United States Enforcement and EPA/305/B-98/011
Environmental Protection Compliance Assurance December 1998
Agency	(2224A)	
v>EPA Inspection Manual:
Federal Equipment Leak
Regulations for the
Chemical Manufacturing
Industry
Volume II: Chemical
Manufacturing Industry
Regulations
EPA Office of Compliance
Chemical, Commercial
Services, and Municipal
Division

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ABSTRACT
The purpose of this manual is to enhance an inspector's ability to conduct more
complete and effective inspections at facilities in the chemical industry that are subject
to federal equipment leak regulations. Equipment leak standards are designed to reduce
or eliminate emissions of volatile organic compounds (VOCs), volatile hazardous air
pollutants (VHAPs), and organic HAPs from the miles of piping and numerous
components found in chemical manufacturing processes.
This document is divided into three volumes. The first volume is a manual for
inspectors; the second and third volumes describe regulations that apply to the chemical
manufacturing and the petroleum refining industries, respectively.
Volume I has five chapters dedicated to helping an inspector:
•	Chapter 1 states the goals, background, approaches to rule enforcement, and
organization of the document.
•	Chapter 2 addresses applicability determinations: ensuring the correct rules are
being complied with at a facility, determining whether all appropriate
components have been identified, and ensuring the components are properly
classified by service.
•	Chapter 3 discusses reporting and recordkeeping requirements for NSPS,
NESHAP, HON, and RCRA (recordkeeping only), and strategies for reviewing
reports and records.
•	Chapter 4 covers on-site inspections: walk-throughs and inspections with the
inspector monitoring for leaks. It addresses pre-inspection activities, timing and
scope, interviews, leak monitoring evaluations, inspections of the process area
and records, and post-inspection reviews and reports.
•	Chapter 5 discusses recommended inspection techniques and procedures.
Volume II tackles the equipment leak regulations applicable to the chemical
manufacturing industry.
•	The first three appendices of Volume II summarize the regulations of 40 CFR
Part 60 Subpart VV, Part 61 Subparts J and V, Part 63 Subparts H and I, Part
264 Subpart BB, and Part 265 Subpart BB; detail the differences among the
regulations; and give the requirements grouped by component.
•	Appendix D describes the regulated equipment.
•	Appendix E contains the "Method 21" approach to leak detection.
•	Appendix F lists chemical manufacturing processes that are subject to HON.
•	Appendix G lists organic HAPs that are subject to HON.
•	Appendix H lists manufacturing processes and associated organic HAP
emissions that are subject to HON.

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Volume III contains the equipment leak regulations applicable to the petroleum refining
industry.
• The three appendices of Volume in summarize the regulations of 40 CFR Part
60 Subparts DDD, GGG, KKK, and QQQ, and Part 63 Subpart CC; detail the
differences among the regulations; and give the requirements grouped by
component.

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CONTENTS
VOLUME II: CHEMICAL MANUFACTURING INDUSTRY REGULATIONS
Page
Appendix A Equipment Leak Regulations: Side-by-Side Comparisons . . . A-I
Appendix B Equipment Leak Regulations: Summary of Differences .... B-l
Appendix C Equipment Leak Regulations: Summary by Component .... C-I
Appendix D Regulated Equipment 	D-I
Appendix E Method 21 (40 CFR 60, Appendix A)	E-l
Appendix F Chemical Manufacturing Processes Subject to HON
Standards (40 CFR 63, Subpart H)	F-l
Appendix G Organic HAPs Subject to HON Standards (Subpart H) .... G-l
Appendix H Manufacturing Processes and Organic HAPs Subject to
HON Standards (Subpart I)	H-l

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CONTENTS (continued)
VOLUME I: INSPECTION MANUAL
Chapter 1
Chapter 2
Chapter 3
Chapter 4
Chapter 5
Bibliography
Statement of Goals, Background, Approaches to Rule
Enforcement, and Organization of Document
Applicability
Compliance/Inspection Through Reports and Recordkeeping
Compliance/Assessment Through On-Site Inspections
Recommended Inspection Techniques and Procedures
VOLUME III: PETROLEUM REFINING INDUSTRY REGULATIONS
Appendix A Equipment Leak Regulations: Side-by-Side Comparisons
Appendix B Equipment Leak Regulations: Summary of Differences
Appendix C Equipment Leak Regulations: Summary by Component

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APPENDIX A
EQUIPMENT LEAK REGULATIONS: SIDE-BY-SIDE COMPARISONS
page
GENERAL ASPECTS OF RULE
Applicability		A-l
Exemptions 		A-2
Definitions		A-2
Equipment Identification		A-5
Compliance Demonstrations 		A-5
Method of Compliance Determination	A-6
Requirements When More than One Standard Applies	A-6
SPECIFIC COMPONENT SUMMARIES
Valves, Gas/Vapor or Light Liquid Service 		A-7
Valves, Heavy Liquid Service 		A-10
Alternative Standards for Valves		A-l 1
Pumps, Light Liquid Service		A-13
Pumps, Heavy Liquid Service 	A-15
Pressure Relief Devices, Gas/Vapor Service		A-17
Pressure Relief Devices, Light Liquid or Heavy Liquid Service	A-18
Compressors 		A-19
Sampling Connections Systems	A-21
Open-Ended Valves or Lines	A-22
Flanges and Connectors (All Services)	A-23
Connectors, Gas/Vapor or Light Liquid Service	A-24
Connectors, Heavy Liquid Service 		A-26
Agitators, Gas/Vapor Service or Light Liquid Service	A-27
Agitators, Heavy Liquid Service		A-30
Instrumentation Systems	A-31
Product Accumulator Vessels	A-32
Surge Control Vessels and Bottoms Receivers	A-33
Closed-Vent Systems and Control Devices	A-34
DELAY OF REPAIR	A-37
QUALITY IMPROVEMENT PROGRAMS		A-39
EQUIVALENCE OF (or ALTERNATIVE) MEANS OF EMISSIONS LIMITATION
General	 A-45
Batch Processes	A-46

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Enclosed-Vented Process Units 	A-48
TEST METHODS AND PROCEDURES	A-49
RECORDKEEPING REQUIREMENTS	A-54
REPORTING REQUIREMENTS 	 A-67

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SUMMARY OF REGULATIONS
page A-l

REGULATION
General Aspects of Rule
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
APPLICABILITY
All equipment within a
process unit in the
synthetic organic
manufacturing industry that
commences construction,
reconstruction, or
modification after 1/5/81
A list of SOCMI chemicals
produced as intermediates
or final products by
process units is provided to
determine applicability
Equipment that is operated
in benzene service.
Equipment operated in
volatile HAP (VHAP)
service after the date for
which part 61 regulations
have been promulgated
Equipment in organic HAP
service operated at least
300 hours per year at
facilities for which part 63
regulations have been
adopted and that cross-
reference this subpart
A list of organic HAP is
provided to determine
applicability.
Equipment in organic HAP
service (see Definitions)
operated at least 300 hours
per year in the following
types of processes Styrene-
butadiene rubber production,
polybutadiene rubber
production, processes
producing five specific
agricultural chemicals,
processes producing six
specific types of
polymers/resins or other
chemicals; pharmaceutical
processes using carbon
tetrachloride or methylene
chloride, and five specified
polymers/resins."
Specific HAPs are
designated for determining
applicability
Equipment at facilities that
treat, store, or dispose of
hazardous wastes that
contains or contacts,
hazardous waste with
organic concentrations of at
least 10 percent by weight
that are managed in units
subject (o the permitting
requirements of part 270 or
hazardous waste recycling
units located at such
facilities otherwise subject
to the permitting
requirements of part 270

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SUMMARY OF REGULATIONS
page A-2
General Aspects of Rule
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR pan 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
EXEMPTIONS
Any affected facility with
design capacity to produce
less than 1,000 Mg per
year
Any affected facility that
produces heavy liquid
chemicals only from heavy
liquid feed or raw
materials
Any affected facility that
produces beverage alcohol
Any affected facility that
has no equipment in VOC
service (Must maintain
certain records
demonstrating exemption
applies)
Coke by-product plants
Any equipment in benzene
service located at plant
designed to produce or use
less than 1,000 Mg of
benzene per year
Any process unit that has
no equipment in benzene
service
Exempt from part 60 if
subject to part 61
None specified
Research and development
facilities
Exempt from part 60 and
from part 61 if provisions
of Part 63 are effective
Petroleum refining process
units
Ethylene process units
Equipment subject to
subpart which does not
emit HAPs
CMPUs located at coke
by-product recovery
plants
Solvent reclamation,
recovery, or recycling
operations at hazardous
waste TSDFs that require a
40 CFR part 270 permit
that are not part of a
SOCMI CMPU
Facilities that do not have
the designated HAP(s) need
only document the basis for
this determination
Research and development
facilities
Exempt until no later than
April 22, 1997, if plant site
emits less than 10 tpy of any
individual HAP and less
than 25 tpy of any
combination of HAP
None specified
DEFINITIONS
"In gas/vapor service"
The piece of equipment
contains process fluid that
is in gaseous slate at
operating conditions
A piece of equipment contains process fluid that is in the
gaseous state at operating conditions
A piece of equipment in organic hazardous air pollutant
(HAP) service contains a gas or vapor at operating
conditions
The piece of equipment
contains or contacts a
hazardous waste stream (hat
is in the gaseous state at
operating conditions
"In heavy liquid
service"
The piece of equipment is
not in gas/vapor service or
in light liquid service
Not applicable
A piece of equipment in organic HAP service is not in
gas/vapor service or in light liquid service
The piece of equipment is
not in gas/vapor service or
in light liquid service

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SUMMARY OF REGULATIONS
page A-3

REGULATION
General Aspects of Rule
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
DEFINITIONS
(continued)






"In light liquid service"
The piece of equipment
contains a liquid that meets
the following conditions
1	The vapor pressure of
one or more of the
components is greater than
0 3 kPa at 20ฐC,
2	The total concentration
of pure components having
a vapor pressure greater
than 0 3 kPa at 20ฐC is
equal to or greater than 20
percent by weight; and
3	The fluid is a liquid at
operating conditions.
Not applicable

A piece of equipment in organic HAP service contains a
liquid that meets the following conditions
1. The vapor pressure of one or more of the organic
compounds is greater than 0 3 kPa at 20ฐC.
2	The total concentration of the pure organic compounds
having a vapor pressure greater than 0 3 kPa at 20ฐC is
equal to or greater than 20 percent by weight of the total
process stream, and
3	The fluid is a liquid at operating conditions
The piece of equipment
contains or contacts ,a waste
stream that meets the
following conditions
1	The vapor pressure of
one or more of the
components is greater than
0 3 kPa at 20"C,
2	The total concentration
of pure components having
a vapor pressure greater
than 0 3 kPa at 20ฐC is
equal to or greater than 20
percent by weight, and
3	The fluid is a liquid at
operating conditions
"In liquid service"
Not applicable
A piece of equipment is not in gas/vapor service
A piece of equipment in organic HAP service is not in
gas/vapor service
Not applicable
"In VOC service"
The piece of equipment
contains or contacts a
process fluid that is at least
10 percent VOC by
weight
The piece of equipment contains or contacts a process
fluid that is at least 10 percent VOC by weight and the
piece of equipment is not in heavy liquid service (as
defined under 40 CFR part 60, subpart VV)
The piece of equipment contains or contacts a process fluid
that is at least 10 percent VOC by weight and the piece of
equipment is not in heavy liquid service (as defined under
40 CFR part 60, subpart VV)
Not applicable
"In VHAP service"
Not applicable
A piece of equipment either contains or contacts a fluid
(liquid or gas) that is at least 10 percent by weight a
volatile hazardous air pollutant (VHAP)
Not applicable.
Not applicable

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SUMMARY OF REGULATIONS
page A-4
General Aspects of Rule
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart 5
40 CFR part 61,
Subpart V
40 CFR part 63.
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
DEFINITIONS
(continued)
"In organic hazardous
air pollutant or in
organic (HAP) service"
Not applicable
Not applicable
A piece of equipment
either contains or contacts
a fluid (liquid or gas) (hat
is at least 5 percent by
weight total organic HAP
A piece of equipment either
contains or contacts a fluid
(liquid or gas) that is at least
5 percent by weight of the
designated organic HAP
listed in ง63 190(b) of this
subpart
Not applicable
"In benzene service"
Not applicable
A piece of equipment
contains or contacts a fluid
(liquid or gas) that is at
least 10% benzene by
weight
Not applicable
Not applicable
Not applicable
Equipment
Each pump, compressor,
pressure relief device,
sampling connection
system, open-ended valve
or line, valve, and flange
or other connector in VOC
service and any devices or
systems required by this
subpart
Each pump, compressor, pressure relief device, sampling
connection system, open-ended valve or line, valve, flange
or other connector, product accumulator vessel in VHAP
service, and any devices or systems required by this
subpart
Each pump, compressor, agitator, pressure relief device,
sampling connection system, open-ended valve or line,
valve, connector, surge control vessel, bottoms receiver,
and instrumentation system in organic HAP service, and
any devices or systems required by this subpart
Each valve, pump,
compressor, pressure relief
device, sampling connection
system, open-ended valve or
line, or flange or any
devices or systems required
by this subpart
Process Unit (hazardous
waste management unit
for 40 CFR parts 264
and 265)
Components assembled to
produce, as intermediate or
final products, one or more
of the chemicals specified
in ง60 489 A process unit
can operate independently
if supplied with sufficient
feed or raw materials and
sufficient storage facilities
for the product
Equipment assembled to produce a VHAP or its
derivatives as intermediate or final products, or equipment
assembled to use a VHAP in the production of a product
A process unit can operate independently if supplied with
sufficient feed or raw materials and sufficient product
storage facilities
A chemical manufacturing process unit as defined in
subpart F of this part, a process unit subject to the
provisions of subpart I of this part, or a process unit subject
to another subpart in 40 CFR part 63 that references this
subpart'
A contiguous area of land
on or in which hazardous
waste is placed, or the
largest area in which there
is significant likelihood of
mixing hazardous waste
constituents in the same
area'

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SUMMARY OF REGULATIONS
page A-5

REGULATION
Genera! Aspects of Rule
40 CFR part 60,
Subpart VV
40 CFR pan 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
DEFINITIONS
(concluded)






Repaired
Equipment is adjusted, or
otherwise altered, in order
to eliminate a leak as
indicated by one of the
following an instrument
reading of 10,000 ppm or
greater, indications of
liquids dripping, or
indication by sensor that a
seal or barrier fluid has
failed
Equipment is adjusted, or otherwise altered, to eliminate a
leak
Equipment is adjusted, or otherwise altered, to eliminate a
leak as defined in the applicable sections of this subpart and
unless otherwise specified in the applicable provisions of
this subpart, is monitored to verify that emissions are below
the applicable leak definition
Equipment is adjusted, or
otherwise altered, to
eliminate a leak
First Attempt at Repair
To take rapid action for the
purpose of stopping or
reducing leakage of
organic material to
atmosphere using best
practices
To take rapid action for the purpose of stopping or
reducing leakage of organic material to atmosphere using
best practices
To take action for the purpose of stopping or reducing
leakage of organic material to atmosphere followed by
monitoring to verify that the leak is repaired unless the
owner or operator determines by other means that the leak
is not repaired
To take rapid action for the
purpose of stopping or
reducing leakage of organic
material to atmosphere
using best practices
EQUIPMENT
IDENTIFICATION
(see also Recordkeeping
Requirements)
Not specified
Marked in manner such that it can be readily distinguished
from other pieces of equipment
Marked in manner such that it can be readily distinguished
from equipment not subject to this subpart (does not require
physical tagging except for leaking equipment)
Marked in manner such that
it can be readily
distinguished from other
pieces of equipment
COMPLIANCE
DEMONSTRATIONS
Performance test required
for all equipment within
180 days of initial startup
Performance test required for all equipment within 180
days of initial startup
For existing sources, shall be in compliance within 90
days after the effective date of the applicable standard
For new sources, shall be in compliance upon effective
date of the applicable standard
Performance test required within 180 days of initial startup
For existing sources, shall be in compliance no later than
the following dates
Group I October 24, 1994
Group II January 23, 1995
Group III April 24, 1995
Group IV July 24, 1995
Group V October 23, 1995
For new sources, shall be in compliance upon initial
startup, or the effective date of the applicable standard
Not specified

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SUMMARY OF REGULATIONS
page A-6

REGULATION
General Aspects of Rule
40 CFR part 60,
Subpart VV
40 CFR part 61.
Subpart J
40 CFR part 61,
Subpart V
40 CFR pan 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR pari 265,
Subpart BB
METHOD OF
COMPLIANCE
DETERMINATION
Review of records and
reports, review of
performance test results,
and inspections
Review of records, review of performance test results,
and inspections
Review of records and reports, review of performance test
results, and inspections
Not specified
REQUIREMENTS
WHEN MORE THAN
ONE STANDARD
APPLIES
Not specified
A source subject to this
subpart that is also subject
to 40 CFR part 60 only
will be required to comply
with the provisions of this
subpart
A source subject to this
subpart that is also subject
to 40 CFR part 60 only
will be required to comply
with the provisions of this
subpart
Equipment subject to this subpart that are also subject to 40
CFR part 60 or 40 CFR part 61 will be required to comply
only with the provisions of this subpart
Any facility subject to tins
subpart and 40 CFR part
60, subpart VV or 40 CFR
part 61, subpart V, may
elect to comply with this
subpart or the provisions >n
part 60 or 61 to the extent
that the documentation
under the regulation at part
60 or part 61 duplicates the
documentation required
under this subpart
" Processes producing styrene-butadiene rubber (butadiene and styrene emissions only) Processes producing polybutadtene rubber (butadiene emissions only) Processes producing the following agricultural chemicals
(butadiene, carbon tetrachloride, methylene chloride, and ethylene dichloride emissions only) Captafol (R), Captan (R), Chlorothalonil, Dacthal, and Tordon (R) acid Processes producing the following polymers/resins
and other chemicals (carbon tetrachloride, methylene chloride, tetrachloroethylene, chloroform, and ethylene dichloride emissions only) Hypalon (R), Oxybisphenoxarsine/l,3-dnsocyanate [OBPA (R)j, polycarbonates,
polysulfide rubber, chlorinated paraffins, and symmetrical tetrachloropyridine Pharmaceutical production processes using carbon tetrachloride or methylene chloride (carbon tetrachloride and methylene chloride emissions
only) Processes producing the following polymers/resins and other chemicals (butadiene emissions only) tetrahydrophthalic anhydride (THPA), melhlymethacrylate-buiadiene styrene resins (MBS), butadiene-furiural cotrrmer,
methlymethacrylate-acrylomtrile-butadiene-styrene (MABS) resins, and ethylidene norbornene
" "Chemical manufacturing process unit" means the equipment assembled and connected by pipes or ducts to process raw materials and to manufacture an intended product A CMPU consists of more than one unit operation
For the purposes of this subpart, chemical manufacturing process unit includes air oxidation reactors and their associated product separators and recovery devices; reactors and their associated product separators and recovery
devices, distillation units and dieir associated distillate receivers and recovery devices, associated unit operations (as defined in this section) and associated recovery devices, and any feed, intermediate, and product storage
vessels, product transfer racks, and connected ducts and piping A chemical manufacturing process unit includes pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves or
lines, valves, connectors, instrumentation systems, and control devices or systems A chemical process manufacturing unit is identified by its primary product
c Examples of hazardous waste management units include a surface impoundment, a waste pile, a land treatment area, a landfill cell, an incinerator, a tank and its associated piping and underlying containment system and
a container storage area A container alone does not constitute a unit, the unit includes containers and the land or pad upon which they are placed

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SUMMARY OF REGULATIONS	page A-
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE
Standards
Monitor monthly
After two consecutive months of no leaks, a
valve may be monitored quarterly
If leak detected, monitor valve monthly until
leak is not detected for two consecutive
months
Monitor monthly
After two consecutive months of no leaks, a
valve may be monitored quarterly
If leak detected, monitor valve monthly until
leak is not detected for two consecutive
months
In Phases 1 and II, monitor each valve
quarterly
In Phase III, monitoring frequency based on
percent valves found leaking
Percent Leaking Monitonna Freauencv
2 Monthly or implement a
quality implementation
plan (QIP)
<	2 Quarterly
<	1 Quarterly or once every
2 quarters
0.5 Quarterly or once every
4 quarters
Monitor monthly
After two consecutive months of no leaks, a
valve may be monitored quarterly
If leak detected, monitor valve monthly until
leak is not detected for two consecutive
months




(If i>2% leaking valves at a plant site with
less than 250 valves in organic HAP service-
monitor quarterly )





Existing Sources






Phase I begins on compliance date





Phase II begins no later than one year after
(lie compliance date





Phase III begins no later than 2 'A years
after the compliance date


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SUMMARY OF REGULATIONS
page A
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE (continued)
Standards
(concluded)



New Sources
Phase I this phase is not applicable
Phase II begins upon facility startup
Phase III begins no later than one year after
initial startup

Leak
Definition
10,000 ppm
10,000 ppm
Phase I 10,000 ppm
Phase II 500 ppm
Phase III 500 ppm
10,000 ppm
Repair
Repair as soon as practicable, no later than
15 calendar days after detection
Repair as soon as practicable, no later than
15 calendar days after detection
Repair as soon as practicable, no later than
15 calendar days after detection
Repair as soon as practicable, no later than
15 calendar days after detection

First attempt within 5 calendar days of
detection
First attempt within 5 calendar days of
detection
First attempt within 5 calendar days of
detection
First attempt within 5 calendar days of
detection




When repaired, monitor at least once within
first 3 months after repair

First Attempt
at Repair
Practices
Best practices include, but are not limited to
-	tightening of bonnet bolls
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited
to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited to
-	tightening of bonnet bolls
-	replacement of bonnet bolts
-	lightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing

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SUMMARY OF REGULATIONS
page A
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)
Exemptions
Equipment in vacuum service
"No detectable emissions" valves less than
500 ppm above background
"Unsafe to monitor" valves written plan to
monitor as frequently as practicable during
safe to monitor times
"Difficult to monitor" valves written plan to
monitor at least once per year No more than
3 0 percent of valves in affected facility can
be designated as difficult to monitor
Equipment in vacuum service
"No detectable emissions" valves less than
500 ppm above background
"Unsafe to monitor" valves written plan to
monitor as frequently as practicable during
safe to monitor times
"Difficult to monitor" valves written plan
to monitor at least once per year
Equipment in vacuum service
Equipment operated fewer than 300 hours per
year
"Unsafe to monitor" valves written plan to
monitor as frequently as practicable during
safe to monitor times
"Difficult to monitor" valves written plan to
monitor at least once per year. No more than
3 0 percent of valves in new facility can be
designated as difficult to moniior
Equipment located at plant sites with fewer
than 250 valves is exempt from monthly
monitoring; instead monitor once per quarter
or comply with percent leak requirements for
< 1% or 0 5%, as applicable
Equipment in vacuum service
"No detectable emissions" valves less than
500 ppm above background
"Unsafe to monitor" valves written plan to
monitor as frequently as practicable during
safe to monitor times
"Difficult to monitor" valves written plan to
monitor at least once per year
No external activating mechanism in contact
with hazardous waste stream, is tested for
compliance initially, annually, and as
requested by the Regional Administrator
Valves designated as difficult to monitor at
hazardous waste management units in
operation prior to June 21, 1990, and
owner/operator follows written plan that
requires monitoring of valves at least once
per calendar year

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SUMMARY OF REGULATIONS
page A-10
Specific
Component
Summaries
REGULATION
40 CFR pari 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63.
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
VALVES. HEAVY LIQUID SERVICE
Standards
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method
Not applicable
Monitoring of potential leaks within S
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, or other detection method
Monitoring of potential teaks within 5
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, or other detection method
Leak
Definition
10,000 ppm
Not applicable
Monitoring 500 ppm
10,000 ppm
Repair
Repair as soon as practicable, no later than
IS calendar days after detection
First attempt within 5 calendar days of
detection
Not applicable
Repair as soon as practicable, no later than
IS calendar after detection
First attempt within 5 calendar days of
detection
For equipment that are not monitored
(Method 21), repair shall mean that visual,
olfactory or other indications of a leak have
been eliminated, no bubbles are observed at
potential leak sites during lead check with
soap solution, or system will hold a test
pressure
Repair as soon as practicable, no later than
15 calendar days after detection
First attempt within 5 calendar days of
detection
First Attempl
at Repair
Practices
Best practices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolls
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Not applicable
Best practices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolls
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Exemptions
Equipment in vacuum service
Not applicable
Equipment in vacuum service
Equipment operated fewer than 300 hours per
year
Equipment in vacuum service

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SUMMARY OF REGULATIONS
page A-11
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
ALTERNATIVE STANDARDS FOR VALVES
Allowable Percentage of Valves Leaking
Standard
Allowable percentage of leaking valves is
equal to or less than 2 0 percent
Notify Administrator of election to comply
with alternative standard
Conduct performance test initially, annually,
and at other times as requested by the
Administrator.
Performance tests shall
•	Monitor all valves in gas/vapor and in light
liquid service within one week
•	Calculate percent leaking
Notify Administrator of election to comply
with alternative standard.
Conduct performance test initially, annually,
and at other times as requested by the
Administrator
Performance tests shall
•	Monitor all valves in gas/vapor and in
light liquid service within one week
•	Calculate percent leaking
•	Equal to or less than 2.0 percent leaking
Notify Administrator in writing when owner
or operator elects to no longer comply with
alternative standard
Not applicable.
Notify Regional Administrator of election to
comply with alternative standard
Conduct performance test initially, annually,
and at other times as requested by the
Regional Administrator
Performance tests shall
•	Monitor all valves in gas/vapor and in light
liquid service within one week
•	Calculate percent leaking
•	Equal to or less than 2 0 percent leaking
Notify Regional Administrator when owner
or operator elects to no longer comply with
alternative standard
Leak
Definition
10,000 ppm
10,000 ppm
Not applicable
10,000 ppm
Repair
Repair as soon as practicable, no later than
IS calendar days after detection
First attempt within 5 calendar days of
detection
Repair as soon as practicable, no later than
15 calendar days after detection
First attempt within 5 calendar days of
detection
Not applicable
Repair as soon as practicable, no later than
15 calendar days after detection
First attempt within 5 calendar days of
detection
First Attempt
a( Repair
Practices
Best practices include, but are not limited to.
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited
to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Not applicable
Best practices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing

-------
SUMMARY OF REGULATIONS
page A-12
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63.
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CPR part 265,
Subpart BB
Skip Period Leak Detection and Repair
Standard
Notify Administrator of election to comply
with alternative standard
Comply initially with monthly LDAR, then
either
1	After 2 consecutive quarters with equal
to or less than 2 percent leakers,
monitor semiannually, or
2	After 5 consecutive quarters with equal
to or less than 2 percent leakers,
monitor annually
Revert to monthly monitoring if percent
leakers exceed 2 percent
Keep record of percent leakers during each
leak detection
Notify Administrator of election to comply
with alternative standard
Comply initially with monthly LDAR, then
either
1	After 2 consecutive quarters with
equal to or less than 2 percent leakers,
monitor semiannually
2	After 5 consecutive quarters with
equal to or less than 2 percent leakers,
monitor annually
Revert to monthly monitoring if percent
leakers exceed 2 percent
Not applicable
Notify Regional Administrator of election to
comply with alternative standard
Conduct performance test initially, annually,
and at other times as requested by the
Regional Administrator
Comply initially with monthly LDAR, then
either
1	After 2 consecutive quarters with equal
to or less than 2 percent leakers,
monitor semiannually
2	After 5 consecutive quarters with equal
to or less than 2 percent leakers,
monitor annually
Revert to monthly monitoring if percent
leakers exceed 2 percent
Notify Regional Administrator when owner
or operator elects to no longer comply with
alternative standard

-------
SUMMARY OF REGULATIONS	page A-13
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61.
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PUMPS, LIGHT LIQUID SERVICE
Standards
Pumps Monitor monthly and conduct
weekly visual inspections
Pumps Monitor monthly and conduct
weekly visual inspections If located at
unmanned plant site, visual inspections
required at least monthly
Pumps Monitor monthly and conduct
weekly visual inspections If located at
unmanned plant site, visual inspections
required at least monthly
Pumps Monitor monthly and conduct
weekly visual inspections




Phase III- If the ereater of either 10 Dercent
of pumps in a process unit (or source-wide)
or 3 pumps in a process unit (or source-wide)
teak, then implement technology review and
improvement Q1P (This does not apply to
process unit if more than 90% of the pumps
in the unit are either dual mechanical seal or
designed with no externally activated shaft
penetrating the housing.)





Existing Sources






Phase I- begins on compliance date





Phase II begins no later than one year after
the compliance date





Phase III begins no later than 2 'A years
after the compliance date





Nfw S
-------
SUMMARY OF REGULATIONS
page A-14
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PUMPS, LIGHT LIQUID SERVICE (continued)
Leak
Definition
10,000 ppm
Indications of liquids dripping from pump
seal
10,000 ppm
Indications of liquids dripping from pump
seal
"Dual Mechanical Seal" Pumps Indications
of liquid dripping from pump seal where
monitoring for VHAP indicates the presence
of VHAP (less background reading) and for
monitoring total VOCs measures greater
than 10,000 ppm
Phase I 10,000 ppm
Phase II 5,000 ppm
Phase III 5,000 ppm (polymerizing
monomers)
2,000 ppm (food/medical
services)
1.000 ppm (all other pumps)
Indications of liquids dripping from pump
seal
10.000 ppm
Indications of liquids dripping from pump
seal
Repair
Repair as soon as practicable, no later than
15 calendar days after detection
Repair as soon as practicable, no later than
IS calendar days after detection
Repair as soon as practicable, no later than
15 calendar days after detection
Repair as soon as practicable, no later than
15 calendar days after detection

First attempt withm 5 calendar days of
detection
First attempt within 5 calendar days of
detection
First attempt within 5 calendar days of
detection
First attempt within 5 calendar days of
detection




Phase III pumps with leak definition of 1,000
ppm repair only required for pumps leaking
at 2,000 ppm or more

First Attempt
at Repair
Practices
None specified
None specified
Best practices include, but are not limited to
-	tightening of packing gland nuts
-	ensuring that the seal flush is operating
at design pressure and temperature
None specified

-------
SUMMARY OF REGULATIONS
page A-15
Specific
Component
Summaries
REGULATION
40 CFR pari 50,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PUMPS, LIGHT LIQUID SERVICE (concluded)
Exemptions
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service

Any pump equipped with a compliant closed-
vent system and control device
Any pump equipped with a compliant
closed-vent system and control device
Any pump equipped with a compliant closed-
vent system that transports leakage back to
the process, fuel gas system, or to a
compliant control device
Any pump equipped with a compliant closed-
vent system and control device

"Dual Mechanical Seal" pumps specific
operating and design requirements
"Dual Mechanical Seal" pumps specific
operating and design requirements
"Dual Mechanical Seal" pumps specific
operating and design requirements
"Dual Mechanical Seal" pumps specific
operating and design requirements

"No Detectable Emissions" pumps less than
500 ppm above background and specified
design requirements
"No Detectable Emissions" pumps less
than 500 ppm above background and
specified design requirements
Any pump located at an unmanned site is
exempt from weekly visual inspections and
daily sensor checks, provided each pump is
inspected as often as practicable and at least
monthly
"No Detectable Emissions" pumps less than
500 ppm above background and specified
design requirements
No external shaft penetrating the pump
housing weekly visual inspection.
Equipment operated fewer than 300 hours per
year
"No Detectable Emissions" pumps less than
500 ppm above background and specified
design requirements




Process units with more than 90% of pumps
with dual mechanical seal or closed-vent
system are exempt from monthly calculations
of percent leaking pumps





If at unmanned site, visually inspect as often
as practicable and at least monthly





Unsafe to monitor pumps are exempt if
monitoring personnel would be exposed to an
immediate danger and owner/operator has a
plan that requires monitoring as often as
practical during safe to monitor times, but not
more frequently than the periodic monitoring
schedule otherwise applicable


-------
SUMMARY OF REGULATIONS
page A-16
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PUMPS, HEAVY LIQUID SERVICE
Standards
Monitoring of potential leaks within S
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method
Not applicable
Monitoring of potential leaks within S
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method
Monitoring of potential leaks witlun 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method
Leak
Definition
10,000 ppm
Not applicable
Monitoring 2,000 ppm, unless handling
polymerizing monomers - 5,000 ppm
10,000 ppm
Repair
Repair as soon as practicable, no later than
15 calendar days after detection
First attempt within 5 calendar days of
detection
Not applicable
Repair as soon as practicable, no later than
15 calendar after detection
First attempt within 5 calendar days of
detection
For equipment that are not monitored
(Method 21), repair shall mean that visual,
olfactory or other indications of a leak have
been eliminated, no bubbles are observed at
potential leak sites during lead check with
soap solution, or system will hold a lest
pressure
Repair as soon as practicable, no later than
15 calendar days after detection
First attempt within 5 calendar days of
detection
First Attempt
at Repair
Practices
Best practices include, but are not limited to
-	tightening of bonnet bolls
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Not applicable
Best practices include, but are not limited to
-	lightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	lightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Exemptions
Equipment in vacuum service
Not applicable
Equipment in vacuum service
Equipment operated fewer than 300 hours per
year
Equipment in vacuum service

-------
SUMMARY OF REGULATIONS
page A-17
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR pan 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PRESSURE RELIEF DEVICES, GAS/VAPOR SERVICE

Standards
No detectable emissions, except during
pressure releases (less than 500 ppm above
background)
After each release, return to no detectable
emissions within 5 calendar days as indicated
by monitoring of the pressure relief device
No detectable emissions (less than 500 ppm
above background)
After each release, return to no detectable
emissions within 5 calendar days as
indicated by monitoring of the pressure
relief device
No RuDture Disk
No detectable emissions (less than 500 ppm
above background)
After each release, return to no detectable
emissions within 5 calendar days as indicated
by monitoring of the pressure relied device
No detectable emissions (less than 500 ppm
above background)
After each release, return to no detectable
emissions within 5 calendar days as indicated
by monitoring of the pressure relief device




With Ructure Disk






After each release, replace rupture disk
within 5 calendar days

Leak
Definition
"No detectable emissions" - less than 500
ppm above background
"No detectable emissions" - less than 500
ppm above background
"No detectable emissions" - less than 500
ppm above background
"No detectable emissions" - less than 500
ppm above background
Repair
Return to condition of "no detectable
emissions" as soon as practicable but no later
than 5 calendar days after pressure release
Return to condition of "no detectable
emissions" as soon as practicable but no
later than 5 calendar days after pressure
release
Not applicable
Return to condition of "no detectable
emissions" as soon as practicable but no later
than 5 calendar days after pressure release
Exemptions
Pressure relief devices equipped with closed-
vent system and control device
Pressure relief devices equipped with
compliant closed-vent system and control
device
Pressure relief devices routed to a process or
fuel gas system or equipped with compliant
closed-vent system and control device
Pressure relief devices equipped with
compliant closed-vent system and control
device

Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service




Equipment operated fewer than 300 hours per
year





Any pressure relief device equipped with a
rupture disk meeting the requirements of the
rule


-------
SUMMARY OF REGULATIONS
page A-18
Specific
Componenl
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61.
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PRESSURE RELIEF DEVICES, LIGHT LIQUID OR HEAVY LIQUID SERVICE
Standards
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method
Leak
Definition
10,000 ppni
10,000 ppm
Monitoring 500 ppm
10,000 ppm
Repair
Repair as soon as practicable, no later than
IS calendar days after detection
Repair as soon as practicable, no later than
IS calendar days after detection
Repair as soon as practicable, no later than
15 calendar after detection
Repair as soon as practicable, no later than
15 calendar days after detection

First attempt within S calendar days of
detection
First attempt within S calendar days of
detection
First attempt within 5 calendar days of
detection
First attempt within S calendar days of
detection




For equipment that are not monitored
(Method 21), repair shall mean that visual,
olfactory or other indications of a leak have
been eliminated, no bubbles are observed at
potential leak sites during lead check with
soap solution, or system will hold a lest
pressure

First Attempt
at Repair
Practices
Best praclices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited
to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing

Exemptions
Equipment in vacuum service
[Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service




Equipment operated fewer than 300 hours per
year


-------
SUMMARY OF REGULATIONS
page A-19
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR pan 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265.
Subpart BB
COMPRESSORS
Standards
Equip with compliant seal system lhat
includes a barrier fluid system and lhat
prevents leakage to atmosphere
Equip with seal system that includes a
barrier fluid system and that prevents
leakage to atmosphere
Equip with seal system that includes a barrier
fluid system and that prevents leakage to
atmosphere
Equip with seal system that includes a barrier
fluid system and that prevents leakage to
atmosphere

Seal system shall meet certain design and
operation requirements
Seal system shall meet certain design and
operation requirements
Seal system shall meet certain design and
operation requirements
Seal system shall meet certain design and
operalion requirements

Install sensor to detect failure of seal system,
barrier fluid system, or bolh
Install sensor to detect failure of seal
system, barrier fluid system, or both
Install sensor to detect failure of seal system,
barrier fluid system, or both
Install sensor to detect failure of seal system,
barrier fluid system, or both

Check sensor daily or equip with audible
alarm
Visually check sensor daily or equip with
audible alarm (unless located at unmanned
plant site)
Check sensor daily or equip with audible
alarm that is checked monthly (unless located
at unmanned plant site, then check daily)
Check sensor daily or equip with audible
alarm that is checked monthly, if at
unmanned plant site, check daily

Establish criteria that indicates failure of seal
system, barrier fluid system, or both
Establish criteria that indicates failure of
seal system, barrier fluid system, or both
Establish criteria that indicates failure of seal
system, barrier fluid system, or both
Establish criteria that indicates failure of seal
system, barrier fluid system, or both
Leak
Definition
Sensor indicates failure of seal system,
barrier fluid system, or bolh based on
established criteria
Sensor indicates failure of seal system,
barrier fluid system, or both based on
established criteria
Sensor indicates failure of seal system,
barrier fluid system, or both based on
established criteria.
Sensor indicates failure of seal system,
barrier fluid system, or both based on
established criteria
Repair
Repair as soon as practicable, no later than
15 calendar days after detection
Repair as soon as practicable, no later than
IS calendar days after detection
Repair as soon as practicable, no later than
IS calendar days after detection
Repair as soon as practicable, no later than
15 calendar days after detection

First attempt within 5 calendar days of
detection
First attempt within 5 calendar days of
detection
First attempt within 5 calendar days of
detection
First attempt within 5 calendar days of
detection

-------
SUMMARY OF REGULATIONS
page A-20
Specific
Component
Summaries
REGULATION
40 CFR pari 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265.
Subpart BB
COMPRESSORS (concluded)
Exemptions
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service

Compressors equipped with compliant closed-
vent system and control device
Compressors equipped with compliant
closed-vent system and control device
Any compressors equipped with compliant
closed-vent system that returns to process,
fuel gas system, or transports leakage back to
the process or to a compliant control device
Compressors equipped with compliant
closed-vent system and control device

Compressors designed to operate with an
instrument reading less than 500 ppm above
background
Compressors designed to operate with an
instrument reading less than 500 ppm above
background
Compressors designed to operate with an
instrument reading less than 500 ppm above
background
Compressors designed to operate with an
instrument reading less than 500 ppm above
background

Reciprocating compressors that meet certain
criteria


Compressors operated fewer than 300 hours
per year in organic HAP service


-------
SUMMARY OF REGULATIONS
page A-21
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61.
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR.part 265,
Subpart BB
SAMPLING CONNECTION SYSTEMS
Standards
Equipped with closed-purge, closed-loop, or
closed-vent system that returns the purged
process fluid to the process line, collects and
recycles the purged process fluid to a
process, or is designed and operated to
capture and transport all the purged process
fluid to a compliant control device
Equipped with closed-purge system or
closed-vent system that either returns the
fluid to the process line or collects and
recycles the purged fluid with zero VHAP
emissions to the atmosphere, or captures
and transports all purged fluids to a
compliant control device.
Equipped with closed-purge system, closed-
loop, or closed-vent system that either returns
the fluid to the process, recycles the purged
fluid, send it to a compliant control device, or
collect, store, and transport it to an
appropriate facility
Gases displaced during filling of samples are
not required to be collected or captured
Equipped with closed-purge system or
closed-vent system that either returns the
fluid to the process line or collects and
recycles the purged fluid with zero VHAP
emissions to the atmosphere, or captures and
transports all the purged hazardous waste
stream to a compliant control device.
Leak
Definition
Not applicable
Not applicable
Not applicable
Not applicable
Repair
Not applicable
Not applicable
Not applicable
Not applicable
Exemptions
Equipment in vacuum service
In-situ sampling systems and sampling
systems without purges
Equipment in vacuum service
In-situ sampling systems
Equipment in vacuum service
In-situ sampling systems and sampling
systems without purges
Equipment operated fewer than 300 hours per
year
Equipment in vacuum service
In-situ sampling systems
Sampling systems without purges

-------
SUMMARY OF REGULATIONS
page A-22
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
OPEN-ENDED VALVES OR LINES
Standards
Equip with cap, blind flange, plug, or second
valve to seal open end at all time except
when operations require flow through open
end
Equip with cap, blind flange, plug, or
second valve to seal open end at all time
except when operations require flow through
open end
Equip with cap, blind flange, plug, or second
valve to seal open end at all time except when
operations require flow through open end or
during maintenance and repair
Equip with cap, blind flange, plug, or second
valve to seal open end at all tune except
when operations require flow through open
end

Second Valve
Close valve on process fluid end before
closing second valve
Double Block and Bleed Svstem
Bleed valve or line may remain open during
operations that require venting the line
between the block valves, but comply with
basic standard at all other times
Second Valve
Close valve on process fluid end prior to
closing second valve
Double Block and Bleed Svstem
May remain open during operations that
require venting the line between the block
valves, but comply with basic standard at all
other times
Second Valve
Close valve on process fluid end prior to
closing second valve
Double Block and Bleed Svstem
May remain open during operations that
require venting the line between the block
valves, but comply with basic standard at all
other times
Second Valve
Close valve on hazardous waste stream end
prior to closing second valve
Double Block and Bleed Svstem
May remain open during operations that
require venting the line between the block
valves, but comply with basic standard at all
other times
Leak
Definition
Nol applicable
Not applicable
Not applicable
Not applicable
Repair
Not applicable
Not applicable
Not applicable
Not applicable
Exemptions
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service




Open-ended valves and lines in an emergency
shutdown system that are designed to open
automatically in the event of a process upset





Equipment operated fewer than 300 hours per
year





Equipment containing materials which would
automatically polymerize or cause a safety
hazard if capped or equipped with a double
block and bleed system


-------
SUMMARY OF REGULATIONS
page A-23
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR pan 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
FLANGES AND OTHER CONNECTORS (ALL SERVICES)
Standards
Monitor within S days if evidence of a
potential leak is found by visual, auditory,
olfactory, or other detection methods
Monitor within 5 days if evidence of a
potential leak is found by visual, auditory,
olfactory, or other detection methods
(see Connectors, gas/vapor or light liquid
service)
Monitor within 5 days if evidence of a
potential leak is found by visual, auditory,
olfactory, or other detection methods
Leak
Definition
10,000
10,000
(see Connectors, gas/vapor or light liquid
service)
10.000
Repair
Repair as soon as practicable, no later than
IS calendar days after detection
Firsi attempt within 5 calendar days of
detection
Repair as soon as practicable, no later than
15 calendar days after detection
First attempt within S calendar days of
detection
(see Connectors, gas/vapor or light liquid
service)
Repair as soon as practicable, no later than
IS calendar days after detection
First attempt within S calendar days of
detection
First Attempt
at Repair
Practices
Best practices include, but are not limited to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
Best practices include, but are not limited
to
-	tightening of bonnet bolts
-	replacement of bonnet bolts
-	tightening of packing gland nuts
-	injection of lubricant into lubricated
packing
(see Connectors, gas/vapor or tight liquid
service)

Exemptions
Equipment in vacuum service
Equipment in vacuum service
(see Connectors, gas/vapor or light liquid
service)
Equipment in vacuum service

-------
SUMMARY OF REGULATIONS	page A-24
Specific
Component
Summaries
REGULATION
40 CFR pari 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
CONNECTORS, GAS/VAPOR OR LIGHT LIQUID SERVICE
Standards
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
Initial Survey Monitor all connectors within
a 12 month period
(see "Flanges and other connectors, all
services)




Subsequent monitoring frequency based on
percent leaking connectors





•	annual if a 0 5%
•	once every 2 years if < 0 5%
•	once every 4 years if <0 5% during 2
year monitoring
•	once every 2 years if 0 5 to < 1 % during 4
year monitoring
•	annual if > 1 % during 4 year monitoring





To comply with monitoring frequency of once
every two years, monitor at least 40% of the
connectors in the first year and the remainder
in the second year





To comply with monitoring frequency of once
every four years, monitor at least 20% each
year until all have been monitored within 4
years





Connectors that have been opened or
reconnected or have had the seal broken
Monitor for leaks within 3 months after being
returned to organic HAP service or calculate
percent leakers by setting nonreparable
components to zero for all monitoring
periods May switch between these
alternatives at end of monitoring period





A switch in alternatives requires initial
monitoring no later than 12 months after
reporting the switch


-------
SUMMARY OF REGULATIONS
page A-25
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
CONNECTORS. GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)
Leak
Definition
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
500 ppm (except for inaccessible, ceramic, or
ceramic-lined connectors)
(see "Flanges and other connectors, all
services)
Repair
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
Repair as soon as practicable, but no later
than IS calendar days after detection
(see "Flanges and other connectors, all
services)




First attempt to repair within 5 calendar days
of detection





When repaired, monitor at least once within
first 3 months of repair

Exemptions
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
Equipment in vacuum service
Equipment operated fewer than 300 hours per
year
(see "Flanges and other connectors, all
services)




"Unsafe to monitor" connectors Written
plan to monitor as frequently as practicable
during safe to monitor periods, but no more
frequently than the periodic schedule
otherwise applicable





"Unsafe to repair" connectors Repair by end
of the next scheduled process unit shutdown





"Inaccessible" or "ceramic" or "ceramic-
lined" connectors Repair any observed leak


-------
SUMMARY OF REGULATIONS
page A-26
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61.
Subpart J
40 CFR part 61,
Subpart V
40 CFR pari 63.
Subpart H
40 CFR part 63,
Subpart 1
40 CFR pan 264,
Subpart BB
40 CFR part 265,
Subpart BB
CONNECTORS, HEAVY LIQUID SERVICE
Standards
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
Monitoring of potential leaks within S
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, and other detection methods
(see "Flanges and other connectors, all
services)
Leak
Definition
(see "Ranges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
Monitoring 500 ppm
(see "Flanges and other connectors, all
services)
Repair
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
Repair as soon as practicable, no later than
15 calendar after detection
For connectors in heavy liquid service that
are not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or other
indications of a leak have been eliminated, no
bubbles are observed at potential leak sites
during leak check with soap solution, or
system will hold a test pressure
(see "Flanges and other connectors, all
services)
Exemptions
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
Equipment in vacuum service
Equipment operated fewer than 300 hours per
year
(see "Flanges and other connectors, all
services)

-------
SUMMARY OF REGULATIONS
page A-27
Specific
Component
Summaries
REGULATION
40 CFR part 60.
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63.
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
AGITATORS, GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
Standards
Not applicable
Not applicable

"Non Dual Mechanical Seal" Aeitators
Monthly monitoring and weekly visual check
for indications of dripping liquid If at
unmanned site, visually inspect as often as
practicable and at least monthly
Not applicable




"Dual Mechanical Seal
" Aeitators





Daily sensor check and weekly visual
inspections for indications of dripping liquid





Dual mechanical seal requirements
• Barrier fluid pressure at all times greater
than agitator stuffing box pressure, or





• Barrier fluid degassing reservoir routed to
a process or fuel gas system or connected
by a compliant closed-vent system to a
control device, or





• Closed-loop system that purges the barrier
fluid into a process stream





Owner/operator determines criteria applicable
to the presence and frequency of drips and to
the sensor that indicates failure of the seal
system, the barrier fluid system, or both

AGITATORS. GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE (concluded)

-------
SUMMARY OF REGULATIONS
page A-28
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Leak
Definition
Not applicable
Not applicable

"Non Dual Mechanical Seal" Aeitators.
Monthly monitoring 10,000 ppm
Weekly Visual presence of indications of
dripping liquids
Not applicable




"Dual Mechanical Seal
" Aeitators.





