United States
         Environmental Protection
         Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC
EPA 340/1-90-026f
September 1990
Revised May 1993
         Stationary Source Compliance Training Series
&EPA  COURSE #380
         INSPECTION TECHNIQUES
         FOR FUGITIVE VOC
         EMISSION SOURCES

         Reference Volume 3 -
         Inspection Manuals

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                                       EPA 340/1-90-026f
                                       Revised May 1993
       Course Module #380


   Inspection Techniques  For
Fugitive VOC Emission  Sources


         Reference Volume 3:
          Inspection Manuals


                 Prepared by:
         Pacific Environmental Services, Inc.
           5001 South Miami Boulevard
                PO Box 12077
   Research Triangle Park, North Carolina 27709-2077
            Contract No. 68-D2-0058
            Work Assignment No. I-29
      EPA Work Assignment Manager: Kirk Foster
         EPA Project Officer: Aaron Martin
    US. ENVIRONMENTAL PROTECTION AGENCY
       Stationary Source Compliance Division
    Office of Air Quality Planning and Standards
            Washington, DC 20460
               September 1990
              Revised May 1993

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                 TABLE OF CONTENTS



REFERENCE VOLUME 3 : INSPECTION MANUALS / FIELD NOTEBOOK



     3-1   Portable Instruments User's Manual for Monitoring VOC Sources



     3-2   Benzene Equipment Leak Inspection Manual

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BENZENE EQUIPMENT LEAK
   INSPECTION MANUAL
ICE VOLUME 3 : INSPECTION MANUALS

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            United States        Office of Air Quality    EPA-3-40/1-90-001
            Environmental Protection   Planning and Standoras   July 1990
            Agency           Washlnton. D.C. 20460

            Stationary Source Compliance Series
c/EPA      Benzene  Equipment
            Leak  Inspection  Manual

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BENZENE  EQUIPMENT LEAK
INSPECTION MANUAL
PREPARED FOR
U.S. ENVIRONMENTAL PROTECTION
              AGENCY

 STATIONARY SOURCE COMPLIANCE DIVISION
   OFFICE OF AIR QUALITY PLANNING AND
              STANDARDS
         WASHINGTON, D.C. 20460
    EPA PROJECT MANAGER: OMAYRA SALGADO
           CONTRACT NO. 68-02-4467
          WORK ASSIGNMENT NO. 69
PREPARED BY
   ENGINEERING - SCIENCE, INC,

        10521 ROSEHAVEN STREET
         FAIRFAX, VIRGINIA 22030
               JULY 1990

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                                DISCLAIMER

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

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

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                          TABLE OF  CONTENTS

 1.   INTRODUCTION	 1-1

 2.   REGULATORY REQUIREMENTS	2-1
      2.1  Introduction	2-1
      2.2  Regulatory Requirements	2-2
          2.2.1  Applicability Determinations	2-2
          2.2.2  Exemptions	2-3
          2.2.3  Compliance Monitoring Requirements	2-4
                   22.3.1  Valves 	2-5
                   2.232  Pumps 	2-12
                   2.233  Compressors	2-14
                   223.4  Sampling Connections	2-14
                   223.5  Pressure Relief Devices and Connectors	2-14
                   223.6  Open-Ended Valves		2-15
                   223.7  Product Accumulator Vessels	:.. 2-15
                   223.8  Closed-Vent Systems	2-15
                   223.9  Control Devices		2-16
          22.4  Alternatives for Emission Limitation		2-17
          22.5  Leak Repair and Records ........	.............	2-17
                   22JS.1  Leak Repair	2-17
                   22J2  Leak Records	2-19
          22.6  Facility Reporting Requirements		2-21

3.  FUGITIVE BENZENE EMISSION SOURCES	3-1
     3.1   Process Valves	3-1
          3.1.1  Gate Valves	3-2
          3.12  Globe Valves	3-2
          3.13  Angle Valves	3-5
                                    ni

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

INSTRUMENTATION SELECTION AND OPERATION	4-1
 4.1   VOC Detectors	4-1
      4.1.1  Flame lonization Detector (FID) „	4-4
      4.1.2  Photoionization Detector (FID)	4-4
      4.13  Nondispersive Infrared Detector (NDIR)	4-6
      4.1.4  Catalytic Combustion	4-7
 42  Selection of Instruments	^.^.^....	.	4-7
      4.2.1  Detector Response and Selectivity	4-7
            Range and Accuracy	~~	.~..~~~....~..—....	..— 4-8
                                  IV

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

5   PRE-INSPECnON		5-1
     5.1   Facility Background Information Review		5-1
          5.1.1  General Facility Background Information	5-2
          5.12  Inspection Reports	5-2
          5.13  Legal Records	5-3
          5.1.4  Information Sources ..__._____.„_	5-3
          5.1.5  Review of Reports	5-4
     52   Development of the Inspection Plan	5-6
          52.1  Plant Records	5-6
          522  Inspection Monitoring _~~	5-6
     53   Notification	5-8

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

 6  INSPECTIONS	6-1

      6.2   Inspector's Responsibilities	6-3
          6.2.1   Legal Responsibilities	6-3
          6.2.2   Procedural Responsibilities	6-4
      6.3   Facility Inspections	6-4
          6.3.1   Entry	6-5
                    6.3.1.1   Arrival	6-5
                    63.1.2   Consent	6-5
          6.3.2   Initial Interview		6-5
          6.3.3   Evaluating the Facility Leak Monitoring
                 Program	6-7
                    633.1   Observation of Calibration Procedures	6-7
                    6332   Observing Leak Detection Monitoring by
                             Plant Personnel	.—.		6-8
                 .  6333   Spot-Check by Inspector		6-10
           1      -i         > i
          63.4   Record Inspections	'„	6-15
          633   Closing Conference ._..~.....~......_.....~.	.	.	6-23

7   POST INSPECTION	7-1
     7.1   Writing The Report	7-1
          7.1.1  Emrcduction	7-2
          7.12  Compliance Status for Regulated Equipment	7-2
                    7.12.3  Individual Source Compliance Status	7-3
                    7.1.23  Exemptions	7-4
                    7.123  Alternative Standards	7-4
                    7.1.2.4  Leak Detection Procedures	7-4

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                  7.12 J  Reports and Recordkeeping	7-5
         7.13   Data	7-5
         7.1.4   Summary	7-5
    7.2  Handling Confidential Business Information	7-6
8  REFERENCES	8-1
                                   VII

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                                LIST OF FIGURES

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

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                             LIST OF TABLES


TABLE                                                             PAGE


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

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

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

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

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                               1.0 INTRODUCTION

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

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

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

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

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                      2.0 REGULATORY REQUIREMENTS

 2.1    INTRODUCTION

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

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

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 2.2    REGULATORY REQUIREMENTS

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

 2.2.1  Applicability Determinations

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

 (1)    Benzene Sulfonic Acid Production

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

 (3)    Chlprobenzene Production

 (4)    Cumene Production

 (5)   Cyclohexane Production

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

(7)   Bthylbenzene Production

(8)   Hydroquinone  Production

(9)   Linear Alkylbenzene Production

(10)   Maleic Anhydride Production
                                      2-2

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 (11)   Nitrobenzene Production

 (12)   Petroleum Refineries

 (13)   Pipeline Companies and Storage Terminals

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

 (15)   Resorcinol Production

 (16)   Styrene Production

 (17)   Phenylsilicone Production

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

 22.2   Exemptions

       Facilities are exempt from Subparts J and V requirements if:

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

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

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

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

 Additional exemptions are allowed for:

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

223  Compliance Monitoring Requirements

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

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

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

2.23.1 Valves

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

      Valves must be monitored monthly to detect leaks unless:

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

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                                               TABLE 2-1

                              SUMMARY OF LEAK DETECTION STANDARDS
                                     AND EQUIPMENT STANDARDS
Equipment
   Item
   Equipment
 Type/Category
     Standard
           Comments
Valves
Pumps
General
With no external
actuating mechanism in
contact with process
fluid

In unsafe location

In difficult to monitor
location (existing plants
ONLY)

General
Monthly Method 21 test
                                      No detectable emissions
                                      Minimum of annual Method 21 test
Weekly visual check
    AND
Monthly leak detection
Leak = 10,000 ppm or greater (Ef two
successive months have no leaks then
valve can be monitored quarterly)

Leak = 500 ppm
  above background
Annual test
Owner to have written monitoring plan

Owner to have written monitoring plan



Leak = any liquid drips
        OR
  10,000 ppm or greater

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Equipment
   Item
   Equipment
 Type/Category
                                          TABLE 2-1 (CONTINUED)
     Standard
           Comments
Pumps
(continued)
With dual mechanical
seals and barrier fluid
system
Weekly visual check
                With no external shaft     No detectable emissions
                With closed-vent
                system

                Located at unmanned
                plant site
Compressor     General
                         Minimum of monthly visual check
                         and leak detection
                        No detectable emissions
Pressure nf barrier fluid greater than >
pressure of benzene fluid
       OR
Degassing reservoir with controls
       OR
Purge into process stream
       AND
Barrier fluid not in VHAP service
       AND
Sensor for failure
  (checked daily or has audible
  alarm)
Leak = failure of seal
       OR
Any liquid drips

Leak = 500 ppm
    above background
Annual Method 21 test

Must comply with closed-vent
  requirements

Exempt from weekly and daily checks
(leaks and/or
 sensor/alarm)

Leak = 500 ppm
  above background
Annual Method 21 test

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                                          TABLE 2-1 (CONTINUED)
Equipment
Item
Compressor
(continued)
Equipment
Type/Category Standard
Dosed- Vent System
Comments
i
Must comply with closed-vent
requirement
Sampling
Connections
Product
Accumulator
                Unmanned Plant Site


                Barrier Fluid Seal
                System
Dosed Purge or
Closed-Vent System
In-Situ

Closed-Vent System
                         Minimum of monthly visual check
                         and leak detection
                                         Exempt
Exempt from daily sensor/ alarm
check

Pressure of harrier fluid greater than
pressure of benzene fluid
       OR
Barrier fluid vented to controls
       OR
Purge into process stream
       AND
Barrier fluid not in VHAP service
       AND
Sensor for failure
 (checked daily or has audible
  alarm)
       AND
Plant to establish criterion for
 leak
Leak = criterion is exceeded

Return purge to process stream
       OR
Collect and recycle purge
       OR
Vent to control system and meet
closed-vent requirements
Must comply with closed-vent
requirements

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                                          TABLE 2-1 (CONTINUED)
Equipment
Item
Closed-Vent
Systems
Equipment
Type/Category
Closed-Vents
Standard
No detectable emissions
Comments
Annual Method 21 test
Leak = 500 ppm
above background
OR
by visual detection
                Control devices

                Vapor recovery systems

                Enclosed combustion
                devices

                Flares
Open-Ended     Must have cap, blind
Valve and Lines  flange, plug or second
                valve
Pressure Relief
in Liquid
Service,
Flanges and
Other
Connections
General
                        Monitor

                        95% Efficiency

                        95% Efficiency
                        0.5 Seconds
                        1400°F
                        No Visible Emissions
                         '(except 5 mins/2 hour
                          period)
                        Flame Present Detector
                        BTU Requirements
                        Velocity Requirements
No scheduled detection
                                   Ensure operating per design
                                   By Method 22 test
Shall be closed except during operation
       AND
Second valve shall be shut first
(double block and bleed valve can be
open during venting but must be closed
at other times)

Potential Leak = Visual, Audible,
Olfactory, etc.
       AND
Leak =  10,000 ppm or greater

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                                       TABLE 2-1 (CONTINUED)

Equipment        Equipment
   Item         Type/Category              Standard                                Comments


Pressure Relief  General                No Detectable Emissions            Leak = 500 ppm
in Gas/ Vapor                                                              above background
Service                                                                       AND
                                                                      Method 21 test within 5 Days of a
                                                                      Release

               Gosed'vent system                                        Must comply with closed-vent
                                                                      requirements

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

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

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

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

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

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

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

 2232 Pumps

       Pumps are required to comply with the monthly leak detection and repair program,
 where any leak emission over 10,000 ppm is defined as a leak. They must also be visually
 inspected weekly for any liquid drips. However, any pump which is located  within the
 boundary of an unmanned plant site is exempt from the weekly visual pump seal inspection
 requirements  [40  CFR 61242-2(a)(2)  and  (d)(2)]  and the  daily sensor  inspection
 requirements [40 CFR 61.242-2(d)(5)(i)] as long as each pump is visually inspected as often
 as practicable and at least monthly.

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

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

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

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

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

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

Pumps must be monitored monthly unless:

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

       Compressors are required by 40 CFR 61242-3 to be equipped with a seal system
 that includes a barrier fluid system and that prevents leakage  of process fluid to the
 atmosphere.  The barrier fluid system must be equipped with a sensor that will detect
 failure of the seal or barrier fluid system. Sensors must be checked daily or have an alarm.
 If the sensor detects a failure, a leak is discovered. Compressors are to be tested annually
 unless equipped with a  closed-vent system  capable  of capturing and  transporting any
 leakage  from the seal to a control device that complies with the applicable requirements.
 However, it should be noted that compressors are rarely "in benzene service" because pure
 benzene is not easily compressed.

 2.2.3.4 Sampling Connections

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

 2.23.5 Pressure Relief Devices and Connectors

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

       Pressure relief devices in gas or vapor service shall be operated in accordance with
the no detectable emission standard (<500ppm).  As an alternative, compliance may be
                                       2-14

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

 2.2.3.6  Open-Ended Valves

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

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

 22.3.7  Product Accumulator Vessels

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

223.8 Closed - Vent Systems

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

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

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

       o     Must be designed and operated with no visible emissions as  determined by
            Reference Method 22, except for a total of 5 minutes  in any 2-hour period.
       o     Must be operated with a flame present at all times.  The flame's presence can
            be  ensured.by monitoring the flare's pilot light with  the appropriate heat
            sensor such as a thermocouple, an  infrared monitor  or any other equivalent
            device.
      o     Only steam-assisted, air-assisted or non-assisted flares may be used to comply
            with the regulation.  The net heating valve of the gas being combusted must
            be at least 300 BTU/scf for steam-assisted or air-assisted flares, and at least
            200 BTU/scf for non-assisted flares.
      o     Steam-assisted and non-assisted flares must  be designed for and operated
            with an exit velocity less than 60 ft/sec, except that higher exit velocities are
            permitted for gases having net heating values greater than 300 BTU/scf. A
            maximum exist velocity of 400 ft/sec is allowed when  the net heating value of
            the gas exceeds 1,000 BTU/sct
      o     For air-assisted flares, the maximum permitted velocity increases as the net
            heating value  of the  gas  being  combusted  increases.  The  maximum
            permitted velocity is  54.5 ft/sec at  the minimum allowable heating value of
            300 BTU/sct and 1152 ft/sec at a heating value of 1,000 BTU/scf.
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 2.2.4  Alternatives for Emission Limitation

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

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

22.5   Leak Repair and Records.

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

      o      tightening bonnet bolts
      o      replacement of bonnet bolts
      o      tightening of packing gland nuts
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       o     injection of lubricant into lubricated packing
       o     others
       The first attempt at repair for pressure relief devices in liquid service, flanges and
 other connections includes the same practices as mentioned for valves.

       According to the regulations, the first attempt at repair must be initiated within five
 calender days after discovering the leak. The leak repairs must be completed, that is, the
 equipment must achieve the previous emission limit standard (i.e. less than 10,000 ppm or
 less than 500 ppm above background reading) within 15 calendar days.
       Delay of repair is allowed when the repair is technically or physically infeasible
 without a process unit shutdown. For example, if a leaking valve cannot be isolated from
 the process stream and requires complete replacement or replacement of multiple internal
 parts, the valve repairs can be delayed until the next process unit shut-down.  Delay of
 repair will also be allowed if the leaking source is isolated from the process and does not
 contain or contact benzene in concentrations greater than 10 percent.  Delay of repair for
 valves is allowed when:

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

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

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

 2.2.5.2 Leak Records

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

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

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

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

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

       The following information pertaining to valves shall be recorded for:

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

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

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

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

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

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

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

2.2.6 Facility Reporting Requirements

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

       Receipt  of the  initial   report  is essential  for  ensuring compliance  with  the
regulations.  The initial  report  must include a statement that the general requirements of
the  benzene NESHAP standards, testing, recordkeeping and reporting are  being
implemented.   The owner or operator of each  existing  or new source (Le., building,
structure, facility, installation or piece of equipment which emits or may emit benzene)
                                      2-21

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 which has an initial startup  date  preceding the  effective date, must  also include the
 following information in the initial report to be submitted within 90 days after the effective
 date as required under 40 CFR 61.10(a) of the NESHAP general provisions:

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

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

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

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

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

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

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

3.1    PROCESS VALVES

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

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

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

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

 3.1.1  Gate Valves

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

3.12 Globe Valves

      Globe valves (Figure 3-2) are a type of block  valve whose name arises from the
shape of the body.  They are designed as either inside-screw rising stem or outside-screw
rising stem.  Small valves generally are of the inside-screw type, while in larger sizes the
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GATE VALVE1
 FIGURE 3-1
      3-3

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  Handwheel
 Stem
    Packing Nut
                                  Packing
                                  Bonnet
                                  Seat
Body
      GLOBE VALVE WITH PACKED SEAL4



                 FIGURE 3-2
                     3-4

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

 3.1.3  Angle Valves

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

 3.1.4  Diaphragm Valves

       Diaphragm valves (Figure 3-3) are control valves which limit flow by manipulating a
 flexible diaphragm.  The  process fluid is separated from the  valve stem by a flexible
 diaphragm so that the potential for leakage around the stem is eliminated.  The fabric-
 reinforced diaphragms may be made from natural rubber, from a synthetic rubber, or from
 natural or synthetic rubbers faced with Teflon9. The simple shape of the body makes lining
 it economical.  Plastic bodies, which have  low moduli of elasticity compared with metals,
 are practical in diaphragm valves since  alignment  and distortion are minor problems.
 Diaphragm  valves have excellent  corrosion  resistance characteristics but  are limited to
 pressures of approximately SO psig.

3.1.5   Ball Valves

       Ball valves  (Figure 3-4) as the name suggests, use a spherical element to block flow.
Since the sealing element is a ball, its alignment with the axis of the stem is not essential to
tight shutoff. In free-ball valves the ball is free to move axially. Pressure differential across
the valve forces the ball in the dosed position against the downstream seat and the latter
against the body.  In fixed-ball valves, the ball rotates on stem extensions, with the bearings
sealed with O-rings.
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               Handwheel
               Plunger
                 Flexible
                 diaphragm
                   Saddle
                   shaped
                   seat
DIAPHRAGM VALVE
    FIGURE 3-3
        3-6

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


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 3.1.6  Butterfly Valves

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

 3.1.7  Valve Seals and Leak Sources

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

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

      Bellows seals (Figure 3-7)  are more effective for preventing process fluid leaks than
 are conventional  packing glands  or any other gland-seal  arrangements.  This seal
 incorporates a formed metal  bellows that makes a barrier between the  disc and body
 bonnet joint. The bellows is the weak point of the system and its service life can be quite
variable.  Consequently, the bellows seal is usually backed up with a conventional packing
gland and often fined with a leak detector in case the seal fails.
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                     Potential
                     leak area
                          Disk
BUTTERFLY VALVE
    FIGURE 3-5
        3-9

-------
   Pump stuffing box
Fluid

end
        IXIXIXDOXIXt;
id   n   VJ_C5__C

d  1~          •
                        n
                              Packing gland
                              -Seal face
          (XlXIXIXlXIXlXi
            Packing
                           I    ^ Possible leak

                           --'''    area
             SIMPLE PACKED SEAL
                 FIGURE 3-6
                     3-10

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

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

 3.2   PUMPS

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

 3.2.1  Centrifugal  Pumps

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

3.12  Reciprocating Pumps

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

-------
TWO-STAGE PUMP WITH DOUBLE-SUCTION IMPELLERS1
                  FIGURE 3-8

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

 3.2.3  Rotary Pumps

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

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

-------
               Air chamber
                                       Delivery ball

                                        valve-
                                                  Flexible
                                                   iaphragm
                                                    Suction ball
                                                    valv<
                              Suction
SHRIVER MECHANICALLY ACTUATED DIAPHRAGM PUMP
                    FIGURE 3-9

-------
MOYNO SINGLE-ROTOR SCREW PUMP WITH ELASTOMERIC LINING1
                     FIGURE 3-10

-------
GEAR-TYPE ROTARY PUMP HAVING TWO IMPELLERS1
                 FIGURE 3-11
                       3-17

-------
       Discharge
t
                               Coolant circulating tube
                                 Stator liner
Suction
               Impleller
                     Bearings
                   SEAL-LESS CANNED MOTOR PUMP
                              FIGURE 3-12
                                  3-18

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

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

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

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

-------
 packed seals where no lantern ring is used, a small amount of leakage through the packing
 is essential for lubrication of the seal.

       The chief advantage of packing over other types of seals is the ease with which it can
 be adjusted  or replaced.   Most equipment is designed so that disassembly  of major
 components is not required to remove or add packing rings. The major disadvantages of a
 packing-type seal are the necessity for frequent adjustment and the quantity of fluid flow
 required to lubricate it.

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

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

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

-------
                   Gland gasket
  Pump stuffing box
                           _  „ Gland ring
                                        , Insert packhg
                                          Stationary
                                          ' element
                 Sp*g'    Shaft  \  Seal face
                  ¥       packing <
                               i
                               i
                             Rotating
                             sealing
       BASIC SINGLE MECHANICAL SEAL
  Possbfe leak krto
    seafng fluid
                Seaing-BquW
                  i Met
                      Seatog-fiquid
                         outlet
Fkild end-
    x Seal face \

toner seal assembly
                              Outer seal assembV_
          DOUBLE MECHANICAL SEAL4
                   FIGURE 3-13
                        3-21

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

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

 33    COMPRESSORS

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

 33.1   Compressor Types

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

33.2   Compressor Seals and Leak Sources

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

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

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

 3.4   PRESSURE RELIEF DEVICES

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

3.4.1  Types of Pressure Relief Devices

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

-------
                           Oil in from reservoir
Inner bushins
/Outer bushing
Internal gas
 pressure
                     Shaft sleeve
                X/ X/ /'f///SSS7//ff ////'/,
            Contaminated   Ol1 out
              oil out to
              reservoir
  Atmosphere
            LIQUID-FILM COMPRESSOR SHAFT SEAL
                         FIGURE 3-14
                                                   2
                              3-24

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

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

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

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

-------
 3.4.2  Emissions Sources

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

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

 3.5    SAMPLING CONNECTIONS SYSTEM

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

3.6    OPEN-ENDED VALVES OR LINES

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

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

 3.7    PRODUCT ACCUMULATOR VESSELS

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

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

3.8    FLANGES AND OTHER CONNECTORS

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

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

 3.9   CLOSED VENT SYSTEMS AND CONTROL DEVICES

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

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            4.0 INSTRUMENTATION SELECTION AND OPERATION

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

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

 4.1    VOC DETECTORS

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

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

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

-------
                        Table 4-1  PERFORMANCE COMPARISON OF FOUR  MAJOR VOC DETECTORS
                                                                                                    Catalytic
                                                                                                   Combustion
                                                                                                                                IR
1.   Well detected VOC daaaaj
Aliphatic, ofeflnfe, and aromatic
hydrocarbons
1   Poorly detected VOC classes   Highly oiygenated or hatogenated
                               compounds. Sulfur, nitrogen,
                               phosphorus containing compounds also
                               reduced response
3.  Typical calibration
    compound
4.   Typical oetection range,
                                                                    Aromitle and olefinle
                                                                    hydrocarbons, chlorinated
                                                                    com pounds
S.   Typical.
                       racy.    MO
                                                                    Bentene, butadiene
                                                                    1-2000 or 10-20.000 (with
                                                                    dilution)
5-10
                                                                                                 Similar to FID
                                                                                                 Similar lo FID
                                                                                                 Mctnanc, propane
                                                                                                 n-hcnne
                                                                                                 Several ranges available
                                                                                                 from 10 ppm up lo lower
                                                                                                 explosion limit

                                                                                                 2-10
                                                     Hydrocarbons
                                                     Highly dependent on
                                                     IR absorption
                                                     spectrum. Water
                                                     vapor will Interfere
                                                     wiih certain
                                                     compounds

                                                     Compound of interest
                                                     or very similar
                                                     compound

                                                     1-10.000 (highly
                                                     dependent on specific
                                                     compound)
6.   Typical calibration precision,    2-5
                                                                    2-5
                             2-3
                                                                                                                         2-5

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Table 4-1 PERFORMANCE COMPARISON OF FOUR MAJOR VOC DETECTORS (Continued)

7.

«.






9.









Typical response IniMi
seconds
Major advantages






Major limitations








FID
3-10

•) some response obtained for
many organic compounds





•) poor response for highly
oxygenated or chlorinated
compounds

b) external gas supply (hydrogen)
required



pro
3-10

a) detects oxygenated
and chlorinated
compounds not
detected by FID

b) no external gas
supply required
a) does not respond to
low molecular
weight aliphatic
hydrocarbons

b) detection of high
levels may require
dilution of the
sample stream
Catalytic
Combustion
3-20

a) low cost a)

b) lighter to carry
b)
c) no external gas supply '
required

a) poor response for a)
highly oxygenated or
chlorinated
compounds

b) not as sensitive as the
other techniques


m
5-100

qualitative information
may be obtained

no external gas supply
required


water vapor and other
atmospheric constituents
may interfere







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

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

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

       Although nitrogen (N2),  carbon monoxide (CO), carbon dioxide (CX>2), and water
 vapor (H2O) do  not produce significant interferences, condensed water vapor can block
 the sample entry tube and the flame arrestors causing erratic readings. Also, when oxygen
 (02) content of  the organic compound exceeds 4 percent, a significantly lower output
 reading  can occur.  The relative response  of  the  FID to various  organic compounds,
 including those with attached oxygen, chlorine, and nitrogen atoms, varies from compound
 to compound.

4.12 Photoionization Detector (PTD)

      In the  photoionization process,  ultraviolet light ionizes a molecule as follows:
 R +  hvs=R+  +  e", where  R"1" is the ionized  species and hv represents a photon with

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

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

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

 4.13 Nondispersive Infrared Detector (NDIR)

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

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

 4.2    SELECTION OF INSTRUMENTS

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

 42.1  Detector Response and Selectivity

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

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

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

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

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

 423 Ease-of-Use

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

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

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



HNU PI-101            PID

TECO Model 580       PID


TECO Model 712       FID

Barachach TLV         Cata-
  Sniffer              lytic

Miran 1A              Infra-
                      red
26



 9

 8


14

 5


32
Case with handle
Shoulder strap

Small case with
handle

Shoulder strap

Shoulder strap


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

Necessary to open
case at each
measurement site
Readout on probe
Necessary to set
unit down at each
measurement site
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 calibration. Generally, the easier an instrument is to use, the more likely it will be used
 properly and generate data of acceptable quality.

 4.2.4 Safety

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

 4.3    INSTRUMENT CALIBRATION AND EVALUATION

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

43.1  Instrument Calibration Requirements and Procedures

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

       o     The instruments should be calibrated daily.
       o     The  gas  concentration used for calibration should  be  close to  the leak
            definition concentration.
       o     The calibration gas should be methane or n-hexane.
       o     A calibration precision test should be conducted every month.
       o     If gas blending is used to prepare gas standards, it should provide a known
            concentration with an accuracy of i 2 percent
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       The  daily  calibration requirement  specified in  Method  21  gives  individual
 instrument operators some flexibility.   The calibration could consist  of a multipoint
 calibration in the lab, or it could be a single-point "span check" in the field.

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

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

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

      The calibration  procedures  for each instrument  model  are specified in  the
manufacturer's instruction manual.   Material presented in this  section is intended to
emphasize the importance of certain calibration procedures discussed in these various
instruction manuals.
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       Regardless of the  type  of VOC  instrument, the flow  rate of  the  gas  during
 calibration should be approximately equal to the normal sampling rate of the  instrument,
 as flow rate can influence the measured concentration.  Proper flow rate is very important
 for the FED instruments.

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

 4.3.2 Field Span Check Procedures

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

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

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

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

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

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

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

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

      Data concerning the span checks (such as a plot of calibration gas  concentration
versus instrument  reading) should be recorded in the  inspector's field notes. This will
 demonstrate that the specific unit operated properly during the period in which compliance
information was  obtained at the  inspection site.  If gauges  are provided with  the
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 instrument, the field inspector also should occasionally note the instrument sample gas flow
 rate and document the flow rates occasionally during the inspection.

 4.4    INSTRUMENT MAINTENANCE PROGRAM AND RECORDS
                                   t
       In most regulatory agencies, numerous individuals will use  the portable organic
 vapor analyzers,  and it is  unrealistic to expect all  of them to be fully knowledgeable
 concerning instrument calibration and repair.  It is also unrealistic to ask each of them to
 make independent  determinations of organic vapor analyzer response factors or other
 performance data obtained on a frequent basis.  Therefore, one or two people should be
 assigned the  responsibility for the overall maintenance of the instruments and records of
 calibrations or repairs. Persons skilled in instrument  calibration and/or repair are needed
 for this assignment.  They can make whatever nonroutine tests and  measurements  are
 necessary to  ensure that the monitors continue to perform adequately.  They can also
 instruct other agency personnel concerning the proper way to replace filters, detectors, and
 battery packs; to operate the unit; and to perform field span checks. The persons assigned
 responsibility for the instruments should become familiar  with the  manufacturer's
 operation manual and the recommended routine maintenance schedules and procedures
 for each instrument.

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

       Records should be maintained on each instrument including: all calibrations, (field
and laboratory),  any  response  factor determinations, and all repair notes.  Problems
reported by field personnel should be briefly summarized in a chronological record. The
file should contain at least one copy of the operating manual for the instrument and a list
of all  pan numbers (if not included in the manual). There should also be a chronological
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 record of each time the instrument was used in the field, it's operator, and the location of
 the inspection.

 4.5 INSTRUMENT PERFORMANCE CHECKS

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

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

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

4.5.1 Leak Checks

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

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

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

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

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

4.5.2 Probe Condition

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

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

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

 4.5.3 Battery Pack Status Checks

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

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

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

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 4.5.4 Detector Condition

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

 4.5.5 Spare Pans and Supplies

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

       If the facility to be inspected is expected to be especially dirty, the inspector should
also have spare, dean probes and/or another complete instrument on hand.  It is often
much  easier  and  faster to diange equipment than to dean 'and  recalibrate heavily
contaminated instruments.
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 4.6    FIELD CHECKS

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

 4.6.1 Instrument Zero

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

4.6.2 Instrument Response.

       The instrument response should also  be checked routinely  during field testing
because all of the instrument types are vulnerable to operating problems that can result in
reduced sensitivity or complete loss of response.  In the case of FDD's, exposure to very high
VOC concentrations  (above 70,000 ppmv) can lead to flame-out of the unit  It is
sometimes difficult to hear the audible flame-out alarm over plant noise unless earphones
(supplied with some models) are used. If the inspector fails to hear the flame-out alarm, he
or she could miss a  number of fugitive leaks.  The catalytic combustion units are also
vulnerable to problems when exposed to very high concentrations as the detector can reach
temperatures high  enough to cause some loss of the catalyst coating.  If done repeatedly,
this can also shorten the life of the detector. Exposure to lead-containing gasoline can lead
                                       4.19

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 to poisoning of the detector catalyst.  For these reasons, the response should be checked
 whenever the unit is "pegged."

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

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

 4.6.3  Battery Condition

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

4.6.4 Probe/Sampling Line Leakage

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

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

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

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

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

5.1    FACILITY BACKGROUND INFORMATION REVIEW

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

 5.1.1   General Facility Background Information

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

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

5.1.2  Inspection Reports

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

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

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

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

 5.1.4  Information Sources

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

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

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

 5.1.5  Review of Reports

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

      The regulations also require sources to submit semiannual reports which contain
detailed information about the results of facility emission monitoring programs, including
the number of leaks detected  and the subject equipment  repairs.  The inspector should
identify any approved equivalent means of emission limitation,  any approved alternative
emission testing methods or alternative valve standards and review facility compliance. A
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                                      Figure 5-1
            BENZENE  NESHAP INSPECTION  PREPARATION  CHECKLIST
                               FOR INITIAL REPORTS
 Initial Report Review for Completeness

 40 CFR 61.10 Information
 	   Name & address of the owner or operator
 	   Location of the source
 	   Brief Description of the facility's operation and design capacity
 	   Average weight benzene or benzene related product processed per month
 	   Primary emission control (e.g. flare, scrubber, incinerator)
 	   Secondary emission control (if present)
 	   Control efficiency
 40 CFR 61247(a) and 40 CFR 61247(c) Information
 	   Statement that requirements of standard are being implemented
 	   List of all subject equipment including:
    ,  	   Type of equipment (e.g. valve or pump)
      	   Process unit where equipment is located
      	   Percent by weight benzene in the fluid at the equipment
      	   Process fluid state at the equipment (gas/vapor, liquid two phase fluid)
      	   Method of compliance with the  standard (e.g. monthly leak detection and  repair,
            equipped with dual mechanical seals)
	   Schedule for submitting semiannual reports (note in comments section)
Comments:
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 checklist designed to aid the inspector in evaluating the completeness of the semiannual
 reports is shown in Figure 5-2.

 5.2    DEVELOPMENT OF THE INSPECTION PLAN

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

 52.1   Plant Records

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

522   Inspection Monitoring

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

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                                      Figure 5-2

            BENZEN7E NESHAP INSPECTION PREPARATION CHECKLIST

                            FOR SEMIANNUAL REPORTS

Review of Semiannual Reports

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

Comments:


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

	    Process unit identification
	    Number of valves for which leaks were detected [40 CFR 61.242-7(b), 61243-2]
	    Number of valves for which leaks were not properly repaired [40 CFR 61.242-7(d)]
	    Number of pumps for which leaks were detected [40 CFR 61.242-2(b), 61.242-2(d)(6)]
	    Number of pumps for which leaks were not properly repaired [40 CFR 61242-2(c), 61.242-
       2(d)(6)]
	    Number of compressors for which leaks were detected [40 CFR 61242-3(f)]
	    Number of compressors for which leaks were not properly repaired [40 CFR 61242-3(g)]
	    For each improper (delayed) repair, the facts that explain  the  delay and,  where
       appropriate, why a process unit shutdown was technically infeasible
	    Dates of process unit shutdowns during the semiannual reporting period
	    Revisions to items submitted in the initial repon if changes have occurred during the
       reporting period
	    The results of all  performance  tests conducted  during  the  reporting period  on  all
       equipment that are designated to meet the "no detectable emissions" compliance option [40
       CFR 61242-2(e), 61242-3(i), 61242-4(a), 61242-7(0,61242-1 l(f)]
	    The results of all performance tests conducted during the reporting period on valves that
       are designated to meet the "allowable percentage of valves leaking" compliance option [40
       CFR 61243-1]
	    The results of all performance tests conducted during the reporting period on valves that
       are designated to meet the "skip period leak detection and repair" compliance option [40
       CFR 61243-2]

Comments:

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

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

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

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

Component

Stream composition
Gas

Liquid
-
Tag
number
-
id Repair S
Instrument
Date
leak
located

urvey Log
operator
Analyzer

Date
maintenance
performed

Component recheck
after maintenance
Date

Analyzer
readme
(ppmv)

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

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

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

 5.4    MONITORING EQUIPMENT

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

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

 5.5    SAFETY

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

5.6    REFERENCE MATERIAL

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

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

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

 6.1    SAFETY

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

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

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

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

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

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

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

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

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

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

 6.2    INSPECTOR'S RESPONSIBILITIES

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

 6.2.1   Legal Responsibilities

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

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

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

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

 63   FAOLTTY INSPECTIONS

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

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 6.3.1  Entry

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

 63.1.1 Arrival

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

 63.1.2 Consent

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

 632  Initial Interview

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

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

 6.3.3.1 Observation of Calibration Procedures

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

      o     The instruments should be calibrated daily with two  calibration standards,
            zero air and a calibration gas.
      o     The  gas concentration used for  calibration  should  be close to the leak
            definition  concentration.
      o     The calibration gas should be methane or n-hexane, certified to be accurate
            within 2 percent and within the specified self life.
      o     If gas blending is used to prepare gas standards, it should provide a known
            concentration with  an accuracy of plus or minus two percent
      o     The zero air used for calibration should be certified to contain less  than  10
            ppm of hydrocarbon in air and within the specified shelf life.
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       A number of other factors can be  important such  as:  probe cleanliness,  probe
 leakages, gas flow rates, improper warm-up period, incorrect zero or meter adjustment. If
 the meter readout cannot be adjusted to the proper value, a malfunction of the analyzer is
 indicated and corrective actions are necessary before using the analyzer.  The inspector
 should verify that the correct calibration gases are used and that the gases are within the
 proper range. The inspector should record  the instrument response time, response factors
 and calibration precision tests.

 6.33.2 Observing Leak Detection Monitoring By Plant Personnel

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

       Fugitive leaks from valves occur primarily from the valve stem packing gland.  This
 packing material is intended to seal the process gas and/or liquids from the atmosphere.
 As the packing lubricant is lost or the packing material wears, some  volatilization or
 organic vapors is possible.  For these types of valves, the emissions are monitored at the
 point where  the valve stem  leaves the packing  gland.  The normal  procedure  is to
 circumscribe  the valve stem  with the  probe held at the stem-packing gland interface.
 Maintaining such a close proximity to the stem is necessary in order to obtain an accurate
 measurement because  of the relatively poor capture effectiveness  inherent in the probe
 design. The presence of a strong cross-draft caused by ambient wind further reduces the
probe capture capability. For  these reasons the proper placement of the probe is critical.
It should be noted, however, that this monitoring requirement  dictates that the inspector
position himself or herself in the immediate vicinity of the leak because most probes are
relatively short in length. To minimize inhalation h,fl7?rds. the inspector should terminate
any monitoring when the concentration  of organic vapor in the breathing zone exceeds the
maximum safe concentration of his or her specific respirator.
                                         6-8

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

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

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

       Care must be. exercised when  monitoring sources, such as valves and pumps, that
 handle  heavy  liquid streams at  high temperatures.   Relatively  nonvolatile  organic
 compounds can condense in the probe and detector. Both the instrument response to the
 emissions and the instrument return  to zero may be slowed due to the condensation of
 these compounds.  For fugitive VOC sources that  have a highly variable leak rate, the
          sustained concentration or p™*"™1"1 repeated  concentration observed should
generally be recorded. .-

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

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

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

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

 6333 Spot-Check By Inspector

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

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

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                                 FIGURE 6-1
           FACILITY  LEAK MONITORING PROGRAM CHECKLIST

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

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

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

       Furthermore, the inspector should be aware of the common potential leak screening
 detection problems and the necessary  precautionary or corrective measures. Some of these
 common problems are described in the following paragraphs.

       The most typical monitoring problem encountered during inspection is locating the
 exact site of a leaking source because once emitted, organic vapors are quickly dispersed.
 To alleviate the problem, the probe should be positioned perpendicular to the source and
 rotated very slowly while simultaneously observing the analyzer meter. Unless the probe is
 positioned directly in line with the emission plume, detection will be difficult.

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

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                                FIGURE 6-2
           EQUIPMENT AND LEAK IDENTIFICATION CHECKLIST
 Spot check equipment for proper identification numbers and leak identification [40 CFR
 61242-(l)(d) and 61246(b)].
 	   Pumps [40 CFR 61.242-2]
 Equipment ID No.:
	   Compressors [40 CFR 61242-3]
Equipment ID No.:


	   Pressure relief devices [40 CFR 61242-4]
Equipment ID No.:

TJ	   Sampling connection systems [40 CFR 61242-5]
'Equipment ID No.:
	   Open ended valves or lines [40 CFR 61242-6]
Equipment ID No.:
                                    6-13

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

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


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

	   Product accumulator vessels [40 CFR 61242-9]
Equipment ID No.:
*   Is the above equipment marked in such a manner that it can be distinguished readily
    from other pieces of equipment [40 CFR 61.242-1(4)]?
*'  Be  sure to record the monitored CVSCD parameters as specified in the Control
    Device Checklist.
Comments:
                                     6-14

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

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

 6.3.4  Record Inspections

       The primary objective of the record -inspections is to minimize fugitive benzene
 emissions through requiring adherence to the reporting and recordkeeping requirements of
 40 CFR  61246 and 61.247.  From pre-inspection activities  the inspector should already
 possess a general understanding of the plant under investigation, the processes employed,
 the  products produced in  addition to being familiar with all applicable regulations and
 knowing what type  of information is required to  determine compliance with each.  This
 knowledge is necessary to help select those units suspected or detected as being compliance
 problems and to help avoid  giving unnecessary attention to items in  compliance or not
 covered  by compliance  regulations.  The  inspector, after  conducting the  facility leak
 monitoring portion  of the  inspection, should have a better  understanding of the facility
 layout and its program, as  well as having identified specific equipment tagged for repair
which can be checked during the record review. The inspector should seek to screen the
records for key data necessary to document compliance with the regulations.  The types of
data that are suggested for review are in-plant logs  and semiannual reports.

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

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                                  FIGURE 6-3
                       IN-PLANT RECORDS CHECKLIST
40 CFR 61.246(c) - Does the plant have the following information in a twoyear log
regarding leaks located on pumps (40 CFR 61.242-2), compressors (40 CFR 61.242-3),
valves (40 CFR 61242-7), liquid SRVs, flanges, and other connectors (40 CFR 61242-8)?
	   The  instrument  and  operator identification  numbers   and  the  equipment
      identification number.
	   The date the leak was detected and the dates of each attempt to repair the leak.
	   Repair methods applied in each attempt to repair the leak.
	   "Above 10,000 ppm" if the maximum instrument reading measured by the methods
      specified in  40 CFR 61.245(a) after each attempt is equal to or greater than 10,000
      ppm.
	   "Repair delayed" and the reason for the delay if a  leak is not repaired within  IS
      calendar days after discovery of the leak.
	   The signature of the owner or operator (or designate) whose decision it was that
      repair could not be effected without a process shutdown.
	   The expected date of successful repair of the leak if a leak is not repaired within IS
      calendar days after discovery of the leak.
	   The date of successful repair of the leak.
•   40 CFR 61246(b) specifies tagging requirements for leaks of the above listed type.
    Select a few recently detected leaks to field check for proper tags and place them on
    the appropriate portion of the Equipment and Leak Identification Checklist.
•'  Are there any general comments regarding the frequency and duration of delayed leak
    repairs?
Comments:
                                      6-16

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                                   FIGURE 6-3

                IN-PLANT RECORDS  CHECKLIST fCONTmiJEDl
 40 CFR 61.246(d) - Does the plant have the following information pertaining to their
 closed vent system and control device (CVSCD) in a permanent log?

 	   Detailed  schematics,  design  specifications,  and  piping and  instrumentation
       diagrams.

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

 	   A description  of the parameter or  parameters monitored [see  61.242-1 l(e)] to
       ensure that the control device is operated and maintained in conformance with its
       design and an explanation of why that parameter (or parameters) was selected for
       monitoring.

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

 	   Dates of startups and shutdowns of the CVSCD.

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

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

	  An analysis demonstrating the design capacity of the process unit

	  An analysis demonstrating that equipment is not in benzene service.

Comments:
                                     6-17

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                                  FIGURE 6-3

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

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

      	   Pumps [40 CFR 61.242-2]
      	   Compressors [40 CFR 61.242-3]
      	   Pressure relief devices in gas/vapor service [40 CFR 61.242-4]
      	   Sampling connection systems 140 CFR 61.242-5]
            Open ended valves or lines [40 CFR 61242-6]
      ~   Valves [40 CFR 61.242-7]
            Pressure relief devices in liquid service, flanges and other connectors [40
      ~~~   CFR 61242-81
            Product accumulator vessels [40 CFR 61242-9]
      ~   CVSCD [40 CFR 61242-11]

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

            Pumps [40 CFR 61242-2(e)]
            Compressors [40 CFR 61242-3(i)]
      ~   Valves [40 CFR 61242-7(0]

	   A list of identification numbers for pressure relief devices which are required to
      meet the "no detectable emissions" standard [40 CFR 61242-4(a)].

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

            Pumps [40 CFR 61242-2(i)
            CompressorsMO CFR 61242-3(i)]
      —   Valves [40 CFR 61242-7(01
      ~   Pressure relief devices [40 CFR 61242-4(a)]

      A list of identification numbers for equipment in vacuum service [which are exempt
      per [40 CFR 61242-l(e)J.

Comments:
                                     6-18

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                                  FIGURE 6-3

                TN-PLANT RECORDS  CHECKLIST (CONTINUED^



 40 CFR 61246(0 - Does the plant have the following information in a permanent log?

       A  list of all  valves which are designated "unsafe to monitor"  as  outlined  in
       40CFR61.242-7(g).

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

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

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

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

 Comments:



 40 CFR 61246(g) - For valves complying with the "skip period leak detection and repair"
 compliance option [see 40 CFR 61243-2], does the plant have a permanent log containing:

	    A schedule for monitoring.
	    The percent of valves found leaking during each monitoring period.

40 CFR 61246(h) - Pumps and compressors that are equipped with a dual mechanical seal
system pursuant to 40 CFR 61242-2(d) or 40 CFR 61242-3(a) must have sensors to detect
failure of the seal system, the barrier fluid system, or both. The following information
should be in a permanent log regarding these types of pumps and compressors:

	    For each pump, the design criterion  (or parameter chosen to monitor)  and  an
       explanation of that criterion [40 CFR 61242-2(d)(5)].

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

       	  Any changes to this criterion and the reasons for the changes.

Comments:
                                     6-19

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

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

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

       The in-plant logs  and records should be  examined for inconsistencies with the
information presented to the regulatory agencies in the initial and semiannual reports (40
CFR 61247). Some typical reporting inconsistencies are as follows:

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

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

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

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                                   FIGURE 6-4

                        CONTROL DEVICE CHECKLIST




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


	   Vapor recovery (condensers, adsorbers, absorbers)

	   Enclosed combustion (incinerators, boilers)

	   Flares

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

Comments:
Vapor Recovery Systems 40 CFR 61242-ll(b):

	   Compression/refrigeration, condensation

	   Adsorption (e.g. carbon bed filters)

	   Absorption (e.g. wet scrubbers) ''

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

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                                   FIGURE 6-4
Enclosed Combustion Device 40 CFR 61242-1 l(c):

	Incinerator

	Boiler

What is the claimed  control device  efficiency?  Is  the efficiency measured (tested) or
calculated?  Obtain a copy of any of these test results or calculations.   What is the
combustion temperature during the inspection (from the field or control room)?
Flares 40 CFR 61.242-1 l(d):

	   Steam Assisted

	   Air Assisted

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

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

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

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

 63.5  Closing Conference

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

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

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

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                              7.0 POST INSPECTION

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

 7.1    WRITING  THE REPORT

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

      The  inspection results are to be organized in a  comprehensive,  objective and
 accurate report In preparing an  inspection report, confidential material must be treated
with care and included only  if relevant to the compliance discussions.  A standardized
 format for the inspector's report is recommended to enable accurate and efficient reviews.
 In addition, adopting a standardized reporting format emphasizes completeness through
                                       7-1

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 uniformity of data presentation, promotes better quality reporting procedures by inspectors
 and is  beneficial in correlating benzene leaks with  noncompliance,  thereby  enhancing
 speed of review  and allowing prompt response concerning  any  necessary enforcement
 proceedings. The recommended report elements are listed below:

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

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

 7.1.1  Introduction

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

 7.12 Compliance Status for Regulated Equipment

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

(1)   A thorough determination of  the source compliance status according to each
      applicable rule (40 CFR 61241 through 61242-11).

(2)   A general discussion addressing exemptions.

(3)   A summary of any alternative standards pursuant to 40 CFR 61243 and 61244.
                                      7-2

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 (4)  .  A-discussion of the leak detection procedures conducted as described in 40 CFR
       61245 and Reference Method 21.

