EPA-453/R-95-017



# 1995 Protocol for Equipment Leak Emission Estimates

Emission Standards Division

U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air and Radiation Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711

November 1995This report has been reviewed by the Emission Standards Division of the Office of Air Quality Planning and Standards, the EPA and approved for publication. Mention of trade names or commercial products is not intended to constitute endorsement or recommendation for use. Copies of this report are available through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711; from the Office of Air Quality Planning and Standards Technology Transfer Network, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711; or, for a fee, from the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.

Publication No. EPA-453/R-95-017FOREWORD

The EPA’s protocol for estimating equipment leak emissions is the result of detailed information gathering and data analysis. The protocol was written to provide a thorough understanding of acceptable approaches to generating process unit-specific emission estimates. In preparing this document, the EPA has encouraged knowledgeable individuals in industry and the regulatory community to provide comments. The EPA has put forth considerable effort to make this document as comprehensive as possible. However, it should be understood that not all details and topics pertaining to equipment leaks could feasibly be included in this document. Additionally, it should be understood that the procedures presented in this document are not necessarily suitable for all applications. There will be cases where it will be necessary for the user of the document to make a professional judgement as to the appropriate technical approach for collecting and analyzing data used to estimate equipment leak emissions. Additional data on equipment leak emissions continues to be collected. It is the intent of the EPA to periodically update this document after analysis of the data warrants such an update. For example, data recently collected in the petroleum industry has been used to revise the existing refinery correlations, which are based on data collected in the late 1970s. Furthermore, as new techniques for collecting and analyzing data are developed, they will be included in updated versions of this document. Mention of any manufacturer or company name within this document does not represent endorsement by the EPA.

iTABLE OF CONTENTS

Section Page

FOREWORD .......................... i

1.0 INTRODUCTIO N . . . . . . . . . . . . . . . . . . . . . . 1-1
2.0 DEVELOPMENT OF EQUIPMENT LEAK EMISSION ESTIMATE S . . . . 2-1

2.1 Introduction . . . . . . . . . . . . . . . . . . . 2-1 2.2 General Information on the Approaches for Estimating Equipment Leak Emission s . . . . . . . . 2-3
2.2.1 Equipment Leak Emission Estimation Approache s . . . . . . . . . . . . . . . . . 2-3 2.2.2 Overview of Equipment Leak Data Collection . 2-6
2.3 Approaches for Estimating Equipment Leak Emission s.................... 2-10
2.3.1 Average Emission Factor Approac h..... 2-10 2.3.2 Screening Ranges Approach

........ 2-18 2.3.3 EPA Correlation Approac h......... 2-24 2.3.4 Unit-Specific Correlation Approac h.... 2-38
2.4 Special Topics

................. 2-44
2.4.1 Speciating Emission s........... 2-45 2.4.2 Using Response Factor s.......... 2-46 2.4.3 Monitoring Instrument Type and Calibration Gas . . . . . . . . . . . . . . . . . . . 2-51 2.4.4 Estimating Emissions for Equipment Not Screene d................. 2-51 2.4.5 Using Screening Data Collected at Several Different Times

............. 2-52 2.4.6 Estimating VOC Emission Rates from Equipment Containing Non-VOC’ s........... 2-52 2.4.7 Estimating Equipment Leak Emissions of Inorganic Compounds

........... 2-53

2.5 References

................... 2-54

3.0 SOURCE SCREENIN G . . . . . . . . . . . . . . . . . . . . 3-1

3.1 Introduction . . . . . . . . . . . . . . . . . . . 3-1 3.2 Monitoring Instruments . . . . . . . . . . . . . . 3-2
3.2.1 Operating Principles and Limitations of Portable VOC Detection Device s . . . . . . . 3-2

iiTABLE OF CONTENTS (Continued)

Section Page

3.2.2 Specifications and Performance Criteria of Portable VOC Detection Device s . . . . . . . 3-4 3.2.3 Use of Monitoring Devices That Do Not Meet EPA Reference Method 21 Requirement s... 3-10
3.3 The Screening Progra m.............. 3-12
3.3.1 Identification of Equipment to be Screened 3-12 3.3.2 Procedure for Screening

......... 3-15 3.3.3 Data Handling

.............. 3-25

3.4 References

................... 3-27

4.0 MASS EMISSION SAMPLIN G . . . . . . . . . . . . . . . . . 4-1

4.1 Introduction . . . . . . . . . . . . . . . . . . . 4-1 4.2 Sampling Methods . . . . . . . . . . . . . . . . . 4-2

4.2.1 Vacuum Method . . . . . . . . . . . . . . . 4-4 4.2.2 Blow-Through Method . . . . . . . . . . . . 4-8

4.3 Source Enclosure

................ 4-15

4.3.1 Valve s.................. 4-15 4.3.2 Pumps and Agitators

........... 4-16 4.3.3 Compressors

............... 4-17 4.3.4 Connector s................ 4-17 4.3.5 Relief Valves

.............. 4-18
4.4 Analytical Technique s.............. 4-18
4.4.1 Analytical Instrumentatio n........ 4-19 4.4.2 Calibration of Analytical Instruments . . 4-19 4.4.3 Analytical Techniques for Condensat e... 4-21 4.4.4 Calibration Procedures for the Portable Monitoring Instrument

.......... 4-21
4.5 Quality Control and Quality Assurance Guidelines 4-21
4.5.1 Quality Control Procedure s........ 4-22 4.5.2 Quality Assurance Procedure s....... 4-25

4.6 References

................... 4-29
5.0 ESTIMATION OF CONTROL EFFICIENCIES FOR EQUIPMENT LEAK CONTROL TECHNIQUE S . . . . . . . . . . . . . . . . . . . 5-1

5.1 Introduction . . . . . . . . . . . . . . . . . . . 5-1

iiiTABLE OF CONTENTS (Continued)

Section Page

5.2 Equipment Modification Control Efficienc y . . . . . 5-1
5.2.1 Closed-Vent Systems . . . . . . . . . . . . 5-2 5.2.2 Pumps . . . . . . . . . . . . . . . . . . . 5-2 5.2.3 Compressors . . . . . . . . . . . . . . . . 5-4 5.2.4 Pressure Relief Valve s . . . . . . . . . . . 5-4 5.2.5 Valve s . . . . . . . . . . . . . . . . . . . 5-5 5.2.6 Connector s . . . . . . . . . . . . . . . . . 5-5 5.2.7 Open-Ended Line s . . . . . . . . . . . . . . 5-6 5.2.8 Sampling Connection s . . . . . . . . . . . . 5-6
5.3 Leak Detection and Repair Control Effectivenes s . . 5-6
5.3.1 Approach for Estimating LDAR Control Effectiveness . . . . . . . . . . . . . . . 5-8 5.3.2 Example Application of Approach

..... 5-57

5.4 References

................... 5-61

APPENDICES
A Example Calculation s . . . . . . . . . . . . . . . . . . A-1
B Leak Rate Screening Value Correlation Development and Revision of SOCMI Correlations and Emission Factors . . B-1
C Revision of Petroleum Industry Correlations and Emission Facto r . . . . . . . . . . . . . . . . . . . . . . . . . C-1

D Response Factor s . . . . . . . . . . . . . . . . . . . . D-1
E Selection of Sample Size for Screening Connectors . . . E-1

F Reference Method 21 . . . . . . . . . . . . . . . . . . F-1
G Development of Leak Rate Versus Fraction Leaking Equations and Determination of LDAR Control Effectiveness . . . . . . . . . . . . . . . . . . . . . G-1

ivLIST OF TABLES

Table Page

2-1 SOCMI Average Emission Factors

......... 2-12
2-2 Refinery Average Emission Factor s........ 2-13
2-3 Marketing Terminal Average Emission Factor s... 2-14
2-4 Oil and Gas Production Operations Average Emission Factor s..................... 2-15
2-5 SOCMI Screening Ranges Emission Factor s..... 2-19
2-6 Refinery Screening Ranges Emission Factors . . . 2-20
2-7 Marketing Terminal Screening Ranges Emission Factor s..................... 2-21
2-8 Oil and Gas Production Operations Screening Ranges Emission Factors

................ 2-22
2-9 SOCMI Leak Rate/Screening Value Correlations . . 2-26
2-10 Petroleum Industry Leak Rate/Screening Value Correlations

.................. 2-27

2-11 Default-Zero Values: SOCMI Process Unit s.... 2-33
2-12 Default-Zero Values: Petroleum Industry

.... 2-34
2-13 10,000 and 100,000 ppmv Screening Value Pegged Emission Rates For SOCMI Process Unit s.......... 2-36
2-14 10,000 and 100,000 ppmv Screening Value Pegged Emission Rates For the Petroleum Industry

........ 2-37

3-1 Performance Criteria for Portable VOC Detector s . . 3-6

3-2 Portable VOC Detection Instruments

....... 3-11
3-3 Equipment Leak Emission Source s......... 3-13
3-4 Example Field Sheets For Equipment Screening Data 3-26
4-1 Calculation Procedures For Leak Rate When Using the Vacuum Metho d . . . . . . . . . . . . . . . . . 4-9
4-2 Calculation Procedures For Leak Rate When Using the Blow-Through Metho d............. 4-13
4-3 Example GC Calibration Data Shee t........ 4-20

vLIST OF TABLES (Continued)

Table Page

4-4 Example Data Collection Form For Fugitive Emissions Bagging Test (Blow-Through Method) . . 4-23
4-5 Example Data Collection Form For Fugitive Emissions Bagging Test (Vacuum Method)

..... 4-24
4-6 Example Drift Test Report Form

......... 4-28
5-1 Summary of Equipment Modifications . . . . . . . . 5-3
5-2 Control Effectiveness For an LDAR Program At a SOCMI Process Unit . . . . . . . . . . . . . . . . 5-9
5-3 Control Effectiveness For an LDAR Program At a Refinery Process Uni t.............. 5-10
5-4 Equations Relating Average Leak Rate to Fraction Leaking at SOCMI Units

............. 5-46
5-5 Equations Relating Average Leak Rate to Fraction Leaking at Refinery Unit s............ 5-47
5-6 Equations Relating Average Leak Rate to Fraction Leaking At Marketing Terminal Unit s....... 5-48
5-7 Equations Relating Average Leak Rate to Fraction Leaking At Oil and Gas Production Operating Unit s...................... 5-50
5-8 Values Used in Example Calculation

....... 5-58
5-9 Example Calculation To Determine the Final Leak Frequency Of SOCMI Gas Valves In a Monthly Monitoring LDAR Program With a Leak Definition of 10,000 ppmv

................. 5-60

viLIST OF FIGURES
Figure Page

2-1 Overview of Data Collection and Analysis Approaches for Developing Equipment Leak Emissions Inventor y . . . . . . . . . . . . . . . . 2-4
2-2 SOCMI Correlations Relating Total Organic Compound (TOC) Leak Rate to Screening Value: 0 - 1,000 ppmv

................. 2-28
2-3 SOCMI Correlations Relating Total Organic Compound (TOC) Leak Rate to Screening Value: 1,000 - 1,000,000 ppmv

............. 2-29
2-4 Petroleum Industry Correlations Relating Total Organic Compound (TOC) Leak Rate to Screening Value: 1,000 - 1,000,000 ppmv

............. 2-30
2-5 Petroleum Industry Correlations Relating Total Organic Compound (TOC) Leak Rate to Screening Value: 1,000 - 1,000,000 ppmv

............. 2-31

3-1 Gate Valve s................... 3-17

3-2 Globe Valves

.................. 3-18
3-3 Lubricated Plug Valv e.............. 3-19
3-4 Ball Valve and Butterfly Valve

......... 3-20
3-5 Weir-Type Diaphragm Valve and Check Valves . . . 3-21
3-6 Centrifugal Pump s................ 3-23
3-7 Spring-Loaded Relief Valve

........... 3-24
4-1 Sampling Train for Bagging a Source Using the Vacuum Metho d . . . . . . . . . . . . . . . . . . . 4-5
4-2 Equipment Required for the Blow-Through Sampling Techniqu e.................... 4-10
5-1 SOCMI Gas Valve Average Leak Rate Versus Fraction Leaking at Several Leak Definition s....... 5-11
5-2 SOCMI Light Liquid Valve Average Leak Rate Versus Fraction Leaking at Several Leak Definitions . . 5-12
5-3 SOCMI Light Liquid Pump Average Leak Rate Versus Fraction Leaking at Several Leak Definitions . . 5-13

viiLIST OF FIGURES (Continued)
Figure Page

5-4 SOCMI Connector Average Leak Rate Versus Fraction Leaking at Several Leak Definition s....... 5-14
5-5 Refinery Gas Valve Average Leak Rate Versus Fraction Leaking at Several Leak Definitions . . 5-15
5-6 Refinery Light Liquid Valve Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-16
5-7 Refinery Light Liquid Pump Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-17
5-8 Refinery Connector Average Leak Rate Versus Fraction Leaking at Several Leak Definitions . . 5-18
5-9 Marketing Terminal Gas Fittings Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-19
5-10 Marketing Terminal Light Liquid Fittings Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-20
5-11 Marketing Terminal Gas Others Average Leak Rate Versus Fraction Leaking at Several Leak Definitions . . 5-21
5-12 Marketing Terminal Light Liquid Others Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-22
5-13 Marketing Terminal Light Liquid Pumps Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-23
5-14 Marketing Terminal Gas Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definitions . . 5-24
5-15 Marketing Terminal Light Liquid Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-25
5-16 Oil and Gas Production Gas Connectors Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-27

viiiLIST OF FIGURES (Continued)
Figure Page

5-17 Oil and Gas Production Light Oil Connectors Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-28
5-18 Oil and Gas Production Water/Oil Connectors Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-29
5-19 Oil and Gas Production Gas Flanges Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-30
5-20 Oil and Gas Production Light Oil Flanges Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-31
5-21 Oil and Gas Production Gas Open-Ended Lines Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-32
5-22 Oil and Gas Production Heavy Oil Open-Ended Lines Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

................ 5-33
5-23 Oil and Gas Production Light Oil Open-Ended Lines Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

................ 5-34
5-24 Oil and Gas Production Water/Oil Open-Ended Lines Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

................ 5-35
5-25 Oil and Gas Production Gas Other Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-36
5-26 Oil and Gas Production Heavy Oil Other Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-37
5-27 Oil and Gas Production Light Oil Other Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-38
5-28 Oil and Gas Production Water/Oil Other Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-39

ixLIST OF FIGURES (Continued)
Figure Page

5-29 Oil and Gas Production Gas Pumps Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-40
5-30 Oil and Gas Production Light Oil Pumps Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-41
5-31 Oil and Gas Production Gas Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-42
5-32 Oil and Gas Production Heavy Oil Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-43
5-33 Oil and Gas Production Light Oil Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-44
5-34 Oil and Gas Production Water/Oil Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-45
5-35 Marketing Terminals Light Liquid Pumps Average Leak Rate Versus Fraction Leaking at Several Leak Definition s................... 5-55

x1.0 INTRODUCTION

This document is an update to the EPA equipment leaks protocol document ("Protocol for Equipment Leak Emission Estimates," EPA-453/R-93-026, June 1993). The purpose of this document is the same as the original protocol document and subsequent revisions- to present standard procedures for estimating mass emissions from equipment leaks. However, this document publishes the results of additional data collection and analysis that has occurred since the original protocol and subsequent revisions were published, and also expands on some of the topics that were covered in the original protocol. Some of the new features of the updated protocol are:
(1) New correlation equations, default zero emission rates, and pegged emission rates for the petroleum industry that replace the refinery correlations previously published are presented. The correlations relate screening values obtained using a portable monitoring instrument to mass emissions.
(2) The document has been expanded to include emission factors for marketing terminals and for oil and gas production operations. The refinery emission factors were not revised due to an unavailability of new data.
(3) Pegged emission rates for pegged readings at 10,000 ppmv have been added for SOCMI process units.
(4) Several of the equations in this version of the protocol have been revised by simplifying the symbols to more clearly communicate the concept being conveyed.
(5) An adjustment has been added to the blow-through method of calculating mass emissions. This adjustment more accurately accounts for the total flow through the bag.

1-1As with the original protocol document, this document presents standard procedures for general use in generating unit-specific emission estimates for permitting and inventories. The document describes methodologies the EPA considers appropriate for development of equipment leak emission estimates. These methodologies are intended to assist States and industry in their efforts to estimate equipment leak emissions. The updated protocol is divided into five chapters and several appendices. Chapter 2.0 describes how to estimate equipment leak emissions. Chapter 3.0 describes collecting screening data that can be used in the emission estimates. Chapter 4.0 describes collecting unit-specific equipment leak mass emissions data. Chapter 5.0 describes how to estimate the control efficiencies of equipment leak control techniques. The appendices support information contained in the chapters. Each of these chapters and the appendices are briefly described below. Chapter 2.0 presents the four approaches for estimating total organic emissions from equipment leaks. These approaches are: Average Emission Factor Approach; Screening Ranges Approach; EPA Correlation Approach; and Unit-Specific Correlation Approach. Additionally, several topics that are relevant to estimating equipment leak emissions are addressed. These topics include speciating equipment leak emissions of individual compounds from an equipment piece containing a mixture, using response factors, estimating emissions of volatile organic compounds, estimating emissions of inorganic compounds, and other topics not specifically related to any one of the four approaches. Chapter 3.0 explains how to perform a screening survey at a process unit. Requirements for the use of a portable monitoring instrument are described. These requirements are based on the EPA Reference Method 21. Additionally, in chapter 3.0, guidance is provided on how to set up a screening program and how to screen different types of equipment.

1-2Chapter 4.0, explains how to collect equipment leak rate data (bagging data) by enclosing individual equipment in a "bag" and measuring mass emissions. These data can be used to develop unit-specific leak rate/screening value correlations. Chapter 4.0 details the rigorous steps that need to be followed when collecting the bagging data to generate unit-specific correlations. These steps are intended to ensure that the data are of high quality. Chapter 5.0, explains how to estimate the control efficiency of equipment leak emission control techniques. The two primary control techniques for reducing equipment leak emissions are (1) equipment modifications (such as replacing a standard valve with a sealless type) and (2) implementing a leak detection and repair (LDAR) program. Control efficiencies for different equipment leak modifications are summarized, and an approach for estimating the control efficiency of any LDAR program is provided. Appendices A through G provide additional information supporting the material in the chapters. Appendix A contains detailed example calculations using the approaches described in chapter 2.0. Appendix B documents how the SOCMI correlations and emission factors were revised. Appendix B also serves as a demonstration of how data can be analyzed to develop unit-specific correlations. Appendix C presents the rationale for the development of the petroleum industry correlations, as well as the background for the development of marketing terminal and oil and gas production operations emission factors. Appendix D summarizes available data on response factors. Appendix E provides guidance on how to collect representative screening data for connectors. Appendix F contains a copy of the EPA Reference Method 21. Finally, appendix G demonstrates how LDAR control efficiencies presented in chapter 5.0 were
calculated.

1-32.0. DEVELOPMENT OF EQUIPMENT LEAK EMISSION ESTIMATES

2.1 INTRODUCTION The purpose of this chapter is to describe the methods for estimating mass emissions from equipment leaks in a chemical processing unit. Four approaches for estimating equipment leak emissions are presented: Approach 1: Average Emission Factor Approach; Approach 2: Screening Ranges Approach; Approach 3: EPA Correlation Approach; and Approach 4: Unit-Specific Correlation Approach. General information on these approaches is presented in section 2.2, and detailed information on applying each of the approaches is presented in section 2.3. Included in section 2.3 are emission factors and leak rate/screening value correlations for use in estimating emissions from equipment leaks in the petroleum industry and the synthetic organic chemical manufacturing industry (SOCMI). The SOCMI emission factors and correlations were revised and introduced in the 1993 update of this document. The refinery correlations that have been revised and expanded to include the entire petroleum industry are introduced in this document. Additionally, emission factors for marketing terminals are introduced in this document. Emission factors for gas plants that have been updated and expanded to included oil and gas production operations are also introduced in this document. The procedures in this document estimate emissions of total organic compounds (TOC’s). However, special procedures are also described for the purpose of estimating volatile organic compounds (VOC’s). As defined by the EPA, VOC’s

2-1include all organic compounds except those specifically excluded by the EPA due to negligible photochemical activity. After the four approaches have been discussed, topics that are not specifically related to any particular approach, but are relevant to how equipment leak emissions are estimated, are addressed in section 2.4. These topics include:
Estimating emissions of individual compounds within a mixture;
Using response factors when estimating emissions;
Considerations regarding the monitoring instrument used;
Estimating emissions of equipment not screened when other equipment have been screened;
Using screening data collected at different times;
Estimating VOC emissions from equipment containing organic compounds excluded from the EPA’s classification of TOC’s; and
Estimating emissions from equipment containing inorganic compounds.
Appendices A through E contain supporting documentation for the material presented in this chapter. Appendix A contains detailed example calculations that demonstrate the four approaches for estimating equipment leak emissions, as well as the topics discussed in section 2.4. Appendix B presents details on how unit-specific correlations can be developed, and also presents background information on the revision of the SOCMI correlations and emission factors. Appendix C presents background information on the development of average emission factors and correlation equations for the petroleum industry. Appendix D offers a detailed listing of available response factors. Appendix E contains information on the minimum number of connectors in a process unit that must be screened in order to obtain a representative sample.

2-22.2 GENERAL INFORMATION ON THE APPROACHES FOR ESTIMATING EQUIPMENT LEAK EMISSIONS This section presents general information on the four approaches for estimating equipment leak emissions. Each approach is briefly described, and data requirements for each are summarized. Additionally, background information is presented to provide an historical overview of data collection and analysis on emissions of VOC’s from equipment leaks. 2.2.1 Equipment Leak Emission Estimation Approaches The four approaches described here can be used by any chemical-handling facility to develop an inventory of TOC or VOC emissions from equipment leaks. The approaches, in order of increasing refinement, are: Average Emission Factor Approach, Screening Ranges Approach, EPA Correlation Approach, and Unit-Specific Correlation Approach. In general, the more refined approaches require more data and provide more accurate emission estimates for a process unit. In the Average Emission Factor Approach and the Screening Ranges Approach, emission factors are combined with equipment counts to estimate emissions. To estimate emissions with the EPA Correlation Approach, measured concentrations (screening values) for all equipment are individually entered into general correlations developed by the EPA. In the Unit-Specific Correlation Approach, screening and leak rate data are measured for a select set of individual equipment components and then used to develop unit-specific correlations. Screening values for all components are then entered into these unit-specific correlations to estimate emissions. Figure 2-1 is an overview of the data collection and analysis required to apply each of the approaches. As can be seen from this figure, all of the approaches require an accurate count of equipment components by type of equipment (i.e., valves, pumps, connectors, etc.). Additionally, for some of the equipment types, the count must be further described by service (i.e., heavy liquid, light liquid, and gas).

2-32-4 Figure 2-1. Overview of Data Collection and Analysis Approaches for Developing Equipment Leak Emissions InventoryExcept for the Average Emission Factor Approach, all of the approaches require screening data. Screening data are collected by using a portable monitoring instrument to sample air from potential leak interfaces on individual pieces of equipment. A screening value is a measure of the concentration of leaking compounds in the ambient air that provides an indication of the leak rate from an equipment piece, and is measured in units of parts per million by volume (ppmv). The procedures for collecting screening data are presented in chapter 3.0. In addition to equipment counts and screening data, the Unit-Specific Correlation Approach requires bagging data. Bagging data consist of screening values and their associated measured leak rates. A leak rate is measured by enclosing an equipment piece in a bag to determine the actual mass emission rate of the leak. The screening values and measured leak rates from several pieces of equipment are used to develop a unit-specific correlation. The resulting leak rate/screening value correlation predicts the mass emission rate as a function of the screening value. Procedures for collecting bagging data are described in detail in chapter 4.0. Each of the approaches are applicable to any chemical-handling facility. However, the EPA has developed more than one set of emission factors and correlations, and the type of process unit being considered governs which set must be used to estimate emissions. Historical data collection on emissions from equipment leaks in SOCMI, refineries, marketing terminals and oils and gas production operations have yielded emission factors and correlations for these source categories. Emission factors and correlations for other source categories have not been developed. For process units in source categories for which emission factors and/or correlations have not been developed, the factors and/or correlations already developed can be utilized. However, appropriate evidence should indicate that the existing emission factors and correlations are applicable to the source category in question. Criteria for determining the appropriateness of

2-5applying existing emission factors and correlations to another source category may include one or more of the following: (1) process design, (2) process operation parameters (i.e., pressure and temperature), (3) types of equipment used, and (4) types of material handled. For example, in most cases, SOCMI emission factors and correlations are applicable for estimating equipment leak emissions from the polymer and resin manufacturing industry. This is because, in general, these two industries have comparable process design and comparable process operation, they use the same types of equipment, and they tend to use similar feedstock. 2.2.2 Overview of Equipment Leak Data Collection Data on equipment leak emissions of organic compounds have been collected from refineries, marketing terminals, oil and gas production operations, and SOCMI process units. Emission factors and correlations have been developed for the following equipment types: valves, pumps, compressors, pressure relief valves, connectors, flanges, and open-ended lines. An "others" category has also been developed for the petroleum industry. For sampling connections, an average emission factor has been developed that estimates the typical amount of material purged when a sample is collected. A brief history of the development of these factors and correlations is presented below. 2.2.2.1 Refinery Assessment Study

. 1,2 In the late 1970s, the EPA initiated the Petroleum Refinery Assessment Study, and equipment leak data from 13 refineries were collected. In this study, equipment was screened and the majority of sources that had screening values over 200 ppmv were bagged. Bagged equipment emission rates were reported as non-methane organic compound emission rates. Average emission factors and correlations for each equipment type were developed based on the screening and bagging data collected in this study. The Refinery Assessment Study included an investigation of possible correlations between equipment leaks and process variables. The only process variables found to correlate with mass emission rates in a statistically significant manner were

2-6(1) the phase of the process stream (service), and (2) the relative volatility of liquid streams. This finding led to the separation of data for valves, pumps, and pressure relief valves by type of service. Three service categories were defined: Gas/vapor - material in a gaseous state at operating conditions;
Light liquid - material in a liquid state in which the sum of the concentration of individual constituents with a vapor pressure over 0.3 kilopascals (kPa) at 20 o C is greater than or equal to 20 weight percent; and
Heavy liquid - not in gas/vapor service or light liquid service.

2.2.2.2 Gas Plant Studies

. 3 A total of six gas plants were screened in two studies: Four were screened by the EPA and two by the American Petroleum Institute. Average emission factors were developed, and information on the percentage of equipment with screening values equal to or greater than 10,000 ppmv was presented. The average factors include emissions of ethane and methane, which are hydrocarbons but are not classified as VOC’s. 2.2.2.3 Revised Petroleum Industry Correlations and Emission

Factors . During the early-1990’s, new petroleum industry equipment leak bagging data were collected and analyzed. The Western States Petroleum Association (WSPA) and the American Petroleum Institute (API) jointly commissioned the 1994 refinery equipment leak report 4 to evaluate fugitive emissions collected from five petroleum refineries. The API also commissioned the 1993 marketing terminal equipment leak report, 5 which included bagging data from three marketing terminals, and, along with the Gas Research Institute (GRI), jointly commissioned the 1993 and 1995 oil and gas production operations reports, which included bagging data from 24 facilities. 6,7 In addition to the bagging data, screening data were also collected from 17 marketing terminals 8 and 24 oil and gas production facilities. 6,7 Data from gas/vapor, light liquid, and/or heavy liquid streams were collected for these studies from non-flanged connectors, flanges, open-ended lines, pumps, values, instruments, loading arms,

2-7pressure relief valves, stuffing boxes, vents, compressors, dump lever arms, diaphrams, drains, hatches, meters, and polished
rods. A specific goal of the above studies was to collect high quality data to enhance or replace the previously published refinery correlations. As a result of the analyses discussed in appendix C, the bagging data collected from refineries, marketing terminals, and oil and gas production facilities during the early-1990’s were combined to replace the previously published refinery correlations with correlations applicable to the entire petroleum industry. In addition, the new correlations apply across all services for a given equipment type. The previously published refinery correlations were specific to service and equipment. The screening data were used to develop average emission factors for marketing terminals and for oil and gas production operations. The average emission factors for oil and gas production operations replace the gas plant factors published in previous versions of this document and apply to light crude, heavy crude, gas plant, gas production and off shore facilities. No new screening data were available for refineries, therefore the previously published refinery average emission factors remain unchanged in this version of the protocol. Appendix C contains more detailed information on how the new petroleum industry correlations, marketing terminal emission factors, and oil and gas production operations emission factors were developed. 2.2.2.4 Original SOCMI Average Emission Factors and Correlations . In 1980, two studies were coordinated by the EPA to collect data from SOCMI process units. These studies were the 24-Unit Study, 9 and the Six-Unit Maintenance Study. 10 In the 24-Unit Study, screening data were obtained from equipment containing organic compounds at 24 individual chemical process units representing a cross-section of the SOCMI. In the Six-Unit Maintenance Study, bagging data were collected from six of the process units within the 24-Unit Study to determine the effect of maintenance on equipment leak emissions. Most of the bagging

2-8data were collected from equipment with screening values above 1,000 ppmv. As part of the Six-Unit Maintenance Study, correlations were developed for light liquid pumps, gas valves, and light liquid valves. The original SOCMI average emission factors were first presented in the document "Fugitive Emission Sources of Organic Compounds--Additional Information on Emissions, Emission Reductions, and Costs." 6 This document is referred to as the Fugitive Emissions Additional Information Document (AID). In the Fugitive Emissions AID, the data from the Refinery Assessment Study were further analyzed to develop "leak/no leak" emission factors. (A "leak" was defined as a screening value greater than or equal to 10,000 ppmv.) With the exception of the factor for gas valves, the original SOCMI average emission factors were developed using (1) the leak/no-leak emission factors developed from the Refinery Assessment Study data, and (2) the leak frequencies from the SOCMI 24-Unit Study screening value data set. This approach was based on statistical comparisons that indicated that the most significant characteristic that distinguished equipment in SOCMI facilities from that in refineries was not the leak rate for a given screening value, but rather the fraction of equipment that had screening values greater than or equal to 10,000 ppmv. Thus, the following equation was used to calculate the original SOCMI average emission factors:

SOCMI Average Factor = (F × RLF) + (1 - F) × RNLF

where:
F = Fraction of sources from the 24-Unit Study that screened greater than or equal to 10,000 ppmv;
RLF = Refinery leaking emission factor; and
RNLF = Refinery non-leaking emission factor.

For gas valves, the previously collected data suggested that for a given screening value the leak rate at a SOCMI facility was

2-9not statistically equivalent to the leak rate at a refinery. Therefore, data from the Six-Unit Maintenance Study were used to develop the gas valve average emission factor. 2.2.2.5 Revised SOCMI Emission Factors and Correlations . In 1987 and 1988, screening data were obtained from 19 ethylene oxide and butadiene producers, and, in 1990, bagging data were collected from 16 of these process units. Screening and bagging data were collected from light liquid pumps, gas valves, light liquid valves, and connectors. A specific goal of the program was to bag equipment that had screening values less than 1,000 ppmv. The bagging data were combined with bagging data previously collected in the Six-Unit Maintenance Study, and this combined bagging data set was used to revise the SOCMI correlations. Likewise, the new screening data were combined with screening data previously collected in the 24-Unit Study, and this combined screening data set was used with the revised correlations to generate new SOCMI emission factors. Appendix B.2 contains more detailed information on how the revised SOCMI correlations and emission factors were developed. 2.3 APPROACHES FOR ESTIMATING EQUIPMENT LEAK EMISSIONS In this section, each of the approaches for estimating equipment leak emissions are discussed. The description of each approach focuses on the basic method for estimating TOC emissions. Each of the approaches are demonstrated in example calculations contained in appendix A. Special topics at the end of the chapter have been included to address how to estimate VOC emissions when some of the organic compounds in the stream are not classified as VOC’s and also how to speciate emissions for individual chemicals from equipment containing a mixture. 2.3.1 Average Emission Factor Approach One accepted approach for estimating emissions allows use of average emission factors developed by the EPA in combination with unit-specific data that are relatively simple to obtain. These data include: (1) the number of each type of component in a unit (valve, connector, etc.), (2) the service each component is in (gas, light liquid, or heavy liquid), (3) the TOC concentration

2-10of the stream (and VOC or HAP concentrations if speciation is to be performed), and (4) the time period each component was in that service. The average emission factors for SOCMI process units, refineries, marketing terminals, and oil and gas production operations are presented in tables 2-1, 2-2, 2-3, and 2-4 respectively. The SOCMI, marketing terminal, and oil and gas production operations average emission factors predict total organic compound emission rates, whereas the refinery average factors predict non-methane organic compound emission rates. Note that limited data has been collected on the leak rate of agitators, and, until additional data are collected for emissions from agitator seals, the average factor for light liquid pump seals can be used to estimate emissions from agitators. Although the average emission factors are in units of kilogram per hour per individual source, it is important to note that these factors are most valid for estimating emissions from a population of equipment. The average factors are not intended to be used for estimating emissions from an individual piece of equipment over a short time period (i.e., 1 hour). To estimate emissions using the Average Emission Factor Approach, the concentration of TOC in weight fraction within the equipment is needed because equipment with higher TOC concentrations tend to have higher TOC leak rates. When using the Average Emission Factor Approach, equipment should be grouped into "streams" where all the equipment within the stream have approximately the same TOC weight fraction. To apply the average emission factors, use the following equation to estimate TOC mass emissions from all of the equipment in a stream of a given equipment type:

E TOC = F A × WF TOC × N

where:

E TOC = Emission rate of TOC from all equipment in the stream of a given equipment type (kg/hr);

2-11TABLE 2-1. SOCMI AVERAGE EMISSION FACTORS

Equipment type Service Emission factor a (kg/hr/source)
Valves Gas Light liquid Heavy liquid 0.00597 0.00403 0.00023 Pump seals b Light liquid Heavy liquid 0.0199 0.00862 Compressor seals Gas 0.228
Pressure relief valves Gas 0.104

Connectors All 0.00183 Open-ended lines All 0.0017 Sampling connections All 0.0150

a These factors are for total organic compound emission

rates.
b The light liquid pump seal factor can be used to estimate the

leak rate from agitator seals.

2-12TABLE 2-2. REFINERY AVERAGE EMISSION FACTORS a

Equipment type Service Emission factor (kg/hr/source) b

Valves Gas Light liquid Heavy liquid 0.0268 0.0109 0.00023 Pump seals c Light liquid Heavy liquid 0.114 0.021 Compressor seals Gas 0.636
Pressure relief valves Gas 0.16

Connectors All 0.00025 Open-ended lines All 0.0023 Sampling connections All 0.0150

a Source: Reference 2.

b These factors are for non-methane organic compound

emission rates.

c The light liquid pump seal factor can be used to estimate the

leak rate from agitator seals.

2-13TABLE 2-3. MARKETING TERMINAL AVERAGE EMISSION FACTORS

Equipment type Service Emission factor (kg/hr/source) a

Valves Gas Light Liquid 1.3E-05 4.3E-05 Pump seals Gas Light Liquid 6.5E-05 5.4E-04 Others (compressors and others) b Gas Light Liquid 1.2E-04 1.3E-04 Fittings (connectors and flanges) c Gas Light Liquid 4.2E-05 8.0E-06

a These factors are for total organic compound emission rates

(including non-VOC’s such as methane and ethane).

b The "other" equipment type should be applied for any equipment

type other than fittings, pumps, or valves.

c "Fittings" were not identified as flanges or non-flanged

connectors; therefore, the fitting emissions were estimated by averaging the estimates from the connector and the flange correlation equations.

2-14TABLE 2-4. OIL AND GAS PRODUCTION OPERATIONS AVERAGE EMISSION FACTORS (kg/hr/source)

Equipment Type Service a Emission Factor (kg/hr/source) b

Valves Gas Heavy Oil Light Oil Water/Oil 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Pump seals Gas Heavy Oil Light Oil Water/Oil 2.4E-03 NA 1.3E-02 2.4E-05
Others c Gas Heavy Oil Light Oil Water/Oil 8.8E-03 3.2E-05 7.5E-03 1.4E-02

Connectors Gas Heavy Oil Light Oil Water/Oil 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges Gas Heavy Oil Light Oil Water/Oil 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended lines Gas Heavy Oil Light Oil Water/Oil 2.0E-03 1.4E-04 1.4E-03 2.5E-04

a Water/Oil emission factors apply to water streams in oil service

with a water content greater than 50%, from the point of origin to the point where the water content reaches 99%. For water streams with a water content greater than 99%, the emission rate is considered negligible. b These factors are for total organic compound emission rates

(including non-VOC’s such as methane and ethane) and apply to light crude, heavy crude, gas plant, gas production, and off shore facilities. "NA" indicates that not enough data were available to develop the indicated emission factor. c The "other" equipment type was derived from compressors,

diaphrams, drains, dump arms, hatches, instruments, meters, pressure relief valves, polished rods, relief valves, and vents. This "other" equipment type should be applied for any equipment type other than connectors, flanges, open-ended lines, pumps, or valves.

2-15F A = Applicable average emission factor for the equipment type (kg/hr/source);

FOR REFINERIES ONLY: The emission factor "F A " must be adjusted to account for all organic compounds in the stream because the refinery factors are only valid for non-methane organic compounds (percents up to a maximum of 10 percent by weight methane are permitted):

WF TOC F A = F A × ; WF TOC - WF methane

WF TOC = Average weight fraction of TOC in the stream;

WF methane = Average weight fraction of methane in the stream; and
N = Number of pieces of equipment of the applicable equipment type in the stream.

Note that the emission factor "F A " is defined differently for refineries than for SOCMI, marketing terminals, or oil and gas production operations when calculating TOC mass emissions. It is necessary to adjust the "F A " term when applied to refineries, because when the refinery factors were developed, the methane was subtracted out of the organic total. Adjusting the "F A " term for refineries is a way to correct for this. Two guidelines when correcting the "F A " term when applied to refineries are as
follows:
The correction should only be applied to equipment containing a mixture of organics and methane; and
The maximum correction for the methane weight fraction should not exceed 0.10, even if the equipment contains greater than 10 weight percent methane. (This reflects that equipment in the Refinery Assessment Study 1,2 typically contained 10 weight percent or less methane).

Thus, at a SOCMI process unit, if there were 100 gas valves in a stream containing, on average, 90 weight percent TOC and 10 weight percent water vapor, emissions would be calculated as
follows:

2-16E TOC = F A × WF TOC × N
= 0.00597 kg/hr/gas valve × 0.9 × 100 gas valves
= 0.54 kg/hr of VOC from gas valves in the stream

At a refinery, if there were 100 gas valves in a stream that, on average, contained 80 weight percent non-methane TOC, 10 weight percent water vapor, and 10 weight percent methane (thus, the TOC weight percent would be 90), emissions would be calculated using the above equation as follows:

WF TOC E TOC = F A × × W F TOC × N WF TOC - WF methane = 0.0268 kg/hr/gas valve × (0.9/0.9-0.1) × 0.9 × 100 gas valves
= 2.71 kg/hr of VOC from gas valves in the stream

If there are several streams at a process unit, the total TOC emission rate for an equipment type is the sum of emissions from each of the streams. The total emission rates for all of the equipment types are summed to generate the process unit total TOC emission rate from leaking equipment. Assuming all of the organic compounds in the stream are classified as VOC’s, the total VOC emission for each stream is calculated as the sum of TOC emissions associated with each specific equipment type in the stream. Section 2.4.6 discusses an adjustment that can be made to predict the VOC emission rate if some of the organic compounds in the stream are not classified as VOC’s (such as methane and ethane). As mentioned earlier, the average emission factors are not intended to provide an accurate estimate of the emission rate from a single piece of equipment. Rather, the average factors are more appropriately applied to the estimation of emissions from populations of equipment. Data indicate that the range of possible leak rates from individual pieces of equipment spans

2-17several orders of magnitude. As a result, the majority of total emissions from a population of equipment at any given time will normally occur from a small percentage of the total equipment. The average emission factors account for the span of possible leak rates, but, as a result, they are not necessarily an accurate indication of the mass emission rate from an individual piece of equipment. Furthermore, the average emission factors do not reflect different site-specific conditions among process units within a source category. Site-specific factors can have considerable influence on leak rates from equipment. Nevertheless, in the absence of screening data, the average emission factors do provide an indication of equipment leak emission rates from equipment in a process unit. 2.3.2 Screening Ranges Approach The Screening Ranges Approach (formerly known as the leak/no-leak approach) offers some refinement over the Average Emission Factor Approach, thereby allowing some adjustment for individual unit conditions and operation. This approach is included in this section primarily to aid in the analysis of old datasets which were collected for older regulations that used 10,000 ppmv as the leak definition. This approach and the other two remaining approaches require that screening data be collected for the equipment in the process unit. The screening data are an indication of leak rates. When applying this approach, it is assumed that components having screening values greater than 10,000 ppmv have a different average emission rate than components with screening values less than 10,000 ppmv. This approach may be applied when screening data are available as either "greater than or equal to 10,000 ppmv" or as "less than 10,000 ppmv." Emission factors for SOCMI, refineries, marketing terminals, and oil and gas production operations for these two ranges of screening values are presented in tables 2-5, 2-6, and 2-7, and 2-8, respectively. As with the average factors, the SOCMI, marketing terminal, and oil and gas production operations screening range factors predict total

2-18TABLE 2-5. SOCMI SCREENING RANGES EMISSION FACTORS

Equipment type Service ≥ 10,000 ppmv Emission factor (kg/hr/source) a <10,000 ppmv Emission factor (kg/hr/source) a

Valves Gas Light liquid Heavy liquid 0.0782 0.0892 0.00023 0.000131 0.000165 0.00023 Pump seals b Light liquid Heavy liquid 0.243 0.216 0.00187 0.00210 Compressor seals Gas 1.608 0.0894

Pressure relief valves Gas 1.691 0.0447

Connectors All 0.113 0.0000810 Open-ended lines All 0.01195 0.00150

a These factors are for total organic compound emission rates.

b The light liquid pump seal factors can be applied to estimate

the leak rate from agitator seals.

2-19TABLE 2-6. REFINERY SCREENING RANGES EMISSION FACTORS a

Equipment type Service ≥ 10,000 ppmv Emission factor (kg/hr/source) b <10,000 ppmv Emission factor (kg/hr/source) b
Valves Gas 0.2626 0.0006 Light liquid 0.0852 0.0017 Heavy liquid 0.00023 0.00023

Pump seals c Light liquid 0.437 0.0120 Heavy liquid 0.3885 0.0135

Compressor seals Gas 1.608 0.0894

Pressure relief valves Gas 1.691 0.0447

Connectors All 0.0375 0.00006

Open-ended lines All 0.01195 0.00150

a Source: Reference 6.

b These factors are for non-methane organic compound emission

rates.

c The light liquid pump seal factors can be applied to estimate

the leak rate from agitator seals.

2-20TABLE 2-7. MARKETING TERMINAL SCREENING RANGES EMISSION FACTORS

Equipment type Service ≥ 10,000 ppmv Emission factor (kg/hr/source) a <10,000 ppmv Emission factor (kg/hr/source) a

Valves Gas Light Liquid NA 2.3E-02 1.3E-05 1.5E-05 Pump seals Light liquid 7.7E-02 2.4E-04
Other (compressors and others) b Gas Light liquid NA 3.4E-02 1.2E-04 2.4E-05

Fittings (connectors and flanges) c Gas Light liquid 3.4E-02 6.5E-03 5.9E-06 7.2E-06

a These factors are for total organic compound emission rates

(including non-VOC’s such as methane and ethane). "NA" indicates that not enough data were available to develop the indicated emission factor.

b The "other" equipment type should be applied for any equipment

type other than fittings, pumps, or valves.

c "Fittings" were not identified as flanges or connectors;

therefore, the fitting emissions were estimated by averaging the estimates from the connector and the flange correlation equations.

2-21TABLE 2-8. OIL AND GAS PRODUCTION OPERATIONS SCREENING RANGES EMISSION FACTORS

Equipment type Service b ≥ 10,000 ppmv Emission factor (kg/hr/source) a <10,000 ppmv Emission factor (kg/hr/source) a Valves Gas Heavy Oil Light Oil Water/Oil 9.8E-02 NA 8.7E-02 6.4E-02 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Pump seals Gas Heavy Oil Light Oil Water/Oil 7.4E-02 NA 1.0E-01 NA 3.5E-04 NA 5.1E-04 2.4E-05 Others c Gas Heavy Oil Light Oil Water/Oil 8.9E-02 NA 8.3E-02 6.9E-02 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Connectors Gas Heavy Oil Light Oil Water/Oil 2.6E-02 NA 2.6E-02 2.8E-02 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges Gas Heavy Oil Light Oil Water/Oil 8.2E-02 NA 7.3E-02 NA 5.7E-06 3.9E-07 2.4E-06 2.9E-06 Open-ended lines Gas Heavy Oil Light Oil Water/Oil 5.5E-02 3.0E-02 4.4E-02 3.0E-02 1.5E-05 7.2E-06 1.4E-05 3.5E-06

a These factors are for total organic compound emission rates

(including non-VOC’s such as methane and ethane) and apply to light crude, heavy crude, gas plant, gas production, and offshore facilities. "NA" indicates that not enough data were available to develop the indicated emission factor. b Water/Oil emission factors apply to water streams in oil service

with a water content greater than 50%, from the point of origin to the point where the water content reaches 99%. For water streams with a water content greater than 99%, the emission rate is considered negligible. c The "other" equipment type was derived from compressors,

diaphrams, drains, dump arms, hatches, instruments, meters, pressure relief valves, polished rods, relief valves, and vents. This "other" equipment type should be applied for any equipment type other than connectors, flanges, open-ended lines, pumps, or valves.

2-22organic compound emissions, whereas the refinery screening range factors predict non-methane organic compound emissions. Note that there are not screening range factors for sampling connections because emissions from sampling connections occur when the line is purged, and, thus, are independent of any screening value. Also, as with the average factors, the screening range factors for light liquid pumps can be applied to agitators. The Screening Ranges Approach is applied in a similar manner as the Average Emission Factor Approach in that equipment counts are multiplied by the applicable emission factor. Also, for refineries, the screening range emission factors must be adjusted for methane in the equipment because when the refinery factors were developed, the methane was subtracted out of the organic
total. To calculate TOC emissions using the Screening Ranges Approach, the following equation is used:

E TOC = (F G × N G ) + (F L × N L )

where:

E TOC = TOC emission rate for an equipment type (kg/hr);

F G = Applicable emission factor for sources with screening values greater than or equal to 10,000 ppmv (kg/hr/source);

FOR REFINERIES ONLY: The emission factor "F G " must be adjusted to account for all organic compounds in the stream because the refinery factors are only valid for non-methane organic compounds (percents up to a maximum of 10 percent by weight methane are permitted):

WP TOC F G = F G × ; WP TOC - WP methane

WP TOC = Average weight percent of TOC in the stream;

2-23WP methane = Average weight percent of methane in the stream;

N G = Equipment count (specific equipment type) for sources with screening values greater than or equal to 10,000 ppmv;

F L = Applicable emission factor for sources with screening values less than 10,000 ppmv (kg/hr/source)

FOR REFINERIES ONLY: The emission factor "F L " must be adjusted to account for all organic compounds in the stream because the refinery factors are only valid for non-methane organic compounds (percents up to a maximum of 10 percent by weight methane are permitted):

WP TOC F L = F L × ; and WP TOC - WP methane

N L = Equipment count (specific equipment type) for sources with screening values less than 10,000 ppmv. Assuming all of the organic compounds in the stream are classified as VOC’s, the total VOC emission for each stream is calculated as the sum of TOC emissions associated with each specific equipment type in the stream. Section 2.4.6 discusses an adjustment that can be made to predict the VOC emission rate if some of the organic compounds in the stream are not classified as VOC’s (such as methane and ethane). The screening range emission factors are a better indication of the actual leak rate from individual equipment than the average emission factors. Nevertheless, available data indicate that measured mass emission rates can vary considerably from the rates predicted by use of these factors. 2.3.3 EPA Correlation Approach This approach offers an additional refinement to estimating emissions from equipment leaks by providing an equation to predict mass emission rate as a function of screening value for a particular equipment type. Correlations developed by the EPA relating screening values to mass emission rates for SOCMI

2-24process units and for petroleum industry process units are presented in tables 2-9 and 2-10, respectively. Correlations for the petroleum industry apply to refineries, marketing terminals and oil and gas production operations. Figures 2-2 through 2-5 plot the correlations. Both the SOCMI and petroleum industry correlations predict total organic compound emission rates. Appendix B.1 contains additional information on the general development of correlation equations. Additionally, appendix B.2 contains information about the development of the SOCMI correlations and appendix C contains information about the development of the petroleum industry correlations. The EPA Correlation Approach is preferred when actual screening values are available. Correlations can be used to estimate emissions for the entire range of non-zero screening values, from the highest potential screening value to the screening value that represents the minimum detection limit of the monitoring device. This approach involves entering the non-zero, non-pegged screening value into the correlation equation, which predicts the TOC mass emission rate based on the screening value. Default zero emission rates are used for screening values of zero ppmv and pegged emission rates are used for "pegged" screening values (the screening value is beyond the upper limit measured by the portable screening device). Correlations for SOCMI are available for (1) gas valves; (2) light liquid valves; (3) connectors; and (4) light liquid pump seals. Correlations for the petroleum industry are available for (1) valves; (2) connectors; (3) pumps; (4) flanges; (5) open-ended lines; and (6) "others" (derived from instruments, loading arms, pressure relief valves, stuffing boxes, and vents). Limited bagging data for compressors and pressure relief devices have been obtained at SOCMI plants. However, because statistical tests performed as part of the Refinery Assessment Study 2 indicated that emissions from light liquid pumps, compressors, and pressure relief valves could be expressed with a single correlation, until additional data are collected, the SOCMI equation for light liquid pump seals can be applied to

2-25TABLE 2-9. SOCMI LEAK RATE/SCREENING VALUE CORRELATIONS

Equipment type Correlation a,b

Gas valves Leak rate (kg/hr) = 1.87E-06 × (SV) 0.873 Light liquid valves Leak rate (kg/hr) = 6.41E-06 × (SV) 0.797

Light liquid pumps c Leak rate (kg/hr) = 1.90E-05 × (SV) 0.824

Connectors Leak rate (kg/hr) = 3.05E-06 × (SV) 0.885

a SV = Screening value in ppmv.

b These correlations predict total organic compound emission

rates.

c The correlation for light liquid pumps can be applied to

compressor seals, pressure relief valves, agitator seals, and heavy liquid pumps.

2-26TABLE 2-10. PETROLEUM INDUSTRY LEAK RATE/SCREENING VALUE CORRELATIONS a

Equipment type/service Correlation b,c

Valves/all Leak rate (kg/hr) = 2.29E-06 × (SV) 0.746
Pump seals/all Leak rate (kg/hr) = 5.03E-05 × (SV) 0.610

Others d Leak rate (kg/hr) = 1.36E-05 × (SV) 0.589
Connectors/all Leak rate (kg/hr) = 1.53E-06 × (SV) 0.735
Flanges/all Leak rate (kg/hr) = 4.61E-06 × (SV) 0.703 Open-ended lines/all Leak rate (kg/hr) = 2.20E-06 × (SV) 0.704

a The correlations presented in this table are revised petroleum

industry correlations.

b SV = Screening value in ppmv.

c These correlations predict total organic compound emission

rates (including non-VOC’s such as methane and ethane).

d The "other" equipment type was derived from instruments,

loading arms, pressure relief valves, stuffing boxes, and vents. This "other" equipment type should be applied to any equipment type other than connectors, flanges, open-ended lines, pumps, or valves.

2-27Figure 2-2. SOCMI Correlations relating total organic compound (TOC) leak rate to screening value: 0 - 1,000 ppmv

2-28Figure 2-3. SOCMI Correlations relating total organic compound (TOC) leak rate to screening value: 1,000 - 1,000,000 ppmv

2-29Figure 2-4. Petroleum Industry Correlations relating total organic compound (TOC) leak rate to screening value: 1,000 - 1,000,000 ppmv

2-30Figure 2-5. Petroleum Industry Correlations relating total organic compound (TOC)leak rate to screening value: 1,000 - 1,000,000 ppmv

2-31estimate emissions for compressor seals and pressure relief valves in SOCMI process units. Because bagging data were limited and the frequency of occurrence of some equipment types was small, a correlation for an "other" equipment type was developed for the petroleum industry correlations to apply to any equipment type other than connectors, flanges, open-ended lines, pumps, or
valves. Bagging data for agitator seals at petroleum industry and SOCMI process units are unavailable at this time. Compared to those equipment types that have correlations, agitators most closely resemble light liquid pumps, and, for this reason, the applicable light liquid pump correlation can be used to estimate agitator emissions. Similarly, the SOCMI light liquid pump correlation can be used to estimate emissions from SOCMI heavy liquid pumps. The "default-zero" leak rate is the mass emission rate associated with a screening value of zero. (Note that any screening value that is less than or equal to ambient [background] concentration is considered a screening value of zero.) The correlations mathematically predict zero emissions for zero screening values. However, data collected by the EPA show this prediction to be incorrect. Mass emissions have been measured from equipment having a screening value of zero. A specific goal when revising the SOCMI and petroleum industry correlations was to collect mass emissions data from equipment that had a screening value of zero. These data were used to determine a default-zero leak rate associated with equipment with zero screening values. Table 2-11 lists the SOCMI default-zero leak rates and table 2-12 presents the petroleum industry default-zero leak rates for each of the equipment types with correlation equations. These default-zero leak rates are applicable only when the minimum detection limit of the portable monitoring instrument is 1 ppmv or less above background. The portable monitoring device used to collect the default-zero data was sufficiently sensitive to indicate a

2-32TABLE 2-11. DEFAULT-ZERO VALUES: SOCMI PROCESS UNITS

Equipment type Default-zero emission rate (kg/hr/source) a
Gas valve 6.6E-07 Light liquid valve 4.9E-07 Light liquid pump b 7.5E-06

Connectors 6.1E-07

a The default zero emission rates are for total organic compounds

(including non-VOC’s such as methane and ethane).

b The light liquid pump default zero value can be applied to

compressors, pressure relief valves, agitators, and heavy liquid pumps.

