United States        Office of Air Quality     EPA-340/1-90-001
            Environmental Protection   Planning and^ Standards   July 1990
            Agency           Washlnton, D.C. 20460

            Stationary Source Compliance Series
&EPA      Benzene Equipment
I           Leak  Inspection  Manual
                                          Printed on RecydedPaper

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                               DISCLAIMER

       This manual was prepared by Engineering-Science, Inc. for the Stationary
Source Compliance Division of the U.S. Environmental Protection Agency.  It has
been  completed in  accordance with  EPA  Contract  No.  68-02-4462,^ Work
Assignment No. 69. The contents of this report are reproduced herein as received
from the contractor. The opinions, findings, and conclusions expressed are those of
the authors and not necessarily those of the U.S. Environmental Protection Agency.
Any mention  of product names does not constitute endorsement by the U.S.
Environmental Protection Agency.

       The safety precautions set forth in this manual and presented at any training
or orientation session, seminar, or other presentation using this manual are general
in nature. The precise safety precautions required for any given situation depend
upon and must be tailored to the specific circumstances. Engineering-Science, Inc.
expressly disclaim any liability for any personal injuries, death, property damage, or
economic loss  arising  from any actions taken in reliance upon this manual  or any
training or orientation session, seminar, or other presentations based upon this
manual.
                                     11

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                           TABLE OF CONTENTS

1.   INTRODUCTION	« 1-1

2.   REGULATORY REQUIREMENTS	2-1
     2.1  Introduction	•	2-1
     2.2  Regulatory Requirements	2-2
          2.2.1   Applicability Determinations	2-2
          2.2.2   Exemptions	2-3
          2.2.3   Compliance Monitoring Requirements	2-4
                    2.2.3.1   Valves	2-5
                    2.2.3.2   Pumps	...»	 2-12
                    2.2.3.3   Compressors	2-14
                    2.2.3.4   Sampling Connections	2-14
                    2.2.3.5   Pressure Relief Devices and Connectors	2-14
                    2.2.3.6   Open-Ended Valves 	2-15
                    2.2.3.7   Product Accumulator Vessels	,	2-15
                    2.2.3.8   Closed-Vent Systems	2-15
                    2.2.3.9   Control Devices	2-16
          2.2.4   Alternatives for Emission Limitation	,	2-17
          2.2.5   Leak Repair and Records	2-17
                    2.2.5.1   Leak Repair	2-17
                    2.2.5.2   Leak Records	2-19
          2.2.6   Facility Reporting Requirements	2-21

3.  FUGITIVE BENZENE EMISSION SOURCES 	'.	3-1
     3.1  Process Valves	».»	- 3-1
          3.1.1   Gate Valves	3-2
          3.1.2   Globe Valves	 3-2
          3.13   Angle Valves	»• 3-5
                                       111

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          3.1.4   Diaphragm Valves	3-5
          3.1.5   BallValves	..	3-5
          3.1.6   Butterfly Valves	3-8
          3.1.7   Valve Seals and Leak Sources	3-8
     3.2  Pumps	3-12
          3.2.1   Centrifugal Pumps	3-12
          3.2.2   Reciprocating Pumps	3-12
          3.2.3   Rotary Pumps	3-14
          3.2.4   Canned Motor Pumps	3-14
          3.2.5   Pump Seals and Leak Sources	3-19
     3.3  Compressors	3-22
          3.3.1   Compressor Types	3-22
          3.3.2   Compressor Seals and Leak Sources	3-22
     3.4  Pressure Relief Devices	3-23
          3.4.1   Types of Pressure Relief Devices	3-23
          3.4.2   Emissions Sources	3-27
     3.5  Sampling Connections System	3-27
     3.6  Open-ended Valves and Lines	3-27
     3.7  Product Accumulator Vessels	3-28
     3.8  Flanges and Other Connectors	3-28
     3.9  Closed Vent Systems and Control Devices	3-29

4.   INSTRUMENTATION SELECTION AND OPERATION	4-1
     4.1  VOC Detectors	4-1
          4.1.1   Flame lonization Detector (FID)	4-4
          4.1.2   Photoionization Detector (PID)	4-4
          4.1.3   Nondispersive Infrared Detector (NDIR)	4-6
          4.1.4   Catalytic Combustion	4-7
     4.2  Selection of Instruments	4-7
          42.1   Detector Response and Selectivity	4-7
          4.2.2  Range and Accuracy	4-8
                                      IV

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         4.2.3  Ease-of-Use	..	4-8
         4.2.4  Safety	..4-8
     4.3   Instrument Calibration and Evaluation .,	 4-10
         43.1  Instrument Calibration Requirements
                and Procedures	4-10
         43.2  Field Span Check Procedures	 4-12
     4.4   Instrument Maintenance Programs and Records	 4-14
     4.5   Instrument Performance Checks	 4-15
         4.5.1  Leak Checks	:	.'	4-15
         4.5.2  Probe Condition	4-16
         4.53  Battery Pack Status Checks 	4-17
         4.5.4  Detector Condition	4-18
         4.5.5  Spare Parts and Supplies	 4-18
     4.6   Field Checks	i	4-19
         4.6.1  Instrument Zero	4-19
         4.6.2  Instrument Response	4-19
         4.6.3  Battery Condition	4-20
         4.6.4  Probe/Sampling Line Leakage	4-20
     4.7   Quality Assurance	4-21

5   PRE-INSPECnON	5-1
     5.1   Facility Background Information Review	5-1
         5.1.1  General Facility Background Information	5-2
         5.1.2  Inspection Reports	5-2
         5.13  Legal Records	 5-3
         5.1.4  Information Sources	5-3
         5.15  Review of Reports	5-4
     5.2   Development of the Inspection Plan	5-6
         52.1  Plant Records	5-6
         5.22,  Inspection Monitoring	5-6
     53   Notification	5-8

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     5.4   Monitoring Equipment	5-10
     5.5   Safety	5-11
     5.6   Reference Material 	5-11

6   INSPECTIONS	:	..	6-1
     6.1   Safety	6-1
     6.2   Inspector's Responsibilities	6-3
          6.2.1  Legal Responsibilities	6-3
          6.2.2  Procedural Responsibilities	6-4
     6.3   Facility Inspections ....;	6-4
          6.3.1  Entry	6-5
                   63.1.1   Arrival	6-5
                   6.3.1.2   Consent	6-5
          6.3.2  Initial Interview	6-5
          6.3.3  Evaluating the Facility Leak Monitoring
                Program	6-7
                   6.3.3.1   Observation of Calibration Procedures	6-7
                   6.3.3.2   Observing Leak Detection Monitoring by
                            Plant Personnel	6-8
                   6.3.3.3   Spot-Check by Inspector	6-10
          6.3.4  Record Inspections	6-15
          6.3.5  Closing Conference	6-23
7   POST INSPECTION	7-1
     7.1   Writing The Report	7-1
          7.1.1  Introduction	 7-2
          7.1.2  Compliance Status for Regulated Equipment	7-2
                   7.1.2.1   Individual Source Compliance Status	7-3
                   7.12.2   Exemptions	7-4
                   7.1.23   Alternative Standards	7-4
                   7.12.4   Leak Detection Procedures	7-4
                                       VI

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                  7.1.2.5  Reports and Recordkeeping	 7-5
         7.1.3  Data	'.	7-5
         7.1.4  Summary	7-5
    7.2  Handling Confidential Business Information	7-6
8  REFERENCES	..8-1
                                    Vll

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                               LIST OF FIGURES

FIGURE                                            .                      PAGE
3-1         Gate Valve	  3-3
3-2         Globe Valve with Packed Seal	  3-4
3-3         Diaphragm Valve	  3-6
3-4         Ball Valve	3-7
3-5         Butterfly Valve	  3-9
3-6         Simple Packed Seal	3-10
3-7         Sealed Bellows Valve	3-11
3-8         Two-Stage Pump with Double-Suction Impellers	3-13
3-9         Shriver Mechanically Actuated Diaphragm Pump	3-15
3-10        Moyno Single-Rotor Screw Pump with Elastomeric Lining	3-16
3-11        Gear-Type Rotary Pump Having Two Impellers	3-17
3-12        Seal-less Canned Motor Pump		,	;.. 3-18
3-13        Basic Single Mechanical Seal and Double Mechanical Seal	3-21
3-14        Liquid-Film Compressor Shaft Seal	3-24
3-15        Diagram of a Spring-Loaded Safety/Relief Valve	3-25
5-1         Benzene NESHAP Inspection Preparation Checklist for
                 Initial Reports	  5-5
5-2         Benzene NESHAP Inspection Preparation Checklist for
                 Semiannual Reports	  5-7
5-3         Monitoring Survey Log Sheet	  5-9
6-1         Facility Leak Monitoring Program Checklist	...;	6-11
6-2         Equipment and Leak Identification Checklist	6-13
6-3         In-Plant Records Checklist	.		6-16
6-4         Control Device Checklist	.		6-21
                                        V11I

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                               LIST OF TABLES


TABLE


2-1          Summary of Leak Detection Standards
                 and Equipment Standards	 2-6

4-1         " Performance Comparison of Four Major
                 VOC Detectors	 4-2

4-2          Most Common Portable VOC Detection
                 Instruments	4-5

4-3          Ease-of-Use of Organic Vapor Analyzers	 4-9
                                       DC

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                              1.0 INTRODUCTION

      The Environmental Protection Agency (EPA) established  regulations concerning
the monitoring of benzene fugitive emissions on June 6, 1984.  Promulgation of benzene
emission standards resulted  from  the  EPA determination that benzene presents  a
significant carcinogenic risk to human health and is therefore, a  hazardous pollutant as
defined in Section 112 of the Clean Air  Act.   The national standards  limit fugitive
emissions  of  benzene  from existing  and  new  petroleum  refining  and  chemical
manufacturing units. It covers equipment in these units that contain materials having a
benzene concentration of 10 percent or more by weight. Equipment which must conform
to the benzene standards includes:  valves,  pumps, compressors,  pressure relief devices,
sampling connection systems, open-ended valves or lines,  flanges, product accumulator
vessels, closed vent systems and control devices.

       The EPA  regional, state and local  compliance  inspectors are  charged with the
responsibility to determine the compliance of the regulated facilities with the standards. In
order to insure uniform enforcement of the  standard, guidance procedures must be
established and adopted. Recognizing this need, the EPA Stationary Source Compliance
Division has developed this manual .which compiles the needed procedures.

       This manual is intended  to provide basic guidance to enable the inspector to
systematically and  comprehensively gather  the  information and conduct the benzene
inspections  required to determine a facility's  compliance with  the benzene National
Emission Standards for Hazardous Pollutants (NESHAP) regulations.  The  manual is
divided into seven chapters including the introduction.  The second chapter covers the
benzene NESHAP regulations presented in 40 CFR 61 Subpart A,  J and V which establish
the legal premise for determining facility compliance.  The various types  of equipment
subject to the NESHAP regulations are described and the specific leak areas of each type
are covered in Chapter 3.  Chapter 4 presents the selection and  use of various Volatile
Organic Compound (VOC) leak detection equipment specified for determining compliance
as well as the calibration and maintenance procedures.  The preparation required for an
organized and efficient facility inspection is detailed in Chapter 5. Chapter 6  covers the
                                        l-l

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inspection procedures including the record review and leak detection monitoring.  The
post-inspection facility compliance  determination, reporting and confidential business
information procedures are presented in Chapter 7.
                                         1-2

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                                                      r\
                      2.0 REGULATORY REQUIREMENTS

2.1   INTRODUCTION

      On January 5, 1981, the Environmental  Protection Agency (EPA) proposed the
national emission standard for fugitive benzene emissions (46 FR 1165) under authority of
Section 112 of the Clean  Air Act.  The purpose of the standard is to reduce benzene
emissions from fugitive emission sources. Fugitive emissions of benzene can be reduced  by
two types of control techniques: (1) leak detection and repair programs, and (2) equipment
design and operational specifications. The leak  detection and repair programs consist  of
monitoring potential  fugitive benzene emission sources with the approved portable VOC
detection instruments and then repairing or replacing any source determined to be leaking.
The repairs or replacement must be completed within a specified time after discovery
depending on the source,  and the ability to make repairs without a process shutdown.
Fugitive benzene emissions could also be reduced by installing certain control equipment.
For  example,  fugitive emission from pumps occur primarily at the pump seal.  These
emissions could be reduced by installing the following equipment: sealless pumps,  pumps
with dual mechanical seals, or closed vent systems and control devices for collection and
removal  or destruction of emissions.  However,  because of process condition limitations,
installation of control equipment is not suitable for all pump applications. Therefore, the
standard requires a combination of monthly monitoring and the installation of specific
control equipment to provide the greatest level of control for fugitive benzene emissions.

      This chapter describes the regulatory requirements,  applicability determinations,
exemptions, compliance monitoring methods, alternate test methods, waivers, leak  repair,
recordkeeping and  reporting procedures stipulated  by the fugitive benzene  emission
regulations. A thorough understanding of the fugitive benzene emission regulation is a
prerequisite before the inspector can begin an inspection.  The objective of this chapter is
to assist  the inspector in acquiring this  understanding by providing an explanation of the
regulations.
                                       2-1

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2.2   REGULATORY REQUIREMENTS

      Benzene emissions are regulated by the National Emission Standards for Hazardous
Air Pollutants (NESHAP) found in Title 40 Part 61 of the Code of Federal Regulations
(CFR), Subparts A, J, and V.  Subpart A gives the general provision of the  regulations.
Subpart J outlines the specific standards for benzene equipment leaks, and requires that
affected sources must meet the general requirements of Subpart V. Subpart  V covers in
detail all of the compliance regulations for equipment leaks.  Subpart V is generic, or
common, to all volatile hazardous air pollutants (VHAP) that have been or will be made
subject to Subpart V.

2.2.1  Applicability  Determinations

      It is important to understand exactly what types of facilities may be subject to the
benzene NESHAP,  since any potential  subject facility which claims exemption from the
benzene standard is  required to keep records which document that the exemption is valid
(40 CFR 61.110 (c)  (1) and 40 CFR 61.246 (i)). Presented below is a list of some of the
types of facilities are potentially subject to the benzene NESHAP.

(1)   Benzene Sulfonic Acid Production

(2)   Benzene and/or Toluene and/or Xylene Production

(3)   Chlorobenzene Production

(4)   Cumene Production

(5)   Cyclohexane Production

(6)   Ethanol Production where benzene is used as an azeotropic distillation solvent

(7)   Ethylbenzene Production

(8)   Hydroquinone Production

(9)   Linear Alkylbenzene Production

(10)  Maleic Anhydride Production
                                      2-2

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(11)  Nitrobenzene Production

(12)  Petroleum Refineries

(13)  Pipeline Companies and Storage Terminals

(14)  Polymer Production where benzene is used as a solvent

(15)  Resorcinol Production

(16)  Styrene Production

(17)  Phenylsilicone Production

      The standard covers new and existing valves, pumps, compressors, pressure relief
devices, sampling  connection  systems, open-ended  valves or  lines,  flanges and  other
connectors, product accumulator vessels,  and control  devices or systems used to comply
with the standard.  To be covered by the regulations, the equipment must be "in benzene
service" i.e., it must contain or contact a fluid (liquid or gas) with a benzene concentration
of 10 percent or more by weight. All equipment "in benzene service" must be identified or
marked in a permanent manner easily distinguishable for leak monitoring purposes.  The
two most common methods for marking  or  identifing subject equipment are tagging or
painting.

2.2.2 Exemptions

      Facilities are exempt from Subparts J and V requirements if:

      o      plant site is designed to produce or use less than  1000 Megagrams of benzene
             per year (1,100 tons per year).
      o      faculty processes, through  equipment,  liquid  or gaseous streams which
             contain less than 10 weight percent benzene.
      o      Sources located  in coke by-product plants  (these sources are covered by
             other regulations).

      In regards  to  the  first exemption, EPA selected a  minimum cut-off of 1,000
Megagrams per year or the equivalent of 1,100 tons per year per plant site based on the
                                       2-3

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benzene design production or usage rate.  EPA interprets "produce or use" to include
throughput.  Throughput is determined by a mass balance made during the design stages of
the process operations and incorporates the accumulation of all benzene processed in one
year.

      The regulations  which govern the second exemption stipulate that each piece of
equipment within a process unit that can conceivably contain equipment in benzene service
is presumed to be in benzene service unless an owner or operator demonstrates that the
piece of equipment is  not  in benzene  service.  In order to  determine that  a piece of
equipment is not in benzene service, it must be determined that the  percent benzene
content can be reasonably expected never to exceed 10 percent by weight.  To demonstrate
that the percent benzene content does not exceed 10 percent  by weight,  the owner or
operator must use the  methods described in ASTM Method D-2267.   Alternatively,  if
agreed upon by the Administrator, the owner or operator may use engineering judgement
provided it clearly demonstrates the benzene content doesn't exceed 10 percent by weight.

Additional exemptions are allowed for:

      o     Storage Tanks - regulations do not apply to tank breathing loss, however,
             associated pumps, valves and connectors may be subject.
      o     Welded fittings - no number or identification is required, however, if a leak is
             detected, it must be corrected.
      o     Vacuum  Service  -  regulations only  apply to  equipment  continuously
             operating at an internal pressure which is at least 5 kilopascals (20 inches of
             water) below ambient pressure, or at a minimum gauge vacuum of 20 inches
             of water (1.48 inches  of mercury).

2.2.3  Compliance Monitoring Requirements

      The benzene NESHAP emission standards require that fugitive emissions sources
be monitored at  specific schedules and  after every leak repair to determine compliance.
Reference Method  21, in  the New  Source  Performance Standards, 40 CFR Part 60,
Appendix A, was designated by the EPA as the acceptable technical method to determine
benzene leak from these sources. Method 21 stipulates the specifications and performance
                                      2-4

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requirements which the portable VOC monitors must meet. There are several instruments
available on the market that may be used for compliance monitoring. Chapter 4 covers the
advantages and disadvantages of the different types.

      The benzene standards places specific limits on fugitive emissions from valves,
pumps,  compressors,  pressure-relief devices, sampling connection systems,  open-ended
valves or  lines, flanges  and other connectors, product accumulator vessels  and control
devices  or systems.  Two control  techniques are employed by the standard to achieve
reduction of benzene fugitive emissions. The first control method is a leak detection and
repair program in which fugitive source leaks are located and repaired at regular intervals.
The second control method is a preventative program in which potential fugitive sources
are eliminated by either retrofitting with specified controls or replacement with leakless
equipment.   Specific monitoring or control  equipment requirements for the equipment
items subject to  the  benzene standard are described in  the following paragraphs.   A
summary of these requirements is presented in Table 2.1.

2.2.3.1 Valves

      Valves in gas or liquid service must be monitored monthly in compliance with the
leak detection and  repair program.  A leak is described as a reading of 10,000 ppm  or
greater of benzene material. Any valve found not to be leaking for two consecutive months
may switch to quarterly monitoring.  If a leak is detected, the valve  shall be monitored
monthly until a leak is not detected for two consecutive months.

      Valves must be monitored monthly to detect leaks unless:

      o     the valve is designated as a difficult-to-monitor valve
      o     the valve is designated as an unsafe-to-monitor valve
      o     the valve is designated for no detectable emissions
                                       2-5

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      Valves  designated as difficult to monitor are those which require elevating the
monitoring personnel more than two  meters above any permanent available support
surface.  Valves that cannot be safely monitored by the use of step ladders  are also
classified as difficult to monitor. For valves designated as difficult to monitor, an annual
leak detection and repair program must be developed and followed.  The description of
this program must be kept in a readily accessible location.

