EPA 340/l-90-026c
SEPA
September 1990
Inspector Training Series
COURSE MODULE S380
INSPECTION TECHNIQUES
FOR FUGITIVE VOC
EMISSION SOURCES
Prepared for:
U.S. Environmental Protection Agency
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
Washington, D.C. 20460
SLIDE MANUAL
Pacific Environmental Services, Inc.
3708 Mayfair Street
Suite 202
Durham, North Carolina 27707
Prepared by:


-------
& EPA
EPA 340/l-90-026c
September 1990
Inspector Training Series
COURSE MODULE S380
INSPECTION TECHNIQUES
FOR FUGITIVE VOC
EMISSION SOURCES
SLIDE MANUAL
Prepared by:
Pacific Environmental Services, Inc.
3708 Mayfair Street
Suite 202
Durham, North Carolina 27707
Prepared for:
U.S. Environmental Protection Agency
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
Washington, D.C. 20460

-------
DISCLAIMER
This is not an official policy and standards document. The opinions,
findings, and conclusions are those of the authors and not necessarily those of the
Environmental Protection Agency. Every attempt has been made to represent the
present state of the art as well as subject areas still under evaluation. Any
mention of products or organizations does not constitute endorsement by the U.S.
Environmental Protection Agency.
i

-------
LECTURE 1
WELCOME AND INTRODUCTION

-------
INTRODUCTION
This manual is intended for use during the workshop. The manual contains "copies" of
the slides that are presented during the workshop. The only slides not included are those of
photographs. In their place are brief descriptions of the photographs. There are no slides for
Lecture 1; thus, this manual starts with Lecture 2 slides.
Ample space is provided on each page for the student to take notes directly in this
manual during the workshop. This will allow the student to use this manual rather than the
Student's Manual for note-taking.
1-1

-------
LECTURE 2
INTRODUCTION TO
FUGITIVE EMISSION
REGULATIONS

-------
INTRODUCTION TO EQUIPMENT
LEAK STANDARDS FOR VOC AND
VHAP
SLIDE 2-1
WHAT ARE EQUIPMENT LEAK
STANDARDS?
Federal and State Regulations Designed
to Cause Sources to Reduce Emissions
from Leaking Process Equipment
SLIDE 2-2

-------
FEDERAL REGULATIONS
1.	New Source Performance Standards
(NSPS)
-	Apply to new VOC sources
2.	National Emission Standards for
Hazardous Air Pollutants (NESHAP)
-	Apply to new and existing
hazardous air pollutant sources
STATE REGULATIONS
1. State Implementation Plans
-	Apply to existing VOC sources
SLIDE 2-3
WHY ARE EQUIPMENT LEAK
STANDARDS NEEDED?
•	VOC, NO„ and sunlight produce
ozone
•	Ozone nonattainment is a serious
problem
•	Easier to control VOCs than NO, or
sunlight
•	VHAPs are hazardous to human
health
SLIDE 2-4

-------
ARE EQUIPMENT LEAKS REALLY
SIGNIFICANT?
Nationwide
Uncontrolled
Emissions
ftons/veart
Source Category
Refineries
SOCMIs
Benzene
53,900
91,500
8,700
SLIDE 2-5
ARE EQUIPMENT LEAKS REALLY SIGNIFICANT?
Source Category
Refineries
SOCMIs
Benzene
Nationwide Emissions (tons/year)
Uncontrolled After Control
53,900
91,500
8,700
19,800
40,700
2,750
SLIDE 2-6
2-3

-------
WHAT SOURCE CATEGORIES ARE
REGULATED?
NSPS:
STATE:
NESHAP:
SOCMI
Petroleum refineries
Onshore natural gas
processing plants
SOCMI
Petroleum refineries
Natural gas processing
plants
Polymer manufacturing
plants
Benzene
Vinyl Chloride
SLIDE 2-7
WHAT EQUIPMENT IS REGULATED?
•	Pumps
•	Compressors
•	Pressure relief devices
•	Sampling connections
•	Open ended valves or lines
•	Process Valves
•	Flanges and other connectors
•	Product accumulator vessels
•	Agitators
•	Closed Vent Systems
SLIDE 2-8

-------
TYPES OF STANDARDS
•	Performance Standards
-	no detectable emissions
•	Equipment Standards
-	equipment specifications
-	design specifications
-	operational specifications
•	Work Practice Standards
-	leak detection and repair
-	evidence of potential leaks
SLIDE 2-9
SIMILARITIES IN STANDARDS
•	Covered equipment
•	Leak definition
•	Sampling method for leak detection
•	Repair/retest procedures
•	Recordkeeping and reporting
requirements
SLIDE 2-10

-------
DIFFERENCES IN STANDARDS
•	Exemptions
•	Definition of light/heavy liquid
•	Component Labeling
•	Monitoring Frequency
SLIDE 2-11

MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance

standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
SLIDE 2-12
2-6

-------
MAJOR LECTURE TOPICS
1. Definitions
Z Finding the regulations
3.	Applicable source categories
4.	Component Identification
5.	Leak detection and repair standards
6.	Equipment and performance
standards
7.	Equivalent means of emission
limitations
8.	Test methods and procedures
9.	Recordkeeping requirements
10.	Reporting requirements
SLIDE 2-13

-------
DEFINITIONS
•	Affected facility
•	Process unit
•	Equipment
•	In VOC service
•	In gas/vapor service
•	In liquid service (light and heavy)
•	Volatile hazardous air pollutant
(VHAP)
•	In VHAP service
•	Connector
•	Product accumulator vessel
SLIDE 2-14
MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance

standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
SLIDE 2-15
2-8

-------
NSPS REGULATIONS
40CFR60
Subpart W
Subpart GGG
Subpart KKK
SOCMI
Petroleum
refineries
October 18, 1983
May 30, 1984
Onshore natural June 24, 198S
gas processing
plants
SLIDE 2-16
NESHAP REGULATIONS
40 CFR 61
Subpart J
Subpart F
Subpart V
Benzene
Vinyl
chloride
June 6,1984
September 23,1988
National emission June 6, 1984
standard for
equipment leaks
(fugitive emission
sources)
SLIDE 2-17

-------

MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance

standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
SLIDE 2-18
APPLICABILITY REQUIREMENTS -
SOCMI
•	"Retroactive" to January 5, 1981
•	Industry that produces one or more
chemicals listed in section 60.489
•	Process stream contains 10% or more
VOC
•	Applies to process units
•	Exemptions:
-	Design capacity <1,000 mg/yr (1,100
tons/yr)
• Only heavy liquid chemicals
produced from heavy liquid feed or
raw materials
-	Beverge alcohol production
-	No equipment in VOC service
-	Equipment in vacuum service
SLIDE 2-19

-------
APPLICABILITY REQUIREMENTS -
PETROLEUM REFINERIES
•	"Retroactive" to January 4, 1983
•	Facilities subject to Subpart W or
KKK are excluded
•	Applies to process units and
compressors
•	Alternative definition for light liquid
(>10% evaporates at 150°C)
•	Exemptions:
-	Equipment in vacuum service
-	Compressors in hydrogen service
(>50% H)?
-	Process units on Alaskan north
slope
SLIDE 2-20

-------
APPLICABILITY REQUIREMENTS -
ONSHORE NATURAL GAS
PROCESSING PLANTS
•	"Retroactive" to January 20, 1984
•	Facilities subject to subpart W or
GGG are excluded
•	Applies to process units and
compressors
•	Alternative definitions for light liquid
(>10 percent evaporates at 150°C)
and for heavy liquid (<10 percent
evaporates at 150°C)
•	Exemptions:
-	Sampling connection systems
-	Nonfractionating plants with design
capacity less than 10 million scfd
-	Process units on Alaskan north
slope
-	Reciprocating compressors in wet
gas service
SLIDE 2-21