2-33TABLE 2-12. DEFAULT-ZERO VALUES: PETROLEUM INDUSTRY

Equipment type/service Default-zero emission rates a,b (kg/hr/source)
Valves/all 7.8E-06 Pump seals/all 2.4E-05
Others c /all 4.0E-06 Connectors/all 7.5E-06 Flanges/all 3.1E-07 Open-ended lines/all 2.0E-06

a Default zero emission rates were based on the combined

1993 refinery and marketing terminal data only (default zero data were not collected from oil and gas production facilities).

b These default zero emission rates are for total organic

compounds (including non-VOC’s such as methane and ethane).

c The "other" equipment type was developed from instruments,

loading arms, pressure relief valves, stuffing boxes, vents, compressors, and dump lever arms. This "other" equipment type should be applied to any equipment type other than connectors, flanges, open-ended lines, pumps, or valves.

2-34screening value of 1 ppmv or less. In cases where a monitoring instrument has a minimum detection limit greater than 1 ppmv, the default-zero leak rates presented in tables 2-11 and 2-12 are not applicable. For these cases, an alternative approach for determining a default-zero leak rate is to (1) determine one-half the minimum screening value of the monitoring instrument, and (2) enter this screening value into the applicable correlation to determine the associated default-zero leak rate. The "pegged" emission rate is the mass emission rate associated with a screening value that has "pegged" the meter on the portable screening device (i.e. the screening value is beyond the upper limit measured by the portable screening device). In the case of a screening value pegged at 10,000 ppmv, a dilution probe should be used to extend the upper limit of the portable screening device to 100,000 ppmv. Thus, screening values can be reported up to 100,000 ppmv before pegging the instrument and the correlation equation can be used to estimate the mass emissions. However, in the case of previously-collected data or in the absence of a dilution probe, pegged readings of 10,000 ppmv are sometimes reported. In such cases, the 10,000 ppmv pegged emission rates can be used to estimate the mass emissions. Table 2-13 presents the 10,000 ppmv and 100,000 ppmv pegged emission rates for SOCMI process units and table 2-14 presents the 10,000 ppmv and 100,000 ppmv pegged emission rates for petroleum industry process units. These pegged emission rates are to be used to estimate emissions when instrument readings are pegged and a dilution probe is not used. Assuming all of the organic compounds in the equipment are classified as VOC’s, total VOC emissions for each equipment type are calculated as the sum of emissions associated with each of the screening values. Section 2.4.6 discusses a correction that can be made to the predicted VOC emissions rate if some of the organic compounds in the equipment are not classified as VOC’s (such as methane and ethane). To summarize the correlation approach, each equipment piece with a screening value of zero is assigned the default-zero leak

2-35TABLE 2-13. 10,000 PPMV AND 100,000 PPMV SCREENING VALUE PEGGED EMISSION RATES FOR SOCMI PROCESS UNITS

Equipment type 10,000 ppmv pegged emission rate (kg/hr/source) a,b 100,000 ppmv pegged emission rate (kg/hr/source) a
Gas valves 0.024 0.11 Light liquid valves 0.036 0.15

Light liquid pump seals b 0.14 0.62

Connectors 0.044 0.22

a The SOCMI pegged emission rates are for total organic compounds.

b The 10,000 ppmv pegged emission rate applies only when a

dilution probe cannot be used or in the case of previously-collected data that contained screening values reported pegged at 10,000 ppmv.

c The light liquid pump seal pegged emission rates can be applied

to compressors, pressure relief valves, and agitators.

2-36TABLE 2-14. 10,000 ppmv and 100,000 PPMV SCREENING VALUE PEGGED EMISSION RATES FOR THE PETROLEUM INDUSTRY

Equipment type/service 10,000 ppmv pegged emission rate (kg/hr/source) a,b 100,000 ppmv pegged emission rate (kg/hr/source) a
Valves/all 0.064 0.140 Pump seals/all 0.074 0.160 c

Others d /all 0.073 0.110 Connectors/all 0.028 0.030 Flanges/all 0.085 0.084 Open-ended lines/all 0.030 0.079

a The petroleum industry pegged emission rates are for total

organic compounds (including non-VOC’s such as methane and ethane).
b The 10,000 ppmv pegged emission rate applies only when a

dilution probe cannot be used or in the case of previously-collected data that contained screening values reported pegged at 10,000 ppmv. The 10,000 ppmv pegged emission rate was based on components screened at greater than or equal to 10,000 ppmv; however, in some cases, most of the data could have come from components screened at greater than 100,000 ppmv, thereby resulting in similar pegged emission rates for both the 10,000 and 100,000 pegged levels (e.g., connector and flanges).

c Only 2 data points were available for the pump seal

100,000 pegged emission rate; therefore the ratio of the pump seal 10,000 pegged emission rate to the overall 10,000 ppmv pegged emission rate was multiplied by the overall 10,000 ppmv pegged emission rate to approximate the pump 100,000 ppmv pegged emission rate.

d The "other" equipment type was developed from instruments,

loading arms, pressure relief valves, stuffing boxes, vents, compressors, dump lever arms, diaphrams, drains, hatches, meters, and polished rods. This "other" equipment type should be applied to any equipment type other than connectors, flanges, open-ended lines, pumps, and valves.

2-37rate. For all equipment with a non-zero screening value, the screening value associated with each individual equipment piece is entered into the applicable correlation to predict emissions. It should be noted that each individual screening value must be entered into the correlation to predict emissions for an equipment piece. Do not average screening values and then enter the average value into the correlation to estimate emissions. Finally, each equipment piece with a screening value reported as pegged is assigned the appropriate pegged emission rate. 2.3.4 Unit-Specific Correlation Approach To develop unit-specific correlations screening value and corresponding mass emissions data (i.e., bagging data) must be collected from process unit equipment. (See chapter 4.0 for a detailed discussion on the procedures for bagging equipment.) The equipment selected for bagging should be screened at the time of bagging. The mass emissions rate determined by bagging, and the associated screening value, can then be used to develop a leak rate/screening value relationship (i.e., correlation) for that specific equipment type in that process unit. The correlations must be developed on a process unit basis to minimize the error associated with differing leak rate characteristics between units. If a unit-specific correlation is developed, as long as the procedures for bagging discussed in chapter 4.0 are followed, it is not necessary to demonstrate that the correlation is statistically different from the EPA correlation for it to be applied. However, before developing unit-specific correlations, it may be desirable to evaluate the validity of the EPA correlations to a particular process unit. As few as four leak rate measurements of a particular equipment type in a particular service can be adequate for this purpose. The measured emission rates can be compared with the rates that would be predicted by the EPA correlations to evaluate whether or not the EPA correlations provide reasonable mass emission estimates. A simple method of comparison is to determine if measured emission rates are consistently less than or greater than what would be

2-38predicted by the EPA correlation. If there is a consistent trend, such as all of the measured leak rates being lower than the rate predicted by the EPA correlation, the EPA correlation may not provide reasonable emission estimates for the process unit. A more formal comparison is the Wilcoxon signed-rank test. This test can be performed by comparing the logarithm of the measured mass emission rates to the logarithm of the corresponding rates predicted by the EPA correlation. The absolute magnitude of the differences are then ranked (e.g., the pair with the smallest difference is assigned a rank of 1, the pair with the next smallest difference a rank of 2, etc.), and the sum of the ranks associated with positive differences is computed. For example, if four bags were measured and they each predicted higher mass emission rates than the EPA correlation, the value of the sum of the ranks associated with those pairs with positive differences would equal:

1 + 2 + 3 + 4 = 10

On the other hand, if four bags were measured and three predicted higher mass emission rates than the EPA correlation, but the one with the greatest absolute difference predicted a lower rate than the EPA correlation, then the sum of the positive ranks would equal:

1 + 2 + 3 = 6. (Note: The sum of the negative ranks would equal 4).

The value of the sum of the positive ranks can be compared to given values on statistical tables to evaluate if there are statistically significant differences between the measured rates and the rates predicted by the EPA correlation. However the comparison is performed, in cases where the EPA correlations provide an adequate estimate of emissions, then the potential increase in accuracy obtained by developing

2-39unit-specific correlations may not be worth the effort. Consideration should also be given to the typical screening value measured at a process unit. If a process unit normally has very low screening values, then the difference between the sum of unit equipment leak emissions predicted by a unit-specific correlation and the EPA correlation will likely be relatively small. In developing new correlations, a minimum number of leak rate measurements and screening value pairs must be obtained according to the following methodology. First, equipment at the process unit is screened so that the distribution of screening values at the unit is known. Then, mass emissions data must be collected from individual sources that have screening values distributed over the entire range. The criteria for choosing these sources is as follows. For each equipment type (i.e., valves, pumps, etc.) and service (i.e., gas, light liquid, etc.), a random sample of a minimum of six components should be chosen for bagging from each of the following screening value ranges:

Screening Value Range (ppmv)
1 - 100 101 - 1,000 1,001 - 10,000 10,001 - 100,000 > 100,000

The requirement of six bags per screening value range is based on the EPA experience with bagging components. There are two primary reasons for the above requirement: (1) to be confident in the representativeness of the data, and (2) to accurately reflect the range of possible mass emission rates associated with a given screening value. The importance of the first reason is self-evident: The more data collected the better the representativeness. The importance of the second reason is that a given screening value does not necessarily have a "true" emissions rate. For a single screening value, the mass emissions may range over several orders of magnitude depending upon several

2-40factors, including the equipment type (i.e., gate valve versus ball valve versus plug valve, etc.) and operating parameters (i.e., chemical handled, temperature, pressure, etc.). This range of possible mass emission rates is accounted for when the correlation is developed (see discussion on the scale bias correction factor), and it is important to obtain enough data to accurately reflect the range. If six sources are not available in a particular screening value range, additional sources from the nearest range should be tested so that a minimum of 30 emission rate/screening value pairs are obtained for each source type. If 30 or more bags are collected, the process unit-specific correlation can be used to estimate emissions across the entire range of screening values (1 to 1,000,000 ppmv). In some cases, it may be desirable to develop a correlation with fewer than 30 bags. This can be accomplished by developing a correlation that is not valid across the entire range of screening values. Two alternatives are available: (1) to develop a correlation valid for screening values ranging from 1 to 100,000 ppmv, or (2) to develop a correlation valid for screening values ranging from 1 to 10,000 ppmv. These alternatives may be preferable for process units with equipment that do not normally have high screening values. An example of this type of process unit is one that already has a leak detection and repair program in place to prevent the release of odor-causing chemicals. At this type of process unit, leaks may be quickly detected and repaired. For the first alternative, a minimum of 24 bags are required, rather than 30, because sources with screening values greater than 100,000 ppmv do not need to be bagged. Thus, a minimum of six sources each should be chosen for bagging from each of the screening ranges presented above except for the greater than 100,000 ppmv range. In the event that a source screens at 100,000 ppmv or greater, emissions can be estimated using "pegged" emission rates shown in table 2-13 for SOCMI process units, and in table 2-14 for petroleum industry process units.

2-41For the second alternative, a minimum of 18 bags are required, because sources screening greater than 10,000 ppmv do not need to be bagged. Thus, a minimum of six sources should be chosen for bagging from the 1 to 100 ppmv range, the 100 to 1000 ppmv range, and the 1,000 to 10,000 ppmv range. In the event that a source screens at 10,000 ppmv or greater, emissions can be estimated using the applicable greater than or equal to 10,000 ppmv pegged emission rate presented in table 2-13 for SOCMI process units, or table 2-14 for petroleum industry process units. An advantage of using the greater than or equal to 10,000 ppmv pegged emission rates is that several of the available portable monitoring instruments have a maximum readout of 10,000 ppmv, and to obtain a screening value from a source screening at 10,000 ppmv, it is necessary to install a dilution probe. However, if the greater than or equal to 10,000 ppmv factor is used, installing a dilution probe is not necessary for this alternative. The above groupings and recommended number of sources are given as guidelines. They are based on experience in measuring leak rates and developing leak rate/screening value correlations. Other source selection strategies can be used if an appropriate rationale is given. With mass emissions data and screening values, leak rate/screening value correlations can be generated using the following methodology. Least-squares regression analyses are completed for each equipment type/service, regressing the log of the leak rate on the log of the screening concentration, according to:

Log 10 (leak rate [in kg/hr]) = β 0 + β 1 × Log 10 (SV)

where: β 0 , β 1 = Regression constants; and
SV = Screening value.

2-42Note that the results are the same whether the base 10 or natural logarithm are used (see appendix B). The equations presented here are written assuming the base 10 logarithm is used. All analyses should be conducted using logarithms of both the leak rate and screening value because this type of data has been shown to be log-normally distributed. A scale bias correction factor (SBCF) is required in transforming the equation in the log-scale back to the original units. The transformed equation is the unit-specific correlation, and is expressed as:

where: Leak rate = SBCF x 10 β 0 x SV β 1

Leak rate = Emission rate of TOC’s from the individual equipment piece (kg/hr);

SBCF = Scale bias correction factor; β 0 , β 1 = Regression constants; and
SV = Screening value.

The SBCF is a function of the mean square error of the correlation in log space. The greater the range of possible emission rates for a given screening value, the greater the SBCF will be. The purpose of the SBCF is to reflect this range when transforming the correlation out of log space. When regressed in log space, in general, approximately half of the data points will lie above the correlation line and half will lie below it, and, for a given screening value, the correlation will pass through the mean log leak rate (i.e., the geometric mean). Thus, one way of thinking of the correlation in log space is that it predicts the geometric mean emissions rate across the range of screening values. However, the geometric mean always underestimates the arithmetic mean. A simplified hypothetical example will help demonstrate this point: For a screening value of 500,000 ppmv, three bagging data points were obtained with mass emission rates of 0.1 kg/hr,

2-431 kg/hr, and 10 kg/hr. In log space, these emission rates correspond to log 10 (0.1) = -1, log 10 (1) = 0, and log 10 (10) = 1, respectively. Thus, the geometric mean of these three points is (- 1+0+ 1)/3 = 0. Directly transforming this geometric mean to normal space predicts an emission rate for a screening value of 500,000 ppmv of 10 0 = 1 kg/hr, whereas the arithmetic mean of the emission rates is (0.1 + 1 + 10)/3 = 3.7 kg/hr. From this example, it can be seen that the geometric mean underestimates the arithmetic mean. Thus, if the correlation was directly transformed, it would underestimate the true average emission rate associated with a given screening value, and, for this reason, the SBCF is necessary to transform the correlation out of log space. In appendix B, additional details on developing a process-unit specific correlation are presented. Appendix B also contains information on development of the revised SOCMI correlations.
2.4 SPECIAL TOPICS There are several special topics relevant to estimating equipment leak emissions that are not specific to any one of the four approaches that have been described. These special topics are discussed in this section: Speciating emissions;
Using response factors;
Monitoring instrument type and calibration gas;
Estimating emissions for equipment not screened (when other screening data are available);
Using screening data collected at several different times;
Estimating VOC emission rates from equipment containing organic compounds not classified as VOC’s (such as methane and ethane); and
Estimating equipment leak emissions of inorganic compounds.

2-44Each of these topics above are addressed in the following sections. 2.4.1 Speciating Emissions For each of the four approaches for estimating equipment leak emissions, the equations presented are used to estimate TOC emissions for estimating equipment leak emissions. Often, in a chemical-handling facility, material in equipment is a mixture of several chemicals, and, in some cases, it may be necessary to estimate emissions of a specific VOC in the mixture. The following equation is used to speciate emissions from a single equipment piece:

E x = E TOC × (WP x /WP TOC )

where:

E x = The mass emissions of organic chemical "x" from the equipment (kg/hr);

E TOC = The TOC mass emissions from the equipment (kg/hr) calculated from either the Average Emission Factor, Screening Ranges, Correlation, or Unit-Specific Correlation approaches;

WP x = The concentration of organic chemical "x" in the equipment in weight percent; and

WP TOC = The TOC concentration in the equipment in weight percent.
An assumption in the above equation is that the weight percent of the chemicals in the mixture contained in the equipment will equal the weight percent of the chemicals in the leaking material. In general, this assumption should be accurate for single-phase streams containing (1) any gas/vapor material, or (2) liquid mixtures containing constituents of similar volatilities. If the material in the equipment piece is a liquid mixture of constituents with varying volatilities, in certain cases this assumption may not be correct. Whether or not the assumption is valid for a liquid mixture of varying volatilities depends on the physical mechanism of how the leakage occurs from the equipment.

2-45If the physical mechanism is one in which the liquid "flashes" before it leaks from the equipment, the leaking vapor may contain a higher concentration of the more volatile constituents than is contained in the liquid mixture. On the other hand, if the mechanism is one in which the liquid material leaks from the equipment and then evaporates, the assumption that the weight percent of each constituent in the liquid will equal the weight percent of each constituent in the vapor is valid. There are no clear guidelines to determine what mechanism is taking place for any given piece of equipment; for this reason, unless there is information to suggest otherwise, it should be assumed that the leaking vapor has the same concentrations as the liquid. For those cases where it is suspected the leaking vapor will have different concentrations than the liquid, engineering judgement should be used to estimate emissions of individual chemical species. An example might be equipment containing material in two phases. Another hypothetical example is a case where equipment contain a liquid mixture of two constituents with one of the constituents having a very low vapor pressure and the other a much higher vapor pressure. Leaks may occur from the equipment such that the constituent with higher vapor pressure volatilizes to the atmosphere, but the constituent with lower vapor pressure is washed to the waste water treatment system prior to volatilization. 2.4.2 Using Response Factors A correction factor that can be applied to a screening value is a response factor (RF) that relates the actual concentration to the measured concentration of a given compound, using a specific reference gas. As stated earlier, screening values are obtained by using a portable monitoring instrument to detect VOC’s at an equipment piece leak interface. An "ideal" screening RF value is one that is equal to the actual concentration of VOC’s at the leak interface. However, portable monitoring instruments used to detect TOC concentration do not respond to different TOC’s equally. (This is discussed in more detail in chapter 3.0). To demonstrate this point, consider a monitoring

2-46instrument calibrated using a reference gas. If the instrument is calibrated correctly and is used to measure the concentration of the gas with which it has been calibrated, it will indicate the actual concentration. However, when used to measure other gases for which the monitoring instrument is more or less sensitive than the calibration gas, it will not indicate the actual concentration. To correct for this, RF’s have been developed. The RF is calculated using the equation:

RF = AC/SV

where:
RF = Response factor;
AC = Actual concentration of the organic compound (ppmv); and
SV = Screening value (ppmv).

The value of the RF is a function of several parameters. These parameters include the monitoring instrument, the calibration gas used to calibrate the instrument, the compound(s) being screened, and the screening value. The correlations presented in this chapter have been developed primarily from screening value/mass emission data pairs collected from equipment containing compounds that had RF’s less than three. Thus, for cases in which a calibrated instrument is used to measure concentrations of a compound for which that instrument has an RF of three or less, reasonably accurate emission estimates can be obtained directly without adjusting the screening value. However, for a case in which a compound has an RF greater than three for the calibrated instrument, the emissions estimated using the unadjusted screening value will generally underestimate the actual emissions. The EPA recommends that if a compound (or mixture) has an RF greater than three, then the RF should be used to adjust the screening value before it is used in estimating emissions.

2-47A detailed listing of published RF’s is contained in appendix D. These RF’s were developed by injecting a known concentration of a pure compound into a monitoring instrument and comparing that actual concentration to the instrument readout (i.e., screening value). As an example of applying a RF, consider chloroform. From table D-2 in appendix D, it can be seen that the RF for chloroform at an actual concentration of 10,000 ppmv is equal to 4.48 for a Foxboro OVA-108 monitoring instrument calibrated with methane. Thus, when the actual concentration of chloroform is 10,000 ppmv, the instrument will read 10,000 ppmv divided by 4.48, which equals 2,230 ppmv. If the measured value for chloroform was directly entered into the correlation, it would tend to underestimate emissions. (Note that when the RF is less than 1 the unadjusted screening value will tend to overestimate actual emissions.) The RF’s in appendix D are for pure compounds. Those RF’s can be used to estimate the RF for a mixture using the equation:

where: RF m = 1

n

i 1 x i /RF i

RF m = Response factor of the mixture; n = Number of components in the mixture;

x i = Mole fraction of constituent i in the mixture; and

RF i = Response factor of constituent i in the mixture. This equation is derived in appendix A. An alternative approach for determining the RF of a pure compound or a mixture is to perform analysis in a laboratory to generate the data used to calculate a RF. The approach for generating these data in the laboratory is described in chapter 3.0. The approach involves injecting samples of a known concentration of the material of interest into the actual portable monitoring instrument used to obtain the screening values and calculating the RF based on the instrument readout.

2-48In general, calculating the RF by performing analysis on site will give the most accurate RF information, since, among other factors, RF’s have been shown to be a function of the individual monitoring instrument. Ideally, when using screening values to estimate equipment leak emissions, the RF would be equal to 1, and, in this way, the screening value would be the actual concentration. However, because RF’s are a function of several parameters, this cannot normally be achieved. Response factors can be used to correct all screening values, if so desired. To evaluate whether a RF correction to a screening value should be made, the following three steps can be carried out. (1) For the combination of monitoring instrument and calibration gas used, determine the RF’s of a given material at an actual concentration of 500 ppmv and 10,000 ppmv. (See appendix D; in some cases, it may not be possible to achieve an actual concentration of 10,000 ppmv for a given material. In these cases, the RF at the highest concentration that can be safely achieved should be determined.)
(2) If the RF’s at both actual concentrations are below 3, it is not necessary to adjust the screening values.
(3) If either of the RF’s are greater than 3, then the EPA recommends an RF be applied for those screening values for which the RF exceeds 3.
One of the following two approaches can be applied to correct screening values: (1) Use the higher of either the 500 ppmv RF or the 10,000 ppmv RF to adjust all screening values.
(2) Generate a response factor curve to adjust the screening values.
A RF curve can be generated in one of two ways. The simplest way is to assume that the RF value is a linear function of the screening value. The first step to generate a line relating screening value to RF is to convert the RF at the actual concentration to the RF at the associated screening value. This is done by dividing the RF by the actual concentration to get the associated screening value. Thus, if, at an actual concentration

2-49of 10,000 ppmv, an instrument has a RF of 5, this corresponds to a screening value of 2,000 ppmv (i.e., 10,000 ppmv divided by 5). This procedure is implemented at both actual concentrations of 10,000 ppmv and 500 ppmv, and a line is drawn between the RF’s at each associated screening value. This line can then be used to estimate the RF at any given screening value. (See appendix A for a demonstration of this procedure.) The line should not be extrapolated for screening values beyond the endpoints. For these screening values, the endpoint RF should be applied. For some materials, the RF is nonlinear as the screening value increases. For these materials, RF’s at several screening values can be estimated by collecting data in a laboratory, as mentioned earlier. The RF/screening value relationship can then be generated by fitting a curve through the data pairs. When an RF is used, the screening value is multiplied by the RF before mass emissions are estimated. Thus, if a screening value is 3,000 ppmv and the associated RF is 4, then the screening value must be adjusted to 12,000 ppmv (i.e., 3,000 multiplied by 4) before mass emissions are predicted. It should be noted that if it is possible to calibrate the monitoring instrument with the material contained in the equipment that is being screened, the RF should equal 1. Thus, theoretically, the screening values will equal the actual concentration, and no RF adjustment will be necessary. If it is necessary to apply RF’s, site personnel should use engineering judgement to group process equipment into streams containing similar compounds. All components associated with a given stream can then be assigned the same RF, as opposed to calculating an RF for each individual equipment piece. 2.4.3 Monitoring Instrument Type and Calibration Gas When the correlations presented in section 2.3 were developed, in general, for each of the source categories, the data were collected using a specific type of monitoring instrument calibrated with a specific calibration gas. The correlations are intended to relate actual concentration to mass emissions. For this reason, screening values obtained from any

2-50combination of monitoring instrument and calibration gas can be entered directly into the correlations as long as the screening values are an indication of actual concentration. If the screening values are not an indication of the actual concentration, the guidelines set forth in the previous section on RF’s can be applied to correct the screening values (i.e., screening values should be adjusted if the RF is greater than 3). Otherwise, it is not necessary to correct screening values to account for the instrument type and calibration gas that were used to develop the correlation curves developed by
the EPA. 2.4.4 Estimating Emissions for Equipment Not Screened Often, screening data cannot be collected for all of the equipment pieces in a process unit. In some cases, equipment are difficult or unsafe to screen. Difficult or unsafe to screen equipment must be included in the equipment counts. For these equipment pieces, the average emission factors must be used to estimate emissions. In other cases, it is not possible to screen every equipment piece due to cost considerations. This is particularly true for connectors. Appendix E provides criteria for determining how many connectors must be screened to constitute a large enough sample size to identify the screening value distribution for connectors. If the criteria in appendix E are met, the average emission rate for connectors that were screened can be applied to connectors that were not screened. It should be noted that if connectors must be included in a leak detection and repair program as part of an equipment leaks standard, then all connectors must be screened. For equipment types other than connectors, if they are not monitored, the Average Emission Factor approach should be used to estimate emissions. 2.4.5 Using Screening Data Collected at Several Different Times When screening data is collected and used to estimate emissions, the emissions estimate represents a "snapshot" of emissions at the time the screening data were obtained. Over

2-51time, it is possible that more screening data will be collected, and that for individual equipment pieces, several screening values will have been obtained at different time periods. For example, if quarterly monitoring is performed on a valve, in an annual period four screening values will be obtained from the valve. The annual emissions from the valve should be calculated by determining the emissions for each quarter based on the operational hours for the quarter, and summing the quarterly emissions together to arrive at emissions for the entire year. See appendix A for an example of estimating emissions from an equipment piece for which more than one screening value has been obtained. 2.4.6 Estimating VOC Emission Rates from Equipment Containing Non-VOC’s Some organic compounds not classified as VOC’s can be detected by the screening instrument. Because the compounds are detected, the emissions associated with the screening value will include emissions of the "non-VOC’s." The two key organic compounds not classified as VOC’s are methane and ethane, but other organic compounds not classified as VOC’s include methylene chloride, 1,1,1-trichloroethane, and several chlorofluorocarbons. An approach very similar to that outlined in section 2.4.1 (Speciating Emissions) is used to estimate VOC emissions from equipment containing these non-VOC’s mixed with VOC’s. Once TOC emissions have been estimated by using either the Average Emission Factor, the Screening Ranges, the Correlation, or the Unit-Specific Correlation approaches, the VOC emissions from a group of equipment containing similar composition can be calculated using the equation:

E VOC = E TOC × (WP VOC /WP TOC )

where:

E VOC = The VOC mass emissions from the equipment (kg/hr);

E TOC = The TOC mass emissions from the equipment (kg/hr) calculated form either the Average

2-52Emission Factor, Screening Ranges, Correlation, or Unit-Specific Correlation approaches;

WP VOC = The concentration of VOC in the equipment in weight percent;

WP TOC = The TOC concentration in the equipment in weight percent.

2.4.7 Estimating Equipment Leak Emissions of Inorganic Compounds The majority of data collected for estimating equipment leak emissions has been for TOC’s or VOC’s and not for inorganic compounds. Accordingly, the emission factors and correlations presented in section 2.3 are not intended to be applied for the used of estimating emissions of inorganic compounds. However, in some cases, there may be a need to estimate equipment leak emissions of inorganic compounds--particularly for those that exist as a gas/vapor or for those that are volatile. Some examples of inorganic compounds include sulfur dioxide, ammonia, and hydrochloric acid. The best way to estimate equipment leak emissions of inorganic compounds would be to develop unit-specific correlations as described in section 2.3.4. To do this, it would be necessary to obtain a portable monitoring instrument that could detect the inorganic compounds. If it is not possible to develop a unit-specific correlation, but a portable monitoring instrument (or some other approach) can be used to indicate the actual concentration of the inorganic compound at the equipment leak interface, then the "screening values" obtained with this instrument can be entered into the applicable correlations presented in section 2.3.3 to estimate emissions. Alternatively, the equal to or greater than 10,000 ppmv, or the less than 10,000 ppmv emission factors could be applied. In the event that there is no approach that can be used to estimate the concentration of the inorganic compound at the leak interface, then in the absence of any other data, the average emission
factors can be used.

2-532.5 REFERENCES

1. Radian Corporation. Assessment of Atmospheric Emissions from Petroleum Refining: Volume 4. Appendices C, D, E. Prepared for U.S. Environmental Protection Agency. Research Triangle Park, NC. Publication No. EPA-600/2-80-075d. July 1980.
2. Wetherhold, R.G., L.P. Provost, and C.D. Smith (Radian Corporation). Assessment of Atmospheric Emissions from Petroleum Refining: Volume 3. Appendix B. Prepared for U.S. Environmental Protection Agency. Research Triangle Park, NC. Publication No. EPA-600/2-80-075c. April 1980.
3. DuBose, D.A., J.I. Steinmetz, and G.E. Harris (Radian Corporation). Frequency of Leak Occurrence and Emission Factors for Natural Gas Liquid Plants. Final Report. Prepared for U.S. Environmental Protection Agency. Research Triangle Park, NC. EMB Report No. 80-FOL-1. July 1982.
4. 1993 Study of Refinery Fugitive Emissions from Equipment Leaks, Volumes I, II, and III, Radian DCN No. 93-209-081-02, Radian Corporation, Prepared for Western States Petroleum Association, Glendale, CA, and American Petroleum Institute, Washington, D.C., 1994.
5. Development of Fugitive Emission Factors and Emission Profiles for Petroleum Marketing Terminals, Volumes I and II, API 4588, Radian Corporation, Prepared for American Petroleum Institute, 1993.
6. Fugitive Hydrocarbon Emissions from Oil and Gas Production Operations, API 4589, Star Environmental, Prepared for American Petroleum Institute, 1993.
7. Emission Factors for Oil and Gas Production Operations, API 4615, Star Environmental, Prepared for American Petroleum Institute, 1995.
8. Letter from Robert Strieter, API, to David Markwordt, U.S. EPA, regarding the submittal of gasoline distribution facility fugitive equipment screening data. April 26, 1994.
9. Blacksmith, J.R., et al. (Radian Corporation.) Problem-Oriented Report: Frequency of Leak Occurrence for Fittings in Synthetic Organic Chemical Plant Process Units. Prepared for U.S. Environmental Protection Agency. Research Triangle Park, NC. Publication No. EPA-600/2-81-003. September 1980.
10. Langley, G.J. and R.G. Wetherhold. (Radian Corporation.) Evaluation of Maintenance for Fugitive VOC Emissions Control.

2-54Prepared for U.S. Environmental Protection Agency. Research Triangle Park, NC. Publication No. EPA-600/S2-81-080. May 1981.
11. U.S. Environmental Protection Agency. Fugitive Emission Sources of Organic Compounds - Additional Information of Emissions, Emission Reductions, and Costs (section 2). Research Triangle Park, NC. Publication No. EPA-450/3 82-010. April 1982.

2-553.0 SOURCE SCREENING

3.1 INTRODUCTION This chapter presents procedures for screening equipment components with a portable volatile organic compound (VOC) analyzer. When performing source screening, the portable analyzer probe opening is placed at the leak interface of the equipment component to obtain a "screening" value. The screening value is an indication of the concentration level of any leaking material at the leak interface. A screening value is not a direct measure of mass emissions rate, but, as discussed in chapter 2.0, can be entered into a mass emissions/screening value correlation equation to estimate mass emissions. This chapter is divided into two sections. The first section provides a description of the portable analyzers that can be used when conducting screening surveys. Operating principles of the analyzers and performance criteria and specifications in the EPA Reference Method 21 (the method describing the use of portable VOC analyzers) 1 are described, and the use of monitoring devices that do not meet the EPA Reference Method 21 requirements is discussed. The second section presents the protocol for successfully conducting a screening program. This section includes methods to identify components to be included in the screening program, a discussion on the development of a systematic approach for performing the screening survey, the protocol for screening each of the equipment types, and recommendations for collecting and handling data.

3-13.2 MONITORING INSTRUMENTS A number of portable VOC detection devices have the potential to measure the concentration level at the leak interface of equipment. Any analyzer can be used, provided it meets the specifications and performance criteria set forth in the EPA Reference Method 21, section 3.0. 1 . Reference Method 21 is included in this document as appendix F. In general, portable VOC monitoring instruments are equipped with a probe that is placed at the leak interface of a piece of equipment. A pump within the instrument draws a continuous sample of gas from the leak interface area to the instrument detector. The instrument response is a screening value--that is, a relative measure of concentration level. The screening value is in units of parts per million by volume (ppmv). However, the screening value does not necessarily indicate the actual total concentration at the leak interface of the compound(s) being detected because the sensitivity of instruments vary for different compounds. As discussed in section 2.4.2, response factors (RF’s) relate actual concentration of a compound to the observed concentration from the detector. Before a monitoring instrument is used, it must first be calibrated using a reference gas containing a known compound at a known concentration. Methane and isobutylene are frequently used reference compounds. 3.2.1 Operating Principles and Limitations of Portable VOC Detection Devices Monitoring instruments operate on a variety of detection principles, with the three most common being ionization, infrared absorption, and combustion. Ionization detectors operate by ionizing the sample and then measuring the charge (i.e., number of ions) produced. Two methods of ionization currently used are flame ionization and photoionization. Each of these detector types are briefly described below. A standard flame ionization detector (FID) theoretically measures the total carbon content of the organic vapor sampled, but many other factors influence the FID readout. Although carbon monoxide and carbon dioxide (CO 2 ) do not produce

3-2interferences, FID’s react to water vapor at a low sensitivity. Furthermore, erratic readings may result if water condenses in the sample tube. A filter is used to remove particulate matter from the sample. Certain portable FID instruments are equipped with gas chromatograph (GC) options making them capable of measuring total gaseous non-methane organics or individual organic components. Certain organic compounds containing nitrogen, oxygen, or halogen atoms give a reduced response when sampled with an FID, and the FID may not respond to some organic compounds. Photoionization detectors use ultraviolet light (instead of a flame) to ionize organic vapors. As with FID’s, the detector response varies with the functional group in the organic compounds. Photoionization detectors have been used to detect equipment leaks in process units in the SOCMI, especially for certain compounds, such as formaldehyde, aldehydes, and other oxygenated compounds, which will not give a satisfactory response on a FID or combustion-type detector. Nondispersive infrared (NDIR) instruments operate on the principle of light absorption characteristics of certain gases. These instruments are usually subject to interference because other gases, such as water vapor and CO 2 , may also absorb light at the same wavelength as the compound of interest. These detectors are generally used only for the detection and measurement of single components. For this type of detection, the wavelength at which a certain compound absorbs infrared radiation is predetermined and the device is preset for that specific wavelength through the use of optical filters. For example, if set to a wavelength of 3.4 micrometers, infrared devices can detect and measure petroleum fractions, including gasoline and naphtha. Combustion analyzers are designed either to measure the thermal conductivity of a gas or to measure the heat produced by combustion of the gas. The most common method in which portable VOC detection devices are used involves the measurement of the heat of combustion. These detection devices are referred to as

3-3hot wire detectors or catalytic oxidizers. Combustion analyzers, like most other detectors, are nonspecific for gas mixtures. In addition, combustion analyzers exhibit reduced response (and, in some cases, no response) to gases that are not readily combusted, such as formaldehyde and carbon tetrachloride. 3.2.2 Specifications and Performance Criteria of Portable VOC Detection Devices As previously stated, any portable analyzer may be used as a screening device, provided it meets the specifications and the performance criteria called for in the EPA Reference Method 21. (See appendix F.) Reference Method 21 specifies the requirements that must be met when a facility is collecting screening data to comply with a regulation. The requirements of the EPA Reference Method 21 are also applicable when screening data are collected for the sole purpose of estimating emissions. When the requirements of Reference Method 21 refer to a "leak definition," this is the screening value indicating that a piece of equipment is leaking as defined in the applicable regulation. If screening data are collected for the sole purpose of estimating emissions, the equivalent to the "leak definition" concentration in the text that follows is the highest screening value (i.e., 10,000 ppmv) that the monitoring instrument can readout. Reference Method 21 requires that the analyzer meet the following specifications: 1

• The VOC detector should respond to those organic compounds being processed (determined by the RF);
• Both the linear response range and the measurable range of the instrument for the VOC to be measured and the calibration gas must encompass the leak definition concentration specified in the regulation;
• The scale of the analyzer meter must be readable to ± 2.5 percent of the specified leak definition concentration;
• The analyzer must be equipped with an electrically driven pump so that a continuous sample is provided at a nominal flow rate of between 0.1 and 3.0 liters per minute;

3-4• The analyzer must be intrinsically safe for operation in explosive atmospheres; and
The analyzer must be equipped with a probe or probe extension for sampling not to exceed .25 inch in outside diameter, with a single end opening for admission of sample. Note that the suction flow rate span allowed by Reference Method 21 is intended to accommodate a wide variety of instruments, and manufacturers guidelines for appropriate suction
flow rate should be followed. In addition to the above specifications, criteria for the calibration gases to be used are specified. A minimum of two calibration gases are required for analyzer performance evaluation. One is a "zero" gas, which is defined as air with less than 10 ppmv VOC; the other calibration gas, or reference gas, uses a specified reference compound in an air mixture. The concentration of the reference compound must approximately equal 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 ± 2 percent accuracy. The shelf life must also be specified. Calibration gases can also be prepared by the user as long as they are accurate to within ± 2 percent. The instrument performance criteria that each analyzer must meet are presented in table 3-1 and discussed in greater detail in the following sections. 3.2.2.1 Response Factor . The sensitivity of an analyzer varies, depending on the composition of the sample and concentration of VOC detected. The RF quantifies the sensitivity of the analyzer to each compound. The RF is defined by:

An RF must be determined for each compound that is to be RF = Actual Concentration of Compound Observed Concentration from Detector

measured. Response factors may be determined either by testing or from referenced sources. (The RF’s for many commonly screened compounds are presented in appendix D.) The RF tests are

3-5TABLE 3-1. PERFORMANCE CRITERIA FOR PORTABLE VOC DETECTORS a

Criteria Requirement Time interval

Instrument response factor Must be <10 unless correction curve is used One time, before detector is put in service.

Instrument response time Must be ≤ 30 seconds One time, before detector is put in service. If modification to sample pumping or flow configuration is made, a new test is required.
Calibration precision Must be ≤ 10 percent of calibration gas value Before detector is put in service and at 3-month intervals or next use, whichever is later.

a Source: Reference 1.

3-6required before placing the analyzer into service, but do not need to be repeated. The RF for each compound to be measured must be less than 10 for an analyzer to be acceptable for use in a screening program. According to Reference Method 21, the RF can either be measured in the laboratory using a prepared gas concentration at 80 percent of the applicable leak definition, or it can be taken from values published in the literature. When no instrument is available that meets this criteria when calibrated with the reference compound specified in the applicable regulation, the available instrument may be calibrated with one of the VOC’s to be measured. However, the analyzer RF must still
be less than 10 for each VOC to be measured. As discussed in section 2.4.2, RF’s depend on several parameters, including the compound, the screening value, the monitoring instrument, and the calibration gas. In chapter 2.0, guidance was provided on when and how to apply RF’s for estimating emissions. Methods were presented on calculating an RF for a given chemical at a screening value other than one for which data were published. Methods were also presented for calculating RF’s for mixtures. In this chapter, several additional issues pertaining to RF’s are discussed. These issues are (1) the consideration of RF’s when selecting a monitoring instrument, (2) how laboratory analysis can be performed to generate data to determine an RF for a given compound, and (3) when laboratory analysis is
recommended. Response factors contained in appendix D can be used as a guide for selecting an appropriate monitoring device. If at the applicable leak definition, the RF of an instrument is greater than 10, that instrument does not meet Reference Method 21 requirements unless a substitute reference gas is used to calibrate the instrument. For example, at a concentration of 10,000 ppmv, it can be seen that when screening equipment in a process unit that contains cumene, an FID can be used (RF = 1.92 at an actual concentration of 10,000 ppmv), while the catalytic oxidation detector cannot (RF = 12.49). Similarly, at a

3-7concentration of 10,000 ppmv, neither of these devices respond to carbon tetrachloride and, therefore, cannot be used unless calibrated with a substitute VOC such that an RF of under 10 can be calculated for this compound. Response factors can be determined by laboratory analysis using the following method. First, the analyzer is calibrated using the reference gas. Then, for each organic species that is to be measured, a known standard in air is obtained or prepared. The concentration of the organic species should be at approximately the leak definition value. This mixture is then injected into the analyzer and the observed meter reading is recorded. The analyzer is then "zeroed" by injecting zero air until a stable reading is obtained. The procedure is repeated by alternating between the mixture and zero air until a total of three measurements are obtained. An RF is calculated for each repetition and then averaged over the three measurements. This procedure can be repeated at several different concentration values. The data can then be used to generate a curve that relates RF to screening value. (See appendix A.) The most accurate method for estimating RF’s is to perform laboratory analysis. This is particularly true because RF’s vary, not just for the detector type, but also for each individual instrument. However, in some cases, time and resource constraints may require the use of published RF data. Nevertheless, a limitation of the published data is that it is typically specific to a pure compound for a single actual concentration value, detector type, and calibration gas. Additionally, although an RF for mixtures can be calculated as described in section 2.4.2 (i.e., if an RF is known for each individual compound), the most accurate RF for a mixture is calculated by preparing known standards of air for the mixture and injecting the standard into the analyzer as described earlier.

3-83.2.2.2 Response Time . The response time of an analyzer is defined as the time interval from a step change in VOC concentration at the input of a sampling system, to the time at which the corresponding concentration value is reached as displayed on the analyzer readout meter. Response time is determined by introducing zero air into the instrument sample probe. When the meter reading has stabilized, the specified calibration gas is injected. The response time is measured as the time lapsed between switching to the calibration gas and the time when 90 percent of the final stable reading is obtained. This test is performed three times and the response time is calculated as the average of the three tests. The response time must be equal to or less than 30 seconds for the analyzer to be acceptable for screening purposes. The response time test is required before placing an analyzer in service. The response time must be determined for the analyzer configuration that will be used during testing. If a modification to the sample pumping system or flow configuration is made that would change the response time (e.g., change in analyzer probe or probe filter, or the instrument pump), a new test is required before the screening survey is conducted. 3.2.2.3 Calibration Precision . Calibration precision is the degree of agreement between measurements of the same known value. To ensure that the readings obtained are repeatable, a calibration precision test must be completed before placing the analyzer in service, and at 3-month intervals, or at the next use, whichever is later. The calibration precision must be equal to or less than 10 percent of the calibration gas value. To perform the calibration precision test, three measurements are required for each non-zero concentration. Measurements are made by first introducing zero gas and adjusting the analyzer to zero. The specified calibration gas (reference) is then introduced and the meter reading is recorded. This procedure must be performed three times. The average algebraic difference between the meter readings and the known value of the calibration gas is then computed. This average difference is then divided by

3-9the known calibration value and multiplied by 100 to express the resulting calibration precision as percent. The calibration precision of the analyzer must be equal to or less than 10 percent of the calibration gas value. 3.2.2.4 Safety . Portable instruments to detect VOC emissions from equipment leak sources are required to be used in potentially hazardous locations such as petroleum refineries and bulk gasoline terminals. The National Electrical Code requires that instruments to be used in hazardous locations be certified to be explosion-proof, intrinsically safe, or purged. Hazardous locations are divided into three classes: Class I, Class II, and Class III. Each class is divided into two divisions (division 1 or 2) according to the probability that a hazardous atmosphere will be present and also into seven groups, depending on the type of hazardous material exposure: Groups A through D are flammable gases or vapors, and groups E, F, and G apply to combustible or conductive gases. Class I, division 1, groups A, B, C, and D locations are those in which hazardous concentrations of flammable gases or vapors may exist under normal operating conditions. Class I, division 2, groups A, B, C, and D locations are those in which hazardous concentrations of flammable gases may exist only under unlikely conditions of operation. Any instrument considered for use in potentially hazardous environments must be classified as intrinsically safe for Class I, division 1 and class II, division 1 conditions at a minimum. The instrument must not be operated with any safety device, such as an exhaust flame arrestor, removed. Table 3-2 lists several portable VOC detection instruments. table 3-2 includes manufacturer, model number, pollutants detected, principle of operation, and range. Note that additional instruments, not listed here, may be available. 3.2.3 Use of Monitoring Devices That Do Not Meet EPA Reference Method 21 Requirements In some cases, a monitoring device may not be available that meets all of the performance specifications of the EPA Reference

3-10TABLE 3-2. PORTABLE VOC DETECTION INSTRUMENTSManufacturerModel no.Pollutant(s)detectedPrinciple ofoperationRange(ppm)Bacharach Instrument Co.,Santa Clara, CaliforniaLTLV SnifferCombustible gasesCombustible gasesCatalytic combustionCatalytic combustion0-100% LELa0-1,000 and 0-10,000Foxboro,S. Norwalk, ConnecticutOVA-128OVA-108Miran IBXMost organic compoundsMost organic compoundsCompounds that absorbinfrared radiationFID/GCFID/GCNDIR0-1,0000-10,000Compound specificHealth Consultants Detecto -PAK IIIMost organic compounds FID/GC 0-10,000HNU Systems, Inc.Newton Upper Falls,MassachusettsHW-101 Chlorinated hydrocarbons,aromatics, aldehydes,ketones, any substancethat UV light ionizesPhotoionization 0-20, 0-200, 0-2,000Mine Safety Appliances Co.,Pittsburgh, Pennsylvania40 Combustible gases Catalytic combustion 0-10% and0-100% LELaSurvey and Analysis, Inc.,Northboro, MassachusettsOn Mark Model 5Combustible gasesThermal conductivity0-5 and 0-100% LELaaLEL = Lower explosive limit.

3-11Method 21. For example, there are several cases (e.g., phosgene) where the RF at 10,000 ppmv is greater than 10. An instrument may meet all other requirements, but fail as a Reference Method 21 instrument because it cannot meet the RF requirement. If an instrument fails to meet Reference Method 21 requirements, it can still be used for the purpose of estimating emissions if its reliability can be documented. Two primary steps must be taken to document the reliability of an analyzer that fails to meet the Reference Method 21 requirements. First, a laboratory program must be undertaken to demonstrate the response of the monitoring instrument to the compounds being measured; that is, an instrument response curve must be developed for the entire screening value range and documented so that screening values taken in the field can be adjusted to actual concentrations if necessary. Second, the testing program must be sufficiently well-documented to demonstrate how the instrument will be used when screening equipment. For example, if the response time of the candidate instrument exceeds the Reference Method 21 performance specification, the test plan should reflect added screening time at each potential leak point. Once this laboratory demonstration has been completed and the screening value correction curve has been established, the instrument may be used in a screening

program. 3.3 THE SCREENING PROGRAM The goal of the screening program is to measure VOC concentrations at seals, shafts, and other potential leak points. All equipment to be included in the screening survey needs to be identified before the screening program starts. A list of equipment types that are potential sources of fugitive emissions is provided in table 3-3. 3.3.1 Identification of Equipment to be Screened The first step in the screening survey is to precisely define the process unit boundaries. This is usually straightforward, but occasionally multiple units may be built on the same pad and share some common facilities. A process unit can be defined as

3-12TABLE 3-3. EQUIPMENT LEAK EMISSION SOURCES

Equipment types

Agitator seals Compressor seals
Connectors Diaphrams Drains Dump lever arms Flanges
Hatches

Instruments Loading arms

Meters Open-ended lines Polished rods Pressure relief devices Pump seals Stuffing boxes
Valves

Vents

Service Gas/vapor Light liquid Heavy liquid

3-13the smallest set of process equipment that can operate independently and includes all operations necessary to achieve its process objective. The exact basis for the unit definition should be documented. A plot plan of the unit should be obtained and marked with the appropriate boundaries. The next step is to obtain a simplified flow diagram of the process and note the process streams. The actual screening and data collection can be done efficiently by systematically following each stream. For example, a logical starting point would be where one of the feed lines enters the process boundary. The screening team would follow that line, screening all sources, until the line terminates at the connectors of a reactor or separation step. This approach offers the advantage of screening groups of equipment with roughly the same composition of material in the line. Screening would then continue on the outlet side of the reactor or separation equipment. Minor loops, such as a bypass around a control valve, pump, or heat exchanger, should be screened on the initial pass. Larger loops of process equipment, such as parallel passes and processing alternatives, are more effectively treated as separate streams. Each source should be uniquely identified to indicate that it has been screened. For example, sources can be tagged. Tags can consist of any form of weatherproof and readily visible identification. Alternatively, a process unit can be considered appropriately tagged if the unit has a system of identifying markings with an associated diagram allowing easy location of marked sources. Once all the equipment along the major streams has been screened, the unit should be divided into a grid to search for fittings missed on the initial survey. Consistent with equipment leaks standards, equipment that is unsafe to monitor or very difficult to access does not need to be included in the survey. Documentation must be provided, however, to substantiate the unsafe or confined nature of such equipment.

3-143.3.2 Procedure for Screening Once the equipment to be screened has been identified, the procedures outlined in the EPA Reference Method 21 to screen each equipment type are followed. 1 The probe inlet is placed at the surface of the potential leak interface where leakage could occur. (The potential leak interface is the boundary between the process fluid and the atmosphere.) For equipment with no moving parts at the leak interface, the probe should be placed directly on the leak interface; for equipment with moving parts (e.g., pumps, compressors, and agitators), the probe should be placed approximately 1 centimeter off from the leak interface. Care must be taken to ensure that the probe is held perpendicular, not tangential, to the leak potential interface; otherwise, inaccurate readings will result. The probe must then be moved along the interface periphery while observing the instrument readout. If an increased meter reading is observed, slowly move the probe along the interface where concentrations register until the maximum meter reading is obtained. The probe inlet should be left at this maximum reading location for approximately two times the instrument response time. The maximum reading is recorded as the screening value. The instrument measurement may exceed the scale of the instrument. This is referred to as a "pegged" readout. For example, for several instruments, the highest readout on the scale is 10,000 ppmv. For the purposes of generating an emissions estimate, a dilution probe should be employed to measure concentrations greater than the instrument’s normal range unless average emission factors for greater than or equal to the "pegged" readout are applied. It is important to note that extending the measurement range necessitates the calibration of the instrument to the higher concentrations. Care should be taken to avoid fouling the probe with grease, dust, or liquids. A short piece of Teflon® tubing can be used as a probe tip extender and then can be snipped off as the tip fouls. In areas with a noticeable particulate loading, this tubing can be packed loosely with untreated fiberglass, which

3-15acts as a filter. (Note that the instrument must also be calibrated with this filter in place.) If a surface to be screened is obviously dirty, hold the probe tip just over the surface to avoid scooping up contaminants. Some fouling is unavoidable, so it is recommended that the probe tip filter be cleaned at least daily and any other filters on a weekly basis. Normally, these filters can be cleaned by just tapping them lightly on a table top, but if the deposits are wet and caked on, they should be washed with an aqueous solution of soap and alcohol. This solution also can be used to wash the probe and transfer line periodically. Care should be taken to blow the equipment dry before reuse. This general procedure can be used to screen equipment such as valves, connectors and flanges, pumps and compressors, open-ended lines, and other potential sources of VOC leakage, such as pressure relief devices, loading arms, stuffing boxes, instruments, vents, dump lever arms, drains, diaphrams, hatches, notes, or polished rods. The following sections describe the location on each type of equipment where screening efforts should
be concentrated.
3.3.2.1 Valves . For valves, the most common source of leaks is at the seal between the stem and housing. To screen this source, the probe opening is placed where the stem exits the packing gland and is moved around the stem circumference. The maximum reading is recorded as the screening valve. Also, the probe opening is placed at the packing gland take-up connector seat, and the probe is moved along the periphery. In addition, valve housings of multipart assemblies should be screened at the surface of all points where leaks could occur. Figures 3-1 through 3-5 illustrate screening points for several different types of valves. 3.3.2.2 Connectors and Flanges . For connectors, the probe opening is placed at the outer edge of the connector - gasket interface and the circumference of the connector is sampled. For screwed connectors, the threaded connection interface must also be screened. Other types of nonpermanent joints, such as

3-16Rising Stem Type Nonrising Stem Type Packing Nut

Packing Gland

Packing

Disk or Wedge Screen Here Stem

Packing Gland

Packing Packing Out

Screen Here

Disk or Wedge

3-17 Figure 3-1. Gate ValvesManual Globe Valve Stem

Packing Gland

Packing Screen Here Packing Nut

Screen Here

Body Seat

Disk Stem

Body Screen Here

Packing

Globe Type Control Valve

3-18 Figure 3-2. Globe Valves throughPlug Screen Here

3-19 Figure 3-3. Lubricated Plug ValveBall Valve Ball Packing Screen Here

Disk Screen Here

Butterfly Valve

3-20 Figure 3-4. Ball Valve and Butterfly ValveDiaphragm Stem

Weir Screen Here

Weir-Type Diaphragm Valve

Check Valves Swing Check

Lift Check Screen Here

Screen Here

3-21 Figure 3-5. Weir-Type Diaphragm Valve and Check Valvesthreaded connections, are sampled with a similar traverse. 3.3.2.3 Pumps, Compressors, and Agitators . Pumps, compressors, and agitators are screened with a circumferential traverse at the outer surface shaft and seal interface where the shaft exits the housing. If the source is a rotating shaft, the probe inlet is positioned within 1 centimeter of the shaft - seal interface. If the housing configuration prevents a complete traverse of the shaft periphery, all accessible portions must be sampled. All other joints on the pump or compressor housing where leakage could occur should also be sampled. Figure 3-6 illustrates screening points for two types of centrifugal pumps. 3.3.2.4 Pressure Relief Devices . The configuration of most pressure relief devices prevents sampling at the sealing seat. Because of their design and function, pressure relief devices must be approached with extreme caution. These devices should not be approached during periods of process upsets, or other times when the device is likely to activate. Similarly, care must be used in screening pressure relief devices to avoid interfering with the working parts of the device (e.g., the seal disk, the spring, etc.) For those devices equipped with an enclosed extension, or horn, the probe inlet is placed at approximately the center of the exhaust area to the atmosphere. It should be noted that personnel conducting the screening should be careful not to place hands, arms, or any parts of the body in the horn. Figure 3-7 illustrates the screening points for a spring-loaded relief valve. 3.3.2.5 Open-Ended Lines . Fugitive leaks from open-ended lines are emitted through a regularly shaped opening. If that opening is very small (as in sampling lines of less than 1 inch in diameter), a single reading in the center is sufficient. For larger openings it is necessary to traverse the perimeter of the opening. The concentration at the center must also be read.

