United States     Industrial Environmental Research EPA-n'OO 980013
         Environmental Protection  Laboratory         M.irch 1980
         Agency       Research Tnanejle Park INC 27711
         Research anil
v>EPA   Proceedings:
        Symposium on
        Atmospheric Emissions
        from Petroleum Refineries
        (November 1979,
        Austin, TX)

        Interagency
        Energy/Environment
        R&D Program Report

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Research reports of the Office of Research and Development, U.S. Environmental
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The nine series are:

    1. Environmental Health Effects Research

    2. Environmental Protection Technology

    3. Ecological Research

    4. Environmental Monitoring

    5. Socioeconomic Environmental Studies

    6. Scientific and Technical Assessment Reports (STAR)

    7  Interagency Energy-Environment Research and Development

    8. "Special" Reports

    9. Miscellaneous Reports
This report has been assigned to the MISCELLANEOUS REPORTS series. This
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                        EPA REVIEW NOTICE
This report has been reviewed by the U.S. Environmental Protection Agency, and
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This document is available to the public through the National Technical Information
Service, Springfield, Virginia 22161.

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                                       EPA-600/9-80-013

                                               March 1980
Proceedings:  Symposium on Atmospheric
    Emissions from  Petroleum Refineries
         (November 1979, Austin, TX)
                   Donald D. Rosebrook, Compiler

                       Radian Corporation
                        P.O. Box 9948
                      Austin, Texas 78766
                     Contract No. 68-02-2608
                         Task No. 76
                    Program Element No. 1AB604
                 EPA Project Officer: Bruce A. Tichenor

               Industrial Environmental Research Laboratory
             Office of Environmental Engineering and Technology
                  Research Triangle Park, NC 27711
                        Prepared for

               U.S. ENVIRONMENTAL PROTECTION AGENCY
                  Office of Research and Development
                     Washington, DC 20460

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                                  ABSTRACT
     The proceedings are a compilation of papers, formal discussions, and
question and answer sessions from the EPA-sponsored Symposium on Atmospheric
Emissions from Petroleum Refineries, November 5-6, 1979, in Austin, Texas.
The symposium focused on results of the petroleum refining environmental
assessment program conducted by Radian Corporation under the sponsorship and
direction of EPA's  Industrial Environmental Research Laboratory, Research
Triangle Park, NC. The 4-year program cost $2.5 million and included extensive
sampling of atmospheric emissions in 13 oil refineries throughout the U.S.
Papers were presented by Radian and EPA on emissions measurement, quality
control, and analysis and application of results. Emphasis was on fugitive
emissions. Formal discussions of each paper were provided: discussers in-
cluded petroleum industry representatives, environmental consultants, and
state environmental regulatory personnel. Each paper and formal discussion
was followed by a question and answer session between the audience and the
presenter.
                                     ii

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TABLE OF CONTENTS
                                                                         Page
ABSTRACT [[[    ii

WELCOME, by fl/t. -Donald  M.  CaftJtton .....................................     1

OPENING COMMENTS , by Dfi. Vonciid V.  RoieMoofe ..........................     3

METHODOLOGY - SAMPLING  AND ANALYSIS OF ATMOSPHERIC EMISSIONS
         FROM PETROLEUM REFINERIES , by C.  V.  Sm-Ltk ....................     5

         REVIEW by R. M. RobeA&> ......................................   62

         QUEST IONS /ANSWERS ............................................   67

QUALITY ASSURANCE AND DEVELOPMENT OF STATISTICAL
         MODELS, by  Lloyd  ?.  PHovoAt ..................................   74

         REVIEW by Kznn&tk Bdk&L ..................... . ................  125

         QUEST IONS /ANSWERS ............................................  130

RESULTS OF MEASUREMENT  AND CHARACTERIZATION OF ATMOSPHERIC EMISSIONS
         FROM PETROLEUM REFINERIES, by FfLCLnk G. MeA-ick ................  135
         REVIEW by James  J.  MoKgeAteA ............. , ...................  187

         QUESTIONS /ANSWERS ............................................  190

REFINERY AIR EMISSIONS  CONTROL TECHNOLOGY,  by W.  'R.ob^ut PhAILLpA ......  195

         REVIEW by J. A.  MuZtuz4 ......................................  256

         QUESTIONS /ANSWERS ............................................  263

CORRELATION OF  FUGITIVE EMISSION RATES FROM BAGGABLE SOURCES
         WITH REFINERY  PROCESS VARIABLES, by R. L.  \\QYlQJl\lOWp ..........  265

         REVIEW by A.  F.  Pope. ........... ---- .........................  307

         QUESTIONS/ANSWERS ............................................  312

THE EFFECT  OF MAINTENANCE PROCEDURES ON THE REDUCTION OF FUGITIVE
         HYDROCARBON EMISSIONS FROM VALVES IN PETROLEUM
         REFINERIES, by R. 6.  WnXhoJloLd. and S.  L. PtiZAton .............  317

         REVIEW by M. R.  OLbOYl ........................................  353


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                                                                      Page

ENVIRONMENTAL ASSESSMENT OF ATMOSPHERIC EMISSIONS FROM
     PETROLEUM REFINERIES, by ff. E. Harris and M. W. Hooper .........  362

     REVIEW by S. S. Wise ...........................................  408

     QUESTIONS/ANSWERS ..............................................  413

CONTROLLING PETROLEUM REFINERY  FUGITIVE EMISSIONS VIA LEAK
     DETECTION AND REPAIR, by B. A. Tichenor, K. C. HustVedt
     and R. C. Weber ................................................  421
     REVIEW by Ivan H. Oilman
                                      IV

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                                  WELCOME


                           Dr. Donald M. CarIton

                       President, Radian Corporation

                               Austin, Texas
          I appreciate this opportunity to visit with you for a few minutes
this morning.  Anyone who shows up at 8:30 on Monday morning to talk about
fugitive emissions has to be very dedicated.  So it is a pleasure to see
so many people.

          The term fugitive emissions and the whole topic means a lot of
things to a lot of different people.  1 would like to give you a little
Radian history on fugitive emissions, because I think it might set the
stage for why we are here this morning.

          At Radian Corporation, fugitive emissions began as a topic of
some interest in the early 70s.  We received a contract from EPA and CEQ to
investigate the environmental impact associated with siting petroleum
refineries.  In particular, refineries sited in coastal areas.  The ground
rules were to make use of existing information.  We were fortunate being
able to find quite a bit of information in the literature about refinery
technology.

          Then we came to the issue of fugitive emissions, and we found two
sources of information about fugitive emissions.  One was some work that
Bernie Steigerwald  and others did in Los Angeles in the late 50s.  The
other was unaccounted for data furnished by API.  Those were fairly tenuous
grounds for the basis of fugitive emission projections, but nevertheless,
that is all we had.   We reported that if you believed that kind of infor-
mation, fugitive emissions were a first class problem.  We reported that
you should be careful with these numbers and that we felt like they did not
mean a whole lot.  But, as those kind of things typically happen, there is
sometimes a matter of interpretation.  All of a sudden, we found that the
name Radian Corporation was the subject of much criticism among oil
companies and petrochemical processors for awhile.

          But, as I am sure each of you know this is indeed an important
topic and has tended to be an emotional topic, because after that
particular report we found ourselves testifying in several hearings on
refinery technology, about the need for addressing the issue of fugitive

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Donald M. Carlton
emission's experimentally.  The EPA and API, of course, were well aware of
the problem.  They got their heads together, and fortunately, all of that
conversation led to where we are today.

          We hope, as a result of these two-day discussions, that we will
be able to come away with a far better understanding of the issue of
fugitive emissions and hopefully "incumber the topic with data" as someone
said.  So, I am hopeful, as I am sure you are, that we will get fugitive
emissions on a much firmer ground.

          So, it is my pleasure to welcome you here today.  I certainly
hope we all have a good two days and want you to know that if there is any-
thing that we can do to make you stay more informative, more enjoyable,
please be sure to let us know.

          Glad to have you.

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                              OPENING COMMENTS


                           Dr. Donald  D.  Rosebrook

                 Senior Program Manager, Radian Corporation

                               Austin,  Texas
          I would like to acknowledge the support of the EPA for providing
the funding for this symposium.  I would like to thank in advance those
people who have so graciously given of their time to be reviewers of these
papers.

          We have had previous symposia on emissions from petroleum refining.
In those cases we have generally invited Industry participation, participa-
tion from other government agencies and from other consulting firms.  In
this case our object is to report completely on the results of the EPA
study conducted by Radian.  In order to give it a more general form, our
format was to invite reviews from  eminently  qualified people in the
industry and from among our competition.  We hope that this meeting will
serve a good purpose for all of you who have attended.

          We started the work which we are going to report upon almost four
years ago, and first went into the field almost three years ago.  We have
had a great deal of cooperation from all parties involved, and we would
also like to acknowledge that; especially the refiners who were so gracious
as hosts in this study.  And we thank them for their participation and their
desire to understand what we were doing and to help us do it.  And it is,
in a very large measure, their assistance which has made this study possible.

          We have visited thirteen refineries to provide the data which
you are going to hear today.  In addition to that we have had contributions
from other refineries, where the work was done under contract to the
refiners, and Radian and the EPA considered the data to be of sufficient
importance to use those pieces which were appropriate in preparing the
results of this study.

          We started with three objectives.  We think that by in large we
have met the requirements of those three objectives.  The first of those
and that which Is probably the most publicized was to determine emission
factors for fugitive emissions from refining activities.  The second was
to evaluate the available control technology for not only fugitive emissions,
but other refining activities which could have atmospheric hydrocarbon

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Donald D. Rosebrook
emissions.  The third objective was to determine precisely what was the
composition of those emissions and to determine whether or not materials,
which were being emitted, posed some type of a human health hazard.

          The presentations which you will hear today and tomorrow will
address these questions, and will show that we have met the objectives of
the study.

          We would like to start today's presentations with a description
of the methodology that was used and we will proceed to the methodology
used in evaluating the data, then show you the data.  We will proceed to
talk about control technology and the other factors which this meeting will
address.

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 C. D. Smith
              METHODOLOGY - SAMPLING AND ANALYSIS OF ATMOSPHERIC

                      EMISSIONS  FROM  PETROLEUM  REFINERIES

                                  C.  D.  Smith
                              Radian Corporation
                                Austin,  Texas


                                   ABSTRACT

           This paper contains a description of the sampling and analytical
methodologies used to sample fugitive emissions and emissions from point
sources in petroleum refineries.  Emphasis is placed on fugitive emissions.
                                    RESUME

           Calvin D. Smith is a Senior Scientist in the Technical Division
at Radian Corporation.  His formal training at Clemson University and the
University of Georgia was in physical-organic chemistry.  He has worked in
industry as Operations Manager of Story Chemical Corporation and as Manager
of Pilot Plants at Velsicol Chemical Corporation.  At Radian Mr. Smith was
Field Supervisor for Refinery Sampling Program.

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 C. D. Smith
             METHODOLOGY - SAMPLING AND ANALYSIS OF ATMOSPHERIC

                     EMISSIONS FROM PETROLEUM REFINERIES


                                  SECTION 1

                                INTRODUCTION


          The purpose of this paper is to describe the sampling and
analytical methodology used while  sampling for atmospheric emissions at
petroleum refineries.  Those methods that are commonly accepted as routine
methods will receive less emphasis than newer techniques.

          Three areas of sampling  took place.

          •    Stack effluents.

          *    Wastewater and cooling tower emissions.

          •    Fugitive emissions  from process unit sources.

These will be discussed in the following sections.

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 C.  D.  Smith
                                  SECTION  2

                               FIELD SAMPLING
FUGITIVE EMISSIONS FROM PROCESS SOURCES

          Baggable sources have been defined as those sources that can be
completely enclosed and sealed in a manner sufficient to prevent any loss of
material to the atmosphere from inside the enclosure or "bag."  These sources
represent the majority of the potential sources selected for testing at each
refinery.  They include valves, flanges, pump seals, compressor seals, drains
and relief devices.


Baggable Source Selection - Important Variables

          Variables thought to affect the fugitive emissions from baggable
sources were classified into choice and correlating parameters.  The vari-
ables were further defined according to availability and usefulness.  Avail-
ability was determined from the degree of difficulty expected when obtaining
the necessary data in the field.  Some information, such as pressure or
temperature, is  readily available.  Other facts, such as age of valve pack-
ing, might be unavailable.

          The final usefulness of a variable in the computation of the fugi-
tive emissions from a refinery was also considered.  Some important variables
were not categorized for sampling because of their lack of ultimate usefulness,
For example, using the age of some equipment as a parameter may not be very
useful.  Most refiners do not know the age of valve packing or flange gaskets,
for example.

          Prioritizing variables according to these criteria allowed the most
significant ones to be determined for each baggable source.  Decisions were
then made concerning which categories should be used to define the types and
numbers of fugitive sources to be sampled.


Site-Specific Sampling Plan

          Structured flexibility formed the tone of the sampling plan.  The
structure assured that all needed measurement and analysis requirements were
efficiently covered.  Flexibility was maintained within a procedural frame-
work to apply what was learned toward subsequent sampling and analysis.

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 C. D.  Smith
          The sampling plan structure consisted of outlining detailed
 procedures before sampling began.  This included:

          •  Identification of process units to be sampled.

          •  Number and type of fittings within units.

          •  Specifying choice and correlating variables (choice
             variables specify sampling categories, while corre-
             lating variables are others we wished to record
             because they might be important).

          •  Developing forms for recording screening, sampling,
             variables, and analysis results.

 Each  site specific sampling plan reflected modifications due to what had been
 learned at previous refineries.

 Baggable Source Selection - Field Selection

          The initial steps of the selection process were carried out prior
 to the start of field sampling.  These steps included the selection of
 individual process units to be sampled, and the development of a format for
 the selection of individual sources.

          The primary goals of the preselection process were to obtain:

          •  A statistically unbiased set of fittings, selected in
             a random manner.

          •  A wide range of correlating parameters or process condi-
             tions for each set of selected fittings.

          The selection of individual baggable sources was done using piping
and instrumentation diagrams or process flow diagrams supplied by the refiner.
Baggable sources included valves, flanges, pumps,  compressors, drains, and
pressure relief devices.  The approixmate number of sources selected at each
refinery was:

               Valves            250 - 300
               Flanges           100 - 750
               Pumps             100 - 127
               Compressors        10 -  20
               Drains             20 -  40
               Relief Devices     20 -  40

          Selecting fittings from the process flow diagrams gave two important
benefits.  First, this method eliminated any bias  which might have resulted
had these fittings been selected in the field.  That  is, fittings which could

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C. D.  Smith
be determined to be leaking by observation were not selected preferentially
over nonleaking fittings or vice versa.  Second, a wide variation in process
conditions was desired.  Using basic knowledge of the process operation, it
was possible to distribute the allotted fittings such that a wide range in
the values of variables thought to affect the emissions rate was obtained.

          The variables chosen for each type of fitting consisted of the
characteristics of the fluid within the fitting and the physical character-
istics of the fitting itself.  Choice parameters were defined as variables
that might directly affect fugitive emissions and were used in selecting the
source distribution.  The choice parameters used for each fitting type at
the first nine refineries are listed in Table 1.

Valve Selection

          The selection method used in the field is detailed below for valves.

          The most difficult choice parameter to select was the valve size.
In most cases, a complete range of valve sizes was not present in an individ-
ual process unit.  However, since many of the same process units were chosen
in several refineries, an exact distribution within each individual unit was
not considered essential.

          In general, all of the different hydrocarbon streams within the
process unit were incorporated into the valve selection process.  When there
was more than one valve for each process stream (as was most always the case),
valves were selected to give a variety of temperature/pressure combinations
for each process stream.

          The selection of valves within each process unit was based on a
format of the type illustrated in Figure 1.  In general, the number of valves
allotted to each final grouping was based roughly on the proportion of valves
in the process unit corresponding to that grouping.  For example, a larger
fraction of the valves would be assigned to the gas/vapor groups in a gas
processing unit than in a lube oil processing unit.


Screening

          In order to minimize the number of sources which were bagged, a
preliminary screening was carried out to determine the need for sampling.
Those sources which were found to be leaking significant amounts of material
were sampled.  When it was determined that the leaks were absent or insignifi-
cant, sampling was not done.  All the choice and correlating variables were
recorded, however, for those sources that were screened but not sampled as
well as for those sampled.  The  values were recorded on formatted data sheets.
An example of these data sheets is shown in Figure 2.

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     C. D.  Smith
   TABLE 1.  RANGE OF CHOICE VARIABLES FOR SCREENED BAGGABLE SOURCES
   Baggable Source
  Choice Variable
      Variable Ranges
    for Screened Sources
  Valves
 Flanges
 Pump Seals
Compressor  Seals
Drains

Relief Valves
 Pressure
 Temperature
 Fluid State
 Service
 Function
 Size

 Pressure
 Temperature
 Fluid State
 Service

 Size

 Pressure
 Temperature
 Capacity
 Shaft Motion
 Seal Type
 Liquid RVP

 Pressure
 Temperature
 Shaft  Motion
 Seal Type
Lubrication Method
 Capacity

Service

Pressure
Temperature
Fluid
 -10 - 3000 psig
 -190 - 925*F
 Gas, Liquid, 2-phase
 In-line,  Open-ended
 Block, .Throttling,  Control
 0.5 -.36  inches

 -14 - 3000 psig
 -30 - 950*F
 Gas,  Liquid,  2-phase
 Pipe,  Exchanger, Vessel,
  Orifice
 1-54 inches

 0 - 3090  psig
 0 - SOOT
 0 - 100;000  gpm
 Centrifugal, Reciprocating
Mechanical Seal, packed seal
 Complete  range

 0 - 3000  psig
 40  - 300*F
 Centrifugal, reciprocating
Packed, labyrinth, mechanical
Hydrocarbon lubricant
 0.06 - 66.0 MMSCFD

Active, Wash-up

0 - 1350 psig
40 - 1100T
Gas, Liquid
                                       10

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  C.  D. Smith
                     Organization of
                    Choice Variables
                            Typical Number of
                             Allotted Valves
  Selected
Process Unit
In Line Valves
    Gas/Vapor Service
      ^Control Valves
                                      4"
                                     4-8"
                                      8"
                            Block Valves
                               •Size
                                      4"
                                     4-8"
                                      8"
    Liquid Service
     ^Control Valves
         I^Size
                  4"
                 4-8"
                  8"
        Block Valves
         \Size  4"
                 4-8"
                  8"
                                     1
                                     2
                                     1
                                     2
                                     4
                                     2
                                                        3
                                                        3
                                                        3


                                                        7
                                                        7
                                                        7
                    Open Ended Valves —Drain Valves    1
                                        Sample Valves   1
                                                       44
                       Figure 1. Typical Valve Selection Format
                                11

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C. D.  Smith
  1.  Radian ID#
               1  23   4   5   6  78
  3.  Refinery ID//
                       2.  Unic
VAKIABU
4. Press

5. Tempi

6. Gas c

7. Line

8. Type



-
2S:
sure, psig

srature, °F

sr liquid (G,

size, in
UE - »«ld
TH - threaded
Ff - f jac face


cube sh^et






L)









1
9 10

13 14











11

15



18


20




12

16

17

19


21
















r , T
[A - iir cnoler
9. Special service o - oci:ic« ?iice

10. Age, yrs

11. Mts. of const. [«-»»J

12. Manufacturer

13. Gasket mtl

-. -•
14. Vibtation 3 - "i?nt
« - ™d«ric«|
[a - Sl»vy J




^a

25

27


29




22

24

26

28


3O

31














  PROCESS FLUID DESCRIPTION:

 15. Nane
         32 33 34  35  36  37 38  39 40  41
 SCREENING DATA:

16. Dace of screening

18. Liquid leak (Y, N)

19. TLV readings  	

20. Max TLV

42  43  44 45  46 47
                      17.  Screening team
                                         48  49
                 SO
                        51  52 53  54 55  56
    Remarks:
             Figure  2.   Data Sheet - Flange
                                          12

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C, D. Smith
Screening Techniques

          There are several techniques that have historically been used to
screen potential sources in the baggable classification for leaks.  These
include visual observation of vapor leaks, visual observation of liquid leaks
or buildup of residue, and spraying with soap solution.  These methods are
commonly used in refineries as a means of identifying those equipment items
in need of maintenance, repair, or replacement.  All these methods are
qualitative, however.  A leak detected by any of these methods will be
relatively significant and would be bagged and sampled.

          Many, if not the majority, of potential baggable emission sources
have skin temperatures above 100°C.  Above this temperature, the technique
of spraying soap solution is unusable since it vaporizes on the hot source.
Any bubbles created by leaking vapors are indistinguishable from those
created by the vaporizing solution.

          In Radian's experience in screening these sources, significant
leakage has been measured where none of the visual methods indicated a leak.
For this reason, a more quantitative estimate of leak rate was required to
adequately screen the selected sources and identify those that require
bagging.


Instrumentation

          A Bacharach Instrument Company J-W Model TLV Sniffer has been found
to be useful for the screening of baggable sources.  This instrument utilizes
a catalytic combustion detector to measure low concentrations of flammable
vapors.  It can detect hydrocarbon concentrations as low as 1.0 ppm.  Three
concentration scales; 0-100 ppm, 0-1000 ppm, and 0-10,000 ppm, are built
into this instrument.  A dilution probe was used when the TLV readings
exceeded 10,000 ppm which allowed readings of up to 100,000 ppm.  The instru-
ment meter displays the result as ppm hexane by volume.  It is battery
operated, self-contained, compact and portable.  The instrument performance
has been very satisfactory.

          A second instrument used to screen for hydrocarbon emissions was
the Century Instrument Company Organic Vapor Analyzer  (Model OVA-108).  This
Instrument utilized a flame ionization detector to measure hydrocarbon
concentrations.

          The role of the OVA was limited to obtaining original screening
values only.  When leaking sources were identified, they were rescreened
with the TLV Sniffer when the sources were sampled.


Dilution Probe

          The probe can also function as a. dilution probe.  This extends the
range of the TLV from 10,000 ppm to 100,000 ppm.  To operate the dilution

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 C.  D.  Smith
probe, the black rubber washer is pulled back to expose the dilution air
intake holes.  In this mode, the meter will read a concentration which is
approximately one-tenth of the actual concentration.

          This dilution factor can be verified by reading the high-range
(xlOO) gas standard with the meter zeroed on the midrange (xlO) scale.  The
dilution factor is calculated as follows:

                             ppmv, calibration gas   ^
          Dilution factor =  —- meter reading     ~ 10


All subsequent screening results are multiplied by the dilution factor
obtained here.  However, if the calculated dilution factor falls between 9
and 11, it is sufficient to use a factor of 10.  This simplifies the screen-
ing process  considerably.


Screening Procedures

          The procedure used for screening with the devices was quite simple.
The sample probe was held as close as possible to the suspected leak source.
This reduced the effect of the wind and increased the reproducibility of the
readings.  The screening procedure differed slightly for  each baggable source
type as discussed below.


Valves—Most of the valves that were selected for screening were either gate,
globe, or control valves.  Hydrocarbon leaks from these valves occur at the
stem and/or the packing gland, as indicated in Figure 3.   Some plug valves
were also selected.  Hydrocarbon leaks from this type of  valve can occur at
the plug square or under the malleable gland.

          Both the stem and the packing gland of selected valves were
screened.  The probe locations used included the four compass points around
the seal, relative to the valve casing.  Thus, a total of eight such readings
were taken for each valve.  In addition, two more readings (one for the stem
and one for the glands) were obtained at a distance of 5 cm from the leak
source.  The probe was rotated in a circular path around the leak source and
the maximum reading was recorded.
Flanges—Flanges were screened by placing the TLV Sniffer probe at two-inch
intervals around the perimeter of the flange.  After locating the maximum
leak point, three additional readings were taken at the remaining compass
points, relative to the location of the maximum leak point.


Pump and Compressor Seals—Pump seals were screened in a manner similar to that
used for screening valves.  Leakage occurs around the rotating shaft at the
                                     14

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C. D. Smith
         Q
Gate, globe, and
control valves are
screened at these
two locations.  Four
readings are taken at
each location.
                            Figure 3.   Gate Valve
                                      15

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 C. D. Smith
 point where it  enters  the  pump housing.  The Bacharach TLV Sniffer probe was
 placed as close as  possible  to the potential leak point around the shaft at
 the pump housing.   Prior to  this, the  instrument was zeroed at ambient condi-
 tions.  Four readings  were taken at points 90° apart around the shaft.  Also,
 the maximum readings,  taken  at a distance of 5 cm, was recorded.  The probe
 was left at each point for a minimum of 5 seconds.  The detection of hydro-
 carbon at a concentration  of 200 ppm at any of the four points resulted in
 the pump being  bagged  and  sampled.

           Large pumps  or pumps in severe services may have two seals, an
 inboard seal and an outboard seal.  In these cases, each seal was screened
 separately.

           The screening procedure for  compressors depended on the accessi-
 bility of the seal  area.   If the seal  area was accessible, the screening
 procedure was identical to that for pumps.  After zeroing at ambient condi-
 tions, the TLV  Sniffer probe was placed at four locations 90° apart around
 the shaft and right at the point where the shaft enters the compressor
 housing.  A hydrocarbon concentration  of 200 ppm or more at any point indi-
 cated the need  for  bagging and sampling of the seal.

           In many cases the  seal area  was enclosed and hydrocarbons leaking
 from the seal were  vented  to the atmosphere or to a vapor recovery system.
 When compressors vented to the atmosphere were encountered, they were
 screened and sampled,  if necessary, at the point where the vent pipe dis-
 charged to the  air.  The TLV probe was positioned at a point located just
 inside the end  of the  vent.

           Compressors  often  have more  than one seal.  Each seal was
 individually screened  and, if necessary, bagged and sampled.


 Pressure-Relief Devices—Only those pressure-relief devices that are vented
 to  the atmosphere were screened.  Those devices that are vented to blowdown
 and  flare systems can  only leak to the atmosphere at the connecting flanges,
 and  these leak  sources are considered  to be flanges.

           The relief valves  were screened using the Bacharach TLV Sniffer.
After  zeroing the instrument at ambient conditions, the probe was placed at
two-inch  intervals  around  the perimeter of the vent (horn) just at the exit.
The  probe was also  placed  at the center of the vent opening at a level with
the vent  exit.

          When  the  top  of  the horn was inaccessible, a screening value was
obtained  at  the weep hole, located near the bottom of the horn.  The probe
was  left  at  each location  for a minimum of 5 seconds.  If a hydrocarbon
concentration of 20 ppm was  detected during this 5-second period, the probe
was  left  in  place for  at least an additional 5 seconds.  The maximum TLV
readings  during  the 10-second period were recorded.  If any readings exceeded
 200  ppm,  the relief device was to be sampled and bagged.
                                      16

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C. D.  Smith
Common Operating Problems - TLV—There are several situations which may arise
that could cause difficulty in obtaining proper results.  Some of the more
common problems are discussed below.

          On some TLV Sniffers, the zeros for each of the three concentration
ranges may not coincide.  If this is the case, the magnitude of the differ-
ence should be determined and screening values adjusted accordingly.  For
example, assume that the meter has been zeroed on the (xl) scale and a read-
ing of 500 ppm is obtained when the meter is switched to the (xlOO)  scale.
In this case, 500 should be subtracted from all readings taken on the (xlOO)
scale.  Small differences from one scale to the next, however, may be
neglected.

          In some cases, it may be difficult to determine whether a meter
response is due to high ambient air hydrocarbons or a source leak, particu-
larly when the ambient reading is highly variable.  This problem is commonly
experienced in compressor houses or other enclosed areas.  One method to
determine if the source is leaking is to place the probe at the leak source
and then remove it from the leak source.  This operation is repeated at
regular intervals.  If the movement of the needle corresponds to the place-
ment and removal of the probe  (keeping in mind the two-second time lag), the
source is probably leaking.  The screening value is then determined by sub-
tracting the ambient reading from the measured screening result.  A variety
of such situations may be encountered and a judgment on the part of the
operator may be required to obtain a representative reading.

         Occasionally, a source may be encountered which has a highly variable
leak rate.  The design of the TLV Sniffer tends to damp these variations some-
what; however, some oscillation in the reading may still occur.  In general
the maximum sustained reading or the maximum repeatable reading should be
recorded.  Again, a judgement on the part of the operator may be required to
obtain a representative reading.

          One further screening difficulty may arise when screening sources
contain heavier hydrocarbon streams, particularly on hot sources.  When these
valves are screened, some of the vapor tends to condense on the interval
probe-sample hose surfaces.  The response of the meter is considerably slower
for these sources relative to that seen when screening lighter hydrocarbons.
And, the meter may require more time to return to zero.  When screening this
type of source, the meter should be allowed to stabilize before recording the
result.  The meter should be allowed to return to about 20 percent of the
recorded value before moving to the next screening point.  Prior to screen-
ing the next source, sufficient time should be allowed for the meter to
stabilize or return to zero.  Often the meter will not return completely to
zero and a considerable adjustment may be required.

          Under no circumstances should the end of the probe be placed in
contact with liquid.  If liquid is drawn through the sample hose, it will
damage the catalytic element.  A liquid trap, connected between the TLV
                                     17

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 C.  D.  Smith
Sniffer and the sample hose, was used.  This gave some protection against
damage to the element.


Sampling Train

          The method preferred for sampling leaks from baggable sources is
the dilution or flow-through method.  The sampling train that was used in
this method is shown in Figure 4.  The train was contained on a portable
cart, which could be easily pushed around the unit from source to source.

          An alternate method, "blow-through," was used when very high or
very low air flow rates were required.

          The vacuum pump was a 4.8 CFM Teflon-ring piston-type equipped
with a 3/4 horsepower air-driven motor.  Low pressure air (~ 100 psig) is
available at or near most refinery process units.

          The dry gas meter was a Rockwell Model 1755 Test Gas Meter with a
Number 83 Test Index.

          The leak source is shown as a valve in the figure.  However, the
same sampling train was used for all baggable source sampling with a flow-
through technique.  The size and shape of the leak source enclosure (tent)
was changed and adjusted to fit each particular source shape and operating
condition.

          When the sampling train is operating, the vacuum pump is able to
maintain a maximum flow rate of approximately 2 1/2 cubic feet per minute.

          Sample bags were used to collect gas samples and transport them to
the mobile laboratory for analyses.  Several types of bags were tested by
Radian in the laboratory and in the field.  Most of them, including
Calibrated Instrument Company's five-layer "snout" bags, were found to adsorb
hydrocarbons, making them unsuitable for use.  Bags of 2 mil Mylar and Tedlar
plastic were constructed, and were found to be very satisfactory.  A drawing
of a typical sample bag is shown in Figure 5.

          A cold trap was placed in the system to condense water and heavy
hydrocarbons, thus preventing condensation in down-stream lines and equipment.
The cold trap was simply a 500 ml flask in an ice bath and was placed as close
as possible to the tent.  This ice bath was found to be very effective in
preventing condensation in the remainder of the sampling train and in the gas
sample bag.   Any organic condensate that collected in the cold trap was
measured and recorded for later use in calculating total leak rates.  The use
of such a cold trap is critical; without it, order of magnitude errors are
possible and, in  some cases, probable.
                                      18

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MAGNEHELIC

     t
                  THIS LINE SHOULD
                    BE AS SHORT
                    AS POSSIBLE
   TEMT
                   COLD TRAP
                   (ICE BATH)
         LEAKING
         VALVE
    TRAP
                                                    a
               J
                                                                     Hg MANOMETER
                  CONTROL
                   VALVE
DRY GAS
 METER
                                                    o
                                                    •

                                                    o
                                                    0
                                                    H-
                                                                           FILTER    VACUUM PUMP
                                                            SMALL
                                                         DIAPHRAGM
                                                            PUMP
                                                                             SAMPLE BAG
                      TWO WAY VALVE
                 Figure 4.  Sampling Train for Baggable Sources of Hydrocarbon
                           Emmissions Using a Diaphragm Sampling Pump

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C. D.  Smith
                  Figure 5.  Mylar Plastic Sample Bag
                                      20

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 C.  D.  Smith
"Tent" Construction

          An enclosure or "tent" of Mylar plastic (polyethylene terephthalate)
is formed around the leak source.  The thickness of the Mylar can range from
1.5-15 mil depending on the type of source being bagged.  Radian has found
that Mylar is well suited to this function as it does not absorb significant
amounts of hydrocarbons, it is very tough, and it has a high melting point
(250°C).  A typical tent is shown in Figure 6.

          The enclosures were kept as small as practical.  This had several
beneficial effects:

          •   The time required to reach equilibrium was kept
              to a minimum.

          •   The time required to construct the enclosure was
              minimized.

          •   A more effective seal resulted from the reduced
              seal area.

          •   Condensation of heavy hydrocarbons inside the
              enclosures was minimized or prevented due to
              reduced residence time and decreased surface area
              available for heat transfer.

          In a typical sampling operation, the tent was constructed around
the leak source and connected by means of a bulkhead fitting and Teflon hose
to the sample train.

          A separate line was connected from the tent to a magnehelic.  This
allowed continuous monitoring of the pressure.


Sampling - Total Leak

          The cold trap was connected to the tent and immersed in an ice bath.
Then the vacuum pump was started and the timing of the run was simultaneously
initiated.  The time, pressure and temperature at the dry gas meter, and dry
gas meter reading was recorded.  These data were recorded at 2-10 minute
intervals.  Equilibrium was normally reached within 5 minutes or less.
Sampling was not started until equilibrium had been established throughout the
system.

          The TLV Sniffer was placed in the sample train at the exit of the
vacuum pump.  The instrument was used to monitor the gas stream in order to
assure that equilibrium had been established.

          To sample the gas stream, an evacuated Mylar sample bag, which had
been previously completely flushed with air for an extended period at the
                                     21

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K!
M
                  Mylar Bagging

             Flexible Plastic
             Mesh Reinforcing
             Material
              Bag
Beneath
                                                                                      Surgical Tubing
                                                                                      Pressure Top
                                                                     Outlet to
                                                                     Pump
                                                                                                                 o
                                                                                                                 00
                                                                                                                 3
                                                                                                                 H-
                          Figure 6.  Tent Construction Around the Seal Area of a Vertical
                                     Pump

-------
 C.  D.  Smith
mobile laboratory, was attached to the diaphragm pump exhaust.  The bag was
first completely flushed with sample gas.  Then a sample was transferred into
the bag.

          At the same time that this sample was being withdrawn, an ambient
air sample was taken near the tent.  This air sample was taken with a large
plastic syringe and transferred to a Mylar sample bag.  The gas sample and
ambient air sample were taken to the mobile laboratory for analysis.  The
vacuum pump was then stopped and a final set of readings recorded.  The cold
trap was removed from the ice bath, sealed, and sent to the laboratory for
analysis.  The tent was then removed from the source, and the train moved to
the next sampling point.

          The "Blow-Through" Method - a schematic diagram of the sampling
train used with the "blow-through" method of measuring hydrocarbon emission
rates is shown in Figure 7.

          In this method, plant air is used as  the source of diluent air to
the enclosure around the leaking source.  Plant air is first passed through
an activated carbon canister to remove contaminants.  The air then passes
through a dry gas meter and into the enclosure.  The air is exhausted from the
enclosure through a line connected to the opposite side of the tent.  A
fraction of the exit air is continually drawn through an air driven vacuum
(sampling) pump.  When equilibrium has been established, this fraction of the
air stream is collected in a plastic bag.  The contents are then analyzed for
methane and total nonmethane hydrocarbon using gas chromatographs equipped
with flame ionization detectors.

          The hydrocarbon emission rates can be calculated from the inlet air
flow rate and the hydrocarbon concentration in the outlet air.  The "blow-
through" method can be used when very low or very high flow rates of air are
required.

Speciation Selection and Sampling

          During the sampling for total hydrocarbon emissions a minimum number
of samples was taken for complete characterization.  It is from these that the
effects of refinery size and location on the characteristics of emissions were
determined.  For this reason it was important that a wide variety of process
units be included in the overall speciation-sample gathering task.

          The number of samples projected to be taken from each source was
based upon the likelihood of that source containing hazardous organic materials,
It was felt that this is the most efficient and accurate way to obtain a com-
prehensive picture of potentially hazardous components in refinery streams.

          It was believed that this sampling scheme would provide a complete
description of the potentially hazardous compounds emitted from refining
operations.  Essentially all streams selected were included for at least
duplicate analysis.


                                     23

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Compressed
air
               Portable modular housing
                    Filter
                                         Pressure
                                         gauges     Dial
                                                    thermometer
                               Activated
                               carbon
                                     Throttling
                                     valve
                                                   Dry. gas
                                                  .meter.	1
Tented
fitting
                To sample bag
                or analytical
                Instrument
                                                                                                              o

                                                                                                              o
                                                                                                             CO
                                                                                                             3
                                                                                                             H-
                 Quick disconnect fittings
                 Figure 7.  Schematic Diagram of the Apparatus for the Blow-Through
                            Sampling Technique

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C. D.  Smith
Vapor/Liquid Compositions of Fugitive Emissions

          The relationship between the composition of a vapor leak and the
composition of the stream from which it came was investigated by taking both
liquid and vapor speciation samples wherever possible.  (This was not always
possible because not every stream selected for speciation sampling contained
vapor-leaking sources.)

          Vapor samples for speciation analyses were taken by means of
adsorption on a porous polymer.  Extraction with an organic solvent releases
the adsorbed material for analysis.  The effect of this technique is removal
and concentration of materials in the hydrocarbon/air mixture.

          Liquid samples taken as speciation samples were drawn directly
from sample lines or ports.  In some cases, it was necessary to pass hot
liquid through a cooling coil in an ice bath as it came out of the line.
In this manner, vaporization of the more volatile constituents was prevented.


Sorbents

          For broad boiling range speciation a combination of sorbent techni-
ques is advisable.  For volatile organics from acetone to naphthalene, Tenax
can be used as a sorbent and thermally desorbed.  Benzenes, toluenes and
xylenes are the compounds in the volatility range that would be expected as
fugitives with known adverse environmental effects.  Charcoal tubes are
also efficient in the  trapping of very volatile emissions, such as vinyl
chloride, which are of interest from a health effects standpoint, but not
expected as fugitives from the refining process.  To provide a volatility
continuum, charcoal tubes should be used in the fugitive sampling procedure
and the extracts analyzed for any compounds of interest in the 120°C to 150°C
boiling range.  For the high molecular weight fugitives XAD-2 is recommended
as an adsorbent.  Heterocyclic nitrogen and sulfur compounds and polynuclear
aromatic emissions are trapped with the XAD-2 sampling module.  Each sorbent
system is outlined in the following sections.


Collection of Leaking Vapor for Species Identification

          Samples of the leaking vapor were collected on Tenax adsorbent,
XAD-2 resin, and charcoal.  The air containing hydrocarbons from the enclosed
leaking valve was passed through tubes containing the various adsorbents.
Both the "draw-through" and the "blow-through" methods were used for this
purpose.  Sampling trains are shown in Figures 8 and 9 and Table 2 shows
sampling conditions for the three types.


Collection of Bulk Liquid Samples

          Samples of various representative liquid streams were collected
from sampling points along the reprocessing lines.  All samples were taken
                                      25

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              MAGNAIIEL1X
                  F=tX]=
                            TENAX OR
                          CHARCOAL TUBE
                                            =1X1=
                                                                                                         n
                                                                                                        en
                                                                                                        3
                                                                                                        n-
                                                                                                        :r
                                          Q DUDDLE METER
                                                                         VACUUM
                                                                          PUMP
                                  VACUUM
                                   PUMP
LEAKING
 VALVE
Figure 8.
                              Typical Sampling Train for Taking  Gas  Samples  on
                              Tenax Resin and Charcoal Using the Flow-Through
                              Method                                      &

-------
to
                                                                                                                           O
                                                                                                                          v:
                                                                                                                          H-
                                                                                                                          rt
                                                                                                                          53*
                     LEAKING
                     VALVE
                                                          DRY GAS
                                                           METER
                          Figure  9.   Typical Sampling  Train for Taking Gas  Samples on XAD-2
                                      Resin Using the Flow-Through Method

-------
                                                                                                                 n
                        TABLE 2.  NOMINAL OPERATING CONDITIONS FOR SAMPLING WITH ADSORBENTS
                                                                  Recommended Ranges
                    Detection                                                                  Inlet
        Sorbent       Limit      Method       Volume         Flow            Mass          Concentration



       TENAX        ^1 PPB        GC/MS      1-2 L        10-25 ml/min     50-100 ng
                                                                           minimum


       Charcoal*    ^500 PPB      GC/MS      5-10 L       20-50 ml/min     2-15 mg         200-500 vPPM

g                   ^50 PPM       GC


       XAD-2        ^50-100 PPB   GC/MS      300-600 L    5-10 1/min       3-4 G maximum   100-1000 vPPM

-------
 C.  D.  Smith
in Pyrex sample bottles, tightly sealed with Teflon-lined screw caps, and
refrigerated until analyzed.


WASTEWATER AND COOLING TOWERS

          There are a number of potential hydrocarbon emission sources in a
refinery that are not amenable to sampling with bags or enclosures.  These
sources include operations that are broad in area, intermittent in operation,
and/or very complex in their functioning.

          Nonbaggable sources include drainage and wastewater systems, cool-
ing towers, barometric condensers, removal of coke from delayed cokers,
sampling operations, blind changing, and maintenance turnarounds.  Some of
these sources can only be sampled using very elaborate and complex sampling
procedures and equipment.  Nonbaggable sources that were sampled are the
wastewater system and cooling towers.


Nonbaggable Sampling Philosophy

          The sampled nonbaggable systems were the wastewater processing units
and the cooling towers.  The approach to sampling nonbaggable systems was to
use a mass balance around the particular unit.  The difference between the
hydrocarbon into the system (liquid influent) and hydrocarbon out (liquid
effluent) is equal to fugitive emissions to the atmosphere.

          The key elements to this approach are collection of representative
samples of liquid streams into  and out of a particular unit and accurate
measurement of flow rates through the system.


Oil-Water Separators

          Oil-water separation is normally the first process that the waste-
water encounters as it enters the wastewater treatment section of a refinery.
Oil-water separation can be accomplished in a surge tank, API separator, or
corrugated-plate interceptor.  The API separator is the most widely used of
these three types of separators.  The sampling methods described below for
API separators can be applied to the other two types of units, also.

          The inlet liquid to the separator consists of a mixture of hydro-
carbon and water.  The principal problem encountered in sampling is the pro-
curement of truly representative samples of two-phase streams.  Samples of
each phase were obtained from the separator inlet line, or from the
separator at a point as close as possible to the oil-water inlet.

          Three streams normally exit from an API separator.  These are the
oil that is skimmed from the surface of the liquid in the separator, the
water, and sludge that is pumped from the bottom of the separator.  The
sludge was not considered in the sampling program, because it is not a
significant source of emissions to the air at this point.
                                     29

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 C.  D.  Smith
          The oil that is skimmed from the surface of the separator is
normally pumped to a slop-oil tank.  Oil samples were preferably taken at
the outlet of this pump to insure a reasonably representative sample.  Other
sampling points were the skim pipe itself, the line from the separator to
the slop tank, and the slop tank itself.

          In the separator the water flows under a barrier weir and then over
another weir to a basin from which it is pumped or allowed to flow by gravity
to the next processing area in the wastewater treatment.  Water samples were
taken at the overflow weir.  Samples were obtained at several points along
the weir, and were composited to form one sample.  Factors which determined
the particular sampling point for a given separator included accessibility,
residence time in the basin, and presence of sample taps in the pump dis-
charge line.

          The average oil outlet rate can be determined from level readings
on  the slop-oil tank over given periods of time.  The average outlet oil
rate was used to estimate the residence time in the API separator.  The
thickness of the oil layer in the separator, and the dimensions of the area
containing the oil layer also are required in estimating the oil residence
time.

          Samples were taken of each stream of each separator several times
a day for several days.  Daily samples from each sample point were composited
before analysis.  The oil and water samples from the inlet and outlet of the
API separator were collected in glass bottles.  These bottles were completely
filled and kept tightly capped to prevent the escape of volatile hydrocarbons.


Dissolved-Air Flotation Units

          If dissolved-air flotation (DAF) units are used in a refinery
wastewater treating system, they usually process water from the oil-water
separators.  Air is dissolved or sparged into the water, and the air bubbles
attach themselves to colloidal oil droplets, causing them to rise to the
surface, where the oil-air emulsion is removed.

          Some DAF units are partially enclosed and others are completely
open to the atmosphere.  The hydrocarbon material balance method is the pre-
ferred technique for determining hydrocarbon emissions from open units, and
may also be used for partially enclosed units.

          Only one stream containing a significant -amount of hydrocarbons
enters the DAF unit.   This is the water phase from the oil-water separator.
There is normally little free oil in this water.  Ambient air, which may
contain low background concentrations of hydrocarbons is also injected or
sparged into the water.  Three streams leave the DAF unit.  These are the
water, the air-oil emulsion and air.  All these streams contain some
hydrocarbons.
                                      30

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 C. D.  Smith
          When applying the material balance method to DAF units, samples
of inlet water were taken.  These were normally the same as the outlet water
samples from the API separator, and the same analysis sufficed for both
separator and DAF hydrocarbon material balances.

          In order to close the material balance sufficiently to calculate
hydrocarbon emissions, samples of the outlet water stream and the air-oil
emulsion must also be taken.  The outlet water sample was taken at the over-
flow weir.  The emulsion samples were judged to be negligible contributors to
air emissions.

          The water samples were collected several times each day for several
days.  The daily samples from each point were composited for analysis.


Cooling Towers

          The preferred method for determining hydrocarbon emissions from
cooling towers is  the  hydrocarbon material balance.  Water enters the
cooling towers from two sources:  make-up water and the hot water from process
exchange.  Water leaves as vapor from the top of the cooling tower, as cooled
water returning to process exchange, and as blowdown.  A water material
balance shows that the outlet rate to the process must equal the inlet  water
rate from the process, since the make-up water rate is controlled to exactly
balance blowdown plus evaporation.

          Thus, if the hydrocarbon content of the incoming hot water and the
return cooled water are known, the evaporative hydrocarbon emissions can be
determined.

          Samples of inlet and outlet cooling water were collected daily from
each selected tower over a period of several days.  In order to diminish the
effect of hydrocarbon concentration fluctuations, the outlet sample was taken
from the water flowing downward through the tower at a location just above
the level of the cooling tower basin.  The inlet samples were taken from one
of the many small sampling valves which are normally present and branch off
the large cooling water return risers.  Many of these are continually flushed
into the tower basin.

          The samples were kept in sealed bottles under refrigeration until
they were analyzed.


SAMPLING STACK EFFLUENTS

          Stacks or vents which can be identified as emission points for
hydrocarbons and other criteria pollutants are classified as process sources.
The general strategy regarding the sampling of point source emission included
sampling the total hydrocarbon emissions, obtaining samples for speciation
analysis and sampling for other criteria pollutants.
                                      31

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C. D.  Smith
          Measurements made in the  base case were:  EPA Reference Methods
No. 1, 2, 3, and 4 on all stacks; methane and nonmethane hydrocarbons on all
stacks; particulate and vapor collection for organic characterization on one
stack; and, sulfur gases on the sulfur recovery and/or tail-gas  treating
stack.

          Stack sampling procedures are a combination of:  EPA approved methods
for criteria pollutants  (S02, S03, and particulates); EPA Level  1 screening
procedures  (S02, COS, CS, H2S, NO, NOX, "organic vapor"); Texas  Air  Control
Board  methodology; and, Radian-devised methods  (HCN, NH3 , THC).  The procedures
were selected with several criteria in mind:

          •   Accepted or proved  methodology.

          •   Accurate,  reproducible Measurements.

          •   Commercially available equipment.

          •   Freedom from interference.

          •   Cost-effective  trade-off between  sampling  and
              analysis.

          •   Shortest feasible sampling time.

 Figures  10  through  12 depict  the  sampling trains used.

 Stack Sampling  Methods

          The characterization of refinery  stack emission involved sampling
 and analysis  for  the  following species:

          particulates                   total  hydrocarbons

          S0x                            fixed  gas

          trace organic  species          sulfur species

          total aldehydes                nitrogen species

Particulates

          Particulate samples were collected from each stack  according to  the
procedures described  in the EPA Reference Method 5 using a Lear  Sigeler, Inc.
stack  sampling train.  Sampling was performed isokinetically  along two perpen-
dicular traverses of  each stack.  Duplicate sample runs were  made on each
stack  insofar as possible.  Stacks were sampled that did not  meet EPA require-
ments.   In those cases the number of traverse points was taken that  was  felt
to be  useful.
                                      32

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CO

U3
                      Probe
               "S" Type Pilot Tube
                                                                             6%       6%

                                                               80%   IPA   H202/    H202    Silica Gel •
                                                                  \
                                                 Hoi Box    Filler Holder
                                                                                          Thermometer
                                    —Slack Wall
                                             Pilot Gauge
                        &ZM£^&tim
                                                                                                         _.   , ,,
                                                                                                         Check Valve
                                                                                                        Vacuum Line
     v

Cyclone Set Impingers
Fine Control Valve     lce Balh
                                                                                                 Vacuum Gauge

                                                                                             Coarse Control Valve
                                                        Orifice Gaugo
                                                                      ^f	^ /   ri»
-------
                Teflon/Cla&s Fiber  Filter
\
Sample-
                                                               o
                                                                                         "21
                                                                                Vacuum Pump
                                                                                                                o

                                                                                                                G
                                                                                                         C/3

                                                                                                         H-
                                                                                                         ft
                                                      Ror.oiiie.ter/Flew  Controller
                                    Figure 11.  Aldehyde Impinger Train

-------
Ln
f
5lninl«nr. Steal.
t"robe
Rotometer/
Fiow Controller
rn.. / 	 |
TeClon/Class : '
Fiber Filter \
IT^-H 	 — 	 ^i i 	 ;; i- -u
	 Xl/1-!! 	 irH — tl 1
Sainple 1.1 DP A . 	 .__.
I Tefloii-l.ined
, , | Vocinini Sini|iie
Hunld Dry l>umP
Air Ait
o
e
CO
H-
rt
Telia r Bag
^ (Total Hydrocarbons)
	 ^. Glass Bomb (NOX)
(Sulfur Species)
^ Scotchpak Bag
(Fixed Gasea)
	 i. Impingers
(HCN, NHt)
                                Figure 12.  Grab Sample Collection and Preparation System

-------
C. D. Smith
SO
  x

          Oxides of sulfur (S03 and S02) were collected according to EPA
Reference Method 8.  This  was  done during each particulate collection run
by passing the filtered sample gases through an impinger train consisting
of an 80 percent isopropanol impinger for S03 followed by two 6 percent
aqueous hydrogen peroxide impingers for S02 and a silica gel impinger.  The
total mass of water collected in this train was used to determine the mois-
ture content of the stack gas.


Aldehydes

          The aldehyde train  (Figure 11) used in sampling stacks consisted
of two  ice-cooled Impingers, each containing 10 ml of a 1.0 percent aqueous
sodium  bisulfate solution.  Approximately 12 liters of stack gas were drawn
through each  impinger train at a rate of 200 ml per minute.  A stainless
steel probe was inserted into the stack to a point of average velocity, and
the  gas was transferred to the impinger train by a small vacuum sampling
pump through  a heated Teflon  sample line equipped with a Teflon particulate
filter.  Radian has found that the use of a heated transfer line is very
important to  prevent moisture condensation and subsequent loss of sample by
absorption and dissolution.


HCN  and NH3

          Hydrogen cyanide was collected using the Method 5 stack sampling
equipment by  passing the filtered sample gases through three impingers
containing 2.0 N sodium hydroxide.  Ammonia was collected similarly using
three  impingers containing 0.1 N sulfuric acid.  In each case sampling was
conducted over thirty-minute  periods and resulted in approximately  10 SCF
of gas  for each sample.


Grab Samples

          The remaining four  categories of species are all collected by grab
sampling  techniques (Figure 12).   From Radian's experience in sampling for
these species in refinery stack gases, it has been found that collecting and
transporting the sample in a way that preserves its integrity is a nontrivial
task.   All of the following factors have been found to contribute to the
nonrepresentativeness and/or degradation of the sample:

          •   Sampling equipment construction.

          •   condensation of moisture in the sample line and
              vessel.

          •   Particulate removal.
                                     36

-------
C. D.  Smith
          •   Sample vessel construction.

          •   Time lag between sampling and analysis.

          Radian has developed a sampling and operating procedure which
eliminates the negative aspects of all five of the above factors.  A stain-
less steel probe is  inserted into the stack to the point of average velocity,
and the sample gas is drawn out through a heated Teflon sampling line.  The
construction of the sample line is important to prevent moisture, condensation
and reaction of the reactive species with any non-inert surfaces.  The sample
then passes through a heated Teflon glass/fiber filter to remove particulates
followed by a permeation drying system to remove moisture.  The Perma-Pure
Products, Inc.® multi-tube drier has been found to be effective in removing
moisture down to 100 ppm while causing only a 1 - 3 percent loss of the
desired species.  Without this sample drying technique, condensation of
moisture inside the sample vessels and the resulting reaction, absorption or
dissolution of reactive species has resulted in poor analyses and complete
loss of sample.  Movement of the sample through the system is accomplished
by a miniature Thomas vacuum pump equipped with Teflon heads and diaphragm.
The outlet stream from the pump is directed to the several bags and bombs
used to transport the samples to the field laboratory for analysis.  Sampling
and analysis procedures allow no more than 15 minutes elapsed time between
sample catch and start of analysis.  If the sample was not analyzed within
that time, a new sample was obtained.


Hydrocarbons—Samples for methane and nonmethane hydrocarbons analysis were
collected in 4 liter Tedlar sample bags.  Bags made of aluminized polyethy-
lene have been tried, but substantial sample loss through absorption or
reaction was observed.  The Tedlar bags were flushed with zero grade air
prior to use.


Fixed Gases—Samples for fixed gases (C02, N2, H2, 02, CO) analysis were
collected in aluminized Scotchpak sample bags.  These species are quite
unreactive and are not prone  to absorb onto the bag walls significantly.


Gaseous Sulfur Species—The sulfur species, CS2, H2S, COS, and S02, proved
to be the most difficult to collect and transport.  The two major problems
of reaction/dissolution with condensed moisture and reaction/absorption on
the surfaces of the sample vessel were  eliminated by using the sample
system described in Figure 12.


NO  (A)—Samples for NOX were collected in evacuated 2 liter flasks to which
had been added 25 ml of a potassium dichromate-aqueous sulfuric acid solu-
tion.  The temperature and pressure of the gas were recorded.


NOX (B)—Samples for NOX were collected in evacuated 2 liter flasks to
which had been added 15 ml of chromotropic acid solution.  The temperature
and pressure of the gas- were recorded.
                                     37

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C. D. Smith
Flue Gas and Particulate Sampling—Samples for trace organics speciation
were collected from the selected stack using a modified Aerotherm Source
Assessment Sampling System (SASS) (see Figure 13).   A 1154 SCF sample of
stack gas was drawn from a point of average velocity in the stack.  The
particulates were removed on a filter, and the gas  was then cooled and
passed through a sorbent canister (Figure 13a) filled with XAD-2 resin to
trap any nonvolatile organic compounds.  The particulates, the condensate
that resulted from cooling the gas, and the XAD-2 resin were collected and
returned to Austin for extraction and analysis.

          The organic concentrator for the SASS  train is a canister filled
with XAD-2 resin.  It replaces the canister that comes with the SASS train.
                                     38

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OJ
                                                        CONVECTION OVEN
____                  ^
                                                                               FILTER
                                       I	
                                                CAS TEMPERATURE T.C.
                                                                          CONDENSATE
                                                                           COLLECTOR
                        DRY GAS METER OFFICE METER
                          CENTRALIZED TEMPERATURE
                           AND PRESSURE READOUT
                                CONTROL MODULE
                                                                                                 GAS COOLER
                                                                                               XAD-2 CARTRIDGE
  IMF/COOLER

TRACE ELEMENT

  COLLECTOR
                                                                                                                        IMPINGER

                                                                                                                          T.C.
                                        CO
                                        B
                                        H-
                                        rt
                                                            10 CFM VACUUM PUMP
                                              Figure 13.   Source Assessment  Sampling System

-------
                   HOT GAS
                   FROM OVEN
                   LIQUID PASSAGE
                     GAS PASSAGE


                     GAS COOLER -
XAD-2  CARTRIDGE
                     CONDENSATE
                     RESERVOIR
                                                                                3-WAY  SOLENOID VALVE


                                                                                     TO COOLING BATH

                                                                                      FROM COOLING BATH
COOLING-FLUID
  RESERVOIR
                                                                                    IMMERSION
                                                                                    HEATER
                                                                                LIQUID PUMP
                                                                                   TEMPERATURE
                                                                                   CONTROLLER
                                                                                                                          n

                                                                                                                          o
                                      H-
                                      rt
                                   Figure 13a.   XAD-2 Sorbent Trap Module

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C. D. Smith
                                  SECTION 3

                               FIELD ANALYSIS
MOBILE LABORATORY

          Radian dedicated a mobile laboratory to the sampling in refineries.
The laboratory is housed in an 8' x 26' van trailer and has the capability
of supporting a wide variety of sampling and analytical procedures.  The
forward area is equipped with counter space and utilities to support the
wide variety of analytical instruments contained in the trailer.

          The remainder  of  the laboratory is equipped with standard wet-
chemistry benches and extensive equipment storage space.  A fume hood, with
externally mounted explosion-proof blowers, has  been provided for contain-
ment of hazardous experiments and exhaust of vapors.  All external components
of the air-conditioning system are explosion proof.  Electrical, water, and
drainage utilities needed to operate the laboratory are obtained on-site,
and external connections are provided to interface with the required services.

FUGITIVE EMISSIONS ANALYSES FROM PROCESS SOURCES


Total Hydrocarbon Content (Methane/Nonmethane)

          The analysis for methane and nonmethane  hydrocarbon content of
fugitive emission gas samples was accomplished using a specially designed
Total Hydrocarbon Analyzer (THC) Model 301C made  for Radian by Byron
Instruments.  The instrument is made to accept samples by:

          •   Sampling from a bag.

          •   Syringe injection.

          •   Unattended, continuous in-line sampling.

          Analysis of baggable samples of gas was accomplished by pumping
gas out of the Mylar sampling bag into a gas sample loop using an integral
pump in the THC analyzer.  The instrument operates automatically after being
connected to the bag.  The results of the first run were discarded to avoid
contamination occurring from sample retained from the previous analysis or
ambient air entering the system during sample changing.  Two additional runs
are made and the results recorded by a strip-chart recorder.
                                     41

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C. D. Smith
          The instrument has several ranges for both methane and nonmethane
hydrocarbons.  The full-scale direct readout ranges from 0 - 2 to 0-20,000
ppm by weight.  When these ranges were exceeded, a portion of the sample was
diluted with zero grade air until it could be analyzed on one of the above
ranges.  Then the dilution factor was used to calculate the original
concentration.

