DRAFT COPY
ENVIRONMENTAL PROTECTION AGENCY
[40 CFR Part 60]
Standards of Performance for New Stationary Sources
VOC Fugitive Emission Sources in
Synthetic Organic Chemicals Manufacturing Industry
AGENCY: Environmental Protection Agency (EPA)
ACTION: Proposed Rule and Notice of Public Hearing
SUMMARY: The proposed standards would limit emissions of volatile
organic compounds (VOC) from fugitive emission sources in the Synthetic
Organic Chemicals Manufacturing Industry (SOCMI). These standards would
(1) require a leak detection and repair program to reduce emissions from
valves in VOC (volatile organic compounds) service, and (2) specify the
inclusion of certain equipment to reduce emissions from pumps, compressors,
sampling connections, and open-ended lines in VOC service. The proposed
standards would also prohibit leaks from safety/relief valves during
normal operations. Some control equipment would be required to meet
specified design criteria and other control equipment would be subject
to operational requirements.
The proposed standards implement the Clean Air Act and are based
on the Administrator's determination that fugitive emission sources of
VOC in SOCMI contribute significantly to air pollution. As required by
Section 111 of the Clean Air Act, the proposed standards are intended
to require new, modified, and reconstructed facilities.in SOCMI to
use the best demonstrated system of continuous emission reduction,
considering costs, non-air quality health and environmental impacts, and
energy impacts.
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A public hearing will be held to provide interested persons an
opportunity for oral presentation of data, views, or arguments concerning
the proposed standards.
DATES: Comments. Comments must be received by (60 days
after publication in the FEDERAL REGISTER).
Public Hearing. A public hearing will be held about 30 days after
proposal beginning at a.m. and ending before p.m.
Request to Soeak at Hearing. Persons wishing to present oral
testimony must contact EPA one week before the hearing.
ADDRESSES: Comments. Comments should be submitted (in duplicate
if possible) to: Central Docket Section (A-130), Attention: Docket No.
A-79-32, U.S. Environmental Protection Agency, 401 M Street S.W.,
Washington, O.C. 20460.
Public Hearing. The public hearing will be held at
. Persons wishing to present oral testimony should
notify Ms. Shirley Tabler, Standards Development Branch (MO-13),
Environmental Protection Agency, Research Triangle Park, North Carolina
27711, telephone number (919) 541-5421.
Background Information Document. The Background Information Document
(BID) for the proposed standards may be obtained from the U.S. EPA
Library (MD-35), Research Triangle Park, North Carolina 27711, telephone
number (919) 341-2777. Please refer to VOC Fugitive Emissions In Synthetic
Organic Chemicals Manufacturing Industry - Background Information "or
Proposed Standards.
Docket. Docket No. A-79-32, containing supporting infomation used
in developing the proposed standards, is available for public inspection
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and copying between 8:00 a.m. and 4:00 p.m., Monday through Friday, at
EPA's Central Docket Section, Room 2903B, Waterside Mall, 401 M Street,
S.W., Washington, O.C. 20460. A reasonable fee may be charged for copying.
FOR FURTHER INFORMATION CONTACT: Susan Wyatt, Emission Standards
and Engineering Division (MD-13), Environmental Protection Agency, Research
Triangle Park, North Carolina 27711, telephone number (919) 541-5477.
SUPPLEMENTARY INFORMATION:
PROPOSED STANDARDS
The proposed standards of performance would apply to process units
that are operated to produce one or more of 378 specific organic chemicals.
The proposed standards would require: (1) the implementation of a leak
detection and repair program for in-line and open-ended valves in gas and
light liquid service; (2) the use of certain equipment with various
fugitive emission sources; and (3) no detectable VOC (volatile organic
compound) emissions from safety/relief valves during normal operation.
Implementation of the proposed standards would reduce fugitive emissions
of VOC from pumps, compressors, valves, sampling connections, safety/
relief valves, and open-ended lines in VOC service. VOC service means that
a fugitive emission source contains or contacts a process fluid composed of
equal to or greater than 10 percent VOC by weight if the process fluid is a
liquid, or equal to or greater than 10 percent VOC by volume if the process
fluid is a gas.
The proposed standards include a leak detection and repair program
that would require monthly monitoring for in-line and open-ended valves
in gas and light liquid service. This monitoring would be conducted in
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accordance with Method 21. For valves that leak (defined as a detected
VOC concentration equal to or greater than 10,000 parts per million by
volume (ppmv) the proposed standards would require repair within 15 days
after detection of the leak. An initial attempt at repairing these
valves would be required within 3 days after detection of a leak. Delay
of repair of a leaking valve beyond 15 days after detection could be
requested if shutdown of the process unit is required for repair.
The proposed standards would require the utilization of certain
equipment with pumps, compressors, sampling connections, safety/relief
valves, and open-ended lines. The proposed standards would require pumps
in "light liquid" service (liquids with a vapor pressure greater than
0.3 kPa at 20°C) to be equipped with double mechanical seals that include
a static or flow-through barrier fluid system between the seals. Each
barrier fluid system would be equipped with a pressure sensor so that
failure of the inner and/or outer seals could be detected. In addition,
each barrier fluid system would be operated at a pressure greater than
the pump discharge pressure or be equipped with a barrier fluid degassing
reservoir. The degassing reservoir would be connected, by a closed
vent system, to either an enclosed combustion device having a minimum
VOC residence time of 0.5 seconds at 760°C or to a vapor recovery system
capable of capturing 95 percent of the VOC entering the system. The
proposed standards would also require weekly visual inspections of the
seals on light liquid pumps in order to identify failure of the outer
seal. Upon visual detection of a laak, instrument monitoring of the
source would be required. If monitoring of the source indicated a laak
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(defined as a concentration equal to or greater than 10,000 ppmv VOC),
repair of the pump would be required within 15 days after the leak was
detected. The first attempt at repairing the pump would be required
within 3 days after detection of the leak.
The proposed standards would require compressors to be equipped with
seals having a static or flow-through barrier fluid system that prevents
leakage of the process fluid to the atmosphere. These standards would also
require each barrier fluid system to either operate at a pressure greater
than the compressor discharge pressure or be equipped with a barrier
fluid degassing reservoir. The degassing reservoir would be connected
by a closed vent system to either an enclosed combustion device having
a minimum VOC residence time of 0.5 seconds at 760°C or a vapor recovery
system capable of capturing 95 percent of the VOC entering the system.
The proposed standards would require each barrier fluid system to be
equipped with a pressure sensor so that seal failures may be detected.
When seal failure is detected, repair would be required within 15 days.
An initial .attempt at repair would be required within 3 days. If a
compressor could not be equipped with a barrier fluid system, a closed
vent system would be required to transport leakage from the seal to an
enclosed combustion source or vapor recovery system.
The proposed standards would require that VOC's purged from sampling
connections be recycled to the process or collected in a closed disposal
system. A closed sampling loop could be used to recycle purged VOC's and
reduce fugitive emissions from sampling connections.
For safety/relief valves, the proposed standards would require that
each valve have no detectable VOC emissions except in cases of emergency
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overpressure relief. After aach overpressure relief, the proposed
standards would require the safety/relief valves to be returned to a
state of no detectable emissions within 3 days. Open-ended lines would
be required to be sealed with a second valve, cap, blind flange or plug.
The valve, cap, blind flange, or plug could be opened or removed only
when the open-ended line is placed into service.
Cooling towers, agitator seals, and components containing fluids
that have less than 10 percent VOC would be excluded from the requirements
of the proposed standards. Flanges, safety/relief valves in liquid .
ser/ice, and all equipment components in "heavy liquid" service (liquids
with vapor pressure less than 0.3 kPa at 20"C) would be excluded from
the routine monitoring requirements of the proposed standards. If YOG
leaks were visually or otherwise detected from any of these sources, the
15 day repair requirements of the proposed standards would apply.
Compliance status would be determined by reviewing the installation
of specified equipment and by reviewing the implementation of the leak
detection and repair program. Recordkeeping and reporting requirements
would be used in assessing compliance. To meet these requirements, the
owner/opera tor 'would record the presence of any source that is found to
be exceeding the 10,000 ppmv leak definition as well as the concentration
detected after it had been repaired. The owner/opera tor would request a
delay for those leaks that could not be repaired within the 15 day
rapair interval without a process unit shutdown. The owner/operator
would also submit a quarterly signed statement declaring that all monitoring
had been performed in accordance with the standards all specified equipment
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had been installed and operated in accordance with the standards, and
all emission limits had been met. This report would allow enforcement
personnel to assess compliance of affected facilities with the standards.
Under the proposed standards, any owner or operator of a facility
that would be subject to the standards could request the Administrator
to determine the equivalence of any alternative means of emission limitation
to the controls or work practices specified by the standards. Upon receiving a
request for determination of equivalence, the Administrator would provide
an opportunity for public hearing. After such a hearing, the Administrator
would make a decision and publish his decision in the Federal Register.
To determine the equivalence of these alternative means of emission
limitations to equipment requirements, the Administrator would compare
emission test data for the alternative means of emission limitation and
similar data for equipment required by the standards. Collection and
verification of emission test data would be the responsibility of the
applicant. Upon making his decision, the Administrator could also require ,.„
that design or operational specifications be implemented to assure
proper operation and maintenance of the alternative means of emission
limitation.
To determine the equivalence of the alternative means of emission
limitation to work practices specified by the proposed standards, the
Administrator would compare emission test data for the alternative means
of emission limitation and the work practices required by the standards.
The emission data for both the alternative means of emission limitation
and work practices would reflect a minimum of 12 months of implementation.
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The applicant would be responsible for collecting and verifying the
emission data. The Administrator could require that design or operational
specifications be implemented to assure proper operation and maintenance
of the alternative means of emission limitation.
SUMMARY OF ENVIRONMENTAL, ENERGY, AND ECONOMIC IMPACTS
The proposed standards of performance would reduce fugitive emissions
of VOC from new process units in SOCMI by approximately 87 percent. Over
a five-year period (1981-1985), the proposed standards would reduce the
total uncontrolled fugitive emissions from new process units from
approximately 330 to 80 gigagrams (Gg). This reduction is based on an
annual growth rate in equipment inventories of 5.9 percent and an annual
equipment replacement based on twenty year equipment life.
The proposed standards of performance would not significantly
increase the energy usage of SOCMI process units because, in general, the
controls required by the standards do not require much energy. Implemen-
tation of the proposed standards could result in a minor impact on
wastewatar and solid wasta.
The proposed standards would require, on an industry-wide basis,
a capital investment ranging from S41 million in 1981 to $52 million in
1985. The total industry-wide capital investment over the five-year
period would be approximately $232 million. The industry-wide net
annualizad cost would range from about 52 million in 1981 to about
Sll million in 1985. This net annualizad cost reflects the credit
resulting from "recovered" fugitive emissions.
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RATIONALE
SELECTION OF SOURCES AND POLLUTANTS
The Synthetic Organic Chemicals Manufacturing Industry (SOCMI) is
comprised of all process units which produce, (as intermediates of final
products), any of the 378 chemicals presented in Appendix E of the
proposed 40 CFR 60.48. These chemicals are manufactured in a multi-
level system of chemical processes that is based on ten petroleum-
derived feedstock chemicals. These feedstocks proceed through one or
more process levels to produce the 378 chemical products which comprise
SOCMI. These 378 chemicals then are used for fabrication and manufacturing
in eight basic industries which include plastics, fibers, surfactants,
Pharmaceuticals, elastomers, dyes, pesticides, and specialty organics.
Although sixty percent of SOCfll's production volume is produced in
Texas and Louisiana, SOCMI units are located in most industrialized
areas of the country. In general, SOCMI is comprised of large processing
complexes which are frequently located in or near population centers in
the U.S. However, SOCMI units may be located away from population centers.
Furthermore, this industry is expanding at a growth rate of 5.9 percent
annually.
The Priority List, 40 CFR 60.16, identifies various sources of
emissions on a nationwide basis in terms of the quantities of emissions
from source categories, the mobility and competitive nature of each source
category, and the extent to which each pollutant endangers health or
welfare. The sources on the priority list are ranked in decreasing order.
The SOCMI source category has been ranked first on the final priority
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list (44 FR 49222, August 21, 1979) of 59 major source categories
for Mew Source Performance Standards (NSPS) development.
Pollutants emitted from SOCMI include particulates, volatile organic
compounds (VOC), nitrogen oxides (NO ), sulfur oxides (SOJ, sulfurlc acid
/x /\
(rLS04) and hydrochloric acid (HCL) as '-veil as other chemicals. Emissions of
particulates, NO and SO from this industry are regulated under combustion
and process standards that have been or may be developed. Total VOC
emissions from stationary sources in this country are approximately
19,000 gigagrams per year (Gg/yr). The total VOC emissions from SOCMI -.-
are about 1,000 Gg/yr or 5 percent of the national total. The potential
sources of VOC emissions in this industry include process sources, storage
and handling equipment sources, fugitive emission sources, and secondary
\
emission sources. It is estimated that approximately 200 Gg/yr of the
total emissions of VOC from SOCMI (or about 20 percent) are attributable
to fugitive emission sources.
The VOC's that would be regulated by the proposed standards are
compounds which can be measured by the applicable test methods described
in Method 21. Compounds excluded from this definition are methane, ethane,
methyl chloroform, and trichlorotrifluoroethane. Specific VOC's which
the Administrator lists as hazardous air pollutants 'would be covered by
Section 112 of the Clean Air Act. The 200 Gg/yr of VOC's emitted from
SOCMI contribute to atmospheric photochemical reactions0 that aroduca
photochemical oxidants which could have adverse health effects. Sinca
fugitive anissions of VOC from SOCMI contribute to the production of
3hotochemical oxidants, the Administrator is affirming the decision to
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list SOCMI as a category of stationary sources that, in his judgment,
cause or significantly contribute to air pollution which may reasonably
be anticipated to endanger public health or welfare.
SELECTION OF REGULATORY APPROACH AND AFFECTED FACILITIES
The Synthetic Organic Chemicals Manufacturing Industry (SOCMI) is
composed of a large number of process units which produce or consume
many different organic chemical compounds. Two general regulatory
approaches could be used in developing standards for SOCMI. The first
approach involves the development of standards applicable to each specific
chemical process; this approach has historically been used in developing
air pollution regulations. The second approach involves the development
of standards on the basis of similar types of unit operations, emission
sources, and applicable emission control techniques. The second approach
was selected for development of the proposed standards for SOCMI because
it is the most effective way to regulate a large number of process units
that produce a diverse range of products. Because these process units
have similar fugitive emission sources, the available emission control
techniques should be applicable to all of the industry population.
Therefore, a single regulation could be developed for controlling fugitive
emissions from the entire industry.
Affected facilities for fugitive emissions standards could be
defined as individual emission sources (equipment components), groups of
equipment components that are operated in conjunction with each other
(process units), or groups of process units at one location (plant sites).
The rationale for selection of the definition of affected facilities is
influenced by the provisions of 40 CFR 60.2 (aa), 60.14(a), and 50.15.
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An existing facility, as defined in 40 C?R 60,2(aa), is a facility
that was constructad or modified before the proposal data of the appli-
cable standards of performance. However, an existing facility that is
modified or reconstructed after the date of proposal of the standards
becomes an affected facility and then is subject to applicable standards
of performance.
Modification is defined in 40 CFR 60.14(a) as any physical or
operational change of an existing facility which increases the emission
rate of any pollutant to which a standard applies. Exemptions to this ""•
definition include an increase in production rate, if such an increase
can be made without capital expenditure; an increase in the hours of
operation; the use of an alternative fuel or raw material; the addition
of air pollution control equipment; and routine maintenance, repair, and
replacement.
Reconstruction is defined in 40 CFS 50.15 as any replacement of
components in an existing facility where the fixed capital cost of the
new components exceeds 50 percent of the fixed capital cost that would
be required to construct a comparable entirely new facility. Fixed capital
cost means the capital needed to provide all depreciable components of the
facility. Under such conditions, an existing facility becomes an affected
facility.