3-223-23 Figure 3-6. Centrifugal Pumps Horizontal Centrifugal Pump Vertical Centrifugal Pump

Screen Here Stationary Casing Screen Here Moving Shaft3-24 Figure 3-7. Spring-Loaded Relief Valve Screen Here

Horn Tension Adjustment Thimble

Spring

Disk

Nozzle Alternate Screening Area if Horn Inaccessible

To Process3.3.3 Data Handling To ensure that data quality is maintained, it is recommended that data be recorded on prepared data sheets. The data collected should include the following:
1. Monitoring instrument type and model number.
2. Operator’s name.

3. Date.
4. Component identification number (ID number). (If permanent ID’s are not in place, assign ID’s as each source is screened.)
5. Component type (i.e., valve, connector, open-ended line, etc.)
6. Location/stream. (Provide brief description of where the screened component is located and the composition of material in the equipment.)
7. Service (i.e., gas, light liquid, or heavy liquid).
8. Number of hours per year the component is in service.
9. Screening value (ppmv).
10. Background concentration (ppmv).
11. Comments. If any explanation is required, it should be noted in a "comments" section.
In some cases, it may be necessary or desirable to adjust the screening values for RF. In these cases, the data sheet should be designed to accommodate extra columns for RF and corrected screening values. Table 3-4 provides an example data sheet that may be used to log measurements taken during a screening program.

3-25TABLE 3-4. EXAMPLE FIELD SHEETS FOR EQUIPMENT SCREENING DATADetector model no.Operator nameDateComponentIDComponentTypeLocation/StreamServiceOperatinghrs/yrScreeningvalue(ppmv)Background(ppmv)Comments

3-263.4 REFERENCES

1. Code of Federal Regulations, Title 40, Part 60, Appendix A. Reference Method 21, Determination of Volatile Organic Compound Leaks. Washington, DC. U.S. Government Printing Office. Revised June 22, 1990.

3-274.0 MASS EMISSION SAMPLING

4.1 INTRODUCTION This chapter describes the procedures for "bagging" equipment to measure mass emissions of organic compounds. An equipment component is bagged by enclosing the component to collect leaking vapors. Measured emission rates from bagged equipment coupled with screening values can be used to develop unit-specific screening value/mass emission rate correlation equations. Unit-specific correlations can provide precise estimates of mass emissions from equipment leaks at the process unit. However, it is recommended that unit-specific correlations are only developed in cases where the existing EPA correlations do not give reasonable mass emission estimates for the process unit. The focus of the chapter is on bagging equipment containing organic compounds, but similar procedures can be applied to bag equipment containing inorganic compounds as long as there are comparable analytical techniques for measuring the concentration of the inorganic compound. This chapter is divided into four sections. In section 4.2, the methods for bagging equipment are discussed. Considerations for bagging each equipment type are discussed in section 4.3. In section 4.4, techniques used in the laboratory analysis of bagged samples are discussed. Section 4.4 also includes a description of a rigorous calibration procedure for the portable monitoring device that must be followed. Finally, in section 4.5, quality assurance and quality control (QA/QC) guidelines are provided.

4-14.2 SAMPLING METHODS The emission rate from an equipment component is measured by bagging the component--that is, isolating the component from ambient air to collect any leaking compound(s). A tent (i.e., bag) made of material impermeable to the compound(s) of interest is constructed around the leak interface of the piece of equipment. A known rate of carrier gas is induced through the bag and a sample of the gas from the bag is collected and analyzed to determine the concentration (in parts per million by volume [ppmv]) of leaking material. The concentration is measured using laboratory instrumentation and procedures. Mass emissions are calculated based on the measured concentration and the flow rate of carrier gas through the bag. In some cases, it may be necessary to collect liquid leaking from a bagged equipment piece. Liquid can either be dripping from the equipment piece prior to bagging, and/or be formed as condensate within the bag. If liquid accumulates in the bag, then the bag should be configured so that there is a low point to collect the liquid. The time in which the liquid accumulates should be recorded. The accumulated liquid should then be taken to the laboratory and transferred to a graduated cylinder to measure the volume of organic material. Based on the volume of organic material in the cylinder (with the volume of water or nonorganic material subtracted out), the density of the organic material, and the time in which the liquid accumulated, the organic liquid leak rate can be calculated. Note that the density can be assumed to be equivalent to the density of organic material in the equipment piece, or, if sufficient volume is collected, can be measured using a hydrometer. It should be noted that in some cases condensate may form a light coating on the inside surface of the bag, but will not accumulate. In these cases, it can be assumed that an equilibrium between condensation and evaporation has been reached and that the vapor emissions are equivalent to total emissions from the source. When bagging an equipment piece, the enclosure should be kept as small as practical. This has several beneficial effects:

4-2The time required to reach equilibrium is kept to a minimum;
The time required to construct the enclosure is minimized;

A more effective seal results from the reduced seal area; and
Condensation of heavy organic compounds inside the enclosure is minimized or prevented due to reduced residence time and decreased surface area available for heat transfer. Two methods are generally employed in sampling source enclosures: the vacuum method and the blow-through method. Both methods involve enclosing individual equipment pieces with a bag and setting up a sampling train to collect two samples of leaking vapors to be taken to the laboratory for analysis. Both methods require that a screening value be obtained from the equipment piece prior to and after the equipment piece is enclosed. The methods differ in the ways in which the carrier gas is conveyed through the bag. In the vacuum method, a vacuum pump is used to pull air through the bag. In the blow-through method, a carrier gas such as nitrogen (or other inert gas) is blown into the bag. In general, the blow-through method has advantages over the vacuum method. These advantages are as follows. (1) The blow-through method is more conducive to better mixing in the bag.
(2) The blow-through method minimizes ambient air in the bag and thus reduces potential error associated with background organic compound concentrations. (For this reason the blow-through method is especially preferable when measuring the leak rate from components with zero or very low screening values.)
(3) The blow-through method minimizes oxygen concentration in the bag (assuming air is not used as the carrier gas) and the risk of creating an explosive environment. (4) In general, less equipment is required to set up the blow-through method sampling train. However, the blow-through method does require a carrier gas source, and preferably the carrier gas should be inert and free

4-3of any organic compounds and moisture. The vacuum method does not require a special carrier gas. Details of the sampling train of each of these bagging methods are discussed in sections 4.2.1 and 4.2.2, respectively. These sections also contain summaries of the steps of the sampling procedure for each method. For both methods, the approach described above for collecting and measuring liquid leak rates can be utilized. In addition to the sampling descriptions presented in the following sections, the quality control and assurance guidelines presented in section 4.5 must also be followed when bagging equipment.
4.2.1 Vacuum Method The sampling train used in the vacuum method is depicted in figure 4-1. The train can be mounted on a portable cart, which can be moved around the process unit from component to component. The major equipment items in the sampling train are the vacuum pump used to draw air through the system, and the dry gas meter used to measure the flow rate of gas through the train. In previous studies that the EPA conducted, a 4.8-cubic feet per minute Teflon® ring piston-type vacuum pump equipped with a 3/4-horsepower, air-driven motor was used. Other equipment that may be used in the train includes valves, copper and stainless steel tubing, Teflon® tubing and tape, thermometer, pressure-reading device, liquid collection device, and air-driven diaphragm sampling pumps. It also may be necessary to use desiccant preceding the dry gas meter to remove any moisture. The bag is connected by means of a bulkhead fitting and Teflon® tubing to the sampling train. A separate line is connected from the bag to a pressure-reading device to allow continuous monitoring of the pressure inside the bag. If a significant vacuum exists inside the bag when air is being pulled through, a hole is made in the opposite side of the bag from the outlet to the sampling train. This allows air to enter the bag more easily and, thus, reduces the vacuum in the enclosure. However, it is important to maintain a vacuum in the bag, since VOC could be lost through the hole if the bag became pressurized.

4-4This line should be as short as possible

Tent

Leaking Valve Cold Trap in Ice Bath (Optional)

Dry Gas Meter Trap

Hg Manometer

Control Valve

Filter

Small Diaphragm

Pump Two-Way Valve Sample Bag Vacuum Pump Pressure Reading Device

4-5 Figure 4-1. Sampling train for bagging a source using the vacuum method.In practice, it has been found that only a very slight vacuum (0.1 inches of water) is present in the bag during most of the sampling, even in the absence of a hole through the bag wall. Sufficient air enters around the seals to prevent the development of a significant vacuum in the bag. A small diaphragm sampling pump can be used to collect two samples into sample bags or canisters, which are then transported to the laboratory for analysis. The diaphragm pump can also be used to collect a background sample of the ambient air near the bagged component. The concentration in the background bag is subtracted from the average concentration in the sample bags when calculating the leak rate. Often this correction is insignificant (particularly for components with high leak rates or in cases where there is no detectable volatile organic compound (VOC) concentration measured by the portable monitoring device), and collection of a background bag is optional. However, in some cases collection of a background bag is important so that emission rates are not biased high. Any liquid that accumulates in the bag should be collected using the approach described in section 4.2. Note that if there is a concern that condensation will occur in equipment downstream from the bag outlet, a cold trap can be placed as close to the bag outlet as possible to remove water or heavy organic compounds that may condense downstream. Any organic condensate that collects in the cold trap must be measured to calculate the total
leak rate. The flow rate through the system can be varied by throttling the flow with a control valve immediately upstream of the vacuum pump. Typical flow rates are approximately 60 liters per minute ( /min) or less. A good flow rate to use is one in which a balance can be found between reaching equilibrium conditions and having a high enough concentration of organic compounds in the bag outlet to accurately measure the concentration in the laboratory. As the flow rate is decreased, the concentration of organic compounds increases in the gas flowing through the

4-6sampling system. The flow rate should be adjusted to avoid any operations with an explosive mixture of organic compounds in air. It may also be possible to increase the flow rate in order to minimize liquid condensation in the bag. The flow rate should be set to a constant rate and kept at that rate long enough for the system to reach equilibrium. To determine if equilibrium conditions have been reached, a portable monitoring device can be used to indicate if the outlet concentration has stabilized. It is not recommended that the vacuum method be used to measure the leak rate from equipment that have low screening values (approximately 10 ppmv or less), because considerable error can be introduced due to the background organic concentration in the ambient air that is pulled through the bag. In summary, the vacuum sampling procedure consists of the following steps. (1) Determine the composition of material in the designated equipment component, and the operating conditions of the component.
(2) Obtain and record a screening value with the portable monitoring instrument.
(3) Cut a bag from appropriate material (see section 4.3) that will easily fit over the equipment component.
(4) Connect the bag to the sampling train.
(5) If a cold trap is used, immerse the trap in an ice bath.
(6) Note the initial reading of the dry gas meter.
(7) Start the vacuum pump and a stopwatch simultaneously. Make sure a vacuum exists within the bag.
(8) Record the temperature and pressure at the dry gas meter.
(9) Observe the VOC concentration at the vacuum pump exhaust with the monitoring instrument. Make sure concentration stays below the lower explosive limit.
(10) Record the temperature, pressure, dry gas meter reading, outlet VOC concentration and elapsed time every 2 to 5 minutes (min).

4-7(11) Collect 2 gas samples from the discharge of the diaphragm sampling pump when the outlet concentration stabilizes (i.e., the system is at equilibrium).
(12) Collect a background bag (optional).
(13) Collect any liquid that accumulated in the bag as well as in the cold trap (if used) in a sealed container.
(14) Take a final set of readings and stop the vacuum pump. (15) Transport all samples to the laboratory, along with the data sheet.
(16) Remove the bag.
(17) Rescreen the source with the portable monitoring instrument and record.
Based on the data collected in the steps described above, mass emissions are calculated using the equation presented in
table 4-1. 4.2.2 Blow-Through Method The sampling train for the blow-through method is presented in figure 4-2. The temperature and oxygen concentrations are measured inside the bag with a thermocouple (or thermometer) and an oxygen/combustible gas monitor. The carrier gas is metered into the bag through one or two tubes (two tubes provide for better mixing) at a steady rate throughout the sampling period. The flow rate of the carrier gas is monitored in a gas rotameter calibrated to the gas. Typical flow rates are approximately 60 /min or less. It is preferable to use an inert gas such as nitrogen for the blow-through method so as to minimize the risk of creating an explosive environment inside the bag. Also, the carrier gas should be free of any organic compounds and moisture. The pressure in the bag should never exceed 1 pound per square inch gauge (psig). The flow rate through the bag can be varied by adjusting the carrier gas regulator. As mentioned in section 4.2.1, a good flow rate to use is one in which a balance can be found between reaching equilibrium conditions and having a high enough

4-8TABLE 4-1. CALCULATION PROCEDURES FOR LEAK RATE WHEN USING THE VACUUM METHOD

Leak Rate = 9.63 x 10 -10 (Q)(MW)(GC)(P) ( ρ )(V L ) + (kg/hr) T + 273.15 16.67(t)

where:

9.63 x 10 -10 = A conversion factor using the gas constant:

°K × 10 6 × kg-mol × min
; × hour × mmHg

Q = Flow rate out of bag ( /min);

MW a = Molecular weight of organic compound(s) in the sample bag c or alternatively in the process stream contained within the equipment piece being bagged (kg/kg-mol);

GC b = Sample bag organic compound concentration (ppmv) minus background bag organic compound concentration c (ppmv);
P = Absolute pressure at the dry gas meter (mmHg);
T = Temperature at the dry gas meter (°C);

ρ = Density of organic liquid collected (g/m );

V L = Volume of liquid collected (m );
16.67 = A conversion factor to adjust term to units of kilograms per hour (g × hr)/(kg × min)
t = Time in which liquid is collected (min); and

a For mixtures calculate MW as:

n n

= ∑ MW i X i / ∑ X i i=1 i=1 where: MW i = Molecular weight of organic compound i;

X i = Mole fraction of organic compound i; and

n = Number of organic compounds in mixture. b For mixtures, the value of GC is the total concentration of all

the organic compounds in the mixture. c Collection of a background bag is optional. If a background bag

is not collected, assume the background concentration is zero.

4-9Carrier
Gas
Source Pressure Regulator

Dessicant

Activated
Charcoal Rotameter 1/4" Insulated
Teflon Tubing

Valve Stem

Tape or Adjustable Metal Band

Sample Port for Collecting Data on - Temperature - Hydrocarbon Concentration - Oxygen Concentration

Tape or Compressed Foil Foil or Mylar
Enclosure (if needed)

(if needed) R

R

4-10 Figure 4-2. Equipment Required for the Blow-Through Sampling Techniqueconcentration of organic compounds in the bag outlet to accurately measure the concentration in the laboratory. Adjustments to the flow rate may also help minimize liquid condensation in the bag. Any liquid that does accumulate in the bag should be collected using the approach described in section 4.2. The carrier gas flow rate should be set to a constant rate and kept at that rate long enough for the system to reach equilibrium. In addition to the carrier gas flow through the bag, some ambient air may enter the bag if it is not airtight. The oxygen measurements are used to determine the flow of ambient air through the bag. The oxygen measurements are also an indication of the quality of the bagging procedure (the lower the oxygen concentration the better). Once oxygen concentration falls below 5 percent, the portable monitoring instrument is used to check organic compound concentrations at several locations within the bag to ensure that the bag contents are at steady

state. Once the bag contents are at steady state, two gas samples are drawn out of the bag for laboratory analysis using a portable sampling pump. It may also be necessary to collect a background bag sample, particularly if the source had screened at zero and if there is still a detectable level of oxygen in the bag. However, collection of a background bag is optional. In summary, the blow-through method consists of the following steps, which assume nitrogen is used as the carrier

gas.

(1) Determine the composition of the material in the designated equipment component, and the operating conditions of the component.
(2) Screen the component using the portable monitoring instrument.
(3) Cut a bag that will easily fit over the equipment component.

4-11(4) Connect tubing from the nearest nitrogen source to a rotameter stand.
(5) Run tubing from the rotameter outlet to a "Y" that splits the nitrogen flow into two pieces of tubing and insert the tubes into openings located on either side of the bag.
(6) Turn on the nitrogen flow and regulate it at the rotameter to a constant rate and record the time.
(7) After the nitrogen is flowing, wrap aluminum foil around those parts of the component where air could enter the bag-enclosed volume.
(8) Use duct tape, wire, and/or rope to secure the bag to the component.
(9) Put a third hole in the bag roughly equidistant from the two carrier gas-fed holes.
(10) Measure the oxygen concentration in the bag by inserting the lead from an oxygen meter into the third hole. Adjust the bag (i.e., modify the seals at potential leak points) until the oxygen concentration is less than 5 percent.
(11) Measure the temperature in the bag.
(12) Check the organic compound concentration at several points in the bag with the portable monitoring instrument to ensure that carrier gas and VOC are well mixed throughout the bag.
(13) Collect samples in sample bags or canisters by drawing a sample out of the bag with a portable sampling pump.
(14) Collect a background bag (optional).
(15) Remove the bag and collect any liquid that accumulated in the bag in a sealed container. Note the time over which the liquid accumulated.

(16) Rescreen the source.
Table 4-2 gives equations used to calculate mass emission rates when using the blow-through method. An adjustment is provided for the leak rate equation in table 4-2 to account for the total flow through the bag. This adjustment is recommended and represents an improvement over previous versions

4-12TABLE 4-2. CALCULATION PROCEDURES FOR LEAK RATE WHEN USING THE BLOW-THROUGH METHOD

where:

Leak Rate (kg/hr)       1.219 x 10 5 (Q) (MW) (GC) T 273.15 ( ρ ) (V L ) 16.67 (t) x       10 6 ppmv 10 6 ppmv GC

1.219 x 10 -5 = A conversion factor taking into account the gas constant and assuming a pressure in the tent of 1 atmosphere:

o K × 10 6 × kg-mol ;
m 3

Q = flow rate out of tent (m 3 /hr);

= N 2 Flow Rate ( /min) [0.06 (m 3 /min)] × 1 - [Tent Oxygen Conc. (volume %)/21] ( /hr)

MW a = Molecular weight of organic compounds in the sample bag or alternatively in the process stream contained within the equipment piece being bagged (kg/kg-mol);

GC b = Sample bag organic compound concentration (ppmv), corrected for background bag organic compound concentration (ppmv); c
T = Temperature in tent ( o C);

ρ = Density of organic liquid collected (g/m );

V L = Volume of liquid collected (m );
16.67 = A conversion factor to adjust term to units of Kilograms per hour (g × hr)/(kg × min); and
t = Time in which liquid is collected (min).

a For mixtures calculate MW as:

n n

= ∑ MW i X i / ∑ X i i=1 i=1 where: MW i = Molecular weight of organic compound i;

4-13TABLE 4-2. CALCULATION PROCEDURES FOR LEAK RATE WHEN USING THE BLOW-THROUGH METHOD (Continued)

X i = Mole fraction of organic compound i; and

n = Number of organic compounds in mixture.

b For mixtures, the value of GC is the total concentration of all

the organic compounds in the mixture.

c Collection of a background bag is optional. If a background bag

is not collected, assume the background concentration is zero. To correct for background concentration, use the following equation:

where: GC (ppmv) SB TENT 21 x BG

SB = Sample bag concentration (ppmv); TENT = Tent oxygen concentration (volume %); and BG = Background bag concentration (ppmv)

4-14of this document for quantifying mass emissions from the blow through method.
4.3 SOURCE ENCLOSURE In this section, choosing a bagging material and the approach for bagging specific equipment types are discussed. An important criteria when choosing the bagging material is that it is impermeable to the specific compounds being emitted from the equipment piece. This criteria is also applicable for sample gas bags that are used to transport samples to the laboratory. A bag stability test over time similar to the Flexible Bag Procedure described in section 5.3.2 of the EPA method 18 is one way to check the suitability of a bagging material. 1 After a bag has been used, it must be purged. Bags containing residual organic compounds that cannot be purged should be discarded. Mylar®, Tedlar®, Teflon®, aluminum foil, or aluminized Mylar® are recommended potential bagging materials. The thickness of the bagging material can range from 1.5 to 15 millimeters (mm), depending on the bagging configuration needed for the type of equipment being bagged, and the bagging material. Bag construction for individual sources is discussed in sections 4.3.1 through 4.3.5. For convenience, Mylar® will be used as an example of bagging material in the following discussions.
4.3.1 Valves When a valve is bagged, only the leak points on the valve should be enclosed. Do not enclose surrounding flanges. The most important property of the valve that affects the type of enclosure selected for use is the metal skin temperature where the bag will be sealed. At skin temperatures of approximately
200 o C or less, the valve stem and/or stem support can be wrapped with 1.5- to 2.0-mm Mylar® and sealed with duct tape at each end and at the seam. The Mylar® bag must be constructed to enclose the valve stem seal and the packing gland seal. When skin temperatures are in excess of 200 o C, a different method of bagging the valve should be utilized. Metal bands, wires, or foil can be wrapped around all hot points that would be

4-15in contact with the Mylar® bag material. Seals are then made against the insulation using duct tape or adjustable metal bands of stainless steel. At extremely high temperatures, metal foil can be used as the bagging material and metal bands used to form seals. At points where the shape of the equipment prevent a satisfactory seal with metal bands, the foil can be crimped to
make a seal. 4.3.2 Pumps and Agitators As with valves, a property of concern when preparing to sample a pump or agitator is the metal skin temperature at areas or points that are in contact with the bag material. At skin temperatures below 200 o C, Mylar® plastic and duct tape are satisfactory materials for constructing a bag around a pump or agitator seal. If the temperature is too high or the potential points of contact are too numerous to insulate, an enclosure made of aluminum foil can be constructed. This enclosure is sealed around the pump and bearing housing using silicone fabric insulting tape, adjustable metal bands, or wire. The configuration of the bag will depend upon the type of pump. Most centrifugal pumps have a housing or support that connects the pump drive (or bearing housing) to the pump itself. The support normally encloses about one-half of the area between the pump and drive motor, leaving open areas on the sides. The pump can be bagged by cutting panels to fit these open areas. These panels can be made using thicker bagging material such as 14-mm Mylar®. In cases where supports are absent or quite narrow, a cylindrical enclosure around the seal can be made so that it extends from the pump housing to the motor or bearing support. As with the panels, this enclosure should be made with thicker bagging material to provide strength and rigidity. Reciprocating pumps can present a somewhat more difficult bagging problem. If supports are present, the same type of two-panel Mylar® bag can be constructed as that for centrifugal pumps. In many instances, however, sufficiently large supports are not provided, or the distance between pump and driver is relatively long. In these cases, a cylindrical enclosure as

4-16discussed above can be constructed. If it is impractical to extend the enclosure all the way from the pump seal to the pump driver, a seal can be made around the reciprocating shaft. This can usually be best completed by using heavy aluminum foil and crimping it to fit closely around the shaft. The foil is attached to the Mylar® plastic of the enclosure and sealed with the duct tape. In cases where liquid is leaking from a pump, the outlet from the bag to the sampling train should be placed at the top of the bag and as far away from spraying leaks as practical. A low point should be formed in the bag to collect the liquid so that the volume of the liquid can be measured and converted to a mass

rate. 4.3.3 Compressors In general, the same types of bags that are suitable for pumps can be directly applied to compressors. However, in some cases, compressor seals are enclosed and vented to the atmosphere at a high-point vent. If the seals are vented to a high-point vent, this vent line can be sampled. A Mylar® bag can be
constructed and sealed around the outlet of the vent and connected to the sampling train. If the high-point vents are inaccessible, the vent lines from the compressor seal enclosures can be disconnected at some convenient point between the compressor and the normal vent exit. Sampling is then conducted at this intermediate point. In other cases, enclosed compressor seals are vented by means of induced draft blowers or fans. In these cases, if the air flow rate is know or can be determined, the outlet from the blower/fan can be sampled to determine the emission rate.
4.3.4 Connectors In most cases, the physical configurations of connectors lend themselves well to the determination of leak rates. The same technique can be used for a connector whether it is a flanged or a threaded fitting. To bag a connector with a skin temperature below 200 o C, a narrow section of Mylar® film is constructed to span the distance between the two flange faces or

4-17the threaded fitting of the leaking source. The Mylar® is attached and sealed with duct tape. When testing connectors with skin temperatures above 200 o C, the outside perimeter of both sides of the connector are wrapped with heat-resistant insulating tape. Then, a narrow strip of aluminum foil can be used to span the distance between the connection. This narrow strip of foil can be sealed against the insulating tape using adjustable bands of stainless steel. 4.3.5 Relief Valves Relief devices in gas/vapor service generally relieve to the atmosphere through a large-diameter pipe that is normally located at a high point on the process unit that it serves. The "horns" can be easily bagged by placing a Mylar® plastic bag over the opening and sealing it to the horn with duct tape. Because may of these devices are above grade level, accessibility to the sampling train may be limited or prevented. It is sometimes possible to run a long piece of tubing from the outlet connection on the bag to the sampling train located at grade level or on a stable platform. As discussed previously in section 3.0, the purpose of pressure relief devices makes them inherently dangerous to sample, especially over a long period of time. If these equipment are to be sampled for mass emissions, special care and precautions should be taken to ensure the safety of the personnel conducting the field sampling. 4.4 ANALYTICAL TECHNIQUES The techniques used in the laboratory analysis of the bagged samples will depend on the type of processes sampled. The following sections describe the analytical instrumentation and calibration, and analytical techniques for condensate. These are guidelines and are not meant to be a detailed protocol for the laboratory personnel. Laboratory personnel should be well-versed in the analysis of organic compound mixtures and should design their specific analyses to the samples being examined. Also discussed is the calibration protocol for the portable monitoring instrument. When bagging data are collected, it is

4-18critical that the screening value associated with mass emission rates is accurate. For this reason, a more rigorous calibration of the portable monitoring instrument is required than if only screening data are being collected. 4.4.1 Analytical Instrumentation The use of analytical instrumentation in a laboratory is critical to accurately estimate mass emissions. The analytical instrument of choice depends on the type of sample being processed. Gas chromatographs (GC’s) equipped with a flame ionization detector or electron capture detector are commonly used to identify individual constituents of a sample. Other considerations besides instrument choice are the type of column used, and the need for temperature programming to separate individual constituents in the process stream with sufficient resolution. For some process streams, total hydrocarbon analyses may be satisfactory. 4.4.2 Calibration of Analytical Instruments Gas chromatographs should be calibrated with either gas standards generated from calibrated permeation tubes containing individual VOC components, or bottled standards of common gases. Standards must be in the range of the concentrations to be measured. If cylinder calibration gas mixtures are used, they must be analyzed and certified by the manufacturer to be within ± 2 percent accuracy, and a shelf life must be specified. Cylinder standards beyond the shelf life must either be reanalyzed or replaced. Field experience indicates that certified accuracies of ± 2 percent are difficult to obtain for very low-parts per million (ppm) calibration standards (< 10 ppm). Users of low-parts per million calibration standards should strive to obtain calibration standards that are as accurate as possible. The accuracy must be documented for each concentration standard. The results of all calibrations should be recorded on prepared data sheets. Table 4-3 provides an example of a data collection form for calibrating a GC. If other analytical instruments are used to detect the organic compounds from liquid

4-19TABLE 4-3. EXAMPLE GC CALIBRATION DATA SHEET

Plant ID Instrument ID Analyst Name

Date Time Certified Gas Conc. (ppmv) Instrument Reading

(ppmv) Comments

4-20samples, they should be calibrated according to standard calibration procedures for the instrument. 4.4.3 Analytical Techniques for Condensate Any condensate collected should be brought to the laboratory sealed in the cold trap flask. This material is transferred to a graduated cylinder to measure the volume collected. If there is enough volume to make it feasible, the organic layer should be separated from the aqueous layer (if present) and weighed to determine its density. If water-miscible organic compounds are present, both the aqueous and organic phases should be analyzed by GC to determine the total volume of organic material. 4.4.4. Calibration Procedures for the Portable Monitoring Instrument To generate precise screening values, a rigorous calibration of the portable monitoring instrument is necessary. Calibrations must be performed at the start and end of each working day, and the instrument reading must be within 10 percent of each of the calibration gas concentrations. A minimum of five calibration gas standards must be prepared including a zero gas standard, a standard approaching the maximum readout of the screening instrument, and three standards between these values. If the monitoring instrument range is from 0 to 10,000 ppmv, the following calibration gases are required: A zero gas (0-0.2 ppm) organic in air standard; A 9.0 ppm (8-10 ppm) organic in air standard; A 90 ppm (80-100 ppm) organic in air standard; A 900 ppm (800-1,000 ppm) organic in air standard; and A 9,000 ppm (8,000-10,000 ppm) organic in air standard. The same guidelines for the analysis and certification of the calibration gases as described for calibrating laboratory analytical instruments must be followed for calibrating the portable monitoring instrument. 4.5 QUALITY CONTROL AND QUALITY ASSURANCE GUIDELINES To ensure that the data collected during the bagging program is of the highest quality, the following QC/QA procedures must be followed. Quality control requirements include procedures to be

4-21followed when performing equipment leak mass emissions sampling. Quality assurance requirements include accuracy checks of the instrumentation used to perform mass emissions sampling. Each of these QC/QA requirements are discussed below. 4.5.1 Quality Control Procedures A standard data collection form must be prepared and used when collecting data in the field. Tables 4-4 and 4-5 are examples of data collection forms for the blow-through and vacuum methods of mass emissions sampling, respectively. In addition to completing the data collection forms, the following guidelines need to be adhered to when performing the bagging analysis:
Background levels near equipment that is selected for bagging must not exceed 10 ppmv, as measured with the portable monitoring device.
Screening values for equipment that is selected for bagging must be readable within the spanned range of the monitoring instruments. If a screening value exceeds the highest reading on the meter (i.e., "pegged reading"), a dilution probe should be used, or in the event that this is not possible, the reading should be identified as pegged.
Only one piece of equipment can be enclosed per bag; a separate bag must be constructed for each equipment component.
A separate sample bag must be used for each equipment component that is bagged. Alternatively, bags should be purged and checked for contamination prior to reuse.

A GC must be used to measure the concentrations from gas samples.
Gas chromatography analyses of bagged samples must follow the analytical procedures outlined in the EPA method 18.
To ensure adequate mixing within the bag when using the blow-through method, the dilution gas must be directed onto the equipment leak interface.
To ensure that steady-state conditions exist within the bag, wait at least five time constants (volume of bag dilution/gas flow rate) before withdrawing a sample for recording the analysis.

4-22TABLE 4-4. EXAMPLE DATA COLLECTION FORM FOR FUGITIVE EMISSIONS BAGGING TEST (BLOW-THROUGH METHOD)

Equipment Type Component ID Equipment Category Plant ID Line Size Date Stream Phase (G/V, LL, HL) Analysis Team Barometric Pressure Ambient Temperature Instrument ID Stream Temperature Stream Pressure Stream Composition (Wt %)
,

, ,

Time Bagging Test Measurement Data

Initial Screening (ppmv) Equipment Piece Bkgd. Background Bag Organic Compound Conc. (ppmv) a Dilution Gas Flow Rate ( /min) Sample Bag 1 Organic Compound Conc. (ppmv)
O 2 Concentration (volume %) Bag Temperature (°C)

Dilution Gas Flow Rate ( /min) Sample Bag 2 Organic Compound Conc. (ppmv)
O 2 Concentration (volume %) Bag Temperature (°C)

Condensate Accumulation: Starting Time Final Time Organic Condensate Collected (m ) Density of Organic Condensate (g/m )

Final Screening (ppmv) Equipment Piece Bkgd.

a Collection of a background bag is optional. However, it is

recommended in cases where the screening value is less than 10 ppmv and there is a detectable oxygen level in the bag.

4-23TABLE 4-5. EXAMPLE DATA COLLECTION FORM FOR FUGITIVE EMISSIONS BAGGING TEST (VACUUM METHOD)

Equipment Type Component ID Equipment Category Plant ID Line Size Date Stream Phase (G/V, LL, HL) Analysis Team Barometric Pressure Ambient Temperature Instrument ID Stream Temperature Stream Pressure Stream Composition (Wt %)
,

, ,

Time Bagging Test Measurement Data

Initial Screening (ppmv) Equipment Piece a Bkgd. Background Bag Organic Compound Conc. (ppmv) b Dry Gas Meter Reading ( /min) Sample Bag 1 Organic Compound Conc. (ppmv) Vacuum Check in Bag (Y/N) (Must be YES to collect sample.) Dry Gas Meter Temperature c (°C) Dry Gas Meter Pressure c (mmHg)

Dry Gas Meter Reading ( /min) Sample Bag 2 Organic Compound Conc. (ppmv) Vacuum Check in Bag (Y/N) (Must be YES to collect sample.) Dry Gas Meter Temperature c (°C) Dry Gas Meter Pressure c (mmHg)

Condensate Accumulation: Starting Time Final Time Organic Condensate Collected (m ) Density of Organic Condensate (g/m )

Final Screening (ppmv) Equip. Piece a Bkgd.

a The vacuum method is not recommended if the screening value is

approximately 10 ppmv or less. b Collection of a background bag is optional.

c Pressure and temperature are measured at the dry gas meter.

4-24The carrier gas used in the blow-through method of bagging should be analyzed by GC before it is used, and the concentration of organic compounds in the sample should be documented. For cylinder purge gases, one gas sample should be analyzed. For plant purge gas systems, gas samples should be analyzed with each bagged sample unless plant personnel can demonstrate that the plant gas remains stable enough over time to allow a one-time analysis.
The portable monitoring instrument calibration procedure described in section 4.4.4 should be performed at the beginning and end of each day.
4.5.2 Quality Assurance Procedures Accuracy checks on the laboratory instrumentation and portable monitoring device must be performed to ensure data quality. These checks include a leak rate check performed in the laboratory, blind standards to be analyzed by the laboratory instrumentation, and drift checks on the portable monitoring device.
4.5.2.1 Leak Rate Check A leak rate check is normally performed in the laboratory by sampling an artificially induced leak rate of a known gas. This can clarify the magnitude of any bias in the combination of sampling/test method, and defines the variance in emissions estimation due to the sampling. If the result is outside the 80 to 120 percent recovery range, the problem must be investigated and corrected before sampling continues. The problems and associated solutions should be noted in the test report. Leak rate checks should be performed at least two times per week during the program. The leak rate checks should be conducted at two concentrations: (1) within the range of 10 multiplied by the calculated lower limit of detection for the laboratory analytical instrument; and (2) within 20 percent of the maximum concentration that has been or is expected to be detected in the field during the bagging program. To perform a leak rate check, first induce a known flow rate with one of the known gas concentrations into a sampling bag.

4-25For example, this can be done using a gas permeation tube of a known organic compound constituent. Next, determine the concentration of the gas using a laboratory analytical instrument and compare the results to the known gas concentration. If the calculated leak rate is not within ± 20 percent of the induced leak rate, further analysis should be performed to determine the reason. Areas that can potentially induce accuracy problems include: Condensation, Pluggage, Seal of bag not tight (leakage), Adsorption onto bag, and Permeation of bag.
The results of all accuracy checks should be recorded on prepared
data sheets. 4.5.2.2 Blind Standards Preparation and Performance Blind standards are analyzed by the laboratory instrumentation to ensure that the instrument is properly calibrated. Blind standards must be prepared and submitted at least two times per week during the program. The blind standards are prepared by diluting or mixing known gas concentrations in a prescribed fashion so that the resulting concentrations are known. The analytical results should be within ± 25 percent of the blind standard gas concentration. If the results are not within 25 percent of the blind standard concentration, further analyses must be performed to determine the reason. Use of blind standards not only defines the analytical variance component and analytical accuracy, but it can serve to point out equipment malfunctions and/or operator error before questionable data are generated. 4.5.2.3 Drift Checks Drift checks need to be performed to ensure that the portable monitoring instrument remains calibrated. At a minimum, drift checks must be performed before and after a small group of components (i.e., two or three) are bagged. Preferably, drift

4-26checks should be performed on the screening instrument immediately before and after each component is bagged. These checks should be performed by analyzing one of the calibration gases used to calibrate the portable monitoring instrument. The choice of calibration gas concentration should reflect the anticipated screening value of the next component to be monitored. For example, if a component had previously screened at 1,000 ppmv and been identified for bagging, the calibration standard should be approximately 900 ppmv. Drift check data must be recorded on data sheets containing the information shown in the example in table 4-6. If the observed instrument reading is different from the certified value by greater than ± 20 percent, then a full multipoint calibration must be performed (see section 3.2.4.1). Also, all those components analyzed since the last drift check must be retested. Drift checks should also be performed if flameout of the portable monitoring instrument occurs. Using the lowest calibration gas standard (i.e., approximately 9 ppmv standard), determine the associated response on the portable monitoring instrument. If the response is not within ± 10 percent of the calibration gas concentration, a full multipoint calibration is required before testing resumes.

4-27TABLE 4-6. EXAMPLE DRIFT TEST REPORT FORM

Plant ID

Instrument ID
Analyst Name

Date Standard Gas Conc. (ppmv) Time Measured Conc. (ppmv) % Error a ID Number of Component Bagged Since Last Test

a % Error = Certified Conc. - Measured Conc. * 100 Certified Conc.

4-284.6 REFERENCES

1. Code of Federal Regulations, Title 40, Part 60, Appendix A. Reference Method 21, Determination of Volatile Organic Compound Leaks. Washington, DC. U.S. Government Printing Office. Revised June 22, 1990.

4-295.0 ESTIMATION OF CONTROL EFFICIENCIES FOR EQUIPMENT LEAK CONTROL TECHNIQUES

5.1 INTRODUCTION In this chapter, control techniques for reducing equipment leak emissions are described. There are two primary techniques for reducing equipment leak emissions: (1) modifying or replacing existing equipment, and (2) implementing a leak detection and repair (LDAR) program. Modifying or replacing existing equipment is referred to in this chapter as an "equipment modification." Examples of equipment modifications include installing a cap on an open-ended line, replacing an existing pump with a sealless type, and installing on a compressor a closed-vent system that collects potential leaks and routes them to a control device. In section 5.2, possible equipment modifications for each of the equipment types are briefly described. Also, the estimated control efficiency is presented for each equipment modification. An LDAR program is a structured program to detect and repair equipment that is identified as leaking. The focus of this chapter is LDAR programs for which a portable monitoring device is used to identify equipment leaks from individual pieces of equipment. In section 5.3, an approach is presented for estimating the control effectiveness of an LDAR program. 5.2 EQUIPMENT MODIFICATION CONTROL EFFICIENCY Controlling emissions by modifying existing equipment is achieved by either installing additional equipment that eliminates or reduces emissions, or replacing existing equipment with sealless types. Equipment modifications for each equipment type are described in the following sections. A separate section

5-1is included on closed-vent systems, which can be installed on more than one type of equipment. Equipment modifications that can be used for each equipment type are summarized in table 5-1. Table 5-1 also contains an approximate control efficiency for each modification. 5.2.1 Closed-Vent Systems A closed-vent system captures leaking vapors and routes them to a control device. The control efficiency of a closed-vent system depends on the percentage of leaking vapors that are routed to the control device and the efficiency of the control device. A closed-vent system can be installed on a single piece of equipment or on a group of equipment pieces. For use on single pieces of equipment, closed-vent systems are primarily applicable to equipment types with higher potential emission rates, such as pumps, compressors, and pressure relief devices. 5.2.2 Pumps Equipment modifications that are control options for pumps include routing leaking vapors to a closed-vent system (as discussed in section 5.2.1), installing a dual mechanical seal containing a barrier fluid, or replacing the existing pump with a sealless type. 5.2.2.1 Dual Mechanical Seals . A dual mechanical seal contains two seals between which a barrier fluid is circulated. Depending on the design of the dual mechanical seal, the barrier fluid can be maintained at a pressure that is higher than the pumped fluid or at a pressure that is lower than the pumped fluid. If the barrier fluid is maintained at a higher pressure than the pumped fluid, the pumped fluid will not leak to the atmosphere. The control efficiency of a dual mechanical seal with a barrier fluid at a higher pressure than the pumped fluid is essentially 100 percent, assuming both the inner and outer seal do not fail simultaneously. If the barrier fluid is maintained at a lower pressure than the pumped fluid, a leak in the inner seal would result in the pumped fluid entering the barrier fluid. To prevent emissions of the pumped fluid to the atmosphere, a barrier fluid reservoir

5-2TABLE 5-1. SUMMARY OF EQUIPMENT MODIFICATIONS

Equipment type Modification Approximate control efficiency (%)
Pumps Sealless design
Closed-vent system

Dual mechanical seal with barrier fluid maintained at a higher pressure than the pumped fluid 100 a

90 b

100

Compressors Closed-vent system

Dual mechanical seal with barrier fluid maintained at a higher pressure than the compressed gas 90 b

100

Pressure relief devices Closed-vent system
Rupture disk assembly c

100 Valves Sealless design 100 a Connectors Weld together 100 Open-ended lines Blind, cap, plug, or second valve 100

Sampling connections Closed-loop sampling 100

a Sealless equipment can be a large source of emissions in the

event of equipment failure.

b Actual efficiency of a closed-vent system depends on percentage

of vapors collected and efficiency of control device to which the vapors are routed.

c Control efficiency of closed vent-systems installed on a

pressure relief device may be lower than other closed-vent systems, because they must be designed to handle both potentially large and small volumes of vapor.

5-3system should be used. At the reservoir, the pumped fluid can vaporize (i.e., de-gas) and then be collected by a closed-vent system. The actual emissions reduction achievable through use of dual mechanical seals depends on the frequency of seal failure. Failure of both the inner and outer seals could result in relatively large releases of the process fluid. Pressure monitoring of the barrier fluid may be used to detect failure of the seals, allowing for a quick response to a failure. 5.2.2.2 Sealless Pumps . When operating properly, a sealless pump will not leak because the process fluid cannot escape to the atmosphere. Sealless pumps are used primarily in processes where the pumped fluid is hazardous, highly toxic, or very expensive, and where every effort must be made to prevent all possible leakage of the fluid. Under proper operating conditions, the control efficiency of sealless pumps is essentially 100 percent; however, if a catastrophic failure of a sealless pump occurs, there is a potential for a large quantity of emissions. 5.2.3 Compressors Emissions from compressors may be reduced by collecting and controlling the emissions from the seal or by improving seal performance. Shaft seals for compressors are of several different types--all of which restrict but do not eliminate leakage. In some cases, compressors can be equipped with ports in the seal area to evacuate collected gases using a closed-vent system. Additionally, for some compressor seal types, emissions can be controlled by using a barrier fluid in a similar manner as described for pumps. 5.2.4 Pressure Relief Valves Equipment leaks from pressure relief valves (PRV’s) occur as a result of improper reseating of the valve after a release, or if the process is operating too close to the set pressure of the PRV and the PRV does not maintain its seal. Emissions occurring from PRV’s as a result of an overpressure discharge are not considered to be equipment leak emissions. There are two primary

5-4alternatives for controlling equipment leaks from pressure relief devices: use of a rupture disk (RD) in conjunction with the PRV, or use of a closed-vent system. 5.2.4.1 Rupture Disk/Pressure Relief Valve Combination

. Although they are also pressure relief devices, RD’s can be installed upstream of a PRV to prevent fugitive emissions through the PRV seat. Rupture disk/pressure relief valve combinations require certain design constraints and criteria to avoid potential safety hazards, which are not covered in this document. If the RD fails, it must be replaced. The control efficiency of the RD/PRV combination is assumed to be 100 percent when operated and maintained properly. 5.2.4.2 Closed-Vent System . A closed-vent system can be used to transport equipment leaks from a pressure relief device to a control device such as a flare. The equipment leak control efficiency for a closed-vent system installed on a pressure relief device may not be as high as the control efficiency that can be achieved by installing a closed-vent system on other equipment types. This is because emissions from pressure relief devices can be either high flow emissions during an overpressure incident or low flow emissions associated with equipment leaks, and it may be difficult to design a control device to efficiently handle both high and low flow emissions.
5.2.5 Valves Emissions from process valves can be eliminated if the valve stem can be isolated from the process fluid. Two types of sealless valves are available: diaphragm valves and sealed bellows valves. The control efficiency of both diaphragm and sealed bellows valves is virtually 100 percent. However, a failure of these types of valves has the potential to cause temporary emissions much larger than those from other types of
valves.
5.2.6 Connectors In cases where connectors are not required for safety, maintenance, process modification, or periodic equipment removal, emissions can be eliminated by welding the connectors together.

5-55.2.7 Open-Ended Lines Emissions from open-ended lines can be controlled by properly installing a cap, plug, or second valve to the open end. If a second valve is installed, the upstream valve should always be closed first after use of the valves to prevent the trapping of fluids between the valves. The control efficiency of these measures is assumed to be essentially 100 percent. 5.2.8 Sampling Connections Emissions from sampling connections occur as a result of purging the sampling line to obtain a representative sample of the process fluid. Emissions from sampling connections can be reduced by using a closed-loop sampling system or by collecting the purged process fluid and transferring it to a control device or back to the process. The closed-loop sampling system is designed to return the purged fluid to the process at a point of lower pressure. A throttle valve or other device is used to induce the pressure drop across the sample loop. The efficiency of a closed-loop system is assumed to be 100 percent. Alternatively, in some cases, sampling connections can be designed to collect samples without purging the line. If such a sampling connection is installed and no emissions to the atmosphere occur when a sample is collected, then the control efficiency can be assumed to be 100 percent.
5.3 LEAK DETECTION AND REPAIR CONTROL EFFECTIVENESS An LDAR program is designed to identify pieces of equipment that are emitting sufficient amounts of material to warrant reduction of the emissions through repair. These programs are best applied to equipment types that can be repaired on-line, resulting in immediate emissions reduction, and/or to equipment types for which equipment modifications are not feasible. An LDAR program is best suited to valves and pumps, and can also be implemented for connectors. For other equipment types, an LDAR program is not as applicable. Compressors are repaired in a manner similar to pumps; however, because compressors ordinarily do not have a spare for bypass, a process unit shutdown may be required for

5-6repair. Open-ended lines are most easily controlled by equipment modifications. Emissions from sampling connections can only be reduced by changing the method of collecting the sample (since by definition equipment leak emissions are the material purged from the line), and cannot be reduced by an LDAR program. Safety considerations may preclude the use of an LDAR program on pressure relief valves. In this section, an approach is presented that can be used to estimate the control effectiveness of any given LDAR program for light liquid pumps, gas valves, light liquid valves, and connectors. The approach is based on the relationship between the percentage of equipment pieces that are leaking and the corresponding average leak rate for all of the equipment. In this approach, the three most important factors in determining the control effectiveness are: (1) how a "leak" is defined, (2) the initial leak frequency before the LDAR program is implemented, and (3) the final leak frequency after the LDAR program is implemented. The leak definition (or action level) is the screening value at which a "leak" is indicated if a piece of equipment screens equal to or greater than that value. The leak frequency is the fraction of equipment with screening values equal to or greater than the leak definition. Once these three factors are determined, a graph that plots leak frequency versus mass emission rate at several different leak definitions is used to predict emissions preceding and subsequent to implementing the LDAR program. In this way the emissions reduction (i.e., control effectiveness) associated with the LDAR program can be easily calculated. A general description of the approach is provided in the subsections below. This is followed by an example application of the approach. The approach has been applied to determine the control effectiveness at Synthetic Organic Chemical Manufacturing Industry (SOCMI) and refinery process units for the following LDAR programs: (1) monthly LDAR with a leak definition of 10,000 parts per million by volume (ppmv), (2) quarterly LDAR with a leak definition of 10,000 ppmv, and (3) LDAR equivalent to that

5-7specified in the proposed hazardous organic National Emission Standard for Hazardous Air Pollutants (NESHAP) equipment leaks negotiated regulation. 1 Tables 5-2 and 5-3 summarize the estimated control effectiveness for the three LDAR programs mentioned above at SOCMI process units and refineries, respectively. It should be noted that, to calculate the control effectiveness values presented in tables 5-2 and 5-3, assumptions were made that may not necessarily be applicable to specific process units. For example, the control effectiveness values in the tables are based on the assumption that the emission rate prior to implementing the LDAR program is the emission rate that would be predicted by the average emission factor. The best way to calculate the effectiveness of an LDAR program is by collecting and analyzing data at the specific process unit. 5.3.1 Approach for Estimating LDAR Control Effectiveness As previously stated, the key parameters for estimating the control effectiveness of an LDAR program are the leak definition, the initial leak frequency, and the final leak frequency. The leak definition is a given part of an LDAR program. It can either be defined by the process unit implementing the program or by an equipment standard to which the process unit must comply. After the leak definition is established, the control effectiveness of an LDAR program can be estimated based on the average leak rate before the LDAR program is implemented, and the average leak rate after the program is in place. Figures 5-1 through 5-4 are graphs presenting mass emission rate versus leak frequency for SOCMI-type process units at several leak definitions for gas valves, light liquid valves, light liquid pumps, and connectors, respectively. Figures 5-5 through 5-8 are graphs presenting mass emission rate versus leak frequency for refinery process units at several leak definitions for gas valves, light liquid valves, light liquid pumps, and connectors, respectively. Figures 5-9 through 5-15 are graphs presenting mass emission rate versus leak frequency for gas fittings, light liquid fittings, gas others, light liquid others, light liquid pumps, gas valves, and light liquid valves, for

5-8TABLE 5-2. CONTROL EFFECTIVENESS FOR AN LDAR PROGRAM AT A SOCMI PROCESS UNITEquipment type andserviceControl effectiveness (%)Monthly monitoring10,000 ppmv leakdefinitionQuarterly monitoring10,000 ppmv leakdefinitionHON reg negaValves - gas876792Valves - light liquid 84 61 88Pumps - light liquid 69 45 75Connectors - allbb93aControl effectiveness attributable to the requirements of the proposed hazardousorganic NESHAP equipment leak negotiated regulation are estimated based on equipmentspecific leak definitions and performance levels.bData are not available to estimate control effectiveness.

5-9TABLE 5-3. CONTROL EFFECTIVENESS FOR AN LDAR PROGRAM AT A REFINERY PROCESS UNITEquipment type andserviceControl effectiveness (%)Monthly monitoring10,000 ppmv leakdefinitionQuarterly monitoring10,000 ppmv leakdefinitionHON reg negaValves - gas887096Valves - light liquid 76 61 95Pumps - light liquid 68 45 88Connectors - allbb81aControl effectiveness attributable to the requirements of the proposed hazardousorganic NESHAP equipment leak negotiated regulation are estimated based on equipmentspecific leak definitions and performance levels.bData are not available to estimate control effectiveness.

5-10Figure 5-1. SOCMI Gas Valve Average Leak Rate Versus Fraction Leaking at Several Leak Definitions.

5-11Figure 5-2. SOCMI Light Liquid Valve Average Mass Emission Rate Versus Fraction Leaking at Several Leak Definitions

5-12Figure 5-3. SOCMI Light Liquid Pump Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-13Figure 5-4. SOCMI Connector Average Leak Rate Versus Fraction Leaking at Several Leak Definitions.

5-14Figure 5-5. Refinery Gas Valve Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-15Figure 5-6. Refinery Light Liquid Valve Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-16Figure 5-7. Refinery Light Liquid Pump Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-17Figure 5-8. Refinery Connector Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-18Figure 5-9. Marketing Terminal Gas Fittings Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-19Figure 5-10. Marketing Terminal Light Liquid Fittings Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-20Figure 5-11. Marketing Terminal Gas Others Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-21Figure 5-12. Marketing Terminal Light Liquid Others Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-22Figure 5-13. Marketing Terminal Light Liquid Pumps Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-23Figure 5-14. Marketing Terminal Gas Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-24Figure 5-15. Marketing Terminal Liquid Light Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-25marketing terminal process units. Figures 5-16 through 5-34 present mass emission rate as a function of leak frequency for connectors, flanges, open-ended lines, others, pumps, and valves at oil and gas production operations. Using these figures, for a given leak definition, the leak rate before and after the LDAR program is implemented, along with the corresponding control effectiveness, can be determined by plotting the initial and final leak frequency on these graphs. Tables 5-4, 5-5, 5-6, and 5-7 present equations for the lines in each of the SOCMI, refinery, marketing terminal, and oil and gas production operations, and graphs, respectively. Appendix G describes the approach that was used to develop the equations. Figure 5-35 provides guidance on how to determine the initial and final leak frequencies. This figure is a simplified graphical presentation on how the leak frequency will change after an LDAR program is implemented. When generating the figure, it was assumed that all equipment pieces are monitored at the same time. Each occurrence of equipment monitoring is referred to as a "monitoring cycle," and it is assumed that equal time periods lapse between monitoring cycles. From figure 5-35, it can be seen that there is an immediate reduction in leak frequency after the LDAR program is implemented, and then the leak frequency will oscillate over monitoring cycles. This oscillation occurs because between monitoring cycles a certain percentage of previously non-leaking equipment will begin to leak. There are four key points on the graph presented in figure 5-35. These key points are: Point X - initial leak frequency;
Point Y - leak frequency immediately after monitoring for and repairing leaking equipment (i.e., immediately after a monitoring cycle);
Point Z - leak frequency immediately preceding a monitoring cycle; and
Point F - average leak frequency between monitoring cycles (final leak frequency).