      Valves defined as unsafe to monitor are those that could, as demonstrated by the
owner or operator,  expose monitoring personnel to imminent hazards from temperature,
pressure, or explosive process conditions. For valves designated as unsafe to monitor, an
owner or operator is required to develop and follow a plan that defines a leak detection
and repair program conforming with the routine monitoring requirements  of the  standard
as much as possible, with the understanding that monitoring should not occur during unsafe
conditions.  There should be very few valves in benzene service that are unsafe to monitor.

      Valves  designated for no  detectable  emission  must comply  with the following
equipment standards:

      o      Have no external actuating mechanism in contact with the process fluid
     • o      Be operated with emissions less than 500 ppm
      o      Leak tested initially upon designation and annually

      The benzene NESHAP standard allows alternatives to the valve standard described
above. The owner  or operator may elect to choose one of two alternative standards for
valves in gas/vapor and liquid service.   Both of these alternatives  require one year of
monthly monitoring to obtain data on which to base the alternative standard. An  owner or
operator selecting to comply with the provisions of either of these options  must notify the
Administrator 90 days before implementing the option.

      The first alternative standard specifies that the percentage of leaking valves must be
two percent or less within a process unit, as determined by the initial performance test and
a minimum  of one performance test annually thereafter.  This alternative  may be met by
implementing any type  of  monitoring program and engineering controls chosen at the
discretion of the owner or operator. Whenever the percentage of valves leaking is greater
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than two percent, the process unit is in violation.  If at any time, the owners or operators
decide they no longer wish to comply with this alternative, they must submit a written
notice to EPA accepting compliance with the monthly/quarterly leak detection and repair
programs.

      The second alternative standard specifies two skip period leak detection and repair
programs.  Under this alternative option, an owner or operator after notifying EPA, can
skip from monthly/quarterly monitoring to a  less frequent monitoring schedule,  after
completing a specified number of consecutive monitoring intervals with the percentage of
valves leaking equal to or less  than two percent.  Under the first program, the owner or
operator may skip to semiannual monitoring after two consecutive quarterly periods with
fewer than two percent of valves leaking.  Under the second program, the owner or
operator may skip to annual monitoring after 5 consecutive quarterly periods with fewer
than two percent of valves  leaking.  However, the owner or operator may not  adopt
semiannual monitoring and then proceed directly to annual monitoring by claiming one
period of semiannual monitoring substitutes for two quarterly leak detection and repair. If
the owner or operator exceeds the two percent level, the  monthly/quarterly leak detection
and repair program must be reinstated. However, if EPA determines that the two percent
level is exceeded, an evaluation of compliance should occur.

2.2.3.2 Pumps

      Pumps are required to comply with the monthly leak detection and repair program,
where any leak emission over 10,000 ppm is defined as a leak. They must also be visually
inspected weekly  for any liquid drips. However, any pump which is located within the
boundary of an unmanned plant site is exempt from the weekly visual pump seal inspection
requirements  [40 CFR 61.242-2(a)(2)  and (d)(2)] and the daily sensor  inspection
requirements [40 CFR 61.242-2(d)(5)(i)] as long as each pump is visually inspected as often
as practicable and at least monthly.

      Alternatively, pumps  may  comply with  the NESHAP standard by  meeting the
equipment specifications standards. To comply with the equipment standard, pumps must
be equipped with  dual mechanical seals and  a barrier fluid system as specified in 40 CFR
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61.242-2  (d) or designated for no detectable emission or equipped with a closed-vent
system.

      To be in compliance with  the dual mechanical seal and barrier fluid system the
following five contingencies must be satisfied.

1)    Each mechanical seal must:
             (a)    be operated with the barrier fluid at a pressure that is at all times
                   greater than the pump stuffing box pressure;
                          -or-
             (b)    be equipped with a barrier fluid degassing reservoir that is connected
                   by a closed-vent system to a control device that complies with the
                   requirements of 40 CFR 61.242-11;
                          -or-
             (c)    be equipped with a system that purges the barrier fluid into a process
                   stream with zero VHAP emission to atmosphere.
2)    The barrier fluid must not be in VHAP service.

3)    Each barrier fluid system must be equipped with a sensor that will detect failure of
      the seal system, the barrier fluid system or both.

4)    Each pump must be visually inspected for leaks dripping from the pump seal.

5)    Each sensor  must be checked daily or equipped with an audible alarm.  A leak is
      detected if there are indications of liquids dripping from the pump seal or the sensor
      indicates failure of the seal system the barrier fluid system or both.

Pumps must be monitored monthly unless:

      o      the pump is equipped with a dual mechanical seal system
      o      the pump is designated for no detectable emission
      o      the  pump is equipped with a closed-vent system capable of capturing and
             transporting any leakage from the seal or seals to a control  device  that
             complies with the requirements.
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2.2.3.3 Compressors

       Compressors are required by 40 CFR 61.242-3 to be equipped with a seal system
that includes a barrier fluid system and  that prevents leakage of process fluid to the
atmosphere.  The barrier fluid system must be  equipped with a sensor that will detect
failure of the seal or barrier fluid system.  Sensors must be checked daily or have an alarm.
If the sensor detects a failure, a leak is discovered.  Compressors are to be tested annually
unless equipped with  a closed-vent system  capable  of capturing and  transporting any
leakage from the seal to a control device that complies with the applicable requirements.
However, it should be noted that compressors are rarely "in benzene service" because pure
benzene is not easily compressed.

2.2.3.4 Sampling Connections

       Sampling connection systems allow analysis of feedstock, intermediate or product
streams  to test product quality and process unit operation.   To obtain representative
samples for the analysis, sampling lines are generally purged first.  If this flushing purge is
not returned to the process, it  could release benzene to the atmosphere. The standard
requires sampling connection systems be equipped with either a closed purge system which
eliminates emissions due to purging by returning  the purge material directly to the process
or a closed-vent system which collects any emissions released and vents them to a control
device.

2.2.3.5 Pressure Relief Devices and Connectors

       Pressure relief devices, in liquid service flanges and other connectors are excluded
from routine leak detection and repair  requirements.   However, if  any evidence  of a
potential leak is discovered by visual, audible, olfactory or any other detection method, (in
inspector vernacular, that means seen, heard, smelled or otherwise detected) these devices
must be monitored for  leaks within 5 calendar days. If a leak is detected, the facility  must
make the first attempt at repair within 5 calendar days and must complete the repairs
within 15 calendar days.

       Pressure relief devices in gas or vapor service shall be operated in accordance with
the no detectable emission standard (<500ppm).  As an alternative, compliance may be
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achieved by use of a closed-vent system capable of capturing and transporting leakage from
the pressure relief device to a control device, such as a flare.  The standard does not apply
to the emissions discharged to relieve overpressurized systems.  Pressure relief devices in
gas or vapor service shall be monitored within 5 days of a pressure release to confirm that
the device is operating in accordance with the no detectable emission standard (<500ppm).

2.2.3.6  Open-Ended Valves

      Open-ended valves or lines shall be equipped with a cap, blind flange, plug, or a
second valve which shall seal the open end at all times except during operations requiring
process fluid flow through the  open-ended valve or line. If a second valve is used, the
standard requires the upstream valve to be closed first.  This will prevent trapping process
fluid between the two valves.

      When a double block and bleed system is used, the bleed valve or line may only
remain open during operations  that require venting the line between the block valves.  At
all other times, the double block and bleed system  must remain sealed except during
operations requiring process flow through the bleed valve or line.

2.2.3.7 Product Accumulator Vessels

      Product Accumulator vessels shall be equipped with a closed-vent system capable of
effectively capturing and transporting any leakage from the vessel to control device.

2.2.3.8 Closed - Vent Systems

      Closed-vent systems shall be operated with no detectable emission and  annually
monitored to confirm a less than 500 ppm instrument reading.  The standard also requires
that closed-vent systems be checked visually to ensure there are no leaks  in the piping or
ducts.
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2.2.3.9 Control Devices

      Vapor recovery systems such as condensers and adsorbers must be designed and
operated to recover the organic vapors vented to them with an efficiency of 95 percent or
greater. Enclosed combustion devices, such as thermal incinerators, catalytic incinerators,
boilers, or process heaters must be designed and operated to destroy benzene emissions
vented to them  with  an efficiency of 95 percent or greater or  to provide a minimum
residence time of 0.50 seconds at a minimum temperature of 760°C.

      As  an alternative, the  use of smokeless flares are  allowed  provided they are
designed and operated according to the following requirements:

      o     Must be designed and operated with no visible emissions as determined by
            Reference Method 22, except for a total of 5 minutes in any 2-hour period.
      o     Must be operated with a flame present at all times. The flame's presence can
            be  ensured by monitoring  the flare's pilot light with the  appropriate heat
            sensor such as a thermocouple, an infrared monitor  or any other equivalent
            device.
      o     Only steam-assisted, air-assisted or non-assisted flares may be used to comply
            with the regulation. The net heating valve of the gas being combusted must
            be at least 300 BTU/scf for steam-assisted or air-assisted flares, and at least
            200 BTU/scf for non-assisted flares.
      o     Steam-assisted and non-assisted flares must be designed for and operated
            with an exit velocity less than 60 ft/sec, except that higher exit velocities are
            permitted for gases having net heating values greater than 300 BTU/scf. A
            maximum exist velocity of 400 ft/sec is allowed when the net heating  value of
            the gas exceeds 1,000 BTU/scf.
      o     For air-assisted flares, the maximum permitted velocity increases as the net
            heating  value  of the  gas  being  combusted  increases.   The  maximum
            permitted velocity is 54.5 ft/sec at the minimum allowable heating value of
            300 BTU/scf, and 115.2 ft/sec at a heating value of 1,000 BTU/scf.
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2.2.4  Alternatives for Emission Limitation

      The owner or operator may apply for permission to use an alternative means of
emission limitation under Section 112(e)(3) of the Clean Air Act.  The alternative means of
emission limitation may be an equipment standard, a design standard, an operational basis
standard,  a work  practice  standard  or  a unique  approach to  demonstrate emission
limitation.  Approval of an alternative means of emission limitation constitutes a standard
setting.  For this reason, only the  Emission Standards Division of U.S.  EPA has the
authority to grant such approvals.

      Each source  for  which the  Administrator  grants  permission, must achieve  a,
reduction at least equivalent to the emission reduction attained by the required controls.  If
the emission limitation is achieved by means of an equipment standard, design standard or
operational requirement, permission may be  granted  on the condition that  certain
operation and maintenance requirements are met to assure  continued compliance. If the
emission limitation is achieved by  means of  a work  practice standard, each source
requesting permission  must demonstrate for a minimum period of 12 months  that the
emission reduction is achieved. Permission may be granted on the condition that certain
operation and maintenance requirements are met to assure continued compliance.  The
owner or operator may also offer a unique approach to demonstrate any alternative means
of emission limitation.  Additionally, the  manufacturers of equipment used to control
equipment leaks of a VHAP may request permission for an  alternative means of emission
limitation.

2.2.5  Leak Repair and Records.

2.2.5.1 Leak Repair

      The regulations specify what initial repair action is to be taken.  For valves, fugitive
leaks often occur at the valve stem packing gland. The first attempt at repair may consist
of:

      o     tightening bonnet bolts
      o     replacement of bonnet bolts
      o     tightening of packing gland nuts
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  _ ~   o     injection of lubricant into lubricated packing
       o     others

       The first attempt at repair for pressure relief devices in liquid service, flanges and
other connections includes the same practices as mentioned for valves.

       According to the regulations, the first attempt at repair must be initiated within five
calender days after discovering the leak.  The leak repairs must be completed, that is, the
equipment must achieve the previous emission limit standard (i.e. less than 10,000 ppm or
less than 500 ppm above background reading) within 15 calendar days.

       Delay of repair is allowed when the repair is technically  or physically infeasible
without a process unit shutdown.  For example, if a leaking valve cannot be isolated from
the process stream and requires complete replacement or replacement of multiple internal
parts, the valve  repairs can be  delayed until the next process unit  shut-down.  Delay of
repair will also be allowed if the leaking source is isolated from the process and does not
contain or contact benzene in concentrations greater than 10 percent.  Delay of repair for
valves is allowed when:

       1)     the emissions of purged material resulting from immediate repair are greater
             than the fugitive emissions likely to result from a delay of repair,
                          -  AND  -
       2)     at the  time of repair, benzene  emissions are collected and destroyed or
             vented to control devices which comply with the requirements for closed-vent
             systems and control devices.

       In addition, delay of repair beyond a process shutdown will be allowed for valves
when unforeseeable  circumstances deplete  the supply of valves used for repair, provided
that these supplies were sufficiently stocked before the ensuing depletion occurred.  A
delay of repair beyond the next process unit shutdown will not be allowed unless the next
shutdown occurs before 6 months have elapsed after the first process unit shutdown.
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      Delay of repair for pumps is allowed if:

      1)    repair requires the use of a dual mechanical seal system that includes a
            barrier fluid system;
                          - AND -
      2)    repair is completed as soon as practical, but not later than 6 months after the
            leak is detected.

2.2.5.2 Leak Records

      The standards require recording of specific information pertaining to  the monthly
monitoring. When a leak is detected the following information shall be recorded in a log
and shall be kept for 2 years:

      o     Identification numbers of leaking equipment, detection instrument used, and
            operator who found the leak.
      o     Dates of leak detected,  each attempt to  repair the leak,  process  unit
            shutdowns while unrepaired, and successful repair.
      o     "Repair delayed" if the leak was not repaired within 15 calendar days after
            discovery, the reasons for unsuccessful repair and the date of anticipated
            successful repair.
      o     Repair methods used.
      o     "Above 10,000  ppm" if the maximum instrument reading after each repair
            attempt is above 10,000 ppm.
      o     Signature of owner/operator who decided to delay repair until the process
            shutdown.

      Each source  found to  be  leaking  must be identified with  a readily  visible
weatherproof identification bearing the source identification number.  For valves, the
identification may be removed only after the source has been repaired, monitored for leaks
for the next two successive months and no leaks detected during those two months.  For all
other equipment, the identification may be removed after repair.
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2.2.6  Recordkeeping Requirements

      The rationale  for recordkeeping is  to  document  information about  the  use  of
specific equipment and  the results of the leak  detection  and repair programs  for
determining compliance with the standard.  Recordkeeping requirements are designed to
require the minimum level of industrial effort necessary to ensure effective implementation
of the standard. The general equipment records to be recorded in a log are to include a list
of identification numbers  for  all equipment  (except  welded  fittings) subject  to the
standards. For all equipment under the no detectable emissions designation (less than 500
ppm above background reading) the information recorded in the log must  include:

      o      List of identification numbers of pumps, compressors and valves subject and
             the signature of the owner or operator.
      o      List of identification numbers of pressure relief devices in gas/vapor service
      o      Records of compliance tests for  pumps, compressors, valves and pressure
             relief devices  which include  the  date, background reading and maximum
             instrument reading measured at the equipment.

      The following information pertaining to valves shall be recorded for:

      o      Valves designated  as  unsafe  to  monitor  -  the  identification number, an
             explanation stating why the valve is  unsafe to  monitor and the plan for
             monitoring each valve.
      o      Valves designated  as difficult to monitor - the identification number, an
             explanation stating why the valve is difficult to  monitor and a  monitoring
             schedule for each valve.
      o      Valves complying with skip period leak, detection. - The monitoring schedule
             and the percentage of leaking valves per period.

      The following information shall be recorded for closed-vent systems and control
devices:

      o      Detailed schematics, design specifications and piping and instrumentation
             diagrams,
      o      Dates and description of any changes in the design specifications,
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      o     Description and rationale of parameters monitored to ensure proper control
            device operation and maintenance,
      o     Periods when the closed vent systems and control device were not operated
            as designed,
      o     Periods when the pilot light did not have flame (flares),
      o     Dates of start-up and shut-downs of the systems.

      The following information shall be recorded for each pump and  compressor with
dual mechanical seals and barrier fluid systems:

      o     The design criteria and an explanation of the design criteria.
      o     Any changes to this criteria and the reasons for any changes.

      Facilities claiming exemptions from the benzene standards must maintain records of
the following information in a log:

      o     Analysis of design capacity of process unit
      o     Analysis of equipment that is not in VHAP service
      o     Information and data to demonstrate that a piece of equipment is not "in
            benzene service."

2.2.6 Facility Reporting Requirements

      Regulations require facilities to submit two types of reports to regulatory agencies.
The first is an initial report and the second is a series of semiannual reports. The facility
must submit an initial report within 90 days of the effective date for existing sources or new
sources having an initial startup date which precedes the effective date. For new sources,
the initial report must be submitted with the application for approval of construction.

      Receipt  of the initial report is essential  for ensuring  compliance with  the
regulations. The initial report must include a statement that the general requirements of
the benzene NESHAP   standards,  testing,  recordkeeping  and  reporting  are  being
implemented.   The owner or operator of each existing or new  source  (i.e., building,
structure, facility, installation or piece of equipment which emits or may emit benzene)
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which  has an initial  startup date preceding the effective date,  must also include  the
following information in the initial report to be submitted within 90 days after the effective
date as required under 40 CFR 61.10(a) of the NESHAP general provisions:

       o     Name and address of the owner or operator
       o     The location of the source
       o     The type of hazardous pollutants emitted by the stationary source
       o     A brief description of the nature, size, design and method of operation of the
             stationary source including its design capacity and identifying each point of
             emission for each hazardous pollutant
       o     The average weight per month of the hazardous materials being processed by
             the source, over the last 12 months preceding the date of the report.
       o     A description of the existing control equipment which includes each control
             device  for each hazardous pollutant and the estimated  control efficiency
             (percent) of each control device.
       o     A statement by the owner or operator as to whether the source can comply
             with the standards within 90 days after the effective date.

       In the case of new sources which did not have an initial start up date preceding the
effective date, the initial report must specify equipment identification numbers and process
unit identification, equipment types, percent by weight benzene contained in the equipment
fluid, state of the process fluid (vapor or liquid) and the method of compliance with  the
standards (monthly leak detection or equipped with dual mechanical seals) for each piece
of equipment or stationary source (i.e.,  building, structure, facility or installation) which
emits or may emit benzene.  The initial report must be submitted with the application for
approval of construction.

       Semiannual reports contain some of the data necessary for determining substantive
compliance with the benzene  NESHAP standards however, the  rest of such data and
procedural compliance can only  be determined by inspection.  Semiannual reports of all
pump, valve and compressor leaks detected and the leak repair efforts within a process unit
are required.   Leaks must be  reported for  each month of  the reporting period,  and
separately for valves, pumps and compressors.  The  report must  include the number of
leaks occurring during the reporting period, the number of leaks  not repaired within 15
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days, an explanation of the delay of repair and the reasons why process shutdowns were
infeasible. The semiannual report must contain the results of all performance tests used to
determine compliance with the no detectable emissions standard  and the alternative
standards  for  valves i.e.,  two percent annual leakage or  skip period leak monitoring
requirements.   Also the  report must include dates  of  process shutdowns during the
reporting period and any revisions to the initial report.

      The semiannual  reporting  schedule  should be  included  in the initial report.
Although not specifically required, it is desirable that the schedule also report the months
of monitoring  included in each semiannual report.  Ideally  no more than 30 days should
elapse between the end of a monitoring period and the report submission.  All  future
semiannual reports must be submitted  according to the schedule unless a revised schedule
is submitted.

      The  regulations  specify additional   reporting  requirements for  changes  or
modifications.  For example,  if the owner or operator decides to meet the  provisions of
alternative standards for  valves, the  Administrator must be notified 90 days  prior to
execution of the  new standards.   Also, an  application  for approval of construction or
modifications must be submitted unless the new source complies with the standards, the
new sources are not part of the construction of a process unit, and all of the information is
submitted in the next semiannual report.
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                 3.0 FUGITIVE BENZENE EMISSION SOURCES

      The purpose of this section is to identify major sources of fugitive benzene emissions
which are subject to the NESHAP regulations and to explain the control devices and leak
detection or prevention programs which are required to reduce or control these emissions.
Typically found in petroleum refining and chemical manufacturing units, the regulated
sources include; pumps, compressors, valves, sampling lines,  open-ended valves, pressure
relief valves,  flanges and other connectors, product  accumulator  vessels, closed vent
systems and control devices.  The sources include equipment which develop leaks due to
failure of seals and, if left uncontrolled, would emit benzene to the atmosphere; equipment
which emits benzene during upset or intermittent  operational conditions; as well as
equipment which fails to adequately capture, recycle, recover or destroy benzene pollution.
Although additional equipment may emit benzene pollutants, the Agency promulgated
regulations for only the aforementioned sources which  are deemed to  pose the most
significant risks to public health.