Weekly Visual if indications of dripping
liquids, monitor and if reading is 10,000 ppm
based or higher, a leak is detected





Drip Criteria A leak is detected if the drip
criteria established are exceeded





Sensor A leak is detected if the sensor
indicates failure of the seal system, the
barrier fluid system, or both

Repairs
Not applicable
Not applicable

Repair as soon as practicable, no later than
15 days after detection
First attempt to repair within S calendar days
of detection
Not applicable

-------
SUMMARY OF REGULATIONS
page A-29
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63.
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Exemptions
Not applicable
Not applicable

Designed with no externally actuated shaft
penetrating the agitator housing
Equipment in vacuum service
Agitators operated fewer than 300 hours per
year m organic HAP service
Any agitator equipped with a compliant
closed-vent system and control device
"Difficult to monitor" agitators less than 3%
or agitators may be so marked
"Unsafe to monitor1' agitators written plan to
monitor as frequently as practicable during
safe to monitor periods, but no more
frequently than the periodic schedule
otherwise applicable
Agitators obstructed by equipment piping that
prevents access by a monitor probe
Agitators located at unmanned plant sites are
exempt from weekly visual inspection and
daily sensor check if visually inspected as
often as possible and at least monthly
Not applicable

-------
SUMMARY OF REGULATIONS
page A-30
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
AGITATORS, HEAVY LIQUID SERVICE
Standards
Not applicable
Not applicable
Monitoring of potential leaks within S
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, or other detection method
Not applicable
Leak
Definition
Not applicable
Not applicable
Monitoring 10,000 ppm
Not applicable
Repair
Not applicable
Not applicable
Repair as soon as practicable, no later than
IS calendar after detection
For agitators in heavy liquid service that are
not monitored (Method 21), repair shall mean
that visual, audible, olfactory, or other
indications of a leak have been eliminated, no
bubbles are observed at potential leak sues
during leak check with soap solution, or
system will hold a test pressure
Not applicable
Exemptions
Not applicable
Not applicable
Equipment in vacuum servtce
Equipment operated fewer than 300 hours per
year
Not applicable

-------
SUMMARY OF REGULATIONS
page A-31
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61.
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
INSTRUMENTATION SYSTEMS
Standards
Not applicable
Not applicable
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, or other detection method
Not applicable
Leak
Definition
Not applicable
Not applicable
Monitoring 500 ppm
Not applicable
Repair
Not applicable
Not applicable
Repair as soon as practicable, no later than
IS calendar after detection
For instrumentation systems that are not
monitored (Method 21), repair shall mean
that visual, audible, olfactory, or other
indications of a leak have been eliminated, no
bubbles are observed at potential leak sites
during leak check with soap solution, or
system will hold a test pressure
Not applicable
Exemptions
Not applicable
Not applicable
Equipment in vacuum service
Equipment operated fewer than 300 hours per
year.
Not applicable

-------
SUMMARY OF REGULATIONS
page A-32
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PRODUCT ACCUMULATOR VESSELS
Standards
Not applicable
Compliant closed-vent system and control
device
(see Surge Control Vessels and Bottoms
Receivers)
Not applicable
Leak
Definition
Not applicable
Not applicable
(see Surge Control Vessels and Bottoms
Receivers)
Not applicable
Repair
Not applicable
Not applicable
(see Surge Control Vessels and Bottoms
Receivers)
Not applicable
Exemptions
Not applicable
Equipment in vacuum service
(see Surge Control Vessels and Bottoms
Receivers)
Not applicable

-------
SUMMARY OF REGULATIONS
page A-33
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
SURGE CONTROL VESSELS AND BOTTOMS RECEIVERS
Standards
Not applicable
(see Product Accumulator Vessels)
Use of closed-vent system that routes the
organic vapors either back to process or to
compliant control device
Comply with the requirements for fixed roofs
with internal or external floating roofs.
Not applicable
Leak
Definition
Not applicable
(see Product Accumulator Vessels)
Not applicable.
Not applicable
Repair
Not applicable.
(see Product Accumulator Vessels)
Not applicable
Not applicable
Exemptions
Not applicable
(see Product Accumulator Vessels)
Surge control vessels routed back to process
Equipment in vacuum service
Equipment operated fewer than 300 hours per
year
Surge control vessels that do not meet certain
capacity and vapor pressure criteria; see
Tables 2 and 3 of Subpart H
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-34
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
CLOSED VENT SYSTEMS AND CONTROL DEVICES
Standards
Control devices and closed-vent systems to be
operated at all limes that emissions may be
vented to them
Control Devices
Vapor recovery systems 95 percent or
greater recovery
Combustion devices 95 percent or greater
reduction or minimum residence time of 0 75
seconds and minimum temperature of 816ฐC
Flares Comply with ง60 18
Closed-Vent Systems (CVS)
Hard pipe construction Initial inspection
(Method 21) and then annual visual
inspections
Ductwork construction Initial and annual
inspections using Method 21
Does not apply if CVS is in vacuum service
Control devices and closed-vent systems to
be operated at all times that emissions may
be vented to them
Control Devices
Vapor recovery systems 95 percent or
greater recovery
Combustion devices 95 percent or greater
reduction or minimum residence time of
0.50 seconds and minimum temperature of
760ฐC
Flares Comply with ง60 18
Closed-Vent Systems (CVS)
No detectable emissions (less than 500 ppm
above background) and no visual
indications
Control devices and closed-vent systems to be
operated at all times that emissions may be
vented to them
Control devices subject to 40 CFR 63 subpart
H and 40 CFR 264 subpart BB or 40 CFR
265 subpart BB may comply with the
monitoring, recordkeeping and reporting
requirements of subpart H or of parts 264
and/or 265
Recovery or Recapture Devices.
Vapor recovery sysiems 95 percent or
greater recovery or an exit concentration of
20 ppmv, whichever is less stringent
Combustion devices 95 percent or greater
reduction or 20 ppmv on any basis, corrected
to 3% Oj. whichever is less stringent, or
minimum residence time of 0 50 seconds and
minimum temperature of 760PC
Flares Comply with ง63 11(b)
Closed-Vent Systems (CVS)
Hard pipe construction Initial inspection
(Method 21) and then annual visual
inspections
Ductwork construction. Initial and annual
inspections using Method 21
Does not apply if CVS is in vacuum service
Control devices and closed-vent sysiems to
be operated at all times that emissions may
be vented to them
Control Devices
Vapor recovery systems 95 percent or
greater recovery unless total organic
emission limits of 1 4 kg/hr (12 8 Mg/yr) for
all affected processes can be attained at an
efficiency of less than 95 percent
For carbon adsorbers, carbon replacement
intervals specified
Combustion devices 95 percent or greater
reduction, 20 ppmv total organic compound
concentration, or minimum residence time of
0 50 seconds and minimum temperature of
760ฐC
Boilers and process heaters Introduce vent
stream into flame combustion zone
Flares Flame present at all times, no visible
emissions (except for periods not to exceed a
total of 5 minutes during any 2 consecutive
hours), basic requirements for heat content
and exit velocities
Closed-Vent Systems (CVS)
No detectable emissions (less than 500 ppm
above background)

-------
SUMMARY OF REGULATIONS
page A-35
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63.
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
CLOSED VENT SYSTEMS AND CONTROL DEVICES (continued)
Monitoring
Control Devices Monitor to ensure operated
and maintained in conformance with their
designs
Control Devices Monitor to ensure
operated and maintained in conformance
with their designs
Control Devices Monitor to ensure operated
and maintained in conformance with their
designs
Control Devices Monitor to ensure operated
and maintained in conformance with their
designs Specific requirements identified for
vent stream flow monitors and other
monitors for specific types of control
devices

Closed-Vent Systems If contains by-pass
lines, (1) vent stream flow meters or (2) car-
seal or lock-and-key type of configuration
wiih monthly visual inspection required
Inspect initially, annually, and at other times
as requested by the Administrator
Hard pipe construction Method 21 for initial
inspection, annual visual inspections
Closed-Vent Systems Initially, annually,
and at other times as requested by the
Administrator
Closed-Vent Systems If contains by-pass
lines install, set or adjust and maintain vent
stream flow indicator installed at entrance to
any bypass line or (l)vent stream flow meters
or (2) car-seal or lock-and-key type of
configuration with monthly visual inspection
required
Closed-Vent Systems Initially, annually,
and at other times as requested by the
Administrator

Duct Work construction Method 21 for
initial and annual inspections





Leak
Definition
> 500 ppm or above background
Visual inspection
500 ppm
Visual inspection
500 ppm
Visual inspection
CVS detectable emissions (i500 above
background)
Repair
Repair as soon as practicable, but no later
than IS calendar days after detection
Repair as soon as practicable, but no later
than 15 calendar days after detection
Repair as soon as practicable, but no later
than 15 calendar days after detection
Repair as soon as practicable, but no later
than 15 calendar days after detection

First attempt to repair within 5 calendar days
of detection
First attempt to repair within 5 calendar
days of detection
First attempt to repair within 5 calendar days
of detection
First attempt to repair within 5 calendar days
of detection

-------
SUMMARY OF REGULATIONS
page A-36
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR pari 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
CLOSED VENT SYSTEMS AND CONTROL DEVICES (concluded)
Exemptions
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service
Equipment in vacuum service

"Unsafe to inspect" parts inspect as
frequently as practicable during safe to
inspect times


"Unsafe to inspect" parts inspect as
frequently as practicable but not more than
once per year
Equipment that contains or contacts a
hazardous waste of at least 10% by weight
for fewer than 300 hours per year

"Difficult to inspect" parts inspect at least
once every 5 years


"Difficult to inspect" parts inspect at least
once every 5 years
Equipment m organic HAP service fewer
than 300 hours per year
Equipment needed for safety purposes are not
subject to these monitoring requirements
"Unsafe to monitor" parts monitor as
frequently as possible during safe to monitor
times

-------
SUMMARY OF REGULATIONS
page A-37
Delay of Repair
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
General
Allowed if repair is technically infeasible
without a process unit shutdown
Repair to occur before end of next process
unit shutdown
Allowed for equipment isolated from the
process and that does not remain in VOC
service
Allowed if repair is technically infeasible
without a process unit shutdown
Repair to occur before end of next process
unit shutdown
Allowed for equipment isolated from the
process and that does not remain in VHAP
service
Allowed if repair is technically infeasible
without a process unit shutdown
Repair to occur before end of next process
unit shutdown
Allowed for equipment isolated from the
process and that does not remain in organic
HAP service
Allowed if repair is technically infeasible
without a hazardous waste management unit
shutdown
Repair to occur before end of next
hazardous waste management unit
shutdown
Allowed for equipment isolated from the
unit and that docs not continue to contain or
contact hazardous waste with organic
concentrations of at least 10 percent by
weight
Valves
(including
connectors and
agitators for 40
CFR part 63
only)
Allowed if
Emissions of purged material resulting from
immediate repair greater than the fugitive
emissions likely to result from the delay in
the repair and purged material is collected
and destroyed or recovered in compliant
control device when procedures are
effecled
Delay beyond a process unit shutdown
allowed if valve assemblies have been
depleted and valve assembly supplies had
been sufficiently stocked before supplies
were depleted
Not allowed beyond next process unit
shutdown, unless next process unit
shutdown occurs sooner than 6 months after
first process unit shutdown
Allowed if
Emissions of purged material resulting from
immediate repair greater than the fugitive
emissions likely to result from the delay in
(he repair and purged material is collected
and destroyed or recovered in compliant
control device when procedures are
effected
Delay beyond a process unit shutdown
allowed if valve assemblies have been
depleted, valve assembly supplies had been
sufficiently stocked before supplies were
depleted
Not allowed unless next process unit
shutdown occurs sooner than 6 months after
firsl process unit shutdown
Allowed if
Emissions of purged material resulting from
immediate repair greater than the fugitive
emissions likely to result from the delay in
the repair and purged material is collected
and destroyed or recovered in compliant
control device when procedures are effected
Delay beyond a process unit shutdown
allowed if valve assemblies have been
depleted, valve assembly supplies had been
sufficiently stocked before supplies were
depleted
Not allowed beyond the second process unit
shutdown unless the third process unit
shutdown occurs sooner than 6 months after
first process unit shutdown
Allowed if
Emissions of purged material resulting from
immediate repair greater than the fugitive
emissions likely to result from the delay in
the repair and purged materia! is collected
and destroyed or recovered in compliant
control device when procedures are
effected
Delay beyond a hazardous waste
management unit shutdown allowed if valve
assemblies have been depleted, valve
assembly supplies had been sufficiently
stocked before supplies were depleted
Not allowed unless next unit shutdown
occurs sooner than 6 months after first unit
shutdown

-------
SUMMARY OF REGULATIONS
page A-38

REGULATION
Delay of Repair
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Pumps
Allowed if
Allowed if

Allowed if

Allowed if

Repair requires use of DMS seal system
that includes barrier fluid and
Repair requires use of DMS seal system that
includes barrier fluid and
Repair requires replacing existing seal design
with a new system that provides better
performance under provisions of a QIP or
using a DMS, a pump designed with no
externally actuated shaft, or a compliant
closed-vent system and control device
Repair requires use of DMS seal system that
includes barrier fluid and

Repair completed as soon as practicable,
but not later than 6 months after leak was
detected
Repair completed as soon as practicable, but
not later than 6 months after leak was
detected
Repair completed as soon as practicable, but
not later than 6 months after leak was
detected
Repair completed as soon as practicable, bul
not later than 6 months after leak was
detected
Closed-Vent
Systems and
Control Devices
Allowed if emissions resulting from delay
of repair would be greater than fugitive
emissions front delay of repair Repair
required by end of next process unit
shutdown
Not applicable
Allowed if emissions resulting from delay of
repair would be greater than fugitive
emissions from delay of repair Repair
required by end of next process unit
shutdown
Allowed if emissions resulting from delay of
repair would be greater than fugitive
emissions from delay of repair Repair
required by end of next process unit
shutdown

-------
SUMMARY OF REGULATIONS
page A-39
Quality
Improvement
Programs
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63.
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Applicability
Not applicable.
Not applicable
YflWfS

Not applicable



Optional in phase III to owners\operators with <ฃ.%
leakers.




Decision required within first year of phase III




If rolling average of percent leakers is <2% for 2
consecutive quarters' (1) comply with QIP, (2) comply
with ง63 168, or (3) comply with both QIP and ง63 168




If comply with ง63 168 only, can not use QIP again if leak
rale goes above 2 percent, monthly monitoring is required




If not continuing QIP (i.e , complying with valve standard)
cannot use QIP again if leak rate goes above 2%, monthly
monitoring is required




If complying with both QIP and valve standard,
owner/operator may use the following monitoring
frequencies*
-	if <2% leaking, (hen monitor once per quarter
-	if < 1 % leaking, then once every 2 quarters
-	if <0 5% leaking, then once every 4 quarters




Pumps





Required in phase III if 6 month rolling average is the
greater of either > 10% or 3 pumps leaking




Once < 10% or <3 pumps (6 month rolling average)
leaking is achieved, comply with ง63 163




If leak rate again exceeds the greater of either > 10% or 3
pumps leaking, can use QIP again


-------
SUMMARY OF REGULATIONS
page A-40
Quality
Improvement
Programs
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Valves,
Demonstration
of Further
Progress
Not applicable
Not applicable
Comply with valve standard except monitor quarterly
Collect data and maintain records as follows
•	maximum instrument reading observed in each
monitoring observation before repair, response factor
for each stream, instrument model number, and date of
observation
•	classification of valve "gas or light liquid service"
•	repair method used and instrument readings after repair
(monitoring required at least once within the first 3
months after the repair is completed)(ID tag on a
leaking valve may be removed after (he valve
successfully passes this monitoring period)
Continue to collect data on the valves for as long as the
process unit is in QIP
Demonstrate progress in reducing the percent leaking
valves each quarter by at least
•	10 percent (meaning that each quarter there is at least a
10 percent reduction in the percent leaking valves from
the preceding monitoring period) [calculation to be
made by formula specified in ง63 175(d)(4)(i)], or
•	alternative quarterly percent reduction [calculated
according to the equation in ง63 175(d)(4)(m)(A)l and
to less than 2 percent within 2 years
The provisions for failure to meet the 10 percent reduction
for 2 consecutive rolling averages are
•	a choice of monthly monitoring, or
•	implementation of a QIP for technology review as
specified in ง63 175(e)


-------
SUMMARY OF REGULATIONS
page A-41
Quality
Improvement
Programs
REGULATION
40 CFR pari 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR pan 61.
Subpart V
40 CFR part 63.
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Valves,
Technology
Review and
Improvement
Not applicable
Not applicable

Data collection for the valves as long as in QIP
•	Valve type and manufacturer, valve design, materials of
construction, packing material, and year installed
•	Service characteristics of the stream (e g , operating
pressure, temperature, line diameter, corrosivity)
•	Whether in gas/vapor or light liquid service
•	If a teak is detected, the maximum instrument reading
observed before a repair, response factor for stream if
adjusted, instrument model number, and date of
observation
•	If a leak is repaired, repair methods used and the
instrument readings after the repair
Inspect all valves removed due to leaks to determine cause
of failure and recommend design and other changes to
reduce leak potential
Analyze data to determine the services, operating and
maintenance procedures, and valve designs or technologies
that have poorer than average emission performance and
those that have better than average emission performance
The first analysis shall be completed no later than 18
months after the start of Phase III, shall use a minimum of
6 months of data, shall be done yearly for as long as the
process unit is in the QIP program
Superior valve performance is defined as
•	technology for valves having a leak frequency of <2%
for specific applications in process unit
•	technology has low emission performance and is
capable of achieving <2% leaking valves in process
unit
Not applicable

-------
SUMMARY OF REGULATIONS
page A-42
Quality
Improvement
Programs
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR pan 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Valves,
Technology
Review and
Improvement
(concluded)
Not applicable
Not applicable

Trial evaluation program is required for plants that have
not demonstrated superior performing valve designs and
technologies
1	The number of valves in the trial program shall be the
lesser of 1 percent or 20 valves for programs involving
single process units and the lesser of 1 percent or SO
valves for programs involving groups of process units
2	The program shall specify and include design
documentation of
•	superior performing valve designs or technologies
•	stages of evaluating these valve designs or technologies
•	frequency of monitoring or inspection
•	range of operating conditions component will be
evaluated under
•	conclusions regarding the emission performance and
appropriate operating conditions and services
The performance trials shall be conducted for a 6-month
period beginning no later than 18 months after the
beginning of the QIP
Conclusions will be drawn no later than 24 months after
the beginning of the QIP
Any plant site with fewer than 400 valves and owned by a
company with fewer than 100 total employees is exempt
from the trial evaluations of valves. These exempted
plants shall begin the program at the start of the fourth
year of Phase III.
If superior emission performance technology can not be
identified, replacement valve shall be one with lowest
emission performance technologies identified for the
specific application
Not applicable

-------
SUMMARY OF REGULATIONS
page A-43
Quality
Improvement
Programs
REGULATION
40 CFR pan 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Pumps,
Technology
Review and
Improvement
Not applicable
Not applicable

Data collection'
•	Pumps type and manufacturer, seal type and
manufacturer, pump design, materials of construction,
barrier fluid or packing material, and year installed
•	Service characteristics of the stream, discharge
pressure, temperature, flow rate, corrosivity, and
annual operating hours.
•	Maximum instrument readings observed before repair,
response factor for the stream, instrument number, and
date of observation
•	If a leak is detected, repair methods used and the
instrument readings after the repair
Inspect all pumps or pump seals that exhibit frequent seal
failure and were removed due to leaks Inspection shall
determine probable cause and recommendation for design
changes or changes in specifications to reduce leak
potential
Analyze data to determine the services, operating and
maintenance procedures, and pumps and pump seal designs
or technologies that have poorer than average emission
performance and those that have better than average
emission performance. The first analysis shall be
completed no later than 18 months after the start of the
program, shall use a minimum of 6 months of data, shall
be done yearly for as long as the process unit is in the QIP
program.
Not applicable

-------
SUMMARY OF REGULATIONS
page A-44
Quality
Improvement
Programs
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Pumps,
Technology
Review and
Improvement
(concluded)
Not applicable
Not applicable

Superior pump performance is defined as
•	pumps or pump seals that will result in < 10% leaking
pumps in the process unit
•	includes material or design changes to the existing
pump, pump seal, seal support system, installation of
multiple mechanical seals or equivalent, or pump
replacement
Trial evaluation program is required for plants that have
not demonstrated superior technologies
1	The number of pump seal technologies or pumps in
the trial program shall be the lesser of 1 percent or 2
pumps for programs involving single process units and the
lesser of 1 percent or 5 pumps for plant sites or groups of
process units The minimum number of pumps or pump
seal technologies in the program shall be 1, and
2	The program shall specify and include design
documentation of Ihe following
•	superior performing pump seal designs or technologies
•	stages of evaluating these pump designs or pump seal
technologies
•	frequency of monitoring or inspection
•	range of operating conditions component will be
evaluated under
•	conclusions regarding the emission performance and
appropriate operating conditions and services
The performance trials shall be conducted for a 6-month
period beginning no later than 18 months after the
beginning of the QIP
Conclusions will be drawn no later than 24 months after
the beginning of the QIP
Beginning at the start of the third year of the QIP for
plants with 400 or more valves or 100 or more employees
and at Ihe start of the fourth year for others, the
owner/operator shall replace the pumps and pump seals
that are not superior technology Pumps or pump seals
shall be replaced at the rate of 20 % per year and shall
continue to be replaced until all are superior technology
Not applicable

-------
SUMMARY OF REGULATIONS
page A-45
Equivalence of (or
Alternative) Means
of Emission
Limitation
General
REGULATION
40 CFR part 60,
Subpart VV
40 CFR pan 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265.
Subpart BB
Equipment,
Design, and
Operational
Requirements
Owner/operator collect and verify lest data
lo demonstrate equivalence
Administrator compares test data
Administrator may condition approval
Owner/operalor collect and verify test data
for alternative means of emission limitation
Administrator may condition approval
Owner/operator collect and verify test data
for alternative means of emission limitation
Administrator compares test data
Administrator may condition approval
Not applicable
Work Practices
Owner/operalor collect and verify test data
to demonstrate equivalence
Owner/operator demonstrates emission
reduction achieved by required work
practice
Owner/operator demonstrates emission
reduction achieved by equivalent means of
emission limitation
Owner/operator commiis to alternative
work practices
Administrator compares demonstrated
emission reductions
Administrator may condition approval
Owner/operator collect and verify test data
for alternative means of emission limitation.
Owner/operator demonstrates emission
reduction achieved by required work
practice (for minimum of 12 months)
Owner/operator demonstrates emission
reduction achieved by alternative means of
emission limitation
Owner/operator commits in writing to work
practices that provide for emission
reductions equal to or greater than emission
reductions achieved by required work
practices
Administrator compares demonstrated
emission reductions
Administrator may condition approval
Owner/operator collect and verify test data
for alternative means of emission limitation
Owner/operator demonstrates emission
reduction achieved by required work
practice (for minimum of 12 months)
Owner/operator demonstrates emission
reduction achieved by alternative means of
emission limitation
Owner/operator commits to alternative
work practices
Administrator compares demonstrated
emission reductions
Administrator may condition approval
Not applicable
Unique Approach
Owner/operator may offer unique approach
to demonstrate equivalency
Owner/operator may offer unique approach
lo demonstrate equivalency
Owner/operator may offer unique approach
to demonstrate equivalency
Not applicable
Manufacturers of
Equipment
May apply for determination of equivalency
for equipment, design, and operational
requirements
May apply for determination of equivalency
for equipment, design, and operational
requirements
May apply for determination of equivalency
for equipment, design, and operational
requirements
Not applicable

-------
SUMMARY OF REGULATIONS
page A-46
Alternative Means
REGULATION
Limitations
Batch Processes
40 CFR part 60,
subpart VV
40 CFR part 61,
subpart J
40 CFR part 61,
subpart V
40 CFR part 63,
subpart H
40 CFR part 63,
subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
subpart BB
Monitoring Option
Not applicable
Not applicable
Not applicable
The batch processes provision is an alternative to complying with งง63 163 through
63 171 and งง63 173 through 63 176 Under the monitoring option for batch
processes, the standards are similar to those for continuous processes with the
monitoring frequency prorated to time in use of organic HAP
Each time equipment is reconfigured for the production of a new product, the
reconfigured equipment is to be monitored for leaks within 30 days of start-up This
initial monitoring of (he reconfigured equipment can not be used in determining
percent leaking equipment in the process unit
Not applicable




Connectors are to be monitored in accordance with ง63 174






Equipment olher than connectors are to be monitored based on (he frequencies shown
below, which can be adjusted to accommodate process operations





BATCH PROCESS EQUIPMENT MONITORING FREQUENCIES
(other than connectors)





Batch Process Time
in Use (% of year)
Equivalent Continuous Process
Monitoring Frequency






Monthly
Quarterly
Semiannually





0 to < 25%
quarterly
annually
annually





25 to < 50%
quarterly
semiannually
annually





50 to < 75 %
bimonthly
three times a year
semiannually





75 to 100%
monthly
quarterly
semiannually





If a leak is detected, it must be repaired as soon as practicable, but no later than 15
calendars after detection Delay of repair is allowed if equipment supplies have been
depleted and supplies had been sufficiently stocked before their depletion and the
repair is made no later than 10 calendar days after delivery of the replacement
equipment


-------
SUMMARY OF REGULATIONS
page A-47
Alternative Means
of Emission
Limitations
Batch Processes
REGULATION
40 CFR part 60,
subpart VV
40 CFR part 61,
subpart J
40 CFR part 61,
subpart V
40 CFR part 63,
subpart H
40 CFR part 63,
subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
subpart BB
Pressure Test
Option
Not applicable
Not applicable
Not applicable
Monitor for leaks when the equipment is in organic HAP service, in use with an
acceptable surrogate volatile organic compound which is not an organic HAP, or is in
use with any other detectable gas or vapor
Each time equipment is reconfigured for production of a different product or
intermediate, the batch process tram is to be pressure-tested for leaks before organic
HAP is first fed into the equipment
Pressure test new or disturbed equipment when a batch process train is reconfigured
Pressure testing not required for routine seal breaks, such as changing hoses and
niters
Batch process equipment lest using either
•	procedures specified for pressure or vacuum loss [see ง63 180(01 or
•	procedures specified for using a liquid [see ง63 180(g)]
Each batch process that operates in organic HAP service during a calendar year must
be pressure tested at least once during that same calendar year
For pressure or vacuum tests, a leak is detected if the rate of pressure change in
excess of 6 9 kilopascals (1 psig) in 1 hour, or if there is visible, audible, or olfactory
evidence of fluid loss.
For pressure tests using a liquid, a leak is detected if there are indications of dripping
liquid or other evidence of fluid loss from process units
When leaks are detected, repairs must be made and a retest conducted before startup
of the process
If the process unit fails this retest or the second of 2 consecutive pressure tests, the
equipment must be repaired as soon as practicable but not later than 30 calendar days
after the second pressure test
Not applicable

-------
SUMMARY OF REGULATIONS
page A-48
Alternative Means
of Emission
REGULATION
Limitations






Enclosed-Vented
40 CFR part 60,
40 CFR part 61,
40 CFR part 61,
40 CFR part 63,
40 CFR part 63,
40 CFR pari 264,
Process Units
Subpart VV
Subpart J
Subpart V
Subpart H
Subpart I
Subpart BB






40 CFR part 265,






Subpart BB

Not applicable
Not applicable
Process units enclosed such that all
emissions from equipment leaks are vented
through a closed-vent system to a control
device are exempt from the requirements of
งง63 163 through 63 171 and งง63 173 and
63 174
Enclosure is to be maintained under
negative pressure at all times the process
unit is in operation
Not applicable

-------
SUMMARY OF REGULATIONS
page A-49

REGULATION
Tesl Methods and
Procedures
40 CFR part 60,
Subpart VV
40 CFR pari 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR pari 63,
Subpart H
40 CFR part 63.
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Monitoring Method
and Technique
Method 21 of 40 CFR pari 60, Appendix A
Tesl each piece of equipment unless
demonstration is made thai equipment is not
in VOC service
Method 21 of 40 CFR pari 60, Appendix A
Instrument to meet performance criteria of
Method 21
Traverse probe around all potential leak
interfaces as close as possible as described
in Method 21
Method 21 of 40 CFR part 60, Appendix A
Instrument to meet performance criteria of
Method 21 except
• response factor criteria is for the average
composition of the process fluid, not each
individual VOC in stream
Method 21 of 40 CFR part 60, Appendix A
Instrument to meet performance criteria of
Method 21
Traverse probe around all potential leak
interfaces as close as possible as described
in Method 21




• for process streams lhat contain inerts that
are not organic HAPs or VOC, average
stream response factor is calculated on an
inert-free basis





If no instrument available that meet all Method
21 criteria, then instrument readings may be
adjusted as specified





Monitor all equipment while n is "in service"

Calibration
Before use each day of use
Before use each day of use
Before use each day of use
Before use each day of use

Procedures specified in Method 21
Procedures specified in Method 21
Procedures specified in Method 21
Procedures specified in Method 21

Calibration gases used
Calibralion gases used

Calibration gases used

Calibration gases used

• zero air (less than 10 ppm hydrocarbon
in air)
• zero air (less than 10 ppm hydrocarbon
in air)
• zero air (less than 10 ppm of hydrocarbon
in air)
• zero air (less than 10 ppm hydrocarbon
in air)

• mixture of methane or n-hexane and air
at aboul, but less than, 10,000 ppm
methane or n-hexane
• mixture of methane or n-hexane and air
at about, but less than, 10,000 ppm
methane or n-hexane
• Phase 1 mixture of methane in air at
concentration of about, but less than,
10,000 ppm
• mixture of methane or n-hexane and air
at about, but less than, 10,000 ppm
methane or n-hexane




• Phase II mixture of methane in air at
concentration of about, but less than
10,000 ppm for agitators
5,000 ppm for pumps
500 ppm for all other equipment


-------
SUMMARY OF REGULATIONS
page A-50
Test Methods and
Procedures
REGULATION
40 CFR part 60,
Subpart VV
40 CFR pari 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR pari 63.
Subpart H
40 CFR part 63.
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Calibration
(concluded)


• Phase III mixture of methane in air at
concentration of about, but less than
10,000 ppm for agitators
2,000 ppm for pumps in food/ medical
service
5,000 ppm for pumps in polymerizing
monomer service
1,000 ppm for all other pumps
500 ppm for all other equipment
Phases II and III exception under certain
conditions may calibrate up to 2,000 ppm
higher than (he leak definition

"No delectable
emissions"
monitoring
Background level determined by Method 21
Traverse probe as close to the potential
leak interface as possible as described in
Method 21
Calculate arithmetic difference between the
maximum concentration indicated by the
instrument and the background level
compared to 500 ppm to determine
compliance
Background level determined by Method 21
Traverse probe as close to the potential leak
interface as possible as described in Method
21
Calculate arithmetic difference between the
maximum concentration indicated by the
instrument and the background level
compared to 500 ppm to determine
compliance
Background level determined by Method 21
Traverse probe as close to the potential leak
interface as possible as described in Method
21
Calculate arithmetic difference between the
maximum concentration indicated by (he
instrument and the background level compared
(o 500 ppm to determine compliance
Background level determined by Method 21
Traverse probe as close to the potential leak
interface as possible as described in Method
21
Calculate arithmetic difference between the
maximum concentration indicated by ihe
instrument and the background level
compared to 500 ppni to determine
compliance

-------
SUMMARY OF REGULATIONS
page A-51

REGULATION
Test Methods and
Procedures
40 CFR pari 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Noi "in service"
demonstration
Equipment must be demonstrated not to be
in VOC service (t e , VOC content never
greater than 10% by weight)
Equipment is presumed to be in VHAP
service unless demonstrated that the VHAP
content can never reasonably expected to
exceed 10 percent by weight
Equipment is presumed to be in organic HAP
service unless demonstrated that the organic
HAP content can never reasonably expected to
exceed 5 percent by weight
Test each component to determine whether
it contains or contacts a hazardous waste
with organic concentration of 10 percent by
weight or greater

For demonstration
For demonstration

For demonstration

For demonstration

Use procedures that conform to ASTM E-
260, E-168, E-169 to determine percent
VOC in process fluid that is contained or
contacts a piece of equipment
Use procedures that conform to ASTM
Method D-2267
Use Method 18 of 40 CFR part 60, appendix
A to determine percent organic HAP
Use ASTM Methods D 2267-88, E 169-87,
E 168-88, E260-85, or Method 9060 or
8240 of SW-846

Engineering judgement may be used to
estimate (lie VOC content if piece of
equipment had not been shown previously
to be in VOC service
Engineering judgment may be used to
determine percent VHAP clearly does not
exceed 10 percent
Engineering judgment may be used to
determine percent organic HAP does not
exceed 5 percent
Engineering judgment may be used to
estimate organic concentration

Administrator will require use of ASTM
Method D-2267b in event of disagreement
to determine VOC content
Administrator will require use of ASTM
Method D-2267 in event of disagreement to
determine VOC content
Owner/operator may instead determine
organic HAP content does not exceed 5
percent by weight
Regional Administrator will require the use
of ASTM Methods D 2267-88, E 169-87, E
168-88, E260-85, or Method 9060 or 8240
of SW-846 in the event of disagreement to
determine VOC content

Compounds determined by EPA to have
negligible photochemical reactivity can be
excluded in determining VOC content of a
process fluid
If owner or operator determines that a piece
of equipment is in VHAP service,
determination can only be revised by
following demonstration procedures


If owner or operator determines that a piece
of equipment contains or contacts a
hazardous waste with an organic
concentration of at least 10% be weight, the
determination can only be revised by
following the demonstration procedures
Samples
Representative of process fluid that is
contained in or contacts the equipment or
the gas being combusted in flare
Representative of process fluid that is
contained in or contacts the equipment or
the gas being combusted in flare
Representative of process fluid that is
contained in or contacts the equipment
Representative of the highest total organic
content hazardous waste (hat is contained in
or contacts the equipment
Vapor pressures
Standard reference texts or
ASTM D-2879
Not specified

Standard reference texts or
ASTM D-2879-86

-------
SUMMARY OF REGULATIONS
page A-52
Test Methods and
Procedures
REGULATION
40 CFR pari 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Flare Compliance
Visible emissions Method 22
Presence of flame thermocouple or
equivalent
Exit velocity Method 2, 2A, 2C, or 2D
Component concentration Method 18 and
ASTM D 2504-67
Net Heat of Combustion Published values
or ASTM D 2382-76, if published values
not available or cannot be calculated
Visible emissions Method 22
Presence of flame thermocouple or
equivalent
Exit velocity Method 2, 2A, 2C, or 2D
Concentration Method 18 or ASTM
D2509-67
Net Heat of Combustion published value
or ASTM D2382-76, if published values not
available or cannot be calculated
Visible emissions Method 22
Presence of flame thermocouple or
equivalent
Exit velocity Method 2, 2A, 2C, or 2D
Concentration Method 18
Net Heal of Combustion published value or
ASTM D2382-76, if published values not
available or cannot be calculated
Visible emissions Method 22
Presence of flame heal sensing monitoring
device with a continuous recorder that
indicates the continuous ignition of the pilot
flame
Exit velocity Method 2, 2A, 2C, or 2D
Concentration Method 18
Net Heal of Combustion published value
or ASTM D2382-76, if published values not
available or cannot be calculated
Batch Processes -
Pressure Test with
Gas or Vacuum
Not applicable
Not applicable
Pressurize to operating pressure or place under
vacuum
Turn off once test pressure or vacuum is
obtained
Test for at least (5 minutes
Calculate change in pressure
Use pressure measurement device with
accuracy of +2 5 millimeters of mercury
Alternative equivalent procedures are allowed
provided alternative is capable of detecting a
pressure loss or rise
Not applicable

-------
SUMMARY OF REGULATIONS
page A-53

REGULATION
Test Methods and






Procedures
40 CFR part 60,
40 CFR part 61,
40 CFR part 61,
40 CFR part 63,
40 CFR part 63,
40 CFR part 264,

Subpart VV
Subpart J
Subpart V
Subpart H
Subpart I
Subpart BB






40 CFR part 265,






Subpart BB
Batch Processes -
Pressure Test with
Liquid
Not applicable
Not applicable
Fill with test liquid until normal operating
pressure is obtained
Test for at least 60 minutes, unless test fails
before then
Inspect each seal for indications of fluid loss
If indications are found, a leak is detected
Alternative equivalent procedures are allowed
provided alternative is capable of detecting
fluid loss
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-54

