September 1994
INSPECTION MANUAL FOR
THE HAZARDOUS ORGANIC NESHAP
(HON)
U.S. Environmental Protection Agency
Chemical, Commercial Services, and Municipal Division
Washington, D.C. 20460
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TABLE OF CONTENTS
Section* - Page
1 PURPOSE OF THIS MANUAL 1-1
2 PREPARING FOR THE INSPECTION 2-1
3 OVERVIEW OFTHE HAZARDOUS ORGANIC NESHAP 3-1
3.1 SUBPART F 3-1
3.2 SUBPART G 3-1
3.3 SUBPART H 3-5
3.4 SUBPART I 3-6
3.5 GENERAL REPORTING 3-6
3.5.1 Initial Notification 3-7
3.5.2 Implementation Plan 3-7
3.5.3 Notification of Compliance Status 3-7
3.5.4 Periodic Reports 3-8
3.5.5 Other Reports 3-9
3.6 USE OF CONTINUOUS MONITORING TO DETERMINE COMPLIANCE 3-9
4 APPLICABILITY OF THE RULE 4-1
4.1 IDENTIFICATION OF SOCMI PROCESS UNITS 4-1
4.2 DETERMINATION OF THE HON SOURCE 4-2
4.3 DETERMINATION OF NEW SOURCE VS. EXISTING SOURCE 4-6
4.3.1 New Sources 4-6
4.3.2 Existing Sources 4-11
4.3.3 Other Process Changes 4-11
4.3.4 Compliance Dates 4-12
5 PROCESS VENTS 5-1
5.1 DESCRIPTION OF EMISSION POINT 5-1
5.2 DESCRIPTION OF EMISSION CONTROL TECHNOLOGIES 5-3
5.2.1 Combustion Control Devices 5-7
5.2.1.1 Thermal Incinerators 5-7
5.2.1.2 Catalytic Incinerators 5-7
5.2.1.3 Industrial Boilers and Process Heaters 5-11
5.2.1.4 Rares . 5-11
5.2.1.5 Halogenated Streams 5-13
5.2.2 Product Recovery Devices 5-13
5.2.2.1 Condensers 5-13
5.2.2.2 Adsorption 5-16
5.2.2.3 Absorption 5-16
5.3 PROCESS VENT PROVISIONS 5-19
5.3.1 Process Vent Definition 5-19
5.3.2 Process Vent Group Determination 5-19
5.3.3 Process Vent Control Requirements 5-20
5.3.4 Process Vent Testing, Monitoring, Recordkeeping, and Reporting 5-23
5.4 PROCESS VENT INSPECTION PROCEDURES 5-29
5.5 REFERENCES 5-48
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TABLE OF CONTENTS, continued
6 TRANSFER OPERATIONS 6-1
6.1 DESCRIPTION OF EMISSION POINT 6-1
6.2 DESCRIPTION OF EMISSION CONTROL TECHNOLOGIES 6-1
6.2.1 Vapor Collection System 6-2
6.2.2 Combustion and Recovery Devices 6-2
6.2.3 Vapor Balancing 6-2
6.3 TRANSFER OPERATIONS PROVISIONS 6-2
6.3.1 Transfer Operations Definition 6-2
6.3.2 Transfer Operations Group Determination 6-4
6.3.3 Transfer Operation Control Requirements 6-4
6.3.4 Transfer Operations Testing, Monitoring, Recordkeeping, and Reporting ... 6-7
6.4 TRANSFER OPERATIONS INSPECTION PROCEDURES 6-17
6.5 REFERENCES 6-17
7 STORAGE VESSELS 7-1
7.1 DESCRIPTION OF EMISSION POINT 7-1
7.1.1 Fixed-Roof Storage Vessel 7-1
7.1.2 Roating Roof Storage Vessel 7-1
7.1.2.1 External Roating Roof Vessel 7-2
7.1.2.2 Internal Roating Roof Vessel 7-2
7.1.2.3 External Roating Roof Vessel Converted to an Internal Roating
Roof Vessel 7-2
7.2 DESCRIPTION OF EMISSION CONTROL TECHNOLOGIES 7-2
7.2.1 Fixed-Roof Vessels 7-2
7.2.2 Roating Roof Vessels 7-3
7.3 STORAGE VESSEL PROVISIONS 7-4
7.3.1 Storage Vessel Definition 7-4
7.3.2 Storage Vessel Group Determination 7-4
7.3.3 Storage Vessel Control Requirements 7-4
7.3.4 Storage Vessel Testing, Monitoring, Recordkeeping, and Reporting 7-7
7.4 STORAGE VESSEL INSPECTION PROCEDURES 7-18
7.5 REFERENCES , . 7-18
8 WASTEWATER . . 8-1
8.1 DESCRIPTION OF EMISSION POINT 8-1
8.1.1 Individual Drain Systems 8-3
8.1.2 Manholes 8-3
8.1.3 Trenches 8-3
8.1.4 Sumps 8-3
8.1.5 Junction Boxes 8-4
8.1.6 Lift Stations 8-4
8.1.7 Weirs '. 8-4
8.1.8 Oil-Water Separators 8-4
8.1.9 Equalization Basins 8-4
8.1.10 Treatment Tanks 8-5
8.1.11 Biological Treatment Basins 8-5
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TABLE OF CONTENTS, continued
Section Page
8.1.12 Clarifiers 8-5
8.1.13 Surface Impoundments 8-5
8.1.14 Containers : 8-6
8.2 DESCRIPTION OF EMISSION CONTROL TECHNOLOGIES 8-6
8.2.1 Waste Management Units 8-6
8.2.1.1 Controls for Process Drains 8-6
8.2.1.2 Controls for Junction Boxes. Manholes, Trenches, Weirs,
Sumps, and Lift Stations 8-7
8.2.1.3 Controls for Wastewater Tanks and Oil-Water Separators 8-7
8.2.1.4 Containers '. 8-8
8.2.2 Treatment Processes 8-8
8.2.2.1 Steam Stripping 8-8
8.2.2.2 Biological Treatment 8-10
8.2.3 Closed-Vent Systems and Control Devices 8-10
8.3 WASTEWATER PROVISIONS 8-10
8.3.1 Wastewater Definition 8-11
8.3.2 Sourcewide 1 Mg/yr Exemption 8-12
8.3.3 Process Wastewater Group Determination 8-12
8.3.4 Process Wastewater Control Requirements 8-15
8.3.4.1 Waste Management Units : 8-17
8.3.4.2 Treatment Processes 8-21
8.3.4.3 Closed-Vent Systems and Control Devices 8-27
8.3.4.4 Residuals Management 8-27
8.3.5 Process Wastewater Testing, Monitoring, Recordkeeping and Reporting .. 8-28
8.3.6 Heat Exchange Systems and Cooling Water Management Requirements .. 8-29
8.3.7 Maintenance Wastewater Management Requirements 8-36
8.4 WASTEWATER INSPECTION PROCEDURES 8-37
8.5 REFERENCES 8-37
Appendices:
Appendix A: Code of Federal Regulations Citations
Appendix B: Comparison of HON Process Vent Provisions with Distillation, Air Oxidation, and
Reactors NSPS
Appendix C: Example Calculation of TRE Index Value
Appendix D: Logic Row Diagrams for Wastewater Provisions
Appendix E: Information on Wastewater to be Submitted with Inplementation Plan
Appendix F: Information on Wastewater to be Submitted with Notification of Compliance Status
Appendix G: Compliance Checklists
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UST OF TABLES
Table ' Page
3-1 Organization of HON 3-2
4-1 Applicability of the HON 4-3
4-2 Determination of the Primary Product and Applicability for Rexible Operation Units 4-4
4-3 Determination of Primary Product 4-5
4-4 Assignment of Storage Vessels 4-7
4-5 Assignment of Transfer Racks : 4-8
4-6 Assignment of Distillation Units 4-9
4-7 Compliance Dates for Existing, New, and Reconstructed Sources 4-13
5-1 Applicability and Group Determination Checklist for Process Vents 5-21
5-2 Process Vents Initial Performance Test and Recordkeeplng and Reporting for
Compliance Determination 5-24
5-3 Initial Group Determination and Recordkeeping and Reporting Requirements for Group 2
Process Vents 5-27
5-4 Monitoring, Recordkeeplng, and Reporting Requirements for Process Vents Complying
with 98 Weight-Percent Reduction of Emissions or a Limit of 20 Parts per Million by
Volume or Using a Rare 5-30
5-5 Monitoring, Recordkeeping, and Reporting Requirements for Process Vents Maintaining
a TRE Index Value >1.0 and <4.0 5-34
5-6 Compliance Checklist for Process Vent Systems 5-37
6-1 Applicability and Group Determination Checklist for Transfer Operations 6-5
6-2 Transfer Rack Initial Performance Test and Recordkeeping and Reporting for
Compliance Determination 6-8
6-3 Monitoring, Recordkeeping, and Reporting Requirements for Transfer Racks Complying
with 98 Weight-Percent Reduction of Emissions or a Limit of 20 Parts per Million by
Volume or Using a Rare 6-11
6-4 Compliance Checklist for Transfer Operations 6-18
7-1 Applicability and Group Determination Checklist for Storage Vessels 7-5
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UST OF TABLES, continued
Table f Page
7-2 Periodic Inspection, Measurement, Recordkeeping, and Reporting Requirements for
Storage Vessels Equipped with an Internal Roating Roof Vessel, an External Roating
Roof, or an External Roating Roof Vessel Converted to an Internal Roating Roof Vessel ... 7-9
7-3 Periodic and Continuous Monitoring, Inspection, Recordkeeping, and Reporting
Requirements for Storage Vessels Equipped With a Closed-Vent System and Control
Device 7-15
7-4 Compliance Checklist for Storage Vessels 7-19
8-1 Common Components of Wastewater Collection Systems and Treatment Processes 8-2
8-2 Applicability Checklist for Process and Maintenance Wastewater 8-13
8-3 Group 1/Group 2 Determination for Process Wastewater Streams 8-16
8-4 Wastewater Tank Emission Control Requirements 8-18
8-5 Container Emission Control Requirements 8-20
8-6 Process Wastewater Compliance Options for New Sources 8-23
8-7 Process Wastewater Compliance Options for Existing Sources 8-25
8-8 Inspection and Monitoring Requirements for Waste Management Units 8-30
8-9 Monitoring Requirements for Treatment Processes 8-32
8-10 Monitoring Requirements for Control Devices 8-33
8-11 Periodic Reporting Requirements for Control Devices used to Comply with
§§63.133-63.139 8-35
8-12 Compliance Checklist for Waste. Management Units 8-38
8-13 Compliance Checklist for Treatment Processes 8-58
8-14 Compliance Checklist for Control Equipment Requiring Leak Detection 8-62
8-15 Compliance Checklist for Wastewater Control Devices 8-65
8-16 Compliance Checklist for Heat Exchange Systems Requiring Leak Detection 8-74
8-17 Compliance Checklist for Maintenance Wastewater Management 8-76
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UST OF FIGURES
Figure * Page
5-1 Examples of Reactor-Related Vents 5-2
5-2 Potential VOC and HAP Emission Points for an Atmospheric (Nonvacuum) Distillation
Column 5-4
5-3 Potential VOC and HAP Emission Points for a Vacuum Distillation Column Using Steam
Jet Ejectors with Barometric Condenser 5-5
5-4 Potential VOC and HAP Emission Points for a Vacuum Distillation Column Using a
Vacuum Pump 5-6
5-5 Discrete Burner, Thermal Incinerator 5-8
5-6 Distributed Burner, Thermal Incinerator 5-9
5-7 Catalytic Incinerator 5-10
5-8 Steam-Assisted Elevated Rare System 5-12
5-9 Refrigerated Surface Condenser System for VOC Vapor Recovery 5-14
5-10 Schematic Diagram of a Shell and Tube Surface Condenser 5-15
5-11 Two-Stage Regenerative Adsorption System 5-17
5-12 Packed Tower Absorption Process 5-18
6-1 Vapor Balancing System 6-3
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SECTION 1
PURPOSE OF THIS MANUAL
This manual is consistent with the promulgated hazardous organic national emission
standard for hazardous air pollutants (hazardous organic NESHAP, or HON). The final rule was
published in the Federal Register on April 22, 1994 (59 PR 19453).
Section 112 of the Clean Air Act directed the U. S. Environmental Protection Agency (EPA)
to set national emission standards for hazardous air pollutants (NESHAP). Section 112(b) listed
189 hazardous air pollutants (HAP's). Section 112 required the EPA to publish a list of categories of
sources that emit HAP's and to develop regulations for these source categories. The synthetic organic
chemical manufacturing industry (SOCMI) was subsequently listed as a source category emitting HAP's.
The hazardous organic NESHAP (HON) regulates emissions of 112 organic HAP's from the
SOCMI. The regulation can be found in the Code of Federal Regulations (40 CFR Part 63) in
Subparts F, G, H, and I. Subpart F contains provisions for determining applicability of the HON,
definitions, and general procedures for testing, compliance, reporting, and recordkeeping. The specific
control, monitoring, reporting, and recordkeeping requirements are stated in Subpart G for process
vents, transfer operations, storage vessels, and wastewater streams, and in Subpart H for equipment
leak emissions. Subpart I provides the applicability criteria for non-SOCMI processes subject to the
negotiated regulation for equipment leaks and requires compliance with Subpart H.
The purpose of this manual is to assist federal, state, and local regulatory personnel with
enforcement of the process vent, transfer operation, storage vessel, and wastewater provisions of
Subpart G. The emissions averaging provisions of Subpart G and the equipment leak provisions of
Subpart H are not included. Because the process vents provisions of the HON are similar to new
source performance standards (NSPS) for SOCMI air oxidation reactors and distillation operations, this
manual will also be useful for enforcement of those NSPS. While this manual does not describe the
NSPS in detail, an appendix identifies key differences between the HON process vents provisions and
the NSPS.
This manual is organized in eight sections. Section 2 provides guidelines for preparing for
an inspection. Section 3 is an overview of the requirements of the rule, and Section 4 discusses
applicability of the rule. Sections 5 through 8 provide a detailed description of the requirements of the
rule for process vents, transfer operations, storage vessels, and wastewater streams. Tables
summarizing monitoring, recordkeeping, and reporting requirements are included along with compliance
checklists.
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Seven appendices are included in this manual. Appendix A lists Code of Federal
Regulations citations for the HON, the NESHAP General Provisions, test methods required by the HON,
and the air oxidation and distillation NSPS. This will allow inspectors to easily locate the complete text
of these rules. Appendix B contains a comparison of the HON process vents provisions with those in
the NSPS for distillation, air oxidation, and reactors. Appendix C illustrates the calculation of total
resource effectiveness (THE) index value for process vents. The TRE index value is used to determine
whether process vent emissions must be controlled. Appendix D contains logic flow diagrams for the
wastewater provisions. Appendices E and F list the information on wastewater that must be reported in
the Implementation Plan and Notification of Compliance Status, respectively. Finally, Appendix G
provides additional blank copies of the checklists presented in Sections 5 through 8. The forms in this
appendix can be reproduced and used for inspections.
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SECTION 2
PREPARING FOR THE INSPECTION
Compliance with the HON can be determined by review of records and reports, review of
performance tests, and visual inspections using the methods and procedures specified in the rule. As
required by the rule,, testing, monitoring, and inspections are to be carried out by the owner or operator
with records kept for 5 years. Therefore, the local, state, or federal inspector can determine compliance
by the review of plant records, along with spot inspections to verify the operation, performance, and
condition of the control equipment.
Prior to conducting the inspection, the inspector should become familiar with the regulation,
search the EPA, state, or local agency files for information on the facility, and review all relevant
information. The HON requires that an Implementation Plan or operating permit application be
submitted by each facility that is subject to the regulation. These documents specify which emission
points are subject to the HON and what type of control is applied to each emission point. The inspector
can use these documents to develop a list of control devices to inspect. The most recent periodic
report should provide information on the facility's compliance status. A review of files will help the
inspector become familiar with the operation of the facility and the most recent compliance history. The
compliance history and prior inspections will help the inspector prioritize areas of concern for the
upcoming inspection. For example, if a leaking tank roof was identified in the last inspection, the
inspector would want to check the facility records to verify that the tank roof was repaired in the allotted
amount of time. The inspector may also want to visually inspect the tank to verify that it has been
repaired.
The inspector may also need to gather safety and emissions detection equipment prior to
the inspection. Some facilities will require inspectors to wear hard hats, safety glasses, and steel-toed
shoes during their visual inspection. If the inspector will need to do any climbing to inspect equipment
such as a tank roof, additional safety equipment may be necessary. As detailed in the checklist in
Section 7.4, respiratory protection may be needed for storage vessel inspections, and inspectors should
consult documents addressing safety issues prior to conducting internal inspections of storage vessels.
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 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.
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The inspection consists of a review of records and reports kept by the plant and a visual
inspection of plant equipment. Sections 5.4, 6.4, 7.4, and 8.4 provide inspection checklists for process
vents, transfer operations, storage vessels, and wastewater. The checklists will enable the inspector to
systematically review the plant records and reports. Each checklist provides a series of yes and no
statements. A "yes" response to all of the statements indicates compliance with the standard. However,
there are a few statements in the checklists that can be checked "no", and the facility would still be in
compliance. These exceptions are noted in the checklists. Appendix G is a collection of the process
vent, transfer operation, storage vessel, and wastewater inspection checklists. The inspector should
copy the checklists in the appendix 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 visual inspections. Control equipment should be checked for
obvious leaks and lack of maintenance.
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SECTION 3
OVERVIEW OF THE HAZARDOUS ORGANIC NESHAP
The HON regulates emissions from five kinds of emission points at SOCMI sources:
(1) process vents, (2) transfer operations, (3) storage vessels, (4) air emissions from wastewater streams
and wastewater collection and treatment operations, and (5) equipment leaks. The organization of the
regulation Is shown in Table 3-1.
3.1 SUBPARTF
Section 63.100 contains provisions to determine which chemical manufacturing processes at
a plant are subject to the HON. Table 1 of Subpart F contains a list of SOCMI chemicals, and Table 2
contains a list of organic HAP's regulated by the HON. In general, If a process both (1) produces one of
the listed SOCMI chemicals and (2) either uses as a reactant or produces a listed organic HAP In the
process, then that process Is subject to the HON. Section 63.100 contains additional details for
determining applicability in situations where a process makes multiple products. If a chemical
manufacturing process is subject to the HON, then the emission points associated with that process are
regulated. Details on how to determine which storage vessels, transfer racks, and distillation units are
part of a chemical manufacturing process are also contained in §63.100.
Definitions of terms used in Subparts F, G, and H are contained in §63.101. Sections 63.102
and 63.103 contain general compliance, recordkeeping, and reporting provisions and override certain
portions of the NESHAP General Provisions (40 CFR 63, Subpart A). These sections specify general
performance test conditions, require records to be maintained for 5 years, and clarify where reports
required under Subparts G and H are to be sent Section 63.104 contains requirements for heat
exchange systems and §63.105 contains requirements for maintenance wastewater.
3.2 SUBPART G
Subpart G contains the standard for process vents, transfer operations, storage vessels, and
wastewater. It includes emissions averaging provisions. The first section of Subpart G (§63.110)
contains applicability provisions that clarify potential overlaps between process vents, storage,
wastewater, and equipment leaks. The second section (§63.111) contains definitions.
Section 63.112 provides an equation representing a site-specific allowable overall emission
limit for each source. The 'source' Is the combination of all emission points subject to the HON at a
plant site (contiguous area under common control). The standard requires sources to meet the
allowable emission limit; however, the equation in §63.112 is not used to determine compliance with the
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TABLE 3-1. ORGANIZATION OF HON
Section
Number*
Title of Section
Subpart F - National Emission Standards for Organic Hazardous Air Pollutants from the Synthetic
Organic Chemical Manufacturing Industry
63.100
63.101
63.102
63.103
63.104
63.105
63.106
Applicability and designation of source.
Definitions.
General standards.
General compliance, reporting, and recordkeeping provisions.
Heat exchange system requirements.
Maintenance wastewater requirements.
Delegation of authority.
Subpart G - National Emission Standards for Organic Hazardous Air Pollutants from Synthetic
Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations,
and Wastewater.
63.110
63.111
63.112
63.113
63.114
63.115
63.116
63.117
63.118
63.119
63.120
63.121
63.122
63.123
63.124
63.125
Applicability.
Definitions.
Emission standards.
Process vent provisions - reference control technology,
Process vent provisions - monitoring requirements.
Process vent provisions - methods and procedures for process vent group
determination.
Process vent provisions - performance test methods and procedures to determine
compliance.
Process vent provisions - reporting and recordkeeping requirements for group and THE
determinations and performance tests.
Process vent provisions - periodic reporting and recordkeeping requirements.
Storage vessel provisions reference control technology.
Storage vessel provisions - procedures to determine compliance.
Storage vessel provisions - alternative means of emission limitation.
Storage vessel provisions - reporting.
Storage vessel provisions - recordkeeping.
Reserved.
Reserved.
(continued)
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TABLE 3-1. ORGANIZATION OF HON
Section
Nurriber*
Title of Section
63.126
63.127
63.128
63.129
63.130
63.131
63.132
63.133
63.134
63.135
63.136
63.137
63.138
63.139
63.140
63.141
63.142
63.143
63.144
63.145
63.146
63.147
63.148
63.149
63.150
63.151
63.152
Transfer operations provisions - reference control technology.
Transfer operations provisions - monitoring requirements.
Transfer operations provisions - test methods and procedures.
Transfer operations provisions - reporting and recordkeeping for performance tests and
notification of compliance status.
Transfer operations provisions - periodic reporting and recordkeeping.
Process wastewater provisions - flow diagrams and tables.
Process wastewater provisions - general.
Process wastewater provisions - wastewater tanks.
Process wastewater provisions - surface impoundments.
Process wastewater provisions - containers.
Process wastewater provisions - individual drain systems.
Process wastewater provisions - oil-water separators.
Process wastewater provisions - treatment processes.
Process wastewater provisions - control devices.
Process wastewater provisions - delay of repair.
Reserved.
Reserved.
Process wastewater provisions - inspections and monitoring of operations.
Process wastewater provisions - test methods and procedures for applicability and
Group 1 /Group 2 determination.
Process wastewater provisions - test methods and procedures to determine compliance.
Process wastewater provisions - reporting.
Process wastewater provisions - recordkeeping.
Leak inspection provisions.
Reserved.
Emissions averaging provisions.
Initial Notification and Implementation Plan.
General reporting and continuous records.
(continued)
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TABLE 3-1. ORGANIZATION OF HON
Section
Nurfiber*
Title of Section
Subpart H - National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks.
63.160
63.161
63.162
63.163
63.164
63.165
63.166
63.167
63.168
63.169
63.170
63.171
63.172
63.173
63.174
63.175
63.176
63.177
63.178
63.179
63.180
63.181
63.182
Applicability and designation of sources.
Definitions.
Standards: General.
Standards: Pumps in light liquid service.
Standards: Compressors.
Standards: Pressure relief devices in gas/vapor service.
Standards: Sampling connection systems.
Standards: Open-ended valves or lines.
Standards: Valves in gas/vapor service and in light liquid service.
Standards: Pumps, valves, connectors, and agitators in heavy liquid service;
instrumentation systems; and pressure relief devices in liquid service.
Standards: Surge control vessels and bottoms receivers.
Standards: Delay of repair.
Standards: Closed-vent systems and control devices.
Standards: Agitators in gas/vapor service and in light liquid service.
Standards: Connectors in gas/vapor service and in light liquid service.
Quality Improvement program for valves.
Quality improvement program for pumps.
Alternative means of emission limitation: General.
Alternative means of emission limitation: Batch processes.
Alternative means of emission limitation: Endosed-vented process units.
Test methods and procedures.
Recordkeeping requirements.
Reporting requirements.
Subpart I - National Emission Standards for Organic Hazardous Air Pollutants for Certain Processes
Subject to the Negotiated Regulation for Equipment Leaks.
63.190
63.191
63.192
63.193
Applicability and designation of source.
Definitions.
Standard.
Delegation of Authority.
a Section numbers of 40 CFR Part 63.
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standard, and source owners or operators are not required to calculate their allowable emission limit. As
provided In §63.1l2(c), the owner or operator of an existing source must demonstrate compliance using
one or* both of two approaches: the point-by-point compliance approach or the emissions averaging
approach. As provided in §63.112(d), the owner or operator of a new source must demonstrate
compliance using the point-by-point approach. Emissions averaging is not allowed for new sources.
Under the point-by-point approach, the owner or operator would apply control to each
'Group 1" emission point. A Group 1 emission point is a point which meets the control applicability
criteria, and the owner or operator must reduce emissions to specified levels; whereas a Group 2
emission point is one that does not meet the criteria and no emission reduction is required. These
Group 1 and Group 2 emission points are defined in §63.111. Owners or operators selecting the point-
by-point compliance approach must comply with the process vent provisions in §63.113 through
§63.118, the storage vessel provisions in §63.119 through §63.123, the transfer operation provisions in
§63.126 through §63.130, and the wastewater provisions in §63.131 through §63.147. These sections
include applicability criteria, emission limits, equipment and work practice standards, testing, monitoring,
recordkeeping, and reporting provisions. The specific criteria for Group 1 /Group 2 determinations and
required control levels for process vents, transfer operations, storage vessels, and wastewater streams
are listed in Sections 5 through 8 of this report.
Under the emissions averaging approach, an owner or operator may elect to control
different groups of emission points within the source to different levels than specified in §63.113 through
§63.147, as long as the overall emissions do not exceed the overall allowable emission level. An owner
or operator can choose not to control a Group 1 emission point (or to control the emission point with a
less effective control technique) Jf the owner or operator over controls another emission point within the
source. Emission 'debits' (in Mg of HAP emissions) are generated for each Group 1 emission point that
is uncontrolled or under-controlled. Emission 'credits' (also in Mg) are generated for over-controlled
points. Credits can be generated if a Group 2 point is controlled, or if a Group 1 point Is controlled by a
distinct technology that EPA approves as having a greater efficiency than the level of control required for
Group 1 points. Credits have to equal or exceed debits for a source to be in compliance.
Section 63.150 of the rule contains detailed equations for calculating debits and credits.
3.3 SUBPART H
Subpart H contains the standard for equipment leaks. Equipment regulated includes
pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended
valves or lines, valves, connectors, surge control vessels, bottoms receivers, and instrumentation
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systems in organic HAP service. A piece of equipment is in organic HAP service if it contains or
contacts a fluid that is at least 5 percent organic HAP by weight.
' The applicability of Subpart H and definitions are contained in §63.160 and §63.161.
respectively. Sections 63.162 through 63.179 contain the standards for the various kinds of equipment
and alternative means of emission limitation. These include leak detection and repair provisions and
other control requirements. Sections 63.180 through 63.182 contain test methods and procedures and
reporting and recordkeeping provisions.
3.4 SUBPART I
Subpart I provides the applicability criteria for the non-SOCMI processes subject to the
negotiated regulation for equipment leaks. Regulated equipment is the same as that for Subpart H:
pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended
valves or lines, valves, connectors, surge control vessels, bottoms receivers, and instrumentation
systems in organic HAP service. The applicability criteria for Subpart I and the definitions are specified
in §63.190 and §63.191, respectively. Section 63.193 contains the standard which basically requires
compliance with Subpart H.
3.5 GENERAL REPORTING
Sections 63.151 (Initial Notification and Implementation Plan) and 63.152 (General
Reporting) of Subpart G require sources to submit the following five types of reports:
1. Initial Notification,
2. Implementation Plan (if an operating permit application has not been
submitted),
3. Notification of Compliance Status,
4. Periodic Reports, and
5. other reports.
Sources subject to the HON are also subject to the NESHAP General Provisions (40 CFR
Part 63 Subpart A), which include additional reporting requirements. Table 3 of Subpart F of the HON
identifies which parts of the General Provisions apply to HON sources.
Records of reported information and other information necessary to document compliance
with the regulation are required to be kept for 5 years. A few records pertaining to equipment design
would be kept for the life of the equipment.
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3.5.1 Initial Notification
The purpose of the Initial Notification is to establish an early dialogue between the source
and trie regulatory agency, allowing both to plan for compliance activities. The notice is due August 20,
1994 for existing sources. For a new source with an initial startup on or after July 21,1994, the
application for approval of construction or reconstruction required by §63.5 (d) of subpart A must be
submitted Instead of the Initial Notification. This application is due as soon as practicable before
commencement of construction or reconstruction but no earlier than July 21,1994.
For a new source with an initial startup before July 21,1994, the Initial Notification is due on
July 21, 1994 but the application described in §63.5(d) of subpart A is not required.
The notification must list the chemical manufacturing processes at the source that are
subject to Subpart G, and which provisions may apply (e.g., process vents, transfer operations, storage
vessel, and/or wastewater provisions). A detailed identification of emission points is not required. The
Initial Notification must include a statement of whether the source can achieve compliance by the
specified compliance date, but a request for a compliance extension may be submitted later (by the date
the Implementation Plan Is due).
3.5.2 Implementation Plan
The Implementation Plan details how the source plans to comply with Subpart G. The plan
Identifies Group 1 and Group 2 emission points, and specifies the control technique that will be applied
to each Group 1 emission point. Implementation Plans are only required for sources that have not
submitted an operating permit application. An operating permit application would contain all of the
information required in the Implementation Plan, therefore, it would be redundant to require sources to
submit both.
For points included In emission averages, existing sources must submit the Implementation
Plan 18 months prior to the compliance date; for emission points not included in an emissions average,
the Implementation Plan Is due 12 months prior to the compliance date. For a new source with an initial
startup on or after July 21, 1994, the Implementation Plan must be submitted with the application for
approval of construction or reconstruction (i.e., as soon as practicable before commencement of
construction or reconstruction but no earlier than July 21,1994).
For a new source with an initial startup before July 21,1994, the Implementation Plan Is due
July 21. 1994.
3.5.3 Notification of Compliance Status
The Notification of Compliance Status must be submitted within 150 days after the source's
compliance date. The date of compliance for existing sources is 3 years after the date of promulgation.
The date of compliance for new sources is the date of promulgation or the startup date, whichever is
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later. The Notification of Compliance Status contains the information necessary to demonstrate that
compliance has been achieved, such as the results of performance tests for process vent and transfer
control devices, process vents TRE determinations, and monitoring system performance evaluations.
Sources with a large number of emission points are likely to submit results of multiple
performance tests. For each test method used for a particular kind of emission point (e.g., a process
vent), one complete test report must be submitted. For additional tests performed for the same kind of
emission point using the same method, the results must be submitted, but the complete test reports may
be kept at the plant
Another type of information to be included in the Notification of Compliance Status is the
specific range for each monitored parameter for each emission point, and the rationale for why this
range indicates proper operation of the control device. (If this range has already been established in the
operating permit. It need not be repeated in the Notification of Compliance Status). As an example, for a
process vent controlled by an Incinerator, the notification would include the site-specific minimum firebox
temperature that will ensure proper operation of the incinerator, and the data and rationale to support
this minimum temperature.
3.5.4 Periodic Reports
Periodic Reports are required to demonstrate that the standards continue to be met and that
control devices are operated and maintained properly. Generally, Periodic Reports would be submitted
semiannually. However, If monitoring data are insufficient or If monitoring results show that the
parameter values for an emission point are outside the established range for more than the excused
number of days specified in §63.152, the Administrator (or delegated regulatory authority) may request
that the owner or operator submit quarterly reports for that emission point. After 1 year, the source can
return to semiannual reporting, unless the regulatory authority requests continuation of quarterly reports.
Periodic Reports specify periods when the daily average values of continuously monitored
parameters are outside the ranges established in the Notification of Compliance Status or operating
permit For some kinds of emission points and controls, periodic (e.g., monthly, quarterly, or annual)
inspections or measurements are required instead of continuous monitoring. Records that such
inspections or measurements were done must be kept; results are included in Periodic Reports only if a
problem is found. Periodic reports may also include information on startups, shutdowns, and
malfunctions if any occurred during the reporting period. Details of the information required are
specified in §63.10(d)(5) of Subpart A.
The first periodic report is due no later than 8 months after the date the notification of
compliance status is due. All other semiannual reports are due no later than 60 days after the end of
each 6 month period. Quarterly reports, if required, are due 60 days after the end of each quarter.
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3.5.5 Other Reports
There are a very limited number of other reports. Where possible, Subpart G Is structured
to allow all information to be reported in the semiannual (or quarterly) Periodic Reports. However, In a
few cases, It is necessary for the source to provide information to the regulatory authority shortly before
or after a specific event. For example, for storage vessels, notification prior to internal tank inspections
is required to allow the regulatory authority the opportunity to have an observer present. The semi-
annual start-up, shutdown, and malfunction reports may be submitted on the same schedule as the
Periodic Reports.
3.6 USE OF CONTINUOUS MONITORING TO DETERMINE COMPLIANCE
This section summarizes the basic approaches for determining compliance for Group 1
emission points where continuous monitoring is required (i.e., process vents and transfer operations).
As described in Sections 5.3 and 6.3 of this manual, performance tests and continuous monitoring of
control device operating parameters are required for most kinds of devices used to control Group 1
process vents and transfer racks. Compliance with the 98 percent reduction or 20 ppmv outlet
concentration requirement is determined by performance testing. Results of the tests are reported in the
Notification of Compliance Status. Continuous parameter monitoring results are not used to determine
compliance with the percent reduction or emission limit; however, monitoring results are used to
determine compliance with operating requirements.
Each source must establish site-specific ranges for monitored parameters that will
demonstrate proper operation of each control device for which continuous monitoring is required.
These site-specific ranges can be set through performance testing supplemented by engineering
assessments and manufacturers' recommendations (The performance test is not required to be
conducted over the entire range of permitted parameter values). The justification for the site-specific
range is included In the operating permit application or Notification of Compliance Status. The ranges
are then Incorporated in the sources' operating permit Each source must continuously monitor and
record the operating parameter(s) for each control device and report any dally average value of an
operating parameter that is outside the established range as well as any days when insufficient
monitoring data are collected. These excursions are reported in the quarterly or semiannual reports
described in Section 3.5.4. If, during a reporting period, a monitored operating parameter is outside the
established range or insufficient data are collected for more than the number of days specified in
§63.152(c) of Subpart G, this is considered a violation of the operating permit requirements.
An owner or operator may request approval to use alternatives to continuous operating
parameter monitoring, as allowed by §63.151 (g) of Subpart G. Continuous monitoring is not required for
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storage vessels or wastewater streams. The compliance determination approaches for storage and
wastewater are described in Sections 7.3.4 and 8.3.4 of this manual, respectively.
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SECTION 4
APPUCABIUTY OF THE RULE
Prior to an inspection, the first step is to determine which chemical manufacturing process units
(CMPU's) are subject to the HON. The second step Is to identify the equipment within those CMPU's.
Next, the source must be designated as a new source or an existing source. The final step in
determining the applicability of the rule Is to determine which emission points within the CMPU satisfy
the HON definitions of process vent, storage vessel, transfer rack, and wastewater stream. This chapter
will explain In more detail the first three steps. The final step of determining applicability to specific
emission points Is addressed in the applicability checklists In sections 5 through 8.
4.1 IDENTIFICATION OF SOCMI PROCESS UNITS
For the HON to apply to a CMPU, the CMPU must meet three criteria. First, the CMPU must be
a SOCMI unit, which means a SOCMI chemical in Table 1 of Subpart F is the primary product made In
the unit Second, organic HAP's regulated by the HON, which are listed in Table 2 of Subpart F, have to
be used as a reactant or manufactured in the CMPU. Finally, the plant site where the CMPU Is located
has to be a major HAP source as defined In Section 112(a) of the Act, i.e., any stationary source or
group of stationary sources located within a contiguous area and under common control that emits or
has the potential to emit, considering controls, in the aggregate, 10 tons per year (tpy) or more of any
hazardous air pollutant or 25 tpy or more of any combination of hazardous air pollutants.
Identification of the primary product of a CMPU may not be obvious. In the chemical
manufacturing industry, most facilities consist of integrated operations involving some combination of
refinery processes, SOCMI processes, polymers and resins processes, agricultural chemical production,
pharmaceutical production, and specialty chemical production. Thus, a CMPU may produce multiple
chemicals Including valuable co-products and materials that will be used as reactants for downstream
units. Also, some CMPU's are designed and operated as flexible operation units, that is, the equipment
Is used to make different chemicals at different times during the year. Determining applicability of a rule
and what equipment is subject to the rule is complex and requires detailed information about the facility
and its operations.
To address this complexity, the rule includes procedures for determining the primary product of
a CMPU. The rule also exempts certain units and equipment from all requirements. Specifically, the
HON does not apply to the following processes:
Research and development facilities, even if they are located at the same plant site as
the CMPU that is subject to the HON;
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Petroleum refining and ethylene process units, even if they supply feedstocks that are
SOCf.'i chemicals to CMPU's that are subject to the HON;
Equipment that is located with a CMPU subject to the HON but does not contain
organic HAP's;
CMPU's located in coke by-product recovery plants; and
Solvent reclamation, recovery, or recycling operations at hazardous waste treatment,
storage, and disposal facilities (TSDF) that are not part of a SOCMI unit.
Table 4-1 is a checklist for determining whether a CMPU is subject to the HON. Table 4-2 contains
questions for determining the primary product and applicability for flexible operation units in particular.
Table 4-3 addresses determination of primary product in ail other cases.
4.2 DETERMINATION OF THE HON SOURCE
The source to which the HON applies is defined as the collection of the following emission
points within SOCMI CMPU's:
Process vents;
Storage vessels;
Transfer racks;
Wastewater and the associated treatment residuals; and
Pumps, compressors, agitators, pressure relief devices, sampling connection systems,
open-ended valves or lines, valves, connectors, instrumentation systems, surge control
vessels, and bottoms receivers (equipment leaks).
However, certain emission points are exempted from the rule. The HON does not apply to the following
points:
Vents from CMPU's that are designed and operated as batch operations;
Stormwater from segregated sewers;
Water from fire-fighting and deluge systems in segregated sewers;
Spills;
Water from safety showers;
Vessels storing organic liquids that contain organic HAP's only as Impurities;
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TABLE 4-1. APPLICABILITY OF THE HON
1. Do total potential emissions at the plant site exceed 10 tpy of an Individual HAP or 25 tpy of a
combination of HAP's?
oY Continue with this checklist
DN The plant site Is not subject to the HON.
2. Is the CMPU a petroleum refining process unit; an ethylene process unit; a solvent reclamation,
recovery, or recycling operation at a hazardous waste TSDF8 facility; an R&D° facility; or a
process unit located in a coke by-product recovery plant?
D Y The CMPU is not subject to the HON.
D N Continue with this checklist.
3. Does the CMPU produce different intended products periodically throughout the year?
D Y The CMPU is a flexible operation unit Skip to Table 4-2 to determine primary product
and applicability.
D N Continue with this checklist
4. Is the primary product of the CMPU, as determined in Table 4-3, a SOCMI chemical (listed in
Table 1 of Subpart F)?
a Y Continue with this checklist
a N The CMPU is not subject to the HON.
5. Does the CMPU use as a reactant or produce as a product co-product, or by-product one of
. the organic HAP's listed in Table 2 of Subpart F?
D Y The CMPU is subject to the HON.
D N The CMPU is not subject to the HON.
a TSDF = Treatment storage, and disposal facility.
b R&D = Research and development
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TABLE 4-2. DETERMINATION OF PRIMARY PRODUCT AND APPLICABILITY
FOR FLEXIBLE OPERATION UNITS3
If the CMPU produces different products periodically, determine:
The product produced for the greatest annual operating time.
If all products are produced for the same amount of operating time, determine:
The product with the greatest annual production on a mass basis.
1. Is the product determined in either case above listed in Table 1 of Subpart F?
D Y The primary product of the CMPU is a SOCMI chemical. Continue with this checklist
D N The primary product of the CMPU is not a SOCMI chemical, and the CMPU is not
subject to the HON.
2. Does the flexible operation unit use as a reactant or manufacture as a product, by-product, or
co-product one or more of the organic HAP's listed in Table 2 of Subpart F?
D Y The CMPU is subject to the HON.b
D N The CMPU is not subject to the HON.
a Determination is based on the expected utilization for the five years following April 22,1994 for existing
sources and the five years after initial start-up for new sources.
b Determination of applicability must be reported in the Implementation Plan or as part of the operating
permit application.
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TABLE 4-3. DETERMINATION OF THE PRIMARY PRODUCT
List the Intended products for the CMPU.
1. Does one of the intended products have the greatest annual design capacity on a mass basis
(e.g., makes up >50% on a mass basis If two products are made)?
D Y This is the primary product of the CMPU.
D N Continue with this checklist.
2. If two or more of the intended products have the same annual design capacity on a mass basis,
are any or all of the products listed in Table 1 of Subpart F?
a Y Any of the products that are listed in Table 1 of Subpart F may be designated the
primary product of the CMPU. Thus, the primary product is a SOCMI chemical. Go to
question 5 on Table 4-1.
a N The primary product is not a SOCMI chemical, and the CMPU is not subject to the
HON.
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Loading racks, loading amis, and loading hoses that only transfer liquids containing
organic HAP's only as impurities;
Loading racks, loading amis, and loading hoses that vapor balance during all loading
operations; and
Equipment that is intended to operate in organic HAP service for less than 300 hours
per calendar year.
In large chemical manufacturing facilities, It is often difficult to determine where one process unit
ends and the next begins. For example, a storage tank may contain a chemical that is the product of
one CMPU and the raw material for another CMPU. A transfer rack may load the products of several
CMPU's, some that are SOCMI and others that are not. Distillation columns may be used to purify a
product for sale or to remove inhibitors and impurities from a raw material. To clarify the applicability of
the HON in these situations, the rule includes procedures for assigning storage vessels, transfer racks,
and distillation columns to the appropriate CMPU. Tables 4-4 through 4-6 are checklists for these
procedures.
4.3 DETERMINATION OF NEW SOURCE VS. EXISTING SOURCE
Once the HON source has been identified, it must be classified as a new or existing source
because the rule contains different requirements for new versus existing sources. Many of these
requirements pertain only to specific kinds of emission points and are therefore discussed in later
sections of this document This section addresses the definitions, MACT requirements, and compliance
dates for new sources, existing sources, and other process changes.
4.3.1 New Sources
A source is subject to the HON's new source MACT requirements if it meets the criteria for a
new source or a reconstructed source. A source would be a new source if all of the following criteria
are true:
An entire CMPU or group of CMPU's is being added (The addition of a single emission
point, e.g., a storage tank, cannot be a new source regardless of the magnitude of
emissions from the tank);
The additional CMPU produces a SOCMI chemical listed in Table 1 of Subpart F and
uses as a reactant or produces an organic HAP listed in Table 2 of Subpart F;
The additional CMPU meets the definition of construction in §63.2 of Subpart A of 40
CFR Part 63 (i.e., fabrication, erection, or installation);
Construction of the additional CMPU started after December 31,1992; and
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TABLE 44. ASSIGNMENT OF STORAGE VESSELS
1. Is the storage vessel used by a single CMPU?
a Y The storage vessel Is assigned to that CMPU. Skip to question 4.
D N Continue With this checklist.
2. Is there a predominant use of the storage vessel?8
a. Is the greatest input into the storage vessel from a CMPU located on the same plant
site?
D Y The storage vessel is assigned to that CMPU. Skip to question 4.
a N Continue with this checklist.
b. Does a CMPU at the same plant site receive the greatest output from the storage
vessel?
a Y The storage vessel is assigned to that CMPU. Skip to question 4.
a N Continue with this checklist.
3. If the storage vessel is shared among CMPU's so that there is no single predominant use, Is at
least one of the CMPU's subject to the HON?
D Y The storage vessel may be assigned to any one of the CMPU's subject to the HON and
the storage vessel is part of the HON source.
D N The storage vessel is not part of the HON source.0
4. Is the CMPU referred to in questions 1, 2a, or 2b subject to the HON?
a Y The storage vessel is part of the HON source.'1
D N The storage vessel is not part of the HON source.b
8 If the predominant use of the storage vessel varies from year to year, applicability of the HON is to be
based on utilization between April 22. 1993 and April 22,1994. This determination must be reported in
the Implementation Plan or in the operating permit application.
b If there is a change in the material stored, applicability of the HON must be reevaluated.
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TABLE 4-5. ASSIGNMENT OF TRANSFER RACKS
1. Is the transfer rack used by a single CMPU?
D Y The transfer rack is assigned to that CMPU. Skip to question 5.
D N Continue with this checklist for each individual loading arm or loading hose.
2. Is the loading arm or loading hose dedicated to the transfer of liquid organic HAP from a single
unit?
a Y The loading arm or loading hose is assigned to that CMPU. Skip to question 5.
D N Continue with this checklist.
3. Does one CMPU provide the greatest amount of the material that is loaded by a loading arm or
loading hose?8
D Y The loading ami or loading hose is assigned to that CMPU. Skip to question 5.
D N Continue with this checklist
4. If the transfer rack is shared among CMPU's so that there is no single predominant use, is at
least one of the CMPU's providing material to the loading ami or loading hose subject to the
HON?
D Y The loading arm or loading hose may be assigned to any of the CMPU's subject to the
HON and the loading arm or loading hose is part of the HON source.
D N The loading arm or loading hose is not part of the HON source.0
5. Is the CMPU referred to in questions 1, 2, or 3 subject to the HON?
D Y The loading rack, loading arm, or loading hose is part of the HON source.'3
D N The loading rack, loading arm, or loading hose is not part of the HON source.&
a If the predominant use of the transfer rack varies from year to year, applicability of the HON is to be
based on utilization between April 22, 1993 and April 22, 1994. This determination must be reported in
the Implementation Plan or in the operating permit application.
b If there is a change in the material loaded, applicability of the HON must be reevaluated.
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TABLE 4-6. ASSIGNMENT OF DISTILLATION UNITS
1. Aromex units
a. Is the distillation unit part of the Aromex unit that produces benzene, toluene, and
xyiene?
D Y Go to question 1 b.
D N Go to question 2.
b. Does the vent stream contain greater than 0.005 weight percent total organic HAP's?
D Y The vents from the distillation unit are part of the HON source.
D N The vents from the distillation unit are not part of the HON source.
2. Hexane units.
a. Is the distillation unit part of the unit that produces hexane?
D Y Go to question 2b.
D N Go to question 3.
b. Does the vent stream contain greater than 0.005 weight percent total organic HAP's?
D Y The vents from the distillation unit are part of the HON source.
D N The vents from the distillation unit are not part of the HON source.
3. Cyclohexane units.
a. Is the distillation unit part of the unit that produces cydohexane?
D Y Go to question 3b.
ON Go to question 4.
b. Does the vent stream contain greater than 0.005 weight percent total organic HAP's?
D Y The vents from the distillation unit are part of the HON source.
D N The vents from the distillation unit are not part of the HON source.
(continued)
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TABLE 4-6. ASSIGNMENT OF DISTILLATION UNITS (continued)
4. Is the distillation unit used by a single CMPU?
D Y The distillation unit is assigned to that CMPU. Skip to question 7.
D N Continue with this checklist.
5. Is there a predominant use of the distillation unit?3
a. Is the greatest input into the distillation unit from a CMPU located on the same plant
site?
D Y The distillation unit is assigned to that CMPU. Skip to question 7.
D N Continue with this checklist.
b. Does a CMPU at the same plant site receive the greatest output from the distillation
unit?
D Y The distillation unit is assigned to that CMPU. Skip to question 7.
D N Continue with this checklist
6. If the distillation unit Is shared among CMPU's so that there is no single predominant use, is at
least one of the CMPU's subject to the HON?
a Y The distillation unit may be assigned to any one of the CMPU's subject to the HON and
the distillation unit is part of the HON source.
a N The distillation unit is not part of the HON source.0
7. Is the CMPU referred to in questions 4, 5a, or 5b subject to the HON?
D Y The distillation unit is part of the HON source.0
a N The distillation unit is not part of the HON source.b
a If the predominant use of the distillation unit varies from year to year, applicability of the HON is to be
based on utilization between April 22,1993 and April 22, 1994. This determination must be reported in
the Implementation Plan or in the operating permit application.
° If there is a change in the material stored, applicability of the HON must be reevaluated.
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The additional CMPU has the potential to emit 10 tpy or more of a single HAP or 25 tpy
or more of any combination of HAP's.
A source would be a reconstructed source if all of the following were true:
Changes to the source meet the definition of reconstruction in §63.2 of Subpart A of
40 CFR Part 63 (i.e., the source is changed to such an extent that the fixed capital cost
of the new components exceeds 50 percent of the fixed capital cost required to
construct a comparable new source); and
The reconstruction started after December 31,1992.
4.3.2 Existing Sources
A source is subject to the HON's existing source MACT requirements if it does not meet the
criteria in Section 4.3.1 for a new source or reconstructed source. Examples of existing sources could
include CMPU's that were already in operation prior to December 31,1992; addition of an individual
emission point such as a storage tank or transfer rack; and addition of a CMPU with emissions below
the 10 tpy/25 tpy threshhold.
4.3.3 Other Process Changes
As is common in any manufacturing facility, chemical plants are characterized by frequent
changes In operations. Cost concerns, market needs, and product improvement efforts mean individual
equipment and often entire process units, may be changed or added to an existing plant site. As
defined in the HON, process changes include, but are not limited to:
Changes in production capacity, feedstock type, or catalyst type; and
Replacement, removal, or addition of recovery equipment
Process changes do not include:
Process upsets;
Unintentional temporary process changes; and
Changes that are within the equipment configuration and operating conditions
documented in the Notification of Compliance Status.
Section 4.3.1 listed the criteria for determining whether additions or changes would be
considered new or reconstructed sources. It is also possible that an addition or change would satisfy
neither set of criteria. If a change did not exceed the 50% fixed capital cost to be a reconstruction or
the 10 tpy/25 tpy emission potential to be a new source, the added or changed equipment might still be
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subject to the HON. For example, an owner or operator may switch from using a non-HAP raw material
to using a HAP as a raw material. Or, a change in catalyst type could increase capacity thereby causing
an increase in emissions above the 10 tpy/25 tpy threshhold. In such cases, if the addition or change
did not satisfy the criteria for new or reconstructed source, but the additions or changes were made to
part of the HON source, the added or changed equipment would be subject to the HON's existing
source MACT requirements.
4.3.4 Compliance Dates
Table 4-7 lists the compliance dates for existing, new, and reconstructed sources arid for
additions or changes that are not subject to new source requirements. For compliance with the
equipment leak provisions in Subpart H, process units have been placed in five groups with different
compliance dates. Group designations are listed in Table 1 of Subpart F.
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TABLE 4-7. COMPLIANCE DATES FOR EXISTING, NEW, AND RECONSTRUCTED SOURCES
I
I
i
Kind of Emission
Point
At Existing Sources
In a New or
Reconstructed Source8
«
Part of a Change or Addition that Is not Subject to
New Source Requirements
Process vents,
storage vessels,
transfer racks, and
wastewater streams
(Subparts F and G)
Existing source MACT by
April 22, 1997 unless an
extension has been granted.
New source MACT
upon Initial start-up or
Aprfl 22, 1994,
whichever Is later.
Existing source MACT upon Initial start-up or by
Aprfl 22, 1997, whichever Is later.
Special case: If a deliberate process change to an
existing CMPU causes a Group 2 point to become
a Group 1 point, the owner or operator may request
a longer compliance schedule In accordance with
§63.100(I)(4)(II)(B) and (m). However, the
compliance date cannot be later than 3 years after
the point becomes Group 1.
CO
Equipment leaks
(Subparts F & H)
Existing source MACT by the
following dates:
Group I: October 24, 1994;
Group II: January 23, 1995;
Group III: April 24, 1995;
Group IV: July 24, 1995; and
Group V: October 23, 1995.
New source MACT
upon Initial start-up or
by Aprfl 22, 1994,
whichever Is later.
Existing source MACT upon Initial start-up or by
April 22, 1997, whichever Is later.
a Sources constructed or reconstructed after December 31, 1992.
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SECTION 5
PROCESS VENTS
5.1 DESCRIPTION OF EMISSION POINT
A chemical manufacturing process consists of reactors, recovery units, or a combination of
the two. The design of a process wDI vary at each facility depending on the product, the type of
process, and the design capacity. Therefore, each process will have a different number, type, and
configuration of process vents.
Manufacture of organic chemicals may involve conversion and separation processes.
Reactor and air oxidation processes are conversion processes involving chemical reactions that alter the
molecular structure of chemical compounds and form one or more new compounds. An air oxidation
process uses air, or a combination of air and oxygen, as an oxygen source in a chemical reaction.
Separation processes are used to produce or recover a product from a mixture and are often used
following a conversion process. Distillation, stripping, absorption, adsorption, filtration, crystallization,
and extraction are all separation processes which divide chemical mixtures into distinct fractions, such
as products and by-products. All of these processes have potential emission points. The process vent
provisions of the hazardous organics NESHAP (HON) and the SOCMI distillation, air oxidation, and
reactor processes NSPS* focus primarily on vents from reactor and air oxidation processes and
distillation operations. They cover both vent streams emitted directly from these operations, as well as
vent streams that are emitted indirectly (e.g., through a recovery device).
Reactor processes.may involve liquid-phase or gas-phase reactions. Gas-phase reactions
usually have at least one recovery device used to produce a liquid product Reactors may have an
atmospheric vent, may vent to one or more recovery devices, or both. Also, any vent from a reactor or
recovery device may vent to a combustion device. Figure 5-1 shows four vent types, including:
(A) Direct reactor process vents from liquid-phase reactors;
(B) Process vents from recovery devices applied to vent streams from liquid phase
reactors;
(C) Process vents from gas-phase reactors after a recovery device;
(D) Process vents from combustion devices applied to vent types A, B, and C.
These four diagrams represent only a few of the possible vent configurations. For example,
a reactor may have both A and B type vents, or multiple type B vents.
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(A)'Liquid-Phase Reactor
Gas
(C) Gas-Phase Reactor
Gas
Vent Type A
(B) Product/By-Product
Recovery Device
Liquid
Vent Type B
Recovered
Product
Uquid
Gas
Vent Type C
Liquid
(D) Process Vents Controlled by Combustion
Process Vent Streams
from A, B, or C
Gas
Vent Type D
Combustion
C
Figure 5-1. Examples of Reactor-Related Vents
5-2
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Air oxidation reactor processes vent large .quantities of vapors with low concentrations of
volatile organic compounds (VOC's) because large quantities of air or air enriched with oxygen act as
the oxidizing agent In the process. Because of the increased air flow, these vents are typically larger In
size. An air oxidation process typically occurs In a reactor over a catalyst bed, followed by a
condensation/extraction process which is usually vented to the atmosphere.
Distillation Is the most widely used separation process and has the potential to release
larger amounts of VOC's and hazardous air pollutants (HAP's) from multiple emission points than other
separation processes. Distillation processes occur at various temperatures and pressures and require
varying numbers of distillation stages. Six potential emission points for atmospheric and vacuum
distillation columns are shown in Figures 5-2 through 5-4. These emission points can include vents on:
(1) condensers, (2) overhead receivers, (3) hot wells, (4) steam jet ejectors, (5) vacuum pumps, and
(6) pressure relief valves. Strippers are a type of fractionating distillation column and will have emission
points similar to those shown in Figures 5-2 through 5-4. [It should be noted that emissions from
hotwells are subject to the wastewater provisions of the HON rather than the process vent provisions
because the emissions result from a contaminated stream.1]
5.2 DESCRIPTION OF EMISSION CONTROL TECHNOLOGIES
Combustion is the most universally applicable technique for control of organic HAP and
VOC emissions from process vents. Combustion devices can be applied to reactor, air oxidation, and
distillation process vents, and can achieve efficiencies of 98 percent reduction in organic HAP or VOC
emissions, or an outlet HAP or VOC concentration of 20 parts per million by volume (ppmv) dry basis,
corrected to 3 percent oxygen. Combustion control devices are described In Section 5.2.1.
As described in Section 5.1, recovery devices are used in many chemical manufacturing
processes. The most common types of recovery devices are described In Section 5.2.2. Recovery
devices are not considered 'control devices" for purposes of meeting the 98 percent reduction
requirements of the process vents provisions of the HON. However, the HON allows the use of recovery
devices to achieve compliance if certain conditions are met. If a recovery device is used to increase the
total resource effectiveness (TRE) index value to greater than 1.0, then the process vent is considered to
be in compliance. The TRE Is an index of the cost effectiveness of control and is calculated from
measurements or estimates of vent stream flow and HAP and VOC concentrations after the final
recovery device. Information on the specific compliance options for process vents, including the use
and calculation of TRE index values, is presented in Section 5.3.3.
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Vent to Atmosphere
Vapor Phase
Liquid Reflux
Pressure Relief
Valve (6)
Overhead Receiver
(2)
Overhead Product
Distillation
Column
Figure 5-2. Potential VOC and HAP Emission Points for an
Atmospheric (Nonvacuum) Distillation Column
tr
|
5-4
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Steam
Steam Jet
Ejector (4)
Pressure Relief
Valve (6)
Overhead Receiver
(2)
Cooling
Water (CW)
Overhead Product
Steam
Steam Jet
Ejector (4)
Barometric
Condenser
Distillation
Column
Vent
Wastewater (3) Hot well
Vent
(3) Hot well Wastewater
Figure 5-3. Potential VOC and HAP Emission Points for
a Vacuum Distillation Column Using Steam Jet
Ejectors With Barometric Condenser
OC
8
S
5-5
-------
Vapor Phase
Condenser (1)
Vent
Vacuum Pump (5)
Overhead Receiver (2)
Liquid Reflux
Overhead Product
Distillation
Column
Figure 5-4. Potential VOC and HAP Emission Points for a
Vacuum Distillation Column Using a Vacuum Pump
s
s
s
5-6
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5.2.1 Combustion Control Devices
Combustion control devices include incinerators, flares, boilers, and process heaters.
Combustion control devices operate on the principle that any VOC heated to a high enough temperature
in the presence of sufficient oxygen will oxidize to carbon dioxide and water. The theoretical
combustion temperature varies because VOC's are oxidized at different temperatures, depending on
their properties. A consistent VOC destruction efficiency can usually be achieved in combustion devices,
regardless of the amount and type of VOC in the vent stream. Scrubbers can be used downstream of
combustion control devices (other than flares) to treat halogenated streams. Scrubbers reduce
emissions of halogens and hydrogen halkles, such as chlorine and hydrogen chloride, formed during
combustion.
5.2.1.1 Thermal Incinerators
Thermal incinerators are usually refractory-lined chambers containing a burner (or set of
burners). An efficient thermal incinerator provides: (1) a chamber temperature high enough to
completely oxidize the VOC's; (2) sufficient mixing of combustion products, air, and the process vent
streams; and (3) sufficient residence time to allow for complete oxidation of VOC's. Figure 5-5 shows
the premixing chamber and combustion chamber of a discrete burner thermal incinerator. As shown in
the figure, heat can be recovered to preheat combustion air or the process vent stream, or to generate
steam. Figure 5-6 shows a distributed burner thermal incinerator which uses less fuel and has a shorter
reaction chamber than a discrete burner thermal incinerator. All thermal incinerators operate using
excess air to ensure a sufficient supply of oxygen.
Thermal incinerators can achieve at least 98 percent destruction for most VOC's. For vent
streams with VOC concentrations below 2,000 ppmv, all new thermal incinerators can achieve outlet
concentrations of 20 ppmv or lower. Thermal incinerators are technically feasible control options for
most vent streams. Excessive fluctuations in flow rate may prevent the use of a thermal Incinerator; in
such situations, a flare could be used.
5.2.1.2 Catalytic Incinerators
Catalytic incinerators operate at lower temperatures than thermal incinerators because some
VOC's are oxidized at lower temperatures in the presence of a catalyst A schematic of a catalytic
incinerator is shown In Figure 5-7. The vent stream is preheated in the mixing chamber, and oxidation
takes place on the catalyst bed. As with thermal incinerators, heat can be recovered from the exiting
gas stream.
Catalytic incinerators can achieve overall VOC destruction efficiencies of 95 to over
98 percent. The efficiency depends on temperature, oxygen content, catalyst activity, and the
characteristics and concentration of the VOC. Catalytic incinerators are typically used for vent streams
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Stack
Vent Stream
Inlet
(2)
Auxilliary
Burner
(Discrete)
(D
Optional Heat
Recovery
(6)
V
Combustion
Chamber
(5)
Figure 5-5. Discrete Burner, Thermal Incinerator
5-8
-------
Stack
Vent
Stream
Inlet
Incinerator Chamber (3)
Burner Plate
121
x
Flame Jets
'"
J
Auxiliary Fuel
(Natural Gas)
Optional Heat
Recovery
(4)
Figure 5-6. Distributed Burner, Thermal Incinerator
5-9
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Auxiliary
Burners
(3)
Vent Stream
0) -
Auxiliary
Burners
Catalyst Bed
/ w
Mixing Chamber
(2)
To Atmosphere
Stack
r
Waste Heat
Recovery (Optional)
Figure 5-7. Catalytic Incinerator
5-10
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with stable flow rates and stable concentrations. They cannot be used on vent streams that poison or
block the catalyst reactive sites, or on vent streams with high inlet concentrations or flow rates.
5.2.1.4 Industrial Boilers and Process Heaters
Industrial boilers and process heaters combust VOC's by incorporating the vent stream into
the inlet fuel or by feeding the vent stream into the boiler or heater through a separate burner. Industrial
boilers are used to produce steam. When boilers fire natural gas, forced- or natural-draft burners mix
the incoming fuel and combustion air. A VOC-containing vent stream can be added to this mixture or it
can be fed into the boiler through a separate burner. The majority of industrial boilers used in the
chemical industry are of watertube design, where hot combustion gases contact the outside of heat
transfer tubes which contain hot water and steam. Process heaters are used to raise the temperature of
process streams using a similar tube design, where the process fluids are contained in the tubes. Heat
recovery from the exiting gas stream is achievable for both industrial boilers and process heaters.
Boilers and process heaters can achieve efficiencies of at least 98 percent. They can be
used to reduce VOC emissions from any vent streams that will not reduce the performance or reliability
of the boiler or process heater. For example, the varying flow rate and organic content of some vent
streams can lead to explosive mixtures or flame instability. Boilers and process heaters are most
applicable where the potential exists for heat recovery from the combustion of the vent stream. Vent
streams with a high VOC concentration and high flow rate can provide enough equivalent heat value to
act as a substitute for fuel. Because boilers and process heaters cannot tolerate wide fluctuations in the
fuel supply, they are not widely used to reduce VOC emissions from batch operations and other
noncontinuous vent streams. Vent streams with sulfur or halogenated compounds are not usually
combusted in boilers or process heaters because these streams are corrosive.
5.2.1.4 Flares
Raring is an open combustion process In which the oxygen necessary for combustion is
provided by the air around the flame. High combustion efficiency in a flare is governed by flame
temperature, residence time of the organic compound in the combustion zone, turbulent mixing to
complete the oxidation reaction, and the amount of available oxygen. Steam-assisted elevated flares are
the most common type used in the chemical industry (see Figure 5-8). The high flow rate of the vent
stream into the flare requires more combustion air than diffusion of the surrounding air to the flame can
supply. Steam injection nozzles are added to increase gas turbulence.
Flares can achieve 98 percent destruction efficiencies. Rares are most applicable to vent
streams with wide flammability limits, low auto-ignition temperatures, and high heat contents. Rares can
be designed to control both normal process releases and emergency upsets. Rares can be used to
control almost any VOC stream and can handle fluctuations in VOC concentration, flow rate, heat
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Combustion Zone
(10)
Steam Nozzles
(9)
Flare Tip
(8)
Pilot Burners
(7)
Gas Barrier
(6)
Gas Collection Header
(1)
I r\
Vent Stream-»
Knockout
Drum
(2)
1 Steam Line
Ignition
Device
Air Line
Gas Line
Drain
Figure 5-8. Steam-Assisted Elevated Flare System
5-12
s.