Sinca the provisions of any standards promulgated under the authority
of Section 111 of the Clean Air Act apply to new, modified, and recon-
structed facilities, the definition of the affected facility will influence
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the sources covered by the standards. If the affected facilities
were designated on the basis of individual equipment components, any
replacement of an equipment component (pump, valve, etc.) would be
considered a new source and would be subject to the new source standards.
This would result in situations where replaced equipment components in
existing process units would be subject to new source standards, while
adjacent components would not be subject to the standards. Determining
which components were subject to requirements of the standards could be
difficult for the owner/operator as well as for enforcement personnel.
Furthermore, emission control techniques such as equipment specifications
can be taken into account during the design phase of new process unit
construction. In cases of replacement of components in existing process
units, these equipment specifications may be inappropriate. Emission
control work practices are not well suited for application to a few
widely scattered sources within a process unit, but are designed for
systematic application to all sources within the unit.
Process units are any combination of piping, pumps, valves, compressors,
or any other process equipment that is operated in concert to produce,
treat, separate, transport, modify or otherwise process organic chemicals.
Designating affected facilities on the basis of process units combines
individual emission sources into a unified group. If affected facilities
were defined as process units, any simple replacement of equipment com-
ponents within an existing unit would not increase the overall emission rate,
and would be a small capital expenditure compared to the cost of the entire
unit. Therefore, the unit would not be subject to the standards due to
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fnodification or reconstruction considerations. If equipment components were
to be added to an existing process unit and if the amiss ion increase caused
by the addition cou.ld be offset by adding emission controls to any emission
sources within the unit, the existing unit would not be considered a new
facility under considerations of modification. If the emission increase
could not be offset, the existing unit would be considered a new facility.
Affected facilities could also be defined on the basis of plant
sites. A plant site consists of one or more process units at the same
geographical location. If affected facilities were defined as plant "
sites, construction of new process units at existing sites would make the
entire site subject to the standards because of modification considerations.
This restriction is an unreasonable burden for owner/operators that have
existing plant sites that may consist of many process units. If an entire
process unit was replaced within an existing plant site, no emission increase
would result, and therefore the unit and site would not be subject to the
standards under modification considerations. If the plant site consisted
of many process units, the replacement of one unit would probably not
exceed 50 percent of the replacement cost of the affected facility (plant
site), and therefore the unit and site would not be subject to the
standards under reconstruction considerations. This could result in
situations where new process units could be built that would not be subject
to new source standards.
For the proposed standards, process units were selected as "he basis
for defining affected facilities. This definition allows existing sources
to expand without the restriction of existing process uni~s being subject
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to NSPS while also providing for full coverage by NSPS of all new process
units. This definition also provides for the most reasonable and
straightforward application of the provisions of modification and recon-
struction. It also provides for the most reasonable application of the
available control techniques for fugitive emission sources.
SELECTION OF REGULATORY ALTERNATIVES
Fugitive emissions of VOC can be reduced by two types of control
techniques: (1) implementation of leak detection and repair programs
and (2) compliance with equipment, design, and operational specifications.
Four regulatory alternatives which would achieve different levels of
emission reduction using various combinations of leak detection and repair
programs and equipment, design, and operational requirements were developed.
Control Techniques
The leak detection and repair programs included in the various
regulatory alternatives consist of two phases. The initial phase involves
monitoring potential fugitive emission sources in a process unit to detect'
fugitive emissions of VOC. After detection of the leak, the source would
be repaired or replaced in order to reduce the emissions. Several leak
detection methods were considered in the development of the regulatory
alternatives. These methods include the use of VOC detection instruments
and soap bubble solutions to locate individual leaking sources.
Furthermore, the methods include periodic monitoring for leaking sources
on an individual component or an area basis and continuous automatic
instrument monitoring of ambient air at multiple sites within a facility.
As detailed in the Selection of Test Methods, the individual component
survey with a portable VOC detection instrument would be the leak
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detection method for the proposed standards. This method would incorporate
the use of a portable VOC detector to regularly monitor sources for
fugitive emissions of VOC. The VOC concentration at the surface of each
source would be monitored with the portable instrument. The effectiveness
of an individual source leak detection program would depend on the
frequency of the monitoring schedule; more frequent monitoring would
allow more frequent maintenance and a corresponding reduction in fugitive
emissions. The frequencies of the monitoring schedules would vary for
aach regulatory alternative.
Repair or replacement of a source would be required within a specified
period of tine after the detection of a VOC concentration equal to or in
excess of a predetermined level. These repair and replacement procedures
would vary for each source. Fugitive emissions from packed seals on a
pump or compressor for example could be reduced by tightening the packing
gland. However, the packing could deteriorate to a point where further
tightening would no longer reduce, but instead, would increase the
emission rate. At this point, the packing would have to be replaced.
Mechanical seals on pumps and compressors would need to be removed for
repair. Replacement of these seals would be an alternative to their repair.
The repair of a leaking safety/relief valve normally requires that
it be removed from service. To facilitate the removal of a relief valve
without necessitating a orocass shutdown would require the use of a block
valve upstream of the relief valve.
Most process valves have a packing gland which could be tightened
while the valve is in ser/ice. Tightening of .the packing gland would
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normally reduce fugitive emissions from a leaking valve, but the emission
rate could increase if the packing is old and brittle or if the packing
were to be overly tightened. When this occurs, the packing would have
to be replaced. Plug valves may be repaired by addition of grease.
Some valves could not be repaired while in service. These valves
include control valves, which may be excluded from in-service repair by
operating or safety considerations, and block valves, whose removal for
repair or replacement might require a process shutdown. Other valves,
such as control valves with a manual bypass loop, could be isolated for
repair or removal.
Leaks from flanges could often be reduced by tightening of the flange •
bolts. Most flanges could not be isolated from the process to permit
replacement of the gasket.
In addition to a leak detection and repair programm emissions could
be reduced by requiring certain equipment. Equipment specifications were
considered for the following fugitive emission sources in the development
of the regulatory alternatives: pumps, compressors, pressure relief
devices, open-ended lines, sampling connections, and valves.
Fugitive emissions from pumps occur primarily at the pump seal. These
emissions could be reduced by implementation of the following equipment
specifications: use of seal!ess pumps, replacement of existing seals with
improved seals (e.g., double mechanical seals), or collection and control
of emissions with closed vent systems. Because of process condition
limitations, sealless pumps are not suitable for all pump applications.
Double mechanical seals are currently used in many SOCMI process applications,
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These seals characteristically include a barrier fluid between the
seals. YOC's could leak into the barrier fluid and later omitted to the
atmosphere through degassing vents on the barrier fluid reservoir.
Connecting the degassing vents to a control device (enclosed combustion or
vapor recovery system) could effectively control fugitive emissions
originating from double mechanical seals. The control efficiency varies
with the condition of the double mechanical seal and the type of control
device used, but control efficiencies of approximately 100 percent can
be achieved. Consequently, a system combining double mechanical seals and
degassing vents connected to a control device was considered as the equipment
specification for pumps.
Emissions from compressors also occur primarily at the seal. A
closed vent system or replacement of the seal with an improved seal
(double mechanical) could be specified to reduce emissions from compressors.
The use of double mechanical seals on compressors and connection of the
barrier fluid reservoir to a control device (enclosed combustion or vapor
recovery system) with a closed vent system would provide control efficiencies
approaching 100 percent. Therefore, a system combining double mechanical
seals and controlled degassing vents or controlled seal area vents was
considered as the equipment specification for compressors.
Safety/relief valves may emit fugitive VOC due to defects in valve
seating surfaces, improper reseating after relieving, or process operating
near the relief valve sat point. Equipment specifications for control ling
fuaitive VOC emissions from relief valves include closed vent systams
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connected to a control device or rupture disks upstream of safety/relief
valve.
A closed vent system can be used to transport the relief valve
discharge (and fugitive emissions) to a control device such as a flare.
These types of systems are currently used in SOCMI process units; however,
under certain applications, such as flaring halogenated compounds, these
systems could result in emissions which may be less desirable than the
VOC emissions. The control efficiency of a closed vent and control device
system is mostly dependent on the effectiveness of the control device.
For example, a closed vent system is about 100 percent effective in VOC
capture, and a typical flare process is about 60 to 99 percent effective
for VOC destruction; thus the overall efficiency is about 69-99 percent,
depending on the turn-down capability of the flare.
Rupture disks can be installed upstream of safety-relief valves to .
prevent the emission of VOC's through the valve seat. The use of a
rupture disk upstream of a safety/relief valve can result in no detectable
emissions from the valve. Consequently, rupture disks were considered as
the equipment specification for safety/relief valves.
When process samples are taken for analysis, obtaining a representa-
tive stream sample requires purging some process fluid through the sample .
connection, this sample purge could be vented to the atmosphere if
the fluid were gaseous, and liquid sample purges could be drained onto
the ground or into open collection systems where evaporative emissions could
result. Fugitive emissions from sampling connections can be reduced by
using a closed-loop sampling system that eliminates atmospheric purging
of process material.
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Fugitive emissions from open-ended lines can be controlled by
installing a cap, plug, blind flange, or second valve on the open end of
the line. Capping of open-ended lines and closed-loop sampling represent
readily available equipment specifications that have been applied in
SOCMI and exhibit control efficiencies of approximately 100 percent.
The actual control efficiencies will depend on site specific factors.
Because these devices are demonstrated technology and their control
efficiencies are very high, caps, plugs, blinds, or valves were considered
for equipment specifications for open-ended lines, and closed-loop .
sampling was considered for sampling connections.
Fugitive emissions from valves occur at the stem or gland area of
the valve body.. These emissions could be controlled by using diaphragm
valves which have formed metal bellows that makes a barrier between the
disc and body bonnet joint. Although the control effectiveness of
diaphragm or bellows seal valves is about 100 percent, their use is
limited by the strength of the diaphragm. Because the application of
diaphragm valves would be limited to certain service, no equipment
specifications were considered for valves in the regulatory alternatives.
Exclusions
The proposed standards would exclude flanges, relief valves in
liquid service, and all components in "heavy liquid" (fluids with vapor
pressures lass than 0.3 kPa at 20°C) service. However, if leaks ara
detactad from these sourcas, the same allowable repair interval would
apply. These sourcas were axcluded from monitoring on the basis of data
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from EPA testing in petroleum refineries. Flanges in refineries have
very low emission rates, and although they represent 61 percent of the
total sources in refineries, their total contribution to overall emissions
is about 2.2 percent. In EPA testing of fugitive emission sources in
refineries, safety/relief valves in liquid service also exhibited very low
emission rates. These valves contribute only 0.2 percent of all emissions
from refineries. Components in "heavy liquid" service have emission rates
that are much lower than "light liquid" or gas service components. Since
all three of these types of sources contribute a very small portion of
overall emissions, including them in the monitoring and equipment require-
ments was not considered reasonable.
Regulatory Alternatives
Four regulatory alternatives, which achieve different levels of
emission reduction by using various combinations of leak detection and
repair programs and equipment specifications, were considered in the
development of the proposed standards. Regulatory Alternative I is the
baseline alternative and represents the level of control that would exist
in the absence of any standards of performance. Under Alternative I, SOCMI
facilities located in (oxidant) pollutant standard attainment areas would
not be subject to any VOC fugitive emission regulations; however, facilities
in nonattainment areas would be subject to applicable SIP regulations.
Only a few states have developed or are considering near-term development
of these specific regulations. Under Alternative I, fugitive emissions
of VOC could also be controlled to some extent by OSHA health standards or
controls based on provisions of insurance policy for fire and or explosion
orotaction.
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Regulatory Alternative II includes the same monitoring requirements
and equipment specifications included in the petroleum refinery Control
Techniques Guidelines (CTG) document. These requirements and specifi-
cations are:
• Quarterly monitoring of all in-line valves, open-ended
valves and safety/relief valves in gas service (relief
valves would also be monitored after overpressure
relieving to check for proper reseating);
• Annual monitoring of all in-line valves and open-ended
valves in light liquid service;
• Quarterly monitoring of compressor seals;
• Annual monitoring of light liquid service pumps (such pumps
would also be inspected"visually for liquid leaks each week;
immediate instrument monitoring of visually leaking pumps
would be required); and
• Installation of caps, blinds, plugs, or second valves to
seal all open-ended lines.
Regulatory Alternative III specifies a more frequent equipment
monitoring schedule than Regulatory Alternative II and thus provides for
more stringent control of fugitive emissions of VOC. For instance,
Regulatory Alternative III would require monthly, rather than quarterly
or annual monitoring. Monthly monitoring would result in a reduction
of emissions from residual leaking sources, i.e., those sources which
are found to be leaking and are repaired but begin to leak again before
the next inspection and those previously non-leaking sources that begin
leaking between inspections. Alternative III would also reauira the
use of caps, plugs, or second valves on open-ended lines.
22
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Of the four alternatives, Regulatory Alternative IV would provide
the greatest level of control for fugitive emissions of VOC through the
use of equipment specifications. The implementation of equipment speci-
fications for the various potential fugitive emission sources would lessen
the need for periodic monitoring. The monitoring and equipment speci-
fications requirements of Regulatory Alternative IV are:
• Monthly monitoring of all in-line valves and open-ended
valves in gas and light liquid service;
• Installation of rupture disks upstream of gas service
safety/relief valves that vent to the atmosphere (the
disk would be replaced if disk failure were detected);
• Installation of closed vents and control devices for
compressor seal areas and/or degassing vents from
compressor seal oil reservoirs;
• Installation of double mechanical seals on pumps in
light liquid service and installation of closed vent
control devices for degassing vents from seal oil
reservoirs of all pumps in light liquid service (weekly
visual inspections of pumps in light liquid service
would also be required, with subsequent instrument
monitoring required for those pumps with visible liquid
leaks);
• Installation of closed loop sampling systems; and
• Installation of caps, blinds, plugs, or second valves to seal
all open-ended lines.
SELECTION OF BASIS FOR THE PROPOSED STANDARD
Selection of a regulatory alternative as the basis for the proposed
standards was based upon consideration of the estimated fugitive emission
reduction, energy savings or usage, and cost and economic impacts. SOCMI
with approximately 1680 operating process units in the United States in
1980, is projected to grow at an annual rate of 5.9 percent. Based on
this growth rate, approximately 2240 process units will be in operation in
24
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1985. Approximately 330 of these facilities would be subject to the
proposed standards in 1985 .due to new construction, reconstruction, or
modification considerations. Of this total, about 560 facilities would
be newly constructed and subject to the standards on this basis. The
remaining 270 facilities would be replaced or modified to the extent that
they would be subject to the standards under construction or modification
considerations.
Regulatory Alternative II would reduce fugitive emissions of VOC
from the 330 affected facilities in 1985 from an uncontrolled level of
200 Gg/yr to approximately 73 Gg/yr, or by 63 percent. The YOC's recovered
in 1985 as the result of implementing Alternative II would have an
energy content equivalent to 650,000 barrels of crude oil. The total
energy associated with a YOC being processed is made up of the energy
value of the compound and the energy expended to process (condense, pump,
vaporize, etc.) the compound. The total energy associated with the VOC
would be lost if the VOC were to leak to the atmosphere. This energy
loss would be reduced if the VOC were combusted in an enclosed combustion
system because some of the energy released during combustion could be
recovered. If the VOC could be kept within the process and sold as
product, the energy loss would be eliminated. Alternative II reduces the
energy loss that would result in the absence of any standards.
During the first five years after implementation of Regulatory Altar-
native II, SOCMI's cumulative capital costs would be 321 minion. In the
fifth year, Alternative II would result in an annual 1 zed net credit of
S29 .Trillion due to the value of the recovered oroduct. Imolanentation of
25
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Regulatory Alternative II could have a slight positive impact on waste-
water from SOCMI facilities because leak detection would result in the
identification and repair of liquid VOC leaks, and therefore, reduction
of VOC's in wastewater from SOCMI facilities. This alternative would have
no impact on any solid wastes associated with SOCMI.
