United States Office of Air Quality Office of
Environmental Protection Planning and Standards Research and Development
Agency RTP, NC 27711 Cincinnati OH 45268
Technology Transfer CERI 90-124b December 1990
&EPA Workshop -
Organic Air
Emissions from
Waste Management
Facilities
Speaker Slide Copies and
Supporting Information
Volume 2
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ORGANIC AIR EMISSIONS FROM WASTE
MANAGEMENT FACILITIES
Speaker Slide Copies and Supporting Information
December 1990
Document Prepared by
PEER Consultants, P.C.
Dayton, OH 45432
and
Slides and Presentations Prepared by
Research Triangle Institute
RTP, NC 27709
for
Office of Research and Development
Cincinnati, OH 45268
and
Office of Air Quality
Planning and Standards
RTP, NC 27711
Printed on Recycled Paper
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NOTICE
This document is a preliminary draft. It has not been formally released by
the U.S. Environmental Protection Agency and should not at this stage be
construed to represent Agency policy. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
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TABLE OF CONTENTS
Abbreviation Index iv
Section 1
Implementation of RCRA Air Rules
Abstract 1-1
Slides 1-2
Section 2
Benzene Waste NESHAP
Abstract 2-1
Slides 2-2
Section 3
Compliance Inspections 3-1
Slides 3-2
Section 4
Leak. Detection Monitoring 4-1
Slides 4-2
iii
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r
ABBREVIATION INDEX
ACT
API
ARAR
ASTM
ASTSWMO
Atm
BDAT
Btu
BZ
°C
CAA
CERCLA
CERI
CFC
cfm
CFR
CPI
CTG
CWA
DOT
DRE
dscm
EDC
Alternative Control Techniques Document
American Petroleum Institute
Applicable, Relevant, and Appropriate Requirements
American Society for Testing and Materials
Association of State and Territorial Solid Waste Management Officials
Atmosphere
Best Demonstrated Available Technology
British Thermal Units
Benzene
Celsius
Clean Air Act
Comprehensive Environmental Response, Compensation, and Liability
Act (Superfund)
Center for Environmental Research Information
Chlorofluorocarbons
Cubic Feet per Minute
Code of Federal Regulations
Corrugated Plate Interceptor
Control Techniques Guideline Document
Clean Water Act
Department of Transportation
Destruction and Removal Efficiency
Dry Standard Cubic Meter
Ethylene Dichloride
iv
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EP Extraction Procedure
EPA United States Environmental Protection Agency
ESD Emission Standards Division
ER Emission Rate
FID Flame Ionization Detector
FR Federal Register
ft Feet
gal Gallon
GC Gas Chromatography
h Hours
HAP Hazardous Air Pollutant
HLC Henry's Law Constant
HON Hazardous Organic NESHAP
HSWA Hazardous and Solid Waste Amendments
HWMU Hazardous Waste Management Unit
IR Infrared
kg Kilograms
kPa Kilopascal
L Liters
lb Pounds
LDAR Leak Detection and Repair
LDR Land Disposal Restrictions
m^ Cubic Meters
Mg Megagrams
v
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MS Mass Spectrometry
MW Megawatts
NAAQS National Ambient Air Quality Standards (CAA)
NAPCTAC National Air Pollution Control Techniques Advisory Committee
NCP National Contingency Plan (CERCLA)
NESHAP National Emission Standard for Hazardous Air Pollutants (CAA)
NPDES National Pollution Discharge Elimination System (CWA)
NSPS New Source Performance Standards (CAA)
OAQPS Office of Air Quality Planning and Standards
OAR Office of Air and Radiation
ORD Office of Research and Development
o/o Owner/Operator
OSW Office of Solid Waste
OSWER Office of Solid Waste and Emergency Response
PCB Polychlorinated Biphenyls
PM Particulate Matter
POTW Publicly Owned Treatment Works
ppm Parts per Million
ppmv Parts per Million by Volume
ppmw Parts per Million by Weight
psia Pounds per Square Inch Absolute
psig Pounds per Square Inch Gauge
RAC Reference Air Concentration
RACT Reasonably Available Control Technology
RCRA Resource Conservation and Recovery Act
vi
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SEPA
IMPLEMENTATION OF
RCRA AIR RULES
1-1
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ABSTRACT: IMPLEMENTATION OF RCRA AIR RULES
The Accelerated Rules (Phase I) as promulgated are self-implementing, composed
of specific requirements. Compliance is possible from direct reading of the
regulations. No need exists for interaction between the permittee and the permitting
agency or for judgement in interpretation of the regulations.
The Phase I rules are HSWA regulations. As a result, the rules are effective
immediately in all states. In nonauthorized states, the rules will be enforced by the
U.S. EPA. In HSWA-authorized states, the rules will initially be enforced after state
programs are revised. For the Phase I rule, state program revision should be completed
by July 1, 1991 (or July 1, 1992, if a statutory change is required). The implementation
of Phase II is essentially identical to Phase I with the schedule to be determined by the
promulgation date.
The Phase I rules are effective as of December 21, 1990, six months from
promulgation. The compliance date for specific facilities is tied to the classification of
the facility (i.e., permitted, interim status, newly regulated, or new facility). Specific
compliance requirements of facilities are tied to the facility classifications as well. By
the effective date, all facilities must be in compliance, have a compliance schedule in
the operating record, or document that the emission rate standard is not exceeded.
Control equipment must be installed within 18 months after the effective date.
Proposed rules of Phase II will have impacts on Phase I rules. Changes proposed
under Phase II include the elimination of permit as a shield and the inclusion of
accumulation tanks and containers to comply with Subparts AA, BB, and CC.
Accumulation is a RCRA regulation and would follow RCRA state implementation (as
opposed to HSWA implementation) procedures. Phase II rules would become effective
six months after promulgation which is anticipated in late 1991.
1-2
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Highlights
• Regulations are self-implementing
• Effective date 6 months after
promulgation (Dec. 21, 1990)
• Control equipment to be installed within
18 months after effective date depending
on type of facility
• Changes under Phase II for Phase I
Topics
I. Background
II. Requirements of Phase I Rules
III. Changes under Phase II
Topics
I. Background
- Self-Implementing Rules
- State Authorization
II. Requirements of Phase I Rules
III. Changes under Phase II
1-3
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Background
Regulations are Self-Implementing
• No need for interaction
• Specific requirements
• No judgment involved
• Requirements for 264 and 265 identical
Background
State Authorization
Air rules are pursuant to 3004(n) of HSWA,
therefore:
• Effective immediately in all States
• Implemented by EPA in nonauthorized
States
• Implemented by EPA in authorized States
until State program is revised
Background
State Authorization
(continued)
• Authorized States must adopt Phase I
regulations by:
- July 1,1991
- July 1,1992.(if statutory change
required)
• Schedule can be extended in some cases
1-4
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Topics
I. Background
II. Requirements of Phase I Rules
- Impacts on permitting
- Applicability to different types of
facilities
- Compliance requirements
- Information for Part B applications
- Facilities without installed controls
III. Changes under Phase II
Phase I Rules
Implementation Impacts
on Permitting
• Delays likely on permits scheduled in early
1991
• Minimize delays by:
- Calling for Part B information early
- Incorporating air requirements into draft
permit
Phase I Rules
When To Expect Facility
Information
Dependent upon
• Effective date of Phase I standards
(Dec. 21, 1990)
• Compliance date tied to the
classification of the facility
l-S
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Phase I Rules/Facility Type
interim Status Facilities
* Subject to rules on the effective date
(Dec. 21, 1990)
• Modified Part B applications submitted,
before effective date
Up to 24 months (18 months from
effective date) allowed to install control
equipment (June 21,1992)
Phase I Rules/Facility Type
Permitted Facility
• Permits issued before effective date
(Dec. 21,1990) are shielded from Phase
air standards
• Agency can apply the standardswhen
permit is:
Reissued
Modified
• Phase I rules provide cause for Agency to
modify permit under 270.41
Phase I Rules
Applicability to Different
Types of Facilities
• Interim status facility/unit
• Permitted facility
• Facility/unit newly subject to RCRA
• Newly constructed facility/unit
• Unit newly subject to air standards
1-6
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Phase I Rules/Facility Typo
Facility/Unit Newly
Subject to RCRA
Example: A unit or facility is brought under RCRA
regulation because of a newly listed waste
• Air standards apply 6 months after listing
date of waste
• Up to 24 months (18 months from listing
of waste) allowed to install control
equipment
Phase I Rules/Facility Type
Newly Constructed Facility
• Facility being permitted
- Permits issued after Dec. 21, 1990,
must include applicable air emission
standards
- Receive final permit prior to construction
- Part B applications submitted prior to
effective date (Dec. 21, 1990) to be
modified
- Controls in place and operating upon
startup
Phase I Rules/Facility Type
Newly Constructed
Facility/Unit
(continued)
• New unit at permitted facility
- Permit modification required
- Standards apply on date permit
modification approved
• New unit at interim status facility
- Revised Part A application required
- Standards apply on date revised Part A
approved
• Controls installed and operating upon
startup
1-7
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Phase I Rules/Facility Type
Unit Newly Subject
to Air Standards
Example: Facility experiences a change in
waste concentration that exceeds waste
classification limits (10 ppmw, Subpart AA, or
10%, Subpart BB)
• Air rules apply on the date facility exceeds
• Control must be installed and operating
on effective date
limits
Phase I Rules
Compliance Requirements
for Phase I Rule$
1. Documention of determinations must be
complete by effective date
Review:
- Waste determinations
- Emission estimates
- Control device efficiencies
Phase I Rules
Compliance Requirements
for Phase I Rules
(continued)
2. Review data-in operating record:
- Monitoring results
- Leak detection results
- Repair records
1-8
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Phase I Rules
Compliance Requirements
(continued)
3. By effective date, facility must:
- Be in compliance
- Have implementation schedule in
operating record, or
- Document that emission rate is not
exceeded.
Phase I Rules
Compliance Requirements
(continued)
4. Control equipment must be installed
within 24 months (18 months after
effective date)
Phase I Rules
Information for
Part B Applications
Documentation must include:
1. Equipment and process vent determinations
2. Determination that process vent emission
rate limit is or will be met
3. Determination of equipment in heavy-liquid
service
1-9
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Phase I Rules
Information for Part B
Applications
(continued)
4. Reports and records of leak detection
and repair
5. Verification of:
- Use of appropriate test methods,
and/or
- Engineering judgment
6. Implementation schedule (if controls not
installed on effective date)
Phase I Rules
Procedure for Facilities
without Controls Installed
by Effective Date
1. Extension of up to 18 months allowed:
- Interim status facilities
- Newly regulated facilities
Document that installation could not
•reasonably be expected to be completed.
earlier
3. Show dates by which design and
construction will be completed
Phase I Rules
Procedure for Facilities
without Controls Installed
by Effective Date
(continued)
4. Install equipment wittyn 2 years from
promulgation
5. Document that any schedule change
could not reasonably be avoided
6. Schedule in operating record on effective
date
1-10
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Topics
I. Background
II. Requirements of Phase I Rules
III. Changes under Phase II
Changes under
Phase II
• Implementation of Phase II same as
discussed under Phase I
• Changes to Phase I
- Permit-as-a-shield
- Accumulation tanks and containers
• Changes to Phase I effective 6 months after
promulgation of Phase II (anticipated late 1991)
Phase II/
Permit-as-a-Shield
How Would Elimination
of Permit-as-a-Shield
Affect Phase 1 Rules?
1. Permitted facilities originally exempt from
Phase I rules would become subject to
interim status rules (Part 265)
- Additional time allowed to install
control equipment
2. Interim status rules would apply directly
until permit is modified or reissued
1-11
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Phase II/Accumulation
Tanks and Containers
Phase II Regulatory Revisions
• Would require compliance with AA, BB,
and CC control requirements to maintain
permit exemption
• Would not affect:
- Small-quantity generators
- Satellite accumulation
Summary
• Rules are self-implementing
• Phase I regulations effective as of
December 21,1990
• Compliance date depends on
classification of facility
• Phase I rules are HSWA rules, effective
immediately
• Promulgation of Phase II affects
implementation of Phase I air rules
1-12
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Toxicity Characteristic
Background
•
RCRA interprets "hazardous" characteristic as:
- Ignitable - Reactive
- Corrosive - Toxic
•
40 Toxic organic and inorganic compounds and elements
•
Concentration-based limits for toxicity characteristic
leaching procedure
•
Effective date = September 25,1990
Toxicity Characteristic
Relation to Section 3004(n) Standards
• Increases the volume of waste managed as hazardous
Land Disposal Restrictions
Background
• Treatment required before land disposal
• Land disposal units include:
— Landfills
— Surface impoundments
— Wastepiles
— Land treatment units
— Underground injection wells
• Final effective date = May 8, 1990
• Surface impoundments (treatment) exempt
if dredged annually
1-13
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Land Disposal Restrictions
Air Emissions Reduced by Land Ban
Organic Emission
Sources
Yes
No
Tanks
V
Containers
V
Process vents
Equipment leaks
¦J
Miscellaneous units
V
Surface impoundments
J
Landfills
-i
Land treatment units
V
Wastepiles
V
Underground injection wells
V
Land Disposal Restrictions
Impact on TSDF Air Emissions
• Treatment can cause cross-media air emissions
• Treatment reduces air emissions from land disposal units
Land Disposal Restrictions
Relation to TSDF Air Standards
• Phase I addresses LDR treatment process emissions
• Phase II suppresses emissions to LDR treatment unit
for removal or destruction
1-14
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Corrective Action
Background
• Addresses constituent releases to air, water, and soil
• Applies to hazardous and solid waste management
units at TSDF
• Establishes site-specific compliance standards for
releases to each media
Corrective Action
Relation to Section 3004(n)
Air Standards
• Corrective action units must comply with air rules
• Corrective action relies on Section 3004(n) for control
of organic emissions
CERCLA/SARA
Background
• Authorizes EPA to "remove" and "remediate" hazardous
substance releases
• *Removal"-short-lerm action to minimize exposure
Example: cleanup of a transportation spill
« "Remediation"-long-term action to provide permanent remedy
1—15
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CERCLA/SARA
Criteria
• Site-specific
• 10'6 target risk
• Meet ARARs
CERCLA/SARA
ARARs - "Applicable or Relevant
and Appropriate Requirements"
• "Applicable" requirements - rules applicable to CERCLA
actions
• "Relevant and appropriate" requirements - rules not
applicable but similar
CERCLA/SARA
ARARs - Relation to TSDF
Air Standards
• Phase I may be ARARs for certain processes
• Phase II when promulgated may be ARARs for certain
processes
• Hazardous waste generated at CERCLA sites would
be managed at TSDF (under air standards)
i -1 (>
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CERCLA/SARA
ARARS — Potential Relation
to TSDF Air Standards
Applicable
Relevant and
appropriate
Hazardous wastes
>10 ppmw
volatile organics
'Substances" (e.g., non-
hazardous wastes)
>10 ppmw
volatile organics
CERCLA Management
Processes:
Distillation
Thin-film evaporation
Air stripping
Steam stripping
Fractionation
Solvent extraction
CERCLA/SARA
ARARs - Relation to TSDF
Air Standards
• Phase I process vent standards are neither "applicable" nor
"relevant and appropriate" to:
— Soil excavation — In situ soil vapor extraction
— In situ steam — Soil washing
stripping of soil _ Bioremediation
In situ stabilization
— Low-temperature thermal
desorption
Summary
• Rules are self-implementing
• Phase I regulations become effective on
December 21,1990
• Compliance date depends on
classification of facility
• Phase I rules are HSWA rules/effective
immediately
• Promulgation of Phase II affects
implementation of Phase I air rules
1-17
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&EPA
RCRA PERMIT WRITING
2-L
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ABSTRACT: PERMIT WRITING
This section contains materials on information required in RCRA Part B permit
applications regarding compliance with 40 CFR 264, Subparts—
A A— Air Emissions Standards for Process Vents, and
BB — Emission Standards for Equipment Leaks.
This section also provides a permit application completeness checklist for these
Subparts and an instruction on how to evaluate this Part B information. Specific
exercises on reviewing Part B information are provided in the Case Study.
2-2
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BIBLIOGRAPHY: PERMIT WRITING
1. 55 FR 25454. Hazardous Waste Treatment, Storage, and Disposal
Facilities; Organic Air Emission Standards for Process Vents and
Equipment Leaks. Final Rule. June 21, 1990.
2. Permit Writer's Training Manual. A videotape sponsored by the
Association of State and Territorial Solid Waste Management Officials.
Produced by the University of Michigan. 1989.
3. Model RCRA Permit for Hazardous Waste Management Facilities. Draft.
U. S. Environmental Protection Agency, Office of Solid Waste.
September 1988.
4. RCRA Permit Quality Protocol. U.S. Environmental Protection Agency,
Office of Solid Waste. September 1988.
2-3
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RCRA Part B
Information Requirements
for Phase I Rules
Process Vents and Equipment Leaks
Part B Topics To Be Covered
• Inspection and Monitoring Schedule
• Documentation of Compliance
• Implementation Schedule
Process Vents and Equipment -
Inspection and Monitoring Schedule
• Required in "General Inspection Schedule"
• Phase I inspection and monitoring procedures
(40 CFR 264.1033 - Process Vents)
(40 CFR 264.1052, .1053, and .1058 - Equipment)
• Schedule must address:
- Control devices
- Closed-vent systems
- Equipment
2-4
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PROCESS VENTS
Control Device Monitoring Schedule
Control devices
Parameter
Monitoring
schedule
Notes
IProcess venl flow rale
to all control devices)
Hourly
-
Thermal vapor Incinerator
Temperature
Continuous
One sensor required
Catalytic vapor incinerator
Temperature
Continuous
Two sensors
required
Rare
Temperature
Continuous
Use heat sensing unit
Boiler or process heater
Temperature
Continuous
<44 MW
Boiler or process heater
Indicator ot
good
combustion
Continuous
>44 MW
PROCESS VENTS
Control Device Monitoring Schedule
Control devices
Parameters
Monitoring schedule
Condenser
Organic conc.
or temperature
Continuous
Fixed-bed carbon adsorber
Organic conc.
or
indicator (or
predetermined
regeneration time
Continuous
Continuous
Nonregenerable carbon
adsorber
Organic conc.
or carbon
consumption lime
Daily, or
interval not >20%
PROCESS VENTS
Control Device Inspection Schedule
Control devices Inspection schedule
All control devices At least daily
2-5
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PROCESS VENTS
Closed-Vent Systems -
Inspection and Monitoring Schedule
• Monitoring for leaks >500 ppm volatile organics
- On date facility becomes subject to standards
- Annually
- Per Regional Administrator's request
• No inspection frequency specified
EQUIPMENT LEAKS
Inspection and Monitoring Schedule
Equipment
Monitoring
Inspection
Light liquid service pumps
Monthly (Method 21)
Weekly (visual)
Compressors
Not specified
Daily (failure sensor), or
Monthly (audible alarm)
Heavy liquid service pumps -i
Pressure-relief devices
(light or heavy liquids)
Within 5 days of
finding potential leak,
use Method 21
Use visual, audible
olfactory, or other method
(frequency not specified)
Flanges
Other connections
Part B Topics To Be Covered
• Inspection and Monitoring Schedule
• Documentation of Compliance
• Implementation Schedule
2-6
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PROCESS VENTS AND EQUIPMENT LEAKS -
DOCUMENTATION OF COMPLIANCE
Identification of Affected Vents and
Equipment
• Inventory of all process vents and equipment -
identity and location of each
• For each hazardous waste management unit with
process vent and/or ancillary equipment:
- Annual waste throughput
- Operating hours
• Data to determine if process vents and equipment
are subject to regulation
PROCESS VENTS AND EQUIPMENT LEAKS -
DOCUMENTATION OF COMPLIANCE
Performance Test Plan
Performance test plan is needed for control devices not
specified in the regulation. Test plan must include:
• Test procedures
• Operating conditions
• Acceptable operating ranges of key process and
control device parameters during testing
PROCESS VENTS AND EQUIPMENT LEAKS -
DOCUMENTATION OF COMPLIANCE
Design Information
• Flow rate and organic content of each equipment piece
• Detailed engineering description of closed-vent system
and control device
- Type
- Manufacturer's name and model number
- Dimensions
- Capacity
- Construction materials
2-7
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PROCESS VENTS AND EQUIPMENT LEAKS -
DOCUMENTATION OF COMPLIANCE
Other Compliance Requirements
• List of all information sources supporting documentation
• Dates of compliance tests and other pertinent records
• Owner/operator certification of representativeness of
operating parameters
• Owner/operator statement certifying 95% control device
efficiency
PROCESS VENTS -
DOCUMENTATION OF COMPLIANCE
Emissions Determinations for Process Vents
• Estimated uncontrolled emission rate per process vent
• Cumulative TSDF process vent emission rate
• Data supporting estimated controlled process vent
emission rates*
• Data supporting estimated emission reduction
achieved*
'Data must reflect highest loading or capacity level of process
vent reasonably expected.
