xvEPA
United States
Environmental Protection
Agency
INSPECTION TOOL FOR THE
MISCELLANEOUS ORGANIC CHEMICAL
MANUFACTURING NESHAP
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EPA-305-B-06-002
September 2006
Inspection Tool for the Miscellaneous
Organic Chemical Manufacturing
NESHAP
Prepared for:
Air Compliance Branch
Compliance Assessment and Media Programs Division (CAMPD)
Office of Compliance (OC)
Office of Enforcement and Compliance Assurance (OECA)
U.S. Environmental Protection Agency
Washington, DC 20460
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Disclaimer
The statements in this document are intended solely for compliance assistance. This document
is to be used in conjunction with the regulations, not in place of them. It is not intended, nor
can it be relied on, to create any rights enforceable by any party in litigation with the United
States. The U.S. Environmental Protection Agency (EPA) and State officials may decide to
follow the guidance provided in this document, or to act in variance with it, based on analysis
of specific site circumstances. This guidance may be revised without public notice to reflect
possible rule changes and changes in EPA's policy.
Please be aware that EPA has made its best effort to present an accurate summary of the
regulatory requirements in the miscellaneous organic chemical manufacturing NESHAP as
promulgated on November 10, 2003, and amended on July 1, 2005, March 1, 2006, and
July 14, 2006. Note that it is not intended to summarize every option and detail of the rule.
Finally, in the event that there are typing errors or deviations from the final rule, the final rule
stands.
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Table of Contents
Table of Contents
Page
Section
1.0 Background and Purpose of this Document 1-1
1.1 How to Use the Checklists 1-1
1.2 Preparing the Inspection 1-3
2.0 General Applicability 2-1
3.0 Process Vents 3-1
4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers 4-1
5.0 Wastewater Systems 5-1
6.0 Equipment Leaks 6-1
7.0 Transfer Racks 7-1
8.0 Heat Exchange Systems 8-1
9.0 Closed-Vent Systems 9-1
10.0 Control Device and Recovery Device Checklists 10-1
11.0 Alternative Standard 11-1
12.0 Reporting 12-1
Appendix A Questions and Answers on Provisions in Subpart FFFF A-l
Appendix B Definitions in Subpart FFFF B-l
Appendix C Summary of Initial Compliance Requirements for Process Vents and
Monitoring Requirements for Various Types of Vent Streams C-l
Appendix D Inspection and Monitoring Requirements for Waste Management Units as
Specified in Table 11 to 40 CFR Part 63, Subpart G D-l
Appendix E Control Equipment Failures for Waste Management Units E-l
in
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Table of Contents
List of Figures
Figure Page
2-1 Subpart FFFF applicability on a facility basis 2-3
2-2 Subpart FFFF applicability for miscellaneous organic chemical manufacturing processes .... 2-5
3-1 Applicability for continuous process vents 3-3
3-2 Applicability for batch process vents 3-6
3-3 Emission limits and work practice standards for organic F£AP emissions
from batch or continuous process vents 3-8
3-4 Applicability and control requirements for hydrogen halide and halogen F£AP emissions
from process vents 3-9
3-5 Applicability and control requirements for hydrogen halide and halogen F£AP emissions
from process vents at new sources 3-10
4-1 Applicability for storage tanks, surge control vessels, and bottoms receivers 4-2
4-2 Emission limits for Group 1 storage tanks, surge control vessels, and bottoms receivers 4-4
5-1 Applicability for wastewater 5-2
5-2 Applicability of process or maintenance wastewater 5-4
5-3 Determination of group status for process wastewater streams 5-6
5-4 Emission suppression requirements for waste management units 5-7
5-5 Exception to emission suppression requirements 5-7
5-6 Requirements for wastewater tanks 5-9
5-7 Treatment requirements for process wastewater streams 5-10
5-8 Applicability for process equipment that manages liquid streams in open systems within
an MCPU 5-11
6-1 Applicability and requirements for equipment leaks 6-2
6-2 Flowchart of monitoring frequencies for connectors in gas/vapor service or light liquid
service under subpart UU and the CAR 6-4
7-1 Applicability for transfer racks 7-2
7-2 Emission limits and work practice standards for Group 1 transfer racks 7-3
8-1 Applicability and work practice standards for heat exchange systems 8-2
11-1 Alternative standard for process vents or storage tanks 11-1
List of Tables
Table Page
2-1 Options to Minimize Overlapping Requirements Between Subpart FFFF and Other Rules . . . 2-6
3-1 Inspection Checklist for Controlling Organic HAP Emissions from Continuous Process
Vents that Are Subject to Subpart FFFF 3-11
3-2 Inspection Checklist for Controlling Organic HAP Emissions from Batch Process Vents
in a Process Subject to Subpart FFFF 3-14
3-3 Compliance Checklist for Group 2 Batch Process Vents 3-17
3-4 Inspection Checklist for Controlling Hydrogen Halide and Halogen HAP Emissions from
Process Vents Within Processes that Are Subject to Subpart FFFF 3-19
3-5 Compliance Checklist for Processes with Hydrogen Halide and Halogen HAP Emissions
From All Process Vents Less than 1,000 Ib/yr 3-20
3-6 Inspection Checklist for Controlling HAP Metals Emissions from Process Vents Within
Processes at New Sources that Are Subject to Subpart FFFF 3-21
IV
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Table of Contents
4-1 Inspection Checklist for Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Subject to Subpart FFFF 4-5
4-2 Compliance Checklist for a Group 1 Storage Tank with an External Floating Roof 4-7
4-3 Compliance Checklist for a Group 1 Storage Tank with an Internal Floating Roof 4-13
4-4 Compliance Checklist for Group 1 Storage Tanks Equipped with a Control Device 4-18
4-5 Compliance Checklist for Storage Tanks Using Vapor Balancing 4-19
4-6 Alternative Standard Checklist 4-21
5-1 Inspection Checklist for Wastewater Streams and Residuals Subject to Subpart FFFF 5-13
5-2 Applicable Checklists for Emission Suppression Options for Waste Management Units .... 5-14
5-3 Compliance Checklist for Inspections of Wastewater Tanks for Improper Work Practices
and Control Equipment Failures 5-16
5-4 Compliance Checklist for Inspections of Surface Impoundments for Improper Work
Practices and Control Equipment Failures 5-18
5-5 Compliance Checklist for Inspections of Containers for Improper Work Practices and
Control Equipment Failures 5-20
5-6 Compliance Checklist for Inspections of Individual Drain Systems for Improper Work
Practices and Control Equipment Failures 5-22
5-7 Compliance Checklist for Inspections of Oil-Water Separators for Improper Work
Practices and Control Equipment Failures 5-25
5-8 Compliance Checklist for Inspection of Covers, Enclosures, and Fixed Roofs for Leaks .... 5-29
5-9 Checklist for Compliance with Alternative Requirements for Wastewater that Is Group 1
Only for Soluble HAP 5-31
5-10 Compliance Checklist for Steam Strippers 5-32
5-11 Compliance Checklist for Treatment Processes Other than Steam Strippers 5-34
5-12 Compliance Checklist for Equipment Handling In-Process Liquid Streams 5-35
6-1 Checklist to Demonstrate Compliance with the Basic LDAR Program 6-5
6-2 Checklist for Determining Compliance with the Pressure Testing Alternative Standard 6-15
6-3 Checklist for Determining Compliance with the Enclosed Process Alternative 6-17
7-1 Inspection Checklist for Controlling Organic HAP Emissions from Transfer Racks that
Are Subjectto Subpart FFFF 7-4
8-1 Compliance Checklist for Heat Exchange Systems Requiring Leak Detection 8-3
9-1 Compliance Checklist for Bypass Line Provisions for Closed-vent Systems 9-2
9-2 Compliance Checklist for Closed-Vent Systems 9-4
10-1 Compliance Checklist for Flares 10-3
10-2 Compliance Checklist for Thermal Incinerators 10-5
10-3 Compliance Checklist for Catalytic Incinerators 10-9
10-4 Compliance Checklist for a Boiler or Process Heater with a Design Heat Input Capacity
Less than 44 Megawatts and the Vent Stream Is Not Introduced with the Primary Fuel . . . . 10-14
10-5 Compliance Checklist for a Boiler or Process Heater with a Design Heat Input Capacity
Greater than 44 Megawatts or the Emission Stream is Introduced with the Primary Fuel . . . 10-18
10-6 Compliance Checklist for a Regenerative Carbon Adsorber Used as a Control Device or
Recovery Device 10-19
10-7 Compliance Checklist for an Absorber Used as a Control Device or Recovery Device
and the Scrubbing Fluid Is Anything Other than Water 10-23
10-8 Compliance Checklist for a Condenser Used as a Control Device or Recovery Device .... 10-28
10-9 Compliance Checklist for a Control Device or Recovery Device Not Specifically Listed . . 10-33
10-10 Compliance Checklist for a Scrubber Used as a Control Device or an Absorber that
Uses Water as the Scrubbing Fluid 10-35
10-11 Compliance Checklist for Biofilters 10-39
10-12 Compliance Checklist for Fabric Filters 10-42
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Table of Contents
11-1 Checklist to Demonstrate Compliance with Continuous Emissions Monitoring
Requirements 11-2
11-2 Checklist for Parameter Monitoring Option for Scrubbers Used to Reduce Hydrogen
Halide and Halogen HAP Emissions Under the Alternative Standard 11-4
12-1 Inspection Checklist for Notification of Compliance Status Report 12-2
12-2 Inspection Checklist for Compliance Reports 12-7
VI
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List of Acronyms
List of Acronyms
ADI Applicability Determination Index
AMR actual mass removal
BR bottoms receiver
CAR Consolidated Federal Air Rule
CEMS continuous emissions monitoring system.
CFR code of federal regulations
CMS continuous monitoring system
CPMS continuous parameter monitoring system.
CVS closed vent system
DOT U.S. Department of Transportation
EFRs external floating roofs
EPA U.S. Environmental Protection Agency
Fblo fraction biodegraded
HAP hazardous air pollutant.
HON hazardous organic NESHAP
IFRs internal floating roofs
LDAR leak detection and repair
MACT maximum achievable control technology
MCPU miscellaneous organic chemical manufacturing process unit
MON miscellaneous organic NESHAP
MTVP maximum true vapor pressure
NAICS North American Industry Classification System
NESHAP national emission standards for hazardous air pollutants
NPDES National Pollution Discharge Elimination System
OLD organic liquid distribution
P2 pollution prevention
PAI pesticide active ingredient
POD point of determination
PMPU pharmaceutical manufacturing process unit
PRO pressure relief devices
PSHAP partially soluble HAP
PUG process unit group
PTE potential to emit
QIP quality improvement program
RCRA Resource Conservation and Recovery Act
R&D research and development
RMR required mass removal
SCV surge control vessel
SHAP soluble HAP
SSM startup, shutdown, and malfunction.
SSMP startup, shutdown, and malfunction plan
TOC total organic compounds
TRE total resource effectiveness
VOC volatile organic compound
VOHAP volatile organic HAP
WMUs waste management units
vn
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List of Acronyms
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Vlll
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1.0 Introduction
1.0 Background and Purpose of this Document
This inspection tool is consistent with the promulgated national emission standards for hazardous
air pollutants (NESHAP) for miscellaneous organic chemical manufacturing (i.e., miscellaneous organic
NESHAP, or MON). The final rule was published in the Federal Register on November 10, 2003 (68 FR
63852), and it is located in 40 CFR part 63, subpart FFFF. Final amendments were published on July 1,
2005 (70 FR 38554), March 1, 2006 (71 FR 10439), and July 14, 2006 (71 FR40316).
The purpose of this document is to assist federal, state, and local regulatory personnel with
enforcement of the process vent, storage tank, wastewater, equipment leak, transfer operation, and heat
exchange system provisions in subpart FFFF. The alternative standard for process vents and storage
tanks is also included, but the emissions averaging and pollution prevention options are not. A chapter
also covers the requirements for the notification of compliance status report and compliance reports.
Most chapters include flowcharts that are designed to assist the user in identifying applicability for a
particular emission stream. Flowcharts also identify available control options for emission streams that
meet particular applicability criteria. Each chapter also includes inspection checklists to determine
compliance with the applicable requirements.
The next two sections in this chapter give a brief overview of how to use the checklists and steps
to take in preparation for an inspection.
1.1 How to Use the Checklists
The checklists in this inspection tool are flexible, and suitable for several different approaches to
examining a facility. These checklists may be used singularly or in combination at a facility where the
user is seeking compliance information on a specific emission point or points, or the user may proceed
through the entire group of checklists, section by section, if the approach to examining a facility begins
with the initial question of whether there is a miscellaneous organic chemical manufacturing process unit
(MCPU) at the facility that must comply with subpart FFFF.
If a user chooses to proceed through this document sequentially, the most logical starting point is
to determine which facilities and MCPUs are subject to subpart FFFF. This can be done with the
flowcharts in Section 2. Once the process unit applicability is established (either through the flowcharts
1-1
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1.0 Introduction
in Section 2 or by prior knowledge), the user can move on to the flowcharts and checklists in Section 3 to
determine which emission streams from process equipment are continuous or batch process vents, the
thresholds for control of organic HAP and/or hydrogen halide and halogen HAP (i.e., the group status of
process vents), and the emission limits and compliance requirements for the different types of process
vents. Sections 4 through 8 provide similar information for storage tanks, wastewater systems, equipment
leaks, transfer operations, and heat exchange systems. The checklists in some of these sections also refer
to checklists in Section 9 for closed-vent systems, Section 10 for control devices, and Section 11 for the
alternative standard.
Alternatively, individual checklists may be used to examine only certain types of emission points
at a facility or specific types of control devices. For example, a user may need to know only about the
compliance status of process vents at a facility. In this case, the user would be able to visit the facility
and conduct an inspection by taking only the checklists in Section 3 for process vents, Section 9 for
closed-vent systems, and Section 10 for control devices (and possibly Section 11 for the alternative
standard). If the inspector knows the specific control and/or recovery devices being used, the inspector
could take just the checklists for those specific devices (and the checklists for closed-vent systems).
Section 12 includes checklists for the notification of compliance status report and compliance reports. An
inspector may want to inspect the most recent compliance report to make sure all required information is
included. Another instance in which the user benefits from the flexibility of these checklists occurs when
a specific control device or recovery device must be examined for compliance. For example, if the user
has to examine only one device, such as a thermal incinerator for Group 1 batch process vents, then it is
only necessary to take the checklist from Table 10-2.
These examples illustrate the flexibility of the checklists for use at a variety of inspection sites
and to meet the needs of various approaches to inspecting for compliance at the site. Hence, an inspector
may have little or no information about a facility and benefit from using all of the checklists together in
order to determine compliance. Alternatively, if only specific emission points and control devices need
inspection, the user can selectively apply the applicable checklists as necessary.
A "yes" response to a question in any checklist means compliance with that specific requirement,
and a "no" response means noncompliance with the requirement. For most questions an "N/A" box is
also provided in case a question is not applicable at a particular facility. For example, subpart FFFF
provides several monitoring options for catalytic incinerators. When asking if an applicable monitoring
device is present and operating, the checklist in Table 10-3 has a separate question for each type of
device. This way the inspector can check the N/A box for the types of devices that are not in use. An
advantage of separate questions over a single question is that it is clear which device a particular facility
is using. Similarly, numerous questions ask if specific information is recorded for inspections when a
1-2
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1.0 Introduction
leak or some other failure is detected. However, if a failure has never been detected, the only appropriate
response to the question is to indicate that it is not applicable.
1.2 Preparing the Inspection
Compliance with subpart FFFF can be determined by review of records and reports, review of
performance tests, and visual inspections using the methods and procedures specified in the rule. As
required by the rule, testing, monitoring, and inspections are to be carried out by the owner or operator,
with records kept for 5 years. Therefore, the local, state, or federal inspector can determine compliance
by a review of plant records, along with spot inspections to verify the operation, performance, and
condition of the control equipment.
Prior to conducting the inspection, the inspector should become familiar with the regulation,
search the EPA, state, or local agency files for information on the facility, and review all relevant
information. Subpart FFFF requires each facility that is subject to the regulation to prepare "operating
scenarios" for each MCPU that specify the emission points, the type of control that is applied to each
emission point, and the monitoring procedures. The operating scenarios must be submitted in the
notification of compliance status report (or compliance reports for processes that start operation after the
compliance date). These operating scenarios would be a good place to start the inspection. This material
can be reviewed along with the applicability requirements of subpart FFFF (see flowcharts for MCPUs in
Section 2 and group status flowcharts in chapters 3 through 8) in order to identify any applicability
concerns or questions the inspector may have. In reviewing the determination of group status, focusing
on the determination of Group 2 status may be the best use of time because the Group 1 emission points
will be controlled (unless the facility is emissions averaging, which is not covered in this document).
Appendices A through C to this document also contain information that an inspector may wish to review.
Appendix A contain questions from industry on applicability and other compliance issues along with EPA
answers. Appendix B contains definitions of terms from §63.2550(i) of subpart FFFF. Appendix C
contains flow charts that summarize initial compliance requirements for process vents and monitoring
requirements for vent streams that are routed to control devices or recovery devices. Another source of
information that may help clarify applicability and other issues is the Applicability Determination Index
(ADI) at http://www.epa.gov/compliance/assistance/applicability/index.html. Although the responses to
inquiries in the ADI are directed to the specific source that submitted an inquiry, the same situation may
exist at other sources.
The inspector can also use the operating scenarios (or a title V permit application) to develop a
list of control devices to inspect. The most recent compliance report should provide information on the
1-3
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1.0 Introduction
facility's compliance status. A review of files will help the inspector become familiar with the operaton
of the facility and the most recent compliance history. The compliance history and prior inspections will
help the inspector prioritize areas of concern for the upcoming inspection. For example, if a leaking tank
roof was identified in the last inspection, the inspector would want to check the facility records to verify
that the tank roof was repaired in the allotted amount of time. The inspector may also want to visually
inspect the tank to verify that it has been repaired.
The inspector may also need to gather safety and emissions detection equipment prior to the
inspection. Some facilities will require inspectors to wear hard hats, safety glasses, and steel-toed shoes
during their visual inspection. If the inspector will need to do any climbing to inspect equipment such as
a tank roof, additional safety equipment may be necessary. If an inspector feels that it is necessary to
enter a storage vessel, please be aware of the requirements under EPA Order 1440.2, and the safety
information in Guidance on Confined Space Entry in NESHAP Inspections of Benzene Storage Vessels
(EPA 455/R-92-003, September 1997). The inspector will also need a portable VOC analyzer to conduct
Method 21 tests, and uniform probes for measuring gaps in storage tank roofs.
Because the review of records is the primary means of determining compliance, the local, state, or
federal inspector should notify the facility management prior to the inspection. This gives the facility
personnel enough time to gather relevant records and have them organized and available for review. The
facility should also provide a map and/or process flow diagrams to the inspector.
The inspection consists of a review of records and reports kept by the plant, and a visual
inspection of plant equipment. The checklists in this document will allow an inspector to systematically
review the plant records and reports. Each checklist provides a series of questions with expected
responses of yes or no. A "yes" response to a question means compliance with that requirement, and a
"no" response means noncompliance with the requirement. The inspector should copy the applicable
checklists prior to each inspection.
Inspectors should conduct visual inspections to verify that the records and reports provided by the
facility are accurate. Visual inspections will also enable the inspector to assess the condition of the
control equipment. When making visual inspections, the checklists, along with plant drawings and
specifications, should be used. Notations should be made on the checklists if there are discrepancies
between the plant records and reports and the visual inspections. Control equipment should be checked
for obvious leaks and lack of maintenance.
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2.0 General Applicability
2.0 General Applicability
Subpart FFFF of part 63, national emission standards for hazardous air pollutants (NESHAP) for
miscellaneous organic chemical manufacturing (commonly referred to as the miscellaneous organic
NESHAP [MON]) was promulgated on November 10, 2003. Amendments were published on July 1,
2005, March 1, 2006, and July 14, 2006. The compliance date for existing sources is May 10, 2008. The
affected source is the collection of equipment that manufactures a range of miscellaneous organic
materials or families of materials that are described by a number of NAICS codes as products or isolated
intermediates. Equipment is part of the affected source when a MON product is being produced, and the
equipment is not part of the affected source when non-MON products are being produced or if the
equipment is already part of another part 63 affected source. In identifying the affected source
(Figure 2-1) each product or family of materials produced at a facility must be evaluated (Figure 2-2) to
see if the process meets the criteria for being a MON process. If so, the equipment used to produce that
product or isolated intermediate comprises a Miscellaneous Organic Chemical Manufacturing Process
Unit (MCPU), and the collection of all MCPUs, associated heat exchange systems, wastewater and waste
management units comprise the subpart FFFF affected source.
The MON will generally regulate emission sources in organic chemical manufacturing that are
not regulated under other MACT standards. Because the MON's compliance date is later than most other
chemical industry standards, it is the "catch all" MACT standard for miscellaneous organic chemical
processes that have not been regulated under earlier standards. Therefore, an organic chemical
manufacturing process that is not part of another affected source but is located at a major source that uses,
generates, or processes HAP will most likely be subject to the MON. The MON will also cover solvent
recovery processes and formulation processes that have previously been excluded from other MACT
standards, such as the hazardous organic NESHAP (HON) (which excluded batch vents and sources with
only HAP solvent emissions from its affected source) and the PAI MACT (which specifically excludes
formulation operations).
Because some of the processes that are subject to the MON are run in non-dedicated equipment
that may also be used to produce products that are subject to other part 63 standards (e.g., the
Pharmaceuticals Production NESHAP in subpart GGG and the Pesticide Active Ingredient Production
NESHAP in subpart MMM), the MON includes provisions in §63.2535(1) that allow an owner or operator
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2.0 General Applicability
to determine one rule that can be applied to all of the processes in the multipurpose equipment. If an
owner or operator elects to comply with these provisions, it is possible that a process making materials
meeting the characteristics specified in §63.2435(b)(l) may comply with subpart MMM or subpart GGG,
or vice versa. If implementing these provisions, the owner or operator must also include information
documenting the determination of which rule will apply to all processes run in the equipment in the
notification of compliance status report. Examples illustrating how these provisions may be applied are
presented in the EPA document Compliance Assistance Tool for Pharmaceutical Production, Pesticide
Active Ingredient Production, and Miscellaneous Organic Chemical Manufacturing NESHAP:
Comparison of Regulatory Requirements and Case Study Compliance Illustrations for Nondedicated
Equipment (EPA 305-B-04-001, February 2004).
In addition to the provisions designed to minimize overlapping requirements for non-dedicated
processing equipment, subpart FFFF also includes provisions designed to minimize overlap with other
rules that apply to the same equipment or emission point. For example, a storage tank or reactor may be
subject to new source performance standards as well as subpart FFFF. Other provisions are designed to
minimize the burden of complying with slightly different requirements for process units in different
source categories at a facility. For example, equipment leak and wastewater requirements in subparts
GGG and MMM for Pharmaceuticals Production and Pesticide Active Ingredient Production,
respectively, are similar to the requirements in subpart FFFF. An inspector needs to be aware that some
of the checklists in other sections of this document may need to be modified when a facility complies with
provisions in a different rule as allowed by some of these overlapping provisions. Table 2-1 summarizes
the provision in subpart FFFF that minimize the burden of complying with overlapping and related
requirements.
2-2
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2.0 General Applicability
No rec|y
~* *
Figure 2-1. Subpart FFFF applicability on a facility basis.
2-3
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2.0 General Applicability
===(^0====
TN* facility a
\
1
/
Yas
Figure 2-1. (continued)
2-4
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2.0 General Applicability
Tn» m a
manufacturing
Figure 2-2. Subpart FFFF applicability for miscellaneous organic
chemical manufacturing processes.
2-5
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Table 2-1. Options to Minimize Overlapping Requirements Between Subpart FFFF and Other Rules
If the MON affected source...
Then, the facility..
According to this
section of subpart
FFFF...
has a storage tank that is also subject to either
40 CFR part 60, subpart Kb, or 40 CFR part
61, subpart Y
may elect to:
• control emissions using a floating roof in accordance with subpart Kb
or Y to demonstrate compliance with subpart FFFF; or
• control emissions using a fixed roof, closed-vent system, and control
device in accordance with subpart Kb or Y, and comply with
monitoring, recordkeeping, and reporting requirement in subpart
FFFF; or
• comply with the requirements for Group 1 storage tanks in subpart
FFFF to demonstrate compliance with all rules.
§63.2535(c)
is at a facility that has a process unit with
equipment subject to 40 CFR part 63, subpart
I, GGG, or MMM
may elect to comply with the equipment leak requirements in subpart H,
GGG, or MMM (whichever applies to a non-MON process unit at the
facility) for all equipment in MCPUs at the facility.
§63.2535(d)
has equipment that is also subject to 40 CFR
part 60, subpart VV or 40 CFR part 61, subpart
V
may elect to comply only with the equipment leak requirements in §63.2535(k)
subpart FFFF for all of the equipment.
has equipment to which the equipment leak
requirements in subpart FFFF do not apply,
but which are subject to 40 CFR part 60,
subpart VV, or 40 CFR part 61, subpart V
may elect to comply only with the equipment leak requirements in
subpart FFFF for all of the equipment, except that all total organic
compounds, minus methane and ethane, must be considered as if they
are organic F£AP.
§63.2535(k)
Kj
is at a facility that also generates wastewater
streams that meet the applicability threshold in
§63.1256 of 40 CFR part 63, subpart GGG
(Pharmaceuticals Production)
may elect to comply only with subpart FFFF for all of the wastewater §63.2535(e)
streams.
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If the MON affected source...
Then, the facility...
According to this
section of subpart
FFFF...
is at a facility that also generates wastewater
streams that meet the applicability threshold in
§63.1362(d) of 40 CFRpart 63, subpart MMM
(Pesticide Active Ingredient Production)
may elect to comply only with subpart FFFF for all of the wastewater
streams, except that the 99 percent reduction requirement for streams
subject to §63.1362(d)(10) still applies.
§63.2535(f)
has a Group 1 or Group 2 wastewater stream
that is also subject to 40 CFR 61.342(c)
through (h) in the benzene waste operations
NESHAP (subpart FF), and is not exempt
under 40 CFR 61.342(c)(2) or (3)
may elect to comply only with the requirements for Group 1 wastewater
streams in subpart FFFF.
§63.2535(j)
has a Group 2 wastewater stream that is
exempted from 40 CFR 61.342(c)(l) by 40
CFR61.342(c)(2)or(3)
may elect to comply only with the reporting and recordkeeping
requirements for Group 2 wastewater streams in subpart FFFF (exempt
from 40 CFR part 61, subpart FF).
§63.2535(j)
has a Group 1 wastewater stream that is also
subject to 40 CFR parts 260 through 272
may elect to determine whether subpart FFFF or 40 CFR parts 260
through 272 contain the more stringent control, testing, monitoring,
recordkeeping, and reporting requirements; and
comply with the provisions in 40 CFR parts 260 through 272 that are
determined to be more stringent than the requirements of subpart
FFFF to demonstrate compliance with subpart FFFF.
§63.2535(g)
contains processing equipment that is also
subject to 40 CFR part 60, subpart ODD, III,
NNN, orRRR
may elect to comply only with subpart FFFF for all of the equipment.
§63.2535(h)
Kj
contains processing equipment that is not
subject to subpart FFFF, but is subject to 40
CFR part 60, subpart ODD, III, NNN, or RRR
may elect to comply only with the requirements from Group 1 process
vents in subpart FFFF for the equipment, except that all total organic
compounds, minus methane and ethane, must be considered as if they
are organic HAP.
§63.2535(h)
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If the MON affected source...
Then, the facility...
According to this
section of subpart
FFFF...
has an MCPU that includes a batch process
vent that is also part of a CMPU under the
RON
must comply with the emission limits, operating limits, work practice
standards, and the compliance, monitoring, recordkeeping, and
reporting requirements for batch process vents in subpart FFFF; and
must continue to comply with the requirements in subparts F, G, and
H of the HON that are applicable to the CMPU and associated
equipment.
§63.2535(a)(l)
has a Group 1 transfer rack that is also subject
to 40 CFR part 61, subpart BB
may elect to comply only with the provisions of subpart FFFF.
§63.2535(i)(l)
§63.2535(i)(2)(i)
has a Group 2 transfer rack that is also subject
to control requirements specified in §61.302 of
40 CFR part 61
may elect to comply with either the requirements in 40 CFR part 61,
subpart BB, or the requirements for Group 1 transfer racks under subpart
FFFF.
has a Group 2 transfer rack that is also subject
to the recordkeeping and reporting
requirements in 40 CFR part 61, subpart BB
may elect to comply only with the recordkeeping and reporting
requirements in subpart FFFF for Group 2 transfer racks (exempt from
reporting and recordkeeping under subpart BB).
§63.2535(i)(2)(n)
has a control device that is used to comply
with subpart FFFF and is also subject to either:
• monitoring, recordkeeping, and reporting
requirements in 40 CFR part 264, subpart
AA, BB, or CC; or
• monitoring and recordkeeping requirements
in 40 CFR part 265, subpart AA, BB, or CC
and the periodic reporting requirements
under 40 CFR part 264, subpart AA, BB, or
CC that would apply if the facility had final
permitted status
may elect to comply with either:
• the monitoring, recordkeeping, and reporting requirements of subpart
FFFF; or
• the monitoring and recordkeeping requirements in 40 CFR part 264
or 265 and the reporting requirements in 40 CFR part 264. These
reports must include the information described in §63.2520(e).
§63.2535(b)
Kj
-------
According to this
section of subpart
If the MON affected source... Then, the facility... FFFF...
includes one or more MCPU that operate in • may elect to develop a process unit group (PUG) consisting of §63.2535(1)
nondedicated equipment that is used to make MCPUs and other process units that share processing equipment; and
MON materials and material in other source • for all process units in the PUG, comply with the NESFIAP that
categories applies to the material that is determined to be the primary product
for the PUG, provided the primary product is material subject to
subpart GGG, MMM, or FFFF. (If the primary product is material
that is subject to another NESHAP, the PUG concept does not
minimize overlapping requirements.)
Kj
-------
2.0 General Applicability
[This page intentionally left blank]
2-10
-------
3.0 Process Vents
3.0 Process Vents
This section contains applicability and control flowcharts and inspection checklists for controlling
HAP emissions from process vents. Use Figures 3-1 and 3-2 to determine if a vent from a process unit
operation is a continuous process vent or a batch process vent, respectively. These flowcharts also can be
used to determine the group status of process vents. Figure 3-3 identifies the available compliance
options for organic F£AP emissions from Group 1 continuous process vents and Group 1 batch process
vents. Use Figure 3-4 to determine if hydrogen halide and halogen F£AP must be controlled and the
available compliance options for these emissions. Use Figure 3-5 to determine if F£AP metals must be
controlled and the compliance requirements for these emissions.
Use the checklist in Table 3-1 to document the identity, group status, and applicable control
option of a continuous process vent. This checklist also points you to checklists in other sections for
determining compliance with the applicable requirements for the Group 1 vent. If the vent is a Group 2
continuous process vent, the checklist in Table 3-1 allows you to document the TRE level and indicate
whether the TRE was determined after a recovery device. If the TRE is maintained within a specified
range by a recovery device, the checklist points you to other checklists for determining compliance with
applicable monitoring requirements. Finally, the checklist in Table 3-1 includes a question to determine
compliance with notification requirements for vents that change from Group 2 to Group 1.
Use the checklist in Table 3-2 to document the group status and control technique(s) for the
collection of batch process vents within a process. This checklist also points you to checklists in other
sections for closed-vent systems, applicable add-on control devices, and the alternative standard. It also
points you to the checklist in Table 3-3, which may be used to determine compliance for Group 2 batch
process vents. Finally, the checklist in Table 3-2 includes a question to determine compliance with
general recordkeeping requirements for Group 1 batch process vents.
Use the checklist in Table 3-4 to document the control technique(s) for all of the process vents
within a process that emit hydrogen halide and halogen HAP and to determine compliance with general
recordkeeping requirements for such process vents. This checklist also points you to checklists in other
sections for closed-vent systems, applicable add-on control devices, and the alternative standard. Use the
checklist in Table 3-5 to determine compliance for process vents that fall below the threshold for control
of hydrogen halide and halogen HAP emissions.
3-1
-------
3.0 Process Vents
Use the checklist in Table 3-6 to document the control technique for all of the process vents
within a process at a new source that emits HAP metals. This checklist also points you to a checklist in
Section 10 for the control devices used to comply with the emission limit.
3-2
-------
3.0 Process Vents
Use this flowchart for each point of cischarge to the atmosphere {or
point of entry into a control device, if any) from an fv'CPU thai is of
an affected source uncer subpart lv F F F° ard 1.5 not any of She following:*
a storage tank vent (see Figure 4-1)
a bottoms ffiesivw vent (see Figure 4-1)
a surge control vessel vent (see Figure 4-1)
a transfer operation vent (see Figure 6-1)
a waste mgnricernejit unil vent (sees Figure 5-1)
a leak from equipment subject la st;bparl H csr UU (see Figure '
Yes
A
••'* Does some ~"\
or all of the gas stream "\_
from a continuous operationi"""--.^
fsote that the gas stream may through a
recovery device or a device that recovers only
mechanical energy from the gas stream
""\ before discharge to the atmosphere _,-<••*
"v\_ or before entering __..,-"''
"*\_ a control _,--"'"
v\ device. ,*•''
Y«s
— i
the
or all of the
a
of the
WCPU?
_/*'' Does the gas \
_..,-••'' stream contain > 0.005 \,
' weight percent total organic HAP
at the point of discharge (or the
\_ point of entry to a control _/
"""--.,, device, if any)? ..,--'*
Yes
If Lh8 gas aUeam at (he point of csscharce [or entry la a cortml device) includes contributions
from more than ore MCPU. apply the Mowcfiart separately to the fractions of the total gas stream
tan each IVCPU.
Figure 3-1. Applicability for continuous process vents.
3-3
-------
3.0 Process Vents
-~~~ Does Ihtj gas stream "~""~-~,_
^--"~" pass through any unit operation ~""~~-~—.
for a process purpose, other lhar recovery devices or a
device that recovers only mechanical energy from the
'"""•-,,__ gas stream, before discharge to the ,. """"
~~~~--.._ atmosphere? „ ~~~
No
-Yes-
Ttie gas stream is part of the process- It
is not a process vent- (The discharge
from the Sbbseeuer't unit operation,
however, must still be evaluated to
determine if it is a continuous process
vent or a batch process vert.)
.„,--'" Is the \.^
as stream any of the toMowing: a'~"-\
f valve oisctiarge, dischargee to a 1uel gas ~""~-..._
'system; discharged to a process for reaction or other use;
exrting a control device usec io comply with Table 1 to
"--.^ subpart FFFF: exiting an analyzer, or transferee for _..,.
"""•--.^ fuel value, use. or reuse-, or _,,-•"""
^""•\_ for for fuel value. ..„-'"''
""~-~...,^ use or reuse-? _.„.--'"'
The of is not a
it is not
to
No
[[[ ± [[[
The emission point is a continuous process went Note that
the discharge point may b& esther onsite or off site
Ihe
„ .
metalsl1
No
-Ves->
Go to 3-S to
-------
3.0 Process Vents
Is the
_,,X Is this TRE ~--
x--*' < 1.9 for or exiting
-No-
Yes
You have a Group 1 continuous
process vftf I. Meet the emission limits
3rd work practice staridarot; specified
in Table 1 to subpan FFFF ard
oeacribed in Figure 3-3.
You a Group 2
continuous process vent.
/ Is tile TRE \
< 5.0 for an existir.g \x
source {* 8.0 for a J> No
new source)'7
Yes
i
If the emission stream is routed
to u recovery device, establish
OfWBtirg limits over trie same time
period .35 the TRE determination ann
y monitor for eomplisnce
wilh these limits.
No adcilionul
requirements upply to
the vent.
Figure 3-1. (continued)
3-5
-------
3.0 Process Vents
Start
Use this flowchart for each vent IP each MCPU through which HAP-
containing oas streams are, or have the potential to be, released to the
atmosphere, except do not use for:
* continuous process vents figure 3-1)
• a bottoms receiver vent (see Figures 4-1)
« 3 surge control vessel vert (see Figure —-1J
» vents on storage tanks fsee Figure 4-"*)
» vents on waslewater emission- sources (see Figure 5-' J
* omissions from cornporenls subject to subparl H or UU (soe Figure 7-11
* a transfer operation vert (see Figure 6*1)
*'*" Is the gas
from a drum,
pail, or tote?
;>—Yes-
^-'" Is the "\.^
^" train a flexible ~\._
elephant trur-k system that draws
ambient air away from operators
""'\ when vessels ,..-''"
"*\_ areopenec? ,--'"''
-Ves-
No
A
-Yes-
The vent is rot a
process vent, and it is not
subject to control ureter
subpart FFFF.
No
^^-'''=Is the HAP~""\
•'•'"" corcentration in the "\
stream from an individual emission
""\ ^'•"'^
"~"--^_ < 50 ppmv? .---"''
—*•
T
No
Continue at
©
The gas alrearn for tlie
s peci Tic is s i or" e p i s ade
does not cause the vent to be
a batch proce&a vent, anr; it
is not subject to control unctjr
subpart FFFF, Note,
however, thai the vent
may still be a batch process
vert for other emission
streams thai are released
through the same vent.
Figure 3-2. Applicability for batch process vents.
3-6
-------
3.0 Process Vents
f,--''" is the lots I HAP \
"'' contained in the gas stream "
from all emissions episodes that
... dischargtj through tin-; vent ^
""\. < 200 ir}/vr? .„--""""
-Yes
Y
No
Tine gas slream for the
specific emission episode's)
does rot cause the venl to
too a batch pen-cuss vr,«nt,
and it is not subject to
control uncer subpart FFFF.
1 he verl is a batch process vert.
i
god
If the gas stream(si from Ire
batch process vent contain
If the the
are of a
and
go to 3-5.
/' Is tre total \
/' uncontrolled organic
x** HAP emission level from all
process vents wilhir this
at an easting source
> 10.000 Ib/yr {> 3.000 ib/yr ^
'\ for an MCPU at ^/
\. a new source T> ,..-''
-No—*.
This fi-'CPU has Group 2
batch process vents. No
control is required.
Yes
This MCPU has Group-1 batch
vents that must meet the emission
and work practice standards specified in
Table 2 to subpart FFFF arc!
summarized in Figure 3-3
Figure 3-2. (continued)
3-7
-------
1
1 £
£:
Use P. hrJoger radue:;on device ajfeif*
the conbys'joi duvcoo ic 'C;cuc€- !hs
halogei" atO'ii hiiais. irnlEsion rate :o
< 0 45 Ng-'hrrj' In a corn^rrxafsor
< 20 ppir.v.
* i far of and
Figure 3-3. Emission limits and work practice standards for organic HAP emissions from batch or continuous process vents.
3
s
£?
-------
3.0 Process Vents
Start
Use this flowchart if you are referrec to it from
Figure 3-1 or 3-2 for hydrogen r-alide anc halogen HAP
emissions (i.e , HCI. Hf, and Cl.?'( from continuous process
vents or batch proc-ess vents.
,"'*" Are the- ~\
collective u-ncorUolled
HAP emissions from oil continuous
and/or t ana/or j anc/c
y_ i i
Reduce the halogen
atom mass emission rate
from the sum of ali natch
process vents and each
individual continuous
process vent to £ C .4 5
kq.'hr by venting trrough-
one or more closed-vent
systems to a halogen
reduction device ''
Reduce collective
hydrogen halide anc
halogen HAP emissions
from any or all process
vents by i 911 percert by
venting through one or
more closed -v&rt
systems to any
combination of control
devices.
i
[ Reduce hydrogen halide
j and halogen HAP
t emissions from ary or all
t process vents to an outlet
t concentration £20 pprnv
| by venting through one or
I more do sec -vent
[ systems to any
f combination of control
t devices
^^1
Demonstrate initial comptiance by |
coneucting a perforrriiSnce test Or |
design evaluation. Deniorstrate S
ongoing campiiar:ce by |
monitoring cortrol device [
operating pariiirneiets. |
*
Recuce hydrogen halide
and halogen HAP
emissions from any or all
process vents to sn outlet
concentration ^SO ppmv by
complying with the
alternative standard as
specifiec ir §63.2305 See
Figure 11-1 .
t
\ Demonstrate compliance
1 using CbWS.
the 0.45 kg/t'r limit applies to all batch process wents a a of is
not for process vents when complying with the 0.45 k|flir limit.
Figure 3-4. Applicability and control requirements for hydrogen halide and halogen
HAP emissions from process vents.
3-9
-------
3.0 Process Vents
Start
Use this flowchart if yen, E'.re referred 1o it from
Figure 3-1 or 3-2 for HAP metals from continuous
process verts or batch process vonts.