5-26Figure 5-16. Oil and Gas Production Gas Connectors Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-27Figure 5-17. Oil and Gas Production Light Oil Connectors Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-28Figure 5-18. Oil and Gas Production Water/Oil Connectors Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-29Figure 5-19. Oil and Gas Production Gas Flanges Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-30Figure 5-20. Oil and Gas Production Light Oil Flanges Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-31Figure 5-21. Oil and Gas Production Gas Open-Ended Lines Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-32Figure 5-22. Oil and Gas Production Heavy Oil Open-Ended Lines Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-33Figure 5-23. Oil and Gas Production Light Oil Open-Ended Lines Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-34Figure 5-24. Oil and Gas Production Water/Oil Open-Ended Lines Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-35Figure 5-25. Oil and Gas Production Gas Other Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-36Figure 5-26. Oil and Gas Production Heavy Oil Other Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-37Figure 5-27. Oil and Gas Production Light Oil Other Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-38Figure 5-28. Oil and Gas Production Water/Oil Other Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-39Figure 5-29. Oil and Gas Production Gas Pump Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-40Figure 5-30. Oil and Gas Production Light Oil Pumps Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-41Figure 5-31. Oil and Gas Production Gas Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-42Figure 5-32. Oil and Gas Production Heavy Oil Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-43Figure 5-33. Oil and Gas Production Light Oil Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-44Figure 5-34. Oil and Gas Production Water/Oil Valves Average Leak Rate Versus Fraction Leaking at Several Leak Definitions

5-45TABLE 5-4. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT SOCMI UNITSEquipment typeLeak definition(ppmv)EquationsaGas valve500ALR = (0.044× LKFRAC)+ 1.7E-051000ALR = (0.050 × LKFRAC) + 2.8E-052000ALR = (0.057 × LKFRAC) + 4.3E-055000ALR = (0.068 × LKFRAC) + 8.1E-0510000ALR = (0.078 × LKFRAC) + 1.3E-04Light liquid valve500ALR = (0.047 × LKFRAC) + 2.7E-051000 ALR = (0.053 × LKFRAC) + 3.9E-052000 ALR = (0.061 × LKFRAC) + 5.9E-055000 ALR = (0.077 × LKFRAC) + 1.1E-0410000 ALR = (0.089 × LKFRAC) + 1.7E-04Light liquid pump 500 ALR = (0.095 × LKFRAC) + 3.1E-041000ALR = (0.11 × LKFRAC) + 4.6E-042000ALR = (0.13 × LKFRAC) + 6.7E-045000ALR = (0.20 × LKFRAC) + 1.4E-0310000ALR = (0.24 × LKFRAC) + 1.9E-03Connector 500 ALR = (0.047 × LKFRAC) + 1.7E-051000 ALR = (0.060 × LKFRAC) + 2.5E-052000 ALR = (0.073 × LKFRAC) + 3.5E-055000 ALR = (0.092 × LKFRAC) + 5.4E-0510000ALR = (0.11× LKFRAC)+ 8.1E-05aALR = Average leak rate (kg/hr per source) and LKFRAC = leak fraction.

5-46TABLE 5-5. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT REFINERY UNITSEquipment typeLeak definition(ppmv)EquationaGas valve500ALR = (0.11 × LKFRAC) + 8.8E-051000ALR = (0.13 × LKFRAC) + 1.4E-0410000ALR = (0.26 × LKFRAC) + 6.0E-04Light liquid valve500ALR = (0.038 × LKFRAC) + 2.0E-041000ALR = (0.042 × LKFRAC) + 2.8E-0410000ALR = (0.084 × LKFRAC) + 1.7E-03Light liquid pump500ALR = (0.20 × LKFRAC) + 1.3E-031000ALR = (0.23 × LKFRAC) + 2.0E-0310000ALR = (0.43 × LKFRAC) + 1.2E-02Connector500ALR = (0.014 × LKFRAC) + 1.3E-051000ALR = (0.017 × LKFRAC) + 1.8E-0510000ALR = (0.037× LKFRAC)+ 6.0E-05aALR = Average leak rate (kg/hr per source) and LKFRAC = leak fraction.

5-47TABLE 5-6. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT MARKETING TERMINAL UNITS

Equipment Type Leak Definition (ppmv) Equation a

Gas Connector 500 ALR = (0.017 × LKFRAC) + 5.3E-06 1000 ALR = (0.017 × LKFRAC) + 5.3E-06 2000 ALR = (0.034 × LKFRAC) + 5.9E-06 5000 ALR = (0.034 × LKFRAC) + 5.9E-06 10000 ALR = (0.034 × LKFRAC) + 5.9E-06 Light Liquid Connector 500 ALR = (0.0021 × LKFRAC) + 7.0E-06
1000 ALR = (0.0028 × LKFRAC) + 7.1E-06
2000 ALR = (0.0042 × LKFRAC) + 7.1E-06 5000 ALR = (0.0058 × LKFRAC) + 7.2E-06 10000 ALR = (0.0065 × LKFRAC) + 7.2E-06 Gas Other 500 ALR = (0.0018 × LKFRAC) + 3.1E-05 1000 ALR = (0.0021 × LKFRAC) + 4.0E-05 2000 ALR = (0.0023 × LKFRAC) + 4.8E-05 5000 ALR = (0.0029 × LKFRAC) + 8.4E-05
10000 ALR = 1.2E-04 Light Liquid Other 500 ALR = (0.019 × LKFRAC) + 2.1E-05
1000 ALR = (0.022 × LKFRAC) + 2.2E-05
2000 ALR = (0.025 × LKFRAC) + 2.2E-05 5000 ALR = (0.034 × LKFRAC) + 2.4E-05 10000 ALR = (0.034 × LKFRAC) + 2.4E-05 Light Liquid Pump 500 ALR = (0.014 × LKFRAC) + 9.6E-05 1000 ALR = (0.018 × LKFRAC) + 1.2E-04 2000 ALR = (0.029 × LKFRAC) + 1.6E-04 5000 ALR = (0.051 × LKFRAC) + 2.1E-04
10000 ALR = (0.077 × LKFRAC) + 2.4E-04

5-48TABLE 5-6. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT MARKETING TERMINAL UNITS (CONTINUED)

Equipment Type Leak Definition (ppmv) Equation a
Gas Valve 500 ALR = (0.0012 × LKFRAC) + 8.9E-06 1000 ALR = (0.0017 × LKFRAC) + 9.2E-06 2000 ALR = (0.0017 × LKFRAC) + 9.2E-06 5000 ALR = (0.0017 × LKFRAC) + 9.2E-06
10000 ALR = 1.3E-05 Light Liquid Valve 500 ALR = (0.0045 × LKFRAC) + 9.5E-06
1000 ALR = (0.0052 × LKFRAC) + 9.8E-06
2000 ALR = (0.0077 × LKFRAC) + 1.1E-05 5000 ALR = (0.013 × LKFRAC) + 1.2E-05
10000 ALR = (0.023 × LKFRAC) + 1.5E-05

a ALR = Average leak rate (kg/hr per source)

LKFRAC = Leak fraction.

5-49TABLE 5-7. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT OIL AND GAS PRODUCTION OPERATION UNITS

Equipment Type Leak Definition (ppmv) Equation a

Gas Connector 500 ALR = (0.016 × LKFRAC) + 7.7E-06 1000 ALR = (0.018 × LKFRAC) + 8.0E-06 2000 ALR = (0.020 × LKFRAC) + 8.5E-06 5000 ALR = (0.023 × LKFRAC) + 9.4E-06 10000 ALR = (0.026 × LKFRAC) + 1.0E-05 Light Oil Connector 500 ALR = (0.016 × LKFRAC) + 7.7E-06 1000 ALR = (0.021 × LKFRAC) + 8.3E-06 2000 ALR = (0.022 × LKFRAC) + 8.6E-06 5000 ALR = (0.025 × LKFRAC) + 9.2E-06 10000 ALR = (0.026 × LKFRAC) + 9.7E-06 Water/Oil Connector 500 ALR = (0.013 × LKFRAC) + 7.8E-06 1000 ALR = (0.014 × LKFRAC) + 7.9E-06 2000 ALR = (0.016 × LKFRAC) + 8.3E-06 5000 ALR = (0.023 × LKFRAC) + 9.4E-06 10000 ALR = (0.028 × LKFRAC) + 1.0E-05 Gas Flange 500 ALR = (0.043 × LKFRAC) + 1.1E-06 1000 ALR = (0.051 × LKFRAC) + 1.8E-06 2000 ALR = (0.059 × LKFRAC) + 2.6E-06 5000 ALR = (0.075 × LKFRAC) + 4.7E-06 10000 ALR = (0.082 × LKFRAC) + 5.7E-06 Light Oil Flange 500 ALR = (0.037 × LKFRAC) + 9.4E-07 1000 ALR = (0.046 × LKFRAC) + 1.2E-06 2000 ALR = (0.055 × LKFRAC) + 1.6E-06 5000 ALR = (0.068 × LKFRAC) + 2.1E-06
10000 ALR = (0.073 × LKFRAC) + 2.4E-06

5-50TABLE 5-7. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT OIL AND GAS PRODUCTION OPERATION UNITS (CONTINUED)

Equipment Type Leak Definition (ppmv) Equation a

Gas Open-Ended Line 500 ALR = (0.037 × LKFRAC) + 4.1E-06
1000 ALR = (0.039 × LKFRAC) + 5.0E-06
2000 ALR = (0.045 × LKFRAC) + 7.5E-06 5000 ALR = (0.051 × LKFRAC) + 1.2E-05 10000 ALR = (0.055 × LKFRAC) + 1.5E-05 Heavy Oil Open-Ended Line 500 ALR = (0.012 × LKFRAC) + 4.3E-06
1000 ALR = (0.015 × LKFRAC) + 4.9E-06
2000 ALR = (0.020 × LKFRAC) + 6.0E-06 5000 ALR = (0.030 × LKFRAC) + 7.2E-06 10000 ALR = (0.030 × LKFRAC) + 7.2E-06 Light Oil Open-Ended Line 500 ALR = (0.030 × LKFRAC) + 3.8E-06
1000 ALR = (0.032 × LKFRAC) + 4.7E-06
2000 ALR = (0.036 × LKFRAC) + 6.7E-06 5000 ALR = (0.040 × LKFRAC) + 9.7E-06 10000 ALR = (0.044 × LKFRAC) + 1.4E-05 Water/Oil Open-Ended Line 500 ALR = (0.030 × LKFRAC) + 3.5E-06
1000 ALR = (0.030 × LKFRAC) + 3.5E-06
2000 ALR = (0.030 × LKFRAC) + 3.5E-06 5000 ALR = (0.030 × LKFRAC) + 3.5E-06 10000 ALR = (0.030 × LKFRAC) + 3.5E-06 Gas Other 500 ALR = (0.055 × LKFRAC) + 1.8E-05 1000 ALR = (0.061 × LKFRAC) + 3.1E-05 2000 ALR = (0.066 × LKFRAC) + 4.5E-05 5000 ALR = (0.078 × LKFRAC) + 8.2E-05
10000 ALR = (0.089 × LKFRAC) + 1.2E-04

5-51TABLE 5-7. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT OIL AND GAS PRODUCTION OPERATION UNITS (CONTINUED)

Equipment Type Leak Definition (ppmv) Equation a Heavy Oil Other 500 ALR = (0.0011 × LKFRAC) + 2.1E-05 1000 ALR = (0.0011 × LKFRAC) + 2.1E-05
2000 ALR = 3.2E-05
5000 ALR = 3.2E-05
10000 ALR = 3.2E-05 Light Oil Other 500 ALR = (0.053 × LKFRAC) + 3.4E-05 1000 ALR = (0.058 × LKFRAC) + 4.4E-05 2000 ALR = (0.067 × LKFRAC) + 6.4E-05 5000 ALR = (0.075 × LKFRAC) + 8.6E-05 10000 ALR = (0.083 × LKFRAC) + 1.4E-04 Water/Oil Other 500 ALR = (0.066 × LKFRAC) + 2.5E-05 1000 ALR = (0.066 × LKFRAC) + 2.5E-05 2000 ALR = (0.066 × LKFRAC) + 2.5E-05 5000 ALR = (0.066 × LKFRAC) + 2.5E-05 10000 ALR = (0.069 × LKFRAC) + 5.9E-05 Gas Pump 500 ALR = (0.027 × LKFRAC) + 1.1E-04 1000 ALR = (0.052 × LKFRAC) + 2.3E-04 2000 ALR = (0.052 × LKFRAC) + 2.3E-04 5000 ALR = (0.074 × LKFRAC) + 3.5E-04 10000 ALR = (0.074 × LKFRAC) + 3.5E-04 Light Oil Pump 500 ALR = (0.071 × LKFRAC) + 7.9E-05 1000 ALR = (0.079 × LKFRAC) + 1.5E-04 2000 ALR = (0.082 × LKFRAC) + 1.9E-04 5000 ALR = (0.10 × LKFRAC) + 5.1E-04
10000 ALR = (0.10 × LKFRAC) + 5.1E-04

5-52TABLE 5-7. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT OIL AND GAS PRODUCTION OPERATION UNITS (CONTINUED)

Equipment Type Leak Definition (ppmv) Equation a
Gas Valve 500 ALR = (0.070 × LKFRAC) + 9.1E-06 1000 ALR = (0.076 × LKFRAC) + 1.1E-05 2000 ALR = (0.083 × LKFRAC) + 1.4E-05 5000 ALR = (0.092 × LKFRAC) + 1.9E-05 10000 ALR = (0.098 × LKFRAC) + 2.5E-05 Heavy Oil Valve 500 ALR = (0.0013 × LKFRAC) + 7.8E-06 1000 ALR = (0.0013 × LKFRAC) + 7.8E-06 2000 ALR = (0.0013 × LKFRAC) + 7.8E-06
5000 ALR = 8.4E-06
10000 ALR = 8.4E-06 Light Oil Valve 500 ALR = (0.059 × LKFRAC) + 9.4E-06 1000 ALR = (0.069 × LKFRAC) + 1.2E-05 2000 ALR = (0.075 × LKFRAC) + 1.4E-05 5000 ALR = (0.083 × LKFRAC) + 1.7E-05 10000 ALR = (0.087 × LKFRAC) + 1.9E-05 Water/Light Oil Valve 500 ALR = (0.022 × LKFRAC) + 8.1E-06 1000 ALR = (0.022 × LKFRAC) + 8.1E-06 2000 ALR = (0.064 × LKFRAC) + 9.7E-06 5000 ALR = (0.064 × LKFRAC) + 9.7E-06
10000 ALR = (0.064 × LKFRAC) + 9.7E-06

a ALR = Average leak rate (kg/hr per source)

LKFRAC = Leak fraction.

5-53The initial leak frequency is the fraction of sources defined as leaking before the LDAR program is implemented. The initial leak frequency is point X on figure 5-35. The lower the leak definition, the higher the initial leak frequency. At a process unit, the initial leak frequency can be determined based on collected screening data. If no screening data are available, the initial leak frequency can be assumed to be equivalent to the leak frequency associated with the applicable average emission factor. However, if a process unit already has some type of LDAR program in place, the average emission factor may overestimate emissions. On figures 5-1 through 5-34, the average emission factor for each equipment type is plotted as a horizontal line. From this line, an initial leak frequency can be determined for any of the leak definitions. For example, on figure 5-1, which is for gas valves, the SOCMI average emission factor equals 0.00597 kilograms per hour (kg/hr). For a leak definition of 500 ppmv, this average emission factor corresponds to a fraction leaking of approximately 0.136. Similarly, for a leak definition of 10,000 ppmv, the average emission factor corresponds to a fraction leaking of 0.075. These points are determined by finding the intersection of the SOCMI average emission factor line and the applicable leak definition line and reading off the corresponding fraction leaking. Alternatively the fraction leaking associated with the average factor can be calculated using the equations in tables 5-4, 5-5, 5-6, and 5-7. The leak frequency immediately after a monitoring cycle is Point Y on figure 5-35. After an LDAR program is implemented for a given time period, point Y will reach a "steady-state" value. As presented in figure 5-35, point Y depends on two key factors: (1) the percentage of equipment successfully repaired after being identified as leaking, and (2) the percentage of equipment that was repaired for which leaks recurred. Two simplifying assumptions when calculating point Y are: (1) that leaking equipment is instantaneously repaired, and (2) that the recurring leaks will occur instantaneously after the equipment is repaired.

5-545-55 Figure 5-35. Simplified Graphical Presentation of Changes in Leak Frequency After Implementation of an LDAR ProgramBased on these assumptions the value for point Y is calculated using the following equation:

Y i = Z i - (FR × Z i ) + (FR × Z i × R)

where:

Y i = Leak fraction immediately after monitoring cycle i;

Z i = Leak fraction immediately preceding monitoring cycle i (note that Z 1 equals point X.);
R = Fraction of repaired sources for which a leak immediately recurs; and
FR = Fraction of leaking sources successfully repaired.
Point Z on figure 5-35 is the leak frequency immediately preceding equipment monitoring. After an LDAR program is implemented for a given time period, point Z will reach a "steady-state" value. To go from point Y to point Z on figure 5-35, the occurrence rate is added to point Y. The occurrence rate equals the percentage of initially nonleaking equipment that starts to leak between monitoring cycles. Use the following equation to go from point Y to point Z:

Z i+1 = Oc × (1 - Y i )+Y i

where:

Z i+1 = Leak fraction immediately preceding monitoring cycl e i + 1; Oc = Fraction of nonleaking sources which will leak in the time period between monitoring cycles (i.e, occurrence rate); and

Y i = Leak fraction immediately after monitoring cycle i.
After several monitoring cycles, the leak frequency will be found to approximately oscillate between points Y and Z. The average value of these two "steady-state" values is the final leak frequency. This is point F on figure 5-35. The final leak frequency is the average percent of sources that are still leaking after an LDAR program has been implemented. Once the initial and final leak frequencies are determined, they can be entered into the applicable equation from table 5-4

5-56or table 5-5 to calculate the associated average leak rates at these leak frequencies. Based on the initial leak rate and the final leak rate, the control effectiveness for an LDAR program can be calculated. The control effectiveness is calculated as:

Eff = (ILR-FLR)/ILR × 100

where:
Eff = Control effectiveness (percent);
ILR = Initial leak rate (kg/hr/source); and
FLR = Final leak rate (kg/hr/source).
5.3.2 Example Application of Approach As previously mentioned, the approach described in section 5.3.1 was applied to estimate the control effectiveness for three types of LDAR programs: (1) monthly inspection with a leak definition of 10,000 ppmv, (2) quarterly inspection with a leak definition of 10,000 ppmv, and (3) a program complying with the requirements specified in the proposed hazardous organic NESHAP equipment leaks negotiated regulation. 1 Details of these calculations are presented in appendix G. As an example of applying the approach, the control effectiveness for gas valves at a SOCMI process unit implementing a monthly LDAR program with a leak definition of 10,000 ppmv is presented in the following paragraphs. Table 5-8 presents the SOCMI gas valve occurrence rate, recurrence rate, unsuccessful repair rate, and initial leak frequency. (See appendix G for details on how each of these parameters were determined.) Using the values presented in table 5-6 and the approach presented in section 5.3.1, the LDAR control effectiveness can be calculated. Note that figure 5-9 is also based on monthly monitoring of gas valves in a SOCMI process unit with a leak definition of 10,000 ppmv, and it is referred to in this example demonstration. For gas valves with a leak definition of 10,000 ppmv, the initial leak frequency is 7.5 percent. This initial leak frequency value is taken from figure 5-1, by finding the value of

5-57TABLE 5-8. VALUES USED IN EXAMPLE CALCULATION a

Source Category: SOCMI Equipment Type: Gas Valves LDAR Program: Monthly Monitoring with a Leak Definition of 10,000 ppmv
Occurrence Rate: 1.00%
Recurrence Rate: 14% Unsuccessful Repair Rate: 10% Initial Leak Frequency: b 7.5%

a See appendix F for information on how the occurrence rate, recurrence rate, and unsuccessful repair rate were determined.

b Based on the SOCMI average emission factor for gas valves.

5-58the fraction leaking at the intersection of the SOCMI average factor line and the 10,000-ppmv leak definition line. The initial leak rate for this leak frequency is the SOCMI gas valve average emission factor, which equals 0.00597. After the LDAR program is implemented and monitoring occurs on a monthly basis, the steady-state leak frequency immediately after monitoring (see point Y 6 on figure 5-35) equals 0.29 percent. The steady-state leak frequency prior to monitoring (see point Z 6 on figure 5-35) equals 1.29 percent. This gives an average of 0.79 percent as the final leak frequency (see point F on figure 5-35). The calculations performed to determine the final leak frequency are shown in table 5-9. Once the estimated gas valve final leak frequency is determined, the associated leak rate can be found using figure 5-1 or the gas valve equation for a leak definition of 10,000 ppmv listed on table 5-4. The corresponding leak rate associated with the final leak frequency of 0.79 percent at a leak definition of 10,000 ppmv is 0.00075 kg/hr. Thus, the control effectiveness of a monthly LDAR program with a leak definition of 10,000 ppmv for gas valves is:

= (0.00597-0.00075)/0.00597 × 100
= 87 percent.

5-59TABLE 5-9. EXAMPLE CALCULATION TO DETERMINE THE FINAL LEAK FREQUENCY OF SOCMI GAS VALVESIN A MONTHLY MONITORING LDAR PROGRAM WITH A LEAK DEFINITION OF 10,000 PPMVaStarting parametersResulting parameters1. Leak definition:= 10,000 ppmv2. Leak occurrence (Oc):= 1.00 percent3. Leak recurrence (R):= 14 percent4. Successful repair rate (FR):= 90 percent5. Initial leak frequency (Point X):= 7.5 percent1. Steady-state leak frequency aftermonitoring (Point Y6):= 0.29 percent2. Steady-state leak frequency immediatelyprior to monitoring (Point Z6):= 1.29 percent3. Final leak frequency (Point F)b:= 0.79 percentCalculationsMonitoring cycleLeak frequency aftermonitoring: Point Yi(percent)cLeak frequency prior tomonitoring: Point Zi(percent)d123456e1.700.610.360.310.290.297.502.671.601.361.301.29aRefer to Figure 5-4 for graphical presentation of all points identified in this table.bFinal Leak Frequency equals the average of the prior to monitoring and after monitoringsteady-state leak frequencies.cYi= Zi- (FR * Zi) + (FR * Zi* R)dZi+ 1 = Oc * (1 - Yi)+YieAfter the sixth monitoring cycle, the values for Yiand Zireach steady-state.

5-605.4 REFERENCES

1. National Emission Standards for Hazardous Air Pollutants for Source Categories; Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry and Seven Other Processes. Subpart H--Equipment Leaks. Federal Register. Vol. 57, No. 252, pp 62765-62785. Washington, DC. Office of the Federal Register. December 31, 1992.

5-61APPENDIX A: EXAMPLE CALCULATIONSA-1. INTRODUCTION This appendix provides example calculations demonstrating the approaches described in chapter 2.0. A simple dataset from a hypothetical process unit is expanded as needed to illustrate how the data are is used in each approach. Table A-1 summarizes information used in the example calculations. This information includes the equipment count, hours of operation, and composition for each stream. The stream compositions presented in table A-1 are completely hypothetical and were chosen for the sole purpose of demonstrating the various approaches. Three streams are presented in table A-1. Note that the hours of operation are based on the time in which the equipment contains material. (Even if a process unit is shutdown, if the equipment contains material, then the shutdown time must still be included in the hours of operation.) Two SOCMI equipment type/service categories are used in the example calculations: pumps/light liquid and valves/gas. The same technique used for these equipment type/service categories can be followed for any equipment type/service. In each of the calculations, emissions are estimated on an annual basis. The following sections present the example calculations. In section A-2, the Average Emission Factor Approach is presented. Section A-3 presents the Screening Ranges Approach. In section A-4, the EPA Correlation Equation Approach is presented, and in section A-5, the use of the Unit-Specific Correlation is discussed. Section A-6 explains how to speciate emissions. Section A-7 demonstrates three approaches for applying response factors (RF’s). Section A-8 demonstrates how to annualize emissions when more than one screening value is collected from individual equipment pieces over an annual time period. Section A-9 shows how to estimate VOC emissions when screening data are collected from equipment containing organic compounds not classified as VOC’s. Finally, section A-10 addresses estimating emissions from equipment containing inorganic compounds.

A-1TABLE A-1. DATA FOR EXAMPLE CALCULATIONSStream IDEquipmenttype/serviceEquipment countHours ofoperationa(hr/yr)Stream compositionConstituentwt. fractionA Pumps/lightliquid15 8,760 ethyl acrylatewater0.800.20B Pumps/lightliquid12 4,380 ethyl acrylatestyrene0.100.90CValves/gas408,760ethyl acrylateethanewater vapor0.650.250.10aHours or operation include all time in which material is contained in the equipment.

A-2A-2. AVERAGE EMISSION FACTOR APPROACH The Average Emission Factor Approach is demonstrated for Streams A and B, which contain light liquid pumps. The SOCMI average TOC emission factor for light liquid pumps is 0.0199 kg/hr. Based on this emission factor and data contained in table A-1, total VOC emissions can be calculated. Note that the TOC’s in Stream A are also VOC’s and that stream A contains water, which is not a VOC. This is accounted for when total VOC emissions are estimated from Stream A. Table A-2 summarizes the Average Emission Factor Approach calculations.
A-3. SCREENING RANGES APPROACH The Screening Ranges Approach is demonstrated for Streams A and B. The calculations for the Screening Ranges Approach are similar to those used for the Average Emission Factor Approach, except that an emission factor for each screening value range is used. In this example, the component screening values are designated as either less than 10,000 ppmv or equal to or greater than 10,000 ppmv. It is assumed that none of the light liquid pumps in Stream A have a screening value greater than or equal to 10,000 ppmv, and one of the light liquid pumps in Stream B screens greater than 10,000 ppmv. It is also assumed that one of the pumps in Stream B could not be screened. Emissions from this pump are calculated using the average emission factor. Table A-3 summarizes the calculations used in the Screening Ranges Approach. A-4. EPA CORRELATION EQUATION APPROACH The EPA Correlation Equation Approach is demonstrated for Streams A and B. The EPA Correlation Equation Approach involves entering screening values into a correlation equation to generate an emission rate for each equipment piece. In table A-4, assumed screening values and the resulting emissions for each individual equipment piece are presented. Emissions from the pump that was not screened are estimated using the average emission factor.

A-3TABLE A-2. AVERAGE EMISSION FACTOR METHODStream IDEquipmentcountTOC Emissionfactor(kg/hr/source)Weight Fractionof TOCHours of operation(hr/yr)VOC emissionsa(kg/yr)A 15 0.0199 0.80 8,760 2,090B120.01991.004,3801,050Total Emissions3,140aVOC Emissions = (no. of components) × (emission factor) × (wt. fraction TOC) × (WPVOC/WPTOC) × (hours ofoperation).

A-4TABLE A-3. SCREENING VALUE RANGES METHODStream IDEquipmentcountTOC Emissionfactor(kg/hr/source)Hours ofoperation(hr/yr)VOC emissions(kg/yr)Components screening >10,000 ppmvaB 1 0.243 4,380 1,060Components screening < 10,000 ppmvaA150.001878,760246B100.001874,38082Components not screenedbB (TOC wt. fraction equal to 1.0) 10.01994,38087Total emissions1,480aVOC emissions = (no. of components) × (TOC emission factor) × (WPVOC/WPTOC) × (hours of operation).bVOC emissions = (no. of components) × (average TOC emission factor) × (wt. fraction of TOC) ×(WPVOC/WPTOC) × (hours of operation).

A-5TABLE A-4. EPA CORRELATION EQUATION METHOD a

Equipment ID Screening value (ppmv) TOC mass emissions b (kg/yr)

A-1 A-2 A-3 A-4 A-5 A-6 A-7 A-8 A-9 A-10 A-11 A-12 A-13 A-14 A-15 0 0 0 0 0 20 50 50 100 100 200 400 1,000 2,000 5,000 0.066 0.066 0.066 0.066 0.066 2.0 4.2 4.2 7.4 7.4 13 23 49 87 190
Total Stream A Emissions: 390

B-1 B-2 B-3 B-4 B-5 B-6 B-7 B-8 B-9 B-10 B-11 B-12 (100% TOC) 0 0 0 10 30 250 500 2,000 5,000 8,000 25,000 Not screened 0.033 0.033 0.033 0.55 1.4 7.9 14 44 93 140 350

87
Total Stream B Emissions: 740
Total Emissions 1,130

a Equipment type: Light liquid pumps.

Correlation equation: Leak rate (kg/hr) = 1.90×10 -5 × (SV) 0.824 Default-zero mass emission rate: 7.49 × 10 -6 kg/hr Hours of operation: Stream A = 8,760; Stream B = 4,380.

b VOC Emissions = (correlation equation or default-zero emission

rate) × (WP VOC /WP TOC ) × (hours of operation)

c VOC Emissions = (average emission factor) × (wt. fraction

of TOC) × (WP VOC/WP TOC ) × (hours of operation)

A-6A-5. UNIT-SPECIFIC CORRELATION APPROACH Correlation equations may be developed for specific units rather than using the more general EPA Correlation Equations. Appendix B presents details on developing unit-specific correlations. Once correlations are developed using the approach outlined in appendix B, they are applied in the same manner as described for the EPA correlations.
A-6. SPECIATING EMISSIONS The emission rate of specific compounds in a mixture can be calculated if the concentration of the compound in the stream is known. The equation for speciating emissions is

E x = E TOC × (WP x /WP TOC ) where:

E x = The mass emissions of organic chemical "x" from the equipment piece (mass/time);

E TOC = The TOC mass emissions from the individual equipment piece (mass/time) calculated from either the Average Emission Factor, Screening Ranges, Correlation, or Unit-Specific Correlation approaches;

WP x = The concentration of organic chemical "x" in the equipment piece (weight percent);

WP TOC = The total TOC concentration in the equipment piece (weight percent).
See table A-5 for a demonstration of speciating emissions of Stream B. Because all of the equipment in Stream B contains the same composition, the emissions can be speciated on a stream-wide basis.
A-7. RESPONSE FACTORS Response factors are used to correct screening values to compensate for variations in a monitor’s response to different compounds. Determination of whether an adjustment to the screening value will provide more valid emission estimates can be made by reviewing RF’s at actual concentrations of 500 ppmv and 10,000 ppmv for the material in the equipment being screened.

A-7TABLE A-5. SPECIATING EMISSIONS OF STREAM BaMethod of calculationTotal TOC emission(kg/yr)Ethyl acrylate emissionsb(kg/yr)Styrene emissionsb(kg/yr)Avg. emission factor 1,050c105 945Screening ranges 1,230d123 1,110Correlation equation740e74666aEquipment type: Light liquid pumpsTotal TOC wt. fraction 1.0Ethyl acrylate wt. fraction 0.1Styrene wt. fraction 0.9bEmissions for species = (total TOC emissions) × (wt. fraction of individual chemical)/(total TOC wt.fraction).cFrom Table A-2.dFrom Table A-3.eFrom Table A-4.

A-8The RF’s can be taken from table D-1 in appendix D, or may be calculated based on analytical measurement performed in a laboratory. For materials with RF’s below three at both actual concentrations, the screening value does not need to be corrected. If the RF at either concentration is above three, the screening value obtained from the monitoring device should be adjusted. If it is necessary to adjust the screening value, one of two approaches can be applied: (1) Use the higher of either the 500 ppmv or 10,000 ppmv RF to adjust all screening values, or
(2) Plot the RF versus screening value and determine the applicable RF for each screening value. Table D-1 in appendix D presents the RF’s for chemical compounds at actual concentrations of 500 ppmv and 10,000 ppmv for several different monitoring devices. For the example calculations presented here, data for the Foxboro OVA-108 is utilized. Table A-6 presents the RF’s for ethyl acrylate and styrene. From table A-6, it can be seen that at both concentrations, the RF for ethyl acrylate is below three. Therefore, it is not necessary to adjust any of the screening values taken from the equipment in Stream A. (The only TOC constituent in Stream A is ethyl acrylate.) Stream B contains 10 percent ethyl acrylate and 90 percent styrene. The RF’s at both concentration values for Stream B are calculated using the following equation:

RF m = 1

n

i 1 (X i /RF i )

where:

RF m = Response factor of the mixture; n = Number of constituents in the mixture;

X i = Mole fraction of constituent i in the mixture; and

A-9TABLE A-6. APPLICATION OF RESPONSE FACTORSaChemicalMolecularweightMole fractionfor stream BbResponse factorat actual conc.of 500 ppmvResponse factorat actual conc.of 10,000 ppmvEthyl Acrylate(0.10 wt. frac.)100.10.10362.490.72Styrene(0.90 wt. frac.)104.20.89641.106.06aResponse factors are taken from Table D-1 in Appendix D and are based on a FoxboroOVA-108 calibrated with methane.bMole fraction calculated as:Weight fraction compound i=MW of compound in∑Weight fraction compound ii=1MW of compound i

A-10RF i = Response factor of constituent i in the mixture;

The derivation of the above equation is presented in table A-7. Using the RF’s and mole fraction information from table A-6, the RF for the mixture in Stream B is calculated as
follows:

RF m (@ 500 ppmv) = (0.1036/2.49 + 0.8963/1.10) -1 = 1.17

and

RF m (@ 10,000 ppmv) = (0.1036/0.72 + 0.8964/6.06) -1 = 3.43

From the above calculations, it can be seen that at an actual concentration of 10,000 ppmv the RF is above three, which means the screening values need to be adjusted. Table A-8 demonstrates the simplest approach for adjusting the screening values. This approach involves multiplying all of the screening values by whichever RF is higher. Correcting the screening values by the approach described above may be inaccurate in some cases. For example, if all or most of the equipment have low screening values, using the RF based on an actual concentration of 10,000 ppmv may cause an over estimate in the calculated emission rate. A more precise application of RF’s is to plot the RF versus the screening value. This can be done by fitting a straight line between the RF and the corresponding screening values associated with the 500 and 10,000 ppmv actual concentrations. For the example case, this is
done as follows.

Screening value associated with actual concentration of 500 ppmv:
= (500 ppmv)/(RF at actual concentration of 500 ppmv)
= 500 ppmv/1.17
= 427 ppmv

A-11Screening value associated with actual concentration of 10,000 ppmv:
= (10,000 ppmv)/(RF at actual concentration of 10,000 ppmv)

A-12TABLE A-8. APPLYING RESPONSE FACTORS FROM TABLE C-1aEquipment IDUnadjustedscreening value(ppmv)Response factorof mixtureAdjustedscreening valueb(ppmv)VOCEmission ratec(kg/yr)B-1 0 -- Default zero 0.033B-20--Default zero0.033B-30--Default zero0.033B-4103.43341.5B-5303.431033.8B-62503.4385822B-75003.431,71539B-82,0003.436,860120B-95,0003.4317,150260B-108,0003.4327,440380B-1125,0003.4385,750970B-12Not Screened----87dTotal Emissions of Stream B1,880aEquipment type: Light liquid pumpsCorrelation equation: Leak rate (kg/hr) = 1.90 × 10-5(SV)0.824Default-zero mass emission rate: 7.49 × 10-6kg/hrHours of operation: Stream B = 4,380bAdjusted SV = (unadjusted SV) × (RF of mixture)cVOC Emission = (correlation equation or default-zero emission rate) × (WPVOC/WPTOC) ×(hours of operation)dVOC Emission = (average emission factor) × (wt. fraction of VOC) × (WPVOC/WPTOC) × (hours of operation)

A-13TABLE A-7. DERIVATION OF EQUATION USED TO ESTIMATE RESPONSE FACTOR FOR A MIXTURE

(1) Response Factor (RF) Equation:

(2) For a mixture, each compound will contribute to the actual concentration RF Actual Concentration (ppmv) Screening Value (ppmv) = A SV

and to the screening value, thus:

A=A 1 + A 2 + A 3 ...=A TOT SV = SV 1 + SV 2 + SV 3 ... Thus, the above equation converts to:

(3) The value for the screening value of each individual compound (SV i ) is RF = A TOT SV 1 SV 2 SV 3 ...

calculated as:

(4) The mole fraction of each individual compound (X i ) is calculated as: SV i = A i RF i ; substituting gives:

RF = A TOT A 1 RF 1 A 2 RF 2 A 3 RF 3 ...

Thus, the actual concentration of compound i is calculated as: X i = A i A TOT ;

(5) Thus, the response factor of a mixture is calculated as: A i = X i A TOT ; substituting gives:

RF = A TOT X 1 A TOT RF 1 X 2 A TOT RF 2 X 3 A TOT RF 3 ... = 1 X 1 RF 1 X 2 RF 2 X 3 RF 3 ...

RF = 1

n

i=1 X i /RF i

A-14= 10,000/3.43
= 2,915 ppmv

Figure A-1 plots this screening value/RF relationship. Table A-9 uses this plot to calculate emissions. Note that in table A-9, all of the screening values are adjusted. An alternative would be to adjust only those screening values having an associated RF greater than three. Note that for all screening values less than 427 ppmv, the RF calculated at 427 ppmv is applied, and, similarly, for all screening values above 2,915 ppmv, the RF at 2,915 ppmv is applied. An alternative to using the RF’s in appendix D is to use the analytical technique described in chapter 3.0 to determine RF’s at several different actual concentrations. These RF’s are then related to the screening value. Once the RF’s and associated screening values are determined, a first-order or second-order (if the relationship appears nonlinear) equation can be fitted to
the RF data. Table A-10 demonstrates how the collected data of RF’s at actual concentrations is converted to RF’s for the associated screening values. A hypothetical plot of the RF/screening value relationship is shown in figure A-2. Table A-11 demonstrates how emissions can then be calculated by applying the plot. Note that the line is not extrapolated beyond the highest screening value for which data were obtained.
A-8. ANNUALIZING EMISSIONS If more than one screening value is obtained from an equipment piece, all of the screening values can be used to estimate emissions, as long as the elapsed time between each screening value obtained is known. This is demonstrated for pump A-15 in Stream A. Table A-12 shows how emissions are calculated for each period between the collection of screening values. Notice that each screening value is used to estimate emissions since the last screening value was obtained.

A-15Figure A-1. Response Factor Curve Generated From Response Factor Data in Table C-1

A-16TABLE A-9. ESTIMATING EMISSIONS USING RESPONSE FACTORS GENERATED FROM FIGURE A-1aEquipment IDUnadjustedscreening value(ppmv)Response factor ofmixtureAdjusted screeningvalueb(ppmv)VOC Emission ratec(kg/yr)B-1 0 -- Default zero 0.033B-20--Default zero0.033B-30--Default zero0.033B-4101.17120.63B-5301.17351.6B-62501.172939.0B-75001.2462017B-820002.625,24097B-950003.4317,150260B-1080003.4327,440380B-11250003.4385,750970B-12Not screened----87dTotal Emissions of Stream B1,820aEquipment type: Light liquid pumpsCorrelation equation: Leak rate (kg/hr) = 1.90 × 10-5(SV)0.824Default-zero mass emission rate: 7.49 × 10-6kg/hrHours of operation: Stream B = 4,380bAdjusted SV = (unadjusted SV) × (RF of mixture taken from Figure A-1)cVOC Emission = (correlation equation or default-zero emission rate) × (WPVOC/WPTOC) × (hours of operation)dVOC Emission = (no. of components) × (average emission factor) × (wt. fraction of VOC) × (WPVOC/WPTOC) ×(hours of operation)

A-17TABLE A-10. GENERATION OF HYPOTHETICAL RESPONSE FACTOR DATA FOR STREAM B a

Actual standard gas concentration (ppmv) Sample number Measured screening value (ppmv) Response factor
500 500 500 1 2 3 375 390 390 Avg = 385 1.33 1.28 1.28 Avg = 1.30
2,000 2,000 2,000 1 2 3 1,219 1,205 1,258 Avg = 1,227 1.64 1.66 1.59 Avg = 1.63
5,000 5,000 5,000 1 2 3 1,865 1,930 1,872 Avg = 1,889 2.68 2.59 2.67 Avg = 2.65
10,000 10,000 10,000 1 2 3 2,976 3,040 2,994 Avg = 3,003 3.36 3.29 3.34 Avg = 3.33
25,000 25,000 25,000 1 2 3 6,361 6,394 6,476 Avg = 6,410 3.93 3.91 3.86 Avg = 3.90

a This table is a demonstration of how analytical determination

of response factors can be used to generate a response factor/screening value relationship.

A-18Figure A-2. Response Factor Curve Generated by Analytical Determination of Response Factors

A-19TABLE A-11. RESPONSE FACTORS GENERATED FROM FIGURE A-2aEquipment IDUnadjustedscreening value(ppmv)Response factorof mixtureAdjusted screeningvalueb(ppmv)VOCEmission ratec(kg/yr)B-1 0 -- Default zero 0.033B-20--Default zero0.033B-30--Default zero0.033B-4101.46150.76B-5301.47441.9B-62501.5639011B-75001.6984521B-82,0002.314,62087B-95,0003.6018,000270B-108,0004.2033,600450B-1125,0004.20105,0001,140B-12Not screened----87dTotal Emissions of Stream B2,070aEquipment type: Light liquid pumpsCorrelation equation: Leak rate (kg/hr) = 1.90 × 10-5(SV)0.824Default-zero mass emission rate: 7.49 × 10-6kg/hrHours of operation: Stream B = 4,380bAdjusted SV = (unadjusted SV) × (RF of mixture taken from Figure A-2).cVOC Emissions = (correlation equation or default-zero emission rate) × (WPVOC/WPTOC) × (hours ofoperation).dVOC Emission = (no. of components) × (average emission factor) × ( wt. fraction of VOC) × (WPVOC/WPTOC) ×(hours of operation).

A-20TABLE A-12. ANNUALIZING EMISSIONS FOR LIGHT LIQUID PUMP A-15a

Hypothetical date Screening value (ppmv) Hours elapsed since last screening

value b VOC emissions since last screening value c (kg) January 1 5,000

-- -- February 1 0 744 0.006
March 1 0 672 0.005 April 1 8,000 744 23.3 May 1 100 720 0.6
June 1 1,000 744 4.2 July 1 0 720 0.005 August 1 0 744 0.006 September 1 0 744 0.006
October 1 10,000 720 27.0
November 1 0 744 0.006
December 1 0 720 0.005 January 1 0 744 0.006

TOTALS: 8,760 55.1

a Equipment type: Light liquid pumps

Correlation equation: Leak rate (kg/hr) = 1.90 × 10 -5 (SV) 0.824 Default-zero mass emission rate: 7.49 × 10 -6 kg/hr

b Hours elapsed since the last screening value was obtained. For

example, the hours elapsed since the screening value obtained on March 1 are the hours from February 1 to March 1, which equal 24 hr/day × 28 days, or 672 hours.

c VOC Emissions = (correlation equation or default-zero

emission rate) × (WP VOC /WP TOC) × (hours elapsed).

A-21A-9. ESTIMATING VOC EMISSIONS FROM EQUIPMENT CONTAINING ORGANIC COMPOUNDS NOT CLASSIFIED AS VOC’s. Stream C contains ethane, which is an organic compound, but is not classified as a VOC. When a monitoring instrument is used to screen equipment in Stream C, the resulting screening value will include measurement of the ethane. However, the ethane should not be included in the estimated VOC emission rate. The following equation is applied to subtract out the ethane contribution:

E VOC = E TOC × (WP VOC /WP TOC )
where:

E VOC = The VOC mass emissions from the equipment (kg/hr);

E TOC = The TOC mass emissions from the equipment (kg/hr); calculated from either the Average Emission Factor, Screening Ranges, Correlation, or Unit-Specific Correlation approaches;

WP VOC = The concentration of VOC in the equipment in weight percent;

WP TOC = The TOC concentration in the equipment in weight percent. The above calculation is demonstrated below by assuming that screening values have been obtained from equipment in Stream C as either greater than or equal to 10,000 ppmv or less than 10,000 ppmv. Assume 2 of the 40 gas valves in Stream C screened above 10,000 ppmv, and the remainder screened below 10,000 ppmv. Uncorrected VOC emissions are calculated using the Screening Ranges Approach:

E TOC = (F G × N G) + (F L × N L )
where:

E TOC = TOC emission rate for an equipment type (kg/hr);

F G = Applicable emission factor for sources with screening values greater than or equal to 10,000 ppmv (kg/hr/source);

A-22N G = Equipment count (specific equipment type) for sources with screening values greater than or equal to 10,000 ppmv;

F L = Applicable emission factor for sources with screening values less than 10,000 ppmv (kg/hr/source); and

N L = Equipment count (specific equipment type) for sources with screening values less than 10,000 ppmv.

Thus,

E TOC = 0.0782 kg/h r×2+ 0.000131 kg/hr × 38
= 0.161 kg/hr

Converting to an annual emission rate gives:

= 0.161 kg/hr × 8,760 hr/yr
= 1,410 kg/yr

Using the weight fraction of the compounds in Stream C given in table A-1 (65% ethyl acrylate, 25% ethane, and 10% water vapor), the above emission rate is corrected as follows:

E VOC = E TOC × (WP VOC /WP TOC ) = 1,410 kg/yr × 65/(65 + 25) = 1,020 kg/yr VOC emissions

A-10. ESTIMATING INORGANIC EQUIPMENT LEAKS If the hypothetical process unit also had equipment that contained a volatile inorganic compound, emissions could be estimated using the following guidelines. If a monitoring device is not available, the equipment emissions can be calculated using the Average Emission Factor Approach. If a monitoring device is available, the best approach for estimating the emissions is to generate unit specific correlations, but the EPA Correlation Equations could also be applied as in section A-4. If the monitoring device cannot accurately predict the screening value

A-23but can be used to predict concentrations greater than/less than 10,000 ppmv, the emissions may be estimated by applying the Screening Ranges approach presented in section A-3.

A-24APPENDIX B:

LEAK RATE/SCREENING VALUE CORRELATION DEVELOPMENT
AND REVISION OF SOCMI CORRELATIONS
AND EMISSION FACTORSAPPENDIX B

The purpose of this appendix is to provide supplemental information on the approach for developing site-specific correlations as discussed in chapter 2.0 of this document. Also, this appendix contains background information on the data collection and analysis performed to revise the SOCMI correlations and emission factors, and presents summary parameters associated with the SOCMI and petroleum industry correlations. Section B.1 addresses the following: Analysis of bagging and screening data; Development of a correlation equation; and Development of a default-zero leak rate. Section B.2 addresses the following: Analysis of new SOCMI bagging data; Development of revised correlations and default-zero leak rates; Development of revised SOCMI emission factors; and Summary of SOCMI and petroleum industry correlation parameters.

B.1 DEVELOPMENT OF SITE-SPECIFIC CORRELATION EQUATIONS Development of site-specific correlations involves bagging individual pieces of equipment. (Refer to chapter 4.0 for details on how equipment is bagged.) The emission rate and associated screening value from several equipment pieces of the same type (valve, pump, connector, etc.) and service (gas, light liquid or heavy liquid) are used to develop a correlation. The correlation predicts a leak rate based on a screening value. To develop a correlation, "bagging data" must be collected. In this appendix, "bagging data" refers to data used to estimate the mass emission rate from an equipment piece, and the screening value obtained with the portable monitoring instrument when the equipment piece is bagged. B.1.1 Preliminary Analysis of Bagging Data

. For the purposes of this discussion, it is assumed the blow-through method is used to bag the equipment piece. For each

B-1bagged (tented) equipment piece, two sample bags should be collected. For each sample bag the following bagging data should be recorded: (1) total organic compound concentration (ppmv) measured in the sample bag at the laboratory using a GC or similar instrument, (2) the mole percent and molecular weight of each of the constituents in the sample bag (or alternatively in the process stream contained within the enclosed equipment piece), (3) the temperature in the tent when the sample bag is collected, (4) the carrier gas flow rate out of the tent, (5) the tent oxygen concentration (6) background bag organic compound concentration measured at the laboratory (optional), and (7) the density and volume of any organic liquid collected from the bagged equipment piece and the time in which the liquid
accumulated. In some cases, the sample bag total organic concentration will be below the GC minimum detection limit. If this occurs, one half the GC minimum detection limit should be used to estimate emissions. For each sample bag, the vapor leak rate is calculated using the following equation:

(1.219×10 -5 )×(Q)×(MW)×(GC) Vapor leak rate (kg/hr) = T + 273.15

where:

1.219 x 10 -5 = A conversion factor based on the gas constant and assuming a pressure in the tent of 1 atmosphere ( o K × 10 6 × kg-mol/m 3 ) Q = Flow rate out of tent (m 3 /hr)

= N 2 flow rate ( /min) 1 [tent oxygen conc. (volume %)/21] × 0.06 m 3 /min /hr

T = Temperature in tent ( o C)

B-2MW = Molecular weight of organic compounds in the sample bag or alternatively in the process stream contained within the equipment piece being bagged. For mixtures, MW is calculated as follows:

MW = n

i=1 MW i x i

n

i=1 x i

where:

MW i = Molecular weight of organic compound i;

x i = Mole fraction of organic compound i; and

n = Number of organic compounds in the mixture.
GC = Sample bag organic compound concentration. If a background sample bag is obtained, the value of GC can be corrected for background organic compound concentration using the following equation:

where: GC = SBC Oxy x BBC 21

SBC = Sample bag organic compound concentration (ppmv); Oxy = Tent oxygen concentration (volume %); and BBC = Background sample bag organic compound concentration.
The vapor leak rate calculated from the two sample bags is averaged. Added to this average vapor leak rate is the leak rate of any liquid that is collected in the bag. The liquid leak rate is calculated as follows:

Liquid leak rate (kg/hr) = ρ V L 16.67 t

B-3where:
ρ = Density of organic liquid collected (g/m );

V L = Volume of organic liquid collected (m );

t = Time in which liquid is collected (minutes); and 16.67 = A conversion factor to adjust term to units of kilograms per hour [g × hr/(kg × min)]

Thus, the total emission rate for the bagged equipment piece is
as follows:

Leak rate (kg/hr) = Average vapor leak rate (kg/hr) + Liquid leak rate (kg/hr)

The screening value associated with each bagged equipment piece is calculated by subtracting the background screening value from the average of the initial and final screening values. In cases where the background concentration was larger than the average of the initial and final screening values, the screening value should be recorded as 0 ppmv. B.1.2 Correlation Equation Development

. After preliminary analysis of the bagging data is complete, there will be a mass emission rate and corresponding screening value associated with each individual equipment piece that was bagged. All mass emission rate/screening value data pairs with nonzero screening values are used to develop the site-specific correlation. Data pairs with a screening value of zero can be used to develop a default-zero leak rate, and this is discussed in section B.1.3. Two terms used in conjunction with developing the correlation are defined as follows: "log space"--where the logarithms of both the screening values and mass emission rates are evaluated, and "arithmetic space"--where the actual screening values and emission rates are evaluated. The data is first analyzed in log space to develop an expression relating the logarithm of the screening value to the logarithm of the mass

B-4emission rate. This expression is then transformed to arithmetic space to arrive at the correlation equation. It is necessary to perform the initial analysis in log space because both the screening value and mass emission rate data typically span several orders of magnitude, and the data are not normally distributed in arithmetic space. Normality of the data is important for the validity of the statistical procedures being used. Historically, the data have been shown to be approximately log-normally distributed. The first step in the development of the correlation equation is to calculate the logarithm of each screening value and mass emission rate. Note that the correlation developed will be the same whether the natural logarithm or base 10 logarithm is used. The next step is to perform simple linear (least squares) regression in log space. The log of the mass emission rate (dependent variable, Y) is regressed on the log of the screening value (independent variable, X). The resulting regression line takes the following form:

where: Y i = β 0 β 1 X i

Y i = Logarithm of the leak rate determined by bagging equipment piece i;

X i = Logarithm of the screening value for equipment piece i; β o = Intercept of regression line; and β 1 = Slope of regression line.

The value for the slope and intercept are calculated using the following equations:

β 1 = ( XY) ( X) ( Y)
X 2 ( X) 2

B-5and

where: β 0 = Y β 1 X

Once these have been calculated, then the Mean Squared Error X = X i
n

Y = Y i
n

XY = X i Y i
n

X 2
= X i 2

n
n = number of screening/bagging pairs.

(MSE) can be given by:

MSE = 1

n 2 n

i=1 r i 2

where:

The slope and intercept and a scale bias correction factor r i = Y i β 0 β 1 X i

(SCBF) are used in the final step to transform the regression equation from log space to arithmetic space. The transformed equation is the correlation equation and it is calculated as
follows:

Note that if the natural logarithm of the leak rates and Leak rate (kg/hr) = SBCF x (e or 10) β 0 x (Screening value) β 1

screening values is used when developing the regression line, then the "e" term should be raised to the power of the intercept

B-6( β 0 ). On the other hand, if the base 10 logarithm of the leak rates and screening values is used when developing the regression line, then the "10" term should be raised to the power of the intercept ( β 0 ). The SBCF is a correction factor which accounts for the variability of the data in the log space (see discussion in section 2.3.4). It is obtained by summing a sufficient number (usually 10-15) of the terms from the infinite series given
below:

(m-1)×T (m-1) 3 ×T 2 (m-1) 5 ×T 3 SBCF = 1 + + + + ....,
m m 2 ×2!×(m+1) m 3 ×3!×(m+1)×(m+3)

where:
T (when regression performed using base 10 logarithms) = (MSE/2)×((ln10) 2 );
T (when regression performed using natural logarithms) = (MSE/2);
MSE = mean square error from the regression;
ln10 = natural logarithm of 10; and
m = number of data pairs (n) - 1.
B.1.3 Determination of Default Zero and Pegged Mass Emission Rates

A default zero emission rate can be calculated based on the emission rates measured from bagged equipment that have a screening value of zero ppmv. A pegged emisison rate can be calculated based on the emission rates measured from bagged equipment that have a screening value reported as pegged. The first step to determine the default-zero or pegged leak rate is to take the logarithm of each of the mass emission rates and then determine the average log leak rate. The average log leak rate is used to calculate the default-zero or pegged mass emission rate. Analysis is performed in log space rather than just determining the arithmetic average because this gives the most efficient estimator of the default-zero or pegged leak rate. The average log leak rate and a scale bias correction factor, that

B-7takes into account the variance of the log mass emission rates, are then utilized in the following equation to calculate the
default zero leak rate:

Default Zero or pegged Leak Rate = SBCF × (10 or e) LOG:AVG (kg/hr)

where:

SBCF = Scale bias correction factor for the logs of the mass emission rates; and
LOG:AVG = Average of the logs of the mass emission rates.
The SBCF for the default zero or pegged leak rate determination is calculated using the same equation for the SBCF as presented in section B.1.2, with the following two exceptions: (1) the variance of the log mass emission rates is used in the "T" term, rather than the regression mean square error (MSE); and (2) the sample size (n) is used in the "m" term, rather than "n-1". The variance (S 2 ) of the log mass emission rates is calculated as:

S 2
= 1

n 1 n

i=1 (LOG:LEAK i LOG:AVG) 2

where:

LOG:LEAK i = Logarithm of leak rate from component i; LOG:AVG = Average of the logs of the mass emission rates; and n = Number of data points.

