;

                     Water from testing of firefighting systems;
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                                        Overview of Emission Points. Control Technologies, and HON Provisions
                                              	"	~——~~—~~~

                     Vessels storing organic liquids that contain organic HAP's only as impurities;

                     Loading racks, loading arms, and loading hoses that only transfer liquids
                     containing organic HAP's only as impurities;

                     Loading racks, loading arms, and loading hoses that vapor balance during all
                     loading operations; and

                     Equipment as defined in § 63.101  of subpart F that is intended to operate in
                     organic HAP service for less than 300 hours per calendar year.

       In large chemical manufacturing facilities, it is often difficult to determine where one process unit
       ends and the next begins. For example, a storage vessel may contain a chemical that is the
       product of one CMPU and the raw material for another CMPU. A transfer rack may load the
       products of several CMPU's, some that are SOCMI and others that are not. Distillation columns
       may be used to purify a product for sale or to remove inhibitors and impurities from a raw material.
       To clarify the applicability of the HON in these situations, the rule includes procedures for
       assigning storage vessels, transfer racks, and distillation columns to the appropriate CMPU. In
       order to determine the boudaries of the CMPU,  the storage vessels, transfer racks, and distillation
       columns are assigned to the CMPU according to the predominant use  of each one.  Tables 4-2,
       4-5 and 4-8 of Volume II are checklists for these procedures.

3.3    DETERMINATION OF NEW SOURCE  VS. EXISTING SOURCE

       Once the HON source has been identified, it must be classified as a new or existing source
       because the rule contains different requirements for new versus existing sources. Many of these
       requirements pertain only to specific kinds of emission points and are therefore  discussed in later
       sections of this document. This section addresses the definitions, MACT requirements, and
       compliance dates for new sources, existing sources, and other process changes.

3.3.1  New Sources

       A source is subject to the HON's new source MACT requirements if it  meets the criteria for a new
       source or a reconstructed source. A source would be a new source if all of the  following criteria
       are true:

                      An entire CMPU or group of CMPU's is being added (The addition of a single
                      emission point, e.g., a storage vessel, cannot be a new source regardless of the
                      magnitude of emissions from the vessel);

                      The additional CMPU produces a SOCMI chemical listed in Table 1 of Subpart F
                      and uses as a reactant or produces an organic HAP listed in Table 2 of
                      Subpart F;

                      The additional CMPU  meets the definition of construction in 40 CFR 63.2,
                      Subpart A (i.e., fabrication, erection, or installation);

                      Construction of the additional  CMPU started after December 31,1992; and
                                                 1-14
                                                                                   September 1997

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                                          Overview of Emission Points, Control Technologies, and HON Provisions


              •       The additional CMPU has the potential to emit 10 tpy or more of a single HAP or
                      25 tpy or more of any combination of HAP's.

       A source would be a reconstructed source if all of the following were true:

              •       Changes to the source meet the definition of reconstruction in 40 CFR 63.2,
                      Subpart A (i.e., the source is changed to such an extent that the fixed capital cost
                      of the new components exceeds 50 percent of the fixed capital cost required to
                      construct a comparable new source); and

              •       The reconstruction started after December 31,1992.

3.3.2  Existing Sources

       A source is subject to the HON's existing source MACT requirements if it does not meet the
       criteria in Section 3.3.1 for a new source or reconstructed source. Examples of existing sources
       could include CMPU's that were already in operation prior to December 31, 1992; addition of an
       individual emission point such as a storage vessel or transfer rack; and addition of a CMPU with
       emissions below the 10 tpy/25 tpy threshold;

3.3.3  Other Process Changes

       As is common  in any manufacturing facility, chemical plants are characterized by frequent
       changes in operations.  Cost concerns, market needs, and product improvement efforts mean
       individual equipment and often entire process units, may  be changed or added to an existing plant
       site. As defined in the HON, process changes include, but are not limited to:

              •       Changes in production capacity, feedstock type, or catalyst type; and

                      Replacement, removal, or addition of recovery equipment.

       Process changes do not include:

              •       Process upsets;

              •       Unintentional temporary process changes; and

              •       Changes that are within the equipment configuration and operating conditions
                      documented in the Notification of Compliance Status.

       Section 3.3.1 listed the criteria for determining whether additions or changes would be considered
       new or reconstructed sources. It is also possible that an  addition or change would satisfy neither
       set of criteria.  If a change did not exceed the 50 percent  fixed capital cost to be a reconstruction
       or the 10 tpy/25 tpy emission potential to be a new source, the added or changed equipment
       might still be subject to the HON. For example, an owner or operator may switch from using a
       non-HAP raw material to using a HAP as a raw material.  Or, a change in catalyst type could
       increase capacity thereby causing an increase in emissions above the 10 tpy/25 tpy threshold.  In
       such cases, if the addition or change did not satisfy the criteria for new or reconstructed source,
       but the additions or changes were made to part of the HON source, the added or changed
       equipment would be subject to the HON's existing source MACT requirements.
                                                1-15
                                                                                   September 1997

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Vdumel	Overview of Emission Points, Control Technologies, and HON Provisions


3.3.4 Compliance Dates

       Table 3-1 lists the compliance dates for existing, new, and reconstructed sources and for
       additions or changes that are not subject to new source requirements.  For compliance with the
       equipment leak provisions in Subpart H, process units have been placed in five groups with
       different compliance dates. Group designations are listed in Table 1 of Subpart F.
                                                                                     September 1997

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Volume I
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                                                                1-17
                                                                                                               September 1997

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                                         Overview of Emission Points. Control Technologies, and HON Provisions
                        4.0 GENERAL PROVISIONS APPLICABLE TO
                                             THE HON
       The regulations In 40 CFR 63, Subpart A (i.e., the General Provisions) contain "boilerplate"
       requirements that apply, in general, to all affected sources subject to applicable requirements in
       other subparts of Part 63.  Rather than repeat common standards or administrative specifications
       as sections withirr subsequent NESHAPs, Subpart A provides a common, consolidated repository
       of these requirements.

       Subsequent NESHAPs do, however, may override some parts of the General Provisions as may
       be warranted by the particular conditions of the affected source and its compliance obligations.
       Because of the complexity and timing of the HON, it superceded certain portions of the General
       Provisions. Accordingly, this section of the guide summarizes only those sections of the General
       Provisions not overridden by the HON. Where the HON did supercede pieces of the General
       Provisions, the other sections of this guide address such requirements.  Table 3 of Subpart F of
       the rule specifically list the overrides applicability of the General Provisions by the HON.

4.1  APPLICABILITY AND DEFINITIONS

       The General Provisions provided in subpart A apply to owners and operators subject to the HON
       rule except when otherwise specified in the HON rule subpart. Part 63 emission standards or
       other requirements do not diminish or replace the requirements of a more stringent emission
       limitation or other applicable requirement established under the Clean Air Act or under state
       authority. Time periods and deadlines may be changed by agreement between the owner or
       operator and the administrator. In addition to complying with applicable requirements in the HON
       rule and the General Provisions, the owner or operator of a subject source may be required to
       obtain a Title V operating permit. Extension of compliance for some requirements does not delay
       the owner's or operator's obligation for compliance with all other parts.

       Some terms used in the HON are
       defined in the General Provisions.

 4.2 PROHIBITED ACTIVITIES AND
        CIRCUMVENTION
Sgetjon4,
         Provisions Applicable to the HON
4,1
4,2
4.3
4*4

4.$
Applicability arid Definitions
4.7
4.8
4.9
4.10
Construction and Reconstruction .,	
Compltance with Standards and Maintenance
Requirements ,,>..,,, + ,<>.< >< + ,<>•<-< + .
Performance Testing Requirements <> • <>< +
Monitoring Requirements  ,,.,.. +	*
RecordReeping and Reporting Requirements
Control Device Requirements	
Availability ofJnformatton and Confidentiality
        The owner or operator of an affected
        source shall not operate the source in
        violation of the requirements except
        under an extension of compliance
        granted by the administrator or by a
        state with an approved permit program
        or under an exemption granted by the
        President. After the effective date of an approved permit program in a state, the owner or
        operator of an affected source that is required to have a Title V operating permit must operate in
        compliance with the provisions of the State's permit program. No owner or operator shall fail to
        keep required records or file reports as required. The owner or operator of an affected source
        must comply with the requirements by the compliance date(s) regardless of whether a Title V
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        permit has been issued or, if a Title V permit has been issued, whether such permit has been
        modified to incorporate HON rule requirements.

        The owner/operator of an affected source may not conceal an emission that would otherwise
        constitute noncompliance. Concealment includes:

                      Dluting an effluent stream to meet concentration standards, and
                      Fragmentation of an operation to avoid a standard.

        The provisions of the HON rule and the general provisions are federally enforceable regardless of
        how they may be incorporated into a Title V permit.

 4.3 CONSTRUCTION AND RECONSTRUCTION

        A new source that is constructed after the promulgation date of the HON rule is subject to the
        relevant requirements for new sources, including compliance dates. After the promulgation date
        of the HON rule no major source can be constructed or reconstructed without written approval  A
        separate application for approval must be submitted for each construction or reconstruction  The
        requirements for the application for approval are provided in checklist format (see Table 11-10 of
        Volume II of this document). The administrator may request additional information after submittal
        of the application. Approval will be granted if the administrator determines that the source will not
        cause an emission violation or a violation of the relevant standards or other federally enforceable
        requirements. In addition, for reconstructions, the administrator will consider:

               •       Fixed capital costs compared to cost of a new facility,
                      Estimated life of the source compared to a new source,
                      Extent to which components being replaced contribute to emissions, and
                      Economic or technical  limitations on compliance with relevant standards that are
                      inherent in proposed replacements.

        The applicant will be notified of the completeness status of the application within 30 days of
        receipt of an application or of additional information for an application. The applicant will be
        notified of approval or intent to deny approval within 60  days of having a complete application
        After notification of intent to deny, applicant has 30 days to provide additional information or
        arguments. Final determination is made within 60 days of receiving additional information and/or
        arguments.

4.4  COMPLIANCE WITH STANDARDS AND MAINTENANCE REQUIREMENTS

        Section 63.6 applies to an affected source unless it has received an extension of compliance from
        the Administrator or an exemption from compliance granted by the  President. Further  it outlines
        the process for and content of the extension or denial. This section would also apply to an area
        source that otherwise would be subject to a relevant standard or other requirement if the area
        source's potential to emit subsequently increases above major source levels. This section allows
        sources commencing construction or reconstruction between proposal and promulgation up to
       three years after the effective date to comply with the promulgated standard  if it is more stringent
       that the proposed standard, provided that the source complies with the proposed standard in the
        interim.
                                                1-19
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       Section 63.6 requires that malfunctions be corrected as soon as practicable after their occurrence
       in accordance with the source's Startup, Shutdown and Malfunction Plan, it also requires that the
       owner or operator operate and maintain emission source and air pollution control equipment in
       accordance with the procedures in Startup, Shutdown and Malfunction Plan. This section also
       allows the Administrator to require that the owner or operator make changes to the Plan to
       address inadequacies.  Contents of the Startup, Shutdown and Malfunction Plan are listed on
       Table 11-7.

       Section 63.6 also indicates that demonstrating compliance with nonopacity emission standards
       may be accomplished by performance tests, conformance with operation and maintenance
       requirements, monitoring data, records, or inspection of the source.

 4.5  PERFORMANCE TESTING REQUIREMENTS

        Section 63.7 gives the Administrator the authority to request the owner or operator of an affected
        source to conduct performance testing any time allowed by Section 114  of the Clean Air Act. If
        required to do performance testing, the owner or operator of the affected source shall supply the
        necessary testing facilities,  including sampling ports, platforms, utilities, etc. This section
        stipulates that testing be conducted under representative conditions, which do not include startup,
        shutdown, or malfunction. The Administrator may request records from  the source to determine
        these representative conditions.  This section also requires performance test to be conducted and
        data to be reduced in accordance with the test methods and procedures set forth  in Part 63 or the
        applicable appendices of Parts 51, 60, 61, and 63 unless the Administrator approves:

                       Minor  changes in methodology,
               •       The use of an alternative method,
                       Shorter sampling times or smaller sampling volumes unless the Administrator
                       waives the requirement for performance tests.

 4.6  MONITORING REQUIREMENTS

        Section 63.8 specifies general monitoring requirements such as those governing  the conduct of
        monitoring and those in requests to use alternative monitoring methods. It also specifies detailed
        requirements that apply to  affected sources required to use continuous  monitoring systems (CMS)
        under a relevant standard. This section allows the Administrator to approve minor changes in
        methodology or use alternative monitoring requirements or procedures.

        When more than one CMS is used to measure the emissions from one  affected source, the owner
        or operator shall report the results as required for each CMS. However, if a CMS is installed with
        the intent of serving as a backup, then its data should only be reported  during periods when it is
         required to gather compliance monitoring data (i.e., is serving in place of the primary CMS). The
         owner or operator shall: operate and maintain each CMS consistent with good air pollution control
         practices, ensure the correction of routine or predictable CMS malfunctions, with spare parts
         readily available. Such repairs shall be reported in the semiannual startup, shutdown, and
         malfunction report.  All CMS must acquire representative data and must be located according to
         procedures contained in the applicable performance specifications. CMS operational status
         verification shall include, at a minimum, completion of the manufacturer's written specifications or
         recommendations for installation, operation, and calibration of the system. CMS data shall be
         verified either prior to or in conjunction with conducting performance tests.
                                                                                     September 1997

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        The Administrator may approve a request for alternative monitoring procedures related to the
        following issues:

                       Interferences caused by substances (including water) within effluent gases,
                •       Infrequent source operation,
                       Accommodation of additional measurements to correct for stack gas moisture,
                       Alternative locations provided the data will still be representative,
                       Alternate methods for converting pollutant concentration measurements,
                       Alternate procedures for performing daily checks of zero and high-level drift,
                •       Alternatives to ASTM or other sampling procedures,
                       Alternative CMS that do not meet the design or performance requirements of the
                       General Provisions but that adequately demonstrate a definite and consistent
                       relationship, or
                       Alternative monitoring when the effluent from a single  affected source or the
                       combined effluent from multiple sources is released through more than one point.


        The application for an alternative monitoring method shall  contain a description of the proposed
        alternative monitoring system and information justifying the owner or operator's request for the
        alternative monitoring method such as technical or economic infeasibility or the impracticality of
        the affected source using the required method.

4.7 NOTIFICATION REQUIREMENTS

        Section 63.9 describes the conditions and timing under which affected  sources must provide
        notification to the EPA or the appropriate delegated authority of becoming subject to applicable
        requirements. It also addresses overlap of state and federal notifications, allowing that any
        notification required by a state (i.e., the delegated authority) that contains all the information
        required in any notification of this section may be submitted to the EPA in lieu of the otherwise
        required federal notification. The specific information required in the notifications is addressed in
        Table 11-9 of Volume  II of this document. This section also provides for adjustments to time
        periods or postmark deadlines for submittal and  review of required communications upon mutual
        agreement of the owner  or operator with the Administrator.

4.8  RECORDKEEPING AND REPORTING REQUIREMENTS

        Section 63.10 describes  the conditions and timing under which affected sources must submit
        reports to the EPA or the appropriate delegated authority to demonstrate compliance with
        applicable requirements.  It also addresses overlap of state and  federal reports allowing that any
        report required by a state (i.e., the delegated authority) that contains all the information required in
        a report required by this section may  be  submitted to the EPA in lieu of the otherwise required
        federal report.  Fpr an  owner or operator that supervises more than one stationary source affected
        by more than one standard in Part 63 or by a standard in Part 63 as well as a standard in Part 60
        and/or Part 61, this section allows the Administrator and the owner or operator to agree to a
        common schedule for which all relevant periodic reports may be submitted.

       This section also indicates that, under specific conditions, progress reports pursuant to
       compliance extensions and startup, shutdown and malfunction reports may need to be submitted
       to the administrator. The submittal schedules vary according to the content of the reports  Also
       included in this section is the option for the owner or operator of an affected source to submit a
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                                        Overview of Emission Points, Control Technologies, and HON Provisions
                                        ^H^BBg^m^MII^HB^^Bi^Hll^^ai^MB^M^BB^HBBM

       request for a waiver of recordkeeping or reporting requirements. Contents of the Startup,
       Shutdown, and Malfunction Report is outlined in Table 11-8 of Volume II of this document.

4.9  CONTROL DEVICE REQUIREMENTS

       Section 63 11 contains general requirements for control devices used to comply with applicable
       requirements in regulations in Part 63. Specifically, it requires owners or operators to monitor
       flares to assure that they are operated and maintained in conformance with their designs.
       Detailed requirements for flares are addressed in Table 10-1 in Volume II of this document.

4.10 AVAILABILITY OF INFORMATION AND CONFIDENTIALITY

       Section 63.15 specifies that the following materials are deemed a matter of public record with the
       exception of information protected as confidential:

                      Reports,
                      Records,
                      Information collected by the Administrator,
                      Permit applications,
                      Compliance plans (including compliance schedules),
                      Notifications of compliance status,
                      Excess emissions reports,
                      Continuous monitoring system performance reports, and
                      Title V permits.
                                                                                   September 1997

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5.1  PROCESS VENTS

       A chemical manufacturing process consists of reactors, recovery units, or a combination of the
       two. The design of a process will vary at each facility depending on the product the type of
       process, and the design capacity. Therefore, each process will have a different number tvoe
       and configuration of process vents.                                                '     '

       Manufacture of organic chemicals may involve conversion and separation processes  Reactor
       and air oxidation processes are conversion processes involving chemical reactions that alter the
       molecular structure of chemical compounds and form one or more new compounds  An air
       oxidation process uses air, or a combination of air and oxygen, as an oxygen source in a chemical
       reaction. Separation processes are used to produce or recover a product from a mixture and are
       often used following a conversion process. Distillation, stripping, absorption, adsorption filtration
       crystallization, and  extraction are all separation processes which divide chemical mixtures into   '
       distinct fractions, such as products and by-products.  All of these processes have potential
       emission points.  The process vent provisions of the hazardous organics NESHAP (HON) and the
       SOCMI distillation,  air oxidation, and reactor processes NSPS focus primarily on vents from
       reactor and air oxidation processes and distillation operations.  They cover both vent streams
       emitted directly from these operations, as well as vent streams that are emitted indirectly (e a
       through a recovery  device).
                                         5,1
                          Process Vents,	,.,»,„, ./..»„,..„.".    ,.*',>,
                          Transfer Operations *,,>,,>< *,,»,,,,*, ] + M, [ „ j ] f, [
                          Storage:Vessels  ,m><	+ »<>», >x + ><**,>,»,, + *,,
                              ' Boating Kjpnf Storage V«$$eJ  ,,",»,,, r,,,       '
Reactor processes may involve
liquid-phase or gas-phase
reactions. Gas-phase reactions
usually have at least one
recovery device used to produce
a liquid product.  Reactors may
have an atmospheric vent, may
vent to one or more recovery
devices, or both. Also, any vent
from a reactor or recovery device
may vent to a combustion device.
Figure 5-1 shows four vent types, including:

       (A)     Direct reactor process vents from liquid-phase reactors;

       (B)     Process vents from recovery devices applied to vent streams from liquid phase
               reactors;

       (C)     Process vents from gas-phase reactors after a recovery device;
              (D)
Process vents from combustion devices applied to vent types A, B, and C.
      These four diagrams represent only a few of the possible vent configurations.  For example a
      reactor may have both A and B type vents, or multiple type B vents. Air oxidation reactor  '
      ?^SS?S Vent Iar9e 9uantities of vapors with low concentrations of volatile organic compounds
      (VOC s) because large quantities of air or air enriched with oxygen  act as the oxidizing agent in
                                                1-23
                                                                                   September 1997

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                                 Overview of Emission Points. Control Technologies, and HON Provisions
(A) Liquid-Phase Reactor
                                                                     Gas
                            Vent Type A
                                             (B) Product/By-Product     t
                                                Recovery Device       r vem w D
                                       Liquid
                                                                               Recovered
                                                                                Product
                         *• Uquid
 (C) Gas-Phase Reactor
                                               Gas
                                                  VentTypeC
                                                         Liquid
 (D) Process Vents Controlled by Combustion
      Process Vent Streams
        fr6mA,B,orC
Combustion
                                                                        Vent TVps D
                Figure 5-1.  Examples of Reactor-related Vents
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        the process.  Because of the increased air flow, these vents are typically larger in size  An air
        oxidation process typically occurs in a reactor over a catalyst bed, followed by a
        condensation/extraction process which is usually vented to the atmosphere.

        Distillation is the most widely used separation process and has the potential to release larger
        amounts of VOC's and hazardous air pollutants (HAP's) from multiple emission points than other
        separation processes. Distillation processes occur at various temperatures and pressures and
        require varying numbers of distillation stages. Six potential emission points for atmospheric and
        vacuum distillation columns are shown in Figures 5-2 and 5-3.  These emission points can include
        vents on:  (1) condensers, (2) overhead receivers, (3) hot wells, (4) steam jet ejectors
        (5) vacuum pumps, and (6) pressure relief valves. Strippers are a type of fractionating distillation
        column and will have emission points similar to those shown in  Figures 5-2 and 5-3  [It should be
        noted that emissions from hotwells are subject to  the wastewater provisions of the HON rather
        than the process vent provisions because the emissions result from a contaminated stream1
        Also, pressure relief valves are not considered to  be process vents in the HON because the gas
        stream is discharged intermittenly, not continuously during operation of the unit]

 5.2 TRANSFER OPERATIONS

        The principal method of transferring liquid product to tank trucks and railcars is submerged
        loading, including submerged fill pipe loading and  bottom loading.  In submerged fill pipe loading
        the fill pipe enters the vessel from the top but extends almost to the bottom of the vessel such that
        the fill pipe opening is completely submerged in the liquid product.  In bottom loading the fill pipe
        enters the vessel from the bottom, so that the fill pipe opening is positioned below the liquid level
        Figures 5-4 and 5-5 illustrate submerged fill pipe and bottom loading. Both submerged loading
        techniques significantly reduce liquid turbulence and liquid surface area resulting in low vaoor
        generation.                                                                       K

        Top splash loading, rarely used in SOCMI facilities, is another loading technique in which the fill
        pipe enters the vessel through the top but does not extend below the surface of the liquid  This
        type of loading results in high vapor generation.

        The loading rack is the equipment used to transfer materials into tank trucks and railcars  The
        loading rack and the transfer vehicle are emission  points during loading operations. A typical
        loading rack consists of loading arms, pumps, meters, shutoff valves, relief valves, and other
        associated piping necessary to perform either loading or unloading operations.

        Figures 5-6 and 5-7 illustrate tank truck bottom- and top-loading rack arrangements. Sections 4 1
       and 4.2 of the  Benzene Transfer Operation Inspection Manual2 provide additional details
        including illustrations of various transfer loading operations. They describe transfer equipment
       transfer emission  points, and the requirements of the Benzene NESHAP.  In some cases  the  '
       requirements of the HON will differ from the requirements of the Benzene NESHAP.

5.3  STORAGE VESSELS

       Two types of storage vessels are of concern in inspecting a SOCMI facility: fixed-roof storage
       vessels (i.e., with no internal floating roof) and floating roof storage  vessels.  They are exclusively
       above-ground  and cylindrical in shape with the axis perpendicular to the foundation There are
       also horizontal tanks, but these are generally smaller and not as widely used
                                                 1-25
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                     Overview of Emission Points, Control Technologies, and HON Provisions
                            Vent to Atmosphere
Vapor Phase
        Liquid Reflux
       Distillation
        Column
                                                     Pressure Relief
                                                       Valve (6}
                                     Overhead Receiver
                                          (2)
                                   Overhead Product
Figure 5-2.  Potential VOC and HAP Emission Points for An
       Atmospheric (Nonvacuum) Distillation Column
                              1-26
                                                               September 1997

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         Vapor Phase
               Liquid Reflux
              Distillation
               Column
                                       Condenser. (1)
                                                                         Vent
                                                        Vacuum Pump (5)
                                                         Overhead Receiver (2)
                                                     Overhead Product
     Figure 5-3. Potential VOC and HAP Emission Points for a Vaccum
Distillation Column Using a Vacuum Pump
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                                      Overview of Emission Points, Control Technologies, and HON Provisions
                                                              Fill pipe
                        Benzene vaoor emissions
                                                                    Hatch cover
                                                                      Cargo tank
                            Figure 5-4.  Submerged Fill Pipe
                    Vaoor vent
                    to recovery
                    or atmosphere
                                                Hatch closed
                                                                     Cargo tank
                                                                         Fill pipe
                             Figure 5-5. Bottom Loading
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                                          Overview of Emission Points, Control Technologies, and HON Provisions
                            Figure 5-6.  Tank Truck Bottom Loading
                                                1-29
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                                          Overview of Emission Points. Control Technologies, and HON Provisions
                                        Top loaning arm.
                                     Flexible hose
                      Compatible vapor tight adapters
                      Permanent
                      submerged
                      lilt pipe
                            Vapor
                            line
Vapor connector
                              Figure 5-7.  Tank Truck Top Loading
 5.3.1  Fixed-Roof Storage Vessel

        A typical fixed-roof vessel is a cylindrical steel shell with a cone- or dome-shaped roof
        permanently affixed to it. Refer to Section 4.1.1 of the Benzene Storage Inspection Manual3 for a
        description of typical fixed-roof vessels and their potential emission points. Figure 5-8 illustrates a
        fixed-roof vessel with a closed-vent system and control device. As described in the Benzene
        Storage Inspection Manual3, most emissions from these vessels are released through roof vents.
        Gauge hatches/sample wells, float gauges, and roof manholes on the fixed roof, which provide
        access to these tanks, also are potential but less significant sources of emissions.
      Figure 5-8. Fixed Roof Tank with Closed-Vent System and Control Device
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Overview of Emission Points, Control Technologies, and HON Provisions
5.3.2  Floating Roof Storage Vessel

       A floating roof vessel is a cylindrical steel shell equipped with a disk-shaped deck with a diameter
       slightly less than the inside tank diameter.  The floating deck floats freely on the surface of the
       stored liquid, rising and falling with the liquid level. The liquid surface is completely covered by the
       floating deck, except in the small annular space between the deck and the shell. A rim seal
       attached to the floating deck slides against the vessel wall as the deck is raised or lowered,
       covering the annular space where the deck is not covering the liquid.  Refer to Section 4.1.2 of the
       Benzene Storage Inspection Manual3 for a general description of a floating roof vessel and a
       general discussion of emissions from these vessels. Figure 5-9 illustrates a floating roof tank.

       For compliance with the storage vessel provisions, the HON allows three specific types of floating
       roof storage vessels: an external floating roof (EFR) vessel, an internal floating roof (IFR) vessel
       (i.e., a fixed roof vessel with an IFR), and an EFR vessel converted to an IFR vessel (i.e., a fixed
       roof installed above an EFR).  These floating roof storage vessel types are described below.
                                           VENT.
                                                                       GAGE HATCH.
                      —GUIDE POLE
                      .WEATHERMASTER  SEAL

                                  FLOATING ROOF
                                    FIXED ROOF
                                     SUPPORTS
                                      PIPE COLUMN-—
                                                                              MANHOLE
                                   Figure 5-9. Floating Roof Tank

        Each discussion refers to specific sections and figures in the Benzene Storage Inspection Manual3
        for more detail. The sections referred to in the Benzene Storage Inspection Manual3 include
        discussions about the requirements of the Benzene Storage NESHAP and descriptions of the
        vessel types.  In some cases, the requirements in the HON will differ from the requirements of the
        Benzene Storage NESHAP.
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5.3.2.1  External Floating Roof Vessel

       An EFR vessel does not have a fixed roof; instead, its floating deck is the only barrier between the
       stored liquid and the atmosphere. An EFR vessel may have several types of rim seals and deck
       fittings.  Figure 5-10 shows an EFR vessel.  Refer to Section 4.1.2.1  of the Benzene Storage
       Inspection Manual3 for a description of a typical EFR vessel and associated emissions. Two types
       of deck fittings, a gauge hatch and a sampling port, are not shown in  Figure 5-10, but are
       mentioned in Section 4.1.2.1 of the Benzene Storage Inspection Manual,3 Rim seals associated
       with EFR vessels are described in Section 4.1.2.3 of the Benzene Storage Inspection Manual3
       and the associated figures.
                       Automatic
Gauge Float
  System
                                     Emergency
                                      Roof Drain
                                                              Guide-pole
                                                                 Well
        Mechanical
           Shoe
           Seal


                         Figure 5-10.  External Floating Roof Tank

5.3.2.2  internal Floating Roof Vessel

       An IFR vessel is equipped with a permanently affixed roof above the floating deck. Refer to
       Section 4.1.2.2 of the Benzene Storage Inspection Manual3 for details. Figure 5-11 illustrates an
       IFR vessel.  In reviewing Figure 5-11, note that the deck fittings and the rim space vent for a
       mechanical shoe seal are not shown. A rim space vent is illustrated in Figure 5-10 an EFR
       vessel, and would be the same on an IFR vessel equipped with a mechanical shoe seal. Seals
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       associated with IFR vessels are described in Section 4.1.2.3 of the Benzene Storage Inspection
       Manual3 and the associated figures.

                                                                       Gauge
                                                                   Float System
      Figure 5-11. Internal Floating Roof Tank
5.3.2.3  External Floating Roof Vessel Converted to an Internal Floating Roof
         Vessel

       The HON specifies that an EFR vessel may be converted to an IFR vessel in order to comply with
       the storage provisions. This conversion is accomplished by affixing a permanent roof to an EFR
       vessel, above the floating deck, and equipping the EFR with a seal mechanism equivalent to
       those required for an IFR. These converted vessels would have the external appearance of an
       internal floating roof vessel, deck fittings required for an external floating roof vessel, and a rim
       seal with the characteristics of an IFR vessel. Figure 5-11 shows the characteristics of the
       permanently affixed roof applicable to a vessel converted from an EFR to an IFR, and Figure 5-10
       shows the characteristics of the floating deck applicable to an EFR converted to an IFR. The
       types of seals applicable to an EFR converted to an IFR would be the same as those for an IFR
       vessel described in Section 4.1.2.3 of the Benzene Storage Inspection Manual3 and its associated
       figures.

5.4  WASTEWATER

       The HON regulates wastewater streams that are generated when HAP's listed on Table 9 of
       Subpart G of the HON exit the last recovery device or chemical manufacturing process unit
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      ••••••••••••^^^••BBBB^^^^^BBBHI^^^^^^^^^^^^^^^^^^^^^™^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^™

       equipment. Water that contacts HAP's may be categorized as in-process liquid streams, process
       wastewater, maintenance wastewater, or cooling water. Process wastewater is in-process liquid
       streams that have been discarded and constitutes the majority of wastewater generated at a
       SOCMI facility. There are requirements under the HON applicable to in-process liquid stream.
       Maintenance wastewater is generated periodically.  Cooling water is not categorized as
       wastewater.

       In addition to the process wastewater requirements, the HON regulates the emissions from certain
       process waters.  Specifically, it provides control requirements for equipment coming in contact
       with certain liquid streams containing hazardous air pollutants in open systems within the
       manufacturing process.

       Examples of process wastewater include, but are not limited to, water used to wash impurities
       from organic products or reactants, water used to cool or quench organic vapor streams through
       direct contact, condensed steam from jet ejector systems pulling vacuum on vessels containing
       organics, product and feed tank drawdown. Maintenance wastewater streams include, but are not
       limited to, those generated by descaling heat exchanger tubing bundles, cleaning distillation
       column traps, draining of pumps into an individual drain system, and wastewater generated during
       equipment washes and spill cleanups.  Cooling water is water that has been contaminated with
       organic HAP's by leaking heat exchange systems.

       Process wastewater typically passes through a series of collection units and primary and
       secondary treatment units.  As defined in the HON, the wastewater emission point at a SOCMI
       source comprises numerous pieces of equipment such as wastewater tanks, surface
       impoundments, containers, individual drain systems, oil-water separators, treatment systems,
       closed-vent systems, and control devices. The wastewater requirements of the HON apply at the
        point where the wastewater stream exits the last recovery device. Each of the wastewater
        collection and treatment units must be inspected to ensure compliance with the HON.

        Collection and treatment scenarios for process wastewater are facility-specific.  The flow rate and
        organic composition of process wastewater streams at a particular facility are functions of the
        processes used and influence the sizes and types of collection and treatment units that must be
        employed. Table 5-1 lists common components of wastewater collection and treatment systems
        at SOCMI facilities.  The following sections briefly discuss each of these emission components. A
        detailed discussion of wastewater collection and treatment systems, including diagrams, typical
        design parameters, emission mechanisms, and factors affecting emissions, is contained in the
        Control Technology Center (CTC) document.4 In addition, emission estimation models and
        example calculations for VOC emissions are presented in Appendices A and B of the same
        document.
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            TABLE 5-1. COMMON COMPONENTS OF WASTEWATER COLLECTION SYSTEMS
                                   AND TREATMENT PROCESSES
                      Waste Management Units and Treatment Processes3:

                                 Biological treatment basins
                                 Clarifiers
                                 Containers
                                 Drains
                                 Equalization basins or neutralization basins
                                 Junction boxes
                                 Lift stations
                                 Manholes
                                 Oil-water separators
                                 Steam strippers
                                 Sumps
                                 Surface impoundments
                                 Treatment tanks
                                 Trenches
                                 Weirs
        aThis list includes equipment that may be handling in-process streams and not handling
         wastewater.

 5.4.1  Individual Drain Systems

        Wastewater streams from various equipment throughout a given process are introduced into the
        collection system through process drains. Individual drains usually connect directly to the main
        process sewer line, but may also drain to trenches, sumps, or ditches. Some drains are
        dedicated to a single piece of equipment, while others, known as area drains, serve several units.
        In the HON, "individual drain system" is defined as the stationary system used to convey
        wastewater streams or residuals to a waste management unit or to discharge or disposal. The
        term includes all hard-piping, process drains and junction boxes, together with their associated
        sewer lines and other junction boxes, manholes, sumps, and lift stations conveying wastewater
        streams or residuals.  A segregated stormwater sewer system, which is a drain and collection
        system designed and operated for the sole purpose of collecting rainfall-runoff at the facility, and
        which is segregated from all other individual drain systems, is excluded from the definition.

 5.4.2  Manholes

        Manholes are service  entrances into process sewer lines that permit inspection and cleaning of
        the sewer line. They are placed at periodic lengths along the sewer line or where sewers intersect
        or change significantly in direction, grade, or line diameter. A typical manhole opening is about 2
        ft in diameter and is covered with a heavy cast-iron plate that contains two  to four holes so that
        the manhole cover can be more easily grasped for removal.
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5.4.3  Trenches

       Trenches are used to transport wastewater from the point of process equipment discharge to
       wastewater collection units. In older plants, trenches may be the primary mode of wastewater
       transportation in the collection system. Trenches are often interconnected throughout the process
       area and handle equipment pad water runoff, water from equipment wash down and spill
       cleanups, and process wastewater discharges.  Trench length is determined by the locations of
       the process equipment and the downstream collection system units, and typically ranges from 50
       to 500 ft. Depth and width  are dictated by the flow rate of the wastewater discharged from
       process equipment and must be sufficient to accommodate emergency wastewater flows from the
       process equipment. Trenches are typically open or covered with grates.

5.4.4  Sumps

       Sumps are used to collect and equalize wastewater flow from trenches before treatment. They
       are usually quiescent and open to the atmosphere. Sumps are sized based on the total flow rate
       of the Incoming wastewater stream.

5.4.5  Junction Boxes

       Ajunction box is defined as a manhole or access point to a wastewater sewer line or lift station. A
       junction box may combine multiple wastewater streams into one stream which flows downstream.
       Generally, the flow rate from the junction box is controlled by the liquid level in the junction box.
       Junction boxes  are either square or rectangular and  are sized based on the total flow rate of the
       entering streams.  Junction boxes are typically open, but may be closed (for safety) and vented to
       the atmosphere.

5.4.6  Lift Stations

       A lift station is normally the last collection unit before the treatment system and accepts
       wastewater from one or several sewer lines. The main function of the lift station is to collect
       wastewater for transport to the treatment system.  A pump provides the necessary head pressure
       for transport and is usually  designed to switch on and off based on  preset high and low liquid
       levels. Lift stations are typically rectangular in shape and greater in depth than length or width
       and are either open or closed and vented to the atmosphere.

5.4.7  Weirs

       Weirs act as dams in open  channels. The weir face is usually aligned perpendicular to the bed
       and the walls of the channel.  Water from the channel normally overflows the weir but may pass
       through a notch, or opening, in the weir face. Because of this configuration, weirs provide some
       control over the level and flow rate through the channel.  Weirs may also be used for wastewater
       flow rate measurement.  Water overflowing the weir may proceed down steps, which aerates the
       wastewater. This increases diffusion of oxygen into the water, which may benefit the
       biodegradation  process (often the next treatment step).  However, this increased contact with air
       also accelerates the volatilization of organic compounds contained  in the wastewater.
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 5.4.8  Oil-Water Separators

        Oil-water separation is often the first step in wastewater treatment, but oil-water separators may
        also be found in the process area. These units separate and remove 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. 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.

 5.4.9  Equalization Basins

        Equalization basins are used to reduce fluctuations in the temperature, flow rate, pH, and organic
        compound concentrations of the wastewater going to the downstream treatment processes. The
        equalization of the wastewater flow rate results in more uniform effluent quality from downstream
        units and can also benefit biological treatment performance by damping any influent concentration
        and flow rate fluctuations. This damping protects biological processes from upset or failure
        caused by shock loadings of toxic or treatment-inhibiting compounds. Equalization basins
        normally use hydraulic retention time to ensure equalization of the wastewater effluent leaving the
        basin. However, some basins are equipped with mixers or surface aerators to enhance the
        equalization,  accelerate wastewater cooling, or saturate the wastewater with oxygen before
        secondary treatment.

 5.4.10 Treatment Tanks

        Several different types of treatment tanks may be used in wastewater treatment systems  Tanks
        designed for pH adjustment are typically used preceding the biological treatment step.  In these
        tanks, the wastewater pH is adjusted using acidic or alkaline additives to prevent shocking the
        biological system downstream. Flocculation tanks, on the other hand, are usually used to treat
        wastewater after biological treatment. Flocculating agents are added to the wastewater to
        promote the formation or agglomeration of larger particle masses from the fine solids formed
        during biological treatment.  These larger particles precipitate  more readily out of the wastewater
        in the clarifier, which usually follows flocculation in the treatment system.

5.4.11   Biological  Treatment Basins

        Biological waste treatment is normally accomplished using aeration basins.  Microorganisms
        require oxygen  to carry out the biodegradation of organic compounds, which results in energy and
        biomass production. The aerobic environment in the basin is normally achieved with diffused or
     .   mechanical aeration.  This aeration also maintains the biomass in a well-mixed regime  The
        performance of aeration basins is particularly affected by (1) mass of organics per unit area of
        wastewater, (2) temperature and wind patterns, (3) hydraulic retention time, (4) dispersion and
        mixing characteristics, (5) characteristics of the solids in the influent, and (6) amount of essential
        microbial nutrients present.

5.4.12  Clarifiers

        The primary purpose of a clarifier is to separate solids from wastewater through gravitational
        settling. Most clarifiers are equipped with surface skimmers to clear the water of floating oil
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       deposits, grease, and scum. Clarifiers also have sludge-raking arms that remove the
       accumulation of organic solids that collects at the bottom of the tank. The depth and
       cross-sectional area of a clarifier are functions of the settling rate of the suspended solids and the
       thickening characteristics of the sludge. Clarifiers are designed to provide sufficient retention time
       for the settling and thickening of these solids.

5.4.13 Surface Impoundments

       Surface impoundments are used for evaporation, polishing, storage before further treatment or
       disposal, equalization, leachate collection, and as emergency surge basins.  They may be
       quiescent or mechanically agitated.

5.4.14 Containers

       Containers which are compatible with the material(s) held may be used to collect residuals
       generated by treatment prior to offsite shipment and for other purposes that require mobility.
       Containers may vary in size and shape ranging from a 55-gallon drum to a tanker truck.

5.5 REFERENCES

1.      Memorandum from Paul, D., J.A. Probert, and R. Mead (Radian Corporation), to Dr. Janet S.
        Meyer (U.S. Environmental Protection Agency, Standards Development Branch).
        Characterization of Product Accumulator Vessels.  January 18,1994. p. 20.

2.      U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Stationary
        Source Compliance Division. Level II Inspection Manual: Benzene Transfer Operation.
        Washington, DC. January 1993.

3.      U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Stationary
        Source Compliance Division. NESHAP Inspection Manual: Benzene Storage Vessels. EPA-
        455/R-92-006. Washington, DC. September 1991.

4.      U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Office of
        Research and Development. Control Technology Center, Industrial Wastewater Volatile Organic
        Compound Emissions -  Background Information for BACT/LAER Determinations. EPA 450/3-90-
        004.  Research Triangle Park, NC. January 1990.
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                          6.0 DESCRIPTION OF EMISSION CONTRO
                                       !• TECHNOLOGIES51
       Combustion is the most universally applicable technique for control of organic HAP and VOC
       emissions. Combustion devices can be applied to reactor, air oxidation, and distillation process
       vents, storage vessels, or emissions from transfer racks and wastewater streams and can
       achieve efficiencies of 98 percent reduction in organic HAP or VOC emissions, or an outlet HAP
       or VOC concentration of 20 parts per million by volume  (ppmv) dry basis, corrected to 3 percent
       oxygen. Combustion control devices are described in Section 6.1.

       As described in Section 5.1, recovery devices are used  in many chemical manufacturing
       processes. The most common types of recovery devices are described in Section 6.2.  Recovery
       devices are not considered "control devices" for purposes of meeting the 98 percent reduction
       requirements of the process vents provisions of the HON.  However, the HON allows the use of
       recovery devices to achieve compliance if certain conditions are met. If a recovery device is used
       to increase the total resource effectiveness (TRE) index value to greater than 1.0, then the
       process vent is considered to be in compliance. The TRE is an index of the cost effectiveness of
       control and is calculated from measurements or estimates of vent stream flow and HAP and VOC
       concentrations after the final recovery device. A recovery device may also be used alone or in
       combination with one or more control devices to meet the 98 percent reduction if the following
       three conditions are met: (1) the control system was installed before December 31,1992; (2) the
       recovery device used to meet the 98 percent reduction is the last recovery device before release
       to the atmosphere; and (3) the recovery device alone or in combination with one or more control
       devices can meet the 98 percent reduction but is not capable of reliably reducing emissions to a
       concentration of 20 ppmv or less.

       A recapture device may also be
       used to meet the 98 percent
       reduction or 20 ppmw
       concentrations. Recapture
       devices are considered control
       devices for the purposes of the
       process vent provisions and are
       the same types of devices as
       recovery devices, however the
       material that is recovered is not
Section &0 Oescriptlon of Emission Control Technologies.
6.2
6.S

6.4
Combustion Control Devices ,,,.,,,,,, t,. t.,
ProdtictReeoVery and Recapture Devices
Control Techniques Specific to Transfer
Operations
Coetrol Techniques Specific to Storage Vessels .
Control Techniques Specific to Wastewaler >.„,
       normally used, reused, or sold.  For example, the materials may be recovered primarily for
       disposal. The most common recapture devices are also described in Section 6.2.

       Information on the specific compliance options for process vents, transfer operations, storage
       vessels, and wastewater streams are presented in Section 7.

6.1  COMBUSTION CONTROL DEVICES

       Combustion control devices include incinerators, flares, boilers, and process heaters.
       Combustion control devices operate on the principle that any VOC heated to a high enough
       temperature in the presence of sufficient oxygen will oxidize to carbon dioxide and water.  The
       theoretical combustion temperature varies because VOC's are oxidized at different temperatures,
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       depending on their properties. A consistent VOC destruction efficiency can usually be achieved in
       combustion devices, regardless of the amount and type of VOC in the vent stream. Scrubbers
       can be used downstream of combustion control devices (other than flares) to treat halogenated
       streams.  Scrubbers reduce emissions of halogens and hydrogen halides, such as chlorine and
       hydrogen chloride, formed during combustion.

6.1.1  Thermal Incinerators

       Thermal incinerators are usually refractory-lined chambers containing a burner (or set of burners).
       An efficient thermal incinerator provides: (1) a chamber temperature high enough to completely
       oxidize the VOC's; (2) sufficient mixing of combustion products, air, and the process vent streams;
       and (3) sufficient residence time to allow for complete oxidation of VOC's. Figure 6-1 shows the
       premixing chamber and combustion chamber of a discrete burner thermal incinerator. As shown
       in the figure,  heat can be recovered to preheat combustion air or the process vent stream, or to
       generate steam. All thermal incinerators operate using excess air to ensure a sufficient supply of
       oxygen.
                                                                                        Stack-
             Vent Stream
                Inlet
                 (2)
         Auxilltzuy
          Burner
         (Discrete)
                                                                             Optional Heat
                                                                              Recovery
                                                                                 (6)
                                                 V
                                              Combustion
                                               Chamber
                                                 (5)
                      Figure 6-1.  Discrete Burner, Thermal Incinerator
        Thermal incinerators can achieve at least 98 percent destruction for most VOC's. For vent
        streams with VOC concentrations below 1,000 ppmv, all new thermal incinerators can achieve
        outlet concentrations of 20 ppmv or lower. Thermal incinerators are technically feasible control
        options for most vent streams.  Excessive fluctuations in flow rate may prevent the use of a
        thermal incinerator; in such situations, a flare could be used.
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6.1.2  Catalytic Incinerators

       Catalytic incinerators operate at lower temperatures than thermal incinerators because some
       VOC's are oxidized at lower temperatures in the presence of a catalyst.  A schematic of a catalytic
       incinerator is shown in Figure 6-2.  The vent stream is preheated in the mixing chamber, and
       oxidation takes place on the catalyst bed. As with thermal incinerators, heat can be recovered
       from the exiting gas stream.
                                                                                   To Atmosphere
                                                                                      Stack
           Auxiliary
           Burners
             (3)
         Catalyst Bed
                                                   ,
        Vent Stream
           (1)   -
          Burners
Mixing Chamber
     (2)
                                                                           Waste Heat
                                                                         Recovery (Optional)
                                                                               (5)
                               Figure 6-2.  Catalytic Incinerator


       Catalytic incinerators can achieve overall VOC destruction efficiencies of 95 to over 98 percent.
       The efficiency depends on temperature, oxygen content, catalyst activity, and the characteristics
       and concentration of the VOC. Catalytic incinerators are typically used for vent streams with
       stable flow rates and stable concentrations.  They cannot be used on vent streams that poison or
       block the catalyst reactive sites, or on vent streams with high inlet concentrations or flow rates.
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6.1.3 Industrial Boilers and Process Heaters

        Industrial boilers and process heaters combust VOC's by incorporating the vent stream into the
        inlet fuel or by feeding the vent stream into the boiler or heater through a separate burner.
        Industrial boilers are used to produce steam.  When boilers fire natural gas, forced- or natural-
        draft burners mix the incoming fuel and combustion air. A VOC-containing vent stream can be
        added to this mixture or it can be fed into the boiler through a separate burner. The majority of
        industrial boilers used in the chemical industry are of watertube design, where hot combustion
        gases contact the outside of heat transfer tubes which  contain hot water and steam. Process
        heaters are used to raise the temperature of process streams using a similar tube design, where
        the process fluids are contained in the tubes. Heat recovery from the exiting gas stream is
        achievable for both industrial boilers and process heaters.