S
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content, moisture content, and inerts content. Raring is appropriate for continuous, batch, and variable
flow vent streams. However, halogenated or sulfur-containing vent streams are usually not flared
because they can corrode the flare tip or cause the formation of acid gases or sulfur dioxide. The HON
provisions do not allow vent streams above a specified halogen content to be routed to a flare.
5.2.1.5 Halogenated Streams
Combustion equipment used for control of halogenated streams is usually followed by
additional control equipment to remove corrosive combustion products (acid gases). The flue gas
temperature is lowered, and the flue gas is then routed to a scrubber such as a packed tower or liquid
jet scrubber. Absorption equipment (e.g., scrubbers) can also be used as recovery devices and are
discussed in Section 5.2.2 of this manual.
5.2.2 Product Recovery Devices
Product recovery devices include absorbers, carbon adsorbers, and condensers, and the
specific device used is determined by the vent stream characteristics. These characteristics affect the
performance of recovery devices, therefore no single recovery technology is applicable to all process
vent streams.
5.2.2.1 Condensers
Condensation is a separation technique in which one or more volatile components are
separated from a vapor mixture through saturation followed by a phase change. Condensation can be
achieved by lowering the temperature at a constant pressure, and refrigeration can be used to obtain the
lower temperatures needed for compounds with lower boiling points.
Surface condensers and direct contact condensers are the two most commonly used types.
A typical configuration for a refrigerated surface condenser is shown in Figure 5-9. In surface
condensers, heat transfer occurs through tubes or plates in the condenser. Thus, the coolant fluid does
not contact the vent stream which allows for reuse of the coolant fluid. Furthermore, the VOC's can be
directly recovered from the gas stream. A shell-and-tube condenser which circulates the coolant fluid on
the tube side Is shown in Figure 5-10. Plate-type heat exchangers separate the coolant and vent stream
by thin, flat plates. Direct contact condensers spray the coolant directly into the vent stream. Therefore,
the coolant cannot be reused directly and VOC's cannot be recovered without further processing.
Precoolers may be necessary to remove moisture from the vent stream before the vent
stream enters the condenser. A recovery tank for temporary storage of condensed VOC may be
necessary, along with pumps and blowers.
Condensers may be used to recover raw materials and/or products. The removal
efficiencies of condensers range from 50 to 95 percent, and the efficiency is dependent upon the vent
stream flow rate, concentration, temperature, moisture content, and physical properties. Condensers are
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Discharge
from
System
Hot Gas
Stream
Cooler Gas Stream
Main
Condenser
Unit
Liquid Stream
(primarily VOC)
Liquid
Stream
(water and
*
Precooler
Refrigeration
Unit
(contains
primary
refrigerant
in closed
loop)
Secondary Refrigerant Loop'
(coolant)
Main
Refrigeration
Unit
(contains
primary
refrigerant
in closed
loop)
cc
in
oo
in
Figure 5-9. Refrigerated Surface Condenser System for VOC Vapor Recovery
-------
V
^
en
Coolant
Inlet
Coolant
Outlet
Vapor
Outlet
Vapor
Inlet
Condensed
VOC
Figure 5-10. Schematic Diagram of a Shell and Tube Surface Condenser
s
§
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more economically feasible for streams with higher condensation temperatures. Vent streams with high
concentrations of non-condensables will require a condenser with a larger surface area.
5.2.2.2 Adsorption
Adsorption is a mass-transfer operation where the gas-phase (adsorbate) is captured on the
solid-phase (adsorbent) by physical or chemical means. A physically adsorbed molecule is easily
removed from the adsorbent, whereas, the removal of chemisorbed molecules is much more difficult.
The most common industrial adsorption systems use activated carbon as the adsorbent
Activated carbon captures organic vapors by physical adsorption. Since oxygenated adsorbents
selectively capture water vapor, they are not suitable for high-moisture process vent streams. Activated
carbon beds are regenerated with steam or nitrogen which release the captured vapors. Figure 5-11
shows a typical fixed-bed, regenerative carbon adsorption system. When one bed is saturated, the vent
stream is routed to an alternate bed while the saturated carbon bed is regenerated. The steam-laden
vapors from regeneration are sent to a condenser and then to a VOC recovery system to separate the
VOC's from the condensed steam.
Continuous VOC removal efficiencies of more than 95 percent are achievable using
adsorption. The VOC removal efficiency of an adsorption unit depends on the vent stream
characteristics, the physical properties of the compounds in the vent stream and of the adsorbent, and
the condition of the bed. Carbon adsorption is not recommended for vent streams with high VOC
concentrations, high or low molecular weight compounds, mixtures of high and low boiling point VOC's,
or vent streams with a high moisture content.
5.2.2.3 Absorption
Absorption is the selective transfer of one or more components of a gas mixture (solute)
into a liquid solvent Devices based on absorption principles Include spray towers, Venturi and wet
impingement scrubbers, packed columns, and plate columns. Spray towers have the least effective
ma transfer capability and are generally restricted to paniculate matter removal and control of high-
sot rcy gases. Venturi scrubbers are also limited to paniculate matter and high-solubility gases.
Therefore, VOC control by gas absorption is limited to packed or plate columns.
Packed towers are vertical columns containing Inert packing that provides surface area for
contact between the liquid and gas phases. A counter-current packed column is shown in Figure 5-12.
Packed columns are used primarily for corrosive materials and liquids with tendencies to foam or plug.
They are less expensive than plate columns when the column diameter is small and more suitable where
pis'3 columns would result in large pressure drops. The vent stream and saturated liquid from a packed
c - may require further treatment.
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VOC-Laden
Vent Stream
(1)
Fan
Low
Pressure (4)
Steam
Closed
Open
Adsorber 1
(adsorbing)
Steam
Adsorber 2
(regenerating)
Open
Closed
(5)
Condenser
Vent to
Atmosphere
Decanter and/or
Distilling Tower
(6)
Recovered
Solvent
Water
Figure 5-11. Two-Stage Regenerative Adsorption System
5-17
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Absorbing
Liquid In
(5) Cleaned Gas Out
to Final Control Device
or to Atmosphere
(3)
Packing (2)
Packing Support
(1) VOC-Laden
Gas In
Absorbing Liquid
with VOC out to Disposal
or VOC/Solvent Recovery
(T
s
Figure 5-12. Packed Tower Absorption Process
5-18
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In plate or tray columns, contact between the liquid and gas phases takes place on a series
of trays. These columns are preferred for large-scale operations, where internal cooling is desired or
where'low liquid flow rates would inadequately wet the packing.
Control efficiencies for absorbers vary from 50 to greater than 95 percent. Efficiency
depends on the selected solvent, the contact surface area (absorber size), and the temperature. The
applicability of absorption to vent streams is dependent on the availability of a suitable solvent, and the
solubility of the VOC in the solvent. If a VOC cannot be easily desorbed from the solvent, then
absorption Is less viable. Absorption is usually considered for streams with a VOC concentration above
200 to 300 ppmv.
Scrubbers are used downstream of combustion devices to control emissions of halogens
and halogen halkJes formed during combustion. The typical scrubbing solvents used are water or a
caustic solution. Either plate or packed bed scrubbers can be used, and these scrubbers can have
counter-current or crosscurrent flow. The type and orientation of the scrubber used depends on liquid
and gas flow rates.
Scrubber efficiencies for removal of halogens and halogen halides will vary depending on
the type of scrubber and the type of solvent used, and the equilibrium relationship between the gas and
liquid. However, most systems can achieve efficiencies from 90 percent to greater than 99 percent.
5.3 PROCESS VENT PROVISIONS
This section summarizes the process vent provisions in §63.113 through §63.118 of
Subpart G.
5.3.1 Process Vent Definition
For purposes of the HON, a "process vent* is a gas stream containing greater than
0.005 weight percent total organic HAP that is continuously discharged during operation of the unit from
an air oxidation reactor, other reactor or distillation unit within a chemical manufacturing process unit
that meets all applicability criteria in §63.100 of Subpart F. This includes vents from distillate receivers,
product separators associated with reactors, and ejector-condensers. Process vents Include gas
streams discharged directly to the atmosphere and those that are discharged to the atmosphere after
diversion through a product recovery device. Relief valve discharges are not process vents.
5.3.2 Process Vent Group Determination
Group 1 and Group 2 process vents are defined in §63.111 of Subpart G, based on the vent
stream total resource effectiveness (TRE) index value. The TRE index value Is a measure of the
supplemental total resource requirement per unit reduction of organic HAP associated with a process
vent stream. The TRE index value is a cost-effectiveness index, associated with an individual process
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vent stream and is dependent on the process vent flow rate, net heating value, total organic compounds
(TOO) emission rate, and HAP emission rate. Equations that must be used to calculate the TRE index
value for a process vent stream are provided in Appendix C. The coefficients used in the equation to
calculate the TRE index value are different for process vents at new and existing sources. If the TRE
index value is 1.0 or less, the vent is a Group 1 vent
Table 5-1 is an applicability and group determination checklist for process vents. Section I
of the table presents a set of true/false statements which can be used to determine if a process vent is
subject to the process vent provisions of the HON. Section II of Table 5-1 can be used to determine if
a process vent that is subject to the process vent provisions of the HON is Group 1 or Group 2.
Process vents that are not subject to the process vent provisions may be subject to the equipment leak
provisions in Subpart H (NESHAP for SOCMI equipment leaks) or the wastewater provisions in
Subpart G, as noted in the checklist Group 1/Group 2 determinations are required for each process
vent stream that is subject to the process vent provisions, unless the process vent is already in
compliance with the Group 1 requirements (98 percent reduction, 20 ppmv outlet concentration, or flare
control).
5.3.3 Process Vent Control Requirements
Group 1 process vents must meet the control requirements in §63.113 of Subpart G unless
they are included in an emissions average. Compliance options for Group 1 process vent streams
include:
Reducing emissions of organic HAP's using a flare meeting the specification in
§63.11(b) of Subpart A (the NESHAP General Provisions);
Reducing emissions of total organic HAP or TOO by 98 weight percent or to an
exit concentration of 20 parts per million by volume, whichever is less stringent
(product recovery devices are considered part of the process and cannot be
included in determining compliance with this option); or
Achieving and maintaining a TRE index value greater than 1.0 (e.g., by process
modification or a product recovery device).
If a process vent stream with a mass rate of total hydrogen halides and halogen atoms
greater than 0.45 kilograms per hour is combusted, a control device must be installed following the
combustion device to reduce emissions of halogens and hydrogen halides. Control devices installed
after December 31,1992, must reduce overall emissions of halogens and hydrogen halides by
99 percent or reduce the outlet mass of total hydrogen halides and halogens to less than 0.45 kilograms
per hour, whichever is less stringent Control devices installed prior to December 31,1992 must reduce
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TABLE 5-1. APPLICABILITY AND GROUP DETERMINATION
CHECKUST FOR PROCESS VENTS
Process Vents Applicability
a. The vent stream is discharged from a chemical To FD
manufacturing process subject to the HON.
b. The vent is a gas stream containing greater than T D F D
0.005 weight percent HAP.
c. The vent stream is continuously discharged (the vent is T a Fa
not associated with a batch process).
d. The vent stream is from a reactor or air oxidation T D F D
reactor or distillation unit, or from a product separator,
distillate receiver, or ejector condenser that is
associated with a reactor, air oxidation reactor, or
distillation unit,8 and is either:
(1) Discharged directly to the atmosphere; or
(2) Discharged indirectly through a recovery
device.
e.
The vent is not a pressure relief device.0 To F D
f. The vent is not from a recovery device installed to To F n
control emissions from wastewater treatment
operations.0
g. The vent is not an equipment leak as defined in To Fa
Subpart H.b
Is the vent subject to the HON process vent provisions?
D Yes: If all of the statements above are true, the vent
is subject to the process vent provisions in
Subpart G of the HON.
D No: If any of the statements above are false, the
vent Is not subject to the process vent
provisions in Subpart G of the HON.
(Continued)
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TABLE 5-1. APPLICABILITY AND GROUP DETERMINATION
CHECKLIST FOR PROCESS VENTS
II. Process Vents Group Determination^*6
(Complete this portion only If the answer to Section I Is
yes-.)
a. The flow rate of the vent stream is _>. 0.005 scmm. To FD
b. The HAP concentration of the vent stream is _>. To Fa
50 ppmv.
c. The THE index value of the vent is .< 1.0.f To FD
Is the process vent Group 1?
a Yes: The process vent is Group 1 if all of the above
statements are true.
D No: The process vent Is Group 2 if any of the above
statements are false.
a The terms reactor, air oxidation reactor, distillation unit, product separator, and distillate receiver are
defined in §63.101 of subpart F.
b If false, the emission point is not subject to the process vents provisions of Subpart G, but may be
subject to the equipment leak provisions in Subpart H of the HON.
c If false, the emission point Is not subject to the process vents provisions, but may be subject to the
wastewater provisions in Subpart G of the HON.
d Group 1 vents must meet the control requirements in §63.113 of Subpart G, unless they are
Included in an emissions average. Group 2 vents are not required to apply additional controls.
6 If an owner/operator complies with the 98 percent reduction, 20 ppmv, or flare control provisions in
§63.113, group determination is not required.
' The coefficients used in the equation to calculate the TRE index value are different for process vents at
new and existing sources. See Appendix C.
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overall emissions of halogens and hydrogen halides by 95 percent or reduce the outlet mass of total
hydrogen halides and halogens to less than 0.45 kilograms per hour, whichever is less stringent.
' A control device may be used to reduce the vent stream halogen atom mass emission rate
to less than 0.45 kilograms per hour prior to any combustion control device, and thus make the vent
stream nonhalogenated. Rares cannot be used to control halogenated process vent streams.
If a boiler or process heater is used to comply with the 98 percent reduction or 20 ppmv
outlet concentration, then the vent stream must be introduced into the flame zone of the control device.
If an owner or operator elects to achieve and maintain a TRE index value greater than 1.0,
the vent would become a Group 2 vent and must comply with the provisions for Group 2 vents.
Group 2 vents are not required to apply any additional emission controls, however, they are subject to
certain monitoring, reporting, and recordkeeping requirements to ensure that they were correctly
' determined to be Group 2 and that they remain Group 2.
5.3.4 Process Vent Testing. Monitoring. Recordkeeplnq. and Reporting
Procedures for determining group status of vents, including test procedures and TRE
equations, are contained in §63.115 of Subpart G. Performance test procedures are specified In
§63.116. The initial performance testing and initial reporting and recordkeeping requirements for process
vents that are controlled with an incinerator, boiler, process heater, or flare are outlined in Table 5-2.
Note that compliance can be demonstrated by measuring either HAP or TOO emissions. Initial testing,
reporting, and recordkeeping requirements for scrubbers used downstream of a combustion device used
to control halogenated streams are also shown in Table 5-2. A performance test is not required for
flares. However, a compliance determination by visible emissions observation is required.
Performance tests are not required for boilers and process heaters with a design heat input
capacity of 44 Megawatts or greater or for boilers or process heaters where the vent stream is
introduced with the primary fuel. A boiler or process heater burning hazardous waste which is permitted
under 40 CFR Part 270 (the RCRA hazardous waste permit program) and is in compliance with 40 CFR
Part 266 Subpart H (standard for hazardous waste burned in boilers and industrial furnaces) also does
not require a performance test.
Table 5-3 shows the group determination, reporting and recordkeeping requirements for
Group 2 process vent streams. As shown in Table 5-1, a Group 2 vent may be classified Group 2 on the
basis of flow, concentration, or TRE index value. If the TRE index value is less than 4.0, the TRE index
value calculation must be based on the test measurement parameters summarized in Table 5-3. If the
TRE index value is expected to be greater than 4.0, then the parameters (e.g., flow and concentration)
used in the TRE index value calculation may be estimated using engineering assessments instead of a
test.
pJs|13S/sect-S.pv
9/26/94 5-23
-------
TABLE 5-2. PROCESS VENTS INITIAL PERFORMANCE TEST AND RECORDKEEPING AND
REPORTING FOR COMPLIANCE DETERMINATION
s
to
Control devices
which require a
performance test
Thermal Incinerator;
Catalytic Incinerator
or
Boiler or process heater
with design heat Input
capacity less than
44 megawatts and the
vent stream Is not
mixed with the primary
fuel
Test parameters
Test Methods
(1) Percent reduction of
organic HAP or TOCb If
complying with
98 percent reduction In
§63.113(a)(2).
or
The outlet concentration
of HAP or TOCD In
ppmv If complying with
20 ppmv limit In
§63.113(a)(2).
(2) Sampling Sites
Location
(3) Volumetric Row Rate
(4) Oxygen Concentration
(1) Method 18 or any
method validated by
Method 301
(2) Method 1 or 1A
(3) Method 2, 2A, 2C, 2D
(4) Method 3B
Recordkeeplng/Reportlng8
(A) Record and report the
percent reduction of organic
HAP or TOCb or the outlet
concentration of HAP or
TOC1 In ppmv
(B) Record and report the value
of the appropriate monitored
operating parameter(s)
shown on Table 5-4,
averaged over the time
period of the performance
test
(C) For boilers and process
heaters, record and report
the location at which the
vent stream Is Introduced
(Continued)
-------
TABLE 5-2. PROCESS VENTS INFTIAL PERFORMANCE TEST AND RECORDKEEPING AND
RETORTING FOR COMPLIANCE DETERMINATION
Control devices
which require a
performance test
Scrubber for
halogenated vent
streams
V
to
Ul
Test parameters
Test Methods
(1) Percent reduction of
total halogens and
hydrogen halkjes If
complying with the
appropriate reduction
requirements In
§63.113(c)(1)
or
Outlet mass of total
hydrogen nalkJes and
halogens to less than
0.45 kilograms per hour
(1) Method 26 or 26A or
any method validated
by Method 301
Recordkeeplng/Reportlng8
(A) Record and report the
percent reduction of
halogens and hydrogen
halkJes or the concentration
of each Individual
compound at the outlet
Rare (no performance
test Is required to
determine percent
emissions reduction or
outlet HAP or TOC
concentration)
(1) Visible emissions
(1) Method 22
(A) Record and report all visible
emission readings, heat
content, flow rate, and exit
velocity
(B) Record and report all
periods during the
compliance determination
when the pilot flame Is
absent
(C) Record and report flare
design
(Continued)
-------
TABLE 5-Z PROCESS VENTS INITIAL PERFORMANCE TEST AND RECOflDKEEPING AND
REPORTING FOR COMPLIANCE DETERMINATION
Control devices
which require a
performance test
All Control Devices
Test parameters
Test Methods
(1) Halogen concentration
(1) Method 18C
Recordkeeplng/Reportlng9
(A) Record and report the
halogen concentration In the
vent stream
a Reported Information must be Included In the Notification of Compliance Status discussed In Section 3.5.3 of this manual and In §63.152 of
Subpart G.
b TOC = Total organic compounds.
c The owner or operator may also use process knowledge to determine that no halogens or hydrogen halldes are present or may use
engineering assessment to calculate concentration.
01
-------
TABLE 5-3. INITIAL GROUP DETERMINATION AND RECORDKEEPING AND REPORTING REQUIREMENTS
FOR GROUP 2 PROCESS VENTS8
Type of vent stream
Process vent stream
with a TRE Index value
greater than 1 .0 but
less than 4.0
Process vent stream
with a TRE Index value
greater than 4.0
Process vent stream
with a flow rate less
than 0.005 standard
cubic meter per minute
Test parameters Test Methods
(1) Volumetric Row Rate (1) Method 2, 2A, 2C, 2D
(2) Molar composition of the (2) Method 18
vent stream
(3) Concentration of carbon (3) ASTM Method
monoxide and hydrogen D 1946-77
(4) Concentration of water
vapor (4) Method 4
(5) Total halogen concentration
(5) Method 18
None None
(1) Sampling sites - location (1) Method 1 or 1A
(2) Volumetric flow rate (2) Method 2, 2A, 2C, 2D
Recordkeeplng/Reportlngb
(A) Record and report the
measurements and
calculations performed
to determine the TRE
Index value
(B) If an absorber,
condenser, or adsorber
Is used, record and
report the value of the
appropriate monitored
operating parameter(s)
shown on Table 5-5 and
averaged over the time
period of the flow rate
and concentration
measurements
(A) Record and report any
measurements,
engineering
assessments, and
calculations performed
to determine the TRE
Index value
(A) Record and report the
flow rate measurement
o»
to
(Continued)
-------
TABLE 5-3. INITIAL GROUP DET
'NATION AND RECORDKEEPING AND REPORTING REQUIREMENTS
r OR GROUP 2 PROCESS VENTS8
Type of vent stream
Process vent stream
with a organic HAP or
TOC concentration less
than 50 parts per million
by volume
All process vent
streams with a TRE
Index value greater
than 1.0
Test parameters
(1) Sampling sites - location
(2) The outlet concentration of
HAP or TOC
(1) Halogen concentration
Test Methods
(1) Method 1 or 1A
(2) Method 18 or 25A or
any method validated
by Method 301 c
(1) Method 18d
Recordkeeplng/Reportlngb
(A) Record and report the
organic HAP or TOC
concentration
measurement
(A) Record and report the
halogen concentration In
the vent stream
V
ro
CO
a A Group 2 vent may be determined by demonstrating any of three criteria: TRE > 1.0; flow rate < 0.005 scmm; or HAP or TOC concentration
< 50 ppmv. For example, If the flow rate Is < 0.005 scmm, the TRE Index value need not be calculated. Test methods
for each criterion are shown In the table.
b Reported Information Is Included In the Notification of Compliance Status discussed In Section 3.5.3 of this manual and In §63.152 of
Subpart G.
c If Method 25A Is used, the calibration gas must be a single organic HAP compound present at greater than 50 percent by volume.
Method 25A must show that the concentration of TOC Is below 25 ppmv for the process vent to be Group 2.
d The owner or operator may also use process knowledge to determine that no halogens or hydrogen halkJes are present or may use
engineering assessment to calculate concentration.
-------
Monitoring provisions for process vents are contained in §63.114 of Subpart G. Continuous
monitoring, recordkeeping, and reporting requirements for complying with the 98 percent reduction
requirement or 20 ppmv outlet concentration are presented in Table 5-4. Continuous monitoring,
recordkeeping, and reporting requirements for maintaining a TRE index value greater than 1.0 and less
than or equal to 4.0 are presented In Table 5-5. Any boiler or process heater In which all vent streams
are introduced with the primary fuel or where the design heat Input capacity is greater than or equal to
44 Megawatts is exempt from monitoring requirements. Hazardous waste boilers that are permitted
under 40 CFR Part 270 and are in compliance with 40 CFR Part 266 do not have continuous monitoring
requirements. Monitoring Is also not required for process vents with a TRE index value greater than 4.0,
a flow rate less than 0.005 standard cubic meters per minute, or a concentration less than 50 ppmv.
For each parameter monitored according to Tables 5-4 and 5-5, the owner or operator must
establish a site-specific range for the parameter that indicates proper operation of the control or
recovery device. If an owner or operator uses a control device or recovery device other than those
listed In Tables 5-4 and 5-5, or wishes to monitor parameters other than those specified in Tables 5-4
and 5-5, the owner or operator must submit a description of. and rationale for, the planned monitoring,
recordkeeping and reporting in the Implementation Plan discussed in Section 3.5.2 or the operating
permit application.
For Group 2 process vents, any process changes which can cause a change in the TRE
index value, the flow rate, or the outlet concentration must be reported. Any recalculation or
remeasurement of the parameter(s) used to determine Group 2 status, TRE index value, flow rate, or
outlet concentration, must also be reported. If the process change causes the flow rate to increase to
0.005 standard cubic meter per minute or the HAP concentration to increase to 50 ppmv, a TRE index
value calculation must be performed if either of these parameters are used to determine Group 2 status.
5.4 PROCESS VENT INSPECTION PROCEDURES
Table 5-6 presents a checklist that can be used to verify if a process vent Is in compliance
with the process vent provisions of the HON. The table lists the specific records and reports that a
facility needs to keep for each of the control and recovery devices that are likely to be used for
compliance. The owner or operator may comply using a control device other than those listed in
Table 5-6 or may request to monitor parameters other than those specified in Table 5-6. In these cases,
the Inspector should verify that the facility obtained approval from the Administrator (or agency to which
authority has been delegated) and then verify that the approved parameters are recorded and reported.
pjs)135/sect-5.pv
9/26/94 5-29
-------
TABLE 5-4. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS VENTS
COMPLYING WITH 98 WEIGHT-PERCENT REDUC : JN OF EMISSIONS OR A
LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
2.
s
Control Device
Parameters to be Monitored8
Recordkeeplng and Reporting Requirements for Monitored Parameters
Thermal Incinerator
Firebox temperature^
1. Continuous records0
2. Record and report the firebox temperature averaged over the full period of the
performance test - NCSd
3. . Record the dally average firebox temperature for each operating day8
4. Report all dally average temperatures that are outside the range established In
the NCS or operating permit and all operating days when Insufficient
monitoring data are collected' - PR9
Catalytic Incinerator
Temperature upstream and
downstream of the catalyst
bed (63.114(a)(1)(ll))
1. Continuous records
2. Record and report the upstream and downstream temperatures and the
temperature difference across the catalyst bed averaged over the full period of
the performance test - NCS
3. Record the dally average upstream temperature and temperature difference
across catalyst bed for each operating day6
4. Report all dally average upstream temperatures that are outside the range
established In the NCS or operating permit - PR
5. Report all dally average temperature differences across the catalyst bed that
are outside the range established In the NCS or operating permit - PR
6. Report all operating days when Insufficient monitoring data are collected*
(Continued)
-------
TABLE 5-4. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS VENTS
COMPLYING WITH 98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A
LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
Control Device
Parameters to be Monitored3
Recordkeeplng and Reporting Requirements for Monitored Parameters
Boiler or Process
Heater with a design
heat Input capacity
less than
44 megawatts and
Vent Stream Is not
Introduced with or as
the primary fuel
Firebox temperature'1
[63.114(a)(3)]
1. Continuous records
2. Record and report the firebox temperature averaged over the full period of the
performance test - NCS
3. Record the dally average firebox temperature for each operating day8
4. Report all dally average firebox temperatures that are outside the range
established In the NCS or operating permit and all operating days when
Insufficient monitoring data are collected' - PR
Rare
Presence of a flame at the
pilot light [63.114(a)(2)j
Hourly records of whether the monitor was continuously operating and whether
the pilot flame was continuously present during each hour.
Record and report the presence of a flame at the pilot light over the full period
of the compliance determination - NCS
Record the times and durations of all periods when a pilot flame Is absent or
the monitor Is not operating - PR
Report the times and durations of all periods when all pilot flames of a flare are
absent - PR
Scrubber for
Halogenated Vent
Streams (Note:
Controlled by a
combustion device
other than a flare)
pH of scrubber effluent
[63.114(a)(4)(l)]. and
1. Continuous records
2. Record and report the pH of the scrubber effluent averaged over the full period
of the performance test - NCS
3. Record the daily average pH of the scrubber effluent for each operating day6
4. Report all daily average pH values of the scrubber effluent that are outside the
range established In the NCS or operating permit and all operating days when
Insufficient monitoring data are collected'- PR
(Continued)
-------
TABLE 5-4. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS VENTS
COMPLYING WITH 98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A
LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
2,
2
Control Device
Parameters to be Monitored8
Recordkeeplng and Reporting Requirements for Monitored Parameters
Scrubber for
Halogenated Vent
Streams (Note:
Controlled by a
combustion device
other than a flare)
(continued)
Scrubber liquid and gas flow
rates [63.114(a) (4) (II)]
1. Continuous records
2. Record and report the scrubber liquid/gas ratio averaged over the full period
of the performance test - NCS
3. Record the dally average scrubber liquid/gas ratio for each operating day6
4. Report all dally average scrubber llquld/gas ratios that are outside the range
established In the NCS or operating permit and all operating days when
Insufficient monitoring data are collected' - PR
in
fe
All Control Devices
Presence of flow diverted
from the control device to
the atmosphere
|63.114(d)(1)) or
Hourly records of whether the flow Indicator was operating and whether flow
was detected at any time during each hour
Record and report the times and durations of all periods when the vent stream
is diverted through a bypass line or the monitor Is not operating - PR
Monthly Inspections of
sealed valves [63.114(d) (2)]
1. Records that monthly Inspections were performed
2. Record and report the duration of all periods when the car-seal or other seal
mechanism Is broken, the bypass line valve position has changed, or the key
for a lock-and-key type lock has been checked out - PR
Other Control
Devices not listed
above
Owner or operator must
submit a plan for monitoring,
recordkeeplng, and reporting
l§63.114(c),§63.151(f),
§63.152(6))
As specified In the Implementation plan or operating permit
8 Regulatory citations are listed In brackets.
b Monitor may be installed In the firebox or In the ductwork Immediately downstream of the firebox before any substantial heat exchange is
encountered.
c 'Continuous records' Is defined In §63.111 of Subpart G.
(continued)
-------
TABLE 5-4. MONITORING, RECOROKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS VENTS
COMPLYING WITH 98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A
I LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
_
2 ° NCS = Notification of Compliance Status described In §63.152 of Subpart G and discussed In Section 3.5.3 of this manual.
6 The dally average Is the average of all recorded parameter values for the operating day. If all recorded values during an operating day are
within the range established In the NCS or operating permit, a statement to this effect can be recorded Instead of the dally average.
' The periodic reports shall Include the duration of periods when monitoring data Is not collected for each excursion as defined In
§63.152(c)(2)(ll)(A) of Subpart G.
9 PR = Periodic Reports described In §63.152 of Subpart G and discussed In Section 3.5.4 of this manual.
-------
TABLE 5-5. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS
VENTS MAINTAINING A TRE INDEX VALUE >1.0 AND <4.0
Final Recovery
Device
Parameters to be Monitored8
Recordkeeplng and Reporting Requirements for Monitored Parameters
Absorber0
Ol
Exit temperature of the
absorbing liquid
[63.114(b)(1)], and
Continuous records0
Record and report the exit temperature of the absorbing liquid averaged over
the full period of the TRE determination - NCSd
Record the dally average exit temperature of the absorbing liquid for each
operating day6
Report all the dally average exit temperatures of the absorbing liquid that are
outside the range established In the NCS or operating permit - PR*
Exit specific gravity
1. Continuous records
2. Record and report the exit specific gravity averaged over the full period of the
TRE determination NCS
3. Record the dally average exit specific gravity for each operating day6
4. Report all the dally average exit specific gravity values that are outside the
range established In the NCS or operating permit - PR
Condenser**
Exit (product side)
temperature (63.114(b)(2))
1. Continuous records
2. Record and report the exit temperature averaged over the full period of the
TRE determination - NCS
3. Record the dally average exit temperature for each operating day6
4. Report all the dally average exit temperatures that are outside the range
established In the NCS or operating permit - PR
(Continued)
-------
TABLE 5-5. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS
VENTS MAINTAINING A THE INDEX VALUE > 1.0 AND <4.0
Final Recovery
Device
Parameters to be Monitored9
Recordkeeplng and Reporting Requirements for Monitored Parameters
en
Carbon Adsorber**
Total regeneration stream
mass flow during carbon bed
regeneration cyde(s)
[63.114(b)(3)J, and
Record of total regeneration stream mass flow for each carbon bed
regeneration cycle
Record and report the total regeneration stream mass flow during each carbon
bed regeneration cycle during the period of the TRE determination - NCS
Report all carbon bed regeneration cycles when the total regeneration stream
mass flow Is outside the range established In the NCS or operating permit - PR
Temperature of the carbon
bed after regeneration [and
within 15 minutes of
completing any cooling
cyde(s)] (63.114(b)(3)]
1. Records of the temperature of the carbon bed after each regeneration
2. Record and report the temperature of the carbon bed after each regeneration
during the period of the TRE determination - NCS
3. Report all carbon bed regeneration cycles during which temperature of the
carbon bed after regeneration Is outside the range established In the NCS or
operating permit - PR
All Recovery Devices
(as an alternative to
the above)
Concentration level or
reading Indicated by an
organic monitoring device at
the outlet of the recovery
device
1. Continuous records
2. Record and report the concentration level or reading averaged over the full
period of the TRE determination - NCS
3. Record the dally average concentration level or reading for each operating
day8
4. Report all dally average concentration levels or readings that are outside the
range established In the NCS or operating permit - PR
(Continued)
-------
TABLE 5-5. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR PROCESS
VENTS MAINTAINING A TRE INDEX VALUE >1.0 AND <4.0
Final Recovery
Device
Parameters to be Monitored8
Recordkeeplng and Reporting Requirements for Monitored Parameters
£
s
Other Recovery
Devices not listed
above or a Process
Vent that maintains a
TRE Index value
> 1.0 and _< 4.0
without a Recovery
Device
Owner or operator must
submit a plan for monitoring,
recordkeeplng, and reporting
(§63.114(c).§63.151(f),
§63.152(6)]
As specified In the Implementation plan or operating permit
Ul
a Regulatory citations are listed In brackets Note that under §63.114(e), an owner or operator may apply to monitor an alternate parameter by
submitting a plan and rationale In the Implementation Plan or operating permit application as provided In §63.151(1) or §63.152(e) of
Subpart G.
b Alternatively, these devices may comply with the organic monitoring device provisions listed at the end of this table under "All Recovery
Devices."
c "Continuous records" Is defined In §63.111 of Subpart G.
d NCS = Notification of Compliance Status described In §63.152 of Subpart G and discussed In Section 3.5.3 of this manual.
8 The dally average Is the average of all values recorded during the operating day. If all recorded values during an operating day are within the
range established In the NCS or operating permit, a statement to this effect can be recorded Instead of the dally average.
f PR = Periodic Reports described In §63.152 of Subpart G and discussed In Section 3.5.4 of this manual.
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
Complete this form for process vent systems. A "yes" response to all questions will indicate full
compliance and, "no" response will indicate noncompliance with the standard except where noted.
CONTROL OR RECOVERY DEVICE
DATE OF STARTUP
REVIEW OF RECORDS
IF THE CONTROL DEVICE IS A FLARE
1. Results of the initial test were submitted in the NCS.a YD No
2. The presence of a continuous flare pilot flame is monitored YD No
using a device designed to detect the presence of a flame.
3. All periods when all pilot flames to a flare were absent or the YD No
monitor was not operating have been recorded and
reported in the PR.b
IF THE CONTROL DEVICE IS A THERMAL INCINERATOR
1. Results of the initial performance test were submitted in the YD No
NCS.a
2. Test documentation demonstrates 98 percent HAP or TOC YD No
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
3. A temperature monitoring device equipped with a YD No
continuous recorder is used to measure the temperature of
the gas stream in the firebox (or in the ductwork
immediately downstream of the firebox before any
substantial heat exchange occurs).
4. Documentation to establish a site-specific range for firebox YD No
temperature was submitted in the NCSa or operating permit
application.
5. Continuous records0 of firebox temperature are kept YD N o
6. Records of daily average firebox temperature are kept YD No
7. All daily average firebox temperatures that are outside the YD N n
site-specific established range and all operating days when
insufficient monitoring data are collected are reported in the
PR.b
(continued)
p)s]135/table-5.06 5-37
-------
TABLE 5-6. COMPLIANCE CHECKLIST FOR PROCESS VENT SYSTEMS
8. The number of excursions does not exceed the number of YD No
excused excursions in the semi-annual reporting period.**
9. If the firebox temperature is not monitored, the facility has YD N D
documentation that they applied for and received approval
to monitor an alternative parameter, and are performing the
required recordkeeping and reporting.
[Note: If #9 is checked "Yes", the facility is in compliance
even if numbers 3 through 8 are checked "No*.]
IF THE CONTROL DEVICE IS A CATALYTIC INCINERATOR
1. Results of the initial performance test were submitted in the YD N D
NCS.a
2. Test documentation demonstrates 98 percent HAP orTOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
3. Temperature monitoring devices equipped with continuous YD N D
recorders are used to measure the temperature in the gas
stream immediately before and after the catalyst bed.
4. Documentation to establish a site-specific range for the gas YD N D
stream temperature upstream of the catalyst bed and the
temperature difference across the bed was submitted in the
NCSa or operating permit application.
5. Continuous records0 are kept of the temperature of the gas YD N D
stream upstream of the catalyst bed and the temperature
difference across the catalyst bed.
6. Records of the daily average temperature upstream of the YD N D
catalyst bed and the temperature difference across the
catalyst bed are kept.
7. All daily average upstream temperatures that are outside the 'YD N D
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
8. All daily average temperature differences across the catalyst YD N D
bed that are outside the site-specific range and all operating
days when insufficient monitoring data are collected are
reported in the PR.11
9. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.d
(continued)
pjs)135Aable-5.06 5-38
-------
TABLE 5-6. COMPLIANCE CHECKLIST FOR PROCESS VENT SYSTEMS
10. If the temperature upstream of the catalyst bed and /or the YD ND
temperature differential across the catalyst bed are not
monitored, the facility has documentation that they applied
for and received approval to monitor an alternative
parameter, and are performing the required recordkeeping
and reporting.
[Note: If #10 is checked "Yes*, the facility is in compliance
even if numbers 3 through 9 are checked "No".]
IF THE CONTROL DEVICE IS 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
1. Results of the initial performance test were submitted in the YD N D
NCS.a
2. A description of the location at which the vent stream is YD N D
introduced into the boiler or process heater was submitted
in the NCS.a
3. The vent stream is introduced into the flame zone of the YD N D
boiler or process heater.
4. Test documentation demonstrates 98 percent HAP or TOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
5. A temperature monitoring device equipped with a YD N D
continuous monitor Is used to measure the temperature of
the gas stream in the firebox.
6. Documentation to establish a site-specific range for firebox YD N D
temperature was submitted in the NCSa or operating permit .
application.
7. Continuous records0 are kept of the firebox temperature. YD N D
8. Records of the daily average firebox temperature are kept YD N D
9. All daily average firebox temperatures that are outside the YD N D
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
10. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.0'
(continued)
pjsJ135/lable-5.06 5-39
-------
TABLE 5-6. COMPLIANCE CHECKUST FOR PROCESS VENT SYSTEMS
11. If the firebox temperature is not monitored, the facility has YD No
documentation that they applied for and received approval
to monitor an alternative parameter, and are performing the
required recordkeeping and reporting.
[Note: If #11 is checked "Yes", the facility is in compliance
even if numbers 5 through 10 are checked "No".]
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER
WITH A DESIGN HEAT INPUT CAPACITY GREATER THAN
44 MEGAWATTS
1. A description of the location at which the vent stream Is YD N D
introduced into the boiler or process heater was submitted
in the NCS.a
2. The vent stream is introduced into the flame zone of the YD N D
boiler or process heater.
IF THE CONTROL DEVICE IS A SCRUBBER (FOLLOWING A
COMBUSTOR FOR A HALOGENATED VENT STREAM)
1. Results of the initial performance test were submitted in the YD N D
NCS.a
2. Either: (1) Test documentation demonstrates 99 percent YD N D
control efficiency for total halogens and hydrogen halides or
test documentation demonstrates that the outlet mass of
total hydrogen halides and halogens are less than 0.45
kilograms per hour, or, (2) if the scrubber was installed prior
to December 31, 1992, test documentation demonstrates
95 percent control efficiency for total halogens and
hydrogen halides or test documentation demonstrates that
the outlet mass of total hydrogen halides and halogens are
less than 0.45 kilograms per hour.
3. A pH monitoring device equipped with a continuous YD N D
recorder is used to monitor the pH of the scrubber effluent
4. A flow meter equipped with a continuous recorder is used to YD N D
measure the influent liquid flow and effluent vapor flow.
5. Documentation to establish a site-specific range for the pH, YD N D
and liquid/gas ratio was submitted in the NCSa or operating
permit.
(continued)
pjs|135/tat>le-5.06 5-40
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
6.
7.
8.
9.
Continuous records0 of the pH of the scrubber effluent are
kept.
Continuous records0 of the scrubber liquid/gas ratio are
kept.
Records of the daily average pH and the daily average
liquid/gas ratio are kept.
All daily average pH values of the scrubber effluent that are
YD
YD
YD
YD
ND
ND
ND
ND
outside the site-specific range and all operating days when
insufficient monitoring data are collected are reported In the
PR.b
10. All daily average scrubber liquid /gas ratios that are outside YD ND
the site-specific range and all operating days when
insufficient monitoring data are collected are reported in the
PR.b
11. The number of excursions does not exceed the number of YD No
excused excursions in the semi-annual reporting period.01
12. If the pH and/or the scrubber liquid to gas ratio are not YD N D
monitored, the facility has documentation that they applied
for and received approval to monitor an alternative
parameter, and are performing the required recordkeeping
and reporting.
[Note: If #12 is checked "Yes", the facility is in compliance
even if numbers 3 through 11 are checked "No".]
IF THE RECOVERY DEVICE IS A CARBON ADSORBER AND THE
TRE INDEX VALUE IS GREATER THAN 1.0 AND LESS THAN OR
EQUAL TO 4.0
1. Documentation of the initial TRE calculation including test YD ND
results was submitted in the NCS.a
2. An integrating regeneration stream (e.g., steam) flow YD N D
monitoring device having an accuracy of _f10 percent and
capable of recording total regeneration stream mass flow for
each regeneration cycle is used to measure regeneration
stream flow.
(continued)
p|s|135Aable-5.06 5-41
-------
TABLE 5-6. COMPUANCE CHECKLIST FOR PROCESS VENT SYSTEMS
3. A carbon bed temperature monitoring device capable of YD N D
recording the carbon bed temperature after each
regeneration and within 15 minutes of completing any
cooling cycle is used to measure carbon bed regeneration
temperature.
4. Documentation to establish a site-specific range for the YD N D
regeneration stream flow and carbon bed regeneration
temperature was submitted in the NCSa or operating permit.
5. Records are kept of the total regeneration stream mass flow YD N n
for each carbon bed regeneration cycle.
6. Records are kept of the temperature of the carbon bed after YD N D
each carbon bed regeneration.
7. All regeneration cycles when the total regeneration stream YD N D
mass flow is outside the site-specific range are reported in
the PR.b
8. All regeneration cycles during which the temperature of the YD N D
carbon bed after regeneration is outside the site-specific
range are reported in the PR.b
9. If the regeneration stream flow and/or the carbon bed
regeneration temperature are not monitored, either
(a) The facility has documentation that they applied for YD No
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with items
. [(b)and(c)and(d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD No
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
[Note: If #9(a) is checked "Yes", .or if 9(b) and 9(c) and 9(d)
are checked "Yes", the facility is in compliance even if
numbers 2 through 8 are checked "No'.]
(continued)
pjsj135/table-5.06 5-42
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
IF THE RECOVERY DEVICE IS AN ABSORBER AND THE TRE
INDEX VALUE IS GREATER THAN 1.0 AND LESS THAN OR
EQUAL TO 4.0
1. Documentation of the initial TRE calculation including test Y D
results was submitted in the NCS.a
2. A temperature monitoring device and a specific gravity Y a
monitoring device equipped with a continuous monitor are
used to measure the exit temperature of the scrubbing liquid
and the exit specific gravity.
3. Documentation to establish a site-specific range for the exit Y a
temperature of the scrubbing liquid and exit specific gravity
was submitted in the NCSa or operating permit.
4. Records of the dally average exit temperature of the -YD
scrubbing liquid and exit specific gravity are kept
5. Continuous records0 of the exit temperature of the Y a
absorbing liquid are kept.
6. Continuous records0 of the exit specific gravity are kept. Y D
7. All daily average exit temperatures of the absorbing liquid Y D
that are outside the site-specific range are reported in the
PR.b
8. All daily average specific gravity values that are outside the Y a
site-specific range are reported in the PR.b
9. If the exit temperature and/or the exit specific gravity are
not monitored, either:
(a) The facility has documentation that they applied for Y D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with items
Kb) and (c) and (dll.
(b) Continuous records are kept of the concentration Y o
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration Y D
level or reading for each operating day.
(d) All daily average concentration levels or readings Y a
that are outside the site-specific range are reported
in the PR.b
NO
ND
ND
Nn
Nn
ND
Nn
Nn
Nn
ND
ND
ND
(continued)
pjs)135/table-5.06
5-43
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
[Note: If #9(a) is checked "Yes", or if 9(b) and 9(c) and 9(d)
are checked "Yes", the facility is in compliance even if
numbers 2 through 8 are checked "No".]
IF THE RECOVERY DEVICE IS A CONDENSER AND THE TRE
INDEX VALUE IS GREATER THAN 1.0 AND LESS THAN OR
EQUAL TO 4.0
1. Documentation of the initial TRE calculation including test YD No
results was submitted in the NCS.a
2. A temperature monitoring device equipped with a Y a N D
continuous recorder is used to measure the product side
exit temperature.
3. Documentation to establish a site-specific range for the exit YD N D
temperature was submitted in the NCSa or operating permit.
4. Records of the daily average exit temperature are kept. YD No
5. Continuous records0 of the exit temperature are kept YD N D
6. All product side daily average exit temperatures that are YD No
outside the site-specific range are reported in the PR.b
7. If the exit temperature is not monitored, either:
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
record keeping and reporting .or continue with items
[(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N a
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
[Note: If #7(a) is checked "Yes", or if 7(b) and 7(c) and 7(d)
are checked "Yes", the facility is in compliance even if
numbers 2 through 6 are checked "No".]
(continued)
p)s)135/Uble-5.06 5-44
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
GENERAL - FOR ANY (NON-RECOVERY) CONTROL DEVICE
[Note: Items #1 through #4 do not apply to low leg drains, high
point bleeds, analyzer vents, open-ended valves or lines, and
pressure relief valves needed for safety purposes.]
1. Hourly records are kept of whether the flow Indicator in the Y o N n
bypass line was operating and whether flow was detected at
any time during the hour, when seal mechanisms are not
used and
2. The time and duration of all periods when flow is diverted or YD No
the monitor is not operating are reported in the PR when
seal mechanisms are not used [or #3 and #4].
3. Records of monthly visual inspections are kept when seal YD No
mechanisms are used and
4. All periods when the seal mechanism is broken, the bypass YD No
line valve position has changed, or the key to unlock the
bypass line valve was checked out are recorded and
reported in the PR when seal mechanisms are used.
[Note: In order to be in compliance with provisions for
bypass lines either #1 and #2 must both be checked "yes"
or both #3 and #4 must both be checked "yes'.]
GENERAL - FOR GROUP 2 PROCESS VENTS
1. Records of process changes and the recalculation of TRE Y a N a
index values are kept when the TRE index value of the vent
stream is greater than 1.0.d
2. Records of process changes and the recalculation of flow Y a N a
rate are kept when the flow rate of the vent stream is less
than 0.005 standard cubic meter per minute.
3. Records of process changes and the recalculation or Y a No
remeasurement of concentration are kept if the
concentration in the vent stream is less than 50 ppmv.
(continued)
p)s]135/table-5.06 5-45
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
4. Whenever process changes are made which cause a YD No
change in the status of the process vent stream, records are
kept and a report was submitted within 180 days of the
process modification or in the next PR describing the
process modification and showing the results of the
recalculation of flow rate, organic HAP concentration,
and/or THE index value.
VISUAL INSPECTION
1. A flow indicator is present at the entrance to any bypass line YD N a
that could divert the vent stream flow away from the control
device to the atmosphere .or all bypass line valves are
sealed in a closed position (e.g., with a car seal or lock-and-
key configuration).
2. For flares, a device for detecting the flame Is present. YD No
3. For all incinerators, and for boilers and process heaters with YD N n
design heat input capacities less than 44 megawatts and the
vent steam is not Introduced with the primary fuel, a
temperature monitoring device is present.
4. For scrubbers used after combustors for halogenated vent YD N a
streams, a device for measuring pH and a device for
measuring flow are present.
5. For carbon adsorbers, a device for measuring carbon bed YD No
temperature and a device for measuring regeneration
stream flow are present [or #8].
6. For absorbers, a device for measuring exit liquid YD N a
temperature and a device for measuring exit specific gravity
are present [or #8].
7. For condensers, a temperature monitoring device is present YD N D
[or #8].
8. If the monitoring devices listed in items 5 through 7 are not YD N D
present, an organic compounds monitor is present.
[Note: If item #8 is checked "Yes", the facility is in
compliance even if numbers 5 through 7 are checked "No".]
9. Visual inspection of the facility is consistent with written YD N D
records.
a NCS = Notification of Compliance Status.
b PR = Periodic Reports.
(continued)
p|sJ135Aable-5.06 5-46
-------
TABLE 5-6. COMPLIANCE CHECKUST FOR PROCESS VENT SYSTEMS
c Continuous records, as defined in §63.111, means documentation, either in computer readable
form or hard copy, or data values measured at least once every 15 minutes and recorded at the
frequency specified in §63.152(f). Section 63.152(f) allows the owner to record either values
measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
all measured values during each period. If the daily average value of a monitored value for a given
parameter is within the range established in the NCS, the owner or operator may retain block hourly
averages instead of the 15-minute values. An owner or operator may request approval to use
alternatives to continuous monitoring under §63.151 (g) of Subpart G.
d The number of excused excursions is as follows:
For the first semi-annual period after the NCS Is due - 6 excursions;
For the second semi-annual period - 5 excursions;
For the third semi-annual period - 4 excursions;
For the fourth semi-annual period - 3 excursions;
For the fifth semi-annual period - 2 excursions;
For the sixth and all subsequent semi-annual periods -1 excursion.
An excursion occurs when: (1) the daily average value of the monitored parameter is outside the
range established in the NCS or operating permit; or (2) If monitoring data are insufficient. In order
to have sufficient data, a source must have measured values for each 15-minute period within each
hour for at least 75 percent of the hours the control device is operating in a day. For example, if a
control device operates 24 hours per day, data must be available for all 15-minute periods in at
least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
hour of incomplete data is allowed.
e Examples of process changes include, but are not limited to, changes in production capacity,
production rate, feedstock type, or catalyst type, or whenever there is replacement, removal, or
addition of recovery equipment. Process changes do not include process upsets; unintentional,
temporary process changes; and changes that are within the range on which the original TRE
calculation was based.
NOTE ALL DEFICIENCIES
p|s|135/table-5.06 5-47
-------
5.5 REFERENCES
1. , Memorandum from Paul, D., J.A. Probert, and R. Mead (Radian Corporation), to Dr. Janet S.
Meyer (U.S. Environmental Protection Agency, Standards Development Branch).
Characterization of Product Accumulator Vessels. January 18, 1994. p. 20.
pis|135/sect-5.pv
9/26/94
-------
SECTION 6
TRANSFER OPERATIONS
6.1 DESCRIPTION OF EMISSION POINT
The principal method of transferring liquid product to tank trucks and rallcars Is submerged
loading, Including submerged fill pipe loading and bottom loading. In submerged fill pipe loading, the fill
pipe enters the vessel from the top but extends almost to the bottom of the vessel such that the fill pipe
opening is completely submerged In the liquid product. In bottom loading, the fill pipe enters the vessel
from the bottom, so that the fill pipe opening is positioned below the liquid level. Figures 4-1 and 4-2 in
the Benzene Transfer Operation Inspection Manual1 illustrate submerged fill pipe and bottom loading.
Both submerged loading techniques significantly reduce liquid turbulence and liquid surface area
resulting in low vapor generation.
Top splash loading, rarely used In SOCMI facilities, is another loading technique in which
the fill pipe enters the vessel through the top but does not extend below the surface of the liquid. This
type of loading results in high vapor generation.
The loading rack is the equipment used to transfer materials into tank trucks and railcars.
The loading rack and the transfer vehicle are emission points during loading operations. A typical
loading rack consists of loading arms, pumps, meters, shutoff valves, relief valves, and other associated
piping necessary to perform either loading or unloading operations.
Figures 4-3 and 4-4 in the Benzene Transfer Operation Inspection Manual1 illustrate tank
truck bottom- and top-loading rack arrangements. Sections 4.1 and 4.2 of the Benzene Transfer
Operation Inspection Manual1 provide additional details, including illustrations of various transfer loading
operations. They describe transfer equipment transfer emission points, and the requirements of the
Benzene NESHAP. In some cases, the requirements of the HON will differ from the requirements of the
Benzene NESHAP.
6.2 DESCRIPTION OF EMISSION CONTROL TECHNOLOGIES
Organic HAP and VOC emissions from tank truck and railcar transfer racks can be collected
in a vapor collection system and routed to a control device. Unlike process vents, the HON definition of
'control device" for transfer racks includes recovery devices as well as combustion devices. Any device
that achieves 98 percent reduction of organic HAP or VOC or achieves a 20 ppmv outlet concentration
of organic HAP or VOC can be used to comply with the HON transfer provisions. Alternatively, transfer
rack emissions can be controlled using a vapor balancing system.
p)s|135/»ec1-6.tr
9/26/94 6-1
-------
6.?1 Vapor Collection System
Vapor collection systems consist of piping or ductwork that captures and transports to a
.ud device organic compounds from the vapor space of a transport vessel. Loading rack systems
that incorporate the product and vapor lines into a single system are preferred since both connections
can be conveniently moved out to the vessel simultaneously. The vapor return line can either be a
flexible hose or a metal pipe incorporated into the loading rack arrangement using a dual style
orientation. Figure 4-5 in the Benzene Transfer Operation Inspection Manual1 illustrates a dual arm
loading rack, and Figure 4-7 in the Benzene Manual1 shows a tank truck with a vapor collection system
(vapor return line).
Section 4.2.1 of the Benzene Transfer Operation Inspection Manual1 provides additional
detaBs on transfer vapor collection systems and control techniques, however, this section also discusses
the transfer requirements of the Benzene NESHAP. In some cases, these requirements will differ from
the requirements of the HON. For example, the Benzene NESHAP applies to marine vessels, but the
HON does not
6.2.2 Combustion and Recovery Devices
Incinerators, flares, boilers, and process heaters, which are described in Section 5.2.1, are
combustion control devices that can be used to comply with the transfer control requirements. Product
recovery devices that can be used to meet the transfer control requirements include condensers, carbon
adsorbers, and absorbers, which are described in Section 5.2.2. Figure 4-7 in the Benzene Transfer
Operation Inspection Manual1 shows a tank truck vapor return line routed to a vapor recovery device.
6 .1.3 Vapor Balancing
Vapor balancing is another means of collecting vapors and reducing emissions from transfer
operations. Vapor balancing is most commonly used where storage facilities are adjacent to the loading
facility. As shown in Rgure 6-1, an additional line is connected from the transport vessel to the storage
tanx to return any vapor that is displaced from the transport vessel to the vapor space of the storage
vessel from which the transferred liquid was pumped. Because this Is a direct volumetric exchange,
there should be no losses to the atmosphere.
6.3 TRANSFER OPERATIONS PROVISIONS
This section summarizes the transfer operation provisions in §63.126 through §63.130 of
Subpart G.
6.3.1 Transfer Operations Definition
A transfer operation is defined as the loading of one or more liquid organic HAP's from a
transfer rack assigned to a chemical manufacturing process that meets the applicability criteria In
p|9j13S/sect-6.tr
9/26/94 6-2
-------
Vapor Balanca Lina
oo
Liquid Transfer
Figure 6-1. Vapor Balancing System
-------
§63.100 into a tank truck or railcar. A transfer rack is defined as the loading arms, pumps, meters,
sr-jtoff valves, relief valves, and other piping and valves necessary to fill tank trucks or railcars. Transfer
operations loading at an operating pressure greater than 204.9 kPa are not subject to the HON. Racks
that transfer liquids that contain organic HAP's only as impurities are not subject to the HON. Racks
that vapor balance during all loading operations are not subject to the transfer provisions in §63.126
through §63.130.
6.3.2 Transfer Operations Group Determination
Group 1 and Group 2 transfer racks are defined in §63.111 of Subpart G. The criteria used
to determine whether a rack is Group 1 or Group 2 are annual throughput of organic HAP-containing
liqu os and rack-weighted average vapor pressure.
Table 6-1 is an applicability and group determination checklist for transfer operations.
Section I of the table presents a set of true/false statements which can be used to determine if the
transfer provisions of the HON are applicable to a transfer rack. If a transfer rack is subject to the
transfer provisions in the HON, Section II of Table 6-1 can be used to determine if the transfer rack is
Group 1 or Group 2.
6.3.3 Transfer Operation Control Requirements
Group 1 transfer racks must meet the control requirements in §63.126 of Subpart G when
the operating pressure of the transfer operation is less than or equal to 204.9 kilopascals, unless the
rack is included in an emissions average. Each Group 1 loading rack must be equipped with a vapor
collection system and control device. The control device must comply with one of the following criteria:
Reduce emissions of total organic HAP's by 98 weight-percent or to an exit
concentration of 20 parts per million by volume, whichever is less stringent;
Reduce emissions of organic HAP's using a flare which meets the specifications
in §63.11 (b) of Subpart A (the NESHAP General Provisions); or
Reduce emissions of organic HAP's using a vapor balancing system.
In contrast to the process vents provisions which do not allow use of product recovery
devices to determine compliance with the first option above, for transfer racks, the 98 weight percent
reduction or 20 ppmv exit concentration can be achieved using either a combustion device or a product
recovery device.
p)s|13S/»ect-6.tr
9/26/94 . 6-4
-------
TABLE 6-1. APPLICABILITY AND GROUP DETERMINATION
CHECKLIST FOR TRANSFER OPERATIONS
I. Transfer Rack Applicability
a. The transfer rack loads vessels other than marine To Fa
vessels.
b. The transfer rack operates at pressures less than or To Fa
equal to 204.9 kUopascals.
c. The transfer rack loads liquids that contain HAP's other T a Fa
than Impurities.
d. The transfer rack does not use vapor balancing for all To Fa
loading of organic HAP-containing liquids.
Is the transfer rack subject to the HON transfer provisions?
a Yes: If all of the statements above are true, the
transfer rack is subject to the transfer
provisions in Subpart G of the HON.
a No: If any of the statements above are false, the
transfer rack is not subject to the process vent
provisions in Subpart G of the HON.
II. Transfer Rack Group Determination8
(Complete this portion only if the answer to Section I Is "yes".)
a. The transfer rack loads more than 650,000 liters per T a Fa
year of liquid products containing organic HAP's.
b. The transfer rack weighted average partial pressure Is T a Fa
greater than or equal to 10.3 kilopascals.
Is the transfer rack Group 1?
a Yes: The transfer rack is Group 1 if all of the above
statements are true.
a No: The transfer rack is Group 2 If any of the above
statements are false.
a Group 1 transfer racks must meet the control requirements in Section 63.126 of Subpart G during
transfer operations when the operating pressures are less than or equal to 204.9 kilopascals, unless the
rack is included in an emissions average. Group 2 transfer racks are not required to apply additional
controls.
p|sJ135Aat>to-6.01 6-5
-------
Each vapor collection system used to comply with the transfer provisions must achieve the
foi Wing:
t
Collect the displaced vapors from the transfer operation and route them to a
control device; and
Prevent organic HAP vapors collected in one arm from passing through another
loading arm to the atmosphere.
If a vapor balancing system is used to comply with the transfer provisions, the vapor
balancing system must achieve the following:
Collect the displaced vapors from the transfer operation and either
route them to the storage vessel from which the transferred liquid
originated; or
compress the vapors and commingle the liquid with the raw feed to
the chemical manufacturing process unit
If a transfer rack vent stream with a mass rate of total hydrogen halldes and halogen atoms
greater than 0.45 kilograms per hour is combusted, a control device must be installed following the
combustion device to reduce emissions of halogens and hydrogen halides. Control devices installed
after December 31, 1992 must reduce overall emissions of halogens and hydrogen halides by 99 percent
or reduce the outlet mass of total hydrogen halides and halogens to less than 0.45 kilograms per hour,
whichever Is less stringent Control devices installed prior to December 31,1992 must reduce overall
emissions of halogens and hydrogen halides by 95 percent or reduce the outlet mass of total hydrogen
halides and halogens to less than 0.45 kilograms per hour, whichever is less stringent.
A control device may be used to reduce the vent stream halogen atom mass emission rate
to less than 0.45 kilograms per hour prior to any combustion control device, and thus make the vent
stream nonhalogenated. Halogenated streams cannot be routed to a flare.
If a boiler or process heater is used to control the vent stream from a transfer rack, the vent
stream must be introduced into the flame zone.
The tank truck or raOcar vapor collection equipment must be compatible with and connected
to the loading rack's vapor collection system. The owner or operator must ensure that any pressure-
vac jm vent will not open during loading and that ail vents that could divert the vapor flow to the
pjs|135/sect-6.tr
9/26/94 6-6
-------
atmosphere are either secured using a car seal or a lock-and-key type configuration, or equipped with a
flow Indicator.
Group 2 transfer racks are not required to apply emission controls, but recordkeeping and
reporting is required to verify that they are Group 2.
6.3.4 Transfer Operations Testing. Monitoring. Recordkeeplna. and Reporting
Initial performance testing, and Initial reporting, and recordkeeping requirements for Group 1
transfer racks are summarized in Table 6-2. A performance test is not required for flares. However, a
compliance determination is required which includes determining visible emissions.
Performance tests are not required for vapor balancing systems, or boilers or process
heaters with a design heat input capacity of 44 Megawatts or greater or where the vent stream Is
introduced with the primary fuel. A boiler or process heater burning hazardous waste which is permitted
under 40 CFR part 270 and is in compliance with 40 CFR part 266 Subpart H also does not require a
performance test.
For transfer racks that transfer less than 11.8 million liters per year of liquid containing
organic HAP's, the owner or operator may submit a design evaluation for the control device, and
monitor the design parameters instead of conducting performance tests.
Continuous monitoring, recordkeeping, and reporting requirements for transfer racks are
presented in Table 6-3. Any boiler or process heater in which all vent streams are introduced with the
primary fuel or where the design heat input capacity is greater than or equal to 44 Megawatts is exempt
from monitoring requirements. Hazardous waste boilers that are permitted under 40 CFR Part 270 and
are in compliance with 40 CFR Part 266 do not have continuous monitoring requirements.
The HON also requires periodic inspection of vapor collection and vapor balancing systems
to detect leaks. The provisions are specified in §63.148 of Subpart G.
For each parameter monitored in Table 6-3, the owner or operator must establish a site-
specific range for the parameters that indicates proper operation of the control device. If an owner or
operator uses a control device other than those specified in Table 6-3, or wishes to monitor a parameter
other than those specified in Table 6-3, the owner or operator must submit a description of and rationale
for the planned monitoring, recordkeeping, and reporting in the Implementation Plan discussed in
Section 3.5.2 or the operating permit application.
Group 1 transfer racks may only load tank trucks and railcars that are vapor tight. Vapor
tightness must be demonstrated by either (1) having a current certification In accordance with the
U.S. Department of Transportation pressure test requirements of 49 CFR 180 for tank trucks or
49 CFR 173.31 for railcars or (2) having been shown to be vapor tight within the preceding 12 months
using Method 27.
p(sJ135/sect-6.tr
9/26/94 6-7
-------
TABLE 6-2. TRANSFER RACK INITIAL PERFORMANCE TEST AND RECORDKEEPING AND
REPORTING FOR COMPI !/\NCE DETERMINAI .."*
I
I
I
S
Control devices which
require a performance
test
Thermal Incinerator;
Catalytic Incinerator
or
Boiler or process
heater with design
heat Input capacity
less than
44 megawatts and the
vent stream Is not
mixed with the primary
fuel
or
Absorber; Condenser;
or Carbon Adsorber
Test parameters
(1) Percent reduction of
organic HAP or TOCb
If complying with
98 percent reduction In
§63.126(b)(1).
or
The outlet
concentration of HAP
or TOCb In ppmv If
complying with
20 ppmv limit In
§63.126(b)(1).
(2) Sampling Sites -
Location
(3) Volumetric Row Rate
(4) Oxygen Concentration
Test Methods
(1) Method 18 or 25A
or any method
validated by
Method 301
(2) Method 1 or 1A
(3) Method 2, 2A, 2C,
20
(4) Method 3B
Recordkeeplng/Reportlng
(A) Record and report the percent
reduction of organic HAP or
TOCb or the outlet concentration
of HAP or TOCb In ppmv
(B) Record and report the valuo of
the appropriate monitored
operating parameter(s) shown on
Table 5-8, averaged over the time
period of the performance test
(C) For boilers and process heaters,
record and report the location at
which the vent stream Is
Introduced.