^-'"' Are the ""=--,^
,,*•""" colleclive uncontrolled '"-\
HAP meta!s emissions from all
continuous process vents a no batch
"""••.„. process vents _„.."""'"
-No—+
No.
or
;tml
is
re-quired.
Reduce overall emissions of HAP metals by
> 9? percent by weight.
Figure 3-5. Applicability and control requirements for HAP metals
emissions from process vents at new sources.
3-10
-------
3.0 Process Vents
Table 3-1. Inspection Checklist for Controlling Organic HAP Emissions from
Continuous Process Vents that Are Subject to Subpart FFFF
Note: Use this checklist for each continuous process vent that is subject to subpart FFFF. A "yes"
response to questions in the review of records section of this checklist means compliance with
that requirement, and a "no" response means noncompliance with the requirement. If a question
is not applicable, check the "N/A" box.
I. General Information
1. Process and Continuous Process Vent Identification:
2. What is the Group Status of the continuous process vent (determined according to Figure 3-1):
D Group 1, or
Continue with item "3, " in this section of the checklist and items "1" and
"3 " in the review of records section of this checklist.
D Group 2
Continue with items "2" and "3" in the review of records section of this
checklist.
3. Which type of emission limit applies to the organic HAP emissions from the
Group 1 continuous process vents? (check all that apply)
D Use a flare? (go to checklists in Tables 9-1, 9-2, and 10-1)
Note: Halogenated vent streams may not be controlled using a flare,
unless a halogen reduction device before the flare reduces the mass
emission rate of halogen atoms in organic compounds to less that 0.45
kg/hr. See item "1" in the review of records section of this checklist.
D Reduce organic HAP emissions by >98 percent in a control device or to
less than 20 ppmv as organic HAP or TOC using one or more of the
following add-on devices:
Note: Also see item "4" in this checklist if the continuous process vent
emits a halogenated vent stream that is controlled with a combustion
device.
D A thermal incinerator? (go to checklists in Tables 9-1, 9-2, and 10-2)
D A catalytic incinerator? (go to checklists in Tables 9-1, 9-2, and 10-3)
D A boiler or process heater with a capacity less than 44 MW that does
not have the emission stream introduced with the primary fuel? (go to
checklists in Tables 9-1, 9-2, and 10-4).
D A boiler or process heater with a capacity greater than 44 MW or that
has the vent stream introduced with the primary fuel? (go to
checklists in Tables 9-1, 9-2, and 10-5)
3-11
-------
3.0 Process Vents
Table 3-1. (continued)
I. General Information
D A carbon adsorber? (go to checklists in Tables 9-1, 9-2, and 10-6).
D An absorber? (goto checklists in Tables 9-1, 9-2, and either 10-7 or
10-10)
D A condenser? (go to checklists in Tables 9-1, 9-2, and 10-8)
D Another type of control device? (go to checklists in Tables 9-1, 9-2,
and 10-9)
D Install a recovery device to maintain the TRE above 1.9 and <5.0 for an
existing source (above 5.0 and <8.0 for a new source)? (go to items "2"
and "3" in the review of records section of this checklist for Group 2
continuous process vents)
D Comply with the alternative standard in §63.2505? (go to checklists in
Tables 9-1, 9-2, 11-1, and, if applicable, 11-2)
II. Review of Records
1. If a halogenated vent stream from a Group 1 continuous process vent is D Y D N/A D N
controlled using a combustion device, is a halogen reduction device also used
either before or after the combustion device? If yes, which of the following
requirements are met:
D Is a halogen reduction device used before the combustion device to
reduce the halogen atom mass emission rate to <0.45 kg/hr or to a
concentration <20 ppmv? (go to the appropriate checklist in Section 10;
for example, go to Table 10-10 if the halogen reduction device is a
scrubber)
D Is a halogen reduction device used after the combustion device to reduce
hydrogen halide and halogen HAP emissions by >99 percent, to <0.45
kg/hr, or to a concentration <20 ppmv? (go to the appropriate checklist
in Section 10; for example, go to Table 10-10 if the halogen reduction
device is a scrubber)
Note: When the organic HAP is controlled with a flare, the halogen
content must be reduced before venting to the flare.
2. Which of the following conditions describes the Group 2 continuous process
vent:
D The TRE is >1.9 at an existing source (>5.0 at a new source) without a
recovery device?
D The TRE is >5.0 after the last recovery device at an existing source (>8.0
at a new source)?
3-12
-------
3.0 Process Vents
Table 3-1. (continued)
II. Review of Records
D The TRE is > 1.9 and <5.0 after the last recovery device at an existing
source (>5.0 and <8.0 at a new source). If this condition applies, which
of the following recovery devices are used (check all that apply):
D A carbon adsorber? (go to the checklist in Table 10-6)
D An absorber? (go to the checklist in either Table 10-7 or Table 10-10)
D A condenser? (goto the checklist in Table 10-8)
D Another type of recovery device? (go to the checklist in Table 10-9)
3. If the continuous process vent changed from Group 2 to Group 1, did the DY D N/A DN
facility notify the permitting agency 60 days before the change took effect?
§63.2520(e)(10)(ii)(C)
III. Note All Deficiencies
3-13
-------
3.0 Process Vents
Table 3-2. Inspection Checklist for Controlling Organic HAP Emissions from
Batch Process Vents in a Process Subject to Subpart FFFF
Note: Use this checklist for the collection of batch process vents within a process that is subject to
subpart FFFF. A "yes" response to a question in the review of records section of this checklist
means compliance with that requirement, and a "no" response means noncompliance with the
requirement. If a question is not applicable, check the "N/A" box.
I. General Information
1. Process Identification or Identification of Batch Process Vents in the Process:
2. What is the Group Status of the batch process vents (determined according to Figure 3-2):
D Group 1, or
Continue with this checklist.
D Group 2
No control is required, but go to checklist in Table 3-3 to determine
compliance with other requirements.
3. Which type of emission limit applies to the organic HAP emissions from
Group 1 batch process vents? (check all that apply)
D Use a flare? (go to checklists in Tables 9-1, 9-2, and 10-1)
Note: Halogenated vent streams may not be controlled using a flare,
unless a halogen reduction device before the flare reduces the mass
emission rate of halogen atoms in organic compounds to less that 0.45
kg/hr. See item "1" in the review of records section of this checklist.
D Reduce organic HAP emissions by > 98 percent in a control device, > 95
percent in a recovery device or biofilter, or to less than 20 ppmv as
organic HAP or TOC using one or more of the following add-on devices:
Note: Also see item "1" in the review of records section of this checklist
if any of the batch process vents emit halogenated vent streams that are
controlled with a combustion device.
D A thermal incinerator? (go to checklists in Tables 9-1, 9-2, and 10-2)
D A catalytic incinerator? (go to checklists in Tables 9-1, 9-2, and 10-3)
D A boiler or process heater with a capacity less than 44 MW that does
not have the emission stream introduced with the primary fuel? (go to
checklists in Tables 9-1, 9-2, and 10-4).
D A boiler or process heater with a capacity greater than 44 MW or that
has the vent stream introduced with the primary fuel? (go to
checklists in Tables 9-1, 9-2, and 10-5)
3-14
-------
3.0 Process Vents
Table 3-2. (continued)
I. General Information
D A carbon adsorber? (go to checklists in Tables 9-1, 9-2, and 10-6).
D An absorber? (goto checklists in Tables 9-1, 9-2, and either 10-7 or
10-10)
D A condenser? (go to checklists in Tables 9-1, 9-2, and 10-8)
D Another type of control device? (go to checklists in Tables 9-1, 9-2,
and 10-9)
D A biofilter? (go to checklists in Tables 9-1, 9-2, and 10-11)
D Comply with the alternative standard in §63.2505? (go to checklists in
Tables 9-1, 9-2, 11-1, and, if applicable, 11-2)
II. Review of Records
1. If halogenated vent streams from Group 1 batch process vents are controlled D Y D N/A D N
using a combustion device, is a halogen reduction device also used either
before or after the combustion device? If yes, which of the following
requirements are met: (note that both types of devices may exist if the Group
1 batch process vents for a given process are controlled by more than one
combustion device)
D Is a halogen reduction device used before the combustion device to
reduce the halogen atom mass emission rate to <0.45 kg/hr or to a
concentration <20 ppmv? (go to the appropriate checklist in Section 10;
for example, go to Table 10-10 if the halogen reduction device is a
scrubber)
D Is a halogen reduction device used after the combustion device to reduce
hydrogen halide and halogen HAP emissions by >99 percent, to <0.45
kg/hr, or to a concentration <20 ppmv? (go to the appropriate checklist
in Section 10; for example, go to Table 10-10 if the halogen reduction
device is a scrubber)
Note: When the organic HAP to the flare is controlled with a flare, the
halogen content must be reduced before venting to the flare.
2. If Group 1 batch process vents are in compliance with a percent reduction
emission limit and some of the vents are controlled to less than the required
average for all vents, are all of the following records kept for each batch:
(a) Whether the batch was a standard batch or a nonstandard batch? D Y D N/A D N
(b) The estimated uncontrolled emissions for each batch that was a D Y D N/A D N
nonstandard batch?
Note: An inspector should check that the overall required percent
reduction is achieved for nonstandard batches.
3-15
-------
3.0 Process Vents
Table 3-2. (continued)
II. Review of Records
3. Does the facility have a schedule or log of operating scenarios for processes DY DN
with batch process vents from batch operations? §63.2525(c)
4. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
III. Note All Deficiencies
3-16
-------
3.0 Process Vents
Table 3-3. Compliance Checklist for Group 2 Batch Process Vents
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If a question is not applicable, check
the "N/A" box.
Note: This checklist does not apply if the facility has elected to designate a batch process vent as a
Group 1 batch process vent.
I. Review of Records
1. Does the facility have calculation records of the uncontrolled organic HAP D Y D N
emissions from each batch process vent and the collective uncontrolled
emissions for a standard batch (i.e., as part of an operating scenario)?
§§63.2460(b) and 63.2525(b)
2. If the facility does not maintain records related to each batch for the process, DY DN/A DN
does the notification of compliance status report indicate it is because of one
of the following reasons? If yes, check the applicable reason.
§63.2525(e)(l)
D The MCPU does not process, use, or generate HAP?
D The Group 2 batch process vents are controlled using a flare that meets
the requirements of §63.987?
D The Group 2 batch process vents are controlled using a control device
that also controls Group 1 batch process vents, and worst-case
conditions for the initial compliance demonstration included the
contribution from the Group 2 batch process vents?
3. If the facility documented in its notification of compliance status report that
non-reactive organic HAP is the only HAP used in the process and usage is
< 10,000 Ib/yr, does it maintain all of the following records: §63.2525(e)(2)
(a) Amount of non-reactive organic HAP material used per day or per DY DN/A DN
batch?
(b) Daily rolling annual summations of the amount used in the preceding DY D N/A DN
365 days?
Note: The summation calculations do not have to be performed every
day, but calculations must be performed at least once per month for
each of the days since the previous calculations.
4. If the facility documented in its notification of compliance status report that
uncontrolled organic HAP emissions are < 1,000 Ib/yr from the batch
process vents in the process, does it maintain records of the following:
§63.2525(e)(3)
(a) Number of batches operated? DY DN/A DN
3-17
-------
3.0 Process Vents
Table 3-3. (continued)
I. Review of Records
(b) Daily rolling annual sum of the batches operated in the preceding 365 D Y D N/A D N
days?
Note: The summation calculations do not have to be performed every
day, but the calculations must be performed at least once per month for
each of the days since the previous calculations.
5. If none of the conditions in items 2-4 above apply, are all of the following
records maintained for each batch? §63.2525(e)
(a) The day the batch was completed? DY DN/A DN
(b) Whether the batch was a standard batch or a nonstandard batch? D Y D N/A D N
(c) The estimated uncontrolled emissions, if the batch was a nonstandard DY DN/A DN
batch?
(d) A summation of the total uncontrolled emissions over the preceding 365 DY D N/A DN
days (and are the sums less than 10,000 Ib for a process at an existing
source and less than 3,000 Ib for a process at a new source)?
Note: The summation calculations do not have to be performed every
day, but they must be performed at least once per month for each of the
days since the previous calculation.
6. If the status of the batch process vents changed from Group 2 to Group 1, DY DN/A DN
did the facility notify the permitting agency 60 days before the change took
effect? §63.2520(e)(10)(ii)(C)
Note: The advance notification is not required if the process operated with
Group 2 batch process vents for at least 1 year before the change.
7. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Note All Deficiencies
3-18
-------
3.0 Process Vents
Table 3-4. Inspection Checklist for Controlling Hydrogen Halide and Halogen HAP Emissions
from Process Vents within Processes that Are Subject to Subpart FFFF
Note: Use this checklist for all process vents within a process that is subject to subpart FFFF and emits
hydrogen halide and halogen F£AP.
I. General Information
1. Process Identification and Identification of the Process Vent(s):
2. Are the collective uncontrolled hydrogen halide and halogen HAP emissions from all process vents
within the process:
D >l,0001b/yr, or
Continue with this checklist.
D 99 percent in a
control device or to less than 20 ppmv using one or more of the following
add-on halogen reduction devices:
D A scrubber? (go to checklists in Tables 9-1, 9-2, and 10-10)
D Another type of halogen reduction device? (go to checklists in Tables
9-1, 9-2, and 10-9)
D Comply with the alternative standard in §63.2505? (go to checklists in
Tables 9-1, 9-2, and 11-1)
D Reduce the halogen atom mass emission rate from the sum of all batch
process vents and each individual continuous process vent to < 0.45 kg/hr
using one or more of the following halogen reduction devices:
D A scrubber? (go to checklists in Tables 9-1, 9-2, and 10-10)
D Another type of halogen reduction device? (go to checklists in Tables
9-1, 9-2, and 10-9)
II. Note All Deficiencies
3-19
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3.0 Process Vents
Table 3-5. Compliance Checklist for Processes with Hydrogen Halide and
Halogen HAP Emissions from All Process Vents Less than 1,000 Ib/yr
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If a question is not applicable, check
the "N/A" box.
I. Review of Records
1. Does the facility have calculation records of the uncontrolled hydrogen halide D Y D N
and halogen HAP emissions from each process vent and the collective
uncontrolled emissions for a standard batch (i.e., as part of an operating
scenario) ? §§63.2465(b) and 63.2525(b)
2. Are all of the following records maintained for each process: §63.2525(e)
(a) The day the batch was completed, if applicable? DY DN/A DN
(b) Whether the batch was a standard batch or a nonstandard batch, if D Y D N/A D N
applicable?
(c) The estimated uncontrolled hydrogen halide and halogen HAP emissions D Y D N/A D N
from batch process vents and continuous process vents for each
nonstandard batch?
(d) A summation of the total uncontrolled hydrogen halide and halogen HAP D Y D N/A D N
emissions during the preceding 365 days (and are the sums less than 1,000
lb)?
Note: The summation calculations do not need to be performed every
day, but calculations for each day since the previous calculation must be
performed at least once per month.
3. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Note All Deficiencies
3-20
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3.0 Process Vents
Table 3-6. Inspection Checklist for Controlling HAP Metals Emissions from Process Vents
within Processes at New Sources that Are Subject to Subpart FFFF
Note: Use this checklist for all process vents within a process at a new source that is subject to subpart
FFFF and emits F£AP metals.
I. General Information
1. Process Identification and Identification of the Process Vent(s):
2. Are the collective uncontrolled HAP metals emissions from all process vents within the process:
D >1501b/yr, or
Continue with this checklist.
D <1501b/yr
Stop. No control is required. Do not continue with this checklist.
3. How does the facility comply with the 97 percent reduction requirement?
D Using a fabric filter? (goto checklist in Table 10-12)
D Using another type of control device? (go to checklist in Table 10-12)
II. Note All Deficiencies
3-21
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3.0 Process Vents
[This page intentionally left blank.]
3-22
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
This section contains applicability and control flowcharts and inspection checklists for storage
tanks, surge control vessels, and bottoms receivers. Use Figures 4-1 and 4-2 to determine if a storage
tank, surge control vessel, or bottoms receiver is subject to subpart FFFF, its group status, and its
compliance options. Note that surge control vessels and bottoms receivers that meet the same capacity
and maximum true vapor pressure thresholds as Group 1 storage tanks must be controlled as Group 1
storage tanks (see Appendix B for definitions of surge control vessel and bottoms receiver).
To determine compliance, use the applicable inspection checklist for the control technique that is
used to minimize emissions from the storage tank, surge control vessel, or bottoms receiver. The
checklist in Table 4-1 is used to document the group status and control technique for a specific tank. It
also points you to other checklists for the applicable control technique, and it includes a checklist for
general recordkeeping requirements. Table 4-2 provides a checklist for external floating roofs (EFRs),
and Table 4-3 applies to internal floating roofs (IFRs). Checklists for closed-vent systems and air
pollution control devices are in Sections 9 and 10, respectively, and Table 4-4 supplements these
checklists with details about periods of planned routine maintenance for the control device. Table 4-5 is a
checklist for complying with the vapor balancing option. Table 4-6 covers the requirements for
complying with the alternative standard.
4-1
-------
to
>-Ye
/ Tte
\ in pppp |jo dpi apply,
'
MTVPoftte
trtatl-W
>6.9kPa?
-No-
-Yes-
The s-ofiige :ank
%;.i— —& «a:i:ifft!i«:iis ir sutjpt
\ FFFFdQW.applv.
H^
C5
o
1
Figure 4-1. Applicability for storage tanks, surge control vessels, and bottoms receivers.
-------
No
I
rt—NO
^ Isihe ^-^
storage lark assigrec '^
ID ai> MCfL- th 0.69 kPa?
i- i .-.
Fit-jjie- '-1-2
r1^
C5
o
1
Figure 4-1. (continued)
-------
4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
• S,i-lie cor'In.: lias'sal of •.Kiv.ornL-; rt&tiiwr '.ha!./
TIUS" 36 COf'tfOllSK!
MTVP of total HAP
Yes
Compy witi :hc elterrai've sandard spe-sife-d ;r §63.250.5 and h ^igtre 11-!.
i' RecL-ce totsi HAP emissions syi'35% by weigh: or :c £20 Mmv asTCC orc-'ij?ric
"*', HAP by usi-'ig a c.osed vent system an3 any combination of control cewfces.
I
Figure 4-2. Emission limits for Group 1 storage tanks,
surge control vessels, and bottoms receivers.
4-4
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-1. Inspection Checklist for Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Subject to Subpart FFFF
Note: Use this checklist for each storage tank, surge control vessel, and bottoms receiver that is subject
to subpart FFFF. A "yes" response to a question in item 4 in this checklist means compliance
with that requirement, and a "no" response means noncompliance with the requirement.
Note: Throughout this table and Tables 4-2 through 4-6, any reference to Group 1 storage tanks also
applies to surge control vessels and bottoms receivers that meet the same capacity and maximum
true vapor pressure thresholds, as noted in figure 4-1.
I. General Information
1. Storage Tank Identification:
2. What is the Group Status of the storage tank, or is it a surge control vessel or bottoms receiver that
is subject to control under subpart FFFF (determined according to Figure 4-1):
D Group 1
D Group 2
D Surge control vessel or bottoms receiver
3. How are the emissions from the storage tank, surge control vessel, or bottoms receiver
controlled?
Group 2 storage tank
D Control is not required
Group 1 storage tank, surge control vessel, or bottoms receiver
D An external floating roof (go to Table 4-2).
D An internal floating roof (go to Table 4-3).
D An external floating roof converted to an internal floating roof (go to Table 4-2).
D A flare (go to Table 9-1 for the closed-vent system and both Tables 4-4 and 10-1
for flares).
D A closed-vent system and a non-flare control device (go to Table 9-1 for closed-
vent system and both Table 4-4 and the appropriate table in Section 10 for the
non-flare control device).
D Emissions are routed to a fuel gas system (the owner or operator must include a
statement of connection in the notification of compliance status report; go to
Table 12-1).
D Emissions are routed to a process (the owner or operator must prepare a design
evaluation or engineering assessment that documents the extent to which the
emissions are recycled, consumed, transformed by chemical reaction into
materials that are not F£AP, incorporated into a product, and/or removed, and
include the results of this determination in the notification of compliance status
report; go to Table 12-1).
D Vapor balancing (go to Table 4-5).
D The alternative standard (go to Table 9-1 for the closed-vent system and Table 4-
6 for the control device).
4-5
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-1. (continued)
I. General Information
4. Are all of the following records kept for the storage tank: §§63.1065(a) and
63.2520(d)(2)(i)
• Dimensions of the storage tank? D Y D N
• Capacity of the storage tank? D Y D N
• Identification of the liquid stored in the storage tank? D Y D N
Note: Section 63.1065(a) explicitly requires all of these records for Group 1
storage tanks that are equipped with floating roofs. Although subpart FFFF does
not explicitly require these records for Group 2 storage tanks and other Group 1
storage tanks, §63.2520(d)(2)(i) requires the results of applicability
determinations to be included in the notification of compliance report. The
information described by these records is needed to make those applicability
determinations. Thus, these records are required for all storage tanks that are
part of an affected source under subpart FFFF. These are the only requirements
for Group 2 storage tanks.
II. Note All Deficiencies
4-6
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-2. Compliance Checklist for a Group 1 Storage Tank with an External Floating Roof
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If a question is not applicable, check
the "N/A" response (e.g., item 10, which describes procedures to follow when performing the
measurements is determined to be unsafe, is not applicable if performing the measurements is not
determined to be unsafe).
Storage Tank Identification:
I. Review of Records
1. Are all records kept for at least 5 years? §63.1065 D Y D N
2. Do records indicate that seal gap measurements have been made every 5 D Y D N/A D N
years for the primary seal? §63.1063(c)(2)(ii)
3. Do records indicate that seal gap measurements have been made annually DY DN/A DN
for the secondary seal?3 §63.1063(c)(2)(ii)
4. Do records indicate the floating roof deck, deck fittings, and rim seals are DY DN/A DN
visually inspected each time the tank is completely emptied and degassed or
every 10 years? §63.1063(c)(2)(iii)
5. Were both of the following recorded for all visual inspections and seal gap
measurements: §63.1065(b)(l)(i) and (ii)
• Identification of the storage vessel? D Y D N
• Date of the inspection? D Y D N
6. For all seal gap measurements, was all of the following information
recorded: §63.1065(b)(2)
• All of the raw data that were obtained? D Y D N
• All calculations that were performed (e.g., total gap area)? DY DN
7. When a failure was detected during a visual inspection or seal gap
measurement, was all of the following information recorded:
§63.1065(b)(l)(iii) through (v)
• A description of all inspection failures? DY DN/A DN
• A description of all repairs and the dates they were made? DY DN/A DN
• The date the storage tank was removed from service (if the inspection D Y D N/A D N
was performed while the tank was in operation and repairs can not be
completed while operating)?
4-7
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-2. (continued)
I. Review of Records
8. Whenever a floating roof was set on its legs or other supports, was all of the
following information recorded: §63.1065(c)
• The date when the floating roof was set on it legs or other supports? DY DN/A DN
• The date when the floating roof was refloated? D Y D N/A D N
• An indication of whether the process of refloating was continuous? D Y D N/A D N
9. If a tank was taken out of service to complete repairs, but it could not be
emptied within 45 days of detecting a failure, was all of the following
information kept to document the decision to request up to two 30-day
extensions: §§63.1063(e)(2), 63.1065(d), and 63.1066(b)(4)
• A description of the failure? DY DN/A DN
• Documentation that alternate storage capacity was not available? D Y D N/A D N
• Schedule of actions taken to make repairs or empty the tank as soon as DY DN/A DN
possible?
10. If performing a required seal gap measurement was determined to be unsafe,
and the vessel could not be emptied within 45 days, was all of the following
information kept to document the decision to request up to two 30-day
extensions: §§63.1063(c)(2)(iv)(B), 63.1065(d), and 63.1066(b)(4)
• Explanation of why it was unsafe to perform the seal gap measurement? DY D N/A DN
• Documentation that alternate storage capacity was unavailable? D Y D N/A D N
• Schedule of actions taken to make repairs or empty the tank as soon as DY DN/A DN
possible?
11. Was the Administrator or delegated state or local agency notified at least 30 D Y D N/A D N
days before each internal inspection or seal gap measurement (7 days if the
inspection was unplanned and could not be foreseen 30 days in advance)?
§63.1066(b)(l)
Note: a delegated state or local agency may waive this requirement.
12. When a failure was detected during a visual inspection or seal gap D Y D N/A D N
measurement, was a copy of the inspection records submitted in the next
compliance report? §63.1066(b)(2)
4-8
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-2. (continued)
II. Visual Inspection
Note: The inspector should not perform the inspection without proper respiratory protection if the roof
is below 4 feet of the top of the tank. Based on the inspector's assessment of the availability of
records documenting the design of the control equipment, an adequate inspection without
respiratory protection may be performed with a combination of a record inspection and a visual
inspection conducted from the platform with the aid of vision-enhancing devices (binoculars). If
the inspector feels that it is necessary to be on the EFR when the roof is below 4 feet of the top of
the tank, please be aware of the requirements under EPA Order 1440.2 (required only for Agency
personnel) and the safety information in Guidance on Confined Space Entry in NESHAP
Inspections of Benzene Storage Vessels (EPA 455/R-92-003, September 1992).
1. Does the EFR float on the surface of the stored liquid? §63.1063(b)(l) DY D N/A DN
and (2)
Note: The EFR is not required to be floating on the liquid when it is
supported by its leg supports either because the liquid depth is insufficient
to float the EFR or the tank is empty.
2. Is the floating roof deck free of pools of standing liquid? DY DN
§63.1063(d)(l)(i)
3. Inspect the secondary seal.
• Is the secondary seal free of holes and tears?b §63.1063(d)(l)(ii) D Y D N/A D N
• Is the secondary seal continuously attached around the circumference of D Y D N/A D N
the EFR?
4. Perform seal gap measurement of the secondary seal.b
• Is the accumulated area of gaps between the tank wall and the DY DN/A DN
secondary seal no greater than 21.2 cm^ per meter of tank diameter?
• Is the maximum gap width between the tank wall and the seal no D Y D N/A D N
greater than 1.27 cm?
Note: Procedures for performing the seal gap measurements and
determining the total gap area and maximum gap width are specified in
§63.1063(d)(3).
5. Inspect the primary seal.
• Is the primary seal either a mechanical/metallic shoe seal or a liquid- D Y D N
mounted seal?b §63.1063(a)(l)(ii) and see definitions of "mechanical
shoe seal" and "liquid-mountedseal" in §63.1061
• Is the primary seal free of holes and tears? §63.1063(d)(l)(ii) D Y D N
• Is the primary seal continuously attached around the circumference of D Y D N
the EFR?
4-9
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-2. (continued)
II. Visual Inspection
• If the primary seal is a mechanical/metallic shoe seal:
- Does the lower end of the mechanical/metallic shoe seal extend into D Y D N/A D N
the stored liquid (no specific distance)?
- Does the upper end of the mechanical/metallic shoe seal extend a D Y D N/A D N
minimum vertical distance of 61 cm above the stored liquid surface?
- Does a flexible coated fabric span the space between the metal shoe D Y D N/A D N
and the tank wall?
• If the primary seal is a liquid-mounted seal, is the seal in contact with DY D N/A DN
the liquid between the wall of the storage tank and the EFR?
6. Perform seal gap measurements of the primary seal.
• Is the accumulated area of gaps between the tank wall and the primary DY DN
seal no greater than 212 cm2 per meter of tank diameter?
• Is the maximum gap width between the tank wall and the seal no more D Y D N
than 3.81cm?
Note: Procedures for performing the seal gap measurements and
determining the total gap area and maximum gap width are specified in
§63.1063(d)(3).
1. Inspect deck openings.
• Is the lower edge of each opening in the floating roof, except automatic DY DN/A DN
bleeder vents and rim space vents, below the surface of the stored
liquid?0 §63.1063(a)(2)(i)
• Except for automatic bleeder vents, rim space vents, deck drains, and D Y D N/A D N
leg sleeves, does each opening in the roof have a gasketed cover?0
§63.1063(a)(2)(ii)
• Is each gasketed cover, seal, or lid on any opening in the EFR closed, D Y D N/A D N
except when it must be open for access?0 §63.1063(b)(3)
• Is the cover on each access hatch and gauge float well designed to be D Y D N/A D N
bolted or fastened when closed?0 §63.1063(a)(2)(vi)
• Does each deck fitting gasket, seal, and wiper fit between the surfaces it D Y D N/A D N
is intended to seal without any gaps larger than 0.32 cm (1/8 in)?
§63.1063(d)(l)(v)
4-10
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-2. (continued)
II. Visual Inspection
8. Inspect automatic bleeder vents (vacuum breaker vents).
• Is each automatic bleeder vent closed, except when required to be open D Y D N
to relieve excess pressure or vacuum? §63.1063(b)(4)
• Does each automatic bleeder vent have a gasketed lid, pallet, flapper, or D Y D N/A D N
other closure device?0 §63.1063(a)(2)(iii)
9. Inspect rim space vents.
• Is each rim space vent closed, except when required to be open to D Y D N
relieve excess pressure or vacuum? §63.1063(b)(4)
• Does each rim space vent have a gasketed lid, pallet, flapper, or other D Y D N/A D N
closure device?0 §63.1063(a)(2)(iii)
10. Does each deck drain that empties into the stored liquid have either a DY DN/A DN
gasketed cover or a slit fabric seal or similar device that covers at least 90
percent of the area of the opening?0 §63.1063(a)(2)(v)
11. Does each unslotted guide pole well have a pole wiper?0 D Y D N/A D N
§63.1063(a)(2)(vii)
12. Does each unslotted guide pole have a gasketed cap on the end of the DY DN/A DN
pole?0 §63.1063(a)(2)(vii)
13. Is the cap on each unslotted guidepole closed, except when gauging the DY DN/A DN
liquid level or taking liquid samples? §63.1063(b)(5)
14. Does each slotted guide pole have either of the following: (1) a pole wiper DY DN/A DN
and pole float, or (2) a pole wiper and pole sleeve?0 §63.1063(a)(2)(viii)
15. Does each sample well have either a gasketed cover or a slit fabric seal or DY DN/A DN
similar device that covers at least 90 percent of the area of the opening?0
§63.1063(a)(2)(v)
III. Note All Deficiencies
EFR = external floating roof.
4-11
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-2. (continued)
If an EFR has a liquid-mounted or metallic shoe primary seal as of April 4, 2002, a secondary seal is not required
until the next time the tank is emptied and degassed or until November 10, 2013, whichever is earlier.
§63.1063(a)(l)(ii)(C)
If the EFR is equipped, as of April 4, 2002, with either: (1) a liquid-mounted primary seal and no secondary seal,
(2) a metallic shoe primary seal and no secondary seal, or (3) a vapor-mounted primary seal and a secondary seal,
then the seal requirement of a liquid-mounted or metallic shoe primary seal and secondary seal does not apply
until the earlier of the following dates: (1) the next time the storage tank is emptied and degassed, or (2)
November 10, 2013. §63.1063(a)(l)(ii)(C)
If these requirements were not met for a floating roof in place as of April 4, 2002, then this requirement does not
apply until the earlier of the following dates: (1) the next time the storage tank is emptied and degassed, or (2) no
later than November 10, 2013. §63.1063(a) (2) (ix)
4-12
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-3. Compliance Checklist for a Group 1 Storage Tank with an Internal Floating Roof
Note: An external floating roof located in a storage tank to which a fixed roof has been added is defined
as an internal floating roof. §63.1061
A "yes" response to a question in this checklist means compliance with that provision, and a "no"
response means noncompliance with the requirement. If a question is not applicable, check the
"N/A" box (e.g., item 5 would not be applicable if the floating roof has not been set on its legs or
other supports).
Storage Tank Identification:
I. Review of Records
1. Are all records kept for at least 5 years? §63.1065 D Y D N
2. Do records show that visual inspections are conducted on either of the
following schedules: §63.1063(c)(l)(i) and (ii)
(a) Internal and tank-top inspections are conducted as follows:
• Tank-top visual inspections are conducted at least once per year? D Y D N/A D N
• Internal visual inspections are conducted each time the storage tank D Y D N/A D N
is emptied and degassed, or every 10 years, whichever occurs first?
(b) Internal inspections are conducted each time the storage tank is emptied D Y D N/A D N
and degassed or every 5 years, whichever occurs first?
Note: The second option is allowed only for storage tanks with both
primary and secondary seals.
3. Were both of the following recorded for all visual inspections:
§63.1065(b)(l)(i) and (ii)
(a) Identification of the storage vessel? D Y D N
(b) Date of the inspection? D Y D N
4. When a failure was detected during a visual inspection, was all of the
following information recorded: §63.1065(b)(l)(iii) through (v)
(a) A description of all inspection failures? DY DN/A DN
(b) A description of all repairs and the dates they were made? DY DN/A DN
(c) The date the storage tank was removed from service (if the inspection D Y D N/A D N
was performed while the tank was in operation and repairs can not be
completed while operating)?
5. Whenever a floating roof was set on its legs or other supports, was all of the
following information recorded: §63.1065(c)
(a) The date when the floating roof was set on it legs or other supports? DY DN/A DN
4-13
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-3. (continued)
I. Review of Records
(b) The date when the floating roof was refloated? DY DN/A DN
(c) An indication of whether the process of refloating was continuous? D Y D N/A D N
6. If a tank was taken out of service to complete repairs, but it could not be
emptied within 45 days of detecting a failure, was all of the following
information kept to document the decision to request up to two 30-day
extensions: §§63.1063(e)(2), 63.1065(d), and 63.1066(b)(4)
(a) A description of the failure? DY DN/A DN
(b) Documentation that alternate storage capacity was not available? D Y D N/A D N
(c) Schedule of actions taken to make repairs or empty the tank as soon as D Y D N/A D N
possible?
7. Was the Administrator or delegated State or local agency notified at least 30 DY DN/A DN
days before each visual inspection (7 days if the inspection was unplanned
and could not be foreseen 30 days in advance)? §63.1066(b)(l)
Note: a delegated State or local agency may waive this requirement.
8. When a failure was detected during a visual inspection, was a copy of the DY DN/A DN
inspection records submitted in the next compliance report? §63.1066(b)(2)
II. Visual Inspection
Note: The inspector should be advised of the hazards of inspecting an internal floating roof tank that
contains a liquid hazardous air pollutant (HAP). An inspector may perform an external (tank-
top) visual inspection of a storage tank at any time (i.e., the tank does not need to be taken out of
service). However, the inspector will need to have proper respiratory protection before opening
the roof hatch to visually inspect, from the fixed roof, the floating deck and seal. An inspector
may perform the more thorough internal inspection only when the tank has been taken out of
service (i.e., emptied, degassed and cleaned). Unless a tank is taken out of service more
frequently than is required by subpart FFFF, this internal inspection can only take place once
every 10 years. The inspector should never enter a storage tank to inspect the IFR without first
consulting documents that address the safety issues to consider while entering a confined space
and while inspecting an IRF that contains HAP - EPA Order 1440.2 and the EPA document
Guidance on Confined Space Entry in NESHAP Inspections of Benzene Storage Vessels (EPA
455/R-92-003, September 1992).
1. Does the IFR float on the surface of the stored liquid? §63.1063(b)(l) and DY D N/A DN
(2)
Note: The IFR is not required to be floating on the liquid when it is
supported by its leg supports either because the liquid depth is insufficient
to float the IFR or the tank is empty.
2. Is the floating roof deck free of pools of standing liquid? §63.1063(d)(l)(i) DY DN
4-14
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-3. (continued)
II. Visual Inspection
3. Inspect the rim seal(s).
(a) Does the IFR have any one of the following closure devices:3 D Y D N/A D N
§63.1063(a)(l)
- A liquid-mounted primary seal? See definition of "liquid-mounted
seal" in §63.1061
- A mechanical/metallic shoe primary seal? See definition of
"mechanical shoe seal" in §63.1061
- Both a primary seal and a secondary seal?
(b) Is the primary seal continuously attached around the circumference of D Y D N
the IFR?
(c) If the IFR has a secondary seal, is it continuously attached around the D Y D N/A D N
circumference of the IFR?
(d) Are there no visible gaps between the seal(s) and the wall of the storage DY DN
tank?
(e) Is the primary seal free of holes and tears? §63.1063(d)(l)(ii) DY DN
(f) If the IFR has a secondary seal, is it free of holes and tears? DY DN/A DN
§63.1063(d)(l)(ii)
(g) If the primary seal is a mechanical/metallic shoe seal:
- Does the lower end of the metallic shoe seal extend into the stored D Y D N/A D N
liquid (no specific distance)?
- Does a flexible coated fabric span the space between the metal shoe D Y D N/A D N
and the tank wall?
(h) If the primary seal is a liquid-mounted seal, is the seal is in contact with DY D N/A DN
the liquid between the wall of the storage tank and the IFR?
4. Inspect deck openings.
(a) If the IFR is non-contact, is the lower edge of each opening in the DY DN/A DN
floating roof, except automatic bleeder vents and rim space vents, below
the surface of the stored liquid?b §63.1063(a)(2)(i)
(b) Except for automatic bleeder vents, rim space vents, deck drains, leg D Y D N/A D N
sleeves, and openings for fixed roof support columns, does each
opening in the roof have a gasketed cover?b §63.1063(a)(2)(ii)
(c) Is each gasketed cover, seal, or lid on any opening in the IFR closed, D Y D N/A D N
except when it must be open for access?*3 §63.1063(b)(3)
(d) Does each opening for a fixed roof support column have either a D Y D N/A D N
flexible fabric sleeve seal or a gasketed cover?b §63.1063(a)(2)(iv)
4-15
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-3. (continued)
II. Visual Inspection
(e) Is the cover on each access hatch and gauge float well designed to be D Y D N/A D N
bolted or fastened when closed?b §63.1063(a)(2)(vi)
(f) Does each deck fitting gasket, seal, and wiper fit between the surfaces it D Y D N
is intended to seal without any gaps larger than 0.32 cm (1/8 in)?
§63.1063(d)(l)(v)
5. Inspect automatic bleeder vents (vacuum breaker vents).
(a) Is each automatic bleeder vent closed, except when required to be open D Y D N
to relieve excess pressure or vacuum? §63.1063(b)(4)
(b) Does each automatic bleeder vent have a gasketed lid, pallet, flapper, or D Y D N/A D N
other closure device?b §63.1063(a)(2)(iii)
6. Inspect each rim space vent.
(a) Is each rim space vent closed, except when required to be open to D Y D N
relieve excess pressure or vacuum? §63.1063(b)(4)
(b) Does each rim space vent have a gasketed lid, pallet, flapper, or other D Y D N/A D N
closure device?b §63.1063(a)(2)(iii)
1. Is each deck drain that empties into the stored liquid have either a gasketed DY DN/A DN
cover or a slit fabric seal or similar device that covers at least 90 percent of
the area of the opening?b §63.1063(a)(2)(v)
8. Does each unslotted guide pole well have a pole wiper?b DY DN/A DN
§63.1063(a)(2)(vii)
9. Does each unslotted guide pole have a gasketed cap on the end of the pole?b DY DN/A DN
§63.1063(a)(2)(vii)
10. Is the cap on each unslotted guidepole closed, except when guaging the DY DN/A DN
liquid level or taking liquid samples? §63.1063(b)(5)
11. Does each slotted guide pole have either of the following: (1) a pole wiper D Y D N/A D N
and pole float, or (2) a pole wiper and pole sleeve?b §63.1063(a)(2)(viii)
12. Does each sample well have either a gasketed cover or a slit fabric seal or DY DN/A DN
similar device that covers at least 90 percent of the area of the opening ?b
§63.1063(a)(2)(v)
III. Note All Deficiencies
4-16
-------
4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-3. (continued)
III. Note All Deficiencies
IFR = internal floating roof.
a If the IFR has a vapor-mounted seal as of April 4, 2002, the requirement for a liquid-mounted seal,
mechanical/metallic shoe seal, or a secondary seal is not required until the next time the storage tank is emptied
and degassed or November 10, 2013, whichever is earlier. §63.1063(a)(l)(ii)(D)
b If these requirements were not met for a floating roof in place as of April 4, 2002, then this requirement does not
apply until the earlier of the following dates: (1) the next time the storage tank is emptied and degassed, or (2) no
later than November 10, 2013. §63.1063(a) (2) (ix)
4-17
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-4. Compliance Checklist for Group 1 Storage Tanks Equipped with a Control Device
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement.
Note: Use this checklist in addition to the checklists in section 9 for the closed vent system and the
applicable checklist from section 10 for the type of control device that is used to reduce emissions
from the storage tank. Use the checklist in Table 4-6 instead of this checklist if the facility
complies with the alternative standard in §63.2505.