          The THC uses a flame ionization detector for measurement of hydro-
carbon concentration and, thus, produces a linear readout over the entire
range of the instrument.  Hydrocarbon-free air is used for the carrier gas.


Quantitative Analysis

          The chromatograph gives a voltage output which changes with time.
The  simplest device for handling this is the strip chart recorder, which
produces a sheet of paper with an inked line on it.

          The easiest thing to measure is the maximum amount by which the
peak departs from the baseline, i.e., peak height.  The advantages of this
means of quantitation are speed and ease.   It is, however, subject to many
sources of error.  Anything which alters the peak shape will create problems.

          Area under the curve does not depend on shape.  So long as the same
amount of material is injected, even if the column overloads, the same area
will be obtained.  Operator technique variation, assuming the same amount
injected, has essentially no effect on the area figure.  Electronic integra-
tion is the best approach for measuring area.

          Radian used a gas chromatographic instrument that resolves hydro-
carbon mixtures into two peaks.  Methane is separated from all other hydro-
carbons and passed through the FID and then all other hydrocarbons are
passed through the FID simultaneously.

          To quantitatively  measure methane the following procedure is
used.

          A known volume of sample of known parts per million by weight
(ppmw) of methane in air was injected into the analyzer.  The peak height
was  measured.  For a single component peak height is an adequate measure of
response.  A plot of peak height versus ppmw then allows any peak height of
an unknown sample to be directly translated into ppmw.  The equation of the
line shown in Figure 14 is:
                                     42

-------
C. D.  Smith
           peak height =  (slope)  (ppmw) +  intercept

           intercept   =  0,  no material, no  response
           slope
peak  height of  standard material
ppmw  of standard material
                                ppmw

                               Figure 14
The instrument was  calibrated with the standard of known methane so that the
slope was identical from day to  day or shift  to shift.

         To quantitatively measure the nonmethane hydrocarbons a similar
procedure was used.  A standard  of propane of known ppmw in air was used
daily to calculate  and keep constant the slope of a line similar to that
of Figure 15.
     Area  Under
     Nonmethane
     Hydrocarbon
     Peak
                             ppmw Hydrocarbon
                               Figure 15
                                  43

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 C. D.  Smith
          Standardization of the THC was accomplished through a separate  gas
sampling loop without disconnecting the instrument from the sample being
analyzed.  The instrument was standardized every time it was turned on  or
once per laboratory shift, whichever was more frequent.  The standard con-
tained 100 ppm methane and 100 ppm propane on a molar basis.  Repeated  tests
against other standards have demonstrated the linearity of the response of
the instrument.


Calculations

          The hydrocarbon emission or leak rate from each sampled source  was
calculated as a sum of the methane emission rate, the nonmethane gas emission
rate,  and the organic condensate rate, i.e.,

               E  = E  + E   + E
                T    M    NM    L

where

          E   = total hydrocarbon emission rate^ Ib/hr.

          E   = methane emission rate. Ib/hr.

          E   = condensed organic liquid rate, Ib/hr.
           Li
          E   = nonmethane hydrocarbon emission rate, Ib/hr.

          The emission rates of methane and nonmethane hydrocarbons may be
calculated from the following equation:

                      QPM
               p  = v —	— (r  — r }         T — A£n° 4- °v
               fiTT — K.  T   ^u  — L ) „        i — HOD  +  t
                n.      X     S    cL ti

where

          £„  = hydrocarbon emission rate, methane and/or nonmethane, Ib/hr.

          K   = 2.74 x 10"  ,  a factor incorporating conversion factors  and
                standard  temperature and pressure.

          Q    = flow rate of gas through the sample train, actual cubic
                feet/minute.

          P    =  sampling  system pressure at the dry gas meter, psia.

          M    = molecular  weight of the air/hydrocarbon mixture, effectively
                the molecular weight of air.
                                     44

-------
C. D. Smith
          C   -  concentration of methane /nonme thane hydrocarbon in the
                 gas sample from the sampling train, ppm by weight.

          C   =  concentration of me thane /nonme thane hydrocarbon in the
                 ambient air, ppm by weight.

          (C  - C )  = methane and/or nonmethane concentration difference
                      between gas and ambient air, ppm by weight.

          T   =  sampling system temperature at the dry gas meter, °R.


          The organic condensate rate,  E ,  was calculated from the follow
ing equation:


                          V
                L      t

where

          E   =  organic condensate rate, pounds /hour.
           J_i

          V   =  volume of condensate collected, ml,

          t   =  time over which the sample was collected, min.


          This calculation assumes an average density of 0.75 gr/cc for the
organic condensate.  The condensate was measured, and this weight was used
to calculate the condensate rate.  The data sheet containing the appropriate
information is shown in Figure 16.


Organic Species Characterization

          The measurement of organic species was accomplished by a combina-
tion of experimental methods employing gas chromatography and mass spectro-
metry (GC/MS) , as described in the following subsections.

          Samples were collected and analyzed for characterization of the
following:

          •    Point source  emissions such as CO boiler regenerator
               flue gas .

          •    Fugitive emissions from valves, pumps, etc.

          •    Effluent streams from wastewater treatment processes.
                                      45

-------
   C. D.  Smith
     1. Radiaa
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                                             , 18. Specific  grsviry of
                                  SI  S3 5*  Si
                                                       organic ceadensz:e       s« 67  46
      ASALYSIS BAIA:
Acbiesc air (1)
            (2).
19. Avg.
                            20.
                                                AITSSSATS ASALYSIS ^THOD:

                             Soaae thane              Keehac_e                 Kosagthane

                           (1)	      (!)__	        CD	

                           (2)	      (2)	        C2)	

                                             ' 19-   1      '.   '.   '.   I  20.
21. Avg.
   56  60  tl  62  63      64   66  66 67  63

       (1)	   CD	

       (2)                (2)	

   I    .    .   .   .   I 22.
                                                      5560 61 62 S3
                                                    (2)
                                                                        64  65  £6  67  66

                                                                          (1)	

                                                                          (2)	
         tS  70  71  72  73
                               74 7S 76 77 78 78
                                              21. Avg.
                                                             •   I   I
                            22.
                                                                                     t  _!	T
                                                          66 70 71  J2 73     74 75 76 77 78 73
     CALOJI-ilZD IZAX XAIZS (Ib/hr) :

                             Methane
                                              Nomnechane
                                Total
                                                            Condeasete
          iiSEJC DATA:

     Raditn ID
                         Screening Tttn
                                          Rescreeaingf
                                                Date I
             12345678
  Screeaisg  Concentration,

All sources, |
   Valve Stc
                                                         S  10   11  12   13  14
                                 Screening
                                     Teca
                                                                                         IS   16
                                                          *	»	i	I	*
    Valve ?ackir.g
           Gland
                 17 16 18 20 21 22  23  24  25  29  27 28   29  30  31  32 33 34  35 36 37 36 38 40
                                                                    5 Ch S.«dlr.g
	

lilt'



	 1
                 41 42 43 44 45 46  47  46 43  iO  51  52   S3  J4  SS  S6  57 i£  S9 60 61  62 63  64

                                                                    S CX Reading
         Figure  16.   Data Sheet - Baggables  and Tented Liquid Leaks
                                                46

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 C.  D.  Smith
Qualitative Analysis

Instrumentation—Analyses for organic species were performed in Radian's
GC/MS laboratory.  The instrumentation used is summarized in Table 3.

Extraction—Depending on the sample type and emission source, different
analytical procedures were employed to adequately measure the organic
species.  Table 4 lists the sample type received and the analytical pro-
cedures employed for each sample.  Each of these procedures will be
described in the following subsections.

Preliminary Sample Treatment—The analysis of trace organic species by GC/MS
required preliminary sample treatment.  These preliminary steps and their
purposes were:

          •    Isolation, to remove the organic species or
               interest.

          •    Separation, to divide the isolated organic species
               into groups of similar chemical or physical
               properties.

          •    Enrichment, to increase the concentration of the
               organic species.

          Each of the samples collected during this work required some or
all of  these steps as described below.

Isolation of the Organic Species—Removal of the organic species was per-
formed  by two techniques, solvent extraction and thermal desorption.  The
thermal desorption of volatile species from Tenax tubes is an integral part
of the  analysis and, as such, will be discussed later.

          The determination of trace organic species required special pre-
cautions in the sample preparation.  Only high-purity distilled-in-glass
solvents (Burdick and Jackson) were employed.  All laboratory glassware was
cleaned with chromic acid before use.  Immediately prior to use, the glass-
ware was rinsed with an organic solvent to remove any traces of organic
material.  Only teflon, glass or stainless steel labware contacted the
sample.  Aqueous reagents were presaturated with solvent before use.

          Isolation of the organic species from the XAD-2 resin and particu-
late samples was performed by a 24-hour Soxhlet extraction with diethyl
ether.  Diethyl ether was preferred because:

          •    It has been demonstrated that ether is a superior
               solvent for removal of polynuclear aromatics and
               other species from XAD-2 resin.
                                     47

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                                                                          o
TABLE 3.  MASS SPECTROMETERS - RADIAN
MAXIMUM IONIZATION SAMPLE GC/MS
INSTRUMENT MO. TYPE RESOLUTION MODES INLETS INTERFACE SIM
Hewlett Packard 1 Quadripole Unit El, CI GC, Probo Glass Jet Yes
(5982) or membrane
or direct
-P-
oo
Hewlett Packard 1 Quadrapole Unit El, CI GC, Probe Glass jet Yes
(S9B5) or direct

1


DATA
SYSTEM
Hewlett
Packard
(5933)


Hewlett
Packard
(ZIMX-E)
Hewlett
Packard
(5934 A)
OTHER FEATURES
Capillary GC. Subanblent GC,
Purge and Trap VOA Analysis



Capillary GC, Subamblent CC,
Purge and Trap VOA Analysis

Disc - Tnpn Interface digital
tape unit, lets plotter.
acoustical telephone coupler

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                                                                                                                     o
                                                                                                                     •


                                                                                                                     e
                                                                                                                     0
                                                                                                                     H-
-P-

VD
                          TABLE 4.  SUMMARY OF SAMPLE TYPES AND ANALYSIS PROCEDURES
SAMPLE TYPE
Process Liquid
Tenax
XAD-2 Resin
Particulate
Effluent Water
Charcoal
SAMPLE COMPOSITION
Organic Liquid
Sorbed organic vapor
Sorbed organic vapor
Particulate
Aqueous
Sorbed organic vapor
EMISSION SOURCE
Fugitive
Fugitive
Point
Point
Point
Fugitive
ANALYTICAL PROCEDURE
Pentane Dilution l
Thermal Desorption
ABN
ABN
Ether extraction
CSa extraction
              Note:  1) Some samples  also fractionated on silica gel.

-------
C. D. Smith
          •    Any water associated with the resin is removed by
               the ether.

          Aqueous samples were manually extracted with diethyl ether in
a separatory funnel.

          Thus, at the conclusion of this phase of analysis, the organic
species in each sample had been transferred to a different matrix.  The
process liquids were ready for analysis.  The effluent water sample still
required concentration as described later.  The XAD-2 resin and particulate
sample extracts were further separated as described in the following section.


The ABN Sepa'ration/Derivitization Scheme—The acid-base-neutral (ABN) separa-
tion  strategy was developed by Radian Corporation for the analysis of com-
plex  environmental samples.  The ABN approach is illustrated schematically
in Figure  17.  The strategy is based on a series of liquid-liquid extrac-
tions that separate a sample into three principal fractions:

           A - organic acids whose salts partition into water at high pH.

           B - organic bases whose salts partition into water at low pH.

           N - neutral hydrophobic compounds.

           These principal fractions are then further subdivided to yield a
total of seven fractions which are analyzed by GC/MS.

           The ABN extraction procedure was employed to characterize the
semi-volatile organic species in the XAD-2 resin and particulate samples.
This  separation scheme was chosen on the bases that (1) the distribution
of compounds throughout the procedure can be predicted with reasonable
accuracy,  (2) the procedures do not involve elevated temperatures and
(3) the number of fractions presented for analysis is minimal.

          The purpose of the separation scheme was to effect a sufficient
division of organic components so that those compounds of primary interest
could be identified and quantitated.  This scheme was not intended to be the
ultimate in separations, and it was not intended that every compound
collected in a particular sample would be isolated and identified.

          The complete ABN separation scheme is described in the subsections
below.

          Separation of Neutral, Acidic, and Basic Species—The ether extract
of the XAD-2 resin,  in particular,  was extracted with three 100 ml portions
of 5 percent HC1 in a separatory funnel.  The combined acidic and neutral
extract was then separated as described later.  The pH of the aqueous phase
was adjusted to a pH of 11 with NaOH pellets and then extracted with three
                                     50

-------
                                            HUH COLAH NtUlHALS I P.I
                                            HOD. POLAR NEUTRALS  F.2
                                                             F.7
o
•


O
                                                                                            H-
                                                                                            rt
Figure  17.   ABN Scheme

-------
C. D. Smith
100 ml portions of  ether.   This ether extract containing basic species was
then concentrated.

          The acidic/neutral extract was extracted with three 100 ml portions
of 5 percent NaOH.   The remaining neutral extract was separated while the
basic aqueous extract was  extracted and derivatized.

          Separation of Neutral Compounds—The ether extract containing the
neutral species was dried by passing it through a column of sodium sulfate
and then concentrated to 1 ml.  Hexane (10 ml) was then added and the sample
was reconcentrated to 5 ml to remove the ether.

          Silica gel (E Merck, grade 60, 70-230 mesh) was fully activated
by placing it  in an oven at 180°C for four hours.  A small plug of glass
wool was placed in the tip of a 1 cm x 100 cm column and the silica gel was
transferred while still hot to a depth of 70 cm.  A 1 cm bed of sand was
placed on top  of the packed silica gel and 100 ml of dry n-hexane was added
to the column.  The hexane was eluted using enough nitrogen pressure to give
a  flow rate of about 5 ml per minute.  The flow was stopped when the solvent
level reached  the top of the bed and the quantity of hexane eluted was
measured.  The void volume of the column was calculated according to the
following equation:

          [V =  (ml hexane added)  -  (ml hexane measured)].


          The hexane concentrate containing the neutral compounds was then
transferred to the silica gel column and the receiver was rinsed with a
small volume of hexane which was added to the column.  The reservoir was
filled with hexane.  As the solvent level dropped, a total of 5 column
volumes was added.  When the solvent reaches the bed, five column volumes
of the next solvent are added after the receiver is rinsed with small
portions of this solvent.   In a similar manner, five column volumes of
each succeeding solvent combinations were added to give a total of four
fractions.

          The solvents and desired order were:

          •    F-l, Non-polar neutrals, eluted with hexane.

          •    F-2, Moderately polar neutrals, eluted with 1:1 hexane:
               methylene chloride.

          •    F-3, Polar neutrals, eluted with 99:1 methylene chloride:
               methanol.

          •    F-4, Very polar neutrals, eluted with methanol.

Each fraction was collected and then concentrated.
                                    52

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C. D.  Smith
          Separation and Derivatization of Acidic Compounds—The alkaline
extract containing the acidic compounds was methylated in two steps to con-
vert phenols into methyl ethers using dimethyl sulfate and carboxylic acids
into methyl esters diazomethane to yield fractions F-5 and F-6 as described
below.

          The alkaline extract was placed in a 250 ml round bottom flask and
10 ml of 50 percent NaOH-was added.  The flask was heated to 90°C after which
time 10 ml of dimethyl sulfate was added dropwise over a period of ten
minutes.  After the addition of dimethyl sulfate, the mixture was stirred
for one hour.  After the excess dimethyl sulfate was destroyed by addition
of 5 ml of 50 percent NaOH, the mixture was cooled to room temperature.  The
aqueous mixture was then extracted in a continuous extractor for 24 hours
with ethyl ether.  The ether extract containing the ethers of phenols was
concentrated to 1 ml.

          After extracting the phenol ethers, the alkaline solution was
acidified with 6N HC1 to a pH 5 2.  This acidic solution was extracted in a
continuous extractor for 24 hours with ethyl ether.  The ethereal extract
was concentrated to about 1 to 2 ml and then transferred to an open hypo-vial.
About 1 ml of a diazomethane solution prepared as described below was added
to the extract concentrate.  After swirling the mixture, more diazomethane
was added until a yellow color persisted.  The mixture was allowed to sit
for 15 minutes with occasional swirling.  The excess diazomethane was then
removed by evaporation on top of a steam bath.  The solution containing
methyl esters of carboxylic acids was concentrated.

          Diazomethane was prepared in a special distillation apparatus that
has Clear-Seal joints in place of ground glass joints to prevent possible
explosions (Adrich cat. #210-0250).  The preparative procedure which follows
was supplied with this kit.  Twenty-five ml of 95 percent ethanol is added
to a solution of KOH in water (5g in 8 ml) contained in a 100 ml distilling
flask fitted with a dropping funnel and a condenser.  The condenser is
connected to two receiving flasks in series, the second containing 20 to 30
ml of ethyl ether.  Both receivers are cooled to 0°C.

          The flask containing the KOH solution is heated in a water bath
to 65°C and a solution of 21.5g (0.1 mole) of Diazald in about 200 ml of
ethyl ether is added through the dropping funnel in about 25 minutes.  When
the dropping funnel is empty, another 40 ml of ether is added and the dis-
tillation is continued until the distilling ether is colorless.  This
distillate contains about 3 grams of diazomethane.

          Concentration of Sample Extract—Each of the sample extracts
generated in this separation scheme were concentrated before analysis.
Radian employed both macro and micro Kuderna-Danish (K-D) concentrators for
this purpose.  Typically, an extract was concentrated to 5-10 ml in a
large K-D and then further concentrated to 1 ml in a micro K-D.  An internal
standard, di0-anthracene was then added to each extract at a known level,
                                    53

-------
 C. D. Smith
 typically  200  ppm.  All  sample  concentrates were stored  in  crimp-top  vials
 with  Teflon-lined  seals.

 Identification of  Individual Components—Each extract generated  as  described
 previously was analyzed  by  combined gas chromatography/mass  spectrometry
 (GC/MS)  utilizing  either a  Hewlett Packard Model 5982 or  a  Hewlett  Packard
 Model 5985 GC/MS computer system.  Both capillary and packed column gas
 chromatography were employed as described in the following  subsections.

           Identification of the chromatographic peaks was achieved  by
 analysis of  the individual  mass spectra.  Interpretation  of  mass  spectra
 was performed  by three approaches:

           •     Manual interpretation of an unknown mass spectrum.

           *     Comparison of the unknown mass spectrum against the
                mass spectrum generated from the analysis  of  a
                previously analyzed standard.

           •     Computer  search  of the unknown mass spectrum
                against libraries containing reference spectra.

           In addition, another  technique was utilized to  identify selected
 organic  species at trace levels.  This technique, termed  selected ion
 current  profile (SICP) searches, is based on the appearance  of key  ions
 within a narrow retention time window.  This technique was utilized to
 search for certain compounds, especially polynuclear aromatic hydrocarbons,
 in the extracts.   Identification of the suspected compounds  was  confirmed
 by examination of  their  mass spectra.

 Analysis of  ABN Sample Extracts—Each extract from the ABN separation
 scheme was analyzed on a six-foot chromatographic column  containing one
 percent  SP-2250 on 80/100 Supelcoport.  Typically, 2y£ of each sample extract
was injected onto  the column.

           The  GC conditions were as follows:  After an initial hold at 50°C
 for four minutes,  the column was temperature programmed to  260°C at 8°C per
minute.  The organic species which eluted from the gas chromatograph  were
 transferred  to  the ion source of the mass spectrometer by means  of  a  glass
jet separator.   The mass  spectrometer was scanned continuously from m/e
50 to m/e  350 with a cycle  time of three seconds.

Analysis of  Process Liquids—The process liquids were analyzed by capillary
GC/MS  employing a special large bore 60M SP-2100 WOOT capillary  column.
The chromatographic and  mass spectrometer conditions were the same  as the
ABN analysis with ly£ of  each sample injected.

Analysis of  Tenax Tubes—Volatile species were determined by thermally
desorbing the  organics sorbed onto the Tenax tubes into the  GC/MS system.
A Tekmar Liquid Sample Concentrator was employed for this purpose.  The
                                    54

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C. D. Smith
sample was desorbed by rapidly heating the Tenax trap to 180°C and passing
a helium flow over the sorbent.  The sorbent tube effluent was connected
directly to the head of a cold (- 40°C) gas chromatographic column.  A
9-foot column packed with Carbopack C  (80/100 mesh) coated with 0.2 percent
Carbowax 1500, preceded by a one-foot section packed with Chromosorb W
coated with 3 percent Carbowax 1500 was employed for this analysis.
Quantitative analysis was achieved by injecting 50 ng of d8-toluene in
methanol onto the cold chromatographic column.

          The mass spectrometer was operated in the repetitive scanning
mode, scanning continuously from m/e 45 to m/e 300.  Electron impact (70 eV)
ionization was also employed for this work.  After the thermal desorption
was completed, the gas chromatograph was rapidly heated to 60 °C.   The
temperature was held at 60 °C for four minutes and then temperature programmed
to 170°C at 4°C per minute.  The temperature was held at 170°C until all of
the volatile species had eluted.


Semi-Quantitative Analysis

          Semi-quantitative analysis of the identified compounds  was achieved
by measurement of the area under the selected ion current profile for each
compound.  For a given compound, the area under the most abundant ion was
calculated using the data system.  The computed area was then compared against
the area found from the most abundant ion of the appropriate internal
standard, di0-anthracene or dg-toluene.  The concentration of the species is
then calculated using the following equation:

                      x C
                         a
                    A  x  R
                     a

where  C  is the concentration of the component.  AC is the integrated area
of the characteristic ion from the selected ion current profile,  R is the
response factor for this component relative to the internal standard,  Aa
is the integrated area of the characteristic ion for the internal standard
and Ca is the concentration of the internal standard in the sample.

          Radian determined response factors for many compounds relative to
di o-anthracene and da-toluene.  Where the response factor was not known, a
value of 1.0 was employed.
          Electron impact (70 eV) ionization was employed exclusively for
analyses.  The mass spectral information obtained was stored on a magnetic
disc for future interpretation and reference.
                                     55

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 C.  D.  Smith
Wastewater and Cooling Tower Analyses

Oil

          The oil layer samples are assayed by placing 2 ml of oil into an
open container.  The sample is stirred for 8 hours which allows the volatile
material in the sample to evaporate.  The volatiles content is represented
by the change in the sample weight over the test period.

          Calculation of volatile organics in an oil sample can be
accomplished with the equation below:
               VO =
Aw
w.
 i
where
          VO = weight fraction of volatiles in sample.

          Aw = initial sample weight - final sample weight.

          w. = initial sample weight.

          The emission rate of volatile hydrocarbons from oil can be calcu-
 lated  using the following equation:
               ER
                 oil
   G(VO. - VO )
   	i	o
      1 - VO.
            i
where
          ER    = emission rate of hydrocarbon, Ib/hr.

          G     = flow of weathered oil, Ib/hr.

          VO.   = weight fraction of volatiles in inlet oil.

          VO    = weight fraction of volatiles in outlet oil.
            o
Water
          Wastewater samples are analyzed for the amount of purgeable
organics.  The basis for the analysis is that only the volatile components
in the wastewater collection and treatment systems will be lost as fugitive
emissions.  These volatile compounds comprise the bulk of the purgeable
organics in the liquid.
                                    56

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C. D. Smith
          The purgeable organics are swept out of the water into a Teflon
sampling bag.  At the conclusion of the purging cycle, the contents of the
Teflon bag are analyzed on the Total Hydrocarbon Analyzer as previously
described.  The equipment for this analysis is organized as shown in Figure
18.  The bag is a standard Teflon sampling bag.  The purge gas for the Bellar
unit is zero grade nitrogen with a flow rate of approximately 30 ml/min.   The
flow rate is controlled with two needle valves but will vary slightly from
sample to sample and must be measured each time using a bubble meter on the
downstream side of the Bellar apparatus.  Purging is continued for approxi-
mately 30 minutes.  The Bellar apparatus requires thorough cleaning between
samples.  The Teflon bag must be thoroughly flushed with zero grade nitrogen
between each sample and a blank sample is analyzed for total hydrocarbons at
the end of the flushing cycle.

          The volatile hydrocarbon content of the water can be calculated
from the following equation:
where
          VO = (FR) (time) (ppmw) (P         )
                                    purge gas
          VO   = volatile organics, grams.

          FR   = purge flow rate, ml/min.

          time = time of purge, min.

          ppmw = concentration of total hydrocarbon in bag,  parts  per
                 million by weight.

          P          = density of purge gas,  g/ml.
           purge gas

          The emission rate of volatile hydrocarbons can then be calculated
with the following equation:
               ER
                 water
       500 (f ) (VO. - VO )
       	w	i     o
               V
where
          ER      = emission rate of hydrocarbon,  Ib/hr.
            water
          f       = flow rate of water through system,  gal/min.
           w
          VO.
            i
= volatile organics in the inlet water stream,  grams.
                                    57

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C. D.  Smith
                                       III" OO
                                                   TUDINO
                                   TOOIIIO

                                nuuueii
                   •<••• oo cor re n ittuiim

                          -K3=-,T"
                             MICIIO
                           ;tou

                             IIUUUtN lUUINtt
                                                  UlllliO BISK
                                       NELLAH UHII
     Figure 18.   Wastewater  and Cooling  Tower  Samples Purge Apparatus
                                        58

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C. D.  Smith
          VO  = volatile organics in the outlet water stream, grains.

          V   = volume of sample, ml.
           s

Total Organic Carbon

          Total organic carbon assays were accomplished with a Dohrraann
DC52D TOG Analyzer.  This instrument oxidizes organics to carbon dioxide
and then reduces the carbon dioxide to methane.  The methane is measured
with a flame ionization detector.

          The instrument is zeroed using a "zero carbon water standard"
especially prepared for this analysis by Radian.  The water is deionized,
filtered and distilled from potassium permanganate under helium with a
high reflux.  This has proven to be superior to commercial standards.
The standard for the analysis is 180 ppm carbon in water available from
Dohrmann.

          Several replications of each sample were required because the
size of the portion of the sample actually analyzed is so small (30 \iH)
that it is difficult to obtain a representative portion.


Stack Gas Analyses


Particulate Determination

          The total weight of the particulates was determined from the com-
bined weight of material collected on the filter, on the exposed surfaces
preceeding the filter in the EPA Method 5 sampling train, and in the first
impinger.  Procedures described in EPA Reference Method 5 were used, and a
gain loading value was determined based on the total volume of stack gas
sampled.


Sulfur Oxides (SOX)

          Separate analyses for SO3 and SOa were performed on the impinger
samples collected during each EPA Method 5 train operation.  Aliquots of the
isopropanol (SOs) and the two 6 percent HaOa^SOa) impingers were titrated with
barium perchlorate to a Thorin indicator and point as specified in the EPA
Reference Method 8.  The amount of sulfate found was used to determine the
amounts of S03 and S02 originally collected from the volume of stack gas
sampled.

Determination of Nitrogen Oxides - Phenoldisulfonic Acid Method

          Nitrogen oxides (NO and/or NOa, or collectively, NOX) in stack gas
are determined as nitrate (N03) colorimetrically.  N0v is collected in a
                                                     X
                                     59

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 C.  D.  Smith
glass flow-through type bomb and converted to nitrate ion by reaction with
aqueous hydrogen peroxide which is injected immediately following collection
of the sample.  A yellow color is developed at a later time by the addition
of reagents.  The color intensity developed is a function of the concentra-
tion of the nitrate.  The intensity is measured using a spectrophotometer
capable of operating at 410 nM.

Referee Method for Low Concentrations of Nitrate:
Spectrophotometric Using Chromotropic Acid

           In  this method a 2-ml nitrate sample is  mixed with masking reagents
and  chromotropic acid indicator in a sulfuric acid medium.
    2NO?
medium
Yellow Color,  Max.
Absorbance =  410 nM
                   S03H    S03H
 The absorbance of the yellow reaction product is measured in a 1-cm cell at
 410 nM.  The nitrate concentration is calculated by comparing the absorbance
 to  that  of a known nitrate standard.


 Aldehydes

          The 1 percent solution bisulfite impinger solutions were analyzed
 using an iodine-starch titration.  Samples were collected,  diluted to 50 ml
 and  treated with 10 ml of bisulfite and 1 ml starch indicator.  Any excess
 bisulfite was then destroyed with an excess of 0.1 N iodine.   The excess
 iodine was then destroyed with a few drops of sodium thiosulfate.   The
 thiosulfate was then titrated to a faint blue endpoint.   Addition of 25  ml
 of carbonate buffer solution released the complexed bisulfite which was
 titrated to a final endpoint with 0.01 N iodine.

          This procedure measures total aldehydes as formaldehyde.   One  ml
 of 0.01 N iodine is equivalent to 0.15 mg of formaldehyde.   By accurately
measuring the amount of titrant used  in the final titration only,  the total
 mg of aldehyde may be calculated.
                                     60

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 C. D.  Smith
Ammonia

          Ammonia in the gas stream is collected by bubbling the gas through
impingers containing sulfuric acid at a pH < 2.  Ammonia is determined by a
distillation-titration method in which the sample is buffered to pH of 9.5
by using sodium hydroxide and a sodium tetraborate buffer.  The sample is
then placed in a distillation flask with the ammonia being driven off and
bubbled through an indicating boric acid scrubbing solution.  This scrubbing
solution changes color upon reaction with the ammonia.  The amount of ammonia
present is quantified by a titration technique utilizing a standard sulfuric
acid solution to titrate back to the indicator's original color.


Hydrogen Cyanide

          Cyanide in the gas stream is collected by bubbling the gas through
impingers containing sodium hydroxide at pH < 12.  The resulting impinger
solutions are tested for the presence of oxidizing agents, which if found
are removed by the addition of ascorbic acid.  The solutions are also tested
for the presence of sulfide, which if found is precipitated using lead
nitrate and filtered off.  An aliquot of sample is then placed in a cyanide
distillation apparatus and an air purge is applied with a vacuum.  The sample
is acidified using sulfuric acid with the resultant off-gases being collected
in a bubbler containing a solution of sodium hydroxide.  This distillation is
used to separate CN  from other cyano compounds.  The concentration of CN~
in the scrubber solution is then determined by colorimetric determination
using pyridine-barbituric acid, which forms an intense blue color with free
cyanide.  The absorbance is then read and concentrations determined against
standards.  These concentrations are calculated as hydrogen cyanide.
                                     61

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R. M. Roberts
                                  REVIEW

                                    by

                              R. M. Roberts
                     KVB, A Research-Cottrell Company
                             Tustin,  California

                                    on


            METHODOLOGY - SAMPLING AND ANALYSIS OF ATMOSPHERIC

                    EMISSIONS FROM PETROLEUM REFINERIES
                                  RESUME

         Richard M. Roberts is a Principal Engineer in the Research &
Analyses Division at KVB.  His academic background comprises a B.S. degree
in Chemistry from U.C.L.A. at Aerojet-General Corp., he moved from
analytical chemistry to specialized instrumentation development and thence
to bench and engineering studies involving various processes keyed to
pollution control or energy conservation.  Prior to his recent affiliation
with KVB, Mr. Roberts was vice president of Analytical Research Laboratories,
Inc., in charge of government contract operations.
                                     62

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R. M. Roberts
                                  REVIEW

                                    by

                               R. M.  Roberts
                      KVB,  A Research-Cottrell  Company
                             Tustin, California

                                    on

            METHODOLOGY - SAMPLING AND ANALYSIS OF ATMOSPHERIC

                    EMISSIONS FROM PETROLEUM  REFINERIES
OVERVIEW

         Perhaps unlike other papers given at this symposium, it is almost
inappropriate for a reviewer to comment on the present one in generalized
terms.  Mr. Smith has described very specific methodology, such that the
commentator has no alternative but to deal in the same coin—specifics.

         Because of this, and the possibility that some of these specifics
may have been misunderstood, the reviewer met with Calvin Smith before the
symposium.  This resulted in several clarifications of what were Indeed
reviewer's misconceptions.  The editing, if any, of the preprinted symposium
proceedings may not incorporate all of these clarifications, however.
These misunderstood subjects are therefore still addressed here, assuming
that other readers may stumble on the same topics.  In such cases, the
clarifications provided by Mr. Smith have been provided.

         The reviewer's knowledge base of the present work was limited to
the paper considered here and that presented by D. D. Rosebrook at the last
annual APCA meeting.  It is, nonetheless, clear from these publications
that one of the key products of the study was the development of nomographs
for estimating mass losses from valves and flanges using TLV readouts.

         We hope to apply this very powerful tool at an early date at a
large west coast refinery.  We would, however, first prescreen a large
population of valves and flanges using the old soap technique, then quantify
all the leakers found using the TLV sniffer.  As is suggested in some of
the following comments, this "broad brush" approach is statistically safe
and may, perhaps, be actually less laborious than systematically preselecting
a small count of representative fittings.
                                    63

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R. M. Roberts
 SPECIFIC  COMMENTS

 Statistical  Base

          It  is hoped  that  the population of valves  and  flanges  selected  for
 testing (see p. 8,  Smith report) can be supported by statistical  arguments.
 It would  seem, given  the expectable incidence of leakers,  that  the  field
 sizes  may be too small, inviting skewing in the findings.  For  example,  at
 one refinery, we tested 3,100 gas service and 4,700 liquid service  flanges
 and located  only 17 leakers  in  the former and 2 leakers  in the  latter
 category.  Considering that  Radian recommends an upper  test population of
 less than one-tenth that,  the number of leakers found could be  only one  or
 two.  In  contrast,  the populations of pumps, compressors,  drains, and relief
 devices specified  appears  quite adequate.

          A point of clarification regarding valve and flange populations
 involves  Figure 3  (p. 15).   The failure there to identify  the bonnet flange
 as a potential valve  leakage point results from Radian's practice of
 including that seal as part  of  the flange population rather than  considering
 it as  part of a valve.

 Sampling  Trains

          Flow Through Method

          Explanation  of the  mode of operation of the sampling train
 principally  used (Figure 4,  p.  19) omitted a key factor.   No vent is shown.
 Mr.  Smith pointed  out that the  tent is affixed to the top  of the  valve with
 intentional  gaps being produced in the taping.  The tent itself is  sometimes
 punctured to allow inflow  of purge air.

          A problem with this arrangement is that one is bleeding  refinery
 air  into  the bag and  that  air may be of questionable and spatially  variable
 quality.   This is  corrected  for by taking a background  sample,  the  total
 hydrocarbon  content of which is input to the leakage formula.

         We  would  suggest  that  if an intentional vent,  fitted with  sections
 of activated charcoal and  silica gel, is used, you will "obviate the need
 for making the background  correction.  This means, of course, that  the
 sealing of the tent must be  tight since the envelope is being operated at a
 slight negative pressure.  Thus the sealing as shown in Figure  6  (p. 22)
 could invite leakage,  since  oily surfaces might be involved.

         An  incidental comment here addresses compressor testing.   Mr. Smith
advised that only the seals  on  these devices are tested.   Our experience has
shown that cap nuts, particularly the end one, also leak occasionally and
should be checked.
                                     64

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R. M. Roberts
         Blow-Through Technique

         Mr. Smith acknowledged the problems with this technique, which
consequently resulted in its very minor usage on the program.  The principal
problem is that, in using a compressed air carrier, any leakage from the
tent could result in erroneous data.  Flow is measured upstream of the
potential leak sites (in the tent).  Also, since such tent leaks may not
involve completely mixed gas, outflow composition may not truly represent
that which would result from the fully confined mixing of the air carrier
and the hydrocarbons escaping from the valve or fitting.

         It is assumed that the flow-through method was actually used in lieu
of the blow-through method.  This would be appropriate for the slow leaking
components.  In the case of high leakers, however, volumetric loss is
usually enough to drive the train without use of pump or carrier.  The
fitting is tightly bagged and the sample line run out to a gas meter,
analyzer, and any collection device required.

         Stack Grab Samples

         Management of moisture in flue gas grab samples has always been a
serious problem.  A technique for circumventing this is shown in Figure 12
(p. 35).  Calvin Smith acknowledged that the system proved to be less than
successful.

         Our experience has shown that use of the Perma Pure Drier in any
train in which compositional analyses are conducted should be cautiously
approached.  The device is definitely not permselective for water.  Hydro-
carbon species of interest also permeate the membrance and are lost to the
measurement.

Oil-Water Separators

         The methodology described for estimating hydrocarbon releases from
oil-water separators apparently did not furnish acceptable results.  The
IERL has now contracted with Engineering-Sciences to develop a more
acceptable approach.  The virtual source technique -is being investigated
there.  It is hoped that this controversial technique will prove successful.

Water Cooling Towers

         The discussion of in/out hydrocarbon change in water cooling towers
(p. 56) introduces a disturbing feature.  Emissions are based on the
difference in hydrocarbons measured in the purgeable organic fraction
present in the pre- and post-cooled streams.  Problems were encountered
when total organic carbon measurements were attempted.

         Working with the purgeable fraction is technically all right, jlf_
the system is faithfully measured the same way each time.  The bellar
Lichtenberg procedure was intended only for compounds that are quantitatively
                                     65

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R. M. Roberts
recovered by the method.  These are then specifically analyzed, usually by
GC/MS.  When total hydrocarbon readouts are used, as described here, you
also involve unresolved components that are higher boiling and which are
not quantitatively recovered.   His fractional recovery effect for materials
of intermediate volatility will vary with test conditions.  Thus, unless the
transfer process is not carefully reproduced, unreliable data can result.

         There is also the obvious question of the effect of measuring only
a fraction of substances that  are also fractionally lost during the cooling
process.  That is, if half of  intermediate boiler "Z" emits to the air
while passing through the cooling effects and only half is measured during
analyses of the in/out water samples, then the analysis would account for
only one quarter of "Z" being  emitted to the air.
                                    66

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C. D. Smith
                            QUESTIONS  AND  ANSWERS
Q.  James J. Morgester/California Air Resources Board - I was interested in
how you handled hot valves.

A. - In the case of hot valves we used a little different technique for
constructing the enclosure around it.  We generally had asbestos tape and
aluminum foil which actually made the seal at the valve.  A standard hose
clamp is enough to seal the aluminum foil on the asbestos tape.  I should
like to point out that you do not need a very tight seal with this vacuum
technique for sampling leaks.  As a matter of fact, sometimes with duct tape
and Mylar, the seals were made too tight.  In that case, you must punch a
small hole into the Mylar to reduce the vacuum inside that enclosure.

Q. James J. Morgester/California Air Resources Board - Thank you!  Do you
have an estimate of the total number of valves that you actually did bag
and what percentage of those were hot valves?

A. - I am not certain but I would say that the percentage of the valves
that we actually bagged that were hot was probably 3 or 4 percent.

Q.  James J. Morgester/California Air Resources Board - How did you limit
your sampling?

A. - You will get this information in detail in the succeeding papers.  As
I remember, with our arbitrary 200 ppm cut-off on the screening value, we,
in general, had designated something like 20 percent (± 5%), at any given
refinery of the valves to be bagged.  And for the first four refineries,
or so, we bagged everyone of those.  As the data base grew we realized two
things.  We were not able to bag everyone that we wanted to because of time
constraints, but additionally we realized that we had enough data so that
we could now bag a statistical sampling of those valves and flanges.  So we
did reduce the number that we sampled that were above 200 ppm after about
the fifth or sixth refinery.  For instance, it seems to me like we bagged
something like one out of 40 below 200 ppm as part of the quality control
program, and at low screening values (between 200 and 5,000 ppm), we would
bag something like 50 percent.  We never reduced the number that we bagged
in the high leak rate ranges, because they were the ones that were going
to have a pronounced influence on the emission factors, so we bagged every
one above a certain screening value.
                                     67

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C. D. Smith
Q.  James J. Morgester/California Air Resources Board - I noticed you
calibrated your lab device with propane and your field device with hexane,
was that simply an artifact that showed up or was there a reason for that?

A. - Well, there was a reason for it, I'm not sure how good it was.  The
fact is that you can obtain NBS standard of propane but you cannot get an
NBS standard of hexane in that concentration range.  We wanted to calibrate
the total hydrocarbon analyzer with the same material that we had an NBS
standard for.  For the TLV, as you know, its not nearly as critical that you
have that instrument calibrated exactly, because the readings that you get
from that instrument are quite variable.  We had certified standards of
hexane from manufacturers, but they were not traceable to an NBS standard,
whereas on the analyses of the bag samples we did want them traceable to an
NBS standard.

Q.  James J. Morgester/California Air Resources Board - If we developed,
however,  some kind of a regulation or standard that uses the field screening
devices, which is the direction we are all going, does Radian recommend that
standard be set up on hexane standard or propane standard?

Aj_ - I don't know what Radian recommends.  I think we and several others are
in the process of formulating what that should be.

Q.  James Stone/Louisiana Air Control Commission - I have several questions.
One of them is what type of refineries did you visit?  I've seen that
generally refineries fall into two types.  There is a major refinery that
would have its own crude oil supply available to it and it would have its
own internal engineering standards that it would adhere to and it would be
one type.  Then, the other type would be usually a bit smaller.  They would
usually get their crude from the spot market and a lot of times they are
running almost on a shoe string and so their maintenance procedures are quite
a bit different from what the major refineries usually are.  Did you make any
attempt to include or exclude different types?

A. - In the design we tried to get something that was representative of the
refinery industry.  So we went to refineries in four geographical locations.
We had them broken down into old and new refineries, the cut-off being an
old refinery was older than 20 years, or contained any unit that was over
20 years old.   We went to large refineries and small refineries.  The cut-
off there being any refinery that processed less than 50,000 barrels of
crude per day was a small refinery.  Anything more than that was a large
refinery.   We went to refineries that were primarily producing gasoline,
refineries that produced lubricating oils, and refineries that had mixes of
everything.   So,  we think we have a pretty representative sample of all the
different types of refineries.

Q.  James Stone/Louisiana Air Control Commission - Second question is what
about heat exchangers?  When I've gone through refineries there have been
many of these that are leaking.  They are a large source of fugitive
emissions, but it is a very difficult one to control or characterize.
                                     68

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C. D. Smith
A^_ - I believe that some of the flanges, in our data base, are in fact the
flanges on heat exchangers.

Q.  James Stone/Louisiana Air Control Commission - Looking at your sample
train it appears to me that you could adjust the amount of hydrocarbon
measured to any convenient number by the way you handle the apparatus.

A. - I didn't understand that.

Q.  James Stone/Louisiana Air Control Commission - O.K., if you have a small
leak and you sample at a slow rate, then you've got a large number, and if
you have a large leak you sample at a fast rate, you've got a small number.

A. - Yes, there is some adjustment of the concentration at equilibrium in
that sampling train, but that doesn't adjust the emission rate.

Q.  James Stone/Louisiana Air Control Commission - I think your sampling
system is very subject to being biased by the way you run it.  What you are
measuring is not independent of the operator, it is very much determined by
the way the operator handles the equipment.

A. - By adjusting the flow through the sampling train all you do is intro-
duce more or less dilution air.  The amount of hydrocarbon that is leaking
out of the valve is constant.  You are varying the concentration, in that
sampling train, by diluting it with more or less ambient air, depending on
how fast you run the vacuum pump.

Q.  James Stone/Louisiana Air Control Commission - But usually you don't
measure how much ambient air is leaking into it.  You just punch a hold.
That is no way to measure.

A._ - No!  The hydrocarbon leak from the valve plus the ambient air, that
total flow rate through the system, is measured by a dry gas meter on the
sampling train.  So, we do measure the amount of air that is coming through
that enclosure.

Q.  Paul Harrison/Engineering-Science - Why did you use the TLV Sniffer for
the correlations instead of the OVA?

A._ - We used the TLV because it was the first one that we encountered that
was a reasonable device.  It only weighs 2 to 3 pounds.  It is pretty
compact.  It is battery operated, and it is pretty sensitive.  You can read
on those scales that I showed you between 0- 100 ppm, or 0 - 1,000 ppm, or
0-10,000 ppm, or 0-100,000 ppm.  That is pretty flexible in terms of the
concentrations.  The reason we went to the OVA is because some people in
the EPA, decided that instrument gave a much faster response time than the
TLV did, and consequently you could measure the screening values at valves
a little bit faster.  In addition, it has a flame ionization detector,
which most people tend to think is a better, more reliable, detector for
                                      69

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 C.  D.  Smith
measuring hydrocarbons.  Also, response factors for hydrocarbons are
generally centered around one  (1), relative to each other, with a  flame
ionization detector, whereas with thermal conductivity cells sometimes they
are not.  With other kinds of  detectors the response factors are normally
so tightly grouped.

          We  started with the  TLV early into the program and when  the EPA
began  evaluating an OVA then we decided that we should probably do  that
too.

Q.  Paul Harrison/Engineering-Science - What was your experience with each,
I realize some of the reasons  why one is better than the other, from what
1 have heard, but what did you think of it in the field?

A_._ - As far as actually being  able to carry it around and operate  it, I
would  say that the only differences between the OVA and the TLV are:  the
OVA is a little heavier, and if you are the guy that has to lug it  up a
tower, then you are a little bit more reluctant to do that; it does recover
faster from a source that is leaking at a higher rate.  If you screen a
source that leaks at a 100,000 ppm with the TLV, it may be two or  three
minutes before it has come back to baseline.  So, in fact, the OVA  does
have a faster response in terms of return to baseline.  My basic problem
with OVA is that it has a fairly peculiar-type flame ionization detector.
Even though on most flame ionization detectors all hydrocarbons, and
generally they are referenced  to heptane, have response factors of  one
± 5 or 6 percent, on the OVA that is not the case.  Those response  factors
vary considerably and the "magic" of FID I think is a little misleading
there.

Q.  Paul Harrison/Engineering-Science - What was the smallest refinery you
hit?

A. - I think  it was something  like 8,000 barrels a day.

Q.  Paul Harrison/Engineering-Science - Was it fully integrated?

A._ - No.

Q.  Paul Harrison/Engineering-Science - I should comment that we have seen
things like Scotts Bluff in Nebraska where they are fully integrated at that
size,  so there are a few that  try to be fully integrated.  They look like
toys.

          Why don't you use the more readily available methane standards?
From the operational point of  view, it is much easier to get in pressurized
cylinders.   I can use either one, but it seems to me that methane  is much
more available.

A_^ - I suppose that it is just as easy to choose methane or hexane.  We were,
however,  relating the emission rates to hexane, as was done in previous studies,
                                      70

-------
C. D. Smith
so we chose to calibrate the TLV with hexane.  It was just as arbitrary, or
a little less arbitrary actually, for the total hydrocarbon analyser.  As I
said the reason we chose propane to calibrate it was because we could trace
it to a NBS standard.  And the other thing, that always tempers it, is that
with methane, not very many people are concerned about the amount of methane
that is being emitted, so why relate everything to methane?  Those are
arbitrary decisions, but I think that is probably the kind of thinking that
went into it.

COMMENT/Donald D. Rosebrook/Radian Corporation - If I may, I would like to
call for a short discussion from someone here in the audience.  As you are
aware, it was brought out somewhat by Calvin and much more broadly by Mike,
that we did not feel any confidence at all, in the numbers that we generated
for fugitive emissions from wastewater systems, and you should be aware that
the EPA has undertaken another study to measure those fugitive emissions.  I
would imagine that study has, within the last month or so, gotten underway.
That contract, as I understand it, is placed with Engineering-Science.  There
are some representatives here today of Engineering-Science and of EPA.  I
would like to make a general request that they give us a short summary as to
their approach, and how they intend to conduct these measurements.  Is there
someone here who is willing to address that question?

COMMENT/Bruce A. Tichenor/USEPA-IERL/RTP - I am the project officer on the
study that Don just mentioned.  The contract was let a month ago.  It is
going to extend for 16 months, and that 16 months means that is until the
final report is due.

          Basically, all we are talking about is a three-phase program.   The
first phase is scheduled for about three months and is essentially the
development of the experimental methodology.  The second phase will also
extend about three months, and these numbers may be off a month or so, but
I don't think so.  That will be the verification of that methodology in the
field at operating petroleum refineries and we are going to look at two
petroleum refineries to do this.  What we are talking about is not relying
specifically on one method, but always having an alternative method so there
will be some way to verify that the data we do get are reasonable.  And the
third phase will be the data collection phase, which will be very similar to
the Radian program that will be discussed in the next two days, and is going
out into the field looking at operating wastewater systems, and gathering
emission data from them.  The range of sampling methods that are being looked
at include:  upwind, downwind dispersions; use of tracers; the possible
enclosing of the systems for some of the smaller systems; and, the possi-
bility of looking at laboratory models of the systems.  We are going to look
at approximately ten petroleum refineries, and we will hopefully get the
same cooperation from the industry we got with the Radian program.  That is
it in a nutshell, but like I said if any of you are interested in more
details feel free to contact me, Paul, or anyone else from Engineering-Science.
I am sure we can provide you that information.
                                     71

-------
C. D. Smith
COMMENT/Donald D. Rosebrook/Radian Corporation - Thank youI  Are there any
further questions for either Mike or Calvin or any further commentary from
the  conferees?

Q.   Joseph Zabago/Mobil Oil - What did you do about bonnet flanges?

A. - We considered the bonnet flange a flange.

Q.   Thomas Goff/Kern County Air Pollutj-on Control District - I was wondering
if the baggable  sources selected off the P&I diagram, which I understand  is
about  20  percent of those selected that were actually bagged and tested,
turned out to be the ones at ground level?

A. - We could not tell, on the piping and instrumentation diagrams which
ones were above  grade and which ones were not.  Then of course, the screen-
ing  value dictated which ones were sampled and which ones were not sampled.
If one above grade leaked, we sampled it.  If you will remember the slides
showing the sampling train, you saw the coil of black hose, the Teflon
lined hose.  We  had enough hose to sample at levels of around 120 to 150
feet.  As a matter of fact, we used that to sample relief valves.

Q.   P. L. Scupholme/BP - Environmental Control Center/ENGLAND - Can I first
of all say how impressive I've found your presentation.  My colleagues in
Europe hope we can use some of the data at European refineries in the years
to come.  My question though is probably simple, hopefully not irrelevant.
What effect do you think weather conditions may have on these emissions,
either ambient temperature or wind speed?

A_._ - I have no data that, allows me to say one way or the other.  I have no
idea.

COMMENT/Donald D. Rosebrook/Radian Corporation - We can say one thing.  We
can  tell  you a little bit about what weather conditions do to the sample
team and  therefore some of the variability of the data.  I think you will see
later in  some of these presentations, where there is some significant
variability,  there apparently is some small bias introduced from one
refinery where the weather was rotten.  If you count sleet, snow and high
wind and  cold rain at about 30°F, rotten weather, that is what it was.

Q.   (To Roberts)  William Benusa/Gulf R & D Company - You commented on the
sampling  technique using the Bellar system as probably not being very
adequate.   Did you have a recommendation as to a better system for getting
hydrocarbons  from your cooling towers or wastewater treatment systems?

A. (By Roberts)  - We are thinking about writing a proposal on that very
subject now.   I'm afraid I can't comment on the approach that we would
recommend, but I think there is a better way.  It involves, in essence, the
same type of  methodology that Calvin described, looking at hydrocarbons in
and out.   It  is  just a matter of the measurement of these moieties.
                                      72

-------
C. D. Smith
Q.  William Benusa/Gulf R & D Company - When you sampled, say valves with
liquid leaks, under the screening procedure  what kind of a judgment do you
make as to the placement of the probe?

A._ - You'll find very quickly that you don't put the probe in the liquid or
you've destroyed that reading.  In general, if the valve stem is coming out
like this, the liquid is going to be dripping down there, so you obviously
don't put the probe right in the liquid, but still you choose four cardinal
points.  You just rotate them so that you don't have the probe in the
liquid.  It obviously is going to bias the reading, but then if you have a
liquid leak it is going to be a highly leaking valve anyway.
                                      73

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L. P. Provost
                     QUALITY ASSURANCE AND DEVELOPMENT OF
                              STATISTICAL MODELS

                               Lloyd P. Provost
                              Radian Corporation
                                Austin, Texas
                                   ABSTRACT

          This paper discusses the primary quality assurance and statistical
analysis procedures used in Radian's fugitive emissions sampling program.
Quality control data from the screening and sampling of baggable sources is
analyzed and a critical evaluation of the statistical models used to estimate
emission factors is presented.
                                    RESUME

          Lloyd Provost is the Quality Assurance Director for Radian Corpora-
tion.  He received his B.S. degree from the University of Tennessee in
Statistics and his M.S. degree from the University of Florida in Applied
Statistics.  He worked for the U.S. Department of Agriculture as a mathemati-
cal statistician for seven years prior to joining Radian in 1977.  His duties
at Radian include overseeing quality assurance programs for all of Radian's
contract work, coordinating the development and execution of specific quality
control programs, and coordination of data analyses for specific projects.
Mr. Provost is a member of the American Statistical Association, ASTM
Committee Ell on Statistical Methods, ANSI Z-l Committee on Quality Assurance
and the American Society for Quality Control (ASQC).
                                     74

-------
L. P. Provost
                    QUALITY ASSURANCE AND DEVELOPMENT OF
                             STATISTICAL MODELS
                                  SECTION  1

                                INTRODUCTION
          This paper presents and discusses the most significant quality
control efforts in Radian's Refinery Fugitive Emissions Sampling program.
The complete QA/QC procedures and data are described in Appendix C to the
final report, "Quality Assurance and Statistical Analysis of Emissions Data."

          This paper presents the results in three major areas of the QA
program:

          •    Quality control for hydrocarbon screening devices.

          •    Quality control for hydrocarbon measurements from
               baggable sources.

          •    Statistical procedures for analyzing the emissions
               data.
                                       75

-------
 L.  P. Provost
                                  SECTION  2

              QUALITY CONTROL  FOR HYDROCARBON SCREENING DEVICES
           The  screening of sources during this field sampling program was
 accomplished with  sensitive portable hydrocarbon detectors.  The principal
 device  used in this study was the J. W. Bacharach Instrument Co.  "TLV
 Sniffer."  The Century Instrument Company Organic Vapor Analyzer (Model
 OVA-108) was used  for some screening, but these values were not included in
 the  primary correlation calculations.  The instruments were calibrated daily
 with standard  mixtures of hexane in air.  The OVA-108 and TLV Sniffer give
 direct  readings of hydrocarbon concentrations in ppm by volume.

           When screening, the probe of the hydrocarbon detector was normally
 placed  as  close as possible to the potentially leaking source.  The maximum
 reading obtained on the source was used as the screening value.  For evalua-
 tion purposes, some readings were also obtained five centimeters from the
 source  for all source types.

 .SCREENING  DEVICE CALIBRATION CHECKS

           The  TLV  and OVA instruments were calibrated each day they were used.
 Standards  of 500-525 ppmv and 2000 ppmv hexane in air were used to get a two
 point calibration  each day.  Before a recalibration was made each day, the
 values  obtained from the instrument were recorded.  This served two purposes:

           •     Check for instrument damage or malfunction,

           •     Document the stability of the daily calibration.

          The  results of these calibration checks at selected refineries
visited are shown  in Figure 1 for the lower standard.  The data for the high
standard were  similar.   Three different TLV instruments were used at these
refineries.  Table 1 gives a statistical summary of these data.  None of the
devices gives  any  indication of a consistent bias (or drift) at either the
high or low level.   The maximum percent differences found were always less
than 20 percent of the known concentration.

          Based on this data, it is concluded that the daily calibration of
the screening  devices at two levels using standard gases was adequate for
obtaining consistent,  unbiased readings.
                                     76

-------
                                                          Symbol is code for  device :
   fc £. 0 4-                                                                                                1
   felb +                                                    1  TLV  7C7C04
   faiu +                                                    2  TLV  7C7C16                                                 ^
   kOS +                                                    3  TLV  7ESB55                                                 H
T  6CU 4-                                                                                                                   °
L  S1^ 4-                                                                                                                   §
V  690 +                                                                                        1                           £
   5Hb f
H  b a U +
E  ^ *
A  =>70 *
       +•
       +                                3                                 3
G
   545 +
0  M+U 4-                   3            2        1
N  bib +                                                 3
       +               32                 33
L
0  5£U +                                    *                313
w  bib +
       +           2                        a
       •»•           3                        11
 s
 T  500 4-12            1
 D  H'^b +
       4-                    1
       +
       +           1            1
   470 4-
   "+6b +
               2                3
               + . -->---+---+.--_4-----f---4- --- -(•_-- + _--4._-_ + -_-4.___ + _-_ + ._.4._-.4.--_4..«_ + _._ + _._4..__4.
               1   2   3    4    5   6    /   o    9   iO  11  12   13   It  15  16   17   1H  19  UO   21
            3  OBS
                   Figure  1.  Calibration Checks  for TLV Sniffer - Low  Standard

-------
00
                                     TABLE 1.   STATISTICAL SUMMARY OF CALIBRATION CHECKS

Instrument 1
Low Standard (525 ppm)
High Standard (2023 ppm)
Instrument 2
Low Standard
High Standard
Instrument 3
Low Standard
High Standard

Number
of Checks

21
21

8
8

20
20

Average
Difference
(ppm)

- 4.4
-28.0

-16.9
- 4.8

- 5.3
-19.8

Average
Percent
Difference

-0.8
-1.4

-3.2
-0.2

-1.0
-1.0

Minimum
Percent
Difference

-12.3
-11.0

- 6.1
-14.3

-14.3
-11.0

Maximum
Percent
Difference

19.5
3.8

3.8
2.9

7.9
8.7
Standard
Deviation
of %
Difference

7.3
4.1

5.4
2.9

5.2
4.1
95% Confidence
Interval for
Average Percent
Difference

(-4.1 , 2.5)
(-3.3 , .5)

(-7.7 , 1.3)
(-4.7 , 4.3)

(-3.4 , 1.4)
(-2.0 , 0.9)
                                                                                                                                >rJ
                                                                                                                                 id
                                                                                                                                 i-i
                                                                                                                                 o
           Percent difference = (Measured - Standard) x 100/Standard

-------
L. P. Provost
REPEATABILITY AND REPRODUCIBILITY OF  SCREENING DEVICES

          The repeatability of the screening process was investigated by
performing repeated screenings on the same source by the same operators.
Both the TLV sniffer and the OVA-108 instruments were used to screen at the
sources and 5 cm from the source.  The absolute value of the percent differ-
ence between the duplicate readings is plotted against the mean of the
duplicate readings in Figures 2 and 3 for maximum reading using a TLV and
OVA, respectively.  Most percent differences at the source are less than 75
percent for the TLV and below 40 percent for the OVA.  The percent differ-
ences for the TLV at 5 cm tend to be higher, indicating that the method is
not as repeatable as screening directly at the source.