Part B Topics To Be Covered
• Inspection and Monitoring Schedule
• Documentation of Compliance
• Implementation Schedule
2-8
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Implementation Schedule
• Required when controls cannot be installed by the time
affected vents and equipment become subject to
Subparts AA and BB
• Content of schedule:
- List of each closed-vent system and control device
- Date each becomes fully operational
Implementation Schedule (continued)
• Content of schedule (continued):
- Rationale why it cannot operate on effective date
• Vendor's delivery constraints
• Immediate installation causes greater
emissions than delaying installation until
routine shutdown
Instructions for
Writing RCRA Permits
2-9
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Current Model RCRA Permit - Contents
• Permit cover sheet
• 13 permit modules:*
- I - II General permit conditions
- Ill-IX Permit conditions by hazardous waste
management unit type
- X - XII Groundwater monitoring and corrective
action permit conditions
- XIII Post-closure care
« New air modules:
- XIV Process vents
- XV Equipment
"Source: EPA's Model RCRA Permit for Hazardous Waste
Management Facilities, Draft, September 1988.
Options for Writing Permit Conditions
• Streamline approach, or
• Prepare detailed permit conditions
Streamlining Approach
Simply state in permit:
"The permittee shall comply with the air emissions
requirements of 40 CFR 264, Subpart AA (for process
vents) and/or Subpart BB (for equipment leaks) as
applicable."
2-10
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Preparing Detailed Permit
Conditions for Process Vents
(Module XIV)
Process Vents Applicability
Waste >10 ppm organics
Permitted
Hazardous Waste
Mgt. Units
Recycling
Units
PROCESS VENTS
Format for Model Permit Conditions
• Summary of regulated activities
• Permitted and prohibited waste identification
• Emission control technology
• Operating requirements
• Monitoring and inspection schedules and
procedures
• Recordkeeping and reporting
• Compliance schedule
2-11
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Summary of Regulated Activities
Permit includes a general description of air emission
activities:
• Listing of each process vent with waste organic
concentration >10 ppmw
• Each vent's approximate location at the facility
• Annual waste throughput per hazardous waste
management or recycling unit connected to a process
vent (including nonhazardous waste)
Summary of Regulated Activities (continued)
• Number of hours the unit operates annually
• Estimated uncontrolled and controlled organic emission
rate per vent
• Estimated total facility organic emission rate from
regulated process vents
Permitted and Prohibited Waste Identification
The permittee may vent emissions from the following wastes subject to the terms of this permit
as follows:
Venl
ID No.
Hazardous waste
management or
recycling unit
Description ot
hazardous waste
EPA hazardous Maximum
waste number wBste volume
Example:
A.I.
Treatment Tank A
Waste halogen-
oted solvents
F001 11,000 gal/yr
The permittee is prohibited Irom managing hazardous waste that is no! identified in permit
condition XIV.B.1
2-12
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PROCESS VENTS
Emission Control Technology
The permittee shall design, install, operate, and maintain
the closed-vent system and control device(s) according to
detailed plans and reports contained in permit attachment
XIV-1. [40 CFR 264.1032(a)(2) and 264.1033]
Operating Requirements
The permittee shall operate each vapor recovery
control device at an efficiency of 95 percent or greater
unless total organic emission limits of 3 Ib/h and 3.1 ton/yr
for all affected process vents can be attained at an efficiency
of less than 95 weight percent. [40 CFR 264.1033(b)]
Monitoring and Inspection
Schedules and Procedures
The permittee shall monitor the closed-vent system and
control devices in accordance with the monitoring schedule,
permit attachment XIV-2, and shall comply with the following
permit conditions as part of that monitoring.
• Each process vent flow rate shall be monitored hourly
using the procedures in permit attachment XIV-2.
[40 CFR 264.1033(f)(1)]
• For thermal vapor incinerators, temperature shall be
monitored continuously using at least one sensor.
[40 CFR 264.1033(f)(2)(i>]
• (More examples in model permit)
2-13
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Recordkeeping and Reporting
The permittee shall keep on file at the facility in attachment
XIV-4 the implementation schedule required in Subpart
AA.
Recordkeeping and Reporting
The permittee shall report semiannually to the Regional
Administrator the dates during the reporting period when
a control device exceeded or operated outside the design
specifications as defined in 40 CFR 264.1035(c)(4) as
indicated by the control device monitoring required by 40
CFR 264.1033(f) and was not corrected within 24 hours.
[40 CFR 264.1036(a)(2)]
[Note: For flares that operate with visible emissions as
defined in 40 CFR 264.1033(d) as determined by
Method 22 monitoring, the report shall include
the duration and cause of each exceedance or
visible emission and any corrective measures
taken.]
Implementation Schedule
Permittee shall comply with the Implementation Schedule required by Subpart AA.
Item Date
Example:
1. Installation of carbon June 26,1991
adsorber on tank A
2. Installation ol condenser January 10,1992
on distillation unit K
2-14
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Permit Attachments Referenced in
Module XIV - Process Vents
Permit Attachment No.
Plan or Document
XIV-1
Detailed plans and reports on the design,
installation, operation, and maintenance of
closed-vent systems and control devices
XIV-2
Closed-vent system and control device
monitoring schedule and procedures
X!V-3
Closed-vent system and control device
inspection schedule and procedures
XIV-4
Implementation schedule
XIV-5
Performance test plan for control devices other
than those listed in the regulations
Omnibus Permitting
Authority
2-15
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Omnibus Permitting Authority
• RCRA Section 3005 states permits issued:
- "...shall contain such terms and conditions.,
necessary to protect human health and the
environment."
• Omnibus permitting
- Allows permit writers to require more stringent
controls on a case-by-case basis
OMNIBUS PERMITTING
Potential Areas of Omnibus Controls
• For Phase I standards: in some cases unacceptably
high risk remains
- Require leakless valves and sealless pumps
- Lower organic cutoff
- Increase control device performance (>95%
efficiency)
• Phase II standards may be considered on a site-specific
basis after proposal I
OMNIBUS PERMITTING -
IDENTIFICATION AND CONTROL OF SITE-SPECIFIC RISKS
Future Guidance Documents
• Procedures to identify high-risk TSDF
• Methods for providing additional emission controls:
- Work practice controls
- Technological controls
• Detailed example cases
• Checklists for permit writers to apply guidance
2-16
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CHECKLIST FOR PART B
INFORMATION REQUIREMENTS
Distributed at
U.S. Environmental Protection Agency
Workshop On
Air Emissions from Waste Mangement Facilities
2-17
-------
PART B IM=OR*TICN RSJJIHaeirS
LOCATION IN
PART 270
PART 264
SUBJECT REQUIPB^T
APPLICATION
COUNTS
270.14(b) (5)
264.1023
INSPECTION AND MONITORING
- Qsneral Inspection Schedule and Specific
ftaqu i reman ts
- Process Vents
284.1033 (e)(1) - Reference Uathod 22 (visible flare
missions) observation period = 2 hr.
(O
Monitor and inspect etch control device
(0(1) ~ Process vent flow r»te to control device
At leest onca every Sour
(f) (2) - Continuous monitoring:
(i) - thermal vapor incinerator
(tenperature; one sensor)
(1 i) - catalytic vapor incinerator
(tenperature; 2 seraors)
(iii) - flare (beat sensing device)
(iv) - boiler or process heater < 44 Mff
(tenperaUire)
(v) - boiler or process heater £ 44 WW
(panroter indicating good
combustion)
(vi) - condenser (organic concentration
or tenperature)
(vi i) - fixed bed system carbon adsorption
(organic concentration or other
indicator parameter for
predetermined regoneration cycle
time)
(O (3)
Inspect readings at least daily
-------
PART B IhFORUKTKM RSJLTO^e^rS (continued)
PART 2 TO
PART 264
SUBJECT RBBMIRB^fT
LOCATICN IN
APPLICATHM
CT»*eJTS
270.14 0) (5)
264.1G33 (h)(1)
270.14(b) (5)
270.24(c)
270.14(b) (5)
264.1033 (i)
264.10330)/
264.1035 (b)(3)
Nonregenerable carbon adsorption
system (organic concentration)
- monitor daily, or
- wool tor at interval no > 2CK of
carbon consurption time
Alternate control device monitoring
- monitoring frequency
Othor control devices:
- sarrpling end monitoring frequency
264.1033 (V) (1) - Closed vent system
- visual Inspections
(V) (2) - Closed vent system monitoring
- Date syrtan la subject to regulation
- Annually
- Other times per RA request
- Valves in light liquid service
264.1057
264.1067 (»)-(e)
-------
PART B IN^ORUVTTCN REpUr^VBITS (continued)
LOCATION IN
PART 270 PART 204 SUBJECT RS3MIFEWB/T APPLICATION COUNTS
270.1-4 (b) (5) 264.1063 - Compressors
(e)(1) - check failure sensor dal ly, or
- K»s audible alarm
- Inspect alarm monthly
2&4.1068 - Piwps and valves In heavy liquid
service, pressure relief devices
in light liquid or heevy liquid
NJ ser-»loe, flanges, and other
connectors
(a) - use visual, audible, olfactory, or
any other rethods to determine
potential leak
- If potential leak detected, von 1 tor
within 5 days using Method 21
270.14(b)(8) - procedures, structures, or equipment
used
(iv) - altlgate effects of equipment failure
and poeer outages
(v) - prevent personnel exposure to hazardous
werte
(vi) - prevent releases to the atmosphere
PROCESS veiTS
270.24(a) 264 .1033 (a)(2) -
Implementation schedule «hen closed vent
systen and control device can't be
installed on Subpart AA's effective
date (12/21/90)
-------
PART B IhFORVKTICN RSSMIRae^TS (continued)
PART 27<0
PART 264
SUBJECT RSJUIK&eJr
LOCATION IN
APPLICATHM
COU^fTS
270.24(b)
(1)
(2)
(3)
(c)
(<0
a)
(2)
(3)
(<)
(S)
Documentation of compliance with process
vwit standards in 264.1032:
- identity of all affected prooess vents
- annual throughput and operating Sours
of each affected unit
- estimated uncontrolled and control led
can i S3 ion rates per vent and for
faci I ity
location of eech affected unit in facility
- data supporting estimates of vent
emissions and emission reduction by
add-on control devices
- data used to determine if a process vent
Is subject to regulation
- for um of unspecified control device,
performance test plan
Documentation of cooplianoe of procoss
vent standards in 264.1033 including
list of all Information ref<
and sources U9ed to prepare
documntation
- records including dates of corrpI ianoe
tests for 1033 (V)
- basic control device design information
- o/o oartif i cat ion of representati veness
of operating parameters
- o/o staWnent certifying £ 96 *t. percent
control device efficiency
-------
PART B IhFORMATION RBBUIRJEMENTS (continued)
LOCATION IN
PART 270
PART 264
subject REqLHRae^r
APPLICATION
COfcfcBfTS
BQMIPVetT
270.2S (a) - For ooch piooa of equipment
(1) Identification nucber
- Respective hazardous wast* managsnant
unit identification
(2) - Location within the TSDF
(3) - Typo of equipment
(4) - X (wt) total organ I a In equipments'
wast* strena
(5) - Physical stat* of wast*
(6) - Method of compliance, *.fl.,
* monthly I oak do tact ion and repair, or
* equipped with dual Mechanical m I a
(b) 284.1033 (a)(2) - Implementation schadul* whan closed vant
system and control device can't be
install«d on Subpart SB's effective
da to (12/21/90)
(c). 284.1035 (b)(3) - For use of urwpoci f iod control device,
a peformence tost plan
(tf) 284.1062 A - Documentation of cooplianoe with
264.1069 equipment standards In 284.1062 k
264.1069
(•) 264.1060 - Documentation of conpllanoa with
equipment standard in 284.10G0
including
- list of all information references
and souroes used to prepare
docunentat i on
-------
PART B ]M=Ofl»VnGN RSQUBEXetTS (continued)
LOCATION IN
PART 270 PART 2W SUBJECT RSQUIRQOrr APPLICATION COAeflS
270.2S («) (2) - records Including d»tos of carpi Unco
tMU for 204.1033 (V)
(3) - basic control device design Information
(4) - o/o certification of representativeness
of operating parameters
(6) - o/o statement oerti fylng ^ 96 wt. percent
control dov1oe efficiency
-------
CASE STUDY
PERMIT WRITING/REVIEW
Presented at
U.S. Environmental Protection Agency
Workshop On
Air Emissions from Waste Mangement Facilities
2-24
-------
GENERAL INFORMATION
The following exercises will give permit writers an opportunity to
review and evaluate RCRA permit applications and information
requirements of the Phase I TSDF air standards (40 CFR 264 and 265,
Subparts AA and BB). It consists of a case study which covers both
process vents and equipment leaks. First, you will be provided with
general facility background information.
The case study will then be divided into five sections, as follows:
I. Description/Applicability Determinations (for both process vents
and equipment)
II. Mass Balance/Emissions Estimation (for one vent)
III. Supporting Data for Emission Rate Determinations (for process
vents)
IV. Control Device Design (for one vent)
V. Equipment Requirements
VI. Other Compliance Requirements
Each section within the case study contains:
• statement of purpose and what is expected in that section,
• fictitious Part B permit application information relevant to that section
or subject matter, and
• questions specific to the section and supporting information which
should be used as guidance in determining the completeness and
adequacy of the information provided.
2-25
-------
The scenarios used and information provided are simplified to
emphasize the key points of permitting process vents and equipment.
Information gaps and misinformation are placed intentionally in the Part
B information provided by the applicant to train permit writers in the
interpretation of the air standards and in the use of permit review/writing
tools available.
For each section within the case study you should first familiarize
yourself with the general contents. Each section will then be walked
through to determine its completeness. The Part B Checklist provided
during the permit writing lecture provides more detailed requirements
along with the regulation citation for each requirement.
Upon completion of the case study, answer packages to the
questions will be provided.
2-26
-------
FACILITY BACKGROUND INFORMATION
ABC Chemicals, Inc.
• A chemical production facility.
• Operates its own hazardous waste treatment, storage, and
disposal facility onsite.
• Also, recycles hazardous waste solvents and wastewaters
containing other organics for reuse onsite.
• Only those recycling units designated for waste solvents have
process vents venting emissions from wastes that exceed 10
ppmw.
• Wastewater recycled in the other units are below this
concentration limit.
• This Part B permit application case study addresses only the
regulated solvent recycling process vents.
• A general diagram of the facility and its operations are shown
in Figure 1.
• A general diagram of the facility and it's operations including
the installation of a control device on the distillation unit A.
2-27
-------
ABC CHEMICALS --PART B
Manufacturing/ Pi
/production^r6i
0
^5 ft aft -
(\ \ Pfimary I
I
J 4 <
waste
From
Production
(Product \
AccumulationJ
VomI J
' Sent C
Stte
Storooe
one
Feed
Tank .
fc.
Carbon
Canbter
Thln-Hlm
voporator
vatve
Sludge
To Land
Disposal
VaJve SfPvrrp
Barrier
mMp
Storage
Decanted
Water
One-Stage Regenerative Carbon Adsorption System
Condenser
I
Decanter
(Seperator)
r:n/#v>r> <4f+inrfv»r
(BegeneraSon)
Coolant
Regeneration
Motor
Filtering BJoW9f
and
CccBng
Coolant
Manufacturing/
Production Area
/ A - Manufacturing?
— — Production Aroa
P
O
- Veni and Id No.
Subject to Air Rule
¦ Pump and or VaJve Id No.
Subject to Air Rule
Figure 1. ABC Chemicals, Inc. Storage, Disposal,
and Recycling Facility Layout
Property Line
-------
/ /
o
ABC CHEMICALS --PART B
y Mafi ufacturing/production^i4a
Closed Vent System and Condenser
. ® |"\~^-\ K3sili> MsS
x Ix it i ! u y
(f| **>»>? I [\ ! ~ " !
Viewer! J/ I •
/J-\ f ! 9\m
J ^ CoolB/ii L —
y :
fieffrermtlof
Plan!
Product
^ ^ICCL'rTTUlflflOrj
V Vw+l J
One-StageRegenerative Carbon Adsorption Syst$m
Waste
Thh*fllm
swsoremi
S+ntOf!
Sit*
Production
V2
0-E "«"*
Siudgo
Tc l*Ad
5?373???
utspesaJ
(Rtgemrav&n)
Rvganeftitlon
V*f*
FtttrtftS ac*»"
Bttrri#
Fluid
Dftmlnt
Cooing
Coo 1*1 r
termf
{Sopemiof)
Y / A - Mtnuiactuffng/
1 ' ' 1 Production ArvB
- Vant and Id No.
Subject (o Air Rule
¦ Pump and or Valve Id No.
Subject to Air Rule
Figure 2. ABC Chemicals, Inc. Storage, Disposal,
and Recycling Facility Layout
Manufacturing/
Production Area
Property Line
-------
I. Description/Applicability Determinations
This section of the case study is concerned with the applicability
determination and inventory requirements for process vents and
equipment. The owner/operator (applicant) is required by the regulations
to make a determination of all process vents which are affected by the
Subpart AA air rules. For a process vent to be affected it must be:
• associated with a hazardous waste management unit (HWMU) at
a regulated hazardous waste treatment storage and disposal
facility,
• be associated with a hazardous waste distillation/separation unit
specified in the rule (e.g., distillation, thin film evaporation), and
• this unit must manage, come in contact with, or be associated
with hazardous waste streams with an organic content of greater
than 10 ppmw
Once the process vents which are affected by the air rules are
identified, the applicant must then fulfill inventory requirements. The
applicant is required to provide an inventory of all affected process vents.
This inventory must include:
• vent ID, including the hazardous waste management unit
(HWMU);
• location of each vent within the facility;
• RCRA waste code associated with that vent;
• organic content of the waste stream (ppmw)
• design throughput of that waste stream;
• emissions estimates (both uncontrolled and controlled) for each
process vent and total emissions from all affected process vents
at the facility; and
• type of emissions control devices used (if needed) or
determination that total facility emissions below emission rate
limit (3.0 Ib./hr and 3.1 tons/yr).
2-30
-------
For equipment to be affected by the rules it must be:
• associated with a hazardous waste management unit (HWMU)
at a regulated hazardous waste treatment storage and disposal
facility,
• manages, comes in contact with, or is associated with waste
streams with an organic content ot greater than 10% organics.
Once the equipment which are affected by the air rules are identified,
the applicant must then fulfill inventory requirements. The applicant is
required to provide an inventory of all affected equipment. This inventory
must include:
• equipment ID, equipment type, the hazardous waste management
unit (HWMU);
• location of each equipment within the facility;
• RCRA waste code associated with that equipment;
• organic content of the waste stream (%)
• design throughput of that waste stream;
• designate whether that equipment is in light or heavy liquid service.
In this section of the case study you will be asked to review an
applicant's submittal (covering both process vents 1 and 2 and equipment
associated with the thin film evaporation unit) to determine the adequacy
and correctness of the information provided.
2-31
-------
Following is the information provided to you, the permit writer, from the
applicant regarding the determination of applicability and inventory of
process vents regulated under 40 CFR 264, Subpart AA, and equipment
regulated under Subpart BB.
Vent Identification and Location
• Table 1 contains a list of process vents regulated under Subpart A A at the
ABC Chemicals, Inc., hazardous waste treatment, storage, and disposal
facility.
• The waste management units - Distillation Column A and Thin Film
Evaporator A - are considered recycling units and are, therefore, not
RCRA permitted. Thus, the waste information necessary to determine
compliance Is provided in this section, not in the Waste Analysis Plan of
this Part B permit application.
• Figure 2 identifies the location of each waste management unit and
regulated process vents and equipment.
• Table 2 provides information on waste throughput and the corresponding
organic emissions for process vents 1 and 2.
TABLE 1. Process Vents Regulated Under 40 CFR 264, Subpart AA
Annual Wtd.
RCRA Waste Avg. Organic
Vent ID HWMU Location (Fig. 1) Codes Managed Conc.(ppmw)
1 Distillation column A F005 (toluene) 800,000
2 Thin film evaporator A F002 (1,1,1- 700,000
trichloroethane)
2-32
-------
Ni
I
U)
TABLE 1 (Cont.
Equipment Regulated under 40 GFR 264, Subpart BB
Equip ID
Type
HWMU RCRA Waste Total Organics Heavy or Method of
Codes Managed (% by wght.) Light Liquid Compliance
P.1
Pump
Thin film F002 70 Light Dual mechanical seals with
evaporator barrier fluid system to
carbon adsorption canister
V.1
V.2
Valve
same same same same Monthly leak detection &
repair in compliance with
40 CFR 264.1057(a)
-------
TABLE 2. Process Vent Waste Throughput and Emissions Data
Vent ID
HWMU
Waste Maximum Uncontrolled
Throughput HWMU Operating Emissions
(ton/yr) Hours/year (Ib/hr) (ton/yr)
Controlled
Emissions Control
(Ib/hr) (ton/yr) Device
Distilla-
tion Column A
250
2,000
10
10
0.5
0.5
Condenser
Thin film
evaporator A
392
1,500
17.3 12.97
maximum
0.34 0.26
average
0.23 0.17
Carbon
Adsorber
-------
QUESTIONS
Part B Permit Case Study (Section I)
Please mark correct answer on this sheet for
each of the following questions.