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

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

 7.1.2.1 Individual Source-Compliance Status .

       This section must address each of the following sources that are intended to operate
 in benzene  service:  pumps, compressors,  pressure relief devices, sampling connection
 systems, open-ended  valves  or lines, valves, flanges and other connectors,  product
 accumulator vessels and control devices or systems pursuant  to 40 CFR 61262-1, 61242-2,
 61242-3,61242-4,61242-5,61242-6,61242-7,61242-8,61242-9,61242-10 and 61242-11.
The completed benzene inspection  checklists, initial and semiannual reports and copies of
in-plant logs may be used to determine compliance.  Any violation, whether it  is procedural
or an excess emission, constitutes noncompliance.  The following illustrates a typical report
format:

(1)   40 CFR 61242-l(d) - Each piece of equipment in benzene service is tagged with a
      permanent metallic tag. Compliance  determined by visual observation.

(2)   40 CFR 61242-2(a)(l) and 61242-2(a)(2)  - All pumps in benzene service are
      monitored on a monthly basis. Each pump is visually inspected on a weekly basis.
      The company appears  to be in compliance with  the requirements  of this rule.
      Compliance determined by record review and discussions with facility personnel.
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 (3)   40 CFR 61242-4 - This facility has a  total of nineteen relief valves in benzene
       service.  They operate with no detectable emissions (less than 500 ppm).  The
       company is  aware of the requirements of this rule.  Compliance determined by
       record review and monitoring.

 7.1.2.2 Exemptions

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

 7.1.2.3 Alternative Standards

       If the facility has requested and received  permission to comply with one of the
 alternative standards for valves or and  alternative method of emission limitation, the
 inspector should discuss facility compliance with the alternative standard. The inspector
 should evaluate  whether the facility owner  or  operator  understands the alternative
 standard and  performs  the necessary leak  detection  monitoring  and recordkeeping
 required to comply with the standard.  Deviations from any of the  leak monitoring or
 recordkeeping requirements of 40 CFR 61243 constitute a violation.

 7.12.4 Leak Detection Procedures
                                             . i   '• !
       The inspector's report should include a section that  discusses the procedures
 employed in the facility  leak monitoring program.  The discussion should  be  brief and
 emphasize those pans of the inspection in which deviations from established performance
 criteria, calibration and leak monitoring procedures of Reference Method 21 are observed.
The inspector should  include  comments  regarding  the  portable VOC calibration
information Le., dates of calibrations, instrument response factors, calibration precision
and instrument response  time. Any quality assurance procedures observed or performed
during the leak detection monitoring such as drift span checks, response check and zero gas
checks should be noted.  The inspector should also note whether the facility is operating
under normal conditions and capacity on the day of inspection.
                                       7-4

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 7.12.5 Reports and Recordkeeping

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

 7.13  Data

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

 7.1.4   Summary

       The summary should contain a brief overview of the inspection results, the overall
 compliance  status  of the facility and a description of any  action taken as a result  of the
 investigation.  Although  each agency may use somewhat different formats,  the inspector
 should be cautioned against presenting any conclusions regarding violations in the body of
 the report Ideally, the summary section is completely separate from the rest of the  report
 and reserved for addressing facility violations. By placing  the summary at the end  of the
 report, it is easier to exclude it when releasing the report to  other governmental agencies or
 if legal actions are pending. If noncompliance results are  juxtaposed with the  applicable
performance specification, interpretation and  review will be  greatly facilitated.  The
following example may be used:
                                       7-5

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       During the inspection, the compliance status with all applicable National Emission
 Standards for Hazardous Air Pollutants (NESHAP) regulations was investigated.  Records
 and recordkeeping requirements as well as leak  monitoring procedures were reviewed.
 The facility appears to be in compliance with these rules except the following:

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

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

 12    HANDLING  CONFIDENTIAL BUSINESS INFORMATION

       Industry today is increasingly sensitive to agency use and disclosure of confidential
 business information. The EPA established regulations governing confidential  business
 information are covered under 40 CFR Part 2 Subpart B.  Because the inspector can be
 held personally liable for disclosure, it is extremely important for all agencies performing
 benzene equipment  leak inspections  to adopt rules and  guidelines  for handling  and
 releasing confidential business information. From  the inspector's standpoint, confidential
 business information is defined as information received under a request of confidentiality
which may concern or relate to trade secrets, processes, operational data, style  of work,
 statistical data or financial data including amount  of source of income, profits, losses or
expenditives.  This information may exist in the written form, in photographs or in the
inspector's memory.   Whenever possible, confidential business information  should be
referenced in a nonconfidential manner. For example, the inspector may simply refer to a
document in the confidential files but present only a general description of the referenced
document in his or her inspection report, thereby minimizing the risk of exposure.  At all
times, confidential business information should be  kept in a secure, lockable file cabinet
expressly dedicated for  confidential  information,  and  precautions should  be made to
                                      1-6

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safeguard the confidential data.  If confidential business information must be included in
the inspector's report, the entire report must be treated as a confidential document.
                                       7-7

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                             REFERENCES

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

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

3.    U.S. Environmental Protection Agency.  Air Pollution Training  Institute
      Course SI:417 Controlling VOC Emissions from Leaking Process Equipment
      - Student Guidebook. EPA 450/2-82-015 August 1982.
                                  8-1

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PORTABLE INSTRUMENTS USER'S
MANUAL FOR MONITORING VOC
          SOURCES
  JCE VOLUME 3 : INSPECTION MANUALS

-------
            United States      Office of Air Quality       EPA- 340 '1-86-015
            Environmental Protection  Planning and Standards      June 1986
            Agency        Washington. DC 20460

            Stationary Source Compliance Series
&EPA      Portable
            Instruments
            User's Manual
            for Monitoring
            VOC Sources

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                                  EPA-340/1-86-015
Portable Instruments User's
    Manual for Monitoring
           VOC Sources
                     by
               PEI Associates. Inc.
               11499 Chester Road
               Post Off ice Box 46100
            Cincinnati. Ohio 45246-0100
                    and

               Richards Engineering
            Durham. North Carolina 27705
              Contract No. 68-02-3963
             Work Assignment No. 103
                  Prepared for

            EPA Project Officer: John Busik
     EPA Work Assignment Manager: Mary Cunningham
       U.S. ENVIRONMENTAL PROTECTION AGENCY
         Stationary Source Compliance Division
       Office of Air Quality Planning and Standards
              Washington. D.C. 20460

                  June 1986

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                                  DISCLAIMER
     This report was prepared by PEI Associates, Inc., Cincinnati, Ohio,
under Contract No. 68-02-3963, Work Assignment No.  103.   It has been reviewed
by the Stationary Source Compliance Division of the Office of Air Quality
Planning and Standards, U.S. Environmental  Protection Agency and approved
for publication.  Approval  does not signify that the contents necessarily
reflect the views and policies of the U.S.  Environmental  Protection Agency.
Mention of trade names or commercial products is not intended to constitute
endorsement or recommendation for use.

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                                  CONTENTS
Tables	'•  •  •    y
Acknowledgment 	   vi

     1.   Introduction 	    1

     2.   Regulatory Requirements	    3

               New Source Performance  Standards	    3
               National  Emission Standards  for  Hazardous  Pollutants.  .  .    9
               Instrument specifications  	   15

     3.   Portable Instrument Operating Principles  	   16

               VOC detectors	   16
               Thermocouples  	   19
               Static pressure gauges	   20

     4.   Establishing an Agency Program  for the  Use  of Portable
            Instruments for Monitoring VOC  and  Air  Toxics Sources.  ...   21

               Selection of the necessary types of  instruments  	   21
               Instrument spare parts  and accessories	   28
               Laboratory and shop support  facilities	   29
               Instrument maintenance  program and records	   31
               Costs	   32
               Preparing bid  specifications	   39

     5.   Instrument Calibration and Evaluation	   41

               Instrument calibration  requirements  and procedures.  ...   41
               Routine laboratory evaluation of instrument performance .   49
               Routine field-oriented  evaluations of  instrument condi-
                 tions and performance	   51

     6.   Field Inspection Procedures  and Inspection  Safety	   58

               Principles, requirements,  and limitations  of agency
                 inspections	   58
               Screening tests for VOC leaks from process equipment.  . .   61
               Inspection of  carbon-bed adsorbers	   67

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                            CONTENTS (continued)

          Inspection of thermal and catalytic incinerators 	   69
          Inspection of vapor recovery systems 	   71
          Surveying emissions from stacks, vents, and roof monitors. .  .   72

References	   75

Appendices

     A.   Reference Method 21 and NSPS and NESHAPS Regulations 	   80
     B.   Organic vapor analyzer response factors	  119
     C.   lonization potentials of selected organic compounds	130

Glossary	  134
                                      iv

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                                   TABLES

Number
   1      NSPS VOC Fugitive (Leak)  Emission  Limits
   2      NSPS VOC Monitoring Requirements  for  Sources  Controlled  by
            Carbon-Bed Absorbers and Thermal  or Catalytic  Incineration  .     6
   3      NESHAP Monitoring Requirements  for  Fugitive  Emissions .....    10
   4      Most Common Portable VOC Detection  Instruments  ........    17
   5      Ease-of-Use of Organic Vapor Analyzers ............    25
   6      Definitions of Hazardous Locations  in Accordance With  the
            National Electrical Code ..................    26
   7      Intrinsic Safety Ratings of Commercial Instruments, January
            1986 ...........................  .    27
   8      Estimated Costs of HNU Model PI-101 Photoionization Analyzer .    34
   9      Estimates Costs for Foxboro Model 108 FID Type  Orgr.nic Vapor
            Analyzer ..........................    35
  10      Estimated Costs for Bacharach TLV Sniffer ...........    36
  11      Estimated Costs for Omega Portable  Thermometer  ........    37
  12      General Equipment Costs ....................    39
  13      Recommended Calibration Gases for Routine Instrument Service .    43
  14      Calibration Time Requirements When  Using Commercially Prepared
            Calibration Gases ......................    44
  15      Calibration Time Requirements When  Calibration  Gas Mixtures
            are Blended .........................    46
  16      Time Required for Field Span Checks ..............    48
  17      Partial Listing of Recommended Ons ite Spare Parts and Supplies
            for Portable Instruments ..................    55
  18      Estimated Leakage Rates for Refinery Components ........    63

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                                ACKNOWLEDGMENT


     This report was prepared for the U.S.  Environmental  Protection Agency by
PEI Associates, Inc., Cincinnati, Ohio, and Richards Engineering, Durham,
North Carolina.  Mr. John Busik was the EPA Project Officer and Ms. Mary
Cunningham the Work Assignment Manager.  Mr. John Zoller served as the Project
Director, and Mr. David Dunbar was the Project Manager.   The principal authors
were Mr. G. Vinson Hellwig, Mr. David Dunbar, and Mr.  John Richards, Richards
Engineering.  Mr. Tom Ponder served as Senior Technical  Advisor.   The authors
wish to thank Ms. Mary Cunningham for her guidance and direction on this work
assignment.

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                                  SECTION 1
                                INTRODUCTION

     The U.S. Environmental Protection Agency (EPA)  has promulgated New Source
Performance Standards (NSPS) and National Emission Standards for Hazardous
Air Pollutants (NESHAP's) for several categories of sources that emit volatile
organic compounds (VOC's) and that require monitoring with portable detection
instruments.  The EPA has also issued control techniques guidelines (CTG's)  for
a number of source categories that emit VOC's.   The source categories covered
by the NSPS, NESHAP's, and CTG's include petroleum refineries, synthetic or-
ganic chemical plants, coating operations, and natural gas processing plants.
     Fugitive VOC emissions at these sources occur at valves, pumps, drains,
pressure relief devices, etc.  If these points of fugitive emissions can be
identified, the leaks can be repaired and the emissions can be eliminated.
     This manual presents information on the principles of operation of cur-
rently available portable monitors and the field inspection techniques for
the monitor's safe use in both screening and compliance determinations.  This
manual is intended to be used by State or local agencies.
     The level of the inspection performed is often determined by the com-
pliance history of the source and the regulatory requirements.  If the in-
spection procedure involves the use of a sophisticated instrument to deter-
mine compliance with a regulation, it is classed as a Level 3 inspection,
which is the most thorough and time-consuming level.  Level 3 inspections are
designed to provide a detailed engineering analysis of source compliance by
use of measured operating parameters or emissions data.  The Level 3 inspec-
tion for determining fugitive VOC emissions requires the use of portable hand-
held instruments.  These instruments include portable organic vapor monitors,
thermocouples, and static pressure gauges.
     The EPA has published Reference Method 21 to provide a technical method
to test for leaks from these sources.  Method 21 allows the user to select

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one of several instruments available on the market if they meet the specifi-
cations and performance requirements, discussed in Section 2.   A summary of
the published specifications of many of the portable VOC monitors is presented
in this manual.
     Because the inspector will be using a reference test method and the
aquired data may be used in an enforcement action against the  facility,
special care should be taken in the use of portable instruments during a
Level 3 inspection.  Calibration procedures must be strictly adhered to  verify
the acquired data.

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                                  SECTION 2
                           REGULATORY REQUIREMENTS

     The use of portable VOC-detecting instruments is based primarily on re-
quirements regarding control of leaks as contained in the NSPS and NESHAP's
and in the CTG's published by EPA to provide guidance for State and local
agencies in the development of their own regulations.

2.1  NEW SOURCE PERFORMANCE STANDARDS
     Two categories of VOC emissions must be monitored:   1) emissions from
sources controlled by carbon-bed absorbers, thermal incinerators, and vapor
recovery systems; and 2) fugitive emissions from process equipment.  Appendix
A contains the NSPS requirements for the source categories in Table 1.  The
monitoring is to be performed as described in 40 CFR 60, Appendix A, Reference
Method 21.
2.1.1  Determination of Volatile Organic Compound Leaks  From Sources Con-
       trolled by Carbon-Bed Absorbers, Condenser Units, and Thermal or'
       Catalytic Incinerators
     Carbon-bed absorbers, condenser units, and thermal  or catalytic inciner-
ators are used to control emissions from the surface coating of metal furni-
ture, automobiles and light-duty trucks, pressure-sensitive tape and labels,
large appliances, metal coils, and beverage cans, and flexible vinyl and
urethane coating and printing.
     Carbon-bed absorption units, condenser units, and thermal or catalytic
incinerators normally require onsite monitoring with stationary instruments
rather than portable ones; however, some measurements can be made with portable
instruments to verify both the operation of the control  equipment and the on-
site stationary monitoring results.  Carbon-bed absorbers and condenser units
require the use of both VOC-detection equipment and temperature-monitoring
equipment.  Thermal and catalytic incinerators also require the use of
temperature monitoring equipment.

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             TABLE  1.  NSPS VOC FUGITIVE (LEAK) EMISSION LIMITS
     Source category
    Equipment
      Emission
       limit
Monitoring
requirement
 Subpart VV - Equipment
 Leaks of VOC in the
 Synthetic Organic
 Chemicals Manufacturing
 Industry
Subpart XX - Bulk
Gasoline Terminals
Subpart GGG - Equip-
ment Leaks of VOC in
Petroleum Refineries
Valves


Pumps
                          Compressors
                          Sampling connec-
                          tions

                          Open-ended lines
                          Pressure-relief
                          devices
Exception:
plants process-
ing only heavy
liquids or
solids and
facilities pro-
ducing beverage
alcohol

All the loading
racks at a bulk
gasoline ter-
minal that de-
liver gasoline
into any de-
livery tank truck

Valves
                          Pumps
                          Sampling connec-
                          tions
10,000 ppm by volume
(ppmv)

10,000 ppmv or
visible leak from
seal in pumps in
liquid service

Zero
                  Zero
                  Zero
                  500 ppmv or less
                  above background
                  level
10,000 ppmv
10,000 ppmv
                  10,000 ppmv
                  or visible leak

                  Zero
Monthly
Monthly
No require-
ments

No require-
ments

No require-
ments

Periodic3
Monthly
Monthly


Monthly
                       No require-
                       ments
(continued)

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TABLE 1 (continued)
Source category


Subpart KKK - Equip-
ment Leaks of VOC from
Onshore Natural Gas
Processing Plants



Equipment
Open-ended lines
Pressure relief
device
Valves
Pumps
Sampling connec-
tions
Open-ended lines
Pressure relief
devices
Emission
limit
Zero
500 ppmv or less
above background
level
10,000 ppmv
10,000 ppmv
Zero
Zero
10,000 ppmv
Monitoring
requirement
No require-
ments
Periodic9
Monthly
Monthly
No require-
ments
No require-
ments
Periodic3
aExcept in the case of pressure releases where the source must be monitored
 within 5 days of a pressure release.

     In certain source categories, the NSPS regulations require adherence to
an emission limit or some other operating parameter.   Compliance with this
requirement is monitored by onsite equipment.   These  standards apply to
various surface coating operations and flexible vinyl and urethane coating
and printing (Table 2).
     Portable monitoring instruments can be used on the exit vent/stack side
of the carbon absorbers and condenser units to detect breakthrough of the
VOC's.  A portable monitor used to perform this type  of test must be sensi-
tive in the 50 to 500 ppmv range.   Such an instrument can detect VOC emis-
sions that are over and above what would be expected  from a controlled source.
Because these portable instruments are continuous or  semi continuous, the
probe only has to be put in the gas stream for the length of time necessary
to exceed the response time specified in the instrument manual.

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         TABLE 2.   NSPS VOC MONITORING REQUIREMENTS  FOR  SOURCES CONTROLLED BY CARBON-BED ABSORBERS
                                   AND THERMAL  OR CATALYTIC  INCINERATION
  Source category
    Equipment or
     operations
   Emission limit or
     work practice
    Monitoring requirements
Subpart EE - Surface
Coating, of Metal
Furniture
Subpart MM - Automobile
and Light-Duty Truck
Surface Coating Opera-
tions
Subpart RR - Pressure-
Sensitive Tape and
Label Surface Coating
All metal furniture
surface coating
operations applying
organic coatings

Prime coating      ;
                         Guide coating
                         Top coating
Exempt:  plastic
components and all-
plastic bodies on
separate lines

Coating line Input-
Ing greater than
45 Mg (50 tons)
VOC per 12-month
period
0.90 kg/liter of coating
solids applied
0.16 kg/liter of applied
coating solids per each
prime coat operation

1.40 kg/liter of applied
coating solids per each
guide coat operation

1.47 kg/liter of applied
costing solids per each
top coat operation
(continued)
0.2 kg of VOC per kg of
coating solids applied

         or

90% VOC emission reduc-
tion or an overall emis-
sion reduction equivalent
to the 0.20 kg per kg of
coating solids applied,
whichever Is less stringent
Temperature measurement with
capture system and incineration
Permanent record of incinera-
tor temperature, if applicable


Same as above
                                                    Same as  above
                                                                            Same as above
Facilities with thermal  in-
cinerators:  temperature of
incinerator's exhaust gases
                                                                             Facilities  with  catalytic in-
                                                                             cinerators:   gas temperature
                                                                             upstream and  downstream of the
                                                                             catalyst bed

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TABLE 2 (continued)
  Source category
    Equipment or
     operations

   Emission limit or
     work practice
    Monitoring requirements
Subpart SS - In-
dustrial Surface Coat-
ing:  Large Appliances

Subpart TT - Metal
Coil Surface Coating
Subpart WW - Beverage
Can Surface Coating
Industry
Coating line Input-
Ing less than 45 Mg
(50 tons) VOC per
12-month period

All large appliance
surface coating
line operations

Prime coating
operations, finish
coating operations,
and combined prime
and finish coating
operations when
finish coat Is
applied wet on wet
over prime coat
and cured simul-
taneously
Two-piece beverage
can coating:

Exterior base
coating operation
                         Clear base coating
                         or overvarnlsh
                         coating
                                              Not subject to limits
                                              subject to monitoring
                                              requirements
                      but
0.90 kg/liter applied coat-
ing solids
0.28 kg/liter coating solids
with no emission control

0.14 kg/liter coating solids
with continuous emission
control

10% VOC's applied (90%
emission reduction)

Prorated value with
Intermittent emission
control
Temperature measurement with
capture system and incinera-
tion

Continuous record of incinera-
tor temperature, if applicable

Same as above
                                                                             Same  as  above
                                                                             Same  as  above
0.29 kg VOC/liter of
coating solids (except
clear base coating)

0.46 kg VOC/liter of
coating solids
                                                                             Temperature measurement for
                                                                             incineration
                                                    Same as above
 (continued)

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   TABLE 2  (continued)
     Source category
    Equipment or
     operations
   Emission limit or
     work practice

    Monitoring requirements
   Subpart FFF - Flexible
   Vinyl and Urethane
   Coating and Printing
Inside spray coat-
Ing

Rotogravure print-
Ing line
0.89 kg VOC/liter of
coating solids

Reduce gaseous VOC emis-
sions by 85%
Temperature measurement for
Incineration

Continuous measurement and
recording of the temperature of
thermal incinerator exhaust
gases or of the gas tempera-
ture upstream and downstream
of a catalytic incinerator,
installation of a continuous
monitoring system for solvent
recovery
00

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     Portable monitors also can be used to check the continuous monitor re-
quired at some sources.  This measurement process is the same as that used for
testing breakthrough.
     A thermocouple can be used to check the exit gas temperature from a
thermal or catalytic incinerator.  A baseline stack temperature measurement
should be taken at the time the incinerator's permanent thermocouple is cali-
brated.  This baseline temperature measurement gives a reference point for
future inspections.
2.1.2  Fugitive Emissions From Process Equipment
     For the synthetic organic chemicals manufacturing industry, bulk gaso-
line terminals, petroleum refineries and on-shore natural gas processing
plants (Table 1), NSPS requires periodic leak inspections of the equipment to
determine if. any fugitive VOC emissions are escaping.  These leak inspections
are performed with portable VOC-detecting equipment according to Reference
Method 21.  Equipment to be tested includes valves, pumps, seals, compressors,
sampling connections, open-ended lines, and pressure-relief devices.
     A portable VOC-detection monitor may be used for leak inspections.  The
probe must be inserted in the vicinity of a potential leak and must be moved
around the area where the leak may occur.  The leak must be compared against
a background concentration, especially when the standards call for an emis-
sion limit of 0 or 500 ppmv.  Field procedures for conducting leak inspection
monitoring are discussed in Section 6 of this manual.

2.2  NATIONAL EMISSION STANDARDS FOR HAZARDOUS POLLUTANTS
     For certain categories of sources, NESHAP's place a not-to-be-exceeded
limit on fugitive emissions from processes, pumps, compressors, valves,
pressure-relief systems, etc.  These standards apply to vinyl chloride,
ethylene dichloride, benezene, and volatile hazardous air pollutants (VHAP).
     Emissions are monitored both by stationary onsite monitors and portable
instruments, depending on the regulatory requirements.  Table 3 lists the
regulated facilities, emission standards (where monitoring is required), and
monitoring requirements for fugitive emissions from process sources.  The
methods of detecting leaks and types of equipment to be inspected for leaks

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  Source category
                      TABLE 3.   NESHAP MONITORING REQUIREMENTS FOR FUGITIVE  EMISSIONS
    Equipment or
     operations
   Emission limit or
   equipment standard
    Monitoring requirements
Subpart F - Vinyl
Chloride
Ethylene dlchlorlde
manufacture
                         Vinyl chloride
                         manufacture

                         Polyvlnyl chloride
                         manufacture

                           Reactor; strip-
                           per; mixing,
                           weighing and
                           holding con-
                           tainers; monomer
                           recovery system

                           Reactor opening
                           loss
                           Reactor manual
                           vent

                           Sources follow-
                           ing stripper
1)  Ethylene dichloride
    purification:   10 ppmv
2)  Oxychlorination reactor:
    0.2 g/kg (0.0002 Ib/lb)
    of the 100% ethylene
    dichloride product

10 ppmva
                     10 ppmv
                     0.02 g vinyl chloride/kg
                     (0.00002 Ib vinyl chloride/
                     No emissions
                     For each calendar day:
                     1)  Using stripping tech-
                         nology - 2000 ppmv for
                         polyvinyl chloride dis
                         persion resins (exclud
                         ing latex), 400 ppmv
Source test
Continuous monitor
Source test
Continuous monitor
                                                    Source test
                                                    Continuous monitor
                               Source test
                               Continuous monitor
                               Source test
                               Continuous monitor
                               Source test
(continued)

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TABLE 3 (continued)
  Source category
Equipment or
 operations
Emission limit or
equipment standard
Monitoring requirements^
                         Ethylene bichloride,
                         vinyl chloride and/
                         or polyvlnyl
                         chloride manu-
                         facture

                           Relief valve dis-
                           charge

                           Loading and un-
                           loading lines
                           Slip gauges
                           Pump; compressor
                           and agitator seal
                                                  each for other polyvinyl
                                                  chloride resins (includ-
                                                  ing latex)

                                              2)  Other than stripping
                                                  technology - 2 g/kg
                                                  (0.002 Ib/lb) product for
                                                  dispersion polyvinyl
                                                  chloride resins (exclud-
                                                  ing latex)
                                                  0.4 g/kg (0.0004 Ib/lb
                                                  product for other poly-
                                                  vinyl chloride resins
                                                  (Including latex)
                                                Source  test
                 No discharge
                 0.0038 m  after each load-
                 ing, or 10 ppm when con-
                 tained by a control system

                 10 ppm from the required
                 control system

                 10 ppm from the required
                 control system with seals
                            No requirement
                            Source test
                            Continuous monitor
                            Source test
                            Continuous monitor

                            Source test
                            Continuous monitor
 (continued)

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TABLE 3 (continued)
  Source category
    Equipment or
     operations
   Emission limit or
   equipment standard
    Monitoring requirements
Subpart J - Equipment
Leaks (Fugitive Emis-
sion Sources) of
Benzene
(continued)
  Leakage from
  relief valves

  Manual venting
  of gases

  Opening of
  equipment

  Samples (at
  least 10% by
  weight vinyl
  chloride)

  Leak detection
  and elimination

  In-process waste-
  water

Pumps
Compressors
                         Pressure-relief
                         devices

                         Sampling connec-
                         systems

                         Open-ended valves
                         or lines
                                              Rupture disk must  be
                                              installed

                                              10 ppmv from a  required
                                              control system

                                              10 ppmv from a  required
                                              control system

                                              Returned to system
                                              Implementation of an
                                              approved program

                                              10 ppmv before discharge
No leakage (instrument
reading <10,000 ppmv)

Meet equipment specifica-
tions

No detectable emissions
                     No VHAP emissions
                     Meet equipment specifications

                     Meet equipment specifications
                               No requirement
                               Source test
                               Continuous monitor

                               Source test
                               Continuous monitor

                               No requirement
                               Approved testing program
Source test
Continuous monitor

Monthly leak detection and
repair program

No requirement
                                                    No requirement
                               No requirement
                               No requirement

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TABLE 3 (continued)
  Source category
    Equipment or
     operations
   Emission limit or
   equipment standard
    Monitoring requirements
Subpart V - Equipment
Leaks (Fugitive Emis-
sion Sources)
(continued)
                         Valves
Pressure-relief
devices In liquid
service and flanges
and other con-
nectors

Product accumulator-
vessels or systems'
designed to produce
or use >1,000 Mg/yr
benzene

Closed-vent systems

Control systems:

Vapor recovery
systems

Enclosed combustion
devices

Flares

Pumps, compressors,
pressure relief
devices, sampling
connection systems,
open-ended valves
or lines, valves,
flanges and other
No leakage (Instrument read-
Ing <10,000 ppmv)

No leakage (Instrument read-
ing <10,000 ppmv)
                                              Meet equipment specifications
No detectable emissions



Operate at 95% efficiency


Operate at 95% efficiency


No visible emissions

Same as Subpart J
Monthly leak detection and
repair program

No requirement
                               No requirement
No requirement



No requirement


No requirement


No requirement

Same as Subpart J

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TABLE 3 (continued)
  Source category
Equipment or
 operations
Emission limit or
equipment standard

Monitoring requirements
                         connectors,  pro-
                         duct accumulator
                         vessels,  and
                         control  devices
aBefore opening any equipment for any reason,  the  quantity of vinyl chloride is to be reduced so that the
 equipment contains no more than 2.0% by volume vinyl chloride or 0.0950 m3 (25 gal) of vinyl chloride,
 whichever is larger, at standard temperature  and  pressure.

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are similar to those presented in Subsection 2.1.2.   Table 3 also presents
the requirements for leak detection and the emission limits.  It should be
noted that because vented discharges from NESHAP sources are controlled with
thermal or catalytic incineration devices, these sources are monitored with
temperature sensing devices.   Appendix A contains the NESHAP1s that are
listed in Table 2.

2.3  INSTRUMENT SPECIFICATIONS
     Limited portable VOC-detection instruments specifications are outlined in
Appendix A of 40 CFR 60.  The reader is encouraged to review Reference Method
21 (Appendix A) to become familiar with the required instrument specifications.
It should be noted that no specifications concerning other types of instru-
ments such as thermocouples and static pressure gauges are currently available.
                                     15

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                                  SECTION 3
                   PORTABLE INSTRUMENT OPERATING PRINCIPLES

     Various types of instruments are available for detecting organic  vapors
during inspections.  These monitors involve a variety of detectors  that
operate on several different principles.   Each detector has its  own advantages,
disadvantages, and sensitivity.
     Other types of portable equipment used during source inspections  in-
clude temperature monitors, flow monitors, and pressure gauges.   This  equip-
ment is much smaller, less expensive, and easier to use than the portable  VOC
detectors.

3.1  VOC DETECTORS
     Several types of portable VOC detectors can be used either  as  screening
tools or to meet the requirements of EPA Method 21.  These include:
     o    Flame ionization detector (FID)
           •
     o    Photoionization (ultraviolet) detector (PID)..
     o    Nondispersive infrared detector (NDIR)
     o    Catalytic combustion or hot wire detector.
     The specifications of these instruments vary greatly with regard to
sensitivity, range, and responsiveness.  Table 4 lists the most common moni-
tors currently in use and the associated detection principle, range, sensi-
tivity, and response time of each.
3.1.1  Flame Ionization Detector
     In an FID, the sample is introduced into a hydrogen flame.   A concentra-
tion of even 0.1 ppm of a hydrocarbon produces measurable ionization, which
is a function of the number of carbon ions present.  A positively charged
collector surrounds the flame, and the ion current between the flame and the
collector is measured electronically.  Pure hydrogen burning in air produces

                                     16

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          TABLE 4.  MOST COMMON PORTABLE VOC DETECTION INSTRUMENTS*
Monitor
550, 551, 555
(AID, Inc.)
OVA 108, 128
Century
Systems, Inc.
(Foxboro)
PI-101
(HNu Systems,
Inc.)
TLV Sniffer
(Bacharach)
Ecolyzer 400
(Energetics
Science)
Mi ran 1A
(Foxboro)
Detection
principle
FID
FID .
PID
Catalytic
combustion
Catalytic
combustion
IR
Range, ppm
0-200,
0-2000,
0-10,000
0-10,
0-100,
0-1000
0-20,
0-200,
0-2000
0-500,
0-5000,
0-50,000
0-100%
LFL
ppm to %
Sensitivity
0.1 ppm at
0-200 ppm
0.2 ppm (Model 128)
0.5 ppm (Model 108)
1 ppm
2.0 ppm
1% LFLb
1 ppm
Response
time, s
5
2
2
5

15
1, 4, 10
and 40
 Does not necessarily represent all portable monitors currently being sold.
 Lower flammability limit.

very little ionization, so background effects are essentially masked by the
hydrogen flame.  The calibrated output current is read on a panel  meter or
chart recorder.
     Organic compounds containing nitrogen, oxygen, or halogen atoms give a
reduced response when compared to compounds without these atoms.  The FID
hydrocarbon analyzers are usually calibrated In terms of a gas such as methane
or hexane, and the output is read In parts per million of carbon measured as
methane or hexane.
     Although nitrogen (N»), carbon monoxide (CO), carbon dioxide (C02), and
water vapor (HpO) do not produce significant interferences, condensed water
vapor can block the sample entry tube and cause erratic readings.   Also, when
oxygen (02) exceeds 4 percent, a significantly lower output reading can occur.
                                     17

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The relative response of the FID to various organic compounds, including those
with attached oxygen, chlorine, and nitrogen atoms, varies from compound to
compound.
3.1.2  Photoionization Detectors-
     In the photoionization process, ultraviolet light ionizes a molecule as
follows:  R + hv •+• R+ + e", where R  is the ionized species and hv represents
a photon with energy less than or equal to the ionization potential of the
molecule.  Generally all species with an ionization potential less than the
ionization energy of the lamp are detected.  Because the ionization poten-
tial of all major components of air (Ogj Ng, CO, COg, and H20) is greater
than the ionization energy of the lamps in general  use, they are not detected.
     The sensor consists of an argon-filled, ultraviolet (UV) light source
that emits photons.  A chamber adjacent to the sensor contains a pair of
electrodes.  When a positive potential is applied to one electrode, the field
that is created drives any ions formed by the absorption of UV light to the
collector electrode, where the current (proportional to the concentration) is
measured.
3.1.3  Nondispersive Infrared Detector
     Nondispersive infrared (NDIR) spectrometry is a technique based on the
broadband absorption characteristics of certain gases.  Infrared radiation is
typically directed through two separate absorption cells:  a reference cell
and a sample cell.  The sealed reference cell is filled with nonabsorbing gas,
such as nitrogen or argon.  The sample cell is physically identical to the
reference cell and receives a continuous stream of the gas being analyzed.
When a particular hydrocarbon is present, the IR absorption is proportional
to the molecular concentration of that gas.  The detector consists of a double
chamber separated by an impermeable diaphragm.  Radiant energy passing through
the two absorption cells heats the two portions of the detector chamber dif-
ferentially.  The pressure difference causes the diaphragm between the cells
in a capacitor to distend and vary.  This variation in capacitance, which is
proportional to the concentration of the component of gas present, is mea-
sured electronically.
                                     18

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     The NDIR instruments are usually subject to interference because other
gases  (e.g., H20 and C02) absorb at the wavelength of the gas of interest.
Efforts to eliminate the interferences by use of reference cells or optical
filters are only partially successful.  For hydrocarbon (HC) monitoring, the
detector is filled with one or several different hydrocarbons, which may be
different from the HC contained in the sample; this causes a disproportionate
response.  Other sources of errors include gas leaks in the detector and
reference cells, inaccurate zero and span gases, nonlinear response, and
electronic drift.
3.1.4  Catalytic Combustion or Hot Wire Detector
     The heat of combustion of a gas is sometimes used for quantitative
detection of that gas.  Suffering the same limitation as thermal conductivity,
this method is nonspecific, and satisfactory results depend on sampling and
measurement conditions.
     One type of thermal combustion cell uses a resistance bridge containing
arms that are heated filaments.  The combustible gas is ignited in a gas cell
upon contact with a heated filament; the resulting heat release changes the
filament resistance, which is measured and related to the gas concentration.
     Another combustion method uses catalytic heated filaments or oxidation
catalysts.  Filament temperature change or resistance is measured and related
to gas concentrations.

3.2  THERMOCOUPLES
     The temperature monitors most commonly used are direct-readout hand-held
thermocouples.  The thermocouple is composed of two wires of dissimilar metals
that are joined at one end.  When the joined end is heated, a voltage flow
can be observed (Seebeck effect).  A voltmeter is attached to the thermocouple,
and the observed voltage is proportional to the measured temperature.  A
portable thermocouple assembly consists of a shielded probe, a connecting
wire, and a voltmeter.  The voltmeter may be a temperature conversion unit on
a multimeter or a dedicated direct readout temperature unit.  The voltmeter
is battery-operated, small, and easily portable.
                                     19

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3.3  STATIC PRESSURE GAUGES
     Among the several  different available static pressure gauges,  the most
commonly used for this  type of field work are the inclined manometer and the
diaphragm gauge.   A pressure tap is necessary for use of a portable static
pressure gauge.   The pressure tap basically consists of a small  opening in
the wall of a duct, which can be fitted with a connection and a  hose to make
pressure measurements.   The tap should be far enough away from such distur-
bances as elbows  and internal obstructions to make the effects of such distur-
                  A
bances negligible.
     The appropriate side, positive or negative,  of the manometer or pressure
gauge is connected by a rubber hose at the tap, and a pressure reading can be
taken.  It is often advantageous to disconnect a  permanent pressure gauge and
take a pressure  reading at that point to compare  it with the facility's in-
strumentation.
                                     20

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                                   SECTION  4
      ESTABLISHING AN AGENCY  PROGRAM  FOR THE USE OF PORTABLE  INSTRUMENTS
                   FOR MONITORING  VOC AND AIR TOXICS SOURCES

      The portable instruments  used during  VOC and air toxics source inspec-
 tions require special  care and attention to ensure that they provide re-
 sults that are consistent with the agencies overall goal and objectives.  A
 well  developed and organized program is necessary to ensure selection of the
 proper instruments and adequate calibration procedures; the adoption of
 written measurement and recordkeeping procedures; and the taking of sufficient
 field notes during inspections.   The purpose of this section is to help a
 regulatory agency establish  a  complete program for the use of portable instru-
 ments for VOC source inspections.
      Factors to consider during the  preparation of bid specifications include
 the instrument performance requirements of the promulgated regulations and
 the practical  features that  improve  the instrument's reliability and make it
 more  convenient to use.  Detailed information is necessary concerning the type
 of laboratory and shop facilities that will be needed to support portable in-
 spection instruments.   These instruments should not be calibrated, maintained,
 and stored in an office.

 4.1  SELECTION OF THE  NECESSARY TYPES OF INSTRUMENTS
      Selection of the  types  of instruments needed for source evaluation is
 based primarily on a review  of the types of industrial facilities within the
 agency's jurisdiction  and an evaluation of the inspection requirements
 inherent in the promulgated  VOC regulations.  Agencies should also determine
 if it is possible to select  instruments that can be used for future air toxic
.control  requirements as  well as the  already existing VOC regulations.
 4.1.1  Organic Vapor Analyzers
 Detector's Response--
      One important criterion in the  selection of organic vapor detectors is
 the response of the instrument to the specific chemical or chemicals present
                                     21

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in the gas stream.  The abilities of the major classes of organic vapor
analyzers to detect different organic chemicals differ substantially.   The
response factor, defined below, provides a convenient index of this property.
     Response Factor = Actual Concentration/Instrument Observed Concentration
     A response factor of 1.0 means that the instrument readout is identical
to the actual concentration of the chemical in the gas sample.  As the
response factor increases, the instrument readout is proportionally less than
the actual concentration.  If the regulatory limit is 10,000 ppmv (observed),
the use of an instrument with a response factor of 10 for the specific chemi-
cal(s) would allow an actual concentration of 100,000 ppmv.  Conversely, the
use of an instrument with a response factor of 0.1 would indicate that the
regulatory limit of 10,000 ppmv had been exceeded when the actual concentra-
tion is only 1000 ppmv.  It is desirable to select an instrument with  response
factors as close as possible to 1.0 for the specific compounds of interest.
     Unfortunately, instrument response factors can be complex functions of
numerous variables.  The response factors depend on the chemical compound used
to calibrate the organic vapor detector and on the concentration of organic
vapor being analyzed.     Published response factors that specify the  value
based on the instrument-determined concentration are preferred in the  selec-
tion of an instrument because they are the most consistent with the regulatory
format.
     Fugitive leaks often will involve mixtures of organic vapors.  Work done
by Brown, Dubose, and Harris indicated that the response factor for a  mixture
of two organic compounds falls between the individual response factors for
the compounds.   This would suggest that the instrument offers no synergistic
phenomenon and that weighted average response factors could be used to approxi-
mate instrument response to a mixture.
     Representatives of instrument manufacturing companies contacted as part
of this study generally believe that the response factors published by EPA
and by their companies are sufficiently accurate.  *'    Slight differences,
however, do exist between response factors determined by EPA and those reported
by instrument manufacturers.  These differences could be due to differences
in the calibration procedures, the specific instrument model used in the work,
or the specific instrument itself.  Many instrument manufacturers, however,

                                      22

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believe that instrument-to-instrument variability in the response factors is
slight and that the values remain relatively stable over the life of the
instrument.19'21'39'40  Neither the EPA nor the instrument manufacturing
companies, however, have specifically studied instrument-to-instrument
variability or long-term response factor stability.  One consulting firm has
recommended that users routinely redetermine the response factors rather than
                            0 A
relying on published values.    There are some who believe that routine re-
determination of instrument-specific response factors by regulatory agencies
is unnecessary in most cases.  The most recent response factor data published
by both EPA and the instrument manufacturers should be consulted before in-
struments are purchased.  The response factor data compiled in Appendix B
should assist regulatory agencies in their evaluation of the general capa-
bilities of different styles of instruments.  These data include a partial
listing of the response factors determined for the Foxboro OVA-108 and the
Bacharach TLV Sniffers. *   Limited response factor information concerning
photoionization analyzers and one infrared analyzer has been abstracted from
              8 9
other sources.
     A review of the response factor data shown in Appendix B indicates that
a substantial difference exists among the four major categories of VOC in-
struments.  The instruments capable of monitoring high concentrations of hydro-
carbon compounds, which make up many of the VOC emissions, are not as useful
for measuring some of the oxygenated and chlorinated organic compounds, which
represent many of the air toxic emissions.  Thus, it may be impossible to re-
concile the needs of both the VOC and air toxics inspection programs by the
selection of a single type of instrument.
     Because response factor data are currently very limited, agencies may
wish to use additional data in selecting organic vapor analyzers.  In the
case of photoionization units, the ionization potentials of organic compounds
provide a qualitative index of the instrument's capability to detect the com-
pound.  A summary of ionization potential data provided by an instrument manu-
facturer   is provided in Appendix C.  In reviewing these data, the agency
should note that an instrument often can detect compounds with ionization
potentials slightly above the rating of the lamp.  For example, a compound
with an ionization potential of 10.5 eV could possibly be monitored with an
                                      23

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instrument having a 10.0 eV lamp.    Although the lamp's rating is based on
the wavelength of the most intense emission line, there are often less in-
tense emission lines at shorter wavelengths.
Range and Accuracy—
     The ability of an instrument to measure  10,000 ppmv should be carefully
considered if the instrument will be used to  determine compliance with EPA
Method 21 regulations.  As indicated in Table 4,  only a few of the currently
available units can operate at 10,000 ppmv or above.   Other units can operate
at this concentration only by using dilution  probes.   Although dilution
probes can be used accurately, they can also  be a large source of error.
Both changes in flow rate through the dilution probe and saturation of the
charcoal tubes used to remove organic vapors  from the dilution air can lead
to large errors in the indicated organic vapor concentration.   Dilution
probes also complicate calibration and field  span checks.   For these reasons,
they should be avoided whenever possible.
     Generally, the .instruments should have the desired accuracy at the con-
centration of interest.  It should be noted that an accuracy of +5 percent
is required for Method 21 work.
Ease-of-Use—
     Ease of use is an important instrument selection criterion because of
the,conditions under which the field inspector must work.   The instrument
must be as light as possible because the inspector must walk over relatively
large areas (in most facilities) to evaluate  fugitive leaks from numerous
valves and other sources.  In some cases, a moderate amount of climbing' is also
necessary.  After 4 to 6 hours, even a light instrument can seem uncomfortably
cumbersome.
     Table 5 contains information concerning  the portability of some of the
commercially available organic vapor instruments.  As shown, the weights of
the units and the manner in which they are used differ substantially.
     Generally, instruments equipped with shoulder straps are the most con-
venient to use for fugitive VOC leak surveys.    The instrument readout on
the hand-held probe is very important, because the inspector immediately sees
when the probe has been placed in a very high VOC concentration.  The hand-
held gauge also slightly reduces the time involved in leak surveys.

                                     24

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              TABLE 5.  EASE-OF-USE OF ORGANIC VAPOR ANALYZERS
Instrument
manufacturer
Century (Foxboro)
108
Century (Foxboro)
128
Photovac 10S50
HNU PI-101
AID Model 585
AID Model 712
Barachach TLV
Ecolyzer 400
Mi ran 1A
Type
FID
FID
PID
PID
PID
FID
Cata-
lytic
Cata-
lytic
Infra-
red
Weight,
Ibs
13
13
26
9
8
14
5.5
8
12.5
Mode of use
Shoulder strap
Shoulder strap
Case with handle
Shoulder strap
Small case with
handle
Shoulder strap
Shoulder strap
Shoulder strap
Carrying handle
Other comments
Readout on probe
Readout on probe
Necessary to remove
cover to adjust range
Necessary to open case
at each measurement
site


Readout on probe


Necessary to set unit
down at each measure-
ment site
Intrinsic Safety-
     All instruments used during field inspections of VOC source and air toxic
sources must be intrinsically safe if they are to be used in potentially
explosive atmospheres.  Localized pockets of gas (and even particulates)
within the explosive range can result from fugitive leaks and malfunctioning
control devices.  Intrinsic safety simply means that the instrument will not
provide a source of ignition for the explosive materials when the instrument
is used properly.  Instrument designs are certified as intrinsically safe for
certain types of atmospheres by organizations such as the Factory Mutual Research
Corporation.  Table 6 lists the types of atmospheres by safety classification.
The conditions can be further classified according to Groups A through G,
                                     25

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TABLE 6.  DEFINITIONS OF HAZARDOUS LOCATIONS IN ACCORDANCE WITH THE NATIONAL
                              ELECTRICAL CODE3
  Classification
                     Description
 Class  I  locations


 Division  1


 Division  2



 Class  II  locations

 Division  1



 Division  2



 Class  III locations


 Division  1


 Division 2
Areas where volatile flammable liquids and flammable
gases are used and handled.

Class I areas where hazardous concentrations are
likely to occur in the course of normal operations.

Class I areas where hazardous concentrations are
probable only in the case of accidents or unusual
operating conditions.

Areas where combustible dust may be present.

Class II areas where combustible dust is likely to
be present in explosive or ignitable concentrations
in the course of normal operations.

Class II areas where hazardous concentrations of
combustible dust is probable only in the case of
accidents or unusual operating conditions.

Areas where easily ignited fibers and materials that
could result in combustible flyings are present.

Class III areas where easily ignited fibers and
materials are processed.

Class III areas where easily ignited fibers and
materials are stored or handled.
 Sources:  References 12 and 13.


which denote the type of flammable vapor or combustible dust that may be
present.

     The large majority of the organic vapor analyzers are designed to be
instrinsically safe in Class 1 areas.  Factory Mutual, however, has certified

only a few of the currently available commercial instruments to be intrinsically

safe.  Table 7 lists the present status of commercial instruments.
     It should be noted that the information presented in Table 7 could change

in the near future.  At least one manufacturer has several applications pend-
                                           14
ing concerning, hazardous location approval.
                                     26

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 TABLE 7.   INTRINSIC SAFETY RATINGS OF COMMERCIAL INSTRUMENTS, JANUARY 1986°
Instrument
manufacturer
Foxboro
Foxboro
Bacharach
AID, Inc.
AID, Inc.
HNU Systems, Inc.
Model
OVA- 108
OVA- 128
TLVb
585
712
PI-101
Atmosphere
Class I,
Class I,
Class I,
Class I,
Class I,
Class I,
Division 1
Division 1
Division 1 and 2
Division 2
Division 1
Division 2
Factory mutual
approved
Yes
Yes
Yes
No
No
No
 Not a complete listing of commercial instruments.
bModel 0023-7356.

Other Considerations--
     Several recent improvements have been made in probe design.   As a result,
agencies should carefully evaluate the probes available with the  organic vapor
analyzer models they are considering.  By reviewing detailed drawings or
examining "leaner" probes, agencies can determine if the probe is susceptible
to leakage.  Air infiltration through the probe has been a common problem in
the past.  '  '  '    This problem has been especially severe on  telescoping-
type extension probes.
     Some older flame ionization analyzers have suffered hydrogen leaks due
to cold creep of the TEFLON washers used to seal part of the pressurized
              18 19
hydrogen line.       The hydrogen leak ignition problems reported in earlier
studies,   however, may have been solved by redesigning the hydrogen line
         19
fittings.    Agencies should examine the hydrogen line design on  any FID that
is being seriously considered for purchase to ensure that this will not be a
problem.
4.1.2  Thermocouples
     It should be noted that currently none of the battery-powered thermo-
couples are designed as intrinsically safe for either Class I or  Class II
atmospheres.   Therefore, these instruments cannot be taken into or through
                                     27

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areas where there is a possibility of encountering explosive mixtures of
organic vapor and/or dust.  Conventional flashlights are also not intrinsically
safe, and they should be replaced by explosion-proof flashlights.