REGULATION
Recordkeeping
Requirements
40 CFR pari 60,
Subpart VV
40 CFR part 61.
Subpart J
40 CFR pan 61,
Subpart V
40 CFR pan 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR pan 264,
Subpart BB
40 CFR part 265,
Subpart BB
Consolidated
Recordkeeping
An owner or operator of more than one
affected facility subject to this subpart
may use one recordkeeping system if the
system identifies each record by facility
An owner or operator of more than one
process unit subject to this subpart may
use one recordkeeping system if the
system identifies each record by process
unit
An owner or operator of more than one
process unit subject to this subpart may
use one recordkeeping system if the
system identifies each record by process
unit and the program being implemented
for each type of equipment
An owner or operator of more than one
hazardous waste management unit
subject to this subpart may use one
recordkeeping system if the system
identifies each record by hazardous
waste management unit
When leak detected
Tafieme Requirements
Tafieina Retirements
Tassine Reouirements
TaKjnnE Retirements

• a weather-proof and readily visible
identification, marked with (he
equipment ID number, attached to the
leaking equipment
• a weather-proof and readily visible
identification, marked with the
equipment ID number, attached to the
leaking equipment
• a weather-proof and readily visible
identification, marked with the
equipment ID number, attached to the
leaking equipment
• a weather-proof and readily visible
identification, marked with the
equipment ID number, date evidence
of potential leak found (heavy liquid
service only), and date leak detected,
attached to the leaking equipment

• ID may be removed after it has been
repaired, except for valves
• ID may be removed after it has been
repaired, except for valves
• ID may be removed after it has been
repaired, except for valves and
connectors
• ID may be removed after it has been
repaired, except for valves

• for valves, ID may be removed after
2 months of monitoring with no teaks
detected
• for valves, ID may be removed after
2 months or monitoring with no leaks
detected
• for valves and connectors, ID may be
removed after it has been monitored
as specified and no leak has been
detected during the follow-up
monitoring
• for valves, ID may be removed after
2 months of monitoring with no leaks
detected

Loe Retirements
Loe Retirements

Lob Retirements

Lob Reouirements

• instrument and operator ID numbers
and equipment ID number
• instrument and operator ID numbers
and equipment ID number
• instrument and equipment ID number,
and operator name, initials, and ID
number
•	instrument and operator ID numbers
and equipment ID number
•	date evidence of potential leak found
(only for equipment in heavy liquid
service, pressure relief devices in
light liquid service, and flanges and
other connectors)

• date leak detected
• date leak detected

• date leak detected

• date leak detected

(Continued on next page)
(Continued on next page)
(Continued on next page)
(Continued on next page)

-------
SUMMARY OF REGULATIONS
page A-55
Recordkeeping
Requirements
REGULATION
40 CFR pari 60,
Subpart VV
40 CFR pan 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR pari 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart SB
40 CFR part 265,
Subpart BB
When leak delected
(concluded)
dates of each attempt to repair leak
repair methods applied in each
attempt to repair
"above 10,000" tf maximum
instrument reading after each repair
attempt is >. 10,000 ppm
"repair delayed" and reason for delay
if leak is not repaired within 15
calendar days after detection
signature of owner/operator whose
decision it was that repair could not
be effected without a process
shutdown
expected date of successful repair if
leak is not repaired within the 15
days
•	dates of process unit shutdown that
occurred while the equipment ts
unrepaired
•	date of successful repair of the leak
Retain for 2 years in readily accessible
location
•	dales of each attempt to repair leak
ซ repair methods applied in each
attempt to repair
•	"above 10,000" if maximum
instrument reading after each repair
attempt is >. 10,000 ppm
•	" repair delayed" and reason far delay
if leak is not repaired within 15
calendar days after detection
•	signature of owner/operator whose
decision it was that repair could not
be effected without a process
shutdown
expected date of successful repair if
leak is not repaired within the 15 days
•	dates of process unit shutdown that
occurred while the equipment \s
unrepaired
*	date of successful repair of the leak
Retain for 2 years in readily accessible
location
dates of firs) attempt to repair leak
•	maximum instrument reading after
successful repair or determined to be
nonreparable
•	"repair delayed" and reason for delay
if leak is not repaired within IS
calendar days after detection
•	documentation of sufficient supply of
spare paits on-site before depletion
and reason for depletion if repair
delayed because stocked parts were
depleted
•	ID of connectors open or otherwise
had the seal broken since last
monitoring period, and dates and
results of follow-up monitoring
•	dates and results of monitoring
•	dales of process unit shutdown that
occurred while the equipment is
unrepaired
•	date of successful repair of the leak
Retain for 2 years in a manner that can
be readily accessed al the plant sue
dates of each attempt to repair leak
repair methods applied in each
attempt lo lepair
"above 10,000" if maximum
instrument reading after each repair
attempt is >. 10,000 ppm
"repair delayed" and reason for
delay if leak is not repaired within 15
calendar days after detection
signature of owner/operator whose
decision it was that repair could not
be effected without a unii shutdown
expected dale of successful repair tf
leak is not repaired within the 15
days
documentation supporting delay of
repair of a valve
• dale of successful repair of the leak
Log to be kept in the facility operating
record for 3 years

-------
SUMMARY OF REGULATIONS
page A-56

REGULATION
Recordkeeping






Requirements
40 CFR part 60,
40 CFR part 61,
40 CFR part 61,
40 CFR part 63.
40 CFR part 63,
40 CFR part 264,

Subpart VV
Subpart J
Subpart V
Subpart H
Subpart I
Subpart BB
40 CFR part 265,
Subpart BB
Closed vent
• detailed schematics, design
• detailed schematics, design
Design Specifications and Performance
Description and date of each
sysiems and control
specifications, and piping and
specifications, and piping and
Demonstration

modification made to the closed-vent
devices
instrumentation diagrams
instrumentation diagrams


system or control device design




• detailed schematics, design


• dates and descriptions of any changes
• dales and descriptions of any changes
specifications, and piping and
Identification of operating parameter,

in design specifications
in design specifications
instrumentation diagrams
description of monitoring device, and






diagram of monitoring sensor

• description of parameter(s) to be
• description of parameler(s) to be
• dates and descriptions of any changes
location(s) for the following types of

monitored to ensure proper operation
monitored to ensure proper operation
in design specifications
monitoring devices vent stream flow.

and maintenance
and maintenance



temperature, heal sensing, organic




• description of parameter(s) to be
concentration, regeneration cycles for

• explanation of selection of
• explanation of selection of
monitored to ensure proper operation
carbon beds, and good combustion

parameter(s)
parameters)

and maintenance

practices

• periods when not operated according
• periods when not operated according
• flare design and compliance
Monitoring, operating, and inspection

to design
to design, including when flare pilot
demonstration results
information required by paragraphs


light is out



งง63 1033 (0 through (j)

• dates of startups and shutdowns of


• explanation of selection of


control devices and closed-vent
• dates of startups and shutdowns of
parameter(s)

Date, time, and duration of each period

systems
control devices and closed-vent


that occurs while the control device is


systems

The design specification and
operating when any monitored

When no leak detected


performance demonstration records are
parameter exceeds the value established

- record that instrument of visual
Keep these records in a readily
to be kept for the life of the equipment
in the control device design analysis

inspection was conducted
accessible location





- date of inspection




Explanation for each period for which

- statement that no leaks were




monitored parameter exceeded the

detected




established value

For unsafe and difficult to inspect parts




For carbon adsorption systems, dale

of closed-vent system




when existing carbon in the control

- identification




device is replaced with fresh carbon or.

- explanation




if monitoring the organic concentration

- plan for inspecting equipment




to determine breakthrough, date and
time of carbon breakthrough and date

Keep these records in a readily




when existing carbon is replaced with

accessible location




fresh carbon

-------
SUMMARY OF REGULATIONS
page A-57
Recordkeeping
Requirements
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Closed vent
systems and control
devices (concluded)


Records of Operation
•	records of operation of closed-vent
systems and control devices
•	dates and duration when closed-vent
systems, and control devices not
operated according to design
•	dates and duration when monitoring
systems/devices are nonoperative
•	dates of startups and shutdowns
•	records of closed-vent inspections
The records of operation are to be kept
for 2 years
Part 264
• For "other" control devices, ihe
Regional Administrator will specify
the appropriate recordkeeping
requirements
Part 265
ฆ For "other" control devices,
monitoring and inspection
information indicating proper
operation and maintenance
Keep these records up-to-date in the
facility operating record Operating
information is lo be kept for 3 years
Visual inspections
Not applicable
Not applicable
Documentation that inspection was
conducted
Dates of inspection
These records are to be kept for 2 years
Not applicable
All equipment
List of ID numbers of subject equipment
List of ID numbers of equipment
designated for no detectable emissions
and signed by owner/operator
List of ID numbers for pressure relief
devices in gas/vapor service
For each compliance test for
components designated for no detectable
emissions
•	dates conducted
•	background level measured
•	maximum instrument reading
List of ID numbers of equipment in
vacuum service
List of ID numbers of subject equipment
(except welded fittings)
List of ID numbers of equipment
designated for no detectable emissions
and signed by owner/operator
List of ID numbers for pressure relief
devices in gas/vapor service
For each compliance test for components
designated for no detectable emissions
•	dates conducted
•	background level measured
•	maximum instrument reading
List of ID numbers of equipment in
vacuum service
List of ID numbers of subject equipment
(except certain connectors)
Location of equipmenl on site plan, log
entries, etc
Connectors do not need to be
individually identified if all connectors in
a designated area or length of pipe are
identified as a group and the number of
connectors is identified
Schedule by process unit for monitoring
connectors and valves
Identification of equipment in HAP
service by tagging, identified on a plant
site plan, in log entries, or other
methods
List of ID numbers of subject
equipment (except welded fittings)
List of ID numbers of equipment
designated for no detectable emissions
and signed by owner/operator
List of ID numbers for pressure relief
devices in gas/vapor service
For each compliance test for
components designated for no detectable
emissions
•	dates conducted
•	background level measured
•	maximum instrument reading
List of ID numbers of equipment in
vacuum service

-------
SUMMARY OF REGULATIONS
page A-58
Recordkeeping
Requirements
REGULATION
40 CFR part 60,
Subpart VV
40 CFR pan 61,
Subpart J
40 CFR part 61.
Subpart V
40 CFR part 63,
Subpart H
40 CFR pan 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
All equipment
(continued)
Maintain records in a readily accessible
location
Maintain records for 2 years in a readily
accessible location
List of ID numbers for equipment
equipped with a closed-vent system and
control device
For each compliance test for components
designated for no detectable emissions
•	dates conducted and results
•	background level measured
•	maximum instrument reading.
List of ID numbers of compressors and
pressure relief devices complying with
an instrument reading of less than 500
ppm above background standard
ID of surge control vessels or bottoms
receivers equipped with a closed-vent
system or control device.
ID of pressure relief devices equipped
with rupture disks
ID of instrumentation systems (individual
components need not be identified)
ID of screwed connectors complying
with ง63 174(c)(2) Identification can be
by grouping or area
ID of connectors opened since last
monitoring period
List of valves and connectors removed
from or added to the process if net
credits for the removal or the valves or
connectors are expected to be used
Documentation of ihe integrity of the
weld for removed connectors
For open-ended valves or lines, list of
ID numbers of subject valves and lines
ID numbers for equipment that contains
or contacts hazardous waste with an
organic concentration of at least 10%
by weight for a period of fewer than
300 hours per year
Equipment identification number and
hazardous waste management unit
identification
Information to be kept for pumps
equipped with a dual mechanical seal
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to the criteria and the
reason for change
Approximate facility location on facility
plot
Type of equipment
Percent-by-weight of total orgamcs in
hazardous waste at the equipment
Hazardous waste slate at the equipment
Method of compliance
Retain in a log that is kept in the facility
operating record

-------
SUMMARY OF REGULATIONS
page A-59
Recordkeeping
Requirements
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63.
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
All equipment
(concluded)


Design criteria, explanation, and
changes to criteria of any pumps
equipped with a dual mechanical seal
Copies of periodic reports (if database
not capable of generating such)
Maintain records in a manner that is
readily accessible at the plant site

Unsafe to Monitor
Equipment
List of ID numbers
Planned schedule for monitoring
List of ID numbers
Planned schedule for monitoring
List of ID numbers
Planned schedule for monitoring
List of ID numbers
Planned schedule for monitoring
Difficult to Monitor
Equipment
List of ID numbers
Explanation for designation
Planned schedule for monitoring
List of [D numbers
Explanation for designation
Planned schedule for monitoring
List of ID numbers
Explanation for designation
Planned schedule for monitoring
List of ID numbers
Explanation for designation
Planned schedule for monitoring
Unsafe to Repair
Connectors
Not applicable
Not applicable
List of ID numbers
Explanation for designation
Not applicable
Valves complying
with alternative
standard for skip-
periods
Schedule of monitoring
Percent valves leaking during each
monitoring period
Schedule of monitoring
Percent valves leaking during each
monitoring period
Not applicable
Schedule of monitoring
Percent valves leaking during each
monitoring period
Barrier fluid and
seal systems
Design criteria for indicating failure
Explanation for selected criteria
Any changes to selected criteria and
reasons for change
Design criteria for indicating failure
Explanation for selected criteria
Any changes to selected criteria and
reasons for change
Design criteria for indicating failure
Explanation for selected criteria
Any changes to selected criteria and
reasons for change
Design criteria for indicating failure
Explanation for selected criteria
Any changes to selected criteria and
reasons for change

-------
SUMMARY OF REGULATIONS
page A-60

REGULATION
Recordkeeping
Requirements
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR pan 61,
Subpart V
40 CFR part 63.
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Exemptions
Determinations
Analysis demonstrating facility design
capacity
Statement listing feed or raw materials
and products from facility and analysis
demonstrating whether these chemicals
are heavy liquids or beverage alcohols
Analysis demonstrating facility design
capacity
Analysis demonstrating thai equipment is
not in VHAP service
Information and data used to
demonstrate that equipment is not in
organic HAP service, is in HAP service
fewer than 300 hours per year, or is in
heavy liquid service
Analysis determining the design
capacity of the unit
Statement listing the hazardous waste
influent to and effluent from each
subject unit and an analysis determining
whether these wastes are heavy liquids

Analysis demonstrating that equipment is
not in VOC service




Up-to-date analysis and supporting
information to determine whether or
equipment is subject to this subpart A
new determination is required when the
owner/operator takes any action that
could result in an increase in the total
organic content of the waste contained
in or contacted by closed vent systems
and control devices previously
determined not subject to this rule
Not "In service"
Information and data used to
demonstrate that a piece of equipment is
not in VOC service
Information and data used to
demonstrate that a piece of equipment is
not in VHAP service
Information, data, and analysis used to
demonstrate that a piece of equipment or
process unit is m heavy liquid service
Not specified
Batch Processes
Not applicable
Not applicable

Momtorine of Batch Processes
List of equipment added since last
monitoring period
Record inspection performed if no leaks
found
Documentation of any switch from batch
process monitoring to pressure testing or
vice versa
Identify equipment on a plant site plan,
in log entries, or by other appropriate
methods
Not applicable

-------
SUMMARY OF REGULATIONS
page A-61

REGULATION
Recordkeeping
Requirements
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 26S,
Subpart BB
Batch Processes
(concluded)



Pressure Test of Batch Processes
ID of each product, or product code,
produced during calendar year
Records demonstrating the proportion of
the time during the calendar year the
equipment is in use in a batch process
that is subject to tho provisions of this
subpart
Date and results of monitoring for
equipment added to the batch process
unit since the last monitoring period
Physical tagging not required; may be
identified on plant site plan, in log
entries, other appropriate methods
Dates of each pressure test, the test
pressure, and the pressure drop observed
during the pressure test
Records of any visible, audible, or
olfactory evidence of fluid loss
Failure of two consecutive pressure
tests. Record the following and keep for
two years'
•	date of each pressure test
•	date of each leak repair attempt
•	repair methods applied
•	reason for delay of repair
•	expected and actual delivery date of
replacement equipment
•	date of successful repair


-------
SUMMARY OF REGULATIONS
page A-62

REGULATION
Recordkeeping
Requirement1;
40 CFR pari 60,
Subpart VV
40 CFR part 61.
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
No detectable
emissions
Background level
Maximum instrument reading
Background level
Maximum instrument reading
Not applicable
Background level
Maximum instrument reading

-------
SUMMARY OF REGULATIONS
page A-63
Recordkeeping
Requirements
REGULATION
40 CFR pari 60.
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61.
Subpart V
40 CFR part 63.
Subpart H
40 CFR part 63,
Subpart 1
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Q1P
Not applicable
Not applicable

If leak not repaired within IS calendar
days of discovery, reason for teak repair
delay and expected date of successful
repair
Records of all analyses required under
งง63 175(e) and ง63.176(d). including
•	list identifying areas associated with
poorer than average performance and
the associated service characteristics
of the stream, the operating
conditions, and maintenance practices
•	reasons for rejecting specific
candidate superior emission
performing valve or pump technology
from performance trials
•	list of candidate superior emission
performing valve or pump
technologies and documentation of
performance trial program items
•	beginning date and duration of
performance trials of each candidate
superior emission performing
technology
Records documenting the quality
assurance program
Records indicating all valves or pumps
replaced or modified are in compliance
with the quality assurance requirements
Records documenting compliance with
the 20 percent or greater annual
replacement rate for pumps
Information and data showing company
has less than 100 employees
Not applicable

-------
SUMMARY OF REGULATIONS
page A-64
Recordkeeping
Requirements
REGULATION
40 CFR part 60,
Subpart VV
40 CFR pari 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
QIP - Reasonable
further progress
Not applicable
Not applicable
For each valve in each process unit
subject to the QIP
•	maximum instrument reading
observed in each monitoring
observation before repair, response
factor for the stream (if appropriate),
instrument model number, and date of
the observation
•	whether the valve is in gas or light
liquid service
•	if a leak is delected, the repair
methods used and the instrument
readings after repair
If data analyzed as part of a larger
analysis program, describe any
maintenance or QIP intended lo improve
emission performance
Percent leaking valves and rolling
average percent reduction observed each
quarter
Beginning and end dates while meeting
the requirements of the QIP
Not applicable

-------
SUMMARY OF REGULATIONS
page A-65
Recordkeeping
Requirements
REGULATION
40 CFR pari 60,
Subpart VV
40 CFR pari 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
QIP - Technology
review and
improvement
Not applicable
Not applicable
For valves
Type and manufacturer, design,
materials of construction, packing
material, and year installed
Service characteristics of the stream
(e g , operating pressure, temperature,
line diameter, corrosivity)
Whether in gas/vapor or light liquid
service
If a leak is detected, the maximum
instrument reading observed before a
repair, response factor for stream if
adjusted, instrument model number, and
date of observation
Repair methods used and the instrument
readings after the repair
Description of any maintenance or
quality assurance program used in the
process unit that are intended to improve
performance
Percent leaking valves observed each
quarter
Documentation of all inspections and
recommendations for design or
specification changes to reduce leak
frequency
Beginning and end dates while meeting
requirements of (he QIP
Not applicable

-------
SUMMARY OF REGULATIONS
page A-66

REGULATION
Recordkeeping
Requirements
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 61,
Subpart V
40 CFR part 63.
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
QIP - Technology
review and
improvement
(concluded)



For Dumos
Type and manufacturer, seal type and
manufacturer, pump design, materials of
construction, barrier fluid or packing
material, and year installed
Service characteristics of the stream,
discharge pressure, temperature, flow
rate, corrosivity, and annual operating
hours
Maximum instrument readings observed
before repair, response factor for the
stream, instrument number, and date of
observation
If a leak is detected, repair methods used
and the instrument readings after the
repair
Rolling average percent leaking pumps
Documentation of all inspections and
recommendations for design or
specification changes to reduce leak
frequency
Beginning and end dates while meeting
requirements of the QIP

Enclosed Vent
Process
Not applicable
Not applicable

ID of process units and organic HAPs
handled
Schematic of process unit, enclosure,
and closed-vent system
Description of system used to create
negative pressure
Not applicable

-------
SUMMARY OF REGULATIONS
page A-67
Reporting
Requirements
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR pari 61,
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Initial Report
Process unit identification
Number of valves in gas/vapor and light
liquid service, excluding those
designated for no detectable emissions
Number of pumps in light liquid service,
excluding those designated for no
detectable emissions or equipped with a
compliant closed-vent system or control
device
Number of compressors, excluding
those designated for no detectable
emissions or equipped with a compliant
closed-vent system and control device
For each source
•	equipment identification number
•	process unit identification
•	type of equipment
•	percent weight VHAP
•	process fluid state
•	method of compliance
Reporting schedule for submittal of
subsequent semiannual reports
An owner or operator is also required to
submit a statement notifying (he
Administrator that the requirements of
this subpart are being implemented For
existing sources and new sources with an
initial startup dale preceding the effective
date, this notification is to be submitted
within 90 days of the effective date For
new source with an initial startup date
after the compliance date, this
notification is to be submitted with the
application for approval of construction
Initial Notification
•	name and address of owner/operator
•	address of facility (physical location)
•	identification of subject processes
•	compliance statement
•	statement of whether a source can
achieve compliance by the applicable
compliance date
Notification of Compliance Status (for
each subiect process unit)
A For each subject unit
•	process unit identification
•	number of each equipment type
(except those in vacuum service)
•	method of compliance
•	planned schedule for each phase (for
light liquid pumps and gas/vapor
valves)
B Batch processes
•	batch products or product codes
•	planned schedule for testing
C Enclosed-vented process units
•	process unit identification
•	description of negative pressure
system and control device
Not specified

-------
SUMMARY OF REGULATIONS
page A-68

REGULATION
Reporting






Requirements
40 CFR part 60,
40 CFR part 61.
40 CFR part 61,
40 CFR part 63,
40 CFR part 63,
40 CFR part 264,

Subpart VV
Subpart J
Subpart V
Subpart H
Subpart 1
Subpart BB






40 CFR part 265,






Subpart BB
Subsequent
Process unit identification
Process unit identification
Submit the following information semi-
NOTE The following is applicable to
Semiannual/



annually starting 6 months after the
40 CFR part 264, subpart BB only
Periodic Reports
The following information by month in
The following information by month in
Notification of Compliance


the reporting period
the reporting period



The EPA identification number, name.




• the number of valves, pumps,
and address of the facility

• number of valves, pumps, and
• number of valves, pumps, and
compressors, agitators, connectors,


compressors for which leaks were
compressors for which leaks were
and screwed connectors for which
The following information by month in

delected
detected

leaks were detected
the reporting period

• number of valves, pumps, and
• number of valves, pumps, and
• the percent leakers for valves, pumps,
• equipment identification number of

compressors for which leaks were not
compressors for which leaks were nol
conneciors, and screwed connectors
each valve, pump, and compressor

repaired as required
repaired as required


for which leaks were not repaired as




• the total number of valves, pumps,
required

• the facts thai explain each delay of
• the facts that explain each delay of
connectors, and screwed connectors


repair, and where appropriate, why a
repair, and where appropriate, why a
monitored

• dates of hazardous waste management

process unit shutdown was technically
process unit shutdown was technically


unit shutdowns thai occurred within

infeasible
infeasible

• the number of valves, pumps,
the Semiannual reporting period




compressors, agitators, connectors,


Dales of process unit shutdowns that
Dates of process unit shutdowns that
and screwed connectors for which
• dates when the required control

occurred within (he semiannual
occurred within the semiannual reporting
leaks were not repaired
device exceeded or operated outside

reporting period
period



design specifications and was not




• identification of the number of valves
corrected within 24 hours, the

Revisions to items reporied in the initial
Revisions to items reported in the initial
and connectors determined to be
duration and cause of each

semiannual report if changes have
semiannual report if changes have
nonreparable

exceedance, and any corrective

occurred since the initial semiannual
occurred since the initial semiannual


measures taken

report or subsequent revisions to the
report or subsequent revisions to the
• explanation of why repairs delayed and


initial semiannual report
initial semiannual report
why process unit shutdown was
If during the semiannual reporting




infeasible

period, pumps, valves, and connectors

Repori of all performance tests in




are repaired as required and the control

accordance with ง60 8


• notification of change in connector
device does not exceed or operate




monitoring alternatives (if applicable)
outside of design specifications for






more than 24 hours, a report to the




Revisions to items reported in the
Regional Administrator is not required




notification of compliance status if





method of compliance has changed since





the last report






Information listed under Notification of





Compliance Status for process units with





later compliance dates





For "no detectable emissions"





components all monitoring to show





compliance



-------
SUMMARY OF REGULATIONS
page A-69

REGULATION
Reporting
Requirements
40 CFR part 60,
Subpart VV
40 CFR part 61,
Subpart J
40 CFR part 6),
Subpart V
40 CFR part 63,
Subpart H
40 CFR part 63,
Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Batch Processes -
Pressure Testing
Not applicable
Not applicable

Batch product process equipment train
identification
Number of pressure tests conducted.
Number of failed pressure tests
Explanation of delay of repairs
All monitoring results
Not applicable
Other
Notification 90 days prior to election to
comply with either alternative standard
for valves in gas/vapor service
Report of all performance test in
accordance with ง60 8, except 30 day
notification required only for initial
performance test
Notification 90 days prior to complying
with either alternative standard for
valves in gas/vapor service
Report of all performance test and
monitoring to determine compliance with
no detectable emissions and with
ง63 243-1 and -2 conducted within the
semiannual reporting period
Not applicable

Not applicable

-------
APPENDIX B
EQUIPMENT LEAK REGULATIONS: SUMMARY OF DIFFERENCES
page
GENERAL ASPECTS OF RULE
Applicability	B-l
Exemptions 	B-l
Definitions	B-2
Equipment	B-2
Process Unit	B-3
Repaired 	B-3
Equipment Identification	B-3
SPECIFIC COMPONENT SUMMARIES
Valves, Gas/Vapor or Light Liquid Service 	B-4
Valves, Heavy Liquid Service 	B-5
Alternative Standards for Valves	B-6
Pumps, Light Liquid Service	B-7
Pumps, Heavy Liquid Service 	B-9
Pressure Relief Devices, Gas/Vapor Service	 B-10
Pressure Relief Devices, Light Liquid or Heavy Liquid Service 	 B-10
Compressors 	 B-ll
Sampling Connection Systems 	 B-12
Open-Ended Valves or Lines	 B-12
Flanges and Other Connectors (All Services)	 B-l3
Connectors, Gas/Vapor or Light Liquid Service	 B-l3
Connectors, Heavy Liquid Service 	 B-l3
Agitators, Gas/Vapor Service or Light Liquid Service	 B-l3
Agitators, Heavy Liquid Service	 B-l3
Instrumentation Systems	 B-14
Product Accumulator Vessels	 B-14
Surge Control Vessels and Bottoms Receivers	 B-14
Closed-Vent Systems and Control Devices	 B-l5
DELAY OF REPAIR		B-17
QUALITY IMPROVEMENT PROGRAMS		B-18
EQUIVALENCE OF (OR ALTERNATIVE) MEANS OF
EMISSIONS LIMITATION	 		B-19

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ALTERNATIVE MEANS OF EMISSION LIMITATION:
BATCH PROCESSES	 B-19
ALTERNATIVE MEANS OF EMISSION LIMITATION:
ENCLOSED-VENTED PROCESS UNITS 	 B-19
TEST METHODS AND PROCEDURES	 B-20
RECORDKEEPING REQUIREMENTS 	 B-23
REPORTING REQUIREMENTS	 B-27

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SUMMARY OF REGULATION DIFFERENCES
page B-l

REGULATION
General Aspects of
Rule
40 CFR Pari 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
APPLICABILITY
All equipment within a
process unit in the
sy/itlietic organic
manufacturing industry that
commences construction,
reconstruction, or
modification after 1/5/81
A list of SOCMI chemicals
produced as intermediates
or final products by
process units is provided to
determine applicability
Equipment that is operated
in benzene service
Equipment operated in
volatile HAP (VHAP)
service after the date for
which pan 61 regulations
have been promulgated
Equipment in organic HAP
service operated at least 300
hours per year at facilities
for which part 63
regulations have been
adopted and that cross-
reference this subpart
A list of organic HAP is
provided to determine
applicability
Equipment in organic HAP
service (see Definitions)
operated at least 300 hours
per year in the following
types of processes Styrene-
butadiene rubber production,
polybutadiene rubber
production, processes
producing five specific
agricultural chemicals,
processes producing six
specific types of
polymers/resins or other
chemicals, pharmaceutical
processes using carbon
tetrachloride or methylene
chloride, and five specified
polymers/resins a
Specific HAPs are
designated for determining
applicability
Equipment at facilities that
treat, store, or dispose of
hazardous wastes that
contains or contacts
hazardous waste with
organic concentrations of at
least 10 percent by weight
that are managed in units
subject to the permitting
requirements of part 270 or
hazardous waste recycling
units located at such
facilities otherwise subject
to the permitting
requirements of part 270
EXEMPTIONS
Any affected facility with
design capacity to produce
less than 1,000 Mg per
year
Any affected facility that
has no equipment in VOC
service
Any affected facility that
produces heavy liquid
chemicals only from heavy
liquid feed or raw
materials
Any affected facility that
produces beverage alcohol
Any equipment in benzene
service located at plant
designed to produce or use
less than 1,000 Mg of
benzene per year
Any process unit that has
no equipment in benzene
service
Coke by-product plants
Exempt from part 60 if
subject to part 61
None specified
Research and development
facilities
Exempt from part 60 and
from part 61 if subject to
part 63
Research and development
facilities
Facilities that do not have
the designated HAP(s) need
only document the basis for
this determination
Exempt until no later than
April 22. 1997, if plant site
emus less than 10 tpy of any
individual HAP and less
than 25 tpy of any
combination of HAP
None specified

-------
SUMMARY OF REGULATION DIFFERENCES
page B-2
General Aspects of
Rule
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63.
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
DEFINITIONS
"In gas/vapor
service"
The piece of equipment
contains process fluid that
is in gaseous state at
operating conditions
A piece of equipment contains process fluid (hat is in the
gaseous state at operating conditions
A piece of equipment in organic hazardous air pollutant
(HAP) service contains a gas or vapor at operating
conditions
The piece of equipment
contains or contacts a
hazardous waste stream that
is in the gaseous state at
operating conditions
"In heavy liquid
service"

Not applicable

"In light liquid
service"

Not applicable

"In liquid service"
Not applicable
A piece of equipment is not in gas/vapor service
A piece of equipment in organic HAP service is not in
gas/vapor service
Not applicable
"In VOC service"
The piece of equipment
contains or contacts a
process fluid that is at least
10 percent VOC by
weight
The piece of equipment contains or contacts a process fluid
that is at least 10 percent VOC by weight and the piece of
equipment is not in heavy liquid service (as defined under
40 CFR Part 60, subpart VV)
The piece of equipment contains or contacts a process fluid
lhat is at least 10 percent VOC by weight and the piece of
equipment is not in heavy liquid service (as defined under 40
CFR Part 60, subpart VV)
Not applicable
"lป VHAP service"
Not applicable
A piece of equipment either contains or contacts a fluid
(liquid or gas) lhat is at least 10 percent by weight a volatile
hazardous air pollutant (VHAP)
Not applicable
Not applicable
"In organic
hazardous air
pollutant or in
organic (HAP)
service"
Not applicable
Not applicable
A piece of equipment either
contains or contacts a fluid
(liquid or gas) that is at least
5 percent by weight total
organic HAP
A piece of equipment either
contains or contacts a fluid
(liquid or gas) that is at least
5 percent by weight of the
designated organic HAP
listed in ง63 190(b) of this
subpart
Not applicable
"In benzene service"
Not applicable
A piece of equipment
contains or contacts a fluid
(liquid or gas) that is at
least 10% benzene by
weight
Not applicable
Not applicable
Not applicable
EQUIPMENT

ADOS product accumulator vessels
ADDS agitators, surge control vessels, bottoms receivers,
and instrumentation systems


-------
SUMMARY OF REGULATION DIFFERENCES
page B-3
General Aspects of
Rule
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart 1
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
PROCESS UNIT
Components assembled to
produce, as intermediate or
final products, one or more
of the chemicals specified
in ง50 489 A process unit
can operate independently
if supplied with sufficient
feed or raw materials and
sufficient storage facilities
for the product
Equipment assembled to produce a VHAP or its derivatives
as intermediate or final products, or equipment assembled
to use a VHAP in the production of a product A process
unit can operate independently if supplied with sufficient
feed or raw materials and sufficient product storage
facilities
A chemical manufacturing process unit as defined in subpart
F of this part, a process unit subject to the provisions of
subpart I of this part, or a process unit subject to another
subpart in 40 CFR Part 63 that references this subpart
A contiguous area of land
on or in which hazardous
waste is placed, or the
largest area in which there
is significant likelihood of
mixing hazardous waste
constituents in (he same
c
area
REPAIRED
Equipment is adjusted, or
otherwise altered, in order
to eliminate a leak as
indicated by one of the
following an instrument
reading of 10,000 ppm or
greater, indications of
liquids dripping, or
indication by sensor that a
seal or barrier fluid has
Tailed
Equipment is adjusted, or otherwise altered, to eliminate a
leak
Equipment is adjusted, or otherwise altered, to eliminate a
leak as defined in the applicable sections of this subpart
Equipment is adjusted, or
otherwise altered, to
eliminate a leak
EQUIPMENT
IDENTIFICATION
None specified
Mark subject equipment in such a manner as to readily
distinguish from other pieces of equipment
Same as 40 CFR Part 61, but adds Identification does not
require physical tagging
Mark subject equipment in
such a manner as to readily
distinguish from other
pieces of equipment
a Processes producing styrene-butadiene rubber (butadiene and styrene emissions only) Processes producing polybutadiene robber (butadiene emissions only) Processes producing the following agricultural chemicals
(butadiene, carbon tetrachloride, methylene chloride, and ethylene dichlonde emissions only) Captafol (R), Captan (R), Chlorothaloml, Dacthal, and Tordon (R) acid Processes producing the following polymers/resins
and other chemicals (carbon tetrachloride, methylene chloride, tetrachloroethylene, chloroform, and ethylene dichloride emissions only) Hypalon (R), Oxybisphenoxarsine/l,3-dtisocyanate [OBPA (R)], polycarbonates,
polysulfide rubber, chlorinated paraffins, and symmetrical tetrachloropyndine Pharmaceutical production processes using carbon tetrachloride or methylene chloride (carbon tetrachloride and methylene chloride emissions
only) Processes producing the following polymers/resins and other chemicals (butadiene emissions only) tetrahydrophthahc anhydride (THPA), methlymethacrylate-butadiene styrene resins (MBS), butadiene-furfural cotrimer,
methlymethacrylate-acrylonitrile-butadiene-styrene (MABS) resins, and ethylidene norbornene
b "Chemical manufacturing process unit" means the equipment assembled and connected by pipes or ducts to process raw materials and to manufacture an intended product For the purposes of (his subpart, chemical
manufacturing process unit includes air oxidation reactors and their associaled product separators and recovery devices, reactors and their associated product separators and recovery devices, distillation units and their associated
distillate receivers and recovery devices, associated unit operations (as defined in this section), and any feed, intermediate, and product storage vessels, product transfer racks, and connected ducts and piping A chemical
manufacturing process unit includes pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves or lines, valves, connectors, instrumentation systems, and control devices or systems
A chemical process manufacturing unit is identified by its primary product
c Examples of hazardous waste management units include a surface impoundment, a waste pile, a land treatment area, a landfill cell, an incinerator, a tank and its associated piping and underlying containment system and
a container storage area A container alone does not constitute a unit, the unit includes containers and the land or pad upon which (hey are placed

-------
SUMMARY OF REGULATION DIFFERENCES
page
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Pari 61.
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE
Standards

Designates valves "in liquid service" not in
either "light liquid" or "heavy liquid"
service

Standards
Basic
Monitoring
Interval
Monthly that can go to quarterly
Monthly that can go to quarterly
Quarterly in Phases 1 and II
In Phase III, varies depending on percent
leaking
Monthly that can go to quarterly
Standards
Plants with
less than 250
valves in
organic HAP
service
Not applicable
Not applicable
In Phase III, can monitor quarterly (rather
than monthly) or comply with paragraphs
(d)(3) or (d)(4)
Not applicable
No
Detectable
Emissions

Not applicable

Unsafe-to-
Monitor
Interval

ADDS but not more frequently than the
periodic monitoring schedule otherwise
applicable

Difficult-to-
Momtor
Definition

ADDS or it is not accessible at anytime in
a safe manner

Difficult-to-
Monitor
Limit on
Number
No more than 3 0 percent of valves in
affected facility can be designated as difficult-
lo-monitor
None specified
No more than 3 0 percent of valves in
affected facility can be designated as
difficult-to-nionilor
None specified

-------
SUMMARY OF REGULATION DIFFERENCES
page
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Pari 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)


Leak
Definition
10,000 ppm
10,000 ppm
Phase I 10,000 ppm
Phase II 500 ppm
Phase III 500 ppm
10,000 ppm
Repairs

ADDS When repaired, monitor at least
once within first 3 months after repair

Exemptions

Equipment operated less than 300 hours per
year


VALVES, HEAVY LIQUID SERVICE
Standards

Not applicable

Leak
Definition
10,000 ppm
10,000 ppm
Monitoring 500 ppm
10,000 ppm
Repair

For valves in heavy liquid service that are
not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or
other indications of a leak have been
eliminated, no bubbles are observed at
potential leak sites during leak check with
soap solution, or system will hold a test
pressure


-------
SUMMARY OF REGULATION DIFFERENCES
page
Specific
Component
Summaries
REGULATION
40 CFR Part 60.
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart 1
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
ALTERNATIVE STANDARDS FOR VALVES
Allowable Percentage of Valves Leaking
Standard
Applies to "affected facilities"
Applies to "process units"
Not applicable
Applies to "hazardous waste management
units"
Notification
Not required
Notification required if compliance with
allowable percent is discontinued
Not required
Notification required if compliance with
allowable percent is discontinued
Skip Period Leak Detection and Repair
Standard

Not applicable

Calculation
Calculate percent leaking by dividing sum of
valves found leaking during current
monitoring and valves for which repair has
been delayed by the total number of subject
valves
Not specified

Not specified

-------
SUMMARY OF REGULATION DIFFERENCES
page
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
PUMPS, LIGHT LIQUID SERVICE
Standards

ADDS If located at unmanned plant site,
visual inspections required at least monthly
ADDS If located at unmanned plant site,
visual inspections required at least monthly





ADDS






Phase III






If the greater of either 10 percent of pumps
in a process unit (or source-wtde) or 3
pumps in a process unit (or source-wide)
leak, (hen implement technology review and
improvement QIP (This does not apply to
process unit if more than 90% of the pumps
in the unit are either dual mechanical seal or
designed with no externally activated shaft
penetrating the housing )

DMS
Barrier Fluid
Purges into
Process
zero VOC emissions
zero VHAP emissions
no similar statement
no detectable emissions
DMS
Barrier Fluid
System
in heavy liquid service and not in VOC
service
not in VHAP service and nol in VOC
service
not in light liquid service
must not be a hazardous waste with organic
concentrations 10 percent or greater by
weight
DMS
Indications of
Liquids
Dripping
Indications means a leak is detected
Indications require monitoring with
instrument A leak is delected if (l)the
presence of VHAP is detected, or (2) an
instrument reading is 10,000 ppm or greater
(total VOC) is measured
Indications require monitoring with
instrument A leak is detected if instrument
reading is 1,000 ppm or greater
Indications means a leak is delected
DMS Sensor
and Audible
Alarm

Daily observation or equipped with alarm
waived if located at an unmanned plant site
Check alarm monthly to ensure it is
functioning properly

-------
SUMMARY OF REGULATION DIFFERENCES
page B-8
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63.
Subpart I
40 CFR Pari 264,
Subpart BB
40 CFR Part 265,
Subpart BB
PUMPS, LIGHT LIQUID SERVICE (concluded)
No
Detectable
Emissions

Not provided Instead provides basic
exemption for pumps designed with no
externally actuated shaft penetrating the
pump housing (a specification under the
other standards for pumps designated for no
detectable emissions)

Leak
Definition
10,000 ppm
10,000 ppm
Phase I 10,000 ppm
Phase II 5,000 ppm
Phase III 5,000 ppm (polymerizing
monomers)
2,000 ppm (food/medical
services)
1,000 ppm (all other pumps)
10,000 ppm
Repair

For pumps in Phase III subject to the leak
definition of 1,000 ppm, repair is not
required unless instrument reading of 2,000
ppm or greater is detected

Tirst Attempt
at Repair
None specified
None specified
Best practices include, but are not limited
to
tightening of packing gland nuts
ensuring that the seal (lush is
operating at design pressure and
temperature
None specified
Exemptions

ADDS Use compliant closed-vent system
that transDorts leakaee back to the process
or to a compliant control device
Equipment operated less than 300 hours per
year


-------
SUMMARY OF REGULATION DIFFERENCES
page
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
PUMPS. HEAVY LIQUID SERVICE
Standards

Not applicable

Leak
Definition
10,000 ppm

Monitoring- 2,000 ppm
10,000 ppm
Repair

For pumps in heavy liquid service that are
not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or
other indications of a leak have been
eliminated, no bubbles are observed at
potential leak sites during leak check with
soap solution, or system will hold a test
pressure

Exemptions

Equipment operated less than 300 hours per
year


-------
SUMMARY OF REGULATION DIFFERENCES
page B-
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
PRESSURE RELIEF DEVICES. GAS/VAPOR SERVICE
Standards

ADDS
With RuDture Disk
After each release, replace rupture disk
within 5 calendar days

Repair

Not applicable

Exemptions

Equipment operated less than 300 hours per
year


PRESSURE RELIEF DEVICES, LIGHT LIQUID OR HEAVY LIQUID SERVICE
Standards

Leak
Definition
10,000 ppm
10,000 ppm
Monitoring 500 ppm
10,000 ppm
Repair

For pressure relief devices in liquid service
that are not monitored (Method 21), repair
shall mean that visual, audible, olfactory, or
other indications of a leak have been
eliminated, no bubbles are observed at
potential leak sites during leak check with
soap solution, or system will hold a test
pressure

Exemptions

Equipment operated less than 300 hours per
year


-------
SUMMARY OF REGULATION DIFFERENCES
page B
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61.
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
COMPRESSORS
Standards

Standards
Barrier Fluid
Purges into
Process
zero VOC emissions
zero VHAP emissions
no similar statement
no detectable emissions
Standards
Barrier Fluid
Systems
in heavy liquid service and not in VOC
service
not in VHAP service and not in VOC
service
not in light liquid service
must not be a hazardous waste with organic
concentrations 10 percent or greater by
weight
Standards
Sensor and
Audible
Alarm

Daily observation or equipped with alarm
waived if located at an unmanned plant site
Check alarm monthly to ensure it is
functioning properly
Exemptions
Reciprocating compressors that meet certain
criteria.

