P.1 

OAR Box 1338 

Prepped by Ollie Stewart 

Document Number: 

11) ll-E-22 

Docket Number: 

A-89-10 

Printed 6/17/2008 1:48:06 PM Sheet 11 of 105 
P.2 

LAW OFFICES 

PHILIP J. HARTER 

SUITE 404 

2301 M STREET. N.W. 

WASHINGTON. D.C. 20037 

(202) 887-1033 

FAX: (202) 887.1036 

June 12,1990 

MEMORANDUM 

A-89-10 

Fi • '•• w "; .< 

[ I , p-•••••--•— • 

!"t ; W - ' 

To: 

Fr: 

EPA Negotiated Rulemaking Committee on Fugitive Emissions from Equipment Leaks 

and Interested Parties 

Philip J. Harter 

Facilitator 

Re: Outline of Agreement; July Meeting; Change in location of July Meeting 

Congratulations! We did it. The process was clearly difficult and even painful at times, but we 

reached agreement on the contours of a sound, workable rule. Much work remains on translating those 

marked-up flowcharts into regulatoryese and some additional questions still need to be addressed, so we still 

have a lot to do at the July meeting. 

Rather than enclose minutes of the meeting, as is customary, I enclose a summary prepared by EPA 

and Radian of what we agreed to plus a list of open issues.. Please review them carefully to make sure they 

comport with your understanding. If anyone has comments on the materials, please call Bob Ajax or me so 

that we can compile a working outline that reflects the committee's agreement. 

As we discussed at the end of the meeting, a drafting committee meeting will be scheduled. Because 

committees are notoriously unable to draft complex language from the ground up, EPA will update its 

strawman to reflect the agreement, so it can serve as the basis for the committee's work. In the meantime, if 

anyone feels strongly about a particular section, they are encouraged to prepare some implementing language. 

The next meeting is July 17-18. We decided to hold it in Washington, but after a cold, hard budget 

analysis, it appears that it would be far better to hold it in North Carolina (government travel budgets get 

tight around this time of year, especially when so many have to travel). Since the committee did not appear 

to feel strongly about the location, I arrogated it to myself to relocate the meeting: It will be at the Meredith 

Suites at the Park; 300 Meredith Drive; Durham, NC 27713; 919-361-1234. The hotel is off Exit 278 

on 1-40, which is the same exit as the Pickett Suites where we met before. A block of rooms has been 

reserved. When calling for reservations, please identify yourself as being with "EPA Fugitives". 

The meeting will begin at 10:00 on the first day and 9:00 on the second. It will run until about 6:00 on 

the first day and about 5:00 on the second. 
P.3 

a-' C 

REGULATORY NEGOTIATION MEETING ON FUGITIVE EQUIPMENT LEAKS 

JUNE 6-7, 1990 

COMPRI HOTEL 

RESEARCH TRIANGLE PARK, NORTH CAROLINA 

DRAFT MEETING MINUTES 

This meeting focused on key aspects of the standards. Discussion centered 

primarily around timing and implementation of the quality improvement (Ql) 

program for valves, the valve nonrepairable pool, frequency of flange 

monitoring, and basic conceptual approaches for pumps (i.e., an enforceable 

standard with a leak definition of 2000 ppm, a leak definition of 1000 ppm and 

Ql, and dual seals for new pumps.) 

In lieu of meeting notes, a summary of the general agreements reached and 

miscellaneous open issues related to the negotiation are presented. The 

following presentation materials are attached. 

Attachment 1 

Attachment 2 

Attachment 3 

Attachment 4 

Attachment 5 

Attachment 6 

Attachment 7 

Attachment 8 

Attachment 9 

Attachment 10 

Meeting Agenda 

Attendees June 6, 1990 

Conceptual Approach for Valves 

Timeline for Implementing Valves Standard 

Conceptual Approach for Pumps 

Timeline for Implementing Pumps Standard 

Conceptual Approach for Flanges 

Draft Recordkeeping and Reporting Requirements 

Batch Work Group Meeting Minutes 

EPA Suggested Provisions for Batch Processes 

Summary of Preliminary Agreements 

Valves 

Attachment 3 presents the conceptual approach for valves. Attachment 4 

presents the timeline for implementing the conceptual approach. 

• Plants with less than 250 valves will be exempt from the monthly 

monitoring and Ql provisions outlined in the valve standard but 

will be required to comply with the leak detection and repair 

provisions. 

• Phase I, 10,000 ppm LDAR program, starts the second quarter after 

promulgation. 

• Preliminary agreement was reached that the non-repairable valve 

pool could consist of up to 1% of the valve population. The nonrepairable pool would exist within any monitoring frequency and 

there would be no "sunset" provision beyond which the nonrepairable pool is eliminated. Non-repairable valves must be 

considered in calculation of leak frequency the first time they 

are identified but not at subsequent times. 

• For determining sampling frequency, results will be calculated as 

a rolling average of two consecutive monitoring periods for 

triggering or exiting monthly, quarterly or semiannual monitoring 

programs. This calculation procedure will also be used for the Ql 

program. A rolling average of three out of four consecutive 

monitoring intervals will be used to qualify for or exit the 

annual monitoring program. 
P.4 

Mr. Larry Goodheart will be refining the provisions for a Ql 

program. The program will provide for data collection, data 

analysis, and performance trials at large plants, and will require 

that all components that are replaced must be replaced with 

"superior" equipment. Also, in each plant, any groups or types of 

significantly poorer performers (SPP) will be identified, and 25% 

of the SPP's must be replaced each year. If significant 

differences are not found among types or groups of valves, then 

the 25% replacement provision does not apply. 

Pumps 

Attachment 5 presents the conceptual approach for pumps. Attachment 6 

presents the timeline for implementing the conceptual approach. 

• The allowable limit will be computed as an average of two 

consecutive monitoring periods. 

• "Small" businesses, which will be exempt from the performance 

trials outlined in the Ql program, will be defined as corporations 

having a specified maximum number of total employees (for example, 

100) and a minimum number of pumps (for example, 10). 

• No exemptions will be allowed for pumps (e.g., food/medical 

processes, monomers). 

Flanges 

Attachment 7 presents the conceptual approach for flanges. 

The conceptual approach for flanges begins at promulgation. 

The first monitoring survey must be completed within 12 months 

after promulgation. 

Buried flanges and insulated flanges will be exempted from the 

standard monitoring program. 

The regulation will explicitly state that it is not necessary to 

physically tag flanges. Flanges may be identified relative to 

other components, such as valves. 

The percent leaking flanges will be computed for each monitoring 

period; rolling averages are not permitted. 

A non-repairable flange pool of up to 2% of a unit's flange 

population will be allowed. The non-repairable flanges will not 

be included in the calculation of the percent leaking flanges. 

Repaired flanges must be monitored monthly until a leak is not 

detected for two consecutive months. 

Flanges that have been disturbed for any reason must be monitored 

within one month. 
P.5 

• Plants that monitor flanges every 2 years have the option of 

monitoring 50% of the total flange population one year and the 

other 50% in the second year. Similarly, plants that monitor 

flanges every 4 years have the option of monitoring 25% of the 

total flange population each year until all flanges have been 

monitored. 

• In addition to the existing definitions of difficult-to-monitor 

and unsafe-to-monitor, a third definition of unsafe-to-repair will 

be described in the regulation for flanges. Flanges that are 

unsafe to repair must be tagged during the first monitoring period 

of the program as being unrepairable until a plant shutdown. 

• All flanges must be monitored before a planned plant shutdown. 

Agitator Seals 

• Both new and existing agitator seals must be monitored monthly. 

Agitator seals that screen at 10,000 ppmv or greater will be 

classified as leakers. 

Other Equipment 

• All other equipment currently controlled in the existing SOCMI 

equipment leaks regulation (CFR 40, Part 60, Subpart W ) will be 

identically controlled in the negotiated standard. 

General 

The vapor pressure cutoff separating light and heavy liquids will 

remain unchanged from the existing definition (i.e., 0.3 kPa -

0.044 psia). 

The de minimis concentration cutoff will be 5 percent HAP by 

weight. 

Pilot plants are currently exempt from regulation in the House 

version of the proposed Clean Air Act amendments unless they are 

major facilities on their own. The equipment leak rule will not 

exempt pilot plants unless the Clean Air Act amendments retain 

this exemption. 

Miscellaneous Issues 

New versus Existing Plants. 

The standard will be the same for new and existing plants except 

for phasing of the requirements. 

If an existing plant does not begin its Ql program for pumps or 

valves at the end of Year 3, then it cannot opt for a Ql program 

at a later date. New plants will have one year to decide whether 

or not to begin a Ql program. 
P.6 

Process Unit Shutdowns 

Proposed language requires that, if possible, equipment should be 

isolated for repair. Otherwise, equipment repair can be delayed 

until shutdown. The EPA agreed conceptually to the language 

suggested by CMA but may make minor modifications upon further 

review. 

Response Factors. 

Mr. Ajax commented that there needs to be a maximum range on 

allowable response factors. There was no discussion on this 

comment during the meeting. Mr. Ajax believes there is a need to 

discuss this issue; otherwise, the effect of the standard could 

vary widely, and the potential for gaming would be large (e.g., by 

selecting an instrument with a favorable response factor). One 

approach would be a one-time calculation for each plant of an 

average response factor. If the average response factor lies 

within an acceptable range (e.g., 0.5 to 1.5), then there would be 

no need to adjust for response factor. Otherwise, an average 

response factor correction must be made. 

Equivalent Approaches 

The language that currently appears in the strawman regulation 

will be used to describe equivalent approaches to the standard. 

The building enclosure approach will be described as an example in 

the preamble. 

De Minimis Line Sizes 

The committee agreed to consider alternatives to including 

equipment of 3/8" or less in the leak detection and repair 

provisions. CMA agreed to review the issue and may offer an 

alternative proposal. 

Drafting Session 

A drafting session will be held for interested parties before the 

next committee meeting. The purpose of the session will be to 

begin drafting the regulation, to identify unresolved issues, and 

to discuss recordkeeping and reporting requirements. Unresolved 

issues will be discussed at the next Regulatory Negotiation 

Committee meeting. A draft example of the recordkeeping and 

reporting requirements is included as Attachment 8. 

Batch Processes 

The results of the Batch Work Group meeting on June 1 were not 

presented due to lack of time. The Batch Work Group meeting 

minutes are provided as Attachment 9. 