      In order to control fugitive benzene emissions, the benzene NESHAP regulations
require'a combination leak detection and repair program  and a preventive program. The
leak detection and repair program seeks to limit fugitive  benzene  emissions from
equipment sources by requiring frequent leak detection monitoring.  This program focuses
monitoring efforts on detecting leaks from equipment seals and other sources. Once the
leak is located, repair or replacement is performed to eliminate the leak, thereby reducing
fugitive benzene emissions.  The preventive program seeks to prevent and thus eliminate
fugitive benzene sources.  Benzene  emissions are eliminated by retrofitting or replacing
leak sources  with  leakless  equipment.   In other applications,  benzene  emissions  are
prevented from entering the atmosphere by requiring enclosure systems for leak areas and
destruction or removal of captured emissions by control devices.

3.1   PROCESS VALVES

      One of the most common pieces  of equipment in a refinery or  organic chemical
production unit is the valve.  Individually, process valves have a low emission rate, but
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because of the large number of valves typically used in a production unit, as a group they
usually constitute the largest source of fugitive VOC emissions.

       There are several types of valves, such as globe, gate, plug, ball, and check valves.
These valves can be grouped into three functional categories:

       o      Block which are used for on/off control.
       o      Control which are used for flow rate control.
       o      Check which are used for directional control. Since these valves do not have
             stems (and therefore a potential leak area), they will not be covered in this
             manual.

The following paragraphs are intended to familiarize the inspector with the principal types
of valves, describe their operating mechanisms and identify potential leak sources.

3.1.1   Gate Valves

       Gate valves (Figure 3-1) are used to minimize  pressure drop in the open position
and to stop the flow of fluid rather than to regulate it.  Gate valves are  designed in two
types:  inclined-seat  and parallel seat. The wedge-shaped gate, inclined-seat type is most
commonly used. The wedge gate is usually solid but may be flexible (partly cut into halves
by a plane at right angles to the pipe), or split (completely cleft by such a plane). Flexible
and split wedges minimize galling (seizure at point of contact) of the sealing surfaces by
distorting more easily to match angularly misaligned seats. In the double-disk, parallel-seat
type, an inclined plane device mounted between the  disks converts stem force to axial
force, pressing the disks against the seats, after the disks are positioned for closing.  This
gate assembly distorts automatically to match both angular misalignment of the seats and
longitudinal shrinkage of the valve body on cooling.

3.1.2   Globe Valves

       Globe valves  (Figure 3-2) are a type of block  valve whose name arises from the
shape of the body.  They are designed as either inside-screw rising stem or outside-screw
rising stem. Small valves generally are of  the inside-screw type, while in larger sizes the
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GATE VALVE
 FIGURE 3-1
      3-3

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  Handwheel
 Stem
    Packing Nut
Disk
Body
                                  Packing
                                  Bonnet
                                   Seat
      GLOBE VALVE WITH PACKED SEAL
                 FIGURE 3-2
                     3-4

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outside-screw type is preferred. In most designs the disks are free to rotate on the stems;
this prevents galling between the disk and the seat. Globe valves are preferably installed
with the higher-pressure side connected to the top of the disk.  Exceptions are (1) where
blocked flow caused by separation of the disk from the stem would damage equipment, or
(2) where the valve is installed in seldom-used vertical drain lines in which accumulation of
rust, scale, or sludge might prevent opening the valve.

3.1.3   Angle Valves

       Angle valves are similar to globe valves; the same bonnet, stem, and disk are used
for both.  They combine an elbow fitting and a globe valve into one component with a
substantial saving in pressure drop.  Flanged angle valves are easier to remove and replace
than flanged globe valves.

3.1.4   Diaphragm Valves

       Diaphragm valves (Figure 3-3) are control valves which limit flow by manipulating a
flexible diaphragm.  The process fluid is separated from the  valve stem by  a flexible
diaphragm so that the potential for leakage around the stem is eliminated.  The fabric-
reinforced diaphragms may be made from natural rubber, from a synthetic rubber, or from
natural or synthetic rubbers faced with Teflon®. The simple shape of the body makes lining
it economical.  Plastic bodies, which have low moduli of elasticity compared with metals,
are practical in diaphragm valves  since  alignment  and distortion are minor  problems.
Diaphragm  valves have excellent  corrosion resistance  characteristics but  are limited to
pressures of approximately 50 psig.

3.1.5  Ball Valves

       Ball valves (Figure 3-4) as the name suggests, use a spherical element to block flow.
Since the sealing element is a ball, its alignment with the axis of the stem is not essential to
tight shutoff. In free-ball valves the ball is free to move axially. Pressure differential across
the valve forces the ball in the closed position against the downstream seat and the latter
against the body. In fixed-ball valves, the ball rotates on stem extensions, with the bearings
sealed with  O-rings.

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               Handwheel
               Plunger
                 Flexible
                 diaphragm
                   Saddle
                   shaped
                   seat
DIAPHRAGM VALVE
    FIGURE 3-3
        3-6

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Potential
 leak area
        BALL VALVE
         FIGURE 3-4
              3-7

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3.1.6   Butterfly Valves

       A butterfly valve (Figure 3-5) is a block valve which is essentially a flat circular plate
that presses against a seal in the closed position and is held iii place by fluid pressure.  In
the open position, the plate (which may be rounded somewhat for hydro-dynamic reasons)
is parallel to the direction of flow. They occupy less space in the line than any other valves.
Relatively tight sealing without excessive operating torque and seat wear is accomplished
by a variety of methods, such as resilient seats, piston rings on the disk, and inclining the
stem to limit contact between the portions of disk closest to the stem and the body seat to a
few degrees of curvature.

3.1.7   Valve Seals and Leak Sources

       Generally, the seal around the valve stem is a potential leak source on a valve.  The
most common type of valve stem seal is the packed seal (Figure 3-6), where a specialized
packing material (lubricated braided asbestos, graphite, graphite-impregnated fibers,  or
Teflon® is inserted into the area around the valve  stem, and then compressed by a packing
gland to form  a tight seal.  The packing material used depends upon the valve application
and configuration. At high pressures these glands must be quite  tight to achieve a good
seal. As the packing wears or lubricant loss occurs, the packing gland must be tightened to
in order to provide a tight seal.

       Elastomeric O-rings are also used for sealing process valves. These O-rings provide
a good seal, but are  not suitable where there is sliding motion through the packing gland,
and are rarely used in high  pressure service.  Operating temperatures are limited by the O-
ring material.

       Bellows seals  (Figure 3-7) are more effective for preventing process fluid leaks  than
are conventional packing  glands or  any other gland-seal  arrangements.   This  seal
incorporates a formed metal bellows that makes a  barrier between the disc and body
bonnet joint. The bellows is the weak point of the system and its service life can be quite
variable. Consequently, the bellows seal is usually backed up with a conventional packing
gland and often fitted with a leak detector in case the seal fails.
                                         3-8

-------
                     Potential
                     leak area
                          Disk
BUTTERFLY VALVE
    FIGURE 3-5
        3-9

-------
   Pump stuffing box
Fluid
end
                                  ^Packing gland
_^_\_J^-^	3~Seal face
                                  ^ Possible leak
                                 ~      area
              Packing
              SIMPLE PACKED SEAL'
                   FIGURE 3-6
                        3-10

-------
             Stem
                   Yoke
                      Bellows
SEALED BELLOWS VALVE
      FIGURE 3-7
          3-11

-------
       Specialized valve designs can isolate both the working parts of the valve and the
environment from the process liquid. This may be done with a diaphragm seal or a weir
seal.  The weir seal's diaphragm may also be used to control the flow of the process fluid.
In this design, a compressor component pushes the diaphragm toward the valve bottom,
throttling the flow.  The diaphragm and compressor are connected so that it is impossible
for them to be separated under normal working conditions. When the diaphragm reaches
the valve bottom,  it seats firmly,  forming a leak-proof seal.   This configuration is
recommended for fluids containing solid particles and for medium-pressure  service.  A
valve using a diaphragm seal can become a source  of fugitive emissions if that seal fails.

3.2    PUMPS

       Because pumps are used extensively in the  refining and organic chemical industries
for moving  organic fluid  they are also a major potential  benzene emission source.
Centrifugal pumps are used most often in these industries, although positive-displacement
pumps, reciprocating, rotary  action  pumps,  and  the  specialized  canned  and diaphragm
pumps are used for some applications. The following sections describe the principal pump
types,  their  operating mechanisms,  and  the  pump  seal,  the component  most  often
responsible for fugitive emissions from pumps.

3.2.1   Centrifugal Pumps

       A centrifugal pump (Figure 3-8), in its simplest form, consists of an impeller rotating
within a casing.  The impeller consists of a number of blades, either open or shrouded,
mounted on a shaft that projects outside the  casing.  Impellers  may have their axis of
rotation either horizontal or vertical, to suit the  work to be done. Closed-type or shrouded
impellers are generally most  efficient.  Open-  or semi-open-type impellers are used for
viscous liquids or liquids containing solid materials and on many small pumps for general
service. Impellers may be  of the single-suction type (if the liquid enters from one side) or
double-suction type (if it enters from both sides).

3.2.2   Reciprocating Pumps

       There are three classes of reciprocating pumps; piston pumps, plunger pumps, and
diaphragm pumps. In general, the action of the liquid-transferring parts of these pumps is
                                        3-12

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the same, a cylindrical piston, plunger, bucket, or round diaphragm being caused to pass or
flex back  and forth  in a  chamber.  The  device is equipped with valves for Met  and
discharge of the liquid being pumped, and the operation of these valves is related in a
definite manner to the motions of the piston. Diaphragm pumps (Figure 3-9) are a special
case of reciprocating pumps. Their construction differs in that the reciprocating driving
member  is a  flexible  diaphragm  fabricated of metal, rubber, or  plastic.   The chief
advantage of this arrangement over other reciprocating pumps is the elimination of all
packing and seals exposed to the liquid pumped.

3.2.3   Rotary Pumps

       In rotary pumps (Figure 3-10) mechanical displacement of the liquid is produced by
rotation of one or more members within a stationary housing.  Because internal clearances
are small, these pumps will only  handle  liquid  that does not contain grit  or abrasive
material. When two or more impellers are  used in a rotary-pump casing, the impellers will
take the form of toothed-gear wheels as in  Figure 3-11, of helical gears, or of lobed cams.
In either case, these  impellers rotate with  extremely small clearance between each other
and between the surface of the impeller and the casing.  Referring to Figure 3-11, the two
toothed impellers rotate as  indicated by the arrows.  The suction connection is at the
bottom. As the spaces between the teeth of the impeller pass the suction opening, liquid is
impounded between  them, carried  around  the casing to the discharge opening, and then
forced out through this opening. The arrows indicate this flow of liquid.

3.2.4   Canned Motor Pumps

       The canned-motor  pump  (Figure 3-12) commands considerable attention in the
chemical industry.  These units are close-coupled designs in which the cavity housing the
motor rotor and the pump casing are interconnected. As a result, the motor bearings run
in the process liquid and all seals are eliminated. Because the process liquid is the bearing
lubricant, abrasive solids cannot be  tolerated. Canned-motor pumps are being widely used
for handling organic solvents, organic heat-transfer  liquids, and light oils,  as well as many
clean toxic or hazardous liquids, or where leakage is an economic problem.
                                        3-14

-------
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GEAR-TYPE ROTARY PUMP HAVING TWO IMPELLERS1
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                       3-17

-------
       Discharge
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Suction
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Bearings
                   SEAL-LESS CANNED MOTOR PUMP
                              FIGURE 3-12
                                   3-18

-------
3.2.5  Pump Seals and Leak Sources

      The major source of fugitive benzene emissions from pumps (except for canned and
diaphragm types) is the pump shaft seal.  The rotating pump shaft requires a seal to isolate
the pump's interior fluid  from the  atmosphere.   When in operation, rotating shafts in
pumps are usually displaced by amounts that very depending on the loads transmitted,
therefore, their seals must  be very flexible.  Shaft lengths normally limited by such items as
critical speed and allowable deflection require that seals be compact.  The combination of
flexibility, compactness and tightness can be difficult to achieve and maintain.  The two
most common seals used are packed and mechanical seals.  The following, description of
the different  types of seals is intended to provide the inspector an understanding of the
impact of seal design on fugitive emission potential.

      The most common  type of rotating shaft seal is the packed seal which consists of
packing composed of fibers which are first woven, twisted, or braided into strands, and then
formed into coils, spirals,  or rings.   The packed seal can be used on reciprocating and
rotary pumps. The packing material  is compressed into a cavity or stuffing box forming a
seal around the moving shaft,  A packing gland is used to apply compression necessary to
form a  tight  seal. Common packing materials are  asbestos fabric, braided arid twisted
asbestos, rubber and duck, flax, jute, and metallic braids.  The so-called plastic packings
can be made with varying amounts of fiber combined with a binder and lubricant for high-
speed applications.  Each of these materials has a maximum temperature beyond which it
may not be used, therefore, packed seals require lubrication to prevent frictional heat
buildup between the seal and shaft.

      To ensure initial lubrication and to facilitate installation, the basic packing materials
are often  impregnated with  a lubricant.   An effective means of renewing packing
lubrication is to provide a lubricating lantern ring.  The ring provides an opening for the
forced feeding of oil, grease, sealed  or secondary medium into the packing set, giving a
constant supply  of lubricant.  This method is particularly effective on pumps handling
volatile liquids and for the exclusion of solids from the sealing faces. Lantern rings are also
employed for cooling, to provide an additional seal against leakage of liquid being pumped,
and to prevent infiltration of air through the stuffing box on the pump suction side.  In
                                         3-19

-------
 packed seals where no lantern ring is used, a small amount of leakage through the packing
 is essential for lubrication of the seal.
       The chief advantage of packing over other types of seals is the ease with which it can
be adjusted  or replaced.  Most equipment is designed so  that disassembly of major
components is not required to remove or add packing rings.  The major disadvantages of a
packing-type seal are the necessity for frequent adjustment and the quantity of fluid flow
required to lubricate it

       Mechanical seals are the most prominent seals used in industry.  Mechanical seals
may be classified as either single or double.  Single mechanical seals (Figure 3-13), prevent
leakage by  means of two sealing rings,  one stationary and  one rotating.  In a single
mechanical seal, the surfaces or faces where the rotating primary ring and the stationary
ring make contact are polished or precision finished to a very high degree of flatness  in
order to maintain contact over their entire surface, thereby creating a seal.  The seal
formed by the sealing faces is perpendicular to the shaft rather than parallel to it as in the
packed seal.  Single mechanical seals,  like packed seals require lubrication  to decrease
frictional heat buildup. The lubricant used is often the pumped liquid or other fluids which
are compatible with the fluid being pumped. Singe mechanical seals may develop leaks
when the two sealing surfaces are damaged so that they no longer form a complete seal.

       Dual mechanical seals are more effective than single mechanical seals in preventing
leaks.  Dual mechanical seals may be arranged back-to-back or hi tandem.  In the back-to-
back arrangement, a closed cavity is formed between the two seal  faces.  The barrier fluid
between the two seals is circulated through the cavity to lubricate  and cool the seals.  The
barrier fluid must be maintained at a pressure greater than the pump stuffing box pressure
in order  for the seal to function  properly.   Hence, due to the pressure difference, any
leakage occurring between the seals would be limited to the barrier fluid escaping into the
process fluid. As long as the seals are operating properly, the barrier fluid will prevent the
process fluid from contacting the environment and releasing benzene.

      In the tandem dual mechanical seal  arrangement, both seals are facing the same
direction.  The inner seal is located in the stuffing box housing. A barrier fluid, used for
lubrication is maintained at a lower pressure than that of the pump stuffing box pressure.
Leakage will occur from the pump stuffing box into the seal cavity containing the barrier
         •; "••  ••/•••>."••••': '•"-'. •:-•:••' •  -  •       3-20

-------
                   Gland gasket
 Pump stuffing box
    Fluid
    end
                 Spring'
 Shaft  \  Seal face
packing \
              _.  ^ GSand ring
               ^.Insert packing

                  Stationary
                  ' element

               '!-- Possible
                 —\  leak .
                   \  area
       BASIC SINGLE MECHANICAL SEAL
  Possbte teak into
    seahig fluid
                Sealng-fiquid
                  i Met
         Sealng-liquid
             outtet
Fluid end-
      Outer seal assembly
            Inner seal assembly
           DOUBLE MECHANICAL SEAL'
                    FIGURE 3-13
                         3-21

-------
fluid. To ensure that no benzene leaks occur, the barrier fluid system must be connected to
a closed vent  system which vents the emissions  to a control device  (i.e., enclosed
combustion or vapor recovery).

      Mechanical seals of all types find their best applications where fluids must be
contained under substantial pressures. In such services, advantages of mechanical seals, as
compared with conventional packed  stuffing  boxes, are  reduced  friction-power loss,
elimination of wear on shaft or shaft sleeve, negligible leakage over a long service life, and
freedom from periodic maintenance.  On the other hand, mechanical seals are precision
components and demand special handling and installation.

3.3    COMPRESSORS

      Compressors are basically pumps that are used in gas service.  Compressors, like
pumps, can be both centrifugal and positive displacement types.  They also have  a shaft
that requires  a seal to isolate the compressor interior gas from the atmosphere. As with
pumps, the possibility of a leak through this seal makes it a potential  source of benzene
emissions.

3.3.1  Compressor Types

      Compressors may  be of two types, centrifugal and rotary.  The  principle of  a
centrifugal compressor is the same as that of a centrifugal pump, the main difference being
that the gas handled in the compressor is compressible while the liquids handled in a pump
are practically  incompressible.   Rotary compressors, blowers and vacuum pumps are
machines of the positive  displacement type.  Such units are essentially constant-volume
machines with variable discharge pressure. Volume can be varied only by changing the
speed or by by-passing or washing some of the capacity of the compressor.

3.3.2  Compressor Seals and Leak Sources

      Fugitive  benzene  emissions from compressors result,  for the most part, from an
imperfect seal  between  the rotating shaft and the compressor  housing.  To prevent
emissions, compressor seal systems  may be built with all the seals described for pumps.
                                        3-22

-------
Mechanical contact seals for compressors are similar to the mechanical seals described for
pump applications.  Mechanical contact seals reduce the  clearance between the rotating
and stationary components to essentially zero. Oil or another suitable lubricant is applied
to the seal faces.  Barrier fluid reservoir degassing vents must be controlled with a closed-
vent and control device system as described for pumps. Sometimes a barrier gas may be
used to form  a buffer between the compressed gas and the atmosphere.  This system
requires a clean external gas  supply that is compatible with the gas being compressed.
Contaminated barrier  gas  must be  disposed  of properly.   The control  efficiency for
mechanical contact seals depends on the efficiency of the control device and the frequency
of seal failures.

      In addition to having seal types like those  used for  pumps, centrifugal compressors
can be equipped with a liquid-film seal as shown in Figure 3-14.  The seal is a film of oil
that flows between the rotating shaft and the stationary gland.  This seal is generally not
subject to fugitive emissions at the seal itself, but the oil that leaves the compressor from
the pressurized system side is under the system internal gas pressure and is contaminated
with the benzene pollutant.  When this contaminated oil is  returned  to the  open oil
reservoir, process gas and entrained benzene can be released to  atmosphere. To eliminate
release of emissions from the seal oil system, the reservoir must  be enclosed and vented to
a control device.