        Boilers and process heaters can achieve efficiencies of at least 98 percent. They can be used to
        reduce VOC emissions from any vent streams that will not reduce the performance or reliability of
        the boiler or process heater. For example, the varying flow rate and organic content of some vent
        streams can lead to explosive mixtures or flame instability.  Boilers and process heaters are most
        applicable where the potential exists for heat recovery from the combustion of the vent stream.
        Vent streams with a high VOC concentration and high  flow rate can provide enough equivalent
        heat value to act as a substitute for fuel. Because boilers and process heaters cannot tolerate
        wide fluctuations in the fuel supply, they are not widely used to reduce VOC emissions from batch
        operations and other noncontinuous vent streams. Vent streams with sulfur or halogenated
        compounds are not usually combusted in boilers or process heaters because these streams are
        corrosive.

 6.1.4  Flares

        Flaring is an open combustion process  in which the oxygen necessary for combustion is provided
        by the air around the flame. High combustion efficiency in a flare is governed by flame
        temperature, residence time of the organic compound in the combustion zone, turbulent mixing to
        complete the oxidation reaction, and the amount of available oxygen.  Steam-assisted elevated
        flares are the most common type used in the chemical industry (see Figure 6-3).  The high flow
        rate of the vent stream into the flare requires more combustion air than diffusion of the
        surrounding air to the flame can supply. Steam injection nozzles are added to increase gas
        turbulence.

        Flares can achieve 98 percent destruction efficiencies. Flares are most applicable to vent
        streams with wide flammability limits, low auto-ignition temperatures, and high heat contents.
        Flares can be designed to control both  normal process releases and emergency upsets. Flares
        can be used to control almost any VOC stream and can handle fluctuations in VOC concentration,
        flow rate, heat content, moisture content, and inerts content. Flaring is appropriate for continuous,
        batch, and variable flow vent streams.  However, halogenated or sulfur-containing vent streams
        are usually not flared because they can corrode the flare tip or cause the formation of acid gases
        or sulfur dioxide.  The HON provisions  do not allow vent streams above a specified halogen
        content to be routed to a flare.
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                                                                                Combustion Zone
                                                                                     (10)
                                                    Steam Nozzles
                                                        (9)
                                                    Gas Barrier
                                                       (6)
                                                                                            Flare Tip
                                                                                              (8)
 Pilot Burners
     P)
                                                         Flare Stack
                                                            (5)    -
                    Gas Collection Header
         Vent Stream-^"
                              Knockout
                               Drum
                                (2)
1—  Steam Line


    Ignition
     evice


     Airline

     Gas Une
                                         Drain
                       Figure 6-3.  Steam-Assisted Elevated Flare System
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                               •^m^m

6.1.5  Halogenated Streams

       Combustion equipment used for control of halogenated streams is usually followed by additional
       control equipment to remove corrosive combustion products (acid gases). The flue gas
       temperature is lowered, and the flue gas is then routed to a halogen reduction device such as a
       packed tower or liquid jet scrubber. Absorption equipment (e.g., scrubbers) can also be used as
       recovery devices  and are discussed in Section 6.2 of this manual.

6.2  PRODUCT RECOVERY AND RECAPTURE DEVICES

       Product recovery devices and recapture devices include absorbers, carbon adsorbers, and
       condensers, and  the specific device used is determined by the vent stream characteristics. These
       characteristics affect the performance of recovery or recapture devices, therefore no single
       technology is applicable to all vent streams.

6.2.1  Condensers

       Condensation is a separation technique in which one or more volatile components are separated
       from a vapor mixture through saturation followed by a phase change. Condensation can be
       achieved by lowering the temperature at a constant pressure, and refrigeration can be used to
       obtain the lower temperatures needed for compounds with lower boiling points.

       Surface condensers and direct contact condensers are the two most commonly used types.  In
       surface condensers, heat transfer occurs through tubes or plates in the condenser. Thus, the
       coolant fluid does not contact the vent stream which allows for reuse of the coolant fluid.
        Furthermore, the VOC's can be directly recovered from the gas stream.  A shell-and-tube
        condenser which circulates the coolant fluid on the tube side is shown in Figure 6-4. Direct
        contact condensers spray the coolant directly into the vent stream.  Therefore, the coolant cannot
        be reused directly and VOC's cannot be recovered without further processing.
          Figure 6-4.  Schematic Diagram of a Shell and Tube Surface Condenser
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        Condensers may be used to recover raw materials and/or products.  The removal efficiencies of
        condensers range from 50 to 95 percent, and the efficiency is dependent upon the vent stream
        flow rate, concentration, temperature, moisture content, and physical properties.  Condensers are
        more economically feasible for streams with higher condensation temperatures. Vent streams
        with high concentrations of non-condensables will require a condenser with a larger surface area.

 6.2.2 Adsorption

        Adsorption is a mass-transfer operation where the gas-phase (adsorbate) is captured on the solid-
        phase (adsorbent) by physical or chemical means. A physically adsorbed molecule is easily
        removed from the adsorbent, whereas, the removal of chemisorbed molecules  is much more
        difficult.

        The most common industrial adsorption systems use activated carbon as the adsorbent
        Activated carbon captures organic vapors by physical adsorption. Since oxygenated adsorbents
        selectively capture water vapor, they are not suitable for high-moisture process vent streams
        Activated carbon beds are regenerated with steam or nitrogen which release the captured vapors
        Figure 6-5 shows a typical fixed-bed, regenerative carbon adsorption system. When one bed is
        saturated, the vent stream is routed to an alternate bed while the saturated carbon bed is
        regenerated. The steam-laden vapors from regeneration are sent to a condenser and then to a
        VOC recovery system to separate the VOC's from the condensed steam.

        Continuous VOC removal efficiencies of more than 95 percent are achievable using adsorption
       The VOC removal efficiency of an adsorption unit depends on the vent stream characteristics  the
        physical properties of the compounds in the vent stream and of the adsorbent, and the condition
       of the bed. Carbon adsorption is not recommended for vent streams with high VOC
       concentrations, high or low molecular weight compounds, mixtures of high and low boilinq point
       VOC's, or vent streams with a high moisture content.

6.2.3  Absorption

       Absorption is the selective transfer of one or more components of a gas mixture (solute) into a
       liquid solvent. Devices based on absorption principles include spray towers, Venturi and wet
       impingement scrubbers, packed columns, and plate columns.  Spray towers have the least
       effective mass transfer capability and are generally restricted to particulate matter removal and
       control of high-solubility gases. Venturi scrubbers are also limited to particulate matter and hiqh-
       solubihty gases. Therefore, VOC control  by gas absorption is limited to packed  or plate columns
       A countercurrent packed  column is shown in Figure 6-6.

       Control efficiencies for absorbers vary from 50 to greater than 95 percent. Efficiency depends on
       the selected solvent, the contact surface area (absorber size), and the temperature  The
       applicability of absorption to vent streams is dependent on the availability of a suitable solvent
       and the solubility of the VOC in the solvent. If a VOC cannot be easily desorbed from the solvent
       then absorption  is less viable. Absorption is usually considered for streams with a VOC
       concentration above 200 to 300 ppmv.

       Scrubbers are used downstream of combustion devices to control  emissions of halogens and
       halogen halides formed during combustion. The typical scrubbing  solvents used are water or a
       caustic solution. Either plate or packed bed scrubbers can be used, and these scrubbers can
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Volume 1
              VOC-Laden
              Vent Stream
                   Fan
            Low
           Pressure  (4)
           Steam
                                         Overview of Emission Points, Control Technologies, and HON Provisions
                                                Vent to
                                              Atmosphere
                                                Adsorber 1
                                                (adsorbing)
                                   Closed
                                                                 Open
                                                    Steam
 Open 	,
-HI
                                                                , Closed
                                                 Adsorber 2
                                                (regenerating)
                                                                          (5)
                                                               I    Condenser   ]
                                                         Decanter and/or
                                                         Distilling Tower
                                                                        (6)
                                              Recovered
                                               Solvent


                                              Water
                    Figure 6-5.  Two-Stage Regenerative Adsorption System
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         Absorbing  (3)
          Liquid In
                                                                     ^  (5} Cleaned Gas Out
                                                                       to Final Control Device
                                                                         or to Atmosphere
                                          ;-  f "^Packing (2) N'v\r,;;
                                                    "         ''
                                               Absorbing Liquid
                                             with VOC out to Disposal
                                             or VOC/Solvent Recovery
                                                                                  (l)VOC-Laden
                                                                                 —  Gas In
                       Figure 6-6.  Packed Tower Absorption Process
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                                         Overview of Emission Points, Control Technologies, and RON Provisions
        have countercurrent or crosscurrent flow.  The type and orientation of the scrubber used depends
       on liquid and gas flow rates.

       Scrubber efficiencies for removal of halogens and halogen halides will vary depending on the type
       of scrubber and the type of solvent used, and the equilibrium relationship between the gas and
       liquid. However, most systems can achieve efficiencies from 90 percent to greater than
       99 percent.

6.3 CONTROL TECHNIQUES SPECIFIC TO TRANSFER OPERATIONS

       Organic HAP and VOC emissions from tank truck and railcar transfer racks can be collected in a
       vapor collection system and  routed to a control device. Unlike process vents, the HON definition
       of "control device" for transfer racks includes recovery devices as well as combustion devices.
       Any device that achieves 98 percent reduction of organic HAP or VOC or achieves a 20 ppmv
       outlet concentration of organic HAP or VOC can be used to comply with the HON transfer
       provisions. Figure 6-7 shows a tank truck vapor return line routed to a vapor recovery device.
       Alternatively, transfer rack emissions can be controlled by using a vapor balancing system or
       routing to a process or fuel gas system.
             Vapor relurn line
Exhaust gas
vented to
atmosphuii:
                  Truck
                  storage   •—»
                  compartments
                Benzene from
                loading terminal
                storage tank
                   Figure 6-7.  Tank Truck Loading with Vapor Recovery
 6.3.1  Vapor Collection System

        Vapor collection systems consist of piping or ductwork that captures and transports to a control
        device organic compounds from the vapor space of a transport vessel.  Loading rack systems that
        incorporate the product and vapor lines into a single system are preferred since both connections
        can be conveniently moved out to the vessel simultaneously. The vapor return line can either be
        a flexible hose or a metal pipe incorporated into the loading rack arrangement using a dual style
        orientation. Figure 6-7 shows a tank truck with a vapor collection system (vapor return line), and
        Figure 6-8 illustrates a dual arm loading rack.

        Section 4.2.1  of the Benzene Transfer Operation Inspection Manual1 provides additional details on
        transfer vapor collection systems and control techniques, however, this section also discusses the
        transfer requirements of the Benzene NESHAP. In some cases, these requirements will differ
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        from the requirements of the HON. For example, the Benzene NESHAP applies to marine
        vessels, but the HON does not.
                                                                 Vaoor line
       Hatch cover
       Liquid line

Lift cylinder
                                                      Truck tank shell
6.3.2 Vapor Balancing
                                              Drop tube
                            Figure 6-8. Dual Arm Loading Rack
       Vapor balancing is another means of collecting vapors and reducing emissions from transfer
       operations. Vapor balancing is most commonly used where storage facilities are adjacent to the
       loading facility.  As shown in Figure 6-9, an additional line is connected from the transport vessel
       to the storage tank to return any vapor that is displaced from the transport vessel to the vapor
       space of the storage vessel from which the transferred liquid was pumped. Because this is a
       direct volumetric exchange, there should be no losses to the atmosphere.
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           Overview of Emission Points, Control Technologies, and HON Provisions
            O>
MINIM
n
  Figure 6-9. Vapor Balancing System
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 6.3.3 Route to a Process or Fuel Gas System

        Emissions from transfer operations may be routed to a process or to a fuel gas system to comply
        with the transfer control requirements. Fuel gas systems contain large boilers or process heaters
        that easily combust the HAP and VOC emissions from transfer operations  Section 6 1 3
        describes industrial boilers and process heaters. Section 7.2.3 describes the conditions that must
        be met for emissions routed to a process.

 6.4 CONTROL TECHNIQUES SPECIFIC TO STORAGE VESSELS

       The control techniques to reduce emissions from storage vessels include equipment designs
       (e.g., seal design and fittings closure) and work practices.

 6.4.1  Fixed-Roof Vessels

       Emissions from a fixed-roof vessel may be reduced by equipping it with either a floating roof (i e
       converting it to an IF vessel) or by using a closed vent system routed to a 95-percent efficient
       control device. Under the HON, if a fixed roof vessel is equipped with an IFR, it is considered an
       IFR vessel and would be required  to be equipped with certain controls and meet certain work
       practices for an IFR as described in Section 6.4.2.

       A closed vent system captures the vapors released by the fixed roof vessel and transfers them to
       a product recovery or combustion control device. Refer to Section 5.2 of this manual for a
       description of product recovery and combustion control devices. These same devices would be
       allowed by the storage provisions.

       A closed vent system and control device could also be applied to a horizontal tank. Because of
       the tank configuration, a floating roof cannot be applied to a horizontal tank.

6.4.2  Floating Roof Vessels

       As discussed in Section 5.3.2, the three types of floating roof vessels are IFR vessels, EFR
       vessels, and EFR vessels converted to IFR vessels.

       There are three methods for controlling emissions from floating roof vessels:  applying controls to
       deck fittings, employing certain types of seals, and employing certain work practices.  Examples of
       these three methods are to equip the covers on certain deck fittings with gaskets, to equip an EFR
       or IF with a liquid-mounted seal instead of a vapor-mounted seal, and to keep all covers
       associated with deck fittings closed at all times except for access, respectively  Refer to
       Sections 4.1.2.1 and 4.1.2.2 in the Benzene Storage Inspection Manual2 for descriptions of the
       equipment and work practice controls that may be applied to deck fittings on EFR vessels and IFR
       vessels, respectively.  For information on applying controls to the deck fittings of an EFR
       converted to an IFR, refer to the discussion about controls applied to fittings of EFR vessels in
       Section 4.1.2.1 of the  Benzene Storage Inspection Manual.2 For a description of the types of
       seals that can be used to control emissions from floating roof vessels, refer to Section 4 1 2 3 of
       the Benzene Storage  Inspection Manual.2

       The deck fitting control requirements in the HON are similar  but not equivalent to the control
       requirements of the Benzene NESHAP which are described  in the Benzene Storage Inspection
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                                         Overview of Emission Points, Control Technologies, and HON Provisions
                                        •^^^•mmB^M^^i^™™^"^^"^™^™™^1"^^"*^™^™•^•"

       Manual2 The HON specifies a few additional deck fitting controls that are not discussed in the
       Benzene Storage Inspection Manual.2 For example, for EFR vessels the HON specifies the
       following three additional controls: (1) roof drains must have a slotted membrane fabric cover that
       covers 90 percent of the area of the opening, (2) openings with covers must be bolted when
       closed and (3) guide pole wells must have a sliding cover or flexible fabric sleeve seal and, if the
       guide pole is slotted, a gasketed float inside the guide pole.  For IFR vessels, the HON specifies
       the following two additional controls: (1) ladder wells must have a gasketed sliding cover, and
       (2) rim vents must be gasketed and closed except when the IFR is not floating on the stored liquid
       or when the pressure beneath the rim seal exceeds the manufacturer's recommended setting.
       Sections 4.1.2.1 and 4.1.2.2 in the Benzene Storage Inspection Manual2 should be consulted to
       gain familiarity with the control options for deck fittings on floating roof vessels.

6.4.3  Route to a Process or a Fuel Gas System

       Similar to transfer operations, emissions from storage vessels may be routed to a process or to a
       fuel gas system to comply with the storage vessel requirements. Fuel gas systems contain large
       boilers or process heaters that easily combust the HAP and VOC emissions from storage vessels.
       Section 6.1.3 describes industrial boilers or process  heaters.  Section 7.3.3 describes the
       conditions that must be met for emissions routed to a process.

6.5 CONTROL TECHNIQUES SPECIFIC TO WASTEWATER

       The technologies used to reduce emissions from SOCMI wastewater systems involve a
       combination of control equipment and good work practices. This section describes applicable
       emission control technologies for collection and waste management units, and treatment
       processes  For each of the control technologies discussed in this section, the design and
       operation of the control device or system is described including an explanation of the physical
        and/or chemical processes that destroy the organic HAP's  or remove them from the wastewater
        stream Additionally, the factors affecting the efficiency of the control device, such as operating
        parameters are provided. Several emission control technologies including combustion
        technologies (e.g., flares, incinerators), fixed and floating roofs, and product recovery devices
        (e g condensers, adsorbers) that can be used to control emissions from wastewater are also
        applicable to process vents, storage vessels, and/or transfer operations.  In such cases, this
        section discusses the applicability of the control technology to emissions  from wastewater and
        refers to the respective sections in this document for details.

 6.5.1 Waste Management Units

        As described in Section 5.4, wastewater collection systems and waste management units are the
        equipment structure(s) and/or devices used to convey, store, treat, or dispose of wastewater
        streams  or residuals. Examples of waste management units include wastewater tanks, surface
         impoundments individual drain systems (which include process drains, junction boxes, manholes,
         etc) and biological treatment units.  Examples of equipment that may be waste management
         units' include containers, air flotation units, oil-water separators or organic-water separators, or
         organic removal devices such as decanters, strippers, or thin-film evaporation units.  If such
         equipment is used for recovery, then it is part of a chemical  manufacturing process unit and is not
         a waste  management unit. Emissions from wastewater collection system components must be
         controlled through the use of emission suppression technologies. Suppression technologies
         reduce volatilization of HAP's and prevent the release of volatile HAP's to the ambient air.  This
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        allows the treatment process(es) following the collection system to achieve greater removal and/or
        destruc ion of HAP s. The following sections describe the suppression techniques suitable for the
        different components in a wastewater collection system.

 6.5.1.1  Controls for Process Drains

        Water seal controls reduce emissions by limiting the effects of convection and diffusion on VOC's
        in the wastewater Water seals can be either P-legs or seal pots.  P-leg sealed drains are similar
        to open drains, which are usually 4 to 6 inches in diameter and extend vertically to a height of 4 to
        6 inches above grade, except that a "P" bend in the pipe is found below grade  The P-bend
        provides a liquid seal for the individual drain, similar to that found in household plumbing  A seal
        pot dram has a cap covering the drain opening, and the bottom edge of the cap extends below the
        evel of the drain entrance. Liquid from the various drain pipes falls into the drain area outside of
        the cap and then flows under the edge of the cap into the drain line. The drain cap can easily be
                            "   entranCe and drain line"  Various drain configurations are illustrated in
        Water seals will result in emission control only if the liquid levels in the water seals are properly
        maintained, thereby minimizing mass transfer from the wastewater to the ambient air Therefore
        the control equipment must be coupled with work practices to ensure maximum effectiveness.  '

        A second method for controlling VOC emissions from process drains is to use a closed drain
        system.  In closed dram systems, emission control is achieved by mechanical and/or physical
        barriers inherent to the drain design and are not dependent on operating procedures (e q
        maintaining an appropriate level of water). Typically, a drain riser extends approximately 12 to 18
        inches above grade.  The top of the riser is completely sealed with a flange.  Drain pipes are
        welded directly to the riser.  This line is normally closed with a valve, but provides access to the
        closed dram system for intermittent and infrequent needs such as pump drainage  Hoses or
        flexible lines can be connected to the riser valve from the liquid source. The emission control
        achieved by a closed system can be as high as 95 percent, depending on the maintenance of the
        system. A diagram illustrating a closed drain system is in Figure 6-1 1
6-5"1'2  Controls for Junction Boxes. Manholes. Trenches. Weirs. Sumos
         Stations
dLjft
       Control of emissions from individual drain system components is based on an equipment standard
       supported by appropriate work practices. For example, the most feasible method of reducinq
       emissions from a junction box is by installing a tightly fitting solid cover. Figure 6-12 shows a
       typical junction box. The cover reduces the exposure of the wastewater to the atmosphere
       thereby minimizing the effects of diffusion and convection on the HAP's present in the wastewater
       stream. The cover may be vented to reduce the buildup of pressure and/or explosive
       concentrations of gases or have openings necessary for operation, inspection or maintenance. In
       such cases the vent could be routed to a recovery or combustion control device to prevent the
       volatHized HAP s from being released to the atmosphere. Emission suppression may also be
       achieved through the use of other totally enclosed equipment such as hard-piping in place of open
       irGrlCn GS.
                                                1-53
                                                                                   September 1997

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               Drain
Overview of Emission Points, Control Technologies, and HON Provisions


                                             Drain
                                             Pipe
               Drain
Open, Unsealed
Configuration A
                              •S
                      (Alternate Offset
                      configuration)
                                             Drain
                                             Riser
                                                       •s
                                  P-LegSeal
                                Configurat on B
          Drain
f
                       Seal
                       Pot
                             Drain
                                              Drain
                                              *"
                     Figure 6-10.  Types of Drains
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              Process Unit
               Boundary
                                                       Sump Pumps
                                Figure 6-11. Closed Drain System
                                                                                   Oily Waste Pumped
                                                                                    To Intermediate
                                                                                    Storage Tanks or
                                                                                               tor
Underground
 Collection
   Tank
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                                  Vent
                                         Overview of Emission Points, Control Technologies, and HON Provisions
Gas Tight
  Cover
                                                                            Grade
                                                                               Concrete
                       Water

                            Figure 6-12.  Drain System Junction Box

6.5.1.3   Controls for Wastewater Tanks and Oil-Water Separators

       Emissions from wastewater tanks and oil-water separators can be reduced by installing either a
       floating roof over the liquid surface of the separator or tank, or a fixed roof vented to a control
       device. The roof reduces the effects of evaporation, wind speed, and solar radiation.
       Fixed roofs can be constructed of various materials and can be mounted on the sides of the tank
       or separator or supported by horizontal beams set in the sides of the tank or separator. The
       space between the roof and the edge of the tank or separator, and the spaces around any access
       doors, can be sealed with gaskets to prevent the release of any HAP's that volatilize from the
       wastewater. The vent from the tank would be routed to a recovery or combustion control device.

       Floating roofs actually float on the liquid surface, thereby minimizing the vapor space above the
       wastewater.  Floating roofs can be constructed of various materials including plastic, glass foam
       blocks, aluminum pontoons, or fiberglass. Seals are placed between the roof and the wall of the
       separator to minimize VOC emissions.  A primary seal consists of a foam or liquid-filled seal
       mounted, in contact with the liquid, between the floating  roof and the wall of the separator.
       Emission reductions from floating roofs can be greater than 95 percent for tanks and oil-water
       separators holding wastewater. The effectiveness of the roofs in reducing emissions depends on
       a variety of factors - the most important being maintenance of the seals around the roofs, doors,
       and other openings. The HON includes work practices to ensure optimal performance of the
       control technology. Section 6.4 of this document provides additional details on both fixed and
       floating roofs.
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6.5.1.4 Containers

        The technologies used for controlling emissions from containers include the use of covers,
        submerged-fill pipes, and enclosures. When wastewater or residuals from wastewater treatment
        are added to a container, use of a submerged-fill pipe minimizes the loss of HAP's during filling.
        As discussed in Section 5.2 of this manual, in submerged loading the fill pipe is below the liquid
        level, thus reducing the amount of turbulence and resulting in lower vapor generation. Covers
        reduce losses due to evaporation and wind. Any container that must be opened can be placed in
        an enclosure that is vented to a closed-vent system and control device. The conveyance of the
        gases to a control device reduces the potential for buildup of pressure and/or explosive
        concentrations of gases in the enclosure. To be subject to the HON, a container must have a
        capacity greater than or equal to 0.1 m3.

6.5.2  Treatment Processes

        For wastewater, the primary treatment processes  are steam stripping and biological treatment.
        This section provides a detailed discussion of each.

6.5.2.1  Steam Stripping

        Steam stripping involves  the fractional distillation of wastewater to remove HAP's. As the
       wastewater flows down the column, it contacts the steam flowing countercurrently up the column.
        Organic compounds are vaporized through heat transfer from the steam. As the organics
       vaporize in the column, they are transferred from the liquid phase into the gas phase.  The
       vaporized organic constituents flow out the top of the column with any uncondensed steam and
       undergo a phase change to a liquid in the overhead condenser. From the condenser, the liquid is
       sent to a decanter where the organic compounds separate from the condensed steam due to
       differences in density (e.g., the organic layer may float on top of the aqueous phase). The organic
       layer is usually either recycled and reused in the process or incinerated in an on-site combustion
       device for heat recovery.3 If the organic layer is reused  or recycled then the steam stripper is
       considered part of a chemical manufacturing process unit, not a waste management unit.

       The wastewater effluent leaving the bottom of the steam stripper is usually either routed to an on-
       site wastewater treatment plant and discharged  to a National Pollutant Discharge Elimination
       System (NPDES)-permitted outfall, or sent to a publicly-owned treatment works (POTW).

       Steam stripper systems may be operated in batch  or continuous mode.  Batch steam strippers are
       more prevalent when the  wastewater feed is generated by batch processes, when the
       characteristics of the feed are highly variable, or when small volumes of wastewater are
       generated. Batch strippers may also be used if the wastewater contains relatively high
       concentrations of solids, resins, or tars.

       In contrast to batch  strippers, continuous steam  strippers are designed to treat wastewater
       streams with relatively consistent characteristics. A typical continuous steam stripper system is in
       Figure 6-13.  Design of the continuous stripper system is based on the flow rate and composition
                                                1-57
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                                        Overview of Emission Points, Control Technologies, and HON Provisions
                       Figure 6-13.  Continuous Steam Stripper System.
                                                1-58
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       of a specific wastewater feed stream or combination of streams. Multi-stage, continuous strippers
       normally achieve greater efficiencies of organic compound removal than batch strippers.

       Wastewater streams continuously discharged from process equipment are usually relatively
       consistent in composition.  Such wastewater streams would be efficiently treated with a
       continuous steam stripper system. However, batch wastewater streams can also be controlled by
       continuous steam strippers by incorporating a feed tank with adequate residence time to provide a
       consistent outlet composition. In such cases, the feed tank serves as a buffer between the batch
       process and the continuous steam stripper. During periods of no wastewater flow from the batch
       process, wastewater stored in the feed tank is fed to the stripper at a relatively constant rate.

       Steam stripping achieves emission reductions of 0 to 99 percent, based on the chemical
       characteristics (e.g., strippability) of the wastewater stream.  However, 95 to 99 percent reduction
       can be achieved for the majority of organic compounds regulated by the HON. The organic
       compound removal performance of the steam stripper depends on the degree of contact between
       the steam and the wastewater. Several factors affecting the degree of contact that occurs in the
       steam stripper column are: (1) the dimensions of the column (height and diameter); (2) the
       contacting media in the column (trays or packing); and (3) operating parameters such as the
       steam-to-feed ratio, column temperatures, and pH of the wastewater.

       Steam stripping is most applicable to treating wastewaters with organic compounds that are highly
       volatile  and have a low solubility in water. Oil, grease, and solids content and the pH  of a
       wastewater stream also affect the feasibility of steam stripping. High levels of oil, grease, and
       solids can cause fouling of the stripper system.  High or low pH may prove to be corrosive to
       equipment.  However, these problems can usually be circumvented by design or wastewater
       preconditioning techniques. Section 2.2.3 of "Hazardous Air Pollutant Emissions from Process
       Units in the SOCMI — Background Information for Proposed Standards, Volume 1B:  Control
       Technologies" provides additional details on  steam  stripping.4

6.5.2.2  Biological Treatment

       The use of biological treatment systems as a control technology can be an effective method for
       the removal of numerous HAP's through microbial degradation. Such systems involve the use of
       bacteria, algae, fungi, and  microorganisms to stabilize, absorb, alter, or destroy organic
       compounds. The most common form of biological treatment is aerobic (i.e., in the presence of
       oxygen).  In the presence of excess oxygen, organic chemicals are oxidized by bacteria to carbon
       dioxide and water.  Initially, the wastewater stream(s) entering the system must be equalized in
       order to prevent either the flow rate or concentration from chemically shocking the bacteria.
       Mixing from aerators combines organic compounds and the activated sludge, The effluent is
       allowed to settle in a clarifier where a fraction of the sludge is returned to the aeration lagoon to
       reseed the population of microorganisms. The remaining sludge is usually land disposed.

       The design and operating  parameters of a biological treatment unit are facility-specific and are
       dependent on the composition of the wastewater feed stream.  The primary factors that affect the
       removal of HAP's from wastewater in a biological treatment unit include the food-to-microorganism
       ratio, oxygen availability, mixed  liquor suspended solids ratio, pH, temperature, and residence
       time. Another consideration is the maintenance of a suspended-growth process that generates
        biomass, uses recycled biomass, and periodically removes biomass from the process.
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6.6        REFERENCES

1.     U.S. Environmental Protection Agency, Office of Air Quality Planning Standards, Stationary
       Source Compliance Division. Level II Inspection Manual: Benzene Tranfer Operation.
       Washington, DC. January 1993.

2.     U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Stationary
       Source Compliance Division. NESHAP Inspection Manual: Benzene Storage Vessels.  EPA-
       455/R-92-006. Washington, DC.  September 1991.

3.     LaGrega, Michael and associates. Hazardous Waste Management.  McGraw-Hill, Inc.  New York,
       NY. 1994.

4.     U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Office of
       Research and Development. Hazardous Air Pollutant Emissions from Process Units in  the
       SOCMI — Background Information for Proposed Standards, Volume 1B: Control Technologies.
       EPA-453/D-92-016b. Research Triangle Park, NC.  November 1992.
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                                          Overview of Emission Points
                                    7.0 THE PROVISIONS
 7.1  PROCESS VENT PROVISIONS

        This section summarizes the process vent provisions in §63.113 through §63.118 of Subpart G
        The checklists in Sections 5, 9 and 10 of Volume II provide additional details of the process vent
        provisions.

 7.1.1  Process Vent Definition

        For purposes of the HON, a "process vent" is a gas stream containing greater than 0.005 weight
        percent total organic HAP that is continuously discharged during operation of the unit from an air
        oxidation reactor, other reactor or distillation unit within a chemical manufacturing process unit
        that meets all applicability criteria in §63.100 of Subpart F. Process vents are gas streams
        discharged to the atmosphere (with or without passing through a control device) either directly or
        after passing through one or more recovery devices.  Relief valve discharges, gaseous streams
        routed to a fuel gas system(s), and leaks from equipment regulated under Subpart H are not
        process vents.

7.1.2  Process Vent Group Determination

       Group 1 and Group 2 process vents are defined in §63.111 of Subpart G.  A Group 1 process
       vent is a process vent with a flow rate of 0.005 scmm or greater, a total organic HAP
       concentration of 50 ppmv or greater and a total resource effectiveness (TRE)  index value of 1 0 or
       less. A Group 2 process vent is a process vent that is not a Group 1 process  vent  The TRE
       index value is a  measure of the supplemental total resource requirement per unit reduction of
       organic HAP associated with a process vent stream. The TRE index value is a cost-effectiveness
       index, associated with an individual process vent stream and is dependent on the process vent
       flow rate, net heating value, total  organic compounds (TOG) emission rate, and HAP emission
       rate. Equations  that must be used to calculate the TRE index value for a process vent stream are
       provided in Appendix C. The coefficients used in the equation to calculate the TRE index value
       are different for process vents at  new and existing sources.
       Table 5-1 of Volume II is a
       applicability and group
       determination checklist for
       process vents.  Process vents
       that are not subject to the
       process vent provisions may be
       subject to the equipment leak
       provisions in Subpart H (NESHAP
       for SOCMI equipment leaks) or
Volume I. The Provisions
7.1
7,2
7.3
7.4
Process Vent Provisions ,	'
Transfer Operations Provisions ,,,>.,,>	'
Storage Vessel Provisions ,,. + ,,;	t ,,>*.','>'..'>">'T  \-S2
Wastewater Provisions , t .,..,>,„., k.
       the wastewater provisions in Subpart G, as noted in the checklist Group 1/Group 2
       determinations are required for each process vent stream that is subject to the process vent
       provisions, unless the process vent is already in compliance with the Group 1 requirements (98
       percent reduction, 20 ppmv outlet concentration, or flare control)
                                                1-61
                                                                                  September 1997

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                                          Overview of Emission Points, Control Technologies, and HON Provisions
7.1.3  Process Vent Control Requirements
       Group 1 process vents must meet the control requirements in §63.113 of Subpart G unless they
       are included in an emissions average. Compliance options for Group 1 process vent streams
       include:


           .   Reducing emissions of organic HAP's using a flare meeting the specification in §63.11 (b)
               of Subpart A (the NESHAP General Provisions);

           .   Reducing emissions of total organic HAP or TOG by 98 weight percent or to an exit
               concentration of 20 parts per million by volume, whichever is less stringent (product
               recovery devices are considered part of the process and cannot be included in
               determining compliance with this option except for recovery devices meeting certain
               conditions as described below); or

            •   Achieving and maintaining a TRE index value greater than 1.0 (e.g., by process
               modification or a product recovery device).

        A recovery device may also be used alone or in combination with one or more control devices to
        meet the 98 percent reduction if the following three conditions are met: (1) the control system was
        installed before December 31,1992; (2) the recovery device used to meet the 98 percent
        reduction is the last recovery device before release to the atmosphere; and (3) the recovery
        device alone or in combination with one or more control devices can meet the 98 percent
        reduction but is not capable of reliably reducing emissions to a concentration  of 20 ppmv or less.

        A recapture device may also be used to meet the 98 percent reduction. Recapture devices are
        considered control devices and are the same types of devices as recovery devices, however the
        material that is recovered is not normally used, reused, or sold.  For example, the materials may
        be recovered primarily for disposal.

        If a process vent stream with a mass rate of total hydrogen halides and halogen atoms greater
        than 0.45 kilograms per hour is combusted, a control device must be installed following the
        combustion device to reduce emissions of halogens and hydrogen halides. Halogen reduction
        devices installed after December  31,1992, must reduce overall emissions of halogens and
        hydrogen halides by 99 percent or reduce the outlet mass of total hydrogen halides and halogens
        to less than 0.45 kilograms per hour, whichever is less stringent.  Halogen reduction devices
        installed prior to December 31,1992 must reduce overall emissions of halogens and hydrogen
         halides by 95  percent or reduce the outlet mass of total hydrogen halides and halogens to less
         than  0.45 kilograms per hour, whichever is less stringent.

         A halogen reduction device may be used to reduce the vent stream halogen  atom mass emission
         rate to less than 0.45 kilograms per hour prior to any combustion control device, and thus make
         the vent stream nonhalogenated. Flares cannot be used to control halogenated process vent
         streams.

         If a boiler or process heater is used to comply with the 98 percent reduction or 20 ppmv outlet
         concentration, then the vent stream must be introduced into the flame zone of the control device.
                                                   1-62
                                                                                      September 1997

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Volume I	Overview of Emission Points, Control Technologies, and HON Provisions


       If an owner or operator elects to achieve and maintain a TRE index value greater than 1.0, the
       vent would become a Group 2 vent and must comply with the provisions for Group 2 vents.
       Group 2 vents are not required to apply any additional emission controls, however, they are
       subject to certain monitoring, reporting, and recordkeeping requirements to ensure that they were
       correctly determined to be Group 2 and that they remain Group 2.

7.1.4  Process Vent Testing, Monitoring, Recordkeeping, and Reporting

       Procedures for determining group status of vents, including test procedures and TRE equations,
       are contained in §63.115 of Subpart G. Performance test procedures are specified in §63.116.
       The initial performance testing and  initial reporting and recordkeeping requirements for process
       vents that are controlled with an incinerator, boiler, process heater, or flare are outlined in
       Table 7-1. Note that compliance can be demonstrated by measuring either HAP or TOC
       emissions. Initial testing, reporting, and recordkeeping requirements for scrubbers used
       downstream of a combustion device used to control halogenated streams are also shown in
       Table 7-1. A performance test is not required for flares. However, a compliance determination by
       visible emissions observation is required.

       Performance tests are not required for boilers and process heaters with a design heat input
       capacity of 44 Megawatts or greater, or for boilers or process heaters where the vent stream is
       introduced with or used as the primary fuel. A boiler or process heater burning hazardous waste
       which is  permitted under 40 CFR Part 270 (the RCRA hazardous waste permit program) and is in
       compliance with 40 CFR Part 266 Subpart H (standard for hazardous waste burned in boilers and
       industrial furnaces) does not require a performance test under the HON. The compliance
       demonstrations under these rules replace the performance test under the HON. Performance
       tests are also not required under the HON for hazardous waste incinerators that are permitted
       under 40 CFR Part 270 and comply with the requirements of 40 CFR Part 264, Subpart O, or has
       certified  compliance with the interim status requirements of 40 CFR Part 265, Subpart O. The
       compliance demonstrations under these rules replace the performance test under the HON.  In
       addition, a performance test is not required if (1) a performance test was already conducted to
       determine compliance with a regulation promulgated by EPA,  (2) the test was conducted using the
       same methods as required by the HON, and (3) either no process changes have been made
       since the test or it can be demonstrated that the performance test results can reliably demonstrate
       compliance despite process changes.

       Table 7-2 shows the group determination, reporting and recordkeeping requirements for Group 2
       process vent streams. As described in Section 7.1.2, a Group 2 vent may be classified Group 2
       on the basis of flow, concentration, or TRE index value. If the TRE index value is less than 4.0,
       the TRE index value calculation must be based on the test measurement parameters summarized
        in Table 7-2. If the TRE  index value is expected to be greater than 4.0, then the parameters (e.g.,
       flow and concentration) used in the TRE index value calculation may be estimated using
       engineering assessments instead of a test.

        Monitoring provisions for process vents are contained in §63.114 of Subpart G.  Continuous
        monitoring, recordkeeping, and reporting requirements for complying with the 98 percent
        reduction requirement or 20 ppmv outlet concentration are presented in Table 7-3.  Continuous
        monitoring, recordkeeping, and reporting requirements for maintaining a TRE index value greater
        than 1.0 and less than or equal to 4.0 are presented in Table 7-4.  Any boiler or process heater in
        which all vent streams are introduced with the primary fuel or where the design heat input capacity
        is greater than or equal to 44 Megawatts is exempt from monitoring requirements.  Hazardous
                                                 T f\^
                                                                                   September 1997

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VdumeI
                                                  Overview of Emission Points. Control Technologies, and HON Provisions
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                                                         1-64
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Volume 1
                                                  Overview of Emission Points, Control Technologies, and HON Provisions
                                                             1-66
                                                                                                      September 1997

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                                                1-67
                                                                                   September 1997

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Overview of Emission Points, Control Technologies, and HON Provisions
11


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                                                 1-69
                                                                                    September 1997

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Overview of Emission Points, Control Technologies, and HON Provisions





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           1-70
                                                     September 1997

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Volume I
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period of the performance test - NCS
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range established in the NCS or operating permit and all operating day
when insufficient monitoring data are collected^ - PR
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Volume I
                                                       Overview of Emission Points, Control Technologies, and HON Provisions
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                                                 Overview of Emis
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                                                       1-73
                                                                                              September 1997

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Overview of Emission Points, Control Technologies, and HON Provisions
volume i
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           1-74
                                                     September 1997

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                                                    1-75
                                                                                           September 1997

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                                         Overview of Emission Points, Control Technologies, and HON Provisions
                                        M^^|^HBlM^M^^H^^MI^HMIBMBBHI^Bi^BMBBi^BMH

      waste boilers that are permitted under 40 CFR Part 270 and are in compliance with 40 CFR
      Part 266 do not have additional continuous monitoring requirements under the HON. The
      monitoring under these rules replace the monitoring under the HON. Monitoring is also not
      required for process vents with a TRE index value greater than 4.0, a flow rate less than 0.005
      standard cubic meters per minute, or a concentration less than 50 ppmv.

      For each parameter monitored according to Tables 7-3 and 7-4, the owner or operator must
      establish a site-specific range for the parameter that indicates proper operation of the control or
      recovery device. If an owner or operator uses a control device or recovery device other than
      those listed in Tables 7-3 and 7-4, or wishes to monitor parameters other than those specified in
      Tables 7-3 and 7-4, the owner or operator must submit a description of, and rationale for, the
      planned monitoring, recordkeeping and reporting in the operating permit application or by other
      appropriate means.

       For Group 2  process vents, any process changes which can cause a change in the TRE index
       value the flow rate, or the outlet concentration must be reported. Any recalculation or
       remeasurement of the parameter(s) used to determine Group 2 status, TRE index value, flow rate,
       or outlet concentration, must also be reported. If the process change causes the flow rate to
       increase to 0.005 standard  cubic meter per minute or the HAP concentration to increase to
       50 ppmv, a TRE index value calculation must be performed if either of these parameters are used
       to determine Group 2 status.

7.2  TRANSFER OPERATION PROVISIONS

       This section summarizes the transfer operation provisions in §63.126 through §63.130 of
       Subpart G.  The checklists in Sections 6, 9 and 10 of Volume II provide additional details of the
       transfer operation provisions.

7.2.1  Transfer Operations Definition

       A "transfer operation" is defined as the loading of one or more liquid organic HAP's from a transfer
       rack assigned to a chemical manufacturing process that is subject to the HON into a tank truck or
       railcar. A transfer rack is defined as the loading arms, pumps, meters, shutoff valves, relief
       valves  and other piping and valves necessary to fill tank trucks or railcars. Transfer operations
       loading at an operating pressure greater than 204.9 kPa are not subject to the HON.  Racks that
       transfer liquids that contain organic HAP's only as impurities are not subject to the HON.  Racks
       that vapor balance during all loading operations are not subject to the transfer provisions in
        §63.126 through §63.130.

 7.2.2 Transfer Operations  Group Determination

        Group 1 and Group 2 transfer racks are defined in §63.111 of Subpart G.  A Group 1 transfer
        rack is a transfer rack that loads 0.65 million liters per year, or greater, of liquids that contain
        organic HAP's with a rack weighted average vapor pressure of 10.3 kPa or greater. A Group 2
        transfer rack is not a Group  1 transfer rack.

        Tables 4-4 and 4-5 of Volume II are applicability and group determination checklists for transfer
        operations.
                                                  1-76
                                                                                    September 1997

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Volume I
7.2.3  Transfer Operation Control Requirements


       Group 1 transfer racks must meet the control requirements in §63.126 of Subpart G when the
       operating pressure of the transfer operation is less than or equal to 204.9 kilopascals unless the
       rack is included in an emissions average.  Each Group 1 loading rack must be equipped with a
       vapor collection system and control device. The control device must comply with one of the
       following criteria:


           •  Reduce emissions of total organic HAP's by 98 weight-percent or to an exit concentration
              of 20 parts per million by volume, whichever is less stringent;


           •  Reduce emissions of organic HAP's using a flare which meets the specifications in
              §63.11 (b)  of Subpart A (the NESHAP General Provisions);


           •  Reduce emissions of organic HAP's using a vapor balancing system;  or


           •  Reduce emissions of organic HAP's by routing emissions to a fuel gas system or to a
              process.


       In contrast to the process vents provisions which do not allow use  of product recovery devices to
       determine compliance with the first option above, for transfer racks, the 98 weight percent
       reduction or 20 ppmv exit concentration can be achieved using either a combustion device or a
       product recovery device.


       Each vapor collection system used to comply with the transfer provisions must achieve the
       following:


           •   Collect the displaced vapors from the transfer operation and route them to a control
              device; and


           •   Prevent organic HAP vapors collected in one arm from passing through another loading
              arm to the  atmosphere.


       If a vapor balancing system is used to comply with the transfer provisions, the  vapor balancinq
       system must achieve the following:


           •   Collect the displaced vapors from the transfer operation and either:


                      route them to the storage vessel from which the transferred liquid originated; or

                      compress the vapors and commingle the liquid with the raw feed to the chemical
                     manufacturing process unit.


       If the emissions are routed to a process, the organic HAP emissions shall meet one or a
       combination of the following ends:


          •   Recycled and/or consumed in the same manner as a material that fulfills the same
              function in that process;
                                               1-77
                                                                                  September 1997

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                                        Overview of Emission Points, Control Technologies, and HON Provisions
                                       ^^I^BBBBH^B^^HI^Hi^^a^HH^Bi^^BH^m^HBi^Bi^B

          •   Transformed by chemical reaction into materials that are not organic hazardous air
             pollutants;

          •   Incorporated into a product; and/or

          •   Recovered.

      If a transfer rack vent stream with a mass rate of total hydrogen halides and halogen atoms
      greater than 0.45 kilograms per hour is combusted, a halogen reduction device must be installed
      following the combustion device to reduce emissions of halogens and hydrogen halides.  Halogen
      reduction devices installed on or after December 31,1992 must reduce overall emissions of
      halogens and hydrogen halides by 99 percent or reduce the outlet mass of total hydrogen halides
      and halogens to less than 0.45 kilograms per hour, whichever is less stringent.  Halogen  reduction
      devices installed prior to  December 31,1992 must reduce overall emissions of halogens  and
      hydrogen halides by 95 percent or reduce the outlet mass of total hydrogen halides and halogens
      to less than 0.45 kilograms per hour, whichever is less stringent.

      A halogen reduction device may be used to reduce the vent stream halogen atom mass emission
      rate to less than 0.45 kilograms per hour prior to any combustion control device, and thus make
      the vent stream nonhalogenated.  Halogenated streams cannot be routed to a flare.

      If a boiler or process heater is used to control the vent stream from a transfer rack, the vent
      stream must be introduced into the flame zone.

      The tank truck or railcar vapor collection equipment must be compatible with and connected to the
      loading rack's vapor collection system.  The owner or operator must ensure that any pressure-
      relief device will not open during loading and that all vents that could divert the vapor flow to the
      atmosphere are either secured using a car seal or a lock-and-key type configuration, or equipped
      with a flow indicator. Also, organic HAP's may only be loaded into a tank truck or railcar which
      has a current certification for the U.S. Department of Transportation (DOT) pressure test
       requirements, or which has been demonstrated to be vapor-tight within the preceding 12 months.

       Group 2 transfer racks are not required to  apply emission controls, but recordkeeping and
       reporting is required to verify that they are Group 2.

7.2.4 Transfer Operations Testing, Monitoring, Recordkeeping, and Reporting

        Initial performance testing, initial reporting, and recordkeeping requirements for Group 1 transfer
        racks are summarized in Table 7-5.  A performance test is not required for flares.  However, a
        compliance determination is required which includes determining visible emissions.

        If a control device is shared between a process vent and a transfer rack, the performance test
        procedures for process vents shall be followed and a separate performance test for the transfer
        operation's use of the control device does not have to be conducted. Performance tests are not
        required for vapor balancing systems, or boilers or process heaters with a design heat input
        capacity of 44 Megawatts or greater or where the vent stream is introduced with the primary fuel.
        A boiler or process heater burning hazardous waste which is permitted under 40 CFR Part 270
        and is in compliance with 40 CFR Part 266  Subpart H also does not require a performance test
        under the HON. The compliance demonstration  under these rules replace the compliance
        demonstration under the HON.  A performance test is not required when emissions are routed to
                                                 1-78
                                                                                    September 1997

-------
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                                                          1-79
                                                                                                    September 1997

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Overview of Emission Points, Control Technologies, and HON Provisions
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           1-80
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Volume
                                                  Overview of Emission Points Control Technologies, and HON Provisions








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                                                       1-81
                                                                                                September 1997

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                                       Overview of Emission Points, Control Technologies, and HON Provisions


     a fuel aas svstem or recycled to a process. Hazardous waste incinerators that are permitted
     un^e 40 CFR P^rt 270 and comply with the requirements of 40 CFR Part 264  SubpariIO or have
     certffied compliance with the interim status requirements of 40 CFR Part 265, Subpart O are not
     SquhS to have performance tests conducted under the HON. The compliance demonstrator,
     under these rules replace the compliance demonstration under the HON.