Subsequent to the last meeting, EPA staff reviewed the Batch Work 

Group minutes. These provisions are suggested recognizing the 

complexity and difficulty of demonstrating equivalency and are 

intended to provide a practical program that is roughly comparable 
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to LDAR. If anyone feels strongly about these provisions, they 

are encouraged to prepare an alternative set of provisions. Batch 

Work Group's proposed definition of batch processes and 

alternative testing provisions and Attachment 10 present the 

staff's suggested modifications to the proposed provisions. 
P.8 

, - <• ATTACHMENT 1 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATED RULEMAKING 

CONCERNING 

CONTROL OF FUGITIVE EMISSIONS FROM EQUIPMENT LEAKS 

AGENDA FOR MEETING OF JUNE 6-7 

ADMINISTRATIVE 

• Introductions 

• Review of the Agenda: additions, subtractions, order 

• Minutes of March meeting: Any major heartburns 

GENERAL PROVISIONS OF THE STANDARD 

• Exemptions 

- Vapor pressure cutoffs 

- De minimis concentrations 

- De minimis number of components (one level for exemption from standard; another for different 

types of requirements) 

- Equipment time in use 

- Diameter of line 

- Effects of monomers on pump performance 

- Pilot plants 

• Reasonable further progress 

• Unrepairable component set aside 

• Equivalent approaches 

• New versus existing plants 

• Phase-in 

• Tagging requirements 

• Reporting and recordkeeping 

• Incentives/awards 
P.9 

ATTACHMENT 2 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

ATTENDEES LIST FOR MEETING OF JUNE 6, 1990 

NAME 

Ed Moretti 

Bill Grimley 

Bruce Davis 

Jerry M. Schroy 

Leigh Marks 

Jan Meyer 

Walter Brenner 

Don Piehn 

Ron Berglund 

David Markwordt 

Glenn Rives 

Rick Colyer 

Ellen Siegler 

Bruce Grumstrup 

Karin Ritter 

Robert Majewski 

Robert Ajax 

Tom Kittleman 

Harvel M Rogers 

Philip Harter 

Jack Kace 

Al Bickum 

Linda Curran 

L.T. Goodheart 

Gus VonBodungen 

Fred Dimmick 

Kathy Bailey 

Charles Bennett 

David Gustafson 

John Kitchen 

Cheryl Sutterfield 

Dwight Atkinson 

Mike Pope 

Bob Rowland 

James Murphy 

Richard Sigman 

Lyman Busard 

Karen Olson 

Allen Hershkowitz 

David Doniger 

AFFILIATION 

Radian Corporation 

EPA 

Exxon Chemical Company 

Monsanto Company 

Eli Lilly & Company 

EPA 

SUN Company 

John Crane, Inc. 

Union Carbide 

EPA 

Radian 

EPA 

API 

Fisher Controls Company 

API 

NESCAUM 

U.S. EPA 

CMA (DuPont) 

Jefferson Co. APCD (Law Env.) 

Facilitator 

PMA (Hoffmann La Roche) 

IISRP (Goodyear) 

Amoco Oil Company 

API/Chevron 

LA DEQ-Air Quality 

EPA/OAQPS/RTP 

CMA 

Ashland Petroleum 

Dow Chemical 

DuPont 

PMA 

EPA/OPPE 

DOW 

Pfizer Inc. 

W.R. Grace 

CMA 

Eli Lilly and Company 

TACB 

NRDC 

NRDC 
P.10 

ar

 T 

ATTACHMENT 3 

VALVES 

PhSMl 

PhaMll 

Ph •Mill 

Monthly 

LDAR 

Quality 

Improvement 

<2%, 500 ppmv 

>2%, 500 ppmv 

> 1 % 

500 pp 

>0.5^ 

500 pp 

mv 

it 

mv 

10,000 ppm 

LDAR 

1 

500 ppm 

LDAR 

1 

Quarterly 

LDAR 

. 

Semi-Annual 

LDAR 

, 

Annual 

LDAR 

501 

1 

«s 

501 

1 

< 1 % 

3 ppmv 

•0.5% 

0 ppmv 
PhaMl 

p.11 

ATTACHMENT 4 

PhaMll 

VALVES 

Pha M III 

10,000 ppm 500 ppm 

Quarterly i Quarterly 

Promulgation EOY-1 

+ 3 months 

EOY-2 EOY-3 EOY-4 EOY-5 EOY-6 

• Ql Analyze 

i <2%, or Data 

i Monthly LDAR, or aQI 

i Quality Performance 

Improvement Trials for 

• collect data Large Plants 

i Q.I. Valve 

Replacement 

Program for 

Large Plants 

t Q.I. 

Valve 

Replacement 

Program for 

Small Plants 

EOY = EndofYear 
P.12 

ATTACHMENT 5 

PUMPS 

Phaaal 

Phaaall 

10,000 ppm 

LDAR 

1,000 ppm 

LDAR 

Phasa III 

Quality 

Improvement 

< 10%, 1,000 ppmv 

>10%, 1,000 ppmv 

Monthly 

LDAR 
ATTACHMENT 6 

PUMPS 

P.13 

Phaaal PhaMll Phase III 

10,000 ppm 

LDAR 

Monthly 

1,000 ppm EST 

Monthly 

Promulgation 

•4-3 months 

EOY-1 EOY-2 

EOY = EndofYear 

EOY-3 EOY-4 EOY-5 EOY-6 

i Ql Small plants install 

superior equipment In 

pumps (10% per year) 

i Ql Large plants Install 

superior equipment in 

pumps (10% per year) 

• Ql Analyze Data 

- large plants perform trials 

on 10% (or 3, whichever 

Is less) pumps 

• <10%or 

• Quality 

Improvement (Ql) 

- collect data 
P.14 

ATTACHMENT 7 

FLANGES 

Annual 

<0.5%, 500 ppmv 

- >0.5% 1 Every 2 years 

500 ppmv 

<0.5%, 500 ppmv 

Every 4 years 

>1% 

500 ppmv 

- >0.5% -

500 ppmv 
P.15 

ATTACHMENT 8 

New provisions are shown in bold italic print. 

§ 6. Recordkeeping Requirements 

(a) An owner or operator of more than one process unit subject to the 

provisions of this subpart may comply with the recordkeeping requirements for 

these facilities in one recordkeeping system if the system identifies each 

record by process unit and the program being implemented (e.g., quarterly). 

(b) When each leak is detected as specified in , the following 

requirements apply: 

(1) A weatherproof and readily visible identification, marked with.the 

equipment identification number, shall be attached to the leaking equipment. 

(2) The identification on a valve or a flange may be removed after it 

has been monitored for 2 successive months as specified in § and no 

leak has been detected during those 2 months. 

(3) The identification on equipment except on a valve or a flange, may 

be removed after it has been repaired. 

(c) When each leak is detected as specified in , the following 

information shall be recorded in a log and shall be kept for 2 years in a 

readily accessible location: 

(1) The instrument and operator identification numbers and the 

equipment identification number. 

(2) The date the leak was detected and the dates of each attempt to 

repair the leak. 

(3) Repair methods applied in each attempt to repair the leak. 

(4) Maximum instrument reading measured by the method specified in § 

after each repair attempt. 
P.16 

(5) "Repair delayed" and the reason for the delay if a leak is not 

repaired within 15 calendar days after discovery of the leak. 

(6) The signature of the owner or operator (or designate) whose 

decision it was that repair could not be effected without a process shutdown. 

(7) The expected date of successful repair of the leak if a leak is not 

repaired within 15 days. 

(8) Dates of process unit shutdown that occur while the equipment is 

unrepaired. 

(9) The date of successful repair of the leak. 

(d) The following information pertaining to the design requirements for 

closed-vent systems and control devices described in shall be 

recorded and kept in a readily accessible location: 

(1) Detailed schematics, design specifications, and piping and 

instrumentation diagrams. 

(2) The dates and description of any changes in the design 

specifications. 

(3) A'description of the parameter or parameters monitored, as required 

in , to ensure that control devices are operated and 

maintained in conformance with their design and an explanation of why that 

parameter (or parameters) was selected for the monitoring. 

(4) Periods when the closed-vent systems and control devices required 

in are not operated as designed, including periods when a 

flare pilot light does not have a flame. 

(5) Dates of startups and shutdowns of the closed-vent systems and 

control devices required in __. 
P.17 

(e) The following information pertaining to all equipment in each 

process unit subject to the requirements in § to § shall be 

recorded in a log that is kept in a readily accessible location: 

(l)(i) A list of identification numbers for equipment (except welded 

fittings) subject to the requirements of this subpart and the location of the 

equipment in the process unit. 

(ii) The list of equipment identification numbers and locations shall 

also include the line size, pressure, and stream service for each item of 

equipment. 

(iii) Physical tagging of the equipment is not required. Equipment 

subject to the provisions of this subpart may be identified on a plant site 

plan, in log entries, or by other appropriate methods. 

(2)(i) A list of identification numbers for equipment that the owner or 

operator elects to designate for no detectable emissions, as indicated by an 

instrument reading of less than 25 ppm above background, under the provisions 

of and . 

(ii) The designation of this equipment as subject to the requirements of 

§ , § , or § shall be signed by the owner or 

operator. 

(3) A list of equipment identification numbers for pressure relief 

devices required to comply with § . 

(4)(i) The dates of each compliance test required in 

(ii) The background level measured during each compliance test 

(iii) The maximum instrument reading measured at the equipment during 

each compliance test. 
P.18 

(5) A list of identification numbers for equipment in vacuum service. 

(6) The frequency of monitoring and provisions of the standard being 

implemented for each process unit subject to the requirements of the subpart. 

(f) The following information pertaining to all valves subject to the 

requirements of and shall be recorded in a log 

that is kept in a readily accessible location: 

NOTE: Unsafe to monitor, etc., provisions. 

(1) A list of identification numbers for valves that are designated as 

unsafe-to-monitor, an explanation for each valve stating why the valve is 

unsafe-to-monitor, and the plan for monitoring each valve. 

(2) A list of identification numbers for valves that are designated as 

difficult-to-monitor, an explanation for each valve stating why the valve is 

difficult-to-monitor, and the schedule for monitoring each valve. 

(g) The following information shall be recorded for valves complying 

with . 

NOTE: Skip period provisions. 

(1) A schedule of monitoring. 

(2) The percent of valves found leaking during each monitoring period. 

(h) The following information pertaining to all flanges subject to the 

requirements of and shall be recorded in a log that is 

kept in a readily accessible location: 

NOTE: Unsafe to monitor, etc., provisions. 