          Quality control studies were run on the TLV sniffer to determine
the reproducibility of the measurement method.  Between one and five sources
at selected refineries were selected with screening values between 200 and
10,000 ppm.  Each day that screening was done, at least one team would
screen each of the sources.  Duplicate readings were sometimes performed on
each device, both at the source and 5 cm from the source.  Figure 4 illus-
trates typical results obtained from the repeated screenings using the TLV
sniffer at the source.  Within a day, the screening results from each team
were generally close.  A visual comparison of duplicate readings by the same
team can also be seen.  The magnitude of the concentrations at 5 cm is less
than at the source.   The magnitude of the difference between operators is
larger, in one case, and about the same in the other case.

          A variance component analysis was run on both TLV sniffer and
OVA-108 data from the reproducibility and repeatability studies on selected
devices.  The results of this analysis for each device are given in
Table 2.  The pooled standard deviation for all TLV repeat readings at the
source (all devices) is 0.50 Ln. (screening value), yielding a 90 percent
repeatability of 117 percent.

          The effect of different operators can also be observed in this
analysis.  Pooling the data from pumps and valves, the standard deviation is
56 percent.  Ninety percent reproducibility is then equal to 130 percent.
The pooled standard deviation for all OVA (at the source) repeat readings is
30.5 percent producing a repeatability of 85 percent.  Note that the
repeatability of the OVA instrument appears better than that of the TLV, but
that there is less data available to evaluate the OVA.

          A similar variance component analysis was done on the 5 cm
TLV readings.  The pooled standard deviation for repeat readings was
0.79 Lvi (screening value) and the pooled 90 percent repeatability is 184
percent.  This high repeatability figure again shows the 5 cm method to be
more variable than screening at the source.  Reproducibility was also calcu-
lated by pooling the variance from both TLV sniffers to describe the operator
effect.  The standard deviation is 1.06 and the percent reproducibility is
246 percent, again much higher than that for screening at the source.
                                      79

-------
  L.  P. Provost
                                        LE.t»ENU: A = I  UbS« B = 'i UUS« LIC.
      i
      1
      i
   175 *
      j
      r
at the source
      t
      i
   125 *
»     I -
      I
L'     »
I  100 4
f     /
f     t
      t
    75 +
      (
      i
      1
    50 +
      t
                                            9OJ_ Repe a tab i1 i ty^ -_ U_7%_
      >
      » A
      *
                             AAA

                              t\
                                    A
                                /\  rt
                              IV  /( UA (I
                                 ft rt  /<


                                A*.
  A     A
AAA

     A    A
  A  AAA
 A B        A
 «A A       t)
         U
    A    A
 A    /< A
           )UU                  lUbU

                            KLftN TLV, pprav


                   : A = I UBSi B =  i UBSi tit.
   175 4
      /
      t
      t
   15U «
                                                                                    lUuflUO
                                                   5 cm  from source
      t
      t
      *
   10U »
      *
    7S +
   iO *
      *
         A    B
      *   A   A
      *
    U *
                                          A       I'
                                                                   ionoo
                                          fB*M 5CM Tl.l .  ppmv

           Figure  2.   Percent Difference  Between Duplicate TLV Readings
                                             80

-------
L. P.  Provost
                                              A = 1 u«S« b = '* oaSi Lit.
 96
            at  the source
    \___	.'5.°J°.S?DeatabiUty_=_85%_	'_	__..
    t
  US *
    1
    t
    t
  32 *
    t
    t
    t
  16 *
    t
    t
    t
   0 4
     t
   BO +
     *
     t
     t
   to «•
     (
   to +
     *
     t
     t
   so *
X    *
     t
0    *
I  MO +
F    *
F    *
                                           f,LAN 1>VA, pprav
                                                                                   ----.-+
                                                                                    1VUQUU
                LEbtNUt H = 1 UUS. b = a UliS.  LIU.
         .*	_	fpj^Repeatabilit^^eSJ^
                                                                5 cm from  source
   ZO +
     *
     *
     t
   10 +
     f.
     t
     t
    0 «
     -«-
      0
                          100
    100U


HEAN SUM UVA .
                                                                  inouo
                                                                                      1UUQUU
        Figure  3.   Percent  Difference Between Duplicate OVA Readings
                                            81

-------
  L.  P. Provost
         /   at the  source
                                               SYMBOL IS CODE FOR SCREENER

         t
         t
T-        *
L        *
V   10000 +.
k
T
     lore,
      ten 4.

         *
         i

         1
         t
        C *
                                        fa    7     0     9   10    11    12    13    I1*


                                                 Ull!
 Ml TE:
            I RS HlL'l.'£tl
          ^... 5.. PK. f r.9™. .source	
                                                SYMBOL IS CODE FOR SCREENER
     1000
      100
NOT*-!
              )     i!
          2 UHS  HIUUt.ll
                                                   B

                                                 UAT
9   1U    11    1£   13
     Figure  4.   TLV Quality  Control - Daily Readings -  Refinery F,  Pump  Seal  92
                                              82

-------
00


TABLE


Valves

Variance Source Degrees of
TOTAL 23
IOTIVIDUAL VALVES 2
DAY 15
REPEAT 6



2 . VARIANCE

(for OVA)
in (screening value)



COMPONENTS FOR




Freedom Variance Component Percent
2.342
1.799
0.401
0.141

100
76.8
17.1
6.1



SCREENING



Variance

TOTAL
INDIVIDUAL
DAY
OPERATOR
REPEAT


MEASUREMENTS


Valves -
Source Degrees of

155
VALVES 5
70
39


AT THE SOURCE

(for TLV)
tn (screening value)
Freedom Variance Component Percent

2.847 100
1.384 48.6
1.134 39.8
0.060 2.1 •
H
O
O
03
rt








41 0.269 9.5
                 Variance Source
                                          90/:  Repeatability  «  87%
                                         Pump  Seals - in  (screening value)
                                     Degrees of Freedom    Variance Component
                                                                                  Percent
                                                                                                                       90X Repeatability -  121%
                                                                                                                       90% Reproducibility  -  134%
Pump Seals - In (screening value)
TOTAL 15 0-908
INDIVIDUAL PU:lPS 1 0.359
DAY 10 0.528
REPEAT 4 0.021

90% Repeatability - 362

100
Variance Source Degrees of Freedom
jy . j — — — ~_^— —
58.2 TOTAL
2.3 INDIVIDUAL PUMPS
DAY
OPERATOR
REPEAT

46
1
27
10
8
Variance Component Percet

0.^27
-0.008
0.192
0.068
0.167

100
0.0
44.9
15.9
39.2
                                                                                                                      90% Repeattbllity - 95*
                                                                                                                      90X Reproducibility - 113X

-------
L. P, Provost
          The OVA-108 screening device data from 5 cm was also checked
for repeatability.  The pooled standard deviation for repeated readings
is 0.28 Ln  (screening value) and the percent repeatability is 65 percent.
The repeatability for the 5 cm OVA readings is slightly better than that for
OVA screened at the source  (72 percent) but the difference is not statisti-
cally  significant.


TLV READINGS VS LEAK RATE

          Screening values were obtained during the field sampling program
when the  source was first located and rescreening values were obtained nearer
to the time that the source was actually sampled.  Correlations and nomo-
graphs have been developed to relate the maximum TLV with leak rates.  These
will be reported in another paper at this conference.  A number of summary
statistics were evaluated before selecting the maximum reading.  Table 3
reports simple correlations between leak rates and selected screening statis-
tics (including individual readings) for valves.  The maximum at the source
was selected because of its high correlations and simple determination.


TLV READINGS COMPARED TO "SOAP SCREENING"

          At one refinery, a short test was made to compare screening of
sources using a soap solution with screening using a TLV sniffer.  Following
the usual screening technique on selected sources, the maximum TLV value was
obtained.  Then the source was sprayed with either a "snoop" soap solution
 (relatively thin) or a relatively thick solution made from Ivory liquid soap.
Then the  "action" or "description" of the soap solution was recorded.

          This data is plotted in Figure 5.  As can be seen, the soap solu-
tion formed bubbles for all screening values greater than 1000 ppm except
for the vertical sources and one other valve.


CONCLUSIONS

          (1)  Daily two point calibration of the screening devices is
adequate to obtain unbiased readings.  Calibration will almost always be less
than 10%.

          (2)  Readings from both the TLV and OVA devices are quite variable.
Differences by the same operator at the same time can be up to 100% for read-
ings at the source and 200% for 5 cm readings.   Reproducibility (different
operators, different instrument)  can be up to  200% at the source and 300% at
5 cm.   For valves  and pump seals, these variations are small relative to the
order of magnitude differences between days and between devices.

          (3)   The maximum screening value, which is easily determined,
correlates with leak rate  as well as other possible statistics.
                                     84

-------
             TABLE  3.       CORRELATIONS  OF  SCREENING  VARIABLES  AND NONMETHANE LEAK RATES
00
Ln



1.
2.
3.
4.
5.
6.
7.
(Lb/hr) - VALVES

VARIABLE (2) MAX BC
Hosimethniie Leak .628(584)
Maximum Screening Value
Maximum Reacreenlng Value
Average Reacreenlng Value
Avg of Maximum 5-CM Reading
North Stem Reading
North Gland Reading
(.All Correlations Based on Log or Var:

(3) MAX RSC (4) AVC RSC (5) 5-CM (6) N. 8TU
.715(260) .739(260) .685(246) . 703(751)
.745 .748 .593 .677
.978 .804 .858
.837 .890
.733
-

Lable;

(7) N. Gl.
.511(195)
.434
.633
.693
.722
.545
-
o
o
en
rt








                 Tabled valuea are r (m)

                       r - almple correlation coefficient - E(X1 - X)(Y1 - Y)    -  wher« X ond Y are the paired varlablea



                       a • number of palra of data obaervatlona uaed In computing correlation coefficient

-------
03
100,000 .


3 10,000
8
Ed
ex
^ 1,000 -
1
>
H
a 100 .
n
10 .
V VV
vv
V
& V - Valve
c ^ C - Compressor Seal
^^^ P - Pump Seal
v 0 - Vertical Service
Q

V
V

5
1 '1 ' 1 I |
No slight bubbling, rapid rapid bubbles
Bubbles barely detectible bubbles clusters, spitting
(1) (2) (3) (4)
                                                                                                                      IT)
                                                                                                                      O
                                                                                                                      O
                                       Description of Dubbling of  Soap  Solution
                                       sprayed on source
                       Figure 5.   Relationship of TLV Reading and Bubbling From Soap Solution

-------
L. P. Provost
          (4)   When comparing "soap bubble" screening to the TLV, a general
positive correlation is apparent, except for devices in vertical service.
                                     87

-------
 L.  P.  Provost
                                  SECTION  3

                QUALITY CONTROL FOR HYDROCARBON MEASUREMENTS

                            FROM BAGGABLE  SOURCES
          This section describes the quality control procedures implemented
 during the analysis of samples for methane and nomethane hydrocarben from
 process valves, pump seals, compressor seals, flanges, relief valves, and
 drains.  A significant amount of the total quality assurance effort went into
 this area because the sampling procedure had not been previously validated
 under field conditions and because of the extreme variability of leak rates
 found from these sources.  The quality control procedures discussed here
 include laboratory blind standards analysis, repeatability of the total hydro-
 carbon (THC) analysis, recovery studies of the sampling train, and repro-
 ducibility of the sampling/analysis from a given source.


 LABORATORY STANDARD ANALYSIS

          Regularly scheduled analyses of blind standards were used to
 evaluate the THC daily calibration as well as the stability of the calibra-
 tion.  The quality assurance protocol required at least one blind standard
 to be analyzed each week.  The following standard gases were used for these
 checks:

          Propane  (NBS)           16.3 ppmv -  722 ppmv

          Hexane                 525   ppmv - 8393 ppmv

          Methane                103   ppmv -  433 ppmv

          Ci - C6 Hydrocarbons    100   ppmv

 Most of the propane standards were NBS standards of propane in air.

          Figure 6 shows the percent difference versus the measured concen-
 tration where percent differences is computed as:

               % difference = (Known-Measured) * 100/Known.

          The differences ranged from - 88 ppm to + 66 ppm with an average
difference of - 2.5 ppmv and a standard deviation of 22.5 ppm.  A 95% con-
fidence interval for the mean difference is - 2.5 ± 6.6 ppm or - 9.1 to
4.1 ppm.
                                     88

-------
                                                     A = 1 ObS» B x Z ObS,
      t
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           0    60    120   3.60   240    SOU    360    420    400   540   faOO   £.60    /^U   7aO   840
                                           MEASURED CONCENTRATION (ppmv)
                Figure 6.  Hydrocarbon Blind Standards  Analysis Percent Differences

-------
 L.  P.  Provost
          The percent differences ranged from - 54.6% to 12.9% with an
average difference of - 1.65% and standard deviation of 9.9%.  This gives
a 95% confidence interval for the mean difference of - 1.65 ± 3.0% or
- 4.7% to 1.4%.


REPLICATE THC ANALYSES

          The analysis for methane and nomenthane hydrocarbon content of
fugitive emission gas samples was accomplished using a specially designed
Total Hydrocarbon Analyzer (THC) Model 301C made for Radian by Byron
Instruments.  For each sample, two runs were made with the results recorded
by a strip-chart recorder.

          To document the precision of this analysis, a stratified random
sample of pairs of runs were selected at each refinery and statistically
analyzed.  The percent difference for each pair was calculated using:

               „  ,.,.,-         (1st analyses - 2nd analysis)
               % difference =	i—-=—-	^—•*	-
                                 average  of two analyses

Figure 7 shows a plot of these percent differences obtained at each refinery.
As can be seen, most differences were within the target limits of ± 7%.  The
7% target limit was based on Radian laboratory studies prior to using the THC
in the field.

          The standard deviation was computed for each pair of readings.
These standard deviations are shown graphically in Figure 8.  The following
statistics summarize the duplicate THC analyses.

               # of replicate pairs:                130

               pooled standard deviation:             2.44%
               repeatability - maximum difference
               expected between two readings 95%
               of time:                               6.2%

               95% confidence interval for mean
               reading based on single analysis:    ±  4.8%
               95% confidence interval for mean
               reading based on the average of
               two analyses:                        ±  3.4%

          Since the average of the two readings was used in computing leak-
ing for all sources,  the ± 3.4% interval best describes the precision of the
THC analysis.
                                      90

-------
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       ABCDEFGHIJKL

                                                  REFINERY
                Figure 7.   Percent Difference in Replicate  THC Analysis  for Each Refinery

-------
                                 LEGtNDJ A =  1  OBSt B s 2 DBS, ETC.
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-------
L. P. Provost
 SAMPLING AND ANAJLYSIS  OF  STANDARDS - RECOVERY STUDIES

          To evaluate the overall accuracy of the baggable sampling and
analysis technique,  a procedure was devised to generate "known" leak rates.
Standards of propane and propylene were used as the emissions source, and the
leak rate was varied by altering the flow of these standards into the sampling
cart.   The use of flow meters to measure the rate of gas induced into the
system introduced an additional source of variation into the sampling/analysis
system.  Extensive calibration procedures were followed to insure that no
systematic error was introduced by using the flow meters.   Samples of the
induced leak were collected in bags using the usual procedure and set for THC
analysis as a "blind standard."

          Sixty-three recovery checks were made at the nine refineries visited
beginning with Refinery "E".  In addition, six similar checks were made of the
sampling train by Research Triangle Institute (RTI) during an EPA audit at
Refinery "E".  Eleven recovery checks were made at the Radian laboratory
between the visit to Refineries "I" and "J".  The induced leak rates ranged
from 0.007 to 2.93 Ibs/hr.  Figure 9 shows the percent recovery for each
induced leak rate plotted versus the induced leak rate with the plotted
symbol representing the refinery at which the check was made.

          Figure 10 shows a schematic plot of the recoveries obtained at each
refinery in the order in which they were visited.  A high recovery value of
235% obtained at Refinery "J" could not be explained for physical reasons.
The value was eliminated from further statistical analysis after it was
rejected using Dixon's statistical outlier test.   Some differences in
average recovery rates are evident from these plots.

          Table 4 contains a statistical summary of the recoveries at each
refinery and overall.  The results from the RTI audit are also given in the
table.  The 95% confidence intervals for the average recovery included 100%
for all refineries except "F" and "G", with the upper limit for "G" at 98.5%.
At Refinery "F" a new technique for pumping air through the sampling train
was instituted.  A check of the system after reviewing the accuracy checks
showed that a low bias would be introduced by the way the pump was fitted.
Therefore it was concluded that the leak rate data from Refinery-"F" could
be about 15% low.  When the accuracy checks from Refinery "F" are removed,
the remaining checks average 98.7% recovery with a 95% confidence interval of
95% to 103%.  It was therefore concluded that there was no significant source
of bias in the sampling/analysis system except for leak rate data from
Refinery "F".  Adjustments based on the amount of data obtained at Refinery
"F" and the estimated 15% bias were made to calculate emission factors and
their confidence intervals.


REPEATED SAMPLES FROM INDIVIDUAL SOURCES

          A significant effort was extended throughout the field sampling
program to evaluate the repeatability of the sampling/analysis procedures for
                                     93

-------
                                                                SYMBOL IS CODE FOR REFINEEY
v-D
PERCENT RECOVERY


250
225
200
175
150
125
inn
75
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                                                 INDUCED LEAK RATE (16/hr)
                                Figure 9.   Recovery Studies - Percent Recovery Versus Induced  Leak Rate

-------
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                                  RITIHERY 1C
Figure  10.   Sample Train Recovery  Studies - Refinery Fugitive  Emission:

-------
                                TABLE  4.
             STATISTICAL SUMMARY OF RECOVERY STUDIES
REFINERY

   E
   F
   G
  • H
   I
   J
   K
   L
   M
 Radian
                 NUMBER OF
              RECOVERY CHECKS
                    12
                     7
                    11
                     5
                     9
                     5
                     9
                     4
                     1
                    11
        TOTAL      74
TOTAL WITHOUT F    67
RTI AUDIT DURING    6
 REFINERY E
  AVERAGE
RECOVERY (%)
   95.3
   85.7
   89.0
   82.4
   99.2
  107.4
  112.3
  107.4
   96.5
  100.7

   97.4
   98.7
   92.6
:ANDARD DEVIATION RANGE OF RECOVERIES (%)
IF RECOVERY (%) MINIMUM MAXIMUM
15.5
8.5
14.2
22.5
22.0
7.1
21.2
7.0
7.5
17.2
17.3
12.3
64.4
66.9
63.5
44.0
76.0
97.4
88.0
100.7
85.6
44.0
44.0
78.5
118.8
92.8
117.6
100.0
145.0
113.6
161.3
115.3
114.8
161.3
161.3
112.2
95% CONFIDENCE INTERVAL
FOR AVERAGE RECOVERY (%)
(85.5 ,
(77.4 ,
(79.5 ,
(54.5 ,
(82.3 ,
(98.6 ,
(96.0 ,
(96.2 ,
(95.7 ,
(93.5 ,
(94.5 ,
(79.7 ,
105.1)
93.0)
98.0)
110.3)
116.1)
116.2)
128.6)
118.6)
105.7)
101.3)
102.9)
105.5)

-------
L. P. Provost
baggable sources.  Repeated samplings were done to determine the variability
in the leak rate due to the sampling procedure, sampling teams, inherent
changes in the leak rate over time, and level of leak rate.  The number of
quality control samples was as follows:
Source Type
Valves
Pump Seals
Compressor Seals
Flanges
Relief Valves
Drains
Number of
Sources
Sampled
627
382
124
62
52
49
Number of
Sources
with QC
Samples
65
62
40
7
16
14
Percent of
Sources
with QC
Samples
10.4
16.2
32.3
11.3
30.7
28.6
Total
Number of
QC Samples
137
133
66
12
30
33
     TOTAL
1296
204
15.7%
411
Approximately 16% of the sources sampled had one or more quality control
sample with an average of about two quality control samples for each source
with QC.

          Control charts were provided for recording the intra- and inter-
team differences at each refinery as soon as the analyses were completed.
An example of the charts for one refinery are shown in Figure 11.  Figures
12, 13, and 14 show the percent differences for each QC check grouped by
refineries for valves, pump seals, and drains.  Figure 15 shows these same
percent differences plotted versus the average leak rate of the samples for
valves.  Control limits of ± 70% are included on these plots.  A maximum
70% difference between samples was the original goal for the baggables
sampling and analysis procedure.  As can be seen, a significant number of
checks were outside these limits.  Leak rates from drains were especially
nonrepeatable.  A frequency distribution of the percent differences for
valves shown in Figure 16.

          Figure 17 shows the standard deviation of leak rates for each valve
versus the average leak rate of the original and quality control samples.
Since the standard deviation is obviously related to the concentration level,
percent standard deviations were computed.  The percent standard deviations
are plotted versus the mean leak rate in Figure 18.  The percent standard
deviation appears fairly constant for all levels with a slightly larger
percent difference for leak rates less than 0.01 Ibs/hr.
                                    97

-------
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                                                 Leakers (>.5 Iba/lir)                             Intermediate Leakers (<.5 Ibs/lir)
                               Leak:    5.19  .92   .89  2.81  .80 6.1  1.7  3'.4   1.9        0.46  .005  .182  .019  .050             .448
                               Date: ill 1ft    17   17   17    20 21   21  12/1   1      U/  30    30  12/1    11              12
                       Source Number!    076   079  091   013  094 089  094  173   069         004   004  071  046   184   006   079   038
                                                                                                                                                          o
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                                    Figure  11.   Example  Quality Control  Charts for Repeat  Samples

-------
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                                        REFINERY
Figure  12.  Percent  Difference Between Repeat  Samples  by Refinery - Valves

-------
                                LEGEND;  A =  i DBS. n = 2 OBS» ETC,
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                                        REFINERY
Figure 13.  Percent  Difference Between Repeat Samples by Refinery - Pump  Seals

-------
                           LEGENDS A = 1  OBS« B = 2 OBS. ETC.
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                                   REFINERY
Figure 14.  Percent Difference  for  Repeat  Samples by Refinery - Drains

-------
                                   LEGEND:  A  =  i  DBS,  8=2 DBS, ETC,
                                                                   r1
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MEAN UEAKRATE OF SAMPLE  (Ib/hr)
                                                                                          10,00
Figure 15.  Percent Difference for Repeat Samples Versus Mean Leak Rate - Valves

-------
FREQUENCY
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                                         PERCENT DIFFERENCE MIDPOINT
                  Figure 16.  Frequency Bar Chart for Percent Differences Between Samples - Valves

-------
                                           LEGEND: A r  1 OBS, B  s  2  OBS,  ETC.


0.64 +
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                                               MEAN  LEAK RATE  OF SAMPLE
              Figure 17.  Standard Deviation of  Repeat  Samples Versus Mean Leak Rate - Valves

-------
                                                 LEGEND;  A = i OBS« B =  2  oesi  ETC
   160
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MEAN LEAK RATE OF SAMPLE (lbs/hr)
                                                                          10.00
               Figure 18.  Percent Standard Deviation  Between Samples Versus Mean Leak Rate - Valves

-------
 L.  P.  Provost
          Table 5 summarizes the statistical analysis of the repeat QC
                                                             r^
                                                           ESJS
 based on  a  single test of ± 80%.
          This standard deviation of 40% is composed of variation due  to
 analysis, sampling train components, sampling team effect,  and inherent
 variability in the leak rate.   In previous sections, the standard deviation
 for the THC analysis was shown to be about 2.4% and the standard deviation
 for sampling and analysis of standard gases was shown to be about 17%.  No
 significant differences between sampling teams or  sampling  carts were  found,
 therefore a -significant portion of the variability in the leak rate  quality
 control samples is probably due to short term changes in the leak rate from
 a given source.


 VARIANCE  COMPONENT ANALYSIS

          The variability when measuring the leak  rate from a single source
 can be put in proper perspective for this program  by comparing this  observed
 variation from sampling/analysis of a given source with the total variability
 of the leak rate data from all sources.   Statistical analyses of variance
 techniques can be used to separate the total variability of the measured leak
 rate into its various components.

          Table 6 summarizes the estimation of variance components for the
 six baggable source types.   The variation of the logarithm  of the leak rate
 is broken down into four components of variation:

               •   refineries

               •   units within a refinery

               •   individual  sources within a unit

               •   sampling/analysis, short-term leak variations.

The estimation technique assumes all the components are random,  i.e., a
random selection of refineries, of units within a  refinery,  of sources with-
in a unit, and of samples from a particular source.   The degrees of  freedom
in the table is the number  of  independent pieces of data available for
estimating the component of variation.

          As can be seen from  Table 6,  the largest percentage of the varia-
tion in the  log leak rate is due to individual sources,  except for compressor
seals.  The  variation due to differences between refineries is negligible for
all sources  except  relief valves.  The percentage  variation due to the
sampling and analysis procedures ranges  from 3.8%  for relief valves  to 21.4%
for drains.   This component for valves is 5.7%.  Therefore,  the standard
                                   106

-------
                       TABLE 5.
SUMMARY OF BAGGABLE LEAK RATE QUALITY CONTROL SAMPLE
Source Type
Valves
Pump Seals
Compressor Seals
Flanges
Relief Valves
Drains
Overall
Number
Of Sources
With QC
65
62
40
7
16
14
204
Total QC
Samples
137
133
66
12
30
33
411
Average %
Difference1
37.8
44.7
39.5
40.0
18.5
71.1
41.9
Standard
Deviation of
o
Sampling Analysis
36.6
41.9
38.1
39.1
19.5
59.1
40.7
95%
Reproducibility of
Sampling/Analysis 3
101.4%
116.2%
105.6%
108.2%
54.0%
163.7%
112.8%
90% Confidence
Interval about a
Sample Test Result**
± 71.7%
± 82.2%
± 74.4%
± 76.6%
± 38.2%
±115.8%
± 79.8%
1Average % difference - average of pooled percent differences  for  each  source with  QC  sample.

                   Where:  % diff = [original - QC leak]/(average  of  original and QC leak).

2Standard deviation of sampling/analysis - estimated standard  deviation of  the  sampling and
 analyses procedures for non-methane hydrocarbons.  Estimated  from the  pool individual
 percent differences for each QC sample.

395% rcproducibility of sampling/analysis - quantity that  will be  exceeded  only about  5%
 of the time by the difference of two test results on a given  source  under  similar  process
 conditions.  The quantity is equal to 2.77 x standard deviation.

"*90% confidence interval - When taken about a single test  result,  95% of these  intervals
would be expected to include the  "actual" leak rate (without bias considerations)j
 the quantity is equal to 1.96 x standard deviation.

-------
                                                                                                                           r1

                                                                                                                           <-a
                    TABLE  6.    VARIANCE COMPONENT ANALYSIS  -  BAGGABLE SOURCES - LN (Leak  Rate)
O
CO

SOUKCE OF
VARIATION
Refineries
Unit/Refinery
Sonrcea/Unlt
Samp ling-Analysis
TOTAL

SOURCE OF
VARIATION
Refineries
Unit/Refinery
Source/Unit
Sampl 1 ng- Anu 1 y H 1 s
TOTAL

df*
8
43
573
lib
740

df*
12
24
140
76
252
VALVES
var lunce
component
-0.174
o.aai
4.952
0.351
6.184
COMPRESSOR SEALS
variance
component
-0.207
3.907
1.927
0.792
6. 526

percent of
variation
0.0
14.2
80.1
5.7
IOUX

percent of
variation
0.0
5'J.O
2>i.i
11.9
IOOZ

df*
8
43
326
137
514
Rl'.l.
df*
8

-------
L. P. Provost
deviation of 40% shown above is not large when compared to the total
variability of the leak rate in the data base where leak rates span seven
orders of magnitude.  Since the emphasis on this program is on overall
estimates rather than estimates of individual leak rates, the variability of
the sampling and analysis process is certainly acceptable for the program
objectives.


CONCLUSIONS

          (1)  Laboratory standards analysis indicated no overall biases in
the THC analysis.

          (2)  Replicate THC analysis had percent differences less than 7%
most of the time.  The analytical leak rate as developed in this study can
be assumed to be within ± 3.4% of the concentration in the sample bag.

          (3)  After removing the data from one refinery, the standard leaks
collected in the sampling train and analyzed on the THC had an average
recovery of 98.7 ± 4.3% of the induced leak.  The standard deviation of the
recoveries was found to be 17% indicating that a sample estimate would be
within ± 34% of the actual leak rate most of the time.

          (4)  Repeated samples from individual sources were quite variable.
About 16% of the sources sampled in the study were resampled for quality
control purposes.  Overall, a repeat sample could be expected to differ by
as much as 113% of the original leak rate.  The overall standard deviation
between samples was about 41%.  This is higher than the 17% standard devia-
tion for repeated sampling of standards.  The difference is assumed
attributable to inherent short term variations in the actual leak rate.

          (5)  A variance component analysis showed that most of the variation
in leak rates measured in the study can be attributed to differences between
sources.  The sampling/analytical variance accounted for less than 10% for
all sources except compressor seals (12%) and drains (21%).  Differences in
leak rates between refineries were negligible except for relief valves.
                                     109

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L. P. Provost
                                  SECTION  4

                    STATISTICAL PROCEDURES FOR ANALYZING

                               EMISSIONS DATA
          A number of statistical analysis procedures were used in analyzing
the emissions data from this program.  The discussions in the previous
sections have shown that individual hydrocarbon measurements were not very
precise (precision was usually greater than ± 50%) and that variability of
leak rates from different sources spanned several orders of magnitude.  This
extreme variability made the use of properly selected statistical models and
techniques very important in extrapolating the data selected from this
program to the population of fugitive emissions.

          The estimation of emission factors was one important objective of
this program.  Because of the high degree of skewness in the distribution of
nonmethane leak  rates from baggable sources, conventional statistics were
inadequate for efficient estimation of emission factors and their variances.
In addition to the skewness, a large percentage of the sources studied were
considered "nonleaking."  These sources affect the emission factor and
therefore had to be considered in developing estimates for these factors.
Another statistical problem which had to be addressed in developing the
emission factors was the estimation of leak rates for sources which screened
greater than or equal to 200 ppmv but were not sampled for economic reasons.

          The population to which the data from this study can be extra-
polated is the total number of sources from all United States refineries.
For this analysis, it is assumed that a random selection was made for
refineries, units within a refinery, and sources within a specific choice
variable category within a unit.  The "true value," e.g., of an emission
factor, is an abstract concept.  Essentially, this "true value" is that
number which would be obtained if at a given point in time all sources of a
particular type in the population could be sampled, analyzed and averaged.


ESTIMATING EMISSIONS FOR NONSAMPLED SOURCES

          Due to time and equipment constraints, it was not always possible
to sample all sources that screened greater than 200 ppmv.  At the fifth
refinery,  a sampling strategy was developed to reduce the sampling workload.
All sources screening greater than 10,000 ppmv were sampled, but only one-
fourth of the valves and pumps with screening values between 200 and 10,000
ppmv were sampled.  In order not to bias the distribution of leaking sources,
                                     110

-------
L. P. Provost
it was necessary to develop estimated values for all sources screening
greater than 200 ppmv and not sampled.  The number of sources sampled and
estimated for each source type is shown in the following table:
Baggable Source
Type
Valves
Pump Seals
Compressor Seals
Hydrocarbon Service
Hydrogen Service
Flanges
Drains
Relief Valves
Total Sources
Sampled or Screened
> 200 ppmv
627
382

102
69
62
49
58
Sources
Sampled
474
281

83
60
43
28
31
Sources to
Be Estimated
153
101

19
9
19
21
27








          Least-squares regression analyses were done for each device type,
regressing the logarithm of the nonmethane leak rate on the logarithm of
the maximum screening reading.  Both the original screening value and
rescreening values (taken closer to the time of sampling for leak rate)  were
evaluated and a "best" equation was selected for each device as summarized
in Table 7.

          Using the equations in Table 7 , predicted log-nonmethane leak rates
were computed for each source not sampled with a screening value greater than
or equal to 200 ppmv.  Leak rates (Ib/hr) were then computed using

          leak rate = expio[log leak + z (standard error of estimate)],


the number of sources estimated, where  z  is a random number from a standard-
normal distribution.   The use of the random number is an attempt to yield a
predicted distribution of leak rates which would approximate the distribution
if all sources were sampled.  No bias correction factor is needed in con-
verting from the log to linear scale since the mean leak rate is not being
predicted.  The predicted leak rates were used in further analyses and
development of emission factors.

          Because the true leak rate/screening relationship is unknown,  there
is a potential bias introduced when these predicted leak rates are used in
developing emission factors.  The potential bias is proportional to the
                                     111

-------
                     TABLE  7.     PREDICTION EQUATIONS FOR NONMET11ANE LEAK RATES
                                  BASED ON MAXIMUM TLV SCREENING OR RESCKEENING VALUES

SOURCE TYPE
Valves
Pump Seals
Compressor Seals:
Hydrocarbon Service
Hydrogen Service
Flanges
Drains
Relief Valves






LEAST - SQUARES EQUATION
LOG(NMLK)=
LOG(NMLK)-
LOC(NMLK)=
LOG(NMLK)=
LOG(NMLK)=
LOG(NMLK)=
LOG(NMLK)=
—5
-4
-4
-3
-5
—5
-4
.41
.64
.77
.66
.11
.02
.47
+ 0.
+ 0.
+ 0.
+ 0.
+ 0.
-f 1.
+ 0.
88
89
92
44
84
16
87
LOG(HXTLV-RS)
LOG(MXTLV-RS)
LOG(MXTLV-RS)
LOG(MXTLV- S)
LOG(MXTLV- S)
LOG(MXTLV- S)
LOG(MXTLV-RS)
NUMBER
CORRELATION
OF DATA ^COEFFICIENT
PAIRS (r)
177
171
48
44
47
60
53
0.
Q.
0.
0.
0.
0.
78
68
58
36
74
72
0.78
	 	 — ' 	
STANDARD g
ERROR OF <
ESTIMATE »
0.
0.
0.
0.
0.
0.
0.
736
820
791
884
535
807
,637
NMLK - Nonmethane  leak rate (Ib/hr)
MXTLV- S - Maximum value  -  original  screening (ppmv)
MXTLV-RS - Maximum value  -  rescreening (ppmv)
LOG - Logarithm, base  10

-------
 L. P. Provost
standard error of the estimates adjusted for number of data pairs used to
develop the equation and the impact of the bias on emission factors depends
on the percent of sources leaking.  The potential bias for each source type
estimated was approximated and found to be less than 6% for all source types
except compressors (14% potential bias for compressors in hydrocarbon service)
The potential biases were taken into consideration in developing confidence
intervals for emission factors.
 STATISTICAL DISTRIBUTION MODELS FOR LEAK RATES

          A lognormal distribution was used to model the distribution of
leaking sources.   This distribution has the property that when the original
data are transformed by taking natural logarithms, the transformed data will
follow a normal distribution.  The lognormal distribution is often appropriate
when the standard error of an individual value is proportional to the magni-
tude of the value.  The form of the lognormal distribution is as follows:
               f(x)  =


0
. [Un x -
' "L 2a2
xa ^ 2ir

u)2l
J


                                                  for  0 > x > °°
                                                  for x < 0
               Mean = exp y + -r-
               Variance = exp[2y + 2a2 ]  - exp[2y + a2]
          In order to develop estimates for emission factors, the nonleaking
sources (leak rate assumed equal to zero)  also had to be modeled.  A mixed
distribution,  specifically a lognormal distribution with a discrete proba-
bility mass  at zero,  was  used for this purpose.   Letting  p  equal the
fraction of  nonleaking sources in the population, this mixed-lognormal dis-
tribution has  the following form:
                        (1 - p)  exp -
                                         x - l-Q'
               f(x)  =
                        P

                        0
for  0 < x <



for x = 0

for x < 0
                                    113

-------
L. P. Provost
               Mean = (1 - p)  expl ]l + -y-
               Variance = (1 - p) [exp(2u + a2)] [exp(a2) -  (1 - p) ]
Efficient estimates of the mean and variance of the population model by this
mixed distribution have been developed [Finney (1941), Aitchison  (1955)].
These estimates are as follows:

          The best, unbiased estimator of the population mean emission rate
is
                           t(x)] g
          m =
and the best, unbiased estimator of the population variance of the emission
rates is

              /    r\    , -  [ ,  2^    L     r  \  /n-r-2  2\~|
          v = (l - -) exp(2x)  ^g(2s2)  - (l - ^y) ^^^^ * jj

where

          n = number of sources screened

          r = number of sources screened < 200 ppm or with measured
              leak < 10~5 Ibs/hr

          m = n - r = number of "leaking" sources

          g(t) = infinite series


               = ! + (m-l)t +  (m-l)3t2  +     (m-1)5 t3
                        rn      tn9! ^m-l-1^    m
                        m      mz2! (m+1)   m33!(m+l) (m+3)  '  '  '

          x = average of the logarithm of leaking sources

              n-r
            = / J tv\. (nonmethane leaks)/(n-r)
               1
          s2 = variance of the logarithm of leaking sources
               n-r

             = / * [-in (nonmethane leaks) - x]2/(n-r-l).
                1
                                     114

-------
L. P. Provost
          The mean and variance formulas hold whenever there is more than
one leaking source (n - r > 1).  When only one leaking source is identified,
the following estimates are appropriate:


                 x                 x2
          mean = —- and variance = —   ,
                  n                  n


where  x  is the single measured leak.  If no leaks are found (r = n),  then
the best estimate for both the mean and variance is zero.

          This estimator for the mean was used for all emission factors
developed in this program.  Finney  (1941) showed that this estimator of the
mean is more than twice as efficient as the arithmetic average for data
distributed similarly to the leak rates from baggable sources.

          Since data distributed lognormally can be transformed to a normal
distribution by taking natural logarithms of the data, the distribution
assumption for the leaking sources can be tested by examining distributions
of the log leak rates.  Histograms displaying these distributions  were con-
structed for all important source type and process stream classifications.
The data for most sources appeared to adequately approximate a normal  dis-
tribution.  Figure 19 shows the leak rate histogram for valves in  light
liquid and two-phase streams.  The compressor seal data from hydrocarbon
service and the heavy stream data for pump seals both appeared skewed to the
left.  Compressor seals with sampled leak rates less than 10~3 were con-
sidered as negligible (zero) to minimize this skewness.

          To statistically test the assumption of a normal distribution for
the log-leak rates,  skewness and kurtosis statistics were computed for each
data group and tested for departures from their expected values of zero in
a normal distribution.  Table  8 summarizes these statistics.   Only three of
the twelve cases indicate significant lack of normality, confirming the
conclusions from the histograms.

          The other assumption made in using the mixed-lognormal model was
that the sources with screening values less than 200 ppmv (calibrated to
hexane) had insignificant leak rates which could be assumed equal  to zero.
A number of sources with TLV's less than 200 were sampled during the program
in order to evaluate this assumption.  Table  9  summarizes the leak rate data
for these sources.  A "worst-case" impact of this zero-emission assumption on
emission factor estimates can be evaluated by comparing the median value
times the percent of sources screening < 200 ppmv that were used in computing
the emission factor.  Table 10 summarizes this comparison.

          Only for flanges does the zero assumption appear to have a poten-
tial impact on the emission factor estimate.  For flanges, the median leak
rate for the 5 sources screening < 200 ppmv was approximately equal to the
emission factor.  Setting all sources that were considered zero to 0.00054
Ibs/hr would almost double the emission factor.  This potential bias was
                                    115

-------
       FREQUENCY

-------
 L. P. Provost
     TABLE  8.       SKEWNESS  AND KURTOSIS STATISTICS
Source  Type/                     Number of
Stream  Group                   Leaking Sources      Skewness     Kurtosis

Valves
 Gas/Vapor Streams                   154             0.19        -0.33
 Light  Liquids/Two-Phase             330            -0.16        -0.18
 Heavy  Liquids                        32             0.28        -0.88
 Hydrogen  Streams                     59            -0.18        -1.09*
 Open-ended Valves                    30            -0.01        -0.98

 Puinp Seals
 Light Liquids                      296             0.03        -0.36
 Heavy Liquids                       66            -0.77*        0.06

 Compressor Seals
 Hydrocarbon Service                102            -0-99*        1.16*
 Hydrocarbon Service                 69            -0.29         0.69

 Flanges               .               62             0.39         0,20

 Drains                               49            -0.04        -0.47

 Relief Valves                        57            -0.05        -0.21

 *  probability  <.05 given a normal distribution.
                                    117

-------
                  TABLE  9,,
     LEAK RATES FOR SOURCES SCREENING LESS THAN 200 PPM.
Source
Type
Compressor Seals
Drains
Flanges
Pump Seals
Relief Valves
Valves
// Sampled
<200ppmv
3
5
5
12
8
30
MAX TLV (ppmv)
Minimum
0
0
0
8
40
0
Maximum
140
120
110
180
180
190
Leak Rates (Ib/hr) %
Minimum
0
0
0
0
0
0
.00086
.00056
.00007
.00006
.00037
.00001
Median Maximum
0
0
0
0
0
0
.00416
.00197
.00056
.00137
.00132
.00042
0
0
0
0
0
0
.1058
.1078
.0047
.0052
.0765
:..0383
of Total Sources o
Screened <200 o
23
81
96
51
60
67
.•5
.8
.9
.5
.8
.2
00
             TABLE 10.
IMPACT OF "ZERO LEAK RATE" ASSUMPTION ON EMISSION FACTOR


Source
Compressor Seals
Drains
Flanges
Pump Seals
Relief Valves
Valves

Approximate Emission
Factor Estimate (Ib/hr)
0.8
0.07
0.00058
0.17
0.19
0.023
Median Leak Rate Times
Percent of Sources
< 200 (Ib/hr)
0.00098
0.00161
0.00054
0.00071
0.00080
0.00029
Median Times % of Sources
<200 Expressed as Percent
of Emission Factor
0.1
2.3
92.8
0.4
0.4
1.2

-------
L. P. Provost
accounted for in developing confidence intervals for the emission factor
estimate for flanges.


CONFIDENCE INTERVALS FOR PERCENT SOURCES LEAKING AND FOR
EMISSION FACTORS

          Confidence intervals for the percent of leaking sources were com-
puted using the Binomial Distribution.  The Binomial is used to model data
when a random sample is selected and each item is classified into one of two
categories (leaking or nonleaking here).  Exact confidence limits (level
1 - a) for the estimate of percent leaking can be obtained by iteration
solving for  P£  in
           n
                  P. (1 - PO)    = —  for the lower limit and for  P   in
                   X/       A/       2.                                \i
          i=k
                  P  (1 - P )    = —   for the upper limit
          1=0
where

          n = number of sources screened

          k = number of leaking sources


Tables of these solutions, available for most cases, were used to develop
95% confidence intervals for reporting and for computing 97.5% confidence
intervals which were used in developing confidence intervals for emission
factors.  97.5% was selected so that 95% confidence intervals for emission
factors would result when the estimated percent leaking was combined with
the estimated mean leak rate (0-975 x 0.975 - 0.95).

          Patterson (1966) described how confidence intervals for the mean
from a lognormal distribution can be computed using estimators developed by
Finney (1941).  97.5% confidence intervals were computed for the average,
Y,  of the transformed data,  y = -In (leak) , using
          C£ = lower limit = y - 2.24  [s2/(n-r)]

and
                                                 1/2
                                     119

-------
L. P. Provost
          C  = upper limit = y + 2.24 [s2/(n - r)]z/2
           u

where

          s2 = the variance of the transformed data

          n-r = the number of leaking sources.

Then, following Patterson's arguments, confidence intervals for the mean leak
rate can be computed using:

          C" = lower limit = exp [C^] g(s2/2)

and

          C' = upper limit = exp[C ] g(s2/2)

where

          g(t) = the series given above

          To obtain 95% confidence limits for the emission factors, the
confidence limits for the percent leaking and for the mean leak rate were
combined as follows:

          lower 95% limit for emission factor = Pp C^O

          upper 95% limit for emission factor = P  (CO
                                                 u   u

These confidence intervals are conservative in the sense that 95% is a lower
bound for the confidence coefficient for the intervals.  The confidence
intervals should be interpreted as follows:

               When we state that the true emission factor falls
          within the limits computed as described above, we expect
          to be correct at least 95% of the time.

          These confidence intervals consider random sampling variation and
random test error, with no adjustments for potential bias in the sampling
and analytical methods.  The potential sources for bias have been discussed
in previous sections.

          (1)   recoveries from sampling

          (2)   analytical inaccuracies

          (3)   biases in estimating leak rates from nonsampled sources
                                    120

-------
L. P. Provost
          (4)  bias  in  assuming sources screening < 200 could be
              considered as  zero leak rates.

Each of  these  potential biases  was evaluated during the quality assurance
activities as  previously discussed.

          The  potential systematic errors were considered independent so the
net effect of  combining all types of systematic errors was used in adjusting
the emission factors and confidence limits,   The following table summarizes
these net  systematic adjustments made to emission factors and confidence
intervals:
                                Total Systematic Adjustments  (%)
   Source  Type      ———	
                   Lower Confidence     Upper Confidence     Emission Factor
                         Limit                Limit              Estimate

Valves                   -0.6              +  2.7               +1.8

Pump Seals               -0.9              +  4.7               +2.0

Flanges                  +  0.4              + 93.6               +0.7

Compressor Seals:
Hydrocarbon
Hydrogen
Relief Valves
Drains
- 13.8
- 2.9
- 4.6
- 2.1
+ 12.1
+ 1.9
+ 6.5
+ 5.6
+ 0-3
+ 0.3
+ 1.4
+ 2.1
DEVELOPMENT OF NOMOGRAPHS
          Nomographs  were developed as part of the statistical analyses for
this project  to  predict  the mean leak rate from screening values.   An example
of these nomographs  is given in Figure 20.  A statistical analysis of
covariance was done  to determine if different equations were required for the
various source types  and stream groupings.  Although the equations were
developed on  a logarithmic scale,  the nomographs are shown on an arithmetic
scale for ease in reading and interpolation.  Predicting the arithmetic mean
leak rate for a  given screening value is similar to predicting the mean from
a lognormal distribution as previously discussed.   The mean value for a given
screening value  on the nomograph was computed as follows:
         mean  =  exp10[B0 + B1  log! o (screening) ]  g(SE

                     "R                   H
               =  (10)  ° (screening value) 1 (scale bias correction factor)
                                     121

-------
L.  P.  Provost
         0.07
      - 0.06
      at
      **
      •a
      S 0.05
      o
      -a
      a
      o 0.04
      5 0.03
      a>
      2 0.02
      •5
      «
      i.
      a.
        0.01
                  Logi. (NM Leak Rate) * -4.9 + 0.80 Logi, (Max Screening Value)
                  Correlation Coefficient - 0.79
                  Nuri>er of Data Pairs • 119
                  Standard Error of Estimate = 0.60 Logu (NM Leak Rate)
                  Scale Bias Correction Factor =2.53
                          Upper Limit of 90* Confidence
                          Interval for Mean
                                                          Mean
                          Lower Limit of 90S Confidence
                          Interval for Mean
               1,000
5,000
10,000
                 Maximum Screening Value (ppmv as Hexane)
              Using J.W. Bacharach TLV Sniffer at the Source.
        Figure 20.   Nomograph For  Predicting Total Nonmethane Hydrocarbon
                      Leak Rates from Maximum Screening Values - Valves,
                      Light Liquid/Two-Phase  Streams  (Part  I:   Screening
                      Values from 0-10,000 ppm)
                                            122

-------
L. P. Provost
where

          BO   = log regression intercept

          Bx   = log regression slope

          SEp  = standard error of estimate  in natural log scale

          g(t) = series previously described


Ninety percent confidence intervals for the predicted mean leak rate for a
given screening value were  computed in  a  similar  manner  to the  confidence
intervals for the mean  leak rate  as previously described.

CONCLUSIONS

          (1)  The leak rate measurements for baggable sources obtained in
this program required special statistical analysis procedures because the
high degree of skewness in  the leak rate,

          (2)  Procedures were developed to predict leak rates for non-
sampled sources.  Potential biases in using these estimates were evaluated.

          (3)  A mixed lognormal  distribution with a discrete probability
mass at zero was used to model the leak rate data.  The model was shown to
adequately fit the data in  most cases.  Emission factor estimates based on
this model are known to give much more efficient estimates than arithmetic
averages.

          (4)  Confidence intervals were developed for estimates of percent
leaking and for emission factor estimates.  These confidence intervals
account for random variations and potential biases from the sampling,
analysis, and estimation procedures.

          (5)  Nomographs were developed to give unbiased estimates of the
expected leak rate for a selected screening value.
                                     123

-------
 L.  P.  Provost
                                REFERENCES
1.  Aitchison,  J.,  "On the Distribution  of  a  Positive  Random Variable Having
    a Discrete  Probability Mass  at  the Origin," American Statistical Associ-
    ation Journal,  50,  (9),  1955, 901-908.

2.  Finney,  D.  J.,  "On the Distribution  of  a  Variate Whose  Logarithm is
    Normally Distributed," Journal  of the Royal Statistical Society, Series
    B, 7 (1941),  155-161.

3.  Patterson,  R. L.,  "Difficulties Involved  in the Estimation of a Popula-
    tion Mean Using Transformed  Sample Data:  Technometrics 8,  No.  3 (1966),
    535-537.

4.  Radian Corporation,  "Quality Assurance  and Statistical  Analysis of
    Emissions Data-Draft Appendix C," The Assessment of  Environmental
    Emissions from  Oil  Refining, July 1979.

5.  Wetherold,  R. G.,  and Provost,  L. P.,   Emission Factors and Frequency  of
    Leak Occurrence for Fittings in Refinery  Process Units,   EPA Report No.
    EPA 600/2-79-044 IERL RTP, NC,  February,  1979-
                                    124

-------
Kenneth Baker
                                  REVIEW

                                    by

                               Kenneth Baker
                         Greene & Associates,  Inc.
                               Dallas, Texas


                                    on


                   QUALITY ASSURANCE  AND DEVELOPMENT OF
                            STATISTICAL MODELS
                                  RESUME


         Kenneth Baker is a consultant for Greene & Associates, Inc., a
firm of registered professional consulting engineers dedicated to serving
all sectors of the energy and chemical industries.  Mr. Baker received his
B.S. and M.S. degrees in Chemical Engineering from Texas Technological
College in Lubbock, Texas.  Prior to joining Greene & Associates, Inc. in
1975 he spent three years with the U.S. Environmental Protection Agency
and seven years with Celanese Chemical Company.  While with the EPA he
worked as a project officer on research and development efforts dealing
with petroleum refineries and petrochemical processes.  With Celanese he
worked on feasibility studies, process developments at pilot and semi-
works scale and commercial units.  Mr. Baker now provides expertise in
feasibility studies and economic evaluations, project management, and
investigations, expert testimony and representation of petroleum refining,
natural gas processing and chemical industries.  He has worked "for major
and independent oil companies, gas processing companies, banks, Government
regulatory agencies, petrochemical companies and various law firms.  He is
a member of the American Institute of Chemical Engineers, the American
Association of Cost Engineers and the American Society for Testing and
Materials.
                                    125

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Kenneth Baker
                                  REVIEW

                                    by

                              Kenneth Baker
                        Greene & Associates,  Inc,
                              Dallas, Texas

                                    on
                   QUALITY ASSURANCE AND DEVELOPMENT OF
                            STATISTICAL MODELS
         In 1883, Lord Kelvin wrote "When you can measure what you are
speaking about and express it in numbers you know something about it. . .
When you cannot express it in numbers, your knowledge is of meagre and
unsatisfactory kind:  you have scarcely advanced to the stage of science."

         Lord Kelvin's quotation certainly applies when one is concerned
with quality assurance and quality control.  For knowledge of the refinery
fugitive emissions to be satisfactory we must speak and express it in
numbers.  Mr. Provost in his paper has presented the procedures used in
three major areas of Radian's quality assurance program.  It is obvious
that quality assurance and quality control has been a major concern for
this sampling project from the very first.  It has involved a commitment
by all of the people, all of the time who have been associated with this
project.  Quality control and quality assurance cannot be a one-man or
step-child type of effort for a testing program of this magnitude.

         Knowledge of how the testing results are to be used and the
accuracy required must be understood.  Then, plans must be made to get
sufficient test data to meet the requirements to assure that the end
results are useful.  But it must be emphasized that quality control does
not stop there.  It continues throughout the project—data acquisition,
testing results, analysis and reporting.  A breakdown at any point will
reduce the credibility of the results.

         I would like to now quote a man with a vastly different background
than Lord Kelvin.  Stanley Marcus in his book Quest for the Best says:  "I
learned to differentiate not between good and bad but between better  and
best, and to pursue the best, regardless of cost or effort.  The difference
in cost to achieve the best may be negligible but overcoming the inertia  of
                                     126

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Kenneth Baker
the status quo and the willingness  of  most  people to  settle  for  less  than
perfection always takes greater  effort."  Because the rates  measured  by
these tests will probably be used for  years in evaluating  existing  and
potential new refineries, the best  must be  pursued.   Industry, EPA  and
Radian must practice what Mr. Marcus learned.

         A quality assurance program should test  for  the properties of a
good experiment.  It should test for:

         1.  systematic error
         2.  precision
         3.  range of validity
         4.  simplicity
         5.  calculation of the  uncertainties

         The testing should be free from  systematic error.   Although  this
statement seems totally obvious  and compelling, it is  sometimes  flagrantly
violated, knowingly or not.  As  an  example,  suppose that tests were made to
compare the emission rates resulting from two  valves.  Although  the test
equipment may be quite sophisticated,  there are only  two valves  to be tested.
Through Valve A is flowing propane  and through a  second valve flows butane.
Regardless of laboratory techniques and precisions of  measurement,  the com-
parison of emission rates in the valves is  handicapped by  the systematic
error incorporated in the comparison of the valves for the comparison is
also a comparison of the materials  flowing  through them.  Needless  to say,
such systematic errors should be avoided  if  possible.  The primary  technique
which is used to eliminate systematic  errors is that  of randomization.
Radian has tried to do this at each of the  refineries  and  for the types of
sources sampled.

         Secondly, the need for  precision may  be  clearly perceived; however,
it is not so obvious how it is to be achieved.  The variance in  precision of
many tests and their differences is dependent  on  the  inherent variability of
the source being tested and the  number of tests and the design or sequence
of the testing.  While the tester can  do  nothing  about the first factor, he
can exercise considerable control to achieve the  needed precision through the
second and third factors.

         The third property of a good  experiment  is the range of validity.
The basic idea of the testing should encompass a  sufficiently wide  range of
values, so that reasonable inferences  about the emission rates from refiner-
ies may be drawn from the testing.  With  the emission rates  measured  in
different refineries ranging over several orders  of magnitude, an adequate
range of validity has been covered.

         It should be noted that in incorporating a wide range of emission
rates into the testing tends to  decrease  the precision of  the testing.
                                     127

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Kenneth Baker
         The fourth requirement of a good test is that it is simple.  It
does not mean that it is naive or stupid.  On the other hand, it behooves
one to keep the test as simple and as uncomplicated as possible so as to
minimize the potential points for variation.

         Finally,  the testing program should  be planned so that the uncer-
tainties of the results can be calculated.   Back to what Lord Kelvin said...
"express it in numbers...".  As noted above,  precision depends on the
variability of the test.  This variability can be classified into two areas:

         1.  the random or chance portion,  which is uncontrollable and
             is the sum of all the causes of  chance that are involved,
             and

         2.  the assignable causes, that is,  the differences between
             testing equipment, the differences between workers, the
             differences among the sources being tested, and the
             differences in these above three factors over a period of
             time.

         Differences in the above relationships one to another will also
change the quality of the testing results.  As described in Mr. Provost's
paper, Radian has considered each of these areas.

         In the first part of his paper on the quality control of hydro-
carbons screening devices, Mr. Provost evaluated the Bacharach "TLV Sniffer"
and the Century Model OVA-108 used for screening the refinery sources that
would ultimately be tested.  It was important that these screening instru-
ments be properly calibrated, their results be reproducible and that a
correlation be developed between screening value and the emission leak rate,
because it is not practical to sample all possible sources in each or any
refinery.  However, a sufficient number of sources could be screened.  The
existence of a good correlation between maximum screening value and the
measured emission rate is a very important result.  Without such a correla-
tion many more detailed samples would have been required.

         In the section on quality control for hydrocarbon measurements
from baggable sources, Radian covered the five points of a good test.  They
reviewed the analytical instrument, the total hydrocarbon analysis instru-
ment used; they measured the variation due to different operating teams;
the differences in sources sampled:  valves,  flanges, pumps, etc.  Addition-
ally, they considered the variation and interrelationship of these variables
over time.

         It is reported that a repeat sample  could be expected to differ by
as much as 113 percent of the original leak rate and the overall standard
deviation between samples was 41 percent.  While these numbers may initially
appear high when considered relative to the total amounts being emitted from
a single source and the inherent short-term variation in the leak rate, the
differences do not negate the usefulness of the results.
                                     128

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Kenneth  Baker
         In the last part of Mr.  Provost's paper the statistical procedures
were discussed.   As  noted for the first part of his paper, the correlation
between screening values and leak rates was an important development.  The
use of these correlations and other estimates to predict leak rates created
the potential for biases.  The potential biases in using the correlations
and estimates to predict leak rates was a point of concern.  Statistics have
been used to determine confidence intervals for the estimates.

         Nomographs  of the type presented in Mr. Provost's paper and those
for the other equipment types studied will certainly be used for years to
come.

         I have been favorably impressed with the results of this project.
However, when one uses the generalizing words such as some, several, good,
bad, etc. because they "read or sound" better, we do not demonstrate satis-
factory knowledge of our subject.  However, each of us can understand
exactly the difference in numbers.

         I would like to suggest that as often as possible we practice what
Lord Kelvin and Mr.  Marcus said "...express it in numbers . . . and . . .
differentiate . . .  and pursue the best."  These are things we must strive
for in quality control efforts.

         Thank you.
                                     129

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 Lloyd  P.  Provost
                           QUESTIONS AND ANSWERS


 Q^_ James  Stone/Louisiana Air  Control  Commission - I have two questions.
 One,  when  you measure  relief valves  and drains,  what were they actually
 measuring?  And,  the other one is,  did you concentrate the refineries in
 one part of the country  or did you  grab them from all over the place?

 A.  (By Rosebrook)  - The  data came from three refineries in California, one
 in the State of Washington, one in  Texas,  one in Oklahoma, one in Louisiana,
 one in Illinois,  one in  Indiana,  one in Pennsylvania, one in Delaware, one
 in Kansas, and one in  New Jersey.   Relief  valves were bagged just as valves
 and pumps  were.  We put  a tent around  them,  pulled the sample and took that
 to the lab and measured  the hydrocarbon.