     For transfer racks that transfer less than 11.8 million liters per year of liquid containing organic
     HAPs, the owner or operator may submit a design evaluation for the control device, and monitor
     the design parameters instead of conducting performance tests.

     Continuous monitoring, recordkeeping, and reporting requirements for transfer racks are
     presented ,n Table 7-6.  Any boiler or process heater in which  all vent streams are introduced with
     fhTprSy fuel or where the design  heat input capacity is greater than or equal to 44 Megawatts
      s exempt from monitoring requirements.  Hazardous waste boilers that are permitted under
     4^0 ?FR Part^70 and are in compliance with 40 CFR Part 266 do not have continuous monrtonng
      requirements.

      The HON also requires periodic inspection of vapor collection and vapor balancing systems to
      detect leaks. The provisions are specified in §63.148 of Subpart G.

      For each parameter monitored in Table 7-6, the owner or operator must establish *»site-specific
      range for the parameters that indicates proper operation  of the control device^ If an owner or
      operator uses a control device other than those specified in Table 7-6, or wishes to monitor a
      oarameter other than those specified in Table 7-6, the owner or operator must submit a
      descSon of ^nd rationale Group 1 transfer racks may only load tank trucks and railcars that are
      vapor tight  Vapor tightness must be demonstrated by either: (1) having a current: certification in
      accordance with the U.S. Department of Transportation pressure test requirements of
      5CTR180 fortank trucks oV 49 CFR 173.31 for railcars or (2) having been shown to be vapor
      tight within the preceding 12 months using Method 27.

      Each owner or operator must maintain a record of the transfer rack vent system which lists all
      valves and vent streams that could  divert the vent stream from the control device   The valves
      which are secured by car-seals or lock-and-key type configurations and the position of these
      valves must be identified.

       The owner or operator of a Group 1 or Group 2 transfer rack must record and update annually an
       Inalysl demon'strating the design and actual annual throughput of the^transfer rack the> weight-
       nercent organic HAP of the liquid loaded, and the annual rack we.ghted average HAP vapor
       pressure  For Group 2 transfer racks that only transfer  organic HAP's with vapor pressures less
       San 10 3 kilopascate, the owner or operator must only document each individual HAP that is
       Uansfen^ed For Group 2 transfer racks that transfer organic HAP's with vapor pressures both
       above and below 10.3 kilopascals, the owner or operator must calculate and document the rack
       weighted average vapor pressure.

7,3  STORAGE VESSEL PROVISIONS

       This section summarizes the storage vessel provisions in §63.119 through §63.123 of Subpart G.
       The checklfets in sLons 7, 9 and 10 of Volume II provide additional details of the storage vessel
       provisions.
                                                                                   September 1997

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                                         1-83
                                                                       September 1997

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Overview of Emission Points, Control Technologies, and HON Provisions
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           1-84
                                                     September 1997

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 Volume I
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                                                       1-85
                                                                                               September 1997

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                                                                                I
Overview of Emission Points, Control Technologies, and HON Provisions
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••«••••••


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\ 98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR
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                                                                                                    September 1997

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Volume 1
CORDKEEPING, AND REPORTING REQUIREMENTS FOR TRANSFER
^JG WITH 98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR
PARTS PER MILLION BY VOLUME OR USING A FLARE
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 7.3.1  Storage Vessel Definition

        A "storage vessel" is a tank or other vessel that is used to store liquid organic HAP's and is
        assigned to a chemical manufacturing process subject to the HON. Storage vessels do not
        include vessels permanently attached to motor vehicles, pressure vessels, vessels with capacities
        less than 38 m-5, or vessels storing liquids that contain organic HAP's only as impurities  Bottoms
        receiver tanks and surge control vessels are not considered storage vessels because they are
        covered by the equipment leak provisions, and wastewater storage tanks are not considered
        storage vessels, since they are covered by the wastewater provisions.

 7.3.2 Storage Vessel Group Determination

        Group 1  and Group 2 storage vessels are defined in §63.119 of Subpart G. The vessel's design
        capacity and the vapor pressure of the stored liquid are used to determine whether a storage
        vessel is Group 1 or Group 2.  Group 1 storage vessels at existing sources are storage vessels
        with capacities of 75 m3 or greater but less than 151 m3 storing liquids with a vapor pressure of
        total organic  HAP of 13.1 kPa or greater.  Storage vessels at existing sources with capacities of
        151 m«> or greater storing liquids with a vapor pressure of total organic HAP of 5 2 kPa or greater
        are also Group 1 storage vessels. Group 1 storage vessels at new sources are storage vessels
       with capacities or 38 m3 or greater but less than 151 m3, storing liquids with a vapor pressure of
       total organic HAP of 13.1 kPa or greater. Storage vessels at new sources with capacities of
        151 m-3 or greater storing liquids with a vapor pressure of total organic HAP of 0 7 kPa or greater
       are also Group 1 storage vessels. Table 7-1 of Volume II is a checklist for applicability and group
       determination for storage vessels. Group 1/Group 2 determinations are required for each storage
       vessel that is subject to the storage vessel provisions,  unless the storage vessel is already in
       compliance with the Group  1 requirements.

7.3.3  Storage Vessel Control Requirements

       Group 1 storage vessels must meet the control requirements in §63.119 of Subpart G unless they
       are included in an emissions average.  Compliance options for Group 1 storage vessels include:

           •  Reducing emissions of organic HAP's using a fixed-roof tank equipped with an internal
              floating roof which is operated according to specified work practices (e.g., keeping access
              hatches  closed and bolted), equipped with specified deck fittings, and equipped with
              specified seal configurations (i.e., a single liquid-mounted seal, a single metallic shoe
              seal, or double seals);

           •  Reducing emissions of organic HAP's using an external floating roof tank operated
              according to specified work practices, equipped with specified  deck fittings, and equipped
              with specified seal configurations (i.e., double seals, with the primary seal to be either a
              liquid-mounted or a  metallic shoe seal);

           •  Reducing emissions of organic HAP's using an external floating roof tank converted to a
              fixed-roof tank equipped with an internal floating roof, which is operated according to
              specified work practices, equipped with specified deck fittings,  and equipped with
              specified seal configurations (i.e., a single liquid-mounted seal, a single metallic shoe
              seal, or double seals);
                                                 1-89
                                                                                    September 1997

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                                          Overview of Emission Points. Control Technologies, and HON Provisions
                                         ••^••^H^^M^M

           .   Reducing emissions of organic HAP's by 95 weight percent using a closed vent system
              (i e., vapor collection system) and control device or combination of control devices (or
              reducing emissions of organic HAP's by 90 weight percent using a closed-vent system
              and control device if the control device was installed before December 31,1992); or

           .   Reducing emissions of organic HAP's by routing the emissions to a process or a fuel gas
              system, if emissions are routed to a process the emissions must meet one of the same
              ends listed in Section 7.2.3 for transfer operation emissions routed to a process or fuel
              gas system.

       A detailed list of the work practices and deck fittings specified for internal floating roof vessels,
       external floating roofs, and external floating roof vessels converted to internal floating roof vessels
       is provided in Table 7-7, which is discussed in the next section.

       Group 2 storage vessels are not required to apply any emission controls, but recordkeeping and
       reporting is required to verify that they are Group 2.

7.3.4 Storage Vessel Testing, Monitoring, Recordkeeping, and Reporting

       Compliance determination for storage vessels using floating roofs is different than for process
       vents and transfer operations in that performance testing and continuous monitoring are not
       required.  Instead, periodic inspections of the floating roofs and their seals and fittings are
       required, and any defects must be repaired within specified time periods.

       For both Group 1 and Group 2 storage vessels, a record must be kept which provides the
       dimensions and an analysis showing  the capacity of each Group 1 and Group 2 storage vessel.
        For Group 2 storage vessels, this  recordkeeping requirement is the only requirement under the
        HON, unless the vessel is included in an emission average.

        Initial testing for visible emissions (i.e., as specified in §63.11 (b) of Subpart A) is required for
        Group 1 storage vessels controlled with flares. The initial testing is not a performance test, but is
        a compliance determination.  The compliance determination also involves gathering data such as
        the heat content, the flow rate, and the exit velocity for all periods when the pilot flame is absent.
        The initial recordkeeping and reporting (i.e., as part of the Notification of Compliance Status)
        includes records and reports of flare  design; visible emission readings and measurements of the
        heat content, the flow rate, and the exit velocity made during the compliance determination; and,
        periods when the pilot flame is absent.

         Initial performance tests are not required for vapor collection systems or control devices other
        than flares.  Instead, a report is required to be submitted as part of the Notification of Compliance
         Status which demonstrates that the control  device being used achieves the required percent
         reduction, during reasonably expected maximum loading conditions. This documentation must
         include a design evaluation of the control device and a description of the gas stream which enters
         the control device, including flow and organic HAP content under varying liquid level conditions
         (dynamic and static). This documentation is not required for the following control devices:

             •   A boiler or process heater with a design heat input capacity of 44 MW or greater;

             .   A boiler or process heater into which the vent stream is introduced with the primary fuel;
                                                   1-90
                                                                                      September 1997

-------
Volume I
                                       Overview of Emission Points, Control Technologies, and HON Provisions
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                                             1-91
                                                                             September 1997

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Volume I
                                    Overview of Emission Points, Control Technologies, and HON Provisions
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                                             Overview of Emission Points, Control Technologies, and HON Provisions
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                                                   1-93
                                                                                        September 1997

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Vdume I
                                                  Overview of Emission Points, Control Technologies, and HON Provisions
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                                                           1-94
                                                                                                     September 1997

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Volume I
Overview of Emission Points, Control Technologies, and HON Provisions


Q£
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iCORDKEEPING, AND REPORTING REQUIREMENTS F<
FLOATING ROOF VESSEL, AN EXTERNAL FLOATING
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the floating deck. Gasket failures include any time that a
gasket no longer closes off the liquid surface to the
atmosphere. Slotted membrane failures includes any time
a slotted membrane has more than 10 percent open area.


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                                                               1-95
                                                                                                           September 1997

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Volume I
Overview of Emission Points, Control Technologies, and HON Provisions
NG, AND REPORTING REQUIREMENTS FOR
OOF VESSEL, AN EXTERNAL FLOATING
0 AN INTERNAL FLOATING ROOF VESSEL
TT, RECORDKEEPI
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                                                          1-96
                                                                                                   September 1997

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Volume I
           •   A boiler or process heater burning hazardous waste which has been issued a final permit
               under 40 CFR Part 270 and complies with the requirements of 40 CFR Part 266,
               Subpart H, or has certified compliance with the interim status requirements of 40 CFR
               Part 266, Subpart H; or

           •   A hazardous waste incinerator which has been issued a final permit under 40 CFR
               Part 270 and complies with the requirements of 40 CFR Part 264, Subpart O or has
               certified compliance with the interim status requirements of 40 CFR Part 265, Subpart O.

       For enclosed combustion devices with a minimum residence time of 0.5 seconds and a
       temperature of at least 760°C documentation that these conditions exist is sufficient for the design
       evaluation. For thermal incinerators, carbon adsorbers, and condensers, the design evaluation
       must include additional information specified in the storage provisions under §63.120(d)(1). If the
       control device used to comply with the storage provisions is also used to comply with the process
       vent, transfer, or wastewater provisions, the performance test required by the process vent,
       transfer, or wastewater provisions is acceptable to demonstrate compliance with the storage
       provisions and a design evaluation would not be required.

       As part of the Notification of Compliance Status, the owner or operator must also submit a
       monitoring plan including the following: (1) a description of the parameter(s) to be monitored to
       ensure that the control device is operated and maintained in conformance with its design, (2) an
       explanation of the criteria used for selection of the parameter(s), and (3) the frequency with which
       monitoring will be performed. The owner or operator must also submit in the Notification of
       Compliance Status the operating range for each monitoring  parameter identified. This specified
       operating range must represent the conditions for which the control device can achieve the
       95 percent or greater emission reduction, or a 90 percent or greater emission reduction if installed
       prior to December 31, 1992.

       For storage vessel emissions that are routed to a process, a design evaluation or engineering
       assessment is required that demonstrates the extent to which one or more of the following ends
       are being met:

           •    Recycled and/or consumed in the same manner as  a material that fulfills the same
              function in that process;

           •   Transformed by chemical reaction into materials that are not organic hazardous air
              pollutants;

           •   Incorporated into a product; and/or

           •   Recovered.

       This design evaluation is to be submitted with the Notification of Compliance Status.

       Initial performance testing is not required for Group 1 storage vessels equipped with an internal
       floating roof, an external floating roof, external floating  roof converted to an internal floating roof,
       or a system that routes emissions to a fuel gas system. However, for external floating roof
       vessels, an initial measurement of seal gap area and maximum seal gap width for both the
       primary seal and the secondary seal is required to be performed and recorded during the
       hydrostatic testing of the vessel or by the compliance date, whichever is  later, and to be reported
                                                1-97
                                                                                   September 1997

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Volume!	Overview of Emission Points, Control Technologies, and HON Provisions


       in the first periodic report. For systems that route emissions to a fuel gas system, the owner or
       operator must include a report as part of the Notification of Compliance Status that the emission
       stream is connected to the fuel gas system and whether it is subject to §63.148 of Subpart G.

       Periodic inspection, measurement, recordkeeping, and reporting requirements for storage vessels
       equipped with an internal floating roof, an external floating roof, or an external floating roof
       converted to an internal floating roof are presented in Table 7-7.  Continuous and periodic
       monitoring, recordkeeping, and reporting requirements associated with closed vent systems and
       control devices for storage vessels are presented in Table 7-8. Included in the tables are both
       "periodic reports", which are submitted semi-annually, and "other reports", which are submitted as
       needed, on an irregular basis.

       The HON also requires periodic inspection of closed vent systems to detect leaks.  The provisions
       are specified in §63.148 of Subpart G.  The provisions of §63.148 also apply to  any system other
       than hard-piping that is operated under positive pressure used to route emissions to a fuel gas
       system or to a process.

       Bypassing the fuel gas system or process is permitted if one of the following conditions are met:

            •   The level in the storage vessel is not increased;

            •   The emissions are routed through a closed-vent system to a control device that is
               complying with the storage vessel provisions for control  devices in §63.119(e) of
               Subpart G; or

            •   The total aggregate amount of time during the year that  the emissions bypass the fuel gas
               system or process and are not routed to a control device does not exceed 240 hours.

        For owners or operators that bypass the fuel gas system or process shall have a record available
        of the reason it was necessary to bypass the process equipment or fuel gas system, and a record
        of the duration of the period when the process equipment or fuel gas system was bypassed. Also,
        the record must include certification of which of the three conditions were met.

 7.4  WASTEWATER PROVISIONS

        This section summarizes the wastewater provisions of the HON. The discussion focuses on the
        process wastewater provisions in §63.132 through §63.147 of Subpart G.  However,
        Sections 7.4.6,7.4.7, and 7.4.8 address process water provisions in §63.149 of Subpart G, the
        cooling water provisions in §63.104 of Subpart F, and the maintenance wastewater provisions in
        §63.105 of Subpart F.   The checklists in Sections 8, 9 and  10 of Volume II provide additional
        details of the storage vessel provisions.

 7.4.1 Wastewater Definition

        For the purpose of the HON, "wastewater" is defined as organic HAP-containing water,, raw
        material, intermediate, product, by-product, co-product, or waste material that exits equipment in a
        SOCMI chemical manufacturing process unit (including the last recovery device) and enters an
        individual drain  system and either: (1) contains an annual average concentration of Table 9
        compounds of at least 5 ppmw and has an annual average flow rate of 0.02 c/min or greater;, or
        (2) contains an  annual average concentration of Table 9 compounds of at least 10,000 ppmw at
                                                                                    September 1997

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Volume I
                                          Overview of Emission Points, Control Technologies, and HON Provisions
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Volume I




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                                       1-101
                                                                     September 1997

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                              Overview of Emission Points, Control Technologies, and HON Provisions
PING, AND REPORTING 1 ?
1 AND CONTROL DEVICE 1 [
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TABLE 7-8 PERIODIC AND CONTINUOUS MONITORING, INSPECTION, RECORDKEE
REQUIREMENTS FOR STORAGE VESSELS EQUIPPED WITH A CLOSED VENT SYSTE
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Section 2.5.3 of this manual.
Deriod: (1 ) the first time of day
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the conclusion of maintenance.
1992, and 90 percent for control

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and date that the control device did not achieve the required percent reduction at the begmni
first time of day and date that the control device did achieve the required percent reduction al
The required percent reduction is 95 percent for control devices installed after December 31 ,
devices installed before December 31, 1992.

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as frequently as practicable during safe-to-inspect times, as indicated in a written plan.
§63.1 82(b) of Subpart H (the 1
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The reports'required for closed-vent systems are to be submitted with the reports required b]
equipment leak prpvisions).
operator name or initials; 1
at repair; and (6) maximum 1

The record and report should include the following: (1) instrument identification numbers; (2
(3) identification of leaking equipment; (4) date the leak was detected; (5) date of first attemp
instrument reading after leak is repaired or determined to be non-repairable.
wn, or (2) the emissions of
associated with the leak, likely to
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purged material resulting from immediate repair would be greater than the fugitive emissions
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                                        1-102
                                                                                  September 1997

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 any flow rate.  Wastewater includes both process wastewater and maintenance wastewater.
 Table 9 compounds are those compounds listed on Table 9 of subpart G of the HON. Table 8
 compounds, which will be referred to later are those compounds listed on Table 8 of subpart G of
 the HON.

 "Process wastewater" means wastewater which, during manufacturing or processing, comes into
 direct contact with or results from the production or use of any raw material, intermediate product,
 finished product, by-product, or waste product.  Examples are product tank drawdown or feed
 tank drawdown; water formed during a chemical reaction or used as a reactant; water used to
 wash impurities from organic products or reactants; water used to cool or quench organic vapor
 streams through direct contact; and condensed steam from jet ejector systems pulling vacuum on
 vessels containing organics. Process water is considered wastewater when it exits the last
 recovery device in the chemical manufacturing process.

 "Maintenance wastewater" means wastewater generated by the draining of process fluid from
 components in the chemical manufacturing process unit into an individual drain system prior to or
 during maintenance activities.  Maintenance wastewater can be generated during planned and
 unplanned shutdowns and during periods not associated with a shutdown. Examples of activities
 that can generate maintenance wastewaters include descaling of heat exchanger tubing bundles,
 cleaning of distillation column traps, draining of low legs and high point bleeds, draining of pumps'
 into an individual drain system, and draining of portions of the chemical manufacturing process
 unit for repair.

 Other terms that are critical to understanding the HON wastewater provisions are "residual,"
 "annual average concentration," and "point of determination."

 "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 (nondestructive units). Examples of residuals from nondestructive wastewater
 management units are:  the organic layer and bottom residue removed by a decanter or organic-
 waste separator and the overheads from a steam stripper or air stripper.  Examples of materials
 which are not residuals  are: silt; mud; leaves; bottoms from a steam stripper or air  stripper;  and
 sludges,  ash, or other materials removed from wastewater being treated  by destructive devices
 such as biological treatment units and incinerators.

 The term "annual average concentration" is defined as the flow-weighted annual average
 concentration, as determined in §63.144(b).

 "Point of determination"  means each point where process wastewater exits the chemical
 manufacturing process unit (after the last recovery device). NOTE: The  regulation allows
 determination of wastewater stream characteristics (1) at the point of determination or
 (2) downstream of the point of determination if corrections are made for changes in flow rate and
 annual average concentration. Such changes include losses by air emissions; reduction of annual
 average concentration or changes in flow rate by mixing with other water or wastewater streams;
 and reduction in flow rate or annual average concentration by treating or otherwise  handling the '
wastewater stream to remove or destroy HAP's.

Spills, water from safety showers, testing of deluge systems or firefighting systems, wastewaters
that are discharged from a CMPU not subject to the HON are all wastewaters not subject to  the
 HON. Stormwater and water from firefighting and deluge systems are also not subject to the HON
                                         1-103
                                                                            September 1997

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                                         Overview of Emission Points, Control Technologies, and HON Provisions
                                        ™BM««»I^™«B— «••— -»-™»»^«™»«»"*-—B^;

       if they are in a segregated sewer. HON is not applicable to wastewater with an annual average
       concentration of Table 9 compounds of less than 10,000 ppmw at a flow rate less than 0.02 Cpm,
       or to wastewater streams less than 5 ppmw of Table 9 compounds at any flow. Table 4-1 0 in
       volume II of this manual is an applicability determination checklist for maintenance wastewater
       and process wastewater. If a maintenance wastewater stream is subject to the HON, the stream
       must comply with the requirements described in Section 7.4.8 of this chapter.  If a process
       wastewater stream is subject to the HON, the stream must be categorized as either a Group 1 or
       Group 2 stream to determine which process wastewater provisions apply.

7.4.2  Sourcewide 1 Mg/yr Exemption

       This exemption will be used most often for process wastewater streams which have a high
       concentration of HAP's but have a low flow rate. It includes two options. The first option is an
       applicability exemption in §63.138(i)(1), which exempts all Group 1 wastewater streams at a
       source from process wastewater control requirements if the total source mass flow rate for all
       Table 8 and/or Table 9 compounds is less than 1 Mg/yr [calculated according to procedures
       specified in §63.138(i)(1)(i) and
       The second option is a control option in §63.138(i)(2), which exempts untreated and partially
       treated Group 1 wastewater streams at a source from compliance with process wastewater
       control requirements if the source ensures that the total source mass flow rate for untreated and
       partially-treated Group 1 process wastewater streams is less than 1 Mg/yr [calculated according
       to procedures specified in §63.138(i)(2)(i) and (l)(2)(li)]. Therefore, the source may elect to treat
       or partially treat some wastewater streams so that the total source mass flow rate of the untreated
       and partially-treated Group 1 process wastewater steams for the source is less than 1 Mg/yr.
       Also, all waste management units used to receive, manage, or treat Group 1 process wastewater
       streams must be in compliance with the control requirements described in Section 7.4.4.

 7.4.3 Process Wastewater Group Determination

        Group 1 and Group 2 wastewater streams are defined in §63.1 1 1 of Subpart G based on flow
        rate,  annual average concentration, and whether the stream is part of a new or existing source. It
        is important to identify whether the source is new or existing because process wastewater
        streams from new sources are evaluated using more stringent criteria than streams from existing
        sources.  Streams from new sources must be evaluated for concentration and flow rate of HAP's
        listed on Table 8 of Subpart G of the HON. Table 8 is a list of those HAP's more volatile than
        benzene. Whether or not a wastewater stream from a new source is a Group 1 stream for HAP's
        listed on Table 8 of Subpart G of the HON, it must still be evaluated for HAP's listed on Table 9 of
        Subpart G of the HON. Table 8 is a subset of Table 9. To be considered a Group 1  wastewater
        stream, the stream  must consist of process wastewater as defined in §63.101 of Subpart F. For
        existing sources, Group 1 wastewater streams have a total annual average concentration of
        greater than or equal to 10,000 ppmv of Table 9 compounds at any flow, or a concentration of
        1,000 ppmw or greater of Table 9 compounds at an annual average flow rate of 10 0pm or greater.
        For new sources, Group 1 wastewater streams have an annual average concentration of 10 ppmv
        or greater of Table  8 compounds and an annual average flow rate of 0.02 epm or greater.
        Wastewater streams at new sources are also  considered Group 1 wastewater streams if they
        meet the criteria for Group  1 status at existing sources - Group  1 status for Table 9 compounds.

        Process wastewater streams from existing sources do not need to be evaluated using the more
        stringent concentration and flow rate values that apply to Table 8 HAP's. Rather, process
                                                 I~ 1 ™                              September 1997

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 Volume I
        wastewater streams from existing sources must be evaluated using only the concentration and
        flow rate criteria for Table 9 HAP's.

        Both new and existing facilities also may designate either a single process wastewater stream or
        a combination of process wastewater streams a Group 1 process wastewater stream instead of
        determing the group status using process knowledge or through sampling and analysis This
        option allows sources to declare that at a designated location downstream of the point(s) of
        determination, all wastewater streams at this location and upstream are Group 1 and will therefore
        be controlled.  The source is required to meet all requirements for Group 1 process wastewater
        streams (both upstream of the point of determination and downstream) for the designated Group 1
        wastewater stream. For example, if a Group 1 and Group 2 stream were mixed, and hard piped
        together, the combined stream could be designated as a Group 1 process wastewater stream and
        managed accordingly. Designating process wastewater streams as Group 1 streams will be used
        most commonly for combinations of streams.

        Table 8-1  of Volume II of this manual is  a Group determination checklist for process wastewater
        streams.

7.4.4 Process Wastewater Control Requirements

        Group 1 process wastewater streams and equipment managing such streams at both new and
        existing sources must meet control requirements in §63.132 through §63.139 of Subpart G and
        the leak detection requirements in §63.148 of Subpart G unless they are included in emissions
        averaging. Existing  sources are not required to  meet control requirements if Group 1  process
        wastewater streams are included in the  1 Mg/yr  source-wide exemption discussed  in Section 742
        of this section. Group 2 wastewater streams and equipment managing only Group 2 streams are
        not required to apply additional controls  unless the 95-percent biological treatment option which  is
        discussed in Section 7.4.4.2, is used.

       The HON wastewater provisions include control  requirements for: (1) waste management units
        including wastewater tanks, surface impoundments, containers, individual drain systems and oil-
       water separators; (2) treatment processes including the design steam stripper biological'
       treatment units, or other treatment devices; and  (3) closed-vent systems and control devices such
       as flares, catalytic incinerators, etc. This section provides an overview of the control requirements
       for such equipment when it receives, manages, or treats Group 1 process wastewater streams or
       residuals removed from process wastewater streams.

7.4.4.1  Waste  Management Units

       Waste management units are the equipment, structures, or devices used to convey store treat
       or dispose of wastewater streams or residuals.

       Wastewater tanks.  The control requirements for tanks holding Group 1  process wastewater are
       dependent on tank capacity and vapor pressure criteria.  Table 7-9 provides the tank capacity and
       vapor pressure thresholds with a corresponding summary of control requirements  Wastewater
       tanks holding only Group 1 process wastewater streams must meet the control requirements in
       §63.133 of Subpart G unless the wastewater is included in an emissions  average  Wastewater
       tanks holding only Group 2 wastewater streams are not required to apply any additional  controls
       Compliance options for wastewater tanks holding Group 1 process wastewater streams  include-'
                                               1-105
                                                                                  September 1997

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                                          Overview of Emission Points, Control Technologies, and HON Provisions
           TABLE 7-9.  WASTEWATER TANK EMISSION CONTROL REQUIREMENTS
    Capacity (m3)
Vapor Pressure (kPa)
            Control Requirements3
         <75
                                 N/A
      75 and < 151
                        Use of a fixed roof as specified in §63.133(a)(1) of
                        Subpart G
          151
        <5.2
      75 and < 151
         13.1
         2:151
Use of a fixed roof and a closed-vent system that
routes HAP vapors to a control device; or
Use of a fixed roof and an internal floating roof that
meets the requirements specified in §63.119(b) of
Subpart G; or
Use of an external floating roof that meets the
requirements specified in §§63.119(c),
63.120(b)(5), and 63.120(b)(6) of Subpart G; or
an equivalent means of emission limitation as
specified in §63.133(a)(2)(lv).
a To simplify the table, only an abbreviated description of the control requirement is given. Refer
  to the text for a more detailed description of the requirements.

               Reducing emissions of organic HAP's using a fixed-roof tank which is operated according
               to specified work practices (e.g., keeping hatches closed and bolted except during
               sampling, removal, or for equipment inspection maintenance or repair).  If the wastewater
               tank is used for heating wastewater or treating by means of exothermic reaction, or the
               contents of the tank are sparged, this option can not be used for this tank;

               Reducing emissions of organic HAP's using a fixed-roof tank and a closed-vent system
               that routes organic HAP vapors to a control device.  The fixed roof must be operated
               according to specified work practices (e.g., keeping hatches closed and bolted) and
                equipped with a lid that remains in a closed position (e.g., covered by a lid).  The closed-
               vent system, which is subject to the requirements of §63.148 of Subpart G, and the
                control device, which  is subject to the requirements of §63.139 of Subpart G, are
                discussed in Section 7.4.4.3 of this inspection tool;

                Reducing emissions of organic HAP's using a fixed-roof tank equipped with an internal
                floating roof which is operated according to specified work practices, equipped with
                specified deck fittings, and equipped with specified seal configurations (i.e., a single
                liquid-mounted seal, a single metallic shoe seal, or double seals);

                Reducing emissions of organic HAP's using an external floating roof tank operated
                according to specified work practices, equipped with specified deck fittings, and equipped
                with specified seal configurations (i.e., double seals, with the primary seal to be either a
                liquid-mounted  or a metallic shoe seal); or

                 Using another means of emission limitation approved in accordance with §63.102(b) of
                 Subpart F.
                                               1-106
                                                                                      September 1997

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Volume
                                          Overview of Emission Point
       A detailed checklist of the work practices and deck fittings specified for fixed-roof tanks internal
       floating roof tanks, and external floating roof tanks is provided in Sections 7 and 8, Volume II.

       Surface Impoundments. Surface impoundments holding Group 1 process wastewater streams
       must meet the control requirements in §63.134 of Subpart G unless the wastewater is included in
       an emissions average. Surface impoundments holding Group 2 wastewater streams are not
       required to apply any additional controls. The control requirement for surface impoundments
       holding Group 1 process wastewater streams is:

                      Reducing emissions of organic HAP's using a cover (e.g., air-supported structure
                      or rigid cover) and a  closed-vent system that routes organic HAP vapors to a
                      control device. The cover must be operated according to specified work
                      practices (e.g., keeping hatches, sampling ports, and gauge wells closed)  The
                      closed-vent system, which is subject to the requirements of §63.148 of
                      Subpart G, and the control device, which is subject to the requirements of
                      §63.139 of Subpart G, are discussed in Section 7.4.4.3 of this document; or

                      Reducing emissions of organic HAP's using a floating flexible membrane  The
                      floating flexible membrane must float on the surface of the liquid and form a
                      continuous barrier over the entire surface area  of the liquid. Requirements are
                      given for the fabrication of the membrane material (HOPE of 2.5 millimeters or
                      any material with equivalent organic permeability properties). The flexible
                      floating membrane must be installed properly, have a closure device and
                      emergency cover drains (for stormwater removal). The closure device must
                      minimize exposure of HAP's to the atmosphere, and be operated according to
                      specified work practices (e.g., keeping closed except for inspection,
                      maintenance, or repair).

      Containers.  The control requirements for containers holding Group 1 process wastewater are
      dependent on container capacity thresholds. Table 7-10 provides the container capacity criteria
      and corresponding summary of control requirements.  Containers holding Group 1 process
      wastewater streams must meet the control requirements in §63.135 of Subpart G unless the
      wastewater is included in an emissions average.  Containers holding Group 2 wastewater streams
      are not required to apply any additional controls
                                               1-107
                                                                                  September 1997

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                                         Overview of Emission Points. Control Technologies, and HON Provisions
              TABLE 7-10.  CONTAINER3 EMISSION CONTROL REQUIREMENTS
           Capacity
        0.1  z capacity < 0.42
                 0.42
                  Control Requirements
Container must meet DOT specifications and testing
requirements under 49 CFR Part 178; or
The cover and all openings must be maintained without leaks
as specified in §63.148 of Subpart G	
The cover and all openings must be maintained without leaks
as specified in §63.148 of Subpart G; and
Submerged fill pipes which meet specifications (e.g., fill pipe
outlet can extend no more than six inches or within two fill pipe
diameters of the bottom of the container) must be used; and
Emissions of organic HAP's must be reduced using an
enclosure. The enclosure must be operated with a closed-vent
system routed to a control device.
a The term container is defined in the HON (§63.111) to have a capacity greater than or equal to
  0.1 m3.


Individual Drain Systems.  Individual drain systems holding Group 1 process wastewater streams must
meet the control requirements in §63.136 of Subpart G unless the wastewater is included in an emissions
average.  Individual drain systems holding Group 2 wastewater streams are not required to apply any
additional controls. The control requirements for individual drain systems holding Group 1 process
wastewater streams include:

                Reducing emissions of organic HAP's using a cover on each opening in the individual
                drain system and, if vented, a closed vent system that routes organic HAP vapors to a
                process or control device. The cover must be operated according to specified work
                practices (e.g., keeping access hatches and sampling ports closed). The closed-vent
                system, which is subject to the requirements of §63.148 of Subpart G, and the control
                device, which is subject to the requirements of §63.139 of Subpart G, are discussed in
                Section 7.4.4.3 of this document; or
                                              1-108
                                                                                    September 1997

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 Volume I
        ^^••^•••^••i

                       Reducing emissions of organic HAP's using drains equipped with water seal
                       controls (e.g., p-trap) or a tightly fitting cap or plug which are operated according
                       to specified work practices; and junction boxes equipped with a cover and, if
                       vented, a closed vent system that routes organic HAP vapors to a process or a
                       control device. Junction boxes that are fed by gravity or are operated with slight
                       flunctuations in the liquid level are not required to use a closed vent system
                       routing emissions to a process or control device. Instead the vent pipe is to be
                       operated according to specified equipment standards and work practices.  The
                       closed-vent system, which is subject to the requirements of §63.148 of
                       Subpart G, and the control device, which is subject to the requirements of
                       §63.139 of Subpart G, are discussed in Section 7.4.4.3 of this document.  Each
                       sewer line shall not be open to the atmosphere and shall be covered or enclosed
                       in a manner so as to have no visible gaps or cracks in joints, seals, or other
                       emission interfaces.

        Oil-water separators. Oil-water separators holding Group 1  process wastewater streams must
        meet the control requirements in §63.137 of Subpart G unless the wastewater is included in an
        emissions average. Oil-water separators holding Group 2 wastewater streams are not required to
        apply any additional controls.  The control requirements for oil-water separators holding Group 1
        process wastewater streams include:

                       Reducing emissions of organic HAP's using a fixed roof and a closed-vent
                       system that routes organic HAP vapors to a control device. The fixed roof must
                       be operated according to specified work practices (e.g.,  keeping hatches bolted
                       and closed).  The closed-vent system, which is subject to the requirements of
                       §63.148 of Subpart G, and the control device, which is subject to the
                       requirements of §63.139 of Subpart G, are discussed in  Section 7.4.4.3 of this
                       document;

                       Reducing emissions of organic HAP's using a floating roof operated according to
                       specifications provided in 40 CFR Part 60 Subpart QQQ §§63.693-2(a)(1)(i),
                       (a)(1)(ii), (a)(2), (a)(3), and (a)(4).  Where a floating roof is infeasible, such as
                       over a weir mechanism, a fixed roof and closed-vent system routed to a control
                       device may be used; or

                       Using another equivalent means of emission limitation approved in accordance
                      with §63.102(b) of Subpart F.

       A detailed checklist of work practices and equipment standards is provided in Volume II.

7.4.4.2  Treatment Processes

       Treatment processes are techniques that remove or destroy the organics in a wastewater stream
       or residual. Section 63.138 of the HON wastewater provisions includes several compliance
       options and specifies how treatment processes 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.

       The following is a list of all of the compliance options covered in §63.138.  However, it should be
       noted that not all of the listed options may be used by all sources. For example, some options are
                                                1-109
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                                   Overview of Emission Points, Control Technologies, and HON Provisions


available only for existing sources. Other options may be used to treat only certain types of
wastewater streams. All Group 1 wastewater streams not included in an emissions average must
be controlled for air emissions prior to treatment and must be treated.  Steam stripping and
biological treatment are two common methods used for treating wastewater, but other methods
not specified in the rule (e.g., thin film evaporation) also may be used. In many plant wastewater
systems, Group 1 streams are combined with other Group 1 streams or with Group 2 streams
before they are treated. Tables 7-11 and 7-12 provide details on the use of the available
compliance options. The following are the compliance options for Group 1 wastewater streams
for both Table 8 and Table 9 compounds, unless otherwise indicated:

        1.       At new or existing sources, reduce, by removal or destruction, the total
                concentration of Table 9 compounds to a level less than 50 ppmw as specified in
                §63.145(b). [Note: cannot use biological treatment process or dilution with this
                option]; or

        2.       At new sources, reduce, by removal or destruction, individual Table 8
                compounds to a level less than 10 ppmw as specified in §63.145(b). [Note:
                cannot use biological treatment process or dilution with this option]; or

        3.       Use a design steam stripper which meets the design criteria  specified in
                §63.138(d);or

        4.       Use a waste management unit or treatment process to reduce by at least
                99 percent, by removal or destruction, the total mass flow rate of Table 8 or
                Table 9 compounds; or

         5       Use a waste management unit or treatment process to reduce, by removal or
                destruction, the mass flow rate of each Table 9 and/or Table 8 compound by at
                least the fraction removed (Fr) values specified in Table 9 and/or Table 8.  [Note
                the Fr value for all Table 8 compounds is 0.99];  or

         6.      Use a waste management unit or treatment process to achieve the required
                mass removal (RMR) of Table 8  compounds at new sources or Table 9
                compounds at new or existing sources. To determine compliance for:
                nonbiological treatment use procedures in §63.145(e); aerobic biological
                treatment use §63.145(e) or (f);  closed biological treatment use  §63.145(e); or
                 open biological treatment use §63.145(f);  or

         7.       For new or existing sources,  use a biological treatment unit  that achieves a RMR
                 of at least 95 percent for all compounds listed on Table 9, or at new sources, use
                 a  biological treatment unit that achieves a RMR of 95 percent for all table 8
                 compounds. [Note: all Group 1 and Group 2 wastewater stream  entering  the
                 biological treatment unit that are subject to subpart F must be included in the
                 demonstration of 95 percent removal]; or

         8.      Treat the wastewater or residual in a permitted RCRA hazardous waste
                 incinerator, a RCRA permitted process heater or boiler, or discharge it to a
                 properly permitted underground injection  well.
                                           1-110
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Volume I                              	Overview of Emission Points. Control Technologies, and HON Provisions


      TABLE 7-11. PROCESS WASTEWATER COMPLIANCE OPTIONS FOR NEW SOURCES
Compliance Options3***
!„ Use a steam stripper which meets the design criteria
specified in §63.l38(d) df Subpart G
2. Reduce mass flow rate df each Table 8 .and/or Table 9
compdund by Fr values specified in Table 9 df
Subpart G [Fr values fdr Table 8 compounds are all
&99]
& Reduce HAP mass fldw rate by 99%
4, Achieve required mass remdva) as specified in
§63.145{e) and/dr |63.145(f) df Subpart G
5. Treat in a biological treatment unit that achieves 95%
HAP removal6
6, Reduce tdtal concentration df Table 9 compounds to
less than 50 ppnw
7. Reduce the concentration of each individually specified
Table 8 HAP to less than 10 pprnw
8» Treat in a RCRA permitted waste incinerator, process
heater or boiler, or underground injection well
9. Demonstrate that the total source mass flow rate of
Table 8 and/or Table 9 compounds is less than 1 Mg/yr
using procedures in §63.138(i)(1)(0 and (ii)
Qroup 1 for
Table 8C
Compounds
•
•
•
•
•
N/A
•
•
•
Group 1 for
Tables6
Compounds
•
•
•
•
•
•9
N/A
•
•
Group 2
Streams
Qnly<*
N/A
N/A
N/A
N/A
•
N/A
N/A
N/A
N/A
• means the compliance option can be used for the wastewater stream; and N/A means the compliance
  option is not applicable.

a Options correspond to those listed in Section 7.4.4.2. To simplify the table, only an abbreviated
  description of the option is given. Refer to  Section 7.4.4.2 for a more detailed description of the
  requirements of the option.
b This table provides a list of compliance options.  The stream(s) also need(s) to meet the suppression
  and control requirements described in Section 7.4.4.1.
c If a stream is Group 1 for Table 8 and/or Table 9 compounds, it must meet the treatment requirements
 for Table 8 and/or Table 9 compounds, as applicable.
d Group 2 streams that are not combined with Group 1 do not require treatment, except for the fifth
  compliance option - biological treatment unit achieving 95% HAP removal.
e If the option to achieve a 95-percent HAP destruction using biological treatment is selected, all Group 1
  and Group 2 wastewater streams subject to the HON must be routed to the biological treatment unit.
' When meeting a concentration-based compliance option, the source must ensure that each Group 1
 wastewater stream achieves the required average concentration.  Dilution is not allowed as a method for
 reducing concentraticn.
9 New sdurces selecting a concentration-based compliance option must ensure that the total
  concentration of each individual compound listed On Table 8 of Subpart G are reduced to less than
  10 ppmw.
                                            1-111
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Volume I
                                          Overview of Emission Points, Control Technologies, and HON Provisions
    TABLE 7-12. PROCESS WASTEWATER COMPLIANCE OPTIONS FOR EXISTING SOURCES
Compliance Options3**1
1. Use a steam stripper which meets the design criteria
specified in §63.138(d) of Subpart G
2. Reduce mass flow rate of each Table 9 organic HAP
by the Fr values specified in Table 9 of Subpart G
3. Reduce mass flow rate of Table 9 compounds by 99%
4. Achieve required mass removal as specified in
§63.1 45(e) or (f) of Subpart G
5. Treat in a biological treatment unit that achieves 95%
HAP removal6
6. Reduce total concentration of Table 9 compounds to
less than 50 ppmwf
7. Treat in a RCRA permitted waste incinerator, process
heater or boiler, or underground injection well
8. Demonstrate that the total source flow rate of Table 9
compounds is less than 1 Mg/yr using procedures in
§63.138(i)(1)(i) and (i)(1)(ii)
Group 1 for Table
9 Compounds0
•
•
•
•
•
•
•
•
Group 2 Streams
Onlyd
N/A
N/A
N/A
N/A
•
N/A
N/A
N/A
 • means the compliance option can be used for the wastewater stream; and N/A means the compliance
   option is not applicable.

 a Options correspond to those listed in Section 7.4.4.2. To simplify the table, only an abbreviated
  description of the option is given. Refer to Section 7.4.4.2 for a more detailed description of the
  requirements of the option.

 b This table provides a list of compliance options. The stream(s) also need(s) to meet the suppression
  and control requirements described in  Section 7.4.4.1.

 c Existing sources must comply with requirements only for HAP's listed on Table 9 of Subpart G.

 d Group 2 streams that are not combined with Group 1 do not require treatment, except for the fifth
  compliance option - biological treatment unit achieving 95% HAP removal.

 e If the option to achieve 95-percent destruction using biological treatment is selected, all Group 1 and
  Group 2 wastewater streams subject to the HON must be routed to the biological treatment unit.

 f When meeting a concentration-based compliance option, the source must ensure that each Group 1
  wastewater stream achieves the required  annual average concentration.  Dilution is not allowed as a
  method for reducing concentration.
                                              1-112
                                                                                    September 1997

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 Volume
                                          Overview of Emission Point
        Sources complying with any of the options, except the design steam stripper or RCRA option
        must conduct either a design evaluation or performance test to prove compliance with the chosen
        option(s). Sources using open biological treatment processes must conduct a performance that
        (excep as noted in Table 36 of Subpart G). The design evaluation must address the operating
        characteristics of the treatment process based on operation at representative wastewater flow and
        a concentration under which it would be most difficult to demonstrate compliance  Performance
        tests must be conducted as specified in §63.145 of Subpart G.

        It should be noted that wastewater streams are exempt from the above compliance options if the
        total source mass flow rate for Table 8 and/or Table 9 compounds is less than 1 megagram per
        year, based on the mass before the wastewater stream is treated. A detailed  checklist of the
        requirements for each of the treatment compliance options is provided in Section 8 of Volume II.

 7.4.4.3 Closed-Vent Systems and Control Devices

        Closed-vent systems are used to transport organic HAP vapors from waste management units
        and treatment processes to control devices. In order to reduce emissions during transport the
        duct work or piping in the closed-vent system is subject to periodic leak inspections in §63 148 of
        Subpart G. There are also provisions in §63.148 to prevent releases through by-pass lines.

        Control devices are used to recover or destroy organic HAP vapors. Section 63 139 of the HON
        wastewater provisions requires that control devices reduce by 95 percent the organic HAP
        emissions routed to them from waste management units and treatment processes or allow an
        outlet concentration of 20 ppmv or less.  A variety of control devices may be used including flares-
        enclosed combustion devices such as thermal and catalytic incinerators, boilers and process  '
        heaters; vapor recovery systems such as condensers and carbon adsorbers; scrubbers-  and any
        other dev,ces that can reduce total organic HAP emissions by 95 weight percent or greater or
        reduce the outlet concentration to 20 ppmv or less.                               «"».*«

7.4.4.4 Residuals Management

       Residuals may be generated during the treatment of wastewater. As described in Section 7 4 1
       residuals can include, among other things, the organic layer removed by a decanter or the  '  ' '
       overheads condensate from a steam stripper or air stripper.  Residuals generated from the
       management of a Group 1 process wastewater stream must be managed according to §63 138(k)
       of Subpart G. Specifically, they must be controlled for air emissions by one of the followinq
       compliance options:

          •  Recycling the residual to a production process;

          • Selling the residual for the purpose of recycling or for any other purpose.  Residuals beinq
           stored prior to  sale must be in compliance with waste management unit control
           requirements.  Additionally, once residuals are sold, they must continue to be managed in
           accordance with the HON;                                                "=
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                                         Overview of Emission Points. Control Technologies, and HON Provisions
                                        I^HMBBMnMHMBMI^M

          •  Comply with RCRA treatment options given in §63.138(h).

       Any residuals generated from Group 2 streams do not require control under the HON; however,
       other regulations such as RCRA may be applicable.

7.4.5  Process Wastewater Testing, Monitoring, Recordkeeping and Reporting

       For both Group 1 and Group 2 process wastewater streams, a record must be kept which
       provides the annual average flow rate and the annual average concentration for each process
       wastewater stream. If process knowledge is used to determine that a process wastewater stream
       is Group 2, a record of how the process knowledge was used to make the decision must be
       maintained.

       As part of the Notification of Compliance Status, sources must submit more specific details on the
       waste management units, treatment processes, and control devices that are being used, including
       design analyses, performance test results, and compliance determination results.  For HAP s
       listed on Table 8 and/or Table 9 of Subpart G, each new source must submit the information
       described in Appendix D, Table D-1.

        For each treatment process or waste management unit identified in Tables D-1, the sources also
        must complete Table D-2 for treatment processes and Table D-3 for waste management units
        For each residual removed from a Group 1 process wastewater stream, sources must submit the
        information described in Table D-4.

        If the vapors from a waste management unit or treatment process are routed to a flare, the
        sources must submit records and reports of flare design, visible emission readings, heat content
        determinations, flow rate measurements, exit velocity, and periods when the pilot flame is absent.
        For each control device that is not a flare, the source must submit information justifying site-
        specific monitoring parameter ranges and either the results of performance tests or a design
        evaluation for a thermal incinerator, catalytic incinerator, boiler or process heater,  condenser,
        carbon adsorption system, or scrubber. The documentation must include the vent stream
        composition, constituent concentrations, flow rate, and control device operating parameters
        Some control devices are not required to submit design evaluation criteria, including: (1) boilers
        or process heaters either with a design heat input capacity of 44 MW or greater, or into which the
        emission stream is introduced with the primary fuel; or (2) boilers or process heaters burning
        hazardous waste for which the owner or operator has been issued either a final permit or a
        certification of interim status under RCRA 40 CFR Parts 270 and 266, Subpart H.