4.2  INSTRUMENT SPARE PARTS AND ACCESSORIES
     Portable instruments for inspection of VOC sources and air toxic sources
are sophisticated units.  Maintaining an available supply of certain accessory
spare parts and routine replacement parts will  minimize unnecessary downtime
of these instruments and will help field inspectors to obtain high quality
data.
4.2.1  Battery Packs
     All of the organic vapor analyzers require a rechargable battery pack
to operate the sample pump and the electrical components.  Failure of these
battery packs is a common problems with these instruments.  '*    A re-
placement battery pack should be taken along on all field inspections in case
an unexpected failure should occur.  A spare is also useful when field work
is being conducted during cold conditions, as such conditions reduce the
                      19
useful operating time.
     A spare recharger is also necessary for the lead-acid gel battery packs
used in some types of flame ionization analyzers, as these batteries must be
recharged on an almost continuous basis to prevent loss of the charge.  If a
deep discharge occurs, the battery pack cannot be recharged by the unit sup-
                          no
plied with the instrument.    Thus, two rechargers are needed, one for the
original instrument battery pack and one for the backup battery pack.
     Spare rechargers are also recommended for the nickel-cadmium (Ni-Cd)
battery packs commonly used in the photoionization instruments.  Recent improve-
ments in battery rechargers have significantly reduced the possibility of
                   20
battery overcharge.    Only these newer style units should be used if the
instrument has the Ni-Cd batteries.
     A nonrechargable 9-volt battery similar to those used in radios, is
normally used in a thermocouple.  As a result, a spare is recommended.
                                     28

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4.2.2  Detectors
     The photoionization analyzers and the catalytic combustion analyzers have
detectors that must be replaced after extended use.   The inspectors should
                                                                            17 21
take replacement detectors with them on field trips  in case they are needed.   '
     For photoionization units, the key component is the ionization lamp
within the detector.  Inspectors should take at least one spare lamp on all
field work in the event that one of the following may occur:  the lamp is
damaged by the deposition of nonvolatile components  on the lamp window, the
window is scratched during cleaning, the lamp is damaged by physical shock,
or the lamp simply wears out.
     The detectors of catalytic combustion analyzers are composed of a coated
hot wire that is part of a Wheatstone bridge.  Exposure to high concentra-
tions of organic vapor can cause excessive volatilization of the catalyst
                      21
from the wire surface.    The sensor also can be damaged by the deposition of
nonvolatile, noncombustibTe material.  For these reasons, at least two re-
placement sensors should be taken on field Inspections.
4.2.3  Particulate Filters
     All organic vapor analyzers are subject to damage by the deposition of
nonvolatile materials in the instrument probes and/or the instrument detectors.
Most commercially available units include some form of particulate filters
within the probes to collect this material.  Several replacement filters should
be taken along with the instruments because the filters are easily blinded.
     Most experienced instrument operators consider it prudent to use a glass
wool  "Prefilter" in addition to the instrument filters to reduce further the
chances of particulate deposition inside the instruments.  *  f    A small
section of plastic tubing with some glass wool is recommended for all organic
vapor analyzers.  Care must be taken, however, to ensure that the filter does
not add excessive sample flow resistance.

4.3  LABORATORY AND SHOP SUPPORT FACILITIES
     Because of their level of sophistication, organic vapor analyzers require
laboratory and instrument shop support facilities.  Regulatory agency in-
spectors should not attempt to store and calibrate the instruments in their
                                     29

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offices, as this practice can lead to significant safety problems and com-
plicate the routine maintenance of the instruments.
4.3.1  Storage of Compressed Gases
     One of the primary purposes of the laboratory facility is to provide a
safe location for storage of the gas cylinders used to calibrate the organic
vapor analyzers.  These facilities are able to secure the cylinders firmly so
they cannot be knocked over accidently.  Accidents involving even small  gas
cylinders in offices could have very serious consequences.   Furthermore
laboratories can and should store the cylinders in areas that are properly
ventilated with exhaust hoods.  Conversely, leaks of compressed gas in offices
can lead to localized high concentrations of gases such as  hexane, benzene,
butadiene, and vinyl chloride, or even to localized pockets of explosive gas
mixtures.  For these reasons, it is very important to store and use the  cali-
bration cylinders, zero gas cylinders, and hydrogen cylinders (for flame
ionization analyzers) in properly designed laboratory facilities.
     Another important consideration is that the exhaust from organic vapor
analyzers during calibration can be toxic.  In the case of the photo-ionization
analyzers, most of the inlet calibration gas is exhausted because the instru-
ments are nondestructive.  In the case of flame ionization detectors, however,
low concentrations of phosgene and hydrogen chloride can be emitted when
                                                  22
chlorinated hydrocarbons are used for calibration.    Thus, the instrument
should be placed in a location where the exhaust is captured by an approved
hood and ventilation system.
4.3.2  Gas Flow Evaluation
     Many of the organic vapor analyzers, especially the flame ionization
detectors, are sensitive to the sample gas flow rate.  Routine confirmation
of proper flow rate is important, especially for those instruments that do not
include a flow sensor.  Flow rates are normally measured by use of a rotameter
designed for flow rates between 0.5 and 5.0 liters per minute.  The rotameter
should be calibrated against a soap bubble flow meter.
4.3.3  Electrical Diagnostic Equipment
     The extent to which malfunctioning organic vapor analyzers can be ser-
viced by agency personnel is limited because the intrinsic safety of the

                                     30

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 instrument can be voided inadvertently.  Nevertheless, qualified agency in-
 strument technicians should be equipped to check such basic operating param-
 eters as the lamp voltages of photoionization units and the battery output
 voltages on all portable instruments.
 4.3.4  Thermocouple Calibration Equipment
     The thermocopule readout device and thermocouple probes should be cali-
 brated at least twice a year.  For convenience, the calibrations should be
 performed in-house with a conventional tube furnace.  The field instrument
 and probes are compared against National Bureau of Standards (NBS) traceable
 thermocouple probes.
 4.3.5  Static Pressure Calibration Equipment
     All diaphragm-type static pressure gauges must be calibrated on at least
 a weekly basis.  A relatively large U-tube manometer should be permanently
 mounted in the agency laboratory for calibration of 0 to 10 inch U.C. and the
                         23
 0 to 60 inch W.C. gauges.    An inclined manometer is needed for calibration
 of the 0 to 2 inch U.C. gauges.
 4.3.6  Storage Space
     Adequate space should be provided to store the instruments, the riecessary
 spare parts, and the routine calibration/maintenance records.  The availa-
                                 i           i
 bility of convenient storage space removes the temptation to store the instru-
ments in the trunk of a car, where they could be damaged by excessive vibra-
 tion and shock or by excessive heat.  A checklist should be posted near the
 stored units listing the spare parts that should be taken to jobsites to
ensure adequate instrument performance during the inspection.
     Adequate working area should be provided for the inspectors to calibrate
and check-out the instruments before leaving for the field.  The working area
must be large enough to accommodate a 20 to 30 liter TEDLAR bag, the instru-
ment, the gas cylinders, and any gas-blending equipment that may be necessary.

4.4  INSTRUMENT MAINTENANCE PROGRAM AND RECORDS
     In most regulatory agencies, numerous individuals will use the portable
organic vapor analyzers, thermometers, and static pressure gauges, and it is
                                     31

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unrealistic to expect all of them to be fully knowledgeable concerning instru-
ment calibration and repair.  It is also unrealistic to ask each of them to
make independent determinations of organic vapor analyzer response factors or
other performance data obtained on an infrequent basis.  Therefore, one or
two people should be assigned the responsibility for the overall maintenance
of the instruments.  Persons skilled in instrument calibration and/or repair
are ideal for this assignment.  They can make whatever nonroutine tests and
measurements are necessary to ensure that the monitors continue to perform
adequately.  They can also instruct other agency personnel concerning the
proper way to replace filters, detectors, and battery packs, to operate the
unit; and to perform field span checks.
     Only those persons assigned responsibility for the instruments should
make any routine repairs other than the replacement of detectors, photoioni-
zation lamps, battery packs and particulate filters, which can be replaced by
the inspector and the replacements noted in a log or report provided to the
person who has been assigned responsibility for the unit.  This reduces the
chance of the intrinsic safety of an instrument being inadvertently bypassed
by an unqualified individual.  The instruments should be returned to the
manufacturers for any nonroutine repairs.
     Records should be maintained on eatf instrument including all routine
calibrations, any response factor determinations, and all repair notes.
Problems reported by field personnel should be briefly summarized in a chrono-
logical record.  The file should contain at least one copy of each operating
manual and a list of all part numbers (if not included in the manual).

4.5  COSTS
4.5.1  Instruments and Accessories
     Cost data for various organic vapor analyzers and other instruments have
been compiled to illustrate the capital and operating costs.  These data are
presented simply to help regulatory agencies prepare realistic budgets.  They
should not be used for comparison of different instruments, as each instrument
has different applications and capabilities.
     The cost data are based on verbal quotes and published price lists pre-
pared by instrument manufacturers.  The data were obtained in December 1985

                                      32

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and were confirmed in January 1986.  Cost data presented in earlier re-
ports24'25'^6 are generally out-of-date.  All of the price information presented
in this section should be confirmed because price increases are expected in
the near future.
     Also included are the costs of various accessories believed to be helpful
in ensuring high-quality field data and acceptable instrument availability.
Organic vapor analyzers require numerous accessories and spare parts and the
cost of these should be included in the original budgets.
     The yearly operating cost estimates presented herein are based on the
use of the instrument for 50 days a year, 6 hours a day.  It has been assumed
that laboratory calibration will be performed before any field work begins
and that field span checks will be performed at least twice a day.   Costs
of calibration gases for the field span checks are based on the disposable-
type cylinders offered by several different suppliers.
     The cost of the HNU PI-101, the Foxboro OVA 108, and the Bacharach TLV
Sniffers are presented in Tables 8, 9, and 10, respectively.  The specified
costs apply to the intrinsically safe model, which is the only type that
regulatory agencies should use.  The tables represent the kind of informa-
tion that should be compiled regardless of which type of instrument or model
is being considered.
     The relatively large fraction of the basic analyzer cost represented by
the accessories reflects the high cost of spare battery packs and rechargers
needed because of the vulnerability of intrinsically safe battery packs when
not cared for properly.  When a battery pack fails, getting a replacement
could take anywhere from 1 week to several months; therefore, having spare
battery packs and chargers is a necessary expense.
     Another major component that drives the accessory costs up is the
detector cells.  The detector in each of the instruments has one or more
sensitive components.  Exposure to high temperature, moisture, particulates,
or very high organic vapor concentrations can cause premature failure.
Regulatory agencies that use these instruments for a variety of purposes
ranging from leak surveys to roof monitor emission surveys are likely to
damage the detectors occasionally regardless of how carefully the inspectors
conduct the field work.
                                     33

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   TABLE 8.   ESTIMATED COSTS OF HNU MODEL PI-101 PHOTOIONIZATION ANALYZER
           Equipment and supplies
   Cost.
Analyzer, Model 81-IS-101-100  (intrinsically
   safe), with corrosion-resistant detector
   chamber
Accessories
     Spare 10.2 eV lamp
     Span gas cylinder regulator
     Instrument carrying case
     Spare battery pack
     Spare recharger
     Spare probe extension
     Spare fan
                                                       Subtotal
    5245

     300
      99
     250
     200
     360
      30
     240
    1479
Expendable supplies
     Calibration gas cylinder (3 cylinders
       per year minimum)
     Particulate filters
     Cleaning compound ($24 per unit,
       1 unit required)
     Replacement lamp
     Yearly factory service
Cost/year. $

     150
      20

      25
     300
                                                       Subtotal
     300'
     795
aAll cost data provided by HNU Systems, Inc.27'28
 Necessary accessories and supplies specified by Richards Engineering.
°Does not include $40 shipping charges.
                                     34

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      TABLE 9.  ESTIMATED COSTS FOR FOXBORO MODEL 108 FID TYPE ORGANIC
                               VAPOR ANALYZER3
           Equipment and supplies
          Cost, S
Analyzer, with GC option
Accessories
     Spare battery pack
     Spare recharger
     Spare probe
     Recorder (intrinsically safe)
     Ignitors
     Pump valves (package of 10)
     Pump diaphragm
     Mixer/burner assemblies
     Washers, TEFLON (package of 12)
     Washers, brass (package of 12)
     Calibration kit regulator and case
           5200
            460
            427
             40
            460
             32
             15
             20
            200
             18
             15
             90
Subtotal   1777
Service and supplies
     Yearly factory service
     Chart paper ($60/6 rolls, 6 rolls/year)
     Flame arrestors (package of 10)
     Calibration gas for field span checks
       (4 at $63)
     Factor determinations (2 cylinders at $82 each)
     Hydrogen gas (< 0.5 ppm HC)
                                                              Cost/year, $
            no1
             60
              9

            252
            164
             60
                                                       Subtotal
            736
A
 Instrument related cost-data provided by Foxboro.    Calibration gas and
 hydrogen gas cost data.30'31'^
 Necessary accessories and supplies specified by Richards Engineering.
GDoes not include $40 shipping charges.
                                     35

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            TABLE 10.  ESTIMATED COSTS FOR BACHARACH TLV SNIFFER
          Equipment and supplies
          Cost, S
Analyzer, Model 53-7-TLV
Accessories
     In-line filter and water trap assembly
     Battery charger
     Spare battery pack
     Spare detector cell
     Calibration kit (regulator, case and 2
       cylinders)
                                                       Subtotal
           1580

             62
             56
            392
            115

            212
            837
Service and supplies
     Factory servicing
     Calibration gas for field span checks
       (4 at $63)
     Calibration gases for office calibrations
       and response factor checks (2 cylinders
       at $73)
     Replacement detector
       Cost/year, S

            100C

            252

            146
            115
Subtotal    613
alnstrument related cost data provided by Bacharach, Inc.    Calibration
 gas data.30»31»32
 Necessary accessories and supplies specified by Richards Engineering.
GDoes not include $40 shipping charges.
                                     36

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         TABLE 11.  ESTIMATED COSTS FOR OMEGA PORTABLE THERMOMETER*
          Equipment and supplies
   Cost, S
Analyzer, Model 871
Accessories
     Beaded probes, 6 feet (2 probes)
     Carrying case
                                                       Subtotal
     225.00
      51.20
      10.00
      61.20
Service and supplies
     Replacement batteries (5 at $3 each)
     Calibration (semiannual at $50 each)
Cost/year, S


      15.00
     100.00
                                                       Subtotal
     115.00
aCost data provided by Omega Engineering, Inc.
 Necessary accessories and supplies specified by Richards Engineering.

     The yearly operating cost of each instrument includes a fee for factory
service.  This is considered a desirable precaution because the instruments
are used for compliance determination and because only limited repair/adjust-
ment of intrinsically safe instruments should be attempted by agency personnel.
     One of the main yearly operating costs is for calibration gases (certified
to plus or minus 2%) shipped in disposable cylinders.  Assuming each field
span check requires 1 to 2 minutes and the instrument draws 2 liters per
minute, the average disposable cylinder will be adequate for only 10 to 20
measurements (assuming 40 liters of compressed gas).  At a rate of approxi-
mately $70 per replacement cylinder  ''   each span check would cost be-
tween $3.50 and $7.00.  Although that is not a high price to ensure high-
quality data, some agencies may wish to investigate less expensive alternatives.
One alternative is a gas-transfer system.  With this approach, calibration
gas would be supplied by the same large cylinder used for the laboratory
                                     37

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calibrations and be transported by means of a standard sampling cylinder.
The total cost of the components of the sample cylinder system would be S300
to $500.30'35  This includes a 1-liter, high-pressure, stainless steel sam-
pling cylinder with needle valves, a 10-liter TEDLAR bag, a carrying case,
and a regulator.  The uncertainty in the cost estimate is due to the lack of
available cost data concerning regulators to transfer gas from a large cylinder
to a sample cylinder.  With the sample cylinder approach, the cost of the
calibration gas itself is essentially negligible because sufficient gas would
be available from the main laboratory cylinder, which should be purchased
once a year.  Whereas the initial cost is moderately high, the yearly cost
is quite low because the cost of disposable cylinders is eliminated.  Another
advantage is that the sampling cylinder would only have to be pressurized to
approximately 325 psig to provide adequate gas for two span checks per day.
This is lower than the 1000 psig used in some types of disposable cylinders.
Additional work is necessary to determine if the transfer approach is a safe
and economical alternative to the use of disposable cylinders.
     The costs of the thermocouple thermometer, shown in Table 11, include
the cost of semiannual recalibration against NBS-traceable thermocouples.
Although this is a relatively simple procedure, it is assumed that regulatory
agencies will not be equipped to perform this calibration.  Therefore, the
cost for outside calibration has been listed.  ,
     The cost of static.pressure gauges ranges from $25 to $50 apiece, de-
pending on the range of the unit and the manufacturer.  Although no
accessories or supplies are generally necessary to maintain these instruments,
some attrition of the units can be expected if they are treated especially
roughly.
4.5.2  General Equipment
     Certain basic equipment is necessary to support the instruments used for
inspections of VOC and air toxics sources.  The cost for this equipment is
presented in Table 12.  All of the equipment is used and stored in an instru-
ment laboratory or an instrument shop.  The general laboratory equipment is
used primarily for calibration of the organic vapor analyzers and for the
routine determination of instrument-specific response factors.
                                     38

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                     TABLE 12.   GENERAL EQUIPMENT COSTS
Item
20-liter TEDLAR bags
Bag evacuation pump
Cylinder gas regulators
Rotameters, stainless steel
with needle valve and
baseplate
Soap bubble flow meter
Cylinder brackets
TOTAL
Quantity
2
1
2
2
1
2

Cost/unit,
S
22
250
198
123
80
27

Total cost,
S
44
250
396
246
80
54
1070
Reference
35
35
30
36

30

4.6  PREPARING BID SPECIFICATIONS
     Each type of organic vapor analyzer and thermometer is  produced  by
several different manufacturers.  Many of the instrument models  offered  by  the
manufacturers come with different options that are tailored  to certain appli-
cations.  Because of the diversity of commercially available instruments,  the
bid specifications must be prepared carefully.
     An instrument that is to be used for VOC leak surveys must  meet  the EPA
Reference Method 21 specifications summarized earlier in Section 3 and
presented in Appendix A.  An important performance criterion specified is
that the readability of the meter scale must be to plus or minus 5 percent of
the leak definition concentration, which is 10,000 ppmv in certain industries.
To reach this concentration, some instruments must include a dilution assembly.
Another important criterion is that the instrument be intrinsically safe for
Class I, Division 1 and 2 environments.  If a recorder is specified,  it  also
should be intrinsically safe (some are not).
     The specific organic chemicals that will be monitored should be  identified
before bids are solicited.  Instruments have considerably different capabili-
ties, and only .-those with reasonable response factors for the specific chemi-
cals of interest should be used.
                                     39

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     The list of accessories and spare parts should be used along with infor-
mation supplied by the manufacturers on spare parts to determine those that
are necessary.  Including these items on the bid list will  facilitate a more
complete evaluation of the total cost of the different instruments.
                                     40

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                                  SECTION 5
                    INSTRUMENT CALIBRATION AND EVALUATION

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

5.1   INSTRUMENT CALIBRATION REQUIREMENTS AND PROCEDURES
5.1.1  VOC Analyzers
Calibration Procedures--
     Calibration requirements for VOC instrumentation are specified in EPA
Method 21 and in the specific NSPS applicable to sources of fugitive VOC emis-
sions.  The requirements pertaining to calibration are briefly summarized
here, and the complete Method 21 regulations are presented in Appendix A.
     o    The instruments should be calibrated daily.
     o    The gas concentration used for calibration should be close to the
          leak definition concentration.
     o    The callbrant gas should be either methane or hexane.
     o    A calibration precision test should be conducted every month.
   •  o    If gas blending is used to prepare gas standards, it should
          provide a known concentration with an accuracy of ^ 2 percent.
     The daily calibration requirement specified in Method 21 and in the vari-
ous NSPS gives individual instrument operators some flexibility.  The calibra-
tion could consist of a multipoint calibration in the lab, or it could be a
single-point "span check."
                                     41

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     Neither Method 21 nor the applicable  NSPS  specifies  where  the  calibration
takes place.  Obviously it would be simpler to  conduct the  calibration test in
the agency laboratory rather than after arrival  at the plant  being  inspected;
however, the calibration could conceivably shift sufficiently to affect the
accuracy of the leak detection measurements.  The degree  of possible shift has
not been documented for the various commercially available  instruments.
Although a survey of several major instrument manufacturers indicated that most
believe that the units are "calibration stable,"19'21'38'39 no  distinct study
has been conducted to demonstrate confidence in the calibration after the
instrument has been subjected to vibration during transit.  Because of the
suspected potential for calibration shifts in all of the  organic vapor analyzer
types, one should consider conducting at least  a single-point span  check after
the instrument arrives onsite.  This concern is shared by several consul-
tants,  '   an EPA engineer involved in the development of Method 21   and by
                                                      19  38 40
a number of instrument manufacturers' representatives. '»""»  v   Chehaske has
recommended that a span test be run at a midpoint of the  day  and at the con-
clusion of the field work.
     Although the span checks discussed above would in most cases qualify  as
the daily calibrations required by the NSPS; a  separate calibration test for
organic vapor analyzers should be conducted whenever possible.   Calibrations
performed in the regulatory agency laboratory as compared to  calibrations  that
        •  *   i   •    ,  i
are conducted in the field are conducted under more controlled conditions
because uniform day-to-day calibration gas temperatures and calibration gas
flow rates can be maintained in the laboratory.    Furthermore, the initial
calibration test provides an excellent opportunity to confirm that  the entire
instrument system is working properly before it is taken  into the field.  The
laboratory calibration data should be carefully recorded  in the instrument
calibration/maintenance notebook discussed in Section 4,  and  this calibration
should be considered as the official calibration required by  the regulations.
     The laboratory calibration is best performed by the  personnel  assigned
primary responsibility for the maintenance and  testing of all the agency
organic vapor analyzers.  This ensures the use  of proper and  consistent pro-
cedures.  If instrument problems are identified, the instrument can either be
repaired or the field inspector can be issued another unit that is  operating
properly.

                                      42

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Laboratory Calibrations--
     As specified in the EPA-promulgated NSPS,  the instruments  used in  accord-
ance with Method 21 must be calibrated by using either methane  or hexane at
concentrations that are close to the leak-detection limits.   In most cases,
the leak-detection limit is 10,000 ppmv, however,  for certain sources,  it is
500 ppmv above the background levels.
     Methane-in-air is generally the preferred  calibrant gas for the high
concentration range.41  A hexane-in-air concentration of 10,000 ppmv should
not be prepared because it is too close to the  lower explosive  limit.   Also,
some hexane can condense on the calibration bag surfaces at  this high  concen-
tration.    If hexane-in-air calibrations are necessary, the chosen concentra-
tion should be a compromise between the need for adequate calibration  of leak-
detection levels and the practical safety and reproducibility problems  inherent
in the use of hexane.  The EPA has taken the position that the  choice  of cali-
brant gas does not affect the ability of instruments to detect  fugitive leaks.
     Some VOC instruments, such as photoionization and infrared instruments,
do not respond to methane (Section 3).  With these units, a  different  cali-
bration gas should be used.  If the inspection  is  concerned  primarily  with
one specific organic compound (e.g., hexane), that compound  can be used for
calibration.  In other cases, a calibration gas that adequately represents the
expected mixture of organic compounds that could be leaking  from the source
should be used.  The calibration gases recommended by the instrument manufac-
turers are shown in Table 13 as a general guide to inspectors.
41
   TABLE 13.  RECOMMENDED CALIBRATION GASES FOR ROUTINE INSTRUMENT SERVICE
Type of
instrument
FID
FID
PID
Catalytic
combustion
Manufacturer
Foxboro
HNU Systems, Inc.
AID Inc.
Bacharach
Calibration
gas
Methane
Benzene
Benzene
Hexane
Reference
19
20
38
43
                                      43

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     The calibration procedures for each instrument model  are specified in the
instruction manuals.  Material  presented in this section is intended to
emphasize the importance of certain calibration procedures discussed in these
various instruction manuals.
     Regardless of the type of VOC instrument,  the flow rate of the gas during
calibration should be approximately equal to the flow rate during normal  use
                                                                      24
of the instrument, as flow rate influences the  measured concentration.
Proper flow rate is very important for the FID  instruments.
    The two main calibration techniques that can be used are 1) commercially
prepared calibration gas mixtures or 2) blended calibration gas mixtures.   The
commercially prepared calibration'mixtures are  more convenient, but they are
slightly more expensive than the calibration mixtures blended onsite.   When
commercially prepared mixtures are used, a large cylinder containing a  certi-
fied concentration of calibration gas (balance  of gas mixture is air)  is  used
to fill a TEDLAR bag.  The instrument simply withdraws a gas sample from the
bag at a rate of 0.5 to 3.0 liters a minute, depending on the normal sampling
rate.  The estimated time required for the calibration is shown in Table 14.

                TABLE 14.  CALIBRATION TIME REQUIREMENTS WHEN
                USING COMMERCIALLY PREPARED CALIBRATION GASES
               Activity
Time required,.
    mi nutes
     Set up instrument
     Instrument warmup and calibration assembly setup
     Flush sample bags
     Fill bags with calibration gas and with zero air
     Reset instrument
     Record results in notebook or on logsheet
          Total
        2
       10
        5
        2
        5
       _2
       26
     Obtaining the desired calibration gas mixture in commercially prepared
cylinders is sometimes impractical.  In such cases, the mixture can be pre-
pared by blending the calibration compound with hydrocarbon-free air in a
large TEDLAR or TEFLON bag.  This is a much more time-consuming procedure.

                                      44

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                                                                            o
 For example, the specific steps in the procedures used by Menzies and Fasano
 are as follows:
     1.   Flush and evacuate bag three times with hydrocarbon-free air.
     2.   Fill bag with hydrocarbon-free air.
     3.   Inject a known volume of test compound into the bag.
     4.   Permit at least 1 hour of equilibration to ensure adequate evapora-
          tion (if sample is liquid) and mixing.
     5.   Draw gas sample from the bag.
 Menzies and Fasano prepared the hydrocarbon-free air by passing compressed air
 through silica gel (for air drying), charcoal, and a high efficiency filter.
 As long as the charcoal bed is not saturated with water and/or organic vapor,
 it should adequately remove organic vapor.  Charcoal beds do not remove
 methane, however.  Menzies and Fasano metered the hydrocarbon-free air into
 the bag by using a rotameter.  Presumably, they used precision rotameters or
 other accurate gas flow monitors to achieve a known concentration within the
 required accuracy of +_ 2 percent.  They injected the calibration compound (a
 liquid in their work) into the bag with a microliter syringe.
     Calibration time requirements can be high.  Menzies and Fasano recommended
 an equilibration time of 1 hour to inject the liquid into the gas.  Even when
 a calibration gas is introduced into a bag, the equilibration time should be
 between 15 and 30 minutes.  Additional time is required to flush the bags
 several times with VOC-free air.  Time requirements for a bag sample calibra-
 tion are summarized in Table 15.
     Because of the lengthy calibration time required by this approach, it
would be especially helpful to have an instrument specialist conduct the pro-
cedure.  This person could calibrate several instruments simultaneously, as
much of the time is spent in 1) waiting for the instrument to warmup, 2) wait-
 ing for the bag evacuation pump to empty the TEDLAR bag, and 3) waiting for
the gas sample to equilibrate in the bag.
     When charcoal beds are used to provide the VOC-free air, a routine check
                                                              24
should be made to determine breakthrough of organic compounds.    This is done
by passing a low-hydrocarbon-concentration gas stream (approximately 10 to  50
ppmv) through the bed for a period of 5 to 10 minutes.  If the bed has not

                                      45

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          TABLE 15.  CALIBRATION TIME REQUIREMENTS WHEN CALIBRATION
                          GAS MIXTURES ARE BLENDED
               Activity
Time required,
    minutes
     Setup instrument
     Instrument wartnup and calibration assembly setup
     Empty and flush bags
     Inject calibration compound and equilibrate
     Set calibration and zero
     Record results in notebook or on logsheet
          Total
        2
       15
       10
    30 to 60
        5
        2
    75 to 105
become saturated, the outlet hydrocarbon concentration should be low.   Obvious-
ly, methane should not be used as the hydrocarbon because charcoal  is  ineffec-
tive in adsorbing methane.
Field Span Check Procedures—
    The following are some' of the various ways to calibrate the portable
instrument onsite:
     o    Use large pressurized gas cylinders transported to inspection sites.
     o    Use certified gas cylinders provided by the source being inspected.
     o    Use disposable gas cylinders with the appropriate gas composition
          and concentration.
     o    Use a gas sampling cylinder with a gas blending system.
     Transporting large pressurized gas cylinders is generally impracticable
because most agencies do not have the vehicles necessary for this purpose.
It is not safe to transport unsecured, pressurized gas cylinders in personal
or State-owned cars.  Furthermore, there are specific Department of Transpor-
tation (DOT) regulatons governing the shipping of compressed gases.
     Using the source's gas cylinders is certainly the least expensive approach
for a regulatory agency; however, the appropriate gas cylinders are not always
available.  Also, the use of the source's cylinders prevents the agency from
                                      46

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making a completely independent assessment of the VOC fugitive leaks and from
evaluating the adequacy of the plant's leak-detection program.
     Using disposable cylinders of certified calibration gas mixtures is rela-
tively simple because no onsite blending is necessary and the cylinders are
easily transported.  The calibration gas mixture may be fed to the instrument
directly by using a preset regulator that provides constant gas flow and pres-
sure; or the gas can be fed into a TEDLAR or TEFLON bag, from which it is
drawn into the portable instrument.
     A third approach involves the use of a stainless steel gas sample cylinder
with a small TEDLAR sample bag.  A small quantity of calibration gas is drawn
from a large cylinder of certified gas mixture (at the agency's main labora-
tory) into the small transportable gas sample cylinder.  The calibration gas
is kept at a relatively low pressure to minimize safety problems during trans-
port of the material to the jobsite.  The compressed gas is transferred to the
TEDLAR bag through a regulator and needle valve.  At a pressure of 325 psig,
a 1 liter sample cylinder should provide enough span check gas for two field
checks.  Zero air can be supplied by drawing ambient air through a small char-
coal filter.  This approach is very inexpensive because the agency is using
small quantities of the certified calibration gas mixture from the main cylin-
der at the laboratory and they are not purchasing any disposable cylinders.
Some additional development work on this simple approach is necessary to
ensure that a regulator is available to transfer the gas from the main cylin-
der to the sample cylinder at pressures reaching several hundred psig.  Most
regulators have a delivery pressure limit of 100 psig.  '    It is also neces-
sary to confirm that the compressed gas can be transferred safely.  It should
be noted, however, that this is the same approach used to fill the hydrogen
fuel cylinders on the flame ionization analyzers.  Therefore, an approach of
this type should be feasible.
     Relatively little time is required for the span checks when portable
cylinders of certified gas mixtures or transfer gas sample cylinders are used.
The time required for various activities is indicated in Table 16.  It should
be noted that the instrument warmup must be done anyway, therefore this time
should not be "charged" against the span check.  The overall time commitment
to the field sp'an checks is not excessive when one considers the clear indica-
tion of organic vapor analyzer performance that these checks provide.

                                      47

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               TABLE 16.  TIME REQUIRED FOR FIELD SPAN CHECKS
               Activity
Time required,
    minutes
     Initial span check

          Assemble and leak-check instrument
          Warmup instrument and assembly of span check
            equipment
          Monitor span check gas
          Record results in field notes

     Subtotal

     Midday span check

          Return to location of span check assembly
          Fill bag/start span check system
          Monitor span check gas
          Record results in field notes
     Subtotal

     Final span check

          Fill bag/start span check
          Monitor span check gas
          Record results in field notes
          Empty bag and pack span check equipment
     Subtotal
       10
        2
       _2

       18
       15
        4
        2
       _2

       23
        4
        2
        2
       _4

       12
     The field span check should be performed as far away as possible from
potential sources of fugitive VOC.  It should also be performed in areas

where there are no large AC motors or other equipment that generate strong
electrical fields, as such equipment can have an adverse effect on certain
                                                       1 A
types of instruments (e.g., photoionization analyzers).    The charcoal filter

used in the "clean air" supply should be routinely regenerated to avoid the
possibility of saturation.  The charcoal filter should be checked occasionally
for saturation by supplying a moderate, known concentration of VOC and then
checking the measured exit concentration after several minutes.

     Data concerning the span checks should be recorded in the inspector's
field notes.  This will demonstrate that the specific unit operated properly
during the period in which compliance information was obtained at the
                                      48

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inspection site.  If gauges are provided with the instrument, the field in-
spector also should occasionally note the instrument sample gas flow rate.
5.1.2  Thermocouples
     Thermocouples may be tested in several ways.  The simplest method for
testing is checking a thermocouple in an ice bath and in boiling distilled
water.  There are electronic "ice point" reference circuits commercially
available to check thermocouple operation.   There also is an isothermal zone
box test equipment to test the thermocouple in a different range.  There are
several suggestions for thermocouple operation.  These include:
     1.   Use the largest wire possible that will not shunt heat away from
          the measurement area
     2.   Avoid mechanical stress and vibration that could strain the wires
     3.   Avoid steep temperature gradients
     4.   Use the thermocouple wire well within its temperature rating
     5.   Use the proper sheathing materials in hostile environments.

5.2  ROUTINE LABORATORY EVALUATION OF INSTRUMENT PERFORMANCE
     Routine laboratory evaluation of instrument performance must be con-
ducted.  This evaluation includes determination of response factors, deter-
mination of response time, determination of instrument sample flow rates, and
calibration precision tests.
5.2.1  Determination of Response Factors
     When published response factors for the organic compounds being monitored
are much greater than 1 (approaching 10) or much smaller than 1 (approaching
0.1), however, it would be prudent to measure the response factor for these
specific compounds.  A response factor of 10 1s the maximum allowed by Method
21, which means that the meter response was 10,000 ppmv when the actual con-
centration was 100,000 ppmv.  Although Method 21 does not specify a lower
limit to the response factor, a response factor value of 0.1 means the observed
concentration is 10,000 ppmv when the actual concentration is only 1,000 ppmv.
The general  procedure for measuring the response factor is presented in Method
21 (Appendix A).
                                      49

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5.2.2  Determination of Response Time
     The response time of the organic vapor analyzer is an important operating
variable.  A decrease in instrument response time due either to leakage down-
stream of the pump or to increased flow resistance through instrument probes
and filters can slow down the field work.
     For compliance with Method 21 specifications, the response time should
be checked before initially using the instruments in the field and whenever
the sample flow system has been changed.  Agency personnel should conduct this
test more frequently, however, to confirm that no leakage of sample air has
occurred downstream of the pump.  The use of soap solution is the only alterna-
                                                              18
live to identify sample gas leakage after the instrument pump,   and it is
difficult to apply and observe soap solution in the cramped areas around the
instrument pumps.  Instructions for conducting response factor tests are
included in Section 4.4.3 of Method 21.
5.2.3  Determination of Instrument Sample Flow Rate
     For organic vapor analyzers, especially those without flow monitors, the
sample flow rate should be measured on a routine schedule.  A calibrated rota-
meter or other flow sensor should be used to determine the flow rate when the
typical particulate filters, prefilters, and other flow restrictions are in
place.  If an instrument rotameter is used, its adequacy should be checked.
 ""  The fact that instrument response is relatively insensitive to sample
flow rate (i.e., photoionization analyzers) does not eliminate concern over
proper flow rate.  The tip of the sensor probe operates much like a small
hood, and reductions in sample flow rate reduce the effectiveness of pollutant
capture.   Furthermore, if the probe is not oriented correctly, the "high"
pressure organic vapor plume acts like a strong cross-draft across the probe
inlet.  For these reasons, maximum capture effectiveness is essential, and
reduced sample flow rates should be of concern regardless of the type of
organic vapor analyzer used.
5.2.4  Calibration Precision Tests
     Calibration precision tests must be made before the analyzer is placed in
operation and.at 3-month intervals thereafter.  The general procedures are
discussed in Section 4.4.2 of Method 21.  As with the other instrument

                                      50

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evaluation procedures, this test is best performed by instrument specialists
who are assigned responsibility for routine calibration and maintenance of
all the agency's portable instruments (discussed in Section 4.4 of this
manual).

5.3  ROUTINE FIELD-ORIENTED EVALUATIONS OF INSTRUMENT CONDITIONS AND PERFORMANCE
     Several instrument performance checks should be made before the inspector
leaves for the jobsite and during the routine screening of possible fugitive
VOC sources.  The field-check procedures are in addition to, not a replacement
for, the calibration procedures discussed earlier.  The daily calibration, the
field span checks, and the routine field performance checks are necessary to
confirm that the instrument is operating properly.  Preferably, the initial
instrument checks should be made by the regulatory agency's instrument specia-
list assigned responsibility for the monitors.  Brief notes concerning each
day's initial instrument checks should be included in the main instrument
evaluation/maintenance notebook kept in the instrument laboratory.  The inspec-
tors make the field checks by using the instruments at the jobsite and .docu-
mentation of these field checks should be part of the inspectors' field notes.
5.3.1  Initial Instrument Checks
     It is very important that a few simple instrument checks be made before
the inspector leaves for the jobsite.  The appropriate field checks for each
instrument can be found in the instruction manual supplied by the instrument
manufacturer.  The following common factors, however, should be checked re-
gardless of the type of instrument:
     o    Leak checks including integrity of sample line and adequacy of
          pump operation
     o    Probe condition
     o    Battery pack status
     o    Detector condition
     o    Spare parts and supplies.
     All  of these checks can be made in a period of 5 to 15 minutes.  Repairs
to the detectors, batteries, and probes usually can be accomplished quickly if

                                      51

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a set of spare parts is kept on hand.  Some of the checks that should be made
before field work is begun are discussed in the following subsections.
Leak Checks--
     To leak check the probes on units with flow meters, the probe outlet
should be plugged for 1 to 2 seconds while the sample pump is running.   If
the sample flow rate drops to zero, there are no significant leaks in the en-
tire sampling line.  If any detectable sample flow rate is noted, further
leak checks will be necessary to prevent dilution of the VOC sample gas during
screening tests.  The leak checks involve a step-by-step disassembly of the
probe/sample line starting at the probe inlet and working back toward the
instrument.  At each step, the probe/sample line is briefly plugged to  deter-
mine if inleakage is still occurring at an upstream location.  Once the site
of leakage has been determined, the probe/sample line is repaired and reassem-
bled.  To confirm that the probe/sample line is now free of air infiltration,
the probe is again briefly plugged at the inlet to demonstrate that the sample
flow rate drops to zero.
     When leaks are detected, there is sometimes a tendency to overtighten
the fittings, especially those between the instrument body and the end of the
sample line.  With some types of fittings (e.g., Swagelok fittings) over
                                                                    38
tightening can damage the fitting and even lead to persistent leaks.
  ..   Units that do not have flow monitors should be leak-tested by installing
a rotameter on the sample line as close as possible to the inlet to the instru-
ment body.  The leak-testing procedure described above can then be followed.
Also, the sound of the pump should be noted, as this provides one qualitative
means of identifying pluggage.  It should be noted, however, that pump noise
is useless for identification of probe leakage because the pump continues to
receive air due to the infiltration.
     One report states that the catalytic combustion units should not be leak-
                             24
tested by plugging the probe.    Short-term loss of sample flow would reportedly
lead to high detector temperatures.  One manufacturer, however, reports that
the detector used on their instrument is the same as the detector used on a
diffusion-controlled sampler and that the short-term loss of sample flow would
                             21
not be a significant problem.
                                      52

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     When more than one probe can be attached to the instrument body, each
probe should be tested.  Only those that can be sealed properly should be
packed for field use.
Probe Condition--
     The probes for some instruments can contain a number of independent com-
ponents, especially those that dilute the sample before analysis.   The physi-
cal condition of the probe should be visually-checked before use.   These checks
include, but are not limited to:
     o    Presence of any organic deposits on the inside of the probe
     o    Presence of clean particulate filter in the probe
     o    Condition of orifice(s) used to control dilution air flow into
          the sample probe
     o    Condition of sealing "0" ring or other sealing assembly  used to
          prevent inadvertent dilution of sample flow.
     Any deposits found should be removed, or a different probe should be used.
Cleaning instructions can be found in the manufacturers' operating manuals.
Generally, the probes are cleaned with acetone and then carefully  purged of
                                  19
any acetone vapor before assembly.
Battery Pack Status "Checks-
     Checking the battery pack is particularly important because it can be a
source of frequent problems.  The battery pack condition is normally checked
by simply switching the instrument to the "Battery Check" position and observ-
ing the dial setting.  If the battery appears at all weak, a new battery pack
should be installed.  Most batteries fail because they have not been recharged
sufficiently.
     The Ni-Cd batteries, used in many photoionization, catalytic, and
infrared instruments, must be charged for 8 to 12 hours for each 8 hours of
operation.   These batteries are very vulnerable to overcharging.  Recent
improvements in the Ni-Cd battery chargers, however, have substantially
                                   38
reduced the chance of overcharging.    Despite a common misconception, the
lead acid-gel batteries commonly used in FID instruments are not subject to
overcharging, and they should be left on the battery pack recharger whenever
                             19
the instrument is not in use.

                                      53

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     During cold weather, weak batteries will  operate for only a short period.
In fact, if the unit is to be operated in cold conditions for most of the
inspection day, it would be helpful to bring a second battery pack along so
                                           19
the battery pack can be replaced at midday.
Detector Condition--
     Each of the instruments includes a key  component within the VOC detector.
Rather than an initial calibration (recommended earlier in Section 5.1), some
inspectors check the detector status by briefly monitoring automobile exhaust.
This is not generally advisable because condensable organic compounds and par-
ticulate matter can deposit in the probe, partially plug the filters, and even
damage the detector.  If a qualitative response test is desired, an organic
vapor source, such as a cigarette lighter (do not take into plants to be
inspected), certain marking implements, liquid paper thinner, or a small sample
bag should be used.  A complete calibration  is preferred over these qualitative
response checks.
     The flame ionization instruments are checked by depressing the ignitor
button for several seconds.  If the unit will  not ignite after repeated attempts,
there may be problems with the batteries, ignitor, or hydrogen supply.   Most
of these problems cannot be solved immediately; therefore, other instruments
will have to be used until the repairs are completed.  Hydrogen leak problems
                                               19
are much less prevalent with newer instruments.    Failure of the catalytic
units to respond to organic vapor is often due to failure of the main detector
cell, an easily replaced component.
Spare Parts and Supplies-
     Most of the instruments used on VOC Inspections are sophisticated instru-
ments rather than simple "off-the-shelf" items.  Each requires some spare parts
and supplies to ensure that the inspection is not terminated prematurely.  Table
17 provides a partial listing of the recommended spare parts for each general
type of instrument.  All of the parts listed should be carried to the jobsite.
Other spare parts (discussed in Section 4) should be left at the instrument
laboratory/shop.  Further information is available in the manufacturers' operat-
ing manuals and from the manufacturers' representatives.
                                      54

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         TABLE  17.   PARTIAL LISTING OF RECOMMENDED ONSITE SPARE PARTS
                    AND SUPPLIES FOR PORTABLE INSTRUMENTS
         Instrument
  Spare parts and supplies
 Flame  iom'zation detectors
 Photoionization detectors
 Nondispersive infrared detectors
Catalytic combustion units
Thermocouples
    Battery pack
    Particulate filters
    Glass wool
    TYGON tubing (1 foot)

    Window cleaning kit
    Spare lamp
    Particulate filters
    Glass wool
    Dilution probe
    TYGON tubing (1 foot)
    Rotameter
    Battery pack

    Battery pack
    Particulate filter
    Rotameter
    Glass wool
    TYGON tubing (1 foot)

    Detector
    Battery pack
    Particulate filter
    Rotameter
    TYGON tubing (1 foot)

    Battery
    Probe
5.3.2  Routine Performance Checks During Field Work

     Several routine performance checks should be conducted during field viork.
These checks take very little time and demonstrate that the unit is continuing
to perform in a proper manner.  They also should be discussed briefly in the
field notes.

Instrument Zero—
     The instrument zero should be recnecked whenever it has been exposed to
very high organic vapor concentrations and whenever organic liquids may have
been inadvertently sucked into the probe.
                                         18,24,44
The instrument zero should
be checked at least twice a day, even when these problems do not occur or are
                                      55

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not suspected.  It can be checked by sampling background air at a location up-
wind of any possible VOC sources or by supplying some charcoal-filtered air to
the analyzer.  If the zero has drifted significantly, the probe particulate
filter and the prefilter (if one is used) should be replaced.   Also,  the probe
should either be cleaned or replaced.   The instrument then should be  recali-
brated before the field work continues.
Instrument Response—
     The instrument response should also be checked routinely during  field
testing because all of the instrument types are vulnerable to operating prob-
lems that can result in reduced sensitivity or complete loss of response.   In
the case of FID's, exposure to very high VOC concentrations (above 70,000
                                        19
ppmv) can lead to flame out of the unit.    It is sometimes difficult to hear
the audible flame-out alarm over plant noise unless earphones (supplied with
some models) are used.  If the inspector fails to hear the flame-out  alarm,
he or she could miss a number of fugitive leaks.
     The catalytic combustion units are also vulnerable to problems when ex-
posed to very high concentrations.  The detector can reach temperatures high
                                                  21
enough to cause some loss of the catalyst coating.    If done repeatedly, this
                                          21
can also shorten the life of the detector.    Exposure to lead-containing
                                                             21
gasoline can lead to some poisoning of the detector catalyst.    For  these
reasons, the response should be checked whenever the unit is "pegged."  The
remaining gas in the TEDLAR bag used for span checks provides a convenient
source of organic vapor to confirm instrument response.
     Response problems of the photoionization and nondispersive infrared
detectors result primarily from deposition of condensed organic compounds on
the optical surface.  The window should be cleaned at least once a day and
whenever material might have been deposited as a result of exposure to high con-
centrations or entrained liquids.  '*    Unfortunately, contamination on the
optical window is not always visible.   Therefore, inspectors should simply
assume the window is dirty and take the necessary time to use the cleaning
solution.  Instrument manufacturers recommend a solvent similar to methanol
(instrument manufacturers should be contacted for specific recommendations)
for routine cleaning.       The cleaning compound is mildly abrasive  and is
intended only'for stubborn deposits that cannot be removed by more gentle
         27
cleaners.
                                      56

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Battery Condition-
     In the case of some FID's, weak batteries  will  not have  enough  power to
operate the ignitor, even though a proper reading  was  obtained  during  the bat-
           19
tery check.    This can be a problem after the  FID has been operated for several
hours and after a number of flame-outs  have occurred.   Therefore,  the  instrument
operator should check the battery condition several  times  during  the day.
Probe/Sampling Line Leakage—
     The probe and sampling line integrity should  be checked  several times  a
day by simply plugging the probe inlet.   The flow  rate indicated  by  the  instru-
ment meter (if one is present)  and the  sound of the  instrument  should  be
noted.  Any potential leaks should be corrected before work is  continued.
                                      57

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                                .  SECTION 6
              FIELD INSPECTION PROCEDURES AND INSPECTION SAFETY

     This section presents field measurement procedures for regulatory agency
inspectors.  The first subsection presents several  basic reasons why the
measurement procedures used by agency inspectors are inherently different from
those that may be used by source personnel or their consultants.  It also pre-
sents some important basic principles concerning the inspection of VOC and air
toxic sources.  The remaining subsections concern major types  of sources  for
which portable inspection instruments have proven useful.   Safety considera-
tions have been integrated with the information concerning field inspection
procedures and underlined to emphasize their importance as an  essential part  of
all activities involving the portable instruments.