 Q.   James  Stone/Louisiana Air  Control  Commission - Were you only measuring
 the ones that were not hooked  up  to  a  flare-header?

 A.   (By Rosebrook) - Yes!

 Q.   James  Stone/Louisiana Air  Control  Commission - On drains, were you just
-dropping a probe down  in the drain  and measuring?

 A.  (By Rosebrook)  - No,  in drains, when we screened them, we screened around
 the lip of the drain.  When we measured them and this is reflected in the
 problems with that data,  we bagged  them, pulled  a slow air flow across the
 top of the drain,  and  tried not to  induce  flow back from the drain up into
 the bags through our air movement.   Obviously, we believe that we were not
 able to achieve that as  well as we  achieved a lot of other things.

 Q.   S. M.  D'Orsie/Exxon  Company-USA -  In the next paper there is a table
 that I think provides  some summary  statistics, and you present a 95 percent
 confidence interval around emission factors.  I  just want to make sure that
 I understand how this  ties with the work that you just presented.  And what
 I am thinking is that, all your exercises  here,  in terms of determining the
 statistical reliability  of the data were used to determine these final
 confidence intervals.  Is that a  correct statement?

 A.  - The rest of the speakers  will  be  reporting  a lot of different emission
 factors and hopefully, almost  all the  time,  they will have a confidence
 interval associated with that. A confidence interval is what we feel is
 good measurement of how  well we have estimated the emission factor.  We
 called it  95 percent because we felt that  it was approximately in that area,
 and it does consider random variations as  well as the corrections we made
                                    130

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Lloyd P. Provost
for potential sources of bias.   So,  in  answer  to  your  question,  yes  the
methodology I just went through, was used  to produce both  the  emission
factors and the confidence intervals you'll see in the rest  of the papers.

Q.  S. M. D'Orsie/Exxon Company-USA  - So,  in your data handling  then, when
we talk about the goodness of  the  data, what conceptualizing in  terms of
confidence intervals, rather than  more  simplistic definitions  such as
plus or minus 100 percent, has been  done.

A_._ - Two different things, I think.   We talked about the goodness of the
data, individual measurements  of pounds per hour  baggings, and actual
hydrocarbon measurements.  I used  simple statistics, plus  or minus, for
individual readings, and in one  case, an average  of two readings.

         For emission factors, it  is a very complicated statistic, and it
required a little more complicated expression, but the interpretation is
the same thing, just like an individual piece  of  data  might  be plus or
minus 70 percent, the confidence intervals presented,  represent  plus or
minus how good that emission factor  is  estimated.   Just as 70  percent tells
how well an individual piece of  data is estimated.

Q.  Thomas C. Ponder, Jr./PEDCo  Environmental, Inc. -  I noticed  in the
earlier presentation you showed your screening tool, how did you maintain
the 5 cm probe distance?  I didn't see  any kind of device  on it.

A.  (By Rosebrook) - Since there is  no  device  attached to  it,  normally, and
since that was a study done to accommodate some results requested by another
part of EPA, we merely attach  a wire or guide  to  set it at the desired
distance.  I'd like to point out that we have  also done this in  the State
of California where their requirement is 1 cm.  We then attached a small
Teflon pointer, or whatever you  care to call it,  so that you maintain the
1 cm distance.

Q.  Thomas C. Ponder, Jr./PEDCo  Environmental, Inc. -  Were you changing back
and forth when you were doing both measurements at the same  time?  Where
you do the probe on the source and then you take  it back and put the 5 cm
thing on it and do it right then or  how were you  flipping back and forth?
We have trouble doing that.

A.  (By Rosebrook) - Yes!

Q.  Thomas C. Ponder, Jr./PEDCo  Environmental, Inc. -  The  other  question we
have is from our OSHA people.  They  say 1  cm is the same as  on the source
because you don't plug the probe.  You just mentioned  that California says
that 1 cm is on the source.  What  is right in  this business?

A.  (By Rosebrook) - I have a  comment and  then Mr. Morgester has a comment.
Why don't you speak first Jim?
                                    131

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Lloyd P. Provost
COMMENT/James J. Morgester/California Air Resources Board - Let me just  give
you a little background on where the 1 cm came from.  There wasn't anything
magical about it.  The original regulation required measurement right  on
the source and 1 cm was simply picked because when you use the FID,  if you
put it right on the source, it puts the flame out.  A gentleman here says
it is put out at 1 cm too.

COMMENT/Rosebrook - It is a problem that we don't have with the TLV  and  it
allowed us, in our estimation, to be more reproducible.  We were not
affected by the weather, to the same extent.

Q.  Thomas C. Ponder, Jr./PEDCo Environmental, Inc. - Which way is EPA
going to pursue, do you know that?

A.  (By Rosebrook) - Which way is EPA going to pursue?  On the source? Yes.

Q.  Thomas C. Ponder, Jr./PEDCo Environmental, Inc. - Can you use the  OVA
then, based on the previous comment?  As the flame goes out the thing
probably doesn't work.

A.  (By Rosebrook) - Well, as the flame goes out you know you've go.t a
leak.  You've got quite a leak.  The flame goes out because basically  you
overwhelm it and you can't support combustion.  It doesn't got out merely
by the act of putting it there.  You've got to find a good size leak.

Q.  Thomas C. Ponder, Jr./PEDCo Environmental, Inc. - What number do you
put down on your sheet?

COMMENT/John Sawyer/ACCUREX Corporation - I had quite a bit of experience
with the OVA, and if the flame does go out it will readily relight when you
pull away from the source.  You also have a 10 to 1 dilution probe which
you can put on, and if it puts it out at 100,000 ppm, then you've got  a
pretty serious leak.

COMMENT/Rosebrook - We have also done some work with double-dilution probes
so that we can measure, theoretically up to a million ppm.

Q.  Thomas C. Ponder, Jr./PEDCo Environmental, Inc. - I would like to  see
it standardized, so that we all do it the same, I guess that is my main
distress.

A.  (By Rosebrook) - I don't have much control over that!

Q.  Paul Harrison/Engineering-Science^ - I think the compromise is if you
want to use English units use 2-1/2 cm, if you want to use cgs then  2  cm.
If you have a pinhole leak and you put the OVA, or any sampler on that leak,
two things happen.  One, is that after awhile you get a 100 percent  of the
leak plus whatever air it can suck in, and two, you have problems of the
grease around the seal.   There are logistical problems, and just field
problems about using at the source.  It is very easy to develop a nomograph
                                    132

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Lloyd  P.  Provost
for any reasonable distance up to 5 cm.  And, as you pointed out there
is about an order of magnitude difference between 1 cm and 5 cm.  The 1 to
2-1/2 cm distance also eliminates most wind effects except under pretty
high wind conditions and turbulent conditions if you simply go for the
highest value,  which of course is typically downwind of the leak.  I don't
really feel there is much difference between 1 cm and 2-1/2 cm except
setting a universal standard.   I would not recommend, and the State of
California originally said at the source, right on the leak, and of course
they had the logistical problems and had to pull back to 1 cm, which is
perfectly alright.  But it really doesn't make that much difference except
in the level that you set for your survey.  Originally we started out at
5 cm and the original guideline documents for EPA was 5 cm, because most
of the data that was available at that time was 5 cm.

COMMENT/Rosebrook - Bruce (Tichenor), do you still have a comment?

COMMENT/Bruce A. Tichenor/US-EPA-IERL-RTP - I am speaking for ORD, not
OAQPS.  I agree with some of the comments that were made.  It really doesn't
make much difference.  There are two factors,  I think.  One is you say "at
the source" and you are at the source, and there is no confusion.  You say
a centimeter and you have the thing tilted one way or another, you have a
problem.  The second is that the data that Lloyd showed does show that the
variability of the individual readings are less at the source then they are
from some distance from the source.  The other thing is that when we talk
about these screening values of 200 or 1,000 or 10,000, again those are not
regulatory requirements at this point, at least not for what I am talking
about.  For the purpose of this program 200 was simply selected as a break-
point to enable us to go and get the data.  I am not answering the question
as to what is best.  From my point, from an R&D standpoint I think "at the
source" is best because I think they have less problems.  Now whether that's
going to translate itself into a regulatory requirement, I don't know-

Q.  R. C. Weber/US-EPA-IERL-Cincinnati - Calvin commented a little bit about
the difficulty with sampling "at the source" since that is the way it was
primarily done in the refinery program; was there a significant problem of
plugging of the probe or whatever?

A.  (By Smith)  - Well, of course not every valve is the cleanest piece of
equipment in the world, so certainly there is a film of oil or grease on
some of the valves.  Part of the equipment that our engineers carried in
the unit when they were screening these sources was a package of pipe
cleaners to clean out the probe, because occasionally you do get material
inside the probe from just simply touching the valve.  After they back
away from the valve, of course the instrument goes back to whatever the
ambient reading is.  Sometimes if you have very heavy hydrocarbon streams,
and use the TLV, that material will coat the inside of the probe and the
detector will take some time to come back to an ambient reading.  When you
get the tip of the probe or the inside of the probe contaminated you can
tell very quickly because the ambient reading will be a lot higher than
what you would expect, and at that point you just simply take a pipe cleaner
and clean it out.


                                   133

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Lloyd P. Provost
Q.  Cynthia M. Harvey/PEDCo Environmental, Inc. - What you have  talked about
is the statistical approach that has been used once you gathered your data.
What I'm interested in is what statistical approach did you use  to get your
sample and are you sure that you have a representative sample of the valves,
flanges, etc.?

A._ - The first speaker went into that briefly, I think it is probably
covered more in detail in Calvin's paper, but if not, there have been a
number of previous presentations.  I know Don Rosebrook has made two or
three and Bob Wetherold has made one at other conferences which  described
the detailed experimental design used on this program.  Just real briefly,
we started off with a factorial approach.  We named what we call choice
variables, -variables that we thought could affect the leak rate, like
temperature, unit, pressure, gas lines, liquid lines, types of equipment,
valves, pumps and so forth and came up with a factorial representation of
those and then picked a number in each cell and from there we handed it to
an engineer.  He picked them on a P&ID at random before he went  out into
the unit.  The intent was to minimize any bias from looking at the unit.
It was a kind of modified fractional/fractorial with extensive quality
control on the back end to document the precision of the measurements.
                                   134

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 F.  G.  Mesich
                RESULTS  OF MEASUREMENT AND CHARACTERIZATION
                        OF ATMOSPHERIC EMISSIONS FROM
                            PETROLEUM REFINERIES


                                     by


                               Frank G.  Mesich
                             Radian Corporation
                              McLean, Virginia


                                  ABSTRACT


          The results of the sampling and analytical efforts in the
measurement of fugitive emissions from point and area sources in petroleum
refineries are summarized.  Nomographs useful in the prediction of emissions
are presented as are the statistically determined emission factors for each
source category.
                                   RESUME

          Dr. Frank G. Mesich is an Assistant Vice President of Radian
Corporation in the Office of Research and Engineering.  He is also General
Manager of Radian's Northern Virginia facility.  His educational background
includes a bachelor's degree in chemistry from the Colorado College and a
Doctorate in Physical Chemistry from Iowa State University.  His industrial
experience includes seven years of process development and improvement with
Celanese Corporation.  With Radian he has directed a wide variety of environ-
mentally related programs and served as Program Manager for the initial
phases of the refinery fugitive emission work.
                                    135

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 F.  G.  Mesich
                 RESULTS  OF MEASUREMENT AND  CHARACTERIZATION

                         OF ATMOSPHERIC EMISSIONS FROM

                            PETROLEUM REFINERIES
          Previous  papers have  generally described  the overall program  con-
 ducted by Radian  Corporation  for  the Environmental  Protection Agency  to
 perform  an  "Assessment  of Environmental Emissions From Oil Refining."   The
 program  required  extensive  sampling of both controlled (stack emissions) and
 uncontrolled  (fugitive)  emissions.  With strong  industry cooperation  sampling
 was  conducted  at  thirteen  (13)  refineries geographically spread across  the
 continental United  States.  This  paper summarizes the results of  the  fugi-
 tive emission  sampling  and  presents the emission factors derived  from a
 statistical analysis  of  the data.  The complete  results will be the subject
 of a final  report to  EPA which  is nearing completion.


 DESCRIPTION OF EMISSION SOURCES

          The  fugitive  emissions  associated with petroleum refining opera-
 tions present  two very  different  sampling problems.  From a sampling  stand-
 point the sources of  emissions  or leaks within the  refinery battery limits
 may  be classed into (1)  those which emit from a  localized area or point
 source,  termed "baggable" sources and  (2) those  which are emitted from  a
 diffuse  area such as  wastewater treatment.  Tankage leaks are the subject
 of many  other  studies and were  not included in this program.

          Baggable  sources, which can be enclosed for accurate sampling,
 included valves of  all  types, flanges, compressor and pump seals, and plant
 drains.  The other, less tractable, sources include cooling towers, oil/
water separators  and  other  components of the wastewater treament  systems.
The  bulk of this  discussion will  center around the  baggable sources where
 the  preponderance of  data exist.


RESULTS OF THE SAMPLING OF  BAGGABLE SOURCES

          As was  discussed  in detail in a previous  paper, two fundamental
measurements of non-methane hydrocarbons were made  for each source:   rapid
screening using a hand held hydrocarbon detector in the immediate vicinity
of a suspected leak and a precise measurement of leak rate by enclosing the
source.

          Based on  the average emission results  of  this program the baggable
sources can be grouped into twelve (12) categories  listed in Table 1.   It
                                     136

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.  G. Mesich
             TABLE  1.   CATEGORIES  OF  BAGGABLE  SOURCES
Category
1
2
3
4
5
6
7
8
9
10
11
12
Source
Description
Valves, Gas /Vapor Streams
Valves, Light Liquid/Two-Phase Streams
Valves, Heavy Liquid Streams
Valves, Predominantly Hydrogen Streams
Open-ended Valves (all streams)
Pump Seals, Light Liquid Streams
Pump Seals, Heavy Liquid Streams
Compressor Seals, Hydrocarbon Service
Compressor Seals, Hydrogen Service
Flanges (all streams)
Drains (all streams)
Relief Valves (venting to atmosphere)
Number of Sources
Screened
563
913
485
135
129
470
292
142
33
2094
257
148
                                    137

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F. G. Mesich
should be noted that several subcategorles are defined based on the service
for which the equipment is used.  Our results show that stream composition,
particularly vapor pressure, has a significant effect on the leak rate or
emission factor.  Table 2 summarizes the emissions factors determined from
the analysis of all of the program data.  Twelve emission factors are given
representing the twelve categories.  Confidence intervals are shown for both
the percentage of leaking sources and for the estimated emission factors.
Thus, the table provides an estimate at the 95 percent confidence level for
predicting both average emissions and occurrence of leaks.

          A "leaking" source in this study was defined as any source with
measured emissions greater than 10" 5 Ibs/hr or any source not sampled with a
screening value greater than 200 ppmv (TLV calibrated to hexane).  Several
important conclusions can be drawn from the data in Table 2.  Stream service
has a large measurable effect on the frequency and size of non-methane hydro-
carbon leaks.  For the valve category, which includes block, gate, and con-
trol valves, the average emission per valve ranges from 0.0005 Ib/hr for
valves in heavy liquid service to 0.059 Ib/hr for those in vapor service.
Pumps show a similar trend.  Relief valves show both the highest occurrence
rate and mass emissions on a per valve basis of any of the valves.  The
highest per source emission is for compressor seals while the lowest is for
flanges.

          The primary use of these data is in the prediction of emission
levels from either existing or contemplated refineries.  It must be remem-
bered that these emission factor estimates are based on data from thirteen
(13) refineries and only form the basis for an estimate of any single
refinery.  The confidence limits describe how well the average emission
factors (on a national level) are estimated.

          Tables 3 and 4 summarize the information collected during sampling
as  a function of the process unit studied for valves and pump seals.  Similar
tables for the  other source types will be available in the final report.  The
data within each process unit are a composite of all data collected for that
unit.  Within these unit processes, the unit emission factors should be used
with caution owing to some deviations from completely random process selec-
tion.  More sources processing vapor materials were sampled than in heavy
liquid service  in order to increase the accuracy of the individual valve
emission factors.  The overall emission factors in Table 1 are not subject
to  the same biases and may be used within the stated confidence limits.

          During the planning and conduct of this program, heavy attention
was given to determining any correlations which exist between leak rates and
process or equipment variables.  These will be addressed in detail in
another of this series of papers.

          As a conclusion to the discussion of emission factors, consider
their application to a hypothetical refinery.  The analyses of the emissions
rate data show that hydrocarbon emissions from valves, pump seals, and com-
pressor seals are functions of the service or process stream properties.  To
                                    138

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OJ
                      TABLE 2.  SUMMARY STATISTICS  AND ESTIMATED VAPOR EMISSION FACTORS

                                FOR NONMETHANE HYDROCARBONS  FROM BAGGABLE SOURCES
Source Type
Valves
Gns Vapor Streams
Light Llquld/Two-Phase
Heavy Liquid
Hydrogen
Open-Ended Valves
Pumps
Light Liquid Streams
Heavy Liquid Streams
Drains
Flanges
Relief Valves
Compressors
Hydrocarbon Service
Hydrogen Service
Number
Screened

563
913
485
135
129

470
292
257
2094
148

142
83
Number
Leaking

154
330
32
59
30

296
66
49
62
58

102
69
Percent
Leaking

27.
36.
6.
43.
23.

63.
22.
19.
3.
39.

71.
83.

4
1
6
7
3

0
6
1
0
2

8
1
95Z Confidence
Interval for
Percent Leaking

(24,
(33.
( 4,
(35.
(16.

(59,
(18.
(14,
( 2.
(31.

(64.
(75.

3J)
39)
9)
52)
3D

67)
27)
24)
4)
47)

79)
91)
F.mlselon
Factor
Estimate
(Ib/lir/sourcc)

0.
0.
0.
0.
0.

0.
0.
0.
0.
0.

1.
0.

059
024
0005
018
005

25
046
070
00056
19

4
11
95Z Confidence
Interval for
Emission Factor
(Ib/hr/source)

(0.
(0.
(0.
(0.
(0.

(0.
(0.
(0.
(0.
(0.

(0.
(0.

030,
017,
0002
007.
0016

16,
019,
023.
0002
070,

66,
05,

0.110)
0.036)
, 0.0015)
0.045)
. 0.016)

0.37)
0.11)
0.20)
, 0.0025)
0.49)

2.9)
0.23)
                                                                                                                      ct>
                                                                                                                      CO
                                                                                                                      H-
                                                                                                                      n

-------
             TABLE 3.   SUMMARY  OF EMISSIONS DATA  BY PROCESS UNIT  - VALVES
Nonraethane Hydrocarbons
Unlf
Code
15
13
22
1
27
17
2,4,8
33
23
32,
34,35
18
5
11
36

Unit
Identification
Atmospheric Distillation
Fuel Gas/Light Ends
Processing
Catalytic Cracking
Catalytic Reforming
Alkylatlon
Vacuum Distillation
Catalytic Hydro treat Ing/
Refining
Aroma tics Extraction
Delayed Coking
Dcwaxlng, Treating
Sulfur Recovery
llydrocracklng
Hydrogen Production
llydrodealkylatlon
Other
Number
Screened
278
460
190
153
227
57
285
45
86
289
10
83
49
36
11
Number
Leaking
62
158
49
86
85
0
69
15
9
44
0
27
9
14
0
951 Confidence
Percent Interval for
Leaking Percent Leaking
22.
34.
25.
56.
37.
0.
24.
33.
10.
15.
0.
32.
18.
38.
0.
3
3
8
2
4
0
2
3
5
2
0
5
4
9
0
(17.
(30,
(20,
(46,
(31,
( o,
(19,
(20,
( 5,
(11.
( o,
(23,
( 9,
(23,
( o,
27)
39)
33)
67)
44)
6)
29)
49)
19)
19)
3D
44)
32)
57)
28)
(intimated
Emission
Factor
(Ib/lir/source)
0
0
0
0
0
.0023
.046
.047
.029
.031
neg
0
0
0
0

0
0
0

.0051
.0053
.0019
.011
A
.057
.0013
.013
A
951 Confidence
Interval for
Emission Factor
(Ib/hr/aource)
(0.001.
(0.026.
(0.015,
(0.015,
(0.015,
(neg, 0
(0.002.
(0.001,
(0.001,
(0.003,

(0.01,
(neg, 0
(0.001,

0.005)
0.084)
0.14)
0.059)
0.065)
.009)
0.012)
0.03)
0.02)
0.04)
A
0.30)
.02)
0.09)
A
* Insufficient data

-------
         TABLE 4.  SUMMARY OF EMISSIONS  DATA BY PROCESS UNIT - PUMP  SEALS
                                                                                                             o
Nonme thane Hydrocarbons
Unit Unit
Coda Identification
35 Atmospheric Distillation
13 Fuel Gas/Light Ends
Processing
22 Catalytic Cracking
1 Catalytic Reforming
27 Alky 1 at Ion
17 Vacuum Distillation
2,4,8 Catalytic llydrotreatlng/
Refining
33 Aroma tics Extraction
23 Delayed Coking
32, Dcw.ixing, Treating
34,35
5 llydrocracklng
11 Hydrogen Production
36 Hydrodealkylatlon
Other
Number
Screened
149
156
77
41
76
25
61
43
37
65
40
7
5
5
Number
Leaking
65
83
31
32
60
3
23
25
10
26
20
0
4
0
Percent
Leaking
43.6
53.2
40.3
78.0
78.9
12.0
37.7
58.1
27.0
40.0
50.0
0.0
80.0
0.0
95Z Confidence
interval for
Percent Leaking
(36,
(45,
(29,
(62,
(68,
( 3,
(26,
(42,
(14,
(26.
(34,
( o,
(28,
( o,
52)
61)
52)
89)
87)
3D
51)
73)
44)
56)
66)
41)
99)
52)
Estimated
Emission
Kactor
(Ib/hr/nourcc)
0.022
0.19
0.081
0.18
1.3
*
0.033
0.20
0.020
0.056
0.053
*
*
*
95Z Confidence
Interval for
Emission Factor
(lb/hr/nonri:e)
(0.001, 0.023)
(0.09, 0.40)
(0.02, 0.29)
(0.06, 0.51)
(0.51, 3.5)
*
(0.01. 0.13)
(0.05, 0.73)
(0.002, 0.15)
(0.02, 0.20)
(0.01, 0.20)
• *
*
*
                                                                                                             n>
                                                                                                             CO
                                                                                                             H-
                                                                                                             o
Innuffic lent diitn

-------
F. G. Mesich
 estimate the total hydrocarbon emissions from a refinery or unit process, the
 populations of the various potential sources must be known.  To aid in these
 calculations, two other tasks were accomplished during this program—counting
 the number of fittings and other sources in a number of selected refinery
 units and making an estimate of the relative number of each source type
 associated with various process stream types.

SOURCE COUNTS

           Individual sources were physically  counted  in several  process units
at  five  refineries.  The sources counted  included  valves, flanges,  pumps,
compressors,  drains, and relief valves  (venting  to atmosphere).  The counts
include  only  those sources in hydrocarbon service.

           The visual source counts were used  as  a  basis for estimating the
total source  populations in some of  the major  types of refinery  process units.
These estimated  source  populations are presented in Table 5.   Sources were
not  counted in some types of process units  including  vaccuum distribution,
aromatics  extraction, delayed coking, hydrodealkylation, and sulfur recovery
units.   The number of sources in these units were  estimated from source
counts obtained  in other types  of units.  The  distribution  of  source counts
by  process stream classification are presented in  detail in the  final report.

FUGITIVE HYDROCARBON EMISSIONS  FROM A HYPOTHETICAL REFINERY

           An  estimate was made  of the total fugitive  hydrocarbon emissions
from six source  types in a hypothetical refinery.  The Texas Gulf Coast
Cluster  Model Refinery, developed by Arthur D. Little, Inc.,2 was used for
this purpose.  The major process units are  shown in Table 6.  These process
units were developed from the block flow  diagram of the ADL Gulf Coast Model
Refinery.  Two atmospheric distillation units, two reformers,  and a hydrogen
plant are  included in the list  of process units.   The capacities of each
unit are also shown in  Table 6.

          An estimate of the total number of  each  source type and their total
hydrocarbon emissions are given in Table  7.  Where applicable, the  number of
sources  and the  total emissions from sources  in  the various stream  services
are also presented.

          It should be  emphasized that this example is intended  only to be
illustrative of  the use of the  emission factor data and serves to show some
of the factors which must be known before making such an estimate.


DISTRIBUTION OF LEAKS

          In addition to the derivation of  emission factors, a number of
              #                                             7
other uses may be made of the data developed during this program.   For
example,  the distribution of leaks within a source category gives insight
                                    142

-------
                        TABLE 5.   ESTIMATED NUMBER OF INDIVIDUAL EMISSION  SOURCES'
                                    SPECIFIC  REFINERY PROCESS UNITS
IN FIFTEEN
                                        K
                                        (D
                                        cn
                                        H-
                                        o
.p-
U)
                                                      Estimated Number of Sources Within Battery Limits of Process
                                                                                 Units
Process Unit
Atmospheric Distillation
Vacuum Distillation'
Fuel Gas/Light Ends Processing
Catalytic Hydroprocessing
Catalytic Cracking
Hydroc racking
Catalytic Reforming
Aromatics Extraction1
Alkylation
Delayed Coking'
Fluid Coking
Hydroealkylation*
Treat ing /Dewaxing
Hydrogen Production
Sulfur Kocovory1
Valves
890
500
180
650
1310
930
690
600
680
300
300
690
600
180
200
Flanges
3540
2000
760
2600
5200
3760
2760
2400
2280
1240
1240
3760
2290
640
800
Pumps3
31
16
3
10
30
22
14
IB1
11
91
9
14 »
18
5
6l
Compressors'1
1
O1
2
3
3
3
3
O1
0
O1
4
31
1
3
O1
Drains
69
35
11
24
65
58
49
41
41
28
28
58
44
17
20
Relief
Valves
6
6
6
6
6
6
6
6
6
6
6
6
6
4
4
                 Sources were not counted in process units of thin  type.  The number of  sources was estimated.
               2  Only those sources in hydrocarbon  (or organic compound) service.
               1  Number of pump seals - 1.4  x number of pumps.
                 Number of compressor seals  " 2.0 x number of compressors.

-------
TABLE 6.   MAJOR PROCESS UNITS IN HYPOTHETICAL REFINERY
                                                                                 (D
ADL - Texas Gulf Cluster Model;  330.000 BPCD
      Refinery Process Unit                                              Capacity,  BPCD

Atmospheric Distillation #1                                                 200,000
Atmospheric Distillation 02                                                 131,000
Vacuum Distillation                                                         134,000
Light Ends/Gas Processing                                                    12,000
HDU:  Reformer Feed                                                          57,000
HDU:  Light Gas Oil                                                          11,000
HDU:  Heavy Gas Oil                                                          15,000
HDU:  Light Cycle Oil                                                        15,000
HDU:  Vacuum Gas Oil                                                         17,000
HDU:  Coker Naphtha                                                           3,000
Hydrocracker                                                                 15,000
FCCU                                                                         93,000
Catalytic  Reformer: //I                                                       41,000
Catalytic  Reformer: //2                                                       30,000
Aromatics  Extraction                                                         16,000
Alkylation                                                                  18»°°°
Coker                                                                        17>°°°
Hydrogen Plant
                                                                                 H-
                                                                                 n

-------
                                        TABLE 7.   HYPOTHETICAL  REFINERY:   HYDROCARBON  EMISSIONS1
I—

Number of Valves in Units
Process Unit
Atmospheric Distillation: No.
Atmospheric Distillation: No.
Vacuum Distillation
Light Ends/Gas Processing
HDS: Reformer Feed
HDS: Light Gas Oil
HDS: Heavy Gas Oil
HDS: Light Cycle Oil
HDS: Vacuum Gas Oil
HDS: Coker Naphtha
FCCU
Hydrocracking
Catalytic Reformer No. 1
Catalytic Reformer No. 2
Aromatics Extraction
Alkylation
Coking
Hydrogen Production

Gas
Service
1 90
2 90
50
90
340*
340*
340*
340*
340*
340*
380
250*
260*
260*
60
230
30
80*
3,910
Lt. Liq.
Service
280
280
50
80
210
210
210
210
210
210
410
380
390
390
500
340
60
80
4,500
Hvy. Liq.
Service
520
520
400
20
100
100
100
100
100
100
510
310
40
40
40
0
220
20
3,240
Total
890
890
500
190
650
650
650
650
650
650
1,300
940
690
690
600
570
310
180
11,650
Valve Emissions, Ib/hr
Gas
Service
5.31
5.31
2.95
5.31
15.88
15.88
15.88
15.88
15.88
15.88
22.42
11.68
12.14
12.14
3.54
13.57
1.77
3.74
195.16
Lt. Liq.
Service
6.72
6.72
1.20
1.92
5.04
5.04
5.04
5.04
5.04
5.04
9.84
9.12
9.36
9.36
12.00
8.16
1.44
1.92
108.00
Hvy. Liq.
Service
0.26
0.26
0.20
0.01
0.05
0.05
0.05
0.05
0.05
0.05
0.26
0.16
0.02
0.02
0.02
0.00
0.11
0.01
1.63
Total
12.29
12.29
4.35
7.24
20.97
20.97
20.97
20.97
20.97
20.97
32.52
20.96
21.52
21.52
15.56
21.73
3.32
5.67
304 . 79
Relief Valves
Total
R.V.
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
4
106
Emissions ,
Ib/hr
1.14
1.14
1.14
1.14
1.14
1.14
1.14
1.14
1.14
1.14
1.14-
1.14
1.14
1.14
1.14
1.14
l.]4
0.76
20.14
Flanges
Total
Flanges
3,560
3,560
2,000
760
2,600
2,600
2,600
2,600
2,600
2,600
5,200
3,760
2,760
2,760
2,400
2,280
1,240
640
46,520
Emissions,
Ib/hr
1.99
1.99
1.12
0.43
1.46
1.46
1.46
1.46
1.46
1.46
2.91
2.11
1.55
1.55
1.34
1.28
0.69
0.36
26.08

O


g
fD
en
H-
O
              Thirty percent of these valves are assumed to be in service in streams containing more than 50% hydrogen.

-------
                                                     TABLE 7.    (.Continued)

Number of Pump
Process Unit
Atmospheric Distillation: No. 1
Atmospheric Distillation: No. 2
Vacuum Distillation
Light Ends/G^s Processing
HDS: Reformer Feed
HDS: Light Gas Oil
HDS: Heavy Gas Oil
HDS: Light. Cycle Oil
HDS: Vacuum Gas Oil
HDS: Coker Naphtha
FCCU
Hydrocracking
Catalytic Reformer No. 1
Catalytic Reformer No. 2
Aromatics Extraction
Alkylation
Coking
Lt. Liq.
Service
15
15
2
4
9
9
9
9
9
9
18
17
18
18
15
15
3
194
Hvy. Liq.
Service
28
28
19
0
5
5
5
5
5
5
24
14
2
2
2
0
10
159
Seals
Total
43
43
21
4
14
14
14
14
14
14
42
31
20
20
17
15
13
353
Pump Seal
Lt. Liq.
Service
3.75
3.75
0.50
1.00
2.25
2.25
2.25
2.25
2.25
2.25
4.50
4.25
4.50
4.50
3.75
3.75
0.75
48.50
Emissions,
Hvy. Liq.
Service
1.29
1.29
0.87
0.00
0.23
0.23
0.23
0.23
0.23
0.23
1.10
0.64
0.09
0.09
0,09
0.00
0.46
7.30
Ib/hr
Total
5.04
5.04
1.37
1.00
2.48
2.48
2.48
2.48
2.48
2.48
5.60
4.89
4.59
4.59
3.84
3.75
1.21
55.80
Compressor
Total
Seals
2
2
-
4
6
6
6
6
6
6
6
6
6
6
0
0
0
68
Emissions ,
Ib/hr
2.
2.
-
5.
0.
0.
0.
0.
0.
0.
8.
0.
0.
0.
-
-
-
25.
80
80
-
20
66
66
66
66
66
66
40
66
66
66
-
-
-
14
Drains
Total
Drains
69
69
35
11
22
22
22
22
22
22.
65
58
49
49
41
41
28
647
Emissions,
Ib/hr
4.83
4.83
2.45
0.77
1.54
1.54
1.54
1.54
1.54
1.54
4.55
4.06
3.43
3.43
2.87
2.87
1.96
45.29

Q


S

05
H-
n
Emissions from within the battery limits  of the respective process  units.

-------
F. G. Mesich
into the question of approaches to leak  detection  and  control.   Table  8  shows
the distribution of non-methane hydrocarbon  leaks  for  each  of  the baggable
source categories.  Typical histograms developed from  the same data  illustrate
leak distribution within the source categories  and are shown in Figures  1,
2, and 3.

          These data demonstrate that the bulk  of  emissions from the fugitive
sources result from a small fraction of  the  sources.   For example, 93  percent
of the total measured leaks from valves  in gas  service are  emitted from  only
4.4 percent of the valves.  With flanges, 89 percent of  the leakage results
from less than 1 percent of the total number of figures.  With  pumps in  light
liquid services, 20 percent of the pumps account for 95  percent  of the mass
of the leaks.

          While it is encouraging that the majority of the hydrocarbon emis-
sions are coming from only a small fraction  of  the possible leaking sources,
in order to repair the leaks one must first  find them.   This program ran into
the same situation when identifying sources  for bagging.  To be  useful, a
technique for screening potential leak sources must be rapid,  convenient,
and enable an estimate of the magnitude  of the  leak.


SCREENING DATA

          The screening of sources during this program was accomplished with
sensitive portable hydrocarbon detectors.  The principal device  used in  this
study was the J. W. Bacharach Instrument Co. "TLV Sniffer."  The  Century
Instrument Co. Organic Vapor Analyzer (Model OVA-108)  was used  for some
screening, but these readings were not included in the correlations which
follow.  The instruments were calibrated with standard mixtures  of hexane
in air.  The OVA-108 and TLV Sniffer give direct readings of hydrocarbon
concentrations in ppm by volume.  In this report,  the  terms "screening
values" and "TLV screening values" refer to  the maximum  hydrocarbon concen-
tration detected at selected baggable sources.

          Screening values were obtained when the  source was first located,
and rescreening values were taken at the time each source was  sampled.  The
rescreening values were taken at the time each source  was sampled.   The
rescreening values were generally more highly correlated with  leak rates
than are the original screening results.  For example,  the correlation
coefficient for the original screening values and  non-methane hydrocarbon
leak rates of all valves is 0.63.  A correlation coefficient of  0.72 is
obtained for the maximum rescreening values and non-methane hydrocarbon
leak rates of valves.

          The final report of this study will contain  detailed descriptions
of the least-squares linear regression equations developed for predicting
leak rates from unsampled sources in the data base.  For potential predic-
tion purposes outside this data base, a  statistical analysis of  covariance
was done to determine whether different  linear equations are required  for
                                    147

-------
F. G. Mesich
         TABLE 8.  DISTRIBUTION OF NONMETHANE LEAK RATES FROM
                   SAMPLED SOURCES
Leaking Sources •
Within Range
Leak Range
(Ib/hr) No.
Total Leakage
Within Range
% of % of Total Total
Leaking Sources Leakage % of Total
Sources Screened (Ib/hr) Source of Leakage
Valves, Gas/Vapor Streams = 563
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0
0.00001 -
7
18
43
.01 49
0.001 37
154
4.6
11.7
27.9
31.8
24.0
100%
1.2
3.2
7.6
8.7
6.6
20.3%
Valves, Light Liquid/Two-Phase Streams
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.
0.00001 -
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.
0.00001 -
1
31
105
.01 121
0.001 72
330
Valves ,
0
0
5
01 13
0.001 14
32
0.3
9.4
31.8
36.7
21.8
100 r.
Heavy Liquid
0.0
0.0
15.6
40.6
43.8
100%
0.1
3.4
11.5
13.3
7.8
36.1%
Streams = 485
0.0
0.0
1.0
2.7
2.9
6.6%
Screened
17.7654
5.9187
1.4867
0.2052
0.0133
25.3893
= 913 Screened
2.2297
9.3351
3.3877
0.5028
0.0266
15.4819
Screened
0.0
0.0
0.1773
0.0569
0.0051
0.2393
70.0
23.3
5.5
0.8
0.1
100 Z
14.4
60.3
21.9
3.2
0.2
100%
0.0
0.0
74.1
23.8
2.1
100%
                                                       Continued
                                   148

-------
F. G.  Mesich
                             TABLE 8.   (Continued)
Leaking Sources
Within Range
% of
Leak Range Leaking
(Ib/hr) No. Sources
Total Leakage
Within Ranee
% of Total Total
Sources Leakage 7, of Total
Screened (Ib/hr) Source of Leakage
Valves, Predominantly Hydrogen Streams =
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.
0.00001 -
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.
0,00001 -
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.
0.00001 -
0
3
19
01 18
0.001 19
59
Op en-Ended
0
1
9
01 12
0.001 8
30
0
4
12
01 28
0.001 18
62
0.0
5.1
32.2
30.5
32.2
100%
Valves,
0.0
3.3
30.0
40.0
26.7
100%
Flanges
0.0
6.4
19.4
45.2
29.0
100%
0.0
2.2
14.1
13.3
14.1
43.7%
All Streams = 129
0.0
0.8
7.0
9.3
6.2
23.3% . ,
= 2094 Screened
0.0
0.19
0.57
1.33
0.86
2.95%
135 Screened
0.0
0.3789
0.6691
0.0532
0.0059
1.1071
Screened
0.0
0.1242
0.3475
0.0576
X
0.0033
0.5326
0.0
0.8655
0.4117
0.0820
0.0096
1.3688
0.0
34.2
60.5
4.8
0.5
100%
0.0
23.3
65.3
10.8
0.6
100%
0.0
63.2
30.1
6.0
_£LJ
100%
                                                        Continued
                                      149

-------
F. G. Mesich
                               TABLE 8.   (Continued)
Leaking Sources
Within Range
% of % of
Total
Leak Range Leaking Sources
(Ib/hr) No. Sources Screened
Pump
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.01
0.00001 - 0.001
Pump
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.01
0=00001 - 0.001
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.01
0.00001 - 0.001
Seals,
19
73
107
77
20
296
Seals ,
0
16
28
17
5
66
4
12
17
13
3
49
Light Liquid
6.4
24.7
36.1
26.0
6.8
100%
Heavy Liquid
0.0
24.2
42.4
25.8
7.6
100%
Drains = 257
8.2
24.5
34.7
26.5
6.1
100%
Streams =
4.0
15 .-5
22.7
16.4
4.3
62.9%
Streams =
0.0
5.5
9.6
5.8
1.7
22.6%
Screened
1.6
4.7
6.6
5.1
1.1
19.1%
Total Leakage
Within Range
Total

Leakage % of Total
(Ib/hr) Source of Leakage
470 Screened
63.1913
22.0347
3.9^30
0.3274
0.0086
89.5051
292 Screened
0.0
4.3139
1.50S9
0.0699
0.00178
5.3995
7.3958
3.9615
0.5939
0.0630
0.0013
12.0155
70.6
24.6
4.4
0.4
0.0
100"
0.0
73.2
25.6
1.2
0.0
100%
61.6
33.0
4.9
0.5
0.0
100%
                                                        Continued
                                    150

-------
F. G. Meslch
                                TABLE  8.   (Continued)
Leak P-snge
(lb/hr)
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.01
0.00001 - 0.
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.01
0.00001 - 0.

No.
5
15
22
12
001 4
58
Compressor
23
48
24
7
001 3
105
Leaking
Within
" of
Leaking
Sources
Relief
8.6
25.9
37.9
20.7
6.9
100%
Sources
Range
% of Total
Sources
Screened
Total Leakage
Within Range
Total
Leakage % of Total
(lb/hr) Source of Leakage
Valves = 148- Screened
3.4
10.1
14.7
8.1
2.7
39.0%
Seals, Hydrocarbon Service
21.9
45.7
22.9
6.6
2.9
100%
16.2
33.8
16.9
4.9
2.1
73.9 %
Compressor Seals, Hydrogen Service
>1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.01
0.00001 - 0.
0
14
22
21
001 12
69
0.0
20.3
31.9
30.4
17.4
100%
0.0
16.9
26.5
25.3
14.5
83.2
15.5333
3.9313
0.9121
0.05-SO
0.0022
20.4419
* 142 Screened
67.9440
22.2482
1.3014
0.0224
0.0013
91.5172
= 83 Screened
0.0
3.3954
1.0105
0.0794
0.0064
4.^:917
76.0
19.2
4.5
0.3
0.0
100%
74.3
24.3
1.4
0.0
0.0
1002
0.0
75.6
22.5
1.8
0.1
10 OS
                                    151

-------
    30-
    25-
    20-
i   »
     10
          N-89
                                                                                                                 o
                                                                                                                 3;
                                                                                                                 (D
                                                                                                                 CO
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                                                                                                                 n
                                     I   I
                   I     .1
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        o /—  «* in
        o o o QO o

        o o o o o o
        V
in
o
in
o
in
in
in
o
a
o
in

a

A
                                           Midpoint of
                                   Non Methane Leak Rate (Ibs/hr)
                    Figure 1.   Distribution of  Leak Rates for

                                 Valves - Gas Vapor Streams

-------

30-
25-
20-
1
e
10-
5-
g
Y-197


I



nil
III
II Illi ,111 , 1. I ,1 1 , 1.
in m in in in in m m in in ift tn in in a
Or— <\j i»> «!• m o *n O in o in o m c
oooooo r— •-* o-j *M f*i **i ^- ^* in
OOOC3OO O O O CD O O O O O
y ft
                                                                                       CO
                                                                                       H-
                                                                                       o
            Midpoint of Nonmethane Leak Rate (Ibs/hr)
Figure  2.   Distribution of Leak  Rates for Valves - Light

            Liquid/Two-Phase Streams

-------
                         30-n
                         25-
                                                                                                                              o
                                                                                                                              •

                                                                                                                              is
                                                                                                                              rti
                                                                                                                              w
                                                                                                                              H-
                                                                                                                              o
                         20-
                         15-
Ln
-P-
                         10-
                         5-
                              IJ
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                             O<—CM M «» UI
                             oooo o o

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                                            in
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                            in
                            o
                            «M
in
CM
        in
        O
in
in
        o


        o
o
o
in
                                                Midpoint of Non Methane Leak Rate (Ibs/hr)
                                       Figure 3.  Distribution of Leak Rates  of

                                                   Valves -  Heavy Liquid Streams,

-------
F. G. Mesich
each baggable source and stream type.   It was found  that  the source and
stream types could be grouped such  that seven  (7)  equations were adequate
for predicting leak rates from screened sources.   The  seven groups are as
follows:

          o  Pumps in light liquid/two-phase streams,  compressors,
             and relief valves in gas/vapor streams

          o  Valves and compressor  seals in hydrogen service

          o  Valves in gas/vapor streams

          o  Valves in light liquid/two-phase streams

          o  Flanges

          o  Drains

          o  Pump seals in heavy liquid streams.

          The equations for flanges, drains, and pump  seals in heavy liquid
streams were developed from the original maximum screening values.  This is
because small sample sizes (less than 20) would have been available in each
of the three (3) cases if the rescreening values had been used.  No equation
was developed for valves in heavy liquid streams;  a sample size of less than
20 was available with either the maximum screening or maximum rescreening
values.

          Typical data used to develop  these equations are shown in Fig-
ures 4 through 6.

          The resulting equations were  used to develop nomographs which
relate the predicted leak rate to the screening values for the various
source and stream types.  Examples  of these nomographs are shown in Fig-
ures 7 through 12.

          Each nomograph gives the  predicted mean  leak rate as a function
of the maximum TLV Sniffer screening readings taken directly at the source
of the leak.  Although the equations were developed on a logarithmic scale,
the nomographs are shown on a arithmetic scale for ease in reading and
interpolation.

          The 90 percent confidence intervals shown on the nomographs are
for the mean leak rate and should not be confused with confidence intervals
for individual leak rates for given screening values.  Figures 13 and 14
graphically compare the confidence  intervals for individual leak rates with
the confidence interval for the mean leak rate for valves (light liquid/
two-phase streams).
                                    155

-------
                                                    :  A  =  1 UUSt » = i! ()°St  11C.
                                                                                                                  cn
   1 .(,
   O.It  «
       *
       t
       t
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  - n . t»

-------
  - 0 . (I
  -1.6
  - 2 . '4
                                               LCbtNU:  A  =  1 UUSi M = i! 0"S« Lit.
                                                                                                                 o
                                                                                                                 re
                                                                                                                 en
                                                                                                                 H-
                                                                                                                 n
  -3. ^ *
"« -M.O +
S      t
  -6.4
                                                                     --4--

                                                                      H.fl
           •- I --
           1.«
2.1
2.7     3.U     3.3     3.b     3.9     M.2

Logu of Maximum Screening Value at the Source
                         Figure 5.   Leak Rate/Screening Relationship  -  Valves and
                                     Compressor  Seals, Hydrogen Streams,

-------
                                                                 I I 0| MU! A = 1 UDSt II s V. ()l»Si lit.
Ui
oo
                         i.r.
    d.O     3. -5     3.6     i.V     M.r

Logn of Maximum Screening  Value at the Source
                                                                                                                 5.1
                                                                                                                                    o
                                                                                                                                    3
                                                                                                                                    (0
                                                                                                                                    en
                                                                                                                                    H-
                                                                                                                                    O
                                          Figure 6,  Leak Rate/Screening Relationship - Valves,
                                                      Gas/Vapor Streams.

-------
F. G.  Mesich
                                                          Upper Limit of 905 Confidence
                                                       / Interval  for Mean
                                                         Mean
                                                         Lower Limit of 90S Confidence
                                                         Interval  for Mean
                                       Login (NM Leak Rate) « -4.4 + 0.83 Logi,  (Max Screening Value)
                                       Con-elation Coefficient » 0.68
                                       Number of Data Pairs = 259
                                       Standard Error of Estimate » 0.7S Logio (IN Leak Rate)
                                       Scale Bias Correction Factor « 4.58
              1,000
5,000
10.0CO
                  Maximum Screening  Value (ppmv as Hexane)
              Using J.W. Bacharach TLV Sniffer at the Source.
          Figure  7.   Nomograph for Predicting Total Hydrocarbon  Leak
                       Rates  From Maximum Screening Values -  Pumps (Light
                       Liquids), Compressors,  Relief Valves  (Gas/Vapor
                       Streams)  (Part I:   Screening Values from 0-10,000 ppm)
                                            159

-------
F.  G.  Mesich
           4.0
           3.S
           3.0
           2.5
        u
        o
        g  2.o
        j=
        4J
        01

        I  1.5
        *  1.0
           0.5
                          Upper Limit of 90S Confidence
                        / Interval  for Mean
                                                            Mean
                                                            Lower Limit of 90S Confidence
                                                            Interval for Mean
     Logn (NM Leak Rate} * -4.4 + 0.83 Logic (Max Screening Value)
     Correlation Coefficient « 0.63
     Number of Data Pairs - 259*
     Standard Error of Estimate * 0-76 Logig (NK Leak Rate)
     Scale Bias Correction Factor « 4.58
                 10,000
50,000
100,000
                     Maximum Screening Value (ppmv as Hexane)
                 Using J.W. Bacharach TLV Sniffer at the Source.
           Figure  8.   Nomograph for Predicting Total Hydrocarbon  Leak
                        Rates  from Maximum Screening Values -  Pumps (Light
                        Liquids), Compressors,  Relief Valves  (Gas/Vapor
                        Streams)  (Part II:   Screening Values  from
                        0-100,000 ppm).
                                           160

-------
G. Mesicn
          0.07
       £ 0.06
          0.05
        c
        I
        a
       fi 0.03
        
-------
F.  G- Mesich
       g  0.45
          0.35  -
       «  0.25  -
          0.15  -
          0.05  -
                                                          / Upper Limit of  90* Confidence
                                                          '  Interval for Mean
                                                            Mean
                                                         / Lower Liniit of 90% Confidence
                                                            Interval  for Mean
       Logjj (KM Leak Rate)-' -7.0 + 1.23 Logic  (hax Screening Value)
       Correlation Coefficient - 0.75
       Number of Data Pairs - 0.79
       Standard Error of Estimate « 0.78 Log; t (fi« Leak Rate)
       Scale Bias Correction Factor * 4.81
                10,000
50,000
100,000
                    Maximum Screening Value (ppmv  as Hexane)
                Using J.W. Bacharach TLV Sniffer at the Source.
             Figure 10.   Nomograph for Predicting Total  Nonmethane
                           Hydrocarbon  Leak Rates from Maximum Screening
                           Values  - Valves,  Gas/Vapor Streams  (Part II:
                           Screening Values from 0-100,000 ppm).
                                              162

-------
p.  G. Mesich
                 0.07
              - 0.06
               S O.OS
              _>

              I
               o 0.04
              5 0.03

              i
              - 0.02
                 0.01
                          Logi. (KM Leak Rate) » -4.9 * 0.60 Logi, (Hdx Screening Value)
                          Correction Coefficient * 0.79
                          Number of Data Pairs • 119
                          Standard Error of Estimate • 0.60 log\, (NM Leak Rate)
                          Scale Bias Correction Factor "2.53
                          Upper Limit of 90S Confidence
                          Interval  for Mean
                         Mean
                         Lower Limit of 901 Confidence
                         Interval  for Mean
                                       /
                       1.000
5,000
10,000
                          Maximum Screening Value (ppmv as Hexane)
                       Using J.tf. Bacharach TLV Sniffer at the Source.
                    Figure  11.  Nomograph  for  Predicting  Total Nonmethane
                                  Hydrocarbon Leak Rates  from Maximum Screening
                                  Values - Valves, Light  Liquid/Two-Phase Streams
                                   (Part  I:   Screening  Values from 0-10,000 ppm).
                                            163

-------
F.  G.  Mesich
          0.45  -
          0.40 -
           0.15 -
           0.10 -
           O.OS
                                                           Upper limit of 901 Confidence
                                                        /  Interval  for Mean
                                                            Mean
                                                            Lower Limit of 90S Confidence
                                                            Interval  for Mean
                                     Logn (NH Leak Rate) - -4.9 + 0.80 Logic  (Max Screening Value)
                                     Correlation Coefficient » 0.79
                                     Number of Data Pairs « 119
                                     Standard Error of Estimate - 0.60 Loan (NM Leak Rate)
                                     Scale Bias Correction Factor «2.53
                  _t	1	J	I	I	I	I
                 10,000
50,000
100.000
                    Maximum Screening Value (ppnv as Hexane)
                 Iking  J.M. Bacharach TLV  Sniffer at the Source.
            Figure  12:   Nomograph  for Predicting  Total Nonmethane
                           Hydrocarbon Leak Rates  from Maximum Screening
                           Values - Valves, Light  Liquid/Two-Phase Streams
                           (Part  II:   Screening Values from  0-100,000  ppm)
                                             164

-------
F.  G. Mesich
                                                           Upp«r Limit  of 90* Confidence
                                                           Interval  for Individual  Values
         0.45  -
                                     Logn (KM Leak Rate) - -4.9 + 0.80 Log,, (Max Screening Value)
                                     Correlation Coefficient * 0.79
                                     Nuaber of Data Pairs * 11?
                                     Standard Error of Estimate « 0.60 logi, (NK Leak Rate)
                                     Scale Bias Correction Factor »2.53
                             Upper Limit of 905 Confidence
                             Interval for Mean Leak Rate
                                                                  Lower Limit of 9M Confidence
                                                                  Interval for Mean Leak Rate
                                                                 Lower Limit of 90S  Confidence
                                                                 Interval for Individual Values
               1 ,000
5,000
                                                       10,000
                   Maximum  Screening Valu*  (ppnw as Hexane)
                Using J.W.  Bacharach TUV Sniffer at th« Source.
                    Figure 13.   Nomograph for Predicting  Total Nonmethane
                                   Hydrocarbon  Leak Rates from Maximum  Screening
                                   Values -  Valves,  Light Liquid/Two-Phase  Streams
                                    (Part I:   Screening  Values from  0-10,000 ppm).
                                              165

-------
F.  G. Mesich
         3.5
      5  3.0
      oe

      IS 2.5
       3  2.0
       o
      £
      
-------
F. G. Mesich
           From the  results of this study, nomographs have also been prepared
 relating hydrocarbon concentration at the source (screening value)  to the
 percentage of  each  source type expected to have screening values above any
 selected value.   Other nomographs have been prepared relating screening values
 to  the  percentage of total mass emissions which can be expected from sources
 with  screening values greater than any given value.
          These nomographs for  the valves,  flanges,  and  pump  seals  (with
appropriate stream groups) are  presented  in Figures  15 through 21.  The "B"
figures relate the percent of total mass  emissions for a given source cate-
gory to screening values; the "A" figures relate  the percent  of sources to
screening values.  The screening values in  these  nomographs are the hydro-
carbon concentrations obtained  at the  source (0 cm)  with a Bacharach TLV
Sniffer calibrated with hexane.

          Confidence intervals  are included on each  of these  nomographs.
The confidence intervals for both types of  nomographs indicate how well the
cumulative function has been estimated from the data collected in this
program.

          The 95 percent confidence intervals for the cumulative percent
of sources can be interpreted as ranges of  values which  contain the actual
percent from the population of  sources studied.   Note that these intervals
apply to the entire population  of sources (i.e.,  a composite  of all United
States refineries), and are not necessarily applicable to a finite number
of sources at any particular refinery.  Because of the nature of the func-
tion, the confidence intervals will be approximately valid any time a random
sample of greater than 100 sources is  being considered.

          The 90 percent confidence intervals for the cumulative percent of
total emissions function can be interpreted as ranges of values which contain
the actual percent of total emissions  function for the entire population of
sources.  Again, these intervals describe how well the function has been
estimated for the entire population and are not directly applicable to a
particular refinery situation with a finite number of sources.  The varia-
tion of the function for a particular  sample of sources  is a  complex function
of the number of sources.