3.4   PRESSURE RELIEF DEVICES

      Safety/relief valves  are designed to  release a product  material  from distillation
columns, pressure vessels,  reactors, and other pressurized systems during emergency or
upset conditions.   Release of material containing benzene makes this equipment an
emission source.  The frequency and duration of releases, however, are dependent on the
operating conditions of the particular plant, and wide operational variations between plants
can occur.

3.4.1 Types of Pressure Relief Devices

      Safety/relief valves  are required by engineering codes for applications where the
pressure on a vessel or a system may exceed the maximum design level.  A spring-loaded
safety/relief valve, which is shown in Figure 3-15,  is typically used for this service. The seal
is a flat disk held in place  on a seat by a spring during  normal system operation.  But,
                                         3-23

-------
                          Oil in from reservoir
Inner bushing
 Internal gas
  pressure

                                  x-Outer bushing
             Contaminated   Oil out
              oil out to
              reservoir
Atmosphere
             LIQUID-FILM COMPRESSOR SHAFT SEAL
                          FIGURE 3-14
                              3-24

-------
  Seat
                 Process side
                                Spring
                                 Nozzle
DIAGRAM OF A SPRING-LOADED SAFETY/RELIEF VALVE
                   FIGURE 3-15
                        3-25

-------
internal pressure build up will raise the disk, thereby breaking the seal and compressing the
spring. Once the pressure is relieved, the disk will reseat.

       Rupture disks are also commonly used on process units.  These disks can be used in
combination with or in place of pressure relief valves.  For instance, a rupture disk can be
installed upstream of a relief valve in order to prevent fugitive emissions through the relief-
valve seat. Under normal conditions, the rupture disk seals the system tightly. But if its set
pressure is  exceeded,  it will break and the relief valve will  relieve the pressure.   This
procedure may require the use of a larger size relief valve because of operating codes.
Since it is possible that the disk may rupture, the disk/valve combination may also require
appropriate piping changes to prevent disk fragments from lodging in the valve, which
would  keep it from being reseated properly. A block valve upstream of the rupture disk
may be required hi order to permit in-service replacement of the disk after rupture. If the
disk were not replaced,  the first overpressure would result in the relief valve being the
same as  an  uncontrolled relief valve and it might actually be worse since disk fragments
may prevent proper reseating of the relief valve.  In some plants, installation of a block
valve upstream of a pressure relief device is common practice.  In others, it is forbidden by
operating or safety procedures. Tandem pressure relief devices with a three-way valve can
be used to prevent operation without relief protection if block valves are not allowed.

       In rupture-disk/relief-valve combinations, some provision for testing the integrity of
the disk is necessary. Pressure should not be allowed to build up in the pocket between the
disk and the relief valve; otherwise, the disk will not function properly. The pocket must be
connected to a pressure indicator, recorder, or alarm.  If  the process fluid is not hazardous
or toxic, a  simple bubbler apparatus can be  used to test the integrity  of the disk by
connecting the bubbler to the pocket. The control efficiency of the disk/valve combination
is assumed  to be 100  percent  for fugitive emissions  resulting from improper seating or
relief valve simmering. The control efficiency would be lowered if the disk integrity were
not maintained or if the disk were not replaced after rupture; The disk/valve combination
has no effect on emissions resulting from overpressure relieving.
                                         3-26

-------
3.4.2  Emissions Sources                .  ..

      Sealing problems constitute the largest percentage of fugitive benzene emissions
from pressure relief devices in service.  Leaks through the seal on a pressure relief device
may be caused by three reasons:  (1) simmering or popping, (2) improper reseating of the
valve after a relieving operation or (3) corrosion or degradation of the valve seat. Leaks
caused by simmering occur when the operating pressure is similar to the set pressure of the
valve.  Leaks caused by popping occur when the operating pressure does exceed the set
pressure, however, only for an extremely short period.

      The advantage of a rupture disk is that it seals tightly and does not allow benzene to
escape from the system under normal operation. However, when the disk does rupture, the
system depressurizes until atmospheric conditions are  obtained.  This could result in an
excessive  loss of product or a corresponding excessive release  of fugitive emissions.  To
provide control for both overpressure occurrences and any leakage that may occur, the
rupture disk and relief valve may be vented to a control device such as a flare.

3.5   SAMPLING CONNECTIONS SYSTEM

      Periodic analysis of feedstocks and product streams is often necessary to verify the
proper operation of process units.  To obtain a representative  sample, purging of the
sample lines is often required; During sampling procedures, the open-ended sample line is
an intermittent source of fugitive emissions, since benzene emissions  may be released to
the atmosphere as a result of purging the vapor or liquid to the atmosphere or to open
drains.  To prevent emissions from reaching the atmosphere,   each sampling connection
system must be equipped with a closed-purge system or a closed vent system. Closed-purge
systems or closed vent systems eliminate benzene emissions  by one of three methods,
namely:   (1) returning the purged process fluid or vapor directly to the process, (2)
collecting and  eventually recycling the purged  process material or (3) capturing  and
transporting all of the purged process fluid or vapor to a control device.

3.6   OPEN-ENDED VALVES OR LINES

      In some process units, valves and lines are operated with  a downstream line open to
the atmosphere. Some examples are valves used for purging, venting or draining.  In these
                                         3-27

-------
cases,  faulty valve seats or incompletely closed valves are sources of fugitive benzene
emissions, since leaks would be emitted directly to the atmosphere.  Therefore, a blind,
flange, cap,  plug or a second valve is required to seal off the end of valves and lines when
they are not in use.  When installed downstream of an open-ended, valve, these devices
prevent valve seal leaks from reaching the atmosphere.  If a second valve is used in
conjunction  with the first valve, the upstream valve should always be completely closed
before the downstream valve is  closed.  This  operational requirement is  necessary to
prevent the trapping of process fluid between the two valves.

3.7    PRODUCT ACCUMULATOR VESSELS

       Product accumulator vessels include overhead and bottoms receiver vessels utilized
with fractionation columns,  and product separator vessels utilized in series with reactor
vessels to separate reaction products.   Storage tanks or vessels are exempt  from the
regulations unless they are surge vessels in a process unit.  Only accumulator vessels which
contain benzene at a level of 10 percent (in either the liquid or vapor phase), are classified
as benzene  emission sources under the  NESHAP  regulations and  therefore require
emission control.

       Emissions from  accumulator  vessels occur through accumulator vessel vents  and
seal oil degassing system. The emissions must be controlled by a closed-vent system which
captures and transports any leakage to a control device.  The control device could be a
closed combustion device, such as a process heater or a boiler  or a vapor recovery device.
Benzene emissions from accumulator  vessels which  contain organic  compounds  may
produce noxious or corrosive gases if combusted. In these cases, the emissions should be
vented by a  closed vent system to a vapory recovery control device such as an  absorber,
adsorber, or condenser.

3.8   FLANGES AND OTHER CONNECTORS

      Flanges and  other connectors are used  between sections of pipe and  pieces of
equipment  For the purposes of reporting and recordkeeping, the term connector refers to
only flanged fittings which are not covered by insulation or other materials  that prevent
location of the fittings.   Flanges are  bolted gasket-sealed junctions used between pipe or
                                        3-28

-------
equipment components such as vessels, pumps or valves which may require isolation or
removal. The gasket seal which is a potential leak area, makes flanges a source of fugitive
benzene emissions.  Flanges are generally leak-free if properly installed, but can develop
leaks in the case of extreme overpressure.  Flanges and other  connectors are often so
numerous that they cannot be isolated from the process to permit gasket replacement if a
leak is detected. For on-line flanges, the only repair techniques are tightening the flange
bolts or injection of a sealing fluid.  In some cases, delay of repair may be allowed until the
next process unit shutdown. Similar sources of benzene emissions are any joint connectors
which have seals to prevent fugitive emissions. The two other major types of connectors
are screwed and welded fittings. Screwed fittings may be sources of emissions when not
properly tightened to form a complete seal.

3.9    CLOSED VENT SYSTEMS AND CONTROL DEVICES

       One method of controlling fugitive benzene emissions from sources is to  require a
means of enclosing the source and venting the emissions to a control device. The  operating
parameters of the control device will affect the overall efficiency of the closed-vent/control
device system.  The closed-vent system  employed must be able to collect and  transport
fugitive emissions  to a control device.  The venting system may be applied to control
emissions from pump or compressor seals  (or barrier fluid degassing reservoirs), pressure
relief valves and product accumulator vessels. The closed-vent system itself may be a leak
source if it  fails to operate at the "no detectable emission" level.  Similarly, the  control
device which receives the vented benzene emissions, becomes a leak source if it emits
benzene to the atmosphere due to inadequate recovery or destruction operation. The two
types of control devices which may be used to destroy benzene emissions are combustion or
vapor recovery. Combustion devices consist of boilers, incinerators, process heaters or
flares. Vapor recovery control devices include condensers, adsorbers and absorbers.
                                         3-29

-------

-------
           4.0 INSTRUMENTATION SELECTION AND OPERATION

      The benzene  NESHAP  regulations  require  periodic  monitoring of process
equipment to  determine facility  adherence  with the  fugitive  emission limitations.
Reference Method 21 provides the technical procedure to be used for the emission testing.
According to Reference  Method 21, the inspector may  select  any  one of the various
portable VOC  detection instruments available on the market as long as it meets the
instrument performance specifications stipulated by the  method. These monitors involve a
variety of detectors that operate on several different principles. Each detector has its own
advantages, disadvantages, and sensitivity.

      Conducting a fugitive  emissions inspection that efficiently  satisfies the goals of the
leak detection and repair program requires that the inspector be  thoroughly familiar with
all the equipment available, the important variables to consider when selecting a monitor,
as well as the calibration, operation and maintenance procedures.

4.1    VOC DETECTORS

      Several types of portable VOC detectors can be used either as screening tools or to
meet the requirements of Reference Method 21. These  include:

      o     Flame ionization detector (FID)
      o     Photoionization (ultraviolet) detector (PID)
      o     Nondispersive infrared detector (NDIR)
      o     Catalytic combustion

      Each  of these  detectors  has its peculiar advantages and disadvantages.  The
particular detector that is best for any given application will depend on a number of factors,
such as the type and concentration VOC to be monitored, and other VOC's that may be
present, and conditions at the plant (such as dust, smoke or high humidity). Table 4-1 lists
typical parameters, advantages and disadvantages for each type of detector.
                                        4-1

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       The specifications of individual instruments vary greatly with regard to sensitivity,
range, and responsiveness.  Table 4-2 lists the most common monitors currently in use and
the associated detection principle, range, sensitivity, and  response time of  each.  The
following sections will discuss the operating principle and limitations of  each type  of
detector.

4.1.1  Flame lonization Detector (FTO

       Flame ionization detectors utilize a flame to supply energy to ionize the sample and
then measure the charge or  number of ions produced.  Pure hydrogen burning in air
produces  very little ionization,  so  background  effects are  essentially masked by the
hydrogen flame.  A concentration of even 0.1 ppm of a hydrocarbon produces  measurable
ionization, which is a function of the number of carbon ions present. A positively charged
collector surrounds the flame, and the ion current between the flame and the collector is
measured electronically.  The calibrated output current is read on a panel meter or chart
recorder.

       Organic compounds containing nitrogen, oxygen, or halogen atoms give a reduced
response when compared to  compounds without these atoms.   The  FID hydrocarbon
analyzers are usually calibrated  in terms of a gas such as methane  or hexane, and the
output is read in parts per million of carbon measured as methane or hexane.

       Although nitrogen (N2), carbon monoxide (CO), carbon dioxide (CO2), and water
vapor (H2O) do not produce significant interferences, condensed water vapor can block
the sample entry tube and the flame arresters causing erratic readings.  Also, when oxygen
(02) content of the organic compound  exceeds 4 percent, a significantly  lower output
reading can occur.  The  relative response of the  FID to various organic compounds,
including those with attached oxygen, chlorine, and nitrogen atoms, varies from compound
to compound.

4.1.2 Photoionization Detector (PID^

       In the photoionization process, ultraviolet light ionizes  a molecule  as follows:
R + hv=R+ +  e", where R+  is the ionized species and hv represents a photon  with
                                       4-4

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      TABLE 4-2 MOST COMMON PORTABLE VQC DETECTION INSTRUMENTS3
Monitor
Century ,
OVA 108, b
(Foxboro)
Century
OVA 128 b
Detection
Principle
FID
FID
Range, ppm
1-10,000
0-1,000
Sensitivity
0.5 ppm (Model 108)
0.2 ppm (Model 128)
Response
Time, Sec
2
2
(Foxboro)
PI-101
(HNU Systems, c
Inc.)
TLV Sniffer d
(Bacharach)
Miran 1 A c
(Foxboro)
PID
Catalytic
combustion
IR
0-20,
0-200,
0-2000
0-500,
0-5000,
0-50,000
ppm to %
Ippm
2.0 ppm
1 ppm
5
3-20
1, 4, 10
and 40
a Does not necessarily represent all portable monitors currently being sold.
b Foxboro Company instrument manual for Century OVA 108 and Century OVA 128 Analyzers, 1989.
CHNU Systems, Inc. instrument manual for PI-101 Analyzer, 1989.
d Bacharach Inc. instrument manual for TLV Sniffer, 1987.
c Foxboro Company instrument manual for Miron 1A Analyzer, 1985.
                                        4-5

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energy greater than or equal to the ionization potential of the molecule.  Generally all
species  with an ionization potential less than the  ionization energy of the lamp are
detected.  Because  the ionization potential for all major components of air (C>2, N2, CO,
CO2, and H2O) is greater than the ionization energy of lamps  in  general use, these
compounds may not be detected. Lamps are categorized by their major emission spectra
but they usually emit additional emissions, although much  less intense, at higher energy
level wavelengths. Therefore, some compounds can be detected even when their ionization
potential is slightly above the lamp rating.

      The sensor consists of an ultraviolet (UV) light source and an optical window which
forms the base of the lamp and one side of the photoionization chamber.  The chamber
adjacent to the sensor contains a pair of electrodes  and the sample gas inlet and  outlet
ports.  Organic compounds within the sample gas absorb UV radiation and form positive
ions. When a potential is applied to  one electrode, the electrical field that is created drives
ions formed by the  absorption of UV light to the collector electrode, where the electrical
current (proportional to the organic vapor concentration) is measured.

4.1.3 Nondispersive Infrared Detector (NDIR)

      Nondispersive infrared (NDIR) spectrometry is a technique based on the broadband
absorption characteristics of certain  gases. Infrared radiation is typically directed through
two separate absorption cells:  a reference cell and a sample cell. The sealed reference cell
is filled with nonabsorbing gas, such as nitrogen or argon.  The sample cell is physically
identical to the reference cell and receives a continuous stream of the gas being analyzed.
When  a particular hydrocarbon is  present, the  IR absorption is proportional  to the
molecular concentration of that gas.  The detector consists of a  double  chamber separated
by an impermeable diaphragm.  Radiant energy passing through the two absorption cells
heats the  two portions of the detector chamber differentially.  The pressure difference
causes the diaphragm between the cells in a capacitor to distend and vary, changing the
capacitance.  This variation in capacitance, which is proportional to the concentration of
the component of gas present, is measured electronically.
                                        4-6

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4.1.4 Catalytic Combustion

      The catalytic combustion detector employs a heat source to oxidize organic vapors.
The organic vapor  is ignited in a gas cell upon contact with a heated catalyst coated
filament; the resulting heat release changes the filament resistance, which is measured and
related to the gas concentration.

4.2   SELECTION OF INSTRUMENTS

      The selection of equipment to be used in fugitive benzene emissions inspections is
based on several factors:  detector response and selectivity; instrument range and accuracy;
ease of use; and safety. These factors are discussed in detail in this section.

4.2.1 Detector Response and Selectivity

      One important criterion in the selection of organic vapor detectors is the response
of the instrument to the specific  chemical or chemicals present in the gas stream.  The
abilities of the four major classes of- organic vapor analyzers to detect different organic
chemicals differ substantially.

      Unfortunately, instrument response  can be  complex  functions  of numerous
variables. The response depends on the chemical compound used to calibrate the organic
vapor detector and on the concentration and composition of organic vapor being analyzed.
Published response factors  that specify the value based on  the instrument-determined
concentration are preferred in the selection of an instrument because they are the most
consistent with the regulatory format.

      Rapidity  of  detector response is another factor that must  be considered in the
choice of instrument. Short response times can speed the conduct  of the inspection, and
help to prevent condensation of  non-volatile compounds, which can result if the probe
remains for too long in a concentrated atmosphere.
                                        4-7

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4.2.2 Range and Accuracy

      The ability of an instrument to measure 10,000 ppmv should be carefully considered
if the instrument will be  used to determine compliance with benzene regulations.  As
indicated in Table 4-2, only a few of the currently available units can operate at 10,000
ppmv or above. Other units can operate at this concentration only by using dilution probes.
Although dilution probes can be used accurately, they can also be a source of error. Both
changes in flow rate through the dilution probe and saturation of the charcoal tubes used to
remove organic vapors from the dilution air can lead to errors in the indicated organic
vapor concentration.   Charcoal  tubes have a finite limit on the amount  of organic
compounds that can be absorbed  per unit mass of charcoal at a given temperature.  The
presence of high vapor concentrations  in  the ambient  air will  therefore cause  rapid
saturation of the charcoal. The inspector should watch for this and carry spare tubes for
use should replacement be necessary. Dilution probes also complicate calibration and field
span checks.

      Generally, the instruments should have the desired accuracy at the concentration of
interest.  It should  be noted that an instrument accuracy of +_ 5 percent is required by
Method 21.

4.2.3 Ease-of-Use

      Ease of use is an important instrument selection criterion because of the conditions
under which the field inspector must work.   The instrument must be as light as possible
because the inspector may need to  walk over relatively large  areas to evaluate fugitive
leaks from numerous valves and  other sources.  In some cases, a moderate  amount  of
climbing is also necessary.  After several  hours, even a light instrument  can become
uncomfortably cumbersome.

      Table  4-3 contains  information  concerning  the  portability  of some  of the
commercially available organic vapor instruments.  As shown, the weights of the units and
the manner in which they are used differ substantially.   Other factors which should be
considered are  (1)  how easy the  gauge is to read,  and (2) whether the zero and span
adjustment knobs are sensitive (but not too much so) and  lock firmly in place after
                                        4-8

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             TABLE 4-3 EASE-OF-USE OF ORGANIC VAPOR ANALYZERS
Instrument
Manufacturer
Foxboro 108
Foxboro 128
Type
FID
FID
Weight,
Ibs
12
12
Mode of use
Shoulder strap
Shoulder strap
Other Comments
Readout on probe
Readout on probe
Photovac 10S50



HNU PI-101

TECO Model 580


TECO Model 712

Barachach TLV
  Sniffer

Miran 1A
PID



PID

PID


FID

Cata-
lytic

Infra-
red
26



 9

 8


14

 5


32
Case with handle
Shoulder strap

Small case with
handle

Shoulder strap

Shoulder strap


Carrying handle
Necessary to re-
move cover to ad-
just range

Necessary to open
case at each
measurement site
Readout on probe
Necessary to set
unit down at each
measurement site
                                       4-9

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calibration.  Generally, the easier an instrument is to use, the more likely it will be used
properly and generate data of acceptable quality.

4.2.4  Safety

       All  instruments used  during  field inspections  of  benzene  sources  must  be
intrinsically  safe if they are to be used in potentially explosive atmospheres.  Localized
pockets of gas (and even particulates)  within the explosive range can result from fugitive
leaks and malfunctioning control devices.  Intrinsic safety simply means that the instrument
will not provide a source of ignition for  the explosive materials when the instrument is used
properly.   Instrument  designs  are  certified  as intrinsically safe for certain  types  of
atmospheres by organizations such as the Factory Mutual Research Corporation.