(1) A list of identification numbers for flanges that are designated as 

unsafe-to-monitor, an explanation for each flange stating why the flange is 

unsafe-to-monitor, and the plan for monitoring each flange. 
P.19 

(2) A list of identification numbers for flanges that are designated as 

difficult-to-monitor, an explanation for each flange stating why the flange is 

difficult-to-monitor, and the schedule for monitoring each flange. 

(i) The following information shall be recorded for flange complying 

with . 

NOTE: Skip period provisions. 

(1) A schedule of monitoring. 

(2) The percent of flanges found leaking during each monitoring period. 

(j) The following information shall be recorded in a log that is kept 

in a readily accessible location: , c r-

(1) Design criterion required in and and 

explanation of the design criterion; and 

(2) Any changes to this criterion and the reasons for?the changes. 

(k) Each owner or operator of a process unit subject to the reasonable 

further progress program shall maintain at the process unit for a period of 2 

years and make available to the Administrator upon request the following 

records: 

NOTE: It is assumed that there will be a separate section in the regulation that will specify the 

specific criteria of an .acceptable RFP program. The recordkeeping requirements given below are preliminary 

based on discussions to date. This section is intended to implement the RFP program and not to specify its 

features. 

(1) A description of the program and a statement of the performance 

goals. 

(2) Results of bench scale and field evaluations of low emission 

performance technology including assessment of applicability, maintenance 

needed to ensure low emission performance, and specifications necessary for 
P.20 

quality control of purchased equipment. These records will include the 

following information: 

(i) The instrument and operator identification numbers and the 

equipment identification number. 

(ii) Maximum instrument reading measured by the method specified in 

(Hi) If a leak is detected, the repair methods applied in each attempt 

to repair the leak and the maximum instrument reading measured after each 

repair attempt. 

(iv) If a leak is not repaired within 15 calendar days after discovery 

of the leak, the reason for the delay and the expected date of successful 

repair. 

(3) Evaluations of operating practices and maintenance programs needed 

to achieve low emission performance. The records shall include the data used 

to assess the effect of operating practices and maintenance on the emission 

performance of equipment. 

(4) Schedule and plan for installation of low emission potential 

equipment. 

(5) Documentation of the reasons use of low emission performance 

equipment is not technically feasible. The planned operating practices and 

maintenance of this equipment shall also be specified. 

(6) Documentation of equipment specifications for quality assurance and 

control of equipment purchases. 

(7) Documentation of operating practices, maintenance programs, and 

personnel training that will be used to achieve low emission performance. 
P.21 

(1) The following information shall be recorded in a log that is kept 

in a readily accessible location for use ih determining exemptions as provided 

in . 

NOTE: This list is preliminary and is based on the discussions in the May meeting. 

(1) An analysis demonstrating the design capacity of the affected 

facility, 

(2) A statement listing the feed or raw materials and products from the 

process unit and an analysis demonstrating whether these chemicals are heavy 

liquids, and; 

(3) An analysis demonstrating that equipment is not in VHAP service, 

(m) Information and data used to demonstrate that a piece of equipment 

is not in VHAP service shall be recorded in a log that is kept in a readily 

accessible location. 

(n) The provisions of §61.14(f) do not apply to process units subject 

to this subpart. 

§ 7. Reporting Requirements 

(a)(1) Each owner or operator of a process unit subject to the 

provisions of this subpart shall submit a statement notifying the 

Administrator which of the requirements will be implemented. 

(2) In the case of an existing process unit or a new process unit with 

a startup date preceding the effective date, the statement shall be submitted 

by days after the effective date and semiannually thereafter. 

(3) In the case of new process units which did not startup before the 

effective date, the statement shall be submitted with the application for 

approval of construction, as described in §61.07. 
P.22 

(4) The statement shall contain the following information for each 

process unit: 

(i) Process unit identification 

(ii) Number of each equipment type (e.g., valves, pumps) excluding 

equipment designated for no detectable emissions service under the provisions 

of and those in vacuum service, 

(iii) Method of compliance with the standard (for example, "monthly leak 

detection and repair" or "equipped with dual mechanical seals"). 

(iv) Planned schedule for each phase of the requirements of this 

subpart. • -•••" 

(b) A report shall be submitted to the Administrator semiannually 

starting 6 months after the initial report required in paragraph (a) of this 

section, that includes the following information: 

(1) Process unit identification, frequency of monitoring, and specific 

provisions of this subpart being implemented. 

(2) For each monitoring period during the semiannual 

reporting period, 

(i) Number of valves for which leaks were detected, the percent 

leakers, and the total number of valves tested 

(ii) Number of valves for which leaks were not repaired as required in 

(iii) Number of pumps for which leaks were detected as described in 

(iv) Number of pumps for which leaks were not repaired as described in 
P.23 

(v) Number of compressors for which leaks were detected as described in 

§ : .. 

(vi) Number of compressors for which leaks were not repaired as required 

in § . 

(vii) Mumber of flanges for which leaks were detected, the percent 

leakers, and the total number of flanges tested. 

(viii) Mumber of flanges for which leaks were not repaired as required 

in . 

(ix) Mumber of agitator seals for which leaks were detected as described 

in 

(xi) The facts that explain any delay of repairs and, where appropriate, 

why a process unit shutdown was technically infeasible. 

(xii) An example format for reporting this information is given in 

Appendix C. 

(3) Dates of process unit shutdowns which occurred within the 

semiannual reporting period. 

(4) Revisions to items reported according to paragraph (a) if changes 

have occurred since the initial report or subsequent revisions to the initial 

report. 

NOTE: Compliance with the requirements of §61.10(c) is not required for revisions documented under 

this paragraph. 

(5) The results of all performance tests to determine compliance with _ 

conducted within the 

semiannual reporting period. 

(c) An application for approval of construction or modification, 

§§61.05(a) and 61.07, will not be required if --
P.24 

(1) The new source complies with the standard, §. 

(2) The new source is not part of the construction of a process unit; 

and 

(3) In the next semiannual report required by paragraph (b) of this 

section, the information in paragraph (a)(4) of this section is reported. 

(d) An owner or operator of a process unit that fails to comply with 

(phase III standard for valves) shall notify the Administrator within 30 days 

of initiating the monthly monitoring program under or a 

reasonable further progress program under . 

(e) Each owner or operator of a process unit subject to this subpart 

shall submit a written report each year to the Administrator that Includes the 

fol1 owing information: 

(1) Analysis of trends or associations between equipment service, line 

pressure, materials of construction, line size, and other relevant variables 

and leak frequency 

(2) Assessment of performance of low emission potential technology and 

operating practices 

(3) Annual assessment of emission performance of equipment and 

conclusions on possible future improvements in low emission technology and 

operating practices. 

(f) If acceptable to both the Administrator and the owner or operator 

of the process unit, the reports may be submitted on electronic media. 

10 
P.25 

ATTACHMENT 9 

Batch Workgroup 

Meeting Minutes — June 1, 1990 

The definition of batch process equipment was discussed. Some dedicated 

batch equipment has a relatively low time-in-use (I.e., 5 days/week 

production, 1 or 2 shifts/day). Multipurpose batch equipment 1s sometimes 

run 7 days/week, 3 shifts, for the length of the campaign. It 1s then 

shut down and reconfigured to make another product. The reactor size 

of batch pharmaceutical products is primarily 1,000 gallons or less. 

The largest reactors are generally 5,000 gallons. It was decided to 

recommend that the proposed definition of batch process equipment not 

be changed from that presented with the last meeting minutes. 

The alternate of pressure testing was discussed. Eli Lilly and Company 

prepared a summary (copy attached) of the variables impacting on the 

equivalency demonstration. These variables include system temperature, 

pressure, volume, liquid/vapor ratio, and solvent volatility. The consensus 

of the group was that a pressure drop of 0.3 ps1/l ,000 ft3/15 m1n. for 

air or nitrogen represented a mid range value that is near the practical 

analytical limits. 

The Pfizer Inc. representative is investigating a pressure test with water. 

The consultant used by Pfizer is recommending a constant pressure test. 

The pressure is maintained by pumping a metered amount of water into the 

system. It is a system currently used by underground tank testers to 

measure the tightness of pipelines. This will be investigated further. 

There is likely a need to include a visible liquid leak requirement with 

the pressure test alternative. 

The alternate of measuring fugitive components with a portable meter was 

discussed. The bookkeeping and paperwork associated with this alternative 

will be very complex for a multipurpose plant. 
P.26 

PRESSURE TEST EQUIVALENT STUDY 

Eli Lilly did several case studies as requested by the PMA Fugitive 

Emission Workgroup to determine if pressure testing can be equated 

to a leak detection and repair (LDAR) program. Eli Lilly modeled ail 

calculations concerning this study for the equipment in Process Z 

which is described in Appendix A. The comparison of a pressure test 

model and a leak detection and repair (LDAR) model is extremely 

complex because both tests depend on many variables. 

LDAR LEAKRATES CALCULATED FROM EMISSION FACTORS 

The volatile hazardous air pollutant (VHAP) leakrate for a 

LDAR program is calculated from the emission factors distributed by 

the EPA on 3/27/90 during the Fugitive Emission Negotiating 

Committee (Appendix B). Table 1 compares the VHAP leakrates for 

process Z when two different criteria are used to determine the 

emission factors (Appendix B): 

TABLE 1 

Criteria for emission factors 

Pumps: 15% at 5000 ppm 

Valves: 4% at 1000 ppm 

Flanges: 4% at 1000 ppm 

Pumps: 5% at 5000 ppm 

Valves: 3% at 500 ppm 

Flanges: 2% at 500 ppm 

Instantaneous Leakrate Mb/hr, 

1.54 

0.50 

The calculated LDAR leakrate for VHAP also depends on many 

variables: on the total number of components, the definition of a 

leak for each component, and the percentage of allowable leakers. 