Equipment operated less than 300 hours per
year


-------
SUMMARY OF REGULATION DIFFERENCES
page B
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
SAMPLING CONNECTION SYSTEMS
Standards
Introduction

ADDS
The system shall collect or capture the
sample purge for return to the process
Gases displaced during filling of the sample
container are not required to be collected or
captured

Standards
Return of
fluid (o
process or
recycle
ADDS Closed-loop system
with zero VOC emissions to the atmosphere
with zero VHAP emissions to the
atmosphere
ADDS Closed-loop system
No mention of emissions to the atmosphere
With no detectable emissions to the
atmosphere
Exemptions
ADDS Sampling systems without purges

ADDS Sampling systems without purges
Equipment operated less than 300 hours per
year


OPEN-ENDED VALVES OR LINES
Standards

ADDS flow allowed during maintenance
or repair

Exemptions

ADDS Open-ended valves and lines in an
emergency shutdown system that are
designed to open automatically in the event
of a process upset
Equipment operated less than 300 hours per
year


-------
SUMMARY OF REGULATION DIFFERENCES
page B
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61.
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
FLANGES AND OTHER CONNECTORS (ALL SERVICES)
Standards

Not applicable The subpart has standards
for connector in gas/vapor or light liquid
service and for connectors in heavy liquid
service


CONNECTORS. GAS/VAPOR OR LIGHT LIQUID SERVICE
Standards
Not applicable [See Flanges and other
connectors (all services)]
Not applicable [See Flanges and other
connectors (all services))
See Regulatory Summary table for
description of regulations for these
components
Not applicable [See Flanges and other
connectors (all services)]

CONNECTORS. HEAVY LIQUID SERVICE
Standards
Not applicable [See Flanges and other
connectors (all services)]
Not applicable
See Regulatory Summary table for
description of regulations for these
components
Not applicable [See Flanges and other
connectors (all services)}

AGITATORS, GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
Standards
Not applicable
Not applicable
See Regulatory Summary table for
description of regulations for these
components
Not applicable
AGITATORS. HEAVY LIQUID SERVICE

Standards
Not applicable
Not applicable
See Regulatory Summary table for
description of regulations for these
components
Not applicable

-------
SUMMARY OF REGULATION DIFFERENCES
page B
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265.
Subpart BB
INSTRUMENTATION SYSTEMS
Standards
Not applicable
Not applicable
See Regulatory Summary table for
description of regulations for these
components
Not applicable

PRODUCT ACCUMULATOR VESSELS
Standards
Not applicable
See Regulatory Summary table for
description of regulations for these
components
Not applicable (see Surge Control Vessels
and Bottoms Receivers)
Not applicable

SURGE CONTROL VESSELS AND BOTTOMS RECEIVERS
Standards
Not applicable
Not applicable (see Product Accumulator
Vessels)
See Regulatory Summary table for
description of regulations for these
components
Not applicable

-------
SUMMARY OF REGULATION DIFFERENCES
page B
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61.
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
CLOSED VENT SYSTEMS AND CONTROL DEVICES

Standards
Vapor
Recovery
Devices

Vapor recovery systems 95 percent or
greater recovery unless total organic
emission limits of ง265 1032(a)(1) for all
affected processes can be attained at an
efficiency of less than 95 percent
For carbon adsorbers, carbon replacement
intervals specified
Slandards
Combustion
Devices
minimum residence time of 0 75 seconds and
minimum temperature of 816ฐC
minimum residence time of 0 50 seconds
and minimum temperature of 76CC
minimum residence time of 0 50 seconds
and minimum temperature of 760ฐC
minimum residence time of 0 50 seconds
and minimum temperature of 760ฐC or to 20
ppmv
Standards
Hares
Comply with ง60 18
Comply with ง60 18
Comply with ง63 11(b)
Basic requirements for visible emissions,
heat content, and exit velocities
Standards
Closed-Vent
Systems
Initial and annual inspection requirements,
which vary based on whether hard piping or
ductwork is used
No detectable emissions and no visual
indications
Initial and annual inspection requirements,
which vary based on whether hard piping or
ductwork is used
No detectable emissions
Monitoring
Control
Devices

Specific requirements identified for vent
stream flow monitors and other monitors for
specific types of control devices
Monitoring
Closed-Vent
Systems
Install flow monitors or monthly visual
inspections where bypass lines could divert
flow
Initially, annually, and at other times
specified by EPA
Install flow monitors or monthly visual
inspections where bypass lines could divert
flow
Initially, annually, and at other times
specified by EPA
Inspections
Closed-Vent
Systems
If contains by-pass lines, (1) vent stream flow
meters or (2) car-seal or lock-and-key type of
configuration with monthly visual inspection
required
"Unsafe-to-monitor" parts inspect as
frequently as practicable, but no more
frequently than annually
"Difficult-to-monitor" parts inspect at least
once every 5 years
None specified
If contains by-pass lines, (1) vent stream
flow meters or (2) car-seal or lock-and-key
type of configuration with monthly visual
inspection required
"Unsafe-to-monitor" parts inspect as
frequently as practicable, but no more
frequently than annually
"Difficult-to-monitor" parts inspect at least
once every 5 years
None specified

-------
SUMMARY OF REGULATION DIFFERENCES
page B
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63.
Subpart H
40 CFR Part 63.
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
CLOSED VENT SYSTEMS AND CONTROL DEVICES (concluded)

Leak
Definition
500 ppm
Not applicable
500 ppm
Not applicable
CVS detectable emissions >.500 above
background
Repair
ADDS Delay of repair allowed under
certain circumstances Repair required no
later than by end of next process unit
shutdown

ADDS Delay of repair allowed under
certain circumstances Repair required no
later than by end of next process unit
shutdown

Exemptions

Equipment operated less than 300 hours per
year
Equipment needed for safety purposes are
not subject to these monitoring
requirements


-------
SUMMARY OF REGULATION DIFFERENCES
page B-17
Delay of Repair
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63.
Subpart K
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
General
Isolated
Equipment
Does not remain in VOC service
Does not remain in VHAP service
Does not remain in organic HAP service
Does not continue to contain or contact
hazardous waste with organic concentrations
of at least 10 percent by weight
Valves
Not allowed unless next process unit
shutdown occurs sooner than 6 months after
1st process unit shutdown
Not allowed unless next process unit
shutdown occurs sooner than 6 months after
1st process unit shutdown
Not allowed beyond the second process unit
shutdown unless the third process unit
shutdown occurs sooner than 6 months after
1st process unit shutdown.
Not allowed unless next unit shutdown occur
sooner than 6 months after 1st unit
shutdown
Connectors and
Agitators
Not applicable
Not applicable.
Allowed if-
emissions from purged material resulting
from immediate repair less than from the
delay
purged material is later collected and
destroyed or recovered in compliant control
device
Delay beyond next process unit shutdown
allowed if otherwise sufficient supply of
valves have been depleted
Not applicable
Pumps

Additional allowances
If repair requires replacing existing seal
design with a new system (hat provides better
performance or compliant closed-vent system
and control device


-------
SUMMARY OF REGULATION DIFFERENCES
page B-18
Quality
Improvement
Programs
REGULATION
40 CFR Part 60.
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Applicability
Not applicable
Not applicable
See Regulatory Summary table for description of Quality
Improvement Programs
Not applicable

-------
SUMMARY OF REGULATION DIFFERENCES
page B-19
Equivalence of (or
Alternative) Means
of Emission
Limitation
REGULATION
40 CFR Part 60.
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Equipment, Design,
and Operational
Requirements

No requirement for Administrator to
compare test data

Not applicable
Work Practices
Demonstration of
Emission Reduction
for Required Work
Practice
No length of demons!ration period
indicated
Required for minimum of 12 months
Required for minimum of 12 months
Not applicable
Unique Approach

Not applicable
Manufacturers of
Equipment

Not applicable
Alternative Means
of Emission
Limitation
Batch Processes
REGULATION
40 CFR Part 60,
subpart VV
40 CFR Part 61,
subpart J
40 CFR Part 61,
subpart V
40 CFR Part 63,
subpart H
40 CFR Part 63.
subpart 1
40 CFR Part 265,
subpart BB

Not applicable
Not applicable
See Regulatory Summary table for description of standards for batch processes
No! applicable
Alternative Means
of Emission
REGULATION
Limitation






Enclosed-Vented
40 CFR Part 60,
40 CFR Part 61,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 63,
40 CFR Part 264,
Process Units
Subpart VV
Subpart J
Subpart V
Subpart H
Subpart I
Subpart BB






40 CFR Part 265,






Subpart BB

Not applicable
Not applicable
See Regulatory Summary table for
description of standards for enctosed-
vented process unils
Not applicable

-------
SUMMARY OF REGULATION DIFFERENCES
page B-20
Tesi Meihods and
Procedures
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61.
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Pan 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Monitoring
Method,
Technique, and
Instrument
ADDS Test each piece of equipment
unless demonstration is made that
equipment is not in VOC service
ADDS Instrument to meet performance
criteria of Method 21
Traverse probe around all potential leak
interfaces as close as possible as described
in Method 21
ADDS Instrument to meet performance
criteria of Method 21 except
response factor criteria is for the average
composition of the process fluid, not each
individual VOC in stream
for process streams that contain inerts that
are not organic HAPs or VOC, average
stream response factor is calculated on an
inert-free basis
If no instrument available that meet all
Method 21 criteria, then instrument
readings may be adjusted as specified
Monitor alt equipment while it is "in
service"
ADDS Instrument to meet performance
cruena of Method 21
Traverse probe around all potential leak
interfaces as close as possible as described
in Method 21
Calibration

gases limits to methane
Phase 11 mixture of methane in air at
concentration of about, but less than
10,000 ppm for agitators
5,000 ppm for pumps
500 ppm all other equipment
Phase III mixture of methane in air at
concentration of about, but less than
10,000 ppm for agitators
2,000 ppm for pumps in food/ medical
service
5,000 ppm for pumps in polymerizing
monomer service
1,000 ppm for all other pumps
500 ppm for all other equipment
Phase II and III Exception under certain
conditions may calibrate up to 2,000 ppm
higher than the leak definition


-------
SUMMARY OF REGULATION DIFFERENCES
page B-21
Test Methods and
Procedures
REGULATION
40 CFR Pari 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63.
Subpart H
40 CFR Part 63,
Subpart 1
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Not "in service
determination
For demonstration
Use procedures that conform to ASTM E-
260, E-168, E-169 to determine percent
VOC in process fluid that is contained or
contacts a piece of equipment
Engineering judgement may be used to
estimate the VOC content if piece of
equipment had not been shown previously
to be in VOC service
Administrator will require use of ASTM
Method D-2267b in event of disagreement
to determine VOC content
Compounds determined by EPA to have
negligible photochemical reactivity can be
excluded in determining VOC content of a
process fluid
For demonstration
Use procedures that conform to ASTM
Method D-2267
Engineering judgment may be used to
determine percent VHAP clearly does not
exceed 10 percent
Administrator will require use of ASTM
Method D-2267b in event of disagreement
to determine VOC content
For demonstration
Use Method 18 of 40 CFR Part 60,
appendix A to determine percent organic
HAP
Engineering judgment may be used to
determine percent organic HAP does not
exceed 5 percent
Owner/operator may instead determine
organic HAP content does not exceed S
percent by weight
For demonstration
Use ASTM Methods D 2267-88, I- 169-87,
E 168-88, E260-85, or Method 9060 or
8240 of SW-846
Engineering judgment may be used to
estimate organic concentration
Regional Administrator will require the use
of ASTM Methods D 2267-88, E 169-87, E
168-88, E260-85, or Method 9060 or 8240
of SW-846 m the event of disagreement to
determine VOC content
Revisions of "In
service"
determination
None specified
Determination of in VHAP service can be
revised only by following specified
procedures
Determination of in organic HAP service
can be revised by either following specified
procedures or documenting a change in
process or raw materials no longer causes
equipment to be in organic HAP service
If owner or operator determines that a piece
of equipment contains or contacts a
hazardous waste with an organic
concentration of at least 10% be weight, the
determination can only be revised by
following the demonstration procedures
Samples
Representative of process fluid that is
contained in or contacts the equipment or
the gas being combusted in flare
Representative of process fluid that is
contained in or contacts the equipment or
the gas being combusted in flare
Representative of process fluid that is
contained in or contacts the equipment
Representative of (he highest total organic
content hazardous waste that is contained in
or contacts the equipment
Vapor pressures
Standard reference texts
or
ASTM D-2879
Not specified
Not specified
Standard reference texts
or
ASTM D-2879-86
Flare Compliance
Presence of flame thermocouple or
equivalent
Component concentration Method 18 and
ASTM D-2504-67
Presence of flame thermocouple or
equivalent
Concentration Method 18 or ASTM
D2509-67
Presence of flame thermocouple or
equivalent
Concentration Method 18
Presence of flame heat sensing monitoring
device with a continuous recorder that
indicates the continuous ignition of the pilot
flame
Concentration Method 18

-------
SUMMARY OF REGULATION DIFFERENCES
page B-22
Test Methods and
Procedures
REGULATION
40 CFR Part 60.
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61.
Subpart V
40 CFR Pari 63.
Subpart H
40 CFR Part 63,
Subpart 1
40 CFR Part 264.
Subpart BB
40 CFR Part 265,
Subpart BB
Batch Processes -
Pressure Test with
Gas or Vacuum
Not applicable
Not applicable
See Regulation Summary table for specific
requirements
Not applicable
Batch Processes -
Pressure Test with
Liquid
Not applicable
Not applicable
See Regulation Summary table for specific
requirements
Not applicable

-------
SUMMARY OF REGULATION DIFFERENCES
page B-23

REGULATION
Recordkeeping
Requirements
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
When teak detected


id removal after repair except for valves and
connectors and no leak detected durine followuD
momtonnE
for valves and connectors, id mav be removed
after 2 months of no leaks detected and no leak has
been detected durinn the followuo momtorine
for a weather-proof and readily visible
identification, adds.
date evidence of potential leak found and date
leak detected



ADDS

ADDS



operator name and initials

date evidence of potential leak found



maximum instrument reading after successful
repair or determined to be nonrepairable
documentation supporting delay of repair of
a valve

DOES NOT HAVE
dates of process unit shutdown that
occurred while the equipment is
unrepaired

for connectors id of connectors disturbed since
last monitoring period, and dates and results of
follow-up monitoring
copies of periodic reports (if database not capable
of generating such)
DOES NOT HAVE
dates of process unit shutdown that occurred
while the equipment is unrepaired



DOES NOT HAVE.





repair methods applied in each attempt to repair




"above 10,000" if maximum instrument reading
after each repair attempt is >. 10,000 ppm




signature of owner/operator whose decision it
was that repair could not be effected without a
process shutdown


-------
SUMMARY OF REGULATION DIFFERENCES
page B-24
Recordkeeping
Requirements
REGULATION
40 CFR Part 60.
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63.
Subpart 1
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Closed vent
systems and control
devices

ADDS
flare design and compliance demonstration results
records of operation of closed-vent systems and
control devices
dates and duration when closed-vent systems, and
control devices not operated according to design
dates and duration when monitoring
systems/devices are nonoperative
records of closed-vent inspections
ADDS
explanation of each period of exceedances
For carbon adsorbers
date when fresh carbon added
monitoring of carbon breakthrough (certain
carbon adsorbers)
For other, non-specified control devices,
monitoring and inspection information
indicating proper operation and maintenance
Visual inspections
Not applicable
Not applicable
documentation that inspection was conducted
dates of inspection
Not applicable

-------
SUMMARY OF REGULATION DIFFERENCES
page B-25
Recordkeeping
Require ments
REGULATION
40CFR Pari 60.
Subpart VV
40CFR Part 61,
Subpart J
40CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
All equipment
list of id numbers of subject
equipment
list of id numbers of subject
equipment (except welded fittines')
list of id numbers of subject equipment (except
certain connectors)
ADDS
schedule for monitoring connectors
list of id numbers for equipment equipped with
closed-vent system and control device
list of id numbers of compressors and pressure
relief devices complying with less than 500 ppm
above background standard
list of id numbers of pressure relief devices with
rupture disks
id of instrumentation systems
id of screwed connectors complying with
ง63 174(c)(2)
list of valves and connectors removed if net
credits for their removal are expected to be used
DOES NOT HAVE
list of id numbers of equipment designated for no
detectable emissions and signed by owner/operator
list of id numbers for pressure relief devices in
gas/vapor service
for each compliance test for components
designated for no detectable emissions
date conducted
background level measured
maximum instrument reading
list of id numbers of equipment in vacuum
service		
list of id numbers of subject equipment
(except welded fittings)
ADDS
equipment identification number and
hazardous waste management unit
identification
approximate facility location
type of equipment
perccnt-by-weight of total organics in
hazardous waste at the equipment
hazardous waste state at the equipment
method of compliance

-------
SUMMARY OF REGULATION DIFFERENCES
page B-26

REGULATION
Recordkeeping
Requirements
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264.
Subpart BB
40 CFR Part 265.
Subpart BB
Unsafe or Difficult
to Monitor Valves

Unsafe-to- Monitor
or Repair.
Inaccessible or
Glass-Lined
Connectors
Not applicable
Not applicable
list of id numbers
explanation for designation
plan or schedule for monitoring
Not applicable
Valves complying
with alternative
standard for skip-
periods

Not applicable

Exemption
Determinations
analysis demonstrating facility design
capacity
analysis demonstrating facility design
capacity
identification of equipment in organic HAP
service less than 300 hours per year
an analysis determining the design capacity
of the unit

statement listing Teed or raw
materials and products from facility
and analysis demonstrating whether
these chemicals are heavy liquids or
beverage alcohol
analysis demonstrating that equipment
is not in VOC service
analysis demonstrating that equipment
is not in VHAP service


statement listing the hazardous waste
influent to and effluent from each subject unit
and an analysis determining whether these
wastes are heavy liquids
an up-to-date analysis and supporting
information to determine whether or
equipment is subject to this subpart
Not "In service"
information and data used to
demonstrate that a piece of equipment
is not in VOC service
information and data used to
demonstrate that a piece of equipment
is not in VHAP service
information, data, and analysis used to
demonstrate that a piece of equipment or process
unit js in heavy liquid service
Not specified
Batch Processes
Noi applicable
Not applicable
See Regulation Summary table for specific
requirements
Not applicable
QIP
Not applicable
Not applicable
See Regulation Summary table for specific
requirements
Not applicable
Enclosed Vent
Process
Not applicable
Not applicable
See Regulation Summary table for specific
requirements
Not applicable

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SUMMARY OF REGULATION DIFFERENCES
page B-27
Reporting
Requirements
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Pare 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Initial Report
process unit identification
number of valves, pumps, and
compressors, excluding those designated
for no detectable emissions
For each source
equipment identification number
process unit identification
type of equipment
percent weight VHAP
process fluid state
method of compliance
Reporting schedule for submittal of
subsequent semiannual reports
An owner or operator is also required to
submit a statement notifying the
Administrator that the requirements of
this subpart are being implemented For
existing sources and new sources with an
initial startup dare preceding the effective
date, this notification is to be submitted
within 90 days of the effective date. For
new source with an initial startup date
after the compliance date, this
notification is to be submitted wilh the
application for approval of construction
Initial Notification
name and address of owner/operator
address of facility (physical location)
identification of subject processes
compliance statement
statement of whether a source can
achieve compliance by the applicable
compliance date
Notification of Compliance Status (for
each subiect process unit)
A For each subject unit-
process unit identification
number of each equipment type (except
(hose in vacuum service)
method of compliance
planned schedule for each phase
B Batch processes
batch products or product codes
planned schedule for testing
C. Enclosed-vented Process Units
process unit identification
description of negative pressure system
and control device
Not specified

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SUMMARY OF REGULATION DIFFERENCES
page B-28
REGULATION
Reporting
Requirements
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Subsequent
SemiAnnual/
Period Reports
process unit identification
The following information by month in
the reporting period
number of valves, pumps, and
compressors for which leaks were
detected
number of valves, pumps, and
compressors for which leaks were not
repaired as required
the facts (hat explain each delay of
repair, and where appropriate, why a
process unit shutdown was technically
infeasible
process unit identification
The following information by month in
the reporting period
number of valves, pumps, and
compressors for which leaks were
detected
number of valves, pumps, and
compressors for which leaks were not
repaired as required
the facts that explain each delay of
repair, and where appropriate, why a
process unit shutdown was technically
infeasible
not required
not required by month
the number of valves, pumps,
compressors, agitators, connectors, and
screwed connectors for which leaks were
detected
the number of valves, pumps,
compressors, agitators, connectors, and
screwed connectors for which leaks were
not repaired
explanation of why repairs delayed and
why process unit shutdown was
infeasible
ADDS
the percent leakers for valves, pumps,
connectors, and screwed connectors
the total number of valves, pumps,
connectors, and screwed connectors
monitored
identification of the number of valves
and connectors determined to be
nonrepairable
notification of change in connector
monitoring alternatives (if applicable)
For "no detectable emissions"
components all monitoring to show
compliance
initiation of monthly monitoring under
phase 111 or Q1P (if applicable)	
Not specified for part 265
For part 264
The EPA identification number, name,
and address of the facility
The following information by month in
the reporting period
equipment identification number of
each valve, pump, and compressor for
which leaks were not repaired as
required
dates of hazardous waste management
unit shutdowns that occurred within the
semiannual reporting period
dates when the required control device
exceeded or operated outside design
specifications and was not corrected
within 24 hours, the duration and cause
of each exceedance, and any corrective
measures taken
If during the semiannual reporting
period, pumps, valves, and connectors
are repaired as required and (he control
device does not exceed or operate
outside of design specifications for
more than 24 hours, a report to the
Regional Administrator is not required

-------
SUMMARY OF REGULATION DIFFERENCES
page B-29

REGULATION
Reporting
Requirements
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
40 CFR Part 63.
Subpart H
40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Subsequent
SemiAnnual/
Period Reports
(concluded)
Dates of process unit shutdowns that
occurred within the semiannual
reporting period
Revisions to items reported in the initial
semiannual report if changes have
occurred since the initial semiannual
report or subsequent revisions to the
initial semiannual report
Dates of process unit shutdowns that
occurred within the semiannual reporting
period
Revisions to items reported in the initial
semiannual report if changes have
occurred since the initial semiannual
report or subsequent revisions to the
initial semiannual report
not required
not required

not required
not required

Rfnori of All perforniflnef tfsl in
accordance with 560.8.
Reoort of all Derformance test and
momtorine to determine compliance with
no delectable emissions and with
663.243-1 and -2.
not required

not required
Batch Processes -
Pressure Testing
Not applicable
Not applicable
See Regulation Summary table for
specific requirements
Not applicable
Compliance with
Alternative
Standards for
Valves
90 day prior notice required
90 day prior notice required
Not applicable.
Not applicable.

-------
APPENDIX C
EQUIPMENT LEAK REGULATIONS: SUMMARY BY COMPONENT
page
40 CFR PART 60, SUBPART W
Closed-Vent Systems and Control Devices	C-l
Compressors 	C-3
Dual Mechanical Seal System	C-6
No Detectable Emissions	C-8
Open-Ended Valves or Lines	C-10
Pressure Relief Devices in Gas/Vapor Service		C-ll
Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light
Liquid or Heavy Liquid Service, and Flanges and Other Connectors 		C-13
Pumps in Light Liquid Service		C-l5
Sampling Connection Systems	C-18
Valves in Gas/Vapor and Light Liquid Service 	C-20
40 CFR PART 61, SUBPARTS J AND V
Closed-Vent Systems and Control Devices	C-23
Compressors 	C-25
Dual Mechanical Seal System	C-28
No Detectable Emissions	C-31
Open-Ended Valves or Lines	C-3 3
Pressure Relief Devices in Gas/Vapor Service		C-35
Pressure Relief Devices in Liquid Services, Flanges and Other Connectors		C-37
Product Accumulator Vessels	C-39
Pumps in VHAP Service	C-41
Sampling Connection Systems 	C-44
Valves in VHAP Service	C-46
40 CFR PART 63, SUBPARTS H AND I
Agitators in Gas/Vapor Service or Light Liquid Service 		C-49
Alternative Means of Emission Limitations: Enclosed-Vented Process Units		C-53
Alternative Means of Emission Limitations: Batch Processes		C-54
Closed-Vent Systems and Control Devices		C-58
Compressors 		C-62
Connectors in Gas/Vapor and Light Liquid Service	C-65
Dual Mechanical Seal System	C-70
Open-Ended Valves or Lines		C-73
Pressure Relief Devices in Gas/Vapor Service 	C-75

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page
Pumps in Light Liquid Service		C-78
Pumps, Valves, Connectors, and Agitators in Heavy Liquid Service;
Instrumentation Systems; and Pressure Relief Devices in Liquid Service	C-82
Quality Improvement Program for Pumps in Light Liquid Service	C-86
Quality Improvement Program for Valves		C-89
Sampling Connection Systems 	C-93
Surge Control Vessels and Bottoms Receivers	C-95
Valves in Gas/Vapor and Light Liquid Service 	C-97
40 CFR PART 264 AND PART 265, SUBPARTS BB
Closed-Vent Systems and Control Devices		C-101
Compressors 		C-105
Dual Mechanical Seal System		C-108
No Detectable Emissions		C-lll
Open-Ended Valves or Lines		C-113
Pressure Relief Devices in Gas/Vapor Service		C-l 15
Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light
Liquid or Heavy Liquid Service, and Flanges and Other Connectors		C-l 17
Pumps in Light Liquid Service		C-120
Sampling Connection Systems 		C-l23
Valves in Gas/Vapor and Light Liquid Service 		C-125

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63.
40 CFR Pan 264, Subpan BB
Subpan VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Basic Standard
Control devices and closed-vent systems to be operated at all times that emissions may be vented to
them
Control Devices
•	vapor recovery systems. 95 percent or greater recovery
•	combustion devices. 95 percent or greater reduction or minimum residence time of 0 75 seconds
at a minimum temperature of 816 ฐC
•	flares comply with ง60.18
•	monitor to ensure operated and maintained in conformance with design
Monitoring
•	closed-vent systems: inspect initially, annually, and at other times as requested by the
Administrator
Leak Definition
> 500 ppm above background or visual inspections
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Vapor collection or closed-vent systems operated under a vacuum
Unsafe or difficult to inspect portions of closed-vent systems require alternate inspection plan
Monitoring
Method
Hard pipe construction: Method 21 for initial inspection, annual visual inspections
Duct work construction Method 21 for initial and annual inspections
Repair
Requirements
First attempt to repair within 5 calendar days of detection
Repair as soon as practicable, no later than IS days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown or if owner/operator determines that
emissions from immediate repair would be greater than emissions from delay of repair Repair is
required before end of next process unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-l

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Part 61.
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB



ITEM
REQUIREMENTS
Recordkeeping
Requirements
When no leak detected
•	record that instrument or visual inspection was conducted
•	date of inspection
•	statement that no leaks were detected
Information to be kept for all closed-vent systems and control devices-
•	detailed schematics, design specifications, and piping and instrumentation diagrams
•	dates and descriptions of any changes in design specifications
•	description of parameter(s) to be monitored to ensure proper operation and maintenance
•	explanation of selected parameter(s)
•	periods when not operated according to design
•	dates of startups and shutdown of closed-vent system and control device
•	list of ID numbers of subject closed-vent systems and control devices
•	list of ID numbers for closed-vent systems and control devices in vacuum service
Information to be kept in a log for determining exemptions
•	analysis demonstrating design capacity of affected facility
•	demonstration that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not in VOC service
Information to be kept for unsafe to inspect parts of closed-vent system (40 CFR 60 482-10(j))
•	identification
•	explanation for designation
•	plan for inspecting equipment
Information to be kept for difficult to inspect parts of closed-vent system (40 CFR 60 482-10(k))
•	identification
•	explanation for designation
•	plan for inspecting equipment
Reporting
Requirements
Initial report:
•	process unit identification
Subsequent semiannual reports
•	process unit identification
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests in accordance with ง60 8
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-2

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Part 63.
Subparts H arid 1
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Equipped with compliant seal system that includes a barrier fluid system that prevents leakage of
VOC to atmosphere
For each seal system
o operate with the barrier fluid at a pressure that is greater than the stuffing box pressure, or
o equip with a barrier fluid system that is connected by a closed vent system to a compliant control
device, or
o equip with a system that purges the barrier fluid into a process stream with zero VOC emissions
to the atmosphere
The barrier fluid system shall be in heavy liquid service or shall not be in VOC service
Install sensor to detect failure of seal system, barrier fluid system, or both
Check sensor daily or equip with audible alarm
Establish criteria that indicates failure of seal system, barrier fluid system, or both
Leak Definition
Sensor indicates failure of seal system, barrier fluid system, ot both, based on established criteria.
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
Reciprocating compressors that meet certain criteria
Compressors designated for no detectable emissions, which operate less than 500 ppm above
background (see No Detectable Emissions)
Compressors equipped with a compliant closed-vent system and control device (see Closed-vent
Systems and Control Devices)
Monitoring
Method
Sensor alarm or visual check
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain m VOC service
COMPRESSORS
page C-3

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS


Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak delected
•	instrument and operator ID numbers and equipment ED number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the 15 days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all compressors
•	list of ID numbers of subject compressors
•	list of ID numbers of compressors designated for no detectable emissions and signed by
owner/operator
•	for each compliance test for compressors designated for no detectable emissions
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for compressors in vacuum service
Information to be kept for barrier fluid and seal systems
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to selected criteria and reasons for change
Information to be kept in a log for determining exemptions
•	analysis demonstrating design capacity of affected facility
•	demonstrations that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not in VOC service
Information to be kept if equipped with a closed-vent system and control device
•	periods when closed-vent system and control device are not operated according to design
•	dates of startup and shutdown of the closed-vent system and control device
COMPRESSORS
page C-4

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB



ITEM
REQUIREMENTS
Reporting
Requirements
Initial report*
•	process unit identification
•	number of compressors, excluding those designated for no detectable emissions or equipped with
a compliant closed-vent system and control device
Subsequent semiannual reports
•	process unit identification
•	the following information for each month in the reporting period:
•	• number of compressors for which leaks were detected
•	• number of compressors for which teaks were not repaired within 15 days after detection
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests in accordance with ง60.8
COMPRESSORS
page C-5

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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Pan 265, Subpan BB



40 CFR Part 60,
Subpart W
ITEM
REQUIREMENTS
Basic Standard
For each dual mechanical seal system
•	operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
•	connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
•	equip with a system that purges the barrier fluid into a process stream with zero VOC emissions
to the atmosphere
For all dual mechanical seal systems
•	the barrier fluid system shall be in heavy liquid service or not in VOC service
•	equip each barrier fluid system with a sensor that detects failure of seal system, barrier fluid
system, or both
• • check each sensor daily or equip with audible alarm
•	determine criteria for sensor and for dripping liquids that indicates failure of the seal system, the
barrier fluid system, or both
•	perform weekly visual inspections for indications of liquids dripping from the pump seals
Applies as an exemption to. Pumps in Light Liquid Service
Leak Definition
Indications of liquids dripping from the pump seal or sensor detection
Alternative
Standards
N/A
Exemptions
N/A
Monitoring
Method
Visual, sensor
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
Delay of Repair
If repair requires use of a dual mechanical seal system that includes a barrier fluid system and repair
is completed as soon as practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
DUAL MECHANICAL SEAL SYSTEM
page C-6

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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ED number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is _>_ 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the 15 days
ฆ dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all dual mechanical seal systems
•	list of ID numbers of equipment with dual mechanical seal systems
•	list of ID numbers of equipment in vacuum service
Information to be kept for barrier fluid and seal systems
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to selected criteria and reasons for change
Information to be kept in a log for determining exemptions
•	analysis demonstrating design capacity of affected facility
•	demonstration that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not in VOC service
Reporting
Requirements
Initial report:
•	process unit identification
Subsequent semiannual reports
•	process unit identification
•	the following information for each month in the reporting period
•	• number of pumps for which leaks were detected
•	• number of pumps for which leaks were not repaired as required
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests in accordance with ง60.8
DUAL MECHANICAL SEAL SYSTEM
page C-7

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NO DETECTABLE EMISSIONS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Has an instrument reading of less than 500 ppm above background as measured by the methods
specified in 60 485(c)
Test for compliance initially upon designation, annually, and at other times as requested by the
Administrator
Applies as basic standard for.
•	pressure relief devices m gas/vapor service
Applies as an alternate standard to:
•	pumps in light liquid service (must have no externally actuated shaft penetrating the pump
housing)
•	valves in gas/vapor service or in light liquid service (must have no external actuating mechanism
in contact with the process fluid)
Leak Definition
< 500 ppm above background
Alternative
Standards
N/A
Exemptions
N/A
Monitoring
Method
Method 21
Repair
Requirements
N/A
Delay of Repair
N/A
NO DETECTABLE EMISSIONS
page C-8

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NO DETECTABLE EMISSIONS
APPLICABLE REGULATIONS
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB



40 CFR Pan 60,
Subpart W
ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak delected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after leak has been repaired
Information to be kept in log for 2 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is a 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within IS calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the IS days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept
•	list of ID numbers of equipment designated for no detectable emissions and signed by
owner/operator
•	for each compliance test for no detectable emissions
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for equipment in vacuum service
•	list of ID numbers for pressure relief devices in gas/vapor service
Reporting
Requirements
Semiannual reports
•	dates of process unit shutdowns that occurred within the semi-annual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests in accordance with ง60 8
NO DETECTABLE EMISSIONS
page C-9

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OPEN-ENDED VALVES OR LINES
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve- close valve on process fluid end before closing second valve
Double block and bleed system bleed valve or line may remain open during operations that require
venting the line between the block valves, but comply with basic standard at all other times
Leak Definition
N/A
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept for all open-ended valves or lines.
•	list of ID number of subject open-ended valves or lines
•	list of ID numbers of equipment in vacuum service
Information to be kept in a log for determining exemptions
•	analysis demonstrating design capacity of affected facility
•	demonstration that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not in VOC service
Reporting
Requirements
Initial report
•	process unit identification
Subsequent semiannual reports
•	process unit ID
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
OPEN-ENDED VALVES OR LINES
page C-IO

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Part 265, Subpan BB



40 CFR Pan 60,
Subpart VV
ITEM
REQUIREMENTS
Basic Standard
No detectable emissions (less than 500 ppm above background), except during pressure releases
After each release return to no detectable emissions within 5 calendar days as indicated by monitoring
of the pressure relief device
Leak Definition
No detectable emissions (< 500 ppm above background)
Alternative
Standards
N/A
Exemptions
Equipment in vacuum service
Pressure relief devices equipped with a compliant closed-vent system and control device (see Closed-
vent Systems and Control Devices)
Monitoring
Method
Method 21
Repair
Requirements
Return to condition of "no detectable emissions" as soon as practicable but no later than 5 calendar
days after pressure release
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-11

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265, Subpan BB



ITEM
REQUIREMENTS
Recordkeeping
Require merits
Information lo be kept for all pressure relief devices:
•	list of ID numbers of pressure relief devices required to comply
•	list of ID numbers for no detectable emissions
•	for each compliance test for pressure relief devices designated for no detectable emissions
•	• dates conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for pressure relief devices in vacuum service
Information to be kept in a log for determining exemptions:
•	analysis demonstrating design capacity of affected facility
•	demonstration that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not in VOC service
Information to be kept if equipped with a closed-vent system and control device:
•	periods when closed-vent system and control device were not operated according to design
•	dates of startup and shutdown of the closed-vent system and control device
Reporting
Requirements
Initial report
•	process unit ID for pressure relief devices
Subsequent semiannual reports
•	process unit identification
•	ihe facts that explain each delay of repair, and where appropriate, why a process unit shutdown
was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests in accordance with ง60 8.
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-12

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PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
SERVICE, AND FLANGES AND OTHER CONNECTORS
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Monitoring of potential leaks within S calendar days of detection if evidence of potential leak is found
by visual, auditory, olfactory, or other detection method
Leak Definition
10,000 ppm
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
For valves.
•	allowed if emissions of purged material resulting from immediate repair would exceed fugitive
emissions from delay of repair, and purged material is collected and destroyed or recovered in
compliant control device when repair occurs
•	delay beyond a process unit shutdown allowed if valve assemblies have been depleted and valve
assembly supplies had been sufficiently stocked before supplies were depleted
•	not allowed beyond next process unit shutdown unless next process unit shutdown occurs sooner
than 6 months after first process unit shutdown
For pumps
•	allowed if repair requires use of dual mechanical seal system that includes barrier fluid and
repair is completed as soon as practicable but not later than 6 months after leak was detected
PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
LIQUID OR HEAVY LIQUID SERVICE. AND FLANGES AND OTHER CONNECTORS	page C-13

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PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
SERVICE, AND FLANGES AND OTHER CONNECTORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61.
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected-
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after 11 has been repaired
Information to be kept in log for 2 years after leak detected:
•	instrument and operator ID numbers and equipment ED number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is >. 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be affected without a
process shutdown
•	expected date of successful repair if leak is not repaired within 15 days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all equipment in these categories-
•	list of ID numbers of subject equipment in these categories
•	list of ID numbers for equipment in vacuum service
Information to be kept in a log for determining exemptions.
•	analysis demonstrating design capacity of affected facility
•	demonstration thai the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not in VOC service
Reporting
Requirements
Initial report-
•	process unit identification
Subsequent semiannual reports
•	process unit identification
•	by month in the reporting period, the facts that explain each delay of repair, and where
appropriate, why a process unit shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests in accordance with ง60 8
PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS	page C-I4

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60.
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB



ITEM
REQUIREMENTS
Basic Standard
Monthly leak detection and repair
Weekly visual observation for leaks
Leak Definition
10,000 ppm
Indications of liquids dripping from pump seal
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Pumps in vacuum service
Dual mechanical seal pumps (see Dual Mechanical Seals)
Any pump designated for no detectable emissions (see No Detectable Emissions)
Any pump equipped with a compliant closed-vent system and control device (see Closed-vent Systems
and Control Devices)
Monitoring
Method
Method 21, no more than 1 cm from rotating shaft
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Allowed if repair requires use of a dual mechanical seal system that includes a barrier fluid system
and repair is completed as soon as practicable but not later than 6 months after leak was detected
PUMPS IN LIGHT LIQUID SERVICE
page C-15

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB



ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak detected-
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the 15 days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all pumps
•	list of ID numbers of subject pumps
•	list of ID numbers of pumps designated for no detectable emissions and signed by
owner/operator
•	for each compliance test for pumps designated for no detectable emissions:
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	identification of pumps in vacuum service
Information to be kept for barrier fluid and seal systems
•	design criteria for indicating failure
•	explanation of selected criteria
•	any changes to selected criteria and reasons for change
Information to be kept if pump is equipped with a closed-vent system and control device-
•	periods when closed-vent system and control device is not operating according to design
•	dates of startup and shutdown of closed-vent system and control device
Information to be kept in a log for determining exemptions
•	analysis demonstrating design capacity of affected facility
•	demonstration that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not in VOC service
PUMPS IN LIGHT LIQUID SERVICE
page C-16

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts 1 and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial report:
•	process unit identification
•	number of pumps, excluding those designated for no detectable emissions or equipped with a
closed-vent system or control device
Subsequent semiannual reports.
•	process unit identification
•	the following information for each month in the reporting period:
•	• number of pumps for which leaks were detected
•	• number of pumps for which leaks were not repaired within 15 days after detection
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance test in accordance with ง60.8
PUMPS IN LIGHT LIQUID SERVICE
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SAMPLING CONNECTION SYSTEMS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subpans J and V
40 CFR Pan 63,
Subpans H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265, Subpart BB



ITEM
REQUIREMENTS
Basic Standard
Equipped with closed-purged, closed-loop, or closed-vent system that returns the fluid to the process
line, recycles the purged fluid to a process, or sends it to a compliant control device
Leak Definition
N/A
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
In-situ sampling systems
Sampling systems without purges
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept for all sampling connections
•	list of ID numbers of subject sampling connection systems
•	list of ID numbers of sampling connections systems in vacuum service
Information to be kept if equipped with closed-vent system and control device
•	periods when closed-vent system and control device is not operated according to design
•	dates of startup and shutdown of closed-vent system and control device
Information to be kept in a log for determining exemptions.
•	analysis demonstrating design capacity of affected facility
•	demonstration that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not in VOC service
SAMPLING CONNECTION SYSTEMS
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SAMPLING CONNECTION SYSTEMS
APPLICABLE REGULATIONS
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB



40 CFR Pan 60,
Subpart W
ITEM
REQUIREMENTS
Reporting
Requirements
Initial report
•	process unit identification
Subsequent semiannual reports:
•	process unit ID
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
SAMPLING CONNECTION SYSTEMS
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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Pan 61,
Subparts ] and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB



ITEM
REQUIREMENTS
Basic Standard
Monitor monthly
If valve does not leak for 2 months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
Leak Definition
10,000 ppm
Alternative
Standards
Equivalent means of emission limitation
Allowable percentage of valves leaking: may elect to comply with s2% leaking valves
•	notify Administrator before implementing
•	conduct performance tests initially, annually, and as requested by Administrator
•	• monitor within one week using Method 21
•	• leak definition is 10,000 ppm
•	• leak percentage cannot be greater than 2.0%
Skip period leak detection and repair
•	notify Administrator before implementing
•	comply initially with basic standard
•	if s2% leaking after 2 consecutive quarterly leak detection periods, may begin to skip 1 of the
quarterly monitoring periods
•	after 5 consecutive periods with <,2 0% leaking, may begin to skip 3 of the quarterly periods
•	if >2 0% leaking, comply with basic standard, but can again elect to use alternate standard
Exemptions
Valves in vacuum service
Valves designated for no detectable emissions (less than 500 ppm above background - see No
Detectable Emissions)
Valves designated unsafe to monitor or difficult to monitor
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than IS days after detection
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Delay of Repair
Allowed if technically mfeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a compliant control
device when repair occurs
Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted and supplies had been sufficiently stocked before depletion
Not allowed beyond next process unit shutdown unless next shutdown occurs sooner than 6 months
after first process unit shutdown
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired and monitored for 2 months with no leaks detected
dunng those 2 months
Information to be kept in log for 2 years after leak detected.
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within IS calendar days after detection
ฆ	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the IS days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all valves:
•	list of ID numbers of subject valves
•	list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
ฆ	for each compliance test for valves designated for no detectable emissions
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for valves in vacuum service
(Continued on next page)
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-21