          The nomographs must be carefully  evaluated when comparing these
estimates to actual measured emissions (samples sources).  As discussed
earlier, the correlation between screening  values and actual  leak rates is
imperfect.  Because of this, values obtained from the nomographs for percent
of total emissions caused by a  specific percent of total sources may not
exactly match similar values for measured leak rates.  Table  8 gave
the distribution of total emissions as a  function of measured leak  rates.
In most cases, the nomographs will indicate a higher percentage than in
Table 8 of sources being responsible  for  a  given  percentage of total
emissions.  In this sense,  if actual  leak rates could be measured,  the
                                     167

-------
F. G.  Mesich
           u
           u
           u
           a
           o
           vt
           u
           u
TOO




 90




 80




 70




 60




 50




 40




 30




 20





 10




  0
                                  Upper Um1t of 951 Confidence  Interval
                                                Estimated Percent of Sources
                        Lower Limit of 955

                        Confidence Interval
                1  2  345  10      50 100       1,000      10,000      100,000    1,000,000



                             Screening Value  (pptnv)  (Log^Q Scale)
              Percent of Sources - Indicates  the percent of sources with screening


                                 values greater than the selected value.
                   Figure 15A.   Cumulative  Distribution of  Sources and

                                   Total  Emissions by Screening Values  for

                                   Valves - Gas/Vapor Streams.
                                           168

-------
F. G.  Mesich
            100




             90





             30

          *
          e
          o

          «  70
          •A


          UJ

          -  60
          Wt

          £


          •  50
          *«
          o
          t—


          o  40

          4J
          e
          «


          S  30
          &



             20





             10
                                        Upper Limit of 901

                                        Confidence Interval
              Estimated Percent of

              Total Mass Emissions
                   Lower Limit of the

                   90S Confidence Interval
                   i  i 1
                                  1   !
                1   2  345  10
50 100
1,000
10,000
100,000    1,000,000
                                Screening Value (ppmv) (Log^g Scale)
            Percent of Total  Mass Emissions - Indicates the percent of total emissions

                                           attributable to sources with  screening values

                                           greater than the selected value.
           Figure 15B.   Cumulative Distribution  of Source  and  Total

                          Emissions  by Screening Values for  Valves -

                          Gas/Vapor  Stream.
                                            169

-------
F. G.  Mesich
                                          Upper Limit of 95% Confidence Interval
                         Lower Limit of 95%
                         Confidence  Interval
                                                   Estimated Percent of Sources
                  1  2  345  10      50 100       1,000       10,000     100,000    1,000,000

                               Screening Value (ppmv) (Log10 Scale)

                Percent of Sources -  Indicates the percent of sources with screening
                                   values  greater than the selected value.
                    Figure  16A.   Cumulative  Distribution of  Source  and
                                   Total Emissions by Screening Values for
                                   Valves - Light Liquid/Two-Phase  Streams.
                                           170

-------
F.  G. Mesich
«
*J
o
            100


             90


             30


             70


             30


             50


             40


             30


             20


             10
                                                             Upper Limit of 90*
                                                             Confidence Interval
                          Estimated Percent df
                          Total Mass Emissions
                  111!   I
                                 I
                                    Lower Limit of the
                                    90S Confidence Interval
               1   2 345  10
                        50 100
1.000
                                                        10,000
                                                         100.000    1,000,000
                               Screening Value (ppav) (Log-|g Scale)
            Percent of Total Mass  Emissions  - Indicates the percent of total  emissions
                                          attributable to  sources  with screening values
                                          greater  than the selected value.
              Figure 16B.
                    Cumulative  Distribution of  Source and  Total
                    Emissions by Screening Values for Valves  -
                    Light  Liquid/Two-Phase Streams.
                                            171

-------
F. G.  Mesich
             V
             u
             £
             V
100

 90


 80


 70


 60


 SO


 40


 30


 20


 10
                               Upper  Limit of 95% Confidence  Interval

                               ^ /f
                                        Estimated Percent of Sources
                    Uoper Limit of
                    Confidence Interval
                   1  2 345  10     50 100       1,000      10,000     100,000    1.000,000

                                Screening Value  (ppmv)  (Log-|Q Scale)

                 Percent of Sources - indicates  the percent of sources with screening
                                   values greater than the selected value.
                   Figure  17A.   Cumulative Distribution  of Sources  and
                                   Total  Emissions by  Screening  Values for
                                   Valves - Heavy Liquids Stream,
                                           172

-------
F. G.  Mesich
                                                    Upper Limit of 90S
                                                    Confidence Interval
          a
          u
                                        \     \
                   Estimated Percent of —*-\  \
                   Total Mass Emissions
                                              \  \  \
                      Lower Limit of the         \  \  \
                      90S Confidence Interval      \   \ \
                                                \  \  \
               1  2  345 10
    50 100
1,000
10,000
100,000    1,000,000
                                Screening Value (ppav)  (Log-|0 Scale)
            Percent of Total  Mass Emissions - indicates the  percent of total  emissions
                                           attributable to sources with screening values
                                           •greater than the selected value.
             Figure 17B.
Cumulative Distribution of  Source and  Total
Emissions by  Screening  Values for Valves -
Heavy Liquid  Streams.
                                           173

-------
F.  G.  Mesich
              100


               90


               30


               70


               60
          jo    4Q
               30


               20


               10
                     Upper Limit of 95S Confidence Interval
                                  Estimated Percent of Sources
Lower Limit of the 955
Confidence Interval
                  1 2 345  10      50 100       1,000      10,000


                               Screening Value (ppmv) (Logi0 Scale)
                                           100,000    1,000,000
              Percent of Sources  - Indicates the percent of sources with screening
                                values  greater than the selected value.
                    Figure  ISA.   Cumulative  Distribution of  Sources and
                                    Total  Emissions  by Screening Values  for
                                    Valves - Hydrogen Service.
                                            174

-------
F.  G- Mesich
             100


              90



              30



              70


              60


              50



              40


              30


              20


              10
Estimated Percent of
Total Mass Emissions
                   t  n i   i
                                  j	i
                                         Upper Limit of 90S
                                         Confidence Interval
            Lower Limit of the 901
            Confidence Interval
                1   2 345  10
       50 100
1,000
10,000
100,000    1,000,000
                                Screening Value (ppmv) (Log-|Q Scale)
             Percent of Total Mass Emissions -  indicates  the percent of total emissions
                                            attributable to sources with screening values
                                            greater than the selected value.
                    Figure 18B.   Cumulative  Distribution of  Source and
                                    Total  Emissions  by Screening Values  for
                                    Valves  - Hydrogen Service.
                                             175

-------
F. G.  Mesich
 100

  90

  80

  70
I
1  60
I
l
;  so

  40

  30

  23

  10

   3
                                   Upper Limit of 95X Confidence Interval
                                                 Estimated Percent of Sources
                      Lower Limit of the 95
                      Confidence Interval
    1  2 345  10     50 100        1,000      10,000

                 Screening Value  (ppmv)  (LogjQ Scale)
                                                               100,000    1,000,000
           Percent of Sources - indicates the percent of sources with screening
                             values greater than the selected value.
             Figure  19A.   Cumulative Distribution  of Sources  and
                             Total  Emissions by  Screening Values for
                             Pump Seals -  Light  Liquid/Two-Phase Streams,
                                          176

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G. Mesich
        100


         90


         80
      e
     «   70
     M
     5
     *   60
50


40


30


20


10
                                                      Upper Limit of 90S
                                                      Confidence Interval
                         Estimated Percent of
                         Total Mass Emissions
              lit;   i
                                         Lower L1ro1t of the
                                         90S Confidence Interval
           1   2  345  10      50 100       1,000      10,000     100,000


                           Screening Value  (ppav) (Logio Scale)
                                                                1,000,000
        Percent of Total Mass Emissions - Indicates the percent of total emissions
                                      attributable to  sources  with screening values
                                      greater than the selected value.
          Figure 19B.   Cumulative Distribution of  Source and  Total
                         Emissions by  Screening  Values for Pump Seals
                         Light Liquid/Two-Phase  Streams.
                                       177

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F. G.  Mesich
                         Upper Limit of 95% Confidence  Interval
             _   Lower  Limit  of     N
                 the  95%  Confidence
                                       Estimated Percent of Sources
             1  2  345  10      50 100       1,000      10,000     100,000   1,000,000


                          Screening Value  (ppmv)  (log-jo  Scale)

           Percent of Sources - indicates the percent of sources with  screening

                             values greater than the selected value.
              Figure  20A.  Cumulative  Distribution  of Sources and
                            Total Emissions by Screening Values  for
                            Pump Seals  - Heavy Liquids
                                          178

-------
F.  G. Mesicti
          e
          o
          •
         *>
          o
          
-------
F.  G.  Mesich
           e
           0)
           o
 100



  90




  80




  70


I


I  60



  50




  40




  30




  20




  10
                   Upper Limit of 95





                	•—-	""""" •~ —
Jpper Limit of 951 Confidence Interval




                 .Estimated Percent of Sources
                   1111   i
                                               •«-1 - Lower Limit of 95S Confidence  Interval
                                                     - ^   i           i	i
                 1  2 345  10
                      50  100
                           1,000
10,000
100,000    1,000,000
                              Screening Value (ppav)  (Log-|g Scale)
              Percent of Sources - Indicates the percent of sources with  screening

                                 values  greater than the selected value.
               Figure  21A.   Cumulative Distribution  of Sources and

                               Total Emissions by  Screening Values  for

                               Flanges.
                                             180

-------
F. G.  Mesich
                                                          Upper Limit of 905
                                                          Confidence Interval
                        Lower Limit of the
                        905 Confidence Interval
1   2 345  10
                               50 100
1,000
                                                      10,000
                                                    ICO,COO    1,000,000
                              Screening Value (ppmv) (Log-jQ Scale)

          Percent of Total Mass Emissions - Indicates the percent of total emissions
                                         attributable to sources with screening  values
                                         greater than the selected value.
             Figure  21B.   Cumulative Distribution  of Source  and
                             Total Emissions by  Screening  Values
                             for  Flanges.
                                           181

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F. G. Mesich
 nomographs will be conservative (i.e., they will identify more sources to
 achieve a given level of reduction on total emissions than would be identi-
 fied through sampling).   In a practical sense, however, it is unreasonable
 to expect that every source with a screening value exceeding a specific level
 could be bagged and sampled.  Since, at this time, there is no better method
 than screening for identifying sources for maintenance, the nomographs are
 appropriate for evaluating maintenance and control options.

          The nomographs are therefore useful  in evaluating the potential
effectiveness of maintaining and repairing sources for reducing emissions.
For example, approximately 50 percent of valves in gas vapor stream  service
can be expected to have screening values above 50,000 ppmv.  However,  these
5 percent £>f the valves are  responsible for an estimated 95 percent  of  the
mass emissions.  Similarly,  for a screening value of 10,000 ppmv,  the  per-
cent of sources and percent  of emissions are 9 percent and 99 percent,
respectively.

COOLING TOWERS AND WASTEWATER TREATMENT SYSTEMS

          During the  course  of this  program, extensive effort was  expended
in an attempt to directly determine  the hydrocarbon emissions from open
sources such as cooling towers and wastewater  treatment systems.  This was
an exceedingly difficult task in that the composition of materials within
these sources was highly variable and the sources consisted of large areas
exposed to the atmosphere.   Enclosing of these sources was either imprac-
tical from a size standpoint or hazardous from an explosion standpoint.
A material balance technique was used in an attempt to quantify the  loss of
volatile hydrocarbons.


Cooling Towers

          Thirty-one  (31) cooling towers were  sampled, eight (8) of which
had statistically significant emissions.  Streams from five  (5) towers were
analyzed by both TOG analysis and purge analysis; therefore, streams from a
total of 21 towers were analyzed by  TOG and 15 by purging.  Because  purge
values were judged to be the more precise, they were chosen to represent
the towers analyzed by both methods  in the calculations of mean emissions
for all towers.  A summary of the emissions and the  A  ppm values for these
towers is given in Table 9.

          The magnitude of the sampling/analytical, variation caused  some
problems in quantifying the  low levels of emissions from the towers.   The
standard deviation for replicate TOG analyses was 4.2 ppm.  If two tests
were run each day, the standard deviation for  the average would be 3.0 ppm.
The between day standard deviation (after averaging replicate samples
and analyses) using the TOG  analyses was 3.61 ppm.  Since this is
close to the analytical standard deviation when replicate samples  are  aver-
aged, it appears most of the variation in the  TOG data is due to  the analyti-
cal technique or the homogenity of replicate samples.
                                     182

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                              TABLE 9.  SUMMARY OF COOLING TOWER EMISSIONS
               Cooling  Towers  Sampled
               Cooling  Towers  Having Statistically  Significant  Emissions
               Range  of Cooling  Tower Circulation Rates	
      31
      8
      714 to 58.000 GPM
                                                                                                                       o
                                                                                                                en
                                                                                                                H-
                                                                                                                O
                                                   Results  (estimate with 95% confidence interval)
oo
       Mean Cooling  Tower  A HC  Concentration
            From Emitting  Towers         n  ,„,  .  ~  , n
                 „ .,  .  ,               0.101  ±  0.19  ppm
                 Both  Analyses                        r
     From All Towers Sampled
          TOC Analysis
          Purge Analysis
          Both Analyses3

Mean Cooling Tower Emissions
     From Emitting Towers
          Both Analysis

     From All Towers Sampled
          TOC Analysis
          Purge Analysis
          Both Analyses
                                         1.25  ±  1.24  ppm
                                         0.0130  ±  0.0299 ppm
                                         0.0173  ±  0.058  ppm
                                         0.00088  ±  0.0016  lb/1000  gal
                                         0.0124  ±  0.0123  lb/1000  gal
                                         0.000108  ±  0.00025  lb/1000 gal
                                         0.000151  ±  0.00051  lb/1000 gal
        Range of Measurable Emissions    0.36  to  8.46  Ib/hr
(negligible, 0.29 ppm)
(0.01, 2.5 ppm)
(negligible, 0.043 ppm)
(negligible, 0.075 ppm)
(negligible,  0.0025 lb/1000 gal)
(0.0001,  0.025 lb/1000 gal)
(negligible,  0.000261 lb/1000 gal)
(negligible,  0.00066 lb/1000 gal)
         Calculated for 15 towers analyzed by TOC only  plus  16  towers analyzed by purge.  The 5  towers
         analyzed by both methods were represented only by the  purge values, considered more accurate
         than TOC values.

-------
 F.  G.  Mesich
          The analytical standard deviation for the purge method is 80 percent
of the concentration (averaging about 0.1 ppm).  The between day standard devi-
ation calculated here was 0.12 ppm so again most of the variation in the purge
data is due to the analytical method.  But, since the levels reported by the
purge method were at least an order of magnitude smaller than the TOG values,
the absolute variation is much smaller for towers evaluated using the purge
techniques.

          Since sampling was only done on five to seven days for most towers,
and emissions from the towers were found to be relatively low, it was not sur-
prising to get some negative values as estimates of emissions for a particular
tower.  The negative estimates are as follows:

Analytical            Number of                  Towers with Negative Estimate
  Method                Towers                       Number        Percent

TOC                       21                            7            33.3

Purge                     15                            2            13.3

Combined                  31                            8            25.8

          The negative estimates are due primarily to the analytical variation.
In order not to bias the average emission calculation for cooling towers, these
negative values have been used rather than setting the estimate to zero.

          The mean emissions for the 16 towers analyzed by TOC only and the
15 analyzed by purge were 0.00015 lb/1000 gal with 95 percent confidence inter-
val of ± 0.00051  (negligible, 0.00066 lb/1000 gal).  Mean emissions for the
eight towers with statistically significant emissions were 0.00088 ± 0.0016 lb./
1000 gal (negligible, 0.0025 lb/1000 gal).  Mean emissions for the 21 towers
analyzed by TOC were 0.0124 ± 0.0123 lb/1000 gal (0.0001, 0.025 lb/1000 gal).
For the 15 towers analyzed by the purge method, mean emissions were 0.000108 ±
0.00025 lb/1000 gal (negligible, 0.00026 lb/1000 gal).

          Where values obtained by TOC analysis and values obtained by purging
were combined to obtain a mean value, the confidence limit was sometimes larger
than the obtained value.

          Because of the varying precision of the methods, the upper confidence
limit for each estimate may be a more useful value than the estimated average
for many purposes.  These values which give a "worst-case" estimate for the
magnitude of hydrocarbon emissions from cooling towers are as follows:

          Analytical                         "Worst-Case" Estimate of Average
         Method Used                           Emissions from Cooling Towers

             TOC                                  0.025 lb/1000 gal
             Purge                                0.0003 lb/1000 gal
             Combined                             0.0007 lb/1000 gal
                                     184

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F. G. Mesich
Even  these values  are  small relative to other sources of emissions from
refineries.


WASTEWATER SYSTEMS

         Wastewater  treatment is usually accomplished in three stages:  pri-
mary,  secondary, and  tertiary treatment.  Primary treatment facilities are
principally  involved  in physically upgrading the wastewater by removal of oil,
oily  sludge, and grit.  Thus, primary treatment facilities will be the princi-
pal sources  of  fugitive hydrocarbon emissions from the waste treatment plant.
Oil removal  equipment  includes API separators, corrugated plate interceptors,
flocculation units, and dissolved air flotation units.  The latter are also
used for suspended solids removal.

          Table 10 summaries the average emissions per gallon of material
throughout for  all sampled devises by refinery.  Unfortunately, the data from
the cooling  tower  and  wastewater treatment systems are not sufficiently repro-
ducible to develop usable emission factors.  Cooling towers appear to be minor
sources of emissions  while oil/water separators require more work to determine
the significance of the emissions.
                                     185

-------
                               TABLE 10.   DESCRIPTION OF SAMPLED DEVICES - WASTE OIL/WATER SYSTEMS
00
Average Hydrocarbon Emissions m
Refinery
1
2
3
4
5
6
7
B
Device
R Rectangular API Separator
Circular DAF
Rectangular API Separator
Corrugated Plato Interceptor
Corrugated Plate Interceptor
Rectangular API Separator
Forebay Covered
Surge Tank
Two Rectangular Separators
Rectangular DAF
Rectangular API Separator
Rectangular API Separator
Rectangular PAF
Circular Separator
Circular DAF
Covered/Uncovered
C
U
C
C
C
U
U
U
U
I!
U
U
U
U
Losses from
Oil Phase,
Ib/gal slop oil
1.6 + 2
0.073 ± 0.4
1.84 + 1.11
-1.5 + 0.08
-0.11 + 0.06
0.12 + 1.3
0.45
-1.1 + 0.74
0.14 ± 0.4
0.48 + 0.61
Losses from H1
Water Phasn, y
Ib/gal water
2.7ilO~* +
8.2xlO~* +
-3.01xlO~*
—
2.2x10"* +
-2.4xlO~5~H
1.5x10"* +
6.5x10"* -t
1.1x10"* +
3.4xlO~* +
1.4xlO"s +
1.8x10"*
1.5xlO~*
+ lxlO~s

2.7xlO~*
3xlO~6
h 2.7x10 s
2.4xlO~*
1.9xlO~*
1.3x10"*
1.8xlO~*
1.7x10 !

-------
James J.  Morgester
                                  REVIEW

                                    by

                            James J. Morgester
                      California Air Resources Board
                          Sacramento, California


                                    on


              RESULTS OF MEASUREMENT AND CHARACTERIZATION OF
                        ATMOSPHERIC EMISSIONS FROM
                           PETROLEUM REFINERIES
                                  RESUME
         James Morgester attended the University of Washington and the
University of California at Berkeley specializing in physical science
and environmental law.  Jim is the author of over 30 technical papers on
air and water pollution control and has 20 years experience in the fields,
He is presently chief of enforcement for the California Air Resources
Board.
                                    187

-------
James J. Morgester
                                  REVIEW

                                    by

                            James J. Morgester
                      California Air Resources Board
                          Sacramento, California

                                    on

              RESULTS OF MEASUREMENT AND CHARACTERIZATION OF
                        ATMOSPHERIC EMISSIONS FROM
                           PETROLEUM REFINERIES
         The thirteen-refinery study that has been conducted by Radian
Corporation for the Environmental Protection Agency (EPA) and summarized
in  this paper is probably the best work, on the national level, done to
date on fugitive emission quantification in general and valve, flange,
pump, and compressor leakage in particular.  However,  since the sample
population for which the results are published in this paper was taken
from refineries in various regions of the U.S. (four refineries on the
West Coast), it is questionable whether the study statistics are directly
applicable to refineries in California or any specific region.  In addi-
tion, the sample size for each source (valve, flange,  pump, etc.) was less
than that sampled in previous California studies (e.g. 13,685 valves were
inspected in the Air Resources Board's 1978 California study, whereas
Radian examined 2,244 valves).  This means that generalizing from Radian's
sample results is not as well supported as generalizing based on a larger
data base.

         The most startling findings of the Radian study have been the high
occurrence of leakage found in valves and flanges (27 percent for valves
and 3 percent for flanges, overall), and the high average mass emission
rates for valves (approximately 0.55 Ib/day/valve depending on the assumed
line-service profile at the refinery).  The Air Resources Board's 1978 study
of valve and flange leakage in California refineries indicated nominal leak
frequencies of about 9 percent for valves and about 0.4 percent for flanges.
Furthermore, in 3 previous valve and flange studies in California (includ-
ing the Air Resources Board study), the overall mass emission rate for
valves was calculated to be in the 0.11-0.15 Ib/day/valve range.  Compari-
son of this emission rate with that found by Radian for valves indicates
the possibility of significant differences in inspection methods and/or the
                                    188

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James J. Merges ter
existing  preventative maintenance programs of California refineries versus
other  U.S.  refineries.

         The  specific results of Radian's California refinery inspections
have not  been published to date so it is impossible to make any comparison
between those results and the data obtained in other regions of the U.S.
It has been our experience that significant differences can exist among
refineries  in overall valve and flange leakage and in the leakage at similar
process units,  indicating a cause for leaks other than the nature of valve
and flange  service.   It was evident to the Air Resources Board field
personnel during our 1978 inspections of 7 major refineries and 6 chemical
plants in California that variations of 6 percent to 18 percent valve leak-
age in refineries and 0.3 percent and 22 percent in chemical plants were
largely due to the priority and emphasis given to routine maintenance of
valves and  flanges by each facility.  In chemical plants it was clear that
the priority  given to routine maintenance was directly influenced by the
costs  of  products being lost to leakage.

         If the Radian study results which are summarized in this paper by
Mr. Mesich  are indicative of results to be expected on the regional level
(although I have reservations about this being true), then past estimates
of hydrocarbon emissions from valves and flanges in refineries may have
been understated by as much as factor of five.  Using your emission factors
for valves  and flanges, I calculate that emissions from valves in refineries
in the South  Coast Air Basin would be 64.1 tons/day and from flanges 3 tons/
day.  Accordingly, previous estimates of the emission reduction and cost
savings achieveable by the implementation of effective and enforceable
valve  and flange emission control rules may have also been vastly under-
estimated.  In the coming era of higher and higher costs for petroleum
products, such rules may very well come to be viewed as the most cost
effective ever implemented.

         If such rules have been logically implemented 20 years ago, after
the 1958  joint study, the cumulative product savings in California refin-
eries  alone would have amounted to about 880,000 tons, or the equivalent
of over 300,000,000 gallons of gasoline.  At today's wholesale prices for
gasoline  the  total cost savings would be $220,000,000.

         Obviously,  the Radian study has been long overdue, and the data
generated from it probably will provide air quality analysts and control
strategists working on the national level with a valuable tool in the years
to come.
                                    189

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F. G. Mesich
                           QUESTIONS AND ANSWERS
Q.  James Stone/Louisiana Air Control Commission - On slide 23 you show that
your flanges don't have any leaks greater than 1 pound per hour and at some
other point in the talks they told me that you had included heat exchangers
and things like that in the flanges and if I have seen a large leak that
was not going to be stopped from a flange it was a heat exchanger.  Does
that mean that you did not include these in your study?

A. - No I  All flanges measured are included in the data base.  I would like
to state for the record that visual inspection is not a good way to esti-
mate the magnitude of a leak.  For example, in several instances that I was
personally involved in, things that had liquid leaks were screening and
bagging very low in terms of air emissions, again showing the dependence on
the volatility of material that was leaking from the line.  And further,
one of the largest sources our study identified was not recognized by the
crew until they screened it and put a bag around it and the bag just about
blew out.  It was not visually or audibly apparent.

Q.  James Stone/Louisiana Air Control Commission - The one refinery I am
thinking about has a whole bank of exchangers.  I have given them viola-
tions on opacity from smoke because of the drips from the exchangers.  And
I think those would probably qualify as bigger than one.

A. - All we can speak from is the data base of the thirteen refineries that
we were in.  And every flange that we measured is in that data base
somewhere.

Q.  Paul Harrison/Engineering-Science - I think that both the CARE study and
the Radian study may be accurate, depending upon how you count.  For
example,  I've seen an oven with maybe 3,000 components on one oven.  A
hydrogen oven where you have a lot of process gas entering; each one has a
burner,  each one has a valve, each one has a union and has them on both
sides.   And,  if you start counting that way your percentage of leakers
goes down.  The value 0.5 pounds per day for unmaintained valves is not bad.
I have found that the percentage of leakers x^as something like 2 percent
for a new refinery and 6 percent for an old refinery, but that is including
everything, including flanges, valves, compressors seals all in the same
pot.   I did not differentiate with valves.  So, I could easily believe the
GARB study.  In any one unit I could believe the Radian study.  In certain
process units it is probably easily 25 percent with that stringent kind of
study.   In addition, my study was conducted at 5 cm as opposed to the
1 cm so I could easily double it as well up to 12 percent which is more
like the GARB study.  One more comment about heat exchangers.  I caution you
                                    190

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F. G. Mesich
that just because you have visible  smoke  coming  out  of  a heat  exchanger
does not mean that it is detectable as VOC.   That  could be  particulates
and "heavies" which are dripping  out.  Many  times  those "heavies" aren't
very volatile and you can barely  see them on a detector.  So,  they would
not get through the screening.  The thing about  visual  leaks is  that many
times there are "heavies" that  get  into the  ground,  and maybe  they are
volatilizing over a long period.  But many times screening  devices will
not pick them up.

A. - That is correct.  Two other  very brief  comments.   One  is  that I don't
know whether our percentage of  leakers is really different  from  California's
or not.  In that ours is based  on the 200 ppm level  at  the  surface.  We
presented a little data looking at  the soap  bubble technique.  The data are
really insufficient at this point to correlate between  the  two methods of
detecting leaks.  I tend to prefer  the direct measurement to a somewhat
subjective interpretation of  the  formation of bubbles,  but  I certainly
would not make the statement  that the latter method  would be ineffective.
Jim Morgester evidenced a concern that there would be large differences
between refineries.  Lloyd presented a slide this morning that pretty
graphically shows that among  the  thirteen refineries, we found twelve that
the differences between refineries  were not  a variable  in terms  of influ-
encing our data, and I believe  one  refinery  did  have a  small effect in the
variance analysis.  So, we basically did  not see large  differences, when
you aggregate the data base.

COMMENT/Rosebrook - I think there are two other  things  that should be said.
The first, deals with the differences in  the data.   I recall during some
testimony about six weeks ago in  San Francisco when  we  introduced the
screening data which was collected  at the six Bay Area  refineries.  This
included the screening of some  25,000 valves.  Our data then began to
differ when we used a different cutoff.   We  used the California  screening
approach of one centimeter with the proper calibration  gas  and so forth
and reported it as they wished  to have it reported.  I  do not remember
whose data was which but one  of us  found  10  percent  leaking and  the other
one found 8 percent leaking.  So, basically  we are talking  in terms of how
we define a leak.  Once we came close to  using the same definition, I
think we found approximately  the  same percentage of  leaking fittings.  Thus,
we are not talking about the  difference between  6  and 30.   Given the proper
basis these numbers do agree.   The  second point  is that anyone having
access to the raw data could  compare two  processing  units or two refineries
(if one takes only two of them) and find  that there  is  indeed a  difference.
But insofar as its effect on  our  overall  data base no refinery had a signifi-
cant contribution which would skew  the data  base.  We definitely found
refineries where our random samples tended to give emission rates which were
much higher than they were in other refineries.

Q.  Thomas C. Ponder, Jr./PEDCo Environmental, Inc.  - Based on what you were
showing us Frank, you are saying  that if  we  had  a  50,000 barrel  a day
refinery and 300,000 barrel a day refinery and they  had the same number of
process units we should have  the  same amount of  emissions from each one?
                                    191

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F. G. Mesich
Because the number of valves is pretty constant like a FCC has the same
number of valves, a little FCC and a big FCC has the same number of valves.

A. - Within the confidence limits yes.

COMMENT/Dan Martin/Union Carbide Corporation - The data presented here is
for existing units in refineries or in chemical plants.  It has only been
in the last 12 to 18 months that the concern for fugitive losses has come
out.  On units now being built, should there be much concern about this
because now we are addressing ourselves to valve and piping specifications
that we never did before.  We found a lot of valves in the past that came
in improperly packed and were put in the system.  Under the new standards
I wonder when building a new unit if fugitive losses would be a problem in
a permitting process rather than going back as some sort of a RACT or back
up and correct the existing units.  In addition, a plant that is now
operating today has to be more concerned about occupational health.  We
are already going in now and doing a lot of correction on fugitive losses
where you have employee exposure.  We have never been concerned about that
in the past and are tightening up things.  Is fugitive loss really going
to be that big of a problem in the future?  And I have one last comment and
answer.  If a person has over 30,000 ppm coming out of something particu-
larly a VOC you better be careful because you've got a flammable situation.
You have got a time bomb.  And even though the wind is blowing, some day
you are going to have a fire on your hands.

COMMENT/K. C. Hustvedt/USEPA-RTP - From the plants that I have been in, the
benzene unit is the one area where I think occupational health was already
a factor.  We haven't seen much difference in the leak incidence from our
testing in those plants or elsewhere.  It is a problem where you can't see
the leaks.  The plants are doing what they can for the ones they know about,
but it is the ones they don't know about that cause the leaks that have
created the emission factors we now have.  Another point that will be shown
in some of the correlations we see tomorrow is that it is not so much a
factor of the type of equipment put in and how it is installed, but more
how it is maintained once it is inline.  You can see that the percent of
sources, creating 90 percent of the emissions is a very small percent of
the sources.   It is the few that aren't properly maintained where something
has gone wrong and they haven't been able to detect it.  So, I think with
even better design in the future and better installation you are still
going to have problems.   Vibration; you will still have incorrect specifica-
tion; and, still have to do some level of monitoring to find these as they
happen and correct the problem.

         One other point you were talking about.  The 30,000 ppm having an
explosive problem.  I think when you get right down to a source, 30,000 ppm
sounds like a big number but it really isn't much.  Sometimes you can have
30,000 ppm at the source and step back a foot and not see anything, if it
is a pinhole type leak and you have a lot of wind.
                                    192

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F. G. Mesich
COMMENT/Rosebrook - Jim Morgester would you  care to  address  that  question
also, from a state's standpoint and whether  you  see  any  difference  in  the
future on the types of enforcement problems  and  the  types  of regulations
and so forth.

COMMENT/James J. Morgester/California Air  Resources  Board  -  Well, you  have
two different issues you have to look at.  California's  standpoint  is,
number one, we have a number of refineries there on-line now and  it is
clear to me that this problem was demonstrated in 1958.  The problem is
still with us twenty-two years later.  Maybe it  is worse than what  we
estimated in 1958, so there has got to be  a  clear motivating mechanism to
make the people that are the decision makers aware of  the  issue and the
problem and take care of it.  That is for  existing facilities.  I think
that it is a little optimistic to think that any significantly different
type of valve arrangement is going to be used in a new unit.  I think  that
the valves are shelf items and that most design  engineers  simply pull  this
valve off the shelf and unfortunately I think you are  going  to see  the same
type of valve configuration twenty years in  the  future that  we have seen
twenty years in the past.  So, there is going to be  a  need for this type
of regulations, strictly looking at it from  a parochial  narrow vision
enforcement standpoint.  My only objective is to make  the  stakes high
enough that the management of the oil refineries cause these emissions
sources to be looked at.

Q.  Thomas C. Ponder, Jr./PEDCo Environmental, Inc.  -  About  two weeks  ago
we had inspected a vinyl chloride plant with a VOC instrument, even though
they had an ambient network in the plant to  pick up  fugitive emissions
leaks.  We found leaks over a 1,000 ppm, which was as  high as this  machine
had been calibrated to go that day.  They  were picking up  nothing on their
ambient network.  We found nothing coming  out of the pump  seals, which
have double mechanicals with oil flush for each  shaft,  and  the compressor
seals and the relief valves, which have rupture  disks.   These people were
very shocked to find leaks out of flanges  and sampling valves, well over
1,000 ppm.  Obviously since their networks weren't picking it up they
weren't checking.

COMMENT/ Jim A. Mullins/ Shell Oil Company - I would like  to respond to the
comment on the vinyl chloride plant.  In particular  I  think  it is totally a
function of not only the placement of area monitors  but  the  level of
detection those area monitors are set to detect  and  the  option levels  where
repairs are done.  In our particular plants  we have  such an  action  level
that the area monitors will detect.  For example, in a period of six months
they detected 150 leaks, which were repaired.  At the  end  of that six
month period every flange., valve and seal  in the plant was checked  item by
item and we found two leaks.  And that was over  5,000  valves, pumps,
flanges.  So, I think it is totally a function of how  the  system  is
designed and should not be interpreted as  a  general  indictment of area
monitoring.
                                   193

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F. G. Mesich
Q.  Michael Scherm/Union Carbide Corporation - Did you make  any  distinction
in your data base of the difference between a daily operated type valve and
a valve that is simply in-line and rarely turned or rarely used?

A.  (By Rosebrook) - There is a distinction which rests primarily on the
emission rates which we found for control valves, as opposed to  any type
of block valves.  We found that if there is a difference  in  the  emission
rates for control valves, it is not statistically significant.  We made
no attempt to determine for each of the valves that we monitored, any
frequency of use, other than breaking them up by putting  control valves
in a separate category.

Q.  Greg David/Dow Chemical Oyster Creek Division - I would  just like to
point out that I think that on your examples or predictions  for hypotheti-
cal refineries that you should have put somewhere on that piece of paper
that that is worst case.  You have the number of valves to be 90 and you
estimate emissions in pounds per hour to equal 5.  However,  in your
screening phase you found somewhere around 27 percent of  those valves to
be leakers, and I think that you should put a qualifier on that page.

A. - Actually I wish that were true, but the emission factors are based on
the total valve population and not only on leaking valves.   In other words,
the zeroes are counted in and used as a devisor for determining emission
factors.  Otherwise the emission factor wouldn't be very  useful.
                                   194

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W. R. Phillips
                REFINERY AIR EMISSIONS CONTROL TECHNOLOGY

                             W.  Robert Phillips
                             Radian Corporation
                              Austin, Texas
                                  ABSTRACT

           Selected  refinery process and fugitive emission sources and
 controls are  discussed.   Emission data from a recent study by Radian
 Corporation of  selected  emission sources in thirteen refineries are dis-
 cussed.  Pollution  control technologies are described and evaluated.
 Specific topics discussed include sulfur recovery,  catalyst regeneration,
 process boilers and heaters; valve and pump seals and packings; wastewater
 and cooling water systems.
                                   RESUME

           Mr.  Phillips (B.S.  - Chemical Engineering,  Texas Tech,  1955)  is
 employed by Radian Corporation.   He has twenty years  process industry  exper-
 ience which began with his return from military service in 1959.   Experience
 includes (chronologically) refinery production engineering (3+ years);
 chemical company research, development and project engineering of principally
 oxidation reaction systems (12+ years); environmental and energy  system
 research and development,  Radian Corporation (3 years).  Professional
 Affiliation:   American Institute of Chemical Engineers.
                                     195

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 W.  R.  Phillips
                 REFINERY AIR EMISSIONS CONTROL TECHNOLOGY


INTRODUCTION

Background

          Radian's refinery emissions study was conducted in thirteen
refineries.  Although fugitive emission testing within process battery limits
was emphasized, twenty process stacks (process heaters, CO boilers, SRU tail
gas, etc.) and off-site cooling towers and primary wastewater facilities
were surveyed.

Objectives

          Objectives of this paper are to:

          •    Review state-of-the-art of process and fugitive emission
               controls.

          •    Discuss available control technology.
          Discussion of process emissions for purposes of this paper has
been narrowed relative to that which appears in Radian's final Refinery
Emissions Report.  Focus will be on sulfur recovery, catalytic cracking
regenerator control, and process heater control.

          Certain low-impact fugitive air emission sources will be discussed
only briefly.  Emissions from loading, unloading and storage tanks were not
measured as part of the original field study, so are omitted from discussion
here.

PROCESS EMISSIONS

          Table 1 lists process emissions by source and type.  Emission
sources in this table are coded to indicate which were field-measured and
reported in the recent refinery study.

          The major sources of atmospheric process emissions are sulfur
recovery, regeneration of fluid catalytic cracker catalyst and process heaters
and boilers.   This section focuses on these sources.

          The major types of atmospheric process emissions from refineries
are hydrocarbons, sulfur oxides, particulates and carbon oxides.
                                    196

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.  R.  Phillips
            TABLE  1.   PROCESS EMISSIONS BY  SOURCE AND TYPE
 Source
Sulfur
Recovery
        a
Catalyst
Regeneration
(CO Boiler Vent)
           3,
Boilers and
Process Heaters

      b
Vacuum
Distillation
                       HC
X
X
X
X
X
                                             Emissions
                SO,
                                       X
X
X
Coking
b
Air Blowing
Chemical ,
Sweetening
Acid Treating
Slowdown
Compressor
Engines
X
X
X
X
X
X
X


X

X X
                CO  Aldehydes  NH3
                         X
X
X
                                                X
X
X
                               NOX
                X
                                                                        X
 Detailed results are  in Refinery Assessment Report.
  Emission not measured in this study.
                                     197

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W. R. Phillips
          Process heaters and boilers are used in a number of different
refinery processes.  Therefore, they will be discussed, not by process, but
collectively as a separate emission source.

Sulfur Recovery

          The amount of sulfur in various product streams depends directly
on the sulfur content of the crude oil.  As the oil is fractionated initially
sulfur tends to become more concentrated in the heavier cuts because of the
low volatility of its various compounds.  The sulfur content of crude can
vary from less than 0.1 weight percent to more than 5 weight percent.  Any
crude oil with more than 0.5 weight percent sulfur is generally considered to
be a sour crude and its products are subjected to sulfur removal processing.1
If not removed, the sulfur can cause corrosion, pollution and catalysis
problems during refining or when the products are used as fuel or as petro-
chemical feedstocks.

          Sulfur removal from whole crude is not generally economical.2
Intermediate stock streams routinely subjected to sulfur removal include the
outlet streams from crude distillation and cracking units.3  Sulfur components
in these streams are converted to hydrogen sulfide by hydro-processing with
hydrogen over a nickel-molybdenum catalyst at an elevated temperature.
Resulting H2S boils between ethane and propane, so must be selectively
removed from the sour gas stream and concentrated by one of several means,
the most common of which is absorption by monoethanolamine (MEA) or diethanol-
amine (DBA) followed by steam stripping.

          With increasing use of hydro-processing of ever increasing sulfur-
containing crude stocks, it has become environmentally and economically sound
to introduce a process for removal of EzS generated by hydro-processing.  The
Glaus process presently dominates.  Tail gas from a Glaus unit can be a major
source of SOa emissions in a refinery.  In the Glaus process, some H2S feed
is oxidized to form SOa and water.  Additional HzS reacts with 502 to form
elemental sulfur and water.

          Glaus unit tail gas contains H2S, SC>2, CS2, COS and Sx.  The
emission rates of these sulfur compounds depends on the concentration of the
HzS stream to the Glaus unit and the efficiency of the unit.  Tail gas from
a typical three-stage Glaus unit, 95 to 96 percent efficient, can be expected
to contain about 7000-12,000 parts per million by volume sulfur compounds. '*'5
The tail gas also contains carbon monoxide formed from small amounts of
hydrocarbons and carbon dioxide in the feed stream.  Typical compositions of
Glaus unit feed and product gases are found in Table 2.

Catalyst Regeneration

          Catalysts are used in several petroleum refining operations,
including fluid catalytic cracking, moving bed catalytic cracking  (known as
Thermofor catalytic cracking or TCC), catalytic hydrocracking, reforming, and
various oil desulfurizations.  These catalysts become coated with carbon and
                                     198

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W. R. Phillips
         TABLE 2.   TYPICAL COMPOSITIONS OF FEED STREAM AND TAIL CAS
                   FOR A 94 PERCENT EFFICIENT GLAUS UNITn
                                    Sour  Gas  Feed,            Glaus Tail Gas,
 Component                          Volume  Percent            Volume Percent
H2S
S02
Se Vapor
SB Aerosol
COS
CS2
CO
CO 2
02
N2
H2
H20
HC

Temperature, °F
Pressure, psig
89-9
0.0
0.0
0.0
0.0
0.0
0.0
4.6
0.0
0.0
0.0
5.5
0.0
100.0
104
6.6
                                                                   0.85
                                                                   0.42a
                                                                 0.10 as Si
                                                                 0.30 as Si
                                                                   0.05
                                                                   0.05
                                                                   0.22
                                                                   2.37
                                                                   0.00
                                                                  61.04
                                                                   1.60
                                                                  33.00
                                                                   0.00

                                                                 100.00
                                                                 284

                                                                   1.5

 Total Gas Volumeb                       -                      3.0 x feed
                                                               gas volume
 SNSPS requires an emission  of  less  than  250  ppmv  (0.025  percent) S02, zero
  02, dry basis if Claus unit  tail gas  is oxidized  last as a  control step,
  or, 300 ppmv S02 equivalent  reduced compounds  (H2S,  COS, CS2) and 10 ppm
  S02 if the tail gas  is reduced  as  the last  process  step.

  Gas volumes compared at  standard conditions.
                                      199

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W. R. Phillips
metals and must be regenerated to restore their activity.  During regeneration,
the carbon is oxidized to carbon monoxide and carbon dioxide and the hydro-
carbons are burned incompletely.

          In most applications, a catalyst must be regenerated only a few
times a year.  Emissions during these episodes may include catalyst fumes,
oil mist, hydrocarbons, ammonia, SOx, chlorides, cyanides, NOX, CO, and
aerosols.7  Though there may be significant emissions during the regeneration
of one of these catalysts, the total emissions over the course of the year
are not significant.

          Catalytic cracking catalyst regeneration is a continuous process.
Uncontrolled cracking catalyst regeneration is one of the major sources of
air pollution in a petroleum refinery.  Flue gases from catalytic cracker
regenerators contain particulates, SOX, carbon monoxide, hydrocarbons, NOX,
aldehydes and ammonia.

          Emission factors for uncontrolled regeneration of FCC and TCC
catalysts are reported in AP-42 and are listed here in Table 3.  These
factors are from a 1956 stack sampling survey of FCC and TCC units in Los
Angeles County.8  The survey involved six FCC units and nine TCC units.

          TABLE 3.  EMISSION FACTORS FOR UNCONTROLLED REGENERATION
                     OF THE CATALYTIC CRACKING CATALYST9

               _ Emission Factor, lb/1000 bbl Fresh Feed _
               Particu-   SOX as            Total      NOX as
 Process         late     SOa       CO   Hydrocarbon   NOa    Aldehydes  NH3
  Fluid Catalytic  242     493     13,700    220         71       19      54
  Cracking  (FCC)

  Moving Bed        17      60      3,800     87          5       12       6
  Catalytic
  Cracking  (TCC)
          These factors indicate that the uncontrolled emissions from FCC
units are several times greater than from TCC units.  The  term "uncontrolled
emission" here implies conventional regeneration without any external control.
Radian believes that these 1956 emission factors should be reviewed because
of advances in technology, especially the FCC particulates emission factor
(242) because of the following:

          1.   FCC regenerator cyclone technology has advanced since the 1956
               survey.  Catalyst losses from properly designed two-stage
               regenerator cyclone systems in the range of 80-100  lb/103 bbl
               of fresh feed are typical.
                                     200

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W.  R.  Phillips
          2.   Five  out  of  six of the FCC units surveyed in 1956 had emission
              factors of 50 lb/103  bbl fresh feed or less.  The sixth may
              have  been troubled by condensation at low stack temperature
              of  high concentrations of S03.  The individual emission factors
              were  181, 50,  43,  35, 27, and 24 (average:  60).

          3.   For several  of the TCC units in the survey,  emissions for the
              entire unit  were extrapolated from measurements made on one
              stack.  This method can produce errors, because TCC units
              employ several dissimilar stacks.

Boilers  and Process  Heaters

          Most refineries use steam boilers to provide steam for direct use
in various processes, for heating and for driving steam turbines.   Large
amounts  of steam are needed for light ends strippers, vacuum steam ejectors,
process  heat  exchangers  and reactors.  About 40 pounds of steam are required
by a typical  refinery per barrel of refining feed.  This steam demand requires
a boiler size of 53,000  Btu per barrel of refining feed.10   Some steam is also
generated in  waste heat  boilers,  the largest of which is, in some refineries,
a carbon monoxide  boiler used to control emissions from the regeneration of
the catalytic cracking catalyst.   Another carbon monoxide control technique
is high  temperature  catalyst regeneration at approximately  1300°F minimum.
Most process  steam generated is low pressure steam.

          Process  heaters are the largest combustion source of hydrocarbons
in a refinery.   Total process heater demand in a modern refinery is approxi-
mately 270,000 Btu per barrel of refining feed.  Older, less efficient
refineries may require 600,000 Btu per barrel of refining feed.11

          Refining boilers  and heaters are fired with the most available fuel,
usually  purchased  natural gas, refinery fuel gas (mostly methane), or residual
fuel oil.  Ordinarily, the  refinery gas supplies approximately one-half the
fuel needs; natural  gas  is  used in the summer months and residual oil in the
cooler months when natural  gas supplies go to preferred residential customers.
These estimates  vary with the individual refinery.  Emission factors for
burning  of natural gas and  residual fuel are found in Table 4. -

          In  addition to combustion emissions, there are also emissions
associated with  the  decoking of heaters.  At intervals of about  six months
to three years,  each heater must be flushed with a steam-air mixture to
remove interior  coke deposits.  Emissions are similar to those from decoking
operations on delayed coking units,  but less.

Existing Control Technology

          Most of  the process emissions described previously can be con-
trolled.   This section describes control methods that are now in use or
might be adapted to  refinery use.
                                     201

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W. R. Phillips
         TABLE 4.  EMISSIONS FROM REFINERY BOILERS AND HEATERS12

                                                   Fuel
                                   Natural Gas,                Fuel Oil,
  Pollutant                       lb/106 std ft3               lb/103 gal
Hydrocarbons (as


Particulates                           5-15


SOX as S02  '                            0.6b                     157


CO                                      17                          5


NOX as N02                           120-230d                      6Q6
 A function of fuel oil grade and sulfur content
     For Grade 6:  lb/103 gal = 10 S + 3
     For Grade 5:  10 lb/103 gal
     For Grade 4:  7 lb/103 gal

 Based on average sulfur content of natural gas of 2000 gr/106 Std Ft .
Q
 S equals percent by weight of sulfur in fuel.
 Uses first number for tangentially fired units, second for horizontally
 fired units.
p
 Strongly dependent on the fuel nitrogen content.
                                   202

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W. R. Phillips
          "Existing" controls included are  those considered to be in
relatively common usage in refining.  "Available" controls, which will be
discussed following this section, are those which have had only limited
application or which have not yet been applied.  Those controls which have
been used in other industries and which might be applicable to the refining
industry, are included in the section following available controls.

Sulfur Recovery

          The Glaus unit is the accepted method for sulfur removal in a
modern refinery.  However, because  it is not totally efficient in producing
elemental sulfur, it is a major source of emissions.  Much progress has been
made in recent years in the control of emissions from Glaus units.  This
discussion will consider first the  Glaus unit itself, then methods for
cleaning up the Glaus unit tail gas.  Incineration is an integral part of
several of these methods, so it is  discussed immediately after the Glaus
unit.

          More than 70 methods have been proposed for treatment of the Glaus
unit tail gas.    These methods may be continuations of the Glaus reaction or
add-on processes with chemistry quite different from that of the Glaus reac-
tion.  Incineration is sometimes used alone to clean Glaus unit tail gas,
sometimes to prepare the tail gas for further treatment, and sometimes after
that treatment.

The Glaus Process—

          The Glaus process is recognized as a very effective control device.
Since implementation of the Environmental Pollution Act in 1970, Glaus has
been used to remove sulfur from refinery process streams at an average
efficiency exceeding 95 percent.

          The overall Glaus reaction is as  follows:

          H2S 4- % 02 = ( — ) Sn + H20                                     (1)

where n represents the various molecular forms of sulfur vapor.  The two
most popular designs of Glaus units are illustrated in Figure 1.  In the
"once-through" design, the incoming H2S-rich stream is burned in a limited
amount of air to convert one-third  of the H2S to S02 according to the
following reaction:

          2H2S + 202 = S02 + S + 2H20                                    C2)

The hot gases from this reaction are then passed over a bauxite, alumina, or
cobalt-molybdenum catalyst, to react the sulfur dioxide with unburned H2S
according to the following reaction:
          2H2S + S02 = 3S +  2H20
                                                                          (3)
                                     203

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ACID [LAS
    AIR
                                                      FEED WATER
                                               CONDLNSERS
                                                   L.P. STEAK
                                                            gar
                                                                                TAIL  GAS
                                    1	»- LIQUID SULFUR

                                   STRAIGHT THROUGH CLAUS  PROCESS
                                                               SUITOR PIT
     ACID GAS t
                                                                              •>• TAIL GAS
                                                                 SULFUR PIT
                                             LIQUID SULFUR
                                       SPLIT now CLAUS PROCCSS

                            Figure  1.   The  Glaus Process.

                                            204

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W. R.  Phillips
If the  "split-stream",  or "by-pass", design is used, one-third of the incoming
stream  is  separated and burned more completely according to the following
reaction:

          H2S  + 3/202 =  S02 + H20

The remaining  H2S is reacted over a catalyst with the hot gas from the
furnace to form elemental sulfur according to reaction (3) above.

          The  "direct oxidation" design is for streams with lower concentra-
tions of H2S.   In this  design the incoming stream is preheated, mixed with
air, and then  passed over the bauxite or alumina catalyst.

          The  Glaus designs described above with one pass through the
catalytic  reactor convert 80 to 86 percent of the H2S to elemental sulfur.^ '1S
This efficiency can be  greatly enhanced by repeating the catalytic stage one
or more times.  Thus, two-stage Glaus units can achieve 92 to 95 percent
efficiency;  three stages, 95 to 96 percent; and four stages, 96 to 97 per-
cent.   Conversion is  ultimately limited by the reverse reaction.  Recovery
rates for  various feed  compositions are found in Table 5.

          These efficiencies, once considered sufficient, do not meet new
regulations.   Further treatment of. the Glaus unit tail gas is discussed in
succeeding sections.

Incineration of Glaus Unit Tail Gas—

          The  tail gas  from the Glaus unit is often  incinerated before it
either  passes  to the atmosphere or is subjected to further treatment.  This
incineration takes place at temperatures of about 1200°F or above in refrac-
tory-lined vessels with one or more burners.

          Auxiliary fuel such as natural gas or fuel oil provides the heat
necessary  for  incineration since the heating value of the tail gas is low.
Excess  air levels of 20 to 30 percent are used.

          The  objective of tail gas incineration is to convert all sulfur
compounds  in the tail gas to S02, but this conversion is incomplete.  Typical
compositions of a sour  gas feed stream and the corresponding Glaus unit tail
gas before and after incineration are given in Table 6.

Tail Gas Clean-Up—•

          Each of the six tail gas clean-up methods listed in Table 7 has
three or more  commercial installations to its credit.  The first three pro-
cesses—Amoco's CBA process, the Sulfreen process, and the IFF process—are
continuations  of the Glaus reaction under more favorable conditions.  The
second  three processes—the Beavon process, the SCOT process, and the Wellman-^
Lord process—are add-on units with higher efficiencies than the first three.
                                     205

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                   TABLE 5.   TYPICAL CLAUS  PLANT SULFUR RECOVERY  FOR  VARIOUS  FEED  COMPOSITIONS18
o
O\
Hydrogen Sulfide in Sulfur
Plant Feed (Dry Basis) , %
20
30
40
50
60
70
80
90

Two Reactors
92.7
93.1
93.5
93.9
94.4
94.7
95.0
95.3
Calculated Percentage Recovery3-
Three Reactors
93.8
94.4
94.8
95.3
95.7
96.1
96.4
96.6

Four Reactors
95.0
95.7
96.1
96.5
96.7
96.8
97.0
97.1
        o
         Assumes  1 mole  percent hydrocarbon contamination,  conventional temperatures and reheat techniques,

         average  organic by-products and entrainment allowance.
                                                                                                                     !*
                                                                                                                     >-ti

                                                                                                                     H-
                                                                                                                     M
                                                                                                                     M
                                                                                                                     H-
                                                                                                                     -d
                                                                                                                     en

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W. R. Phillips
     TABLE 6.  TYPICAL COMPOSITIONS OF FEED STREAM AND TAIL GAS STREAMS
           FROM A 94 PERCENT EFFICIENT GLAUS UNIT AND INCINERATOR19
Sour Gas Feed,
Component Volume Percent
H2S
SO 2
Se Vapor
SB Aerosol
COS
CS2
CO
C02
02
N2
H2
H20
HC
Temperature
°C
°F
Pressure
Kilopascals
Psig
Total Gas Volume3
89.9
0.0
0.0
0.0
0.0
0.0
0.0
4.6
0.0
0.0
0.0
5.5
0.0
100.0

40
104

150
6.6
-
Thermally Incinerated
Glaus Tail Gas, Tail Gas,
Volume Percent Volume Percent
0.85
0.42
0.10 as Si
0.30 as Si
0.05
0.05
0.22
2.37
0.00
61.04
1.60
33.00
0.00
100.00

140
284

110
1.5
3.0 x Feed
Gas Volume
0.001
0.89
0.00
0.00
0.02
0.01
0.10
1.45
7.39
71.07
0.50
18.57
0.00
100.00

400
752

100
0
5.8 x Feed
Gas Volume
  Gas volumes  compared  at  standard  conditions.
                                     207

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                         TABLE 7.   ESTABLISHED METHODS FOR REMOVAL OF SULFUR FROM GLAUS TAIL GAS
?c
to
o
00
Name
CBA





Sulf reen



IFP-1500


BSRP




SCOT


Wellman-
Lord


Developer
Amoco





SNPA/Lurgi



Institut
Francais
du Petrole
Ralph M.
Parsons &
Union Oil
Co. of
California
Shell


Wellman
Power Gas


Efficiency Cost (Percent Commercial
Description (Glaus + Add-on) Product of Glaus _ ,
Glaus reaction continued at 98-99.5 percent S0 50-150 3
low temperature; removal of 1500 ppmv S
condensed sulfur drives
reaction. Bed regenerated
with hot gas from Glaus
unit.
Glaus reaction continued at 99 percent S0 50-150 19
low temperature as in CBA. 1500-2000 ppm S
Bed regenerated with hot
nitrogen.
Glaus reaction occurs in a 1000-2000 ppm S So Variable 25
solvent.

a
All sulfur compounds reduced 250 ppm S or less So 100 36
to HaS which is processed
in a Stretford unit.


All sulfur compounds reduced 200-500 ppmv HaS Feed to 75-100 35
to HaS which is recycled to Glaus
Glaus.
S02 in incinerator gas 200 ppmv S02 NaSOi*/ 130-150 for 7
contacted with NaS03 to form NaS03 100 It/d
NaHSOa. NaSOs regenerated in Crystals Glaus unit
evaporator /crystallizer.
                                                                                                                          "S
        1Figure includes plants in operation, under construction or being designed.

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W. R.  Phillips
         These  six processes are discussed in more detail in Radian's
refinery  emissions  report.

FCCU Catalyst Regeneration

         Regeneration of the catalyst in fluid catalytic cracking units
(FCCU's)  produces three principal types of atmospheric emissions:   SOX,
particulates, and COX. • Lesser emissions include hydrocarbons, NOX, aldehydes,
and ammonia.  SOX is typically controlled by feedstock desulfurization;
particulates by  cyclones and electrostatic precipitators; and CO by a CO
boiler.   No single  process can control all three.

SOX Emissions—

         Hydrodesulfurization (HDS)  of feedstock to FCCU's has been
practiced for years, since it increases the yield of salable products.

         In HDS of FCCU feedstock, the ratio of weight percent sulfur in
the coke  over the weight percent sulfur in the desulfurized feedstock
increases with  the  degree of desulfurization.  The result is that  very high
levels of hydrodesulfurization are needed to achieve 90 percent or higher
reduction in SOX emissions.  For a feedstock with 2.3 weight percent sulfur,
for example, 92  to  95 percent desulfurization of the feed is necessary for
a 250 ppm SOX concentration in the flue gas.21

Particulates  (Catalyst Fines)—

         Before exiting the regenerator, gases pass through a series of
cyclones  that remove the small catalyst particles (fines) present  in the exit
gas.  Some refineries have additional cyclones downstream of the regenerator.

         Particles smaller than 5 microns are ordinarily not collected by
cyclones. The majority of refineries use electrostatic precipitators to
remove these catalyst fines from the flue gas.

         The collecting efficiency of ESP's for catalyst fines is commonly
99.5 percent of  the particles that escape the cyclones.22  In most cases,
final disposal  of the waste particles is by burial in a sanitary landfill.

CO Emissions—

         All methods of controlling the CO content of flue gas from FCC
regeneration involve combustion of CO to C02.  A typical unit with "conven-
tional" regeneration burns off the coke from spent catalyst to, roughly, a
50-50 mixture of CO and C02-

         The majority of refineries—66 percent in 1976— used a CO boiler
to recover part  of  the energy from hot FCCU flue gases and to reduce CO
emissions.23  The flue gas goes to the furnace of a CO boiler and external
heat is applied  to  raise the temperature high enough (vL300°F) to achieve
                                     209

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W. R. Phillips
near complete combustion (99.5 percent or more).  The heat  of  combustion is
recovered as steam, often used to drive the regenerator air blower as well
as for other refinery operations.

          In all but small refineries, the cost of CO boilers  can be recovered
in a few years.  Small refineries may find it more economical  to control CO
emissions with flares, even though no energy recovery is possible.

Other Catalyst Regeneration

          Because emissions from TCC catalyst regeneration  are significantly
less than those from FCCU catalyst regeneration, use of a CO boiler may not
be justified.  Flue gases from TCC catalyst regenerators are usually released
directly to' the atmosphere.

          Flue gases from other catalyst regenerations may  also be incinerated
in a process heater or flared, but use of these control methods is not wide-
spread because these emission sources are typically insignificant.

Control Technology Available in Refineries

          Controls with limited application and those which have not yet been
applied are included in this section.  Information available on new tech-
nologies is often limited.

          Controls chosen for inclusion in this section are those which have
been proposed for consideration by the industry.  Inclusion here merely indi-
cates that it is worthy of consideration, and not necessarily  a good choice.

Sulfur Recovery

          A number of alternatives to the Glaus method of sulfur removal
have been proposed in recent years.  Some are applicable only  to Claus tail
gas treatment, while others may be applied to other problem sulfur-bearing
streams as well.  Also being tested are one alternative to  the Claus unit
and an integrated Claus tail gas process.  These alternatives  would produce
no objectionable tail gas stream.  Tail gas treatment methods  are found in
Table 8.

UOP Sulfox Process2k

          The UOP Sulfox process is an alternative to the Claus process.
Initially, aqueous ammonia, instead of an amine solution, is used to scrub
H2S from refinery feed gas.  The ammonia is then scrubbed from the gas with
purified water.

          The rich solution is mixed with air and sour water and passed over
a catalyst.  Elemental sulfur is formed according to the following reaction:

          NH4HS + h 02 = S0 + H20 + NH3                                   (5)
                                    210

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TABLE 8.  AVAILABLE METHODS FOR REMOVAL  OF  SULFUR FROM GLAUS TAIL GAS
Name
IFP-15025
Cleanair26'27
9 fl
Trencor-M

Aqua-Glaus29'30

Sulf oxide31
Topsoe32
Developer
Institut
Franca is
du Petrole
Pritchard
Trentham

Stauffer

Alberta
Sulfur
Research,
Ltd.
SNPA/
Topsoe
Efficiency or
Description Outlet Concentration
Gas from IFP-1500 scrubbed <200 ppm S02
with ammonia; S02-laden
ammonia mixed with H2S in a
glycol to form elemental
sulfur and water.
Glaus reactors operated at 50 ppmv S
high temperature to reduce
COS and CS2 levels; S02 and
elemental sulfur removed by
aqueous scrubbing; H2S
removed by Stretford Process.
All sulfur compounds reduced 100-200 ppmv S02
to H2S. H2S absorbed by
amine solution and returned
to Glaus.
S02 from incinerator mixed <100 ppmv S02
with H2S-rich Glaus feed;
Glaus reaction occurs in
aqueous phase.
Glaus reaction occurs in an <1000 ppmv S,
organic sulfoxide medium. Typically
<500 ppmv S
S02 from incinerator 90 Percent
oxidized to SO 3 which is
converted to H2SOij.
Cost (Percent
Product of Glaus)
So Variable
S0 100
Feed to 150
Glaus

So 125-135
Na2S04

S0 Not
Available
H2SOit Not
Available
                                                                                                 D"
                                                                                                 H-
                                                                  Continued

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TABLE 8.  Continued
Name
SFGD 3 3 ' 3 4
Westvaco35'36
Ammonium
Bisulfate/
Ammonium
Thiosulfate37
BSR/
Selectox I38
Limestone
Slurry39
Catalytic
Incineration
Efficiency or
Developer Description Outlet Concentration
Shell SOa in gas from incinerator 90 Percent
absorbed by CuO bed which is
regenerated with hydrogen.
Westvaco S02 in gas from incinerator <200 ppmv S02
removed and catalyzed to
H~2SOit in activated carbon
bed which is regenerated
with HaS.
Pritchard SO 2 in gas from incinerator <900 ppmv SOa
absorbed in aqueous ammonia
and converted to ammonium
thiosulfate.
Union Oil All sulfur compounds reduced >98 Percent
to HaS which is then
oxidized to S.
Mineral & S02 in incinerator gas >99.9 Percent
Chemical absorbed by limestone
Resource slurry.
Company
Institut Catalyst promotes oxidation <200 ppmv S
Francais of sulfur compounds to SOa
Cost (Percent
Product of Glaus)
Feed to
Glaus
So or
Feed to
Glaus
Ammonium
Thiosulfate
So
CaS03/
limestone
solids
SO 2
250
Not
Available
75
<200
Not
Available
Not
Available
                                                                        •a
                                                                         en

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W. R.  Phillips
With ammonia and sulfide present, the elemental sulfur remains in solution
as polysulfide.   The liquid product from this reaction is then heated above
the melting point of sulfur, mixed with air, and passed over a second catalyst
where any remaining sulfide is oxidized to elemental sulfur.  With no sulfide
remaining to solubilize the sulfur as polysulfide, the sulfur exists as a
separate molten product.