6.1  PRINCIPLES, REQUIREMENTS, AND LIMITATIONS OF AGENCY INSPECTIONS
     One of the basic premises of the inspection techniques presented in  this
section is that the.agency inspector does not have  sufficient  time to survey
all'.potential sources of fugitive emissions independently or to monitor the
performance of all air pollution control devices completely.  Furthermore, each
inspection involves a review of the permits, a review of operating records, and
interviews with appropriate plant supervisory personnel.  Because the use of
portable instruments, the subject of this manual, composes only one part  of
the overall inspection, it is unrealistic to assume that agency inspectors can
spend the majority of the inspection day using the  portable instruments.
Rather, inspectors must be able to select those few measurement activities that
are most useful in the characterization of the overall conditions at the  facil-
ity.   In the case of fugitive VOC and air toxic leaks, the inspector must
determine the monitoring accordingly.
     Field inspection surveys conducted by plant personnel and consultants
often involve a team of at least two individuals—one to operate the
instrument and one to record the data and tag the appropriate  sources.

                                      58

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Regulatory agencies usually send only one inspector.  As a result, the inspec-
tion proceeds more slowly, as the inspector normally must set the instrument
down to record the results.  This problem cannot be solved by the use of con-
tinuous recorders because most of them are not intrinsically safe and should
not be used.
     The data obtained by regulatory agency inspectors must be of the highest
quality reasonably possible because these data are used to determine the com-
pliance status of the facility.  Time should be allocated for the field span
checks, response checks, and zero gas checks discussed in the earlier sections.
It is preferable to have a limited set of data of unquestionably high quality
than a large set of potentially inaccurate data.
6.1.1  Inspection Principles
     Use of the baseline technique is the best approach to inspection of air
pollution control devices such as carbon-bed adsorbers, incinerators, and vapor
recovery.  The baseline technique is based on the comparison of current inspec-
tion data against unit-specific performance data obtained in the past.  Shifts
in several operating parameters are used as an indication of problems.  The
portable instruments are used only when there are insufficient onsite equip-
ment performance monitors or when reasonable questions arise concerning the
adequacy of the onsite gauges.  The basic principles of the baseline technique
are as follows:
     o    Only unit-specific data are used to evaluate performance.
     o    Portable instruments are used when onsite gauges are either
          unavailable or unreliable.
     o    Problems are identified by evaluating changes in a number of operat-
          ing parameters and conditions.
     o    The information is compiled in a methodical manner.
     o    The inspection procedure 1s modified or limited to the extent
          necessary to ensure safety of the inspector, plant personnel, and
          the source's equipment.
     The baseline technique is not directly applicable to the fugitive VOC and
air toxics leak sources, as no directly observable valve or pump operating
parameters govern the rate of fugitive emissions.  These sources either leak or
                                      59

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 they don't.  For the fugitive leak sources, the baseline concept should be
 applied to the plant's leak-detection and repair program rather than to the indi-
 vidual leaking components.  The adequacy of the leak-detection procedures is
 determined by spot-checking potential leaking sources and by rechecking those
 components that have been tagged previously.  Changes over time in the leak-
 detection and repair program that could have an adverse impact on total emissions
 should be .evaluated.  In other words, the adequacy of a plant's leak-detection
 and repair program is evaluated by using leak data obtained during the current
 inspection and data obtained during previous inspections.  This is a more
 accurate approach than simply evaluating what activities are conducted at what
 frequency in a given plant's program.  The type of programs necessary at one
 plant and those at supposedly similar facilities can differ significantly.
 6.1.2  General Safety Procedures
     All agency personnel should have an occupational health medical examination
 before conducting any field Inspections.  This examination demonstrates that the
 Inspector 1s physically capable of the stress associated with carrying the port-
 able Instruments, climbing ladders/stairs, and wearing the required respirators
 and other personnel protection equipment.    Annual medical examinations should
 be required.
     All regulatory agencies should adopt and adhere to written safety procedures
 governing all routine activities of field personnel.    Specific safety proce-
 dures concerning the use of portable instruments and the types of industries
 the Inspector will visit should be included In these procedures.
     Because agency coworkers are rarely present, the Inspector should insist
 that someone from the plant accompany him or her at all times to ensure that
 the Inspector does not Inadvertently enter unsafe areas, to assist the in-
 spector in the event of accidental gas releases within the facility, to get
help if the inspector is Injured, and to provide general assistance and advice
regarding safety.   '    Inspectors should not work alone in the facility for
any reason.
     Prior to leaving for the jobsite, the inspector should obtain all necessary
safety equipment.   All the safety equipment, especially respirators, should be
checked to confirm that they are in good working condition.  The proper safety
shoes should be worn for the conditions that exist at the facility being

                                      60

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inspected.  Because safety shoe requirements differ, the plant should be con-
sulted to determine the proper type of shoe before the inspector departs for the
jobsite.
     Before entering the processing areas of the facilities, the inspector
should discuss the instrument intrinsic safety with the appropriate plant repre-
sentatives.  Portable instruments that are not intrinsically safe should not
be  taken into Class I, Division 1 and Division 2 areas.
     During the field survey, the inspector should use an organic vapor analyzer
to  help determine if conditions are safe.  This is especially true when a tank
with a floating roof is only partially full.  These situations must be approached
with great caution as they are similar to entering a confined area.  Half-face
cartridge-type respirators for organic vapor are limited to maximum concentra-
tions of 50 ppmv.  This concentration can be easily exceeded in the immediate
vicinity of fugitive leaks.  The inspector should use the organic vapor analyzer
to  determine if poorly ventilated areas have organic vapor concentrations in
the breathing zone that are above the concentration limits of the respirator.
     Inspectors rarely have the opportunity to acclimate to heat stress.  Heat
exhaustion and stroke can result from the physical exertion of carrying the
instruments and from exposure to hot process equipment.  Inspectors should plan
to  take regularly scheduled breaks and drink fluids to reduce the risk of heat
exhaustion and heat stroke.  These breaks are good times to check the zero
drift or to perform the field span checks of the portable instruments.

6.2  SCREENING TESTS FOR VOC LEAKS FROM PROCESS EQUIPMENT
     The primary purpose of the VOC leak-screening tests is to determine If the
plant's leak-detection and maintenance program 1s adequate.  The Inspection con-
sists of a review of the leak records and a field survey with an organic vapor
analyzer.
6.2.1  Selecting an Inspection Strategy
     Because the time available for the field survey is often limited, the most
probable "leakers" should be targeted for evaluation.  The Inspector should con-
sider the following factors to determine potential problem sources.
     o    Specific components Identified as leakers in the past
     o    Type of service (e.g., gas, light liquid, heavy liquid)

                                      61

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     o    Type of component (e.g., valves, pumps, flanges, compressors, open-
          ended lines, relief valves)
     o    Pressure of line
     o    Temperature of line
     o    Specific design of component (e.g., type of pump seal, type of valve,
          type of valve packing)
     o    Age of equipment/component
     o    Volatility of specific organic compound(s) being handled
     o    Presence of dripping liquids.
     Because the field inspector does not have the luxury of spending hours to
determine the optimum field survey strategy, it is recommended that field moni-
toring primarily emphasize the following:  1) those components/process areas
with a demonstrated history of high leak rates, 2) valves in gas and light
liquid service, 3) pumps in light liquid service, and 4) compressors.  Data
obtained during a number of EPA-sponsored studies and private studies have
clearly indicated that these sources have the highest frequency of VOC leaks
in refineries and synthetic organic chemical manufacturing industry plants.  *  *  *
For example, data compiled by WetheroId et al.   and shown in Table 18 indicate
that valves and pumps in heavy liquid service leak much less frequently than
those in gas service and in light liquid s'ervice (light liquid means a boil-
ing point below that of kerosene; heavy liquid means a boiling point equal to
or above that of kerosene).  Investigators have generally concluded that most
chemical plant and refinery components in heavy liquid service have a low
probability of leaking.
     The data presented in Table 18 clearly indicates that flanges are a
relatively minor source of emissions.  Although this is consistent with other
studies of petroleum refineries, the flange leakage in some synthetic organic
chemical manufacturing industry facilities may be higher, based on observa-
                           49
tions by Harvey and Nelson.    Nevertheless, flanges are not good targets for
the field survey because they are numerous and their overall leak rate is less
than those of other components.
     Conversely, most refineries and synthetic organic chemical manufacturing
industry plants have very few pumps and compressors, but the leak frequencies

                                      62

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          TABLE  18.  ESTIMATED LEAKAGE RATES FOR REFINERY COMPONENTS'
            Source type
Estimated percentage
  that are leaking
  Valves
      Gas/vapor  streams
      Light  liquid/two-phase streams
      Heavy  liquid streams
  Flanges
  Pump seals
      Light  liquid streams
      Heavy  liquid streams
  Compressor  seals
      Hydrocarbon service
      Hydrogen service
  Drains
  Relief valves
         29.3
         36.5
          6.7
          3.1
         63.8
         22.8
         70.3
         81.2
         19.2
         39.2
 aInformation abstracted from Table 1-1 In Reference 25.

 appear to be high. - Several of these should be included on the field survey.
''Any pump that has liquid dripping from the seal certainly should be moni-
      52 53
 tored  '   although this is not an entirely reliable indicator of excessive
                    52
 fugitive emissions.
      Because of their large number in a typical refinery or synthetic organic
 chemical manufacturing industry plants, valves are considered dominant sources
                           25 48 49
 of fugitive VOC emissions,  '*   and a number of these should certainly be
 included on any field survey.  Unfortunately, the EPA-sponsored studies indi-
 cate that a relatively small fraction of the valves are responsible for most
 of the emissions from this fugitive source.  For example, WetheroId and Provost
 found that 3.6 percent of the valves were causing more than 90 percent of the
                                         25
 fugitive emissions attributed to valves.    To the extent possible, the in-
 spector should target the field survey toward the offending valves.  The
 identification'of the problem is complicated by the fact that a typical re-
                                                     49 54
 finery could have more than 10,000 to 20,000 valves.   '
                                       63

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     Soap solution can be used to help in the selection of the valves to moni-
tor.   ''    The time required to spray the soap on the valve stem, however,
is just slightly less than that required to monitor the emissions with an organic
vapor analyzer.  Soap screening techniques are more appropriate when the actual
emissions are to be quantified by source bagging, which is a time-intensive
approach.  Source bagging is commonly practiced as part of special fugitive
leak studies, but it is not a routine inspection tool.
     During the field survey, inspectors should listen  for any audible leaks,
as this may help to locate "leakers" that were not suspected.   Sometimes odors
also can be of benefit in adjusting the field survey portion of the inspection.
The effectiveness of both of these techniques is limited, however.
     Another technique of limited usefulness is the "walk through" survey, in
which a portable organic vapor analyzer is used to identify areas of high con-
centrations relative to background concentrations.  Supposedly, these areas
would be in the immediate area of fugitive leaks.  Unfortunately, this technique
does not appear to be a reliable indicator of fugitive  leak locations.  Weber
and Minis found that the results could not be reproduced even when the technique
was repeated almost immediately.
     With regard to line pressure and temperature, Wetherold et al. found no
significant relationship between these parameters and leak frequency in refin-
eries,   however, Langley et al. found that line pressure did correlate with
               '   I  , . ^ I .   . L. .
leak frequency in selected synthetic organic chemical manufacturing industry
facilities.     Inspectors should consider line pressure only as a secondary
variable when attempting to evaluate the most important components and/or
process areas.
6.2.2  Measurement Procedures
     Fugitive leaks from valves in closed systems occur primarily from the
valve stem packing gland.  This packing material is intended to seal the pro-
cess gas and/or liquids from the atmosphere.  As the packing lubricant is lost
or the packing material wears, some volatilization of organic vapors is possible.
     For these types of valves, the emissions are monitored at the point where
the valve steam leaves the packing gland.  The normal procedure is to circum-
scribe this  location with the probe within 1 centimeter of the valve stem.
This close location is necessary because of the relatively poor capture

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 effectiveness inherent in the probe designs used on commercially available
 instruments.  The capture effectiveness decreases very rapidly with distance
 from the probe.  The presence of a strong cross-draft due to ambient wind
 further reduces the probe capture capability.  For these reasons, the probe
 must be placed very close to the valve packing gland.  It should be noted,
 however, that this brings the inspector into the immediate vicinity of the
 leak because of the short length of most probes.  While monitoring the leak,
 the inspector could exceed the safe operating range of the respirator and even
 saturate the respirator cartridge.  To minimize inhalation hazards, the in-
 spector should terminate any screening tests when the concentration of organic
 vapor in the breathing zone exceeds the maximum safe concentration of his or
 her specific respirator.
     Some EPA-sponsored work has indicated that fugitive emissions from sources
 such as valves could be reliably monitored at 5 centimeters from the valve stem
                                                      52
 rather than the 1-centimeter distance discussed above.    A leak definition of
 1000 ppmv at 5 centimeters appears equivalent to the conventional leak defini-
 tion of 10,000 ppmv at 1 centimeter.  The 5-centimeter distance is an attractive
 alternative because this lessens the chance that liquids on the surface of the
 valve will be carried into the instrument.  For Method 21 inspections, however,
 leak definition of 10,000 ppmv at 1 centimeter should be used to ensure con-
 sistency with the regulation.
     Valves used on the ends of drains or sample lines have two sources of
 leakage, the valve stem and the valve seat.  Most sources use a double valve
arrangement or incorporate a blind flange to protect against emission losses
through the valve seat of the main shutoff valve.  To confirm the adequacy of
the drain or sampling line seal, the probe is usually placed at the center of
the discharge pipe.
     Fugitive emissions from pumps occur from the pump shaft seal used to
isolate the process fluid from the atmosphere.  The most commoly used seals
are single mechanical seals, double mechanical seals, and packed seals.  Moni-
toring is done within 1 centimeter of the seal and the rotating shaft.  A rigid
probe tip should not be used near the rotating shaft.  The probe tip could
break if the inspector were not able to hold the probe absolutely steady during
the measurement.   A flexible tip is usually added to the end of the rigid
                          16 58
probe when sampling pumps.   '

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     Most pump shafts have shaft guards that protect against entrapment in the
 rapidly rotating shaft.  With some instruments, it is difficult to reach
 through the guard to the location of the shaft and shaft seal.  The guard should
 not  be removed under any circumstances, and those pumps without guards should
 be approached very carefully.  If there is any question concerning the safety of
 the  measurement, it should not be performed.  Pump monitoring safety should be
 discussed with plant personnel before the field survey portion of the inspection
 is initiated.
     Several organic vapor analyzer problems can be caused by sampling gases
 having too high a concentration.   At hydrocarbon concentrations above 70,000 ppmv,
                                                  19
 flame-out of flame ionization detectors can occur.    High concentrations of
 hydrocarbons can lead to very high detector temperatures and the loss of catalyst
 in catalytic units.  Condensation of a portion of these high concentration vapors
 on photoionization unit lamp windows can reduce the sensitivity of the instrument.
 The  condensation of material in the probe and sampling lines can be a problem
 for  all types of instruments.  For these reasons, the inspector should monitor
 the  hydrocarbon concentration while slowly approaching the valve stem, pump
 shaft seal, or other source.  If the instrument gauge indicates high concentra-
 tions, the specific leak site on the valve stem or pump seal should be approached
 very carefully.  In some cases, the concentration will exceed the leak definition
 even before the probe is placed close to the leak site.  Obviously, in these
 cases, there is no need to move the probe closer and risk affecting the perform-
 ance of the organic vapor analyzer.  Furthermore, there is nothing to be gained
 by maintaining the probe at the leak site for two times the response time (a
 general rule) if the instrument already indicates a concentration above the
 leak.  To the maximum extent possible, field inspectors should protect the
organic vapor analyzers against high organic vapor concentrations.
     The organic vapor analyzer probe should never be placed in direct contact
with liquids during the monitoring of fugitive emissions.  A portion of the
 liquid could be pulled into the probe and damage the instrument detector.  If
 there is contact with liquid, it may be necessary to clean and/or repair the
 instrument.
     The inspector also must exercise care when monitoring sources, such as
 valves and pumps, that handle heavy liquid streams at high temperatures.  Rela-
 tively nonvolatile organic compounds can condense in the probe and the

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detector.  Both the instrument response to the emissions and the instrument
return to zero may be slowed because of the condensation of these compounds.
For fugitive VOC sources that have a highly variable leak rate, the maximum
sustained concentration or maximum repeated concentration observed should gen-
erally be recorded.
     Certain fugitive leak sources are subject to a "no detectable leak" regula-
tion, i.e., the difference between the background organic vapor concentration
and the concentration downstream of the source should not be greater than 500
ppmv.  The background concentration is determined by placing the probe 1 to 2
meters upwind of the source.  If other equipment interferes with the background
measurement, the upwind monitoring location can be as close as 25 centimeters.
     No heroic attempts should be made to reach valves and other fugitive
sources in inaccessible locations.  A relatively high percentage of the valves
are often in difficult-to-reach locations.55'59

6.3  INSPECTION OF CARBON-BED ADSORBERS
     Carbon-bed adsorbers are used to recover valuable solvents used in the
manufacturing process.  Most larger systems are regenerative units with two or
more carbon-bed vessels.  The beds are.isolated one by one for regeneration
while the others remain on-line.  Steam is the most common means of bed regen-
eration.  Selection of the regeneration cycle is based on the need to maximize
solvent recovery while minimizing steam consumption.  The organic compounds
desorbed from the bed during regeneration are condensed, along with the steam,
in a condenser.  The water and the solvents are then separated in a decanter.
Unless the field inspector has a prior background in carbon-bed design and
operation, it will be difficult to identify carbon-bed system problems by using
only the control device gauges.
     Portable inspection instrumentation is very useful for this type of air
pollution control device because it provides a direct means of determining
whether the removal efficiency has decreased since the baseline period.  The
effluent gas during the adsorption period from each separate bed should be be-
tween 50 and 500 ppmv, if the carbon bed is being operated properly and the
adsorbent remains in good condition.  If the bed is being operated too long
between regeneration cycles or the adsorbent is no longer able to handle the
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 solvent  loading, the effluent gas concentration increases dramatically.  Emis-
 sions can also  increase if the bed has become partially saturated with hard-to-
 remove compounds.
     To  determine if the carbon beds have a "breakthrough" condition, the
 inspector places the portable organic vapor analyzer near the exhaust of each
 individual bed.  '    The emissions should be monitored several times during
 the adsorption  cycle of each bed.  Because the instrument usually is not cali-
 brated for the  specific solvents being handled, the value does not correspond
 directly with the actual concentration.  Nevertheless, a comparison of the cur-
 rent value against effluent concentrations that were measured when the control
 system was working properly provides an indication of operating problems.  A
 very high reading during the inspection is also a clear indication of bed
 problems.
     Before being used in field work, the organic vapor analyzer should be
 calibrated for  a moderately low concentration.  A calibration to 10,000 ppmv
 methane  is not  appropriate when the emissions being measured are expected to
 be in the range of 50 to 500 ppmv.
     Portable instruments generally can be used safely on the exhaust streams
 because  the maximum organic vapor concentration is rarely above 25 to 50 per-
 cent of  the lower explosive limit (LEL).  Nevertheless, field inspectors should
 use only intrinsically safe instruments as other areas around the carbon bed
 or the facility could have potentially explosive vapors during unusual operating
 conditions.
     No heroic efforts should be made to monitor carbon-bed exhaust vents that
 are in difficult to reach locations.  These exhausts are often too high to
 reach with standard probes.  Inspectors also must be careful to avoid the
downdraft emissions from the vents.  Even when the carbon-bed is operating
properly, the organic vapor concentrations exceeds the maximum allowable con-
centration of cartridge-type respirators.  When the bed is not operating
properly, concentrations in the stack can be very high.  Plume downdraft is
quite common because the gas stream is not very hot, the exit velocities are
 low, and the vents are usually only 5 to 15 feet above the ground.
     Carbon-bed performance problems identified by the organic vapor instruments
can be confirmed by using a solvent material balance.  Because it is relatively
time-consuming, however, this exercise is generally performed only when the bed

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emissions are abnormally high or when safety considerations preclude the use of
measurements.
     Static pressure gauges have a limited application in the inspection and
evaluation of carbon-bed adsorbers.  The gauge can be used to measure the
static pressure drop across the bed if static pressure measurement taps are
available above and below the bed.  These data are useful in determining if
the bed has collapsed (often caused by corrosion) of if the total  gas flow
rate to the carbon-bed has increased substantially.

6.4  INSPECTION OF THERMAL AND CATALYTIC INCINERATORS
     Theoretically, thermometers should be very valuable for routine inspec-
tions of thermal and catalytic incinerators.  On all types of incinerators,
the operating temperature is one of the main variables determining the effec-
tiveness of pollutant destruction.  The independent measurement of the in-
cinerator operating temperature during the inspection would be very useful in
confirming proper operation.  Unfortunately, however, the incinerators rarely
have ports in which a thermocouple could be inserted to determine  the temper-
ature, partially because it is very difficult to obtain accurate measurements
with portable thermometers.  If the probe is placed within the direct line-
of-sight of the burner flame, the radiant energy received by the probe can
indicate higher-than-actual gas temperatures.  Conversely, thermocouple probes
partially or completely shielded by refractory baffles can indicate much
lower-than-actual gas temperatures.  Most facilities rely on permanently mounted
temperature indicators installed with the incinerator rather than attempting
to measure the incinerator temperature.  Chances that an onsite gauge will be
significantly in error are slight because failure of the onsite temperature
monitor usually causes the'incinerator to trip off-line.  For these reasons,
regulatory agency inspectors generally use the onsite gauge to confirm the
proper operation of incinerators.
     If an independent temperature measurement is needed, the inspector can
monitor the incinerator stack temperature.  A drop in this value compared with
baseline data indicates a decrease in the incinerator operating temperature.
Whereas actual incinerator conditions could not be reliably inferred from the
stack temperature data alone, large decreases in the stack temperature could

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 demonstrate the need for a stack test.  Most thermal and catalytic incinerator
 stacks,  however, do not have appropriate ports for portable thermocouples, and
 many of  those that do are in inaccessible locations.  Inspectors must be
 extremely careful when making measurements on incinerator stacks.  Potential
 problems include (but are not limited to) severe burns, heat stress, falls,
 and inhalation hazards.  It should also be noted that battery-powered thermom-
 eters are generally not intrinsically safe; therefore, these instruments
 cannot be used in areas where potentially explosive gas mixtures or dust
 clouds could exist.
     Although specific procedures have not yet been developed, organic vapor
 analyzers could conceivably be used as part of an incinerator inspection.  A
 portion of the incinerator stack gas could be withdrawn and cooled to a gas
 temperature compatible with the organic vapor analyzer.  Presumably, this
 would require that the instrument probe be replaced with a sampling train in-
 cluding a high-temperature probe, a condenser, a moisture trap, and a particu-
 late filter arranged in series.  The measured organic vapor concentration
 would provide a direct indication of the effectiveness of the incinerator.
 Actually, a procedure of this type would be difficult to implement at the
 present time for the following reasons:.
     o    The sampling train includes several bulky items that are time-
          consuming to setup and cumbersome to transport.
     o    A traverse of the stack would be necessary to determine the
          presence of any stratification of partially combusted organic vapors.
     o    Condensation of nonvolatile organic compounds could plug the par-
          ti culate filter or damage the instrument detectors.
     o    Failure to cool the stack gas adequately would result in damage to
          the instrument.
     o    There is no assurance that the instrument will detect a sufficient
          fraction of the partially combusted organic compounds.
     For these reasons, field inspectors do not currently use this technique.
All of the sampling train problems probably could be worked out, however, the
 uncertainty of instrument response due to unknown organic compound species may
 preclude use of this technique.  At the present time, it is recommended that
 regulatory agency inspectors not attempt to use organic vapor analyzers for
 the evaluation of incinerator effluent.

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6.5  INSPECTION OF VAPOR RECOVERY SYSTEMS
     Three major types of vapor recovery systems are commonly used at gasoline
terminals:  1) carbon-bed adsorbers with followup gasoline absorption, 2) re-
frigeration, and 3) thermal oxidation.  Portable instruments can be used to a
limited extent to inspect these air pollution control systems.
     Vapor recovery systems using carbon adsorbers are inspected in a manner
similar to that described earlier for carbon-bed adsorbers in Subsection 6.3.
If the exhaust vent for each bed (normally there are two beds)  is accessible,
the organic vapor analyzer probe can be used to confirm that the exhaust con-
centration during the adsorbtion cycle is less than 500 ppmv.  Failure of the
desorption process or saturation of the bed both lead to "breakthough" and
very high VOC concentrations during the adsorbtion cycle.   In fact, the emis-
sions from the carbon bed during severe malfunction can be within the explosive
range.
     The potentially high vapor concentrations necessitate that the probe
initially be placed well downwind of the exhaust vent in an area where dilu-
tion of the effluent has already occurred.  If the observed concentration is
high (> 200 to 300 ppmv), the bed obviously is not operating properly and no
further measurements are necessary.  If the downwind concentration is very
low, the probe can be advanced slowly toward the exhaust vent itself,  if the
observed concentration exceeds several thousand ppmv at any time, the measure-
ments should be discontinued.  This cautious approach is required because of
the remote possibility that a significant static charge can accumulate on the
instrument probe or the inspector's clothing as he or she walks around the
unit.  A spark in a cloud of gasoline vapors within the explosive range would
have serious consequences.  Therefore, the probe Is never allowed to enter
the exhaust plume at an area where explosive concentrations could conceivably
exist.
     Many carbon-bed vapor recovery systems do not have platforms above the
beds to permit access to the exhaust vents, which are usually 10 to 15 feet
above the ground.  When this is the case, inspectors should not attempt to
climb up to the vapor recovery systems to reach the exhaust vents.
     Portable instruments have very little application in the inspection of
the refrigeration and incinerator vapor recovery systems.   In the case of the
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 refrigeration  units, the normal exhaust concentrations are 30,000 to 50,000
 ppmv, which are above the normal operating range of most instruments.  Further-
 more, the  gasoline vapor concentration can be in the explosive range.  Also
 access  to  the  exhaust vents, normally 10 to 15 feet high, is generally very
 poor.   The thermal incinerators rarely have measurement ports to permit the
 use  of  portable thermometers, and the inherent measurement accuracy problems
 are  the same as those for large thermal and catalytic systems.

 6.6  SURVEYING EMISSIONS FROM STACKS, VENTS, AND ROOF MONITORS
     Regulatory agency personnel have expressed an interest in evaluating the
 organic vapor  emissions from stacks, vents, and roof monitors as part of
 special  inspections.  Some of the principal objectives of these surveys are
 summarized below:
     o     To evaluate possible sources of community odors.
     o     To evaluate emissions from bypass stacks and vents believed to be
           sealed.
     o     To evaluate adequacy of pollutant capture in specific process areas
           and  buildings.
     o     To identify sources of organic compounds not currently included on
           the  plant emission inventory or covered by operating permits.
 i    ,
     These activities are obviously different from those of a conventional
 source  inspection.  Unfortunately, most regulatory agencies currently do not
 have the necessary equipment to perform such evaluations.  Presumably, the
 organic vapor analyzers purchased for inspection of VOC and air toxic sources
 could be used for these additional activities.
     Stacks, vents, and roof monitors are difficult sources to measure with
 portable organic vapor analyzers.  All of the commonly used instruments are
easily damaged if particulate is carried into the instrument detector.  Con-
densable organic vapors, condensable acid vapors, and moisture could severely
 damage the instrument detectors, the instrument pumps, and the entire
 sample-handling system.  Thus, the instruments should include a moisture trap
 and a particulate filter, at the very minimum.  An additional glass wool plug
 at the probe inlet would provide additional protection.  Both the glass wool
                                      72

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and the instrument particulate filter should be changed if there is an indica-
tion that the sample flow rate has decreased during the survey.
     High organic vapor concentrations can lead to flame-out of  the FID's and
damage to all types of instrument detectors.  When high concentrations are
expected, the instrument should include a dilution probe.   As an alternative,
the sample could be taken in a TEDLAR or TEFLON bag and diluted  with hydro-
carbon-free air before the instrument is used.  If high VOC concentrations are
accidently found, the probe should not be left in the high concentration stream
for a long time.
     In sources of this type, the specific chemical compounds in the gas
stream are rarely known.  Lack of knowledge concerning the appropriate re-
sponse factors makes it difficult to interpret the organic vapor analyzer
meter readings.  The instrument simply provides a qualitative indication of
the presence or absence of high concentrations of organic  vapors.   In some
compounds, the response may be so poor that small sources  of emissions will
not be reliably identified.  To improve the reliability of detection, field
inspectors could use two different types of analyzers.  Combinations such as
an FID and a PID, a catalytic unit and a PID, or an FID and an infrared unit
would cover a much broader group of organic compounds.  This also increases
the time and difficulty of the survey, however.
     Before conducting any surveys of stacks, vents, and roof monitors, regu-
latory agency personnel should carefully evaluate the potential  safety hazards
and the potential variability of emissions.  It may be difficult to obtain
good data even if the instruments are responding properly.
     Many fugitive emissions passing up through the stacks, vents, and roof
monitors are intermittent in nature.  Some degree of luck  is necessary to have
the instrument at the right spot at the right time.  The probability of detec-
tion is improved if the inspector is familiar with the plant operating cycles.
Even with a good working knowledge of the plant operations, however, the
inspector can miss the short-term emission events.  Another major problem
is the size of some of the vents and roof monitors.  The probes  used with the
portable instruments are relatively short and would not be appropriate for
traversing large open sources.  Although the use of longer probes is possible,
the additional, flow resistance could have a detrimental effect on the
                                      73

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instrument's sample gas flow rate.  This is important because some instruments,
notably the FID, are especially sensitive to flow rate variation.
     Several potentially serious safety problems  must be considered before
surveys of stacks, vents, and roof monitors are attempted:
     o    Falls through weak roofs
     o    Sudden exposure to potentially toxic compounds through inhalation
          if a pollutant downdraft exists
     o    Heat stress around hot sources
     o    Climbing hazards because of the cumbersomeness of the portable
          instruments and accessories.
The most important of the safety problems is the  possibility of falls  through
weak roofs.  Structural problems in portions of roofs are very common  and it
is often difficult to spot the weak areas.   Agency inspectors must exercise
extreme caution when walking across or working on roofs.  Unfortunately, walk-
ing across the roofs is the only way to read most of the vents and roof moni-
tors.  The second major problem is the sudden exposure to high concentrations
of potentially toxic organic compounds.  Exposure can occur before the in-
spector can put on the respirator and the organic vapor concentrations can
greatly exceed the allowable limits of the respirator.  The problem is further
compounded by the fact that some of the organic compounds are skin- and eye-
absorbable, thus limiting the help provided by a  respirator.
     Based on the potential instrument damage, the uncertainties of instrument
response, the variability of pollutant emissions, and the possible safety
hazards, extreme care should be exercised in conducting these type of  surveys.
Obviously, if unsafe conditions exist with respect to these type of surveys
they should not be conducted.
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                                 REFERENCES
 1.  U.S. Environmental Protection Agency.   Summary of Available Portable VOC
     Detection Instruments.   EPA-340/1-80-010,  1980.

 2.  U.S. Environmental Protection Agency.   Evaluation of Potential  VOC Screen-
     ing Instruments.  EPA-600/7-82-063, 1982.

 3.  Temperature Measurement Handbook and Enclyclopedia,  1985.   Omega Engineer-
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 4.  Jorgensen, R., Ed.  Fan Engineering.  Buffalo Forge  Co., Buffalo, New
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 5.  Brown, G. E., et al.  Project Summary Response Factors of VOC Analyzers
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 6.  Dubose, D. A., and G. E. Harris.  Project Summary.  Response Factors of
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 7.  Dubose, 0. A., G. E. Brown,  and G. E.  Harris.  Response of Portable VOC
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 9.  Analytical Instrument Development, Inc.   PID - Different lonization
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10.  Analytical Instrument Development, Inc.   Design and  Characteristics of a
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11.  Ressl, R. A., and T. C. Ponder, Jr.  Field Experience With Four Portable
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     tract No.•'68-02-3767.  December 1984.
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 12.  Brooks, J. C.  Excerpts of Some of the Articles and Sections of the
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 13.  Michaels, E. C.  Defining the Limits of Hazardous (Classified) Locations
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 19.  Personal communication from N. Davis, Foxboro Corp., to J.  Richards,
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25.  Wetherold, R., and L. Provost.  Emission Factors and Frequency of Leak
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     March 1980.

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 27.   Personal communication from R. Sevalo, HNU Systems,  Inc.,  to  J.  Richards,
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 28.   HNU Systems  Inc.  Model PI-101 Photoionization Analyzer, Price  List.
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 29.   Personal communication from N. Davis, Foxboro Corp., to J.  Richards,
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 30.   Scott Environmental Technology, Inc.  Scott Specialty Gases.  1985.

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 33.   Personal communication from A. Smith, Bacharach,  Inc., to  J.  Richards,
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 34.   Omega Engineering,  Inc.  1983  Complete Temperature Measurement  Handbook.
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 35.   Personal communication from R. Stroup, Nutech Corp., to J.  Richards,
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 36.   Cole-Parmer  Instrument Company.  1985-86 Cole-Parmer Catalog.   1985-1986.

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 38.   Personal •communication from J. Washle, Analytical  Instrument  Development,
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 39.   Personal communication from R. Sevalo, HNU Systems,  Inc.,  to  J.  Richards,
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40.   Personal communication from N. Barker, Photovac,  Inc., to  J.  Richards,
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42.   U.S. Environmental  Protection  Agency.  Control of Volatile Organic Com-
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      Instruction  23-9613, Revision  1.   September 1982.
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44.  PEDCo Environmental,  Inc.  VOC Sampling and Analysis Workshop, Volume  II.
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46.  Richards, J., and R.  Segal!.  Air Pollution Source  Inspection Safety
     Procedures, Student Manual.  EPA-340/185-002a, September  1985.

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     Density Polyethylene  Process Unit.  EPA-600/2-81-109, June 1981.

50.  Morgester, J. J., et  al.  Control of Emissions From Leaking Valves and
     Flanges at Oil Refineries.  California Air Resources Board Publication.
     November 15,  1978.

51.  Uetherold, R. G., L.  P. Provost, and C. D. Smith.   Assessment of
     Atmospheric Emissions From Petroleum Refining:  Volume 3, Appendix B.
     EPA-600/2-80-075c, April 1980.

52.  Hustvedt, K.  C., et al.  Control of Volatile Organic Compound Leaks From
     Petroleum Refinery Equipment.  EPA-450/2-78-036, June 1978.

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

54.  Williamson, A. M.  Valves - A Possible Source of Fugitive Emissions in
     Hydrocarbon Processes.  In:  Proceedings of Symposium/Workshop on
     Petroleum Refining Emissions.  EPA-600/2-78-199, September 1978.

55.  U.S. Environmental Protection Agency.  Control of Volatile Organic
     Compound Leaks From Synthetic Organic Chemical and  Polymer Manufacturing
     Equipment, Guideline  Series.  EPA-450/3-83-006, March 1984.

56.  Weber, R., and K. Mims.  Project Summary.  Evaluation of  the Walkthrough
     Survey Method for Detection of Volatile Organic Compound  Leaks.  EPA-
     600/S2-81-073, July 1981.

57.  Langley, G. J., et al.  Analysis of SOCMI VOC Fugitive Emissions Data.
     EPA-600/2-81-111, June 1981.
                                     78

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58.  Langley, G. J., and R. 6. Wetherold.  Project Summary.  Evaluation of
     Maintenance for Fugitive VOC Emissions Control.  EPA-600/S2-81-080,
     July 1981.

59.  Labadie, G. P.  Fugitive Hydrocarbon Emission Control at Chevron U.S.A.'s
     El Segundo Refinery.   Presented at the Americal Petroleum Institute
     Operating Practice Committee, Subcommittee on Facilities and Maintenance,
     San Francisco, California, May 14, 1979.

60.  Michaelis, T.  B.   Techniques to Detect Failure on Carbon Adsorption
     Systems.  EPA-340/1-80-011, April  1980.

61.  Personal communication from T.  Michaelis, Michaelis and Associates, Inc.,
     and J.  Richards,  Richards Engineering, December 9, 1985.
                                    79

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         APPENDIX A

REFERENCE METHOD 21 AND NSPS
   AND NESHAPS REGULATIONS
            80

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REFERENCE METHOD 21
        81

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  Method 21. Determination of Volatile Organic
           -  -   -
    1. Applicability and Principle.
   1.1  Applicability This method ipphei to
 the determination of volatile organic
 compound (VOC) leaks from proem
 equipment. Theme lourcet include, but are not
 limned to. valvei. flanges and other
 connections, pumps snd compressors.
 pressure relief devices, process drains, open-
 ended valves, pump and compressor seal
 system degassing vents, accumulator  vessel
 venta. agitator seals, and access door seals.
   13  Principle. A portable instrument is
 used to detect VOC leaks from individual
 sources. The instrument detector type is not
 specified, but it must meet the specifications
 and performance en tens contained in Section
 3 A leak definition concentration based on a
 reference compound is specified in each
 applicable regulation. This procedure is
 intended to locale snd classify leaks only.
 snd is not to be used as a direct measure of
 mass emission rates from individual sources.
   2. Definitions.
   2.1  Leak Definition Concentration The
 local VOC concentration at the surface of a
 leak source thai  indicates thai a VOC
 emission (leak) is present The leak definition
 :s an instrument meter reading based  on a
 reference compound
   i2  Reference Compound. The VOC
 species selected aa an instrument calibration
 basis for specification of the leak definition
 concentration. (For example: If a leak
 definition concentration is 10400 ppmv as
 methane, then any source emission that
 results in a local concentration that yields a
 meter reading of 1OOOO on an instrument
 calibrated with methane would be classified
 •s a leak. In this example, the leak definition
 is 10.000 ppmv. and the reference compound
 is methane.)
  23  Calibration Cos. The VOC compound
 used to adjust the instrument meter reading
 to a known value. The calibration gas is
 usually the reference compound at a
 concentration approximately equal to  the
 leak definition concentration.
  2.4 No Detectable Emission. The local
 VOC concentration at the surface of a leak
 source that indicates that a VOC emission
 (leak) is not present Since background VOC
 concentrations may exist and to account for
 instrument drift and imperfect
 reproduability. a difference between the
 source surface concentration and the local
 ambient concentration is determined. A
 difference baaed on meter readings of lesa
 than a concentration corresponding to the
 minimum readability specification indicates
 that a VOC emission (leek) is not present
 (For example, if the leak definition in e
 regulation is 10400 ppmv. then the allowable
 increase m surface concentration versus local
 ambient concentration would be 500 ppmv
 based on the instrument meter readings.)
  23 Response Factor. The ratio of the
known concentration of a VOC compound to
the observed meter reading when measured
•sing an instrument calibrated with the
reference compound specified in the
application regulation.
  2.8 Calibration Precisian. The degree of
agreement between measurements of the
same known value, expressed as the relative
percentage of the average difference between
 the meter readings and the known
 concentration to the known concentration.
   2.7  Response Time. The time interval
 from a step change in VOC concentration at
 the input of the sampling system to the time
 at which 90 percent of the corresponding final
 value  is reached as displayed on the
 mstrumen'l readout meter.
   3. Apparatus
   3.1  Monitoring Instrument
   3.11  Specifications.
   a. The VOC instrument detector shall
 respond to the compounds being processed
 Detector types which may meet this
 requirement include, but are not limited to.
 catalytic oxidation, flame lomzation. infrared
 absorption, and photoionization.
   b. The instrument shall be capable of
 measunng the leak definition concentration
 specified in the regulation.
   c. The scale of the instrument meter shall
 be readable tozS percent of the specified lesk
 definition concentration.
   d. The instrument shall be equipped with a
 pump  so that s continuous sample is provided
 to the  detector. The nominal sample flow rate
 shall be to to 3 liters per minute.
   e. The instrument shall be intrinsically safe
 for operation in explosive atmospheres as
 defined by the applicable USA. standards
 |e.g.. National Electrical Code by the National
 FIR Prevention Association). 2 3
   3.23  Performance Criteria.
   a. The instrument response factors for the
 indttndal compounds to be measured must be
 less than 10.
   b. The instrument response time must be
 equal to or leas than 30 seconds. The
 response time must be determined for the
 instrument configuration to be used during
 testing.
   c. The calibration precision must be equal
 to or less than 10 percent of the calibration
 gas value.
   d. The evaluation procedure for each >
 parameter is given in Section 4.4.
   3.13 Performance Evaluation
 Requirements.
   a. A response factor must be determined
 far each compound that is to be measured.
 either by testing or from reference sources
 The response factor testa are required before
 placing the analyzer into service, but do not
 haw to be repeated aa subsequent intervals
   b. The calibration precision last must be
 completed prior to placing the analyzer into
 service, and at subsequent 3-month intervals
 or at the next use whichever is later.
   c. The response time test is required pnor
 to placing the instrument into service. If a
 modification to the sample pumping system
 or flow configuration is made that would
 change the response time, a new test is
 required pnor to further use.
  33   Calibration Gates. The monitoring
 instrument is calibrated in terns of parts per
million by volume (ppmv) of the reference
rnmpound specified in the applicable
 regulation. The calibration gases required for
 monitoring and instrument performance
 •valuation are a sera gaa (air. lesa than 10
ppmv VOC) and a calibration gas in air
 mixture approximately equal to the leak
definition specified in the regulation. If
cylinder calibration gas mixture are used, they
must be analyzed and certified by the
 manufacturer to be within ±2 oercent
 accuracy, and a shelf life must be specified.
 Cylinder standards must be either reanalyzed
 or replaced at the end of the specified shelf
 life. Alternately, calibration gases may be
 prepared by the user according to any
 accepted gaseous standards preparation
 procedure that will yield a mixture accurate
 to within £2 percent. Prepared standards
 must be replaced each day of use unless it
 can be demonstrated that degradation does
 not occur dunng storage.
  Calibrations may be performed using s
 compound other than the reference
 compound if a conversion factor is
 determined for that alternative compound so
 that the resulting meter reading! dunng
 source surveys can be convened to reference
 compound results 213
  4. Procedures
  4.1   Pretest Preparations Perform ike
 instrument evaluation procedures given in
 Section 4.4 if the evaluation requirements of
 Section 3.1 J have not been met.
  4.2   Calibration Procedures. Assemble and
 start up the VOC analyzer according to the
 manufacturer's instructions. After the
 sppropnate warmup period and zero internal
 calibration procedure, introduce the
 calibration gas into the instrument sample
 probe. Adjust the instrument meter readout to
 correspond to the calibration gas value.
  Note—If the meter readout cannot be
 adjusted to the proper value, a malfunction  of
 the analyzer is indicated and corrective
 actions are necessary before use.
  43   Individual Source Surveys.
  4J.1  Type I—Leak Definition Based on
 Concentration. Place  the probe inlet at the
 surface of the component interface where
 leakage could occur. Move the probe along
 the interface periphery while observing the
 instrument readout If an increased meter
 reading is observed, slowly sample the
 interface where leakage is indicated until the
 maximum meter reading ta obtained  Leave
 the probe inlet at this maximum reading
 jocatioa for approximately two times the
 instrument response tune. If the maximum
 observed meter reading is greater than the
 leak definition m the applicable regulation.
 record and report the results aa specified in
 the regulation reporting requirements.
 Examples of the application of this general
 technique to specific equipment types are:
  a. Valves—The most common source of
 leaks bom valves is at the seal between the
 stem and housing. Place the probe at the
 interface whan the stem exiats the packing
 gland and sample the stem circumference.
 Also, place the probe at the interface of the
 packing gland take-up flange seat and sample
 tb» periphery. In addition, survey valve
housings of multipart assembly at the surface
of all interfaces where • leak could occur. 213
  b. Flanges and Other Connections—For
welded flsngn. place the probe at the outer
edge of the flange-gasket interface and
sample the circumference of the flange.
Sample other types of nonpermaneni joints
(such as threaded connections) with a similar
traverse.
  c. Pusipa and Compreasors  Conduct a
circumferential traverse at the outer surface
of the pump or compressor shaft and seal
Interface. If the source is a rotating shaft.
position the probe inlet within l cm of the

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 •haft-Mil interface for the survey. If the
 housing configuration prevent* a complete
 traverse of the shaft periphery, sample all
 accessible portions. Sample all other |omu
 on the pump or compressor homing where
 leakage could occur.
   d. Pressure Relief Devices   The
 configuration of most pressure relief devices
 prevents sampling at the sealing seat
 interface. For those devices equipped with an
 enclosed extension, or horn, place the probe
 inlei at approximately the center of the
 exhaust area to the atmosphere.
   e. Process Drains—For open drams, place
 the probe inlet at approximately the center of
 the area open to the atmosphere. For covered
 drams, place the probe at the  surface of the
 cover interface and conduct a peripheral
 traverse.
   f. Open-Ended Lines or Valve*—Place the
 probe inlet at approximately the center of the
 opening to the atmosphere.
   g. Seal System Degassing Vents and
 Accumulator Vents—Place the probe inlet at
 approximate!) the center of the opening to
 the atmosphere
   h Access Door Seals—Place the probe inlet
 at the surface of the door seal interface and
 conduct a peripheral travel se.
   4 3 2  Type II—"No Detectable Emission ".
   Determine the local ambient concentration
 around the source by moving  the probe inlet
 randomly upwind and downwind at a
 distance of one to two meters from the
 source If an interference exists with this
 determination due to a nearby emission or
 leak, the local ambient concentration may be
 determined at distances closer to the source.
 but in no case shall the distance be less than
 25 centimeters. Then move the probe inlet to
 the surface of the source and determine the
 concentration described in 4 J.l. The
 difference between these concentrations
 determines whether there are  no detectable
 emissions. Record and report the results as
 specified by the regulation.
  For those cases where the regulation
 requires a specific device installation, or that
 specified vents be ducted or piped to a
 control device, the existence of these
 conditions shall be visually confirmed. When
 the regulation also requires that no
 detectable emissions exist visual
 observations and sampling surveys are
 required. Example* of this technique are:
  (a) Pump or Compressor Seals—If
 applicable, determine the type of shaft seal.
 Preform a  survey of the local area ambient
 VOC concentration and determine if
 detectable eausaions exist as described
 above.
  f» Seal System Degassing Vents.
 Accumulator Vessel Vents. Pressure Relief
 Devices .If applicable, observe whether or
not the applicable ducting or piping exists.
Also, determine if any sources exist m the
dueling «r piping where emissions could
occur prior to the control device. If the
required ducting or piping exists and there
ere no sources where the emissions could be
vented to the atmosphere poor to the control
device, then it is presumed that no detectable
•missions  are present. If there are sources in
 the ducting or piping where emissions could
 be vented or sources where leaks could
 occur, the  sampling surveys described in this
paragraph shall be used to determine if
delectable emissions exist
  4JJ  Alternative Screening Procedure A
screening procedure based on the formation
of bubbles in a soap solution that is sprayed
on a potential leak source may be used for
those sources that do not have continuously
moving parts, that do not have surface
temperatures greater than the boiling point or
less than the freezing point of the sosp
solution, that do not have open areas to the
atmosphere that the soap solution cannot
bndge. or that do not exhibit evidence of
liquid leakage. Sources that  have these
conditions present must be surveyed using
the instrument techniques of'4.31 or 4.3.2
  Spray s soap solution over sll  potential
leak sources. The soap solution may be a
commercially available leak detection
solution or may be prepared using
concentrated detergent and  water. A pressure
•prayer or a squeeze bottle may  be used to
dispense the solution. Observe the potential
leak sites to determine if any bubbles are
formed. If no bubbles are observed, the
source is presumed to have no detectable
emissions or leaks as applicable If ar.x
bubbles are observed,  the instrument
techniques of 4 31 or 4.3.2 shall be used to
determine if a leak exists, or if the source h*»
detectable emissions, as applicable. 213
  44 Instrument Evaluation Procedures. At
the beginning of the  instrument performance
evaluation test, assemble and start up the
instrument according to the  manufacturer's
instructions for recommended wannup penod
and preliminary adjustments.
  44.1 Response Fcciar. Calibrate the
instrument with the reference compound as
specified m the applicable regulation. For
each organic species that ia  to be measured
during individual source tur ays. obtain or
prepare a known standard in air at a
concentration of approximately 80 percent of
the applicable leak definition unless limited
by volatility or exploannty. In these cases.
prepare a standard it 90 percent of the
saturation concentration, or 70 percent of the
lower explosive limit, respectively. Introduce
this mixture to the analyzer and  record the
observed meter raiding. Introduce zero air
until a stable reading is obtained. Make a
total of three measurements by alternating
between the known  mixture and zero air
Calculate the response factor for each
repetition and the average response (actor.
  Alternatively, if response  factors have been
published for the compounds of interest for
the instrument or detector type, the response
factor determination is not required, and
existing results may be referenced. Examples
of published response  factors for flame
ionizatien and catalytic oxidation detectors
an included in Section 5.
  4.43 Calibration Precision. Make a total of
three measurements by alternately using zero
gaa and the specified calibration gas. Record
the meter readings. Calculate the avenge
algebraic difference between the meter
readings and the known value. Divide this
average difference by the known calibration
value and mutiply by 100 to express the
resulting calibration precision aa a
percentage.
   4.4J JUtperue Time. Introduce zero gi
 into the instrument sample probe. When
 meter reading baa stabilized, switch quic..?
 to the specified calibration gaa. Measure the
 tune from switching to when 80 percent o   e
 Anal stable reading is attained. Perform tl
 test sequence three bmes and record the
 results. Calculate the average response time.
  4 Bibliography.
  8.1 DuBata. DA., and C£ Hams,
 Response Facton af VOC Analyzers at a
 Meter Reading of 10.000 npmv for Selected
 Organic Compounds. US. Environmental
 Protection Agency. Research Triangle Perl
 N.C. Publication No. EPA 800/2-81-051.
 September IBM.
  SJ frown. ££. et oJ. Response Facton of
 VOC Analysers Calibrated with Methane:
 Selected Organic Compounds. Ui
 Environmental Protection Agency. Researc
Triangle Park. N.C Publication No. EPA MO/
a-n-OZZMayun.
  AJ DuBaem. DA. et el. Response of
 Portable VOC Analyzers to Chemical
 Mixtures, U.S. Environmental Protection
 Agency. Research Triangle Park, N.C
 Publication No. EPA BOO/2-n-iiO. Septeml
 ion.
                                                                  83

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NSPS REGULATIONS
       84

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     Sutpart W-Standvda of
     Perfonnanca for Equipment Laoka of
     VOC In the Synthttlc Organic
     Chenueala Manufacturing Industry

             AppHabflRy and tfnlgrutlen of
  the following aquation: Y-* 14—4X75
  log X. whan X to MB  adaa* the year of
                   230
      (a)(l) The provisions of this subpart
    apply to affected facilities in the
    synthetic organic chemicals
    manufacturing industry.
      (2) The group of all equipment
    (defined in J 60.461) within a process
    unit is an affected facility.
      (b) Any affected facility under
    paragraph (a) of this section that
    commences construction or modification
    after January 5.1981. shall be subject to
    the requirements of this subpart.
     (c) Addition or replacement of
    equipment for the purpose of process
    improvement which is accomplished
   without a capital expenditure shall not
   by itself be considered a modification
   under this subpart.
     (dJIl) If an owner or operator applies
   for one or more of the exemptions in this
   KELt1*™ we_owaer"operator
    (3) The applicable basic annual asset
  guideline repair allowance. R is selected
  from the following table consistent with
  the applicable subpart: »7

   TABU FON OTTERMMMC APPUCABU ton B
                                          ODD.
                                          006.
                                                                         IMS
                                   «*»
                                   1*5
                                   re
                                   44
     (2) Any affected facility that has the
   f !S!??,Ca,pldfy to P^wee less than
    (3) If an affected facility produces
  heavy liquid chemicals only from heavy
  liquid feed or raw materials, then it is
  exempt from f 60.482.
    (4) Any affected facility that produces
  beverage alcohol is exempt from

    (5) Any affected facility that has no
  equipment in VOC service is exempt
  from { 60.462.                   *
 I60.4S1  OMnmona.