-------
APPLICABILITY REQUIREMENTS -
BENZENE FACILITIES
•	10% or more benzene in process fluid
•	Applies to individual pieces of
equipment
•	Exemptions:
-	Plant site designed to produce or
use <1,000 Mg/yr (1,100 tons/yr) of
benzene
-	process units having no equipment
in benzene service
-	Coke by-product plants
-	Equipment in vacuum service
SLIDE 2-22
APPLICABILITY REQUIREMENTS
VINYL CHLORIDE FACILITIES
•	Applies to plants which produce:
-	Ethylene dichloride
-	Vinyl chloride
-	Polymers containing polymerized
vinyl chloride
•	Exemptions
-	R&D reactors <0.19m3 (50 gal)
SLIDE 2-23A
2-13

-------
APPLICABILITY REQUIREMENTS
VINYL CHLORIDE FACILITIES
• Exemptions (Cont.)
-	R&D reactors between 0.19 to
4.07m3 (50 to 1,075 gal) have less
stringent requirements
-	Equipment in vacuum service
exempted
-	If process unit has <2% leaking
valves, then:
- Recordkeeping is different
-- Reporting is different
~ Equipment marking not
required
SLIDE 2-23B

MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance

standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
SLIDE 2-24
2-14

-------
COMPONENT IDENTIFICATION
•	ID number
•	Affected facility
•	Component type
•	Component location
•	Fluid state
•	Plus NESHAPS:
Mark each component
% VHAP
SLIDE 2-25
MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance

standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
SLIDE 2-26

-------
LEAK DETECTION
AND REPAIR
Phase 1 - Detection of Leaks
Phase 2 - Repair of Leaks
SLIDE 2-27
LDAR PROGRAM
•	Monitoring Interval
-	monthly/quarterly
•	Leak Definition
-	10,000 ppm
•	Repair Interval
-	within 5 days first attempt
-	completed within 15 days
-	delay allowed under certain
circumstances
SLIDE 2-28

-------
FIRST ATTEMPT AT REPAIR
Valves
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
SLIDE 2-29
DELAY OF REPAIRS
Infeasible without process unit
shutdown
- repair at next shutdown
Isolated from process and does not
remain in VOC or VHAP service
Valves and pumps specific conditions
SLIDE 2-30

-------
OB
DELAY OF REPAIRS - VALVES
•	Additional Condition
purged material emissions from
immediate repair are greater than
emissions from delay
and
at repair, purged material is
destroyed or recovered in control
device
•	Delay Beyond Next Shutdown
valve assembly replacement needed
and
supplies depleted (but adequate
prior to depletion)
only if next shutdown occurs
within 6 months after first
SLIDE 2-31
DELAY OF REPAIRS -
PUMPS
• Additional Condition
dual mechanical seal system with
barrier fluid system; and
repaired within 6 months
SLIDE 2-32

-------
LDAR:
EQUIPMENT COVERED
•	Valves
-	in gas/vapor, in light liquid VOC, in
VHAP service
-	difficult-to-monitor
-	unsafe-to-monitor
•	Pumps
-	in light liquid service
•	Other Equipment
-	flanges and otheT connectors
-	PRDs in liquid service
-	pumps and valves in heavy liquid
service
SLIDE 2-33
LEAK DETECTION:
VALVES
Type of
Value
In gas/
vapor or
light li-
quid ser-
vice or in
VHAP
service
Difficult-
to-monitor
Unsafe-to-
monitor
Leak
Detected
> JO,000
>	10,000
>	10,000
Monitoring
Frequency
monthly/
quarterly
annually
(minimum)
when safe
to monitor
SLIDE 2-34
2-19

-------
Potential
Leak Ateas
Packing
SLIDE 2-35
Handwheel
Slem
Packing Nul
Packing
-Bonnet
GLOBE VALVE WtTH PACKED SEAL
SLIDE 2-36
2-20

-------
SLIDE 2-37
LEAK DETECTION:
VALVES
Alternate Standards
-	not more than 2 percent leaking valves
-	skip period LDAR
SLIDE 2-38
2-21

-------
ALTERNATIVE STANDARDS FOR
VALVE LEAK DETECTION
PROGRAMS
Alternative 1: Not more than 2%
leaking valves
•	Notify administrator 90 days before
implementing alternative
•	M-Zl test initially, annually, and when
requested by administrator
•	All valves monitored within one week
•	Leakers must be repaired within 15
days, with first attempt at repair
within 5 days
•	>2% leaking valves is a violation
SLIDE 2-39
ALTERNATIVE STANDARDS FOR
VALVE LEAK DETECTION
PROGRAMS
Alternative 2: Skip period leak
detection and repair
•	Option 1: After consecutive
quarters with <=2%
leaks; skip to semiannual
monitoring
•	Option 2: After 5 consecutive
quarters with <«= 2%
leaks; skip to annual
monitoring
- If >2% leaking valves, revert back to
monthly monitoring, but this is not a
violation
SLIDE 2-40

-------
LEAK DETECTION:
VALVES
Type of Leak
Value Detected
In gas/	> 10,000
vapor or
light liquid
service or
in VHAP
service
Difficult- to- > 10,000
monitor
Unsafe-to-
monitor
> 10,000
Monitoring
Frequency
monthly/
quarterly
annually
(minimum)
when safe
to monitor
SLIDE 2-41
LEAK DETECTION:
VALVES
Type of
Value
In gas/
vapor or
light li-
quid ser-
vice or in
VHAP
service
Difficult-
to-monitor
Leak
Detected
> 10,000
> 10,000
Unsqfe-to- > 10,000
monitor
Monitoring
Frequency
monthly/
quarterly
annually
(minimum)
when safe to
monitor
SLIDE 2-42
2-23

-------
LEAK DETECTION:
PUMPS
Leak
Detected
> 10,000 ppm
by Method 21
visual indication
Monitoring
Frequency
Monthly
Weekly*
* Unmanned plant sites to be visually
inspected as often as practicable and at
least monthly.
SLIDE 2-43
Pump Stulltng Box
L^»P«cklng
Fluid End
Packing
Qland
SMlfac*
PoMlbteLMfc
Am
SIMPLE PACKED SEAL
SLIDE 2-44
2-24

-------
Gland Gaakat
Gland Ring
Pump Slutting Box
,ln««fl Packing
.Stationary Elemant
	Poiftlbte Leak Arm
BASIC SINGLE MECHANICAL SEAL
SLIDE 2-45
LEAK DETECTION:
FLANGES AND OTHER
CONNECTORS, PRDS IN LIQUID
SERVICE, PUMPS AND VALVES IN
HEAVY LIQUID SERVICE
•	Evidence of a potential leak
-	visual
-	audible
-	olfactory
-	other
•	Monitor (Method 21) within 5 days
-	> 10,000 ppm
SLIDE 2-46
2-25

-------

MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
SLIDE 2-47
EQUIPMENT AND PERFORMANCE
STANDARDS
•	Pumps
•	Compressors
•	Valves
•	PRDs
•	Sampling Connections
•	Open-End Valves or Lines
•	Flanges and other connectors
•	Closed vent system and control
devices
•	Product accumulator vessels
•	Agitators
SLIDE 2-48