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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements,
continued
Information to be kept for unsafe or difficult to monitor valves:
•	list of ID numbers
•	explanation for designation
•	planned schedule for monitoring
Information to be kept for valves complying with alternative standard - skip period leak detection and
repair:
•	schedule of monitoring
•	percent of valves found leaking during each monitoring period
Information and data to be kept in a log for determining exemptions
•	analysis demonstrating design capacity of affected facility
•	demonstration that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
•	analysis demonstrating that equipment is not m VOC service
Reporting
Requirements
Initial report
•	process unit identification
•	number of valves, excluding those designated for no detectable emissions
Subsequent semiannual reports
•	process unit identification
•	the following information for each month in the reporting period:
•	• number of valves for which leaks were detected
•• number of valves for which leaks were not repaired within 15 days after detection
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests in accordance with ง60.8
If complying with alternative standard, notify Administrator 90 days before implementation
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Control devices and closed-vent systems to be operated at all times that emissions may be vented to
them
Control Devices
•	vapor recovery systems 95 percent or greater recovery
•	enclosed combustion devices 95 percent or greater reduction or minimum residence time of
0.50 seconds and minimum temperature of 760 ฎC
•	flares, comply with ง60.18
•	monitor to ensure operated and maintained in conformance with their design
Closed-Vent Systems
•	no detectable emissions (less than 500 ppm above background) and no visual indications
•	monitor initially, annually, and at other times as requested by the Administrator
Leak Definition
Closed-vent system, no detectable emissions (< 500 ppm above background) and visual inspection
Alternative
Standards
Alternative means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
As soon as practicable, but no later than 15 calendar days after detection
First attempt to repair within 5 calendar days of detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all closed-vent systems and control devices:
•	detailed schematics, design specifications, and piping and instrumentation diagrams
•	dates and descriptions of any changes in design specifications
•	description of parameter(s) to be monitored to ensure proper operation and maintenance
•	explanation of selected parameter(s)
•	periods when not operated according to design, including periods when a flare pilot light does
not have a flame
•	dates of startups and shutdown of the closed-vent system and control device
•	list of ID numbers of subject closed-vent systems and control devices
•	list of ID numbers of closed-vent systems and control devices designated for no detectable
emissions and signed by owner/operator
•	list of ID numbers for closed-vent systems and control devices in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for use in determining exemptions:
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
Reporting
Requirements
Initial report:
•	process unit identification
•	equipment identification number
•	type of equipment
•	percent weight VHAP
•	process fluid stale
•	method of compliance
•	reporting schedule for submittal of subsequent semiannual reports
•	statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports:
•	process unit identification
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests to determine compliance with no detectable emissions
•	by month in the reporting period, the facts that explain any delay of repairs and, where
appropriate, why a process unit shutdown was technically infeasible
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Equip with compliant seal system that includes a barrier fluid system that prevents leakage to
atmosphere
•	operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
•	connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
•	equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
The barrier fluid system is not in VHAP service and, if covered under 40 CFR 60, is not in VOC
service
Install sensor that will detect failure of seal system, barrier fluid system, or both
•	check each sensor daily or equip with audible alarm, unless at unmanned plant site
Establish criteria that indicates failure of seal system, barrier fluid system, or both
Leak Definition
Sensor indicates failure of seal system, barrier fluid system, or both, based on established criteria
Alternative
Standards
Alternative means of emission limitation
Exemptions
Equipment in vacuum service
Compressors designated for no detectable emissions, which operate less than 500 ppm above
background (see No Detectable Emissions)
Compressors equipped with a compliant closed-vent system and control device (see Closed-vent
Systems and Control Devices)
Monitoring
Method
Sensor alarm or visual check
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than IS calendar days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
COMPRESSORS
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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and 1
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is >. 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the 15 days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all compressors
•	list of ID numbers of subject compressors
•	list of ID numbers of compressors designated for no detectable emissions and signed by
owner/operator
•	for each compliance test for compressors designated for no detectable emissions
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for compressors in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for barrier fluid and seal systems:
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to criteria and reasons for change
Information to be kept for compressors equipped with a closed-vent system and control device-
•	periods when the closed-vent system and control device is not operated as designed, including
periods when a flare pilot light does not have a flame
ฆ dates of start-up and shutdown of the closed-vent system and control device
Information to be kept for use in determining exemptions
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
COMPRESSORS
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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart VV
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB
ITEM
REQUIREMENTS
Reporting
Requirements
Initial report:
•	equipment identification number
•	process unit number
•	type of equipment
•	percent weight VHAP
•	process fluid state
•	method of compliance
•	reporting schedule for submittal of subsequent semiannual reports
•	statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports:
•	process unit identification
•	the following information by month in the reporting period:
•	• number of compressors for which teaks were detected
•	• number of compressors for which leaks were not repaired within 15 days after detection
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial repon or
subsequent revisions to the initial report
•	report of all performance tests and monitoring to determine compliance with rto detectable
emissions
COMPRESSORS
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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
For each dual mechanical seal system
•	operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
•	connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
•	equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
The barrier fluid system is not ui VHAP service and, if covered under 40 CFR 60, is not in VOC
service
Equip each barrier fluid system with a sensor that will detect failure of seal system, barrier fluid
system, or both
•	check each sensor daily or equip with audible alarm
•	if at unmanned site, visually inspect as often as practicable and at least monthly
Determine criterion for sensor that indicates failure of the seal system, the barrier fluid system, or
both
Determine criteria for presence and frequency of drips that indicate failure
Perform weekly visual inspections for indications of liquids dripping from the pump seal
•	if indications of liquid, monitor with Method 21 to determine presence of VOC and VHAP in
barrier fluid
Applies as an alternative standard to' Pumps in Light Liquid Service
Leak Definition
Sensor
Presence of VHAP above background
10,000 ppm total VOC
Cnteria
Alternative
Standards
N/A
Exemptions
N/A
Monitoring
Method
Visual, sensor, Method 21
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
DUAL MECHANICAL SEAL SYSTEM
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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Delay of Repair
If repair requires use of a dual mechanical seal system that includes a barrier fluid system and repair
is completed as soon as practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Recordkeeping
Requirements
When leak is detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after leak has been repaired
Information to be kept in log for 2 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date teak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is J> 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the IS days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all dual mechanical seal systems
•	list of ID numbers of dual mechanical seal systems
•	list of ID numbers designated for no detectable emissions and signed by owner/operator
•	for each compliance test for dual mechanical seal systems designated for no detectable emissions-
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for dual mechanical seal systems in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for barrier fluid and seal systems
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to criteria and reasons for change
Information to be kept for use in determining exemptions
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
DUAL MECHANICAL SEAL SYSTEM
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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpan W
40 CFR Pan 61.
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial report
•	process unit identification
Subsequent semiannual reports
•	process unit identification
•	By month m the reporting period, the facts that explain each delay of repair, and where
appropriate, why a process unit shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
DUAL MECHANICAL SEAL SYSTEM
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NO DETECTABLE EMISSIONS
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Has an instrument reading of less than 500 ppm above background as measured by the methods
specified in 61.245(c)
Test compliance initially upon designation, annually, and as requested by the Administrator
Applies as basic standard for-
•	closed vent systems
•	pressure relief devices in gas/vapor service
Applies as an alternate standard to:
•	pumps (must have no externally actuated shaft penetrating the pump housing)
•	valves (must have no external actuating mechanism in contact with the process fluid)
•	compressors
Leak Definition
No detectable emissions (<500 ppm above background)
Alternative
Standards
N/A
Exemptions
N/A
Monitoring
Method
Method 21
Repair
Requirements
N/A
Delay of Repair
N/A
NO DETECTABLE EMISSIONS
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NO DETECTABLE EMISSIONS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak is detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after leak has been repaired
Information to be kept in log for 2 years after leak detected:
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within IS calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the IS days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all
•	list of ID numbers of equipment designated for no detectable emissions and signed by
owner/operator
•	for each compliance test for no detectable emissions.
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of IDs of equipment in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for use in determining exemptions.
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
Reporting
Requirements
Semiannual reports
•	process unit ID
•	dates of process unit shutdowns that occurred within the semi-annual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests and monitoring to determine compliance with no detectable
emissions
NO DETECTABLE EMISSIONS
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OPEN-ENDED VALVES OR LINES
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Part 61.
40 CFR Pan 63.
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Basic Standard
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve close valve on process fluid end before closing second valve
Double block and bleed system bleed valve or line may remain open during venting operations that
require venting the line between the block valves but comply with basic standard at all other times
Leak Definition
N/A
Alternative
Standards
Alternative means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept for all open-ended valves or lines:
•	list of ID number of subject open-ended valves or lines
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for use in determining exemptions
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
OPEN-ENDED VALVES OR LINES
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OPEN-ENDED VALVES OR LINES
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial report
•	equipment identification number
•	process unit number
•	type of equipment
•	percent weight VHAP
•	process fluid state
•	method of compliance
•	reporting schedule for submittal of subsequent semiannual reports
•	statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports
•	process unit ID
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
OPEN-ENDED VALVES OR LINES
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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
No detectable emissions (less than 500 ppm above background)
After each release, return to no detectable emissions within 5 calendar days as indicated by
monitoring of the pressure relief device
Leak Definition
No detectable emissions (< 500 ppm above background)
Alternative
Standards
N/A
Exemptions
Equipment in vacuum service
Any pressure relief device equipped with a compliant closed-vent system and control device (see
Closed-vent Systems and Control Devices)
Monitoring
Method
Method 21
Repair
Requirements
Return to condition of "no detectable emissions" as soon as practicable but no later than 5 calendar
days after pressure release
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all pressure relief devices.
•	list of ID numbers of subject pressure relief devices
•	list of ID numbers of pressure relief devices for no detectable emissions and signed by
owner/operator
•	for each compliance test for pressure relief devices designated for no detectable emissions
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for pressure relief devices in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kepi for pressure relief devices equipped with a closed-vent system and control
device
•	periods when the closed-vent system and control device is not operated as designed, including
periods when a flare pilot light does not have a flame
•	dates of start-up and shutdown of the closed-vent system and control device
Information to be kept for use in determining exemptions'
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
Reporting
Requirements
Initial report
•	equipment identification number
•	process unit number
•	type of equipment
•	percent weight VHAP
•	process fluid state
•	method of compliance
•	reporting schedule for submittal of subsequent semiannual reports
•	statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports
•	process unit identification
•	the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests and monitoring to determine compliance with no detectable
emissions
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
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PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
FLANGES AND OTHER CONNECTORS
		APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265, Subpan BB
ITEM
REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, auditory, olfactory, or other detection method
Leak Definition
10,OCX) ppm
Alternative
Standards
Alternative means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is _> 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the 15 days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
(Continued on next page)
PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
FLANGES AND OTHER CONNECTORS
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PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
FLANGES AND OTHER CONNECTORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
(continued)
Information to be kept for all pressure relief devices, flanges and other connectors:
•	list of ID numbers of subject pressure relief devices, flanges and other connectors
•	list of ID numbers for equipment in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for use in determining exemptions
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
Reporting
Requirements
Initial report:
•	equipment identification number
•	process unit number
•	type of equipment
•	percent weight VHAP
•	process fluid state
•	method of compliance
•	reporting schedule for submittal of subsequent semiannual reports
•	statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports
•	process unit identification
•	the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions Co the initial report
PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
FLANGES AND OTHER CONNECTORS
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PRODUCT ACCUMULATOR VESSELS
APPLICABLE REGULATIONS
40 era Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Equip with a compliant closed-vert system and control device
Leak Definition
N/A
Alternative
Standards
Alternative means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept for all product accumulator vessels
•	list of ID numbers of subject product accumulator vessels
•	list of ID numbers for product accumulator vessels in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
•	periods when the closed-vent system and control device are not operated as designed, including
periods when a flare pilot light does not have a flame
•	dates of startups and shutdowns of the closed-vent system and control device
Information to be kept for use in determining exemptions
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
PRODUCT ACCUMULATOR VESSELS
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PRODUCT ACCUMULATOR VESSELS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpan BB
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial report*
•	process unit identification
•	equipment identification number
•	type of equipment
•	percent weight VHAP
•	process fluid state
•	method of compliance
•	reporting schedule for submittal of subsequent semiannual reports
•	statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports
•	process unit identification
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
PRODUCT ACCUMULATOR VESSELS
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PUMPS IN VHAP SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Monthly monitoring
Weekly visual observation for dripping liquids
Leak Definition
10,000 ppm
Indications of liquids dripping from pump seal
Alternative
Standards
Alternative means of emission limitation
Exemptions
Pumps designated for no detectable emissions (see No Detectable Emissions)
Pumps equipped with a compliant closed-vent system and control device (see Closed-vent Systems
and Control Devices)
Pumps equipped with a dual mechanical seal (see Dual Mechanical Seals)
Pumps in vacuum service
Any pump located at unmanned site is exempt from weekly visual inspections and daily sensor checks
provided each pump is visually inspected as often as practicable and at least monthly
Monitoring
Method
Method 21, no more than 1 cm from rotating shaft
Repair
Requirements
First attempt withm 5 calendar days of detection
Repair as soon as practicable, no later than IS days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
Allowed if repair requires use of a dual mechanical seal system that includes a barrier fluid system
and repair is completed as soon as practicable but not later than 6 months after leak was detected
PUMPS IN VHAP SERVICE
page C-4L

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PUMPS IN VHAP SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63.
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is _> 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within IS calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the 15 days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all pumps
•	list of ID numbers of subject pumps
•	list of ID numbers of pumps designated for no detectable emissions and signed by
owner/operator
•	for each compliance test for pumps designated for no detectable emissions
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of pumps in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for barrier fluid and seal systems:
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to criteria and reasons for change
Information to be kept for pumps equipped with a closed-vent system and control device
•	periods when the closed-vent system and control device is not operated as designed, including
periods when a flare pilot light does not have a flame
•	dates of start-up and shutdown of the closed-vent system and control device
Information to be kept for use in determining exemptions
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
PUMPS IN VHAP SERVICE
page C-42

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PUMPS IN VHAP SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pari 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial report:
•	equipment identification number
•	process unit number
•	type of equipment
•	percent weight VHAP
•	process fluid state
•	method of compliance
•	reporting schedule for submittal of subsequent semiannual reports
•	statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports:
•	process unit identification
•	the following information by month in the reporting period:
•	• number of pumps for which leaks were detected
•	• number of pumps for which leaks were not repaired within IS days after detection
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to uems reported m the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests and monitoring to determine compliance with no detectable
emissions.
PUMPS IN VHAP SERVICE
page C-43

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SAMPLING CONNECTION SYSTEMS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB





ITEM
REQUIREMENTS
Basic Standard
Equip with closed-purge system or closed-vent system that returns the fluid to the process line with
zero VHAP emissions to the atmosphere, recycles the purged fluid with zero VHAP emissions to the
atmosphere, or sends it to a compliant control device
Leak Definition
N/A
Alternative
Standards
Alternative means of emission limitation
Exemptions
Equipment in vacuum service
In-situ sampling systems
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept for all sampling connections:
•	list of ID numbers of subject sampling connection systems
•	periods when the closed-vent system and control device are not operated as designed, including
periods when a flare pilot light does not have a flame
•	dates of startups and shutdowns of the closed-vent system and control device
•	list of ID numbers of equipment m vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for use m determining exemptions
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
SAMPLING CONNECTION SYSTEMS
page C-44

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SAMPLING CONNECTION SYSTEMS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial report,
o process unit identification
ฐ equipment identification number
o type of equipment
ป percent weight VHAP
o process fluid state
o method of compliance
ฐ reporting schedule for submittal of subsequent semiannual reports
o statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports:
ฎ process unit ID
o revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
SAMPLING CONNECTION SYSTEMS
page C-45

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VALVES IN VHAP SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61,
40 CFR Pan 63.
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Monthly monitoring
If valve does not leak for 2 months, may be monitored quarterly
If leak detected, monitor monthly until no leak is detected for 2 consecutive months
Leak Definition
10,000 ppm
Alternative
Standards
Alternative means of emission limitation
Allowable percentage of valves leaking may elect to comply with s2% leaking valves
•	notify Administrator before implementing
•	conduct performance tests initially, annually, and as requested by Administrator
•	• monitor within one week using Method 21
•	• leak definition is 10,000 ppm
•	• leak percentage cannot be greater than 2.0%
•	notify Administrator if no longer complying with alternate standard
Skip period leak detection and repair.
•	notify Administrator before implementing
•	comply initially with basic standard
•	if s2% leaking after 2 consecutive quarterly leak detection periods, may begin to skip 1 of the
quarterly monitoring periods
•	after 5 consecutive periods with s2 0% leaking, may begin to skip 3 of the quarterly periods
•	if >2.0% leaking, comply with basic standard, but can again elect to use alternate standard
Exemptions
Valves in vacuum service
Valves designated for no detectable emissions {less than 500 ppm above background) (see No
Detectable Emissions)
Valves designated unsafe to monitor or difficult to monitor
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
VALVES IN VHAP SERVICE
page C-46

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VALVES IN VHAP SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs
Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted
Not allowed beyond next process unit shutdown unless next process unit shutdown occurs sooner than
6 months after first process unit shutdown
Recordkeeping
Requirements
When leak detected-
•	a weather-proof and readily visible identification, marked with the equipment ED number,
attached to the leaking equipment
•	ID may be removed after it has been repaired and monitored for 2 months with no leaks
Information to be kept in log for 2 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within IS calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
ฆ expected date of successful repair if leak is not repaired within the IS days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all valves.
•	list of ID numbers of subject valves
•	list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
•	for each compliance test for valves designated for no detectable emissions
•	• dale conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for valves in vacuum service
•	information and data used to demonstrate equipment is not in VHAP service
Information to be kept for unsafe or difficult to monitor valves
•	list of ED numbers
•	explanation for designation
o planned schedule for monitoring
(Continued on next page)
VALVES IN VHAP SERVICE
page C-47

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VALVES IN VHAP SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements,
continued
Information to be kept for valves complying with alternate standard - skip period leak detection and
repair:
•	schedule of monitoring
•	percent of valves found leaking during each monitonng period
Information to be kept for use in determining exemptions
•	analysis demonstrating design capacity of the process unit
•	analysis demonstrating that equipment is not in VHAP service
Reporting
Requirements
Initial report
•	valve ID number
•	process unit identification
•	type of equipment
•	percent weight VHAP
•	process fluid state
•	method of compliance
•	reporting schedule for submittal of subsequent semiannual reports
•	statement notifying Administrator that subpart requirements are being implemented
Subsequent semiannual reports
•	process unit identification
•	the following information by month in the reporting period
•	• number of valves for which leaks were detected
•	• number of valves for which leaks were not repaired within 15 days after detection
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	report of all performance tests in accordance with no detectable emissions
VALVES IN VHAP SERVICE
page C-48

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AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and 1
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
"Non-dual mechanical seal" agitators
•	monthly monitoring and weekly visual check for indications of dripping liquid
•	if at unmanned site, visually inspect as often as practicable and at least monthly
Leak Definition
Monitoring 10,000 ppm
Visual, indications of liquids dripping from agitator
Alternative
Standards
Enclosed-vented process units may enclose process units and operate under negative pressure while
venting all leaks from equipment through a closed-vent system to a control device meeting the
requirements of this rule
Batch processes, may pressure test or monitor equipment for leaks
Exemptions
Dual mechanical seal agitators (see Dual Mechanical Seal Systems)
Agitators designed with no externally actuated shaft penetrating the agitator housing
Agitators equipped with closed-vent system and control device (see Closed-vent Systems and Control
Devices)
Agitators located at unmanned plant site are exempt from weekly visual inspection and daily sensor
check if visually inspected as often as practical and at least monthly
Difficult to monitor agitators exempt if-
•	agitator cannot be monitored without elevating personnel more than 2 meters above a support
surface or if it is not accessible at any time in a safe manner,
•	process unit where agitator is located is an existing source or < 3 % of total number of agitators
in a new source are designated difficult to monitor, and
•	written plan requires monitoring at least once per calendar year
Unsafe to monitor agitators are exempt if
•	monitoring personnel would be exposed to an immediate danger, and
•	written plan requires monitoring as frequently as practical during safe to monitor times, but not
more frequently than monitoring schedule
Agitators obstructed by equipment or piping that prevents access by a monitor probe
Equipment in vacuum service
Equipment operated fewer than 300 hours per year in organic HAP service
Monitoring
Method
Method 21, no more than 1 cm from rotating shaft
•	response factor criteria (excluding inerts) for average composition of process fluid
•	monitor all equipment while it is "in service"
AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
page C-49

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AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
Delay of Repair
Allowed if technically mfeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs
AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
page C-50

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AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak detected.
•	instrument and equipment ID number and operator name, initials, or ID number
•	date leak detected
•	date of first attempt to repair leak
•	maximum instrument reading after successful repair or determination the equipment is
nonrepairable
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	copies of periodic reports (if database not capable of generating)
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all agitators.
•	list of ID numbers of subject equipment
•	location of equipment on site plan, log entries, etc
•	list of ID numbers of equipment equipped with closed-vent system and control device
•	documentation and dates of visual inspections
Information to be kept for agitators with dual mechanical seal system-
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to criteria and reasons for changes
Information to be kept for unsafe to monitor agitators
•	identification of equipment designated as unsafe to monitor
•	plan for monitoring
Information to be kept for difficult to monitor agitators
•	list of ID numbers for equipment designated as difficult to monitor
•	explanation of designation
•	planned schedule for monitoring
Information and data used to demonstrate that equipment is not in organic HAP service, is in HAP
service fewer than 300 hours/year, or is in heavy liquid service
AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
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AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Pari 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of compliance status'
•	process unit identification
•	number of agitators (excluding those in vacuum service)
•	method of compliance
Subsequent semiannual reports
•	the following information for each monitoring period during the 6-month reporting period-
•	• number of agitators for which leaks were detected
•	• number of agitators for which leaks were not repaired as required
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	revisions to items reported m the notification of compliance status if method of compliance has
changed since the last report
•	information listed under notification of compliance status for process units with later compliance
dates
AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
page C-52

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ALTERNATIVE MEANS OF EMISSION LIMITATION:
ENCLOSED-VENTED PROCESS UNITS
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and 1
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Process units enclosed in such a manner that all emissions from equipment leaks are vented through a
closed-vent system to a control device The enclosures shall be maintained under negative pressure at
all times the process unit is in operation
Recordkeeping
Requirements
Owner/operators shall maintain the following records:
•	ID numbers of the process units and the organic HAPs they handle
•	a schematic of the process unit, enclosure, and closed vent system
•	a description of the system used to create a negative pressure in the enclosure to ensure that all
emissions are routed to the control device
Reporting
Requirements
Information for each process unit:
•	process unit identification
•	description of the system used to create a negative pressure in the enclosure and the control
device used
ALTERNATIVE MEANS OF EMISSION LIMITATION
ENCLOSED-VENTED PROCESS UNITS	page C-53

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ALTERNATIVE MEANS OF EMISSION LIMITATION:
BATCH PROCESSES
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Basic Standard
(Alternative)
1)	Batch pressure test or
2)	Meet standards for continuous processes with changes to monitoring
Monitoring
Options
1)	Batch pressure testing
•	test batch process equipment using either
•	• procedures specified for pressure or vacuum loss [see ง63.180(f)] or
•	• with a liquid using procedures specified in ง63 180(g)
•	each time equipment is reconfigured for production of a different product or intermediate, the
batch product-process equipment train shall be pressure tested for leaks before organic HAP is
first fed to the equipment and the equipment is placed in organic HAP service
•	when the batch product-process train is reconfigured to produce a different product, pressure
testing is required only for the new or disturbed equipment
•	each batch process that operates in organic HAP service during a calendar year must be pressure
tested at least once during that calendar year
•	pressure testing is not required for routine seal breaks, such as changing hoses or filters, which
are not part of the reconfiguration to product a different product or intermediate
•	for pressure tests using a gas or a vacuum, a leak is found if the rate of pressure change exceeds
1 psig in 1 hour or if there is visible, audible, or olfactory evidence of fluid loss
•	for pressure tests using a liquid, a leak is defined as dripping liquid or other evidence of fluid
loss from process units
2)	Continuous process monitoring method
•	monitor for leaks when the equipment is in organic HAP service, in use with an acceptable
surrogate volatile organic compound which is not an organic HAP, or in use with any other
detectable gas or vapor
•	each time the equipment is reconfigured for the production of a new product, the reconfigured
equipment shall be monitored for leaks within 30 days of start-up of the process; this initial
monitoring of reconfigured equipment shall not be included in determining percent leaking
equipment in the process unit.
•	connectors are to be monitored in accordance with ง63 174
•	monitor equipment other than connectors at the frequencies specified in the following schedule
EQUIPMENT MONITORING FREQUENCIES (other than connectors)
Time in Use (% of year) Equivalent Continuous Process Monitoring Frequency
Monthly Quarterly Semiannually
Oto <25 quarterly annually annually
25 to <50 quarterly semiannually annually
50 to < 75 bimonthly three times/year semiannually
75 to 100 monthly quarterly semiannually

ALTERNATIVE MEANS OF EMISSION LIMITATION
BATCH PROCESSES
page C-54

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ALTERNATIVE MEANS OF EMISSION LIMITATION:
BATCH PROCESSES
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 263, Subpart BB




ITEM
REQUIREMENTS
Repair
Requirements
Batch
•	when leaks are detected, repairs must be made and a retest conducted before startup of the
process
•	if the process unit fails this retest or the second of 2 consecutive pressure tests, the equipment
must be repaired as soon as practicable but not later than 30 calendar days after second pressure
test
Continuous:
•	If a leak is detected, it shall be repaired as soon as practicable but not later than 15 calendar days
after it is detected
Delay of Repair
Allowed if the replacement equipment is not available, providing the following conditions are met"
ฆ equipment supplies have been depleted and supplies had been sufficiently stocked before the
supplies were depleted
• the repair is made no later than 10 calendar days after delivery of the replacement equipment
ALTERNATIVE MEANS OF EMISSION LIMITATION
BATCH PROCESSES	page C-55

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ALTERNATIVE MEANS OF EMISSION LIMITATION:
BATCH PROCESSES
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265. Subpart BB
ITEM
REQUIREMENTS
Recordkeeping
For each component, all other elements of the rule (leak definition, records, reports, etc.) apply the
same as for continuous processes
Identify equipment on a plant site plan, in log entries, or by other appropriate methods
List of equipment added since last monitoring period
Documentation of any switch from batch process monitoring to pressure testing or vice versa
Record that inspection was performed if no leaks are found
Records of any visible, audible, or olfactory evidence of fluid loss
Batch pressure testing
•	batch products or product codes for equipment subject to this monitoring option
•	identification of each product or product code produced during the calendar year; it is not
necessary to identify individual items of equipment in a batch product process equipment train
•	records demonstrating the proportion of the time during the calendar year the equipment is in use
in a batch process, examples of suitable documentation are records of time in use for individual
pieces of equipment or average time in use for the process unit
•	the dates of each pressure test, the test pressure, and the pressure drop observed durtng the test
When a batch product process equipment train does not pass two consecutive pressure tests, the
following information shall be recorded in a log and kept for 2 years
•	the date of each pressure test and the date of each leak repair attempt
•	repair methods applied in each attempt to repair the leak
•	the reason for the delay of repair
•	the expected date for delivery of the replacement equipment and the actual date of delivery of the
replacement equipment
•	the date of successful repair
Continuous process monitoring-
•	records demonstrating the proportion of the time during the calendar year the equipment is in use
in a batch process, examples of suitable documentation are records of time in use for individual
pieces of equipment or average time in use for the process unit, these records are not required if
the owner or operator does not adjust monitoring frequency by the time in use
•	date and results of monitoring for equipment added to the batch process unit since the last
monitoring period
ALTERNATIVE MEANS OF EMISSION LIMITATION
BATCH PROCESSES
page C-56

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ALTERNATIVE MEANS OF EMISSION LIMITATION:
BATCH PROCESSES
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Notification of compliance status'
•	batch products or product codes designated for pressure testing and
•	a planned schedule for pressure testing when equipment is configured for production of products
subject to provisions of subpart.
Periodic reports:
•	batch product process equipment train identification
•	the number of pressure tests conducted
•	the number of pressure tests where the equipment train failed the pressure test
•	the facts that explain any delay of repairs
•	the results of all monitoring to determine compliance of closed-vent systems
ALTERNATIVE MEANS OF EMISSION LIMITATION
BATCH PROCESSES	page C-57

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264. Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Basic Standard
Control devices and closed-vent systems operate whenever HAP emissions may be vented to them
Control devices subject to 40 CFR 63 subpart H and 40 CFR 264 subpart BB or 40 CFR 265 subpart
BB may comply with the monitoring, recordkeeping and reporting requirements of subpart H or of
pans 264 and/or 265
Recovery or Recanture Devices
Vapor recovery systems 95 percent or greater recovery or an exit concentration of 20 ppmv,
whichever is less stringent
Enclosed combustion devices- 95% or more reduction, or 20 ppmv on any basis, corrected to
3% 02, whichever is less stringent, or minimum residence time/temp 0.50 sec. & 760ฐ C
Flares Comply with ง63 11(b)
Closed-Vent Systems
Initial and annual inspection requirements-
•	hard pipe construction initial inspection per Method 21, annual visual inspections for
visual, olfactory or audible leaks
•	duct work construction, initial and annual inspections per Method 21
Leak Definition
No detectable emissions (< 500 ppm above background)
Visual inspections
Alternative
Standard
Alternative means of emission limitation
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-58

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpan BB




ITEM
REQUIREMENTS
Exemptions
Equipment in vacuum service
Equipment in organic HAP service fewer than 300 hours per year
Equipment such as low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and
pressure relief valves needed for safety purposes exempt from monitoring requirements
"Unsafe to inspect" parts are exempt from ง63 180(b) inspections if.
•	inspecting personnel would be exposed to an imminent or potential danger, and
•	the owner or operator has a written plan requiring inspection during safe to inspect times as
frequently as practicable but not more than once per year
"Difficult to inspect" parts are exempt from ง63 180(b) inspections if.
•	the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters
above a support surface, and
•	the owner or operator has a written plan requiring inspection of the equipment at least once every
5 years
Monitoring
Method
Monitor control devices to ensure operated & maintained in conformance with design specifications
By-pass lines
•	install, set or adjust and maintain vent stream flow indicator installed at entrance to any bypass
line or
•	secure valve in non-diverting position with car-seal or lock-and-key type locks with monthly
visual inspection
Method 21
•	response factor criteria (excluding inerts) for average composition of process fluid
•	monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically mfeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, required before end of next process unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-59

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after equipment has been repaired
Information to be kept in log for 2 years after leak detected
•	instrument and equipment ID number and operator name, initials, and ID number
•	date leak detected
•	date of first attempt to repair leak
•	maximum instrument reading after successful repair or if determined to be nonrepayable
•	"repair delayed" and reason for delay if leak not repaired within IS calendar days after detection
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	copies of periodic reports (if database not capable of generating)
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all closed-vent systems and control devices
•	list of ID numbers of subject equipment
•	location of equipment on site plan, log entries, etc.
•	list of ID numbers for components equipped with closed-vent system and control device
•	ID of surge control vessels and bottoms receivers equipped with closed-vent system and control
device
•	documentation of visual inspections
•	design specifications (retain for life of equipment)
•	• design specifications and performance demonstrations to include detailed schematics and
piping and instrumentation diagrams
•	• dates and descriptions of any changes m the design specifications
•	• flare design and results of compliance demonstration
•	• description and explanation of control device monitoring parameters
•	records of operation (retain for 2 years)
•	• dates and durations when closed-vent system and control device is not operated as designed
(includes lack of flame in flare pilot light) and when monitoring systems/devices are
nonoperative
•	• dates and durations of start-ups and shutdowns of control devices
•	records of inspections (retain for 2 years)
•	• if no leaks detected record date and fact of inspection and statement no leaks detected
•	• if leaks detected information specified previously
Information and data used to demonstrate that a closed-vent system and control device is not in
organic HAP service or is in HAP service fewer than 300 hours/year
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-60

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Pan 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification:
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of compliance status:
•	process unit identification
•	number of closed-vent system and control device, excluding those in vacuum service
•	method of compliance
Subsequent semiannual reports:
•	the facts that explain any delay of repairs
•	the results of all monitoring of closed-vent systems or of control devices
•	revisions to items reported in the initial compliance notice if method of compliance has changed
since the last report
•	if applicable, the compliance option selected for closed-vent systems and control devices
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-61

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subpans J and V
40 CFR Pan 63,
Subpans H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Equip with compliant seal system that includes a barrier fluid system that prevents leakage to
atmosphere
For each compressor seal system:
•	operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
•	equip with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or
connected by a closed-vent system to a control device, or
•	equip with a closed-loop system that purges the barrier fluid into a process stream
The barrier fluid system is not in light liquid service
Install sensor to detect failure of seal system, barrier fluid system, or both
Check sensor daily or equip with audible alarm, unless at an unmanned plant site
Establish criteria that indicates failure of seal system or barrier fluid system or both
Leak Definition
Sensor indicates failure of seal or barrier fluid system or both based on established critena
Alternative
Standards
Alternative means of emission limitation
Enclosed-vented process units may enclose process units and operate under negative pressure while
venting all leaks from equipment through a closed-vent system to a control device meeting the
requirements of the rule
Batch processes: may pressure test or monitor equipment for leaks
Exemptions
Compressors designated to operate with instrument reading of less than 500 ppm above background
(see No Detectable Emissions)
Compressors equipped with closed-vent system, returns to a process, fuel gas system or compliant
control device (see Closed-vent Systems and Control Devices)
Compressors in vacuum service
Compressors operated fewer than 300 hours per year in organic HAP services
Monitoring
Method
Daily observation of sensors or use of sensor alarm system
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 calendar days after detection
COMPRESSORS
page C-62

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Recordkeeping
Requirements
When leak detected:
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak detected.
•	instrument and equipment ID number and operator name, initials, or ID number
•	date leak detected
•	date of first attempt to repair leak
•	maximum instrument reading after successful repair or determination to be nonrepayable
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	dates of process unit shutdowns that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for ail compressors
•	list of ID numbers of subject compressors
•	location of compressor on site plan, log entries, etc
•	list of ID numbers of compressors equipped with closed-vent system and control device
•	list of ID numbers of compressors designated to operate at less than 500 ppm above background
•	documentation and dates of visual inspections
•	for each compliance test for compressors designated to operate at less than 500 ppm above
background
•	• date conducted and results of test
•	• background level measured
•	• maximum instrument reading
•	copies of periodic reports (if database not capable of generating)
Information to be kept for barrier fluid and seal systems.
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to criteria and reasons for change
Information and data used to demonstrate that a compressor is not in organic HAP service or is in
HAP service fewer than 300 hours/year
COMPRESSORS
page C-63

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of compliance status
•	process unit identification
•	number of compressors (excluding those in vacuum service)
•	method of compliance
Subsequent semiannual reports
•	the following information for each monitoring period during the 6-month period
•	• number of compressors for which leaks were detected
•	• number of compressors for which leaks were not repaired as required
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	results of monitoring for compressors designated to operate at less than 500 ppm
•	revisions to items reported in the notification of compliance status if method of compliance has
changed since the last report
•	information listed under Notification of Compliance for process units with later compliance dates
COMPRESSORS
page C-64

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CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
REQUIREMENTS
Basic Standard
Initial survey
•	Monitor all connectors within first 12 months after initial start-up (new sources)
•	Monitor all connectors no later than 12 months after compliance date (existing)
Subsequent monitoring frequency based on percent leaking-
•	Annual if sO 5% during last annual or biennial period
•	Once every 2 years- if <0 5% during last monitoring period (monitor at least 40% of connectors
m first year and remainder in second year)
•	Once every 4 years: if <0 5% during 2 year monitoring period (monitor at least 20% per year
until all are monitored within 4 years)
•	Once every 2 years: 0.5 to < 1 % during 4 year monitoring period (monitor at least 40% of
connectors first year and remainder in second year)
•	Annual if > 1 % during 4 year monitoring period
For any connector that has been opened or otherwise has had its seal broken, monitor when
reconnected or within first 3 months of being returned to HAP service.
If leak is detected and it cannot be repaired, then the connector should be counted as nonrepayable
for purposes of determining monitoring frequency If the owner or operator chooses not to monitor
connectors that have been opened or otherwise had the seal broken, then he cannot count
nonrepayable connectors for the purposes of determining monitoring frequency The owner or
operator will instead set the nonrepayable component of the monitoring frequency equation to zero
for all monitoring periods
A switch in alternatives requires initial monitoring no later than 12 months after reporting the switch
Leak Definition
500 ppm (except for inaccessible, ceramic, or ceramic-lined connectors)
Alternative
Standards
Alternative means of emission limitation
Alternative requirements allowed for screwed connectors less than 2 inches in nominal inside
diameter; may comply with 63.169 and monitor within first 3 months of return to organic HAP
service after being opened or having seal otherwise broken
Alternative requirements for connectors that have had the seal broken or otherwise been opened (see
Basic Standard above)
CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-65

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CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Exemptions
Connectors in vacuum service
Connectors in organic HAP service fewer than 300 hours per year
"Unsafe-to-monitor" connectors monitor as frequently as practicable during safe to monitor periods,
but no more frequently than the periodic schedule otherwise applicable
"Unsafe-to-repair" connectors repair by end of the next scheduled process unit shutdown
"Inaccessible" or "ceramic" or "ceramic-lined" connectors repair any leak observed by visual,
audible, olfactory or other means
Monitoring
Method
Method 21
•	response factor criteria (excluding inerts) for average composition of process fluid
•	monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
When repaired, monitor at least once within first 3 months of repair
Delay of Repair
Allowed if technically mfeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed if emissions of purged materials from immediate repair would exceed fugitive emissions
from delay of repair, and purged materials are collected and destroyed or recovered in a control
device when repair occurs
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Calculation of
Percent Leaking
For the first monitoring period
•	percent leaking connectors = [number of connectors measured at 500 ppm or greater / (total
number of measured connectors in the process unit + optional credit for removed connectors)] *
100
For subsequent monitoring periods'
•	percent leaking connectors = {(number of connectors measured at 500 ppm or greater - number
of allowable nonrepayable connectors) / (total number of monitored connectors in the process
unit + optional credit for removed connectors)] * 100
CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-66

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CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61.
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Optional Credit
for Removed
Connectors
Credit may be given for eliminating connectors if the following requirements are met.
•	connector was welded after the date of proposal of the specific subpart that references this
subpart
•	integrity of the weld is demonstrated by monitoring it accordtng to the procedures m 63.180(b)
or by testing using X-ray, acoustic monitoring, hydrotesting, or other applicable method
•	welds created after the date of proposal but before the date of promulgation of a specific subpart
that references this subpart are monitored or tested by 3 months after the compliance date
specified in the applicable subpart, and
•	welds created after promulgation of the subpart that references this subpart are monitored or
tested within 3 months after being welded
If an inadequate weld is found or the connector is not welded completely around the circumference,
the connector is not considered a welded connector and is therefore not exempt.
In percent leaking connectors equations, optional credit for removed connectors is calculated-
0.67 * net (total removed - total added) number of connectors in organic HAP service that are
removed from the process unit after compliance date for existing units and after initial start-up for
new units If credits are not taken, the credit = 0
CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
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CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired and monitored when reconnected or within first 3
months of repair and no leak is delected
Information to be kept in log for 2 years after leak detected
•	instrument and equipment ID number and operator name, initials, or ID number
•	date leak detected
•	date of first attempt to repair leak
•	maximum instrument reading after successful repair or determination as nonrepairable
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	dates of process unit shutdowns that occurred while the equipment is unrepaired
•	date of successful repair of the leak
•	dates and results of monitoring
Information to be kept for all connectors:
•	identification of connectors, by area or grouping, with total number of connectors within each
group
•	ID of screwed connectors, by area or grouping, with total number of screwed connectors with
each group
•	location of areas or groups on site plan, log entries, etc.
•	schedule by process unit for monitoring connectors
•	list of connectors removed and added if net credits for their removal are expected to be used
•	list of ID numbers for connectors in vacuum service
•	documentation of the integrity of the weld for removed connectors
•	copies of periodic reports (if database not capable of generating)
•	ID of connectors open or otherwise had the seal broken since the last monitoring period, and
dates and results of follow-up monitoring
Information to be kept for unsafe to monitor connectors
•	identification of equipment designated as unsafe to monitor
•	plan for monitoring
Information to be kept for unsafe to repair connectors
•	list of ID numbers
•	explanation for designation
Information to be kept for inaccessible, ceramic, and ceramic-lined connectors:
•	exempt from recordkeeping requirements
Information and data used to demonstrate that connectors are not in organic HAP service, are in HAP
service fewer than 300 hours/year, or are in heavy liquid service
CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-68

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CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subpans H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of compliance status
•	process unit identification
•	number of connectors, excluding those in vacuum service
•	method of compliance
Subsequent semiannual reports
•	number of connectors and screwed connectors for which leaks were detected
•	total number of connectors and screwed connectors monitored
•	the percent leakers for connectors and screwed connectors
•	number of connectors and screwed connectors for which leaks were not repaired within 15 days
after detection
•	identification of the number of connectors determined to be nonrepairable
•	the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
was technically infeasible
•	notification of change in connector monitoring alternatives (if applicable)
•	revisions to items reported in the initial report if method of compliance has changed since the last
report
•	initiation of monthly monitoring under Phase HI or QIP (if applicable)
•	information listed under notification of compliance status for process units with later compliance
dates
Inaccessible, ceramic, and ceramic-lined connectors exempt from reporting requirements
CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-69

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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61.
40 CFR Pan 63,
40 CFR Pan 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265. Subpan BB