         For waste management units, treatment processes, and control devices, sources must submit
         results of inspections and monitoring as part of the Periodic Report, which is submitted semi-
         annually A list of inspection and monitoring requirements is provided for waste management
         units in Table 7-13, for treatment processes in Table 7-14, and for control devices in Table 7-15.
         Table 7-16 provides a list of reporting and recordkeeping requirements for control devices.

  7.4.6 Process Water Control Requirements

         The approach used in the HON to regulate wastewater emissions assumed that ail process water
         containing HAP's would  be managed in closed systems to minimize the loss of recoverable
         materials  The provisions on the control of emissions from process water were included to ensure
         that process fluids containing hazardous air pollutants within the manufacturing process would be
                                                  1-114
                                                                                     September 1997

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Volume I
                                                  Overview of Emission Points, Control Technologies, and HON Provisions
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                                                 Overview of Emission Points, Control Technologies, and HON Provisions
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Volume I
                                                    Overview of Emission Points, Control Technologies, and HON Provisions
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                                                          1-119
                                                                                                      September 1997

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Overview of Emission Points, Control Technologies, and HON Provisions
11



II
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                                                                                          September 1997

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                                         Overview of Emission Points, Control Technologies, and HON Provisions
                                         ^^^^^g^^H^^H^^HII^BH^BI^^^MI^nH^^HI^^MI^HBHl

       handled in amanner consistent with the requirements for wastewater streams subject to control.
       The process waters regulated by the HON are certain liquid streams in open systems within a
       chemical manufacturing process unit. The provisions in §63.149 contain control requirements for
       equipment that comes in contact with such process water streams.  Table 7-17 lists the control
       requirements for equipment coming in contact with such streams.

7.4.7  Heat Exchange Systems and  Cooling Water Management Requirements

       A heat exchange system, as defined in the HON, includes any recirculating heat exchange
       system (i.e., 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. The requirements for managing cooling water
       are provided in §63.104 of Subpart F.

       The HON requires sources using heat exchange systems (either recirculating or once-through
       heat exchange systems) to monitor cooling water for leaks. The HON requires sources using
       recirculating heat exchange systems to monitor for leaks of HAP's listed on Table 4 of Subpart F.
       Sources using once-through heat exchange systems are required to monitor for leaks of all
       Table 9 compounds.

       All heat exchange systems must be monitored for leaks using one of the following parameters:
       total HAP, total VOC, speciated HAP's, TOG, or other representative substances that would
       indicate the presence of a leak in the heat exchange system. Monitoring must be performed
       monthly for the first six months and quarterly thereafter.

        Monitoring parameter (e.g., total HAP, total VOC) concentrations in cooling water must be
        determined using any EPA-approved method listed in 40 CFR Part 136 that is sensitive to
        concentrations as low as 10 ppm. The same method must be used to measure the inlet and the
        outlet concentration of the heat exchange system. A leak is detected if a statistically significant
        difference in concentration of at least 1 ppm at a 95 percent confidence level is observed.  Leaks
        must be repaired no  more than 45 days after monitoring tests indicate a leak is present unless the
        source provides documentation meeting the criteria in §63.104(e) for delay of repair. After a leak
        is repaired, the source must monitor monthly for six months and quarterly thereafter to ensure that
        the leak does not recur.

        Sources are not required to comply with leak detection monitoring requirements if either: (1) the
        heat exchange system is operated with the minimum pressure on the cooling water side at least
        35 kilopascals greater than the maximum pressure on  the process side; or (2) there is an
        intervening cooling fluid containing less than 5 percent by weight of the compounds listed in
        Table 4 of subpart F; or (3) the once-through heat exchange system has an NPDES permit with
        an allowable discharge limit of less than 1 ppm; or (4) the once-through heat exchange system
        has an NPDES permit that requires  monitoring conditions or parameters to detect a leak of
        process fluid, specifies the normal range of the parameters or conditions, requires monitoring for
        the parameters or conditions no less frequently than every month for the first six months and
         quarterly thereafter, and requires the owner or operator to report and repair leaks when parameter
         conditions exceed the normal range; or (5) the recirculation heat exchange system is used to cool
         process fluids that contain less than 5 percent by weight of the compounds listed in Table 4 of
         subpart F; or (6) the once-through heat exchange system is used to cool process fluids that
                                                  1-122
                                                                                     September 1997

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Volume
           TABLE 7-17. CONTROL REQUIREMENTS FOR ITEMS OF EQUIPMENT THAT
                        MEET THE CRITERIA OF §63.149 OF SUBPART G
     Item of
   Equipment
 Drain or drain
 hub
 Manholeb
 Lift station
 French
 Pipe
 Oil/Water
 separator
 rank0
                            Control Requirements3
(a)  Tightly fitting solid cover (TFSC); or
(b)  TFSC with a vent to either a process, to a fuel gas system, or to a control device
     meeting the requirements of § 63.139 (c); or
(c)  Water seal with submerged discharge or barrier to protect discharge from wind.
(a)  TFSC; or
(b)  TSFC with a vent to either a process, to a fuel gas system, or to a control device
     meeting the requirements of § 63.139 (c); or
(c)  If the item is vented to the atmosphere, use a TFSC with a properly operating
     water seal at the entrance or exit to the item to restrict ventilation in the collection
     system. The vent pipe shall be at least 90 cm in length and not exceeding  10.2
     cm in  nominal inside diameter.
(a)  TFSC; or
(b)  TFSC with a vent to either a process, to a fuel gas system, or to a control device
     meeting the requirements of § 63.139 (c); or
(c)  If the lift station is vented to.the atmosphere, use a TFSC with a properly
     operating water seal at the entrance or exit to the item to restrict ventilation in the
     collection system.  The vent pipe shall be at least 90 cm in length and not
     exceeding 10.2 cm in nominal inside diameter. The lift station shall be level
     controlled to minimize changes in the liquid level.
(a)   TFSC; or
(b)   TSFC with a vent to either a process, to a fuel gas system, or to a control device
     meeting the requirements of § 63.139 (c); or
(c)   If the item is vented to the atmosphere, use a TFSC with a properly operating
     water seal at the entrance or exit to the item to restrict ventilation in the collection
     system. The vent pipe shall be at least 90 cm in length and not exceeding 10.2
     cm in  nominal inside diameter.
Each pipe shall have no visible gaps in joints, seals, or other emission interfaces.
(a) Equip with a fixed roof and closed vent system that routes vapors to process
equipment or to a control device meeting the requirements of § 63.139 (c); or
(b) Equip with a floating roof that meets the equipment specifications of § 60.693
(a)(1 )(i), (a)(1 )(ii), (a)(2), (a)(3),  and (a)(4).
Maintain a fixed roofd. If the tank is sparged6 or used for heating or treating by means
of an exothermic reaction, a fixed roof and a closed vent system shall be maintained
that routes the organic HAP vapors to other process equipment or to a control device
that meets the requirements of 40 CFR § 63.119(e)(1) or (e)(2).
a Where a tight fitting solid cover is required, it shall be maintained with no visible gaps or openings,
  except during periods of sampling, inspection, or maintenance.
° Manhole includes sumps and other points of access to a conveyance system.
c Applies to tanks with capacities of 38 m3 or greater.
d A fixed roof may have openings necessary for proper venting of the tank, such as pressure/vacuum
  vent, j-pipe vent.
e The liquid in the tank is agitated by  injecting compresses air or gas.
                                             1-123
                                                                                    September 1997

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Volume I                      	Overview of Emission Points, Control Technologies, and HON Provisions
       contain less than 5 percent by weight of the Table 9 compounds. Table 8-5 of Volume II provides
       a detailed checklist of requirements for heat exchange systems requiring leak detection
       monitoring.

7.4.8  Maintenance Wastewater Management Requirements

       Maintenance wastewater is defined as wastewater generated by the draining of process fluid from
       components in the chemical manufacturing process unit into an individual drain system prior to or
       during maintenance activities. Maintenance wastewater can be generated during planned and
       unplanned shutdowns and during periods not associated with a shutdown. Examples of activities
       that can generate maintenance wastewater include descaling of heat exchanger tubing bundles,
       cleaning of distillation column traps, draining of low legs and high point bleeds, draining of pumps
       into an individual drain system, and draining of portions of the chemical manufacturing process
       unit for repair. The requirements for managing maintenance wastewater are provided in §63.105
       of Subpart F.

       As part of the facility's startup, shutdown, and malfunction plan required by §63.6(e)(3) of 40 CFR
       Part 63 Subpart A, the HON requires sources to prepare a description of procedures for managing
       maintenance wastewater. The description must include maintenance procedures for  managing
       wastewater generated from emptying and purging equipment during temporary shutdowns that
       are necessary for inspections, maintenance, and repair (i.e., maintenance-turnaround) and during
       periods which are not shutdowns (i.e., routine maintenance). At a minimum, the description must
       specify:  (1) the process equipment and/or maintenance tasks that are expected to create
       wastewater during maintenance activities; (2) the procedure for properly managing the
       wastewater and controlling HAP emissions to the atmosphere; and (3) the procedures for clearing
       materials from process equipment.

       The description is to be modified and updated as needed following each maintenance procedure.
        Records of the maintenance procedures must be kept as part of the startup, shutdown, and
        malfunction plan. A detailed checklist of the maintenance wastewater requirements are provided
        in Table 8-6 of Volume II.
                                                 I" 124                              September 1997

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                                              September 1997
              Inspection Tool for
        the Hazardous Organic NESHAP
                    (HON)

        Volume II: Inspection Checklists
       U.S. Environmental Protection Agency
Chemical, Commercial Services, and Municipal Division
             Washington, D.C. 20460

-------

-------
Volume II
                                       Inspection Checklists
                               1.0  HOW TO USE THE CHECKLISTS
        The checklists in this inspection tool are flexible, and suitable for several different approaches to
        examining a facility. These checklists may be used singularly or in combination at a facility where
        the user is seeking compliance information on a specific emission point or points, or the user may
        proceed through the entire group of checklists, section by section, if the approach to examining
        the facility begins with the initial question of whether there is a chemical manufacturing process
        unit (CMPU) at the facility that must comply with the HON.

        Organization of the Checklists - If the users choose to proceed through the checklists
        sequentially, they may begin by determining which CMPU's are subject to the HON, which can be
        done with the checklists in Section 3. Once the applicability is established (either through the
        checklists in Section 3 or by prior information), the user can move on to the checklists in Section 4
        to determine which emission points are subject to the HON. This information allows the user to
        then move to the sections on  emission points that are located at the facility.  These sections are
        for process vents, transfer operations, storage vessels, and wastewater, and the checklists for
        each are found in Sections 5,6, 7, and 8, respectively.  These sections contain the compliance
        checklists for the provisions that are unique to the specific emission point. These checklists may
        also refer to checklists in Sections 9 and 10 which contain provisions that apply to multiple types
        of emission points (process vents, transfer operations, storage vessels, and wastewater).
        Section 9 has checklists for control equipment requiring leak detection; it covers the provisions on
        bypass lines and leak inspection requirements for equipment like closed-vent systems.
        Section 10 has compliance checklists for each of the control and recovery equipment listed in the
        rule. Thus, if a transfer rack is controlled using a flare, Section 6 would give the general transfer
        rack compliance checklists, and refer to Section 9 for the closed-vent system checklist and
        Section 10 for the checklist on flares.

        Flexible  Use - However, the
        checklists may also be used in a
        flexible manner to examine only
        certain types of emission points at
        a facility  or specific types of
        control devices.  For example, the
        user may need to know only
        about the compliance status of
        process vents at a facility.  In this
        case the user would be able to
        visit the facility and conduct an
        . inspection by taking only the
        checklists in Section 5 for
        process vents, Checklist 9-1, (the
        only checklist in Section 9 that
        applies to process vents), and
        Section 10 for the control and recovery devices used to control process vents.  If the inspector
        knew the specific control and/or recovery devices being used, the inspector could just take those
        specific checklists. Also, Section 11 includes a series of checklists for specific types of reports.
        An inspector may want to inspect the most recent periodic report to make sure all the components
        are included.  Section 11 contains a checklist for periodic report.
Volume 1) Inspection Checklist
1.0
2.0
3,0
4.D

6,0
6,0
f>0
8,0
9.0

mo
11,0
'How to Use Ite Checklists  	,	„.,,	fi-1
 Preparing for the Inspection  	,	„	„.,,	fl-3
 Applicability of the HON 	t	tl-5
 Emission Point Applicability and Assignment of Emission
 Points to the Chemical Manufacturing Process Units 	1.11-11
 Process Vents., <., ».<>„«.,,,,,,«,,,.<,.*>,,.,,, <,,, II-26
 Transfer Operations . < ,,*,,,,,,, < >,,,, , ^ >,,.,,< «,,, (1-31
 Storage Vessels >  < * .,,.,>,,.,,, + ,,,,,,.„,,,. t>, ttt> JI-37
 Wastewater,,.,,,,.,,,,,,,..,,,,., „.,.,,,,,.,,,,.,, M1
 GlDsed*Vsrtt Systems and Control Equipment Requiring
 Leak.Detection ,,..,	,..,	,..,,	U-86
 Control Device and Recovery Device Checklists	11-91
 Compliance timeline and Reporting Checklists	„.,,,,. H-116
                                                     11-1
                                                                                          September 1997

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Volume II                                                                         Inspection Checklists


       Another instance in which the user benefits from the flexibility of these checklists occurs when a
       specific control device or recovery device must be examined for compliance.  For example, if the
       user has to examine only one device, such as a carbon adsorber at a Group 1 process vent
       emission point, it is only necessary to take Checklist 10-6 from Section 10.

       The utility of these checklists resides in their capacity to function at a variety of inspection sites
       and to meet the needs of various approaches to  inspecting for compliance at the site. Hence, the
       inspector may have little or no information about a facility and benefit from using all of the
       checklists together in order to determine compliance, or specific emission points and control
       devices may need inspection, so that the user can selectively apply those checklists from the
       sections as necessary.

       These checklists provide the flexibility and ease of use so that the inspector may use them at
       facilities as efficiently as possible, and refer only to the necessary sections to  select the checklists
       which pertain to that facility's emission point or points for their particular inspection needs.

       Meaning of Responses - In general a "yes" response in the checklist indicates compliance and a
       "no" response indicates  noncompliance.  Exceptions to this are in  the roadmap tables, tables that
       do not apply to the specific situation, and questions that do not apply to the situation being
       inspected. The roadmap tables are used to inform the inspector which checklists apply to the
       situation they are inspecting, therefore a "no" response would indicate that the compliance option
       does  not apply and not that there is a compliance issue. Some tables do not apply to the situation
       being inspected. For instance, if an inspector is inspecting Group 1 process vents, Table 5-3,
       Group 2 Process Vents, would not apply and should not be used. There are also specific
       questions in the checklists that might not apply to the situation being inspected.  For example, if an
       inspector is inspecting Group 2 process vents and is using Table  5-3 to perform the inspection,
       item 4 may or may not be applicable. Item 4 only applies when a process change is made that
       changes the group status. If the facility has not made a change that affects the group status of the
       process vent being inspected, this item would not apply and should not be marked "yes" or "no". In
       all cases where an item  in a checklist may not apply it is obvious in the language that the item is
       conditional. These items should be skipped when they do not apply.
                                                   II-2
                                                                                       September 1997

-------

Volume II
                                                                                 Inspection Checklists
                               2.0   PREPARING THE INSPECTIO
                                           Examples of when incorrect applicability determinations may fie uncovered
                                           through review of tne Title V permit application

                                                  The source claims that a benzene units Is part of a refinery,
                                                  A proce$s vent from a HON chemical manufacturing unft is
                                                  routed to a refinery operation and the source claims it is not
                                                  subject to the HON process vent provisions.
Compliance with the HON can be determined by review of records and reports, review of
performance tests, and visual inspections using the methods and procedures specified in the rule.
As required by the rule, testing, monitoring, and inspections are to be carried out by the owner or
operator, with records kept for 5 years.  Therefore, the local, state, or federal inspector can
determine compliance by a review of plant records, along with spot inspections to verify the
operation, performance, and condition of the control equipment.

Prior to conducting the inspection,
the inspector should become
familiar with the regulation,
search the EPA, state, or local
agency files for information on the
facility, and review all relevant
information. The HON requires
that the operating permit	
application submitted by each        ^                    		_i_
facility that is subject to the
regulation specify which emission points are subject to the HON and what type of control is
applied to each emission point. The title V permit application is a good place to start the
inspection. Much of the material concerning applicability will be addressed in the application. The
Title V permit application can be reviewed along with the applicability requirements of the HON in
order to identify any applicability concerns or questions the inspector may have.  (The applicability
checklists are located  in Sections 3 and 4 with group status checklists in the emission point-
specific Sections 5, 6 and 7.) In reviewing the determination of group status, it is suggested that
the inspector focus on the determination of Group 2 status, because the Group 1 emission points
will be controlled (unless the facility is emissions averaging, which is not covered in this
document).

The inspector can also use the Title V permit application to develop a list of control devices to
inspect. The most recent periodic report should provide information on the facility's compliance
status. A review of files will help the inspector become familiar with the  operation of the facility
and the most recent compliance history. The compliance history and prior inspections will help
the inspector prioritize areas of concern for the upcoming inspection. For example, if a leaking
tank roof was identified in the last inspection, the inspector would want to check the facility
records to verify that the tank roof was repaired in the allotted amount of time.  The inspector may
also want to visually inspect the tank to verify that it has been  repaired.

The inspector may also need to gather safety and emissions detection equipment prior to the
inspection. Some facilities will require inspectors to wear hard hats, safety glasses, and steel-
toed shoes during their visual inspection.  If the inspector will need to do any climbing to inspect
equipment such as a tank roof, additional safety equipment may be necessary. If an inspector
feels that it is necessary to enter a storage vessel, please be aware of the requirements under
EPA Order 1440.2, and the safety information  in Guidance on Confined  Spacy Entry in NESHAP
Inspections of Benzene Storage Vessels (EPA 455/R-92-:003, September 1997).  The inspector
will also need a portable VOC analyzer to conduct Method 21  tests, and uniform probes for
measuring gaps in storage tank roofs.
                                                   II-3
                                                                                        September 1997

-------
VoUime II	Inspection Checklists


        Because the review of records is the primary means of determining compliance, the local, state, or
        federal inspector should notify the facility management prior to inspection. This gives the facility
        personnel enough time to gather relevant records and have them organized and available for
        review.  The facility should also provide a map and/or process flow diagrams to the inspector.

        The inspection consists of a review of records and reports kept by the plant, and a visual
        inspection of plant equipment. Volume II provides inspection checklists for process vents, transfer
        operations,  storage vessels, and wastewater. The checklists will enable the inspector to
        systematically review the plant records and reports. Each checklist provides a series of yes and
        no statements. A "yes" response to all of the statements indicates compliance with  the standard.
        However, there are a few statements in the checklists that can be checked "no", and the facility
        would still be in compliance. These exceptions are noted in the checklists. The inspector should
        copy the applicable checklists in Volume II prior to each inspection.

        Inspectors should conduct visual inspections to verify that the records and reports provided by the
        facility are accurate. Visual inspections will also enable the inspector to assess the condition of
        the control equipment. When making visual inspections, the checklists, along with plant drawings
        and specifications, should be used. Notations should be made on the checklists if there are
        discrepancies between the plant records and reports and the visual inspections. Control
        equipment should be checked for obvious leaks and lack of maintenance.
                                                                                        September 1997

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Volume II
                                                                                 Inspection Checklists
                                     APPLICABILITY OF
        Section 3 takes the inspector through the determination of what chemical manufacturing process
        units (CMPU's) are subject to the HON. Tables 3-1 and 3-2 establish which CMPU's are subject
        to the HON.  Table 3-1 refers the inspector to Table 3-2 when a facility has a flexible operation
        unit.  Table 3-2 steps through the determination of the primary product and whether the flexible
        operation unit is subject to HON.  Table 3-3 is used to determine the primary product of other
        CMPU's. The primary product of a CMPU is key in determining whether the CMPU is subject  to
        the HON. Table 3-4 is a checklist to determine if new or existing requirements pertain to the HON
        source.  Table 3-4 is used once it is determined, using Table 3-1 and/or 3-2, that the CMPU is
        subject to the HON. Table 3-5 provides a place for the inspector to take notes and identify the
        CMPU's subject to the HON.
                                           Section a. Applicability of ttte HON

                                           Table 3-1    . Applicability of 1h& HON , *	,,+,,,.,,<*,	< IJ-6
                                           Tabfe 3-2     Determination of Primary Product and Applicability
                                                     ' for Flexible Operation Units	,	.,...,.<,. II-7
                                           Tabfe 3-3     Determination of the Primary Product ..,.,	II-8
                                           Tabfe 3^4     Determination of Applicability of Existing and New Source
                                                      Requirements »,..,	,	,,.. n-9
                                           Tabte 3-5     Identification of CMPU's Subject to the HON	.",. il-10
                                                                                        September 1997

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Volume II	Inspection Checklists


                           TABLE 3-1. APPLICABILITY OF THE HON
 Complete this form to determine if a CMPU is subject to the HON,

1.     Do total potential emissions at the plant site exceed 10 tpy of an individual HAP or 25 tpy of a
       combination of HAP's?

       Y D    Continue with this checklist.

       N D    The plant site is not subject to the HON.

2.     Is the CMPU a petroleum refining process unit; an ethylene process unit; a solvent reclamation,
       recovery, or recycling operation at a hazardous waste TSDFa facility; an R&Db facility; or a
       process unit located in a coke by-product recovery plant?

       YD    The CMPU is not subject to the HON.

       N D    Continue with this checklist.

3.     Does the CMPU produce different intended products periodically throughout the year?

       Y D    The CMPU is a flexible operation unit. Skip to Table 3-2 to determine primary product
               and applicability.

       N D    Continue with this checklist.

4.     Is the primary product of the CMPU, as determined in Table 3-3, a SOCMI chemical (listed in
       Table 1 of SubpartF)?

       Y D    Continue with this checklist.

       ND    The CMPU is not subject to the HON.

5.     Does the CMPU use as a reactant or manufacture as a product, co-product one of the organic
       HAP's listed in Table 2 of Subpart F?

       YD    The CMPU is subject to the HON .c

       N D    The CMPU is not subject to the HON.
 a TSDF = Treatment, storage, and disposal facility.
 b R&D = Research and development (see §63.101 of Subpart F for definition).
 c Determination of applicability must be reported as part of the operating permit application or as
  otherwise specified by the permitting authority.
                                              II fi
                                              "~°                                    September 1997

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Volume II
           TABLE 3-2. DETERMINATION OF PRIMARY PRODUCT AND APPLICABILITY
                              FOR FLEXIBLE OPERATION UNITS3
  Complete this form to determine the primary product of a flexible operation unit and whether it is subject
  to the HOR  "          -   -                                  '                        •  '  -
                                                                                          I
If the CMPU manufactures different products periodically, determine:

              The product manufactured for the greatest annual operating time.

If all products are manufactured for the same amount of operating time, determine:

       •      The product with the greatest annual production on a mass basis.

       Is the product determined in either case above listed in Table 1 of Subpart F?

       Y D   The primary product of the CMPU is a SOCMI chemical. Continue with this checklist.

       N D   The primary product of the CMPU is not a SOCMI chemical, and the CMPU is not subject
              to the HON.
1.
2.
       Does the flexible operation unit use as a reactant or manufacture as a product, or co-product one
       or more of the organic HAP's listed in Table 2 of Subpart F?

       YD    The CMPU is subject to the HON.b

       ND    The CMPU is not subject to the HON.
a Determination is based on the expected utilization for the five years following April 22,1994 for
  existing sources and the five years after initial start-up for new sources.

b Determination of applicability must be reported as part of the operating permit application or as
  otherwise specified by the permitting authority.
                                                                                  September 1997

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Volume It
                                                                           Inspection Checklists
                  TABLE 3-3.  DETERMINATION OF THE PRIMARY PRODUCT
 Complete this form if referred from Table 3-1. ft is used to determine the primary product of CMPU's  -
 other than flexible operating units.
I
List the Intended products for the CMPU.

1.     Does one of the intended products have the greatest annual design capacity on a mass basis
       (e.g., makes up >50% on a mass basis if two products are made)?

       Y D   This is the primary product of the CMPU.

       N O   Continue with this checklist.

2.     If two or more of the intended products have the same annual design capacity on a mass basis,
       are any or all of the products listed in Table 1 of Subpart F?

       Y D   Any of the products that are listed in Table 1 of Subpart F may be designated the primary
              product of the CMPU. Thus, the primary product is a SOCMI chemical. Go to question 5
              on Table 3-1.

        N O   The primary product is not a SOCMI chemical, and the CMPU is not subject to the HON.
                                              II-8
                                                                                    September 1997

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Volume II	Inspection Checklists
              TABLE 3-4. DETERMINATION OF APPLICABILITY OF EXISTING AND
                               NEW SOURCE REQUIREMENTS
 Complete this form to determine If a chemical manufacturing process unit (CMPU) subject to the HON,
 as determined in Tables 3<-1 or 3-2, is a new or an existing source,
I
1.     Is the CMPU a new construction (on-site fabrication, erection, or installation of an affected
       source); or is it a reconstruction of an existing CMPU where the fixed capital cost of the new
       components exceeds 50% of the fixed capital cost that would be required to construct a
       comparable new CMPU.

       Y D   Continue with this checklist.

       N D   The CMPU is subject to existing source requirements.

2.     Did the reconstruction commence after 12/31/92?

       Y D   The reconstructed CMPU is subject to new source requirements.

       N D   The reconstructed CMPU is subject to existing source requirements.

3.     Did the construction  commence after 12/31/92 and the addition has the potential to emit 10 tons
       per year or more of any HAP or 25 tons per year or more of any combinations of HAPs?

       Y D    The constructed CMPU is subject to new source requirements.

        N D    The constructed CMPU is subject to existing source requirements.
                                                                                   September 1997

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Volume II
                                                                              Inspection Checklists
                 TABLE 4-1. APPLICABILITY CHECKLIST FOR PROCESS VENTS
 1.    The vent stream is discharged from a chemical manufacturing          Y D
       process subject to the HON.  (For process vents from distillation
       units, Table 4-2 is used to determine whether the distillation unit is
       part of a CMPU that is subject to the HON.)

 2.    The vent !s a gas stream containing greater than 0.005 weight          YD
       percent HAP.

 3.    The vent stream is continuously discharged (the vent is not            Y D
       associated with a batch process).

 4.    The vent stream is from a reactor or air oxidation reactor or            YD
       distillation unit,3 and is either:

       (a)    Discharged directly to the atmosphere (with or without
              passing through a control device); or

       (b)    Discharged after passing through a recovery device.

 5.    The vent is not a pressure relief device.b                             Y D

 6.    The vent is not a gaseous stream routed to a fuel gas system.          Y D

 7.    The vent is not from a recovery device installed to control              Y D
       emissions from wastewater treatment operations.0

 8.    The vent is not an equipment leak as defined in Subpart H.b            YD
       Is the vent subject to the HON process vent provisions?

               D      If all of the statements above are marked "Yes",
                      the vent is subject to the process vent provisions
                      in Subpart G of the HON*

               D      If any of the statements above are marked "No",
                      the vent is not subject to the process vent
                      provisions in Subpart G of the HON,  No other
                      checklists for these process vents apply.
ND




ND


ND


ND
ND

ND

ND


ND
a The terms reactor, air oxidation reactor, distillation unit, are defined in §63.101 of Subpart F.

b If false, the emission point is not subject to the process vents provisions of Subpart G, but may
  be subject to the equipment leak provisions in Subpart H of the HON.

c If false, the emission point is not subject to the process vents provisions, but may be subject to
  the wastewater provisions in Subpart G of the HON.
                                             11-12
                                                                                     September 1997

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Volume II
                       TABLE 4-2. ASSIGNMENT OF DISTILLATION UNITS
 Complete this form if referred from Table 4-1,  It is used to determine if a distillation unit is
 assigned to a CMPU subject to the M0N, and therefore the process vents from the distillation
 unit are subject to the HON.
       Aromex units:  Is the distillation unit part of the Aromex unit that produces benzene toluene  and
       xylene?                                                                          '


              Y D    The vent streams from the distillation unit are part of a CMPU that is subject to
                      the HON.

              N D    Go to question 2.


       Hexane units:  Is the distillation unit part of the unit that produces hexane?


              Y D    The vent streams from the distillation unit are part of a CMPU that is subject to
                      the HON.

              N D    Go to question 3.


       Cyclohexane units: Is the distillation unit part of the unit that produces cyclohexane?

              Y D    The vent streams from the distillation unit are part of a CMPU that is subject to
                      the HON.

              ND    Go to question 4.

       Is the distillation unit used by a single CMPU?


              Y D    The distillation unit is assigned to that CMPU. Skip to question 7.

              N D    Continue with this checklist.

       Is there a predominant use of the distillation unit?3


       a.      Is the greatest input into the distillation unit from a CMPU located on the same plant site?

              Y D    The distillation unit is assigned to that CMPU. Skip to question 7.

              N D   Continue with this checklist.


       b.      Does a CMPU at the same plant site receive the greatest output from the distillation unit?

              YD    The distillation unit is assigned to that CMPU. Skip to question 7.

              N D    Continue with this checklist.
                                            11-13
                                                                                     September 1997

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                                                                              Inspection Checklists
                      TABLE 4-2. ASSIGNMENT OF DISTILLATION UNITS
6.     If the distillation unit is shared among CMPU's so that there is no single predominant use, is at
       least one of the CMPU's subject to the HON?

       YD    The distillation unit may be assigned to any one of the CMPU's subject to the HON and
               therefore the distillation unit is part of a CMPU that is subject to the HON.  Go to
               checklist 4-1, question 2.

       ND    The distillation unit is not subject to the HON.D

7.     Is the CMPU referred to in questions 4, 5a, or 5b subject to the HON?

       YD    The distillation unit is part of a CMPU that is subject to the HON.b Go to checklist 4-1,
               question 2.

       Y O    The distillation unit is not part of a CMPU that is subject to the HON.b
 a If the predominant use of the distillation unit varies from year to year, applicability of the HON is
  to be based on utilization between April 22,1993 and April 22,1994. This determination must
  be reported in the operating permit application or as otherwise specified by the permitting
  agency.

 b If there is a change in the material stored or a distillation unit that was dedicated to a single
  CMPU begins to serve another CMPU, applicability of the HON must be reevaluated.
                                               11-14
                                                                                       September 1997

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Volume II
           TABLE 4-3. IDENTIFICATION OF PROCESS VENTS SUBJECT TO THE HON
Identify the process vents subject to the HON:
Use the checklists in Section 5 to determine which of these process vents are Group 1 and Group 2 and
the requirements of the various control options.
                                          11-15
                                                                                September 1997

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Volume II
                                                                              Inspection Checklists
             TABLE 4-4. APPLICABILITY CHECKLIST FOR TRANSFER OPERATIONS
  1.    The transfer rack loads vessels other than marine vessels.

  2.    The transfer rack operates at pressures less than or equal to
       204.9 kilopascals.

  3.    The transfer rack loads liquids that contain HAP's other than
       impurities.

  4.    The transfer rack does not use vapor balancing for all loading of
       organic HAP-containing liquids.
        D      If all of the statements above are marked 'Yes", see
               Table 4-5 to determine if the transfer rack is part of a
               CMPU unit subject to the HON and is therefore subject
               to the transfer provisions in Subpart <3 of the HON.

        n      If any of the statements above are marked "No", the
               transfer rack is not subject to the transfer rack
               provisions in Subpart G of the HON, No other checklists
               for these transfer racks apply.
TD

TD


TD


TD
FD

FD


FD


FD
                                               11-16
                                                                                      September 1997

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Volume II
                       TABLE 4-5.  ASSIGNMENT OF TRANSFER RACKS
 Complete this form if referred from Table 4-4, ft is used to determine if any part of tie transfer rack is
 assigned to & CMPU subject to the HON, and, therefore, the transfer rack, arm, or hose is subject to
 the HON,
1.      Is the transfer rack used by a single CMPU?

       Y O   The transfer rack is assigned to that CMPU.  Skip to question 5.

       N D   Continue with this checklist for each individual loading arm or loading hose.

2.      Is the loading arm or loading hose dedicated to the transfer of liquid organic HAP from a single
       unit?

       Y D   The loading arm or loading hose is assigned to that CMPU. Skip to question 5.

       N D   Continue with this checklist.

3.      Does one CMPU provide the greatest amount of the material that is loaded by a loading arm or
       loading hose?3

       Y D   The loading arm or loading hose is assigned to that CMPU. Skip to question 5.

       N D   Continue with this checklist.

4.      If the transfer rack is shared among CMPU's so that there is no single predominant use, is at least
       one of the CMPU's providing material to the loading arm or loading hose subject to the HON?

       Y D   The loading arm or loading hose may be assigned to any of the CMPU's subject to the
              HON and therefore the loading arm or loading hose is subject to the HON.b

       N D   The loading arm or loading hose is not  subject to the HON.b

5.      Is the CMPU referred to in questions 1, 2, or 3 subject to the HON?

       Y D   The transfer rack, loading arm, or loading hose is subject to the HON.b

       N D   The transfer rack, loading arm, or loading hose is not subject to the HON.b



a If the predominant use of the transfer rack varies from year to year, applicability of the HON is to
 be based on utilization between April 22,1993 and April 22,1994. This determination must be
 reported in the operating permit application or as otherwise specified by the permitting authority.

b If there is a change in the material loaded, applicability of the HON must be reevaluated.
                                                                                    September 1997

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Volume II                     	Inspection Checklists
   TABLE 4-6. IDENTIFICATION OF TRANSFER RACKS, LOADING ARMS, OR LOADING HOSES
                                  SUBJECT TO THE HON
Identify the transfer racks, loading arms, or loading hoses subject to the HON:
 Use the checklists in Section 6 to determine which of these transfer operations are Group 1 and Group 2
 and the requirements of the various control options.
                                            I] A Q
                                            n"10                                  September 1997

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Volume II
               TABLE 4-7. APPLICABILITY CHECKLIST FOR STORAGE VESSELS
 1.
 2.
 3.

 4.
 5.

 6.
 7.
The storage vessel stores organic liquid containing organic HAP.
The capacity of the storage vessel is greater than or equal to 38 m3.
The storage vessel is not a pressure vessel designed to operate in
excess of 204.9 kPa and without emissions to the atmosphere.
The organic HAP's stored in the vessel are not considered impurities.
The storage vessel is not a surge control vessel, or bottoms receiver
tank.3
The storage vessel is not permanently attached to a motor vehicle.
The storage vessel is not a wastewater storage tank.b
       n Yes; If all of the statements above are marked "Yes", see Table 4-8 to
              determine if the storage vessef is part of a CMPU subject to tie
              MOM and Is therefore subject to the storage vessel provisions in
              SubpartGoftheHON,
       O No;  If arty of the statements above are marked "No", the storage
              vessel is not subject to the storage vessel provisions in Subpart
              G of the HON> No other checklists for these storage vessels
              apply.
YD
YD
YD

YD
YD

YD
YD
ND
ND
ND

ND
ND

ND
ND
 a If false, the emission point may be subject to the equipment leak provisions in Subpart H of the HON.
 b If false, the emission point may be subject to the wastewater provisions in Subpart G of the HON.
                                           11-19
                                                                                  September 1997

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                                                                            Inspection Checklists
                      TABLE 4-8. ASSIGNMENT OF STORAGE VESSELS
 Complete this form if referred from Table 4-7. It is used to determine if any part of a storage vessel is
 assigned to a CMPU subject to the HQN, and, therefore, the storage vessel Is subject to the HON.

1.      Is the storage vessel located in a tank farm (including a marine tank farm)?
              YD    Continue with this checklist.
              N D    Skip to question 3.
2.      Is there an intervening storage vessel used by a CMPU before the product or raw material is
       transferred to the storage vessel in the tank farm?
              Y D   The storage vessel in the tank farm is not subject to the HON.
              N D   Continue with this checklist.
 3.     Is the storage vessel used by a single CMPU?
              Y D   The storage vessel is assigned to that CMPU. Skip to question 6.
               N D    Continue with this checklist.

 4.      Is there a predominant use of the storage vessel?3
        a.      Is the greatest input into the storage vessel from a CMPU located on the same plant site?
               YD    The storage vessel is assigned to that CMPU. Skip to question 6.
               N Q    Continue with this checklist.
        b.     Does a CMPU at the same plant site receive the greatest output from the storage vessel?
               Y D    The storage vessel is assigned to that CMPU. Skip to question 6.
                N D   Continue with this checklist.
 5.      If the storage vessel is shared among CMPU's so that there is no single predominant use, is at
         least one of the CMPU's subject to the HON?
                Y D   The storage vessel may be assigned to any one of the CMPU's subject to the
                       HON and therefore the storage vessel is subject to the HON.b
                N D    The storage vessel is not subject to the HON.b
 6.      is the CMPU referred to in questions 3, 4a, or 4b subject to the HON?
                                              II-20
                                                                                     September ,1997

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Volume II	
        ••^•••^^MM

                       TABLE 4-8. ASSIGNMENT OF STORAGE VESSELS



              .YD    The storage vessel is subject to the HON.b

              N D    The storage vessel is not subject to the HON.b


a if the predominant use of the storage vessel varies from year to year, applicability of the HON is
 to be based on  utilization between April 22,1993 and April 22,1994. This determination must
 be reported in the operating permit application or as otherwise specified by the permitting
 authority.

b If there is a change in the material stored, applicability of the HON must be Devaluated.
                                                                                    September 1997

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Volume II	Inspection Checklists


          TABLE 4-9. IDENTIFICATION OF STORAGE VESSELS SUBJECT TO THE HON


Identify the storage vessels subject to the HON:
 Use the checklists in Section 7 to determine which of these storage vessels are Group 1 and Group 2 and
 the requirements of the various control options.
                                             M-22
                                                                                   September 1997

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 Volume II
                  TABLE 4-10. APPLICABILITY CHECKLIST FOR PROCESS AND
                                MAINTENANCE WASTEWATER
  1.
  2.
  3.

  4.

  5.

  6.
The stream is water other than stormwater in a separate sewer.
The stream is water other than a spill or water from a safety shower.
The stream is water other than from fire fighting or deluge systems
segregated in a separate sewer.
The stream is water other than from testing or deluge system or testinq of
firefighting systems.
The stream is discharged from a chemical manufacturing unit subject to
the HON.
The annual average concentration of Table 9 compounds of the
wastewater * 5 ppmw and the flowrate is z 0.02 0pm, or the concentration
of Table 9 compounds of the wastewater is ^ 10,000 ppmw at any flow
rate. The concentration and flow are to be evaluated at the streams point
of determination.
YD
YD
YD

YD

YO

YD
ND
ND
ND

ND

NO

ND
       n
       D
       If all of the statements above are marked 'Yes*,
       stream is subject to the wastewater provisions,3
       If arty of the statements above are marked W, the wastewater
       stream is not subject to the wastewater provisions in Subpart <3 of
       the HON. No other checklists for these wastewater streams
       apply.
a The wastewater stream subject to the HON is either a process wastewater stream or a
  maintenance wastewater stream depending on if it was created from a process or a
  maintenance activity.
                                                                                 September 1997

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Vdu
                                                                            Inspection Checklists
            TABLE 4-11. APPLICABILITY CHECKLIST FOR EQUIPMENT HANDLING
                               IN-PROCESS LIQUID STREAMS
  Complete this checklist to determine what equipment handling in-process liquid streams are subject id
  the §63.149 of subpartG,                          ,    •—"   ;  ^	,
  1.    The equipment is a drain, drain hub, manhole, lift station, trench, pipe, oil-
       water separator and/or tank.
  2.    The equipment handles water other than stormwater.
  3.    The equipment handles water other than spill water and/or water from
       safety showers.
  4.    The equipment handles water other than firefighting and/or deluge
        systems.
  5.     The equipment handles water other than testing firefighting and/or deluge
        systems.
  6.     The equipment handles water other than a combination of stormwater,
        spillwater, water from safety showers, water from firefighting, deluge
        systems, and/or water from the testing of firefighting and/or deluge
        systems.
  7,    The equipment is part of a chemical manufacturing processing unit
        (CMPU) subject to the HON.
  8.    The equipment is located at a CMPU subject to new or existing source
        requirements and contains water with an annual average concentration of
        Table 9 compounds ;> 1,000 ppmw at an average flow rate ;> 10 Cpm; or
        an annual average concentration of Table 9 compounds, z 10,000 ppmw
        at any flow rate; or the equipment is located at a CMPU subject to new
        source requirements and contains water with an annual average
        concentration of Table 8 compounds * 10 ppmw at an average flowrate
        * 10 Cpm.
         D      If alt of the statements above are marked "Yes", the equipment is
                subject to the provisions of § 63.149 of Subpart <&.  '

         D      If any of the statements above are marked *Mo", the equipment is
                not subject to the provisions of § 63,149 of Subpart G,
YD


YD

YD


YD


YD


YD




YD


YD
ND


ND

ND


ND


ND


ND




ND


ND
                                              II-24
                                                                                     September 1997

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 Volume II
   TABLE 4-12. IDENTIFICATION OF PROCESS AND MAINTENANCE WASTEWATER STREAMS
                                 SUBJECT TO THE HON  .
 Identify the wastewater streams subject to the HON and equipment subject to §63.149 of Subpart G:
Use the checklists in Section 8 to determine which of the process wastewater streams subject to the HON
are Group 1 or Group 2 and to check the requirements for the Group 1 process wastewater streams
Group 2 process wastewater streams, maintenance wastewater streams, and equipment subject to '
§63.149 of Subpart G.
                                         II-25
                                                                             September 1997

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                                          Inspection Checklists
5.0   PROCESS VENTS
    Sections. Process Vents
    Table 5*2,
    Table 5-3,
Group Determination Checklist for Process Vente ,-> ^
Roadrnap to the Checklists for Group 1 Prt>yes& Writs ,
Group 2 Process Vertts .,	- v	
This section of the inspection tool
is used after determining that a
facility has a process vent that is
subject to the HON - after
working through the applicability
checklists in Sections 3 and 4.  It
contains a checklist to walk
through the process vent group
determination (Table 5-1), a list of the control options that the site may have chosen for the
Group 1  process vents with pointers to the appropriate checklists for the chosen control
techniques (Table 5-2), and a checklist for the requirements for Group 2 process vents
(Table 5-3). Once it is determined that a facility has a Group 1 process vent, then Table 5-2 is
used to determine the control options. Table 5-2 acts as a roadmap to determine which of the
checklists in this document apply to Group 1 process vents. It refers to the checklist for bypass
line provisions in Section 9 and the appropriate control or recovery device checklists in
Section 10  Table 5-3 is used once it is determined that the facility has a Group 2 process vent.
                                                         mv
              II-26
                                                    September 1997

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 Volume II
            TABLE 5-1. GROUP DETERMINATION CHECKLIST FOR PROCESS VENTS
  Complete this form for ail process vents subject to the HON as determined in Section 4,
 ^jjUm^jjgjgjgjjjl^_ ^^—^^—...... ,--.-•
  Process Vents Group Determination3-13
        1.      The flow rate of the vent stream is > 0.005 scmm.
        2.      The HAP concentration of the vent stream is > 50 ppmv.
        3.      The TRE index value of the vent is < 1,0.c
YD
YD
YD
        Is the process vent Group 1 ?
               D      The process vent is Group 1 if alJ of the above
                      statements are rnarked "Yes".
               D      The process vent is Group 2 if any of the above
                      statements are marked "No".
NO
ND
ND
a Group 1 vents must meet the control requirements in §63.113 of Subpart G, unless they are
 included in an emissions average. Group 2 vents are not required to apply additional controls.
b If an owner/operator complies with the 98 percent reduction, 20 ppmv, or flare control provisions
  In §63.113, group determination is not required.
c The coefficients used in the equation to calculate the TRE index value are different for process
 vents at new and existing sources. See Appendix C.
                                            II-27
                                                                                   September 1997

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Volume II	        Inspection Checklists


         TABLE 5-2. ROADMAP TO THE CHECKLISTS FOR GROUP 1 PROCESS VENTS
 This table Is a roadmap to the checklists used to assess Compliance with the Group 1 process vent
 provisions.                                             -  -
  I.     HALOGENTATED AND NONHALOGENATED PROCESS VENTS.

  1.     Are emissions routed to a flare to control emissions (halogenated vents may not be flared unless
        a halogen reduction device is present prior to flaring—Option II.2 below)?

        YD    Go to Checklists 9-1 and 10-1
        N D    Continue with this checklist

  2.     Are emissions routed to a control device that reduces emissions by 98% or to an outlet
        concentration of 20 ppmv?

        YD    Go to checklist 9-1, and select from below the checklist corresponding to the appropriate
               control device:
               D      thermal incinerator, checklist 10-2;
               D      catalytic incinerator, checklist 10-3;
               D      boiler or process heater with a capacity less than 44 MW that does not have the
                      emission stream introduced with the primary fuel, checklist 10-4;
               d      boiler or process heater with a capacity greater than 44 MW or that has the vent
                      stream introduced with the primary fuel, checklist 10-5;
               D      carbon adsorber used as a recapture device, checklist 10-6;
               D       absorber used as a recapture device, checklist 10-7;
               D       condenser used as a recapture device, checklist 10-8; or
               D       other control device used as a recapture device, checklist 10-9.

        N D    Continue with this checklist.

  3.    Does the process vent maintain a TRE index value greater than 1.0 using a recovery device?

        Y D    Select the checklist corresponding to the appropriate recovery device:

               D      Carbon adsorber used as a recovery device, checklist 10-6;
               D      Absorber used as a recovery device, checklist 10-7;
               D      Condenser used as a recovery device, checklist 10-8;
               D      Another recovery device not listed above, checklist 10-9.


  All compliance options are listed in this checklist. The facility will be using one of the options in this
  checklist to be In compliance with the HON process vent provisions.

  II.     HALOGENATED VENTS THAT ARE COMBUSTED

   1.     Is the vent stream exiting the combustion device routed to a halogen reduction device?

         YD    Go to checklist 10-10 when a scrubber is used.

         N D    Continue with this checklist.
                                               II-28
                                                                                      September 1997

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Volume II                                                       	    Inspection Checklists

         TABLE 5-2. ROADMAP TO THE CHECKLISTS FOR GROUP 1 PROCESS VENTS



 2.    Is the vent stream routed to a halogen reduction device prior to combustion?

       Go to checklist 10-10 when a scrubber is used.


 the compliance options for halogenated vents are halogen reduction device prior to combustion or
 after.  The facility will be using one of these options to be in compliance with the HON.
                                                                                  September 1997

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Vdume II	Inspection Checklists


                           TABLE 5-3.  GROUP 2 PROCESS VENTS
 A "yes response to all questions in Part I wil) Indicate compliance, and "no" responses will indicate
 noncomplianco. Part It of this checklist is a roadmap to checklists that apply to Qroup 2 process vents
 using a recovery device to maintain the TRE index value greater than 1.0 and less than or equal to 4.0*
 I.  REVIEW OF RECORDS

 1.    Records of process changes and the recalculation of TRE         YD            N D
       index values are kept when the TRE index value of the vent
       stream is greater than 1.0.a
 2.    Records of process changes and the recalculation of flow          YD            N D
       rate are kept when the flow rate of the vent stream is less
       than 0.005 standard cubic meter per minute.
 3.    Records of process changes and the recalculation or              YD            N D
       remeasurement of concentration are kept if the concentration
       In the vent stream is less than 50 ppmv.
 4.    Whenever process changes are made which cause a change       YD            N D
       In the status of the process vent stream, records are kept
       and a report was submitted within 180 days of the process
       modification or in the next PR describing the process
       modification and showing the results of the recalculation of
       flow rate, organic HAP concentration, and/or TRE index
       value.