Regulatory Alternative III would result in a fugitive emission rate
of approximately 62 Gg/yr from the 830 affected facilities in 1985; this
represents a 69 percent reduction in the baseline, or Regulatory
Alternative I, level. The VOC's "recovered" in 1985 due to the imple-
mentation of Alternative III would have energy content equivalent to
700,000 barrels of crude oil. Consequently, Alternative III, like
Alternative II, reduces the energy loss that would result from SOCMI
in the absence of any standards. SOCMI would incur cumulative capital
costs of $21 million under this alternative. However, due to the
increased cost of implementing a more frequent monitoring schedule of
Regulatory Alternative III would result in an annualized net credit of
$21 million in 1985. Regulatory Alternative III would have the same
potential positive impact on wastewater from SOCMI facilities as
Alternative II, and no impact on solid waste.
Regulatory Alternative IV would reduce fugitive emissions of VOC
from the 830 affected facilities in 1985 to 26 Gg/yr; this represents an
87 percent reduction from the Regulatory Alternative I level. The VOC's
recovered in 1985 due to the implementation of Alternative IV would have an
energy content approximately equivalent to 880,000 barrels of crude oil.
Alternative IV would minimize the energy loss that would result from SOCMI
in the absence of any standards.
26
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For Alternative IV the capital costs would be about 552 million in
1985. The net annualized cost for this alternative would be $11 million
in 1985. These costs should not significantly increase the prices of
SOCMI products. Implementation of Regulatory Alternative IV could have
a slight positive impact on wastewater for the same reasons as Alternatives
II and III. A wastewater containing suspended solids and some solid
waste could result from the use of various control processes with the
equipment specifications implemented under this alternative. However,
the impact of these waste streams would be slight. Solid waste impact-.
would also be minimal.
As the above data show, Regulatory Alternative IV would achieve the
greatest reduction of VOC fugitive emissions. The costs, energy require-
ments, and non-air environmental impacts of Alternative IV would be
similar to those of the other alternatives. Based on this information,
Alternative IV was selected as the basis for the proposed standards of
performance for SOCMI.
SELECTION OF FORMAT FOR THE PROPOSED STANDARDS
Several formats could be used to implement Regulatory Alternative IV.
Section 111 of the Clean Air Act requires that a standard of performance be
prescribed unless, in the judgement of the Administrator, it is not feasible
to prescribe or enforce that standard. If a standard of performance is
not feasible, the Administrator may instead promulgate a design, equipment,
work practice, or operational standard, or combination thereof as provided
in Section m(h)(l). The formats that could be specified for Regulatory
Alternative IV 'would include all of these formats.
27
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For design and equipment standards, additional conditions are required by
Section lll(h)(l). Performance standards may not be feasible to prescribe
for some SOCMI process unit VOC fugitive emission sources due to the
provisions of Section lll(h)(2)(B): The application of measurement
methodology to a particular class of sources is not practicable due to
technological or economic limitations. For these classes of sources,
other formats must be selected. Section lll(h)(3) requires the
Administrator to allow the use of alternative means of emission limitation
for classes of sources not covered by a performance standard. The
alternative means of emission limitations must achieve a reduction in
emissions at least equivalent to the reduction in emissions achieved by
the controls implemented under equipment, design, operational, or work
practice standards.
For fugitive emission sources, performance standards could specify
emission limits or allowable numbers of leaking sources. Emission limits
could be specified for individual sources or for the entire population of
sources. For Regulatory Alternative IV, the only controls that have a
proven achievable performance level are rupture disks for safety/relief
valves. The rupture disk will prevent any emissions except during
overpressure relief. A pressure sensor between the disk and the relief
valve is needed in order to assure that the disk integrity is maintained.
For this control method, an emission limit for each individual source
can be specified, and emission limits were selected as the format for
the proposed standards for safety/relief valves.
28
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The other controls specified under Regulatory Alternative IV do not
have a documented control efficiency, and therefore emission limits
cannot be specified for these controls. A performance standard based on
an allowable number of sources leaking above a particular rate would be
possible if sufficient data were available for estimation of "average"
control efficiency for a large population of emission sources. This
would avoid the problems associated with specification of emission limits
for controls that may have variable control efficiency for individual
sources. The allowable number of leaking sources could be determined
by assessment of test data for the specified control methods when applied
to a spectrum of SOCMI process unit variations. The allowable number of
leaking sources could also be determined by comparison to the control
level achieved by applying the specified controls at a site. The problem
with determining an appropriate performance level is that a lot of time and
expense would be necessary for.testing to establish achievable control
levels. Although a performance standard would allow flexibility for
achieving the control level, it would not provide for any greater control
than the controls specified in Alternative IV.
Equipment specifications are the best format for sources where
control equipment is available and applicable, and the control efficiency
for individual sources may be different, depending on site specific
factors. Control equipment for pumps, compressors, open-ended lines and
sampling connections were identified and evaluated. Although the
achievable efficiency for these controls is not documented, the equipment
29
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should be applicable to nearly all SOCMI sources. Equipment specifications
were selected as the format for the proposed standards for pumps,
compressors, open-ended lines, and sampling connections.
Work practices can be specified for sources where achievable performance
is not known and equipment specifications are not feasible. The highly
variable emission rate from individual valves precludes the specification
of emission limits, and achievable performance levels such as number
of leaking sources are not well documented. Equipment specifications for
valves would be very expensive, and would not be applicable for some
SOCMI sources. Therefore the only viable format for the proposed
standards for valves is work practices.
Design standards were selected for application to the control
equipment specifications for pumps and compressors. The design requirements
are necessary in order to assure that the emissions collected by the
control equipment specifications are adequately recycled or incinerated.
Operational standards were selected for certain applications of control
equipment specifications for open-ended lines. The operational requirements
are necessary to prevent emissions as a result of improper operation of the
control equipment.
The proposed standards incorporate all of the potential regulatory
formats. Different formats are required for different classes of sources
because characteristics of the emission sources and the available
emission control options differ among the sources. Emission limit
performance standards were selected for safety/relief valves. Equipment
30
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specifications were selected for pumps, compressors, open-ended lines and
sampling connections and work practices were selected for valves.
SELECTION OF EMISSION LIMITS, EQUIPMENT SPECIFICATIONS
WORK PRACTICES, DESIGN CRITERIA AND OPERATIONAL REQUIREMENTS
The regulatory formats selected for the proposed standards include
emission limits, equipment specifications, work practices, design criteria
and operational requirements. In implementing the requirements of Regulatory
Alternative IV, the requirements of Section lll(h) of the Clean Air Act
must be considered. This section states that if the Administrator judges
that a standard of performance is not feasible to prescribe or enforce, the
Administrator may promulgate a design, equipment, work practice, or
operational standard, or combination thereof. Design and equipment
standards must also include requirements that assure proper operation and
maintenance of the design or equipment. For each fugitive emission
source, several options which could satisfy the requirements of Section
lll(h) were evaluated. These options and the relative advantages and
disadvantages of each option are discussed below. Selection of the best
option is also discussed.
Numerical Emission Limits
Section lll(h) requires that a standard of performance be promulgated
unless it fs not feasible to prescribe or enforce. Thus control techniques
included in Regulatory Alternative IV were first evaluated to determine if
a standard of performance could be promulgated. The only control
techniques that nave a demonstrated achievable level of control are the
contra! techniques for safety/relief valves. The control tachniaues
31
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for other fugitive emission sources are not definable in terms of standards
of performance.
Rupture disks were evaluated as the control equipment specification
for gas service safety/relief valves under Regulatory Alternative IV.
When the integrity of rupture disks is maintained, fugitive emissions
through the relief valve are eliminated, Thus, a zero emission standard
could be proposed. However, as discussed in selection of test methods,
measurement techniques for determining the emission rate from safety/
relief valves cannot be reasonably applied. But a measurement technique
that allows the determination of the existence of fugitive emissions from
this source type is available. This technique can be used when emissions -•
are eliminated to determine if emissions are detected. For control
techniques that eliminate fugitive emission, an emission limit of no
detectable emission as measured by Method 21 is feasible. Therefore, the,:
proposed standard for safety/relief valves in gas service is "no detectable
emissions." The "no detectable emission" level does not apply to
discharges through the safety/relief valve during emergency overpressure
relief.
Equipment Specifications
Equipment specifications were considered for Regulatory Alternative
IV for pumps, compressors, open-ended lines, sampling connections and
open-ended valves. Viable options for implementing these equipment
specifications were evaluated for each source type. The advantages and
disadvantages of each option are described below for each source type.
Equipment specifications evaluated for pumps were double mechanical
seals with closed vents for the seal oil degassing reservoirs, closed
32
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vents for the pump seal areas, and sealless pumps. Double mechanical
seals were selected as the basis for the equipment specifications for
pumps in Regulatory Alternative IV. They are frequently used in SOCMI
pump applications. A barrier fluid between the two seals would collect
any leakage from the inner seal, and the VOC leakage collected by the
barrier fluid could be controlled by connecting the barrier fluid
reservoir to a control device (enclosed combustion or vapor recovery) with
a closed vent system. The double mechanical seal and closed vent system
is the most universally applicable of the three options evaluated.
Because double mechanical seals and closed seal oil degassing vents
provide a high control efficiency (dependent on the control device
efficiency), and they are the most applicable control technique for pumps,
they were selected as the specified equipment for pumps. A pressure
indicator on the barrier fluid system would reveal any catastrophic failure
of the inner or outer seal, and leakage through the outer seal would be
detected by weekly visual inspections. Leakage through the inner seal
would be captured and controlled by the barrier fluid/closed vent system.
Sealless pumps, such as diaphragm or canned pumps, do not have a
potential leak area, and therefore should achieve approximately 100 percent
control. Some SOCMI process applications nay not be suitable for use of
seal!ess pumps due to throughput, pressure, or fluid composition constraints,
Seallass pumps were not selected under Regulatory Alternative IV and,
therefore, were not selected as requirements for the proposed standards.
However, seal!ess pumps are allowed by the proposed standards because they
are essentially as good as, if not better than, double mechanical seals
33
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in controlling fugitive emissions. Because of their limited use,
sealless pumps were not selected as the equipment specifications for
pumps.
The seal area of a pump could be completely enclosed, and this
enclosed area could be connected to a control device (enclosed combustion
or vapor recovery) with a closed vent system. The control efficiency of
this arrangement is dependent on the control efficiency of the vapor
recovery system or enclosed combustion device. The closed vent system
could require a flow inducing device to transport emissions from the
4
seal area to the control device. Because of safety or operating
constraints, enclosure of the pump seal area may not be feasible in all
cases. Thus, enclosure of the pump seal area was not selected as the
required equipment specification for pump seals.
Equipment specifications evaluated for compressors were sealless
compressors, closed vents for seal oil degassing reservoirs, and closed
vents for the compressor seal area. Closed vents for seal oil degassing
reservoirs were selected as the basis for Alternative IV. Some
compressors in current SOCMI applications have a seal system with a
circulating barrier fluid system. This barrier fluid system is similar to
the system described for pumps with double mechanical seals, although the
compressor seal may be double mechanical, labyrinth, or another type of
seal. Leakage through the seal could result in the presence of VOC in
the seal oil. The VOC's could be emitted from the seal oil reservoir.
These fugitive emissions of VOC's could be collected and directed to a
control device (enclosed combustion or vapor recovery system) by a
closed vent system that is connected to the seal oil reservoir.
34
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Closed vent systems for seal oil degassing reservoirs were selected as
the equipment specification for compressors.
For some high pressure applications, reciprocating compressors may
be required. Under high pressure conditions double mechanical seals
with a seal oil system could not be utilized due to the low pressure
normally desired for the seal oil system. For those cases, enclosure of
the seal area was considered. The enclosed area could be connected to a
control device (enclosed combustion or vapor recovery) with a closed vent
system Enclosed seal areas connected to a control device with a closed
*
vent system was selected as the equipment specification for compressors
that cannot utilize a barrier fluid system.
Although seal!ess compressors would achieve approximately 100 percent
control, sealless compressors are not readily available in capacities
large enough for most SOC.MI process applications, and therefore, have
limited use in SOCMI. Consequently, seal!ess compressors were not
considered under Regulatory Alternative IV and were not selected as
equipment specifications for the proposed standards.
VOC leakage from open-ended lines occurs due to leakage through the
valve seat of a valve which seals the open end from the process fluid.
Equipment specifications considered for open-ended lines included
improved valve seat technology and closure of the open-end. Improved
valve seat technology was not selected because the effectiveness of such
technology could be nullified by operating variables such as incomplete
closure of the valve by operating personnel. Closure of the open snd
35
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would be achieved by installing a cap, plug, blind flauge, or a second valve
on the open end. The control efficiency associated with these techniques
is approximately 100 percent. However, it should be noted that VOC's
could leak through the valve seat and become trapped in the line between
the valve and closure. These trapped VOC's would be emitted when the
closure was removed for operation of the valves and open-end line.
Consequently, the "no detectable" emission level was not selected as the
basis for the proposed standard. Because the closure of the open end
can be easily accomplished, equipment such as caps, plugs, blinds, or
second valves was selected as equipment specifications for open-ended
valves.
Closed loop sampling was considered as the equipment specification
for sampling connections. When process samples are taken for analysis,
it is necessary to obtain a representative stream sample by purging some
process fluid through the sample connection. This sample purge would be
vented to the atmosphere if the fluid was gaseous, and liquid sample
purges could be drained onto the ground or into open collection systems
where evaporative emissions would result. Closed loop sampling systems
eliminate these purge emissions by either returning the purge material
directly to the process or by collecting the purge in a closed collection
system for recycle or disposal. Although the VOC control efficiency of a
closed'loop sampling system is approximately 100 percent, some VOC could
be emitted during its transfer to a closed collection device or its
ultimate disposal. Consequently, the "no detectable" emission level was
not selected as the basis for the proposed standard. Closed loop
sampling was selected as the equipment specification for sampling
connections because its control of VOC is effective.
36
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Equipment specifications considered for valves were diaphragm valves
and bellows sealed valves. These equipment specifications would not be
suitable for all SOCMI process applications, and therefore, were not
selected as part of Regulatory Alternative IV. However, use of these
valves would be allowed if their use would result in "no detectable
emissions". The only requirements associated with these valves would be
proper operation and maintenance to insure "no detectable emissions".
Work Practices
Work practices consisting of periodic leak detection and repair
programs were considered for valves in Regulatory Alternative IV.
Performance standards or emissions limits could not be specified becuase
adequate test data are not available to document achievable performance or
emission rates for valves. In addition, test methods for valves are
expensive and imprecise, and test data have shown that emission rates from
individual valves may be variable. These facts combined with the very
large population of valves in a SOCMI process unit present problems for
specifying of a performance standard. Equipment specifications would not
be universally applicable for valves, and therefore work practices are the
best format for control of fugitive VOC emissions from valves.
Several factors influence the level of emission reduction that can be
achieved by a leak detection and repair program. The three main factors
are the monitoring interval, leak definition, and rapair interval. Training
and diligence of personnel conducting the program, rapair methods attamptad,
and other sita-specific factors may also influence the level of emission
reduction achievable; however, these factor are lass quantifiabla than
the three main factors.
37
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The monitoring interval is the frequency at which individual
component monitoring is conducted. The length of time between inspections
should be determined by the rate at which new leaks occur and repaired
leaks recur. More frequent inspections could then be required for
sources which tend to develop leaks rapidly from previously non-leaking
and repaired sources. No data are available to quantify the frequency of
occurrence and recurrence of leaks from valves, and therefore selection
of a monitoring interval based on a rigorous numerical evaluation is not
possible. However, more frequent monitoring would result in greater--
emission reduction. Three monitoring intervals were considered in
developing the regulatory alternatives. These intervals were annual,
quarterly, and monthly.
Monthly monitoring was considered in Regulatory Alternative IV.
Less frequent intervals were not selected because test data indicate that
new leaks would be found with monthly inspections. More frequent intervals
were not considered because the large number of valves in certain SOCMI
process units limits the practical minimum for the monitoring intervals.