Storage Tank Identification:
I. Review of Records
1. Does the facility keep all of the following records of periods of planned routine
maintenance for the control device: §63.998(d)(2)(ii)
(a) Time of day and date when each period of planned routine maintenance starts? D Y D N
(b) Time of day and date when each period of planned routine maintenance ends? DY DN
(c) Description of the type of maintenance performed? DY DN
2. Do both of the following occur each time the facility has periods of planned routine
maintenance that exceed 240 hr/yr: §63.2470(d)
(a) The facility submitted an application to the Administrator requesting approval of
an extension to no more than 360 hr/yr that contained both of the following:
• An explanation of why the extension is needed? DY DN
A statement affirming that no material will be added to the storage tank D Y D N
between the time the 240 hr limit is exceeded and the date the control device
is returned to service?
(b) The application was submitted at least 60 days before the 240 hr/yr limit is D Y D N
exceeded?
3. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Note All Deficiencies
4-18
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-5. Compliance Checklist for Storage Tanks Using Vapor Balancing
Note: Use this checklist when emissions from a storage tank are vapor balanced to the tank truck,
railcar, or barge that delivered material to the storage tank. This checklist is designed only for
assessing operations at the miscellaneous organic chemical manufacturing source; it does not
address requirements for offsite facilities that clean or reload tank trucks, railcars, or barges. A
"yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement.
Storage Tank Identification:
I. Review of Records
1. Does the facility have records that the tank trucks, railcars, and/or barges D Y D N
from which the storage tank is filled meet U.S. DOT pressure requirements
in 49 CFRpart 180, 49 CFR 173.31, or 40 CFR 61.304(f), respectively?
§63.1259(b)(12) as referenced from §§63.2470(e) and 63.1253(f)(2)
2. Does the facility have a record of the pressure relief vent setting? DY DN
§63.1259(b)(12) as referenced from §§63.2470(e) and 63.1253(f)(5)
3. If the setting in item "2" above is less than 2.5 psig, did the facility provide D Y D N/A D N
rationale in the notification of compliance status report explaining why the
lower value is sufficient to prevent breathing losses at all times?
§63.2470(e)(3)
4. Does the facility have written certification from facilities that reload and/or D Y D N
clean the tank trucks, railcars, and barges that they will either reduce the
HAP content of the displaced vapor by >95 percent (and meet the
compliance requirements in subpart FFFF) or vapor balance to the tank from
which the tank truck or railcar is loaded? §63.1253(f)(7)(i) as referenced
from §63.2470(e)
5. For each leak detected during quarterly monitoring, does the facility have all
of the following records: §§63.1253(f)(5)(iii), 63.1255(g)(4), and
63.1259 (b) (12)
(a)
(b)
(c)
(d)
(e)
(f)
(g)
6. Are
The instrument?
The equipment identification number?
The operator name, initials, or identification number?
Date the leak was detected?
Date of first repair attempt?
Date of successful repair?
Maximum instrument reading measured by Method 21 after the leak is
successfully repaired or determined to be nonrepairable?
all records kept for at least 5 years? §63.10(b)(l)
DY
DY
DY
DY
DY
DY
DY
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DY
DN
DN
DN
DN
DN
DN
DN
DN
4-19
-------
4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-5. (continued)
II. Visual Inspections
1. Is there a pressure relief device on the storage tank, and does the pressure relief setting D Y D N
match the value specified in the notification of compliance status report?
III. Note All Deficiencies
U.S. DOT = U.S. Department of Transportation.
4-20
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-6. Alternative Standard Checklist
Note: Use this checklist when emissions from a Group 1 storage tank are vented to a control device and
the facility complies with the alternative standard specified in §63.2505. If the control device is
also used to control process vent emissions, then the applicable checklists in Section 11 may be
used to evaluate compliance with both the process vent and storage tank emission limits;
supplement that checklist with questions regarding planned routine maintenance of the control
device in this checklist. A "yes" response to a question in this checklist means compliance with
that requirement, and a "no" response means noncompliance with the requirement. If a question
is not applicable, check the "N/A" box.
Storage Tank Identification:
I. Review of Records
1 . Does the facility have all of the following initial compliance records:
(a) Documentation that the Administrator was notified at least 60 days D Y D N
before conducting a performance evaluation of the CEMS? §63.8(e)(2)
(b) Results of CEMS performance evaluations (and measurements needed to D Y D N
determine conditions of performance evaluation)? §63.10(b)(2)(viii)
and (ix)
(c) Identification of target analytes or predominant HAP that are used in DY DN
calibrating the CEMS in the notification of compliance status report?
§§63.2505(b)(3) and 63.2450(j)(2)
(d) Inclusion of the storage tank in all applicable MCPU operating D Y D N
scenarios? §63.2525(b)
(e) Written copies of all of the procedures (e.g., calibrations) that are part of DY DN
the quality control program? §§63.8(d)(2) and 63.10(c)(14)
2. Does the facility have all of the following ongoing quality control records:
(a) CEMS calibration checks? §63. 10(b)(2)(x) DY DN
(b) Adjustments and maintenance performed on the CEMS? DY D N/A DN
§63.10(b)(2)(xi)
3. Does the facility have all of the following operating records:
(a) All CEMS measurements when the storage tank is in service (including D Y D N
periods of SSM, unavoidable CEMS breakdowns, and out-of-control
periods)? §63.10(b)(2)(vii) and(c)(l)
(b) Date and time when CEMS was malfunctioning or inoperative (except D Y D N/A D N
for zero [low-level] and high-level checks)? §§63.10(b)(2)(vi) and
(c) Nature and cause of malfunctions (if known) and corrective actions DY D N/A DN
taken? §63. 1 0(c) (1 0) and (1 1)
(d) Date and time when CEMS was out of control (e.g., calibration drift DY DN/A DN
exceed specifications or CEMS fails cylinder gas audit)?
§63. 10(b) (2) (vi) and (c) (6) _
4-21
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-6. (continued)
I. Review of Records
(e) Date and time of each deviation from the outlet concentration emission D Y D N/A D N
limit, and whether or not the deviation occurred during a period of
startup, shutdown, and malfunction? §63.2525(h)
4. Are the CEMS data (excluding data collected when the CEMS was out of DY DN
control) reduced to operating day averages for comparison with the outlet
concentration emission limits? §§63.2505(b)(7) and 63.8(c)(7)(ii)
5. If the storage tank emissions are combined with supplemental gases before DY DN/A DN
the control device, do records show the facility does either of the following:
(a) Corrects the concentrations to account for dilution caused by
supplemental gases using the procedures specified in §§63.2450(i) and
63.2460(c)(6)? §63.2450(j)(5)
(b) Monitors operating parameters as specified in §63.1258(b)(5)(ii)?
§63.2505 (b)
6. If the facility uses the exemption for periods of planned routine maintenance DY D N/A DN
for a shared control device, are storage tank emissions the only emissions that
are not controlled during such periods? §63.2505(b)(9)
7. Does the facility keep all of the following records of periods of planned
routine maintenance for the control device: §§63.998(d)(2)(ii) and
6 3.2 50 5 (b) (9)
(a) Time of day and date when each period of planned routine maintenance DY DN/A DN
starts?
(b) Time of day and date when each period of planned routine maintenance DY DN/A DN
ends?
(c) Description of the type of maintenance performed? DY D N/A DN
8. Do both of the following occur each time the facility has periods of planned
routine maintenance that exceed 240 hr/yr: §§63.2470(d) and 63.2505(b)(9)
(a) The facility submitted an application to the Administrator requesting
approval of an extension to no more than 360 hr/yr that contained both
of the following:
• An explanation of why the extension is needed? DY D N/A DN
A statement affirming that no material will be added to the storage D Y D N/A D N
tank between the time the 240 hr limit is exceeded and the date the
control device is returned to service?
(b) The application was submitted at least 60 days before the 240 hr/yr limit D Y D N/A D N
is exceeded?
4-22
-------
4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-6. (continued)
I. Review of Records
9. If the facility complies with the 95 percent reduction emission limit for
scrubbers used to control hydrogen halide and halogen HAP generated by a
combustion device, does the facility have the following records:
(a) Continuous monitoring records for all of the following scrubber
operating parameters: §§63.994(c), 63.2505(b)(5)(ii), and 63.2450(k)
(Note that the continuous records are not required under alternative
recordkeepingprovisions in §63.998(b)(l)(iii) or (b)(5).)
pH or caustic strength? DY D N/A DN
Liquid flow? DY D N/A DN
Gas flow (if complying with §63.994(c)(l)(ii)(B))? DY D N/A DN
(b) Performance test and operating limits that were determined during the D Y D N/A D N
test for pH (or caustic strength) and liquid-to-gas ratio?
§§63.2505(b)(5)(i), 63.998(a)(2)(ii)(D), and 63.999(a)(2) and (b)(3)
(c) Daily averages of pH or caustic strength and liquid-to-gas ratio (or a DY DN/A DN
record that all values for an operating day met the operating limit)?
§§63.2505(b) (7) and 998(b) (3)
(d) The following CPMS records: §63.998(c) (1) and (d) (5)
Procedure used for calibrating the CPMS? D Y D N/A D N
• Date and time of completion of calibration and preventive DY DN/A DN
maintenance?
"As found" and "as left" CPMS readings, whenever an adjustment D Y D N/A D N
is made that affects the CPMS reading, and a "no adjustment"
statement otherwise?
Start time and duration (or start and stop times) of any periods DY D N/A DN
when the CPMS is inoperative?
Occurrence and duration of each start-up, shutdown, and DY DN/A DN
malfunction during which excess emissions occur?
If excess emissions occur during a period of SSM, documentation D Y D N/A D N
that procedures in the SSM plan were followed or a description of
actions taken?
Documentation of each SSM event? DY DN/A DN
• If no excess emissions occur during an SSM event, documentation D Y D N/A D N
affirming this result?
Occurrence and cause of periods when the monitored parameters DY DN/A DN
do not meet the operating limits?
10. Are all records kept for at least 5 years? §63.10(b)(l) D Y D N
4-23
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4.0 Storage Tanks, Surge Control Vessels, and Bottoms Receivers
Table 4-6. (continued)
II. Visual Inspections
1. Are CEMS for TOC and/or total hydrogen halide and halogen HAP, as DY DN
applicable, located in the exhaust line from the control device?
2. If the facility is monitoring control device parameters instead of correcting DY D N/A DN
measured concentrations to account for dilution caused by mixing the
emission stream with supplemental gases, are the appropriate monitoring
devices present and operating?
3. If the facility is complying with the 95 percent reduction emission limit, are
the following devices present and operating:
(a) pH or caustic strength monitoring device? D Y D N/A D N
(b) Liquid flow monitoring device? D Y D N/A D N
(c) Gas flow monitoring device (if complying with DY D N/A DN
§63.994(c)(l)(n)(B))?
(d) If flow can be intermittent, a flow indicator at the inlet or outlet to the DY DN/A DN
scrubber?
III. Note All Deficiencies
CEMS = continuous emissions monitoring system.
CPMS = continuous parameter monitoring system.
HAP = hazardous air pollutant.
MCPU = miscellaneous organic chemical manufacturing process unit.
SSM = startup, shutdown, and malfunction.
TOC = total organic compounds.
4-24
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5.0 Wastewater Systems
5.0 Wastewater Systems
This section contains applicability and control flowcharts and inspection checklists for
wastewater systems. Use Figure 5-1 to determine if a water-containing stream is wastewater. Use
Figure 5-2 to determine if a wastewater stream is process wastewater or maintenance wastewater. For a
process wastewater stream, use Figure 5-3 to determine if it is a Group 1 process wastewater stream that
is subject to management and treatment requirements under subpart FFFF. Figures 5-4 through 5-6
identify the emission suppression requirements for waste management units (WMUs) that are used to
convey, store, or treat Group 1 process wastewater streams. Figure 5-7 identifies treatment options for
Group 1 process wastewater streams. Use Figure 5-8 to identify items of equipment that manage liquid
streams in open systems within an MCPU that are subject to control requirements.
For each Group 1 process wastewater stream, use the applicable inspection checklists to
determine compliance with the emission suppression and treatment requirements. The checklist in Table
5-1 is used to identify wastewater streams and residuals that are managed and treated in a similar manner.
It is also used to identify the WMUs in the wastewater system for those streams and points you to the
applicable checklists for those WMUs. Table 5-2 identifies the appropriate checklists for each type of
waste management unit depending on the emission suppression technique that is used. Tables 5-3
through 5-7 present checklists for inspections of wastewater tanks, surface impoundments, containers,
individual drain systems, and oil-water separators, respectively. Table 5-8 is a checklist for visual
inspections of leaks from covers, fixed roofs, and enclosures that are used to suppress emissions from any
type of WMU. Table 5-9 is a checklist for wastewater treatment systems that comply with the alternative
requirements for wastewater that is Group 1 only for SF£AP. Table 5-10 is a checklist for steam stripper
treatment units, and Table 5-11 is a checklist for other types of treatment units.
This section also includes a checklist for equipment within a process that conveys or receives
water streams that meet the flow rate and F£AP concentration thresholds that are used to define Group 1
process wastewater streams. Table 5-12 is a checklist for emission suppression techniques that are
specific to these items of equipment.
5-1
-------
5.0 Wastewater Systems
Start for water
streams
s the stream
discarded from an
MCPU?
Does the
stream originate as
storm-water from
segregated
sewers?
Does the
stream originate from
Ire-fighting and deluge
systems, including testing
of these systems'
Does the
stream originate
from equipment
leaks?
Does the
stream originate
from safety
showers'
The stream Is not
wastewater
f Continue at (A)
Figure 5-1. Applicability for wastewater.
5-2
-------
5.0 Wastewater Systems
Notes:
PSHAP means partially soluble HAP as listed in
Table 8 to subpatl FFFF
SHAP means soluble HAP as listed In Table 9
to subpart FFFF
" Use methods in §63,144{b)
" Use methods in §63 144(c)
Does the
stream originate as
wastewater d ri ps from
procedures such as
disconnecting hoses
after cleaning
lines?
Is the
stream a
sample of a size
not greater than reasonably
necessary foe the method
of analysis that
is used?
The stream is not
Does ttie
stream originate from
noncontact cooling
watar?
Is the
total SHAP and
PSHAP annual average
concentration
Is the
tola! SHAP and
PSHAP annual average
concentration > 10.000
pprnw?"
The stream is not
wastewater.
Is the
annual average tow
rate > 0.02 liters per
minute?*
3_£
The stream is
wastewater.
Figure 5-1. (continued)
5-2
-------
5.0 Wastewater Systems
I Start few each
\ waste*ater stream /
Is the
wastewaler from
routine cleaning operations
occurring as part of
batch operations?
Is the
astewatef from descaling
of heat exchanger tubing
bundles?
Is the
wastewaler from cleaning
distillation column
traps?
Is the
wastewater drained from
pymps?
Is the
wastewater process
uid drained from any portion
of trie MCPU for repair of in
preparation for or during any
other maintenance
oclivity?
{ Continue at (A)
V w
The wastewater is process
wastewater. See Figure 5-3 to
determine whether it is a Group 1 or
Group 2 process wastewater stream.
The wa&Eewater Is maintenance
wastiwater. Comply with the
requirements for maintenance
wastewater in Tafofe 7 to
subpart FFFF.
Figure 5-2. Applicability of process or maintenance wastewater.
5-4
-------
5.0 Wastewater Systems
Is the
wastewater product lank
drawdown or feed tank
drawdown?
Is the
wastewater water
formed during chemical
reaction or used as a
reactarrt?
Is the
wastewater water
used to wash impurities
from organic products or
reactants'-'
Is the
wastewater water
used to cool of quench organic vapor
streams through direct
contact?
Is the
wastewater condensed
steam from jet ejector systems pulling
vacuum on vessels containing
organics?
During any
other manufacturing
or processing step did the
wastewater come into direct contact
with or result from She production or
use of any raw material, intermediate
product, finished product,
by-product, or
waste product?
Yes—
Yes—
•Yes—I
The wastewater is
process wastewater. See
Figure S3 to determine
whetter it is a Group 1 or
Group 2 precess
wastewater stream
The wastewater is not process wastewater or
maintenance waslewater. No control is required.
Figure 5-2. (continued)
5-5
-------
Start (or each
ss wastewster
stream
The was'ewater stream is Group 1
for the HAP in Table 8 to subpart G
that are present at > 10 pprnw.
Also determine if the wastewater is
Group 1 for HAP in Tables 8
and 9 to subpart FFFF.
Is the
concentration of
any individual HAP in
Table 8 to subpart G
> 10 ppmw
Is the
process wastewater
designated as a Group 1
wastswatar
stream ?
Is the
wastewater stream
part of a new
source'
The wastewater stream
is subject to the
process wastawater
requirements in Table 7
to subpart FFFF.
Is the
PSHAP concentration
> 10. DM ppnriw?
Is the
PSHAP concentration
> 1.000 ppmw?
Is the
annual average
ftowrate of wastewater
> 1 liter per
minute?
Is the
total PSHAP and
SHAP concentration
> 30,000
ppmw?
The wastewater stream
is Group 2 for HAP in
Tables 8 and 9 to
subpart FFFF..
Is the
total annual load
of PSHAP
> 200 IWyr?
Is the total
annual load of
PSHAP and SHAP
> 1 ipy"?
The wastewater stream is a Group 1 process wastewater and is subject to the process wastewater
requirements in Table 7 to subpart FFFF.
The wastewater stream
is Group 2 for HAP in
Tables 8 and 9 to
subpart FFFF.
I
Figure 5-3. Determination of group status for process wastewater streams.
-------
AND
IF 1
Wastewatcr Tanks
(§§63.133and63.24B5(d))
Waste Management Units
for Group 1 Wastewater
and Residuals8
AND
P
Surface Impoundments
(§63.134)
4 1
See Figure 5-6
Must meet one of these
control requirements:1
» An air-supported or rigid
cover with a closed-vent
system that routes
organic HAP vapors to a
control devced
0«
• Floating flexible
membrane cover
i
AMR
r\nu
f
Containers'1
(§63.135)
|
Musi meet these control
requirements:'1
• A cover on each container
used to handle, transfer,
of store Group I
wastewater
AND
« For containers with a
capacity > 0,42 mj, a
submerged fill pipe must
be used
AND
« If treatment is performed
in the container, then
beats It In an enclosure
with a closed-vsnt system
that routes HAP vapors to
a control device'1
1
Afcli\
M
F
Individual Drain Systems
(§§63.136 and 63.2485(e))
|
Must meet either of these
control requirements:'
* Each opening of the drain
system must be covered,
anrS if vented, route HAP
vapors to a control device"
OR
» Each drain must be
equipped with water seal
controls and/or tightly
fining caps and plugs;
each junction box must be
equipped with a cover.
and if vented," vapors
must be routed to a
cant ol device"3; and sewer
lines must not be open to
the atmosphere'
1
r
Oil-Water Separators
(§63.137)
|
Must meet either of these
control requirements-;'7
• A fixed roof and a clos-e-d-
vent system that routes
organic HAP vapors to a
control device"
cm
• A floating roof that meets
the requirements of
sobpart QQQ d 40 CFR
60
An exemption for specific waste management units is illustrated in Figure 5-5,
Requirements apply only to containers with capacity >_ 0. 1 rnj. See Appendix B for definition of "container."
Part of the requirements for each WMU includes periodic inspections foe improper work practices and control equipment failures and any necessary repairs, See the
checklist in Table 5-8.
The oantrol device must reduce total organic HAP by > 95% or to an outlet TOC or organic HAP concentration £20 ppimv. Note that the 20 pprnv option is not allowed
for noncornbusticfi devices used to control emissions from surface impoundments and containers. Alternatively, fie control device may be a combustion device with a
residence time > 0 5 seconds and a temperature > 7W"C. or a fare thai meets the conditions in §63.1 1(b), or a RCRA-permitted unit. Closed-vent systems may meet
the fequiremeflte in §63. 1 72 or §63. 1034 (see §63"24aS|f)).
Venting to the atmosphere is allowed under certain conditions as specified in §63.1 36(e)(2)(ii) and §63.2485|n'K'3}.
Venting to the atmosphere is allowed under certain conditions as specified in §63.2465
-------
5.0 Wastewater Systems
Use this flowchart to determine \
If a waste management unit is exempt \
from emission suppression J
requirements. /
is the waste
management unit an
'equalltation unit, neutralization*"
unit, or clarifer located prior to
an activated sludge unit in a
biological treatment
unit?
Yea
Is wastewater
"that is Group 1 for
the only Group I wastewater
Jhat is managed in the
management unit?
-Mo-
Does the
'biological treatment'
unit achieve a destruction
efficiency > 90%, as determined
vusing procedures specified inx
§63.2485
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5.0 Wastewater Systems
Are the
PSHAP and SNAP
emissions from the tank
more than 5% higher than if the
contents of the tank were not
heated, treated by
exothermic reaction,
or sparged'*
Aretha
contents of the wastewater
tanks heated, treated by means of
exothermic reaction.
or sparged?
Control emissions using a fixed roof
Is the
MTVP'ofthe
PSHAP and SWAP in
Ihe wastewater
> 52 kPa?
Is (he
capacity of the
wastewater tank
=• 151 m1?
is tie
MTVPcafthe
PSHAP and SNAP in the
wastewater
> 13,1 kPa?
Is Hie
capacity of the
wa&tewater tank
> 75 m3?
Control emissions using a ixed root
Yes-
Must use any of the following:*-"
• A fixed roof with a closed vent
system that routes organic HAP
vapors to a control device,'"'' or
* A fixed roof with an Internal floating
roof that meats the requirements of
§63.119(b) orsubpart WW, or
• An external floating roof that meets
tie requirements of §63 119(c) or
subpart WW
-Yes-
" Note that an exception to these emission suppression requirements is allowed for wastewater tanks that meet conditions described in
Figure 5-5
13 Periodic Inspections arid repairs for irr^woper work practices and control equipment failures arc required.
c The control device must reduce total organic HAP by i95% or to an outlet TOC or organic HAP concentration <.20 ppmv. Alternatively,
the control device may be a combustion device witi a residence time > 0.5 seconds and a temperature > 760°C. or a flare that meets
the conditions in §63.11{b), or a RCRA-perrnitted unit. Secticn 63 2485(d)(4) specifies that control device limits do not apply for up to
240 hr/yr of planned routine maintenance (extendable to 360 hr/yr with approval)
"Closed-vent systems may meal the requirements in pa. 172 or §£3.1034 (see §63.24aS(f'j).
1MTVP means maximum true vapor pressure.
Figure 5-6. Requirements for wastewater tanks.
5-9
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5.0 Wastewater Systems
wastewater streams.
that are Group 1 for
Achieve 90% reduction in
PSHAP and SHAP in
accordance with pro
specified in S63.2485fnX2}.°
HAP in Tab es 8 and
i.e., new or existing
Achieve the RMR to
SHAP and/of PSMAP
For all Group 1 and
Group 2 wastewater from
MCPU's sent to the biological
treatment unit, aciiwve RfylR of
at least 95% for total SHAP
and PSHAP
Exempt this stream from
complete treatment by
demonstrating that the total mass
of total PSHAP and SHAP In
untreated or partially treated
Group 1 wastewater
is < 1 megagram per yesr
(§63138(1))
Operate and maintain a
deslqn steam stripper
Was the
wastewater
designated as a
Group 1
wastewater
stream? .
/ Achieve the RMR fa HAP
I in Table 8 to subpart G
Group 2 wastewatef
from MCPU's ssnt to the
biological treatment unit,
achieve RMR of at least 95%
for HAP In Table 8
to subpart G
Exempt this stream from
complete treatment by
demonstrating that the total
mass of HAP in
Table 8 to subpart G is
< 1 mfr^agram p&r
(§63.138(i»
Achieve the required mass \ / Achieve the required mass
removal (RMR) for SHAP I ( removal (RMR) fa HAP in
and/or PSHAP J V Table 8 to subpart G
Treat the wastewater
stream in a RCRA unil
/ Reduce mass flow rats \
—-W of PSHAP and/of SHAP by J
V 99% or by Fr value /
V . -s
Reduce 1he total
concentration of PSHAP and
SHAP to t 50 ppmw
C Reduce mass flow rate
for HAP in Table 8 to
Subpart G by 99%
I Reduce the total \
I concentration of HAP In Table 8 V
V to subpart G to < 10 ppmw J
Was
the wastewater
designated as a
Group 1
wastewater
stream?
Motes:
' PSHAP means partially soluble HAP listed in Table 8 to subpart FFFF.
i SHAP means soluble HAP listed in Table 9 to subpart FFFF.
i RMR (required mass removal) is a function of the density* and flowrate of the wastewater stream and the ooncentration and Fr valiw
of each HAP In the stream. For more Information, see §63.145.
Note that this option is allowed only if wastewater is Group 1 only for SHAP Moreover, this option specifies collection system design
cfiterig in §63 2485(n)(1), and PSHAP in Group 2 streams that are co*nWned witfi the streams that are Group 1 foe SHAP also must
be Included In the 90% destruction efficiency. Wastewatar that Is Group 1 for PSHAP may be treated by other means to meet the
treatment requirements for PSHAP prior to complying with this option for SHAP, as specified in §63.24£5(n)(4}.
Figure 5-7. Treatment requirements for process wastewater streams.
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5.0 Wastewater Systems
Start !or llanos of equipment that convey or \
receive llqjkl streams
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5.0 Wastewater Systems
dram hub. manhole, lift station
trencti, pipe, or oil»water separator,
does it convey water that meets 1tie
orcentration, tew, arid toad
a in §63,24S5(
pmsnt is a tank
3ne or more
in watet thai
nual average flow rate of
a 0 02 liter D
Yes
Control the item of equipment as specffied
in Table 35 to subparf 6 of part 63
Figure 5-8. (continued)
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5.0 Wastewater Systems
Table 5-1. Inspection Checklist for Wastewater Streams and Residuals Subject to Subpart FFFF
Note: Use this checklist for each of the following types of streams that are subject to subpart FFFF:
Group 1 wastewater streams
• Residuals from Group 1 wastewater streams
• Group 2 wastewater streams that are combined with a Group 1 wastewater stream for which
compliance is based on the 95 percent RMR option in §63.138(g) for biological treatment, or
the 90 percent reduction option in §63.2485(n).
Note: Records of other Group 2 determinations must be included in the notification of compliance
status report (see the checklist in Table 12-1).
1. Wastewater Stream and Residual Identification:
Note: Identify all streams (wastewater and residuals) that are discharged to the same
drain system and conveyed to the same treatment unit.
2. Which of the following WMUs, including treatment processes, are used to convey,
store, or treat the identified wastewater stream(s) and/or residual(s)? Check all that
apply. For example, note that a tank that is used to operate a closed biological
treatment process, and for which initial compliance was not demonstrated in
accordance with §63.145(f) or (g), is subject to the emission suppression requirements
for a wastewater tank as well as the requirements for biological treatment processes.
§63.138(a)(3)
D Wastewater tank (see Table 5-2 for appropriate checklists)
D Surface impoundment (see Table 5-2 for appropriate checklists)
D Container (see Table 5-2 for appropriate checklists)
D Individual drain system (see Table 5-2 for appropriate checklists)
D Oil-water separator (see Table 5-2 for appropriate checklists)
D Steam stripper treatment unit (use the checklist in Table 5-10)
D Other treatment units (use the checklist in Table 5-11)
3. Which WMUs in the wastewater system for the identified wastewater stream(s) and/or
residual(s) are exempt from emission suppression requirements? Check all that apply;
if any apply, use the checklists in Tables 5-9 and 5-11 in addition to other applicable
checklists as noted in Table 5-2. §63.2485(n)
D Wastewater tank
D Surface impoundment
D Clarifier
D None
RMR = required mass removal.
WMU = waste management unit.
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5.0 Wastewater Systems
Table 5-2. Applicable Checklists for Emission Suppression Options for Waste Management Units
Note: Use the guidance below to identify the appropriate inspection checklists to determine compliance
with the emission suppression requirements for WMUs that manage, store, and/or treat Group 1
process wastewater streams and residuals.
Note: Appendix D to this document includes a tabular summary of inspection requirements (i.e.,
inspections for improper work practices, control equipment failures, and leaks) for all WMUs.
The summary identifies the type of inspection (i.e., inspections for improper work practices,
control equipment failures, and leaks), the section of the rule that requires the inspection, the
required frequency of inspections, and the methods to use.
If the wastewater
system includes a(n) ...
And emissions must be suppressed
using ...
Then use the checklists in ...
wastewater tanka a fixed roof with a closed-vent system Tables 5-3, 5-8, 9-1, 9-2, and the
routed to a control device, or applicable table in Section 10 for the
specific control device that is used
an EFR, or Tables 5-3 and 4-2c
a fixed roof with an IFR, or an EFR Tables 5-3 and 4-3c
converted to an IFR, or
a fixed roofb Table 5-3
surface impoundment3 a cover with a closed-vent system routed Tables 5-4, 5-8, 9-1, 9-2, and the
to a control device, or applicable table in Section 10 for the
specific control device that is used
a floating flexible membrane cover Tables 5-4 and 5-8
container3 a cover, or Tables 5-5 and 5-8
a cover and enclosure with a closed-vent Tables 5-5, 5-8, 9-1, 9-2, and the
system to route emissions to a control applicable table in Section 10 for the
device specific control device that is used
individual drain system a cover and, if vented, emissions are Tables 5-6, 5-8, and if a cover is vented
routed to a process or through a closed- to a control device, Tables 9-1, 9-2, and
vent system to a control device, or the table in Section 10 for the specific
control device that is used
water seal controls or a tightly fitting cap Tables 5-6, 5-8, and if a cover is vented
or plug for drains, tightly fitting solid to a control device, Tables 9-1, 9-2, and
covers or vented covers for junction the table in Section 10 for the specific
boxes, and closed sewer lines control device that is used
oil-water separator a fixed roof and closed-vent system Tables 5-7, 5-8, 9-1, 9-2, and the
routed to a control device, or applicable checklist in Section 10 for the
specific control device that is used
a floating roof
Table 5-7
(continued)
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5.0 Wastewater Systems
Table 5-2. (continued)
EFR = external floating roof
IFR = internal floating roof
WMU = waste management unit.
a The emission suppression requirements are not applicable if the WMU is also a biological treatment unit for which
initial compliance with the treatment requirements is demonstrated by determining the fraction biodegraded in the
treatment unit in accordance with §63.145(f) or (g). §63.138(a)(3)
" See Figure 5-5 for conditions under which a fixed roof alone is sufficient.
c Note that the rule citations in Tables 4-2 and 4-3 are for sections in subpart WW rather than subpart G; the
requirements, however, are essentially the same in both subparts.
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5.0 Wastewater Systems
Table 5-3. Compliance Checklist for Inspections of Wastewater Tanks for Improper Work
Practices and Control Equipment Failures
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the requirement is not applicable,
check the "N/A" box.
I. Review of Records
1. Is the occurrence of each semiannual visual inspection of wastewater tanks for D Y D N
improper work practices recorded? §§63.133(f), 63.147(b)(l), and Table 11
to subpart G
2. Is the occurrence of each semiannual visual inspection of wastewater tanks for D Y D N
control equipment failures recorded? §§63.133(g), 63.147(b)(l), and Table
11 to subpart G
Note: See Appendix Efor the types of control equipment failures listed in
§63.133.
3. If the wastewater tank is equipped with a fixed roof, and emissions are vented D Y D N/A D N
through a closed-vent system to a control device, is the occurrence of each
semiannual sensory inspection for leaks recorded? §63.133(b)(l)(i),
§63.147(b)(l), §63.148(b)(3), and Table 11 to subpart G
4. If the wastewater tank is equipped with an IFR, is the occurrence of each D Y D N/A D N
periodic inspection of the seals recorded (see Table 4-3 for the schedule
options)? §63.120(a)(2) and (3), §63.133(c), §63.147(b)(l), and Table 11 to
subpart G
5. If the wastewater tank is equipped with an EFR, is the occurrence of each D Y D N/A D N
inspection of the seals recorded (annually for the secondary seal and every 5
years for primary seals)? §63.133(d), §63.143(a), §63.147(b)(l), and Table
11 to subpart G
6. For each inspection during which a control equipment failure (as defined in
§63.133(g)(l)) was identified, were all of the following recorded and reported
in the next compliance report: §63.146(c)
(a)
(b)
(c)
(d)
(e)
7. Are
Date of the inspection?
Identification of the
wastewater
tank having the failure?
Description of the failure?
Description of the nature of the
Date the repair was
all records kept for
made?
repair?
D
D
D
D
D
Y
Y
Y
Y
Y
D
D
D
D
D
at least 5 years? §63.10(b)(l)
N/A
N/A
N/A
N/A
N/A
DY
D
D
D
D
D
D
N
N
N
N
N
N
5-16
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5.0 Wastewater Systems
Table 5-3. (continued)
II. Visual Inspections
1. Are all openings (e.g., hatches, sampling ports, and gauge wells) closed (e.g., DY DN
covered by a lid) except when in use (e.g., it is in use during wastewater
sampling or removal or for equipment maintenance, inspection, or repair)?
§63.133(f)
III. Note All Deficiencies
EFR = external floating roof.
IFR = internal floating roof.
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5.0 Wastewater Systems
Table 5-4. Compliance Checklist for Inspections of Surface Impoundments for Improper Work
Practices and Control Equipment Failures
Note: A "yes
"no" response means
check the "N/A" box.
response to a question in this checklist means compliance with that requirement, and a
ponse means noncompliance with the requirement. If the requirement is not applicable,
e "N/A" box.
I. Review of Records
1 . Is the occurrence of each semiannual visual inspection of surface D Y D N
impoundments for improper work practices recorded? §§63.134(c),
63.147(b)(l), and Table 11 to subpart G
2. Is the occurrence of each semiannual visual inspection of surface DY DN
impoundments for control equipment failures recorded? §§63.134(c),
63.147(b)(l), and Table 11 to subpart G
Note: See Appendix Efor the types of control equipment failures listed in
§63.134.
3 . For each inspection during which a control equipment failure (as defined in
§63.134(c)(2)) was identified, were all of the following recorded and reported
in the next compliance report: §63.146(c)
(a) Date of the inspection? DY DN/A DN
(b) Identification of the surface impoundment having the failure? DY D N/A DN
(c) Description of the failure? DY D N/A DN
(d) Description of the nature of the repair? DY D N/A DN
(e) Date the repair was made? DY DN/A DN
4. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspections
1. If the surface impoundment contains Group 1 process wastewater, is the cover D Y D N/A D N
in use? §63.134(b)(l)(iii) and (b)(2)(vii)
2. Are all openings in a rigid air-supported cover (e.g., access hatches, sampling D Y D N/A D N
ports, and gauge wells) closed (e.g., covered by a lid) except when in use
(e.g., it is in use during wastewater sampling or removal or for equipment
maintenance, inspection, or repair)? §63.134(b)(l)(ii) and (c)(l)
3 . If a flexible floating membrane is used, is it free of cracks, holes, gaps, or D Y D N/A D N
other open spaces between the cover section seams or between the interface of
the cover edge and its foundation mountings? §63.134(b)(2)(iii), (vi), and
4. Are all openings in a floating membrane cover equipped with a closure device DY DN/A DN
and secured in the closed position with no visible cracks, holes, gaps, or other
open spaces in the closure device or between the perimeter of the cover
opening and the closure device? §63.134(b)(2)(iv) and (c)
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5.0 Wastewater Systems
Table 5-4. (continued)
II. Visual Inspections
5. If a floating membrane cover is used on the surface impoundment, are all of
the following requirements met:
(a) Is the cover floating on the liquid surface over the entire area of the liquid D Y D N/A D N
surface? §63.134(b)(2)(i)
(b) Is the floating membrane cover made out of either of the following: D Y D N/A D N
§63.134(b)(2)(ii)
• high density polyethylene with a thickness of at least 2.5 millimeters,
or
• a material that has an equivalent organic permeability and integrity for
the intended life of the floating roof cover?
6. If a floating membrane cover has emergency drains for storm water removal, DY D N/A DN
are the drains equipped with either of the following: §63.134(b)(2)(v)
(a) A slotted membrane fabric cover that covers at least 90 percent of the
drain area opening, or
(b) A flexible fabric seal?
III. Note All Deficiencies
5-19
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5.0 Wastewater Systems
Table 5-5. Compliance Checklist for Inspections of Containers for Improper Work Practices and
Control Equipment Failures
Note: A "yes
"no" response means
check the "N/A" box.
response to a question in this checklist means compliance with that requirement, and a
ponse means noncompliance with the requirement. If the requirement is not applicable,
e "N/A" box.
I. Review of Records
1. Is the occurrence of each semiannual visual inspection of containers for D Y D N
improper work practices recorded? §63.135(e), §63.147(b)(l), and Table 11
to subpart G
2. Is the occurrence of each semiannual visual inspection of containers for DY DN
control equipment failures recorded? §63.135(e), §63.147(b)(l), and Table
11 to subpart G
Note: See Appendix Efor the types of control equipment failures listed in
§63.135.
3. For each inspection during which a control equipment failure (as defined in
§63.135(e)(2)) was identified, were all of the following recorded and reported
in the next compliance report: §63.146(c)
(a) Date of the inspection? DY DN/A DN
(b) Identification of the container having the failure? D Y D N/A D N
(c) Description of the failure? DY D N/A DN
(d) Description of the nature of the repair? D Y D N/A D N
(e) Date the repair was made? DY DN/A DN
4. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspections
1. Do the containers have covers? §63.135(b) DY DN
2. Is all control equipment functioning properly (e..g., covers, and doors are not DY DN
cracked, gapped, or broken)? §63.135(e)
3. Are the covers and all openings closed (e.g., covered by a lid) except when in DY DN
use (e.g., an opening is in use during filling, removal, inspection, sampling, or
pressure relief events related to safety)? §63.135(b)(3) and (c)(2)
5-20
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5.0 Wastewater Systems
Table 5-5. (continued)
II. Visual Inspections
4. For containers with a capacity greater than or equal to 0.1 nr but less than or D Y D N/A D N
equal to 0.42 m , are either of the following requirements met: §63.135(b)(2)
(a) The container meets existing DOT specifications and testing
requirements, or
(b) The cover is inspected for leaks as specified in §63.148 (see checklist in
Table 5-8)?
5. Are containers with a capacity greater than 0.42 nr equipped with a DY D N/A DN
submerged fill pipe that does not extend more than 6 in or within two fill pipe
diameters of the bottom of the container while the container is being filled?
§63.135(c)(l)
6. Whenever a container with a capacity greater than or equal to 0.1 nr is used D Y D N/A D N
to treat a Group 1 wastewater stream or residual, and it is necessary for the
container to be open, is the container located within an enclosure that has a
closed-vent system to transport emissions to a control device? §63.135(d)
III. Note All Deficiencies
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5.0 Wastewater Systems
Table 5-6. Compliance Checklist for Inspections of Individual Drain Systems for Improper Work
Practices and Control Equipment Failures
Note: A "yes
"no" response means
check the "N/A" box.
response to a question in this checklist means compliance with that requirement, and a
ponse means noncompliance with the requirement. If the requirement is not applicable,
e "N/A" box.
I. Review of Records
1. Are all of the following records kept when compliance is met by covering all
openings in the drain system in accordance with §63.136(b) through (d)?
(a) A record of the occurrence of each semiannual visual inspection of the DY DN/A DN
individual drain system for improper work practices? §63.136(c),
§63.147(b)(l), and Table 11 to subpart G
(b) A record of the occurrence of each semiannual visual inspection of the DY DN/A DN
individual drain system for control equipment failures? §63.136(c),
§63.147(b)(l), and Table 11 to subpart G
Note: See Appendix Efor the types of control equipment failures listed in
§63.136.
(c) All of the following records for each inspection during which a control
equipment failure (as defined in §63.136(c)(2)) was identified:
§63.146(c)
• Date of the inspection? DY DN/A DN
• Identification of the individual drain system having the failure? D Y D N/A D N
• Description of the failure? DY D N/A DN
• Description of the nature of the repair? D Y D N/A D N
• Date the repair was made? DY DN/A DN
2. Are all of the following records kept when compliance is met by
implementing separate requirements for drains, junction boxes, and sewers as
specified in §63.136(e) through (g)?
(a) For drains with caps or plugs, documentation of the occurrence of each DY D N/A DN
semiannual visual inspection to ensure that the caps or plugs are in place
and properly installed? §§63.136(f)(l) and 63.147(b)(l)
(b) For drains with water seals, documentation of the occurrence of each D Y D N/A D N
semiannual verification that sufficient water is present to properly
maintain the integrity of the water seal? §§63.136(e)(l)(i), 63.143(a),
63.147(b)(l), and Table 11 to subpart G
(c) Documentation of the occurrence of each semiannual visual inspection of DY D N/A DN
junction boxes to ensure that there are no gaps, cracks, or other holes in
the cover? §§63.136(f)(2) and 63.147(b)(l)
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5.0 Wastewater Systems
Table 5-6. (continued)
I. Review of Records
(d) Documentation of the occurrence of each semiannual visual inspection of DY D N/A DN
the unburied portion of each sewer line to ensure that there are no cracks
or gaps that could result in air emissions? §§63.136(f)(3) and
63.147(b)(l)
3. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspections
1. Inspect all of the following items if all openings in the individual drain system
are covered in accordance with §63.136(b) through (d):
(a) Is the individual drain system designed and operated to segregate the D Y D N/A D N
vapors within the system from other drain systems and the atmosphere?