B.2 DEVELOPMENT OF REVISED SOCMI CORRELATIONS AND FACTORS In 1990 bagging data were obtained from several ethylene oxide (EO) and butadiene (BD) producers. Bagging data were collected from connectors, light liquid pumps, gas valves, and light liquid valves. In 1987 and 1988 screening data had been

B-8collected from the same EO/BD process units. These bagging and screening data were used to revise the SOCMI correlations and
factors. (Note that as used in the following discussion, "bagging data" refers to the screening value/mass emission data pairs, and "screening data" to the data set of screening values collected independently of the bagging data. Normally, bagging data are collected from a chosen set of equipment pieces to provide the best data for developing a correlation. On the other hand, screening data are collected from all equipment pieces to give a representative distribution of screening values). To revise the SOCMI correlations and factors, the data collected from the EO/BD process units were compared with data previously collected from SOCMI process units. In the following discussion this previously collected data are referred to as "old" data. The old SOCMI bagging data were collected in the Six-Unit Maintenance Study (EPA-600/S2-81-080). The old SOCMI screening data were collected in the 24-Unit Study (EPA-600/2-81-003). The EO/BD data are referred to as "new." When the data sets are joined, the resulting data set is referred to as "combined." B.2.1 Analysis of SOCMI Bagging Data Following the approach described in section B.1, the new SOCMI bagging data were analyzed to develop new correlations. A comparison of the old and new bagging data was performed to evaluate any differences. Note that for connectors, only new bagging data were analyzed since connectors were not bagged as part of the Six-Unit Maintenance Study. Attachment 1 includes the complete list of each of the emission rate/screening value datapoints and presents summary tables on the regression statistics of the old, new, and combined data. To evaluate the differences between the new and the old data for light liquid pumps, light liquid valves, and gas valves, the following statistical tests were applied:

B-9• Wilcoxon test of paired differences, and
• F-test of statistical parameters.

The statistical tests did not have consistent results for the three equipment types. For light liquid pumps, no statistically significant differences were found, for light liquid valves, the tests indicated significant differences, and for gas valves, the tests were inconclusive. A better comparison was a visual comparison of the data plotted in log space. This comparison was made by developing plots of the old and new bagging data with regression lines superimposed. All of the regression equations are plotted in figures B-1 through B-4. Figure B-1 presents the new bagging data and regression equation for connectors. Figures B-2 through B-4 show old and new bagging data superimposed upon the old, new, and combined regression equations for light liquid pumps, gas valves, and light liquid valves, respectively. The regression lines in these four figures are drawn to correspond only to the data points from which they were derived. Figures B-2 through B-4 suggest the old and new data points appear to lie along a common axis with a similar amount of scatter. Figures B-2 through B-4 also demonstrate that most of the old data were from equipment which had screening values exceeding 1,000 ppmv, whereas a significant portion of the new data came from equipment screening less than 1,000 ppmv. The correlation derived from combining the old and new bagging data spans the greatest range of screening values. Additionally, for each of the equipment types, the combined correlation equation has the best fit. Since the combined regressions span the greatest range of screening values and have the best fit, the combined data set was used to develop the revised SOCMI correlation equations. B.2.2 Development of Revised SOCMI Correlations and Development of Default-Zero Factors

.

B-10B-11

Figure B-1. Connector Regression EquationB-12 Figure B-2. Light Liquid Pump Regression EquationsB-13 Figure B-3. Gas Valve Regression EquationsB-14 Figure B-4. Light Liquid Valve Regression EquationsAfter the old and new bagging data were combined, an initial regression analysis was performed on the logarithms of the screening values and mass emission rates following the procedures outlined in section B.1 on the development of correlation equations. For the combined data sets outliers were removed. The residuals (differences between measured log mass emission rates and log mass emission rates predicted by the regression) were used to flag outliers. A data pair was flagged as an outlier whenever the absolute value of its studentized residual (the residual divided by its standard error) was greater than or equal to 3. These data pairs are indicated as outliers in the table contained in attachment 1, which lists the screening values and mass emission rates for the combined bagging data set. Attachment 2 contains a table listing all of the bagging data used to develop the default zero mass emission rates. These data were collected at the EO/BD process units, and were analyzed using the approach outlined in section B.1.3. B.2.3 Revision of SOCMI Emission Factors After the SOCMI correlations were revised, they were utilized in conjunction with the "old", "new", and "combined" screening value data sets to revise the SOCMI emission factors. Recall that the "old" screening data were the data collected in the SOCMI 24-Unit Study (EPA-600/2-81-003), the "new" screening data were the data collected from the EO/BD process units in 1987 and 1988, and the combined data were the two data sets combined. Using screening data in conjunction with the applicable correlation equation, emission factors are calculated in the following manner.
(1) Screening values with a value of zero are assigned the default zero emission rate,
(2) Pegged screening values were assigned the appropriate pegged emission rate,
(3) All other screening values are entered into the applicable correlation equation to determine the associated mass emission rate, and

B-15(4) The sum of all of the individual emission rates is divided by the total number of screening values (i.e., equipment pieces) to give the average factor. These steps were followed to revise the SOCMI average emission factors for connectors, light liquid pumps, gas valves, and light liquid valves. The same approach was used to revise the SOCMI Screening Range Emission factors (> 10,000 ppmv / <10,000 ppmv), except that the screening values were segregated into the two ranges to calculate the average of each range. Consistent with development of the revised SOCMI correlation equations (which were developed from the combined bagging data set), the combined screening data set was used to revise the SOCMI factors. The combined data set has the advantage that it reflects changes that have occurred in SOCMI process units since the 24-Unit Study, and contains data from a representative sampling of SOCMI process units. To develop the emission factors it was necessary to make adjustments to a small percentage of the screening values. These adjustments were applied to large screening values that were identified as "pegged data." The large screening value data are important in the emission factor calculations and these adjustments were made in an attempt to keep as many screening values in the analysis as possible. Examination of the frequency distributions of the screening value data sets revealed spikes near 10,000 ppmv (between 9980 and 10,001 ppmv) and near 100,000 ppmv (between 99,980 and 100,001 ppmv). These spikes indicate that the instrument was "pegged" or unable to measure the concentration being sampled because the concentration was beyond the measurement range of the instrument. It was assumed that screening values pegged at 10,000 ppmv had actual values between 10,000 and 100,000 ppmv, and that screening values pegged at 100,000 ppmv had actual values greater than 100,000 ppmv. Because there were several screening values greater than 10,000 ppmv and 100,000 ppmv that were not pegged, an average from the two ranges

B-16(10,000-100,000 ppmv and >100,000 ppv) was calculated to substitute for the pegged readings. For the 10,000-100,000 ppmv range, the average was 33,620 ppm and for the greater than 100,000 ppmv range, the average was 302,367 ppm. These averages were used in the emission factor analysis for pegged data from the screening data sets. Thus, each pegged screening value was assigned the applicable average screening value, which was entered into the correlation to predict emissions. Attachment 3 lists the average emission factors generated from each of the screening data sets, using the revised SOCMI correlations. There are thousands of screening values in the data sets, and these data sets are not reproduced in this appendix. Instead, figures plotting the distribution of the screening values are presented in attachment 3. B.2.4 Summary of SOCMI and Petroleum Industry Correlation

Parameters Table B-1 presents the regression line slope and intercept and the SBCF associated with each of the revised SOCMI and petroleum industry correlations contained in tables 2-9 and 2-10 of this document.

B-17TABLE B-1. SUMMARY OF SOCMI AND PETROLEUM INDUSTRY CORRELATION PARAMETERS.

Equipment type Regression intercept a ( β 0 ) Regression slope ( β 0 ) SBCF
SOCMI Correlations
Gas valves -6.529 0.873 6.315 Light liquid valves -6.069 0.797 7.520 Light liquid pumps -5.273 0.824 3.563
Connectors -6.434 0.885 8.298 Petroleum Industry Correlation
Valves -6.154 0.746 3.27
Pumps -5.014 0.610 5.15
Others -5.575 0.589 5.14

Connectors -6.468 0.735 4.51 Flanges -5.988 0.703 4.48 Open-Ended Lines -6.366 0.704 5.11

a Regression intercepts are based on analysis in log space using

Base 10 logarithms of leak rates in kg/hr.

B-18APPENDIX B: ATTACHMENT 1

This attachment lists bagging data used to develop the combined correlation equations for each of the equipment types in table B-1-1. Also included is a summary table (table B-1-2) of the regression statistics associated with the old, new, and combined SOCMI bagging data sets. Note that the regression statistics presented in table B-1-2 are based on development of the regression lines using natural log leak rates and natural log screening values.

B-19Table B-1-1. Bagging data used to develop the combined correlation equations.
---------------------- Equipment Type=CONNECTOR Service=ALL -----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv)

EO NEW 0.0000000728 299.00 -16.4361 5.7004 EO NEW 0.0000000734 2.00 -16.4271 0.6931 EO NEW 0.0000001004 4.50 -16.1142 1.5041 EO NEW 0.0000001061 0.50 -16.0586 -0.6931 EO NEW 0.0000001101 6.00 -16.0217 1.7918 EO NEW 0.0000001137 0.80 -15.9900 -0.2231 BD NEW 0.0000001265 2.90 -15.8832 1.0647 EO NEW 0.0000001544 21.50 -15.6835 3.0681 EO NEW 0.0000001613 4.25 -15.6400 1.4469 BD NEW 0.0000001620 1.00 -15.6354 0.0000 EO NEW 0.0000001644 2.00 -15.6207 0.6931 EO NEW 0.0000001731 18.50 -15.5693 2.9178 EO NEW 0.0000002953 458.50 -15.0354 6.1280 EO NEW 0.0000002996 0.40 -15.0209 -0.9163 EO NEW 0.0000003195 0.40 -14.9565 -0.9163 BD NEW 0.0000003254 13.80 -14.9382 2.6247 BD NEW 0.0000003346 1.70 -14.9105 0.5306 BD NEW 0.0000003430 1.35 -14.8856 0.3001 BD NEW 0.0000003442 12.75 -14.8819 2.5455 BD NEW 0.0000003939 4.00 -14.7473 1.3863 BD NEW 0.0000003994 10.00 -14.7334 2.3026 EO NEW 0.0000004007 0.80 -14.7300 -0.2231 BD NEW 0.0000004288 4.00 -14.6623 1.3863 BD NEW 0.0000004757 1.50 -14.5586 0.4055 EO NEW 0.0000004798 999.00 -14.5499 6.9068 EO NEW 0.0000005309 399.40 -14.4486 5.9900 EO NEW 0.0000005812 2.75 -14.3582 1.0116 EO NEW 0.0000005944 28.50 -14.3357 3.3499 EO NEW 0.0000006075 128.00 -14.3140 4.8520 BD NEW 0.0000006524 97.00 -14.2426 4.5747 EO NEW 0.0000007355 3.50 -14.1227 1.2528 BD NEW 0.0000007648 3.25 -14.0837 1.1787 BD NEW 0.0000008560 8.50 -13.9710 2.1401 BD NEW 0.0000008798 28.50 -13.9436 3.3499 BD NEW 0.0000008869 2.00 -13.9356 0.6931 EO NEW 0.0000008924 8.30 -13.9293 2.1163 EO NEW 0.0000009888 4.25 -13.8267 1.4469 BD NEW 0.0000010715 17.00 -13.7464 2.8332 EO NEW 0.0000012661 1.00 -13.5795 0.0000 EO NEW 0.0000016351 4.50 -13.3238 1.5041 BD NEW 0.0000017995 4.00 -13.2280 1.3863 BD NEW 0.0000018303 19.25 -13.2110 2.9575 BD NEW 0.0000020777 3.50 -13.0842 1.2528 BD NEW 0.0000022858 3.75 -12.9888 1.3218 EO NEW 0.0000032725 3.00 -12.6300 1.0986

B-20Table B-1-1. Bagging data used to develop the correlation equations
---------------------- Equipment Type=CONNECTOR Service=ALL ----------------------- (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv)

EO NEW 0.0000036190 1.60 -12.5293 0.4700 BD NEW 0.0000036396 0.80 -12.5236 -0.2231 BD NEW 0.0000038387 8.50 -12.4704 2.1401 EO NEW 0.0000041625 6.50 -12.3894 1.8718 EO NEW 0.0000044784 48.00 -12.3162 3.8712 BD NEW 0.0000046207 7.80 -12.2850 2.0541 BD NEW 0.0000057784 41.50 -12.0614 3.7257 BD NEW 0.0000080668 12.00 -11.7278 2.4849 BD NEW 0.0000095125 100.00 -11.5629 4.6052 EO NEW 0.0000100797 297.00 -11.5050 5.6937 BD NEW 0.0000137255 19.75 -11.1963 2.9832 BD NEW 0.0000140845 4.50 -11.1704 1.5041 BD NEW 0.0000140911 14.00 -11.1700 2.6391 EO NEW 0.0000142252 63.50 -11.1605 4.1510 BD NEW 0.0000143958 195.50 -11.1486 5.2756 BD NEW 0.0000151611 16.00 -11.0968 2.7726 BD NEW 0.0000161064 13.50 -11.0363 2.6027 EO NEW 0.0000166253 18.50 -11.0046 2.9178 BD NEW 0.0000168916 195.00 -10.9887 5.2730 EO NEW 0.0000178679 0.95 -10.9325 -0.0513 BD NEW 0.0000183124 123.50 -10.9079 4.8162 BD NEW 0.0000191290 4995.00 -10.8643 8.5162 BD NEW 0.0000194650 16.50 -10.8469 2.8034 EO NEW 0.0000197515 50.50 -10.8323 3.9220 BD NEW 0.0000198244 23.00 -10.8286 3.1355 BD NEW 0.0000227951 320.50 -10.6890 5.7699 BD NEW 0.0000279813 67.00 -10.4840 4.2047 BD NEW 0.0000348217 18.00 -10.2653 2.8904 BD NEW 0.0000351763 195.50 -10.2551 5.2756 BD NEW 0.0000359334 9.00 -10.2338 2.1972 BD NEW 0.0000403480 198.00 -10.1180 5.2883 BD NEW 0.0000423987 472.00 -10.0684 6.1570 BD NEW 0.0000445724 13.00 -10.0184 2.5649 EO NEW 0.0000509982 25.00 -9.8837 3.2189 EO NEW 0.0000512445 323.00 -9.8789 5.7777 BD NEW 0.0000595643 275.00 -9.7285 5.6168 BD NEW 0.0000758688 35.00 -9.4865 3.5553 BD NEW 0.0000860423 98.00 -9.3607 4.5850 BD NEW 0.0000910990 1049.00 -9.3036 6.9556 BD NEW 0.0000947099 94.40 -9.2647 4.5475 BD NEW 0.0001007398 197.50 -9.2030 5.2857 BD NEW 0.0001051050 38.80 -9.1606 3.6584 BD NEW 0.0001178839 94.80 -9.0458 4.5518 BD NEW 0.0001397861 371.00 -8.8754 5.9162

B-21Table B-1-1. Bagging data used to develop the correlation equations
---------------------- Equipment Type=CONNECTOR Service=ALL ----------------------- (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv)

BD NEW 0.0001721438 54.90 -8.6672 4.0055 BD NEW 0.0001806903 4747.00 -8.6187 8.4653 BD NEW 0.0002038979 895.00 -8.4979 6.7968 BD NEW 0.0002463283 97.00 -8.3088 4.5747 BD NEW 0.0002731277 549.00 -8.2056 6.3081 BD NEW 0.0002853205 345.00 -8.1619 5.8435 BD NEW 0.0003727741 198.50 -7.8945 5.2908 BD NEW 0.0004184529 199.00 -7.7789 5.2933 BD NEW 0.0005627360 195.00 -7.4827 5.2730 EO NEW 0.0008093015 997.00 -7.1193 6.9048 BD NEW 0.0008566981 99.00 -7.0624 4.5951 BD NEW 0.0013381945 1049.00 -6.6164 6.9556 BD NEW 0.0013408366 999.00 -6.6145 6.9068 BD NEW 0.0017192076 471.50 -6.3659 6.1559 BD NEW 0.0021650014 1997.00 -6.1353 7.5994 BD NEW 0.0085056085 2999.00 -4.7670 8.0060 BD NEW 0.0101785661 3996.00 -4.5875 8.2930 BD NEW 0.0587476684 99998.80 -2.8345 11.5129
N = 107 (0 outliers)

B-22Table B-1-1. Bagging data used to develop the correlation equations
------------------------ Equipment Type=PUMP Service=LL ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

BD NEW 0.0000003333 3.00 -14.9141 1.0986 BD NEW 0.0000003346 64.40 -14.9104 4.1651 OUTLIER BD NEW 0.0000004908 1.30 -14.5272 0.2624 EO NEW 0.0000012091 4.00 -13.6256 1.3863 BD NEW 0.0000021532 9.50 -13.0486 2.2513 EO NEW 0.0000038359 768.00 -12.4711 6.6438 OUTLIER EO NEW 0.0000055733 49.00 -12.0975 3.8918 EO NEW 0.0000067016 8.40 -11.9132 2.1282 RE OLD 0.0000068315 42.53 -11.8940 3.7503 EO NEW 0.0000115240 3.00 -11.3711 1.0986 EO NEW 0.0000137032 1.00 -11.1979 0.0000 BD NEW 0.0000173708 15.00 -10.9607 2.7081 RE OLD 0.0000182707 83.26 -10.9102 4.4220 BD NEW 0.0000218470 21.00 -10.7314 3.0445 BD NEW 0.0000234610 8.00 -10.6602 2.0794 BD NEW 0.0000243023 10.00 -10.6249 2.3026 BD NEW 0.0000262744 95.00 -10.5469 4.5539 RE OLD 0.0000273344 647.80 -10.5074 6.4736 BD NEW 0.0000287475 7.80 -10.4570 2.0541 RE OLD 0.0000343297 719.36 -10.2795 6.5784 EO NEW 0.0000385230 13.90 -10.1643 2.6319 BD NEW 0.0000418537 394.00 -10.0813 5.9764 BD NEW 0.0000474696 4.00 -9.9554 1.3863 EO NEW 0.0000588925 2.75 -9.7398 1.0116 BD NEW 0.0000715064 33.00 -9.5457 3.4965 EO NEW 0.0000722114 180.00 -9.5359 5.1930 BD NEW 0.0000978468 1.00 -9.2321 0.0000 BD NEW 0.0001152858 2.75 -9.0681 1.0116 EO NEW 0.0001232483 74.00 -9.0013 4.3041 EO NEW 0.0001803724 44.00 -8.6205 3.7842 RE OLD 0.0001957145 47.12 -8.5389 3.8526 RE OLD 0.0001991513 49.68 -8.5214 3.9057 RE OLD 0.0002209241 744.91 -8.4177 6.6133 BD NEW 0.0002667811 892.50 -8.2291 6.7940 RE OLD 0.0002999432 2388.28 -8.1119 7.7783 BD NEW 0.0003013546 65.00 -8.1072 4.1744 RE OLD 0.0004782523 49.86 -7.6454 3.9091 EO NEW 0.0005168934 105.00 -7.5677 4.6540 EO NEW 0.0005477897 499.00 -7.5096 6.2126 RE OLD 0.0005646821 16033.45 -7.4792 9.6824 EO NEW 0.0005681949 595.00 -7.4730 6.3886 EO NEW 0.0005857415 349.00 -7.4426 5.8551 RE OLD 0.0006402389 3102.49 -7.3537 8.0400 EO NEW 0.0006886734 199.00 -7.2807 5.2933 BD NEW 0.0007364641 598.00 -7.2137 6.3936

B-23Table B-1-1. Bagging data used to develop the correlation equations
------------------------ Equipment Type=PUMP Service=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

RE OLD 0.0007563452 1378.39 -7.1870 7.2287 RE OLD 0.0007987816 8095.43 -7.1324 8.9991 RE OLD 0.0009912542 289.26 -6.9165 5.6673 BD NEW 0.0010889569 471.00 -6.8225 6.1549 RE OLD 0.0011480956 521.79 -6.7697 6.2573 BD NEW 0.0012930833 348.00 -6.6507 5.8522 RE OLD 0.0013248663 2221.10 -6.6264 7.7058 BD NEW 0.0014886548 3197.00 -6.5099 8.0700 EO NEW 0.0016401471 101.20 -6.4130 4.6171 RE OLD 0.0017660014 24145.32 -6.3390 10.0918 BD NEW 0.0018539657 299.00 -6.2904 5.7004 BD NEW 0.0021087390 997.00 -6.1617 6.9048 EO NEW 0.0022296212 2000.00 -6.1059 7.6009 BD NEW 0.0023007567 5499.25 -6.0745 8.6124 BD NEW 0.0025947420 1993.80 -5.9543 7.5978 RE OLD 0.0027435637 2125.99 -5.8985 7.6620 RE OLD 0.0029144932 5870.47 -5.8381 8.6777 BD NEW 0.0029456140 5.75 -5.8274 1.7492 BD NEW 0.0033415187 125.00 -5.7013 4.8283 BD NEW 0.0036014533 1899.00 -5.6264 7.5491 BD NEW 0.0036569429 1393.90 -5.6111 7.2399 EO NEW 0.0037009240 3197.50 -5.5992 8.0701 BD NEW 0.0037297151 599.00 -5.5914 6.3953 BD NEW 0.0039913442 700.00 -5.5236 6.5511 RE OLD 0.0041248489 2775.53 -5.4907 7.9286 RE OLD 0.0046220969 16654.09 -5.3769 9.7204 RE OLD 0.0046281246 6538.83 -5.3756 8.7855 BD NEW 0.0050222262 1099.00 -5.2939 7.0022 RE OLD 0.0054013839 9501.80 -5.2211 9.1592 BD NEW 0.0055450728 2998.00 -5.1948 8.0057 RE OLD 0.0070361493 1381.77 -4.9567 7.2311 BD NEW 0.0071307927 27.60 -4.9433 3.3178 BD NEW 0.0081605157 6498.00 -4.8084 8.7792 EO NEW 0.0090139120 7696.90 -4.7090 8.9486 BD NEW 0.0098565101 2548.00 -4.6196 7.8431 BD NEW 0.0101206645 2997.00 -4.5932 8.0054 RE OLD 0.0108936908 12820.53 -4.5196 9.4588 RE OLD 0.0110475772 14254.89 -4.5055 9.5649 BD NEW 0.0115165376 3194.50 -4.4640 8.0692 RE OLD 0.0120415404 20840.78 -4.4194 9.9447 RE OLD 0.0120492786 19187.09 -4.4188 9.8620 BD NEW 0.0126046858 5248.25 -4.3737 8.5656 RE OLD 0.0135546418 15011.05 -4.3010 9.6165 RE OLD 0.0138366847 10491.80 -4.2804 9.2583

B-24Table B-1-1. Bagging data used to develop the correlation equations
------------------------ Equipment Type=PUMP Service=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

BD NEW 0.0154757686 3998.50 -4.1685 8.2937 BD NEW 0.0155724932 3998.00 -4.1622 8.2935 RE OLD 0.0156873305 300.60 -4.1549 5.7058 RE OLD 0.0159032925 51041.21 -4.1412 10.8404 RE OLD 0.0196113751 88270.79 -3.9316 11.3882 BD NEW 0.0198424922 2748.50 -3.9199 7.9188 BD NEW 0.0219422932 797.00 -3.8193 6.6809 RE OLD 0.0220953073 38632.61 -3.8124 10.5619 BD NEW 0.0221617288 6996.50 -3.8094 8.8532 RE OLD 0.0226278893 12142.30 -3.7886 9.4045 RE OLD 0.0232021936 22078.88 -3.7635 10.0024 RE OLD 0.0258831450 10996.59 -3.6542 9.3053 RE OLD 0.0263221310 8527.17 -3.6373 9.0510 RE OLD 0.0274280572 193253.34 -3.5962 12.1718 RE OLD 0.0300037851 12130.06 -3.5064 9.4034 RE OLD 0.0305561087 16850.04 -3.4882 9.7321 RE OLD 0.0361388265 9472.44 -3.3204 9.1561 RE OLD 0.0371630240 37500.32 -3.2924 10.5321 RE OLD 0.0409811410 12196.61 -3.1946 9.4089 RE OLD 0.0476567087 130564.77 -3.0437 11.7796 RE OLD 0.0480145702 23101.38 -3.0363 10.0476 BD NEW 0.0492542578 5998.00 -3.0108 8.6992 RE OLD 0.0556463965 38446.34 -2.8887 10.5570 RE OLD 0.0572488867 3111.50 -2.8603 8.0429 RE OLD 0.0586671574 41504.10 -2.8359 10.6335 BD NEW 0.0863688407 99996.00 -2.4491 11.5129 RE OLD 0.0977863072 88269.36 -2.3250 11.3881 BD NEW 0.1039387219 5997.00 -2.2640 8.6990 RE OLD 0.1074526291 45285.17 -2.2307 10.7207 BD NEW 0.2535689673 99994.00 -1.3721 11.5129
N = 119 (2 outliers)

B-25Table B-1-1. Bagging data used to develop the correlation equations
------------------------ Equipment Type=VALVE Service=G ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

EO NEW 0.0000000717 37.50 -16.4508 3.6243 EO NEW 0.0000000720 35.00 -16.4468 3.5553 EO NEW 0.0000000737 2.00 -16.4235 0.6931 BD NEW 0.0000001062 1.00 -16.0577 0.0000 EO NEW 0.0000001082 4.00 -16.0396 1.3863 EO NEW 0.0000001147 4.00 -15.9811 1.3863 EO NEW 0.0000001167 0.10 -15.9641 -2.3026 EO NEW 0.0000001170 9.00 -15.9608 2.1972 EO NEW 0.0000001172 5.00 -15.9591 1.6094 EO NEW 0.0000001198 4.00 -15.9374 1.3863 EO NEW 0.0000001251 21.50 -15.8945 3.0681 EO NEW 0.0000001525 1.20 -15.6963 0.1823 EO NEW 0.0000001579 1.00 -15.6615 0.0000 EO NEW 0.0000001705 2.00 -15.5848 0.6931 EO NEW 0.0000001964 98.25 -15.4430 4.5875 EO NEW 0.0000002292 3.00 -15.2887 1.0986 EO NEW 0.0000002537 224.30 -15.1869 5.4130 EO NEW 0.0000002824 9.00 -15.0800 2.1972 BD NEW 0.0000003468 6.20 -14.8747 1.8245 BD NEW 0.0000003511 1.75 -14.8622 0.5596 EO NEW 0.0000003724 0.40 -14.8032 -0.9163 BD NEW 0.0000004915 1.00 -14.5259 0.0000 BD NEW 0.0000005202 1.50 -14.4690 0.4055 EO NEW 0.0000005222 108.00 -14.4652 4.6821 EO NEW 0.0000005551 4.00 -14.4041 1.3863 BD NEW 0.0000006288 1.25 -14.2795 0.2231 EO NEW 0.0000007041 0.20 -14.1663 -1.6094 EO NEW 0.0000007204 1497.50 -14.1434 7.3116 BD NEW 0.0000007597 2.50 -14.0903 0.9163 EO NEW 0.0000008744 68.90 -13.9497 4.2327 EO NEW 0.0000010541 198.00 -13.7628 5.2883 BD NEW 0.0000013384 51.50 -13.5241 3.9416 BD NEW 0.0000013799 3499.30 -13.4935 8.1603 BD NEW 0.0000013870 15.70 -13.4884 2.7537 BD NEW 0.0000018645 6.00 -13.1925 1.7918 BD NEW 0.0000018779 1.50 -13.1854 0.4055 EO NEW 0.0000021100 99.00 -13.0688 4.5951 EO NEW 0.0000022366 0.20 -13.0105 -1.6094 EO NEW 0.0000024148 598.00 -12.9339 6.3936 BD NEW 0.0000025627 28.00 -12.8744 3.3322 EO NEW 0.0000034003 678.00 -12.5916 6.5191 BD NEW 0.0000036200 6.00 -12.5290 1.7918 EO NEW 0.0000036375 19.00 -12.5242 2.9444 EO NEW 0.0000038715 118.25 -12.4619 4.7728 EO NEW 0.0000042396 38.40 -12.3710 3.6481

B-26Table B-1-1. Bagging data used to develop the correlation equations
------------------------ Equipment Type=VALVE Service=G ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

BD NEW 0.0000045549 5.40 -12.2993 1.6864 EO NEW 0.0000056834 9.50 -12.0780 2.2513 BD NEW 0.0000061124 4.00 -12.0052 1.3863 EO NEW 0.0000070548 2.10 -11.8618 0.7419 BD NEW 0.0000074252 17.50 -11.8106 2.8622 BD NEW 0.0000080241 3.40 -11.7331 1.2238 EO NEW 0.0000083624 40.15 -11.6918 3.6926 RE OLD 0.0000118648 20.46 -11.3419 3.0184 BD NEW 0.0000128110 8.50 -11.2652 2.1401 BD NEW 0.0000137662 83.90 -11.1933 4.4296 RE OLD 0.0000149663 4952.69 -11.1097 8.5077 RE OLD 0.0000166075 4954.50 -11.0057 8.5081 RE OLD 0.0000175591 1007.37 -10.9499 6.9151 EO NEW 0.0000214657 698.50 -10.7491 6.5489 BD NEW 0.0000220929 20.50 -10.7203 3.0204 EO NEW 0.0000243523 850.00 -10.6229 6.7452 BD NEW 0.0000246644 144.50 -10.6101 4.9733 BD NEW 0.0000263657 139.25 -10.5434 4.9363 BD NEW 0.0000285391 15.50 -10.4642 2.7408 BD NEW 0.0000298709 109.00 -10.4186 4.6913 RE OLD 0.0000357822 2987.55 -10.2381 8.0022 RE OLD 0.0000359337 2497.04 -10.2338 7.8229 BD NEW 0.0000365393 598.00 -10.2171 6.3936 BD NEW 0.0000395358 3.50 -10.1383 1.2528 BD NEW 0.0000421641 98.50 -10.0739 4.5901 RE OLD 0.0000440123 2282.07 -10.0310 7.7328 EO NEW 0.0000445925 17.50 -10.0179 2.8622 BD NEW 0.0000523996 78.00 -9.8566 4.3567 BD NEW 0.0000557747 119.00 -9.7942 4.7791 RE OLD 0.0000617007 2670.91 -9.6932 7.8902 RE OLD 0.0000647076 1740.60 -9.6456 7.4620 RE OLD 0.0000724907 680.87 -9.5321 6.5234 RE OLD 0.0000779572 1315.53 -9.4594 7.1820 RE OLD 0.0000833618 290.43 -9.3923 5.6714 RE OLD 0.0000996210 700.59 -9.2141 6.5519 RE OLD 0.0001071514 4740.81 -9.1413 8.4640 RE OLD 0.0001137777 4385.68 -9.0813 8.3861 BD NEW 0.0001197735 474.40 -9.0299 6.1621 RE OLD 0.0001341897 987.15 -8.9163 6.8948 RE OLD 0.0001376705 496.21 -8.8906 6.2070 RE OLD 0.0001518078 1224.74 -8.7929 7.1105 RE OLD 0.0001625511 24157.28 -8.7245 10.0923 EO NEW 0.0001720041 498.75 -8.6680 6.2121 RE OLD 0.0001766026 7061.58 -8.6416 8.8624

B-27Table B-1-1. Bagging data used to develop the correlation equations
------------------------ Equipment Type=VALVE Service=G ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

BD NEW 0.0001866845 824.40 -8.5861 6.7147 RE OLD 0.0001904680 1643.51 -8.5660 7.4046 RE OLD 0.0001964120 1423.98 -8.5353 7.2612 RE OLD 0.0001977607 24689.43 -8.5285 10.1141 RE OLD 0.0002152405 1556.44 -8.4438 7.3502 RE OLD 0.0002180108 2095.88 -8.4310 7.6477 RE OLD 0.0002232184 3292.43 -8.4074 8.0994 RE OLD 0.0002275124 6482.10 -8.3883 8.7768 RE OLD 0.0002307162 4804.03 -8.3743 8.4772 RE OLD 0.0002322459 4368.95 -8.3677 8.3823 BD NEW 0.0002437423 499.40 -8.3194 6.2134 RE OLD 0.0002528838 928.66 -8.2826 6.8337 RE OLD 0.0002757637 877.50 -8.1960 6.7771 BD NEW 0.0002760188 6695.10 -8.1950 8.8091 EO NEW 0.0002904846 8998.00 -8.1440 9.1048 RE OLD 0.0003425098 2139.46 -7.9792 7.6683 EO NEW 0.0003724437 9998.00 -7.8954 9.2101 BD NEW 0.0003991030 394.00 -7.8263 5.9764 RE OLD 0.0004050504 9863.86 -7.8115 9.1966 BD NEW 0.0004404057 1999.00 -7.7278 7.6004 RE OLD 0.0004427801 4287.44 -7.7224 8.3634 RE OLD 0.0004461460 18661.82 -7.7149 9.8342 BD NEW 0.0004471948 799.00 -7.7125 6.6834 RE OLD 0.0004520589 55794.96 -7.7017 10.9294 RE OLD 0.0004529831 4949.37 -7.6997 8.5070 RE OLD 0.0004536846 3965.77 -7.6981 8.2855 RE OLD 0.0004640417 560.84 -7.6755 6.3294 RE OLD 0.0004685177 4279.25 -7.6659 8.3615 RE OLD 0.0004728028 14956.09 -7.6568 9.6129 RE OLD 0.0005228957 4399.96 -7.5561 8.3894 RE OLD 0.0005323154 2867.11 -7.5383 7.9611 RE OLD 0.0005465275 16699.10 -7.5119 9.7231 BD NEW 0.0005634682 2999.70 -7.4814 8.0063 BD NEW 0.0005651718 247.00 -7.4784 5.5094 RE OLD 0.0005730494 2037.49 -7.4645 7.6195 RE OLD 0.0005839129 35105.41 -7.4458 10.4661 RE OLD 0.0005991093 246.51 -7.4201 5.5074 RE OLD 0.0006007199 27836.27 -7.4174 10.2341 RE OLD 0.0006146615 1592.14 -7.3944 7.3728 BD NEW 0.0006404920 2743.50 -7.3533 7.9170 RE OLD 0.0006448431 2313.46 -7.3465 7.7465 BD NEW 0.0007363507 1247.00 -7.2138 7.1285 EO NEW 0.0009188385 3448.00 -6.9924 8.1455 RE OLD 0.0009212745 2316.36 -6.9898 7.7478

B-28Table B-1-1. Bagging data used to develop the correlation equations
------------------------ Equipment Type=VALVE Service=G ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

RE OLD 0.0009386789 7331.62 -6.9710 8.9000 RE OLD 0.0009859662 32119.44 -6.9219 10.3772 RE OLD 0.0011533445 2785.34 -6.7651 7.9321 RE OLD 0.0011636438 2797.20 -6.7562 7.9364 RE OLD 0.0011668930 203224.00 -6.7534 12.2221 RE OLD 0.0011712242 21751.69 -6.7497 9.9874 RE OLD 0.0017829290 67504.85 -6.3295 11.1200 RE OLD 0.0019401846 56199.96 -6.2450 10.9367 RE OLD 0.0020010182 8684.64 -6.2141 9.0693 RE OLD 0.0022581253 4284.86 -6.0932 8.3628 RE OLD 0.0022870889 3791.44 -6.0805 8.2405 RE OLD 0.0025260448 3163.33 -5.9811 8.0594 RE OLD 0.0025348896 534.08 -5.9776 6.2805 RE OLD 0.0026295658 50201.19 -5.9409 10.8238 RE OLD 0.0027833322 20393.42 -5.8841 9.9230 RE OLD 0.0029409798 4530.72 -5.8290 8.4186 RE OLD 0.0031312882 1860.09 -5.7663 7.5284 BD NEW 0.0031778789 4297.80 -5.7515 8.3659 RE OLD 0.0033409352 219611.97 -5.7015 12.2996 RE OLD 0.0033838729 23015.69 -5.6887 10.0439 RE OLD 0.0036846059 17536.22 -5.6036 9.7720 RE OLD 0.0036971583 16495.48 -5.6002 9.7108 RE OLD 0.0039426484 12647.22 -5.5359 9.4452 RE OLD 0.0039504089 34241.04 -5.5339 10.4412 RE OLD 0.0040050325 1333.88 -5.5202 7.1958 RE OLD 0.0041065399 4005.05 -5.4952 8.2953 RE OLD 0.0041660267 2803.86 -5.4808 7.9388 RE OLD 0.0046273787 20516.30 -5.3758 9.9290 RE OLD 0.0051511364 3629.80 -5.2685 8.1969 RE OLD 0.0060064387 760.42 -5.1149 6.6339 RE OLD 0.0064640997 61150.08 -5.0415 11.0211 RE OLD 0.0067947745 102781.04 -4.9916 11.5404 RE OLD 0.0086599432 287461.04 -4.7490 12.5688 BD NEW 0.0102338821 12994.00 -4.5821 9.4722 RE OLD 0.0112479155 9730.32 -4.4876 9.1830 RE OLD 0.0150883255 749143.47 -4.1938 13.5267 RE OLD 0.0192079955 191834.63 -3.9524 12.1644 RE OLD 0.0212769340 29340.67 -3.8501 10.2867 RE OLD 0.0262475666 189629.11 -3.6402 12.1528 RE OLD 0.0265051976 2373.75 -3.6304 7.7722 RE OLD 0.0277367164 820321.32 -3.5850 13.6175 RE OLD 0.0342721260 90882.86 -3.3734 11.4173 RE OLD 0.0449106195 17031.74 -3.1031 9.7428 RE OLD 0.0645502674 16874.50 -2.7403 9.7336

B-29Table B-1-1. Bagging data used to develop the correlation equations
------------------------ Equipment Type=VALVE Service=G ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

RE OLD 0.1109042134 326432.21 -2.1991 12.6960 RE OLD 0.1140677949 20836.56 -2.1710 9.9445
N = 179 (0 outliers)

B-30Table B-1-1. Bagging data used to develop the correlation equations
----------------------- Equipment Type=VALVE Service=LL ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

EO NEW 0.0000001148 2.00 -15.9798 0.6931 EO NEW 0.0000001182 0.40 -15.9509 -0.9163 EO NEW 0.0000001490 0.70 -15.7195 -0.3567 EO NEW 0.0000001545 7.00 -15.6828 1.9459 BD NEW 0.0000001546 2.00 -15.6825 0.6931 BD NEW 0.0000001705 2.25 -15.5843 0.8109 EO NEW 0.0000001748 13.50 -15.5593 2.6027 BD NEW 0.0000001777 1.50 -15.5431 0.4055 EO NEW 0.0000002092 0.90 -15.3801 -0.1054 EO NEW 0.0000002655 24.25 -15.1418 3.1884 EO NEW 0.0000002662 34.00 -15.1392 3.5264 EO NEW 0.0000002674 119.00 -15.1344 4.7791 EO NEW 0.0000002973 1.00 -15.0285 0.0000 BD NEW 0.0000003209 0.25 -14.9523 -1.3863 BD NEW 0.0000003246 14.00 -14.9406 2.6391 BD NEW 0.0000003272 145.00 -14.9326 4.9767 BD NEW 0.0000003761 1.00 -14.7934 0.0000 EO NEW 0.0000004160 1.10 -14.6925 0.0953 BD NEW 0.0000004269 2.50 -14.6668 0.9163 EO NEW 0.0000005550 0.60 -14.4043 -0.5108 EO NEW 0.0000006711 2.00 -14.2144 0.6931 EO NEW 0.0000006800 1547.50 -14.2011 7.3444 EO NEW 0.0000007182 2.80 -14.1465 1.0296 BD NEW 0.0000007281 1.30 -14.1328 0.2624 EO NEW 0.0000007741 1.85 -14.0715 0.6152 EO NEW 0.0000007760 0.45 -14.0691 -0.7985 BD NEW 0.0000009403 2.25 -13.8770 0.8109 BD NEW 0.0000009766 3.25 -13.8391 1.1787 BD NEW 0.0000010750 3.50 -13.7432 1.2528 BD NEW 0.0000013768 6.45 -13.4957 1.8641 EO NEW 0.0000014189 398.00 -13.4656 5.9865 BD NEW 0.0000017270 4.00 -13.2691 1.3863

B-31Table B-1-1. Bagging data used to develop the correlation equations
----------------------- Equipment Type=VALVE Service=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

BD NEW 0.0000021600 209.00 -13.0454 5.3423 EO NEW 0.0000026370 6.70 -12.8459 1.9021 BD NEW 0.0000026381 18.50 -12.8455 2.9178 EO NEW 0.0000028522 51.20 -12.7674 3.9357 EO NEW 0.0000031653 21.80 -12.6633 3.0819 RE OLD 0.0000032615 2740.82 -12.6333 7.9160 BD NEW 0.0000034734 13.50 -12.5704 2.6027 BD NEW 0.0000034854 486.75 -12.5669 6.1878 BD NEW 0.0000036357 1.40 -12.5247 0.3365 BD NEW 0.0000036487 3.05 -12.5211 1.1151 BD NEW 0.0000038172 0.20 -12.4760 -1.6094 EO NEW 0.0000038185 45.00 -12.4756 3.8067 EO NEW 0.0000045401 21.50 -12.3026 3.0681 BD NEW 0.0000048429 21.50 -12.2380 3.0681 EO NEW 0.0000053288 11.40 -12.1424 2.4336 EO NEW 0.0000054257 1.00 -12.1244 0.0000 BD NEW 0.0000054590 44.90 -12.1182 3.8044 RE OLD 0.0000061236 5194.17 -12.0034 8.5553 EO NEW 0.0000063620 4.80 -11.9652 1.5686 EO NEW 0.0000076923 30.00 -11.7753 3.4012 BD NEW 0.0000079625 195.50 -11.7408 5.2756 BD NEW 0.0000080291 20.85 -11.7324 3.0374 BD NEW 0.0000081895 17.75 -11.7127 2.8764 BD NEW 0.0000087183 0.25 -11.6501 -1.3863 BD NEW 0.0000090393 7.00 -11.6139 1.9459 EO NEW 0.0000096017 0.90 -11.5536 -0.1054 EO NEW 0.0000106063 29.00 -11.4541 3.3673 BD NEW 0.0000114056 2.40 -11.3814 0.8755 EO NEW 0.0000116662 90.00 -11.3588 4.4998 RE OLD 0.0000118300 97.72 -11.3449 4.5821 BD NEW 0.0000123249 21.90 -11.3039 3.0865 BD NEW 0.0000130315 20.00 -11.2481 2.9957 BD NEW 0.0000136318 49.80 -11.2031 3.9080 EO NEW 0.0000138914 39.40 -11.1842 3.6738 RE OLD 0.0000150006 500.63 -11.1074 6.2159 EO NEW 0.0000150217 108.00 -11.1060 4.6821 BD NEW 0.0000150810 32.50 -11.1021 3.4812 BD NEW 0.0000155478 54.50 -11.0716 3.9982 RE OLD 0.0000185551 78.10 -10.8948 4.3580 RE OLD 0.0000191256 191501.42 -10.8645 12.1627 OUTLIER RE OLD 0.0000196624 4878.72 -10.8368 8.4926 BD NEW 0.0000200735 250.00 -10.8161 5.5215 BD NEW 0.0000212478 67.00 -10.7593 4.2047 EO NEW 0.0000226439 44.10 -10.6956 3.7865

B-32Table B-1-1. Bagging data used to develop the correlation equations
----------------------- Equipment Type=VALVE Service=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

EO NEW 0.0000228716 74.80 -10.6856 4.3148 EO NEW 0.0000242425 2.40 -10.6274 0.8755 BD NEW 0.0000244394 35.50 -10.6193 3.5695 RE OLD 0.0000269514 5443.31 -10.5215 8.6021 BD NEW 0.0000298536 298.90 -10.4192 5.7001 EO NEW 0.0000301615 148.00 -10.4089 4.9972 EO NEW 0.0000330901 59.25 -10.3163 4.0818 BD NEW 0.0000336994 92.50 -10.2980 4.5272 BD NEW 0.0000354699 28.50 -10.2468 3.3499 RE OLD 0.0000378083 604.46 -10.1830 6.4043 EO NEW 0.0000382742 657.80 -10.1707 6.4889 EO NEW 0.0000383797 243.60 -10.1680 5.4955 RE OLD 0.0000387557 242.12 -10.1582 5.4894 EO NEW 0.0000387574 48.90 -10.1582 3.8898 BD NEW 0.0000407202 29.00 -10.1088 3.3673 BD NEW 0.0000415953 1349.80 -10.0875 7.2077 RE OLD 0.0000417925 42609.46 -10.0828 10.6598 BD NEW 0.0000429883 248.00 -10.0546 5.5134 BD NEW 0.0000443510 99.00 -10.0234 4.5951 BD NEW 0.0000462778 1.75 -9.9808 0.5596 RE OLD 0.0000470621 906.10 -9.9640 6.8091 RE OLD 0.0000482670 10833.21 -9.9388 9.2904 EO NEW 0.0000508340 79.00 -9.8869 4.3694 RE OLD 0.0000529921 890.55 -9.8454 6.7918 RE OLD 0.0000546755 1193.53 -9.8141 7.0847 EO NEW 0.0000561055 348.00 -9.7883 5.8522 EO NEW 0.0000569507 60.00 -9.7733 4.0943 EO NEW 0.0000626293 163.70 -9.6783 5.0980 RE OLD 0.0000626636 1985.67 -9.6777 7.5937 RE OLD 0.0000654535 318.60 -9.6342 5.7639 RE OLD 0.0000660567 5226.31 -9.6250 8.5615 RE OLD 0.0000664281 4914.24 -9.6194 8.4999 EO NEW 0.0000713497 343.00 -9.5479 5.8377 RE OLD 0.0000749810 1458.90 -9.4983 7.2854 EO NEW 0.0000778658 148.50 -9.4605 5.0006 BD NEW 0.0000893438 350.00 -9.3230 5.8579 BD NEW 0.0000936958 199.75 -9.2755 5.2971 BD NEW 0.0001029548 872.75 -9.1812 6.7716 EO NEW 0.0001063538 148.75 -9.1487 5.0023 BD NEW 0.0001147397 499.50 -9.0728 6.2136 RE OLD 0.0001266782 1183.21 -8.9739 7.0760 BD NEW 0.0001377292 73.00 -8.8902 4.2905 BD NEW 0.0001972580 174.75 -8.5310 5.1634 RE OLD 0.0002313295 50044.57 -8.3717 10.8207

B-33Table B-1-1. Bagging data used to develop the correlation equations
----------------------- Equipment Type=VALVE Service=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

BD NEW 0.0002317965 180.00 -8.3697 5.1930 RE OLD 0.0002524777 12405.49 -8.2842 9.4259 RE OLD 0.0002580228 44328.29 -8.2625 10.6994 RE OLD 0.0002594664 510.60 -8.2569 6.2356 RE OLD 0.0002714139 185.88 -8.2119 5.2251 RE OLD 0.0002825941 6976.92 -8.1715 8.8504 RE OLD 0.0002947841 1516.43 -8.1293 7.3241 RE OLD 0.0003011106 44592.42 -8.1080 10.7053 RE OLD 0.0003056054 181.92 -8.0932 5.2036 RE OLD 0.0003367527 88.38 -7.9962 4.4816 RE OLD 0.0003494725 1041.01 -7.9591 6.9479 RE OLD 0.0003655199 17367.57 -7.9142 9.7624 RE OLD 0.0003726697 856.19 -7.8948 6.7525 RE OLD 0.0003738730 8088.28 -7.8916 8.9982 RE OLD 0.0003743390 1959.19 -7.8903 7.5803 RE OLD 0.0003964414 4048.28 -7.8330 8.3060 RE OLD 0.0004653107 35414.65 -7.6728 10.4749 BD NEW 0.0004698821 1543.75 -7.6630 7.3420 RE OLD 0.0004809845 4284.78 -7.6397 8.3628 RE OLD 0.0004922594 104088.32 -7.6165 11.5530 BD NEW 0.0005246367 2645.50 -7.5528 7.8806 RE OLD 0.0005251847 1151.37 -7.5518 7.0487 RE OLD 0.0005308943 14765.02 -7.5409 9.6000 RE OLD 0.0005614771 97.30 -7.4849 4.5778 BD NEW 0.0005705547 358.30 -7.4689 5.8814 RE OLD 0.0006267770 1565.55 -7.3749 7.3560 RE OLD 0.0006426108 5861.53 -7.3500 8.6762 RE OLD 0.0006597100 1793.09 -7.3237 7.4917 BD NEW 0.0006830173 94.75 -7.2890 4.5512 RE OLD 0.0007019466 8827.10 -7.2617 9.0856 RE OLD 0.0007129023 9940.79 -7.2462 9.2044 RE OLD 0.0007649183 25559.24 -7.1757 10.1488 RE OLD 0.0007702967 14.18 -7.1687 2.6518 RE OLD 0.0008350761 1281.36 -7.0880 7.1557 BD NEW 0.0008369235 6097.00 -7.0858 8.7156 RE OLD 0.0008536995 2810.09 -7.0659 7.9410 RE OLD 0.0008577230 6709.07 -7.0612 8.8112 RE OLD 0.0009616788 46673.57 -6.9468 10.7509 RE OLD 0.0010351161 71798.27 -6.8732 11.1816 RE OLD 0.0010736310 3136.03 -6.8367 8.0507 RE OLD 0.0012337497 8519.07 -6.6977 9.0501 RE OLD 0.0012793343 16658.85 -6.6614 9.7207 RE OLD 0.0013448227 962.89 -6.6115 6.8699 RE OLD 0.0013933013 1602.40 -6.5761 7.3793

B-34Table B-1-1. Bagging data used to develop the correlation equations
----------------------- Equipment Type=VALVE Service=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

RE OLD 0.0014732045 22177.98 -6.5203 10.0069 RE OLD 0.0016009142 22172.87 -6.4372 10.0066 RE OLD 0.0018373887 1769.15 -6.2994 7.4783 RE OLD 0.0018697565 25877.90 -6.2819 10.1611 RE OLD 0.0021076721 93629.13 -6.1622 11.4471 RE OLD 0.0022196068 4376.80 -6.1104 8.3841 BD NEW 0.0023716142 1495.00 -6.0442 7.3099 RE OLD 0.0026041383 1313.08 -5.9507 7.1801 RE OLD 0.0026564280 52084.68 -5.9308 10.8606 RE OLD 0.0030068935 45068.90 -5.8068 10.7159 RE OLD 0.0030297587 6771.42 -5.7993 8.8205 RE OLD 0.0032025436 9836.80 -5.7438 9.1939 RE OLD 0.0032489277 140865.29 -5.7294 11.8556 RE OLD 0.0032868739 134149.17 -5.7178 11.8067 RE OLD 0.0034814651 284948.25 -5.6603 12.5601 RE OLD 0.0034830527 59618.63 -5.6598 10.9957 RE OLD 0.0035502018 4839.96 -5.6408 8.4847 RE OLD 0.0036059944 5555.74 -5.6252 8.6226 RE OLD 0.0037109239 72002.57 -5.5965 11.1845 RE OLD 0.0037115648 24755.46 -5.5963 10.1168 RE OLD 0.0038957946 9810.65 -5.5479 9.1912 BD NEW 0.0038969686 1544.40 -5.5476 7.3424 RE OLD 0.0039248950 7476.44 -5.5404 8.9195 RE OLD 0.0040089261 13953.59 -5.5192 9.5435 RE OLD 0.0042596218 30597.64 -5.4586 10.3287 RE OLD 0.0043498677 2026.05 -5.4376 7.6138 RE OLD 0.0043951332 4587.13 -5.4273 8.4310 RE OLD 0.0046094493 73036.68 -5.3796 11.1987 RE OLD 0.0046247477 2875.27 -5.3763 7.9639 RE OLD 0.0046555934 3279.62 -5.3697 8.0955 RE OLD 0.0047542941 5891.43 -5.3487 8.6813 RE OLD 0.0049436538 2135.71 -5.3097 7.6666 RE OLD 0.0049687260 9436.54 -5.3046 9.1523 RE OLD 0.0055770694 80485.19 -5.1891 11.2958 RE OLD 0.0059962681 19368.05 -5.1166 9.8714 RE OLD 0.0066867186 28552.82 -5.0076 10.2595 RE OLD 0.0073478291 129657.01 -4.9134 11.7726 RE OLD 0.0076182294 194.63 -4.8772 5.2711 RE OLD 0.0078722531 3118.82 -4.8444 8.0452 BD NEW 0.0079621021 9500.00 -4.8331 9.1590 RE OLD 0.0095095298 2553.37 -4.6555 7.8452 RE OLD 0.0102176741 44254.56 -4.5836 10.6977 RE OLD 0.0105761365 20652.95 -4.5492 9.9356 RE OLD 0.0126755860 960160.86 -4.3681 13.7749

B-35Table B-1-1. Bagging data used to develop the correlation equations
----------------------- Equipment Type=VALVE Service=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Data Emission Screening Rate Value Outlier Type Origin Rate (kg/hr) Value (ppmv) (kg/hr) (ppmv) Flag

RE OLD 0.0128994159 301945.80 -4.3506 12.6180 RE OLD 0.0134752877 28558.21 -4.3069 10.2597 RE OLD 0.0137156706 114.30 -4.2892 4.7388 RE OLD 0.0190054451 1649.34 -3.9630 7.4081 RE OLD 0.0194889771 518201.90 -3.9379 13.1581 RE OLD 0.0220373843 213772.09 -3.8150 12.2727 RE OLD 0.0220386022 7980.81 -3.8150 8.9848 RE OLD 0.0221003955 362645.26 -3.8122 12.8012 RE OLD 0.0248459751 9843.83 -3.6951 9.1946 RE OLD 0.0254155227 41862.00 -3.6724 10.6421 RE OLD 0.0263386824 659517.01 -3.6367 13.3993 RE OLD 0.0272779071 1399.25 -3.6017 7.2437 RE OLD 0.0283621432 288.41 -3.5627 5.6644 RE OLD 0.0283930499 352.85 -3.5616 5.8660 RE OLD 0.0293848208 480.98 -3.5273 6.1758 RE OLD 0.0303470196 562236.45 -3.4951 13.2397 RE OLD 0.0305360632 21853.55 -3.4888 9.9921 RE OLD 0.0372725448 122666.22 -3.2895 11.7172 RE OLD 0.0410821388 62573.58 -3.1922 11.0441 RE OLD 0.0468639667 393961.70 -3.0605 12.8840 RE OLD 0.0687821973 49473.43 -2.6768 10.8092 RE OLD 0.0713743302 36751.32 -2.6398 10.5119 RE OLD 0.0838252864 360547.09 -2.4790 12.7954 RE OLD 0.1027415340 53569.80 -2.2755 10.8887 RE OLD 0.2448798474 371111.15 -1.4070 12.8243
N = 233 (1 outliers)

B-36Table B-1-2. Comparison of regression results for the old, new, and combined bagging data sets.
Equipment Type/Service: Connectors/All
Data Used in Regression

Statistical Parameter New
Number of data pairs 107 Regression intercept -14.815 Regression slope 0.885 Regression R 2 0.525 Regression correlation coefficient 0.725 Regression mean square error 4.355 Regression root mean square error 2.087 Average ln screening value 3.472 Sum of squares of ln screening values 646.821 Scale bias correction factor 8.298 Correlation equation constant 3.05E-6

Equipment Type/Service: Pumps/Light Liquid
Data Used in Regression

Statistical Parameter Old a New Combined
Number of data pairs 51 68 117 Regression intercept -12.827 -12.515 -12.142 Regression slope 0.865 0.907 0.824 Regression R 2 0.613 0.644 0.710 Regression correlation coefficient 0.783 0.803 0.842 Regression mean square error 2.246 3.783 2.591 Regression root mean square error 1.499 1.945 1.610 Average ln screening value 8.582 5.393 6.783 Sum of squares of ln screening values 233.223 548.793 1071.500 Scale bias correction factor 2.941 6.149 3.563 Correlation equation constant 7.91E-6 2.26E-5 1.90E-5
a Indicates that the parameter were derived from the digitized data pairs for the OLD regression.