-------
STANDARDS FOR PUMPS
IN LIGHT LIQUID SERVICE (NSPS)
OR IN VHAP SERVICE (NESHAP)
•	LDAR
•	Dual mechanical seal system that
includes a barrier fluid system
•	"no detectable emissions"
•	closed vent system to control device
SLIDE 2-49
PUMPS:
Dual Mechanical Seal Systems
with Barrier Fluid System
1. Dual Mechanical Seal System
•	Barrier fluid pressure pump >
stuffing box pressure; or
•	Barrier fluid degassing reservoir
is connected by a closed vent
system to a control device; or
•	Barrier fluid is purged into a
process stream with zero VOC
(or VHAP) emissions to the
atmosphere
SLIDE 2-50
2-27

-------
PUMPS:
Dual Mechanical Seal Systems
with Barrier Fluid System
(continued)
2.	Barrier fluid system is in heavy liquid
service (NSPS only) or is not in VOC
(or VHAP) service
3.	Weekly visual inspection for
indications of liquids dripping from
pump seals
SLIDE 2-51
PUMPS:
Dual Mechanical Seal Systems
with Barrier Fluid System
(concluded)
4.	Sensor to detect failure of seal system
and/or barrier fluid system
•	checked daily or audible alarm
•	owner-determined criterion of
failure indicator
•	not applicable at unmanned plant
sites
5.	Repair of detected leaks
SLIDE 2-52

-------
SMllng-Ltquld
Oulltl
Poutbla Laak Into
SMHns Fluid
DOUBLE MECHANICAL SEAL
SLIDE 2-53
PUMPS:
No Detectable Emissions
•	Instrument reading of < 500 ppm
» No externally actuated shaft
penetrating pump housing
•	Test for compliance:
initially
- annually
as requested by Administrator
SLIDE 2-54

-------
Discharge i	Coolant Circulating Tuba
Slalor Linei
Impeller
Bearings
SEAL-LESS CANNED MOTOR PUMP
SLIDE 2-55
Diaphragm
Piston
DIAPHRAGM PUMP
SLIDE 2-56
-30

-------
MAGNET DRIVE PUMP
IMPELLER
CONTAINMENT SHELL
TORQUE RING (INNER MAGNET RING)
OUTER MAGNET RING (OMR)
MOTOR
COUPLING
MOTOR
isgi—rggi
SLIDE 2-57
PUMPS:
Closed Vent Systems to Control Device
•	Equipped with a closed vent system
capable of capturing and transporting
any leakage to a control device
•	Closed vent system and control device
must meet requirements of §60.482-10
(or 561.242-11).
SLIDE 2-58
2-31

-------
STANDARDS FOR COMPRESSORS
(NSPS and NESHAP)
•	Seal system that includes a barrier
fluid system
•	closed vent system to control device
•	"no detectable emissions"
SLIDE 2-59
COMPRESSORS:
Seal System with Barrier Fluid System
1. Compressor Seal System
•	Barrier fluid pressure >
compressor stuffing pressure; or
•	Barrier fluid system connected by
a closed vent system to a control
device; or
•	Barrier fluid purged into a
process stream with zero VOC
(or VHAP) emissions to the
atmosphere
SLIDE 2-60

-------
COMPRESSORS:
Barrier Fluid System
(concluded)
2.	Barrier fluid system is in heavy liquid
service (NSPS only) or is not in VOC
(or VHAP) service
3.	Sensor to detect failure of seal system
and/or barrier fluid system
•	checked daily or audible alarm
•	owner-determined criterion of
failure indicator
•	not applicable at unmanned plant
sites
4.	Repair of detected leaks
SLIDE 2-61
COMPRESSORS:
Closed Vent Systems to Control
Device
•	Equipped with a closed vent system
capable of capturing and transporting
any leakage to a control device
•	Closed vent system and control device
must meet requirements of §60.482-10
(or §61.242-11)
SLIDE 2-62

-------
Oil in From Reservoir
Internal
Gas
Pressure
Inner
Bushing
Atmosphere
Outer
Bushing
Contaminated Oil Out
Oil Out
To Reservoir
LIQUID-FILM COMPRESSOR SHAFT SEAL
SLIDE 2-63
COMPRESSORS:
"No Detectable Emissions"
•	Instrument reading of < 500 ppm
•	Test for compliance:
initially
annually
as requested by Administrator
SLIDE 2-64
2-34

-------
STANDARDS FOR PRESSURE RELIEF
DEVICES (PRDs) IN GAS/VAPOR
SERVICE
•	"no detectable emissions"
•	closed vent system to control device
SLIDE 2-65
Seal
Spring
Disk
Nozzle
Process Side
DIAGRAM OF A SPRING-LOADED RELIEF VALVE
SLIDE 2-66
2-35

-------
.Ten»lon-Ad|u§tment
ThlmDt#
Spring
To
Atmospheric
Vent
Nozzle
Rupture Disk
From System
RUPTURE DISK INSTALLATION
UPSTREAM OF A RELIEF VALVE
SLIDE 2-67
PRDs:
"No Detectable Emissions"
•	Instrument reading of < 500 ppm,
except during pressure releases
•	Return to "no detectable emissions"
within 5 days after each pressure
release
SLIDE 2-68

-------
PRDs:
Closed Vent System To
Control Device
*	Equipped with a closed vent system
capable of capturing and transporting
any leakage to a control device.
•	Closed vent system and control device
must meet requirements of §60.482-10
(or §61.242-11).
SLIDE 2-69
STANDARDS FOR
SAMPLING CONNECTIONS
•	Closed purge system or closed vent
system
return purge directly to process
line with zero emissions; or
collect and recycle with zero
emissions; or
capture and transport all purged
fluid to compliant control device
•	in-situ sampling connections are
exempt
SLIDE 2-70

-------
q ProcoMLln*	ProcM# Ltn%
rA-
Li
i
Sftmpto ConlatMr
Stmptfl ConlalrMf
DIAGRAM OF TWO CLOSED-LOOP SAMPLING SYSTEMS
SLIDE 2-71
STANDARDS FOR OPEN-ENDED
VALVES OR LINES
•	Caps, blind flange, plug, or second
valve
•	Seal open end at all times except
during operations requiring flow
through valve or line
SLIDE 2-72
2-38

-------
STANDARDS FOR OPEN-ENDED
VALVES OR LINES:
(concluded)
• Second valve
valve on process fluid end is to be
closed before second valve is
closed
• Double block-and-bleed system
bleed valve or line may remain
open during operations requiring
venting the line between the block
valves
closed at all other times
SLIDE 2-73
STANDARDS FOR VALVES
IN GAS/VAPOR OR LIGHT LIQUID
SERVICE
•	LDAR
alternative standards
"unsafe-to-monitor"
"difficult-to-monitor"
•	"no detectable emissions"
SLIDE 2-74

-------
STANDARDS FOR VALVES:
No Detectable Emissions
•	Instrument reading < 500 ppm
•	No external actuating mechanism in
contact with process fluid
•	Test for compliance
initially
annually
as requested by Administrator
SLIDE 2-75
Diaphragm
2-40

-------
Diaphragm
BONNET DIAPHRAGM SEAL
Bellows
SEALED BELLOWS VALVE
SLIDE 2-78
2-41

-------
STANDARDS FOR PRODUCT
ACCUMULATOR VESSELS
(NESHAP only)
• Closed vent system capable of
capturing and transporting any leakage
from the vessel to a compliant control
device
SLIDE 2-79
STANDARDS FOR AGITATORS
• Double mechanical seals
maintain pressure between seals so
that any leak is into the agitated
vessel; or
duct any vinyl chloride between
seals to control device (< 10 ppm
of vinyl chloride in exhaust); or
equivalent
SLIDE 2-80