Vent Description. Applicability
1. Does the application Include an Inventory of all
affected process vents and equipment?
1. Yes
2. No
2. Does this inventory Indude the Identity and
location of each affected process vent and
equipment?
1. Yes
2. No
3. For each unit with an affected process vent
and/or equipment, has the annual waste
throughput and operating hours been
Included?
1. Yes
2. No
4. Has there been a determination made that the
process vents and equipment listed In the
Inventory are subject to the regulation?
1. Yes
2. No
5. Has data/information been included to support
the determination?
6. Has the applicant estimated the uncontrolled
and controlled emission rate per affected
process vent?
1. Yes
2. No
7. Has the total controlled and uncontrolled
emission rate from all affected process vents
for the entire facility been estimated?
1. Yes
2. No
1. Yes
2. No
2-35
-------
II. EMISSION ESTIMATION/MASS BALANCE
PROCESS VENTS
This section provides a sample exercise in mass balance calculations
and is intended as a basic review in mass balance, to aid in visualizing
issues regarding emissions estimates, and to cover several issues specific
to the TSDF air rules regarding process vents.
To complete this exercise refer to Figure 3, which provides a schematic
for the distillation unit A and it's control devices. Based on five years of
operating records, the facility claims that annual waste throughput is 250
tons per year (tpy). Based on information provided in Table 1, the waste
stream consists of 80% toluene or 200 tpy throughput. For the purposes of
this mass balance exercise we will only focus on the (200 tpy) toluene.
The facility also claims to have recovered 4 tpy in still bottoms from
distillation unit A and 186 tpy of product from the primary condenser unit.
The facility has determined a need for the addition of an emissions control
device, and is proposing a secondary condenser. They have assumed a
control efficiency of 95% for the secondary condenser on past
performance, vent stream parameters, and engineering design.
2-36
-------
ABC CHEMICALS -PART B
tons/yr j
Uncontrolled 1
Emissions
Waste FOQS
(250 tons/yr)
< 200 tons/yr
Toluene *
196 tons/yr
Toluene
B&
SL
"•N
Primary
Condenser
Distillation
S8%
Still Bottoms
4 tons/yr
Toluene *
Coolant L
Closed Vent System and Condenser
Secondary
Condenser
Dehunidtficatlon
Distillate
R&dever
¦ i i (
T
Refigeraticn
Plant
r
Product
I Accumulation
\ Vessel
136 tons/yr
Toluene *
_ tons/yr
Controlled
Emissions
9S%
Recycled
Product
Storage
Tank
. tons/yr,
Toluene
Recovered
ft
Vent and Id, No
(Subject to Regulation)
1 = Efficency
* = Based on 5 years operating records. Inputs to mass balance
** = Based on engineering design calculations and vendor certification
Figure 3. Enlargement of Distillation Unit A and Closed Vent
System and Control Device (Secondary Condenser)
-------
QUESTIONS
Part B Permit Case Study (Section II)
Please mark conred answer on this sheet for
each of the following questions.
[Emission Estimation/Mass Balance
1. Using data given in Figure 2 calculate the
following emission rales (ER):
a- ^^primary condensed tODS/yr
^^socondary coodenser= tOnS/yr
b. Would the facility still be In compliance?
1. Yes
2. No
3. Insufficient Information provide to
determine.
If not, what Is requirement of the TSDF air rules
which has been violated?
2. Using the same information as given in
question 1 above, calculate the organlcs
(toluene) recovered (OR) from the secondary
condensers:
O^secondary condensef tonS/yr.
tf yes, tell why. What Is the maximum allowed
emissions (short or long term), or lowest
control efficiency which still allow the facility to
be in compliance? What additional information
Is needed?
3. If the applicant only predicted 80% control
efficiency for the secondary condenser:
a- ^ ^secondary condenser^ tOns/yr
Calculations:
2-38
-------
III. DATA SUPPORTING EMISSIONS ESTIMATE
This exercise will cover the review of the data and calculations that the
applicant has submitted to support the emissions estimate. Once affected
process vents have been identified the applicant is required to estimate the
emissions from each affected process vent and for the total from all
affected process vents at the facility. Once emissions estimates have been
made, the need for emission reductions and emissions control devices can
be assessed.
• Emissions control devices are required for affected process vents
unless total facilities emissions from all affected process vents are less
than 3.0 lbs./hr. and 3.1 tons/yr.
• If control devices are required, an overall control efficiency of 95% or
meeting the total facility emission rate limits is required. Therefore it is
important that emissions estimates be accurate and complete and meet
all the emission determination criteria in the rules.
2-39
J
-------
The method of estimating emissions is left to the discretion of the facility
owner/operator (applicant). Emissions may be estimated through:
• the use of engineering calculations, based on:
• operating records,
• design criteria, or
• engineering judgement, or
• from actual field test data, (from the specific site or from similar
operations at other sites).
In this case study, two types of data have been used to estimate
emissions.
• For process vent 1 (associated with distillation unit A) emissions were
calculated based on 5 years of operating records.
• For process vent 2 (associated with the thin film evaporation unit)
emissions were estimated based on field test data.
In this exercise you will be asked to review the data supporting the
emissions estimates presented in Table 2. Data representing the mass
balance previously covered in Figure 3 is provided for process vent 1
followed by a couple of questions. The process is then repeated for
process vent 2.
2-40
-------
The following information represents the applicant's submittal to support
the emissions estimates in Table 2. First data supporting the emissions
estimates for process vent #1 will be covered followed by a review of the
data for process vent #2.
A. Process Vent No. 1 (Distillation Unit)
To support the emission estimates listed above (demonstrating 95%
condenser efficiency), the following data provide a mass balance of
organic constituents in waste F005 entering the distillation unit and all
emission or accumulation points afterwards.
• The mass balance is based on five years of operating records.
• Figure 3 displays the distillation unit, its control device, and the mass
balance.
• The calculations in Table 3 below support the mass balance depicted in
Figure 3.
2-41
-------
ABC CHEMICALS --PART B
Closed Vent System and Condenser
Waste F005
(250 tons/yr)
¦ 200 tons/yr
Toluene *
10 tons/yr
Uncontrolled
Emissions
196 tons/yr
Toluene
(1
1
£L
Primary
Condenser
Distillation
| q- 98% |
Still Bottoms
¦ 4 tons/yr
Coolant
Secondary
Condenser
Dehurridllicauon
Distillate
Reciever
tons/yr
Rehgeration
Plant
Controlled
Emissions
%- 95%
Recycled
Product
Storage
Tank
Product
Accumulation
Vessel
186 tons/yr
Toluene *
9.5
tons/yr
Toluene
Recovered
Toluene *
S vent and id. No Figure 3. Enlargement of Distillation Unit A and Closed Vent
System and Control Device (Secondary Condenser)
^ (Subject to Regulation)
1 = Efficency
* = Based on 5 years operating records. Inputs to mass balance
** = Based on engineering design calculations and vendor certification
-------
ABC CHEMICALS --PART B
Closed Vent System and Condenser
K>
I
U>
Organic-Laden
Gas
Dehumidification
Refigeration
n ^ m
Secondary
>-
Condenser
j=r::-
Coolant
Return
Condensed
Organic
Coolant
Distillate
Reciever
To Recycled Product
Storage Tank
Figure 4. Enlargement of Condensation System
-------
Table 3: MASS BALANCE
Process Vent No. 1 (Distillation Unit)
RCRA waste code:
Maximum waste volume processed annually:
Total organic concentration of F005:
Total organic processed/year:
800,000 ppmw x 250 ton/yr
Estimated still removal efficiency:
98% x 200 ton/yr = 196 ton/yr
F005
(toluene)
250 ton *
800,000 ppmw
=200 ton/yr *
98%
=196 ton/yr
Total organics collected in still bottoms:
(2% of total organics processed)
Total volume of product recovered annually from primary
condenser:
(186 tons/yr -s-196 ton/yr x 100% = 95% recovery efficiency)
Estimated uncontrolled losses via vent emissions:
200-(4+ 186)= 10 ton/yr
(10 Ib/hr given 2,000 operating hr/yr)
Control device (condenser) efficiency:
Amount of condensed organics recovered from
control device (secondary condenser):
Estimated controlled vent emissions:
4 ton/yr *
186 ton/yr *
10 ton/yr
95%
9.5 ton/yr
0.5 ton/yr
=0.5 Ib/hr
*Based on direct measurements of recovered organics over 5 year operating record.
2-44
-------
TABLE 2. Process Vent Waste Throughput and Emissions Data
Vent ID
HWMU
Waste Maximum Uncontrolled
Throughput HWMU Operating Emissions
(ton/yrV Hours/year (Ib/hrl (ton/vr)
Controlled
Emissions Control
Ctb/hr> fton/vr) Device
Distilla-
tion Column A
250
2,000
10
10
0.5
0.5
Condenser
ro
I
Ln
Thin film
evaporator A
392
1,500
17.3 12.97
maximum
0.34 0.26
average
0.23 0.17
Carbon
Adsorber
-------
QUESTIONS
Part B Permit Case Study (Section III)
Please mark correct answer on Ihls sheet for
each of the following questions.
Process Vent 1:
Supporting Emissions Estimates
1. Does the application include data supporting
estimated emission rates of affected process
vents in distillation unit A and Its dosed vent
system?
1. Yes
2. No
5. Are these data In this portion of the application
(e.g., data used in calculating emission rates,
and emission reduction achieved) of sufficient
quality on which to base judgement?
1. Yes
2. No
If not, what additional data would you need to see
or request?
If yes, tell why.
2. Does the application include data supporting
the estimated emission reduction achieved?
1. Yes
2. No
3. Have the estimated emission rates and the
emission reduction achieved been calculated
correctly from a numerical sland point?
1. Yes
2. No
4. Does this dafa reflect the highest loading or
capacity level reasonably expected for both
hourly and annually?
1. Yes
2. No
3. Sufficient data not provided to make this
determination
2-46
-------
III. DATA SUPPORTING EMISSION ESTIMATES
(Cont...)
The following information represents the applicant's submittal to support
the emissions estimates in Table 2 for process vent No. 2.
B. Process Vent No. 2 (thin film evaporator)
To document the emission estimates for process vent 2 listed in
Table 2:
• A performance test has been undertaken.
• Field test data from the performance test are provided in
Table 4.
• Additional information on the waste stream and operating
conditions are provided below. ^
2-47
-------
TABLE 2. Process Vent Waste Throughput and Emissions Data
Vent ID
HWMU
Waste
(ton/yr)
Maximum
Uncontrolled
Throughput HWMU Operating Emissions
Hours/year (Ib/hr) (ton/yr)
Controlled
Emissions Control
flb/hr) (ton/yr) Device
Distilla-
tion Column A
250
2,000
10
10
0.5
0.5
Condenser
Thin film
evaporator A
392
1,500
17.3 12.97
maximum
0.34 0.26
average
0.23 0.17
Carbon
Adsorber
-------
TABLE 4. Source Testing Results for ABC Chemicals'
Thin Film Evaporator 1,1,1 -Trichloroethane
Emissions with Gas Phase, Fixed Bed Carbon Adsorber Applieda
Exhaust from
Thin Film Evaporator
Exhaust from
Carbon Adsorber
Removal
Date
mass flow rate Cone.
(Ib/hr) (ppmv)
max mass flow
(Ib/hr)
Cone,
(ppmv)
Efficiency
(%)
18-Aug-90
20.5
27,000
0.42
• 550
98.0
19-Aug-90
16.7
22,000
0.33
435
98.0
20-Aug-90
14.7
19,000
0.27
356
98.2
Ave.=
17.3
22,700
0.34
447
98.1
Total annual emissions = 0.34 Ib/hr x 1500 hr/vr = 0.26 tons/yr
2000 lbs/ton
a This table demonstrates the effectiveness of activated carbon as an adsorbent for 1,1,1 -trichloroethane in gaseous streams.
J
-------
QUESTIONS
Part B Permit Case Study (Section III)
Please mark correct answer on this sheet for
each of the following questions.
Process Vent 2:
5. Are these data in this portion of the application
(e.g., emission rate data) of sufficient quality
on which to base judgement?
1. Yes
buoDortlna Emissions Estimates
2. No
1. Does the application include data supporting
estimated control emission rates of affected
process vents in the thin-film evaporator and
closed vent system?
If not, what additional data would you need to see
or request?
1. Yes
2. No
If yes, tell why.
2. Does the application include data
the estimated emission reduction
supporting
achieved?
1. Yes
2. No
3. Have the estimated emission rates and the
emission reduction achieved been calculated
correctly from a numerical stand point?
1. Yes
2. No
5. Does this data reflect the highest loading or
capacity level reasonably expected tor both
hourly and annually?
1. Yes
2. No
3. Sufficient data not provided to make this
determination
2-50
-------
IV.CLOSED VENT SYSTEMS /
CONTROL DEVICE DESIGN
This section of the case study is concerned with the information
requirements associated with the design of closed vent systems and
control devices. If control devices are required because total facility
emissions exceed the emission rate limits of 3.0 Ib./hr or 3.1 tons/yr the
owner/operator (applicant) is required by the regulations to submit detailed
engineering design plans and details concerning closed vent systems and
control device design. Design information required for closed vent systems
and control devices includes:
• Flow rate and organic content for each equipment piece and
vent
• Detailed engineering description of closed-vent system and
control device
- Type
Manufacturer's name and model number
Dimensions
Capacity
Construction materials
• Basic engineering design and operating parameters
Control devices specifically outlined in the regulation include: thermal
destruction, carbon adsorption, and condensation. Should the owner/operator
choose to use a control device not specified in the regulation a performance
test plan is required to insure that emissions reduction achieved is acceptable.
A performance test plan must include:
• test procedures used
• operating conditions
• acceptable operating ranges of key process and control device
parameters during testing
2-51
-------
Review of Applicant's Submittal
for Closed-Vent System and Control Device Design
The closed-vent system and control device for process vent #2 (carbon
adsorber) will be used to illustrate the design information requirements. You
will be asked to review the information submitted by the applicant to assess
it's adequacy and to determine what additional information, if any are
required.
The following constitutes the applicant's submittal to satisfy the
requirements associated with closed-vent system and control device design
information.
Process Vent #2
• Figures 5 and 6 are diagrams for the closed vent system and control
device installed on Process Vent 2 (carbon adsorber).
• The adsorber was manufactured by Sorption Systems, Inc.
• Design specifications and product performance data were
developed by Sorption Systems for this vent stream and are
provided in the following pages.
2-52
-------
ABC CHEMICALS -- PART B
Waste
TfurbHtm
vapcntor
Production
One-Stage Regenerative Carbon Adsorption System
S tor ego
ana
r«o' Tank
V&jve
Sludge
To Land
Condenser
DisposeI
Coolant
Steam In
y if Pump
•*
Motor
Condenser
ES
flfterftig Blower
and
Coaling
Barrier
Coo/snt
Degassing
Storage
Tank
Carbon
Decanter
(Seperator)
Decanted
Canister
Water
Decanter
(Seperator)
ft
OJ Vent and Id. No
(Subject to Regulation)
Pump and or Valve Id.No.
Subject to Air Rule
Figure 5. Enlargement of Thin-film Evaporator System Vented
To a Carbon Adsorption System
-------
ABC CHEMICALS -- PART B
One-Stage.Regenerative Carbon Adsorption System
Vapor Exhaust
From Thin-Film
Evaporator
Filtering
and
Cooling
Carbon Adsorber
Steam
for
Regeneration
tVoo*o-0
5°
Motor
Blower
¦c4>-
Stegm,
(Regeneration)
[p?
Condenser
&
Coolant
Decanter
(Seperator)
ft
Vent and Id. No
(Subject to Regulation)
Figure 6. Enlargement of Thin-film Evaporator System Vented
To a Carbon Adsorption System
-------
OPERATING PARAMETERS
Process Vent No. 2 (Thin film evaporator)
Vent stream composition:
1,1,1 -trichloroethane, water
Constituent concentrations: 1,1,1 trichloroethane
(vent gas)
Flow rate:
Relative humidity:
Temperature:
Design exhaust vent stream organic compound
concentration level (carbon bed exhaust vent)
Capacity of carbon bed (per 1,000 lb carbon):
No. of carbon beds;
Capacity of carbon beds:
Type of activated carbon used for carbon beds:
Working capacity of carbon beds
(per 1,000 lb carbon):
Design total steam flow over the period of
each complete carbon bed regeneration cycle:
=8.5 x 10"3 lb/ft3
= 17.3 Ib/hr
= 2.28% by volume
«= 22,800 ppmv
34 scfm
40%
21 °C (70 °F)
(max)-
(avg.)-
= 1.67 x 10"4 lb/ft3
= 0.34 Ib/hr
= 0.045%
= 450 ppmv
= 1.12 x 10"4 lb/ft3
= 0.23 Ib/hr
= 0.03%
= 300 ppmv
= 150 lb organics
= 2,000 lb
Sorption Systems
Type 001
= 70 lb
6,000 lb steam
2-55
-------
OPERATING PARAMTERS
Process Vent No. 2 (Thin film evaporator)
Duration of carbon bed -
. steaming (heating and desorbing),
. cooling/drying,
. and standby cycles
Total
Design carbon bed temperature after regeneration: ambient
Design carbon bed regeneration time: = 8 hours total
Design service life of carbon: = 2 years
= 4 hours
= 2 hours
« 2 hours
= 8 hours
2-56
-------
SORPTION SYSTEMS, INC.
Anytown, USA
This statement documents the design of a fixed-bed carbon adsorber to control the
emissions from a condenser vent of a gas stream associated with a thin film
evaporator (TFE) unit. The main pollutant to be collected/recovered is 1,1,1-
trichioroethane (1,1,1-TCE). The condenser vent has a total gas flow rate of
approximately 34 scfm and emits 17.3 Ib/hr of 1,1,1-TCE (equal to 13 tons per year)
based on 1,500 hours of operation per year. At this flow, the 1,1,1-TCE
concentration exceeds the lower explosive limit (LEL). Typical safe practice is to
operate at or below 25% of LEL, which would require dilution air to increase the flow
rate to at least an acceptable level/concentration.
As the TFE at this facility is operated one shift per day, five days per week, there is
ampie time during the second and third shifts to regenerate the carbon bed while the
TFE is not operating, and therefore, only one carbon bed is required for this
application. The equilibrium capacity (we) of carbon for 1,1,1-TCE is 0.15 lb 1,1,1-
TCE/lb carbon. The working capacity (wc) is typically assumed to be 0.5we (EPA
Cost Control Manual, 4th edition). Using a working capacity of wc = 0.07 lb/lb of
carbon and an 8-hour adsorption cycle, the amount of carbon required is:
(17.3 lb orq./hr) x (8 hr) =1 j980 ,b carbon
(0.07 lb org./lb carbon)
According to the standard carbon adsorption design references (e.g., EPA Control Cost
Manual, 4th ed.), a typical design velocity for the gas stream in a carbon bed is 60 ft/min.
To achieve a reasonable bed configuration and to ensure safe operating range, the process
vent stream will be diluted with ambient air. The total flow will be increased to 3,400 scfm.
The stream temperature will be maintained at 70 °F. The dimensions of the column at a
3,400 scfm total flow rate are 12.75 ft long by 4.4 ft in diameter.
The manufacturer's experience has shown carbon life to be between two and five years
and that three lb of steam are required to regenerate 1 lb of carbon. These values are
within the ranges cited in various EPA documents (e.g., EPA Control Cost Manual, Control
of Gaseous Emissions (APTI Course 415). The owner/operator has been informed by
Sorption Systems that the use service life of this particular activated carbon is two years.
The carbon type is Sorption Systems Type 001. Details regarding the carbon bed design
parameters are provided in the attached table.
2-57
-------
SORPTION SYSTEMS -- TYPE 001
CARBON BED DESIGN PARAMETERS:
Number of adsorbing vessels: 1
Number of desorbing vessels: 0
Work cap. carbon, lb VOC/lb carb: 0.07
Adsorption cycle time: 8
Lower explosive limit, ppmv: 10000
VO molecular weight: 133.0
VO removed (995% efficiency), MG/yr: 11.8
Total Organic Flow Rate, Mg/yr: 11.8
Calculated Values:
Gas flow rate, cu ft/min: 3400.0
Weight of carbon, lbs: 1982.40
Carbon bed length, ft: 12.75
Carbon bed diameter, ft: 4.44
Carbon bed volume, cu ft: 197.63
Mass of VO to be adsorbed, Ib/hr: 17.346
(Based on 5% percent of the waste being organic and 6% of that organic being the uncontrolled
emissions from 116500 Mg/yr. Air flow @25% LEL= 336.3 scfm
VARIABLE NAMES
Volumetric gas flow rate, cu ft/min: . , 3400.00
Superficial bed velocity, ft/min: 60
Carbon bed diameter, ft: 4.44
Carbon bed volume, cu ft: 197.63
•
Number of vessels: 1
Weight of carbon, lbs: 1982
Price of carbon, $/lb: 1.8
Price of steam, $/thous lbs: 3.26
Price of cooling water, $/thous gal: 0.15
Price of electricity, $/hr: 0.0463
Operating labor wage rate, $/hr: 12
Maintenance labor wage rate, $/hr: 13.2
Operating hours, hrs/yr: 1500
Number of shifts/day: 1
Number of operating days/yr: 250
Service life for carbon, yrs: 2
Service life for adsorber systems, yrs: 10
Interest rate: 0.1
Site Preparation: 500
2-58
-------
QUESTIONS
Part B Permit Case Study (Section IV)
Please mark conrect answer on this sheet for
each of the following sections.