For example, a typical large process unit, Model Unit C, includes 2800
valves (in gas and light liquid service) requiring periodic monitoring.
Each leak detection and repair survey would require approximately 95
labor hours for monitoring and 16 labor hours for repair. Since some time
may be required to schedule repair after a leak is detected, monitoring
intervals shorter than one month could result in a situation where a
38
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detected leak could not be repaired before the next monitoring was
required. One month was selected as the required monitoring interval
because it would provide the greatest emission reduction potential without
imposing difficulties in implementing the leak detection and repair
program.
The leak definition is the VOC concentration observed during monitoring
that defines leaking sources that require repair. Two primary factors
affect the selection of the leak definition. These factors are: (1) the
percent of total mass emissions which can potentially be controlled by "-
the leak detection/repair program, and (2) the ability to repair the
leaking components. The maximum potential emission reduction resulting
from various leak definitions can be estimated for valves in gas and light
liquid service. Estimated emission reduction potentials are shown in
Table 1.
TABLE 1. MAXIMUM PERCENT EMISSION REDUCTION AT VARIOUS LEAK DEFINITIONS
Source Type
Gas valves
Light liquid valves
100,000
35
49
Leak defi
50,000
92
62
nition (ootnv)
10,000
98
34
1 ,000
99
96
100
99*
99
As the leak definition decreases, the maximum potential emission reduction
Increases due to the increasing number of sources that have anission
rates that are greater than the decreasing leak definitions. In order
to maximize control affectiveness of the leak detection and rsoair progrsm,
the lowest leak definition, which is feasible in tarns of -noni taring and
39
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controlling effectively without being overly costly or burdensome to
operating and enforcement personnel, should be selected. As Table 1
indicates, leak definitions of 10,000 ppmv or less would reduce VOC fugitive
emissions from valves in gas service by approximately 98 percent. However,
the data in this table also show that a significant reduction in the
leak definition results in only a small increase in the percentage reduction
of fugitive emissions.
Preliminary data show that attempting on-line repair of valves at
or above a leak definition of 10,000 ppmv could result in a few cases where
the attempted repair would increase the emission rate from the valve. In
these cases, the valve would require a more extensive repair effort than
tightening or regreasing the packing. Replacement of the valve may be
necessary. Data also show that attempting the repair of valves in the
1,000-10,000 ppmv range could frequently result in emission rate increases
after repair. If such increases were to occur, the attempted repair of
"low level" leaks could result in a lower overall emission reduction at
1,000 ppmv than at the 10,000 ppmv leak definition. Because the 10,000
ppmv action level clearly results in the reduction of fugitive emissions of
VOC's and is reasonable from an operating standpoint, 10,000 ppmv was
selected as the leak definition for leak detection monitoring.
The repair interval is defined as the length of time allowed between
the detection of a leak and repair of the leak. In order to provide the
maximum effectiveness of the leak detection and repair program, the repair
interval should require expeditious reduction of the fugitive emission but
should also allow the owner/operator to maintain a reasonable degree of
flexibility in overall maintenance scheduling.
40
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The length of the repair interval would affect emission reductions
achievable by the leak detection and repair program because leaking sources
would be allowed to continue to leak for a given length of time. Repair
intervals of 1, 5, 10, 15, 30 and 45 days were evaluated. The effect on
the maximum emission reduction potential is proportional to the number of
days the source is allowed to leak between detection and repair. The
maximum percent reductions for each of the repair intervals are shown in
Table 2.
TABLE 2. MAXIMUM EMISSION REDUCTION AT VARIOUS REPAIR INTERVALS
Repair Interval (days) 1 5 10 15 30 45
Maximum emission reduction (*.) 99.7 98.5 97.3 95.9 91.9 87.7
These percentages are based on the assumption that, on the average,
leaking sources would leak for one-half of the allowed repair interval and
yearly average period. There is a distinct incremental control difference
between 15 and 30 days. The control percentage decreases slowly up to 15 days,
but is clearly lower for 30 and 45 days. A repair interval of one day would
essentially require repair of each component as soon as the leak was
discovered. A repair Interval of one day would cause problems in coordinating
activities of personnel involved in leak detection and leak repair and in
certain circumstancas, would not be technically feasible.
Seme sources may not be repairable by simole field .^aintananca. These
sourcas may recuire spare parts or ranoval from the process for rapair.
41
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Repair intervals of 5 and 10 days could cause problems in obtaining
acceptable repair for these sources. However, a 15-day interval provides
the owner/operator with sufficient time for flexibility in repair
scheduling, and provides time for better determination of methods for
isolating pieces of leaking equipment for repair. In general, a 15 day
repair interval allows more efficient handling of repair tasks while
maintaining an effective reduction in fugitive emissions. The repair
interval selected for the leak repair program was 15 days.
However, the first attempt at repair of a leaking source would be.
required as soon as practicable after detection of the leak, and no
later than 3 days after discovery. Most repairs can be done quickly,
and 3 days should provide sufficient time to schedule repair and repair a
leaking source. Attempting to repair the leak within 3 days will help
to identify the leaks that cannot be repaired within the 15 day repair
interval. A request for delay of repair would be allowed for leaks which
could not be repaired without a process unit shutdown.
Design and Operational Requirements
The equipment specifications selected for implementation with various
potential fugitive emission sources must be designed and operated correctly
in order to minimize the emissions from the source. Design requirements
must be specified in order to assure that appropriate emission reductions
are achieved from control devices used in conjunction with closed vent
systems. Enclosed combustion sources and vapor recovery systems were
considered in evaluating control devices.
42
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Closed vent systems connected to an enclosed combustion source could
be used with pumps and compressors. Enclosed combustion was specified
because open flares may only be 60 percent efficient for VOC destruction of
these low flow, intermittent streams.. The design requirements specified
for enclosed combustion are the attainment of a minimum 760°C for 0.5
seconds. Under these conditions, complete VOC destruction is achieved.
Vapor recovery systems may also be used to control VOC from closed
vent systems used with pumps and compressors. In order to assure adequate
control of VOC from the closed vent system, vapor recovery systems must be
designed to control 95 percent of the VOC vapor input to the vapor
recovery system.
The proposed standards require open-ended lines to be equipped with
a cap, plug, blind flange, or a second valve. If a second valve is used, the
proposed standards would require the upstream valve to be closed first.
After the upstream valve is completely closed, the downstream valve may be
closed. This operational requirement is necessary in order to prevent
trapping process fluid between the two valves, which could result in a
situation equivalent to the uncontrolled open-ended line.
MODIFICATION OR RECONSTRUCTION CONSIDERATIONS
An existing facility, as defined in 40 CFR 60.2(aa), is a facility
that was constructed or modified before the proposal date of the
applicable standards of performance. However, an existing racility
that is modified or reconstructed after the date of proposal of the
standards becomes an affected facility and then is subjec* to applicable
standards of oerfornance.
43
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Modification is defined in 40 CFR 60.14 (a) as any physical or
operational change of an existing facility which increases the emission
rate of any pollutant to which a standard applies. Exemptions to this
definition include an increase in production rate, if such an increase
can be made without capital expenditure; an increase in the hours of
operation; the use of an alternative fuel or raw material; the addition of
air pollution control equipment; and routine maintenance, repair, and
replacement.
Reconstruction is considered to occur, in general, upon the
replacement of components if the fixed capital cost of the new components
exceeds 50 percent of the fixed capital cost that would be required to
construct an entirely new comparable facility. Under such conditions,
an existing facility becomes an affected facility. Based on this
definition, the replacement of an individual component will not constitute
reconstruction; consequently, the process unit will not become an affected
facility and will not be subject to standards of performance. A process
unit may become an affected facility under the provisions of reconstruction
if numerous components such as reactors and/or exchangers were also replaced,
Modification is considered to occur, in general, when the replacement
or addition of a component results in a net increase of VOC fugitive
emissions from the process unit. For instance, the addition of a
potential fugitive emission source, such as a pump, to the process unit
would result in making the unit subject to standards of performance if the
fugitive emissions from the unit were increased by the addition. In
order to keep the fugitive emission from increasing due to the addition
44
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of a component, the operator may purposely remove existing fugitive
amission sources from operation. The operator may also impose stringent
controls on the new and existing sources so that the total fugitive
emissions would not be increased by the addition of new sources.
• In some cases a process unit in the organic chemical industry can be
converted from the production of one chemical to the production of another
chemical. In such a case, modification would occur if either the number
of fugitive emission sources or the vapor pressure of the process fluids
increases during this conversion. As before, other fugitive emission
sources within the process unit could be removed from service or controls
added to the new and existing sources in order to maintain the same emission
rates that existed prior to the conversion and, consequently, avoid
subjecting the process unit to standards of performance under the provisions
of modification.
SEL£CTION OF RECQRDKEEPING AND REPORTING REQUIREMENTS
Recordkeeping and reporting would be required by the proposed
standards to provide documentation for the assessment of compliance with
(1) work practice standards, (2) equipment standards, (3) design standards,
(4) emission standards, and (5) operational standards. Review of records
and reports would provide information for enforcement personnel to assess
implementation of the proposed standards. Recordkeeping and reporting
would also be necessary for determining the equivalency of alternative
control methods for the proposed work practice, equipment, design,
amission, and operational standards.
Requirements for Compliance
Recordkeeaing - Three recordkeeping alternatives wers considered
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in evaluating the amount of recorded information needed to assess
compliance with the proposed standards. These alternatives represent
varying levels of the amount of information which could be recorded
during activities associated with complying with the standards.
Consequently, these alternatives represent varying levels of resource
requirements for industry.
The first alternative would be to require no formal recordkeeping
other than the recordkeeping required by the General Provisions of
40 CFR Part 60.7 for notification of construction, start-up, and modification
or malfunction of control equipment. Failure to require recorded documentation
of the proposed work practice, equipment, design, and operational standards
would not provide a mechanism for checking the thoroughness of the
implementation of the proposed standards and therefore would not ensure
fugitive emission reduction. Because the effectiveness of the proposed
standards is dependent upon the thoroughness of the industry's efforts, this
alternative was not chosen as the basis of the recordkeeping requirements.
The second alternative would require recordkeeping to document
results of the leak detection and repair program and information relating
to equipment, design, and operation requirements. Information would be
recorded in sufficient detail to enable owners/operators to demonstrate
compliance with the standards and therefore provide reasonable assurance of
adequate reduction of fugitive emissions. This alternative would require the
maintenance of instrument calibration records and quantitative records of
repaired and unrepaired leaking components. This alternative would require
only the minimum amount of records on the equipment, design, emission, and
operational standards and the work practice leak detection and repair
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program necessary to ensure the effective implementation of the proposed
standards.
The third alternative would require recordkeeping of all the
information generated by the proposed standards, e.g., the number of
leaking sources detected at a concentration less than 10,000 ppmv. Much
of this information would not be necessary to ensure the implementation
of the proposed standards. The level of recordkeeping in the third
alternative is more appropriate for requirements to establish equivalent
methods for emission limitation which is discussed below.
The second alternative was selected as the basis for the
recordkeeping requirements of the proposed standards. This alternative
would require the minimum resources of industry for providing the
necessary records to ensure effective implementation of the proposed
standards. This alternative would also provide a basis for efficient
reporting.
The proposed standards would require records concerning calibration
of the portable monitoring instrument conducted before each monthly
monitoring survey. Recorded information would include the concentrations
of the calibration standard gases, the instrument 1.0. number, the
obser/ed instrument reading, adjustments made if the reading exceeded
the acceptable tolerance, and results of the new calibration check.
Specific information pertaining to the monthly monitoring far the
•c
work practice standards would be recorded. Each leaking source would
be identified with a readily visible weatherproof tag bearing the I.D.
number of the source and the data of discovery. The tag would be removed
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after the source was repaired. A Survey log would be maintained for
information pertaining to the leaking sources. The survey log would
contain the instrument and operator identification numbers, the leaking
source identification number, the date of detection of the leaking source,
the date of each attempt to repair the leaking source, and the maximum
screening value after each attempt. The survey log would be kept for
2 years following the survey.
Upon approval of a request for delay of repair beyond 15 calendar
days of the date of detection, "repair delayed" would be recorded in
the survey log for that particular source. The I.D. tag on the leaking
source would be narked to indicate the first date repair was attempted
and the dates of subsequent attempts to repair the leaking source. The
reasons for unsuccessful repair, date of detection, date of request for
delay, and the expected date of repair of the leaking source, and the
maximum screening value observed after repair would be recorded in the
survey log. These records would be needed to establish a data base to
provide the information necessary to allow enforcement personnel to assess
compliance with the work practice standards.
No records would be required for valves which were found not to
leak. Similarly, no records would need to be maintained of th weekly
pump inspections if no leaks were observed visually. If a leak was observed,
however, instrument monitoring would be required. If the maximum screening
value was in excess of the action level, the same recording requirements as
outlined for the monthly survey would be fulfilled.
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For emission standards, records would be maintained in a permanent
log of the date of the initial inspection of the safety/relief valves
and the results of monitoring indicating whether emissions were detected
from each source. After each incident in which a safety/relief valve was
activated, the date and results of monitoring indicating that the source
was once again performing with no detectable emissions would be recorded.
For equipment specifications, records would be maintained in a
permanent log of the dates of installation, start-up, equipment repair,
and equipment alterations. The dates and descriptions of any equipment
failures would also be recorded. These records would be needed to
astablish a data base to provide information necessary to allow enforcement
personnel to assess the effectiveness of implementation of the equipment
standards.
For design standards, records would be maintained of the location
of materials which document control device design criteria, such as
design specifications for a vapor recovery system or an incinerator. When
the control equipment was modified or replaced, the date of replacement
and new design criteria would be recorded.
No recording of the results of the proposed operational standards
would be required. However,'procedures in keeping with good operating
practice to ensure adherence to the standards would be maintained and
in evidence through operator instructions.
Deporting - Three rsoorting alternatives were considered in
avaluating the amount of reqortad information needed to assess conoliancs
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with the proposed standards. These alternatives represent varying levels
of enforcement monitoring of the proposed standards. Enforcement
personnel would review the reports submitted by industry personnel on
the status of implementing the proposed standards. This review procedure
reduces the need for in-plant inspections. Consequently, these alternatives
also represent varying levels of resources required for industry and
enforcement personnel.
The first alternative would require minimum reporting of information
which was recorded to monitor compliance with the proposed standards.
Recorded information would be available at the plant to enforcement
personnel, but the owner/operator would be required only to supply a
report testifying that all equipment, design, emission, and operational
standards had been met, that all components had been monitored and that
those with leaks had been repaired. The more detailed recorded information
would then be available upon specific request or plant visit by enforcement
oersonnel. This alternative would not ensure that fugitive emission reductions
had been achieved in all cases and would not provide a mechanism for
checking the thoroughness of the industry's efforts to reduce these emissions.
Thus, assessment of compliance with the standards would be intermittent
and somewhat random since it would mainly be determined through in-plant
inspections rather than through submittal of information to enforcement
agencies.
The second reporting alternative would require the submittal of
information in sufficient detail to assure compliance with the proposed
working practice, equipment, design, emission, and ooerational standards.
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These requirements would stipulate the submittal of quarterly reports.
Included in the reports would be a list of only those leaks not repaired
within the allowable repair interval. This requirement would provide
enforcement personnel with an overview of the repair of leaks. A report
signed by the plant owner/operator attesting to the validity of the results
of the monitoring surveys and instrument calibration procedures would allow
enforcement personnel to assess the compliance of facilities with the work
practice standards. This report would also attest to the proper application,
operation, and maintenance of the equipment required by the proposed -.-
equipment, design, emission, and operational standards. These requirements
would not necessarily include all records kept by industry. Only information
that would be necessary to assess the implementation of the equipment
standards would be required.