§63.136(b)(5)
(b) Are the cover and all openings (e.g., access hatches and sampling ports) D Y D N/A D N.
kept closed except when in use (e.g., an opening is in use during
sampling, removal, or equipment maintenance, inspection, or repair)?
§63.136(b)(l)(ii)
(c) Are the cover and all openings maintained in good condition? §63.136(c) DY D N/A DN
2. Inspect all of the following items for drains that are to be in compliance with
§63.136(e) through (g):
(a) Is each drain equipped with either a water seal (e.g., p-trap or s-trap) or a DY DN/A DN
tightly fitting cap or plug? §63.136(e)(l)
(b) For each drain equipped with a water seal, is water present in the water D Y D N/A D N
seal? §63.136(e)(l)(i)
(c) Is one of the following requirements met for each drain that is equipped DY D N/A DN
with a water seal: §63.136(e) (1) (ii)
• Does the drain pipe discharging the wastewater extend below the
liquid surface in the water seal, or
Is a flexible shield (or other enclosure that restricts wind motion)
installed that encloses the space between the discharge pipe and the
drain receiving the wastewater?
3. Inspect all of the following items for junction boxes that are to be in
compliance with §63.136(e) through (g):
(a) Are the junction boxes equipped with tightly-fitting solid covers (vented D Y D N/A D N
or unvented) that are free of gaps, cracks, or holes? §63.136(e)(2)
(b) If the covers are vented, are either of the following requirements met: D Y D N/A D N
5-23
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5.0 Wastewater Systems
Table 5-6. (continued)
II. Visual Inspections
• Is the vent pipe connected to a closed-vent system that transports
emissions to a process or control device (see checklists in Tables 8-1,
8-2, and Section 9), or §63.136(e)(2)
If vented to the atmosphere, is the vent pipe at least 90 centimeters in
length, is the diameter of the vent pipe less than 10.2 centimeters, and
is a water seal installed at the entrance or exit of the junction box?
§63.136(e)(2)(ti)
Note: Venting to the atmosphere is allowed only if the junction box is
filled and emptied by gravity flow or it is operated with only slight
fluctuations in the liquid level. Also, the specified vent pipe
dimensions do not apply for a lift station that is larger than 10,000
gal and used in a system complying with §63.2485(n). See the
checklist in Table 5-9.
4. If the individual drain system is to be in compliance with §63.136(e) through DY D N/A DN
(g), are the sewer lines enclosed or covered in a manner so that there are no
visible gaps or cracks in joints, seals, or other emission interfaces?
§63.136(e)(3)
Note: A sewer line that is connected to drains that are water sealed or
equippedwith a tightly fitting cap or plug in accordance with §63.136(e)(l)
may be vented to the atmosphere if the sewer line entrance to the first
downstream junction box is water sealed and the vent pipe is at least 90 cm in
length and no greater than 10.2 cm in nominal inside diameter.
§63.2485(e)(l)
III. Note All Deficiencies
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5.0 Wastewater Systems
Table 5-7. Compliance Checklist for Inspections of Oil-Water Separators for Improper Work
Practices and Control Equipment Failures
Note: A "yes
"no" response means
check the "N/A" box.
response to a question in this checklist means compliance with that requirement, and a
ponse means noncompliance with the requirement. If the requirement is not applicable,
e "N/A" box.
I. Review of Records
1. Is the occurrence of each semiannual visual inspection of the individual drain DY DN
system for improper work practices recorded? §§63.13 7(d) and 63.14 7(b) (1)
2. Is the occurrence of each semiannual visual inspection of the oil-water DY DN
separator for control equipment failures recorded? §§63.137(e) and
63.147(b)(l)
Note: See Appendix Efor the types of control equipment failures listed in
§63.137.
3. For each inspection during which a control equipment failure (as defined in
§63.137(e)) was identified, was all of the following information recorded and
reported in the next compliance report: §63.146(c)
(a) Date of the inspection? DY DN/A DN
(b) Identification of the individual drain system having the failure? D Y D N/A D N
(c) Description of the failure? DY D N/A DN
(d) Description of the nature of the repair? D Y D N/A D N
(e) Date the repair was made? DY DN/A DN
4. If the oil-water separator is equipped with a floating roof, do records indicate
all of the following:
(a) That seal gap measurements were performed annually for the secondary D Y D N/A D N
seal? §§63.137(c)(2) and 63.147(b)(l)
(b) That seal gap measurements were performed every 5 years for the primary D Y D N/A D N
seal? §§63.137(c)(l) and63.147(b)(l)
(c) The results of each seal gap measurement (i.e., the date of measurement, DY DN/A DN
raw data obtained, and calculations performed)? §63.147(b)(3)
5. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
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5.0 Wastewater Systems
Table 5-7. (continued)
II. Visual Inspections
Note: If the oil-water separator is equipped with a floating roof, the inspector should not perform
the inspection without proper respiratory protection if the roof is below 4 feet of the top of
the separator. Based on the inspector's assessment of the availability of records
documenting the design of the control equipment, an adequate inspection without respiratory
protection may be performed with a combination of a record inspection and a visual
inspection conducted from the platform with the aid of vision-enhancing devices
(binoculars). If the inspector feels that it is necessary to be on the EFR when the roof is
below 4 feet of the top of the tank, please be aware of the requirements under EPA Order
1440.2 (required only for Agency personnel) and the safety information in Guidance on
Confined Space Entry in NESHAP Inspections of Benzene Storage Vessels (EPA 455/R-92-
003, September 1992).
Note: Answer all questions in this section if the oil-water separator is equipped with a floating
roof. If it is equipped with a fixed roof that is vented to a control device, answer only
questions 1 through 3.
Note: The requirements in §60.693-2(a) are referenced from §63.137(a)(2).
1 . Are all openings in the fixed or floating roof equipped with a gasketed cover, D Y D N
seal, or lid? §§63.137(b)(l)(ii) and 60. 69 3-2 (a) (2)
2. Are all openings kept closed except when in use (e.g., an opening is in use DY DN
during sampling, removal of material, inspection, maintenance, or repair)?
§63.137(b)(l)(ii) and (d) for fixed roofs, and §60. 69 3-2 (a) (2) for floating
roofs
Note: Section 60. 693-2(a)(2) only allows openings for inspection and
maintenance.
3. Are gaskets, joints, lids, covers, and doors in good condition (i.e., not cracked, D Y D N
gapped, or broken) ? §63. 1 3 7(e) (1) (vii)
4. Is the floating roof resting on the liquid surface of the stored material, except DY DN/A DN
during abnormal conditions (i.e., low flow rates)? §§63.137(e)(l)(i) and
60. 69 3-2 (a) (3)
5. Is the floating roof in good condition (i.e., free of defects such as corrosion DY D N/A DN
and pools of standing liquid)? §63.137(e)(l)(ii)
6. Is a secondary seal installed above the primary seal for the floating roof? D Y D N/A D N
§§6 3. 137 (a) (2) and 60.693-2(a)(l)(i) and (ii)
7. Does the secondary seal meet all of the following requirements:
(a) Is the seal and seal fabric free of holes, tears, and other openings? DY DN/A DN
§63.137(e)(l)(iv)
(b) Is the seal continuously attached along the edge of the floating deck? D Y D N/A D N
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5.0 Wastewater Systems
Table 5-7. (continued)
II. Visual Inspections
(c) Does the seal completely cover the space between the edge of the floating
roof and the oil-water separator wall, except as allowed by both of the
following: §§63.13 7(e) (1) (vi) and 60.693-2(a) (1) (ii)
Is the total gap area between the separator wall and the secondary seal D Y D N/A D N
less than or equal to 6.7 square centimeters per meter of the separator
wall perimeter?
Is the maximum gap width between the separator wall and the seal D Y D N/A D N
less than or equal to 1.3 centimeters at all points along the separator
wall perimeter?
8. Does the primary seal meet all of the following requirements:
(a) Is the primary seal either a liquid-mounted seal or a mechanical shoe seal? D Y D N/A D N
§60.693-2(a)(l)(i)
(b) Is the seal fabric, seal envelope, or shoe (if a metallic shoe is used) free of D Y D N/A D N
holes, tears, and other openings? §63.137(e)(l)(iv)
(c) If the primary seal is a liquid-mounted seal (e.g., foam or liquid-filled DY D N/A DN
seal), is the seal in contact with the liquid between the wall of the oil-
water separator and the floating roof? §60.693-2(a)(l)(i)(A)
(d) Does the primary seal form a continuous closure that completely covers
the annular space between the wall of the oil-water separator and the edge
of the floating roof, except as allowed by both of the following:
§§63.137(e)(l)(v) and 60.693-2(a)(l)(i)(B) and (C)
• Is the total gap area between the wall of the oil-water separator and D Y D N/A D N
the primary seal less than or equal to 67 square centimeters per meter
of the separator wall perimeter?
• Is the maximum gap width between the wall of the oil-water separator D Y D N/A D N
and the seal less than or equal to 3.8 centimeters at all points along the
separator wall perimeter?
9. If the floating roof is equipped with one or more emergency roof drains for D Y D N/A D N
removal of stormwater, is each emergency roof drain equipped with either of
the following: §60.693-2(a)(4)
(a) A slotted membrane fabric cover that covers at least 90 percent of the
drain opening area, or
(b) A flexible fabric sleeve seal?
III. Note All Deficiencies
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5.0 Wastewater Systems
Table 5-7. (continued)
III. Note All Deficiencies
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5.0 Wastewater Systems
Table 5-8. Compliance Checklist for Inspection of Covers, Enclosures, and Fixed Roofs for Leaks
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the requirement is not applicable,
check the "N/A" box.
Note: This checklist does not apply to covers, fixed roofs, and enclosures that are maintained under
negative pressure. §§63.133(b)(4), 63.134(b)(5), 63.135(d)(4), 63.136(b)(4), and 63.137(b)(4)
I. Review of Records
1. Do records identify all parts of the covers, fixed roofs, and enclosures that are D Y D N/A D N
designated as unsafe to inspect or difficult to inspect, and do the records
explain why these designations were assigned? §63.148(i)(l) and (2)
2. Does the facility have a written plan for inspecting the unsafe-to-inspect parts DY DN/A DN
of the covers, fixed roofs, and enclosures as frequently as practicable?
§63.148(g)(2)and(i)(l)
3. Does the facility have a written plan for inspecting the difficult-to-inspect D Y D N/A D N
parts of the covers, fixed roofs, and enclosures at least once every 5 years?
§63.148(h)(2)and(i)(2)
4. For each inspection during which no leaks were detected, do records D Y D N/A D N
document the occurrence and date of the inspections along with a statement
that no leaks were detected? §63.148(b)(3) and (i)(6)
5. For each inspection during which a leak was detected, do records document
all of the following information: §63.148(i)(4)
(a) Operator name or initials, and identification of the leaking equipment? D Y D N/A D N
(b) Date the leak was detected? DY DN/A DN
(c) Date of the first attempt at repair? DY DN/A DN
Note: The first attempt at repair must be no later than 5 calendar days
after the leak was detected. §63.148(d) (I)
(d) Maximum instrument reading measured by Method 21 after the leak was D Y D N/A D N
repaired or determined to be nonrepairable?
(e) All of the following if the leak was not repaired within 15 calendar days
after the leak was discovered:
• Reason for the delay? DY DN/A DN
• Name, initials, or other form of identification of the person who DY D N/A DN
decided repairs could not be made without a shutdown?
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5.0 Wastewater Systems
Table 5-8. (continued)
I. Review of Records
Expected date of successful repair? D Y D N/A D N
Note: Delay of repair until the next shutdown is allowed if the repair
is technically infeasible without a shutdown, or if the emissions from
immediate repair would be greater than the fugitive emissions likely
from delay. §63.148(e)
(f) Dates of shutdowns that occur while the equipment is unrepaired? D Y D N/A D N
(g) Date of successful repair of the leak? DY DN/A DN
6. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Note All Deficiencies
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5.0 Wastewater Systems
Table 5-9. Checklist for Compliance with Alternative Requirements for
Wastewater that Is Group 1 Only for Soluble HAP
Note: Use this checklist for wastewater systems with an equalization unit, neutralization unit, and/or
clarifier that are exempt from the emission suppression requirements in accordance with
§63.2485(n). Also use the checklist in Table 5-11 for the biological treatment unit, and use
checklists in Tables 5-3 through 5-7 for WMUs that are not exempt.
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement.
Treatment Unit Identification:
I. Review of Records
1. Do records show the overall destruction efficiency of total PSHAP and SHAP DY DN
is calculated using Equation 1 in §63.2485(n)(2) and the destruction
efficiency is >90 percent? §63.2485(n)
Note: Streams that are Group 1 for PSHAP may be treated in accordance
with the requirements specified in Table 7 to subpart FFFF and then
combined with streams that are Group 1 only for SHAP. The combined
stream may comply with these alternative treatment requirement, and the
PSHAP remaining after treatment in accordance with the Table 7
requirements does not need to be included in the destruction efficiency
calculation under this alternative. §63.2485(n)(4)
2. Are all required records kept for at least 5 years? §63.10(b)(l) D Y D N
II. Visual Inspection
1. Are connections between the equalization unit, neutralization unit, and/or D Y D N
clarifier and the activated sludge unit made with hard piping? §63.2485(n)(l)
Note: The requirement for hard piping does not apply when transfer between
any of these types of units when the units are part of the same structure and
one unit overflows into the next.
III. Note All Deficiencies
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5.0 Wastewater Systems
Table 5-10. Compliance Checklist for Steam Strippers
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the requirement is not applicable,
check the "N/A" box.
check the "N/A" box.
Steam Stripper Identification:
I. Review of Records
1. Do records document that the facility continuously monitors all of the
following parameters, unless approval to monitor alternative parameters has
been granted: §63.143(b) and Table 12 to subpart G
(a) Steam flow rate? DY DN/A DN
(b) Wastewater mass flow rate? D Y D N/A D N
(c) Either wastewater feed temperature or column temperature? D Y D N/A D N
2. For the continuously monitored parameters identified in item 1 above, does D Y D N/A D N
the facility maintain records of continuously monitored parameters in one of
the following formats: §§63.147(d) and 63.152(f)(2) and (3)
(a) All measured values, or
(b) All block average values for 15-minute or shorter periods calculated from
all measured data values during each period (or from at least one
measured data value per minute if measured mor frequently than once per
minute), or
(c) All continuous records for only the current operating day, and block
hourly average values for earlier data?
Note: To use the third option, the daily average must be within the
established range.
3. Does the facility keep records of either the daily averages of each of the D Y D N/A D N
parameters in item 1 above or a statement that all values were within the
established operating range? §§63.147(d) and 63.152(f)(6)
4. As an alternative to items 3 and 4 above, does the facility meet both of the
following requirements: §63.152(g)(l)(i) through (vi)
(a) Document in their notification of compliance status report or compliance D Y D N/A D N
report that they were implementing this alternative?
(b) Retain only the daily average? DY DN/A DN
Note: No record of the daily average is required if 6 months have passed
without an excursion. §63.152(g) (2)
5. If the facility applied for and received approval to monitor parameters other DY DN/A DN
than those listed in item "2" of this checklist, is the facility performing the
approved recordkeeping and reporting? §63.147(e)
6. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
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5.0 Wastewater Systems
Table 5-10. (continued)
II. Visual Inspections
1. Are overheads from the steam stripper vented through a closed-vent system to D Y D N/A D N
a control device that meets the requirements of §63.139 (see checklists in
Tables 9-1 and 9-2 for the closed-vent system and the appropriate checklist in
Section 10 for the specific control device)? §63.138(a)(5)
2. If the steam stripper is a design steam stripper, does it meet all of the
following requirements: §63.138(d)
(a) Is the minimum active column height at least 5 meters? D Y D N/A D N
(b) Does the countercurrent flow configuration have at least 10 actual trays? D Y D N/A D N
(c) Is the steam flow rate at least 0.04 kilograms of steam per liter of D Y D N/A D N
wastewater feed?
(d) Is the temperature of the wastewater feed to the steam stripper (or the DY DN/A DN
column temperature) at least 95 °C?
(e) Is the wastewater liquid loading no greater than 67,100 liters per hour per DY D N/A DN
square meter?
(f) Does the steam stripper operate at nominal atmospheric pressure? DY DN/A DN
III. Note All Deficiencies
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5.0 Wastewater Systems
Table 5-11. Compliance Checklist for Treatment Processes Other than Steam Strippers
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the requirement is not applicable,
check the "N/A" box.
Treatment Process Identification:
I. Review of Records
1. Does the facility keep records as approved by the Administrator? D Y D N
§63.147(b)(4)
2. For each parameter approved by the permitting authority that is required to be DY D N/A DN
monitored continuously, are records of the daily average value kept?
§63.147(d)
3. If the facility has a biological treatment process and calculates the AMR based D Y D N/A D N
on the fraction biodegraded, are records kept of the Fblo determination?
Note: Fbio does not have to be determined for enhanced biological treatment
processes that meet the requirements in §63.145(h)(l)(ii).
4. Are all records kept for at least 5 years? §63.lO(b)(l) D Y D N
II. Visual Inspection
1. Are all gas streams from the treatment process vented through a closed-vent D Y D N D N/A
system to a control device that meets the requirements of §63.139 (see
checklists in Tables 9-1 and 9-2 for the closed-vent system and the appropriate
checklist in Section 10 for the specific control device)? §63.138(a)(5)
Note: An open or closed biological treatment unit for which compliance is
demonstrated in accordance with §63.145(f) or (g) does not have to be vented
to a control device that meets the requirements of §63.139. §63.138(a)(3)
Note: Another exception to the requirements in §63.139 is that a vent from
an anaerobic biological treatment unit may be routed through hard-piping to
a fuel gas system. §63.138 (a) (5)
2. Are monitoring devices present to conduct monitoring that was approved by DY DN DN/A
the Administrator or permitting authority? §63.143(c) and (d)
III. Note All Deficiencies
AMR = actual mass removal.
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5.0 Wastewater Systems
Table 5-12. Compliance Checklist for Equipment Handling In-Process Liquid Streams
Note: This checklist applies only to equipment of the type listed in Table 35 to subpart G that handle
streams within the MCPU that have the flow and concentration characteristics of a Group 1
process wastewater stream.
Note: A "yes
"no" response means
check the "N/A" box.
response to a question in this checklist means compliance with that requirement, and a
ponse means noncompliance with the requirement. If the requirement is not applicable,
e "N/A" box.
I. Visual Inspections"
1. Is each tank with a capacity >38 m3 equipped with a fixed roof? D Y D N/A D N
2. Are all drains and drain hubs equipped with either tightly fitting solid covers D Y D N/A D N
or water seals?
3. Do drains and drain hubs that are equipped with water seals also have either a D Y D N/A D N
submerged discharge or a barrier to protect the discharge from the wind?
4. Are all tightly fitting solid covers for drains, drain hubs, manholes, lift D Y D N/A D N
stations, and trenches free of visible gaps or openings, except during periods
of sampling, inspection, or maintenance?
5. For all tightly fitting solid covers with water seals and an atmospheric vent, D Y D N/A D N
are the vent pipes at least 90 cm in length with a nominal inside diameter less
than or equal to 10.2 cm?
6. For lift stations with tightly fitting solid covers and water seals, is the lift D Y D N/A D N
station level controlled to minimize changes in liquid level?
II. Note All Deficiencies
3 All requirements are from Table 35 to subpart G.
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5.0 Wastewater Systems
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5-36
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6.0 Equipment Leaks
6.0 Equipment Leaks
This section contains applicability and control flowcharts and inspection checklists for equipment
leaks. Use the flowchart in Figure 6-1 to identify equipment that is subject to the equipment leak
requirements in subpart FFFF and the control options for such equipment. Use the checklists in
Tables 6-1 through 6-3 to determine compliance with the various control options. Table 6-1 is for the
basic LDAR program that specifies different requirements for each type of equipment. Table 6-2 is for
the pressure test option. Table 6-3 is for processes or portions of processes that are enclosed and
emissions are vented to a process, fuel gas system, or control device.
As illustrated in Figure 6-1, the final rule requires compliance with one of three existing rules for
equipment leaks. These rules are 40 CFR part 63, subpart H; 40 CFR part 63, subpart UU; or 40 CFR
part 65, subpart F (also known as the Consolidated Federal Air Rule [CAR]). New sources must comply
with one of the cross-referenced rules in its entirety, but existing sources may elect to comply with
alternative LDAR requirements for certain connectors and pumps. The optional provisions for existing
sources are listed in Figure 6-1.
The checklists in this chapter are specifically designed for determining compliance with 40 CFR
part 63, subpart UU. Most of the requirements in subpart H and the CAR are essentially the same, but the
checklists do not include the specific citations for these rules. One requirement that differs among the
rules is the skip monitoring intervals for connectors. Figure 6-2 illustrates how to determine the
applicable interval under subpart UU and the CAR. The more complicated procedures in subpart H are
not illustrated.
6-1
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6.0 Equipment Leaks
/ The equipment is not in
/ organic HAP service and is
I not subject to requifernents
I forequipmentlsaks
\ in subpart FFFF.
The equipment is exempt from \
;he requirements for equipment l
leaks in subpart FFFF, J
Use Shis flowchart for
Equipment Leaks"
Does the
equipment either
contain or contact a iron
process fluid (e,g,, part -of a heating
and cooling system that does not
combine fluid
witti process
materials}?
Is the
equipment In vacuum
service?
Is the
fluid thai is in
contact with the equipment
5% organic HAP by
weight?'
The equipment is exempt from
emission control requirements if its
identity (by list, location, or other
method) is recorded.
Is the
equipment in organic
HAP service
<300 hr/yr?
No
Continue at f A
3 "Equipment" consists of pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-
ended valves and lines, valves, connectors, and instrumentation systems,
" Equipment Is presumed to be In organic HAP service unless you demonstrate that It Is not by following the procedures In
§63.180(d).
Figure 6-1. Applicability and requirements for equipment leaks.
6-2
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6.0 Equipment Leaks
Is the
equipment part of
a new affected soyroe und«
subpart FFFF?
Yes-
Comply with any of the following
requirements, except, as
provided below:
Sybpart H of 40 CFR part 63
- Subpart UU of 40 CFR part 83
- Subpart F of 40 CFR part 65
You may elect to comply with the
following alternatives to the
above requirements:
- You are not required to
develop an initial list of
identification numbers for
connectors
- All connectors may comply
with the requirements for
connactois in ts&avy
service
- If an MCPU has no continuous
process vents, you may
consider leaking pumps to bs
those with instrument readings
greater than or equal to
10,000 ppm
Comply with any of the following
requirements:
Sybpart H of 40 CFR part 63
- Subpart UU of 40 CFR part 63
- Subpart F of 40 CFR part 65
Figure 6-1. (continued)
6-3
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6.0 Equipment Leaks
Start
Monitor all connectors in the process
unit within one year after the
compliance date.
Did
> 0.5% of
your connectors leak
in tie monitoring
period?
Did
> 0.25% of
your connectors leak
in fie monitoring
period?
•Yes—»
Monitor all connectors in the process unit once during the
next year. Return to (S) at fie end of the year to
determine the subsequent monitoring frequency
•Yes—*•
Your new required monitoring frequency is at least once in
4 years. You must monitor 40% of the connectors in the
process unit in the fret 2 years, Return to i/V) at the end
of the 4-year period to determine subsequent monitoring
frequency
Your new required mentoring
frequency is at once in 8 years.
You must monitor 50% of the
connectors in the process unit In the
first 4 years.
Did
> 0.35% of
your connectofs leak
in the first 4-year
period?
Monitor all remaining connectors wihin 6 months. Then
determine the percent leaking connectors in the total
process unit, and return to (R) to determine the
subsequent monitoring frequency.
Monitor the remaining 50% of connectors in the second
4 years of the 8-year period. Return to $f) at the end of
the 8-year period to determine trie subsequent monitoring
frequency.
Figure 6-2. Flowchart of monitoring frequencies for connectors in gas/vapor service or
light liquid service under subpart UU and the CAR.
6-4
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6.0 Equipment Leaks
Table 6-1. Checklist to Demonstrate Compliance with the Basic LDAR Program
Note: Use this checklist to demonstrate compliance with the basic LDAR program requirements for
each type of equipment as specified in 40 CFR part 63, subpart UU. A "yes" response to a
question in this checklist means compliance with that requirement, and a "no"response means
noncompliance with the requirement. If a question is not applicable, check the "N/A" box.
Process or Process Area Identification:
I. Review of Records
1. Does the facility have the following equipment identification records as an
alternative to physically tagging each piece of equipment:
(a) General identification of equipment that is subject to subpart FFFF DY DN/A DN
(e.g., on a plant site plan, in log entries, designation of process unit or
affected source boundaries, etc.)? §§63.1022(a) and 63.1038(b)(l)
(b) Specific identification of connectors (either individually or the total D Y D N/A D N
number of connectors as a group in a designated area)?
§§63.1022(b)(l) and 63.1038(b)(l)
Note: This provision is optional for existing sources. §63.2480(b)(3)
Note: Inaccessible, ceramic, or ceramic-lined connectors are exempt
from this recordkeeping requirement.
(c) Specific identification of pumps in light liquid service, agitators, D Y D N/A D N
pressure relief devices in gas and vapor service, or compressors from
which leaks are routed to a process, a fuel gas system, or through a
closed-vent system to a control device? §§63.1022(b)(2) and
63.1038(b)(l)
Note: Go to item II. 7 in this checklist (i.e., Table 6-1) if emissions
from equipment leaks are routed to a process or fuel gas system. Go
to items 1.15 and II. 7 in this checklist if emissions are routed through
a closed-vent system to a control device. No other items in this
checklist apply to equipment leak emissions routed to a process, fuel
gas system, or through a closed-vent system to a control device.
(d) Specific identification of pressure relief devices that are equipped with DY DN/A DN
rupture disks? §§63.1022(b)(3) and 63.1038(b)(l)
(e) Specific identification of instrumentation systems? §§63.1022(b)(4) DY D N/A DN
and63.1038(b)(l)
(f) Specific identification (either by list, location, or other method) of D Y D N/A D N
equipment in organic HAP service less than 300 hours per calendar
year within the affected source? §§63.1022(b)(5) and 63.1038(b)(l)
(g) Identification of equipment designated as unsafe-to-monitor or DY D N/A DN
difficult-to-monitor? §63.1022(c) (3)
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6.0 Equipment Leaks
Table 6-1. (continued)
I. Review of Records
2. If the facility has designated any valves, pumps, connectors, and/or D Y D N/A D N
agitators as unsafe to monitor, do they have a written plan describing the
actual monitoring frequency that will be used (but not more frequently than
would otherwise be required) and stating that any such equipment that is
found to be leaking will be repaired following the same procedures as for
any other leaking equipment? §§63.1022(c)(4)(i) and 63.1038(b)(2)
Note: No other records described in this checklist (i.e., Table 6-1) apply to
equipment that is designated as unsafe to monitor.
3. If the facility has designated any valves and/or agitators as difficult to D Y D N/A D N
monitor, do they have a written plan describing the actual monitoring
frequency that will be used (at least once per year) and stating that any such
equipment that is found to be leaking will be repaired following the same
procedures as for any other leaking equipment? §§63.1022(c)(4)(ii) and
63.10 38 (b) (2)
Note: No other records described in this checklist (i.e., Table 6-1) apply to
equipment that is designated as difficult to monitor.
4. If the facility has designated any compressors as unsafe to repair, do D Y D N/A D N
records identify such compressors and explain why the connectors are
unsafe to repair? §§63.1022(d) (2) and 63.1038(b)(3)
5. If the facility has designated any compressors as operating with an DY D N/A DN
instrument reading of less than 500 ppm above background, do records
identify such compressors? §§63.1022(e) and 63.1038(b)(4)
6. If the facility has determined that any equipment is in heavy liquid service, D Y D N/A D N
do they have records of the information, data, and analyses used to make
such determinations? §§63.1022(f)(l) and 63.1038(b)(5)
1. When leaks are detected by instrument monitoring (for valves, pumps,
connectors, agitators, pressure relief devices, and compressors) or by
sensory monitoring (for pumps and agitators), does the facility maintain all
of the following records: §§63.1023(e)(2), 63.1024(f), and 63.1038(b)(6)
and (7)
Note: Although the rule does not explicitly require identification of leaking
equipment, the records must be sufficiently specific to allow an inspector to
determine compliance with the equipment leak repair requirements.
(a) The date of the first attempt to repair the leak? DY DN/A DN
(b) The date of successful repair of the leak? DY DN/A DN
(c) The maximum instrument reading measured by Method 21 at the time DY D N/A DN
the leak was repaired or determined to be nonrepairable
6-6
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6.0 Equipment Leaks
Table 6-1. (continued)
I. Review of Records
(d) The reason for the delay if the leak was not repaired within 15 D Y D N/A D N
calendar days after the leak was detected?
Note: Section 63.1024(d) specifies conditions under which delay of
repair is allowed.
Note: For a valve, if delay of repair beyond a process unit shutdown
was caused by depletion of stocked parts, the records must also
document that the spare parts were sufficiently stocked on-site before
depletion and the reason for depletion.
(e) The dates of process unit (or affected source) shutdowns that occurred DY DN/A DN
while the equipment was unrepaired?
8. For valves in gas and vapor service or in light liquid service, does the
facility keep records of both of the following, as applicable:
(a) The monitoring schedule? §§63.l025(b)(3)(vi) and 63.l038(c)(l)(i) D Y D N/A D N
(b) All of the following information for valve subgroups:
§§63.1025(b) (4) (iv) and 63.1038(c) (1) (ii)
Note: Subgroups for a process unit or affected source are allowed
only if less than 2 percent of the total number of valves in all
subgroups are determined to be leaking.
• Which valves are assigned to each subgroup? D Y D N/A D N
• Monitoring results and calculations made for each subgroup in D Y D N/A D N
each monitoring period (i.e., the total number of valves monitored,
the number found leaking, the number of nonrepairable valves, the
percent leaking in the subgroup, and the percent leaking for
determining the subsequent monitoring frequency for the subgroup
as specified in §63.1025(c)(l)(ii) and (2))?
• Which, if any, valves have been reassigned from one subgroup to DY D N/A DN
another, the last monitoring result prior to a reassignment, and the
date when the reassignment was made?
• The results of the semiannual overall performance calculations? D Y D N/A D N
9. For pumps in light liquid service, does the facility keep all of the following
records:
(a) The occurrence and dates of weekly visual inspections for leaks? D Y D N/A D N
§§63.1026(b)(4) and (e)(l)(v) and 63.1038(c)(2)(i) and (ii)
Note: These inspections are not required for pumps with no external
shaft.
6-7
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6.0 Equipment Leaks
Table 6-1. (continued)
I. Review of Records
(b) All of the following records for pumps equipped with a dual
mechanical seal system that includes a barrier fluid system:
§§63.1026(e) (1) (i) and 63.1038(c) (2) (Hi)
• The design criteria related to the presence and frequency of drips D Y D N/A D N
that indicates failure of the seal system, the barrier fluid system, or
both?
• An explanation of the design criteria? D Y D N/A D N
• Any changes to these design criteria? D Y D N/A D N
• The reasons for any changes? D Y D N/A D N
10. For connectors in gas and vapor service or in light liquid service, does the DY D N/A DN
facility maintain a record of the start date and end date of each monitoring
period? §§63.102 7(b) (3) (v) and 63.1038(c) (3)
Note: This record is not required for existing sources that elect to comply
with §63.1029 instead of §63.102 7. §63.2480(b) (4)
Note: The monitoring and recordkeeping requirements do not apply to
inaccessible, ceramic, or ceramic-lined connectors.
11. For agitators in gas and vapor service or in light liquid service, does the
facility maintain all of the following records:
(a) The occurrence and dates of weekly visual inspections for leaks? D Y D N/A D N
§§63.1028(c) (3) and 63.1038(c) (4) (i)
Note: According to §63.1028(e)(2), these inspections are not required
for agitators with no external shaft.
Note: Although §63.1028(e)(l)(iv) does not explicitly require records
documenting the inspection for agitators with dual mechanical seals,
a record would be required in order to demonstrate compliance
(similar to the requirement in §63.1026(e)(l)(v)).
(b) For each agitator equipped with a dual mechanical seal system that D Y D N/A D N
includes a barrier fluid system, the design criteria related to the
presence and frequency of drips that indicates failure of the seal
system, the barrier fluid system, or both; an explanation of the design
criteria; any changes to the design criteria; and the reasons for any
changes? §§63.1028(e)(l)(vi)(B) and 63.1038(c)(4)(ii)
6-8
-------
6.0 Equipment Leaks
Table 6-1. (continued)
I. Review of Records
12. For pressure relief devices in gas and vapor service or in light liquid
service, does the facility maintain records of the following information for
monitoring within 5 days after a pressure release? §§63.1030 (c)(3) and
63.10 38 (c) (5)
Note: These requirements do not apply to pressure relief devices that are
equipped with a rupture disk upstream of the pressure relief device.
(a) Date the monitoring was conducted? D Y D N/A D N
(b) Background level measured? DY DN/A DN
(c) Maximum instrument reading measured? D Y D N/A D N
13. For each compressor that is equipped with a seal system that includes a
barrier fluid system, does the facility maintain records of either of the
following:
(a) the design criteria for the barrier fluid sensor that indicates failure of D Y D N/A D N
the seal system, the barrier fluid system, or both; an explanation of the
design criteria; any changes to the design criteria; and the reasons for
any changes, or §§63.1031 (d) (2) and 63.1038(c) (6) (i)
(b) If the facility complies with the alternative compressor standard (i.e.,
the compressor is designated as operating with an instrument reading
of less than 500 parts per million above background), all of the
following information for each compliance test: §§63.1031(f)(2) and
63.1038(c)(6)(ii)
Date of each compliance test? DY DN/A DN
• Background level measured? D Y D N/A D N
Maximum instrument reading? D Y D N/A D N
14. If the facility has implemented a quality improvement program for pumps,
are all of the following records maintained:
(a) All of the following data for each pump: §§63.1035(d)(2) and
63.1038(c)(7)(i)
Pump type? DY D N/A DN
Pump manufacturer? D Y D N/A D N
Seal type? DY DN/A DN
Seal manufacturer? DY DN/A DN
Pump design? DY D N/A DN
Materials of construction? DY D N/A DN
Barrier fluid or packing material, if applicable? D Y D N/A D N
6-9
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6.0 Equipment Leaks
Table 6-1. (continued)
I. Review of Records
Year installed? DY DN/A DN
• Service characteristics of the pumped stream? D Y D N/A D N
• Maximum instrument readings observed in each monitoring D Y D N/A D N
observation before repair, response factor for the stream (if
appropriate), instrument model number, and date of observation?
• If a leak was detected, the repair methods used and the D Y D N/A D N
instrument readings after repair?
• If the data will be analyzed as part of a larger analysis program DY DN/A DN
involving data from other plants or other types of process units or
affected sources, a description of any maintenance or quality
assurance programs used in the process unit or affected source
that are intended to improve emission performance?
(b) A list identifying areas associated with poorer than average D Y D N/A D N
performance and the associated service characteristics of the stream,
the operating conditions and maintenance practices?
§§63.1035(e) (3) (i) and 63.1038(c) (7) (v)
(c) All of the following information for each trial evaluation program:
§§63.1035(d)(6)(i), (d)(6)(iii), (d)(6)(vi), (e)(3)(ii), and (e)(3)(Hi); and
63.1038(c)(7)(ii) and (in)
Note: Section 63.1035(d)(6) describes the situations under which a
trial evaluation program must be conducted.
• A list of the candidate superior performing pump seal designs or DY D N/A DN
technologies to be evaluated?
• The reasons for rejecting any specific candidate superior D Y D N/A D N
emission performing pump technologies from performance trials?
• The stages for evaluating the candidate pump designs or pump D Y D N/A D N
seal technologies?
• The anticipated time period necessary to test the applicability of D Y D N/A D N
candidate designs or technologies?
• The frequency of monitoring or inspection of the equipment? DY D N/A DN
• The range of operating conditions over which the component will D Y D N/A D N
be evaluated?
The beginning date and actual duration of performance trials for DY DN/A DN
each candidate superior emission performing technology?
• Conclusions regarding the emission performance and the D Y D N/A D N
appropriate operating conditions and services for the trial pump
seal technologies or pumps?
6-10
-------
6.0 Equipment Leaks
Table 6-1. (continued)
I. Review of Records
If all alternatives are judged to be technically infeasible or D Y D N/A D N
incapable of reducing emissions, an engineering evaluation of
each alternative documenting the physical, chemical, or
engineering basis for the judgement?
(d) All of the following records of ongoing activities during the QIP:
The rolling average percent leaking pumps? §§63.1035(e)(l)(i) DY D N/A DN
and63.1038(c)(7)(v)
• Documentation of all inspections of pumps or pump seals that DY D N/A DN
exhibited frequent seal failures and were removed from the
process unit or affected source due to leaks? §§63.1035(d)(4)
and (e)(l)(ii) and 63.1038(c)(7)(v)
The beginning and end dates for the QIP? §§63.1035(e)(l)(iii) D Y D N/A D N
and63.1038(c)(7)(v)
If a leak is not repaired within 15 calendar days after its DY DN/A DN
discovery, the reason for the delay and the expected date of
successful repair? §§63.1035(e)(2) and 63.1038(c)(7)(v)
(e) Quality assurance program documentation, including records D Y D N/A D N
indicating that all pumps replaced or modified during the period of the
QIP are in compliance with the quality assurance program?
§§63.1035(d)(7) and (e)(4) and 63.1038(c)(7)(iv) and (v)
(f) The following records related to the pump or pump seal replacement
requirements:
Note: The number of years after starting the QIP when replacements
must begin is specified in §63.1035(d)(8).
• Records documenting compliance with the 20 percent or greater D Y D N/A D N
annual replacement rate ? §§63.1035(e) (5) and 63.1038(c) (7) (v)
• If complying with the schedule for corporations with fewer than DY D N/A DN
100 employees, information documenting the number of
employees, including employees providing professional and
technical contracted services? §§63.1035(e)(6) and
6 3.10 38 (c) (7) (v)
6-11
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6.0 Equipment Leaks
Table 6-1. (continued)
I. Review of Records
15. If emissions from any equipment are routed through a closed-vent system
to a non-flare control device, are records maintained of all of the following
information: §63.998(d)(4) as referenced from §§63.1034(b), 63.982(c)(3),
and63.986(c)
Note: Use the checklists in Tables 9-1, 9-2, and 10-1 if the control device
is a flare. §§63.1034(b) (2) (in) and 63.998 (a) (1)
(a) Detailed schematics, design specifications of the control device, and D Y D N/A D N
piping and instrumentation diagrams?
(b) The dates and descriptions of any changes in the design DY DN/A DN
specifications?
(c) A description of the parameter or parameters monitored to ensure that D Y D N/A D N
the control device is operated and maintained as designed, and a
description of why each parameter was selected for monitoring?
(d) Dates and durations when the monitored parameter values indicate the D Y D N/A D N
closed-vent system and control device(s) were not being operated as
designed?
(e) Dates and durations when the monitoring device was inoperative? D Y D N/A D N
(f) Dates and durations of startup and shutdown of the control device? DY DN/A DN
16. If the facility complies with the alternative equipment monitoring schedule
for batch processes as specified in §63.1036(c), are records maintained of
all of the following information: §§63.1036(d) and 63.1038(c)(8)(ii)
Note: All other items in this checklist also apply when the facility complies
with this alternative.
(a) A list of equipment added to the batch product process since the last DY DN/A DN
monitoring?
(b) For any components for which the facility adjusts the monitoring D Y D N/A D N
frequency in accordance with this alternative, documentation
demonstrating the proportion of time during the calendar year that the
equipment is in use?
(c) The following information related to monitoring equipment that is
added after reconfiguration to produce a new product:
Date of the monitoring? DY D N/A DN
Note: The monitoring must be conducted within 30 days of
startup of the process. §63.1036(c)(3)(i)
• Either the actual monitoring results if leaks were found or a D Y D N/A D N
statement that the monitoring was conducted if no leaks were
found?