(Continued)
-------
TABLE 0-2. TRANSFER RACK INITIAL PERFORMANCE TEST AND RECORDKEEPING AND
REPORTING FOR COMPLIANCE DETERMINATION8
I
S
s
Control devices which
require a performance
test
Scrubber for
halogenated vent
streams controlled by
combustion
Test parameters
Test Methods
(1) Percent reduction of
total halogens and
hydrogen halldes If
complying with the
appropriate reduction
requirements In
§63.123(d)(1)
or
Outlet mass of total
hydrogen halldes and
halogens to less than
0.45 kilograms per
hour
(1) Method 26 or 26A
or any method
validated by
Method 301
Recordkeeplng/Reportlng
(A) Record and report the percent
reduction of halogens and
hydrogen halldes or the
concentration of each Individual
compounds at the outlet
(B) Record and report the pH of the
scrubber effluent
(C) Record and report the scrubber
liquid to gas ratio
Rare (no performance
test Is required to
determine percent
emissions reduction or
outlet HAP or TOC
concentration)
(1) Visible emissions
(1) Method 22
(A) Record and report all visible
emission readings, heat content,
flow rate, and exit velocity
(B) Record and report all periods
during the compliance
determination when the pilot
flame Is absent
(C) Record and report flare design
(Continued)
-------
TABLE 6-2. TflANSFFR RACK INITIAL PERFORMANCE TEST AND RECORDKEEPING AND
ORT1NG FOR COMPUANCL it IERMINATION*
Control devices which
require a performance
test
Vapor Collection
System
All Control Devices
Test parameters
(1) Equipment leaks
(1) Halogen concentration
Test Methods
(1) Method 21
(1) Method 26 or 26A
or any method
validated by
Method 301
Recordkeeplng/Reportlng
(A) Record and report visual
Inspections and leak readings
(A) Record and report the halogen
concentration In the vent stream
a For transfer racks that transfer less than 11.8 million liters per year, a design analysis may be conducted Instead of a performance test.
b TOC = Total organic compounds.
-------
TABLE 6-3. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR TRANSFER RACKS COMPLYING WITH
98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
Control Device
Parameters to be Monitored8
Recordkeeplng and Reporting Requirements for Monitored Parameters
Thermal Incinerator
Firebox temperature^
1. Continuous records0 during loading.
2. Record and report the firebox temperature averaged over the full period of the
performance test - NCSd
3. Record the dally average firebox temperature for each operating day6
4. Report dally average temperatures that are outside the range established In the
NCS or operating permit and all operating days when Insufficient monitoring
data are collected' - PRO
Catalytic Incinerator
Temperature upstream and
downstream of the catalyst
bed (63.127(a)(1)(ll)]
1. Continuous records0 during loading.
2. Record and report the upstream and downstream temperatures and the
temperature difference across the catalyst bed averaged over the full period of
the performance test - NCS
3. Record the daily average upstream temperature and temperature difference
across catalyst bed for each operating day6
4. Report all dally average upstream temperatures that are outside the range
established In the NCS or operating permit - PR
5. Report all daily average temperature differences across the catalyst bed that
are outside the range established In the NCS or operating permit - PR
6. Report all operating days when Insufficient monitoring data are collected'
(Continued)
-------
TABLE 6-3. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR TRANSFER RACKS COMPLYING WITH
98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
Control Device
Parameters to be Monitored9
Recordkeeplng and Reporting Requirements for Monitored Parameters
Boiler or Process
Heater with a design
heat Input capacity
less than
44 megawatts and
the vent stream Is
not Introduced with
or as the primary fuel
Firebox temperature*5
(63.127(a)(3))
Continuous records0 during loading.
Record and report the firebox temperature averaged over the full period of the
performance test - NCS
Record the daRy average firebox temperature for each operating day6
Report all dally average firebox temperatures that are outside the range
established In the NCS or operating permit and all operating days when
Insufficient data are collected' - PR
Flare
Presence of a flame at the
pHot light [63.127(a)(2)J
Hourly records of whether the monitor was continuously operating and whether
the pilot flame was continuously present during each hour.
Record and report the presence of a flame at the pilot light over the full period
of the compliance determination - NCS
Record the times and duration of all periods when the pilot flame Is absent or
the monitor Is not operating - PR
Report the duration of all periods when all pilot flames of a flare are absent -
PR
Scrubber for
Halogenated Vent
Streams (Note:
Controlled by a
combustion device
other than a flare)
pH of scrubber effluent
(63.127(a)(4)(l)]. and
1. Continuous records0 during loading
2. Record and report the pH of the scrubber effluent averaged over the full period
of the performance test - NCS
3. Record the dally average pH of the scrubber effluent for each operating day6
4. Report all dally average pH values of the scrubber effluent that are outside the
range established In the NCS or operating permit and all operating days when
Insufficient monitoring data are collected*- PR
'Continued)
-------
TABLE 6-3. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR TRANSFER RACKS COMPLYING WITH
98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
Control Device
Parameters to be Monitored3
Recordkeeplng and Reporting Requirements for Monitored Parameters
Scrubber for
Halogenated Vent
Streams (Note:
Controlled by a
combustion device
other than a flare)
(continued)
Scrubber liquid and gas flow
rates (63.127(a)(4)(ll)]
1. Continuous records0 during loading
2. Record and report the scrubber liquid/gas ratio averaged over the full period
of the performance test - NCS
3. Record the dally average scrubber liquid/gas ratio for each operating day6
4. Report all dally average scrubber llquld/gas ratios that are outside the range
established In the NCS or operating permit and all operating days when
Insufficient monitoring data are collected' - PR
2
O)
Absorber0
Exit temperature of the
absorbing liquid
(63.127(b)(1)), and
1. Continuous records0 during loading
2. Record and report the exit temperature of the absorbing liquid averaged over
the full period of the performance test - NCS
3. Record the dally average exit temperature of the absorbing liquid for each
operating day6
4. Report all dally average exit temperatures of the absorbing liquid that are
outside the range established In the NCS or operating permit and all operating
days when Insufficient monitoring data are collected* - PR
Exit specific gravity
[63.127(b)(1)j
1. Continuous records0 during loading
2. Record and report the exit specific gravity averaged over the full period of the
performance test - NCS
3. Record the dally average exit specific gravity for each operating day6
4. Report all dally average exit specific gravity values that are outside the range
established In the NCS or operating permit and all operating days when
Insufficient monitoring data are collected' - PR
(Continued)
-------
TABLE 6-3. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS FOR TRANSFER RACKS COMPLYING WITH
98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
Control Device
Parameters to be Monitored8
Recordkeeplng and Reporting Requirements for Monitored Parameters
Condenser"
Exit (product side)
temperature (63.127(b)(2)]
1. Continuous records0 during loading
2. Record and report the exit temperature averaged over the full period of the
performance test - NCS
3. Record the daily average exit temperature for each operating day8
4. Report all dally average exit temperatures that are outside the range
established In the NCS or operating permit and all operating days when
Insufficient monitoring data are collected' - PR
Carbon Adsorber"
Total regeneration stream
mass flow during carbon bed
regeneration cyde(s)
[63.127(b)(3)j, and
Records of total regeneration stream mass flow for each carbon bed
regeneration cycle
Record and report the total regeneration stream mass flow during each .carbon
bed regeneration cycle during the period of the performance test - NCS
Report all carbon bed regeneration cycles when the total regeneration stream
mass flow Is outside the range established In the NCS or operating permit and
all operating days when Insufficient monitoring data are collected' - PR
Temperature of the carbon
bed after regeneration [and
within 15 minutes of
completing any cooling
cyde(s)] {63.127(b)(3)]
Records of the temperature of the carbon bed after each regeneration
Record and report the temperature of the carbon bed after each regeneration
during the period of the performance test - NCS
Report all the carbon bed regeneration cycles during which the temperature of
the carbon bed after regeneration Is outside the range established In the NCS
or operating permit and all operating days when Insufficient monitoring data
are collected' - PR
(Continued)
-------
TABLE 6-3. MONITORING, RECOROKEEPING, AND REPORTING REQUIREMENTS FOR TRANSFER RACKS COMPLYING WITH
98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
Control Device
Parameters to be Monitored8
Recordkeeplng and Reporting Requirements for Monitored Parameters
All Recovery Devices
(as an alternative to
the above)
Concentration level or
reading Indicated by an
organic monitoring device at
the outlet of the recovery
device [63.127(b>]
1. Continuous records0 during loading
2. Record and report the concentration level or reading averaged over the full
period of the performance test - NCS
3. Record the dally average concentration level or reading for each operating
day8
4. Report all dally average concentration levels or readings that are outside the
range established In the NCS or operating permit and all operating days when
Insufficient monitoring data are collected'- PR
en
All Control Devices
and Vapor Balancing
Systems
Presence of flow diverted to
the atmosphere from the
control device |63.127(d)(1))
or
Hourly records of whether the flow Indicator was operating and whether flow
was detected at any time during each hour
Record and report the duration of all periods when the vent stream Is diverted
through a bypass line or the monitor Is not operating - PR
Monthly Inspections of
sealed valves (63.127(d)(2)]
1. Records that monthly Inspections were performed
2. Record and report the duration of all periods when the car-seal or other seal
mechanism Is broken, the bypass line valve position has changed, or the key
for the lock-and-key type lock has been checked out - PR
3. Report all times when maintenance Is performed on car-sealed valves - PR
Other Control
Devices not listed
above
Owner or operator must
submit a plan for monitoring,
recordkeeplng, and reporting
(§63.127(c). §63.151(f),
§63.152(e)j
As specified In the Implementation plan or operating permit
a Regulatory citations are listed In brackets.
b Monitor may be Installed In the firebox or In the ductwork immediately downstream of the firebox before any substantial heat exchange Is
encountered.
(continued)
-------
TABLE 6-3. MONITORING, a£CORDKEEPING, AND REPORTING REQUIREMENTS FOR TRANSFER RACKS COMPLYING WITH
98 WEIGHT-PERCENT REDUCTION OF EMISSIONS OR A LIMIT OF 20 PARTS PER MILLION BY VOLUME OR USING A FLARE
| c 'Continuous records* Is defined In §63.1 1 1 of Subpart G.
"13
I d NCS = Notification of Compliance Status described In §63.152 of Subpart G and discussed In Section 3.5.3 of this manual.
° e The dally average Is the average of all recorded parameter values for the operating day. If all recorded values during an operating day are
within the range established In the NCS or operating permit, a statement to this effect can be recorded Instead of the dally average.
' The periodic reports shall Include the duration of periods when monitoring data are not collected for each excursion as defined In
§63.152(c)(2)(li)(A) of Subpart G.
9 PR = Periodic Reports described In §63.152 of Subpart G and discussed In Section 3.5.4 of this manual.
h Alternatively, these devices may comply with the organic monitoring device provisions listed at the end of this table under 'All Recovery
Devices.'
at
-------
Each owner or operator must maintain a record of the transfer rack vent system which lists
all valves and vent streams that could divert the vent stream from the control device. The valves which
»
are secured by car-seals or lock-and-key type configurations and the position of these valves must be
identified.
The owner or operator of a Group 1 or Group 2 transfer rack must record and update
annually an analysis demonstrating the design and actual annual throughput of the transfer rack, the
weight-percent organic HAP of the liquid loaded, and the annual rack weighted average HAP vapor
pressure. For Group 2 transfer racks that only transfer organic HAP's with vapor pressures less than
10.3 kilopascals, the owner or operator must only document each Individual HAP that Is transferred. For
Group 2 transfer racks that transfer organic HAP's with vapor pressures above and below
10.3 kilopascals, the owner or operator must calculate and document the rack weighted average vapor
pressure.
6.4 TRANSFER OPERATIONS INSPECTION PROCEDURES
Table 6-4 presents a checklist that can be used to verify If a transfer rack is in compliance
with the transfer provisions of the HON. The table lists the specific records and reports that a facility
needs to keep for each of the control and recovery devices that are likely to be used for compliance.
The owner or operator may comply using a control device other than those listed in Table 6-4 or may
request to monitor parameters other than those specified in Table 6-4. In these cases, the inspector
should verify that the facility obtained approval from the Administrator (or agency to which authority has
been delegated) and then verify that the approved parameters are recorded and reported.
6.5 REFERENCES
1. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards,
Stationary Source Compliance Division. Level II Inspection Manual: Benzene Transfer
Operation. Washington, DC. January 1993.
p|SJ135/sect-6.tr
9/26/94 6-17
-------
TABLE 6-4. COMPUANCE CHECKLIST FOR TRANSFER OPERATIONS
Complete this form for transfer racks. A "yes" response to all questions will Indicate full compliance,
and a "no" response will indicate noncompliance with the standard except where noted. Note that for
transfer racks, a combustion or recovery device can be used to reduce emissions by 98 percent or to
20 ppmv. Vapor balancing can also be used to comply.
CONTROL DEVICE
DATE OF STARTUP
REVIEW OF RECORDS
IF THE CONTROL DEVICE IS A FLARE
1. Results of the initial test were submitted in the NCS.a YD N o
2. The presence of a continuous flare pilot flame is monitored using YD No
a heat sensing device designed to detect the presence of a flame.
3. All periods when the flare pilot did not have a flame have been YD No
recorded and reported in the PR.b
IF THE CONTROL DEVICE IS A THERMAL INCINERATOR
1. Either the results of the initial performance test were submitted in YD N D
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. Either (1) test documentation demonstrates98 percent HAP or YD ND
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3 A temperature monitoring device equipped with a continuous YD No
monitor is used to measure the temperature of the gas stream in
the firebox (or in the ductwork immediately downstream of the
firebox before any substantial heat exchange occurs).
4. Documentation to establish a site-specific range for firebox YD N a
temperature was submitted in the NCSa or operating permit
application.
5. Continuous records^ of firebox temperature are kept0 YD N D
6. Records of daily average firebox temperature are kept. YD N D
(continued)
pjsjl 35/table-6.04 6-18
-------
TABLE 6-4. COMPUANCE CHECKUST FOR TRANSFER OPERATIONS
7. All daily average firebox temperatures that are outside the site- YD No
specific established range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
8. The number of excursions does not exceed the number of YD No
excused excursions in the semi-annual reporting period.6
9. If the firebox temperature is not monitored, the facility has YD N a
documentation that they applied for and received approval to
monitor an alternative parameter, and are performing the required
recordkeeping and reporting.
[Note: If #9 is checked "Yes", the facility is in compliance even if
numbers 3 through 8 are checked "No".]
IF THE CONTROL DEVICE IS A CATALYTIC INCINERATOR
1. Either the results of the initial performance test were submitted In YD No
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. Either (1) test documentation demonstrates 98 percent HAP or YD No
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3. Temperature monitoring devices equipped with continuous YD N D
recorders are used to measure the temperature in the gas stream
immediately before and after the catalyst bed.
4. Documentation to establish a site-specific range for the gas YD N D
stream temperature upstream of the catalyst bed and the
temperature difference across the bed was submitted in the NCSa
or operating permit application.
5. Continuous records0' are kept of the temperature of the gas YD N D
stream upstream of the catalyst bed and the temperature
difference across the catalyst bed.c
6. Records of the daily average temperature upstream of the YD N D
catalyst bed and the temperature difference across the catalyst
bed are kept.
(continued)
p|s|135Asble-6.04 6-19
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
7. All daily average upstream temperatures that are outside the site- YD N o
specific range and all operating days when insufficient monitoring
data are collected are reported in the PR.b
8. All daily average temperature differences across the catalyst bed YD N a
that are outside the site-specific range and all operating days
when insufficient monitoring data are collected are reported in the
PR.b
9. The number of excursions does not exceed the number of YD N a
excused excursions in the semi-annual reporting period.6
10. If the temperature upstream of the catalyst bed and/or the YD No
temperature differential across the catalyst bed are not monitored,
the facility has documentation that they applied for and received
approval to monitor an alternative parameter, and are performing
the required recordkeeping and reporting.
[Note: If #10 is checked "Yes", the facility is in compliance even if
numbers 3 through 9 are checked "No".]
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER WITH
A DESIGN HEAT INPUT CAPACITY LESS THAN 44 MEGAWATTS AND
THE VENT STREAM IS NOT INTRODUCED WTTH THE PRIMARY FUEL
1. Either the results of the initial performance test were submitted in YD N a
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. A description of the location at which the vent stream is YD .No
introduced into the boiler or process heater was submitted in the
NCS.a
3. The vent stream is introduced into the flame zone of the boiler or YD N D
process heater.
4. Either (1) test documentation demonstrates 98 percent HAP or YD N D
TOO control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
5. A temperature monitoring device equipped with a continuous YD N D
monitor is used to measure the temperature of the gas stream in
the firebox.
(continued)
p|s|135/table-6.04 6-20
-------
TABLE 6-4. COMPUANCE CHECKLIST FOR TRANSFER OPERATIONS
6. Documentation to establish a site-specific range for firebox Y a
temperature was submitted in the NCSa or operating permit
application.
7. Continuous records^ are kept of the firebox temperature.0 Y o
8. Records of the daily average firebox temperature are kept. Y o
9. All daily average firebox temperatures that are outside the site- Y a
specific range and all operating days when insufficient monitoring
data are collected are reported in the PR.b
10. The number of excursions does not exceed the number of YD
excused excursions in the semi-annual reporting period.6
11. If the firebox temperature is not monitored, the facility has Y a
documentation that they applied for and received approval to
monitor an alternative parameter, and are performing the required
record keeping and reporting.
No
No
No
No
No
NO
[Note: If #1 1 is checked "Yes", the facility is in compliance even if
numbers 5 through 10 are checked "No".]
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER WITH
A DESIGN HEAT INPUT CAPACITY GREATER THAN 44 MEGAWATTS
1. A description of the location at which the vent stream is Y o
introduced into the boiler or process heater was submitted in the
NCS.a
2. The vent stream is introduced into the flame zone of the boiler or YD
process heater.
No
No
IF THE CONTROL DEVICE IS A SCRUBBER (FOLLOWING A
COMBUSTOR FOR A HALOGENATED VENT STREAM)
1. Either the results of the initial performance test were submitted in
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
Yo
No
(continued)
pjs|135/table-«.04
6-21
-------
TABLE 6-4. COMPUANCE CHECKLIST FOR TRANSFER OPERATIONS
2. Either (1) test documentation demonstrates 99 percent control Y a N a
efficiency for total halogens and hydrogen halkjes or test
documentation demonstrates that the outlet mass of total
hydrogen halides and halogens are less than 0.45 kilograms per
hour, or (2) if the scrubber was installed prior to December 31,
1992, test documentation demonstrates 95 percent control
efficiency for total halogens and hydrogen halides or test
documentation demonstrates that the outlet mass of total
hydrogen halides and halogens are less than 0.45 kilograms per
hour.
3. A pH monitoring device equipped with a continuous recorder is Y a N a
used to monitor the pH of the scrubber effluent.
4. A flow meter equipped with a continuous recorder is used to YD No
measure the influent liquid flow and effluent vapor flow.
5. Documentation to establish a site-specific range for the pH, and YD No
liquid/gas ratio was submitted in the NCSa or operating permit.
6. Continuous records0* of the pH of the scrubber effluent are kept. YD N D
7. Continuous records^ of the scrubber liquid/gas ratio are kept0 YD No
8. Records of the daily average pH and the daily average liquid/gas YD N D
ratio are kept.
9. All daily average pH values of the scrubber effluent that are YD N D
outside the site-specific range and all operating days when
insufficient monitoring data are collected are reported in the PR.b
10. All daily average scrubber liquid/gas ratios that are outside the YD No
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
11. The number of excursions does not exceed the number of YD N a
excused excursions in the semi-annual reporting period.6
12. If the pH and/or the scrubber liquid to gas ratio are not YD No
monitored, the facility has documentation that they applied for
and received approval to monitor an alternative parameter, and
are performing the required recordkeeping and reporting.
[Note: If #12 is checked "Yes", the facility is in compliance even if
numbers 3 through 11 are checked 'No'.]
(continued)
p)s]135Aable-6.04 6-22
-------
TABLE 6-4. COMPUANCE CHECKUST FOR TRANSFER OPERATIONS
IF THE RECOVERY DEVICE IS A CARBON ADSORBER
1. Either the results of the initial performance test were submitted in Y a No
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. Either (1) test documentation demonstrates 98 percent HAP or YD No
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3. An integrating regeneration stream (e.g., steam) flow monitoring YD No
device having an accuracy of jMO percent and capable of
recording total regeneration stream mass flow for each
regeneration cycle is used to measure regeneration stream flow.
4. A carbon bed temperature monitoring device capable of YD No
recording the carbon bed temperature after each regeneration
and within 15 minutes of completing any cooling cycle is used to
measure carbon bed regeneration temperature.
5. Documentation to establish a site-specific range for the YD No
regeneration stream flow and carbon bed regeneration
temperature was submitted in the NCSa or operating permit.
6. Records are kept of the total regeneration stream mass flow for YD N o
each carbon bed regeneration cycle.
7. Records are kept of the temperature of the carbon bed after each YD . N a
carbon bed regeneration.
8. All regeneration cycles when the total regeneration stream mass YD N a
flow is outside the site-specific range and all operating days when
insufficient monitoring data are collected are reported in the PR.b
9. All regeneration cycles during which the temperature of the YD No
carbon bed after regeneration is outside the site-specific range
and all operating days when insufficient monitoring data are
collected are reported in the PR.b
10. The number of excursions does not exceed the number of YD No
excused excursions in the semi-annual reporting period.6
(continued)
p|s|135/tal>le-6.04 ' 6-23
-------
TABLE &-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
11. If the regeneration stream flow and/or the carbon bed
regeneration temperature are not monitored, either
(a) The facility has documentation that they applied for and YD N D
received approval to monitor an alternative parameter,
and are performing the required recordkeeping and
reporting .or continue with hems [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration level or YD N D
reading indicated by an organic monitoring device at the
outlet of the control device.
(c) Records are kept of the daily average concentration level YD N a
or reading for each operating day.
(d) All daily average concentration levels or readings that are YD N D
outside the site-specific range are reported in the PR.b
[Note: If #11 (a) is checked "Yes", or If 11 (b) and 11 (c) and 11 (d)
are checked "Yes", the facility is in compliance even If numbers 3
through 10 are checked "No".]
IF THE RECOVERY DEVICE IS AN ABSORBER
1. Either the results of the initial performance test were submitted in YD No
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. Either (1) test documentation demonstrates 98 percent HAP or YD N D
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified In the NCS.
3. A temperature monitoring device and a specific gravity monitoring YD N D
device equipped with a continuous monitor are used to measure
the exit temperature of the scrubbing liquid and the exit specific
gravity.
4. Documentation to establish a site-specific range for the exit YD N D
temperature of the scrubbing liquid and exit specific gravity was
submitted in the NCSa or operating permit
5. Records of the daily average exit temperature of the scrubbing YD N D
liquid and exit specific gravity are kept
(continued)
p|s)135/table-6.04 6-24
-------
TABLE 6-4. COMPLIANCE CHECKLIST FOR TRANSFER OPERATIONS
6. Continuous records^ of the exit temperature of the absorbing Y a
liquid are kept.0
7. Continuous records^ of the exit specific gravity are kept. Y a
8. All daily average exit temperatures of the absorbing liquid that are Y a
outside the site-specific range and all operating days when
insufficient monitoring data are collected are reported in the PR.b
9. All daily average exit specific gravity values that are outside the Y o
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
10. The number of excursions does not exceed the number of YD
excused excursions in the semi-annual reporting period.6
11. If the exit temperature and/or the exit specific gravity are not
monitored, either:
(a) The facility has documentation that they applied for and Y a
received approval to monitor an alternative parameter,
and are performing the required recordkeeping and
reporting .or continue with items [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration level or Y a
reading indicated by an organic monitoring device at the
outlet of the control device.
(c) Records are kept of the daily average concentration level Y o
or reading for each operating day.
(d) All daily average concentration levels or readings that are Y D
outside the site-specific range are reported In the PR.b
[Note: If #11 (a) Is checked "Yes", or if 11 (b) and 11 (c) and 11 (d)
are checked "Yes", the facility is in compliance even if numbers 3
through 10 are checked "No".]
ND
No
ND
ND
ND
ND
ND
No
ND
IF THE RECOVERY DEVICE IS A CONDENSER
1. Either the results of the initial performance test were submitted in
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
YD
No
(continued)
pjs|135/ta&le-6.04
6-25
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
2. Either (1) test documentation demonstrates 98 percent HAP or YD N D
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3. A temperature monitoring device equipped with a continuous YD N a
recorder is used to measure the product side exit temperature.
4. Documentation to establish a site-specific range for the exit YD No
temperature was submitted in the NCSa or operating permit
5. Records of the daily average exit temperature are kept Y a N a
6. Continuous records01 of the exit temperature are keptc YD N a
7. All product side daily average exit temperatures that are outside YD N D
the site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.*3
8. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.6
9. If the exit temperature is not monitored, either
(a) The facility has documentation that they applied for and YD No
received approval to monitor an alternative parameter,
and are performing the required recordkeeping and
reporting .or continue with items [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration level or YD N D
reading indicated by an organic monitoring device at the
outlet of the control device.
(c) Records are kept of the daily average concentration level YD N D
or reading for each operating day.
(d) All daily average concentration levels or readings that are YD N D
outside the site-specific range are reported in the PR.b
[Note: If #9(a) is checked "Yes", or if 9(b) and 9(c) and 9(d) are
checked "Yes", the facility is in compliance even if numbers 3
through 8 are checked "No'.]
(continued)
p]s|135/table-6.04 6-26
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
r
IF THE RECOVERY DEVICE IS A VAPOR-BALANCING SYSTEM AND
THE LOADING OPERATION IS SUBJECT TO HON TRANSFER
PROVISIONS*
1. Records are kept of all parts of any vapor-balancing system that
are designated as either unsafe-to-inspect or difficult-to-inspect.
2. For equipment that Is designated as difficult to inspect, a written
plan is kept that requires inspection of equipment at least once
every five years.
3. For equipment that is designated as unsafe to inspect, a written
plan is kept that requires inspection of equipment as frequently as
practicable.
4. For each inspection during which a leak was detected, the
following information is recorded and reported.
(a) Instrument identification numbers, operator name or
initials, and equipment identification information;
(b) The date the leak was detected and the date of the first
attempt to repair it;
(c) Maximum instrument reading after the leak is repaired or
determined to be non-repairable;
(d) Explanation of delay in repair, if the leak was not repaired
within 15 days after it was discovered;
(e) Name or initials of person who decides repairs cannot be
made without a shutdown;
(f) Expected date of successful repair if not repaired within
15 days;
(g) Dates of shutdowns that occur while the equipment is
unrepaired; and
(h) Date of successful repair of the leak.
5. For each inspection during which no leaks were detected, the
following records are kept:
(a) Record that the inspection was performed;
(b) Date of the inspection; and
(c) Statement that no leaks were found.
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
ND
No
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
(continued)
pjs)135/lable-6.04
6-27
-------
TABLE 6-4. COMPUANCE CHECKUST FOR TRANSFER OPERATIONS
GENERAL - FOR ANY CONTROL DEVICE, RECOVERY DEVICE, OR
VAPOR-BALANCING SYSTEM
Note: Items #1 through #4 do not apply to low leg drains, high point bleeds, analyzer vents, open-
ended valves or lines, and pressure relief valves needed for safety purposes.
1. Hourly records are kept of whether the flow indicator in the YD N D
bypass line was operating and whether flow was detected at any
time during the hour, when seal mechanisms are not used, and
2. The time and duration of ail periods when flow is diverted or the YD No
monitor is not operating are reported in the PR when seal
mechanisms are not used [or #3 and #4].
3. Records of monthly inspections are kept when seal mechanisms YD N D
are used and
4. All periods when the seal mechanism is broken, the bypass line YD N D
valve position has changed, or the key to unlock the bypass line
valve was checked out are recorded and reported in the PR when
seal mechanisms are used.
[Note: In order to be in compliance with provisions for bypass
lines either #1 and #2 must both be checked "Yes" or both #3
and #4 must be checked "Yes".]
5. All tank trucks and railcars have a current DOT pressure test YD N D
certification in accordance with the requirements of 49 CFR 180
for tank trucks or 49 CFR 173.31 for railcars or have been
demonstrated to be vapor-tight within the preceding 12 months.9
[Note: Items #6 through #10 do not apply to vapor collection
systems that are operated under negative pressure.]
6. Records are kept of all parts of any vapor-collection system that YD N D
are designated as either unsafe-to-inspect or drfficult-to-inspect.
7. For equipment that is designated as difficult to inspect, a written YD N D
plan is kept that requires inspection of equipment at least once
every five years.
8. For equipment that is designated as unsafe to inspect, a written YD N D
plan is kept that requires inspection of equipment as frequently as
practicable.
9. For each inspection during which a leak was detected, the
following information is recorded and reported.
(a) Instrument identification numbers, operator name or YD N D
initials, and equipment identification information;
(continued)
pjsj135/table-6.04 6-28
-------
TABLE 6-4. COMPUANCE CHECKUST FOR TRANSFER OPERATIONS
(b)
(c)
(d)
(e)
(0
(g)
(h)
The date the leak was detected and the date of the first
attempt to repair it;
Maximum instrument reading after the leak Is repaired or
determined to be non-repairable;
Explanation of delay In repair, If the leak was not repaired
within 15 days after it was discovered;
Name or initials of person who decides repairs cannot be
made without a shutdown;
Expected date of successful repair if not repaired within
15 days;
Dates of shutdowns that occur while the equipment Is
unrepaired; and
Date of successful repair of the leak.
YD
YD
YD
YD
YD
YD
YD
ND
ND
ND
ND
ND
ND
ND
10. For each inspection during which no leaks were detected, the
following records are kept:
(a)
(b)
(c)
Record that the inspection was performed;
Date of the inspection; and
Statement that no leaks were found.
YD
YD
YD
ND
ND
No
GENERAL - FOR GROUP 1 AND GROUP 2 TRANSFER RACKS
1. Records are kept of the design and actual annual throughput of YD N D
the loading rack, the weight percent HAP of liquid loaded, and
the annual rack weighted average HAP vapor pressure.
V1SUAL INSPECTION
1. A flow indicator is present at the entrance to any bypass line that YD N D
could divert the vent stream flow away from the control device to
the atmosphere .or all bypass line valves are sealed in a closed
position (e.g., with a car seal or lock-and-key configuration).
2. For flares, a device for detecting the flame is present YD N D
3. For all incinerators, and for boilers and process heaters with YD N D
design heat input capacities less than 44 megawatts and the vent
steam is not introduced with the primary fuel, a temperature
monitoring device is present.
(continued)
p)s|135Aable-.04 6-29
-------
TABLE 6-4. COMPLIANCE CHECKLIST FOR TRANSFER OPERATIONS
4. For scrubbers used after combustors for halogenated vent YD No
streams, a device for measuring pH and a device for measuring
flow are present.
5. For carbon adsorbers, a device for measuring carbon bed YD N D
temperature and a device for measuring regeneration stream flow
are present [or #8].
6. For absorbers, a device for measuring exit liquid temperature and YD N D
a device for measuring exit specific gravity are present [or #8].
7. For condensers, a temperature monitoring device is present YD N a
[or #8].
8. If the monitoring devices listed in items 5 through 7 are not YD No
present, an organic compounds monitor is present
[Note: If item #8 is checked "Yes", the facility is in compliance
even if numbers 5 through 7 are checked "No".]
9. Visual inspection of the facility is consistent with written records. Y o No
a NCS = Notification of Compliance Status.
b PR = Periodic Reports.
c For transfer racks that transfer less than 11.8 million liters per year of liquids containing organic
HAP's, the owner or operator may conduct a design evaluation and monitor the design parameters
instead of conducting a performance test.
d Continuous records, as defined in §63.111, means documentation, either in computer readable
form or hard copy, or data values measured at least once every 15 minutes and recorded at the
frequency specified in §63.152(f). Section 63.152(0 allows the owner to record either values
measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
all measured values during each period. If the daily average value of a monitored value for a given
parameter Is within the range established in the NCS, the owner or operator may retain block hourly
averages instead of the 15-minute values. An owner or operator may request approval to use
alternatives to continuous monitoring under §63.151 (g) of Subpart G.
(continued)
pjs)135/table-6.04 6-30
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
6 The number of excused excursions is as follows:
For the first semi-annual period after the NCS is due - 6 excursions;
For the second semi-annual period - 5 excursions;
For the third semi-annual period - 4 excursions;
For the fourth semi-annual period - 3 excursions;
For the fifth semi-annual period - 2 excursions;
For the sixth and all subsequent semi-annual periods -1 excursion.
An excursion occurs when: (1) the daily average value of the monitored parameter is outside the
range established in the NCS or operating permit; or (2) if monitoring data are insufficient. In order
to have sufficient data, a source must have measured values for each 15-minute period within each
hour for at least 75 percent of the hours the control device is operating in a day. For example, if a
control device operates 24 hours per day, data must be available for all 15-minute periods in at
least 18 hours; but up to 6 hours may have Incomplete data. If more than 6 hours have incomplete
data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
hour of incomplete data is allowed.
' Under §63.111 (d)(2) of Subpart G, the owner or operator may be exempt from the transfer
provisions during operations during which vapor balancing is used. However, the owner or
operator may elect to designate the rack as a transfer rack subject to the HON and comply with the
provisions of §63.126 through §63.130 during operations when vapor balancing is used. For
example, an owner or operator may elect to be subject In order to include the rack In an emissions
average.
9 This requirement does not apply for operations during which a vapor balancing system is used.
NOTE ALL DEFICIENCIES
pjsj135rtat>le-6.04 6-31
-------
SECTION 7
STORAGE VESSELS
7.1 DESCRIPTION OF EMISSION POINT
Two types of storage vessels are of concern In Inspecting a SOCMI facility: fixed-roof
storage vessels (I.e., with no internal floating roof) and floating roof storage vessels. They are
exclusively above-ground and cylindrical In shape with the axis perpendicular to the foundation. There
are also horizontal tanks, but these are generally smaller and not as widely used.
7.1.1 Fixed-Roof Storage Vessel
A typical fixed-roof vessel is a cylindrical steel shell with a cone- or dome-shaped roof
permanently affixed to it. Refer to Section 4.1.1 and Figure 4-1 of the Benzene Storage Inspection
Manual1 for a description of typical fixed-roof vessels and their potential emission points. As described
in the Benzene Storage Inspection Manual1, most emissions from these vessels are released through
roof vents. Gauge hatches/sample wells, float gauges, and roof manholes on the fixed roof, which
provide access to these tanks, also are potential, but less significant sources of emissions.
7.1.2 Floating Roof Storage Vessel
A floating roof vessel is a cylindrical steel shell equipped with a disk-shaped deck with a
diameter slightly less than the Inside tank diameter. The floating deck floats freely on the surface of the
stored liquid, rising and falling with the liquid level. The liquid surface Is completely covered by the
floating deck, except in the small annular space between the deck and the shell. A rim seal attached to
the floating deck slides against the vessel wall as the deck is raised or lowered, covering the annular
space where the deck is not covering the liquid. Refer to Section 4.1.2 and Figure 4-2 of the Benzene
Storage Inspection Manual1 for a general description of a floating roof vessel and a general discussion
of emissions from these vessels.
For compliance with the storage vessel provisions, the HON allows three specific types of
floating roof storage vessels: an external floating roof (EFR) vessel, an internal floating roof (IFR) vessel
(i.e., a fixed roof vessel with an IFR), and an EFR vessel converted to an IFR vessel (i.e., a fixed roof
installed above an EFR). These floating roof storage vessel types are described below. Each discussion
refers to specific sections and figures In the Benzene Storage Inspection Manual1 for more detail. The
sections referred to in the Benzene Storage Inspection Manual1 include discussions about the
requirements of the Benzene Storage NESHAP and descriptions of the vessel types. In some cases, the
requirements In the HON will differ from the requirements of the Benzene Storage NESHAP.
p)s)115/secl-7.sl
7-1
-------
7.1.2.1 External Floating Roof Vessel
An EFR vessel does not have a fixed roof; instead, its floating deck is the only barrier
between the stored liquid and the atmosphere. An EFR vessel may have several types of rim seals and
deck fittings. Refer to Section 4.1.2.1 and Figure 4-4 of the Benzene Storage Inspection Manual1 for a
description of a typical EFR vessel and associated emissions. In reviewing the Benzene Storage
Inspection Manual,1 note that two types of deck fittings, a gauge hatch and a sampling port, are not
shown in Figure 4-4, but are mentioned in Section 4.1.2.1. Rim seals associated with EFR vessels are
described in Section 4.1.2.3 of the Benzene Storage Inspection Manual1 and the associated figures.
7.1.2.2 Internal Floating Roof Vessel
An IFR vessel is equipped with a permanently affixed roof above the floating deck. Refer to
Section 4.1.2.2 and Figure 4-5 of the Benzene Storage Inspection Manual1 for details. In reviewing
Figure 4-5, note that the deck fittings and the rim space vent for a mechanical shoe seal are not shown.
A rim space vent is illustrated in Figure 4-4 of the Benzene Storage Inspection Manual1 for an EFR
vessel, and would be the same on an IFR vessel equipped with a mechanical shoe seal. Seals
ociated with IFR vessels are described in Section 4.1.2.3 of the Benzene Storage Inspection Manual1
the associated figures.
2.3 External Floating Roof Vessel Converted to an Internal Floating Roof Vessel
The HON specifies that an EFR vessel may be converted to an IFR vessel in order to
comply with the storage provisions. This conversion is accomplished by affixing a permanent roof to an
EFR vessel, above the floating deck, and equipping the EFR with a seal mechanism equivalent to those
required for an IFR. These converted vessels would have the external appearance of an internal floating
roof vessel, deck fittings required for an external floating roof vessel, and a rim seal with the
characteristics of an IFR vessel. In the Benzene Storage Inspection Manual,1 Figure 4-5 shows the
characteristics of the permanently affixed roof applicable to a vessel converted from an EFR to an IFR,
and Figure 4-4 shows the characteristics of the floating deck applicable to an EFR converted to an IFR.
The types of seals applicable to an EFR converted to an IFR would be the same as those for an IFR
vessel described in Section 4.1.2.3 of the Benzene Storage Inspection Manual1 and its associated
figures.
7.2 DESCRIPTION OF EMISSION CONTROL TECHNOLOGIES
The control techniques to reduce emissions from storage vessels include equipment designs
(e.g., seal design and fittings closure) and work practices.
7.2.1 Fixed-Roof Vessels
Emissions from a fixed-roof vessel may be reduced by equipping it with either a floating roof
(i.e. . -inverting It to an IFR vessel) or by using a closed vent system routed to a 95-percent efficient
p|sJ133/sect-7.st
9/13/94 7-2
-------
control device. Under the HON, if a fixed roof vessel .Is equipped with an IFR, it Is considered an IFR
vessel and would be required to be equipped with certain controls and meet certain work practices for
an IFR* as described In Section 7.2.2.
A closed vent system captures the vapors released by the fixed roof vessel and transfers
them to a product recovery or combustion control device. Refer to Section 5.2 of this manual for a
description of product recovery and combustion control devices. These same devices would be allowed
by the storage provisions.
A closed vent system and control device could also be applied to a horizontal tank.
Because of the tank configuration, a floating roof cannot be applied to a horizontal tank.
7.2.2 Floating Roof Vessels
As discussed In Section 7.1.2, the three types of floating roof vessels are IFR vessels, EFR
vessels, and EFR vessels converted to IFR vessels.
There are three methods for controlling emissions from floating roof vessels: applying
controls to deck fittings, employing certain types of seals, and employing certain work practices.
Examples of these three methods are to equip the covers on certain deck fittings with gaskets, to equip
an EFR or IFR with a liquid-mounted seal instead of a vapor-mounted seal, and to keep all covers
associated with deck fittings closed at all times except for access, respectively. Refer to Sections 4.1.2.1
and 4.1.2.2 In the Benzene Storage Inspection Manual1 for descriptions of the equipment and work
practice controls that may be applied to deck fittings on EFR vessels and IFR vessels, respectively. For
information on applying controls to the deck fittings of an EFR converted to an IFR, refer to the
discussion about controls applied to fittings of EFR vessels In Section 4.1.2.1 of the Benzene Storage
Inspection Manual.1 For a description of the types of seals that can be used to control emissions from
floating roof vessels, refer to Section 4.1.2.3 of the Benzene Storage Inspection Manual.1
The deck fitting control requirements in the HON are similar but not equivalent to the control
requirements of the Benzene NESHAP which are described in the Benzene Storage Inspection Manual.1
The HON specifies a few additional deck fitting controls that are not discussed in the Benzene Storage
Inspection Manual.1 For example, for EFR vessels, the HON specifies the following three additional
controls: (1) roof drains must have a slotted membrane fabric cover that covers 90 percent of the area
of the opening. (2) openings with covers must be bolted when dosed, and (3) guide pole wells must
have a sliding cover or flexible fabric sleeve seal and, if the guide pole is slotted, a gasketed float Inside
the guide pole. For IFR vessels, the HON specifies the following two additional controls: (1) ladder
wells must have a gasketed sliding cover, and (2) rim vents must be gasketed and closed except when
the IFR is not floating on the stored liquid or when the pressure beneath the rim seal exceeds the
manufacturer's recommended setting. Sections 4.1.2.1 and 4.1.2.2 in the Benzene Storage Inspection
Pj3j135/sect-7.st
. 7-3
-------
Manual1 should be consulted to gain familiarity with the control options for deck fittings on floating roof
vessels.
i
7.3 STORAGE VESSEL PROVISIONS
This section summarizes the storage vessel provisions in §63.119 through §63.123 of
Subpart G.
7.3.1 Storage Vessel Definition
A "storage vessel' is a tank or other vessel that is used to store liquid organic HAP's and is
assigned to a chemical manufacturing process subject to the HON. Storage vessels do not include
vessels permanently attached to motor vehicles, pressure vessels, vessels with capacities less than
38 m3. or vessels storing liquids that contain organic HAP's only as impurities.
T3.2 Storage Vessel Group Determination
Group 1 and Group 2 storage vessels are defined in §63.119 of Subpart G. The vessel's
design capacity and the vapor pressure of the stored liquid are used to determine whether a storage
vessel is Group 1 or Group 2. Table 7-1 is a checklist for applicability and group determination for
storage vessels. Section I of the table presents a set of true/false statements which can be used to
determine If a storage vessel is subject to the storage vessel provisions of the HON. Sections II and III
of Table 7-1 can be used to determine If a storage vessel subject to the storage vessel provisions of the
HON is Group 1 or Group 2. Section II pertains to storage vessels at new sources, and Section III
oertains to storage vessels at existing sources. Group 1/Group 2 determinations are required for each
v.orage vessel that Is subject to the storage vessel provisions, unless the storage vessel Is already in
compliance with the Group 1 requirements.
Storage vessels that are not subject to the storage vessel provisions may be subject to the
equipment leak provisions in Subpart H (NESHAP for SOCMI equipment leaks) or the wastewater
provisions In Subpart G, as noted in the checklist
7.3.3 Storage Vessel Control Requirements
Group 1 storage vessels must meet the control requirements in §63.119 of Subpart G unless
they are included in an emissions average. Compliance options for Group 1 storage vessels include:
Reducing emissions of organic HAP's using a fixed-roof tank equipped with an
internal floating roof which is operated according to specified work practices
(e.g., keeping access hatches closed and bolted), equipped with specified deck
fittings, and equipped with specified seal configurations (i.e., a single liquid-
mounted seal, a single metallic shoe seal, or double seals);
Reducing emissions of organic HAP's using an external floating roof tank
operated according to specified work practices, equipped with specified deck
p)sJ135/sect-7.s1
7-4
-------
TABLE 7-1. APPLICABILITY AND GROUP DETERMINATION CHECKLIST
FOR STORAGE VESSELS
I.
Storage Vessel ApplicabPity
a. The storage vessel stores organic HAP for a chemical
manufacturing process subject to the HON.
b. The capacity of the storage vessel Is greater than or equal to
38m3.
c. The storage vessel is not a pressure vessel designed to operate
To
Tn
TD
Fn
Fo
Fa
In excess of 204.9 kPa and without emissions to the
atmosphere.
d. The organic HAP's stored in the vessel are not considered To Fa
Impurities.
e. The storage vessel is not a product accumulator vessel.8 T D F n
f. The storage vessel is not permanently attached to a motor T a Fa
vehicle.
g. The storage vessel is not a wastewater storage tank.0 To F D
Is the storage vessel subject to the HON storage vessel provisions?
a Yes: If all of the statements above are true, the storage vessel
is subject to the storage vessel provisions in Subpart G
of the HON.
D No: If any of the statements above are false, the storage
vessel is not subject to the storage vessel provisions In
Subpart G of the HON.
II. Group Determination For Storage Vessels at New Sourcesc>d
(Complete this portion only if the answer to Section I is "yes'.)
a. The storage vessel capacity te greater than or equal to 151 m^. Tn FD
and the vapor pressure of the stored organic HAP is greater
than or equal to 0.7 kPa.e
b. The storage vessel capacity is greater than or equal to 38 m3 T D Fa
and less than 151 m3, and the vapor pressure of the stored
organic HAP is greater than or equal to 13.1 kPa.e
(continued)
pjs|135/lable-7.0l 7-5
-------
TABLE 7-1. APPLICABILITY AND GROUP DETERMINATION CHECKLIST
FOR STORAGE VESSELS
Is the storage vessel Group 1?
D Yes: The storage vessel Is Group 1 if either of the above
statements Is true.
D No: The storage vessel Is Group 2 If both of the above
statements are false.
III. Group Determination For Storage Vessels at Existing Sources0-*
(Complete this portion only If the answer to Section I is "yes".)
a. The storage vessel capacity is greater than or equal to 151m3 To FD
and the vapor pressure of the stored organic HAP is greater
than or equal to 5.2 kPa.e
b. The storage vessel capacity Is greater than or equal to 75m3 To F n
and less than 151m3, and the vapor pressure of the stored
organic HAP is greater than or equal to 13.1 kPa.6
Is the storage vessel Group 1?
D Yes: The storage vessel is Group 1 if either of the above
statements is true.
D No: The storage vessel is Group 2 if both of the above
statements are false.
1 If false, the emission point may be subject to the equipment leak provisions in Subpart H of the
HON.
b If false, the emission point may be subject to the wastewater provisions in Subpart G of the
HON.
c Group 1 storage vessels must meet the control requirements in Section 63.119 of Subpart G of
the HON, unless they are included in an emissions average. Group 2 storage vessels are not
required to apply additional controls.
d A 'new* source refers to a source (not a storage vessel) that commenced construction or
reconstruction after December 31, 1992.
"Vapor pressure' refers to the maximum true vapor pressure of total organic HAP at storage
temperature.
' An 'existing* source refers to a source (not a storage vessel) that commenced construction or
reconstruction before December 31.1992.
Pt8)lT5/tal>le-7.01 7-6
-------
fittings, and equipped with specified seal configurations (i.e., double seals, with
the primary seal to be either a liquid-mounted or a metallic shoe seal);
Reducing emissions of organic HAP's using an external floating roof tank
converted to a fixed-roof tank equipped with an Internal floating roof, which is
operated according to specified work practices, equipped with specified deck
finings, and equipped with specified seal configurations (i.e., a single liquid-
mounted seal, a single metallic shoe seal, or double seals); or
Reducing emissions of organic HAP's by 95 weight percent using a closed vent
system (i.e., vapor collection system) and control device (or reducing emissions
of organic HAP's by 90 weight percent using a closed-vent system and control
device If the control device was installed before December 31,1992).
A detailed list of the work practices and deck fittings specified for internal floating roof vessels, external
floating roofs, and external floating roof vessels converted to internal floating roof vessels is provided in
Table 7-2, which is discussed in the next section.
Group 2 storage vessels are not required to apply any emission controls, but recordkeeplng
and reporting is required to verify that they are Group 2.
7.3.4 Storage Vessel Testing. Monitoring. Recordkeeplng. and Reporting
Compliance determination for storage vessels using floating roofs is different than for
process vents and transfer operations in that performance testing and continuous monitoring are not
required. Instead, periodic inspections of the floating roofs and their seals and fittings are required, and
any defects must be repaired within specified time periods.
For both Group 1 and Group 2 storage vessels, a record must be kept which provides the
dimensions and an analysis showing the capacity of each Group 1 and Group 2 storage vessel. For
Group 2 storage vessels, this recordkeeping requirement is the only requirement under the HON, unless
the vessel is included In an emission average.
Initial testing for visible emissions (i.e., as specified In §63.11(b) of Subpart A) is required for
Group 1 storage vessels controlled with flares. The initial testing is not a performance test, but Is a
compliance determination. The compliance determination also Involves gathering data such as the heat
content the flow rate, and the exit velocity for all periods when the pilot flame is absent The initial
recordkeeping and reporting (i-e., as part of the Notification of Compliance Status) includes records and
reports of flare design; visible emission readings and measurements of the heat content the flow rate,
and the exit velocity made during the compliance determination; and, periods when the pilot flame is
absent
Initial performance tests are not required for vapor collection systems or control devices
other than flares. Instead, a report is required to be submitted as part of the Implementation Plan which
p)s]133/sect-7.st
9/13/94 7-7
-------
demonstrates that the control device being used achieves the required percent reduction, during
reasonably expected maximum loading conditions. This documentation must include a design
evaluation of the control device and a description of the gas stream which enters the control device,
Including flow and organic HAP content under varying liquid level conditions (dynamic and static). This
documentation is not required for enclosed combustion devices with a minimum residence time of
0.5 seconds and a temperature of at least 760°C. For thermal incinerators, carbon adsorbers, and
condensers, the design evaluation must include additional information specified in the storage provisions
under §63.l20(d)(1). If the control device used to comply with the storage provisions is also used to
comply with the process vent, transfer, or wastewater provisions, the performance test required by the
process vent, transfer, or wastewater provisions is acceptable to demonstrate compliance with the
storage provisions and a design evaluation would not be required.
As part of the Implementation Plan, the owner or operator must also submit the following:
(1) a description of the parameter(s) to be monitored to ensure that the control device is operated and
maintained in conformance with Its design, (2) an explanation of the criteria used for selection of the
parameter(s), and (3) the frequency with which monitoring wDI be performed. The owner or operator
must submit in the Notification of Compliance Status the operating range for each monitoring parameter
Identified in the Implementation Plan. This specified operating range must represent the conditions for
which the control device can achieve the 95 percent or greater emission reduction, or a 90 percent or
greater emission reduction if installed prior to December 31,1992.
Initial performance testing is not required for Group 1 storage vessels equipped with an
Internal floating roof, an external floating roof, or external floating roof converted to an internal floating
roof. However, for external floating roof vessels, an initial measurement of seal gap area and maximum
seal gap width for both the primary seal and the secondary seal is required to be performed and
recorded during the hydrostatic testing of the vessel or by the compliance date, whichever is later, and
to be reported in the first periodic report.
Periodic inspection, measurement, recordkeeping, and reporting requirements for storage
vessels equipped with an internal floating roof, an external floating roof, or an external floating roof
converted to an internal floating roof are presented in Table 7-2. Continuous and periodic monitoring,.
recordkeeping, and reporting requirements associated with dosed vent systems and control devices for
storage vessels are presented in Table 7-3. Included in the tables are both 'periodic reports', which are
submitted semt-annually, and 'other reports', which are submitted as needed, on an irregular basis.
The HON also requires periodic inspection of closed vent systems to detect leaks. The
provisions are specified in §63.148 of Subpart G.
pjs|135/sect-7.st
9/13/94 7-8
-------
TABLE 7-2. PERIODIC INSPECTION. MEASUREMENT. RECORDKEEPING, AND REPORTING REQUIREMENTS
FOR STORAGE VESSELS EQUIPPED WTTH AN INTERNAL FLOATING ROOF VESSEL. AN EXTERNAL FLOATING
ROOF, OR AN EXTERNAL FLOATING ROOF VESSEL CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL
Control
Device
Type and Frequency of
Inspection or
Measurement8
Parameters to be
Inspected or
Measured
Recordkeeplng and Reporting for Inspected or Measured Parameters
IFR or EFR
converted to
IFRb
External Visual
Inspection0-0' (performed
annually)
[For vessels equipped
with a single-seal system:
63.120(a)(2)(l)]
[For vessels equipped
with a double-seal
system: 63.120(a) (3) (II))
Seal6, floating
deck
1. Record and report the date of the Inspection - PR*
2. Record and report each storage vessel In which a failure was
detected and a description of the failure - PR
Seal failures Include the following: (1) the seal Is detached from
the floating deck, (2) holes, tears, or other openings In the seal
or seal fabric, and (3) any visible gaps between the seal and
the wall of the storage vessel. Floating deck falures Include
the following: (1) the IFR Is not resting on the surface of the
liquid storage In the storage vessel and Is not resting on the
leg supports, and (2) there Is liquid on the floating deck.
3. If a failure Is detected and repaired within 45 days, record and report
the nature of and date the repair was made - PR
4. If a failure Is detected and the vessel Is not emptied for repair within
45 days, the owner or operator may choose to utilize up to two
extensions of 30 days each, In which case the owner or operator
must Include In the next Periodic Report, documentation that
alternate storage capacity was unavailable, a description of the
failure, a schedule of actions that ensured that the control equipment
was repaired or the storage vessel was emptied as soon as possible,
and the nature of and date the repair was made, or the date the
storage vessel was emptied - PR
(Continued)
-------
TABLE 7-2. PERIODIC INSPECTION, MEASUREMENT. RECORDKEEP1NG, AND REPORTING REQUIREMENTS
FOR STORAGE VESSELS EQUIPPED WITH AN INTERNAL FLOATING ROOF VESSEL, AN EXTERNAL FLOATING
ROOF, OR AN EXTERNAL FLOATING ROOF CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL -
Control
Device
Type and Frequency of
Inspection or
Measurement8
Parameters to be
Inspected or
Measured
Recordkeeplng and Reporting for Inspected or Measured Parameters
IFR or EFR
converted to
IFR
(continued)
Internal Visual Inspection
(performed each time a
vessel Is emptied and
degassed, and at least
once every 10 years)0
[For vessels equipped
with a single-seal system:
63 1
[For vessels equipped
with a double-seal
system: 63. 120 (a) (3) (III)]
Seal.9 floating
roof, gaskets,
slotted
membranes,
sleeve seals (If
any)
1. Record and report the date of the Inspection - PR
2. Record and report each storage vessel In which a failure was
detected and a description of the failure - PR
Seal failures Include any holes, tears, or other openings In the
seal or seal fabrlc.9 Floating roof failures Include any defect of
the floating deck. Gasket failures Include any time that a
gasket no longer closes off the liquid surface to the
atmosphere. Slotted membrane failures Includes any time that
a slotted membrane has more than 10 percent open area.
3. If a failure Is detected and repaired, record and report the nature of
the repair and the date the repair was made prior to refilling the
storage vessel - PR
4. Prior to each Inspection, report the date that the vessel will be refilled
after the Inspection, In order to afford the Administrator the
opportunity to have an observer present; keep a record of this
report" - OR
(Continued)
-------
TABLE 7-2. PERIODIC INSPECTION. MEASUREMENT. RECORDKEEPING, AND REPORTING REQUIREMENTS
FOR STORAGE VESSELS EQUIPPED WTTH AN INTERNAL FLOATING ROOF VESSEL. AN EXTERNAL FLOATING
ROOF. OR AN EXTERNAL FLOATING ROOF CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL -'
Control
Device
Type and Frequency of
Inspection or
Measurement8
Parameters to be
Inspected or
Measured
Recordkeeplng and Reporting for Inspected or Measured Parameters
EFR
Seal Gap Measurement'
[63 120(b)(1) through
(b)(4)], which Includes a
visual seal Inspection
[63 120(b)(5) and (b)(6)]
(performed at least once
every 5 years for the
primary seal and annually
for the secondary seal)
Primary seal and
secondary seal
1. Record and report the date of the measurement PR
2. Record and report the raw data obtained In the measurement (the
width and circumferential length of each gap with a width equal to or
greater than 0.32 centimeters), and the calculations of the
accumulated area of gaps between the vessel wall and both the
primary and secondary seal - PR
3. Record and report each occurrence when the following conditions
are Identified during the measurement: - PR
(a) The accumulated area of gaps or maximum gap width between
the vessel wall and either the primary or secondary seal
exceeds specified values!
(b) If the primary seal Is a metallic shoe seal, the upper end of the
metallic shoe seal does not extend a minimum vertical distance
of 61 centimeters above the stored liquid surface
(c) If the primary seal Is a metallic shoe seal, the lower end of the
metallic shoe seal does not extend Into the liquid
(d) There are holes, tears, or other openings In the shoe (If a
metallic shoe seal Is used), seal fabric, or seal envelope of the
primary seal
(e) There are holes, tears, or other openings In the seal or seal
fabric of the secondary seal
(Continued)
-------
TABLE 72. PERIODIC INSPECTION. MEASUREMENT, RECORDKEEPING, AND REPORTING REQUIREMENTS
FOR STORAGE VESSELS EQUIPPED WTTH AM INTERNA1 FLOATING ROOF VESSEL, AN EXTERNAL FLOATING
ROOF, OR AN EXTERNAL FLOATING ROOF CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL *
Control
Device
Type and Frequency of
Inspection or
Measurement8
Parameters to be
Inspected or
Measured
Recordkeeplng and Reporting for Inspected or Measured Parameters
EFR
(continued)
to
Seal Gap Measurement'
[63.120(b)(1) through
(b)(4)), which Includes a
visual seal Inspection
(63.120(b)(5) and (b)(6)]
(performed at least once
every 5 years for the
primary seal and annually
for the secondary seal)
(continued)
Internal Visual Inspection
(performed each time the
vessel Is emptied and
degassed) k.l
[63.120(b)(10>]
Primary and
Secondary Seal
(continued)
primary seal
secondary seal,
floating roof,
gaskets, slotted
membranes"1
4. If any of the conditions described In Items 3(a) through 3(e) are
Identified during a measurement and the repair was completed within
45 days of the measurement, record and report the nature of the
repair and the date the repair was made or the date the storage
vessel was emptied - PR
5. If any of the conditions described In Kerns 3(a) through 3(d) are
Identified during a measurement and the repair was not completed
within 45 days of the measurement, the owner or operator may utilize
up to two 30-day extensions, and must record and report In the next
PR Identification of the vessel, a description of the failure,
documentation that alternative storage capacity was not available, a
schedule of actions that ensured the control equipment would be
repaired or the vessel would be emptied as soon as possible, and the
nature of and the date the repair was made, or the date the storage
vessel was emptied - PR
6. Thirty days prior to the seal gap measurement, report the date that
the measurement will be made, In order to afford the Administrator
the opportunity to have an observer present. Keep a record of this
report - OR
1. Record and report the date of the Inspection - PR
(Continued)
-------
TABLE 7-2. PERIODIC INSPECTION. MEASUREMENT, RECORDKEEPING, AND REPORTING REQUIREMENTS
FOR STORAGE VESSELS EQUIPPED WITH AN INTERNAL FLOATING ROOF VESSEL, AN EXTERNAL FLOATING
ROOF, OR AN EXTERNAL FLOATING ROOF CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL *
Control
Device
Type and Frequency of
Inspection or
Measurement8
Parameters to be
Inspected or
Measured
Record keeping and Reporting for Inspected or Measured Parameters
EFR
(continued)
u
Internal Visual Inspection
(performed each time the
vessel Is emptied and
degassed)1*-'
(63.120(b)(10))
(continued)
primary seal
secondary seal,
floating roof,
gaskets, slotted
membranes171
(continued)
2. Record and report each storage vessel In which a failure was
detected and a description of the failure - PR
Seal failures Include any holes, tears, or other openings In the
seal of seal fabric. Roatlng roof failures Include any defect of
the floating deck. Gasket failures Include any time that a
gasket no longer doses off the liquid surface to the
atmosphere. Slotted membrane failures Includes any time that
a slotted membrane has more than 10 percent open area.
3. If a failure Is detected and repaired, record and report the nature of
the repair and the date the repair was made prior to refilling the
storage vessel - PR
4. Prior to each Inspection, report the date that the vessel will be refilled
after the Inspection, In order to afford the Administrator the
opportunity to have an observer present.9 Keep a record of this
report - OR
a Regulatory citations are listed In brackets.
b IFR = Internal floating roof.
EFR = external floating roof.
c If a double-seal rather than single-seal system Is used on the IFR or EFR converted to IFR, a source has the option to perform the
Internal visual Inspection (§63.120(a)(3)(l)] each time the vessel Is emptied and degassed and at least once every 5 years and not perform
annual external visual Inspections [§63.120(a)(3)(ll)l or Internal visual Inspections every 10 years [§63.120(a)(3)(lll)]
d External visual Inspections are visual Inspection of the specified equipment as seen from the fixed roof of a vessel, looking at the
specified equipment through the manholes and roof hatches on the fixed roof.
(Continued)
-------
TABLE 7-2. PERIODIC INSPECTION, MEASUREMENT, RECORDKEEPING. AND REPORTING ; QUIREMENTS
FOR STORAGE VESSELS EQUIPPED WITH AN INTERNAL FLOATING ROOF VESSEL, AN EXTERNAL FLOATING
ROOF, OR AN EXTERNAL FLOATING ROOF CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL - '
8 If a single-seal system Is used, Inspect the single seal. If a double-seal system Is used, Inspect the secondary seal.
1 PR = Periodic reports described In §63.152 of Subpart G, and discussed In Section 3.5.4 of this manual.
9 If a single-seal system Is used, Inspect the single seal. If a double-seal system used, Inspect both the primary and secondary seals.
n If the Inspection Is planned, this report Is due 30 days prior to the refilling. If the Inspection was not planned and the report could not be
submitted 30 days prior to the refilling, then the report should Include an explanation of why the Inspection was unplanned.
' Seal gap measurements are made according to the method described in section 63.120(b)(2) through (b)(4) of Subpart G.
I The specified values for the primary seal are:
Accumulated area of gaps between the vessel wall and the seal: 212 square centimeters per meter of vessel diameter.
Maximum gap width between the vessel wall and the seal: 3.81 centimeters.
The specified values for the secondary seal are:
Accumulated area of gaps between the vessel wall and the seal: 21.2 square centimeters per meter of vessel diameter.
Maximum gap width between the vessel wall and the seal: 1.27 centimeters.
k The storage provisions do not specify a maximum period of time between these Inspections.
' Repair each storage vessel In which a failure was detected; however, no recordkeeplng or reporting is specified In the storage provisions.
m Seal failures Include the following: the primary or secondary seal has holes, tears, or other openings In the seal or the seal fabric.
Roatlng roof failures Include any defect of the floating deck. Gasket failures Include any time that a gasket no longer closes off the
liquid surface to the atmosphere. Slotted membrane failures Include any time that a slotted membrane has more than 10 percent open
area.
-------
TABLE 7-3. PERIODIC AND CONTINUOUS MONITORING, INSPECTION. RECORDKEEPING. AND REPORTING
REQUIREMENTS FOR STORAGE VESSELS EQUIPPED WTTH A CLOSED VENT SYSTEM AND CONTROL DEVICE
Control Device
Parameters to be
Monitored or Inspected8
Recordkeeplng and Reporting for Monitored or Inspected Parameters
Flare
Meet the general control device
requirements specified In §63.11(b)
of Subpart A
(63.120(e)(4))
en
1. Record and report each occurrence when the flare does not meet the general
control device requirements specified In §63.11(b) of Subpart A - PRb
Each record and report of an occurrence when a flare does not meet the
general control device requirements should Include the following:
(1) Identification of the flare that did not meet the requirements, and (2) the
reason the flare did not meet the general control device requirements.
2. Record and report all routine maintenance of the flare that Is planned for the next
six months and that was performed during the previous six months - PR
3. Record and report the total number of hours of routine maintenance of the flare
during which the flare did not meet the general control device requirements
specified In §63.11 (b) of subpart A due to the routine maintenance0 - PR
All Control
Devices Other
than a Flare
Monitor the parameter or
parameters that are specified In the
Implementation Plan at the
specified frequency^-6
[63.120(d)(5)J
1. Report and record each occurrence when a monitored parameter Is outside of Its
parameter range (which Is documented In the Notification of Compliance Status
or the operating permit)' - PR
The report and record shall Include the following Information:
(1) Identification of the control device for which the measured parameter
was outside of Its established range, and (2) the cause for the measured
parameter to be outside of Its established range.