4.3    INSTRUMENT CALIBRATION AND EVALUATION

       Instruments used to determine compliance of industrial facilities must be accurately
calibrated on a routine basis.  The calibration precision test, response time, and response
factor tests  also  should be performed to confirm  that the  instruments  are operating
properly for the  specific  application(s).   This section presents various calibration and
instrument evaluation options available.

4.3.1  Instrument Calibration Requirements and Procedures

       Calibration requirements for  benzene instrumentation are specified  in Reference
Method 21.  The requirements pertaining to calibration are briefly summarized here.

       o     The instruments should be calibrated daily.
       o     The  gas concentration used for calibration  should be  close to  the leak
             definition concentration.
       o     The calibration gas should be methane or n-hexane.
       o     A calibration precision test should be conducted every month.
       o     If gas blending is used  to prepare gas standards, it should provide a known
             concentration with an accuracy of ±. 2 percent.
                                        4-10

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      The  daily  calibration  requirement  specified in  Method  21  gives  individual
instrument operators some flexibility.   The calibration could consist of a multipoint
calibration in the lab, or it could be a single-point "span check" in the field.

      Method 21  does not specify where the daily calibration takes place.  Obviously it
would be simpler to conduct the calibration test in the agency laboratory rather than after
arrival at the  plant being  inspected; however,  the  calibration could  conceivably shift
sufficiently to affect the accuracy of the leak  detection measurements.  Because of the
suspected potential for calibration  shifts in all of the organic  vapor analyzer types, one
should consider conducting  at least a single-point span check after the instrument arrives
on-site and every subsequent day of testing.

      Calibrations performed  in the regulatory  agency laboratory are  conducted under
more controlled conditions than calibrations  that are  conducted in the field  because
uniform day-to-day calibration gas temperatures and calibration gas flow rates can be
maintained in the laboratory. Furthermore, the initial calibration test provides an excellent
opportunity to  confirm that the entire instrument system is working properly before it is
taken into the field. The laboratory calibration data should be carefully recorded in the
instrument calibration/maintenance notebook discussed  later, and this calibration should
be considered as the official calibration required by  the regulations.  A span check that
differs significantly from the laboratory calibration is cause for concern, and the  cause of
the deviation should be determined and corrected before the inspection proceeds.

      The laboratory  calibration is best performed by the personnel assigned primary
responsibility for the maintenance and testing  of all  the agency organic vapor analyzers.
This ensures the use of proper and consistent procedures.  If instrument problems are
identified, either the instrument can be repaired or the  field inspector can be  issued
another unit that is operating properly.

      The  calibration procedures  for  each  instrument   model are  specified in the
manufacturer's instruction manual.   Material presented in this  section is  intended to
emphasize the importance  of certain calibration procedures discussed in these various
instruction manuals.
                                        4-11

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      Regardless of  the  type  of VOC instrument, the flow  rate of the  gas  during
calibration should be approximately equal to the normal sampling rate of the  instrument,
as flow rate can influence the measured concentration.  Proper flow rate is very important
for the FED instruments.

      The gas used for calibration must be methane or n-hexane at a known concentration
of approximately, but  not less than, 10,000 ppmv methane or n-hexane.  A TEDLAR or
MYLAR bag should be rilled with the calibration gas.  During calibration, the instrument
simply withdraws a gas sample from  the bag at a rate of 0.5 to 3.0 liters per minute,
depending on its normal sampling rate and is  adjusted (according to manufacturer's
instructions) to give appropriate readings.

4.3.2 Field Span Check Procedures

      Proper performance of the field span check is crucial to insuring the validity of the
data to  be collected on the inspection.  This section will discuss generating calibration
atmospheres, length of time spent on the span check, where the span check should  be
performed and the documentation that should be made of the results of the span check.

      The following are some of the various means to provide a calibration gas on-site:

      o     Use large pressurized gas cylinders transported to inspection sites.
      o     Use certified gas cylinders provided by the source being inspected.
      o     Use disposable gas cylinders with  the  appropriate gas composition and
             concentration.

      Transporting large pressurized gas cylinders is generally impracticable because most
agencies do not have  the vehicles necessary for this purpose. It is not safe to transport
unsecured, pressurized gas cylinders in personal or State-owned cars. Furthermore, there
are specific  Department of Transportation (DOT) regulations governing the shipping of
compressed gases. The gas cylinders are also heavy and awkward to use in the field.
                                        4-12

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       Using the source's gas cylinders  is certainly the least expensive approach  for a
regulatory agency; however, the appropriate gas cylinders are not always available.  Also,
the  use of  the  source's  cylinders prevents  the  agency  from  making  a completely
independent assessment of the VOC fugitive leaks.

       Disposable cylinders of certified calibration gas mixtures are relatively simple to use
because no on-site blending is necessary and the cylinders are  easily transported.   The
calibration gas mixture may be fed to the instrument directly by using a preset regulator
that provides constant gas flow and pressure; or the gas can be fed into a TEDLAR or
MYLAR bag, from which it is drawn into the portable instrument.

       Relatively little time is required for the span checks when portable cylinders of
certified gas mixtures or transfer gas sample cylinders are used.  It should be  noted that the
instrument warm-up must be done anyway, therefore this  time  should not be  "charged"
against the  span check.  The overall time commitment to the  field span  checks is not
excessive when one considers the clear indication of organic vapor analyzer performance
that these checks provide and the waste of time that would occur if a problem that could
have been detected was overlooked.

       The field span check should be performed as far away as possible from potential
sources of fugitive VOC.  The check should also be performed in areas where there are no
large AC motors or other equipment  that generate  strong electrical fields, as  such
equipment can have an adverse effect on certain types of instruments (e.g., photoionization
analyzers).   The  charcoal  filter used  in the "clean air" supply should be  routinely
regenerated or replaced to avoid the possibility of saturation. The charcoal filter should be
checked occasionally for saturation by supplying a moderate, known concentration of VOC
and then checking the measured exit concentration after several minutes. Spare charcoal
filters should be kept with the instrument.

       Data concerning the span checks (such as a plot of calibration gas  concentration
versus instrument reading) should be recorded in the  inspector's field notes.   This will
demonstrate that the specific unit operated properly during the period in which compliance
information was  obtained at the  inspection site.  If  gauges  are provided  with the
                                        4-13

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instrument, the field inspector also should occasionally note the instrument sample gas flow
rate and document the flow rates occasionally during the inspection.

4.4   INSTRUMENT MAINTENANCE PROGRAM AND RECORDS

      In most regulatory agencies, numerous individuals will  use  the portable organic
vapor analyzers, and it is unrealistic to expect all of them to be fully knowledgeable
concerning instrument calibration and repair.  It is also unrealistic to ask each of them to
make independent determinations of organic vapor analyzer response factors or other
performance data obtained on a frequent basis.  Therefore, one or two people should be
assigned the responsibility for the overall maintenance of the instruments and records of
calibrations or repairs.  Persons skilled in instrument calibration and/or repair are needed
for this assignment.  They can make whatever nonroutine  tests  and measurements are
necessary  to ensure that the monitors continue to perform adequately.  They can also
instruct other agency personnel concerning the proper way to replace filters, detectors, and
battery packs; to operate the unit; and to perform field span checks.  The persons assigned
responsibility  for  the  instruments should become familiar  with  the manufacturer's
operation manual  and  the recommended routine maintenance schedules and procedures
for each instrument.

      Only those  persons assigned responsibility for the instruments should  make any
repairs other than  the replacement of detectors, photoionization lamps, battery packs and
particulate filters.   These  components can be  replaced by the  inspector  and  the
replacements noted in a log or report provided to the person who  has been assigned
responsibility for the unit. Allowing only qualified  personnel to work on the instruments
reduces  the chance   of  the  intrinsic safety  of  an  instrument being  inadvertently
compromised.  The instruments should be returned to the manufacturers for any repairs
that the people assigned responsibility for instrument maintenance cannot perform.

      Records should  be maintained on each instrument including: all calibrations, (field
and laboratory), any  response factor  determinations, and  all repair notes.   Problems
reported by field personnel should be briefly summarized in a chronological record. The
file should contain at least one copy of the operating manual for the instrument and a list
of all part numbers (if  not included hi the manual).  There should also be a chronological
                                        4-14

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record of each time the instrument was used in the field, it's operator, and the location of
the inspection.

4.5 INSTRUMENT PERFORMANCE CHECKS

       Several instrument performance checks should be made before the inspector leaves
for the job-site and during the routine  screening of possible fugitive benzene sources.
Preferably, the initial instrument checks should  be made by the regulatory agency's
instrument specialist assigned responsibility for the monitors.  Brief notes  concerning each
day's   initial  instrument  checks  should   be  included  in  the  main  instrument
evaluation/maintenance   file  kept  in  the  instrument laboratory.   The  appropriate
performance checks for each specific instrument can be found in  the instruction manual
supplied  by  the instrument manufacturer.  The following common elements, however,
should be checked regardless of the type of instrument:

       o     Leak  checks  including integrity of  sample  line  and adequacy  of pump
            operation
       o     Probe condition
       o     Battery pack status
       o     Detector condition
       o     Spare parts and supplies.

       All of these checks can be made in a period of 5 to  15 minutes.  The lost time and
embarrassment that can be prevented by these checks, and proper calibrations and field
checks more than compensates for the time spent  in their performance.   Repairs  to the
detectors, batteries, and probes usually can be accomplished quickly if a set of spare parts
is kept on hand.  Repeating these checks in the field is good procedure. The following
subsections describe some of the elements to be checked before beginning field work.

4.5.1 Leak Checks

      To leak  check the probes on units with flow meters, the probe outlet should  be
plugged for 1 to 2 seconds while the sample pump is running. If the sample flow rate drops
to zero, there are no significant leaks in the entire sampling line. If any detectable sample
                                       4-15

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flow rate is noted, further leak checks will be necessary to prevent dilution of the sample
gas during screening tests.  The  leak checks involve a step-by-step  disassembly of the
probe/sample line starting at the probe inlet and working back toward the instrument. At
each step, the probe/sample line is briefly plugged to determine if leakage is still occurring
at an upstream location. Once the site of leakage has been determined, and the leak has
been corrected, the probe  is again briefly plugged at the inlet  to demonstrate that the
sample flow rate drops to zero.  When more than  one probe can be attached to the
instrument body, each  probe should be  tested.  Only those that can be sealed properly
should be packed for field use.

      When leaks are  detected, there is sometimes a tendency to overtighten the fittings,
especially those between the instrument body and the end of the sample line. With some
types of fittings overtightening can damage the fitting and even lead to persistent leaks.

      Units that do not have flow monitors should be leak-tested by installing a rotameter
on the sample line as  close as possible to the  instrument body inlet.  The leak-testing
procedure described above can then be followed. Also,  the sound of the pump should be
noted, as this provides one qualitative means of identifying pluggage.

      One report states that the  catalytic combustion units should not be  leak-tested by
plugging the probe.  According to  this report, short-term loss of sample flow would lead to
high detector temperatures and failure of the detector.  One manufacturer, however,
reports that the detector used on their instrument is the same as the detector used on a
diffusion-controlled sampler and that the short-term loss of sample flow would not cause a
significant problem. In case of doubt, the inspector should consult the manufacturer about
the efficiency and safety of the procedure.

4.5.2 Probe Condition

      The probes for some instruments can contain a number of independent components,
especially those that dilute the sample before analysis. The physical condition of the probe
should be visually checked before use.  These checks include, but are not limited to:
                                        4-16

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      o     Presence of any deposits ori the inside of the probe
      o     Presence of a clean particulate filter in the probe
      o     Condition of the orifice(s) used to control dilution air flow into the sample
             probe
      o     Condition of  the  "O" ring or  other  sealing assembly used  to  prevent
             inadvertent dilution of sample flow.

      Any deposits found  should  be  removed,  or  a different probe  should be used.
Cleaning instructions can be  found in the manufacturer's operating manual.  Generally, the
probes are cleaned with acetone and then carefully purged of any acetone vapor before
assembly.

4.5.3 Battery Pack Status Checks

      The condition of the battery pack is particularly important to monitor because it can
be a source of frequent problems.  The battery level is normally tested by switching the
instrument control to the  "Battery Check" position and observing the dial setting.  If the
battery appears weak, a new battery pack should be installed.  Most batteries fail because
they have not been recharged sufficiently.

      The nickel-cadmium batteries, used in many photoionization, catalytic and infrared
instruments, must  be charged for 8  to 12 hours for each 8 hours of operation.  These
batteries are very vulnerable to overcharging. Recent improvements  in nickel-cadmium
battery chargers, however, have substantially reduced the risk of overcharging. Despite a
common misconception, the  lead acid-gel batteries commonly used in FID instruments are
not subject to overcharging, and they should be left on the battery pack recharger whenever
the instrument is not in use.

      During cold weather, weak batteries will operate for only a short period. In fact, if
the unit is to be operated in cold conditions for most of the inspection day, it would be wise
to bring a second battery pack along so the battery pack can be replaced at midday. At
least one spare, fully recharged battery pack should be carried to every job-site.
                                        4-17

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4.5.4 Detector Condition

      The detector is the key component within the portable VOC monitor.  Inspectors
may check the detector status by briefly monitoring an organic vapor source, such as certain
fiber pens,  liquid paper thinner, or a small sample bag.  It is not generally advisable to
monitor automobile exhaust because condensable  organic  compounds and  particulate
matter can deposit in the probe, partially plug the filters, and even damage the detector. A
complete calibration is preferred over a brief qualitative response check since this shows
only that the instrument will respond to organic vapors, but not  that it was properly
calibrated or operating as it should.  FID instruments are checked by depressing the igniter
button for several seconds.  If the unit will not ignite after repeated attempts, there may be
problems with the batteries, ignitor, or hydrogen supply. Hydrogen leaks are less prevalent
in newer instruments.  Most of these problems cannot be solved immediately; therefore,
another instrument should  be used.  Failure of the catalytic units to respond to organic
vapor is often due  to failure of the main detector cell,  an easily replaced  component.
Problems of this sort should be detected before the instrument is released for field use.

4.5.5 Spare Parts and Supplies

      Most of the instruments  used on VOC  inspections are sophisticated instruments
rather than simple "off-the-shelf1 items and each requires some spare parts and supplies to
ensure that the inspection is not terminated prematurely. The instrument manual will have
a list of recommended  spare parts and supplies.    At a  minimum, spare battery packs,
detectors, charcoal  tubes and a  small tool kit should be carried to the job-site.  If the
instrument has a chart recorder, spare pens and paper should be available, and for those
instruments with optical surfaces, such as FED or NDIR, the inspector should have the
equipment necessary to clean them.

      If the facility to be inspected is expected to  be especially dirty, the inspector should
also have spare, clean probes and/or another complete instrument on hand.  It is often
much easier and  faster to change equipment than  to clean  and recalibrate heavily
contaminated instruments.
                                        4-18

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4.6   FIELD CHECKS

      Due  to the importance  of  obtaining accurate and  valid data  from inspection
monitoring,  several routine performance checks  should be conducted during field work.
These checks take very little time, and demonstrate adequate sensitivity and that the unit is
continuing to perform in a proper manner.  They also should be documented in the field
notes. Loss  of sensitivity of the monitoring instrument can happen gradually and will result
in erroneously low detection levels of emissions. The following sections cover simple field
checks that may indicate a loss of sensitivity.

4.6.1  Instrument Zero

      The instrument zero should be rechecked whenever it has been exposed to very high
organic  vapor concentrations and whenever organic liquids may have been  inadvertently
sucked into  the probe.  The  instrument zero should be checked at least twice a day, even
when these  conditions do not occur or are not suspected.  It  can be checked by sampling
background  air at a location up-wind of any possible VOC sources or by supplying some
charcoal-filtered  air to  the  analyzer.   If the zero has drifted significantly, the probe
particulate filter and the prefilter (if one is used) should  be replaced.  Also, the probe
should either be cleaned or replaced.  The instrument then should be recalibrated before
the field work continues. It  may be necessary (or at least,  more efficient) to change to a
back-up instrument in the case of severe contamination.

4.6.2  Instrument Response

      The  instrument response should also be checked  routinely  during field testing
because all of the instrument types are vulnerable to operating problems that can result in
reduced sensitivity or complete loss of response. In the case of FID's, exposure to very high
VOC concentrations (above 70,000 ppmv)  can lead to  flame-out  of  the unit.  It is
sometimes difficult to hear the audible flame-out alarm over plant noise unless earphones
(supplied with some models)  are used. If the inspector fails to hear the flame-out alarm, he
or she could miss a number of  fugitive leaks.  The  catalytic combustion units are also
vulnerable to problems when exposed to very high concentrations as the detector can reach
temperatures high enough to cause some loss of the catalyst coating.  If done repeatedly,
this can also shorten the life of the detector.  Exposure to lead-containing gasoline can lead
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to poisoning of the detector catalyst.  For these reasons, the response should be checked
whenever the unit is "pegged."

      Response problems of the photoionization and nondispersive  infrared detectors
result primarily from deposition of condensed organic compounds on the optical surface.
The window should be cleaned at least once a day and whenever material, might have been
deposited as  a  result  of  exposure  to high  concentrations  or entrained  liquids.
Unfortunately, contamination on the optical  window is  not always visible, but can be
inferred from loss of sensitivity. Therefore, inspectors should simply assume the window is
dirty and take the necessary time to clean the optics.  Many instrument manufacturers
recommend  a solvent similar to methanol (instrument manufacturers should be contacted
for specific recommendations) for routine cleaning.   The special cleaning  compound is
mildly abrasive and is intended only for stubborn deposits that cannot be removed by more
gentle methods.

      Performing and documenting these routine mid-test checks will help to identify and
solve problems that might compromise the integrity of the inspection if left undetected.  An
appropriate time to accomplish the checks is during the recommended monitoring breaks.

4.6.3  Battery Condition

      In the case of some FID's, weak batteries will not have enough power to operate the,
ignitor, even though a proper reading was obtained during the battery check.  This can be a
problem after the FED has been operated for several hours and after a  number of flame-
outs have occurred.  In many cases, weak batteries will not cause instrument failure,  but
will alter the response.  Therefore,  the instrument operator should check  the battery
condition several times during the day. This is excellent procedure for all battery-operated
equipment, takes almost no time and can save much. Spare batteries should be kept on
hand at all times for replacement as necessary.

4.6.4  Probe/Sampling Line Leakage

      The probe and sampling line integrity should be checked  several times a day by
simply plugging the probe inlet.  The flow rate indicated by the instrument flow meter (if
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one is present) and the sound of the instrument should be noted.  Any potential leaks
should be corrected before work is continued.

4.7    QUALITY ASSURANCE

       Quality assurance in this type of inspection program depends mainly on proper
recordkeeping.   Along with  the instrument  maintenance  records  discussed  earlier,
traceability of standards, instrument stability and history,  and all calibrations and field
checks should be carefully documented.  The inspector should be aware at all times that a
report of violations, especially one which supports legal action, will be subjected to careful
review and that lack of documentation can prejudice such reports. The presence of such
documentation, however,  demonstrates the care  and  professionalism  with  which the
inspector performs his work.
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                              5.0 PRE-INSPECTION

       Inspecting fugitive benzene emission  sources is expensive  and time consuming,
therefore, thorough planning is a prerequisite for a successful inspection.  Because of the
numerous fugitive benzene emission sources typically located at the process unit subject to
the benzene regulations,  the  inspector cannot monitor every source, but  instead must
choose a representative portion to conduct emission monitoring. Adequate preparation is
essential to ensure the inspection is focused on obtaining the relevant information and data
necessary to document  compliance or  noncompliance.   The  pre-inspection includes
activities to  help  an  inspector prepare for and  efficiently conduct a  comprehensive
inspection (i.e., an inspection where all compliance related issues are  covered).  The pre-
inspection involves:

       o     Facility background information review
       o     Development of an inspection plan
       o     Notifications
       o     Monitoring equipment
       o     Safety
       o     Reference material

Each of these elements are discussed in the following paragraphs.  The objective of this
chapter is to help the inspector develop, review and organize the best monitoring plan prior
to conducting the inspection.