ITEM
REQUIREMENTS
Basic Standard
For each dual mechanical seal system
•	operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
•	equip with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or
connected by a closed-vent system to a control device, or
•	equip with a closed-loop system that purges the barrier fluid into a process stream
For all dual mechanical seal systems
•	the barrier fluid system is not m light liquid service
•	barrier fluid system is equipped with a sensor to detect failure of seal system, barrier fluid
system, or both
•	• check each sensor daily or equip with audible alarm unless located at unmanned sue
•	• determine cnienon that indicates failure of the seal system, the barrier fluid system, or both
•	perform weekly visual inspections for indications of liquid dripping from the pump seals;
monitor if indications observed to determine if there is a leak of HAP in the barrier fluid
Applies as an alternative standard for
•	Pumps in Light Liquid Service
•	Agitators an GasA'apor Service and in Lighi Liquid Service
Leak Definition
Indications of liquids dripping from the pump seal and instrument reading of 1000 ppm HAP, failure
of sensor criteria
Alternative
Standards
N/A
Exemptions
Any affected equipment equipped with a closed-vent system transporting fluid to process fuel gas
system or control device
Unsafe-to-momtor pumps are exempt if-
•	monitoring personnel would be exposed to an immediate danger
*	owner/operator has a written plan that requires monitoring as often as practical during safe to
monitor times
If at unmanned plant site, visually inspect as often as practical and at least monthly
Monitoring
Method
Visual, sensor
Repair
Requirements
First anempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after leak is detected
DUAL MECHANICAL SEAL SYSTEM
page C-70

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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265. Subpart BB
ITEM
REQUIREMENTS
Delay of Repair
Allowed if repair requires replacing the existing seal design with a new system that meets improved
performance criterion
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Recordkeeping
Requirements
When leak detected.
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after leak has been repaired
Information to be kept in log for 2 years after leak detected
•	instrument and equipment ID number, and operator name, initials, or ID number
•	date leak detected
•	date of first attempt to repair leak
•	maximum instrument reading after successful repair or determined to be nonrepayable
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	expected date of successful repair if leak is not repaired within the IS days
•	date of successful repair of the leak
Information to be kept for all dual mechanical seal systems
•	list of ID numbers of dual mechanical seal systems
•	location of equipment on site plan, log entries, etc
•	documentation and dates of visual inspections
•	copies of periodic reports (if database not capable of generating)
Information to be kept for barrier fluid and seal systems-
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to criteria and reasons for change
Identification, by list or location, of equipment m organic HAP service fewer than 300 hours per year
DUAL MECHANICAL SEAL SYSTEM
page C-7]

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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpan BB
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of compliance status*
•	process unit identification
•	number of pumps (excluding those in vacuum service)
•	method of compliance
Subsequent semiannual reports
•	the following information for each monitoring period in the reporting period-
•	• number of pumps for which leaks were detected
•	• percent of pumps leaking
•	• total number of pumps monitored
•	• number of pumps for which leaks were not repaired as required
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	revisions to items reported in the initial notification of compliance if method of compliance has
changed since the last report
•	information listed under Notification of Compliance for process units with later compliance dates
DUAL MECHANICAL SEAL SYSTEM
page C-72

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OPEN-ENDED VALVES OR LINES
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end or during maintenance and repair
Second valve close valve on process fluid end prior to closing second valve
Double block and bleed system bleed line valve may remain open during venting operations that
require venting the line between the block valves but comply with basic standard at all other times
Leak Definition
N/A
Alternative
Standards
Alternative means of emission limitation
Exemptions
Emergency shutdown system
Equipment containing materials which would automatically polymerize or cause a safety hazard if
capped or equipped with a double block and bleed system
Equipment in vacuum service
Equipment operated fewer than 300 hours per year
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept for all open-ended valves or lines-
•	list of ID number of subject equipment
•	location on site plan, log entries, etc
Copies of periodic reports (if database not capable of generating)
Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours/year
OPEN-ENDED VALVES OR LINES
page C-73

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OPEN-ENDED VALVES OR LINES
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpan W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of compliance status
•	process unit identification
•	number of open-ended valves or lines (excluding those in vacuum service)
•	method of compliance
Subsequent semiannual reports
•	dates of process unit shutdowns that occurred within the semiannual reporting period
•	revisions to items reported in the initial report if changes in the method of compliance have
changed since the last report
•	information listed in notification of compliance status for process units with later compliance
dates
OPEN-ENDED VALVES OR LINES
page C-74

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61.
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Without rupture disk.
•	operate at less than 500 ppm above background except during pressure releases
•	within 5 calendar days after each release, return to operating standard and monitor the pressure
relief device (PRD) to confirm
•	within 5 calendar days after the pressure release and being returned to HAP service, monitor to
confirm 500 ppm above background standard
With rupture disk
•	after each release, replace rupture disk within 5 calendar days
Leak Definition
< 500 ppm above background
Alternative
Standards
Alternative means of emission limitation
Exemptions
Pressure relief device routed to a process or fuel gas system or equipped with compliant closed-vent
system and control device (see Closed-vent Systems and Control Devices)
Pressure relief device in vacuum service
Pressure relief device in organic HAP service fewer than 300 hours per year
Any pressure relief device equipped with a rupture disk meeting the requirements of the rule
Monitoring
Method
Method 21
•	Response factor criteria (excluding inerts) for average composition of process fluid
•	Monitor all equipment while it is "in service"
Repair
Requirements
See basic standard
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-75

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after leak has been repaired
Information to be kept in log for 2 years after leak detected:
•	instrument and equipment ID number, and operator name, initials, or ID number
•	date leak detected
•	dates of first attempt to repair leak
•	maximum instrument reading after successful repair or determined to be nonrepairable
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	copies of periodic reports (if database not capable of generating such)
•	expected date of successful repair if leak is not repaired within the 15 days
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all pressure relief devices.
•	list of ID numbers of pressure relief devices
•	list of ID numbers of pressure relief devices equipped with rupture disks
•	list of ID numbers of pressure relief devices complying with an instrument reading of less than
500 ppm above background standard
•	location of pressure relief devices on sue plan, log entries, etc
•	list of ID numbers for pressure relief devices equipped with closed-vent system and control
device
•	documentation and dates of visual inspections
•	for monitoring following a pressure release for each PRD
•	• dates and results of monitoring
•	• background level measured
•	• maximum instrument reading
Information and data used to demonstrate that a pressure relief device is not in organic HAP service
or is in HAP service fewer than 300 hours/year
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-76

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 Cre Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of Compliance Status:
•	process unit identification
•	number of pressure relief devices, excluding those in vacuum service
•	method of compliance
Subsequent semiannual reports
•	by monitoring period in the reporting period, explanation of why repairs delayed and why a
process unit shutdown was infeasible
•	for "no detectable emissions" components, results of all monitoring to show compliance with the
operating standard of less than 500 ppm
•	revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
•	information listed in Notice of Compliance Status for process units with later compliance dates
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-77

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS

40 CFR Part 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpan BB

Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Monthly leak detection and repair
Weekly visual observation for leaks
For existing sources
•	Phase I begins on compliance date
•	Phase II begins no later than 1 year after compliance date
•	Phase III begins no later than 2 years after compliance date
For new sources
•	Phase II begins after initial start-up
•	Phase III begins no later than 1 year after initial start-up
Choose no later than first monitoring penod whether to calculate percent leaking pumps on a process
unit basis or source-wide basis
Phase III: if the greater of 10% or 3 pumps in a process unit leaks (6 month average), Quality
Improvement Program (QEP) required
Leak Definition
Phase I 10,000 ppm
Phase n- 5,000 ppm
Phase III 5,000 ppm for pumps handling polymerizing monomers
2,000 ppm for pumps in food/medical service
1,000 ppm for all other pumps
Indications of liquids dripping from pump seal
Alternative
Standards
Alternative means of emission limitation
Enclosed-vented process units: may enclose process units and operate under negative pressure while
venting all leaks from equipment through a closed vent system to a control device meeting the
requirements of this rule
Batch processes may pressure test or monitor equipment for leaks
"No detectable emissions" pumps (see No Detectable Emissions)
PUMPS IN LIGHT LIQUID SERVICE
page C-78

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60.
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Exemptions
Dual mechanical seal pumps (see Dual Mechanical Seal System)
Pumps designed with no externally actuated shaft penetrating pump housing
Pump equipped with closed-vent system and control device (see Closed-vent Systems and Control
Devices)
Pumps in vacuum service
Pumps operated fewer than 300 hours per year in organic HAP service
Process units with more than 90% of pumps with dual mechanical seal or closed-vent system are
exempt from monthly calculations of percent leaking pumps
If at unmanned site, visually inspect as often as practicable and at least monthly
Unsafe to monitor pumps are exempt if
•	monitoring personnel would be exposed to an immediate danger
•	owner/operator has a written plan that requires monitoring as often as practical during safe to
monitor times, but not more frequently than the periodic monitoring schedule otherwise
applicable
Monitoring
Method
Method 21, no more than 1 cm from rotating shaft
•	response factor criteria (excluding merts) for average composition of process fluid
•	monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than IS days after detection
Phase IH pumps with leak definition of 1,000 ppm: repair only required for pumps leaking at 2,000
ppm or more
Delay of Repair
Allowed if technically mfeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Allowed if repair requires use of
•	a new system determined to provide better performance under provisions of a QIP, or
•	a dual mechanical seal that includes a barrier fluid system, or
•	a pump designed with no externally actuated shaft, or
•	a closed-vent system and control device
and repair is completed as soon as practicable but not later than 6 months after leak detected
PUMPS IN LIGHT LIQUID SERVICE
page C-79

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected-
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 2 years after leak detected:
•	instrument and equipment ID number and operator name, initials, or ID number
•	date leak detected
•	date of first attempt to repair leak
•	maximum instrument reading (M21) after successful repair or determination the pump is
nonrepayable
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all pumps
•	list of ID numbers of subject pumps
•	location of pump on site plan, log entries, etc.
•	list of ID numbers of pumps equipped with closed-vent system and control device
•	documentation and dates of visual inspections
•	copies of periodic reports (if database not capable of generating)
Information to be kept for unsafe to monitor pumps
•	identification of equipment designated as unsafe to monitor
•	plan for monitoring
Information to be kept for difficult to monitor pumps:
•	list of ID numbers
•	explanation for designation
•	planned schedule for monitoring
Information to be kept for pumps equipped with dual mechanical seal
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to the criteria, and reason for change
Information and data used to demonstrate that a pump is not in organic HAP service, is in HAP
service fewer than 300 hours/year, or is in heavy liquid service
PUMPS IN LIGHT LIQUID SERVICE
page C-80

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification:
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of compliance status
•	process unit identification
•	number of pumps (excluding those in vacuum service)
•	method of compliance
•	planned schedule for each phase of requirements
Subsequent semiannual reports:
•	the following information for each monitoring period in the reporting period:
•	• number of pumps for which leaks were detected
•	• percent of pumps leaking
•	• total number of pumps monitored
•	• number of pumps for which leaks were not repaired as required
•	• the facts that explain each delay of repair, and where appropriate, why a process unit
shutdown was technically infeasible
•	revisions to items reported in the initial notification of compliance status if method of compliance
has changed since the last report
•	initiation of monthly monitoring under phase HI or QIP (if applicable)
•	information listed under notification of compliance status for process units with later compliance
dates
PUMPS IN LIGHT LIQUID SERVICE
page C-8I

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PUMPS, VALVES, CONNECTORS, AND AGITATORS
IN HEAVY LIQUID SERVICE, INSTRUMENTATION SYSTEMS;
AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60.
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts K and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method, unless repaired as discussed under "Repair
Requirements" below
Leak Definition
Monitoring
•	agitators - 10,000 ppm
•	pumps - 2,000 ppm
•	valves, connectors, pressure relief devices, instrumentation systems - 500 ppm
•	pumps in food/medical service - 2,000 ppm
•	pumps handling polymerizing monomers - 5,000 ppm
Other
•	evidence of potential leak by visual, audible, olfactory or other detection requirement
Alternative
Standards
Alternative means of emission limitation
Enclosed vented process units may enclose process units and operate under negative pressure while
venting all leaks from equipment through a closed vent system to a control device meeting the
requirements of this rule.
Batch processes may pressure test or monitor equipment for leaks
Exemptions
Equipment in vacuum service
Equipment operated fewer than 300 hours per year in organic HAP service
Monitoring
Method
Method 21, no more than 1 cm from rotating shaft
•	response factor criteria (excluding inerts) for average composition of process fluid
•	monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
For equipment that are not monitored (Method 21), repair shall mean that visual, olfactory or other
indications of a leak have been eliminated, no bubbles are observed at potential leak sites during lead
check with soap solution, or system will hold a test pressure
PUMPS, VALVES, CONNECTORS. AND AGITATORS IN HEAVY LIQUID SERVICE.
INSTRUMENTATION SYSTEMS. AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
page C-82

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PUMPS, VALVES, CONNECTORS, AND AGITATORS
IN HEAVY LIQUID SERVICE; INSTRUMENTATION SYSTEMS;
AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart VV
40 CFR Pan 61,
Subparts 3 and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB
ITEM
REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Valves, connectors and agitators
ฆ Allowed if emissions of purged material resulting from immediate repair would exceed fugitive
emissions from delay of repair and purged material is collected and destroyed or recovered in
compliant control device when repair is done
Valves
•	Delay beyond a process unit shutdown allowed if sufficiently stocked supplies of valve
assemblies have been depleted
•	Delay not allowed beyond the second process unit shutdown unless the third process unit
shutdown occurs sooner than 6 months after first process unit shutdown
Pumps
•	Allowed if repair requires replacing existing seal design with a new system that provides better
performance, dual mechanical seal system, meets requirements of ง63 163(0, or compliant
closed-vent system and control device, and repair is completed as soon as practicable but not
later than 6 months after leak detected
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired, except valves
•	ID may be removed from valve after it has been monitored at least once within first 3 months of
repair and no leak is detected
•	ID may be removed from connector after it has been repaired and monitored when reconnected
or within 3 months of repair and no leak is detected
(Continued on next page)
PUMPS VALVES, CONNECTORS, AND AGITATORS IN HEAVY LIQUID SERVICE,
INSTRUMENTATION SYSTEMS. AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
page C-83

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PUMPS, VALVES, CONNECTORS, AND AGITATORS
IN HEAVY LIQUID SERVICE; INSTRUMENTATION SYSTEMS;
AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Pan 63.
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
(continued)
Information to be kept in log for 2 years after leak detected
•	instrument and equipment ID number and operator name, initials, and ED number
•	date leak detected
•	dates of each attempt to repair leak
•	maximum instrument reading after successful repair or determination the equipment is
nonrepairable
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
Information to be kept for all equipment.
•	list of ID numbers of subject equipment (except instrumentation systems)
•	location of equipment on site plan, log entries, etc.
•	documentation and dates of visual inspections
•	ED of instrumentation systems; individual components need not be identified
•	Information, data, and analysis used to demonstrate that a piece of equipment or process unit is
in heavy liquid service
•	copies of periodic reports (if database not capable of generating)
Additional information to be kept for connectors'
•	identification of connectors, by area or grouping, with total number of connectors within each
group
•	ID of connectors opened or otherwise had the seal broken since the last monitoring period, and
dates and results of follow-up monitoring
PUMPS, VALVES. CONNECTORS, AND AGITATORS IN HEAVY LIQUID SERVICE,
INSTRUMENTATION SYSTEMS, AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
page C-84

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PUMPS, VALVES, CONNECTORS, AND AGITATORS
IN HEAVY LIQUID SERVICE; INSTRUMENTATION SYSTEMS;
AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification:
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of compliance status*
•	process unit identification
•	number of each type of equipment (excluding those in vacuum service)
•	method of compliance
Subsequent semiannual reports:
•	for each monitoring period, the facts that explain each delay of repair, and where appropriate,
why a process unit shutdown was technically infeasible
•	revisions to items reported in the initial Notification of Compliance Status if method of
compliance has changed since the last report
•	information listed in the Notification of Compliance Status for process units with later
compliance dates
PUMPS, VALVES, CONNECTORS, AND AGITATORS IN HEAVY LIQUID SERVICE,
INSTRUMENTATION SYSTEMS, AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
page C-85

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QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60.
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
ITEM
REQUIREMENTS
Applicability
A technology review of improvement QIP's are required in Phase HI if the greater of either 10% of
pumps in a process unit (or plant site) or 3 pumps in a process unit (or plant site) leak
Once < 10% or < 3 pumps leaking is achieved (6 month rolling average), comply with basic
standard
If leak rate again exceeds the greater of either > 10% or 3 pumps leaking, can use QIP again
Basic Standard
Comply with basic standard for pumps not in QIP
Collect the following data-
Pumps
•	type and manufacturer
•	seal type and manufacturer
•	pump design
•	materials of construction
•	year installed
•	barrier fluid or packing material
Service characteristics of the stream
•	discharge pressure, temperature, flow rate, corrosivity, annual operating hours
Maximum instrument readings before repair, response factor for stream, instrument number, and
date of observation
If leak is detected, repair methods used and the instrument readings after the repair
Inspect all pumps and pump seals that exhibit frequent failure and were removed from the process
unit due to leaks, determine probable cause of leaks and recommend changes to reduce leak potential
Continue to collect data as long as part of QIP
Data Analysis
Analyze data to determine the services, operating and maintenance procedures, and pumps and pump
seal designs or technologies that have poorer and those that have better than average performance,
the first analysis shall be completed no later than 18 months after the start of the program, shall use a
minimum of 6 months of data, and shall be done yearly for as long as the process unit is in the QIP
program The analysis shall determine if specific trouble areas can be identified
QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
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QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN UGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpan VV
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Performance Trial
Evaluation
Required for plants that have not demonstrated superior technologies
•	the number of pump seal technologies or pumps in the trial program shall be the lesser of 1 % or
2 pumps for programs involving single process units and the lesser of 1 % or 5 pumps for plant
sites or groups of process units, the minimum number of pumps or pump seal technologies in the
program shall be 1
•	the program shall specify and include design documentation, the evaluation stages, frequency of
monitoring, the range of operating conditions, and conclusions
The performance trials shall be conducted for a 6-month period beginning no later than 18 months
after the beginning of the QIP
Conclusions will be drawn no later than 24 months after the beginning of the QIP
Any plant site with fewer than 400 valves and owned by a company with fewer than 100 employees
exempt from trial evaluations Instead begin pump seal or pump replacement program at the start of
the fourth year of QIP.
Performance Test
Evaluation
Termination
Continue to conduct trials as long as no superior performing design or technology has been identified
or until there are no technically feasible alternatives as demonstrated through an engineering
evaluation Otherwise the facility may stop conducting performance tests after all alternative superior
emission performance technologies have been evaluated and a superior performing design or
technology has been demonstrated
Quality Assurance
Program
Establishes minimum design standards for each category of pumps or pump seal technology
Requires that all equipment orders specify the design standard for the pump or pump seal
Provides for an audit procedure for quality control of purchased equipment
Details off-line pump maintenance and repair procedures
Shall be established no later than start of third year of QIP for sites with 2400 valves or i 100
employees, by start of fourth year for others
Equipment
Replacement
Beginning at the start of the third year of the QIP for plants with 400 or more valves or 100 or more
employees and at the start of the fourth year for others, the owner/operator shall replace the pumps
and pump seals that are not superior emission performance technology with pumps or pump seals of
superior technology that comply with QA standards for the pump category
Pumps or pump seals shall be replaced at the rate of 20% per year based on the total number of
pumps m light liquid service (minimum of one) and shall continue to be replaced until all are
superior technology
QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
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QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Superior Emission
Performance
Technology
Category or design of pumps or pump seals that will result in < 10% leaking pumps in the process
unit of plant site
Includes material or design changes to the existing pump, pump seal, seal suppon system, installation
of multiple mechanical seals or equivalent, or pump replacement
Recordkeeping
Requirements
•	pump type, manufacturer, seal type and manufacturer, design, materials of construction (if
applicable), barrier fluid or packing material, and year installed
•	service characteristics of the stream, discharge pressure, temperature, flow rate, corrosivity, and
annual operating hours
•	maximum instrument readings before repair, response factor, instrument number, and date of
observation
•	if leak detected, the repair method used and the instrument reading after repair
•	if data analyzed as part of a larger analysis program; describe any maintenance or QIP intended
to improve emission performance
•	rolling average percent leaking pumps
•	documentation of all inspections and recommendations for design or specification changes to
reduce leak frequency
•	beginning and end dates while meeting requirements of the QIP
•	reason for any leak repair delay and expected date of successful repair
•	records of all analyses required under ง63.176(d), including:
•	• list identifying areas associated with poorer than average performance and associated
service characteristics of the stream, operating conditions, and maintenance procedures
•	• reasons for rejecting specific candidate superior emission performing pump technology from
performance trials
•	• list of candidate superior emission performing pump technologies and documentation of
performance trial program items required under 63 176(d)(6)(ui)
•	• beginning date and duration of performance trials for each candidate superior emission
performing technology
•	records documenting the quality assurance program, as specified in 63.176(d)(7)
•	records indicating all pumps replaced or modified are in compliance with the quality assurance
program
•	records documenting compliance with 20% or greater annual replacement rate for pumps
•	information and data showing company has fewer than 100 employees
Reporting
Requirements
Semiannual reports
• initiation of monthly monitoring under Phase m or QIP (if applicable)
QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
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QUALITY IMPROVEMENT PROGRAM FOR VALVES
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61.
40 CFR Pan 63,
40 CFR Part 264, Subpan BB
Subpan VV
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Applicability
Optional in Phase III to owners/operations with s 2% leakers
Decision required within first year of Phase III
If rolling average of percent leakers is < 2% for 2 consecutive quarters: 1) comply with QIP, 2)
comply with valve standard, or 3) comply with both QIP and valve standard
If continuing QIP, exempt from performance trial requirements or further progress as long as process
unit has <2% leaking valves
If not continuing QIP (l e., complying with valve standard) cannot use QIP again if leak rate goes
above 2%, monthly monitoring is required
If complying with both QIP and valve standard, owner/operator may use the following monitoring
frequencies-
•	if <2% leaking, then monitor once per quarter
•	if < 1 % leaking, then monitor once every 2 quarters
•	if <0 5% leaking, then once every 4 quarters
Demonstration of
Further Progress
Comply with valve standard except monitor quarterly
Collect data and maintain records as follows-
•	maximum instrument reading observed in each monitoring, response factor, model number, and
date of observation
•	classification of valve "gas or light liquid service"
•	repair method used and instrument readings after repair (monitoring required at least once within
the first 3 months after the repair is completed)(ID tag on a leaking valve may be removed after
the valve successfully passes this monitoring period)
Continue to collect data for as long as the process unit is in QIP
Demonstrate progress in reducing the percent leaking valves each quarter by at least
•	10 percent (meaning that each quarter there is at least a 10 percent reduction in the percent
leaking valves from the preceding monitoring period) or
•	determine required quarterly percent reduction and to less than 2% within 2 years
The provisions for failure to meet the 10% reduction for 2 consecutive rolling averages are
•	a choice of monthly monitoring, or
•	implementation of a QIP for technology review as specified in ง63 175(e)
QUALITY IMPROVEMENT PROGRAM FOR VALVES
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QUALITY IMPROVEMENT PROGRAM FOR VALVES
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265. Subpan BB
ITEM
REQUIREMENTS
Data Collection
(Technology
Review and
Improvement)
Data collection for as long as in QIP'
•	valve type and manufacturer, valve design, materials of construction, year installed, and packing
material
•	service characteristics of the stream (e.g., operating pressure, temperature, line diameter,
corrosivity)
•	gas/vapor or light liquid service
•	repair methods used and the instrument readings after the repair
•	maximum instrument reading before repair, response factor, model number, and date of
observation
•	description of use of any maintenance or quality assurance programs intended to improve
emissions
Inspect all valves removed due to leaks to determine cause of failure and recommend design and
other changes to reduce leak potential
Data Analysis
(Technology
Review and
Improvement)
Analyze data to determine the services, operating and maintenance procedures, and valve designs or
technologies that have poorer and those that have better than average performance to determine
specific trouble areas; the first analysis shall be completed no later than 18 months after the start of
the program, shall use a minimum of 6 months of data, shall be done yearly for as long as the
process unit is in the QIP program
Definition of
Superior
Performing Valve
Technology
Technology for valves having a leak frequency of <2% for specific applications in process unit
Candidate demonstrates or reports having low emission performance and capable of achieving <2%
leaking valves in process unit
Performance Test
Trial Evaluation
(Technology
Review and
Improvement)
Required for plants that have not demonstrated superior technologies
•	the number of valves in the trial program shall be the lesser of 1 % or 20 valves for programs
involving single process units and the lesser of 1 % or 50 valves for programs involving groups
of process units
•	the program shall specify and include design documentation, the evaluation stages, frequency of
monitoring, the range of operating conditions, and conclusions regarding performance and
operating conditions and services
Any plant sue with fewer than 400 valves and owned by a company with fewer than 100 employees
exempt from trial evaluations Instead begin program at the start of the fourth year of Phase HI
The performance trials shall be conducted for a 6-month period beginning no later than 18 months
after the beginning of the QIP
Conclusions will be drawn no later than 24 months after the beginning of the QIP
Performance test trials will continue as long as no superior design or technology is identified
QUALITY IMPROVEMENT PROGRAM FOR VALVES
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QUALITY IMPROVEMENT PROGRAM FOR VALVES
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subpans H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Quality Assurance
Plan
Program shall be established no later than the start of the third year of Phase III for plant sites with
>400 valves or 2100 employees, and no later than the start of the fourth year of Phase ID for plants
with < 400 valves and < 100 employees
Program shall be reviewed and updated (as appropriate) each year as long as the process unit has
22% leaking valves
Program shall
•	Establish minimum design standards for each category of valves
•	Require that all equipment orders specify the design standard
•	Include a written procedure for bench testing
•	Require that all valves repaired on-line be monitored for 2 successive months after repair
•	Provide for an audit procedure for quality control of purchased equipment
•	Detail off-line valve maintenance and repair procedures
Equipment
Replacement
(Technology
Review and
Improvement)
Beginning at the start of the third year of Phase III for plants with 400 or more valves or 100 or more
employees and at the start of the fourth year of Phase III for others, each replacement valve shall
meet quality assurance and superior emission performance technology standards
If superior emission performance technology cannot be identified, replacement valve shall be one
with lowest emission performance technologies identified for the specific application
Recordkeeping
Requirements
QIP.
•	reason for any leak repair delay and expected date of successful repair
•	records of all analyses required under ง63 175(e)
•	records documenting the quality assurance program
•	records indicating all valves replaced or modified are in compliance with the quality assurance
requirements
•	information and data showing company has fewer than 100 employees
Recordkeeping for
QIP-
Demonstration of
Reasonable
Further Progress
QIP - reasonable further progress.
•	owner or operator shall collect the following data and maintain records for each valve in each
process unit subject to the QIP
•	• maximum instrument reading before repair, response factor, instrument model number, and
date of observation
•	• whether valve is in gas or light liquid service
•	• if leak detected, the repair methods used and instrument reading after repair
•	percent leaking valves and rolling average percent reduction observed each quarter
•	beginning and end dates while meeting the requirements of the QIP
QUALITY IMPROVEMENT PROGRAM FOR VALVES
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QUALITY IMPROVEMENT PROGRAM FOR VALVES
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CPU Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping for
QIP - Technology
Review and
Improvement
QIP - technology review and improvement-
•	valve type, manufacturer, design, materials of construction, packing material, and year installed
•	service characteristics of the stream (e g. operating pressure, temperature, line diameter,
corrosivity)
•	whether valve is in gas/vapor or light liquid service
•	if leak detected, maximum instrument reading before repair, response factor, model number, and
date of observation
•	if leak detected, the repair method used and the instrument reading after repair
•	if data analyzed as part of a larger analysis program, describe any maintenance or QEP intended
to improve emission performance
•	percent leaking valves observed each quarter
•	documentation of all inspections and recommendations for design or specification changes to
reduce leak frequency
•	beginning and end dates while meeting requirements of the QEP of technology review and
improvement
Reporting
Requirements
Subsequent semiannual reports
• initiation of monthly monitoring under Phase III or QIP (if applicable)
QUALITY IMPROVEMENT PROGRAM FOR VALVES
page C-92

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SAMPLING CONNECTION SYSTEMS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subpans J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Equipped with closed-purge system or closed-vent system that returns the fluid to the process line,
recycles the purged fluid, sends it to a compliant control device, or collects, stores and transports it
to an appropriate facility
Gases displaced during filling of samples are not required to be collected or captured
Leak Definition
N/A
Alternative
Standards
Alternative means of emission limitation
Exemptions
Sampling systems in vacuum service
In-situ sampling systems and sampling systems without purges
Sampling systems in organic HAP service fewer than 300 hours per year
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept for all sampling connections
•	list of ID numbers of subject sampling connection systems
•	location of sampling system on site plan, log entries, etc
Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours/year
SAMPLING CONNECTION SYSTEMS
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SAMPLING CONNECTION SYSTEMS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpan BB
40 CFR Pan 265. Subpart BB
ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification:
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of Compliance Status:
•	process unit identification
•	number of sampling connection systems, excluding those in vacuum service
•	method of compliance
Subsequent semiannual reports
•	for each monitoring period during the 6 month period, the facts that explain any delay of repairs
and, where appropriate, why a process unit shutdown was infeasible
•	revisions to items reported in the initial notification of compliance status if the method of
compliance has changed since the last report
•	information listed under Notice of Compliance Status for process units with later compliance
dates
SAMPLING CONNECTION SYSTEMS
page C-94

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SURGE CONTROL VESSELS AND BOTTOM RECEIVERS
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Use of closed-vent system that routes the organic vapors either back to process or to compliant
control device
Comply with the requirements under ง63.119(b) for fixed roofs with internal floating roofs or under
ง63 119(c) for external floating roofs
Leak Definition
N/A
Alternative
Standards
Alternative means of emission limitation
Exemptions
Equipment in vacuum service
Equipment in organic HAP service fewer than 300 hours per year
Surge control vessels routed back to process
Surge control vessels that do not meet certain capacity and vapor pressure criteria, see Tables 2 and 3
of Subpart H
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept for all equipment"
•	list of ID numbers of subject equipment
•	location of equipment on site plan, log entries, etc
•	ID of surge control vessels or bottoms receivers equipped with a closed vent system or control
device
Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours/year
SURGE CONTROL VESSELS AND BOTTOM RECEIVERS
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SURGE CONTROL VESSELS AND BOTTOM RECEIVERS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Pan 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification-
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of Compliance Status:
•	process unit identification
•	number of each type of equipment, excluding those in vacuum service
•	method of compliance
Subsequent semiannual reports*
•	revisions to items reported in the Notification of Compliance Status if the method of compliance
has changed since the last report
•	Information listed in the Notice of Compliance Status for process units with later compliance
dates
SURGE CONTROL VESSELS AND BOTTOM RECEIVERS
page C-96

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VALVES IN GAS VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpan W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Basic Standard
Phase I & II- Monitor each valve quarterly
Phase III: Monitoring frequency based on percent valves found leaking
Percent Leaking Monitoring Freauencv
2% (or more) Monthly or QIP
<2% Quarterly
< 1 % Quarterly or once every 2 quarters
<0.5% Quarterly or once every 4 quarters
For existing sources
•	Phase I begins on compliance date
•	Phase II begins no later than 1 year after compliance date
•	Phase HI begins no later than 2 xh years after compliance date
For new sources:
•	Phase II begins after initial start-up
•	Phase III begins no later than 1 year after initial start-up
Leak Definition
Phase I 10,000 ppm
Phase II 500 ppm
Phase III: 500 ppm
Alternative
Standards
Alternative means of emission limitation
QIP for valves (Phase m)
Exemptions
Valves in vacuum service
Valves in organic HAP service fewer than 300 hours per year
Valves designated unsafe to monitor or difficult to monitor (at new facilities, maximum 3% of valves
may be designated as difficult to monitor)
Equipment located at plant sites with fewer than 250 valves is exempt from monthly monitoring,
instead monitor once per quarter or comply with percent leak requirements for <1% or 0.5%, as
applicable
Monitoring
Method
Method 21
•	response factor criteria (excluding mens) for average composition of process fluid
•	monitor all equipment while it is "in service"
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
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VALVES IN GAS VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Pan 265, Subpart BB
ITEM
REQUIREMENTS
Repair
Requirements
First anempt within 5 calendar days of detection
Repair as soon as practicable; no later than IS days after detection
When repaired, monitor at least once within first 3 months of repair
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs
Allowed beyond process unit shutdown if valve assembly replacement supplies are exhausted and had
been sufficiently stocked before supplies were depleted
Not allowed beyond second process unit shutdown unless third shutdown occurs sooner than 6 months
after first shutdown
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-98

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VALVES IN GAS VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
•	ID may be removed after it has been repaired and monitored at least once within first 3 months
of repair and no leak is detected
Information to be kept in log for 2 years after leak detected
•	instrument and equipment ID number and operator name, initials, or ED number
•	date leak detected
•	date of first attempt to repair leak
•	maximum instrument reading after successful repair or if determined to be nonrepayable
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
The owner or operator may develop and cite a written procedure that identifies conditions
justifying a delay of repair
•	documentation of sufficient supply of spare parts on-site before depletion and reason for
depletion if repair delayed because stocked parts were depleted
•	dates of process unit shutdown that occurred while the equipment is unrepaired
•	date of successful repair of the leak
•	copies of periodic reports (if database not capable of generating)
Information to be kept for all valves
•	list of ID numbers of subject valves
•	location of valve on-site plan, log entries, etc
•	schedule by process unit for monitoring valves
•	list of valves removed and added to a process unit after the compliance date if net credits for
their removal are expected to be used
Information to be kept for difficult to monitor valves
•	list of ID numbers
•	explanation for designation
•	planned schedule for monitoring
Information to be kept for unsafe to monitor valves.
•	identification of equipment designated as unsafe to monitor
•	plan for monitoring
Information and data used to demonstrate that a valve is not in organic HAP service, is in HAP
service fewer than 300 hours/year, or is in heavy liquid service
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-99

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VALVES IN GAS VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Initial notification:
•	name and address of owner/operator
•	address of facility
•	identification of subject processes
•	compliance statement
•	statement if a source can achieve compliance by applicable date
Notification of Compliance Status:
•	process unit identification
•	number of valves, excluding those m vacuum service
•	method of compliance
•	planned schedule for each phase
Subsequent semiannual reports:
•	the following information for each monitoring period in the reporting period-
•	• number of valves for which leaks were detected
•	• total number of valves monitored
•	• the percent leakers for valves
•	• number of valves for which leaks were not repaired within 15 days after detection
•	• identification of the number of valves determined to be nonrepairable
•	• explanation of why repairs delayed and why a process unit shutdown was infeasible
•	revisions to items reported in the initial compliance notice if the method of compliance has
changed since the last report
•	initiation of monthly monitoring under Phase HI or Q1P (if applicable)
•	information listed in the Notice of Compliance Status for process units with later compliance
dates
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-lOO

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Control devices and closed-vent systems to be operated at all times that emissions may be vented to
them
Each piece of equipment shall be marked in such a manner to distinguish it readily from other pieces
of equipment
Applies to equipment containing or contacting hazardous waste with minimum organic concentrations
of 10% by weight
Control Devices
•	vapor recovery systems 95 percent by weight or greater recovery unless total organic emission
limits of ง265 1032(a)(1) for all affected processes can be attained at an efficiency of less than 95
percent
•	carbon adsorbers' carbon replacement intervals specified
•	enclosed combustion devices (e g , vapor incinerator, boiler, or process heater): 95 percent or
greater reduction, 20 ppmv total organic compound concentration, or minimum residence time of
0 50 seconds at a minimum temperature of 760 ฐC, boilers and process heaters introduce vent
stream into flame combustion zone
•	flares basic requirements for visible emissions, heat content, exit velocities, and flare design,
flame present at all times
Closed-Vent Systems-
•	designed to operate with no detectable emissions, indicated by instrument reading of less than
500 ppmv above background and by visual inspections, or
•	designed to operate at a pressure below atmospheric pressure
Monitoring
•	Control devices:
•	• monitor to ensure operated and maintained in conformance with their designs
•	• specific requirements identified for vent stream flow monitors and other monitors for
specific types of control devices
•	Closed-vent systems
•	• initial leak detection monitoring to demonstrate that closed-vent system operates with no
detectable emissions (< 500 ppmv above background)
•	• initial inspection to be performed on or before the system is subject to regulation
•	• closed-vent system joints, seams or other connections that are permanently or semi-
permanently sealed shall be visually inspected at least once per year
•	• components shall be monitored after repair or replacement or after connection is unsealed
•	• closed-vent system components or connections (except those designated unsafe to monitor)
shall be monitored annually and at other times as requested by the Regional Administrator
Leak Definition
No detectable emissions (< 500 ppm above background)
Alternative
Standards
N/A
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I



40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
ITEM
REQUIREMENTS
Exemptions
Equipment which contains or contacts a hazardous waste of at least 10% by weight for a period of
fewer than 300 hours per year
Any components of a closed-vent system designated as unsafe to monitor are exempt from annual
monitoring if:
•	monitoring personnel would be exposed to an immediate danger, and
•	the owner or operator adheres to a written plan that requires monitoring as frequently as
practicable during safe to monitor times
Monitoring
Method
Method 21 (closed-vent systems)
Specified monitoring procedures for control devices
Repair
Requirements
First attempt to repair within 5 calendar days of detection
Repair as soon as practicable, no later than IS days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown or if emissions from immediate repair
would be greater than fugitive emissions from delay of repair, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste at least 10% by weight
Recordkeeping
Requirements
Information to be kept for each closed vent system and control device (information to be maintained
in facility's operating record)
•	equipment ID and hazardous waste management unit ID
•	approximate location within facility on facility plot plan
•	type of equipment
•	percent by weight total organics in hazardous waste stream
•	hazardous waste state at the closed-vent system and control device
•	method of compliance with the standard
•	implementation schedule for installation and operation of closed-vent system and control device if
unable to install and comply by the effective date of the rule
•	performance test plan if using test data to demonstrate the organic removal efficiency or total
organic compound concentration achieved by the closed-vent system and control device
including:
• • description of how the test will be conducted when the hazardous waste management unit is
operating at the highest load or capacity level reasonably expected to occur, including
estimated or design flow rate and organic content of each vent stream and definition of
acceptable operating ranges of key process and control parameters during the test program
(Continued on next page)
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-102

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
(continued)
•	• a detailed engineering description of the closed-vent system and control device including'
•	• • manufacturers name and model number
•	• • type of control device
•	• • dimensions of control device
•	• • capacity
•	• • construction materials
•	• a detailed description of sampling and monitoring procedures, including location in the
system, equipment used, sampling and monitoring frequency and planned analytical
procedures
•	documentation of compliance with standard including detailed design documentation or
performance test results specified in 264.1035(b)(4) and 265.1035(b)(4)
•	design documentation and operating, monitoring, and inspection information for each closed vent
system and control device as specified in 264 1035(c) and 265.1035(c); maintain for 3 years
•	for control devices other than thermal vapor incinerators, catalytic vapor incinerators, flares,
boilers, process heaters, condensers, or carbon adsorption systems, monitoring and inspection
information indicating proper operation and maintenance
•	list of ID numbers for the closed vent systems and control devices
•	list of ID numbers for equipment m vacuum service
•	identification, by list or location, of equipment that contains or contacts hazardous waste with an
organic concentration of at least 10% by weight for a period of less than 300 hours/year
Information to be kept for the purpose of determining exemptions
•	analysis determining the design capacity of the hazardous waste management unit
•	statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these are heavy liquids
•	up-to-date analysis and supporting information and data used to determine if equipment is subject
to the requirements of the rule including supporting documentation required by 264 1063(d)(3)
and 265 1063(d)(3) A new determination is required when the owner/operator takes any action
that could result in an increase in the total organic content of the waste contained in or contacted
by equipment previously determined not be subject
Information to be kept for unsafe to monitor closed-vent system and control device
•	identification of equipment designated as unsafe to monitor
•	explanation stating why the closed-vent system is unsafe to monitor
•	plan for monitoring
In addition
•	Part 264 - for "other" control devices - monitoring and inspection criteria indicating proper
operation and maintenance of the control device will be determined by the Regional
Administrator
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-103

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
APPLICABLE REGULATIONS
40 CFR Part 60.
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I



40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
REQUIREMENTS
Reporting
Requirements
Semiannual report requirements
•	Part 265
•	• None
•	Part 264 *
•	• the EPA ID number, name and address of the facility
•	• dates of hazardous waste management unit shutdowns that occurred within the semiannual
reporting period
•	• for each month during the semiannual reporting period, if any control device exceeded or
operated outside design specifications and was not corrected within 24 hours, report the
duration and cause of each exceedance, and any corrective measures taken
* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-104

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Equip with compliant seal system that includes a barrier fluid system that prevents leakage to
atmosphere
For each barrier fluid system:
•	operate the barrier fluid at a pressure (hat is at all times greater than the pump stuffing box
pressure, or
•	connect the barrier fluid degassing reservoir by a closed-vent system to a compliant control
device, or
•	equip with a system that purges the barrier fluid into a hazardous waste stream with no detectable
emissions to the atmosphere (less than 500 ppm above background)
The barner fluid system must not be a hazardous waste with organic concentrations 10% or greater
by weight
Install sensor to detect failure of seal system, barrier fluid system, or both
Check sensor daily or equip with audible alarm that is checked monthly; if at unmanned plant site,
check sensor daily
Establish criteria that indicates failure of seal system, barrier fluid system, or both
Leak Definition
Sensor indicates failure of seal system, barrier fluid system, or both based on established criteria
Alternative
Standards
N/A
Exemptions
Equipment designated for no detectable emissions (less than 500 ppm above background) (see No
Detectable Emissions)
Equipment in vacuum service
Equipment equipped with closed vent system and control device capable of capturing and transporting
leakage from the seal to a compliant control device (see Closed-vent Systems and Control Devices)
Monitoring
Method
Observation of sensor
Method 21 for no detectable emissions
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 calendar days after detection
COMPRESSORS
page C-105

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Delay of Repair
Allowed if technically mfeasible without hazardous waste management unit shutdown, required
before end of next waste management unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste at least 10% by weight
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number and
date leak was detected, attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in log for 3 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is 2 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	expected date of successful repair if leak is not repaired within the 15 days
ฆ date of successful repair of the leak
Information to be kept for all compressors
•	compressor ID number and hazardous waste management unit identification
•	approximate facility location
•	type of equipment
•	percent-by-weight of total organics in hazardous waste at the compressor
•	hazardous waste state at the compressor
•	method of compliance
•	list of ID numbers of subject compressors
•	list of ID numbers of compressors designated for no detectable emissions and signed by
owner/operator
•	for each compliance test for compressors designated for no detectable emissions
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for compressors in vacuum service
•	identification, by list or location, of equipment that contains or contacts hazardous waste with an
organic concentration of at least 10% by weight for a period of fewer than 300 hours per year
Information to be kept for barrier fluid and seal systems
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to criteria and reasons for change
(Continued on next page)
COMPRESSORS
page C-106