VI. Type of adsorption bed?
a. Yes
b. No
Process Vent 2:
I Control Device Design
VII. Desorption time?
a Yes
b. No
1. Does the application include a detailed
design and engineering description of the
thin-film evaporator dosed vent system and
control devices?
VII. Regeneration drying and cooling time?
a. Yes
b. No
1. Yes
2. No
3.
List the types of control devices used at this
facility:
2. Does this detailed engineering and design
description Include the following:
1.
2.
1. Type of control device?
a. Yes
b. No
4.
Are there any control devices used at this
facility not specified in the regulation?
II. Manufacturer's name and control device
model number?
a. Yes
b. No
III. Dimensions of control device?
a. Yes
b. No
5.
1. Yes
2. No
Assume the answer to question 4 Is "yes*.
Which of the following Hems should be
included in the performance test?
1. Test procedure used
2. Operating conditions for the test
IV. Capacity?
a. Yes
b. No
3. Acceptable operating ranges of key process
and control device parameters during testing
4. None of the above
V. Construction materials?
a. Yes
b. No
5. All of the above
2-59
-------
V. Equipment Requirements
This section of the case study is concerned with the specific
requirements of Subpart BB. Once equipment has been identified as
affected by the TSDF air emission standards there are several
requirements which must be met. First, an inventory of all affected
equipment must be made. This inventory should include designation of the
type of service for each piece of equipment which depends on the
characteristics of the waste stream (i.e., gas, light liquid, and heavy liquid
service). This was covered in the first exercise of the case study. Specific
inspection and monitoring requirements are a function of the type service
for that equipment.
For equipment to be in light liquid service the organic waste stream
must contain one or more organic constituents with a vapor pressure of
greater than 0.3 kilopascals (2.26 mm Hg) at 20°C, and the total
concentration of these constituent(s) must be at least 20% by weight.
Specific inspection and monitoring requirements depend on the type
of equipment. Examples of inspection and monitoring requirements are
shown in the table below.
Equipment
Light liquid or
gas vapor valves
Light liquid pumps
Compressors
Heavy liquid pumps
or valves
Monitoring
Monthly (Method 21)
Monthly (Method 21)
Not specified
Inspection
Not specified
Weekly (visual)
Daily (failure sensor)
Monthly (audible alarm)
Pressure-relief
devices Within 5 days of Use visual, audible,
finding potential olfactory, or other method
Flanges leak using Method 21 (frequency not specified)
Other connnectors
2-60
-------
The applicant has several options to meet the equipment leak
requirements. For example, for equipment in light liquid service
compliance can be achieved through conformance with emission limits,
equipment specifications, or work practices. Compliance can occur
through the demonstration of no detectable emissions are likely to occur in
the life of the equipment (e.g., use of sealess pumps), through the
specification of the use of dual seals and closed vent systems, or through
work practices of monthly monitoring (Method 21) and weekly inspection.
If the applicant chooses either no detectable emissions or selects the
use of dual seals and closed vent systems monitoring requirements are
minimized. Should the applicant choose conformance with emission limits,
once no detectable emissions have been demonstrated weekly inspection
and monthly monitoring are not required. If the equipment specification
option using a dual mechanical seal system is chosen, monthly monitoring
is not required. Weekly inspections are still required.
2-61
-------
Table 1 gives an inventory of the affected equipment at the facility.
This has been greatly simplified for the purposes of this case study. In
actuality it is likely there would be numerous equipment which would be
affected by the rules. The applicant has also submitted the following to
demonstrate compliance with the equipment leak standards dealing with
pumps.
Documentation of Compliance
with 40 CFR 264.1052 and 264.1059
-- 264.1052 (Pump standard)
This pump is in light liquid service. It is equipped with a dual mechanical seal
system that includes a barrier fluid of water. The pump is equipped with a barrier
fluid degassing reservoir that is connected by a closed vent system to a carbon
adsorber canister that complies with 264.1060. (See below). Since the pump is
equipped with a closed vent system to the carbon adsorber the system is capable of
capturing and transporting any leakage from the seal(s) to the carbon adsorber.
Therefore, this pump's seal system and barrier fluid system will not be inspected as
required otherwise for pumps.
2-62
-------
TABLE 1 : Equipment Regulated under 40 CFR 264, Subpart BB
ro
i
u»
Equip ID Type
¦ P.i-
HWMU RCRA Waste Total Organics Heavy or Method of
Codes Managed (%bywght.) Light Liquid Compliance
Thin film F002
evaporator
70
Light Dual mechanical seals with
barrier fluid system to
carbon adsorption canister
V.1
V.2
Valve
same
same
same same Monthly leak detection &
repair in compliance with
40 CFR 264.1057(a)
-------
QUESTIONS
Part B Permit Case Study (Section V)
Please mark correct answer on this sheet for
each of the following questions.
Equipment Requirements/Pumps
1. Does the applicants choice of venting
emissions from a pump with dual mechanical
seals to a carbon canister meet the
requirements of Subpart B8?
1. Yes
2. No
2. The applicants proposes not to inspect or
monitor the pump. Is this in compliance with
Subpart BB?
1. Yes
2. No
Why?
3. The applicant chose equipment specification
(the use of dual mechanical seal system
pumps vented to a control device) to meet
compliance requirements. What other
options were available?
a)_
b)_
4. If the applicant had chosen work practices as a
means of compliance, what would be the
requirements for:
a) inspection?
b) monitoring?
5. Is there anything missjng from the applicants
submittal to demonstrate compliance?
1. Yes
2. No
If yes, what?.
If no. is there sufficient detail In what has been
submitted?
2-64
-------
VI. OTHER COMPLIANCE REQUIREMENTS /
DOCUMENTATION
In addition to the specific data, design, and engineering requirements
associated with process vents, equipment and their closed vent systems
and control devices there are several administrative requirements. This
section of the case study is concerned with the additional information
required in Part B applications.
Additional information which is required in a Part B includes:
• List of all information sources supporting documentation (e.g., of
emission estimates, control device performance and design)
• Dates of compliance tests and other pertinent data
• Owner/operator certification of representativeness of operating
parameters
• Owner/operator statement certifying 95% control device efficiency
The following pages constitute the applicant's submittal to satisfy the
other additional administrative requirements not previously covered in
previous exercises. You will be asked to review this material to determine
if all information has been included.
2-65
-------
LIST OF INFORMATION REFERENCES AND SOURCES
USED TO PREPARE DOCUMENTATION
Vent No. 2 (carbon adsorber)
Sorption Systems, Inc., Manufacturers Brochures
Control Cost Manual, 4th Ed., by U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards, Economics
Analysis Branch
2-66
-------
RECORDS PERTAINING TO COMPLIANCE WITH 40 CFR
264.1033(k)(2)
Appendix A contains closed vent system monitoring records
demonstrating compliance with the 40 CFR 264.1033(k)(1) emission limit
of less than 500 ppm. These records reflect both visual inspections and
use of EPA Method 21 for both the condenser and carbon adsorber
closed vent systems. Records show monitoring was conducted initially,
when the facility became subject to the process vent air standards, and
annually thereafter, The EPA Regional Administrator did not request any
additional monitoring of the closed vent systems during interim status.
OWNER/OPERATOR CERTIFICATION OF
REPRESENTATIVENESS OF OPERATING PARAMETERS
AND GREATER THAN OR EQUAL TO
95 WEIGHT PERCENT CONTROL DEVICE
I certify under penalty of law that I have personally examined and am
familiar with the information submitted in this document and all
attachments and that, based on my inquiry of those individuals
immediately responsible for obtaining the information, I believe that the
operating parameters selected for each process vent and control device
are representative. I also certify that each control device attains greater
than or equal to 95 weight percent efficiency under these operating
parameters based on the design analysis provided by the vendors
specified in this section. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and
imprisonment.
Signed
Title
Date
2-67
-------
APPENDIX A
RECORDS PERTAINING TO COMPLIANCE WITH 40 CFR 264.1003(k)(2)
INITIAL MONITORING OF CARBON ADSORBER CLOSED VENT SYSTEM:
Monitoring Run No. I ~ I Date 8 - 3 I -
Time % O. nr\ . » |1 y.iv^ ,
1. Facility Name and Address A8C
2. Purpose of Monitoring
To UO?VK 2.tS. (j) (.Is)
3. a. Monitoring Location £vfcf.,fcW
b. Description cloS(A
Tfe 4© V Ak"f C±r\bK AAscrpfJe^
4. a. Number of Method 21 Readings Taken: £*,dU ductwork connCcK®
(o
b. Duration of Readings:
4$ 5eco*vAi
5. Visual Inspection Results
)0<> viatic.!
6. Followup actions taken:
0^*, «Al ^ ^ Cc^U<^c<
Signature of Sampling Person:
2-68
-------
ANNUAL MONITORING OF CARBON ADSORBER CLOSED VENT SYSTEM:
Monitoring Run No. \-1* Date ^ >
Time to pr**. - .
1. Facility Name and Address ABC CWe «vv Ca\s
/Vmtri cc»+, Ci-kj t
2. Purpose of Monitoring
"TT CPU. 2SS CjK«>
3. a. Monitoring Location .
b. Description c\*$*k
V&uvA 4> « aW+ Au^vwkHc,
4. a. Number of Method 21 Readings Taken: 60 nntc^6^ *
c,
b. Duration of Readings:
it q co t-J. i
5. Visual Inspection Results
A, Vv fo#_l C'uiA'tvvC* |ce*_ic.€~e^
6. Followup actions taken:
P\fc(Ajt,
-------
QUESTIONS
Part B Permit Case Study (Section VI)
Please mark correct answer on this sheet for
each of the following questions.
6. Does the application include an owner/operator
statement certifying 95% control device
efficiency included In the application?
1. Yes
2. No
Other Compliance Requirements
1. Were compliance tests conducted?
1. Yes
2. No
2. If compliance tests were conducted, were the
dates of the compliance tests Included?
1. Yes
2. No
3. Do the compliance tests contain other
pertinent records?
1. Yes
2. No
4. Does the application include a list of all
Information sources supporting
documentation of compliance with vent
standards?
1. Yes
2. No
5. Is the owner/operator certification of
representiveness of operating parameters
included in the application?
1. Yes
2. No
2-70
-------
Compliance Inspections
General Aspects
Inspection Procedures
Monitoring Procedures
Follow-up Procedures
Violations
-------
Compliance Inspections
Learning Objectives
¦ Understand elements and types of compliance inspections
¦ Understand pre-inspeciion, field inspection, and follow-up procedures to insure
thorough inspections
¦ Understand use of checklists in carrying out inspections
¦ Understand monitoring procedures for equipment leaks (Method 21)
¦ Understand general aspects of performance standards for control devices for process
vents
¦ Understand types of violations
General Aspects Of Inspection
¦ Types of inspection
• Initial
• Follow-up
¦ Scheduling of inspections
¦ Inspection checklists
¦ Key inspection elements
Inspection Checklists
¦ General aspects
• Facility permit status
• Identification of applicable units
• Identification of equipment and process vents
¦ Worksheet for each type of equipment or control device
• Performance standards
• Records
• Physical Inspection
¦ Glossary
3-2
-------
Key Inspection Elements
¦ LDAR (leak detection and repair)
¦ Facility operating log/record
¦ Types of fluid covered
¦ Types of equipment and control devices
¦ Sampling procedures and methods
¦ Applicable units and process vents
¦ Dales for compliance
LDAR
Definition of leak
•>10,000 ppm
• Visual
• No detectable emission (NDE) > 500 ppm above background
¦ Sensor exceeds criteria
Repair
• 5/15 days
• Immediately/5 days
• Immediately/24 hours
Delay of repair
• General
• Pumps
• Valves
Facility Operating Log/Record
¦ Determination of applicable units
¦ Identification and designation of units/equipment
B Monitoring and prior inspection results
II Leak detection and repair
3-3
-------
Types of Fluids Covered
¦ Gas/vapor
¦ Light liquid
¦ Heavy liquid
l(
i-ntil'ication Of Equipment Covered By Rule
¦
liquipnicnt
• I'uinps
- General
- Dual mechanical
- NDU (sealless)
- Closed vent/control device
• Compressors
- General
- NDE (sealless)
- Closed vent/control device
- General
- Leakless
- Unsafe to monitor
- Difficult to monitor
Alicr allowable %
- Alicr skip period LDRP
• Closed -Vent/Control Devices
General
Vjpor recovery
- Condensor
- Regeneration adsorber
- Non-regeneration adsorber
Identification Of Equipment Covered By Rule (Cont'd.)
¦ Equipment
• Closcd-Vcnl/Conlrol Devices (Cont'd.)
- Enclosed combustion
- Process heater
- Boiler
- Catalytic vapor incinerator
- Thermal vapor incinerator
• Flares
- Air-assisted
- Steam-assisted
- Non-assisted
3-4
-------
Sampling Procedures and Methods
¦ Process Vent Rule
• Waste stream organic composition: 10 ppmw
- Knowledge or test
• Hourly Process Vent Organic Emission Rate
- Knowledge or test
• Annual Process Vent Organic Emission Rate
- From hourly rate
Sampling Procedures and Methods
¦ Equipment Leaks
• Leaks
- 10,000 or NDE
' - Method 21
• Waste Stream Organic Concentration: 10% wt.
- Knowledge or test
Applicable Units for Process Vents
¦ Applicable Units
• HW Management units using
- Distillation
- Fractionation
-Thin-film evaporation
- Solvent extractor
- Air stripping
- Steam stripping
• Managing wastes with 10 ppmw or greater
¦ Exempt Units
• "90-day" tanks
• Pari of "totally enclosed treatment facility"
• Pan of closed-loop reclamation unit
• Part of wastewater or elementary neutralization unit regulated under CWA
• Units of product separation (while waste is still in the product separation unit)
3-5
-------
Applicable Units For Process Vents
¦ Passage of fluids into atmosphere due to mechanical or process-related means
Vent (2)
Veni(1)
Vapors
Condenser
Solvenifeed
Storage
tank
Rallinate
lank and
leed tank
Distillate
receiver
Column
Solvent
extractor
Vent(i)
vent(2)
Vent (1)
Oveihead
product
Feed
Storage
tank
Separation
device
. Bottoms product
(disposal, lecycle. tuel)
Heat
Storage
tank
tank
i~i feed
lark
Wasle in
Pump
Impure
exlract
Schematic diagram of solvent extraction system
Note:
(1) Veni is not sjbject to the retirements o! Subpart AA because the passage ol liquids, gases, or lumes into the atmosphere is
not caused by mechanical or process-related means.
(2) Vent is subject to the requirements ol Subpart AA.
(3) Vent is sub;ect to the requirements ot Subpart AA only il uncondensed overhead vapors trom the batch still operation are
veiled through the tank
-------
Dates
¦ Dec. 21, 1990 or the facility effective dale
• Initial waste stream organic concentration determination
• Initial process vent organic emission rate determination
• Identify and designate all equipment process vents in log
• Have installation schedule written for closed-vent and control devices
• Complete initial sampling and monitoring
¦ June 21, 1992 or 18 months after effective date
• All closed-vent systems and control devices must be installed
Pre-Inspection Procedures
¦ Review permit and its status
¦ Information in permits/applications
• Units
• Waste streams - types and test methods
• Equipment identification numbers, designation
¦ Previous inspection reports
• Equipment with prior problems
• Facility schematic and flow chart diagrams
• From CAA benzene rule
¦ Discussions
• With permit writers
• With other inspectors
• With CAA benzene rule inspectors
Pre-Inspection Procedures (Cont'd.)
¦ Review reports by facility
• Semi-annual report
- Equipment l.D. number for equipment not repaired, 5/15
- Dates of unit shutdowns
- Dates with operating exceedances
• Noiification to Regional Administrator to use alternative standards for valves
3-7
-------
l7ield Inspection
Facility Interview
¦ Interview with facility representatives
¦ Operating history of unils/equipment
• Changes to process or waste streams
• Schemaiic/flow diagram with equipment l.D. numbers
• Implementation schedule/plan for control device installation before 12/21/90 or
applicable date
• Equipment identified/designated
¦ lniiial and annual waste stream analyses in unit lines
Field Inspection (Cont'd.)
Facility Interview (cont'd)
¦ Verify checklist entries for changes
¦ Review of facility test results
• Performance tests for emission rates
• Process vent tests for 10 ppmv
• Equipment tests for 10%
¦ Light vj heavy, gas/vapor determinations
Field Inspection (Cont'd.)
Walk-Through and Monitoring
¦ Inspect each piece of equipment
• Look for indication ofleatc such as visual, smell, alarm or sensor
• Check dateof tag for repair (5/15)
• Check recording devices for control devices
¦ Monitoring
• Use Method 21 for NDE and 10,000 ppm leaking levels
• May want to have facility do their monthly monitoring a! this time
¦ Note any equipment on line not identified in facility records, inconsistencies, or
operational variances
3-8
-------
Field Inspection (Cont'd.)
Record Review at Facility
¦ Review facility operating record
• Weekly/monthly inspection records
• Monthly alarm test records
• Monllily Method 21 monitoring dates and resulls
¦ LDAR procedure results
¦ Compliance with Phase I Rule
Field Inspection (Cont'd.)
Close-Oul Meeting
¦ Address concerns raised during inspection, as appropriate
¦ Complete checklists
¦ Miscellaneous matters
Follow-Up Procedures
¦ Inspection report
¦ Enforcement action if violations are found or determined
3-9
-------
identification and Documentation of Violations
¦ Types of violations - ten categories of violations
• Equipment
• Permits
• Control devices
• Emission levels
• Analysis methods/performance tests
• Reporting
• Recordkeeping
• Repair/maintenance
• Monitoring
• Inspections
¦ Use of checklist
- There are over 100 separate violations in Paris 264/265 AA and BB
Types Of Violations
¦ Waste analysis and emission rale determination
• Initially, annual, correctly, test plans
¦ Equipment and closed vent/control devices
• Identified, designated, marked, design criteria and parameters for operation
¦ Closed vent/conirol devices
• Installed or implementation plan
¦ Inspection
• Visually, by sensor or alarm
¦ Monitoring
• Emissions
- within 5 days of leak, monthly, annually and initially
• Parameter for process vents and control devices
- temperature
- flow indicator once an hour
- other parameter as specified
Types Of Violations (cont'd)
¦ Repair
¦ Equipment
- 5/15 or delay
- 'agged
• Process vents
- immediately and complete by 15 days
¦ Everything pui in the record
¦ Reports
• Semi-annual reports if needed
• RA not notified about alternative value managemet.t
3-10
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Checklist
Process Vents Applications
Part 264/265 AA
General
1. Does the facility need authorization under RCRA Section 3005?
la. Facility status, interim or final?
lb. Effective date for the facility: Dec. 21,1990 or permit
renegotiation.
lc. Have these rules been incorporated into Part B application
submittal?
2. Hazardous waste management units using:
permitted unit § or recycling unit # waste stream # vent if
separation
distillation
fractionation
thin-film evaporation
solvent extraction
air stripping
steam stripping
waste streams
2a. Are any of the units RCRA exempt units?
Waste Streams
3. Which of the waste streams, contain 10 ppmw or greater organics
concentration?
3a. Method of determination? knowledge, 9060, or 8240
3b. Date of initial determination
3c. Dates of other analysis? annually, change to stream
3d. Annual Average Concentration calculated correctly?
3-11
-------
Checklist
Process Vents Applications
Part 264/265 AA
3e. Analysis had 4 grab samples, collected at entry to separation
unit.
3f. Which of the process vents are considered?
Performance Standards
4. Hourly process vent organic emission rate => 3 lb/hr
4a. Method of determination; knowledge, Method 2, 13
4b. If Method 2 and 18, was test plan prepared and on record?
4c. Has owner/operator signed statement that test conditions portray
worst case actual operating conditions?
4d. Dates of tests or calculations: initially, annually or at change?
4e. Check calculations
data needed: flow rate, org. conc., avg mole wt.
4f. Is yearly facility organic emission rate => 3 tons/yr?
4g. Check calculations
data needed: hourly rate, no. of operating hours
5. Is emission reduction required?
5a. Which method will they use to comply?
Install control devices to reduce emissions below 3 lb/hr and
3.1 tons/yr.
Implement process changes or hours to meet 3 lb/hr and 3.1 ton/yr.