-------
STANDARDS FOR CLOSED VENT
SYSTEMS AND CONTROL
DEVICES
Closed Vent Systems
•	no detectable emissions
< 500 ppm
visual inspections
•	monitoring
initially
annually
as requested by Administrator
•	repair of leaks (> 500 ppm or visual)
•	operated at all times when emissions
may be vented to them
SLIDE 2-81
STANDARDS FOR CLOSED VENT
SYSTEMS AND CONTROL
DEVICES (concluded)
CONTROL DEVICES
•	Monitor parameters to ensure proper
operation and maintenance
determined by plant
owner/operator
•	Operate at all times when emissions
may be vented to them
SLIDE 2-82

-------
STANDARDS FOR CLOSED VENT
SYSTEMS AND CONTROL
DEVICES (continued)
CONTROL DEVICES Ccontinuedl
•	Vapor recovery devices: £ 95 percent
efficiency
•	Enclosed combustion devices: > 95
percent efficiency
NSPS: a 0.75 residence time
>	8I6°C temperature
NESHAP: > 0.5 residence time
>	760°C temperature
SLIDE 2-83
STANDARDS FOR CLOSED VENT
SYSTEMS AND CONTROL
DEVICES (continued)
CONTROL DEVICES (concluded'!
• Flares
no visible emissions
operated with flame present at all
times
heat content
exit velocity
steam-assisted, air-assisted,
nonassisted
Comply with Section 60.18
SLIDE 2-84

-------
Ground Ftara
& Compressor SmI Oil
DagMlngVMilt
SIMPLIFIED CLOSED-VENT SYSTEM WITH DUAL FLARE8
SLIDE 2-85
MAJOR LECTURE TOPICS
1.	Definitions
2.	Finding the regulations
3.	Applicable source categories
4.	Component Identification
5.	Leak detection and repair standards
6.	Equipment and performance
standards
7.	Equivalent means of emission
limitations
8.	Test methods and procedures
9.	Recordkeeping requirements
10.	Reporting requirements
SLIDE 2-86
2-45

-------
EQUIVALENT MEANS OF EMISSION
LIMITATION
•	Petition administrator
•	Demonstrate equivalence
-	Test data
-	Demonstrate emissions reduction
achieved
-	Emission reductions a achieved by
EPA standard
-	Federal register notice - public
hearing
-	Determination published in Federal
Register
SLIDE 2-87
MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance

standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
SLIDE 2-88

-------
TEST METHODS AND PROCEDURES
•	Monitoring
Method 21
•	In VOC service presumption
unless demonstrated otherwise by
owner or operator
ASTM methods or engineering
judgement
-- D-2267 for VHAP
-- E-260, -168, 169 for VOC
•	In light liquid service conditions
•	Representative samples
•	Flares (refer to 60.18 for general
provisions)
Reference Method 22 for VE
Presence of flare pilot flame
Heat content
Velocity
SLIDE 2-89

-------
MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance

standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
BBSBSSSSm
SLIDE 2-90
2-48

-------
RECORDKEEPING REQUIREMENTS
•	Equipment
list IDs
compliance test
unsafe-to-monitor valves
difficult-to-monitor valves
•	No detectable emissions designation
•	In vacuum service
•	Not in VOC (or VHAP) service
•	LDAR results
monitoring
repair
•	Closed Vent Systems
•	Control Devices
SLIDE 2-91
MAJOR LECTURE TOPICS
1.
Definitions
2.
Finding the regulations
3.
Applicable source categories
4.
Component Identification
5.
Leak detection and repair standards
6.
Equipment and performance

standards
7.
Equivalent means of emission

limitations
8.
Test methods and procedures
9.
Recordkeeping requirements
10.
Reporting requirements
SLIDE 2-92

-------
REPORTING REQUIREMENTS
NSPS
Notification of Construction
Initial Semi-annual report
Semi-annual reports
NESHAP
Initial Statement
Semi-annual report
Vinyl chloride - no report if < 2
percent of the valves leak
SLIDE 2-93

-------
LECTURE 3
PORTABLE VOC ANALYZER
CHARACTERISTICS

-------
PERFORMANCE SPECIFICATIONS
FOR METHOD 21
•	Must respond to organic compounds being
processed (detectors include catalytic oxidation,
flame ionization, infrared adsorption,
photoionization)
•	Intrinsically safe for operation in explosive
atmospheres
•	Must measure concentration specified in the
regulation
•	Must have nominal flow rate of 0.1-3.0
liter/min
•	Scale must be readable to ± 2.5 percent of
defined leak concentration
SLIDE 3-1
PERFORMANCE CRITRIA FOR METHOD 21
•	Response time of 30 seconds or less
•	Calibration precision must be less than or
equal to 10 percent of the calibration gas value
•	Instrument subjected to response time and
calibration precision tests prior to being placed
in service
•	Calibration precision repeated every 6 months
or if modification or replacement of the
instrument detector is required
•	Response time retested after modifications to
sample pumping system or flow configuration
SLIDE 3-2
3-1

-------
COMMON TYPES OF PORTABLE VOC
ANALYZERS
•	Flame ionization detectors
•	Photoionization detectors
•	Catalytic combustion analyzers
•	Infrared analyzers
SLIDE 3-3
FLAME IONIZATION DETECTOR
OPERATING PRINCIPLES
•	Sample gas is drawn in continuously
•	The sample gas is mixed with hydrogen
•	The organic vapor is burned in a
hydrogen flame using the oxygen
present in the sample gas
•	Positive ions are generated during
combustion and collected on an
electrode in the burner chamber
•	The current is amplified and displayed
SLIDE 3-4

-------
MMMM OF AFLAME
nMunoN ocraciai (Hit
uru
.couictiok
OKTMK
IWCT
SLIDE 3-5
VOC ANALYZED U8INO
nDOtltClim	CLCCtMCTM/
~
COLLECTION
CLECfRQOC
EXHAUST
mm
PMCL-AOUirCB
01 NMQ-MCLO
fCTCR
FUWK
HOUSIM
SWU	FILTCH
FLOW
KTCft
SLIDE 3-6

-------
FLAME IONIZATION DETECTOR
INSTRUMENT CHARACTERISTICS
•	Sensitive to sample gas flow rate
changes
•	Sample gas organic vapor "destroyed"
•	Sensitive to air infiltration prior to the
burner
SLIDE 3-7
PHOTOIONIZATION ANALYZER
OPERATING PRINCIPLES
*	Sample gas is drawn in continuously
*	Organic vapor is ionized by absorption
or ultraviolet radiation
*	Positive ions are collected
*	Current is amplified and measured
SLIDE 3-8
3-4

-------
OtAQftAMOtPHOTOIOMZATON
oencnwtm
COUXCTION
SLIDE 3-9
VOC ANALYZER USING
ftDOCTiCTOfl
CUCTWKTCIU
triiniMi
Ml tltlttct
SLIDE 3-10

-------
PHOTOIONIZATION ANALYZER
INSTRUMENT CHARACTERISTICS
•	Insensitive to sample gas flow rate
changes
•	Sample gas organic vapor not
"destroyed"
•	Sensitive to air infiltration prior to the
detector
SLIDE 3-11
CATALYTIC COMBUSTION
ANALYZER OPERATION
PRINCIPLES
•	The sample gas stream is drawn in
continuously
•	The organic vapor is oxidized as it
passes over a catalyst coated wire
•	The change in electrical resistance of
the coated wire is sensed and a current
signal is generated
SLIDE 3-12