B-37Table B-1-2. (continued)

Equipment Type/Service: Valves/Gas
Data Used in Regression

Statistical Parameter Old a New Combined
Number of data pairs 95 84 179 Regression intercept -12.848 -14.936 -15.033 Regression slope 0.661 0.750 0.873 Regression R 2 0.359 0.516 0.715 Regression correlation coefficient 0.599 0.711 0.846 Regression mean square error 2.767 4.392 3.745 Regression root mean square error 1.663 2.096 1.935 Average ln screening value 8.823 3.691 6.415 Sum of squares of ln screening values 329.550 682.442 2186.020 Scale bias correction factor 3.858 8.311 6.315 Correlation equation constant 1.02E-5 2.71E-6 1.87E-6

a Indicates that the parameter were derived from the digitized data pairs for the OLD regression.

Equipment Type/Service: Valves/Light Liquid
Data Used in Regression

Statistical Parameter Old a New Combined
Number of data pairs 126 107 232 Regression intercept -10.585 -14.137 -13.975 Regression slope 0.452 0.721 0.797 Regression R 2 0.194 0.502 0.677 Regression correlation coefficient 0.441 0.709 0.823 Regression mean square error 4.413 3.115 4.088 Regression root mean square error 2.101 1.765 2.022 Average ln screening value 8.978 3.300 6.345 Sum of squares of ln screening values 644.683 633.647 3110.310 Scale bias correction factor 8.608 4.580 7.520 Correlation equation constant 2.18E-4 3.32E-6 6.41E-6

a indicates that the parameter were derived from the digitized data pairs for the OLD regression

B-38APPENDIX B: ATTACHMENT 2

This attachment lists the data used to develop the default-zero emission leak rates in table B-2-1. Table B-2-2 lists summary information on the default-zero development.

B-39Table B-2-1. Data used for default zero calculations.
------------Equipment Type=CONNECTORS Service=ALL------- Natural Log Mass of Mass Screening Emission Emission PLT_TYPE Value (ppmv) Rate (kg/hr) Rate (kg/hr

EO 0.00 0.0000000475 -16.86331619 EO 0.00 0.0000000608 -16.61499543 EO 0.00 0.0000000613 -16.60715372 EO 0.00 0.0000000790 -16.35377339 EO 0.00 0.0000000988 -16.13056673 EO 0.00 0.0000001027 -16.09179287 BD 0.00 0.0000001033 -16.08517422 BD 0.00 0.0000001037 -16.08139097 EO 0.00 0.0000001065 -16.05508510 EO 0.00 0.0000001079 -16.04208307 EO 0.00 0.0000001085 -16.03689892 EO 0.00 0.0000001089 -16.03320436 EO 0.00 0.0000001112 -16.01231281 EO 0.00 0.0000001113 -16.01113856 EO 0.00 0.0000001115 -16.00911113 EO 0.00 0.0000001120 -16.00437388 EO 0.00 0.0000001125 -16.00075170 EO 0.00 0.0000001133 -15.99300732 EO 0.00 0.0000001146 -15.98221965 EO 0.00 0.0000001146 -15.98146212 EO 0.00 0.0000001150 -15.97834935 EO 0.00 0.0000001166 -15.96444127 EO 0.00 0.0000001176 -15.95559511 EO 0.00 0.0000001177 -15.95545662 EO 0.00 0.0000001178 -15.95391595 EO 0.00 0.0000001181 -15.95192362 EO 0.00 0.0000001189 -15.94478891 EO 0.00 0.0000001213 -15.92488652 EO 0.00 0.0000001234 -15.90745448 EO 0.00 0.0000001240 -15.90308275 EO 0.00 0.0000001296 -15.85882804 EO 0.00 0.0000001320 -15.84081663 BD 0.00 0.0000001349 -15.81855266 EO 0.00 0.0000001376 -15.79862472 EO 0.00 0.0000001390 -15.78899513 BD 0.00 0.0000001412 -15.77318199 EO 0.00 0.0000001413 -15.77244897 BD 0.00 0.0000001440 -15.75326730 BD 0.00 0.0000001446 -15.74929429 BD 0.00 0.0000001448 -15.74817023 BD 0.00 0.0000001454 -15.74382504 BD 0.00 0.0000001455 -15.74329360 BD 0.00 0.0000001485 -15.72271562 BD 0.00 0.0000001490 -15.71949421 BD 0.00 0.0000001497 -15.71483698 BD 0.00 0.0000001505 -15.70909501

B-40Table B-2-1. Data used for default zero calculations.
-------- Equipment Type=CONNECTORS Service=ALL --------- (continued) Natural Log Mass of Mass Screening Emission Emission PLT_TYPE Value (ppmv) Rate (kg/hr) Rate (kg/hr

EO 0.00 0.0000001511 -15.70514515 EO 0.00 0.0000001544 -15.68403336 BD 0.00 0.0000001547 -15.68204363 EO 0.00 0.0000001563 -15.67144879 BD 0.00 0.0000001573 -15.66508859 BD 0.00 0.0000001574 -15.66465227 BD 0.00 0.0000001596 -15.65073157 BD 0.00 0.0000001614 -15.63962500 BD 0.00 0.0000001621 -15.63500235 BD 0.00 0.0000001625 -15.63229582 EO 0.00 0.0000001631 -15.62914831 EO 0.00 0.0000001636 -15.62557049 EO 0.00 0.0000001641 -15.62273582 EO 0.00 0.0000001642 -15.62198449 EO 0.00 0.0000001648 -15.61837621 EO 0.00 0.0000001648 -15.61837621 EO 0.00 0.0000001650 -15.61705986 EO 0.00 0.0000001650 -15.61705962 EO 0.00 0.0000001651 -15.61656953 EO 0.00 0.0000001657 -15.61295101 EO 0.00 0.0000001657 -15.61295101 EO 0.00 0.0000001660 -15.61112981 EO 0.00 0.0000001688 -15.59463081 EO 0.00 0.0000001692 -15.59241662 EO 0.00 0.0000001717 -15.57752890 BD 0.00 0.0000001741 -15.56347827 BD 0.00 0.0000001747 -15.56001908 EO 0.00 0.0000001750 -15.55828552 EO 0.00 0.0000001807 -15.52620814 EO 0.00 0.0000001812 -15.52341721 BD 0.00 0.0000001904 -15.47417798 BD 0.00 0.0000001920 -15.46559058 BD 0.00 0.0000001932 -15.45958528 EO 0.00 0.0000001990 -15.43018880 EO 0.00 0.0000002086 -15.38283699 EO 0.00 0.0000002194 -15.33220908 EO 0.00 0.0000002431 -15.22964242 EO 0.00 0.0000002476 -15.21159451 EO 0.00 0.0000002508 -15.19874994 EO 0.00 0.0000002570 -15.17423032 BD 0.00 0.0000002585 -15.16823490 EO 0.00 0.0000002593 -15.16532554 BD 0.00 0.0000002594 -15.16500428 EO 0.00 0.0000002602 -15.16174131 EO 0.00 0.0000002607 -15.15994436

B-41Table B-2-1. Data used for default zero calculations.
-------- Equipment Type=CONNECTORS Service=ALL --------- (continued) Natural Log Mass of Mass Screening Emission Emission PLT_TYPE Value (ppmv) Rate (kg/hr) Rate (kg/hr

EO 0.00 0.0000002626 -15.15272411 EO 0.00 0.0000002626 -15.15272411 EO 0.00 0.0000002659 -15.13996186 EO 0.00 0.0000002664 -15.13812531 BD 0.00 0.0000002959 -15.03330632 EO 0.00 0.0000003055 -15.00115460 BD 0.00 0.0000003140 -14.97386313 EO 0.00 0.0000003276 -14.93133352 BD 0.00 0.0000003303 -14.92340849 BD 0.00 0.0000003315 -14.91955531 BD 0.00 0.0000003346 -14.91035517 BD 0.00 0.0000003436 -14.88372774 BD 0.00 0.0000003436 -14.88368692 BD 0.00 0.0000003442 -14.88192105 BD 0.00 0.0000003461 -14.87648133 BD 0.00 0.0000003504 -14.86410580 BD 0.00 0.0000003672 -14.81747447 BD 0.00 0.0000003946 -14.74527193 BD 0.00 0.0000004121 -14.70207785 EO 0.00 0.0000004133 -14.69904106 BD 0.00 0.0000004212 -14.68010001 EO 0.00 0.0000004468 -14.62113094 BD 0.00 0.0000004720 -14.56621062 EO 0.00 0.0000005089 -14.49108397 EO 0.00 0.0000005180 -14.47320006 EO 0.00 0.0000005187 -14.47197698 EO 0.00 0.0000005908 -14.34186784 EO 0.00 0.0000006166 -14.29899587 BD 0.00 0.0000006960 -14.17794549 EO 0.00 0.0000007110 -14.15652787 EO 0.00 0.0000007192 -14.14510177 EO 0.00 0.0000008267 -14.00581175 EO 0.00 0.0000009572 -13.85929011 EO 0.00 0.0000010002 -13.81535039 BD 0.00 0.0000010065 -13.80901606 EO 0.00 0.0000010071 -13.80841513 EO 0.00 0.0000011795 -13.65045667 EO 0.00 0.0000011927 -13.63931593 EO 0.00 0.0000021315 -13.05868377 BD 0.00 0.0000023492 -12.96141917 EO 0.00 0.0000024557 -12.91711588 BD 0.00 0.0000024895 -12.90342759 BD 0.00 0.0000025620 -12.87473675 BD 0.00 0.0000030901 -12.68731235 BD 0.00 0.0000033269 -12.61346713

B-42Table B-2-1. Data used for default zero calculations.
--------- Equipment Type=CONNECTORS Service=ALL -------- (continued) Natural Log Mass of Mass Screening Emission Emission PLT_TYPE Value (ppmv) Rate (kg/hr) Rate (kg/hr

BD 0.00 0.0000037589 -12.49138454 BD 0.00 0.0000040185 -12.42460572 BD 0.00 0.0000042414 -12.37062573 BD 0.00 0.0000044626 -12.31978282 BD 0.00 0.0000066833 -11.91589131 BD 0.00 0.0000075709 -11.79119727 BD 0.00 0.0000105577 -11.45865639 BD 0.00 0.0000144776 -11.14290744 BD 0.00 0.0000154005 -11.08111125 BD 0.00 0.0000165494 -11.00916328

N = 146
------------------- Equipment Type=PUMP Service=LL

------------------- Natural Log Mass of Mass Screening Emission Emission PLT_TYPE Value (ppmv) Rate (kg/hr) Rate (kg/hr

EO 0.00 0.0000002532 -15.18920187 EO 0.00 0.0000002674 -15.13444207 BD 0.00 0.0000003397 -14.89520337 BD 0.00 0.0000006493 -14.24738145 BD 0.00 0.0000013801 -13.49334976 BD 0.00 0.0000031715 -12.66130995 EO 0.00 0.0000061497 -11.99910617 BD 0.00 0.0000978267 -9.232313175

N=8

B-43Table B-2-1. Data used for default zero calculations.
----------- Equipment Type=VALVE Service=G -------------
Natural Log Mass of Mass Screening Emission Emission PLT_TYPE Value (ppmv) Rate (kg/hr) Rate (kg/hr

EO 0.00 0.0000000591 -16.64400086 EO 0.00 0.0000000722 -16.44327301 EO 0.00 0.0000000737 -16.42283692 EO 0.00 0.0000000786 -16.35920326 EO 0.00 0.0000000790 -16.35376554 EO 0.00 0.0000000796 -16.34647953 EO 0.00 0.0000001079 -16.04237697 EO 0.00 0.0000001081 -16.04053084 EO 0.00 0.0000001083 -16.03863245 EO 0.00 0.0000001312 -15.84631356 EO 0.00 0.0000001321 -15.83996505 EO 0.00 0.0000001325 -15.83639998 BD 0.00 0.0000001382 -15.79429751 BD 0.00 0.0000001436 -15.75651804 EO 0.00 0.0000001446 -15.74956966 BD 0.00 0.0000001516 -15.70207714 EO 0.00 0.0000001581 -15.65972752 BD 0.00 0.0000001595 -15.65122577 BD 0.00 0.0000001602 -15.64710329 EO 0.00 0.0000001750 -15.55828552 EO 0.00 0.0000002350 -15.26347692 BD 0.00 0.0000002539 -15.18638489 EO 0.00 0.0000002612 -15.15814418 BD 0.00 0.0000002633 -15.14979281 EO 0.00 0.0000002674 -15.13444207 BD 0.00 0.0000003272 -14.93266093 BD 0.00 0.0000003339 -14.91228255 EO 0.00 0.0000003878 -14.76283680 EO 0.00 0.0000004091 -14.70928502 BD 0.00 0.0000004607 -14.59056027 EO 0.00 0.0000006457 -14.25286952 BD 0.00 0.0000007014 -14.17014032 EO 0.00 0.0000009932 -13.82235860 BD 0.00 0.0000009955 -13.81999480 BD 0.00 0.0000022122 -13.02153380 BD 0.00 0.0000022562 -13.00184573 BD 0.00 0.0000025712 -12.87114036 BD 0.00 0.0000033699 -12.60062417 BD 0.00 0.0000044219 -12.32894306 BD 0.00 0.0000106176 -11.45299698

N = 40

B-44Table B-2-1. Data used for default zero calculations.
---------- Equipment Type=VALVE Service=LL ------------- Natural Log Mass of Mass Screening Emission Emission PLT_TYPE Value (ppmv) Rate (kg/hr) Rate (kg/hr

EO 0.00 0.0000001121 -16.00352165 EO 0.00 0.0000001173 -15.95857877 EO 0.00 0.0000001211 -15.92634574 EO 0.00 0.0000001229 -15.91229458 EO 0.00 0.0000001337 -15.82756192 BD 0.00 0.0000001440 -15.75311308 BD 0.00 0.0000001461 -15.73913742 BD 0.00 0.0000001498 -15.71376221 BD 0.00 0.0000001503 -15.71042334 BD 0.00 0.0000001513 -15.70424314 EO 0.00 0.0000001642 -15.62246991 EO 0.00 0.0000001644 -15.62066973 EO 0.00 0.0000001644 -15.62066973 EO 0.00 0.0000001645 -15.62017964 EO 0.00 0.0000001648 -15.61837621 EO 0.00 0.0000001654 -15.61475957 EO 0.00 0.0000001656 -15.61343643 EO 0.00 0.0000001657 -15.61294634 EO 0.00 0.0000001660 -15.61112981 EO 0.00 0.0000001663 -15.60930997 BD 0.00 0.0000001669 -15.60596798 EO 0.00 0.0000001758 -15.55382679 EO 0.00 0.0000001758 -15.55382679 BD 0.00 0.0000001780 -15.54144504 BD 0.00 0.0000001804 -15.52802656 EO 0.00 0.0000001827 -15.51543605 BD 0.00 0.0000001853 -15.50155175 EO 0.00 0.0000002507 -15.19885548 EO 0.00 0.0000002568 -15.17511567 EO 0.00 0.0000002623 -15.15362868 EO 0.00 0.0000002645 -15.14545135 EO 0.00 0.0000002654 -15.14208066 EO 0.00 0.0000002657 -15.14094135 EO 0.00 0.0000002664 -15.13812531 EO 0.00 0.0000002750 -15.10635430 BD 0.00 0.0000002786 -15.09348218 BD 0.00 0.0000002807 -15.08603323 BD 0.00 0.0000002831 -15.07737541 BD 0.00 0.0000003292 -14.92670035 BD 0.00 0.0000003296 -14.92525863 BD 0.00 0.0000003327 -14.91592554 EO 0.00 0.0000003803 -14.78222371 EO 0.00 0.0000003997 -14.73266021 EO 0.00 0.0000004350 -14.64784669 EO 0.00 0.0000004933 -14.52205744 BD 0.00 0.0000005121 -14.48467228

B-45Table B-2-1. Data used for default zero calculations.
------------ Equipment Type=VALVE Service=LL ------------ (continued) Natural Log Mass of Mass Screening Emission Emission PLT_TYPE Value (ppmv) Rate (kg/hr) Rate (kg/hr

EO 0.00 0.0000007099 -14.15820731 BD 0.00 0.0000011219 -13.70046348 BD 0.00 0.0000022380 -13.00992148 EO 0.00 0.0000028444 -12.77016392 BD 0.00 0.0000041389 -12.39507152 BD 0.00 0.0000053490 -12.13860411 EO 0.00 0.0000121637 -11.31705756

N = 53

B-46Table B-2-2. Comparison of Default Zero Mass Emission Rates from the Original EPA Protocol and from the CMA/EPA EO/BD StudyResults from CMA/EPA EO/BD Bagging Data StudyOldRevisedDefault ZeroDefault ZeroScale Bias Default Zero Lower 95% Upper 95% ScreeningEquipmentEmission Rate Number of Correction Emission Rate Confidence Confidence ValueaType Service (kg/hr) Observations Factor (kg/hr) Limit Limit (ppmv)CONNEC ALL 9.34E-51462.066.12E-75.02E-7 7.45E-7 0.163PUMP LL 3.91E-584.737.49E-61.36E-6 4.11E-5 0.323VALVE G 3.31E-5402.196.56E-74.35E-7 9.87E-7 0.301VALVE LL 4.52E-4531.654.85E-73.67E-7 6.42E-7 0.039aThe "default zero" screening value is the screening value that would result in emissions equal tothe default zero mass emission rate when entered into the applicable correlation. The revised SOCMI correlationswere used to estimate the "default zero" screening values.

B-47APPENDIX B: ATTACHMENT 3 This attachment summarizes information on each of the screening data sets. Table B-3-1 summarizes data used to revise the SOCMI emission factors. Figures B-3-1 through B-3-4 plot the screening value distributions for each data set.

B-48Figure B-3-1. Distribution of Connectors Screening Values for SOCMI

B-49Figure B-3-2. Distribution of Light Liquid Pumps Screening Values for SOCMI

B-50Figure B-3-3. Distributio of Gas Valves Screening Values for SOCMI

B-51Figure B-3-4. Distribution of Light Liquid Valves Screening Values for SOCMI

B-52Table B-3-1. Emission Factors Calculated From Revised SOCMI Correlation Equations.

Average Default Old Total nonzero Number of zero Average emission number of emission zero emission emission Screening Equipment factor screening rate screening rate factor data set type Phase (kg/hr) values (kg/hr) values (kg/hr) (kg/hr)

24 UNIT CONNEC ALL 8.30E-04 4,283 2.50E-02 3,740 6.12E-07 3.16E-03
24 UNIT PUMP LL 4.94E-02 646 5.36E-02 335 7.45E-06 2.58E-02 24 UNIT VALVE G 5.60E-03 9,669 2.47E-02 5,962 6.56E-07 9.45E-03 24 UNIT VALVE LL 7.10E-03 18,300 2.99E-02 14,292 4.85E-07 6.55E-03 EO/BD CONNEC ALL 8.30E-04 3,562 3.76E-04 1,381 6.12E-07 2.30E-04 EO/BD PUMP LL 4.94E-02 252 7.12E-03 85 7.45E-06 4.72E-03 EO/BD VALVE G 5.60E-03 6,507 2.83E-03 4,685 6.56E-07 7.92E-04 EO/BD VALVE LL 7.10E-03 15,810 3.26E-03 10,429 4.85E-07 1.11E-03 COMBINED CONNEC ALL 8.30E-04 7,845 5.28E-03 5,121 6.12E-07 1.83E-03 a

COMBINED PUMP LL 4.94E-02 898 3.73E-02 420 7.45E-06 1.99E-02 a
COMBINED VALVE G 5.60E-03 16,176 1.75E-02 10,647 6.56E-07 5.97E-03 a
COMBINED VALVE LL 7.10E-03 34,110 1.46E-02 24,721 4.85E-07 4.03E-03 a

a These average emission factors are the revised SOCMI average emission factors.

B-53APPENDIX C:

Revision of Petroleum Industry Correlations and Emisison FactorsAPPENDIX C The purpose of this appendix is to provide background information on the data collection and analysis performed to revise the petroleum industry (refineries, marketing terminals, and oil and gas production operations) correlations and to develop marketing terminal and oil and gas production operation average emission factors. Section C.1 addresses the following: • Comparison of old (1980) and new (1993) refinery data; • Development of revised petroleum industry correlation equations, default zero emission rates, and pegged emission rates; • Summary of petroleum industry correlation parameters; and • Development of marketing terminal and oil and gas production operation average emission factors. The figures for this section appear at the end of section C.1. Several attachments that list all of the data are also included for this appendix. Attachment 1 lists the bagging data used to develop the correlation equations, attachment 2 lists the bagging data used to develop pegged emission rates, attachment 3 lists the bagging data used to develop default zero emission rates, and attachment 4 summarizes the screening data for average emission factors.
C.1 DEVELOPMENT OF REVISED PETROLEUM INDUSTRY CORRELATIONS AND FACTORS During the early-1990’s, new petroleum industry equipment leak data were collected and analyzed. The Western States Petroleum Association (WSPA) and the American Petroleum Institute (API) jointly commissioned the 1994 refinery equipment leak report 1 to evaluate fugitive emissions at petroleum refineries. The API also commissioned the 1993 marketing terminal equipment leak report, 2 and, along with the Gas Research Institute (GRI), jointly commissioned the 1993 oil and gas production operations reports. 3,4 These data are referred to in this discussion as the 1993 petroleum industry data. In contrast to the data collected during the late-1970’s for the 1980 refinery report 5 (these are referred to in this discussion as the 1980 refinery data) which came from uncontrolled facilities and were used to develop correlations and emission factors that appear in previous

C-1versions of this protocol, the 1993 petroleum industry data came from controlled facilities and were collected using current procedures that are considered state of the art for the 1990’s. The purpose of this section is to explain how and why the 1993 data were used to update the petroleum industry correlations and to present the data that were used in this update. The conclusions presented in this section were based on a combination of engineering judgement and quantitative statistical analysis of the available emission data. Judgments were made based on an understanding of possible mechanisms of equipment leak emissions and qualitative assessment of the data. A more detailed explanation of the analyses highlighted in this section appear in a technical memorandum 6 that is available on EPA’s electronic bulletin board. 7 C.1.1 Overview of Data Analysis Based on guidelines presented in chapter 4 of this document, the quality control/quality assurance (QC/QA) procedures for data collection and laboratory analysis of the 1993 petroleum industry data were evaluated and found to be of sufficient quality for the development of correlations. However, a few data pairs were excluded from correlation development due to large background concentrations or high screening value variability. Several options were considered for using the 1993 petroleum industry equipment leak data, including:

• Combine the 1980 refinery data and the 1993 refinery data to develop revised refinery correlations and, based on 1993 data, provide separate new correlations for marketing terminals and oil and gas production operations.
• Combine the 1980 refinery data with the 1993 refinery, marketing terminal, and oil and gas production data to develop new petroleum industry correlations that apply to all three industry segments.
• Drop the 1980 data and correlations from further use. Combine the 1993 refinery, marketing terminal, and oil and gas production operations data to develop a single correlation that applies to all three industry segments or keep the three industry segment correlations separate.

C-2Judgments based upon an understanding of equipment leak emission mechanisms and a qualitative assessment of the data were used in conjunction with the following visual comparisons and statistical tests, that quantitatively evaluate the similarities or differences between the data being compared, to assess the options listed above:

• Visual comparison of the plotted data, regression lines, and 95 percent confidence intervals for the regression lines, to identify general characteristics of the data and to put the results of statistical tests into perspective.
• F-test for the mean square error (MSE) differences between the regression equations, to compare the variability of the errors of the predictions.
• T-tests for intercept (b 0 ) and slope (b 1 ) differences between the regression equations, to determine whether the regressions were statistically different. If the t-test for the intercepts indicated similarities, but the t-test for the slopes indicated differences or vice versa, the regressions were considered statistically different. However, when both the intercept and slope t-tests indicated similarities, the regressions were considered statistically the same.
• Mass verification analysis. Because of the statistical requirement for normality of the data distributions for the above tests to be valid, the visual and statistical tests were evaluated in log-log space (i.e., the mathematical space that results when regressing the natural logarithm of the mass emission rate against the natural logarithm of the screening value). The mass verification analysis was conducted to assess the impact of the correlations on the nontransformed data. The total measured mass was compared to the total mass predicted from each of the industry segment correlations and from the combined correlations. Mass ratios (the ratio of the total predicted mass to the total measured mass) formed the basis for evaluating the results. The mass verification was considered good when mass ratio was close to 1.0, indicating that the predicted mass was close to the measured mass (a mass ratio of 1.0 indicates a perfect prediction because the predicted mass equals the measured mass).

C-3C.1.2 Comparison of the 1993 Refinery Data with the 1980 Refinery Data
The 1980 refinery data were collected and analyzed in the laboratory using procedures that were not as stringent as the current procedures. Thus, the 1993 refinery data are of better quality than the 1980 data, as evaluated by today’s standards. Also, the 1980 data were screened with a TLV calibrated with hexane and the 1993 refinery data were screened with an OVA calibrated with methane. Thus, any comparisons between the two datasets must be made on a common basis. The conversion from TLV to OVA is not totally clear or understood. Multiple conversion equations exist and the TLV/OVA relationship changes at different screening levels. Also, the TLV and OVA use different methods to obtain measurements that give different results for the same data. This difficulty was overcome sufficiently to perform a crude comparison; however no adjustments could be made to compare both datasets on a common basis with regards to data quality. The following relationship (taken from Figure C3-18a) 8 was used to approximate an OVA-methane screening value from a TLV-hexane screening value:
SV OVA-methane = 10 C (C-1)
where:

SV OVA-methane = screening value taken with OVA-methane

C = [log 10 (SV TLV-hexane ) + 0.193]

0.952

SV TLV-hexane = screening value taken with TLV-hexane.

However, this transformation was achieved in the 1993 refinery report 1 using another conversion equation (from the 1979 valve screening report 9 ) that gave results that were different from those obtained using Equation C-1 above, thereby emphasizing the uncertainty that exists for any of the transformations from
TLV to OVA. Additionally, pegged data were identified in the 1980 dataset and removed prior to comparisons with the 1993 refinery

C-4data, because separate emission rates are now calculated for pegged readings. Thus, the 1980 correlations were adjusted for screening instrument (TLV) and pegged data. Using available screening data from 17 marketing terminals as an example, the adjusted 1980 correlations gave estimations of total facility emissions that ranged between 42% to 116% of the total facility emissions obtained from the published 1980 correlations. The adjusted 1980 correlations gave an estimation of the total emissions from all 17 marketing terminals that were 61% of the total emissions estimated from the published 1980 correlations. The comparisons between the 1980 refinery data and the 1993 refinery data were made for matching equipment types/services. The following four equipment types/services were compared: all connectors, light liquid pumps, gas valves, and light liquid valves. Plots that compare the raw data, the regression lines, and the 95 percent confidence intervals of the regression lines for the 1980 and 1993 refinery data were constructed for the four equipment types/services. The plot for all connector data, which illustrates the largest visual differences, is shown in Figure C-1 and the plot for gas valve data, which illustrates the smallest visual differences, is shown in figure c-2. All of the plots revealed a general separation of data pairs and 95 percent confidence intervals of the regression lines, thereby suggesting that there were differences between the 1980 and 1993 refinery
data. The results of the statistical tests (not shown) for differences between the 1980 and 1993 refinery regressions indicated that the regression lines were different because statistically significant differences between the 1980 refinery data and the 1993 refinery data existed for both the slope and intercept for all equipment types/services. Figure C-3 shows the ratios of predicted to measured mass that were calculated from the 1980 refinery data, the 1993 refinery data, and the combined 1980/1993 refinery data (a predicted to measured mass ratio of 1.0 would indicate a perfect prediction). In all cases, either the combined correlation or the 1993 refinery correlation did a

C-5better job of predicting the total mass of the 1980 refinery data than did the 1980 correlation, and the 1993 refinery correlation always gave the best mass ratios for the 1993 refinery data. The ratios of predicted to measured mass using the combined 1980/1993 refinery correlations were further from 1.0 than those obtained individually with either the 1980 or 1993 refinery correlations for the respective datasets, and thus, a rather poor verification of the combined correlation was indicated. Based on the above results, the 1980 refinery data were not used to develop the revised correlations that are presented in this revised version of the protocol. C.1.3 Comparison of the 1993 Refinery Data, the 1993 Marketing Terminal Data, and the 1993 Oil and Gas Production Operations Data
An underlying concern with all of the comparisons discussed in this section was the relatively small sample size for most of the equipment types/services. This problem was also encountered in the 1980 refinery report. 5 Table C-1 shows the sample size for each equipment type/service for the 1993 refinery data, the 1993 marketing terminal data, and the 1993 oil and gas production operations data that were deemed suitable for correlation development. (For comparative purposes, the corresponding sample sizes from the 1980 refinery analysis 5 are footnoted in Table C-1.) The sample size was 30 or larger for only 9 of the 46 equipment types/services for which data were collected. It is recommended in chapter 2 that the sample size should be 30 or larger for the development of correlations. In addition, the sample size was 10 or less for 23 of the 46 equipment types/services. Sample sizes that are this small may produce results of only limited usefulness and meaning. Two-way statistical comparisons were made between the 1993 refinery, marketing terminal, and oil and gas production operations data for equipment types/services where data were collected. All comparisons were service-specific. The following equipment types/services were compared: light liquid connectors, light liquid flanges, light liquid open-ended lines, light liquid

C-6TABLE C-1. SUMMARY OF THE SAMPLE SIZE FOR EACH EQUIPMENT TYPE/SERVICE FOR THE 1993 REFINERY DATA, THE 1993 MARKETING TERMINAL DATA, AND THE 1993 OIL AND GAS PRODUCTION OPERATIONS DATA

Equipment Type Stream Service Sample Size

Total 1993 Refinery Data 1993 Marketing Terminal Data 1993 Oil & Gas Production Operations Data Connector Gas Heavy Liquid Light Liquid 8 2 18 2 0 21 24 1 42 34 3 81 Flange Gas Heavy Liquid Light Liquid 4 1 15 1 0 12 9 1 13 14 2 40

Instrument a Gas Light Liquid 0 0 0 0 2 1 2 1 Loading

Arm a Gas Light Liquid 0 0 7 16 0 0 7 16 Open-Ended Line Gas Heavy Liquid Light Liquid 7 3 15 0 0 16 48 13 39 55 16 70 Other a Gas Light Liquid 0 0 1 3 0 0 1 1 Pressure

Relief Valve a Gas Light Liquid 1 1 0 0 6 3 7 4 Pump Heavy Liquid Light Liquid 11 30 0 11 0 1 11 42 Stuffing Box a Heavy Liquid Light Liquid 0 0 0 0 11 12 11 12 Valve Gas Heavy Liquid Light Liquid 50 22 82 2 0 45 84 1 51 136 23 178 Vent a Gas Light Liquid 0 0 0 0 3 3 3 3
1993 Petroleum Industry Total 270 137 368 775

1980 Refinery Total b 678

a Components with small sample sizes will be grouped together to form an "OTHERS" category. b For comparative purposes, sample sizes from the 1980 refinery report are: all flanges-52; light liquid pumps-259, gas valves-79; light liquid values-119; valves and compressors in hydrogen service-47; all drains-61; and heavy liquid pumps-61.

C-7pumps, gas valves, and light liquid valves. Plots that compare the 1993 refinery, marketing terminal, and oil and gas production operations raw data, regression lines, and 95 percent confidence intervals for the regression lines were constructed for all equipment types/services listed above. The plot for light liquid flange data, which illustrates the largest visual differences, is shown in Figure C-4 and the plot for light liquid valve data, which illustrates the smallest visual differences, is shown in Figure C-5. In general, all of the data plots revealed a general intermingling of data pairs from the three petroleum industry segments and an overlapping of 95 percent confidence intervals of the regression lines. No clear separation of petroleum industry segments was evident in most of the data plots. The results of the statistical tests (not shown) for two-way differences between regressions for the petroleum industry segment datasets indicated statistically significant differences for all of the equipment types/services; however, the visual plots indicated that these differences may be too small to really be relevant, especially when compared to the magnitude of the differences between the 1980 and 1993 refinery data. Figure C-6 presents the ratios of predicted to measured mass that were calculated from the 1993 refinery, marketing terminal, and oil and gas production operations data. The mass ratios from facility type-specific correlations for the predictions that were closest to 1.0 for a given facility type dataset were usually from the correlation based on another facility type. For example, for light liquid valves, the marketing terminal correlation gave a mass ratio of 1.06 for the refinery data, whereas the refinery correlation gave a mass ratio of 1.50 for the refinery data. In several cases, the combined petroleum industry correlation gave an even closer ratio of predicted to measured mass than any of the individual facility type-specific correlations. For example, for light liquid flanges, the combined correlation gave a mass ratio of 0.94 for the marketing

C-8terminal data, which is better than the 1.34 obtained when using the marketing terminal correlation. Overall, the combined 1993 petroleum industry correlations gave mass ratios ranging between 0.10 and 2.85 for facility type-specific datasets. The mass ratios using the combined correlations to predict the total mass of the combined dataset ranged between 0.28 and 1.42 for all equipment types/services. Thus, the ratios of predicted to measured mass obtained from the combined 1993 petroleum industry correlations were closer to 1.0 than those obtained individually with facility type-specific correlations, thus supporting the combination of data from the three petroleum industry segments. It is not surprising that the visual and statistical results showed similarities between the petroleum industry segment datasets because the three industry segments produce similar products of similar molecular weights, viscosities, and densities. Therefore the leak mechanisms and screening instrument response rates are not expected to be different between the industry segments. Although some small differences were identified, there is not compelling evidence to believe that these differences were large enough to be real or meaningful. C.1.4 Development of the Combined Refinery/Marketing Terminal/Oil and Gas Production Pperations Correlations, Default Zero Emission Rates, and Pegged Emission Rates
Based on the results presented in the above section, the 1993 refinery, marketing terminal data, and oil and gas production operations data were combined to develop petroleum industry correlations using the procedures outlined in chapter 2 and appendix B. Due to the small sample size for some equipment types, an "others" category was developed to provide a correlation for cases not otherwise covered. The equipment types flagged in Table C-1 (instruments, loading arms, other, pressure relief valves, stuffing boxes, and vents, compressors, and dump lever arms) were combined to form this "other" equipment type. The visual and statistical tests for differences between regression equations were applied to the combined dataset to aid in the decision of what equipment type(s)/service(s), if any, to

C-9combine for developing the correlations. Visual inspection of the data plots (not shown) revealed that the gas, light liquid, and heavy liquid service data were generally well intermingled. The p-values from the t-tests for b 0 and b 1 differences indicated that the services were statistically similar only for gas/heavy liquid open-ended lines and for gas/light liquid open-ended lines. However, most of the statistically significant differences appeared too small in the visual plots to really be relevant. As with the comparisons between the refinery, marketing terminal, and oil and gas production operations data, the mass verification analysis for the services showed that when differences were identified for the service comparisons, they were small, thereby lending support towards combining the data. Other factors that support combining services include: • The leak mechanism is the same regardless of service. However, screening value distributions, which affect total emissions (not correlations), may be different for each service.
• When services were segregated, sample sizes for nearly all equipment types were less than 30, the sample size recommended in chapter 2 for developing correlations, even after combining all of the petroleum industry segment data. Combination of data from all services increased the sample size to above 30 for nearly all equipment types.
• The importance of the component service was investigated in the 1994 refinery report, 1 using additional statistical tests. The analyses of variance that were presented in the refinery report showed that services should be combined because there were no statistically significant differences between the correlations for different services for a given equipment type.
The visual analysis that was conducted to compare the regression equations for the different equipment types revealed that the raw data for the different equipment types were well intermingled for some equipment types and separated for other types. However, a stacking of regression lines and confidence intervals was evident, such that some equations overlapped (connectors and open-ended lines), but there were rather large differences between other equations (pumps versus connectors). Thus, in contrast to other comparisons, where the differences

C-10were either consistently large (1980 versus 1993 refinery data) or small (1993 petroleum industry segment data), differences between the equipment types varied. Based on the visual results, it was felt that further analysis outside the objectives of this study was necessary to determine which equipment types to combine. Therefore, the equipment types remained segregated. Correlations, default zero emission rates, and pegged emission rates were developed from the combined 1993 refinery, marketing terminal, and oil and gas production operations data for combined services for connectors, flanges, open-ended lines, pumps, valves, and "other" equipment types. Table C-2 shows the regression statistics for correlations. The R 2 values ranged from 0.32 for "others" to 0.54 for valves, thereby indicating that the equations were capable of predicting about half of the variability of the mass emission rates. These R 2 values corresponded to correlation coefficients (r, the square root of

R 2 ) ranging from 0.57 to 0.73. Although these R 2 values were sometimes less than those obtained for individual facility/service types, they were more consistent across equipment types than the R 2 values for the individual facility/service types which ranged from 0.04 to 0.75. These R 2 values revealed the inherent limits of this tool for predicting mass emission rates (an inability to account for 25% to 50% of the mass emission variance) and were not substantially different from those shown in other reports. 1,2,3,5 Table C-3 shows the petroleum industry correlations, default zero emission rates, and pegged emission rates for each equipment type as calculated from the combined 1993 refinery, marketing terminal, and oil and gas production operations data. Emission estimates from the revised correlations depend on the distribution of equipment types and screening values at a given facility. Comparisons of the results obtained from the 1993 correlations and previously published correlations can vary greatly from facility-to-facility. For screening data that contained a large number of low screening values from 17 marketing terminals, the 1993 correlations gave estimations of

C-11TABLE C-2. REGRESSION STATISTICS FOR THE COMBINED 1993 REFINERY, MARKETING TERMINAL,AND OIL AND GAS PRODUCTION OPERATIONS DATAEquipment Type/ServiceNumberof DataPairsIntercept(b0)Slope(b1)Coefficientof SimpleDetermination (R2)StandardError ofEstimateMean lnScreeningValueaSum ofSquaredDifferencesbScale BiasCorrectionFactor(SBCF)Half-Widthof the 95%ConfidenceIntervalcValve/All337-14.1690.7460.541.5446.4771705.073.270.17Connector/All 118 -14.893 0.735 0.47 1.754 6.214 592.09 4.51 0.32Pump/All53 -11.546 0.610 0.46 1.856 5.816 409.21 5.15 0.51Otherd/All70 -12.838 0.589 0.32 1.843 5.437 316.36 5.14 0.44Flange/All56 -13.788 0.703 0.37 1.771 5.767 204.71 4.48 0.47Open-Ended Line/All141-14.6580.7040.441.8236.166745.975.110.30aThe mean ln screening value is the average of all of the ln screening values:X_= (1/n)×Σ(Xi).bThe sum of squared differences refers to the difference between the individual lnscreening values and the average ln screening value:Σ(Xi-X_)2. (The mean lnscreening value and the sum of squared differences are used to calculate confidenceintervals.)cThe half-width of the 95 percent confidence interval is calculated using the mean lnscreening value as the X-value being evaluated in the confidence intervalcalculation.dThe "other" equipment type includes instruments, loading arms, pressure reliefvalves,stuffing boxes, vents, compressors, and dump lever arms.

C-12TABLE C-3. CORRELATION EQUATIONS, DEFAULT ZERO EMISSION RATES, AND PEGGED EMISSIONRATES FOR PREDICTING TOTAL ORGANIC COMPOUND EMISSIONS FROM THE COMBINED 1993 REFINERY,MARKETING TERMINAL, AND OIL AND GAS PRODUCTION OPERATIONS DATAaEquipment Type/ServiceDefault Zero EmissionRate (kg/hr/source)bPegged Emission Rates (kg/hr/source)cCorrelation Equationd(kg/hr/source)10,000 ppmv100,000 ppmvValve/All7.8E-060.0640.140LEAK = 2.29E-06×(SV)0.746Pump/All2.4E-050.0740.160eLEAK = 5.03E-05×(SV)0.610Otherf/All4.0E-060.0730.110LEAK = 1.36E-05×(SV)0.589Connector/All7.5E-060.0280.030LEAK = 1.53E-06×(SV)0.735Flange/All3.1E-070.0850.084LEAK = 4.61E-06×(SV)0.703Open-Ended Line/All2.0E-060.0300.079LEAK = 2.20E-06×(SV)0.704aTo estimate emissions: use the default zero emission rates only when the screening value (adjusted forbackground) equals 0.0 ppmv; otherwise use the correlation equations. If the monitoring deviceregisters a pegged value, use the appropriate pegged emission rate.bDefault zero emission rates were based on the combined 1993 refinery and marketing terminal data only(default zero data were not collected from oil and gas production facilities).cThe 10,000 ppmv pegged emission rate was based on components screened at greater than 10,000 ppmv;however, in some cases, most of the data could have come from components screened at greater than100,000 ppmv, thereby resulting in similar pegged emission rates for both the 10,000 and 100,000 peggedlevels (e.g., connector and flanges).dLEAK is the predicted mass emission rate (kg/hr) and SV is the screening value (ppmv) measured by themonitoring device.eOnly 2 data points were available for the pump 100,000 pegged emission rate; therefore the ratio ofthe pump 10,000 pegged emission rate to the overall 10,000 ppmv pegged emission rate was multiplied bythe overall 100,000 ppmv pegged emission rate to approximate the pump 100,000 ppmv pegged emissionrate.fThe "other" equipment type was developed from instruments, loading arms, pressure relief devices,stuffing boxes, vents, compressors, dump lever arms, diaphrams, drains, hatches, meters, and polishedrods. This "other" equipment type sould be applied to any equipment other than connectors, flanges,open-ended lines, pumps or valves.

C-13the total facility emissions that ranged from less than 10% to over 800% of the total facility emissions obtained from the adjusted 1980 correlations presented in this paper. When the total emissions from all 17 marketing terminals were evaluated, the 1993 correlations gave an estimate that was 40% of the total estimated by the adjusted 1980 correlations. Though the 17 marketing terminals do not represent the entire petroleum industry, these results illustrate the differences encountered when comparing emission estimates for individual facilities versus evaluating all facilities as a single group. C.1.4 Marketing Terminal and Oil and Gas Production Operation Screening Data for Development of Average Emission Factors
Screening data from 17 marketing terminals 10 and from 24 oil and gas production operation facilities 11,12 were available to EPA for the development of average emission factors using the same procedures as discussed in appendix B.2.3 for the revision of SOCMI average factors. Attachment 4 to appendix C summarizes the screening data used to develop the emission factors. Little documentation is available for the marketing terminal data because the data were collected and delivered directly to EPA with no formal report being written. The marketing terminal emission factors (shown in Tables 2-3 and 2-7) represent emissions from uncontrolled facilities. The following five facility types were represented in the oil and gas production operations screening dataset: • light crude facilities, • heavy crude facilities, • gas plants, • gas production facilities, and • offshore facilities. The 24 oil and gas production operations facilities generally represent uncontrolled facilities, however, a couple of gas plants have agency-mandated inspection and maintenance programs. Anecdotal data were available regarding the control level at other facilities. A statistical analysis revealed that there were no significant differences between emission factors for those groups of sites with some form of inspection and

C-14maintenance program versus those sites with no such programs13

. Thus, the oil and gas production operations emission factors (shown in Tables 2-4 and 2-8) represent emissions from uncontrolled facilities.

C-15REFERENCES
1. 1993 Study of Refinery Fugitive Emissions from Equipment Leaks, Volumes I, II, and III, Radian DCN No. 93-209-081-02, Radian Corporation, Prepared for Western States Petroleum Association, Glendale, CA, and American Petroleum Institute, Washington, D.C., 1994.
2. Development of Fugitive Emission Factors and Emission Profiles for Petroleum Marketing Terminals, Volumes I and II, API 4588, Radian Corporation, Prepared for American Petroleum Institute, 1993.
3. Fugitive Hydrocarbon Emissions from Oil and Gas Production Operations, API 4589, Star Environmental, Prepared for American Petroleum Institute, 1993.
4. Emission Factors for Oil and Gas Production Operations, API 4615, Star Enivironmental, Prepared for American Petroleum Institute, 1995.
5. Assessment of Atmospheric Emissions from Petroleum Refining, EPA-600/2-80-075., U.S. Environmental Protection Agency, Research Triangle Park, NC, 1980.
6. Petroleum Industry Equipment Leaks: Revised Correlations, Default Zero Emission Rates, and Pegged Emission Rates for Estimating VOC Emissions, Developed from 1993 Data from Refineries, Marketing Terminals, and Oil and Gas Production Operations, technical memorandum from David Epperson, Radian Corporation/Reasearch Triangle Park, to David Markwordt, US EPA/OAQPS, January 27, 1995.
7. Technology Transfer Network (Electronic Bulletin Boards), Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC, help desk phone number: (919) 541-5384, 1-5 pm EST.
8. Assessment of Atmospheric Emissions from Petroleum Refining: Volume 4, Appendix C, EPA-600/2-80-075d, U.S. Environmental Protection Agency, Research Triangle Park, NC, 1980.
9. Valve Screening Study at Six San Francisco Bay Area Petroleum Refineries, Radian DCN No. 79-219-370-05. Radian Corporation, Prepared for the United States Environmental Protection Agency, Research Triangle Park, NC, 1979.
10. Letter from Robert Strieter, API, to David Markwordt, U.S. EPA, regarding the submittal of gasoline distribution facility fugitive equipment screening data. April 26, 1994.
11. Fugitive Hydrocarbon Emissions from Oil and Gas Production Operations, API 4589, Star Environmental, Prepared for American Petroleum Institute, 1993.

C-1612. Emission Factors for Oil and Gas Production Operations, API 4615, Star Enivironmental, Prepared for American Petroleum Institute, 1995.
13. Fax to Eric Peterson, Santa Barbara APCD, Santa Barbara, CA from G.E. Harris, Radian/Austin, August 31, 1995.

C-17Figure C-1. Plot of data and regression lines with 95 percent confidence intervals for the all connector data from the 1980 (solid lines for regression equations and confidence bounds; O for individual data points) and 1993 (dashed lines for regression equations and confidence bounds; N for individual data points) refinery reports (screening values are in ppmv and leak rates in kg/hr).

C-18Figure C-2. Plot of data and regression lines with 95 percent confidence intervals for the gas valve data from the 1980 (solid lines for regression equations and confidence bounds; O for individual data points) and 1993 (dashed lines for regression equations and confidence bounds; N for individual data points) refinery reports (screening values are in ppmv and leak rates in kg/hr).

C-19Figure C-3. Comparison of ratios of predicted to measured mass formthe 1980 refinery, the 1993 refinery, and the combined 1980/1993 refinery data (a predicted-to-measured mass ratio of 1.0 indicates a perfect prediction). Bars that reach 4.0 on the chart actually extend beyond 4.0.

C-20Figure C-4. Plot of data and regression lines with 95 percent confidence intervals for the light liquid flange data from the 1993 refinery (solid lines for regression equations and confidence bounds; R for individual data points), the 1993 marketing terminal (short dashed lines for regression equations and confidence bounds; M for individual data points), and the 1993 oil and gas production operations (alternating short and long dashed lines for regression equations and confidence bounds; M for individual data points) reports (screening values are in ppmv and leak rates in kg/hr).

C-21Figure C-5. Plot of data and regression lines with 95 percent confidence intervals for the light liquid valve data from the 1993 refinery (solid lines for regression equations and confidence bounds; R for individual data points), the 1993 marketing terminal (short dashed lines for regression equations and confidence bounds; M for individual data points), and the 1993 oil and gas production operations (alternating short and long dashed lines for regression equations and confidence bounds; M for individual data points) reports (screening values are in ppmv and leak rates in kg/hr).

C-22Figure C-6. Comparison of the ratios of predicted to observed mass from the 1993 refinery, marketing terminal, oil and gas production operations, and the combined refinery/marketing terminal/oil and gas production operations data (a predicted-to-measured mass ratio of 1.0 indicates a perfect prediction). Bars that reach 4.0 on the chart actually extend beyond 4.0.

C-23APPENDIX C: ATTACHMENT 1 This attachment lists the bagging data used to develop the correlation equations for each of the equipment types in table C-1-1. Also included is a summary table (table C-1-2) of the regression statistics for the 1993 refinery, marketing terminal and oil and gas production operations data individually. Note that the regression statistics presented in table C-1-2 are based on the development of the regression lines using natural logarithms of the leak rates and screening values. Table C-1-3 lists the bagging data for the 1980 refinery data while table C-1-4 presents regression statistics for the 1980 and 1993 refinery data sets.