2. Record the measured values of the monitored parameters.
3. Record and report all routine maintenance of the control device that Is planned
for the next six months and that was performed during the previous six months -
PR
4. Record and report the total number of hours of routine maintenance of the
control device during which the control device did not reduce Inlet emissions by
95 percent (or 90 percent if the control device was Installed prior to
December 31, 1992)9 - PR
(Continued)
-------
TABLE 7-3. PERIODIC AND COK" - 'OUS MONfTORING, INSPECTION, RECORDKEEPING, AND REPORTING
REQUIREMENTS F^ ORAGE VESSELS EQUIPPED W!fH A CLOSED VENT SYSTEM AND CONTROL DEVICE
Control Device
Parameters to be
Monitored or Inspected8
Recordkeeplng and Reporting for Monitored or Inspected Parameters
;s|
8
All dosed Vent
Systems and
Control
Devlcesh
tn
Annual Leak Inspections of Closed
Vent Systems'
(63.148]
1. Record all parts of the closed vent system that are designated as difficult or
unsafe to Inspect, with an explanation of the designations and a plan for
Inspecting the equipment.'
2. Record the occurance of each annual Inspection.
3. Record and report) the results of each annual Inspection In which a leak Is
detected In the closed vent system by an Instrument reading of 500 parts per
million by volume or greater above background using Method 21 of 40 CFR 60,
Appendix A - PRk
4. If a leak, as described In Item 3, Is detected and cannot be repaired within
15 days, and If the circumstances of the repair meet certain criteria, then record
and report! that there wHI be a delay, explaining how the circumstances of the
repair meet these certain criteria; the expected date of successful repair; dates of
shutdowns that occur while the equipment Is unrepaired; and date of successful
repair.
Presence of flow diverted from the
control device to the atmosphere
[63.148(0(1)1
or
Monthly Inspections of sealed
valves |63.148(f)(2)]
1. Hourly records of whether the flow Indicator was operating and whether flow was
detected at any time during each hour
2. Record and report the times and durations of all periods when the vent stream Is
diverted through a bypass line or the monitor Is not operating - PR
or
1. Records that monthly Inspections were performed
2. Record and report all monthly Inspections that show the valves are not closed or
the seal has been changed - PR
a Regulatory citations are listed In brackets.
b PR - ,ls described In §63.152 of Subpart G, and discussed In Section 3.5.4 of this manual.
(Continued)
-------
TABLE 7-3. PERIODIC AND CONTINUOUS MONITORING. INSPECTION, RECORDKEEPING, AND REPORTING
REQUIREMENTS FOR STORAGE VESSELS EQUIPPED WITH A CLOSED VENT SYSTEM AND CONTROL DEVICE
c The record should Include the following detailed Information about each routine maintenance period: (1) the first time of day and date that the
flare did not meet the general control device requirements specified In §63.11 (b) of Subpart A, and (2) the first time of day and date that the
control device did meet the general control device requirements specified In §63.11 (b) of Subpart A at the conclusion of maintenance.
d The Implementation Plan Is described In §63.152 of Subpart G and discussed In Section 3.5.2 of this manual.
6 The owner or operator must specify a proposed monitoring parameter (or parameters) and monitoring frequency In the Implementation Plan
for approval.
' The Notification of Compliance Status Is described In §63.152 of Subpart G and discussed In Section 3.5.3 of this manual.
9 The record should Include the following detailed Information about each routine maintenance period: (1) the first time of day and date that the
control device did not achieve the required percent reduction at the beginning of maintenance and (2) the first time of day and date that the
control device did achieve the required percent reduction at the conclusion of maintenance. The required percent reduction Is 95 percent for
control devices Installed after December 31, 1992, and 90 percent for control devices Installed before December 31, 1992.
n A closed vent system Is equivalent to a vapor collection system.
' For those parts of closed vent systems designated as difficult-to-lnspect, the Inspection Is required once every 5 years as Indicated In a written
plan. For those parts of closed vent systems designated as unsafe-to-lnspect, the Inspection Is required as frequently as practicable during
safe-to-lnspect times, as Indicated In a written plan.
i The reports required for closed-vent systems are to be submitted with the reports required by §63.182(b) of Subpart H (the equipment leak
provisions).
k The record and report should Include the following: (1) Instrument Identification numbers; (2) operator name or Initials; (3) Identification of
leaking equipment; (4) date the leak was detected; (5) date of first attempt at repair; and (6) maximum Instrument reading after leak Is repaired
or determined to be non-repairable.
1 The 'certain criteria" Include the following: (1) the repair would require a process unit shutdown, or (2) the emissions of purged material
resulting from Immediate repair would be greater than the fugitive emissions associated with the leak, likely to result from delaying the repair.
-------
7.4 STORAGE VESSEL INSPECTION PROCEDURES
Table 7-4 presents a checklist that can be used to verify if a storage vessel is in compliance
with the storage provisions of the HON. The table lists the specific records and reports that a facility is
required to keep/submit for each type of control equipment used for compliance. The owner or
operator may comply using a control technique other than those listed in Table 7-4. In these cases, the
Inspector should verify that the facility obtained approval from the Administrator (or agency to which
authority has been delegated) and then verify that the approved parameters are recorded and reported.
7.5 REFERENCES
1. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards,
Stationary Source Compliance Division. NESHAP Inspection Manual: Benzene Storage
Vessels. EPA-455/R-92-006. Washington, DC. September 1991.
pjsJ13S/MCt-7.st
9/13/94 7-18
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
Complete this form for storage vessels. A "yes" response to all questions will indicate full compliance,
and a 'no* response will indicate noncompliance with the standard.
CONTROL EQUIPMENT.
DATE OF STARTUP
REVIEW OF RECORDS
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
1. Review records of Seal Gap Measurements.
(a) Records indicate that seal gap measurements were made YD No
annually for the secondary seal and every five years for
the primary seal.8
(b) When a failure is detected, the date and results of seal YD N o
gap measurements are submitted in periodic reports,
annually for the secondary seal and every five years for
the primary seal.
(c) When a failure Is detected in the seal(s), the date and YD No
results of the visual inspection of the seals (which is
performed together with the seal gap measurement) are
Included in the PR.b
(d) The date of the seal gap measurement, the raw data YD N D
obtained during the measurement, and the calculations
made are recorded.
(e) The raw data and calculations recorded for seal gap YD N D
measurements is consistent with the information reported
in the PR.
(f) For each seal gap measurement in a periodic report, YD N D
there Is a report notifying the Administrator of the
measurement in advance. If the measurement had been
planned, then the report was submitted 30 days in
advance of the measurement If the measurement was
not planned, then the report was submitted at least
7 days in advance of the measurement and included an
explanation of why the measurement was unplanned.
(continued)
pjsjl 13/Ut>le-7.04 7-19
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(g) If a failure was detected during a seal gap measurement YD No
and visual seal inspection, the PR indicated the date and
the nature 'of the repair or the date the vessel was
emptied.
(h) If the report described in (g) documents that the repair YD N n
was made more than 45 days after the failure was
detected, then the next PR Includes documentation of the
use of up to two 30-day extensions for completing the
repair, including identification of the storage vessel, a
description of the failure, documentation that alternate
storage capacity was unavailable, a schedule of actions
to be taken to repair the control equipment or empty the
vessel as soon as possible, and the date the storage
vessel was emptied and the nature of and date the repair
was made.
2. Review records of Internal visual inspections.
(a) The occurrence of each internal visual inspection is YD No
recorded.
(b) For each internal visual Inspection in which a failure was YD N D
detected, the following information is submitted in the PR:
(1) the date of the inspection, (2) Identification of all
storage vessels for which failures were detected, (3) a
description of those failures, and (4) either the date and
nature of the repair or the date the vessel was emptied.
(c) Any repairs performed as described in (b) were YD N D
completed before the repaired storage vessel was refilled.
(d) For each Internal visual inspection documented in a PR, YD N D
there is a report notifying the Administrator in advance of
the date the inspected vessel would be refilled after the
inspection. If the inspection had been planned, the report
was submitted 30 days In advance of refilling the vessel.
If the inspection was not planned, then the report was
submitted at least 7 days in advance of refilling the vessel
and included an explanation of why the inspection was
unplanned.
(continued)
Pls|135Aable-7.04 7-20
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
IF THE CONTROL EQUIPMENT IS AN INTERNAL FLOATING ROOF OR
AN EXTERNAL FLOATING ROOF CONVERTED TO AN INTERNAL
FLOATING ROOF
1. Review records of external visual inspections
(a) The occurrence of each annual external visual inspection YD N o
is recorded. If the floating roof Is equipped with double
seals, the source will not have performed this Inspection if
It chose to perform internal visual inspections once every
5 years instead of performing both annual external visual
inspections and internal visual inspections at least once
every 10 years. See Item 2 below.
(b) For each annual external visual inspection In which a YD N a
failure was detected, the following information is
submitted in the PR: (1) the date of the inspection,
(2) identification of all storage vessels for which failures
were detected, (3) a description of those failures, and
(4) either the date and the nature of the repair or the date
the vessel was emptied.
(c) If the report described In (a) and (b) documents that the Y a N a
repair was made more than 45 days after the failure was
detected, then the next PR includes documentation of the
use of up to two 30-day extensions for completing the
repair and the following information: Identification of the
storage vessel, a description of the failure, documentation
that alternate storage capacity was unavailable, a
schedule of actions to be taken to repair the control
equipment or empty the vessel as soon as possible, and
the date the storage vessel was emptied and the nature
of and date the repair was made.
2. Review records of internal visual inspections.
(a) The occurrence of each internal visual inspection is YD N D
recorded. If the floating roof is equipped with double
seals and the source chose not to perform annual
external inspections [described in Item 1 (b)], this
Inspection will be performed, recorded, and reported at
least every 5 years.
(continued)
p|S|135/Uble-7.04 7-21
-------
TABLE 7-4. COMPLIANCE CHECKUST FOR STORAGE VESSELS
(b) For each internal visual inspection in which a failure was YD No
detected, the following information is submitted in the PR:
(1) the date of the inspection, (2) identification of all
storage vessels for which failures were detected, (3) a
description of those failures, and (4) the date and nature
of the repair.
(c) Any repairs performed as described in (b) were YD No
completed before the repaired storage vessel was refilled.
(d) For each internal visual inspection documented in a PR, YD No
there is a report notifying the Administrator in advance of
the date the inspected vessel would be refilled after the
inspection. If the inspection had been planned, the report
was submitted 30 days in advance of refilling the vessel.
If the inspection was not planned, then the report was
submitted at least 7 days in advance of refilling the vessel
and included an explanation of why the inspection was
unplanned.
IF THE CONTROL EQUIPMENT IS A CLOSED VENT SYSTEM AND
CONTROL DEVICE
1. If the control device is a flare, review the following records.
(a) The results of the initial compliance determination were YD N D
submitted in the NCS.C
(b) All periods when the flare does not meet the general YD N D
control device requirements specified in §63.11(b) of
Subpart A are recorded and reported in the PR.
(c) Each record and report described in (b) includes an YD N D
identification of the flare not meeting the general control
device requirements and the reason the flare did not
meet the general control device requirements.
(d) The total number of hours of routine maintenance of the YD N D
flare during which the flare does not meet the general
control device requirements specified in §63.11(b) of
Subpart A Is recorded and reported in the PR.
(continued)
p)s|135/table-7.04 7-22
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
2. If the control device is not a flare, review the following records.
(a) A design evaluation of the control device and a
description of the gas stream entering the control device
are recorded and reported in the IP.0*-6-'
(1) If the control device is a thermal incinerator, the YD No
design evaluation includes the autoignttion
temperature of the organic HAP emission stream,
the combustion temperature, and the residence
time at the combustion temperature.6
(2) If the control device is a carbon adsorber, the Yd N a
design evaluation includes the affinity of the
organic HAP vapors for carbon, the amount of
carbon in each bed, the number of beds, the
humidity of the feed gases, the temperature of
the feed gases, the flow rate of the organic HAP
emission stream, the desorption schedule, the
regeneration stream pressure or temperature, and
the flow rate of the regeneration stream. For
vacuum desorption, pressure drop is included.
(3) If the control device is a condenser, the design YD No
evaluation includes the final temperature of the
organic HAP vapors, the type of condenser, and
the design flow rate of the organic HAP emission
stream.
(b) The documentation described in (a) demonstrates that YD N D
the control device achieves 95-percent control efficiency
during reasonably expected maximum loading conditions
(or 90-percent efficiency If the control device was
installed prior to December 31,1992).
(c) Recorded and reported in the IP are: (1) a description of YD No
the parameter (or parameters) to be monitored to ensure
that the control device is operated and maintained in
conformance with its design, (2) an explanation of the
criteria used for selection of the parameter (or
parameters), and (3) the frequency with which monitoring
wDI be performed.
(d) For each monitoring parameter identified in the IP, the YD N D
operating range is recorded and reported in the NCS.
(continued)
p|sJ13S/Uble-7.04 7-23
-------
TABLE 7-4. COMPLIANCE CHECKUST FOR STORAGE VESSELS
(e) Records of the monitored parameter (or parameters), as YD No
described in (c) and (d), are kept at the required
frequency.
(f) Each occurrence when the monitored parameter (or Y a N a
parameters) was outside its parameter range
(documented in the NCS) is recorded and reported in the
PR.
(g) Each record and report described in (f) includes an YD N a
explanation of why the measured parameter (or
parameters) was outside of its established range.
(h) The total number of hours of routine maintenance of the YD N D
control device during which the control device does not
achieve a 95-percent control efficiency (or 90-percent
control efficiency if the control device was Installed prior
to December 31,1992) is recorded and reported in the
PR.
3. For all control devices, review the following records.
(a) A description of the routine maintenance planned for the YD N D
next 6 months and actually performed in the previous 6
months is recorded and reported In the PR.
Note: Items (b) through (f) do not apply to vapor-
collection systems that are operated and
maintained under negative pressure.
(b) Records are kept of all parts of any vapor-collection YD N D
system that are designated as either unsafe-to-inspect or
difficurt-to-inspect, with an explanation of the designation.
(c) For equipment that is designated as difficult to inspect, a YD N D
written plan Is kept that requires inspection of equipment
at least once every five years.
(d) For equipment that is designated as unsafe to inspect, a YD N D
written plan is kept that requires inspection of equipment
as frequently as practicable.
(e) For each inspection during which a leak was detected,
the following information is recorded and reported.
(1) Instrument identification numbers, operator name YD N D
or initials, and equipment identification
information;
(continued)
pjs|135/lable-7.04 7-24
-------
TABLE 7-4. COMPUANCE CHECKUST FOR STORAGE VESSELS
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(f) For
the
0)
(2)
0)
(g) Hoi
The date the leak was detected and the date of
the first attempt to repair It;
Maximum instrument reading after the leak is
repaired or determined to be non-repairable;
Explanation of delay in repair, if the leak was not
repaired within 15 days after It was discovered;
Name or initials of person who decides repairs
cannot be made without a shutdown;
Expected date of successful repair if not repaired
within 15 days;
Dates of shutdowns that occur while the
equipment is unrepaired; and
Date of successful repair of the leak.
each Inspection during which no leaks were detected,
following records are kept:
Record that the inspection was performed;
Date of the inspection; and
Statement that no leaks were found.
jrly records are kept of whether the flow indicator in
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
ND
. ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
the bypass line was operating and whether flow was
detected at any time during the hour, when seal
mechanisms are not used and
(h) The time and duration of all periods when flow Is diverted YD N D
or the monitor is not operating are reported in the PR
when seal mechanisms are not used [or (I) and fl)].
(i) Records of monthly visual inspections are kept when seal YD N D
mechanisms are used and
(continued)
p|s|135/lBbl*-7.04 7-25
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(j) All periods when the seal mechanism is broken, the YD No
bypass line valve position has changed, or the key to
unlock the bypass line valve was checked out are
recorded and reported in the PR when seal mechanisms
are used.
Note: In order to be in compliance with provisions for
bypass lines either Items (g) and (h) must both
be checked "Yes" or both items 0) and (j) must
be checked "Yes".
VIS AL INSPECTION
IF T CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
Note: The inspector should not perform the inspection while on the EFR if the roof is below four feet
of the top of the tank and if the inspector is not equipped with the proper respiratory
protection. Based on the inspector's assessment of the availability of records documenting the
design of the control equipment, an adequate inspection without respiratory protection may be
performed with a combination of a record inspection and a visual inspection conducted from
the platform with the aid of vision-enhancing devices (binoculars).
1 . The EFR is resting on the liquid surface of the stored material, YD No
unless the EFR is resting on the roof leg supports because the
vessel has just been emptied and degassed or the vessel is
partially or completely emptied before being subsequently refilled
or degassed.
2. The external floating roof Is in good condition (i.e., free of defects YD N D
such as corrosion and pools of standing liquid).
3. There is a secondary seal installed above the primary seal." YD N D
4. Inspect the secondary seal.h
(a) The secondary seal is continuous and completely covers YD N D
the annular space between the EFR and the vessel wall.
(b) There are no holes, tears, or other openings in the seal or YD N D
seal fabric.
(c) There are no visible gaps between the seal and the wall YD N D
of the storage vessel, except as specified in (e)(1) and
(d) The seal is not detached from the floating deck. YD N D
(continued)
pj9j13SAoble-7.04 7-26
-------
TABLE 7-4. COMPUANCE CHECKUST FOR STORAGE VESSELS
(e) Perform seal gap measurement of the secondary seal as
specified In §63.l20(b)(l) through (b)(4) of the HON
storage provisions.
(1) The accumulated area of gaps between the YD No
vessel wall and the secondary seal does not
exceed 21.2 cm2 per meter of vessel diameter.
(2) The maximum gap width between the vessel wall YD No
and the seal does not exceed 1.27 cm.
5. Inspect the primary seal."
(a) The primary seal is either a metallic shoe seal or a liquid- YD N D
mounted seal."
(b) The primary seal forms a continuous closure that YD N D
completely covers the annular space between the wall of
the storage vessel and the edge of the EFR, except as
described in (f)(l) and (f)(2).
(c) There are no holes, tears, or other openings In the seal YD N D
fabric, seal envelope, or shoe (if a metallic shoe seal is
used).
(d) If the primary seal is a metallic shoe seal:
(1) The lower end of the metallic shoe send extends YD N D
into the stored liquid (no specific distance);
(2) The upper end of the metallic shoe seal extends YD N D
a minimum vertical distance of 61 cm above the
stored liquid surface; and
(3) There is a flexible coated fabric that spans the YD N D
space between the metal shoe and the vessel
wall.
(e) If the primary seal is a liquid-mounted seal, the seal is in YD N D
contact with the liquid between the wall of the storage
vessel and the EFR.
(f) Perform seal gap measurements of the primary seal as
specified In §63.120(b)(l) through (b)(4) of the HON
storage provisions.
(1) The accumulated area of gaps between the YD Nn
vessel wall and the primary seat does not exceed
212 cm2 per meter of vessel diameter.
(continued)
p)sJ135/laCle-7.04 7-27
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(2) The maximum gap width between the vessel wall
and the seal does not exceed 3.81 cm.
Inspect deck openings.
(a) If the EFR is non-contact, then each opening in the
floating roof, except automatic bleeder vents and rim
space vents, provides a projection below the stored
liquid's surface.'
(b) Except for automatic bleeder vents, rim space vents, roof
drains, and leg sleeves, each opening in the roof is
equipped with a gasketed cover, seal, or lid which forms
a vapor-tight seal.
(c) Each gasketed cover, seal, or lid on any opening in the
EFR is closed, unless the cover or lid must be open for
access.
(d) Covers on each access hatch and gauge float well are
bolted or fastened so as to be air-tight when dosed.
(e) The gasket on each cover, seal, or lid described in (b)
doses off the liquid surface from the atmosphere.
Inspect automatic bleeder vents.
(a) Automatic bleeder vents are dosed, unless the roof is
being floated off or is being landed on the roof leg
supports.
Automatic bleeder vents are gasketed.
(b)
(c)
The gasket on the automatic bleeder vents dose off the
liquid surface from the atmosphere.
8. Inspect rim space vents.
(a) Rim space vents are dosed, except when the roof is
being floated off the roof leg supports or when the
pressure beneath the rim seal exceeds the manufacturer's
recommended setting.
(b) Rim space vents are gasketed.
(c) The gaskets on the rim space vents dose off the liquid
surface from the atmosphere.
9. Each roof drain is covered with a slotted membrane fabric that
covers at least 90 percent of the area of the opening.
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
No
No
No
ND
No
ND
ND
ND
ND
ND
No
ND
NO
(continued)
pjsJ135/tot>le-7.04
7-28
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
10. Each unslotted guide pole well has either a gasketed sliding YD No
cover or a flexible fabric sleeve seal.
11. Each unslotted guide pole shall have on the end of the pole a YD N D
gasketed cap which is closed at all times except when gauging
the liquid level or taking liquid samples.
12. Each slotted guide pole well is equipped with the following YD No
equipment: (1) a gasketed sliding cover or a flexible fabric sleeve
seal, and (2) a gasketed float inside the guide pole or other
control device which closes off the liquid surface from the
atmosphere.
13. Each gauge hatch/sample well has a gasketed cover which is YD No
closed (except when the hatch or well must be open for access).
14. All of the gaskets described in 10 through 13 dose off the liquid YD No
surface from the atmosphere.
IF THE CONTROL EQUIPMENT IS AN INTERNAL FLOATING ROOF
Note: The Inspector should be advised of the hazards of inspecting an internal floating roof vessel
that contains a liquid hazardous air pollutant (HAP). An inspector may perform an external
visual Inspection of a storage vessel at any time (1-6- the vessel does not need to be taken out
of service). However, the inspector wOl need to have proper respiratory protection before
opening the roof hatch to visually inspect, from the fixed roof, the floating deck and seal. An
inspector may perform the more thorough internal inspection only when the vessel has been
taken out of service (i.e., emptied, degassed and cleaned). Unless a vessel is taken out of
service more frequently than is required by the HON, this internal inspection can only take
place once every ten years, during those 30 days after which the State Agency has received
notice that the vessel has been emptied and degassed and wfll subsequently be refilled. The
Inspector should never enter a storage vessel to inspect the IFR without first consulting
documents that address the safety issues to consider while entering a confined space and
while inspecting an IFR that contains HAP (e.g., the EPA document 'Confined Space Safety
Document for Conducting NESHAP Compliance Inspections of Benzene Storage Tanks.')
1. External Visual Inspection
(a) The IFR is resting on the liquid surface of the stored YD N D
material, unless the IFR is resting on the leg supports
because the vessel has just been emptied and degassed
or the vessel is partially or completely emptied before
being subsequently refilled or degassed.
(b) The IFR is In good condition (le., free of defects such as YD N D
corrosion and pools of standing liquid).
(continued)
pJSJ13S/tat>l«-7.04 7-29
-------
TABLE 7-4. COMPLIANCE CHECKUST FOR STORAGE VESSELS
(c) Inspect the seal (i.e., If a single-seal system Is used,
Inspect the single seal, and if a double-seal system Is
used, inspect both the primary and secondary seals).
(1) The seal Is not detached from the IFR. YD No
(2) There are no holes, tears, or other openings in YD N D
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N a
the wall of the storage vessel.
2. Internal Visual Inspection
(a) The IFR is resting on the liquid surface of the stored YD N D
material, unless the IFR is resting on the leg supports
because the vessel has just been emptied and degassed
or the vessel is partially or completely emptied before
being subsequently refilled or degassed.
(b) The IFR is in good condition (i.e., free of defects such as YD N D
corrosion and pools of standing liquid).
(c) The IFR is equipped with one of the following closure YD N D
devices, between the wall of the storage vessel and the
edge of the IFR: (1) a liquid-mounted seal, (2) a metallic
shoe seal, or (3) two seals (i-e., a primary and secondary
seal), each of which forms a continuous closure that
completely covers the annular space between the wall of
the storage vessel and the edge of the IFRJ
(d) Inspect the seal (i-e.. if a single-seal system is used,
inspect the single seal, and if a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the IFR. YD N D
(2) There are no holes, tears, or other openings in YD N D
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N D
the wall of the storage vessel.
(e) Inspect deck openings.
(1) If the IFR is non-contact, then each opening in YD No
the floating roof, except for automatic bleeder
vents and rim space vents, provides a projection
below the stored liquid's surface.'
(continued)
pJsj135Aable-7.04 7-30
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(2) Except for leg sleeves, automatic bleeder vents, Y a
rim space vents, column wells, ladder wells,
sample wells, and stub drains, each opening in
the IFR is equipped with a gasketed cover or lid.1*
(3) Each cover or lid on any opening in the IFR is YD
dosed, unless the cover or lid is open for access.
(4) Covers on each access hatch and automatic Y a
gauge float well are bolted or fastened so as to
be air-tight when closed.
(5) The gasket on each cover or lid described in (3) Y n
closes off the liquid surface from the atmosphere.
(f) Inspect automatic bleeder vents.
(1) Automatic bleeder vents are closed, unless the Y D
roof is being floated off or is being landed on the
roof leg supports.
(2) Each automatic bleeder vent is gasketed.k Y D
(3) The gasket on each automatic bleeder vent Y D
closes off the liquid surface from the atmosphere.
(g) Inspect rim space vents.
(1) Rim space vents are closed, except when the Y a
roof is being floated off the roof leg supports or
when the pressure beneath the rim seal exceeds
the manufacturer's recommended setting.
(2) Rim space vents are gasketed.k Y a
(3) The gaskets on the rim space vents dose off the Y a
liquid surface from the atmosphere.
(h) Each, sample well (le'.t each penetration of the IFR for YD
the purpose of sampling), has a silt fabric cover that
covers at least 90 percent of the opening.k
(i) Each penetration of the IFR that allows for passage of a YD
ladder has a gasketed sliding cover.k
(j) Each penetration of the IFR that allows for passage of a YD
column supporting the fixed roof has either a flexible
fabric sleeve seal or a gasketed sliding cover.k
ND
No
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
(continued)
7-31
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(k) The gaskets described in (i) and (j) dose off the liquid YD No
surface to the atmosphere.
0) If a flexible fabric sleeve seal is used as described in (j), YD No
the fabric sleeve Is free of defects (i.e., free of holes,
tears, or gaps).
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL
Note: The inspector should be advised of the hazards of inspecting an external floating roof vessel
converted to an internal floating roof vessel that contains a liquid hazardous air pollutant (HAP).
An inspector may perform an external visual inspection of a storage vessel at any time (i.e., the
vessel does not need to be taken out of service). However, the inspector will need to have
proper respiratory protection before opening the roof hatch to visually inspect, from the fixed
roof, the floating deck and seal. An Inspector may perform the more thorough internal
inspection only when the vessel has been taken out of service (i.e., emptied, degassed and
cleaned). Unless a vessel is taken out of service more frequently than is required by the HON,
this internal inspection can only take place once every ten years, during those 30 days after
which the State Agency has received notice that the vessel has been emptied and degassed
and will subsequently be refilled. The inspector should never enter a storage vessel to inspect
the floating roof without first consulting documents that address the safety issues to consider
while entering a confined space and while inspecting an external floating roof vessel converted
to an internal floating roof vessel that contains HAP (e.g., the EPA document "Confined Space
Safety Document for Conducting NESHAP Compliance Inspections of Benzene Storage
Tanks.')
1. External visual Inspection
(a) The floating roof is resting on the liquid surface of the Y o N D
stored material, unless the floating roof is resting on the
leg supports because the vessel has just been emptied
and degassed or the vessel Is partially or completely
emptied before being subsequently refilled or degassed.
(b) The floating roof is in good condition (i.e., free of defects .YD No
such as corrosion and pools of standing liquid).
(c) Inspect the seal 0.e.. If a single-seal system Is used,
inspect the single seal, and If a double-seal system is
used, Inspect both the primary and secondary seals).
(1) The seal is not detached from the floating roof. YD ND
(2) There are no holes, tears, or other openings in YD No
the seal or seal fabric.
(continued)
p)s]v. TM 7-32
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(3) There are no visible gaps between the seal and YD No
the wall of the storage vessel.
2. Internal visual Inspection
(a) The floating deck is resting on the liquid surface of the YD No
stored material, unless the floating deck Is resting on the
leg supports because the vessel has just been emptied
and degassed or the vessel is partially or completely
emptied before being subsequently refilled or degassed.
(b) The floating deck Is In good condition (U., free of defects YD N D
such as corrosion and pools of standing liquid).
(c) The floating deck is equipped with one of the following YD No
closure devices, between the wall of the storage vessel
and the edge of the floating deck: (1) a liquid-mounted
seal, (2) a metallic shoe seal, or (3) two seals (1-8., a
primary and secondary seal), each of which forms a
continuous closure that completely covers the annular
space between the wall of the storage vessel and the
edge of the floating deckJ
(d) Inspect the seal (I.e., if a single-seal system is used,
inspect the single seal, and If a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the floating deck. YD N D
(2) There are no holes, tears, or other openings In YD N D
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N D
the wall of the storage vessel.
(e) Inspect deck openings
(1) If the floating deck is non-contact then each YD No
opening in the floating roof, except automatic
bleeder vents and rim space vents, provides a
projection below the stored liquid's surface.'
(2) Except for automatic bleeder vents, rim space YD N D
vents, roof drains, and leg sleeves, each opening
in the roof is equipped with a gasketed cover,
seal, or lid which forms a vapor-tight seal.
(continued)
pjs|13S/lat>te-7.04 7-33
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(3) Each gasketed cover, seal, or lid on any opening Y D
in the floating deck is dosed, unless the cover or
lid must be open for access.
(4) Covers on each access hatch and gauge float Y D
well are bolted or fastened so as to be air-tight
when dosed.
(5) The gasket on each cover, seal, or lid described Y D
in (2) doses off the liquid surface from the
atmosphere.
(f) Inspect automatic bleeder vents
(1) Automatic bleeder vents are dosed, unless the YD
roof is being floated off or is being landed on the
roof leg supports.
(2) Automatic bleeder vents are gasketed. Y D
(3) The gaskets on the automatic bleeder vents dose Y D
off the liquid surface from the atmosphere.
(g) Inspect rim space vents
(1) Rim space vents are dosed, except when the YD
roof is being floated off the roof leg supports or
when the pressure beneath the rim seal exceeds
the manufacturer's recommended setting.
(2) Rim space vents are gasketed. Y D
(3) The gaskets on the rim space vents dose off the YD
liquid surface from the atmosphere.
(h) Each roof drain is covered with a slotted membrane Y D
fabric that covers at least 90 percent of the area of the
opening.
(0 Each unslotted guide pole well has either a gasketed Y D
sliding cover or a flexible fabric sleeve seal.
Q) Each unslotted guide pole shall have on the end of the YD
pole a gasketed cap which is dosed at all times except
when gauging the liquid level or taking liquid samples.
ND
No
Na
No
ND
ND
ND
ND
ND
ND
ND
ND
(continued)
pJs)13S/teble-7.04
7-34
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(k) Each slotted guide pole well is equipped with the YD No
following equipment: (1) a gasketed sliding cover or a
flexible fabric sleeve seal, and (2) a gasketed float inside
the guide pole or other control device which closes off
the liquid surface from the atmosphere.
0) Each gauge hatch/sample well has a gasketed cover YD N D
which Is closed (except when the hatch or well must be
open for access).
(m) All of the gaskets described in (I), (j), (k), and (I) dose off YD N D
the liquid surface from the atmosphere.
IF THE CONTROL EQUIPMENT IS A CLOSED VENT SYSTEM
(I.E., VAPOR COLLECTION SYSTEM) AND CONTROL DEVICE.
1. There are no visible gaps, holes, or corrosion spots seen in the YD N D
ductwork of the vapor collection system.
2. If the control device is a flare, a device for detecting the flame is YD N D
present
3. If the control device is not a flare, a device to monitor the YD N D
parameter (or parameters) specified in the IP Is present
4. A flow Indicator Is present at the entrance to any bypass line that YD N D
could divert the vent stream flow away from the control device to
the atmosphere .or all bypass line valves are sealed In a closed
position (e.g., with a car seal or lock-and-key configuration).
8 If an external floating roof has a liquid-mounted or metallic shoe primary seal as of
December 31,1992, a secondary seal is not required unto the next emptying and degassing or
April 22, 2004, whichever is later. For such storage vessels, measurement of gaps in the primary seal
must be conducted once per year until a secondary seal is installed.
b PR = Periodic Report
c NCS - Notification of Compliance Status
d IP - Implementation Plan
6 If an enclosed combustion device is documented to have a minimum residence time of 0.5 seconds
and a minimum temperature of 760°C, then additional documentation is not required.
(continued)
p|sJ133/tat>l«-7.04 7-35
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
' If the control device used to comply with the storage vessel provisions is also used to comply with
the process vent, transfer, or wastewater provisions, the performance test required by those
provisions is an acceptable substitute for the design evaluation for determining compliance.
9 A Vapor collection system' is equivalent to a 'dosed vent system.'
n If the external floating roof is equipped, as of December 31,1992, with either: (1) a liquid-mounted
primary seal and no secondary seal, (2) a metallic shoe primary seal and no secondary seal, or (3) a
vapor mounted primary seal and a secondary seal, then the seal requirement of a liquid-mounted or
metallic shoe primary seal and secondary seal does not apply until the earlier of the following dates:
(1) the next time the storage vessel Is emptied and degassed, or (2) April 22, 2004.
' If these openings (excluding automatic bleeder vents and rim space vents) did not provide projections
below the liquid service as of December 31,1992, this requirement does not apply until the earlier of
the following dates: (1) the next time the storage vessel is emptied and degassed, or (2) no later than
April 22, 2004.
J If the internal floating roof is equipped, as of December 31,1992, with a single vapor-mounted seal,
then the requirement for a liquid-mounted seal or metallic shoe seal or two seals does not apply until
the earlier of the following dates: (1) the next time the storage vessel is emptied and degassed, or
(2) April 22, 2004.
k If the internal floating roof did not meet these specifications as of December 15,1992, the requirement
to meet these specifications does not apply until the earlier of the following dates: (1) the next time
the storage vessel is emptied and degassed, or (2) no later than April 22, 2004.
NOTE ALL DEFICIENCIES.
pjsJ135/tat>le-7.04 7-36
-------
SECTION 8.
WASTEWATER
The HON regulates wastewater streams that are generated when HAP's listed on Table 9 of
Subpart G of the HON exit chemical manufacturing process unit equipment. Water that contacts HAP's
may be categorized as process wastewater, maintenance wastewater, or cooling water. Process
wastewater constitutes the majority of wastewater generated at a SOCMI facility, while maintenance
wastewater is generated periodically. Cooling water is not categorized as wastewater.
Examples of process wastewater include, but are not limited to, water used to wash
impurities from organic products or reactants, water used to cool or quench organic vapor streams
through direct contact, condensed steam from jet ejector systems pulling vacuum on vessels containing
organics, product and feed tank drawdown. Maintenance wastewater streams include, but are not
limited to, those generated by descaling heat exchanger tubing bundles, cleaning distillation column
traps, draining of pumps into an individual drain system, and wastewater generated during equipment
washes and spill cleanups. Cooling water is water that has been contaminated with organic HAP's by
leaking heat exchange systems.
This section focuses on emissions from and control of process wastewater, and residuals
removed from process wastewater. The requirements for maintenance wastewater and cooling water will
be addressed in the checklists.
8.1 DESCRIPTION OF EMISSION POINT
Process wastewater typically passes through a series of collection units and primary and
secondary treatment units before being discharged from a facility. As defined in the HON, the
wastewater emission point at a SOCMI source comprises numerous pieces of equipment such as
wastewater tanks, surface impoundments, containers, individual drain systems, oil-water separators,
treatment systems, closed-vent systems, and control devices. Each of these collection and treatment
units must be inspected to ensure compliance with the HON.
Collection and treatment scenarios for process wastewater are facility-specific. The flow rate
and organic composition of process wastewater streams at a particular facility are functions of the
processes used and influence the sizes and types of collection and treatment units that must be
employed. Table 8-1 lists common components of wastewater collection and treatment systems at
SOCMI facilities. The following sections briefly discuss each of these emission components. A detailed
discussion of wastewater collection and treatment systems, including diagrams, typical design
parameters, emission mechanisms, and factors affecting emissions, is contained in the Control
p]sJ135/sect-8.ww
9/28/94 8-1
-------
TABLE 8-1. COMMON COMPONENTS OF WASTEWATER COLLECTION SYSTEMS
AND TREATMENT PROCESSES
Waste Management Units and Treatment Processes:
Biological treatment basins
Clarifiers
Containers
Drains
Equalization basins or neutralization basins
Junction boxes
Lift stations
Manholes
Oil-water separators
Steam strippers
Sumps
Surface impoundments
Treatment tanks
Trenches
Weirs
pJsJ135/sect-e.ww
9/28/94 8-2
-------
Technology Center (CTC) document.1 In addition, emission estimation models and example
calculations for VOC emissions are presented in Appendices A and B of the same document.
8.1.1 Individual Drain Systems
Wastewater streams from various equipment throughout a given process are introduced into
the collection system through process drains. Individual drains usually connect directly to the main
process sewer line, but may also drain to trenches, sumps, or ditches. Some drains are dedicated to a
single piece of equipment, while others, known as area drains, serve several units. In the HON,
'individual drain system" is defined as the system used to convey wastewater streams from a process
unit, product storage tank, feed storage tank, or waste management unit to a waste management unit.
The term includes all process drains, junction boxes, together with their associated sewer lines and other
{unction boxes, manholes, sumps, and lift stations, down to the receiving waste management unit. A
segregated stormwater sewer system, which is a drain and collection system designed and operated for
the sole purpose of collecting rainfall-runoff at the facility and which is segregated from all other
individual drain systems, is excluded from the definition.
8.1.2 Manholes
Manholes are service entrances Into process sewer lines that permit inspection and cleaning
of the sewer line. They are placed at periodic lengths along the sewer line or where sewers intersect or
change significantly in direction, grade, or line diameter. A typical manhole opening is about 2 ft in
diameter and is covered with a heavy cast-iron plate that contains two to four holes so that the manhole
cover can be more easily grasped for removal.
8.1.3 Trenches
Trenches are used to transport wastewater from the point of process equipment discharge
to wastewater collection units. In older plants, trenches may be the primary mode of wastewater
transportation in the collection system. Trenches are often interconnected throughout the process area
and handle equipment pad water runoff, water from equipment wash down and spill cleanups, and
process wastewater discharges. Trench length is determined by the locations of the process equipment
and the downstream collection system units, and typically ranges from 50 to 500 ft. Depth and width are
dictated by the flow rate of the wastewater discharged from process equipment and must be sufficient to
accommodate emergency wastewater flows from the process equipment. Trenches are typically open or
covered with grates.
8.1.4 Sumps
Sumps are used to collect and equalize wastewater flow from trenches before treatment.
They are usually quiescent and open to the atmosphere. Sumps are sized based on the total flow rate
of the Incoming wastewater stream.
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8.1.5 Junction Boxes
A junction box combines multiple wastewater streams Into one stream which flows
downstream. Generally, the flow rate from the junction box is controlled by the liquid level in the
junction box. Junction boxes are either square or rectangular and are sized based on the total flow rate
of the entering streams. Junction boxes are typically open, but may be closed (for safety) and vented to
the atmosphere.
8.1.6 Lift Stations
A lift station is normally the last collection unit before the treatment system and accepts
wastewater from one or several sewer lines. The main function of the lift station is to collect wastewater
for transport to the treatment system. A pump provides the necessary head pressure for transport and
is usually designed to switch on and off based on preset high and low liquid levels. Lift stations are
typically rectangular in shape and greater in depth than length or width and are either open or dosed
and vented to the atmosphere.
8.1.7 Weirs
Weirs act as dams in open channels. The weir face is usually aligned perpendicular to the
bed and the walls of the channel. Water from the channel normally overflows the weir but may pass
through a notch, or opening, in the weir face. Because of this configuration, weirs provide some control
over the level and flow rate through the channel. Weirs may also be used for wastewater flow rate
measurement. Water overflowing the weir may proceed down steps, which aerates the wastewater. This
increases diffusion of oxygen into the water, which may benefit the biodegradation process (often the
next treatment step). However, this increased contact with air also accelerates the volatilization of
organic compounds contained in the wastewater.
8.1.8 Oil-Water Separators
Oil-water separation is often the first step in wastewater treatment, but oil-water separators
may also be found in the process area. These units separate and remove oils, scum, and solids from
the wastewater by gravity. Most of the separation occurs as the wastewater stream passes through a
quiescent zone in the unit. Oils and scum with specific gravities less than water float to the top of the
aqueous phase, while heavier solids sink to the bottom. Some of the organic compounds contained in
the wastewater will partition to the oil phase and then can be removed with the skimmed oil, leaving the
separated water.
8.1.9 Equalization Basins
Equalization basins are used to reduce fluctuations in the temperature, flow rate, pH, and
organic compound concentrations of the wastewater going to the downstream treatment processes.
The equalization of the wastewater flow rate results in more uniform effluent quality from downstream
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units and can also benefit biological treatment performance by damping any Influent concentration and
flow rate fluctuations. This damping protects biological processes from upset or failure caused by shock
loadings of toxic or treatment-inhibiting compounds. Equalization basins normally use hydraulic
retention time to ensure equalization of the wastewater effluent leaving the basin. However, some basins
are equipped with mixers or surface aerators to enhance the equalization, accelerate wastewater cooling,
or saturate the wastewater with oxygen before secondary treatment.
8.1.10 Treatment Tanks
Several different types of treatment tanks may be used in wastewater treatment systems.
Tanks designed for pH adjustment are typically used preceding the biological treatment step. In these
tanks, the wastewater pH is adjusted using acidic or alkaline additives to prevent shocking the biological
system downstream. Flocculation tanks, on the other hand, are usually used to treat wastewater after
biological treatment. Flocculating agents are added to the wastewater to promote the formation or
agglomeration of larger particle masses from the fine solids formed during biological treatment. These
larger panicles precipitate more readily out of the wastewater In the clarifler, which usually follows
flocculation in the treatment system.
8.1.11 Biological Treatment Basins
Biological waste treatment is normally accomplished using aeration basins. Microorganisms
require oxygen to carry out the biodegradation of organic compounds, which results In energy and
biomass production. The aerobic environment in the basin is normally achieved with diffused or
mechanical aeration. This aeration also maintains the biomass In a well-mixed regime. The performance
of aeration basins is particularly affected by (1) mass of organics per unit area of wastewater,
(2) temperature and wind patterns, (3) hydraulic retention time, (4) dispersion and mixing characteristics,
(5) characteristics of the solids in the influent, and (6) amount of essential microbial nutrients present
8.1.12 Clarifiers
The primary purpose of a clarifier is to separate solids from wastewater through gravitational
settling. Most clartflers are equipped with surface skimmers to dear the water of floating oil deposits,
grease, and scum. Clarifiers also have sludge-raking arms that remove the accumulation of organic
solids that collects at the bottom of the tank. The depth and cross-sectional area of a clarifler are
functions of the settling rate of the suspended solids and the thickening characteristics of the sludge.
Clarifiers are designed to provide sufficient retention time for the settling and thickening of these solids.
8.1.13 Surface Impoundments
Surface impoundments are used for evaporation, polishing, storage before further treatment
or disposal, equalization, leachate collection, and as emergency surge basins. They may be quiescent
or mechanically agitated.
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8.1.14 Containers
Containers which are compatible with the material(s) held may be used to collect residuals
generated by treatment prior to offsite shipment and for other purposes that require mobility. Containers
may vary in size and shape ranging from a 55-gallon drum to a tanker truck.
8.2 DESCRIPTION OF EMISSION CONTROL TECHNOLOGIES
The technologies used to reduce emissions from SOCMI wastewater systems involve a
combination of control equipment and good work practices. This section describes applicable emission
control technologies for collection and waste management units, treatment processes, and closed-vent
systems and control devices. For each of the control technologies discussed In this section, the design
and operation of the control device or system is described including an explanation of the physical
and/or chemical processes that destroy the organic HAP's or remove them from the wastewater stream.
Additionally, the factors affecting the efficiency of the control device, such as operating parameters, are
provided. Several emission control technologies including combustion technologies (e.g., flares,
incinerators), fixed and floating roofs, and product recovery devices (e.g., condensers, adsorbers) that
can be used to control emissions from wastewater are also applicable to process vents, storage vessels,
and/or transfer operations. In such cases, this section discusses the applicability of the control
technology to emissions from wastewater and refers to the respective sections in this document for
details.
8.2.1 Waste Management Units
As described in Section 8.1. wastewater collection systems and waste management units
include wastewater tanks, surface impoundments, containers, individual drain systems (which include
process drains, junction boxes, manholes, etc.), and oil-water separators. Emissions from wastewater
collection system components must be controlled through the use of emission suppression
technologies. Suppression technologies reduce volatilization of HAP's and prevent the release of volatile
HAP's to the ambient air. This allows the treatment process(es) following the collection system to
achieve greater removal and/or destruction of HAP's. The following sections describe the suppression
techniques suitable for the different components in a wastewater collection system.
8.2.1.1 Controls for Process Drains
Water seal controls reduce emissions by limiting the effects of convection and diffusion on
VOC's in the wastewater. Water seals can be either P-legs or seal pots. P-leg sealed drains are similar
to open drains, which are usually 4 to 6 inches in diameter and extend vertically to a height of 4 to 6
inches above grade, except that a "P" bend in the pipe is found below grade. The P-bend provides a
liquid seal for the individual drain, similar to that found in household plumbing. A seal pot drain has a
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cap covering the drain opening, and the bottom edge of the cap extends below the level of the drain
entrance. Liquid from the various drain pipes falls into the drain area outside of the cap and then flows
under the edge of the cap into the drain line. The drain cap can easily be removed to clean the drain
entrance and drain line.
Water seals will result In emission control only if the liquid levels in the water seals are
properly maintained, thereby minimizing mass transfer from the wastewater to the ambient air.
Therefore, the control equipment must be coupled with work practices to ensure maximum effectiveness.
A second method for controlling VOC emissions from process drains is to use a closed
drain system. In closed drain systems, emission control is achieved by mechanical and/or physical
barriers inherent to the drain design and are not dependent on operating procedures (e.g., maintaining
an appropriate level of water). Typically, a drain riser extends approximately 12 to 18 inches above
grade. The top of the riser is completely sealed with a flange. Drain pipes are welded directly to the
riser. This line is normally closed with a valve, but provides access to the closed drain system for
intermittent and infrequent needs such as pump drainage. Hoses or flexible lines can be connected to
the riser valve from the liquid source. The emission control achieved by a closed system can be as high
as 95 percent, depending on the maintenance of the system. Diagrams illustrating water seals and
closed drain systems are located in the Regulatory and Inspection Manual for Petroleum Refinery
Wastewater Systems.2
8.2.1.2 Controls for Junction Boxes. Manholes. Trenches. Weirs. Sumps, and Uft Stations
Control of emissions from individual drain system components is based on an equipment
standard supported by appropriate work practices. For example, the most feasible method of reducing
emissions from a junction box is by installing a tightly sealed cover. The cover reduces the exposure of
the wastewater to the atmosphere, thereby minimizing the effects of diffusion and convection on the
MAP's present in the wastewater stream. The cover may be vented to reduce the buildup of pressure
and/or explosive concentrations of gases. In such cases, the vent could be routed to a recovery or
combustion control device to prevent the volatilized HAP's from being released to the atmosphere.
Emission suppression may also be achieved through the use of other totally enclosed equipment such
as hard-piping In place of open trenches.
8.2.1.3 Controls for Wastewater Tanks and Oil-Water Separators
Emissions from wastewater tanks and oD-water separators can be reduced by installing
either a floating roof over the liquid surface of the separator or tank, or a fixed roof vented to a control
device. The roof reduces the effects of evaporation, wind speed, and solar radiation.
Fixed roofs can be constructed of various materials and can be mounted on the sides of the
tank or separator or supported by horizontal beams set in the sides of the tank or separator. The space
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between the roof and the edge of the tank or separator, and the spaces around any access doors, can
be seajed with gaskets to prevent the release of any HAP's that volatilize from the wastewater. The vent
from the tank would be routed to a recovery or combustion control device.
Roating roofs actually float on the liquid surface, thereby minimizing the vapor space above
the wastewater. Roating roofs can be constructed of various materials including plastic, glass foam
blocks, aluminum pontoons, or fiberglass. Seals are placed between the roof and the wall of the
separator to minimize VOC emissions. A primary seal consists of a foam or liquid-filled seal mounted, In
contact with the liquid, between the floating roof and the wall of the separator. Emission reductions from
floating roofs can be greater than 95 percent for tanks and oil-water separators holding wastewater. The
effectiveness of the roofs in reducing emissions depends on a variety of factors - the most important
being maintenance of the seals around the roofs, doors, and other openings. The HON includes work
practices to ensure optimal performance of the control technology. Section 7.2 of this document
provides additional details on both fixed and floating roofs.
8.2.1.4 Containers
The technologies used for controlling emissions from containers include the use of covers,
submerged-fill pipes, and enclosures. When wastewater or residuals from wastewater treatment are
added to a container, use of a submerged-fill pipe minimizes the loss of HAP's during filling. As
discussed in Section 6.1 of this manual, in submerged loading the fill pipe is below the liquid level, thus
reducing the amount of turbulence and resulting in lower vapor generation. Covers reduce losses due
to evaporation and wind. Any container that must be opened can be placed in an enclosure that is
vented to a closed-vent system and control device. The conveyance of the gases to a control device
reduces the potential for buildup of pressure and/or explosive concentrations of gases in the enclosure.
To be subject to the HON, a container must have a capacity greater than or equal to 0.1 m3.
8.2.2 Treatment Processes
For wastewater, the primary treatment processes are steam stripping and biological
treatment. This section provides a detailed discussion of each.
8.2.2.1 Steam Stripping
Steam stripping involves the fractional distillation of wastewater to remove HAP's. As the
wastewater flows down the column, it contacts the steam flowing countercurrentiy up the column.
Organic compounds are vaporized through heat transfer from the steam. As the organics vaporize in
the column, they are transferred from the liquid phase into the gas phase. The vaporized organic
constituents flow out the top of the column with any uncondensed steam and undergo a phase change
to a liquid in the overhead condenser. From the condenser, the liquid is sent to a decanter where the
organic compounds separate from the condensed steam due to differences in density (e.g.. the organic
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layer may float on top of the aqueous phase). The organic layer Is usually either recycled and reused In
the process or Incinerated in an on-slte combustion device for heat recovery.3
The wastewater effluent leaving the bottom of the steam stripper Is usually either routed to
an on-slte wastewater treatment plant and discharged to a National Pollutant Discharge Elimination
System (NPOES)-permitted outfall, or sent to a publicly-owned treatment works (POTW).
Steam stripper systems may be operated in batch or continuous mode. Batch steam
strippers are more prevalent when the wastewater feed Is generated by batch processes, when the
characteristics of the feed are highly variable, or when small volumes of wastewater are generated.
Batch strippers may also be used if the wastewater contains relatively high concentrations of solids,
resins, or tars.
In contrast to batch strippers, continuous steam strippers are designed to treat wastewater
streams with relatively consistent characteristics. Design of the continuous stripper system is based on
the flow rate and composition of a specific wastewater feed stream or combination of streams. Multi-
stage, continuous strippers normally achieve greater efficiencies of organic compound removal than
batch strippers.
Wastewater streams continuously discharged from process equipment are usually relatively
consistent in composition. Such wastewater streams would be efficiently treated with a continuous
steam stripper system. However, batch wastewater streams can also be controlled by continuous steam
strippers by incorporating a feed tank with adequate residence time to provide a consistent outlet
composition. In such cases, the feed tank serves as a buffer between the batch process and the
continuous steam stripper. During periods of no wastewater flow from the batch process, wastewater
stored In the feed tank is fed to the stripper at a relatively constant rate.
Steam stripping achieves emission reductions of 0 to 99 percent, based on the chemical
characteristics (e.g., strippability) of the wastewater stream. However, 95 to 99 percent reduction can be
achieved for the majority of organic compounds regulated by the HON. The organic compound removal
performance of the steam stripper depends on the degree of contact between the steam and the
wastewater. Several factors affecting the degree of contact that occurs in the steam stripper column
are: (1) the dimensions of the column (height and diameter); (2) the contacting media in the column
(trays or packing); and (3) operating parameters such as the steam-to-feed ratio, column temperatures,
and pH of the wastewater.
Steam stripping is most applicable to treating wastewaters with organic compounds that are
highly volatile and have a low solubility in water. OD, grease, and solids content and the pH of a
wastewater stream also affect the feasibility of steam stripping. High levels of oD, grease, and solids can
cause fouling of the stripper system. High or low pH may prove to be corrosive to equipment
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However, these problems can usually be circumvented by design or wastewater preconditioning
techniques. Section 2.2.3 of 'Hazardous Air Pollutant Emissions from Process Units in the SOCMI -
Background Information for Proposed Standards, Volume 1B: Control Technologies' provides additional
details on steam stripping.4
8.2.2.2 Biological Treatment
The use of biological treatment systems as a control technology is an effective method for
the removal of numerous HAP's through microbial degradation. Such systems involve the use of
bacteria, algae, fungi, and microorganisms to stabilize, absorb, alter, or destroy organic compounds.
The most common form of biological treatment is aerobic (i.e., in the presence of oxygen). In the
presence of excess oxygen, organic chemicals are oxidized by bacteria to carbon dioxide and water.
Initially, the wastewater stream(s) entering the system must be equalized in order to prevent either the
flow rate or concentration from chemically shocking the bacteria. Vigorous mixing from aerators
combines organic compounds and the activated sludge. The effluent is allowed to settle in a clarrfier
where a fraction of the sludge is returned to the aeration lagoon to reseed the population of
microorganisms. The remaining sludge is usually land disposed.
The design and operating parameters of a biological treatment unit are facility-specific and
are dependent on the composition of the wastewater feed stream. The primary factors that affect the
removal of HAP's from wastewater in a biological treatment unit include the food-to-microorganism ratio,
oxygen availability, mixed liquor suspended solids ratio, pH, temperature, and residence time. Another
consideration is the maintenance of a suspended-growth process that generates biomass, uses recycled
biomass, and periodically removes biomass from the process.
8.2.3 Closed-Vent Systems and Control Devices
By routing emissions from collection systems and treatment processes through closed-vent
systems that are vented to control devices, organic HAP emissions volatilizing from wastewater to the air
are minimized. Sections 5.2.1 and 5.2.2 of this document provide detailed discussions on combustion
and recovery control devices.
8.3 WASTEWATER PROVISIONS
This section summarizes the wastewater provisions of the HON. The discussion focuses on
the process wastewater provisions in §63.132 through §63.147 of Subpart G. However, Sections 8.3.5
and 8.3.6 address the cooling water provisions in §63.104 of Subpart F and the maintenance wastewater
provisions In §63.105 of Subpart F.
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8.3.1 Wastewater Definition
For the purpose of the HON, "wastewater" is defined as organic HAP-containing water, raw
t
material, intermediate, product, by-product, co-product, or waste material that exits equipment in a
SOCMI chemical manufacturing process unit and enters an individual drain system and either:
(1) contains a total volatile organic HAP concentration of at least 5 ppmw and has a flow rate of
0.02 je/min or greater; or (2) contains a total volatile organic HAP concentration of at least 10,000 ppmw
at any flow rate. Wastewater includes both process wastewater and maintenance wastewater.
'Process wastewater" means wastewater which, during manufacturing or processing, comes
into direct contact with or results from the production or use of any raw material, intermediate product,
finished product, by-product, or waste product. Examples are product tank drawdown or feed tank
drawdown; water formed during a chemical reaction or used as a reactant; water used to wash
impurities from organic products or reactants; water used to cool or quench organic vapor streams
through direct contact and condensed steam from jet ejector systems pulling vacuum on vessels
containing organics.
Maintenance wastewater* means wastewater generated by the draining of process fluid
from components in the chemical manufacturing process unit into an individual drain system prior to or
during maintenance activities. Maintenance wastewater can be generated during planned and
unplanned shutdowns and during periods not associated with a shutdown. Examples of activities that
can generate maintenance wastewaters include descaling of heat exchanger tubing bundles, cleaning of
distillation column traps, draining of low legs and high point bleeds, draining of pumps into an individual
drain system, and draining of portions of the chemical manufacturing process unit for repair.
Other terms that are critical to understanding the HON wastewater provisions are 'residual,'
"volatile organic hazardous air pollutant (VOHAP) concentration,* and 'point of generation.'
'Residual* means any HAP-containing water or organic that is removed from a wastewater
stream by a waste management unit or treatment process that does not destroy organics
(nondestructive units). Examples of residuals from nondestructive wastewater management units are:
the organic layer and bottom residue removed by a decanter or organic-waste separator and the
overheads from a steam stripper or air stripper. Examples of materials which are not residuals are: silt;
mud; leaves; bottoms from a steam stripper or air stripper and sludges, ash, or other materials removed
from wastewater being treated by destructive devices such as biological treatment units and incinerators.
The term "VOHAP concentration* Is defined as the concentration of an individually speciated
organic HAP In a wastewater stream or a residual that is measured by Method 305 of 40 CPR Part 63.
'Point of generation' means the location where process wastewater exits process unit
equipment and enters an individual drain system or waste management unit NOTE: The regulation
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allows determination of wastewater stream characteristics (1) at the point of generation or
(2) downstream of the point of generation if corrections are made for changes in flow rate and VOHAP
f
concentration. Such changes include losses by air emissions; reduction of VOHAP concentration or
changes in flow rate by mixing with other water or wastewater streams; and reduction in flow rate or
VOHAP concentration by treating or otherwise handling the wastewater stream to remove or destroy
HAP's.
Table 8-2 Is an applicability determination checklist for maintenance wastewater and process
wastewater. The table presents a set of yes/no questions which can be used to determine if a
maintenance wastewater stream or process wastewater stream is subject to the HON. If Table 8-2
indicates that a maintenance wastewater stream is subject to the HON, the stream must comply with the
requirements described in Section 8.3.6 of this chapter. If Table 8-2 indicates that a process wastewater
stream is subject to the HON, the stream must be categorized as either a Group 1 or Group 2 stream to
determine which process wastewater provisions apply.
8.3.2 Sourcewide 1 Mg/vr Exemption
This exemption will be used most often for process wastewater streams which have a high
concentration of HAP's but have a low flow rate. It includes two options. The first option Is an
applicability exemption in §63.138(c)(5), which exempts an existing source from process wastewater
control requirements if the sum of the VOHAP mass flow rates of all Group 1 process wastewater
streams is less than 1 Mg/yr when they exit process unit equipment. The second option is a control
option in §63.138(c)(6), which exempts an existing source from compliance with process wastewater
control requirements if the source ensures that the sum of the VOHAP mass flow rates of all untreated or
partially-treated Group 1 process wastewater streams is less than 1 Mg/yr. Therefore, the source may
elect to treat or partially treat some wastewater streams so that the total VOHAP mass flow rate for the
source is less than 1 Mg/yr. All treated Group 1 process wastewater streams that are in compliance
with a treatment option presented in Table 8-7 (presented in Section 8.3.4) may not be calculated in the
source's total VOHAP mass flow rate. Also, all waste management units used to receive, manage, or
treat Group 1 process wastewater streams must be in compliance with the control requirements
described in Section 8.3.4.
8.3.3 Process Wastewater Group Determination
Group 1 and Group 2 wastewater streams are defined in §63.111 of Subpart G based on
flow rate, VOHAP concentration, and whether the stream is part of a new or existing source. It is
important to Identify whether the source is new or existing because process wastewater streams from
new sources are evaluated using more stringent criteria than streams from existing sources. Streams
from new sources must be evaluated for concentration and flow rate of HAP's listed on Table 8 of
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TABLE 8-2. APPLICABILITY CHECKLIST FOR PROCESS AND MAINTENANCE WASTEWATER
^.^__«^mm___^^__^
Evaluate each Individual stream at Its point of generation.
1a. Is the stream stormwater?
D Y Continue with this checklist.
D N Skip to question 2.
ib. Is the stormwater in a separate sewer (i.e., segregated from the wastewater sewer)?
D Y The stream Is not a wastewater stream and is not subject to the HON.
D N Skip to question 4.
2. Is the stream a spill or water from a safety shower?
D Y The stream is not a wastewater stream and is not subject to the HON.
D N Continue with this checklist.
3a. Is the stream from fire fighting and deluge systems?
O Y Continue with this checklist.
D N Skip to question 4.
3b. Is the stream in a separate sewer (i.e., segregated from the wastewater sewer)?
a Y The stream is not a wastewater stream and is not subject to the HON.
ON Continue with this checklist.
4. Is the stream a wastewater stream discharged from a chemical manufacturing process unit
subject to the HON?
a Y Continue with this checklist.
o N The stream is not a wastewater stream and is not subject to the HON.
5. Is the VOHAP concentration of the wastewater > 10,000 ppmw?
D Y The wastewater stream Is subject to the HON.
D N Continue with this checklist.
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TABLE 8-2. APPLICABILITY CHECKLIST FOR PROCESS AND MAINTENANCE WASTEWATER,
continued
6. Is the VOHAP concentration of the wastewater stream >5 ppmw and < 10,000 ppmw mid the flow
rate >0.02 ipm?
D Y The wastewater stream is subject to the HON.
D N The wastewater stream is not subject to the HON.
7. Is the sum of the VOHAP mass flow rate of all Group 1 process wastewater streams at the source
less than 1 megagram per year?
O Y The wastewater stream Is not required to be controlled.
D N The wastewater stream is subject to the HON.
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Subpart G of the HON. Table 8 is a list of those HAP's more volatile than benzene. Whether or not a
*
wastewater stream from a new source is a Group 1 stream for HAP's listed on Table 8 of Subpart G of
the HON, it must still be evaluated for HAP's listed on Table 9 of Subpart G of the HON. Table 8 is a
subset of Table 9. .
Process wastewater streams from existing sources do not need to be evaluated using the
more stringent concentration and flow rate values that apply to Table 8 HAP's. Rather, process
wastewater streams from existing sources must be evaluated using only the concentration and flow rate
criteria for Table 9 HAP's.
Both new and existing facilities also may simplify the Group 1 /Group 2 determination
process by designating as a Group 1 process wastewater stream either a single process wastewater
stream or a combination of process wastewater streams. This option allows sources to declare that at a
designated location downstream of the point(s) of generation, all wastewater streams at this location and
upstream are Group 1 and will therefore be controlled. The source is required to meet all requirements
for Group 1 process wastewater streams (both upstream of the point of generation and downstream) for
the designated Group 1 wastewater stream. By applying process knowledge or through sampling and
analysis, sources may designate process wastewater streams as Group 1 streams. For example, if a
Group 1 and Group 2 stream were mixed, and hard piped together, the combined stream could be
designated as a Group 1 process wastewater stream and managed accordingly. Designating process
wastewater streams as Group 1 streams will be used most commonly for combinations of streams.
Both new and existing facilities must consider all HAP's listed on Table 9 of Subpart G when
designating process wastewater as Group 1. New sources must account for any HAP's listed on Table 8
of Subpart G when designating Group 1 wastewater streams.
Table 8-3 is a Group determination checklist for process wastewater streams. Section I of
the table addresses streams at new sources, and Section II addresses both new and existing sources.
8.3.4 Process Wastewater Control Requirements
Group 1 process wastewater streams and equipment managing such streams at both new
and existing sources must meet control requirements in §63.131 through §63.139 of Subpart G and the
leak detection requirements in §63.148 of Subpart G unless they are included in emissions averaging. .
Existing sources are not required to meet control requirements if Group 1 process wastewater streams
are included in the 1 Mg/yr source-wide exemption discussed in Section 8.3.2 of this section. Group 2
wastewater streams and equipment managing only Group 2 streams are not required to apply additional
controls unless the 95-percent biological treatment option, which is discussed in Section 8.3.4.2, Is used.