Install control device to reduce emissions by 95%.
5b. For each process vent covered, identify closed-vent, and control
device #.
(Use individual control device worksheets to continue inspection)
5c. For facilities that don't have control devices installed, do they
have an installation plan?
5d. I9 their projected date for installation and compliance 18 months
after the facility effective date?
3-12
-------
Checklist
Process Vents Applications
Part 264/265 AA
Identification of Facility Vents and Control Devices
Vent # Control Device CD # Unit #
Condenser
Adsorber (Regen)
Adsorber (Monreg)
Process Heater
Boiler
Catalytic Vapor Incinerator
Thermal Vapor Incinerator
Air Assisted Flare
Steam Assisted Flare
Nonassisted Flare
3-13
-------
Condenser
Standard:
=> 95 wt% efficiency or
=> emission limits of 3 lb/hr and 3.1 tons/yr
Monitoring: A and either B or C
A. flow indicator
records hourly
installation point
daily inspection
B. [organic compd] in condenser exhaust vent stream
continuously record
daily inspection
C. temperature monitoring device
continuously record
two locations:
exhaust vent stream from condenser
coolent fluid exiting the condenser
accuracy:
+/- 1% of Temp being monitored or
.5 degrees C {whichever is greater
inspect daily
Repair:
immediately upon daily inspection
Recordkeeping: A, B, and C
A. Emissions reductions from condenser i or ii
i. Based on tests
test plan
design flow rate
design organic content
ranges of other parameters
insure using highest capacity loading
manufactures name, model number
type of control device
dimensions of control device
capacity
construction materials
description of sampling and
locations
equipment to be used
frequency
analytical procedures
all performance test results
ii. Based on engineering calculations
list of all reference and sources
dates of closed-vent monitoring
design analysis, specs, drawings,
(vendor info ok)
condenser parameters
vent stream composition
constituent concentration
flow rate
relative humidity
temperature
design outlet (organic compd] level
monitoring
for analysis
piping
3-14
-------
design average T of cond. exhaust
vent stream
design avg. T of coolent fluid at
inlet, outlet
owner/operator statements
realistic paramters used for high load,
capacity
device designed to operate at 95%
removal eff.
unless it reduces [organic]
< 10 pptnw or unless it mets
3 lb/hr and 3.1 tons/yr
B. General Device Information
description and date of any modifications to CV/CD
id operating parameters
describe monitoring device
diagram of monitor sensor location
dates on device start up and shutdown
C. Exceedances:
if monitoring [organic] in exhaust:
when [organic] > 20% above design outlet [organic]
if monitoring T:
either T exhaust > 6 deg above design avg exhaust T
or T coolent out > 6 deg above design avg coolent T
cause of exceedance
measures taken to correct it
Closed-vent system
standard: No Detectable Emissions and no visual emissions
monitor: At facility effective date
Annually
RA requested times
repair: 5/15
3-15
-------
Catalytic Vapor Incinerator
Standard:
=> 95 wt% efficiency or
(TOC] = 20 ppmw, baaed ori summation of compds, dry basis, 3%
02 or
RTm = .5 seconds at => 750 deg C
Monitoring: A and B
A. flow indicator
records hourly
installation point
daily inspection
B. temperature monitoring device
continuously record
two locations:
exhaust vent stream from condenser
coolent fluid exiting the condenser
accuracy:
+/- 1% of Temp being monitored or
.5 degrees C (whichever is greater
inspect daily
Repair:
immediately upon daily inspection
Recordkeeping: A, B, and C
A. Emissions reductions from condenser i or ii
i. Based on tests
test plan
design flow rate
design organic content
ranges of other parameters
insure using highest capacity loading
manufactures name, model number
type of control device
dimensions of control device
capacity
construction materials
description of sampling and monitoring
locations
equipment to be used
frequency
analytical procedures for analysis
all performance test results
ii. Based on engineering calculations
list of all reference and sources
dates of closed-vent monitoring
design analysis, specs, drawings,
piping (vendor info ok)
3e. Analysis had 4 grab samples, collected at entry
to separation unit.
3f. Which of the process vents are considered?
adsorber parameters
vent stream composition
constituent concentration
flow rate
design min. T across cat. bed inlet, outlet
design avg. T across cat. bed inlet, outlet
owner/operator statements
3-16
-------
realistic paramters used for high load,
capacity
device deaigned to operate at 95%
removal eff.
unless it reduces [organic]
< 10 ppmw or unless it mets 3 lb/hr
and 3.1 tons/yr
B. General Device Information
description and date of any modifications to CV/CD
id operating parameters
describe monitoring device
diagram of monitor sensor location
dates on device start up and shutdown
C< i^xceedances:
T inlet > 28 deg C below design avg. T inlet
T diff. across bed < 80% design avg. T difference
cause of exceedance
measures taken to correct it
Closed-vent system
standard:
monitor:
repair:
No Detectable Emissions and no visual emissions
At facility effective date
Annually
RA requested times
5/15
3-17
-------
Thermal Vapor Incinerator
Standard:
=> 95 wt% efficiency or
[TOC] = 20 ppmv baaed on sum of compd.,dry basis, 3% 02
RTmin = .5 sec where => 760 deg C
Monitoring: A and B
A. flow indicator
records hourly
installation point
daily inspection
B. temperature monitoring device
continuously record
one location:
in combustion chamber downstream of
combustion zone
accuracy:
+/- 1% of Temp being monitored or
.5 degrees C (whichever is greater)
inspect daily
Repair:
immediately upon daily inspection
Recordkeeping: A, B, and C
A. Emissions reductions from condenser i or ii
i. Based on tests
test plan
design flow rate
design organic content
ranges of other parameters
insure using highest capacity loading
manufactures name, model number
type of control device
dimensions of control device
capacity
construction materials
description of sampling and monitoring
locations
equipment to be used
frequency
analytical procedures for analys
all performance test results
3-18
-------
ii. Based on engineering calculations
list of all reference and sources
dates of closed-vent monitoring
design analysis, specs, drawings,
(vendor info ok)
incinerator parameters
vent stream composition
constituent concentration
flow rate
design min. T in combustion
design avg. T in combustion
RT in combustion zone
owner/operator statements
realistic paramters used for high load,
capacity
device designed to operate at 95%
removal eff.
unless it reduces [organic] < 10 ppmw or
unless it meets 3 lb/hr and 3.1 tons/yr
B. General Device Information
description and date of any modifications to CV/CD
id operating parameters
describe monitoring device
diagram of monitor sensor location
dates on device start up and shutdown
C. Exceedances:
if monitoring RT min:
when T < 760 deg C
if standard 95% eff:
when T conb zone > 28 deg C below design avg.
comb, zone T
cause of exceedance
measures taken to correct it
piping
zone
zone
Closed-vent system
standard:
monitor:
repair:
No Detectable Emissions and
At facility effective date
Annually
RA requested times
5/15
no visual emissions
3-19
-------
Boiler/Process Heater
Standard:
=> 95 wt% efficiency or
[XOC] = 20 ppmv based on sum of compd, dry basis, 3% O-,
RTmin = .5 sec with T => 760 deg C
and vent stream must enter flame combustion zone of 3/ph
Monitoring: A and B
A. flow indicator
records hourly
installation point
daily inspection
If design heat input capacity < 44 MW
B. temperature monitoring device
continuously record
one location:
in furnace downstream of combustion zone
accuracy:
+/- 1% of Temp being monitored or
.5 degrees C (whichever is greater)
inspect daily
If design heat input capacity => 44 MW
continuously record
paramter that indicates good combustion practices
inspect daily
Repair:
immediately upon daily inspection
Recordkeeping: A, B, and C
A. Emissions reductions from condenser i or ii
i. Based on tests
test plan
design flow rate
design organic content
ranges of other parameters
insure using highest capacity loading
manufactures name, model number
type of control device
dimensions of control device
capacity
construction materials
description of sampling and monitoring
locations
equipment to be used
frequency
analytical procedures for analysi
all performance test results
3-20
-------
ii. Based on engineering calculations
list of all reference and sources
dates of closed-vent monitoring
design analysis, specs, drawings,piping
(vendor info ok)
B/ph parameters
vent stream composition
constituent concentration
flow rate
design min. flame zone T
design avg. flame zone T
combustion zone RT
description of method and location where
vent stream goes in combusiton zone
owner/operator statements
realistic paramters used for high load,
capacity
device designed to operate at 95%
removal eff.
uless it reduces [organic] < 10 ppmw o
unless it mets 3 lb/hr and 3.1 tons/yr
B. General Device Information
description and date of any modifications to CV/CD
id operating parameters
describe monitoring device
diagram of monitor sensor location
dates on device start up and shutdown
C. Exceedances:
T flame zone > 28 deg C below disign avg. flame zone T
position changes where vent stream is introducted
cause of exceedance
measures taken to correct it
Closed-vent system
standard:
monitor:
repair:
No Detectable Emissions and no visual emissions
At facility effective date
Annually
RA requested times
5/15
3-21
-------
Flares
Standard:
no visible emissions > 5 minutes/any consecitive hrs
flame present at all times
if steam-asaisted:
Ve < 60 ft/s and Ht > 300 BTU or
60 ft/s 1000 BTU
Ve < Vmax < 400 and Ht > 300 BTU
if air-assisted:
Ve < Vmax and Ht => 300 BTU or
Ve < 60 ft/sec and Ht => 300 BTU
if non-assisted:
Ve < 60 ft/sec and Ht => 200 BTU or
60 < Ve < 400 ft/sec and Ht > 1000 BTU
Ve < Vmax < 400 and Ht > 200 BTU
Monitoring: A and B
A. flow indicator
records hourly
installation point
daily inspection
B. heat sensing device for continuous ignition of pilot flame
continuously record
inspect daily
Repair:
immediately upon daily inspection
Recordkeeping: A, B, and C
A. Emissions reductions from condenser i or ii
i. Baaed on testa
test plan
design flow rate
design organic content
ranges of other parameters
insure using highest capacity loading
manufactures name, model number
type of control device
dimensions of control device
capacity
construction materials
description of sampling and monitoring
locations
equipment to be used
frequency
analytical procedures for analysis
all performance test results
3-22
-------
ii. Based on engineering calculations
list of all reference and sources
dates of closed-vent monitoring
design analysis, specs, drawings, piping
(vendor info ok)
flare parameters
vent stream composition
constituent concentration
flow rate
no visible emissions
flame present
Ht
Ve
owner/operator statements
realistic paramtera used for high load,
capacity
device designed to operate at 95%
removal eff.
uless it reduces [organic] < 10 ppmw or
unless it mets 3 lb/hr and 3.1 tons/yr
B. General Device Information
description and date of any modifications to CV/CD
id operating parameters
describe monitoring device
diagram of monitor Eensor location
dates on device start up and shutdown
C. Exceedancea:
period when pilot flame is not ignited
cause of exceedance
measures taken to correct it
Closed-vent system
standard: No Detectable Emissions and no visual emissions
monitor: At facility effective date
Annually
RA requested times
repair: 5/15
3-23
-------
Carbon Adsorber System- Regenerative
Standard:
=> 95 wt% efficiency or
=> emission limits of 3 lb/hr and 3.1 tons/yr
Monitoring: A and either B or C
A. flow indicator
records hourly
installation point
daily inspection
B. [organic compd] in carbon bed exhaust vent stream
continuously record
daily inspection
C. device to measure a parameter that indicates regeneration
on a regular, predetermined time cycle
continuously record
inspect daily
D. replace carbon at regualr, predetermined time interval
that is < carbon service life
Repair:
immediately upon daily inspection
Recordkeeping: A, B, and C
A. Emissions reductions from condenser i or ii
i. Based on tests
test plan
design flow rate
design organic content
ranges of other parameters
insure using highest capacity loading
manufactures name, model number
type of control device
dimensions of control device
capacity
construction materials
description of sampling and monitoring
locations
equipment to be used
frequency
analytical procedures for analysis
all performance test results
3-24
-------
ii. Based on engineering calculations
list of all reference and sources _
dates of closed-vent monitoring _
design analysis, specs, drawings,
piping (vendor info ok) _
adsorber parameters _
vent stream composition _
constituent concentration __
flow rate _
relative humidity _
temperature _
design outlet [organic compd] level __
no. and capacity of beds _
type and working capacity of act.
Carbon for beds _
design total stream flow over period
of each complete carbon bed regenerative
cycle _
duration of carbon bed steaming and
cooling/drying cycles _
design carbon bed T after regeneration _
design carbon bed regeneration time _
design service life of carbon _
owner/operator statements
realistic paramters used for high load,
capacity _
device designed to operate at 95%
removal eff. _
uless it: reduces (organic] < 10 ppmw or
unless it mets 3 lb/hr and 3.1 tons/yr
B. General Device Information
description and date of any modifications to CV/CD _
id operating parameters _
describe monitoring device _
diagram of monitor sensor location _
dates on device start up and shutdown _
date when existing carbon is replaced _
C. Exceedances:
if {organic compd]:
[org] exhaust > 20% above design exhaust vent
stream (org] _
if parameter for regen. on regular cycle _
flow continuos past predetermined reg. time _
cause of exceedance _
measures taken to correct it
Closed-vent system
standard: No Detectable Emissions and no visual emissions
monitor: At facility effective date
Annually
RA requested times
repair: 5/15
3-25
-------
Carbon Adsorber- Nonregenerative
Standard:
=> 95 wt% efficiency or
=> emission limits of 3 lb/hr and 3.1 tons/yr
Monitoring: A and either B or C
A. flow indicator
records hourly
installation point
daily inspection
B. [organic compd] in exhaust vent stream
monitor on regualr basis
inspect daily or at time < 20% time carbon life
(which is longer)
replace carbon when this indicates need
C. replace carbon at regular predetermined time interval less
than design carbon replacement interval
Repair:
immediately upon daily inspection
Recordkeeping: A, B, and C
A. Emissions reductions from condenser i or ii
i. Based on tests
test plan
design flow rate
design organic content
ranges of other parameters
insure using highest capacity loading
manufactures name, model number
type of control device
dimensions of control device
capacity
construction materials
description of sampling and monitoring
locations
equipment to be used
frequency
analytical procedures for analysis
all performance test results
ii. Based on engineering calculations
list of all reference and sources
dates of closed-vent monitoring
design analysis, specs, drawings, piping
(vendor info ok)
parameters
vent stream composition
constituent concentration
flow rate
relative humidity
temperature
3-26
-------
design outlet (organic compd] level
capacity of carbon bed
type and working capacity of act.
carbon in bed
design carbon replacement interval baaed on
total carbon working capacity of CD and
source operating schedule
owner/operator statements
realistic paramters used for high load,
capacity
device designed to operate at 95%
removal eff. unless it reduces [organic]
< 10 ppmw or unless it mets 3 lb/hr and
3.1 tons/yr
B. General Device Information
description and date of any modifications to CV/CD
id operating parameters
describe monitoring device
diagram of monitor sensor location
dates on device start up and shutdown
date when carbon is replaced
C. Exceedances:
if monitoring [organic] in exhaust:
date and time when monitored fro breakthru
and [ ] reading
date when carbon is replaced with fresh carbon
cause of exceedance
measures taken to correct it
Closed-vent system
standard:
monitor:
repaxr:
No Detectable Emissions and no visual emissions
At facility effective date
Annually
RA requested times
5/15
3-27
-------
Checklist
Equipment Leak Applications
Part 264/265 BB
General
1. Does the facility need authorization under RCRA Section 3005?
la. Facility status: interim or final permit?
lb. Effective date for the facility: Dec 21,1990 or permit
renegotiation?
Waste Streams
2. Identify all hazardous waste streams by storage tank #.
2a. Which of the above HV) streams contain at least 10% organics by
weight?
2b. Method of determination? knowledge, ASTM Methods D2267-88,
E169-87, E168-88, E260-85 or Method 9060 or 8240
2c. If knowledge, is it documented?
2d. Date of initial determination
2e. Dates of other analysis? annual, change, batch
3. For each waste stream that does qualify, determine fluid type,
gas/vapor service, light-liquid service, heavy liquid service
3a. Method for determining light liquid service.
vapor pressures of constituents from standard texts
ASTM D-2879-86
4. For each waste stream that does qualify, list the equipment that
contains or contacts the HW?
5. Delete the equipment which is in vacuum service?
6. Delete the equipment associated with exempt units?
7. Do they have a list of equipment under this rule?
8. List the id numbers of NDE equipment with signature of owner/operator.
9. List of PRD in gas/vapor service.
3-28
-------
Checklist
Equipment Leak Applications
Part 264/265 BB
10. Dates of test for NDE
Background level
Maximum instrument reading
11. List of ID numbers for equipment in vacuum service
12. List of ID numbers of "unsafe-to-monitor" and "difficult-to-monitor"
valves, with explanation for each and plan for monitoring or schedule.
13. For skip period valves.
13a. Schedule of monitoring.
13b. Percent found leaking during each monitoring period.
3-29
-------
Identification of Equipment Covered by Rule
Equipment Equipment Id # Waste Stream # Fluid
Pumps
general
dual mechanical
NDE (sealless)
closedvent/control device
Compressors
general
NDE Sealless
CV/Control Device
Pressure Relief Devices
general
CV/Control Devices
Sampling Connecting Systems
general
Valves
general
leakless
unsafe to monitor
difficult to monitor
alter allowable %
alter, skip period LDRP
Closed-Vent/Control Devices
general
vapor recovery
condenser
regeneration adsorber
non reg. adsorber
3-30
-------
Identification-of Equipment Covered by Rule (cont'd)
Equipment Equipment Id # Waste Stream # Fluid
enclosed combustion
process heater
boiler
catalytic vapor incinerator
thermal vapor incinerator
flares
air assisted
steam assisted
nonassisted
3-31
-------
Recordkeeping
unit A
equipment id #
locat ion
type of equipment
% wt. TOC at equipment
fluid state at equipment
designated method for compliance_
Leak Recordkeeping
monitorinq requipment id #
operators id
ristp of visual, audible, olfactory indication of leak
date of leak detection
date of repair attempt
Y* repair methods at each attempt
uj "above 10.000"
10 "rppair delayed" if after 15 days
dnnimpntation of valve repair delay
signature of person approvinq delay
expected date of repair
Physical Inspection
indication of leak by visual, audible or olfactory mean
monitoring equipment id #
calibration correct
operators id
correct monitoring techniques used
Method 21 results
tagged placed on if leak detected
if equipment already has tag:
date leak detected
date of expected repair or repair
-------
Valves Gas/Vapor or Liquid Service
general
1. monitored monthly by Method 21
2. 10,000 ppm means a leak
3. two successive months without a leak, monitor first month or
each quarter, after leak return to monthly monitoring
4. repair 5/15 or delay or repair
NDE
1. designated NDE in operating record
2. has no external actuating mechanism in contact with HW
3. meets NDE by Method 21 (500 ppm + bkgd)
4. initially tested by Dec. 21, 1990 and annually (or as RA
specifies)
"Unsafe to Monitor"
1. designated as such in operating log
2. appers that monitoring personnel would be exposed to immediate
danger
3. owner has a written plan to monitor during safe times
"Difficult to Monitor"
1. designated as such in opeating record
2. valve locatio requires personnel to climb over 2 meters above
support
3. unit was in operating before June 21, 1990
4. owner has written plan to monitor at least once a year
Percentage % Allowed to leak (2%)
1. owner has notified RA that they will use this method
2. a performance test of all valves in unit during the same week by
Dec. 21, 1990 by Method 21
3. repair 5/15 or delay of repair
4. % leaking calculated by:
If valves subject to rule leaking
# valves subject to rule within the unit
Skip Period
1. owner notified RA to use this portion
2. can skip one quarterly leak detection after 2 consecutive
quarterly monitoring with 2% or less leaking
3. after 5 consecutive monitoring periods at 2% or less, can skip 3
4. return to monthly monitoring if exceed 2%
Heavy Liquid Service
general
1. Monitored by Method 21 within 5 days of indication of leak by
sight, smell, or alarm
2. 10,000 ppm means a leak
3. repair 5/15 or delay of repair
3-33
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Pumps Light Liquid Service
general
1. monitor monthly by Method 21
2. inspect visually weekly for leaks
3. leak is 10,000 ppm or above or a visual indication
4. repair 5/15 days
mechanical seal system
1. has one of the following:
a) barrier fluid pressure above stuffing box pressure
b) has barrier fluid degassing reservoir to CV-CD
c) purges barrier fluid into HW stream with NDE to air
2. barrier fluid must not be HW with organics > 10%
3. barrier system must have sensor for failure of sys.
or seal system
4. visual inspection weekly
5. daily check on sensor or audible alarm checked monthly
6. criterion must be set for failure for sensor
7. failure of sensor means a leak
8. repair 5/15 days
no detectable emissions
1. have no externally actuated shaft penetrating the pump housing
2. operate with NDE by Method 21 (500 ppm + bkg)
3. tested initially, annually and any other time by RA
equipped with closed vent system to control device
1. meets control device requirements of the process vent rule
Heavy Liquid Service
1. monitor within 5 days of potential leak determination by visual,
audible, or olfactory method
2. leak is 10,000 ppm by Method 21
3. repair 5/15
3-34
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Sampling Connecting System
1. does it have closed vent or closed purge system
2. do these systems (pick one)
a) return purged HW to process line with NDE
b) collect and recycle purged KW with NDE
c) capture and transport all purged HW to control device
(see control device for requirements)
3. has design, documentation, monitoring, operating and
inspections been recorded and kept up to date in
operating record
Open-ended valves or lines
general
1. is it equipped with cap, blind flange, plug or second
valve which is on at all times execpt during the use of
the line or valve
2. if second valve is used, must be closed after open-ended
valve is closed
3. if doulble block and bleed system is used, the bleed valve
or line may remain open during operations that require
venting the line between the block valves, but must be
closed at all other times.