 II.    ADDITIONALLY, FOR GROUP 2 PROCESS VENTS WITH A TRE INDEX VALUE GREATER
       THAN 1.0 AND LESS THAN OR EQUAL TO 4.0 USING A RECOVERY DEVICE TO
       MAINTAIN THE TRE

           Is the process vent using:

           D  Carbon adsorber used as a recovery device, checklist 10-6;
           D  Absorber used as a recovery device, checklist 10-7;
           D  Condenser used as a recovery device, checklist 10-8;
           D  Another recovery device not listed above, checklist 10-9.
   1 Examples of process changes include, but are not limited to, changes in production capacity,
   production rate, feedstock type, or catalyst type, or whenever there is replacement, removal, or
   addition of recovery equipment.  Process changes do not include process upsets; unintentional,
   temporary process changes; and changes that are within the range on which the original TRE
   calculation was based.
                                                                                   September 1997

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Volume II
                                                                                   Inspection Checklists
                                            Section 6.
                                           Table 6-2,
                                           Table $-&
                                           Table 6-4.
Group Determination Checklist for Transfer Operations lt-32
Roadmap to the Checklists for Group 1 transfer Racks U-33
%oup 1 and Group 2 Transfer Racks  ,>.<>.;,,>.<,. U-35
Routing the Emissions from g Orpup 1 Transfer Rack, to a
Process or Fuel <3as System ,,..._	...>.,,
 Once the transfer operations
 subject to the RON are
 determined in Section 4, this
 section can be used to determine
 which transfer racks require
 control (i.e., which racks are
 Group 1 and Group 2). This
 section also lists the control
 options for Group  1 transfer racks
 and the requirements of Group 2
 transfer racks. Table 6-1  provides a checklist to determine the group status of the transfer racks.
Table 6-2 lists the control options for Group 1 transfer racks.  This table acts as a roadmap
sending the inspector to the appropriate checklist depending on the method of compliance being
used. Table 6-2 refers to the closed-vent system checklists in Section 9 and to the appropriate
control device checklists in Section 10. Table 6-3 provides a checklist for a general
recordkeeping requirement for both Group  1 and Group 2 transfer racks. Table 6-4 provides a
checklist for transfer racks where routing to a fuel gas system or process is used to control
emissions.
                                                  11-31
                                                                                        September 1997

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                                                                            Inspection Checklists
      TABLE 6-1. GROUP DETERMINATION CHECKLIST FOR TRANSFER OPERATIONS
Complete this form for all transfer operations subject to the HQft as determined in Section 4.
Transfer Rack Group Determination3

1.    The transfer rack loads more than 650,000 liters per year of
      liquid products containing organic HAP's.

2.    The transfer rack weighted average partial pressure is greater
      than or equal to 10.3 kilopascals.
      is the transfer rack Group 1t
          D  The transfer rack is Group 1 if ail of tie above
              statements are marked "Yes".

          D  The transfer rack is Group 2 if any of the above
              statements are marked "Mo".
YD


YD
ND


ND
 Group 1 transfer racks must meet the control requirements in Section 63.126 of Subpart G
 during transfer operations when the operating pressures are less than or equal to
 204.9 kilopascals, unless the rack is included in an emissions average.  Group 2 transfer racks
 are not required to apply additional controls.
                                                                                     September 1997

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Volume II	Inspection Checklists


         TABLE 6-2.  ROADMAP TO THE CHECKLISTS FOR GROUP 1 TRANSFER RACKS
 This table is a roadmap to the checklists used to assess compliance with the Group 1 transfer rack
J
I.       HALOGENATED AND NONHALOGENATED VENT STREAMS

1.      Are emissions routed to a flare to control emissions (halogenated vents may not be flared unless
        a halogen reduction device is present prior to flaring—Option 11.2)?

        YD    Go to Checklists 9-1,9-2, and 10-1.

        N D    Continue with this checklist.

2.      Are the emissions routed to a control device that reduces emissions by 98% or to an outlet
        concentration of 20 ppmv?


        YD    Go to checklists 9-1 and 9-2, and select from below the checklist corresponding to the
               appropriate control device:

           D  thermal incinerator, checklist 10-2;
           D  catalytic incinerator, checklist 10-3;
           Cl  boiler or process heater with a capacity less than 44 MW that does not have the
               emission stream introduced with the primary fuel, checklist 10-4;
           D  boiler or process heater with a capacity greater than 44 MW or that has the vent stream
               introduced with the primary fuel, checklist 10-5;
           D  carbon adsorber, checklist 10-6;
           D  adsorber, checklist 10-7;
           D  condenser, checklist 10-8; or
           D  other control device, checklist 10-9.

        N D    Continue with this checklist.

3.      Is vapor balancing used to control emissions?

        YD    Go to Checklists 9-1 and 9-2.

        N D    Continue with this checklist.

4.      Are emissions routed to a fuel gas system or to a process?

        Go to Checklist 6-4.

All compliance options are listed in this checklist. The facility will be using one of the options in this
checklist to be in compliance with the HON transfer provisions.
                                              u ^
                                              " ^                                    September 1997

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Volume II
Inspection Checklists
        TABLE 6-2. ROADMAP TO THE CHECKLISTS FOR GROUP 1 TRANSFER RACKS
 II.    HALOGENATED VENTS THAT ARE COMBUSTED
 1.    Is the vent stream exiting the combustion device routed to a halogen reduction device?
       YD    Go to checklist 10-10 when a scrubber is used.
       N D    Continue with this checklist.
 2.    Is the vent stream routed to a halogen reduction device prior to combustion?
       Go to checklist 10-10 when a scrubber is used.
 The compliance options for halogenated vent streams are halogen reduction prior to combustion or
 after. The facility will be using one of these options to be in compliance with the HON.
                                           II-34
                                                                                September 1997

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 Volume II
                    TABLE 6-3.  GROUP 1 AND GROUP 2 TRANSFER RACKS
  A "yes" response to ad questions will indicate compliance, and "no" responses wilJ indicate
  noncompijance.
  REVIEW OF RECORDS

  1.     Records are kept of the design and actual annual
        throughput of the loading rack, the weight percent
        HAP of liquid loaded, and the annual rack
        weighted average HAP vapor pressure.3

  2.     For Group 1 transfer racks, all tank trucks and
        railcars have a current DOT pressure test
        certification in accordance with the requirements
        of 49 CFR 180 for tank trucks or 49 CFR 173.31
        for railcars or have been demonstrated to be
        vapor-tight within the preceding 12 months.b
  Notes:

YD
YD
ND
ND
a There are no other recordkeeping requirements applicable to Group 2 transfer racks.

b This requirement does not apply for operations during which a vapor balancing system is used.
                                            II-35
                                                                                   September 1997

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Volume II                                                                   InspectJonCheckNsts


        TABLE 6-4. ROUTING THE EMISSIONS FROM A GROUP 1 TRANSFER RACK TO
                            A PROCESS OR FUEL GAS SYSTEM
 Complete this form when the emissions from a Qroup 1 transfer rack; is routed to a process or fuel gas
 system. A "yes" response to the question will Indicate compliance, and a "no" response will indicate
 noncompiiance,
  REVIEW OF RECORDS

  1.    The report was submitted that the emission stream is being routed       YD         ND
       to a fuel gas system or to a process was submitted in the NCS.


 NCS ~ Notification of Compliance Status.
                                            II-36
                                                                                 September 1997

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Volume II
                                                                                    Inspection Checklists
                                             STORAGE VESSELS
                                            Section 7. Storage Vessels
                                                                                                   11-38
After Section 3 and 4 are used to
determine which storage vessels
are subject to the HON,  Section 7
is used to determine the group
status of each storage vessel
subject to the HON, the
compliance options for Group 1
storage vessels, the requirements
for Group 2 storage vessels, and
the inspection checklists for
floating roofs and control devices
used to control emissions from
storage vessels. Table 7-1 is
used to check the group status of
each storage vessel. Table 7-2
lists the control options for
Group 1 storage vessels. The table is a roadmap directing the inspector to the applicable
checklists depending on the compliance option that the owner or operator has chosen. Table 7-3
is a checklist for general recordkeeping and reporting requirements for Group 1 and Group 2
storage vessels. Table 7-4 provides a checklist for external floating roofs, Table 7-5 covers
internal floating roofs, and Table 7-6 lists the requirements for an external floating roof converted
to an internal floating roof. Table 7-7 is a checklist for nonflare control devices used to control
storage vessel emissions. Table 7-8 is a checklist for storage vessel emissions routed to a
process or fuel gas system.
Table 7-1.
Table 7-2.

Table 7-3,
Table 7-4,

Table 7-5.

Table 7-6.
                                            Table 7-7,

                                            Table 7-8.
Group Determination Checklist for Storage Vessels
Roadmap to the Checklists for Group 1 Storage
Vessels  	,,],,,...,	,	,.	H-40
Group 1 and Group 2 Storage Vessels +.,,.;,, + ,,,. 11-41
Compliance Checklist for Group 1 Storage Vessels
wjtfi External Floating Roofs  »,,..,,..	,,. M-2
Compliance CheckBst for Group 1 Storage Vessels
with Infernal Floating Roofs	,	„»	IMS
Compliance Checklist for Group 1 Storage Vessels
with an External Floating Roof Converted To
an Internal Floating Roof	,,	,.,	.,, fl-53
Compliance Checklist for Group 1 'Storage Vessels Equipped
with a Closed-vent System and Control Device , (.<., t 11-58
Compliance Checklist for Group 1 Storage Vessel
Emissions Routed to a Process or Fuel Gas System  .. H-60
                                                     II-37
                                                                                            September 1997

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Volume II
                                                     Inspection Checklists
          TABLE 7-1. GROUP DETERMINATION CHECKLIST FOR STORAGE VESSELS
 Complete this form for all storage vessels subject to the HON as determined in Section 4<
 Storage Vessel Identification:.
I.       Group Determination For Storage Vessels at New Sources3''3
        a.      The storage vessel capacity is greater than or equal to 151 rr
               and the vapor pressure of the stored organic HAP is greater
               than or equal to 0.7 kPa.c

        b.      The storage vessel capacity is greater than or equal to 38 nrr
               and less than 151 m3, and the vapor pressure of the stored
               organic HAP is greater than or equal to  13.1 kPa.c
         Is the storage vessel Group 1?

                D
                D
 The storage vessel is Group 1 if either of the above
 statements is marked "Yes".

 The storage vessel is Group 2 if both of the above
 statements are marked "No",
  II.      Group Determination For Storage Vessels at Existing Sources3'0*

         a.     The storage vessel capacity is greater than or equal to 151 m3
                and the vapor pressure of the stored organic HAP is greater
                than or equal to 5.2 kPa.c
         b.     The storage vessel capacity is greater than or equal to 75 m3
                and less than 151m3, and the vapor pressure of the stored
                organic HAP is greater than or equal to 13.1 kPa.c
          Is the storage vessel Group 1?

                 D
The storage vessel is Group 1 if either of the above
statements is marked 'Yes",

The storage vessel is Group 2 if both of the above
statements are marked "No".
                                                                           YD
                                                                            YD
                                                    YD
                                                    YD
                                                              ND
                                                              ND
                                                                                    ND
                                                                                     ND
                                             II-38
                                                                                    September 1997

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Volume II
                                                                            Inspection Checklists
          TABLE 7-1.  GROUP DETERMINATION CHECKLIST FOR STORAGE VESSELS
      Group 1 storage vessels must meet the control requirements in § 63.119 of Subpart G of the
      HON, unless they are included in an emissions average.  Group 2 storage vessels are not
      required to apply additional controls.


      A "new" source refers to a source (not a storage vessel) that commenced construction or
      reconstruction after December 31,1992.


      "Vapor pressure" refers to the maximum true vapor pressure of total organic HAP at
      temperature.


      An "existing" source refers to a source (not a storage vessel) that commenced construction or
      reconstruction before December 31,1992.
                                          II-39
                                                                                 September 1997

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                                                                              Inspection Checklists
       TABLE 7-2.  ROADMAP TO THE CHECKLISTS FOR GROUP 1 STORAGE VESSELS
 This table is a roadmap to the checklists used to assess compliance with the Group 1 storage vessei
 provisions,                               s      ,,'''"'
Storage Vessei Identification:		—
1.      Is an external floating roof used to control emissions?
        YD    Go to checklist 7-4.
        N D    Continue with this checklist.
2.      Is an internal floating roof used to control emissions?
        YD    Go to checklist 7-5.
        N D    Continue with this checklist.
3.      Is an external floating roof converted to an internal floating roof used to control emissions?
        Y O    Go to checklist 7-6.
        ND   Continue with this checklist.
 4.      Is a flare used to control emissions?
        YD   Go to checklists 9-1, 9-2, and 10-1.
        N D   Continue with this checklist.
 5.     Is a closed-vent system and a non-flare control device used to control emissions?
        YD   Go to checklists 7-7, 9-1, and 9-2.
        N D    Continue with this checklist.
 6.     Are the emissions routed to a fuel gas system or to a process?
        YD    Go to checklist 7-8.
         N D    If the facility is using another means to comply with the HON for Group 1 storage vessels,
                review records for compliance with the approved alternative means of emission limitation.
                                               II-40
                                                                                       September 1997

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Volume II
                  TABLE 7-3. GROUP 1 AND GROUP 2 STORAGE VESSELS
 ,A "yes" response fo all questions will indicated compliance, and a "no" response will indicate
 noncompJiance with the
1
 Storage Vessel Identification:.
 GENERAL RECORDKEEPING REQUIREMENT FOR GROUP 1 AND GROUP 2 STORAGE
 VESSELS:


 REVIEW OF RECORDS


       1.      Records are kept of the dimensions of the storage vessel       YD         N D
              and an analysis showing the capacity of the storage
              vessel.3

       2.      For Group 1 storage vessels with a control device, a           YD         N D
              description of the routine maintenance planned for the
              next 6 months and actually performed in the previous 6
              months is recorded and reported in the PR.
 NOTES:
       There are no other requirements applicable to a Group 2 storage vessel unless it is part of an
       emissions average.
                                                                               September 1997

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Volume II	:	Inspection Checklists


           TABLE 7-4. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                             WITH EXTERNAL FLOATING ROOFS
 A "yes" response to all questions wilf indicated compliance, and a W response wilt indicate
 noncompliance with the standard.       -     ^   --,-,<
  Storage Vessel Identification:..	


  REVIEW OF RECORDS

  1.     Review records of Seal Gap Measurements.

        (a)     Records indicate that seal gap measurements were made       YD         N D
               annually for the secondary seal and every five years for
               the primary seal.3
        (b)     When a failure is detected, the date and results of seal          YD         N D
               gap measurements are submitted in PR, annually for the
               secondary seal and every five years for the primary seal.
        (c)     When a failure is detected in the seal(s), the date and           YD         ND
               results of the visual inspection of the seals (which is
               performed together with the seal gap measurement) are
               included in the PR.
        (d)     The date of the seal gap measurement, the raw data           YD         N D
               obtained during the measurement, and the calculations
               made are recorded.
        (e)     The raw data and calculations recorded for seal gap            YD,        N D
               measurements is consistent with the information reported
               in the PR.
        (f)     For each seal gap measurement in a PR, there is a report       YD         N D
               notifying the Administrator of the measurement in
               advance. If the measurement had been planned, then the
               report was submitted 30 days in advance of the
               measurement.  If the measurement was not planned, then
               the report was submitted  at least 7 days in advance of the
               measurement and included an explanation of why the
               measurement was unplanned.
        (g)    if a failure was detected during a seal gap measurement        YD          ND
               and visual seal inspection, the PR indicated the date and
               the nature of the repair or the date the vessel was
               emptied.
                                             H-42       '                            September 1997

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Volume II
           TABLE 7-4. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                              WITH EXTERNAL FLOATING ROOFS
       (h)     If the report described in (g) documents that the repair was      YD          N d
               made more than 45 days after the failure was detected,
               then the next PR includes documentation of the use of up
               to two Sunday extensions for completing the repair,
               including identification of the storage vessel, a description
               of the failure, documentation that alternate storage
               capacity was unavailable, a schedule of actions to be
               taken to repair the control equipment or empty the vessel
               as soon as possible, and the date the storage vessel was
               emptied and the nature of and date the repair was made.
 2.     Review records of internal visual inspections.

       (a)     The occurrence of each internal visual inspection is             YD          N D
               recorded.

       (b)     For each internal visual inspection in which a failure was        YD          N D
               detected, the following information is submitted in the PR:
               (1) the date of the inspection, (2) identification of all
               storage vessels for which failures were detected, (3) a
               description of those failures, and (4) either the date and
               nature of the repair or the date the vessel was emptied.

       (c)     Any repairs performed as described in (b) were completed       YD         N D
              before the repaired  storage vessel was refilled.

       (d)     For each internal visual inspection documented in  a PR,         YD         ND
              there is  a report notifying the Administrator in advance of
              the date the inspected vessel would be refilled after the
              inspection.  If the inspection had been planned, the report
              was submitted 30 days in advance of refilling the vessel.
              If the inspection was not planned, then the report was
              submitted at least 7 days in advance of refilling the vessel
              and included an explanation of why the inspection  was
              unplanned.
                                            II-43
                                                                                    September 1997

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                                                                            Inspection Checklists
          TABLE 7-4. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                            WITH EXTERNAL FLOATING ROOFS
VISUAL INSPECTION

Note- The inspector should not perform the inspection while on the EFR if the roof is below four feet of
     " the top of the tank and if the inspector is not equipped with the proper respiratory protection.
      Based on the inspector's assessment of the availability of records documenting the design of the
      control equipment, an adequate inspection without respiratory protection may be performed with
      a combination of a record inspection and a visual inspection conducted from the platform with
      the aid of vision-enhancing devices (binoculars).  If the inspector feels that it is necessary to be
      on the EFR when the roof is below four feet of the top of the tank, please be aware of the
      requirements under EPA Order 1440.2 and the safety information in Guidance on Confined
      Space Entry in NESHAP Inspections of Benzene Storage Vessels (EPA 455/R-92-003-
      September1992).
 1.     The EFR is resting on the liquid surface of the stored material,
       unless the EFR is resting on the roof leg supports because the
       vessel has just been emptied and degassed or the vessel is
       partially or completely emptied before being subsequently refilled
       or degassed.
 2.     The external floating roof is in good condition (i.e., free of defects
       such as corrosion and pools of standing liquid).

 3.     There is a secondary seal installed above the primary seal.b

 4.     Inspect the secondary seal.b
       (a)     The secondary seal is continuous and completely covers
              the annular space between the EFR and the vessel wall.

       (b)     There are no holes, tears, or other openings in the seal or
              seal fabric.
       (c)     There are no visible gaps between the seal and  the wall of
               the storage vessel, except as specified in (e)(1)  and (e)(2).

       (d)      The seal is not detached from the floating deck.

       (e)      Perform seal gap measurement of the secondary seal as
               specified in §63.120(b)(1) through (b)(4) of the RON
               storage provisions.
         (1)   The accumulated area of gaps between the vessel wall
               and the secondary seal does not exceed 21.2 cm2 per
               meter of vessel diameter.
         (2)   The maximum gap width between the vessel wall and the
               seal does not exceed 1.27 cm.
YD
YD


YD


YD


YD


YD


YD




 YD



 YD
                                                                                    ND
ND


ND


ND


ND


ND


ND




 ND



 ND
                                              H-44
                                                                                     September 1997

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          TABLE 7-4. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                            WITH EXTERNAL FLOATING ROOFS
5.    Inspect the primary seal.b

      (a)    The primary seal is either a metallic shoe seal or a liquid-        YD          N D
             mounted seal.'3

      (b)    The primary seal forms a continuous closure that               YD          N D
             completely covers the annular space between the wall of
             the storage vessel and the edge of the EFR, except as
             described in (f)(l) and (f)(2).

      (c)    There are no holes, tears, or other openings in the seal          YD          ND
             fabric, seal envelope, or shoe (if a metallic shoe seal is
             used).

      (d)    If the primary seal is a metallic shoe seal:

        (1)   The lower end  of the metallic shoe send extends into the        YD          N D
             stored liquid (no specific distance);

        (2)   The upper end of the metallic shoe seal extends a              YD          ND
             minimum vertical distance of 61 cm above the stored liquid
             surface; and

        (3)   There is a flexible coated fabric that spans the space            YD          N D
             between the metal shoe and the vessel wall.

      (e)    If the primary seal is a liquid-mounted seal, the seal is in         YD          N D
             contact with the liquid between the wall of the storage
             vessel and the EFR.

      (f)     Perform seal gap measurements of the primary seal as
             specified in §63.120(b)(1) through (b)(4) of the HON
             storage provisions.

        (1)   The accumulated area of gaps between the vessel wall          YD          N D
             and the primary seal does not exceed 212 cm^ per meter
             of vessel diameter.

        (2)   The maximum  gap width between  the vessel wall and the        YD          N D
             seal does not exceed 3.81 cm.
6.    Inspect deck openings.

      (a)    If the EFR is non-contact, then each opening in the floating       YD          N D
             roof, except automatic bleeder vents and rim space vents,
             provides a projection below the stored liquid's surface.0

      (b)    Except for automatic bleeder vents, rim space vents, roof        YD          N D
             drains, and leg sleeves, each  opening in the roof is
             equipped with a gasketed cover, seal, or lid which forms a
             vapor-tight seal.
                                            II-45
                                                                                   September 1997

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Volume II	Inspection Checklists


           TABLE 7-4. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                              WITH EXTERNAL FLOATING ROOFS
        (c)     Each gasketed cover, seal, or lid on any opening in the          YD          N D
               EFR is closed, unless the cover or lid must be open for
               access.
        (d)     Covers on each access hatch and gauge float well are          YD          N D
               bolted or fastened so as to be air-tight when closed.

        (e)     The gasket on each cover, seal, or lid described in (b)           YD          N D
               closes off the liquid surface from the atmosphere.

  7.     Inspect automatic bleeder vents.
        (a)     Automatic bleeder vents are closed, unless the roof is           YD          N D
               being floated off or is being landed on the roof leg
               supports.
        (b)     Automatic bleeder vents are gasketed.                        YD          N D
        (c)     The gasket on the automatic bleeder vents close off the         YD          N D
               liquid surface from the atmosphere.

  8.     Inspect rim space vents.
        (a)     Rim space vents are closed, except when the roof is being      YD          N D
               floated off the roof leg supports or when the pressure
               beneath the rim seal exceeds the manufacturer's
               recommended setting.

        (b)     Rim space vents are gasketed.                              YD          N D
        (c)     The gaskets on the rim space vents close off the liquid          YD          N re-
               surface from the atmosphere.
  9.    Each roof drain is covered with a slotted membrane fabric that          YD          N D
        covers at least 90 percent of the area of the opening.
  10.   Each unslotted guide pole well has either a gasketed sliding cover      YD          N D
        or a flexible fabric sleeve seal.
  11.   Each unslotted guide pole shall have on the end of the pole a           YD          N D
        gasketed cap which is closed at all times except when gauging the
        liquid level or taking liquid samples.
  12.   Each slotted guide pole well is equipped with the following             YD          N D
        equipment: (1) a gasketed sliding cover or a flexible fabric sleeve
        seal, and (2) a gasketed float inside the guide pole or other control
        device which closes off the liquid  surface from the atmosphere.

  13.   Each gauge hatch/sample well has a gasketed cover which is          YD         N D
        closed (except when the hatch or well must be open for access).
  14.   All  of the gaskets described in 10 through 13 close off the liquid         YD          N D
        surface from the atmosphere.
                                               II-46
                                                                                       September 1997

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 Volume II
           TABLE 7-4, COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                             WITH EXTERNAL FLOATING ROOFS
PR = Periodic Report.     EFR = External Floating Roof.

a      If an external floating roof has a liquid-mounted or metallic shoe primary seal as of
       December 31,1992, a secondary seal is not required until the next emptying and degassing or
       April 22, 2004, whichever is later. For such storage vessels, measurement of gaps in the primary
       seal must be conducted once per year until a secondary seal is installed.

b      If the external floating  roof is equipped, as of December 31,1992, with either- (1) a liquid-
       mounted primary seal and no secondary seal, (2) a metallic shoe primary seal and no secondary
       seal, or (3) a vapor mounted primary seal and a secondary seal, then the seal requirement of a
       liquid-mounted or metallic shoe primary seal and secondary seal does not apply until the earlier of
       the following dates: (1) the next time the storage vessel is emptied and degassed, or (2) April 22,


c      If these openings (excluding automatic bleeder vents and rim space vents) did not provide
       projections below the liquid service as of December 31,1992, this requirement 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 April 22, 2004.
                                           II-47
                                                                                  September 1997

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                                                                             Inspection Checklists
          TABLE 7-5. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                             WITH INTERNAL FLOATING ROOFS
A "yes" response to all questions will indicate compliance, and a "no" response will indicate
noncompliance with the standard*                  ,         ,,., r   ^
Storage Vessel Identification: ___	_	

REVIEW OF RECORDS

1.     Review records of external visual inspections
       (a)     The occurrence of each annual external visual inspection
              is recorded. If the floating roof is equipped with double
              seals, the source will not have performed this inspection if
              it chose to perform internal visual inspections once every
              5 years instead of performing both annual external visual
              inspections and internal visual inspections at least once
              every 10 years. See Item 2 below.
       (b)     For each annual external visual inspection in which a
              failure was detected, the following information is submitted
              in the PR:  (1) the date of the inspection, (2) identification
              of all storage vessels for which failures were detected,
               (3) a description of those failures, and (4) either the date
               and the nature of the repair or the date the vessel was
               emptied.
       (c)     If the report described in (a) and (b) documents that the
               repair was made more than 45 days after the failure was
               detected, then the next PR includes documentation of the
               use of up to two 30-day extensions for completing the
               repair and the following information: identification of the
               storage vessel, a description of the failure, documentation
               that alternate storage capacity was unavailable, a
               schedule of actions to be taken to repair the control
               equipment or empty the vessel as soon as possible, and
               the date the storage vessel was emptied and the nature of
               and date the repair was made.
  2.    Review records of internal visual inspections.
        (a)    The occurrence of each internal visual inspection is
               recorded. If the floating roof is equipped with double seals
                and the source chose not to perform annual external
                inspections [described in item 1(b)], this inspection will be
                performed, recorded, and reported at least every 5 years.
YD
ND
YD
ND
 YD
  YD
  ND

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Volume l[	\	 	Inspection Checklists
           TABLE 7-5. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                              WITH INTERNAL FLOATING ROOFS
       (b)     For each internal visual inspection in which a failure was        YD          N D
               detected, the following information is submitted in the PR:
               (1) the date of the inspection, (2) identification of all
               storage vessels for which failures were detected, (3) a
               description of those failures, and (4) the date and nature of
               the repair.

       (c)     Any repairs performed as described in (b) were completed      YD          N D
               before the repaired storage vessel was refilled.

       (d)     For each internal visual inspection documented in a PR,        YD          N D
               there is a report notifying the Administrator in advance of
               the date the inspected vessel would be refilled after the
               inspection. If the inspection had been planned, the report
               was submitted 30 days in advance of refilling the vessel.
               If the inspection was not planned, then the report was
               submitted at least 7 days in advance of refilling the vessel
               and included an explanation of why the inspection was
               unplanned.


 VISUAL INSPECTIONS


 Note: The inspector should be advised of the hazards of inspecting an internal floating roof vessel that
       contains a liquid hazardous air pollutant (HAP). An inspector may perform an external visual
       inspection of a storage vessel at any time (i.e., the vessel does  not need to be taken out of
       service). However, the inspector will need to have proper respiratory protection before opening
       the roof hatch to visually inspect, from the fixed roof, the floating deck and seal. An inspector
       may perform the more thorough internal inspection only when the vessel has been taken out of
       service (i.e., emptied, degassed and cleaned). Unless a vessel is taken out of service more
       frequently than is required by the HON, this internal inspection can only take place once every
       ten years, during those 30 days after which the State Agency has received notice that the vessel
       has been emptied and degassed and will subsequently be refilled. The inspector should never
       enter a storage vessel to inspect the IFR without first consulting documents that address the
       safety issues  to consider while entering a confined space and while inspecting an IFR that
       contains HAP - EPA Order 1440.2 and the EPA document Guidance on Confined Space Entry
       in  NESHAP Inspections of Benzene Storage Vessels (EPA-455/R-92-003, September 1992).
 1.     External Visual Inspection

       (a)     The IFR is resting on the liquid surface of the stored            YD          N D
               material, unless the IFR is resting on the leg supports
               because the vessel has just been emptied and degassed
               or the vessel is partially or completely emptied before
               being subsequently refilled or degassed.

       (b)     The IFR is in good condition (i.e., free of defects such as        YD          N D
               corrosion and pools of standing liquid).
                                             II-49
                                                                                     September 1997

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Volume II	Inspection Checklists

           TABLE 7-5. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                              WITH INTERNAL FLOATING ROOFS
        (c)     Inspect the seal (i.e., if a single-seal system is used,
               inspect the single seal, and if a double-seal system is
               used, inspect both the primary and secondary seals).

          (1)   The seal is not detached from the IFR.                        YD          N D
          (2)   There are no holes, tears, or other openings in the seal or       YD          N D
               seal fabric.
          (3)   There are no visible gaps between the seal and the wall of      YD          N D
               the storage vessel.

  2.     Internal Visual Inspection
        (a)     The IFR is resting on the liquid surface of the stored            YD          N D
               material, unless the IFR is resting on the leg supports
               because the vessel has just been emptied and degassed
               or the vessel is partially or completely emptied before
               being subsequently refilled or degassed.
        (b)     The IFR is in good condition (i.e., free of defects such as        YD          N D
               corrosion  and pools of standing liquid).

        (c)     The IFR is equipped with one of the following closure           YD          N D
               devices, between the wall of the storage vessel and the
               edge of the IFR: (1) a liquid-mounted seal, (2) a metallic
               shoe seal, or (3) two seals (i.e., a primary and secondary
               seal), each of which forms a continuous closure that
               completely covers the annular space between the wall of
               the storage vessel and  the edge of the IFR.a

        (d)     Inspect the seal (i.e., if a single-seal system is used,
               inspect the single seal,  and if a double-seal system is
               used, inspect both the primary and secondary seals).
          (1)  The seal is not detached from the IFR.                       YD          ND

          (2)  There are no holes, tears, or other openings in the seal or      YD          N D
               seal fabric.
          (3)  There are no visible gaps between the seal and the wall of      YD          N D
               the storage vessel.

        (e)     Inspect deck openings.
          (1)   If the IFR is non-contact, then each opening in the floating       YD          N D
                roof, except for automatic bleeder vents and rim space
                vents, provides a projection below the stored liquid's
                surface.13
                                                                                       September 1997

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                                                                   Inspection Checklists
  TABLE 7-5. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                    WITH INTERNAL FLOATING ROOFS
(2)   Except for leg sleeves, automatic bleeder vents, rim space      Y D
      vents, column wells, ladder wells, sample wells, and stub
      drains, each opening in the IFR is equipped with a
      gasketed cover or lid.c

(3)   Each cover or lid on any opening in the IFR is closed,           Y D
      unless the cover or lid is open for access.

(4)   Covers on each  access hatch and automatic gauge float        Y D
      well are bolted or fastened so as to  be air-tight when
      closed.
ND




ND


ND
(5)
(0
d)
(2)
(3)
(g)
(1)
(2)
(3)
(h)
0)
(i)
(k)
^ —
The gasket on each cover or lid described in (3) closes off YD
the liquid surface from the atmosphere.
Inspect automatic bleeder vents.
Automatic bleeder vents are closed, unless the roof is YD
being floated off or is being landed on the roof leg
supports.
Each automatic bleeder vent is gasketed.0 y rj
The gasket on each automatic bleeder vent closes off the Y D
liquid surface from the atmosphere.
Inspect rim space vents.
Rim space vents are closed, except when the roof is being Y D
floated off the roof leg supports or when the pressure
beneath the rim seal exceeds the manufacturer's
recommended setting.
Rim space vents are gasketed.0 Y D
The gaskets on the rim space vents close off the liquid Y O
surface from the atmosphere.
Each, sample well (i.e., each penetration of the IFR for the Y D
purpose of sampling), has a slit fabric cover that covers at
least 90 percent of the opening.0
Each penetration of the IFR that allows for passage of a YD
ladder has a gasketed sliding cover.0
Each penetration of the IFR that allows for passage of a YD
column supporting the fixed roof has either a flexible fabric
sleeve seal or a gasketed sliding cover.0
The gaskets described in (i) and (j) close off the liquid Y D
surface to the atmosphere.
ND

ND
ND
ND

Nn
ND
ND
ND
ND
ND
ND
""•"•IN 	 ». 	 __ 	 u 	 	 • 	 - 	 	 ...lg^..,,. 	 aw<
                                                                       September 1997

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                                                                     Inspection Checklists
   TABLE 7-5  COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                      WITH INTERNAL FLOATING ROOFS
(I)
If a flexible fabric sleeve seal is used as described in G),
the fabric sleeve is free of defects (i.e., free of holes, tears,
or gaps).
                                                                YD
                                                                     ND
PR = Periodic Report.   IFR = Internal Floating Roof.

If the internal floating roof is equipped, as of December 31,1992 with a single vapownounted
seal, then the requirement for a liquid-mounted seal or metallic shoe seal or two seals does not
apply until the earlier of the following dates: (1) the next time the storage vessel is emptied and
degassed, or (2) April 22, 2004.

If these openings (excluding automatic bleeder vents and rim space vents) did not Provide
projecHons below the liquid service as of December 31,1992, this requirement 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 April 22, 2004.

 If the internal floating roof did not meet these specifications as of December 15 1992, the
 element to meet these specifications does not apply until the ^'er°!^e fonowing dat»*
 (1) the next time the storage vessel is emptied and degassed, or (2) no later than April 22, 2004.

-------
Volume II
           TABLE 7-6. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                    WITH AN EXTERNAL FLOATING ROOF CONVERTED TO
                               AN INTERNAL FLOATING ROOF
 A "yes" response to ail questions wi Indicate compliance, and a "no" response will indicate
 noncompliance with the standard,
 Storage Vessel Identification:	

 REVIEW OF RECORDS


 1.     Review records of external visual inspections

       (a)     The occurrence of each annual external visual inspection        YD          N D
              is recorded.  If the floating roof is equipped with double
              seals, the source will not have performed this inspection if
              it chose to perform internal visual inspections once every
              5 years instead of performing both annual external visual
              inspections and internal visual inspections at least once
              every 10 years. See Item 2 below.

       (b)     For each annual external visual inspection in which a            YD          ND
              failure was detected, the following  information is submitted
              in the PR: (1) the date of the inspection, (2) identification
              of all storage vessels for which failures were detected,
              (3) a description of those failures, and (4) either the date
              and the nature of  the repair or the date the vessel was
              emptied.

       (c)      If the report described in (a) and (b) documents that the          YD          ND
              repair was made more than 45 days after the failure was
              detected, then the next PR includes documentation of the
              use of up to two 30-day extensions for completing the
              repair and the following information: identification of the
              storage vessel, a  description of the failure, documentation
              that alternate storage capacity was unavailable, a
              schedule of actions to be taken to repair the control
              equipment or empty the vessel as soon as possible, and
             the date the storage vessel was emptied and the nature of
             and date the repair was made.

2.     Review records of internal visual inspections.

      (a)     The occurrence of each internal visual inspection is             YD         N n
             recorded.  If the floating roof is equipped with double seals
             and the source chose not to perform annual external
             inspections [described in item 1(b)], this inspection will be
             performed, recorded, and reported  at least every 5 years.
                                            II-53
                                                                                   September 1997

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                                                                           Inspection Checklists
         TABLE 7-6  COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                  WITH AN EXTERNAL FLOATING ROOF CONVERTED TO
                             AN INTERNAL FLOATING ROOF
                                                                      YD
                                                                    ND
                                                                      YD


                                                                      YD
                                                                     ND


                                                                     ND
(b)     For each internal visual inspection in which a failure was
       detected, the following information is submitted in the PR:
       (1) the date of the inspection, (2) identification of all
       storage vessels for which failures were detected, (3) a
       description of those failures, and (4) the date and nature of
       the repair.
(c)     Any repairs performed as described in (b) were completed
       before the repaired storage vessel was refilled.
(d)     For each internal visual inspection documented in a PR,
       there is a report notifying the Administrator in advance of
       the date the inspected vessel would be refilled after the
       inspection.  If the inspection had been planned, the report
       was submitted 30 days in advance of refilling the vessel.
        If the inspection was not planned, then the report was
        submitted at least 7 days in advance of refilling the vessel
        and included an explanation of why the inspection was
        unplanned.
VISUAL INSPECTIONS

Note- The inspector should be advised of the hazards of inspecting an external floating roof vessel
     ' converted to an internal floating roof vessel that contains a liquid hazardous air pollutant (HAP).
      An inspector may perform an external visual inspection of a storage vessel at any time (i.e., the
      vessel does not need to be taken out of service). However, the inspector will need to have
      proper respiratory protection before opening the roof hatch to visually inspect, from the fixed
      roof the floating deck and seal. An inspector may perform the more thorough internal inspection
      only when the vessel has been taken out of service (i.e., emptied, degassed and cleaned).
      Unless a vessel is taken out of service more frequently than is required by the HON, this internal
      inspection can only take place once every ten years, during those 30 days after which the State
      Agency has received notice that the vessel has been emptied and degassed and will
      subsequently be refilled. The inspector should never enter a storage vessel to inspect the
      floating roof without first consulting documents that address the safety issues to consider while
      entering a confined  space and while inspecting an external floating roof vessel converted to an
      internal floating roof vessel that contains HAP- EPA Order 1440.2 and the EPA document
       Guidance on Confined Space  Entry in NESHAP Inspections of Benzene Storage Vessels (EPA-
      450/R-92-003, September 1992).
 1.     External Visual Inspection

       (a)
The floating roof is resting on the liquid surface of the
stored material, unless the floating roof is resting on the
leg supports because the vessel has just been emptied
and degassed or the vessel is partially or completely
                                                                  YD
                                                                                    September 1997

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                                                                              Inspection Checklists
          TABLE 7-6. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                    WITH AN EXTERNAL FLOATING ROOF CONVERTED TO
                               AN INTERNAL FLOATING ROOF
      (b)
      (c)
        (1)
        (2)


        (3)
 The floating roof is in good condition (i.e., free of defects
 such as corrosion and pools of standing liquid).

 Inspect the seal (i.e., if a single-seal system is used,
 inspect the single seal, and if a double-seal system is
 used, inspect both the primary and secondary seals).

 The seal is not detached from the floating roof.

 There are no holes, tears, or other openings in the seal or
 seal fabric.

 There are no visible gaps between the seal and the wall of
 the storage vessel.
2.     Internal Visual Inspection
      (a)
      (b)

      (c)
      (d)
 The floating deck is resting on the liquid surface of the
 stored material, unless the floating deck is resting on the
 leg supports because the vessel has just been emptied
 and degassed or the  vessel is partially or completely
 emptied before being subsequently refilled or degassed.

 The floating deck is in good  condition (i.e., free of defects
 such as corrosion and pools of standing liquid).

 The floating deck is equipped with one of the following
 closure devices,  between the wall of the storage vessel
 and the edge of the floating deck: (1) a liquid-mounted
 seal, (2) a metallic shoe seal, or (3) two seals (i.e., a
 primary and secondary seal), each of which forms a
 continuous closure that completely covers the annular
 space between the wall of the storage vessel and the
 edge of the floating deck.3

 Inspect the seal (i.e.,  if a  single-seal system is used,
 inspect the single seal, and if a double-seal system is
used, inspect both the primary and secondary seals).

(1)     The seal  is not detached from the floating deck.
             (2)
             (3)
       There are no holes, tears, or other openings in the
       seal or seal fabric.
     (e)
       There are no visible gaps between the seal and
       the wall of the storage vessel.
Inspect deck openings
                                                                        YD
              ND
 YD

 YD


 YD
                                                                       YD
 ND

 ND


 ND




 ND
YD


YD
ND


ND
YD

YD


YD
ND

ND


ND
                                           II-55
                                                                                   September 1997

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                                                                   Inspection Checklists
 TABLE 7-6  COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
          WITH AN EXTERNAL FLOATING ROOF CONVERTED TO
                     AN INTERNAL FLOATING ROOF
(f)
(1)     If the floating deck is non-contact, then each
       opening in the floating roof, except automatic
       bleeder vents and rim space vents, provides a
       projection below the stored liquid's surface.b

(2)     Except for automatic bleeder vents, rim space
       vents, roof drains, and leg sleeves, each opening
       in the roof is equipped with a gasketed cover,
       seal, or lid which forms a vapor-tight seal.

(3)     Each gasketed cover, seal, or lid on any opening
       in the floating deck is closed, unless the cover or
       lid must be open for access.
(4)     Covers on each access hatch and gauge float well
       are bolted or fastened so as to be air-tight when
       closed.            •
(5)    The gasket on each cover, seal, or lid described in
        (2) closes off the liquid surface from the
        atmosphere.

 Inspect automatic bleeder vents
 (1)     Automatic bleeder vents are closed, unless the
        roof is being floated off or is being landed on the
        roof leg supports.
 (2)     Automatic bleeder vents are gasketed.

 (3)     The gaskets on the automatic bleeder vents close
        off the liquid surface from the atmosphere.
(g)   Inspect rim space vents

      (D
 (h)
         Rim space vents are closed, except when the roof
         is being floated off the roof leg supports or when
         the pressure beneath the rim seal exceeds the
         manufacturer's recommended setting.

  (2)     Rim space vents are gasketed.
  (3)     The gaskets on the rim space vents close off the
         liquid surface from the atmosphere.
  Each roof drain is covered with a slotted membrane fabric
  that covers at least 90 percent of the area of the opening.

  Each unslotted guide pole well has either a gasketed
  sliding cover or a flexible fabric sleeve seal.
                                                             YD
                                                              YD
                                                              YD
                                                              YD
                                                              YD
YD



YD

YD



YD




YD

YD


 YD


 YD
                                                                      ND
            ND
            ND
             ND
             ND
ND



ND

ND



ND




ND

ND


ND


 ND
                                     II-56
                                                                            September 1997

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Volume I
           TABLE 7-6.  COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                    WITH AN EXTERNAL FLOATING ROOF CONVERTED TO
                               AN INTERNAL FLOATING ROOF
         G)    Each unslotted guide pole shall have on the end of the          YD          N D
              pole a gasketed cap which is closed at all times except
              when gauging the liquid level or taking liquid samples.

         (k)   Each slotted guide pole well is equipped with the following       YD          N D
              equipment: (1) a gasketed sliding cover or a flexible fabric
              sleeve seal, and (2) a gasketed float inside the guide pole
              or other control device which closes off the liquid surface
              from the atmosphere.

         (I)    Each gauge hatch/sample well has a gasketed cover            YD          N D
              which is closed (except when the hatch or well must be
              open for access).

         (m)   AH of the gaskets described in (i), (j), (k), and (I) close off        YD          N D
              the liquid surface from the atmosphere.


  If the internal floating roof is equipped, as of December 31, 1992, with a single vapor-rnounted seal,
  then the requirement for a liquid-mounted seal or metallic shoe seal or two seals does not apply until
  the earlier of the following dates:  (1) the next time the storage vessel  is emptied and degassed or
  (2) April 22, 2004.

  If these openings (excluding automatic bleeder vents and rim space vents) did not provide projections
  below the liquid service as of December 31,1992, this requirement 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
  April 22, 2004.
                                                                                  September 1997

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                                                                            Inspection Checklists
         TABLE 7-7. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                           EQUIPPED WITH A CONTROL DEVICE
Complete this form for Group 1 storage vessels equipped with & closed-vent system and control device.
If the control device is shared with a Group 1 process vent or Group 1 transfer rack, the provisions for
control devices used for process vents and transfer racks can be followed Instead of the provisions for
storage vessels - see process vent or transfer rack checklists, A "yes" response to a(i questions wilt
indicate compliance and a "no" response will indicate noncompfiance with this standard.
Storage Vessel Identification:.
REVIEW OF RECORDS
1.    A design evaluation of the control device and a description of the
      gas stream entering the control device are recorded and reported
      in the NCS.a'b-c
  (a)  If the control device is a thermal incinerator, the design evaluation       YD          N D
      includes the autoignition temperature of the organic HAP emission
      stream, the combustion temperature, and the residence time at the
      combustion temperature.3'0
  (b)  If the control device is a carbon adsorber, the design evaluation         YD          N D
      includes the affinity of the organic HAP vapors for carbon, the
      amount of carbon in each bed, the number of beds, the humidity of
      the feed gases, the temperature of the feed gases, the flow rate of
      the organic HAP emission stream, the desorption schedule,  the
      regeneration stream pressure or temperature, and the flow rate of
      the regeneration stream.  For vacuum desorption, pressure drop is
      included.
  (c)   If the control device is a condenser, the design evaluation includes      YD         N D
      the final temperature of the organic HAP vapors, the type of
       condenser, and the design flow rate of the organic HAP emission
       stream.
 2.    The documentation described in (a) demonstrates that the control       YD          N D
       device achieves 95-percent control efficiency during reasonably
       expected maximum loading conditions (or 90-percent efficiency if
       the control device was installed prior to December 31,1992).
 3.    Recorded and reported in the NCS are: (1) a description of the          YD          N D
       parameter (or parameters) to be monitored to ensure that the
       control device is operated and maintained in conformance with its
       design, (2) an explanation of the criteria used for selection of the
       parameter (or parameters), and (3) the frequency with which
       monitoring will be performed.
 4.    For each monitoring parameter identified in the NCS, the operating      YD          N D
       range is recorded and reported in the NCS.
                                             H-58                                    September 1997

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Volume II
           TABLE 7-7.  COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSELS
                            EQUIPPED WITH A CONTROL DEVICE
 5.     Records of the monitored parameter (or parameters), as described      YD         N D
        in (c) and (d), are kept at the required frequency.

 6.     Each occurrence when the monitored parameter (or parameters)        YD         N D
        was outside its parameter range (documented in the NCS) is
        recorded and reported in the PR.

 7.     Each record and report described in (6) includes an explanation of      YD         N D
        why the measured parameter (or parameters) was outside of its
        established range.

 8.     The total number of hours of routine maintenance of the control         YD         ND
        device during which the control device does not achieve a
        95-percent control efficiency (or 90-percent control efficiency if the
        control device was installed prior to December 31,1992) is
        recorded and reported in the PR.
 VISUAL INSPECTION

 1.     There are no visible gaps, holes, or corrosion spots seen in the         YD         ND
        ductwork of the vapor collection system.