          Tail gas is scrubbed with water to remove ammonia.  Hydrogen
sulfide content in the treated gas is 10 to 100 ppm.  Although it is possible
to design a Sulfox unit which will achieve 1 ppm HaS in the tail gas, the
new source performance standard requires only 250 ppmv S02 or less from a
final oxidizing step.

          Capital costs for a Sulfox system and a Glaus unit are approximately
equivalent, not including the cost of tail gas cleaning.  Sulfox utility costs
are approximately 60 percent of those of a Glaus unit.

Union Carbide UCAP Process41

          This newly publicized integrated Glaus/tail gas treatment process
requires only one Glaus reactor stage to achieve the NSPS requirement of less
than 250 ppmv of SOa.  The process converts HzS to SC-2, absorbs it in tri-
ethanolamine and recycles the S02 to the Glaus unit.  Economics are not yet
available.  The process appears to be a strong candidate for new integrated
plant installations.

Catalyst Regeneration

          SOX emissions may be controlled by flue gas scrubbing systems.
Exxon presently operates four such scrubber systems installed in its coastal
refineries in Texas, Louisiana and New Jersey.

          Exxon's operations have shown that 95 percent of the SOx and 90
percent of the particulates can be removed by a scrubber.^  They believe
that the cost of controlling both particulates and SOX by scrubbing is less
costly both in initial investment and maintenance than a combination of
desulfurization and ESP's.  The space requirements are also less.

          The scrubbers may be the once-through or regenerable type.  A non-
regenerable process has been used for FCCU flue gas, and the resulting spent
scrubbing liquid is handled by conventional wastewater treatment.  It
contains a high concentration of dissolved solids and salts and has a high
chemical oxygen demand (COD).  To date, scrubbers for controlling SOX from
FCC regeneration have been used only where wastewater can be discharged into
the ocean after treatment.  A 50,000 bbl/d FCCU charging a feed with 2^weight
percent sulfur would generate as much as 60-70 tons of sludge per day.
                                     213

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W. R. Phillips
Boilers and Process Heaters—SOx Removal

          Emissions of SOX from boilers and process heaters can be minimized
by routing the flue gas to an integrated sulfur removal facility.  Post-
combustion removal of SOx from boiler and heater flue gases using an inte-
grated collection system of course poses serious safety and economic barriers.
Pre-startup firebox purging would be extremely difficult and time consuming.
Cost of ducting would probably be economically prohibitive.  Two such units
are. the IFP-150 and the Aqua-Glaus process described in Table 8.

NOX Removal

          NOX emissions may be reduced in the tail gas by any of three
methods.  These methods are 1) gas scrubbing, 2) catalytic reduction, and
3) thermal reduction with added ammonia.  Post-combustion NOX removal tends
to be more expensive than combustion modification because of the high tem-
perature of the gas, the low NOX concentration, interference from other
pollutants, and high power consumption.  Only thermal reduction appears
economically promising."*"*

          Controlled addition of ammonia and oxygen containing flue gas under
strictly controlled conditions at 1300 to 1900°F can selectively reduce
50 to 70 percent of the NOX remaining after combustion.  This "thermal denox"
process is a balance between two gas-phase reactions:  ammonia reduces NO to
N2 in the presence of the oxygen in the flue gas and ammonia is simultaneously
oxidized to NO.  When conditions are carefully controlled, a major portion of
the NOX can be reduced with little ammonia left over.  This process is more
expensive than combustion modification but can supplement these modifications
should stricter control of NOX be required.

Control Technology from Other Industries

          Control methods developed primarily for other industries can also
be used in the petroleum refining industry with some degree of adaptation.
This is especially true of methods developed by the electric utility industry
for flue gas desulfurization.  Some can be applied to the flue gas from a
Claus incinerator; another with accompanying NOX control can be adapted to
the flue gases from process heaters; still others might be used to control
sulfur emissions from FCC regenerators.

Sulfur Recovery

          Table 9 outlines several sulfur recovery processes from other
industries which might be adapted to Claus tail gas sulfur recovery.  These
sulfur recovery processes are described in greater detail in Radian's refinery
emissions report.  They do not uniformly meet NSPS for S02 emission.
                                      214

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        TABLE 9.  POTENTIAL GLAUS TAIL GAS SULFUR RECOVERY PROCESSES FROM OTHER  INDUSTRIES
           Process
                                      Characteristics
H2S or S02
 Removal
   (%)
                                                  Treated Flue Gas
                                                  S02 Concentration
                                                         (ppmv)
                                                                                                             H-
                                                                                                             T)
                                                                                                             cn
Chiyoda Thoroughbred 101
USBM Citrate
            46
Townsend1*7'"*8
Lucas49'50
Takahak
        5 I
Gypsum product.

Elemental sulfur product;
capital = 250 percent of
Glaus cost.  Not
commercialized.

Elemental sulfur product.
Does not remove CS2.   Not
commercialized.

S02 product is recycled.
Capital = 57-80 percent
of Glaus cost.  Semi-
commercial .

Elemental sulfur product.
Allegedly low capital cost.
 97   (S02)

      (S02)
                                                                                         >500
                                                                      (H2S)
                                                                      (S02)
                                                               ^99.9  (H2S)
                          200
                     (+ COS, CS2)

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W. R. Phillips
Catalyst Regeneration

          Several FGD methods used by the utility industry have been proposed
for use on FCC regenerators.5   In addition to the ones described below are
some of the regenerable processes touched on earlier, as applicable for
treatment of the Glaus unit tail gas.  One of the processes described below
simultaneously removes SOX and particulates from the flue gas.

The Lime/Limestone Flue Gas Desulfurization Process53—

          Lime or limestone flue gas desulfurization processes are the most
widely used FGD systems.  The systems are very similar; they consume large
quantities of feed material and produce large quantities of waste sludge, but
have relatively low operating costs and are highly reliable.  An S02 removal
efficiency of greater than 90 percent has been demonstrated.

          The economics of large lime/limestone FGD systems has been treated
in great detail.51*

The Dual Alkali Flue Gas Desulfurization Process55—

          The dual alkali (or double alkali) flue gas desulfurization process
can be used to overcome the scaling problem inherent in lime/limestone FGD
systems while retaining the convenience of solid waste disposal.  There are
53 operating dual alkali systems in the United States and Japan; several more
are under construction.

          These systems can achieve SO2 removal efficiencies of greater than
90 percent.  The capacity for more than 99 percent removal of S02 has been
demonstrated.  The dual alkali process itself is capable of greater than
98 percent particle removal.

          Dual alkali systems are economically competitive with lime/limestone
systems; however, a larger disposal area will be required than for a lime/
limestone system because of the higher moisture content of dual alkali sludge.

Boilers and Process Heaters

          The Shell flue gas desulfurization process (SFGD) can be used to
remove SOx and NOx simultaneously from all stack gas in process heaters,
providing they can be collected and sent to one or two stacks.  The SFGD
process can also be used to remove sulfur from the vent of fluid cat crackers,
as well as from Glaus units.56'57'58

          The Shell flue gas treatment process has demonstrated S02 and NOx
removal efficiencies of greater than 90 percent.  The efficiency of the
system is not affected by variations in the SOa or NOX concentration.  Costs
for an integrated SFGD system are not available, because such a system has
not yet been built at a U.S. installation.
                                      216

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Wi  R. Phillips
         The processes proposed for control of  SOz  emission from FCCU
regenerators may possibly be applied to flue gases  from boilers and process
heaters as well as from a Glaus unit.

Emission Reduction Through Alternative Operating Practices and Conditions

         Refinery operations are routinely modified to meet product speci-
fication requirements, product marketing  trends, feedstock availability
constraints, and operating cost goals.  The operating choices made include
both deliberate actions concerning processing alternatives (such as which
catalyst to use or which cut point to pick) and  more subtle actions, mainly
in the energy conservation areas (such as attention  to steam leaks or furnace
efficiency).  These choices can also affect the  overall refinery emissions.

         This subsection summarizes the  effects on  emissions of some of
these alternative operating practices.
High Temperature FCCU Catalyst Regeneration
                                           59>60>61>62jG3
         In older FCCU regenerators,  the highly  exothermic oxidation of  CO
to COz is avoided because the resulting high  temperature can damage regenera-
tor equipment, permanently deactivate  the catalyst,  and damage downstream
equipment.  To avoid this oxidation, the flue gas from the regenerator
generally contains little oxygen and large, nearly equal,  amounts  of CO and
C02.

         With high temperature regeneration, coke is  burned from  the catalyst
more efficiently, therefore yield from the FCC unit is increased.   The carbon
monoxide level in the exit gas from the regenerator can be reduced to well
below 500 ppm; in many instances a CO  boiler  is no longer  necessary for
emission control.  Because the catalyst to the FCC unit is hotter, preheat  of
the feed to the unit may not be necessary.   (Five hundred  ppm of CO corre-
sponds to the NSPS limit.)

         Several new catalysts, or promoters, have been introduced in the
last several years to promote the combustion  of CO to  C02.  A promoter may
be chosen to promote complete combustion or partial combustion where
metallurgy cannot withstand the higher temperatures.   Partial combustion  can
also  be used in situations where the CO is needed as fuel.

         One type of noble metal promoter is made part of the catalyst
recipe.  A second type is a liquid injected  into  the regenerator combination
zone.  The third is a solid added to makeup catalyst.

         In situations where partial  combustion  is needed, it is  possible
to combine high temperature regeneration with the CO boiler.  For  this
combined operation, the degree of high-temperature regeneration, and the
final temperature, can be controlled by the amount of  promoter used.
Higher regenerator outlet temperature  partially compensates for the
reduced quantity of CO reaching the CO boiler. Supplemental fuel  to
                                     217

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W. R. Phillips
the boiler is still required, but its cost is offset by the  increased product
yields in the FCC unit.

          In 1975, the cost of converting a relatively modern FCCU with
stainless steel cyclones to high-temperature regeneration was $50,000 to
$300,000.  Cost of a CO boiler for the unit was perhaps $2 million to $3
million.

SOX Removal in the FCC Regenerator

          Amoco has developed a catalyst which prevents sulfur from leaving
the regenerator as SOa-  The catalyst holds the sulfur until it is returned
to the reactor, where it is released and converted to H2S.  The H2S leaves
the reactor with the cracked product and is later converted to sulfur in the
Glaus plant; the regenerated catalyst returns to the regenerator.

          Cost for a 60-75 percent reduction in SOx emissions with this
method in a new facility is estimated at $0.03/bbl, compared to $0.22-0.24/
bbl for stack-gas scrubbing and up to $0.27/bbl for feed hydrodesulfurization.
The use of the catalyst for SOX control is also less expensive than other
methods in retrofit applications.

Combustion Modification for Control of N0x61f'65'66

          Of the oxides of nitrogen, only NO and NOa are of environmental
concern.  In combustion sources, NO may be produced either by the fixation
of atmospheric nitrogen in the flame (thermal NOx) or by the oxidation of a
portion of the nitrogen in the fuel (fuel NOX).  N02 from combustion sources
is produced as the NO combines with oxygen in the atmosphere.  Refining
sources of thermal NOX and fuel NOX are given in Table 10.

          A number of specific combustion modifications for NOX control have
been devised.  Those for refinery boilers are summarized in Table 11.  Com-
binations of these methods have been shown to yield a smaller effect than
the sums of the effects from the individual technologies.  The effectiveness
of some of the individual methods and some combinations at different boiler
loads are shown in Table 12.

          The subject of combustion modification is covered  in greater detail
in the refinery emissions report.

CONTROL OF FUGITIVE EMISSIONS

Sources of Fugitive Emissions

Sources Tested in This Study

          The hydrocarbon (HC) emission factors developed in this study  for
valves, flanges, pump seals, compressor seals, drains and relief valves  have
reasonable confidence limits.  Confidence limits for oil-water separator and
                                     218

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  W. R.  Phillips
          TABLE 10.   REFINING SOURCES OF THERMAL NOX AND FUEL
             N0>
Classification
High Temperature


Internal
Combustion
Moderate
'•""- 	 	 .-,-,
Source
Power boilers
firing - gas
Power boilers
firing - oil
Power boilers
firing - coal
Engines
Turbines
CO boilers
	 . ^
Thermal
NO
X
Present
Present
Present
Present
Strong
Present
	 ~ ' ~ •
Fuel
NO
X
Possible
Present
Strong
Unlikely
Possible
Present
Temperature
                      Coke and  residual
                      fuels

                      Catalyst
Present
Present
regeneration
Incineration
Process Heating
Gas cracking
Oil cracking
Oil heating
Unlikely
Present
Present
Unlikely
Unlikely
Present
Present
Possible
Possible
Possible
                                  219

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   W. R.  Phillips
   TABLE 11.  BOILER COMBUSTION MODIFICATIONS FOR REDUCTION  OF NOx EMISSIONS
        METHOD
      EFFECTS
    GAS FIRED
      UNITS
   OIL FIRED
     UNITS
                         Rating

                         Advantages
 Low excess air
                        Disadvantages
                   Good

                   Improved effi-
                   ciency; less
                   power
                   More complex ducts
                   and controls
                     Good

                     Improved effi-
                     ciency; less
                     power; less
                     chance of cold
                     end deposits

                     More complex
                     ducts and
                     controls
 Flue  gas
 recirculation
 Rating

 Advantages



 Disadvantages
 Excellent

 Very  effective;
 does  not upset
 combustion

 High  initial
 cost; high  operat-
 ing cost; addi-
 tional controls
 Good

 In moderation
 does not  upset
 combustion

 High initial
 cost;  high
 operating cost;
 additional con-
 trols; works
 mainly on
 thermal NO.
Staged combustion

   Two-stage
   combustion with
   over-fire air
   ports
Rating

Advantages



Disadvantages
                                          Excellent

                                          Inexpensive;
                                          very effective
Longer flames;
slight increase
in excess air
Very good

Inexpensive;
moderately
effective

Longer flames;
slight increase
in excess air
                                                        (Continued)
                                     220

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     W.  R. Phillips
                              TABLE 11.  Continued
       METHOD
   EFFECTS
   GAS -FIRED
    UNITS
   OIL FIRED
     UNITS
 Staged  combustion
    (Cont'd)

    Off-stoichioroetric
    or Biased firing
 Rating

 Advantages



 Disadvantages
Very  good

No power;
effective
                                           Slightly longer
                                           flames; small
                                           increase in
                                           excess air
                         Disadvantages
                  Reduced unit
                  efficiency;
                  require equipment
Good

No  power;
moderately
effective

Slightly longer
flames; small
increase in
excess air

Direct cooling
Lower preheat or
Water injection
Rating
Advantages
Fair
Simple; no
power
Fair
Simple; no
power
                    Reduced unit
                    efficiency;
                    require equipment
Reduced load or
Oversized fire box
Rating

Advantages


Disadvantages
Very good

Simple; no power
                                           High initial
                                           cost
Very good

Simple; no
power

High initial
cost; more
radiant super-
heater
                         Rating

Burner modifications      Advantages


                         Disadvantages
                  Good

                  Simple; no power


                  None
                    Very good

                    Simple; no
                    power

                    None
                                       221

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        TABLE 12.   REDUCTIONS  OF NOV EMISSIONS WITH COMBUSTION MODIFICATIONS AT VARIOUS BOILER  LOADS67
Combustion
Modification
(Percent Full Load)
Fuel Burner
Fired Arrangement
Gas Front Wall
Horizontally
Opposed
Tangential
Average
to
N3
Oil Front Wall
Horizontally
Opposed
Tangential
Average
Percent Reduction in NOX Emissions
Low
85/105
13

17
-
16


27

10
28
19
Excess
60/85
24

15
-
19


20

16
22
19
Air Staging
50/60 85/105 60/85
7 37 30

32 54 35
- -
26 45 31


28 29 20

12 34 34
17
18 30 22
Low Excess Air Flue. Gas Possible Combined
and Staging Recirculation Modifications
50/60 85/105 60/85 50/60 85/105 60/85
30 48 42 36 - -

59 61 48 68 -
- - - 60
52 54 44 52 - 60


20 39 32 21 46 31

47 35 44 42 -
45 10 13
34 38 37 37 28 23
50/60 85/105
43

20 73
66
20 64


50

38
-
47
60/85
42

52
65
51


41

35
59
42
50/60
36

72
-
60


21

55
--
38
                                                                                                                     1-1
Possible combination of modifications on the boilers tested.

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W. R. Phillips
cooling tower emission factors were considerably broader; as a result, data
from other sources have been substituted  in Table  13  for  results  from'the
latter two systems.

Relative Importance of Fugitive Emission  Sources

          Table 13 lists emitting sources  in refineries.  All the types of
emission sources listed were field-monitored except for numerically rare
items or those sources otherwise deemed insignificant.  Table 14 ranks the
eight most important emission sources according to the total estimated HC
losses from a hypothetical refinery.68  Emission factors are compared to
current literature values.  Results show  that process valves are typically
the largest fugitive emission source because of their great number in the
refinery.

          The oil-water separator is ranked second in importance in fugitive
hydrocarbon emissions based upon previous  work  (see Table 14 footnotes).
Additional field measurements and/or improved analytical techniques may be
required to obtain satisfactory confidence limits  for separator emission
factors because of the variability of waste oil vapor pressures, composition,
rates, wind effects, etc. from day to day  and from refinery to refinery.
Controlled testing of a covered simulated  separator gave results which would
lower the estimated emission from the AP-42 based  value of 110.5 Ib/hr to
  20.6 Ib/hr.69

          Cooling towers are also temporarily ranked high in HC emissions.
The broad emission factor confidence limits found may be a result of real
differences among cooling towers tested, or may reflect analytical imprecision
resulting from having to analyze water-dissolved hydrocarbons in the 1-5 ppm
range.  Additional field work in this area may be justified.

          Pump and compressor seal emission factors are averages for their
respective arrays, as listed in Table 13.  Types include packed gland,
mechanical face, labyrinth and oil seals,  for both rotary and reciprocating
shaft types, where applicable.  There were an average of about 1.4 seals per
pump in the refineries surveyed, and 2.0  seals per compressor.

          The emission factor for equipment drains is a useful addition to
the literature (0.070 lb/(hr-drain)) because no other factor has been avail-
able except in combination with one for oil-water  separators.

          Pipe flanges constitute the next to smallest fugitive emission
source, even with the largest estimated total number of devices.  The emis-
sion factor is 0.00058 lb/(hr-flange).

          Relief valves contribute the least total HC emission, because of
their relatively small number, but have a  significant emission factor  (0.190
lb/(hr-relief valve).
                                     223

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W. R. Phillips
                   TABLE 13.  FUGITIVE EMISSION SOURCES
                                            Number        Estimated Total
                                              of            Emissions, a
     System or Device                       Devices           Ib/hr

Process Piping System
   Valves                                   11,650            289.50
   Flanges                                  46,520             26.98
Safety Relief Valves                           106             20.14
Agitator Seals (Hydraulic, lip,                   Not Measured
   packed, mechanical)
Pump Seals                                     353C            57.63
   Rotaty Shaft
      Mechanical Face
      Packed Gland
   Reciprocating Shaft
      Packed Gland
Compressor Seals                                68             45.46
   Rotary Shaft
      Labyrinth
      Oil
      Mechanical Face
   Reciprocating Shaft
      Packed Gland
Water Systems
Wastewater Systems
   Drains - Process and Storm                  647             45.29
   Primary Treatment - API separator,            1             21e
      CPIe (covered)
   Intermediate Treatment - Air         Air Flot. Units tested; results
      flotation, holding basin            statistically inconclusive
   Secondary Treatment - Biological                 Not Tested
      oxidation processes
   Tertiary Treatment - Carbon
      absorption, filtration, ion
      exchange, reverse osmosis
Cooling Water System - Cooling Towers           V5a           113.3
Solid Waste System Alternatives                     Not Tested
   Land Farming                             1 Site              Og

Total Fugitive HC Emissions, Ib/hr                            618.3
                             (Ib/bbl feed)                   (0.045)

*3
 Estimated from data in Reference 71.
 Basis:   330,000 BCD hypothetical refinery, Reference 72.
 Basis:   1.4 seals (Av.) per pump, Reference 73.
 Basis:   2.0 seals (Av.) per compressor, Reference 74.
p
 Data from Reference 69.
 Based on 6 Ib HC/106 gal H20 (Reference 76) and 0.954 gpm circ. 4- B/D crude
 feed (Reference 77).
^Reference 78.

                                      224

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TABLE 14. FUGITIVE AIR EMISSION
Item
(Device or System)
Process Valves
^•1 TT ^ *. Uncovered
Oil-Water Separator ,
Covered
Cooling Towers
Pump Seals
Compressor Seals
Drains
Pipe Flanges
Relief Valves
This Study
Total HC
Emission, Ib/hr
289.5
178
20.6
2.04g'h
57.63
45.46
45.29
26.98
20.14

RANKINGS

Number
of Items
11,650
1
1
5d
353
68
647
46,520
106

- HYPOTHETICAL 330
Emission
This Study
0.0248
12.9 lb/103 bbl1
1.5 lb/103 bbl1
0.408
0.163
0.669
0.070
0.000580f
0.190

,000 B/D REFINERY
Factor, Ib/hr-item
Other Source
0.00625a
252 -lb/103 bblk'C>1
9.6 lb/103 bbl b'c'1
22.7b'd
0.175a
0.354a
N/A
0.006256
o.ioo6
Si
, R. Phillips







 Reference 79.
 Reference 80.
/-*
"Reference 81.
 Reference 82.
""Reference 83.
 The pipe flange emission factor is in units of Ib/hr-flange pair.
"Based upon purge method.
 Equivalent to 0.108 and 12.4 Ib HC/106 gal C.W. circulation and 0.954 gpm circulation of  C.W./
.B/D crude oil feed.
"""Bbl implies  bbl of refinery crude oil feed.

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W. R. Phillips
Control Technology - Fugitive Emissions

Process Valves

Existing Levels of Control in Refineries:  Process Valves—
Types of Valves—Process valve technology, per se, will not be covered here;
instead, the focus will be on valve seals.  Excellent recent valve technology
review articles are available; one such is recommended.    With the exception
of the check, plug, and diaphragm valve, valves are generally equipped with
packed stem seals to prevent the working fluid from leaking to the atmosphere.

Packed Stem Seals—Figure 2 is a simplified diagram of the type of packed
seal used for valve stems.  In practice, the stuffing box is filled with
rings of one or more types of compliant packing material.  The packing gland
is gently forced against the packing by tightening the bolts or studs
connecting the packing gland to the stuffing box flange (bolts not shown).
Upon being compressed, the packing material is forced against the stem or
shaft, forming a snug seal face (see figure).  This concentric contact seals
the working fluid from the atmosphere.
                                 -Stuffing
                                    Box
              Working
              Fluid
              End
L-     Spal Far^
                        Stuffing Box
                           Flange
                                                      Packing
                                                      Gland
                                                    Possible
                                                    Leak
                                                    Areas
                                   Packing
                       Figure 2.  Simple packed seal.
                                     226

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W. R.  Phillips
Packing Materials—Table 15 shows the diversity of materials used alone or in
combination.85  The following trends in packings have been noted:

               Asbestos packing may continue to be used in high temperature
               service, especially with metal wire core, but is being
               displaced by TFE, TFE-filled glass fibers, etc., up to about
               450-500°F (TFE = "Teflon"®).

               Graphite "ribbon" packing, which may be die-formed or formed
               in the stuffing box, is currently used in high temperature,
               high pressure service up to 4000 psi and 1200°F.

Control Valve Packings (High Temperature Steam Service)—One investigator
reported poor results using ribbon graphite packing alone.  The sliding stem
of the control valve, after gland tightening, was roughened, friction was
excessive,  and after as few as 800 cycles, leakage exceeded the target limit
of 0.5 cc/hr for a 0.5 in diameter stem.85  By sandwiching laminated rings
of graphite packing between layers of braided graphite filament packing, the
former acting to control fluid loss parallel to, and along, the stem, and the
latter acting to polish the stem, the life of the packing was extended to
over 47,000 cycles before leakage exceeded 0.5 cc/hr.  This cycle endurance
is roughly equivalent to the mechanical life of many valves, so such a valve
might never require repacking of the stem.87

Frequency of Application:  Valves—

Process Valve Types—Table 16 lists the approximate distribution of Battery
Limits refinery valves within two broad categories (manual and control) and
by valve'configuration.  Radian's battery limits survey shows that 86 percent
of all manual valves are gate valves, and 92 percent of the control valves
are globe-type.  The nine-refinery survey shows that these two categories,
manual gate valves and controlled globe valves, make up 88 percent of all
refinery valves.

Packed Seals—Radian's refinery observations further showed that all the
gate-, globe- and butterfly valves catalogued had packed-gland stem seals.
These packed-stem valves constitute an estimated 94.2 percent of the process
valve population.  On the basis of emission factors found in Table 14, it can
be shown that, on the average, 95.5 percent of the total emission from a
flanged in-line valve will be from the packing gland, and only 4.5 percent
from the two flanges.  Hence, the emphasis in valve emission control for
existing valves must be to select proper monitoring, operating, and mainte-
nance schedules and procedures, as well as suitable packings, for the packed-
stem seals.

Effectiveness of Existing Levels of Control:  Valves—

Factors Affecting Emission Rate—An established plant with a valve emission
problem will seldom in practice solve it by changing the fluid conditions
or the valve type.  The valve originally selected will instead have been
                                    227

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                                TABLE 15.  PACKING MATERIALS - PROCESS VALVES
                                                                            68
              Packing Material
        Form
  Used For
 Temperature
OS
      Flexible, all metallic
      Flexible metallic packings
      (aluminum).
       Flexible  metallic  packing  (copper).
       Long-fiber pure asbestos and fine
       lubricating graphite (nonmetallic),

       Closely braided asbestos yarn, top
       jacket reinforced with Inconel
       wire; core: long fiber asbestos.

       Pure asbestos yarn with an Inconel
       wire insert around a resilient
       asbestos core impregnated with
       graphite.

       Twisted long fiber Canadian
       asbestos.
Spiral wrapping.   Thin
ribbons of soft babbit
foil.

Spiral wrapping.   Thin
ribbons of soft annealed
aluminum foil loosely
around a small core of
pure dry asbestos.

Soft annealed copper
foil loosely around a
small  core of pure dry
asbestos.

Graphite  special  long-
fiber  asbestos binder.

Spools,  die-formed
rings.
 Spool form,  die formed.
 Spool form, die formed.
Valve stem
Hot oil valves,
diphenyl valves,
Up to 450°F.
Up to 1000°F,
Hot oil valves,    Up  to  1000'F,
diphenyl valves.
 Extreme
 resilience.
 Up to 7508F.
 High-temperature   Up to 1200eF.
 valves.
 Valve stem for     Stuffing box
 air, water steam   temperature up
 and mineral oil.   to 1200°F,
 Valves handling,
 high and low
 pressure steam.
 Up  to  500'F,
                                                                                                               T)
                                                                                                               cn
                                                                                           (Continued)

-------
                                      TABLE 15.  Continued
        Packing Material
        Form
  Used For
Temperature
Asbestos, graphite and oilproof
binder.

Solid, braided TFE.
Braided asbestos with complete
impregnation of TFE.
 Braided  of  high  quality wire-
 inserted asbestos  over a  loose
 core of  graphite and  asbestos.

 Braided  of  high quality wire-
 inserted asbestos over  a  loose
 core of  graphite.

 Braided of long-fiber Canadian
 asbestos yarn each strand impreg-
 nated with heat-resistant lubricant.

 Long-fiber Canadian asbestos yarn,
 each strand  treated with a synthe-
 tic oilproof binder and  impreg-
 nated with dry  graphite,
Spool form,  die formed,
Coil, spool, ring.
Coil, spool, ring.
Coils, spools,
 Coils,  spools.
 Coils,  spools.
 Coils,  spools,
Shutoff valves.    Up to 550eF.
Valve shaft for    100°F to  500°F.
highly corrosive
service.

Valve stems in     100°F to  600°F.
mild chemical or
solvent service.
Valve stems,
steam, air,
mineral oil.
Up to 1200"F.
 Stainless-steel     Up  to  12008F.
 valve  stems,  air,
 steam, water.

 Valves for  steam,   Up  to  550°F.
 air,  gas  and  mild
 chemicals.

 Refinery  valves.    To  750°F.
                                                                                     (Continued)

-------
                                             TABLE 15.   Continued
to
O
              Packing Material
                                             Form
       Braided/ovetbraided, wire-
       inserted, white asbestos packing
       impregnated with a heat-resistant
       lubricant.

       Braided white asbestos yarn
       impregnated with TFE suspensoid.

       Braided or bleached TFE multi-
       filament  yarn.
Braided TFE multifilament yarn
impregnated with TFE suspensoid.
        Asbestos  jacket,  braided  over  a
        dry-lubricated plastic core of
        asbestos  graphite and elastomers.
                                     Coils, spools.
Coils,  spools.


Spools, coils.



Spools, coils.
                            Used For
                    Temperature
                                      Spools and coils.
Valve stems, for
valves handling
steam, air, gas
cresylic acid.

Valve stems.
                                             Up  to  750°F.
                                                                                   1008F  to  600°F,
Valve stems for     12°F  to  506°F.
highly corrosive
liquids.

Valve stems for     120°F to 600°F.
corrosive  chemi-
cals, solvents,
gases.

Valve  stems,  for    Up to 850"F.
valves  handling
 superheated steam,
 hot gases.
IT)
ff
H-
I—•
t—'
H-
K

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         TABLE 16.  APPROXIMATE DISTRIBUTION OF REFINERY PROCESS VALVES3                         ^
                   BY TYPE AND SERVICE                                                     H-
Service
Type Valve
Gate
Globe
Plug
Butterfly
Diaphragm
Total
Manual
64.7
3.8
5.7
0.6
• o.o
74.8
Control
0.0
23.3
0.0
1.8
0.1
25.2
Total
64.7
27.0
5.7
2.5
0.1
100.0
'Check  and sample  system valves  excluded.   No dry-service slide
 valves surveyed  (Radian statistical survey basis).

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W. R. Phillips
chosen to fit the fluid flow conditions.   It will further have been based
upon economy of operation and safety in accordance with API code.  The
latter factor of safety, particularly with regard to potential failure in
a fire, cannot be overemphasized.

          Actions most apt to be used to solve or attenuate leakage, listed
in increasing order of cost, are as follows:

          1)   Tighten packing gland;

          2)   Lubricate lantern ring (packed stem valve) or plug (plug
               valve);

          3)   Replace or change type of packing;

          4)   Replace or change type of valve.

Operations/Maintenance Cooperation—Many companies require operating
personnel to check all major equipment once per shift or per day for leaks
for purposes of economy and safety.  Tightening and lubricating valves is
routine.

          Replacing valve packing is considered routine even though not all
maintenance personnel are skilled at it.   A change in type of packing materials
is not generally costly.  The cost breakdown for machinery packing (probably
                                                    " - -	 - ' iT
a pump) outage is:

               Item                                 Percent of Cost

          Packing Material                                  3
          Labor to Pack                                    13
          Fluid Loss                                       21
          Downtime                                         63

          Total                                           100

Statistical Results and Rationale for Results—Table 14 showed the average
valve emission factor for the valve mix in a 330,000 BPCD refinery to be
0.0248 lb/(hr-valve).  Emission rate was interestingly only weakly dependent
on valve size.  Rationale might be:

          1)   Small valves have shallower stuffing boxes than large
               valves, so leak more for their stem size than large
               valves.

          2)   Large valves may get more maintenance and operation
               attention than small valves.

          3)   Large valves may be manufactured to closer tolerances
               than small valves.
                                     232

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 .  R. Phillips
Point 1 may be an area for  improvement in valve design.  Aside from retooling
costs, the overall cost of  small  valves should not be increased significantly
by deepening the stuffing box.  Points 2 and 3 are speculative.

Available Control Technology  for  Fugitive Emissions in the Refining Industry:
Valves—

Types of Controls Available for Valves:  "Packless" Seals—The following
types of valve seals are not  apparently used in refineries based upon our
survey:

         •    Diaphragm bonnet seal,

         •    Bellows bonnet seal.

These packless seals when correctly  applied in noncritical, low-stress
conditions of temperature,  pressure  or corrosivity (in the case of the
bellows seal) should approach zero leakage.  The diaphragm material in the
first valve shown limits operation to  about 50 psi pressure differential.90
This type valve has definite  limitations in refinery use; it would fail
catastrophically upon overheating of the elastomer diaphragm, so use would
not include hydrocarbon service where  a fire could be fed by failure.  The
bellows-sealed valve, because of  the corrosion and fatigue failure potential
of the bellows, is limited  in its use  by combined temperature-pressure-
corrosivity stress, which level is best defined by the valve manufacturer.
Back-up stem packing would  appear to be absolutely necessary for these
valves in case of diaphragm or bellows failure.

Valve Maintenance Programs—Valve monitoring and maintenance programs can
be an effective method for  reducing  valve emissions.   These programs and
their effectiveness are discussed in detail in another paper of this
symposium.

Energy Requirements:  Valves—No  primary energy cost would result from
substitution of a very limited number  of packless valves for conventional
packed-stem, bonnet-sealed  valves.  As to a valve maintenance program,
incremental manpower requirement  would probably be necessary if refineries
not already doing so were to  begin comprehensive periodic inspections.

Cost-Available Refinery Technology—Estimates for the substitution of packless
valves for packed-stem valves range  from 150-367 percent91 to 1000-2000
percent92 of packed stem valve cost.  Application of packless valves
(diaphragm-sealed; bellows-sealed) in  critical services is not seen as
probable because of problems  associated with valve failure, so economic
impact is correspondingly nil.

         Because the long-term effects of valve maintenance are not yet
clearly defined, costs of a valve maintenance program have not been developed.
Any valve maintenance program would  probably be more burdensome to the small
                                     233

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W- R. Phillips
refiner, because the number of valves inspected/maintained per unit throughput
will be higher for small refineries.

Control Technology from Associated Industries:  Valves—

          Ball valves may possibly find broad use in refining, but with TFE
and TFE-filled fiber seats, are limited to use below about 450°F.  They were
not available in statistically significant numbers in this study, so their
field-tested emission factors are not available.

Development Needs:  Valves—Short-term, there appears to be a need for a
small packed-stem valve with a deeper stuffing box than is currently
available.93

Pump Seals

Existing Levels of Fugitive Emission Control in Refineries:  Pump Seals—

Types of Pump Seals—This survey showed that refinery pump-seal combinations
almost exclusively fall into one of three broad categories:

                                                          Percent of
                                                          Population

          A.   Centrifugal Pump - Mechanical Seal            82.1
          B.   Centrifugal  Pump - Packed Seal               11.5
          C.   Reciprocating Pump - Packed Seal               6.4

                                        Total               100.0

These seals are depicted in rudimentary form in Figure 3.

          The packed seal, Figure 3(A), is used to seal both rotary and
reciprocating shafts against leakage of liquid from the "working fluid" end
of the shafts to the atmosphere.  Compressed packing in the stuffing box
forms a contact seal against the moving drive shaft.  High-speed friction
resulting from this contact requires that either the working fluid be
allowed to leak from the stuffing box housing the packed shaft, or a
supplementary liquid be introduced to remove frictional heat.  A typical
leak rate would be 60 drops per minute (^3 ml per minute).91f

          Mechanical seal application, contrary to the broader applicability
of packed seals to both rotating and reciprocating shafts, is limited to use
on rotary shafts.   Mechanical seals may be used to seal both pump and com-
pressor shafts, but are more universally applied to pumps, specifically
centrifugal pumps.

          Packings - Service limits for selected packings are found in
          Table 17.
                                     234

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W.  R.  Phillips
                                                ^-Stuffing box
                                         B. Mechanical packing
                                               ^Stuffing  box
                             Fluid

                         Impeller
                           end
                             Fluid
                                         •b. Mechanical seal
                      Figure 3.   Common pump  seals  - simplified.
                                              235

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                                                                                 a
                          TABLE  17.  SERVICE LIMITS FOR SELECTED MECHANICAL PACKINGS '
                                                                                   95
NJ
CO
Break-In.
Leakage
Packing (drops/min)
Asbestos/TFE 120
TFE (lubed) 120
Asbestos/Graphite
Graphite-Fiber
Graphite-Ribbon
Lead
Aluminum
Inconel-Reinforced
Asbestos Over ,
Resilient Core
Running Maximum
Leakage Temperature
(drops/min) (°F)
60
60
60
60
60
60
60


500
500
400
1000 (600)d
1000 (600)d
350
800 (500)d
1200

Pressure at Temperature
Maximum Maximum At Maximum
C C C
Temperature Pressure Pressure
(psig) (paig) (°F)
50 200
50 200
50 250
50 350
50 350
50 400e
50 400e
Unknown

100
100
100
300
.300
100
200


       aBasic data:  2-in shaft, 3550 rpm.  Controlled leakage for 720 h\r  Pumped liquid is water.
        Assumes maximum AT of 100°F  (50°F for flax) due to shaft friction.  Satisfactory results can be
        expected by using these maximum limits and following FSA (Fluid Sealing Assn.) Test Procedure  01.

        Leakage rate:  1 ml/rain a 10 to 20 drops/min,

       cTeraperature is product  temperature; pressure  is stuffing-box pressure.

        Larger number is nonoxidizing environment; smaller number  is oxidizing environment.

       Assumes rings are die-formed.
        For  low-speed shafts only.   (Green, Tweed  and Company).
S3

pa

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  . R. Phillips
          Lubricants for packings include  the  following  substances:96

          •     Mica and talc

          •     Graphite

          •     Molybdenum disulfide (MoS2)

               Hydrocarbon type lubricants (greases, tallow, petroleum oils)

          •     Tungsten disulfide

               TFE

          •     Silicone oils.

          Mechanical seals - The mechanical seal in its many forms is the
          predominant pump seal today.  At the time of the Los Angeles
          County,  California study twenty years ago, mechanical seals made
          up only  42 percent of the seals in use there.97  Radian's survey
          revealed that by 1978, approximately 82 percent of the refinery
          pump seals were mechanical type.

          Mechanical seals are prefabricated assemblies which shift the
          point of wear from the drive shaft, as with packed seals, to
          easily-replaced pairs of rings, one of which is attached to the
          pump shaft, and the other to the gland plate or its equivalent.
          Seal faces are perpendicular to the shaft as shown in Figure 4.
          Faces are typically lapped to a flatness of two microns which
          accounts for their typically low leak rate when carefully instailed>
          started  up and flushed properly.

          Double mechanical seals provide a margin of protection against
          seal failure not offered by single mechanical seals.

          If the inner seal should fail, the outer seal prevents escaping
          fluid from reaching the atmosphere; in case of accidental pressure
          loss in  the seal liquid system, however, the pumped liquid will
          contaminate the seal liquid.  If the seal liquid is contained
          within a pressurized "seal pot" system, the problem of contaminated
          seal liquid cleanup is minimized.

Frequency  of Application of Pump Seals—The hypothetical  refinery mentioned
much earlier in  this  paper (Table 14)  was seen to emit an estimated 57.63
Ib/hr from 353  pump  seals for a weighted emission factor  of 0.163 lb/(hr-pump
seal).  This total HC emission rate  places pump seals fourth in importance
among the  process-related fugitive  emissions  studied by Radian.
                                     237

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                                                                                                                    Gland

                                                                                                                    plate
UJ
oo
                             i "9 * y^—i


                        KUmped liquid ^
                                         a. Outiide teal
                                                                                               b. Inside
                                Figure 4.   Location of primary ring determines  seal type.
                                                                                                                                        H-
                                                                                                                                        T3
                                                                                                                                        cn

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W. R. Phillips
          Table 18 is a comparison of seal distributions and emission factors
taken from the 1958 California Study98 and the current refinery survey."
In 1958,  the percentages of mechanical and packed seals on pumps clearly
favored packed seals:

          Centrifugal Pumps, Packed Seals                  34.7%
          Reciprocating Pumps, Packed Seals                23.1
          Subtotal Packed Seals                            57fQ

          Centrifugal Pumps, Mechanical Seals              42.2
          Total                                           100.0

By 1978 the percentage of mechanical seals used in refineries had almost
doubled; approximately 82 percent of the seals were by then mechanical type.
The Radian survey showed this percentage to be further subdivided into
approximately 67 percent single mechanical seals and 15 percent double
mechanical seals.  No further subdivisions were made.

Effectiveness of Existing Levels of Control in Refineries—Table 18 reveals
that the overall pump seal emission factor has improved slightly over 20
years from 0.17 Ib/hr-seal to 0.16 Ib/hr-seal.

          Pump seal emission factors as shown in Table 18 should not be used
injudiciously without referring to the detailed results and statistical
analyses as found in the Final Report of this study.  To illustrate the
reasoning behind this statement, refer to Table 19.  First, there is little
doubt that pump seals in light liquid service emit hydrocarbons at a higher
rate than those in heavy liquid service (0.256 vs. 0.046).  The two emission
factor confidence intervals do not overlap, adding validity to the estimated
factors (0.17-0.39 vs. 0.02-0.11).  By contrast, the emission factor confi-
dence intervals for the three major seal types do overlap, meaning that
within the limits of certainty  (95 percent), all three classes of pump seals
could have identical emission factors.  These broad confidence limits were
characteristic of the emission factors statistically separated according to
type of seal, regardless of whether the emission factors were analyzed within
stream types (light vs. heavy hydrocarbons) or not.  One factor in the history
of mechanical seal applications should not be overlooked.  Typically, they
were applied first in those services which presented the greatest emission
problems:  especially high pressure, high vapor pressure liquids with little
self-lubrication.

Available Control Technology in the Refining Industry:  Pump Seals—

Types—Application of the types of pump seals already described is relatively
uniform within the refining industry.  This may be the result of a greater
uniformity of feedstocks and products than, say, the chemical industry uses
and produces.  The application of standards published by the American
Petroleum Institute (API) has also undoubtedly led to uniformity among
                                     239

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              TABLE 18.   DISTRIBUTION OF TYPES OF,  AND EMISSION FACTORS FOR,  REFINERY PUMP SEALS
N3
-P-
o
Seal Type
Rotary Shaft (Centrifugal)
Mechanical - Single
Mechanical - Double
Subtotal
Packed
Reciprocating Shaft
Packed
Total
(Source) 1958a
Distribution Emission Factor
(%) (Ib/hr-seal)

42.2 0.13
34.7 0.20

23.1 0.22
100.0 0.17
(This
Distribution
(X)
67.1
15.0
82.1
11.5

6.4
100.0
Study) 1978b
Emission Factor
(Ib/hr-seal)
0.19°
0,15°
0.19
0.071

0.14
0.16
       California joint refinery study among federal, state and Los Angeles District agencies.

        Percentages ara baaed upon complete process unit surveys within each of nine refineries, but
        without random selection of unit  types,  Units selected are Isited in Interim Reports
        Emission  factors are average from operational and- standby pumps.

       cEmi8sion  factor confidence limits for the  three basic  types of  seals  (centrifugal-packed,
        centrifugal-mechanical, reciprocating-packed) overlap  to  the extent  that  all three  classes of
        seals  could have identical emission factors.

-------
TABLE 19.
Source
Type


Stream 2J*
Stream 3
Total
Seal Type
Seal Type
Seal Type
Total
Stream 2
Stream 2
Stream 2
Total
Number
Screened





CMC
CPd
RPe

- CM
- CP
- RP


466
290
756
621
87
48
756
404
37
25
Total
Leaking


298
66

312
32
20

264
17
17
PUMP
Percent
Leaking


63.
22.

51.
36.
41.

65.
45.
68.


9
7

0
8
7

3
9
0
SEAL EMISSION FACTORS
97.5 Percent
Confidence Interval


(58.9,
(17.2,

(46.5,
(24.6,
(24.8,

(59.9,
(26.3,
(41.9,


68.9)
28.2)

55.5)
47.8)
60.0)

70.6)
66.6)
87.8)
Estimated
Emission
Factor


0.
0.

0.
0.
0.

0.
0.
0.


256
046

187
071
141

263
082
248
z:
95 Percent "^
Confidence Interval ^
For Emission Factor. £


(0.17,
(0.02,

' (0.13,
(0.02,
(0.057

(0.18,
(0.013
(0.04,
T)
CO
0.39)
0.11)

0.29)
0.22)
, 0.69)

0.41)
, 0.34)
1.2)
  Total
           466
Stream 3
Stream 3
Stream 3
- CM
- CP
- RP
217
50
23
48
15
3
22.1
30.0
13.0
                                                (15.7, 28.4)
                                                (15.6, 47.9)
                                                ( 1.8, 38.5)
                                                              0.044
                                                              0.041
                                                              0.013
(0.02,  0.12)
(0.0083, 0.17)
(10-5,  7.2)
  Total
           290
'Light  liquids
'Heavy  liquids
'CM • Centrifugal pump - mechanical  seal
 CP M Centrifugal pump - packed seal
•RP
Reciprocating pump - packed seal

-------
W. R. Phillips
devices used to control fugitive emissions, not only from pumps, but also
other devices surveyed by Radian.

Effectiveness—All refinery pump seal emission technology believed to be
available today was found among the thirteen refineries surveyed, and the
control effectiveness by seal type was reported in the preceding section.
A detailed account of emission factor statistics is found in the Final Report
of this study.

Energy Requirements and Relative Costs—Industry experience has shown that
mechanical seals lose less frictional energy than packed seals.  One seal
manufacturer100 reports the following relative friction losses:
       Type Pump Seal

Balanced Single Mechanical
Unbalanced Single Mechanical
Packed
                        Average Power
                       Requirement, kW

                            0.333...
                            0.400
                            2.00
Annual Electrical
     Cost, $*

       105
       126
       630
* Cost Basis:
4
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W. R. Phillips
satisfactory long-term performance history.  It would probably be necessary
for the API to take a positive position on the inherent design and performance
of this type pump before refiners would be willing to apply them.

Wastewater Systems

Existing Levels of Control in Refineries:  Wastewater Systems—

          Refinery wastewater systems vary tremendously in volume of process
water, storm water, particulates, oil and grease, and other contaminants.
Refinery wastewater systems also vary from one refinery to the next.  About
the only common denominator is an oil and water separator of the API or CPI
type.  As a result of variations in wastewater, reliable data for hydrocarbon
emissions from refinery wastewater systems do not exist.

          Variation in wastewater composition causes corresponding differences
in fugitive emission rates.  This was seen in emission measurements as
reported in Radian's fugitive emissions report.

          Despite the lack of reliable emissions data, control of fugitive
emissions is not complex, because emissions consist primarily of hydrocarbons
released from the collection system and oil-water separator.J Qlf

Characterization of Existing Wastewater Systems—Refinery wastewater systems
have evolved over the years as people have become aware of water pollution
problems, and as various treatment systems have been developed.  The basic
treatment steps may be summarized as follows:105

          •    Primary Separation - The removal of oil by gravity separation.
               Normally an API or CPI type separator is used.

          •    Intermediate Separation - The removal of suspended solids
               and additional oil by chemical sedimentation or air flotation.

          •    Secondary Treatment - The reduction of the biological oxygen
               demand (BOD) with some type of biochemical oxidation.

          •    Tertiary Treatment - Removal of dissolved organics which will
               not degrade with biological treatment methods.  Carbon
               adsorption is the most common form of tertiary treatment.

          Only the collection and primary separation systems will be
discussed.  Losses from intermediate, secondary, and tertiary treatment
systems are small in comparison.

          Since the fugitive emissions from refinery wastewater systems
consist almost exclusively of hydrocarbon losses from the collection system
and the oil and water separator, measurement and control strategies should
be limited to these two areas.   (One additional potential source^of air
pollution is the vent gas from the carbon regeneration system.     This
                                      243

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W. R. Phillips
source probably does not produce a significant amount of fugitive emissions,
but should be investigated more fully as the number of refineries using
carbon adsorption increases.)

Estimated Hydrocarbon Losses to the Air—In 1958, hydrocarbon emissions from
wastewater separators in existing refineries in the Los Angeles County area
were estimated to range from 10 lb/1000 bbls refinery capacity to 200 lb/1000
                       i n 7
bbls refinery capacity.

          The third edition of report AP-42 (August 1977) lists the relevant
hydrocarbon emission factors as follows:

          Process Drains

               Uncontrolled                210 lb/1000 bbl wastewater

               Vapor Recovery or             8 lb/1000 bbl wastewater
               Separator Covers

          The relationship between wastewater flow rate and crude oil
throughput has been shown to vary widely among refineries.  Newer or updated
refineries do a better job of segregating process water from storm water.
                                        i n ft
The following ratios have been reported.

          Refinery Classification          Bbl Wastewater/Bbl Crude

                  Older                               6.0
                  Typical                             2.4
                  Newer                               1.2

Another source gives a ratio of 0.8 barrels of wastewater per barrel of
crude.109  The original 1958 Los Angeles factors and the current AP-42
factors are very similar when a ratio of wastewater to crude of slightly over
one is used.

          Table 14 of this report ranks hydrocarbon emissions from oil and
water separators as the second largest source of fugitive emissions from a
refinery-  This ranking is based on the emission factor for uncovered
separators according to Litchfield.ll°  Litchfield's reported emission rates
for covered and uncovered separators were obtained under controlled condi-
tions, and are reasonable bases (with modifications which are to be shown)
for revising the AP-42 emission factors.111

          Using the most recent information available, Arthur D. Little
employed characteristics of raw and treated process wastewater to generate
models of two base case refineries.112  For a 200,000 BPD East/Gulf Coast
refinery, the oil and grease in the API separator effluent was given as 1920
Ib/day, or 9.6 lb/1000 bbls refinery capacity.  For the 330,000 BPD hypo-
thetical refinery in Radian's study, this factor gives 132 Ib/hr oil and
grease in the separator effluent water to the dissolved air flotation unit.
                                     244

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W.  R. Phillips
         Separator removal  efficiencies are reported to be 60 to 99
percent,113 and 50 to 87 percent.111*   Using 87 percent as a typical high
efficiency number, oil and grease rate to the separator becomes 1015 Ib/hr,
or 74 lb/103 bbl of crude oil  to  the  refinery.

         In a 1971 study  (using  laboratory data from a simulated API
separator) by D. K. Litchfield of American Oil Company, evaporative losses
of oil  from API separators were found to average 16 volume percent without
covers  and two volume percent  with covers of a cellular glass insulation
(manufactured by Pittsburgh  Corning)  floating directly on the oil.115  The
two volume percent loss with covers is not affected significantly by air
temperature because of the insulating effect of the cover.  The evaporative
oil loss from uncovered separators was found to vary with ambient temperature,
influent temperature, and  the  10  percent true boiling point of the oil.   The
16 percent volume loss reported is for an average ambient temperature of
40.1°F, an average separator water temperature of 140°F, and an average 10
percent true boiling point of  the oil of 300°F.

         The average ambient  temperature of 40.1°F is low for an estimate of
maximum hydrocarbon emissions, so an  average ambient temperature of 80°F
will be used.  Using an evaporation factor of 0.0319 volume percent per °F
increase, the oil evaporation  from an uncovered separator is 17.3 volume
percent and the oil loss with  covers  remains around two volume percent.

         These loss rates give hydrocarbon evaporation rates from the 330,000
BPD refinery of 178 Ib/hr  for  uncovered separators and 20.6 Ib/hr for covered
separators.  If these more recent studies are more representative than the
initial work beginning with  the Los Angeles studies, then the wastewater
system  hydrocarbon emission  factors should be:

         12.9 lb/1000 bbl crude  for  uncovered API separators,

          1.5 lb/1000 bbl crude  for  covered API separators.

Separator covers may therefore be expected to reduce emissions approximately
89 percent.  These factors show that  the fugitive hydrocarbon emissions from
wastewater systems with covered separators should rank well down .on the list
of total emissions, and that API  separator covers produce significant emis-
sions reductions.

Collection System - Process  and Storm Sewers—

         The contribution of  the wastewater collection system to the overall
refinery fugitive hydrocarbon  emissions is shown as 45.29 Ib/hr in Table 15
for the hypothetical 330,000 BPD  refinery.  These emissions result mainly
from allowing oil or oily  water to be exposed to the air in the process
areas or in the drains and sewers.

         In general, available controls for reducing fugitive emissions
from existing process and  storm sewers and collection systems consist of
                                     245

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W. R. Phillips
relatively minor modifications such as sealing open  sewer  systems,  altering
pump bases for better drainage, recurbing some process areas  for  separation
of oily water, and improving housekeeping.  These changes  should  be made
wherever applicable.

          Changes which involve substantial capital  outlays  (or which may be
nearly infeasible from a construction standpoint) such as major revisions to
existing underground sewer systems or installation of vapor recovery systems
do not represent best available technology economically achievable.

Primary Treatment - Oil and Water Separator—

          The primary treatment of process water is  the oil and water
separator which is usually of the API or CPI type (corrugated-plate inter-
ceptor).  All U.S. refineries have facilities for gravity  separation of oil
and water.     These separators are effective in removing  free oil  from water.
                                                                    117
but will not separate substances in solution or break up emulsions.

          Covering the oil and water separator is the only effective and
economical means of reducing hydrocarbon emissions from refinery wastewater
treatment systems.  If the separator is operated properly, then hydrocarbon
emissions from the downstream equipment will be negligible, and if  the
separator is covered, then hydrocarbon emissions from that source will be
effectively controlled.

          API separators are covered by floating pontoons or  double-deck type
covers which are sealed against the outer walls of each bay.  A CPI separator
normally will have a fixed roof cover.118

          Using an API separator as an example, the  economic  incentive of
reducing oil losses to the atmosphere by covering the bays will be  examined
here.  Conservative economics here will show the minimum return on  investment
for installing covers.

          Sources indicate separator cover requirements of 0.028 an 0.050 ft2
per BPD wastewater flow.119'120  Corresponding costs escalated by the M&S
equipment cost index (Chemical Engineering Magazine) to third quarter 1979
are $15.84 and $14.85 per ftz, respectively.  A capital cost  of $265,000 is
obtained for a 330,000 BPD refinery using $16.00/ft2 and 0.050 ft2/BPD.

          A typical refinery installing covers would see evaporative oil
losses of approximately 17 percent reduced to less than 2  percent.  For the
330,000 BPD theoretical refinery this means a savings of 157  Ib/hr  or 12
BPD at an assumed specific gravity of 0.87.  At $16  per barrel this savings
is worth $70,000 per year.  If annual maintenance costs of $5000  are incurred
on the covers, then the net savings is $65,000 per year.   This savings yields
a before tax discounted cash flow (DCF) rate of return of  28  percent assuming
a 20-year economic life and no investment tax credits.
                                      246

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W. R. Phillips
          The economic incentive to install covers on oil and water separators
combined with the resultant reduction of fugitive hydrocarbon emissions make
a strong case for all separators to be covered.  As of January 1977, 80
percent of the refining capacity was located in states where these covers are
required.J 21

Cooling Towers

Existing Levels of Cooling Tower Control in Refineries—

Types—At the time of the 1958 Los Angeles County California Emissions
Study,122 "atmospheric sections" (splash-cooled heat exchanger tubes) could
still be found in refinery cooling towers, although they were prone to leak
and were difficult to repair.  Chromates and chlorine were used to control
corrosion and biological growth, respectively.  The emission factor for
cooling towers was estimated to be 6.2 lb hydrocarbons/106 gal cooling water
circulation.

          By 1978, wetted "atmospheric" sections had, generally, been phased
out of refineries, organo-phosphates had replaced chromates for corrosion
control, and biological growth was being controlled by combinations of
chlorine and, often, nonoxidizing biocides.

          Today, as in 1958, makeup water ranges from near-pristine snow-
based surface water to sea water.  Some refineries now recycle water from
sour water strippers, which tends to reduce total plant water effluent and
retain phenols in the plant.  If recycled to a cooling tower, the aeration
encourages oxidation of phenols  from the  stripper bottoms water.

          Emission factors determined during this study have been based upon
two analytical methods:  Total Organic Carbon  (TOG) Analysis, and a purge
technique.  These results bracket the 1958 emission factor of 6.2 lb/10
gal cooling water:

                                                 Emission Factor
          Analytical Technique                  lb HC/106 gal C.W.

                 TOG                                  12-4

                 Purge                                 0.108

The purge technique is more precise and accurate than the TOC technique based
upon standardization runs, so one concludes that there is a high probability
that progress has been made in reducing cooling tower hydrocarbon losses.

Cooling Tower Control Technology Available in Refineries and Associated
Industry—

Types and Effectiveness—Forced-draft cooling  towers characterize refineries
and organic chemical plants.  The greater heat release rates of power
                                     247

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W. R. Phillips
industry plants make parabolic,  natural-draft towers more economical.  There
is no inherent advantage to either basic type of tower in terms of primary
air emission control.

          Air monitoring and water monitoring instruments for the purpose of
leak detection are common to all the process industries; no analytical
problems of a refinery water system may be considered unique.

Costs—As industries tighten restrictions on water emissions, the likelihood
of having to deal with a broader array of recycle water types increases.
This will probably require progressively more attention to materials of
construction of cooling towers,  heat exchangers and water piping.  Also,
more complex treatment chemicals and application systems may be called for.
Changes in the circulating water may of course affect levels of air emissions
as a result of corrosion-induced leaks.  Air emissions may also increase from
use of cooling towers as bio-oxidation devices, as in the case of recycled
phenols already mentioned.  The overall impact of these forecast changes on
air emission control costs ha's not been addressed, to the best of our
knowledge.
                                     248

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 . R. Phillips
REFERENCES

1.    Gary,  J.  H.,  and G.  E.  Handwerk.  Petroleum Refining, Technology and
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2.    Elkin, H.  G., and R. A. Constable.  Source/Control of Air Emissions.
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3.    Dickerman,  J. C. , T. D. Raye, and J. D. Colley.  The Petroleum Refining
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4.    Bryant, H.  S.  Environment Needs Guide to Refinery Sulfur Recovery.
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5.    Environmental Protection Agency.  Compilation of Air Pollution Emission
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6.    Groenendaal,  W. , and H. C. A. Van Meurs.  Shell Launches HS Glaus Off-
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7.    Radian Corporation.   A Program to Investigate Various Factors in
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8.    Sussman, U.  H.  Atmospheric Emissions from Catalytic Cracking Unit
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9.    Reference 5.

10.  Radian Corporation.   Control Techniques for Volatile Organic Emissions
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11.  Reference 10.

12.  Reference 5.

13.  Laengrich,  A. R. , and W. L. Cameron.  Tail-Gas Cleanup Addition May
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14.  Valdez, A.  R.  New Look at Sulfur Plants.  Hydrocarbon Proc. Petrol.
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15.  Reference 1.

16.  Reference 5.

17.  Hydroprocessing Is Lively Topic.  Oil Gas J.  75(28):153, 1977.
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W. R. Phillips
18.  Barry, C.  B.  Reduce Glaus Sulfur Emission.  Kydrucctibou Proc. 51(4):
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19.  Reference 6.