The HON wastewater provisions include control requirements for. (1) waste management
units Including wastewater tanks, surface impoundments, containers, individual drain systems, and oil-
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TABLE 8-3. GROUP 1/GROUP 2 DETERMINATION FOR PROCESS WASTEWATER STREAMS
I. New Sources- Group 1 /Group 2 Determination for Streams Containing HAP's Listed on
Table 8 of Subpart G of the HON
1. Is the flow rate >0.02 ipm and the VOHAP concentration of any HAP listed on Table 8 of
Subpart G of the HON >10 ppmw?
D Y The wastewater stream is Group 1 for HAP's listed on Table 8 of Subpart G of the
HON.
D N The wastewater stream is Group 2 for HAP's listed on Table 8 of Subpart G of the
HON. Continue to Section II of this table to determine If the wastewater stream Is
Group 1 for HAP's listed on Table 9 of Subpart G of the HON.
II. New and Existing Sources- Group 1 /Group 2 Determination for Streams Containing HAP's
Listed on Table 9 of Subpart G of the HON
1. Is the total VOHAP concentration of HAP's listed on Table 9 of Subpart G of the HON
> 10,000 ppmw at any flow rate or is the total VOHAP concentration of HAP's listed on Table 9
of Subpart G of the HON > 1,000 ppmw and the flow rate >10 £pm?
D Y The wastewater stream is Group 1 for HAP's listed on Table 9 of Subpart G of the
HON. Existing sources must continue with Part III to determine if control is required.
New sources do not continue with Part III of this checklist
D N The wastewater stream is Group 2 for HAP's listed on Table 9 of Subpart G of the
HON. Do not continue with Part III of this checklist.
III. Existing Sources - 1 Mg/yr Source-Wide Exemption
1. Has the existing source elected to comply with the 1 Mg/yr source-wide exemption?
D Y The wastewater stream is Group 1. but is not required to comply with HON treatment
and control requirements.
D N The wastewater stream is Group 1 for HAP's listed on Table 9 of Subpart G of the
HON and must meet the treatment and control requirements.
pjs)135/sect-6.ww
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water separators; (2) treatment processes including the design steam stripper, biological treatment units,
or other treatment devices; and (3) closed-vent systems and control devices such as flares, catalytic
incinerators, etc. This section provides an overview of the control requirements for such equipment
when It receives, manages, or treats Group 1 process wastewater streams or residuals removed from
process wastewater streams.
8.3.4.1 Waste Management Units
Waste management units are used for the collection and transport of Group 1 process
wastewater as It exits process units and enters individual drain systems (Le., point of generation). Waste
management units convey process wastewater from the point(s) of generation to the treatment
process(es).
Wastewater tanks. The control requirements for tanks holding Group 1 process wastewater
are dependent on tank capacity and vapor pressure criteria. Table 8-4 provides the tank capacity and
vapor pressure thresholds with a corresponding summary of control requirements. Wastewater tanks
holding only Group 1 process wastewater streams must meet the control requirements in §63.133 of
Subpart G unless the wastewater is included In an emissions average. Wastewater tanks holding only
Group 2 wastewater streams are not required to apply any additional controls. Compliance options for
wastewater tanks holding Group 1 process wastewater streams include:
Reducing emissions of organic HAP's using a fixed-roof tank which is operated
according to specified work practices (e.g., keeping hatches closed and
bolted);
Reducing emissions of organic HAP's using a fixed-roof tank and a closed-vent
system that routes organic HAP vapors to a control device. The fixed roof must
be operated according to specified work practices (e.g., keeping hatches
closed and bolted) and equipped with a lid that remains in a closed, sealed
position (e.g., covered by a lid that is gasketed and latched). The closed-vent
system, which is subject to the requirements of §63.148 of Subpart G, and the
control device, which is subject to the requirements of §63.139 of Subpart G,
are discussed in Section 8.3.4.3 of this manual;
Reducing emissions of organic HAP's using a fixed-roof tank equipped with an
internal floating roof which is operated according to specified work practices,
equipped with specified deck finings, and equipped with specified seal
configurations (i.e., a single liquid-mounted seal, a single metallic shoe seal, or
double seals);
Reducing emissions of organic HAP's using an external floating roof tank
operated according to specified work practices, equipped with specified deck
finings, and equipped with specified seal configurations (i.e., double seals, with
the primary seal to be either a liquid-mounted or a metallic shoe seal); or
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TABLE 8-4. WASTEWATER TANK EMISSION CONTROL REQUIREMENTS
Capacity (m3)
< 75
> 75 and < 151 .
> 151
> 75 and < 151
> 151
Vapor Pressure (kPa)
N/A
< 13.1
< 5.2
> 13.1
>5.2
Control Requirements3
Use of a fixed roof as specified in §63.133(a)(1) of
Subpart G
Use of a fixed roof and a closed-vent system that
routes HAP vapors to a control device; or
Use of a fixed roof and an internal floating roof
that meets the requirements specified in
§63.1 19(b) of Subpart G; or
Use of an external floating roof that meets the
requirements specified in §§63.1 19(c),
63.l20(b)(5), and 63.120(b)(6) of Subpart G
a To simplify the table, only an abbreviated description of the control requirement is given. Refer to the
preceding text for a more detailed description of the requirements.
pjsJ135/sect-e.ww
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Using another means of emission limitation approved in accordance with
§63.102(b) of Subpart F.
A detailed checklist of the work practices and deck finings specified for fixed-roof tanks,
internal floating roof tanks, and external floating roof tanks Is provided in Section 8.4 in Table 8-12.
Surface Impoundments. Surface impoundments holding Group 1 process wastewater
streams must meet the control requirements in §63.134 of Subpart G unless the wastewater is Included
in an emissions average. Surface impoundments holding Group 2 wastewater streams are not required
to apply any additional controls. The control requirement for surface impoundments holding Group 1
process wastewater streams Is:
Reducing emissions of organic HAP's using a cover (e.g., air-supported
structure or rigid cover) and a closed-vent system that routes organic HAP
vapors to a control device. The cover must be operated according to specified
work practices (e.g., keeping hatches, sampling ports, and gauge wells closed).
The closed-vent system, which is subject to the requirements of §63.148 of
Subpart G, and the control device, which is subject to the requirements of
§63.139 of Subpart G, are discussed in Section 8.3.4.3 of this manual.
A detailed list of work practices is provided in Section 8.4 in Table 8-12.
Containers. The control requirements for containers holding Group 1 process wastewater
are dependent on container capacity thresholds. Table 8-5 provides the container capacity criteria and
corresponding summary of control requirements. Containers holding Group 1 process wastewater
streams must meet the control requirements in §63.135 of Subpart G unless the wastewater is included
in an emissions average. Containers holding Group 2 wastewater streams are not required to apply any
additional controls.
A detailed checklist of the work practices specified for covers, submerged fill pipes, and
enclosures is provided in Section 8.4 In Table 8-12.
Individual Drain Systems. Individual drain systems holding Group 1 process wastewater
streams must meet the control requirements in §63.136 of Subpart G unless the wastewater is Included
in an emissions average. Individual drain systems holding Group 2 wastewater streams are not required
to apply any additional controls. The control requirements for individual drain systems holding Group 1
process wastewater streams include:
Reducing emissions of organic HAP's using a cover and closed-vent system on
each opening in the individual drain system that routes organic HAP vapors to a
control device. The cover must be operated according to specified work
practices (e.g., keeping access hatches and sampling ports closed). The
closed-vent system, which Is subject to the requirements of §63.148 of
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TABLE 8-5. CONTAINER8 EMISSION CONTROL REQUIREMENTS
Capacity (m3)
Control Requirements
0.1 < capacity < 0.42
Container must meet DOT specifications and testing
requirements under 49 CFR Part 178; .or
The cover and all openings must be maintained without leaks
as specified in §63.148 of Subpart G
>0.42
The cover and all openings must be maintained without leaks
as specified in §63.148 of Subpart G; and
Submerged fill pipes which meet specifications (e.g., fill pipe
outlet can extend no more than six inches or within two fill
pipe diameters of the bottom of the container) must be used;
and
Emissions of organic HAP's must be reduced using an
enclosure. The enclosure must be operated with a closed-
vent system routed to a control device.
a The term container is defined in the HON (§63.111) to have a capacity greater than or equal to 0.1 m3.
p|s|135/»ect-6.ww
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Subpart G, and the control device, which Is subject to the requirements of
§63.139 of Subpart G, are discussed in Section 8.3.4.3 of this manual; or
Reducing emissions of organic HAP's using drains equipped with water seal
controls (e.g., p-trap) or a tightly sealed cap or plug which are operated
according to specified work practices; and junction boxes equipped with a
cover and, if vented, a vent pipe, which are operated according to specified
equipment standards and work practices.
A detailed checklist of the equipment standards and work practices is provided in
Section 8.4 in Table 8-12.
Oil-water separators. Oil-water separators holding Group 1 process wastewater streams
must meet the control requirements in §63.137 of Subpart G unless the wastewater is included in an
emissions average. Oil-water separators holding Group 2 wastewater streams are not required to apply
any additional controls. The control requirements for oil-water separators holding Group 1 process
wastewater streams include:
Reducing emissions of organic HAP's using a fixed roof and a closed-vent
system that routes organic HAP vapors to a control device. The fixed roof must
be operated according to specified work practices (e.g., keeping hatches bolted
and closed). The closed-vent system, which is subject to the requirements of
§63.148 of Subpart G, and the control device, which is subject to the
requirements of §63.139 of Subpart G, are discussed in Section 8.3.4.3 of this
manual;
Reducing emissions of organic HAP's using a floating roof operated according
to specifications provided in 40 CFR Part 60 Subpart QQQ §§63.693-2(a)(1)(i),
(a)(1)(ii), (a)(2), (a)(3), and (a)(4). Where a floating roof is infeasible, such as
over a weir mechanism, a fixed roof and closed-vent system routed to a control
device may be used; or
Using another equivalent means of emission limitation approved In accordance
with §63.l02(b) of Subpart F.
A detailed checklist of work practices and equipment standards is provided in Section 8.4 in
Table 8-12.
8.3.4.2 Treatment Processes
Treatment processes are techniques that remove or destroy the organics in a wastewater
stream or residual. Section 63.138 of the HON wastewater provisions includes several compliance
options and specifies how treatment processes may be used to achieve compliance with one or more of
the compliance options. The compliance options may be used individually or in combination to achieve
the required emission control.
p]s|135/sect-8.v»w
9/26/94 8-21
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The following Is a list of all of the compliance options covered in §63.138. However, it
should be noted that not all of the listed options may be used by all sources. For example, some
i
options are available only for existing sources. Other options may be used to treat only certain types of
wastewater streams. All Group 1 wastewater streams not Included in an emissions average must be
controlled for air emissions prior to treatment and must be treated. Steam stripping and biological
treatment are two common methods used for treating wastewater, but other methods not specified in the
rule (e.g., thin film evaporation) also may be used. In many plant wastewater systems, Group 1 streams
are combined with other Group 1 streams or with Group 2 streams before they are treated. Some of the
treatment options that are allowed for individual Group 1 streams are not allowed for combined streams.
Tables 8-6 and 8-7 provide details on the use of the available compliance options.
1. Recycling to a process without the stream being exposed to the atmosphere
during recycling or at the process unit; or
2. Using a design steam stripper which meets the design criteria specified in
§63.138(g) of Subpart G; or
3. Using a waste management unit or treatment process to reduce, by removal or
destruction, the HAP mass flow rate of each organic HAP listed in Table 9 of
Subpart G by at least the fraction removed (Fr) values specified in Table 9 of
Subpart G; or
4. Using a waste management unit or treatment process to reduce by at least
99 percent, by removal or destruction, the total HAP mass flow rate of organic
HAP's listed in either Table 8 or Table 9 of Subpart G; or
5. Using a waste management unit or treatment process to achieve the required
HAP mass removal of organic HAP's as determined by procedures in §63.145(f)
for HAP's listed on Table 8 of Subpart G and in §63.145(g) for HAP's listed on
Table 9 of Subpart G. Compliance is demonstrated by calculating the actual
mass removal according to the procedures specified in §63.145(h); or
6. Using a biological treatment unit, which destroys at least 95-percent total
organic HAP mass of all HAP's listed on Table 9 of Subpart G, to treat all
Group 1 and Group 2 process wastewater streams subject to the HON. This
option may be combined with other compliance options as long as any treated
wastewater that is mixed with untreated wastewater is controlled during
collection and transport prior to entry in the biological treatment unit.
7. Using a waste management unit or treatment process to reduce, by removal or
destruction, the total VOHAP average concentration of the organic HAP's listed
in Table 9 of Subpart G to less than 50 ppmw; or
8. Using a waste management unit or treatment process to reduce, by removal or
destruction, the average VOHAP concentration of each organic HAP listed in
Table 8 of Subpart G to less than 10 ppmw; or
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9/28/94 8-22
-------
TABLE 8-6. PROCESS WASTEWATER COMPLIANCE OPTIONS FOR NEW SOURCES
Compliance Options3-1*
1. Recycle to a process
2. Use a steam stripper which meets the design
criteria specified In §63.138(g) of Subpart G
3. Reduce HAP mass flow rate of each organic
HAP by HAP-speclflc Fr values specified In
Table 9 of Subpart G
4. Reduce HAP mass by 99%
5. Achieve required HAP mass removal as
specified In §63.145(1) and/or §63.145(g) of
Subpart G
6. Treat In a biological treatment unit that
achieves 95% HAP removal
7. Reduce total VOHAP concentration to less than
50 ppmw
8. Reduce total VOHAP concentration of each
Individually specified HAP to less than
10 ppmw
Wastewater Streams
Containing HAP'a listed
In Subpart G
Table flC
N/A
N/A
Table §c
'
N/A
: -4*
Single or Combined Group 1 /Group 2 Streams
Single
Group 1
; : : Stream
X
9
9
Combination
of Group 1
Streams
X
X
X
Combination of
Group 1 and
Group 2 Streams
e
X
X
Group 2
Streams
Ontyd
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
means the treatment option can be used for the wastewater stream; X means the treatment option is not allowed to be used for the
wastewater stream; and N/A means the treatment option is not applicable.
a Options correspond to those listed In Section 8.3.4.2. To simplify the table, only an abbreviated description of the option Is given. Refer to
Section 8.3.4.2 for a more detailed description of the requirements of the option.
This table provides a list of treatment options. The stream(s) also need(s) to meet the suppression and control requirements described in
Section 8.3.4.1.
-------
TABLE 8-6. PROCESS WASTEWATER COMPLIANCE OPTIONS FOR NEW SOURCES, continued
c If a stream Is Group 1 for Table 8 and/or Table 9 HAP's, ft must meet the treatment requirements for Table 8 and/or Table 9 HAP's, as -
applicable.
d Group 2 streams that are not combined with Group 1 do not require treatment.
6 If the option to achieve a 95-percent HAP destruction using biological treatment Is selected, all Group 1 and Group 2 wastewater streams
subject to the HON must be routed to the biological treatment unit.
* New sources selecting a concentration-based compliance option must ensure that the VOHAP concentration of each Individual HAP listed on
Table 8 of Subpart G are reduced to less than 10 ppmw.
9 When meeting a concentration-based compliance option, the source must ensure that each Group 1 wastewater stream achieves the required
VOHAP concentration. Dilution is not allowed as a method for reducing concentration.
-------
TABLE 8-7. PROCESS WASTEWATER COMPLIANCE OPTIONS FOR EXISTING SOURCES
1
i
Compliance Options1^
1. Recycle to a process
2. Use a steam stripper which meets the design
criteria specified In §63.138(g) of Subpart G
3. Reduce HAP mass flow rate of each organic HAP
by the HAP -specific Fr values specified In Table 9
of Subpart G
4. Reduce HAP mass by 99%
5. Achieve required HAP mass removal as specified
In §63.1 45 (g) of Subpart G
6. Treat In a biological treatment unit that achieves
95% HAP removal
7. Reduce total VOHAP concentration to less than
50 ppmw
9. Use the process unit alternative compliance option
Wastewater Streams
Containing HAP's
listed In Table 9 of
Subpart Gc
Single or Combined Group 1 /Group 2 Streams
Single
Group 1
Stream";!
X
'
9
Combination
of Group 1
Streams
X
X
g
<*^JL«ULJLtu_lLlfjL»t *Jt
ComotriaUon of
Group 1 and
Group 2 streams
.
e
X
9 _j
Group 2
Streams
Ontyd
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
means the treatment option can be used for the wastewater stream; X means the treatment option Is not allowed to be used for the
wastewater stream; and N/A means the treatment option Is not applicable.
a Options correspond to those listed In Section 8.3.4.2. To simplify the table, only an abbreviated description of the option Is given. Refer to
Section 8.3.4.2 for a more detailed description of the requirements of the option.
0 This table provides a list of treatment options. The stream(s) also need(s) to meet the suppression and control requirements described In
Section 8.3.4.1.
c Existing sources must comply with requirements only for HAP's listed on Table 9 of Subpart G.
d Group 2 streams that are not combined with Group 1 do not require treatment.
-------
TABLE 8-7. PROCESS WASTEWATER COMPLIANCE OPTIONS FOR EXISTING SOURCES, continued
2.
£.
g e If the option to achieve 95-percent HAP destruction using biological treatment Is selected, all Group 1 and Group 2 wastewater streams aubfect
f to the HON must be routed to the biological treatment unit.
I
° * When meeting a concentration-based compliance option, the source must ensure that each Group 1 wastewater stream achieves the required
VOHAP concentration. Dilution Is not allowed as a method for reducing concentration.
9 The process unit alternative, which may only be used by existing sources, requires that a|l process wastewater (I.e., both Group 1 and
Group 2) from a particular process unit be managed by either recycling to a process or reducing the total VOHAP concentration of each
stream from the process unit to less than 10 ppmw.
-------
9. Using the process unit alternative compliance option which requires that all
process wastewater (i.e., both Group 1 and Group 2 streams) discharged from
a single chemical manufacturing process unit be either (1) recycled to a
process or (2) treated to achieve less than 10 ppmw total VOHAP average
concentration of organic HAP's listed in Table 9 of Subpart G from each
process wastewater stream exiting the process unit. If process wastewater
streams are combined prior to treatment, the source must treat by destruction
or removal those streams with greater than or equal to 10 ppmw total VOHAP
concentration. Dilution is not an acceptable form of treatment. The combined
streams must be controlled according to the provisions in §§63.133 through
63.137 prior to recycling or treatment.
A detailed checklist of the requirements for each of the treatment compliance options is
provided in Section 8.4 in Table 8-13 of this manual.
8.3.4.3 Closed-Vent Systems and Control Devices
Closed-vent systems are used to transport organic HAP vapors from waste management
units and treatment processes to control devices. In order to reduce emissions during transport, the
duct work or piping in the closed-vent system is subject to periodic leak inspections in §63.148 of
Subpart G. There are also provisions in §63.148 to prevent releases through by-pass lines. A detailed
checklist of inspection requirements is provided in Section 8.4 in Table 8-14.
Control devices are used to recover or destroy organic HAP vapors. Section 63.139 of the
HON wastewater provisions requires that control devices reduce by 95 percent the organic HAP
emissions routed to them from waste management units and treatment processes. A variety of control
devices may be used including flares; enclosed combustion devices such as thermal and catalytic
incinerators, boilers, and process heaters; vapor recovery systems such as condensers, carbon
adsorbers, and absorbers; scrubbers; and any other devices that can reduce total organic HAP
emissions by 95 weight percent or greater. A detailed checklist of operating requirements is provided in
Section 8.4 in Table 8-15.
8.3.4.4 Residuals Management
Residuals may be generated during the treatment of wastewater. As described in
Section 8.3.1, residuals can include, among other things, the organic layer removed by a decanter or the
overheads condensate from a steam stripper or air stripper. Residuals generated from the management
of a Group 1 process wastewater stream must be managed according to §63.138(h) of Subpart G.
Specifically, they must be controlled for air emissions by one of the following compliance options:
Recycling the residual to a production process;
Selling the residual for the purpose of recycling or for any other purpose.
Residuals being stored prior to sale must be in compliance with waste
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9/28/94 8-27
-------
management unit control requirements. Additionally, once residuals are sold,
they must continue to be managed In accordance with the HON;
Returning the residual to a treatment process (e.g., send to a boiler); or
Treating the residual to destroy the total combined HAP mass flow rate by
99 percent or more.
Any residuals generated from Group 2 streams do not require control under the HON;
however, other regulations such as RCRA may be applicable.
8.3.5 Process Wastewater Testing. Monitoring. Recordkeeplng and Reporting
For both Group 1 and Group 2 process wastewater streams, a record must be kept which
provides the annual average flow rate and the VOHAP concentration for each process wastewater
stream. If process knowledge Is used to determine that a process wastewater stream Is Group 2, a
record of how the process knowledge was used to make the decision must be maintained.
As part of the Implementation Plan submlttal, sources must submit information on flow rate,
concentration, Group 1/Group 2 status, and intended treatment technology. Appendix E specifies the
information that must be submitted with the Implementation Plan. Each new source must submit the
information Included in Appendix E, Table E-1 for the HAP's listed on Table 8 of Subpart G. For HAP's
listed on Table 9 of Subpart G, both new and existing sources must submit the information specified In
Table E-2 of Appendix E. New sources are not required to provide duplicative Information in Tables E-1
and E-2. If a source elects to use a waste management unit, treatment process, or control device that is
not specifically discussed in the rule, the source must submit a request for approval to monitor
alternative parameters as part of the Implementation Plan.
As part of the Notification of Compliance Status, sources must submit more specific details
on the waste management units, treatment processes, and control devices that are being used, including
design analyses, performance test results, and compliance determination results. For HAP's listed on
Table 8 of Subpart G, each new source, must submit the information described in Appendix F, Table F-1.
For HAP's listed on Table 9 of Subpart G, both new and existing sources must submit the information
specified in Table F-2 of Appendix F. New sources are not required to provide duplicative information in
Tables F-1 and F-2. Existing sources that use the process unit alternative must submit the additional
information described in Appendix F, Table F-3.
For each treatment process or waste management unit Identified in Tables F-1, F-2, and F-3,
the sources also must complete Table F-4 for treatment processes and Table F-5 for waste management
units. For each residual removed from a Group 1 process wastewater stream, sources must submit the
information described in Table F-6.
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9/2B/94 8-28
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If the vapors from a waste management unit or treatment process are routed to a flare, the
sources must submit records and reports of flare design, visible emission readings, heat content
i
determinations, flow rate measurements, exit velocity, and periods when the pilot flame is absent. For
each control device that is not a flare, the source must submit information justifying site-specific
monitoring parameter ranges and either the results of performance tests or a design evaluation for a
thermal incinerator, catalytic incinerator, boiler or process heater, condenser, carbon adsorption system,
or scrubber. The documentation must include the vent stream composition, constituent concentrations,
flow rate, and control device operating parameters. Some control devices are not required to submit
design evaluation criteria, including: (1) boilers or process heaters either with a design heat input
capacity of 44 MW or greater, or into which the emission stream is introduced with the primary fuel; or
(2) boilers or process heaters burning hazardous waste for which the owner or operator has been Issued
either a final permit or a certification of interim status under RCRA 40 CFR Parts 270 and 266, Subpart H.
For waste management units, treatment processes, and control devices, sources must
submit results of inspections and monitoring as part of the Periodic Report, which is submitted semi-
annually. A list of inspection and monitoring requirements Is provided for waste management units in
Table 8-8, for treatment processes in Table 8-9, and for control devices in Table 8-10. Table 8-11
provides a list of reporting and recordkeeping requirements for control devices. A copy of all reports
submitted to the EPA and/or the State must be maintained onsite for a total of five years.
8.3.6 Heat Exchange Systems and Cooling Water Management Requirements
A heat exchange system, as defined in the HON, includes any recirculating heat exchange
system (i.e., cooling tower system) or once-through cooling water system (e.g., river or pond water). A
heat exchange system can include more than one heat exchanger and can include an entire
recirculating or once-through cooling system. The requirements for managing cooling water are
provided in §63.104 of Subpart F.
The HON requires sources using heat exchange systems (either recirculating or once-
through heat exchange systems) to monitor cooling water for leaks. The HON requires sources using
recirculating heat exchange systems to monitor for leaks of HAP's listed on Table 2 of Subpart F, except
for the following: benzotrichloride (98077), bis(chloromethyl)ether (542881), maleic anhydride (108316),
and methyl isocyanate (624839). Sources using once-through heat exchange systems are required to
monitor for leaks of all HAP's listed on Table 9 of Subpart G.
All heat exchange systems must be monitored for leaks using one of the following
parameters: total HAP, total VOC, speciated HAP's. or TOC for semi-volatile HAP's listed in Method 625.
Use of TOC Is not allowed for volatile HAP's. Monitoring must be performed monthly for the first six
months and quarterly thereafter.
p]s|135/sect-6.ww
9/28/94 8-29
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TABLE 8-8. INSPECTION AND MONITORING REQUIREMENTS FOR WASTE MANAGEMENT UNITS
To Comply With
WASTEWATER TANKS:
63.133(b)(1)
63.133(c)
63.133(d)
63.133(0
63.133(g)
SURFACE
IMPOUNDMENTS:
63.134(b)(1)(l)
63.134(b)(1)(il)
63.1 34(c)
CONTAINERS:
63.135(b)(1)
63.135(b)(2)(ll)
63.135(d)(1)
63.135(6)
INDIVIDUAL DRAIN
SYSTEMS0:
63.136(b)(1)
63.136(c)
Inspection or Monitoring Requirement
Inspect fixed roof and all openings for leaks3
Inspect Internal floating roof In accordance with
§§63. 120 (a) (2) and (a) (3)
Measure external 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 cover and all openings for leaks8
Inspect surface Impoundment for control equipment
failures and Improper work practices
Inspect cover and all openings for leaks3
Inspect enclosure and all openings for leaks3
Inspect container for control equipment failures and
improper work practices
Inspect cover and all openings for leaks3
Inspect Individual drain system for control equipment
failures and improper work practices
Frequency
Initially
Seml-annually
See §63. 120 (a) (2) and
(a)(3)
Once every 5 years
Annually
Seml-annually
Initially
Seml-annually
Seml-annually
Initially
Initially
Seml-annually
Seml-annually
Initially
Seml-annually
Seml-annually
Method *
Method 21°
Visual
Visual
See §63.120(b)(2)(i) through
(b)(4)
Visual
Method 21 b
Visual
Visual
Method 21°
Method 21°
Visual
Visual
Method 21°
Visual
Visual
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TABLE 8-8. INSPECTION AND MONITORING REQUIREMENTS FOR WASTE MANAGEMENT UNITS, continued
To Comply With
63.136(e)(1)
63.136(f)(1)
63.136(f)(2)
63.136(f)(3)
OIL-WATER SEPARATORS:
63.137(b)(1)
63.137(c)
63.137(d)
Inspection or Monitoring Requirement
Verify flow of water supply to all drains using water
seals to ensure appropriate water levels and to
prevent other conditions that reduce water seal
control effectiveness
Inspect all drains using tightly-sealed caps or plugs
to ensure caps and plugs are In place and properly
Installed
Inspect all junction boxes to ensure covers are In
place and have tight seals around edges
Inspect unburied portion of all sewer lines for cracks
and gaps
Inspect fixed roof and all openings for leaks8
Measure floating roof seal gaps In accordance with
40 CFR 60.696(d)(1)
- Primary seal gaps
- Secondary seal gaps
Inspect oil-water separator for control equipment
failures and Improper work practices
Frequency
Seml-annually
Semi-annually
Seml-annually
Seml-annually
Initially
Seml-annually
Once every 5 years
Annually
Seml-annually
Method
Visual
Visual
Visual
Visual
Method 21 b
Visual
See40CFR60.696(d)(1)
Visual
a Leaks are detectable emissions of 500 parts per million by volume above background.
b Method 21 of 40 CFR part 60, appendix A. The owner or operator shall comply with the requirements of §63.148.
c As specified In §63.136(a), the owner or operator shall comply with the requirements of either §63.136(b) or (c).
-------
TABLE 8-9. MONITORING REQUIREMENTS FOR TREATMENT PROCESSES
To Comply With
Parameters to be Monitored
Frequency
Methods
I
8
1.
HAP mass removal of each organic
HAP compound or total organic
HAP compounds In a properly
operated biological treatment unit
Appropriate parameters may be monitored
upon approval from the permitting authority In
accordance with the requirements specified In
§63.143(c)
Continuous
Method 304, or any other
method which has been
approved by EPA during
compliance demonstrations
HAP mass removal of 95 percent of
total organic HAP compounds In a
properly operated biological
treatment unit
63.138(e)
Appropriate parameters may be monitored
upon approval from the permitting authority In
accordance with the requirements specified In
§63.143(c)
Continuous
Method 304, or any other
method which has been
approved by EPA during
compliance demonstrations
Design steam stripper
63.138(g)(3), (4), and (5)
Alternative monitoring parameters
Steam flow rate
Wastewater feed mass flow rate
Wastewater feed temperature
Other parameters may be monitored upon
approval from the Administrator In accordance
with the requirements specified In §63.143(d)
Continuous
Continuous
Continuous
Integrating steam flow
monitoring device equipped
with a continuous recorder
Liquid flow meter Installed at
stripper Influent and equipped
with a continuous recorder
Liquid temperature monitoring
device Installed at stripper
Influent and equipped with a
continuous recorder
a If met hod (s) are used to measure organic HAP concentrations In a waste or wastewater stream, rather than measuring VOHAP concentrations
In an air stream purged from a waste or wastewater stream, the correction factors listed In table 34 of Subpart G may be used to adjust the
results to provide a measure of the volatile portion (i.e., the VOHAP concentration) of the organic HAP compounds.
-------
TABLE 8-10. MONITORING REQUIREMENTS FOR CONTROL DEVICES
Control Device
Monitoring Equipment Required
Parameters to be Monitored
Frequency
Thermal
Incinerator8
Temperature monitoring device Installed In
firebox or In ductwork Immediately
downstream of firebox0 and equipped with
a continuous recorder0
Firebox temperature
Continuous
Catalytic Incinerator3
Temperature monitoring device Installed in
gas stream Immediately before and after
catalyst bed and equipped with a
continuous recorder0
1. Temperature upstream of
catalyst bed .or
2. Temperature difference
across catalyst bed
Continuous
Flare*
Heat sensing device Installed at the pilot
light and equipped with a continuous
recorder0
Presence of a flame at the pilot
light
Hourly records of whether the
monitor was continuously
operating and whether the pilot
flame was continuously present
during each hour
Boiler or process
heater <44 megawatts
and vent stream Is not
mixed with the primary
fuel9
Temperature monitoring device Installed In
flreboxb and equipped with continuous
recorder0
Combustion temperature
Continuous
Condenser8
Temperature monitoring device Installed at
condenser exit and equipped with
continuous recorder0
Condenser exit (product side)
temperature
Continuous
Carbon Adsorber
(Regenerative)3
Integrating regeneration stream flow
monitoring device having an accuracy of
± 10 percent, and
Carbon bed temperature monitoring device
Total regeneration stream mass
flow during carbon bed
regeneration cyde(s)
Temperature of carbon bed after
regeneration [and within
15 minutes of completing any
cooling cyde(s)]
For each regeneration cycle,
record the total regeneration
stream mass flow
For each regeneration cycle and
within 15 minutes of completing
any cooling cycle, record the
carbon bed temperature
Carbon Adsorber
(Non-regenerative)3
Organic compound concentration
monitoring device^
Organic compound concentration
of adsorber exhaust
Daily or at Intervals no greater than
20 percent of the design carbon
replacement Interval, whichever Is
greater
(Continued)
-------
TABLE 8-10. MONITORING REQUIREMENTS FOR CONTROL DEVICES, continued
Control Device
All Control Devices (as
an alternative to the
above)
All control devices
Alternative monitoring
parameters
Monitoring Equipment Required
Organic monitoring device Installed at the
outlet of the control device and equipped
with a continuous recorder0
1. Row Indicator Installed at all bypass
lines to the atmosphere and equipped
with continuous recorder0 or
2. Valves sealed closed with car-seal or
lock-and-key configuration
Other parameters may be monitored upon
approval from the Administrator In
accordance with the requirements In
§63.143(e)(3)
Parameters to be Monitored
Concentration level or reading
1 . Presence of flow diverted
from the control device to
the atmosphere or
2. Monthly Inspections of
sealed valves
Frequency
Continuous
Hourly records of whether the flow
Indicator was operating and
whether the flow was detected at
any time during each hour
Monthly
I
a Alternatively, these devices may comply with the organic monitoring device provisions listed at the end of this table under "All Control
Devices".
b Monitor may be Installed In the firebox or in the ductwork Immediately downstream of the firebox before any substantial heat exchange Is
encountered.
c "Continuous recorder" Is defined in §63.111 of Subpart G.
d As an alternative to conducting this monitoring, an owner or operator may replace the carbon in the carbon adsorption system with fresh
carbon at a regular predetermined time Interval that Is less than the carbon replacement Interval that Is determined by the maximum design
flow rate and organic concentration In the gas stream vented to the carbon adsorption system.
-------
TABLE 8-11. PERIODIC REPORTING REQUIREMENTS FOR CONTROL DEVICES USED TO COMPLY WITH §§63.133-63.139
GO
&
Control Device
Thermal Incinerator
Catalytic Incinerator
Boiler or Process Heater with a
design heat Input capacity less
than 44 megawatts and vent
stream Is not mixed with the
primary fuel
Rare
Condenser
Carbon Adsorber
All Control Devices
Reporting Requirements
1.
1.
2.
3.
1.
1.
1.
1.
2.
3.
1.
2.
Report all dally average8 temperatures that are outside the range established In the NCSa or operating
permit and all operating days when Insufficient monitoring data are collected6
Report all dally average8 upstream temperatures that are outside the range established In the NCSD or
operating permit
Report all dally average8 temperature differences across the catalyst bed that are outside the range
established In the NCSb or operating permit
Report all operating days when Insufficient monitoring data are collected0
Report all dally average8 firebox temperatures that are outside the range established In the NCSb or
operating permit and all operating days when insufficient monitoring data are collected0
Report the duration of all periods when the pilot flame Is absent
Report all daily average8 exit temperatures that are outside the range established In the NCSD or
operating permit and all operating days when Insufficient monitoring data are collected0
Report all carbon bed regeneration cycles when the total regeneration stream mass flow Is outside the
range established In the NCSb or operating permit
Report all carbon bed regeneration cycles during which the temperature of the carbon bed after
regeneration is outside the range established In the NCSb or operating permit
Report all operating days when Insufficient monitoring data are collected0
Report the times and durations of all periods when the vent stream Is diverted through a bypass line or
the monitor Is not operating, or
Report all monthly Inspections that show the valves are not sealed closed or the seal has been changed
8 The daily average is the average of all values recorded during the operating day, as specified In §63.147(e) of Subpart G.
D NCS = Notification of Compliance Status described In §63.152 of Subpart G.
° The periodic reports shall Include the duration of periods when monitoring data are not collected for each excursion as defined in
§63.152(c)(2)(ii)(A) of Subpart G.
-------
Monitoring parameter (e.g., total HAP, total VOC) concentrations In cooling water must be
determined using any EPA-approved method listed in 40 CFR Part 136 that Is sensitive to concentrations
'»
as low as 1 ppm. The same method must be used to measure the inlet and the outlet concentration of
the heat exchange system. A leak Is detected if a statistically significant difference in concentration of at
least 1 ppm at a 95 percent confidence level Is observed. Leaks must be repaired no more than 45 days
after monitoring tests indicate a leak is present After a leak Is repaired, the source must monitor
monthly for six months and quarterly thereafter to ensure that the leak does not recur.
Sources are not required to comply with leak detection monitoring requirements If either.
(1) the heat exchange system is operated with the minimum pressure on the cooling water side at least
35 kilopascals greater than the maximum pressure on the process side; or (2) the once-through heat
exchange system has an NPDES permit with an allowable discharge limit of less than 1 ppm. Table 8-16
provides a detailed checklist of requirements for heat exchange systems requiring leak detection
monitoring.
8.3.7 Maintenance Wastewater Management Requirements
Maintenance wastewater is defined as wastewater generated by the draining of process fluid
from components in the chemical manufacturing process unit into an individual drain system prior to or
during maintenance activities. Maintenance wastewater can be generated during planned and
unplanned shutdowns and during periods not associated with a shutdown. Examples of activities that
can generate maintenance wastewater include descaling of heat exchanger tubing bundles, cleaning of
distillation column traps, draining of low legs and high point bleeds, draining of pumps into an individual
drain system, and draining of portions of the chemical manufacturing process unit for repair. The
requirements for managing maintenance wastewater are provided in §63.105 of Subpart F.
As part of the facility's startup, shutdown, and malfunction plan required by §63.6(e)(3) of
40 CFR Part 63 Subpart A, the HON requires sources to prepare a description of procedures for
managing maintenance wastewater. The description must include maintenance procedures for
managing wastewater generated from emptying and purging equipment during temporary shutdowns
that are necessary for inspections, maintenance, and repair (i.e., maintenance-turnaround) and during
periods which are not shutdowns (i.e., routine maintenance). At a minimum, the description must
specify: (1) the process equipment and/or maintenance tasks that are expected to create wastewater
during maintenance activities; (2) the procedure for property managing the wastewater and controlling
HAP emissions to the atmosphere; and (3) the procedures for clearing materials from process
equipment
The description is to be modified and updated as needed following each maintenance
procedure. Records of the maintenance procedures must be kept as part of the startup, shutdown, and
pJsJ13S/sec1-e.ww
9/28/94 8-36
-------
malfunction plan. A detailed checklist of the maintenance wastewater requirements are provided in
Table 8-17.
8.4 WASTEWATER INSPECTION PROCEDURES
Tables 8-12 through 8-17 present checklists that can be used to verify whether a wastewater
stream is in compliance with the wastewater provisions of the HON. The tables list the specific records
and reports that a facility is required to keep/submit for each type of control equipment used for
compliance.
The checklists are divided as follows:
Table 8-12: Waste Management Units
Table 8-13: Treatment Processes
Table 8-14: Closed-Vent Systems
Table 8-15: Control Devices
Table 8-16: Heat Exchange Systems
Table 8-17: Maintenance Wastewater.
The owner or operator may comply using control techniques other than those listed In
Tables 8-12 through 8-17. In these cases, the inspector should verify: (1) that the facility obtained
approval from the Administrator (or agency to which authority has been delegated) and (2) that the
approved parameters are recorded and reported.
8.5 REFERENCES
1. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Office
of Research and Development. Control Technology Center, Industrial Wastewater Volatile
Organic Compound Emissions - Background Information for BACT/LAER Determinations.
EPA 450/3-90-004. Research Triangle Park, NC. January 1990.
2. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
Stationary Source Compliance Series, Regulatory and Inspection Manual for Petroleum
Refinery Wastewater Systems. EPA-340/1-91-013. Research Triangle Park, NC. September
1991.
3. LaGrega, Michael and associates. Hazardous Waste Management. McGraw-Hill, Inc. New
York, NY. 1994.
4. U.S.. Environmental Protection Agency, Office of Air Quality Planning and Standards, Office
of Research and Development. Hazardous Air Pollutant Emissions from Process Units in the
SOCMI - Background Information for Proposed Standards, Volume 1B: Control
Technologies. EPA-453/D-92-016b. Research Triangle Park, NC. November 1992.
pjs|135/sect-6.ww
9/28/94 8-37
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
Complete this form for waste management units. A "yes' response to all questions will indicate full
compliance, and 'no" responses will Indicate noncompliance except where noted.
I. REVIEW OF RECORDS
A. WASTEWATER TANKS
1 . The occurrence of each semiannual visual inspection for improper Y O
work practices is recorded.
2. The occurrence of each semiannual visual inspection for control Y D
equipment failures is recorded.
3. For each inspection during which a control equipment failure was
identified, the following were recorded and reported in the next
(a) Date of the inspection. Y D
(b) Identification of the wastewater tank having the failure. Y D
(c) Description of the failure. Y D
(d) Description of the nature of the repair. Y a
(e) Date the repair was made. Y D
Np
NO
NO
ND
ND
ND
ND
IF THE CONTROL EQUIPMENT IS A FIXED ROOF
Review records listed in Table 8-14.
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND A CLOSED-
VENT SYSTEM ROUTED TO A CONTROL DEVICE
Review records listed in Tables 8-14 and 8-15.
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
1. Review records of Seal Gap Measurements.
(a) Records indicate that seal gap measurements were Y D
performed annually for the secondary seal and every five
years for the primary seal.D
(b) When a failure is detected, the date and results of seal Y D
gap measurements are submitted in periodic reports,
annually for the secondary seal and every five years for
the primary seal.
ND
ND
(continued)
p)sj135/table-6.12
8-38
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(c) When a failure is detected in the seal(s), the date and YD N n
results of the visual inspection of the seals (which is
performed together with the seal gap measurement) are
included in the PRa
(d) The date of the seal gap measurement, the raw data YD. No
obtained during the measurement, and the calculations
made are recorded.
(e) The raw data and calculations recorded for seal gap YD N D
measurements is consistent with the information provided
In the PR.
(f) For each seal gap measurement in a periodic report, YD N D
there is a report notifying the Administrator of the
measurement in advance. If the measurement had been
planned, then the report was submitted 30 days in
advance of the measurement. If the measurement was
not planned, then the report was submitted at least
7 days in advance of the measurement and included an
explanation of why the measurement was unplanned.
(g) If a failure was detected during a seal gap measurement YD N D
and visual seal inspection, the PR indicated the date and
the nature of the repair or the date the wastewater tank
was emptied.
(h) If the report described in (g) documents that the repair YD N D
was made more than 45 days after the failure was
. detected, then the next PR Includes documentation of the
use of up to two 30-day extensions for completing the
repair, including identification of the wastewater tank, a
description of the failure, documentation that alternate
storage capacity was unavailable, a schedule of actions
to be taken to repair the control equipment or empty the
wastewater tank as soon as possible, and the date the
wastewater tank was emptied and the nature of and date
the repair was made.
2. Review records of Internal visual inspections.
(a) The occurrence of each Internal visual inspection Is YD N D
recorded.
(continued)
p]sJ135/lable-6.12 8-39
-------
TABLE 8-12. COMPUANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(b) For each internal visual inspection in which a failure was YD No
detected, the following information is submitted in the PR:
(1) the date of the inspection, (2) identification of all
wastewater tanks for which failures were detected, (3) a
description of those failures, and (4) either the date and
nature of the repair or the date the wastewater tank was
emptied.
(c) Any repairs performed as described in (b) were YD N a
completed before the repaired wastewater tank was
refilled.
(d) For each internal visual inspection documented in a PR, YD N D
there is a report notifying the Administrator in advance of
the date the inspected wastewater tank would be refilled
after the inspection. If the inspection had been planned,
the report was submitted 30 days in advance of refilling
the wastewater tank. If the inspection was not planned,
then the report was submitted at least 7 days in advance
of refilling the wastewater tank and included an
explanation of why the inspection was unplanned.
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND AN INTERNAL
FLOATING ROOF
1. Review records of external visual inspections
(a) The occurrence of each annual external visual inspection YD N D
is recorded. If the floating roof is equipped with double
seals, the source will not have performed this inspection if
It chose to perform internal visual Inspections once every
5 years instead of performing both annual external visual
inspections and internal visual inspections at least once
every 10 years. See Item 2 below.
(b) For each annual external visual inspection in which a YD N D
failure Is detected, the following Information is submitted
in the PR: (1) the date of the inspection, (2) identification
of all wastewater tanks for which failures were detected,
(3) a description of those failures, and (4) the date and
the nature of the repair or the date the wastewater tank
was emptied.
(continued)
pjsJ135/Uble-8.12 8-40
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(c) If the report described in (a) and (b) documents that the YD No
repair was made more than 45 days after the failure was
detected, then the next PR includes documentation of the
use of up to two 30-day extensions for completing the
repair and the following information: identification of the
wastewater tank, a description of the failure,
documentation that alternate storage capacity was
unavailable, a schedule of actions to be taken to repair
the control equipment or empty the wastewater tank as
soon as possible, and the date the wastewater tank was
emptied and the nature of and date the repair was made.
2. Review records of internal visual inspections.
(a) The occurrence of each internal visual inspection is Y o No
recorded. If the floating roof is equipped with double
seals and the source chose not to perform annual
external inspections [described in item 1(b)], this
inspection will be performed, recorded, and reported at
least every 5 years.
(b) For each internal visual inspection in which a failure was Y a No
detected, the following information Is submitted In the PR:
(1) the date of the inspection. (2) identification of all
wastewater tanks for which failures were detected, (3) a
description of those failures, and (4) the date and nature
of the repair.
(c) Any repairs performed as described in (b) were YD No
completed before the repaired wastewater tank was
refilled.
(d) For each internal visual inspection documented in a PR, Y a N a
there Is a report notifying the Administrator In advance of
the date the inspected wastewater tank would be refilled
after the inspection. If the inspection had been planned,
the report was submitted 30 days in advance of refilling
the wastewater tank. If the inspection was not planned,
then the report was submitted at least 7 days in advance
of refilling the wastewater tank and included an
explanation of why the inspection was unplanned.
(continued)
p)s)135/table-8.12 8-41
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
IF THE CONTROL EQUIPMENT IS A CLOSED VENT SYSTEM AND
CONTROL DEVICE
Review records listed in Tables 8-14 and 8-15.
B. SURFACE IMPOUNDMENTS
1. The occurrence of each semiannual visual inspection for Improper YD N a
work practices is recorded.
2. The occurrence of each semiannual visual inspection for control YD No
equipment failures is recorded.
3. For each inspection during which a control equipment failure was
identified, the following were recorded and reported in the next
PRa
(a) Date of the inspection. YD N n
(b) Identification of the surface impoundment having the Y a N a
failure.
(c) Description of the failure. YD N a
(d) Description of the nature of the repair. YD N D
(e) Date the repair was made. YD N D
[Note: Other recordkeeping requirements may be listed In
Tables 8-14 and 8-15.]
C. CONTAINERS
1. A record of the capacity of each container at the facility is YD ND
maintained.
2. The occurrence of each semiannual visual inspection for improper YD N D
work practices is recorded.
3. The occurrence of each semiannual visual inspection for control YD N D
equipment failures is recorded.
4. For each inspection during which a control equipment failure was
Identified, the following were recorded and reported in the next
PR8
(a)
(b)
Date of the inspection.
Identification of the container having the failure.
YD
YD
ND
ND
(continued)
pJsJ135/tat>le-8.12 8-42
-------
TABLE 8-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(c) Description of the failure. Y a N a
(d) Description of the nature of the repair. YD No
(e) Date the repair was made. Y a No
[Note: Other recordkeeping requirements may be listed In
Tables 8-14 and 8-15.]
D. INDIVIDUAL DRAIN SYSTEMS
1. If the control equipment is a cover and a closed-vent system
routed to a control device:
(a) The occurrence of each semiannual visual Inspection for YD N D
improper work practices Is recorded.
(b) The occurrence of each semiannual visual Inspection for YD N D
control equipment failures is recorded.
(c) For each inspection during which a control equipment
failure was Identified, the following were recorded and
reported in the next PRa
(1) Date of the inspection. YD N D
(2) Identification of the individual drain system having YD N D
the failure.
(3) Description of the failure. YD N D
(4) Description of the nature of the repair. YD N D
(5) Date the repair was made. YD N D
[Note: Other recordkeeping requirements may be listed
in Tables 8-14 and 8-15.)
2. For drains and junction boxes, as an alternative to Item 1:
(a) A record documents the occurrence of each semiannual YD N D
inspection of drains to ensure that caps or plugs are in
place and properly Installed [or (b)]
(b) A record documents the occurrence of each semiannual YD N D
verification of water supply to the drain.
(c) A record documents the occurrence of each semiannual YD N D
inspection of junction boxes to ensure that a cover is in
place and has a tight seal around the edge.
(continued)
8-43
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(d) A record documents the occurrence of each semiannual YD N a
inspection of the unburied portion of each sewer line for
Indication of cracks or gaps.
E OIL-WATER SEPARATORS
1. The occurrence of each semiannual visual inspection for improper YD No
work practices is recorded.
2. The occurrence of each semiannual visual inspection for control YD No
equipment failures is recorded.
3. For each inspection during which a control equipment failure was
identified, the following were recorded and reported in the next
PR*
(a) Date of the inspection. YD N D
(b) Identification of the oil-water separator having the failure. YD No
(c) Description of the failure. YD N D
(d) Description of the nature of the repair. YD N D
(e) Date the repair was made. YD N D
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND A CLOSED-
VENT SYSTEM ROUTED TO A CONTROL DEVICE
Review records listed in Tables 8-14 and 8-15.
IF THE CONTROL EQUIPMENT IS A FLOATING ROOF
1. Records indicate that seal gap measurements were performed YD ND
annually for the secondary seal and every five years for the
primary seal.
2. When a failure is detected, the date and results of seal gap YD N D
measurements are submitted in periodic reports, annually for the
secondary seal and every five years for the primary seal.
3. When a control equipment failure is detected in the seal(s). the YD N D
date and results of the visual inspection of the seals (which is
performed together with the seal gap measurement) are included
In the PR a
(continued)
p|sJ135/lable-6.12 8-44
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
4. The date of the seal gap measurement, the raw data obtained YD No
during the measurement, and the calculations made are
recorded.
5. The raw data and calculations recorded for seal gap YD No
measurements is consistent with the information provided in the
PR.
6. If a failure was detected during a seal gap measurement and YD N D
visual seal Inspection, the PR indicated the date and the nature of
the repair or the date the wastewater tank was emptied.
II. VISUAL INSPECTION
A. WASTEWATER TANKS
IF THE CONTROL EQUIPMENT IS A FIXED ROOF
1. All openings (e.g., access hatches, sampling ports, and gauge YD N D
wells) are maintained in a closed, sealed position (e.g., covered
by a lid that is gasketed and latched) when not in use
(e.g., during sampling, equipment maintenance, inspection, or
repair).
[Note: The Inspector should also check the fixed roof for leaks in
accordance with the procedures specified in Table 8-14.]
IF THE CONTROL EQUIPMENT IS A FIXED ROOF WTTH A CLOSED-
VENT SYSTEM ROUTED TO A CONTROL DEVICE
1. All openings (e.g., access hatches, sampling ports, and gauge YD N D
wells) are maintained in a closed, sealed position (e.g., covered
by a lid that is gasketed and latched) when not in use
(e.g., during sampling, equipment maintenance, inspection, or
repair).
[Note: The inspector should also check the fixed roof and
closed-vent system for leaks in accordance with the procedures
specified in Table 8-14 and inspect the control device in
accordance with the procedures in Table 8-15.]
(continued)
p)sJ135/table-B.12 8-45
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
Note: The inspector should not perform the inspection while on the EFR if the roof is below four feet
of the top of the tank and if the inspector is not equipped with the proper respiratory
protection. Based on the inspector's assessment of the availability of records documenting the
design of the control equipment, an adequate Inspection without respiratory protection may be
performed with a combination of a record inspection and a visual inspection conducted from
the platform with the aid of vision-enhancing devices (binoculars).
1 . The EFR is resting on the liquid surface of the stored material, YD N a
unless the EFR is resting on the roof leg supports because the
wastewater tank has just been emptied and degassed or the tank
is partially or completely emptied before being subsequently
refilled or degassed.
2. The external floating roof is in good condition (i.e., free of defects YD N a
such as corrosion and pools of standing liquid).
3. There is a secondary seal installed above the primary seal.0 YD No
4. Inspect the secondary
(a) The secondary seal is continuous and completely covers YD N a
the annular space between the EFR and the tank wall.
(b) There are no holes, tears, or other openings in the seal or YD N a
seal fabric.
(c) There are no visible gaps between the seal and the wall YD N n
of the wastewater tank, except as specified in (e)(l) and
(d) The seal is not detached from the floating deck. YD . N o
(e) Perform seal gap measurement of the secondary seal as
specified in §63.120(b)(2)(i) through (b)(2)(iii) and
§63.l20(b)(4) of the HON storage provisions.
(1) The accumulated area of gaps between the tank YD No
wall and the secondary seal does not exceed
21.2 cm2 per meter of tank diameter.
(2) The maximum gap width between the tank wall YD N D
and the seal does not exceed 1.27 cm.
(continued)
pj9J135/table-«.12 8-46
-------
TABLE 8-12. COMPUANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
5. Inspect the primary seal.b
(a) The primary seal Is either a metallic shoe seal or a liquid- YD N a
mounted
(b) The primary seal forms a continuous closure that YD N D
completely covers the annular space between the wall of
the wastewater tank and the edge of the EFR, except as
described In (f)(1) and (0(2).
(c) There are no holes, tears, or other openings In the seal YD N D
fabric, seal envelope, or shoe (if a metallic shoe seal is
used).
(d) If the primary seal Is a metallic shoe seal:
(1) The lower end of the metallic shoe send extends YD ND
into the stored liquid (no specific distance);
(2) The upper end of the metallic shoe seal extends YD No
a minimum vertical distance of 61 cm above the
stored liquid surface; and
(3) There is a flexible coated fabric that spans the YD N D
space between the metal shoe and the tank wall.
(e) If the primary seal is a liquid-mounted seal, the seal Is In YD N D
contact with the liquid between the wall of the wastewater
tank and the EFR.
(f) Perform seal gap measurements of the primary seal as
specified in §63. 1 20 (b) (2)0) through (b)(2)(iii) and
§63.120(b)(4) of the HON storage provisions.
(1) The accumulated area of gaps between the tank .YD ND
wall and the primary seal does not exceed
212 cm2 per meter of tank diameter.
(2) The maximum gap width between the tank wall YD N D
and the seal does not exceed 3.81 cm.
6. Inspect deck openings.
(a) If the EFR is non-contact, then each opening in the YD N D
floating roof, except automatic bleeder vents and rim
space vents, provides a projection below the stored
liquid's surface.0
(continued)
pjsJ135/tat>lo-e.12 8-47
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(b) Except for automatic bleeder vents, rim space vents, roof YD N a
drains, and leg sleeves, each opening in the roof is
equipped with a gasketed cover, seal, or lid which forms
a vapor-tight seal.
(c) Each gasketed cover, seal, or lid on any opening In the YD N a
EFR is closed, unless the cover or lid must be open for
access.
(d) Covers on each access hatch and gauge float well are YD N D
bolted or fastened so as to be air-tight when closed.
(e) The gasket on each cover, seal, or lid described in (b) YD N D
closes off the liquid surface from the atmosphere.
7. Inspect automatic bleeder vents.
(a) Automatic bleeder vents are closed, unless the roof Is YD N D
being floated off or is being landed on the roof leg
supports.
(b) Automatic bleeder vents are gasketed. YD N D
(c) The gasket on the automatic bleeder vents close off the YD N D
liquid surface from the atmosphere.
8. Inspect rim space vents.
(a) Rim space vents are dosed, except when the roof is YD N D
being floated off the roof leg supports or when the
pressure beneath the rim seal exceeds the manufacturer's
recommended setting.
' (b) Rim space vents are gasketed. YD N D
(c) The gaskets on the rim space vents dose off the liquid YD N D
surface from the atmosphere.
9. Each roof drain is covered with a slotted membrane fabric that YD N D
covers at least 90 percent of the area of the opening.
10. Each unslotted guide pole well has either a gasketed sliding YD ND
cover or a flexible fabric sleeve seal.
11. Each unslotted guide pole shall have on the end of the pole a YD N D
gasketed cap which is dosed at all times except when gauging
the liquid level or taking liquid samples.
(continued)
pjs|135/table-e.12 8-48
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
12. Each slotted guide pole well Is equipped with the following YD No
equipment: (1) a gasketed sliding cover or a flexible fabric sleeve
seal, and (2) a gasketed float inside the guide pole or other
control device which closes off the liquid surface from the
atmosphere.
13. Each gauge hatch/sample well has a gasketed cover which is YD N n
closed (except when the hatch or well must be open for access).
14. All of the gaskets described in 10 through 13 dose off the liquid YD Nn
surface from the atmosphere.
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND AN INTERNAL
FLOATING ROOF
Note: The inspector should be advised of the hazards of inspecting an internal floating roof vessel
that contains a liquid hazardous air pollutant (HAP). An inspector may perform an external
visual inspection of a wastewater 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 vessel is taken out of
service more frequently than is required by the HON, this internal inspection can only take
place once every ten years, during those 30 days after which the State Agency has received
notice that the tank has been emptied and degassed and will subsequently be refilled. The
inspector should never enter a wastewater 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 IFR that contains HAP (e.g., the EPA document "Confined Space Safety
Document for Conducting NESHAP Compliance Inspections of Benzene Storage Tanks.")
1. External Visual Inspection
(a) The IFR is resting on the liquid surface of the stored YD N D
material, unless the IFR is resting on the leg supports
because the vessel has just been emptied and degassed
or the vessel is partially or completely emptied before
being subsequently refilled or degassed.
(b) The IFR is in good condition (i.e., free of defects such as YD No
corrosion and pools of standing liquid).
(c) Inspect the seal 0-6., if a single-seal system is used,
inspect the single seal, and If a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the IFR. YD ND
(continued)
p]sJ135/lable-6.12 8-49
-------
TABLE 8-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(2) There are no holes, tears, or other openings in YD No
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N a
the wall of the wastewater tank.
2. Internal Visual Inspection
(a) The IFR is resting on the liquid surface of the stored YD N n
material, unless the IFR is resting on the leg supports
because the tank has just been emptied and degassed or
the tank Is partially or completely emptied before being
subsequently refilled or degassed.
(b) The IFR is in good condition (i.e., free of defects such as YD N n
corrosion and pools of standing liquid).
(c) The IFR Is equipped with one of the following closure YD N D
devices, between the wall of the wastewater tank and the
edge of the IFR: (1) a liquid-mounted seal, (2) a metallic
shoe seal, or (3) two seals (I.e., a primary and secondary
seal), each of which forms a continuous closure that
completely covers the annular space between the wall of
the wastewater tank and the edge of the IFR.d
(d) Inspect the seal (i.e., if a single-seal system is used,
inspect the single seal, and If a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the IFR. YD ND
(2) There are no holes, tears, or other openings in YD N D
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N D
the wall of the wastewater tank.
(e) Inspect deck openings.
(1) If the IFR is non-contact, then each opening in YD ND
the floating roof, except for automatic bleeder
vents and rim space vents, provides a projection
below the stored liquid's surface.0
(2) Except for leg sleeves, automatic bleeder vents, YD N D
rim space vents, column wells, ladder wells,
sample wells, and stub drains, each opening in
the IFR is equipped with a gasketed cover or lid.6
(continued)
pjs|135/lat>le-8.12 8-50
-------
TABLE 8-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(3)
(4)
(5)
(f) Inspect
(D
(2)
(3)
(g) Inspect
(D
(2)
(3)
Each cover or lid on any opening in the IFR is
closed, unless the cover or lid Is open for access.
Covers on each access hatch and automatic
gauge float well are bolted or fastened so as to
be air-tight when closed.
The gasket on each cover or lid described in (3)
closes off the liquid surface from the atmosphere.
automatic bleeder vents.
Automatic bleeder vents are closed, unless the
roof is being floated off or is being landed on the
roof leg supports.
Each automatic bleeder vent is gasketed.6
The gasket on each automatic bleeder vent
closes off the liquid surface from the atmosphere.
rim space vents.
Rim space vents are closed, except when the
roof is being floated off the roof leg supports or
when the pressure beneath the rim seal exceeds
the manufacturer's recommended setting.
Rim space vents are gasketed.6
The gaskets on the rim space vents close off the
YD
YD
YD
YD
YD
YD
YD
YD
YD
No
ND
No
No
NO
ND
No
NO
ND
liquid surface from the atmosphere.
(h) Each, sample well (i.e., each penetration of the IFR for YD No
the purpose of sampling), has a slit fabric cover that
covers at least 90 percent of the opening.6
(I)
0)
(k)
0)
Each penetration of the IFR that allows for passage of a YD
ladder has a gasketed sliding cover.6
Each penetration of the IFR that allows for passage of a YD
column supporting the fixed roof has either a flexible
fabric sleeve seal or a gasketed sliding cover.6
The gaskets described in (i) and (j) dose off the liquid Y o
surface to the atmosphere.
If a flexible fabric sleeve seal is used as described In (j), Y o
the fabric sleeve is free of defects (I-6-, free of holes,
tears, or gaps).
No
No
No
No
(continued)
p|3)135Aable-8.12 8-51
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
B. SURFACE IMPOUNDMENTS
1. Access hatches and all other openings are closed and gasketed YD N a
when not in use.
2. All control equipment is functioning properly (e.g., seals, gaskets, YD N a
joints, lids, covers, and doors are not cracked, gapped, or
broken).
[Note: The Inspector should also check the cover and closed-
vent system for leaks in accordance with the procedures In
Table 8-14 and inspect the control device in accordance with the
procedures in Table 8-15.]
C. CONTAINERS
1. For containers with 0.1 < capacity <0.42 m^.
(a) The container meets existing DOT specifications and YD N D
testing requirements.
(b) The cover and all openings are maintained in a closed, YD N D
sealed position (e.g., covered by a lid that is gasketed
and latched) when not in use (e.g., during filling).
2. For containers with capacity >0.42 trft.
(a) The container is equipped with a submerged fill pipe that YD No
does not extend more than 6 inches or within two fill pipe
diameters of the bottom of the container while the
container is being filled.
(b) The cover and all openings, except those required for the Y a N a
submerged fill pipe and for venting to prevent damage or
deformation of the container or cover, are closed and
sealed.
3. Whenever a container with capacity >0.1 m3 Is open, It is located YD N D
within an enclosure that is routed by a closed-vent system to a
control device.
4. All control equipment is functioning properly (e.g., seals, gaskets, YD N D
joints, lids, covers, and doors are not cracked, gapped, or
broken).
(continued)
pJsJ135/lable-a.12 8-52
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
[Note: The Inspector should also check the cover and closed-
vent system for leaks In accordance with the procedures In
Table 8-14 and inspect the control device in accordance with the
procedures in Table 8-15.]
0. INDIVIDUAL DRAIN SYSTEMS
1. If the control equipment is a cover and a closed-vent system
routed to a control device:
(a) The individual drain system is designed and operated to YD No
segregate the vapors within the system from other drain
systems and the atmosphere through means such as
water seals.
(b) The cover and ail openings (e.g., access hatches, YD No
sampling ports, and gauge wells) are maintained in a
closed, sealed position (e.g., covered by a lid that is
gasketed and latched) when not in use (e.g., during
sampling, equipment maintenance, inspection, or repair).
(c) All control equipment is functioning properly (e.g., seals, YD N a
gaskets, joints, lids, covers, and doors are not cracked,
gapped, or broken).
[Note: The inspector should also check the closed-vent system
for leaks in accordance with the procedures specified in
Table 8-14 and inspect the control device In accordance with the
procedures in Table 8-15.]
2. For drains and junction boxes, as an alternative to Item 1:
(a) Each drain is equipped with either water seal controls YD No
(e.g., p-trap, s-trap) or a tightly-sealed cap or plug.
(b) There is water in the p-trap or s-trap. YD No
(c) If a water seal is used on a drain hub receiving a Group 1 YD N D
process wastewater stream, the drain pipe discharging
the wastewater extends below the liquid surface in the
water seal [or (d)].
(d) A flexible cap (or other enclosure which restricts wind YD N D
motion) is installed that encloses the space between the
drain discharging the wastewater and the drain hub
receiving the wastewater.
(continued)
pjs|135/lable-a.12 8-53
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(e) Each junction box is equipped with a cover, and, if Y a N a
vented, is equipped with a vent pipe.
(f) Any vent pipe Is at least 90 centimeters in length and YD N D
shall not exceed 10.2 centimeters in diameter.
(g) Junction box covers have tight seals around the edge. YD N a
(h) Junction box covers are kept in place at all times except YD N D
during inspection and maintenance.
(i) Each junction box is equipped with a system (e.g., water YD N D
seal controls) to prevent the flow of organic HAP vapors
from the vent pipe to the atmosphere during normal
operation.