6-12
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6.0 Equipment Leaks
Table 6-1. (continued)
I. Review of Records
17. Are all records kept for at least 5 years? §63.10(b)(l) D Y D N
Note: Some records must be kept longer. For example, if connectors are
monitored once every 8 years, connector monitoring records must be kept 5
years beyond the date of their last use. Another example is the non-flare
control device records identified in items 15a, b, and c of this checklist
must be kept for the life of the control device. §§63.1023(e)(2) and
6 3.998 (d) (4)
II. Visual Inspections
1. Are visible, weatherproof identifications attached to all equipment that has D Y D N/A D N
been determined to be leaking and has not yet been repaired, including
equipment determined to be nonrepairable? §63.1023(e)(l)
2. Are the visible, weatherproof leak identifications still attached to repaired D Y D N/A D N
valves and connectors in gas or light liquid service that have not yet been
monitored as required by §§63.1025(d)(2) and 63.1027(b)(3)(iv)?
§63.1024(c)(l)
Note: This requirement does not apply to connectors in gas/vapor or light
liquid service at existing services that elect to comply with §63.2480(b)(4).
Note: The monitoring must be performed within 3 months after repair.
3. Is a rupture disk in place upstream of each pressure relief device for which D Y D N/A D N
the facility claims exemption from the otherwise required monitoring?
§63.1030(e)
4. Are sampling connection systems equipped with a closed-purge, closed- D Y D N/A D N
loop, or closed-vent system? §63.1032(b)
Note: In-situ sampling systems are exempt from this requirement.
§63.W32(d)
5. Are open-ended valves and lines equipped with caps, blind flanges, plugs, DY DN/A DN
or a second valve?
Note: Open-ended valves and lines in an emergency shutdown system that
are designed to open automatically in the event of a process upset are
exempt from this requirement. Open-ended lines and valves containing
materials that would autocatalytically polymerize or would present an
explosion, serious overpressure, or other safety hazard are also exempt.
6. If the facility indicates equipment is vented to a control device, is a closed- DY DN/A DN
vent system in place?
6-13
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6.0 Equipment Leaks
Table 6-1. (continued)
II. Visual Inspections
7. If emissions are routed to a process or a fuel gas system, is the process or D Y D N/A D N
fuel gas system operating when emissions are routed to it? §63.984(a)(l)
as referenced from §§63.1034(b)(l) and 63.982(d)
III. Note All Deficiencies
6-14
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6.0 Equipment Leaks
Table 6-2. Checklist for Determining Compliance with the Pressure Testing Alternative Standard
Note: Use this checklist for each process that is pressure tested as specified in §63.1036(b). A "yes"
response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If a question is not applicable, check the
"N/A" box.
Process Identification:
I. Review of Records §§63.1036(b)(7) and 63.1038(c)(8)(i)
1. Do records identify each product produced during the calendar year (or D Y D N/A D N
codes for those products)?
2. Is the process equipment either physically tagged, or is it identified on a DY D N/A DN
plant site plan, in log entries, or by some other method?
3. Is all of the following information recorded for each pressure test:
(a) Date of the test? DY DN/A DN
(b) The test pressure? DY DN/A DN
(c) The observed pressure drop, for a gas pressure/vacuum test? D Y D N/A D N
(d) Documentation of any visible, audible, or olfactory evidence of fluid D Y D N/A D N
loss, for a liquid pressure test?
4. Is all of the following information recorded anytime the process equipment
train does not pass two consecutive pressure tests:
Note: Section 63.1036(b)(7)(v) specifies that these records must be
maintained for only 2 years.
(a) The date of each pressure test? DY DN/A DN
(b) Repair methods applied in each attempt to repair the leak(s)? D Y D N/A D N
(c) All of the following information if repair is not completed within 30
calendar days after the second pressure test:
Reason for the delay? DY DN/A DN
Expected date for delivery of the replacement equipment? D Y D N/A D N
• Actual date of delivery of the replacement equipment? DY DN/A DN
(d) Date of successful repair? DY DN/A DN
5. Are all records kept for at least 5 years, except as noted above? DY DN/A DN
§63.10(b)(l)
6-15
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6.0 Equipment Leaks
Table 6-2. (continued)
II. Note All Deficiencies
6-16
-------
6.0 Equipment Leaks
Table 6-3. Checklist for Determining Compliance with the Enclosed Process Alternative
Note: Use this checklist for each process or portion of a process that is enclosed and emissions from
equipment leaks are routed to a process, fuel gas system, or through a closed-vent system to a
control device. A "yes" response to a question in this checklist means compliance with that
requirement, and a "no" response means noncompliance with the requirement. If a question is not
applicable, check the "N/A" box.
Process Identification:
I. Review of Records
1. Do records document all of the following information about the process unit
and the enclosure: §§63.103 7(b) and 63.1038(c) (9)
(a) Identification of the process unit and the organic HAP that it handles? DY DN/A DN
(b) A schematic of the process unit, enclosure, and closed-vent system? D Y D N/A D N
(c) A description of the system used to create a negative pressure in the DY DN/A DN
enclosure?
2. Do records document all of the following information, if emissions are routed
through a closed-vent system to a non-flare control device: §63.998(d)(4), as
referenced from §§6 3.10 37 (a), 63.1034(b), 6 3.98 2 (c) (3), and 63.986(c)
Note: Use the checklists in Tables 9-1, 9-2, and 10-1 if the control device is a
flare. §§63.1037(a), 63.1034(b), and 63.982(b)
(a) Detailed schematics, design specifications of the control device, and D Y D N/A D N
piping and instrumentation diagrams?
(b) The dates and descriptions of any changes in the design specifications? D Y D N/A D N
(c) A description of the parameter or parameters monitored to ensure that DY DN/A DN
the control device is operated and maintained as designed, and a
description of why each parameter was selected for monitoring?
(d) Dates and durations when the monitored parameter values indicate the D Y D N/A D N
closed-vent system and control device(s) were not being operated as
designed?
(e) Dates and durations when the monitoring device was inoperative?
(f) Dates and durations of startup and shutdowns of the control devices?
3. Are all records kept for at least 5 years? §63.10(b)(l)
DY
DY
DY
DN/A
DN/A
DN/A
DN
DN
DN
II. Visual Inspections
1 . Is the equipment enclosed?
DY
DN
6-17
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6.0 Equipment Leaks
Table 6-3. (continued)
III. Note All Deficiencies
6-18
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7.0 Transfer Racks
7.0 Transfer Racks
This section contains applicability and control flowcharts and inspection checklists for controlling
organic HAP emissions from transfer racks. Use Figures 7-1 and 7-2 to determine if the transfer rack is
part of the affected source subject to subpart FFFF, the group status of transfer racks that are subject to
subpart FFFF, and the available compliance options. Then use the checklist in Table 7-1 for each transfer
rack. This checklist is used to identify the transfer rack and document its group status. If the transfer
rack is Group 1, the checklist allows you to document the applicable control technique(s) for the
emissions and it points you to checklists in other sections for closed-vent systems and applicable add-on
control devices. The checklist also identifies some general recordkeeping requirements for both Group 1
and Group 2 transfer racks.
7-1
-------
7.0 Transfer Racks
Use this ftewohart tor
each transfer rack"
Is the
transfer rat* part of
an affected source under
another subpart of
part 63?
Can Hie
predominant use of tie
transfer rack be
determined?
The transfe* rack must be
assigned to any one of the
MCRJ that shares it and is
subject to subpart FFFF.
Is the
predominant
USB associated with a
miscellaneous organic chemical
manufacturing
process?
me transfer rack must be
assigned to the MCPU for that
miscellaneous organic chemical
manufacturing process.
Does ihe
transfer rack load more
than 0.65 million liters per year of
liquids that contain organic HAP
to tank trucks and/or
ralfcars?
Is the
rack-weighted average
partial pressure of the organic
HAP> l.5psia?
The transfer rack is \
not part of the miscellaneous \
organic chemical manufacturing /
affected sou roe. J
This transfer rack Is a
Group 2 transfer rack.
No control is required.
(This transfer rack is a Group I transfer rack, You must meet the
emission limits and work practice standards specified in Table 5 to
subpart FFFF and cSasoribed in Figure 7-2.
"Transfer rack" means the collection of loading arms and loading hoses, a! a single loading rack, including associated pumps, meters,
sriutoff valves, relief valves, and other piping and valves.
Figure 7-1. Applicability for transfer racks.
7-2
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7.0 Transfer Racks
Does the vent
stream have a mass
" emission rate of halogen atoms in
^ organic compounds of > 0.45 kg/hr ^
(i.e., is it a halogenated
vent stream)?
_Yes-
or
or
Vent emissions through a dosed vant system to a flare.
Reduce the organic HAP emissions from the transfer
rack by writing to a fuel gas system or process.
Vapor balance to the storage tank of origin or to another
tank connected by a cornrncn header.
Reduce total organic HAP emissions by > 98% by weight or
to < 20 ppmv of TOC or organic HAP by using a closed
vent system and any combination of control devices.
or
If the transfer rack has halogenated vent streams and you are
using a combustion control device, you must also use a halogen
reduction device to meat one of the following requirements.
-•or-
/ Us* a halogen reduction device after the combustion
device to reduce emissions of hydrcxpn halide and halogen
V HAP by >. 99% by weight, or to < 0.45 kg/hr or ^20 ppmv.
Usa a halogen reduction device before the combustion
device to reduce the halogen atom mass emissions to
£ 0.45 kg/hr or < 20 ppmv.
Figure 7-2. Emission limits and work practice standards for Group 1 transfer racks.
7-3
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7.0 Transfer Racks
Table 7-1. Inspection Checklist for Controlling Organic HAP Emissions from
Transfer Racks that Are Subject to Subpart FFFF
Note: Use this checklist for each transfer rack that is subject to subpart FFFF. A "yes" response to a
question means compliance with that requirement, and a "no" response means noncompliance
with the requirement. If a question is not applicable, check the "N/A" box.
I. General Identification
1. Transfer Rack Identification:
2. What is the Group Status of the transfer rack (determined according to Figure 7-1):
D Group 1, or
Continue with this checklist.
D Group 2
No control is required, but go to item II. 1 in this checklist to determine
compliance with recordkeeping requirements.
3. Which type of emission limit applies to the organic HAP emissions from the
Group 1 transfer rack? (check all that apply)
D Use a flare? (go to checklists in Tables 9-1, 9-2, and 10-1)
Note: Halogenated vent streams may not be controlled using a flare,
unless a halogen reduction device before the flare reduces the mass
emission rate of halogen atoms in organic compounds to less that
0.45 kg/hr. See item "4 " in this checklist.
D Reduce organic HAP emissions by >98 percent in a control device or to
less than 20 ppmv as organic HAP or TOC using one or more of the
following add-on devices:
Note: Also see item "4" in this checklist if the transfer rack emits a
halogenated vent stream that is controlled with a combustion device.
D A thermal incinerator? (go to checklists in Tables 9-1, 9-2, and 10-2)
D A catalytic incinerator? (go to checklists in Tables 9-1, 9-2, and 10-3)
D A boiler or process heater with a capacity less than 44 MW that does
not have the emission stream introduced with the primary fuel? (go to
checklists in Tables 9-1, 9-2, and 10-4).
D A boiler or process heater with a capacity greater than 44 MW or that
has the vent stream introduced with the primary fuel? (go to
checklists in Tables 9-1, 9-2, and 10-5)
D A carbon adsorber? (go to checklists in Tables 9-1, 9-2, and 10-6).
7-4
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7.0 Transfer Racks
Table 7-1. (continued)
I. General Identification
D An absorber? (goto checklists in Tables 9-1, 9-2, and either 10-7 or
10-10)
D A condenser? (go to checklists in Tables 9-1, 9-2, and 10-8)
D Another type of control device? (go to checklists in Tables 9-1, 9-2,
and 10-9)
D Vent emissions to a fuel gas system or process? (the owner or operator
must submit a statement of connection in the notification of compliance
status report; go to Table 12-1)
D Vapor balance to the storage tank of origin (or to another tank connected
by a common header)? (go to item "II.2" in this checklist)
4. If halogenated vent streams from the transfer rack are controlled using a D Y D N/A D N
combustion device, are additional controls that meet either of the following
requirements also used: See definition of "halogenated vent stream " in
§63.2550(i).
(a) Is a halogen reduction device used before the combustion device to
reduce the halogen atom mass emission rate to <0.45 kg/hr or to a
concentration <20 ppmv, or (go to the appropriate checklist in Section
10; for example, go to Table 10-10 if the halogen reduction device is a
scrubber)
(b) Is a halogen reduction device used after the combustion device to reduce
hydrogen halide and halogen HAP emissions by >99 percent, to
<0.45 kg/hr, or to a concentration <20 ppmv? (go to the appropriate
checklist in Section 10; for example, go to Table 10-10 if the halogen
reduction device is a scrubber)
Note: This option in item "4.b" is not allowed when the halogenated
vent stream is controlled with a flare.
II. Review of Records
1. For both Group 1 and Group 2 transfer racks, are records kept of the
following information as part of an operating scenario: §63.2525(b)
(a) Design and actual throughput of the transfer rack? DY D N/A DN
(b) Weight percent HAP of liquid loaded? D Y D N/A D N
(c) Annual rack-weighted average HAP partial pressure? D Y D N/A D N
7-5
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7.0 Transfer Racks
Table 7-1. (continued)
II. Review of Records
2. If emissions from a Group 1 transfer rack are controlled by vapor balancing, DY D N/A DN
is the vapor balancing system designed and operated to collect organic HAP
emissions displaced from tank trucks and railcars during loading and route
them to the originating storage tank or another storage tank connected by a
common header? Table 5 to subpart FFFF
III. Note All Deficiencies
7-6
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8.0 Heat Exchange Systems
8.0 Heat Exchange Systems
This section contains a flowchart of applicability and control requirements and an inspection
checklist for heat exchange systems. Use Figure 8-1 to determine if a heat exchange system is subject to
the leak monitoring requirements in §63.104 of subpart G (as referenced from §63.2490 and Table 10 in
subpart FFFF). Use the checklist in Table 8-1 to determine compliance with the monitoring options.
8-1
-------
8.0 Heat Exchange Systems
The system is sxsmpt from lh@ >.
requirements for heat exchange J
systems in subpart FFFF. /
Use this flow chart for each heat exchange system
Is we heat exchange
coding water side ai least 35 kP
i the maximum pressure on th
/The system is exempt fr«n the \
I requirements for teat exchange 1
Is there an
ning cooling fluid' cental
of total HAP between the process and
systems in subpart FFFF
is ta
once-through heat
exchange system?
system used to cool process fluids that
5% by weight of total HAP
listed in Table 4 k
Is the once-
throtigh heat exchange system used to
ccol process fluids that contain * 5% by weight of
total HAP iisted in Table 9
to subpart G?
Is the once-throng
heat exchange system subject to an
NPOES permit with an allowable discharge I
above influent concentration
bject to
meets certain
teat e
NPDES permit th
/'Monitor the cooling water for the presence of one or more organic\
J HAP or another swtetance wtio&e presence in cooling water j
V indicates a leak as specified In §63.104(b)(1)through (6). J
f Monitor the cooling water using a surrogate
I indicator of heat exctiange system leeks'1 as
V specified in §63.1£M(c)(1) through (3).
^-^ **
Heat exchange system means any cooling tower system or once-through cooling water system (e.g., river or pond water). A heat exchange system
can include rnoce than c*ie heat exchanger and can include an entire rec-irculafing or once-ihrougli cwling system.
This intervening fluid serves to isolate the moling water from the process fluid and tie intervening fluid is not sent tfwough a G&olbcj tower or
discharged.
The NPDES permit must (a) require monitoring to detect a leak of process fluids into cooling water; (b) specify tie normal range to maintain; (c)
require monitoring no less frequently than monthly for the first six months and quarterly thereafter; and (d) require reporting and correction when
monitoring is not within She normal range,
Surrogate indicators that muld be used td develop an acceptable monitoring program are «n specific electrode rr»nitoring, pH, eonduetfvily or other
representative indicators.
Figure 8-1. Applicability and work practice standards for heat exchange systems.
8-2
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8.0 Heat Exchange Systems
Table 8-1. Compliance Checklist for Heat Exchange Systems Requiring Leak Detection
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" responses means noncompliance with the requirement. If the requirement is not applicable,
check the "N/A" box.
I. Review of Records
1. Do records indicate that heat exchange systems are monitored for leaks by D Y D N D N/A
either of the following (provided they are not exempt from monitoring for
reasons specified in Figure 8-1):
(a) Monitoring for the presence of total HAP, total volatile organic
compounds, total organic carbon, one or more speciated HAP, or other
representative substances as indicators of a leak, or §63.104(b)
introductory paragraph
(b) Monitoring using a surrogate indicator of leaks? §63.104(c) introductory
paragraph
2. When monitoring of a surrogate indicator of heat exchange system leaks is
used, is a monitoring plan available that contains all of the following:
§63.104(c)(l)
(a) The procedures that will be used to detect leaks of process fluids into DY DN DN/A
cooling water?
(b) A description of the parameter(s) or condition(s) to be monitored? D Y D N D N/A
(c) An explanation of how the selected parameter(s) or condition(s) will D Y D N D N/A
reliably indicate the presence of a leak?
(d) The parameter level(s) or condition(s) that constitute a leak, including D Y D N D N/A
supporting data and calculations?
(e) The monitoring frequency (which must be no less frequent than monthly D Y D N D N/A
for the first 6 months and quarterly thereafter?
(f) The records that will be maintained? DY DN DN/A
3. If monitoring results indicate a leak is detected, are records of all of the
following available: §63.104(d)(l), (f)(l)(i), and (f)(l)(ii)
(a) Monitoring records identifying the leak? D Y D N D N/A
(b) Date the leak was detected? DY DN DN/A
(c) If the results were determined to be due to a condition other than a leak, D Y D N D N/A
the basis for that determination?
4. If the results are confirmed to be a leak, are records of all of the following
available: §63.104(f)(l)(iii) and (iv)
(a) Date(s) of efforts to repair the leak? DY DN DN/A
(b) The method or procedure used to confirm repair of the leak? D Y D N D N/A
8-3
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8.0 Heat Exchange Systems
Table 8-1. (continued)
I. Review of Records
(c) Date the repair was confirmed?
5. If repair of a leak has been delayed, do records indicate either of the
D Y D N D N/A
D Y D N D N/A
following, along with a schedule for completing the repair as soon as
practical: §63.104(e)(2)(i) and (ii)
(a) The basis of a determination that a shutdown for repair would cause
greater emissions than the emissions likely to result from delaying repair,
or
(b) Evidence that the necessary parts or personnel were not available to
make the repair?
Note: Documentation is not necessary if the leaking equipment is
isolated from the process, or if a shutdown is scheduled within the next 2
months after determination that a delay of repair is necessary.
§63.104(e) introductory text and (e)(l)
6. Are all records kept for at least 5 years? §63.10(b)(l) D Y D N
II. Note All Deficiencies
8-4
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9.0 Closed-Vent Systems
9.0 Closed-Vent Systems
This section contains checklists for closed-vent systems. Table 9-1 contains a checklist for the
bypass line provisions, and Table 9-2 contains a checklist for leak detection of closed-vent systems. The
checklists for process vents, storage tanks, transfer operations, and wastewater in Sections 3, 4, 5, and 7
refer to the checklists in this section when the provisions regarding bypass lines and leak detection of
closed-vent systems apply. The checklists also apply if emissions from equipment leaks are directed
through a closed-vent system to a flare. The checklists do not apply to systems that route vapors to
recovery devices for continuous process vents or process condensers for batch process vents because
these recovery devices and process condensers are part of the process, and the system of piping,
ductwork, and connections would not meet the definition of a closed-vent system. The checklists do not
apply to closed-vent systems for equipment leaks (except for routing emissions to a flare) because the
options addressed by checklists in section 6 apply. The checklists also do not apply to equipment that
handles in-process liquid streams that meet the criteria of §§63.2485(1) and 63.149.
9-1
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9.0 Closed-Vent Systems
Table 9-1. Compliance Checklist for Bypass Line Provisions for Closed-vent Systems
Note: Complete this checklist for each closed-vent system that contains a bypass line that could divert a
vent stream away from a control device to the atmosphere. A "yes" response to a question
indicates compliance with that requirement, and a "no" response indicates noncompliance with
the requirement. If a question is not applicable, check the "N/A" box.
System Identification:
I. Review of Records
Note: The items in this checklist do not apply to low leg drains, high point bleeds, analyzer vents,
open-ended valves or lines, and pressure relief valves needed for safety purposes.
1. Are all of the following records available for a bypass line that is equipped
with a flow indicator: §§63.998(d)(l)(ii)(A) and 63.148ft)(3)ft)
(a) Hourly records of whether the flow indicator in the bypass line was D Y D N D N/A
operating?
(b) Whether a diversion was detected at any time during each hour? D Y D N D N/A
(c) The times of all periods when the vent stream was diverted from the DY DN DN/A
control device?
(d) The times of all periods when the flow indicator was not operating? D Y D N D N/A
2. Are all of the following records available for a bypass line that is equipped
with a seal mechanism: §§63.998(d)(l)(ii)(B) and 63.148(i)(3)(ii)
(a) Occurrence of each monthly inspection of the seals or closure DY DN DN/A
mechanism?
(b) All periods when the seal mechanism was broken, the bypass line valve D Y D N D N/A
position was changed, or the key to unlock the bypass line valve was
checked out?
3. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspection
1. Is a flow indicator present at the entrance to any bypass line that could divert D Y D N D N/A
the vent stream flow away from the control device to the atmosphere, or are
all bypass line valves sealed in a closed position (e.g., with a car seal or
lock-and-key configuration)?
9-2
-------
9.0 Closed-Vent Systems
Table 9-1. (continued)
III. Note All Deficiencies
-------
9.0 Closed-Vent Systems
Table 9-2. Compliance Checklist for Closed-Vent Systems
Note: Complete this checklist for each closed-vent system. A "yes" response to a question indicates
compliance with that requirement, and a "no" response indicates noncompliance with the
requirement. If a question is not applicable, check the "N/A" box.
Equipment Identification:
I. Review of Records
Note: This checklist does not apply to closed-vent systems that are operated under negative pressure.
§§63.983(a), 63.133(b)(4), 63.134(b)(5), 63.135(d)(4), 63.136(b)(4), and 6 3.1 37 (b) (4)
1 . Are records kept that identify all parts of closed-vent systems that are D Y D N D N/A
designated as either unsafe-to-inspect or difficult-to-inspect?
§§63.998(d)(l)(i) and 63. 148 ft) (1) and (2)
2. For equipment that is designated as difficult to inspect, is a written plan kept D Y D N D N/A
that describes the actual monitoring frequency that will be used (and is at least
once every five years)? §§63.983(b)(3)(ii), 63.998(d)(l)(i), and 6 3.1 48 (h) (2)
and ft) (1)
3 . For equipment that is designated as unsafe to inspect, is a written plan kept D Y D N D N/A
that indicates equipment will be inspected as frequently as practicable during
safe-to-inspect times (but not more frequently than annually)?
§§63.983(b)(2)(ii), 63.998(d)(l)(i), and 63.148(g)(2) and (i)
4. For each annual inspection during which a leak was detected, was all of the
following information recorded and reported:3 §§63.998(d)(l)(iii) and
6 3. 148 ft) (4)
(a) Identification information of the leaking closed-vent system? D Y D N D N/A
(b) Name or initials of operator conducting the inspection? D Y D N D N/A
(c) Instrument identification number, if instrument monitoring applies? DY DN DN/A
(d) Date the leak was detected? DY DN DN/A
(e) Date of the first attempt to repair the leak? DY DN DN/A
(f) Maximum instrument reading after the leak is repaired or determined to D Y D N D N/A
be non-repairable?
(g) Explanation of delay in repair, if the leak was not repaired within 15 days DY DN DN/A
after it was discovered?
(h) Name or initials of person who decides repairs cannot be made without a DY DN DN/A
shutdown? §63. 1 48 ft) (4) (v)
Note: This record is required only if the closed-vent system is used to
convey wastewater emissions.
9-4
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9.0 Closed-Vent Systems
Table 9-2. (continued)
I. Review of Records
(i) Expected date of successful repair if not repaired within 15 days? DY DN DN/A
§63.148(i)(4)(vi)
Note: This record is required only if the closed-vent system is used to
convey wastewater emissions.
(j) Dates of shutdowns that occur while the equipment is unrepaired? D Y D N D N/A
§63.148(i)(4)(vii)
Note: This record is required only if the closed-vent system is used to
convey wastewater emissions.
(k) Date of successful repair of the leak? DY DN DN/A
5. For each inspection during which no leaks were detected, were records kept of
all of the following:3 §§63.998(d)(l)(iv) and 63.148 ft) (5) and (6)
(a) Record that the inspection was performed?
(b) Date of the inspection?
(c) Statement that no leaks were found?
6. Are all records kept for at least 5 years? §63.10(b)(l)
DY DN
DY DN
DY DN
DY
DN/A
DN/A
DN/A
DN
II. Note All Deficiencies
3 Annual visual inspections for visible, audible, or olfactory indications of leaks are required for closed-
vent systems that are constructed of hard-piping. Annual instrument monitoring using Method 21 of
40 CFR part 60, Appendix A, is required for closed-vent systems constructed of duct work.
§63.983(b)(l)(i)(B) and (ii)
9-5
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9.0 Closed-Vent Systems
[This page intentionally left blank.]
9-6
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10.0 Control Device and Recovery Device Checklists
10.0 Control Device and Recovery Device Checklists
This section contains checklists specific to several types of typical control devices and recovery
devices. The checklists in Tables 10-1 through 10-10 apply to control devices and recovery devices for
continuous process vents, batch process vents, storage tanks, transfer racks, and waste management units.
The checklists in Sections 3, 4, 5, and 7 refer to these checklists when they are applicable. The checklist
in Table 10-11 is for a biofilter, which is specifically listed in Table 2 to subpart FFFF as an acceptable
control device for batch process vents. Biofilters are not prohibited as control devices for other emission
points, but they would have to achieve 98 percent reductions or outlet concentrations < 20 ppm and meet
the requirements of §63.995 according to the checklist in Table 10-9. The checklist in Table 10-12 is for
fabric filters, which may be used to control F£AP metals emissions from process vents at new sources.
The checklists in this section are not applicable for all control devices. For example, although the
checklist in Table 10-1 applies to emissions from equipment leaks that are routed through a closed-vent
system to a flare, the checklists in Tables 10-2 through 10-12 do not apply to equipment leaks. The
checklists in this section also do not apply to equipment that handles in-process liquid streams that meet
the criteria of §§63.2485(1) and 63.149. Finally, if inlet F£AP emissions to a control device are less than 1
tpy, an owner or operator may elect to monitor one or more operating parameters at least once per
averaging period (operating block or day) in accordance with §63.2450(k)(6). The owner or operator
must use the precompliance report to request approval of the procedures to be implemented. The
checklists in this section may need to be modified to reflect the approved recordkeeping requirements for
compliance with this option.
The following table identifies the types of devices that are addressed by the checklists in this
section:
For the following device...
Flare
Thermal incinerator
Catalytic incinerator
Boiler or process heater with a design heat input
capacity less than 44 MW and the vent stream is
not introduced with the primary fuel
Use the checklist in...
Table 10-1
Table 10-2
Table 10-3
Table 10-4
Beginning on page...
10-3
10-5
10-9
10-14
10-1
-------
10.0 Control Device and Recovery Device Checklists
For the following device... Use the checklist in...
Boiler or process heater with a design heat input
capacity greater than 44 MW or the emission
stream is introduced with the primary fuel
Carbon adsorber
Gas absorber (scrubbing fluid anything other than
water)
Condenser
Control or recovery device not specifically listed
Scrubber for halogenated vent streams, or gas
absorber where water is the scrubbing fluid
Biofilter
Fabric filter
Table 10-5
Table 10-6
Table 10-7
Table 10-8
Table 10-9
Table 10-10
Table 10-11
Table 10-12
Beginning on page...
10-18
10-19
10-23
10-28
10-33
10-35
10-39
10-42
Carbon adsorbers, condensers, and absorbers are usually treated as control devices, but for
process vents they can be either control devices or recovery devices depending on the situation. When
used as a control device for continuous process vents and/or batch process vents, performance testing and
continuous monitoring and associated requirements generally apply. These requirements also apply if the
equipment is used as a recovery device for Group 1 batch process vents. However, for batch process
vents, a condenser could be a process condenser (i.e., part of the process) if the criteria specified in the
rule are met and it is so identified in the notification of compliance status report. In that case, none of the
provisions in Table 10-8 apply. For continuous process vents, recovery devices are always considered
part of the process, but are subject to continuous monitoring requirements if the TRE of the continuous
process vent leaving the last recovery device is below 5.0 for an existing source or below 8.0 for a new
source. The checklists in Tables 10-6, 10-7, and 10-8 reflect these differences, but care should be
exercised in their use where recovery devices are involved to be certain which requirements are
applicable.
10-2
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10.0 Control Device and Recovery Device Checklists
Table 10-1. Compliance Checklist for Flares
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Flare Identification:
I. Review of Records
1. Is all of the following information recorded (and included in the flare
compliance assessment report): §§63.998(a)(l)(i)(A) through (C) and
63.146(b)(7)(i)(A) through (C)
(a) Flare design (i.e., steam-assisted, air-assisted, or non-assisted)? DY DN
(b) All visible emission readings, heat content determinations, flow rate D Y D N
measurements, and exit velocity determinations made during the flare
compliance assessment?
(c) All periods during the flare compliance assessment when all pilot flames D Y D N D N/A
are absent or, if only the flare flame is monitored, all periods when the
flare flame is absent?
2. Are hourly records kept of whether the monitor is continuously operating D Y D N
and whether the flare flame or at least one pilot flame is continuously
present? §§63.998(a)(l)(ii) and 63.143(e)(l) and Table 13 to subpart G
Note: Section 63.143 specifies monitoring only of pilot flames for flares that
are used to control emissions from wastewater system. Therefore, sources
wishing to monitor the flare flame for wastewater emissions streams should
submit a request for alternative monitoring as specified in §63.8(f) of the
General Provisions.
3. Are records kept of the times and durations of all periods during which the D Y D N D N/A
flare flame or all pilot flames are absent? §§63.998(a)(l)(iii)(A) and
63.147(d)(l)
4. Are records kept of the times and durations of all periods during which the DY DN DN/A
monitor is not operating? §63.998(a)(l)(iii)(B)
5. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspection
1. Is a device for detecting pilot flames or the flare flame present and operating? D Y D N
10-3
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10.0 Control Device and Recovery Device Checklists
Table 10-1. (continued)
III. Note All Deficiencies
10-4
-------
10.0 Control Device and Recovery Device Checklists
Table 10-2. Compliance Checklist for Thermal Incinerators
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Thermal Incinerator Identification:
I. Review of Records
1. Does the facility maintain the initial compliance records in (a) or (b):
(a) The following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP D Y D N/A D N
orTOC? §63.998(a)(2)(ii)(B)(4)
• The firebox temperature averaged over the full period of the D Y D N/A D N
performance test? §63.998(a)(2)(ii)(B)(l)
(b) Documentation of the design evaluation in the notification of compliance DY D N/A DN
status report? §63.2520(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the only emissions controlled by the thermal
incinerator are from wastewater. A design evaluation also may be
conducted if the thermal incinerator is a small control device as defined
in §63.2550(1) that is used to comply with a percent reduction emission
limit. §§63.2450(h) and 63.139(d)
2. Do records document that the facility continuously monitors the temperature DY DN
of the gas stream in the firebox (or in the ductwork immediately downstream
of the firebox before any substantial heat exchange occurs) or does the
facility have documentation that they requested and received approval to
conduct an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §§63.988(c)(l), 63.996(d), 63.143(e)(l) and (3), and Table 13
to subpart G
Note: Section 63.143(e)(2) specifies that an organic monitoring device may
be used as an alternative to temperature monitoring. Although the rule
explicitly provides this approach as an alternative only for wastewater
control devices, sources wishing to use this as an alternative for other
emission streams should follow the procedures for requesting approval of
alternative monitoring as specified in §63.8(f) of the General Provisions.
Note: If the alternative parameter is the emissions concentration as
measured using a CEMS, also use the checklist in Table 11-1.
10-5
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10.0 Control Device and Recovery Device Checklists
Table 10-2. (continued)
I. Review of Records
If the facility continuously monitors temperature (or other approved
parameters), has the facility:
(a) Established a site-specific operating range for the monitored parameter? D Y D N/A D N
§§63.996(c)(6) and 63.143(f)
(b) Followed manufacturer's or other written specifications or D Y D N/A D N
recommendations for installation, operation, and calibration of the
monitoring equipment? §§63.996(c)(l) and (3) and 63.143(g)
(c) Maintained records of continuously monitored values in one of the DY D N/A DN
following formats: §§63.998(b)(l), 63.147(d), and 63.152(f)(2) and (3)
• all measured values, or
• all block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least one
measured data value per minute if measured more frequently than
once per minute), or
• all continuous records for only the most recent 3 valid hours of
records (under §63.998(b)(l)(iii)) or for the current operating day
(under §63.152(f)(3)(i)), and block hourly average values for earlier
data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)) or the daily
average must be within the established range (§63.152(f)(3) and (4)).
(d) Maintained records of either daily average values or a statement that all DY DN/A DN
values were within the established operating range? §§63.998(b)(3),
63.147(d), and63.152(f>(6)
Note: If the owner or operator chooses to maintain a statement that all
values are within their established ranges and the daily average value is
not calculated and recorded, then continuous or short-term block
averages may not be discarded as otherwise allowed by the third option
in item "c" above. §§63.998(b)(3)(ii) and 63.152(f)(6)
Note: Averages may be over an operating block if the thermal
incinerator is used only for batch process vents. §63.2460(c)(4)
10-6
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10.0 Control Device and Recovery Device Checklists
Table 10-2. (continued)
I. Review of Records
(e) As an alternative to "c" and "d" above when the conditions for alternative
recordkeeping in §63.998(b)(5)(i)(A) through (F) or §63.152(g)(l)(i)
through (vi) are met, does the facility meet both of the following
requirements:
Note: This alternative is not allowed if the thermal incinerator is used
only for storage tank emissions. §63.998(b)(5) introductory paragraph.
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
Retain only the daily average? D Y D N/A D N
Note: No record of the daily average is required if 6 months have
passed without an excursion. §§63.998(d)(5)(ii) and 63.152(g)(2)
(f) Maintained records of the occurrence and cause of all periods when the DY DN/A DN
monitored temperature is outside the established range? §63.998(d)(5)
Note: This requirement does not apply if the thermal incinerator is used
only for wastewater emissions (although the occurrence will be
documented by virtue of the daily average value being outside the
established range).
If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping specified by the Administrator (§63.147(e) for
wastewater controls) or approved by the Administrator (§§63.999(d)(l) and
(2), 63.8(f), and 63.10(b)(2)(vii) for control devices used for all other
emissions)?
Note: If an alternative parameter is monitored continuously, the records
described above in item "3" would be required for the alternative parameter.
Alternative recordkeeping might be required if the alternative monitoring is
not continuous.
For any CPMS, does the facility have records of all of the following:
§§63.998(c)(l)(i) and (ii) and 63.2485(o)
(a) The procedure used for calibrating the CPMS? D Y D N/A D N
(b) The date and time of completion of calibration and preventive DY DN/A DN
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
10-7
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10.0 Control Device and Recovery Device Checklists
Table 10-2. (continued)
I. Review of Records
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction D Y D N/A D N
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
6.
(g) Documentation of each startup, shutdown, and malfunction event?
(h) Documentation that there were no excess emissions during each startup,
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period?
Are all required records kept for at least 5 years? §63.10(b)(l)
DY
DY
DY
DN/A
DN/A
DN/A
DY
DN
DN
DN
DN
II. Visual Inspection
1. Is a temperature monitoring device present in the firebox or in the ductwork DY DN
immediately downstream from the firebox, or is an approved alternative monitor
present and operating?
Note: Section 63.143(e)(2) specifies that an organic monitoring device is also
acceptable for a thermal incinerator that is used to control emissions from waste
management units and wastewater treatment units.
III. Note All Deficiencies
10-8
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10.0 Control Device and Recovery Device Checklists
Table 10-3. Compliance Checklist for Catalytic Incinerators
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Catalytic Incinerator Identification:
I. Review of Records
1. Does the facility maintain either of the following initial compliance records:
(a) Both of the following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP D Y D N/A D N
orTOC? §63.998(a)(2)(ii)(B)(4)
The upstream temperature, downstream temperature, and D Y D N/A D N
temperature difference across the catalyst bed, all averaged over the
full period of the performance test? §63.998(a)(2)(ii)(B)(2)
Note: The downstream temperature and the temperature difference
across the bed do not need to be recorded if the facility complies
with the annual catalyst activity check option in §63.2450(k)(4).
(b) Documentation of the design evaluation in the notification of D Y D N/A D N
compliance status report? §63.2520(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the only emissions controlled by the catalytic
incinerator are from wastewater. A design evaluation may also be
conducted if the catalytic incinerator is a small control device as
defined in §63.2550(1) that is used to comply with a percent reduction
emission limit. §§63.2450(h) and 6 3.139 (d)
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements to demonstrate ongoing compliance for the catalytic incinerator:
(a) Temperatures are monitored according to one or both of the following
procedures, as applicable:
For any gas streams other than wastewater, continuous monitoring
of the gas stream temperature immediately before and after the
catalyst bed, and determination of the daily average temperature
differential across the catalyst bed? §§63.988(c)(2) and
63.998(c)(2)(ii)
• For any wastewater emission streams, continuously monitors either
the temperature before the catalyst bed or the temperature
differential across the catalyst bed? §63.143(e)(l) and Table 13 to
subpart G
10-9
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10.0 Control Device and Recovery Device Checklists
Table 10-3. (continued)
I. Review of Records
(b) Continuous monitoring of the temperature of the gas stream immediately
before the catalyst bed and catalyst bed activity level checks at least
once every 12 months? §63.2450(k)(4)
Note: This option is not explicitly allowed for a catalytic incinerator
that controls wastewater emissions. Therefore, sources wishing to
conduct this monitoring for wastewater emission streams should follow
the procedures for requesting approval of alternative monitoring in
§§63.143(e)(3) and 63.8
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10.0 Control Device and Recovery Device Checklists
Table 10-3. (continued)
I. Review of Records
• All continuous records for only the most recent 3 valid hours of
records (under §63.998(b)(l)(iii)) or for the current operating day
(under §63.152(f)(3)(i)), and block hourly average values for earlier
data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)) or the daily
average must be within the established range (§63.152(f)(3) and
(4)).
(c) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §§63.998(b)(3),
63.147(d), and 63.152(f)(6)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "c" above.
§§63.998(b)(3)(ii) and 63.152(^(6)
Note: Averages may be over an operating block if the catalytic
incinerator is used only for batch process vents. §63.2460 (c) (4)
(d) As an alternative to "c" and "d" above when the conditions for
alternative recordkeeping in §63.998(b)(5)(i)(A) through (F) or
§63.152(g)(l)(i) through (vi) are met, does the facility meet both of the
following requirements:
Note: This alternative is not allowed if the catalytic incinerator is used
only for storage tank emissions. §63.998(b)(5) introductory paragraph
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
• Retain only the daily average? DY D N/A DN
Note: No record of the daily average is required if 6 months have
passed without an excursion. §§63.998(d)(5)(ii) and 63.152(g)(2)
4. If the facility monitors the inlet and outlet temperatures as specified in D Y D N/A D N
§63.988(c)(2), do they maintain records of the daily average temperature
differential? §§63.996(c)(6) and 63.998(c)(2)(ii)
5. If the facility monitors the inlet temperature and conducts annual checks of DY D N/A DN
the activity level of the catalyst as specified in §63.2450(k)(4), do they
maintain records of the annual activity level checks and the subsequent
corrective actions? §63.2450(k)(4)(ii)
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10.0 Control Device and Recovery Device Checklists
Table 10-3. (continued)
I. Review of Records
6. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping specified by the Administrator (§63.147(e) for
wastewater controls) or approved by the Administrator (§§63.999(d)(l) and
(2), 63.8(f), and 63.10(b)(2)(vii) for control devices used for all other
emissions)?
Note: If an alternative parameter is monitored continuously, the records
described above in item "3" would be required for the alternative parameter.
Alternative recordkeeping might be required if the alternative monitoring is
not continuous.
7. Do records document the occurrence and cause of all periods when the daily D Y D N/A D N
averages of the continuously monitored parameters are outside their
established ranges? §§63.998(c)(2)(Hi) and 63.998(d)(5)
Note: This requirement also applies to the temperature differential across
the catalyst bed, if the facility monitors both the inlet and outlet temperatures.
Note: This requirement does not apply if the catalytic incinerator is used
only for wastewater emissions (although the occurrence will be documented
because operation outside the established range is a deviation, which must be
included in the compliance report).