20.  Reference 17.

21.  Vasalos, I. A., et al.  New Cracking Process Controls FCCU SOX-  Oil
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22.  American Petroleum Institute, Division of Refining.  Manual on Disposal
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23.  Rheaume, L., et al.  New FCC Catalysts Cut Energy and Increase Activity.
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24.  Conser, R. E.  Here's a New Way to Clean Process Gases.  Oil Gas J.
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25.  Barthel, Y., et al.  Sulfur Recovery in Oil Refineries Using IFF
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26.  Processes Clean Up Tail Gas.  Oil Gas J. 76(35):160-166, 1978.

27.  Reference 17.

28.  Reference 26.

29.  More Glaus Cleanup Processes Explained.  Oil Gas J. 76(37):88-91, 1978.

30.  Parthasarathy, R., and L. P. Van Brocklin.  Applications of the Phosphate
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     1978 NPRA Annual Meeting, San Antonio, Texas, 1978.

31.  Reference 26.

32.  Reference 29.

33.  Conser, R. E., and R. F. Anderson.  New Tool Combats S02 Emissions.
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34.  Dry Process for S02 Removal Due Test.  Oil Gas J. 70(34):67-70, 1972.

35.  Reference 29.

36.  Ball, F. G., et al.  Glaus Process/Gaseous Wastes.  Hydrocarbon Proc.
     51(10):125-127, 1972.

37.  Reference 17.
                                    250

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W. R. Phillips
 38.  Reference 17.

 39.  Reference 17.

 40.  Reference 17.

 41.  Atwood, G. R., et al.  New Integrated UCAP Process Treats Low
      Streams, Trims Emissions.  Oil Gas J. 77(35):111, 1979.

 42.  Controlling SOx Emissions from Fluid Catalytic Cracking (FCC) Units.
      Wet Scrubber Newsletter  (48):6, 1978.

 43.  Reference 21.

 44.  Reference 22.

 45.  Reference 26.

 46.  Reference 26.

 47.  Reference 29.

 48.  Ritter, R. E.  Tests Make Case for Coke Free Regenerated FCC Catalysts.
      Oil Gas J. 73(36):41-43, 1975.

 49.  Coke Key to Cleaning Glaus Unit Tail Gas.  Oil Gas J. 74(47): 142-144,
      1976.

 50.  Doerges, A., K. Bratzler, and J. Schlauer.  LUCAS Process Cleans Lean
      H2S Streams.  Hydrocarbon Proc. 55(10):110-111, 1976.

 51.  Reference 17.

 52.  Reference 21.

 53.  Hulman, P. B., and J. M. Burke.  The Lime/Limestone Flue Gas Desulfuri-
      zation Processes.  Radian Corporation, Austin, Texas, 1978.

 54.  McGlamery, G. G. , et al.  Detailed Cost Estimates for Advanced Effluent
      Desulfurization Processes, Final Report.  EPA-600/2-75-006.  TVA, Muscle
      Shoals, Alabama, January 1975.


 55.  Gibson, E. D., T. G. Sipes, and J. C. Lacy.  The Dual Alkali Flue Gas
      Desulfurization Process.  Radian Corporation, Austin, Texas, 1978.

 56.  Arneson, A. D., F. M. Nooy, and J. B. Pohlenz.  The Shell FGD Process
      Pilot Plant Experience at Tampa Electric.  Presented at the Fourth
      Symposium on Flue Gas Desulfurization, Hollywood, Florida, 1977.
                                      251

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W. R. Phillips
 57.   Stern,  R.  D. ,  et  al.   Interagency Flue Gas  Desulfurization Evaluation.
      Radian  Corporation, Austin,  Texas 1977.

 58.   Faucett, H.  L.  Private Conversation.   TVA, 26 May 1977.

 59.   Stover, R.  D.   Control of Carbon Monoxide Emissions from FCC Units by
      UltraCat Regeneration.  Ind.  Proc. Des.  Poll.  Control,  Proc. AIChE
      Workshop 6:80-85, 1975.

 60.   Rheaume, L., et al.   Two New Carbon Monoxide Catalysts  Get Commercial
      Tests.   Oil Gas J.  74(21):66-70,  1976.

 61.   Reference  23.

 62.   Davis,  John C.  FCC Units Get Crack Catalysts.  Chem.  Eng. 84(12):
      77-79,  1977.

 63.   American Petroleum Institute, Refining Department.  American Petroleum
      Institute  Refining Department 41st Midyear Meeting, Los Angeles,
      California, May 1976, Proceedings.  Washington, D.C.,  1976.

 64.   Reference  22.

 65.   lya, K. Sridhar.   Reduce NOX in Stack Gases.  Hydrocarbon Proc.  163,
      November 1972.

 66.   Reed, Robert D.  How to Cut Combustion-Produced NOX.  Oil Gas J.  72(3):
      63-64,  1974.

 67.   Reference  22.

 68.   Wetherold, R.  G.   The Distribution of Selected Fugitive Hydrocarbon
      Emission Sources  Among Petroleum Refinery Process Streams, Technical
      Note.  EPA Contract No. 68-02-2665.  Radian Corporation,  Austin,  Texas,
      May 1979.

 69.   Litchfield, D.  K.  Controlling Odors and Vapors from API Separators.
      Oil and Gas Journal 69:60-62, Nov. 1971.

 70.   Reference  68.

 71.   Reference  68,  Table 7.

 72.   Reference  68,  Table 6.

 73.   Reference  68.

 74.   Reference  68.

 75.   Reference  69-
                                     252

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W. R. Phillips
76.  Reference 5.

77.  Los Angeles, County of, Air Pollution  Control District,  et al.  Emissions
     to the Atmosphere from Petroleum Refineries  in Los Angeles County,
     Final Report.

78.  Sittig, M.  Petroleum Refining  Industry  -  Energy  Saving  and Environmental
     Control.  Noyes Data Corporation, Park Ridge, New Jersey, 1978.

79.  California, State of, Air Resource Board,  Legal Affairs  and Enforcement
     of Stationary Source Control Divisions.  Emissions from  Leaking Valves,
     Flanges, Pump and Compressor Seals, and  Other Equipment  at Oil Refineries.
     Report No. LE-78-001.  April 1978, p.  1-2.

80.  Reference 5. '

81.  Jones, H. R.  Pollution Control in the Petroleum  Industry.  Pollution
     Technology Review No. 4.  Noyes Data Corporation, Park Ridge, New Jersey,
     1973, p. 144.

82.  Reference 77.

83.  Burklin, C. E.  Revision of Emission Factors for  Petroleum Refining.
     EPA Contract No. 68-02-1889, Task 2, EPA 450/3-77-030.   Radian
     Corporation, Austin, Texas, October 1977.

84.  Pikulik, A.  Selecting and Specifying  Valves for  New  Plants.  Chem. Eng.
     83(19):168, 1976.

85.  Reference 84.

86.  Wilson, R. T.  How to Pack High-Temperature  Valves.   Hydrocarbon Proc.
     57(1):91, 1978.

87.  Reference 86.

88.  Reference 84.

89.  Greene, Tweed, and Co.  Palmetto Packings  for Pumps,  Valves, Hydraulic
     Presses and Rams.

90.  Perry, R. H., and C. H. Chilton.  Chemical Engineer's Handbook, 5th
     Edition.  McGraw-Hill, New York, New York, 1973,  p. 6-55.

91.  Reference 79, p. V-7.

92.  Frazier, W.  Personal Communication.   Crane  Company,  Houston, Texas,
     18 June 1979.
                                      253

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W. R. Phillips
93.  Reference 92.

94.  Hoyle, R.  How to Select and Use Mechanical Packings.  Chem. Eng.
     85(22):107, 1978.

95.  Reference 94.

96.  Reference 94, p. 106.

97.  Steigerwald, B, J.  Emission of Hydrocarbons to the Atmosphere from
     Seals on Pumps and Compressors.  Report No. 6.  Joint District and
     State Project for the Evaluation of Refinery Emissions, April 1958,
     p. 29-

98.  Reference 97.

99.  Reference 68.

100. Center for Professional Advancement.  Mechanical Seal Technology for
     the Process Industries.  East Brunswick, New Jersey, March 1978.

101. Chemical Engineering Equipment Buyers' Guide, 1979-1980, p. 448,
     McGraw-Hill.

102. Potter, Charles.  Private Conversation.  Crane-Deming Pumps, Houston,
     Texas, 27 July 1979.

103. Reference 102.

104. Dickerman, J. D., et al.  Industrial Process Profiles for Environmental
     Use, Chapter 3, Petroleum Refining Industry.  EPA Contract No. 68-02-
     1319, Task 34, EPA 600/2-77-0230.  Radian Corporation, Austin, Texas,
     January 1977, p. 82.

105. Beychok, Milton R.  Wastewater Treatment.  Hydrocarbon Proc. 50(12):
     110, 1971.

106. Reference  78, p.  130.

107. Kanter, C. V., et al.  Emissions to the Atmosphere from Eight
     Miscellaneous Sources in Oil Refineries.  Report No. 8, Joint District,
     Federal and State Project for the Evaluation of Refinery Emissions.
     Los Angeles County Air Pollution Control District, Los Angeles,
     California, 1958.

108. Reference 81, p. 255.
                                     254

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W. R. Phillips
109. (Arthur D.) Little, Inc.   Environmental  Considerations of  Selected
     Energy Conserving Manufacturing  Process  Options, Final Report.  Volume
     4.  Petroleum Refining  Industry  Report.   EPA Contract No.  68-03-2198,
     EPA 600/7-076-034d.  Cambridge,  Massachusetts, December 1976, p. 28.'

110. Reference 69.

111. Reference 5.

112. Reference 109.

113. Reference 106, p. 202.

114. Azad, H. S., ed.  Industrial Wastewater  Management Handbook.  McGraw-
     Hill, New York, New York,  1976,  pp.  8-27,  8-28.

115. Reference 69.

116. Environmental Protection Agency, Effluent  Guidelines Division.  Interim
     Final Supplement for Pretreatment to the Development Document for the
     Petroleum Refining Industry Existing Point Source Category.  EPA 440/
     1-76-083A.  Washington,  D.C., March  1977,  p.  67.

117. Environmental Protection Agency, Effluent  Guidelines Division.
     Development Document for Effluent Limitations Guidelines and New Source
     Performance Standards for  the Petroleum  Refining Point Source Category,
     Final Report.  EPA 440/l-74-014a, PB 238 612.  Washington, D.C., April
     1974, p. 101.

118. Hustvedt, K. C. , and R.  A.  Quaney.   Control of Refinery Vacuum Producing
     Systems, Wastewater Separators and Process Unit Turnarounds.  EPA
     450/2-77-025, OAQPS No.  1.2-081.  Environmental Protection Agency,
     Office of Air Quality Planning and Standards, Office of Air and Water
     Management, Research Triangle Park,  North  Carolina, October 1977, p. 3-2.

119. Air Pollution Control Association, ed.   Emission Factors and Inventories,
     Anaheim, California, November 1978.   Proceedings of the Specialty
     Conference, Pittsburgh,  Pennsylvania, 1978.

120. Reference 118, p. 4-20.

121. Reference 118, p. 5-3.

122. Reference 77.

123. James,  E. W., W.  F. McGuire,  and W.  L. Harpel.   Using  Waste Water  as
     Cooling  System  Makeup  Water.   Chem.  Eng. 83(18):95,  1976.
                                     255

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J. A. Mullins
                                  REVIEW

                                    by

                               J.  A. Mullins
                             Shell Oil Company
                              Houston, Texas


                                    on

                 REFINERY AIR EMISSION CONTROL TECHNOLOGY
                                  RESUME

         Mr. Mullins is employed as Staff Environmental Engineer in the
Environmental Affairs Department of Shell Oil Company, Head Office in
Houston, Texas.  He received his B.S. degree in Chemical Engineering from
the University of Colorado in 1952.  After military service, he started
with Shell in Chemicals-Manufacturing.  Other assignments have included
design and pilot plant operations.  For the past eight years he has been
involved in environmental engineering, design and regulatory analysis.  He
also serves on several trade organization committees and task groups related
to the environmental area.
                                    256

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J. A.  Mullins
                                  REVIEW

                                    by

                               J.  A. Mullins
                             Shell Oil Company
                              Houston, Texas

                                    on


                 REFINERY AIR EMISSION CONTROL TECHNOLOGY
SUMMARY

         This paper had as its objectives to review  the state-of-the-art
of selected process and fugitive emission controls and to discuss available
control technology.  In order to meet these objectives, three selected
process emission sources are described and the emissions are at least
qualitatively discussed.  Because of the vast differences which exist
between refineries and because of their complexity,  it is recognized that
it is difficult to present a single simplified description or evaluation
of emissions.  In general, while there has been presented a lengthy listing
of conceivable controls, we do not believe that there has been a proper
evaluation of those technologies nor their applicability to petroleum
refineries.

         The classification system chosen for control technologies is
misleading to the reader since it leaves one with the impression that many
technologies can be readily applied to reduce atmospheric emissions when
that is not  the case.

         We  would readily agree that the controls listed as "existing" have
been applied in petroleum refineries and are in usage at many locations.
This fact, however, should not be interpreted that such controls are
economic at  all refiners or even necessary to meet ambient air quality
standards.

         The second listed grouping of control technology is incorrectly
titled as "available."  We believe this to be a poor grouping of possible
processes which contains control technologies that have actually been
applied in a limited number of refineries and those which have been con-
sidered but  never applied.  The use of the word "available" implies that
                                    257

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J. A. Mullins
all the processes listed could be used at least to some extent.  Although
there are general statements as to cost and sometimes safety, we believe
that the review and discussion given these systems is far too shallow to
justify the classification of "available."

         The third classification of process emission control technology—
namely technology transfer—again implies that the process discussed can be
used in the refining industry.  We disagree with the presumption that
limited success and usage in some application classifies a process for
transfer to another industry.

         The portion of the paper dealing with fugitive emissions and the
techniques for controlling them appears to have more technical backup than
the process'emission section and does a reasonable job of defining the
potential leakage rates of various sources.  The paper, in no way, however,
attempts to place in perspective the relative importance of fugitive
emissions to the overall hydrocarbon emission potential.  As pointed out
in the report, the second and third highest fugitive emission sources in
the hypothetical refinery are based upon old or questionable testing data.
Since these two sources alone would be judged to account for over 35 percent
of the total fugitive emissions, additional studies are certainly indicated
before any major conclusions can be made.

DETAIL COMMENTS

         I would like to point out some of the specific areas where we
believe clarification or correction may be warranted.

Process Emissions

         Although the discussion section of the Glaus process indicates the
presence of hydrocarbon in the unit feed gas, Table 2 fails to indicate that
a typical feed gas contains 1 ± 0.5% hydrocarbon.  This can cause control
problems with a Glaus unit and sometimes results in excessive temperatures
in a tail gas incineration device.

         The discussion of catalytic cracking emissions would indicate that
no new emission factors were determined in this study, and that, in the
previous study, "uncontrolled" emission factors excluded control devices
such as cyclone separators.  Justification is presented to review these old
emission factors because of changes in control technology.  This presents a
confusing picture to the reader and should be clarified.  A second reason
for review of the 1956 emission factors seems to be -a concern that one of
the six tested units may have been atypical, and that, if this unit were
excluded, an average emission factor of under 50 pounds per 1,000 barrels
of feed would result.  Since the excluded factor is 181, we do not under-
stand how the published factor 242 was arrived at.  This entire question
requires further review and clarification.
                                    258

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J. A. Mullins
         Because of vast  differences  in complexity of refineries, we  do not
believe that average steam  and  fuel usages  are meaningful.   As  energy con-
servation projects are  implemented these factors will also  change.  Emis-
sions from the boilers  and  heaters are strongly dependent upon  the mix of
fuels used and this also  varies significantly from refinery to  refinery.
The emissions factors shown in  Table  4 are  not in  agreement with those in
AP-42 and the reference for these  factors was not  indicated.

Existing Control Technology

         In the sulfur  recovery discussion,  the inclusion of Glaus tail gas
incineration as a clean-up  device  is  misleading since it only converts the
sulfur compounds to a different form.   In the discussion and accompanying
table for tail gas incineration there are discrepancies which should  be
corrected.  Incineration  temperature  is generally  950 - 1150°F rather  than
the 1200°F stated in the  discussion or the  752°F shown in Table 6.  Tempera-
tures below about 900°F will not convert the H2S and  temperatures above about
1100°F are unnecessary  and  consume large quantities of fuel.  Excess  air is
also more likely to be  100  percent or greater since most of these devices are
natural draft with manual control.

         Although hydrodesulfurization of feedstock to catalytic crackers
is not generally practiced  for  purposes of  SOX contol, it does  occur  in
about 20 percent of the cracking feed in the United States.   We believe that
an estimate of the degree of control  achieved by this technology should be
stated.  It is implied  in the discussion that the  degree of desulfurization
used today is 92 to 95  percent.  This level  is commercially uneconomical
and rarely, if ever, achieved.   More  commonly levels  of 60  to 70 percent are
practiced.

         In the discussion  of FCCU particulate removal, a collection
efficiency for ESP's of 99.5 percent  is stated to  be  a common occurrence.
Again, we believe this  to be rarely,  if ever, achieved in practice.   The
more likely long-term efficiencies are in the range of 90 to 95 percent.

         Control of CO  emissions by CO boilers is, as stated, a fairly
common practice; however, the required combustion  temperature is usually
1800 to 2000°F rather than  the  1300°F indicated.

Available Control Technology

         As discussed earlier,  we  disagree  with the  use of the term
"available" since it implies a  greater degree of assurance  that the technol-
ogy can be used than is justified.  Examples of this  are the UOP Sulfox
Process and the Union Carbide UCAP Process which are  reported as only being
in the testing stage.   The  use  of  many of the alternative methods of  Glaus
tail gas clean-up shown in  Table 8 are also  questionable.   The  Catalytic
Incineration process does not by itself reduce sulfur compound  emissions
and should not be listed  as a clean-up device.
                                     259

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J. A. Mullins
         The system of SOX removal discussed for boilers and process heaters
is not realistic.  The concept of ducting all furnace and boiler flue gases
to an integrated sulfur removal facility is purely theoretical and cannot be
justified either technically or economically.  The safety barriers pointed
out in the discussion would only be the "tip of the iceberg" if this
practice were to be implemented.  Even if such a centralized treatment
system were feasible, the suggested processes for SOX removal would not be
the likely choice.

         For NOX removal (or reduction) from boiler and furnace flue gases,
three add-on techniques are suggested with the conclusion that only the
thermal process appears promising.  We question not including combustion
modifications in this discussion.  In fact, we believe it would be more
appropriate if all of the techniques included in the section devoted to
changes in operating practices were discussed and classified as "existing,"
or "available" technology.  We see no reason to consider these pollution
reduction methods in a different light than the add-on techniques described
in the earlier sections.  Many of them may be more cost-effective than the
proposed add-on devices and should be considered.

         Concerning the "thermal denox" process, we believe the stated 50
to 70 percent reduction is optimistic and would, on a long-term basis, be
in the range of 40 to 50 percent.  Since some of the possible combustion
modifications appear capable of achieving near the same reduction, the use
of add-on techniques may not be justified at this time.  Also, the tempera-
ture range cited for the thermal denox process is incorrect by a factor of
10.  The proper temperature range is 1300 to 1900°F.

         In the discussion of technologies that could be transferred from
other industry for SOX and/or particulate removal from boiler and furnace
flue gases, several processes that are either in commercial use or test for
flue gas scrubbing are suggested.  I would not disagree that this may be
possible from a technical point of view, but I question the economics and
reliability of such schemes.  It is stated that the lime/limestone SOX
removal process is highly reliable.  Considering the recent comments of the
utility industry relative to the SOX scrubber requirements under the
revised NSPS for utility boilers, I would question this conclusion.  It is
especially important when you consider that refinery catalytic crackers are
expected to operate with very high stream factors.

Alternative Operating Practices^

         As discussed earlier, I believe that the various techniques
described in this section should be placed, as appropriate, in the sections
of the paper where technology is described as "existing" or "available."
I see no reason to attempt to segregate things like catalyst changes from
add-on scrubbing when considering the potential to reduce emissions and
evaluating the economics of such changes.
                                    260

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J.  A. Mullins
         In the discussion of high  temperatures  FCCU  catalyst  regeneration,
it is stated that the CO level  can  be  reduced  to well below  500 ppm.  In our
experience the 500 ppm level is  about  the  lower  limit.  We are not aware of
any catalyst supplier or vessel  designer that  would guarantee  CO  levels of
less than 500 ppm.  A recent Federal Register  notice  also states  that 500
ppm CO is the lower limit for high  temperature regneration.

         The newly developed catalysts which prevent  sulfur  from  leaving the
regenerator offer great promise  for SOX emission reduction.  We would, how-
ever, question the costs cited  as realistic.   The  estimate of  $0.03 per
barrel of feed appears to be taken  from an Amoco study in early 1977.
Escalation of these costs should be made as well as some allowances made
for increased size and operating costs of  the  Glaus unit required to handle
the additional load that will be generated.

FUGITIVE EMISSIONS

         As discussed initially, much  of the emission data for fugitive
emissions appears to be on a sounder basis.  A significant effort by Radian
to quantify the emissions was made  and is  the  subject of another paper at
this conference.  It does concern me,  however, that the second and third
highest fugitive emission losses in the hypothetical  refinery  are stated to
be the two categories of sources that  had  the  lowest  confidence limits of
the study and were therefore estimated on  the  basis of  previous work.  The
recommendation that these two potential sources  be investigated further is
certainly justified.

         Even though a separate  paper  is being presented on  the subject of
fugitive emissions, I believe it should be made  clear in this  paper that
the emission factors given for  a particular type of source represent average
leakage or loss, and that by far the majority  of fugitive emissions are the
result of a relatively few leaking  sources.  It  is this fact which makes
some type of leak detection and  maintenance program a viable alternative of
control.  As was discussed, the  use of "leak-proof" equipment  such as
diaphram values does not offer  a reasonable or even achievable solution to
the problem.

         Of significant interest was the finding that,  despite a  great
increase in the usage of mechanical pump seals in  the past 20  years, the
average emission factor for all  pumps  has  essentially not changed.  This
would indicate that the proposals to require mechanical seals  in  certain
processes would not result in emission reductions  commensurate with the
costs involved.  Double mechanical  seals of the  tandem type  are described.
The other type of double seal operates with the  seal  fluid pressure higher
than the pump suction and leakage is therefore into pump.  Leakage across
the outer seal to the atmosphere will  occur; however,  in limited  cases this
could be a nonhydrocarbon.

         "Canned" pumps for horsepowers up to  250, heads to  3,000 feet, flow
to 50,000 GPM and temperatures  to 340°F are suggested.  We are not aware of
                                    261

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J. M. Mullins
any such applications and believe that the few that are used in refineries
are near 30 HP, 200 feet of head, 100 GPM and temperatures of 100°F.  It
may be that confusion exists between the sealless "canned" pump and the
vertical can pump which is sealed by mechanical seals.  We would agree,
however, that general refinery usage of sealless pumps will not occur until
these pumps have met API  standards.
                                    262

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W. R. Phillips
                           QUESTIONS AND ANSWERS


COMMENT/Rosebrook - I would like to make a  comment  at  this  time, because I
think something has happened which makes a  point.   Too often  the only infor-
mation available to consulting firms such as  ourselves,  to  enforcement
agencies, to many other types of firms, is  information which we glean from
the literature, and attempt to appraise based on sound engineering principles.
But it is people like Jim Mullins and Shell Chemical,  and Mobil and Exxon
and others, who tell you that it is not 1300°,  it is 1800.  It really makes
a difference in the economics of that control technology and  the effective-
ness of the control technology, if indeed as  opposed to  the literature,
practical experience, day-to-day running in the field,  shows  that instead of
giving 90 percent efficiency they give 60 percent or 70  percent.

Q.  Joseph Zabago/Mobil Oil - Perhaps you can elucidate  Table 13 and 14,
where you are making an attempt to prioritize sources  with  specific refer-
ence again to Mullins' commentary on the oil/water  separators and the cool-
ing towers.  I am not as interested in your answer  to  the question as I am
in applying the question to a paper that will be given tomorrow, where
people will be talking about dispersion analysis for an  entire refinery.
Table 13 and 14 are the first place that I have seen in  the document where
one has taken the whole A. D. Little hypothetical refinery  and turned out a
number.  We got a number based on all those numbers that Lloyd told us about
this morning, and I like them, in terms of what he  has already done, but then
we have wastewater separators and cooling towers and they just blow Table 13
and 14 out of the water.  It is my way of saying that  I  don't think the
tables are consistent, and I think they should be strongly  qualified as one
is based on a study and one is a paper study.   One  is  based on empirical
work and the other is totally a paper study.

A._- First of all, on the oil/water separators, as  I originally said, I tried
to put these emission factors and total emissions from a hypothetical
refinery in some sort of pecking order.  Well,  for  the oil/water separator,
you can see it only fits into the table if you will look at the uncovered
or uncontrolled oil/water separator.  The emission  in  pounds  per hour is
178, but if you look at a covered separator,  which  I am beating the drum
for here, it drops clear to the bottom of the table.   So, it  is there in
                                     263

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W. R. Phillips
position number 2 only by virtue of what it will do if it is uncovered.  Now,
as to the data that went into that, those who did the separator simulation,
actually took a body of water and an oil layer and covered it and uncovered
it and took their temperatures and samples and so forth.  We feel like that
is probably better than the original work that went into the AP-42 numbers
represented here as 252 pounds per 1,000 barrels.  Well, anyway, not only
are those numbers lower than the original AP-42 numbers, but I think they
were done in a controlled manner.  As to cooling towers, the values which I
show you here for Table 14 include both the values that we got using our
purge method and our TOG method.  I don't believe it appears in your copy.
The original order here was established by the values given by the TOC
results for cooling towers of 234.  It was only after going through the data,
going through the procedures, looking at both the precision and the accuracy
of the two methods that we concluded that the lower values based upon the
purge method were what we should go with.  Now, obviously in that case that
would drop cooling towers way down in the table.  So, your point is well
taken.  Those two, if they are covered, in the first case, and if we use the
purge method in the second, which we feel is the more reliable of the two
numbers, then certainly those two sources of emissions are out of the running
for being important.  Incidentally, we did take a look at rough economics of
covering the API separator.  It is a runaway first choice for doing what was
mentioned earlier today, namely holding onto some of those good hydrocarbons
that you really don't want in the air, that you would like to recycle into
your refinery.  There is a high return I won't mention it because someone
will hang his hat on it.

COMMENT / Joseph Zabago/Mobil Oil - Thank you!  The 234 is not included in
our copies.  That clarifies my total confusion in figuring out why number 3
was the lowest, I now understand that and why a number of cooling towers
should be, say 2.04, put at the bottom of the priority list, and I appreciate
your clarifying the business on the oil/water separators.  The commentary
about the economics is still premature pending the data that we determined
from studies that were talked about earlier.
                                     264

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R.  L. Honerkamp
                          CORRELATION OF FUGITIVE

                        EMISSION RATES FROM BAGGABLE

                           SOURCES WITH REFINERY

                             PROCESS VARIABLES

                              R. L. Honerkamp
                             Radian Corporation
                               Austin, Texas


                                  ABSTRACT

         The  effects  which refinery process variables have on fugitive emis-
sion rates  are  discussed in this paper.   Correlations are presented for both
continuous  and  discrete process variables.   Continuous variables include
temperature,  pressure,  size,  age, etc.   Discrete variables may relate to
function,  type, manufacturer, etc.   The only dominating correlation observed
was for stream  composition;  components containing higher volatility process
fluids tend to  have higher emission rates.   Factors which affect the observed
correlations  or lack  of correlation are also presented.
                                   RESUME

          Russell  Honerkamp is a Staff Chemical Engineer at Radian Corporation.
He received his  B.S.  degree in Chemical Engineering from the University of
Texas at Austin  in 1975.   Since 1976, he has worked on several projects at
Radian pertaining  to  atmospheric emissions of VOC from industrial processes.
He is currently  working on a contract with EPA to support and develop New
Source Performance Standards for fugitive emission sources in the Synthetic
Organic Chemical Manufacturing Industry.
                                      265

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R. L. Honerkamp
             CORRELATION  OF FUGITIVE  EMISSION  RATES  FROM BAGGABLE

                   SOURCES WITH REFINERY PROCESS VARIABLES
  INTRODUCTION AND  OBJECTIVES

            Refinery  process variables  can be  categorized as  continuous  or
  discrete  variables.   Continuous  variables exist  over a range with common
  unit(s) of measure  which  describe  the range.   Continuous variables include
  pressure,  temperature,  size,  age,  capacity,  etc.   Discrete  variables include
  function,  type, manufacturer,  configuration,  etc.   Discrete variables  must
  be  compared individually  and  no  interpolation between levels of the variables
  is  possible.   Some  variables,  such as stream composition, can be treated as
  either  continuous or  discrete depending  on how they are defined.  The  objec-
  tive of this paper  is to  present and  explain the correlations observed in
  this study between  process variables  and fugitive  leak rates.

           There are  two primary reasons for investigating the effects of
 process  variables  on fugitive emission rates.  The more important reason is
 to provide useful  information for developing  fugitive emission control strat-
 egies.  If certain classes of emission sources do not leak due to the effects
 of process variables,  these sources can be excluded from emission reduction
 maintenance programs.   If  changes in certain  process variables increase
 emission rates  significantly,  more  intensive  maintenance programs might be
 indicated  for  the  higher emission rate sources.  Alternatively, changes in
 design,  construction,  or operation  of these source types could be applied to
 counteract the  emission rate increase caused  by the process variables.   The
 second reason  for  examining these correlations is that numerous correlation
 theories were  proposed at  the outset of the sampling program.  Many people
 felt that  these effects would be borne out by sampling data "without a doubt".
 Thus far,  the  surprises have outnumbered the  expected <_= t-r-v. L s .


           One  constraint which complicates the effort to relate emission
 rates and  process  variables is the  accuracy of recorded  process variables.
 A large  number  of  process  variables were collected for each source screened
 or sampled. (Figure  1).   The amount of time and effort that could be expended
 in collecting  these  variables  was limited by  the schedule and budget, and
 sometimes  the  information  simply was not available.  Age is a good example
 of this  problem.   The  "best"  age to record for a source would be the age
 since maintenance  or installation.   But often the only estimate of age
 available  was  the  age  of the process unit.  FUJI a large number of diverse
 sources  (especially  valves)  It was  impossible to obtain accurate process
 variable information.
                                      266

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R.  L. Honerkamp
                                        DATA SHEET  -  PUMP  SEAL
                                                                                          500
        1. Radian ID//	
                     I   23   45   6  "7   8~
        3. Refinery ID#
                    9
                          I - Inboard
                          0 - Outboard
                                                 Note:  Space 5  should be seal identification
                                                        letter (A,B,C etc.). Use sane ID on
                                                        sampling  sheet.
                                                       In-Service/Out  of Service
                                                        10
        VARIABLES:
        4. Discharge pressure, psig

        5. Temperature, °F

        6. Puajp/seal type

        7. RPM or strokes PM
                              11  12 13  14
        8. Stroke length (Recip, in)
                                    26  27 28  29
        9. Capacity; GPM
                .    IF - product leakage   "I
       10. Seal/lube w-v.cer
                    JH - bydrccarbcra lubricaatl
                                 30 31  32  33  34
                                                35
        PROCESS FLUID DESCRIPTION:
       18. Name
                                               1 N - no quench gland]
                                 11.  Gland type f - mi q-^nch
                                               |^V - water quench  _j
                                 12.  Single or double  (S, D)

                                 13.  Shaft diameter,  in 	

                                 14.  Age,  yrs

                                 15.  Manufacturer
                                              16.  Ktls  of  constr
                                              17.  Horizontal  or vertical (H, V)
                47  48 49.' 50  51  52  53 54  55  56
        SCREENING DATA:
       19. Date of screening

       21. Max TLV

       23. TLV data
                                    -1	L_
                                              20.  Screening  team
                       57  58 59  60   61  62
                                         |1 22.  Liquid  leak?  (Y, N)
                                                                      63 64
                       65  66  67 68  69  70
                                                                         71
                        DATA-
                1C
                    '   '	1	1	'
Eadian IH'J	
           'T  £   3.   4  5   6   T
Screening Concentration,  ppm
                                                 Screening
                                                      Date
                                                              i    '    '	I	L
                                                           9   10   11. 12  13  14
                                                              |Screening
                                                              I     Team
                                                                                           15   16
                                                                                i   t   '	I	L.
         5 Cm
17 13 19 20 21  22

  ~.   .   .   .  I
                                      23 *24 *25 26  *27 28  29 30 31 32  33  34 35  36 37 33 39 40
                       >  t7 68
                                                                                      [SJ
                                                                                      60
               Figure  1   Process  Variable  Data Collection  Sheet
                                                 267

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R. L. Honerkamp
 CONCLUSIONS

           The only dominating effect on emission rate that has been observed
 is related to stream composition.   This effect became evident in the early
 stages of the program.   One problem with this effect was related to the units
 used to describe stream composition.  Refinery streams are primarily multi-
 component hydrocarbon mixtures with wide variations of vapor pressure, molecular
 weight, chemical class (paraffins,  aromatics), viscosity,  etc.  Since stream
 composition changes numerous times  within a single process unit, it was im-
 possible to determine complete stream composition variables for each emission
 source screened or sampled.  The most available type of stream identification
 available was the "stream name", such as atmospheric overhead, debutanizer
 bottoms, reformer reactor outlet,  etc.   The actual composition of streams
 with the same name may vary considerably between refineries depending on crude
 composition,  desired products, operating conditions, and other factors.
 Radian developed a stream identification code system to categorize streams
 based on the most volatile class present in >_ 20 weight percent.  (Figure 2).
 Analysis of emission rates showed three distinct "stream classifications".
 Highest emission rates were observed for sources containing gases or vapors.
 Lower emission rates were observed  for sources containing  light liquid or two
 phase streams,  and sources in heavy liquid service had the lowest emission
 rates.  The split between "light" and "heavy" liquids is approximately between
 heavy naphtha and kerosene.  This  corresponds to a vapor pressure of about
 0.1 psia @ 100°F.  Examination of  other process variables  was performed after
 separating stream categories in order to separate the stream composition effect
 from effects  of other variables.

           For all other process variables, no major significance was observed.
 In some cases a statistically significant correlation coefficient was ob-
 served, but no dominating effects,  other than stream composition, were seen.
 The lack of significant correlations may be due to the dominating effect of
 stream composition, the inaccuracy  of measuring process variables,  the
 variability of  leak rates and measurement techniques,  or combinations of all
 of these.   The  only conclusion that can be made is that stream composition
 is the only dominating  variable. Other correlations either don't exist, or
 the data base isn't accurate enough to  identify them.

 PRESENTATION  OF RESULTS

 COMPLICATING  FACTORS

           There are several peculiarities of fugitive emissions and/or this
 particular data base which make it  difficult to draw conclusions about ob-
 served correlations.   These factors include:

              •   The extreme skewness  of the leak rate data with a large
                   percentage of most source types not leaking

               •   The variability of leaks and leak measurement techniques
                                     268

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R.  L.  Honerkamp
  STREAM GROUP1

  Gas/Vapor
  Light Liquids/Two-Phase
  Heavy Liquids
HYDROCARBON STREAM DESCRIPTION2

Ci-Ca Hydrocarbons
Ca-Ci* Hydrocarbons
Cg-Cg Hydrocarbons
Ci o+ Hydrocarbons
Mixed Molecular Weight Hydrocarbon
      Streams
Aromatic Hydrocarbons
Miscellaneous Organic Compounds
Hydrocarbon Streams Containing H2 ,
      and H20
C2 Hydrocarbons
Cs-Ci* Hydrocarbons
Cs-Cs Hydrocarbons
C?-C9 Hydrocarbons
Naphtha
Light Distillate
Aromatic Hydrocarbons (low molecular
      weight)
Miscellaneous Streams

Kerosene, Diesel, Heating Oil
Gas Oils
Atmospheric Resid/Vacuum Gas Oil
Vacuum Res id/ Asphalt
Aromatics/Polymers
Mixed Molecular Weight Streams
Non-distillate Solvents
Miscellaneous Organic Streams
 'Stream group is determined by the stream conditions within the process lines
 The most volatile stream component present at a concentration of 20% or  m
 determines the stream classification.
              FIGURE 2,  PROCESS STREAM CLASSIFICATION BY GROUP
                                   more
                                      269

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R. L. Honerkamp
             •   The dominating effect of stream composition on
                 leak rates

             •   The inaccuracy or unavailability of process
                 variable data

The effects of the first two factors listed above were minimized by  trans-
forming the data to logio.  This normalized the data and gave homogeneous
variability for all levels of logio leak rates.

          Any discussion of the effect of process variables is complicated by
the confounding between variables in the data base.  This  confounding is due
to the lack of independence between process variables as they naturally occur
and the fact that all combinations of levels of many variables could not be
obtained in the study.  A fractional factorial experimental design was fol-
lowed in selecting sources with selection based on key process variables.
This design allowed the estimation of the main effects of  important  variables,
but not all variable interaction effects could be estimated.  Most second
order interactions (such as stream type by line size, by source type) and
higher order interactions are either confounded or there are not enough
replicate data to quantify by their effects with any precision.  This means
that it is difficult to break sources down by more than two variables at a
time to determine emission factors or effects.

         A good example of the difficulty introduced by the distribution of
leak rates is the effect of line size on flange emission rates.  The percent
of flanges leaking, mean leak rate, and emission factor estimate are shown as
a function of line size in Figure 3.  Although there are significant differ-
ences in percent leaking and a significant effect of line  size on leak rate,
the confidence intervals for the five emission factors all overlap.  Since
this effect of overlapping confidence intervals occurs for many other source
and variable interactions, comparison of emission factors  is not a good way to
determine significance of process variable effects.   For continuous variables,
the simple correlation coefficient "r" is an indicator of statistical sig-
nificance of the correlation.   Discrete variables can be compared visually
by preparing "box and whisker" diagrams.

CONTINUOUS VARIABLES

          At the beginning of the sampling program, several trends were ex-
pected to be present.   The process variables which were expected to  show
greatest significance were:

              •   Pressure

              •   Temperature

              •   Size

              •   Age
                                     270

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R. L.  Honerkamp
           15.0
           10.0
           5.0
           0.0
      ^ t/l   J A
      — uj  -4.0
        is
      Ji
           -5.0
           -6.0
                    I
                                                       2.96 Overall
                                                       Percent
                                                       Leaking
In (Leak Rate) • -6.69 + 0.103 -(Line Size)

Correlaflon Coefficient (r) « 0.34
Standard Error of Estimate « 0.87 In(leak),
                                                       x - estimate

                                                       I - 35% confidence
                                                          interval
                  2468

 Njnber Screened   2471 1189  |   340
                  LINE SIZE (INCHES)
             10  12  14  16  18  20  22   24  26  28  30
                    86
                                      118
     Figure  3   Effect of  line  size on  emissions
                    from flanges
                                            271

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R.  L. Honerkamp
 Increasing pressure might provide increasing  driving  force  for  emissions
 through the sealing element.  Temperature extremes might  adversely affect
 the degradation rate of sealing elements.  Larger sizes would be  expected  to
 have larger potential emission area, and therefore greater  emission rates.
 Age or time since last maintenance was also expected  to result  in increased
 degradation of the sealing element.  None of  these expected  results has been
 conclusively determined from the data base.

          The inaccuracies in determining some of the process variables reduce
 the sensitivity of the correlation analysis.  For instance,  the variable "age"
 recorded was usually the age of the unit.  A more useful  age determination
 would have been the years in service of each  individual source, or  possibly
 the time since last maintenance was done, but it was  impractical  to obtain
 this information for the large number of sources studied.  Therefore, the con-
 clusions concerning process variables pertain to the variables as measured
 or determined in this study.

          Table 1 lists the simple correlation coefficients  between the log
 leak rate and the appropriate continuous process variables  for  each source
 type and stream classification.  Correlations significantly  different than
 zero are noted.  The simple correlation coefficient is a  statistical measure
 of  the linear relationship between  two variables.  The correlation between "X"
 and  "Y" is  computed as:
                             (X.-X)2 Z(Y.-Y):
and is bounded:     -1 < r   < 1.
                          XY


          The value of r2 indicates the approximate percentage of the total
variation in the log leak rate that is accounted for by the relationship of
the leak rate with the correlating variable.  For instance if r = 0.50, then
r2 = 0.25 and about 25 percent of the variation in the leak rate is attri-
butable to the relationship with the process variable.  The remaining 75 per-
cent of the variation is due to other variables and random variation.

          The sampling distribution of values of r is highly dependent on
the sample size.  Small values of r (0.1-0.2) may be statistically significant
for large sample sizes while large values of r (0.4-0.7) may not be signifi-
cant for small sample sizes.  Statistically significant refers to a statis-
tical test of the hypothesis that the correlation is equal to zero , i.e.,
no relationship between the variables.  A significant correlation therefore
does not imply a large value of r, since values of r < 0.2 may be significant
for large sample sizes.
                                     272

-------
to
§
TABLE 1 CORRELATIONS BETWEEN CONTINUOUS VARIABLES AND LOG.n LEAK RATE £
10 03
— i
Pressure
Valves
Raa/Vnpor Streams .230*
Liglit Liquid Ktrcamr, .103*
Heavy Liquid Streams -.351*
Hydrogen Service -.088
Open-Ended .236
Pump Senls
Light Liquid Service .0(18
Heavy Liquid Service .097
Flanges .072
Compressor Seals
Hydrocarbon Service .346*
Hydrogen Service .398*
Drains -
Relief Valves .045
Temperature Ap,n

.077 .263*
.051 .096
.144 .220
.129 -.531*
.242 .230

-.012 .062
-.098 .237
.021 -.180

.218* .105
.312* .052
-.408*
.096
LI HP Slroko
Size DJnmoter Aren RTH Cnpnc.Jty Lond Lcnp.tli

.150* - - - • -
.143* ______
.046 -
.288* ______
-.078 ______

.021 - -.064 -
.128 - -.182 -
.336* ______

.278* - -.143a -.138 -.087 -.012
.343* - -.034 .218 -.099 -.074
-.039 -.191 _
-.075 ______
                 * Correlation Coefficient statistically different from zero (P >  .90).
                   Log ifl  RPM was correlated with login  leak rate.

-------
R. L. Honerkamp
          The correlation coefficient, r, can  sometimes be misleading  for the
following reasons:

          •  r does not describe how much Y changes  for
             a given change in X, what the shape of  the curve
             connecting Y and X is, or how accurately Y can be
             predicted from X.

          •  A correlation between X and Y may be due to  their
             common relation to other variables.

          •  Outliers and highly skewed data can distort  the
             frequency distribution of r.

          •  Selecting values of X at which Y  is measured can
             distort the frequency distribution of r.

          •  r may be unduly high because of sampling from two
             different populations instead of  one.

          In order to examine the actual data  used in calculating the cor-
relations presented here, scatter plots of the log leak rate data (in pounds
per hour) and the process variables were developed.  Several of these plots
have been selected to illustrate the "best" correlations observed.  (Figures
4 through 18).  Each plot selected shows a correlation that was considered to
be statistically significant, and although the correlations are statistically
significant, the data show a lot of scatter throughout the range.  Each plot
shows a line representing the mean value of the correlation.  A one order of
magnitude change in leak rate is indicated by  two solid dots on the line.  In
all cases, the variation of leak rates at given values for the process vari-
able is at least one order of magnitude, while the variation in mean leak rate
across the entire range of the process variable is often less than one order
of magnitude.  These plots represented the process variables which showed the
most significant correlations.  All other continuous variables for all other
source types showed more scattering and less statistical correlation.
Several examples of this scattering are shown  in Figures 19 through 25.
These figures show how the expected correlations were not observed in the
data base.

DISCRETE VARIABLES

          Unlike continuous variables, correlation coefficients are not
easily interpreted for discrete variables versus leak rate.  A visual method
for comparing the relationships between levels of the variable and leak rate
is the schematic plot.  On each plot, the level of the variable is represented
by a "box and whisker" figure that identifies  the mean, median, upper  and
lower quartile and range of values.  Because of small sample sizes and over-
lapping values, most of the correlations with  discrete variables  are  not con-
sidered to be significant.
                                     274

-------
                                                 A = 1 UO.S, H r: 2 UllS.  LT<-.
                                         Correlation Coefficient (r) = 0.230*
                                         Number of Data Pairs       = 157
      t
      t
      t
L   i) «•
U     /
G     /
1     /
it  -1 »•

L     t-
t     f
A  -2 +
K     X
   t
-.5 »
   /
   /
   /
-•» +
                                   AA
                           AA
A<- A
A«- A
       A
  A    A   A
   A      A
      A     A     UAA U
A   A A       A       A
 «  AA A  AA      AHA
  (1A	
            UAA
i\   tl       A A   U   A
 A 0 C     A     A   A
 U  I)     A       A
A A »A      A  A
 U  A    A  A  A
  />      A          A
     A    A
    AH                 A
                                            AA
        A       A
            A
          A
        A  A
                                                                       A
                                                                       A
                                       A   A
                                       A
-f.
     . - > - •
      -V»r
                .4	i	|	
                (I    b I    1UU
                                   200   
-------
L
0
ti
1
0
H
A
t
C
    •f »
   -1
L     /
L     t
A  -2  +
K     /
-3 *•
   *
   *
   t
-14 +
   X
   *
   t
-5 t
   #
   /
   t
"6 »
             «AA
               Mi
                                          LEKLNO: A = i  ousi 0=2 uus» trt.
                                          Correlation Coefficient (r) « 0.150*
                                          Number of Data Pairs      =156
                                                                                                       TO
                                                                                                       t-t
                                                                                                       7?
                        A
                        A
                        A
A
A
            0     3     h     9   1?    Ib    10
                                              ---4..
                                               21
              .4	4.
              >•»    ?7
	+	4
  36    3V

             Figure  5  Leak  rate  vs.  line  size - valves, gas/vapor streams.

-------
                                                   A = 1  (|US, II =
                                           Correlation CoefflclRnt (r) = 0.263*
                                           Number of Data Pairs      = 82
                                                                                                              EC
                                                                                                              O
                                                                                                                 7?
                                                                                                                 P
L
0
G
L
t
A
K

H
A
1
E
 0 +
   t
   i
   t
-1 »
   t
   t
   t
-? *
   t
   *
   t
-.} *
   -i) »
   -b +
      #
      t
      i
   -6 *
•t --- + --- + --- 4 --- f ---
 3   5   7   ?   11  1
                                  --- 4 --- 4 --- 4---4 --- 4 --- 4 --- 4 --- 4
                                    15   17   19  21  i?3   *5  i!7  ^V

                                                   (YEARS)
                                                                       --- 4---4 --- > --- 4-
                                                                        JJ  3S  37  iV
                   Figure 6   Leak rate vs.  age  -  valves,  gas/vapor streams

-------
-4

00
1 »
                                      LElitNO:  A  = 1 UWS,  H = 2 OuS, LTC.

                                     Correlation Coefficient (r) = 0.103*

                                     Number of Data Pairs      = 331
                                                                                                                  o
                                                                                                                  3
                                                                                                                  fp
                                             'IP (I
                                                                               ---+-•
                                                                                1320
                                                     PHtSSUML (HSI6»
                Figure  7  Leak rate vs.  pressure - valves,  light liquid/two phase  streams

-------







L
0
G
1
0
L
t
A
K

K
A
T
C




t
I +
t
0 +
_ t
t
*
-1 »
/
i
t.
-2 +
t
#
-3 +
t
t
t
-H +
<
'
-5 +
<
-b *
*
-7  +
                                            A = I
                                    Correlation Coefficient (r)
                                    Number of Data Pairs
0.143*
3Z6
                                                                                                   CD
                                                                                                   "O
                                                 10
                                                         .- + .
                                                          12
                                                                  m
                                                                           it.
                                                                                    10
 Figure  8   Leak  rate  vs. line size  - valves,  light  liquid/two phase  streams

-------
   -O'.f,
   -1.2
              A
              A «
                                                                A = 1 OHSt  H =  if UnSi
                                                        Correlation Coefficient (r)  =-0.351*
                                                        Number of Data Pairs       » 32
                                                                                                          I
                                                                                                          CD
N>
oo
o
L  -1.0  4
0       t
G       y
1       /
n  -;>.n  4
             L
             L
             A
             K
t
t
   -3-0
   -M.O 4
        »
        /
        y
   - 5. 'I +
             ,f	^	4..
             II     fcSO    r)0ll
                                             750   1000   12t>0   IbOU   1 ^5U   ?OUO   2y-i«   ?300   27SO   300U
           Figure 9   Leak rate vs. pressure  - valves,  heavy  liquid  streams.

-------
L
0
G
1
0

L
E
fl
K

H
A
T
t
                                                   «  =  1 ()IJ8i t) = 2 
                                                                                                                     i-i
                                                                                                                     7^
                                                                                                                     1
         l.nn
'I. SI)
O.UO
---+-.
 9.'5
11.50   13. ?
lb.00
• -_ +	
16.75
18.50   20,25  22.00  23.75
             Figure 10   Leak  rate  vs.  line size  -  valves,  hydrogen streams.

-------
NS
00
NJ
L
0
G
1
0

L
t
A
K

H
A
T
                  ii.n
                 -l.fe
-3.2 4
     1
     t
     1
-'l.O •»
     1
     1
     t
-'».»> +
     1
     t
     1
-3.6 +
                 -fp.'t
                                     A
                                     H
                                                            LE.bt.riU! A = 1 ObSt H = 2 OnS«
                                                            Correlation Coefficient (r) • -0.531*
                                                            Number of Data Pairs      * 33
                                                                                                                               (D
                                                                                                                               1-1
                                                                                                                               7?

                                                                                                                               1
                                     2    'I    f,    0   10   12   1't   16   10  20  22  2'l  *f>  20  -id  32  3«l
                                                                     L (YEARS)
                               Figure  11   Leak  rate vs.  age -  valves,  hydrogen  streams

-------
                 1.6
                                                            :  A  = l.«»S«  » = 2 UPS,
                                                      Correlation  Coefficient (r) • 0.346
                                                      Number of Data Pairs      « 10Z
                                                                                                     I
N3
00
             L
             0
             (4
             1
             a

             L
             t
             A
             K
   u.n 4
   o.o 4
     •  1
       i
       t
   -u«8 +
   -1.6
n  -«

l
L
                                 rtA
                                                                                                                   I
                -'••0  4
                     i
                     i
                     t
                -'(.«  f
                     r
                                    eo
                                                                               '([10   '110
                                                                            •-4 -•
                                                                            •too
                                                                                                    bbU
                Figure  12  Leak rate vs.  pressure  - compressor seals,  hydrocarbon service

-------
                                                        A = I  (IMS, M = 2
                                                  Correlation Coefficient (r) = 0.218
                                                  Number of Data Pairs     « 102
oo
          t.
          0
          o
          1
          II

          L
          L
          l\
          K

                                                                                                             o
                                                                                                             0
                                                                                                             (D
                                                                                                             i
            Figure  13  Leak rate  vs. temperature - compressor seals,  hydrocarbon service,

-------
                                                     Correlation Coefficient (r) = O.Z70

                                                     Number of Data Pairs      • 00
IS3

OO
                                                                                                                  Pi
                                                                                                                  o
                                                                                                                  I
3.0
                                                         A . b       i« , (I




                                                          ILK (1NCMKS)
'•.5
                                   S.O
5.5
t>.0
                Figure  14  Leak rate vs.  diameter - compressor seals, hydrocarbon  service.

-------
to
oo
L
U
0
1
0

L
t
A
K

H
A
I
L
                  n.o 4
                     y
                 - U • <> 4
                  1.2 +
                     f
                     t
                     i
                  1»R 4
                     *
                  2.M 4
                 -3.0 4
                 -3.6 4
                                                              ft a  \ 0»Si  U = 2
                                                       Correlation Coefficient (r) » 0.398*
                                                       Humber of Data Pairs      = 62
                                                                                                                en
                                                                                                                o
                                                                                                                0
                                                                                                                n>
                                    H

                                    A
                                                                                       souo
                                                                                   ..-.-+--
                                                                                     3bUU
                  Figure  15  Leak rate vs.  pressure  - compressor seals,  hydrogen service.

-------
                 1
             il. 0 *
                                          Lt.bt.NU:  A  = 1 (»MS«  H  = 2 OHS»  t|t,
                                          Correlation  Coorricicnt (r) • 0.311
                                          Number of Data Pairs      = 59
to
            -o
       *
   -1.2 +
L      /
0  '    /
G    ,  1
1  -l.B *
0    .  t

L      t
t  -2.4 »
A      X
K    -  *
       t
K  -J.O »
A      *
 r      /
t      /
                                                                                                                      -I
                                                 0

                                                 A
                            .«!    00   96
                                                                            4-00
                                                                                       2MO
                                                      I tMPtl
-------
            -1.2
         L  '
         0    "
         G
         1  -JUH
         0
L
E
A
K
            -2. "I  *
1-0
00
00
M
A
T
c
   -3-0
            -3.6
            -H.2 4
                                                          I! A =  )  UHS, M = 2 U|1S«  ML,
                                                    Correlation Coefficient (r) • 0.343
                                                    Number of Data Pairs      « 27
                                                                                                                       8s
                                                                                                                       0
                                                                                                                       0>
                                                                                                                       f-t
            -ll.f.  (
                                                                                                              I
            -'1.0 +
                1

                    V. . I) It
                                      3.00
                                                   3.50
--«•--	4--
'I.UO    1.
  4.	_.-4.__- — -4.-.
»»,50   H.75   5.«0
               Figure 17  Leak  rate vs.  diameter  -  compressor  seals,  hydrogen service.

-------
                                                      Lf. GLNU: A = 1  (JUS. b = ? U»S'  tfC-
                                                      Correlation Coefficient (r) « 0.336*
                                                      Number of Data Pairs      = 60
00
L
0
G

1
0

L
E
A
K
R
A
T
E
                                                                                                                          TO
                                                                                                                          H


                                                                                                                          I
                                                       LlNt.
                                                                 (1MCMLS)
                                  Figure 18   Leak rate  vs.  line  size -  flanges

-------
NJ
*£>
O
/
1 +
t
1
1
0 ^
t
t
t
L -1 *
0 t
G 1-
1 t
0 --2 +
*
L /
L /
A -5 •»
K t
f
U /
A -'« +
T /
t /
1
-5 +
/
t
t
-t, *
f
-7 *




A
A
U
t.
• 	 U-
A 0
C
L
(\
A






n






A
A
A
t
U
l\

-U—
A
A
11
A
II


1)









Jl


A
II
t
n
L
—A- 	
U U
A
n
C «













5 7
uurreiai ion v
Number of Dat
A
A A
A A
t A
AW U
A A n A t
U L U
— 	 	 	 TI 	 0 A
U 13 A
ti
U
A A
tt A
U A
A



n






V 11 U 10 17 19 *i
.Uf 1 1 H. ! Ulll \I / " V.VJV
:a Pairs = 181
A
A
A
A
U B
ABA
A A D
A U A A
ti A 	 — 	 6 	 — 	 ~ 	 ~ 	
A A
AD C
A A
A B
A B
A U A
B
A
A









26 Kb i!7 i!V 31 33 35 37 iV MI
                                                                                                   1
                                                    AOL (YEARS)
                Figure 19  Leak  rate vs.  age - valves,  light  liquid/two phase  streams

-------
to
                        A
              A
             II AH
                A
             A   M
             MC  A H     A
                     A A   A
                                      A

                                    A A
2 t
      1
    1  4
      t

      t    A  A A
    0  4 A   A ft
L     *   A  A
0     /A   AAUA
G     /A CTtA AA CUHAAA U  A
1  -1  4      nnCAB  u&n AUAU
0     «AA A A MA AOHt C A A 0
      /AA A tAA A  OUAA  AA U   A
L     fAHAl'ACAH AtlAAHUAA AAA A
1-24    AMtAA A t HA  OA
A     t    A  CHA «AA ARCO AA
K     JAMAA  1) AA  A A     AA

K  -3 +      HA A   ft         A
A     t         A  UCA       A
T     t      A  A    AAA
L     t  A AA
   -M 4                    A
                                              A
                                              A A
                                             A A
                                                  A
                                               A AB
                                                A
                                                A A
                                                 B
                                                                A = 1 OUSi » =  2  U|)S,
                                                        Correlation Coefficient (r) »  -0.012
                                                        Number of Data Pairs       =  291
                                                                                                                         (0
                                                                                                                         I-J
                                                                                                                         7?
                                                                                                                         I
      <
   -S 4    A A
      t
      t    A
      t
   -6 +
      *
      -4	1	
       o      jf,u
                  Zd     MOU
                                                faMO     000
                                                               V6U    1120
                                                                              1
-------
N3
                                                   iLfctwo: A = i  o»s. a s v <>,,s, LT*-,

                                                   Correlation Coefficient (r) • -0,012









L
0
b
1
0

L
t
A
K

H
A
t
L











t
* *
t
t
1 +
t
i
t
0 *
/.
t
t
-I +
*
t
t
-2 *
t
t
t
-3 +
t
/
*
-i| +
i
t
t
-5 +
t
•t
t
-6 +
t

v v * i u i a v ' un t*u u i i i ^. i T; 1 1 1. \i/ ~ w ( v 1 1
Number of Data Pairs • 294

A
n
A
A HC A
AAA A
AA IIAA A A A
A AAA H A A A A A
A A CtU AAA A A
A CA UtILU AAA8A A A A
A A OG A C A AAA AAA
A A DUO AA A A A AA AA
UCAUAtAA A AA A BA «
A l\ CCfl UHA AA A AAUA A A A
A A AAU'lUB A A A AAA A
A A 0 C UAU A A 0 A . A
AU tAA A A A A A
A f I-AU A A A
A If A A A A
AAUDA A A
OAA A
II A
A



A A

A



-f.u i) bo i?u jnn z'io 300 4&o 'tyu MHO SMO 600 f-^o 720 /ou
                                                                                                                o
                                                                                                                0
                                                                                                                n>
                                                                                                                I
                                                    TtMI'LKATUKt I ^ I
                 Figure  21  Leak rate vs.  temperature - pump seals, light liquid  service,

-------
OJ
                                                           A = i cms. u =. a unsi tn-

                                                    Correlation Coefficient (r) • 0.062
t
? +
t
t
1
1 *
*
/
0 *
u t
o /
b *
i -i *
o t
f
L #
e. -2 *
A t
K *
/
» -3 «•
A t
T t
E /
-'i t
*
*
-0 +
*
*
*
-fc +
*

Number of Data Pairs = 140


A

A A
« U
A A A
A A A ti
n A A A A B A A
AAAA AA AD H
t H B A A B A
A 11 A A BA n A U
A t) A A H B A A
AAAl) BA tAt
U A A A A A
AC AA B A A AH
A A A B B U
rt A B U A A
A A U A
A AAAA
A A




A











A

A "
A

A A


A A


B

A


A









	 + _, 	 4. 	 . 	 -_-«.
                                                                                                                     o
                                                                                                                     3
                                                                                                                     n>
                       O.'j   3.5   fc.b   9.5  12.5  lb.5  l«.5  21.b  ?M.5  27.5  3".5  53.5  36.5  3V.5



                                                           AGL (YEARS)
                       Figure  22   Leak  rate  vs.  age -  pump  seals, light  liquid service

-------



L
0
(,
I
I)

L
L
A
K

H
A.
T
E









*
2 +
t
t
I +
*
1
0 +
*
t
t
-1 *
it\
1
to
-2 «•
t
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*A
-3 +
/
t
t
-t +
t
-5 +
1
t
t
-f, *
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A
A
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U
U
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^
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n
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IV


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o
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1.4
feV 1 1 C 1 <
Number
A
u

c
u
u
G
c
u
t
J
e
i
F
G
H
t
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2.0
ni IUH \AJC i i i u ten t \ i
of Data Pairs
A
A
A
u
A
C
L
U
U
1)
C
c

A
B
U

A








2.6
f — V * UC. t
= 295
A
A
A A
A
A
t) B
C
U A B
n A
H A
A
C A
U
A
A A
A

A

A

A

A



3.2 3.8
                             UlAdtTtH
Figure 23  Leak rate vs.  diameter - pump seals, light liquid service.