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COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart VV
40 CFR Pan 61,
Subparts J and V
40 CFR Part 63,
Subparts H and 1



40 CFR Pan 264, Subpart BB
40 CFR Pan 265, Subpart BB
ITEM
REQUIREMENTS
Recordkeeping
Requirements,
continued
Information to be kept for the purpose of determining exemptions
•	analysis determining the design capacity of the hazardous waste management unit
•	statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these are heavy liquids
•	up-to-date analysis and supporting information and data used to determine if equipment is subject
to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
and 265.1063(d)(3) A new determination is required when the owner/operator takes any action
that could result in an increase in the total organic content of the waste contained in or contacted
by equipment previously determined not be subject
Reporting
Requirements
Semiannual report requirements
•	Part 265
•	• None
•	Part 264 *
•	• the EPA ID number, name and address of the facility
•	• for each month during the semiannual reporting period
•	• • the ID number for each compressor for which a leak was not repaired as required
•	• • if control device for any compressor exceeded or operated outside of design
specification and was not corrected within 24 hours, report the duration and cause of
each exceedance, and any correction measures taken
•	• dates of hazardous waste management unit shutdowns that occurred within the semiannual
reporting period
* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required
COMPRESSORS
page C-107

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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I



40 CFR Pan 264, Subpart BB
40 CFR Pan 265, Subpart BB
ITEM
REQUIREMENTS
Basic Standard
For each dual mechanical seal system that includes a barrier fluid system:
•	operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
•	connect the barrier fluid degassing reservoir by a closed-vent system to a compliant control
device, or
•	equip with a system that purges the barrier fluid into a hazardous waste stream with no detectable
emissions to the atmosphere (Jess than 500 ppm above background)
The barrier fluid system must not be a hazardous waste with organic concentrations 10% or greater
by weight
Equip each barrier fluid system with a sensor that detects failure of the seal system, barrier fluid
system, or both
•	check each sensor daily or equip with audible alarm, check audible alarm monthly to ensure it is
working
Visually inspect weekly for indications of liquids dripping from the pump seals
Establish criteria, based on design and operating experience, that indicates failure of the seal system,
barrier fluid, or both
Applies as an alternative to pumps in light liquid service
Leak Definition
Indications of liquids dripping from the pump seal or sensor detection, based on failure criteria
Alternative
Standards
N/A
Exemptions
Designated for no detectable emissions (less than 500 ppm above background) and if no externally
actuated shaft penetrates pump housing and pump is tested for compliance initially, annually, and at
other times requested by Administrator (see No Detectable Emissions)
Equipped with closed-vent system capable of capturing and transporting leakage from the seal(s) to a
compliant control device (see Closed-vent Systems and Control Devices)
Monitoring
Method
Visual, sensor, criteria
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
DUAL MECHANICAL SEAL SYSTEM
page C-108

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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart VV
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpan BB




ITEM
REQUIREMENTS
Delay of Repair
If repair requires use of a dual mechanical seal that includes a barrier fluid system and repair is
completed as soon as practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Recordkeeping
Requirements
When leak detected:
•	a weather-proof and readily visible identification, marked with the equipment ID number and
date leak was detected, attached to the leaking equipment
•	ID may be removed after it has been repaired
Information to be kept in inspection log for 3 years after leak detected.
•	instrument ID; operator name, initials, or ID number, and equipment ED number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is _> 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
hazardous waste management shutdown
•	expected date of successful repair if leak is not repaired within the IS days
•	date of successful repair of the leak
Information to be kept for all dual mechanical seal systems.
•	list of ID numbers of dual mechanical seal systems
•	list of ID numbers designated for no detectable emissions and signed by owner/operator
•	for each compliance test for components designated for no detectable emissions-
•	• dates conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers of mechanical seal systems in vacuum service
•	equipment ID number and hazardous waste management unit ID
•	approximate facility location on facility plot
•	type of equipment
•	percent-by-weight of total orgamcs in hazardous waste at the equipment
•	hazardous waste state at the equipment
•	method of compliance
•	identification, by list or location, of equipment that contains or contacts hazardous waste with an
organic concentration of at least 10% by weight for a period of fewer than 300 hours per year
Information to be kept for barrier fluid and seal systems
•	design criteria for indicating failure
•	explanation for selected criteria
•	any changes to criteria and reasons for change
(Continued on next page)
DUAL MECHANICAL SEAL SYSTEM
page C-109

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DUAL MECHANICAL SEAL SYSTEM
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I



40 CFR Pan 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
REQUIREMENTS
Recordkeeping
Requirements,
continued
Information to be kept for the purpose of determining exemptions-
•	analysis determining the design capacity of the hazardous waste management unit
•	statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these are heavy liquids
•	up-to-date analysis and supporting information and data used to determine if equipment is subject
to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
and 265 1063(d)(3) A new determination is required when the owner/operator takes any action
that could result in an increase in the total organic content of the waste contained in or contacted
by equipment previously determined not to be subject
Reporting
Requirements
Semiannual report requirements:
•	Pan 265
•	• None
•	Part 264 *
•	• the EPA ID number, name, and address of the facility
•	• by month in the reporting period, dates of hazardous waste management unit shutdowns that
occurred
•	• ID number for any pump not repaired on time
* If, during the semiannual reporting period, leaks from valves, pumps and compressors are repaired
as required and the control device does not exceed or operate outside of the design specifications for
more than 24 hours, no report to the Regional Administrator is required.
DUAL MECHANICAL SEAL SYSTEM
page C-110

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NO DETECTABLE EMISSIONS
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Basic Standard
Has an instrument reading of less than 500 ppm above background as measured by the methods
specified in 264.1063(c) and 265.1063(c)
Test for compliance initially upon designation, annually, and as requested by the Regional
Administrator
Applies as an exemption to-
•	pumps (must have no externally actuated shaft penetrating the pump housing)
•	valves in gas/vapor service or in light liquid service(must have no external actuating mechanism
in contact with the hazardous waste stream)
•	compressors
Applies as basic standard for:
•	closed-vent systems
•	pressure relief devices in gas/vapor service
Leak Definition
< 500 ppm above background
Alternative
Standards
N/A
Exemptions
N/A
Monitoring
Method
Method 21
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
Information to be kept.
•	list of ID numbers of equipment designated for no detectable emission and signed by
owner/operator
•	for each compliance test for no detectable emissions:
•	• date conducted
•	• background level measured
•	• maximum instrument reading
NO DETECTABLE EMISSIONS
page C-l 11

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NO DETECTABLE EMISSIONS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Reporting
Requirements
Semiannual report requirements-
•	Part 265
•	• None
•	Part 264
•	• None specific to no detectable emissions
NO DETECTABLE EMISSIONS
page C-l 12

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OPEN-ENDED VALVES OR LINES
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpan BB
40 CFR Part 26S, Subpan BB




ITEM
REQUIREMENTS
Basic Standard
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve close valve on process fluid end prior to closing second valve
Double block and bleed system bleed lines may remain open during operations that require venting
the line between the block valves but comply with basic standard at all other times
Leak Definition
N/A
Alternative
Standards
N/A
Exemptions
Equipment in vacuum service
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
OPEN-ENDED VALVES OR LINES
page C-l 13

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OPEN-ENDED VALVES OR LINES
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I



40 CFR Part 264, Subpart BB
40 CFR Pan 265. Subpart BB
ITEM
REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all open-ended valves or lines-
•	equipment ID number and hazardous waste management unit identification
•	approximate facility location
•	type of equipment
•	percent-by-weight of total organics in hazardous waste at the valve
•	hazardous waste state at the valve
•	method of compliance
•	list of ED numbers of subject valves and lines
•	list of ID numbers of equipment in vacuum service
•	identification either by list or location of equipment that contains or contacts hazardous waste
with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per
year
Information to be kept for the purpose of determining exemptions:
•	analysis determining the design capacity of the hazardous waste management unit
•	statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these are heavy liquids
•	up-to-date analysis and supporting information and data used to determine if equipment is subject
to the requirements of the rule including supporting documentation required by 264 1063(d)(3)
and 265.1063(d)(3) A new determination is required when the owner/operator takes any action
that could result in an increase in the total organic content of the waste contained in or contacted
by equipment previously determined not to be subject
Reporting
Requirements
Semiannual report requirements.
•	Part 265:
•	• None
•	Part 264:
•	• None specific to open-ended valves or lines
OPEN-ENDED VALVES OR LINES
page C-114

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I



40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
REQUIREMENTS
Basic Standard
No detectable emissions (less than 500 ppm above background)
After each release return to no detectable emissions within 5 calendar days as indicated by monitoring
of the pressure relief device
Leak Definition
No detectable emissions (< 500 ppm above background)
Alternative
Standards
N/A
Exemptions
Pressure relief devices in vacuum service
Pressure relief device equipped with compliant closed-vent system and control device
Monitoring
Method
Method 21
Repair
Requirements
See basic standard
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next
management unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste by 10% weight
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-115

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60.
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts K and I



40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB
ITEM
REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all pressure relief devices-
•	pressure relief device ID number and hazardous waste management unit identification
•	approximate facility location
•	type of equipment
•	percent-by-weight of total organics in hazardous waste at the pressure relief device
•	hazardous waste state at the pressure relief device
•	method of compliance
•	list of ID numbers of subject pressure relief devices
•	list of ID numbers for pressure relief devices in gas/vapor service required to comply with "no
detectable emissions"
•	for each compliance test for pressure relief devices designated for no detectable emissions.
•	• date conducted
•	• background level measured
•	• maximum instrument reading
•	list of ID numbers for pressure relief devices in vacuum service
•	identification, either by list or location, of equipment that contains or contacts hazardous waste
with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per
year
The following information shall be recorded in a log that is kept m the facility operating record for
use in determining exemptions
•	analysis determining the design capacity of the hazardous waste management unit
•	statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these hazardous wastes are heavy liquids
•	up-to-date analysis and the supporting information and data used to determine whether or not
equipment is subject to the requirements of the rule including supporting documentation required
by 264.1063(d)(3) and 265 1063(d)(3) A new determination is required when the
owner/operator takes any action that could result in an increase in the total organic content of the
waste contained in or contacted by equipment previously determined not to be subject
requirements
Reporting
Requirements
Semiannual report requirements-
•	Part 265.
•	• None
•	Part 264 *
•	• the EPA ID number, name and address of the facility
•	• for each month during the semiannual reporting period.
•	• • if control device for any pressure release device exceeded or operated outside of
design specification and was not corrected within 24 hours, report the duration and
cause of each exceedance, and any correction measures taken.
•	• • dates of hazardous waste management unit shutdowns that occurred within the
semiannual reporting period
* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required
PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-116

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PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
SERVICE, AND FLANGES AND OTHER CONNECTORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Part 61,
40 CFR Pan 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method
Leak Definition
10,000 ppm
Alternative
Standards
N/A
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without hazardous waste management unit shutdown, required
before end of next hazardous waste management unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste of at least 10% by weight
Valves:
•	Allowed if emissions of purged material from immediate repair would exceed fugitive emissions
from delay of repair, and purged materials are collected and destroyed or recovered in a
compliant control device when repair occurs
•	Allowed beyond process unit shutdown if valve assembly replacement is necessary and otherwise
sufficient supply of valve assembly replacements is exhausted
•	Not allowed beyond next shutdown unless next unit shutdown occurs sooner than 6 months after
first unit shutdown
Pumps
•	Repair requires use of dual mechanical seal system that includes barrier fluid and repair
completed as soon as practicable but no later than 6 months after leak detected
PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
LIQUID OR HEAVY LIQUID SERVICE. AND FLANGES AND OTHER CONNECTORS	page C-117

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PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
SERVICE, AND FLANGES AND OTHER CONNECTORS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61.
40 CFR Part 63,
40 CFR Pan 264, Subpart BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number, date
evidence of a potential leak found, and date leak detected, attached to the leaking equipment
Information to be kept in log for 3 years after leak detected
•	instrument and operator ID numbers and equipment ID number
•	date evidence of potential leak found
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is i 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	documentation supporting delay of repair of a valve
•	expected date of successful repair if leak is not repaired within IS days
•	date of successful repair of the leak
Information to be kept for all equipment
•	equipment ID number and hazardous waste management unit identification
•	approximate facility location
•	type of equipment
•	percent-by-weight of total organics m hazardous waste at the equipment
•	hazardous waste state at the equipment
•	method of compliance
•	list of ID numbers of subject equipment
•	list of ID numbers for equipment m vacuum service
•	identification, either by list or location, of equipment that contains or contacts hazardous waste
with an organic content of at least 10% by weight for a period of less than 300 hours per year
Information to be kept for the purpose of determining exemptions-
•	analysis determining the design capacity of the hazardous waste management unit
•	statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these are heavy liquids
•	up to date analysis and supporting information and data used to determine if equipment is subject
to the requirements of the rule including supporting documentation required by 264 1063(d)(3)
and 265 1063(d)(3) A new determination is required when the owner/operator takes any action
that could result in an increase m the total organic content of the waste contained in or contacted
by equipment previously determined not to be subject
PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS	page C-l 18

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PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
SERVICE, AND FLANGES AND OTHER CONNECTORS
APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I



40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
REQUIREMENTS
Reporting
Requirements
Semiannual report requirements-
•	Part 265
•	• None
•	Part 264 *
•	• the EPA ID number, name, and address of the facility
•	• dates of hazardous waste management unit shutdowns that occurred within the semiannual
period
* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS	page C-l 19

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Basic Standard
Non-dual mechanical seal pumps Monitor monthly and conduct weekly visual inspections for
indications of liquids dripping from pump seal
Leak Definition
10,000 ppm
Indications of liquids dripping from pump seal
Alternative
Standards
No externally actuated shaft penetrating pump housing
Operate with no detectable emissions
Test for compliance upon designation, annually, and when requested by Regional Admimscrator
Exemptions
Pumps m vacuum service
Any pump equipped with a compliant closed-vent system and control device
Any pump equipped with a dual mechanical seal: specific operating and design requirements (see
Dual Mechanical Seal System)
Any pumps designated for no detectable emissions (less than 500 ppm above background) (see No
Detectable Emissions)
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without hazardous work management unit shutdown, required before
end of next hazardous waste management unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste at least 10% by weight
Allowed if repair requires use of a dual mechanical seal system that includes a barrier fluid system
and repair is completed as soon as practicable, but not later than 6 months after leak detected
PUMPS IN LIGHT LIQUID SERVICE
page C-120

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Part 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Recordkeeping
When leak detected.
Requirements
•
a weather-proof and readily visible identification, marked with the equipment ID number and


date leak detected, attached to the leaking equipment

•
ID may be removed after it has been repaired

Information to be kept in log for 3 years after leak detected

+
instrument ID, operator ID, and equipment ID numbers


date leak detected

•
dates of each attempt to repair leak

•
repair methods applied in each attempt to repair

•
"above 10,000" if maximum instrument reading after each repair attempt is >. 10,000 ppm

•
"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection

•
signature of owner/operator whose decision it was that repair could not be effected without a


process shutdown

•
expected date of successful repair if leak is not repaired within the 15 days

•
date of successful repair of the leak

Information to be kept for all pumps.

•
pump ID number and hazardous waste management unit identification

•
approximate facility location

•
type of equipment

•
percent-by-weight of total organics in hazardous waste at the pump

•
hazardous waste state at the pump

•
method of compliance

•
list of ID numbers of subject pumps

•
list of ID numbers of pumps designated for no detectable emissions and signed by


owner/operator

•
for each compliance test for pumps designated for no detectable emissions


• • date conducted


• • background level measured


• • maximum instrument reading

•
list of ED numbers for pumps in vacuum service

•
identification, either by list or location, of equipment that contains or contacts hazardous waste


with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per


year

Information to be kept for pumps equipped with dual mechanical seal

•
design criteria for indicating failure

•
explanation for selected criteria

•
any changes io the criteria, and reason for change
PUMPS IN LIGHT LIQUID SERVICE
page C-121

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PUMPS IN LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Pan 61,
40 CFR Part 63.
40 CFR Part 264. Subpart BB
Subpart W
Subparts J and V
Subparts H and 1
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements,
continued
The following information shall be recorded in a log that is kept in the facility operattng record for
use in determining exemptions
•	an analysis determining the design capacity of the hazardous waste management unit
•	a statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these hazardous wastes are heavy liquids
•	an up-to-date analysis and the supporting information and data used to determine whether or not
equipment is subject to the requirements of the rule including supporting documentation required
by 264 1063(d)(3) and 265 1063(d)(3) A new determination is required when the
owner/operator takes any action that could result in an increase in the total organic content of the
waste contained in or contacted by equipment previously determined not to be subject.
Reporting
Requirements
Semiannual report requirements.
•	Part 265.
•	None
•	Part 264 *
•	• the EPA ID number, name and address of the facility
•	• for each month during the semiannual reporting period:
•	• • the ID number for each pump for which a leak was not repaired as required
•	• • if control device for any pump exceeded or operated outside of design specification
and was not corrected within 24 hours, report the date, duration and cause of each
exceedance, and any correction measures taken
•	• • dates of hazardous waste management unit shutdowns that occurred within the
semiannual reporting period
* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required
PUMPS IN LIGHT LIQUID SERVICE
page C-122

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SAMPLING CONNECTION SYSTEMS
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB




ITEM
REQUIREMENTS
Basic Standard
Equipped with closed-purge closed vent loop system or closed-vent system that returns the fluid to the
process, recycles the purged fluid to a compliant waste management unit, or sends it to a compliant
control devtce
Leak Definition
N/A
Alternative
Standards
N/A
Exemptions
Equipment in vacuum service
In-situ sampling systems
Sampling systems without purges
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
SAMPLING CONNECTION SYSTEMS
page C-123

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SAMPLING CONNECTION SYSTEMS
APPLICABLE REGULATIONS
40 CFR Pan 60,
40 CFR Pan 61,
40 CFR Pan 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subpans J and V
Subpans H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all sampling connections:
•	sampling connection system ID number and hazardous waste management unit identification
•	approximate facility location
•	type of equipment
•	percent-by-weight of total organics in hazardous waste at the sampling connection system
•	hazardous wastes state at the sampling connection system
•	method of compliance
•	list of ID numbers of sampling connection systems subject to the rule
•	list of ID number of equipment in vacuum service
•	identification, either by list or location, of equipment that contains or contacts hazardous waste
with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per
year
Information to be kept for the purpose of determining exemptions:
•	analysis determining the design capacity of the hazardous waste management unit
•	statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these are heavy liquids
•	up-to-date analysis and supporting information and data used to determine if equipment is subject
to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
and 265.1063(d)(3) A new determination is required when the owner/operator takes any action
that could result in an increase in the total organic content of the waste contained in or contacted
by equipment and control devices previously determined not to be subject
Reporting
Requirements
Semiannual report requirements:
•	Part 265.
•• None
•	Part 264 *
•	• the EPA ID number, name and address of the facility
•	• for each month during the semiannual reporting period
•	• • if control device for any sampling connection system operated outside of design
specification and was not corrected within 24 hours, report the duration and cause of
each exceedance, and any correction measures taken
•	• • dates of hazardous waste management unit shutdowns that occurred within the
semiannual reporting period
* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required
SAMPLING CONNECTION SYSTEMS
page C-124

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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60,
Subpart VV
40 CFR Pan 61,
Subparts J and V
40 CFR Pan 63,
Subparts H and I



40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
REQUIREMENTS
Basic Standard
Monthly monitoring
If valve does not leak for 2 consecutive months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
Leak Definition
10,000 ppm
Alternative
Standards
Allowable percentage of valves leaking or skip period leak detection and repair
Exemptions
Valves in vacuum service
Valves designated for no detectable emissions (less than 500 ppm above background) (see No
Detectable Emissions)
No external activating mechanism in contact with hazardous waste stream, is tested for compliance
annually, initially, and as requested by the Regional Administrator
Valves designated unsafe to monitor owner/operator follows with plan to monitor as frequently as
practicable during safe to monitor times
Valves designated as difficult to monitor at hazardous waste management units in operation prior to
June 21, 1990, and owner/operator follows written plan that requires monitoring of valves at least
once per calendar year
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection
Repair as soon as practicable, no later than 15 days after detection
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-125

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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Pan 60.
40 CFR Pan 61,
40 CFR Part 63,
40 CFR Pan 264, Subpan BB
Subpart W
Subparts J and V
Subparts H and I
40 CFR Pan 265, Subpan BB




ITEM
REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without process unit shutdown, required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste at least 10% by weight
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a compliant control
device when repair occurs
Allowed beyond process unit shutdown if valve assembly replacement is necessary and otherwise
sufficient supply of valve assembly replacements is exhausted
Not allowed beyond next unit shutdown unless next unit shutdown occurs sooner than 6 months after
first unit shutdown
Recordkeeping
Requirements
When leak detected
•	a weather-proof and readily visible identification, marked with the equipment ID number and
date leak detected, attached to the leaking equipment
•	ID may be removed after it has been repaired and monitored for 2 successive months with no
leaks detected during those two months
Information to be kept in log for 3 years after leak detected.
•	instrument and operator ED numbers and equipment ID number
•	date leak detected
•	dates of each attempt to repair leak
•	repair methods applied in each attempt to repair
•	"above 10,000" if maximum instrument reading after each repair attempt is .>_ 10,000 ppm
•	"repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
•	signature of owner/operator whose decision it was that repair could not be effected without a
process shutdown
•	documentation supporting delay of repair
•	expected date of successful repair if leak is not repaired within the IS days
•	date of successful repair of the leak
Information to be kept for all valves"
•	valve ID number and hazardous waste management unit identification
•	approximate facility location
•	type of equipment
•	percent-by-weight of total organics in hazardous waste at the valve
•	hazardous waste state at the valve
•	method of compliance
•	list of ID numbers of subject valves
•	list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
•	for each compliance test for valves designated for no detectable emissions:
•	• date conducted
•	• background level measured
•	• maximum instrument reading
(Continued on next page)
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-126

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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
APPLICABLE REGULATIONS
40 CFR Part 60,
40 CFR Part 61.
40 CFR Part 63,
40 CFR Part 264, Subpart BB
Subpart W
Subparts i and V
Subparts H and I
40 CFR Part 265, Subpart BB




ITEM
REQUIREMENTS
Recordkeeping
Requirements,
continued
•	list of ID numbers for valves in vacuum service
•	identification, either by list or location, of equipment that contains or contacts hazardous waste
with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per
year
Information to be kept for unsafe or difficult to monitor valves-
•	list of ID numbers
•	explanation for designation
•	planned schedule for monitoring
Information to be kept for valves complying with the skip leak detection and repair alternative
standards'
•	schedule of monitoring
•	percent of valves found leaking during each monitoring period
Information to be kept for the purposes of determining exemptions
•	analysis determining the design capacity of the hazardous waste management unit
•	statement listing the hazardous waste influent to and effluent from each hazardous waste
management unit and an analysis determining whether these are heavy liquids
•	up-to-date analysis and supporting information and data used to determine if equipment is subject
to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
and 265.1063(d)(3) A new determination is required when the owner/operator takes any action
that could result in an increase in the total organic content of the waste contained in or contacted
by equipment previously determined not to be subject
Reporting
Requirements
Semiannual report requirements
•	Part 265.
•	• None
•	Part 264 *
•	• the EPA ID number, name and address of the facility
•	• for each month during the semiannual reporting period-
•	• • the ID number for each valve for which a leak was not repaired as required
•	• • dates of hazardous waste management unit shutdowns that occurred within the
semiannual reporting period
* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-127

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THIS PAGE INTENTIONALLY LEFT BLANK
VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE	page C-128

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APPENDIX D
REGULATED EQUIPMENT1
'Source: Handbook: Control Techniques for Fugitive VOC Emissions from Chemical Process
Facilities, Chapter 3, EPA/625/R-93/005, Office of Research and Development, Cincinnati, OH,
45268, March 1994.

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Chapter 3
Regulated Equipment
Equipment leak standards are designed to control
emissions of VOCs and VHAPs from regulated
equipment through the application of work practices
and equipment practices The work practice most
commonly applied to control equipment leaks is the
LDAR program, which is discussed in detail in
Section 2 2 4 2 Subsequent chapters address the
monitonng, recordkeeping, and reporting
requirements of implementing a LDAR program
under NSPS or NESHAP standards In this chapter,
regulated equipment is reviewed to illustrate how
monitonng programs are applied to specific pieces
of equipment
action, and special canned-motor and diaphragm
pumps (U S EPA, 1990)
Chemicals transferred by pumps can leak at the
point of contact between the moving shaft and
stationary casing To isolate the pump's interior from
the atmosphere, all pumps, except the seal-less
type (canned-motor and diaphragm), require a seal
at the point where the shaft penetrates the housing
The most commonly used seals in these pumps are
packed and mechanical (U S EPA, 1980a)
Equipment practices include the use of specific
types of components, equipment design standards
or specifications, and operational standards for
certain types of equipment Equipment practices are
evaluated using performance standards that provide
a basis for monitonng or substantiating the
effectiveness of such control practices Equipment
practices, bnefly summarized in Section 2 2.4 3, are
addressed in greater detail in this chapter.
A general set of equipment is covered by all of the
equipment leak standards Some equipment is
covered only by specific standards For example,
product accumulator vessels are covered only by
the equipment leak standards for benzene Also, the
vinyl chlonde fugitive emission standards cover
additional sources (loading and unloading lines,
agitators, slip gauges, opening of equipment, and in-
process wastewater) Except for agitators, however,
the emissions from these sources generally are not
considered "equipment leaks " The equipment leak
standards also identify requirements for closed-vent
systems and control devices that may be used to
comply with the regulations
3.1 Pumps
Pumps are used extensively in the SOCMI and
petroleum refinery industnes, as well as in natural
gas processing plants, for moving organic fluids
The most widely used pump is the centrifugal pump
Other types of pumps that also may be used are the
positive-displacement, reciprocating and rotary
Pump stuffing box
gland
\
Fluid
Figure 3-1. Diagram of simple packed seal (U.S. EPA, 1980b).
3.1.1 Packed Seals
Packed seals can be used on both reciprocating and
rotary acton pumps. A packed seal consists of a
cavity ("stuffing box") in the pump casing filled with
special packing matenal that is compressed with a
packing gland to form a seal around the shaft A
simple packed seal is illustrated in Figure 3-1 To
prevent buildup of fnctional heat, lubncation is
required A sufficient amount of liquid (either the
liquid being pumped or another liquid that is
injected) must be allowed to flow between the
packing and the shaft to provide the necessary
lubncation If this packing and/or the shaft seal face
degrade after a period of usage, organic compounds
can leak to the atmosphere
REGULATED EQUIPMENT
page D-1

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3.1.2 Single Mechanical Seals
Mechanical seals, limited in application to pumps
with rotating shafts, can be single or dual Basic
designs of mechanical seals vary, but all have a
lapped seal face between a stationary element and
a rotating seal nng (Ramsden, 1978) In a single
mechanical seal application, the rotating-seal nng
and stationary element faces are lapped to a very
high degree of flatness to maintain contact over their
shared surface area (Figure 3-2) The faces are held
together by a combination of pressure supplied by a
spring and the pump pressure transmitted through
the liquid that is being pumped An elastomer seals
the rotating face to the shaft The stationary face is
sealed to the stuffing box with another elastomer or
gasket As with packed seals, the faces must be
lubncated however, because of the mechanical
seal's construction, much less lubncaton is needed
Again, if the seal becomes imperfect because of
wear, the organic compounds being pumped can
leak between the seal faces and can be emitted to
the atmosphere
insert padang
Stannary
^element
RuxJ
leek
Soring Shan
packing
Seal lace
Rotating
seal nng
Figure 3-2. Diagram of basic single mechanical seal (U.S.
EPA, 1980b)
3.1.3 Dual Mechanical Seals
Dual mechanical seals (Figure 3-3) can be arranged
back to back, in tandem, or face to face In the back-
to-back arrangement, the two seals form a closed
cavity A banner fluid, such as water or seal oil, is
circulated through the cavity Because the barrier
fluid surrounds the dual seal and (ubncates both
sets of seal faces, the heat transfer and seal life
charactensbcs of this dual seal are much better than
those of the single seal In order for the seal to
function, the barrier fluid must be at a pressure
greater than the operating pressure of the stuffing
box As a result, some bamer fluid will leak across
the seal faces. Liquid leaking across the inboard
face will enter the stuffing box and mix with the
process liquid Barner fluid going across the
outboard face will exit to the atmosphere. Therefore,
the barner fluid must be compatible with the process
liquid and wrth the environment (Ramsden, 1978, p
99)
Seailqud Sซai tamo
m (bottom)
Gland
plate
FHad
Primary
seal
Seconday
seal
Back-to-Back Arrangement
Seal liquid
Out In
(top) (bottom)
Glartd
'plate
Primary seal	Secondary seal
Tandem Arrangement
Figure 3-3. Typical arrangements of dual mechanical
pump seals (U.S. EPA, 1984).
REGULATED EQUIPMENT
page D-2

-------
In a tandem dual mechanical seal arrangement, the
seals face the same direction, and the secondary
seal provides a backup for the primary seal A seal
flush is used in the stuffing box to remove the heat
generated by friction As with the back-to-back seal
arrangement, the cavity between the two tandem
seals is filled with a barner fluid The barrier fluid,
however, is at a pressure lower than that in the
stuffing box Therefore, any leakage will be from the
stuffing box into the seal cavity containing the barner
fluid Since this liquid is routed to a closed reservoir,
process liquid that leaks into the seal cavity also will
be transferred to the reservoir At the reservoir, the
process liquid could vaporize and be emitted to the
atmosphere To ensure that VOCs or VHAPs do not
leak from the reservoir, the reservoir can be vented
to a control device
seals are eliminated Because the process liquid is
the bearing lubricant, abrasive solids cannot be
tolerated Canned-motor pumps are used widely for
handling organic solvents, organic heat transfer
liquids, light oils, and many toxic or hazardous
liquids Canned-motor pumps also are used when
leakage is an economic problem (Perry and Chilton,
1978, p 6-8)
Diaphragm pumps (Figure 3-5) perform similarly to
piston and plunger pumps The driving member,
however, is a flexible diaphragm fabncated of metal,
rubber, or plastic The primary advantage of this
arrangement is that no packing and shaft seals are
exposed to the process liquid, which is an important
asset when handling hazardous or toxic liquids
Another arrangement of dual seals is face to face In
this configuration, two rotating faces are mated with
a common stationary barrier Barner fluid may be
provided at higher or lower pressures than in the
stuffing box As in the tandem arrangement, if the
barner fluid is at a lower pressure than in the stuffing
box, the barner fluid reservoir may require venting to
a control device
3.1.4 Seal-less Pumps
The seal-less pump includes canned-motor and
diaphragm pumps In canned-motor pumps (Figure
3-4), the cavity housing, the motor rotor, and the
pump casing are interconnected As a result, the
motor beanngs run in the process liquid and all shaft
Discharge
Cootwit areuia&ng tube
Smorbnar
.X
Suction
A
Impeller
Diaphragm
Figure 3-4
Diagram of seal-less canned-motor pump (U.S.
EPA, 1990, P. 2-11).
Figure 3-5. Diagram of diaphragm pump (U S EPA, 1990,
p. 2-13).
3.2 Compressors
In the industnes affected by these standards,
centnfugal, reciprocating, and rotary compressors
are used The centnfugal compressor uses a
rotating element or senes of elements containing
curved blades to increase the pressure of a gas by
centnfugal force Reciprocating and rotary
compressors increase pressure by confining the gas
REGULATED EQUIPMENT
page D-3

-------
Pert may m adaป4
far eeewengmg or
inw>gisaBttotg
Rimmnn
internal
gas pressure
uswammm
Atmosphere
Labyrinth Seal
Port may be
added for
sealing
Sf/ss,
wmmw	i . ฆฆฆ .// VVv
Internal
A&nQIphere
ML '///. I ' ^NWN YS/Y// js.W^C
pressure
^ I sjssr s 35< ? 1ST
y • V SJ 'ฆ• •'/ ฆ V" * , s>\.WV
/. n. Z \~Ld x v j
M-sSNsNV^
Restrictive Ring Seal

Clean oil in
Contaminated
oil out
nternal
pressure
CoKTanrrnated
oil out
Oil out
Single Mechanical Seal
Liquid Film Seal
Figure 3-6. Typical designs of mechanical compressor seals (Ramsden, 1978, p.99)
REGULATED EQUIPMENT	page D-4

-------
in a cavity and progressively decreasing the volume
of the cavity Reciprocating compressors usually use
a piston and cylinder arrangement, while rotary
compressors use rotating elements such as lobed
impellers or sliding vanes
As with pumps, seals are required to prevent
leakage from compressors Rotary shaft seals for
compressors may be labynnth, restnctive carbon
nngs, mechanical contact, or liquid film Figure 3-6
is an illustration of typical designs of these four
types of seals All of these seals are leak restriction
devices, but none of them completely eliminates
leakage To respond to leakage, many compressors
are equipped with ports in the seal area that
evacuate collected gases
3.2.1	Labyrinth
The labynnth seal is composed of a senes of close
tolerance, interlocking "teeth" that restrict the flow of
gas along the shaft Many vanations in "tooth"
design and materials of construction are available
Although labynnth seals as a group have the largest
leak potential of the different types, properly applied
variations in tooth configuration and shape can
reduce leakage by up to 40 percent over a straight-
pass-type labynnth (Nelson, 1977)
3.2.2	Carbon Rings
Restrictive carbon ring seals consist of multiple
stationary carbon nngs with close shaft clearances
These seals may be operated dry with a sealing fluid
or with a buffer gas Restnctive ring seals can
achieve lower leak rates than can the labynnth type
3.2.3	Mechanical
Mechanical contact seals are a common type of seal
for rotary compressor shafts and are similar to the
mechanical seals descnbed for pumps In this type
of seal, the clearance between the rotating and
stationary elements is reduced to zero, and oil or
another suitable lubncant is supplied to the seal
faces Mechanical seals can achieve the lowest leak
rates of the types discussed here, but they are not
suitable for all processing
3.2.4	Packed
Packed seals are used for reciprocating compressor
shafts As with pumps, the packing in me stuffing
box is compressed with a gland to form a seal
Packing used on reciprocating compressor shafts is
often of the "chevron" or netted V type To ensure
operating safety, the area between the compressor
seals and the compressor motor (distance piece)
normally is enclosed and vented outside of the
compressor building If hydrogen sulfide is present
in the gas, then the vented vapors are flared
normally
Reciprocating compressors can use a metallic
packing plate and nonmetallic partially compressible
material (i e , Graffoil, Teflon) or oil wiper nngs to
seal shaft leakage to the distance piece
Nevertheless, some leakage into the distance piece
may occur
3.2.5 Liquid Film Seals
In addition to having seal types like those used for
pumps, centnfugal compressors can be equipped
with a liquid-film seal The seal is a film oil that flows
between the rotating shaft and the stationary gland
The oil that leaves the compressor from the
pressurized system side is under the system
internal gas pressure and is contaminated with the
gas When this contaminated oil is returned to the
open oil reservoir, process gas and entrained VOCs
and VHAPs can be released to the atmosphere
3.3 Pressure Relief Devices
Engineering codes require the use of pressure-
relieving devices or systems in applications where
lean ana
Disc
Figure 3-7.
Diagram of a spring-loaded relief valve (U S
EPA, 1990, p 2-16)
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the process pressure may exceed the maximum
allowable working pressure of the vessel The
pressure relief valve is the most common type of
pressure-relieving device used Typically, relief
valves are spring-loaded (see Figure 3-7) and
designed to open when the system pressure
exceeds a set pressure, allowing the release of
vapors or liquids until the system pressure is
reduced to its normal operating level When the
normal pressure is re-attatned, the valve reseats,
and a seal is again formed The seal is a disc on a
seat, and a leak through this seal is a potential
source of VOC and VHAP fugitive emissions The
potential causes of leakage from relief valves are
"simmenng or popping" (a condition that occurs
when the system pressure comes close to the set
pressure of the valve), improper reseating of the
valve after a relieving operation, and corrosion or
degradation of the valve seat (U S EPA, 1980a, p.
3-3)
Rupture discs also may be used to relieve pressure
in process units (see Figure 3-8) These discs are
made of a material that ruptures when a set
pressure is exceeded, thus allowing the system to
depressunze The advantage of a rupture disc is
that the disc seals tightly and does not allow any
Tunign xipuiuimw
Disc
To
Atmospheric
vent
Seat
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ฑ2H	c>:
^ SiS!*0*6 ฆ r
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Rupture disc
t— I V
VOC or VHAP to escape from the system dunng
normal operations When the disc ruptures,
however, the system will depressunze until
atmospheric conditions are obtained, unless the
disc is used with a pressure relief valve
3.4 Sampling Connections
Process unit operations are checked periodically by
routine analysis of feedstocks and products To
obtain representative samples for these analyses,
sampling lines first must be purged If the flushing
liquid is not controlled, it could be drained onto the
ground or into a process drain where it would
evaporate and release VOCs or VHAPs to the
atmosphere Closed-loop sampling systems control
the purged process fluid by returning it directly to
the process line, collecting and recycling the fluid, or
transporting the fluid to a control device These
sampling system controls typically allow zero VOC
or VHAP emissions to the atmosphere Two closed-
loop sampling systems are illustrated in Figure 3-9
-c2o-
Process line
u
I
t
Process line
Sample
container
From system
Figure 3-8. Typical design of a pressure relief valve
mounted on a rupture disc device (Ramsden,
1978, p.99)
Sample
container
Figure 3-9. Diagram of two closed-loop sampling systems
(Ramsden, 1978, p. 99).
3.5 Open-ended Lines or Open Valves
Some valves are installed in a system so that they
function with the downstream line open to the
atmosphere Open-ended lines, which are used
mainly in intermittent service for sampling and
venting, include purge, drain, and sampling lines
Some open-ended lines are needed to preserve
product punty Normally, these are installed
between mult-use product lines to prevent products
from collecting in cross-tie lines dunng valve seat
leakage A faulty valve seat or incompletely closed
valve would result in leakage through the valve,
releasing fugitive VOC or VHAP emissions to the
atmosphere
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Operational requirements specify that open-ended
valves or lines be equipped with a cap, blind flange,
plug, or second valve The purpose of the cap, blind
flange, plug, or second valve is to seal the open end
at all times, except during operations requiring
process fluid flow through the open-ended valve or
line
If a second valve is used, the open-ended line or
valve ts to be operated so that the valve on the
process fluid end is closed before the second valve
is closed If a double block-and-bleed system is
being used, the bleed valve or line may remain open
during operations that require venting the line
between the block valves At all other times, the
open end of the bleed valve or line must be sealed
(agam, except during operations requinng process
fluid flow through the open-ended line or valve)
Handwheel
Packing
nut