 H-n!^??1 ta *f •,10Part- •I «erms not
 defined herein shall have the meaning
 given them in the Act or in Subpart A of
 nrt 60. and the following terms shall
 nave the specific meanings given them.
   -Capital expenditure" means, fa,
 addition to the definition m 40 CFR 60L2.
 an expenditure for a physical or
 operational change to an existing facility

  (a | Exceeds P. the product of the
 faolity-s replacement cost R. and an
adjusted annual asset guideline repair
allowance. A, as reflected by the
'""—'	: P - R x A, where
                 annual asset
   "Closed vent system" means a system
 that u not open to the atmosphere and
 that is composed of piping, connections.
 and. if necessary, flow inducing devices
 that transport gas or vapor from a piece
 or pieces of equipment to a control
 device.
   "Connector" means flanged, screwed.
 welded, or other joined fittings used to
 connect two pipe lines or s pipe line and
 a piece of process equipment
   "Control device" means an enclosed
 combustion device, vapor recovery
 system, or flare.
  -Distance piece" means an open or
 enclosed casing through which the
 piston rod travels, separating the
 compressor cylinder from the crankcase.
  "Double block and bleed system"

1SJ2!HL!^-••"•'•
                               lean
                        asae
guideline repair allowance. A. is the
product of the percent of the
replacement cost. Y. and the applicable
basic annual asset guideline repair
allowance. & as reflected by the
following equation: A  « Y x (B -r 100).
  (2) The percent Y is  determined from
   -Equipment" means each pump.
 compressor, pressure relief device.
 •amplmg connection system, open-
 ended valve or line, valve, and flange or
 other connector in VOC service andany
 devices or systems required by this
 aubpart                   *
   "First attempt at repair" means to
 take rapid action for the purpose of
 •topping or reducing leakage of organic
 material to atmosphere using best
 practices.
   "In gas/vapor service" means that the
 piece of equipment contains process
 fluid that is in the gaseous state at
 operating conditions.
  In heavy liquid service" means that
 tne piece of equipment is not in gas/
 vapor service or in light liquid service.
  "In tight liquid service" means that the

ESl!**!"1 «••»- •. «"* *»t
  any valve, except safety relief valves.
  having one aide of the valve seat m
  contact with process fluid and one side
  open to the atmosphere, either directly
  or through open piping.
    "Pressure release" means the
  emission of materials resulting from
  system pressure being grester than set
  pressure of the pressure relief device.
    "Process improvement" mesns routine
  changes made for safety and
  occupational health requirements, for
  energy savings, for better utility, for
  ease of maintenance and operation, for
  correction of design deficiencies, for
  bottleneck removal, for changing
  product requirements, or for
  environmental control.
   "Process unit" means components
  assembled to produce, as intermediate
  or final products, one or more of the
  chemicals listed in 160.489 of this part
 A process unit can operate
 independently If supplied with sufficient
 teed  or raw materials and sufficient
 •torage facilities for the product
   "Process unit shutdown" means s
 work practice or operational procedure
 that stops production from a process
 unit or part of a process unit An
 unscheduled work practice or
 operational procedure that stops
 production from a process unit or part of
 a process unit for less than 24 hours is
 not a process unit shutdown. The use of
 •pare equipment and technically
 feasible bypassing of equipment without
 stopping production are not process unit
 shutdowns.
  -Quarter" means a 3-month period
 tile first quarter concludes on the last
 day of the last full month during the 180
 days following initial startup.
  "Replacement cost" means the capital
 needed to purchase all the depreciable
components in a facility. "7
  "Repaired" means that equipment is
 adjusted or otherwise altered, in order
 to eliminate a leak as indicated by one
  ™Jwlowing: an instrument reading
or lOOOOppm or greater, indication of
liquids dripping, or indication by a
—war that a seal or!
    tmilmA
                                        "Liquids dripping" means any visible
                                      leakage from the seal including
                                      spraying, misting, clouding, and ice
                                      formation.
                                        "Open-ended valve or line" means
                                        "Sensor means a device that measures
                                      a physical quantity or the change in a
                                      physical quantity such as temperature.
                                      pressure, flow rate. pR or liquid level
                                         In-situ sampling systems" means
                                      nonextractive samplers or in-line
                                      samplers.
                                       -Synthetic organic chemicals
                                      manufacturing industry" means the
                                      industry that produces, as intermediates
                                      or final products, one or more of the
                                      chemicals listed in 180.489.
                                       "to vacuum service" means that
                                      equipment u operating at an internal

-------
pressure which is at lent 5 kilopascals
(kPa) below ambient pressure.
  "Volatile organic compounds" or VOC
means, for the purposes of this lubpan.
any reactive organic compounds at
defined in 160.2 Definitions.
  "In VOC Service" means that the
piece of equipment contains or contacts
a process fluid that is at leaat 10 percent
VOC by weight. (The provisions of
160.485(d) specify how to determine
that a piece of equipment is not in VOC
service.)

| •0.482-1  Standard*: General.
  (a) Each owner or operator subject to
the provisions of this subpart shall
demonstrate compliance with the
requirements of | 80.482-1 to 180.482-10
for all equipment within 180 days of
initial startup.
  (b) Compliance with 180.482-1 to
I 80.482-10 will be determined by
review of records and reports, review of
performance test results, and inspection
using the methods and procedures
specified in | 80.485.
  (c)(l) An owner or operator may
request a determination of equivalence
of a means of emission limitation to the
requirements of I 80.482-2, -3, -S. -«, -7.
-8. and -10 as provided in 180.484.
  (2) If the Administrator makes a
determination that a means of emission
limitation ia at least equivalent to the
requirements of f 60.482-2. -3. -8, -8. -7.
-8. or -10. an owner or operator shall
comply with the requirements of that
determination,
  (d) Equipment that is in vacuum   -
service is excluded from the
requirements of I 60.482-2 to 180.482-10
if it ia identified as required in
|oU488(e)(5).2"
I •0.482-2
Pumps kiigmsquM
  (•](!) Each pump in light liquid service
shall be monitored monthly to detect
teaks by the methods specified in
|60.486(b). except as provided in
180.482-Kc) and paragraphs (d). (e).
and (2) of this section.
  (2) Each pump in light liquid service
shall be checked by visual inspection
each calendar week for indications of
liquids dripping from the pump seal.
  (b)(l) If an instrument reading of
104)00 ppm or greater ia measured, a
leak ia detected.
  •(2) If there are indications of liquids
dripping from the pump seal a leak is
detected.
  (c)(l) When a leak is delected, it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
detected, except as provided in { 60.462-
9.
  (2) A first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
  (d) Each pump equipped with a dual
mechanical seal system thst include* s
barrier fluid system  is exempt from the
requirements of paragraph (a), provided
the following requirements are met:
  (1) Each dual mechanical seal system
is:
  (i) Operated with the barrier fluid at a
pressure that is at ail tunes greater than
the pump stuffing box pressure-, or
  (li) Equipment with s barrier fluid
degassing reservoir that is connected by
a dosed vent system to a control device
that complies with the requirements of
S 60.482-10: or
  (iii) Equipped with a system that
purees the barrier fluid into a process
stream with zero VOC emissions to the
atmosphere.
  (2) The barrier fluid system is in
heavy liquid service or is not in VOC
service.
  (3) Each barrier fluid system is
  luipped with a sensor that  will detect
   '.ure of the seal system, the barrier
uuid system, or both.
  (4) Each pump is checked by visual
inspection^ each calendar week, for
indications of liquids dripping from the
pump trilti
  (5)(i) Each sensor as described in
paragraph (d)(3) ia checked daily or is
equipped with an audible alarm, and
  (iij The owner or operator determines.
based on design considerations and
operating experience, a criterion that
indicates failure of the seal system, the
barrier fluid system, or both.
  |6)(i] If there are indications of liquids
dripping from the pump seal or the
sensor indicates failure of the seal
system, the barrier fluid system, or both
based on the criterion determined m
paragraph fd)(5)fii). a leak is detected.
  (ii) When a leak is detected. H shall be
repaired as soon as  practicable, but not
later than IS calendar days after it ia
detected except ea provided in 160.482-
9.
  (iii) A first attempt at repair shell be
made no later then 5 calendar days after
each leak is detected.
  |e) Any pump mat is designated, as
described hi | ao.4B8(e) (1) and (2). for
no detectable emission, as indicated by
an instrument reading of less than 500
ppm above background, is exempt from
the requirements of paragraphs (a),  (c).
and (d) if the pump:
  (1) Has no externally actuated shaft
penetrating the pump housing.
  (2) Is demonstrated to be operating
with no detectable emissions as
indicated by an instrument reading  of
less than 500 ppm above background as
measured by the methods specified in
180.485(c). and
  (3) Is tested for compliance with
paragraph (eH2J initially upon
designation, annually, and at other nines
requested by the Administrator
  (0 If any pump-is equipped with s
dosed vent system capable of capturing
and transporting any leakage from the
seal or seals to a control device that
complies with the requirements of
i 80.482-10. it is exempt from the
paragraphs (aHe).

f 80.482.3 Compressors.
  (a) Each compressor shall be equipped
with a seal system that include* a
bamer fluid system and that prevents
leakage of VOC to the atmosphere.
except as provided in 160.482-l(c) and
paragraph (b) and (i) of this section.
  (b) Each compressor seal system as
required in paragraph (a) shall be:
  (1) Operated with the  bamer fluid at a
pressure that is greater than the
compressor stuffing box pressure: or
  (2) Equipped with a bamer fluid
system that is connected by a dosed
vent system to a control device that
complies with the requirements of
160.482-10: or
  (3) Equipped with a system that
purges the barrier fluid into a process
stream with are VOC emissions to the
atmosphere.
  (c) The barrier fluid system shall be in
heavy liquid service or shall not be in
VOC service.
  (d) Each barrier fluid system as
described in paragraph (a) shall be
equipped with a sensor  that will detect
failure of the seal system, bamer fluid
system, or both.
  (e)(l) Each sensor es required in
paragraph (d) shall be checked daily or
shall be equipped with an audible alarm.
  (2) The owner or operator shall
determine, based on design
considerations and operating
experience, a criterion that indicates
failure of the seal system, the barrier
fluid system, or bow.
  (0 If the sensor indicates failure of the
seal system, the barrier system, or both
based on the criterion determined under
polygraph (e)(2). a leak is detected
  (g)(ll When a leak is detected it shall
be repaired as soon aa practicable, but
not later than 15 calendar days after it is
detected except as provided in 180.482-
9.
  (2) A Tint attempt at repair shall be
made no later than S calendar days after
each leak is detected
  (h) A compressor is exempt from the
requirements of paragraphs (a) and (bj.
if it i* equipped with a dosed vent
system capable of capturing and
transporting any leakage from the seal
                                                        86

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 to • central device that complies with
 the requirementi of 160.482-10. except
 •• provided in ft 60.482-3[i).
   (i) Any compressor that is designated.
 as described in i 60.486(e) (1) And (2).
 for no detectable emissions, as indicated
 by an instrument reading of leas than
 500 ppm above background, is exempt
 from the requirements of paragraphs
 (aHh) if the compressor
'  (l) Is demonstrated to be operating
 with no detectable emissions, as
 indicated by an instrument reading of
 less than 500 ppm above background, as
 meesured by the methods specified in
 i 60.485(c). and
   (2) Is tested for compliance with
 paragraph (i)(l) initially upon
 designation, annually, and at other times
 requested by the Administrator.
   (]'} Any existing reciprocating
 compressor in a  process unit which
 becomes an affected facility under
 provisions of { 80.14 or 60.15 is exempt
 from i 60.482 (a), (b). (c). (d). (e). and (h).
 provided the owner or operator
 demonstrates that recasting the distance
 piece or replacing the compressor an
 the only options available to bring the
 compressor into compliance with the
 previsions of 180.4823 (a), (b). (c). (d).
 (e). and (h).

 §60.48*4
160.462-5
   (a] Except during pressure releases.
 each pressure relief device in gas/vapor
 service shall be operated with no
 detectable emissions, as indicated by an
 instrument reading of Ins than 500 ppm
 above background, as determined by the
 methods specified m | 60.48S(c).
   (bNl) After each pressure release, the
 pressure relief device shall be returned
 to a condition  of no detectable
 emissions, as indicated by an instrument
 reading of leas than SOD ppm above
 background, aa soon  as practicable, bat
 no later than 5 calendar days after die   •.
 pressure release, except aa provided in
 160.462-0.
  (2) No later than S calendar days after
 the pressure release,  the pressure relief
 device shall be monitored to confirm the
 conditions of no detectable emissions,
 as indicated by an instrument reading of
 leas than 500 ppm above background, by
 the methods specified in I B0.4BS(c).
  (c) Any pressure relief device that is
 equipped with a dosed vent system
 capable of capturing  and transporting
 leakage through the pressure-relief
 device to a control device as described
 in i 60.482-10  is exempted from the
 requirements of paragraphs (a) and (b].
  (a) Each sampling connection system
•hall be equipped with a closed purge
system or closed vent system, except as
provided in 160.482-l(c).
  '(b) Each closed purge system or
closed vent system as required in
paragraph (a) shall:
  (1) Return the purged process Quid
directly to the process line with zero
VOC emissions to the atmosphere: or
  (2) Collect snd recycle the purged
process fluid with tero VOC emissions
to the atmosphere: or
  (3) Be designed and operated to
capture and transport all the purged
process Quid to a control device that
complies with the requirements of
160.482-10.
  (c) In-sita sampling systems are
exempt from paragraphs (a) and (b).

110.4824
  (a](l) Each open-ended valve or line
•hall be equipped with a cap. blind
flange, plug, or a second valve, except
as provided in 160.482-l(c).
  (2) Hie cap. blind flange, plug, or
second valve shall seal the open end at
•II H^p^f except during operations
requiring process fluid flow through the
open-ended valve or line.
  (b) Each open-ended valve or line
•quipped with a second valve shall be
operated in a manner such that the
valve on the process fluid end is dosed
before the second valve is dosed.
  (c) When a double block-and-bleed
system is being used, the bleed valve 01
line may remain open during operations
that require venting the line between thf
block valves but shall comply with
paragraph (a) at all other times.237

faa.482-7
  (a) Each vahre shall bo monitored
monthly to detect leaks by the methods
specified in | 60.485{b) and shall comply
with paragraphs (bHe).* except ••
provided in paragraphs (f). (g). and (h).
i 00.483-1.2, and | 60.48Z-KC).
  (b) If an instrument reading of 1OOOO
ppm or greater is measured, a leak is
detected.
  (c«l) Any valve for which a leak to
BOI G0ICCted IDT 2 mCC0MlVff BOBtltS
may be monitored the first month of
every quarter, beginning with the next
quarter, until a leak to detected.
  (2) If a leak to detected the valve shall
be monitored monthly until s leak is not
detected for 2 successive months.337
  (d](l) When s leak to detected, it shall
be repaired as soon as practicable, but
no later than 15 calendar days after the
lesk is detected except as provided in
| 80.482-*.
  (2) A first attempt at repair shall be
made no later than 5 calendar days after
each leak to detected
  (e) First attempts at repair include, but
an not limited to. the following best
practices when practicable:
  (1) Tightening of bonnet bolts:
  (2) Replacement of bonnet bolts:
  (3) Tightening of packing gland nuts:
  (4) Injection of lubricant into
lubricated packing.
  (f) Any valve that to designated as
described in 160.486(e)(2). for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background to exempt from the
requirements of paragraph (a) if the
valve:
  (1) Has no external actuating
mechanism in contact with the process
fluid.
  (2) to operated with emissions less
than 500 ppm above background as
determined by the method specified in
160.48S(c). and
  (3) b tested for compliance with
paragraph (!)(2) initially upon
designation, annually, and at other tunes
requested by the Administrator.
  (g) Any valve that to designated aa
described in 160.486(0(1), as an unsafe-
to-monitor valve to exempt from the
requirements of paragraph (a) if:
  (1) The owner or operator of the valve
demonstrates that the valve to unsafe to
monitor because monitoring personnel
would be exposed to an immediate
danger aa a consequence of complying
with paragraph (a), and
  (2) The owner or operator of the valve
adheres to a written plan that requires
monitoring of the valve as frequently aa
practicable during safe-to-monitor times.
  (h) Any valve that to designated as
described ia 160.486(0(2). as a difficult-
to-monitor valve to exempt from the
requirements of paragraph (a) it
. (l)Tha owner or operator of the valve
demonstrates that the valve cannot be
monitored without devoting the
monitoring personnel mon than 2
outers above a support surface.
  (2| The preens unit within which thr
valve is located either becomes an
affected facility through f 60.14 or
I 60.15 or the owner or operator
designates less than 3.0 percent of the
total number of valves as difficult-to-
monitor, andM7
  (3) The owner or operator of the valve
follows a written plan that requires
monitoring of the valve at least once per
calendar year.
                                                         87

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       > m Bom BquM or heavy IquW
       i and fiancee and otnor connectors.
   (a) Pumps and valves in heavy liquid
 service, pressure relief devices in light
 liquid or heavy liquid service, and
 flanges and other connectors shall be
 monitored within 5 days by the method
 specified in 180.4850)) if evidence of a
 potential leak is found by visual
 audible, olfactory, or any other
 detection method.
   0>) If an instrument reading of 10.000
 ppm or greater is measured, s leak is
 detected.
   (c)(l) When a leak is detected it shall
 be repaired as soon as practicable, but
 not later than 15 calendar days after it is
 detected except as provided  in
 I 60.482-9.
   (2) The first attempt at repair shall he
 made no later than 5 calendar days after
 each leak is detected
   (d) First attempts at repair  include.
 but are not limited to. the best practice*
 described under 180.482-7(e).

 | ao.48V0  Standards: Delay of repair.
   (a) Delay of repair of equipment for
 which leaks have been detected will be
 allowed if the repair is technically
 mfeasible without a process unit
 ahutdown. Repair of this equipment  .
 •hall occur before the end of the next
 process unit shutdown.
  (b) Delay of repair of equipment will
 be allowed for equipment which is
 isolated from the process and which
 does not remain in VOC service.
 • (c] Delay of repair for valves will be
 allowed if:
  (1) The owner or operator
 demonsttates that emissions of pursed
 material resulting from immediate repair
 are greater than the fugitive emission*
 likely to result from delay of repair, and
  (2) When repair procedures are
 effected the purged material is collected
 and destroyed or recovered in e control
 device complying with 180.482-10.
  (d) Delay of repair for pumps will be
allowed if:
  (1) Repair requires the use of a dual
mechanical seal system that includes a
barrier fluid system, and
  (2) Repair is completed as soon a*
practicable, but not later than 8 months
after the leak was detected
  (e) Delay of repair beyond a process
unit shutdown will be allowed for a
valve, if valve assembly replacement is
necessary during the process  unit
shutdown, valve assembly supplies have
been depleted, and valve assembly
supplies had been sufficiently stocked
 before the supplies were depleted. Delay
of repair beyond tne next process umt
shutdown will not be allowed unless the
next process unit shutdown occurs
sooner than 6 months after the first
process unit shutdown.
f«L4M-10  BtandardK Ooood vMrt
vyvttfnt MM oooooi owtcm»
  (a) Owners or operators of dosed vent
systems and control devices used to
comply with provisions of this subpart
shall comply with the provisions of this
section.
  (b) Vapor recovery systems (for
example, condensers and adsorbers)
shall be designed and operated to
recover the VOC emissions vented to
them with an efficiency of 95 percent or
greater.
  (c) Enclosed combustion devices shall
be designed and operated to reduce the
VOC emissions  vented to them with an
efficiency of 95 percent or greater, or to
provide a minimum residence time of
0.75 seconds at a mmimmn temperature
ofne'C.
  (d)(l) Flares shall be designed for and
operated with no visible emissions as
determined by the methods specified in
160.4B5(g). except for periods not to
exceed a total of 5 minifies during any 2
consecutive hours.
  (2) Flares shall b* operated with a
flame present at all times, as determined
by the methods specified in I BUBSfe).
  (3) Flares shall be used only with the
net heating value of the gas being
combusted being 11.2 MJ/sem (300 Btu/
scf) or greater if the flare is steam-
assisted or air-assisted: or with the net
heating value of the gas being
combusted being 7.45 M)/scm or greater
if the flare is nonassisted. The net
heating value of the gaa being
combusted shall be determined by the
methods specified in | 80.485(g).
  (4) Steam-assisted and nonasaiated
flares shall be designed for "f4
operated with an exit velocity, aa
determined by the methods specified in
160.48S(8)(4). leas than 18 m/sec (80 ft/
sec).
  (5) Flares used to comply with this
subpart shall be steam-assisted, air*
assisted, or aonassisted.
  (6) Air-assisted flares shall be
designed and operated with an exit
velocity leas than the velocity. V.^. as
determined by the methods specified in
|60.48S(g)(5).
  (e) Owners or operators of control
devices used to  comply with the
provisions of this subpart shall monitor
these control devices to ensure that they
are operated and maintained in
eonformance with their designs.
  (f)(l) Closed vent systems shall be
designed and operated with no
detectable emissions, as  indicated by an
instrument reading of less than 500 ppm
above background and visual
inspection*, as determined by the
methods specified in | a0.4B5(c).
  (2) Closed vent systems shall be
monitored to determine compliance with
this section initially in accordance with
I 80.8. annually and at other times
requested by the Administrator.
  (g) Closed vent systems and control
devices used to comply with provisions
of this subpart shall be operated at all
times when emissions may be vented to
them.
I60.4U.1
               percentage of
  (a) An owner or operator may elect to
comply with an allowable percentage of
valves leaking of equal to or Iesa4han
2.0 percent
  (b) The following requirements shall
be met if an owner or operator wishes to
comply with an allowable percentage of
valves leaking;
  (1) An owner or operator must notify
the Administrator that the owner or
operator has elected to comply with the
allowable percentage of valves leaking
before implementing this alternative
standard, as specified in 180.487(b).
  (2) A performance test as specified In
paragraph (c)  of this section shall be
conducted initially upon designation.
annually, and at other times requested .
by the Administrator.
  (3) If a valve leak is detected, it shaQ
be repaired in accordance with 180.482-
7(d)and(e).
  (c) Performance tests ahall be
conducted in the following manner
  (1) AH valves m gas/vapor and light
liquid service within the affected facility
•ball be monitored  within 1 week by the
methods specified In 180.4850)).
  (2) If an instrument reading of 1OOOO
ppm or greater ia measured, a leak is
detected.
  (3) The leak percentage ahaQ be
determined by dividing the number of
valves for which leaks are detected by
the number of valve* in gaa/vapor and
light liquid service  within the affected
facility.
   (d) Owners and operators who elect
to comply with this alternative standard
shall not have an affected facility with a
leak percentage greater than 10 percent.

180.489-2 Alternate standards lor
  (a)(l) An owner or operator may elect
to comply with one of the alternative
work practices specified in paragraphs
(b) (2) and (3) of this section.
  (2) An owner or operator must notify
the Administrator before implementing
                88

-------
 one of the alternative work practices, aa
 specified in 160.487(b).
   (b)(1) Aa owner or operator shall
 comply initially with the requirements
 for valves in gas/vapor service and
 valves in light liquid service, as
 described in I 60.482-7.
   (2) After 2 consecutive quarterly leak
 detection periods with the percent of
 valves leaking equal to or less than ZA
 an owneur operator may begin to skip
 1 of the quarterly leak detection periods
 for the vslves in gai/vapor and light
 liquid service.
   (3) After 5 consecutive quarterly leak
 detection penods with the percent of
 valves leaking equal to or less than 2.0.
 an owner or operator may begin to skip
 3 of the quarterly leak detection periods
 for the valves in gas/vapor and light
 liquid service.
   (4) If the percent of valves leaking  is
 greater than ID, the owner or operator
 shall comply with the requirements as
 described in 160.482-7 but can again
 elect to use this section.
   (S) Hie percent of valves leaking shall
 be determined by dividing the sum of
 valves found leaking during current  .
 monitoring and valves for which repair
 has been delayed by the total number of
 valves subject to the requirements of
 100.483-2.
   (6) An owner or operator must keep a
 ncoid of the percent of valves found
 leaking during each leak detection
 period.

         IqyWenceqfmeemol

   (a) Each owner or operator subject to
 the provisions of this subpart may apply
 to the Administrator for determination
 of equivalence for any means of
 emission limitation that achieves a
 reduction in emissions of VOC at least
 equivalent to the reduction in emissions
 of VOC achieved by the controls
 required in this subpert.
   |b) Determination of equivalence to
 the equipment design, and operational
 requirements of this sabpart will be
 evaluated by the following guidelines:
   (1) Each owner or operator applying
 for an equivalence determination shall
 be responsible for collecting and
 verifying teat data to demonstrate
 equivalence of *****'*• of emission
 limitation.
   (2) The Administrator wiD compare
-test data for the means of emission
 limitation to test data for the equipment
 design, and operational requirements.
   (3) The Administrator may condition
 the approval  of equivalence on
 requirements that may be necessary to
 assure operation and maintenance to
 achieve the same emission reduction as
the equipment design, and operational
requirements.
  (c) Determination of equivalence to
the required work practices in this
•ubpart will be evaluated by the
following guidelines:
  (1) Each owner or operator applying
for a determination of equivalence shall
be responsible for collecting and
verifying test data to demonstrate
equivalence of an equivalent means of
emission limitation.
  (2) For each affected facility for which
a determination of equivalence is
requested the emission reduction
achieved by the reqsiied work practice
shall be demonstrated
  (3) For each affected faculty, far
which e delenranstion of equivalence is
requested, me emission reduction
achieved by the equivalent means of
emission hmitation shall be
demonsfrateo.
  (4) Each owner or operator applying
for s determination of equivalence shall
commit in writing to work practices)
thai provide for emiasioa redactions
equal to or greater than the enasion
reductions achieved by the required
work practice.
  (S) The Administrator wffl eompare
the demonstrated emission redaction for
the equivalent means of emission
limitation to the demoosOjBted suasion
reduction for the required work
practices ***** wiQ consider tht
commitment in paragraph (c)(4).
  (8) The Administrator may condition
the approval of equivalence on
requirements that may be necessary to
assure operation end maintenance to
achieve the same
the required wo
   redactionu
  (d)An
itormayoffcra
                determination of equivalence far any
                equivalent means of emission lirailatic
                that achieves a reduction in rmiiiimts
                VOC achieved by me equipment, design.
                and operational requirements of (his
                subpan.
                  (2] The Administrator will make an
                equivalence determination according to
                the previsions of paragraphs (H (c). [d%
                and (e).
                faa.415  Taoti
                  (a) Each owner or operator subject to
                the provisions of this subpsrt shall
                comply with the test method and
                procedure requirements provided in thi*
                section.
                  (b) Monitoring, as required in
                U 00.482, 60.463, and 60.464. shall
                comply •««« (be following reqaremeatr
                  (1) Monitoring shall comply with
                Reference Method 21.
                  (2) The detection uistoameat shefl
                meet the performance criteria of
                Reference Method ZL
                  (3) The instrument shall be calibrated
                before use on each day of its use by the
                methods specified B Method 2L
                  (4) Calibration gaaes shall be
                  (Q Zero air (loss than 10 ppm of
                hydrocarbon in airfc and
                  (ii) A mixture of methane or n-hexaoe
                and air at a concentration of
                approximately, but less than. 10*000 ppm
                methane or n-ht
equivalence of any equivalent i
emission limitation.
  (e)(l) After a request for
determination of equivalence to
received the Administrator will pubBsh
a notice in the Federal Register and
provide  me opportunity for public
hearing if the Administrator fudges that
the request may be approved
  (2) After notice and eppomoirf for
public hearing, the Administrator will
determine the equtveleece of a ••••• of
emission limitation end will piMish thr
determination in the Federal Register.
  (3) Any equivalent means of emierion
limitations approved eoder this section
shall constitute a required work
practice, equipment, design, or
operational standard within ^¥P ^fv^^s.
of Section lll(h]|l) of the Clean Air Act
  (f)(l) Manufacturers of equipment
used to control equipment leaks of VOC
may apply to the Administrator for
  (5] The instrument probe snaD be
traversed around aO potential leak
interfaces aa dose to the interface as
possible as described In Reference
Method n.
  (c) When equipment is tested for
compliance with no delectable
emissions aa required in 1 60.482 -gfe). -
3(1). -4. -Tff). and -10(eX the test snail
comply wift the following requirementa:
  (1) The requirements of paragraphs
(b)(lH4)ibaH apply.
  (2) The background level shall be
                            89 tWI IQTtD IB KClC
                 Method a.
                   (3) The instrument probe ahaO be
                 traversed around aD potential leak
                 interfaces as dose to fee Interface as
                 possible; aa described m Reference
                 Method a.
                   (4) The arithmetic difference between

                 by the instrument end ttic background
                 level U
              vdwttnSOOppmfor
                                  of equipment within
                 a process unit is presumed to be in VOC
                 service unless an owner or operator
                 demonstrates that the piece of
                 equipment is not in VOC service. Fore
                 piece of equipment to be considered not
                 in VOC service, it must be determined
                 that the percent VOC content can be
                 reasonably expected never to exceed 10
                 percent by weight For porpoaes of
                                                      80

-------
  determining the percent VOC content in
  the process fluid that is g""t*"««j in or
  contacts equipment procedure, that
  conform to the general method.
  described in ASTM S-OO, 8-186. E-169
  (incorporated by reference aa specified
  in i 80.17) shall be used.
    (2) If an owner or operator decides to
  exclude non-reactive organic
  compounds from thu total quantity of
  organic oomnoaada in determining the
  percent VOC content  of the process
  fluid, the exdonoB will be allowed if
    (i) Those eabatances excluded are
  those considered as having negligible
  photochemical reactivity by the
  Administrator and
    (ii) The owner or operator
  demonstrates that the percent organic
  content excluding non-reactive organic
  compounds, can be reasonably expected
  never to exceed 10 percent by weight
    (3)(i) An owner or operator may use
  engineering judgment rather than the
  procedure, in paragraphs (d) (1) and (2)
  of this section to demonstrate mat the
  percent VOC content does not exceed 10
  percent by weight provided thai the
  engineering judgment demonstrates that
  the VOC content clearly does not
  txceed 10 percent by weight When an
  owner or operator and the
  Administrator do not agree on whether
  a piece of eqnpment la not In VOC
  service, however, the procedures in
  paragraphs (d) (12 and (2) shall be used
  to resolve the disagreement
   (if) ff an owner or operator determines
  that a piece of equipment ia in VOC   .
 service, the determination can be
 revised only after following the
 procedures in paragraphs (d) (1) and (2).
   (a) Equipment is in light liquid aeraee
 if the fouowmg conditions apply:
  (1) The vapor pressure of one or more
 of the components la greater than OJ
 kPa at 20" C Vapor pressures may be
 obtained from standard reference texts
 or may be determined by ASTM 0-2879
 (incorporated by reference as specified
 in 160.17).
  (2) The total concentration of She pure
 components having a vapor pressure
greater than OJkPa at arc is equal to
or greater than 20 percent by we^be
 md
  (3) The fluid is a liquid at operating
conditions.
  (f) Samples used in conjunction with
 paragraphs (d). (e). and (g) shall be
 vpresentathre of the process fluid that
is contained in  or contacts the. •
•quipment or the gas being combusted
 a the flare.
  (g)U| Reference Method 22 shall be
used to determine the compliance of
  flares with the visible emission
  provisions of this tubpart
    (2) The presence of a flan pilot flame
  shall be monitored using a thermocouple
  or any other equivalent device to delect
  the presence of a flame.
    (3) The net heating valoe of the gas
  being combusted in a Bare shall be
  calculated using the following equation:
 Where.
 HT * Net nesting value of the umple. MJ/
     •cm: whire the net enthalpy per mole of
     offga. u baud on combiution at 25'C
     •nd TOO mm H«. but the .landard
     temperature for determining the volume
     cormpondini to one mole u 20*.   ' •
      K«Coiutint.
      1.740 > 10'
 where
 C,- Concentration of umple component i u
    ppm. M measured by Reference Method
    M and ASTM 02304-67 (reapproved
    19H) (incoiporaied by reference as
    ipearwd in 1 80,17).
 H-Net heat of combustion of umple
    component i. kcal/t mole. Tne heat, of
    combiution may be determined using
    ASTM 02382-75 (incorporated by
    reference as specified in 1 80.17) if
    published values are not available or
    cannot be calculated.

  (4) The actual exit velocity of a flare
 shall be determined by dividing the
 volumetric flowrate (in units of standard
 temperature and pressure), as
 determined by Reference Method i 2A.
 2C or 20 as appropriate: by the
 unobstructed (free) cross sectional area
 of the flare tip.
  fS) The maximum permitted velocity.
 VM. for sir-assisted flares shall be
 determined by the following equation:
VM. . Maximum permitted velocity, m/eec
8 706« Constant.
0.70M» Constant.
HT * The net heating value u determined in
    paragraph (g||4).
(Srt 114 of the dean Air Act a. amended (42
U3C 7414)1
|80.48<
  («)(!) Each owner or operator subject
to the provisions of this subpan shall
compK with the recordkeeping
requirements of this section.
  (2) An owner or operator of more than
one affected facility subiect to the
pro\ isions of this subpart may comply
with the recordkeeping requirements for
 these facilities in one recordkeeping
 system if the system identifiei each
 record by each facility.
   (b) When each leak is detected as
 specified in 160.482-2. -3. -7. •& and
 f 60.483-2. the following requirements
 apply:
   (1) A weatherproof and readily visible
 identification, marked with the
 equipment identification number, shall
 be attached to the leaking equipment
   (2) The identification on a valve may
 be removed after it has been monitored
 for 2 successive months a. specified in
 100.462-7(0) and no leak has been
 detected during those 2 months.
   (3) The identification on equipment
 except on a valve, mey be removed after
 it has been repaired.
   (c) When each leak is detected as
 specified in i 60.482-2, -3. -7.4. and
 160.483-2. the following information
 shall be recorded in a log and shall be
 kept for 2 years in a readily accessible
 location:
   (1) The instrument and operator
 identification number, and the
 equipment identification number.
   (2) The date the leak was  detected
 and the dates of each attempt to repair
 the leak.
   (3) Repair methods applied in each
 attempt to repair the leak.
   (4) -Above 10000" if the maximum
 instrument reading measured by the
 methods specified in 160.4BS(a) after
 each repair attempt is equal to or greater
 than 10,000 ppm.
   (5) "Repair delayed" and the reason
 for the delay if a leak is not repaired
 within 15 calendar days after discovery
 of the leak.
   (6) The signature of the owner or
 operator (or designate) whose decision
 it wes that repair could not be effected
 without a process shutdown.
  (7) The expected date of successful
 npair of the leak if a leak u not
 repaired within 15 days.
  (8) Dates of process unit shutdown
 that occur while the equipment is
 unrepaired.
  (9) The date of successful repair of the
 leak.
  (d) The following information
 pertaining to the design requirements for
 closed vent systems and control devices
described in i 60.482.10 shall be
 recorded and kept in a readily
 accessible location:
  (1) Detailed schematics, design
 specifications, and piping and
 instrumentation diagrams.
  (2) The dates and descriptions of any
changes in the design specifications.
  (3) A description of the parameter or
parameters monitored, as required in
 i 60 482-lO(e). to ensure that control
devices are operated and maintained in

-------
 conformance withjheir design and an
 explanation of why that parameter (or
 parameters) was selected for the
 monitoring.
   (4) Periods when the dosed vent
 systems and control devices required in
 160.482-2. -3. -4. and -5 an not operated
 as designed, including penods when a
 flare pilot light does not have a flame.
   (5) Dates of startups and shutdowns of
 the closed" vent systems and control
 devices required in | 60.482-2. -3. -4. and
 -5.
  . (e) The following information
 pertaining to all equipment subject to
 the requirements in | 60.482-1 to -10
 shall be recorded in a log that is kept in
 a readily accessible location:
  (1) A list of identification numbers for
 equipment subject to the requirements
 of this subpan.
  (2)(i) A list of identification numbers
for equipment that are designated for no
detectable emissions under the
provisions of 160.482-2(e). -3(i) and
    (ii) The designation of equipment as
  subject to the requirements of i 60.482-
  2(eJ. -3(1). or -7(f) shall be signed by the
  owner or operator.
    (3) A list of equipment identification
  numbers for pressure relief devices
  required to comply with 180.482-4.
    (4)(i) The dates of each compliance
  test as required in 8 60.482-2(6). -3(i). -4.
  and -7(f).
    (ii) The background level measured
  during each compliance test
   (iii) The maximum instrument reading
 measured at the equipment  during each
 compliance test
   (5) A list of identification numbers for
 equipment in vacua service.
   (f) The following information
 pertaining to all valves subject to the
 requirements of { 60.482-7 (g) and (h)
 shall be recorded in a log that is kepi in
 • readily accessible location:
  (1) A list of identification  numbers for
 valves that are designated as unsafe-to-
 monitor. an explanation for  each valve
 stating why the valve is unsafe-to-
 monitor. and the plan for monitoring
 each valve.
  (2) A list of identification numbers for
valves that are designated as difficult-
to-monitor. an explanation for each
valve stating why the valve ia difficnlt-
to-monitor. and the schedule for
monitoring each value.
  (g) The following information shall be
recorded for valves complying with
160.483-2:               •
  (11A schedule of monitoring
  (2) The percent of valves found
leaking during each monitoring period.
   (h) The following information shall be
 recorded in a log that is kept in a readily
 accessible location:
   (1) Design criterion required in
 160.482-2(d)(5) and 160.482-3(e)I2) and
 explanation of the design criterion: end
   [2] Any changes to this criterion and
 the reasons for the changes.
   (i) The following Information ahaD be
 recorded in a log that is kept m a readily
 accessible location for use in
 determining exemptions as provided in
 I 80.4BO(d)-
   (1) An analysis demonstrating the
 design capacity of the affected facility.
   (2) A steiernent listing the feed or raw
 materials and products from the affected
 facilities and an analysis demonstrating
 whether these chearicab are heavy
 liquids or beverage alcohol, and
   (3) Aa analysis dcmensnatiiig that
 equipment is not in VOC service.
   (j) Information and data used to
 demonstrate thai a piece of equipment is
 not in VOC service shall be recorded in
 a log that is kept in a readily accessible
 location.
  (k) The provisions of 11807 
-------
{M.4M  ••canatruetlofi.
  For the purposes of this subpart
  (a) The cost of the following
frequently replaced components of the
facility shall not be considered in
calculating either the "fixed capital cost
of the new components" or the "fixed
capiiiil costs that would be required to
construct a comparable new facility"
under 160.15- pump seals, nuts and
bolts, ruptarc disks, and packings.
  (b) Under f 60.13. the "fixed capital
cosi of new components" includes the
fixed capitaJ cost of all depreciable
components (except components
specified in 160.488 (a)) which are or
will be replaced pursuant to all
continuous programs of component
replacement which an commenced
within any 2-year penod following the
applicability date for the appropriate
subpart. (See the "Applicability and
designation of affected facility" section
of the appropriate subpart.) For
purposes of this paragraph.
"commenced" means that an owner or
operator has undertaken a continuous
program of component replacement or
that an owner or operator has entered
into a contractual obligation to
undertake and complete, within a
reasonable time. • continuous program
of component replacement.

M0.4it  IM of ctwfiricala produced by
affected fsjctttiaa*
  (a) The following chemicals we
produced, as intermediates or final
products, by procesa units covered
under this subpart. The applicability .
date for process units producing one or
more of these chemicals is January 5.  '
1981.
  CAS N»
srn-
SB-11-4.
ISO-tl-4.
     _
174*7-41-
Ta-at-f.
                                        4170-30-0-
                                        W-1I-*.
                                        110-W-7 .
                                        M1-7V-4 ,
                                        H»-JO-<_
                                        nau-a-t.
                                        111
                                        111-1
                                        tti-«
                                        114.17.7.

                                        111-4M-
                                        111-77-3 .
                                        M-17-1 -
                                        •M-at-a.
                                        f7.1«.7
                                        T7.7B-1
                                        S1-
                                        tsva«-i.
                                              •7.
                                            •1W.
                                          -1T.S.
                                                                                111-
                                                                                iia
                                                                                ii»
                                                                                111.
                                                         92

-------
                                         PrBoettd/«f f eeti v*
                                         46  FR  1136. 1/5/81
                                        48  FR 48328. 10/18/83 (206)
                                        48  FR 22598. 5/30/84 (227
                                        49  FR 26738. 6/29/84 (230)
93

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   Subpevi XX-Standarta of
   Part or manca for Bus* ttaaottna
   IM.SOO
     (•) Tbt affected facility to which the
   provision* of thii lubpsrt apply ii the
   total of ail the loading rack* at a bulk
   gasoline terminal which deliver liquid
   product into gasoline tank truck*.
     (b) Each-facility under paragraph (a)
   of this section, the construction or
   modification of which is commenced
   after December 17.1960. is subject to the
   provisions of this subpart
     (c) For purposes of this subpart any
   replacement of components  of an
   existing facility, described in paragraph
   I aUSOOfa). commenced before August
  18.1883 in order to comply with any
  emission standard adopted by a State or
  political subdivision thereof will not be
  considered a reconstruction  under the
  provisions of 40 CFR 00.15.
  (Note: n* aimt of these standards is to
  mmimiM me tmiuwn* of VOC  through the
  applicsboo of besi demonstrated
  technologies (BUT). The numerical emission
  limits IB this standard arc expressed in terms
  of total oriMuc compound*. This emission
  limit reflects the performanee of BUT.)
 ft0.6M
   The terms used in this subpart an
 defined in the Clean Air ACL in 1 6O2 of
 this part or in this section as follows:
   "Bulk gasoline terminal- means any
 gasoline facility which receives gasoline
 by pipeline, ship or barge, and has a
 gasoline throughput greater than 73.700
 liters per day. Gasoline throughput shall
 be" the """""in calculated design
 throughput aa may be limited by
 compliance with an enforceable
 condition under Federal Slate or 'iM-«l
 law and discoverable by the
 Administrator and any other person.
   "Continuous vapor processing
 ayatem" means a vapor processing
 system that treats total organic
 compounds vapors collected from
 gasoline tank trucks on a
                                asis
without intermediate accumulation in a
vapor holder.
  "Existing vapor processing system-
means a vapor processing ayatem
(capable of achieving emissions to the
atmosphere no greater than 80
milligrams of total organic compounds
per liter of gasoline loaded), the
construction or refurbishment of which
waa commenced before December 17.
1980. and which was not constructed or
refurbished after that date.  .
  "Gasoline" means any petroleum
distillate or petroleum distillate/alcohol
blend having a Reid vapor pressure of
27.6 kilopascals or greater which is used
 as a fuel for internal combustion
 engines.
   "Gasoline tank truck" means a
 delivery tank truck used at bulk gasoline
 terminals which is loading gasoline or
 which has loaded gasoline on the
 immediately previous load.
   "Intermittent vapor processing
 system" means a vapor processing
 system that employs an intermediate
 vapor holder to accumulate total organic
 compounds vapors collected from
 gasoline tank  trucks, and treats the
 accumulated vapors only during
 automatically controlled cycles.
   "Loading rack" means the loading
 arms, pumps, meters, shutoff valves.
 relief valves, and other piping and
 valves necessary to fill delivery tank
 trucks.
   "Refurbishment" means, with
 reference to a vapor processing system.
 replacement of components of. or
 addition of components to. the system
 within any 2-year period such that the
 fixed capital cost of the new
 components required for such
 component replacement or addition
 exceeds 50 percent of the cost of a
 comparable entirely new system.
   Total organic compounds" means
 those compounds measured according to
 the procedures in I *ff 9ft3
   "Vapor collection system" means any
 equipment used for containing total
 organic compounds vapors displaced
 during the lirsding of gasolinetati>f
 toucks.
   "Vapor processing system" means all
 equipment used for recovering or
 oxidizing total organic compounds
 vapors displaced from the affected
 facility.
   "Vapor-tight gasoline tank truck"
means a gasoline tank truck which has
 demonstrated within the 12 preceding
 months that its product delivery tank
 will sustain a pressure change of not
 more than 750 pascals (75 mm of water)
 within 5 minutes after it is pressurized
 to 000 pascals (450 mm of water). This
 capability is to be demonstrated using
 (he pressure test procedure specified m
 Reference Method 27.