Flanges and Other Connectors
general
1. have they monitored within 5 days of evidence of
potential leak by visual, sound or smell.
2. 10,000 ppm means a leak
3. repair 5/15 or delay of repair
Pressure Relief Devices
gas/vapor service
1. operating with NDE as measured by Method 21
2. after release, return to NDE within 5 days
3. monitor within 5 days of release by Method 21
or
2. is it equiped with closed-vent, control device (Hooded)
3. design, monitoring of control device in facility operating
record
light liquid or heavy liguid service
1. monitored by Method 21 within 5 days of visual, smell,
audible indications of potential leak
2. over 10,000 ppm means a leak
3. repair 5/15
Closed-vent systems
1. meet NDE emissions requirements of 500ppm + bkgd
using Method 21
2. monitor initially by Dec 21, 1990 (or when control devices
installed) and annually or other by RA
3. detectable emissions by method 21 or visual
4. repair 5/15
3-35
-------
Compressors
general
1. has a seal system with barrier fluid system
2. a) barrier fluid pressure greater than compressor
stuffing box pressure or
b) barrier fluid system with closed-vent to control
device (see CVCD) or
c) has a barrier fluid purge system for NDE
3. barrier fluid is not HW with 10% by weight or greater
organics
4. equiped with sensor to detect failure of seal system
and/or barrier fluid system
5. a) sensor checked daily or
b) sensor with audible alsarm checked monthly or
c) sensor with audible checked daily if at unmanned site
6. operator has set criterion for sensor failure
7. senosr idcicates failure means leak
8. repair 5/15
Closed-vent and control device (Hooded)
1. see CVCD requirements
NDE
1. is it meeting NDE by Method 21
2. was it certified NDE initally
3-3G
-------
PROCESS VENTS CASE STUDY
GOOD GUYS DISPOSAL COMPANY
Good Guys Disposal Company is a TSD facility with a final permit.
Applicable portions of the air rule were included when their permit was re-
issued on April 17, 1991. Their original permit waa issued November 1990.
They have two unit operations, an incinerator and a distillation unit. The
wastes are generated off site and transported to GGD by rail car and tank
truck.
The date of your inspection is January 14, 1993.
3-37
-------
Permit Information: Issued April 17, 1991
Unit operations:
1. distillation
2. incineration
Storage tanks:
1. TOC = 120,000, light liquid, 200 million gallons/yr
1'. TOC = 8 ppm, light liquid, 56 million gallons/yr
3. TOC = 450 ppm, heavy liquid, 35 million gallons/yr
4. TOC = 150,000, light liquid, 98 million gallons/yr
5. TOC = 160,000 ppm, light liquid, 45 million gallons
Vents at Facility: 8
Pumps: 5
Valves: 3
Pressure Relief Devices: 2
Sampling Connection System: 1
Open-ended Line: 1
3-38
-------
Facility: Good Guys Disposal Co.
vent A
vent B
Unit I
1
von I C
condenser
hatch still
Unit 2
PRD©
© 2 flange | |
fi-X
© ,
vent I)
CJ
a
incinerator
vcnl
ij:(;knd
L,
sampling connection
system
fi
pump
X
o|>cii-ended line
I'RIJ
tl
iiic.miic tcltcl drvii <.
ATK l/l I (i7/.'i«i. ti
i-y)
-------
Operating Record
Pumps:
1, 2 NDE
3 mech. dual, seal
4, 5 general
Valves:
1, 2 general
3 leakless
PRD:
both are closed vent/control device
TOC analysis:
Initially conducted April 1, 1391
Last one was April 1, 1992
Method used: 9060
Fluid type conducted at the same time as TOC by vapor pressure knowledge
Statement that control device reduces emission by 95%
Monitoring:
flow indicator records daily
temperature at two locations, recorded daily, inspected weekly
all correct general device information is included
design avg exhaust T is 150°
recorded on device a 175°
Weekly visual inspection of pumps and valves
Monthly monitoring of all pumps and valves
Monthly monitoring of all pumps and valves
Valve 2 was found leaking on Dec 12 and repaired by Jan 1
Your walk through:
no tag on valve 2
dripping at pump #4
3-40
-------
QUESTIONS*
1. What is their effective date for these rules?
2. Based on the TOO concentrations of the storage tanks, which waste
lines are we concerned with under the equipment leaks rule?
3. Which units fall under the process vent rule?
4. Which vents would we be concerned with here?
5. If the operating record only listed TOC values (or documentation) for
units above 10 ppm, would they be in compliance?
6. What lists must be in the permit (or application) and record?
7. How often do waste stream analyses have to be done, are they in
compliance here: what if distillation uses batch waste streams?
8. List the equipment under the leak rule.
Is PRD /I covered and, if not, when would it be?
9. Assume this facility adds another unit to their operations. This new
unit and its vents fall under the process vent rule. The following
are the emissions rates, both hourly (En) and yearly(Ey), for the
existing unit (Unit 1) and the new unit (Unit 3):
En Ey
Unit 1 1.6 lb/hr 1.7 tona/yr
Unit 3 2.5 lb/hr 2.6 tons/vr
Total for facility 4.1 lb/yr 4.3 tons/yr
If the facility installs only one control device on one of these two
units, is it possible for the facility to be in compliance?
10. During your walk through of the facility, you observe the following:
no tags on any equipment
dripping from pump #4
flow indicator records daily
temperature indicator records hourly
exhaust temperature is 175° and has been for 48 hours
The previous leak detection was valve £2 on Dec 12, 1992
and repaired on Jan. 1, 1993.
What violations have you found?
11. If their records showed that pump /4 had been leaking on Dec. 12 and
repaired by Dec. 20, would seeing dripping from the pump at this time
be a violation?
12. What action is required based on what you saw on the walk through?
For questions 1-9, assume the condenser is associated with the
distillation unit.
For questions 10-13, assume the condenser has been added as a control
device.
3-41
-------
Leak Detection Monitoring
Leak Detection Levels
Types of Equipment
Equipment Preparation - General & Specific
Equipment Usage
4-1
-------
Leak Detection Monitoring
¦ Learning Objective
• Understand various emission levels signifying a leak
• Understand the various types of equipment that can be used for leak detection
monitoring
• Understand the limitations of each type of leak detection monitoring equipment
•. Understand how to use the leak detection equipment - pre-check, calibration, field
use considerations
Leak Detection Levels
¦ NDE - 500 ppm above background
¦ 10,000 ppm - 1%
Leak Detection Levels For Regulated Pieces Of Equipment*
Equipmeni
Gas/Vapor
Service
Light Liquid
Heavy Liquid
Pressure relief
devices
NDE
10,000ppm
I0,000ppm
Closed-vent systems
Compressors with
seals
Pumps
lO.OOOppm
I0,000ppm
lO.OOOppm •
Flanges and other
connectors
10,000ppm -
Sampling connecting
systems
¦ equipment with closed-purge or closed-vent system - NDE
Open-ended valves
or lines
equipmeni with cap, blind flange, plug or .second valve •
* Ftr^utney: Cloifd-vent syutmj - annual: all others - sruvuMy
Action FP.D in (aiivapor -0/3. M 21: oil othtn - JHi, tag
4-2
-------
Leak Detection Levels
¦ Method 21
• 40 CFR Part 60, Appendix A - 3 pages; June 22, 1990 Federal Register
(55 FR 25602)
• Locator/confirmation of leaks, not quantifier of emission rates
• Makes use of portable VOC analyzers
• General guidance for
- definitions
- monitoring instruments (specifications, performance criteria)
- calibration gases and procedures
- sampling techinques: location for sampling for pieces of equipment for NDE and
"leaks based on concentrations"
- instrument evaluation procedures
Meiliod 21
¦ Key Provisions
• I.I - Identifies applicable equipment
¦ 1.2 - No instruments are identified BUT all instruments must meet specifications
• 2.(J - Definitions
• 3.1.1 - Instrument specification
a. 4 types identified
b. Instruments must be capable of measuring conccniraiions in rules
c Meter readability = ± 2.5 percent of concentration
d. Flow rate = 0.1 - 3 liters/minute
c. Intrinsically safe, safety devices shall not be removed
f. Probe diameter
•3.1.2- Instrument performance
a. Response factor < 10
b. Response time < 30 seconds
c. Calibration precision < 10 percent
d. Evaluation procedures - Section 4.4
Method 21
¦ Key Provisions (Cont'd)
•3.1.3- Performance evaluation requirements
a. Response factor - reference or by measurement
b. Frequency of calibration test
c. Response time test
• 3.2 - Calibration gases
• 4.0 - Procedures
1. Pretest
2. Calibration
3. Sampling - to get background: 25 cm
4. Instrument evaluation procedures
Response factor, calibration precision,
response times - 3 measurements for each element
4-3
-------
Calibration Gases And Procedures
¦ Sections 264 and 265.1063 (b)
¦ To be done daily
¦ To be done with mixture of methane or n-hexane and air at concentration
10,000 ppm
Sampling Techniques
¦ Sections 264 and 265.1063 (b) & (c)
¦ "Probe shall be traversed around all potential leak interfaces as close to the interface
as possible"
Types Of Equipmpn*
¦ Flame ionization
¦ Pholoionization
¦ Catalytic oxidation
¦ Infrared absorption —
4-4
-------
Types Of Equipment
¦ Flame ionization
• Century OVA 108
• Hydrogen flame ionizes carbon molecules —> current —> concentration
• Range 0-10,OOOppm
• Easy to calibrate
• Weight of 12 pounds
• Humidity operating range 5 - 95%
• Temperature range 10-40°C
Types Of Equipment
¦ PhQtQionization
xdpF
rfip
• Makes use of light source - UV; to ionize VOC gas molecules —~ current —~
concentration
• Range 0 - 2000ppm \mJ3L W
• Relatively eay to calibrate
• Weight under 10 pounds
• Humidity operating range - up to 90%
• Wide temperature range
V7
Types Of Equipment
¦ Catalytic oxidation
¦ TLV Sniffer
¦ Platinum catalyst element and a catalytically inert second element is used. Sample
is passed between element and current generated —> concentration
• Range 0 - 10,OOOppm
• More difficult to calibrate
¦ Weight of 5 pounds
• Humidity operating range - none specified but instrument is sensitive to humidity
¦ Wide temperature range
• Difficulty: unit must be held in a consistent position for sampling
4-5
-------
Equipment Preparation Procedure
¦ Pre-check
¦ Calibration
[Movie]
[Demonstration]
Model OVA 108 CENTURY Organic Vapor Analyzer
SIDE PACK ASSEMBLY
PROBE/READOUT
ASSEMBLY
RECORDER
CONNECTOR
CNITER
BUTTON
EARPHONE
JACK
READOUT
CONNECTOR
SAMPLE
CONNECTOR
"*UMBIUCAL
CORD
REFILL
CONNECTOR
Equipment Usage - Field Sampling
¦ Method 21 Guidance
¦ Movie
4-6
-------
REVIEW PROBLEM #2
What type or types of portable VOC analyzer would be appropriate
for fugitive leak monitoring of chloroform emissions?
Type of Analyzer
Flame Ionization
Catalytic Combustion
Photoionization
Based on your review of response factors and other information.
what instrument would you choose?
Acceptable
Yes _ No
\J
et>
REVIEW PROBLEM #3
The equipment in VOC service has a light liquid mixture 90% by
weight 1,1,1,2 Tetrachloroethane and 10* by weight 1,1,2,2 Tetra-
chloroethane. Can a catalytic combustion analyzer be used for
fugitive leak monitoring of equipment handling this mixture?
Yes , State justification
No , State justification ~
^ \ D
4-7
-------
REVIEW PROBLEM #4
To avoid inadvertently capturing any water or oil droplets into the
instrument probe, the plant's monitoring personnel keep the probe
tip at least 2 centimeters away from all valve stems and at least
6 centimeters away from all rotating shafts. Also, they attempt to
complete the traversing of a valve (and other components) in about
5 seconds so that they can complete the large number of screening
tests in a timely fashion. Are either of these practjicesj incon-
sistent with MethocJ/ll or Subpart BB requirements?. """
Answer
\Pr>,Vp
*—1 AKjw*
\0 o
REVIEW PROBLEM #5
While conducting leak screening tests, the plant's monitoring
personnel are yanking the probe away immediately after the
instrument gauge pegs off-scale at 10,000 ppm. They are not
keeping the instrument at the leak site for two times the
instrument's response time as specified in Method 21. They are
classifying each of the valves and other sources as "leakers" when
the meter pegs off-scale. Is this screening technique consistent
with subsection 4.3 of Method 21?
Answer
4-8
-------
REVIEW PROBLEM #6
A pipefitter accompanies the plant monitoring person conducting the
fugitive VOC screening tests- If a leak is detected, the pipe-
fitter attempts to repair the leak immediately, if successful, the
plant personnel do not tag the component that was leaking and they
do not list it in their routine records. Is this consistent with
the Subpart BB requirements?
Answer
' *
1
¦—) X
APPENDIX A
REVISED METHOD 21
4-9
-------
2ZG02
Federal Register / Vol. 55. No. 121 / Friday, June 22. 1990 / Rules and Regulations
Drafting Information
The drafters of this regulaiton are
John R. Ailyn. Radarman First Class.
U.S. Coast Guard Croup Grand Haven
and M. Eric Reeves. Lieutenant
Commander. U.S. Coast Cuard. Project
Attorney. Ninth Coast Cuard District
Legal Office.
Discussion of Regulation
The circumstances requiring this
regulation result from a high-speed
power boat race which will be
conducted on Muskegon Lake.
Muskegon. Ml. during this time. The
safety zone is needed to ensure the
protection oi life and property during the
high-speed power boat race.
This regulation is issued pursuant to
33 U.S.C. 122S and all 1231 as set out in
the authority citation for all of part 165.
Federalism
This action has been analyzed in
accordance with the principles and
criteria contained in Executive Order
12512. and it has been determined that
this rulemaking does not have sufficient
federalism implications to warrant the
preparation of a Federalism
Assessment.
Economic Assessment and Certification
These regulations are considered to
be non-major under Executive Order
12291 on Federal Regulations and
nonsignificant under Department of
Transportation regulatory policies and
procedures (44 FR 11034; February 26.
1779). Because of the short duration of
these regulations, their economic impact
hns been found to be so minimal that a
full regulatory evaluation is
unnecessary. This event will draw a
large number of spectator croft into the
area for the duration of the event. This
should have a favorable impact on
commercial facilities providing services
to the spectators. Any impact on
commercial traffic in the area will be
negligible.
Since the impact of these regulations
is expected to be minimal, the Coast
Cuard certifies that they will not have a
significant economic impact on a
substantial number of small entities.
List of Subjects in 33 CFR Part 165
Harbors. Marine safety, Navigation
(water). Security measures. Vessels.
Waterways.
Regulation
In consideration of the foregoing,
subpart C of part 165 of title 33. Code of
Federal Regulations, is amended as
follows:
PART 165—(AMENDED]
1. The authority citation for part 165
continues to read as follows:
Authority 33 U.S.C 1225 and 1231: 50 U.S.C.
191: 49 CFR 1.48 and 33 CFR I.OS-l(g). 6.04-1.
6.04-4. and 160J.
2. A new { 165.T0912 is added to read
as follows:
i 16S.T0912 Safety Zonr Muaka^on Uka,
Muskegon, ML
(a) Location. The following area is a
safety zone: Muskegon Lake in its
entirety.
(b) Effective date. This regulation will
become effective at 10:30 a.m. (e.d.s.t.)
24 June 1990. and terminate at 4 p.m.
(e.d.s.t.) 24 June 1990.
(c) Regulations. (1) In accordance with
the general regulations in f 165.23 of this
part, entry into this zone is prohibited,
except when expressly authorized by
the Coast Guard Patrol Commander
(Commanding Officer, U.S. Coast Cuard
Station Grand Haven. MI.)
(2) The Coast Cuard will Patrol the
Safety zone under the direction of a
designated Coast Guard Patrol
Commander. The Patrol Commander
may be contacted on channel 16 (156.8
MHZ) by the call sign "Coast Guard
Patrol Commander". Operators of
vessels, not participating in the event,
desiring to transit the regulated area,
may do so only with prior approval of
the Patrol Commander and when so
directed by that officer. Transiting
vessels will be operated at bare
steerageway, and will exercise a high
degree of caution in the area.
(3) The Patrol Commander may direct
the anchoring, mooring or movement of
any boat or vessel within the regulated
area. A succession of sharp, short
signals by whistle or horn from vessels
patrolling the area, under the direction
of the Coast Guard Patrol Commander,
shall serve as a signal to stop. Vessels
so signaled shall stop and shall comply
with the orders of the Patrol
Commander. Failure to do so may result
in expulsion from the area, citation for
failure to comply, or both.
(4) The Patrol Commander may
restrict vessel operation within the
regulated area to vessels having
particular operating characteristics.
(5) The Patrol Commander may
terminate the marine event or the
operation of any vessel at any time it is
deemed necessary for the protection of
life and property.
Dated: |une 7. 1990.
1. L. Miiall.
Commander. US. Coast Cuard. Captain of the
Port Crand Haven. Ml.
|FR Doc 90-14452 Filed 8-21-90: 8:45 am|
HUJM COOC UK-IK
ENVIRONMENTAL PROTECTION
AGENCY
(AD-FRL-3727-3)
40 CFR Pari 60
Standards of Performance for New
Stationary Sources; Tett Methods
agency: Environmental Protection
Agency (EPA).
action; Final rule.
summary: Method 21 appiies to the
determination of volatile organic
compounds (VOC) leaks from process
equipment such as valves, flanges and
connections, pumps and compressors,
and pressure relief devices. Since
Method 21 was promulgated in 1983.
several deficiencies in the method that
could lead to inconsistencies in the
determination of VOC leaks from such
devices have come to the attention of
EPA in the form of questions as to the
proper application of the method. On
May 30.1989. EPA proposed appropriate
additions and revisions to Method 21 to
alleviate any deficiencies (54 FR 22920).
This action promulgates those additions
and revisions.
dates: Effective Date. June 22.1990.
Judicial Review. Under section
307(b)(1) of the Clean Air Act judicial
review of the actions taken by this
notice is available only by the filing of a
petition tor review in the U.S. Court of
Appeals for the District of Columbia
Circuit within 60 days of today's
publication of this notice. Under section
307(b)(2) of the Clean Air Act. the
requirements that are the subject of
today's notice may not be challenged
later in civil or criminal proceedings
brought by EPA to enforce these
requirements.
ADOfttSSEK Docket A docket, number
A-88-29. containing information
considered by EPA in development of
the promulgated rulemaking is available
for public inspection between 8 a.m. and
4 pjru Monday through Friday, at EPA's
Air Docket Section (LE-131). room M-
1500. First Floor. Waterside MalL 401 M
Street SW„ Washington. DC 2046a A
reasonable fee may be charged for
copying.
ran FURTHER INFORMATION CONTACT
William Crimley or Roger T. Shigehara.
Emission Measurement Branch (MD-19).
Technical Support Division. U.S.
Environmental Protection Agency.
Research Triangle Park. North Carolina
27711. telephone (919) 541-2237.
4-10
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Federal Register / Vol. 55. No. 121 / Friday. June 22. 1990 / R jles and Regulations
25603
SUPPLEMENTARY INFORMATION;
t. The Rulemaking
Section 2.4 is being revised to remove
a description of the leak determination
procedure, which Is already given, and
more properly belongs in aection 4.3.2.
The example of an acceptable increase
in surface concentration vercua local
concentration is incorrect, and is being
removed at all existing regulatory
subparts state that any reading less than
500 ppm constitutes "no detectable
emissions." The definition is now
expressed in terms of the instrument
readability specification.
Section 3.1.1(b) is being revised
because it is important to call attention
to the possibility that the leak definition
concentration may be beyond the linear
response range of aome Instruments for
some VOC. This potential problem is not
Identified by the existing calibration
procedure, which specifies a single
upscale VOC calibration gas. An
argument could be made that a
multipoint calibration shouid. therefore,
be required. However, adding that
requirement would increase the
method's performance burden and cost.
Section 3.1.1(c) is being revised in
consideration of existing regulatory
subparts, where the intention is for the
readability to be to the nearest 500 ppm.