-------
                                                  A =
                                           Correlation Coefficient (r) » 0.105
                                           Number of Data Pairs      = BO
                                                                                            PC
                                                                                            o
                                                                                            n>
L
0
        t
        1
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        Figure 24  Leak  rate  vs.  age  -  compressor seals,  hydrocarbon  service

-------
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                    Figure 25   Leak  rate vs.  pressure  - relief valves

-------
R.  L.
          Several trends were expected to exist for discrete variables.
 Control valves were expected to  leak more then block valves because of a
 higher frequency of operation.   Vibration was expected to be directly pro-
 portional to leak rate.  Packed,  single mechanical, and double mechanical
 seals were expected to represent the range of highest to lowest emission rates.
 It was also speculated that sources  made by different manufacturers would
 exhibit different emission rates.  Several examples of discrete variable
 correlations are shown in Figures  26 through 34.

 CONCLUDING REMARKS

          Even  the  "most  significant"  correlations observed showed a lot of
 scattered data  and  the correlations  were not dramatic.  The only exception to
 this is the effect  observed  for  stream composition.  These results do not
 necessarily indicate  that correlations between emission rates and process
 variables are nonexistent.   There were several factors discussed previously
 which probably  explain why no  significant correlations were observed, and
 therefore no  conclusions  can be  drawn  from the observed results.  As fugitive
 emissions become  subject  to  regulatory constraints, additional data may be
 collected by  the  regulated industries.  This expanded data base'may eventually
 reveal significant  correlations  between process variables and fugitive emis-
 sion rates.
                                      297

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-------
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-------
A. F. Pope
                                   REVIEW

                                     by

                                A.  F.  Pope
                      ARCO Petroleum Products Company
                               A Division of
                        Atlantic  Richfield  Company
                          Los Angeles, California
                                     on
           CORRELATION OF FUGITIVE  EMISSION  RATES FROM  BAGGABLE
                  SOURCES WITH REFINERY PROCESS VARIABLES
                                   RESUME

         Arthur F. Pope  is  the Manager, Environmental Policy and Planning,
 for ARCO Petroleum Products  Company,  a division of Atlantic Richfield
 Company.  He received his B.S. degree in Mechanical Engineering from the
 University of Detroit in 1969.   Since 1974,  he has worked  for Atlantic
 Richfield as a Project Engineer, Manager, Air and Water  Conservation, and
 Manager, Environmental and  Energy  Conservation, at the Watson refinery,
 Carson, California.  He  has  participated in  the several  projects conducted
 by EPA and the California Air Resources Board which attempted to ascertain
 atmospheric emissions of VOC from  refinery sources, including valves, during
 his assignments at the Watson refinery.
                                     307

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A. F. Pope
                                  REVIEW

                                    by

                                A. F. Pope
                      ARCO Petroleum Products  Company
                               A Division  of
                        Atlantic Richfield Company
                          Los  Angeles,  California

                                    on

           CORRELATION OF FUGITIVE EMISSION RATES FROM BAGGABLE
                  SOURCES  WITH REFINERY PROCESS  VARIABLES

INTRODUCTION

         Refinery fugitive VOC emissions have been studied a number of times,
starting in 1957 with the Joint Study1 of the then Los Angeles County Air
Pollution Control District and culminating most recently with the completion
of the EPA/RADIAN program under discussion at this Symposium.  The Atlantic
Richfield Watson refinery has been involved in each of these studies except
the recent RADIAN effort.  Therefore, the observations made in these previous
studies should be useful in comparing the results from our experiences with
the results from facilities examined by RADIAN.  I will limit my discussion
to the subject of R. L. Honerkamp's paper, "Correlation of Fugitive Emission
Rates From Baggable Sources With Refinery Process Variables."

         The data I will present corroberates what Honerkamp found—the
dominating correlation is stream composition.  I will also suggest that, for
refinery valves at least, process unit designations may be more suitable and
are certainly more practical than specific stream composition in designing
inspection and maintenance programs for refinery fugitive VOC sources.
                                    308

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A.  F.  Pope
DISCUSSION

         As reported by J. H. Nakagama2 at  a previous  EPA/RADIAN workshop
on this subject at Jekyll Island, Georgia,  in  1978, Atlantic  Richfield
Company undertook a study of all the valves and  fittings  in one of  its  crude
oil distillation units.  The objective of this study was  to assess  the  costs
that would be incurred .for the inspection of all valves and fittings  for the
detection of any leaks, using a soap-solution  method.  Of the more  than
11,000 potential leak sources checked in this  38,000 B/D  crude unit,  38
leaks were discovered.  Thirty-one leaks were  repaired with the unit
on-stream.

         Subsequent to this study, the California Air  Resources Board,  using
enforcement personnel, conducted a two-week study of refinery valves  and
flanges in the South Coast Air Basin including Watson.  Upon  reinspection of
this same crude oil distillation unit, using soap-solution methods, no  leaks
were found.  Approximately eight months had elapsed between studies.

         Some conclusions that can be reached  are:  (1) once  repaired,  crude
oil distillation unit valves and fittings will not begin  to leak for  at
least eight months, and (2) crude oil distillation unit process stream  con-
ditions of pressure, temperature, stream composition,  etc., collectively
yield a low probability that a component will  be found to be  leaking, when-
ever it is inspected.

         In each of the studies mentioned,  virtually all  valves and flanges
were examined.  As a result, it would be more  accurate to say that  these
studies had characterized the emission factor  for the  valves  for that speci-
fic crude oil distillation unit, rather than the emission factor for  the
category of valves in general.  Indeed, the data ought not be considered in
statistical analysis, since the valves were not  selected  on a random  basis.
Therefore, it is not possible to compare these results directly with  results
obtained by RADIAN.

         However, these data and that which I  am about to describe  generally
support the finding that stream composition is an appropriate variable  to
consider when developing fugitive emission  control strategies and that, as
noted in the crude oil distillation unit case, the composite  effect of  the
process variables associated with a process unit may be more  practical  in
identifying those refinery sources which have  a  higher probability  that an
individual component within that process unit  will be  found to be leaking.
                                     309

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A. F. Pope
         While Atlantic Richfield Company disagreed3 with the inspection
methodology and the conclusions reached by the California Air Resources
Board enforcement personnel, some insight on the composite effect of process
variables can be gleaned from the data obtained during this effort.  The
process units inspected at Watson included the crude oil distillation unit
mentioned previously, two additional crude oil distillation units, an
alkylation unit, a super fractionation and isomerization (SFIA) unit, and
LPG storage vessels and associated transfer piping.

         The refinery obtained duplicate gas samples of each component which
was bagged by GARB and analyzed the sampes for VOC.  Using the GARB leak rate
measurement and the mass spectrometer results from the refinery laboratory,
the following estimated emission factors were developed for the valves and
flanges associated with each specific process unit:

                           VOC EMISSION FACTOR
      UNIT TYPE                LB/DAY/VALVE           LEAKING MATERIAL

      Crude                     0                     N/A

      Alkylation                0.0299                Butanes

      SFIA                      0.0362                Light Gasoline
                                                        Components

      LPG                       0.0596                LPG
         These emission factors incorporate all the variables possible for
each process unit without the need to determine their individual influence.
In general terms, these factors also indicate that the stream composition
plays a significant part in the unit emission factor, i.e., the lighter and
higher pressure streams exhibited higher leak rates.

         A crude oil distillation unit will have many different streams at
different temperatures, compositions, and pressures.  This type of unit was
found not to have any leaks.  At the other end of the spectrum, the LPG
facilities handle a single stream at relatively constant temperature and
pressure and was found to leak most.  If one were to consider all streams
within a process unit and determine an "average" stream, the stream compo-
sition effect is easily seen.
                                     310

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A. F. Pope
CONCLUSIONS

         Several conclusions  concerning  fugitive VOC  emissions result from
the preceding discussion:

         1.  Process unit VOC emission factors  for valves correlate
             well with "average"  stream  composition.

         2.  Process unit designation offers  a  more practical
             method for evaluating  fugitive emission  control
             strategies than  stream type.

         3.  Process unit designation minimizes the problem of
             attempting to  correlate a multiplicity of process
             variables, including component age, line size,
             pressure, temperature,  and  stream  composition.

         4.  The data discussed support  the conclusion of
             R. L. Honerkamp  that the dominating correlation
             is stream composition.

REFERENCES

1.  "Joint District, Federal, and State  Project for the Evaluation of
    Refinery Emissions," Los  Angeles Air Pollution Control District,1957.

2.  "Inspection and Monitoring Concepts  for Refinery  Fugitive Emissions,"
    J. H. Nakagama, 1978.

3.  Letter, N. E. Pennels  (Atlantic Richfield Company) to J. J. Morgester
    (California Air Resources Board), May 5,  1978.
                                     311

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R. L. Honerkamp
                           QUESTIONS  AND ANSWERS

Q.  James Stone/Louisiana Air Control Commission - The first question,
maybe frivolous.  Did you assess operator motivation as a variable?  In
other words, in an HF alkylation unit, he is very likely to see to it that
any leak is repaired immediately, while in some other units, like a coker
nothing dripping is going to hurt him, so he wouldn't go after the leak
quite as fast.

A. - No!  We did not attempt to assess that particular variable.  The results
that I presented here were not really a documentation of any existing main-
tenance practices, but based on the entire data base collected from the
thirteen refineries nation-wide.  All sources in the stream composition
service shown pose the effect of the process variables on the emission rate.
But, perhaps looking at it on a unit basis, as Art Pope suggested, might show
differences that could be attributable to that factor.  But, I don't have any
data that I could present that would show how that effect could be quantified.
Art, do you have anything else?

COMMENT/A. F. Pope/ARCO Petroleum Products Company - One of the units in the
study that I did not present any information on was that in our plant we
happened to have a benzene unit and there were no high VOC emissions from
that unit.  There were some hydrogen leaks, but there were no VOC leaks.
So, that might tend to answer your question.

Q.  James Stone/Louisiana Air Control Commission - The second question is
that you have been putting a lot of effort into your statistical evaluation
of the data.  Do you think that a statistical approach would have validity
in regulations which we might write to cover maintenance of this type?

A._ - I think it certainly might, although I don't think that any of the
correlations presented here this morning other than stream compositions are
significant enough to warrant such attention.  All the variations that we
saw were primarily about an order of magnitude variation in leak rate
throughout the entire range of the variable.  Although there were much
greater variations than that at individual values.  So, based on that I
don't think we can conclude that any particular temperature range or pressure
                                     312

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R. L.  Honerkamp
range should have more or less frequent inspection  of maintenance.  Although
the effect does seem to be there as far as stream composition.

Q.  James Stone/Louisiana Air Control Commission -  What  I  really mean  is
that we have a regulation in Louisiana that says that best practical main-
tenance shall be used at all times in a refinery.   And,  as we inspect  the
place, if we pick a statistical number of valves rather  than try to inspect
everything on paper, and if we find that below a certain number is leaking,
they are in compliance, and above a certain number,  they would be considered
to be in violation of that regulation.

A.   (By Rosebrook) - Lloyd Provost has a very definite view on that.   The
line of reasoning is that he can, given a sufficient data  base for the
enforcement people to work with, he can set confidence intervals based on
the  time since the refinery last did their inspection and  maintenance  in a
particular unit, he feels very strongly a set of numbers could be developed
which would allow you to come in and for example screen  100 valves or  200
valves, rather than screening the entire unit.  If  you find a certain  number
leaking then you could call it a violation with some kind  of confidence, if
you  find some leaking but not the limiting number then it  should not be a
violation.  I can't go through that explanation near as  well as Mr. Provost,
and  perhaps we can at least have you get together with him to answer that
question.

A.   (By Honerkamp) - One thing that such a scheme does require is that
several variables be understood.  Those variables will be  discussed in
greater detail in the final paper that EPA will present  this afternoon,
those include:  what level of repairs are achievable; and, how long after
repair do the leaks reoccur.  You must know, with confidence, what those
factors are before you can attempt to develop the statistical enforcement
program.

COMMENT/Person unknown - I encourage the regulators not  to write that  number
as zero.  The data that you have seen would tell you that  on any given day,
in any given plant, there is going to be at least one component that is
going to leak to some degree or another.  And, what I am trying to tell you
is that if you have a nonattainment area and you have a  source requesting a
permit, and that source has to certify that he is in compliance with all
federal, state, and local regulations, under penalty of  perjury, how can he
do that if you have a regulation that requires all  discrete components in a
plant, not to leak.  That is a no growth regulation.
                                     313

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R. L. Honerkamp
Q.  Nancy A. Kilbourn/PEDCo Environmental, Inc. - My first question is how
much did it cost Atlantic Richfield to monitor all the valves?  And, my
second question is how much do you think that you will save after you
establish an I and M (inspection and maintenance) program?

A.  (By Pope) - We are subject to California regulation now and have been
for almost a year to conduct I and M in the Southern California area at our
Watson refinery, and we have utilized the resources of a contractor to do
that inspection and minor maintenance work.  The costs this year are going
to run on the order of $100,000 to do the inspection and perhaps another
$50,000 to do some special repairs on-line, to avoid shutting down unit to
make that repair.  The State of California regulation for your information,
has a maintenance provision in it.  It allows two working days from the
discovery of a leak to repair it to a no-leak condition.  And, a leak in
this case is 10,000 ppm at 1 cm.  A repair is 1,000 ppm at 1 cm.

Q.  R. L. Honerkamp/Radian - Do those numbers include regular maintenance or
is that just special maintenance?

A.  (By Pope) - No, that is just special maintenance for this program.
There would be additional costs to the number that I gave you for the
contractors costs to us, the internal cost of our own people.  I'm really
not sure what they are at this point.  It would be more.

Q.  Nancy A. Kilbourn/PEDCo Environmental, Inc. - How much do you think you
would save then in recovering your volatile organic compounds?

A.  (By Pope) - I don't have a number for you.

Q.  James Stone/Louisiana Air Control Commission - Just going to follow-up
on that same question.  When your contractor does that sampling, do they
sample all valves or flanges or do they use some percentage to work by?

A.  (By Pope) - No, the regulation we are subject to, requires a comprehen-
sive inspection of all valves.  Flanges are not included.

Q.  James Stone/Louisiana Air Control Commission - How many is that?  How
many valves for your facility?

A.  (By Pope) - I think we estimated, since we don't really have a complete
count with a high degree of accuracy, something on the order of 100,000 to
130,000 components.  They are $1.60 a piece to check if you want.
                                     314

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R. L. Honerkamp
Q.  K. C. Hustvedt/US-EPA-RTP - On  the whisker  diagrams,  looking  at  the
difference between the block valves and  the  control  valves,  the emission
factors before you crossed the lines  looked  like  the same  for all three
process stream variables; the gas,  the light liquid,  and  the heavy liquid.
I think that it has biased the diagrams  by excluding the  nonleakers  from
them.  You are showing emission factors  that are  not the  real emission
factors.

A_._ - But I am showing leak rates  for  the ones that did  leak.  As  I pointed
out in the beginning, the combination of that effect  plus  the effect on the
percent that leaks, i.e. how many that don't leak at  all,  is what results in
the emission factor.  But rather  than look at emission  factors for my pre-
sentation I looked at just the effect on the ones that were leaking.  Since
there were no dramatic effects that were going  to be  shown at all, I felt
that it would be more interesting to  look at the  effect on the ones  that
did leak, rather than whether or  not  they leaked  at  all.   That effect has
been split out in the stream category designation.

Q.  K. C. Hustvedt/US-EPA-RTP - To  completely compare the  two between block
and control valves you have to know what your total  population looked like,
not just some arbitrary subset, say over 200 ppm, to be able to compare the
effects of those if 90 percent of the block  valves did not leak and  50
percent of the control valves did not leak.   Just comparing their average
emission factors for leakers doesn't  tell you on  the  average if block valves
or control valves leak more or less.  You have  to look at  the total  popula-
tion, I would think, to see what  a  real  true comparison between what the
effect of those two is, not a subset  based on an  arbitrary cutoff.

A_._ - We weren't looking at the effect on emission factor,  but the effect on
the ones that leaked.  It is true that if such  an effect did exist that
emission factors were significantly different for block and controlled valves,
that would have been the incorrect  presentation to look at.  I don't believe
such an effect, on emission factors does exist, as far  as  block and  control
valves.  That is, I think the confidence intervals probably do overlap
significantly, if you look at emission factors.   But  it is true,  that what
we looked at were just the ones that  were leaking.

Q.  A. F. Pope/ARCO Petroleum Products Company  -  I would  like to  encourage
you not to think just of the components, as  I mentioned in my discussion.  I
think you will be better served in  looking at this whole  spectrum of things
that need to be done on a practical level.   The people  out there  like myself
have to implement something.  If  you  can focus  on getting  to where you want
                                    315

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R. L. Honerkamp
to go in a practical manner, some of these discrete things you might like
to evaluate would be good to know, and perhaps will be helpful in
redesigning components for minimizing losses from those components.  But
in terms of I & M programs, I don't think that they are really worthy of
the significant effort to characterize them in a very discrete manner.
                                     316

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R. G.  Wetherold/S. L. Preston
          THE EFFECT OF MAINTENANCE PROCEDURES ON THE REDUCTION OF

                FUGITIVE HYDROCARBON EMISSIONS FROM VALVES IN

                             PETROLEUM REFINERIES

                      R. G. Wetherold and S. L. Preston
                              Radian Corporation
                                Austin, Texas


                                   ABSTRACT

           Regulations  pertaining to the screening and maintenance  of  refinery
  process valves are being  proposed by regulatory agencies.   Under an EPA
  contract, Radian has studied the effect of simple maintenance  practices  on
  the  reduction of hydrocarbon emissions from refinery valves.   The  results
  are  presented here.  Included in the study were block and  control  valves in
  the  major types of refinery process stream services.  The  reduction in
  hydrocarbon emissions  after maintenance was determined for  valves  having
  initial leak rates ranging from large to small.   The merits of hydrocarbon
  monitoring during the  performance of maintenance were evaluated.   Finally,
  the  effectiveness of valve maintenance over short (one week) and long
  (six months) time periods was investigated.

                                    RESUME
                               R. G. Wetherold
           Robert G. Wetherold is a Senior  Staff Engineer at Radian Corpora-
  tion in Austin, Texas.  He is currently Project Director for several
  programs associated with  the study of fugitive emissions from  petroleum
  refineries and chemical plants.   He received his B.S. in chemical  engineer-
  ing  from Texas A&I University,  a M.S.  in chemical engineering  from Texas A&M
  University, and his Ph.D. from the University of Texas at  Austin.  Before
  coming to Radian, he was  employed as an Associate Engineer in  the  Process
  Development Division of Mobil Chemical Company.   He also worked in the
  Process Design Division of Chevron Research Company.  He is a  member  of
  AIChE.

                              Sheryl L. Preston

           Sheryl Preston  is a Data Management Specialist at Radian Corpora-
  tion.  She has a B.S.  from the University of Arizona, and  is currently  in  a
  Masters program at the University of Texas.  She is a member of ASQC.  For
  the  past 3 years she has  managed the Fugitive Emissions from Petroleum
  Refining data base at  Radian and contributed in data analysis.
                                      317

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R. G. Wetherold/S. L. Preston
          THE EFFECT OF MAINTENANCE PROCEDURES ON THE REDUCTION OF

                FUGITIVE  HYDROCARBON EMISSIONS FROM VALVES IN

                            PETROLEUM REFINERIES
          The effects of relatively simple maintenance procedures on the
reduction of fugitive emissions must be defined to evaluate the cost
effectiveness of inspection and maintenance procedures.  The reduction of
fugitive hydrocarbon emissions from valves as a result of maintenance has
been studied as part of the EPA's program for the environmental assessment of
petroleum refineries.  The emission reduction study is described in this
paper.  The results of the study are presented.


OBJECTIVES

          The objectives of this maintenance study are given below:

               •   To select for the program those fugitive hydro-
                   carbon emission sources which could be studied
                   in the most cost-effective manner.

               •   To define a group of the selected emission sources
                   which would provide a representative sample for the
                   maintenance study.

               •   To determine the immediate effects of directed and
                   undirected maintenance activities on the reduction
                   of hydrocarbon emissions.

               •   To define the short and long-term effects of main-
                   tenance procedures on the reduction of fugitive
                   hydrocarbon emissions.


MAINTENANCE PROCEDURES

          The six "baggable" sources were all considered for maintenance
studies in this program.  These sources include valves, flanges, pump seals,
compressor seals, relief valves, and drains.  The types of maintenance con-
sidered for each source are described below.  They are listed in order of
increasing difficulty, complexity, and generally, cost.
                                      318

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R. G.  Wetherold/S. L. Preston
          The majority  of  valves  in refineries  are  gate  valves  (on/off) and
 globe valves  (control).  Plug valves are  also present.   The  types of main-
 tenance considered  for  valves include:

               •    Tightening packing gland nuts (gate and  globe valves)

               •    Adding  grease  (plug valve)

               •    Replacing  the  valve packing

               •    Injecting  sealant into the packing area

               •    Replacing  the  entire valve

          Pump seals  are either of  the packed or mechanical types.  The main-
 tenance procedures  applicable to  these seals are:

               •    Tightening of  the packing gland nuts  (packed seal)

               •    Replacement of the packing (packed seal)

               •    Replacement of the mechanical seal

          The maintenance  of  compressor seals takes the  same form as that of
 pump seals.   Included are:

               •    Tightening of  the packing gland nuts  (packed seal)

               •    Replacement of the packing

               •    Replacement of the mechanical seal

          Repair of flange  leaks  can generally be accomplished by one of
 these procedures:

               •    Tightening of  the flange bolts

               •    Replacing  the  flange gasket

               •    Replacement of the flange or flange face

          Those pressure relief valves  venting to the atmosphere were also
 considered for maintenance  studies.   If these devices are leaking through
 the valve seat to the atmosphere, mechanical repairs are generally required.
 If a dual relief or manual  bypass system  is available, the more simple
 mechanical repairs  might be made  with the valve in the line but blocked out
 of service.   In many  cases, however,  the  entire valve must be removed and
 repaired.
                                      319

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R. G. Wetherold/S. L. Preston
          There is generally no simple maintenance procedure that can be
used to reduce emissions from open drains.  The drainage system must be
revamped to include items such as covers and traps.


EXPERIMENTAL DESIGN OF THE MAINTENANCE STUDY

          It was not possible to study the effectiveness of various types
of maintenance on all six baggable source types.  The study was limited by
time, funds, and practical considerations in an operating refinery.  As an
aid in the definition of a useful but limited program, the total emissions
from the six source types in the major process units of a refinery were
estimated.  The Gulf Coast Cluster Model Refinery developed by A. D. Little,
Inc.1 was used as a basis to these estimates.  The number of sources in each
unit were developed from source counts made during the course of the sampling
program or from source counts of relatively similar process units.

          The estimated total number of baggable source types in each major
process unit is shown in Table I.  In Table II the estimated percentage of
leaking source types and the relative emission contribution of these sources
are presented.  The most numerous source types are valves and flanges.  How-
ever, the percentage of flanges that leak is quite low, and their contribution
to the total emissions is small.  A considerable amount of time would be
required to locate a sufficient number of leaking flanges for a satisfactory
sample size.

          Valves are quite numerous, over a third of them leak, and they
contribute 60 percent of the baggable source emissions.  Preliminary studies
indicated that a significant reduction in valve emissions could be achieved
through simple maintenance.

          Nearly half of all inspected pump seals leaked to some degree.
With the exception of valves, pump seals contribute more emissions than any
other source type.  In the case of packed seals, simple maintenance consists
of tightening the packing gland.  This can be done while the pump is in
service.  Leaking mechanical seals must be replaced.  The pump must be taken
out of service to make this replacement.  Refineries generally have spare
pumps which can be quickly placed in service in place of many of the more
important pumps.  Thus, in many cases, a pump can be taken out of service
for maintenance without disrupting the process.

          The majority of compressor seals leak.  Because there are relatively
few of them, however, their emissions are only 9 percent of the total baggable
source emissions.  Additionally, maintenance of packed seals and replacement  of
mechanical seals can be a major procedure.  In many cases, the process would
have to be shut down to repair or replace the compressor seals.

          Maintenance of relief valves is also not an insignificant viffort.
While over a third of the inspected relief valves leaked, the emissions only
make up 4 percent of the total baggable source emissions.
                                     320

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          TABLE I.  ESTIMATED DISTRIBUTION  OF FUGITIVE EMISSION SOURCE TYPES IN MAJOR PROCESS  UNITS OF A
                    HYPOTHETICAL REFINERY3
OJ
N)
Process Unit
Atmospheric Distillation:
Unit 1
Unit 2
Vacuum Distillation
Light Ends /Gas processing
HDS - Reformer Feed:
Unit 1
Unit 2
HDS -Light Gas Oil
HDS - Light Cycle Oil
HDS - Vacuum Gas Oil
HDS - Coker Naphtha
Fluid Catalytic Cracking
Hydrocracking
Catalytic Reformer:
Unit 1
Unit 2
Aromatics Extraction
Allaylation
Coking
Hydrogen Production

Valves

890
890
500
190

650
650
650
650
650
650
1300
940

690
690
600
570
310
180
11650
Flanges

3560
3560
2000
760

2600
2600
2600
2600
2600
2600
5200
3760

2760
2760
2400
2280
1240
640
46520
Pump
Seals

43
43
21
4

14
14
14
14
14
14
42
31

20
20
17
15
13
3
456
Compressor
Seals

2
2
-
4

6
6
6
6
6
6
6
6

6
6
0
0
0
6
74
Relief
Valves

6
6
6
6

6
6
6
6
6
6
6
6

6
6
6
6
6
4
106
Drains

69
69
35
11

22
22
22
22
22
22
65
58

49
49
41
41
28
8
655
                                                                                                                    O
                                                                                                                    rt
                                                                                                                    i-j
                                                                                                                    o
                                                                                                                    Tl
                                                                                                                    fD
                                                                                                                    CD
      Hypothetical  refinery  units  taken from Arthur D.  Little Gulf Coast Cluster Model Refinery with a
       capacity of 330,000  BPD.

-------
R. G. Wetherold/S. L. Preston
  TABLE II.  ESTIMATED DISTRIBUTION OF FUGITIVE HYDROCARBON EMISSIONS FROM
             SIX SOURCE TYPES IN THE MAJOR PROCESS UNITS OF A HYPOTHETICAL
             REFINERY3
Source Type
Valves
Flanges
Pump Seals
Compressor Seals
Relief Valves
Drains
Estimated
Percent
Leaking
27
3
48
76
39
19
Emissions Contributed
By Each Source Type,
Percent of Total
60
6
12
9
4
9
100
 aArthur D. Little:  Gulf Coast Cluster Model Refinery- 330,000 EPS.
                                      322

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R. G. Wetherold/S. L. Preston
           It was decided that the most  cost effective sources to study were
 valves and pump seals.  Furthermore, the maintenance study would concentrate
 on valves, since they represent the greatest emission source of the baggable
 SOU1TC6 typGS •

           The maintenance to be performed on valves consisted of:

             •   Simple adjustment/tightening of the packing gland,  or

             •   Injection of grease into the fittings of plug valves.

 Additionally, some valves were to be monitored for extended time periods to
 determine the effectiveness of valve maintenance over an extended period of
 time.
           The number of valves required to make the above evaluations  was
 limited through selective experimental design.  The wide variation in  leak
 rates between valves was circumvented by using paired measurement schemes
 for maintenance evaluations.  Only valves with particular selected leak rates
 were studied.

           The factors that were considered in selecting valves for the main-
 tenance study were:

             •   Process stream group (gas/vapor streams, light
                 and two-phase streams, and heavy liquid
                 streams.

             •   Valve type  (block/gate, block/other, control/globe,
                 control/other).

             •   Leak rate or screening value range (500-5000 ppm
                 screening value, 5001-50,000 ppm screening value,
                 and > 50,000 ppm screening value).

 In addition, data were collected on all of the parameters normally included
 in the program.

           A total of 28 valves were proposed for study at each refinery.
 The distribution of these valves is shown in Table III.

           Pump seals were to be selected for the maintenance study in  a
 manner similar to that for valves.  The factors that were considered in the
 selection included:
                                      323

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R. G. Wetherold/S. L. Preston
      TABLE III.  DISTRIBUTION OF VALVES TO BE STUDIED IN EACH REFINERY
Process Stream Valve
Group Type
I Gas -Vapor
Streams


II Light Liquid &
Gas-Liquid
Streams

III Kerosine
& Heavier
Streams

BG
BO
CG
CO
BG
BO
CG
CO
BG
BO
CG
CO
Low
(500-
5,000
ppm)
XO
0
X
0
XO
0
x D
0
X
0
X
0
Medium
(5001-
50,000
ppm)
xoQ
X
X
X
XO
X
X
x n
X
X
x n

High
(> 50,000
ppm)
XO
X
x n
X
xoD
X
X
X
X
0
X
0
Total
X's

10



10



8


 Total X's
12
10
28
  Determined by maximum "TLV Sniffer" reading.
  BG = Block, gate; BO = Block, any type other than gate;
  CG = control valve, globe; CO = control valve, other than globe.
  [  I = control point, i.e. select a valve but do no maintenance.
  X  = select a valve here if possible; 0 = secondary choice for valve
       selection.
                                     324

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R. G.  Wetherold/S.  L.  Preston
             •   Leak rate category (medium leak = 0.5 - 1.0 Ibs/hr,
                 high leak rate = > 1.0 Ib/hr).

             •   Pump type (centrifugal-packed, centrifugal-single
                 mechanical seal, centrifugal-double mechanical seal,
                 centrifugal-packed, etc.).

           It was hoped that 10 leaking pump seals suitable for a maintenance
 study could be found in each of four refineries.

 PROCEDURE

           The steps below were generally followed during the maintenance
 studies:

             •   screening to locate potential sources

             •   rescreening of selected sources

             •   sampling of sources

             •   performance of maintenance

             •   resampling of sources

             •   additional short and long-term screening

             •   application of quality control procedures

           A Bacharach "TLV Sniffer," a sensitive hydrocardon detector,  was
 used to locate and select sources for study.   With a dilution probe, the
 range of this instrument is 0 - 100,000 ppmv.   The TLV Sniffer is calibrated
 with hexane.   For source selection the TLV Sniffer probe was placed as  close
 as possible to the points of potential leakage (valve stem and gland, pump
 seal).  Readings were taken at eight different points around valve stems and
 glands and at four points around pump seals.   The maximum reading was taken
 as the basis for estimating the leak rates.   Leaking valves which fit into
 the desired distribution (Table III)  were tagged for further consideration.
 Selected pump seals were similarly tagged.

           When all the required valves and pump seals were located, prepara-
 tions were made for measuring their leak rate.  Each selected source was
 rescreened immediately prior to sampling.   All data were recorded.   The
 leaking source was then enclosed in plastic.   A sampling train was  attached
 to the enclosure and the leak rate from the source was determined.

           After the initial leak rate was measured, maintenance was performed
 on the leaking source.   This maintenance was defined as either "directed" or
 "undirected."  Directed maintenance involves simultaneous maintenance and
                                     325

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R. G. Wetherold/S. L. Preston
 screening of the source with a hydrocarbon detector.  Maintenance activities
 are continued until no further reduction in hydrocarbon  concentration can be
 achieved.  Undirected maintenance consisted of the normal maintenance pro-
 cedures without any hydrocarbon concentration monitoring during the
 activity.

           When the maintenance procedures were completed, the maintained
 source was again screened and sampled.  The leak rate immediately after
 maintenance was thus determined.

           Whenever possible each maintained source was rescreened several
 times during a period of one to two weeks immediately following the main-
 tenance.  The purpose of this activity was to get an indication of the
 short-term effectiveness of directed and undirected maintenance.

           Arrangements were made at some refineries to obtain some data
 regarding the long-term effects of maintenance on the reduction of emis-
 sions.  In these cases, refinery personnel agreed to monitor selected
 maintained valves at intervals of one week to one month  for a period of six
 months.

           As part of the experimental study, quality control procedures were
 implemented.  These generally consisted of replicate and multiple source
 screening, replicate source sampling, accuracy testing of the sampling
 train, frequent calibration checks, and frequent analysis of standard gases
 in the laboratory.

 RESULTS

           A total of 120 valves were included in the maintenance study.
 Eighty-six of these actually underwent maintenance.  The remaining 34 valves
 were not maintained.  They were screened, however, and were also, in some
 cases, sampled.  The unmaintained group provided data on the variability of
 screening values and the change in leak rate as a function of time.

           Twenty-seven valves underwent directed maintenance.  Fifty-nine
 valves were subjected to undirected maintenance procedures.

           No maintenance studies were performed on pump  seals.  Difficulties
 were encountered in locating leaking pump seals in the proper leak rate
 categories.  In addition some pumps that were found to be leaking could not
 be adequately isolated for seal replacement.  In some cases, there were no
 spare pumps available to replace the leaking pump.  In other cases, it was
 felt that the time required and the cost incurred for seal replacement was
 not justified by the size of the leak.

           The effect of maintenance procedures on leak rates can be expressed
 as a percentage reduction in leak rate.  The percentage  reduction can be
 calculated from Equation 1.
                                     326

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R. G. Wetherold/S. L. Preston
                       LB  ~  LA
                   R = —	 x 100
                           B

 where

           R  = leak rate  reduction, %

           L  = leak rate  before maintenance,  Ib/hr

           L  = leak rate  after maintenance,  Ib/hr.


           Negative percentage reductions  in  leak rates  can be obtained if
 the leak rate is higher after maintenance than  it was before maintenance.
 The highest achievable positive reduction is  100%.   It  is possible, however,
 to get negative percentage  reductions that are  much  greater than 100 percent.
 Thus is particularly true if  the original leak  rate,  LB,  is very low.

           The effect of maintenance procedures  on the leak rates of the
 individual valves involved  in this  study  are  tabulated  in Tables IV and V.
 The data are plotted in Figures 1 and 2 where the effect of maintenance can
 be seen more clearly.  In these figures the  leak rate of the individual
 valves  after maintenance is  plotted as a function of the valve leak rate
 before maintenance.  This is  done for both undirected and directed mainten-
 ance procedures.  The valves  exhibiting a reduction  in  leak rate from main-
 tenance activities are indicated by those points that fall below the
 diagonal line drawn in each figure.   Those valves whose leak rate increased
 after maintenance are represented by the points  which fall above the diagonal
 line.  It can be seen that  the points in  Figure 2 generally fall further
 below the diagonal and closer to the horizontal axis than those plotted in
 Figure 1.  It appears from  these figures,  then,  that directed maintenance
 procedures are generally  more effective than  undirected maintenance activ-
 ities in reducing valve emissions.   Also, a  smaller fraction of valves
 exhibit an increase in emission rate after directed  maintenance than after
 undirected maintenance.

           The data are plotted in the form of histograms in Figure 3.  The
 results of the directed and undirected maintenance studies are shown.  The
 greater effectiveness of  the  directed maintenance procedures is clearly
 shown in this figure.

           The effects of  the  valve  maintenance  studies  are summarized in
 Table VI.  The results are  shown for both the directed  and the undirected
 maintenance programs, and are grouped according to the  level of emission
 rates.  Two results are noteworthy.   It is evident that the average percent-
 age leak reduction for those  valves that  were subjected to directed mainten-
 ance ±8 considerably greater  than that of the valves which underwent
 undirected maintenance.
                                      327

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R. G. Wetherold/S.  L.  Preston
  TABLE IV.  THE EFFECT OF UNDIRECTED MAINTENANCE PROCEDURES  ON LEAK RATES
             FROM INDIVIDUAL VALVES
Valve
ID
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
, 21
22
23
24
25
26
27
28
29
30
31
48
49
50
51
52
53
54
Valve
Function
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Control
Control
Control
Control
Control
Control
Control
Measured Leak
of Nonmethane
Before
Maint.
0.0320
0.0437
0.0158
0.1476
0.6572
0.5801
0.0018
0.0327
0.0871
0.1963
0.1071
0.0026
0.0109
0.1673
0.0019
0.0449
0.0381
0.0295
0.1256
0.0023
0.1995
0.1019
0.0264
0.1761
0.0015
0.0614
0.00049
0.0034
0.0083
0.0182
0.0293
0.2703
0.6235
0.2253
0.0923
0.0227
0.0286
0.5863
Rate, Ib/hr
Hydrocarbons
After
Maint .
0.00001
0.00002
0.00028
0.0051
0.0231
0.0481
0.00015
0.0031
0.0094
0.0288
0.0168
0.00045
0.00191
0.0365
0.00047
0.0174
0.0192
0.0157
0.0767
0.0015
0.1354
0.0714
0.0198
0.1328
0.0012
0.0508
0.00054
0.0044
0.0174
0.0462
0.1398
0.0009
0.0045
0.0017
0.0012
0.0018
0.0023
0.0553
Reduction
After
Maintenance,
Percent
100
100
98
97
96
92
92
90
89
85
84
83
83
78
76
61
50
47
39
34
32
30
25
25
20;^
17
- 10
- 29
-110
-153
-377
100
99
99
99
92
92
91
                                                            Continued
                                     328

-------
R. G.  Wetherold/S.  L.  Preston
                            TABLE IV.  Continued
Measured Leak Rate, Ib/hr
of Nonmethane Hydrocarbons
Valve
ID
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
Valve
Function
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
Before
Maint .
0.0058
0.0054
0.0161
0.0063
0.0514
0.0039
0.1641
0.0276
0.00037
0.0009
0.0055
0.00063
0.0127
0.0234
0.0119
0.0027
0.0015
0.0011
0.00031
0.00013
0.0019
After
Maint.
0.0008
0.0007
0.0029
0.0013
0.0202
0.0018
0.0758
0.0141
0.00026
0.00065
0.0040
0.00049
0.0115
0.0244
0.0133
0.0035
0.0024
0.0027
0.00078
0.00085
0.1673
Reduction
After
Maintenance,
Percent
86
87
82
79
61
54
54
49
29
28
27
22
9
4
• - 12
- 30
- 60
- 145
- 152
- 550
-8745
                                      329

-------
R. G. Wetherold/S. L. Preston
 TABLE V.  THE EFFECT OF DIRECTED MAINTENANCE PROCEDURES ON LEAK RATES FROM
           INDIVIDUAL VALVES
Measured Leak Rate, Ib/hr
of Nonmethane Hydrocarbons
Valve
ID
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98 •
99
100
101
109
110
111
112
113
114
115
116
117
Valve
Function
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Block
Control
Control
Control
Control
Control
Control
Control
Control
Control
Before
Maint .
0.0011
0.0111
0.0891
0.1396
0.0075
0.0383
0.0126
0.0115
0.0307
0.0032
0.0045
0.0800
0.00066
0.0014
0.00078
0.00197
0.00055
0.0053
0.0095
0.0181
0.0065
0.0173
0.0126
0.0025
0.0021
0.0005
0.0016
After
Maint .
0.0000
0.0002
0.0017
0.0028
0.0002
0.0017
0.0009
0.0008
0.0025
0.0004
0.0007
0.0124
0.00013
0.00039
0.00032
0.00106
0.00090
0.0130
0.0000
0.0004
0.0003
0.0010
0.0011
0.0003
0.0005
0.0003
0.0035
Reduction
After
Maintenance,
Percent
100
98
98
98
97
96
93
93
92
87
84
85
80
72
59
46
- 63
-145
100
98
95
94
91
88
76
40
-119
                                      330

-------
                                                                                                                                         o
LO
U)
   i.uoo +
         7
         t
         J-
         t
         t
         t
             L
             t
             A
             K   U.10U
             It
             A
             r
             E
A
F
1
t
rt

M
A
I
N
T
                U.U1U
                U.U01  +
                       t
                       4-
                       1
                                                                    :  A = 1 OUS« H  =  a OUSi LIC,
Leak rate before =
  Leak rate after
  maintenance
                                                                              A  A
                                              U.UU1
                                                         u.uiu

                                               Ct«l\ HATt. Ut-HOKL  ilAilMT.,  (LB/HR)
                                                                                                                                         rt

                                                                                                                                         (D
                                                                                                                                         P-!
                                                                                                                                         O
                                                                                                                            hd
                                                                                                                            f-i
                                                                                                                            n>
                                                                                                                            cn
                                                                                                                            It
                                                                                                                            o
                          Figure 1.   The Effect of  Undirected Maintenance on the Leak  Rate From Valves

-------
                                                                                                                       o
                                                     : A = 1 UbSt  H = U OHS«  ttt.
L
L
A
K

K
A
T
t

A
F
T
M
A
1
                                         Leak rate before «
                                           Leak rate after
                                           maintenance
                                                         t\
                                0.001
          o.uiu

LEAK KATL btHUHt MA1NT»> LB/HR
                                                                                                    1.000
                                                                                                                       ro
                                                                                                                       i
                                                                                                                       o
                                                                          i-t
                                                                          (D
                                                                          en
                Figure 2.  The  Effect of  Directed Maintenance on the  Leak Rate  From Valves

-------
R. G.  Wetherold/S.  L.  Preston
10


 9


 8'H


 7
      u
      c
      01
         2-
         -I
         3-
                Undirected Maintenance
             g
          ~. I  >  I I
                        j
                        /y-^
                       I
                  i
%m
                                           B!
           MS


                                  oooooooo
                              Percent Reduction
LO-]
9-
3-
7-
6"
5-
4-
3-
2-
1-





^

-£
Directed Maintenance




^1





\
y/
//.





/•/
//





SJ




I

6
//

\
i
\
i
^


\
\



//







          OcTiar--i£iLn»rmcNi—   -^c>jro»runu3r-a3cr>o

          "T	   Percent deduction
       Figure  3.  Histograms for Percent Reduction in Leak Rate

                  From Directed and Undirected Maintenance
                                     333

-------
                           TABLE VI.   SUMMARY OF MAINTENANCE REDUCTION BY LEAK RATE LEVEL
bJ
U>

Original Leak Rate

Level Range (Ib/hr)
1



2



3



4



n =

P -
pw =
pm =
< 0.001



0.001 - 0.01



0.01 - 0.1



> 0.1



Number of valves maintained
Average percent reduction =
Weight percent reduction = •
Median percent reduction
n
P"
pw
pm
n
P~
pw
pm
n
F
pw
pm
n
P"
pw
pm

EPi/n, where

Directed Maintenance
4
30.7
35.2
52.6
12
48.7
56.9
86.2
10
93.8
93.0
93.8
1
98.0
98.0
98.0

„ _ (leakage before - leakage

Undirected Maintenance
6
- 105.5
- 26.3
5.6
16
- 530.0
- 276.4
30.4
22
31.7
45.1
60.9
15
73.4
83.5
85.4

after maintenance) „ , nn
1 leakage before maintenance
Eleakage before maintenance - Zleakage after


Eleakage before maintenance

maintenance ..
——————— x J.UU

                                                                                                                        o
                                                                                                                        i-l
                                                                                                                        O
                                                                                                                        CO
                                                                                                                        •

                                                                                                                        r1
                                                                                                                        i-t
                                                                                                                        fD
                                                                                                                        cn
                                                                                                                        rt
                                                                                                                        O

-------
R. G. Wetherold/S. L. Preston
           It  is also  apparent  that  the level of the initial  leak rate  has  a
 marked effect on the  percentage  reduction in emission rate  for both  directed
 and undirected maintenance.  The percentage reduction achieved by mainten-
 ance  is lower for  the initially  small leak rates.   In the low initial  leak
 ranges, < 0.01 pounds per hour,  the average and weight percent reduction
 in emissions was actually negative  for undirected maintenance.

           It  should be noted that as the magnitude  of the leak rate  becomes
 smaller, both the  average percent reduction and weight percent reduction
 decrease rapidly.  Both of these parameters are dependent on the magnitude
 of the initial leak rate and are highly influenced  by extremes within  the
 leak  rate range.   The median percent reduction, however,  is  a more definitive
 measure of  central tendency and  cannot be affected  by the very large nega-
 tive  values of percent reduction encountered at low leak  rates with  undirected
 maintenance.

           The median  percent reduction does show the same pattern as the
 average and weight percent reductions.  The comparison between the median
 percent reductions for the two types of maintenance indicates that directed
 maintenance yields a  higher reduction in leak rate.   Undirected maintenance
 appears to  be even less reliable at low leak rate levels  (<  0.001 Ib/hr).
 This  type of maintenance appears to have a greater  potential for producing
 an  increase in valve  emissions  after  maintenance.

           The percent reduction  from the two maintenance  methods was plotted
 against the original  screening value in Figures 4 and 5.  The positive
 percent reductions with directed maintenance generally appear to be  higher
 than  the reductions achieved with undirected maintenance.  Also,  a greater
 percentage  of the  valves undergoing undirected maintenance appears to have
 increased in  leak  rate (compared to those subjected to directed maintenance)
 after being maintained.   Table VII  bears out these  observations.  The median
 percent reduction  with directed  maintenance (91.2 percent) is significantly
 higher than that with undirected maintenance (53.8  percent).

           The valves  are grouped by function (block or control)  in Table VII.
 Control valves which  had directed maintenance had a slightly higher  median
 percent reduction  in  leak rate than block valves which had the same  type of
 maintenance.  However, the opposite is true for valves which underwent
 undirected  maintenance.   Again,  even within the block/control groupings,
 directed maintenance  appears to  yield a higher percent reduction in  leak
 rate  than undirected  maintenance.

           It  should be noted that leaking valves in some,  categories  of the
 original experimental design were not found.  Very  few valves in the heavy
 liquid stream classification were found to be leaking, particularly  at the
 higher rates.  Valves in some  categories were found in some  refineries,  but
 not in others.  In many cases, substitutions from other categories were  made
 to provide  an adequately sized data base.
                                      335

-------
                                                ft =  1  OUSi b = ? UUS I  LTC.








p
L
C
j_

N
i
K
t
L)
U
C
r
i
0
N





t
t
f
J.MI +
t
1
t
1 U 0 t ;\
t
t
t
bO +
y

/ /t H


^
4
-tjl) f
r
y
/
- 1 U U 4
;
-I'JO +
^
-r'UO i
; (-550)
(1
(0
rt
cr
S
o
i — '
1 -
A /\ A A A C •
H A t A A E ^
ft A A A r
A A Htf
AA A D H
b A P
ff)
A A A A A rt
A A §
A A
A A


A



A
A A A


(-8745) (-377)
	 + 	 •" 	 + «•- - — 	 	 +--
1UU 1C11U iUUUO 1UUQUU
                                          MAX SCREENING VALUE. PPMV
Note:  3 values were out of range
           Figure  4.   Undirected Maintenance - Percent Reduction  in Emissions  as  a Function
                       of Initial Screening Values

-------
UJ
                                                                                                                                o
                                                                                                                                •


                                                                                     LTL.
                                                                                                                                n>
                                                                                                                                i-j
                                                                                                                                o
                                                                                                                                i->
                                                                                                                                &.

                                                                                                                                CO
liltl <
1 U 0 «
I1 '
L /
K r
t Ml t
t. /
N /
t ,' -
K i
t. ^
U /
U -UJ() I
t ^
1 /
1 t
0 -UU 4
N
r
-1'jO <
^
<
-Jo II t
/\ ft tt A A A AC
« A « A A A ' H
A A A
A A
A
A
A
                                                                luiiu                   10 nun


                                                          MAX SCREENING VALUE,  PPMV
                          Figure 5.   Directed Maintenance - Percent Reduction in Emissions as a Function

                                      of  Initial Screening Values
                                                                                                                                it
                                                                                                                                O

-------
                    TABLE  VII.
STATISTICAL SUMMARY  OF  MAINTENANCE  DATA  -  PERCENT  REDUCTION
OJ
00
                Screening
                                    Block Valves
                             DJ-rected Mrtlntrnimce

                                      Control Valves
Range
(ppov)

<5K


5K-50K


>50K

G/V
Stri-nm
2 58.8
56.5
58.8
2 76.1
90.7
76.1
3 93.8
97.8
98.0
LL
Strrnm
5 63.1
90.5
93.1
4 89.8
89.0
90.1
2 -26.4
56.7
-26.4
HL
Strrnm
0


0


0





Total*
Block
7 61.8
86.5
87.3
6 85.2
89.1
88.7
5 45.7
92.3
91.7







G/V
Strnnm
0
1


1


18 64.2 (32,96)
91.0 (82,99)
86.2 (75,97)
45.7
'.5.7
45.7
77.2
77.2
77.2
LL
Rl ronm
4 39.5
84.9
89.8
1 95.0
95.0
95.0
2 97.2
96.4
97.2
HL
Stream
0


0


0





Total All
Control Vnlvos
4 39.5
84.9
89.8
2 70.4
91.5
70.4
3 90.5
95.0
94.5







11 53.74
85.6
88.4
8 81.5
89.2
8R.7
8 62.5
92.6
93.1
9 66.8 (12,100)
89.7 (79,99)
91.2 (9.3,98)
(3.7,100)
(72,99)
(18,98)
(65,98)
(69,100)
(-55,96)
(-7.9,100)
(81,100)
(-33,99)







27 64.6 (38,91)
90.7 (83,98)
91.2 (79.95)
                *Numhers In parentlieaes Indicate an approximate 95X confidence Interval for the average  reduction Tor the three different estimations.
                                                                                                                                     (ContinimoT
o
•


n>
rt

ro

o
H
&

W3
                                                                                                                                                             T)
                                                                                                                                                             i-l
                                                                                                                                                             n>
                                                                                                                                                             en
                                                                                                                                                             rt
                                                                                                                                                             O
                                                                                                                                                             0
                  Code for

                  Each Cell

                  In Table
     1 = Number of valvea maintained

                           .   .    .              .    .     100 x (leak before - leak after maintenance)
     2 - Average of percent reduction where percent reduction > 	Leak before maintenance	
                                                 Weight percent reduction •« —


                                                 Median percent reduction
                                £_JL_ea_k rateM>eforc maintenance - Llcak rate after maintenance

                                             J^leak rate before maintenance

-------
                                                     TABLE  VII.
Continued
u>
                                                                Undirected Maintenance
Screening
Value
Range
(ppmv)

<5K


5K-50K


>50K

Block Valves
C/V
Stream
6 54.0
52,2
65.2
4 69.8
47.8
B2.6
3 75.3
88.4
84.3
I,L
St rciin
6 42.6
58.9
76.9
4 -64.9
- 9.0
28.2
4 81.3
93.0
90.9
ML
Stream
4 -26.1
-43.4
7.37
0


0





Total*
Block
16 29.7
48.5
33.1
8 2.4
20.2
50.1
7 78.7
91.1
85.4







Control Valvefl
U/V
Stream
7 -1321)
- 717
-58.4
2 54.2
53.8
54.2
8 29.4
81.3
19.3
LI.
SL roam
5 5.2
91.1
26.56
4 87.8
96.9
95.6
1 90.6
90.6
90.6
111,
Stream
0


1 82.1
82.1
82.1
0


31 33.7 (-1.8,69)
68.7 (48,89)
61.1 (31,85)
Total*
Total All
Control Valves
12 - 769
-50.5
24.1
7 77.4
90.2
82.1
9 36.2
87.0
29.5







28 -312
33.0
28.9
15 37.4
67.4
82.1
16 54.8
89.6
67.0
28 298 (-940,100)
81.0 (64,98)
51.4 (13,85)
(-950,100)
(-39,100)
(-0.5,79)
(-28.100)
(34,100)
(42,88)
(31.78)
(81.98)
(21.92)







59 -]24 (-410.100)
73.9 (69.88)
53.8 (29.82)
'Numbers In p
Code for
Each Cell
In Table
aronthcscu Indicate
1 2
3
4
1
2
3
an approximate 952 confidence
m Number of valves maintained
• Average of percent reductlo
- Weight percent reduction -
interval for the average percent reduction for the three different estimations.
. . 100 x (leak before - leak after maintenance)
wiidc Ki-*..i-.n- m.t-uMi.i.^vi. Leak before maintenance
F.lenk rule before maintenance. - Elenk rate after maintenance *QQ
^leak rate before maintenance
•s>
•

o
                                                                                                                                             fD
                                                                                                                                             It
                                                                                                                                             rr
                                                                                                                                             m
                                                                                                                                             i-i
                                                                                                                                             o
                                                                                                                                             i-1
                                                                                                                                             on
                                                                                                                                             i-i
                                                                                                                                             fD
                                                                                                                                             CO
                                                                                                                                             rt
                                                                                                                                             O
                                     4 - Median percent, reduction

-------
R. G. Wetherold/S. L. Preston
           A comparison of emission reduction by range of screening value can
 also be made.  For directed maintenance, the median percent reduction stays
 approximately constant across the screening value range.  However, for the
 undirected maintenance group the median percent reduction increases
 dramatically with increasing screening values.  The median percent reduction
 is very low, only 28.9 percent, for those valves having low screening values.
 This may indicate that undirected maintenance at this screening level is not
 effective at all.  For the middle screening value range, the median percent
 leak reduction for valves which underwent directed maintenance increases to
 82.1 percent, almost as high as the reduction with directed maintenance
 (88.7 percent).  However, the median percent leak reduction with directed
 maintenance is somewhat lower (67 percent) for the valves in the high screen-
 ing value range.  The effectiveness of the maintenance program appears to be
 much more consistent when the directed maintenance method is used rather than
 the undirected method.

           The differences in percent reduction discussed above should be con-
 sidered as trends.  Confidence intervals were calculated for the key values
 and these are presented in Table VII.  Differences in the percent emission
 reduction cannot be considered statistically significant if confidence limits
 for the estimates overlap.

           A graphical representation of the differences between the effect
 of maintenance on block and control valves is shown in the next several
 figures.  The leak rates before and after maintenance are plotted for block
 and control valves in Figures 6 and 7.  The percent reduction in leak rate
 for each valve is plotted against the original screening value for block and
 control valves in Figures 8 and 9.

           Finally, Figures 10 and 11 are histograms of percent reduction for
 block and control valves for directed and undirected maintenance.  While no
 large differences between valve function are obvious, the differences between
 the percent reduction in emissions for valves undergoing directed and
 undirected maintenance can be seen.  The advantages of directed maintenance
 are apparent.


 THE SHORT AND LONG TERM EFFECTS OF VALVE MAINTENANCE

           A number of the valves which underwent maintenance were screened
 several times during a one week period following the maintenance.  The
 results are summarized in Table VIII.  The advantage of directed maintenance
 can be clearly seen.  Fifty percent of those valves with initial screening
 values > 10,000 ppmv still had screening values in excess of 10,000 ppmv
 immediately after undirected maintenance.  By the end of one week,  60 percent
 of these valves had exhibited screening values  above 10,000 ppmv.

           By contrast, only 2 of the 10 valves subjected to directed main-
 tenance had screening values in excess of 10,000 ppmv.  One additional valve
 developed a screening value above 10,000 ppmv by the end of the week.
                                     340

-------



L
t.
A
K

K
A
T
t

A
h
1
L
K

M
A
1
N
T
t

L
B
/
H
R
i
J . uiiij •»
*'
I
/
/
•J.I 00 «
t
t
t
t
/
f
t
U.Oll) •*
1
*
t
t
f
7
*
U . u U 1 +
f
J
t
4
t
/
f
U , U 0 U +
                U = Undirected

                D = Directed
                                                          u   u
                            u.uui
                                                  U.U1U                  U.1QU



                                         LtAt\ KAfL Utt-OKt  MAlNTt. LB/HR
                                                                                                              o
                                                                                                              fD
                                                                                                              n
                                                                                                              o
                                                                                                               fD
                                                                                                               en
        i  t.Mts  muut.i'1
Figure  6.   Directed and  Undirected Maintenance - Leak Rate  After Maintenance as a Function of

            the Leak Rate Before Maintenance - Block Valves.

-------
             1 , 0 0 0 4
to
          L
          L
          A
          K

          K
          A
          T
          E

          A
          F
          T
M
A
I
N
T
          L
          B
          /
          H
          R
   o.ioo
/
t
<
t
t
/
4
t
t
1
t
t
t
                              U
                              D
                       Undirected
                       Directed
ft)
o
i-1

en
*
r1
                                                                                                                 (0
                                                                                                                 en
                                                                                                                 rt
                                                                                                                 O
                   U . l IIU
                                          . uui
                                                               0 . 01 U
                                           Ll ftH HI* It  I1LHIKL
                                                                                     u.iou
                                                                           ,  LB/HR
              Figure 7.  Directed and Undirected  Maintenance - Leak Rate After Maintenance as  a  Function of
                          the Leak Rate Before Maintenance - Control Valves

-------
I1
E
C
t
N
T
K
E
0
U
C
T
S o
LO N

i
t U • Undirected
150 * D = Directed
/
/
lull t i' u U D U U D
/ II III) U U U (I I) U
x URDU
, U U
bO * D U
* U U
t u U U U
* u
/ u
/ o
Jt
-t>0 +
/ u
*
-iuo +
t- U
*
>
-1'jO 4 U
^
^
I (-377)
r IUO 100M 1UUOO
1)
n
It
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                                     MAX SCREENING VALUE, PPHV
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Figure  8.   Directed and Undirected Maintenance - Percent Reduction in Emission Rate as a

            Function of the  Screening Value - Block Valves

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