 HO-SOa  Standard for V«4MUeOrBMi4e
 Compound (VOC) airtsaluns  from bum
  On and after the dete on which
I 6O8(a) requires a performance test to
be completed, the owner or operator of
each bulk gasoline terminal containing
an affected facility shall comply with
the requirements of this section 3I3
  (a) Each affected facility shall be
equipped with a vapor collection system
designed to collect the total organic
compounds vapors displaced from tank
trucks during product loading

                 94
    (b) The emissions to the atmosphere
  from the vapor collection system due to
  the loading of liquid product into
  gasoline tank trucks are not to exceed 35
  milligrams of total organic compounds
  per liter of gasoline loaded, except as
  noted in paragraph (c) of this section
    (c) For each affected facility equipped
  with an existing vapor processing
  system, the emissions to the atmosphere
  from  the vapor collection system due to
  the loading of liquid product into
  gasoline tank trucks are not to exceed 80
  milligrams of total organic compounds
  per liter of gasoline loaded.
   (d) Each vapor collection system shall
  be designed to prevent any total organic
  compounds vapors collected at one
  loading rack from passing to another
 loading rack.
   (e) Loadings of liquid product into
 gasoline tank trucks shall be limited to
 vapor-tight gasoline tank trucks using
 the following procedures:
   (1) The owner or operator shall obtain
 the vapor tightness documentation
 described in 160.SOS(b) for each
 gasoline tank truck which is to be
 loaded at the affected facility.
   (2) The owner or operator shall
 require the tank identification number to
 be recorded as each gasoline tank truck
 is loaded at the affected facility.
   [9] The owner or operator shall cross-
 cheek each tank Identification number
 obtained in (e)(2) of this section with the
 file of tank vapor tightness
 documentation within 2 weeks after the
 corresponding tank is loaded.
   (4) The terminal owner or operator
 •hall notify the owner or operator of
 each nonvapor-tight gasoline tank truck
 loaded at the affected facility within 3
 weeks after the loading haa occurred.
   (S) The terminal owner or operator
 •hall take steps assunng that the
 nonvapor-tight gasoline tank truck will
 not be reloaded at the affected facilit)
 until vapor tightness documentation for
 that tank is obtained.
   (6) Alternate procedures to those
 described in (e)|l) through (5) of this
 section for limiting gasoline tank truck
 loadings may be used upon application
 to. and approval by. the Administrator.
   (0 The owner or operator shall act to
 assure that loadings of gasoline tank
 trucks at the affected facility are made
 only into tanks equipped  with vapor
 collection equipment that is compatible
 with the terminal's vapor collection
 system.
  (g) The owner or operator shall act to
 assure that the terminal s and the tank
 truck's vapor collection systems are
 connected during each loading of a
gasoline tank truck at the affected
 facility Examples of actions to

-------
 accomplish this include training drivers
 in the hookup procedures and posting
 visible reminder signs at the affected
 loading racks.
   (h) The vapor collection and liquid
 loading equipment shall be designed and
 operated to prevent gauge pressure in
 the delivery tank from exceeding 4.500
 pascals (450 mm of water) during
 product loading. This level la not to be
 exceeded when measured by the
 procedures'specified in i 80J03(b).
   (i) No pressure-vacuum vent in the
 bulk gasoline terminal's vapor collection
 system shall begin to open at a system
 pressure less than 4.500 pascals (450 mm
 of water).
   (j) Each calendar month, the vapor
 collection system, the vapor processing
 system, and each loading rack handling
 gasoline shall be inspected during the
 loading of gasoline tank trucks for total
 organic compounds liquid or vapor
 leaks. For purposes of this paragraph.
 detection methods incorporating sight.
 sound, or smell are acceptable. Each
 detection of • leak shall be recorded and
 the source of the leek repaired within 15
 calendar days after it ia detected.

 (Approved by the Office of Management and
 Budget-under control number
IfOJO* TaMRwthodaandi
  (a) Section aasff) does not apply to
the performance test procedures
required by this subpart.
  (b) For the purpose of determining
compliance with | aO502(h). the
following procedures shall be used:
  (1) Calibrate and install a pressure
measurement device (liquid manometer.
magnehelic gauge, or equivalent
instrument), capable of measuring up to
500 mm of water gauge pressure with
±ZS nun of water precision.
  (2) Connect the pressure measurement
device to a pressure tap in the terminal's
vapor collection system, located as close
as possible to the connection with the
gasoline tank truck.
  (3) During the performance test.
record the pressure every S minutes
while a gasoline tank truck is being
loaded, and record the highest
instantaneous pressure that occurs
during each loading. Every loading
position must be tested at least once
during the performance test2I3
  (c) For thr purpose of determining
compliance with the mass emission
limitations of | 60.502(b) and (c). the
following reference methods shall be
used:
  (1) For the determination of volume at
the exhaust vent:
  (i| Method 26 for combustion vapor
processing systems.
  (ii) Method 2A for all other vapor
processing systems.
  (2) For the determination of total
organic compounds concentration at the
exhaust vent. Method 25A or 25B The
calibration gas shall be either propane
or butane.
  (d) Immediately pnor to a
performance test required for
determination of cmpliance with
I 60.502(b). (c). and (h). all potential
sources of vapor leakage in the
terminal's vapor collection system
equipment shall be monitored for leaks
using Method 21. The monitoring shall
be conducted only while a gasoline tank
truck is being loaded. A reading of
10.000 ppmv or greater as methane shall
be considered a leak. All leaks shall be
repaired pnor to conducting the
performance test.
  (e) The test procedure for determining
compliance with i 60.502(b) and (c) is a>
follows:
  (1) All testing equipment shall be
prepared and installed as specified in
the appropriate test methods.
  (2) the time period for a performance
test shall be not leas than 6 hours.
during which  at least 300.000 liters of
gasoline are loaded. If the throughput
criterion is not met during the initial e
hours, the teat may be either continued
until the throughput criterion ia met. or
resumed the next day with another
complete 6 hours of testing. As much as
possible, testing should be conducted
during the 6»hour period in which the
highest throughput normally occurs.
  (3) For intermittent vapor processing
systems:
  (i) The vapor holder level shall be
 recorded at the atari of the performance
 test. The end of the performance test
 shall coincide with a time when the
 vapor holder is at its original level.
   (ii) At least two etartups and.
 shutdowns of the vapor processor shall
 occur during the performance test. If this
 does not occur under automatically
 controlled operation, the system shall be
 manually controlled.
   (4) The volume of gasoline dispensed
 during the performance test period at all
 loading racks whose vapor emissions
 are controlled by the processing system
 being  tested  shall be determined This
 volume may  be determined from
 terminal records or from gasoline
 dispensing meters at each loading rack.
   (5) An emission testing interval shall
 consist of each 5-mmute period dunng
 the performance test. For each interval:
   (i) The reading from each
 measurement instrument shall be
 recorded, and

                95
  (ii) The volume exhausted and the
average total organic compounds
concentration in the exhaust vent sh
be determined, as specified in the
appropnate test method. The average
total organic compounds concentrati
shall correspond to the volume
measurement by taking into account me
sampling system. response time.
  (6) The mass emitted dunng each
testing interval shall be calculated ai
fojlows'

M.-U-W.C.

where
M.BHUUI of total organic compounds
    emitted dunng letting interval :. ng
V." volume of tir-vapor mi mure exhuasi
    m1. at standard condition*.
C,» total organic compound* concentration
    (at meaiured) at the exhaust veni. pp
1C -density of calibration gas. mg.'m' at
    standard condition*
       •1JSX10*. far propane
       -141X10*. far bataM       213
s« standard conditions, 2D*C and 780 mm

  (7) The total organic compounds mass
emissions shall be  calculated as folio  :
where:           .            313
E-nasa of total organic compounds emitted
    per volume of gasoline loaded. mg/hter.
M.»maa* of total organic compounds
    emitted dunng tasting interval L mg.
L- total volume of gasoline loaded, litera.
••number of testing istervals
  (f) The owner or operator may ad)i
the emission results to exclude the
methane and ethane content in the
exhaust vent by any method approve*1
by the Administrator.
(Sec, 114 of the dean Air Act as amendec
U.S.C 7414)]
(Approved by the Office of Management i
Budget under control number 2060-0006.)
         Heporttng and i«e»d»oepln»
  (a) The tank truck vapor tightness
documentation required under
160.502(e)(1) shall be kept on file at the
terminal in a permanent form avaiijb
for inspection.
  (b) The documentation file for each
gasoline tank truck shall "be updated ai
least once per year to reflect current •   t
results as determined by Method 27.
This documentation shall include, as _
minimum, the following information.
•  |l) Test Title: Gasoline Delivery T«
Pressure Test— EPA Reference Methc
27.

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   (2) Tank Owner and Address.
   (3) Tank Identif.canon Number
   (4) Testing Locution.
   (5] Date of Test.
   (6) Tester Name and Signature.
   (7) Witnessing Inspector, if any:
 Name. Signature, and Affiliation.
   (8) Test Results: Actual Pressure
 Change in 5 minutes, mm of water
 (average for 2 runs).
   (c) A record of each monthly leak
 inspection-required under | 60.502(j)
 siv.il be kept on Hie at th«> terminal for
 a: least 2 years. Inspection records shall
 include, as a  minimum, the following
 information:
   (1) Date of Inspection.
   (2) Findings (may indicate no leaks
 discovered, or location, nature, and
 •evenly of each leak).
   (3) Leak determination method.
   (4) Corrective Action (date each leak
 repaired: reasons for any repair interval
 in excess of 15 days).
   IS) Inspector Name anJ Signature.
   (dj The  terminal owner or operator
 shall keep documentation of ail
 notifications required under
 I 60.502(e)(4) on file at the terminal for
 at least 2 years.
   (e) [Reserved).
   (f) The owner or operator of an
affected facility shall keep records of all
replacements or additions of
components performed on an existing
vapor processing system for at least 3
yean.
(Sec. 114 of the Clean Air Act as amended (42
U.S.C 7414)]
(Approved by the Office of Management and
Budget under control number 2D60-OOOR)
IMJ06
  For purposes of this subpart.
  (a) The cost of the following
frequently replaced components of the
affected facility shall not be considered
in calculating either the "fixed capital
cost of the new components" or the
"fixed capital cosls that would  be
required to construct a comparable
entirely new facility" under { 60.15.
pump seais. loading arm gaskets and
swivels, coupler gaskets, overfill sensor
couplers and cables, flexible vapor
hcses. and grounding cables and
connectors.
  (b) Under | 60.15. the "fixed capital
cost of the new components" includes
the fixed capital cost  of all depreciable
components (except components
specified in | 60.506(a)| which are or
will be replaced pursuant to all
continuous programs  of component
replacement which are commenced
within any 2-year period following
December 17.1980. For purposes of this
paragraph, "commenced" means that an
owner or operator has undertaken a
continuous program of component
replacement or that an owner or
operator haa entered  into a contractual
obligation to undertake and complete.
within a reasonable time, a continuous
program of component replacement.
(Src. 114 of the Clean Air Act a* amended (42
US.C 7414)|
                                                                                            PraaoiX/ effective
                                                                                            45 FR 83126.  12/17/80
                                                                                            48 n 37578. 8/18/83 (195)
                                                                                            48 n 56580. 12/22/83 (213)
                                                           96

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 Stibpart GGG-Standarde of
 Performance for Equipment LMks of
 VOC to PsjfroHjum Refineries "7

 IW.SM  AppllcsMUtyandOMtgnattonof
 enacted faculty.
   (•)(!) Hie provision* of this subpart
 apply to affected facilities in petroleum
 refineries
   (2) A compressor is an affected
 facility
   (3) The group of all the equipment
 (defined in I 60.591] within a process
 unit is an affected facility
   (b) Any affected facility under
 paragraph (a) of this section that
 commences construction or modification
 after January 4.1983. is subject to the
 requirements of this subpart.
   (c) Addition or replacement of
 equipment (defined in | 60.591) for the
 purpose of process improvement which
 is accomplished without a capita)
 expenditure shall not by itself be
 considered a modification under this
 subpart
   Id) Facilities subiect to Subpart W or
 Subpan KKK of 40 CFR  Part 60 are
 excluded from this subpart

 fMjei  Oetlnmone.
   As used in this subpan. all terms not
 defined herein shall have the meaning  .
 grven them in the Act. in Subpart A of
 Pan ao. or u Subpan W of Part 60. and
 the following terms shall have the
 specific meanings given  them.
  "Alaskan North Slope" means the
 approximately 69.000 square mile area
 extending from the Brooks Range to the
 Arctic Ocean.
  "Equipment" means each valve, pump.
 pressure relief device, sampling '
 connection system, open-ended valve or
 line, and flange or other  connector in
 VOC service. For the purposes of
 recordkeeping and reporting only.
 compressors arc considered equipment.
  In Hydrogen Service" means that a
 compressor contains a process fluid that
 meets the conditions specified in
 160.583(6).
  la Light Liquid Sen-ice" means that
 the piece of equipment contains a liquid
 that meets the conditions specified in
 I aaSB3(c).
  "Petroleum Refinery" means any
 facility engaged in producing gasoline.
 kerosene, distillate fuel oils, residual
 fuel oils, lubricants, or other products
 through the distillation of petroleum, or
 through the redistillation, cracking, or
 reforming of unfinished petroleum
derivatives.
  "Petroleum" means the crude oil
removed from the earth and the oils
derived from tar sands, shale, and coal.
  "Process Unit" means components
assembled to produce intermediate or
final products from petroleum.
unfinished petroleum derivatives, or
other intermediates: a process unit can
operate independently if supplied with
sufficient feed or raw materials and
sufficient storage facilities for the
projuri
 IM.M7
   (a) Edit) owner or operator subject to
 the provisions of this subpan shall
 comply with the requirements of
 I 60.482-1 to I 60.482-10 as soon as
 practicable, but no later than 180 days
 after initial startup.
   (b) An owner or operator may elect to
 comply with the requirements of
 160.4-S.V] and f 60.483-2.
   (c) An owner  or operator may apply to
 the Administrator for a determination of
 equivalency for any means of emission
 limitation thai achieves a reduction in
 emissions of VOC at least equivalent to
 the reduction in emissions of VOC
 achieved by the controls required in this
 subpart In doing so. the owner or
 operator shall comply with requirements
 Of | 60.484.
   (d) Each owner or operator subject to
 the provisions of this subpan shall
 comply with the provisions of 160.485
 except as provided in 160593.
   (e) Each owner or operator subject to
 the provisions of this snbpan shall
 comply with the provisions of 160.486
 and 160.487.
 (Sec 114 of Clean  Air Ac! a* amended (42
 U.SC. 74HI)
 160.593  exceptions.
   (a) Each owner or operator subject to
 the provisions of this subpan may
 comply with the following exceptions to
 the provisions of Subpan W.
   (b)(1) Compressors in hydrogen
 service are exempt from the
 requirements of  160.592 if an owner or
 operator demonstrates that a
 compressor is in hydrogen service.
   (2) Each compressor is presumed not
 be be in hydrogen service unless an
 owner or operator demonstrates that the
 piece of equipment is in hydrogen
 service. For a piece of equipment to be
 considered in hydrogen service, it must
 be determined that the percent hydrogen
 content can be reasonably expected
 always to exceed 50 percent by volume.
 For purposes of determining the percent
 hydrogen content in the process fluid
 that is contained in or contacts a
compressor, procedures that conform to
the general method described in ASTM
E-Zea E-168. or E-169 (incorporated by
 reference as specified in J60.17) shall be
 used.
   (SHU An owner or operator may use
 engineering judgment rather than
 procedures in paragraph (b)(2) of this
 section to demonstrate that the percei
 content exceeds 50 percent by volume.
 provided the engineering judgment
 demonstrates that the content clearly
 exceeds 50 percent by volume. When
 owner or operator and the
 Administrator do not agree on whelhr*
 a piece of equipment is in hydrogen
 service, however, the procedures in
 paragraph (b)(2) shall be used to resolve
 the disagreement.
   (ii) If an owner or operator determii
 that a piece of equipment is in hydrog
 service, the determination can be
 revised only after following the
 procedures in paragraph (b)(2).
  (c) Any existing reciprocating
 compressor that becomes an affected
 facility under provisions of { 60.14 or
 160.15 is exempt from 160.482 (a), (b)
 (c). (d). (e). and (h) provided the owne
 or operator demonstrates that recasting
 the distance piece or replacing the
 compressor are the only options
 available to bring the compressor into
 compliance with the provisions of
 160482 (a), (b). (c). (d). (e). and (h).
  (d) An owner or operator may use tl
 following provision in addition to
 160.485(e): Equipment is in light liquio
service if the percent evaporated is
greater dun 10 percent at 150*C as
determined by ASTM Method D-86
(incorporated by reference as specifie.
in 160.18).
  (e) Pumps in light liquid service and
valves in gas/vapor and light liquid
service within a process unit that is
located in the Alaskan North Slope are
exempt from the requirements of
 160.482-2 and 160.482-7.
                                                  «B FR 279. 1/4/83
                                                  49  FR 22S98. S/30/84 (227)
                                                       97

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P ART 60-[ AMENDED]

  40 CFR.Part 60 is amended as follows:
  1. By .adding a new Subpart GGC as
follows:

Subpart GGG—Standards of Performance
for Equipment Leaks of VOC In Petroleum'
BOSK) Applicability and designation of
   affected facility.
OOSn Definition*.
00.592 Standards.
80583 Exceptions.
60.504 gasps  (Reserved)
 Subpart GGG—Standards of  '-   ' '.!
 Performance for Equipment Leaks of
 VOCIn Petroleum Refineries , - . -  f.

 gjttjttQ- Apptt^Dty and detonation of_:
v affected faculty.*   *     •*  —.  o   \  /-j
   (a)tl] The provisions- of this subpart
 apply to affected facilities in petroleum
 refineries*'      " '    - •
   (2) A compressed is an affected
 facility.        •  '-   • '_
  *(3) The group of all the equipment
 (defined'ln § OL591] within a process .'
 unit is an affected facility.
•  (b) Any affected facility under
 paragraph (aj of this section that
               jtruction or modification
                                       • after January 4.1983. is subject to the
                                        requirements of this subpart.  .
                                        -- (e) Addition or replacement of       ;
                                        equipment (defined in § 60.591) for the '
                                        purpose of process improvement which
                                        is accomplished without a capital
                                        expenditure* shall not by itself be

                                        subpart        •       ,
                                          (d) Facilities subject to Subpart W or
                                        Subpart KKK of 40 CFR Part 60 are
                                        excluded BOB this subparL
                                          Arnsedin this subpart all terms not
                                        defined heroin «h"H have the meaning
                                        given them in the Act m Subpart A of
                                        Part 60* or in Subpart W of Part 60. and
                                       . the following terms shall have the
                                        specific *"*BTiingt given them*
                                          "Alaskan North Slope" means the
                                        approximately 6&000 square mile area
                                        extendmg'from the Brooks Range to the

                                          "Equipment" means each valve,  pump.
                                        pressure relief device, sampling
                                        connection system, open-ended valve or
                                        line, and flange or other connector in
                                        VOC service. For the purposes of
                                        ncordkeeping and reporting only,
                                        compressors an considered equipment
                                          "In Hydrogen Sendee" means that a
                                        compressor contains a process fluid that
                                        meets the conditions specified in
                                        |605B3(b).
                                          "In Light Liquid Service" means that
                                       • the piece of equipment contains a liquid
                                        that meets, die conditions specified in
                                        900583(0).
                                          "Petroleum Refinery" means any    •*
                                        facility engaged in producing gasoline.
                                        kerosene, distillate .fuel oils, residual
                                        fuel oils, lubricants, or other products
                                        through the distillation of petroleum, or
                                        through the redistillation, cracking, or
                                        reforming of unfinished petroleum
                                        derivatives.
                                      98

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    -"Petroleum" means the crude ofl
   removed from the earth and the oils -
   derived from tar sands, shale, and coal
     "Process Unit" means components
   assembled to produce intermediate or
   final products from petroleum.
   unfinished petroleum derivatives, or
   other intermediates; a'process unit can
   operate independently if supplied with
   sufficient feed or raw materials and
   sufficient storage facilities for the
   product

   $60592  Standards.        _     .   .
     (a) Each owner or operator subject to'
   the provisions of this subpart shall
   comply with the requirements of
   5 60.482-1 to 5 60.482-10 as-soon as
   practicable, but no later than 180 days
   after initial startup.
     (b) An owner or operator may elect to-
   comply .with the requirements of
   § 60.483-1 and $ 80.483-2.      .
     (c) An* owner or operator may apply to
   the Administrator for a determination of
   equivalency for any means of emission
   limitation that achieves a reduction in
,  emissions of VOC at least equivalent to
   the reduction in emissions of VOC"
 _ achieved by the controls required in this
   subpart In doing so. the owner or
   operator shall comply with requirements
  0/560.484;    •   -            _' .
    (d) Each owner or operator subject to ~
  the provisions of this subpart shall- — "• .
  comply with the provisions off 60.485  '
  except as provided in {.6O583.        '
    (efEach owner or operator subject to '
  the provisions of this subpart shall
  comply with the provisions of 5 80.486 ".'
  and 5 60.487.        >  -..-.;,  -
  (Sec.114 of Oean Air Act as aia«dedl4?  •
  UA&7414J) - _ '     ;  . ^T"?    y
   (a) Each owner oroperator subject to.;
 the provisions of *h'« subpart nay*— w .'•
 comply with the following exceptions to~"
 the provisions of Subpart W. .••  -.--. • '• -*••
   (b)fl) Compressors in hydrogen- . -"   ,
 service are exempt from the .      •:'.-'•
 requirements of { 60£d2 if an owneeor. _,;
t operator demonstrates that a  *~-  .-   •
 compressor is in hydrogen service. ••• '•'„
   (2) Each compressor is presumed not  -
 be be in hydrogen service unless an /"  -
 owner oroperator demonstrates that the
 piece of equipment is in hydrogen •
 service.-For a piece of equipment to be.r
 considered in Hydrogen service* -it must •  »
 be determined that the percent hydrogen-
                           i+t+mA.-- -.<
 content can be reai	,f _T	
 always to exceed 50 percent byvL.__  .
 For purposes of determining the percent-- ••
 hydrogen content in the process fluid •" /
 that U contained in or contacta Equipment is m light Hqu« -
                                        service if the percent evaporatedis •'• "-:
                                        greater than 10 percent atlSO*C aa vf ":
                                        determined by ASTM Method D-88 r? *
                                        (mcorporateclby reference as specified "
                                        iB S 80ja)r ^.-flT • ^":~- i *• >• 5 •>i*:~VJv: ./ ', .
                                       *  y .adding in^}phabeticaro>der the
         s as leflected'by the-5S5>^-^-.: -~-^- -^^-*-*-*-•~-*fz»:-?-'*r.-•<«r*'«fa.yjg^'«ci,j. —,
 fallowing equation: PW*3r/fcwJiera^.^**^^                     -•  ^
  • (lyibe adjusted annual-asset::^'» *" J--  (SsctiaBi:iaa..iM,andaQi(aJ«f.«eCle8n^  •"•
 goideltae4epairallc%aiiee^.-ia4b»-r ^&™*^#(*VSC;t4a%rq*;.   "    "
                                                           ofthe>i-
                                       replacemenT cost Y; and the applicable - :
                                       basic annual asset gnidcMde Tepair1-. '• -  '-
                                              "                              '
                                       « •60.4824 a* follows:
                                                      99

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.}60.48>1 •Standards: Generet   ,'. v b.C ' § aMasj " Rsecnslrucfloa.  r     '.-.i -^•; -

 •.;• •'->'. < •-• r •*'%ife'a-r.3-5=* = : -•£>"* .Tr-Tor-the purposes of this subpart^ "t^."1*:
. - (d) Equipmentthat-is in vacuum- •_. 1~... • i'[a>The coat of the following   7^ VlV-
 service is excluded from the: -:"  .?"! "•/>:'?ifeequentfy replaced components of the-* * ^
'requirements of 9 60.482-2 to { BG.482-i&. '• faculty shall not be considered in. "  ~"i~
'if it is-identified as required in  2, v*'yrjL'cnlaiIating either the "fixed capital cosr"
i•IM^e]t5^Tis;ar:i|^.^ii£^^^^^S>^ *enew conponents** or the '.'fixed-^-
 r^ftfjna HjtiiA^ and 301(a]^>f me .fej"^< ..construct a comparable"neWfaciHty'**"L' ""f

                                  :^ ';rboltijropture disksv and packings. .77"^" .
                                    •* * ^*"Jfk* !»"••-# L. • A««-^e* *L.*_ ••*«*  *•*—	*• A—t" ^
                                                                              ^ (40J ASTM DW-78. Distillation of. '
                                                                              •Petroleum Products. BR approved for " ~
                                                                              •I80.593(d).   '      .-  '- -  : - ": _   -
                                                                              ,(Seetfons 111.*I14/and30I(a) of the de'an Air
                                                                              : ^ct •» amended («.-.v4-?-"WiIl be replaced pursuant faaQ     ',' ..
 _ (2) If a leak* is detected, tne valve shall  eontinnou programs of component ' . ",">
' be monitored monthly until a Teak is not "/ replacement which are commenced   J
 detected for 2 succjpssivemonths.  . ' J''- : within.-any'2-yeatperiod following the. .
        '
                                                                              (Section* 111.114. and 30l(a) of the Qean Air
                                                                              Act. a> omuided (42 U3.C 7411 7414.
                                                                              7801(alH  .'.  _    .    7   <    ,

                                                                              .' "-11. By reviaing"the first equation in.
                                                                              Section &2.1.1 in Method 18 of Appendix-
                                                                              A as follows:
  .'(2) Hie process uniwithin which the
 valve i» located either becomes as *-•-
; effected fiunlity through J8O14 or .. ir
 1 mi9 or the ownaz ox operator  '-r^'-'
 designates less'-thas 3U> percent of the^T
 monitor, and
                                     .-; ^aubpart (See the "Applicabiliry and "..
                                      • • designatioa of affected facility" section'
                                      .--of the appropriate subpart) ForV J'~
                                      r'P«Bposea ofthia" paragraph. .  . •'    .i
                                       '. "conunencedT meanvthat an owner oc
                                                   undertaken a cooflnnous
                                        program of CDmnonenTTeplacement or .
                                                     or opera tor has entered
                                                                                                     Bq. 18-1
                                                                              (Secttooalll.114. and 301(a) of the dean Air
                                                                             "Act u amended (42 tt&C 7411. 7414.
           'iitand 301W of th*  ean Air-
                                                 and completa. within a
                                               bl      a «yiHtmmt« progranr*
                                                                 '
                                : :" V*
   TLBy revising paragraphs-(c)(2J (ii)
fand (vi) of ft 8O487 as follows:^  .
  IH                      . .•  "^ -•* * '.
  f21 ***              - • r •        * *
  I"!                     • /    »' •
  (u) Number of valves for which leaks  .
were not repaired as required in   '
16tu82-7(d)(i).  -  •.     'j    *-* . :


  (vi) Number of campresson for which
leaks wen not repaired as required is
r80.482-0(3J(l}.and    '  •

(Secdoas 111. 114. sad 301(a) of the dean Air
Act aa amended (42 U3.C 7411.741V
7»W(a)J]            .   ...   .
(Approved by the Office of Management and
Budget under miitrul triimbrr 20UMXM7.)

  8. By adding 9 60.488 to Subpart Was
follows
                                           amponentreplacement.    >w  ..    ^
                                       ' (SacilnnB.in.n4; andaoi(a) ofuS Clean Air
                                       ' Act as emended (42 U.SC 7411.7414.
                                        7BOI(«JJJ  .-  ^:.t , v «..  -•••   ~~  -.*  .

                                       "-I ft By nrvtainrpangraphs (a) (34). (351
                                        and (38J by adding (aH4) of 9 80.17 of
                                       . Subparf A^General Provisions as
                                        follows:  •..•••••-•    • •  •    .    -".
                                        16QLi7
                                        • -. (34) ASTM £189-63 (Reepproved   •
                                        19?7), General Techniques of Ultraviolet-
                                        Quantitative Analysis. JBR approved lor
                                        S80L4aS(d)and|6a593(b).  .•  .-"•
                                          (SSI ASTM E188-87 (Reapproved
                                        1977J. General Techniques of Infrared •
                                        Quantitative Analysis. IBR-approved for
                                        I oU4aS(d] and S 6OS93(b).
                                          (38) ASTM E280-73. General Gas
                                        Chramatography Procedures. DBR
                                        approved for 9 8a48Sfd) and 9 8O593(b).
" .  12. By revising the atation"atation
  a in section a" to "Citation 18 in
. section a," in &2.1.1 m Method 18 of
  Appendix A..
  (Secdonc 111. 114. and 301(a) of the dean Air
  Act-as amended (42 U.S.C. 7411.7414.
 .780«a)JJ

•   13. By changing the word "caped" to
^"capped" in section 8^2.1 in Method 18
''of Appendix A.
  (Secuuu 111. IK and 301(a) of the dean Air
  Act as amended (42 US.C. 7411.7414.
                                                                                      %
                                                                                .14. By changing all fee "ing/liter" to
                                                                              ."g/liter* m section a 2.2.3 in Method 18
                                                                              of Appendix A.
                                                                              (Seetfoaa 111. lit and 301(a) of the dean Air
                                                                              Act as amended (42 U.S.C 7411. 7414.
                                                                              7eni(eM)
                                                                                15. By changing the word "with" to
                                                                              -within" in section 7.4.4J in.Method 18
                                                                              of Appendix A.
                                                                              (Seetiont 111. H4. and 301(a) of the dean Air
                                                                              Act aa amended (42 U.S.C 7411. 7414.
                                                                              7aol(aJJJ
                                                                              in Da*.
                                                      100

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  PAflT«0-IAMEHEm
                                                   5'
   1. The antherfty-dtstton far Part 60
 antiiffia>toireai-BsloQowsr_ ^

-"" Authority:'42U3.C:r411.7Hn(«jr> *.  "
 ' SubparfKXX— StsMdatda at fadeonanc* •
  tor EouipiMnt Uaka of JOCTrom Aistwr*
  NaturaJ.Gaa PracaaalngrRanta.
                 •         -     '••
  60430
   801831 *Dafinltians.
         Exeepttaas>    •   •
   BOLB34  Alternative means of OBUMMB
   affactad facility.
        ts affiactadlaciiitio-ia onhara
   wet gaa>a«EHiee.is-8B-aBactad 'facility.
     (3) The-ywup-oT all equipment, except
   eootpmson (definied m-J 60631) within
   a proce»a-unit:i«-an 'affected, facility.
     (b) Any OkanA mcilfty under
                      ectieB that
                 stnzctton. Teconstroction.
   OMBodiDeaUan-afterlannary 20.1984. is
   subject to the requirements of this
   subpart
     (c) AdStton or replaoemeQt
-------
   "In wet gas service" means that a
 piece of equipment contains or contacts
 the field gas before_the extraction step
 in the process.

 580.832 Standards.
   (a) Each owner or operator subject to
 the provisions of this subpart shall
 comply with the requirements of
 S 60.482-1 (a), (b). and (d) and 5 60.482-2
 through § 60.482-10. except as provided
 in S 60.633. as soon as practicable, but
 no later than 180 days after initial
 startup.
   (b) An owner or operator may elect to
 comply with the requirements of
 5 60.483-1 and $ 60.483-2.
   (c) An owner or operator may apply to
 the Administrator for permission to use
 an alternative means of emission
 limitation that achieves a reductionJn
 emissions of VOC at least equivalent to
 that achieved by the controls required in
 this subpart In doing so. the owner or
 operator shall comply with requirements
 of $ 80.634 of this subpart
   (d) Each owner or operator subject to .
 the provisions of this subpart shall
 comply with the provisions of § 80.485
* except as provided in § 80.833(f) of this
 subpart
   (e) Each owner or operator subjecfto
 the provisions of this subpart shall  •
 comply with the provisions of $ 60.486 * *
 and § 60.487 except as provided in
 S 60433. S 60435. and § 60438 of this .
 subpart.  •   '               -.•-.-
   [f)  An owner or operator shall use the'
 following provision instead of
 { 60.485(d)(l): Each piece of equipment
 is presumed to be in VOC service arm
 wet gas service unless an owner or
 operator demonstrates that the piece of
 equipment is not in VOC service or in -
 wet gas service. For a piece of
 equipment to be considered not in VOC
 service, ft must be determined that the'
 percent VOC content can be reasonably
 expected never to exceed 10.0 percent
 by weight For a piece of equipment to
 be considered in wet gas service, it must
 be determined that it contains or
 contacts the field gas before the  .•
 extraction step in the process. For  •
 purposes of determining the percent
 VOC content of the process fluid that is
 contained in or contacts a piece of
 equipment procedures that conform, to
 the methods described in ASTM
 Methods E16S. E16B. or £280
 (incorporated by reference as specified"'.
 in S 60.17) shall be used.        - : _:   -

 $60433- Exception*.
   (a) Each owner or operator subject to
 the provisions of this subject may
 comply with the following exceptions to
 the provisions of Subpart W.       v
   (b) (1) Each pressure relief device in
 gas/vapor service may be monitored
 quarterly and within 5 days after each
 pressure release to detect leaks by the
 methods specified in S 60.485(b) except
 as provided in { 60.632(c). paragraph
 (b)(4) of this section, and 9 80.482-4(a>-
 (c) of Subpart W.
   (2) If an instrument reading of 10.000
 ppm or greater is measured,  a leak is
 detected.
   (3) (i) WHen a leak is detected, it shall
 be repaired as soon as practicable, but
 no later than 15 calendar days after it is
 detected, except as provided in S 60.482-
 9.
   (ii) A first attempt at repair shall be
 made no later than 5 calendar days after
*each leak is detected.
   (4) (1) Any pressure relief device that
 is located in a nonfracn'onating plant
 that is monitored only by nonplant
 personnel may be monitored after a
 pressure releaseJhe next time the
 monitoring personnel axe on site, instead
 of within 5 days as specified in -
 paragraph (b)(l) of *•*• faction and
 S 80.482-(b)(l) of Subpart VV.
   (ii) No pressure relief device
 described in paragraph (b)(4)p] of this  .
 section shall be allowed to operate for
 more .than 30 days after a pressure.
 release without monitoring,':.   v-~
  ~ (c) Sampling connection systems are
 5OM82-*.             .
  "(dj Pumps in light liquid service; .
 valves in gas/ vapor and light £qtnd
service, and pressure relief devices in
gas/vapor service mat are located at a
nonfracnonanng plant that does not   •
have the design capacity to process
283JXX) standard cubic meters per day
(scmd) (10 million standard cubic Jeet  .
per day (scfd]) or more of field gas an

requirements of 8  80.482—2(a]p>)t
8 60.482-7(8), and 8 6O633(b)(l).
  (e) Pumps in light liquid service,'
valves in gas/vapor and light liquid
service, and pressure relief devices in
gas/vapor .service within a process unit
that is located in the Alaskan North
Slope an exempt from the routine     f
  sec) if the net heating value of the gas
  being combusted is greater than 37.3
  MJ/scm (1000 Btu/scf).
    (2) Steam-assisted and nonassisted
  flares designed for and operated with an
  exit velocity, as determined by the
  methods specified in § 60.485(g)(4). less
  than 122 m/sec (400 ft/sec) and less
  than the velocity. vmax as determined
  by the following equation:
  LoguTmax) » (H, + 28.8J/31.7
  vmax m Maximum permitted velocity, m/aec-
  Z8.8 - Constant.
  31.7 m Constant
  HT • The net heating value as determined IB
      160.485(81(3).
    (h) An owner or operator may use the*
  following provisions instead of
  S 60.4S5(ej:
    (1) Equipment is In heavy liquid .
  service if the weight percent evaporated '
  is 10 percent or leas  at 150 *C as
  determined by ASTM Method D86
  (incorporated by reference as specified
  m§ 60.17).     -...*-"•
    (2) Equipment is in light liquid service •
  if die weight percent evaporated is
  greater than 10 percent et 150 *C as
  determined by ASTM MethodDae
  (incorporated by reference as specified
 • in J-80.17).  .-"•"...-   •  .
  UlflttattkOI> m- m  - • . ._ .  ..    *•

    (ff) If. ip tike Administrator^ judgment
 limitan'on wn achieve a reduction in _.
  VOC emissions at least iMiuill
-------
   (2) If the applicant is an owner or
. operator of an affected facility. He must'
 commit in writing to operate and  - .
 maintain the alternative means so as to
 achieve a reduction in VQC emissions at
 least equivalent to the redaction, in VOC
 emissions achieved under the* design.
 equipment Jivork practice or operational
 standard. _ -„-
'
 560.835  Recordkeoping requirements.^
  • (a) Each owner orbperator subject to','
 the provisions of this subpart shall   .  J"
 comply with the requirements of-
 paragraphs (b) ano*(c) of- this section in*
 addition to the requirements of 9 60.486.
   fl>) The following recordkeeping .V
 requirements shall apply to pressure
 relief devices subject to the-   '
 requirements of 9 80.633(b)(l) of this
 subpart   . ,-J A  .-..-•  . ..\.~ v. '-.'^
   (1) When each leak is detected as
. specified is & 60.633(b)(2). a     .,'.. V..
 weatherproof and readily visible- Y" \ -'..
 identification, marked with the  '"   '   '.
 equipment identification numbers shall"
 be attached to-the leaking equipment. *
 The identification on the pressure relief
 device maybe removed after it has been
 —.  -i      .         -	
 repaired.   .      .-..-,.    '-.-»•»,
   (2) When each leak 'is detected as ''"
 specified in 9 6O833(b)(2). the foQowing
 information shall be recorded*u> a log-
 and shall be kept forZyears in a-readOy
 accessible location:'      -   '•' ". "•* ^
   (i) The jnstnunent and operator -  .""
 identification numbers and the  '   '  •
 equipment identification number.
   (iilThe data the leak was detected  .
 and the dates of each attempt to repair
 the leak.     .  -'
   (iii) Repair-methods applied in each
 attempt to repair the leak.
   (iv) -Above 10000 ppm" if the
 BAXlfllttflK IBSiRUOCBt fB&dK&ff B16fi8UF6tt
 by the methods specified in 9 6O635(a)
  after each repair attempt is 10,000 ppm  -
 ' or greater.'?  '      .'"    ...;—=••--  .».
 :-". (v) "Repair delayed" and the reason •
 ' for the delay-if aleak is not repaired
  within 15 calendar days after discovery
  of the leak.*   -   "    -   "  ^.'^
    (vi) The signature of th'e owner or  ' -.
  . operator [or designate) whose decision
_^.it*was that repair could not be effected
'"- without« process shutdown.     . •"- ' ~::
 , . tvii) The expected date of successful'."
" repair of the lea? if a- leak is not  "_~ -'•
 . repaired within 15 days.        ,- ":\:
  - (viiij Dates of process unit shutdowns
  that occur while the equipment is
  unrepaired.  . ..     ' . -   ••  ;.' J-ii.. •"•
  \ (Ix) The date of successful repair of-
  "theleak.  -  .'-     -   ' .--«-.';:•"
 " "  (x) A list of identification numbers for
 • equipment that an designated for no
r. detectable emissions under the
  provision of 9 60.482-4(a):The Z~''    ''
'• designation^of equipment subject to the"
 * provisions of 9 eo.482-4(arshallbe'  ^r ^ .
 * signed by the owner or operator.'     '  .'.
  "  (c) An. owner or operator shall comply ;
 ' with the following requirementin     ^.'
  addition' to the requirement of  .;      .^:
  9 60.488(11; Information af"f dfttft used to-'*
  .demonstrate that • reciprocating       .
 ..compressor is' in wet gas service to "
  apply for the exemption in 9 60633(9
  shall be recorded in a log that is kept in
  _a readily accessible location.   '.
." (Approved b'y the Ofltce of Management and
  . BunjeTmtier oooboi nosioer 20604120} ^
        .•.   ...-*»-""••     •:

    (a) Each owner or operator subject to '

 - comply with the requirements of   ~
  paragraphs (b) and (c) of this section in
 ' addition to the requirements of 9 80.487.
    (bT An owner or operator shall include
. the fallowing information in the initial
           u report in addition to the
 information required in 9 60.487(b)(l
 •(4): number'of pressure relief devices
 subject to the requirements of
 9 60.633(b) except for those pressure
 relief devices designated for no
:. detectable emissions under the
 provisions of J_80.482-4(a) and those
. pressure relief devices complying wi
 J 60.482^4(c).  '  ;             ^  -
; *  (c) An owner or operator shall include
. the following information in all
           ' reports in addition to the   •
 WMMCBMUMW* ««|0Wft M* •«• •>!•««•»*««>• »W e««w

 mformation required in 9 6O487(c)(2)t
                                                                                                               ij-
                                                                                (1) Number of pressure relief devie
                                                                            f? for which leaks wen detected as
                                                                              required in 9 60.633(b)(2) and
                                                                            +  (2) Number of pressure relief device*
                                                                              for which leaks wen not repaired as
                                                                              required in 9 60J33(b)(3).
                                                                            •  Mppravcd by the Office of Management and
                                                                              Budget under control number 2060-0120)
                                                                                3. By revising paragraphs (a) (34). (3
                                                                            - [38), and (40) of 9 60.17 of Subpart A—
                                                                            .'.•General Provisions to read as follows:  .

                                                                              ^ 60.17  tocorpoiadofi By referencec
                                                                            '(•)*••
                                                                            ...  (34) ASTM £169-63 (Reapproved
                                                                            V-1977), General Techniques of Ultraviol
                                                                              Quantitative Analysis. IBR approved f
                                                                            :  9 6a48SXd).  9 eOS93(b), and 9 6O632(f).
                                                                             '  (35) ASTM £168-67 (Reapproved
                                                                              1977), General Techniques a/Infrared-
                                                                              Quantitative Analysis. IBR approved C
                                                                              1 60.485(d).  9 60S93(b), and 9 60^3Z(f).
                                                                                4»] ASTM £260-73. General Gas
                                                                             • Coromatography Procedures. IBR
                                                                              approved for 9 60.485(d). 9 6O593(b).
                                                                              ••H J 60432(f).
                                                                                (40) ASTM D86-78, Distillation of
                                                                              Petroleum Products. IBR approved for
                                                                              1 60593(d) and 9 6OB33(h).
(FR
          -9
                                                                                            FDed 6-21-85: 8:48 am|
                                                       103

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NESHAPS REGULATIONS
        104

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  Subpart F—National Emission Standard
            for Vinyl Chloride »
 161.60   Applicability.
   (a) This  subpart applies  to  plant*
 which produce:
   (1) Ethylene dichloride by reaction of
 oxygen  and hydrogen chloride with
 ethylene.
   (2) Vinyl  chloride  by  any process,
 and/or
   (1> On* or more polymer* containing
 any traction of polymerized vinyl chlo-
 ride.
   (b) .This subpart does not apply  to
 equipment used in research and develop-
 a?ent if  the  reactor used to polymerize
 the vinyl chloride processed in the equip-
 ment has a  capacity of no more than
 9.19 m'C50 *al).
   (c> Sections of this subpart other than
 If6l.$l: 61.64 U), .  (c>.and (d>;
 •1.67; 61.68: 61.69: 61.70;  and 61.71 do
 not apply to  equipment used In research
 and development if the reactor used  to
 polymerize the vinyl chloride processed
 in  the  equipment has a capacity  of
 greater than 0.19 m'  <50  gal) and no
 •sore than CAT m'(1100 gal).*
 161.61  Definition*.
  Terms used in this subpart are denned
 in the Act. to Subpart A of this part, or
 in this section as follows:
   (a)  "Ethylene dlchlortde plant"  in-
 cludes any plant which produces ethyl-
 ene dichloride by reaction of oxygen and
 hydrogen chloride with ethylene.
    "Vinyl chloride  plant" includes
 any plant which produces vinyl chloride
 by any process.
  (o "Polyvinyl chloride plant" Include
 any plant where vinyl chloride alone or
 m combination with other materials la

   "Slip gauge" means a gauge which
 has a probe that moves through the gas/
 liquid interface In a storage or transfer
 vessel  and indicates the level of vinyl
 chloride  in  the  vessel by the physical
 state  of the material  the  gauge  dis-
 charges.
    "Grade of resin" means the sub-
division of resin classification which de-
scribes it aa a unique resin, U.. the most
exact description of a resin with no fur-
ther subdivision.
  (?)  "Dispersion resin" means  a resin
manufactured in such away as to form
fluid dispersions  when dispersed in a
plasticizer  or plastidzer/dlluent  mix-
tures.
  r«df service" n»»«n«
 that a piece of equipment contains or
 contacts either a liquid that is  at least
  10 percent by weight vinyl chloride or a
 gas that is at least 10 percent by volume
 vinyl chloride.
   (m)  "Standard operating procedure*
 means a formal written procedure offi-
 cially adopted by  the plant owner or
 operator and available on a routine bests
 to those persons responsible for carrying
 out the procedure.
   (n) "Run" means the net period of
 time during which an emission sample Is
 collected.
   (o) "Ethylene dichloride purification"
 includes any part of the process of ethyl-
 ene dichloride production which follows
 ethylene dichloride formation  and in
 which  finished ethylene dichloride is
 produced.
   