5.1     FACILITY BACKGROUND INFORMATION REVIEW

       Collection and analysis of background information on the facility plays  a crucial role
in preparing for an inspection. A thorough search should uncover general background
information, past inspection  reports and the initial and semiannual reports  submitted by
the  facility.  These materials are obtained from Federal, State and local files as well as
technical documents. The inspector should also review the Federal, State and local laws
and regulations  which  dictate  emission standards  and control procedures  for benzene.
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Once the inspector possesses a good working knowledge of the benzene regulations, the
facility reports and any waivers should be reviewed to determine past compliance.

5.1.1  General Facility Background Information

      The following information should be collected and reviewed to give the inspector
general background needed to focus the inspection.

      o      Names, titles and phone numbers of facility officials
      o      Maps showing facility location  and potential environmental impacts from
             emissions (i.e., geographic relationship to nearby residential areas)
      o      Process flow charts and production information
      o      Production levels
      o      Changes or modifications at the plant facility
      o      Description  and  design  data for control devices and relevant  process
             equipment
      o      Emission sources
      o      Emission characterization  ;
      o      Safety equipment requirements

5.1.2  Inspection Reports

      The following reports should be collected and reviewed to give the inspector insight
concerning the past, present and future compliance history of the facility.

       o      Federal and State and local compliance files
       o      Previous inspection reports (initial and semiannual)
       o      Correspondence between the facility, local, State and Federal agencies
       o      Past conditions of noncompliance
       o      Complaints and follow-up actions
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5.1.3   Legal Records

       The following legal records should be reviewed so the inspector understands the
restrictions placed on benzene emissions, the required control procedures as well as the
facility monitoring  and reporting  schedules necessary to  comply  with  the benzene
regulations.

       o     Applicable Federal, State and local regulations
       o     Most recent permits and permit applications for facility
       o     Special exemptions, alternative test methods and waivers
       o     Pending enforcement actions, compliance schedules and/or variances

5.1.4   Information Sources

       To obtain the necessary facility background  information, the inspector may use
several information sources including files, applicable laws and regulations  and technical
documents.  Most of the background information can be obtained from regional, state and
local  files.  These file.s often  contain inspection  reports, compliance enforcement and
litigation history, exemptions, waivers and alternative test methods applied for and granted
or denied, correspondence between facility and federal and state regulatory agencies and
complaints or history of remedial actions. The files also contain the permits which provide
information on  requirements,  emission  limitations, compliance schedules, monitoring,
recordkeeping and reporting requirements.  Permit applications,  which should also be
found in the files typically contain valuable technical information such as facility location
and plant layout, pollutant characterization and points of emission or discharge, types of
process units and the numbers of process units.

       Benzene emissions are regulated by the National Emission Standards for Hazardous
Air Pollutants (NESHAP) promulgated  under Section 112 of the Clean Air Act.  To
conduct a fugitive  benzene emission inspection,  it is crucial that the inspector possess a
good  working knowledge  of the  applicable standards and associated background legal
aspects. Provisions of the regulations that define the sources to be inspected, that describe
what  constitutes a leak, and  detail facility monitoring inspection schedules should be
particularly noted.  This is especially true for the benzene standards because of the relative
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complexity of the standard and the variety of compliance options that subject facilities may
choose to incorporate.  In addition, some State laws and regulations as well as local
ordinances may stipulate more stringent benzene emission standards which apply to the
same facility.

      Additional information  may be  obtained from this manual, technical reports,
documents and guidelines. These sources can provide specific information concerning up-
to-date process control technology,  advantages and limitation of different type of control
equipment, inspection procedures and monitoring test equipment.

5.1.5  Review of Reports

      Requirements under the NESHAP General  Provisions (40  CFR 61.10)  require
affected sources to submit an initial report which includes general information about the
facility.  The initial report should be evaluated for completeness and any discrepancies or
omissions should be documented in the inspector's report.  To aid in evaluating the initial
report for completeness, the inspector may use the  checklist shown  in Figure 5-1. The
checklist is designed to  target only specific information which should be  included in the
initial report. However, no checklist or guidance document should be relied on to replace
the working knowledge of benzene emission standards and inspection procedures which an
experienced inspector possesses.   In order  to  establish  whether or  not the  benzene
NESHAP regulations are applicable to a facility, the inspector must check: the initial report
to determine if the facility uses  or produces benzene at the stipulated level (greater than
1,000 Megagrams/year) and has equipment "in benzene service" (liquid or gas that is at
least 10 percent benzene by weight). The applicability determination should also be cross-
checked with air, wastewater (NPDES), hazardous waste  (RCRA) and toxic substances
(TSCA) permits.

      The regulations also require sources to submit  semiannual reports which contain
detailed information about the results of facility emission monitoring programs, including
the number of leaks detected and  the subject equipment  repairs.  The inspector should
identify any approved equivalent means of emission limitation, any approved alternative
emission testing methods or alternative valve  standards and review facility compliance. A
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                                       Figure 5-1
            BENZENE  NESHAP INSPECTION PREPARATION CHECKLIST
                               FOR INITIAL REPORTS
Initial Report Review for Completeness
40 CFR 61.10 Information
	   Name & address of the owner or operator
	   Location of the source
	   Brief Description of the facility's operation and design capacity
	   Average weight benzene or benzene related product processed per month
	   Primary emission control (e.g. flare, scrubber, incinerator)
	   Secondary emission control (if present)
	   Control efficiency
40 CFR 61.247(a) and 40 CFR 61.247(c) Information
	   Statement that requirements of standard are being implemented       ~~~
	   List of all subject equipment including:
      	  Type of equipment (e.g. valve or pump)
      	  Process unit where equipment is located
      	  Percent by weight benzene in the fluid at the equipment
      	  Process fluid state at the equipment (gas/vapor, liquid two phase fluid)
      	  Method of  compliance with the standard (e.g. monthly leak detection and repair,
            equipped with dual mechanical seals)
	   Schedule for submitting semiannual reports (note in comments section)
Comments:
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checklist designed to aid the inspector in evaluating the completeness of the semiannual
reports is shown in Figure 5-2.

5.2   DEVELOPMENT OF THE INSPECTION PLAN

      Due to time  restraints and the typically large number of fugitive emission sources
located at an affected facility, an inspection plan is essential to conducting a thorough and
efficient inspection.  Based on the review of the background information, a comprehensive
inspection plan should be developed to address the activities and procedures which must be
performed to achieve the objectives.  The objective of the inspection plan is to determine
facility compliance with the benzene NESHAP regulations. The plan typically consists of
the tasks and procedures necessary to document the compliance determination, i.e., plant
record review and inspection monitoring for fugitive benzene emissions.

5.2.1  Plant Records

      Records which are required to be kept by the facility (and not reported) should be
reviewed by the inspector during the on-site inspection.  The inspector should determine
prior to entry, what  additional information needs to be obtained to document compliance.
In particular, the inspector should identify missing information, incomplete data or reports
and inconsistencies  in the available background material and specifically seek to extract
this information from  on-site facility reports for  the purpose of making a compliance
determination. Likewise, if noncompliance is suspected, the inspector should concentrate
efforts on obtaining necessary documentation for verification.

5.2.2  Inspection Monitoring

      Due to the number of sources typical of most subject facilities, it  will generally be
impossible to  inspect  all the  possible  fugitive benzene emission sources  during one
inspection.  Therefore, a selection of representative and priority sources must be made.
Because the time available for field inspection is limited to a few hours, the inspection plan
should select for emission inspection, those units that are most useful in the characterizing
of the overall condition at the facility. In selecting the process units to be monitored, the
inspector should consider the percent by  weight of benzene  in  the  process stream,
allowable emission levels (less than 10,000 ppm or no detectable emission), the equipment
repaired since the  last inspection, the equipment designated  as difficult to monitor or

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                                       Figure 5-2

            BENZENE NESHAP INSPECTION  PREPARATION CHECKLIST

                            FOR SEMIANNUAL REPORTS

Review of Semiannual Reports

	   Have the semiannual  reports been submitted  on the  schedule indicated in the initial
       report? If not, please indicate appropriate due dates and submittal dates for late reports.
Comments:

Check the two most recent semiannual reports for completeness using the checklist below [40
CFR 61.247(b)]:

	   Process unit identification
	   Number of valves for which leaks were detected [40 CFR 61.242-7(b), 61.243-2]
	   Number of valves for which leaks were not properly repaired [40 CFR 61.242-7(d)]
	   Number of pumps for which leaks were detected [40 CFR 61.242-2(b), 61.242-2(d)(6)j
	   Number of pumps for which leaks were not properly repaired [40 CFR 61.242-2(c), 61242-
       2(d)(6)]
	   Number of compressors for which leaks were detected [40 CFR 61.242-3(f)]
	   Number of compressors for which leaks were not properly repaired [40 CFR 61.242-3(g)]
	   For  each improper (delayed)  repair,  the  facts that explain the delay and, where
       appropriate, why a process unit shutdown was technically infeasible
	   Dates of process unit shutdowns during the semiannual reporting period
	   Revisions to items submitted in the initial report if changes have occurred  during the
       reporting period
	   The results of all  performance tests conducted during  the  reporting period on all
       equipment that are designated to meet the "no detectable emissions" compliance option [40
       CFR 61.242-2(e), 61.242-3(i), 61.242-4(a),  61.242-7(f), 61.242-ll(f)]
	   The results of all performance tests conducted during the reporting period on  valves that
       are designated to meet the "allowable percentage of valves leaking" compliance option [40
       CFR 61.243-1]
	   The results of all performance tests conducted during the reporting period on  valves that
       are designated to meet the "skip period leak  detection and repair" compliance option [40
       CFR 61.243-2]                                                          f    i

Comments:

Note:    Remember to bring a copy of at least one semiannual report on the inspection so that
         the semiannual report data can be spot checked against the in-plant records data.
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unsafe to monitor  and any approved alternative method of limiting fugitive benzene
emissions.   Generally,  the most  probable "leakers" should be  targeted  for  emission
evaluation. The following factors should be considered to select equipment items for leak
inspections:

      o      specific components identified as leakers in the past,
      o      type of service (e.g., gas or liquid),
      o      type of component (e.g., valves, pumps, flanges, relief valves),
      o      pressure of line,
      o      temperature of line,
      o      specific design of component (e.g., type of pump seal, type of valve, type of
             valve pack),
      o      age of equipment or component,
      o      volatility of specific organic compound(s) being handled.

      The optimum field  survey strategy focuses the primary monitoring emphasis on the
following:  1) those components of process areas with a demonstrated history of high leak
rates, 2) valves in gas and  light liquid service, and 3) pumps in light liquid service. As part
of the pre-inspection, the inspector should prepare a monitoring survey log sheet for each
selected process unit. An example of a survey log sheet for identifying leaking components
is shown in Figure 5-3.          .

5.3   NOTIFICATION

      The  facility management should be contacted  generally one  day before  the
inspection  date unless  a surprise inspection is intended.   Federal inspectors should also
notify appropriate State and/or local air pollution control agencies. Notification may be by
telephone or letter and should include the purpose of the inspection.  The inspection date
and time should be set, the assistance of specific plant personnel arranged and the facility
management informed to prepare  or make available specific information at the time of
inspection.  The facility representative notified should have the authority to release data
and samples and to arrange for  access to conduct the inspection.  Additionally,  the
inspector should request information about on-site safety regulations and necessary safety
equipment When additional facility information is requested prior to the inspection, a
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         FIGURE 5-3
MONITORING SURVEY LOG SHEET
Leak Detection EE
Process unit

Component

Stream composition
Gas

Liquid

Tag
number

id Repair S
Instrument
Date
leak
located

urvey Log
operator
Analyzer

Date
maintenance
performed

Component recheck
after maintenance
Date

Analyzer
reading
(ppmv)

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letter may be used for notification purposes.  Some of the common information requested
by a notification letter includes:

      o      Raw materials, products, by-products and production levels
      o      Facility layout maps which identify process areas and discharge or emission
             points
      o      Flow diagrams for processes
      o      Description and design of pollution control and treatment systems
      o      Operation and maintenance problems that  may cause violations of emission
             limitations
      o      Recent self-monitoring reports and inventories for discharges and emissions
      o      Files of required reports and records.

      A careful search of available background information should be conducted to avoid
requesting duplicate information.   When requesting  material, the  facility should be
informed of its rights to assert a claim of confidentiality (40 CFR 2.203).

5.4   MONITORING EQUIPMENT

      The  pre-inspection  preparation includes selecting  and  calibrating inspection
monitoring equipment.  The type of equipment best suited to performing the inspection
monitoring will vary according  to the individual facility,  and must be chosen carefully to
ensure the test results will be reliable and useful. The four types of monitoring devices for
Method 21 are:  flame  ionization, photoionization, infrared  absorption  and  catalytic
combustion.  Table 4-1 identifies the advantages and limitations of each type of monitoring
equipment.

      Selection of the appropriate inspection monitoring equipment will be dependent on
the individual facility process streams, control equipment  and plant safety requirements.
The pre-inspection review of background material should include determining whether the
materials handled are toxic, the process conditions (i.e., temperature, pressure, percentage
of benzene and maximum  leak potential) and the different types of equipment to be
monitored.
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      Prior to the inspection, the monitoring equipment  should be pre-checked and
calibrated to ensure equipment performance and accuracy in the field. Chapter 4 discusses
in detail the pre-check and calibration procedures for the four types of monitors.  It is a
good  idea to  obtain backup instrumentation so that  the inspection can be conducted
without interruptions and delays due to nonoperational monitoring equipment or on-site
problems.

5.5   SAFETY

      Safety equipment required by the facility should be identified during the notification
phone call or requested in the notification letter. Safety equipment should be checked and
assembled prior to leaving for the facility to assure the safety of the inspector and to avoid
being denied entry at the facility due to lack of and/or improper equipment. If the plant
does not  mandate personal protective equipment, the inspector should assemble, at a
minimum, long-sleeved clothing made of natural fibers, a hard  hat, safety shoes, safety
glasses,  ear plugs and a half-face chemical cartridge respirator.  The cartridge should be
replaced daily and whenever any odor or taste is noticed.

5.6   REFERENCE MATERIAL

      As  part of the pre-inspection the inspector should reproduce (preferably two-sided)
all of the written material required  during the inspection.   Generally, these reference
documents may include any or all of the following:

      o    Maps
      o    Flowcharts
      o    Plant layout
      o    Copies of regulations, waivers and test methods
      o    Inspection checklists and monitoring survey log sheets
      o    Inspection plan or agenda
      o    Additional facility information
      o    Lists of questions or items to check against facility in-plant records
      o    Inspectors notebook
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                                6.0 INSPECTIONS

      The purpose  of the  inspection is  to document  overall facility compliance  with
fugitive benzene emission limitations, leak monitoring procedures by plant personnel,- and
facility reporting and  recordkeeping  requirements.  The inspectors  must conduct the
inspections in accordance with the Agency policies and procedures pertaining to protocol,
handling of confidential information and all applicable  safety rules.  Also, it is the
inspector's responsibility to collect factual, valid information and data which document the
compliance  determination  and which are supportable  and admissible for use in any
subsequent enforcement action.  This chapter presents  inspection safety considerations,
inspector's responsibilities in addition to the basic activities and leak monitoring techniques
involved in the facility inspection process.

6.1   SAFETY

      Based on studies linking occupational exposure to benzene  with leukemia, EPA
listed benzene  as  a hazardous air  pollutant on June  8,  1977.   Because benzene  is a
cumulative poison and recognized carcinogen, extreme care must be taken by inspectors to
minimize  or eliminate  exposure.   Conducting field leak detection inspections  always
subjects the  inspector to a degree of risk.  The objective of this  section is to describe ways
to minimize  these risks through proper selection of protective equipment, and by following
health and safety plant procedures and safe monitoring practices.

      When facility conditions demand personal protection equipment, the inspector must
know how to select and use this equipment as well as appreciate the limitations of the
equipment.  Any protective  clothing, facial hair restrictions,  ear plugs and  protective
equipment requirements must be established and preparations made for prior  to leaving
for the field  inspection.  All safety equipment, especially respirators should be checked out
to confirm that they are in good working  condition.  The proper safety shoes  should be
worn for the existing plant conditions.

      Safe inspection practices begin with a full understanding and respect for potential
hazards.   Before  entering  the  process  areas,  the inspector  should  discuss potential
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          •   :  /   '      v  ^"  -      •  i
                                    I   :
hazardous conditions within these areas with the appropriate plant representatives.  The
inspector should insist that someone from the plant accompany him or her at all times to
ensure that the inspector does not inadvertently enter unsafe areas, to assist the inspector
in the  event of accidental gas releases within the  facility, to get help if the inspector is
injured, and to provide general assistance and advice regarding safety.

       During the field leak monitoring inspection, the inspector should use the portable.
VOC detector to help determine if conditions are safe.  Half-face cartridge-type respirators
for organic vapors are limited to maximum concentrations of 50 ppmV.  Typically,  this
concentration would be exceeded in. the very localized  area where the inspector is holding
the instrument probe. Also, inspectors should avoid entering poorly ventilated areas which
may have  organic vapor concentrations in  the  breathing zone that  are  above  the
concentration limits of the respirator.

       Inspectors should  also be cognizant of the potential for heat stress.  The physical
exertion of carrying the portable analyzer, coupled with exposure to hot process equipment
can lead to heat stress.   Drinking plenty of  fluids and scheduling rest breaks will greatly
reduce the risk.  Breaks are  an ideal time to check the response of the  portable leak
detection instrument or to conduct other performance checks.

       Safety should always be considered  during field monitoring.   Some components
might  be considered unsafe to  monitor because process conditions include  rotating
equipment and hot surfaces.   When using a portable  VOC detector,  the following safety
practices are suggested:

1)     Do not place a rigid probe near a moving part such as a rotating pump shaft. A
       short, flexible probe extension tip may be used.

2)     Do not place the  umbilical cord from the  detector on a heated surface such as a
       pipe, valve, heat exchanger, or furnace.

3)     Do not place the umbilical.cord from the detector near rotating equipment such as
       pump shafts.
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       Some components may be difficult to reach because they are located in elevated
areas.  Occasionally these components might be reached by using a ladder or scaffolding.
The inspector should avoid monitoring any component which is elevated more than six feet
above  permanent support surfaces.  No heroics should be attempted in order to monitor
the component.

       Also, each plant will have its own safety procedures.  These procedures may involve
restrictions on the use of tools in certain areas.  Before inspecting any facility, the safety
officer should be contacted.

6.2    INSPECTOR'S RESPONSIBILITIES

       The primary responsibility of  inspectors is to gather the information needed to
determine facility compliance with the applicable Federal, State and local regulations. To
accomplish this task, the inspector must adhere to both legal, and procedural guidelines.
Strict adherence to these guidelines is  essential in order to collect valid information during
the inspection.

6.2.1   Legal Responsibilities

       It is  the inspector's legal responsibility to protect trade secrets and confidential
information from public disclosure as stated in  Section  114(c)  of the Clean Air Act.
Confidential information from the inspectors standpoint may be defined as information
concerning or relating to trade secrets, processes, operation,  style of work, apparatus,
confidential statistical data, amount or source of any income, profits, losses or expenditures
which the facility discloses as confidential.  The facility is entitled to make a declaration or
claim of confidentiality for all information that an inspector  has access to or requests.  It is
the inspector's responsibility to inform facility officials during the opening conference of
their rights regarding confidentially claims.   Information which the company is  claiming
confidential must be stamped or typed with a notice such as "trade secrets", "Proprietary",
or "confidential business information". Alternatively, a cover sheet containing the same
wording may be attached to the confidential information.
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6.2.2  Procedural Responsibilities

      The inspector must rely on taking physical measurements, reviewing records and
observing facility operation to provide the evidence required to support a determination of
compliance. The inspector must adhere to the general inspection procedures for gathering
and  documenting  evidence to  avoid the possibility  of endangering any  future legal
proceedings on procedural grounds.