-------
SLIDE 3-13
CATALYTIC COMBUSTION
ANALYZER INSTRUMENT
CHARACTERISTICS
•	Sensitive to sample gas flow rate
changes
•	Sample gas organic vapor "destroyed"
•	Sensitive to air infiltration prior to the
detector cell
SLIDE 3-14
3-7

-------
Response factor =
DEFINITION
Actual concentration
Instrument indicated concentration
SLIDE 3-15
RESPONSE FACTOR, EXAMPLE 1
Actual concentration	= 10,000 ppm
Instrument gauge reading = 5,000 ppm
Response factor	= 2
SLIDE 3-16
3-8

-------
RESPONSE FACTOR, EXAMPLE 2
Actual concentration	= 1,000 ppm
Instrument gauge leading = 3,000 ppm
Response factor	= 0.33
SLIDE 3-17
RESPONSE FACTOR, EXAMPLE 3
Actual concentration	= 100,000 ppm
Instrument gauge reading = 10,000 ppm
Response factor	= 10
SLIDE 3-18

-------
TYPICAL RESPONSE FACTOR
RANGE
0.1 TO 40
The lower the response factor, the more
sensitive the instrument for that compound
SLIDE 3-19
SOURCE OF RESPONSE FACTOR
•	Instrument specific tests
•	Published tables
SLIDE 3-20

-------
RESPONSE FACTORS VARY WITH
ACTUAL CONCENTRATION
SLIDE 3-21
EXAMPLE 1: RESPONSE FACTOR
VARIATION FOR OVA-108 FID:
XYLENES

Actual
Instrument

Concentration
Response
Compound
(PPM)
Factor
para-Xylene
50
3.49

500
3.70

7,700
2.27
meta-Xylene
200
1.04

1,500
0.60

3,000
0.42
ortho-Xylene
200
0.89

1,500
0.86

3,000
039
SLIDE 3-22
3-11

-------
EXAMPLE 2: RESPONSE FACTOR
VARIATION FOR OVA-108 FID:
PARAFFINIC COMPOUNDS

Actual
Instrument

Concentration
Response
Compound
(PPM)
Factor
Ethane
1,000
1.04

3,000
1.16

4,500
0.57
Propane
1,000
0.84

2,000
3.12

4,000
0.59
Pentane
200
1.33

1,500
0.94

5,000
0.48

SLIDE 3-23

EXAMPLE 2: RESPONSE FACTOR
VARIATION FOR OVA-108 FID:
PARAFFINIC COMPOUNDS (CONT.)
Actual	Instrument
Concentration Response
Compound
(PPM)
Factor
N-hexane
150
0.48

550
0.57

1,500
0.57

3,200
0.63

8,000
0.69
Heptane
200
1.00

1,500
0.67

4,000
0.32
Decane
200
10.77

300
0.83

400
1.61
SLIDE 3-24
3-12

-------
EXAMPLE 3: RESPONSE FACTOR
VARIATION FOR OVA-108 FID:
AROMATIC COMPOUNDS
Actual	Instrument
Concentration Response
Compound
(PPM)
Factor
Benzene
50
0.88

2,000
0.32

2,800
0.28

5,000
0.51
Toluene
200
0.67

1,500
0.49

3,000
0.39
Ethylbenzene
50
0.52

1,500
0.83

8,000
1.23
SLIDE 3-25
EXAMPLE 4: RESPONSE FACTOR
VARIATION FOR OVA-108 FID:
CHLOROTOLUENES
Actual	Instrument
Concentration	Response
Compound	(PPM)	Factor
Meta-chlorotoluene 200	0.61
1,500	0.53
3,100	0.50
Ortho-chlorotoluene 200	0.85
1,500	0.63
3,100	0.63
Para-chlorotoluene 200	0.75
1,500	0.55
3,200	0.51
SLIDE 3-26

-------
RESPONSE FACTORS VARY
INSTRUMENT-TO-INSTRUMENT
SLIDE 3-27
EXAMPLE 1: INSTRUMENT-TO-
INSTRUMENT VARIATIONS FOR
OVA-108 FID: CYCLOHEXANOL
Actual	Response
Compound Concentration Factor at
(ppm)	10,000 ppm
Instrument Instrument
1	2
Cyclohexanol	200 1.98	2.21
700 1.67	1.71
1,200 1.21	1.41
SLIDE 3-28
3-14

-------
EXAMPLE 2: INSTRUMENT-TO-
INSTRUMENT VARIATIONS FOR
CATALYTIC COMBUSTION
ANALYZER: XYLENES
Compound
Actual
Concentration
(ppm)
Response
Factor at
10,000 ppm
Instrument Instrument
para-Xylene
meta-Xylene

1
2
50
2.50
1.51
500
9.43
3.98
7,700
7.83
4.00
200
3.53
1.70
1,500
9.44
2.01
3,000
12.84
1.64
4,500
15.01
1.53
7,000
37.86
1.73
SLIDE 3-29
3-15

-------
EXAMPLE 3: INSTRUMENT-TO-
INSTRUMENT VARIATIONS FOR
CATALYTIC COMBUSTION
ANALYZER: ETHYLBENZENE
Response
Actual	Factor at
Compound Concentration 10,000 ppm
(ppm)
Instrument
1 2
Ethylbenzene
50	1.93
500	10.50
4,000	32.62
8,000	27.09
1.16	N.D.
2.62	N.D.
4.11	1.32
3.05	1.14
SLIDE 3-30
RESPONSE FACTORS:
Used to select appropriate
instruments for specific
application,
but
not used to calculate actual
concentration during
Method 21 leak screening
tests.
SLIDE 3-31
3-16

-------
LECTURE 4
PORTABLE VOC ANALYZER
CHECKOUT AND CALIBRATION

-------
INITIAL INSTRUMENT CHECKS
ARE NOT REQUIRED BY
METHOD 21.
SLIDE 4-1
PURPOSE OF INITIAL INSTRUMENT
CHECKS
Ensure that the instrument is
working properly before leaving the
inspection site
SLIDE 4-2

-------
INITIAL CHECKS - FLAME
IONIZATION DETECTORS
•	Check hydrogen supply - refuel if
necessaiy
•	Confirm presence of exhaust port
flame arrestor
•	Check battery status
•	Warm-up instrument electronics
•	Check amplifier settings
•	Check prefilter and probe conditions
•	Leak check probe
•	Measure sample gas flow rate at probe
inlet
SLIDE 4-3
aMSBBssBOBBBBaBBSBsssasaaBassaBsss
INITIAL CHECKS -
PHOTOIONIZATION
ANALYZER
•	Check battery status
•	Check probe condition
•	Check for obvious deposits on optical
window
•	Confirm detector response
•	Measure sample gas flow rate at probe
inlet
SLIDE 4-4

-------
INITIAL CHECKS -
CATALYTIC COMBUSTION
ANALYZER
•	Check battery status
•	Check prefilter and probe conditions
•	Leak check probe
•	Confirm detector response
•	Measure sample gas flow rate at probe
inlet
SLIDE 4-5
PURPOSE OF CALIBRATION
•	Ensure compliance with Method 21
•	Adjust instrument as necessary
•	Identify any malfunctioning
instruments
SLIDE 4-6