PRESSURE TEST LEAKRATES CALCULATED FROM EVACUATION 

COMPUTER MODEL 

The leakrate from a pressure drop is calculated by an 

evacuation model used by Eli Lilly Clinton Laboratories in their 1989 

SARA Title III calculation. Graph 1 compares the leakrate from 

process Z for a pressure drop of 1 PSIG in 15 minutes when the 

volume of the system is varied. Graph 2 compares the VHAP leakrate 

when the solvent and starting pressure is varied. 
GRAPH 1: PRESSURE TEST FOR EQUIVALENCY 

I 

UtkK RATE v» SYSTBll VOLUIIB 

1.8 2J2 

(Thousands) 

SYSTBI VOLUIIB (CUBIC FBT) 

• METHANOL 
GRAPH 2: PRESSURE TEST FOR EQUIVALENCY 

LEAK BATB vs STARTING PBBBSUBB 

STARTING PBBBSUBB (1 PSIG DROP/15 ION) 

• TOLUBNB + METHANOL 

00 
P.29 

The tabulated results from graphs 1 and 2 along with the detailed 

calculations from the computer model are described in Appendix C. 

Many other factors will effect the actual leakrates associated 

with both pressure testing and LDAR monitoring programs but are 

not reflected in these models. For batch processes, an average time 

in service for the component type will be an additional variable. 

For process Z, a leak is determined as a pressure drop of more 

than 0.03 PSIG/ 15 min. A description of the calculation is in 

Appendix D. There are a large number of variables associated with 

pressure testing and the LDAR program. Therefore, Eli Lilly feels 

0.03 PSIG/ 15 min. should not be used as a generic standard for all 

the processes which will be encompassed by this regulation. Further 

study is required to determine generic standards which could equate 

pressure testing and LDAR monitoring program. 

Leigh Marks 

Ray Collins 

Process Engineer 

Clinton Laboratory 

Eli Lilly and Company 

OG 

J. M. Colligan 

Director, Chemical Operations 

M. P. Kinney 

Manager, Chemical Operations 

R. G. Moench 

Team Leader, Environmental Task Force 
P.30 

•1 

APPENDIX A: 

PROCESS Z DESCRIPTION 

SYSTEM: 4 PROCESS TANKS AND ASSOCIATED PIPING. 

Volume = 1229 cu ft 

Temperature = 20 °C 

Solvent = Methylene Chloride (MeCl2) 

Description 

Single mechanical seal pumps 

Agitators 

Gas valves 

Liquid valves 

Flanges 

# of Compnents 

2 

4 

27 

49 

193 

Total components 275 
P.31 

APPENDIX B: 

VHAP LEAKRATES CALCULATED FROM 

EPA EMISSION FACTORS 

CASE 1: 

Criteria for emission factors 

Pumps and agitators: 15% at 5000 ppm 

Valves: 4% at 1000 ppm 

Flanges: 4% at 1000 ppm 

COMMPONENT 

SINGLE MECHANICAL SEAL PUMPS 

AGITATORS 

GAS VALVES 

LIQUID VALVES 

FLANGES 

TOTAL LEAKRATE 

EMISSION FACTOR 

0.008336 kg/hr 

0.008336 kg/hr 

0.000317 kg/hr 

0.001099 kg/hr 

0.003012 kg/hr 

0.6937 kg/hr 

1.53 Ib/hr 

QUANTITY 

2 

4 

27 

29 

193 
P.32 

CASE 2: 

Criteria for emission factors 

Pumps and agitators: 5% at 5000 ppm 

Valves: 3% at 500 ppm 

Flanges: 2% at 500 ppm 

COMMPONENT 

SINGLE MECHANICAL SEAL PUMPS 

AGITATORS 

GAS VALVES 

LIQUID VALVES 

FLANGES 

TOTAL LEAKRATE 

EMISSION FACTOR 

0.002779 kg/hr 

0.002779 kg/hr 

0.000203 kg/hr 

0.000819 kg/hr 

0.001266 kg/hr 

0.2902 kg/hr 

0.499 Ib/hr 

QUANTITY 

2 

4 

27 

29 

193 
P.33 1 

5000 ppm 

1000 ppm 

500 ppm 

5000 ppm 

1000 ppm 

500 ppm 

Assumes 29 

Calculated 

1000 ppm 

500 ppm 

250 ppm 

1000 ppm 

500 ppm 

250 ppm 

EMISSION FACTOR MATRICES 

SINGLE MECHANICAL SEAL PUMPS (KG/HR/SOURCE) 

15X 

0.008336 

0.006761 

0.005198 

10X 

0.00S5S7 

0.004S07 

0.003465 

5X 

0.0027.79 

0.002254 

0.001733 

PLANT EMISSIONS (KG/HR) 

0.241751 

0.196076 

0.150728 

0.161167 

0.130717 

0.100485 

0.080584 

0.065359 

0.050243 

IX 

0.000556 

0.000451 

0.000347 

0.016117 

0.013072 

0.010049 

pumps/plant 

emissions assume plant's emissions are 25% 

GAS VALVES 

4X 

0.000317 

0.000267 

0.000242 

atatMaiaaB*aiaaaaaSaBaBa«aidaaa>a>aaBaa a — - — 

(KG/HR/SOURCE) 

3X 

0.000249 

0.000203 

0.000181 

2X 

0.000182 

0.00014 

0.000121 

PLANT EMISSIONS (KG/HR) 

0.127293 

0.107153 

0.097083 

0.100219 

0.081616 

0.072812 

Assumes 402 gas valves/plant 

Calculated emissions assume plan 

sassaaaaaaaaaasasasasssasasaasaa 

FLANGES (KG/HR/SOURCE 

1000 ppm 

500 ppm 

250 ppm 

1000 ppm 

500 ppm 

250 ppm 

4X 

0.003012 

0.002532 

0.002175 

3X 

0.002259 

0.001899 

0.001631 

0.073144 

0.056079 

0,048542 

ir. 

0.000115 

7.6E-05 

6.04E-05 

0.046069 

0.030542 

0.024271 

t's emissions are 25X 

) 

2X 

0.001506 

.0.001266 

0.001087 

PLANT EMISSIONS (KG/HR) 

7.2288 

6.0768 

5.22 

5.4216 

4.5576 

3.915 

3.6144 

3.0384 

2.61 

IX 

0.000753 

0.000633 

0.000544 

1.8072 

1.5192 

1.305 

Assumes 2400 flanges/plant 

Calculated emissions assume plant's emissions are 25X 

500 ppm 

250 ppm 

100 ppm 

500 ppm 

250 ppm 

100 ppm 

03/27/90 ' 

DUAL MECHANICAL SEAL PUMPS (KG/HR/SOURCE) 

4X 3X 2X IX 

0.001427 0.001092 0.000757 0.000421 

0.001427 0.001092 0.000757 0.000421 

0.00111 0.000832 0.000555 0.000277 

PLANT EMISSIONS (kg/hr) 

0.04139 0.031668 0.021946 0.012223 

0.04139 0.031668 0.021946 0.012223 

0.03219 0.024142 0.016095 0.008047 

ower than emissions at stated percentage and leak definition. 

1000 ppm 

500 ppm 

250 ppm 

1000 ppm 

500 ppm 

250 ppm 

Assumes St 

ower than emis 

sasaaaasssssssi 

--

LIQUID VALVES•(KG/HR/SOURCE) 

4X 3X 2X IX 

0.001099 0.00091 0.00072 0.00053 

0.000976 0.000819 0.000662 0.000505 

0.000839 0.00071 0.000581 0.000452 

PLANT EMISSIONS (KG/HR) 

0.576138 0.476709 0.37728 0.277851 

0.511293 0.429156"oT347019~>.264882 . 

0.439767 0.372171 0.304575 0.236979 

4 1 iquid valves/plant 

sions at stated percentage and leak definition. 

? ' • y • O •" -' 

?'. . -'« • z •' 

*• '" " C I* 

y.Ht 

lower tnan emissions at stated percentage and leak definition. 
P.34 

APPENDIX C: 

VHAP LEAKRATES CALCULATED FROM ELI LILLY'S 

EVACUATION COMPUTER MODEL 
P.35 

... . 

1 

2 

3 

4 

5 

6 

7 

8 

S 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

L 

A 

psig drop i 

/15 min i 

30-29 

20-19 

10.0-9 

40-39 

130-29 

9 20-19 

1 10.0-9 

2 5M 0 

3 

4 40-39 

5 30-29 

6 20-19 

710.0-9 

8 5M 0 

19 

10 20-19 

2120-19 

22 20-19 

23 20-19 

24 

25(20-19-968 . 

26 

B 

organic 

amp. 

meci2 

neon 

toluene 

i 

meoh 

! 

i 

mecl2 

PRESTESTILS 

i 

i 

c 

system 

vol. cu.fL 

i 

i 

i 

i 

1229 

.... . 4 

1229 

1229 

2460 

3690 

6 1! 

39C 

122! 

0 

eakrate 

bs/hour 

i 

i 

! 

13.3 

18.2 

29.2 

0.98 

1.21 

1.58 

2.34 

2.96 

-* 

0.61 

0.75 

0.98 

1.42 

1.76 

3.17 

4.76 

0.7S 

0.i 

0.! 

i 

m 

Paqel 
P.36 

*************************** JOB NO.:9381 

•ELI LILLY VENT EMISSIONS * DATE: 4/19/90 

*************************** 3Y« KDD 

REV.l 

PROCESS OPERATION: EVACUATION w/o CONDENSER (IDEAL MIXTURES) 

STEP: EQUIVALENCY SYSTEM PRESSURE TEST 

(1 PSIG PRESSURE DROP IN 15 MIN.) 

VAPOR PRESSURE CHART (mm Hg) 

METHYLENE 

CHLORIDE 

M.W. 

ANTOINE COEFF.: 

a 

b 

c 

84.933 

16.3029 

2622.44 

-41.7 

PROCESS CALCULATIONS 

1. DETERMINE LIQUID/VAPOR COMPOSITION IN THE REACTOR WHICH DETERMINES 

THE VAPOR COMPOSITION GOING TO ATMOSPHERE. 