 2.     A device to monitor the parameter (or parameters) specified in the      YD         N D
        NCS is present.
NCS = Notification of Compliance Status

a A design evaluation is not required for a boiler or process heater with a capacity of 44 MW or greater; a
  boiler or process heater burning hazardous waste with a final permit under 40 CFR Part 270 meeting
  the requirements of 40 CFR Part 266 Subpart H, or has certified compliance that it meets the
  requirements of 40 CFR Part 266 Subpart H; a hazardous waste incinerator with a final permit under
  40 CFR Part 270 meeting the requirements of 40 CFR Part 264 Subpart O, or has certified compliance
  that it meets the requirements of 40 CFR Part 265 Subpart O; or a boiler or process heater into which
  the vent stream is introduced with the primary fuel.

b If an enclosed combustion device is documented to have a minimum residence time of 0.5 seconds and
  a minimum temperature of 760°C, then additional documentation is not required.

c If the control device used to comply with the storage vessel provisions is also used to comply with the
 process vent, transfer, or wastewater provisions, the performance test required by those provisions is an
 acceptable substitute for the design evaluation for determining compliance.
                                            II-59
                                                                                   September 1997

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Volume II                                                      ^^^^_   '"spection Checklists,


           TABLE 7-8. COMPLIANCE CHECKLIST FOR GROUP 1 STORAGE VESSEL
                 EMISSIONS ROUTED TO A PROCESS OR FUEL GAS SYSTEM
 Complete this form when the emissions from a <3raup 1 storage vessel is routed to a process or fuel
 gas system. A "yes* response to all questions will indicate compliance and a "no11 response win indicate!
 noncompliancewiththe standard,
  Storage Vessel Identification: ,	

  REVIEW OF RECORDS

  1.     For emissions routed to a process, a design evaluation or             YD         N D
        engineering assessment demonstrating the extent to which the
        emissions are recycled, consumed, transformed by chemical
        reaction into materials that are not HAP's, incorporated into a
        product and/or recovered were submitted in the NCS.

  2.     Records are kept for any by-pass of the fuel gas system or            YD         N D
        process. The records include the reason for the by-pass, duration
        of the by-pass, and documentation that the owner or operator
        either did not increase the liquid level in the storage vessel during
        the by-pass, routed the emissions through a closed-vent system to
        a control device during the by-pass, or the total aggregate time of
        by-pass without routing to a control device during the year has not
        exceeded 240 hours.
  3.     If emissions are routed to a fuel gas system, the report was            YD         N D
        submitted as part of the NCS that the emission stream is routed to
        a fuel gas system.
                                             II-60
                                                                                    September 1997

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Volume II
                                          8.0 WASTEWAT^R
                                           Section 8. Wastewater
                                           Table 6-1. Group Determination Check for Process
                                                    Wastewater Streams ,». + .,,.,>,*.<>..,,,*><,.,,<* H-62
                                                    Roarfmap for the Checklists far Waste Management Units fi-63
                                                    Compliance Checklist for Waste Management Urttts ,. ,f H«67
                                                    Compliance Checklist for TreatmentProcesses .,,	u+74
                                                    Compliance, Checklist for Heat Exchange Systems
                                                    RequttlngLeak Detection „,..»	,,..,,,„	11-78
                                           Table 8-& Roactmap to the Checklist for items of Equipment
                                                    Handling in-Process liquid Streams .><+><,,,><*>„,. H-81
                                           Table $-?> Compliance Checklist for Items of equipment
                                                    Handling in-Process Uquld Streams ,,<*,.,,„,<*,,,
Table 8-2.
Table 8-3,
Tablfe 8-4,
Table 8-5,
Once it is determined that a
wastewater stream is subject to
the HON or there are items of
equipment that meet the criteria
of §63.149 of Subpart G,
Section 8 can be used to carry
out the inspection. Table 8-1 is
used to determine the group
status of process wastewater
streams. Table 8-2 outlines the
provisions for waste management
units that receive, manage or
treat Group 1 process wastewater
streams. It refers to other checklists in Sections 7, 9, and 10 where the requirements are
common to provisions for other emission points. Table 8-3 is a compliance checklist for waste
management units. Table 8-4 is a compliance checklist for wastewater treatment.  Table 8-5 is a
checklist for heat exchange systems requiring leak detection. Table 8-6 is a roadmap for items of
equipment handling in-process liquid streams and meeting the criteria of §63.149 of Subpart G
(Table 4-11 steps through the determination of whether equipment meets the criteria of §63.149 of
Subpart G). The table refers to checklists with requirements that are common to other types of
emission points, Sections 9 and 10. Table 8-6 is a compliance checklist for items of equipment
handling in-process liquid streams.
                                                   11-61
                                                                                         September 1997

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Volume II          	Inspection Checklists


    TABLE 8-1. GROUP DETERMINATION CHECK FOR PROCESS WASTEWATER STREAMS
 Complete this form for all wastewater streafns subject to the HON as determined fn Section 4.
1
 I.      New Sources - Group 1/Group 2 Determination for Streams Containing HAP's Listed on
 	Table 8 of Subpart G of the HON	

 1.     Is the flow rate ^0.02 Cpm and the concentration of Table 8 compounds ;> 10 ppmw?

        Y D    The wastewater stream is Group 1 for HAP's listed on Table 8 of Subpart G of the HON.

        N D    The wastewater stream is Group 2 for HAP's listed on Table 8 of Subpart G of the HON.
               Continue to Section II of this table to determine if the wastewater stream is Group 1 for
               HAP's listed on Table 9 of Subpart G of the HON.
 II.     New and Existing Sources •- Group 1/Group 2 Determination for Streams Containing
 	HAP's Listed on Table 9 of Subpart G of the HON	

 1.     Is the total concentration of Table 9 compounds z 10,000 ppmw at any flow rate or is the total
        concentration of Table 9 compounds ;> 1,000 ppmw and the flow rate ;>10 «pm?

        Y D    The wastewater stream is Group 1 for HAP's listed on Table 9 of Subpart G of the HON.

        N D    The wastewater stream is Group 2 for HAP's listed on Table 9 of Subpart G of the HON.
                                            ""62                                  September 1997

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 Volume II
        TABLE 8-2. ROADMAP FOR THE CHECKLISTS FOR WASTE MANAGEMENT UNITS
  Complete this form for .waste management units receiving, managing, or treating Group t wastewater
  streams or a residua* removed from a Group 1 wastewater stream.  Triers is a specific Section of this
  form for each type of waste management unit. This table is a roadmap to the checklists used to assess
  compltance with the provisions for waste management.

 *1111*1*********''***************^^                                        	'"""'   "''".:","•... "":•";„""	,.

Note: In addition to the checklists referred to below, complete checklist 8-3 for all waste management
units receiving, managing, or treating Group 1 wastewater streams or a residual removed from a Group  1
wastewater stream.

I.  WASTEWATER TANKS

1.      Are wastewater tanks controlled using a fixed roof3?

               YD    Go to checklist 9-2.

               N D    Continue with this checklist.
2.
3.
Are wastewater tanks being controlled using a fixed roof and a closed-vent system routed to a
control device?
               YD
                Go to checklists 9-1 and 9-2, and select from below the checklist corresponding
                to the appropriate control device:
                       n
                       n
                       n
                       n

                       n

                       n
                       n
                       n
                      flare, checklist 10-1;
                      thermal incinerator, checklist 10-2;
                      catalytic incinerator, checklist 10-3;
                      boiler or process heater with a capacity less than 44 MW that does not
                      have the emission stream introduced with the primary fuel, checklist 10-4;
                      boiler or process heater with a capacity greater than 44 MW or that has
                      the vent stream introduced with the primary fuel, checklist 10-5;
                      carbon adsorber, checklist 10-6;
                      condenser, checklist 10-8; or
                      other control device, checklist 10-9.
        N D    Continue with this checklist.

Are wastewater tanks controlled using an external floating roof?

        YD    Go to checklist 7-4.

        N D    Continue with this checklist.
                                              II-63
                                                                                      September 1997

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Volume II	    Inspection Checklists

        TABLE 8-2. ROADMAP FOR THE CHECKLISTS FOR WASTE MANAGEMENT UNITS


4.      Are wastewater tanks controlled using a fixed roof with an internal floating roof?

               YD    Go to checklist 7-5.

               N D    Continue with this checklist.

5.      Are wastewater tanks controlled using an equivalent means of emission limitation?

               If an owner or operator is using another method for achieving compliance other than one
               listed  in  1 through 4, above, review the FEDERAL REGISTER notice permitting the use of
               "the alternative and any monitoring records required.

II. SURFACE IMPOUNDMENTS

1.      Are surface impoundments controlled using a cover with a closed-vent system that routes to a
        control device?

               YD    Go to checklists 9-1 and 9-2, and select from below the checklist corresponding
                       to the appropriate control device:

                       D     flare, checklist 10-1;
                       D     thermal incinerator, checklist 10-2;
                       D     catalytic incinerator, checklist 10-3;
                       D     boiler or process heater with a  capacity less than 44 MW that does not
                              have the emission stream introduced with the primary fuel, checklist 10-4;
                       D     boiler or process heater with a  capacity greater than 44 MW or that has
                              the vent stream introduced with the primary fuel, checklist 10-5;
                       D     carbon adsorber, checklist 10-6;
                       D     condenser, checklist 10-8; or  .
                       D     other control device, checklist 10-9.

                N D    Continue with this checklist.


 2.     Are surface impoundments controlled using a floating flexible membrane cover?

                Only checklist 8-3 applies to surface impoundments with floating flexible membrane
                covers.

        Surface impoundments must have either a cover with closed-vent system routed to a control
        device or a floating flexible membrane cover; no other options apply.
                                               II-64
                                                                                       September 1997

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Volume II	                            Inspection Checklists
        TABLE 8-2. ROADMAP FOR THE CHECKLISTS FOR WASTE MANAGEMENT UNITS



III.  CONTAINERS

        Containers must have a cover.

        Go to checklist 9-2 for containers > 0.42m3 and for containers_< 0.42m3 that do not meet the
        existing DOT specifications and testing requirements.

IV.  INDIVIDUAL DRAINS

1.      Are individual drains controlled using a cover and, if vented, routed to a process or through a
        closed-vent system to a control device?

               YD    Go to checklist 8-3 and 9-2 for the covers; go to checklists 9-1 and 9-2 if a
                       closed-vent systems is being used; and select from below the checklist
                       corresponding to the appropriate control device:

                       D      flare, checklist 10-1;
                       D      thermal incinerator, checklist 10-2;
                       D      catalytic incinerator, checklist 10-3;
                       D      boiler or process heater with a capacity less than 44 MW that does not
                              have the emission stream introduced with the primary fuel, checklist 10-4;
                       D      boiler or process heater with a capacity greater than 44 MW or that has
                              the vent stream introduced with the primary fuel, checklist 10-5;
                       D      carbon adsorber, checklist 10-6;
                       D      condenser, checklist 10-8; or
                       D      other control device, checklist 10-9.

               N D    Continue with this checklist.

2.      Are individual drains controlled using water seal controls or a tightly fitting cap or plug for drains,
        tightly fitting solid covers for junction boxes, and covers or  enclosures for sewer lines?

               Only checklist 8-3 applies to drains, junction boxes and sewer lines controlled in this way.

        Individual drains must have either a cover and a closed-vent system routed to a control device or
        drains, junction boxes and sewer lines covered; no other options apply.


V.  OIL-WATER SEPARATORS

1.      Are oil-water separators controlled using a fixed roof and a closed-vent system routed to a control
        device?

               YD    Go to checklists 9-1 and 9-2, and select from below the checklist corresponding
                       to the appropriate control device:

                       D      flare, checklist 10-1;
                       D      thermal incinerator, checklist 10-2;
                       D      catalytic incinerator, checklist 10-3;
                       D      boiler or process heater with a capacity less than 44 MW that does not
                              have the emission stream introduced with the primary fuel, checklist 10-4;
                                                                                       September 1397

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Volume II	Inspection Checklists

        TABLE 8-2. ROADMAP FOR THE CHECKLISTS FOR WASTE MANAGEMENT UNITS



                       D      boiler or process heater with a capacity greater than 44 MW or that has
                              the vent stream introduced with the primary fuel, checklist 10-5;
                       D      carbon adsorber, checklist 10-6;
                       D      condenser, checklist 10-8; or
                       D      other control device, checklist 10-9.

               N D    Continue with this checklist.

2.      Are oil-water separators controlled using a floating roof?

               Y D    Only checklist 8-3 applies to floating roofs used on oil-water separators.

               N D    Continue with this checklist.

3.      Are oil-water separators controlled using an  equivalent means of emissions limitation?

        If an owner or operator is using another method for achieving compliance other than one listed in
        1 through 2, above, review the FEDERAL REGISTER notice permitting the use of the alternative
        and any monitoring records required.
 a A fixed roof only cannot be used on wastewater tanks if the tank is used for heating wastewater, or
  treating by means of an exothermic reaction or the contents of the tank are sparged. Also, this option
  cannot be used on tanks having a capacity greater than 75 m3 and less than 151 m3 storing liquid with
  a vapor pressure greater than or equal to 13.1 kPa, or for tanks with a capacity of 151 m3 or greater
  storing liquids with a vapor pressure greater than or equal to 5.2 kPa. For these tanks, one of the
  compliance options listed in 1b, 1c, 1d, or 1e must be used.
                                               II-66
                                                                                       September 1997

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Volume II	             Inspection Checklists
           TABLE 8-3. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
 Complete this fora for waste management units, See also table 8-2 to determine if other checklists
 apply to waste management units. A "yes" response to all questions will Indicate compliance and "no"
 responses wtll indicate noncompliance except where noted <
 I.     REVIEW OF RECORDS


 A.    FOR WASTEWATER TANKS, SURFACE IMPOUNDMENTS,
       CONTAINERS, INDIVIDUAL DRAIN SYSTEMS, AND
       OIL-WATER SEPARATORS

 1.     The occurrence of each semiannual visual inspection for improper      YD         N D
       work practices is recorded.

 2.     The occurrence of each semiannual visual inspection for control        YD         N D
       equipment failures is recorded.

 3.     For each inspection during which a control equipment failure was
       identified, the following were recorded and reported in the next
       PRa

       (a)     Date of the inspection.                                   YD         N D

       (b)     Identification of the wastewater tank, surface                 YD         N D
              impoundment, container, individual drain system, or
              oil-water separator having the failure.
       (c)     Description of the failure.                                  YD         N D
       (d)     Description of the nature of the repair.                       YD         N D
       (e)     Date the repair was made.                                YD         N D
 B.    ADDITIONALLY FOR CONTAINERS

 1.    A record of the capacity of each container at the facility is              YD         N D
       maintained.
  C.    FOR DRAIN, JUNCTION BOXES, AND SEWER LINES, AS AN
       ALTERNATIVE TO A.

  1.    A record documents the occurrence of each semiannual inspection      Y n         N D
       of drains to ensure that caps or plugs are in place and properly
       installed [or 2]
                                                                                 September 1997

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Volume II	.	Inspection Checklists

           TABLE 8-3.  COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
 2.    A record documents the occurrence of each semiannual               YD         N D
       verification of water supply to the drain.

 3.    A record documents the occurrence of each semiannual inspection      YD         N D
       of junction boxes to ensure that there are no gaps, cracks, or other
       holes in the cover.
 4.    A record documents the occurrence of each semiannual inspection      YD         N D
       of the unburied portion of each sewer line to ensure that there are
       no cracks or gaps that could result in air emissions.

 D.    ADDITIONALLY FOR OIL-WATER SEPARATORS WITH A
       FLOATING ROOF
 1.    Records indicate that seal gap measurements were performed         YD         ND
       annually for the secondary seal and every five years for the
       primary seal.
 2.    When a failure is detected, the date and results of seal gap            YD         N D
       measurements are submitted in periodic reports, annually for the
       secondary seal and every five years for the primary seal.
 3.    When a control equipment failure is detected in the seal(s), the         YD         N D
       date and results of the visual inspection of the seals (which is
       performed together with the seal gap measurement) are included
       in the PR.
 4.    The date of the seal gap measurement, the raw data obtained          YD         N D
       during the measurement, and the calculations made are recorded.

 5.    The raw data and calculations recorded for seal gap                  YD         N D
       measurements is consistent with the information provided in the
       PR.
 6.    If a failure was detected during a seal gap measurement and           YD         N D
       visual seal inspection, the PR indicated the date and the nature of
       the repair or the date the wastewater tank was emptied.
                                                                                   September 1997

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Volume II                       ,                              ^    	   Inspection Checklists

           TABLE 8-3.  COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS




 II.    VISUAL INSPECTION


 A.    WASTEWATER TANKS, IF THE CONTROL EQUIPMENT IS A
       FIXED ROOF OR A FIXED ROOF WITH A CLOSED-VENT
       SYSTEM ROUTED TO A CONTROL DEVICE

 1.    All openings (e.g., access hatches, sampling ports, and gauge           YD          N D
       wells) are maintained in a closed position (e.g., covered by a lid)
       when not in use (e.g., during sampling, equipment maintenance,
       inspection, or repair).


 B.    SURFACE IMPOUNDMENTS

 1.    Access hatches and all other openings are closed when not in use.      YD          N D

 2.    All control equipment is functioning properly (e.g., seals, joints,           YD          N D
       lids, covers, and doors are not cracked, gapped, or broken).

 3.    For surface impoundments with floating flexible membrane covers,       YD          N D
       the floating flexible membrane cover is made of high density
       polyethylene with a thickness of no less than 2.5 millimeters, or a
       material that has an equivalent organic permeability and integrity
       for the intended service life of the floating cover.

 4.    For surface impoundments with floating flexible membrane covers,       YD          N D
       all openings are equipped with closure devices such that there are
       no visible cracks, holes, gaps, or other open spaces between the
       perimeter of the cover opening and the closure device when it is
       closed.


 C.    CONTAINERS

 1.    For containers with 0.1 < capacity s.0.42 m3.

       (a)     The container meets existing DOT specifications and           YD          N D
              testing requirements or the requirements of § 63.148 of
              subpart G which are contained in the checklists 9-1 and
              9-2.

       (b)     The cover and all openings are maintained in a closed           YD          N D
              position (e.g.,  covered by a lid) when not in use
              (e.g., during filling).

 2.    For containers with capacity >0.42 m3.

       (a)     The container is equipped with a submerged fill pipe that         YD          N D
              does not extend more than 6 inches or within two fill pipe
              diameters of the bottom of the container while the
              container is being filled.
                                            H-69                 "
                                                                                   September 1997

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Volume II	Inspection Checklists

           TABLE 8-3. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
       (b)     The cover and all openings, except those required for the        YD          N D
               submerged fill pipe and for venting to prevent damage or
               deformation of the container or cover, are closed.

 3.    Whenever a container with capacity ^0.1 m^ is open, during            YD          N D
       treatment in the container of a Group 1 wastewater stream or
       residual, it is located within an enclosure that is routed by a closed-
       vent system to a control device.  The closed-vent system meets
       the requirements in checklists 9-1 and 9-2 and the control device
       meets the requirements in the appropriate checklist in Section 10.

 4.    AH control equipment is functioning properly (e.g. covers and doors      YD          N D
       are not cracked, gapped, or broken).


 D.    INDIVIDUAL DRAIN SYSTEMS

 1.    If the control equipment is a cover with or without a closed-vent
       system routed to a control device or to a process.

       (a)     The individual drain system is designed and operated to         YD          N D
               segregate the vapors within the system from other drain
               systems and the atmosphere.

       (b)     The cover and all openings (e.g., access hatches,              YD          N D
               sampling ports, and gauge wells) are maintained in a
               closed position when not in use (e.g., during sampling,
               equipment maintenance, inspection, or repair).

       (c)     The cover and all openings are maintained in good
               condition.

 2.    For drains, junction boxes, and sewer lines, as an  alternative to
       Item  1:
       (a)     Each drain is equipped with either water seal controls           YD          N D
               (e.g., p-trap, s-trap) or a tightly-fitting cap or plug.

       (b)     For each drain equipped with a water seal, there is water        YD          N D
               in the water seal.

       (c)     If a water seal is used on a drain receiving a Group 1           YD          N D
               process wastewater stream, then one of the requirements
               in (i) or (ii) below, must be met.


               (i)      The drain pipe discharging the wastewater            YD          N D
                       extends below the liquid surface in  the water seal
                       [or(ii)].
                                                                                      September 1997

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Volume II	
        ^•B

           TABLE 8-3. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
               (ii)     A flexible shield (or other enclosure which              YD          N D
                      restricts wind motion) is installed that encloses
                      the space between the pipe discharging the
                      wastewater and the drain receiving the
                      wastewater.

       (d)     Each junction box is equipped with a tightly fitting solid           YD          N D
               cover, and, if vented, is equipped with a vent pipe meeting
               the requirements in (i) or (ii) below.

               (i)      The vent pipe is connected to a closed vent            YD          N D
                      system that meets the requirements in Table 9-2
                      and is routed to a process or to a control device
                      that meets the requirements in Table 10-1
                      through 10-9 for the applicable control device.

               (ii)     If the junction box is filled and emptied by gravity        YD          N D
                      flow or is operated with no more than slight
                      fluctuations in the liquid level, the junction box
                      may be vented to the atmosphere provided the
                      vent.pipe is at least 90 centimeters in length and
                      shall not exceed  10.2 centimeters in diameter;
                      and a water seal is  installed at the entrance or
                      exit of the junction box that restricts ventilation in
                      the individual drain system and between
                      components in the individual drain system.

       (e)     Each sewer line is not open to the atmosphere and is            YD          N D
               covered or enclosed so that no visible gaps or cracks in
               joints, seals, or other emission interfaces exist.

 E.    OIL-WATER SEPARATORS

 IF THE CONTROL EQUIPMENT IS A FLOATING ROOF

 Note: The inspector should not perform the inspection while on the floating roof if the roof is below four
       feet of the top of the separator and if the inspector is not equipped with the proper respiratory
       protection.  Based on the inspector's assessment of the availability of records documenting the
       design of the control equipment, an adequate inspection without respiratory protection may be
       performed with a combination of a record inspection and a visual inspection conducted from the
       platform with the aid of vision-enhancing devices (binoculars). If the inspector feels that it is
       necessary to be on the EFR when the roof is below four feet of the top of the tank, please be
       aware of the requirements under EPA Order 1440.2 and the safety information in Guidance on
       Confined Space Entry in NESHAP Inspections of Benzene Storage Vessels (EPA 455/R-92-003,
       September 1992).
                                             11-71
                                                                                     September 1997

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Volume II	,	.__	Inspection Checklists


           TABLE 8-3. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
 1,    The floating roof is resting on the liquid surface of the stored            YD          N D
       material, unless the floating roof is resting on the roof leg supports
       because the oil-water separator has just been emptied and
       degassed or the tank is partially or completely emptied before
       being subsequently refilled or degassed.

 2.    The floating roof is in good condition (i.e., free of defects such as        YD          N D
       corrosion and pools of standing liquid).
 3.    There is a secondary seal installed above the primary seal.             YD          N D

 4.    Inspect the secondary seal.
       (a)     The secondary seal is continuous and completely covers        YD          N D
               the annular space between the floating roof and the
               separator wall.
       (b)     There are no holes, tears, or other openings in the seal or       YD          N D
               seal fabric.
        (c)     There are no visible gaps between the seal and the wall of      YD          N D
               the oil-water separator, except as specified in (e)(1) and
               (e)(2) below.
        (d)     The seal is not detached from the floating deck.                YD          N D

        (e)     Perform seal gap measurement of the secondary seal as
               specified in §60.696(d)(1) of the standards of performance
               for VOC emissions.
               (1)     The total  gap  area between the separator wall         YD          N D
                       and the secondary seal does not exceed 6.7 cm2
                       per meter (0.32 in2/ft) of the separator wall
                       perimeter.
                (2)     The maximum gap width between the separator        YD          N D
                       wall and the seal does not exceed 1.3  cm (0.5 in)
                       at any point.

  5.    Inspect the primary seal.
        (a)     The primary seal is a liquid-mounted seal.                     YD         N D
        (b)     The primary seal forms a continuous closure that              YD         ND
                completely covers the annular space between the wall of
                the oil-water separator and the edge of the floating roof,
                except as described in (f)(1) and (f)(2) below.
        (c)     There are no holes, tears, or other openings  in the seal         YD          N D
                fabric, seal envelope,  or shoe (if a metallic shoe seal is
                used).
                                                                                       September 1997

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Volume II	                Inspection Checklists
           TABLE 8-3. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
       (d)     If the primary seal is a liquid-mounted seal (e.g., foam or        YD          N D
               liquid-filled seal), the seal is in contact with theJiquid
               between the wall of the oil-water separator and the floating
               roof.

       (e)     The seal is not detached from the floating roof.                 YD          ND
       (f)      Perform seal gap measurements of the primary seal as
               specified in §60.696(d)(1) of the standards of performance
               for VOC emissions.

               (1)     The total gap area between the separator wall          YD          N D
                      and the primary seal does not exceed 67 cm^ per
                      meter (3.2 in^/ft) of separator wall perimeter.

               (2)     The maximum gap width between the separator        YD          N D
                      wall and the seal does not exceed 3.8 cm (1.5 in)
                      at any point.

 6.    If the floating  roof is equipped with one or more emergency roof         YD          N D
       drains for removal of stormwater, each emergency roof drain is
       fitted with a slotted membrane fabric cover that covers at least
       90 percent of the drain opening area or a flexible fabric sleeve
       seal.

 7.    All openings in the floating roof are equipped with a gasketed           YD          NO
       cover, seal, or lid, which  is maintained in a closed position at all
       times, except during inspection and maintenance.

 8.    No gaskets, joints, lids, covers, or doors are cracked, gapped, or        YD          N D
       broken.
PR = Periodic Report

NOTE ALL DEFICIENCIES.
                                                                                     September 1997

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Volume II	:	:	    .    •    Inspection Checklists


             TABLE 8-4. COMPLIANCE CHECKLIST FOR TREATMENT PROCESSES
 A "yes" response to alt questions wilf indicate full compliance, and a "no" responses wilf indicate
 noncompliance except where noted,                  '  -  -

 Note: The HON does not specify a particular treatment process that must be used to achieve
       compliance.  The source may use any waste management unit or treatment process to achieve
       compliance with one of the compliance options (or a combination of compliance options).  The
       compliance options are listed in Tables 7-11 and 7-12 of Volume I.  If the source elects to use a
       design steam stripper, the HON does specify operating parameters in §63.138(d) of Subpart G.
       These operating parameters are included in this checklist.  Sources meeting the requirements of
       the 1mg/yr exemption, described in 7.4.2 of Volume I wastewater streams.


 TREATMENT PROCESS	         •'
 I.     REVIEW OF RECORDS


 FOR ALL TREATMENT PROCESSES

 1a.   Identification and description of the treatment process,              YD            N D
       identification of the wastewater streams treated by the
       process, and identification of monitoring parameters were
       included in the NCS.
 1b.   If a treatment process other than the design steam stripper is        YD            N D
       used, the request to monitor site-specific parameters was
       included in the operating permit application or Implementation
       Plan.
 2.    Documentation to establish a site-specific range was               YD            N D
       submitted  in the NCS or operating permit application.
 3.    Results of the initial measurement of the parameters               YD            N D
       approved by the Administrator were submitted in the NCS or
       operating permit application.
 4.    Records of a design evaluation and supporting                    YD            N D
       documentation that includes operating characteristics were
       included in the NCS [or #5].
 5.    Records of performance tests conducted using test methods        YD            N D
       and procedures specified in §63.145 of Subpart G were
       included in the NCS.                                           	
                                            ""'4

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Volume II	
        ••••

             TABLE 8-4. COMPLIANCE CHECKLIST FOR TREATMENT PROCESSES
 [Note: The records described in #4 and #5 above are not required if the wastewater stream or residual
 is discharged to:  (1) a hazardous waste incinerator permitted under 40 CFR Part 270 and complying
 with 40 CFR Part 264 Subpart O; (2) an industrial furnace or boiler burning hazardous waste that is
 permitted under 40 CFR Part 270 and complying with 40 CFR Part 266, Subpart H; (3) an industrial
 furnace or boiler burning hazardous waste for which the owner or operator has certified compliance with
 the interim status requirements of 40 CFR Part 266 Subpart H; or (4) an underground injection well
 permitted under 40 CFR Part 270 or 40 CFR Part 144 and complying with 40 CFR Part 122.]


 6.     Records described in #4 and #5. demonstrate that the level of       YD            N D
       treatment required by §63.138(b) and/or (c) is achieved.

 7.     Results of visual inspections, in which a control equipment
       failure was identified, were reported in the PR, including:

  (a)   Identification of the treatment process,                           YD            N D

  (b)   Description of the failure,                                       YD            ND

  (c)   Description of the nature of the repair, and                        YD            N D

  (d)   Date the repair was made.            •                          YD            N D

 8.     For each parameter approved by the permitting authority that
       is required to be monitored continuously:

  (a)   Records of the daily average value of the parameter are kept.       YD            N D

  (b)   Each operating day, when the daily average value of the           YD            N D
       parameter was outside the site-specific range established in
       the NCS (i.e., a monitoring parameter excursion is detected),
       or when insufficient monitoring data are collected, they are
       reported in the PR.

 9.     For each treatment process that receives a residual removed
       from a Group 1 wastewater stream, the following were
       submitted in the NCS:

  (a)   Identification of treatment process;                               YD            ND

  (b)   Identification and description of the residual;                       YD            N D

  (c)   Identification of wastewater stream from which residual was         YD            N D
       removed;

  (d)   Fate of residual;                       -                       YD            ND

  (e)   Identification and description of control device (if any) used to       YD            N D
       destroy the HAP mass in the residual by 99 percent; and

  (f)   Documentation of the 99 percent control efficiency of the           YD             N D
       device in (e).

 10.    Records show that residuals are in compliance with control          YD             N D
       options in §63.138(k) of Subpart G.
                                                                                    September 1997

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Volume II                                                                      InspecfonCheckHsts.

             TABLE 8-4.  COMPLIANCE CHECKLIST FOR TREATMENT PROCESSES
 FOR DESIGN STEAM STRIPPERS
 1.     Records are kept of the steam flow rate, wastewater feed           YD            N D
        mass flow rate, and wastewater feed temperature.
 2.     If the parameters in #1 are not monitored, the facility has            YD            N D
        documentation that they applied for and received approval to
        monitor alternative parameter(s) and are performing the
        required recordkeeping and reporting.
   [Note: If #2 is checked "Yes", the facility is in compliance even if
   number 1 is checked "No".]

 FOR BIOLOGICAL TREATMENT UNITS
 1.     Records are kept of appropriate monitoring parameters that         YD            N D
        were approved by the permitting authority.
 2.     Records are kept of the Fbjo determination made according         YD            N D
        to the procedures in Appendix C to 40 CFR Part 63a


  II.     VISUAL INSPECTION

  FOR ALL TREATMENT PROCESSES
  1.     Each opening in the treatment process (except biological           YD             N D
        treatment systems) is covered and vented to a closed-vent
        system that is routed to a control device.
  2.     Any associated closed-vent system is in compliance with the        YD             N D
        HON according to the checklists in Tables 9-1  and 9-2.
  3.     Any associated control device is in compliance with the HON        YD             N D
        according to the appropriate checklist:
        D   flare, checklist 10-1
        D   thermal incinerator, checklist 10-2
        D   catalytic incinerator, checklist 10-3
        D   boiler or process heater with a capacity less than 44 MW
            that does not have the emission stream introduced with
            the primary fuel, checklist 10-4
        D  boiler or process heater with a capacity greater than
            44 MW or that has the vent stream introduced with the
            primary fuel, checklist 10-5
        D  carbon adsorber, checklist 10-6
        D  condenser, checklist 10-8
         D  other control device, checklist 10-9
  4.     Each cover is kept closed and  is  in compliance with the HON        YD            N D
         according to the checklist in Table 9-2.
                                              II-76
                                                                                     September 1997

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Volume II	
       I^BBB

            TABLE 8-4.  COMPLIANCE CHECKLIST FOR TREATMENT PROCESSES
FOR
1.
2.

3.

4.

5.

6.
7.


DESIGN STEAM STRIPPERS
The minimum active column height is at least 5 meters.
The countercurrent flow configuration has a minimum of
10 actual trays.
The minimum steam flow rate is 0.04 kilograms of steam per
I iter of wastewater feed .
The minimum wastewater feed temperature to the steam
stripper is 95 °C.
The maximum liquid loading is 67,100 liters per hour per
square meter.
Operate at nominal atmospheric pressure.
Associated waste management units, closed-vent systems,
and control devices meet the requirements in Tables 8-2 and
8-3.

YD
YD

YD '

YD

YD"

YD
YD



ND
ND

ND

ND

ND

ND
ND


  NCS = Notification of Compliance Status. PR = Periodic Report.

 a It is not required to determine F^JQ for treatment systems that meet the definition of "enhanced
 biological treatment process" where 99% of all compounds on Table 36 of Subpart G in the wastewater
 streams being treated are compounds on list 1 [63.145(h)(1)J.

 NOTE ALL DEFICIENCIES
                                                                               September 1997

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Volume II                                                                       Inspection Checklists
            TABLE 8-5. COMPLIANCE CHECKLIST FOR HEAT EXCHANGE SYSTEMS
                                REQUIRING LEAK DETECTION
 A "yes" response to all questions will indicate full compliance, and "no" responses will indicate
 noncompliance except where noted.
  HEAT EXCHANGE SYSTEM.
  Note:  Sources are not required to comply with leak detection monitoring requirements if one or more of
        the following conditions are met: (1) the heat exchange system is operated with the minimum
        pressure on the cooling water side at least 35 kilopascals greater than the maximum pressure on
        the process side; (2) the once-through heat exchange system has an NPDES permit with an
        allowable discharge limit of less than or equal to 1 ppm above influent concentration or 10% or
        less above influent concentration, whichever is greater; (3) there is an interviewing cooling fluid,
        containing less than 5% of total HAP listed in Table 4 of subpart F, between the process and
        cooling water; (4) the once-through heat exchange system is subject to an NPDES permit that
        requires monitoring of a parameter of condition, that specifies that normal range of the parameter
        or condition, and that requires monitoring of the parameters no less frequently than monthly for
        the fist 6 months and quarterly thereafter; (5) the recirculating heat exchange system is used to
        cool process fluids that contain less than 5% of total HAPs listed in Table 4 of Subpart F; or (6)
        the once-through heat exchange system is used to cool process fluids that contain less than 5%
        of total HAP listed in Table 9 of subpart G. See paragraph 63.104(a) of Subpart F for additional
        details.

  I.     REVIEW OF RECORDS
  1a.   For once-through heat exchange systems, records indicate        YD            N D
        that systems are monitored for leaks of HAPs listed on
        Table 9 of Subpart G. [ or 2]
  1 b.   For recirculating heat exchange systems, records indicate         YD            N D
        that systems are monitored for leaks of HAPs listed on
        Table 4 of Subpart F. [or 2]
  2.    When monitoring of a surrogate indicator of heat exchange
        system leaks is used, a monitoring plan contains the
        following:
        (a)   The procedures that will be used to detect leaks of          YD             N D
              process fluids into cooling water;
        (b)   A description of the parameter or condition to be            YD             N D
              monitored and an explanation of how the selected
              parameter or condition will reliably indicate the
              presence of a leak;
        (c)   The parameter level or condition that shall constitute         YD             N D
              a leak, documented by data or calculations;
                                               H-78
                                                                                      September 1997

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Volume II
            TABLE 8-5. COMPLIANCE CHECKLIST FOR HEAT EXCHANGE SYSTEMS
                                REQUIRING LEAK DETECTION
       (d)   The monitoring frequency which shall be no less            YD             N D
             frequently than monthly for the first 6 months and
             quarterly thereafter; and

       (e)   The records that will be maintained.                       YD             N D


       [Note:  If #2(a), 2(b), 2(c), 2(d), and 2(e) are all checked "Yes", the facility is in compliance even
       if numbers 1a and/or 1 b are checked "No".]

 3.     Records indicating a leak and the date when the leak was         YD             N D
       detected, and if demonstrated not to be a leak, the basis for
       that determination.

 4.     If a leak is detected, the dates of efforts to repair the leak.         YD             N D

 5.     If a leak is detected, the method or procedure used to             YD             N D
       confirm repair of a leak and the date repair was confirmed.

 6.     Documentation for the basis for the determination that a           YD             N D
       shutdown for repair would cause greater emissions than the
       emissions likely to result from delaying the repair; or
       documentation that the necessary parts or personnel were
       not available to make the repair.3

 7.     If there is a delay of repair of a leak, the following
       information was reported in the PR and maintained as a
       record.
(a)
(b)
(c)
(d)
(e)
Identification of the leak and date the leak was detected.
Whether or not the leak has been repaired.
Reason for delay of repair.
The expected date of repair if the leak remains unrepaired.
The date of repair, if the leak is repaired.
YD
YD .
YD
YD
YD
ND
NP
ND
ND
ND
 PR = Periodic Reports.

 a Documentation for a delay of repair is not necessary if the equipment is isolated from the process, or
   if a shutdown is expected within the next 2 months after it is determined that a delay of repair is
   necessary.
                                            II-79
                                                                                    September 1997

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Vdume II         	 	Inspection Checklists

          TABLE 8-5. COMPLIANCE CHECKLIST FOR HEAT EXCHANGE SYSTEMS
                            REQUIRING LEAK DETECTION
 NOTE ALL DEFICIENCIES
                                        11-80
                                                                         'September 1997

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    TABLE 8-6.  ROADMAP TO THE CHECKLISTS FOR ITEMS OF EQUIPMENT HANDLING IN-
                                 PROCESS LIQUID STREAMS
Complete this form for items of equipment that meet criteria of § 63.149 of Subpart G. Checklist 4-11
can be used to determine if the items of equipment meet the criteria in §&3,14&.
1
I.     FOR MANHOLES, LIFT STATIONS, AND TRENCHES:

1.     Is a tightly fitting solid cover with no vent being used?

      YD     Go to checklist 8-7

      N D     Continue with this section of the checklist

2.     Is a tightly fitting solid cover being used with a vent to either a process, to a fuel gas system, or
      to a control device?


      YD     Go to checklist 8-7, and, if emissions are routed to a control device, select from below
              the checklist corresponding to the appropriate control device:

              D      flare, checklist 10-1;
              D      thermal incinerator, checklist 10-2;
              D      catalytic incinerator, checklist 10-3;
              D      boiler or process heater with a capacity less than 44 MW that does not have the
                     emission stream introduced with the primary fuel, checklist 10-4;
              D      boiler or process heater with a capacity greater than 44 MW or that has the vent
                     stream introduced with the primary fuel, checklist 10-5;
              D      carbon adsorber, checklist 10-6;
              D      condenser, checklist 10-8; or
              D      other control device, checklist 10-9.

      N D     Continue with this checklist

3.     If the item is vented to the atmosphere, is a tightly fitting solid cover being used with a properly
      operating water seal a the entrance or exit to the item to restrict ventilation in the collection
      system?


      YD     Go to checklist8-7.
Manhole, lift stations and trenches must use one of the compliance options in 1.1 through I.3.
                                            11-81
                                                                                    September 1997

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Volume II      	  	Inspection Checklists
     TABLE 8-6. ROADMAP TO THE CHECKLISTS FOR ITEMS OF EQUIPMENT HANDLING IN-
                                  PROCESS LIQUID STREAMS
 II.     DRAIN OR DRAIN HUB
 1.     Is a tightly fitting solid cover with no vent being used?

        YD    Go to checklist 8-7

        N D    Continue with this section of the checklist

 2.     Is a tightly fitting solid cover being used with a vent to either a process, to a fuel gas system, or
        to a control device?

        YD    Go to checklist 8-7; and, if emissions are routed to a control device, select from below
               the checklist corresponding to the appropriate control device:

               D      flare, checklist 10-1;
               D      thermal incinerator, checklist 10-2;
               D      catalytic incinerator, checklist 10-3;
               D      boiler or process heater with a capacity less than 44 MW that does not have the
                       emission stream introduced with the primary fuel, checklist 10-4;
               D      boiler or process heater with a capacity greater than 44 MW or that has the vent
                       stream introduced with the primary fuel, checklist 10-5;
               D      carbon adsorber, checklist 10-6;
               D      condenser, checklist 10-8; or
               D      other control device, checklist 10-9.

        N D    Continue with this section of the checklist

  3.    Is a water seal with submerged discharge or barrier to protect the discharge from wind being
        used?
        Y D    Continue with this checklist.
    Drains or drain hubs must use one of the compliance options in 11.1 through II.3.
                                                                                        September 1997

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Volume II
     TABLE 8-6.  ROADMAP TO THE CHECKLISTS FOR ITEMS OF EQUIPMENT HANDLING IN-
                                  PROCESS LIQUID STREAMS
 III.    OIL-WATER SEPARATOR
 1.     Is the oil-water separator equipped with a fixed roof and closed vent system routed to a process
       or control device?
       D Y   Select from below the checklist corresponding to the appropriate control device:

              D      flare, checklist 10-1;
              D      thermal incinerator, checklist 10-2;
              D      catalytic incinerator, checklist 10-3;
              D      boiler or process heater with a capacity less than 44 MW that does not have the
                      emission stream introduced with the primary fuel, checklist 10-4;
              D      boiler or process heater with a capacity greater than 44 MW or that has the vent
                      stream introduced with the primary fuel, checklist 10-5;
              D      carbon adsorber, checklist 10-6;
              D      condenser, checklist 10-8;  or
              D      other control device, checklist 10-9.

       D N   Continue with this checklist.

  2.    If the oil-water separator equipped with a floating roof?

       Checklist 8-3 applies to floating roofs used on oil-water separators.

       Oil-water separators must have either a fixed roof and a closed-vent system routed to a control
       device, or use a floating roof; no other options apply.

 IV.    TANKS3

 1.     Does the tank have a fixed roof'3 only?

       D Y    The tank is in  compliance
       D N    Continue with this checklist
 2.     Is the tank equipped with a fixed roof, closed vent system and are emissions routed to a fuel gas
       system, process or control device?


       D Y    For emissions routed to a control device, go to checklist 7-7
       Must use one of the compliance options in IV.1 or IV.2.
                                            II-83
                                                                                     September 1997

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                                                                     Inspection Checklists
                                                                      __
   TABLE 8-6. ROADMAP TO THE CHECKLISTS FOR ITEMS OF EQUIPMENT HANDLING IN-
                             PROCESS LIQUID STREAMS
 NOTE ALL DEFICIENCIES
a Applies to tanks with capacities of 38 m3

b A fixed roof only can not be used on a tank that is sparged or used for heating or treating by means of
 an exothermic reaction.
                                          11-84
                                                                             September 1997

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                                                                                                           1
Vqlume II
              TABLE 8-7.  COMPLIANCE CHECKLIST FOR EQUIPMENT HANDLING
                                IN-PROCESS LIQUID STREAMS
 Complete this from for manholes, Hft stations, trenches, drains and drain hubs that handle in-process
 liquid streams and that meet the criteria of section 63,149 of Subpart G. Drain or drain hubs with a
 water seal with submerged discharge or barrier to protect the discharge from the wind are not subject to
 the provisions in this checklist A "yes" response to ail questions will indicate compiiance and "no"
 response wilt indicate noncompliance.	
 VISUAL INSPECTION

 1.     Tight fitting solid covers are maintained with no visible gaps       YD            ND
       or openings, except during periods of sampling, inspection, or
       maintenance.


 2.     For tight fitting solid covers with water seals, the vent pipe is       YD            N D
       at least 90 cm in length and does not exceed 10.2 cm in
       nominal inside diameter.  This item does not apply to drains
       or drain hubs.

 3.     For lift stations with tight fitting solid covers with water seals,       YD            ND
       the lift station is level controlled to minimize changes in liquid
       level.
                                            H-85
                                                                                    September 1997

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Volume II
                                                                               Inspection Checklists
            9.0   CLOSED-VENT SYSTEMS AND CONTROL EQUIPMENT
                             REQUIRING LEAK DETECTION
        This section contains checklists
        for equipment that require leak
        detection.  These equipment
        include vent, closed-vent, vapor
        collection,  and vapor balancing
        systems, and the covers,
        enclosures, and fixed roofs
        associated with wastewater
        streams and in-process liquid
        streams handled by equipment
        subject to  §63.149 of Subpart G.
        Table 9-1  contains a checklist for the bypass line provisions and Table 9-2 contains the checklist
        for the leak detection of closed-vent systems and control equipment. The checklists in Sections 5,
        6,7, and 8 refer to these checklists when the provisions regarding bypass lines and leak detection
        of closed-vent systems and control equipment apply.
Section 9. Closed-Venigvsteitis and Control Equipment Requiring Leak


Table 8-1,  Compliance Checklist for Bypass Provisions for Vent,
         Closed-Vent, Vapor Collection, and Vapor Balancing
         Systems . +, < >. < <• • + ..*..». * >,,.,,,+.,,. , ,',*><> H-87
Table 9-2.  Compliance Checklist for Closed-Vent, Vapor Collection,
         And VapOf Balancing Systems, and Covers, Enclosures,
         And Fixed ROfrfS	,	,.......,	II-89
                                                   ll-8b
                                                                                        September 1997

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                                                                                                         1
Volume II
      TABLE 9-1. COMPLIANCE CHECKLIST FOR BYPASS LINE PROVISIONS FOR VENT
          CLOSED-VENT, VAPOR COLLECTION, AND VAPOR BALANCING SYSTEMS*   '
 Complete this form for vent, closed-vent, vapor collection, and vapor balancing systems used on
 process vents, storage vessels, transfer operations, and waste management and treatment units for
 wastewater streams. This checklist does not apply to vent systems routing vapors to recovery devices
 that are part of a process. A "yes" response to all questions will indicate compliance and a "no"
 response will indicate noncompliance with the standard except where noted
 System Identification:.
 REVIEW OF RECORDS

 [Note: Items #1 through #4 do not apply to low leg drains, high
 point bleeds, analyzer vents, open-ended valves or lines, .and
 pressure relief valves needed for safety purposes.]

 1.     Hourly records are kept of whether the flow indicator in the         YD            ND
       bypass line was operating and whether a diversion was
       detected at any time during the hour, when seal mechanisms
       are not used and

 2.     The time of all periods when flow is diverted or the flow             YD            N D
       indicator is not operating are reported in the PR when seal
       mechanisms are not used [ox #3 and #4].

 3.     Records of monthly visual inspections are kept when seal          YD            N D
       mechanisms are used and

 4.     All periods when the seal mechanism is broken, the bypass         YD            N D
       line valve position has changed, or the key to unlock the
       bypass line valve was checked out are recorded and
       reported in the PR when seal mechanisms are used.

  [Note: In order to be in compliance with provisions for bypass
  lines either: #1 and #2 must both be checked "yes" or both #3 and
  #4 must both be checked "yes".]