The third reporting alternative would require the submittal of all
the information obtained while conducting leak detection and repair
programs. This information would include the information reported in
the second alternative and, additionally, comprehensive information on
all tastad components. This reporting alternative would necsssitata the
recording of all information included in the recordkeeping requirements
and would require more resources than the second alternative. The
extensiveness of the reported information would require the SCCMI to
repor- data "hat would be .nore-appropriate for demonstrating equivalency
of altarnata .^e'hcds of emission control than for establisning ccmolianca
wi-h arooosed standards.
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The second alternative was selected as the reporting requirement for
the proposed standards. This alternative provides sufficient information
to review compliance without requiring excessive resources from industry.
The first alternative was not selected because the compliance with work
practice standards and the implementation of equipment design, emission,
and operational standards could not be adequately assessed by enforcement
personnel to ensure that reductions in fugitive emissions were acheived.
The third reporting alternative was not selected because the additional
resources expended by industry would not facilitate assessment of
compliance and implementation of work practice, equipment, design, emission
and operational standards. However, reporting additional information to
establish equivalency of alternatives for leak detection and repair
programs, equipment specifications, design standards, emission standards,
or operational standards would be an option available to the individual
owner/operator as discussed in the section on equivalence of alternative
means of emission limitations.
In the proposed standards, requests for delay of repair beyond 15
calendar days would be made if it could be demonstrated that repair would
require unscheduled shutdown of the process unit. Other necessary information
that would be reported in a request for delay of repair would include the
location, 1.0. number and date of detection of the leaks. The date of
attempted repair and the maximum screening valve observed after attempted
repair would be required along with the reasons for unsuccessful repair of
the leaking sources and the expected date when repair can be accomplished.
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Quarterly reporting would be required for some of the information
recorded under the proposed work practice, equipment, design, emission, and
operational standards. The reported information would include the leak
report form and a statement attesting to the proper application of the
test methods and procedures and the proper application and operation of
all required equipment and design standards. The report would include
the dates and descriptions of repairs, replacements, adjustment, or other
changes made to the required equipment specified by equipment and design
standards after the first quarterly report was submitted. The report -..
would specify that safety/relief valves had been checked during the
reporting period and would present the results of the check with respect
to requirements for no detectable emissions. The report would indicate
any safety/relief valve that was activated during the reporting period
and the date that the source was returned to service with no detectable
emissions. The report would also indicate whether the facility was being
operated in accordance with operational standards. The report would be
signed by the owner or operator.
Equivalence of Alternative Means of Emission Limitation
Secordkeeping and reporting would be required in order to establish
a data base to enable SQG-1I to request a determination of equivalency for
an alternative control technique. Information in more detail than that
required ~o demonstrate compliance would provide a data base for SGCM! to
demonstrate equivalency of alternative ccn-rcl techniques. Individual
cwners/ocerators in SGCM! would propose nethods far specific apolicaricns
SUCH as (1; altama-a centre! "ne'hcc's, [2] seviacions -rcm the speci-iec
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repair interval and monitoring intervals, and (3) alternate equipment.
Sufficient infomation would have to be collected by a facility to
demonstrate that alternative control techniques would be equivalent to
the control techniques required by the proposed standards. This information
could then accompany a request for a determination of equivalence and
accompany a public notice as part of the documentation necessary to
evaluate the alternative control techniques.
Recordkeeping - Two recordkeeping alternatives were considered for
the assessment of equivalency. The first alternative would rely upon the
recordkeeping requirements of the proposed standards to establish a data
base for establishing equivalence. This alternative would minimize the
resources required by industry and enforcement personnel. However, these
recording requirements would not provide sufficient information to
determine the equivalence of alternate control methods.
The second alternative would require the collection of sufficient
quantitative emission rate test data to show equivalence to the proposed
standards. This alternative would require more resources of industrial
oersonnel than the first alternative. However, increased recordkeeping
would be needed and to verify that alternative methods would be at least
equivalent to the proposed standards in reducing fugitive emissions.
Whether to increase recordkeeping or not would be a decision made solely
by the olant management. Therefore, the second alternative for recordkeeping
to establish eauivalence was selected.
?ne proposed standards would require records of the emission
reduction achieved by implementing the work oractice standards for a
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minimum period of 12 months' application in order to permit assessment
of the emission reduction achieved by the proposed standards at a specific
site. Records of the emission reduction achieved by the alternative work
practice standard for a minimum period of 12 months would also be necessary.
Records would establish that the performance of alternative work practices
was equal to or greater than that achieved by implementing the standards.
Performance levels of "no detectable emissions" would be considered
equivalent.
Records documenting the equivalence of alternative equipment and
aesign specifications would be required. The data must be demonstrated
to be applicable to the facility if the data were collected at another
facility. The test data must demonstrate that alternate equipment or
design specifications are equal to or more effective than the proposed
standards in reducing fugitive emissions. Performance levels of "no
detectable emissions" would also be considered to be equivalent to equipment
and design specifications. Seal!ess pumps and compressors would be
considered to be equivalent to proposed standards for pumps and compressors.
Once alternative standards have been demonstrated to be equivalent
and nave aeen approved by the Administrator, then -he alternatives would
be subject to other recordkeeping requirsnents substituted for the compliance
requirements in the proposed standards.
Resorting - Two reporting alternatives were considered for owner/
operators to apply for equivalence. The first resorting ai "amative woula
be to require trie submittal of information to apply far equivalency in the
same -etail as far demonstrating ccmoliance. Ccmcariscn cf the infcmatlcn
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would be used as a guideline to assess the equivalence of the two methods.
This alternative would require a minimum of resources for reporting since
compliance reporting would be used to establish the control effectiveness
that alternatives must achieve. However, this level of reporting would
not establish that alternative methods were equivalent in reducing
emissions, because the proposed standards require reports for only those
leaking sources which could not be repaired within 15 days of detection. The
effectiveness of alternative monitoring methods, monitoring intervals, repair
intervals, equipment or design specifications or operational procedures
could not be assessed. Therefore, this alternative was not selected.
The second reporting alternative would require the submittal of
information in sufficient detail to establish the equivalence of alternative
control methods in reducing fugitive emissions. Concise reports may be
sufficient for some equivalence determinations and in other determinations,
additional information might be necessary.
The proposed standards would implement the second reporting alternative.
The owner/ operator would report test data to show equivalence of alternative
equipment and operational standards by demonstrating a performance level
of "no detectable emissions" or by providing test data to show equivalence
based upon comparisons of emission rates.
The owner/operator would report test data to show equivalence of
alternative work practice standards by demonstrating a performance level
of "no detectable emissions" or by developing a quantitative performance
level describing the emission reduction achieved that is equivalent to the
methods in the proposed standards. The test data collected to show
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equivalence for a minimum 12-month time period may be requested for both
the alternative control method and the method specified by the proposed
standards. This permits the comparison of emission reductions achieved
by each method. The test data would be in the form of quantitative
emission rates for all sources.
After public notice and opportunity for public hearing, the Administrator
would determine the equivalence of an alternative means of emission limitation
and would publish the determination in the Federal Register. Once the
alternatives have been demonstrated to be equivalent and have been accepted
by the Administrator, then the alternatives would be subject to the reporting
requirements substituted for the compliance requirements of the proposed
standards.
IMPACTS OF REPORTING REQUIREMENTS
In addition to requirements of the General Provision of Subpart A of
40 CF3 Part 50, the proposed standards would require submission of requests
for delay of repair of leaking sources, quarterly reports including
information pertaining to the required equipment specifications, and
information pertaining to the required work practices. Estimates of the
efforts associated with the reporting requirements indicate that the
industry would incur manpower expenditures of approximately 130,000 hours
in 1985 to fulfill the requirements. No overlapping data requirements
with other government agencies are anticipated.
SELECTION OF TEST ME
Several fugitive emission measurement ana monitoring -Tie"hoe's -
icentifiad and analyzed in the develocment of the proposed standards.
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Evaluation of these alternative methods was based upon results of emission
testing conducted at petroleum refineries and synthetic organic chemical
manufacturing plants.
One method of emission measurement is the direct measurement of
mass per unit time, e.g. kg/hr, from each source. For the wide variety of
sources subject to this standard, direct measurement would require
"bagging" techniques for the measurement of mass emissions. "Bagging"
means to enclose a fugitive emission source with a shroud in order to
capture all of the emissions from the source. The shroud must be attached
securely to the source in order to ensure complete capture of emissions,
and a flow measurement device is needed to measure the volumetric emission
rate. After an appropriate equilibration time (5-30 minutes) a sample of
the effluent from the shroud is taken to determine the VOC concentration.
The VOC mass emission rate is then calculated based on the volume flow rate
and VOC concentration. Because of the large numbers of sources in an
affected facility as well as the different physical configurations and
diverse locations, direct measurements of leak rates would be costly,
time-consuming, and impractical for routine testing. Therefore, direct
measurement of leak rates was not selected as the emission measurement
method for the proposed standard.
Indirect emission measurement methods or monitoring methods that would
yield qualitative indications of leaks were reviewed. These monitoring
methods are: (1) a periodic individual component survey that would monitor
all fugitive emission sources; (2) a periodic area, or walkthrough, survey
that would iTicnitor ambient concentrations of VOC; and (3) a continuous
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-ixed-ooint monitoring system that would consist of remote sensing devices
with a central rsadout or a central analyzer system (gas chrcnatograph)
with remotely collected samples.
Individual component sur/eys would be the ,Tost efficient method for
detecting all leaks. The periodic individual component survey would require
a reasonable amount of time by monitoring personnel and would be accomplished
with relative ease. The cost of leak detection equipment for the individual
ccmconent survey would be reasonable. Monitoring of individual components
could result in personnel exposure to VOC emissions; however, walkthrough
or f-fxed-point sur/eys would ultimately present similar problems, because
an individual component survey is also required.
A periodic area, or walkthrough, survey of ambient VOC concentrations
with a portable VOC detector and recorder would be a less efficient method
for detecting leaks than the individual component survey. Interference
due to local rreteorological conditions and leaks from adjacent units would
probably prevent the detection of all leaks within a process unit. In fact,
excerienca has indicated that the area survey is suitable only for locating
large leaks. The time and labor reauired for monitoring personnel would
crobably be less for the area survey than for the individual ccmoonent
survey; fewer components would be screened even if all leaks were found.
Walkthrough monitoring could be accomplished with relative ease, and the
cost of "he ~or*:able VOC detection aouiwment would be -"eascnabla. The
oer"0d*:c area survey would cresen' the sare rroblar1 •I'.'n rerscnne*
exposure to '/OC emissions is the individual ccrconent survey; 2* so, .-irer?
-^cul-i incicata leaking =cu:rmer~, '-civ'a-ja 1 :croonent
:e '•ecuirea to r*nc the leak.
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Implementation of a continuous fixed-point monitoring system would
require a portable VOC analyzer to locate specific leaking components in
addition to multiple stationary monitors or sample collectors. This system
nay be less efficient than the other methods for detecting VOC emissions.
Possible meteorological interference and problems with measuring VOC
concentrations of remotely collected samples would limit the efficiency of
leak detection by a fixed-point system. Except for possible monitoring
equipment calibration problems, the fixed-point system would be operated with
relative ease by monitoring personnel, who would still be required to use
portable VOC detection equipment to find the individual leaking components
indicated by the fixed-point monitoring system. Implementation of a
continuous fixed-point monitoring system would be capital-intensive, although
labor costs would probably be the least of the three monitoring methods.
Because monitoring of equipment by personnel would still be required for the
fixed-point method, personnel exposure to VOC emissions would be similar to
those of the individual component and the walkthrough methods.
Some characteristics of the three indirect emission measurement methods
are similar, including safety considerations and ease of operation for
monitoring personnel. Some aspects of the three methods are different.
Capital and operating costs vary, as do the efficiencies of the methods in
detecting VOC leaks. The component method is characterized by a superior
leak detection efficiency and reasonable costs; other asoects of the method,
including safe~y and ease of operation, are similar to those of the
v/al k-hrough and -ixed-ooint methods. Considering these factors, the
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individual component survey was selected as the monitoring method for the
proposed standards.
Two individual component survey methods were identified: (1) .leak
detection by spraying each component with a soap solution and observing
bubble formation; and (2) leak detection by measuring VGC concentration
with a portable VOC analyzer. The magnitude of leak rates based on bubble
formation is difficult to assess. In addition, soap bubble formation does
not distinguish VOC emissions from other leaking gases or vapors, and bubble
formation is subject to component temperature and component configuration
restraints. Therefore, measurement of VOC concentration with a portable
detector was selected as the method for monitoring individual components.
•Selected Test Procedure - The recommended test method, Method 21, would
incorporate the use of a portable VOC analyzer to measure the concentration
of VOC at a source to yield a qualitative or semiquantitative indication
of the VQC emission rate from the source. The general approach of this
technique assumes that if a VOC leak exists, there is an increased VOC
concentration in the vicinity of the leak. Tests in petroleum refineries
have established general concentration versus mass emission relationships
for various fugitive emission sources. Also, tests have indicates that
local conditions cause variations in concentration readings at points
removed from the surface of the interface on the component where leaking
occurs, "herefore, the prooosad Method 21 requires the concentration to be
measured at the inter-ace surface.
Sceci flea "ions, Calibration, and Psr-omanca Criteria of tne
instrument - "he VOC dense-ion instrument usec in the pro cosed mo ni-re ring
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program is required to conform to several specifications to ensure
consistent industry-wide monitoring, effective VOC emission reduction
efforts, and safe leak detection programs. These equipment specifications
are as follows: (1) the instrument should respond to total hydrocarbons
or combustible gases. Detector types which may meet this requirement
include catalytic oxidation, flame ionization, infrared absorption, and
photoionization; (2) the instrument should be safe for operation in explosive
atmospheres; (3) the instrument should incorporate an appropriate range or
dilution option so that concentration levels of 10,000 ppmv can be measured;
(4) the instrument should be equipped with a pump so that a continuous
sample can be provided to the detector. The nominal sample flow rate
should be 1-3 liters per minute; (5) the scale of the instrument readout
meter should be readable to ±5 percent at 10,000 ppmv.
The proposed standard specifies that the monitoring instrument be
calibrated with n-hexane. Thus, the required calibration gases would be
a zero gas (air, <5 ppmv VOC) and two hexane-air mixtures (800 and
8,000 ppmv hexane). If cylinder calibration gas mixtures would be used,
they would have to analyzed and certified by the manufacturer to within
±2 percent accuracy. Calibration gases prepared by the user according to an
accepted gaseous standards preparation procedure would also have to be
accurate within ±2 percent.
The monitoring instrument would be calibrated before each monitoring
survey. The calibration procedure would include assembly and start-up of
the portable VOC analyzer according to the manufacturer's instructions.
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Aftar the appropriate wara-uo period and zero or intarna! calibration
prccadure, the hexane (or hexane equivalent) calibration gas would be
introduced into the instrument sample probe. The instrument meter
readout would be adjusted to correspond to the calibration gas value.
The monitoring instrument would be subjected to other performance
requirements prior to being placed in ser/ice for the first time. The
instrument would be subjected to the performance criteria every six
months and after any modification or replacement of the instrument
iatactor. Deviations from these performance specifications or long-tarn
trends in the instrument's operating behavior as notad from performance
testing would indicate the need for instrument repair.
PUBLIC HEARING
A public hearing will be held to discuss these proposed standards
in accordance with Section 207(d)(3) of the Clean Air Act. Persons
wishing to make oral presentations should contact E?A at the address
given in the ADDRESSES section of this preamble. Oral presentations
•.•/ill be limited to 15 minutes each. Any member cf the public ray fila 5
written statement with EPA before, during, or within 20 days aftar the
'tearing. Written statements should be addressed to the Central Cockat
Section address given in the ADDRESSES section of this preamble.
OOC:
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that they can intelligently and effectively participate in the rulemaking
process and (3) to serve as the record in case of judicial review.
MISCELLANEOUS
As prescribed by Section 111, establishment of standards of performance
for the Synthetic Organic Chemicals Manufacturing Industry was preceded
by the Administrator's determination (40 CFR 60.16, 44 FR 49222, dated
August 21, 1979) that sources within this industry contribute sigificantly
to air pollution which may reasonably be anticipated to endanger public
health or welfare. In accordance with Section 117 of the Act, publication
of this proposal was preceded by consultation with appropriate advisory
committees, independent experts, and Federal departments and agencies.