METHYLENE 

CHLORIDE 

INPUT THE FOLLOWING DATA MARKED WITH AN (•): 

•POUNDS PRESENT 10 RESIDUAL 

IN VESSEL 

•TEMPERATURE(degC) 20 

•INITIAL SYSTEM 1795 (20 PSIG) 

PRESSURE (mmHg) -' 

•FINAL SYSTEH-j^: 1743 (19 PSIG) 

PRESSURE (nmHgy 

+++»• f++++f+4 ++++++++++++++4H-++4H-++++ + +++++++H^ ^ ¥ + + I f H-++++4 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

#MOLES 0.117739 

TOTAL MOLES 0.117739 

LIQUID 1 

MOLE FRACTION 

4- l-H I I i I I I I I I I I I It I I I I I H I I I I I I f ++++++++++++-H-4- MltHIIII H 

INITIAL CONDITIONS: 
P.37 

TEMPERATURE(dpg K) 293 

VAPOR PRESSURE 

(mmHg) 

IDEAL K 

VAPOR MOLE 

FRACTION(yi) 

calculated 

TOTAL yi 

calculated 

yi corrected 

(w/o INERTS) 

TOTAL yi 

corrected 

Pvp^xi 

(ppVOC) 

TOTAL 

Pvp^xi 

353.3307 

0.196841 

0.196841 

0.196841 

1 

1 

353.3307 

353.3307 

FINAL CONDITIONS: 

IDEAL K 

VAPOR MOLE 

FRACTION(yi) 

calculated 

TOTAL yi 

calculated 

yi corrected 

(w/o INERTS) 

TOTAL yi 

corrected 

Pvp^xi 

(ppVOC) 

TOTAL 

Pvp*xi 

0.202714 

0.202714 

0.202714 

1 

1 

353.3307 

353.3307 

f ¥+ I I It f4.4H-4-4HH-4-4-+4HH-4-4~H-4--H-4-4H-4-4-4-4--f4-4-4-I I I t II 1 I M M I I I I I I I t M I t- |--H-H-H-H-H-» 

AT THIS POINT, THE NITROGEN MOLES/HR SHOULD BE CALCULATED FOR THE 

SPECIFIC STEP AND THE TOTAL MOLES OF SOLVENT CALCULATED. THE TOTAL MOLES 

OF SOLVENT MULTIPLIED BY Yi WILL. GIVE INDIVIDUAL MOLES OF EACH COMPONENT 
P.38 

IN THE VAPOR PHASE IN EQUILIBRIUM AT A SPECIFIC PRESSURE AND TEMPERATURE. 

2. CALCULATE THE #/HR OF INERTS BEING DISPLACED. 

METHYLENE 

CHLORIDE 

I I I I I I I I I I I I I I I I I II4-4-1 I I M I H 4-4-4-4-4-4-4-4-4-4-4-4H-4-4-4-4-4-4-4-4-4-4-4-4- lllllll l 4-4-4-4-4-4-+-H-4-4-4-4 

INPUT THE FOLLOWING DATA MARKED WITH AN (•) : 

• M.W. OF INERT 29 

•EVACUATION TIME 15 

(MINS) 

•VAPOR SPACE, CF 1229 

I I I I- I I I- I I I I I I l4-4-4-4-4-4-4-4^H-4-4H-4-4-4-4-4-4-4-4-4-H-4-4-4-4H-4-4-4-4-4-4-4-4-4-4-4-l I I I I I I I I 4-4-4-» I I f+4-4-4-4 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

PARTIAL PRESSURE 1441.669 

OF INERT (nmHg) 

INITIALLY 

PARTIAL PRESSURE 1389.669 

OF INERT (nnaHg) 

FINALLY 

LN(PPi/PPf) 0.036735 

LOG MEAN 1415.510 

PARTIAL PRESSURE 

y inerts 0.803158 

INITIALLY 

y inerts 0.797285 

FINALLY 

MOLES OF INERTS 0.218334 

DISPLACED 

#/HR INERTS 25.32678 

DISPLACED 

HIHItll^ltlfH-I H I-4444-4444 t I-4-4-4-44444-4-4-4H-4-4-4-4-4-4 4 f 44 f 444+4-444-444444 f44-4-4-4-4 

3. CALCULATE THE VOC RATE OUT OF THE VESSEL. 

METHYLENE 

CHLORIDE 

I I I I I \ t \ I I I I M M I I I I I » I M I I M I I I I I I I I I I I I I I I I H 4 M I I 1-4 I lllllll l I4-444 4 44-4-4-4-4-4 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

# VOC 4.628785 

#/HR VOC 18.51514 
P.39 

*************************** 

•ELI LILLY VENT EMISSIONS • 

*************************** 

PROCESS OPERATION: 

STEP: 

JOB NO.:9381 

DATE: 5/15/90 

BY: KDD 

REV.l 

EVACUATION w/o CONDENSER (IDEAL 

EQUIVALENCY SYSTEM PRESSURE TEST 

(1 PSIG PRESSURE DROP IN 15 MIN.) 

VAPOR PRESSURE CHART (mm Hg) 

METHYLENE 

CHLORIDE 

M.W. 

ANTOINE COEFF.: 

a 

b 

c 

84.933 

16.3029 

2622.44 

-41.7 

PROCESS CALCULATIONS 

1. DETERMINE LIQUID/VAPOR COMPOSITION IN THE REACTOR WHICH 

THE VAPOR COMPOSITION GOING TO ATMOSPHERE. 

METHYLENE 

CHLORIDE 

INPUT THE FOLLOWING DATA MARKED WITH AN (•): 

•POUNDS PRESENT 10 RESIDUAL 

IN VESSEL 

•TEMPERATURE(degC) 

•INITIAL SYSTEM 

PRESSURE (mmHg) t 

20 

1794 (20 PSIG) 

•FINAL SYSTEM^ 1792.6 (19.968 PSIG) 

PRESSURE (mnHS9r£ 

+4-+++4-+4-4-++4-+4-4-4-4-4-++4-4-4-4-+4-4-+4-4-+4-++4-++++^ 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

#MOLES 

TOTAL MOLES 

LIQUID 

MOLE FRACTION 

0.117739 

0.117739 

1 

INITIAL CONDITIONS: 
P.40 

TEMPERATURE(deg K) 293 

VAPOR PRESSURE 

(mmHg) 

IDEAL K 

VAPOR MOLE 

FRACTION(yi) 

calculated 

TOTAL yi 

calculated 

yi corrected 

(w/o INERTS) 

TOTAL yi 

corrected 

Pvp^xi 

(ppVOC) 

TOTAL 

Pvp^xi 

353.3307 

0.196951 

0.196951 

0.196951 

1 

1 

353.3307 

353.3307 

FINAL CONDITIONS: 

IDEAL K 

VAPOR MOLE 

FRACTION(yi) 

calculated 

TOTAL yi 

calculated 

yi corrected 

(w/o INERTS) 

TOTAL yi 

corrected 

Pvp^xi 

(ppVOC) 

TOTAL 

Pvp^xi 

0.197105 

0.197105 

0.197105 

1 

1 

353.3307 

353.3307 

+++4»+++4H-4-4-4-4-4-4-+4-4-4-4-4-4-+4-4-4-4-4-4-4-+4-++++^ 

AT THIS POINT, THE NITROGEN MOLES/HR SHOULD BE CALCULATED F 

SPECIFIC STEP AND THE TOTAL MOLES OF SOLVENT CALCULATED. TH 

OF SOLVENT MULTIPLIED BY Yi WILL GIVE INDIVIDUAL MOLES OF E 
P.41 

IN THE VAPOR PHASE IN EQUILIBRIUM AT A SPECIFIC PRESSURE AN 

2. CALCULATE THE #/HR OF INERTS BEING DISPLACED. . 

METHYLENE 

CHLORIDE 

INPUT THE FOLLOWING DATA MARKED WITH AN (•): 

• M.W. OF INERT 29 

•EVACUATION TIME 15 

(MINS) 

•VAPOR SPACE, CF 1229 

++++4-4-4-4-4-++++4-4-4-4-4-++4-+++4-4-++++++++++4-++4+4-4-+++++++++4-4-4-T+4-4-

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

PARTIAL PRESSURE 1440.669 

OF INERT(mmHg) 

INITIALLY 

PARTIAL PRESSURE 1439.269 

OF INERT(mmHg) 

FINALLY 

LN(PPi/PPf) 

LOG MEAN 

PARTIAL PRESSURE 

y inerts 

INITIALLY 

y inerts 

FINALLY 

MOLES OF INERTS 

DISPLACED 

#/HR INERTS 

DISPLACED 

0.000972 

1439.969 

0.803048 

0.802894 

0.005878 

0.681875 

3. CALCULATE THE VOC RATE OUT OF THE VESSEL. 

METHYLENE 

CHLORIDE 

++++++4-4-4-++4-4-4-4-+4-4-++4-4-4-4-++4-4-+4-4-4-4-+-l-+++4-+^ 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

# VOC 

#/HR VOC 

0.122504 

0.490017 
P.42 

APPENDIX D: 

EQUIVALENCY COMPARISON 

The leakrate from EPA Emission Factors for Process Z was 

determined to be 0.50 Ib/hr (for calculation see Appendix B). The 

total pounds of VHAP emission using a time in service factor from 

Batch Process Z would be: 

0.5 (Ib/hr) x 4.5 (hr/lot) x 449 (lots/yr) = 1010 lbs/ yr. 

The leakrate from a 1 PSIG drop in 15 minutes for Batch Process Z is 

18.5 Ib/hr (for calculation see Appendix C). The total pounds of 

VHAP using a time in service factor would be: 

18.5 (Ib/hr) x 4.5 (hr/lot) x 449 (lots/yr) = 37.379 lbs/ vr. 

If the pressure drop had been 0.03 PSIG in 15 minutes, the loss 

would have corresponded to roughly 1000 lbs/year cited above. 

Thus, a pressure loss of 0.03 PSIG/15 minutes in this system 

demonstrates equivalency. 
P.43 

*************************** JOB NO.:9381 

•ELI LILLY VENT EMISSIONS • DATE: '6/4/90 

*************************** BY: KDD 

REV.l 

PROCESS OPERATION: EVACUATION W/o CONDENSER (IDEAL MIXTURES) 

STEP: EQUIVALENCY SYSTEM PRESSURE TEST 

VAPOR PRESSURE CHART (mm Hg) 

METHANOL 

M.W. 

ANTOINE COEFF.: 

a 

b 

c 

32.042 

18.5875 

3626.55 

-34.29 

PROCESS CALCULATIONS 

1. DETERMINE LIQUID/VAPOR COMPOSITION IN THE REACTOR WHICH DETERMINES 

THE VAPOR COMPOSITION GOING TO ATMOSPHERE. 

