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.
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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.
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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
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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
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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
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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
2-17
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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.
2-18
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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,
2-20
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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
2-22
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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
3-1
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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
3-2
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GATE VALVE1
FIGURE 3-1
3-3
-------
Handwheel
Stem
Packing Nut
Packing
Bonnet
Seat
Body
GLOBE VALVE WITH PACKED SEAL4
FIGURE 3-2
3-4
-------
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.
3-5
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Handwheel
Plunger
Flexible
diaphragm
Saddle
shaped
seat
DIAPHRAGM VALVE
FIGURE 3-3
3-6
-------
Potential
leak area
-
BALL VALVE
FIGURE 3-4
3
3-7
-------
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.
3-8
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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
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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
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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
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Discharge
t
Coolant circulating tube
Stator liner
Suction
Impleller
Bearings
SEAL-LESS CANNED MOTOR PUMP
FIGURE 3-12
3-18
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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
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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
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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
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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
-------
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
-------
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.
4-6
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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.
4-7
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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
-------
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
4-9
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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.
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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
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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:
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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.
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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
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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.
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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.
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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)
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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:
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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
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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.:
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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:
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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
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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:
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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:
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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.
7-3
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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
-------
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
-------
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.
-------
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
-------
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)
-------
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
-------
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
-------
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)
-------
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)
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
64
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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. '
65
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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
66
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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
67
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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
68
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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
69
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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.
70
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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
71
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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.
74
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27. Personal communication from R. Sevalo, HNU Systems, Inc., to J. Richards,
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38. Personal •communication from J. Washle, Analytical Instrument Development,
Inc., to J. Richards, Richards Engineering, December 4, 1985.
39. Personal communication from R. Sevalo, HNU Systems, Inc., to J. Richards,
Richards Engineering, December 5, 1985.
40. Personal communication from N. Barker, Photovac, Inc., to J. Richards,
Richards Engineering, December 4, 1985.
41. U.S. Environmental Protection Agency. Standards of Performance for New
Stationary Source; Synthetic Organic Chemical Manufacturing Industry;
Equipment Leaks of VOC, Reference Methods 18, and 22; Final Rule.
Federal Register. Volume 48, Number 202, page 48334. October 18, 1983.
42. U.S. Environmental Protection Agency. Control of Volatile Organic Com-
pound Leaks From Gasoline Tank Trucks and Vapor Collection Systems.
EPA-450/2-78-051, December 1978.
43. United Technologies, Bacharach. Instruction Manual, TLV Sniffer,
Instruction 23-9613, Revision 1. September 1982.
77
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44. PEDCo Environmental, Inc. VOC Sampling and Analysis Workshop, Volume II.
Papers and Lecture Notes. EPA-340/l-84-001b, September 1983.
45. Personal communication from J. Washall, Analytical Instrument Develop-
ment, Inc., to J. Richards, Richards Engineering, December 5, 1985.
46. Richards, J., and R. Segal!. Air Pollution Source Inspection Safety
Procedures, Student Manual. EPA-340/185-002a, September 1985.
47. Gordon, R. J., et al. Inspection Manual for Control of Volatile Organic
Emissions From Gasoline Marketing Operations. EPA-340/1-80-012,
January 1980.
48. Hanzevack, K. M. Fugitive Hydrocarbon Emissions - Measurement and Data
Analysis Methods. In: Proceedings of Symposium/Workshop on Petroleum
Refinering Emissions. EPA-600/2-78-199, September 1978.
49. Harvey, C. M., and A. C. Nelson, Jr. VOC Fugitive Emission Data - High
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
-------
REFERENCE METHOD 21
81
-------
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
-------
•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
-------
NSPS REGULATIONS
84
-------
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
-------
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
-------
> 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
-------
-"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
-------
.}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
-------
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
-------
NESHAPS REGULATIONS
104
-------
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
-------
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
-------
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
-------
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
-------
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
-------
•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
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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
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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
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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
-------
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
-------
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
-------
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
-------
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).
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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.
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