3.6 Process Valves
One of the most common pieces of equipment
affected by these standards is the process valve
Commonly used types are control, globe, gate, plug,
ball, relief, and check valves (see Figures 3-10 and
3-11) All except the relief valve (see Section 3 3)
and check valve are activated through a valve stem,
which may have either a rotational or linear motion,
depending on the design The valve stem requires
a seat to isolate the process flurd inside the valve
from the atmosphere The possibility of a leak
through this seal makes it a potential source of
fugitive emissions Since a check valve has no stem
or subsequent packing gland, it is not considered a
potential source of fugitive emissions
Body
Disc
Seat
Figure 3-10. Diagram of a globe valve
with a packed seal (U.S.
EPA, 1980b).
The stem can be sealed to prevent leakage by using
a packing gland or O-nng seals Valves that require
the stem to move in and out with or without rotation
must use a packing gland Conventional packing
glands are suited for a wide variety of packing
matenal The most common are vanous types of
braided asbestos that contain lubncants Other
packing matenals include graphite, graphite-
impregnated fibers, and tetrafluorethylene polymer
The packing material used depends on the valve
application and configuration These conventional
packing glands can be used over a range of
operating temperatures, but at high pressures, these
glands must be quite tight to obtain a good seal
(Templeton, 1971)
teak areas
Packing
Bail
Figure 3-11. Diagram of a ball valve (U.S EPA, 1990,
p. 2-21).
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Stem
vokซ
Bellows
Figure 3-12. Diagram of a sealed bellows valve (U.S. EPA,
1990, p. 2-23)
n
Diaphragm
Figure 3-14.
Diagram of a bonnet diaphragm seal (U.S.
EPA, 1990, p. 2-24).
Figure 3-13. Diagram of a weir diaphragm seal
(U.S. EPA, 1990, p. 2-24)
Elastomeric O-rings also are used for sealing
process valves These O-nngs provide good
sealing, but are not suitable if sliding mobon occurs
through the packing gland These seals are used
rarely in high pressure service, and operating
temperatures are limited by the seal matenai
Bellows seals are more effective for preventing
process fluid leaks than is the conventional packing
gland or any other gland-seal arrangement This
type of seal incorporates a formed metal bellows
that makes a barner between the disc and body
bonnet joint (see Figure 3-12) The bellows is the
weak point of this type of system, and service life
can be quite vanable. Consequently, this type of
seal normally is backed up with a conventional
packing gland and often is fitted with a leak detector
in case of failure
A diaphragm may be used to isolate the working
parts of the valve and the environment from the
process liquid. Illustrated in Figures 3-13 and 3-14
are two types of diaphragm seals The diaphragm
also may be used to control the flow of the process
fluid In this design, a compressor component
pushes the diaphragm toward the valve bottom,
throttling the flow The diaphragm and compressor
are connected in a manner so that separating them
is impossible under normal working conditions
When the diaphragm reaches the valve bottom, it
seats firmly against the bottom, forming a leak-proof
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seal This configuration is recommended for fluids
containing solid particles and for medium-pressure
service Depending on the diaphragm matenal, this
type of valve can be used at temperatures up to
205ฐC and in severe acid solutions If the seal fails,
however, a valve using a diaphragm seal can
become a source of fugitive, emissions (Pikulik,
1978, pp 3-23 and 3-24)
3.7	Flanges and Other Connectors
Flanges are bolted, gasket-sealed junctions used
wherever pipes or other equipment such as vessels,
pumps, valves, and heat exchangers may require
isolation or removal Connectors are all other
nonwelded fittings that serve a similar purpose to
flanges, which also allow bends in pipes (elbows),
joining two pipes (couplings), or joining three or tour
pipes (tees or crosses) Connectors typically are
threaded
Flanges may become fugitive emissions sources
when leakage occurs because of improperly chosen
gaskets or poorly assembled flanges The primary
cause of flange leakage is thermal stress, which
causes deformation of the seal between the flange
faces Threaded connectors may leak if the threads
become damaged or corroded or if tightened without
sufficient lubrication or torque LDAR programs are
the pnncipal control technique for flanges and other
connectors
3.8	Product Accumulator Vessels
The background information document for the
proposed benzene standards (U.S EPA 1980b)
states that product accumulator vessels include
overhead and bottoms receiver vessels used with
fractionation columns and product separator vessels
used in senes with reactor vessels to separate
reaction products Accumulator vessels can be
vented directly to the atmosphere or indirectly
through a blowdown drum or vacuum system When
an accumulator vessel contains benzene and vents
to the atmosphere, benzene emissions can occur
This equipment is covered only by the benzene
equipment leak standards
The benzene standards require each product
accumulator vessel to be equipped with a closed-
vent system capable of capturing and transporting
any leakage from the vessel to a control device
Acceptable control devices include vapor recovery
systems, enclosed combustion devices, or flares
These control systems are described in Section
3 10
3.9 Agitators
Agitators are used to stir or blend chemicals Like
pumps and compressors, agitators may leak
organic chemicals at the point where the shaft
penetrates the casing Consequently, seals are
required to minimize fugitive emissions Four seal
arrangements commonly are used with agitators
compression packing (packed seal), mechanical
seals, hydraulic seals, and lip seals Packed seals
for agitators are very similar in design and
application to packed seals for pumps (Ramsey and
Zoller, 1976)
Although mechanical seals are more costly than the
other three types of seals, they offer a greatly
reduced leakage rate to offset their higher cost
Furthermore, the maintenance frequency of
mechanical seals is one-half to one-fourth that of
packed seals At pressures greater than 1,140 kPa
(150 psig), the leakage rate and maintenance
frequency are so superior that the use of packed
seals on agitators is rare As with packed seals, the
mechanical seals for agitators are similar in design
and application to the mechanical seals for pumps
The hydraulic seal, which is the simplest and least
used agitator shaft seal, has an annular cup
attached to the process vessel that contains a liquid
that is in contact with an inverted cup attached to
the rotating agitator shaft The primary advantage of
this seal is that it is a noncontact seal Use of this
seal, however, is limited to low temperatures and
pressures and very small pressure fluctuations In
addition, organic chemicals may contaminate the
seal liquid and then be released into the
atmosphere as fugitive emissions.
A lip seal can be used on a top-entering agitator as
a dust or vapor seal The sealing element is a
spring-loaded elastomer Lip seals are relatively
inexpensive and easy to install Once the seal has
been installed, the agitator shaft rotates in
continuous contact with the lip seal Pressure limits
of the seal are 2 to 3 psig because it operates
without lubncation, and operating temperatures are
limited by the charactenstics of the elastomer
Fugitive emissions can be released through this
seal when the seal wears excessively or the
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operating pressure surpasses the pressure limits of
the seal
3.10	Closed-Vent Systems and Control
Devices
A closed-vent system can be used to collect and
dispose of gaseous VOC emissions from seal oil
degassing vents, pump and compressor seal
leakage, relief valve leakage, and relief valve
discharges because of over-pressure operation A
closed-vent system consists of piping connectors,
flame arrestors, and, if necessary, flow-inducing
devices Closed-vent systems are designed and
operated so that all VOC emissions are transported
to a control device without leakage to the
atmosphere
Several types of control devices can be used to
dispose of VOC and VHAP emissions captured in
the closed-vent system Incineration, carbon
adsorption, and condensation are three control
methods that typically are applied Control
efficiencies of the three methods are dependent on
specific operating characteristics and the types of
emissions being generated Typically, enclosed
combustion devices (boilers, process heaters, and
thermal and catalytic incinerators) can achieve
better than 95 percent destruction efficiencies The
key parameters affecting destruction efficiency are
residence tome and temperature Carbon adsorption
systems can achieve 95 to 99 percent control
efficiency through proper design and operation,
while condensation systems can achieve capture
efficiencies of 90 percent or more.
Flares commonly found at plants subject to these
standards include steam-assisted, air-assisted, non-
assisted, ground, and dual-flare systems. Certain
flares have demonstrated destruction efficiencies
equal to those of enclosed combustion devices
provided certain design specifications (heat content
and exit velocity) are met (U S EPA, 1985)
3.11	References
When an NTIS number is cited in a reference, that
document is available from
National Technical Information Service
5285 Port Royal Road
Spnngfield, VA 22161
703-487-4650
Nelson, WE 1977 Compressor seal fundamentals
Hydrocarbon Processing 56(12)91-95
December
Perry, R H and C H Chilton 1978 Chemical
Engineer's Handbook, 5th Edition McGraw-Hill
Book Company, New York, NY pp 6-8
Pikulik, A 1978 Manually operated valves
Chemical Engineenng 85(7) 121. April 3 pp 3-
23, 3-24
Ramsden, J.H. 1978 How to choose and install
mechanical seals Chemical Engineenng
85(22)97-102 October 9
Ramsey, WD. and GC Zoller 1976 How the
design of shafts, seals and impellers affects
agitator performance Chemical Engineenng
83(18) 101-108 August 30
Templeton, HC 1971 Valve installation, operation
and maintenance Chemical Engineering
78(23)141-149. October 11
US EPA 1990 US Environmental Protection
Agency Inspection techniques for fugitive VOC
emission sources Course module 5380
Student's manual EPA-340/1-90-026a
Washington, DC September
US EPA 1985 U.S Environmental Protection
Agency Polymer manufactunng industry
Background information for proposed standards
EPA-450/3-83-019a NTIS PB88-114996
Research Triangle Park, NC September
US. EPA 1984 US Environmental Protection
Agency Fugitive VOC emissions in the synthetic
organic chemicals manufactunng industry EPA-
625/10-84-004 Research Triangle Park, NC,
and Cincinnati, OH December
US EPA. 1980a US Environmental Protection
Agency. VOC fugitive emissions in synthetic
organic chemicals manufacturing industry.
Background information for proposed standards
EPA-450/3-80-033a NTIS PB81-152167
Research Triangle Park, NC November
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U S EPA. 1980b. U S Environmental Protection
Agency Benzene fugitive emissions
Background information for proposed standards
EPA-450/3-80-032a. NTIS PB81-151664
Research Triangle Park, NC. November.
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APPENDIX E
METHOD 21 (40 CFR 60, APPENDIX A)

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EMISSION MEASUREMENT TECHNICAL INFORMATION CENTER
NSPS TEST METHOD
(EMTIC M-21, 2/9/93)
Method 21 - Determination of Volatile Organic Compound Leaks
1.	APPLICABILITY AND PRINCIPLE
1.1	Applicability. This method applies to the determination of volatile organic compound
(VOC) leaks from process equipment. These sources include, but are not limited to,
valves, flanges and other connections, pumps and compressors, pressure relief devices,
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 specifications and
performance criteria contained in Section 3. A leak definition concentration based on a
reference compound is specified in each applicable regulation. This procedure is intended
to locate and classify leaks only, and is not to be used as a direct measure of mass
emission rate from individual sources
2.	DEFINITIONS
2.1	Leak Definition Concentration. The local VOC concentration at the surface of a
leak source that indicates that a VOC emission (leak) is present, The leak definition is an
instrument meter reading based on a reference compound.
2.2	Reference Compound. The VOC species selected as an instrument calibration basis
for specification of the leak definition concentration. (For example, if a leak definition
concentration is 10,000 ppm as methane, then any source emission that results in a local
concentration that yields a meter reading of 10,000 on an instrument meter calibrated with
methane would be classified as a leak In this example, the leak definition is 10,000 ppm,
and the reference compound is methane.)
2.3	Calibration Gas. The VOC compound used to adjust the instrument meter reading
to a known value. The calibration gas is usually the reference compound at a known
concentration approximately equal to the leak definition concentration.
2.4	No Detectable Emission. The total 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 reproducibility,
a difference between the source surface concentration and the local ambient concentration
is determined A difference based on the meter readings of less than a concentration
METHOD 21 (40 CFR 60. APPENDIX A)
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corresponding to the minimum readability specification indicates that a VOC emission
(leak) is not present. (For example, if the leak definition in a regulation is 10,000 ppm, then
the allowable increase is surface concentration versus local ambient concentration would
be 500 ppm 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 measured using an instrument calibrated with the reference
compound specified in the applicable 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
between the meter readings and the known concentration to the known concentration.
2.7	Response Time. The time interval from a step change in VOC concentration at the
input of the sampling system to the time at which 90 percent of the corresponding final
value is reached as displayed on the instrument readout meter.
3. APPARATUS
3.1 Monitoring Instrument
3.1.1 Specifications
a.	The VOC instrument detector shall respond to the compounds being processed.
Detector types which may meet this requirement include, but are not limited to, catalytic
oxidation, flame ionization, infrared absorption, and photoionization.
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 + or - 5 percent of the specified
leak definition concentration.
d.	The instrument shall be equipped with a pump so that a continuous sample is provided
to the detector. The nominal sample flow rate shall be 0.1 to 3.0 liters per minute.
e.	The instrument shall be intrinsically safe for operation in explosive atmospheres as
defined by the applicable U.S.A. standards (e.g., National Electrical Code by the National
Fire Prevention Association).
f.	The instrument shall be equipped with a probe or probe extension for sampling not to
exceed 1/4 in. in outside diameter, with a single end opening for admission of sample.
METHOD 21 (40 CFR 60. APPENDIX A)
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3.1.2	Performance Criteria.
a.	The instrument response factors for the individual compounds to be measured must
be less than 10.
b.	The instrument response time must be equal to or less than 30 seconds. The
response time must be determined for the instrument configuration to be used during
testing.
c.	The calibration precision must be equal to or less than 10 percent of the calibration gas
value
d.	The evaluation procedure for each parameter is given in Section 4.4.
3.1.3	Performance Evaluation Requirements.
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 intervals
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 before placing the instrument into service If a
modification to the sample pumping system or flow configuration is made that would
change the response time, a new test is required before further use.
3.2 Calibration Gases.
The monitoring instrument is calibrated in terms of parts per million by volume (ppm)
of the reference compound specified in the applicable regulation. The calibration gases
required for monitoring and instrument performance evaluation are a zero gas (air, less
than 10 ppm VOC) and a calibration gas in air mixture approximately equal to the leak
definition specified in the regulation. If cylinder calibration gas mixtures are used, they
must be analyzed and certified by the manufacturer to be within + or - 2 percent accuracy,
and a shelf life must be specified. Cylinder standards must be either reanalyzed or
replaced at the end of the specified shelf life. Alternatively, calibration gases may be
prepared by the user according to any accepted gaseous preparation procedure that will
yield a mixture accurate to within + or - 2 percent. Prepared standards must be replaced
each day of use unless it can be demonstrated that degradation does not occur during
storage.
Calibrations may be performed using a compound other than the reference compound
if a conversion factor is determined for that alternative compound so that the resulting
METHOD 21 (40 CFR 60, APPENDIX A)
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meter readings during source surveys can be converted to reference compound results.
4. PROCEDURES
4.1	Pretest Preparations. Perform the instrument evaluation procedure given in Section
4.4 if the evaluation requirement 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 appropriate warmup period and zero internal
calibration procedure, introduce the calibration gas into the instrument sample probe.
Adjust the instrument meter readout to correspond to the calibration gas value. (Note: If
the meter readout cannot be adjusted to the proper value, a malfunction of the analyzer
is indicated and corrective actions are necessary before use.)
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 interface where leakage is indicated until the maximum
meter reading is obtained. Leave the probe inlet at this maximum reading location for
approximately two times the instrument 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. Examples of the application
of this general technique to specific equipment types are:
a.	Valves - Leaks usually occur at the seal between the stem and the housing Place the
probe at the interface where the stem exits the packing and sample the stem
circumference and the flange periphery. Survey valves of multipart assemblies where a
leak could occur.
b.	Flanges and Other Connections - Place the probe at the outer edge of the flange-
gasket interface and sample the circumference of the flange.
c.	Pump or Compressor Seals - If applicable, determine the type of shaft seal. Perform
a survey of the local area ambient VOC concentration and determine if detectable
emissions exist as described above.
d.	Pressure Relief Devices - For those devices equipped with an enclosed extension, or
horn, place the probe inlet at approximately the center of the exhaust area to the
atmosphere.
e.	Process Drains - For open drains, place the probe inlet as near as possible to the
METHOD 21 (40 CFR 60, APPENDIX A)
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center of the area open to the atmosphere. For covered drains, locate probe at the surface
of the cover and traverse the periphery.
f.	Open-ended Lines or Valves - Place the probe inlet at approximately the center of the
opening of the atmosphere.
g.	Seal System Degassing Vents, Accumulator Vessel Vents, Pressure Relief Devices -
If applicable, observe whether the applicable ducting or piping exists. Also, determine if
any sources exist in the ducting or piping where emissions could occur before the control
device If the required ducting or piping exists and there are no sources where the
emissions could be vented to the atmosphere before the control device, then it is
presumed that no detectable emissions are present. If there are sources in the ducting or
piping where emissions could be vented or sources where leaks could occur, the sampling
surveys described in this section shall be used to determine if detectable emissions exist.
h.	Access door seals - Place the probe inlet at the surface of the door seal interface and
traverse the penphery.
4.3.2	Type II - "No Detectable Emission". Determine the ambient concentration around
the source by moving the probe randomly upwind and downwind around one to two meters
from the source. In case of interferences, this determination may be made closer to the
source down to no closer than 25 centimeters. Then move the probe to the surface of the
source and measure as In 4.3 1. The difference in these concentrations determines
whether there are no detectable emissions. When the regulation also requires that no
detectable emissions exist, visual observations and sampling surveys are required.
Examples of this technique are: (a) Pump or Compressor Seals - Survey the local area
ambient VOC concentration and determine if detectable emissions exist, (b) Seal System
Degassing Vents, AccumulatorVessel Vents, Pressure Relief Devices - Determine if any
VOC sources exist upstream of the device. If such ducting exists and emissions cannot
be vented to the atmosphere upstream of the control device, then it is presumed that no
detectable emissions are present. If venting is possible sample to determine if detectable
emissions are present
4.3.3	Alternative Screening Procedure.
4.3.3.1 A screening procedure based on the formation of bubbles in a soap solution that
is sprayed on a potential leak source may be used for those sources that do not have
continuously moving parts, that do not have surface temperatures greater than the boiling
point or less than the freezing point of the soap solution, that do not have open areas to
the atmosphere that the soap solution cannot bridge, or that do not exhibit evidence of
liquid leakage. Sources that have these conditions present must be surveyed using the
instrument technique of Section 4.3 1 or 4.3.2.
METHOD 21 (40 CFR 60, APPENDIX A)
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4.3.3.2 Spray a soap solution over all potential leak sources. The soap solution may be
a commercially available leak detection solution or may be prepared using concentrated
detergent and water.
A pressure sprayer or squeeze bottle may be used to dispense the solution. Observe the
potential leak sites to determine if any bubbles are formed. If no bubbles are observed,
the source is presumed to have no detectable emissions or leaks as applicable. If any
bubbles are observed, the instrument techniques of Section 4.3.1 or 4.3.2 shall be used
to determine if a leak exists, or if the source has detectable emissions, as applicable.
4.4 Instrument Evaluation Procedures. At the beginning of the instrument performance
evaluation test, assemble and start up the instrument according to the manufacturer's
instructions for recommended warmup period and preliminary adjustments.
4.4.1	Response Factor.
4.4.1.1	Calibrate the instrument 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 concentration of
approximately 80 percent of the applicable leak definition unless limited by volatility or
explosivity. In these cases, prepare a standard at 90 percent of the standard saturation
concentration, or 70 percent of the lower explosive limit, respectively. Introduce this
mixture to the analyzer and record the observed meter reading. Introduce zero air until a
stable reading is obtained. Make a total of three measurements by alternating between
the known mixture and zero air. Calculate the response factor for each repetition and the
average response factor.
4.4.1.2	Alternatively, if response factors have been published for the compounds of
interest for the instrument or detector type, the response factor determination is not
required, and existing results may be referenced. Examples of published response factors
for flame ionization and catalytic oxidation detectors are included in the Bibliography.
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 algebraicdifference between the meter readings and the known value. Divide this
average difference by the known calibration value and multiply by 100 to express the
resulting calibration precision as a percentage.
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 90 percent of the final stable reading is attained. Perform this
test sequence three times and record the results. Calculate the average response time.
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5. BIBLIOGRAPHY
1.	Dubose, D.A., and G.E. Harris. Response Factors of VOC Analyzers at a Meter
Reading of 10,000 ppmv for Selected Organic Compounds. U.S. Environmental Protection
Agency, Research Triangle Park, NC. Publication No. EPA 600/2-81051. September 1981.
2.	Brown, G.E., et al. Response Factors of VOC Analyzers Calibrated with Methane for
Selected Organic Compounds. U.S. Environmental Protection Agency, Research Triangle
Park, NC. Publication No. EPA 600/2-81-022. May 1981.
3.	DuBose, D.A. et al. Response of Portable VOC Analyzers to Chemical Mixtures.
U.S. Environmental Protection Agency, Research Triangle Park, NC. Publication No. EPA
600/2-81-110. September 1981.
METHOD 21 (40 CFR 60. APPENDIX A)
page E-7

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METHOD 21 (40 CFR 60, APPENDIX A)	page E-8

-------
APPENDIX F
CHEMICAL MANUFACTURING PROCESSES
SUBJECT TO HON STANDARDS
(40 CFR 63, SUBPART H)

-------
TABLE 1 TO SUBPART F - SYNTHETIC ORGANIC CHEMICAL MANUFACTURING INDUSTRY
CHEMICALS
Chemical Name0
CAS Number"
Group
Acenaphthene
83329
V
Acetal
105577
V
Acetaldehyde
75070
II
Acetaldol
107891
II
Acetamide
60355
II
Acetanilide
103844
II
Acetic acid
64197
II
Acetic anhydnde
108247
II
Acetoacetanilide
102012
III
Acetone
67641
I
Acetone cyanohydnn
75865
V
Acetonitnle
75058
I
Acetophenone
98862
I
Acrolein
107028
IV
Acrylamide
79061
I
Acrylic acid
79107
IV
Acrylonitrile
107131
I
Adiponitnle
111693
I
Alizarin
72480
V
Alky I anthraquinones
008
V
Allyl alcohol
107186
I
Allyl chlonde
107051
IV
Allyl cyanide
109751
IV
Aminophenol sulfonic acid
0010
V
Aminophenol (p-)
123308
I
Aniline
62533
I
Aniline hydrochlonde
142041
III
Anisidine (o-)
90040
II
Anthracene
120127
V
Anthraquinone
84651
III
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS

page F-1

-------
Chemical Name3
CAS Number"
Group
Azobenzene
103333
I
Benzaldehyde
100527
III
Benzene
71432
I
Benzenedisulfonic acid
98486
I
Benzenesulfonic acid
98113
I
Benzil
134816
III
Benzilic actd
76937
III
Benzoic acid
65850
III
Benzoin
119539
III
Benzonitrile
100470
III
Benzophenone
119619
I
Benzotnchlonde
98077
III
Benzoyl chlonde
98884
III
Benzyl acetate
140114
III
Benzyl alcohol
100516
III
Benzyl benzoate
120514
III
Benzyl chlonde
100447
III
Benzyl dichlonde
98873
III
Biphenyl
92524
l
Bisphenol A
80057
III
Bis(Chloromethy 1) Ether
542881
I
Bromobenzene
108861
I
Bromoform
75252
V
Bromonaphthalene
27497514
IV
Butadiene (1,3-)
106990
II
Butanediol (1,4-)
110634
I
Butyl acrylate (n-)
141322
V
Butylene glycol (1,3-)
107880
II
Butyrolactone
96480
I
Caprolactam
105602
II
Carbaryl
63252
V
Carbazole
86748
V
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS

page F-2

-------
Chemical Name3
CAS Number6
Group
Carbon disulfide
75150
IV
Carbon tetrabromide
558134
II
Carbon tetrachlonde
56235
I
Carbon tetrafluoride
75730
II
Chloral
75876
II
Chloroacetic acid
79118
II
Chloroacetophenone (2-)
532274
I
Chloroaniline (p-)
106478
II
Chlorobenzene
108907
I
2-Chloro-1,3-butadiene (Chloroprene)
126998
II
Chlorodifluoroethane
25497294
V
Chlorodifluoromethane
75456
I
Chloroform
67663
I
Chloronaphthalene
25586430
IV
Chloronitrobenzene (m-)
121733
I
Chloronitrobenzene (o-)
88733
I
Chloronitrobenzene (p-)
100005
I
Chlorophenol (m-)
108430
II
Chlorophenol (o-)
95578
II
Chlorophenol (p-)
106489
II
Chlorotoluene (rrv)
108418
III
Chlorotoluene (o-)
95498
III
Chlorotoluene (p-)
106434
III
Chlorotnfluoromethane
75729
II
Chrysene
218019
V
Cresol and cresylic acid (m-)
108394
III
Cresol and cresylic acid (o-)
95487
III
Cresol and cresylic acid (p-)
106445
111
Cresols and cresylic acids (mixed)
1319773
III
Cumene
98828
I
Cumene hydroperoxide
80159
I
Cyanoacetic acid
372098
II
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS	page F-3

-------
Chemical Name3
CAS Number"
Group
Cyclohexane
110827
I
Cyclohexanol
108930
I
Cyclohexanone
108941
I
Cyclohexylamine
108918
III
Cyclooctadienes
29965977
II
Decahydronaphthalene
91178
IV
Diacetoxy-2-Butene (1,4-)
0012
V
Diaminophenol hydrochloride
137097
V
Dibromomethane
74953
V
Dichloroaniline (mixed isomers)
27134276
I
Dichlorobenzene (p-)
106467
I
Dichlorobenzene (m-)
541731
I
Dichlorobenzene (o-)
95501
I
Dichlorobenzidine (3,3*-)
91941
I
Dichlorodifluoromethane
75718
I
Dichloroethane (1,2-) (Ethylene dichlonde) (EDC)
107062
I
Dichloroethyl ether (bis(2-chloroethyl)ether)
111444
I
Dichloroethylene (1,2-)
540590
II
Dichlorophenol (2,4-)
120832
III
Dichloropropene (1,3-)
542756
II
Dichlorotetrafluoroethane
1320372
V
Dichloro-1-butene (3,4-)
760236
II
Dichloro-2-butene (1,4-)
764410
V
Diethanolamine (2,2'-lminodiethanol)
111422
I
Diethyl sulfate
64675
II
Diethylamine
109897
IV
Diethyianiline (2,6-)
579668
V
Diethylene glycol
111466
I
Diethylene glycol dibutyl ether
112732
I
Diethylene glycol diethyl ether
112367
I
Diethylene glycol dimethyl ether
111966
I
Diethylene glycol monobutyl ether acetate
124174
I
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-4

-------
Chemical Name8
CAS Number"
Group
Diethylene glycol monobutyl ether
112345
I
Diethylene glycol monoethyl ether acetate
112152
I
Diethylene glycol monoethyl ether
111900
I
Diethylene glycol monohexyl ether
112594
V
Diethylene glycol monomethyl ether acetate
629389
V
Diethylene glycol monomethyl ether
111773
I
Dihydroxybenzoic acid (Resorcylic acid)
27138574
V
Dimethylbenzidine (3,3'-)
119937
II
Dimethyl ether
115106
IV
Dimethylfomnamide (N,N-)
68122
II
Dimethylhydrazine (1,1-)
57147
II
Dimethyl sulfate
77781
I
Dimethyl terephthalate
120616
II
Dimethylamine
124403
IV
Dimethylaminoethanol (2-)
108010
I
Dimethylanihne (N,N')
121697
III
Dinitrobenzenes (NOS)c
25154645
I
Dinitrophenol (2,4-)
51285
III
Dinitrotoluene (2,4-)
121142
III
Dioxane (1,4-) (1,4-Diethyleneoxide)
123911
I
Dioxolane (1,3-)
646060
I
Diphenyl methane
101815
1
Diphenyl oxide
101848
1
Diphenyl thiourea
102089
III
Diphenylamine
122394
III
Dipropylene glycol
110985
1
Di-o-tolyguanidine
97392
III
Dodecanedioic acid
693232
1
Dodecyl benzene (branched)
123013
V
Dodecyl phenol (branched)
121158585
V
Dodecylaniline
28675174
V
Dodecylbenzene (n-)
121013
1
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS

page F-5

-------
Chemical Name3
CAS Number"
Group
Dodecylphenol
27193868
III
Epichlorohydnn (1-chloro-2,3-epoxypropane)
106898
I
Ethanolamine
141435
I
Ethyl aery late
140885
II
Ethylbenzene
100414
I
Ethyl chlonde (Chloroethane)
75003
IV
Ethyl chloroacetate
105395
II
Ethylamine
75047
V
Ethylaniline (N-)
103695
III
Ethylaniline (o-)
578541
III
Ethylcellulose
9004573
V
Ethylcyanoacetate
105566
V
Ethylene carbonate
96491
I
Ethylene dibromide (Dibromoethane)
106934
I
Ethylene glycol
107211
I
Ethylene glycol diacetate
111557
I
Ethylene glycol dibutyl ether
112481
V
Ethylene glycol diethyl ether (1,2-diethoxyethane)
629141
I
Ethylene glycol dimethyl ether
110714
I
Ethylene glycol monoacetate
542596
V
Ethylene glycol monobutyl ether acetate
112072
I
Ethylene glycol monobutyl ether
111762
I
Ethylene glycol monoethyl ether acetate
111159
I
Ethylene glycol monoethyl ether
110805
I
Ethylene glycol monohexyl ether
112254
V
Ethylene glycol monomethyl ether acetate
110496
I
Ethylene glycol monomethyl ether
109864
I
Ethylene glycol monooctyl ether
002
V
Ethylene glycol monophenyl ether
122996
I
Ethylene glycol monopropyl ether
2807309
I
Ethylene oxide
75218
I
Ethylenediamine
107153
II
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-6

-------
Chemical Name"
CAS Number"
Group
Ethylenediamine tetraacetic acid
60004
V
Ethylenimine (Azindme)
151564
II
Ethylhexyl acrylate (2-isomer)
103117
II
Fluoranthene
206440
V
Formaldehyde
50000
I
Formamide
75127
II
Formic acid
64186
II
Fumaric acid
110178
I
Glutaraldehyde
111308
IV
Glyceraldehyde
367475
V
Glycerol
56815
II
Glycine
56406
II
Glyoxal
107222
II
Hexachlorobenzene
118741
II
Hexachlorobutadiene
87683
II
Hexachloroethane
67721
II
Hexadiene (1,4-)
592450
II
Hexamethylenetetramine
100970
I
Hexane
110543
V
Hexanetnol (1,2,6-)
106694
IV
Hydroquinone
123319
I
Hydroxyadipaldehyde
141311
V
Isobutyl acrylate
106638
V
Isobutylene
115117
V
Isophorone
78591
IV
Isophorone nitnle
0017
V
Isophthalic acid
121915
III
Isopropylphenol
25168063
III
Linear atkylbenzene
	d
I
Maleic anhydnde
108316
I
Maleic hydrazide
123331
I
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-7

-------
Chemical Name3
CAS Number"
Group
Malic acid
6915157
I
Metarule acid
121471
I
Methacrylic acid
79414
V
Methanol
67561
IV
Methionine
63683
I
Methyl acetate
79209
IV
Methyl acrylate
96333
V
Methyl bromide (Bromomethane)
74839
IV
Methyl chlonde (Chloromethane)
74873
IV
Methyl ethyl ketone (2-butanone)
78933
V
Methyl formate
107313
II
Methyl hydrazine
60344
IV
Methyl isobutyl carbinol
108112
IV
Methyl isobutyl ketone (Hexone)
108101
IV
Methyl isocyanate
624839
IV
Methyl mercaptan
74931
IV
Methyl methacrylate
80626
IV
Methyl phenyl carbinol
98851
II
Methyl tert-butyl ether
1634044
V
Methylamine
74895
IV
Methylaniline (N-)
100618
III
Methylcyclohexane
108872
III
Methylcyclohexanol
25639423
V
Methylcyclohexanone
1331222
III
Methylene chlonde (Dichloromethane)
75092
I
Methylene dianiline (4,4'-isomer)
101779
I
Methylene diphenyl dusocyanate (4,4'-) (MDI)
101688
III
Methylionones (a-)
79696
V
Methylpentynol
77758
V
Methylstyrene (a-)
98839
I
Naphthalene
91203
IV
Naphthalene sulfonic acid (a-)
85472
IV
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS	page F-8

-------
Chemical Name3
CAS Number"
Group
Naphthalene sulfonic acid (b-)
120183
IV
Naphthol (a-)
90153
IV
Naphthol (b-)
135193
IV
Naphtholsulfonic acid (1-)
567180
V
Naphthylamine sulfonic acid (1,4-)
84866
V
Naphthylamine sulfonic acid (2,1-)
81163
V
Naphthylamine (1-)
134327
V
Naphthylamine (2-)
91598
V
Nitroaniline (m-)
99092
II
Nitroaniline (o-)
88744
I
Nitroanisole (o-)
91236
III
Nitroanisole (p-)
100174
III
Nitrobenzene
98953
I
Nitronaphthalene (1-)
86577
IV
Nitrophenol (p-)
100027
III
Nitrophenol (o-)
88755
III
Nitropropane (2-)
79469
II
Nitrotoluene (all isomers)
1321126
III
Nitrotoluene (o-)
88722
III
Nitrotoluene (m-)
99081
III
Nitrotoluene (p-)
99990
III
Nitroxylene
25168041
V
Nonylbenzene (branched)
1081772
V
Nonytphenol
25154523
V
Octene-1
111660
I
Octylphenol
27193288
III
Paraformaldehyde
30525894
1
Paraldehyde
123637
II
Pentachlorophenol
87865
III
Pentaerythntol
115775
1
Peracetic acid
79210
II
Perchloromethyl mercaptan
594423
IV
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS	page F-9

-------
Chemical Name3
CAS Number"
Group
Phenanthrene
85018
V
Phenetidine (p-)
156434
III
Phenol
108952
III
Phenolphthalein
77098
III
Phenolsulfonic acids (all isomers)
1333397
III
Phenyl anthranihc acid (all isomers)
91407
III
Phenylenediamine (p-)
106503
I
Phloroglucinol
108736
111
Phosgene
75445
IV
Phthatic acid
88993
III
Phthalic anhydride
85449
III
Phthalimide
85416
III
Phthalonitnle
91156
III
Picoline (b-)
108996
II
Piperazine
110850
I
Propiolactone (beta-)
57578
I
Propionaldehyde
123386
IV
Propionic acid
79094
I
Propylene carbonate
108327
V
Propylene dichlonde (1,2-dichtoropropane)
78875
IV
Propylene glycol
57556
I
Propylene glycol monomethyl ether
107982
I
Propylene oxide
75569
I
Pyrene
129000
V
Pyridine
110861
II
p-tert-Butyl toluene
98511
III
Quinone
106514
III
Resorcinol
108463
I
Salicylic acid
69727
III
Sodium methoxide
124414
IV
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-10

-------
Chemical Name3
CAS Number"
Group
Sodium phenate
139026
III
Stilbene
588590
III
Styrene
100425
I
Succinic acid
110156
I
Succinomtnle
110612
I
Sulfanilic acid
121573
III
Sulfoiane
126330
II
Tartaric acid
526830
I
Terephthalic acid
100210
II
Tetrabromophthalic anhydride
632791
III
Tetrachlorobenzene (1,2,4,5-)
95943
I
Tetrachloroethane (1,1,2,2-)
79345
II
T etrachioroethylene (Perchloroethylene)
127184
I
Tetrachlorophthalic anhydride
117088
III
Tetraethyl lead
78002
IV
Tetraethylene glycol
112607
1
Tetraethylenepentamine
112572
V
Tetrahydrofuran
109999
1
Tetrahydronapthalene
119642
IV
Tetrahydrophthalic anhydride
85438
II
Tetramethylenediamine
110601
II
Tetramethylethylenediannine
110189
V
Tetramethyllead
75741
V
Toluene
108883
1
Toluene 2,4 diamine
95807
II
Toluene 2,4 diisocyanate
584849
II
Toluene dnsocyanates (mixture)
26471625
II
Toluene sulfonic acids
104154
III
Toluenesulfonyl chloride
98599
III
Toluidine (o-)
95534
II
Trichloroaniline (2,4,6-)
634935
III
Tnchlorobenzene (1,2,3-)
87616
V
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-11

-------
Chemical Name8
CAS Number"
Group
Tnchlorobenzene (1,2,4-)
120821
I
Tnchloroethane (1,1,1-)
71556
II
Tnchloroethane (1,1,2-) (Vinyl trichloride)
79005
II
Tnchloroethylene
79016
I
T nchlorofiuoromethane
75694
I
Tnchlorophenol (2,4,5-)
95954
I
(1,1,2-) Tnchloro (1,2,2-) tnfluoroethane
76131
I
T nethanolamine
102716
I
Triethylamine
121448
IV
Triethylene glycol
112276
I
Triethylene glycol dimethyl ether
112492
I
Triethylene glycol monoethyl ether
112505
V
Triethylene glycol monomethyl ether
112356
I
Trimethylamine
75503
IV
Tnmethylcyclohexanol
933482
IV
Tnmethylcyclohexanone
2408379
IV
T nmethylcyclohexy lamine
34216347
V
T nmethylolpropane
77996
I
Tnmethylpentane (2,2,4-)
540841
V
Tnpropylene glycol
24800440
V
Vinyl acetate
108054
II
Vinyl chlonde (Chloroethylene)
75014
I
Vinyl toluene
25013154
III
Vinylcyclohexene (4-)
100403
II
Vinylidene chlonde (1,1-dichloroethylene)
75354
II
Vinyl(N-)-pyrrolidone(2-)
88120
V
Xanthates
140896
V
Xylene sulfonic acid
25321419
III
Xylenes (NOS)c
1330207
I
Xylene (m-)
108383
I
Xylene (o-)
95476
I
Xylene (p-)
106423
I
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-12

-------
Chemical Name"
CAS Number"
Group
Xylenols (Mixed)
1300716
V
Xylidene
1300738
III
alsomer means all structural arrangements for the same
number of atoms of each element and does not mean salts,
esters, or denvatives
bCAS Number = Chemical Abstract Service number
cNOS = not otherwise specified.
dNo CAS number assigned.
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-13

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THIS PAGE INTENTIONALLY LEFT BLANK
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS	page F-14

-------
APPENDIX G
ORGANIC HAP SUBJECT TO HON STANDARDS (SUBPART H)

-------
TABLE 2 TO SUBPART F - ORGANIC HAZARDOUS AIR POLLUTANTS
Chemical Name8 "
CAS Number'
Acenaphthene
83329
Acetaldehyde
75070
Acetamide
60355
Acetonitnle
75058
Acetophenone
98862
Acrolein
107028
Acrylamide
79061
Acrylic acid
79107
Acrylonitnle
107131
Alizarin
72480
Allyl chloride
107051
Aniline
62533
Amsidine (o-)
90040
Anthracene
120127
Anthraquinone
84651
Benzene
71432
Benzotnchloride
98077
Benzyl chloride
100447
Biphenyl
92524
Bis(chloromethyl)ether
542881
Bromoform
75252
Bromonaphthalene
27497514
Butadiene (1,3-)
106990
Carbon disulfide
75150
Carbon tetrachtonde
56235
Chloroacetic acid
79118
Chloroacetophenone (2-)
532274
Chlorobenzene
108907
ORGANIC HAP SUBJECT TO HON STANDARDS
page G-1

-------
Chemical Name3"
CAS Number'
2-Chloro-,1,3-butadiene (Chloroprene)
126998
Chloroform
67663
Chloronaphthalene
25586430
Chrysene
218019
Cresols and cresylic acids (mixed)
1319773
Cresol and cresylic acid (o-)
95487
Cresol and cresylic acid (m-)
108394
Cresol and cresylic acid (p-)
106445
Cumene
98828
Dichlorobenzene (p-)
106467
Dichlorobenzidine (3,3'-)
91941
Dichloroethane (1,2-) (Ethylene dichlonde) (EDC)
107062
Dichloroethyletber (Bis(2-chloroethyl)ether)
111444
Dichloropropene (1,3-)
542756
Diethanolamine (2,2'-lminodiethanol)
111422
Dimethylaniline (N.N-)
121697
Diethyl sulfate
64675
Dimethylbenzidine (3,3'-)
119937
Dimethylformamide (N,N-)
68122
Dimethylhydrazine (1,1-)
58147
Dimethyl phthalate
131113
Dimethylsulfate
77781
Dinitrophenol (2,4-)
51285
Dinitrotoluene (2,4-)
121142
Dioxane (1,4-) (1,4-Diethyleneoxide)
123911
1,2-Diphenylhydrazine
122667
Epichlorohydnn (1-Chloro-2,3-epoxypropane)
106898
Ethyl acrylate
140885
Ethylbenzene
100414
Ethyl chloride (Chloroethane)
75003
ORGANIC HAP SUBJECT TO HON STANDARDS
page G-2

-------
Chemical Nameฎ-"
CAS Number0
Ethylene dibromide (Dibromoethane)
106934
Ethylene glycol
107211
Ethylene oxide
75218
Ethylidene dichlonde (1,1-Dichloroethane)
75343
Fluoranthene
206440
Formaldehyde
50000
Glycol ethers'1

Hexachlorobenzene
118741
Hexachlorobutadiene
87683
Hexachloroethane
67721
Hexane
110543
Hydroquinone
123319
Isophorone
78591
Maleic anhydnde
108316
Methanol
67561
Methylbromide (Bromomethane)
74839
Methylchloride (Chloromethane)
74873
Methyl ethyl ketone (2-Butanone)
78933
Methyl hydrazine
60344
Methyl isobutyl ketone (Hexone)
108101
Methyl isocyanate
624839
Methyl methacrylate
80626
Methyl tert-butyl ether
1634044
Methylene chloride (Dichloromethane)
75092
Methylene diphenyl dusocyanate (4,4'-) (MDI)
101688
Methylenedianiline (4,4*-)
101779
Naphthalene
91203
Naphthalene sulfonic acid (a)
85472
Naphthalene sulfonic acid (3)
120183
Naphthol (a)
90153
Naphthol (|3)
135193
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Chemical Nameab
CAS Number0
Naphtholsulfonic acid (1-)
567180
Naphthylamine sulfonic acid (1,4-)
84866
Naphthylamine sulfonic acid (2,1-)
81163
Naphthylamine (1-)
134327
Naphthylamine (2-)
91598
Nitronaphthalene (1-)
86577
Nitrobenzene
98953
Nitrophenol (p-)
100027
Nitropropane (2-)
79469
Phenanthrene
85018
Phenol
108952
Phenylenediamine (p-)
106503
Phosgene
75445
Phthalic anhydnde
85449
Propiolactone (beta-)
57578
Propionaldehyde
123386
Propylene dichlonde (1,2-Dichloropropane)
78875
Propylene oxide
75569
Pyrene
129000
Quinone
106514
Styrene
100425
Tetrachloroethane (1,1,2,2-)
79345
Tetrachloroethylene (Perchloroethylene)
127184
Tetrahydronaphthalene
119642
Toluene
108883
Toluene diamine (2,4-)
95807
Toluene diisocyanate (2,4-)
584849
Toluidine (o-)
95534
Tnchlorobenzene (1,2,4-)
120821
Tnchloroethane (1,1,1-) (A/lethyl chloroform)
71556
Tnchloroethane (1,1,2-) (Vinyl tnchlonde)
79005
ORGANIC HAP SU8JECT TO HON STANDARDS
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Chemical Nameob
CAS Number0
Trichloroethylene
79016
Trichlorophenol (2,4,5-)
95954
Tnethylamine
121448
Tnmethylpentane (2,2,4-)
540841
Vinyl acetate
108054
Vinyl chlonde (Chloroethylene)
75014
Vinylidene chlonde (1,1-Dichloroethylene)
75354
Xylenes (NOS)
1330207
Xylene (m-)
108383
Xylene (o-)
95476
Xylene (p-)
106423
a For all Listings above containing the word "Compounds," the following applies' Unless otherwise
specified, these listings are defined as including any unique chemical substance that contains the named
chemical (i e , antimony, arsenic) as part of that chemical's infrastructure.
blsomer means all structural arrangements for the same number of atoms of each element and does not
mean salts, esters, or denvatives
CCAS Number = Chemical Abstract Service number
includes mono- and di- ethers of ethylene glycol, diethylene glycol, and tnethylene glycol
R-(OCH2CH2)n-OR'
where
n = 1, 2, or 3,
R = alkyl or aryl groups, and
R'= R, H, or groups which, when removed, yield glycol ethers with the structure- R-(OCH 2CH2)n-OH
Polymers are excluded from the glycol category
ORGANIC HAP SUBJECT TO HON STANDARDS
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ORGANIC HAP SUBJECT TO HON STANDARDS

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APPENDIX H
MANUFACTURING PROCESSES AND ORGANIC HAP
SUBJECT TO HON STANDARDS (SUBPART I)

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MANUFACTURING PROCESSES AND ORGANIC HAP SUBJECT TO HON
STANDARDS (SUBPART I)
Production Processfesi
Regulated Emissions
Styrene-butadiene rubber production
Butadiene and styrene
Polybutadiene rubber production
Butadiene
The processes producing the agncultural
chemicals
Butadiene, carbon tetrachloride,
methylene chloride, and ethylene
dichlonde
Captafol™
Captan™
Chlorothalonil
Dacthal
Tordon™ acid
Processes producing the polymers/resins or other	Carbon tetrachloride, methylene
chemical products:	chloride, tetrachloroethylene.
Hypalon™
Oxybisphenoxarsine/
1,3-dnsocyanate (OBPA™)
Polycarbonates
Polysulfide rubber
Chlonnated paraffins
Symmetncal tetrachloropyndine
Pharmaceutical production processes using carbon	Carbon tetrachlonde and
tetrachloride or methylene chloride	methylene chlonde
MANUFACTURING PROCESSES AND ORGANIC HAP SUBJECT TO HON STANDARDS (SUBPART I)	page H-1
chloroform, and ethylene
dichlonde

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Production Process(es)
Regulated Emission
Processes producing the polymers/resins or other	Butadiene
chemical products
Methylmethacrylate-butadiene-
styrene resins (MBS)
Butadiene-furfural cotrimer
Methylmethacrylate-acrylonitnle-
butadiene-styrene (MABS) resins
Ethylidene norbornene
MANUFACTURING PROCESSES AND ORGANIC HAP SUBJECT TO HON STANDARDS (SUBPART I)
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