8. For each CPMS, does the facility have manufacturer's or other written DY DN/A DN
specifications or recommendations for installation, operation, and calibration
of the monitoring equipment? §§63.996(c)(l) and (3) and 63.143(g)
9. For each CPMS, does the facility have records of all of the following:
§§63.998(c)(l)(i) and (ii) and 63.2485(o)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive D Y D N/A D N
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when DY D N/A DN
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY D N/A DN
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? D Y D N/A D N
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10.0 Control Device and Recovery Device Checklists
Table 10-3. (continued)
I. Review of Records
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? DY D N/A DN
10. Are all required records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspection
1. Are any one of the following monitoring devices present and operating:
(a) Temperature monitoring devices before and after the catalyst bed (if D Y D N/A D N
complying with §63.988(c)(2) or §63.143(e)(l))?
(b) A temperature monitoring device before the catalyst bed (if complying DY D N/A DN
with §63.2450(k)(4))?
(c) An organic monitoring device at the outlet of the catalytic incinerator (if D Y D N/A DN
complying with §63.143(e)(2))?
(d) Any other approved monitoring device (if complying with §63.996(d) or D Y D N/A D N
§63.143(e)(3))?
III. Note All Deficiencies
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10.0 Control Device and Recovery Device Checklists
Table 10-4. Compliance Checklist for a Boiler or Process Heater with a
Design Heat Input Capacity Less than 44 Megawatts and
the Vent Stream Is Not Introduced with the Primary Fuel
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Boiler or Process Heater Identification:
I. Review of Records
1. Does the facility maintain either of the following initial compliance records:
(a) All of the following records of performance tests:
• A description of the location at which the vent stream is introduced D Y D N/A D N
into the boiler or process heater? §63.998(a)(2)(ii)(B)(5)
• Either the percent reduction or outlet concentration of organic HAP D Y D N/A D N
orTOC? §63.998(a)(2)(ii)(B)(6)
• The firebox temperature averaged over the full period of the D Y D N/A D N
performance test? §63.998(a)(2)(ii)(B)(3)
(b) Documentation of the design evaluation in the notification of compliance DY D N/A DN
status report? §63.2520(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the only emissions controlled by the boiler or process
heater are from wastewater. A design evaluation also may be conducted
if the boiler or process heater is a small control device that is used to
comply with a percent reduction emission limit. §§63.2450(h) and
6 3.139 (d)
2. If the location at which a wastewater vent stream is introduced to the boiler or D Y D N/A D N
process heater changes, does the facility maintain records of the change?
§63.147(c)
Note: This requirement applies only if the boiler or process heater is used to
control wastewater emissions.
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10.0 Control Device and Recovery Device Checklists
Table 10-4. (continued)
I. Review of Records
3. Do records document that the facility continuously monitors the temperature D Y D N
of the gas stream in the firebox, or does the facility have documentation that
they requested and received approval to conduct an alternative to continuous
monitoring or to monitor an alternative parameter(s)? §§63.988(c)(l),
63.996(d), 63.143(e)(l) and (3), and Table 13 to subpart G
Note: Section 63.143(e)(2) specifies that an organic monitoring device may
be used as an alternative to temperature monitoring. Although the rule
explicitly provides this approach as an alternative only for wastewater
control devices, sources wishing to use this as an alternative for other
emission streams should follow the procedures for requesting approval of
alternative monitoring as specified in §63.8(f) of the General Provisions.
Note: If the alternative parameter is the emissions concentration as
measured using a CEMS, also use the checklist in Table 11-1.
4. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the monitored parameter? D Y D N D N/A
§§63.996(c)(6) and 63.143(f)
(b) Followed manufacturer's or other written specifications or D Y D N D N/A
recommendations for installation, operation, and calibration of the
monitoring equipment? §§63.996(c)(l) and (3) and 63.143(g)
(c) Maintained records of continuously monitored values in one of the DY DN DN/A
following formats: §§63.998(b)(l), 63.147(d), and 63.152(f)(2) and (3)
• all measured values, or
• all block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least one
measured data value per minute if measured more frequently than
once per minute), or
• all continuous records for only the most recent 3 valid hours of
records (under §63.998(b)(l)(iii)) or for the current operating day
(under §63.152(f)(3)(i)), and block hourly average values for earlier
data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)) or the daily
average must be within the established range (§63.152(f)(3) and (4)).
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10.0 Control Device and Recovery Device Checklists
Table 10-4. (continued)
I. Review of Records
(d) Maintained records of either daily average values or a statement that all DY DN DN/A
values were within the established operating range? §§63.998(b)(3),
63.147(d), and 63.152(f)(6)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "c " above.
§§63.998(b)(3)(ii) and 63.152(f)(6)
Note: Averages may be over an operating block if the boiler or process
heater is used only for batch process vents. §63.2460 (c) (4)
(e) As an alternative to "c" and "d" above when the conditions for alternative
recordkeeping in §63.998(b)(5)(i)(A) through (F) or §63.152(g)(l)(i)
through (vi) are met, does the facility meet both of the following
requirements:
Note: This alternative is not allowed if the boiler or process heater is
used only for storage tank emissions. §63.998(b)(5) introductory
paragraph
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
Retain only the daily average? D Y D N/A D N
Note: No record of the daily average is required if 6 months have
passed without an excursion. §§63.998(d)(5)(ii) and 63.152(g)(2)
(f) Maintained records of the occurrence and cause of all periods when the DY DN DN/A
monitored temperature is outside the established range?
§§63.998(c)(2)(iii) and 63.998(d)(5)
Note: This requirement does not apply if the process heater or boiler is
used only for wastewater emissions (although the occurrence will be
documented by virtue of the daily average value being outside the
established range).
If the facility received approval to monitor an alternative parameter, are they D Y D N D N/A
performing the recordkeeping specified by the Administrator (§63.147(e) for
wastewater controls) or approved by the Administrator (§§63.999(d)(l) and
(2), 63.8(f), and 63.10(b)(2)(vii) for control devices used for all other
emissions)?
Note: If an alternative parameter is monitored continuously, the records
described above in item "3" would be required for the alternative parameter.
Alternative recordkeeping might be required if the alternative monitoring is
not continuous.
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10.0 Control Device and Recovery Device Checklists
Table 10-4. (continued)
I. Review of Records
6. For any CPMS, does the facility have records of all of the following:
§§63.998(c)(l)(i) and (it) and 63.2485(o)
(a) The procedure used for calibrating the CPMS? DY DN DN/A
(b) The date and time of completion of calibration and preventive DY DN DN/A
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N D N/A
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N D N/A
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY DN DN/A
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N D N/A
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? DY DN DN/A
(h) Documentation that there were no excess emissions during each startup, D Y D N D N/A
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? DY DN DN/A
7. Are all required records kept for at least 5 years? §63.10(b)(l) D Y D N
II. Visual Inspection
1. Is a temperature monitoring device present in the firebox, or is an approved alternative DY DN
monitor present and operating?
Note: Section 63.143(e)(2) specifies that an organic monitoring device is also
acceptable for a thermal incinerator that is used to control emissions from waste
management units and wastewater treatment units.
III. Note All Deficiencies
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10.0 Control Device and Recovery Device Checklists
Table 10-5. Compliance Checklist for a Boiler or Process Heater with a Design
Heat Input Capacity Greater than 44 Megawatts or the Emission
Stream Is Introduced with the Primary Fuel
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Boiler or Process Heater Identification:
I. Review of Records
1. Do records describe the location at which the vent stream is introduced into D Y D N/A D N
the boiler or process heater? §63.998(a)(2)(ii)(B)(5)
Note: This requirement does not apply to boilers and process heaters used
only for wastewater emissions (except as part of a design evaluation as
specified in §63.l39(d)(2)(iii)).
2. If the location at which a wastewater vent stream is introduced to the boiler DY DN/A DN
or process heater changes, does the facility maintain records of the change?
§63.147(c)
Note: This requirement applies only if the boiler or process heater is used
to control wastewater emissions.
II. Note All Deficiencies
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10.0 Control Device and Recovery Device Checklists
Table 10-6. Compliance Checklist for a Regenerative Carbon Adsorber
Used as a Control Device or Recovery Device
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Note: This checklist does not apply if the carbon adsorber is used only to maintain a TRE above 5.0 for
continuous process vents at an existing source (8.0 at anew source).
Carbon Adsorber Identification:
I. Review of Records
1. If the carbon adsorber is used as a recovery device for batch process vents or
as a control device for any emission streams, does the facility maintain the
initial compliance records in (a) or (b):
(a) Both of the following records of performance tests:
Either the percent reduction or outlet concentration of organic HAP
orTOC? §63.998(a)(2)(ii)(C)(5)
D Y DN/A D N
Either the concentration of organic HAP or TOC at the outlet of the DY DN/A DN
carbon adsorber averaged over the full period of the performance
test, or all of the following during the period of each performance
test: (1) the total regeneration stream mass or volumetric flow
during each regeneration, (2) the temperature of the carbon bed after
each regeneration, and (3) the temperature of the carbon bed within
15 minutes after the completion of each cooling cycle?
§63.998(a)(2)(ii)(C)(3) and (4)
2.
(b) Documentation of the design evaluation in the notification of
compliance status report? §63.2520(d) (2) (it)
Note: A design evaluation may be conducted as an alternative to a
performance test if the only emissions controlled by the carbon adsorber
are from wastewater. A design evaluation also may be conducted if the
carbon adsorber is a small control device that is used to comply with a
percent reduction emission limit. §§63.2450(h) and 63.139(d)
If the carbon adsorber is used as a recovery device for a continuous process
vent, does the facility maintain documentation of all of the following
information: §63.998(a)(3)(Hi), (iv), and (v)
(a) All measurements and calculations performed to determine the TRE
index value?
D Y DN/A D N
D Y D N/A D N
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10.0 Control Device and Recovery Device Checklists
Table 10-6. (continued)
I. Review of Records
(b) Either of the following: DY DN/A DN
The total regeneration stream mass or volumetric flow during the
period of the TRE index value determination, the temperature of the
carbon bed after each regeneration during the period of the TRE
index value determination, and the temperature of the carbon bed
within 15 minutes of completion of any cooling cycle(s), or
• The concentration of organic compounds at the exit of the carbon
adsorber averaged over the same time period as the TRE index value
determination?
3. Do records document that the facility meets one of the following monitoring D Y D N
requirements for the carbon adsorber:
(a) Monitors the total regeneration stream mass or volumetric flow for each
regeneration cycle, the temperature of the carbon bed after each
regeneration, and the temperature of the carbon bed within 15 minutes
after the completion of the regeneration cooling cycle? §§63.990(c)(3),
63.993(c)(3), 63.143(e)(l), and Table 13 to subpart G
(b) Uses an "organic monitoring device" to continuously monitor a
parameter that provides an indication of the organic concentration at the
outlet of the carbon adsorber (e.g., millivolts generated by the
concentration sensor)? §§63.990(c) introductory paragraph,
63.993(c)(3), and63.143(e)(2)
(c) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §§63.996(d) and 63.143(e)(3)
Note: If the alternative parameter is the emissions concentration as
measured using a CEMS, also use the checklist in Table 11-1.
4. For the monitored parameters, has the facility:
(a) Established a site-specific operating range for each monitored D Y D N/A D N
parameter? §§63.996(c)(6) and 63.143(f)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §§63.996(c)(l) and (3) and 63.143(g)
(c) Maintained records of the following monitored parameters for each
regeneration cycle, if complying with monitoring identified in item 3 (a)
of this checklist: §§63.998(c) (3) (ii) and 63.14 7(d) (2)
• Total regeneration stream mass or volumetric flow? D Y D N/A D N
• Temperature of the carbon bed after each regeneration? D Y D N/A D N
• Temperature of the carbon bed within 15 minutes of completing any DY D N/A DN
cooling cycle?
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10.0 Control Device and Recovery Device Checklists
Table 10-6. (continued)
I. Review of Records
(d) Maintained records of the periods of operation when a monitored DY DN/A DN
parameter was outside its established range and the cause of these
deviations? §§63.998(c)(3)(iii) and 63.998(d)(5)
Note: The rule does not explicitly specify this recordkeeping
requirement if the carbon adsorber is used only for wastewater
emissions. However, the date and time of each deviation, and a general
summary of causes of deviations, must be included in the compliance
reports. §63.2520(e) (5) (Hi) (C) and (E).
5. If the facility received approval to monitor an alternative parameter, are they DY DN/A DN
performing the recordkeeping specified by the Administrator (§63.147(e) for
wastewater controls) or approved by the Administrator (§§63.999(d)(l) and
(2), 63.8(f), and 63.10(b)(2)(vii) for control devices used for all other
emissions)?
6. For any CPMS, does the facility have records of all of the following:
§§63.998(c)(l)(i) and (ii) and 63.2485(o)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive DY DN/A DN
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY D N/A DN
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? D Y D N/A D N
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? DY D N/A DN
7. Are all required records kept for at least 5 years? §63.10(b)(l) DY DN
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10.0 Control Device and Recovery Device Checklists
Table 10-6. (continued)
II. Visual Inspection
1. Are any one of the following monitoring devices present and operating:
(a) Temperature monitoring device in the carbon bed and a regeneration D Y D N/A D N
stream mass or volumetric flow monitoring device (if complying with
§63.990(c)(3) or §63.143(e)(l))?
(b) An organic monitoring device at the outlet of the carbon adsorber (if DY D N/A DN
complying with §§63.990(c) introductory paragraph, 63.993(c)(3), or
63.143(e)(2))?
(c) Any other approved monitoring device (if complying with §63.996(d) or D Y D N/A D N
§63.143(e)(3))?
(d) If flow can be intermittent, a flow indicator at the inlet or outlet of the D Y D N/A D N
device?
III. Note All Deficiencies
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10.0 Control Device and Recovery Device Checklists
Table 10-7. Compliance Checklist for an Absorber Used as a Control Device or
Recovery Device and the Scrubbing Fluid Is Anything Other than Water
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Note: This checklist does not apply if the absorber is used only to maintain a TRE above 5.0 for
continuous process vents at an existing source (8.0 at anew source).
Note: Use the checklist in Table 10-10 if the absorber is used to remove organic compounds and the
scrubbing fluid is water.
Absorber Identification:
I. Review of Records
D Y DN/A D N
D Y DN/A D N
D Y DN/A D N
1. If the absorber is used as a recovery device for batch process vents or as a
control device for any emission streams, does the facility maintain the initial
compliance records in (a) or (b):
(a) The following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP
orTOC? §63.998(a)(2)(ii)(C)(5)
Either the concentration of organic HAP or TOC at the outlet of the
absorber averaged over the full period of the performance test, or
both the temperature and specific gravity of the exiting scrubber
liquid averaged over the full period of the performance test?
§63.998(a)(2)(ii)(C)(l) and (4)
(b) Documentation of the design evaluation in the notification of
compliance status report? §63.2520(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the only emissions controlled by the absorber are
from wastewater. A design evaluation also may be conducted if the
absorber is a small control device that is used to comply with a percent
reduction emission limit. §§63.2450(h) and 63.139(d)
2. If the absorber is used as a recovery device for a continuous process vent,
does the facility maintain documentation of all of the following information:
§63.998(a) (3) (i), (iv), and (v)
(a) All measurements and calculations performed to determine the TRE
index value?
(b) Either of the following:
Both the exit temperature and specific gravity of the absorbing
liquid averaged over the same time period as the TRE index value
determination, or
The organic compound concentration at the exit of the absorber
averaged over the same time period as the TRE index value
determination?
D Y D N/A DN
D Y D N/A DN
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10.0 Control Device and Recovery Device Checklists
Table 10-7. (continued)
I. Review of Records
3. Do records document that the facility meets one of the following monitoring D Y D N
requirements for the absorber:
(a) Continuously monitors the temperature and specific gravity of the
scrubbing liquid exiting the absorber? §§63.990(c)(l) and 63.993(c)(l)
Note: Subpart G does not specify requirements for absorbers used to
control wastewater emissions. Also, for any other emission streams, if
the difference between the specific gravity of the saturated scrubbing
fluid and the fresh scrubbing fluid is less than 0.02 specific gravity units,
then this option may not be used.
(b) Uses an "organic monitoring device" to continuously monitor a
parameter that provides an indication of the organic concentration at the
outlet of the absorber? §§63.990(c)(l), 63.993(c)(l), and 63.143(e)(2)
(c) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §§63.996(d) and 63.143(e)(3)
Note: If the alternative parameter is the emissions concentration as
measured using a CEMS, also use the checklist in Table 11-1.
4. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the parameter? DY DN/A DN
§§63.996(c)(6) and 63.14 3(f)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §§63.996(c)(l) and (3) and 63.143(g)
(c) Maintained records of the monitoring data in one of the following D Y D N/A D N
formats: §§63.998(b)(l), 63.147(d), and 63.152(f)(2) and (3)
• All measured values, or
• All block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least
one measured data value per minute if measured more frequently
than once per minute), or
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10.0 Control Device and Recovery Device Checklists
Table 10-7. (continued)
I. Review of Records
All continuous records for only the most recent 3 valid hours of
records (under §63.998(b)(l)(iii)) or for the current operating day
(under §63.152(f)(3)(i)), and block hourly average values for earlier
data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)) or the daily
average must be within the established range (§63.152(f)(3) and
(4)).
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §§63.998(b)(3),
63.147(d), and 63.152(6)
Note: Averages may be over an operating block if the absorber is used
only for batch process vents. §63.2460(c) (4)
(e) As an alternative to "c" and "d" above when the conditions for
alternative recordkeeping in §63.998(b)(5)(i)(A) through (F) or
§63.152(g)(l)(i) through (vi) are met, does the facility meet both of the
following requirements:
Note: This alternative is not allowed if the absorber is used only for
storage tank emissions. §63.998(b)(5) introductory paragraph
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
Retain only the daily average? D Y D N/A D N
Note: No record of the daily average is required if 6 months have
passed without an excursion. §§63.998(d)(5)(ii) and 63.152(g)(2)
(f) Maintained records of both the periods of operation when the daily D Y D N/A D N
average of any continuously monitored parameter was outside its
established range and the cause of these deviations? §§63.998(c)(3)(iii)
and 63.998(d) (5)
Note: The rule does not explicitly specify this recordkeeping
requirement if the absorber is used only for wastewater emissions.
However, the date and time of each deviation, the daily average, and a
general summary of the causes of deviations must be included in the
compliance reports. §63.2520(e)(5)(iii)(C), (E), and (L)
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10.0 Control Device and Recovery Device Checklists
Table 10-7. (continued)
I. Review of Records
5. If the facility received approval to monitor an alternative parameter, are they DY DN/A DN
performing the recordkeeping specified by the Administrator (§63.147(e) for
wastewater controls) or approved by the Administrator (§§63.999(d)(l) and
(2), 63.8(f), and 63.10(b)(2)(vii) for control devices used for all other
emissions)?
6. For any CPMS, does the facility have records of all of the following:
§§63.998(c)(l)(i) and (it) and 63.2485(o)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive D Y D N/A D N
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when DY D N/A DN
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY D N/A DN
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? D Y D N/A D N
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? D Y D N/A D N
7. Are all required records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspection
1. Are any one of the following monitoring devices present and operating:
(a) Temperature and specific gravity monitoring devices in the scrubbing D Y D N/A D N
fluid exit line (if complying with §63.990(c)(l) or §63.143(e)(l))?
(b) An organic monitoring device at the outlet of the absorber (if complying DY D N/A DN
with §§63.990(c)(l), 63.993(c)(l), or 63.143(e)(2))?
(c) Any other approved monitoring device (if complying with §63.996(d) or D Y D N/A D N
§63.143(e)(3))?
(d) If flow can be intermittent, a flow indicator at the inlet or outlet of the D Y D N/A D N
device?
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Table 10-7. (continued)
III. Note All Deficiencies
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10.0 Control Device and Recovery Device Checklists
Note:
Note:
Table 10-8. Compliance Checklist for a Condenser Used as
a Control Device or Recovery Device
A "yes" response to a question indicates compliance with that requirement, and a "no" response
dicates noncompliance with the requirement. If a requirement is not applicable, check the
indicates noncompliance
"N/A" box.
This checklist does not apply if the condenser is used only to maintain a TRE above 5.0 for
continuous process vents at an existing source (8.0 at a new source). This checklist also does not
apply if the condenser is only a process condenser for batch process vents.
Condenser Identification:
I. Review of Records
1. If the condenser is used as a recovery device for batch process vents or as a
control device for any emission streams, does the facility maintain the initial
compliance records in (a), (b), or (c):
(a) The following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP D Y
orTOC? §63.998(a)(2)(ii)(C)(5)
DN/A D N
Either the concentration of organic HAP or TOC at the outlet of the
condenser averaged over the full period of the performance test, or
the exit (product side) temperature averaged over the full period of
the performance test? §63.998(a)(2)(ii)(C)(2) and (4)
(b) Documentation of the design evaluation in the notification of
compliance status report? §63.2520(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the only emissions controlled by the condenser are
from wastewater. A design evaluation also may be conducted if the
condenser is a small control device that is used to comply with a percent
reduction emission limit. §§63.2450(h) and 63.139(d)
D Y DN/A D N
D Y DN/A D N
(c) Calculations of the controlled emissions and corresponding percent
reduction in the notification of compliance status report?
§63.2520(d)(2)(ii)
Note: This option applies only if the emissions routed to the condenser
are from batch process vents. §63.2460(c) (2) (Hi)
D Y D N/A D N
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10.0 Control Device and Recovery Device Checklists
Table 10-8. (continued)
I. Review of Records
2. If the condenser is used as a recovery device for a continuous process vent,
does the facility maintain documentation of all of the following information:
§63.998(a)(3)(ii), (iv), and (v)
(a) Measurements and calculations performed to determine the TRE index D Y D N/A D N
value?
(b) Either the exit (product side) temperature or outlet concentration of D Y D N/A D N
organic compounds averaged over the same time period as the TRE
index value determination?
3. Do records document that the facility meets one of the following monitoring D Y D N
requirements for the condenser:
(a) Continuously monitors the product side exit temperature of the
condenser, or §§63.990(c)(2) and 63.993(c)(2)
(b) Uses an "organic monitoring device" to continuously monitor a
parameter that provides an indication of the organic concentration at the
outlet of the condenser, or §§63.990(c)(2), 63.993(c)(2), and
63.143(e)(2)
(c) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §§63.996(d) and 63.143(e)(3)
Note: If the alternative parameter is the emissions concentration as
measured using CEMS, also use the checklist in Table 11-1.
4. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the parameter? DY DN/A DN
§§63.996(c)(6) and 63.143(f)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §§63.996(c)(l) and (3) and 63.143(g)
(c) Maintained records of the monitoring data in one of the following D Y D N/A D N
formats: §§63.998(b)(l), 63.147(d), and 63.152(f)(2) and (3)
All measured values, or
All block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least
one measured data value per minute if measured more frequently
than once per minute), or
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10.0 Control Device and Recovery Device Checklists
Table 10-8. (continued)
I. Review of Records
All continuous records for only the most recent 3 valid hours of
records (under §63.998(b)(l)(iii)) or for the current operating day
(under §63.152(f)(3)(i)), and block hourly average values for earlier
data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)) or the daily
average must be within the established range (§63.152(f)(3) and
(4)).
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §§63.998(b)(3),
63.147(d), and 63.152(6)
Note: Averages may be over an operating block if the condenser is used
only for batch process vents. §63.2460(c) (4)
(e) As an alternative to "c" and "d" above when the conditions for
alternative recordkeeping in §63.998(b)(5)(i)(A) through (F) or
§63.152(g)(l)(i) through (vi) are met, does the facility meet both of the
following requirements:
Note: This alternative is not allowed if the condenser is used only for
storage tank emissions. §63.998(b)(5) introductory paragraph
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
Retain only the daily average? D Y D N/A D N
Note: No record of the daily average is required if 6 months have
passed without an excursion, as long as the daily average continues
to be within established ranges. The facility must document in its
notification of compliance status report that it is electing not to
retain this record. §§63.998(d)(5)(ii) and 63.152(g)(2)
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10.0 Control Device and Recovery Device Checklists
Table 10-8. (continued)
I. Review of Records
(f) Maintained records of both the periods of operation when the daily DY DN/A DN
average of any continuously monitored parameter was outside its
established range and the cause of these deviations? §§63.998(c)(3)(iii)
and 63.998(d) (5)
Note: The rule does not explicitly specify this recordkeeping
requirement if the condenser is used only for wastewater emissions.
However, the date and time, daily averages, and a general summary of
causes of deviations must be included in the compliance reports.
§63.2520(e)(5)(iii)(C), (E), and (L)
5. If the facility received approval to monitor an alternative parameter, are they DY DN/A DN
performing the recordkeeping specified by the Administrator (§63.147(e) for
wastewater controls) or approved by the Administrator (§§63.999(d)(l) and
(2), 63.8(f), and 63.10(b)(2)(vii) for control devices used for all other
emissions)?
6. For any CPMS, does the facility have records of all of the following:
§§63.998(c)(l)(i) and (ii) and 63.2485(o)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive D Y D N/A D N
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when DY D N/A DN
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY D N/A DN
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? D Y D N/A D N
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? D Y D N/A D N
7. Are all required records kept for at least 5 years? §63.10(b)(l) D Y D N
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Table 10-8. (continued)
II. Visual Inspection
1. Are any one of the following monitoring devices present and operating:
(a) A temperature monitoring device at the product side exit of the DY DN/A DN
condenser (if complying with §63.990(c)(2) or §63.143(e)(l)?
(b) An organic monitoring device at the outlet of the condenser (if DY D N/A DN
complying with §63.990(c)(2), §63.993(c)(2), or §63.143(e)(2))?
(c) Any other approved monitoring device (if complying with §63.996(d) D Y D N/A D N
or§63.143(e)(3))?
(d) If flow can be intermittent, a flow indicator at the inlet or outlet of the D Y D N/A D N
device?
III. Note All Deficiencies
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Table 10-9. Compliance Checklist for a Control Device or Recovery
Device Not Specifically Listed
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Control Device or Recovery Device Identification:
I. Review of Records
1. If the device is a recovery device for batch process vents or a control device
for any emission streams, does the facility maintain either of the following
initial compliance records:
(a) Data collected during a performance test as approved by the
Administrator? §§63.995(b), 63.998(a)(2)(i), 63.143(e)(3), and
63.146(b)(7)(ii)(C)
D Y DN/A D N
(b) Documentation of a design evaluation in the notification of compliance D Y ON/A D N
status report? §63.2520(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the device is a small control device that is used to
comply with a percent reduction emission limit. §§63.2450(h) and
63.2460(c)(2)(ii)
2. If the device is used as a recovery device for a continuous process vent, does
the facility keep all of the following records:
(a) Records as approved by the Administrator? §63.993(c)(4) DY D N/A DN
(b) All measurements and calculations performed to determine the TRE D Y D N/A D N
index value? §63.998(a)(3)(v)
3. If the facility received approval for any monitoring, are the parameters being DY D N/A DN
monitored and recorded as approved by the Administrator? §§63.147(e),
63.995(c), 63.999(d)(2), 63.8(f), and 63.10(b)(2)(vii)
4. Are all required records kept for at least 5 years? §63.10(b)(l)
DY DN
II. Visual Inspection
1. Are all approved monitoring devices present and operating?
D Y D N/A D N
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Table 10-9. (continued)
III. Note All Deficiencies
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10.0 Control Device and Recovery Device Checklists
Table 10-10. Compliance Checklist for a Scrubber Used as a Control Device
or an Absorber that Uses Water as the Scrubbing Fluid
Note: Use this checklist for scrubbers that control halogen atoms in halogenated vent streams prior to a
combustion device or control hydrogen halide and halogen emissions from process vents or that
are generated by combusting a halogenated vent stream. Also use this checklist for a gas
absorber that removes organic compounds and uses water as the scrubbing fluid (these devices
are also considered to be "scrubbers" in this checklist). A "yes" response to a question indicates
compliance with that requirement, and a "no" response indicates noncompliance with the
requirement. If a requirement is not applicable, check the "N/A" box.
Scrubber Identification:
I. Review of Records
Does the facility maintain the initial compliance records in (a) or (b):
(a) Either of the following records of performance tests:
• If the scrubber is used before a combustion device to reduce the DY ON/A DN
halogen atom mass emission rate, a record of the halogen
concentration prior to the combustion device? §§63.994(b)(2) and
63.998 (a) (4)
If the scrubber is used to control hydrogen halide and halogen
emissions from process vents or after a combustion device, all of the
following records: §§63.998(a)(2)(ii)(D) and 63.2450(k)(3)
*• The resulting percent reduction, mass emission rate, or outlet D Y ON/A D N
concentration?
*• The pH or caustic strength of the scrubber effluent averaged DY ON/A DN
over the time period of the performance test?
*• The scrubber liquid-to-gas ratio averaged over the time period D Y ON/A D N
of the performance test?
(b) Documentation of the design evaluation in the notification of D Y ON/A D N
compliance status report? §63.2520(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the scrubber is a small control device that is used to
comply with a percent reduction emission limit. A design evaluation
also may be conducted for any halogen reduction device prior to a
combustion control device. §§63.994(b)(2), 63.2450(f) and(h), and
63.2485 (g)
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Table 10-10. (continued)
I. Review of Records
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements for the scrubber:
(a) Monitors all of the following parameters:
Continuously monitors either the pH or the caustic strength of the
scrubber effluent? §§63.994(c)(l)(i) and 63.2450(k)(3)
Note: As an alternative to continuous monitoring, the pH or caustic
strength may be measured at least once per day for halogen
scrubbers that control only batch process vents.
• Continuously monitors the flow of the scrubber liquid influent?
§63.994(c)(l)(H)
• Has measured or otherwise determined the inlet gas flow?
§63.994(c)(l)(iii)
(b) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §63.996(d)
3. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the parameter? DY DN/A DN
§63.996(c)(6)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
(c) Maintained records of the monitoring data in one of the following D Y D N/A D N
formats: §63.998(b)(l)
All measured values, or
All block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least
one measured data value per minute if measured more frequently
than once per minute), or
• All continuous records for only the most recent 3 valid hours of
records and block hourly average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction. §63.998(b)(l)(iii)
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Table 10-10. (continued)
I. Review of Records
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §63.998(b)(3)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "c" above.
§63.998(b)(3)(ii)
(e) As an alternative to "c" and "d" above when the conditions for
alternative recordkeeping in §63.998(b)(5)(i)(A) through (F) are met,
does the facility meet both of the following requirements:
Note: This alternative is not allowed if the scrubber is used only for
storage tank emissions. §63.998(b)(5) introductory paragraph and
§63.2485 (g)
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
• Retain only the daily average? DY D N/A DN
Note: No record of the daily average is required if 6 months have
passed without an excursion. §63.998(d) (5) (ii)
(f) Maintained records of both the periods of operation when the daily D Y D N/A D N
average of any continuously monitored parameter was outside its
established range and the cause of these deviations? §§63.998(c)(3)(iii)
and 63.998(d) (5)
4. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping approved by the Administrator?
§§63.999(d)(l)and(2), 63.8(f), and 63.10(b)(2)(vii)
5. For any CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive DY DN/A DN
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY D N/A DN
of the CPMS during which excess emissions occur?
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Table 10-10. (continued)
I. Review of Records
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? D Y D N/A D N
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? DY D N/A DN
6. Are all required records kept for at least 5 years? §63.10(b)(l) D Y D N
II. Visual Inspection
1. Are either of the following monitoring devices present and operating:
(a) Effluent pH or caustic strength monitor and effluent liquid flow monitor D Y D N/A D N
(if complying with §63.994(c)(l))?
(b) Any other approved monitoring device (if complying with DY D N/A DN
§§63.994(c)(2) and 63.996(d))?
III. Note All Deficiencies
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Table 10-11. Compliance Checklist for Biofilters
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Biofilter Identification:
I. Review of Records
1. Does the facility maintain the following records of performance tests:
Note: A design evaluation is not allowed for biofilters. §63.2460(c)(9)(ii)
(a) Either the percent reduction or outlet concentration of organic HAP or D Y D N/A D N
TOC? §63.998(a)(2)(ii)(B)(4)
(b) Either the biofilter bed temperature or the outlet total organic HAP or D Y D N/A D N
TOC concentration averaged over the full period of the performance test?
§§63.998(a)(2)(ii)(B)(l) and 63.2460(c)(9)(ii)(C)
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements to demonstrate ongoing compliance for the biofilter:
(a) Continuously monitors the biofilter bed temperature? §63.2460(c)(9)(iii)
(b) Uses an "organic monitoring device" to continuously monitor a
parameter that provides an indication of the organic concentration at the
outlet of the biofilter? §63.2460(c) (9) (Hi)
3. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the monitored parameter? D Y D N/A D N
§§63.996(c)(6) and 63.2460(c)(9)(iii)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
(c) Maintained records of continuously monitored values in one of the DY D N/A DN
following formats: §63.998(b)(l)
• all measured values, or
• all block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least one
measured data value per minute if measured more frequently than
once per minute), or
• all continuous records for only the most recent 3 valid hours of
records, and block hourly average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)).
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Table 10-11. (continued)
I. Review of Records
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §63.998(b)(3)
Note: If the owner or operator chooses this option and the daily average
value is not calculated and recorded, then continuous or short-term block
averages may not be discarded as otherwise allowed by the third option
in item "c" above. §63.998(b)(3)(ii)
Note: Averages may be over an operating block if the biofllter is used
only for batch process vents. §63.2460 (c) (4)
(e) As an alternative to "c" and "d" above when the conditions for alternative
recordkeeping in §63.998(b)(5)(i)(A) through (F) are met, does the
facility meet both of the following requirements:
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
Retain only the daily average? D Y D N/A D N
Note: No record of the daily average is required if 6 months have
passed without an excursion. §63.998(d)(5)(ii)
(f) Maintained records of the occurrence and cause of all periods when the DY DN/A DN
monitored parameter is outside its established range? §63.998(d)(5)
4. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping approved by the Administrator (§§63.999(d)(l)
and (2), 63.8(f), and 63.10(b)(2)(vii))?
Note: If an alternative parameter is monitored continuously, the records
described above in item "3" would be required for the alternative parameter.
Alternative recordkeeping might be required if the alternative monitoring is
not continuous.
5. For any CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? D Y D N/A D N
(b) The date and time of completion of calibration and preventive DY DN/A DN
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction D Y D N/A D N
of the CPMS during which excess emissions occur?
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Table 10-11. (continued)
I. Review of Records
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? DY D N/A DN
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? D Y D N/A D N
6. Do records indicate that repeat performance tests were conducted at the
following times: §63.2460(c)(9)(iv)
(a) Within 2 years after the previous performance test? D Y D N/A D N
(b) Within 150 days after either of the following events:
• Replacement of any portion of the biofilter media with a different DY D N/A DN
type of media?
• Replacement of more than 50 percent of the biofilter media with the DY DN/A DN
same type of media?
7. Are all required records kept for at least 5 years? §63.10(b)(l) D Y D N
II. Visual Inspection
1. Are any of the following monitoring devices present and operating?
(a) Temperature monitoring device (or multiple devices) in the biofilter bed? D Y D N/A D N
(b) An organic monitoring device at the outlet of the biofilter bed? D Y D N/A D N
(c) Any other approved monitoring device, if applicable? D Y D N/A D N
III. Note All Deficiencies
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10.0 Control Device and Recovery Device Checklists
Table 10-12. Compliance Checklist for Fabric Filters
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Note: Use this checklist for fabric filters that control HAP metals emissions from process vents at new
sources.
Fabric Filter Identification:
I. Review of Records
1 . Does the facility maintain records of performance tests showing the fabric D Y D N/A D N
filter reduces HAP metals emissions by at least 97 percent? §63.2465(d)(2)
Note: A design evaluation is not allowed for fabric filters.
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements to demonstrate ongoing compliance for the fabric filter:
(a) Use a bag leak detection system? §63.1366(b)(l)(xi) as referenced from
§63. 2 465 (d) (3)
(b) Has documentation that they requested and received approval to conduct
alternative monitoring? §63.8(f)
3 . For each bag leak detection system, do records show the facility followed D Y D N/A D N
EPA guidance for installation, operation, and calibration of the system?
§63.1366(b)(l)(xi)(D)
Note: Written specifications or instructions from the system manufacturer
may be used in the absence of EPA guidance.
4. For each bag leak detection system, does the facility maintain all of the
following records: §63.2525(k)
(a) Date and time of each bag leak detection alarm? D Y D N/A D N
(b) Brief explanation of the cause of the alarm? DY DN/A DN
(c) Description of the corrective action taken? D Y D N/A D N
5. If the facility received approval to conduct alternative monitoring, are they DY D N/A DN
performing the recordkeeping approved by the Administrator (§§63.8(f) and
6. Are all required records kept for at least 5 years? §63.10(b)(l) D Y D N
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10.0 Control Device and Recovery Device Checklists
Table 10-12. (continued)
II. Visual Inspection
1. If the facility uses a bag leak detection system:
(a) Does it provide output of relative participate matter emissions? DY DN/A DN
(b) Is it equipped with an alarm? DY D N/A DN
(c) Are sensors located either in each compartment or cell of a positive D Y D N/A D N
pressure fabric filter or downstream of a negative pressure or induced
draft fabric filter?
(d) Are the sensitivity or range, averaging period, alarm set points, and alarm D Y D N/A D N
delay time the same as in the operation and maintenance plan?
§63.1366(b)(l)(xi)(F)
Note: Sensitivity may be increased by up to 100percent or decreased by
up to 50 percent during a 3 65-day period, provided the baghouse is first
inspected to demonstrate it is in good operating condition.
2. If the facility received approval for alternative monitoring, is the alternative DY D N/A DN
monitoring device present and operating?
III. Note All Deficiencies
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10.0 Control Device and Recovery Device Checklists
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11.0 Alternative Standard
11.0 Alternative Standard
This section contains a flowchart of control requirements and an inspection checklist for process
vents and storage tanks that comply with the alternative standard in §63.2505 of subpart FFFF. Use
Figure 11-1 to determine the applicable control requirements under the alternative standard. Then use the
inspection checklist in Table 11-1 to determine compliance with the continuous emissions monitoring
requirements. Use the checklist in Table 11-2 to determine compliance for a scrubber that is used to
comply with the percent reduction alternative to the otherwise applicable concentration limit for hydrogen
halide and halogen F£AP that are generated in a combustion device that controls a halogenated vent
stream.
( Stan ")
Reduce HAP emissions to
an total organic HAP concentration
of 543 ppcnv of less and to an outlet
concentration of hydrogen halide and
halogen HAP of 53 ppmv or less. Measure
concentrations using CEMS.
Are you
using a combustion
device to comply with the
alternative standard
('flares not
allowed!?
Are yoci
controlling emissions
from a halogenated
vent stream?
organic HAP
emissions lo < 20 ppmv
asTOC. Measure
concentration using CEMS.
Reduce outlet hydrogen
halide and halogen HAP to
2 20 ppmv. Measure
concentration using CEMS
Reduce hydrogen
and halogen HAP
emissions by > 95 percent.
This option is only available
if you use a scrubber after
the combustion device.
Figure 11-1. Alternative standard for process vents or storage tanks.
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11.0 Alternative Standard
Table 11-1. Checklist to Demonstrate Compliance with
Continuous Emissions Monitoring Requirements
Note: Use this checklist when emissions from process vents and/or storage tanks are vented to a control
device and the facility uses CEMS to comply with the alternative standard as specified in
§63.2505 or when the emissions concentration is used as the parameter that is monitored to
demonstrate ongoing compliance with a percent reduction emissions limit. The checklist applies
to CEMS for organic HAP and to CEMS for hydrogen halide and halogen HAP. A "yes"
response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If a question is not applicable, check the
"N/A" box.
Process or Process Vent Identification:
Storage Tank Identification:
Control Device Identification:
I. Review of Records
1. Does the facility have all of the following initial compliance records:
(a) Documentation that the Administrator was notified at least 60 days D Y D N
before conducting a performance evaluation of the CEMS? §63.8(e)(2)
(b) Results of CEMS performance evaluations (and measurements needed to DY DN
determine conditions of performance evaluation)? §63.10(b)(2)(viii)
and (ix)
(c) Identification in the notification of compliance status report of target D Y D N
analytes or predominant HAP that are used to calibrate the CEMS?
§§63.2505(b)(3) and 63.2450(j)(2)
(d) Identification of the process vent(s) and/or storage tank(s), the control D Y D N
requirement, monitoring requirements, and type of control as part of the
operating scenario(s) for the MCPU? §63. 25 25 (b)
(e) Written copies of all of the procedures (e.g., calibrations) that are part of DY DN
the quality control program? §§63.8(d)(2) and 63.10(c)(14)
2. Does the facility have all of the following ongoing quality control records:
(a) CEMS calibration checks? §63. 10(b)(2)(x) DY DN
(b) Adjustments and maintenance performed on the CEMS? DY D N/A DN
§63.10(b)(2)(xi)
3. Does the facility have all of the following operating records:
(a) All CEMS measurements when emissions are vented to the control D Y D N/A D N
device (including periods of SSM, unavoidable CEMS breakdowns, and
out-of-control periods)? §63.10(b)(2)(vii) and (c)(l)
(b) Date and time when CEMS was malfunctioning or inoperative (except D Y D N/A D N
for zero [low-level] and high level checks)? §§63.10(b)(2)(vi) and
(c) Nature and cause of malfunctions (if known) and corrective actions DY D N/A DN
taken? §63. 1 0(c) (1 0) and (1 1)
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11.0 Alternative Standard
Table 11-1. (continued)
I. Review of Records
(d) Date and time when CEMS was out of control (e.g., calibration drift DY DN/A DN
exceeds specifications or CEMS fails cylinder gas audit)?