      Documentation in general refers to all print material produced, copied, or taken by
the inspector to provide evidence of facility compliance status.  This documentation may
include the inspector's field notebook, checklists, drawings, flow sheets, maps, statements,
copies of records,  printed material and photographs.  It is  important that the inspector
recognize the possibility that any documents gathered or produced during the course of the
inspection may eventually become part of an enforcement proceeding and assume the
responsibility of ensuring that all such documents can withstand legal scrutiny.

      A vital part of  the  documentation material is  the inspector's  field  notebook.
Because the government's case in a civil or criminal prosecution depends  on  the evidence
gathered by the inspector, it is important that the inspector keep detailed records for each
inspection. The field notebook may be used to form the premise of the inspector's report
and as evidence in legal proceedings, therefore it is critical that the inspector substantiate
the  facts with tangible  evidence i.e.,  pertinent  observations,  photographs,  copies of
documents, descriptions of procedures, unusual conditions, problems and  statements from
facility personnel.  The field notebook will not remain in the inspector's possession but
becomes part of the Agency's files, although copies may be made for the inspector.

6.3   FACILITY INSPECTIONS

      The facility inspection is divided into five major activities, namely;  entry, initial
interview, evaluation of the leak monitoring program, record review, and closing interview.
The following procedures  are typically followed  during an inspection.   Most of these
procedures  are  common to all  inspections.  At the  inspector's discretion,  however,
emphasis may be  given to any particular procedure(s) which will aid in  making a
compliance determination of the facility.
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6.3.1   Entry

       The Clean Air Act establishes the inspector's authorization to enter a plant for the
purpose of inspection.  Upon presentation of credentials, the inspector is legally authorized
to enter into the plant to inspect any monitoring equipment or methods, conduct leak
screening tests  and access any  records  required  to  be maintained  at the site.   Two
important considerations of plant entry are the arrival and obtaining the consent to conduct
the inspections.

6.3.1.1 Arrival

       The inspectors should arrive at the facility during normal working hours.  Unless
previously instructed otherwise,  the  inspector should enter through  the main gate and
immediately locate the plant official who was contacted during the pre-inspection facility
notification  process.  Upon  meeting the appropriate plant official, the inspector should
introduce himself or herself as  an inspector and  present  the proper credentials.   The
credentials must be presented whether or not identification  is requested by the  plant
official.

6.3.1.2 Consent

       Consent to inspect the plant premises must be given by the owner, operator or his
representative at the time of the inspection.   If the inspector  is allowed to  enter the
premises, the entry is considered to be voluntary and consensual, unless the  inspector is
expressly told to leave the premises.  Expressed consent is not mandatory; absence  of an
expressed denial constitutes consent.

6.3.2   Initial Interview

       Once the inspector has identified himself or herself and been granted entry onto the
plant  site, the initial interview should be conducted. The objective of the interview is to
inform the facility official(s) of the purpose of the inspection, the authority under which it
will be conducted,  and the  procedures which are to be followed.  A successful initial
interview will aid in obtaining cooperation of the plant officials in  providing relevant
information and assistance. The initial interview should cover the following items:
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o     Inspection Objectives.  The inspector should provide an outline of inspection
      objectives to inform the plant  officials of the  purpose and scope of the
      inspection and prevent misunderstandings.
o     Inspection Agenda.  The agenda will help eliminate wasted time by allowing
      officials to  make necessary  arrangements for gathering information, and
      conducting calibration and monitoring procedures.
o     Facility Information Verification. The inspector should verify or collect the
      following information: the correct name and address of facility; the correct
      names of plant management and officials; the principal product(s); and the
      locations of major emission points.
o     List of Records.  A list of  all records to  be inspected during the  initial
      conference will allow plant officials ample time to gather material.
o     Accompaniment.  Regulations stipulate that a facility official accompany the
      inspector  during  the  inspection  to  provide  process and  operation
      information,  identify confidential  data   and   for  safety   and  liability
      considerations.
o     Safety  Requirements.   The inspector should inquire about  plant  safety
      regulations and procedures that he or she should follow while  conducting the
      inspection.   He  or she  should become familiar  with  emergency  warning
      signals and plant evacuation procedures.
o     Meeting Schedules.  The inspector should schedule interviews with key plant
      personnel to  allow them an opportunity  to re-arrange  their activities to
      accommodate the interview.
o     Closing Conference.  A specific time should be scheduled for the post-
      inspection meeting to allow inspectors a final chance to obtain information,
      and  allow  facility  officials  to  ask questions and make  confidentiality
      declarations before leaving the premises.
o     Simultaneous Measurements.  Plant officials should be  informed of their
      rights to conduct their own simultaneous benzene emission measurements.
o     Confidentially Claims.   Plant officials  should be advised of their right to
      request confidential treatment of trade secret information.
                                   6-6

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6.3.3   Evaluating the Facility Leak Monitoring Program

       The key element of the facility inspection is evaluating the leak monitoring program.
This activity includes  observing  facility personnel calibrate leak detection equipment,
observing facility personnel perform limited leak detection monitoring on  each type of
equipment subject to the benzene standard, and spot-checking a representative sample of
equipment sources for leaks.  By performing spot-checks for leaks and observing plant
personnel  conduct calibrations  and leak  detection  monitoring,  the  inspector  verifies
compliance with the leak detection program required by 40 CFR 61.245 as  well as
demonstrates to the regulated industry the agency's determination  to actively pursue
continuous facility  compliance with the regulations.

6.3.3.1 Observation of Calibration Procedures

       The calibration procedures and leak detection monitoring should be performed by
the facility personnel who are responsible for the routine monitoring. The inspector should
document the plant's ability to properly implement the standard.  The instruments used to
determine compliance of facilities must be calibrated on a routine  basis.  The calibration
precision tests, response time and response factor tests reveal whether the instruments are
operating properly for the  specific applications.   The inspector should  witness the
calibration procedures and note any  deviations  from  Method  21.   The Method  21
calibration requirements are:

       o     The  instruments should be calibrated daily with two calibration standards,
            zero  air and a calibration gas.
       o     The  gas  concentration used  for calibration should  be close  to the leak
            definition concentration.
       o     The calibration gas should be methane or n-hexane, certified to be accurate
            within 2 percent and within the specified self life.
       o     If gas blending is used to prepare gas standards, it should provide a known
            concentration with an accuracy of plus or minus two percent.
       o     The zero air used for calibration should  be certified to contain less than 10
            ppm  of hydrocarbon in air and within the specified shelf life.
                                         6-7

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      A number of other factors can be important such as:  probe cleanliness, probe
leakages, gas flow rates, improper warm-up period, incorrect zero or meter adjustment.  If
the meter readout cannot be adjusted to the proper value, a malfunction of the analyzer is
indicated  and corrective actions  are necessary before using the analyzer. The inspector
should verify that the correct calibration gases are used and that the gases are within the
proper range. The inspector should record the instrument response time, response factors
and calibration precision tests.

6.3.3.2 Observing Leak Detection Monitoring By Plant Personnel

      The inspector should also observe the  plant personnel's technique in performing
actual leak  detection measurements.   The plant personnel  should  be able to  correctly
monitor  fugitive benzene  emissions  from all the  equipment types  at the  plant  site.
Additionally, the plant personnel should  be able to correctly  determine background
concentrations.  Any deviations from Method 21 procedures should be noted. Techniques
for correctly monitoring certain equipment items are described in the following paragraphs.

      Fugitive leaks from valves occur primarily  from the valve stem packing gland.  This
packing material is intended to seal the process gas and/or liquids from the atmosphere.
As the  packing lubricant is lost or the  packing material wears, some volatilization  or
organic vapors  is possible.  For these types of valves, the emissions are monitored at the
point where the valve stem  leaves the packing gland.  The normal procedure is  to
circumscribe the valve stem with the probe  held at the stem-packing gland interface.
Maintaining such a close proximity to the stem is necessary in order to obtain an accurate
measurement because of the relatively poor capture effectiveness inherent in the probe
design.  The presence of a strong cross-draft caused by ambient wind further reduces the
probe capture capability.  For these reasons the proper placement of the probe is critical.
It should be noted, however, that this monitoring requirement dictates that the inspector
position himself or herself hi the immediate vicinity of the leak because most probes are
relatively short in length.  To minimize inhalation hazards, the  inspector should terminate
any monitoring when the concentration of organic vapor in the breathing zone exceeds the
maximum safe concentration of his or her specific respirator.
                                         6-8

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      Valves used on the ends of drains or sample lines have two sources of leakage, the
valve stem and the valve seat.  Most sources use a double valve arrangement or incorporate
a blind flange to protect against emission losses through the valve seat of the main shutoff
valve.  To confirm the adequacy of the drain or sampling line seal, the probe .is usually
placed at the center of the discharge pipe.

      Fugitive emissions from pumps occur from the pump shaft seal used to isolate the
process fluid from the atmosphere. The most commonly used seals are single mechanical
seals, double mechanical  seals, and packed seals. Monitoring should be executed within
one centimeter of the seal and the rotating shaft. A rigid probe tip should not be used near
the rotating  shaft because it could break if the inspector were not able to hold the probe
absolutely steady during the measurement.  A flexible tip is usually added to the end of the
rigid probe  when sampling pumps.  If  the housing configuration prevents a complete
traverse of the shaft periphery, sample all accessible portions. Sample all other joints on
the pump or compressor housing where leakage could occur.

      Most pump shafts  have shaft guards that protect against entrapment in  the rapidly
rotating shaft.   With some instruments, it is difficult to reach through the guard  to the
location of  the shaft and shaft  seal.   The guard  should not  be removed  under any
circumstances, and those pumps without guards should be approached very carefully.

      Care  must be exercised when monitoring sources,  such as valves and pumps, that
handle heavy  liquid  streams  at high  temperatures.    Relatively nonvolatile organic
compounds can condense in the probe and detector.  Both the instrument response to the
emissions  and the instrument return to zero may be slowed due to the condensation of
these compounds.  For fugitive VOC sources that have a highly variable leak rate, the
maximum sustained concentration or maximum repeated concentration observed should
generally be recorded.

      Fugitive leaks from flanges or other connectors typically occur at the flange or
connector sealing interface.  For welded flanges, the probe should be positioned  at the
outer edge of the flange - gasket interface and monitoring should be conducted over the
entire circumference of  the flange.  Emissions  from all  other connectors  should be
monitored with a similar traverse.
                                        6-9

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

      Certain fugitive leak sources are subject to a "no detectable emission" regulation, i.e.
the difference between the background organic vapor concentration and the concentration
downstream of the source should  not  be greater  than  500 ppmV.   The  background
concentration is determined by placing  the probe 1 to 2 meters  upwind of the source.  If
other equipment  interferes with the background measurement, the upwind monitoring
location can be as close as 25 centimeters.

      The facility leak monitoring program checklist shown in Figure 6-1 should help the
inspector assess the plant's ability to carry out the work  practice  requirements specified in
the regulations.  The inspector should note problems, including the  need for further
monitoring training.

6.3.3.3 Spot-Check By Inspector

      The inspector should spot-check a few equipment items in benzene service for leaks,
improper  identification,  improper tagging,  or  other   noncompliance.   Under  no
circumstances should the inspector conduct the leak screening tests without the aid of plant
personnel familiar with the hazardous areas of the plant site. Because of the large number
of potential fugitive benzene  emission sources, the inspector should concentrate the field
monitoring on the following:

       1)     Recently leaking devices
      2)     "No detectable emission" devices
      3)     Closed vent systems and cohtrol devices (insure compliance with minimum
             temperature, residence time, efficiency and no detectable emissions)
      4)     Flares (no visible emissions as determined by Reference Method 22)
      5)     Exempt devices (verify compliance)
                                         6-10

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                                  FIGURE 6-1
           FACILITY LEAK MONITORING PROGRAM CHECKLIST

Request a demonstration of the portable hydrocarbon detector calibration procedure.
Document any deviations from Method 21.
Be sure to record:
	   Make and Model of the portable hydrocarbon detector(s)
	   Type of calibration gas (methane/n-hexane) and how it is prepared or purchased
Comments:
Have the responsible plant personnel demonstrate use of the detector in the field. Are the
plant personnel familiar witn the standard?  Assess the plant's ability to carry out the work
practice requirements specified in the regulations.
Comments:
                                       6-11

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      The data obtained by inspectors must be of the highest quality reasonably possible
because this data will be used to determine ;the compliance status of the facility. Therefore,
adequate time should be allocated for the leak detection equipment span checks, response
checks, and zero gas checks during the leak monitoring procedures.

      While  spot-checking equipment for  leaks, the inspector  should  also  verify
equipment identification numbers and  the proper marking of leaks  (tags should be
weatherproof  and visible).  The  equipment and leak  identification checklist shown in
Figure 6-2 may be used in conjunction with the pre-inspection selection of equipment for
leak testing.   Additionally, the  inspector should evaluate each standard  (i.e.,  valve,
sampling connection) individually during the inspection.  Equipment pieces  may not fit
neatly into a  single category  but instead  may be subject to more than one benzene
equipment standard. For example, an open-ended valve on a sampling connection system
may be  concurrently subject to three standards; the valve standard, the open-ended valve
standard and the sample connection system standard.

      Furthermore, the inspector should be aware of the common potential leak screening
detection problems and the necessary precautionary or corrective measures. Some of these
common problems are described in the following paragraphs.
                                       I
      The most typical monitoring problem encountered during inspection is  locating the
exact site  of a leaking source because once emitted, organic vapors are quickly dispersed.
To alleviate the problem, the probe should be positioned perpendicular to the source and
rotated very slowly while simultaneously observing the analyzer meter. Unless  the probe is
positioned directly in line with the emission plume, detection will be difficult.

      Several organic vapor analyzer problems can be caused by monitoring gases with
high VOC concentrations. At hydrocarbon concentration above 70,000 ppmv, flame-out of
flame ionization detectors can occur. High concentrations of hydrocarbons can lead to very
high detector  temperatures and the loss of catalyst in catalytic units.  Condensation of a
portion of these high  concentration vapors on photoionization unit lamp windows can
reduce  the sensitivity of the instrument The condensation of material in the probe and
sampling  lines can be a problem for all  types of instruments.  For these reasons, the
inspector  should monitor the hydrocarbon concentration while slowly approaching the
                                         6-12

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                                FIGURE 6-2
           EQUIPMENT AND LEAK IDENTIFICATION CHECKLIST
Spot check equipment for proper identification numbers and leak identification [40 CFR
61242-(l)(d) and 61.246(b)].
	   Pumps [40 CFR 61.242-2]
Equipment ID No.:
	   Compressors [40 CFR 61.242-3]
Equipment ID No.:
	   Pressure relief devices [40 CFR 61242-4]
Equipment ID No.:
	   Sampling connection systems [40 CFR 61242-5]
"Equipment ID No.:
	   Open ended valves or lines [40 CFR 61242-6]
Equipment ID No.:
                                     6-13

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                                 FIGURE 6-2
   EQUIPMENT AND LEAK IDENTIFICATION CHECKLIST (CONTINUED)

	   Valves [40 CFR 61.242-7]
Equipment ID No.:

      Pressure relief devices in liquid service, flanges and other connectors [40 CFR 61.242-8]
Equipment ED No.:

	   Product accumulator vessels [40 CFR 61242-9]
Equipment DD No.:
 *   Is the above equipment marked in such a manner that it can be distinguished readily
    from other pieces of equipment [40 CFR 61242-l(d)]?
 **  Be  sure to record the monitored  CVSCD parameters  as specified  in the Control
    Device Checklist.
 Comments:
                                       6-14

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valve stem, pump  shaft seal or other source.  If the instrument gauge indicates a high
concentration, the specific leak site should be approached very carefully. In some cases,
the concentration will exceed the leak definition even before the probe is placed close to
the leak site.  Obviously, in these cases, there is no need to move the probe closer and risk
affecting the performance of the detector. Furthermore, there is nothing to be gained by
maintaining the probe at the leak site for two times the response time (a general rule) if
the instrument already indicates a concentration above the leak.

      The organic vapor analyzer  probe should never be placed  in direct contact with
liquids during the monitoring of fugitive emissions. A portion of the liquid could be pulled
into the probe which may damage the instrument detector.  If there is contact with liquid, it
may be necessary to clean and/or repair the instrument.

6.3.4  Record Inspections

      The primary objective of the record  inspections is to minimize  fugitive benzene
emissions through requiring adherence to the reporting and recordkeeping requirements of
40 CFR  61.246 and 61.247.  From  pre-inspection activities the inspector should already
possess a general understanding of the plant under investigation,  the processes employed,
the products produced in addition  to being familiar with all applicable regulations and
knowing  what  type of information is required to  determine compliance  with each.  This
knowledge is necessary to help select those units suspected or detected as being compliance
problems and  to help avoid giving  unnecessary attention  to items in compliance or not
covered  by compliance regulations.  The inspector, after conducting  the facility leak
monitoring portion of the inspection, should have a better understanding of the facility
layout and its program,  as well as having  identified  specific equipment tagged  for repair
which can be checked during the record review.  The inspector should seek to screen the
records for key data necessary to document compliance with the regulations.  The types of
data that are suggested for review are in-plant logs and semiannual reports.

      The facility's in-plant records  should be examined to determine compliance with the
recordkeeping requirements in 40  CFR 61246.  The information recorded should be
complete and maintained in an organized format.  The in-plant records checklist shown in
Figure  6-3  identifies  the  information which facilities  are  required  to  record
                                         6-15

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                                  FIGURE 6-3
                       IN-PLANT RECORDS  CHECKLIST
40 CFR 61.246(c) - Does the plant have the following information in a two year log
regarding leaks located on pumps (40 CFR 61.242-2), compressors (40 CFR 61.242-3),
valves (40 CFR 61.242-7), liquid SRVs, flanges, and other connectors (40 CFR 61.242-8)?
	   The  instrument  and  operator  identification  numbers  and  the  equipment
      identification number.
	   The date the leak was detected and the dates of each attempt to repair the leak.
	   Repair methods applied in each attempt to repair the leak.
	   "Above 10,000 ppm" if the maximum instrument reading measured by the methods
      specified in 40 CFR 61.245(a) after each attempt is equal to or greater than 10,000
      ppm.
	   "Repair delayed" and the reason for the delay  if a leak is not repaired within 15
      calendar days after discovery of the leak.
	   The signature of the  owner or operator (or designate) whose decision it was that
      repair could not be effected without a process shutdown.
	   The expected date of successful repair of the leak if a leak is not repaired within 15
      calendar days after discovery of the leak.
	   The date of successful repair of the leak.
*   40 CFR 61.246(b) specifies tagging requirements for leaks of the above listed type.
    Select a few recently detected leaks to field check for proper tags and place them on
    the appropriate portion of the Equipment and Leak Identification Checklist.
** Are there any general  comments regarding the frequency and duration of delayed leak
    repairs?                           •
Comments:
                                       6-16

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                                  FIGURE 6-3

               IN-PLANT RECORDS CHECKLIST (CONTINUED^
40 CFR 61.246(d) - Does the plant have the following information pertaining to their
         t system and control device (CVSCD) in a permanent log?
closed vent system
	   Detailed  schematics,  design  specifications,  and  piping  and  instrumentation
      diagrams.

	   The dates and description of any changes in the design specifications.

	   A description of the parameter or parameters monitored  [see 61.242-ll(e)j to
      ensure that the control device is operated and maintained in conformance with its
      design and an explanation of why that parameter (or parameters) was selected for
      monitoring.