METHANOL 

INPUT THE FOLLOWING DATA MARKED WITH AN (•): 

•POUNDS PRESENT 10 RESIDUAL 

IN VESSEL 

•TEMPERATURE(degC) 20 

•INITIAL SYSTEM 1795 (20 PSIG) 

PRESSURE (mmHg) 

•FINAL SYSTEM 1779 (19.70 PSIG) 

PRESSURE (mmHg) 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

#MOLES 0.312090 

TOTAL MOLES 0.312090 

LIQUID 1 

MOLE FRACTION 

INITIAL CONDITIONS: 
TEMPERATURE(deg K) 293 

VAPOR PRESSURE 

(mmHg) 

IDEAL K 

VAPOR MOLE 

FRACTION(yi) 

calculated 

TOTAL yi 

calculated 

yi corrected 

(w/o INERTS) 

TOTAL yi 

corrected 

Pvp^xi 

(PPVOC) 

TOTAL 

Pvp^xi 

96.51329 

0.053767 

0.053767 

0.053767 

1 

1 

96.51329 

96.51329 

FINAL CONDITIONS: 

IDEAL K 0.054251 

VAPOR MOLE 0.054251 

FRACTION(yi) 

calculated 

TOTAL yi 0.054251 

calculated 

yi corrected 1 

(w/o INERTS) 

TOTAL yi 

corrected 

Pvp^xi 

(ppVOC) 

TOTAL 

Pvp^xi 

1 

96.51329 

96.51329 

-+++++ 

AT THIS POINT, THE NITROGEN MOLES/HR SHOULD BE CALCULATED FOR THE 

SPECIFIC STEP AND THE TOTAL MOLES OF SOLVENT CALCULATED. THE TOTAL MOLES 

OF SOLVENT MULTIPLIED BY Yi WILL GIVE INDIVIDUAL MOLES OF EACH COMPONENT 
P.45 

IN THE VAPOR PHASE IN EQUILIBRIUM AT A SPECIFIC PRESSURE AND TEMPERATURE. 

2. CALCULATE THE #/HR OF INERTS BEING DISPLACED. 

METHANOL 

INPUT THE FOLLOWING DATA MARKED WITH AN (•): 

• M.W. OF INERT 29 

•EVACUATION TIME 15 

(MINS) 

VAPOR SPACE, CF 1229 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

PARTIAL PRESSURE 1698.486 

OF INERT(mmHg) 

INITIALLY 

PARTIAL PRESSURE 1682.486 

OF INERT(mmHg) 

FINALLY 

LN(PPi/PPf) 0.009464 

LOG MEAN 1690.474 

PARTIAL PRESSURE 

y inerts 0.946232 

INITIALLY 

y inerts 0.945748 

FINALLY 

MOLES OF INERTS 0.067179 

DISPLACED 

#/HR INERTS 7.792857 

DISPLACED 

++++++++++4+44+4++++++4++44+++++++++4+++++++4+4-4-4-+4++++++++4+++44+++++4++++ 

3. CALCULATE THE VOC RATE OUT OF THE VESSEL. 

METHANOL 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

# VOC 0.122895 

#/HR VOC 0.491583 
P.46 

ATTACHMENT 10 

[NOTE: This is a draft outline in regulatory language. Any values in blanks 

are examples only, and do not represent consensus.] 

(a) The owner or operator of a batch process may elect to use the provisions 

of this section or LDAR to comply with the requirements of this subpart. 

(b) Batch process and Batch product-process will be defined in the subpart 

as - -

Batch Process means a process which is intermittent or discontinuous and 

the vast majority of individual items of equipment is infrequently in 

VHAP service. The equipment is fed intermittently or discontinuously. 

Processing then occurs in this equipment after which the equipment is 

generally emptied. Only batch process equipment in use with a hazardous 

air pollutant less than 80% of the total available time (8,760 

hours/year) is eligible for treatment under Section of this rule. 

Examples of industries that use batch process include pharmaceutical 

manufacturers and pesticide manufacturers. 

Batch Product-Process means the collection of equipment (e.g., reactors, 

valves, pumps, etc.) configured to produce a specific product by a batch 

process. 

(c) Each owner or operator electing to use pressure testing shall comply 

with the following requirements: 

1. Each time equipment is reconfigured for batch production of a 

product (i.e., for each batch product-process) and each time a 

seal is disconnected ("broken"), the batch product-process 

equipment shall be pressure tested before VHAP is first fed to the 

equipment. At a minimum each batch product process shall be 

pressure tested [for example, 1] times per year. 

2. The process equipment shall be pressurized using air, nitrogen, or 

' water to the maximum operating pressure of the equipment for the 

period of the test. The test shall be conducted for 

minutes. 

3. A leak is defined as a pressure drop of more than ffor example. 

0.03 psig/15 mini or visible, audible or olfactory evidence of 

fluid loss. 

[NOTE: It would be preferred if the rule specified a generic 

pressure loss criterion for all batch processes or an equation to 

calculate the pressure loss representing a leak. To require 

demonstration of equivalency for every batch process would result 

in an unworkable provision.] 

4. If a leak is detected, the equipment shall be repaired and 

retested before startup of the process. 

5. Any system that fails the retest must be repaired within 30 days 

unless it can be documented that the replacement part is 

unavailable. In the latter case, the repair must be made within 

10 days of the delivery date of the replacement part. 
P.47 

(d) Each owner or operator who elects to use LDAR to comply with this 

subpart shall: 

1. Screen equipment when the equipment is in VHAP service or in use 

with an acceptable surrogate volatile organic compound which is 

not identified as a VHAP ,or in use with any other detectable 

gas/vapor, (e.g., the equipment may be pressurized with any 

detectable gas and LDAR performed). 

2. Monitor equipment at the frequency calculated in the equation 

below or once per year, if the calculated frequency is less than 

1. 

f — T x F 

•*-b -"-op •"• *• continuous 

Where 

fb - screening frequency for batch operations 

Top - average time equipment is in VHAP service in the 

previous year, expressed as percentage of 

8760 hours 

Fcontmuous = monitoring frequency specified for 

equipment in continuous service, (e.g., once 

per 90 days; once per 30 days). 

RECORDKEEPING REQUIREMENTS FOR BATCH PROCESSES 

Additional Requirements -

Each owner or operator who elects to use the provisions for batch 

processes shall maintain records demonstrating that equipment is in 

batch product-processes. Such records might consist of documentation of 

batch product-processes that have equipment in >5% VHAP service and 

documentation that would show that a typical batch cycle conforms to the 

definition of batch, specified in § . 
P.48 

ATTACHMENT 11 

American Petroleum Institute 

1220 L Street, Northwest 

Washington, D.C. 20005 

202-682-8000 

% > 

MEMORANDUM 

DATE: June 8, 1990 

TO: HVOC FUGITIVE EMISSIONS REGULATORY NEGOTIATION COMMITTEE 

FROM: Larry Goodheart, A^********** 

Linda Curran &*cU, &4Si*xtM, ^ 

SUBJECT: Suggested Agreement/Preamble Language 

In my letter dated June l, 1990, I sent you draft language 

for the agreement and preamble that would explain the 

relationship between the regulation being negotiated for SOCMI 

categories and the expected subsequent regulation of fugitive 

emissions of HAPs from petroleum operations. It is very 

important to API and Amoco that both the preamble and the 

agreement contain a short discussion of this issue. 

During the June 6-7 negotiating session, the suggested 

language underwent several revisions. Finally, EPA and API 

agreed (subject to back-home approvals) that the language set 

forth below would be acceptable. Please call me at (414) 

620-4145 or Ellen Siegler at (202) 682-8271 if you have any 

comments on this language. (If you prefer, you may fax comments 

to me at (415) 620-5320 or Ellen at (202) 682-8033. 

Potential Applicability of Standard to Refinery Categories 

The standards incorporated in this Agreement were established 

by the Negotiating Committee based primarily on data from the 

best-performing ethylene oxide plants and data from a few other 

SOCMI plants. The Committee did not review data from petroleum 

refining processes because they were outside the scope of the 

negotiations, and the Committee does not know whether the numeric 

standards incorporated in this agreement are achievable by 

refinery processes. It is agreed that the regulatory framework 

of the negotiated regulation should be used when EPA develops 

MACT regulations for those petroleum processes that are to be 

regulated under Title III of the Clean Air Act. However, the 

Committee believes that there are technical differences between 

SOCMI categories and petroleum operations that may affect the 

achievability of the numerical standards (percent leakers). 

Potential differences include the availability and effectiveness 

of emission control technologies, plant shutdown practices, line 

An equal opportunity employer 
P.49 

sizes, process temperatures and pressures, and cost. 

If any regulatory authority representated on the Committee 

develops regulations, applicable to refineries, similar to these 

negotiated by the Committee, it will conduct a separate 

rulemaking. The achievability of the standards (including 

percent leakers) will be one of the elements considered in the 

rulemaking. 
P.50 

1990—ASQC QUALITY CONGRESS TRANSACTIONS—SAN FRANCISCO 

FUGITIVE EMISSIONS: 

AN UNTAPPED APPLICATION FOR TQC 

. R. L. Berglund J. L. Hansen 

Union Carbide Chemicals and Plastics Company Inc. 

South Charleston, WV 25303 

ABSTRACT 

At the dawn of the quality era, J. M. Juran developed the concept of the second or 'hidden' 

plant from the understanding that as a facility creates a product, the second or hidden plant is 

creating waste. The real significance of this second or 'hidden' plant is now becoming recognized 

as many companies commit to an aggressive program to minimize the impact of their operations on 

employee and community health and the environment. Yet, while both the 'hidden' plant concept and 

the principles of Total Quality Control (TOO are well understood in the manufacturing and service 

areas, they remain virtually unrecognized in the area of environmental control. 

An area to which the TQC principles can be directly applied is that associated with fugitive 

emissions from equipment leaks. Losses of organic compounds through leaks from process equipment 

(valves, pumps, flanges) in a typical chemical plant have historically been estimated to be in the 

range of 500 to 1500 g/Mg (g emissions/million g product made). From an economic standpoint, such 

losses have represented a small fraction of production, were generally acceptable, and often were 

ignored. From an environmental standpoint, such losses need to be reassessed, in terms of the 

magnitude of these losses, and in the appropriate tools for improving the production system to 

reduce these losses. 

To assess the situation, in 1988, massive surveys of equipment leaks in the acrolein, ethylene 

oxide, butadiene and phosgene production industries were undertaken. Nearly 92,000 components at 

30 different companies were monitored. The screening results were matched with a detailed 

industrywide survey of the design, monitoring and maintenance practices of the plants. Based on 

these studies, specific guidelines for determining fugitive emissions from facilities were 

outlined, and selected Benchmark operations in valve and pump selection, maintenance and Inspection 

were determined. Using these insights, a long-term TQC program to reduce fugitive emissions from 

equipment leaks is outlined, and additional opportunities for quality improvement are documented. 