 VISUAL INSPECTION

 1.    A flow indicator is present at the entrance to any bypass line        Y n            N D
      that could divert the vent stream flow away from the control
      device to the atmosphere or all bypass line valves are sealed
      in  a closed position (e.g., with a car seal or lock-and-key
      configuration).
PR = Periodic Reports.
a This checklist is not applicable to closed-vent systems that are subject to §63 172 in the
  negotiated rule for equipment leaks (40 CFR Part 63 Subpart H) because such closed-vent
  systems are exempt from the requirements in §63.148 of Subpart G of the HON
                                                                                 September 1997

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                                                               Inspection Checklists
    TABLE 9-1. COMPLIANCE CHECKLIST FOR BYPASS LINE PROVISIONS FOR VENT,
        CLOSED-VENT, VAPOR COLLECTION, AND VAPOR BALANCING SYSTEMS3
NOTE ALL DEFICIENCIES
                                      II-88
                                                                       September 1997

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Volume II
                  TABLE 9-2.  COMPLIANCE CHECKLIST FOR CLOSED-VENT
                  VAPOR COLLECTION, AND VAPOR BALANCING SYSTEMS,
                      AND COVERS, ENCLOSURES, AND FIXED ROOFS3
 Complete this form for closed-vent, vapor collection, and vapor balancing systems.  This form $ atso for
 covers, enclosures and fixed roofs associated with wastewater streams or equipment subject to
 §63.149. A "yes" response to all questions wilt Indicate compliance, and a "riow response will Indicate
 noncompliance with the standard,
 Equipment Identification:
 [Note: This checklist does not apply to vapor collection systems that are
 operated under negative pressure.]


 1.     Records are kept of all parts of any closed-vent, vapor-collection,        YD         . N D
       or vapor balancing system, fixed roof, cover, or enclosure that are
       designated as either unsafe-to-inspect or difficult-to-inspect.

 2.     For equipment that is designated as difficult to inspect, a written         YD          N D
       plan is kept that requires inspection of equipment at least once
       every five years.

 3.     For equipment that is designated as unsafe to inspect, a written          YD          N D
       plan is kept that requires inspection of equipment as frequently as
       practicable.

 4.     For each annual inspection during which a leak was detected, the
       following information is recorded and reported.*3

  (a)   Instrument identification numbers, operator name or initials, and         YD          N D
       equipment identification information;

  (b)   The date the leak was detected and the date of the first attempt to        YD          N D
       repair it;

  (c)   Maximum instrument reading after the leak is repaired or                YD          NO
       determined to be non-repairable;

  (d)   Explanation of delay in repair, if the leak was not repaired within          YD          N D
       15 days after it was discovered or by the next transfer loading
       operation, for transfer racks;

  (e)   Name or initials of person who decides repairs cannot be made          YD          N D
       without a shutdown;

  (f)    Expected date of successful repair if not repaired within 15 days;         YD          N D

  (g)   Dates of shutdowns that occur while the equipment is unrepaired;       YD          N D
       and

  (h)   Date of successful repair of the leak.                                 YD          N D
                                            II-89
                                                                                    September 1997

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                                                                          Inspection Checklists
                TABLE 9-2. COMPLIANCE CHECKLIST FOR CLOSED-VENT,
                VAPOR COLLECTION, AND VAPOR BALANCING SYSTEMS,
                    AND COVERS, ENCLOSURES, AND FIXED ROOFS3
5.    For each inspection during which no leaks were detected, the
      following records are kept:&
  (a)  Record that the inspection was performed;                          Y D          N D

  (b)  Date of the inspection; and                                       Y D          N D
  (c)  Statement that no leaks were found.                                YD          N D

a This checklist is not applicable to closed-vent systems that are subject to §63.172 in the
  negotiated rule for equipment leaks (40 CFR Part 63 Subpart H) because such closed-vent
  systems are exempt from the requirements in §63.148 of Subpart G of the HON. The
  checklist is also not subject to closed-vent systems used for process vents.

b Annual visual inspections for visible, audible, or olfactory indications of leaks are required. In
  addition, annual instrument monitoring using Method 21 of 40 CFR part 60, Appendix A, is
  required for vapor collection systems and closed-vent systems constructed of duct work.


NOTE ALL DEFICIENCIES
                                            II-90
                                                                                  September 1997

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Volume II
                            CONTROL DEVICE AND  RECOVERY
                                          ;   CHECKLISTS V;N3fs
                      •If"'1
        This section contains checklist
        specific to the control or recovery
        device being used.  The
        checklists in sections 5,6,7, and
        8 refer to these checklists when
        they are applicable.
Section 10. Control: Device and Recovetv Device Checklists

Table 10-1 Compliance Checklist for flares  	^	
Table 10-2, Compliance Checklist for Thermal Incinerators ,,<*,.,,.
Table 10-3, Compliance Checklist for Catalytic Incinerators ,. ,< + »,,..
Table 10-4, Compliance Checklist for a Boiler or Process Heater
         ^W^S Design He^Uttpgi Capacity les$than      -  ,
      s   44 Megawatts and, the Vent Stream Is Not introduced
       -   with the Primary FueT,..,....,..,.	,,..,
fable 10-5. Cornplfance'Checklfetfor a Boiler or Process Heater with a
          Design Heat Inptrt Capacity Greater than 44 Megawatts  Jt-t02
tafele 1Q-a Compliance ChecWtetfor a Carbon Adsorber Used as a
          Control or Recovery Oew'ce «,...>- + .,»..,>. + ,<».,,,  Jf-103
Table 10-7. Compliance Chegfcfist for an Absorber Used as
          a Control; or Recovery Device ,	  JH06
Table. 10-8. Compliance Checklist for a Condenser used as a
          Confrot or Recovery Device ..»,..„	„.,  iMQs
Table 1O-9. Compliance Checklist for a Control or
          Recovery Device tfot Specifically Listed ,	,,,11-112
Table 10-10, Compliance Checklist for Combusted Halogenated Vent
          Streams Using  a Scrubber  .*.<>.,,,».,,..,,, + ,,
                                                      11-91
                                                                                              September 1997

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Volume II	  	Inspection Checklists


                     TABLE 10-1. COMPLIANCE CHECKLIST FOR FLARES
 Complete this form when emissions are routed to a flare from a process vent, storage vessel, transfer
 rack, waste management or wastewater treatment unit, or equipment that handle in-process liquid
 streams and that meet the criteria of § 63,149 of Subpart G. A "yes" response to ail questions will
 Indicate compliance and "no1* response will indicate noncompltance with the standard-
  Flare Identification:
  REVIEW OF RECORDS

  1.     Results of the initial test were submitted in the NCS.               YD            ND

  2.     The presence of a continuous flare pilot flame is monitored         YD            N D
        using a device designed to detect the presence of a flame.
  3.     All periods when all pilot flames to a flare were absent or the        YD            N D
        monitor was not operating have been recorded and reported
        In the PR.

  4.     For a storage vessel flare, the total number of hours of             YD            N D
        routine maintenance of the flare during which the flare is
        bypassed is recorded and reported in the PR.

  VISUAL INSPECTION
  1.     A device for detecting the flame is present.                       YD            N D
   NCS = Notification of Compliance Status.  PR = Periodic Reports.


  NOTE ALL DEFICIENCIES
                                                                                    September 1997

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Volume II                                                           	      Inspection Checklist?


            TABLE 10-2. COMPLIANCE CHECKLIST FOR THERMAL INCINERATORS
 Complete this form when emissions are routed to & thermal incinerator from a process vent, transfer
 rgcK, waste management or waslewafer treatment unit, or equipment that tiandle in-process liquid
 streams and that meet the criteria of § 63.149 of Subpart G. A "yes" response to all questions wtti
 indicate compliance and "no" response will indicate noncompiiance with the standard except where
 noted                                                                 -
 Control Device:
 REVIEW OF RECORDS

 1.    Results of the initial performance test or design evaluation3         YD            N D
       were submitted in the NCS.

 2.    Test documentation demonstrates 98 percent HAP or TOC         YD            N D
       control efficiency for process vents and transfer racks,
       95 percent HAP or TOC control efficiency for wastewater, or
       an outlet concentration of 20 ppmv or less HAP or TOC.a

 3.    A temperature monitoring device equipped with a continuous        YD            N D
       recorder is used to measure the temperature of the gas
       stream in the firebox (or in the ductwork immediately
       downstream of the firebox before any substantial heat
       exchange occurs).

 4.    Documentation to establish a site-specific range for firebox         YD            N D
       temperature was submitted in the NCS or operating permit
       application.

 5.    Continuous records'3 of firebox temperature are kept.              YD            ND

 6.    Records of daily average firebox temperature are kept.             YD            N D

 7.    All daily average firebox temperatures that are outside the          YD            N D
       site-specific  established range and all operating days when
       insufficient monitoring data are collected are reported in the
       PR.

 8.    The number of excursions does not exceed the number of          YD            N D
       excused excursions in the semi-annual reporting period.0
 9.    If the firebox temperature is not monitored, the facility has           YD            N D
       documentation that they applied for and received approval to
       monitor an alternative parameter, and are performing the
       required recordkeeping and reporting.

 10.   For thermal incinerators used for emissions from waste
       management units and wastewater treatment units,  if the
       firebox temperature is not monitored and if #9 is checked
       "No":
                                             11-93
                                                                                    September 1997

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Volume II	Inspection Checklists

            TABLE 10-2.  COMPLIANCE CHECKLIST FOR THERMAL INCINERATORS
   (a)  Continuous records are kept of the concentration level or           YD            N D
       reading indicated by an organic monitoring device at the
       outlet of the control device.
   (b)  Records are kept of the daily average concentration level or         YD            ND
       reading for each operating day.

   (c)  All daily average concentration levels or readings that are           YD            N D
       outside the site-specific range are reported in the PR.

   [Note: If #9 is checked "Yes", or 10(a), 10(b) and 10(c) are
   checked "Yes", the facility is in compliance even if numbers 3
   through 8 are checked "No".]
 VISUAL INSPECTION
 1.    A temperature monitoring device is present, or approved            YD            N D
       alternative monitor is present.
 2.    For waste management and wastewater treatment units, if          YD            N D
       the monitoring devices listed in item 1 is not present, an
       organic compounds monitor is present.
   [Note:  If item #2 is checked "Yes", the facility is in compliance
   even if #1 is checked "No".]


   NCS = Notification of Compliance Status. PR = Periodic Reports.


 a Owners or operators are not required to conduct performance tests on control devices used to control
   emissions from waste management units, wastewater treatment units, or from transfer racks that
   transfer less than 11.8 million liters per year. For these emission points, a design evaluation
   documenting that the control device being used achieves the required control efficiency as specified
   in §63.139(d)(2) for wastewater or §63.128(h) for transfer racks is required to be submitted as part of
   the NCS.  Owners and operators of process vents routed to a control device do not have the option of
   submitting a design evaluation and must perform a performance test.
 b Continuous records, as defined in §63.111,  means documentation, either in computer readable
   form or hard copy, or data values measured at least once every 15 minutes and recorded at the
   frequency specified in §63.152(f). Section 63.152(f) allows the owner to record either values
   measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
   all measured values during each period. If the daily average value of a monitored value for a given
   parameter is within the range established in the NCS, the owner or operator may retain block hourly
   averages instead of the 15-minute values. An owner or operator may request approval to use
   alternatives to continuous monitoring under §63.151 (g) of Subpart G.
                                              ""94                                    September 1997

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                                                                                                          1
Volume II
            TABLE 10-2. COMPLIANCE CHECKLIST FOR THERMAL INCINERATORS
 c The number of excused excursions is as follows:

  For the first semi-annual period after the NCS is due - 6 excursions;
  For the second semi-annual period - 5 excursions;
  For the third semi-annual period - 4 excursions;
  For the fourth semi-annual period - 3 excursions;
  For the fifth semi-annual period - 2 excursions;
  For the sixth and all subsequent semi-annual periods -1 excursion.

  An excursion occurs when:  (1) the daily average value of the monitored parameter is outside the
  range established in the NCS or operating permit; or (2) if monitoring data are insufficient. In order
  to have sufficient data, a source  must have measured values for each 15-minute period within each
  hour for at least 75 percent of the hours the control device is operating in a day.  For example, if a
  control device operates 24 hours per day, data must be available for all 15-minute periods in at
  least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
  data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
  hour of incomplete data is allowed.

 NOTE ALL DEFICIENCIES
                                            II-95
                                                                                    September 1997

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Volume II               		Inspection Checklists


            TABLE 10-3.  COMPLIANCE CHECKLIST FOR CATALYTIC INCINERATORS
 Complete this form when emissions are routed to a catalytic incinerator from a process vent, transfer
 rack, waste management or wastewater treatment unit, or equipment that handte in~proces$ liquid
 streams and that meet the criteria of § 63.149 of Subpart G> A "yes" response to all questions wttl
 indicate compliance and "no" response will indicate noncompliancewith the standard except where
 noted.                                                .         -f- ,-
  Control Device:
  REVIEW OF RECORDS
  1.     Results of the initial performance test or design evaluation3        YD            N D
        were submitted in the NCS.
  2.     Test documentation demonstrates 98 percent HAP or TOG         YD            ND
        control efficiency for process vents and transfer racks,
        95 percent HAP or TOG control efficiency for wastewater, or
        an outlet concentration of 20 ppmv or less HAP or TOC.a
  3.     Temperature monitoring devices equipped with continuous         YD            N D
        recorders are used to measure the temperature in the gas
        stream immediately before and after the catalyst bed.
  4.     Documentation to establish a site-specific range for the gas        YD            N D
        stream temperature upstream of the catalyst bed and the
        temperature difference across the bed was submitted in the
        NCS or operating permit application.13
  5.     Continuous records0 are kept of the temperature of the gas        YD            ND
        stream upstream of the catalyst bed and the temperature
        difference across the catalyst bed.
  6.     Records of the daily average temperature upstream of the          Y n            N D
        catalyst bed and the temperature difference across the
        catalyst bed are kept.b
  7.    All daily average upstream temperatures that are outside the        YD            N D
        site-specific range and all operating days when insufficient
        monitoring data are collected are reported in the PR.b
   8.    All daily average temperature differences across the catalyst        YD            N D
        bed that are outside the site-specific range and all operating
        days when insufficient monitoring data are collected  are
        reported in the PR.b
   9.    The number of excursions does not exceed the number of         YD            N D
        excused excursions in the semi-annual reporting period.d
                                              11-96
                                                                                      September 1997

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Volume II	Inspection Checklists


            TABLE 10-3. COMPLIANCE CHECKLIST FOR CATALYTIC INCINERATORS
 10.   If the temperature upstream of the catalyst bed and/or the           YD            N D
       temperature differential across the catalyst bed are not
       monitored, the facility has documentation that they applied
       for and received approval to monitor an alternative
       parameter, and are performing the required recordkeeping
       and reporting.13

 11.   For catalytic incinerators used for emissions from waste
       management units and wastewater treatment units, if the
       firebox temperature is not monitored and if #10 is checked
       "No":

  (a)  Continuous records are kept of the concentration level or           YD            N D
       reading indicated by an organic monitoring device at the
       outlet of the control device.

  (b)  Records are kept of the daily average concentration level or         YD            ND
       reading for each operating day.

  (c)  All daily average concentration levels or readings that are           YD            N D
       outside the site-specific range are reported in the PR.

  [Note:  If #10 is checked "Yes", or 11 (a), 11 (b) and  11 (c) are
  checked "Yes", the facility is in compliance even if  numbers 3
  through 9 are checked "No".]


 VISUAL INSPECTION


 1.    A temperature monitoring device is present, or approved            YD            ND
       alternative monitor is present.

 2.    For waste management and wastewater treatment units, if          YD            N D
       the monitoring devices listed in item 1 is not present, an
       organic compounds monitor is present.

  [Note:  If item #2 is checked "Yes", the facility is in  compliance
  even if number 1 is checked "No".]
  NCS = Notification of Compliance Status. PR = Periodic Reports.


  3   Owners or operators are not required to conduct performance tests on control devices used to
     control emissions from waste management units, wastewater treatment units, or from transfer racks
     that transfer less than 11.8 million liters per year. For these emission points, a design evaluation
     documenting that the control device being used achieves the required control efficiency as specified
     in §63.139(d)(2) for wastewater or §63.128(h) for transfer racks is required to be submitted as part
     of the NCS. Owners and operators of process vents routed to a control device do not have the
     option of submitting a design evaluation and  must perform a performance test.
                                             II-97
                                                                                     September 1997

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Vb)un>a II  	Inspection Checklists

            TABLE 10-3.  COMPLIANCE CHECKLIST FOR CATALYTIC INCINERATORS
 b   For catalytic incinerators used for wastewater emission, either the gas stream temperature
     upstream of the catalyst bed or the temperature difference across the bed can be monitored.0
     Continuous records, as defined in §63.111, means documentation, either in computer readable form
     or hard copy, or data values measured at least once every 15 minutes and recorded at the
     frequency specified in §63.152(f). Section 63.152(f) allows the owner to record either values
     measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
     all measured values during each period. If the daily average value of a monitored value for a given
     parameter Is within the range established in the NCS, the owner or operator may retain block hourly
     averages instead of the 15-minute values. An owner or operator may request approval to use
     alternatives to continuous monitoring under §63.151 (g) of Subpart G.
 c   The number of excused excursions is as follows:

     For the first semi-annual period after the NCS is due - 6 excursions;
     For the second semi-annual period - 5 excursions;
     For the third semi-annual period - 4 excursions;
     For the fourth semi-annual period - 3 excursions;
     For the fifth semi-annual period - 2 excursions;
     For the sixth and all subsequent semi-annual periods -1 excursion.

 An excursion occurs when: (1) the daily average value of the monitored parameter is outside the range
 established in the NCS or operating permit; or (2) if monitoring data are insufficient. In order to have
 sufficient data, a source must have measured values for each 15-minute period within each hour for at
 least 75 percent of the hours the control device is operating in a day. For example, if a control device
 operates 24 hours per day, data must be available for all 15-minute periods in  at least 18 hours; but up
 to 6 hours may have incomplete data. If more than 6 hours have incomplete data,  an excursion has
 occurred. For control devices that operate less than 4 hours a day,  one hour of incomplete data is
 allowed.
 NOTE ALL DEFICIENCIES
                                                                                      September 1997

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Volume II                                                                     Inspection Checklists


     TABLE 10-4.  COMPLIANCE CHECKLIST FOR A BOILER OR PROCESS HEATER WITH A
              DESIGN HEAT INPUT CAPACITY LESS THAN 44 MEGAWATTS AND
              THE VENT STREAM IS NOT INTRODUCED WITH THE PRIMARY FUEL
  Complete this form when emissions are routed to a boiler or process heater with a design heat input
  capacity less than 44 megawatts and the vent stream is not introduced with the primary fueJ from a
  process vent, transfer rack, waste management or waste treatment unit, or equipment that handle
  in-process liquid streams and that meet the criteria of § 63.149 of Subpart ®, A "yes" response to all
  questions will Indicate compliance and "no" response will indicate noncomplian.ee with the standard
  except where noted,
  Control Device:
  REVIEW OF RECORDS
  1.     Results of the initial performance test or design evaluation3         YD            N D
        were submitted in the NCS.
  2.     A description of the location at which the vent stream is            YD            N D
        introduced into the boiler or process heater was submitted in
        the NCS.
  3.     The vent stream  is introduced into the flame zone of the            YD            N D
        boiler or process heater.
  4.     Test documentation demonstrates 98  percent HAP or TOC         YD            N D
        control efficiency for process vents and transfer racks,
        95 percent HAP or TOC control efficiency for wastewater, or
        an outlet concentration of 20 ppmv or less HAP or TOC.
  5.     A temperature monitoring device equipped with a continuous       YD            ND
        monitor is used to measure the temperature of the gas
        stream in the firebox.
  6.     Documentation to establish a site-specific range for firebox         YD            ND
        temperature was submitted in the NCS or operating permit
        application.
  7.     Continuous records'3 are kept of the firebox temperature.          YD            N D
  8.     Records of the daily average firebox temperature are kept.         YD            N D

  9.     All daily average firebox temperatures that are outside the         YD            N D
        site-specific range and all operating days when insufficient
        monitoring data  are collected are reported in the PR.
  10.   The number of excursions does not exceed the  number  of         YD           N D
        excused excursions in the semi-annual reporting period.0
                                             H-99                                   September 1997

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Volume II	Inspection Checklists

     TABLE 10-4.  COMPLIANCE CHECKLIST FOR A BOILER OR PROCESS HEATER WITH A
               DESIGN HEAT INPUT CAPACITY LESS THAN 44 MEGAWATTS AND
              THE VENT STREAM IS NOT INTRODUCED WITH THE PRIMARY FUEL
 11.   If the firebox temperature is not monitored, the facility has          YD             N D
       documentation that they applied for and received approval to
       monitor an alternative parameter, and are performing the
       required recordkeeping and reporting.

 12.   For boilers or process heaters used for emissions from waste
       management units and wastewater treatment units, if the
       firebox temperature is not monitored and if #11 is checked
       "No":
       (a)    Continuous records are kept of the concentration           YD             N D
              level or reading indicated by an organic monitoring
              device at the outlet of the control device.

       (b)    Records are kept of the daily average concentration        YD             N D
              level or reading for each operating day.

       (c)    All daily average concentration levels or readings          YD             N D
              that are outside the site-specific range are reported
              in the PR.
       [Note:  If #11 is checked "Yes" or 12(a), 12(b), and 12(c) are
       checked "Yes", the facility is in compliance even if numbers 5
       through 10 are checked "No"]

 VISUAL INSPECTION
 1.    A temperature monitoring device is present, or approved           YD             N D
       alternative monitor is present.
 2.    For waste management and wastewater treatment units, if         YD             ND
       the monitoring devices listed in item 1 is not present, an
       organic compounds monitor is present.
       [Note:  If item #2 is checked "Yes", the  facility is in
       compliance even if number 1 is checked "No".]
   NCS = Notification of Compliance Status. PR = Periodic Reports.
  a Owners or operators are not required to conduct performance tests on control devices used to control
   emissions from waste management units, wastewater treatment units, or from transfer racks that
   transfer less than 11.8 million liters per year.  For these emission points, a design evaluation
   documenting that the control device being used achieves the required control efficiency as specified
   in §63.139(d)(2) for wastewater or §63.128(h) for transfer racks is required to be submitted as part of
   the NCS. Owners and operators of process vents routed to a control device do not have the option of
   submitting a design evaluation and must perform a performance test.
                                            "-100                                   September^

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Volume II	     .                                  Inspection Checklists
     TABLE 10-4.  COMPLIANCE CHECKLIST FOR A BOILER OR PROCESS HEATER WITH A
               DESIGN HEAT INPUT CAPACITY LESS THAN 44 MEGAWATTS AND
              THE VENT STREAM IS NOT INTRODUCED WITH THE PRIMARY FUEL
 b Continuous records, as defined in §63.111, means documentation, either in computer readable
   form or hard copy, or data values measured at least once every 15 minutes and recorded at the
   frequency specified in §63.152(f). Section 63,152(f) allows the owner to record either values
   measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
   all measured values during each period. If the daily average value of a monitored value for a given
   parameter is within the range established in the NCS, the owner or operator may retain block hourly
   averages instead of the 15-minute values. An owner or operator may request approval to use
   alternatives to continuous monitoring under §63.151 (g) of Subpart G.

 c The number of excused excursions is as follows:

       For the first semi-annual period after the NCS is due - 6 excursions;
       For the second semi-annual period - 5 excursions;
       For the third semi-annual period - 4 excursions;
       For the fourth semi-annual period - 3 excursions;
       For the fifth semi-annual period - 2 excursions;
     .  For the sixth and all subsequent semi-annual periods -1 excursion.

   An excursion occurs when: (1) the daily average value of the monitored parameter is outside the
   range established in the NCS or operating permit; or (2) if monitoring data are insufficient. In order
   to have sufficient data, a source must have measured values for each 15-minute period within each
   hour for at least 75 percent of the hours the control device is operating in a day. For example, if a
   control device operates 24 hours per day, data must be available for all 15-minute periods in at
   least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
   data, an excursion has occurred.  For control  devices that operate less than 4 hours a day, one
   hour of incomplete data is allowed.
 NOTE ALL DEFICIENCIES
                                                                                   September 1997

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Volume II	Inspection Checklists


     TABLE 10-5. COMPLIANCE CHECKLIST FOR A BOILER OR PROCESS HEATER WITH A
               DESIGN HEAT INPUT CAPACITY GREATER THAN 44 MEGAWATTS
 Complete this form When emissions are routed to a boiler or process heater with a design heat input
 capacity greater than 44 megawatts from a process vent, transfer rack, waste management or
 wastewater treatment unit, or equipment that handles in-process liquid streams and that meet the
 criteria of § 63.149 of Subpart G. A "yes" response to all questions wllf indicate compliance and "no"
 response will indicate noncornpliance with the standard,
 Control Device:
 REVIEW OF RECORDS
 1.    A description of the location at which the vent stream is            YD            ND
       introduced into the boiler or process heater was submitted in
       the NCS.a
 2.    The vent stream is introduced into the flame zone of the            YD            N D
       boiler or process heater.
 3.    For wastewater, if any changes in the location of where the         YD            N D
       vent stream is introduced, records of these changes are kept.


   NCS = Notification of Compliance Status.

 a This provision doesn't apply for boilers or process heaters used to control emissions from waste
   management and wastewater treatment units.
 NOTE ALL DEFICIENCIES
                                            ""''02                                  September 1997

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Volume II                                                   	Inspection Checklists


       TABLE 10-6.  COMPLIANCE CHECKLIST FOR A CARBON ADSORBER USED AS A
                             CONTROL OR RECOVERY DEVICE
 Compfete this form when emissions are rdufed to a carbon adsorber from a process vent, transfer rack,
 waste management or wastewater treatment unit, or equipment that handle in-process liquid streams
 and that meet the criteria of § 63.149 of Subpart G. A "yes" response to all questions will indicate
 compliance and "no" response will indicate noncompliance with the standard except where noted,.
 Control Device:
 REVIEW OF RECORDS


 FOR CARBON ADSORBERS USED AS A RECOVERY DEVICE
 ON A PROCESS VENT TO MAINTAIN THE TRE INDEX VALUE
 GREATER THAN 1.0

 1.     Documentation of the initial TRE calculation including test          YD            N D
       results was submitted in the NCS.


 FOR CARBON ADSORBERS USED AS A CONTROL DEVICE

 1.     Results of the initial performance test or design evaluation3 a       YD            N D
       were submitted in the NCS.

 2.     Test documentation demonstrates 98 percent HAP or TOG         YD            N D
       control efficiency for process vents and transfer racks,
       95 percent HAP or TOG control efficiency for wastewater, or
       an outlet concentration of 20 ppmv or less HAP or TOG.3''3

 3.     The number of excursions does not exceed the number of          YD            N D
       excused excursions in the semi-annual reporting period.0


 FOR ALL CARBON ADSORBERS

 1.     An integrating regeneration stream (e.g., steam)flow              YD            N D
       monitoring device having an accuracy of+10 percent and
       capable of recording total regeneration stream mass or
       volumetric flow for each regeneration cycle is used to
       measure regeneration stream flow.

 2.     A carbon bed temperature monitoring device capable of            YD            N D
       recording the carbon bed temperature after each
       regeneration and within 15 minutes of completing any cooling
       cycle is used to measure carbon bed regeneration
       temperature.

 3.     Documentation to establish a site-specific range for the            YD            N D
       regeneration stream flow and carbon bed regeneration
       temperature was submitted in the NCS or operating permit.
                                          11-103
                                                                                 September 1997

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Volume II                                                                      Inspection Checklists


        TABLE 10-6.  COMPLIANCE CHECKLIST FOR A CARBON ADSORBER USED AS A
                              CONTROL OR RECOVERY DEVICE
 4.    Records are kept of the total regeneration stream mass or          YD            ND
       volumetric flow for each carbon bed regeneration cycle.
 5.    Records are kept of the temperature of the carbon bed after         YD            N D
       each carbon bed regeneration.
 6.    All regeneration cycles when the total regeneration stream          YD            N D
       mass or volumetric flow is outside the site-specific range are
       reported in the PR.
 7.    All regeneration cycles during which the temperature of the         YD            N D
       carbon bed after regeneration is outside the site-specific
       range are reported in the PR.

 8.    If the regeneration stream flow and/or the carbon bed
       regeneration temperature are not monitored, either:
       (a)     The facility has documentation that they applied for         YD            N D
               and received approval to monitor an alternative
               parameter, and are performing the required
               recordkeeping and reporting or continue with items
               [(b)and(c)sM(d)].
       (b)     Continuous records are kept of the concentration           YD            N D
               level or reading indicated by an organic monitoring
               device at the outlet of the control device.
       (c)     Records are  kept of the daily average concentration        YD            N D
               level or reading for each operating day.
       (d)     All daily average concentration levels or readings          YD            N D
               that are outside the site-specific range are reported
               in the PR.b
       [Note: If #8(a) is checked 'Yes", or if 8(b) and 8(c) god 8(d)
       are checked "Yes", the facility is in compliance even if
       numbers 1 through 7 are checked "No".]


  VISUAL INSPECTION
  1.    A device for measuring carbon bed temperature and a device       YD             N D
       for measuring regeneration stream flow are present [or #2].
  2.     If the monitoring devices listed in item 1 is not present, an          YD             ND
        organic compounds monitor is present.
        [Note:  If item #2 is checked "Yes", the facility is in
        compliance even if number 1 is checked "No".]
   NCS = Notification of Compliance Status. PR = Periodic Reports.
                                                                                     September 1997


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                                                                                                           1
Volume I
        TABLE 10-6.  COMPLIANCE CHECKLIST FOR A CARBON ADSORBER USED AS A
                              CONTROL OR RECOVERY DEVICE
 a Owners or operators are not required to conduct performance tests on control devices used to control
   emissions from waste management units, wastewater treatment units, or from transfer racks that
   transfer less than 11.8 million liters per year.  For these emission points, a design evaluation
   documenting that the control device being used achieves the required control efficiency as specified
   in §63.139(d)(2) for wastewater or §63.128(h) for transfer racks is required to be submitted as part of
   the NCS.  Owners and operators of process vents routed to a control device do not have the option of
   submitting a design evaluation and must perform a performance test.
 L
 D The 20 ppmv compliance option is not available for owners or operators using carbon adsorbers on
   emissions from surface impoundments or containers.

 c The number of excused excursions is as follows:

       For the first semi-annual period after the NCS is due - 6 excursions;
       For the second semi-annual period - 5 excursions;
       For the third semi-annual period - 4 excursions;
       For the fourth semi-annual period - 3 excursions;
       For the fifth semi-annual period - 2 excursions;
       For the sixth  and all subsequent semi-annual periods -1 excursion.

   An excursion occurs when:  (1) the daily average value of the monitored parameter is outside the
   range established in the NCS or operating permit; or (2) if monitoring data are insufficient.  In order
   to have sufficient data, a source must have measured values for each 15-minute period within each
   hour for at least 75 percent of the hours the control device is operating in a day. For example, if a
   control device operates 24 hours per day, data must be available for all 15-minute periods in at
   least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
   data, an excursion has occurred.  For control  devices that operate less than 4 hours a day, one
   hour of incomplete data is allowed.


 NOTE ALL DEFICIENCIES
                                           11-105
                                                                                   September 1997

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Volume II         	_	i:.	       Inspection Checklists


            TABLE 10-7. COMPLIANCE CHECKLIST FOR AN ABSORBER USED AS
                            A CONTROL OR RECOVERY DEVICE
 Complete this form when emissions are routed to an absorber from a process vent or transfer rack. A
 "yes" response to all questions will indicate compliance and "no" response'will indicate noncompliance
 with the standard except where noted.                ,   ,
  Control or Recovery Device:
  REVIEW OF RECORDS
  FOR ABSORBERS USED AS A RECOVERY DEVICE ON A
  PROCESS VENT TO MAINTAIN THE TRE INDEX VALUE
  GREATER THAN 1.0
  1.    Documentation of the initial TRE calculation including test          YD           ND
       results was submitted in the NCS.

  FOR ABSORBERS USED AS A CONTROL DEVICE
  1.    Results of the initial performance test or design evaluation3        YD           N'D
       were submitted in the NCS.

  2.    Test documentation demonstrates 98 percent HAP or TOC        YD           N D
       control efficiency for process vents and transfer racks,
       95 percent HAP or TOC control efficiency for wastewater, or
       an outlet concentration of 20 ppmv or less HAP or TOC.a

  3.    The number of excursions does not exceed the number of         YD           N D
       excused excursions in the semi-annual reporting period.b


  FOR ALL ABSORBERS
  1.    A temperature monitoring device and a specific gravity            YD           N D
        monitoring device equipped with a continuous monitor are
        used to measure the exit temperature of the scrubbing liquid
        and the exit specific gravity.
  2.     Documentation to establish a site-specific range for the exit         YD           ND
        temperature of the scrubbing liquid and exit specific gravity
        was submitted in the NCS or operating permit.

  3.     Records of the daily average exit temperature of the              YD           N D
        scrubbing liquid and exit specific gravity are kept.

  4.     Continuous records0 of the exit temperature of the absorbing       YD           ND
        liquid are kept.
  5.    Continuous records0 of the exit specific gravity are kept.           YE3            ND
                                            11-106                                  September 1997

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Volume II
             TABLE 10-7. COMPLIANCE CHECKLIST FOR AN ABSORBER USED AS
                             A CONTROL OR RECOVERY DEVICE
 6.    All daily average exit temperatures of the absorbing liquid           YD            ND
       that are outside the site-specific range are reported in the
       PR.

 7.    All daily average specific gravity values that are outside the         YD            ND
       site-specific range are reported in the PR.

 8.    If the exit temperature and/or the exit specific gravity are not
       monitored, either:

       (a)      The facility has documentation that they applied for         YD            N D
               and received approval to monitor an alternative
               parameter, and are performing the required
               recordkeeping and reporting or continue with items
               Kb) and (c) and (d)].
       (b)      Continuous records are kept of the concentration           YD            N D
               level or reading indicated  by an organic monitoring
               device at the outlet of the control device.

       (c)      Records are kept of the daily average concentration  .       YD            N D
               level or reading for each operating day.

       (d)      All daily average concentration levels or readings           YD            N D
               that are outside the site-specific range are reported
               in the PR.

       [Note: If #8(a) is checked "Yes", or if 8(b) and'8(c) and-8(d)
       are checked "Yes", the facility is in compliance even if
       numbers 1 through 7 are checked "No".]

 VISUAL INSPECTION

 1.    A device for measuring exit liquid temperature and a device         YD            N D
       for measuring exit specific gravity are present [or #2].

 2.    If the monitoring devices listed in item 1 is not present, an           YD            ND
       organic compounds monitor is present.

       [Note:  If item #2 is checked "Yes", the facility is in
       compliance even if number 1 is checked "No".]
  NCS = Notification of Compliance Status. PR = Periodic Reports.

 a Owners or operators are not required to conduct performance tests on control devices used to control
   emissions from waste management units, wastewater treatment units, or from transfer racks that
   transfer less than 11.8 million liters per year. For these emission points, a design evaluation
   documenting that the control device being used achieves the required control efficiency as specified
   in §63.139(d)(2) for wastewater or §63.128(h) for transfer racks is required to be submitted as part of
   the NCS. Owners and operators of process vents routed to a control device do not have the option of
   submitting a design evaluation and must perform a performance test.
                                                                                     September 1997

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Volume II	Inspection Checklists

             TABLE 10-7.  COMPLIANCE CHECKLIST FOR AN ABSORBER USED AS
                             A CONTROL OR RECOVERY DEVICE
 D The number of excused excursions is as follows:

        For the first semi-annual period after the NCS is due - 6 excursions;
        For the second semi-annual period - 5 excursions;
        For the third semi-annual period - 4 excursions;
        For the fourth semi-annual period - 3 excursions;
        For the fifth semi-annual period - 2 excursions;
        For the sixth and all subsequent semi-annual periods -1 excursion.

   An excursion occurs when: (1) the daily average value of the monitored parameter is outside the
   range established in the NCS or operating permit; or (2) if monitoring data are insufficient. In order
   to have sufficient data, a source must have measured values for each 15-minute period within each
   hour for at least 75 percent of the hours the control device is operating in a day.  For example, if a
   control device operates 24 hours per day, data must be available for all 15-minute periods in at
   least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
   data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
   hour of incomplete data is allowed.
 c  Continuous records, as defined in §63.111, means documentation,  either in computer readable
   form or hard copy, or data values measured at least once every 15 minutes and recorded at the
   frequency specified in §63.152(f). Section 63.152(f) allows the owner to record either values
   measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
   all measured values during each period.  If the daily average value of a monitored value for a given
   parameter is within the range established in the NCS, the owner or operator may retain block hourly
   averages instead of the 15-minute values. An owner or operator may request approval to use
   alternatives to continuous monitoring under §63.151(g) of Subpart G.


  NOTE ALL DEFICIENCIES
                                                                                     September 1997

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Volume II
           TABLE 10-8.  COMPLIANCE CHECKLIST FOR A CONDENSER USED AS A
                           CONTROL OR RECOVERY OR DEVICE
          this form when emissions are routed to acondenserfrom a process vent, transfer rack,
 waste management unit, or wastewater treatment unit, or equipment that handles in-process Hquid
 streams and that meet the criteria of § 63.149 of Subpart G. A "yes" response to all questions will
 indicate compliance and "no" response will indicate noncompliance with the standard except where
 noted.
 Control or Recovery Device:


 REVIEW OF RECORDS


 FOR CONDENSERS USED AS A RECOVERY DEVICE ON A
 PROCESS VENT TO MAINTAIN THE TRE INDEX VALUE
 GREATER THAN 1.0

 1.     Documentation of the initial TRE calculation including test          YD           N D
       results was submitted in the NCS.


 FOR CONDENSERS USED AS A CONTROL DEVICE

 1.     Results of the initial performance test or design evaluation3        YD           N D
       were submitted in the NCS.

 2.     Test documentation demonstrates 98 percent HAP or TOC         YD           N D
       control efficiency for process vents and transfer racks,
       95 percent HAP or TOC control efficiency for wastewater, or
       an outlet concentration of 20 ppmv or less HAP or TOC.a'b

 3.     The number of excursions does not exceed the number of         YD           N D
       excused excursions in the semi-annual reporting period.0


 FOR ALL CONDENSERS

 1.     A temperature monitoring device equipped  with a continuous        YD           N D
       recorder is used to measure the product side exit
       temperature.

 2.     Documentation to establish a site-specific range for the exit        YD           N D
       temperature was submitted in the NCS or operating permit.

 3.     Records of the daily average exit temperature are kept.            YD           N D

 4.     Continuous recordsd  of the exit temperature are kept.             YD           N D

 5.     All product side daily  average exit temperatures that are           YD           N D
       outside the site-specific range are reported in the PR.
                                         11-109
                                                                               September 1997

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                                                                            Inspection Checklists
           TABLE 10-8.  COMPLIANCE CHECKLIST FOR A CONDENSER USED AS A
                           CONTROL OR RECOVERY OR DEVICE
6.    If the exit temperature is not monitored, either:
      (a)     The facility has documentation that they applied for         YD            N D
             and received approval to monitor an alternative
             parameter, and are performing the required
             recordkeeping and reporting or continue with items
             [(b)aM(c)aM(d)].
      (b)     Continuous records' are kept of the concentration           YD            N D
             level or reading indicated by an organic monitoring
             device at the outlet of the control device.
      (c)     Records are kept of the daily average concentration        YD            N D
             level or reading for each operating day.
      (d)    All daily average concentration levels or readings that      YD            ND
             are outside the site-specific range are reported in the
             PR.
      [Note: If #6(a) is checked "Yes", QE if 6(b) and 6(c) and 6(d)
      are checked "Yes", the facility is in compliance even if
      numbers 1 through 5 are checked "No".]

 VISUAL INSPECTION
 1.    A temperature monitoring device is present [or #2].                 YD            ND

 2.     If the monitoring devices listed in item 1 is not present, an           YD            N D
       organic compounds monitor is present.
       [Note: If item #2 is checked "Yes", the facility is in compliance
       even if number 1 is  checked  "No".]

  NCS = Notification of Compliance  Status. PR = Periodic Reports.
 a Owners or operators are not required to conduct performance tests on control devices used  to control
   emissions from waste management units, wastewater treatment units, or from transfer racks that
   transfer less than 11.8 million liters per year. For these emission points, a design evaluation
   documenting that the control device being used achieves the required control efficiency as specified
   in §63.139(d)(2) for wastewater or §63.128(h) for transfer racks is required to be submitted as part of
   the NCS. Owners and operators  of process vents routed to a control device do not have the option of
   submitting a design evaluation and must perform a performance test.
  b The 20 ppmv compliance option is not available for owners or operators using condensers on
   emissions from surface impoundments or containers.
                                             H-110                                   September 1997

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Volume II	Inspection Checklists

            TABLE 10-8. COMPLIANCE CHECKLIST FOR A CONDENSER USED AS A
                            CONTROL OR RECOVERY OR DEVICE
 c The number of excused excursions is as follows:

       For the first semi-annual period after the NCS is due - 6 excursions;
       For the second semi-annual period - 5 excursions;
       For the third semi-annual period - 4 excursions;
       For the fourth semi-annual period - 3 excursions;
       For the fifth semi-annual period - 2 excursions;
       For the sixth and all subsequent semi-annual periods -1 excursion.

   An excursion occurs when:  (1) the daily average value of the monitored parameter is outside the
   range established in the NCS or operating permit; or (2) if monitoring data are insufficient. In order
   to have sufficient data, a source must have measured values for each 15-minute period within each
   hour for at least 75 percent of the hours the control device is operating in a day.  For example, if a
   control device operates 24 hours per day, data must be available for all 15-minute periods in at
   least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
   data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
   hour of incomplete data is allowed.

 d Continuous records, as defined in §63.111, means documentation, either in computer readable
   form or hard copy,  or data values measured at least once every 15 minutes and recorded at the
   frequency specified in §63.152(f). Section 63.152(f) allows the owner to record either values
   measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
   all measured values during each period, if the daily average value of a monitored value for a given
   parameter is within the range established in the NCS, the owner or operator may retain block hourly
   averages instead of the 15-minute values.  An owner or operator may request approval to use
   alternatives to continuous monitoring under §63.151(g) of Subpart G.

 NOTE ALL DEFICIENCIES
                                                                                    September 1997

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Volume II                                                                   Inspection Checklists


                TABLE 10-9. COMPLIANCE CHECKLIST FOR A CONTROL OR
                      RECOVERY DEVICE NOT SPECIFICALLY LISTED
 Complete this form When emissions are routed from a process vent, transfer rack, waste management
 unit or wastewater treatment unit, or equipment that handle in-process liquid streams and that meet the
 criteria of § 63.149 of Subpart G to a control or recovery device not specifically fisted trt the HON, A
 "yes" response to all questions will indicate compliance and "ho" response will indicate noncompliance
 with the standard except where noted.
 Control or Recovery Device: 	

 REVIEW OF RECORDS

 FOR OTHER DEVICES USED AS A RECOVERY DEVICE ON A
 PROCESS VENT TO MAINTAIN THE TRE INDEX VALUE
 GREATER THAN 1.0
 1.    Documentation of the initial TRE calculation including test          YD           N D
       results was submitted in the NCS.

 FOR OTHER DEVICES USED AS A CONTROL DEVICE
 1.    Results of the initial performance test or design evaluation3         YD           N D
       were submitted in the NCS.
 2.    Test documentation demonstrates 98 percent HAP or TOC         YD           ND
       control efficiency for process vents and transfer racks, and
       95 percent HAP or TOC control efficiency for wastewater, or
       an outlet concentration of 20 ppmv or less HAP or TOC.a
 3.    The number of excursions does not exceed the number of         YD           N D
       excused excursions in the semi-annual reporting period.'3

  FOR OTHER DEVICES USED AS EITHER A RECOVERY OR
  CONTROL DEVICE


  1.    The facility has documentation that they applied for and            YD           N D
       received approval to monitor an alternative parameter and are
       performing the required recordkeeping and reporting.
  2.    Documentation to establish a site-specific range for the            YD           N D
       monitored parameter was submitted in the NCS or operating
       permit.
  3.    Records of the daily average monitored parameter are kept.        YD           ND

  4.    Continuous records0 of the monitored parameter are kept.         YD           ND
                                           H-112                                  September 1997

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Volume II	;	   Inspection Checklists

                 TABLE 10-9. COMPLIANCE CHECKLIST FOR A CONTROL OR
                        RECOVERY DEVICE NOT SPECIFICALLY LISTED
 5.    Monitored parameters that are outside the site-specific range        YD            N D
       are reported in the PR.

 VISUAL INSPECTION

 1.    The monitoring device to monitor the approved monitoring           YD            N D
       parameter is present.


   NCS = Notification of Compliance Status. PR = Periodic Reports.

 a Owners or operators are not required to conduct performance tests on control devices used to control
   emissions from waste management units, wastewater treatment units, or from transfer racks that
   transfer less than 11.8 million liters per year. For these emission points, a design evaluation
   documenting that the control device being used achieves the required control efficiency as specified
   in §63.139(d)(2) for wastewater or §63.128(h) for transfer racks is required to be submitted as part of
   the NCS. Owners and operators of process vents routed to a control device do not have the option of
   submitting a design evaluation and must perform a performance test.

 k The number of excused excursions is as follows:

        For the first semi-annual period after the NCS is due - 6 excursions;
        For the second semi-annual period - 5 excursions;
        For the third semi-annual period - 4 excursions;
        For the fourth semi-annual period - 3 excursions;
        For the fifth semi-annual period - 2 excursions;
        For the sixth and all subsequent semi-annual periods -1 excursion.

   An excursion occurs when: (1) the daily average value of the monitored parameter is outside the
   range established in the  NCS or operating permit; or (2) if monitoring data are insufficient. In order
   to have sufficient data, a source must have measured values for each 15-minute period within each
   hour for at least 75 percent of the hours the control device is operating in a day.  For example, if a
   control device  operates 24 hours per day, data must be available for all 15-minute periods in at
   least  18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
   data, an excursion has occurred.  For control devices that operate less than 4 hours a day, one
   hour of incomplete data is allowed.

 c Continuous records, as  defined in §63.111, means documentation, either in computer readable
   form or hard copy, or data values measured at least once every 15 minutes and recorded at the
   frequency specified in  §63.152(f). Section 63.152(f) allows the owner to record either values
   measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
   all measured values during each period. If the daily average value of a monitored value for a given
   parameter is within the range established in the NCS, the owner or operator may retain block hourly
   averages instead of the  15-minute values.  An owner or operator may request approval to use
   alternatives to continuous monitoring under §63.151 (g) of Subpart G.
                                              'I '3                                    September 1997

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                                                      Inspection Checklists
COMPLIANCE TIMELINE AND REPORTING
               CHECKLIST
Once it is known that a source
has emission points that are
subject to the HON, the inspector
may use the checklists contained
in this portion of the guide to
evaluate the content of the
reports submitted as part of the
source's compliance procedures.
Figure 11-1 is a compliance
timeline for the HON; it shows the
compliance dates as well as the
dates when reports must be
submitted. Table 11-1 is a
checklist for the Initial Notification.
The checklist contained in
Table 11-2 pertains to the
implementation data to be                                         ^ ,_,  „, „        «,   M r«m«»n
present in operating permit applications or in the implementation plan. Table 11-3 covers the Notification
of Compliance Status.  Tables 11-4 deals with periodic reports. Table 11-5 provides a checklist for
assessing requests for an extension of compliance.  Table 11-6 is a checklist for evaluating requests for
use of alternative monitoring or recordkeeping procedures. A checklist for the Start-Up, Shutdown and
 Malfunction Plan is given in Table 11-7.  Table 11-8  is a checklist for evaluating Start-up,  Shutdown and
 Malfunction reports.  Table 11 -9 is a checklist for initial notifications for new or reconstructed major
 affected sources. Table 11-10 is a checklist for source construction and reconstruction permit application.
  The tables in this section include general provisions applicable to the HON that pertain to reporting.
        Rgure 11-1.
        Table 11-t
        Tablet^
        Table 11*3.
        Table 11*4,
        Table 11-5,
        Table 11-6,

        Table 11-7*

        Table 11-&

        Table 11 -Q.