(j) The vent pipe is connected to a closed vent system that YD N D
meets the requirements in Table 8-14 and is routed to a
control device that meets the requirements in Table 8-15.
(k) Each sewer line is not open to the atmosphere and is YD N D
covered or enclosed so that no visible gaps or cracks in
joints, seals, or other emission interfaces exist
E OIL-WATER SEPARATORS
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND A CLOSED
VENT SYSTEM ROUTED TO A CONTROL DEVICE
1. All openings (e.g., access hatches, sampling ports, and gauge YD N D
wells) are maintained in a closed, sealed position (e.g., covered
by a lid that Is gasketed and latched) when not in use
(e.g., during sampling, equipment maintenance, inspection, or
repair).
2. All control equipment is functioning properly (e.g., seals, gaskets, YD N D
joints, lids, covers, and doors are not cracked, gapped, or
broken).
[Note: The inspector should also check the fixed roof and
closed-vent system for leaks in accordance with the procedures
specified in Table 8-14 and inspect the control device in
accordance with the procedures in Table 8-15.]
(continued)
pjs|135/table-6.12 8-54
-------
TABLE 8-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
IF THE CONTROL EQUIPMENT IS A FLOATING ROOF
Note: The inspector should not perform the inspection while on the floating roof if the roof is below
four feet of the top of the separator and if the inspector is not equipped with the proper
respiratory protection. Based on the inspector's assessment of the availability of records
documenting the design of the control equipment, an adequate inspection without respiratory
protection may be performed with a combination of a record inspection and a visual inspection
conducted from the platform with the aid of vision-enhancing devices (binoculars).
1. The floating roof Is resting on the liquid surface of the stored YD N a
material, unless the floating roof Is resting on the roof leg
supports because the oil-water separator has just been emptied
and degassed or the tank is partially or completely emptied
before being subsequently refilled or degassed.
2. The floating roof is in good condition (i.e., free of defects such as Y a N o
corrosion and pools of standing liquid).
3. There is a secondary seal installed above the primary seal. YD No
4. Inspect the secondary seal.
(a) The secondary seal is continuous and completely covers YD N o
the annular space between the floating roof and the
separator wall.
(b) There are no holes, tears, or other openings in the seal or YD N D
seal fabric.
(c) There are no visible gaps between the seal and the wall YD N D
of the oil-water separator, except as specified in (e)(1)
and(e)(2).
(d) The seal is not detached from the floating deck. YD N D
(e) Perform seal gap measurement of the secondary seal as
specified in §60.696(d)(1) of the standards of
performance for VOC emissions.
(1) The total gap area between the separator wall YD No
and the secondary seal does not exceed 6.7 cm2
per meter (0.32 In^/ft) of the separator wall
perimeter.
(2) The maximum gap width between the separator YD No
wall and the seal does not exceed 1.3 cm (0.5 in)
at any point.
(continued)
pjs|135/table-e.12 8-55
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
5. Inspect the primary seal.
(a) The primary seal is a liquid-mounted seal. YD N a
(b) The primary seal forms a continuous closure that YD No
completely covers the annular space between the wall of
the oil-water separator and the edge of the floating roof,
except as described in (0(1) and (0(2).
(c) There are no holes, tears, or other openings in the seal YD No
fabric, seat envelope, or shoe (if a metallic shoe seal is
used).
(d) If the primary seal is a liquid-mounted seal (e.g., foam or YD N D
liquid-filled seal), the seal is in contact with the liquid
between the wall of the oil-water separator and the
floating roof.
(e) The seal Is not detached from the floating roof. YD N D
(0 Perform seal gap measurements of the primary seal as
specified in §60.696(d)(1) of the standards of
performance for VOC emissions.
(1) The total gap area between the separator wall YD No
and the primary seal does not exceed 67 cm2
per meter (3.2 in^/ft) of separator wall perimeter.
(2) The maximum gap width between the separator YD N D
wall and the seal does not exceed 3.8 cm (1.5 in)
at any point.
6. If the floating roof is equipped with one or more emergency roof YD .N D
drains for removal of stormwater, each emergency roof drain is
fitted with a slotted membrane fabric cover that covers at least
90 percent of the drain opening area or a flexible fabric sleeve
seal.
7. All openings in the floating roof are equipped with a gasketed YD N D
cover, seal, or lid, which is maintained in a dosed position at all
times, except during inspection and maintenance.
8. No gaskets, joints, lids, covers, or doors are cracked, gapped, or YD N D
broken.
a PR = Periodic Report
(continued)
p|s|135Aable-e.12 8-56
-------
TABLE 8-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
b If the external floating roof is equipped, as of December 31,1992, with either (1) a liquid-mounted
primary seal and no secondary seal, or (2) a vapor mounted primary seal and a secondary seal, then
the seal requirement of a liquid-mounted or metallic shoe primary seal and secondary seal does not
apply until the earlier of the following dates: (1) the next time the storage vessel is emptied and
degassed, or (2) April 22, 2004. For such wastewater tanks, measurements of gaps in the primary
seal must be conducted once per year until a secondary seal is installed.
c If these openings (excluding automatic bleeder vents and rim space vents) did not provide projections
below the liquid service as of December 31,1992, this requirement does not apply until the earlier of
the following dates: (1) the next time the storage vessel is emptied and degassed, or (2) no later than
April 22. 2004.
d if the internal floating roof is equipped, as of December 31,1992, with a single vapor-mounted seal,
then the requirement for a liquid-mounted seal or metallic shoe seal-or two seals does not apply until
the earlier of the following dates: (1) the next time the storage vessel is emptied and degassed, or
(2) April 22, 2004.
6 If the internal floating roof did not meet these specifications as of December 15,1992, the requirement
to meet these specifications does not apply until the earlier of the following dates: (1) the next time
the storage vessel is emptied and degassed, or (2) no later than April 22, 2004.
NOTE ALL DEFICIENCIES.
pJsJ135/lable-6.12 8-57
-------
TABLE 8-13. COMPLIANCE CHECKLIST FOR TREATMENT PROCESSES
Complete this form for treatment processes. A 'yes" response to all questions will Indicate full
compliance, and "no" responses will indicate noncompliance except where noted.
Note: The HON does not specify a particular treatment process that must be used to achieve
compliance. The source may use any waste management unit or treatment process to achieve
compliance with one of the control options (or a combination of control options). If the source
elects to use a design steam stripper, the HON does specify operating parameters in
§63.138(g) of Subpart G. These operating parameters are included in this checklist..
TREATMENT PROCESS
DATE OF STARTUP .
I. REVIEW OF RECORDS
FOR ALL TREATMENT PROCESSES
1a. Identification and description of the treatment process, YD ND
identification of the wastewater streams treated by the
process, and identification of monitoring parameters were
included in the NCS.a
1b. If a treatment process other than the design steam stripper YD N a
is used, the request to monitor site-specific parameters was
included in the Implementation Plan or operating permit
application.
2. Documentation to establish a site-specific range was YD N a
submitted in the NCS or operating permit application.
3. Results of the initial measurement of the parameters YD N D
approved by the Administrator were submitted in the NCS or
operating permit application.
4. Records of a design evaluation and supporting YD N D
documentation that includes operating characteristics were
included in the NCS [or #5].
5. Records of performance tests conducted using test methods YD N D
and procedures specified in §63.145 of Subpart G were
included in the NCS.
(continued)
pjs|135/table-e.13 8-58
-------
TABLE 8-13. COMPLIANCE CHECKLIST FOR TREATMENT PROCESSES
[Note: The records described in #4 and #5 are not required if the
wastewater stream or residual is discharged to: (1) a hazardous
waste incinerator permitted under 40 CFR Part 270 and complying
with 40 CFR Part 264 Subpart 0; (2) an industrial furnace or boiler
burning hazardous waste that is permitted under 40 CFR Part 270
and complying with 40 CFR Part 266, Subpart H; (3) an Industrial
furnace or boiler burning hazardous waste for which the owner or
operator has certified compliance with the interim status
requirements of 40 CFR Part 266 Subpart H; or (4) an underground
injection well permitted under 40 CFR Part 270 or 40 CFR Part 144
and complying with 40 CFR Part 122.]
6. Records described In #4 and #5 demonstrate that the level YD No
of treatment required by §63.138(b) and/or (c) is achieved.
7. Results of visual inspections, in which a control equipment
failure was identified, were reported in the PRb, Including:
(a) Identification of the treatment process, YD No
(b) Description of the failure, YD N D
(c) Description of the nature of the repair, and Y D N D
(d) Date the repair was made. YD N a
8. For each parameter approved by the permitting authority
that is required to be monitored continuously:
(a) Records of the dally average value of the parameter YD N D
are kept.
(b) Each operating day, when the dally average value of YD N D
the parameter was outside the site-specific range
established In the NCS (i.e., a monitoring parameter
excursion is detected), or when insufficient
monitoring data are collected, they are reported in
the PR.
9. For each treatment process that receives a residual removed
from a Group 1 wastewater stream, the following were
submitted in the NCS:
(a) Identification of treatment process; YD N D
(b) Identification and description of the residual; YD N D
(c) Identification of wastewater stream from which YD N D
residual was removed;
(continued)
pjsJ135/lable4.13 8-59
-------
TABLE 8-13. COMPLIANCE CHECKUST FOR TREATMENT PROCESSES
(d)
(e)
Fate of residual;
Identification and description of control device
(if
YD
YD
No
No
any) used to destroy the HAP mass in the residual
by 99 percent; and
(f) Documentation of the 99 percent control efficiency YD N D
of the device in (e).
10. Records show that residuals are in compliance with control YD ND
options in §63.138(h) of Subpart G.
FOR DESIGN STEAM STRIPPERS
1. Records are kept of the steam flow rate, wastewater feed YD ND
mass flow rate, and wastewater feed temperature.
2. If the parameters in #1 are not monitored, the facility has YD N D
documentation that they applied for and received approval
to monitor alternative parameter(s) and are performing the
required recordkeeping and reporting.
[Note: If #2 is checked "Yes", the facility is in compliance
even if number 1 is checked "No".]
FOR BIOLOGICAL TREATMENT UMTS
1. Records are kept of appropriate monitoring parameters that YD N D
were approved by the permitting authority.
2. Records are kept of the bench-scale or pilot-scale test using YD N D
Method 304 (or any other method approved by the EPA) in
conjunction with a wastewater model (e.g., WATER?,
BASTE, TOXCHEM, or any other model validated by
Method 301).
II. VISUAL INSPECTION
FOR ALL TREATMENT PROCESSES
1. Each opening in the treatment process (except biological YD N D
treatment systems) is covered and vented to a closed-vent
system that Is routed to a control device.
2. Any associated closed-vent system Is in compliance with the YD N D
HON according to the checklist in Table 8-14.
(continued)
pjsJ135/table-e.13 8-60
-------
TABLE 8-13. COMPLIANCE CHECKLIST FOR TREATMENT PROCESSES
3. Any associated control device Is In compliance with the YD No
HON according to the checklist in Table 8-15.
4. Each cover is kept closed and is in compliance with the YD No
HON according to the checklist in Table 8-14.
FOR DESIGN STEAM STRIPPERS
1. The minimum active column height Is at least 5 meters. YD N D
2. The countercurrent flow configuration has a minimum of YD N D
10 actual trays.
3. The minimum steam flow rate is 0.04 kilograms of steam per YD No
liter of wastewater feed.
4. The minimum wastewater feed temperature to the steam YD N D
stripper is 95 °C.
5. The maximum liquid loading is 67,100 liters per hour per YD No
square meter.
6. The minimum steam quality is 2,765 kiloJoules per kilogram. YD N D
7. Associated waste management units, closed-vent systems, YD N D
and control devices meet the requirements in Tables 8-12,
8-14. and 8-15.
FOR BIOLOGICAL TREATMENT UNITS
The treatment process is in compliance with all visual YD N D
Inspection parameters approved by the permitting authority
and/or specified in the operating permit
a NCS = Notification of Compliance Status.
D PR = Periodic Report
NOTE ALL DEFICIENCIES
pjsj135/lable-6.13 8-61
-------
TABLE 8-14. COMPLIANCE CHECKLIST FOR CONTROL EQUIPMENT REQUIRING
LEAK DETECTION8^
Complete this form for closed-vent systems. A "yes" response to all questions will Indicate full
compliance, and "no" responses will indicate noncompliance except where noted.
CONTROL OR RECOVERY DEVICE
DATE OF STARTUP
I. REVIEW OF RECORDS
IF THE CONTROL EQUIPMENT IS A VAPOR-COLLECTION
SYSTEM. CLOSED-VENT SYSTEM, COVER. ENCLOSURE,
OR FIXED ROOF
1. Records are kept of all parts of any vapor-collection YD No
system, closed-vent system, fixed roof, cover, or
enclosure that are designated as either unsafe-to-
inspect or d'rfficult-to-inspect.
2. For equipment that is designated as difficult to inspect, YD N D
a written plan is kept that requires inspection of
equipment at least once every five years.
3. For equipment that is designated as unsafe to Inspect, YD N D
a written plan is kept that requires inspection of
equipment as frequently as practicable.
4. For each Inspection during which a leak was detected,
the following information Is recorded and reported.0
(a) Instrument identification numbers, operator YD N D
name or initials, and equipment identification
information;
(b) The date the leak was detected and the date of YD N D
the first attempt to repair it;
(c) Maximum instrument reading after the leak is YD N D
repaired or determined to be non-repairable;
(d) Explanation of delay in repair, if the leak was YD N D
not repaired within 15 days after ft was
discovered;
(e) Name or initials of person who decides repairs YD N D
cannot be made without a shutdown;
(continued)
pJsj135Aable-8.14 8-62
-------
TABLE 8-14. COMPUANCE CHECKUST FOR CONTROL EQUIPMENT REQUIRING
LEAK DETECTION
(f) Expected date of successful repair If not YD No
repaired within 15 days;
(g) Dates of shutdowns that occur while the YD No
equipment Is unrepaired; and
(h) Date of successful repair of the leak. YD No
5. For each inspection during which no leaks were
detected, the following records are kept:
(a) Record that the inspection was performed; YD N D
(b) Date of the inspection; and YD N D
(c) Statement that no leaks were found. YD N D
IF THE CONTROL EQUIPMENT IS A VAPOR COLLECTION
SYSTEM OR CLOSED-VENT SYSTEM
1. Hourly records are kept of whether the flow indicator in YD N D
the bypass line was operating and whether flow was
detected at any time during the hour, when seal
mechanisms are not used and
2. The time and duration of all periods when flow Is YD N D
diverted or the monitor Is not operating are reported0
when seal mechanisms are not used [or #3 and #4]
3. Records of monthly visual inspections are kept when YD N D
seal mechanisms are used and
4. All periods when the seal mechanism Is broken, the YD N D
bypass line valve position has changed, or the key to
unlock the bypass line valve was checked out are
recorded and reported0 when seal mechanisms are
used.
[Note: In order to be in compliance with provisions for
bypass lines, either #1 and #2 must both be checked
yes' or both #3 and #4 must be checked "yes'.]
II. VISUAL INSPECTION
Visual inspection of the facility is consistent with written YD N D
records.
(continued)
pJ$J135Aable-8.14 8-63
-------
TABLE 8-14. COMPLIANCE CHECKLIST FOR CONTROL EQUIPMENT REQUIRING
LEAK DETECTION
IF THE CONTROL EQUIPMENT IS A VAPOR-COLLECTION
SYSTEM OR CLOSED-VENT SYSTEM
A flow indicator is present at the entrance to any YD No
bypass line that could divert the vent stream flow away
from the control device to the atmosphere .or all bypass
line valves are sealed In a closed position (e.g., with a
car seal or lock-and-key configuration).
a This checklist is not applicable to closed-vent systems that are subject to §63.172 in the negotiated
rule for equipment leaks (40 CFR Part 63 Subpart H) because such closed-vent systems are exempt
from the requirements in §63.148 of Subpart G of the HON.
° This checklist is not applicable to vapor-collection systems, closed-vent systems, covers,
enclosures, and fixed roofs that are operated and maintained under negative pressure.
c Information is submitted as part of the reports required by §63.182(b) of Subpart H.
NOTE ALL DEFICIENCIES
p|s)135/lable-e.14 8-64
-------
TABLE 8-15. COMPUANCE CHECKUST FOR WASTEWATER CONTROL DEVICES
Complete this form for wastewater control devices. A "yes" response to all questions will indicate full
compliance, and "no" responses will indicate noncompliance with the standard except where noted.
CONTROL OR RECOVERY DEVICE
DATE OF STARTUP
I. REVIEW OF RECORDS
IF THE CONTROL DEVICE IS A FLARE
1. Results of the initial test were submitted In the NCS.a YD No
2. The presence of a continuous flare pilot flame is monitored YD No
using a device designed to detect the presence of a flame.
3. All periods when all pilot flames to a flare were absent or the YD No
monitor was not operating have been recorded and
reported in the PR.&
4. If the presence of a continuous flare pilot flame is not
monitored, either:
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with
questions f(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
IF THE CONTROL DEVICE IS A THERMAL INCINERATOR
1. Results of the initial performance test were submitted in the YD N D
NCS.a
2. Test documentation demonstrates 95 percent HAP or TOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
(continued)
pJsJ135/table-e.1S 8-65
-------
TABLE 8-15. COMPUANCE CHECKUST FOR WASTEWATER CONTROL DEVICES
3. A temperature monitoring device equipped with a YD No
continuous recorder is used to measure the temperature of
the gas stream in the firebox (or in the ductwork
immediately downstream of the firebox before any
substantial heat exchange occurs).
4. Documentation to establish a site-specific range for firebox YD No
temperature was submitted in the NCSa or operating permit
application.
5. Continuous records0 of firebox temperature are kept YD N o
6. Records of daily average firebox temperature are kept YD No
7. All daily average firebox temperatures that are outside the YD N D
site-specific established range and all operating days when
insufficient monitoring data are collected are reported in the
PR.b
8. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.^
9. If the firebox temperature Is not monitored, either
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD No
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) Ail daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
[Note: If #9(a) Is checked "Yes", .or 9(b), 9(c), and 9(d) are
checked "Yes*, the facility is in compliance even if numbers
3 through 8 are checked 'No'.]
IF THE CONTROL DEVICE IS A CATALYTIC INCINERATOR
1. Results of the initial performance test were submitted in the YD N D
NCS.a
(continued)
p]sJ135/table-6.1S 8-66
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TABLE 8-15. COMPUANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
2. Test documentation demonstrates 95 percent HAP or TOO YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOO.
3. Temperature monitoring devices equipped with continuous YD No
recorders are used to measure the temperature in the gas
stream Immediately before and after the catalyst bed.
4. Documentation to establish a site-specific range for the gas YD N o
stream temperature upstream of the catalyst bed and the
temperature difference across the bed was submitted in the
NCSa or operating permit application.
5. Continuous records0 are kept of the temperature of the gas YD No
stream upstream of the catalyst bed and the temperature
difference across the catalyst bed.
6. Records of the daily average temperature upstream of the YD No
catalyst bed and the temperature difference across the
catalyst bed are kept.
7. All daily average upstream temperatures that are outside the YD N D
site-specific range and all operating days when Insufficient
monitoring data are collected are reported in the PR.b
8. All daily average temperature differences across the catalyst YD N D
bed that are outside the site-specific range and all operating
days when Insufficient monitoring data are collected are
reported in the PR.b
9. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.^
10! If the temperature upstream of the catalyst bed and /or the
temperature differential across the catalyst bed are not
monitored, either
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading Indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(continued)
pJsJ13SAable-8.15 8-67
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TABLE 8-15. COMPLIANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.D
[Note: If #lO(a) is checked "Yes", or I0(b), 10(c), and 10(d)
are checked "Yes", the facility is in compliance even if
numbers 3 through 9 are checked "No".]
IF THE CONTROL DEVICE IS 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
1. Results of the initial performance test were submitted in the YD N D
NCS.a
2. A description of the location at which the vent stream is YD N D
introduced into the boiler or process heater was submitted
in the NCS.a
3. The vent stream is introduced into the flame zone of the YD N D
boiler or process heater.
4. Test documentation demonstrates 95 percent HAP orTOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
5. A temperature monitoring device equipped with a YD N D
continuous monitor is used to measure the temperature of
the gas stream in the firebox
6. Documentation to establish a site-specific range for firebox YD N D
temperature was submitted in the NCSa or operating permit
application.
7. Continuous records0 are kept of the firebox temperature. YD N D
8. Records of the daily average firebox temperature are kept YD N D
9. All daily average firebox temperatures that are outside the YD N D
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.D
10. The number of excursions does not exceed the number of YD ND
excused excursions in the semi-annual reporting period.01
(continued)
pjs|135/tat>le-6.15 8-68
-------
TABLE 8-15. COMPLIANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
11. If the firebox temperature is not monitored, either:
(a) The facility has documentation that they applied for YD N o
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeplng and reporting .or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the dally average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.D
[Note: If #11 (a) is checked "Yes11, or 11 (b). 1l(c). and 11(d)
are checked "Yes", the facility is in compliance even if
numbers 5 through 10 are checked "No".]
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER
WITH A DESIGN HEAT INPUT CAPACTTY GREATER THAN
44 MEGAWATTS
1. A description of the location at which the vent stream is YD N D
introduced into the boiler or process heater was submitted
in the NCS.a
2. The vent stream Is Introduced into the flame zone of the YD N D
boiler or process heater.
IF THE CONTROL DEVICE IS A REGENERATIVE CARBON
ADSORBER
la. Results of the initial performance test were submitted in the YD ND
NCS.a
1 b. Test documentation demonstrates 95 percent HAP orTOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
(continued)
pJsJ135/lable-6.15 8-69
-------
TABLE 8-15. COMPLIANCE CHECKUST FOR WASTEWATER CONTROL DEVICES
2. An integrating regeneration stream (e.g., steam) flow YD No
monitoring device having an accuracy of _+10 percent and
capable of recording total regeneration stream mass flow for
each regeneration cycle is used to measure regeneration
stream flow.
3. A carbon bed temperature monitoring device capable of YD No
recording the carbon bed temperature after each
regeneration and within 15 minutes of completing any
cooling cycle is used to measure carbon bed regeneration
temperature.
4. Documentation to establish a site-specific range for the YD N D
regeneration stream flow and carbon bed regeneration
temperature was submitted in the NCSa or operating permit
5. Records are kept of the total regeneration stream mass flow YD N D
for each carbon bed regeneration cycle.
6. Records are kept of the temperature of the carbon bed after YD N D
each carbon bed regeneration.
7. All regeneration cycles when the total regeneration stream YD N D
mass flow is outside the site-specific range are reported in
the PR.b
8. All regeneration cycles during which the temperature of the YD N D
carbon bed after regeneration is outside the site-specific
range are reported in the PR.b
9. If the regeneration stream flow and/or the carbon bed
regeneration temperature are not monitored, either:
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
(continued)
p]sJ135/table-6.15 8-70
-------
TABLE 8-15. COMPUANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
[Note: If #9(a) Is checked "Yes", or 9(b), 9(c), and 9(d) are
checked "Yes", the facility is in compliance even if numbers
2 through B are checked "No".]
IF THE CONTROL DEVICE IS A CONDENSER
1a. Results of the Initial performance test were submitted in the Y a N a
NCS.a
1 b. Test documentation demonstrates 95 percent HAP or TOC YD N a
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
2. A temperature monitoring device equipped with a YD No
continuous recorder is used to measure the product side
exit temperature.
3. Documentation to establish a site-specific range for the exit YD N D
temperature was submitted in the NCSa or operating permit.
4. Records of the daily average exit temperature are kept. YD N a
5. Continuous records0 of the exit temperature are kept YD N D
6. All product side daily average exit temperatures that are YD N D
outside the site-specific range are reported in the PR.b
7. If the exit temperature is not monitored, either
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All dally average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
(Note: If #7(a) is checked "Yes", or 7(b), 7(c). and 7(d) are
checked "Yes", the facility is in compliance even If numbers
2 through 6 are checked "No".]
(continued)
pjs]135/lable-e.1S 8-71
-------
TABLE 8-15. COMPLIANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
II.
1.
2.
VISUAL INSPECTION
For flares, a device for detecting the flame is present.
For all incinerators, and for boilers and process heaters with
YD
YD
ND
No
design heat input capacities less than 44 megawatts and the
vent steam Is not introduced with the primary fuel, a
temperature monitoring device is present
3. For carbon adsorbers, a device for measuring carbon bed YD No
temperature and a device for measuring regeneration
stream flow are present.
. 4. For condensers, a temperature monitoring device is present. YD No
5. Visual inspection of the facility is consistent with written YD No
records.
a NCS = Notification of Compliance Status.
D PR = Periodic Reports.
c Continuous records, as defined in §63.111, means documentation, either in computer readable
form or hard copy, or data values measured at least once every 15 minutes and recorded at the
frequency specified in §63.152(f). Section 63.152(f) allows the owner to record either values
measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
all measured values during each period. If the daily average value of a monitored value for a given
parameter is within the range established in the NCS, the owner or operator may retain block hourly
averages instead of the 15-minute values. An owner or operator may request approval to use
alternatives to continuous monitoring under §63.151 (g) of Subpart G.
. d The number of excused excursions is as follows:
For the first semi-annual period after the NCS is due - 6 excursions;
For the second semi-annual period - 5 excursions;
For the third semi-annual period - 4 excursions;
For the fourth semi-annual period - 3 excursions;
For the fifth semi-annual period - 2 excursions;
For the sixth and all subsequent semi-annual periods -1 excursion.
An excursion occurs when: (1) the daily average value of the monitored parameter is outside the
range established In the NCS or operating permit; or (2) if monitoring data are insufficient In order
to have sufficient data, a source must have measured values for each 15-minute period within each
hour for at least 75 percent of the hours the control device is operating in a day. For example, if a
control device operates 24 hours per day, data must be available for all 15-minute periods in at
least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
hour of Incomplete data is allowed.
(continued)
p)sJ135/tat>le-6.1S 8-72
-------
TABLE 8-15. COMPUANCE CHECKUST FOR WASTEWATER CONTROL DEVICES
NOTE ALL DEFICIENCIES
p|s|135/lable-6.15 8-73
-------
TABLE 8-16. COMPLIANCE CHECKUST FOR HEAT EXCHANGE SYSTEMS
REQUIRING LEAK DETECTION
Complete this form for closed-vent systems. A "yes* response to all questions will indicate full
compliance, and "no" responses will indicate noncompliance except where noted.
HEAT EXCHANGE SYSTEM
DATE OF STARTUP
Note: Sources are not required to comply with leak detection monitoring requirements if either:
(1) the heat exchange system is operated with the minimum pressure on the cooling water side
at least 35 kilopascals greater than the maximum pressure on the process side; or (2) the
once-through heat exchange system has an NPDES permit with an allowable discharge limit of
less than 1 ppm.
I. REVIEW OF RECORDS
1a. For once-through heat exchange systems, records indicate YD N D
that systems are monitored for leaks of HAPs listed on
Table 9 of Subpart G.
1b. For recirculating heat exchange systems, records indicate YD No
that systems are monitored for leaks of HAPs listed on
Table 2 of Subpart F, except for benzotrichloride (98077),
bis(chloromethyi)ether (542881), maleic anhydride
(108316), and methyl isocyanate (624839).
2. If there Is a delay of repair of a leak, the following
information was reported in the PRa and maintained as a
record.
(a) Identification of the leak and date the leak was YD N D
detected.
(b) Whether or not the leak has been repaired. YD No
(c) Reason for delay of repair. YD ND
(d) The expected date of repair if the leak remains Y a N a
unrepaired.
(e) The date of repair, If the leak is repaired. YD N D
II. VISUAL INSPECTION
Visual inspection of the facility Is consistent with written YD N D
records.
a PR = Periodic Reports.
(continued)
pjs)135/toble-e.16 8-74
-------
TABLE 8-16. COMPUANCE CHECKUST FOR HEAT EXCHANGE SYSTEMS
REQUIRING LEAK DETECTION
NOTE ALL DEFICIENCIES
p]s|135/toble-e.16 8-75
-------
TABLE 8-17. COMPUANCE CHECKUST FOR MAINTENANCE WASTEWATER MANAGEMENT
a '__^
Complete this form for maintenance wastewater management activities. A*yes* to all questions will
indicate full compliance, and 'no* responses will indicate noncompliance except where noted.
MAINTENANCE WASTEWATER STREAM
DATE OF STARTUP
I. REVIEW OF RECORDS
1. Records are kept of the procedures for managing YD No
maintenance wastewater as part of the startup, shutdown,
and malfunction plan.
2. The maintenance procedures specify the following Items:
(a) The process equipment and/or maintenance tasks YD N n
that are expected to create wastewater during
maintenance activities.
(b) The procedure for properly managing the YD N n
wastewater and controlling HAP emissions to the
atmosphere.
(c) The procedures for clearing materials from process YD N n
equipment.
II. VISUAL INSPECTION
All maintenance wastewater streams are being managed in YD No
accordance with the procedures specified in the start-up,
shutdown, and malfunction plan.
NOTE ALL DEFICIENCIES
8-76
-------
APPENDIX A - CODE OF FEDERAL REGULATIONS CITATIONS
Hazardous Organic NESHAP
40 CFR 63 Subpart F - National Emission Standards for Organic Hazardous Air Pollutants from
the Synthetic Organic Chemical Manufacturing Industry.
40 CFR 63 Subpart G - National Emission Standards for Organic Hazardous Air Pollutants from
Synthetic Organic Chemical Manufacturing Industry Process Vents, Storage Vessels, Transfer
Operations, and Wastewater.
40 CFR 63 Subpart H - National Emission Standards for Organic Hazardous Air Pollutants for
Equipment Leaks.
II. NESHAP General Provisions
40 CFR 63 Subpart A - General Provisions.
III. NSPS for SOCMI Process Vents
40 CFR 60 Subpart III - Standards of Performance tor Volatile Organic Compound Emissions
from the Synthetic Organic Chemical Manufacturing Industry Air Oxidation Processes.
40 CFR 60 Subpart NNN - Standards of Performance for Volatile Organic Compounds Emissions
from Synthetic Organic Chemical Manufacturing Industry Distillation Operations.
40 CFR 60 Subpart RRR - Standards of Performance for Volatile Organic Compound Emissions
from Synthetic Organic Chemical Manufacturing Industry (SOCMI) Reactor Processes.
IV. Test Methods
40 CFR 60 Appendix A, Method 1 - Sample and velocity traverses for stationary sources.
p|s|135/«ppendlx.a
9/27/94 A-1
-------
40 CFR 60 Appendix A, Method 1A - Sample and velocity traverses for stationary sources with
small stacks or ducts.
40 CFR 60 Appendix A, Method 2 - Determination of stack gas velocity and volumetric flow rate
(Type S pilot tube).
40 CFR 60 Appendix A, Method 2A - Direct measurement of gas volume through pipes and small
ducts.
40 CFR 60 Appendix A, Method 2C Determination of stack gas velocity and volumetric flow
rate in small stacks or ducts (standard pilot tube).
40 CFR 60 Appendix A, Method 2D - Measurement of gas volumetric flow rates In small pipes
and ducts.
40 CFR 60 Appendix A, Method 3B - Gas analysis for the determination of emission rate
correction factor or excess air.
40 CFR 60 Appendix A, Method 4 - Determination of moisture content in stack gases.
40 CFR 60 Appendix A, Method 18 - Measurement of gaseous organic compound emissions by
gas chromatography.
40 CFR 60 Appendix A, Method 21 - Determination of volatile organic compounds leaks.
40 CFR 60 Appendix A, Method 25A - Determination of total gaseous organic concentration
using a flame ionization analyzer.
40 CFR 60 Appendix A. Method 25D - Determination of total gaseous organic concentration
using purge apparatus.
40 CFR 60 Appendix A, Method 26 - Determination of hydrogen halide and halogen emissions
from stationary sources - midget impinger method.
p|s|135/appendix.a
9/27/94 A-2
-------
40 CFR 60 Appendix A, Method 26A - Determination of hydrogen halide and halogen emissions
from stationary sources - isokinetic method.
40 CFR 63 Appendix A, Method 301 - Field validation of emission concentrations from stationary
sources.
40 CFR 63 Appendix A, Method 304A - Determination of biodegradation rates of organic
compounds (vent option).
40 CFR 63 Appendix A, Method 304B - Determination of biodegradation rates of organic
compounds (scrubber option).
40 CFR 63 Appendix A, Method 305 Measurement of emission potential of Individual volatile
organic compounds in waste.
V. Procedures
40 CFR 63 Appendix C - Determination of the fraction biodegraded (FDjo) in a biological
treatment unit.
pjs|135/appendlx.a
9/27/94 A-3
-------
APPENDIX B - COMPARISON OF RON PROCESS VENT PROVISIONS WITH DISTILLATION,
AIR OXIDATION. AND REACTORS NSPS
This Appendix summarizes the major differences between the HON process vent provisions and
the SOCMI distillation, air oxidation, and reactors NSPS (40 CFR 60, Subparts NNN, III, and RRR,
respectively). The comparison is organized into the following sections: applicability; control techniques;
performance testing; monitoring; and recordkeeping and reporting.
Applicability
The three NSPS apply only to new sources. A new distillation facility is defined as a
facility for which construction, modification, or reconstruction commenced after
December 30, 1983. A new air oxidation facility is defined as a facility for which
construction, modification, or reconstruction commenced after October 21, 1983. The
date for reactors is June 29, 1990.
The NSPS apply to VOC's, while the HON applies to HAP's.
The SOCMI chemical lists for the HON and the distillation, air oxidation, and reactor
NSPS are different. The SOCMI list for the distillation, air oxidation, and NSPS can be
found in 40 CFR §60.667, §60.617, and §60.707, respectively.
The definition of a halogenated vent stream in the HON is any vent stream from a
process vent or transfer operation determined to have a mass emission rate of halogen
atoms contained in organic compounds of 0.45 kilograms per hour or greater. The
NSPS define a halogenated vent stream as one containing a total concentration of
halogen compounds of 20 ppmv or greater.
The TRE equatiohs and coefficients are different for the HON and the NSPS. The
coefficients in the NSPS are selected based on the flow rate, heat content, and halogen
status of the vent stream. The coefficients in the HON are based on the halogen status
of the vent stream and whether the facility is new or existing. The NSPS have separate
equations for incinerators and flares. The TRE equations and coefficients for the air
oxidation NSPS are located in 40 CFR §60.614(e), and the TRE equations and
coefficients for the distillation and reactors NSPS are located in 40 CFR §60.664(e), and
§60.704, respectively.
The NSPS do not use the terms Group 1 and Group 2. However, the NSPS have
similar applicability criteria to HON, because they only require control of streams with
TRE index values less than or equal to 1.0. The distillation NSPS has a low flow cutoff.
The reactors NSPS includes low flow and low concentration cutoffs.
Control Techniques
In the NSPS, a scrubber is not required downstream of an incinerator that is used to
combust halogenated vent streams (the NSPS only apply to VOC).
p|Sjl35/aoDenoix.b
9/26/94 B-1
-------
The NSPS do not prohibit the use of flares for control of halogenated vent streams.
There are no emissions averaging provisions in the NSPS.
Performance Testing
Monitoring
The HON allows methods other than Method 18 to determine the concentration in the
vent stream when complying with the 98 percent reduction or 20 ppmv outlet
concentration requirements, or for purposes of calculating the TRE index value as long
as the method has been validated by Method 301. The NSPS only specify Method 18.
The distillation and air oxidation NSPS require Method 3 for measurement of percent
oxygen when determining compliance with the 20 ppmv concentration limit. The
reactors NSPS and the HON specify Method 3B.
The HON and the reactors NSPS do not require an initial performance test for boilers or
process heaters when the vent stream is introduced with the primary fuel or for
permitted hazardous waste boilers. The distillation and air oxidation NSPS do not
contain these exclusions.
The NSPS do not allow the determination of TRE index value parameters by engineering
assessment. The HON provisions allow the determination of TRE index value
parameters by engineering assessment if the TRE index value is greater than 4.0.
There are no initial tests required for scrubbers in the NSPS, because there are no
scrubber provisions in the NSPS.
The distillation and reactors NSPS require a performance test for all process vents with a
TRE index value less than or equal to 8.0. The air oxidation NSPS and the HON require
a test for all process vents with a TRE index value less than or equal to 4.0.
The distillation and air oxidation NSPS do not exempt boilers or process heaters where
the vent stream is introduced with the primary fuel from the monitoring requirements.
The HON and the reactors NSPS contain these exemptions. The HON also exempts
permitted hazardous waste boilers from monitoring, unlike the NSPS.
The distillation and air oxidation NSPS require monitoring of operation for boilers or
process heaters with design heat input capacities of 44 megawatts or greater. The HON
and the reactors NSPS do not require any monitoring of such boilers.
The distillation and reactors NSPS require monitoring for all process vent streams with a
TRE index value less than or equal to 8.0. The air oxidation NSPS, like the HON,
requires monitoring for all process vent streams with a TRE index value less than or
equal to 4.0.
P|sp35/appendix.t>
9/26/94
B-2
-------
Recordkeeping and Reporting of Monitored Parameters
1 The NSPS require semiannual reporting of monitored parameters that are outside the
established range, but the out-of-range periods described in these reports are not
considered violations. The facility may be required to repeat the performance test, and if
the test shows that the facility is no longer in compliance, enforcement action could be
taken. However, violations and penalties cannot be invoked based soley on monitored
parameters, being out of the established range. In contrast, the HON provisions specify
that if parameters are out of range for a longer period of time than the excused
excursion period, this is a direct violation of the permit operating requirements and
enforcement actions can be taken.
The NSPS require three hour averaging periods for records and reports of monitored
data. The HON requires daily averaging periods (24 hour).
The NSPS require performance tests to establish ranges of monitored parameters. The
NSPS specifically define exceedances of monitored parameters which include limits
above and/or below the performance test value of the parameter. For example, an
exceedance for incinerators includes all 3 hour periods of operation during which the
average combustion temperature was more than 28 °C below the value measured
during the performance test. In contrast, the HON does not contain specific definitions
of acceptable ranges or exceedances. The HON requires sources to establish site
specific ranges based on testing supplemented by engineering analyses.
The distillation and air oxidation NSPS require records of operation for boilers or
process heaters with design heat input capacities of 44 megawatts or greater to be kept.
These records may include steam use, fuel use, or data monitored to comply with
another regulation. For the distillation and air oxidation NSPS, all periods when a boiler
or process heater is not in operation must be reported in the semiannual report.
The initial semiannual report is due within 6 months of the initial start-up date in order to
comply with the NSPS. The HON requires the first semiannual report to be submitted
. no later than 8 months after the compliance date.
. The NSPS require that all records of monitored data be kept for 2 years. The HON
requires that records be kept for 5 years.
Recordkeepinq and Reporting - Initial Reports and Notifications
The HON requires an Implementation Plan to report the compliance option that will be
used and a Notification of Compliance Status to report the results of the initial
performance test. The NSPS require a notification of initial start-up and an initial
performance test report.
The NSPS require the results of the performance test to be submitted within 60 days of
achieving the maximum production rate, but no later than 180 days after start-up. The
HON requires the Notification of Compliance Status, which includes the results of the
performance test, to be submitted 150 days after the source's compliance date.
pjsj135/apoenaix.B
9/26/94 B-3
-------
The NSPS require notification of the Administrator no later than 30 days after an affected
facility is constructed or reconstructed. The Administrator must also be notified no later
than 30 days prior to the initial start-up and no later than 15 days after the actual start-
up of an affected facility. The HON (§63.151 of Subpart G) requires an initial notification
which is due 120 days after the date of promulgation for existing sources. For new
sources, the initial notification is due as soon as practicable before commencement of
construction or reconstruction, or 90 days after promulgation, whichever is later.
Additional notification requirements for new sources subject to the HON (such as
applications for approval of construction or reconstruction and notifications of start-up)
are contained in the NESHAP General Provisions (40 CFR 63, Subpart A).
The distillation NSPS requires an initial report of the design production capacity of the
process unit. The reactors NSPS requires a design capacity report for process units
that are exempt from control requirements because they are below the 1 Gg/year
capacity cutoff.
When making a process change, the NSPS require a report of the compliance option to
be used 90 days before the change is made if the compliance option will change.
When making a process change, the NSPS require a performance test to be done within
180 days of the change.
pjsjl 35/appendix.b
9/26/94 B-4
-------
APPENDIX C - EXAMPLE CALCULATION OF TRE INDEX VALUE
This Appendix summarizes the steps for calculating the TRE index value for a process vent stream
and presents an example TRE index value calculation. Detailed requirements for calculating the TRE
index value for a process vent stream are presented in §63.115(d) in Subpart G of the proposed HON
rule.
The equation for calculating the TRE index value for a vent stream controlled by a flare or
incinerator is as follows:
TRE = _J_ [a + b (Qs) + c (HT) + d (ETOC)] (1)
where:
TRE = TRE index value.
EHAP = Hourly emission rate of total organic HAP (kilogram per hour).
05 = Vent stream flow rate (standard cubic meters per minute) at a standard
temperature of 20 °C.
HT = Vent stream net heating value (megaJoules per standard cubic meter).
ETOC = Hourly emission rate of TOC (kilograms per hour minus methane and ethane).
a.b.c.d = Coefficients for existing and new source process vents presented in Tables 1
and 2.
Engineering assessment may be used to determine the total organic HAP emission rate, the
volumetric flow rate, the net heating value, and the TOC emission rate for the representative operating
condition expected to yield the lowest TRE index value. Engineering assessment includes, but is not
limited to:
Previous test results;
Bench-scale or pilot-scale test data;
Permit values; and
Design analysis.
If the calculated TRE index value is greater than 4.0, the owner or operator is not required to
perform any measurements. If the calculated TRE index value is less than or equal to 4.0,
Pjsj135/appendii>.c
9/26/94 C-1
-------
Vtl u
SI
TABLE 1. COEFFICIENTS FOR TOTAL RESOURCE EFFECTIVENESS FOR EXISTING SOURCE
NONHALOGENATED AND HALOGENATED VENT STREAMS
Values of Coefficients
Type of Stream
Nonhalogenated
Halogenated
Control Device Basis
Rare
Thermal Incinerator
0 Percent Heat Recovery
Thermal Incinerator
70 Percent Heat Recovery
Thermal Incinerator and Scrubber
a
1.935
1.492
2.519
3.995
b
3.660 x 10- 1
6.267 x 10'2
1.183x ID'2
5.200 x 10-2
c
-7.687 x 10"3
3.177 x 10'2
1.300x 10'2
-1.769x 10'3
d
-7.333 x 10"4
-1.159x 10'3
4.790 x 10'2
9.700 x 10"4
TABLE 2. COEFFICIENTS FOR TOTAL RESOURCE EFFECTIVENESS FOR NEW SOURCE
NONHALOGENATED AND HALOGENATED VENT STREAMS
O
to
Values of Coefficients
Type of Stream
Nonhalogenated
Halogenated
Control Device Basis
Rare
Thermal Incinerator
0 Percent Heat Recovery
Thermal Incinerator
70 Percent Heat Recovery
Thermal Incinerator and Scrubber
a
0.5276
0.4068
0.6868
1.0895
b
0.0998
0.0171
3.209 x 10'3
1.417x 10-2
C
-2.096 X 10-3
8.664 x lO^3
3.546 x ID"3
-4.822 x 10"4
d
-2.000 x lO^4
-3.162X 10"4
1.306X10'2
2.645 x lO^4
-------
measurements and/or further calculations of the volumetric flow rate, the net heating value, and the TOC
and total organic HAP emission rates must be performed. The volumetric flow rate shall be determined
using Method 2, 2A.2C, or 2D. The molar composition, which is used to calculate net heating value,
shall be determined using the following methods:
Method 18 to measure the concentration of each organic compound;
ASTM Method D 1946-77 to measure the carbon monoxide and hydrogen concentration; and
Method 4 to determine the water vapor content.
The net heating value shall be calculated using the following equation:
q HJ (i - BWS)
(2)
H
where:
HT
Bws
Cj
Hj
Net heating value of the sample (megaJoule per standard cubic meter).
Constant, 1.740 x 10~7 (parts per million)-! (gram-mole per standard cubic meter)
(megaJoule per kilocalorie).
Water vapor content of the vent stream, proportion by volume.
Concentration on a dry basis of all organic compounds j (parts per million).
Net heat of combustion of compound j (kilocalorie per gram-mole).
The emission rate of TOC and the emission rate of total organic HAP shall both be calculated using the
following equation:
= K
Cj M|
Qs
(3)
where:
E
K2
q
Mj
Emission rate of TOC or total organic HAP In the sample (kilograms per hour).
Constant, 2.494 x 10"6 (parts per million)'1 (gram-mole per standard cubic meter)
(kilogram/gram) (minutes/hour).
Concentration on a dry basis of organic compound j (parts per million).
Molecular weight of organic compound j (gram/gram-mole).
Pis|135/aopendix.c
9/26/94
C-3
-------
Os = Vent stream flow rate (dry standard cubic meter per minute) at a temperature of
20 °C.
For nonhalogenated vent steams, the TRE index value must be calculated using the coefficients
for a flare, a thermal incinerator with zero percent heat recovery, and a thermal incinerator with
70 percent heat recovery. The lowest TRE index value must be selected. For halogenated vent streams,
the TRE index value must be calculated using the coefficients for a thermal incinerator with zero percent
heat recovery followed by a scrubber.
Example
Existing source.
Process knowledge was used to determine that the vent stream is nonhalogenated.
Engineering assessment was used to determine that flow rate = 1.66 scmm.
The process vent stream contains xylene as the only organic compound.
The TOC and HAP emission rates are determined using equation 3 as follows:
The molecular weight of xylene = 106 g/gmd.
Engineering assessment was used to determine that the TOC concentration in the vent
stream is 3000 ppm and, because xylene is a HAP, the HAP concentration is also
3000 ppm.
Ejoc (kg/hr) = (2.494 x 10"6) (3000) (106) (1.66)
1.32kg/hr
EHAP (kg/hr) = (2.494 x 10-6) (3000) (106) (1.66)
1.32 kg/hr
The heating value is calculated using equation 2 as follows:
The net heat of combustion of xylene is 666.2 kcal/gmol.
The water vapor content of the vent stream is 1 percent by volume (assumed).
The total organic compound concentration is used (3000 ppm).
pjsj135/aDoendix.c
9/26/94 C-4
-------
HT (MJ/scm) = (1.740 x 1CT7) [(3000) (666.2)] (1 - 0.01)
1 = 0.344 MJ/scm
The TRE index value calculation must be performed using equation 1 and the coefficients for
existing, nonhalogenated vent streams presented in Table 1 for a flare, a thermal incinerator with zero
percent heat recovery, and a thermal incinerator with 70 percent heat recovery.
Flare Calculation:
TRE = [1.935 + 0.3660 (1.66) - 0.007687 (0.344) - 0.0007333 (1.32) ]
1'32 (5)
= 1.92
Similar calculations done for thermal incinerators with zero percent and 70 percent heat recovery yield
the following results:
Zero percent heat recovery, TRE = 1.22
Seventy percent heat recovery, TRE = 1.97
Therefore, the TRE index value = 1.22 (The lowest of the three values must be selected.)
Since the TRE index value is less than 4.0, tests must be performed to determine the volumetric
flow rate and the molar composition, including the concentration of each organic compound, the
concentration of carbon monoxide and hydrogen, and the water vapor content.
p|S|135/ODpendix.c
9/26/94 C-5
-------
APPENDIX D - LOGIC FLOW DIAGRAMS FOR WASTEWATER PROVISIONS
i
This appendix contains the logic flow diagrams for wastewater referred to in §63.131 of
Subpart G of the HON. These diagrams were included in the rule to provide guidance on the
Interrelationship of the wastewater provisions. The following figures are included:
Figure
Number3
1
2
3
. 4
Figure Name
Overview of HON Wastewater Provisions
HON Wastewater Determination
Designation of Group 1 Wastewater Streams
Group 1 and Group 2 Determinations for Wastewater
Streams - Table 8 HAP's
Page Number
D-2
D-3
D-4
D-5
Group 1 and Group 2 Determinations for Wastewater D-6
Streams - Table 9 HAP's
6
7
8
9
10
Compliance Options for Control of Table 8 HAP's
Compliance Options for Control of Table 9 HAP's
Process Unit Alternative Compliance Option (for
existing sources only)
Biological Treatment Alternative Compliance Option (for
new and existing sources)
Compliance Options for Control of Residuals
D-7
D-8
D-9
D-10
D-11
a Figure numbers are identical to those in Subpart G of the HON.
p|s|135/appendbcO
9/27/94 D-1
-------
Not
Subject to
Wastewater
Provisions
HON Wastewater?
(Figure 2)
Yes ^ New Source? \ No
(§63.100(k)and(l))
(Figure 3 or 4)
Group 1
for Table 9
HAP's?
(Figure 3 or 5)
Group 2
Wastewater
Stream
Control
(Figures 6 or 9 & 10)
Control
(Figures?, 8, or9 & 10)
Figure 1. Overview of HON Wastewater Provisions
D-2
-------
CMPU
subject to the HON
§63.100(b)
Storm water
in Segregated
Sewer? or Spill? or Safety
Shower Water? or Water from
Fire-fighting and Deluge Systems in
Segregated Sewers?
§63.100(0)
Not
Subject to
Wastewater
Provisions
VOHAP
Concentration
,000 ppmw&
Flow Rate <0.02 ipm?
(§63.101)
Not
Subject to
Wastewater
Provisions
VOHAP
Concentration
<5 ppmw?
(§63.101)
Not
Subject to
Wastewater
Provisions
i
T
HON Wastewater
(§63.101)
CMPU = Chemical Manufacturing Process Unit
Figure 2. HON Wastewater Determination
D-3
-------
Designate
Wastewater Stream
as a Group 1 Wastewater Stream
for Table 8 and/or
Jable 9 HAP's?
Yes
Emissions
Must be Controlled in
Accordance with §§63.133-137 fronrT
Point of Generation to Point Where Wastewater"
Stream or Mixture of Wastewater Streams
is Designated as Group 1
Wastewater
(§63.144(d))
Group 1 Wastewater Stream for Table 8 and/or Table 9
HAP's Requires Treatment for Table 8 and/or Table 9 HAP's.
Go to Figures 6 or 9 and/or Figures 7, 8, or 9.
Figure 3. Designation of Group 1 Wastewater Streams
(Refer to §§63.132(c) and 63.144(d))
D-4
-------
Determine the VOHAP concentration
and flow rate either (1) at the point of generation
or (2) downstream of the point of generation.
Determine VOHAP Concentration
and Row Rat* (§63.132(c))
Group 2
for Table 8
HAFs. Go
to Rgure 5
Flowrate 20.02 Ipm ^\ No
and VOHAP Concentration of any
Table 8 HAP alOppmw?
(§63.132(c)(1))
Group 1 Wastewater Stream:
for Table 6 HAP's:
Requires Treatment for Table 8 HAP's
Go to Rgure 6 or 9
Figure 4. Group 1 and Group 2 Determinations for Wastewater
Streams - Table 8 HAP's (Refer to §§63.132(d) and 63.138(b))
D-5
-------
Determine the VOHAP concentration
and flow rate either (1) at the point of generation
or (2) downstream of the point of generation.
Determine Concentration
and Row Rate
(§63.132(f))
Total
VOHAP Concentration
£10,000 ppmw?
Beet
1 Mg/yr Source -
Wide Exemption?
(§63.138(c)
(5) or (6))
Group 1
Wastewater
Stream
Goto
Figure 6
Total
VOHAP
Concentration
21000 ppmw and Row
Rate a 10.1pm?
Group 2
Wastewater
Stream
Group 2
Wastewater
Stream
Figure 5. Group 1 and Group 2 Determinations for Wastewater
Streams - Table 9 HAP's (Refer to §§63.132(f) and 63.138(c))
D-6
-------
Control Air Emissions Before
and During Treatment/Recycle
Combined
Group 1 Wastewater
''Streams; Combined Group
Group 2 Wastewater,
Streams?
Yes
For Group 1 Wastewater Streams:
1. Recycle to Process
or
Z. Use Design Steam Stripper
or
3. Reduce HAP Mass by 99%
or
4. Reduce VOHAP Concentration of Each
HAPto <10ppmw (Note: This option
is not available for designated Group 1
wastewater streams or for biological
treatment)
or
5. Treat to Achieve Required HAP
Mass Removal (§63.145(h))
For Combined Group 1 Wastewater Streams
or Group 1/Group 2 Wastewater Streams:
1. Recycle to Process
or
2. Use Design Steam Stripper
or
3. Reduce HAP Mass by 99%
or
4. Treat to Achieve Required HAP
Mass Removal (§63.145(h))
/ Treat Residuals
/ (Figure 10)
! Determine K Group 1
\ for Table 0 HAP's
Figure 6. Compliance Options for Control of Table 8 HAP's
(Refer to §63.138(b))
&
D-7
-------
Control Air Emissions Before
and During Treatment/Recycle
Combined
Group 1 Wastewater
Streams? Combined
Group 1 & Group 2
Wastewater
Streams?
For Group 1 Wastewater Streams:
1. Recycle to Process
or
2. Use Design Steam Stripper
or
3. Reduce HAP Mass by Percentages
Specified in Table 9
or
4. Reduce Total VOHAP Concentration
to <50 ppmw (Note: This option is
not available for designated Group 1
wastewater streams or for biological
treatment)
or
5. Reduce HAP Mass by 99%
or
4. Treat to Achieve Required HAP Mass
Removal (§63.145(h))
For Combined Group 1 Wastewater Streams
or Group 1/Group 2 Wastewater Streams:
1. Recycle to Process
or
2. Use Design Steam Stripper
or
3. Reduce HAP Mass by Percentages
Specified in Table 9
or
4. Treat to Achieve Required HAP Mass
Removal (§63.145(h))
or
5. Reduce HAP Mass by 99%
Figure 7. Compliance Options for Control of Table 9 HAP's
(Refer to §63.138(c))
D-8
-------
Note: Non-process wastewater streams and
wastewater streams from other chemical
manufacturing process units cannot be
combined when using this option. This
option may not be used for designated
Group 1 wastewater streams.
Control Air Emissions Before
and During Treatment/Recycle
All Process Wastewater Streams
from a Process Unit Must Comply
with these Provisions if this
Option is Selected
For All Wastewater Streams:
1. Recycle to the Process
or
2. Reduce Total VOHAP Concentration
to <10 ppmw before Being
Discharged or Combined with
Wastewater Streams from Other
Process Units
Treat
Residuals
, (Figure 10);
Figure 8. Process Unit Alternative Compliance Option
(for existing sources only)
(Referto§63.138(d))
D-9
-------
For control of Table 8 and Table 9 HAP's:
Control Air Emissions Before
and During Treatment/Recycle
\
i
For All Wastewater Treated
in a Biological Treatment Unit:
Achieve 95%
Biodegradation (§63.145(1))
Treat
/ Residuals
\(Figure
Figure 9. Biological Treatment Alternative Compliance Option
(for new and existing sources)
(Refer to §63.138(e))
D-10
-------
Control Air Emissions Before
and During Treatment/Recycle
For All Residuals:
1.
Recycle to Process or Sell
for the Purpose of Recycling
or
Return to Treatment Process
or
3. Destroy Total HAP Mass by 99%
2.
Figure 10. Compliance Options for Control of Residuals
(Referto§63.138(h))
D-11
-------
APPENDIX E - INFORMATION ON WASTEWATER TO BE SUBMITTED WITH IMPLEMENTATION
PLANS
This appendix contains copies of 2 tables (Tables 14a and 14b) from Subpart G of the HON.
The tables specify the information that must be submitted with the Implementation Plan.
Table
Number
E-1
Table Name
Information on Table 8 Organic HAP's to be Submitted
Page Number
E-2
with Implementation Plan for Process Units at New
Sources
E-2 Information on Table 9 Organic HAP's to be Submitted E-3
with Implementation Plan for Process Units at New and
Existing Sources
P|S)135/«poendix.e
9/26/94 E-1
-------
TABLE E-1. INFORMATION ON TABLE 8 ORGANIC HAP's TO BE SUBMITTED WITH IMPLEMENTATION PLAN FOR PROCESS UNITS AT
NEW SOURCESa-b
Process Unit Stream VOHAP Concentration Flow Rate Group 1 or
Identification0 Identification (ppmw)d-e (Iprn) e-f Group 2Q
Average
Intend to
Control?"
(YorN)
Intended
Treatment
Technology'
Intended
Control
Device
m
a The information specified In this table must be submitted; however, It may be submitted in any format. This table presents an example format.
b Other requirements for the Implementation Plan are specified In §63.151 of Subpart G.
c Also include a description of the chemical manufacturing process unit (e.g., storage tank).
d Except when §63.132(c) Is used, annual average VOHAP concentrations, at point of generation, of each HAP compound listed In table 8 of
Subpart G that Is present In the wastewater stream, parts per million by weight (ppmw).
e If §63.132(c) Is used, Include annual average VOHAP concentration and flow rate for the point where Group 1 streams are designated.
' Except when §63.132(c) is used, annual average flow rate at point of generation, liters per minute (Ipm).
9 Is the stream Group 1 or Group 2 for table 8 compounds as determined by the procedures specified In §63.132(c) and (d) of Subpart G?
n Does the owner or operator Intend to control the stream in accordance with the requirements specified In §63.138(b) of Subpart G, yes (Y) or
no (N)?
' If the owner or operator intends to control the stream, what is the intended treatment technology (e.g., steam stripping, biological treatment,
etc.)?
-------
TABLE E-2. INFORMATION ON TABLE 9 ORGANIC HAP's TO BE SUBMITTED WITH IMPLEMENTATION PLAN FOR PROCESS UNITS AT
NEW AND EXISTING SOURCES3-13
Chemical
Manufacturing
Process Unit
Identification0
Stream
Identification
Total VOHAP
Concentration
Average
Flow Rate
(lpm)e-f
Group 1 or
Group 29
Intend to
Control
(YorN)
Intended
Treatment
Technology'
Intended Control
Device
m
a The information specified In this table must be submitted; however, it may be submitted in any format. This table presents an example format.
b Other requirements for the Implementation Plan are specified In §63.151 of Subpart G.
c Also include a description of the process unit (e.g., storage tank).
d Except when §63.132(c) is used, annual average total VOHAP concentration and expected range of total VOHAP in wastewater stream at point
of generation, parts per million by weight (ppmw).
e If §63.132(c) is used, Include annual average VOHAP concentration and flow rate for the point where Group 1 streams are designated.
' Except when §63.132(c) Is used, annual average flow rate at point of generation, liters per minute (Ipm).
9 Is the stream Group 1 or Group 2 for table 9 compounds as determined by the procedures specified In §63.132(c) or (g) of Subpart G?
h Does the owner or operator intend to control the stream in accordance with the requirements of §63.138(c) or (d) of Subpart G, yes (Y) or no
(N)?
' If the owner or operator Intends to control the stream, what Is the intended treatment technology (e.g., steam stripping, biological treatment,
etc.)?
-------
APPENDIX F - INFORMATION ON WASTEWATER TO BE SUBMITTED WITH NOTIFICATION OF
COMPLIANCE STATUS
This appendix contains copies of 6 tables (Tables 15a, 15b, 16, 17, 18, and 19) from Subpart G
of the HON. The tables specify the information that must be submitted with the Notification of
Compliance Status.
Table
Number
Table Name
Page Number
F-1 Information on Table 8 Organic HAP's to be Submitted
with Notification of Compliance Status for Process
Units at New Sources
F-2 Information on Table 9 Organic HAP's to be Submitted
with Notification of Compliance Status for Process
Units at New and Existing Sources
F-3 Information to be Submitted with Notification of
Compliance Status for Process Units at Existing
Sources Complying with Process Unit Alternative in
§63.138(d)
F-2
F-4
F-5
F-4
F-5
F-6
Information for Treatment Processes to be Submitted
with Notification of Compliance Status
Information for Waste Management Units to be
Submitted with Notification of Compliance Status
Information on Residuals to be Submitted with
Notification of Compliance Status
F-6
F-7
F-8
p|5|135/appenOix.l
9/26/94
F-1
-------
TABLE F-1. INFORMATION ON TABLE 8 ORGANIC HAP's TO BE SUBMITTED WITH NOTIFICATION OF COMPLIANCE STATUS FOR
PROCESS UNITS AT NEW SOURCES3-13
Process Unit
Identification
Code0
Stream
Identification
Code
VOHAP
Concentration
Average
Flow Rate Group 1 or
(lpm)e-f Group 29
Compliance
Approach"
Treatment
Process(es)
Identification
Code'
Waste
Management
Unit(s)
Identification!
Intended
Control
Device
Tl
ro
a The information specified in this table must be submitted; however, it may be submitted in any format. This table presents an example format.
b Other requirements for the Notification of Compliance Status are specified in §63.152(b) of Subpart G.
c Also include a description of the process unit (e.g., storage tank).
d Except when §63.132(c) Is used, annual average VOHAP concentrations, at point of generation, of each HAP compound listed in table 8 of
Subpart G that is present In the wastewater stream, parts per million by weight (ppmw).
e When §63.132(c) is used, include the annual average VOHAP concentration and flow rate for the point where the Group 1 stream is
designated.
' Except when §63.132(c) Is used, annual average flow rate at point of generation, liters per minute (Ipm).
9 Is the stream Group 1 or Group 2 for table 8 compounds as determined by the procedures specified In §63.132(c) or (d) of Subpart G?
n If stream Is being controlled In accordance with the requirements of §63.138(b), identify the subparagraph in §63.138(b) with which the owner
or operator has elected to comply. For example, if the owner or operator elects to recycle the stream to a production process, the appropriate
subparagraph Is §63.138(b)(1)(l).
-------
TABLE F-1. INFORMATION ON TABLE 8 ORGANIC HAP's TO BE SUBMITTED WITH NOTIFICATION OF COMPLIANCE STATUS FOR
PROCESS UNITS AT NEW SOURCES.a-b continued
' If the stream Is being treated in accordance with the requirements of §63.138(b), give identification code of treatment unit(s) treating stream.
Identification codes should correspond to entries in Table F-4.
i For each Group 1 wastewater stream, Identify the waste management unit(s) receiving or managing the stream. Identification codes should
correspond to entries In Table F-5.
-------
TABLE F-2. INFORMATION ON TABLE 9 ORGANIC HAP's TO BE SUBMITTED WITH NOTIFICATION OF COMPLIANCE STATUS FOR
PROCESS UNITS AT NEW AND EXISTING SOURCESa-b
«
Process Unit Stream Total VOHAP Flow Rate Group 1 or Compliance Treatment Waste Intended
Identification0 Identification Concentration(ppmw)^e (Ipm)6-' Group 29 Approach" Process Management Unit Control
Identification' Identification! Device
Average
a The information specified in this table must be submitted; however, it may be submitted in any format. This table presents an example format.
b Other requirements for the Notification of Compliance Status are specified in §63.l52(b) of Subpart G.
c Also include a description of the process unit (e.g., storage tank).
d Except when §63.132(c) is used, annual average total VOHAP concentration and expected range of total VOHAP concentration In wastewater
stream at point of generation, parts per million by weight (ppmw).
e When §63.132(c) is used, Include the annual average VOHAP concentration and flow rate for the point where the Group 1 stream is
designated.
f Except when §63.132(c) Is used, annual average flow rate at point of generation, liters per minute (Ipm).
9 Is the stream Group 1 or Group 2 for table 9 HAPs as determined by the procedures specified in §63.132(c) or (g)?
h If the stream is being controlled in accordance with the requirements of §63.138(c), identify the subparagraph In §63.138(c) with which the
owner or operator has elected to comply. For example, if the owner or operator elects to reduce the total VOHAP mass flow rate of an
individual stream by 99 percent, the appropriate subparagraph Is §63.138(c)(1)(ii)(B).
' If stream is being treated In accordance with §63.138(c), give Identification code of treatment unit(s) treating stream. Identification codes should
correspond to entries in Table F-4.
i For each Group 1 wastewater stream, identify the waste management unit(s) receiving or managing the stream. Identification codes should
correspond to entries In Table F-5.