§63.10(b) (2) (vi) and (c) (6)
(e) Date and time of each deviation from the outlet concentration emission D Y D N/A D N
limit, and whether or not the deviation occurred during a period of
startup, shutdown, and malfunction? §63.2525(h)
4. Are the CEMS data (excluding data collected when the CEMS was out of DY DN
control) reduced to operating day averages for comparison with the outlet
concentration emission limits? §§63.2505(b)(7) and 63.8(c)(7)(ii)
5. If the emissions are combined with supplemental gases before the control DY DN/A DN
device, do records show the facility corrects the concentrations to account for
dilution caused by supplemental gases using the procedures specified in
§§63.2450(i) and 63.2460(c)(6)? §63.2450(j)(5)
6. Are all records kept for at least 5 years? §63.10(b)(l) DY D N/A DN
II. Visual Inspections
1. Are CEMS for TOC and/or total hydrogen halide and halogen HAP, as DY DN
applicable, located in the exhaust line from the control device and
operating?
Note: A CEMS for hydrogen halide and halogen HAP is not required if
these HAP are generated in a combustion device that controls halogenated
vent streams and the facility uses a scrubber to reduce the hydrogen halide
and halogen HAP emissions by >95 percent. See the checklist in Table 11-
2 to determine compliance with these requirements.
III. Note All Deficiencies
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11.0 Alternative Standard
Table 11-2. Checklist for Parameter Monitoring Option for Scrubbers Used to Reduce Hydrogen
Halide and Halogen HAP Emissions Under the Alternative Standard
Note: Use this checklist when a facility generates hydrogen halide and halogen HAP emissions in a
combustion control device that controls a halogenated vent stream, and the facility elects to
control the hydrogen halide and halogen HAP emissions to >95 percent (using a scrubber) instead
of to <20 ppmv. A "yes" response to a question in this checklist means compliance with that
requirement, and a "no"response means noncompliance with the requirement. If a question is not
applicable, check the "N/A" box.
Identification of Process Vents and Storage Tanks with Halogenated
Vent Streams:
Scrubber Identification:
I. Review of Records
1. Do results of the initial performance test demonstrate 95 percent reduction in D Y D N/A D N
total hydrogen halide and halogen HAP emissions? §63.2505(b)(5)(i)
2. Do records indicate that the facility monitors all of the following scrubber
operating parameters: §§63.994(c), 63.2505(b)(5)(ii), and 63.2450(k)
(a) continuous monitoring of pH or caustic strength? D Y D N/A D N
(b) continuous monitoring of liquid flow? DY D N/A DN
(c) measurement or other determination of gas flow? DY D N/A DN
3. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the monitored parameter? D Y D N/A D N
§§63.996(c)(6), 63.999(b)(3), and 63.2505(b) (5) (i)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
(c) Maintained records of continuously monitored parameters in one of the DY D N/A DN
following formats: §63.998(b)(l)
• all measured values, or
• all block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least
one measured data value per minute if measured more frequently
than once per minute), or
• all continuous records for only the most recent 3 valid hours of
records and block average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and hourly averages must include periods ofCPMS
breakdown and malfunction. §63.998(b) (1) (Hi)
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11.0 Alternative Standard
Table 11-2. (continued)
I. Review of Records
(d) Maintained records of either daily average values of continuously DY DN/A DN
monitored parameters or a statement that all values are within the
established operating range? §§63.998(b)(3) and 63.2505(b)(7)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "2" above.
§63.998(b)(3)(ii)
Note: Daily averages must be reported in the compliance report for all
days when an excursion occurred. An excursion is either a daily
average value outside the established range or a day for which
insufficient monitoring data were collected. §63.999(c)(6)
(e) As an alternative to "c" and "d" above, does the facility retain only the D Y D N/A D N
daily average because the conditions for alternative recordkeeping in
§63.998(b)(5)(i)(A) are met (and did the facility document in their
notification of compliance status report that they were implementing this
alternative)?
Note: No record of the daily average is required if 6 months have
passed without an excursion. §63.998(d) (5) (ii)
(f) Maintained records of the occurrence and cause of all periods when the DY DN/A DN
monitored parameters are outside their established ranges?
§6 3.998 (d) (5)
4. For each CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i)
(a) procedure used for calibrating the CPMS? D Y D N/A D N
(b) date and time of completion of calibration and preventive maintenance? D Y D N/A D N
(c) "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading, and a "no adjustment" statement
otherwise?
(d) start time and duration (or start and stop times) of any periods when the D Y D N/A D N
CPMS is inoperative?
(e) occurrence and duration of each start-up, shutdown, and malfunction DY D N/A DN
during which excess emissions occur?
(f) if excess emissions occur during a period of SSM, documentation that D Y D N/A D N
procedures in the SSM plan were followed or a description of actions
taken?
(g) documentation of each SSM event? DY DN/A DN
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11.0 Alternative Standard
Table 11-2. (continued)
I. Review of Records
(h) if no excess emissions occur during an SSM event, documentation DY D N/A DN
affirming this result?
(i) the total duration of operating time during the reporting period? DY D N/A DN
5. Are all records kept for at least 5 years? §63.10(b)(l) DY DN/A DN
II. Visual Inspections
1. Are the following devices present and operating:
(a) pH or caustic strength monitoring device? D Y D N
(b) liquid flow monitoring device? D Y D N
(c) gas flow monitoring device (if complying with §63.994(c)(l)(ii)(B))? DY D N/A DN
(d) if flow can be intermittent, a flow indicator at the inlet or outlet to the D Y D N/A D N
control device?
III. Note All Deficiencies
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72.0 Reporting
12.0 Reporting
This section contains inspection checklists for various reports required under subpart FFFF. Use
Table 12-1 to determine compliance with the requirements for notification of compliance status reports.
Use Table 12-2 to determine compliance with compliance reporting requirements.
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72.0 Reporting
Table 12-1. Inspection Checklist for Notification of Compliance Status Report
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the question is not applicable,
check the "N/A" box.
I. Review of Records
1. Does the report include the results of all applicability determinations DY DN/A DN
(including Group 1 or Group 2 determinations), emission calculations, or
other analyses used to identify and quantify HAP usage and/or emissions
from the affected source? §63.2520(d)(2)(i)
Note: Quantifying usage is an option only for Group 2 batch process vents.
As an alternative to estimating uncontrolled emissions from Group 2 batch
process vents at an existing source, an owner or operator may elect to
demonstrate that non-reactive organic HAP are the only HAP used in the
process and that usage is < 10,000 Ib/yr. §63.2460(b)(7)
2. Does the report include all of the following information related to initial
compliance determinations, as applicable:
(a) Emissions profiles and descriptions of worst-case operating and/or testing D Y D N/A D N
conditions when a performance test is conducted for a control device that
is used to comply with an emission limit for batch process vents?
§63.2520(d)(2)(ii) and (v)
(b) Performance test reports, including site-specific operating limits and D Y D N/A D N
supporting data and calculation records? §§63.2520(d)(2)(ii) and (Hi),
63.999(a)(2) and (3), 63.146(b)(7)(ii)(A) and (C), 63.146(b)(8) and
(9)(ii),and63.152(b)
Note: Operating limits and supporting calculations may be included in
operating scenarios.
(c) Flare compliance assessments? §§63.2450(f)(2)(ii), 63.2520(d)(2)(ii), DY D N/A DN
63.999(a)(2), and 63.l46(b)(7)(i)
(d) Design evaluations, including site-specific operating limits? D Y D N/A D N
§§63.2520(d)(2)(ii) and (Hi); 63.999(b)(2)(i) through (iv); and
63.146(b)(7)(ii)(A) and (B), (b)(8), and (b)(9)(i)
Note: Operating limits and supporting calculations may be included in
operating scenarios.
(e) If storage tank emissions are routed to a process, a design evaluation or D Y D N/A D N
engineering assessment demonstrating the extent to which the emissions
are recycled, consumed, transformed by chemical reaction into materials
that are not HAP, incorporated into a product, and/or removed?
§§63.984(b)(2) and (3) and 63.999(b)(l)(i)
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72.0 Reporting
Table 12-1. (continued)
I. Review of Records
(f) If storage tank emissions are routed to a fuel gas system, a statement D Y D N/A D N
documenting that the emission stream is connected to the fuel gas
system? §§63.984(c) and 63.999(b)(l)(ii)
(g) If emissions from a Group 1 transfer rack are routed to a fuel gas system D Y D N/A D N
or process, a statement of connection? §63.999(b)(l)(iii)
(h) Determination of whether a condenser associated with batch operations is DY DN/A DN
a control device or a process condenser? §§63.2460(c)(l) and
63.2520(d)(2)(ii)
3. Does the report include descriptions of monitoring devices and monitoring
frequencies? §63.2520(d)(2)(Hi)
4. Does the report include all of the following information about wastewater
systems:
(a) Information about each wastewater stream from an MCPU that contains D Y D N/A D N
PSHAP and/or SHAP? §63.146(b)(2) and Table 15 to subpart G
Note that Table 15 to subpart G indicates that the information may be
submitted in other formats. Including this information in an operating
scenario is one option.
(b) Information about each treatment process that receives, manages, or treats D Y D N/A D N
a Group 1 wastewater stream or residual removed from a Group 1
wastewater stream? §63.146(b)(4) and Table 17 to subpart G
Note that this information may be included in operating scenarios for
each process that discharges wastewater to the treatment unit.
(c) Information about each waste management unit that receives or manages D Y D N/A D N
a Group 1 wastewater stream or a residual removed from a Group 1
wastewater stream? §63.146(b)(5) and Table 18 to subpart G
Note that this information may be submitted in the operating scenarios
for each process that discharges wastewater to the waste management
unit.
(d) Information about each residual removed from a Group 1 wastewater D Y D N/A D N
stream? §63.146(b)(6) and Table 19 to subpart G
Note that this information may be submitted in the operating scenarios
for each process that discharges wastewater to the waste management
unit.
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72.0 Reporting
Table 12-1. (continued)
I. Review of Records
(e) All of the following for an initial compliance demonstration, if the
facility complies with the alternative requirements for wastewater that is
Group 1 for SHAP:
• Data used in the demonstration (e.g., PSHAP and SHAP DY DN/A DN
concentrations, wastewater flows, Fblo and inputs for WATER9
modeling)?
• Emissions from an uncontrolled equalization unit, neutralization unit, D Y D N/A D N
and/or clarifier as estimated using WATER9 modeling?
• Description of and results of WATER9 modeling validation DY D N/A DN
procedures?
• Results of overall destruction efficiency as calculated using D Y D N/A D N
Equation 1 in §63.2485(n)(2)?
5. Does the report include all of the following information about equipment
leaks: §63.2520(d)(2)(vii) and the sections cited below
(a) Identification of process unit or affected facility? §63.1039(a)(l)(i) DY D N/A DN
(b) Number of each equipment type, excluding equipment in vacuum D Y D N/A D N
service? §63.1039(a)(l)(ii)
(c) Method of compliance with the standards? §63.1039(a)(l)(iii) D Y D N/A D N
(d) If the method of compliance is pressure testing, the products or product D Y D N/A D N
codes and the planned schedule for pressure testing? §63.1039(a)(2)
(e) If the method of compliance is to enclose the process unit or affected DY DN/A DN
facility, identification of the process unit or affected facility, a description
of the system used to create a negative pressure in the enclosure, and a
description of the control device to which the emissions are routed?
§63.10 39 (a) (3)
6. Does the report identify the following equipment and related information:
(a) Parts of the affected source that are subject to other rules and the DY DN/A DN
authority under which the facility will comply for such equipment?
§63.2520(d)(2)(vi)
Note: Section 63.2535 identifies other rules that may overlap with
subpart FFFF and the applicable compliance options.
(b) Storage tanks that comply with the vapor balancing option in D Y D N/A D N
§63.2470(e)? §63.2520(d)(2)(viii)
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72.0 Reporting
Table 12-1. (continued)
I. Review of Records
7. Does the report include the following records for each process unit group
(PUG), if any, that the facility developed: §63.2520(d)(2)(ix) and the
sections cited below
(a) Identification of each MCPU and other process units that are part of the DY DN/A DN
initial PUG, and the procedure used to create the PUG (e.g., processing
equipment that is shared by process units)? §63.2535(l)(l)(v)
(b) Determination of the primary product for the initial PUG? DY D N/A DN
§63.25 35(l)(2)(iv)
8. Does the report include operating scenarios for all MCPUs at the affected
source, and does each operating scenario contain the following information,
as applicable: §§63.2520(d)(2)(iv) and 63.2525(b)
(a) A description of the process and the type of process equipment used? D Y D N/A D N
(b) Identification of process vents and wastewater points of determination for D Y D N/A D N
the process, and identification of storage tanks and transfer racks that are
assigned to the MCPU?
Note: Emission episodes (i.e., HAP emissions for a standard batch in
Ib/batch) should be included for the process vents if compliance with the
emission limits is by a method other than the alternative standard.
(c) Applicable control requirements for each emission stream, including the D Y D N/A D N
level of required control?
Note: Emission limits are for collective organic HAP from all batch
process vents and collective hydrogen halide and halogen HAP emissions
from all process vents (excluding hydrogen halide and halogen HAP
emissions formed in combustion control devices). Therefore, the
operating scenario should identify the level of control for each vent if
some vents are controlled to different levels than others.
(d) Identification of each type of control device and treatment process used, D Y D N/A D N
and a description of operating and/or testing conditions for the control
devices?
(e) Identification of each process vent, wastewater POD, transfer rack, and D Y D N/A D N
storage tank (including those from other processes) that are
simultaneously routed to each control device and treatment process?
(f) A description of the monitoring requirements for each control device and D Y D N/A D N
treatment process, and each parametric level (i.e., operating limit) used to
demonstrate ongoing compliance?
(g) Calculations and engineering analyses required to demonstrate D Y D N/A D N
compliance (e.g., TRE calculations for continuous process vents)?
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72.0 Reporting
Table 12-1. (continued)
I. Review of Records
9. Has a responsible official of the affected source signed the report, certified its DY DN
accuracy, and attested to whether the source has complied with the
requirements in subpart FFFF? §63.9(h)(2)(i) introductory text
II. Note All Deficiencies
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72.0 Reporting
Table 12-2. Inspection Checklist for Compliance Reports
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the question is not applicable,
check the "N/A" box.
I. Review of Records
1. Do compliance reports include all of the following general information:
(a) Company name and address? §63.2520(e)(l) DY DN
(b) Date of the report? §63.2520(e) (3) DY DN
(c) Name, title, and signature by a responsible official of the company D Y D N
certifying the accuracy of the report? §63.2520(e)(2)
2. If excess emissions occurred (e.g., a daily average operating parameter
exceeded an operating limit) with any startup, shutdown, and/or malfunction
during a reporting period, does the compliance report for that period include
the following records: §63.2520(e)(4)
(a) That procedures in the facility's SSMP were followed, or documentation D Y D N/A D N
of actions taken that were inconsistent with the SSMP?
(b) A brief description of each malfunction? D Y D N/A D N
3. If there were no deviations from any emission limit, operating limit, or work D Y D N/A D N
practice standard during a reporting period, does the compliance report for
that period include a statement documenting the absence of any such
deviations? §63.2520(e)(5)(i)
4. If a reporting period included deviations from any emission limits, operating
limits, and/or work practice standards where ongoing compliance is not
demonstrated by using a CMS, does the compliance report for the period
include the following information: §63.2520(e)(5)(ii)
(a) The total operating time of the affected source during the reporting D Y D N/A D N
period?
(b) The total number of deviations? DY DN/A DN
(c) The total duration of deviations? DY DN/A DN
(d) The cause(s) of deviations (including unknown cause, if applicable)? D Y D N/A D N
(e) The corrective action(s) taken? D Y D N/A D N
(f) Operating logs for the day(s) during which the deviation occurred? D Y D N/A D N
Note: Operating logs are required only for processes with batch vents
from batch operations.
Note: Operating logs are not required for deviations of the work
practice standards for equipment leaks.
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72.0 Reporting
Table 12-2. (continued)
I. Review of Records
5. If a reporting period included any deviations from an emission limit or
operating limit where a CMS is used to demonstrate ongoing compliance,
does the compliance report for that period include the following information
for the days when the deviations occurred (e.g., daily average of the
monitored parameter does not meet the operating limit, or data availability
requirements are not met): §§63.2520(e)(5)(iii), 63.999(c)(6)(i), 63.146(d)
and(e), and 63.152(c) (2)
(a) Date and time each CMS was inoperative (except for zero [low-level] D Y D N/A D N
and high level checks)?
(b) For a CEMS, the date, time, and duration that the CEMS was out of D Y D N/A D N
control, and corrective actions taken?
(c) Date and time that each deviation started and stopped, and indication of D Y D N/A D N
whether the deviation occurred during a period of SSM?
(d) Identification of each HAP known to be in the emission stream? D Y D N/A D N
(e) Brief description of the CMS? DY DN/A DN
(f) Date of the most recent CMS certification or audit? DY DN/A DN
(g) Operating logs? DY D N/A DN
Note: Operating logs are required only for processes with batch vents
from batch operations.
(h) Operating day averages of the operating parameter (or pollutant D Y D N/A D N
concentration)?
(i) Summary statistics regarding the total duration, percent of operating DY D N/A DN
time, and causes for all deviations from emission limits and operating
limits, including information on the deviations from outlet concentration
limits under the alternative standard?
(j) Summary of the total duration of CMS downtime during the reporting DY D N/A DN
period, and calculation of the total duration as a percentage of the total
operating time for the affected source during the reporting period?
6. For Group 2 batch process vents based on HAP usage < 10,000 Ib/yr or HAP D Y D N/A D N
emissions < 1,000 Ib/yr, does the compliance report include records
associated with each calculation that exceeds either threshold?
§63.2520(e)(5)(iv)
1. For each CEMS that was never out of control during a reporting period, does D Y D N/A D N
the compliance report for that period include a statement documenting this
result? §63.2520(e)(6)
8. If a flare is used to comply with an emission limit in subpart FFFF, does the DY D N/A DN
compliance report include records of periods when all pilot flames were
absent or the flare flame was absent? §§63.999(c)(3) and 63.146(e)(l)
12-8
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72.0 Reporting
Table 12-2. (continued)
I. Review of Records
9. If a carbon adsorber is used to comply with an emission limit in subpart DY D N/A DN
FFFF, does the compliance report document all carbon bed regeneration
cycles during which a monitored parameter (e.g., regeneration stream flow or
carbon bed temperature) did not meet an applicable operating limit?
§§63.999(c)(6)(ii) and 63.146(e)(l)
10. If a closed-vent system is required to route emissions to a control device,
does the compliance report include the following information about the
closed-vent system: §§63.999(c)(2) and 63.148(j)
(a) The following records when a leak is detected:
• Identification information of the leaking closed-vent system? D Y D N/A D N
• Name, initials, or identification number of operator conducting the D Y D N/A D N
inspection?
• Instrument identification number, if instrument monitoring applies? D Y D N/A DN
Date the leak was detected? DY DN/A DN
Date of the first attempt to repair the leak? DY DN/A DN
• Maximum instrument reading after the leak is repaired or D Y D N/A D N
determined to be non-repairable?
• Explanation of delay in repair, if the leak was not repaired within DY D N/A DN
15 days after it was discovered?
• Name or initials of the person who decided repairs could not be D Y D N/A D N
made without a shutdown, expected date of successful repair if not
repaired within 15 days, and dates of shutdowns that occur while
the equipment remains unrepaired, if applicable?
Note: These records must be included only if the closed-vent
system is used to convey emissions from wastewater systems.
• Date of successful repair of the leak? D Y D N/A D N
(b) The times when a vent stream is diverted from the control device D Y D N/A D N
through a bypass line?
(c) The times when maintenance is performed on car-sealed valves, when D Y D N/A D N
the seal is broken, when the bypass line valve position is changed, or the
key for a lock-and-key type configuration has been checked out?
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72.0 Reporting
Table 12-2. (continued)
I. Review of Records
11. Does the compliance report include the following information for equipment
leaks:
(a) A summary of the following data for valves in gas and vapor service and
light liquid service, pumps in light liquid service, connectors in gas and
vapor service and light liquid service, agitators in gas and vapor service
and light liquid service, and compressors: §63.1039(b)(l)
Note: Information about connectors is not required for existing sources
that comply with §63.2480(b)(4) or (c)(4).
• Number of each type of component for which leaks were detected? D Y D N/A D N
• The percent leakers for valves, pumps, and connectors? D Y D N/A D N
• Total number of components monitored? D Y D N/A D N
• Number of leaking components that were not repaired? D Y D N/A D N
• The number of valves and connectors determined to be DY DN/A DN
nonrepairable?
(b) Documentation of the occurrence and number of times delay of repair DY D N/A DN
has been used? §63.1039(b)(2)
(c) The following records of any valve subgroups: §63.1039(b)(3)
The valves assigned to each subgroup? D Y D N/A D N
• Monitoring results and calculations made for each subgroup for D Y D N/A D N
each monitoring period?
• Identification of any valves that have been reassigned from one D Y D N/A D N
subgroup to another during the reporting period, and the date of
such reassignments?
• Results of the semiannual overall performance calculation? D Y D N/A D N
(d) For pressure relief devices and compressors operating with an D Y D N/A D N
instrument reading less than 500 ppm above background, results of all
monitoring conducted during the reporting period to show compliance?
§6 3.10 39 (b) (4)
(e) Documentation of the initiation of a monthly monitoring program for D Y D N/A D N
valves, if applicable? §63.1039(b) (5)
(f) Documentation of the initiation of a quality improvement program for D Y D N/A D N
pumps, if applicable? §63.1039(b) (6)
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Table 12-2. (continued)
I. Review of Records
(g) If compliance is demonstrated by pressure testing, records of the
following: §63.1039(b)(7)
• Process equipment train identification? D Y D N/A D N
• The number of pressure tests conducted? DY DN/A DN
• The number of pressure tests where the equipment train failed the DY D N/A DN
pressure test?
• Explanation for any delay of repair? D Y D N/A D N
12. If a floating roof is used to meet the emission limit for a storage tank, does
each compliance report include the following information:
(a) Records of inspection results when failures are identified (i.e., storage DY DN/A DN
tank identification, date of inspection, description of failure, description
of repairs and the dates they were made, and date storage tank is
removed from service, if applicable)? §63.1066(b)(2)
(b) Any request to use an alternate control device? §63.1066(b)(3) DY D N/A DN
13. If emissions from a storage tank are routed to a control device, does each
compliance report include all of the following information related to periods
of planned routine maintenance:
(a) All of the following records of periods of planned routine maintenance
during the reporting period: §63.999(c)(4)(i)
• The time of day and date when each period of planned routine DY DN/A DN
maintenance started?
• The time of day and date when each period of planned routine DY DN/A DN
maintenance ends?
• Description of the type of maintenance performed? D Y D N/A D N
(b) Total number of hours in the current and preceding reporting periods DY D N/A DN
when the control device was not operating in compliance with subpart
SS requirements due to planned routine maintenance? §63.999(c)(4)(ii)
(c) A description of the planned routine maintenance for the next reporting D Y D N/A D N
period (i.e., the type of maintenance to be performed, the expected
frequency of the maintenance, and the expected length of the
maintenance periods)? §63.999(c)(4)(iii)
14. For inspections of waste management units during which a control equipment
failure was detected, does the compliance report include records of the
following information: §63.146(c)
(a) Date of inspection?
(b) Identification of each waste management unit in which a control
equipment failure was detected?
D Y D N/A D N
D Y D N/A D N
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Table 12-2. (continued)
I. Review of Records
15.
(c)
(d)
(e)
Description of the
Description of the
Date of repair?
failure?
nature of the repair?
If process wastewater is sent offsite for treatment, do compliance report;
D
D
D
3 D
Y
Y
Y
Y
D
D
D
D
N/A
N/A
N/A
N/A
D
D
D
D
N
N
N
N
document the identity of new treatment facilities or transferees for the
wastewater, if any, during the reporting period? §63.152(c)(4)(iv)
16. If a floating roof is used to meet a requirement for wastewater tanks, does D Y D N/A D N
each compliance report include any requests for extensions to conduct
inspections of the floating roof or for an extension for repair if repair could
not be completed or the vessel emptied within 45 days after a failed
inspection? §63.146(g)
17. Do compliance reports include a copy of each new operating scenario DY DN/A DN
(including revisions to existing operating scenarios) operated during the
reporting period? §63.2520(e)(7)
18. If repair of a leaking heating exchange system has been delayed, is all of the
following information included in all compliance reports until the leak is
repaired: §63.104(f)(2)
(a) Identification of the leak? DY DN/A DN
(b) Date the leak was detected? DY DN/A DN
(c) Whether or not the leak has been repaired? DY DN/A DN
(d) Reason(s) for the delay of repair? DY DN/A DN
(e) Documentation of emissions estimates, if repair was delayed because D Y D N/A D N
emissions from shutdown could be greater than emissions likely to result
from delaying repair?
(f) Either the expected date of repair (if the leak remains unrepaired) or the D Y D N/A D N
date the leak was successfully repaired?
19. If any process units were added to a process unit group during the reporting
period, does the compliance report for that period include the following
records for the added process units: §63.2520(e)(8)
(a) Description of the process unit(s)? DY D N/A DN
(b) Rationale for including the additional process unit(s) in the process unit D Y D N/A D N
group?
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Table 12-2. (continued)
I. Review of Records
20. Does the compliance report document any changes to information originally D Y D N/A D N
reported in the notification of compliance status report or previous
compliance reports (i.e., changes that are not within the scope of operating
scenarios)? §§63.2520(e)(10) and 63.1039(b)(8)
Note: Advance notification is required for 3 types of planned changes: any
change in information submitted in the precompliance report, a change in
status of a control device from small to large, and a change from Group 2 to
Group 1 for any emission point (except batch process vents that have been
Group 2 for at least one year).
II. Note All Deficiencies
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Appendix A
Questions and Answers on Provisions in Subpart FFFF
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Appendix A
Applicability
QA1. Does the replacement and/or debottlenecking of process equipment in an existing
miscellaneous chemical manufacturing process unit (MCPU) make the MCPU a reconstructed
facility subject to new source standards?
AA1. Yes, under certain conditions. A new affected source can be created through either the
construction or reconstruction of an affected source (the facility-wide collection of MCPU and
heat exchange systems, wastewater, and waste management units that are associated with
manufacturing miscellaneous organic chemicals) or a dedicated MCPU. (See section
63.2440(c)). "Construction", as defined in section 63.2550, applies to the on-site fabrication,
erection, or installation of an affected source or MCPU. Since the MCPU described is existing,
the only way the facility would have a new affected source after implementing the changes is if
the changes satisfy the criteria in the definition of reconstruction (i.e., the capital cost of the
replaced equipment exceeds 50% of the capital cost of a comparable new source of either a
dedicated MCPU (one with a PTE of at least 10/25 tpy) or an affected source. In the case of the
reconstruction of a dedicated MCPU, the changes could constitute reconstruction for the
dedicated MCPU alone so that it becomes a new affected source, while the collection of all of
the other MCPU's at the facility are still an existing affected source. Debottlenecking of a
process with no replacement of equipment would not trigger new source requirements.
QA2. A process unit which produces an North American Industry Classification System
(NAICS) 325 organic chemical is located at a major source under 40 CFR part 63 and includes
facilities affected by other MACT standards. The process unit does not process, use or produce a
HAP. Is this process unit an subject to the Miscellaneous Organic National Emission Standards
for Hazardous Air Pollutants (MON)? If so, what are compliance requirements?
AA2. No. The MCPU is not subject to the MON (subpart FFFF). Section 63.2435(b)(2)
specifies that an MCPU must "process, use, or produce" a hazardous air pollutant (HAP) for it to
be subject to subpart FFFF.
QA3. The statutory definition of "Research & Development (R&D) facility" is somewhat
general. How can a facility justify that a pilot system qualifies as an R&D facility?
AA3. The rule doesn't address pilot scale operations specifically, but it would have to meet the
statutory definition for R&D (see section 112(c)(7) of the CAA) to meet the exemption at section
63.2345(c)(l). A facility wishing a determination of applicability should submit a formal
request in writing to their delegated authority.
QA4. A plant uses hydrochloric acid to regenerate ion exchange (I-X) resin which is not
associated with any MON process. From the definition of ancillary, the I-X system would
appear to be an "ancillary" activity. Would the hydrochloric acid (HC1) storage tank also be
included with the I-X ancillary activity and exempt from MON requirements?
AA4. An ancillary activity determination would be made only for a MON process. Thus, the
ion exchange system as described in the question are exempt from the MON because the process
it is associated with is not a MON process. On the other hand, if it were a MON process, then
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Appendix A
the ion exchange system would be an ancillary activity that is exempt from the MON. In either
case, applicability for the HC1 storage tank would depend on the predominant use of the HC1, as
detailed in section 63.2435(d). For example, if the HC1 were used only in the ion exchange
system, then the storage tank would be part of the ancillary activity and exempt from the MON.
Alternatively, if some of the HC1 is used in the process, then the predominant use will determine
whether the storage tank is part of the MCPU or exempt.
QA5. What is the difference between primary product determinations in the Hazardous Organic
National Emission Standards for Hazardous Air Pollutants (HON) rule versus the MON rule?
AA5. The HON uses a primary product determination to identify process units that are subject
to the HON (i.e., all processes operated in equipment for which the primary product is a material
listed in Table 1 to subpart F). The MON, on the other hand, does not use a primary product
determination to establish process applicability because the MON applies to processes that
produce materials that meet the criteria specified in section 63.2435(b) whenever such materials
are produced; the production of other materials in the same equipment, or different
configurations of the equipment, at other times has no bearing on the applicability determination
(and the MON does not apply to the production of these other materials). However, a primary
product determination is included in the MON as part of an option for minimizing the burden of
complying with overlapping standards for non-dedicated (multipurpose) equipment. This
"process unit group" option in section 63.2535(1) allows an owner or operator to determine the
primary product for a collection of non-dedicated equipment; typically, the owner or operator
may then comply with the NESHAP that applies to that material at all times, regardless of what
process the equipment is configured to produce.
QA6. Two reactors that share no equipment. One is used to make methyl esters only. The other
is used to make esters, a small percentage of which is methyl ester. Are the two reactor trains
part of the same process?
AA6. When similar products are produced, the manufacturer must evaluate information on each
product to determine if any of them are part of a family of materials (FOM) as defined in section
63.2550(i). The question does not indicate how many different esters (including methyl esters)
are produced, and it does not provide enough information to determine if any of the esters are
part of the same FOM. Thus, we can provide only a general response that may not address all
possible scenarios. One extreme is if all of the esters, including methyl esters, are part of the
same FOM. In this case, production of all of the esters is considered to be a single MCPU (i.e.,
both reactor trains always are part of the same MCPU). The other extreme would be if none of
the esters form a FOM. For this scenario, because the MON is a process-based standard rather
than an equipment-based standard, production of each ester would constitute a separate MCPU.
This means the MCPU for a particular ester exists whenever that ester is being produced in any
equipment (i.e., both reactor trains could be part of the same MCPU from time to time, but only
if they are both used to produce the same ester). Between these two extremes are potentially
numerous scenarios where various esters are part of a FOM and others are not. Since one reactor
train is dedicated to the production of methyl esters, the two reactor trains would be part of the
same MCPU only under conditions similar to those described for the two extremes (i.e., for each
FOM that uses both reactors, or for any individual methyl ester that is not part of a FOM and is
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Appendix A
produced using both reactors). Finally, note that if any of the ester production processes do not
use, produce, or process HAP, then the MON would not apply during production of those esters.
QA7. Does a non-dedicated unit that is subject to Subpart JJJ and for which no controls are
required need to be evaluated under MON?
AA7. No, there cannot be an affected source subject to both rules at the same time. If the
process unit is designated as a TPPU under subpart JJJ, then it is not subject to subpart FFFF,
even when making products other than thermoplastics, unless the primary product determination
changes and it is no longer subject to subpart JJJ.
Process vents
QPV1. What is the averaging period for demonstrating on-going compliance with the
alternative standard for vents?
APV1. Section 63.2505(b)(7) specifies that compliance with the alternative standard is based on
daily averages.
QPV2. If performance tests are conducted and show compliance with 20-ppmv limit, must a
CEMS be installed or can compliance be demonstrated with surrogate parameter monitoring?
APV2. Parameter monitoring is allowed if complying with the procedures specified in sections
63.2450 through 63.2470 and Tables 1 through 4. For example, one of the emission limit
options specified in Table 1 is a 20 ppmv outlet concentration limit. Section 63.2450(d)
specifies that if you reduce emissions by venting emissions through a closed-vent system to a
control device (to comply with emission limit in table 1), then you must meet the requirements in
section 63.982(c). This section then refers you to other sections in subpart SS, including
parameter monitoring requirements in 63.988(c) for combustion control devices. Alternatively,
section 63.2505, the "alternative standard", is a method of compliance which specifies a 20
ppmv outlet concentration limit (for combustion devices) for which compliance must be
demonstrated by using CEMS.
QPV3. For MCPUs with both batch and continuous process vents, if the batch and continuous
vents are not manifolded together, is the total resource effectiveness (TRE) applied to the
continuous vent and the 10,000 Ib/yr exemption applied separately to the batch vents?
APV3. Yes, that is correct. Additionally, even if the streams are manifolded together, the Group
status of the vents must be determined independently, but the owner/operator may use the
hierarchy for combined streams at section 63.2450(c) for determining the applicable
requirements.
QPV4. How are streams that are unsafe to meet required control addressed under the rule? For
example, a high hydrogen-containing stream which cannot be combusted?
APV4. The rule has provisions at 63.2450(q) for a narrowly defined a class of energetics and
organic peroxides producers and allows, on a case-specific basis, a procedure to request an
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Appendix A
alternative compliance option. For these materials, the owner or operator must prepare and
submit documentation in the precompliance report explaining why an undue safety hazard would
be created if the air emission controls specified in 40 CFR part 63, subpart FFFF, were installed
on process vents, wastewater, and storage tanks containing energetics and organic peroxides, and
describing what practices would be implemented to minimize HAP emissions. The rule does not
currently have procedures for other classes of compounds which may cause a safety issue.
QPV5. Is a non-dedicated process vent subject to Polymers and Resins (P&R) IV Maximum
Achievable Control Technology (MACT) standard also subject to the MON? Does the TRE
have to be recalculated under MON if the primary product is a P&R IV process?
APV5. No, there cannot be an affected source subject to both rules at the same time. If the
process unit is designated as a thermoplastic product process (TPPU) under subpart JJJ, then it is
not subject to subpart FFFF, even when making products other than thermoplastics, unless the
primary product determination changes and it is no longer subject to subpart JJJ.
QPV6. Within a HON regulated CMPU, there is a periodic "unit operation" in which carbon
beds are regenerated to drive off HAP. This practice results in a non-continuous vent to the
control device (CVS furnace-scrubber). Uncontrolled HAP emissions are >200 Ib/yr. Is this a
MON regulated batch process vent? Right now, we can control this vent under our state's air
toxics rule.
APV6. If the carbon beds are used as control devices to meet requirements in the HON, then
they are not subject to the MON. However, if the carbon beds are used within the process (e.g.,
to purify a product), then they would be batch operations with batch process vents that are
subject to the MON.
QPV7. Within a MON regulated MCPU there is a maintenance knock out drum. The drum is
used to collect solvent (HAP) that is flushed through equipment prior to opening for maintenance.
The drum bottoms are either routed back to the reactor as a feedstock, or sent off-site for disposal.
What is the correct classification of this drum? Is it a surge control vessel when the material is
sent back to the process and a process tank when material is sent for offsite disposal? Assuming
the gas stream off of the drum is considered a batch process vent and is the only batch vent in the
process, if its uncontrolled emissions are < 10,000 Ib/yr and it is manifolded with a Group 1
continuous process vent, do I comply with the provision for continuous halogenated PV's in the
hierarchy at section 63.2450(c)(2)(ii)?
APV7. The solvent flush and collection of spent solvent in the knock out drum is a cleaning
operation that meets the definition of "shutdown" because this activity is conducted only when
ceasing continuous operations, in this case to perform maintenance. Thus, the owner or operator
should comply with the requirements for startup, shutdown, and malfunction for this activity as
specified in sections 63.8(e), 63.998(d)(3) and (c)(l)(ii)(D), and 63.2520(d)(4) and (5). For
example, procedures for this activity should be described in the facility's startup, shutdown, and
malfunction plan (SSMP). Since the shutdown activity involves more than just the knock out
drum, the SSMP should address procedures for operating and maintaining the process equipment
to minimize emissions during the cleaning activity in addition to procedures for the knockout
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Appendix A
drum. The ultimate disposition of both layers from the knock out drum do not affect the
requirements, except that they must be described in the SSMP.
QPV8. A MON MCPU and several HON chemical manufacturing process units (CMPU's) share
a common control device. A HON performance test was performed in 1998. The MON MCPU
was constructed in 2001, after the performance test. Can the facility use the HON test for the
MON compliance demonstration?
APV8. Section 63.997 of subpart SS governs the use of prior test results. The owner or operator
should request permission to substitute a prior test by written application to the Administrator as
specified in 63.999(a)(l)(iv). For MON batch process vents, requirements of section
63.1257(b)(8) must be met.
Wastewater
QWW1. Is the HAP content in hydrocarbon included in the determination of wastewater (WW)
characteristics, or are hydrocarbons presumed to be removed by the recovery device?
AWW1. HAPs in all phases of wastewater, not just aqueous phase, must be included in the
Group determination.
QWW2. Can a recovery device (to remove hydrocarbons) be physically located downstream at
the wastewater treatment plant (WWTP), or does it have to be at the process area?
AWW2. A recovery device may be located at the WWTP
QWW3. Can hydrocarbon recovered in a WW stream stripper be returned to the process, or does
it have to be destroyed?
AWW3. Recovered chemicals may be returned to the process.
QWW4. A MON plant routes its wastewater to the wastewater treatment system of an adjacent
paper mill (owned by the same company).
• Does the paper mill need to submit an initial notification that it will be
receiving/treating MON wastewater?
• Is the paper mill considered an "off-site treater"?
AWW4. "Major source means any ...group of stationary sources located within a contiguous area
under common control ..." Therefore, the paper mill would be part of the source and not an off-
site treater.
QWW5. In determining the "annual average flow rate" for a wastewater stream from batch
operations, do you always assume 8760 hours/year operation, or do you divide by total hours of
batch activity?
AWW5. Assume 8760 hr/yr, as in the HON.
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Appendix A
QWW6. What are the requirements for wastewater going to a RCRA incinerator?
AWW6. Wastewater going to RCRA units is covered by the rule as a compliance option. The
rule lets you send the wastewater either offsite or onsite to a RCRA unit. If it goes offsite to a
RCRA incinerator, section 63.2485(i)(l) allows you to document in the notification of
compliance status report that the wastewater will be treated as hazardous waste at an offsite
facility that meets the requirements of section 63.138(h) and waives the requirement for the
offsite treater to submit certification. Note that the notice required by section 63.132(g)(l)(ii),
that must accompany each shipment, has not been overridden, and that the stringency
determination requirements of section 63.2535(g) must still be performed and documented in the
notification of compliance status report.
Equipment leaks
QEL1. Does the leak detection method for disturbed equipment have to be Method 21 or can the
equipment be visual or vacuum tested?
AEL1. When complying with the requirements of subpart UU as specified in Table 6 to subpart
FFFF, there is the option of complying with the pressure/vacuum testing alternative means of
emission limitation in section 63.1036(b), rather than monitoring each component. Section
63.2480(c) specifies that no testing is required when flexible hose connections are the only
disturbed equipment in an equipment train. Whenever any other components are disturbed, a test
must be conducted as specified in 63.1036(b). Neither Method 21 or visual monitoring is part of
this option.
QEL2. Are pressure relief devices (PRDs) on storage tanks subject to leak detection and repair
(LDAR) under the MON? Are they considered to be in gas service? Is vacuum testing only
allowed in subpart UU?
AEL2. LDAR programs don't apply to PRDs which are conservation vents on storage tanks.
However, for a Group 1 storage tank, PRDs could be part of the closed vent system (CVS) to a
control device and, therefore, would be subject to the requirements for CVS as specified in
section 63.983 of subpart SS. A PRD that is part of a CVS on a Group 2 storage tank is not
subject to CVS requirements. Subpart TT does not have provisions for vacuum testing as an
alternative means of emission limitation.