Since the leak definition in existing
subparts is 10.000 ppm. the nearest 500
ppm represents ±Z5 percent, not ±5
percent
Section 3.1.1(d) is being revised to
prevent any flow interruption from
occurring, such as could occur if a
manually operated device was used for
a pump. The minimum flow rate
specification of 0.50 liter per minute is
reduced to 0.10 liter per minute to
prevent the exclusion of some
instruments that do meet th* response
time specification and could be
acceptable if this change was made. The
flow rate specification has been
qualified «» to where, and under what
conditions, it applies in order to prevent
mis under-! landings that it might apply at
the instrument detector, or with no flow
restriction in the probe. The upper flow
limit specification of 3j0 liters per minute
is retained because some upper limit on
flow rate is required to prevent dilution
of any leaking VOC to a concentration
below the definition of a leak.
Section 3.1.1(e) is being revised in
consideration of comments that have
been made to EPA that the existing
wording in not dear end should be more
specific. In addition, it has been
reported that inexperienced sampling
personnel have been observed to use a
portable flame ionization analyzer with
the exhaust flame arrcstor not replaced
after removal for cleaning.
Section 3.1.1(f) being added (o
emphasize that the instrument ii meant
to sample a discrete area. Some probes
have been observed to have a relatively
large inlet area. The addition is
necessary so as to provide as much
consistency in the Identification of leaks
as in reasonably possible. All
measurements made by EPA in support
of its VOC-Ieaks regulatory
development activities have been made
with probes not over V* in. in outside
diameter.
Section 3.1.2(a) is being revised to
include a procedure that ia needed for
those instances where an instrument ia
not available that meets the response
factor criteria when calibrated with the
specified (in regulation) VOC calibration
gas. The new procedure should meet the
spirit of existing VOC-leak regulations.
Finally, section 3.1.2(b) Is being
revised by replacing the word
"configuration" with all of the items of
sampling equipment that might be
between the probe tip and the detector
during testing.
This rulemaking does not Impose
emission measurement requirements
beyond those specified In the current
regulations, nor does it change any
emission standard. Rather, the
rulemaking would simply add methods
for the achievement of emission testing
requirements that would apply
irrespective of this rulemaking.
IL Public Participation
The proposed amendment to 40 CFR
part 60 that contained proposed
revisions and additions to Method 21
was published in the Fadanl Register on
May 3a 1989 (54 FR 22920). Public
comments were solicited at the time of
proposal. To provide interested persons
the opportunity for oral presentation of
data, views, or arguments concerning
the proposed action, a public hearing
was scheduled for )uly 14.1389
beginning at 10 ajn, but was not held
because no one requested to speak. The
public comment period was from May
3a 1989 to August 14.1989. Two
comment letters were received that
contained comments concerning the
proposed methods. The comments were
supportive of the proposed additions
and revisions, with one exception. That
comment has been carefully considered,
but no changes were made to the
proposed rulemaking.
III. ComsMnta and Change* to the
Proposed Standards
Two comment letters were received
from synthetic organic chemical
manufacturers on the proposed methods.
All but one of the comments therein
were statements to the effect that the
comrr.enter agreed with the proposed
additions and revisions. The one
exception stated that the cornrrenter c?id
not agree that an electrically driven
pump should be required in section
3.1.1(d).
The EPA believes it is necessary to
specify that an electrically driven pump
be used in order to eliminate any
potential for imprecise results due to
variations or interruption in sample
flow arising from the use of a hand
operated squeeze pump. It may be
possible for a given person to use a
hand operated pump satisfactorily, but
EPA believes that technique is too prone
to operator fatigue over the course of an
extensive leak survey to permit Its use
in a reference method, and is. therefore,
not making any change in the
requirement for an electrically driven
pump.
IV. Administrative
The docket is an organized and
complete file of all the information
considered by EPA in the development
of this rulemaking. The docket Is a
dynamic file, since material is added
throughout the rulemaking development
The docketing system is intended to
allow members of the public and
industriea involved to identify readily
and locate documents so that they can
effectively participate in the rulemaking
process. Along with the statement of
basis and purpose of the proposed and
promulgated standards, and EPA
responses to significant comments, the
contents of the docket except for
interagency review materials, will serve
as the record in case of (udicial review
[Clean Air Act section 307(d)(7](A)|.
Under Executive Order 12291. EPA is
required to judge whether a regulation is
a "major rule" and. therefore, subject to
the requirements of a regulatory impact
analysis. The Agency has determined
that this regulation would result in none
of the adverse economic effects set forth
in section 1 of the Order as grounds for
finding a regulation to be a "major rule."
The rulemaking does not impose
emission measurement requirements
beyond those specified in the current
regulations, but instead, provides
methods for performing emission
measurement requirements that would
apply irrespective of this rulemaking.
The Agency has. therefore, concluded
that this regulation is not a "major rule"
under Executive Order 12291.
The Regulatory Flexibility Act (RFA)
of 1930 requires the identification of
potentially adverse impacts of Federal
regulations upon small business entities.
The Act specifically requires (he
completion of an RFA in those irstan.-.i-*
4-11
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23601
Federal Register / Vol. 55. No. 121 / Friday, June 22. 1990 / Rules and Regulations
where small business impact* are
possible. Because these standards
impose no adverse economic impacts,
an RFA ha* not been conducted.
Pursuant to the provisions of 5 U.S.C.
605(b). I hereby certify that the
promulgated rule will not have any
economic impact on small entities,
because the rule does not add either to
the existing requirement for flow rate
measurements, or increase their
associated performance cost.
This regulation was submitted to the
Office of Management and Budget
10MB) for review as required by
Executive Order 12231. Any written
comments from OMB and any written
EPA responses are in the docket.
List of Subjects in 40 CFR Part 60
Air pollution control.
Intergovernmental relations. Synthetic
Organic Chemicals Manufacturing
Industry. Reporting and recordkeeping
requirements.
Dated; lune 7.1990.
William K. Reiily,
Administrator.
Method 21. appendix A of 40 CFR part
60 is amended as follows:
1. The Authority for 40 CFR part 60
continues to read as follows:
Authority: Sections 101. 111. 114.110. and
301 of the Clean Air Act as amended (42
U.S.C. 7«J1.7411. 7414. 7416. 7601V
Appendix A—(Amended)
2. By revising section 2.4 to read as
follow*:
2.4 No Detectable Emission. Any VOC
concentration at a potential leak source
(adjusted (or local VOC ambient
concentration) that i» I to than a value
corresponding to the instrument readability
specification oi section 3.1.1(c) indicates that
a leak is not present.
3. By revising section 3.1.1 (b). (c). (d).
and (e) and adding (f) to read as follows:
3.1.1 Specifications.
fb) Both the linear response range and the
measurable range of the instrument for each
of the VOC to be measured, and for the VOC
calibration gas thst is used for calibration.
shaU encompass the leak definition
concentration specified in the regulation. A
dilution probe aisembly may be used to bring
the VOC concentration within both ranges
however, the specifications for instrument
responsa time and sample probe diameter
shall still be met.
(c) The scale of the instrument meter shall
be readable to X2.1 percent of the specified
laak definition concentration when
performing a no detectable emission survey.
(d)TJie instrument shall be equipped with
an etectncally driven pump to insure that a
sample is provided to the detector at a
constant flow rale. The nominal sample flow
rate, as measured at the sample probe tip.
¦ hall be <1.10 to 3.0 liters per minute when the
probe is fitted with a glass wool plug or filter
that may be used lo prevent plugging of the
Instrument
(e) The instrument shall be intrinsically
safe as defined by Ihe applicable U.S.A.
standards (e.g.. National Electric Code by the
National Fire Prevention Association I for
operation in any explosive atmospheres that
may be encountered in its use. The
Instrument shall, at a minimum, be
intrinsically safe for Class 1. Division 1
conditions, and Class 2. Division 1
conditions, as defined by the example Code.
The instrument shall not be operated with
any safely device, such ss sn exhaust flame
arrestor. removed.
IH The instrument shall be equipped with a
probe or probe extension tor sampling not to
exceed V< in. tn outside diameter, with a
single end opening for admission of sample.
4. By revising section 3.1.2 (a) and (bl
to read as follows:
3.1-2 Performance Criteria.
(a) The instrument response factors for
each of the VOC lo be measured shall be less
than 10. When no instrument is available that
meets this specification when calibrated with
the reference VOC specified in the applicable
regulation, the available instrument may be
calibrated with one of the VOC lo be
measured, or any other VOC so long as the
Instrument then has a response factor of less
than 10 for each of the VOC to be measured.
fb| The instrument response time shsli be
equal to or less than 30 seconds. The
instrument pump, dilution probe (if any),
sample probe, and probe filter, that will be
used during tesling. shall all be in place
during the response time determination.
* t I • «
JFR Doc. 90-1384S Filed ft-21-flO:8 4S am)
M.1JMO coot s»«o aa m
4-12
-------
APPENDIX B
PUBLISHED RESPONSE FACTORS
(From EPA 340/1-88-01 5)
4-13
-------
TABLE
1. RESPONSE FACTORS FOR
TECO
MODEL 580
PHOTOIONIZATION TYPE
ORGANIC
VAPOR
ANALYZERS
10. 0
ev Lamp
Compound
Ionization Potential
Response Factor
(ev)
Acetone
9.58
1.7
Acetophenone
N.D.
4 . 2
Acrolein
N.D.
25. 0
Ammonia
10.15
24.5
Aniline
7.70
0.6
Benzene
9.25
0.7
1,3 Butadiene
9.07
1.0
Carbon disulfide
10. 0
2.3
Chlorobenzene
9. 07
0.5
Cyclohexane
9.98
2.1
1,2-Dichloroethane
N.D
50. 0
Diethylamine
N.D.
2. 0
Dimethyl sulfide
8.69
1.3
Ethyl benzene
8.75
1.7
Ethylene oxide
10. 57
33.8
Ethyl ether
9.53
1.5
Hexane
10. 18
11. 3
Hydrogen sulfide
10.45
7.3
Isopropanol
10. 16
19. 8
Methyl ethyl ketone
9. 53
1.6
Methyl isocyanate
10.57
12. 5
Methyl mercaptan
9.4
1.3
Methyl methacrylate
N.D.
4.2
Nitric oxide
9.25
44 . 9
Ortho chloro toluene
8.83
0.5
Ortho xylene
8.56
0.8
Pyridine
9.32
0.6
Styrene
N.D.
3.3
Sec butyl bromide
9.98
1.7
Tetrachloroethene
9.32
1.6
Tetrachloroethylene
N.D.
1.9
Tetrahydrofuran
9.54
3.7
Toluene
8.82
0.5
Trichloroethylene
N.D.
1.3
4-14
-------
Table 2. RESPONSE FACTORS FOR THE
HUN SYSTEMS, INC
MODEL ISPI-
101 PHOTOIONIZATION ANALYZER
Compound
Actual
Instrument
Response
Concentration
Concentration
Factor
Acetal
1000
925
1.1
5000
7200
0.69
10000
13200
0.76
Carbon Disulfide
1000
1990
0.50
10000
12900
0.78
Carbon tetrachloride
500
784
0.64
1000
1070
0.94
10000
6070
1.6
Chloroform
1000
756
1.3
5000
2550
2.0
10000
5250
1.9
Diketene
1000
148
6.8
5000
318
16.0
10000
460
22.0
Perchloromethyl mercaptan
5000
103
48.0
Toluene
1000
1180
0.85
Tetrachloroethane,1,1,2,2-
1000
736
1.4
5000
1170
4.3
10000
1880
5.3
Trichloroethane,1,1,
1000
1020
0.98
5000
6170
0.81
10000
9430
1.1
Trichlorotrifluoroethane
5000
155
32.0
1,1,2-
10000
430
23.0
4-15
-------
Table 3. RESPONSE FACTORS FOR FOXBORO OVA-108 AND
BACHARACH TLV SNIFFER AT 10,000 pprav RESPONSE
Compound Response Factor Response Factor
OVA-108
TLV Sniffer
Acetic acid
1.64
15. 60
Acetic ahydride
1.39
5.88
Acetone
0.80
1.22
Acetonitrile
0.95
1.18
Acetyl chloride
2.04
2.72
Acetylene
0.39
B
Acrylic acid
4.59
B
Acrylonitrile
0.97
3.49 I
Allene
0. 64
15. 00
Allyl alcohol
0.96
X
Amylene
0.44
1. 03
Anisole
0.92
3.91
Benzene
0.29
1. 07
Bromobenzene
0.40
1. 19
Butadiene, 1,3-
0.57
10. 90
Butane, N
1.44 I
4 . 11
Butanol, sec-
0. 76
1.25
Butanol, tert
0.53
2.17
Butene, 1-
0.56
5.84
Butyl acetate
0 . 66
1.38
Butyl acrylate, N-
0.70
2.57 I
Butyl ether, N
2.60
3.58 I
Butyl ether, sec
0 . 35
1. 15
Butylamine, N
0. 69
2 . 02
Butylamine, sec
0.70
1. 56
Butylamine, tert-
0. 63
1.95
Butyrandehyde, N-
1.29
2.30
Butyronitrile
0.52
1.47 I
Carbon disulfide
B
3.92
Chloroacetaldehyde
9.10
5.07
Chlorobenzene
0.38
0.88
Chloroethane
5.38 I
3.90 P
Chloroform
9.28
B
Chloropropene, 1-
0.67
0.87
Chloropropene, 3-
0.80
1.24
Chlorotoluene, M-
0.48
0.91
Chlorotoluene, 0-
0.48
1. 06
Chlorotoluene, P-
0.56
1. 17 I
4-16
-------
Table 3. RESPONSE
FACTORS FOR FOXBORO
OVA-108 AND
BACHARACH
TLV SNIFFER AT 10,
000 ppmv RESPONSE
Compound
Response Factor
Response Factor
OVA-108
TLV Sniffer
Crotonaldehyde
1.25
B
Cumene
1.87
B
Cyclohexane
0.47
0.70
Cyclohexanone
1.50
7.04
Cyclohexene
0.49
2 . 17
Cyclohexylamine
0.57
1.38
Diacetyl
1.54
3 . 28
Dichloro-l-propene,2,3-
0.75
1.75
Dichloroethane,1,1-
0.78
1. 86
Dichloroethane,1,2-
0.95
2 . 15
Dichloroethylene,cisl, 2-
1.27
1. 63
Dichloroethylene,transl, 2-
1. 11
1. 66
Dichloromethane
2.81
3 . 85
Dichloropropane,1,2-
1.03
1.54
Diisobutylene
0.35
1.41
Dimethoxy ethane,1,2-
1.22
1. 52
DimethyIformaraide,N,N-
4. 19
5. 29
Dimethylhydrazine 1,1-
1. 03
2.70
Dioxane
1.48
1.31
Epichlorohydrin
1.69
2.03
Ethane
0.65
0. 69
I
Ethanol
1.78
X
Ethoxy ethanol, 2-
1.55
1.82
Ethyl acetate
0.86
1.43
Ethyl acrylate
0.77
X
Ethyl chloroacetate
1.99
1.59
Ethyl ether
0.97
1.14
Ethylbenzene
0.73
4 . 74
D
Ethylene
0.71
1. 56
Ethylene oxide
2.46
2.40
Ethylenediamine
1.73
3.26
Formic acid
14.20
B
Glycidol
6.88
5.55
Heptane
0.41 I
0. 73
Hexane,N-
0.41
0. 69
Hexene,1-
0.49
4.69
D
Hydroxyacetone
6.90
15. 20
Isobutane
0.41
0. 55
4-17
-------
Table 3. RESPONSE FACTORS FOR FOXBORO OVA-108 AND
BACHARACH TLV SNIFFER AT 10,000 ppmv RESPONSE
Compound Response Factor Response Factor
OVA-108 TLV Sniffer
Isobutylene
3.13
B
Isoprene
0.59
X
Isopropanol
0.91
1.39
Isopropyl acetate
0.71
1.31
Isopropyl chloride
0 . 68
0.98
Isovaleraldehyde
0.64
2.19 D
Mesityl oxide
1.09
3 . 14
Methacrolein
1.20
3.49 D
Methanol
4.39 P
2.01
Methoxy-ethanol,2-
2.25
3 .13
Methyl acetate
1.74
1.85
Methyl acetylene
0.61
6.79
Methyl chloride
1.44
1.84
Methyl ethyl ketone
0. 64
1.12
Methyl formate
3.11
1.94
Methyl methacrylate
0.99
2.42
Methyl-2-pentanol,4-
1.66
2.00
Methyl-2-pentcne,4-
0.56
1.63
Methyl-3-butyn-2-ol,2
0.59
X
Methylcyclohexane
0.48
0.84
Methylcyclohexene
0.44
2.79
Methylstyrene,a-
13.90
B
Nitroethane
1.40
3.45
Nitromethane
3.52
7.60
Nitroopropane
1.05
2.02
Nonane-n
1.54
11.10
Octane
1.03
2 .11
Pentane
0.52
0.83
Picoline,2-
0.43
1.18
Propane
0.55 I
0.60 P
Propionaldehyde
1.14
1.71
Proponic acid
1.30
5.08 D
Propyl alcohol
0.93
1.74
Propylbenzene,n-
0.51
B
Propylene
0.77
1.74 I
Propylene oxide
0.83
1.15
Pyridine
0.4 7
1.16
Styrene
4 .22
B
4-18
-------
Table 3. RESPONSE FACTORS FOR FOXBORO
OVA-108
AND
BACHARACH TLV SNIFFER AT 10,
000 ppmv
RESPONSE
Compound
Response Factor
Response Factor
OVA-108
TLV Sniffer
Tetrachloroethane,1,1,1,2
4.83 D
6.91
Tetrachloroethane,1,1,2,2
7.89
25.40
Tetrachloroethylene
2.97
B
Toluene
0.39
2.68 D
Trichloroethane,l,l,l-
0.80
2.40
Trichloroethane,1,1,2-
1.25
3 . 69
Tricnloroethylene
0.95
3.93
Trichloropropane,1,2,3-
0.96
1.99
Triethylamine
0.51
1.48
vinyl chloride
0.84
1. 06
Vinylidene chloride
1.12
2.41
Xylene, p-
2.12
7.87
Xylene, m-
0.40
5.87 D
Xylene, 0-
0.43
1.40
I Inverse Estimation Method
D Possible Outliers in Data
N Narrow Range of Data
X No Data Available
B 10,000 ppvm Response Unachievable
P Suspect Points Eliminated
4-19
-------
GLOSSARY
Process Vents/Equipmert Leaks
A. Knowledge of Waste Stream Concentration for Process Vents:
Based on
1. Production process information showing no organic compounds
used.
2. Waste is identical to another unit's or facility's determined by
direct measurements.
3. Previous determination and documentation of no process
change.
B. Performance test for Process Vents consists of:
1. 3 separate runs.
2. More than 1 hour per run at highest facility conditions.
3. Mass flow measurements.
4. Arithmetic means of results of 3 runs.
C. Method 21 for Equipment Tasks
1. Performance criteria for equipment.
2. Calibrated every day.
3. Calibration gases: zero air, mixture of methane or n-liexane in
air with concentration of 10,000 ppm.
D. Location of Sampling for Equipment Leaks
1. Valves — Measurements should be taken at interface where
stem exits the packing gland (sample drawn at stem
circumference), at the interface of the packing gland take-up
flange seat (sample drawn at perphery), and around the valve
housings of multipart assembly at the surface of all interfaces
where a leak could occur.
2. Flanges and Other Connections -- Place probe at outer edge of
the flange-gasket interface and sample circumference of the
flange.
3. Pumps and Compressors — Conduct a circumferential traverse
of the outer surface of the pump or compressor shaft and seal
surface (specifically, within 1 cm at a rotating shaft/seal
interface), and sample all accessbible portions and joints
where leaks could occur.
4-20
-------
4. Pressure Relief Devices - Only for those devices which are
equiped with an enclosed extension (or horn), probe inlet
should be placed near the center of the exhaust area to the
atmosphere.
5. Process Drains -- For open drains, place probe in center of the
open areaJ for covered drains, place probe at surface of cover
interface and conduct a peripheral traverse.
6. Open-Ended Line or Valves -- Place probe inlet near center of
opening to the atmosphere.
7. Seal System Degassing Vents and Accumulator Vents --
Place probe inlet near center of opening to the atmosphere.
8. Access Door Seals -- Place probe inlet at surface of the seal
interface and conduct a peripheral traverse.
E. Flows - No Visible Emissions:
1) Reference Method 22 of 40 CFR Part 60 shall be used.
2) The observation period is 2 hours.