-------
TABLE F-3. INFORMATION TO BE SUBMITTED WITH NOTIFICATION OF COMPLIANCE STATUS FOR PROCESS UNITS AT EXISTING
SOURCES COMPLYING WITH PROCESS UNIT ALTERNATIVE IN §63.138(d)a-b.c
«
Process Unit Stream Identification Total VOHAP Concentration6 Flowf Rate Treatment Waste Management Unit
Identification^ (ppmw) (Ipm) Process Identification"
IdentfficationQ
Average
a The information specified In this table shall be provided for each wastewater stream generated by the process unit to which this alternative
provision is being applied.
D The information specified In this table must be submitted; however, it may be submitted In any format. This table presents an example format.
71 c Other requirements for the Notification of Compliance Status are specified in §63.152(b) of Subpart G.
tn
d Also Include a description of the process unit (e.g., storage tank).
6 Flow-weighted annual average and expected range of total VOHAP concentration of individual or combined stream before exposure to the
atmosphere and before combination with streams other than process wastewater from the specific process unit, parts per million by weight
(ppmw).
' Annual average flow rate of combined or individual wastewater stream, liters per minute (Ipm).
9 If stream Is being controlled, give Identification code(s) of treatment unit(s) treating stream. Identification codes should correspond to entries
in Table F-4.
n For each wastewater stream generated within the process unit, Identify the waste management unit(s) receiving or managing the stream.
Identification codes should correspond to entries In Table F-5.
-------
TABLE F-4. INFORMATION FOR TREATMENT PROCESSES TO BE SUBMITTED WITH NOTIFICATION OF COMPLIANCE STATUS3-0
Treatment Process Identification0 Description0" Wastewater Stream(s) Treated6 Monitoring Parameters'
a The information specified In this table must be submitted; however, it may be submitted in any format. This table presents an example format.
b Other requirements for the Notification of Compliance Status are specified In §63.152(b) of Subpart G.
-n c identification codes should correspond to those listed in Tables E-1, E-2, and F-1 through F-3.
O)
d Description of treatment process.
e Stream identification code for each wastewater stream treated by each treatment unit. Identification codes should correspond to entries listed
in Tables E-1. E-2, and F-1 through F-3.
f
Parameter(s) to be monitored or measured In accordance with Table 8-9 of Section 8.3.5.
-------
TABLE F-5. INFORMATION FOR WASTE MANAGEMENT UNITS TO BE SUBMITTED WITH NOTIFICATION OF COMPUANCE STATUSa-b
D
5
U> " " " " rn«-ri-r--r W
3 Waste Management Unit Identification0 Description1* Wastewater Stream(s) Received or Managed6
a The information specified In this table must be submitted; however, it may be submitted in any format. This table presents an example format.
b Other requirements for the Notification of Compliance Status are specified in §63.152(b) of Subpart G.
71 c Identification codes should correspond to those listed In Tables E-1, E-2, and F-1 through F-3.
d Description of waste management unit.
6 Stream identification code for each wastewater stream received or managed by each waste management unit. Identification codes should
correspond to entries listed in Tables E-1, E-2, and F-1 through F-3.
-------
TABLE F-6. INFORMATION ON RESIDUALS TO BE SUBMITTED WITH NOTIFICATION OF COMPLIANCE STATUSa.b
«
Residual Residual Wastewater Stream Treatment Fate9 Control Device Control Device Control Device
Identification0 Descrlptiond Identification6 Process* Identification Code Description0 Efficiency'
a The information specified In this table must be submitted; however, It may be submitted in any format. This table presents an example format.
D Other requirements for the Notification of Compliance Status are specified In §63.152(b) of Subpart G.
71
00 c Name or identification code of residual removed from Group 1 wastewater stream.
d Description of residual (e.g., steam stripper A-13 overhead condensates).
6 Identification of stream from which residual is removed.
f Treatment process from which residual originates.
9 Indicate whether residual Is sold, returned to production process, or returned to waste management unit or treatment process; or whether HAP
mass of residual is destroyed by 99 percent.
h If the fate of the residual Is such that the HAP mass is destroyed by 99 percent, give description of device used for HAP destruction.
1 If the fate of the residual is such that the HAP mass is destroyed by 99 percent, provide an estimate of control device efficiency and attach
substantiation in accordance with §63.146(b)(9) of Subpart G.
-------
APPENDIX G - COMPLIANCE CHECKLISTS
Appendix G is a collection of forms that the inspector can use to conduct a compliance
inspection. These forms are identical to those in chapters 5 through 8. They are reproduced here so
that they can be copied as needed for numerous inspections. Included in the appendix are the following
forms:
Table
Number
5-6
64
7-4
8-12
8-13
8-14
8-15
8-16
8-17
Table Name
Compliance Checklist for Process Vent Systems
Compliance Checklist for Transfer Operations
Compliance Checklist for Storage Vessels
Compliance Checklist for Waste Management Units
Compliance Checklist for Treatment Processes
Compliance Checklist for Control Equipment Requiring
Leak Detection
Compliance Checklist for Wastewater Control Devices
Compliance Checklist for Heat Exchange Systems
Requiring Leak Detection
Compliance Checklist for Maintenance Wastewater
Management
Page Number
G-2
G-13
G-27
G-45
G-65
G-69
G-72
G-81
G-83
p|sJ135/ap0endlx.g
9/27/94
G-1
-------
TABLE 5-6. COMPLIANCE CHECKLIST FOR PROCESS VENT SYSTEMS
Complete this form for process vent systems. A "yes* response to all questions will indicate full
compliance and, "no" response will indicate noncompliance with the standard except where noted.
CONTROL OR RECOVERY DEVICE .
DATE OF STARTUP
REVIEW OF RECORDS
IF THE CONTROL DEVICE IS A FLARE
1. Results of the initial test were submitted in the NCS.a Y a N a
2. The presence of a continuous flare pilot flame is monitored YD N D
using a device designed to detect the presence of a flame.
3. All periods when all pilot flames to a flare were absent or the Y a N a
monitor was not operating have been recorded and
reported in the PR.b
IF THE CONTROL DEVICE IS A THERMAL INCINERATOR
1. Results of the initial performance test were submitted in the YD No
NCS.a
2. Test documentation demonstrates 98 percent HAP orTOC YD N o
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
3. A temperature monitoring device equipped with a YD No
continuous recorder is used to measure the temperature of
the gas stream in the firebox (or in the ductwork
immediately downstream of the firebox before any
substantial heat exchange occurs).
4. Documentation to establish a site-specific range for firebox YD N o
temperature was submitted in the NCSa or operating permit
application.
5. Continuous records0 of firebox temperature are kept YD N D
6. Records of daily average firebox temperature are kept YD N D
7. All daily average firebox temperatures that are outside the YD N D
site-specific established range and all operating days when
insufficient monitoring data are collected are reported in the
PR.b
(continued)
pjsj135Aable-5.06 G-2
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
8. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.0*
9. If the firebox temperature is not monitored, the facility has YD N D
documentation that they applied for and received approval
to monitor an alternative parameter, and are performing the
required recordkeeping and reporting.
[Note: If #9 is checked "Yes*, the facility Is In compliance
even if numbers 3 through 8 are checked "No".]
IF THE CONTROL DEVICE IS A CATALYTIC INCINERATOR
1. Results of the Initial performance test were submitted In the YD N D
NCS.a
2. Test documentation demonstrates 98 percent HAP orTOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
3. Temperature monitoring devices equipped with continuous YD N D
recorders are used to measure the temperature in the gas
stream immediately before and after the catalyst bed.
4. Documentation to establish a site-specific range for the gas YD N D
stream temperature upstream of the catalyst bed and the
temperature difference across the bed was submitted in the
NCSa or operating permit application.
5. Continuous records0 are kept of the temperature of the gas YD N D
stream upstream of the catalyst bed and the temperature
difference across the catalyst bed.
6. Records of the daily average temperature upstream of the YD N D
catalyst bed and the temperature difference across the
catalyst bed are kept
7. All daily average upstream temperatures that are outside the YD N D
site-specific range and all operating days when insufficient
monitoring data are collected are reported In the PR.b
8. All daily average temperature differences across the catalyst YD N D
bed that are outside the site-specific range and all operating
days when insufficient monitoring data are collected are
reported in the PR.D
9. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.d
(continued)
pjs|135/l»t>le-5.06 G-3
-------
TABLE 5-6. COMPUANCE CHECKLIST FOR PROCESS VENT SYSTEMS
10. If the temperature upstream of the catalyst bed and/or the YD ND
temperature differential across the catalyst bed are not
monitored, the facility has documentation that they applied
for and received approval to monitor an alternative
parameter, and are performing the required recordkeeping
and reporting.
[Note: If #10 is checked "Yes", the facility is in compliance
even if numbers 3 through 9 are checked "No".]
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER
WTTH A DESIGN HEAT INPUT CAPACITY LESS THAN 44
MEGAWATTS AND THE VENT STREAM IS NOT INTRODUCED
WITH THE PRIMARY FUEL
1. Results of the initial performance test were submitted in the YD N D
NCS.a
2. A description of the location at which the vent stream is YD No
introduced into the boiler or process heater was submitted
in the NCS.a
3. The vent stream is introduced into the flame zone of the YD N D
boiler or process heater.
4. Test documentation demonstrates 98 percent HAP or TOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
5. A temperature monitoring device equipped with a YD N D
continuous monitor is used to measure the temperature of
the gas stream in the firebox.
6. Documentation to establish a site-specific range for firebox YD N D
temperature was submitted in the NCSa or operating permit
application.
7. Continuous records0 are kept of the firebox temperature. YD N D
8. Records of the daily average firebox temperature are kept. YD N D
9. All daily average firebox temperatures that are outside the YD N D
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
10. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.d
(continued)
p|sJ135/table-5.06 G-4
-------
TABLE 5-6. COMPLIANCE CHECKLIST FOR PROCESS VENT SYSTEMS
11. If the firebox temperature is not monitored, the facility has YD No
documentation that they applied for and received approval
to monitor an alternative parameter, and are performing the
required recordkeeping and reporting.
[Note: If #1 1 Is checked "Yes", the facility Is in compliance
even if numbers 5 through 10 are checked "No".]
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER
WITH A DESIGN HEAT INPUT CAPACITY GREATER THAN
44 MEGAWATTS
1 . A description of the location at which the vent stream is YD No
introduced into the boiler or process heater was submitted
in the NCS.a
2. The vent stream is introduced into the flame zone of the YD N D
boiler or process heater.
IF THE CONTROL DEVICE IS A SCRUBBER (FOLLOWING A
COMBUSTOR FOR A HALOGENATED VENT STREAM)
1 . Results of the initial performance test were submitted in the YD No
NCS.a
2. Either (1) Test documentation demonstrates 99 percent YD Nn
control efficiency for total halogens and hydrogen halides or
test documentation demonstrates that the outlet mass of
total hydrogen halides and halogens are less than 0.45
kilograms per hour, or, (2) if the scrubber was installed prior
to December 31, 1992, test documentation demonstrates
' 95 percent control efficiency for total halogens and
hydrogen halides or test documentation demonstrates that
the outlet mass of total hydrogen halides and halogens are
less than 0.45 kilograms per hour.
3. A pM monitoring device equipped with a continuous YD N D
recorder Is used to monitor the pH of the scrubber effluent.
4. A flow meter equipped with a continuous recorder is used to YD N D
measure the influent liquid flow and effluent vapor flow.
5. Documentation to establish a site-specific range for the pH, YD N D
and liquid/gas ratio was submitted in the NCSa or operating
permit.
(continued)
pjs|135AaOle-5.06 ' G-5
-------
TABLE 5-6. COMPLIANCE CHECKLIST FOR PROCESS VENT SYSTEMS
6.
7.
8.
9.
Continuous records0 of the pH of the scrubber effluent are
kept.
Continuous records0 of the scrubber liquid/gas ratio are
kept.
Records of the daily average pH and the daily average
liquid/gas ratio are kept.
All daily average pH values of the scrubber effluent that are
outside the site-specific range and all operating days when
Insufficient monitoring data are collected are reported in the
PR.b
YD
YD
YD
YD
No
No
.ND
No
10. All daily average scrubber liquid/gas ratios that are outside YD ND
the site-specific range and all operating days when
insufficient monitoring data are collected are reported in the
PR.b
11. The number of excursions does not exceed the number of YD No
excused excursions in the semi-annual reporting period.^
12. If the pH and/or the scrubber liquid to gas ratio are not YD ND
monitored, the facility has documentation that they applied
for and received approval to monitor an alternative
parameter, and are performing the required recordkeeping
and reporting.
[Note: If #12 is checked "Yes*, the facility Is in compliance
even if numbers 3 through 11 are checked "No".]
IF THE RECOVERY DEVICE IS A CARBON ADSORBER AND THE
TRE INDEX VALUE IS GREATER THAN 1.0 AND LESS THAN OR
EQUAL TO 4.0
1. Documentation of the initial TRE calculation including test YD ND
results was submitted in the NCS.a
2. An integrating regeneration stream (e.g., steam) flow YD N D
monitoring device having an accuracy of _+.10 percent and
capable of recording total regeneration stream mass flow for
each regeneration cycle is used to measure regeneration
stream flow.
(continued)
p|s)135/table-5.06 G-6
-------
TABLE 5-6. COMPLIANCE CHECKUST FOR PROCESS VENT SYSTEMS
3. A carbon bed temperature monitoring device capable of YD No
recording the carbon bed temperature after each
regeneration and within 15 minutes of completing any
cooling cycle is used to measure carbon bed regeneration
temperature.
4. Documentation to establish a site-specific range for the YD N D
regeneration stream flow and carbon bed regeneration
temperature was submitted in the NCSa or operating permit.
5. Records are kept of the total regeneration stream mass flow Y a N D
for each carbon bed regeneration cycle.
6. Records are kept of the temperature of the carbon bed after YD No
each carbon bed regeneration.
7. All regeneration cycles when the total regeneration stream Y a No
mass flow is outside the site-specific range are reported in
the PR.b
8. All regeneration cycles during which the temperature of the YD N D
carbon bed after regeneration is outside the site-specific
range are reported in the PR.*5
9. If the regeneration stream flow and/or the carbon bed
regeneration temperature are not monitored, either
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with Items
[(b)and (c)and(d)].
(b) Continuous records are kept of the concentration YD N b
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
[Note: If #9(a) is checked "Yes", or H 9(b) and 9(c) and 9(d)
are checked "Yes', the facility is in compliance even if
numbers 2 through 8 are checked 'No'.]
(continued)
pjs|135/lable-5.06 G-7
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
IF THE RECOVERY DEVICE IS AN ABSORBER AND THE TRE
INDEX VALUE IS GREATER THAN 1.0 AND LESS THAN OR
EQUAL TO 4.0
1. Documentation of the initial TRE calculation including test YD N a
results was submitted in the NCS.a
2. A temperature monitoring device and a specific gravity YD No
monitoring device equipped with a continuous monitor are
used to measure the exit temperature of the scrubbing liquid
and the exit specific gravity.
3. Documentation to establish a site-specific range for the exit YD N D
temperature of the scrubbing liquid and exit specific gravity
was submitted in the NCSa or operating permit.
4. Records of the daily average exit temperature of the YD N D
scrubbing liquid and exit specific gravity are kept.
5. Continuous records0 of the exit temperature of the YD No
absorbing liquid are kept.
6. Continuous records0 of the exit specific gravity are kept. YD N D
7. All daily average exit temperatures of the absorbing liquid YD N D
that are outside the site-specific range are reported in the
PR.D
8. All daily average specific gravity values that are outside the YD N D
site-specific range are reported in the PR.D
9. If the exit temperature and/or the exit specific gravity are
not monitored, either:
(a) The facility has documentation that they applied for YD No
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting JOT continue with items
l(b)and(c)and(d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.D
(continued)
Pisj135/table-5.06 G-8
-------
TABLE 5-6. COMPLIANCE CHECKLIST FOR PROCESS VENT SYSTEMS
[Note: If #9(a) is checked "Yes", or if 9(b) and 9(c) and 9(d)
are checked "Yes", the facility is in compliance even if
numbers 2 through 8 are checked "No".]
IF THE RECOVERY DEVICE IS A CONDENSER AND THE THE
INDEX VALUE IS GREATER THAN 1.0 AND LESS THAN OR
EQUAL TO 4.0
1. Documentation of the initial TRE calculation including test YD N a
results was submitted in the NCS.a
2. A temperature monitoring device equipped with a YD N D
continuous recorder Is used to measure the product side
exit temperature.
3. Documentation to establish a site-specific range for the exit YD N D
temperature was submitted in the NCSa or operating permit.
4. Records of the daily average exit temperature are kept. YD N D
5. Continuous records0 of the exit temperature are kept YD N D
6. All product side daily average exit temperatures that are YD N D
outside the site-specific range are reported in the PR.b
7. If the exit temperature is not monitored, either.
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
record keeping and reporting .or continue with items
((b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
[Note: If #7(a) is checked "Yes", or if 7(b) and 7(c) and 7(d)
are checked "Yes", the facility Is in compliance even if
numbers 2 through 6 are checked "No".]
(continued)
p|s|135/table-5.06 Q.Q
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
GENERAL - FOR ANY (NON-RECOVERY) CONTROL DEVICE
[Note: Items #1 through #4 do not apply to low leg drains, high
point bleeds, analyzer vents, open-ended valves or lines, and
pressure relief valves needed for safety purposes.]
1. Hourly records are kept of whether the flow indicator in the YD N q
bypass line was operating and whether flow was detected at
any time during the hour, when seal mechanisms are not
used and
2. The time and duration of all periods when flow is diverted or YD N a
the monitor is not operating are reported in the PR when
seal mechanisms are not used [or #3 and #4].
3. Records of monthly visual inspections are kept when seal YD N a
mechanisms are used and
4. All periods when the seal mechanism is broken, the bypass YD N D
line valve position has changed, or the key to unlock the
bypass line valve was checked out are recorded and
reported in the PR when seal mechanisms are used.
[Note: In order to be in compliance with provisions for
bypass lines either. #1 and #2 must both be checked 'yes*
or both #3 and #4 must both be checked "yes".]
GENERAL - FOR GROUP 2 PROCESS VENTS
1. Records of process changes and the recalculation of TRE YD N D
index values are kept when the TRE index value of the vent
stream is greater than 1.0.^
2. Records of process changes and the recalculation of flow YD N D
rate are kept when the flow rate of the vent stream is less
than 0.005 standard cubic meter per minute.
3. Records of process changes and the recalculation or YD N D
remeasurement of concentration are kept if the
concentration in the vent stream is less than 50 ppmv.
(continued)
p|s)135/tat)le-5.06 G-10
-------
TABLE 5-6. COMPUANCE CHECKUST FOR PROCESS VENT SYSTEMS
4. Whenever process changes are made which cause a Y o No
change in the status of the process vent stream, records are
kept and a report was submitted within 180 days of the
process modification or in the next PR describing the
process modification and showing the results of the
recalculation of flow rate, organic HAP concentration,
and/or TRE index value.
VISUAL INSPECTION
1. A flow indicator is present at the entrance to any bypass line YD N o
that could divert the vent stream flow away from the control
device to the atmosphere .or all bypass line valves are
sealed in a closed position (e.g., with a car seal or lock-and-
key configuration).
2. For flares, a device for detecting the flame is present. YD N D
3. For all incinerators, and for boilers and process heaters with Y a N a
design heat input capacities less than 44 megawatts and the
vent steam is not introduced with the primary fuel, a
temperature monitoring device is present
4. For scrubbers used after combustors for halogenated vent YD N n
streams, a device for measuring pH and a device for
measuring flow are present.
5. For carbon adsorbers, a device for measuring carbon bed YD No
temperature and a device for measuring regeneration
stream flow are present [or #8].
6. For absorbers, a device for measuring exit liquid YD N o
temperature and a device for measuring exit specific gravity
are present [or #8).
7. For condensers, a temperature monitoring device is present YD N O
[or #8].
8. If the monitoring devices listed in Items 5 through 7 are not YD N D
present, an organic compounds monitor is present
[Note: If Item #8 is checked 'Yes', the facility is in
compliance even if numbers 5 through 7 are checked "No".]
9. Visual inspection of the facility is consistent with written YD N D
records.
a NCS = Notification of Compliance Status.
b PR = Periodic Reports.
(continued)
pjs|135/table-5.06 G-11
-------
TABLE 5-6. COMPLIANCE CHECKLIST FOR PROCESS VENT SYSTEMS
c Continuous records, as defined in §63.111, means documentation, either in computer readable
form or hard copy, or data values measured at least once every 15 minutes and recorded at the
frequency specified in §63.152(f). Section 63.152(1) allows the owner to record either values
measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
all measured values during each period. If the daily average value of a monitored value for a given
parameter is within the range established in the NCS, the owner or operator may retain block hourly
averages instead of the 15-minute values. An owner or operator may request approval to use
alternatives to continuous monitoring under §63.151(g) of Subpart G.
d The number of excused excursions is as follows:
For the first semi-annual period after the NCS is due - 6 excursions;
For the second semi-annual period - 5 excursions;
For the third semi-annual period - 4 excursions;
For the fourth semi-annual period - 3 excursions;
For the fifth semi-annual period - 2 excursions;
For the sixth and all subsequent semi-annual periods -1 excursion.
An excursion occurs when: (1) the daily average value of the monitored parameter is outside the
range established in the NCS or operating permit; or (2) if monitoring data are insufficient. In order
to have sufficient data, a source must have measured values for each 15-minute period within each
hour for at least 75 percent of the hours the control device is operating in a day. For example, if a
control device operates 24 hours per day, data must be available for all 15-minute periods in at
least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
hour of incomplete data is allowed.
e Examples of process changes include, but are not limited to, changes in production capacity,
production rate, feedstock type, or catalyst type, or whenever there is replacement, removal, or
addition of recovery equipment. Process changes do not include process upsets; unintentional,
temporary process changes; and changes that are within the range on which the original TRE
calculation was based.
NOTE ALL DEFICIENCIES
p|s]135Aat>le-5.06 G-12
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
Complete this form for transfer racks. A 'yes* response to all questions will indicate full compliance,
and a 'no* response will indicate noncompliance with the standard except where noted. Note that for
transfer racks, a combustion or recovery device can be used to reduce emissions by 98 percent or to
20 ppmv. Vapor balancing can also be used to comply.
CONTROL DEVICE
DATE OF STARTUP
REVIEW OF RECORDS
IF THE CONTROL DEVICE IS A FLARE
1. Results of the initial test were submitted in the NCS.a Y a N a
2. The presence of a continuous flare pilot flame Is monitored using YD No
a heat sensing device designed to detect the presence of a flame.
3. All periods when the flare pilot did not have a flame have been YD N a
recorded and reported in the PR.*5
IF THE CONTROL DEVICE IS A THERMAL INCINERATOR
1. Either the results of the initial performance test were submitted in Y a N a
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. Either (1) test documentation demonstrates 98 percent HAP or YD N D
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3. A temperature monitoring device equipped with a continuous YD N a
monitor is used to measure the temperature of the gas stream in
the firebox (or in the ductwork immediately downstream of the
firebox before any substantial heat exchange occurs).
4. Documentation to establish a site-specific range for firebox YD N a
temperature was submitted in the NCSa or operating permit
application.
5. Continuous records^ of firebox temperature are kept.0 YD N D
6. Records of daily average firebox temperature are kept. YD N D
(continued)
p|s|13S/lable-6.04 G-13
-------
TABLE 6-4. COMPLIANCE CHECKLIST FOR TRANSFER OPERATIONS
7. All daily average firebox temperatures that are outside the site- YD No
specific established range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
8. The number of excursions does not exceed the number of YD N n
excused excursions in the semi-annual reporting period.6
9. If the firebox temperature is not monitored, the facility has YD N D
documentation that they applied for and received approval to
monitor an alternative parameter, and are performing the required
recordkeeping and reporting.
[Note: If #9 is checked "Yes", the facility is in compliance even If
numbers 3 through 8 are checked "No".]
IF THE CONTROL DEVICE IS A CATALYTIC INCINERATOR
1. Either the results of the initial performance test were submitted in YD N D
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. Either (1) test documentation demonstrates 98 percent HAP or YD N D
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3. Temperature monitoring devices equipped with continuous YD No
recorders are used to measure the temperature in the gas stream
immediately before and after the catalyst bed.
4. Documentation to establish a site-specific range for the gas YD N D
stream temperature upstream of the catalyst bed and the
temperature difference across the bed was submitted in the NCSa
or operating permit application.
5. Continuous records^ are kept of the temperature of the gas . YD N D
stream upstream of the catalyst bed and the temperature
difference across the catalyst bed.c
6. Records of the daily average temperature upstream of the YD N D
catalyst bed and the temperature difference across the catalyst
bed are kept
(continued)
p|s|135Aable-6.M G-14
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
7. All daily average upstream temperatures that are outside the site- Y a N a
specific range and all operating days when Insufficient monitoring
data are collected are reported in the PR.D
8. All daily average temperature differences across the catalyst bed YD No
that are outside the site-specific range and all operating days
when insufficient monitoring data are collected are reported in the
PR.D
9. The number of excursions does not exceed the number of YD No
excused excursions in the semi-annual reporting period.8
10. If the temperature upstream of the catalyst bed and/or the YD ND
temperature differential across the catalyst bed are not monitored,
the facility has documentation that they applied for and received
approval to monitor an alternative parameter, and are performing
the required recordkeeping and reporting.
[Note: If #10 is checked "Yes*, the facility is in compliance even if
numbers 3 through 9 are checked 'No'.]
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER WITH
A DESIGN HEAT INPUT CAPACITY LESS THAN 44 MEGAWATTS AND
THE VENT STREAM IS NOT INTRODUCED WTTH THE PRIMARY FUEL
1. Either the results of the initial performance test were submitted in YD No
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. A description of the location at which the vent stream is YD No
introduced into the boiler or process heater was submitted In the
NCS.a
3. The vent stream is introduced into the flame zone of the boiler or Y a N a
process heater.
4. Either (1) test documentation demonstrates 98 percent HAP or YD ND
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
5. A temperature monitoring device equipped with a continuous YD No
monitor is used to measure the temperature of the gas stream In
the firebox.
(continued)
pjs|135Aable-6.04 ' G-15
-------
TABLE 6-4. COMPLIANCE CHECKLIST FOR TRANSFER OPERATIONS
6. Documentation to establish a site-specific range for firebox Y a
temperature was submitted in the NCSa or operating permit
application.
7. Continuous recordsd are kept of the firebox temperature.0 Y a
8. Records of the daily average firebox temperature are kept. Y a
9. All daily average firebox temperatures that are outside the site- Y a
specific range and all operating days when insufficient monitoring
data are collected are reported in the PR.b
10. The number of excursions does not exceed the number of YD
excused excursions in the semi-annual reporting period.8
11. If the firebox temperature is not monitored, the facility has Y D
documentation that they applied for and received approval to
monitor an alternative parameter, and are performing the required
record keeping and reporting.
[Note: If #11 is checked "Yes", the facility is in compliance even if
numbers 5 through 10 are checked "No".]
ND
No
ND
No
No
ND
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER WITH
A DESIGN HEAT INPUT CAPACITY GREATER THAN 44 MEGAWATTS
1. A description of the location at which the vent stream is YD
introduced into the boiler or process heater was submitted in the
NCS.a
2. The vent stream is introduced into the flame zone of the boiler or YD
process heater.
ND
ND
IF THE CONTROL DEVICE IS A SCRUBBER (FOLLOWING A
COMBUSTOR FOR A HALOGENATED VENT STREAM)
1. Either the results of the initial performance test were submitted in
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
YD
ND
(continued)
p)sJ135/lable-6.04
G-16
-------
TABLE 6-4. COMPUANCE CHECKUST FOR TRANSFER OPERATIONS
2. Either (1) test documentation demonstrates99 percent control YD No
efficiency for total halogens and hydrogen halides or test
documentation demonstrates that the outlet mass of total
hydrogen halides and halogens are less than 0.45 kilograms per
hour, or (2) If the scrubber was installed prior to December 31,
1992, test documentation demonstrates 95 percent control
efficiency for total halogens and hydrogen halides or test
documentation demonstrates that the outlet mass of total
hydrogen halides and halogens are less than 0.45 kilograms per
hour.
3. A pH monitoring device equipped with a continuous recorder is YD No
used to monitor the pH of the scrubber effluent.
4. A flow meter equipped with a continuous recorder is used to Y n N a
measure the influent liquid flow and effluent vapor flow.
5. Documentation to establish a site-specific range for the pH, and YD No
liquid/gas ratio was submitted in the NCSa or operating permit.
6. ' Continuous records^ of the pH of the scrubber effluent are kept YD No
7. Continuous records^ of the scrubber liquid/gas ratio are kept.0 Y o N a
8. Records of the daily average pH and the daily average liquid/gas YD N n
ratio are kept.
9. All daily average pH values of the scrubber effluent that are YD N a
outside the site-specific range and all operating days when
insufficient monitoring data are collected are reported in the PR.*5
10. All daily average scrubber liquid/gas ratios that are outside the Yn Na
site-specific range and all operating days when insufficient
, monitoring data are collected are reported in the PR.b
11. The number of excursions does not exceed the number of Y n No
excused excursions in the semi-annual reporting period.6
12. If the pH and /or the scrubber liquid to gas ratio are not YD No
monitored, the facility has documentation that they applied for
and received approval to monitor an alternative parameter, and
are performing the required recordkeeping and reporting.
[Note: If #12 is checked "Yes*, the facility is In compliance even if
numbers 3 through 11 are checked 'No'.]
(continued)
p)sJ135/Wble-6.04 G-17
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
IF THE RECOVERY DEVICE IS A CARBON ADSORBER
1. Either the results of the initial performance test were submitted in YD No
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. Either (1) test documentation demonstrates 98 percent HAP or YD ND
TOC control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3. An integrating regeneration stream (e.g., steam) flow monitoring YD No
device having an accuracy of jf 10 percent and capable of
recording total regeneration stream mass flow for each
regeneration cycle is used to measure regeneration stream flow.
4. A carbon bed temperature monitoring device capable of YD N D
recording the carbon bed temperature after each regeneration
and within 15 minutes of completing any cooling cycle is used to
measure carbon bed regeneration temperature.
5. Documentation to establish a site-specific range for the YD N D
regeneration stream flow and carbon bed regeneration
temperature was submitted in the NCSa or operating permit
6. Records are kept of the total regeneration stream mass flow for YD N D
each carbon bed regeneration cycle.
7. Records are kept of the temperature of the carbon bed after each YD N D
carbon bed regeneration.
8. All regeneration cycles when the total regeneration stream mass YD N D
flow is outside the site-specific range and all operating days when
Insufficient monitoring data are collected are reported in the PR.13
9. All regeneration cycles during which the temperature of the YD N D
carbon bed after regeneration is outside the site-specific range
and all operating days when insufficient monitoring data are
collected are reported in the PR.*3
10. The number of excursions does not exceed the number of YD ND
excused excursions in the semi-annual reporting period.6
(continued)
p|s|135/table-6.04 G-18
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
11. If the regeneration stream flow and/or the carbon bed
regeneration temperature are not monitored, either:
(a) The facility has documentation that they applied for and YD N a
received approval to monitor an alternative parameter,
and are performing the required recordkeeping and
reporting .or continue with items [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration level or YD N D
reading indicated by an organic monitoring device at the
outlet of the control device.
(c) Records are kept of the daily average concentration level YD N a
or reading for each operating day.
(d) All daily average concentration levels or readings that are YD No
outside the site-specific range are reported in the PR.b
[Note: If #11 (a) is checked "Yes", or if 11 (b) and 11 (c) and 11 (d)
are checked "Yes", the facility is in compliance even if numbers 3
through 10 are checked "No".]
IF THE RECOVERY DEVICE IS AN ABSORBER
1. Either the results of the initial performance test were submitted in YD N a
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
2. Either (1) test documentation demonstrates 98 percent HAP or YD N D
TOO control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3. A temperature monitoring device and a specific gravity monitoring YD N D
device equipped with a continuous monitor are used to measure
the exit temperature of the scrubbing liquid and the exit specific
gravity.
4. Documentation to establish a site-specific range for the exit YD N D
temperature of the scrubbing liquid and exit specific gravity was
submitted in the NCSa or operating permit
5. Records of the daily average exit temperature of the scrubbing YD N D
liquid and exit specific gravity are kept
(continued)
p)s|135AaOle-6.04 G-19
-------
TABLE 6-4. COMPLIANCE CHECKLIST FOR TRANSFER OPERATIONS
6. Continuous records01 of the exit temperature of the absorbing YD No
liquid are kept.0
7. Continuous records^ of the exit specific gravity are kept. YD N D
8. All daily average exit temperatures of the absorbing liquid that are YD N D
outside the site-specific range and all operating days when
insufficient monitoring data are collected are reported in the PR.13
9. All daily average exit specific gravity values that are outside the YD N D
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
10. The number of excursions does not exceed the number of YD ND
excused excursions in the semi-annual reporting period.6
11. If the exit temperature and/or the exit specific gravity are not
monitored, either:
(a) The facility has documentation that they applied for and YD N D
received approval to monitor an alternative parameter,
and are performing the required recordkeeping and
reporting or continue with items [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration level or YD N D
reading indicated by an organic monitoring device at the
outlet of the control device.
(c) Records are kept of the daily average concentration level YD N D
or reading for each operating day.
(d) All daily average concentration levels or readings that are YD N D
outside the site-specific range are reported in the PR.b
[Note: If # 11 (a) is checked "Yes", or if 11 (b) and 11 (c) and 11 (d)
are checked "Yes", the facility is in compliance even if numbers 3
through 10 are checked "No".]
IF THE RECOVERY DEVICE IS A CONDENSER
1. Either the results of the initial performance test were submitted In YD N D
the NCS or a design evaluation was submitted0 in the IP that
documents that the control device achieves the required control
efficiency during maximum load conditions.
(continued)
p|sj135Aable-6.04 G-20
-------
TABLE 6-4. COMPUANCE CHECKUST FOR TRANSFER OPERATIONS
2. Either (1) test documentation demonstrates 98 percent HAP or YD No
TOO control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOO; or (2) the
parameters identified in the design evaluation are being
monitored and maintained within the ranges specified in the NCS.
3. A temperature monitoring device equipped with a continuous YD N n
recorder is used to measure the product side exit temperature.
4. Documentation to establish a site-specific range for the exit Y a N a
temperature was submitted in the NCSa or operating permit
5. Records of the daily average exit temperature are kept YD N n
6. Continuous records^ of the exit temperature are kept.0 YD No
7. All product side daily average exit temperatures that are outside YD No
the site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
8. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.6
9. If the exit temperature is not monitored, either
(a) The facility has documentation that they applied for and YD N D
received approval to monitor an alternative parameter,
and are performing the required recordkeeping and
reporting .or continue with Items [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration level or YD N D
reading indicated by an organic monitoring device at the
outlet of the control device.
(c) Records are kept of the daily average concentration level YD N D
or reading for each operating day.
(d) All daily average concentration levels or readings that are YD N D
outside the site-specific range are reported in the PR.*3
[Note: If #9(a) is checked "Yes", or if 9(b) and 9(c) and 9(d) are
checked "Yes", the facility is in compliance even if numbers 3
through 8 are checked 'No'.]
(continued)
p|s|135/table-6.04 G-21
-------
TABLE 6-4. COMPUANCE CHECKLIST FOR TRANSFER OPERATIONS
IF THE RECOVERY DEVICE IS A VAPOR-BALANCING SYSTEM AND
THE LOADING OPERATION IS SUBJECT TO HON TRANSFER
PROVISIONS'
1 . Records are kept of all parts of any vapor-balancing system that
are designated as either unsafe-to-inspect or difficult-to-inspect.
2. For equipment that is designated as difficult to inspect, a written
plan is kept that requires inspection of equipment at least once
every five years.
3. For equipment that is designated as unsafe to inspect, a written
plan is kept that requires inspection of equipment as frequently as
practicable.
4. For each inspection during which a leak was detected, the
following information is recorded and reported.
(a) Instrument identification numbers, operator name or
initials, and equipment identification information;
(b) The date the leak was detected and the date of the first
attempt to repair it;
(c) Maximum instrument reading after the leak is repaired or
determined to be non-repairable;
(d) Explanation of delay in repair, if the leak was not repaired
within 15 days after it was discovered;
(e) Name or initials of person who decides repairs cannot be
made without a shutdown;
(f) Expected date of successful repair if not repaired within
15 days;
(g) Dates of shutdowns that occur while the equipment is
unrepaired; and
(h) Date of successful repair of the leak.
5. For each inspection during which no leaks were detected, the
following records are kept:
(a) Record that the inspection was performed;
(b) Date of the inspection; and
(c) Statement that no leaks were found.
YD
YD
YD .
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
ND
No
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
(continued)
pjs|13S/toble-6.04 G-22
-------
TABLE 6-4. COMPLIANCE CHECKUST FOR TRANSFER OPERATIONS
GENERAL - FOR ANY CONTROL DEVICE, RECOVERY DEVICE, OR
VAPOR-BALANCING SYSTEM
Note: Items #1 through #4 do not apply to low leg drains, high point bleeds, analyzer vents, open-
ended valves or lines, and pressure relief valves needed for safety purposes.
1 . Hourly records are kept of whether the flow indicator in the YD No
bypass line was operating and whether flow was detected at any
time during the hour, when seal mechanisms are not used, and
2. The time and duration of all periods when flow is diverted or the YD N n
monitor is not operating are reported in the PR when seal
mechanisms are not used [or #3 and
3. Records of monthly inspections are kept when seal mechanisms YD N D
are used and
4. All periods when the seal mechanism is broken, the bypass line YD No
valve position has changed, or the key to unlock the bypass line
valve was checked out are recorded and reported in the PR when
seal mechanisms are used.
[Note: In order to be in compliance with provisions for bypass
lines either: #1 and #2 must both be checked "Yes" or both #3
and #4 must be checked "Yes".]
5. All tank trucks and rail cars have a current DOT pressure test YD N D
certification in accordance with the requirements of 49 CFR 180
for tank trucks or 49 CFR 173.31 for railcars or have been
demonstrated to be vapor-tight within the preceding 12 months.9
[Note: Items #6 through #10 do not apply to vapor collection
systems that are operated under negative pressure.]
6. ' Records are kept of all parts of any vapor-collection system that YD N D
are designated as either unsafe-to-inspect or drfficult-to-inspect
7. For equipment that is designated as difficult to inspect, a written YD N D
plan is kept that requires inspection of equipment at least once
every five years.
8. For equipment that is designated as unsafe to inspect, a written YD N D
plan is kept that requires inspection of equipment as frequently as
practicable.
9. For each inspection during which a leak was detected, the
following information is recorded and reported.
(a) Instrument identification numbers, operator name or YD No
initials, and equipment identification information;
(continued)
p|sJ13S/taoie-6.04 G-23
-------
TABLE 6-4. COMPLIANCE CHECKLIST FOR TRANSFER OPERATIONS
(b)
(c)
(d)
(e)
(0
(g)
(h)
The date the leak was detected and the date of the first
attempt to repair it;
Maximum instrument reading after the leak is repaired or
determined to be non-repairable;
Explanation of delay in repair, if the leak was not repaired
within 15 days after It was discovered;
Name or Initials of person who decides repairs cannot be
made without a shutdown;
Expected date of successful repair if not repaired within
15 days;
Dates of shutdowns that occur while the equipment is
unrepaired; and
Date of successful repair of the teak.
YD
YD
YD
YD
YD
YD
YD
No
ND
. ND
ND
ND
ND
ND
10. For each inspection during which no leaks were detected, the
following records are kept:
(a)
(b)
(c)
Record that the inspection was performed;
Date of the inspection; and
Statement that no leaks were found.
YD
YD
YD
ND
NO
No
GENERAL - FOR GROUP 1 AND GROUP 2 TRANSFER RACKS
1. Records are kept of the design and actual annual throughput of YD No
the loading rack, the weight percent HAP of liquid loaded, and
the annual rack weighted average HAP vapor pressure.
VISUAL INSPECTION
1. A flow indicator is present at the entrance to any bypass line that YD N D
could divert the vent stream flow away from the control device to
the atmosphere .or all bypass line valves are sealed in a dosed
position (e.g., with a car seal or lock-and-key configuration).
2. For flares, a device for detecting the flame is present YD N D
3. For ail incinerators, and for boPers and process heaters with YD N D
design heat input capacities less than 44 megawatts and the vent
steam is not introduced with the primary fuel, a temperature
monitoring device is present.
(continued)
p]s)135Aable-6.(M G-24
-------
TABLE 6-4. COMPUANCE CHECKLIST FOR TRANSFER OPERATIONS
4. For scrubbers used after combustors for halogenated vent YD No
streams, a device for measuring pH and a device for measuring
flow are present.
5. For carbon adsorbers, a device for measuring carbon bed YD N a
temperature and a device for measuring regeneration stream flow
are present [or #8].
6. For absorbers, a device for measuring exit liquid temperature and YD N D
a device for measuring exit specific gravity are present [or #8J.
7. For condensers, a temperature monitoring device Is present YD N D
[or #8].
8. If the monitoring devices listed in items 5 through 7 are not YD N D
present, an organic compounds monitor is present.
[Note: If item #8 is checked "Yes', the facility is in compliance
even if numbers 5 through 7 are checked "No".]
9. Visual inspection of the facility is consistent with written records. YD N D
a NCS = Notification of Compliance Status.
b PR = Periodic Reports.
c For transfer racks that transfer less than 11.8 million liters per year of liquids containing organic
HAP's, the owner or operator may conduct a design evaluation and monitor the design parameters
instead of conducting a performance test.
d Continuous records, as defined in §63.111, means documentation, either in computer readable
form or hard copy, or data values measured at least once every 15 minutes and recorded at the
frequency specified in §63.152(0- Section 63.152(0 allows the owner to record either values
measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
all measured values during each period. If the daily average value of a monitored value for a given
parameter is within the range established in the NCS, the owner or operator may retain block hourly
averages instead of the 15-minute values. An owner or operator may request approval to use
alternatives to continuous monitoring under §63.151 (g) of Subpart G.
(continued)
p|s|135Aoble-6.04 G-25
-------
TABLE 6-4. COMPLIANCE CHECKLIST FOR TRANSFER OPERATIONS
e The number of excused excursions is as follows:
For the first semi-annual period after the NCS is due - 6 excursions;
For the second semi-annual period - 5 excursions;
For the third semi-annual period - 4 excursions;
For the fourth semi-annual period - 3 excursions;
For the fifth semi-annual period - 2 excursions;
For the sixth and all subsequent semi-annual periods -1 excursion.
An excursion occurs when: (1) the daily average value of the monitored parameter is outside the
range established in the NCS or operating permit; or (2) if monitoring data are insufficient In order
to have sufficient data, a source must have measured values for each 15-minute period within each
hour for at least 75 percent of the hours the control device is operating in a day. For example, if a
control device operates 24 hours per day, data must be available for all 15-minute periods in at
least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
hour of incomplete data is allowed.
' Under §63.111 (d)(2) of Subpart G, the owner or operator may be exempt from the transfer
provisions during operations during which vapor balancing is used. However, the owner or
operator may elect to designate the rack as a transfer rack subject to the HON and comply with the
provisions of §63.126 through §63.130 during operations when vapor balancing is used. For
example, an owner or operator may elect to be subject in order to include the rack in an emissions
average.
9 This requirement does not apply for operations during which a vapor balancing system is used.
NOTE ALL DEFICIENCIES
p|s)135A«ble-6.04 G-26
-------
TABLE 7-4. COMPUANCE CHECKLIST FOR STORAGE VESSELS
»
Complete this form for storage vessels. A "yes" response to all questions will indicate full compliance,
and a "no" response will indicate noncompliance with the standard.
CONTROL EQUIPMENT
DATE OF STARTUP
REVIEW OF RECORDS
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
1. Review records of Seal Gap Measurements.
(a) Records indicate that seal gap measurements were made YD N o
annually for the secondary seal and every five years for
the primary seal.3
(b) When a failure is detected, the date and results of seal YD N a
gap measurements are submitted in periodic reports,
annually for the secondary seal and every five years for
the primary seal.
(c) When a failure is detected In the seal(s), the date and YD No
results of the visual Inspection of the seals (which Is
performed together with the seal gap measurement) are
included in the PR.b
(d) The date of the seal gap measurement, the raw data YD N D
obtained during the measurement, and the calculations
made are recorded.
(e) The raw data and calculations recorded for seal gap YD No
measurements is consistent with the information reported
in the PR.
(0 For each seal gap measurement in a periodic report, YD N D
there is a report notifying the Administrator of the
measurement in advance. If the measurement had been
planned, then the report was submitted 30 days in
advance of the measurement If the measurement was
not planned, then the report was submitted at least
7 days in advance of the measurement and included an
explanation of why the measurement was unplanned.
(continued)
p)sJl35Aatjie-7.04 G-27
-------
TABLE 7-4. COMPLIANCE CHECKUST FOR STORAGE VESSELS
(g) If a failure was detected during a seal gap measurement YD No
and visual seal Inspection, the PR indicated the date and
the nature of the repair or the date the vessel was
emptied.
(h) If the report described in (g) documents that the repair YD No
was made more than 45 days after the failure was
detected, then the next PR includes documentation of the
use of up to two 30-day extensions for completing the
repair, including identification of the storage vessel, a
description of the failure, documentation that alternate
storage capacity was unavailable, a schedule of actions
to be taken to repair the control equipment or empty the
vessel as soon as possible, and the date the storage
vessel was emptied and the nature of and date the repair
was made.
2. Review records of internal visual inspections.
(a) The occurrence of each internal visual inspection is YD N D
recorded.
(b) For each internal visual inspection in which a failure was YD No
detected, the following information is submitted in the PR:
(1) the date of the inspection, (2) identification of all
storage vessels for which failures were detected, (3) a
description of those failures, and (4) either the date and
nature of the repair or the date the vessel was emptied.
(c) Any repairs performed as described in (b) were YD N D
completed before the repaired storage vessel was refilled.
(d) For each internal visual inspection documented in a PR, YD N D
there is a report notifying the Administrator in advance of
. the date the inspected vessel would be refilled after the
inspection. If the inspection had been planned, the report
was submitted 30 days in advance of refilling the vessel.
If the inspection was not planned, then the report was
submitted at least 7 days in advance of refilling the vessel
and included an explanation of why the inspection was
unplanned.
(continued)
Pls|135/table-7.04 G-28
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
IF THE CONTROL EQUIPMENT IS AN INTERNAL FLOATING ROOF OR
AN EXTERNAL FLOATING ROOF CONVERTED TO AN INTERNAL
FLOATING ROOF
1. Review records of external visual inspections
(a) The occurrence of each annual external visual inspection YD No
is recorded. If the floating roof is equipped with double
seals, the source will not have performed this inspection if
it chose to perform internal visual inspections once every
5 years instead of performing both annual external visual
inspections and internal visual inspections at least once
every 10 years. See Item 2 below.
(b) For each annual external visual inspection in which a YD N D
failure was detected, the following information is
submitted in the PR: (1) the date of the inspection,
(2) identification of all storage vessels for which failures
were detected, (3) a description of those failures, and
(4) either the date and the nature of the repair or the date
the vessel was emptied.
(c) If the report described in (a) and (b) documents that the YD N D
repair was made more than 45 days after the failure was
detected, then the next PR includes documentation of the
use of up to two 30-day extensions for completing the
repair and the following information: identification of the
storage vessel, a description of the failure, documentation
that alternate storage capacity was unavailable, a
schedule of actions to be taken to repair the control
equipment or empty the vessel as soon as possible, and
the date the storage vessel was emptied and the nature
of and date the repair was made.
2. Review records of internal visual inspections.
(a) The occurrence of each internal visual inspection is YD N D
recorded. If the floating roof is equipped with double
seals and the source chose not to perform annual
external inspections [described in Item 1(b)], this
inspection will be performed, recorded, and reported at
least every 5 years.
(continued)
p|sJ13S/table-7.04 G-29
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(b) For each internal visual inspection in which a failure was YD N n
detected, the following information is submitted in the PR:
(1) the date of the inspection, (2) identification of all
storage vessels for which failures were detected, (3) a
description of those failures, and (4) the date and nature
of the repair.
(c) Any repairs performed as described in (b) were YD N a
completed before the repaired storage vessel was refilled.
(d) For each internal visual inspection documented In a PR, YD N a
there is a report notifying the Administrator in advance of
the date the inspected vessel would be refilled after the
inspection. If the inspection had been planned, the report
was submitted 30 days in advance of refilling the vessel.
If the inspection was not planned, then the report was
submitted at least 7 days in advance of refilling the vessel
and included an explanation of why the inspection was
unplanned.
IF THE CONTROL EQUIPMENT IS A CLOSED VENT SYSTEM AND
CONTROL DEVICE
1. If the control device is a flare, review the following records.
(a) The results of the initial compliance determination were YD N D
submitted in the NCS.C
(b) All periods when the flare does not meet the general YD N D
control device requirements specified in §63.11 (b) of
Subpart A are recorded and reported in the PR.
(c) Each record and report described in (b) includes an YD N D
identification of the flare not meeting the general control
device requirements and the reason the flare did not
meet the general control device requirements.
(d) The total number of hours of routine maintenance of the YD N D
flare during which the flare does not meet the general
control device requirements specified in §63.11(b) of
Subpart A is recorded and reported in the PR.
(continued)
p|s|135rtable-7.04 G-30
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
2. If the control device is not a flare, review the following records.
(a) A design evaluation of the control device and a
description of the gas stream entering the control device
are recorded and reported in the IP.0-6-'
(1) If the control device is a thermal incinerator, the YD No
design evaluation includes the autoignition
temperature of the organic HAP emission stream,
the combustion temperature, and the residence
time at the combustion temperature.6.
(2) If the control device is a carbon adsorber, the YD N D
design evaluation includes the affinity of the
organic HAP vapors for carbon, the amount of
carbon In each bed. the number of beds, the
humidity of the feed gases, the temperature of
the feed gases, the flow rate of the organic HAP
emission stream, the desorption schedule, the
regeneration stream pressure or temperature, and
the flow rate of the regeneration stream. For
vacuum desorption, pressure drop is included.
(3) If the control device is a condenser, the design YD No
evaluation includes the final temperature of the
organic HAP vapors, the type of condenser, and
the design flow rate of the organic HAP emission
stream.
(b) The documentation described in (a) demonstrates that YD N D
the control device achieves 95-percent control efficiency
during reasonably expected maximum loading conditions
(or 90-percent efficiency if the control device was
installed prior to December 31, 1992).
(c) Recorded and reported in the IP are: (1) a description of YD No
the parameter (or parameters) to be monitored to ensure
that the control device is operated and maintained in
conformance with its design, (2) an explanation of the
criteria used for selection of the parameter (or
parameters), and (3) the frequency with which monitoring
will be performed.
(d) For each monitoring parameter identified in the IP. the YD N D
operating range is recorded and reported in the NCS.
(continued)
pjs|135/lable-7.04 G-31
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(e) Records of the monitored parameter (or parameters), as YD No
described in (c) and (d), are kept at the required
frequency.
(f) Each occurrence when the monitored parameter (or Y a N a
parameters) was outside its parameter range
(documented in the NCS) is recorded and reported In the
PR.
(g) Each record and report described in (f) includes an YD N a
explanation of why the measured parameter (or
parameters) was outside of its established range.
(h) The total number of hours of routine maintenance of the YD N D
control device during which the control device does not
achieve a 95-percent control efficiency (or 90-percent
control efficiency if the control device was installed prior
to December 31,1992) is recorded and reported in the
PR.
3. For all control devices, review the following records.
(a) A description of the routine maintenance planned for the YD N D
next 6 months and actually performed In the previous 6
months is recorded and reported in the PR.
Note: Items (b) through (0 do not apply to vapor-
collection systems that are operated and
maintained under negative pressure.
(b) Records are kept of all parts of any vapor-collection YD N D
system that are designated as either unsafe-to-inspect or
difficult-to-inspect, with an explanation of the designation.
(c) For equipment that is designated as difficult to inspect, a YD N D
written plan is kept that requires inspection of equipment
at least once every five years.
(d) For equipment that is designated as unsafe to Inspect, a YD N D
written plan is kept that requires inspection of equipment
as frequently as practicable.
(e) For each inspection during which a leak was detected,
the following Information is recorded and reported.
(1) Instrument Identification numbers, operator name YD N D
or initials, and equipment Identification
information;
(continued)
p]s|135/lable-7.04 G-32
-------
TABLE 7-4. COMPUANCE CHECKUST FOR STORAGE VESSELS
(0
(g)
(h)
w
(2) The date the leak was detected and the date of
the first attempt to repair it;
(3) Maximum instrument reading after the leak is
repaired or determined to be non-repairable;
(4) Explanation of delay in repair, if the leak was not
repaired within 15 days after it was discovered;
(5) Name or initials of person who decides repairs
cannot be made without a shutdown;
(6) Expected date of successful repair if not repaired
within 15 days;
(7) Dates of shutdowns that occur while the
equipment is unrepaired; and
(8) Date of successful repair of the leak.
For each inspection during which no leaks were detected,
the following records are kept:
(1) Record that the inspection was performed;
(2) Date of the inspection; and
(3) Statement that no leaks were found.
Hourly records are kept of whether the flow indicator in
the bypass line was operating and whether flow was
detected at any time during the hour, when seal
mechanisms are not used and
The time and duration of all periods when flow is diverted
or the monitor is not operating are reported in the PR
when seal mechanisms are not used [or (i) and (j)].
Records of monthly visual inspections are kept when seal
mechanisms are used and
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
(continued)
p|sJ135/WOle-7.04 G-33
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(j) All periods when the seal mechanism is broken, the YD N a
bypass line valve position has changed, or the key to
unlock the bypass line valve was checked out are
recorded and reported in the PR when seal mechanisms
are used.
Note: In order to be in compliance with provisions for
bypass lines either: items (g) and (h) must both
be checked "Yes" or both items (i) and Q) must
be checked "Yes".
VISUAL INSPECTION
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
Note: The inspector should not perform the inspection while on the EFR if the roof is below four feet
of the top of the tank and if the inspector is not equipped with the proper respiratory
protection. Based on the inspector's assessment of the availability of records documenting the
design of the control equipment, an adequate inspection without respiratory protection may be
performed with a combination of a record inspection and a visual inspection conducted from
the platform with the aid of vision-enhancing devices (binoculars).
1. The EFR is resting on the liquid surface of the stored material, YD No
unless the EFR is resting on the roof leg supports because the
vessel has just been emptied and degassed or the vessel Is
partially or completely emptied before being subsequently refilled
or degassed.
2. The external floating roof is in good condition (i.e., free of defects YD N D
such as corrosion and pools of standing liquid).
3. There is a secondary seal installed above the primary seal.n YD N D
4. Inspect the secondary seal.n
(a) The secondary seal is continuous and completely covers YD N D
the annular space between the EFR and the vessel wall.
(b) There are no holes, tears, or other openings in the seal or YD N D
seal fabric.
(c) There are no visible gaps between the seal and the wall YD N D
of the storage vessel, except as specified in (e)(1) and
(d) The seal is not detached from the floating deck. YD N D
(continued)
pjs|135/table-7.04 G-34
-------
TABLE 7-4. COMPUANCE CHECKLIST FOR STORAGE VESSELS
(e) Perform seal gap measurement of the secondary seal as
specified in §63.l20(b)(l) through (b)(4) of the HON
storage provisions.
(1) The accumulated area of gaps between the YD No
vessel wall and the secondary seal does not
exceed 21.2 cm2 per meter of vessel diameter.
(2) The maximum gap width between the vessel wall YD N o
and the seal does not exceed 1.27 cm.
5. Inspect the primary seal."
(a) The primary seal is either a metallic shoe seal or a liquid- YD N a
mounted seal.n
(b) The primary seal forms a continuous closure that YD N D
completely covers the annular space between the wall of
the storage vessel and the edge of the EFR, except as
described in (f)(1) and (0(2).
(c) There are no holes, tears, or other openings in the seal YD N a
fabric, seal envelope, or shoe (if a metallic shoe seal is
used).
(d) If the primary seal is a metallic shoe seal:
(1) The lower end of the metallic shoe send extends YD Nn
into the stored liquid (no specific distance);
(2) The upper end of the metallic shoe seal extends YD N D
a minimum vertical distance of 61 cm above the
stored liquid surface; and
(3) There is a flexible coated fabric that spans the YD N D
space between the metal shoe and the vessel
wall.
(e) If the primary seal is a liquid-mounted seal, the seal is in YD N D
contact with the liquid between the wall of the storage
vessel and the EFR.
(f) Perform seal gap measurements of the primary seal as
specified in §63.120(b)(1) through (b)(4) of the HON
storage provisions.
(1) The accumulated area of gaps between the YD ND
vessel wall and the primary seal does not exceed
212 crr>2 per meter of vessel diameter.
(continued)
p|s)135/lable-7.04 G-35
-------
TABLE 7-4. COMPLIANCE CHECKUST FOR STORAGE VESSELS
(2) The maximum gap width between the vessel wall YD N n
and the seal does not exceed 3.81 cm.
6. Inspect deck openings.
(a) If the EFR is non-contact, then each opening in the YD No
floating roof, except automatic bleeder vents and rim
space vents, provides a projection below the stored
liquid's surface.'
(b) Except for automatic bleeder vents, rim space vents, roof YD N a
drains, and leg sleeves, each opening in the roof Is
equipped with a gasketed cover, seal, or lid which forms
a vapor-tight seal.
(c) Each gasketed cover, seal, or lid on any opening in the YD N o
EFR is closed, unless the cover or lid must be open for
access.
(d) Covers on each access hatch and gauge float well are YD N D
bolted or fastened so as to be air-tight when closed.
(e) The gasket on each cover, seal, or lid described in (b) YD N D
closes off the liquid surface from the atmosphere.
7. Inspect automatic bleeder vents.
(a) Automatic bleeder vents are closed, unless the roof is YD N D
being floated off or is being landed on the roof leg
supports.
(b) Automatic bleeder vents are gasketed. YD N D
(c) The gasket on the automatic bleeder vents dose off the YD No
liquid surface from the atmosphere.
8. Inspect rim space vents.
(a) Rim space vents are closed, except when the roof is YD N D
being floated off the roof leg supports or when the
pressure beneath the rim seal exceeds the manufacturer's
recommended setting.
(b) Rim space vents are gasketed. YD N D
(c) The gaskets on the rim space vents dose off the liquid YD N D
surface from the atmosphere.
9. Each roof drain is covered with a slotted membrane fabric that YD N D
covers at least 90 percent of the area of the opening.
(continued)
p|s|135/lable-7.04 G-36
-------
TABLE 7-4. COMPUANCE CHECKLIST FOR STORAGE VESSELS
10. Each unslotted guide pole well has either a gasketed sliding YD Nn
cover or a flexible fabric sleeve seal.
11. Each unslotted guide pole shall have on the end of the pole a YD No
gasketed cap which is dosed at all times except when gauging
the liquid level or taking liquid samples.
12. Each slotted guide pole well is equipped with the following YD N D
equipment: (1) a gasketed sliding cover or a flexible fabric sleeve
seal, and (2) a gasketed float inside the guide pole or other
control device which doses off the liquid surface from the
atmosphere.
13. Each gauge hatch/sample well has a gasketed cover which is Yd ND
dosed (except when the hatch or well must be open for access).
14. All of the gaskets described In 10 through 13 dose off the liquid YD N D
surface from the atmosphere.
IF THE CONTROL EQUIPMENT IS AN INTERNAL FLOATING ROOF
Note: The inspector should be advised of the hazards of inspecting an Internal floating roof vessel
that contains a liquid hazardous air pollutant (HAP). An inspector may perform an external
visual inspection of a storage vessel at any time (i.e., the vessel does not need to be taken out
of service). However, the inspector will need to have proper respiratory protection before
opening the roof hatch to visually inspect, from the fixed roof, the floating deck and seal. An
inspector may perform the more thorough internal inspection only when the vessel has been
taken out of service (i.e., emptied, degassed and deaned). Unless a vessel Is taken out of
service more frequently than is required by the HON, this internal inspection can only take
place once every ten years, during those 30 days after which the State Agency has received
notice that the vessel has been emptied and degassed and will subsequently be refilled. The
inspector should never enter a storage vessel to inspect the IFR without first consulting
documents that address the safety issues to consider while entering a confined space and
while inspecting an IFR that contains HAP (e.g., the EPA document "Confined Space Safety
Document for Conducting NESHAP Compliance Inspections of Benzene Storage Tanks.")
1. External Visual Inspection
(a) The IFR is resting on the liquid surface of the stored YD N D
material, unless the IFR is resting on the leg supports
because the vessel has just been emptied and degassed
or the vessel is partially or completely emptied before
being subsequently refilled or degassed.
(b) The IFR is in good condition (i.e., free of defects such as YD N D
corrosion and pools of standing liquid).
(continued)
p|S|13S/lable-7.(W G-37
-------
TABLE 7-4. COMPLIANCE CHECKUST FOR STORAGE VESSELS
(c) Inspect the seal (i.e., if a single-seal system Is used,
inspect the single seal, and if a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the IFR. YD No
(2) There are no holes, tears, or other openings in YD N n
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD No
the wall of the storage vessel.
2. Internal Visual Inspection
(a) The IFR is resting on the liquid surface of the stored YD N D
material, unless the IFR is resting on the leg supports
because the vessel has just been emptied and degassed
or the vessel is partially or completely emptied before
being subsequently refilled or degassed.
(b) The IFR is in good condition (i.e., free of defects such as YD N D
corrosion and pools of standing liquid).
(c) The IFR is equipped with one of the following closure YD N D
devices, between the wall of the storage vessel and the
edge of the IFR: (1) a liquid-mounted seal, (2) a metallic
shoe seal, or (3)'two seals (i.e., a primary and secondary
seal), each of which forms a continuous closure that
completely covers the annular space between the wall of
the storage vessel and the edge of the IFR j
(d) Inspect the seal (i.e., if a single-seal system is used,
inspect the single seal, and if a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the IFR. YD No
(2) There are no holes, tears, or other openings in YD N D
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N D
the wall of the storage vessel.
(e) Inspect deck openings.
(1) If the IFR is non-contact, then each opening in YD N D
the floating roof, except for automatic bleeder
vents and rim space vents, provides a projection
below the stored liquid's surface.1
(continued)
p|s|135rtable-7.04 G-38
-------
TABLE 7-4. COMPLIANCE CHECKUST FOR STORAGE VESSELS
(2) Except for leg sleeves, automatic bleeder vents,
rim space vents, column wells, ladder wells,
sample wells, and stub drains, each opening in
the IFR is equipped with a gasketed cover or lid.k
(3) Each cover or lid on any opening in the IFR is
closed, unless the cover or lid is open for access.
(4) Covers on each access hatch and automatic
gauge float well are bolted or fastened so as to
be air-tight when closed.
(5) The gasket on each cover or lid described in (3)
closes off the liquid surface from the atmosphere.
(f) Inspect automatic bleeder vents.
(1) Automatic bleeder vents are closed, unless the
roof is being floated off or is being landed on the
roof leg supports.
(2) Each automatic bleeder vent is gasketed.k
(3) The gasket on each automatic bleeder vent
closes off the liquid surface from the atmosphere.
(g) Inspect rim space vents.
(1) Rim space vents are closed, except when the
roof is being floated off the roof leg supports or
when the pressure beneath the rim seal exceeds
the manufacturer's recommended setting.
(2) Rim space vents are gasketed.k
(3) The gaskets on the rim space vents close off the
liquid surface from the atmosphere.
(h) Each, sample well (i.e., each penetration of the IFR for
the purpose of sampling), has a slit fabric cover that
covers at least 90 percent of the opening.k
(i) Each penetration of the IFR that allows for passage of a
ladder has a gasketed sliding cover.k
Q) Each penetration of the IFR that allows for passage of a
column supporting the fixed roof has either a flexible
fabric sleeve seal or a gasketed sliding cover.k
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
ND
ND
ND
ND
ND
No
ND
ND
ND
ND
ND
ND
No
(continued)
pjs|135rtable-7.04
G-39
-------
TABLE 7-4. COMPLIANCE CHECKUST FOR STORAGE VESSELS
(k) The gaskets described in (i) and Q) close off the liquid Y o N D
surface to the atmosphere.