The administrator will welcome comments on all aspects of the proposed
regulations, including economic and technological issues, and on the
proposed test method.
Comments are specifically invited on the severity of the economic
and environmental impact of the proposed standards on the Synthetic Organic
Chemicals Manufacturing Industry since some parties have expressed objection
to applying the proposed standards to this industry. Any comments submitted
to the Administrator on these issues, however, should contain specific
information and data pertinent to an evaluation of the magnitude and
severity of its impact and suggested alternative courses of action that
would avoid this impact.
It should be noted that standards of performance for new sources
established under Section 111 of the Clean Air Act reflect:
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...application of the best technological system of
continuous emission reduction which (taking into consideration
the cost of achieving such emission reduction, any nonair
quality health and environmental impact and energy requirements)
the Administrator determines has been adequately demonstrated
[Section lil(a)(1)].
Although there may be emission control technology available that can
reduce emissions below those levels required to comply with standards of
performance, this technology might not be selected as the basis of standards
of performance because of costs associated with its use. Accordingly,
standards of performance should not be viewed as the ultimate in achievable
emission control. In fact, the Act may require the imposition of a more
stringent emission standard in several situations.
For example, applicable costs do not necessarily play as prominent
a role in determining the "lowest achievable emission rate" for new or
modified sources locating in nonattainment areas, i.e., those areas where
satutorily mandated health and welfare standards are being violated.
In this respect, Section 173 of the Act requires that nay or modified
sources constructed in an area where ambient pollutant concentrations
exceed the National Ambient Air Quality Standard (NAAQS) must reduce
emissions to the level that reflects the "lowest achievable emission
rate" (LAE3), as defined in Section 171(3) for such category of source.
The statue defines LAER as that rate of emissions based on the following,
whichever is more stringent:
(A; -he ^ost stringent emission limitation whic.n :s
contained in the implementation plant of any State *cr such
class or category of source, unless the owner cr opentor
of the srccosed source aemonssrates that such limitations
are not acnievable, or
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(B) the most stringent emission limitation which is
achieved in practice by such class or category of source.
In no event can the emission rate exceed any applicable new source
performance standard (Section 171(3)).
A similar situation may arise under the prevention of significant
deterioration of air quality provisions of the Act (Part C). These
provisions require that certain sources referred to in Section 169(1)
"best available control technology" (BACT) as defined in Section 169(3)
for all pollutants regulated under the Act. Best available control
technology nust be determined on a case-by-case basis, taking energy, -
environmental and economic impacts, and other costs into account. In no
event may the application of BACT result in emissions of any pollutants
which will exceed the emissions allowed by an applicable standard
established pursuant to Section 111 (or 112) of the Act.
In all cases, State Implementation Plans (SIP's) approved or
promulgated under Section 110 of the Act must provide for the attainment
and maintenance of NAAQS designed to protect public health and welfare.
For this purpose, SIP's must in some cases require greater emission
reduction than those required by standards of performance for new sources.
Finally, States are free under Section 116 of the Act to establish
even more stringent emission limits that those established under
Section 111 of those necessary to attain or maintain the NAAQS under
Section 110. Accordingly, new sources nay in some cases be subject
to limitations more stringent than standards of oerfomance under
Section 111, and prospective owners and operators of new sources should
be aware of this aossibilitv in plannina for such .facilities.
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This regulation will be reviewed four years from the date of
promulgation as required by the Clean Air Act. This review will include
an assessment of such factors as the need for integration with other
programs, the existence of alternative methods, enforceability, and
improvements in emission control technology, and reporting requirements.
Section 3T7 of the Clean Air Act requires the Administrator to
prepare an economic impact assessment for any new source standard of
performance oromulgated under Section lll(b) of the Act. An economic
impact assessment was prepared for the prooosed regulations and for
other regulatory alternatives. All aspects of the assessment were
considered in the formulation of the proposed standards to insure that
the oroposed standards would represent the best system of emission
reduction considering costs. The economic impact assessment is included
in the Backcrcund Information Document.
date Aommstrator
o/
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It is proposed to amend Part 60 of Chapter I, Title 4-0 of the Code
of Federal Regulations as follows:
1. 3y adding subpart VV as follows:
Subpart VV - Standards of Performance for Fugitive Emission Sources
in the Synthetic Organic Chemicals Manufacturing Industry.
Sec.
60.430 Applicability and designation of affected facility.
50.481 Definitions.
50.482 Standards.
60.483 Recordkeeoing requirements.
60.484 Reporting requirements.
60.435 Test methods and procedures.
60.486 Equivalence of alternative means of. emission limitation.
AUTHORITY: Sec. Ill, 301(a) of the Clean Air Act as amended
[42 U.S.C. 7411, 7601(a)], and additional authority as noted below.
§50.480 Applicability and designation of affected facility.
The provisions of this subpart apply to the following affected
facilities: process unit fugitive emission sources in the synthetic
organic chemicals manufacturing industry.
§60.481 Definitions.
As used in this subpart, all terms not defined here shall have the
meaning given them in the Act and in subpart A of Part 50, and the
following terms shall have the soecific meanings given them, unless
otherwise -ecuired ov the context.
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"Ambient Background Lave!" means the VOC concentration in the
vicinity of a fugitive emission source which is not influenced by VOC
emissions from any specific emission source.
"Closed Vent System" means a system of oiping, connections and,
if necessary, flow inducing devices that transports gas or vapor from a
fugitive emission source to a control device.
"Enclosed Combustion Device" means any conbustion device, such as a
process heater or furnace, but not a flare.
"Fugitive Emission Source" means each 2ump, valve, safety/relief
valve, ooen-ended line, flange, compressor, or sampling connection in
VOC service.
"Gas/Vapor Service" means that the fugitive emission source contains
process fluid that is in the gaseous state.
"Light Liquid Sen/ice" means that the fugitive emission source
contains a licuid that has a vapor pressure equal to or greater than 0.2 k?a
"*!o Detectable Emission" f«eans that monitoring all potential leak
interfaces does not measure any VOC concentration greater than 100 sarts
~er million by volume (pomv) greater than the ambient background level.
"Ooen-cnded Line" means any valve (exceot safety/relief valves) with
one side of the valve seat in contact with process fluid and one side that
is ccen to the atmosphere, either directly :r through ocer si-^g.
"0y*oc3S3 ::rnt Fugitive Emission Source" reans any ccmb^raticn :f
•ugitive amiss ion sources that is operated in concert to prccuce, ~rea~,
sacarata, transport, .-lodify or otherwise orccass organic chemicals.
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"Repaired" means that a fugitive emissions source is adjusted or
otherwise altered in order to reduce fugitive emissions below the level
that indicates the necessity for repair as required in §60.482.
"Synthetic Organic Chemicals flanufacturing Industry" means all
facilities engaged in production, as intermediates or final products, of
one or more of the 378 chemicals listed in Appendix E of this subpart.
"Vapor Recovery System" means any type of control device capable of
capturing VOC vapor, such as carbon adsorption, vapor compression, and
vapor refrigeration systems.
"Volative Organic Compound (VOC)" means any organic compound, which
is measured by the applicable test methods described in Method 21,
except methane, ethane, methyl chloroform, and trichlorotrifluoroethane.
"VOC Service" means that a fugitive emission source contains or
contacts a process fluid composed of equal to or greater than 10 percent
VOC by weight if the process fluid is a liquid, or equal to or greater
than 10 percent VOC by volume if the process fluid is a gas.
§60.482 Standards.
Each owner or operator subject to the provisions of this subpart
shall comely with the following requirements for fugitive emission sources
in VOC service.
(a) Pumps in light liquid service.
(1) Each cump shall be squiooed with double mechanical seals that
include a static or flow-through barrier fluid system between the double
mechanical seals, exceot as orovided in •56C.432(a)(7).
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(2) Each barrier fluid system as reauired in So0.432(a)(1) shall
be equipped with a pressure sensor that will detect failure of the inner
seal, cuter seal, or both seals.
(2) £ach barrier fluid system as required in §6G.482(a)(1) shall
be —
(A) operated at a pressure that is greater than the pump discharge
pressure; or
(3) eauipped with a barrier fluid degassing reservoir that is
connected by a closed vent system to an enclosed ccnbustion device designed
for a nininum VOC residence tine of G.5 seconds at 750°C or to a vaoor
recovery system designed for a minimum of 95 percent capture of VOC incut
to the system.
(4.) Each purp shall be checked by visual inspection, each calendar
week, for indications of liquids dripping from the pumo seal, and by the
•^onitoring nethods specified in §SG.435(a) —
(A) no later than one calendar day after detecting -indications of
liquids dripping from the punp seal; and
(5) with a seal leak defined as any measured '7QC concentration
5cua" to or greater than 10,OGO parts per -rill ion by volume (ppmv).
(5) Each pump shall be repaired as soon as possible, but not later
than 15 calendar days after detection of a seal leak as defined in
= 60. -32{a) • 2] ; "he first attarpt it'reoair snail be "ace no latar than
2 calendar iavs after defection of a saal leak.
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(5) Each pressure sensor as required in §60.482(a)(2) shall be
checked daily. Based on operating experience, a pressure criterion that
indicates failure of the double mechanical seals or the barrier fluid
system shall be determined for each barrier fluid system. If this
pressure criterion is attained, the pump seals or barrier fluid system
shall be repaired as soon as possible, but no later than 15 calendar days
after detection of attainment of the pressure criterion, except as
provided in §60.432(h); the first attempt at repair shall be made no
later than 3 calendar days after detection of attainment of the pressure-
criterion.
(7) Each pump that is operated with no detectable emissions, as
determined by the methods specified in §60.485(b), shall be exempt from
the requirements of §60.482(a)(l), (2), (3), (4), ( = ), and (6).
(b) Compressors.
(1) Each compressor shall be equipped with a seal(s) that includes
a static or flow-through barrier fluid system that prevents leakage of
process fluid to the atmosphere, except as provided in S60.482(b)(3) and (4),
(A) Each barrier fluid system as required in §50.482(b)(1) shall be
equipoed with a pressure sensor that will detect failure of the seal(s).
(3) Each pressure sensor as required in §60.482(b)(l)(A) shall be
checked daily. Based on operating experience, a pressure criterion that
indicates failure of the seal(s) or the barrier fluid system shall be
•determined for each barrier fluid system. If this pressure criterion Is
attained, the ccnoressor seal(s) or barrier fluid system shall be repaired
=s soon as possible, but no later than 15 calendar Jays after detection of
attainment of the pressure criterion, except as provided in. §50.432(:'0 ; the
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first attempt at repair shall be rnade no Tatar than 3 calendar days
aftar detection cf attainment of the pressure criterion.
(C) Each barrier fluid system as required in iS0.432(b) (1) shall
be —
(i) operated at a oressure that is greater than the compressor
discharge pressure; or
(ii) equipped with a barrier fluid degassing reservoir that is
connected by a closed vent system to an enclosed combustion device
designed for a ninimum VOC residence tine of 0.5 seconds at 750°C or to-..
a vapor recovery system designed for a minimum of 95 rercent capture of
YOG input to the system.
(2) Each compressor shall be —
(A) repaired as soon as possible, but not later than 15 calendar
days aftar visual, audible, olfactory, or any other type of detection of
VGC leakage to the atmosphere; the first attempt at ^eoair shall be nade
no later than 3 calendar days after detection of 7CC leakage to the
atmosphere; or
(3) Each compressor that cannot be eauipped with the recuirements 01
•5cC.482(b) (1}, due to technical infeasibil ity, shall be ecuiooed with a
closed vent system capable of transporting any leakage from the seal to
an enclosed combustion device designed for a minimum VOC residence time
of C.5 seconds at 75C°C or to a vacor recovery syster iesicned -or 2
-*-ji-um of 95 :ercant caoture -of VQC Hout to the syster.
(-} Each ccroressor that is operated with no Detectable 5n~'s3"cns,
is teter^inec by the methods sceci'iec fn |6G.-55(b)i sra1;7 oe e.x-erc~ ~'~~r
tre "ecu"5 rerents of 35C.-32(b) (1"! , •'£'•, ird '3).
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(c) Safety/relief valves in gas/vapor service.
(1) Each safety/relief valve shall be maintained at a state of no
detectable emissions, as determined by the nethods specified in §60.485(b),
except during episodes of emergency pressure release.
(2) Each safety/relief valve shall be returned to a state of no
detectable emissions, after emergency pressure release, as soon as is
technically feasible, but no later than 3 calendar days after emergency
pressure release.
(d) Sanoling connections.
(1) Each sampling connection shall be equipoed with a closed ourge
system.
(2) Each closed purge system as required by §50.482(d)(1) shall
return the purged process fluid directly to the process line, or shall
collect the purged process fluid for recycle or disposal without VOC emissions
to the atmosphere.
(a) Open-ended lines.
(1) Each open-ended line shall be equipped with a cap, blind flange,
olug, or a closed valve attached to effect closure of the open end at all
tines except during operations requiring flow through the open-ended line.
(2) Each open-ended line equipped with a second valve attached to
the open end of the process valve, as required in §60.432(e)(l), shall
be operated such that the uostream (process side) valve is closed first,
after operations reauiring flow through the open-ended line.
'O Valves in aas/vaccr service and valves in licht licuid service.
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(1) Each valve shall be checked once per calendar month by the
monitoring methods specified in 560.435(a), with a leak defined as any
measured VQC concentration equal to or greater than 10,000 parts per
mi 11 i on by vol ume (ppmv).
(2) Each valve shall be repaired as scon as possible, but no
later than 15 calendar days after detection of a leak as defined in
§50.482(f)(1); the first attempt at repair shall be made no later than 3
calendar days after detection of a leak.
(2} Each valve that is operated with no detectable emissions, as
determined ay the methods specified in §60.435(b), snail be exempt from
the reauirements of §60.432(f)(1) and (2).
(g) Fugitive emission sources such as pumps and valves in heavy
licuid sar/ice, safety/relief valves in liquid service, flanges, and
agitators shall be repaired as soon as possible, but no later than 13
calendar days after visual, audible, olfactory, or any other type of
detection of VOC leakage to the atmosphere; the first attempt at repair
snail be made no later than 3 calendar days after detection of VOC
leakage.
('-1} Delay of repair.
(1) Requests for delay of repair beyond 15 calendar days after
detection of the leak nay be made as provided in §60.434(a).
(2) Delay of repair will be allowed only if the .-ecair is technical1;/
•^feasible without a process unit shutdown.
'-'; .- determination of equivalence of alternative reans o~ emission
'•mitition to the ~scui rartents 3f i60.-32fa}, 'c1, ':', ':'•, (5), •'-•, ~r.d
'i- *:av :e .-ecuested as :rcv*iac in if0.^35.
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§60.433 Recordkaeping Requirements.
Each owner or operator subject to the provisions of this subpart shall
comply with the following recordkeeping requirements.
(a) For each calibration of the VOC detection instrument
as required in §60.485, the following information shall be recorded in a
calibration log and shall be kept for two years —
(1) the compositions (species and concentrations) of the calibration
standard gases as required in §60.485; and
(2) the instrument identification number and the observed con-
centration response for each calibration gas; and
(3) a description of adjustments needed to reconcile instrument
response to standard gas concentrations.
(b) For each source found to be leaking VOC as specified in
§60.482(a), (b), (f), and (g) --
(1) a weatherproof and readily visible tag shall be attached to the
leaking source; the tag shall be narked with a source identification
number, the date of discovery of the leak, and the dates of all attempts
to repair the leak; and
(2) the tag may be removed after repair of the leak.
(c) For each source found to be leaking VOC as specified in
§60.482(a), (b), (f), and (g) the following information shall be recorded
in a survey log and shall be kept for two years —
(1) the instrument and operator identification numbers and the
source identification number; and
/b
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(2) the data of discovery of the laak and the datas of each attempt
to repair the leak; and
(3) the naximum VOC cpncentrations detected by Method 21 after
each recair attempt; and
(4.) "repair delayed" if a leak is not repaired within 15 calendar
days after discovery of the leak.