C-24TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS

---------------------- Equipment Type=CONNECTOR SERVICE=G ----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00000045360 8.00 -14.606 2.079 REF 0.00000050826 13.00 -14.492 2.565 ONOFF 0.00000181439 1.75 -13.220 0.560 ONOFF 0.00000272158 106.00 -12.814 4.663 ONOFF 0.00000272158 145.00 -12.814 4.977 ONOFF 0.00000453597 70.00 -12.303 4.248 ONOFF 0.00000498957 98.00 -12.208 4.585 ONOFF 0.00000498957 1,045.00 -12.208 6.952 ONOFF 0.00000680396 1,450.00 -11.898 7.279 ONOFF 0.00000725755 440.00 -11.833 6.087 ONOFF 0.00001043273 195.00 -11.471 5.273 ONOFF 0.00001360791 6,240.00 -11.205 8.739 ONOFF 0.00001632949 4,982.00 -11.023 8.514 MT 0.00001732831 30.00 -10.963 3.401 ONOFF 0.00001995827 93.00 -10.822 4.533 ONOFF 0.00002313345 43.00 -10.674 3.761 ONOFF 0.00002903021 890.00 -10.447 6.791 ONOFF 0.00002993740 549.00 -10.416 6.308 ONOFF 0.00003084460 130.50 -10.387 4.871 REF 0.00004677946 267.00 -9.970 5.587 REF 0.00004909734 446.00 -9.922 6.100 REF 0.00006622970 1,196.50 -9.622 7.087 ONOFF 0.00010659530 2,742.00 -9.146 7.916 ONOFF 0.00013245033 1,999.00 -8.929 7.600 ONOFF 0.00014061508 1,985.00 -8.869 7.593 REF 0.00019757326 271.00 -8.529 5.602 MT 0.00027662615 30.00 -8.193 3.401 ONOFF 0.00033566180 790.00 -7.999 6.672 REF 0.00039860292 7,745.00 -7.828 8.955 ONOFF 0.00046040098 3,996.00 -7.683 8.293 ONOFF 0.00049850313 5,498.00 -7.604 8.612 REF 0.00094198494 10,995.00 -6.968 9.305 ONOFF 0.00105688107 8,995.00 -6.852 9.104 REF 0.00220312075 43,995.00 -6.118 10.692

N = 34

C-25TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
--------------------- Equipment Type=CONNECTOR SERVICE=HL ----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000057407 58.50 -14.371 4.069 ONOFF 0.00001360791 19.50 -11.205 2.970 REF 0.00098339835 8,994.00 -6.924 9.104

N=3

--------------------- Equipment Type=CONNECTOR SERVICE=LL ----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000003124 36.50 -17.282 3.597 REF 0.00000032133 38.00 -14.951 3.638 REF 0.00000039502 6.50 -14.744 1.872 ONOFF 0.00000045360 13.50 -14.606 2.603 REF 0.00000069890 18.00 -14.174 2.890 REF 0.00000138429 1,335.00 -13.490 7.197 REF 0.00000140733 26.50 -13.474 3.277 ONOFF 0.00000226799 1,547.00 -12.997 7.344 REF 0.00000252558 1,393.00 -12.889 7.239 ONOFF 0.00000272158 20.00 -12.814 2.996 ONOFF 0.00000272158 41.00 -12.814 3.714 ONOFF 0.00000272158 155.00 -12.814 5.043 ONOFF 0.00000272158 498.00 -12.814 6.211 ONOFF 0.00000362878 75.00 -12.527 4.317 REF 0.00000366230 91.00 -12.517 4.511 ONOFF 0.00000408237 56.00 -12.409 4.025 ONOFF 0.00000408237 96.00 -12.409 4.564 MT 0.00000418117 35.00 -12.385 3.555 ONOFF 0.00000544316 157.50 -12.121 5.059 ONOFF 0.00000589676 200.00 -12.041 5.298 ONOFF 0.00000635036 290.00 -11.967 5.670 ONOFF 0.00000680396 39.00 -11.898 3.664 ONOFF 0.00000816475 4,400.00 -11.716 8.389 MT 0.00001033612 317.00 -11.480 5.759 ONOFF 0.00001133993 294.00 -11.387 5.684 ONOFF 0.00001133993 1,240.00 -11.387 7.123 REF 0.00001226163 1,345.50 -11.309 7.205 ONOFF 0.00001270072 123.00 -11.274 4.812 MT 0.00001529121 23.00 -11.088 3.135 ONOFF 0.00001542230 322.00 -11.080 5.775

C-26TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
--------------------- Equipment Type=CONNECTOR SERVICE=LL ---------------------- (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00001542230 395.00 -11.080 5.979 MT 0.00001610768 23.00 -11.036 3.135 REF 0.00001628413 649.00 -11.025 6.475 ONOFF 0.00001814388 56.00 -10.917 4.025 REF 0.00001880613 19,304.00 -10.881 9.868 ONOFF 0.00002222625 945.00 -10.714 6.851 ONOFF 0.00002267985 825.00 -10.694 6.715 ONOFF 0.00002313345 5,900.00 -10.674 8.683 ONOFF 0.00002585503 172.00 -10.563 5.147 MT 0.00002609816 45.00 -10.554 3.807 MT 0.00002844053 321.00 -10.468 5.771 ONOFF 0.00002993740 121.00 -10.416 4.796 ONOFF 0.00003356618 450.00 -10.302 6.109 MT 0.00003923025 42.50 -10.146 3.750 MT 0.00004271251 670.00 -10.061 6.507 MT 0.00004451148 446.50 -10.020 6.101 MT 0.00004481675 542.00 -10.013 6.295 ONOFF 0.00005080287 6,930.00 -9.888 8.844 ONOFF 0.00005216366 1,996.00 -9.861 7.599 MT 0.00005430464 112.00 -9.821 4.718 MT 0.00005460855 96.00 -9.815 4.564 ONOFF 0.00006304999 3,248.00 -9.672 8.086 REF 0.00006329946 21,996.00 -9.668 9.999 MT 0.00006931416 141.50 -9.577 4.952 MT 0.00008792071 511.00 -9.339 6.236 ONOFF 0.00009570897 8,450.00 -9.254 9.042 ONOFF 0.00010886329 1,245.00 -9.125 7.127 ONOFF 0.00011612084 3,495.00 -9.061 8.159 ONOFF 0.00012247120 1,900.00 -9.008 7.550 ONOFF 0.00013381112 6,998.00 -8.919 8.853 MT 0.00013952191 420.00 -8.877 6.040 ONOFF 0.00018461399 2,992.00 -8.597 8.004 MT 0.00021457407 621.50 -8.447 6.432 ONOFF 0.00021863377 5,990.00 -8.428 8.698 MT 0.00025722126 41.00 -8.266 3.714 ONOFF 0.00026263268 1,249.00 -8.245 7.130 REF 0.00026441985 3,595.50 -8.238 8.187 MT 0.00030734827 270.00 -8.088 5.598 MT 0.00031839790 171.50 -8.052 5.145 ONOFF 0.00032341468 1,993.00 -8.037 7.597 ONOFF 0.00033475460 2,240.00 -8.002 7.714 ONOFF 0.00041640207 290.00 -7.784 5.670 MT 0.00071681938 6,996.00 -7.241 8.853 MT 0.00075932142 940.00 -7.183 6.846

C-27TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
--------------------- Equipment Type=CONNECTOR SERVICE=LL ---------------------- (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00082713417 89,996.50 -7.098 11.408 REF 0.00087190420 62,482.50 -7.045 11.043 REF 0.00090365599 6,492.50 -7.009 8.778 ONOFF 0.00152363240 2,490.00 -6.487 7.820 REF 0.00337970607 52,843.00 -5.690 10.875 REF 0.02082463939 27,493.00 -3.872 10.222 ONOFF 0.15713462760 44,990.00 -1.851 10.714

N = 81

----------------------- Equipment Type=FLANGE SERVICE=G ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000133929 344.50 -13.523 5.842 ONOFF 0.00000272158 46.00 -12.814 3.829 REF 0.00000347791 97.00 -12.569 4.575 MT 0.00000944344 37.50 -11.570 3.624 ONOFF 0.00000952554 122.00 -11.562 4.804 ONOFF 0.00001133993 398.00 -11.387 5.986 ONOFF 0.00003220539 597.00 -10.343 6.392 REF 0.00003784088 81.00 -10.182 4.394 ONOFF 0.00003810215 39.00 -10.175 3.664 ONOFF 0.00005533884 197.00 -9.802 5.283 ONOFF 0.00007076114 1,996.00 -9.556 7.599 ONOFF 0.00054068765 424.00 -7.523 6.050 REF 0.00268479543 4,996.00 -5.920 8.516 ONOFF 0.00444751882 999.00 -5.415 6.907

N = 14

C-28TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
----------------------- Equipment Type=FLANGE SERVICE=HL -----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000585594 22.50 -12.048 3.114 ONOFF 0.00000907194 345.00 -11.610 5.844

N=2

C-29TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
----------------------- Equipment Type=FLANGE SERVICE=LL -----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000084061 5.00 -13.989 1.609 REF 0.00000206056 19.50 -13.093 2.970 ONOFF 0.00000317518 84.00 -12.660 4.431 ONOFF 0.00000544316 133.50 -12.121 4.894 MT 0.00000558151 46.00 -12.096 3.829 ONOFF 0.00000680396 4,480.00 -11.898 8.407 REF 0.00001045859 595.50 -11.468 6.389 ONOFF 0.00001315431 174.00 -11.239 5.159 MT 0.00001445342 34.50 -11.145 3.541 ONOFF 0.00001451510 65.00 -11.140 4.174 MT 0.00001889096 50.00 -10.877 3.912 ONOFF 0.00001905108 10.50 -10.868 2.351 ONOFF 0.00002585503 186.00 -10.563 5.226 ONOFF 0.00002903021 530.00 -10.447 6.273 MT 0.00003226209 1,096.50 -10.342 7.000 REF 0.00003390230 69.50 -10.292 4.241 ONOFF 0.00003674136 3,997.00 -10.212 8.293 ONOFF 0.00003764855 192.00 -10.187 5.257 ONOFF 0.00003991654 247.00 -10.129 5.509 MT 0.00005107956 87.00 -9.882 4.466 MT 0.00006298648 1,096.50 -9.673 7.000 REF 0.00007970607 1,996.00 -9.437 7.599 REF 0.00008327588 222.50 -9.393 5.405 REF 0.00012617255 593.00 -8.978 6.385 MT 0.00013896398 392.00 -8.881 5.971 REF 0.00016897850 1,548.00 -8.686 7.345 REF 0.00024779098 3,244.50 -8.303 8.085 ONOFF 0.00025129275 1,145.00 -8.289 7.043 MT 0.00025963440 94.00 -8.256 4.543 REF 0.00030001361 671.00 -8.112 6.509 MT 0.00037563277 27.50 -7.887 3.314 MT 0.00046017418 372.50 -7.684 5.920 MT 0.00090079833 37.50 -7.012 3.624 REF 0.00095309807 20,246.00 -6.956 9.916 MT 0.00096566271 997.00 -6.943 6.905 REF 0.00125641840 34,995.50 -6.679 10.463 REF 0.00169028395 3,997.50 -6.383 8.293 REF 0.00344683843 11,547.00 -5.670 9.354 ONOFF 0.00355030391 1,998.00 -5.641 7.600 REF 0.00382985576 1,495.00 -5.565 7.310

N = 40

C-30TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
--------------------- Equipment Type=INSTRUMENT SERVICE=G ----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00007302912 1,992.00 -9.525 7.597 ONOFF 0.00028259095 29,998.00 -8.172 10.309

N=2

--------------------- Equipment Type=INSTRUMENT SERVICE=LL ---------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00000272158 2,743.00 -12.814 7.917

N=1

----------------------- Equipment Type=LOADARM SERVICE=G -----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

MT 0.00000641205 18.00 -11.957 2.890 MT 0.00002664338 45.00 -10.533 3.807 MT 0.00007439445 70.00 -9.506 4.248 MT 0.00036316339 19.50 -7.921 2.970 MT 0.00134378118 2,498.50 -6.612 7.823 MT 0.00294180350 387.00 -5.829 5.958 MT 0.00397654903 1,096.00 -5.527 6.999

N=7

C-31TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
---------------------- Equipment Type=LOADARM SERVICE=LL -----------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

MT 0.00000263449 3.00 -12.847 1.099 MT 0.00000483852 75.00 -12.239 4.317 MT 0.00000647374 76.00 -11.948 4.331 MT 0.00001007893 6.00 -11.505 1.792 MT 0.00001144289 4.50 -11.378 1.504 MT 0.00001305906 5.50 -11.246 1.705 MT 0.00001802640 33.00 -10.924 3.497 MT 0.00001825229 6.00 -10.911 1.792 MT 0.00002585775 79.00 -10.563 4.369 MT 0.00002943210 26.50 -10.433 3.277 MT 0.00004225755 46.50 -10.072 3.839 MT 0.00005778372 15.00 -9.759 2.708 MT 0.00007896671 70.00 -9.446 4.248 MT 0.00010795156 96.00 -9.134 4.564 MT 0.00012671233 10.50 -8.974 2.351 MT 0.00021594394 145.50 -8.440 4.980

N = 16

C-32TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------- Equipment Type=OEL SERVICE=G -------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000077642 20.30 -14.069 3.011 ONOFF 0.00000090719 9.00 -13.913 2.197 ONOFF 0.00000136079 8.00 -13.507 2.079 REF 0.00000177710 60.50 -13.241 4.103 ONOFF 0.00000181439 20.50 -13.220 3.020 ONOFF 0.00000181439 26.50 -13.220 3.277 ONOFF 0.00000181439 30.50 -13.220 3.418 ONOFF 0.00000226799 84.00 -12.997 4.431 ONOFF 0.00000272158 48.00 -12.814 3.871 ONOFF 0.00000272158 195.00 -12.814 5.273 ONOFF 0.00000272158 63.00 -12.814 4.143 ONOFF 0.00000272158 113.50 -12.814 4.732 ONOFF 0.00000362878 440.00 -12.527 6.087 ONOFF 0.00000362878 499.00 -12.527 6.213 REF 0.00000391912 16.50 -12.450 2.803 ONOFF 0.00000408237 546.00 -12.409 6.303 ONOFF 0.00000453597 377.00 -12.303 5.932 ONOFF 0.00000498957 59.00 -12.208 4.078 ONOFF 0.00000544316 24.00 -12.121 3.178 ONOFF 0.00000544316 930.00 -12.121 6.835 ONOFF 0.00000589676 755.00 -12.041 6.627 ONOFF 0.00000771115 65.00 -11.773 4.174 ONOFF 0.00000861834 740.00 -11.662 6.607 ONOFF 0.00000907194 383.00 -11.610 5.948 ONOFF 0.00001043273 600.00 -11.471 6.397 ONOFF 0.00001088633 4,430.00 -11.428 8.396 ONOFF 0.00001133993 250.00 -11.387 5.521 REF 0.00001313209 893.00 -11.240 6.795 ONOFF 0.00001587590 349.00 -11.051 5.855 ONOFF 0.00001859748 2,725.00 -10.892 7.910 ONOFF 0.00002177266 1,745.00 -10.735 7.465 ONOFF 0.00002812302 1,747.00 -10.479 7.466 ONOFF 0.00002857661 1,143.00 -10.463 7.041 ONOFF 0.00003039100 1,400.00 -10.401 7.244 REF 0.00003324186 1,295.00 -10.312 7.166 ONOFF 0.00003447337 1,845.00 -10.275 7.520 REF 0.00004146875 15,068.00 -10.091 9.620 ONOFF 0.00004853488 17,499.00 -9.933 9.770 ONOFF 0.00007166833 820.00 -9.543 6.709 ONOFF 0.00008845142 483.50 -9.333 6.181 ONOFF 0.00010024494 170.00 -9.208 5.136 ONOFF 0.00012065681 1,043.00 -9.023 6.950 ONOFF 0.00013743990 3,400.00 -8.892 8.132 ONOFF 0.00016057335 999.00 -8.737 6.907 ONOFF 0.00016737730 80.00 -8.695 4.382

C-33TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------- Equipment Type=OEL SERVICE=G ------------------------- (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00020729384 3,746.00 -8.481 8.228 ONOFF 0.00025991109 849.00 -8.255 6.744 ONOFF 0.00029257008 13,497.00 -8.137 9.510 ONOFF 0.00043046358 1,980.00 -7.751 7.591 ONOFF 0.00057652182 27,497.00 -7.458 10.222 ONOFF 0.00084278327 5,998.00 -7.079 8.699 REF 0.00087367323 44,998.00 -7.043 10.714 ONOFF 0.00107184977 5,998.00 -6.838 8.699 ONOFF 0.00229792253 14,999.00 -6.076 9.616 ONOFF 0.04543499955 1,800.00 -3.091 7.496

N = 55

------------------------ Equipment Type=OEL SERVICE=HL -------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000137984 195.00 -13.494 5.273 ONOFF 0.00000453597 107.50 -12.303 4.677 ONOFF 0.00000498957 33.50 -12.208 3.512 ONOFF 0.00000544316 75.00 -12.121 4.317 ONOFF 0.00000544316 170.00 -12.121 5.136 ONOFF 0.00000635036 85.50 -11.967 4.449 ONOFF 0.00001224712 75.00 -11.310 4.317 ONOFF 0.00002948381 95.00 -10.432 4.554 ONOFF 0.00005533884 142.00 -9.802 4.956 ONOFF 0.00005715323 58.00 -9.770 4.060 ONOFF 0.00006304999 329.50 -9.672 5.798 ONOFF 0.00008074027 2,994.00 -9.424 8.004 REF 0.00011177991 1,097.50 -9.099 7.001 REF 0.00018571169 15,496.50 -8.591 9.648 ONOFF 0.00045904019 1,194.00 -7.686 7.085 ONOFF 0.00109226163 4,990.00 -6.820 8.515

N = 16

C-34TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------ Equipment Type=OEL SERVICE=LL -------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00000045360 698.00 -14.606 6.548 REF 0.00000079071 100.00 -14.050 4.605 ONOFF 0.00000090719 293.00 -13.913 5.680 MT 0.00000109340 1.00 -13.726 0.000 ONOFF 0.00000136079 122.00 -13.507 4.804 MT 0.00000179606 2.00 -13.230 0.693 ONOFF 0.00000181439 3.75 -13.220 1.322 REF 0.00000269491 14.50 -12.824 2.674 ONOFF 0.00000272158 96.00 -12.814 4.564 ONOFF 0.00000272158 75.00 -12.814 4.317 ONOFF 0.00000272158 110.00 -12.814 4.700 REF 0.00000272462 1,448.00 -12.813 7.278 MT 0.00000289948 8.00 -12.751 2.079 MT 0.00000312574 1.75 -12.676 0.560 ONOFF 0.00000317518 63.00 -12.660 4.143 ONOFF 0.00000317518 547.00 -12.660 6.304 REF 0.00000396675 488.00 -12.438 6.190 ONOFF 0.00000453597 1,004.00 -12.303 6.912 ONOFF 0.00000725755 180.00 -11.833 5.193 ONOFF 0.00000725755 1,148.00 -11.833 7.046 ONOFF 0.00000771115 148.00 -11.773 4.997 ONOFF 0.00000771115 1,000.50 -11.773 6.908 REF 0.00000810124 247.00 -11.723 5.509 ONOFF 0.00000861834 535.00 -11.662 6.282 MT 0.00001089767 175.50 -11.427 5.168 ONOFF 0.00001224712 3.00 -11.310 1.099 MT 0.00001287898 545.50 -11.260 6.302 ONOFF 0.00001360791 996.00 -11.205 6.904 REF 0.00001366144 522.50 -11.201 6.259 ONOFF 0.00001496870 2.50 -11.110 0.916 ONOFF 0.00002131906 44.00 -10.756 3.784 ONOFF 0.00002585503 1,498.00 -10.563 7.312 ONOFF 0.00002721582 99.00 -10.512 4.595 REF 0.00003169282 1,493.00 -10.359 7.309 REF 0.00003332713 66.50 -10.309 4.197 MT 0.00003502223 296.00 -10.260 5.690 ONOFF 0.00004127733 2,144.00 -10.095 7.670 ONOFF 0.00004399891 1,492.00 -10.031 7.308 MT 0.00004551393 51.00 -9.997 3.932 ONOFF 0.00007529711 849.00 -9.494 6.744 REF 0.00007992833 3,243.00 -9.434 8.084 REF 0.00009666606 14,846.00 -9.244 9.605 ONOFF 0.00010659530 1,748.00 -9.146 7.466 ONOFF 0.00010704890 6,985.00 -9.142 8.852 ONOFF 0.00011067767 796.00 -9.109 6.680

C-35TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------ Equipment Type=OEL SERVICE=LL ------------------------- (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00012428558 2,200.00 -8.993 7.696 ONOFF 0.00013063594 34,996.00 -8.943 10.463 REF 0.00013571623 535.00 -8.905 6.282 ONOFF 0.00020956183 2,097.00 -8.470 7.648 ONOFF 0.00023541686 2,248.00 -8.354 7.718 MT 0.00028113490 142.00 -8.177 4.956 ONOFF 0.00029483807 1,744.00 -8.129 7.464 REF 0.00035645469 1,996.00 -7.939 7.599 ONOFF 0.00035970244 1,190.00 -7.930 7.082 ONOFF 0.00038510387 4,489.00 -7.862 8.409 MT 0.00053411050 495.00 -7.535 6.205 REF 0.00056373038 12,493.50 -7.481 9.433 MT 0.00056382110 93.00 -7.481 4.533 MT 0.00076480994 1,186.00 -7.176 7.078 MT 0.00082414043 210.00 -7.101 5.347 MT 0.00086428377 1,039.00 -7.054 6.946 REF 0.00092007620 12,990.00 -6.991 9.472 ONOFF 0.00120112492 37,492.00 -6.724 10.532 MT 0.00175405969 990.00 -6.346 6.898 ONOFF 0.00219268802 19,992.00 -6.123 9.903 ONOFF 0.00361471469 42,493.00 -5.623 10.657 ONOFF 0.00594257462 69,994.00 -5.126 11.156 ONOFF 0.00753968974 347.00 -4.888 5.849 REF 0.00883470924 26,795.00 -4.729 10.196 MT 0.05022226254 7,992.00 -2.991 8.986

N = 70

------------------------ Equipment Type=OTHER SERVICE=G ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

MT 0.00001317427 970.00 -11.237 6.877

N=1

C-36TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
----------------------- Equipment Type=OTHER SERVICE=LL ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

MT 0.00000408142 73.00 -12.409 4.290 MT 0.00001337113 3,995.00 -11.222 8.293 MT 0.00003222716 2,991.00 -10.343 8.003

N=3

------------------------- Equipment Type=PRV SERVICE=G -------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000184074 2,595.00 -13.205 7.861 ONOFF 0.00000408237 19.00 -12.409 2.944 ONOFF 0.00001451510 81.00 -11.140 4.394 ONOFF 0.00007393631 149.00 -9.512 5.004 ONOFF 0.00010387372 578.50 -9.172 6.360 ONOFF 0.00014651184 1,345.00 -8.828 7.204 ONOFF 0.00029166289 1,741.00 -8.140 7.462

N=7

------------------------ Equipment Type=PRV SERVICE=LL -------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000105779 3.80 -13.759 1.335 ONOFF 0.00001496870 297.00 -11.110 5.694 ONOFF 0.00002812302 997.00 -10.479 6.905 ONOFF 0.00024312801 5,491.00 -8.322 8.611

N=4

C-37TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------ Equipment Type=PUMP SERVICE=HL ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000090434 281.00 -13.916 5.638 REF 0.00000241563 10.00 -12.934 2.303 REF 0.00000450227 6.80 -12.311 1.917 REF 0.00001091808 19.00 -11.425 2.944 REF 0.00002612447 18.00 -10.553 2.890 REF 0.00006783543 9.50 -9.598 2.251 REF 0.00032885331 45.50 -8.020 3.818 REF 0.00082590946 323.00 -7.099 5.778 REF 0.00089771387 1,145.50 -7.016 7.044 REF 0.00290669509 277.00 -5.841 5.624 REF 0.01268710877 9,496.50 -4.367 9.159

N = 11

C-38TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------ Equipment Type=PUMP SERVICE=LL ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

MT 0.00000569400 24.50 -12.076 3.199 REF 0.00002452599 107.00 -10.616 4.673 MT 0.00002501950 2.00 -10.596 0.693 MT 0.00002550576 20.00 -10.577 2.996 MT 0.00003079742 95.00 -10.388 4.554 REF 0.00003737186 7,999.00 -10.195 8.987 MT 0.00003825274 45.50 -10.171 3.818 REF 0.00004112537 126.00 -10.099 4.836 REF 0.00004198993 192.00 -10.078 5.257 REF 0.00005151955 66.50 -9.874 4.197 REF 0.00006067767 4.50 -9.710 1.504 MT 0.00006509571 5.00 -9.640 1.609 MT 0.00006677855 7.50 -9.614 2.015 REF 0.00014387644 22.00 -8.847 3.091 REF 0.00018934954 21.50 -8.572 3.068 REF 0.00028473646 7,999.00 -8.164 8.987 REF 0.00034099156 136.00 -7.984 4.913 MT 0.00034670235 8,945.50 -7.967 9.099 REF 0.00048530346 127.00 -7.631 4.844 REF 0.00052476640 15.50 -7.553 2.741 REF 0.00059974599 1,780.00 -7.419 7.484 REF 0.00062650821 66.00 -7.375 4.190 MT 0.00066574435 43.00 -7.315 3.761 REF 0.00082055702 27,996.00 -7.106 10.240 REF 0.00086514560 33,744.50 -7.053 10.427 MT 0.00092406786 6,868.00 -6.987 8.835 REF 0.00095527533 5,970.00 -6.954 8.695 REF 0.00119445704 22,995.00 -6.730 10.043 REF 0.00121223805 1,394.00 -6.715 7.240 REF 0.00122534700 621.00 -6.705 6.431 REF 0.00153538057 183.50 -6.479 5.212 REF 0.00179438447 1,697.00 -6.323 7.437 REF 0.00220076204 947.00 -6.119 6.853 REF 0.00301020593 996.00 -5.806 6.904 REF 0.00489884786 395.00 -5.319 5.979 REF 0.00679034746 5,745.50 -4.992 8.656 REF 0.00757234873 4,997.00 -4.883 8.517 REF 0.00958087635 41,995.00 -4.648 10.645 REF 0.00968248208 13,995.00 -4.637 9.546 MT 0.01317699356 4,488.00 -4.329 8.409 REF 0.03439081920 17,694.50 -3.370 9.781 ONOFF 0.07243808401 4,992.00 -2.625 8.516

N = 42

C-39TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
-------------------- Equipment Type=STUFFING BOX SERVICE=HL --------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00000317518 26.00 -12.660 3.258 ONOFF 0.00000317518 46.00 -12.660 3.829 ONOFF 0.00000317518 47.50 -12.660 3.861 ONOFF 0.00000544316 75.00 -12.121 4.317 ONOFF 0.00000589676 162.00 -12.041 5.088 ONOFF 0.00001043273 145.00 -11.471 4.977 ONOFF 0.00001451510 145.00 -11.140 4.977 ONOFF 0.00004127733 127.00 -10.095 4.844 ONOFF 0.00007076114 294.00 -9.556 5.684 ONOFF 0.00089630772 795.00 -7.017 6.678 ONOFF 0.00129592670 1,095.00 -6.649 6.999

N = 11

-------------------- Equipment Type=STUFFING BOX SERVICE=LL --------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00014197587 293.00 -8.860 5.680 ONOFF 0.00032114669 842.00 -8.044 6.736 ONOFF 0.00046266896 630.00 -7.678 6.446 ONOFF 0.00052390456 71.00 -7.554 4.263 ONOFF 0.00059421210 647.00 -7.428 6.472 ONOFF 0.00107321056 4,498.00 -6.837 8.411 ONOFF 0.00114442529 1,246.00 -6.773 7.128 ONOFF 0.00120611449 992.00 -6.720 6.900 ONOFF 0.00142293387 748.00 -6.555 6.617 ONOFF 0.00371586682 3,994.00 -5.595 8.293 ONOFF 0.00399664338 4,498.00 -5.522 8.411 ONOFF 0.00602331489 3,496.00 -5.112 8.159

N = 12

C-40TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------ Equipment Type=VALVE SERVICE=G ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00000045360 1.25 -14.606 0.223 ONOFF 0.00000045360 9.00 -14.606 2.197 ONOFF 0.00000045360 52.50 -14.606 3.961 ONOFF 0.00000045360 1,997.00 -14.606 7.599 ONOFF 0.00000090719 122.00 -13.913 4.804 REF 0.00000108460 150.00 -13.734 5.011 ONOFF 0.00000136079 142.00 -13.507 4.956 REF 0.00000162324 78.00 -13.331 4.357 MT 0.00000211567 295.50 -13.066 5.689 MT 0.00000226853 1.00 -12.996 0.000 ONOFF 0.00000272158 46.50 -12.814 3.839 ONOFF 0.00000272158 227.50 -12.814 5.427 ONOFF 0.00000317518 31.50 -12.660 3.450 ONOFF 0.00000317518 42.00 -12.660 3.738 REF 0.00000322045 33.00 -12.646 3.497 REF 0.00000323338 23.50 -12.642 3.157 ONOFF 0.00000453597 180.00 -12.303 5.193 REF 0.00000474236 11.00 -12.259 2.398 ONOFF 0.00000498957 1,497.00 -12.208 7.311 ONOFF 0.00000498957 1,780.00 -12.208 7.484 REF 0.00000566633 68.50 -12.081 4.227 REF 0.00000584324 50.00 -12.050 3.912 ONOFF 0.00000635036 749.00 -11.967 6.619 REF 0.00000662796 22.50 -11.924 3.114 ONOFF 0.00000725755 1,620.00 -11.833 7.390 ONOFF 0.00000907194 648.00 -11.610 6.474 ONOFF 0.00000952554 299.00 -11.562 5.700 REF 0.00000959040 105.00 -11.555 4.654 ONOFF 0.00000997913 3.50 -11.515 1.253 ONOFF 0.00000997913 3.50 -11.515 1.253 REF 0.00001004944 240.00 -11.508 5.481 REF 0.00001313209 66.00 -11.240 4.190 REF 0.00001568266 306.00 -11.063 5.724 REF 0.00001582872 26.00 -11.054 3.258 REF 0.00001608773 1,194.50 -11.037 7.085 ONOFF 0.00001905108 1,300.00 -10.868 7.170 REF 0.00001952236 724.00 -10.844 6.585 ONOFF 0.00002177266 96.00 -10.735 4.564 ONOFF 0.00002404064 236.50 -10.636 5.466 REF 0.00002500272 13.00 -10.597 2.565 ONOFF 0.00002721582 115.00 -10.512 4.745 REF 0.00002723941 100.00 -10.511 4.605 REF 0.00002964075 1,495.00 -10.426 7.310 REF 0.00002977456 798.50 -10.422 6.683 ONOFF 0.00002993740 71.00 -10.416 4.263

C-41TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------ Equipment Type=VALVE SERVICE=G ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00003039100 3,485.00 -10.401 8.156 ONOFF 0.00003129819 1,880.00 -10.372 7.539 REF 0.00003320285 297.00 -10.313 5.694 ONOFF 0.00003538057 870.00 -10.249 6.768 ONOFF 0.00004581330 1,746.00 -9.991 7.465 REF 0.00004823551 396.50 -9.939 5.983 ONOFF 0.00004853488 490.00 -9.933 6.194 REF 0.00005161027 195.50 -9.872 5.276 ONOFF 0.00005171006 1,048.00 -9.870 6.955 REF 0.00005379207 331.50 -9.830 5.804 REF 0.00005465391 22.50 -9.814 3.114 REF 0.00005555656 1,049.00 -9.798 6.956 ONOFF 0.00005760682 918.00 -9.762 6.822 REF 0.00005882700 1,045.00 -9.741 6.952 REF 0.00006236052 515.00 -9.683 6.244 ONOFF 0.00006441078 169.00 -9.650 5.130 REF 0.00006601651 496.50 -9.626 6.208 ONOFF 0.00006713236 795.00 -9.609 6.678 ONOFF 0.00007030754 498.00 -9.563 6.211 ONOFF 0.00007166833 1,497.00 -9.543 7.311 REF 0.00007594121 420.00 -9.486 6.040 ONOFF 0.00008618343 249.00 -9.359 5.517 REF 0.00008973964 922.00 -9.319 6.827 ONOFF 0.00009434818 1,748.00 -9.269 7.466 REF 0.00009616711 197.50 -9.249 5.286 REF 0.00009735099 996.00 -9.237 6.904 REF 0.00010011794 1,397.00 -9.209 7.242 ONOFF 0.00010160573 525.00 -9.194 6.263 ONOFF 0.00010523451 3,993.00 -9.159 8.292 ONOFF 0.00010886329 8,180.00 -9.125 9.009 ONOFF 0.00011158487 1,996.00 -9.101 7.599 ONOFF 0.00011294566 499.00 -9.089 6.213 ONOFF 0.00012564638 749.00 -8.982 6.619 ONOFF 0.00013154314 780.00 -8.936 6.659 ONOFF 0.00013426472 785.00 -8.916 6.666 ONOFF 0.00013426472 8,400.00 -8.916 9.036 ONOFF 0.00014605824 3,999.00 -8.832 8.294 ONOFF 0.00014651184 1,997.00 -8.828 7.599 ONOFF 0.00017327406 1,994.00 -8.661 7.598 ONOFF 0.00018053162 290.00 -8.620 5.670 REF 0.00018855575 2,343.00 -8.576 7.759 REF 0.00019906105 142.00 -8.522 4.956 REF 0.00019947836 830.00 -8.520 6.721 ONOFF 0.00021727297 243.00 -8.434 5.493

C-42TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------ Equipment Type=VALVE SERVICE=G ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00021818017 5,725.00 -8.430 8.653 REF 0.00022242130 4,246.00 -8.411 8.354 REF 0.00022387281 297.00 -8.404 5.694 REF 0.00023074027 735.00 -8.374 6.600 ONOFF 0.00023904563 798.00 -8.339 6.682 ONOFF 0.00026898304 999.00 -8.221 6.907 ONOFF 0.00026898304 1,165.00 -8.221 7.060 REF 0.00028817473 3,898.40 -8.152 8.268 ONOFF 0.00029257008 14,995.00 -8.137 9.615 ONOFF 0.00031887871 1,998.00 -8.051 7.600 ONOFF 0.00031978590 1,339.00 -8.048 7.200 ONOFF 0.00032114669 1,339.00 -8.044 7.200 ONOFF 0.00033203302 2,999.00 -8.010 8.006 REF 0.00033339381 7,995.50 -8.006 8.987 REF 0.00033416946 996.00 -8.004 6.904 ONOFF 0.00034972331 7,492.00 -7.958 8.922 REF 0.00035323415 22,495.00 -7.948 10.021 REF 0.00038567541 16,496.00 -7.861 9.711 REF 0.00041993559 1,949.00 -7.775 7.575 ONOFF 0.00043137077 2,997.00 -7.749 8.005 ONOFF 0.00043227796 3,990.00 -7.746 8.292 ONOFF 0.00053070852 3,998.00 -7.541 8.294 REF 0.00060437268 65,699.00 -7.411 11.093 ONOFF 0.00066542683 1,045.00 -7.315 6.952 REF 0.00066864737 3,493.00 -7.310 8.159 ONOFF 0.00069445704 740.00 -7.272 6.607 ONOFF 0.00074027034 699.00 -7.208 6.550 ONOFF 0.00082191781 7,495.00 -7.104 8.922 ONOFF 0.00090220448 69,995.00 -7.011 11.156 ONOFF 0.00094484260 14,999.00 -6.964 9.616 ONOFF 0.00102558287 3,241.00 -6.882 8.084 ONOFF 0.00109815840 44,998.00 -6.814 10.714 REF 0.00111190239 79,998.80 -6.802 11.290 ONOFF 0.00111358069 1,444.00 -6.800 7.275 ONOFF 0.00115621882 4,491.00 -6.763 8.410 ONOFF 0.00124965980 6,000.00 -6.685 8.700 REF 0.00132495691 7,998.00 -6.626 8.987 ONOFF 0.00145377846 2,499.00 -6.534 7.824 ONOFF 0.00155719858 5,235.00 -6.465 8.563 ONOFF 0.00207339200 3,465.00 -6.179 8.150 ONOFF 0.00244851674 2,696.00 -6.012 7.900 ONOFF 0.00269255194 44,995.00 -5.917 10.714 ONOFF 0.00380250386 7,499.00 -5.572 8.923 REF 0.01290846412 2,993.00 -4.350 8.004

C-43TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
------------------------ Equipment Type=VALVE SERVICE=G ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.01376394811 3,498.00 -4.286 8.160 ONOFF 0.01612628141 49,998.00 -4.127 10.820 ONOFF 0.04505624603 64,998.00 -3.100 11.082

N = 136

----------------------- Equipment Type=VALVE SERVICE=HL ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00000007416 22.00 -16.417 3.091 REF 0.00000024878 31.00 -15.207 3.434 REF 0.00000384555 28.00 -12.469 3.332 REF 0.00000417178 23.50 -12.387 3.157 REF 0.00000515059 30.50 -12.176 3.418 REF 0.00000583507 18.50 -12.052 2.918 ONOFF 0.00001043273 120.00 -11.471 4.787 REF 0.00002810986 121.00 -10.479 4.796 REF 0.00003200898 505.00 -10.349 6.225 REF 0.00003625011 122.50 -10.225 4.808 REF 0.00004638030 42.00 -9.979 3.738 REF 0.00007379116 167.00 -9.514 5.118 REF 0.00012682573 92.00 -8.973 4.522 REF 0.00022685294 183.00 -8.391 5.209 REF 0.00025173728 290.00 -8.287 5.670 REF 0.00028499501 464.00 -8.163 6.140 REF 0.00031120838 540.00 -8.075 6.292 REF 0.00040606459 446.00 -7.809 6.100 REF 0.00042830899 956.50 -7.756 6.863 REF 0.00047713871 2,097.50 -7.648 7.649 REF 0.00049600835 2,993.00 -7.609 8.004 REF 0.00223700445 11,494.00 -6.103 9.350 REF 0.01003356618 1,996.00 -4.602 7.599

N = 23

C-44TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
----------------------- Equipment Type=VALVE SERVICE=LL ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00000045360 510.00 -14.606 6.234 REF 0.00000067060 46.50 -14.215 3.839 ONOFF 0.00000090719 3,210.00 -13.913 8.074 REF 0.00000097029 5.50 -13.846 1.705 REF 0.00000097655 51.00 -13.839 3.932 REF 0.00000124345 5.50 -13.598 1.705 REF 0.00000157471 31.50 -13.361 3.450 ONOFF 0.00000181439 8.75 -13.220 2.169 ONOFF 0.00000181439 26.00 -13.220 3.258 REF 0.00000189545 50.00 -13.176 3.912 REF 0.00000203465 26.00 -13.105 3.258 MT 0.00000205103 4.25 -13.097 1.447 REF 0.00000209952 15.00 -13.074 2.708 REF 0.00000232450 23.50 -12.972 3.157 MT 0.00000237776 10.00 -12.949 2.303 REF 0.00000248467 33.50 -12.905 3.512 REF 0.00000401492 136.00 -12.425 4.913 MT 0.00000447800 11.50 -12.316 2.442 REF 0.00000502041 80.00 -12.202 4.382 ONOFF 0.00000635036 274.00 -11.967 5.613 REF 0.00000640298 128.50 -11.959 4.856 ONOFF 0.00000816475 49.00 -11.716 3.892 REF 0.00000834528 51.00 -11.694 3.932 ONOFF 0.00000861834 89.00 -11.662 4.489 MT 0.00000862560 524.00 -11.661 6.261 REF 0.00000895128 119.50 -11.624 4.783 MT 0.00000984079 18.00 -11.529 2.890 ONOFF 0.00000997913 142.00 -11.515 4.956 REF 0.00001072938 60.00 -11.443 4.094 REF 0.00001154767 17.00 -11.369 2.833 REF 0.00001223850 3.50 -11.311 1.253 MT 0.00001432233 59.50 -11.154 4.086 ONOFF 0.00001496870 15.50 -11.110 2.741 MT 0.00001524449 22.00 -11.091 3.091 MT 0.00001602150 34.00 -11.042 3.526 MT 0.00001613626 28.50 -11.034 3.350 REF 0.00001662116 173.00 -11.005 5.153 ONOFF 0.00001769028 339.00 -10.942 5.826 REF 0.00001839744 47.50 -10.903 3.861 ONOFF 0.00002086546 1,197.00 -10.777 7.088 ONOFF 0.00002131906 148.00 -10.756 4.997 ONOFF 0.00002267985 298.00 -10.694 5.697 MT 0.00002288442 74.00 -10.685 4.304 ONOFF 0.00002358705 59.00 -10.655 4.078 ONOFF 0.00002404064 210.00 -10.636 5.347

C-45TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
----------------------- Equipment Type=VALVE SERVICE=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

MT 0.00002413726 588.00 -10.632 6.377 ONOFF 0.00002449424 1,398.00 -10.617 7.243 MT 0.00002719722 75.00 -10.512 4.317 ONOFF 0.00002721582 8,960.00 -10.512 9.101 REF 0.00002937177 646.00 -10.435 6.471 ONOFF 0.00003175179 2,497.00 -10.358 7.823 REF 0.00003262633 176.00 -10.330 5.170 MT 0.00003474508 45.00 -10.267 3.807 ONOFF 0.00003492697 1,143.00 -10.262 7.041 MT 0.00003817473 119.00 -10.173 4.779 MT 0.00003920348 181.00 -10.147 5.198 REF 0.00004325547 400.50 -10.048 5.993 ONOFF 0.00004399891 441.00 -10.031 6.089 MT 0.00004902930 116.00 -9.923 4.754 MT 0.00005014515 109.00 -9.901 4.691 REF 0.00005050349 447.50 -9.893 6.104 MT 0.00005156491 22.00 -9.873 3.091 ONOFF 0.00005352445 1,998.00 -9.835 7.600 MT 0.00005386918 205.00 -9.829 5.323 MT 0.00005803320 691.00 -9.754 6.538 MT 0.00005873628 124.00 -9.742 4.820 REF 0.00005976594 108.80 -9.725 4.690 REF 0.00005993377 793.00 -9.722 6.676 REF 0.00006152590 100.00 -9.696 4.605 MT 0.00006221537 116.00 -9.685 4.754 REF 0.00006287762 2,496.00 -9.674 7.822 MT 0.00006335843 61.00 -9.667 4.111 MT 0.00006978137 71.50 -9.570 4.270 ONOFF 0.00007575070 3,249.00 -9.488 8.086 ONOFF 0.00007756509 272.00 -9.464 5.606 REF 0.00007775560 2,645.50 -9.462 7.881 REF 0.00008625601 26.50 -9.358 3.277 REF 0.00008785721 192.00 -9.340 5.257 ONOFF 0.00009026581 193.00 -9.313 5.263 ONOFF 0.00009661617 2,246.00 -9.245 7.717 REF 0.00009754604 74.00 -9.235 4.304 ONOFF 0.00010342012 17,499.00 -9.177 9.770 REF 0.00010648644 1,196.00 -9.147 7.087 REF 0.00011324050 595.00 -9.086 6.389 MT 0.00012015785 496.50 -9.027 6.208 REF 0.00012067949 5,000.00 -9.022 8.517 REF 0.00012075660 224.00 -9.022 5.412 REF 0.00013744443 23,996.00 -8.892 10.086 ONOFF 0.00014106867 2,998.00 -8.866 8.006

C-46TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
----------------------- Equipment Type=VALVE SERVICE=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

MT 0.00014320058 132.00 -8.851 4.883 REF 0.00015138801 796.50 -8.796 6.680 REF 0.00015260365 2,096.50 -8.788 7.648 REF 0.00015486256 1,044.00 -8.773 6.951 ONOFF 0.00016102694 3,950.00 -8.734 8.281 ONOFF 0.00016374853 798.00 -8.717 6.682 REF 0.00016769028 894.00 -8.693 6.796 ONOFF 0.00016783090 1,997.00 -8.693 7.599 ONOFF 0.00018461399 1,995.00 -8.597 7.598 ONOFF 0.00018461399 2,244.00 -8.597 7.716 ONOFF 0.00019867550 2,998.00 -8.524 8.006 ONOFF 0.00020185068 1,344.00 -8.508 7.203 ONOFF 0.00021545859 596.00 -8.443 6.390 REF 0.00021628867 1,348.00 -8.439 7.206 REF 0.00022579153 3,493.00 -8.396 8.159 REF 0.00022907557 568.00 -8.381 6.342 MT 0.00023388370 20,897.00 -8.361 9.947 MT 0.00024798603 2,744.00 -8.302 7.917 REF 0.00025930781 12,145.50 -8.257 9.405 REF 0.00026239681 2,736.00 -8.246 7.914 ONOFF 0.00027306541 8,450.00 -8.206 9.042 MT 0.00027484804 4,996.50 -8.199 8.516 REF 0.00028502676 1,345.00 -8.163 7.204 REF 0.00028960809 1,248.00 -8.147 7.129 REF 0.00029077384 372.50 -8.143 5.920 MT 0.00029242947 187.50 -8.137 5.234 REF 0.00029891137 105.00 -8.115 4.654 REF 0.00029939672 794.00 -8.114 6.677 MT 0.00031903747 52.50 -8.050 3.961 REF 0.00032606822 4,997.50 -8.028 8.517 ONOFF 0.00032704345 498.00 -8.025 6.211 ONOFF 0.00033611540 253.50 -7.998 5.535 REF 0.00035377846 34,996.50 -7.947 10.463 REF 0.00035974780 2,240.00 -7.930 7.714 ONOFF 0.00036106323 198.00 -7.926 5.288 MT 0.00036868820 4,545.00 -7.906 8.422 ONOFF 0.00037240316 975.00 -7.896 6.882 MT 0.00041536787 3,243.00 -7.786 8.084 MT 0.00042058423 4,246.50 -7.774 8.354 MT 0.00043848771 21,994.00 -7.732 9.999 REF 0.00044372675 42,745.50 -7.720 10.663 REF 0.00045395990 893.00 -7.698 6.795 REF 0.00046035562 20,246.50 -7.684 9.916 REF 0.00046933684 796.00 -7.664 6.680

C-47TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
----------------------- Equipment Type=VALVE SERVICE=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.00047251202 8,490.00 -7.657 9.047 REF 0.00047945205 3,996.00 -7.643 8.293 REF 0.00049981856 159.50 -7.601 5.072 ONOFF 0.00052617255 19,998.00 -7.550 9.903 REF 0.00057253016 674.00 -7.465 6.513 REF 0.00060782001 23,994.50 -7.406 10.086 REF 0.00061521364 1,598.00 -7.394 7.377 MT 0.00062442166 2,147.50 -7.379 7.672 REF 0.00063122562 2,992.00 -7.368 8.004 REF 0.00066533612 133.50 -7.315 4.894 REF 0.00068511295 995.00 -7.286 6.903 ONOFF 0.00070443618 19,994.00 -7.258 9.903 MT 0.00071074118 8,091.00 -7.249 8.999 ONOFF 0.00075932142 54,997.00 -7.183 10.915 REF 0.00095572893 39,996.50 -6.953 10.597 REF 0.00098348907 1,695.00 -6.924 7.435 ONOFF 0.00102558287 54,995.00 -6.882 10.915 MT 0.00103914542 2,745.00 -6.869 7.918 REF 0.00107547854 474.00 -6.835 6.161 REF 0.00113353896 10,997.00 -6.782 9.305 ONOFF 0.00114669328 2,982.00 -6.771 8.000 ONOFF 0.00118570262 2,998.00 -6.737 8.006 MT 0.00134518734 2,257.50 -6.611 7.722 REF 0.00134786356 79,997.00 -6.609 11.290 ONOFF 0.00135444071 1,046.00 -6.604 6.953 REF 0.00135698086 7,497.00 -6.602 8.922 REF 0.00153742175 21,495.00 -6.478 9.976 MT 0.00160918080 5,434.00 -6.432 8.600 ONOFF 0.00169010251 2,740.00 -6.383 7.916 REF 0.00183253198 6,690.00 -6.302 8.808 MT 0.00188274517 8,994.00 -6.275 9.104 MT 0.00197233058 5,494.00 -6.229 8.611 REF 0.00213984396 15,998.50 -6.147 9.680 ONOFF 0.00223351175 54,998.00 -6.104 10.915 MT 0.00239059240 3,844.00 -6.036 8.254 ONOFF 0.00247028939 42,492.00 -6.003 10.657 ONOFF 0.00256236959 2,496.00 -5.967 7.822 REF 0.00258328041 1,004.00 -5.959 6.912 MT 0.00279048353 3,389.00 -5.882 8.128 MT 0.00305193686 3,302.00 -5.792 8.102 REF 0.00312115577 1,243.00 -5.770 7.125 REF 0.00471287308 2,498.00 -5.357 7.823 REF 0.00601378935 25,895.50 -5.114 10.162 REF 0.01730744806 25,490.00 -4.057 10.146

C-48TABLE C-1-1. BAGGING DATA USED TO DEVELOP CORRELATION EQUATIONS (CONTINUED)

Table C-1-1. Bagging Data Used to Develop Correlation Equations
----------------------- Equipment Type=VALVE SERVICE=LL ------------------------ (continued)

Natural Natural Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

REF 0.02037603193 72,924.00 -3.893 11.197

N = 178

------------------------ Equipment Type=VENT SERVICE=G -------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00000952554 99.00 -11.562 4.595 ONOFF 0.00005261725 1,998.00 -9.852 7.600 ONOFF 0.00033883698 894.00 -7.990 6.796

N=3

------------------------ Equipment Type=VENT SERVICE=LL ------------------------

Natural Natural

Log of Log of Measured Emission Screening Plant Emission Screening Rate Value Type Rate(kg/hr) Value (ppmv) (kg/hr) (ppmv)

ONOFF 0.00010478091 1,496.00 -9.164 7.311 ONOFF 0.00014877982 396.00 -8.813 5.981 ONOFF 0.00093168829 3,497.00 -6.979 8.160

N=3

C-49Table C-1-2. REGRESSION STATISTICS FOR THE 1993 REFINERY, MARKETING TERMINAL, AND OILAND GAS PRODUCTION OPERATIONS DATAEquipmentFacilityTypeaSampleSizeIntercept(b0)Slope(b1)Root MeanSquareError(RMSE)Coefficientof SimpleDetermination(R2)Scale BiasCorrectionFactor(SBCF)Mean lnScreeningValueSum of SquaredDeviations fromthe Mean lnScreening ValueTypeServiceConnectorLightLiquidREF9318-18.013551.0051.9600.73535.25957.12669169.2060MT9321-12.572360.5601.1440.34561.82935.2817341.9152OAG9342-15.955230.8601.5640.52233.19566.40961144.7306FlangeLightLiquidREF9315-14.916630.8911.3160.75032.15046.7916085.2498MT9312-10.411030.2371.7480.04133.52505.0021123.3301OAG9313-12.884580.4301.7150.17213.43475.7399236.3270Open-EndedLineLightLiquidREF9315-16.360680.9071.6930.59663.42936.9795466.9792MT9316-14.013550.9951.6140.73723.11604.71076103.1866OAG9339-14.595190.6681.9290.42185.67606.50333225.1838PumpLightLiquidREF9330-10.076070.4191.5790.32813.18826.71261194.3916MT9311-11.407180.5271.6170.51282.29854.4534089.1903ValveGasREF9350-13.946240.6751.2450.57252.11246.22836218.6160OAG9384-15.209990.8581.7080.52964.12286.92689365.7776ValveLightLiquidREF9382-14.178540.7831.4530.63402.79956.56265476.8908MT9345-13.291120.7051.0710.70361.73925.89259235.3645OAG9351-13.795700.6331.6350.39493.59077.02241213.3342aFacility types are: REF93=1993 refinery data, MT93=1993 marketing terminal data, andOAG93=1993 oil and gas production operations data

C-50Table C-1-3. 1980 Refinery Data

--------------------- Equipment Type=CONNECTOR SERVICE=ALL ---------------------

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00002862 68.49 135.17 -10.461 4.227 4.907 0.00007993 287.96 611.03 -9.434 5.663 6.415 0.00011026 43.00 82.89 -9.113 3.761 4.418 0.00011643 336.64 719.98 -9.058 5.819 6.579 0.00015369 576.42 1,266.67 -8.781 6.357 7.144 0.00021599 199.00 414.48 -8.440 5.293 6.027 0.00021940 21.47 39.96 -8.425 3.066 3.688 0.00022339 289.36 614.14 -8.407 5.668 6.420 0.00029047 1,447.68 3,332.47 -8.144 7.278 8.111 0.00031247 914.91 2,057.90 -8.071 6.819 7.629 0.00044767 425.98 921.92 -7.711 6.054 6.826 0.00045162 451.40 979.81 -7.703 6.112 6.887 0.00045829 914.48 2,056.87 -7.688 6.818 7.629 0.00058280 214.08 447.53 -7.448 5.366 6.104 0.00061930 398.97 860.61 -7.387 5.989 6.758 0.00062396 912.27 2,051.66 -7.379 6.816 7.626 0.00062744 677.13 1,500.12 -7.374 6.518 7.313 0.00084939 106.60 215.14 -7.071 4.669 5.371 0.00085546 582.26 1,280.16 -7.064 6.367 7.155 0.00087692 1,959.67 4,580.42 -7.039 7.581 8.430 0.00089035 921.20 2,072.75 -7.024 6.826 7.637 0.00117035 4,529.79 11,044.58 -6.750 8.418 9.310 0.00170106 198.70 413.81 -6.377 5.292 6.025 0.00173544 726.19 1,614.50 -6.356 6.588 7.387 0.00177404 3,302.89 7,925.90 -6.334 8.103 8.978 0.00179269 2,290.01 5,394.75 -6.324 7.736 8.593 0.00179403 999.45 2,258.09 -6.323 6.907 7.722 0.00231632 4,214.88 10,239.49 -6.068 8.346 9.234 0.00242557 2,860.43 6,814.53 -6.022 7.959 8.827 0.00342813 3,385.21 8,133.54 -5.676 8.127 9.004 0.00342813 3,385.21 8,133.54 -5.676 8.127 9.004 0.00467383 3,933.75 9,523.33 -5.366 8.277 9.161 0.00468673 3,933.74 9,523.31 -5.363 8.277 9.161 0.00468673 3,933.74 9,523.31 -5.363 8.277 9.161 0.00670911 496.56 1,083.02 -5.004 6.208 6.988 0.00956087 1,981.92 4,635.07 -4.650 7.592 8.441 0.00988148 4,890.96 11,971.40 -4.617 8.495 9.390 0.01433650 4,984.13 12,211.05 -4.245 8.514 9.410

N = 38

C-51Table C-1-3. 1980 Refinery Data (Con’t.)

----------------------- Equipment Type=DRAIN SERVICE=ALL -----------------------

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00000165 124.56 253.38 -13.318 4.825 5.535 0.00001587 124.20 252.60 -11.051 4.822 5.532 0.00002657 125.41 255.18 -10.536 4.832 5.542 0.00006707 306.36 652.11 -9.610 5.725 6.480 0.00016828 1,084.56 2,460.50 -8.690 6.989 7.808 0.00025242 110.79 224.04 -8.284 4.708 5.412 0.00066593 4.88 8.44 -7.314 1.586 2.133 0.00067665 247.44 521.05 -7.298 5.511 6.256 0.00109637 255.86 539.70 -6.816 5.545 6.291 0.00111300 1,093.11 2,480.86 -6.801 6.997 7.816 0.00163974 9,675.85 24,512.03 -6.413 9.177 10.107 0.00164782 84.27 168.08 -6.408 4.434 5.124 0.00168344 249.76 526.17 -6.387 5.520 6.266 0.00168969 249.75 526.16 -6.383 5.520 6.266 0.00169157 1,095.50 2,486.57 -6.382 6.999 7.819 0.00169595 249.75 526.16 -6.380 5.520 6.266 0.00170673 337.53 721.97 -6.373 5.822 6.582 0.00263438 344.99 738.73 -5.939 5.844 6.605 0.00271318 126.27 257.03 -5.910 4.838 5.549 0.00282061 85.42 170.48 -5.871 4.448 5.139 0.00286144 205.12 427.86 -5.856 5.324 6.059 0.00414221 3,256.12 7,808.06 -5.487 8.088 8.963 0.00414368 1,082.80 2,456.31 -5.486 6.987 7.806 0.00420110 345.22 739.25 -5.472 5.844 6.606 0.00428421 255.41 538.69 -5.453 5.543 6.289 0.00433189 204.22 425.90 -5.442 5.319 6.054 0.00690873 1,213.08 2,767.64 -4.975 7.101 7.926 0.00691392 209.53 437.53 -4.974 5.345 6.081 0.00696835 413.59 893.79 -4.966 6.025 6.795 0.00716594 252.19 531.56 -4.938 5.530 6.276 0.00716625 252.52 532.30 -4.938 5.531 6.277 0.00719254 252.19 531.55 -4.935 5.530 6.276 0.00722439 2,659.82 6,313.44 -4.930 7.886 8.750 0.01088314 672.51 1,489.38 -4.521 6.511 7.306 0.01097489 254.74 537.20 -4.512 5.540 6.286 0.01097489 254.74 537.20 -4.512 5.540 6.286 0.01117409 610.07 1,344.46 -4.494 6.414 7.204 0.01119616 414.95 896.86 -4.492 6.028 6.799 0.01147153 2,922.21 6,969.21 -4.468 7.980 8.849 0.01147253 2,929.91 6,988.51 -4.468 7.983 8.852 0.01673968 254.28 536.20 -4.090 5.538 6.285 0.01673968 254.28 536.20 -4.090 5.538 6.285 0.01748345 600.96 1,323.40 -4.047 6.399 7.188 0.01761340 600.95 1,323.36 -4.039 6.399 7.188 0.01778718 414.14 895.03 -4.029 6.026 6.797

C-52Table C-1-3. 1980 Refinery Data (Con’t.)