F. Applicable Formulas
1. Flows
Ht = K[f C,HJ
1=1
L°glO Vmax = (HT + 28.8)/31.7 or
Vmax = 8/706 + 0J084 (HT)
2. Waste Streams
Annual Average Concentration
£ Ci Qi
= ^
IQ,
4-21
-------
3. Emission Rates
Hourly ER (HER) = Flow rate (rrP/g) x organic
concentration (ppm)
x average molecule weight (Kg/g) x
conversion factors OR
Q [IC MW](.0416)(10^)
5 i=l
Yearly ER = HER x number of operating hours per year
4. Facility Rate
FER = ZEFjii or
FER= ERpVi + ERpv2 + ERpv3 +
4-22
-------
G. Leak Detection and Repair
equipment
pump
valve
compressor
Pressure RD
Flange
Sampling Connections
Systems
Open-ended Valves or
Lines
type of fluid
light liquid
heavy liquid
gas/vapor or
light liquid
heavy liquid
21 within 5 days
all types
light liquid or
heavy liquid
gas/vapor
all types
all types
all types
leak action
Monthly 10,000 5/15,tag
physical
21 within 5 days 10,000 5/15,tag
monthly 21
physical
10:000
sensor
10,000 5/15,tag
5/15,rag
failure 5/15/tas
physical
21 within 5 days 10,000 5/15,tag
500+bkgd 0/5,M2~l
physical
M21 within 5 days 10,000 5/15,tag
NDE
4-23
-------
Exceedances
Condenser alt. conc.
alt. temp.
Adsorber Reg. alt.
Fixed Reg
Adsorber Nonreg.
Thermal Incin
Catalytic Incin.
Boilers/Process
Heaters
Flares
[orgj > 20% above Design level
T out > 6° above Design level Temp
or T coolant > 6° C above DAT
Conc. [orgj exhaust > 20% above Design Conc
Past dates for carbon replacement
Schedule flow beyond Determined Time
Past dates for carbon replacement
Past dates of replacement
Beyond dates monitored manually for breakthrough
Above monitoring device readings
95/20 T > 28° below Design Avg. Temp
Alt. combustion T < 760°
Inlet T < 28° below Design Avg. Temp or
[T out - T in] < 80% Design Avg. Temp Diff.
Comb. T > 28° below Design Avg Comb
T position of vent stream to zone changes
Pilot flame not ignited
4-24
-------
I. Process Vent Control Device Monitoring
Control Device
Required Monitoring
Methods
Flares
Pilot light flame detection
Visible emissions
Tticnnocouples
Method 22(b)
Thermal Incinerator*
Combustion chamber icmpcnmitc downstream of
combustion zone
TlicniKvouplcs
Catalytic Incinerator?
Vent temperatures at nearest feasible point to
catalyst bed inlet and outlet
Thermocouples
Boilers <44 MW
Furnace temperature downstream of combustion
zone
Thennocouples
Boilers > 44 MW
A parameter that demonstrates good combustion
operating practices are being used
Thennocouples for
temperature monitor* lor CO
or NO^
Condensers
Concentration of organics in the exhaust vent OR
Coolant outlet orenhausi vem temperature
Nonmeihane hydroc;ubon
analyzer, Method 18 OR
Thermocouples, diul
thermometers
Carbon Adsorbers
^Trm77Tn7T777TmT7rmrmrT7T7777T777n
Concentration of organics in exhaust veni Oft
A parameter that demonstrates that the bed is
regenerated on a regular basis (for automatic
regeneration)
NonmeihBne hydrocarbon
analyzer, Method 16 OR
(Application specific)
l Unieu otheniiie indicated. iVm meihodi art not ipttifud by bctioas aiiA lA5.l03.Uf] and tfould tx rr;anU-tt nirt-vnfttet only,
b StKiifuiilly required by Sections tft*. 1032(f) ua
-------
Regulatory Decision Tree
SUBPART AA or BB
facility process
vent organic emission
rate > 3 Jb/hr?
Type oi equipment
Pressure
relief devices
;PRD) and
flanges
Compressors
sampling
connections and
open-ended lines
Pumps &
valves
facility process vent
organic emission rate > 3.1
ions per year
Leak detection
and repair
program
(LDAR)
Equipment
in
gas service
No
emission
reduction
required
Emission
reduction
required
service
Equipment
required as
specified in rules
Is the
equipment m
gas service?
PRD
&
flanges
Control
helow emission
rate limit
Non-
rotiiint
monitoring
f evidence
of leak
found
Operated
with no
detectable
Coruro! device &
dosed-vent system
with control device
monitoring
Equipment
in
gas service
VP>0
emissions
compound?
Monthly LDAR
with Method 21
Control
device
or process
changes
required to
meet emission
rale limit
Control
device
required
Is the total
concentration for
compounds with
(VP>0.3 kPa) > 20%
by weight?
95% control
efficiency
{minimum)
Liquid @
operating
conditions
Equipment is in
heavey-liquid
service
Equipment is in
light-liquid
service
• Monthly LDAR with Method
21 or alternative suls.
¦ Nonrouiinc monitoring if
evidence of leak found
4-26
-------
Environmental Protection Agincy
Pt. 60, App. A, Moth. 21
7.3.2 Calculation of Emission Rate Osing
Carbon Dioxide Correction. The COi con-
centration and the pollutant concentration
may be on either a dry basis or a wet basis,
but both concentrations must be on the
same basis for the calculations. Calculate
the pollutant emission rate using Equation
20-7 or 20-8:
100
E=C.F, Eq. 20-7
%CO,
100
E=GJ\ Eq. 20-«
%CO,.
where:
C.=Pollutant concentration measured on a
moist sample basis, ng/sm* (Ib/scf >.
%CO>.=Measured COi concentration meas-
ured on a moist sample basis, percent.
8. Bibliography
1. Curtis, F. A Method for Analyzing NO,
Cylinder Gases-Specific Ion Electrode Pro-
cedure, Monograph available from Emission
Measurement Laboratory, ESED, Research
Triangle Part, NC 27711. October 1978.
2. Slgsby, John E.. F. M. Black, T. A.
Bell&r, and D. L Klosterman. Chemilu-
mlnescent Method for Analysis of Nitrogen
Compounds In Mobile Source Emissions
(NO. NOt. and NHj). "Environmental Sci-
ence and Technology," 7:51-54. January
1973.
3. Shlgehara. R.T.. R.M. Neullcht. and
W.S. Smith. Validating Orsat Analysis Data
from Fossil Fuel-Fired Dnlta. Emission
Measurement Branch, Emission Standards
and Engineering Division. Office of Air
Quality Planning and Standards, U.S. Envi-
ronmental Protection Agency, Research Tri-
angle Parle. NC 27711. June 1078.
Method 21— DmumiATioH or Volatiu
Obgakic Compounds Leaks
1. Applicability and Principle
1.1 Applicability. This method applies to
the determination of volatile organic com-
pound (VOC) leaks from process equipment.
These sources include, but are not limited
to. valves, flanges and other connections,
pumps and compressors, pressure relief de-
vices, process drains, open-ended valves,
pump and compressor seal system degassing
vents, accumulator vessel vents, agitator
seals, and access door seals.
1.2 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 specifica-
tions and performance criteria contained In
Section 3. A leak definition concentration
based on a reference compound is specified
In each applicable regulation. This proce-
dure is intended to locate and classify leaks
only, and Is not to be used as a direct meas-
ure of mass emission rates from individual
sources.
2. Definition*
2.1 Leak Definition Concentration. The
local VOC concentration at the surface of a
leak source that indicates that a VOC emis-
sion (leak) is present. The leak definition is
an instrument meter reading based on a ref-
erence compound.
2.2 Reference Compound. The VOC spe-
cies selected as an Instrument calibration
basis for specification of the leak definition
concentration. (For example: If a leak defi-
nition concentration Is 10,000 ppmv as
methane, then any source emission that re-
sults in a local concentration that yields a
meter reading ol 10.000 on an Instrument
calibrated with methane would be classified
as a leak. In this example, the leak defini-
tion Is 10,000 ppmv, and the reference com-
pound Is methane.)
2.3 Calibration Gas. The VOC compound
used to adjust the instrument meter reading
to a known value. The calibration gas is usu-
ally the reference compound at a concentra-
tion approximately equal to the leak defini-
tion 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 repro-
ducibility, a difference between the source
surface concentration and the local ambient
concentration is determined. A difference
based on meter readings of less than a con-
centration corresponding to the minimum
readability specification indicates that a
VOC emission (leak) Is not present. (For ex-
ample, if the leak definition In a regulation
Is 10,000 ppmv, then the allowable Increase
In surface concentration versus local ambi-
ent concentration would be SOO ppmv based
on the Instrument meter readings.)
2.5 Response Factor. The ratio of the
known concentration of a VOC compound
to the observed meter reading when meas-
ured using an instrument calibrated with
the reference compound specified in the ap-
plication regulation.
2.6 Calibration Precision. The degree of
agreement between measurements of the
same known value, expressed as the relative
percentage of the average difference be-
tween the meter readings and the known
concentration to the known concentration.
4-27
-------
Pt. 60, App. A, M«th. 21
40 CFR Ch. I (7-1-89 Edition)
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 correspond-
ing final value Is reached as displayed on
the Instrument readout meter.
3. Apparatus
3.1 Monitoring Instrument.
3.1.1 Specifications.
a. The VOC instrument detector shall re-
spond to the compounds being processed.
Detector types which may meet this re-
quirement include, but are not limited to.
catalytic oxidation, flame ionization, infra-
red absorption, and photolonlzatlon.
b. The Instrument shall be capable of
measuring the leak definition concentration
specified In the regulation.
c. The scale of the Instrument meter shall
be readable to ±5 percent of the specified
leak definition concentration.
d. The instrument shall be equipped with
a pump so that a continuous sample Is pro-
vided to the detector. The nominal sample
flow rate shall be ft to 3 liters per minute.
e. The instrument shall be Intrinsically
safe for operation in explosive atmospheres
as defined by the applicable U.SJL stand-
ards (e.g.. National Electrical Code by the
National Fire Prevention Association).
3.1.2 Performance Criteria.
a. The instrument response factors for the
lndivldal compounds to be measured must
be less than 10.
b. The instrument response time must be
equal to or less than 30 seconds. The re-
sponse time must be determined for the in-
strument 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 pa-
rameter is given in Section 4.4.
3.1.3 Performance Evaluation Require-
ments.
a. A response factor must be determined
for each compound that is to be measured,
either by testing or from reference sources.
The response factor tests are required
before placing the analyzer into service, but
do not have to be repeated at subsequent in-
tervals.
b. The calibration precision test 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 prior
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 re-
quired prior to further use.
3.2 Calibration Gases. The monitoring in-
strument is calibrated In terms of parts per
million by volume (ppmv) of the reference
compound specified in the applicable regu-
lation. The calibration gases required for
monitoring and instrument performance
evaluation are a zero gas (air. less than 10
ppmv VOC) and a calibration gas In air mix-
ture approximately equal to the leak defini-
tion specified in the regulation. If cylinder
calibration gas mixtures are used, they must
be analyzed and certified by the manufac-
turer to be within ±2 percent accuracy, and
a shelf life must be specified. Cylinder
standards must be either reanalyzed or re-
placed at the end of the specified shelf life.
Alternately, calibration gases may be pre-
pared 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 re-
placed each day of use unless it can be dem-
onstrated that degradation does not occur
during storage.
Calibrations may be performed using a
compound other than the reference com-
pound If a conversion factor is determined
for that alternative compound so that the
resulting meter readings during source sur-
veys can be converted to reference com-
pound results.
4. Procedures
4.1 Pretest Preparations. Perform the in-
strument evaluation procedures given in
Section 4.4 if the evaluation requirements
of Section 3.1.3 have not been met.
4.2 Calibration Procedures. Assemble and
start up the VOC analyzer according to the
manufacturer's Instructions. After the ap-
propriate warmup period and zero internal
calibration procedure, introduce the calibra-
tion gas into the instrument sample probe.
Adjust the Instrument meter readout to cor-
respond to the calibration gas value.
Note: If the meter readout cannot be ad-
justed to the proper value, a malfunction of
the analyzer is indicated and corrective ac-
tions are necessary before use.
4.3 Individual Source Surveys.
4.3.1 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 inter-
face where leakage is indicated until the
maximum meter reading is obtained. Leave
the probe Inlet at this maximum reading lo-
cation for approximately two times the in-
strument response time. If the maximum
observed meter reading is greater than the
leak definition in the applicable regulation,
record and report the results as specified in
the regulation reporting requirements. Ex-
amples of the application of this general
technique to specific equipment types are:
4-28
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Environmental Protection Agency
Pt. 60, App. A, Math. 21
el Valves—The most common source of
leaks from valves is at the seal between the
stem and housing. Place the probe at the
Interlace where the stem exits 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 the periphery. In addition, survey
valve housings of multipart assembly at the
surface of all Interfaces where a leak could
occur.
b. Flanges and Other Connections—For
welded flanges, place the probe at the outer
edge of the flange-gasket interface and
sample the circumference of the flange.
Sample other types of nonpermanent joints
(such as threaded connections) with a simi-
lar traverse.
c. Pumps and Compressors—Conduct a cir-
cumferential 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 1 cm of the
shaft-seal Interface for the survey. II 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.
d. Pressure Relief Devices—The configura-
tion of most pressure relief devices prevents
sampling at the sealing seat Interface. For
those devices equipped with an enclosed ex-
tension. or horn, place the probe inlet at ap-
proximately the center of the exhaust area
to the atmosphere.
e. Process Drains—For open drains, place
the probe Inlet at approximately the center
of the area open to the atmosphere. For
covered drains, place the probe at the sur-
face of the cover Interface and conduct a pe-
ripheral traverse.
f. Open-Ended Lines or Valves—Place the
probe Inlet at approximately the center of
the opening to the atmosphere.
g. Seal System Degassing Vents and Accu-
mulator Vents—Place the probe inlet at ap-
proximately the center of the opening to
the atmosphere.
h. Access Door Seals—Place the probe
inlet at the surface of the door seal inter-
face and conduct a peripheral traverse.
4.3.2 Type II—"No Detectable Emission".
Determine the local ambient concentra-
tion 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 23 centimeters. Then move the
probe Inlet to the surface of the source and
determine the concentration described In
4.3.1. The difference between these concen-
trations determines whether there are no
detectable emissions. Record and report the
results as specified by the regulation.
For those cases where the regulation re-
quires a specific device installation, or that
specified vents be ducted or piped to a con-
trol device, the existence of these conditions
shall be visually confirmed. When the regu-
lation also requires that no detectable emis-
sions exist, visual observations and sampling
surveys are required. Examples of this tech-
nique are:
(a) Pump or Compressor Seals—If applica-
ble. determine the type of shaft seal Pre-
form a survey of the local area ambient
VOC concentration and determine if detect-
able emissions exist as described above.
(b) Seal System Degassing Vents; Accumu-
lator Vessel Vents, Pressure Relief Devices—
If applicable, observe whether or not the ap-
plicable ducting or piping exists. Also, deter-
mine if any sources exist In the ducting or
piping where emissions could occur prior to
the control device. If the required ducting
or piping exists and there are no sources
where the emissions could be vented to the
atmosphere prior to the control device, then
It Is presumed that no detectable emissions
are present. If there are sources In the duct-
ing or piping where emissions could be
vented or sources where leaks could occur,
the sampling surveys described In this para-
graph shall be used to determine If detecta-
ble emissions exist.
4.3.3 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 tem-
peratures greater than the boiling point or
less than the freezing point of the soap solu-
tion. that do not have open areas to the at-
mosphere that the soap solution cannot
bridge, or that do not exhibit evidence of
liquid leakage. Sources that have these con-
ditions present must be surveyed using the
Instrument techniques of 4.3.1 or 4.3.2.
Spray a soap solution over all potential
leak sources. The soap solution may be a
commercially available leak detection solu-
tion or may be prepared using concentrated
detergent and water. A pressure sprayer 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 pre-
sumed to have no detectable emissions or
leaks as applicable. If any bubbles are ob-
served. the Instrument techniques of 4.3.1 or
4.3.2 shall be used to determine If a leak
exists, or If the source has detectable emis-
sions, as applicable.
4.4 Instrument Evaluation Procedures. At
the beginning of the Instrument perform-
ance evaluation test, assemble and start up
the instrument according to the manufac-
4-29
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Pt. 60, App. A, Meth. 22
40 CFR Ch. I (7-1-89 Edition)
Hirer's Instructions for recommended
warmup period and preliminary adjust'
ments.
4.4.1 Response Factor. Calibrate the in-
strument with the reference compound as
specified In the applicable regulation. For
each organic species that is to be measured
during individual source surveys, obtain or
prepare a known standard In air at a con-
centration of approximately 80 percent of
the applicable leak definition unless limited
by volatility or explosivlty. in these cases,
prepare a standard at 90 percent of the
saturation concentration, or 70 percent of
the lower explosive limit, respectively. In-
troduce this mixture to the analyzer and
record the observed meter reading. Intro-
duce zero air until a stable reading Is ob-
tained. 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 re-
sponse factor.
Alternatively. If response factors have
been published for the compounds of inter-
est for the instrument or detector type, the
response factor determination is not re-
quired, and existing results may be refer-
enced. Examples of published response fac-
tors tor flame ionization and catalytic oxi-
dation detectors are included In Section 5.
4.4.2 Calibration Precision. Make a total
of three measurements by alternately using
zero gas and the specified calibration gas.
Record the meter readings. Calculate the
average algebraic difference between the
meter readings and the known value. Divide
this average difference by the known cali-
bration value and mutiply by 100 to express
the resulting calibration precision as a per-
centage.
4.4.3 Response Time. Introduce zero gas
into the instrument sample probe. When
the meter reading has stabilized, switch
quickly to the specified calibration gas.
Measure the time from switching to when
60 percent of the final stable reading is at-
tained. Perform this test sequence three
times and record the results. Calculate the
average response time.
5. Bibliography
5.1 DuBose, DA, and G.E. Harris. Re-
sponse Factors of VOC Analyzers at a Meter
Reading of 10,000 ppmv for Selected Organ-
ic Compounds. U.S. Environmental Protec-
tion Agency, Research Triangle Park, NC.
Publication No. EPA 600/2-41-051. Septem-
ber 1981.
5.2 Brown. G.E., et al. Response Factors
of VOC Analyzers Calibrated with Methane
for Selected Organic Compounds. U.S. Envi-
ronmental Protection Agency, Research Tri-
angle Park. NC. Publication No. EPA 600/2-
81-022. May 1981.
5.3 DuBose. D.A.. et al. Response of Port-
able VOC Analyzers to Chemical Mixtures.
U.S. Environmental Protection Agency. Re-
search Triangle Park, NC. Publication No.
EPA 600/2-81-110. September 1981.
Method 22—Visoal Determination or Fu-
gitive Emissions From Materiai
SoURCSS AND SXOKX EMISSIONS ntOM
Flakxs
1. Introduction
This method involves the visual determi-
nation of fugitive emissions, i.e.. emissions
not emitted directly from a process stack or
duct Fugitive emissions Include emissions
that (1) escape capture by process equip-
ment exhaust hoods; (2) are emitted during
material transfer, (3) are emitted from
buildings housing material processing or
handling equipment: and (4) are emitted di-
rectly from process equipment. This method
is used also to determine visible smoke emis-
sions from flares used for combustion of
waste process materials.
This method determines the amount of
time that any visible emissions occur during
the observation period, i.e.. the accumulated
emission time. This method does not require
that the opacity of emissions be determined.
Since this procedure requires only the de-
termination of whether a visible emission
occurs and does not require the determina-
tion of opacity levels, observer certification
according to the procedures of Method 9 are
not required. However, It Is necessary that
the observer is educated on the general pro-
cedures for determining the presence of visi-
ble emissions. As a minimum, the observer
must be trained and knowledgeable regard-
ing the effects on the visibility of emissions
caused by background contrast, ambient
lighting, observer position relative to light-
ing, wind, and the presence of uncomblned
water (condensing water vapor). This train-
ing is to be obtained from written materials
found in References 7.1 and 7.2 or from the
lecture portion of the Method 9 certifica-
tion course.
2. Applicability and Principle
2.1 Applicability. This method applies to
the determination of the frequency of fugi-
tive emissions from stationary sources (lo-
cated indoors or outdoors) when specified as
the test method for determining compliance
with new source performance standards.
This method also is applicable for the de-
termination of the frequency of visible
smoke emissions from flares.
2.2 Principle. Fugitive emissions pro-
duced during material processing, handling,
and transfer operations or smoke emissions
from flares are visually determined by an
observer without the aid of instruments.
3. Definition*
4-30
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Leak Detection Levels For Regulated Pieces Of Equipment*
Equipment Service
Gas/Vapor Light Liquid Heavy Liquid
Prtssurt NDE lO^OOOppm IO,QQGppm
devices
Coir pressors frith - — — ¦ NDE - -
scab
Pumps lOJKOppm 10,000ppm
Vilvea — ' ' l&,0Q0ppm ¦ ¦ ¦ —¦ ----- ¦ . . -¦
Flanges-and oeher
Samplinf connecting
Opcn-rndcd valves
*frtqw»cj: Ckud-ttu ijwflu - wjui: ail other i - momhij
Asiittf PMD U tasfrapor - OS. M 3J: oft Mbe't - if >5, W(
4-31
6 US. GOVERNMENT PRINTING OfFICE: IWI -
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