-------
CALIBRATION REQUIREMENTS
•	Instruments should be calibrated daily
•	Calibrant gas should be methane or
hexane
•	Calibrant gas concentration should be
close to leak definition concentration
•	A calibration precision test is required
monthly
•	Blended gas calibration mixtures
should have a known concentration
with an accuracy of plus or minus 2%
SLIDE 4-7
CALIBRATION LOCATION
•	Location is not specified by Method 21
•	Calibration at agency shop or
laboratory prior to leaving for
inspection site eliminates hazards
involved with shipping compressed
calibration gases
SLIDE 4-8

-------
INSTRUMENT RESPONSE TIME
•	Instrument must reach 90% of
calibration gas concentration within 30
seconds
•	An average of three separate tests are
used to determine conformance
•	Tests must be repeated whenever
sample flow rate changes are made
•	Records must be kept
•	Response time is usually tested in
conjunction with a daily calibration
procedure
SLIDE 4-9
CALIBRATION PRECISION
•	Calculation
Value = (observed/actual) x 100
•	Algebraically averaged values must be
within 10% of actual concentration
•	Test is done monthly
•	Records must be kept
•	Usually done in conjunction with a
daily calibration procedure
SLIDE 4-10

-------
INHALATION HAZARDS
•	Leakage of toxic calibration gases
•	Emissions of toxic combustion
products from flame ionization
detectors and catalytic combustion
analyzers
SLIDE 4-11
GAS CYLINDER RELATED
PROBLEMS
*	Unsecured compressed gas cylinders
could become dangerous projectiles if
the main valve is damaged
•	Leakage of hydrogen (for FIDs) could
create an explosion hazard in an area
served with standard electrical wiring
SLIDE 4-12
4-6

-------
REQUIRED LABORATORY
FACILITIES
Operational ventilation hoods free
from chemicals or general
contamination
Secure cylinder mounts and facilities
for receiving and shipping cylinders
SLIDE 4-13
INSTRUMENT MAINTENANCE
AND TESTING
Sample gas flow rates should be
determined daily using soap bubble
flow meters and rotameters
Photoionization detectors should be
disassembled and cleaned regularly
Catalytic combustion analyzers must be
removed from instrument cases for
adjustment of zero scales
All types of units must be partially
disassembled when excessive quantities
of vapor and/or droplets have entered
the unit
SLIDE 4-14

-------
REQUIRED LABORATORY
FACILITIES
•	Bench space for maintaining
instruments and charging batteries
•	Storage space for instrument supplies
and accessories
•	Shelf and file space for storing
instrument operating manuals and
maintenance notebooks
SLIDE 4-15

-------
LECTURE 5
LEAK MONITORING PROCEDURES,
PROBLEMS, AND ERRORS

-------
METHOD 21 MONITORING
REQUIREMENTS
-	Probe at surface of component
• Move along interface periphery while
observing readout
-	If increase occurs, sample until
maximum reading occurs
-	record results
SLIDE 5-1
SLIDE 5-2

-------
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
VALVE FOR LEAKS - NO HARD
COPY AVAILABLE
SLIDE 5-3
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
VALVE FOR LEAKS - NO HARD
COPY AVAILABLE
SLIDE 5-4

-------
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
VALVE FOR LEAKS - NO HARD
COPY AVAILABLE
SLIDE 5-5
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
VALVE FOR LEAKS - NO HARD
COPY AVAILABLE
SLIDE 5-6

-------
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
VALVE FOR LEAKS - NO HARD
COPY AVAILABLE
SLIDE 5-7
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
PUMP FOR LEAKS - NO HARD
COPY AVAILABLE
SLIDE 5-8

-------
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
PUMP FOR LEAKS - NO HARD
COPY AVAILABLE
SLIDE 5-9
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
PUMP FOR LEAKS - NO HARD
COPY AVAILABLE
SLIDE 5-10

-------
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
PRESSURE RELIEF DEVICE FOR
LEAKS - NO HARD COPY
AVAILABLE
SLIDE 5-11
THIS SLIDE IS A PHOTOGRAPH OF
AN INSPECTOR MONITORING A
PRESSURE RELIEF DEVICE FOR
LEAKS - NO HARD COPY
AVAILABLE
SLIDE 5-12

-------
PORTABLE VOC ANALYZER PROBE
EMISSION PLUME "CAPTURE"
•	Sampling is done under weak negative
pressure
•	Air is drawn into the probe from all
directions, not just the direction from
the VOC leak
•	Even one probe diameter away from
the probe inlet, there is almost no air
movement toward the probe
SLIDE 5-13
PROBE ORIENTATION
•	Due to poor capture capability, the
probe must be as close as possible to
the leak site
•	Due to poor capture capability, the
probe should be oriented directly into
the plume to take advantage of the
flow characteristics of the positive
pressure leak
SLIDE 5-14

-------
SAMPLE GAS FLOW SENSITIVITY
•	Due to inherent poor capture
capability, all instruments are sensitive
to sample gas flow rates
•	As flow rates decreases, the ability to
draw in the emission plume decreases
SLIDE 5-15
FUGITIVE VOC LEAK
CHARACTERISTICS
•	Concentrations range from
approximately 10,000 ppm to 1,000,000
PPm
•	Mass emission rates from a single leak
site can be significant
•	The leaking VOC gas stream can be
hot and contain compounds which
condense at ambient temperatures
SLIDE 5-16

-------
EFFECTS OF "EXCESSIVE" VOC
INTAKE FLAME IONIZATION
INSTRUMENTS
•	Flame-out at sample gas
concentrations above 70,000 to 100,000
PPm
•	Blinding of flame arrestor leading into
mixer/burner
•	Sustained high observed readings due
to condensation and revolatilization in
sample lines
SLIDE 5-17
EFFECTS OF "EXCESSIVE" VOC
INTAKE CATALYTIC
COMBUSTION ANALYZERS
•	Volatilization of catalyst on detector
wire
•	Sustained high observed readings due
to condensation and revolatilization in
sample lines
SLIDE 5-18

-------
EFFECTS OF "EXCESSIVE" VOC
INTAKE PHOTOIONIZATION
ANALYZERS AND INFRARED
ANALYZERS
•	Condensation of organic materials on
the optical surface
•	Sustained bigh observed readings due
to condensation and revolatilization in
sample lines
SLIDE 5-19
PROCEDURE FOR MINIMIZING RISK
OF "EXCESSIVE" VOC INTAKE
Withdraw probe immediately
when the gauge spikes to
the maximum reading
SLIDE 5-20

-------
OTHER IMPORTANT MONITORING
CONSIDERATIONS
•	Use a plastic tubing extension on the
probe to avoid metal contact with
rotating shafts
•	Use a fiberglass wool prefilter to
protect against droplet intake
SLIDE 5-21
WEATHER LIMITATIONS
•	Minimize field activities during rain to
protect against water droplet intake
¦ Avoid standing layers of water around
horizontal valves after a storm
•	Have a spare battery ready for use
during cold weather
SLIDE 5-22

-------
SAFETY LIMITS TO FIELD
MONITORING
•	Do not attempt to monitor sources
more than 6 feet above safe platforms
•	Do not monitor sources adjacent to
hot surfaces or adjacent to partially
exposed rotating equipment
•	Wear respiratory protection whenever
necessary
•	Use only intrinsically safe instruments
and instrument recorders
•	Check safety features of instruments
before beginning field activities
SLIDE 5-23

-------
LECTURE 6
NSPS AND NESHAP EQUIPMENT LEAK
RECORDS AND REPORTS

-------
NSPS REPORTING
•	Notification of construction within 30
days of commencement
•	Semi-annual report
SLIDE 6-1
NSPS INITIAL SEMI-ANNUAL
REPORT
•	Submission deadline: 6 months after
the initial startup date
•	Process unit ID
•	Number of valves
•	Number of pumps
•	Number of compressors
SLIDE 6-2