"Vinyl chloride purification" in- cludes any part of the process of vinyl chloride production which follows vinyl chloride formation <"*d in which «"*•>« ««i vinyl chloride Is produced. (q) "Reactor" Includes any vessel to which vinyl chloride is partially or tota&y polymerized into polyvinyl chloride. (r) "Reactor opening loss" means the emissions of vinyl chloride occurring when a reactor Is vented to the atmos- phere for any purpose other than an syl chloride* from polyvinyl chloride resin, except bulk resin, m the slurry form by the ve of heat and/or vacuum. In the case of bulk resin, stripper includes any vessel which is used to remove residual vtoyt chloride from polyvinyl chloride resin immediately following the polymerisa- tion step in the plant process flow. (t> "Standard temperature-means a temperature of 20* C <«9* F).3" "f pressure "Standard pressure" means a of 760 mm of Eg (2942 In. of 8 61.62 Emission standard for dichloride plants.3* . (a) Ethylene dichloride puriflci >n The concentration of vinyl chloride U aM exhaust gases discharged to th* -A- mosphere from any equipment u» it •ttrylene dichloride purification ia o< to exceed 10 ppm. except as providcu ir If 1.05(a). This requirement does not apply to equipment that has been op id, Is out of operation, and met the req e- Mot la i 61.65 (b) (6) (1) before j« epened^ (b) Oxyehlorination reactor: Ea st •« provided in § 61.85 (a), emission rf vinyl chloride to the atmosphere 1 n eaeb Oxyehlorination reactor are not to ^03 g/kg (0.0002 to/lb) of the "HI t ethylene dichloride product f a rsbJorinaaon process. piuu. An owner or operator of a vinyl chlo- ride plant shall comply with the require- ments of this section and 1 61.65. -If? Vinylchlortde formation and.pt . aeattpn: The concentration of vir chloride to all exhaust gases discharged to the atmosphere from any equipm used In vinyl chloride formation and purification is not to exceed 10 ppm. eept as provided in i 61.65(a). This re- quirement does not apply to equipm—; that has been opened, is out of operatl and met the requirement m I 61.65 (f > U) before being opened. rf for §61.64 eolorida plants. An owner or operator of a polyvtr-' chloride plant aheJl comply with the i ejkfreae&to of to* section and 161.SS. <•> Beeetor. The following require- apply to reactors: (!) The concentration of vinyl eh. Je in all exhaust gases discharged the atmosphere from each reactor ia c«« to exceed 10 ppm. except as provided in Paragraph (a) (2; of this section u f «L65 The reactor opening loss from eat reactor is not to exceed 0.02 g vinyl cbJortde/kg vinyl chlortd-' lb> of polyvinyl chloride product, wi the product determined on a dry soli basis. This requirement applies to ahy vessel which is used as a reactor or as both a reactor and a stripper. In U talk process, the product means U gnsa product of prepolymertzation an postpolymerizatton. (3) Manual vent valve discharge: Er ospt for an emergency manual vent valv discharge, there is to be no discharge t the atmosphere from any mnm.ni vent valve on a polyvinyl chloride reactor in •»snyl chloride service. An emergent manual vent valve discharge means i *Hsi SMI BU to the atsBosphei t which coul: as* have been avoided by taking meas- tsm to prevent the discharge. Within K 105


-------
    i ef «ny discharge to the atmosphere
from any manual vent valve, the owner
er operator of the source from which the
discharge occurs shall submit to the Ad-
ministrator a report in writing contain-
ing information on the  source, nature
and cause of the discharge, the date and
ttme of the discharge, the approximate
total vinyl chloride loss during the dis-
charge, the method used for determining
the vinyl chloride loss, the action  that
was taken to prevent the discharge, and
measures adopted to prevent  future dis-
charges.
   (D) Stilwer.  The concentration of
vinyl chloride in all exhaust gases dis-
charged  to the  atmosphere  from each
•tripper is not to exceed  10 ppm. except
M provided in 161.65 (a). This require-
ment does not apply to equipment  that
has been opened, is out of operation, and
•et the requirement In f 61.65(b) (6) (1)
before being opened.
   (c) Mixing,  weighing, and  holding
containers. The concentration of vinyl
chloride  In all exhaust gases discharged
to the atmosphere  from each  mixing.
weighing, or  holding container in vinyl
•blonde  service  which  precedes  the
stripper  (or the reactor if the plant has
a* eupper) in tttf plant proceas flow is
a** to exceed 10 ppm. except as provided
in I 61.83U). This requirement does not
apply  to  equipment that  has  been
opened, is out of operation, and met the
requirement  in  181.6S(b) (6) (1)  before
being opened.
   (d)  Monomer  recovery  system.  The
concentration of vinyl chloride in all ex-
haust  gases  discharged  to  the  atmos-
Ahere from far n monomer recovery  sys-
tem is not to exceed 10 ppm. except as
provided in | 61.65(a). This requirement
does not apply to  equipment that has
been opened, is out of operation, and met
the requirement in 161.65(b) (6) (1) be-
fore being opened.
   (e)  Sources following the stripper(t).
The following  requirements apply  to
emissions of  vinyl chloride  to  the at-
mosphere from the combination of all
sources following the stripper(s)  (or the
reactor(s)  If the plant has no strip-
per   Rotating   compressor.   Vinyl
 chloride emissions from seals on all ro-
 tating  compressors in vinyl chloride
 aarvtoe are to be minimized by installing
 compressors  with   double mechanical
 teals, or equivalent as provided in I 61.66.
 V double mechanical seals are used, vinyl
 chloride emissions from the «*•!? are to
 be minimized by '"••"••'•ting the pres-
 •we between  the two seals so that any
 leak that occurs is  into the
  (D  After each ^ir*tl1*ig or  unloading
operation and before opening a loading
or ufiloifttliiu UHB to
quantity of vinyl chloride In an parti of
each IfliiHTig or 'iHlftT^ifff ****• »*«•» gj^
to be opened to the atmosphere is to be
reduced so that the parts ••""^•wl con-
tain no greater than 0.0038 m1 (0,13 Of)
of vinyl chloride, at standard tempera-
ture and pressure; and
  (U) Any vinyl chloride removed from
             unloading  n*** in accord-
     wlth paragraph  (b) (1) (1) of this
section is to be ducted through a control
system from which the concentration of
vinyl chloride in the •»*«"««*  gases *VMr
not exceed 10 ppm. or equivalent as pro-
vided in i 61.66.
   (2> Slip gauges. During loading or un-
loading  operations,  the vinyl chloride
emissions from each slip gauge in vinyl
chloride  set vice are to be •DtmimJaed by
ducting  any vmyl chloride discharged
   	— —————— ^— ^B»V <^P» *«••••*• w^WV* •
 «y ducting any  vinyl chloride between
 the two seals through a control  system
 tram which the concentration of vinyl
 chloride In the exhaust gases does not
 exceed 10 ppm; or equivalent as provided
 to 161.06.
   (iv) Reciprocating compressors. Vinyl
 chloride «nn<««inT»f from tnfa on ill re-
 ciprocating compressors in vinyl chloride
                 seals, or equivalent as
          to  161.66. If double outboard
      are used, vinyl chloride emissions
      the seals are to be  minimized by
 maintaining the pressure between the
 two seals so that any leak that occurs Is
 Into  the compressor:  by ducting  any
 vinyl  chloride between  the  two  seals
 through a control system from which the
 concentration of vinyl chloride in the
 exhaust gases does not exceed  10 ppm:
 or equivalent as provided In } 61.66.
   (v>  Agitator. Vinyl chloride emissions
 tram seals on aQ agitators in vinyl chlo-
 ride service are to  be minimized by in-
                                                        106

-------
•tailing agitators vitb double mechani-
eml seals,  or equlvaleat as provided in
161.66.  IX double mechanical seals are
ueed. vinyl chloride emissions from the
seals are to be minimized by mf
the pressure between the two seals so
that any leak that occurs is Into the agl-
Uted vessel: by ducting any vinyl chlo-
ride between  the two seals  through a
control system from which the concen-
tration of vinyl chloride In the exhaust
gases does not exceed 10 ppm: or equiva-
lent as provided in f 61.66.
   (4) Leakage from relief vetoes. Vinyl
chloride emissions due to leakage from
each relief valve  on equipment in vinyl
chloride service are  to be minimized by
Installing a  rupture disk  between  the
equipment and the relief valve, by con-
necting the relief valve discharge to a
process line or recovery system, or equiv-
alent as provided in I 61.66.
   (5)  Manual venting of gates.  Except
as provided in  I 61.64(a)(3). all gases
which are manually vented from equip-
ment in vinyl chloride service are to be
ducted  through a control  system from
which the concentration of vinyl chloride
in the exhaust gases does not exceed 10
ppm: or equivalent as provided in I 61.66.
   (6)  Opening   of   equipment.   Vinyl
chloride  emissions  from  opening  of
equipment (including loading or unload-
ing lines that are not opened to  the at-
mosphere after each loading or unload-
ing operation) are  to be minimized as
follows:
   (1) Before opening any equipment for
any reason, the quantity of  vinyl chlo-
ride is to be reduced so that the equip-
ment contains no more than 2.0 percent
by volume vinyl chloride or 0.0950 m1 (25
 gal)  of  vinyl  chloride, whichever is
larger, at  standard temperature and
   (11) Any Tiny! chloride removed from
               jp mtmttm^mmfm With
 graph (b) (6) (1)  of this section to to be
 ducted through  a control system from
 which the concentration  of  vinyl chlo-
 ride in the exhaust gases does not exceed
 10 ppm, or equivalent as provided in
 I 61.66.
   (7)  Samples. Unused portions of sam-
 ples rf>n tain Ing  at least  10  percent by
 weight vinyl chloride an  to be returned
 to the p*wf nffi and sampling techniques
 are to be such that simple containers m
 vinyl chloride service are purged into a
 closed process system.
   (8)  Leak detection and ettminatfon.
 Vinyl  chloride  «*"*««>T due to leaks
 from equipment  in vinyl chloride service
 ere to be minimised by instituting  *****
                 formal  }*?*  detection
  to It includes a reliable end accurate
vinyl chloride monitoring system for de-
tection of-major leaks and identification
of the general area of the plant where a
leak is located. A vinyl chloride monitor-
ing system means a device which obtains
air  samples from one or more points on
a continuous sequential basis and ana-
lyzes the samples  with gas ehromatog-
raphy or. if the owner or operator as-
sumes  that all hydrocarbons measured
are vinyl chloride, with infrared spectro-
photometry. flame ion detection, or an
equivalent or alternative method.
  (11) It Includes a reliable and accurate
portable hydrocarbon detector to be used
routinely to find small leaks and to pin-
point the major leaks indicated by the
rtnyl chloride monitoring  system.  A
portable hydrocarbon detector means a
device  which  measures  hydrocarbons
with a sensitivity of at least 10  ppm
and is of such design and size that It can
be used to measure emissions from local-
ised points.
  (ill)  It provides for an acceptable cali-
bration *m*>  fnfl1n*fraT*rf schedule  for
the vinyl chloride monitoring system and
portable hydrocarbon detector. For the
vinyl chloride »p««"<*<"^"g system, a dally
span check  Is  to  be conducted with a
concentration of vinyl chloride equal to
the concentration defined as  a leak ac-
cording to paragraph (b) (8) (vi) of thb
section. The calibration to to be  done
with either:
  (A)  A calibration gas mixture  pre-
pared from the gases specified m sections
5.2.1 and 5.2.2  of  Test Method 108 and
in  accordance  with  section 7.1 of  Test
Method 106. or w
  (B)  A calibration gas  cylinder stand-
ard «"•*•*»«•'*••§; the appropriate concen-
tration of vinyl chloride. The gas com-
position of the calibration gas cylinder
standard to to have been certified by the
manufacturer.  The manufacturer mot

for each cylinder so that the
tton does not  change greater than
percent from the certified val
of  gas cylinder
vinyl chloride concentratk
     elimination program. iiie owiier or
 operator shall submit a description of
 the program to the Administrator for
 approval.  Hie program  is  to  be sub-
 mitted within 45 days of the  effective
 date of these regulations, unless a waiver
 of compliance is granted under 1 61.11.
 If a waiver of compliance is granted, the
 program is  to be submitted on a date
 scheduled  by  the  Administrator. Ap-
 proval of  a program will be granted by
 the Administrator provided he finds:
                   shelf Itfe mutt have
     affixed to the cylinder before ship-

 buyer. XT a
     vinyl  chloride
 these gas mixtures may be dbreetly used
 to prepare a ehr
Method
            m^^^^f ^^B ••> SB) ^^ Mkw^A
            section 73 of net
108. The reqntrements hi
 tton 5.2.3.1 and 5.24.3 of Test Method
 108 for certification of cylinder stand-
 ards and for establishment end verifica-
 tion of caUhrmtton standards are to be
 followed.*
   (lv) The location and number of points
 to be  monitored and  the frequency of
 monltorinK oravided for In the program
 are acceotable when they are compared
 with the number of pieces of equipment
 in vinyl chloride service and the size and
 physical layout of the plant.
   fv)  It contains an acceptable plan of
 action  to be token when a  leak la de-
tected.
  (vl)  It contains a definition  of  " ik
which is acceptable when compared   th
the background  concentrations of •  yl
chloride in the areas of the plant to be
monitored by the vinyl chloride monitor-
ing system. Measurements of backgrc  id
concentrations of  vinyl chloride in  te
areas of the plant to be monitored b> wie
vinyl chloride monitoring system are to
be included with the description of  «
program. The definition of leak fi  a
given plant may vary among the dii»* ••
eat areas within the plant and Is also to
change over  time as  background  <  -
centrations In the plant are reduce
  (9) /nprocess  wastewater. Vinyl c  -
ride «"!««< nng to  the  aniospbere from
toprocess wastewater are to be redu  1
as follows:
  (1) The  concentration of vinyl el  >
Me in each mprocess wastewater stream
containing greater than 10 ppm vi*"*!
chloride measured Immediately as  f
leaves a piece of equipment and bef  s
being mixed  with any other inproc«»
wastewater stream is to be reduced to no
more than 10 ppm by weight before be
mixed with any other inproeess waste?
tar stream which contains less than
ppm vinyl chloride: before being exposed
to  the atmoshere:  before being  tf4—
charged to a wastewater treatment pn
CM:  or before frying discharged untreai
as a wastewater.  This paragraph  du=»
apply to water which Is used to displace
vinyl chloride from equipment before
Is opened to  the atmosphere in  aceoi
ance with |61.64(a>(2> or paragra
(b) (6) of this section, but does not apply
to water which is used to wash out equl--
ment after the  equipment  has  alrea
been opened to the atmosphere in s
eordance  with  |61.64(a)(2>  or par.-
graph (b) (6) of this section,30
  (II)  Any vinyl chloride removed  fn
the  inproeess wastewater m accordu
with paragraph  (b) (9) (D of this sect!
to to be ducted through a control system
from which  the concentration of  vir-1
chloride in the  exhaust gases does a
exceed 10 ppm. or equivalent as iiruvlo
B 161.66.
    The requirements in paragraphs
 (b)(l). (b>(2). (b>(5>. (b)(6). (b>c
and (b) <8> of this section are to be ft
corporated into a standard operatiL,
procedure, and made available upon re-
quest for inspection by the Administri
tor. The standard operating procedure
to Include provisions for measuring tl
vinyl chloride In equipment a»4.75 m1
 (L250 gal) in volume for which an emia
Hen limit  to  prescribed in I 61.65(b) (6
 (1)  prior to opening thg equipment an
namg Test Method 106. a portable hydro-
carbon detector, or an equivalent or a)
ternative method. The method of meaa
urement Is to meet the requirements t
I 61.67(g) (5) (1)  (A) or (g> ((5) (1) (B).**

 tffcc 114 of tte Cfepa A» ,
 Cw) UAC U14M. *"
                                                           107

-------
 I 61.66  Eqwralcnt equipment and pre-
     codnrc*.
  Upoo written application from an own-
 er  or operator, the Administrator mar
 approve use of equipment or procedures
 which have been  demonstrated to his
 satisfaction to be equivalent in terms of
 reducing vinyl chloride emissions to the
 atmosphere to those prescribed for com-
 pliance with a specific paragraph of this
 •ubpart For an-existing source, any re-
 tjuest for using an  equivalent method as
 the initial measure of control Is to be
 •omitted  to  the Administrator within
 M days of the effective date. For a new
 source, any request for using an equiva-
 lent  method  is to  be submitted to the
 Administrator with the application tor
 approval of construction or modification.
 required by I 61.07.
 I 61.67
   (a)  Unless a waiver of emission testing
 Is obtained under 161.13. the  owner or
 operator of a source to which  this sub-
 pan  applies shall  test emissions from
 the source,
  (1) Within 90 days of the effective date
 m the case of an  existing source or a
 new source which has an initial startup
 date preceding the  effective date, or
   (2) Within 90 days of startup in the
 case of a new source, initial startup of
 which occurs after  the effective date.
  (b) The owner or operator shall pro-
 vide the Administrator at least 30 days
 prior notice of an emission test to afford
 the  Administrator  the  opportunity to
 have an observer present during the test.
  (c) Any emission test  is to be  con-
 ducted while the equipment being tested
 is operating at the maximum production
 rate at which  the equipment win be op-
 erated and under other relevant condi-
 tions as may be specified by the Adminis-
 trator based on representative perform-
 ance of the source.
  (d) [Reserved!3*
  (e) When at all possible, each sample
 to to be analyzed within 24 hours, but in
 no case In excess of 72 hours of sample
collection.  Vinyl  chloride
to be determined within 30 days after the
emission  test  The owner  or operator
shall report the determinations to the
Administrator by a registered letter dis-
patched before the close of the next buti-
ness day following the determination*
    Unless otherwise specified,  the
owner or operator shall use test Test
Methods in Appendix B  to this part for
each  test  as required  by  paragraphs
(CHI).  (g>(2).  (g)(3).  (g)(4),   and
(g) (3) of this section, unless an equiva-
   t  method or an alternative  method
has been approved by the Administrator.
If the  Administrator finds .reasonable
grounds to dispute  the results obtained
by an equivalent or alternative method.
he may require  the use  of  a reference
method. If the results of the reference
 and equivalent or  alternative methods
 do not agree, the results obtained by the
 reference method prevail,  and the Ad-
 ministrator may notify the  owner  or
 operator that approval of the  method
 previously considered to be equivalent or
 alternative is withdrawn.
 \Vhcacver T«t Method 107 Je specified.
 and the conditions in Section 1.1.
 "Applicability- of Method 107A are met
 Method 107A may be Mod71

   (1) Test Method 106 is to be used to
 determine  the vinyl chloride emissions
 from any source for which an emission
 limit is prescribed in || 61.62(a) or (b)
 |61.63(a),or H61.64(a)(l). (b). (c).or
 (d). or from any control system to which
'reactor emissions  are required to  be
 ducted in 161.64(a) (2) or to which fugi-
 tive emissions are required to be ducted
 is  |61.65(b)(l)(ii>,  (b)(2).  (b>(5).
 (b) (6X11).or (b)(9)(11).
   <1> For each run. one sample is to  be
 collected. The sampling site Is to be  at
 least two stack or duct diameters down-
 stream  and one half diameter upstream
 from any  flow  disturbance such as a
 bend, expansion, contraction, or visible
 flame. For a rectangular cross section an
 equivalent diameter is to be determined
 from the following equation:
tton:
                            | iooi
                                            equivalent diameter=3
                        (length) (width)
                         length-f width
 The sampling  point  in  the duet is to
 be at the centrold of the cross section.
 The sample is  to be extracted at a rate
 proportional to the  gas  velocity at the
 sampling point  The  sample  is to  be
 taken over a minimum of one hour, and
 is to contain a "»^***wfn volume of SO
 liters corrected to standard conditions.
    Each emission test is to consist of
 three runs. For the purpose of determin-
 ing  emissions,  the average  of results of
 all runs is to apply. The average is to be
 computed on a time weighted basis.1*
   (Ill)  For gas 'Streams rttnTitr|*i*y more
 than 10 percent oxygen the concentra-
 tion of vinyl chloride as determined by
 Test Method 106 is to be corrected to 10
 percent oxygen (dry basis)  for determi-
 nation of i>i*it*f1flTiiT by using t^t^ follow-
 ing equation:
      C< <
                         10J
                   20.9—percent O,
                   concentration  of  vinyl
     chloride in the exhaiut goes, corrected
     to lO-percent oxygen.
   C»=The concentration of vinyl chloride M
     meaning by Ten Method 106.
   30.9=Percent oxygen in the ambient air at
   10.9
        Percent oxygen la the ambient air at
            ~ condition*, minus the lOA-per-
     cent oxygen to which the correction to
   Percent Q,= Percent oxygen m the eihauet
     gai M measured by Reference Method I
     la Appendix A of Part 60 of this chapttJ*

   (tv)  For those emission sources where
 the emission limit is prescribed in terms
 of mass rather than concentration, man
 emissions in kg/100 kg product are to be
 determined by using the following equa-
                                                            108
where:
  C»=kg vinyl chloride/100 kg product
  C«=The concentration of vinyl chloride a*
    measured by Ten Method 106
  3.60= Density  of vinyl ehlonde at one
    atmoaphere and 30* C tn kg/m '
  Q = Volumetric flow rate in mvhr a* de-
    termined by Reference Method 3 of Ap-
    pendix A to Part SO of thia chapter.
  10-*= Coo version factor for ppm.
  2= Production rate (kt/ar). 3*

  (2) Test  Method 107 is  to be used to
determine  the concentration  of  vinyl
chloride  in each  inprocess wastewater
stream for  which an emission  limit is
prescribed in I 61.65* b) (9) (i).
  (3)  Where a stripping operation is
used to attain the emission limit in i 61.-
f4(e). emissions  are to be determined
using Test Method 107 as follows:
  (1)  The number of strippers and sam-
ples and  the types and grades of resin to
be sampled  are to be determined by the
Administrator for each individual plant
at  the time of the  test  based on the
plant's operation.
  (11) Each sample is to be taken Imme-
diately following the stripping operation.
  (ill) The  corresponding quantity  of
material processed by each stripper is to
bo determined on a dry solids basis and
by a method submitted to  and approved
by  the Administrator.
  (lv) At the prior request of  the Ad-
ministrator. the owner or operator shall
provide  duplicates of the samples re-
quired in paragraph  (g)(3)(l)  of this
section.
  (4)  Where control technology other
than or In addition to a stripping opera-
tion is used to  attain the emission limit
In 1 61.64(e) . emissions are to be  deter-
mined as follows:
  (1)  Test  Method 106 is  to be used to
determine  atmospheric »»»»i««*«w«« from
aD.  of the process equipment simultane-
ously. The  requirements of paragraph
(g) d) of thta section are to be met.
  (II)  Test  Method 107 is  to be used to
determine  the concentration  of  vmyl
chloride  in each  mproceu wastewater
stream subject to the emission limit pre-
scribed m 1 61.64(e>. The  mass  of Ttnyl
chloride  in  kg/100 kg product  in each
In process wastewater stream is to be de-
termined by using the following equa-
tion:
         CM:
                       11001
 C»-kf vinyl ehMdr/lOB tor product.
  C«
-------
  to to be made IB to be specified by the
  Administrator for each individual plant
  at the time ot the determination bawd
  on the plant's operation. For a reactor
  that is also used as a stripper, the deter-
  mination may be made Immediately fol-
  lowing the stripping operation.
   /4\ •te^h^MbAt ^m • •• •< J • ^ ^M __ _ _ _  .
   \1> sUCept mm PCOTMMO tt psUBCnpO
  pm.
   Ct.ppm by Tolone »inyl chloride u determined br
        Tan Method  lot or & portable hydrocarbon
        detector  which measure* brdrocarbom
        with a tenitintr  of at leait 10 ppm.
    y- Number of batches sine* the reactor WM iMt
    _   opmdtotlMatinoaphm.
    Z-Awate kf or polyrtnyl chloride produced p*
        bitch In the number of batches Awe th> naeur
        wat UK opened to the umatftun.

   (A)  If Method 106 is used to deter-
 mine the concentration of vinyl chloride
  If a portable hydrocarbon detec-
 tor is used to determine the concentra-
 tion  of vinyl  chloride  . a probe of
 sufficient length to reach the vessel bot-
 tom from  the manhole is  to be used to
 make the measurements. One measure-
 ment will be made within 6 inches of the
 vessel bottom, one near the vessel center
 and one near  the vessel top. Measure-
 ments are to be made  at  each location
 until the reading is str blitzed. All hydro-
 carbons measured are to be assumed to
 be vinyl chloride.
•^  The production rate of pofrvmyl
 chloride (Z) is to be determined  by a
 method submitted to and approved by the
           w
  (ID  A calculation based on the number
of evacuations, the vacuum involved, and
the volume of gas in the reactor is hereby
approved by the Administrator as an al-
ternative method for determining reac-
tor opening loss for postpolymertxatton
   cton in  the  manufacture of  bulk
       l« of tbe
 (41QAC T414U.
| 61.68  Eauaoaet moBhwiag.
  (a) A vinyl chloride monitoring
tern is to be used to monitor on a con-
tinuous  basis  the emissions  from  the
sources for which emission limits are pre-
scribed in 16l.62(a> and 0». f 61.63.
and f 61.64. (b),  <8) (1) may be used to meet
 the requirements of this section.
   (c)  A daily span check is to be eon-
 ducted for each vinyl chloride monitor-
 ing system used.  For all of the •«««•«««•»
 sources listed in paragraph . (bH3>.
                                         («). (b)<7). and   are b*_j
                                         implemented.
                                           (b) (1)  In the  case of  an  exist'
                                         source  or a new source which has
                                         initial startup date preceding the efl
                                         ttve date, the statement is to be submit-
                                         ted within 90 days of the effective dot*.
                                         unless a waiver of compliance Is gran
                                         under \ 61.11.  along with the Inforz
                                         tion required under S 61.10.  If a wal—
                                         of compliance  is granted, the statement
                                         is to be submitted on a date schedu
                                         by the Administrator.
                                          (2) In the case of a new source whi
                                         did not have an initial startup date pre-
                                         ceding the effective date, the stateme-*
                                         is to be submitted within 90  days of tl
                                         initial startup date.
                                          (c) The statement is to contain the
                                         following Information:
                                          (1) A list  of  the equipment install)
                                         for compliance.
                                          (2)' A description of the physical at_
                                         functional  characteristics of  each piece
                                         of equipment.
                                          .(3> A description  of  the meth«
                                        which have been incorporated into tt
                                        standard operating procedures for meas-
                                        uring or calculating the  emissions  fr-
                                        which emission limits are prescribed i
                                        1*1.65   (l)(i) and (b)(6>(l).
                                          (4)  A  statement that each piece of
                                        equipment  is installed  and  that each
                                             of equipment and each procedui
£   161.70  Snm.rmu.1 report.
      (a>  The  owner  or  operator of ar-
    source to which this subpart applies shi
    submit to the Administrator on Septet
    ber IS and March IS of each year a report
    in writing  containing  the information
    required by this section. The first sem
    annual report is to be  submitted f olloi
    ing the first fun 6 month reporting perlba
    after, the initial report is submitted.*9
      (bXl) In the case of an existing sour
    or a new source which has  an Inttii
    startup date preceding the effective dat
    the first report is to be submitted within
    1M days of the effective date, unless -
    waiver of compliance  is granted und<
    161.11. Xf a waiver of compliance •
    granted,  the first report is to be sub-
   mitted on a date scheduled by the Ad-
   minis Lrator.
     (S> In the ease of a new source whlc
                                       did not have an initial startup date pn
                                       ceding the effective date, the first report
                                       Is to be submitted within 180 days of th~
                                       mlttal startup date.
                                         (c)  Unless otherwise  specified,  th
                                       owner or operator shall use the  Test
                                       Methods in  Appendix B to this part to
                                       conduct  emission  tests as  required b,
                                       paragraphs  <3)  of thl
                                       section, unless an equivalent or an alter
                                       native method has been approved by the
                                       Administrator.  If  the AdministraUr
                                       finds irairuuliU grounds to dispute thi
                                       results obtained by an equivalent or al
                                       tentative method, he may require the use
                                                         109

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 of a reference method. If the results of
 the reference and equivalent or alterna-
 tive methods do not. agree, the results
 obtained  by the reference method pre-
 vail. and the Administrator may notify
 the owner or operator  that approval of
 the method previously  considered to be
 equivalent or alternative is withdrawn.
   (1)  The  owner or operator  shall In-
 clude in the report a record of any emis-
 sions  which  averaged  over any hour
 period  (commencing on  the hour)  are
 in  excess of the emission  limits pre-
 scribed in Si 61.62(a) or (b). I 61.63(a>.
 or |61.64(a)(l). . (c), or (d). or for
 any control  system to  which  reactor
 emissions are required  to be ducted in
 I 61.64(a) (2) or to which fugitive emis-
 sions are  required to be ducted In § 61.65
 (bXIXli). . (b)(5). (b) (6) (11). or
 (b) (9) (11) . The emissions are to be meas-
 ured in accordance with { 61.68.
  (2)  In  polyvinyl chloride plants  for
 which a  stripping operation is used to
 attain the emission level prescribed in
 I61.64(e). the owner or  operator shall
 include in  the  report  a  record  of  the
 vinyl chloride content  in the polyvinyl
 chloride resin. Test Method 107 b to be
 used to determine vinyl chloride content
 at follows:
  (1) If batch stripping is used, one rep-
 resentative sample of polyvinyl chloride


 ing the completion of the stripping op-
 eratlon. and identified by  resin type ""*
 grade and the date and time the batch
 is completed. The corresponding quan-
 tity of material processed in each strip-
 per batch is to  be recorded and  Identi-
 fied  by resin type and grade and  the.
 date and  time the batch is completed*
   (11)  If continuous stripping is     .
one  representative sample of polyvinyl
chloride resin is to be taken for each
grade of resin processed or at intervals
of 8  hours for each grade of resin which
is being processed, whichever is more fre-
quent.  The sample is to be taken as  the
resin flows out of the stripper and Iden-
tified by resin type and grade and  the
date and time  the sample was  taken.
The  corresponding quantity of material
pnrmnrl by each stripper over the time
period  represented by the sample during
tho_fjjfhi hour period, is to be recorded
AMtfl  A^^^iBAMl^^V ^^B ^^^*A^ *^.^hA A^.^ ^^^^A
BBS  MBBBDeQ or ram type ana graae
•ad  the date and ttme tt  represent.
  (Hi)  The quantity of material proc-
    1 by the stnpper is to be determined
on a dry solids  basis and  by a method
submitted to and approved by the Ad-
ministrator.
   of this section, aver-
aged separately for each type of resin.
over each calendar day and weighted
according to Uie quantity of each grade
of natal proeesMd by  the strtpp«r(a)
that calendar day. according to the fol-
lowing equation:
               -1 Pa,
                 Or.
wfatre.
  4=M-boer avenge concentration of type.
    T i rain ia ppm (dry weight bull).
  9. =Total production of type T \ r«la over
    the 24-hour period, in kg.
  r «=Tvpe of rarta: 1=1.3 . .. m where m
    tt total number of resin types produced
    during the 34-hour period.
   (vl) The owner or operator shall re-
 tain at the source and  make available
 for Inspection by the Administrator for
 a minimum of 2 years records of all data
 needed to furnish  the information re-
 quired by paragraph  (cXSXv) of this
 section: The records are to contain the
 following  information:
   (A)  The vinyl chloride content found
 in all the samples required in paragraphs
 (c) (2> (1)  and (c) (2) (11) of this section.
 identified by the resin type and grade
 and the time and date of the sample, and
   (B)  The corresponding  quantity  of
 polyvinyl  chloride resin processed by me
 stripper(s). identified  by the resin type
 and  grade  and the ttme and data It
 represents.
   (3) The owner or operator Shan In-
clude B the report a record of the emis-
sions from each  reactor  opening  for
which an  emission limit  is prescribed In
I 61.64 (a)  (2). Emissions are to be deter-
mined in accordance with 181.67(g) (5).
except that emissions for  each reactor
are to be determined. For a reactor that is
also used as a stripper, the determination
may  be made immediately following the
stripping operation.

cstae. 114 ef tt
C4IUAC1414IL'
                                         J»=O»noeaBmtk» of wnyl chloride in one
                                           •mat* of grade O • peeia. in ppm.
                                         FsProducttoa of grade C,  resin repre-
                                           sented by the sample, in kg.
                                         O ,=Grade of rests. e.g» O,. O,. and O,.
                                         »=Totai number of grades of resin pro-
                                           duced during the 34-hour period. M
                                        161.71  Recerdkecping.
                                          (a)  The  owner or  operator of any
                                       source to which this subpart applies shall
                                       retain the following information at the
                                       source and make it available for Inspec-
                                       tion by the Administrator for a  mini-
                                       mum of two years:
                                          (1) A record of the  leaks detected  by
                                       the vinyl chloride monitoring system, as
                                       required by } 81.65'b) (8). including the
                                       concentrations   of   vinyl   chloride
                                       measured, analyzed, and recorded by the
                                       vinyl chloride detector, the  location of
                                       each measurement and the date and ap-
                                       ptOTlmsrit time of each measurement.
                                          (2) AfBoard of the leaks detected dur-
                                       uuLroatlac, monitoring with the portable
                                       hydrocarbon detector and  the  action
                                       taken to  repair  the leaks, as required
                                       by 161.65(b> (8). including a brief state-
                                       ment explaining  the location and cause
                                       of each leak detected with the portable
                                       hydrocarbon detector, the date and time

                                                                     token  to
                                          (3)  A record of emissions measured
                                       to smirrtsiB i with i 61.68."
                                          (4) A daily operating record for each
                                       polyvinyl  chloride  reactor, including
                                        <8tac, 114 ef tt
                                        M8OAC14M1L
                                         38 FR 8826. 4/6/73  (1)

                                           as mended
                                              41 FR 46560.  10/21/76 (28)
                                              41 FR S3017.  12/3/76 130)
                                                            6/7/77 (38)
                                                            8/17/77 (40)
                                               42 FR 29005,
                                               42 FR 41424. _	
                                               43 FR 8800. 3/3/78  (47)
                                               47 FR 39485. 9/8/82 (71)
                                                         110

-------
Standard fof Eqi
 lalEmtolon
jpjrwnt Leaks
(Fugttv* Emission Sourc**) of
        97
141.110
  (a) The provision* of this subpart
apply to each of the following sources
that are intended to operate in benzene
service' pumps, compressors, pressure
relief devices, sampling connections.
systems, open-ended valves or lines.
valves, flanges and other connectors.
product accumulator vessels, and
control devices or systems required by
this subpart
  (b) The provisions of this tubpart do
not apply to sources located in coke by-
product plants.
  (c)(l) If an owner or operator applies
for one of the exemptions in mis
paragraph, then the owner or operator
shall maintain records as required in
I 61.246(i).
  (2) Any equipment in benzene service
that ia located at a plant site designed to
produce or use less than 1.000
megagrams of benzene per year »
exempt from the requirements  of
161.112.
  (3) Any process unit (defined in
181.241) that has no equipment in
 DRUMIv •QlvlCv IS CXcOpI EPDB tfi€
 requirements of f 61.112.
   (d) While the provision of this
 subpart an effective, a source to which
 this subpart applies that ia also subject
 to the provisions of 40 CFR Part 60 onlv
 will be required to comply with the
 provisions) of this subpart.
faun
  As used in thia subpart all terms not
defined herein shall have the meaning
given them in the Act in Subpart A of
Part 61. or in Subpart V of Part 61. and
the following terms shall have the
specific meanings given them:
  "In benzene service" means that a
piece of equipment either contains or
contacts • fluid (Liquid or gas) that ia at
bast 10 percent benzene by weight as
determined according to the provisions
ef 1 61.243(41. The provisione of
1 61.245(4) also specify how to
dateiBino that • piece of equipment ia
not in benzene service.
               means a 0-month
period: the first semiannual period
concludes on the bat day of the last
month daring the 180 days following
initial startup for new sources: and the
first semiannual period concludes on the
last day of the last full month during the
180 days after June 8. 1984 for existing
1 81.113
  (a) Each owner or operator subject to
the provisions of this subpart shall
comply with the requirements of
Subpart V of this part.
 . (b) An owner or operator may elect to
comply with the requirements of
I 8U43-1 and 1 81.243-2.
  (c] An owner or operator may apply to
the Administrator for a determination of
an alternative means of emission
limitation that achieves a reduction in
emissions of benzene at leas: equivalent
to the reduction in emissions of benzene
achieved by the controls required in this
subpart In doing so. the owner or
operator shall comply with requirements
Of | 81.244.
f61.11V81.11t
                                               ]
                                                                 38 FR 8826. 4/6/73 (1)

                                                                   as aacnded

                                                                      49 FR 23498.  6/6/84 (97)
                                                         111

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   Subpart V-Matfond EmtoaJon
   Standard for Equipment Leaks
   (Fugitive Emiaalen Source*)"

   §61.240 AopftcaMttyafidoeaJgnattonof

    (•) The provisions of this subpar.
   apply to each of the following sources
   thai are intended to operate in volatile
   hazardous air pollutant (VHAP) sen-ice:
   pumps, .compressors, pressure relief
   devices, sampling connection systems.
   open-ended valves or lines, valvps.
   flanges and other connectors, product
   accumulator vessels, and control
   devices or systems required by this
   •ubpart.
    (b) The provisions of this subpart
   apply to the sources liste J in paragraph
   (a) after the date of promulgation of a
   specific subpart in Part 61.
    (c) While the provisions of this
   subpart are effective, a source to which
   this subpart applies that ia also subject
   to the provisions of 40 CFR Part 60 milt
  will be required to comply with the
  provisions of this subpart.

  fl6U4l  DaBjeHuna.
    Aa used in this subpart all terms not
  defined herein shall have the meaning .
  oven them in the Act in Subpart A of
  Part 61. or ia specific subparts of Pan 61.
  and the following terms shall have
  specific meaning given them:
    "Closed-vent system" means a system
  that is not open to atmosphere and that
  is composed of piping, connections, and.
  if necessary. Dow-inducing devices that
  transport gaa or vapor from a piece or
  pieces of equipment to • control device
   "Connector means, flanged, screwed.
  welded, or other joined fittings used to
  connect two pipe lines or a pipe line and
  a piece of equipment
   "Control device" means an enclosed
 combustion device, vapor recovery
 system, or flare.
   "Double block and bleed system-
 means two block valves connected in
 aeries with a bleed valve or line that can
 vent the line between me two block
 valves.
   "Equipment- meana each pump.
 compressor, pressure relief device.
 aampling connection system, open-
 ended valve or line, valve, flange or
 other connector, product accumulator
 vessel in VHAP service, and any con:m|
 devices or systems required by this
 subpart.
   'First attempt at repair" means to
-take rapid action for the purpose of
 stopping or reducing leakage of org*n«.
 material to atmosphere  using best
 practices.
    "In gas/vapor service" means that»
  piece of equipment contains process
  fluid that is in the gaseous state at
  operating conditions.
    "In liquid service" means that a piei.e
  of equipment is not in gas/vapor semrp
    "la-titu sampling systems" means
  nonextractivp samplers or in-line
  samplers.
    "In vacuum service" means th«*i
  equipment is operating at an intern.,!
  pressure which is at least 5 kilopascalb
  (kPa) below ambient pressure.
    "In VHAP service" means that a p»»i>
  of equipment either contains or conun*
  a fluid (liquid or gas) that ia at least 10
  percent by weight a volatile hazardous
  air pollutant (VHAP) aa determined
  according to the provisions of
  161 J45(d). The provisions of 16U4S(d)
  also specify how to determine thai •
  piece of equipment ia not in VHAP
  service.
    "In VOC service" means, for the
  purposes of this snbpart that (a) the
  piece of equipment contains or contacts
  a process fluid that ia at least 10 percent
  i^FS? we!?ht (sae *° CFR 80-2 for i»*
  definition of volatile organk compound
  or VOC and 40 CFR 80.486(d) to
  determine whether a  piece of equipment
  is not in VOC sen-ice) and (b) the piece
  of equipment is not in liquid service as
  defined in 40 CFR 60.481.'"
   "Open-ended valve or line" meana
  any valve, except pressure relief valves.
  having one side of the valve seat ia
  contact with process fluid and one side
  open to atmosphere, either directly or
  through open piping.
   "Pressure release" meana the
 emisaiaa of materials  resulting from the
 system pleasure being greater than the
 set pressure of the pressure relief
 device.
   "Process unit" means equipment
 assembled to produce a VHAP or its
 derivatives aa mtemediatas or final
 Piquets, or equipment assembled to use
 • VHAP in the production of a product

 independently if supplied with sufficient
 feed or raw matariala and sufficient
 product storage facilities.
  "Process unit shutdown" mM«it a
 work practice or operational procedure
 that stopa production from a process
 unit or part of a process unit An
 unscheduled work practice or
 operational procedure  that stops
 production from a process unit or part of
 a process unit lor leas thaa 24 hours is
 not a process unit shutdown. The use of
spare equipment and technically
 feasible bypassing of equipment without
stopping production are not process unit
  shutdowns.
    "Product accumulator vessel*' means
  any distillate receiver, bottoms receiver.
  surge control vessel or product
  separator in VHAP service that is
  vented to atmosphere either directly or
  through a vacuum-producing system. A
  product accumulator vessel is in VHAP
  service if the liquid or the vapor in the
  vessel is at least 10 percent by weight
  VHAP.                   *   *
   "Repaired" means that equipment is
  adjusted, or otherwise altered, to
  eliminate a leak as indicated by one of
  the following: an instrument reading of
  10400 ppm or greater, indication of
  liquids dripping, or indication by a
 swar that • Mel ar barrier fluid system
 D4U i8u0^aL
   "Semiannual" means a B-month
 period! the flat samiaafiual period
 coodades oa the last day of the last
 month during the 180 days following
 initial startup for aew sources;  and the
 first semiannual period concludes on tat
 last day of the last full month during the
 180 days after the effective dale of a
 specific subpart that references tius
 subpart far existing sou
                 is device that
 	i • physical quantity or the
 dungs in a physical quantity, anch as
 temperature, pressure, flow rate. pH, or
 liquid level
   "Volatile Hazardous Air Pollutant" or
 -VHAP" mesas s substance regulated
 under this subpart for which a standard
 for equipment leaks of the substance has
 been proposed and promulgated.
 •	T is a VHAP.
 M1243-1
   (a) Each owner or operator subject to
 the provisions of this subpart shall
 J	       •     iwiththe
requirements of I 61-242-1 to 181.242-11
for each new and existing source aa
required fat 40 CFR 6L05. except as
provided in 161J43 and 16L244.
  (b) Ownntianre with this subpart will
be detemmed by review of records.
review of performance test results, and
inspection using the methods and
pioceduiee specified ia 161.245.
  (cHl) An owner or operator may
request a determination of alternative
Beans of emission ttmitation to the
"•Illliailil	Of II 61.242-2.61.242-3.
61.242-5. 61.242-6.
        8L242-7.81242-6.81.242-9 and
61.242-11 aa provided in 161.244.'"
  (2) V the Administrator makes  a
determination that a meana of emission
limitation is at tenet a permissible
alternative to the requirements of
II 61.242-2.61.242-3.61.242-6.61.242-6.
61J42-7.61.244-a, 61-242-« or 61.242-11.
                                                         112

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an owner or jperator shall comply with
the requirements of that determination.
   (d) Each piece of equipment to which
this subpa/t applies shall be marked in
such a manner that it can be
distinquished readily from other pieces
of equipment
   (e) Equipment that is in vacuum
service is excluded from the
requirements of 161.242-2. to ( 61.242-
11 if it to identified as required in
|61.246(e)(5).

111.243-2  Standards: Pumps.
   |a)|l) Each pump shall be monitored
monthly to detect leaks by the methods
specified in 161.24S(b). except as
provided in 16L242-l(c) and
paragraphs (d), (e). and (f) of this
section.
   W Bach puaap ahedl be chackad by
visual mapecaen each calendar week
for indications of liquids dripping from
the pump seal.
   (bfll) if an instrument reading of
10.000 ppm or greater to measured a
leak is detected
   (2) If there an indications of liquids
dripping from the pump seal a leak is

   (c)(l) When a leak to detected it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
detected except as provided in 161.242-
10.
  (2) A first attempt at repair shaD be
made no later than 5 calendar days after
each leak to delected
  (d) Each pump equipped with a dual
mechanical seal system that includes a
barrier fluid system to exempt from the
requirements of pargnph (a), provided
the following requirements are met
  (1) Each dual mechanical seal system
to:
  (i) Operated with the barrier fluid at a
pressure that to at all times greater than
the pump staffing box pressure: or
  (ii) Equipped with a barrier fluid
             rior that is connected by
• dosed>vent system to a control device
that complies with the requirements of
  fiii) Equipped with a system that
purges the barrier fluid into a process
stream with zero VHAP emissions to
atmosphere.
  (2) The barrier fluid is not in VHAP
service and if the pump is covered by
standards under 40 CFR Part 60. is not in
VOC service.
  (3) Each barrier fluid system is
equipped with a sensor that will detect
failure of the seal system, the barrier
fluid system, or both.
                                         (4) Each pump is checked by visual
                                       inspection each calendar week for
                                       indications of liquids dripping from the
                                       pump seal
                                         (5)(i) Each sensor as described in
                                       paragraph (d](3) of this section is
                                       checked daily or is equipped with a
                                       audible alarm, and
                                         (li) The owner or operator determines.
                                       based on design considerations and
                                       operating experience, a criterion that
                                       indicates failure of the teal system, the
                                       barrier fluid system, or both.
                                         (6)(i) If there are indications of liquids
                                       dripping from the pump seal or the
                                       sensor indicates failure of the seal
                                       system, the barrier fluid system, or both
                                       based on the criterion determined in
                                       paragraph (d)(5)(li). a leak is detected
                                         (ii) When a leak is detected it ahall be
                                       repaired aa soon aa practicable, bat not
                                       later than 15 calendar days after it is
                                       detected exoapt aa ppavtoM • | tL242-
                                       10.
                                         «ii) A first attempt at repair shall be
                                       made no later than 5 calendar days after
                                       each leak ia detected
                                         (•) Any pump that ia designated aa
                                       described in | B1.246(e)(2). for no
                                       detectable emissions, as indicated by an
                                       instrument reading of lass than 500 ppm
                                       above background is exempt from the
                                       requirements of paragraphs (a), (c). and
                                       (d) if the pump:
                                         (1) Has no externally actuated shaft
                                                          Bflllfl
                                         (2) Is demonstrated to be operating
                                       with no detectable
                     lie
indicated by an instrument reading of
leas than 500 ppm above bacVcround as
measured by the method specified in
161.245(c), and
  (3) to tested for compliance with
paragraph (e)(2) initially upon
designation, annually, and at other times
requested by the Administrator.
  (Q tf any pump to equipped with a
closed-vent system capable of capturing
and transporting any leakage from the
seal or seals to a control device that
complies with the requirements of
16L242-ll.it to axampt from the
requirements of paragraphs (aH«)-
  (g) Any pump that is located within
the boundary of aa unmanned plant site
to exempt from the weekly visual
inspection requirement of paragraphs
(a)(2) and (d)(4) of this section, and the
daily requirements of paragraph (d)(5)(i)
of this section, provided that each pump
to visually inspected as often ss
practicable and at least monthly.
                  with a seal system that includes a
                  barrier fluid system and that preven'*
                  leakage of process fluid to atmospht
                  except as provided in 1 81.242-l(cJ i
                  paragraphs (h) and (i) of this section.
                    (b) Each compressor seal system ••
                  required in paragraph (a) ahall be:
                    (1) Operated with the barrier fluid   s
                  pressure that is greater than the
                  compressor stuffing box pressure: or
                    (2) Equipped with a barrier fluid
                  system that is connected by a closed
                  vent system to a control device that
                  complies with the requirements of
                  1 61742-11: or
                    (3) Equipped with a system that
                  purges the barrier fluid into a process
                  stream with zero VHAP emissions to
                  atmosphere.
                    (e) The barrier fluid ahall not be in
                  VHAP service and if the compressor is
                  covered by standards under 40 CFR Pc-«
                  aa shall not be in VOC service.
                    (d) Each barrier fluid system as
                  described in paragraphs (aHc) of this
                  section shall be equipped with a sens'"
                  that will detect failure of the seal
                  system, barrier fluid system, or both.
                    (e)(l) Each sensor aa required in
                    paragraph (d) of this section shall b-
                  chocked diuly or ahall be equipped wi
                  an aaeHble alarm unless the compress
                  is located within the boundary of an

                    (2) The owner or operator shall
                  determine, based on design
                  considerations and operating
                  experience, a criterion that indicates
                  failure of the seal system, the barrier
                  fluid system, or both.
                    (0 Ix the sensor indicates failure of the
                  seal aystam,ta* banter fioid system, o-
                  both baaed on the criterion determined
                  under paragraph («X2) of this section, i
                  leak is detected
                    IgUD Whan a kak to detected it aha"
                  be repaired aaaoono practicable, but
                  not later than 15 calendar days after it
                  detected except aa provided in 1 61.242-
                  10.
                    (2) A first attempt at repair shall be
                  made no later than 5 calendar days afti
                  eack leak to detected
                    (n) A compressor to **T* from the
                  requirements of paragraphs (a) and (b)
                  it to equipped with a doseeVvent systei
                  capable of capturing and  transporting
                  any leakage from the seal to a control
                  device that ""T^'IH with tht
161.242-a
  (a) Each
shaO be equipped   above backg
                                                                             requirements of 1 81.242-11. except as
                                                                             provided in paragraph (i).
                                                                               (i) Any Compressor that to designated
                                                                             as described in 1 61 J48(e)(2). for no
                                                                             delectable emission aa indicated by an
                                                                             Instrument reading of less than 500 ppm
                                                                                              to exempt from the
                                                       113

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requirement* of paragraphs (aHh) if the
compressor!
  (1) Is demonstrated to be operating
with no detectable emissions, as
indicated by an instrument reading of
lesi than 500 ppm above background, as
measured by the method specified in
i 81 J45{c): and
  (2) Is tested for compliance with
paragraph (i](l) initially upon
designation, annually, and at other times
requested by the Administrator.

111.242-4
   (c) ln~»itu sampling systems are
 exempt from the requirements of
 paragraphs (a) and (b).

 ! C1.242-4 Standards: Opefrended vetoes
    (a) Except during pressure releases.
  each pressure relief device in gas/vapor
  service shall be operated with no
  detectable emissions, as indicated by an
  instrument reading of less than 500 ppm
  above background  as measured by the
  method specified in 161 -243(c).
    (b)(l) After each pressure release, the
  pressure relief device shall be returned
  to a condition of no detectable
  emissions, as indicated by an instrument
  reading of less than 500 ppm above
  background as soon as practicable, but
  BO later than 5 calendar dayi after each
  pressure release, except as
  provided in 161.242-10.>1:
   (2) No later than B calendar days after
  the pressure release, the pressure relief
  device shall be monitored to confirm the
  condition of no detectable emissions, as
  indicated by an instrument reading of
  less than 500 ppm above background as
  measured by the method specified in
  161 MS(e).
   (c] Any pressure relief device that is
  equipped with a closed-vent system
  capable of capturing and transporting
  leakage from the pressure relief device
  to a control device as described in
  161.242-11 is exempt from the
 requirements of paragraphs (a) and (b).