INTRODUCTION 

What are fugitive emissions? Fugitive emissions are low-level diffuse Volatile Organic 

Compound (VOC) emissions that occur when process fluid (either gaseous or liquid) escapes from 

plant equipment such as valves, flanges, pumps, and compressors into the atmosphere. Both 

industrial and regulatory groups are trying to determine sources of Volatile Organic Compounds 

(VOCs) releases into the environment. As a class, such compounds are believed to be precursors In 

the formation of troposphen'c ozone or smog in urban areas, while some specific chemicals are of a 

high level of additional concern because of their toxicity, explosivity, or flammability. 

Although a typical chemical process unit may contain thousands of pieces of equipment, each of 

which can serve as a potential fugitive emissions source, most fugitive emissions will be contributed by only a small fraction of the possible sources. Because there have been many questions 

over the sources, causes, and controls of .fugitive emissions, programs to study fugitive emissions 

were initiated in the 1950's in the Los Angeles area, which led to nationwide studies in the 

chemical and refining industries in the 1970's. But, interest waned in the late 1970's after the 

US Environmental Protection Agency published a series of factors for estimating fugitive emissions, 

and initiated a special program of Leak Detection and Repair (LDAR) for controlling fugitive 

emissions from regulated sources. These generic factors and the control program were focused on 

what can best be termed the 'Special Causes' of fugitive emissions. This leakage was caused by 

unit upsets, inadequate maintenance, misdirected monitoring and inspection, inattention, lower 

quality design, and unconcern by the unit management. The control strategy was focused on regular 

monitoring for these 'special' (bigger) leaks and subsequently repairing them. Using the generic 

factors, i t would be estimated that fugitive emissions losses from a typical chemical process 

Copyright Q l 990 Union Carbide Chemicals and Plastics Company Inc. 

All Rights Reserved 
P.51 

, 1990—ASQC QUALITY CONGRESS TRANSACTIONS—SAN FRANCISCO 

facility would be small relative to the overall production, of the order of 500 to 1500 g/Mg (grams 

emissions/million grams product made). By directing the detection and repair program to these 

'special' leaks, emissions would be reduced by about two-thirds. 

There are questions over the validity of applying a generic fugitive emission factor and 

control program to the entire chemical process industry. Independent of any regulatory guidance, 

for safety or economic reasons, most process units handling chemicals which are toxic, explosive, 

or otherwise hazardous, already implement special guidelines for monitoring and inspection of 

operating equipment or specifically design equipment to limit organic losses. Few units handling 

toxic or hazardous chemicals were included in the data base used to generate the commonly used 

emission factors. Furthermore, the earlier programs were not focused enough to allow the 'common 

causes' of fugitive emissions to be determined once the 'special causes' were removed, nor could 

they be used to evaluate the methods appropriate for mitigation of these causes. However, such 

methods can be developed from an effective Total Quality Control (TQC) program, the organization of 

which would consist of 1) setting standards, 2) appraising conformance, 3) taking corrective 

action, and 4) planning for improvement. 

SETTING STANDARDS 

A major activity which will be strongly Influencing future operating programs within much of 

the chemical process industry is the 'Responsible Care' program of the Chemical Manufacturers 

Association (CMA), through which 'Industry moves to improve management of chemicals.' One aspect 

of this program, designed for local implementation, encourages member companies to reduce 

environmental releases from their facilities by using the following process: 1) inventorying 

releases to all media, 2) evaluating release reduction opportunities and establishing priorities, 

3) formulating release reduction plans, and 4) periodically communicating progress and future plans 

to employees and the public. 

The CMA Responsible Care program is important to the chemical Industry, yet many chemical 

companies have developed their own programs to either implement or supplement the CMA activity. In 

looking to the future. Union Carbide "has committed itself to getting exposure levels of 

potentially harmful chemicals in our communities to at least 1,000 times lower than workplace 

standards set by the Occupational Safety and Health Administration, or our own standards, whichever 

are tougher. Union Carbide's goal, as existing technology and operating practices are upgraded, is 

complete elimination of emissions of known or suspect carcinogens." 

Such a commitment requires that fugitive emission sources be found and corrected. 

APPRAISING CONFORMANCE 

A typical chemical process unit wil l contain somewhere in the range of 4,000 components, each 

of which could starve as a source of fugitiv e emissions leakage. These components Include flanges 

(60*), valves in gas service (28X), valves in liqui d service (9%), pumps (0.5%), safety valves 

(0.5S), and open-ended lines [2%). Determining fugitive emission leakage from thousands of 

components on a unit would require that each individual component be wrapped and sampled, a costly 

complex logisti c nightmare. To help simplify the problem, the EPA provided industry with a number 

of less rigorous alternatives for estimating fugitive emissions. One Is to screen the component 

with an organic vapor analyzer (OVA), and estimate emissions from a scatter plot lik e that in 

Figure 1. 

Figure 1: EPA Scalier Plot of Log Leak Rate vs. Log OVA Reading 

Valves-Liquid Service 

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P.52 

1990—ASQC QUALITY CONGRESS TRANSACTIONS—SAN FRANCISCO 

In 1988, CMA, with support from the EPA, initiated industrywide fugitive emissions studies to 

better understand existing levels of fugitive emissions. Four chemical production industries were 

studied: acrolein,' 1,3-butadiene, ethylene oxide, and phosgene, during which over 92,000 components were screened. The participants in these studies were located in nine different states, 

but, two-thirds of the units, and all the butadiene units were located in Texas or Louisiana. 

Included in this effort were all valves, pumps, and compressors, safety valves and a statistical 

sampling of flanges, and other connectors. Because of the extent and the completeness of these 

studies, the results have provided the participants with the unique opportunity to compare the 

practices and programs in place in these industries as they affect fugitive emissions. 

The OVA screening measurements, in ppm, obtained in these studies are summarized below. The 

distribution of 'Leakers' for four critical component types is shown in Figure 2. 

Acrolein (4573) 

Butadiene (43581) 

Ethylene Oxide (17563) 

Phosgene (25743) 

4541 

32941 

15258 

25586 

< TOO 

23 

8300 

1811 

117 

<M000 

3 

859 

281 

40 

Leakers 

< 10,000 > 10,000 

3 

764 

111 

0 

2 

717 

101 

0 

EPA Study (24 Plana) 

lutndiene industry (13 Ptanii) 

Ethylene Oildaa Industry (12 Ptima) 

AcroMn mdiaBy (2 Plants) 

Phoscene Industry (13 Plants) 

Vatwa 

(Uqutd S*rvlc«) 

Valv. . 

fOai S*raK«) 

Figure 2: A Comparison ol Leak Frequencies for Critical Components 

In Acrolein, Butadiene, Ethylene Oxide and Phosgene Industries 

Relative to the Original EPA Studies 

By regulatory definition, a 'Leaker' is a component with an OVA screening measurement above 

10,000 ppm. Overall, about 0.04% (3 out of 4536), of the components in the acrolein unit, 0.61 

(102 out of 17563) of the components screened in the ethylene oxide units and 1.65% (717 out of 

43581) of the components screened in the butadiene units would be classified as 'Leakers.' This 

'leaking' equipment accounted for about 90% of the total emissions measured in the acrolein 

industry, 70% of the total emissions measured in the ethylene oxide industry, and 60% of the total 

emissions measured in the butadiene industry. There were no 'Leakers' in the phosgene industry. 

All of these 'leaking' sources were promptly repaired. From previous EPA studies, i t would have 

been expected that 6% of the components would have been 'Leakers.' 

Of all the components screened, 99.8% of the components in the phosgene unit, 98.6% of those 

in the acrolein units, 86% of those in an ethylene oxide unit, and 75% of those in a butadiene unit 

had screening values less than 10 ppm (hear lower level of detection with background air, 0.2 ppm 

for phosgene). 

From the screening data obtained in these studies and the appropriate correlation curve, a new 

set of Industry specific fugitive emissions factors were developed for the components in the four 
— _ P.53 

1990—ASQC QUALITY CONGRESS TRANSACTIONS—SAN FRANCISCO 

production industries. With a few exceptions, for most component types, all the plants in the 

butadiene industry were higher than any of the plants in the ethylene oxide industry which in turn 

were all higher than any of the plants in the phosgene industry. The total emissions for these 

industries (as a percentage of the EPA estimates, and as a fraction of the overall production, 

g/Mg) can be summarized as follows: 

Industry 

EPA Avg 

Butadiene 

Ethylene Oxide 

Acrolein 

Phosgene 

Relative to 

EPA Study 

100 % 

33 % 

10 % 

0.05% 

0.01% 

Relative To 

Production 

500-1500 g/Mg 

450 g/Mg 

35 g/Mg 

0.5 g/Mg 

0.1 g/Mg 

This represents a difference of nearly four orders of magnitude between the four Industries. 

The critical question that continues to remain after examining these trends was: 

"What Is the Difference that Makes the Difference" 

between these industries. 

To evaluate the different 'practices' used by the four industries which might explain these 

trends, and to determine the best 'Benchmark' operations for assuring low fugitive emissions, a 

survey was prepared and distributed to all the participants in these studies. This survey focused 

on the three fundamental aspects of fugitive emissions control: (1) programs for monitoring for a 

leak, (2) practices for maintaining equipment or repairing the leak, once It is detected, and (3) 

procedures for preventing the occurrence of a leak through special design standards. The results 

of this indicate that there are differences between these industries with respect to the 

volatility, corrosivity, acute toxicity and molecular properties of the chemicals of concern and 

the operating pressure, temperatures, and cycles of the different processes. All of these may have 

some impact on the ultimate fugitive emissions levels achieved. It appears that these measured 

levels were reached by the different industries as an indirect consequence of their existing 

internal and external programs for safety, employee health, exposure, and environmental control. 

The Benchmark facilities, the producers of acrolein, phosgene and in many cases, ethylene 

oxide, apparently recognizing the potential acute health hazards of these chemicals seem to be 

operating from a strategic plan which assures that fugitive emissions from the components which 

handled these chemicals are low. This overriding strategy is simply that equipment leaks are not 

tolerated. Over a period of years these industries have developed special tactics In the areas of 

maintenance, monitoring and design necessary to achieve the desired results. Some of these tactics 

are: 

Monitoring: In the Benchmark plants, the unit staff is trained to be 

sensitive to leaks, and the operators are constantly looking fpr leaks. 

Maintenance: Leaks are promptly repaired, shutting down the unit as 

necessary. 