-------
NSPS SEMI-ANNUAL REPORT
•	Process unit ED
•	For each month, the number of valves,
compressors, and pumps:
had detected leaks
were not repaired (explain any
delay of repairs and why process
shutdown infeasible)
•	Dates of process shutdowns during the
period
•	Revisions to initial statement
SLIDE 6-3
OTHER NSPS REPORTING ASPECTS
•	Alternate standards for valves - 90 day
notification required
•	Report all performance test results in
accordance with Section 60.8 and
notify Administrator at least 30 days
before initial performance tests
•	EPA may delegate enforcement
authority to a State agency to receive
semi-annual reports
SLIDE 6-4
6-2

-------
NESHAP REPORTING
•	Initial statement
•	Semi-annual report
•	Vinyl chloride does not have to report
if < 2 percent leaking valves
SLIDE 6-5
INITIAL BENZENE STATEMENT
REPORT
•	Submission deadline
Existing plants - 9/4/84
New plants - submit with
application for approval of
construction
•	Statement that standards, testing,
recordkeeping, and reporting are being
implemented
•	Process unit IDs
•	Equipment IDs, equipment type,
percent VHAP, state of VHAP fluid,
and method of compliance
SLIDE 6-6

-------
^SS^SBBSKSSSKSB^SSSSS^^^^SSSSKSBSSSS^aSSS^aa
BENZENE SEMI-ANNUAL REPORT
•	Process unit ID
•	For each month, the number of valves,
compressors, and pumps that:
were detected leaking
were not repaired (explain any delay of
repairs and why process shutdown
infeasible)
•	Dates of process shutdowns during period
•	Revisions to initial statement
•	Results of all performance tests to determine
compliance with:
no detectable emissions (pumps, valves,
compressors, PRD gas/vapor and C-V
systems)
alternatives for valves (2 percent annual
leakage and skip periods)
SLIDE 6-7

-------
OTHER BENZENE REPORTING
ASPECTS
•	First semi-annual report to include a
schedule for semi-annual reporting
•	Alternative standards for valves - 90
day notification required
•	Application for approval of
construction/modification not required
if:
new source complies with
standards
new source is not part of the
construction of a process unit
all information is submitted in next
semi-annual report
SLIDE 6-8
FUGITIVE VOC (LEAKS)
RECORDKEEPING REQUIREMENTS
SLIDE 6-9

-------
RECORDS FOR EQUIPMENT
List - IDs of all equipment (except welded
fittings)
No detectable emissions designation
List of IDs of applicable pumps,
compressors, and valves, and signature of
owner/operator
List of IDs of applicable pressure relief devices
in gas/vapor service
For each compliance test:
date
background reading
maximum reading of equipment
List of IDs of equipment in vacuum service
SLIDE 6-10
SSSSSBSBB
RECORDS FOR CLOSED-VENT
SYSTEMS AND CONTROL DEVICES
•	Detailed schematics
•	Design specifications
•	Piping and instrumentation diagrams
•	Dates and description of changes
•	Description and rational of monitoring
parameter(s)
•	Non-operational periods
•	Periods of no flame in pilot light for
flares
•	Dates of start-up/shut-downs
SLIDE 6-11

-------
RECORDS FOR PUMPS
AND COMPRESSORS
Dual mechanical seal and barrier fluid
sensor
design criterion
- explanation
any changes (and reasons)
SLIDE 6-12
RECORDS FOR VALVES
•	Unsafe
- IDs
reason
monitoring plan
•	Difficult to monitor
IDs
reason
monitoring schedule
SLIDE 6-13

-------
RECORDS FOR SKIP PERIODS
VALVES
•	Schedule of monitoring
•	Percent of leaking valves per period
SLIDE 6-14
RECORDS FOR EXEMPTIONS
•	Log of:
analysis of design capacity of
process unit
analysis of feed or raw materials
•	Information and data to demonstrate
that a piece of equipment is not in
VOC service
SLIDE 6-15

-------
RECORDKEEPING REQUIREMENTS
FOR COMPLIANCE MONITORING
RESULTS BY M-21
•	Monthly (10,000 ppm):
pumps
valves
•	Annual (no detectable emissions, 500
ppm):
pumps
compressors
valves
closed-vent systems
SLIDE 6-16
RECORDKEEPING REQUIREMENTS
FOR COMPLIANCE MONITORING
RESULTS BY M-21 (CONT.)
•	Other:
pressure relief devices gas/vapor
within 5 days of a release (500
ppm)
pressure relief devices, liquid
flanges, and other connections
within 5 days of a potential leak
(10,000 ppm)
•	Leaks:
after each repair attempt
closed-vent systems
SLIDE 6-17

-------
MARKING OF LEAKS
•	Weatherproof and visible ID
•	Must remain until repaired (valves -
must remain for 2 monthly monitoring
periods)
SLIDE 6-18

-------
RECORD OF LEAKS
Maintain records for 2 years
ID of:
leaking equipment
instrument
operator
Dates of:
leak detected
each repair attempt
expected repair completion
process unit shutdowns while
unrepaired
successful repair
Maximum instrument reading after
each repair attempt "above 10,000"
Signature of owner/operator/designate
decision - delay repair to process
shutdown
SLIDE 6-19

-------
RECORD OF LEAKS
Unit/Area Name:
Comp.
ID No.
Comp.
Type
Leak
Tag No.



	Survey Date:.
Date
Initial
CONC
(ppm)
Recheck
CONC
(ppm)
Initial
Discoveiy
Re-
paired
Monitor
Recheck






Repair
Delay Explanation
Expected
Repair
Date


SLIDE 6-20
6-12

-------
SUMMARY OF REPORTING AND RECORDKEEPING
Component
Reports
Records
Valves, Pumps, Compressors
# of leaks, and those not
repaired
test/repair data
Alternative Valves
percent leaking
performance test data
No detectable emissions
(including designated valves,
pumps, compressors, and
pressure relief devices in
gas/vapor service)
performance/monitoring
test results
performance/monitoring test
data
Pressure relief devices in liquid
service, flanges and other
connectors
NONE
test/repair data
Seal/Barrier Fluid System (for
pumps, compressors)
NONE
design information and
failure sensor criteria
Closed vent systems and control
devices
performance test results
schematics, design
parameters, diagrams,
monitoring information,
periods of non-compliance,
startups and shutdowns
SLIDES 6-21 & 6-22
6-13

-------
LECTURE 7
IMPLEMENTATION DECISIONS
AND GUIDANCE

-------
IMPLEMENTATION DECISIONS
AND GUIDANCE
SLIDE 7-1
EPA POLICY MEMORANDA
•	Enforcement Guideline S-28
•	Sewers
•	Oil/water separators
•	Storage terminals
•	Use of benzene versus purchase of
benzene
•	Welded fittings
•	Bypasses of control devices
•	Product accumulator
•	Determination of "in benzene or
vinyl chloride service"
•	Insulated valves
•	Plant site
SLIDE 7-2

-------
RECORDKEEPING/REPORTING FOR
ENFORCEMENT
•	Data for records different than data for
reports
Pumps, compressors, and valves.
Record all test/repair data, but
report only the number that
leaked.
PRD liq, flanges, and other
connectors: record test/repair data
but no reporting
C-V SYS: record periods of
noncompliance, but report only the
annual performance tests
Alternative skip period valves:
record percent leaking, but report
only the number found leaking
•	No mechanism for recording or
reporting leaks/repairs of sampling
connections and open-ended lines and
valves
•	No schedule for visual emissions
determinations from flares
SLIDE 7-3