        Tabte 11-W
HON Compliance Tiroettne	><*	< + .<» 11-11$
Checklistforftie initial Notification ><„,.,„..>,>. H-120
Chec&listfarftnplernentatiQrt Data ,,,.,,.,,, „.,,. 11*121
C^ecklistfofft^NatifteatldnafCoMpltartOe Status ,, B-123
Checklist for Periodic Reports	>	»11-12S
Checklist for a Request of Compliance Extension .,, IM31
Checklist for Request to Use Alternative Monitoring or
Recordkeepfng Procedures ,., + ,.>,-,.,.<>•<..* (M32
Checklist for Starf-up, Shutdown and
Malfunction Plan , >., >	<*>->,«,< + >	* IM34
Checklist for Start-up, Shutdown and Malfunction
Reports	,...,.:.,	  H-135
Checklist for Initial Notifications by New £r Reconstructed
Major Affected  Sources	 - H-13B
Checklist for Source Construction and Reconstruction
Permit Applications ,,<.<,>	*,. >. * ^ *. ^. IM
                      11-118
                                                                September 1997

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                                                to
                                                O)
                                                o
e

                                                81
                                                         I
                                                         I  1
                                                1 if  «!*|  I  !
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                                                I |  |M:- 1 „*  R
                                                u ?  |1« I S

                                                i i  fi    I
                                                11  III 11
O
i
a
Z
                 J™™ww»lwTOCOXW»i^aftm
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Volume II
                                                                              Inspection Checklists
                   TABLE 11-1. CHECKLIST FOR THE INITIAL NOTIFICATION
  Complete this form for any source with emission points subject to the HON.  A "yes* response to all
  questions will indicate compliance, and a "no" will Indicate noncompliance>
  1.   The report contains the name and address of the owner or
      operator.

  2.   The report provides the physical location (address) of the
      affected sources.

  3.   The report identifies the kinds of emission points within the
      chemical manufacturing process units that are subject to
      Subpart G.
  4.   The report identifies the chemical manufacturing processes
      subject to Subpart G.
  5.   The report provides a statement of whether the source can
      achieve compliance by the relevant compliance dates specified
      in Subpart F.
YD


YD



YD


YD

YD
ND


ND



ND


ND


ND
                                               11-120
                                                                                       September 1997

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Volume I!
                                                                               Inspection Checklists
                    TABLE 11-2.  CHECKLIST FOR IMPLEMENTATION DATA
          this form for existmg sources and for new sources. For existing sources, this Information
          P      ^ m °Pet?inS Permit aPP»ca«w <>r ^ otherwise specified by the permfc
          For new sources, this information must be submitted In the implementation plan 3ss
 already-submitted in the operating permit application, or as otherwise specified by  he permrtC
 authonty A "yes" response to alt questions will indicate compliance, and a "no" wi inlca?e
 noncompfiance except where noted*
 1.
2.
3.
4.
5.
 The report contains a list designating each emission point             y D
 complying with §§63.113 through 63.149 and whether each
 emission point is Group 1 or Group 2.

 The report specifies the control technology or method of              YD
 compliance that will be applied to each Group 1 emission point.

 The report includes a statement that the compliance                  y D
 demonstration, monitoring, inspection, recordkeeping, and
 reporting provisions in §§63.113 through 63.149 that are
 applicable to each emission point will be implemented
 beginning on the date of compliance.

 The report includes the operating plan required by                   YD
 §63.122(a)(2) and (b) for each storage vessel controlled with a
 closed vent system with a control device other than a flare.

 If the owner or operator of the source seeks to comply through
 use of a control technique other than those for which
 monitoring parameters are specified in §63.114 for process
 vents, §63.127 for transfer racks, and §63.143 for process
 wastewater, the report includes:

 (a)   A description of the parameter(s) to be monitored and an
      explanation of the criteria used to select the
      parameter(s);

 (b)  A description of the methods and procedures that will be
     used to demonstrate that the parameter indicates proper
     operation of the control device, the schedule for this
     demonstration, and a statement that the owner or
     operator will establish a range for the monitored
     parameter as part of the Notification of Compliance
     Statues report;

(c)   The frequency and content of and rationale for                Y D
     monitoring and  recording, if monitoring and recording is
     not continuous; and
 ND



 ND


 ND
                                                                                    ND
                                                                    YD
                                                                   YD
ND
ND
                                                                                    September 1997

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                  TABLE 11-2.  CHECKLIST FOR IMPLEMENTATION DATA
    (d)   The frequency and content of and rationale for reporting,
         if reporting of daily average monitoring parameter values
         being outside the acceptable range will not take place in
         the Periodic Reports required under §63.152(c).

6.  If alternative monitoring or recordkeeping is being requested,
    the information in checklist 11-6.
YD
YD
ND

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Volume II
          TABLE 11-3.  CHECKLIST FOR THE NOTIFICATION OF COMPLIANCE STATUS
 Complete this form for any source with emission points subject to the HON, A "yes" response to all
 questions will indicate compliance, and & "no* will Indicate noncomptiance except where noted  Any of
 the information required in the checklist that has already been submitted in the operating permit
 applcatfon does not need to be fesubmitted in the MCS,
 I.   GENERAL CONTENTS
 1.   The report contains results of emission point group
     determinations and performance tests including, as
     necessary:^
     (a)   At least one complete test report for each test method          YD            N D
           used for a particular kind of emission point where the
           complete test report includes:
           (1)   A brief process description,                            YD            N D
           (2)   A sampling site description,                            YD            N D
           (3)   A description of sampling and analysis procedures        YD            N D
                and any modifications to standard procedures,
           (4)   Quality assurance procedures,
           (5)   Records of operating conditions during the test,           YD            N D
           (6)   Records of preparation of standards,                     YD            N D
           (7)   Records of calibrations,                                YD            N D
           (8)   Raw data sheets for field sampling,                      YD            N D
           (9)   Raw data sheets for field and laboratory analyses,         YD            N D
                and
           (10)  Documentation of calculations; and                      YD            ND
     (b)    The results - but not necessarily the complete test report        YD            N D
           - for additional tests of other emission points tested by
           the same method.
2   The report contains the operating range of monitored                 YD            N D
     parameters established during performance tests.
3.   Where a parameter range and operating day is required to be
     established, the report includes:
     (a)    The specific range of the monitored parameter(s) for           YD            N D
           each emission point;
                                           11-123
                                                                                   September 1997

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          TABLE 11-3. CHECKLIST FOR THE NOTIFICATION OF COMPLIANCE STATUS
      (b)   The rationale for the specific range for each parameter         YD            N D
           for each emission point, including any data and
           calculations used to develop the range and a description
           of why the range indicates proper operation of the
           control device; and

      (c)   A definition of the source's operating day for purposes of       YD            N D
           determining daily average values of monitored
           parameters, specifying the times at which an operating
           day begins and ends.

  4.   If the provisions of § 63.110 allows the owner to choose which        YD            N D
      testing, monitoring, reporting and recordkeeping provisions will
      be followed, the report indicates which of the rule's
      requirements will be followed.                      *

  5.   For any Group 1 wastewater stream or any residual removed         YD            N D
      from a Group 1 wastewater stream transferred for treatment by
      another party pursuant to §63.132(g), the report includes the
      name and location of the transferee and a description of the
      Group 1 wastewater stream or residual.

  6.   When  a flare is used as a control device, the report contain the
      results of the flare compliance determination including:

      (a)    The flare design (i.e., steam-assisted, air-assisted, or          YD             N D
             non-assisted);

      (b)    All visible emission readings, heat content                     YD             N D
             determinations, flow rate measurements, and exit
             velocity determinations made during the compliance
             determinations; and

       (c)    All periods during the compliance determination when          YD             N D
             the pilot flame is absent.
                                               11-124                                    September 1997

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Volume II
 II.
 1.
2.
1.
2.
                                                                            Inspection Checklists
          TABLE 11-3. CHECKLIST FOR THE NOTIFICATION OF COMPLIANCE STATUS
     FOR STORAGE VESSELS EQUIPPED WITH A CLOSED-VENT SYSTEM AND CONTROL
     DEVICE AND FOR TRANSFER RACKS WHERE A DESIGN EVALUATION IS CONDUCTED

     The report contains a design evaluation of the control device
     and a description of the gas stream entering the control
     device.c'd'e
                                                                                 ND
                                                                                 ND
     (a)   If the control device is a thermal incinerator, the design        Y D
          evaluation includes the autoignition temperature of the
          organic HAP emission stream, the combustion
          temperature, and the residence time at the combustion
          temperature.0'"

     (b)   If the control device is a carbon adsorber, the design          Y D
          evaluation includes the affinity of the organic HAP
          vapors for carbon, the amount of carbon in each bed, the
          number of beds, the humidity of the feed gases, the
          temperature of the feed gases, the flow rate of the
          organic HAP emission stream, the desorption schedule,
          the regeneration stream pressure or temperature, and
          the flow rate of the regeneration stream. For vacuum
          desorption, pressure drop is included.

     (c)   If the control device is a condenser, the design               Y D
          evaluation includes the final temperature of the organic
          HAP vapors, the type of condenser, and the design flow
          rate of the organic HAP emission stream.
     For storage vessels, the documentation described in  (1)              YD
     demonstrates that the control device achieves 95-percent
     control efficiency during reasonably expected maximum
     loading conditions (or 90-percent efficiency if the control device
    was installed prior to December 31,1992). For transfer racks,
    the documentation described in  (1) demonstrates that the
    control device achieves 98-percent control efficiency during
    reasonably expected  maximum loading conditions.


III.  FOR STORAGE VESSELS AND TRANSFER RACKS WITH EMISSIONS ROUTED TO A FUEL
    GAS SYSTEM OR PROCESS
                                                                                ND
                                                                                ND
    For storage vessels with emissions routed to a process, the           Y D
    report contains a design evaluation or engineering assessment
    demonstrating the extent to which the emissions are recycled,
    consumed, transformed by chemical reaction into materials that
    are not HAP's, incorporated into a product and/or recovered.

    The report contains information that indicates the emission            Y D
    stream is routed to a fuel gas system or a process.
                                                                                ND
                                                                                ND
                                          11-125
                                                                                September 1997

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                                                                        Inspection Checklists
       TABLE 11-3. CHECKLIST FOR THE NOTIFICATION OF COMPLIANCE STATUS
                                                               YD
                                                               YD
              ND
              ND
IV.  FOR WASTEWATER STREAMS TREATMENT PROCESSES

1.   The report contains identification and description of the
    treatment process, identification of the wastewater streams
    treated by the process, and identification of monitoring
    parameters.
2.   The report contains records of a design evaluation and
    supporting documentation that includes operating
    characteristics or records of performance tests conducted
    using test methods and procedures specified in § 63.145 of
    subpart G.c
[Note- The information described in #2 above is not required if the wastewater stream or residual is
discharged to an underground injection well permitted under 40 CFR Part 270 or 40 CFR Part 144 and
complying with 40 CFR Part 122.]

3.  For each treatment process that receives a residual removed
    from a Group 1 wastewater stream, the report includes:
    (a)   Identification of treatment process;
    (b)   Identification and description of the residual;
    (c)   Identification of wastewater stream from which residual
         was removed;
    (d)   Fate of residual;
    (e)   Identification and description of control device (if any)
         used to destroy the HAP mass in the residual by
         99 percent; and
    (f)   Documentation of the 99 percent control efficiency of the
         device in (e).
YD

YD

YD


YD

YD



YD
                                                                               ND

                                                                               ND

                                                                               ND


                                                                               ND

                                                                               ND



                                                                               ND
V   FOR A BOILER OR PROCESS HEATER WITH A DESIGN HEAT INPUT CAPACITY GREATER
    THAN 44 MEGAWATTS, OR WITH A DESIGN HEAT INPUT CAPACITY LESS THAN
    44 MEGAWATTS WHERE THE VENT STREAM IS NOT INTRODUCED WITH THE PRIMARY
    FUEL.
1.  The report contains a description of the location at which the
    vent stream is introduced into the boiler or process heater.0
 YD
                                                                               ND
                                         . 11-126
                                                                                September 1997

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Volume II
         TABLE 11-3. CHECKLIST FOR THE NOTIFICATION OF COMPLIANCE STATUS
a Information may be included in the operating permit application




  des,gn evaluate documenting that the control device being
  efficiency as specified in §63.139(d)(2) for wastewater, §63 ;1
                          ^
                                                                              September 1997

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                                                                             Inspection Checklists
                     TABLE 11-4. CHECKLIST FOR PERIODIC REPORTS
Complete this form for any source with emission points subject to the HQN.  A "yes" response to all
Questions will indicate compliance, and a "no* will indicate noncompt.ar.ce except where noted,
                                                                    YD


                                                                    YD
               ND
               ND
1.   The report indicates periods when any monitored parameters
    were outside their established ranges.

2   The report contains the daily average values of monitored
    parameters for both excused and unexcused excursions, and for
    excursions caused by a lack of monitoring data, the duration of
    periods when monitoring data were not collected.

    [Note- Questions No. 1 and No. 2 do not apply to any storage vessel for which the owner or
    operator is not required by the applicable monitoring plan to keep continuous records.]
     If any performance tests or group determination are included in
     the report, the following information is provided:

     (a)   At least one complete test report for each test method
           used for a particular kind of emission point where the
           complete test report includes:

           1.   A brief process description,

           2.   A sampling site description,

           3.   A description of sampling and analysis procedures
                and any modifications to standard procedures,

           4.    Quality assurance procedures,

           5.    Records of operating conditions during the test,

           6.   Records of preparation of standards,

            7.   Records of calibrations,

            8.   Raw data sheets for field sampling,

            9.   Raw data sheets for field and laboratory analyses,
                 and
            10.   Documentation of calculations; and

       (b)   The results - but not necessarily the complete test report -
            for additional tests of other emission points tested by the
            same method.
YD
YD
                                                                                    ND
                                                                                    ND
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

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                                                                                 Inspection Checklists
                       TABLE 11-4.  CHECKLIST FOR PERIODIC REPORTS
  4.   For process vents, the report contains a description of process
      changes, results of the recalculation of group determination, and
      a statement that the owner or operator will comply with the rule  if
      the group status has changed and control is now required.
 5.
The report contains any needed supplements to the data
provided in the Implementation Plan or in operating permit
applications, as required by §63.151(1) and(j).
 6.   The report contains notification of any Group 2 emission point
      that has become a Group 1 emission point, including a
      compliance schedule.

 7.   For process wastewater streams transferred for treatment by
      another party in accordance with §63.132(g), the report includes
      changes in the identity of the treatment facility or the transferee if
      applicable.

 8.   The report contains information on the occurance of any control
      equipment, seal gap, or seal failure, including:

      (a)    Date of inspections;

     (b)    Identification of equipment (i.e., storage vessel,
           wastewater tank, surface inpoundment, seal, etc ) havinq
           the failure;

     (c)    Description of the failure;

     (d)    Description of the nature of the repair; and

     (e)    Date repair was made.

9.   The report contains times and durations of all periods recorded
     when the vent stream is diverted from the control device throuah
     a bypass line.

10.  The report contains all periods recorded in which the seal
     mechanism is broken, the bypass line valve position has
     changed, or the key to unlock the bypass line was checked out.

11.  The report  contains the times and durations of all periods
     recorded in which all pilot flames  of a flare were absent.

12.  If an extention to repairing or emptying a tank is utilized in
     accordance with § 63.120(b)(7)(ii), (b)(8), § 63.133(e)(2), or (h) of
     subpart G,  the report shall include the following:

     (a)    Identify the storage vessel or wastewater tank;
                                                                 YD
                                                                      YD
                                                                YD
                                                                YD

                                                                YD
                                                               YD
                                                               YD
                                                               YD
 ND
                                                                                ND
ND
ND

ND
YD
YD
YD
YD
ND
ND
ND
ND
                                                                               ND
                                                                                    ND
                                            11-129
                                                                                     September 1997

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                                                                       Inspection Checklists
                TABLE 11-4. CHECKLIST FOR PERIODIC REPORTS
(b)    An explanation of why it was unsafe to perform the
      inspection or seal or gap measurement or a description of
      the failure that cannot be repaired in 45 days;

(c)    Documentation that alternate storage capacity is
      unavailable;

(d)    A schedule of actions that will ensure the storage vessel or
      wastewater tank will be emptied as soon as practical.
YD



YD


YD
ND



ND


ND

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Volume II
•i
            TABLE 11-5.  CHECKLIST FOR A REQUEST OF COMPLIANCE EXTENSION
  Complete this form for any source, subject to the HON, that has requested an extension of compliance
  A "yes" response to all questions will indicate compliance, and a "no" will indicate noncompliance.
 Note:     Requests for extensions must be submitted no later than 120 days prior to the compliance
           dates specified in § 63.100(k)(2), §63.100(I)(4), and §63.100(m) of Subpart F, except as
           provided for in §63.151(a)(6)(iv).a
1.
2.




3.
The request contains a description of the controls to be installed
to comply with the standards.
The request contains a compliance schedule specifying dates by
which:
(a) Contracts for emission control systems or process
changes for emission control will be awarded;
(b) On-site construction, installation of emission control
equipment, or a process change is to be initiated;
(c) On-site construction, installation of emission control
equipment, or a process change is to be completed; and
(d) Final compliance will be achieved.
The request states whether the owner or operator is also
requesting an extension of other applicable requirements (e.g.,
performance testing).
YD
YD
YD
YD
YD
YD
YD
ND
ND
ND
ND
ND
ND
ND
a Requests must be submitted with the operating permit application, as part of the Initial Notification, or as
  a separate submittal.
                                            11-131
                                                                                   September 1997

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Volume II	Inspection Checklists


                TABLE 11-6. CHECKLIST FOR REQUEST TO USE ALTERNATIVE
                      MONITORING OR RECORDKEEPING PROCEDURES3
 Complete this form for any source requesting to use alternative monitoring or recordkeeping procedures]
 A "yes" response to all questions wilt indicate compliance, and a "no" will indicate noncompiiance.
  1.   If the source does not have an automated monitoring and             YD            N D
      recording system capable of measuring parameter values at
      least once every 15 minutes and generating continuous records,
      the request for a less frequent, non-automated monitoring
      system includes:

      (a)   Manual reading and recording of the value of the relevant       YD            N D
            operating parameter no less frequently than once per hour
            and calculation and recording of the daily average value
            from these measurements;

      (b)   A description of the planned monitoring and recordkeeping      YD            N D
            system;

      (c)   Documentation that the source does not have an              YD            N D
            automated monitoring and recording system;

      (d)   A justification for requesting an alternative monitoring and       YD            ND
            recordkeeping system; and

      (e)   A demonstration to the Administrator's satisfaction that the      YD            N D
            proposed monitoring frequency is sufficient to represent
            the control device operating conditions considering typical
            variability of the specific process and control device
            operating parameter being monitored.

  2.  If the source wishes to use an automated data compression          YD            N D
      recording system that does not  record monitored operating
      parameter values at a set frequency, but instead records all
      values that meet set criteria for  variation from previously
      recorded values, the request must address the systems ability to:

      (a)   Measure the operating parameter once every 15 minutes;      YD            N D

      (b)   Record at least 4 values  each hour during periods of          YD            N D
            operation;

      (c)   Record the date and time when monitors are turned on or      YD            N D
            off;

      (d)   Recognize unchanging data that may indicate the monitor      YD            N D
            is not functioning properly, alert the operator, and record
            the incident;
                                              H-132                                   September 1997

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Volume II
                TABLE 11-6. CHECKLIST FOR REQUEST TO USE ALTERNATIVE
                      MONITORING OR RECORDKEEPING PROCEDURES3
      (e)   Compute daily average values of the monitored operating
           parameter based on recorded data; and

      (f)    Retain all recorded data for that operating day if the daily
           average operating parameter value is an excursion.

 3.   In addition, the request for a system described in question 2
      above includes a description of the monitoring system and the
      data compression recording system, including the criteria used to
      determine which monitored values are recorded and retained, the
      method for calculating daily averages, and a demonstration that
      the system meets all the requirements outlined in questions 2(a)
      through 2(f) above.
YD


YD


YD
ND


ND


ND
a The information shall be submitted with the operating permit application or as otherwise specified by the
  permitting authority.                                                                     '
                                           11-133
                                                                                   September 1997

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                                                                            Inspection Checklists
     TABLE 11-7. CHECKLIST FOR START-UP, SHUTDOWN AND MALFUNCTION PLAN3
Complete this form for any source with emission points subject to the HON. A "yes" responseiqall    |
questions will indicate compliance, and a "no" will indicate noncompiiance.
1.  The Plan describes in detail the procedures for operating and
    maintaining the source during periods of startup, shutdown,
    and malfunction.

2.  The Plan defines a program of corrective action for
    malfunctioning process and air pollution control equipment
    used for compliance.

3.  The Plan identifies all routine or otherwise predictable
    continuous monitoring system malfunctions.

4.  The plan includes procedures for managing maintenance
    wastewater and specifies the following items:

     (a)   The process equipment and/or maintenance tasks that
           are expected to create wastewater during maintenance
           activities.

     (b)   The procedure for properly managing the wastewater
           and controlling HAP emissions to the atmosphere.

     (c)   The procedures for clearing materials from process
           equipment.
YD
YD
YD
YD



YD


YD
ND
ND
ND



ND


ND
a The plan must be submitted by the compliance date.
                                             11-134
                                                                                     September 1997

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Volume II
     TABLE 11-8. CHECKLIST FOR START-UP, SHUTDOWN AND MALFUNCTION REPORTS3
 Complete this form for any source with emission points subject to the HON, A wyes* response to all'
 questions will indicate compliance, and a "no* will indicate noncompliance.
  1.   A record of the occurrence and duration of each start-up,             YD           N D
      shutdown and malfunction of operation of air pollution control
      equipment or continuous monitoring systems used to comply
      with Subparts F, G or H during which excess emissions occur.
      (This record is not required to be submitted in the Start-up,
      Shutdown and Malfunction Report.

  2.   For each start-up, shutdown or malfunction during which
      excess emissions occur, the report indicates:

      (a)   That the procedures specified in the source's start-up,          YD           N D
           shutdown and malfunction plan were followed; and

      (b)   Any actions taken that are not consistent with the plan.         YD           ND

  3.   The report includes a letter stating the name, title, and                YD           N D
      signature of the responsible official certifying the report's
      accuracy.


a Reports of Start-up, shutdown and malfunction must be submitted semi-annually and may be included
  with the semiannual report.
                                            11-135
                                                                                    September 1997

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                                                                           Inspection Checklists
                                                                           •••••••••••

TABLE 11-9. CHECKLIST FOR INITIAL NOTIFICATIONS BY NEW OR RECONSTRUCTED MAJOR
                                   AFFECTED SOURCES
Complete this form to address the construction or reconstruction of major affected sources subject to
the HON. A "yes" response to all questions will indicate compliance, and a "no" will indicate
noncompliance.
1.   A notification contains a statement of intention to construct a          YD
    new major affected source, reconstruct a major affected
    source, or reconstruct a major source such that it becomes a
    major affected source.

2.   A notification indicates the date when construction or                YD
    reconstruction was commenced, submitted simultaneously with
    the permit application if it was commenced before the effective
    date of the relevant standard.

3.   A notification indicates the date when construction or                YD
    reconstruction was commenced, postmarked no later than
    30 days after such date if it was commenced after the effective
    date of the relevant standard.

4.   A notification indicates the actual date of startup postmarked          Y D
    within 15 days after that date.
                                                                                  ND
                                                                                  ND
                                                                                  ND
                                                                                  NO
                                            11-136
                                                                                    September 1997

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Volume II
                TABLE 11-10.  CHECKLIST FOR SOURCE CONSTRUCTION AND
                          RECONSTRUCTION PERMIT APPLICATIONS
 Complete this form to address the construction or reconstruction of sources subject to the HON. A
 "yes" response to all questions will indicate compliance, and a "no" will indicate noncomplFance except
 where noted.
 1.   The application contains the applicant's name and address.           YD             N D

 2.   The application contains a notification of intention to construct a
     new major affected source or make any physical or operational
     change to a major affected source.

 3.   The application notes the (proposed) physical location/address        YD             N D
     of the source.

 4.   The application identifies the relevant standard that is the basis        YD             N D
     of the application.

 5.   The application indicates the expected commencement date of        YD             N D
     the construction or reconstruction.

 6.   The application identifies the expected date of initial startup.           YD             N D

 7.   The application addresses the type and quantity of HAPs             YD             N D
     emitted by the source, reported in units and averaging times
     and in accordance with the test methods specified in the
     relevant standard, as well as operating parameters to the
     extent that they are used to demonstrate compliance.

 8.   For reconstructions only, the application contains a brief
     description of the affected source and the components to be
     replaced.

 9.   For reconstructions only, the application contains a description        YD             N D
     of present and proposed emission control system, including
     control efficiencies for each HAP.

 10. For reconstructions only, the application contains an estimate          YD             ND
     of the fixed capital cost of replacements and of constructing a
     comparable entirely new source unless the owner or operator
     declares that there are no economic or technical limitations to
     prevent compliance.

 11. For reconstructions only, the application contains the estimated        YD             N D
     life  of the affected source after the replacements unless the
     owner or operator declares that there are no economic or
     technical limitations to prevent compliance.
                                            11-137
                                                                                     September 1997

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Volume II   	Inspection Checklists
g^gg^^^giail^H^HBH^^^^HHHM^^^^HHM^^^^BHMMMH^BMHHMH^^MMMII^^^^MMHl

                TABLE 11-10. CHECKLIST FOR SOURCE CONSTRUCTION AND
                         RECONSTRUCTION PERMIT APPLICATIONS
 12. For reconstructions only, the application contains a discussion         YD           N D
     of any technical or economic limitations the source may have in
     complying with the applicable requirements unless the owner
     or operator declares that there are no economic or technical
     limitations to prevent compliance.
                                             MA O Q
                                             -IOO    ..'.,.      .                 September 1997

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                               APPENDICES
Appendix A:    Code of Federal Regulations Citations


Appendix B:    Comparison of HON Process Vent Provisions with Distillation, Air Oxidation and
              Reactors NSPS

Appendix C:    Example Calculation of TRE Index Value


Appendix D:    Information on Wastewater to be Submitted with Notification of Compliance
              Status

Appendix E:    Conversion Factors

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APPENDIX A
                                                                 Code of Federal Regulations Citations
       I.      Hazardous Organic NESHAP


              40 CFR 63 Subpart F - National Emission Standards for Organic Hazardous Air Pollutants
              from the Synthetic Organic Chemical Manufacturing Industry.


              40 CFR 63 Subpart G - National Emission Standards for Organic Hazardous Air
              Pollutants from Synthetic Organic Chemical Manufacturing Industry for Process Vents
              Storage Vessels, Transfer Operations, and Wastewater.


              40 CFR 63 Subpart H - National Emission Standards for Organic Hazardous Air
              Pollutants for Equipment Leaks.


       II.      NESHAP General Provisions


              40 CFR 63 Subpart A - General Provisions.


       III.      NSPS for SOCMI Process Vents


              40 CFR 60 Subpart III - Standards of Performance for Volatile Organic Compound
              Emissions (VOC) from the Synthetic Organic Chemical Manufacturing Industry (SOCMI)
              Air Oxidation Unit Processes.                                                  '


              40 CFR 60 Subpart NNN - Standards of Performance for Volatile Organic Compounds
              Emissions (VOC) from Synthetic Organic Chemical Manufacturing Industry (SOCMI)
              Distillation Operations.                                                     '


             40 CFR 60 Subpart RRR - Standards of Performance for Volatile Organic Compound
              Emissions from Synthetic Organic Chemical  Manufacturing Industry (SOCMI) Reactor
              Processes.


      IV.     Test Methods


             40 CFR 60 Appendix A, Method 1  - Sample and velocity traverses for stationary sources.



                                         1 A ' Sample and velocity traverses for stationary sources
             40 CFR 60 Appendix A, Method 2 - Determination of stack gas velocity and volumetric
             flow rate (Type S pilot tube).


             40 CFR 60 Appendix A, Method 2A - Direct measurement of gas volume through pipes
             and small ducts.
             40 CFR 60 Appendix A, Method 2.C - Determination of stack gas velocity and volumetric
             flow rate in small stacks or ducts (standard pilot tube).
                                                                                 September 1997

-------
                                                         Code of Federal Regulations Citations
                                                        I^^^^^««^™B^^BB^^^"^""^

      40 CFR 60 Appendix A, Method 2D - Measurement of gas volumetric flow rates in small
      pipes and ducts.

      40 CFR 60 Appendix A, Method 3B - Gas analysis for the determination of emission rate
      correction factor or excess air.

      40 CFR 60 Appendix A, Method 4 - Determination of moisture content in stack gases.

      40 CFR 60 Appendix A, Method 18 - Measurement of gaseous organic compound
      emissions by gas chromatography.

      40 CFR 60 Appendix A, Method 21 - Determination of volatile organic compounds leaks.

      40 CFR 60 Appendix A, Method 25A - Determination of total gaseous organic
      concentration using a flame ionization analyzer.

      40 CFR 60 Appendix A, Method 25D - Determination of the volatile organic concentration
      of waste samples.

      40 CFR 60 Appendix A, Method 26 - Determination of hydrogen chloride emissions from
      stationary sources.

      40 CFR 60 Appendix A, Method 26A - Determination of hydrogen halide and halogen
      emissions from stationary sources - isokinetic method.

      40 CFR 63 Appendix A, Method 301 - Field validation of emission concentrations from
      stationary sources.

      40 CFR 63 Appendix A, Method 304A - Determination of biodegradation rates of organic
       compounds (vent option).

       40 CFR 63 Appendix A, Method 304B - Determination of biodegradation rates of organic
       compounds (scrubber option).

       40 CFR 63 Appendix A, Method 305 - Measurement of emission potential of individual
       volatile organic compounds in waste.

V.     Procedures

       40 CFR 63 Appendix C - Determination of the fraction biodegraded (Fbj0) in a biological
       treatment unit.
                                          A-2                                September 1997

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APPENDIX B
    Comparison of Hon Process Vent Provisions
with Distillation, Air Oxidation, and Reactors NSPJ
                                       !    APPENDIX 6	f-is|
                           COMPARISON OF HON PRcfgESST
                            PROVISIONS WITH DIStlLfflllSR
       This Appendix summarizes the major differences between the HON process vent provisions and
       the SOCMI distillation, air oxidation, and reactors NSPS (40 CFR 60, Subparts NNN, 111, and
       RRR, respectively). The comparison is organized into the following sections: applicability; control
       techniques; performance testing; monitoring; and recordkeeping and reporting.
Applicability
              The three NSPS apply only to new sources. A new distillation facility is defined as a
              facility for which construction, modification, or reconstruction commenced after
              December 30, 1983. A new air oxidation facility is defined as a facility for which
              construction, modification, or reconstruction commenced after October 21, 1983. The
              date for reactors is June 29,1990.

              The NSPS apply to VOC's, while the HON applies to HAP's.

              The SOCMI chemical lists for the HON and the distillation, air oxidation, and reactor
              NSPS are different. The SOCMI list for the distillation, air oxidation, and NSPS can be
              found in 40 CFR §60.667, §60.617, and §60.707, respectively.

              The definition of a halogenated vent stream in the HON is any vent stream from a process
              vent or transfer operation determined to have a mass emission rate of halogen atoms
              contained in organic compounds of 0.45 kilograms per hour or greater. The NSPS define
              a halogenated vent stream as one containing a total concentration of halogen compounds
             . of 20 ppmv or greater.

              The TRE  equations and coefficients are different for the HON and the NSPS.  The
              coefficients in the NSPS are selected based on the flow rate, heat content, and halogen
              status of the vent stream.  The coefficients in the HON are based on the halogen status of
              the  vent stream and whether the facility is new or existing. The NSPS have separate
              equations for incinerators and flares. The TRE equations and coefficients for the air
              oxidation  NSPS are located in 40 CFR §60.614(e), and the TRE equations and
              coefficients for the distillation and reactors NSPS are located in 40 CFR §60.664(e), and
              §60.704, respectively.

              The NSPS do not use the terms Group 1 and Group 2. However, the NSPS have similar
              applicability criteria to HON, because they only require control of streams with TRE index
              values less than or equal to 1.0. The distillation NSPS has a low flow cutoff. The reactors
              NSPS includes low flow and low concentration  cutoffs.
                                                                                   September 1997

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                                                             Comparison of Hon Process Vent Provisions
APPENDIX B          	   with Distillation, Air Oxidation, and Reactors NSPS


Control Techniques
               In the NSPS, a scrubber is not required downstream of an incinerator that is used to
               combust halogenated vent streams (the NSPS only apply to VOC).

        .       The NSPS do not prohibit the use of flares for control of halogenated vent streams.

        •       There are no emissions averaging provisions in the NSPS.


Performance Testing

        .       The HON allows methods other than Method 18 to determine the concentration in the
               vent stream when complying with the 98 percent reduction or 20 ppmv outlet
               concentration requirements, or for purposes of calculating the TRE index value as long as
               the method has been validated by Method 301. The NSPS only specify Method 18.

               The distillation and air oxidation NSPS require Method 3 for measurement of percent
               oxygen when determining compliance with the 20 ppmv concentration limit. The reactors
               NSPS and the HON specify Method 3B.

               The  HON  and the reactors NSPS do not require an  initial performance test for boilers or
               process heaters when the vent stream is introduced with the primary fuel or for permitted
               hazardous waste boilers. The distillation and air oxidation NSPS do not contain these
               exclusions.

               The NSPS do not allow the determination of TRE index value parameters by engineering
               assessment. The HON provisions allow the determination of TRE index value parameters
               by engineering assessment if the TRE index value is greater than 4.0.

        .      There  are no initial tests required for scrubbers in the NSPS, because there are no
               scrubber provisions in the NSPS.

               The distillation and reactors NSPS require a performance test for all process vents with a
               TRE index value less than or equal to 8.0. The air oxidation NSPS and the HON require
               a test for all process vents with a TRE index value less than or equal to 4.0.
 Monitoring
                The distillation and air oxidation NSPS do not exempt boilers or process heaters where
                the vent stream is introduced with the primary fuel from the monitoring requirements. The
                HON and the reactors NSPS contain these exemptions. The HON also exempts
                permitted hazardous waste boilers from monitoring, unlike the NSPS.

                The distillation and air oxidation NSPS require monitoring of operation for boilers or
                process heaters with design heat input capacities of 44 megawatts or greater. The HON
                and the reactors NSPS do not require any monitoring of such boilers.
                                                                                      September 1997

-------
                                                               Comparison of Hon Process Vent Provisions
                                                           with Distillation. Air Oxidation, and Reactors NSP

                The distillation and reactors NSPS require monitoring for all process vent streams with a
                TRE index value less than or equal to 8.0. The air oxidation NSPS, like the HON
                requires monitoring for all process vent streams with a TRE index value less than or eaual
                to 4.0.                                                                       ^


 Recordkeepina and Reporting of Monitored Parameters


                The NSPS require semiannual reporting of monitored parameters that are outside the
                established range, but the out-of-range periods described in these reports are not
                considered violations.  The facility may be required to repeat the performance test, and if
                the test shows that the facility is no longer in compliance, enforcement action could be
                taken. However, violations and penalties  cannot be invoked based soley on monitored
                parameters being out of the established range. In contrast, the HON provisions specify
                that if parameters are out of range for a longer period of time than the excused excursion
                period, this is a direct violation of the permit operating requirements  and enforcement
                actions can be taken.

                The NSPS require three hour averaging periods for records  and reports of monitored
                data. The HON requires daily averaging periods (24 hour).

               The NSPS require performance tests to establish ranges of monitored parameters. The
                NSPS specifically define exceedances of monitored parameters which include limits
               above and/or below the performance test value of the parameter. For example, an
               exceedance for incinerators includes all 3  hour periods of operation during which the
               average combustion temperature was more than 28 °C below the value measured during
               the performance test.  In contrast, the HON does not contain specific definitions of
               acceptable ranges or exceedances. The HON requires sources to establish site specific
               ranges based on testing supplemented by engineering analyses.

               The distillation and air oxidation NSPS require records of operation for boilers or process
               heaters with design heat input capacities of 44 megawatts or greater to  be kept. These
               records may include steam use, fuel use, or data monitored to comply with another
               regulation. For the distillation and air oxidation NSPS, ail periods when  a boiler or
               process heater is not in operation must be reported in the semiannual report.

               The initial semiannual report is due within 6 months of the initial start-up date in order to
               comply with the NSPS. The HON requires the first semiannual report to be submitted no
               later than 8 months after the compliance date.

               The NSPS require that all records of monitored data be kept  for 2 years. The HON
               requires that records be kept for 5 years.


Recordkeepina and Reporting - Initial Reports and Notifications

               The HON requires the compliance option that will be used, be reported in the operating
               permit or as specified by the permitting authority and a Notification of Compliance Status
               to report the results of the initial performance test. The NSPS require a  notification of
               initial start-up and an initial performance test report.
                                                                                     September 1997

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                                                                            Comparison of Hon Process Vent Provisions
                                                                        with Distillation, Air Oxidation, and Reactors NSPS
                                                                       I^M^BI^^BB^MBMM"^""^^"^^"^™*™•

                            The NSPS require the results of the performance test to be submitted within 60 days of
                            achieving the maximum production rate, but no later than 180 days after start-up. The
                            HON requires the Notification of Compliance Status, which includes the results of the
                            performance test, to be submitted 150 days after the source's compliance date.

                            The NSPS require notification of the Administrator no later than 30 days after an affected
                            facility is constructed or reconstructed. The Administrator must also be notified no later
                            than 30 days prior to the initial start-up and no later than 15 days after the actual start-up
                            of an affected facility. The HON (§63.151 of Subpart G) requires an initial notification
                            which is due 120 days after the date of promulgation for existing sources. For new
                            sources, the initial notification is due as soon as practicable before commencement of
                            construction or reconstruction, or 90 days after promulgation, whichever is later.
                            Additional notification requirements for new sources subject to the HON (such as
                             applications for approval of construction or reconstruction and notifications of start-up) are
                             contained in the NESHAP General Provisions (40 CFR 63, Subpart A).

                             The distillation NSPS requires an initial report of the design production capacity of the
                             process unit.  The reactors NSPS requires a design capacity report for process units that
                             are exempt from control requirements because they are below the 1  Gg/year capacity
                             cutoff.

                             When making a process change, the NSPS require a report of the compliance option to
                             be used 90 days before the change is made if the compliance option will change.

                             When making a process change, the NSPS require a performance test to be done within
                             180 days of the change.
                                                                  B-4
                                                                                                      September 1997
L.

-------
                                                                                                          1
APPENDIX C
                                                                Example Calculation of TRE Index Value
       This Appendix summarizes the steps for calculating the TRE index value for a process vent
       stream and presents an example TRE index value calculation.  Detailed requirements for
       calculating the TRE index value for a process vent stream are presented in 563 115fcn in
       SubpartG of the proposed HON rule.                                     '      '

       The equation for calculating the TRE index value for a vent stream controlled by a flare or
       incinerator is as follows:
                                                                                         (D
       where:
          TRE
          EHAP
          QS

          HT
          ETOC

          a,b,c,d
                     TRE index value.
                     Hourly emission rate of total organic HAP (kilogram per hour).
                     Vent stream flow rate (standard cubic meters per minute) at a standard
                     temperature of 20 °C.
                     Vent stream net heating value (megaJoules per standard cubic meter)
                     Hourly emission rate of TOC (kilograms per hour minus methane and '
                     ethane).
                     Coefficients for existing and new source process vents presented in
                     Tables 1 and 2.

Engineering assessment may be used to determine the total organic HAP emission rate the
volumetric flow rate, the net heating value, and the TOC emission rate for the representative
operatma condition exacted to yield the lowest TRE index value.  Engineering assessment
               Previous test results;
          •     Bench-scale or pilot-scale test data;
               Permit values;  and
          •     Design analysis.

      If the calculated TRE index value is greater than 4.0, the owner or operator is not required to
      perform any measurements.  If the calculated TRE index value is less than or equal to 4 0
      measurements and/or further calculations of the volumetric flow rate, the net heating value, and
      the TOC and total organic HAP emission rates must be performed. The volumetric flow rate shall
      be determined using Method  2, 2A.2C, or 2D.  The molar composition, which is used to calcuLte
      net heating value, shall be determined using the following methods:

               Method 18 to measure the concentration of each organic compound-
               ASTM Method  D1946-77 to measure the carbon monoxide and hydroqen
               concentration; and
               Method 4 to determine the water vapor content.

      The net heating value shall be calculated using the following equation:
                                                                                  September 1997

-------
             HT =
             Cj Hj  (1  - Bws)
                                                         Example Calculation of TRE Index Value
                                                                                   (2)
where:
    HT
    Bws
    Cj
    Hj
Net heating value of the sample (megaJoule per standard cubic meter).
Constant, 1.740 x 10'7 (parts per million)-1 (gram-mole per standard cubic
meter) (megaJoule per kilocalorie).
Water vapor content of the vent stream, proportion by volume.
Concentration on a dry basis of all organic compounds j (parts per million).
Net heat of combustion  of compound j (kilocalorie per gram-mole).
The emission rate of TOG and the emission rate of total organic HAP shall both be calculated
using the following equation:
                      K2
                Cj Mj  Qs
                                                                                    (3)
                            1=1
 where:
     E
     K2

     Cj
     Mj
     Qs
 Emission rate of TOC or total organic HAP in the sample (kilograms per hour).
 Constant, 2.494 x 10"6 (parts per million)-1  (gram-mole per standard cubic
 meter)  (kilogram/gram) (minutes/hour).
 Concentration on a dry basis of organic compound j (parts per million).
 Molecular weight of organic compound j (gram/gram-mole).
 Vent stream flow rate (dry standard cubic meter per minute) at a temperature of
 20 °C.
                                            C-2
                                                                                September 1997

-------
C
APPENDIX C Example Calculation of TRE Index Value



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                                                                                                                               -SeptembeT1997~

-------

-------
APPENDIX D
                                    Information on Wastewater to be Submitted With Notification of Compliance Status
       This appendix contains copies of 4 tables (Tables 15, 17, 18, and 19) from Subpart G of the

                                  lnf°rmati°n ** ™St be SUbmitted With the Notification of
           D-1
           D-2


           D-3


           D-4
Information on Table 8 and/or Table 9 to be
Submitted with Notification of Compliance Status for
Process Units at New and/or Existing Sources

Information for Treatment Processes to be
Submitted with Notification of Compliance Status
Information for Waste Management Units to be
Submitted with Notification of Compliance Status

Information on Residuals to be Submitted with
Notification of Compliance Status
D-3


D-4


D-5
                                                                                    September 1997

-------
                               Information on Wastewater to be Submitted With Notification of Compliance Status
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-------
APPENDIX D
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                                                                                                              September 1997

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                                                                           \
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                                             September 1997

-------

-------
APPENDIX E
                                         APPENDIX E   • :|c||
                                  CONVERSION FACTORS
                           HON INSPECTION TOOL CONVERSION TABLE
        Numbers used in Process
        Vent Provisions
        Numbers used in Transfer
        Provisions
                                    Metric Units given in the Rule
                                   English Units
0.005 standard cubic meter
per minute (scmm)

0.45 kilogram per hour (kg/hr)

44 megawatts (MW)
650,000 liters per year (//yr)


10.3 kilopascals (kPa)


11.8 million liters/year (//yr)


0.45 kilogram per hour (kg/hr)

44 megawatts (MW)
0.18 standard cubic foot per
minute (scfm)

0.99 pound per hour (Ib/hr)
                                                               59,000 horsepower (hp)
                                                               150 million Btu per hour
                                                               (MMBtu/hr)
170,000 gallons per year
(gal/yr)

1.49 pounds per square inch
(psi)

3.12 million gallons per year
(gal/yr)

0.99 pound per hour (Ib/hr)
                                                               59,000 horsepower (hp)
                                                               150 million Btu per hour
                                                               (MMBtu/hr)
                                                                                September 1997

-------
APPENDIX E
                                                                               Conversion Factors
                         HON INSPECTION TOOL CONVERSION TABLE
                                      Metric Units given in the Rule
                                    English Units
         lumbers used in Storage
         v'essel Provisions
151 cubic meters (m3)

0.7 kilopascal (kPa)


38 cubic meters (m3)

13.1 kilopascals (kPa)


5.2 kilopascals (kPa)


75 cubic meters (m3)

21.2 square centimeters
(cm2) per meter of vessel
diameter

1.27 centimeters (cm)

61 centimeters (cm)

212 square centimeters (cm2)

3.81 centimeters (cm)

44 megawatts (MW)
39,900 gallons (gal)

0.1 pound per square inch
(psi)

10,000 gallons (gal)

1.90 pounds per square inch
(psi)

0.75 pound per square inch
(psi)

20,000 gallons (gal)

1.00 square inches (in2) per
foot of vessel diameter
                                                                   0.500 inch (in)

                                                                   24.0 inches (in)

                                                                   32.9 square inches (in2)

                                                                   1.50 inches (in)

                                                                   59,000 horsepower (hp)
                                                                   150 million Btu per hour
                                                                   (MMBtu/hr)
                                                   E-2
                                                                                       September 1997

-------
 APPENDIX E
                                                                                 Conversion Factors
                          HON INSPECTION TOOL CONVERSION TABLE
                                       Metric Units given in the Rule
                                     English Units
          Numbers used in Wastewater
          Provisions
5 meters (m)

0.04 kilogram (kg) steam per
liter (/) of wastewater

44 megawatts (MW)
                                       95 degrees Celsius (°C)

                                       67,100liters/hour/m2

                                       0.1 cubic meter (m3)

                                       0.42 cubic meter (m3)

                                       6.7 square centimeters per
                                       meter (cm2/m) of separator
                                       wall perimeter

                                       1.3 centimeters (cm)

                                       67 square centimeters per
                                       meter (cm2/m)

                                       3.8 centimeters (cm)	
16 feet (ft)

0.3 pound (Ib) steam per
gallon (gal) of wastewater

59,000 horsepower (hp)
150 million Btu per hour
(MMBtu/hr)

200 degrees Fahrenheit (°F)

1650 gallons/hour/ft2

26 gallons (gal)

110 gallons (gal)

0.32 square inch per foot
(in2/ft) of separator wall
perimeter

0.51 inch  (in)

3.2 square inches per foot
(in2/ft)

1.5 inches (in)
         Si/English Conversion Factors:

         1 meter (m) = 3.2808 feet (ft)
         2.54 centimeters (cm) = 1 inch (in)
         1 Iiter(/) = 0.2642 gallon (gal)
         1 cubic meter (m3) = 264.2 gallons (gal)
         1 kilopascal (kPa) = 0.1450 pound per square inch (psi)
         1 kilograms (kg) = 2.2046 pounds (Ib)
         1 megawatt (MW) = 1341 horsepower (hp) = 3.4122 million Btu/hr (MMBtu/hr)
*D.S. GOVERNMENT PRINTING OFFICE: 1997-615-640/90401
                                                   E-3
                                                                                       September 1997

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L

-------