(d) The following information pertaining to equipment specifications
as required in §60.4S2(a), (b), (d), and (e) shall be recorded in a
aeraanent log —
(1) the dates of installation and startup of the specified
acuipnent; and
(2) the dates and descriptions of any repair or other changes made
to the required eauipment; and
(3) the dates and descriptions of any failures of the reauired
equiprssnt; and
(4.) the dates of all repair attempts after failure of the required
acuicrent, ana the date of successful reoair.
(e) The following information pertaining to the design recuirements
for control devices as recuired in §6C.432(a) and (b) shall be recorded
in a permanent log —
(1) the design specifications for the control devices; and
(2) the dates and descriptions of any chances in the design soeci-^ca
~or "he control devices.
•' -'' "ha -allowing infcr-'aticn oertainirg to a";: "eaxs not -acai-ac
be^o**? *i ca'andar davs after discover*-' of the :aak ihall be recor^ec- *n
2 Je* aved "acair "oc and shaT* :a
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(1) the source identification number and the date of discovery of
the Teak; and
(2) the dates of all attempts to minimize VOC emissions from the
leak; and
(3) the reasons for unsuccessful reoair of the leak; and
(4) the expected date of successful repair of the leak; and
(5) the date of a request for delay of repair of the leak; and
(6) the date of successful repair of the leak.
(g) The following information pertaining to all fugitive emission
sources subject to emission limits of no detectable emissions, as
required in §50.482(a), (b), (c), and (f) shall be recorded in a
permanent log —
(1) the dates of each verification test for "no detectable emissions"
status as determined by the methods specified in §50.435(b); and
(2) the ambient background level measured during each verification
test as recuired in §5C.483(g)(1); and
(3) the maximum VOC concentration measured at the source during
each verification test as reauired in §50.483(g)(l).
(Sec. 114 of the Clean Air Act as amended (*2 U.S.C. 7414).)
§60.434 Reporting Requirements.
Each owner or operator subject to the provisions of this subpart
shall comply with the following reporting requirements.
(a) The following information shall be resorted to the Administra-cr
during a request for delay in repair of a leak beyond 15 calendar days
a-tar detection of the leak.
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(1) the source identification number and the date of discovery of the
•eak; and
(2) the dates of attempted reoairs and the maximum VOC concentrations
detected by Method 21 after each attemoted repair of the leak; and
(2) tne reasons for unsuccessful repair of the leaking sources
and the expected dates when repair can be accomplished.
(b) The information recorded as required in §50.433(4), (f), and
(g) shall be reported quarterly to the Administrator.
(Sec. iH of the Clean Air Act as amended (42 U.S.C. 741 i).)
§50.485 Test Methods and Procedures.
'Each owner or operator subject to the provisions of this subpart
shall comply with the following test method and procedure recuirements.
(a) Fugitive emission monitoring as required in §5Q.4S2(a), and
•;f) shall comply with the following requirements.
(1) The VOC detection instrument shall ^eet the aoaiicabla performance
criteria of Method 21.
(2) The instrument shall be calibrated by the methods soecif'ed in
"ethod 21 .
(2} Calibration gases shall be —
(A) zero air (less than 5 ppmv of VOC in air); and
(3; mixtures of n-hexane and air at concentrations of —
fi) approximately :CC ocmv n-hexane; and
'.*'•; aooroxinataly ';CCC ppmv n-hexane.
—' The "Tstr'jmsfTC sha'l be calibrated before snc iftsr sac." ta"'"1/
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(5) The instrument probe shall be traversed around all potential
leak interfaces as close to the interface as possible.
(b) When fugitive emission sources are tested for verification of
no detectable emission status as required in §60.482(a), (b), (c), and
(f), the testing shall comply with the following requirements:
(1) The requirements of §60.485(a)(l), (2), (3), and (4) shall
apply.
(2) The ambient background level shall be determined, as defined
in Method 21.
(3) The instrument probe shall be traversed around all potential
leak interfaces as close to the interface as possible.
(Sec. 114 of the Clean Air Act as amended (42 U.S.C. 7414).)
§60.436 Equivalence of Alternative Means of Emission Limitation.
(a) Each owner or operator subject to the provisions of this subpart
^ay apply to the Administrator for determination of equivalence for any
alternative means of emission limitation that achieves a reduction in
emissions of VOC at least equivalent to the reduction in emissions of VOC
achieved by the controls required in §60.482(a), (b), (d), (e), (f), and (g),
(o) Determination of equivalence to the equipment requirements of
560.432(a), (b), (d), and (e) will be evaluated by the following
guidelines:
(1) Each owner or ooerator applying for an equivalence determination
shall be responsible for collecting and verifying emission test data to
show equivalence of any alternative means of emission limitation
to the requirements of ?50.^S2(a), (b), (d), or (e).
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(2) The Administrator will compare emission tast data for the
alternative means of emission limitation to emission tast data for the
equipment raauirements of §60.432(3), (b), (d), or (a).
(2) The Administrator nay condition the approval of equivalence
on retirements that may be necessary to assure proper operation and
maintenance of the alternative means of emission limitations.
(c) Determination of equivalence to the work practices required in
§60.£82(f) will be evaluated by the following guidelines:
(1) Each owner or operator applying for an ecuivalence determination
shall be responsible for collecting and verifying emission tast data to
show eauivalenca of an alternative Cleans of emission limitation to the
requirements of fS0.432(f).
(2) For each affected facility, the emission reduction achieved by
the requirements of §60.432(f) shall be determined for a rrinimum oeriod
of 12 months. A quantitative performance level shall be determined that
.ascribes the emission reduction achieved by the retirements of §SC.432(f}
(2) For each affected facility, the emission reduction achieved
by any alternative means of emission limitation shall be determined rcr 2
minimum period of 12 months.
(-} Each owner or ooeratcr apolying for a determination of
equivalence shall commit to compliance with a performance level that
rrev idas for emission reductions ecual to or greater than the emission
"eductions achievable by the requirements of 55C.-32'"'.
(5; "he Administrator v^"" ccroare quantitative per^ormanca 'eve^s
~cr t"e alternative "eans of er'issicn 1 imitation 13 cy.in^itativa
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performance levels for the work practices required in §60.482(f).
(5) The Administrator nay condition the approval of equivalence
en requirements that may be necessary to assure proper operation and
maintenance of the alternative means of emission limitation.
(d) When a request for determination of equivalence is received,
the Administrator will provide for notice and opportunity for public
hearing. After notice and opportunity for public hearing, the Administrator
will determine the equivalence of an alternative means of emission
limitation and will publish the determination in the Federal Register. .
2. 3y amending Appendix A of Part 50 by adding Reference Method 21
as follows:
Appendix A - Reference Methods
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METHOD 21. DETERMINATION OF VOLATILE ORGANIC
COMPOUND LEAKS
1 . Applicability and Principle
1.1 Applicability. This method applies to the determination of
volatile organic compound (YOC) leaks from organic process equipment.
These sources include, but are not limited to, valves, flanges and other
connections, pumps and compressors, pressure relief devices, process
drains, open-ended valves, pump and compressor seal system degassing
vents, accumulator vessel vents, and access door seals.
1.2 Principle. A portable instrument is used to detect YOC leaks
from individual sources. The instrument detector is not specified, but
it must meet the specifications and performance criteria contained in
paragraph 2.1.
2. Apparatus
2.1 Monitoring Instrument. The monitoring instrument shall be as
f o 11ows:
2.1.1 Specifications.
a. The YOC instrument detector shall respond to the organic
compounds being processed. Detectors which may meet this requirement
include, but are not limited to, catalytic oxidation, flame ionization,
infrared absorption, and photoionization.
b. The instrument shall be intrinsically safe for operation in
explosive atmospheres as defined by the applicable U.S.A. Standards
(a.:., National electrical Cede by the National :rire Prevention
Association).
c. The instrument shall be able to measure the leak definition
concentration saecified in the reculation.
S3
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d. The instrument shall be equipped with a pump so that a continuous
sample is provided to the detector. The nominal sample flew rate shall
be 1-3 liters per minute.
e. The scale of the instrument meter shall be readable to _+5
percent of the specified leak definition concentration.
2.1.2 Performance Criteria. The instrument must meet the performance
criteria given in Table 21-1. The definitions and evaluation procedures
for each parameter are given in Section 4.
TA3LE 2U1. MONITORING INSTRUMENT PERFORMANCE CRITERIA
Parameter Specification
1. Zero drift (2-hour) <_ 5 ppmv
2. Calibration drift (2-hour) <_ 5% of the calibration gas value
3. Calibration error <_ 5% of the calibration gas value
4. Response time <_ 5 seconds
2.1.3 Quality Assurance. The instrument shall be subjected to the
performance evaluation test prior to being placed in service and every 6
months thereafter, and after any modification or replacement of tha
instrument detector.
2.3 Calibration Gasas. The monitoring instrument is calibrated in
terms of parts per million by volume (ppmv) of the compound specified in
the applicable regulation. The calibration gases required for monitoring
and instrument performance evaluation are a zero gas (air, <3 ppmv VOC)
and a calibration gas in air mixture approximately equal to the Issk
definition specified in the regulation. If cylinder calibration gas
mixtures are usad, they must be analyzed and certified by the manufacturer
to be within ^-2 percent accuracy. Calibration gases may be prepared
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by the user according to any accepted gaseous standards preparation
procedure that will yield a mixture accurate to within _*2 percent.
Alternative calibration gas species may be used in place of the
cjl'ibration compound if a relative response factor for each instrument
is determined so that calibrations with the alternative species may be
expressed as calibration compound equivalents on the meter readout.
3. Procedures
3.1 Calibration. Assemble and start up the VOC analyzer and
recorder according to the manufacturer's instructions. After the appro-
priate warmup period and zero or internal calibration procedure, introduce
the calibration gas into the instrument sample probe. Adjust the instru-
ment t-neter readout to correspond to the calibration gas value.
3.2 Individual Source Surveys.
3.2.1 Case I - Leak Definition Based on Concentration Value.
Place the probe inlet at the surface of the component interface where
leakage could occur. Move the probe along the interface periphery while
observing the instrument readout. If a concentration reading greater
than the leak definition in the regulation is cbtai:-..:-d, record and
resort the result as specified in the regulation reporting requirements.
Examples of ths application of this general technique to specific
equipment types are:
, a. Valves—The most common source of leaks from valves is at the
seal between the stem and housing. Place the probe at the interface
where the stam axits the packing gland and sa.T!p"i the stem circumference.
Also, place the prcba at the interface cf the packing gland taka-jp
flar.ge saac and sample the periphery. *.n addition, survey valve housings
of -nu! tip art assembly at the surface of »1" i near-aces where leaks can
cccur.
as
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b. Flanges and Other Connections—For welded flanges, place the
probe at the outer edge of the flange-gasket interface and sample around
the circumference of the flange. Sample other types of nonpermanent
joints (such as threaded connections) with a similar traverse.
c. Pumps and Compressors—Conduct a circumferential traverse at
the outer surface of the pump or compressor shaft and seal interface.
If the source is a rotating shaft, position the probe inlet within one
centimeter of the shaft-seal interface for the survey. If the housing
configuration prevents a complete traverse of the shaft periphery,
sample all accessible portions. Sample all other joints on the pump or
compressor housing where leakage can occur.
d. Pressure Relief Devices—The configuration of most pressure
relief devices prevents sampling at the sealing seat interface. For
those devices equipped with an enclosed extension, or horn, place the
probe inlet at approximately the center of the exhaust area to the
atmosphere for sampling,
e. Process Drains—For open drains, place, the probe inlet at
approximately the center of the area open to the atmosphere for sampling.
For covered drains, place the probe at the surface of the cover interface
and conduct a peripheral traverse..
f. Open-Ended Lines or Valves —Place the probe inlet at approxi-
mately the center of the opening to the atmosphere for sampling.
g. Seal System Degassing Vents and Acrumulator Vents — Place the
orobs inlet at apcroximataly the center of the opening to the atmosphere
for sampling.
h. Access Cccr Seals —Place the probe inlet at the surface of the
door seal interface and conduct a oeripheral traverse.
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3.2.2 Case II-Lsak Cafiniticn 3asad on "No Oetactaola Emission".
a. Satanrrine the local ambiant concentration around the scurca by
moving tiia probe inlet randomly upwind and downwind at distance of ona
to two meters frorr. the sourca. If an interference exists with this
detar.r.ination cue to a nearby emission or leak, the local ambient
concentration may be determined at distances closer to the sourca, but
in no case shall tha distance be less than 25 cantimetars. Note the
ambient concentration and then move the probe in! at to the surface of
the sourca and conduct a survey as described in 3.2.1 a-h. If a concen-
tration increasa greater than 1 percant of the concantratlon-basad leak
definition is obtained, record and report th, -asults as spaci fiad""by
the regulation.
b. For those cases where the regulation requires a specific davica
installation, or that specified vents b"e ducted or piped to a control
device, the existence of thasa conditions sRall b'e visually confirmed.
Whan the regulation also requires that no detectable emissions exist,
visual observations and sampling surveys are required. Examples of this
technique are:
i. Pump or Compressor Seals—If applicable, determine the type of
shaft seal. Perform a survey of the local area ambient VCC concan-
tration and determine if detectable emissions axi'st as described in
3.2.2.a.
ii. Seal systam degassing vents, accumulator vassal vents, pressure
.-eliaf devices — If aop'icable, obsarva -.vhether or net the app'i^ac'a
duc.-i"ic or pioir.g exists. Also, determine if any scurcas axist in tha
•duct-rig or piping where snissicns could occur prior to the contr-1
dav:ca. If "he racuirad ducting or piping exists and there are .-.o
sourcas of v/hare -.he anissions could 'Pe venzad to the at-rossr.era pr-or
.•57
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to the control devica, then it is presumed that no detectable emissions
are present.
4. Instrument Performance Evaluation Procedures
4.1 Definitions.
4.1.1 Zero Drift. The change in the instrument meter readout over
a stated period of time of normal continuous operation when the VOC
concentration at the time of measurement is zero.
4.1.2 Calibration Drift. The change in tile instrument meter
readout over a stated period of time of normal continuous operation when
the VOC concentration at the time of measurement is the same known
upscale value.
4.1.3 Calibration Error. The difference between the VQC concen-
tration indicated by the meter readout and the known concentration of a
test gas mixture.
4..1..4 Response Time. The time interval from a step change in VOC
concentration at the input of the sampling system to the tirre at which
95 percent of the corresponding final value is reached as displayed on
the instrument readout meter.
4.2 Evaluation Procedures. At the beginning of the instrument
performance evaluation test, assemble and start up the instrument
according to the manufacturer's instructions for recommended warmu-p
period and preliminary adjustments.
4.2.1 Zero and Calibration Drift Test. Calibrate the instrument
per the manufacturer's instructions using zero gas and the specified
calibration gas. Record the lime, zero, and calibration gas readings
(example data sheet shown in Figure 21-1). Aft...- 2 hours of continuous
operation, introduce zero and calibration gases to the instrumer.t.
38
-------
Record the zero and calibration gas meter readings. Repeat- for three
additional 2-hour periods.
4.2.2 Calibration Error Test. Make a total of nine measurements
by alternately using zaro gas and the specified calibration gas. Record
the meter readings (example data sheet shewn i'n Figure 21-2).
4.2.3 Response Time Test Procedure. Introduce zero gas into the
instrument sample probe. Wnen th'e meter reading Has stabilized, switch
quickly to the specified calibration gas. Measure the time from concen-
tration switching to 95 percent of final stable reading. Perform this
test sequence three times and record the results (example data sheet
given in Figure 21-.3).
4.2.4 The calibration error test and the response time test may be
performed during the zero and calibration drift test.
4.3 Calculations. All results are expressed as mean values,
calculated by:
— r x
n 1: i <
Where:
x. = Value of the measurements.