QEL3. A process was originally subject to subpart I of the HON for methylene chloride at a
PHARMA Plant. The process is now subject to the PHARMA MACT and its LDAR
requirements, but has an approved P2 compliance plan. Is the PMPU subject to any LDAR under
the MON?
AEL3. The PMPU is still part of the pharmaceuticals production affected source that is subject to
subpart GGG. Thus, it is not subject to subpart FFFF. Furthermore, if the source is in
compliance with the P2 alternative in subpart GGG, and the P2 alternative includes equipment in
the PMPU subject to the LDAR requirements for GGG, then no LDAR is required for that
equipment which is part of the P2 plan.
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Appendix A
QEL4. If a major source has equipment that is subject to subpart I ( which requires compliance
through subpart H), and now has a MON affected source, can the source opt to comply only with
Subpart H of the HON for all the equipment?
AEL4. Yes, section 63.2535(d) specifies that if you have an affected source (i.e., a MON
affected source) and you also have equipment (anywhere at the major source) that is subject to
subpart I, then you may elect to comply with the requirements of subpart H for all of the
equipment.
QEL5. How does one determine the monitoring frequency for nondedicated equipment that is
used to produce multiple products, some of which may use volatile organic HAP (VOHAP) and
some of which may not? For example, some of the equipment components are in (VOHAP)
service a few months and then empty. Some are in VOHAP service then in non-VOHAP service.
AEL5. MON LDAR requirements are in effect for the components anytime they are in VOHAP
service. Subpart UU has alternative provisions in section 63.1036(c)(3)(iv) to simplify equipment
monitoring for batch processes based on the proportion of the year the batch product process that
is subject to the provisions of subpart UU are operating. If the source elects not to use the batch
monitoring frequencies in Table 1 per section 63.1036, then the component should be monitored
at the appropriate frequency per the requirements of sections 63.1025 through 63.1034. If the
component is not in VOHAP service during the scheduled monitoring period, then the monitoring
would be done during the next period when the equipment is in VOHAP service.
QEL6. Is valve position monitoring an acceptable means to flow monitor a bypass valve? Does
the 5% minimum HAP concentration limit apply to CVS monitoring?
AEL6. Subpart FFFF references CVS requirements in subparts SS and G. Sections
63.983(a)(3)(i) in subpart SS and 63.148(f)(l) in subpart G specify that bypass monitoring may be
accomplished by using a flow indicator at the entrance to the bypass line. According to the
definition of flow indicator in sections 63.981 and 63.111, the valve position may be used to
determine whether gas flow could be present in a line. Also, neither subpart FFFF nor the
referenced CVS provisions in sections 63.983 and 63.148 specify a minimum HAP concentration
level below which CVS monitoring is not required.
QEL7. Can historical quarterly monitoring data showing <2% leak rate for valves be used to
begin skip monitoring for MON? Or must the historical data be monthly?
AEL7. According to section 63.1025(b)(3)(ii), monitoring data collected both before a source
becomes subject to subpart FFFF and in accordance with the criteria specified in sections
63.1023(b)(l) through (5) or in section 63.1023(b)(6) may be used to qualify initially for less
frequent monitoring. Thus, historical quarterly monitoring data obtained using the specified
methods and showing that <2 percent of the valves are leaking may be used to qualify for skip
monitoring at the appropriate frequency specified in sections 63.1026(b)(3)(ii) through (v). For
example, if historical quarterly data show the percent leakers are between 1 and 2 percent, then
the owner or operator may continue with quarterly monitoring after the compliance date. Note
that the percent leakers determination must be based on an average from at least two sets of data
in accordance with section 63.1025(c)(2).
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Appendix A
QEL8. In the Organic Liquid Distribution (OLD) MACT if controls are not required for loading
racks and storage tanks, then LDAR is not required. Why doesn't the MON have this OLD
provision?
AEL8. The MON is a different source category with a different MACT floor determination.
Heat exchangers
QHE1. Does monthly monitoring of heat exchange/cooling towers need to begin on/after the
compliance date or can it start early?
AHE1. Nothing in the regulation precludes the facility from early compliance with the standards.
QHE2. Does the inlet and outlet of each heat exchanger need to be tested or can groups of heat
exchangers be tested? From a cooling tower, can the inlet concentration to all of the heat
exchangers be tested once?
AHE2. Table 10 to subpart FFFF specifies that heat exchangers must comply with the
requirements of section 63.104 for each heat exchange system. The introductory paragraph in
section 63.104(b) specifies that the sample may be taken "at either the entrance and exit of each
heat exchange system or at locations where the cooling water enters and exits each heat
exchanger or any combination of heat exchangers." For a recirculating system, if the owner or
operator elects to sample over the entire system, section 63.104(b)(l) specifies that the entrance is
the point at which the cooling water leaves the cooling tower prior to being returned to the
process equipment.
General requirements, recordkeeping, and reporting
QG1. There are specific requirements for hydrogen halide and halogen HAP (FTP, HC1, C12) for
process vents, but what are the requirements, if any, for these 3 HAPs in storage tanks, equipment
leaks, and/or waste water? If there are requirements, what test methods would be used to
determine compliance?
AG1. Storage tank requirements make no distinction between organic HAPs and other HAPs (the
maximum true vapor pressure must be determined for the HAP that are stored). Table 6 to
subpart FFFF specifies that equipment leak requirements apply only to equipment that is in
organic HAP service; organic HAP does not include hydrogen halide and halogen HAP. Section
63.2485(c) and Tables 8 and 9 to subpart FFFF specify which HAP are subject to wastewater
requirements; hydrogen halide and halogen HAP are not included. In addition, note that all
emission types are subject to requirements if the HAP are halogenated (i.e., contain organic
compounds where the halogen atom content exceeds 0.45 kg/hr), and some of these requirements
may be the same as for hydrogen halide and halogen HAP.
QG2. Is continuous monitoring system (CMS) equal to continuous parametric monitoring system
(CPMS) in compliance report requirements? What are the requirements for continuous emissions
monitoring systems (CEMS)?
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Appendix A
AG2. According to section 63.2 of the General Provisions to 40 CFR part 63, CEMS and CPMS
are different types of CMS. Table 12 to subpart FFFF specifies that CMS requirements in the
General Provisions apply only to CEMS, whereas requirements for CPMS are specified in
subparts G and SS. Additional requirements for CEMS are specified in section 63.2450(j) of
subpart FFFF. Finally, the compliance reporting requirements in section 63.2520(e)(5)(iii) for
deviations when a CMS is used to comply with an emission limit apply to both CPMS and
CEMS, except for some information that is required only for CEMS (e.g., information about the
date, time, and duration of out of control periods is required only for CEMS).
QG3. What is an example of an operating scenario? Would changing to a different product in
the same equipment constitute a different operating scenario?
AG3. An operating scenario includes the information listed at section 63.2525(b), and the
operating scenario for each MCPU is unique because it includes information specific to the
product or family of materials that defines the MCPU, even if the equipment is the same as for
another MCPU. Thus, changing to a different product that is not part of the same family of
materials always means a different operating scenario is now applicable. Additionally, an owner
or operator may opt to have multiple operating scenarios for a single product, or family of
materials, in order to have the operational flexibility to employ differing compliance strategies.
QG4. If you have a Group 2 emission point that could exceed the Group 1 thresholds during an
SSM event, are they required to be included in the startup, shutdown, and malfunction plan
(SSMP)? If no, is it recommended? Can the owner/operator (o/o) choose to include them? How
must they be reported?
AG4. Per 63.2525(j), Group 2 streams do not need to be addressed in the SSMP, even if they
exceed the Group 1 threshold during an startup, shutdown, and malfunction (SSM) event. There
is no requirement to report SSM of Group 2 emission streams. The o/o may choose to include
Group 2 emission points in the SSMP at their discretion.
QG5. How do the definitions of batch startup and shutdown apply to batch processes. The rule
states that the startup of a campaign under normal procedures (i.e., steps) is NOT a startup as
defined in the rule.
AG5. That is correct. Routine operations are not considered startup or shutdown. The beginning
of a campaign after maintenance or after switching to a product that has been produced in the past
are considered to be routine. We consider between batches, ending a campaign, or ending a batch
for planned, preventative maintenance to be routine. These routine operations include both
standard and nonstandard batches. A nonstandard batch is a reasonably anticipated variation of
the standard MCPU. For example, an additional purification step necessary to meet quality
assurance may constitute a nonstandard batch for which additional emissions may need to be
calculated. If the steps taken to put a particular batch into operation or to cease operation differ
from those specified in a standard batch or nonstandard batch (i.e., are not routine), then the event
would be startup or shutdown as specified in the definitions for these terms in section 63.2550(i).
QG6. Is data compression allowed under MON?
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Appendix A
AG6. The MON refers to recordkeeping requirements in subparts SS and G. Data compression
is allowed for data that meet the requirements specified in sections 63.998(b)(l), (3)(ii), (5)(i),
and (5)(ii) of subpart SS and sections 63.152(f) and (g) of subpart G.
QG7. The only MON requirement for pressure release vents (PRVs) is under LDAR. For a
malfunction resulting in the lifting of a PRV, is it correct to consider that excess emissions occur
only if the LDAR requirement is not met (i.e., not monitored for <500 ppm leakage within 5 days
after the release)?
AG7. If the o/o does not re-monitor and record the results of the monitoring after the PRV lifted,
that would be a deviation of the LDAR requirements in section 63.1011(c) or section 63.1030(c).
The term excess emissions applies to the SSM of process operations, i.e., the PRV lifting,
according to 63.998(d)(3), as well as the SSM of the CVS or CD according to 63.998(c)(l)(ii)(D)-
(G).
QG8. Can a source submit more than one precompliance report to address issues that arise after
the initial submittal?
AG8. Additional reports may be submitted up to the date the precompliance report is due. After
the compliance date of rule, section 63.2520(e)(10)(ii) contains the provisions for submitting
items which require preapproval (submit 60 days before the change). The rule does not currently
address the situation where something comes up in between the 6 month period after submittal of
the precompliance report and prior to the compliance date.
QG9. Must monitoring and recordkeeping continue during periods of non-operation of process
equipment (e.g., seasonal shutdown)?
AG9. Section 63.998(b)(2)(ii) specifies that any data collected during "periods of non-operation
of the process unit (or portion thereof), resulting in cessation of the emissions to which the
monitoring applies" are to be excluded from averages used to determine compliance.
QG10. The MON references subpart SS for flare requirements. Is there a deviation if there is a
data point for a steam or air-assisted flare where the net heating value of the gas being combusted
is <300 BTU/scf, but the hourly average is >300 BTU/scf?.
AGIO. The MON requires owners or operators using a flare to control batch or continuous vents
to meet the requirements for flares in 40 CFR 63.987, which reference section 63.1 l(b) of the
General Provisions for flare performance requirements. The 300 Btu/scf is the performance
criteria established for initial compliance, not an on-going parametric monitoring requirement.
The on-going parametric monitoring requirements for flares is found at section 63.987(c) and
include the detection of the pilot or flare flame.
QG11. The rule requires data during SSM venting to be included in the daily averages.
However, section 63.2450(a) says that the o/o must be in compliance with emission limits except
during periods of SSM. This does not seem to agree with the requirement to include SSM events
in the daily averages.
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Appendix A
AG11. The o/o has to include data collected during the SSM event to know whether or not
excess emissions occurred during the SSM event. Section 63.998(c)(l)(ii)(E) and (d)(3) of
subpart SS require records of each SSM event during which excess emissions occur.
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Appendix B
Definitions in Subpart FFFF
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Appendix B
Ancillary activities means boilers and incinerators (not used to comply with the emission limits in
Tables 1 through 7 to this subpart), chillers and refrigeration systems, and other equipment and activities
that are not directly involved (i.e., they operate within a closed system and materials are not combined
with process fluids) in the processing of raw materials or the manufacturing of a product or isolated
intermediate.
Batch operation means a noncontinuous operation involving intermittent or discontinuous feed
into equipment, and, in general, involves the emptying of the equipment after the operation ceases and
prior to beginning a new operation. Addition of raw material and withdrawal of product do not occur
simultaneously in a batch operation.
Batch process vent means a vent from a unit operation or vents from multiple unit operations
within a process that are manifolded together into a common header, through which a HAP-containing
gas stream is, or has the potential to be, released to the atmosphere. Examples of batch process vents
include, but are not limited to, vents on condensers used for product recovery, reactors, filters,
centrifuges, and process tanks. The following are not batch process vents for the purposes of this subpart:
(1) Continuous process vents;
(2) Bottoms receivers;
(3) Surge control vessels;
(4) Gaseous streams routed to a fuel gas system(s);
(5) Vents on storage tanks, wastewater emission sources, or pieces of equipment subject to the
emission limits and work practice standards in Tables 4, 6, and 7 to this subpart;
(6) Drums, pails, and totes;
(7) Flexible elephant trunk systems that draw ambient air (i.e., the system is not ducted, piped, or
otherwise connected to the unit operations) away from operators when vessels are opened; and
(8) Emission streams from emission episodes that are undiluted and uncontrolled containing less
than 50 ppmv HAP are not part of any batch process vent. A vent from a unit operation, or a vent from
multiple unit operations that are manifolded together, from which total uncontrolled HAP emissions are
less than 200 Ib/yr is not a batch process vent; emissions for all emission episodes associated with the unit
operation(s) must be included in the determination of the total mass emitted. The HAP concentration or
mass emission rate may be determined using any of the following: process knowledge that no HAP are
present in the emission stream; an engineering assessment as discussed in §63.1257(d)(2)(ii), except that
you do not need to demonstrate that the equations in §63.1257(d)(2)(i) do not apply, and the
precompliance reporting requirements specified in §63.1257(d)(2)(ii)(E) do not apply for the purposes of
this demonstration; equations specified in §63.1257(d)(2)(i), as applicable; test data using Method 18 of
40 CFR part 60, appendix A; or any other test method that has been validated according to the procedures
in Method 301 of appendix A of this part.
Biofilter means an enclosed control system such as a tank or series of tanks with a fixed roof that
contact emissions with a solid media (such as bark) and use microbiological activity to transform organic
pollutants in a process vent stream to innocuous compounds such as carbon dioxide, water, and inorganic
salts. Wastewater treatment processes such as aeration lagoons or activated sludge systems are not
considered to be biofilters.
Bottoms receiver means a tank that collects bottoms from continuous distillation before the
stream is sent for storage or for further downstream processing.
Construction means the onsite fabrication, erection, or installation of an affected source or
MCPU. Addition of new equipment to an MCPU subject to existing source standards does not constitute
construction, but it may constitute reconstruction of the affected source or MCPU if it satisfies the
definition of reconstruction in §63.2.
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Appendix B
Consumption means the quantity of all HAP raw materials entering a process in excess of the
theoretical amount used as reactant, assuming 100 percent stoichiometric conversion. The raw materials
include reactants, solvents, and any other additives. If a HAP is generated in the process as well as added
as a raw material, consumption includes the quantity generated in the process.
Continuous operation means any operation that is not a batch operation.
Continuous process vent means the point of discharge to the atmosphere (or the point of entry
into a control device, if any) of a gas stream if the gas stream has the characteristics specified in
§63.107(b) through (h), or meets the criteria specified in §63.107(i), except:
(1) The reference in §63.107(e) to a chemical manufacturing process unit that meets the criteria of
§63.100(b) means an MCPU that meets the criteria of §63.2435(b);
(2) The reference in §63.107(h)(4) to §63.113 means Table 1 to this subpart;
(3) The references in §63.107(h)(7) to §§63.119 and 63.126 mean Tables 4 and 5 to this subpart;
and
(4) For the purposes of §63.2455, all references to the characteristics of a process vent (e.g.,
flowrate, total HAP concentration, or TRE index value) mean the characteristics of the gas stream.
(5) The reference to "total organic HAP" in §63.107(d) means "total HAP" for the purposes of
this subpart FFFF.
(6) The references to an "air oxidation reactor, distillation unit, or reactor" in §63.107 mean any
continuous operation for the purposes of this subpart.
(7) A separate determination is required for the emissions from each MCPU, even if emission
streams from two or more MCPU are combined prior to discharge to the atmosphere or to a control
device.
Dedicated MCPU means an MCPU that consists of equipment that is used exclusively for one
process, except that storage tanks assigned to the process according to the procedures in §63.2435(d) also
may be shared by other processes.
Deviation means any instance in which an affected source subject to this subpart, or an owner or
operator of such a source:
(1) Fails to meet any requirement or obligation established by this subpart including, but not
limited to, any emission limit, operating limit, or work practice standard; or
(2) Fails to meet any term or condition that is adopted to implement an applicable requirement in
this subpart and that is included in the operating permit for any affected source required to obtain such a
permit; or
(3) Fails to meet any emission limit, operating limit, or work practice standard in this subpart
during startup, shutdown, or malfunction, regardless of whether or not such failure is permitted by this
subpart.
Emission point means each continuous process vent, batch process vent, storage tank, transfer
rack, and wastewater stream.
Energetics means propellants, explosives, and pyrotechnics and include materials listed at 49
CFR 172.101 as Hazard Class I Hazardous Materials, Divisions 1.1 through 1.6.
Equipment means each pump, compressor, agitator, pressure relief device, sampling connection
system, open-ended valve or line, valve, connector, and instrumentation system in organic HAP service;
and any control devices or systems used to comply with Table 6 to this subpart.
Excess emissions means emissions greater than those allowed by the emission limit.
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Appendix B
Family of materials means a grouping of materials with the same basic composition or the same
basic end use or functionality produced using the same basic feedstocks with essentially identical HAP
emission profiles (primary constituent and relative magnitude on a pound per product basis) and
manufacturing equipment configuration. Examples of families of materials include multiple grades of the
same product or different variations of a product (e.g., blue, black, and red resins).
Group 1 batch process vent means each of the batch process vents in a process for which the
collective uncontrolled organic HAP emissions from all of the batch process vents are greater than or
equal to 10,000 Ib/yr at an existing source or greater than or equal to 3,000 Ib/yr at a new source.
Group 2 batch process vent means each batch process vent that does not meet the definition of
Group 1 batch process vent.
Group 1 continuous process vent means a continuous process vent for which the flow rate is
greater than or equal to 0.005 standard cubic meter per minute, and the total resource effectiveness index
value, calculated according to §63.2455(b), is less than or equal to 1.9 at an existing source and less than
or equal to 5.0 at a new source.
Group 2 continuous process vent means a continuous process vent that does not meet the
definition of a Group 1 continuous process vent.
Group 1 storage tank means a storage tank with a capacity greater than or equal to 10,000 gal
storing material that has a maximum true vapor pressure of total HAP greater than or equal to 6.9
kilopascals at an existing source or greater than or equal to 0.69 kilopascals at a new source.
Group 2 storage tank means a storage tank that does not meet the definition of a Group 1 storage
tank.
Group 1 transfer rack means a transfer rack that loads more than 0.65 million liters/year of liquids
that contain organic HAP with a rack-weighted average partial pressure, as defined in §63.111, greater
than or equal to 1.5 pound per square inch absolute.
Group 2 transfer rack means a transfer rack that does not meet the definition of a Group 1 transfer
rack.
Group 1 wastewater stream means a wastewater stream consisting of process wastewater at an
existing or new source that meets the criteria for Group 1 status in §63.2485(c) for compounds in Tables 8
and 9 to this subpart and/or a wastewater stream consisting of process wastewater at a new source that
meets the criteria for Group 1 status in §63.132(d) for compounds in Table 8 to subpart G of this part 63.
Group 2 wastewater stream means any process wastewater stream that does not meet the
definition of a Group 1 wastewater stream.
Halogen atoms mean chlorine and fluorine.
HAP metals means the metal portion of antimony compounds, arsenic compounds, beryllium
compounds, cadmium compounds, chromium compounds, cobalt compounds, lead compounds,
manganese compounds, mercury compounds, nickel compounds, and selenium compounds.
Halogenated vent stream means a vent stream determined to have a mass emission rate of halogen
atoms contained in organic compounds of 0.45 kilograms per hour or greater determined by the
procedures presented in §63.115(d)(2)(v).
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Appendix B
Hydrogen halide and halogen HAP means hydrogen chloride, hydrogen fluoride, and chlorine.
In organic HAP service means that a piece of equipment either contains or contacts a fluid (liquid
or gas) that is at least 5 percent by weight of total organic HAP as determined according to the provisions
of §63.180(d). The provisions of §63.180(d) also specify how to determine that a piece of equipment is
not in organic HAP service.
Isolated intermediate means a product of a process that is stored before subsequent processing.
An isolated intermediate is usually a product of a chemical synthesis, fermentation, or biological
extraction process. Storage of an isolated intermediate marks the end of a process. Storage occurs at any
time the intermediate is placed in equipment used solely for storage. The storage equipment is part of the
MCPU that produces the isolated intermediate and is not assigned as specified in §63.2435(d).
Large control device means a control device that controls total HAP emissions of greater than or
equal to 10 tpy, before control.
Maintenance wastewater means wastewater generated by the draining of process fluid from
components in the MCPU into an individual drain system in preparation for or during maintenance
activities. Maintenance wastewater can be generated during planned and unplanned shutdowns and
during periods not associated with a shutdown. Examples of activities that can generate maintenance
wastewater include descaling of heat exchanger tubing bundles, cleaning of distillation column traps,
draining of pumps into an individual drain system, and draining of portions of the MCPU for repair.
Wastewater from routine cleaning operations occurring as part of batch operations is not considered
maintenance wastewater.
Maximum true vapor pressure has the meaning given in §63.111, except that it applies to all HAP
rather than only organic HAP.
Miscellaneous organic chemical manufacturing process means all equipment which collectively
function to produce a product or isolated intermediate that are materials described in §63.2435(b). For
the purposes of this subpart, process includes any, all or a combination of reaction, recovery, separation,
purification, or other activity, operation, manufacture, or treatment which are used to produce a product or
isolated intermediate. A process is also defined by the following:
(1) Routine cleaning operations conducted as part of batch operations are considered part of the
process;
(2) Each nondedicated solvent recovery operation is considered a single process;
(3) Each nondedicated formulation operation is considered a single process that is used to
formulate numerous materials and/or products; and
(4) Quality assurance/quality control laboratories are not considered part of any process; and
(5) Ancillary activities are not considered a process or part of any process.
(6) The end of a process that produces a solid material is either up to and including the dryer or
extruder, or for a polymer production process without a dryer or extruder, it is up to and including the
extruder, die plate, or solid-state reactor, except in two cases. If the dryer, extruder, die plate, or
solid-state reactor is followed by an operation that is designed and operated to remove HAP solvent or
residual HAP monomer from the solid, then the solvent removal operation is the last step in the process.
If the dried solid is diluted or mixed with a HAP-based solvent, then the solvent removal operation is the
last step in the process.
Nondedicated solvent recovery operation means a distillation unit or other purification equipment
that receives used solvent from more than one MCPU.
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Appendix B
Nonstandard batch means a batch process that is operated outside of the range of operating
conditions that are documented in an existing operating scenario but is still a reasonably anticipated
event. For example, a nonstandard batch occurs when additional processing or processing at different
operating conditions must be conducted to produce a product that is normally produced under the
conditions described by the standard batch. A nonstandard batch may be necessary as a result of a
malfunction, but it is not itself a malfunction.
On-site or on site means, with respect to records required to be maintained by this subpart or
required by another subpart referenced by this subpart, that records are stored at a location within a major
source which encompasses the affected source. On-site includes, but is not limited to, storage at the
affected source or MCPU to which the records pertain, or storage in central files elsewhere at the major
source.
Operating scenario means, for the purposes of reporting and recordkeeping, any specific
operation of an MCPU as described by records specified in §63.2525(b).
Organic group means structures that contain primarily carbon, hydrogen, and oxygen atoms.
Organic peroxides means organic compounds containing the bivalent -o-o- structure which may
be considered to be a structural derivative of hydrogen peroxide where one or both of the hydrogen atoms
has been replaced by an organic radical.
Point of determination means each point where process wastewater exits the MCPU or control
device.
Note to definition for point of determination: The regulation allows determination of the
characteristics of a wastewater stream: At the point of determination; or downstream of the point of
determination if corrections are made for changes in flow rate and annual average concentration of
soluble HAP and partially soluble HAP compounds as determined according to procedures in §63.144 of
subpart G in this part 63. Such changes include losses by air emissions; reduction of annual average
concentration or changes in flow rate by mixing with other water or wastewater streams; and reduction in
flow rate or annual average concentration by treating or otherwise handling the wastewater stream to
remove or destroy HAP.
Predominant HAP means as used in calibrating an analyzer, the single organic HAP that
constitutes the largest percentage of the total organic HAP in the analyzed gas stream, by volume.
Process condenser means a condenser whose primary purpose is to recover material as an integral
part of an MCPU. All condensers recovering condensate from an MCPU at or above the boiling point or
all condensers in line prior to a vacuum source are considered process condensers. Typically, a primary
condenser or condensers in series are considered to be integral to the MCPU if they are capable of and
normally used for the purpose of recovering chemicals for fuel value (i.e., net positive heating value), use,
reuse or for sale for fuel value, use, or reuse. This definition does not apply to a condenser that is used to
remove materials that would hinder performance of a downstream recovery device as follows:
(1) To remove water vapor that would cause icing in a downstream condenser, or
(2) To remove water vapor that would negatively affect the adsorption capacity of carbon in a
downstream carbon adsorber, or
(3) To remove high molecular weight organic compounds or other organic compounds that
would be difficult to remove during regeneration of a downstream carbon adsorber.
Process tank means a tank or vessel that is used within a process to collect material discharged
from a feedstock storage tank or equipment within the process before the material is transferred to other
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Appendix B
equipment within the process or a product storage tank. A process tank has emissions that are related to
the number of batches, and it does not accumulate product over multiple batches. A tank that is used to
accumulate used solvent from multiple batches of a single process for purposes of solvent recovery is a
process tank and does not represent the end of a process. Surge control vessels and bottoms receivers are
not process tanks.
Production-indexed HAP consumption factor (HAP factor) means the result of dividing the
annual consumption of total HAP by the annual production rate, per process.
Production-indexed VOC consumption factor (YOG factor) means the result of dividing the
annual consumption of total VOC by the annual production rate, per process.
Quaternary ammonium compounds means a type of organic nitrogen compound in which the
molecular structure includes a central nitrogen atom joined to four organic groups as well as an acid
radical of some sort.
Recovery device means an individual unit of equipment used for the purpose of recovering
chemicals from process vent streams and from wastewater streams for fuel value (i.e., net positive heating
value), use, reuse, or for sale for fuel value, use, or reuse. For the purposes of meeting requirements in
Table 2 to this subpart, the recovery device must not be a process condenser and must recover chemicals
to be reused in a process on site. Examples of equipment that may be recovery devices include absorbers,
carbon adsorbers, condensers, oil-water separators or organic-water separators, or organic removal
devices such as decanters, strippers, or thin-film evaporation units. To be a recovery device for a
wastewater stream, a decanter and any other equipment based on the operating principle of gravity
separation must receive only multi-phase liquid streams.
Responsible official means responsible official as defined in 40 CFR 70.2.
Safety device means a closure device such as a pressure relief valve, frangible disc, fusible plug,
or any other type of device which functions exclusively to prevent physical damage or permanent
deformation to a unit or its air emission control equipment by venting gases or vapors directly to the
atmosphere during unsafe conditions resulting from an unplanned, accidental, or emergency event. For
the purposes of this subpart, a safety device is not used for routine venting of gases or vapors from the
vapor headspace underneath a cover such as during filling of the unit or to adjust the pressure in response
to normal daily diurnal ambient temperature fluctuations. A safety device is designed to remain in a
closed position during normal operations and open only when the internal pressure, or another relevant
parameter, exceeds the device threshold setting applicable to the air emission control equipment as
determined by the owner or operator based on manufacturer recommendations, applicable regulations, fire
protection and prevention codes and practices, or other requirements for the safe handling of flammable,
combustible, explosive, reactive, or hazardous materials.
Shutdown means the cessation of operation of a continuous operation for any purpose. Shutdown
also means the cessation of a batch operation, or any related individual piece of equipment required or
used to comply with this subpart, if the steps taken to cease operation differ from those described in a
standard batch or nonstandard batch. Shutdown also applies to emptying and degassing storage vessels.
Shutdown does not apply to cessation of batch operations at the end of a campaign or between batches
within a campaign when the steps taken are routine operations.
Small control device means a control device that controls total F£AP emissions of less than 10 tpy,
before control.
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Appendix B
Standard batch means a batch process operated within a range of operating conditions that are
documented in an operating scenario. Emissions from a standard batch are based on the operating
conditions that result in highest emissions. The standard batch defines the uncontrolled and controlled
emissions for each emission episode defined under the operating scenario.
Startup means the setting in operation of a continuous operation for any purpose; the first time a
new or reconstructed batch operation begins production; for new equipment added, including equipment
required or used to comply with this subpart, the first time the equipment is put into operation; or for the
introduction of a new product/process, the first time the product or process is run in equipment. For batch
operations, startup applies to the first time the equipment is put into operation at the start of a campaign to
produce a product that has been produced in the past if the steps taken to begin production differ from
those specified in a standard batch or nonstandard batch. Startup does not apply when the equipment is
put into operation as part of a batch within a campaign when the steps taken are routine operations.
Storage tank means a tank or other vessel that is used to store liquids that contain organic HAP
and/or hydrogen halide and halogen HAP and that has been assigned to an MCPU according to the
procedures in §63.2435(d). The following are not considered storage tanks for the purposes of this
subpart:
(1) Vessels permanently attached to motor vehicles such as trucks, railcars, barges, or ships;
(2) Pressure vessels designed to operate in excess of 204.9 kilopascals and without emissions to
the atmosphere;
(3) Vessels storing organic liquids that contain HAP only as impurities;
(4) Wastewater storage tanks;
(5) Bottoms receivers;
(6) Surge control vessels; and
(7) Process tanks.
Supplemental gases means the air that is added to a vent stream after the vent stream leaves the
unit operation. Air that is part of the vent stream as a result of the nature of the unit operation is not
considered supplemental gases. Air required to operate combustion device burner(s) is not considered
supplemental gases.
Surge control vessel means feed drums, recycle drums, and intermediate vessels as part of any
continuous operation. Surge control vessels are used within an MCPU when in-process storage, mixing,
or management of flowrates or volumes is needed to introduce material into continuous operations.
Total organic compounds or (TOO means the total gaseous organic compounds (minus methane
and ethane) in a vent stream.
Transfer rack means the collection of loading arms and loading hoses, at a single loading rack,
that are assigned to an MCPU according to the procedures specified in §63.2435(d) and are used to fill
tank trucks and/or rail cars with organic liquids that contain one or more of the organic HAP listed in
section 112(b) of the CAA of this subpart. Transfer rack includes the associated pumps, meters, shutoff
valves, relief valves, and other piping and valves.
Unit operation means those processing steps that occur within distinct equipment that are used,
among other things, to prepare reactants, facilitate reactions, separate and purify products, and recycle
materials. Equipment used for these purposes includes, but is not limited to, reactors, distillation
columns, extraction columns, absorbers, decanters, dryers, condensers, and filtration equipment.
Waste management unit means the equipment, structure(s), and/or device(s) used to convey,
store, treat, or dispose of wastewater streams or residuals. Examples of waste management units include
B-7
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Appendix B
wastewater tanks, air flotation units, surface impoundments, containers, oil-water or organic-water
separators, individual drain systems, biological wastewater treatment units, waste incinerators, and
organic removal devices such as steam and air stripper units, and thin film evaporation units. If such
equipment is being operated as a recovery device, then it is part of a miscellaneous organic chemical
manufacturing process and is not a waste management unit.
Wastewater means water that is discarded from an MCPU or control device through a POD and
that contains either: an annual average concentration of compounds in Tables 8 and 9 to this subpart of at
least 5 ppmw and has an annual average flowrate of 0.02 liters per minute or greater; or an annual average
concentration of compounds in Tables 8 and 9 to this subpart of at least 10,000 ppmw at any flowrate.
Wastewater means process wastewater or maintenance wastewater. The following are not considered
wastewater for the purposes of this subpart:
(1) Stormwater from segregated sewers;
(2) Water from fire-fighting and deluge systems, including testing of such systems;
(3) Spills;
(4) Water from safety showers;
(5) Samples of a size not greater than reasonably necessary for the method of analysis that is
used;
(6) Equipment leaks;
(7) Wastewater drips from procedures such as disconnecting hoses after cleaning lines; and
(8) Noncontact cooling water.
Wastewater stream means a stream that contains only wastewater as defined in this paragraph (i).
Work practice standard means any design, equipment, work practice, or operational standard, or
combination thereof, that is promulgated pursuant to section 112(h) of the CAA.
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Appendix C
Summary of Initial Compliance Requirements for
Process Vents and Monitoring Requirements for
Various Types of Vent Streams
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AH venls
O
No initial compliance
requirements
Calculate uncontrolled
hydrogen halide and
halogen HAP emissions
specified In §63.1257(d)of
sutoart GGG
Emissions
> 1,000 IbVyr/
process?
Conduct design
evaluation in accordance
with §63.1257(a)
ofsubpartGGG
identify continuous and
batch process vents
per their definitions for
the MCPU
Comply with §63.115(d);
calculate TRE or designate
as Group 1; measurements
required for 5 0>TRE>1,9
Mo initial compliance
requirements for Group 2 vents
Small
control device
(excluding
flaresl?
Are
emissions
> 10,000 Ifa/yr,'
process (i.e.,
Group 11?
Is the
control device or
recovery device a
condenser?
organic HAP
emissions as
specified in
§63,1257(5!) of
subpart GGG
Designate as Group 1
Conduct a
performance test as
specified in either
§63.997ofsubpartSS
or §63,1257 of subpart
GGG, as applicable
Calculate controlled
emissions using
procedures in §63.1257
of subpart GGG and
§63.2460(c)(2)(iii)
Figure C-l. Initial compliance demonstration for process vents.
n
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p
to
Is the
emission stream
a continuous process
vent with a recovery
device?
Is the
emission
stream
controlled?
Is the
emission
stream from a
wastewater
management
unit?
Is the
IRE < 5.0 for an
existing source or
<• 8.0 for a new
source?
Subpart SS 63.993 (absorbers, condensers,
carbon adsorbers and diner recovery devices
used as final recovery devices)
Complying with
alternative standard
(for process vents or
storage tanks)?
Islhe
emission stream
from equipment
leaks?
§63.98?!c): Flares
§63.986(c): Non-flare control devices
Halogenated vent
stream?
Using
combustion control
device with acid gas
scrubber?
Is Ins
total uncontrolled
HAP into the
control device
TRY?
Confirm that the device is
operating property (periodic
verification) by conducting
approved daily or per batch
demonstrations as speciied in
§63,2450
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Appendix D
Inspection and Monitoring Requirements for
Waste Management Units as Specified in
Table 11 to 40 CFR Part 63, Subpart G
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TABLE 11.—WASTEWATER—INSPECTION AND MONITORING REQUIREMENTS FOR WASTE
MANAGEMENT UNITS
To comply with
Tanks:
63.133(b)(1)
63 1 33(c)
63.133(d)
63. 133(f) 63.133(g)
Surface impoundments:
63 134(b)(1)
63.134(c)
Containers:
63.135(b)(1),
63.135(b)(2) (ii).
63.135(d)(1)
63 1 35(e)
Individual Drain Systems3:
63 136(b)(1)
63 1 36(c)
63 136(e)(1)
63.136(e)(2),
63.136(f)(1).
Inspection or monitoring requirement
Inspect fixed roof and all openings for leaks
Inspect floating roof in accordance with
§§63. 120 (a) (2) and (a)(3).
Measure floating roof seal gaps in accordance
with §§63.120 (b)(2)(i) through (b)(4).
— Primary seal gaps
— Secondary seal gaps
Inspect wastewater tank for control equipment
failures and improper work practices.
Inspect surface impoundment for control equip-
ment failures and improper work practices.
Inspect cover and all openings for leaks
Inspect enclosure and all openings for leaks ....
Inspect container for control equipment failures
and improper work practices.
Inspect cover and all openings to ensure there
are no gaps, cracks, or holes.
Inspect individual drain system for control
equipment failures and improper work prac-
tices.
Verify that sufficient water is present to prop-
erly maintain integrity of water seals.
Inspect all drains using tightly-fitted caps or
plugs to ensure caps and plugs are in place
and properly installed.
Frequency of inspection
or monitoring
Initially Semi-annually ..
See §63.120 (a)(2) and
(a)(3).
Once every 5 years Ini-
tially Annually.
Initially Semi-annually ..
Initially Semi-annually ..
Initially Semi-annually ..
Initially Semi-annually ..
Initially Semi-annually ..
Initially Semi-annually ..
Initially Semi-annually ..
Initially Semi-annually ..
Initially Semi-annually ..
Initially Semi-annually ..
Method
Visual.
Visual.
See §63.120 (b)(2)(i)
through (b)(4).
Visual.
Visual.
Visual.
Visual.
Visual.
Visual.
Visual.
Visual.
Visual.
Visual.
Environmental Protection Agency
Pt. 63, Subpt. G, App.
TABLE 11.—WASTEWATER—INSPECTION AND MONITORING REQUIREMENTS FOR WASTE
MANAGEMENT UNITS—Continued
To comply with
63.136(f)(2)
63136(f)(3)
Oil-water separators:
63137(b)(1)
63.137(c)
63.137(c)
63 1 37(d)
Inspection or monitoring requirement
Inspect all junction boxes to ensure covers are
in place and have no visible gaps, cracks, or
holes.
cracks and gaps.
Measure floating roof seal gaps in accordance
with 40CFR 60.696(d)(1).
— Pri mary seal gaps
— Secondary seal gaps
ment failures and improper work practices.
Frequency of inspection
or monitoring
Initially Semi-annually ..
Initially11
Once every 5 years.
Initially11 Annually.
Method
Visual or smoke test or
other means as
specified.
Visual
Visual
See 40 CFR
60.696(d)(1).
Visual
aAs specified in §
§63.136 (e) and (f).
bWithin 60 days of
63.136(a), the owner or operator shall comply with either the requirements of §63.136 (b) and (c) or
installation as specified in §63.137(c).
D-l
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Appendix E
Control Equipment Failure for Waste Management Units
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Appendix E
Table E-l. Example Control Equipment Failures for Waste Management Units
For each . . .
wastewater tank
surface impoundment
container
individual drain system
covered in accordance
with§63.136(b)
Control equipment failures include, but are not
limited to ...
• the floating roof is not resting on either the
surface of the liquid or on the leg supports
• there is stored liquid on the floating roof
• a rim seal is detached from the floating roof
• there are holes, tears, cracks, or gaps in the rim
seal or seal fabric of the floating roof
• there are visible gaps between the seal of an
internal floating roof and the wall of the
wastewater tank
• there are gaps between the metallic shoe seal or
the liquid mounted primary seal of an external
floating roof and the wasll of the wastewater
tank that exceed 212 square centimeters per
meter of tank diameter or the width of any
portion oof any gap between the primary seal
and the tank wall exceeds 3.81 centimeters
• there are gaps between the secondary seal of an
external floating roof and the wall of the
wastewater tank that exceed 21.2 square
centimeters per meter of tank diameter or the
width of any portion of any gap between the
secondary seal and the tank wall exceeds 1 .27
centimeters
• where a metallic shoe seal is used on an external
floating roof, one end of the metallic shoe does
not extend into the stored liquid or one end of
the metallic shoe does not extend a minimum
vertical distance of 61 centimeters above the
surface of the stored liquid
• a gasket, joint, lid, cover, or door has a crack,
gap, or is broken
any time a joint, lid, cover, or door has a crack or
gap, or is broken
any time a cover or door has a gap, crack, or is
broken
any time a joint, lid, cover, or door has a gap or
crack, or is broken
According to the
following section of
the rule . . .
§63.133(g)(l)(i)
through (ix)
§63.134(c)(2)
§63.135(e)(2)
§63.136(c)(2)
E-l
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Appendix E
For each ...
Control equipment failures include, but are not
limited to ...
According to the
following section of
the rule ...
oil-water separator
the floating roof is not resting on either the
surface of the liquid or on the leg supports
there is stored liquid on the floating roof
a rim seal is detached from the floating roof
there are holes, tears, or other open spaces in the
rim seal or seal fabric of the floating roof
there are gaps between the primary seal and the
separator wall that exceed 67 square centimeters
per meter of separator wall perimeter or the
width of any portion of any gap between the
primary seal and the separator wall exceeds 3.8
centimeters
there are gaps between the secondary seal and
the separator wall that exceed 6.7 square
centimeters per meter of separator wall
perimeter or the width of any portion of any gap
between the secondary seal and the separator
wall exceeds 1.3 centimeters
a gasket, joint, lid, cover, or door has a gap or
crack, or is broken
§63.137(e)(l)(i)
through (vii)
E-2
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