(I) If a flexible fabric sleeve seal is used as described in (]), YD N D
the fabric sleeve is free of defects (i.e.. free of holes,
tears, or gaps).
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
CONVERTED TO AN INTERNAL FLOATING ROOF VESSEL
Note: The inspector should be advised of the hazards of inspecting an external floating roof vessel
converted to an internal floating roof vessel that contains a liquid hazardous air pollutant (HAP).
An inspector may perform an external visual inspection of a storage vessel at any time (i.e., the
vessel does not need to be taken out of service). However, the inspector will need to have
proper respiratory protection before opening the roof hatch to visually inspect, from the fixed
roof, the floating deck and seal. An inspector may perform the more thorough internal
inspection only when the vessel has been taken out of service (i.e., emptied, degassed and
cleaned). Unless a vessel is taken out of service more frequently than is required by the HON,
this internal inspection can only take place once every ten years, during those 30 days after
which the State Agency has received notice that the vessel has been emptied and degassed
and will subsequently be refilled. The inspector should never enter a storage vessel to inspect
the floating roof without first consulting documents that address the safety Issues to consider
while entering a confined space and while inspecting an external floating roof vessel converted
to an internal floating roof vessel that contains HAP (e.g., the EPA document 'Confined Space
Safety Document for Conducting NESHAP Compliance Inspections of Benzene Storage
Tanks.')
1. External Visual Inspection
(a) The floating roof is resting on the liquid surface of the YD No
stored material, unless the floating roof is resting on the
leg supports because the vessel has just been emptied
and degassed or the vessel is partially or completely
emptied before being subsequently refilled or degassed.
(b) The floating roof is in good condition (i.e.. free of defects YD N D
such as corrosion and pools of standing liquid).
(c) Inspect the seal (i.e., if a single-seal system is used,
Inspect the single seal, and if a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the floating roof. YD N D
(2) There are no holes, tears, or other openings in YD N D
the seal or seal fabric.
(continued)
pjs)135/table-7.04 G-40
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(3) There are no visible gaps between the seal and YD N a
the wall of the storage vessel.
2. Internal Visual Inspection
(a) The floating deck is resting on the liquid surface of the YD N n
stored material, unless the floating deck is resting on the
leg supports because the vessel has just been emptied
and degassed or the vessel is partially or completely
emptied before being subsequently refilled or degassed.
(b) The floating deck is in good condition (i.e., free of defects YD No
such as corrosion and pools of standing liquid).
(c) The floating deck is equipped with one of the following YD N a
closure devices, between the wall of the storage vessel
and the edge of the floating deck: (1) a liquid-mounted
seal, (2) a metallic shoe seal, or (3) two seals (i.e., a
primary and secondary seal), each of which forms a
continuous closure that completely covers the annular
space between the wall of the storage vessel and the
edge of the floating deck.)
(d) Inspect the seal (i.e., if a single-seal system is used,
inspect the single seal, and if a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the floating deck. YD N D
(2) There are no holes, tears, or other openings in YD N D
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N D
the wall of the storage vessel.
(e) Inspect deck openings
(1) If the floating deck is non-contact, then each YD N D
opening in the floating roof, except automatic
bleeder vents and rim space vents, provides a
projection below the stored liquid's surface.'
(2) Except for automatic bleeder vents, rim space YD N D
vents, roof drains, and leg sleeves, each opening
in the roof is equipped with a gasketed cover,
seal, or lid which forms a vapor-tight seal.
(continued)
p|sj13S/Uble-7.04 G-41
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(3) Each gasketed cover, seal, or lid on any opening YD No
in the floating deck is closed, unless the cover or
lid must be open for access.
(4) Covers on each access hatch and gauge float Y a N a
well are bolted or fastened so as to be air-tight
when closed.
(5) The gasket on each cover, seal, or lid described YD No
in (2) closes off the liquid surface from the
atmosphere.
(0 Inspect automatic bleeder vents
(1) Automatic bleeder vents are closed, unless the YD Nn
roof is being floated off or is being landed on the
roof leg supports.
(2) Automatic bleeder vents are gasketed. YD No
(3) The gaskets on the automatic bleeder vents close YD No
off the liquid surface from the atmosphere.
(g) Inspect rim space vents
(1) Rim space vents are dosed, except when the YD No
roof is being floated off the roof leg supports or
when the pressure beneath the rim seal exceeds
the manufacturer's recommended setting.
(2) Rim space vents are gasketed. YD No
(3) The gaskets on the rim space vents dose off the YD No
liquid surface from the atmosphere.
(h) Each roof drain is covered with a slotted membrane YD No
fabric that covers at least 90 percent of the area of the
opening.
(i) Each unslotted guide pole well has either a gasketed YD No
sliding cover or a flexible fabric sleeve seal.
(j) Each unslotted guide pole shall have on the end of the YD No
pole a gasketed cap which is dosed at all times except
when gauging the liquid level or taking liquid samples.
(continued)
p|s|135A«ble-7.04 G-42
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
(k) Each slotted guide pole well is equipped with the YD No
following equipment: (1) a gasketed sliding cover or a
flexible fabric sleeve seal, and (2) a gasketed float inside
the guide pole or other control device which closes off
the liquid surface from the atmosphere.
0) Each gauge hatch/sample well has a gasketed cover Y o N n
which is closed (except when the hatch or well must be
open for access).
(m) All of the gaskets described in (i), (j), (k), and 0) dose off Y a No
the liquid surface from the atmosphere.
IF THE CONTROL EQUIPMENT IS A CLOSED VENT SYSTEM
(I.E, VAPOR COLLECTION SYSTEM) AND CONTROL DEVICE.
1. There are no visible gaps, holes, or corrosion spots seen in the YD N n
ductwork of the vapor collection system.
2. If the control device is a flare, a device for detecting the flame is YD N n
present.
3. If the control device is not a flare, a device to monitor the YD No
parameter (or parameters) specified in the IP Is present.
4. A flow indicator is present at the entrance to any bypass line that YD No
could divert the vent stream flow away from the control device to
the atmosphere .or all bypass line valves are sealed in a dosed
position (e.g., with a car seal or lock-and-key configuration).
a If an external floating roof has a liquid-mounted or metallic shoe primary seal as of
December 31, 1992, a secondary seal is not required until the next emptying and degassing or
April 22, 2004, whichever is later. For such storage vessels, measurement of gaps in the primary seal
must be conducted once per year until a secondary seal is installed.
b PR = Periodic Report
c NCS = Notification of Compliance Status
d IP = Implementation Plan
e If an enclosed combustion device Is documented to have a minimum residence time of 0.5 seconds
and a minimum temperature of 760°C, then additional documentation is not required.
(continued)
p|si135Aabie-7.04 G-43
-------
TABLE 7-4. COMPLIANCE CHECKLIST FOR STORAGE VESSELS
f If the control device used to comply with the storage vessel provisions is also used to comply with
the process vent, transfer, or wastewater provisions, the performance test required by those
provisions is an acceptable substitute for the design evaluation for determining compliance.
9 A "vapor collection system" is equivalent to a "closed vent system."
n If the external floating roof is equipped, as of December 31, 1992, with either (1) a liquid-mounted
primary seal and no secondary seal, (2) a metallic shoe primary seal and no secondary seal, or (3) a
vapor mounted primary seal and a secondary seal, then the seal requirement of a liquid-mounted or
metallic shoe primary seal and secondary seal does not apply until the earlier of the following dates:
(1) the next time the storage vessel is emptied and degassed, or (2) April 22, 2004.
' If these openings (excluding automatic bleeder vents and rim space vents) did not provide projections
below the liquid service as of December 31,1992, this requirement does not apply until the earlier of
the following dates: (1) the next time the storage vessel is emptied and degassed, or (2) no later than
April 22, 2004.
i If the internal floating roof is equipped, as of December 31,1992, with a single vapor-mounted seal,
then the requirement for a liquid-mounted seal or metallic shoe seal or two seals does not apply until
the earlier of the following dates: (1) the next time the storage vessel Is emptied and degassed, or
(2) April 22, 2004.
k If the internal floating roof did not meet these specifications as of December 15,1992, the requirement
to meet these specifications does not apply until the earlier of the following dates: (1) the next time
the storage vessel is emptied and degassed, or (2) no later than April 22, 2004.
NOTE ALL DEFICIENCIES.
pjs|135rtable-7.04 G-44
-------
TABLE 8-12. COMPUANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
Complete this form for waste management units. A "yes" response to all questions will Indicate full
compliance, and "no" responses will indicate noncompliance except where noted.
I.
REVIEW OF RECORDS
A. WASTEWATER TANKS
1. The occurrence of each semiannual visual Inspection for improper Y a
work practices is recorded.
2. The occurrence of each semiannual visual inspection for control Y o
equipment failures is recorded.
3. For each inspection during which a control equipment failure was
Identified, the following were recorded and reported In the next
PRa
(a) Date of the inspection. Y o
(b) Identification of the wastewater tank having the failure. Y a
(c) Description of the failure. Y D
(d) Description of the nature of the repair. Y a
(e) Date the repair was made. Y a
No
No
No
NO
NO
NO
No
IF THE CONTROL EQUIPMENT IS A FIXED ROOF
Review records listed in Table 8-14.
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND A CLOSED-
VENT SYSTEM ROUTED TO A CONTROL DEVICE
Review records listed in Tables 8-14 and 8-15.
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
1. Review records of Seal Gap Measurements.
(a) Records indicate that seal gap measurements were Y o
performed annually for the secondary seal and every five
years for the primary seal.'5
(b) When a failure is detected, the date and results of seal Y o
gap measurements are submitted in periodic reports,
annually for the secondary seal and every five years for
the primary seal.
No
No
(continued)
p|sJ135Aflble-6.12
G-45
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(c) When a failure is detected in the seal(s), the date and YD No
results of the visual inspection of the seals (which Is
performed together with the seal gap measurement) are
included in the PR.a
(d) The date of the seal gap measurement, the raw data YD No
obtained during the measurement, and the calculations
made are recorded.
(e) The raw data and calculations recorded for seal gap YD No
measurements is consistent with the information provided
in the PR.
(f) For each seal gap measurement in a periodic report, YD No
there is a report notifying the Administrator of the
measurement in advance. If the measurement had been
planned, then the report was submitted 30 days in
advance of the measurement. If the measurement was
not planned, then the report was submitted at least
7 days in advance of the measurement and included an
explanation of why the measurement was unplanned.
(g) If a failure was detected during a seal gap measurement YD N D
and visual seal inspection, the PR indicated the date and
the nature of the repair or the date the wastewater tank
was emptied.
(h) If the report described in (g) documents that the repair Y a No
was made more than 45 days after the failure was
detected, then the next PR includes documentation of the
use of up to two 30-day extensions for completing the
repair, including identification of the wastewater tank, a
description of the failure, documentation that alternate
storage capacity was unavailable, a schedule of actions
to be taken to repair the control equipment or empty the
wastewater tank as soon as possible, and the date the
wastewater tank was emptied and the nature of and date
the repair was made.
2. Review records of internal visual inspections.
(a) The occurrence of each internal visual inspection is YD N D
recorded.
(continued)
p|s|135/l«t>le-fl.12 G-46
-------
TABLE 8-12. COMPUANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(b) For each internal visual inspection in which a failure was YD No
detected, the following information is submitted in the PR:
(1) the date of the inspection, (2) identification of all
wastewater tanks for which failures were detected, (3) a
description of those failures, and (4) either the date and
nature of the repair or the date the wastewater tank was
emptied.
(c) Any repairs performed as described in (b) were YD. N a
completed before the repaired wastewater tank was
refilled.
(d) For each internal visual inspection documented in a PR, YD No
there is a report notifying the Administrator in advance of
the date the inspected wastewater tank would be refilled
after the inspection. If the inspection had been planned,
the report was submitted 30 days in advance of refilling
the wastewater tank. If the inspection was not planned,
then the report was submitted at least 7 days in advance
of refilling the wastewater tank and included an
explanation of why the inspection was unplanned.
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND AN INTERNAL
FLOATING ROOF
1. Review records of external visual inspections
(a) The occurrence of each annual external visual inspection YD N D
is recorded. If the floating roof is equipped with double
seals, the source will not have performed this inspection if
It chose to perform internal visual inspections once every
5 years instead of performing both annual external visual
inspections and internal visual inspections at least once
every 10 years. See Item 2 below.
(b) For each annual external visual inspection in which a Y a N a
failure is detected, the following information is submitted
in the PR: (1) the date of the inspection, (2) identification
of all wastewater tanks for which failures were detected,
(3) a description of those failures, and (4) the date and
the nature of the repair or the date the wastewater tank
was emptied.
(continued)
p|s|135Aat>le-8.12 G-47
-------
TABLE 8-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(c) If the report described in (a) and (b) documents that the YD No
repair was made more than 45 days after the failure was
detected, then the next PR includes documentation of the
use of up to two 30-day extensions for completing the
repair and the following information: identification of the
wastewater tank, a description of the failure,
documentation that alternate storage capacity was
unavailable, a schedule of actions to be taken to repair
the control equipment or empty the wastewater tank as
soon as possible, and the date the wastewater tank was
emptied and the nature of and date the repair was made.
2. Review records of internal visual inspections.
(a) The occurrence of each internal visual inspection is YD No
recorded. If the floating roof is equipped with double
seals and the source chose not to perform annual
external inspections [described in item 1(b)], this
inspection will be performed, recorded, and reported at
least every 5 years.
(b) For each internal visual inspection in which a failure was YD N D
detected, the following information is submitted in the PR:
(1) the date of the inspection, (2) identification of all
wastewater tanks for which failures were detected, (3) a
description of those failures, and (4) the date and nature
of the repair.
(c) Any repairs performed as described in (b) were YD N D
completed before the repaired wastewater tank was
refilled.
(d) For each internal visual inspection documented in a PR, YD N a
there is a report notifying the Administrator in advance of
the date the inspected wastewater tank would be refilled
after the inspection. If the Inspection had been planned,
the report was submitted 30 days in advance of refilling
the wastewater tank. If the inspection was not planned,
then the report was submitted at least 7 days in advance
of refilling the wastewater tank and included an
explanation of why the inspection was unplanned.
(continued)
p|s|135/lable-8.12 G-48
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
IF THE CONTROL EQUIPMENT IS A CLOSED VENT SYSTEM AND
CONTROL DEVICE
Review records listed in Tables 8-14 and 8-15.
B. SURFACE IMPOUNDMENTS
1. The occurrence of each semiannual visual inspection for improper YD No
work practices is recorded.
2. The occurrence of each semiannual visual inspection for control YD No
equipment failures is recorded.
3. For each inspection during which a control equipment failure was
identified, the following were recorded and reported in the next
PRa
(a) Date of the inspection. YD N n
(b) Identification of the surface impoundment having the YD No
failure.
(c) Description of the failure. YD N D
(d) Description of the nature of the repair. YD N D
(e) Date the repair was made. YD N D
[Note: Other recordkeeping requirements may be listed in
Tables 8-14 and 8-15.].
C. CONTAINERS
1.. A record of the capacity of each container at the facility is YD N D
maintained.
2. The occurrence of each semiannual visual inspection for improper YD N D
work practices is recorded.
3. The occurrence of each semiannual visual inspection for control YD N D
equipment failures is recorded.
4. For each inspection during which a control equipment failure was
identified, the following were recorded and reported in the next
PR*
(a) Date of the inspection. YD N D
(b) Identification of the container having the failure. YD N D
(continued)
pjs|135/UDIe-S.12 ' G-49
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(c) Description of the failure. YD N D
(d) Description of the nature of the repair. YD No
(e) Date the repair was made. YD No
[Note: Other recordkeeping requirements may be listed in
Tables 8-14 and 8-15.]
D. INDIVIDUAL DRAIN SYSTEMS
. 1. If the control equipment is a cover and a closed-vent system
routed to a control device:
(a) The occurrence of each semiannual visual inspection for YD N D
improper work practices is recorded.
(b) The occurrence of each semiannual visual Inspection for Y a N a
control equipment failures is recorded.
(c) For each inspection during which a control equipment
failure was identified, the following were recorded and
reported in the next PRa
(1) Date of the inspection. YD N n
(2) Identification of the individual drain system having YD No
the failure.
(3) Description of the failure. YD No
(4) Description of the nature of the repair. YD No
(5) Date the repair was made. YD N D
[Note: Other recordkeeping requirements may be listed
in Tables 8-14 and 8-15.]
2. For drains and junction boxes, as an alternative to Item 1:
(a) A record documents the occurrence of each semiannual YD N D
inspection of drains to ensure that caps or plugs are in
place and properly installed [or (b)]
(b) A record documents the occurrence of each semiannual YD N D
verification of water supply to the drain.
(c) A record documents the occurrence of each semiannual YD N D
Inspection of junction boxes to ensure that a cover is in
place and has a tight seal around the edge.
(continued)
pjsJ135/table-a.12 G-50
-------
TABLE 8-12. COMPUANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(d) A record documents the occurrence of each semiannual YD N o
inspection of the unburied portion of each sewer line for
indication of cracks or gaps.
E OIL-WATER SEPARATORS
1. The occurrence of each semiannual visual inspection for improper YD No
work practices is recorded.
2. The occurrence of each semiannual visual Inspection for control YD N D
equipment failures is recorded.
3. For each inspection during which a control equipment failure was
identified, the following were recorded and reported in the next
PRa
(a) Date of the inspection. Y D No
(b) Identification of the oil-water separator having the failure. YD N D
(c) Description of the failure. YD No
(d) Description of the nature of the repair. YD N D
(e) Date the repair was made. YD N D
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND A CLOSED-
VENT SYSTEM ROUTED TO A CONTROL DEVICE
Review records listed in Tables 8-14 and 8-15.
IF THE CONTROL EQUIPMENT IS A FLOATING ROOF
1. Records indicate that seal gap measurements were performed YD N D
annually for the secondary seal and every five years for the
primary seal.
2. When a failure is detected, the date and results of seal gap YD N D
measurements are submitted In periodic reports, annually for the
secondary seal and every five years for the primary seal.
3. When a control equipment failure is detected In the seal(s), the YD N D
date and results of the visual inspection of the seals (which is
performed together with the seal gap measurement) are included
in the PR.a
(continued)
pjs|135/tat)le-e.12 G-51
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
4. The date of the seal gap measurement, the raw data obtained YD N o
during the measurement, and the calculations made are
recorded.
5. The raw data and calculations recorded for seal gap YD No
measurements is consistent with the information provided in the
PR.
6. If a failure was detected during a seal gap measurement and Y o N a
visual seal inspection, the PR indicated the date and the nature of
the repair or the date the wastewater tank was emptied.
II. VISUAL INSPECTION
A. WASTEWATER TANKS
IF THE CONTROL EQUIPMENT IS A FIXED ROOF
1. All openings (e.g., access hatches, sampling ports, and gauge YD N D
wells) are maintained in a closed, sealed position (e.g., covered
by a lid that is gasketed and latched) when not in use
(e.g., during sampling, equipment maintenance, inspection, or
repair).
[Note: The inspector should also check the fixed roof for leaks in
accordance with the procedures specified In Table 8-14.]
IF THE CONTROL EQUIPMENT IS A FIXED ROOF WTTH A CLOSED-
VENT SYSTEM ROUTED TO A CONTROL DEVICE
1. All openings (e.g., access hatches, sampling ports, and gauge YD No
wells) are maintained in a dosed, sealed position (e.g., covered
by a lid that is gasketed and latched) when not in use
(e.g., during sampling, equipment maintenance, inspection, or
repair).
[Note: The inspector should also check the fixed roof and
closed-vent system for leaks in accordance with the procedures
specified in Table 8-14 and inspect the control device in
accordance with the procedures in Table 8-15.]
(continued)
P|si135/laoie-6.12 G-52
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
IF THE CONTROL EQUIPMENT IS AN EXTERNAL FLOATING ROOF
Note: The inspector should not perform the inspection while on the EFR if the roof is below four feet
of the top of the tank and if the inspector is not equipped with the proper respiratory
protection. Based on the inspector's assessment of the availability of records documenting the
design of the control equipment, an adequate inspection without respiratory protection may be
performed with a combination of a record inspection and a visual inspection conducted from
the platform with the aid of vision-enhancing devices (binoculars).
1. The EFR is resting on the liquid surface of the stored material, YD No
unless the EFR is resting on the roof leg supports because the
wastewater tank has just been emptied and degassed or the tank
is partially or completely emptied before being subsequently
refilled or degassed.
2. The external floating roof is in good condition (i.e., free of defects Y o N a
such as corrosion and pools of standing liquid).
3. There is a secondary seal installed above the primary seal.b Y a No
4. Inspect the secondary seal.b
(a) The secondary seal is continuous and completely covers Y a N a
the annular space between the EFR and the tank wall.
(b) There are no holes, tears, or other openings in the seal or YD No
seal fabric.
(c) There are no visible gaps between the seal and the wall YD N n
of the wastewater tank, except as specified in (e)(1) and
(d) The seal is not detached from the floating deck. YD N D
(e) Perform seal gap measurement of the secondary seal as
specified in §63.120(b)(2)(i) through (b)(2)(iii) and
§63.l20(b)(4) of the HON storage provisions.
(1) The accumulated area of gaps between the tank YD ND
wall and the secondary seal does not exceed
21.2 cm2 per meter of tank diameter.
(2) The maximum gap width between the tank wall YD N D
and the seal does not exceed 1.27 cm.
(continued)
p)3|13S/table-6.12 G-53
-------
TABLE 8-12. COMPUANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
5. Inspect the primary seal.'3
(a) The primary seal is either a metallic shoe seal or a liquid- Y o N D
mounted
(b) The primary seal forms a continuous closure that YD N n
completely covers the annular space between the wall of
the wastewater tank and the edge of the EFR, except as
described in (0(1) and (f)(2).
(c) There are no holes, tears, or other openings in the seal YD N a
fabric, seal envelope, or shoe (if a metallic shoe seal is
used).
(d) If the primary seal is a metallic shoe seal:
(1) The lower end of the metallic shoe send extends YD No
into the stored liquid (no specific distance);
(2) The upper end of the metallic shoe seal extends YD N D
a minimum vertical distance of 61 cm above the
stored liquid surface; and
(3) There is a flexible coated fabric that spans the Y a N a
space between the metal shoe and the tank wall.
(e) If the primary seal is a liquid-mounted seal, the seal is in YD N D
contact with the liquid between the wall of the wastewater
tank and the EFR.
(f) Perform seal gap measurements of the primary seal as
specified In §63.120(b)(2)(i) through (b)(2)(iii) and
§63.120(b)(4) of the HON storage provisions.
(1 ) The accumulated area of gaps between the tank YD N D
wall and the primary seal does not exceed
212 cm2 per meter of tank diameter.
(2) The maximum gap width between the tank wall YD. N D
and the seal does not exceed 3.81 cm.
6. Inspect deck openings.
(a) If the EFR is non-contact, then each opening in the YD N D
floating roof, except automatic bleeder vents and rim
space vents, provides a projection below the stored
liquid's surface.0
(continued)
p|s|135/table-6.12 G-54
-------
TABLE 8-12. COMPUANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(b) Except for automatic bleeder vents, rim space vents, roof Y o No
drains, and leg sleeves, each opening In the roof is
equipped with a gasketed cover, seal, or lid which forms
a vapor-tight seal.
(c) Each gasketed cover, seal, or lid on any opening in the YD N a
EFR is closed, unless the cover or lid must be open for
access.
(d) Covers on each access hatch and gauge float well are Y a N a
bolted or fastened so as to be air-tight when closed.
(e) The gasket on each cover, seal, or lid described In (b) YD N D
closes off the liquid surface from the atmosphere.
7. Inspect automatic bleeder vents.
(a) Automatic bleeder vents are dosed, unless the roof is Y a N a
being floated off or Is being landed on the roof leg
supports.
(b) Automatic bleeder vents are gasketed. YD N D
(c) The gasket on the automatic bleeder vents dose off the YD N D
liquid surface from the atmosphere.
8. Inspect rim space vents.
(a) Rim space vents are dosed, except when the roof is YD N D
being floated off the roof leg supports or when the
pressure beneath the rim seal exceeds the manufacturer's
recommended setting.
(b) Rim space vents are gasketed. YD N D
(c) The gaskets on the rim space vents dose off the liquid YD N D
surface from the atmosphere.
9. Each roof drain Is covered with a slotted membrane fabric that YD N D
covers at least 90 percent of the area of the opening.
10. Each unslotted guide pole well has either a gasketed sliding YD N D
cover or a flexible fabric sleeve seal.
11. Each unslotted guide pole shall have on the end of the pole a YD N D
gasketed cap which is dosed at all times except when gauging
the liquid level or taking liquid samples.
(continued)
p|s|135/tat)le-a.12 G-55
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
12. Each slotted guide pole well is equipped with the following YD Nn
equipment: (1) a gasketed sliding cover or a flexible fabric sleeve
seal, and (2) a gasketed float inside the guide pole or other
control device which closes off the liquid surface from the
atmosphere.
13. Each gauge hatch/sample well has a gasketed cover which is YD No
closed (except when the hatch or well must be open for access).
14. All of the gaskets described in 10 through 13 close off the liquid YD No
surface from the atmosphere.
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND AN INTERNAL
FLOATING ROOF
Note: The inspector should be advised of the hazards of inspecting an internal floating roof vessel
that contains a liquid hazardous air pollutant (HAP). An inspector may perform an external
visual inspection of a wastewater 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 vessel is taken out of
service more frequently than is required by the HON, this internal inspection can only take
place once every ten years, during those 30 days after which the State Agency has received
notice that the tank has been emptied and degassed and will subsequently be refilled. The
inspector should never enter a wastewater 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 IFR that contains HAP (e.g., the EPA document 'Confined Space Safety
Document for Conducting NESHAP Compliance Inspections of Benzene Storage Tanks.")
1. External Visual Inspection
(a) The IFR is resting on the liquid surface of the stored YD Nn
material, unless the IFR is resting on the leg supports
because the vessel has just been emptied and degassed
or the vessel is partially or completely emptied before
being subsequently refilled or degassed.
(b) The IFR is in good condition (i.e., free of defects such as YD N n
corrosion and pools of standing liquid).
(c) Inspect the seal (i.e.. if a single-seal system is used,
inspect the single seal, and if a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the IFR. Y n N n
(continued)
pjs|135/t«t>le-e.12 G-56
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(2) There are no holes, tears, or other openings in YD No
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N n
the wall of the wastewater tank.
2. Internal Visual Inspection
(a) The IFR is resting on the liquid surface of the stored YD No
material, unless the IFR is resting on the leg supports
because the tank has just been emptied and degassed or
the tank is partially or completely emptied before being
subsequently refilled or degassed.
(b) The IFR is in good condition (i.e., free of defects such as YD N n
corrosion and pools of standing liquid).
(c) The IFR is equipped with one of the following closure YD N n
devices, between the wall of the wastewater tank and the
edge of the IFR: (1) a liquid-mounted seal, (2) a metallic
shoe seal, or (3) two seals (i.e., a primary and secondary
seal), each of which forms a continuous closure that
completely covers the annular space between the wall of
the wastewater tank and the edge of the IFR.d
(d) Inspect the seal (i.e.. if a single-seal system is used,
inspect the single seal, and if a double-seal system is
used, inspect both the primary and secondary seals).
(1) The seal is not detached from the IFR. YD ND
(2) There are no holes, tears, or other openings in YD N D
the seal or seal fabric.
(3) There are no visible gaps between the seal and YD N D
the wall of the wastewater tank.
(e) Inspect deck openings.
(1) If the IFR is non-contact, then each opening in YD ND
the floating roof, except for automatic bleeder
vents and rim space vents, provides a projection
below the stored liquid's surface.0
(2) Except for leg sleeves, automatic bleeder vents, YD N D
rim space vents, column wells, ladder wells,
sample wells, and stub drains, each opening in
the IFR is equipped with a gasketed cover or lid.6
(continued)
p|s|135Aat>le-a.12 G-57
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
(f)
(g)
(h)
(i)
0)
(k)
0)
(3) Each cover or lid on any opening in the IFR is YD
closed, unless the cover or lid is open for access.
(4) Covers on each access hatch and automatic Y o
gauge float well are bolted or fastened so as to
be air-tight when closed.
(5) The gasket on each cover or lid described in (3) YD
closes off the liquid surface from the atmosphere.
Inspect automatic bleeder vents.
(1) Automatic bleeder vents are closed, unless the Y a
roof is being floated off or is being landed on the
roof leg supports.
(2) Each automatic bleeder vent is gasketed.6 Y n
(3) The gasket on each automatic bleeder vent Y a
closes off the liquid surface from the atmosphere.
Inspect rim space vents.
(1) Rim space vents are closed, except when the Y a
roof is being floated off the roof leg supports or
when the pressure beneath the rim seal exceeds
the manufacturer's recommended setting.
(2) Rim space vents are gasketed.6 Y a
(3) The gaskets on the rim space vents dose off the Y a
liquid surface from the atmosphere.
Each, sample well (i.e., each penetration of the IFR for Y a
the purpose of sampling), has a slit fabric cover that
covers at least 90 percent of the opening.6
Each penetration of the IFR that allows for passage of a YD
ladder has a gasketed sliding cover.6
Each penetration of the IFR that allows for passage of a YD
column supporting the fixed roof has either a flexible
fabric sleeve seal or a gasketed sliding cover.6
The gaskets described in (i) and (j) close off the liquid Y o
surface to the atmosphere.
If a flexible fabric sleeve seal is used as described in (j), YD
the fabric sleeve is free of defects (i.e., free of holes,
tears, or gaps).
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
(continued)
pjs|135Aable-e.12 G-58
-------
TABLE 8-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
B. SURFACE IMPOUNDMENTS
1. Access hatches and all other openings are dosed and gasketed YD No
when not in Use.
2. All control equipment is functioning properly (e.g., seals, gaskets, Y a N a
joints, lids, covers, and doors are not cracked, gapped, or
broken).
[Note: The inspector should also check the cover and closed-
vent system for leaks in accordance with the procedures in
Table 8-14 and Inspect the control device in accordance with the
procedures In Table 8-15.]
C. CONTAINERS
1. For containers with 0.1 < capacity <0.42 m3.
(a) The container meets existing DOT specifications and YD N n
testing requirements.
(b) The cover and all openings are maintained in a dosed, YD No
sealed position (e.g., covered by a lid that is gasketed
and latched) when not in use (e.g., during filling).
2. For containers with capacity >0.42 m3.
(a) The container is equipped with a submerged fill pipe that YD N D
does not extend more than 6 inches or within two fill pipe
diameters of the bottom of the container while the
container is being filled.
, (b) The cover and all openings, except those required for the YD N a
submerged fill pipe and for venting to prevent damage or
deformation of the container or cover, are closed and
sealed.
3. Whenever a container with capacity >0.1 m3 is open, It is located YD ND
within an enclosure that is routed by a closed-vent system to a
control device.
4. All control equipment is functioning properly (e.g., seals, gaskets, YD No
joints, lids, covers, and doors are not cracked, gapped, or
broken).
(continued)
p|3|135Aat>le-e.12 ' G-59
-------
TABLE 8-12. COMPUANCE CHECKUST FOR WASTE MANAGEMENT UNITS
[Note: The inspector should also check the cover and closed-
vent system for leaks In accordance with the procedures In
Table 8-14 and inspect the control device in accordance with the
procedures in Table 8-15.]
D. INDIVIDUAL DRAIN SYSTEMS
1. If the control equipment is a cover and a closed-vent system
routed to a control device:
(a) The individual drain system is designed and operated to YD N a
segregate the vapors within the system from other drain
systems and the atmosphere through means such as
water seals.
(b) The cover and all openings (e.g., access hatches, YD N D
sampling ports, and gauge wells) are maintained in a
closed, sealed position (e.g., covered by a lid that is
gasketed and latched) when not in use (e.g., during
sampling, equipment maintenance, inspection, or repair).
(c) All control equipment is functioning properly (e.g., seals, YD N D
gaskets, joints, lids, cover^, and doors are not cracked,
gapped, or broken).
[Note: The inspector should also check the closed-vent system
for leaks in accordance with the procedures specified in
Table 8-14 and inspect the control device in accordance with the
procedures in Table 8-15.]
2. For drains and junction boxes, as an alternative to Item 1:
(a) Each drain is equipped with either water seal controls YD N D
(e.g., p-trap, s-trap) or a tightly-sealed cap or plug.
(b) There is water In the p-trap or s-trap. YD N D
(c) If a water seal is used on a drain hub receiving a Group 1 YD N D
process wastewater stream, the drain pipe discharging
the wastewater extends below the liquid surface in the
water seal [or (d)].
(d) A flexible cap (or other enclosure which restricts wind YD N D
motion) is installed that encloses the space between the
drairvdischarging the wastewater and the drain hub
receiving the wastewater.
(continued)
pjs|135/table-e.12 G-60
-------
TABLE 8-12. COMPUANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
(e) Each junction box is equipped with a cover, and, if YD No
vented, is equipped with a vent pipe.
(f) Any vent pipe is at least 90 centimeters in length and YD No
shall not exceed 10.2 centimeters in diameter.
(g) Junction box covers have tight seals around the edge. YD N D
(h) Junction box covers are kept in place at all times except YD N D
during inspection and maintenance.
(i) Each junction box is equipped with a system (e.g., water YD N D
seal controls) to prevent the flow of organic HAP vapors
from the vent pipe to the atmosphere during normal
operation.
(j) The vent pipe is connected to a closed vent system that YD N D
meets the requirements in Table 8-14 and is routed to a
control device that meets the requirements in Table 8-15.
(k) Each sewer line is not open to the atmosphere and is YD N D
covered or enclosed so that no visible gaps or cracks in
joints, seals, or other emission interfaces exist.
E. OIL-WATER SEPARATORS
IF THE CONTROL EQUIPMENT IS A FIXED ROOF AND A CLOSED
VENT SYSTEM ROUTED TO A CONTROL DEVICE
1. All openings (e.g., access hatches, sampling ports, and gauge YD N D
wells) are maintained in a closed, sealed position (e.g., covered
by a lid that is gasketed and latched) when not in use
(e.g., during sampling, equipment maintenance, inspection, or
repair).
2. All control equipment is functioning properly (e.g., seals, gaskets, YD N D
joints, lids, covers, and doors are not cracked, gapped, or
broken).
[Note: The Inspector should also check the fixed roof and
dosed-vent system for leaks in accordance with the procedures
specified in Table 8-14 and inspect the control device in
accordance with the procedures In Table 8-15.]
(continued)
p|s|135/lable-6.12 G-61
-------
TABLE 8-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
IF THE CONTROL EQUIPMENT IS A FLOATING ROOF
Note: The inspector should not perform the inspection while on the floating roof If the roof Is below
four feet of the top of the separator and if the Inspector is not equipped with the proper
respiratory protection. Based on the inspector's assessment of the availability of records
documenting the design of the control equipment, an adequate Inspection without respiratory
protection may be performed with a combination of a record inspection and a visual inspection
conducted from the platform with the aid of vision-enhancing devices (binoculars).
1. The floating roof is resting on the liquid surface of the stored YD N D
material, unless the floating roof is resting on the roof leg
supports because the oil-water separator has just been emptied
and degassed or the tank is partially or completely emptied
before being subsequently refilled or degassed.
2. The floating roof is in good condition (i.e., free of defects such as YD No
corrosion and pools of standing liquid).
3. There is a secondary seal installed above the primary seal. YD N D
4. Inspect the secondary seal.
(a) The secondary seal is continuous and completely covers YD N D
the annular space between the floating roof and the
separator wall.
(b) There are no holes, tears, or other openings in the seal or YD N D
seal fabric.
(c) There are no visible gaps between the seal and the wall YD N D
of the oil-water separator, except as specified in (e)(1)
and (e)(2).
(d) The seal is not detached from the floating deck. YD No
(e) Perform seal gap measurement of the secondary seal as
specified in §60.696(d)(1) of the standards of
performance for VOC emissions.
(1) The total gap area between the separator wall YD No
and the secondary seal does not exceed 6.7 cm2
per meter (0.32 in2/ft) of the separator wall
perimeter.
(2) The maximum gap width between the separator YD N D
wall and the seal does not exceed 1.3 cm (0.5 In)
at any point
(continued)
pjs)135/t«ble-e.12 G-62
-------
TABLE 6-12. COMPLIANCE CHECKUST FOR WASTE MANAGEMENT UNITS
5. Inspect the primary seal.
(a) The primary seal Is a liquid-mounted seal. Ya No
(b) The primary seal forms a continuous closure that YD N a
completely covers the annular space between the wall of
the oil-water separator and the edge of the floating roof,
except as described In (f)(1) and (f)(2).
(c) There are no holes, tears, or other openings In the seal Y a N a
fabric, seal envelope, or shoe (if a metallic shoe seal is
used).
(d) If the primary seal is a liquid-mounted seal (e.g., foam or YD N a
liquid-filled seal), the seal is in contact with the liquid
between the wall of the oil-water separator and the
floating roof.
(e) The seal is not detached from the floating roof. Y a N a
(f) Perform seal gap measurements of the primary seal as
specified in §60.696(d)(1) of the standards of
performance for VOC emissions.
(1) The total gap area between the separator wall YD Nn
and the primary seal does not exceed 67 cnv*
per meter (3.2 in2/ft) of separator wall perimeter.
(2) The maximum gap width between the separator YD N D
wall and the seal does not exceed 3.8 cm (1.5 in)
at any point
6. If the floating roof Is equipped with one or more emergency roof YD N D
drains for removal of stormwater, each emergency roof drain is
fitted with a slotted membrane fabric cover that covers at least
90 percent of the drain opening area or a flexible fabric sleeve
seal.
7. All openings in the floating roof are equipped with a gasketed YD N D
cover, seal, or lid, which is maintained in a closed position at all
times, except during inspection and maintenance.
8. No gaskets, joints, lids, covers, or doors are cracked, gapped, or YD N D
broken.
a PR = Periodic Report
(continued)
p)s|135/table-fl.12 G-63
-------
TABLE 8-12. COMPLIANCE CHECKLIST FOR WASTE MANAGEMENT UNITS
b If the external floating roof is equipped, as of December 31, 1992, with either: (1) a liquid-mounted
primary seal and no secondary seal, or (2) a vapor mounted primary seal and a secondary seal, then
the seal requirement of a liquid-mounted or metallic shoe primary seal and secondary seal does not
apply until the earlier of the following dates: (1) the next time the storage vessel is emptied and
degassed, or (2) April 22, 2004. For such wastewater tanks, measurements of gaps in the primary
seal must be conducted once per year until a secondary seal is installed.
c If these openings (excluding automatic bleeder vents and rim space vents) did not provide projections
below the liquid service as of December 31, 1992, this requirement does not apply until the earlier of
the following dates: (1) the next time the storage vessel is emptied and degassed, or (2) no later than
April 22, 2004.
d If the internal floating roof is equipped, as of December 31,1992, with a single vapor-mounted seal,
then the requirement for a liquid-mounted seal or metallic shoe seal or two seals does not apply until
the earlier of the following dates: (1) the next time the storage vessel is emptied and degassed, or
(2) April 22, 2004.
6 If the internal floating roof did not meet these specifications as of December 15, 1992, the requirement
to meet these specifications does not apply until the earlier of the following dates: (1) the next time
the storage vessel is emptied and degassed, or (2) no later than April 22, 2004.
NOTE ALL DEFICIENCIES.
pjs|135Aaeie-8.12 G-64
-------
TABLE 8-13. COMPUANCE CHECKUST FOR TREATMENT PROCESSES
Complete this form for treatment processes. A "yes" response to all questions will indicate full
compliance, and "no" responses will indicate noncompliance except where noted.
Note: The HON does not specify a particular treatment process that must be used to achieve
compliance. The source may use any waste management unit or treatment process to achieve
compliance with one of the control options (or a combination of control options). If the source
elects to use a design steam stripper, the HON does specify operating parameters in
§63.138(g) of Subpart G. These operating parameters are included In this checklist.
TREATMENT PROCESS
DATE OF STARTUP
I. REVIEW OF RECORDS
FOR ALL TREATMENT PROCESSES
1a. Identification and description of the treatment process, YD Nn
identification of the wastewater streams treated by the
process, and identification of monitoring parameters were
included in the NCS.a
1 b. If a treatment process other than the design steam stripper YD No
is used, the request to monitor site-specific parameters was
included in the Implementation Plan or operating permit
application.
2. Documentation to establish a site-specific range was Y o N a
submitted in the NCS or operating permit application.
3. Results of the initial measurement of the parameters Y o No
approved by the Administrator were submitted in the NCS or
operating permit application.
4. Records of a design evaluation and supporting Y a N a
documentation that includes operating characteristics were
included in the NCS [or #5).
5. Records of performance tests conducted using test methods YD No
and procedures specified in §63.145 of Subpart G were
included in the NCS.
(continued)
p)s|135/table-fl.13 G-65
-------
TABLE 8-13. COMPLIANCE CHECKUST FOR TREATMENT PROCESSES
[Note: The records described in #4 and #5 are not required if the
wastewater stream or residual is discharged to: (1) a hazardous
waste incinerator permitted under 40 CFR Part 270 and complying
with 40 CFR Part 264 Subpart O; (2) an industrial furnace or boiler
burning hazardous waste that is permitted under 40 CFR Part 270
and complying with 40 CFR Part 266, Subpart H; (3) an industrial
furnace or boiler burning hazardous waste for which the owner or
operator has certified compliance with the interim status
requirements of 40 CFR Part 266 Subpart H; or (4) an underground
injection well permitted under 40 CFR Part 270 or 40 CFR Part 144
and complying with 40 CFR Part 122.]
6. Records described in #4 and #5 demonstrate that the level YD N n
of treatment required by §63.l38(b) and /or (c) is achieved.
7. Results of visual inspections, in which a control equipment
failure was identified, were reported in the PRb, including:
(a) Identification of the treatment process, YD N D
(b) Description of the failure, YD N D
(c) Description of the nature of the repair, and YD N D
(d) Date the repair was made. YD N D
8. For each parameter approved by the permitting authority
that Is required to be monitored continuously:
(a) Records of the daily average value of the parameter YD N D
are kept.
(b) Each operating day, when the daily average value of YD N D
the parameter was outside the site-specific range
established in the NCS (i.e., a monitoring parameter
excursion is detected), or when insufficient
monitoring data are collected, they are reported in
the PR.
9. For each treatment process that receives a residual removed
from a Group 1 wastewater stream, the following were
submitted in the NCS:
(a) Identification of treatment process; YD N D
(b) Identification and description of the residual; YD N D
(c) Identification of wastewater stream from which YD N D
residual was removed;
(continued)
Pis|135rtable-8.13 G-66
-------
TABLE 8-13. COMPUANCE CHECKUST FOR TREATMENT PROCESSES
(d)
(e)
Fate of residual;
Identification and
description of control device (if
YD
YD
ND
ND
any) used to destroy the HAP mass in the residual
by 99 percent; and
(f) Documentation of the 99 percent control efficiency YD N D
of the device in (e).
10. Records show that residuals are in compliance with control YD ND
options in §63.138(h) of Subpart G.
FOR DESIGN STEAM STRIPPERS
1. Records are kept of the steam flow rate, wastewater feed YD N D
mass flow rate, and wastewater feed temperature.
2. If the parameters in #1 are not monitored, the facility has YD N D
documentation that they applied for and received approval
to monitor alternative parameter(s) and are performing the
required record keeping and reporting.
[Note: If #2 is checked "Yes", the facility is in compliance
even if number 1 is checked "No".]
FOR BIOLOGICAL TREATMENT UNITS
1. Records are kept of appropriate monitoring parameters that YD N D
were approved by the permitting authority.
2. Records are kept of the bench-scale or pilot-scale test using YD N D
Method 304 (or any other method approved by the EPA) in
conjunction with a wastewater model (e.g., WATER?,
BASTE, TOXGHEM, or any other model validated by
Method 301).
II. VISUAL INSPECTION
FOR ALL TREATMENT PROCESSES
1. Each opening in the treatment process (except biological YD N D
treatment systems) is covered and vented to a closed-vent
system that is routed to a control device.
2. Any associated closed-vent system is in compliance with the YD N D
HON according to the checklist in Table 8-14.
(continued)
p|s|135Aflt>le-8.13 ' G-67
-------
TABLE 8-13. COMPUANCE CHECKUST FOR TREATMENT PROCESSES
3. Any associated control device is in compliance with the YD No
HON according to the checklist in Table 8-15.
4. Each cover is kept closed and is in compliance with the YD No
HON according to the checklist in Table 8-14.
FOR DESIGN STEAM STRIPPERS
1 . The minimum active column height is at least 5 meters. Y a N a
2. The counter-current flow configuration has a minimum of YD N D
10 actual trays.
3. The minimum steam flow rate Is 0.04 kilograms of steam per YD No
liter of wastewater feed.
4. The minimum wastewater feed temperature to the steam YD N a
stripper is 95 °C.
5. The maximum liquid loading is 67,100 liters per hour per YD N o
square meter.
6. The minimum steam quality is 2,765 kiloJoules per kilogram. YD N D
7. Associated waste management units, closed-vent systems, YD N D
and control devices meet the requirements in Tables 8-12,
8-14, and 8-15.
FOR BIOLOGICAL TREATMENT UNITS
The treatment process is in compliance with all visual YD N D
inspection parameters approved by the permitting authority
and/or specified in the operating permit.
a NCS = Notification of Compliance Status.
b PR = Periodic Report
NOTE ALL DEFICIENCIES
Pts|135/table-6.13 G-68
-------
TABLE 8-14. COMPLIANCE CHECKUST FOR CONTROL EQUIPMENT REQUIRING
LEAK DETECTION8'1*
Complete this form for closed-vent systems. A "yes" response to all questions will indicate full
compliance, and "no" responses will indicate noncompliance except where noted.
CONTROL OR RECOVERY DEVICE '
DATE OF STARTUP
I. REVIEW OF RECORDS
IF THE CONTROL EQUIPMENT IS A VAPOR-COLLECTION
SYSTEM, CLOSED-VENT SYSTEM, COVER, ENCLOSURE,
OR FIXED ROOF
1. Records are kept of all parts of any vapor-collection Y a No
system, closed-vent system, fixed roof, cover, or
enclosure that are designated as either unsafe-to-
inspect or dtfficult-to-inspect.
2. For equipment that is designated as difficult to inspect, Y a N a
a written plan is kept that requires inspection of
equipment at least once every five years.
3. For equipment that is designated as unsafe to inspect, YD No
a written plan is kept that requires inspection of
equipment as frequently as practicable.
4. For each inspection during which a leak was detected,
the following information is recorded and reported.0
(a) .Instrument identification numbers, operator YD No
name or initials, and equipment identification
information;
(b) The date the leak was detected and the date of YD N n
the first attempt to repair it;
(c) Maximum instrument reading after, the leak is YD No
repaired or determined to be non-repairable;
(d) Explanation of delay in repair, if the leak was YD No
not repaired within 15 days after it was
discovered;
(e) Name or initials of person who decides repairs YD N D
cannot be made without a shutdown;
(continued)
G-69
-------
TABLE 8-14. COMPUANCE CHECKLIST FOR CONTROL EQUIPMENT REQUIRING
LEAK DETECTION
(f) Expected date of successful repair if not YD No
repaired within 15 days;
(g) Dates of shutdowns that occur while the YD N o
equipment Is unrepaired; and
(h) Date of successful repair of the leak. YD N n
5. For each inspection during which no leaks were
detected, the following records are kept:
(a) Record that the Inspection was performed; YD N o
(b) Date of the inspection; and YD N n
(c) Statement that no leaks were found. YD N o
IF THE CONTROL EQUIPMENT IS A VAPOR COLLECTION
SYSTEM OR CLOSED-VENT SYSTEM
1. Hourly records are kept of whether the flow indicator in YD N D
the bypass line was operating and whether flow was
detected at any time during the hour, when seal
mechanisms are not used and
2. The time and duration of all periods when flow is YD N D
diverted or the monitor is not operating are reported0
when seal mechanisms are not used [or #3 and #4]
3. Records of monthly visual inspections are kept when YD N D
seal mechanisms are used and
4. All periods when the seal mechanism is broken, the YD N D
bypass line valve position has changed, or the key to
unlock the bypass line valve was checked out are
recorded and reported0 when seal mechanisms are
used.
[Note: In order to be in compliance with provisions for
bypass lines, either: #1 and #2 must both be checked
yes' or both #3 and #4 must be checked "yes'.]
II. VISUAL INSPECTION
Visual inspection of the facility is consistent with written YD N D
records.
(continued)
G-70
-------
TABLE 8-14. COMPUANCE CHECKLIST FOR CONTROL EQUIPMENT REQUIRING
LEAK DETECTION
IF THE CONTROL EQUIPMENT IS A VAPOR-COLLECTION
SYSTEM OR CLOSED-VENT SYSTEM
A flow indicator is present at the entrance to any YD No
bypass line that could divert the vent stream flow away
from the control device to the atmosphere or all bypass
line valves are sealed in a closed position (e.g., with a
car seal or lock-and-key configuration).
8 This checklist Is not applicable to closed-vent systems that are subject to §63.172 in the negotiated
rule for equipment leaks (40 CFR Part 63 Subpart H) because such closed-vent systems are exempt
from the requirements in §63.148 of Subpart G of the HON.
b This checklist is not applicable to vapor-collection systems, closed-vent systems, covers,
enclosures, and fixed roofs that are operated and maintained under negative pressure.
c Information is submitted as part of the reports required by §63.182(b) of Subpart H.
NOTE ALL DEFICIENCIES
p|s)135/table-fl.14 G-71
-------
TABLE 8-15. COMPLIANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
Complete this form for wastewater control devices. A "yes* response to all questions will indicate full
compliance, and "no* responses will indicate noncompliance with the standard except where noted.
CONTROL OR RECOVERY DEVICE
DATE OF STARTUP
I. REVIEW OF RECORDS
IF THE CONTROL DEVICE IS A FLARE
1. Results of the initial test were submitted in the NCS.a YD N a
2. The presence of a continuous flare pilot flame is monitored Y n N a
using a device designed to detect the presence of a flame.
3. All periods when all pilot flames to a flare were absent or the YD No
monitor was not operating have been recorded and
reported in the PR.b
4. If the presence of a continuous flare pilot flame is not
monitored, either:
(a) The facility has documentation that they applied for YD No
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD No
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD No
level or reading for each operating day.
(d) All daily average concentration levels or readings YD No
that are outside the site-specific range are reported
in the PR.b
IF THE CONTROL DEVICE IS A THERMAL INCINERATOR
1. Results of the initial performance test were submitted in the Y a N D
NCS.a
2. Test documentation demonstrates 95 percent HAP or TOC YD No
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
(continued)
p]s)135/table-fl.15 G-72
-------
TABLE 8-15. COMPUANCE CHECKUST FOR WASTEWATER CONTROL DEVICES
3. A temperature monitoring device equipped with a YD No
continuous recorder is used to measure the temperature of
the gas stream in the firebox (or in the ductwork
immediately downstream of the firebox before any
substantial heat exchange occurs).
4. Documentation to establish a site-specific range for firebox YD N a
temperature was submitted in the NCSa or operating permit
application.
5. Continuous records0 of firebox temperature are kept YD N D
6. Records of daily average firebox temperature are kept. YD N D
7. All daily average firebox temperatures that are outside the YD N D
site-specific established range and all operating days when
insufficient monitoring data are collected are reported in the
PR.b
8. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.^
9. If the firebox temperature is not monitored, either
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
inthePR.b
[Note: If #9(a) is checked "Yes", or 9(b), 9(c). and 9(d) are
checked "Yes", the facility is in compliance even if numbers
3 through 8 are checked "No".]
IF THE CONTROL DEVICE IS A CATALYTIC INCINERATOR
1. Results of the initial performance test were submitted in the YD N D
NCS.a
(continued)
p|s|135/table-6.15 G-73
-------
TABLE 8-15. COMPLIANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
2. Test documentation demonstrates 95 percent HAP or TOC YD No
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
3. Temperature monitoring devices equipped with continuous Y a N a
recorders are used to measure the temperature in the gas
stream immediately before and after the catalyst bed.
4. Documentation to establish a site-specific range for the gas YD No
stream temperature upstream of the catalyst bed and the
temperature difference across the bed was submitted in the
NCSa or operating permit application.
5. Continuous records0 are kept of the temperature of the gas YD N o
stream upstream of the catalyst bed and the temperature
difference across the catalyst bed.
6. Records of the daily average temperature upstream of the YD N D
catalyst bed and the temperature difference across the
catalyst bed are kept.
7. All daily average upstream temperatures that are outside the YD N D
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
8. All daily average temperature differences across the catalyst YD N D
bed that are outside the site-specific range and all operating
days when insufficient monitoring data are collected are
reported in the PR.b
9. The number of excursions does not exceed the number of YD N D
excused excursions in the semi-annual reporting period.0'
10. If the temperature upstream of the catalyst bed and/or the
temperature differential across the catalyst bed are not.
monitored, either
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(continued)
p)s|135/tabl
-------
TABLE 8-15. COMPLIANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
(d) All daily average concentration levels or readings YD No
that are outside the site-specific range are reported
in the PR.b
[Note: If #lO(a) is checked Yes", or 10(b), 10(c), and 10(d)
are checked "Yes*, the facility is In compliance even If
numbers 3 through 9 are checked "No".]
IF THE CONTROL DEVICE IS 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
1. Results of the Initial performance test were submitted In the YD N D
NCS.a
2. A description of the location at which the vent stream is YD N D
introduced into the boiler or process heater was submitted
in the NCS.a
3. The vent stream is Introduced into the flame zone of the YD N D
boiler or process heater.
4. Test documentation demonstrates 95 percent HAP or TOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
5. A temperature monitoring device equipped with a YD N D
continuous monitor is used to measure the temperature of
the gas stream in the firebox.
6. Documentation to establish a site-specific range for firebox YD N D
temperature was submitted in the NCSa or operating permit
application.
7. Continuous records0 are kept of the firebox temperature. YD N D
8. Records of the daily average firebox temperature are kept YD N D
9. All daily average firebox temperatures that are outside the YD N D
site-specific range and all operating days when insufficient
monitoring data are collected are reported in the PR.b
10. The number of excursions does not exceed the number of YD ND
excused excursions in the semi-annual reporting period.0'
(continued)
p|j|135/lable-6.1S G-75
-------
TABLE 8-15. COMPLIANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
11. If the firebox temperature is not monitored, either:
(a) The facility has documentation that they applied for YD No
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting cir continue with
questions f(b) and (c) and (d)].
(b) Continuous records are kept of the concentration Y a N a
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N a
level or reading for each operating day.
(d) All daily average concentration levels or readings YD No
that are outside the site-specific range are reported
in the PR.b
[Note: If #11 (a) is checked "Yes", or 11 (b), 11(0). and n(d)
are checked "Yes*, the facility is in compliance even if
numbers 5 through 10 are checked "No".]
IF THE CONTROL DEVICE IS A BOILER OR PROCESS HEATER
WITH A DESIGN HEAT INPUT CAPACITY GREATER THAN
44 MEGAWATTS
1. A description of the location at which the vent stream Is YD N D
introduced into the boiler or process heater was submitted
in the NCS.a
2. The vent stream is introduced into the flame zone of the YD N D
boiler or process heater.
IF THE CONTROL DEVICE IS A REGENERATIVE CARBON
ADSORBER
la. Results of the initial performance test were submitted In the YD No
NCS.a
1 b. Test documentation demonstrates 95 percent HAP orTOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
(continued)
pjs|135Aat>le-fl.15 G-76
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TABLE 8-15. COMPLIANCE CHECKUST FOR WASTEWATER CONTROL DEVICES
2. An integrating regeneration stream (e.g., steam) flow Y a N a
monitoring device having an accuracy of jMO percent and
capable of recording total regeneration stream mass flow for
each regeneration cycle is used to measure regeneration
stream flow.
3. A carbon bed temperature monitoring device capable of YD No
recording the carbon bed temperature after each
regeneration and within 15 minutes of completing any
cooling cycle is used to measure carbon bed regeneration
temperature.
4. Documentation to establish a site-specific range for the YD N a
regeneration stream flow and carbon bed regeneration
temperature was submitted in the NCSa or operating permit
5. Records are kept of the total regeneration stream mass flow YD N a
for each carbon bed regeneration cycle.
6. Records are kept of the temperature of the carbon bed after YD N a
each carbon bed regeneration.
7. All regeneration cycles when the total regeneration stream YD N a
mass flow is outside the site-specific range are reported in
the PR.b
8. All regeneration cycles during which the temperature of the YD No
carbon bed after regeneration is outside the site-specific
range are reported in the PR.*3
9. If the regeneration stream flow and/or the carbon bed
regeneration temperature are not monitored, either:
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting or continue with
questions [(b) and (c) and (d)).
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
(continued)
p|s|135/«atjle-8.15 G-77
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TABLE 8-15. COMPLIANCE CHECKLIST FOR WASTEWATER CONTROL DEVICES
[Note: If #9(a) is checked "Yes", or 9(b), 9(c), and 9(d) are
checked "Yes*, the facility is in compliance even if numbers
2 through 8 are checked "No*.]
IF THE CONTROL DEVICE IS A CONDENSER
la. Results of the Initial performance test were submitted In the YD Na
NCS.a
1 b. Test documentation demonstrates 95 percent HAP orTOC YD N D
control efficiency or test documentation demonstrates outlet
concentrations of 20 ppmv or less HAP or TOC.
2. A temperature monitoring device equipped with a YD N D
continuous recorder is used to measure the product side
exit temperature.
3. Documentation to establish a site-specific range for the exit YD N D
temperature was submitted in the NCSa or operating permit
4. Records of the daily average exit temperature are kept YD N D
5. Continuous records0 of the exit temperature are kept YD N D
6. All product side daily average exit temperatures that are YD N D
outside the site-specific range are reported in the PR.b
7. If the exit temperature is not monitored, either.
(a) The facility has documentation that they applied for YD N D
and received approval to monitor an alternative
parameter, and are performing the required
recordkeeping and reporting .or continue with
questions [(b) and (c) and (d)].
(b) Continuous records are kept of the concentration YD N D
level or reading indicated by an organic monitoring
device at the outlet of the control device.
(c) Records are kept of the daily average concentration YD N D
level or reading for each operating day.
(d) All daily average concentration levels or readings YD N D
that are outside the site-specific range are reported
in the PR.b
[Note: If #7(a) Is checked "Yes", or 7(b). 7(c). and 7(d) are
checked "Yes", the facility is In compliance even if numbers
2 through 6 are checked *No".]
(continued)
pjs)135/table-a.15 G-78
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TABLE 8-15. COMPLIANCE CHECKUST FOR WASTEWATER CONTROL DEVICES
II. VISUAL INSPECTION
1. For flares, a device for detecting the flame is present. YD No
2. For all incinerators, and for boilers and process heaters with YD N D
design heat input capacities less than 44 megawatts and the
vent steam is not introduced with the primary fuel, a
temperature monitoring device is present.
3. For carbon adsorbers, a device for measuring carbon bed YD No
temperature and a device for measuring regeneration
stream flow are present.
4. For condensers, a temperature monitoring device Is present YD N D
5. Visual inspection of the facility is consistent with written YD N D
records.
a NCS = Notification of Compliance Status.
b PR = Periodic Reports.
c Continuous records, as defined in §63.111, means documentation, either in computer readable
form or hard copy, or data values measured at least once every 15 minutes and recorded at the
frequency specified in §63.152(0. Section 63.152(0 allows the owner to record either values
measured every 15 minutes or 15-minute (or shorter period) block average values calculated from
all measured values during each period. If the daily average value of a monitored value for a given
parameter is within the range established in the NCS, the owner or operator may retain block hourly
averages instead of the 15-minute values. An owner or operator may request approval to use
alternatives to continuous monitoring under §63.151 (g) of Subpart G.
d The number of excused excursions is as follows:
For the first semi-annual period after the NCS is due - 6 excursions;
For the second semi-annual period - 5 excursions;
For the third semi-annual period - 4 excursions;
For the fourth semi-annual period - 3 excursions;
For the fifth semi-annual period - 2 excursions;
For the sixth and all subsequent semi-annual periods -1 excursion.
An excursion occurs when: (1) the daily average value of the monitored parameter Is outside the
range established in the NCS or operating permit; or (2) if monitoring data are insufficient. In order
to have sufficient data, a source must have measured values for each 15-minute period within each
hour for at least 75 percent of the hours the control device is operating In a day. For example, if a
control device operates 24 hours per day, data must be available for all 15-minute periods in at
least 18 hours; but up to 6 hours may have incomplete data. If more than 6 hours have incomplete
data, an excursion has occurred. For control devices that operate less than 4 hours a day, one
hour of incomplete data is allowed.
(continued)
pjs|135/table-e.15 G-79
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TABLE 8-15. COMPUANCE CHECKUST FOR WASTEWATER CONTROL DEVICES
NOTE ALL DEFICIENCIES
p)s)13S/lable-e.15 G-80
-------
TABLE 8-16. COMPLIANCE CHECKLIST FOR HEAT EXCHANGE SYSTEMS
REQUIRING LEAK DETECTION
Complete this form for closed-vent systems. A "yes" response to all questions will indicate full
compliance, and 'no* responses will indicate noncompliance except where noted.
HEAT EXCHANGE SYSTEM
DATE OF STARTUP
Note: Sources are not required to comply with leak detection monitoring requirements If either
(1) the heat exchange system is operated with the minimum pressure on the cooling water side
at least 35 kilopascals greater than the maximum pressure on the process side; or (2) the
once-through heat exchange system has an NPDES permit with an allowable discharge limit of
less than 1. ppm.
I. REVIEW OF RECORDS
la. For once-through heat exchange systems, records indicate YD N n
that systems are monitored for leaks of HAPs listed on
Table 9 of Subpart G.
1 b. For recirculating heat exchange systems, records indicate YD No
that systems are monitored for leaks of HAPs listed on
Table 2 of Subpart F, except for benzotrichloride (98077),
bis(chloromethyl)ether (542881), maleic anhydride
(108316), and methyl isocyanate (624839).
2. If there is a delay of repair of a leak, the following
information was reported in the PRa and maintained as a
record.
(a) Identification of the leak and date the leak was YD No
detected.
(b) Whether or not the leak has been repaired. YD ND
(c) Reason for delay of repair. YD N o
(d) The expected date of repair if the leak remains YD N a
unrepaired.
(e) The date of repair, if the leak is repaired. YD N a
II. VISUAL INSPECTION
Visual inspection of the facility is consistent with written YD N D
records.
a PR = Periodic Reports.
(continued)
p|s)135/lflble-8.l6 G-81
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TABLE 8-16. COMPLIANCE CHECKLIST FOR HEAT EXCHANGE SYSTEMS
REQUIRING LEAK DETECTION
NOTE ALL DEFICIENCIES
p|s|135Aable-6.16 G-82
-------
TABLE 8-17. COMPUANCE CHECKUST FOR MAINTENANCE WASTEWATER MANAGEMENT
Complete this form for maintenance wastewater management activities. A'yes" to all questions will
indicate full compliance, and "no" responses will indicate noncompliance except where noted.
MAINTENANCE WASTEWATER STREAM
DATE OF STARTUP '
I. REVIEW OF RECORDS
1. Records are kept of the procedures for managing YD No
maintenance wastewater as part of the startup, shutdown,
and malfunction plan.
2. The maintenance procedures specify the following items:
(a) The process equipment and/or maintenance tasks Y a N a
that are expected to create wastewater during
maintenance activities.
(b) The procedure for properly managing the YD N n
wastewater and controlling HAP emissions to the
atmosphere.
(c) The procedures for clearing materials from process YD No
equipment.
II. VISUAL INSPECTION
All maintenance wastewater streams are being managed in YD N n
accordance with the procedures specified in the start-up,
shutdown, and malfunction plan.
NOTE ALL DEFICIENCIES
p]s|13S/lot)le-e.17 G-83
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