Z - Sum of the individual values.
7 3 Mean value.
n = Number of data points.
The specific calculations for each performance parameter ;r2 indie:
on the respective exa-pla da-a sheet gfven in Figures 2*-l , ?"-2. and
-------
Instrument ID:
Calibration Gas Data:
ppmv
Date and Time
Zero
Reading
Zero
Drift
^.Calibration
Gas Reading
Calibration
Drift
Start
1.
2.
3.
4.
Mean (1)
Value:
Zero
Drift
_ppmv
100 =>
Til
Absolute Value
Figure 21-1. Zero and Calibration Drift Determination
-------
Instrument ID
Calibration Gas Data
com
Run Calibration Gas Instrument Metar .Difference^ '
Mo. Concentration, ppm Reading, ppm ppm
1.
2.
7.
a.
9.
"aa.n Diffaranca
C.Hbr.«on Zrror
TOO
• •'Calibration Gas Concentration - Instrument Reading
•""'Absoluta Value
Figure 21-2. Calibration Errcr* Dstarr-lr^i c: en
31
-------
Instrument ID
Calibration Gas Concantration
95% Rasponsa Tima:
1. Seconds
2. Seconds
3. Seconds
Mean Response Time Seconds
Figure 2J-3.'. Response Tima Detennination
92
-------
3. 3y adding Appendix E as follows:
Appendix E - Synthetic Organic Chemicals Manufacturing Industry.
1
2
-»
*.
w
4-
5
6
•»
3
,-^
10
n
12
13
1 4
13
15
17
13
19
20
21
22
/ *.
OCPDB No.*
20
30
40
50
65
70
30
90
100
no
120
125
130
140
150
150
170
180
185
190
200
210
220
Chemical
Acetal
Acataldehyde
Acataldol
Acstamide
Acetanilide
Acetic acid
Acetic anhydride
Acetone
Acetone cyanohydrin
Acetonitrile
Acatnphenone
Acetyl chloride
Acatyl ene
Acrolein
Aery 1 amide
Acrylic acid and asters
Acrylonitrila
Adi pic acid
Adiponitrila
Alkyl naphtha lanes
Allyl aiccncl
Ally! chiorlce
Aminocenzoic acid
"The GCPQS Numbers are rafarenca Indicas assigned ~z -r.e various chemica's
in -ne Organic Chemical P-cducars Data 3ase developed by E?A.
-------
OCPDB No. Chemical
24
25
25
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45 '
45
47
48
49
230
235
240
250
260
270
280
290
300
310
320
330
340
350
360
370
380
390
400
410
420 .
430
440
450
460
430
Ami noethy 1 ethanol ami ne
p-aminophenol
Amy! acetates
Amy! alcohols
Amy! amine
Amyl chloride
Amy! mercaptans
Amyl phenol
Aniline
Aniline hydrochloride
Anisidine
Anisole
Anthranilic acid
Anthraquinone
Benzaldehyde
Benzamide
Benzene
Benzenedisulfonic acid
Senzenesulfonic acid
Senzil
Benzilic acid
Senzoic acid
Benzoin
Senzonitri le
Senzophenone
Benzotri chloride
94
-------
QCPC5 No. Chemical
-•- r+
:ju
'j'i
52
33
54
-» •*
w *•*
55
57
53
5?
50
51
52
53
54
55
55
57
53
59
70
71
^«
/ i
/ 0
71
7;
4go
500
510
520
530
540
550
560
570
530
590 .
592
600
630
640
530
550
570
530
590
700
710
750
750
770
7SC
Senzoyl chloride
Senzyl alcohol
3enzyl amine
3enzyl benzoata
Senzyl chloride
aenzyl di chloride
Siphenyl
Sisphenol A
Sromobenzene
Sromonaph tha 1 ene
Butadiene
1-butene
n-butyl acatata
n-butyl acrylata
n-butyl alcohol
s-butyl alcohol
t-butyl alcohol
n-butyl ami ne
s-butyl amine
t-butyl amine
p-tert-butyl benzoic acid
1 ,3-butylane glycol
n-butyraldehyde
Butyric acid
3utyric anhydride
Sutyronitrile
-------
OCPDB No. Chemical
76
77
73
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
785
790
800
810
820
840
850
860
370
880
890
900
905
910
920
921
930
940
950
951
960
964
965
970
980
990
Caprolactam
Carbon disulfide
Carbon tetrabromide
Carbon tetrachloride
Cellulose acetate
Chloroacetic acid
m-chloroaniline
o-chloroaniline
p-chloroaniline
Chlorobenzaldehyde
Chlorobenzene
Chlorobenzoic acid
Chi orobenzotri chl ori de
Chlorobenzoyl chloride
Chlorodifluoroethane
Ch 1 orodi f 1 uoromethane
Chloroform
Chloronapthalene
o-chloroni trobenzene
p-ch 1 oroni trobenzene
Chlorophenols
Chloroprane
Chlorosulfonic acid
ai-chloro toluene
o-chlorotoluene
p-chloro toluene
-------
CC.-CS No. Chemicals
102
103
104
105
105
107
ioa
109
no
in
112
113
114
115
115
117
113
119
120
121
122
122
124
125
125
127
992
1000
1010
1020
1021
1030
1040
1050
1060
1070
ioao
1090
1100
1110
1120
1130
1140
1150
11 50
1170
nao
1190
12CQ
1210
» ^ ^ -
i £ i 2
1215
Chlorotri fluorcme thane
ui-cresol
c-crssol
p-crasol
Mixed cresols
Cresylic acid
Cro tonal dehyde
Cro tonic acid
Cumene
Cumene hydroperoxide
Cyanoacetic acid
Cyanogen chloride
Cyanuric acid
Cyanuric chloride
Cyclohexane
Cyclohexanol
Cyclohexanone
Cyclohexene
Cyclohexylamine
Cyclooctadiene
Decanol
Oidcatcne slcchol
Qicinincfcenzoic acid
jichloroaniT-ine
.Ti-di chl crobanzane
o-aichlorcbanzsne
-------
OCPDB No. Chemical
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
1220
1221
1244
1240
1250
1270
1280
1290
1300
1304
1305
1310
1320
1330
1340
1360
1420
1430
1440
1442
1444
1450
1460
1470
1430
1490
p-di ch 1 orobenzene
Di chl orodi f 1 uorome thane
1 ,2-dichloroethane (EDC)
Dichloroethyl ether
Dichlorohydrin
Dichloropropene
Dicyclohexylamine
Di ethyl ami ne
Oi ethyl ene glycol
Di ethyl ene glycol di ethyl ether
Di ethyl ene glycol dimethyl ether
Di ethyl ene glycol monobutyl ether
Di ethyl ene glycol monobutyl ether acetate
Diethylene glycol monoethyl ether
Di ethyl ene glycol monoethyl ether acetate
Diethylene glycol moncmethyl ether
Di ethyl sulfate
Difluoroe thane
Diisobutylene
Diisodecyl phthalate
Diisooctyl phthalate
Oiketene
Dimethyl ami ne
M ,N-dimet.hyl am' 1 i ne
N,N-dimethyl ather
N .'{-dimethyl formamide
98
-------
OCPOB No. Chemical
154
155
155
.157
153
159
160
151
152
153
154
155
155
167
153
159
170
171
172
173
174
1 73
1 75
1 77
173
1495
1500
1510
1520
1530
1540
1545
1350
1560
1570
1580
1590 '
1600
1610
1520
1630
1640
1650
1560
1661
1670
1530
1590
17CO*
1710
Dimethylhydrazine
Dimethyl sul fata
Dimethyl sul fide
Dimethyl sulfoxide
Dimethyl tarephthalata
3,5-dinitrobenzoic acid
Oinitrophenol
Dinitro toluene
Oioxane
Oi oxo lane
Oiphenylamine
Diphenyl oxide
Oiphenyl thiourea
Dipropylene glycol
Dodecane
Dodecyl aniline
Qodecyl phenol
Epichlorohydrin
Ethanol
Ethanol amines
Ethyl acatata-
ctiiyl acatoacatata
Ethyl aery Tata
Ethyl inine
Ethvlbenzane
99
-------
OCPDB No. Chemicals
179
',80
131
182
133
184
185
136
187
138
189
190
191
192
193
194
195
196
197
198
199
2GO
201
202
202
204
1720
1730
1740
1750
1760
1770
1780
1790
1800
1810
1830
1840
1870
1890
1900
1910
1920
1930
1940
1960
1970
1980
1990
2000
2010
2020
Ethyl bromide
Ethyl cellulose
Ethyl chloride
Ethyl chloroacetate
Ethyl cyanoacetate
Ethylene
Ethyl ene carbonate
Ethylene chlorohydrin
Ethylenediamine
Ethylene di bromide
Ethylene glycol
Ethylene glycol di acetate
Ethylene glycol dimethyl ether
Ethylene glycol monobutyl ether
Ethylene glycol monobutyl ether acetate
Ethylene glycol rr.oncet.hyl ether
Ethylene glycol monoethyl ether acetate
Ethylene glycol monomethyl ether
Ethylene glycol moncmethyl ether acetate
Ethylene glycol monophenyl ether
Ethylene glycol monopropyl ether
Ethylene oxide
Ethyl ether
2-ethylhexanol
Ethyl ortho formats
Ethyl oxaiate
100
-------
OCPOB Mo. Chemical
205
205
207
203
209
210
211
212
213
214
215
215
217
218
219
220
221
222
-^ ** -*
2iJ
224
225
225
227
223
229
220
2030
2Q<-0
2050
2060
2070
2073
2090
2091
2100
2110
2120
2145
2150
2160
2165
2170
2130
2190
2200
2210
2240
2250
2250
2251
2270
2230
Ethyl sodium oxalacatata •
Formaldehyde
Formamide
Formic acid
Fumarfc acid
Furfural
Glycarol (Synthetic)
Glycsrol dichlorohydrin
Glycarol tri ether
Glycine
Glyoxal
Hexachlorobenzane
Hexach 1 oroe thane
Hexadecyl alcohol
Hexamethy 1 anedi ami ne
Hexamethylene glycol
Hexamethy 1 enetatrami ne
Hydrogen cyanide
Hydroquinane
p-hydroxybenzoic acid
Isoamylene
Isobutanol
Isobutyl acatata
Isobuty lane
Isobutyralcanyde
Isobutyric ic:d
101
-------
QCPDB No. Chemical
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
243
249
250
251
252
253
254
255
256
2300
2320
2321
2330
2340
2350
2360
2370
2380
2390
2400
2410
2414
2417
2420
2430
2440
2450
2455
2460
2490
2500
2510
2520
2530
2540
Isodecanol
Isooctyl alcohol
Isopentane
Isophorone
Isophthalic acid
Isoprene
Isopropanol
Isopropyl acetate
Isopropylamine
Isopropyl chloride
Isopropyl phenol
Ketene
Linear alky! sulfonate
Linear alkylbenzene
Maleic acid
Maleic anhydride
Malic acid
Mesityl oxide
Metanilic acid
Methacrylic acid
Methallyl chloride
Methanol
Methyl acetate
Methyl acatoacetate
Me thy! ami ne
n-methylani 1 ine
102
-------
QCPG3 Mo. Chemical
237
253
259
250
251
252
253
254
255
255
257
253
259
270
271
272
273
274
273
275
277
273
273
230
2S1
232
2543
2350
2550
2570
2590
2520
2530
2535
2540
2545
2550
2550
2565
2570
2590
2700
2710
2720
2730
2740
2750
2755
2757
2750
2752
2770
'•'ethyl bromide
Methyl butynol
Methyl chloride
Methyl cyclohexane
Methyl cyclohexanone
Methylene chloride
Methylene di am' line
Methylene diphenyl diisocyanate
Methyl athyl ketone
Methyl fonnata
Methyl isobutyl carbinol
Methyl isobutyl ketone
Methyl methacrylata
Methyl centynol
a-methy 1 s ty r«ne
Morpholine
a-napnthalene sulfcnic acid
3-nannthalene sulfonic acid
a-naphthol
3-napnthol
Meopentanoic acid
o-nitrcaniline
p-nitroani line
o-nitrcanisols
p-nitro anise la
N'i trcbenzsne
103
-------
CCPQS No. Chemical
283
284
2S5
236
237
288
289
290
291
292
293
294
295
296
297
298
299
3CO
301
302
303
304
305
306
307
308
2780
2790
2791
2792
2795
2800
2810
2S20
2830
2840
2850
2851
2855
2860
2882
2890
2900 •
2910
2920
2930
2940
2950
2960
2970
2973
2975
Nitrobenzene acid (o, m, and p)
Ni troethane
Nitromethane
Nitrophenol
Nitropropane
Nitrotoluene
- Nonene
Nonyl phenol
Octyl phenol
Paraldehyde
Pentaerythritol
n-pentane
1-pentene
Perch! oroethylene
Perchloromethyl mercaptan
o-phenetidine
p-phenetidine
Phenol
Phenolsulfonic acids
Phenyl anthranilic acid
Phenyl enedi ami ne
Phosgene
Phthal ic anhydride
Phthalirr.ide
3-picoline
Piperazine
104
-------
GCPG3 No_._ Chemical
209
310
211
212
213
314
315
316
317
213
319
320
321
222
323
324
325
325
227
323
329
330
231
222
322
224
~!2C
3CCO
2010
2025
20S3
2056
3070
3073
3080
3090
3100
3110
3111
3120
3130
3140
3150
2150
3170
3130
3131
3190
3191
52CO
2210
2220
2220
7-5 ,m
-i-rvj
Polybutenes
Polyethylene glycol
Polypropylene glycol
Propionaldehyde
Propionic acid
n-propyl alcohol
Propylanrine
Propyl chloride
Propylene
Propyl ene chlorohydrin
Propylene di chloride
Propylene glycol
Propylene oxide
Pyridine
Quinone
Resorcinol
Resorcylic acid
Salicylic acid
Sodium acatata
Sodium benzoata
Sodium carboxymethyl cellulose
Sodium chloroacetats
Sodium fomata
Sodium pnanata
Soraic acid
Styrsne
Succinic acid
105
-------
OCPDB Mo. Chemical
336
337
338
339
340
341
342
343
344
345
346
347
340
349
350
351
352
353
354
355
356
357
353
359
3250
3251
3260
3270
3230
3290 & 3291
3300
3310
3320
3330
3335
3340
3341
3349
3350
3354
3355
3360
3370
3380
3381
3390,3391
& 3393
3395
3400
Succinitrfle
Sulfanilic acid
Sulfolane
Tannic acid
Terephthalic acid
Tetrachl oroethanes
Tetrachlorophthalic anhydride
Tetraethyllead
Tetrahydronapthal ene
Tetranydrophthalic anhydride
Tetramethyllead
Tetramethy 1 enedi ami ne
Tetramethy 1 ethyl enedi ami ne
Toluene
Toluene-2,4-diamine
To! uene-2 ,4-di i socyanate
Toluene diisocyanates (mixture)
Toluene sulfonamide
Toluene sulfonic acids
Toluene sulfonyl chloride
To lui dines
Trichlorobenzenes
1 ,1 ,1-trichloroethane
1 ,1 ,2-trichloroe thane
106
-------
OCPGB No. Chemical
250
351
252
263
254
365
365
267
258
269
370
371
372
373
374
373
375
377
373
3410
2411
2420
2430
3450
3460
3470
2430
3490
3500
3510
3520
3530
3540
2541
3560
2570
2530
3590
Tri chloroetny lane
Tri ch 1 orof 1 uo rome inane
1 ,2,3-trichloropropane
1 ,1 ,2-trichloro-l ,2,2-triflucrcethane
T pi ethyl ami ne
Tpiethylene glycol
Tpiethylene glycol dimethyl ether
Tpiisobutylene
Tri me thy! ami ne
Urea
Vinyl acatata
Vinyl chloride
Vinylidene chloride
Vinyl toluene
Xy lanes (mixed)
o-xylene
p- xy lane
Xylanol
Xylidine
------- |