Design: Units are designed to minimize leakage, to allow rapid shutdown 

and startup, and to minimize number of components. Vendors are evaluated 

and compoents are tested before and during installation. A leakless 

design, when used, is focused on critical areas. 

Overall, several key points can be made with respect to these Benchmark operations. 

1) Today's performance in the Benchmark units didn't just happen overnight, low fugitive emissions* are the cumulative results of years of 

record keeping, analysis, and effort. 

2) Low fugitive emissions are achieved primarily through the use of 

conventional technology, not necessarily by universal application of new 

leakless technology. 

3) New technology is selectively used where it makes good engineering 

sense. 
P.54 

1990—ASQC QUALITY CONGRESS TRANSACTIONS—SAN FRANCISCO 

The main theme that pervades the programs in use in the Benchmark industries Is that while they 

may use advanced technology, the achievement of low levels of fugitive emissions is a result of 

paying attention to the details of the operation, and responding in an appropriate manner to any 

leakage. The conclusion that can be reached is that a TQC program to assure low fugitive 

emissions must begin and end with the operations staff In the process unit with continuous 

improvement being sought and measured. But, because fugitive emissions from the majority of the 

chemical industry are not yet in a state of statistical control, the results from the Benchmark 

industries cannot be directly extended to other chemical units. Many of the operations have not 

considered the problems associated with fugitive emissions, so no effort has been made to 

differentiate the 'special causes' from the 'common causes' of fugitive emissions. Only after the 

special causes, such as inattention and poor maintenance, are identified and corrected can the 

various industries determine the total effort that will be required to achieve low fugitive 

emissions for their existing set of process characteristics (such as pressure, temperature, size, 

original design, or operating cycle). 

Total Quality Costs: The differences between the four industry groups can be further 

explained from an updated assessment of the Total Costs of Poor Quality. From a fugitive emissions 

perspective, the Internal and External Failure Costs would be the costs associated with defects 

that result in fugitive emissions releases. These would disappear if there are no leaks. These 

costs include: 

Regulatory penalties 

OSHA violations 

Community odors 

Employee and conmunlty health 

Explosions 

Respiratory protection 

Waste material 

Community goodwill 

Appraisal Costs would be the costs incurred to monitor the operation for defects and fugitive 

emissions, while the Prevention Costs would be the costs incurred to prevent leaks from 

occurring. In the Benchmark industries (phosgene, acrolein) the Costs of Poor Quality can be 

substantial, relative to the other industries. Hence, management saw the need for appraisal and 

prevention programs, and, after years of effort, the appraisal and prevention costs in these 

Industries are comparatively lower. 

Fugitive Emissions and Zero Defects. Many units report that they have zero leaks. From a 

regulatory standpoint, this can mean simply that all of the screened components would be within the 

acceptable limit of the regulation, that no component has a screening value above 10,000 ppm 

(Figure 3). Yet, such a bright line to determine when a component should be repaired does not 

appear to assure low fugitive emissions. Better would be to recognize the 'loss function' concept 

as It applies to fugitive emissions. In this case, while the leakers would be repaired, as 

required by regulation, all components with screening values above some acceptable optimum would be 

given some attention. The relative loss or cost to society resulting from their continuing leakage 

would be compared to the costs associated with their ultimate repair. While the rate of Increase 

away from the optimum may change with different chemicals and different components types, a control 

strategy for fugitive emissions would not be limited to the 'leakers' (screening values above 

10,000 ppm), but would also address other components (Figure 4). 

LOSS NON-LEAKER 

(No Impact) 

Not Defective 

LEA&EB 

(Big Impact) 

Defective 

Emissions 

0 10,000 ppm 

Screening Value 

Optimum 

"Target1 

10,000 ppm 

Repair Zone 

Figure 3: Fugitive Emissions Regulations 

Using the Zero Defects Concept 

(The "Goal Post" Approach) 

Figure 4: Loss Function Approach 

For Assessing Fugitive Emission 

Source Contribution 
P.55 

1990—ASQC QUALITY CONGRESS TRANSACTIONS—SAN FRANCISCO 

TAKING CORRECTIVE ACTION 

There are three common causes of fugitive emissions from equipment: 1) component defects, 

2) installation errors, and 3) wearout, somewhat following the standard life characteristic 

('Bathtub') curve. In addition, there are numerous special causes, which may be associated with 

the environment, or the process, and may include simple random failures. 

The causes of fugitive emissions vary for the different process units. In some cases, leakage 

from the components was not detected, so they were simply not maintained. In other cases, hidden 

or latent defects in the design may be such that the component is not able to achieve the desired 

low leak levels, or the group of components may be at the end of Its life cycle. In the first 

case, simply initiating the monitoring and maintenance program would achieve the necessary 

reductions. In both of these latter cases, significant design and replacement changes would be 

warranted. In another case, the process operation may have caused a high stress on the component, 

and design changes in the process configuration itself may be warranted. The appropriate response 

can only be determined from an analysis of the historical component leakage data. 

Process Screening. The first step in determining the appropriate corrective action 1s to 

screen the components in the process unit for leakage (using an appropriate analyzer). The 

screening operation serves three functions: 1) it separates the acceptable components from the 

questionable and unacceptable components, 2) it focuses attention on the most severe leaking 

components warranting immediate attention, and those components warranting longer range attention, 

and may separate the 'special' cases from the 'common' leaks, and 3) it provides the best means of 

estimating fugitive emissions for the unit. 

Record Keeping. Developing a program of continuous improvement which focuses on the 

components with serious leakage (generally with screening values above 10,000 ppm), yet also 

assures that the majority of the acceptable components in the unit will not be adversely affected, 

requires that all activity regarding these components be well-documented (screening measurements, 

maintenance, replacement). This documentation would be useful: 1) for determining progress In 

reducing emissions, 2) for selecting the best suppliers, 3) for preparing an optimum installation 

and testing strategy, 4) for determining the most critical areas of the process that should receive 

future attention in the program, 5) for developing indicators which would tell when a particular 

component should be replaced, or repaired, 6) for determining if leakages can be attributed to 

common causes requiring a group response, or special causes requiring individual responses, and 7) 

for developing a Corrective Action Guideline (CAG) for responding to leak indicators. 

In a number of cases the appropriate corrective response 1s to not attempt to directly fix the 

leak, but to continue to monitor the leak, and plan for future improvement. The latter activity 

represents the fourth stage of the fugitive emissions control program. 

PLANNING FOR IMPROVEMENT 

A long-term program should consist of two focused activities: 1) the monitoring program, and 

subsequent data analysis, which represent the bulk of the Diagnostic portion of the program, and 

2) the Corrective Action Guidelines (CAGs) which represent the bulk of the Corrective or 

Improvement portion of the control program. 

To improve the cost, performance, safety, and reliability standards for the components In the 

participating unit such that low fugitive emissions are achieved, requires a concerted multidisciplinary focus. The immediate gains in applying a TQC plan to fugitive emissions will be 

achieved by the rapid repair of the components at serious leak levels, and replacement of these 

components should they pose continued problems. The long-term gains will be achieved by the 

continued study and ultimate repair and replacement of components at the lower leakage levels. In 

both cases, the records of the monitoring results, and the repair or replacement results should be 

documented, and analyzed using Statistical Process Control (SPC) principles. Components at low 

leak levels which do not yet warrant repaiV should be remonitored to assure that the magnitude of 

the leak does not increase. Similarly, components which are repaired should be remonitored to 

assure that the repairs were effective. Data from components of both high and low leakage should 

be studied to determine if the leakage is attributable to a special cause (specific to each 

component, likely warranting repair or replacement only) or to some common cause (multiple 

components with same problems, warranting a possible design change). The program can be successful 

only if adequate historical records of the monitoring, repair, and replacement activities are 

developed and appropriately analyzed. 
P.56 

1990—ASQC QUALITY CONGRESS TRANSACTIONS—SAN FRANCISCO 

NEW APPLICATIONS FOR TQC IN A FUGITIVE EMISSIONS PROGRAM 

The above analysis provides several key areas where the TQC concepts can be Incorporated In a 

fugitive emissions strategy. To be effective, such a program should: 

1) require rigorous data collection, and appropriate SPC analysis, 

2) promote continuous improvement, with initial activities maintained to 

assure low levels of fugitive emissions, while additional programs, based 

upon the data analysis, are developed to reduce emissions further, 

3) be established individually for each participating unit, focused on the 

desired final emission reduction goal, and 

4) dedicate appropriate resources on record keeping, monitoring, maintenance and design changes in the unit to ultimately assure low fugitive 

emissions. 

Controlling fugitive emissions from equipment leaks is but one area In which the chemical 

industry can strive for Environmental Excellence thru Quality. However, to be successful, such a 

program requires: 

1) leadership and commitment throughout the corporation, 

2) organization to provide training of the operations and engineering 

staff, such that they are continually sensitive to environmental concerns 

and knowledgeable in the use of quality measurement tools in an 

environmental control application, and 

3) recognition of Benchmark units that have achieved environmental 

excellence. 

Ultimately, the program will require Involvement by all aspects of the operations, 

maintenance, purchasing, engineering and research functions, if sustained continuous improvement 

in the operations is to be achieved such that the environmental goals are to be realized. 

BIBLIOGRAPHY 

1. Berglund, R. L., J. A. Mullins, L. S. Parrett, R. R. Romano, and J. L. Randall, "Equipment 

Leaks: Results of Industry-wide Studies of 1,3 Butadiene, Ethylene Oxide, and Phosgene 

Production Facilities," paper #89-120.4, proceedings of the 82nd Annual Meeting of the Air and 

Waste Management Association, June 30, 1989. 

2. Berglund, R. L., D. A. Wood, and T. J. Covin, "Fugitive Emissions from the Acrolein Production 

Industry," paper presented at the AWMA International Specialty Conference: SARA Title III, 

Section 313, Industry Experience in Estimating Chemical Releases, April 6, 1989. 

3. Byrne, D. and Taguchi, S. "The Taguchi Approach to Parameter Design," Quality Progress, 

December, 1987, p 20. 

4. Feigenbaum, A. V., Total Quality Control, Third Edition, McGraw-Hill Book Company, 1983, New 

York. 

5. Juran, J. M., Quality Control Hanbook, McGraw-Hill Book Company, Third Edition, 1974. 

6. United States Environmental Protection.Agency, Protocols for Generating Unit-Specific Emission 

Estimates for Equipment Leaks of VOC and HAP, Research Triangle Park, NC, Publication No. 

EPA-450/3-88-010, October 1988.