  . W E«ch sampling  connection system
 ahall be equipped with a closed-purge
 system or dosed vent system, except aa
 provided to | n-242-l(c).
   (b) Each dosed-purge system or
 dosed-vent system as required in
 paragraph (a) shall:
   (11 Return the purged process fluid
 directly to the process one with zero
 VHAP emissions to atmosphere: or
  (2) Collect and recyde the purged
 process fluid with zero VHAP emissions
 to atmosphere: or
  (3) Be designed and operated to
 capture and transport all the purged
process fluid to a control device that
complies with the requirements of
 I 61.242-11.
   (a)(l) Each open-ended valve or line
 •hall be equipped with a cap. blind
 flange, plug, or a second valve, except
 as provided in 1 61 J42-l(c).
   (2)The cap. blind flange, plug, or
 second valve ahall seal the open end at
 all times except during operations
 requiring process fluid flow through the
 open-ended valve or line.
   (b) Each open-ended valve or line
 equipped with a second valve shall be
 operated in a manner such that the
 valve on the process fluid end is dosed
 before the second valve is dosed.
   (c) When a double block and bleed
 system is being used, the bleed valve or
 line may remain open during operations
 that require venting the line between the
 block valves but shall comply with
 paragraph (a) at all other times.

 f 61.242-7  Standards: Vatvee.
  (a) Each valve shall be monitored
monthly to detect leaks by the method
specified in 1 61 -245(b) and shall comply
with paragraphs (bHe). except as
provided in paragraphs ffl. IgJ. and (h) of
this section. || 6L243-1 or 61.243-2. and
                                                  .
                                         [b] If an instrument reading of 10.000
                                       ppm or greater is measured, a leak is

                                         (c)(l) Any valve for which a leak is
                                       not detected for 2 successive months
                                       may be monitored the first month of
                                       every quarter, beginning with the next
                                       quarter, until a leak is detected.
                                         (2) If e leak is delected the valve shall
                                       be monitored monthly until a leak is not
                                       detected for 2 successive smiths.
                                       .  (dMl)VYba a le*d^ detected Hahall
                                       be repaired as soon as practicable, but
                                       no later than IS calendar days after the
                                       teek is detected except as provided in
                                       161.242-10,
                                         (2) A first attempt tt repair shall be
                                       made no later than S calender days after
                                       each leak is detected
                                         M Pint attempts at repair indude. but
                                       are not limited ta the following best
                                       practices where practicable:
                                         (1) Tightening of bonnet bolts:
                                         (2) Replacement of bonnet bolts:
                                         (3) Tightening of packing gland nuts:
                                      and
                                         (4) Injection of lubricant into
                                      lubricated packing.
                                        (f) Any valve thai is designated aa
                                      described in 1 61 -246(eH2). for no
                                      detectable emissions, as indicated by an
                                      instrument reading of less than 500 ppm
  above background is exempt from the
  requirements of paragraph (a) if the
  valve:
    (1) Has no external actuating
  mechanism in contact with the process
  fluid:
    12} Is operated with emissions less
  than 500 ppm above background, as
  measured by the method specified in
  I 81.24S(c): and
    (3) Is tested for compliance with
  paragraph (f)(2) initially upon
  designation, annually, and at other times
  requested by the Administrator.
   (g) Any valve that is designated as
 described in I 61.246(0(1).» M unsafe-
 to-monitor valve is exempt from the
 requirements of paragraph (a) if:
   (1) The owner or operator of the valve
 demonstrates that the valve is unsafe to
 monitor because monitoring personnel
 would be exposed to an immediate
 danger as a consequence of complying
 with paragraph (a): and
  |2) The owner or operator of the valve
 has a written plan that requires
 monitoring of the valve as  frequent as
 practicable during safe-to-monitor tunes.
  (h) Any valve that is designated as
 described in 161.246(0(2).  as a difficult-
 to-monitor valve is exempt from the
 requirements of paragraph (a) if:
  (1) The owner or operator of the valve
 demonstrates that the valve cannot be
 monitored without elevating the
 monitoring personnel more than 2
 meters above a  support surface:
  (2) The process unit within which the
 valve is located is an existing process
 unit: and
  (3) The owner or operator of the valve
 follow* a written plan that requires
monitoring of the valve at least once per
calendar year.
                                         <•) Pressure relief devices) in liquid
                                                 i ahall be monism ud within 5
                                       d»yt by the method specified in
                                       l«-*S{b) If evidence of a potential
                                       Uak to found by visual audible.
                                       method, except as provided in
                                       101242-1(4.  i'>
                                        (b) If an instrument reading of laooo
                                       ppm or greater is measured a leak is
                                       delected
                                        fcNll When a leak is detected it shall
                                       be repaired as soon as practicable, but
                                       not later than 15 calendar days after it is
                                       detected except as provided in 161.242-
                                       10.
                                        12) The first attempt at repair shall be
                                       made oo later than 5 calendar days after
                                                       114

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each leak i» detected.
  (d) Pint attempts at repair include.
but arc not limited to. the best practices
described under 1 61 J42-7(e).

|6U42-f
                    Product
  Each product accumulator vessel shall
be equipped with a closed-vent system
capable of capturing and transporting
any leakage from the vessel to a control
device as described in 1 6U42-11.
except as provided in | 61 -242-l(c). "J
      the
  (b) Vapor recovery systems (for
example, condensers and adsorbers)
shall be designed and operated to
recover the organic vapors vented to
them with an efficiency of 85 percent or
greater.
  (c) Enclosed combustion devices shall
be designed and operated to reduce the
VHAP emissions vented to themVith an
efficiency of 95 percent or greater or to
provide a minimum residence time of
Q~50 seconds at a minimum temperature
of WC
  (d)(1) Flares shall be designed for an
operated with no visible emissions as
determined by the methods specified in
I 61.245(e). except for periods not to
exceed a total of 5 minutes during any 2
consecutive hours.''3
  (2) Flares shall be operated with a
flame present at all times, as determined
by the methods specified in I 61.245.(e).
  (3) Flares shall be used only wJth the
net heating value of the gas being
combusted being 11.2 MJ/son (300 Btu/
scf) or greater if the flare is steam-
assisted or air-assisted: or with the net
heating value of the gas being
combusted being 7.45 MJ/scm or greater
if the flare is nonassisted The net
heating value of the gas being
combusted shall be determined by the
method specified is 16l.24S(e).
  (4) Steam-assisted and nonassisted
flares shall be designed for and
operated with an exit velocity, as
determined by the method specified in
161.24S|e)(4). less than 18 m/sec (60 ft/
aec).
  (5) Air-assisted flares ahall be
designed and operated with an exit
velocity leas than the velocity, 'max as
determined by the method specified in
I 6l.245
-------
w 9 t«a>^^r^e*  • ••• • • -»— - — —	—  —
vatveelHVMA»aenr>ee sfclppsrtoa»a*
detection and IAJWI. _
  (•}(!) An owner or operator may elect
for all valves within a process unit to
comply with one of the alternative work
gractices specified in paragraphs (b)(2)

-------
   used to determine compliance of flares
   with the visible emission provisions of
   this subpart.
     (2) The presence of s flare pilot flame
   shall be monitored using a thermocouple
   or any other equivalent device to detect
   the presence of a flame.
     (3) The net heating value of the gas
   being combusted in a flare shall be
   calculated using  the following equation
            Hr-K (   I  QH,)
                  *  l-i     /
  Where.
  Hr-Net heating value of the sample. MJ/
      son: where the net enthalpy per mole of
      offgaa ia baaed on combustion at 2VC
      and 780 mm Hg. but the standard
      temperature for determining the volume
      corresponding to one mole ia 20*C
  1C-Constant 1.74XlO-'^l/ppm) (g mole/
   son! (MJ/kcal) where standard "3
   temperature for (g mole/son) it 20'C
  ^-Concentration of sample component i in
   ppm. as measured by Reference Method 18
   of Appendix A of 40 FR Part 80 and ASTM
   D3SO4-67 (reapproved 1877) (incorporated
   by referenrr aa specified in 161.18).
  H-Net heat of combustion of aample
   component Lkcal/g mole. The haata of "
   combustion may be determined using
   ASTM D2382-78 (incorporated  by referem.*
   aa specified In 181.18) if published values
   are not available or cannot be calculated

   (4) The actual exit velocity of a flare
  shall be determined by dividing the
  volumetric flowrate (in units of standard
  temperature and pressure), as
  determined by Reference Method 2.2A.
  2C or' 20. as appropriate, by the
  unobstructed (free) cross section area of
  the fUre tip.
   (5) The maximum permitted velocity.
 VH. for air-assisted flares shall be
 determined by the following equation:
 VMu -&7B+a7084(Hr)
 Where:
 VMax-Maximum permitted velocity, m/aei
 a.70B-Conatajtt.
 OJOMa Constant
 Hr-The net heating value aa determiaed in
  Paragraph (e|(3) of this section.
 [See. 114 of the Clean Air Act a* amended (42
 U.S.C. T414M

  a


  (•1(1) Each owner or operator subject
to the provisions of this subpart shall
comply with the reeordkeeping
requirements of this section.
  (2) An owner or operator of more than
one process unit subject to the
provisions of this subpart may comply
with the reeordkeeping requirements for
   these process units in one reeordkeeping
   system if the system identifies each
   record by each process unit.
    (b) When each leak is detected as
   specified in H 61.242-2. 61.242-3.
   61.242-7. and 61-242-8. the following
   requirements apply:
    (1) A weatherproof and readily visible
   identification, marked with the
  equipment identification number, shall
  be attached to the leaking equipment
    (2) The Identification on a valve may
  be removed after it has been monitored
  for 2 successive months as specified in
  } 61.242-7{c) and no leak has been
  detected during those 2 months.
    (3) The identification on equipment.
  except on a valve, may be removed after
  it has been repaired.
    (c) When each leak, ia detected «»
  specified in U 61.242-2,61.242-3.
  61.242-7. and 6U42-4 the following
  information shall be recorded in a log
  and shall be kept for 2 yean in a readily
  accessible location:
    (1) The instrument and operator
  identification numbers and the
  equipment identification number.
    (2) The date the leak was detected
  and the dates of each attempt to repair
  the leak
    (3) Repair methods applied in each
  attempt to repair the leak
   (4) "Above 1OOOO" if the maximum
 instrument reading measured by the
 methods specified in 161.24S(a) after
 each repair attempt is equal to or greater
 than 1OOOO ppm.
   (5) "Repair delayed" and the reason
 for the delay if • leak ia not repaired
 within IS calendar daya after discovery
 of the leak
   (6) The signature of the owner or
 operator (or designate) whose decision
 it was that repair could not be effected
 without • process shutdown.
   (7) The expected date of successful
 repair of the leak tf • leak ia not
 repaired within 15 calendar days.
   (8) Dates of process unit shutdowns
 that occur while the equipment is
 unrepaired.
   (9) The date of successful repair of the
 leak
   (d) The following information
 pertaining to  the design requirements for
 closed-vent systems and control devices
 described in 101.242-11 shell  be
 recorded end kept to a readily
 aeceasJbJokwtiaa:
   (1) Deteiled schematics, design
 specifications, and piping and
 instrumentation diagrams.
  (2) The detea end deeaipthim of eay
changes in the design snerlflialsuiiB
  (3) A description of the parameter or
   parameters monitored, as required in
   161.242-ll(e). to ensure that control
   devices are operated and maintained
   conformsnce with their design and an
   explanation of why that parameter (o.
   parameters) was selected for the
   monitoring.
    (4) Periods when the closed-vent
   systems snd control devices required ...
   II 81.242-2. 61.242-3. 61.242-4. 61.242-5
   and 61.242-0 are not operated as
   designed, including periods when a fli
   pilot light does not have a flame.
    (5) Dates of startups and shutdowns of
  the closed-vent systems and control
  devices required in || 61.242-2.61.242
  3.61.242-4.61-242-5 and 81.242-9.
    (e) The following information
  pertaining to all equipment subject to
  the requirements in | 61.242-1 to
  i 61.242-11 shall be recorded in a log
  that ia kept in a readily accessible
  location:
    (1) A list of identification numbers fc
  equipment  (except welded
  Bttmejsl   subject to the requirements
  ofthissnbpert112
    (2Ni) A list of identification numbers
  for equipment that the owner or
  operator elects to designate for no
  detectable emissions, as indicated by i
  instrument reading of less than 500 ppi
  above background under the provisior..
  of || 831 J42-2(e). 61.242-3(4). «nd 61.242-
  7(0.
    (ii) The designation of this equipmen
  as subject to the requirements of
  I 61.242-2W. 61.242-3(i). or 61.242-7(0
  shall be signed by the owner or
  operator.
    (3) A list of equipment identification
  numbers for pressure relief devices
  required to comply with 161 J42-4(a).
    (4|(i) The dates of each compliance
  test required in || 61.242-2(e). 61.242-
  3(i). 61.212-4. and 61.242-7(0.
    (ill The background level measured
  during each compliance test.
    (iii) The maximum instrument readin
    isured at the equipment dunng each
   (5) A bet of identification numbers fo
 equipment in vecuum service.
   (f) The following information
 pertaining to ell valves subject to the
 requirements of 161 J42-7(gJ and (h)
 shall be recorded in a log that ia kept ir
^ readily accessible location;
   (1) A Hat of identification numbers fo-
 velvet that are designated es unsafe to
 monitor, en explanation for each valve
 stating why the valve ia unsafe to
 monitor, end me plea for monitoring
 eecbvelve.
   W A hat of ideatfficetion numbers foi
          it era designated es difficult to
                  ibon for each valve
                                                           117

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•toting why tht valve is difficult to
monitor, and the planned schedule for
monitoring each valve.
  (g) The following information thai) be
recorded for valvea complying with
161.243-2:
  (1) A schedule of monitoring.
  (2) The percent of valves found
leaking during each monitoring period.
  (h) The fallowing information shall be
recorded in a log that is kept in a readily
accessible location:
  (1) Design criterion required in
§ «-242-2(d)(5) and i 61.242-3(e)|2) and
an explanation of the design criterion:
and
  (2) Any changes to this criterion and
the reasons for the changes.
  (i) The following information shall be
recorded in a log that is kept in a readily
accessible location for use in
determining exemptions as provided in
the applicability section of this subpart
and other specific subparts:
  (1) An analysis demonstrating the
design capacity of the process unit and
  (2] An analysis demonstrating that
equipment is not in VHAP service.
  (i) Information and data used to
demonstrate that a piece of equipment is
not in VHAP service shall be recorded
in a log that is kept in a readily
accessible location.
(Sec 114 of the Clean Air Act at amended
(42 U5.G. 74141.)
(Approved by the Office of Management and
Budget under control number 2080-0066)

161.247  Reporting requirements.
  (s)(l) An owner or operator of any
piece of equipment to which this subpart
applies shall submit a statement in
writing notifying the Administrator that
the requirements of It 61.242.61.245.
61.246. and 61.247 are being
•implemented.
  (2) In the ease of an existing source or
a new source which has an initial
startup date preceding the effective
date, the statement is to be submitted
within 90 daya of the effective date.
unless a waiver of compliance is granted
under 161.11. along with the
information required under 161.10. If a
waiver of compliance ia granted, the
statement is to be submitted on a date
scheduled by the Administrator.
  (3) In the case of new sources which
did not have an initial startup date
preceding the effective date, the
statement shall be submitted with the
application for approval of construction.
aa described in | 61.07.
  (4) The statement ia to contain the
following information for each source
  (I) Equipment identification number
and process unit identification.
  (II) Type of equipment (for example, a
 pump or pipeline valve).
  (til) Percent by weight VHAP in the
 fluid at the equipment.
  (iv) Process fluid state at the
 equipment (gas/vapor or liquid]
  (v) Method of compliance with the
 standard (for example, "monthly leak
 detection and repair" or "equipped *:ih
 dual mechanical seals'*).
  (b) A report shall be submitted to the
 Administrator semiannual!? starting 6
 months after the initial report required
 in 161.24?(a). that includes the
 following information:
  (1) Process unit identification.
  (2) For each month during the
 semiannual reporting period.
  (i) Number of valves for which leaks
 were detected as described in i 61.242-
 7(b) of 161.243-2.
  (ii) Number of valves for which leaks
 were not repaired as required in
 I 61242-7[d).
  (iii) Number of pumps for which leaks
 were detected as described in § 61.242-
 2(b) and (d)(6)
  (iv) Number of pumps for which Uaks
 were not repaired as required in
 161.242-2(c) and (d)|6).
  (v) Number of compressors for which
 leaks were detected as described in
 161.242-3(0.
  (vi) Number of compressors for which
 leaks were not repaired as required in
 161.242-3(g).
  (vii) The facts that explain any de!d>
of repairs and. where appropriate. «hy
a process unit shutdown was technically
infeasible.
  (3) Dates of process unit shutdowns
which occurred within the semiannual
reporting penod.
  (4) Revisions  to items reported
according to paragraph (a) if changes
have occurred since the initial report or
subsequent revisions to the initial
report.
            of | CUBIC) to i
           -112
  (5) The mulls of all performance tests
to determine compliance with i 61.242-
2Je). 161.242-3(1). 161 -242-»{a).
161.242-710.161.242-11(0,161.243-1
•nd 161.243-2 conducted within th»
semiannual reporting period.
  (c) In the first report submitted as
required in 161-247(a). the report shall
include a reporting schedule stating the
months that semiannual reports shall be
submitted. Subsequent reports shall be
submitted according to that schedule.
            ed schedule has been
  (d) An owner or operator electing to
comply with the provisions of IS 61.243-
1 and 61.243-2 shall notify the
Administrator of the alternative
standard selected 90 days before
implementing either of the provisions,
  (e) An application for approxal of
construction or modification.  { 61.051 a J
and  | 61.07. will nol be required if—
  |1) The new source complies *ith the
standard.  | 61.242.
  (2) The new source is not pan of the
construction of a process-unit: and
  |3) In the next semiannual report
required by I 61.247(b). the information
in i 61.247(a)CI) is reported.
(Sac. 114 of KM Clean Air Ad ai imeno>d |4.-
U.S.C 7414).) (Approved by the Office of
Manaermem and Budget under contmi
number ICR-11S3.)
submitted in a previous semiannual
report.
       38 FR 8826.  4/6/73 (1)

         as anended

            49  FR 23498. 6/6/84  (97)
                                                            113

-------
              APPENDIX B



ORGANIC VAPOR ANALYZER RESPONSE FACTORS
                  119

-------
       TABLE B-l.  RESPONSE FACTORS FOR AID MODEL 580 AND MODEL 585
               PHOTOIONIZATION TYPE ORGANIC VAPOR ANALYZERS3
                              (10.0-eV Lamp)
Compound
Acetone
Acetophenone
Acrolein
Ammonia
An i 1 i ne
Benzene
1,3 Butadiene
Carbon disulfide
Chlorobenzene
Cyclohexane
1,2-Dichloroethane
Di ethyl ami ne
Dimethyl sulfide
Ethyl benzene
Ethyl ene oxide
Ethyl ether
Hexane
Hydrogen sulfide
Isopropanol
Methyl ethyl ketone
Methyl isocyanate
Methyl mercaptan
Methyl methacrylate
Nitric oxide
Ortho chloro toluene
Ortho xylene
Pyridine
Styrene
Sec butyl bromide
Tetrachl oroethene
Tetrachl oroethyl ene
Tetrahydrofuran
Toluene
Trichl oroethyl ene
lonization
potential ,
eV
9.58
N.D.
N.D.
10.15
7.70
9.25
9.07
10.0
9.07
9.98
N.D.
N.D.
8.69
8.75
10.57
9.53
10.18
10.45
10.16
9.53
10.57
9.4
N.D.
9.25
8.83
8.56
9.32
N.D.
9.98
9.32
N.D.
9.54
8.82
N.D.
Response
factor
1.7
4.2
25.0
24.5
0.6
0.7
1.0
2.3
0.5
2.1
50.0
2.0
1.3
1.7
33.8
1.5
11.3
7.3
19.8
1.6
12.5
1.3
4.2
44.9
0.5
0.8
0.6
3.3
1.7
1.6
1.9
3.7
0.5
1.3
Source:  Reference 9.
                                    120

-------
  TABLE B-2.   RESPONSE FACTORS FOR  THE MIRAN  MODEL  1A/80  INFRARED  ANALYZER3
Compound
Acetal
Acetyl-1-propanol, 3-
Benzoyl chloride
Carbon tetrachloride
Chloro-acetaldehyde


Chloroform
Dichloro-1-propanol ,2,3-
Diisopropyl Benzene ,1,3-

01 ketene
Wave-
length,
yin
9.5
3.3
9.5
6.35
5.7
6.35
9.5
13.5
13.5
3.3
6.35
5.7
3.3
Actual
concentration,
ppmv
1,000
5,000
10,000
500
1,000
100
500
1,000
100
500
1,000
500
1,000
10,000
500
1,000
10,000
500
1,000
10,000
500
. 1,000
10,000
1,000
5,000
10,000
1,200
500
1,225
100
500
1,225
5,000
10,000
Instrument
concentration,
ppmv
6,690
23,400
27,200
247
813
39
217
406
4,870
5,080
5,420
115
232
390
4,840
5,680
6,760
76
228
1,880
709
2,300
21,800
6,680
22,200
34,200
64.9
134
507
311
343
380
354
1,240
Response
factor
0.149
0.214
0.368
2.02
1.23
2.55
2.30
2.46
0.02
0.10
0.19
4.35
4.31
25.6
0.103
0.176
1.48
6.58
4.39
5.32
0.705
0.435
0.459
0.150
0.225
0.292
18.5
3*75
2.42
0.331
1.47
3.22
14.1
8.06
(continued)
                                     121

-------
TABLE B-2 (continued)
Compound


Dimethyl sul fide


Ethanol
-
Ethyl ene glycol dimethyl
ether
•

Ethylene glycol
monoethyl ether
acetate
Wave-
length,
uffl
5.7 '
9.5
5.7
6.35
9.5
3.3
3.4
3.3
3.4
3.6
3.6
5.7
Actual
concentration,
ppmv
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
2,000
200
1,000
?.nnn
Instrument
concentration,
ppmv
2,280
6,390
8,600
69.4
377
580
822
1,010
1,180
2,480
4,590
6,540
15.3
120
270
3,830
18,500
34,300
430
3,420
7,530
5,110
21,100
33,800
2,310
11,700
20,600
284
1,870
3,920
50.8
158
2,590
5,110
fi.gfiO
Response
factor
0.439
0.782
1.16
14.4
13.4
17.2
1.22
4.95
8.47
0.403
1.09
1.53
65.4
41.7
37.0
0.261
0.270
0.292
2.33
1.46
1.33
0.196
0.237
0.296
0.433
0.427
0.485
3.52
2.67
2.55
19.7
12.7
0.0772
0.196
0.287
(continued)
                                     122

-------
TABLE B-2 (continued)
Compound


Formaldehyde

Formic acid


Freon 12

Furfural
Glycidol




Hydroxyacetone
Wave-
length,
um
8.8
9.5 .
3.3
3.4
5.7
8.8
9.5
6.35
8.8
13.5
3.3
3.6
5.7
6.35
9.5
5.7
Actual
concentration,
ppmv
1,000
2,000
200
1,000
2,000
500
1,000
1,000
500
5,000
10,000
5,000
10,000
500
5,000
10,000
1212.5
2,425
4,850
1212.5
2,425
4,850
100
500
1,200
100
100
100
100
1,000
100
Instrument
concentration,
ppmv
261
808
472
2,190
3,470
266
916
72.4
4,990
23,600
31,300
1,000
2,920
1,190
9,120
14,100
5,940
6,470
7,490
1,714
3,130
4,680
656
5,470
12,200
262
572
3,100
6,540
132
1,950
Response
factor
3.83
2.48
0.424
0.457
0.576
1.88
1.09
13.8
0.100
0.212
0.319
5.00
3.42
0.420
0.548
0.709
0.204
0.375
0.648
0.707
0.775
1.04
0.152
0.0914
0.0984
0.382
0.175
0.323
0.0153
0.758
0.0513
(continued)
                                     123

-------
TABLE B-2 (continued)
Compound


Methyl styrene, -




Methyl ene chloride
Pentanethiol,!-
Perchloromethyl-
mercaptan




Propylene chlorohydn'n
Wave-
length,
uffl
6.35
9.5
3.3
5.7
6.35
9.5
13.5
3.3
13.5
3.3
3.6
5.7
8.8
9.5
13.5
Actual
concentration,
ppmv
100
100
1,030
5,000
103
1,030
5,000
1,010
5,000
1,030
5,000
1 1,030
5,000
5,000
10,000
5,000
10,000
5,000
5,000
500
1,000
5,000
5,000
500
1,000
5,000
500
1,000
5,000
Instrument
concentration,
ppmv
6,870
24.6
976
2,830
330
1,230
1,570
4,490
6,960
73.6
178
167
948
1,740
3,740
5,300
10,500
612
64.0
1,730
3,410
7,660
426
36.7
132
303
3,800
8,510
38,600
Response
factor
0.0146
4.07
1.06
1.77
0.312
0.837
3.18
0.229
0.718
14.0
28.1
6.17
5.27
2.87
2.67
0.943
0.952
8.17
78.1
0.289
0.293
0.653
11.7
13.6
7.58
16.5
0.132
0.118
0.130
(continued)
                                     124

-------
TABLE B-2 (continued)
Compound
Tetrachloroethane,
1,1,2,1-


Trichloroethane.1,1,1-

Trichlorotrifluoro-
ethane, 1,1,2-

-
Wave-
length,
um
3.3
8.8
13.8
3.3
3.4
8.8
9.5
13.5
Actual
concentration,
ppmv
5,000
10,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
5,000
10,000
Instrument
concentration,
ppmv
582
1,010 '
404
20,000
73,000
101,000
266
2,910
5,920
38.8
421
5,840
16,100
18,500
977
3,690
6,280
1,100
2,270
Response
factor
8.59
9.90
24.fi
0.0500
0.0685
0.0990
3.76
1.72
1.69
129.0
23.8
0.171
0.311
0.541
1.02
1.36
1.59
4.55
4.41
 Abstracted  from Reference 8.
                                    125

-------
    TABLE  B-3.   RESPONSE  FACTORS  FOR  THE  HNU  SYSTEMS,  INC.,  MODEL  PI-101
                          PHOTOIONIZATION ANALYZER3
Compound
Acetal
Carbon disulfide
Carbon tetrachloride
Chloroform
Diketene
Perchloromethyl mecaptan
Toluene
Tetrachloroethane.1,1,2,2-
Trichloroethane,!,!,
Trichlorotrifluoroethane 1,1,2-
Actual
concentration
1,000
5,000
10,000
1,000
10,000
500
1,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
5,000
1,000
1,000
5,000
10,000
1,000
5,000
10,000
5,000
10,000
Instrument
concentration
925
7,200
13,200
1,990
12,900
784
1,070
6,070
756
2,550
5,250
148
318
460
103
1,180
736
1,170
1,880
1,020
6,170
9,430
155
430
Response
factor
1.1
0.69
0.76
0.50
0.78
0.64
0.94
1.6
1.3
2.0
1.9
6.8
16.0
22.0
48.0
0.85
1.4
4.3
5.3
0.98
0.81
1.1
32.0
23.0
Abstracted from Reference 8.
                                    126

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TABLE B-4.  RESPONSE FACTORS FOR FOXBORO OVA-108 AND BACHARACH TLV SNIFFER AT
                            10,000 ppmv RESPONSE3
Compound
Acetic acid
Acetic ahydride
Acetone
Acetonitrile
Acetyl chloride
Acetylene
Acrylic acid
Acrylonitrile
Allene
Allyl alcohol
Amylene
Anisole
Benzene
Bromobenzene
Butadiene, 1,3-
Butane, N
Butanol , sec-
Butanol , tert
Butene, 1-
Butyl acetate
Butyl acrylate, N-
Butyl ether, N
Butyl ether, sec
Butyl ami ne, N
Butyl ami ne, sec
Butyl ami ne, tert- "
Butyraldehyde, N-
Butyronitrile
Carbon disulfide
Chi oroacetal dehyde
Chlorobenzene
Chloroethane
Chloroform
Chloropropene, 1-
Chloropropene, 3-
Chloro toluene, M-
Chlorotoluene, 0-
Chlorotoluene, P-
Cro tonal dehyde
Cumene
Cyclohexane
Cychohexanone
Cyclohexene
Cyclohexylamine
Diacetyl
Response factor
OVA-108b
1.64
1.39
0.80
0.95
2.04
0.39
4.59
0.97
0.64
0.96
0.44
0.92
0.29
0.40
0.57
1.44 I
0.76
0.53
0.56
0.66
0.70
2.60
0.35
0.69
0.70
0.63
1.29
0.52
B
9.10
0.38
5.38 I
9.28
0.67
0.80
0.48
0.48
0.56
1.25
1.87
0.47
1.50
0.49
0.57
1.54
Response factor
TLV sniffer5
15.60
5.88
1.22
1.18
2.72
B
B
3.49 I
15.00
X
1.03
3.91
1.07
1.19
10.90
4.11
1.25
2.17
5.84
1.38
2.57 I
3.58 I
1.15
2.02
1.56
1.95
2.30
1.47 I
3.92
5.07
0.88
3.90 P
B
0.87
1.24
0.91
1.06
1.17 I
B
B
0.70
7.04
2.17
1.38
3.28
(continued)
                                     127

-------
TABLE B-4  (continued)
Compound
Dichloro-l-propene,2,3-
Dichloroethane, 1,1-
Dichloroethane,l,2-
Dichloroethylene.cis.l ,2-
Dichloroethylene, trans, 1 ,1-
Dichloromethane
Dichloropropane, 1 ,2-
Diisobutylene
Dimethoxy ethane, 1, 2-
Dimethylformamide,N,N-
Dimethy 1 hydrazi ne , 1 , 1-
Dioxane
Epichlorohydrin
Ethane
Ethanol
Ethoxy ethanol , 2-
Ethyl acetate
Ethyl aery late
Ethyl chloroacetate
Ethyl ether
Ethyl benzene
Ethyl ene
Ethyl ene oxide
Ethylenediamine
Formic acid
Glycidol
Heptane
Hexane.N-
Hexene,!-
Hydroxyacetone
Isobutane
Isobutylene
Isoprene
Isopropanol
Isopropyl acetate
Isopropyl chloride
Isovaleraldehyde
Mesityl oxide
Methacrolein
Methanol
Methoxy-ethanol ,2-
Methyl acetate
Methyl acetylene
Methyl chloride
Methyl ethyl ketone
Methyl formate
Response factor
OVA-108&
0.75
0.78
0.95
1.27
1.11
2.81
1.03
0.35
1.22
4.19
1.03
1.48
1.69
0.65
1.78
1.55
0.86
0.77
1.99
0.97
0.73
0.71
2.46
1.73
14.20
6.88
0.41 I
0.41
0.49
6.90
0.41
3.13
0.59
0.91
0.71
0.68
0.64
1.09
1.20
4.39 P
2.25
1.74
0.61
1.44
0.64
3.11
Response factor
TLV sniffer6
1.75
1.86
2.15
1.63
1.66
3.85
1.54
1.41
1.52
5.29
2.70
1.31
2.03
0.69 I
X
1.82
1.43
X
1.59
1.14
4.74 D
1.56
2.40
3.26
B
5.55
0.73
0.69
4.69 D
15.20
0.55
B
X
1.39
1.31
0.98
2.19 D
3.14
3.49 0
2.01
3.13
1.85
6.79
1.84
1.12
1.94
(continued)
                                     12G

-------
TABLE B-4 (continued)
Compound
Methyl methacrylate
Methyl -2-pentanol ,4-
Methyl-2-pentone,4-
Methyl-3-butyn-2-ol,2
Methyl cyclohexane
Methylcyclohexene
Methyl styrene,a-
Nitroethane
Nitromethane
Nitropropane
Nonane-n
Octane
Pentane
Picoline,2-
Propane
Propionaldehyde
Proponic acid
Propyl alcohol
Propyl benzene, n-
Propylene
Propyl ene oxide
Pyridine
Styrene
Tetrachloroethane,l,l,l,2
Tetrachloroethane,l,l,2,2
Tetrachloroethylene
Toluene
Trichloroethane, 1 ,1,1-
Trichloroethane.1,1,2-
Trichloroethylene
Trichloropropane.1,2,3-
Tri ethyl ami ne
Vinyl chloride
Vinyl idene chloride
Xylene, p-
Xylene, m-
Xylene, 0-
Response factor
OVA-108b
0.99
1.66
0.56
0.59
0.48
0.44
13.90
1.40
3.52
1.05
1.54
1.03
0.52
0.43
0.55 I
1.14
1.30
0.93
0.51
0.77
0.83
0.47
4.22
4.83 D
7.89
2.97
0.39
0.80
1.25
0.95
0.96
0.51
0.84
1.12
2.12
0.40
0.43
Response factor
TLV snifferb
2.42
2.00
1.63
X
0.84
2.79
B
3.45
7.60
2.02
11.10
2.11
0.83
1.18
0.60 P
1.71
5.08 0
1.74
B
1.74 I
1.15
1.16
B
6.91
25.40
B
i 2.68 D
2.40
3.69
3.93
1.99
1.48
1.06
2.41
7.87
5.87 D
1.40
 Abstracted  from Reference 6.

5I  =  Inverse estimation  method
 D  =  Possible outliers in  data
 N  =  Narrow  range of data
 X  =  No  data available
 B  =  10,000  ppmv response  unachievable
 P  -  Suspect points  eliminated.
                                    129

-------
                    APPENDIX C



IONIZATION POTENTIALS OF SELECTED ORGANIC COMPOUNDS
                        130

-------
    IONIZATION POTENTIAL DATA USEFUL FOR SELECTION OF PHOTOIONIZATION TYPE
                            ORGANIC VAPOR ANALYZERS3
Chemical
lonization
potential
Chemical
lonization
potential
Acetaldehyde             10.21
Acetamide                 9.77
Acetic acid              10.37
Acetone                   9.69
Acetonitrile             12.22
Acetophenone              9.27
Acetyl bromide           10.55
Acetyl chloride          11.02
Acetylene                11.41
Acrolein                 10.10
Acrylonitrile            10.91
Allyl alcohol             9.67
Ammonia                  10.15
Aniline                   7.70
Anisole               .    8.22
Benzaldehyde              9.53
Benzene                   9.25
Benzenethiol              8.33
Benzonitrile              9.71
Benzocrifluoride          9.68
Biphenyl                  8.27
Bromine                  10.55
1-bromobutane            10.13
2-bromobutane             9.98
l-bromo-2-chloroethane   10.63
Bromochloromethane       10.77
l-bromo-4-fluorobenzene   8199
l-bromo-2-methylpropane  10.09
l-bromo-2-methylpropane   9.89
1-bromopentane           10.10
1-bromppropane           10.18
2-bromopropene           10.08
1-bromopropene            9.30
3-bromopropene            9.70
2-bromothiophene          8.63
m-bromotoluene            8.81
o-bromotoluene            8.79
p-bromotolyene            8.67
Butane                   10.63
1,3-butadiene             9.07
2,3-butadione             9.23
1-butanethiol             9.14
1-butene       .           9.58
cis-2-butene  '            9.13
Trans-2-butene            9.13
                     3-butene nitrile         10.39
                     n-butyl acetate          10.01
                     sec-butyl acetate         9.91
                     n-butyl alcohol          10.04
                     n-butyl amine             8.71
                     s-butyl amine             8.70
                     t-butyl amine             8.64
                     n-butly benzene           8.69
                     s-butyl benzene           8.68
                     t-butyl bnnzene           8.68
                     n-butyl formate          10.50
                     1-butyne                 10.18
                     n-butyraldehyde           9.86
                     n-butyric acid           10.16
                     n-butyronitrile          11.67
                     Carbon dioxide           13.79
                     Carbon monoxide          14.01
                     Chlorine                 11.48
                     Chlorobenzene             9.07
                     1-chlorobutane           10.67
                     2-chlorobutane           10.65
                     l-chloro-2-fluorobenzene  9.16
                     l-cholor-3-fluorobenzene  9.21
                     l-chloro-2-methylpropane 10.66
                     2-chloro-2-methylpropane 10.61
                     1-chloropropane          10.82
                     2-chloropropane          10.78
                     3-chloropropene          10.04
                     2-chlorothiophene         8.68
                     m-chlorotoluene           8.83
                     o-chlorotoluene           8.83
                     p-chlorotoluene           8.70
                     Crotonaldehyde            9.73
                     Cyanogen                 13.80
                     Cyclohexane               9.98
                     Cyclohexanone             9.14
                     Cyclohexene               8.95
                     Cyclo-octatetraene        7.99
                     Cyclopentane             10.53
                     Cyclopentanone            9.01
                     Cyclopropane             10.06
                     Dedaborane               11.00
                     Dibromochlororaethane     10.59
                     Dibromodifluoromethane   11.07
                     1,1 dibromoethane        10.19
                                      131

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1,2 dibromoethene         9.45
Dibromomethane           10.49
1,3 dibromopropane       10.07
m-dichlorobenzene         9.12
o-dichlorobenzene         9.07
p-dichlorobenzene         8.94
1,2 dichloroethane       11.12
cis-dichloroethene        9.65
trans-dichloroethene      9.66
Diborane                 12.10
Dichloromethane          11.35
1,2 dichloropropane      10.87
1,3 dichloropropane      10.85
2,3 dichloropropene       9.82
Dibutyl amine             7.69
Diethoxymethane           9.70
N,N-diethyl acetamide     8.60
Diethyl amine             8.01
Diethyl ether             9.43
N.N-diethyl formamide     8.89
Diethyl ketone            9.32
Diethyl sulfide           8.43
Diethyl sulfite           9.68
Dihydropyran              8.34
1,1 dimethoxyethane       9.65
Dimethoxymethane         10.00
Diiodomethane             9.34
Diisopropylamine          7.73
N,N-diraethyl acetamide    8.81
Dinethy1 amine            8.2
2,2-dimethyl butane      10.06
2,3-dimethyl butane      10.02
3,3-d-Mnethyl butanone     9.17
Dimethyl ether           10.00
N.N-dimethyl formamide    9.12
2,2-dimethyl propane     10.35
Dimethyl sulfide          8.69
Dipropyl amine            7.84
Dipropyl sulfide          8.30
Durene                    8.03
Ethane                   11.65
Ethanethiol               9.29
Ethene                   10.52
Ethyl acetate            10.11
Ethyl alcohol            10.48
Ethyl amine               8.86
Ethyl benzene             8.76
Ethyl bromide            10.29
Ethyl chloride           10.98
Ethyl disulfide           8.27
Ethylene oxide           10.57
Ethyl formate            10.61
Ethyl iodide .-            9.33
Ethyl isothiocyanate      9.14
Ethyl methyl sulfide      8.55
Ethyl nitrate
Ethyl propionate
Ethyl thiocyanate
Ethynylbenzene
Fluorine
Fluorobenzene
o-fluorophenol
m-fluorotoluene
o-fluorotolune
p-fluorotoluene
Formaldehyde
Formic acid
Freon 11 (CFC13)
Freon 12 (CF2C12)
Freon 13 (CF3C1)
Freon 22 (CHC1F2)
Freon 113 (CF3CC13)
2-furaldehyde
Furan
Hexane
Heptane
2-Heptanone
1-hexene
Hydrogen
Hydrogen bromide
Hydrogen chloride
Hydrogen cyanide
Hydrogen fluorine
Hydrogen iodide
Hydrogen sulfide
Hydrogen telluride
Iodine
lodobenzene
1-iodobutane
2-iodobutane
l-iodo-2-methylpropane
l-iodo-2-oethylpropane
1-iodopentane
1-iodopropane
2-iodopropane
o-iodotoluene
m-iodotoluene
p-iodotoluene
Isobutane
Isobutyl amine
Isobutyl acetate
Isobutyl formate
Isobutyraldehyde
Isobutyric acid
Isopentane
Isoprene
Isopropyl acetate
Isopropyl benzene
Isopropyl ether
Isovaleraldehyde
15.
 9,
11.22
10.00
 9.89
 8.82
   .70
   .20
 8.66
 8.92
 8.92
 8.79
10.87
11.05
11.77
12.91
12.91
12.45
11.78
 9.21
 8.89
10.18
10.08
 9.33
 9.46
15.43
11.62
12.74
13.91
15.77
10.38
10.46
 9.14
 9.25
 8.73
 9.21
 9.09
 9.18
 9.02
 9.19
 9.26
 9.17
 8.62
 8.61
 8.50
10.57
 8.70
 9.97
10.46
 9.76
10.02
10.32
 8.85
 9.99
10.16
 9.20
 9.71
                                      132

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2,3-lutidine              8.85
2,4-lutidine              8.85
2,6-lutidine              8.85
Mesitylene                8.40
Mesityl oxide             9.08
Methane                  12.98
Methanelthiol             9.44
N-methyl acetamide        8.90
Methyl acetate           10.27
Methyl alcohol           10.85
Methyl amine              8.97
Methyl bromide           10.53
2-methyl-l-butane         9.12
3-methyl-l-butene         9.51
3-methyl-2-butene         8.67
Methyl butyl ketone       9.34
Methyl butyrate          10.07
Methyl chloride          11.28
Methylcyclohexane         9.85
4-methylcyclohexene       8.91
Methyl disulfude          8.46
Methyl ethyl ketone       9.53
Methyl formate           10.82
2-methyl furan            8.39
Methyl iodide             9.54
Methyl isobutyl ketone    9.30
Methyl isobutyrate        9.98
Methyl isopropyl ketone   9.32
Methyl isothiocyanate     9.25
1-methyl naphthalene      7.96
2-methyl naphthalene      7.96
2-methylpentane          10.12
3-methylpentane          10.08
2-methyl propene          9.23
Methyl propionate        10.15
Methyl propyl ketone      9.39
Methyl thiocyanate       10.07
a-methyl styrene          8.35
Naphthalene               8.12
Nitric oxide              9.25
Nitrobenzene              9.92
Nitrogen                 15.50
Nitrogen dioxide          9.78
Nitroethane              10.81
Nitromethane             11.00
1-nitropropane           10.88
2-nitropropane           10.71
Oxygen                   12.08
Ozone                    12.08
Pentaborane              10.40
Pentane                  10.35
2,4 pentanedione.          8.87
1-pentene       '          9.50
Phenetole                 8.11
Phenol                    8.50

aSource:  Reference 5.
    Phenyl  isocyanate
    Phenyl  isothiocyanate
    Phosgene
    2-picoline
    3-picoline
    4-picoline
    Propane
    1-propanethiol
    Propiolactone
    Propionic acid
    Propionitrile
    Propionaldehyde
    Propyl  acetate
    Propyl  alcohol
    Propyl  amine
    Propyl  bnezene
    Propylene
    Propylene oxide
    Propyl  ether
    Propyl  formate
    Propylene
    Pyridine
    Pyrrole
    Styrene
    Thiolacetic acid
    Thiophene
    Tetrachloroethene
    Tetrachloromethane
    Tetrahydrofuran
    Tetrahydropyran
    Tolune
    Tribromethene
    Tribromofluoromethane
    Tribromomethane
    Trichloroethene
    Trichloromethane
    Triethylamine
    Trimethyl amine
    2,2,4-trimethyl pentane
    Tripropyl amine
    Valeraldehyde
    Valeric acid
    Vinyl acetate
    Vinyl bromide
    Vinyl chloride
    Vinyl methyl ether
    Water
    m-xylene
    o-xylene
    p-xylene
 8.77
 8.52
11.77
   02
   02
   04
 9
 9
 9
11.07
  .20
  ,70
 9.
 9,
10.24
11.84
 9.98
10.04
10.20
 8.72
 8.72
 9.73
10.22
 9.27
10.54
10.36
 9.32
 8.20
 8.47
10.00
 8.86
 9.32
11.47
 9.54
 9.26
 8.82
 9.27
10.67
10.51
 9.45
11.42
 7
 7.
   50
   52
 9.86
 7.23
 9.82
10.12
 9.19
 9.80
10.00
 8.93
12.59
 8.56
 8.56
 8.45
133

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                                  GLOSSARY
Accuracy:  The difference between the measured value and the true values
     which has been established by an accepted reference method procedure.
     In most cases, a value is quoted by the manufacturer, and no description
     is given to indicate how this value was obtained.

Action Level:  A measured concentration value obtained  with a portable VOC
     monitor.  It indicates the need for repair.

Calibration:  The method for determining the instrument response to calibra-
     tion gases (dynamic calibration) cr artificial  stimuli (static calibra-
     tion).

Directed Maintenance:  Refers to a maintenance procedure in which the hydro-
     carbon detector is used during maintenance.  The leak is monitored with
     the instrument until the repair reduces the measured concentration below
     the action level.

Fugitive Emissions of VOC:  Generally refers to the diffuse release cf
     vaporized hydrocarbon or other organic compounds.   Fugitive emissions
     originate from equipment leaks and from large and/or diffuse sources.

Ground:  1.  The electrical neutral line having the same potential as the
     surrounding earth.  2.  The negative side of dc power supply.
     3.  Reference point for an electrical system.

Interferences:  Any substance or species causing a deviation of instrument
     output from the value that would result from the presence of only the
     pollutant of concern.

Leak:  A measured VOC concentration cf the action level or greater, deter-
     mined at a specified distance from the fugitive emission source (usually
     0 cm).  The concentration value that defines a leak can vary, depending
     on the regulation and the industry.  A value of 10,000 parts per million
     by volume (ppmv) is by far the most often used and was used in this
     manual unless otherwise noted.

No Detectable Emission:  A local VOC concentration at the surface of a source
     that indicates that a VOC emission (leak) is not present.  Because back-
     ground VOC concentrations may exist and to account for instrument drift
     and imperfect reproducibility, a difference between the source surface
     concentration and the local ambient concentration is determined.  A
     difference based on a meter reading of less than 5 percent of the leak
     definition concentration indicates that a VOC emission is not present.
                                      134

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Precision:  The degree of variation between repeated measurements of the same
     concentration.

Principle of Operation:  The technique used to detect and measure the pollu-
     tant or parameter.

Process Stream:  Process fluids such as reactants, intermediate products,
     final products, and by-products, that are contained within pipes, pumps,
     valves, etc., in a process unit.  Steam, water, air, and other utility
     lines are not considered to be process streams.

Process Unit:  Equipment assembled to produce ar organic chemical as an
     intermediate or final product.  A process unit can operate independently
     if supplied with sufficient feed or raw materials and sufficient storage
     facilities for the final product.

Range:  The lower and upper detectable limits.  (The lower limit is usually
     reported as 0.0 ppm.  This is somewhat misleading and should be reported
     as the true lower detectable limit.)

Repair:  Adjustment or alteration of leaking equipment that reduces the
     screening value from greater than or equal to the action level (i.e.,
     2.10,000 ppmv) to below the action level (i.e., < 1C,000 ppir.v).

Response Factor:  A correction factor that quantifies the difference in meter
     response that a portable VOC analyzer has for various hydrocarbons and
     substituted organic chemicals.

Response Time:  The time interval from a step change in the input concentra-
     tion at the instrument inlet to a reading of 90 percent (unless other-
     wise specified) of the ultimate recorded output.  This measurement is
     the same as-the sum of lag time and rise time.               ,.  •

'Screening:  The act of measuring the hydrocarbon concentration of a source
     with a portable hydrocarbon detector.

Screening Value:  The hydrocarbon concentration (in ppmv) detected at a
     source with a portable hydrocarbon detector while traversing with the
     instrument probe around all the potential leak points of the source.

Source Type:  Process unit equipment components that may emit fugitive emis-
     sions.  Common source types of fugitive emissions are valves, pump
     seals, flanges, compressor seals, and sampling lines.

Thermocouple:   The junction of two dissimilar metals which has a voltage
     output proportional to the difference in temperature between the hot
     junction and the lead wires (cold junction).
                                      135

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Type of Service:   The physical  state (ces,  liquid,  or-  both)  of  the
     material(s)  contained in a specific  pipeline or vessel.  The terms
     liquid and gas ere defined at  operating  condition cf  the process.
     Liquid process streams  can be  further  subdivided  into:

     0    Light VOC liquid—any process stream with e  vapor  pressure  of  equal
          to or greater than 0.3 kPa at 20°C  (lighter  than kerosene).

     '    Heavy VOC liquid—any process stream with a  vapor  pressure  less
          than 0.3 kPa  at 20°C.

Volatile Organic  Compouna iVOC):  Any organic compound that  participates  in
     atmospheric  photochemical  reactions.

Warmup Time:  The elapsed time  necessary  after startup for the  instrument  to
     meet stated  performance specifications when the instrument  has been  shut
     down for at  least  24 hours.
                                     136

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