-------
PLANT OPERATOR
DETERMINATIONS
•	Plant does the initial determination as
to "in benzene or vinyl chloride
service"
•	Plant sets criterion for "leaks" at
pumps and compressors with dual
mechanical seals with barrier fluids
•	Plant sets monitoring system of proper
operating conditions for control
devices
SLIDE 7-4

-------
LECTURE 8
INSPECTION TECHNIQUES

-------
OBSERVATION/INSPECTION
OF
MONITORING RECORDS
AND PROCEDURES
SLIDE 8-1
SUGGESTED INSPECTION STEPS
•	Pre-inspection records search
•	Check applicability
-	Reporting status
•	Initial inspection
-	Check records
•	Equipment survey
-	Plant procedures
•	Post-inspection data sorting
•	Additional inspections
SLIDE 8-2

-------
PRE-INSPECTION RECORDS SEARCH
CHECK APPLICABILITY
•	Review initial reports and/or waiver
request
•	Cross-check with other air, wastewater
(NPDES), hazardous waste (RCRA),
and toxic substances (TSCA) permits
SLIDE 8-3
PRE-INSPECTION RECORDS SEARCH
REPORTING STATUS
•	Review all reports submitted and
compare to the applicability
determination
•	Highlight questions areas and data to
be checked against plant records
•	Does facility seem to be in
compliance? If not, why not?
•	List questions to be asked and items to
be checked during inspection
SLIDE 8-4

-------
INITIAL INSPECTION CHECK
RECORDS
•	Compare with data from reports
•	Are records complete per regulations?
•	Verify unsafe and difficult to monitor
determinations listed
•	Check process unit determinations
SLIDE 8-5
CHECKING REPORTS AND ON-SITE
RECORDS
•	Pumps, compressors, and valves
-	Compare test/repair data in records
to the numbers reported in last
several reports
-	Compare cumulative totals of leaks
and repairs from records and
reports
•	C-V SYS and control devices
-	Check records for excessive periods
of noncompliance
SLIDE 8-6

-------
CHECKING REPORTS AND ON-SITE
RECORDS
No detectable emissions equipment
-	Compare test data in records to
reported results
Alternative valves
-	Check % leaking in records to
reported result
Exemptions
-	Check records to determine if
exemptions are still applicable
SLIDE 8-7
INITIAL INSPECTION
EQUIPMENT SURVEY
Review ID system
Spot-check product accumulators,
sampling connectors, open-ended lines
and valves, etc., for correct equipment
usage per regulations
SLIDE 8-8

-------
INITIAL INSPECTION
PLANT PROCEDURES
•	Monitoring
•	Repairs
•	Tracking system for scheduling
monitoring and repairing as per
regulations
•	System for recording and reporting
their inter-connected data
•	Criterion for failure of dual mechanical
seals with barrier fluids
•	Monitoring of operation of control
devices
SLIDE 8-9
POST-INSPECTION DATA SORTING
•	Review applicability determination for
completeness
•	Review process units and equipment
listings
•	Compare reports to field inspection
notes/copies of records
•	Is recordkeeping system adequate to
track monitoring, leaks, and repairs?
•	Are monitoring staff, equipment, and
procedures adequate?
•	List items to be checked during next
inspection
SLIDE 8-10

-------
ADDITIONAL INSPECTIONS
•	Review file and past inspection report
•	Spot check for leaks (either visually or with
OVA equipment) - select recently repaired
equipment
•	Review records
•	Spot check a different area of plant by
generally walk-through in an effort to
eventually cover the entire affected facility
•	Spot check a different type of equipment
during each inspection
•	Spot check a different portion of the records
during each inspection
SLIDE 8-11

-------
LECTURE 9
INSPECTION SAFETY

-------
SELECTING AND USING VOC
ANALYZERS
•	Only instruments which are rated
intrinsically safe for Class I, Division I
and Division 2 areas should be used.
•	Instrument recorders must meet the
same requirements as the instrument
itself.
•	Intrinsically safe instruments will have
a clearly marked seal.
SLIDE 9-1
SELECTING AND USING VOC
ANALYZERS: CHARACTERISTICS OF
INTRINSICALLY SAFE UNITS
*	Encased battery packs
*	Encapsulated amplifiers
*	Specially designed electrical circuiuy
*	Flame arrestors (Flame ionization
instruments)
SLIDE 9-2

-------
nsBSsnsa^HBBssasBesssssssBsssss^nBaaMaESMMi
SELECTING AND USING VOC
ANALYZERS
Before using an instrument, it is necessary
to confirm that the protective features have
not been disabled by unauthorized repair.
SLIDE 9-3
SELECTING AND USING VOC
ANALYZERS
•	Do not attempt to screen equipment
more than 6 feet above secure
platforms.
•	Do not attempt to hold the analyzers
while climbing ladders. Both hands
must be free.
•	Avoid unprotected rotating equipment
which could snag loose support straps
of the instrument.
•	Avoid work in close proximity to hot
equipment or around slippery surfaces.
SLIDE 9-4

-------
BASIC REASONS FOR INHALATION
RISKS
•	The instrument probes are very short
•	The VOC emission plume
concentrations are very high.
•	It is necessary to position the probe in
line with the emission plume in order
to achieve satisfactory capture.
•	There can be several fugitive VOC
leak sites around the equipment being
checked.
SLIDE 9-5
INHALATION HAZARDS
•	Many of the fugitive VOC compounds
have very poor warning properties.
The odor, taste, and irritations are well
above the permissible exposure limits.
•	Many of the fugitive VOC compounds
have serious physiological effects.
SLIDE 9-6

-------
MINIMIZING INHALATION HAZARDS
•	Do not enter areas with poor natural
ventilation.
•	Do not stand directly above the
portable analyzer probe.
•	Leave the instrument on while walking
through the facility to detect any
intermittent fumigation from VOC
leaks in the general area.
•	Wear respirator protection approved
by plant and agency safety officials.
SLIDE 9-7
LIMITATIONS OF RESPIRATORS
•	Organic cartridges and canisters are
not equally effective for all types of
organic compounds. Consult published
tables of relative breakthrough times.
•	Organic vapor air purifying respirators
become less effective when the air
temperature and/or the relative
humidity increases.
•	Both cartridges and canisters for
organic vapor suffer breakthrough
quickly.
SLIDE 9-8

-------
LIMITATIONS OF RESPIRATORS
•	Many organic compounds emitted as
fugitive leaks are skin absorbable.
Respirators do not provide any
protection against these materials.
•	Decontamination of respirator face
pieces sprayed by liquids may be
incomplete and thereby create a future
hazard.
SLIDE 9-9
GENERAL SAFETY POLICIES
The inspector should obtain all necessary
personal protection equipment prior to
leaving for the inspection site. Equipment
should not be borrowed from the plant
SLIDE 9-10

-------
GENERAL SAFETY POLICIES
Inspectors should not work alone. A plant
representative should accompany the
inspector at all times.
SLIDE 9-11
GENERAL SAFETY POLICIES
Inspectors should take regularly scheduled
breaks and drink fluids to reduce the risk
of heat stress.
SLIDE 9-12

-------
GENERAL SAFETY POLICIES
Inspectors must comply with all DOT
regulations if taking compressed calibration
gas cylinders to the inspection site.
SLIDE 9-13
GENERAL SAFETY POLICIES
Inspectors must be aware of and conform
to all applicable plant and agency safety
policies.
SLIDE 9-14

-------