	   Periods when the CVSCD is not operated as designed. This includes periods when
      vents that should be controlled are bypassed to the atmosphere, a flare pilot does
      not have a flame, etc.

	   Dates of startups and shutdowns of the CVSCD.

*   A separate checklist  for control devices,  Figure 6-2 is attached to  gather the data
    needed to make a preliminary determination of whether the CVSCD conforms with
    the requirements or 40 CFR 61242-11. These requirements depend on whether the
    control device is a vapor recovery system, an enclosed combustion device, or a flare.

Comments:
40 CFR 61.246(i) - Does the facility have the following  information pertaining to
equipment  which is  exempt  from the  benzene NESHAP  [see 40  CFR 61.110(c)(l)]
recorded in a log?

	   An analysis demonstrating the design capacity of the process unit.

	   An analysis demonstrating that equipment is not in benzene service.

Comments:
                                     6-17

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                                  FIGURE 6-3

               IN-PLANT RECORDS CHECKLIST (CONTINUED)
40 CFR 61.246(e) - Does the plant have the following information pertaining to subject
equipment in a permanent log?

	   A list of identification numbers for equipment subject to the standard:

            Pumps [40 CFR 61.242-2]
            Compressors [40 CFR 61.242-3]
      	   Pressure relief devices in gas/vapor service [40 CFR 61.2424]
            Sampling connection systems [40 CFR 61.242-5]
      	   Open ended valves or lines [40 CFR 61.242-6]
      	   Valves [40 CFR 61.242-7]
            Pressure relief devices in liquid service, flanges  and other connectors [40
            CFR 61.242-8]
            Product accumulator vessels [40 CFR 61.242-9]
      	   CVSCD [40 CFR 61.242-11]

      A list of identification numbers for equipment designated to meet the "no detectable
      emissions" compliance option including the owner/operator's authorizing this
      designation:

           • Pumps [40 CFR 61.242-2(e)]
            Compressors [40 CFR 61.242-3(i)]
      	  Valves [40 CFR 61.242-7(f)]

      A list of identification numbers for pressure relief devices which are required  to
      meet the "no detectable emissions" standard [40 CFR 61.242-4(a)].

      The  dates  of each "no  detectable emissions" compliance  test,  including the
       background level measured during  each test and the maximum instrument reading
       measured at the equipment during each test.

             Pumps [40 CFR 61.242-2(i)
             Compressors [40 CFR 61.242-3(i)]
       	   Valves [40 CFR 61.242-7(f)]
       	   Pressure relief devices [40 CFR 6U42-4(a)]

       A list of identification numbers for equipment in vacuum service [which are exempt
 	   per [40 CFR 61.242-l(e)].

 Comments:
                                      6-18

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                                  FIGURE 6-3

               IN-PLANT RECORDS  CHECKLIST (CONTINUED^



40 CFR 61.246(f) - Does the plant have the following information in a permanent log?

	   A list of all  valves which are designated  "unsafe to monitor" as outlined in
      40 CFR 61.242-7(g).

      	   Valve identification numbers
      	   Explanation why each valve is unsafe to monitor
      	   A plan for monitoring each valve

      A list of all valves which  are  designated "difficult to monitor" as outlined in
      40 CFR 61.242-7(h).

      	   Valve identification numbers
      	   Explanation why each valve is difficult to monitor
      	   A plan for monitoring each valve

*   One or two of these valves may be field inspected to verify  that they are unsafe or
    difficult to monitor.

Comments:
40 CFR 61.246(g) - For valves complying with the "skip period leak detection and repair"
compliance option [see 40 CFR 61.243-2], does the plant have a permanent log containing:

	   A schedule for monitoring.
	   The percent of valves found leaking during each monitoring period.
40 CFR 61.246(h) - Pumps and compressors that are equipped with a dual mechanical seal
system pursuant to 40 CFR 61.242-2(d) or 40 CFR 61.242-3(a) must have sensors to detect
failure of the seal system, the barrier fluid system, or both.  The following information
should be in a permanent log regarding these types of pumps and compressors:

	    For  each pump,  the design criterion (or parameter  chosen to monitor) and an
       explanation of that criterion [40 CFR 6L242-2(d)(5)].

	    For each compressor, the design criterion (or parameter chosen to monitor) and an
       explanation ot that criterion [40 CFR 61242-3(e)(2)].
      	   Any changes to this criterion and the reasons for the changes.

Comments:
                                     6-19

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in logs.  The information contained in the control device checklist, Figure 6-4, may be used
to help inspectors evaluate control device compliance with 40 CFR 61.242-11.

      Examination  of  the  logs  may  also  reveal  noncompliance  due to  improper  or
inadequate recording procedures.   Facilities  are  in direct  noncompliance  under  the
following situations:

      o     failure to report leaks and dates of repairs
      o     failure to report the reason for delaying repair of leaks past an allotted time
             frame
      o     failure to develop a schedule to observe visual emissions from flares
      o     failure to perform emission testing for control devices (except in the case of
             flares)
      o     failure to record periods when the control device is not operating

      The in-plant  logs and records  should be examined for inconsistencies with  the
information presented to the regulatory agencies in the initial and semiannual reports (40
CFR 61.247).  Some  typical reporting inconsistencies are as follows:

      o     facilities records  leak  testing  and repair data in logs but fails to report
             information in semiannual reports
      o     facility records periods of noncompliance for control and vent systems but
             only reports results  of annual emission tests

      The following is a list of  questions the inspector should  be  able to answer at the
conclusion of the record inspection:

1)    Are in-plant records being properly kept and are semiannual  reports being properly
      submitted?
                                          6-20

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                                   FIGURE 6-4

                        CONTROL DEVICE CHECKLIST




What type of control device is used in the facility's CVSCD?


	   Vapor recovery (condensers, adsorbers, absorbers)

	   Enclosed combustion (incinerators, boilers)

	   Flares

*   Use the questionnaire/checklist below that is specific for the type of control device to
    gather data to assess compliance with 40 CFR 61.242-11.

Comments:
Vapor Recovery Systems 40 CFR 61.242-ll(b):

	   Compression/refrigeration, condensation

	   Adsorption (e.g. carbon bed filters)

	   Absorption (e.g. wet scrubbers)

Describe the control device and  the critical parameters which demonstrate compliance
(e.g. adsorber pressure drop/regeneration cycle time; scrubbing fluid flow rate/pressure
drop; final temperature leaving condenser). What is the claimed control device efficiency?
Is this efficiency measured (tested) or calculated?  Obtain a copy of these test results or
calculations.   What are  the critical  control device operating parameters during the
inspection (from the field or control room)?
                                         6-21

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                                  FIGURE 6-4

                 CONTROL DEVICE CHECKLIST CONTINUED
Enclosed Combustion Device 40 CFR 61242-ll(c):

	Incinerator

    Boiler
What is the claimed control device efficiency?  Is the efficiency measured (tested)  or
calculated?  Obtain  a  copy of any of these test results or  calculations.   What is the
combustion temperature during the inspection (from the field or control room)?
Flares 40 CFR 61.242-ll(d):

	  Steam Assisted

	  Air Assisted

	  Non-Assisted

During normal operation, what is net heating value and exit velocity of the flare gas? Is the
velocity and net heating value of the flare gas measured (tested) or calculated?  Obtain
copies of these test  results  and/or calculations.  Check the  flame  indicating device
(probably a thermocouple readout) in the field or control room  for proper operation.
Observe the flare for visible emissions.
                                         6-22

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2)     Is all equipment in the facility that should be subject to the standard being treated
       as such?

3)     Does  the facility's  closed  vent system and control  device  (CVSCD) meet the
       requirements of 40 CFR 61.242-11?

4)     When detected leaks are not repaired in  the required time frame, are the delays
       justifiable in accordance with the provisions of 40 CFR 61.242-10?

6.3.5   Closing Conference

       The closing conference is held with the facility personnel at the conclusion of the
record and  leak screening inspections. The  conference  is mainly designed to answer
questions  the facility may have, identify confidential information, and obtain last minute
details and  information in order to complete the mandatory inspection report.  The
inspector  should keep the closing  conference brief, refrain  from making  compliance
judgements and cover the following topics:

       o     Review of Inspection Data - identify and fill in any gaps in the data collected
             and clear up any inconsistencies concerning technical data.
       o     Discussion -  answer  any inspection-related  question  from the  facility
             personnel  but  politely  refrain  from  making  on-the-spot judgements
             concerning facility compliance or enforcement consequences.
       o     Declaration of Confidential Business Information - facility officials should be
             given the opportunity to make confidentiality claims on documents collected
             by the inspector.  It  is the inspector's responsibility to note all information
             claimed confidential  and handle the materials accordingly.

       As a  final note, it should be emphasized that it is the inspector's responsibility to
establish and maintain a working relationship with the facility. Offering or  suggesting
available resources such as technical guidelines, referring questions and concerns to other
EPA personnel and discussing problems and possible solutions will indicate to the facility a
professionalism that will reflect favorably on the inspector and the agency.
                                         6-23

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                             7.0 POST INSPECTION

      Upon completion of the compliance inspection, the inspector begins the final task of
determining facility compliance.  The facility data contained in the initial report, the
semiannual  reports, as well as results of the facility record review and the inspection
provide the inspector with  the information  to determine  facility compliance with the
regulations.   Additional  information, elaboration  or clarification  may  come  from the
inspector's field notebook.  The elements of the inspector's report, the overall facility
compliance  determination and the  handling of confidential business information are
presented in the following paragraphs.   Although each inspector and agency may use
somewhat different reporting format and confidential business information procedures, the
inspector must still present the findings and  support the compliance determination in a
clear, concise manner.

7.1   WRITING THE REPORT

      After returning from the inspection site, the inspector should begin preparing his
inspection report while all the events of the  inspection  are still fresh in his mind.  The
inspector should prepare  the  report before  he or she  conducts  another benzene leak
detection inspection.  When two or more inspections are done  at one time, it becomes
difficult to mentally separate one from another. Also, the inspector should call the facility
to clarify any item about which he or she is uncertain. The inspector's report organizes and
correlates all evidence gathered during the inspection into a concise and useable format.
The report  serves to record the procedures used in gathering the data,  gives  factual
observations and evaluations drawn in determining facility compliance with the NESHAP
regulations for benzene. The inspector's report will also  serve as part of the evidence for
any enforcement proceeding or compliance-related follow-up activities.

      The inspection results  are to  be organized in a comprehensive,  objective and
accurate report. In preparing an inspection report, confidential material  must be  treated
with care  and included only if relevant to the compliance  discussions.  A standardized
format for the inspector's report is recommended to enable accurate and efficient reviews.
In addition,  adopting a standardized reporting format emphasizes completeness through
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uniformity of data presentation, promotes better quality reporting procedures by inspectors
and is beneficial in correlating benzene 'leaks  with  noncompliance, thereby enhancing
speed of review and allowing prompt response concerning any necessary enforcement
proceedings. The recommended report elements are listed below:

      o     Introduction
      o     Compliance Status for Regulated Equipment
      o     Data
      o     Summary

      In the following paragraphs, each of these  topics will be covered in detail.

7.1.1 Introduction

      The introduction should include general information concerning the plant name and
address, the purpose of the investigation (benzene NESHAP), the time and date(s) when
the investigation was conducted and the names of facility personnel who accompanied the
investigator on the inspection.   Also, the introduction should contain  a brief process
description and identify the regulated portion of the facility.

7.1.2 Compliance Status for Regulated Equipment

      The compliance status of the  facility should  be addressed  in this section.   The
benzene inspection checklists discussed in Section 6, may be used to complete this section
of the report  The following summarizes the results of the benzene NESHAP inspection
which should be included in the inspector's report.

(1)   A thorough determination  of the source compliance  status according to  each
      applicable rule (40 CFR 61.241 through 61.242-11).

(2)   A general discussion addressing exemptions.

(3)   A summary of any alternative standards pursuant to 40 CFR 61.243 and 61.244.
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(4)   A discussion of the leak detection procedures conducted as described in 40 CFR
      61.245 and Reference Method 21.

(5)   A discussion of the record review or the reports, records and logs which must be
      submitted or maintained by the facility according to 40 CFR 61.246 and 61.247.

      The information should be arranged in a rule-by-rule format beginning with 40 CFR
61.242-1. Any regulations which are not applicable to the facility being investigated do not
need to be addressed.  Additionally, the report should identify  the method (i.e., visual
inspection, monitoring, record review, etc.)  which was  used to determine compliance.  In
the discussion sections, items 2-5, the inspector should attempt to elaborate and record all
relevant  observations  which may  otherwise  not be  documented,  however, all  of  the
information should be objective and factual. Any speculations or conclusions regarding the
ultimate result of factual findings should be reserved for the summary portion of the report.

7.1.2.1  Individual Source Compliance Status

      This section must address each of the following sources that are intended to operate
in benzene service: pumps, compressors,  pressure relief devices,  sampling connection
systems,  open-ended valves or lines, valves,  flanges and other  connectors, product
accumulator vessels and control devices or systems pursuant to 40 CFR 61.262-1, 61.242-2,
61.242-3, 61242-4, 61.242-5,61.242-6, 61.242-7,61.242-8, 61.242-9, 61.242-10 and 61.242-11.
The completed benzene inspection checklists, initial and semiannual  reports and copies of
in-plant logs may be used to determine compliance.  Any violation, whether it is procedural
or an excess emission, constitutes noncompliance. The following illustrates a typical report
format:

(1)   40 CFR 61.242-l(d) - Each piece of equipment in benzene service is tagged with a
      permanent metallic tag. Compliance  determined by visual observation.

(2)   40 CFR 61.242-2(a)(l) and 61.242-2(a)(2)  - All  pumps in  benzene service  are
      monitored on a monthly basis.  Each pump is visually inspected on a weekly basis.
      The company appears  to be hi compliance with  the requirements of this rule.
      Compliance determined by record review and discussions with facility personnel.
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(3)   40 CFR 61.242-4 - This facility has a total of nineteen  relief valves in benzene
      service.  They operate  with no detectable emissions (less than 500 ppm).  The
      company is aware of the requirements of this rule.  Compliance  determined by
      record review and monitoring.

7.1.2.2 Exemptions                     ;

      If the facility is claiming exemption(s) from the benzene NESHAP regulations, the
compliance status with respect to each exemption must be discussed. The current facility
operations and procedures should be compared to verify compliance with the exemption.

7.1.2.3 Alternative Standards

      If the facility has  requested and received permission to comply with one of the
alternative  standards for valves or and alternative method of emission limitation, the
inspector should discuss facility compliance with the alternative standard.  The inspector
should evaluate whether the facility owner  or operator understands  the  alternative
standard and performs  the necessary leak detection  monitoring and recordkeeping
required to  comply with the standard.  Deviations from any of the leak monitoring or
recordkeeping requirements of 40 CFR 61.243 constitute a violation.

7.1.2.4 Leak Detection Procedures

      The inspector's report should  include a section that discusses  the procedures
employed in the facility leak monitoring program.  The discussion should be brief and
emphasize those parts of the inspection in which deviations from established performance
criteria, calibration and leak monitoring procedures of Reference Method 21 are observed.
The  inspector should include comments regarding  the  portable   VOC. calibration
information i.e., dates of calibrations, instrument response factors, calibration precision
and instrument response time.  Any quality assurance procedures observed or performed
during the leak detection monitoring such as drift span checks, response check and zero gas
checks should be noted.  The inspector should also note whether the facility is operating
under normal conditions and capacity on the day of inspection.
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7.1.2.5 Reports and Recordkeeping

       This section  should present  succinct conclusions regarding the  accuracy and
completeness  of the facility's initial and  semiannual reports,  and all recordkeeping
requirements of 40 CFR 61.246 and 61.247. The inspector should check for computational
or statistical errors. The logs maintained by the facility should be reviewed with respect to
completeness. The inspector should clearly reference or include in the attachment portion
of the report,  any evidence which establishes  the  elements of the violation,  such as,
photocopies of logs which show leaks were not repaired in the allotted tune frame.  Any
violations observed during the record review portion of the inspection should already be
noted in the benzene inspection checklists.

7.1.3   Data

       Data to  determine the performance compliance  of the subject equipment including
results of spot leak checks, copies of monitoring records of control devices, visible emission
observations for flares and the inspector's completed benzene inspection checklists should
be  attached.   The  data  should  include  all  of the documents  which support any
noncompliance determination. The evidence should be adequate to establish the elements
of the violation as indicated by the results of the inspection.

7.1.4   Summary

       The summary should contain a brief overview of the inspection results, the overall
compliance status of the facility and a description of any  action taken as a result of the
investigation.  Although each agency may use somewhat different formats, the inspector
should be cautioned against presenting any conclusions  regarding violations in the body of
the report. Ideally, the summary section is completely separate from the rest of the report
and reserved for addressing facility violations. By placing the summary at the end of the
report, it is easier to exclude it when releasing the report to other governmental agencies or
if legal actions  are pending. If noncompliance results are juxtaposed with the applicable
performance  specification, interpretation and review  will be  greatly facilitated.   The
following example may be used:
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      During the inspection, the compliance status with all applicable National Emission
Standards for Hazardous Air Pollutants (NESHAP) regulations was investigated.  Records
and recordkeeping requirements  as well as leak monitoring procedures were reviewed.
The facility appears to be in compliance with these rules except the following:

(1)   40 CFR 61.245(b)(4)(ii) - The facility uses standard gas with 500 ppm benzene for
      calibration of portable VOC monitors. This constitutes a violation of NESHAP 40
      CFR 61.245(b)(4)(ii) which requires that for  calibration of VOC  monitors, a
      standard gas at a concentration of approximately, but not less than  10,000 ppm of
      methane or n-hexane be used.

(2)   40 CFR 61.242-2(a)(l) - The facility  has not conducted the monthly monitoring of
      pumps.  This constitutes a violation of NESHAP 40 CFR 61.242 (a)(l) which
      requires  that pumps be monitored for leaks on a monthly basis. The facility has
      conducted quarterly monitoring instead of monthly.

7.2   HANDLING  CONFIDENTIAL BUSINESS  INFORMATION

      Industry today is increasingly sensitive to agency use and disclosure  of confidential
business information.  The EPA established regulations governing  confidential business
information are covered under 40 CFR Part 2  Subpart B.  Because the inspector can be
held personally liable for disclosure, it is extremely important for all agencies performing
benzene equipment  leak  inspections  to adopt rules  and guidelines  for handling  and
releasing confidential business information.  From the  inspector's standpoint, confidential
business information is defined as information received under a request of confidentiality
which may concern or relate  to trade secrets, processes, operational data, style of work,
statistical data or financial data including amount of source of income, profits, losses or
expenditives. This information may exist in the written form,  in photographs or in the
inspector's memory.  Whenever possible,  confidential business  information should be
referenced in a nonconfidential manner.  For example,  the inspector may simply refer to a
document in the confidential files but present only a  general description of the referenced
document in his or her inspection report,;thereby minimizing the risk of exposure.  At all
times, confidential business information  should be kept in a secure, lockable file cabinet
expressly dedicated  for confidential information, and precautions should  be made to
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safeguard the confidential data.  If confidential business information must be included in
the inspector's report, the entire report must be treated as a confidential document.
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                             REFERENCES

1.     Perry, John  H.  Chemical  Engineers' Handbook.  Robert Perry,  Cecil
      Chilton, Sidney Kirkpatrick, eds.  McGraw-Hill Book Company. New York
      1963.

2.     U.S. Environmental Protection Agency.   Benzene Fugitive  Emissions -
      Background  Information for Proposed  Standards.  EPA 450/3-80-032a.
      November 1980.

3.     U.S. Environmental Protection Agency.   Air  Pollution  Training Institute
      Course SI:417 Controlling VOC Emissions from Leaking Process Equipment
      - Student Guidebook. EPA 450/2-82-015 August 1982.
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