----------------------- Equipment Type=DRAIN SERVICE=ALL -----------------------

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.01794441 9,705.86 24,591.90 -4.020 9.180 10.110 0.02777731 9,675.31 24,510.60 -3.584 9.177 10.107 0.02864463 2,945.66 7,027.99 -3.553 7.988 8.858 0.04440422 2,195.64 5,161.48 -3.114 7.694 8.549 0.04565131 1,658.94 3,845.08 -3.087 7.414 8.255 0.11170747 2,216.10 5,212.02 -2.192 7.704 8.559 0.11520974 9,757.82 24,730.22 -2.161 9.186 10.116 0.28962977 9,643.68 24,426.45 -1.239 9.174 10.103 0.28962977 9,643.68 24,426.45 -1.239 9.174 10.103 0.28965511 9,669.08 24,494.01 -1.239 9.177 10.106 0.43111208 2,966.41 7,079.99 -0.841 7.995 8.865 0.43111208 2,966.41 7,079.99 -0.841 7.995 8.865 1.12802623 9,741.28 24,686.17 0.120 9.184 10.114 1.14068097 9,753.65 24,719.09 0.132 9.185 10.115 1.77893548 9,735.45 24,670.65 0.576 9.184 10.113 1.78553430 9,735.29 24,670.24 0.580 9.184 10.113

N = 61

C-53Table C-1-3. 1980 Refinery Data (Con’t.)

------------------------ Equipment Type=PUMP SERVICE=HL ------------------------

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00002962 8.11 14.37 -10.427 2.093 2.665 0.00003944 90.04 180.18 -10.141 4.500 5.194 0.00015933 330.36 705.88 -8.745 5.800 6.559 0.00030611 115.55 234.17 -8.092 4.750 5.456 0.00043153 181.88 377.09 -7.748 5.203 5.932 0.00043691 711.47 1,580.13 -7.736 6.567 7.365 0.00044418 712.29 1,582.04 -7.719 6.568 7.366 0.00044597 198.46 413.29 -7.715 5.291 6.024 0.00089174 257.29 542.85 -7.022 5.550 6.297 0.00121225 713.23 1,584.25 -6.715 6.570 7.368 0.00121225 713.23 1,584.25 -6.715 6.570 7.368 0.00121559 714.87 1,588.07 -6.713 6.572 7.370 0.00121579 607.33 1,338.12 -6.712 6.409 7.199 0.00125953 913.98 2,055.71 -6.677 6.818 7.628 0.00168810 3,960.24 9,590.69 -6.384 8.284 9.169 0.00178173 710.83 1,578.63 -6.330 6.566 7.364 0.00180113 846.36 1,896.25 -6.319 6.741 7.548 0.00183552 1,188.93 2,709.80 -6.300 7.081 7.905 0.00242435 789.16 1,761.85 -6.022 6.671 7.474 0.00244487 661.26 1,463.22 -6.014 6.494 7.288 0.00245776 844.47 1,891.79 -6.009 6.739 7.545 0.00250471 1,176.77 2,680.70 -5.990 7.071 7.894 0.00251852 1,179.48 2,687.17 -5.984 7.073 7.896 0.00345651 916.25 2,061.05 -5.667 6.820 7.631 0.00479664 10,438.79 26,546.18 -5.340 9.253 10.187 0.00481697 2,376.33 5,608.57 -5.336 7.773 8.632 0.00483651 648.56 1,433.70 -5.332 6.475 7.268 0.00697471 504.98 1,102.31 -4.965 6.225 7.005 0.00962437 425.60 921.06 -4.643 6.053 6.826 0.00978532 392.28 845.47 -4.627 5.972 6.740 0.00986119 10,464.10 26,613.82 -4.619 9.256 10.189 0.00986121 10,440.11 26,549.72 -4.619 9.253 10.187 0.00995942 1,982.33 4,636.09 -4.609 7.592 8.442 0.00996275 1,422.56 3,271.75 -4.609 7.260 8.093 0.01438591 4,733.39 11,566.60 -4.242 8.462 9.356 0.01931711 3,127.43 7,484.21 -3.947 8.048 8.921 0.01950717 10,513.52 26,745.84 -3.937 9.260 10.194 0.01966882 10,513.54 26,745.91 -3.929 9.260 10.194 0.01970286 1,861.25 4,339.10 -3.927 7.529 8.375 0.02633481 506.84 1,106.58 -3.637 6.228 7.009 0.02731456 3,677.22 8,872.08 -3.600 8.210 9.091 0.02754090 3,681.46 8,882.81 -3.592 8.211 9.092 0.02775928 5,249.27 12,894.31 -3.584 8.566 9.465 0.02815822 199.52 415.60 -3.570 5.296 6.030 0.02818559 1,184.04 2,698.10 -3.569 7.077 7.900

C-54Table C-1-3. 1980 Refinery Data (Con’t.)

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.02842387 1,003.61 2,267.96 -3.561 6.911 7.727 0.02850212 1,003.61 2,267.96 -3.558 6.911 7.727 0.02850212 1,004.76 2,270.70 -3.558 6.913 7.728 0.02859211 10,538.38 26,812.30 -3.555 9.263 10.197 0.02859211 10,538.38 26,812.30 -3.555 9.263 10.197 0.03691188 1,018.75 2,303.91 -3.299 6.926 7.742 0.03917114 3,092.10 7,395.43 -3.240 8.037 8.909 0.03955608 10,526.89 26,781.58 -3.230 9.262 10.195 0.05258516 2,621.03 6,216.74 -2.945 7.871 8.735 0.05616945 2,837.15 6,756.30 -2.879 7.951 8.818 0.07550022 10,588.68 26,946.74 -2.584 9.268 10.202 0.11098012 9,451.61 23,915.68 -2.198 9.154 10.082 0.11374890 10,589.44 26,948.76 -2.174 9.268 10.202 0.15479117 10,565.72 26,885.35 -1.866 9.265 10.199 0.30036837 10,506.45 26,726.96 -1.203 9.260 10.193 0.30369119 10,518.53 26,759.24 -1.192 9.261 10.195

N = 61

C-55Table C-1-3. 1980 Refinery Data (Con’t.)

------------------- Equipment Type=P_CS_PRV SERVICE=LL_G_TPS -------------------

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00004237 3,392.48 8,151.87 -10.069 8.129 9.006 0.00006298 136.58 279.12 -9.673 4.917 5.632 0.00006364 1,886.21 4,400.25 -9.662 7.542 8.389 0.00006397 1,534.24 3,542.06 -9.657 7.336 8.172 0.00010622 170.88 353.17 -9.150 5.141 5.867 0.00016673 3,408.70 8,192.83 -8.699 8.134 9.011 0.00017201 594.94 1,309.46 -8.668 6.388 7.177 0.00041408 374.65 805.59 -7.789 5.926 6.692 0.00041408 374.65 805.59 -7.789 5.926 6.692 0.00042163 1,089.97 2,473.39 -7.771 6.994 7.813 0.00043552 35.08 66.94 -7.739 3.558 4.204 0.00068080 268.97 568.78 -7.292 5.595 6.343 0.00068243 193.58 402.61 -7.290 5.266 5.998 0.00104082 3,463.88 8,332.20 -6.868 8.150 9.028 0.00105002 1,716.27 3,984.79 -6.859 7.448 8.290 0.00105273 1,205.32 2,749.04 -6.856 7.094 7.919 0.00105947 3,814.46 9,220.20 -6.850 8.247 9.129 0.00106711 24.55 46.02 -6.843 3.201 3.829 0.00107106 24.55 46.02 -6.839 3.201 3.829 0.00108841 431.13 933.64 -6.823 6.066 6.839 0.00108885 245.52 516.81 -6.823 5.503 6.248 0.00167903 970.51 2,189.47 -6.390 6.878 7.691 0.00170760 1,207.89 2,755.21 -6.373 7.097 7.921 0.00173961 431.38 934.21 -6.354 6.067 6.840 0.00254547 685.07 1,518.60 -5.973 6.530 7.326 0.00259400 4,915.33 12,034.08 -5.955 8.500 9.395 0.00259443 1,742.04 4,047.66 -5.954 7.463 8.306 0.00263011 15,437.18 40,039.38 -5.941 9.645 10.598 0.00264161 3,073.11 7,347.73 -5.936 8.030 8.902 0.00268912 1,216.00 2,774.64 -5.919 7.103 7.928 0.00271908 1,216.01 2,774.68 -5.907 7.103 7.928 0.00272186 383.07 824.63 -5.906 5.948 6.715 0.00399588 13,479.04 34,722.28 -5.522 9.509 10.455 0.00405129 1,224.09 2,794.03 -5.509 7.110 7.935 0.00406909 3,070.07 7,340.09 -5.504 8.029 8.901 0.00416407 34,171.65 92,254.02 -5.481 10.439 11.432 0.00423609 1,952.06 4,561.75 -5.464 7.577 8.425 0.00423609 1,952.06 4,561.75 -5.464 7.577 8.425 0.00641761 549.40 1,204.39 -5.049 6.309 7.094 0.00646354 11,933.39 30,552.46 -5.042 9.387 10.327 0.00655481 1,738.73 4,039.58 -5.028 7.461 8.304 0.00656223 2,472.04 5,846.08 -5.026 7.813 8.674 0.00656741 6,115.18 15,137.41 -5.026 8.719 9.625 0.00658649 6,816.89 16,967.08 -5.023 8.827 9.739 0.00665525 34,348.91 92,756.76 -5.012 10.444 11.438

C-56Table C-1-3. 1980 Refinery Data (Con’t.)

------------------- Equipment Type=P_CS_PRV SERVICE=LL_G_TPS ------------------- (continued)

Natural Natural Natural Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00672364 3,057.93 7,309.60 -5.002 8.025 8.897 0.00673458 18,598.42 48,693.93 -5.001 9.831 10.793 0.00679853 3,057.97 7,309.71 -4.991 8.026 8.897 0.00684900 3,053.32 7,298.03 -4.984 8.024 8.895 0.00690833 1,550.34 3,581.13 -4.975 7.346 8.183 0.01031255 158.23 325.77 -4.574 5.064 5.786 0.01036867 11,977.05 30,669.89 -4.569 9.391 10.331 0.01058991 3,017.82 7,208.93 -4.548 8.012 8.883 0.01085059 17,055.40 44,459.47 -4.524 9.744 10.702 0.01088011 1,544.12 3,566.03 -4.521 7.342 8.179 0.01088011 1,544.12 3,566.03 -4.521 7.342 8.179 0.01580135 18,934.25 49,617.93 -4.148 9.849 10.812 0.01593600 776.04 1,731.11 -4.139 6.654 7.457 0.01650647 34,388.01 92,867.66 -4.104 10.445 11.439 0.01656751 34,388.09 92,867.88 -4.100 10.445 11.439 0.01689730 3,810.16 9,209.28 -4.081 8.245 9.128 0.01692011 24,077.03 63,863.87 -4.079 10.089 11.065 0.01719892 1,535.57 3,545.31 -4.063 7.337 8.173 0.01719892 1,535.57 3,545.31 -4.063 7.337 8.173 0.02585373 3,477.82 8,367.42 -3.655 8.154 9.032 0.02593482 17,205.09 44,869.44 -3.652 9.753 10.712 0.02608028 60,696.69 168,680.19 -3.647 11.014 12.036 0.02608058 60,603.82 168,409.10 -3.647 11.012 12.034 0.02627388 60,604.52 168,411.13 -3.639 11.012 12.034 0.02639205 1,560.08 3,604.77 -3.635 7.352 8.190 0.02646313 4,937.17 12,090.24 -3.632 8.505 9.400 0.02686162 1,747.13 4,060.09 -3.617 7.466 8.309 0.02686725 21,446.53 56,555.63 -3.617 9.973 10.943 0.02690520 305.39 649.94 -3.615 5.722 6.477 0.02699393 2,453.79 5,800.75 -3.612 7.805 8.666 0.02749516 6,829.08 16,998.96 -3.594 8.829 9.741 0.02757885 34,200.07 92,334.61 -3.591 10.440 11.433 0.02757885 34,200.07 92,334.61 -3.591 10.440 11.433 0.02768154 34,095.81 92,038.95 -3.587 10.437 11.430 0.02778396 34,095.89 92,039.17 -3.583 10.437 11.430 0.02780143 6,829.17 16,999.20 -3.583 8.829 9.741 0.02813742 6,005.66 14,852.78 -3.571 8.700 9.606 0.02824146 6,005.69 14,852.85 -3.567 8.700 9.606 0.03877057 30,226.79 81,100.81 -3.250 10.316 11.303 0.03927627 8,464.05 21,297.97 -3.237 9.044 9.966 0.03996025 6,008.29 14,859.61 -3.220 8.701 9.606 0.03999937 690.59 1,531.47 -3.219 6.538 7.334 0.04005716 54,394.88 150,333.83 -3.217 10.904 11.921 0.04060862 38,084.57 103,381.36 -3.204 10.548 11.546

C-57Table C-1-3. 1980 Refinery Data (Con’t.)

------------------- Equipment Type=P_CS_PRV SERVICE=LL_G_TPS ------------------- (continued)

Natural Natural Natural Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.04060908 38,026.29 103,215.21 -3.204 10.546 11.545 0.04187031 11,943.02 30,578.34 -3.173 9.388 10.328 0.04256917 9,349.99 23,645.64 -3.157 9.143 10.071 0.04256917 9,349.99 23,645.64 -3.157 9.143 10.071 0.04283001 2,432.76 5,748.56 -3.151 7.797 8.657 0.04283051 2,429.05 5,739.33 -3.151 7.795 8.655 0.06487572 24,414.57 64,804.64 -2.735 10.103 11.079 0.06532933 42,937.13 117,260.65 -2.728 10.667 11.672 0.06538471 38,223.99 103,778.94 -2.727 10.551 11.550 0.06581353 42,937.52 117,261.79 -2.721 10.668 11.672 0.06772129 3,881.55 9,390.62 -2.692 8.264 9.147 0.06798752 494.31 1,077.85 -2.688 6.203 6.983 0.06842301 4,313.78 10,492.02 -2.682 8.370 9.258 0.06849158 494.31 1,077.86 -2.681 6.203 6.983 0.06997327 2,509.90 5,940.16 -2.660 7.828 8.689 0.06997569 2,498.40 5,911.58 -2.660 7.823 8.685 0.09915559 42,959.58 117,325.05 -2.311 10.668 11.673 0.10025896 43,025.90 117,515.33 -2.300 10.670 11.674 0.10120459 4,296.13 10,446.92 -2.291 8.365 9.254 0.10206861 77,307.92 217,480.42 -2.282 11.256 12.290 0.10232039 1,581.97 3,657.91 -2.280 7.366 8.205 0.10262666 60,707.73 168,712.42 -2.277 11.014 12.036 0.10331044 1,930.11 4,507.88 -2.270 7.565 8.414 0.10338849 60,615.54 168,443.32 -2.269 11.012 12.034 0.10383965 12,085.32 30,961.16 -2.265 9.400 10.340 0.10462156 54,460.17 150,523.39 -2.257 10.905 11.922 0.10462397 54,293.77 150,040.32 -2.257 10.902 11.919 0.10699986 6,851.16 17,056.70 -2.235 8.832 9.744 0.10931033 7,637.50 19,118.82 -2.214 8.941 9.858 0.15847552 43,182.52 117,964.71 -1.842 10.673 11.678 0.15898465 76,643.97 215,518.87 -1.839 11.247 12.281 0.16951073 3,042.23 7,270.20 -1.775 8.020 8.892 0.25840755 7,645.71 19,140.43 -1.353 8.942 9.860 0.26302874 3,067.28 7,333.09 -1.335 8.029 8.900 0.26527004 12,081.00 30,949.56 -1.327 9.399 10.340 0.42981364 3,073.86 7,349.62 -0.844 8.031 8.902 1.10801132 30,774.57 82,645.36 0.103 10.334 11.322 1.10801132 30,774.57 82,645.36 0.103 10.334 11.322 1.12449932 30,775.07 82,646.76 0.117 10.334 11.322 N = 128

C-58Table C-1-3. 1980 Refinery Data (Con’t.)

------------------------ Equipment Type=VALVE SERVICE=G ------------------------

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00001331 88.91 177.82 -11.227 4.488 5.181 0.00004011 6,639.19 16,502.81 -10.124 8.801 9.711 0.00005873 1,100.81 2,499.23 -9.743 7.004 7.824 0.00008684 28,723.41 76,869.15 -9.351 10.265 11.250 0.00008847 273.72 579.32 -9.333 5.612 6.362 0.00008852 82.39 164.13 -9.332 4.411 5.101 0.00012745 2,159.55 5,072.40 -8.968 7.678 8.532 0.00026556 4,000.01 9,691.89 -8.234 8.294 9.179 0.00037361 4,327.05 10,525.93 -7.892 8.373 9.262 0.00053159 2,786.15 6,628.77 -7.540 7.932 8.799 0.00056183 9,364.08 23,683.07 -7.484 9.145 10.073 0.00056516 9,364.16 23,683.30 -7.478 9.145 10.073 0.00077033 9,401.02 23,781.23 -7.169 9.149 10.077 0.00079547 3,094.87 7,402.39 -7.137 8.038 8.910 0.00111849 2,001.89 4,684.16 -6.796 7.602 8.452 0.00163767 10,341.06 26,285.19 -6.414 9.244 10.177 0.00164080 8,596.21 21,647.44 -6.413 9.059 9.983 0.00164247 10,364.87 26,348.78 -6.412 9.246 10.179 0.00230073 40,320.51 109,766.16 -6.075 10.605 11.606 0.00230829 3,972.31 9,621.40 -6.071 8.287 9.172 0.00329738 17,115.36 44,623.65 -5.715 9.748 10.706 0.00335895 87,956.92 249,053.14 -5.696 11.385 12.425 0.00339793 67,782.41 189,423.49 -5.685 11.124 12.152 0.00479241 4,409.66 10,737.12 -5.341 8.392 9.281 0.00525603 22,456.91 59,357.68 -5.248 10.019 10.991 0.00740749 48,426.60 133,057.03 -4.905 10.788 11.799 0.01034094 62,802.08 174,831.53 -4.572 11.048 12.072 0.01097916 57,627.00 159,730.80 -4.512 10.962 11.981 0.01099118 29,275.75 78,422.59 -4.511 10.285 11.270 0.01504923 44,686.05 122,282.85 -4.196 10.707 11.714 0.01514346 57,523.86 159,430.51 -4.190 10.960 11.979 0.01518837 57,458.07 159,238.97 -4.187 10.959 11.978 0.03115510 15,704.60 40,768.29 -3.469 9.662 10.616 0.04884917 10,348.47 26,304.97 -3.019 9.245 10.178 0.09161977 17,363.25 45,302.80 -2.390 9.762 10.721 0.09853946 44,817.44 122,660.53 -2.317 10.710 11.717 0.13483362 41,140.73 112,112.87 -2.004 10.625 11.627 0.13594593 10,484.70 26,668.84 -1.995 9.258 10.191

N = 38

C-59Table C-1-3. 1980 Refinery Data (Con’t.)

--------------------- Equipment Type=VALVE SERVICE=LL_TPS ----------------------

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00000225 4.59 7.91 -13.007 1.525 2.068 0.00001410 44.59 86.11 -11.170 3.797 4.456 0.00005956 62.56 122.91 -9.729 4.136 4.811 0.00008638 156.77 322.62 -9.357 5.055 5.776 0.00012792 21.47 39.97 -8.964 3.067 3.688 0.00012930 209.02 436.41 -8.953 5.342 6.079 0.00013197 305.66 650.53 -8.933 5.722 6.478 0.00018238 620.52 1,368.68 -8.609 6.431 7.222 0.00018238 620.52 1,368.68 -8.609 6.431 7.222 0.00018799 22.13 41.25 -8.579 3.097 3.720 0.00019149 84.34 168.23 -8.561 4.435 5.125 0.00026364 64.62 127.17 -8.241 4.169 4.846 0.00027025 976.13 2,202.77 -8.216 6.884 7.697 0.00027125 5,330.54 13,104.08 -8.212 8.581 9.481 0.00039603 484.14 1,054.57 -7.834 6.182 6.961 0.00056453 1,162.25 2,645.96 -7.480 7.058 7.881 0.00060409 9,829.56 24,921.22 -7.412 9.193 10.123 0.00075854 8,440.85 21,236.66 -7.184 9.041 9.963 0.00082319 10.05 18.01 -7.102 2.308 2.891 0.00083585 984.52 2,222.66 -7.087 6.892 7.706 0.00085249 3,206.69 7,683.59 -7.067 8.073 8.947 0.00113007 1,153.61 2,625.30 -6.785 7.051 7.873 0.00118193 10.03 17.96 -6.741 2.305 2.888 0.00120220 3,324.54 7,980.47 -6.724 8.109 8.985 0.00123419 9,979.00 25,319.36 -6.697 9.208 10.139 0.00163290 4,540.59 11,072.23 -6.417 8.421 9.312 0.00168838 1,363.36 3,128.89 -6.384 7.218 8.048 0.00170950 1,796.41 4,180.46 -6.372 7.494 8.338 0.00179606 3,953.18 9,572.75 -6.322 8.282 9.167 0.00241099 5,398.93 13,280.75 -6.028 8.594 9.494 0.00241192 860.44 1,929.39 -6.027 6.757 7.565 0.00243467 3,361.20 8,072.96 -6.018 8.120 8.996 0.00247077 3,354.55 8,056.16 -6.003 8.118 8.994 0.00247366 8,515.22 21,433.26 -6.002 9.050 9.973 0.00248176 3,998.89 9,689.06 -5.999 8.294 9.179 0.00249558 8,515.54 21,434.09 -5.993 9.050 9.973 0.00255458 1,013.43 2,291.28 -5.970 6.921 7.737 0.00341580 39,058.18 106,159.28 -5.679 10.573 11.573 0.00348074 33,787.34 91,164.47 -5.661 10.428 11.420 0.00349794 54,274.02 149,982.99 -5.656 10.902 11.918 0.00353072 8,527.25 21,465.06 -5.646 9.051 9.974 0.00353574 30,014.01 80,501.23 -5.645 10.309 11.296 0.00355244 1,381.43 3,172.46 -5.640 7.231 8.062 0.00357339 1,381.46 3,172.54 -5.634 7.231 8.062 0.00357551 15,739.47 40,863.36 -5.634 9.664 10.618

C-60Table C-1-3. 1980 Refinery Data (Con’t.)

--------------------- Equipment Type=VALVE SERVICE=LL_TPS ---------------------- (continued)

Natural Natural Natural Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00485006 8,625.65 21,725.33 -5.329 9.062 9.986 0.00491615 3,398.24 8,166.42 -5.315 8.131 9.008 0.00491615 3,398.24 8,166.42 -5.315 8.131 9.008 0.00493071 3,391.35 8,149.01 -5.312 8.129 9.006 0.00495259 1,383.25 3,176.85 -5.308 7.232 8.064 0.00516794 9,994.91 25,361.77 -5.265 9.210 10.141 0.00729950 8,551.85 21,530.11 -4.920 9.054 9.977 0.00736431 8,534.69 21,484.75 -4.911 9.052 9.975 0.00739766 1,176.57 2,680.21 -4.907 7.070 7.894 0.00755167 86,029.82 243,324.55 -4.886 11.362 12.402 0.00758374 2,932.48 6,994.95 -4.882 7.984 8.853 0.00758440 24,845.17 66,005.77 -4.882 10.120 11.097 0.00759940 13,655.17 35,199.01 -4.880 9.522 10.469 0.00772423 5,502.03 13,547.27 -4.863 8.613 9.514 0.01046618 86,317.33 244,178.82 -4.560 11.366 12.406 0.01047971 73,754.07 206,991.10 -4.558 11.208 12.240 0.01060438 8,547.05 21,517.41 -4.546 9.053 9.977 0.01066692 8,547.24 21,517.93 -4.541 9.053 9.977 0.01079315 8,547.64 21,518.97 -4.529 9.053 9.977 0.01127245 6,475.35 16,075.28 -4.485 8.776 9.685 0.01166120 5,355.65 13,168.93 -4.451 8.586 9.486 0.01474084 8,540.75 21,500.76 -4.217 9.053 9.976 0.01570609 29,161.44 78,100.99 -4.154 10.281 11.266 0.01605400 24,817.50 65,928.55 -4.132 10.119 11.096 0.02334577 7,507.70 18,777.67 -3.757 8.924 9.840 0.02368390 5,459.20 13,436.52 -3.743 8.605 9.506 0.02368390 5,459.20 13,436.52 -3.743 8.605 9.506 0.03207526 21,746.78 57,387.63 -3.440 9.987 10.958 0.04684899 47,238.27 129,629.48 -3.061 10.763 11.772 0.06870371 62,845.47 174,958.43 -2.678 11.048 12.072 0.10218383 62,944.53 175,248.12 -2.281 11.050 12.074 0.13512360 62,501.44 173,952.50 -2.002 11.043 12.067

N = 77

C-61Table C-1-3. 1980 Refinery Data (Con’t.)

---------------------- Equipment Type=V_CS SERVICE=HYDRO -----------------------

Natural Natural Natural

Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.00000026 499.50 1,089.76 -15.164 6.214 6.994 0.00001464 33,440.21 90,180.89 -11.132 10.418 11.410 0.00002100 354.70 760.60 -10.771 5.871 6.634 0.00002104 1,197.44 2,730.17 -10.769 7.088 7.912 0.00002118 1,974.09 4,615.83 -10.762 7.588 8.437 0.00002933 33,494.85 90,335.66 -10.437 10.419 11.411 0.00003021 7,191.76 17,948.51 -10.407 8.881 9.795 0.00004536 253.47 534.39 -10.001 5.535 6.281 0.00012180 28,416.27 76,005.97 -9.013 10.255 11.239 0.00012180 28,416.27 76,005.97 -9.013 10.255 11.239 0.00012252 28,416.66 76,007.07 -9.007 10.255 11.239 0.00018123 95,583.08 271,783.91 -8.616 11.468 12.513 0.00025613 95,116.75 270,391.26 -8.270 11.463 12.508 0.00026043 4,052.53 9,825.60 -8.253 8.307 9.193 0.00041109 141.22 289.09 -7.797 4.950 5.667 0.00054874 95,287.08 270,899.89 -7.508 11.465 12.510 0.00056055 3,638.51 8,773.98 -7.487 8.199 9.080 0.00110337 28,727.31 76,880.12 -6.809 10.266 11.250 0.00110661 28,727.51 76,880.68 -6.806 10.266 11.250 0.00111311 28,727.91 76,881.80 -6.801 10.266 11.250 0.00118994 1,204.72 2,747.61 -6.734 7.094 7.918 0.00170959 10,318.68 26,225.43 -6.371 9.242 10.174 0.00235967 8,602.88 21,665.09 -6.049 9.060 9.983 0.00509039 94,269.02 267,860.46 -5.280 11.454 12.498 0.00706640 95,751.81 272,287.91 -4.952 11.470 12.515 0.00710793 95,753.13 272,291.86 -4.947 11.470 12.515 0.00712880 95,753.80 272,293.84 -4.944 11.470 12.515 0.01037369 95,729.11 272,220.09 -4.568 11.469 12.514 0.01040414 95,729.77 272,222.06 -4.566 11.469 12.514 0.01046548 95,621.82 271,899.63 -4.560 11.468 12.513 0.01049601 95,731.75 272,227.99 -4.557 11.469 12.514 0.01559018 95,711.47 272,167.42 -4.161 11.469 12.514 0.02089894 95,777.39 272,364.32 -3.868 11.470 12.515 0.02102181 95,778.71 272,368.27 -3.862 11.470 12.515 0.02114537 95,780.04 272,372.22 -3.856 11.470 12.515 0.02120783 95,671.37 272,047.64 -3.853 11.469 12.514 0.02133247 95,672.91 272,052.24 -3.848 11.469 12.514 0.03262723 95,877.79 272,664.22 -3.423 11.471 12.516 0.03337807 10,367.31 26,355.28 -3.400 9.246 10.179 0.04530855 95,188.17 270,604.54 -3.094 11.464 12.508 0.04570873 95,190.15 270,610.43 -3.085 11.464 12.508 0.04584365 95,082.37 270,288.60 -3.083 11.462 12.507 0.06482435 29,370.14 78,688.21 -2.736 10.288 11.273 0.06483958 74,453.14 209,052.45 -2.736 11.218 12.250 0.06535400 95,270.18 270,849.44 -2.728 11.464 12.509

C-62Table C-1-3. 1980 Refinery Data (Con’t.)

---------------------- Equipment Type=V_CS SERVICE=HYDRO ----------------------- (continued)

Natural Natural Natural Log of Log of TLV Log of OVA Measured Original TLV OVA Adjusted Emission Screening Screening Emission Screening Screening Rate Value Value Rate(kg/hr) Value (ppmv) Value (ppmv) (kg/hr) (ppmv (ppmv

0.06612569 95,164.29 270,533.21 -2.716 11.463 12.508 0.06612569 95,164.29 270,533.21 -2.716 11.463 12.508

N = 47

C-63Table C-1-4. REGRESSION STATISTICS FOR THE 1980 AND 1993 REFINERY DATAEquipmentFacilityTypeaSampleSizeIntercept(b0)Slope(b1)RootMeanSquareError(RMSE)Coefficient ofSimpleDetermination(R2)Scale BiasCorrection Factor(SBCF)Mean lnScreeningValueSum ofSquaredDeviationsfrom theMean lnScreeningValueTypeServiceConnectorAllREF8038-12.074970.7591.0110.53331.63346.6923972.8674REF9328-17.455991.0071.8510.72334.77747.04812229.6503PumpLightLiquidbREF80128-10.029980.6761.7260.33714.31338.36906417.3760REF9330-10.076070.4191.5790.32813.18826.71261194.3916ValveGasREF8038-14.931760.9601.7510.47884.21099.15822109.8584REF9350-13.946240.6751.2450.57252.11246.22836218.6160ValveLightLiquidcREF8077-11.464810.6781.2300.61452.09357.98760393.2046REF9382-14.178540.7831.4530.63402.79956.56265476.8908aFacility types are: REF80=1980 refinery data and REF93=1993 refinery databFor light liquid pumps, the 1980 refinery data include two-phase stream pumps, gascompressors, gas pressure relief valves, and light liquid pumps.cFor light liquid valves, the 1980 refinery data include two-phase stream valves andlight liquid valves.C-64APPENDIX C: ATTACHMENT 2 This attachment lists the bagging data used to develop the pegged emission rates for the combined 1993 petroleum industry data in table C-2-1. Table C-2-2 lists summary statistics for the 10,000 ppmv pegged emission rates and Table C-2-3 lists summary statistics for the 100,000 ppmv pegged emission rates.

C-65TABLE C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

--------- Equipment Type=COMPRESSOR SERVICE=G ----------

ONOFF 100000 100000 0.02448289939 -3.710 ONOFF 100000 100000 0.03493150685 -3.354

N=2

---------- Equipment Type=COMPRESSOR SERVICE=LL -----------

ONOFF 100000 100000 0.00101197496 -6.896

N=1

----------- Equipment Type=CONNECTOR SERVICE=G -----------

ONOFF 5000 10000 0.00001270072 -11.274 ONOFF 70000 70000 0.00009344099 -9.278 ONOFF 10000 10000 0.00015104781 -8.798 REF 100000 100000 0.00019804046 -8.527 ONOFF 100000 100000 0.00031933231 -8.049 MT 100000 100000 0.00035811031 -7.935 ONOFF 100000 100000 0.00045858659 -7.687 ONOFF 100000 100000 0.00081556745 -7.112 REF 11000 11000 0.00094198494 -6.968 REF 91000 91000 0.00125365146 -6.682 REF 100000 100000 0.00199886601 -6.215 REF 48000 40000 0.00220312075 -6.118 MT 100000 100000 0.00277519731 -5.887 ONOFF 10000 10000 0.00287262996 -5.853 ONOFF 10000 10000 0.00291935045 -5.836 ONOFF 100000 45000 0.00297922526 -5.816 ONOFF 100000 100000 0.00371632042 -5.595 ONOFF 10000 100000 0.00515513018 -5.268 ONOFF 10000 10000 0.00559920167 -5.185 ONOFF 100000 100000 0.00675269890 -4.998 ONOFF 100000 100000 0.00760364692 -4.879 ONOFF 100000 100000 0.00877029847 -4.736 ONOFF 100000 100000 0.01064229339 -4.543 ONOFF 100000 100000 0.01651047809 -4.104 REF 100000 100000 0.02005624603 -3.909 ONOFF 10000 10000 0.03374716502 -3.389 REF 100000 100000 0.03482899392 -3.357 REF 12500 29000 0.03548852400 -3.339 REF 55000 55000 0.05391454232 -2.920

C-66Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

ONOFF 100000 100000 0.06664383562 -2.708 ONOFF 100000 100000 0.10322462125 -2.271

N = 31

----------- Equipment Type=CONNECTOR SERVICE=HL -----------

REF 76650 21900 0.01362968339 -4.296 REF 1700 1200 0.03207475279 -3.440

N=2
----------- Equipment Type=CONNECTOR SERVICE=LL -----------

ONOFF 100000 100000 0.00000408237 -12.409 ONOFF 10000 5000 0.00001859748 -10.892 REF 21060 17550 0.00001880613 -10.881 ONOFF 10000 10000 0.00002494784 -10.599 REF 16500 27500 0.00006329946 -9.668 ONOFF 10000 10000 0.00006441078 -9.650 ONOFF 100000 100000 0.00010977048 -9.117 ONOFF 10000 10000 0.00027215821 -8.209 ONOFF 100000 100000 0.00038328949 -7.867 ONOFF 100000 100000 0.00040143337 -7.820 REF 48000 100000 0.00062002177 -7.386 ONOFF 10000 10000 0.00063594303 -7.360 REF 90000 90000 0.00082713417 -7.098 ONOFF 100000 100000 0.00088768938 -7.027 ONOFF 10000 10000 0.00092760591 -6.983 REF 72000 80000 0.00117463485 -6.747 REF 117000 117000 0.00119817654 -6.727 ONOFF 4000 10000 0.00153451873 -6.480 ONOFF 10000 10000 0.00185475823 -6.290 ONOFF 100000 100000 0.00198267259 -6.223 ONOFF 10000 10000 0.00259548217 -5.954 REF 100000 100000 0.00275909462 -5.893 REF 47000 47000 0.00283806586 -5.865 REF 117000 117000 0.00303991654 -5.796 REF 49700 56000 0.00337970607 -5.690 ONOFF 10000 10000 0.00383470924 -5.564 ONOFF 5000 10000 0.00396035562 -5.531 ONOFF 100000 50000 0.00445613717 -5.413 ONOFF 100000 100000 0.00489748707 -5.319 ONOFF 100000 100000 0.00597387281 -5.120 REF 90000 90000 0.00711648372 -4.945 ONOFF 10000 10000 0.01034019777 -4.572 ONOFF 100000 100000 0.01055701715 -4.551

C-67Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

ONOFF 10000 10000 0.01699718770 -4.075 REF 20000 35000 0.02082463939 -3.872 ONOFF 100000 100000 0.02084550485 -3.871 ONOFF 100000 100000 0.02378708156 -3.739 REF 66000 66000 0.02872992833 -3.550 ONOFF 100000 100000 0.05975551120 -2.817 ONOFF 100000 100000 0.07526807584 -2.587 ONOFF 40000 50000 0.15713462760 -1.851

N = 41
----------- Equipment Type=DUMP LEVER ARM SERVICE=G -----------

ONOFF 100000 100000 0.39765218180 -0.922

N=1

----------- Equipment Type=FLANGE SERVICE=G -----------

ONOFF 10000 10000 0.00000544316 -12.121 REF 86000 86000 0.00007830899 -9.455 ONOFF 10000 8000 0.00030254922 -8.103 ONOFF 4000 10000 0.00045722580 -7.690 ONOFF 100000 100000 0.00241857933 -6.025 ONOFF 10000 9000 0.00292252563 -5.835 REF 86000 86000 0.00374639390 -5.587 ONOFF 100000 90000 0.00613217817 -5.094 ONOFF 100000 100000 0.01279370407 -4.359 ONOFF 100000 100000 0.01363467296 -4.295 ONOFF 100000 100000 0.01780277601 -4.028 ONOFF 100000 100000 0.01851673773 -3.989 REF 100000 100000 0.02487798240 -3.694 ONOFF 100000 100000 0.03357615894 -3.394 ONOFF 100000 20000 0.04434137712 -3.116 ONOFF 100000 100000 0.06712600925 -2.701 ONOFF 100000 100000 0.09028894130 -2.405 ONOFF 100000 100000 0.10636124467 -2.241

N = 18
----------- Equipment Type=FLANGE SERVICE=LL -----------

ONOFF 100000 100000 0.00015603738 -8.765 REF 18000 22500 0.00095309807 -6.956 REF 30000 40000 0.00125641840 -6.679 REF 13200 9900 0.00344683843 -5.670

C-68Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

ONOFF 100000 60000 0.02859657081 -3.554 ONOFF 100000 100000 0.17639481085 -1.735

N=6

----------- Equipment Type=INSTRUMENT SERVICE=G -----------

ONOFF 30000 30000 0.00028259095 -8.172 ONOFF 100000 100000 0.01809307811 -4.012

N=2

----------- Equipment Type=INSTRUMENT SERVICE=LL -----------

ONOFF 100000 100000 0.00345005897 -5.669

N=1
----------- Equipment Type=LOADARM SERVICE=G -----------

MT 100000 100000 0.00021052799 -8.466 MT 400000 400000 0.04320148780 -3.142 MT 310000 310000 0.04397804590 -3.124 MT 7200 24000 0.04716501860 -3.054

N=4

----------- Equipment Type=OEL SERVICE=G -----------

ONOFF 100000 100000 0.00000272158 -12.814 ONOFF 3000 10000 0.00001360791 -11.205 ONOFF 200 10000 0.00001769028 -10.942 ONOFF 10000 10000 0.00001814388 -10.917 ONOFF 10000 10000 0.00003039100 -10.401 REF 13400 16750 0.00004146875 -10.091 ONOFF 20000 15000 0.00004853488 -9.933 ONOFF 10000 10000 0.00005080287 -9.888 ONOFF 3000 10000 0.00007983308 -9.436 ONOFF 10000 10000 0.00008935861 -9.323 ONOFF 10000 10000 0.00009026581 -9.313 REF 100000 100000 0.00013893677 -8.881 ONOFF 9000 10000 0.00014877982 -8.813 ONOFF 10000 100000 0.00020547945 -8.490 REF 6000 10000 0.00023758051 -8.345 ONOFF 12000 15000 0.00029257008 -8.137

C-69Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

ONOFF 100000 100000 0.00046901932 -7.665 ONOFF 35000 20000 0.00057652182 -7.458 ONOFF 10000 10000 0.00059194412 -7.432 ONOFF 100000 100000 0.00072167287 -7.234 REF 50000 40000 0.00087367323 -7.043 ONOFF 100000 100000 0.00094847138 -6.961 ONOFF 100000 100000 0.00100244942 -6.905 ONOFF 10000 10000 0.00142610904 -6.553 ONOFF 10000 9000 0.00148326227 -6.514 ONOFF 70000 70000 0.00203392906 -6.198 ONOFF 15000 15000 0.00229792253 -6.076 REF 119000 119000 0.00267976050 -5.922 ONOFF 100000 100000 0.00350403701 -5.654 ONOFF 40000 100000 0.00398666425 -5.525 REF 89000 89000 0.00412528350 -5.491 ONOFF 100000 100000 0.00440850948 -5.424 ONOFF 100000 100000 0.00509843055 -5.279 ONOFF 10000 10000 0.00556200671 -5.192 REF 110000 110000 0.00582781457 -5.145 ONOFF 10000 10000 0.00610314796 -5.099 ONOFF 100000 100000 0.00673001905 -5.001 ONOFF 100000 100000 0.00783997097 -4.849 ONOFF 100000 80000 0.00808309897 -4.818 ONOFF 100000 100000 0.00899074662 -4.712 REF 140000 140000 0.01182844961 -4.437 ONOFF 100000 100000 0.01357071578 -4.300 REF 140000 140000 0.01958495872 -3.933 ONOFF 100000 100000 0.02699718770 -3.612 ONOFF 100000 100000 0.04810033566 -3.034 ONOFF 100000 100000 0.05125374218 -2.971 ONOFF 100000 100000 0.05756735916 -2.855 ONOFF 100000 100000 0.06938129366 -2.668 ONOFF 100000 100000 0.15146738637 -1.887 ONOFF 100000 100000 0.19622017600 -1.629 ONOFF 100000 100000 0.72652136442 -0.319

N = 51

----------- Equipment Type=OEL SERVICE=HL -----------

ONOFF 10000 8000 0.00003991654 -10.129 REF 15000 16000 0.00018571169 -8.591 ONOFF 10000 10000 0.00264628504 -5.935 REF 700 700 0.00467341014 -5.366

N=4

C-70Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

----------- Equipment Type=OEL SERVICE=LL -----------

ONOFF 20000 100000 0.00003538057 -10.249 REF 13200 16500 0.00009666606 -9.244 ONOFF 20000 3000 0.00011385285 -9.081 ONOFF 30000 40000 0.00013063594 -8.943 ONOFF 2000 10000 0.00043000998 -7.752 ONOFF 10000 8000 0.00043499955 -7.740 REF 12000 13000 0.00056373038 -7.481 ONOFF 6000 20000 0.00085366960 -7.066 REF 100000 100000 0.00085947564 -7.059 REF 14000 12000 0.00092007620 -6.991 REF 95000 100000 0.00101356255 -6.894 ONOFF 10000 1000 0.00117753788 -6.744 ONOFF 40000 35000 0.00120112492 -6.724 MT 300000 300000 0.00217168647 -6.132 ONOFF 20000 20000 0.00219268802 -6.123 MT 136000 119000 0.00292179987 -5.836 ONOFF 50000 35000 0.00361471469 -5.623 ONOFF 100000 100000 0.00493286764 -5.312 ONOFF 80000 60000 0.00594257462 -5.126 ONOFF 100000 100000 0.00672366869 -5.002 ONOFF 50000 100000 0.00678853307 -4.993 ONOFF 100000 30000 0.00804363603 -4.823 ONOFF 100000 100000 0.00847319242 -4.771 REF 20000 33600 0.00883470924 -4.729 ONOFF 10000 10000 0.00924929692 -4.683 ONOFF 10000 10000 0.01178853307 -4.441 ONOFF 100000 100000 0.01185702622 -4.435 REF 73000 73000 0.01350811939 -4.304 ONOFF 100000 100000 0.01985711694 -3.919 ONOFF 100000 100000 0.02174907013 -3.828 REF 140000 140000 0.04261680123 -3.156 ONOFF 100000 100000 0.07331080468 -2.613

N = 32
----------- Equipment Type=OTHER SERVICE=G -----------

MT 100000 100000 0.01708926789 -4.069 MT 100000 100000 0.01809353171 -4.012

N=2

----------- Equipment Type=PRV SERVICE=G -----------

ONOFF 100000 100000 0.02052209018 -3.886

C-71Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

ONOFF 100000 100000 0.36418670054 -1.010

N=2

----------- Equipment Type=PUMP SERVICE=LL -----------

REF 35000 21000 0.00082055702 -7.106 REF 40500 27000 0.00086514560 -7.053 REF 109000 98100 0.00105651819 -6.853 REF 76500 90000 0.00106527261 -6.845 REF 21000 25000 0.00119445704 -6.730 MT 10000 12000 0.00176567178 -6.339 REF 56000 28000 0.00958087635 -4.648 REF 12000 16000 0.00968248208 -4.637 REF 18000 17400 0.03439081920 -3.370 REF 77000 47000 0.03876077293 -3.250 REF 100000 100000 0.16085911276 -1.827 REF 100000 100000 1.25088451420 0.224

N = 12
----------- Equipment Type=STUFFING BOX SERVICE=LL -----------

ONOFF 10000 500 0.00035698086 -7.938 ONOFF 10000 10000 0.00215186428 -6.141

N=2

----------- Equipment Type=VALVE SERVICE=G -----------

ONOFF 100000 100000 0.00000725755 -11.833 ONOFF 1000 10000 0.00001814388 -10.917 ONOFF 10000 10000 0.00002585503 -10.563 ONOFF 60000 10000 0.00002585503 -10.563 ONOFF 100000 100000 0.00002676222 -10.529 ONOFF 100000 100000 0.00004127733 -10.095 ONOFF 10000 10000 0.00005171006 -9.870 ONOFF 100000 100000 0.00005488524 -9.810 ONOFF 100000 3000 0.00008754423 -9.343 REF 20000 2000 0.00023997097 -8.335 ONOFF 100000 100000 0.00026399347 -8.240 ONOFF 10000 10000 0.00026852944 -8.223 ONOFF 15000 15000 0.00029257008 -8.137 ONOFF 100000 100000 0.00031706432 -8.056 REF 22500 22500 0.00035323415 -7.948 ONOFF 10000 10000 0.00038555747 -7.861 REF 18000 15000 0.00038567541 -7.861

C-72Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

REF 65700 65700 0.00060437268 -7.411 REF 100000 100000 0.00060967976 -7.403 ONOFF 10000 10000 0.00064002540 -7.354 ONOFF 100000 100000 0.00068946748 -7.280 ONOFF 100000 20000 0.00069717863 -7.268 REF 80000 48000 0.00085747981 -7.062 ONOFF 70000 70000 0.00090220448 -7.011 ONOFF 30000 10000 0.00094166742 -6.968 ONOFF 15000 15000 0.00094484260 -6.964 ONOFF 10000 10000 0.00095799692 -6.951 ONOFF 100000 100000 0.00104644834 -6.862 ONOFF 50000 40000 0.00109815840 -6.814 ONOFF 10000 10000 0.00121291844 -6.715 ONOFF 7500 10000 0.00122335117 -6.706 REF 100000 100000 0.00128871451 -6.654 ONOFF 100000 100000 0.00128957634 -6.653 ONOFF 100000 100000 0.00133085367 -6.622 REF 100000 100000 0.00160963440 -6.432 ONOFF 40000 40000 0.00171278236 -6.370 REF 109000 109000 0.00178594756 -6.328 ONOFF 10000 10000 0.00181348090 -6.313 ONOFF 10000 10000 0.00199129094 -6.219 REF 100000 100000 0.00205130182 -6.189 ONOFF 60000 100000 0.00206341286 -6.183 ONOFF 100000 100000 0.00208563912 -6.173 ONOFF 25000 40000 0.00233194230 -6.061 ONOFF 50000 40000 0.00269255194 -5.917 MT 300000 300000 0.00277487980 -5.887 ONOFF 100000 100000 0.00287081557 -5.853 REF 67000 100000 0.00287548762 -5.852 ONOFF 100000 100000 0.00300553388 -5.807 ONOFF 100000 100000 0.00333167014 -5.704 ONOFF 100000 100000 0.00336795791 -5.693 REF 77000 77000 0.00341059603 -5.681 REF 80000 80000 0.00349872993 -5.655 ONOFF 100000 100000 0.00377438084 -5.580 REF 58000 35000 0.00417118752 -5.480 REF 100000 100000 0.00479905652 -5.339 REF 100000 100000 0.00497732015 -5.303 ONOFF 100000 100000 0.00498639209 -5.301 REF 78000 78000 0.00514197587 -5.270 ONOFF 100000 100000 0.00520366506 -5.258 ONOFF 100000 100000 0.00543227796 -5.215 ONOFF 10000 10000 0.00546720494 -5.209 REF 100000 100000 0.00554839880 -5.194 ONOFF 100000 100000 0.00594393541 -5.125 ONOFF 10000 10000 0.00630545224 -5.066 ONOFF 100000 100000 0.00660664066 -5.020 REF 70000 63000 0.00672094711 -5.003

C-73Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

ONOFF 80000 100000 0.00687607729 -4.980 ONOFF 100000 100000 0.00845640933 -4.773 ONOFF 80000 100000 0.00850403701 -4.767 REF 100000 100000 0.00879071033 -4.734 REF 90000 90000 0.00915767033 -4.693 ONOFF 100000 100000 0.00999909281 -4.605 REF 100000 100000 0.01077791890 -4.530 ONOFF 100000 100000 0.01084051529 -4.524 ONOFF 10000 10000 0.01150231334 -4.465 ONOFF 100000 100000 0.01338700898 -4.313 REF 50000 100000 0.01343826544 -4.310 REF 16000 80000 0.01372947473 -4.288 ONOFF 100000 100000 0.01451056881 -4.233 ONOFF 50000 50000 0.01612628141 -4.127 ONOFF 30000 100000 0.01659711512 -4.099 ONOFF 100000 100000 0.01664837159 -4.095 REF 58000 58000 0.01690556110 -4.080 REF 120000 120000 0.01879887508 -3.974 ONOFF 100000 100000 0.01883380205 -3.972 ONOFF 100000 100000 0.02038374308 -3.893 ONOFF 100000 100000 0.02074389912 -3.876 ONOFF 100000 100000 0.02144924249 -3.842 ONOFF 100000 100000 0.02216048263 -3.809 ONOFF 100000 100000 0.02497323778 -3.690 REF 71400 71400 0.02521500499 -3.680 ONOFF 100000 100000 0.02522135535 -3.680 ONOFF 100000 100000 0.02819150866 -3.569 ONOFF 100000 100000 0.03083597932 -3.479 ONOFF 100000 100000 0.03347137803 -3.397 ONOFF 100000 100000 0.03378118480 -3.388 ONOFF 100000 100000 0.03389685204 -3.384 ONOFF 100000 100000 0.03527669418 -3.345 ONOFF 100000 100000 0.03595482174 -3.325 ONOFF 100000 100000 0.03649097342 -3.311 ONOFF 100000 100000 0.03771114941 -3.278 ONOFF 100000 100000 0.03832713417 -3.262 ONOFF 5000 10000 0.04127914361 -3.187 ONOFF 100000 100000 0.04416220630 -3.120 ONOFF 100000 100000 0.04438764402 -3.115 ONOFF 60000 70000 0.04505624603 -3.100 ONOFF 100000 100000 0.04937176812 -3.008 ONOFF 10000 10000 0.05139208927 -2.968 ONOFF 100000 100000 0.05296924612 -2.938 ONOFF 100000 100000 0.05525764311 -2.896 ONOFF 100000 100000 0.06018007802 -2.810 MT 90000 300000 0.06055973873 -2.804 ONOFF 10000 10000 0.06589585412 -2.720 ONOFF 10000 10000 0.06919123651 -2.671 ONOFF 10000 100000 0.06986891046 -2.661

C-74Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

ONOFF 100000 100000 0.07176086365 -2.634 REF 100000 100000 0.07735190057 -2.559 ONOFF 100000 100000 0.08639118207 -2.449 ONOFF 10000 10000 0.08908826998 -2.418 ONOFF 100000 100000 0.09582463939 -2.345 ONOFF 100000 100000 0.15789757779 -1.846 ONOFF 100000 100000 0.18449242493 -1.690 ONOFF 100000 100000 0.18958677311 -1.663 ONOFF 100000 100000 0.19712873084 -1.624 ONOFF 100000 100000 0.21433094439 -1.540 ONOFF 100000 100000 0.22602739726 -1.487 ONOFF 100000 100000 0.27724439808 -1.283 ONOFF 10000 10000 0.28369636215 -1.260 ONOFF 100000 100000 0.28827360973 -1.244 ONOFF 100000 100000 0.38205751610 -0.962 ONOFF 100000 100000 0.44049986392 -0.820 ONOFF 100000 100000 0.81931597569 -0.199 ONOFF 100000 100000 1.13625011340 0.128

N = 133

----------- Equipment Type=VALVE SERVICE=HL -----------

REF 10000 16000 0.00043354350 -7.744 REF 11000 12000 0.00223700445 -6.103

N=2
----------- Equipment Type=VALVE SERVICE=LL -----------

ONOFF 10000 10000 0.00002404064 -10.636 ONOFF 10000 10000 0.00002449424 -10.617 ONOFF 100000 100000 0.00003447337 -10.275 REF 80000 32000 0.00009142702 -9.300 ONOFF 15000 20000 0.00010342012 -9.177 REF 16000 32000 0.00013744443 -8.892 ONOFF 10000 4000 0.00018279960 -8.607 MT 19800 22000 0.00023388370 -8.361 REF 13500 10800 0.00025930781 -8.257 REF 42000 28000 0.00035377846 -7.947 MT 17600 26400 0.00043848771 -7.732 REF 49500 36000 0.00044372675 -7.720 REF 70000 35000 0.00045913091 -7.686 REF 18000 22500 0.00046035562 -7.684 ONOFF 10000 10000 0.00050122471 -7.598 ONOFF 20000 20000 0.00052617255 -7.550 ONOFF 10000 10000 0.00056563549 -7.478 REF 2000 10000 0.00056713236 -7.475

C-75Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

REF 10000 24000 0.00059525538 -7.427 REF 24000 24000 0.00060782001 -7.406 ONOFF 100000 60000 0.00065091173 -7.337 ONOFF 30000 4000 0.00068220992 -7.290 ONOFF 20000 20000 0.00070443618 -7.258 ONOFF 10000 10000 0.00070488978 -7.257 ONOFF 70000 40000 0.00075932142 -7.183 REF 50000 30000 0.00095572893 -6.953 ONOFF 60000 50000 0.00102558287 -6.882 REF 11000 11000 0.00113353896 -6.782 REF 80000 80000 0.00134786356 -6.609 ONOFF 80000 100000 0.00135625510 -6.603 MT 10000 11984 0.00142805951 -6.551 REF 25000 18000 0.00153742175 -6.478 ONOFF 10000 10000 0.00168647374 -6.385 ONOFF 350 10000 0.00185929420 -6.288 ONOFF 20000 15000 0.00211829810 -6.157 ONOFF 40000 70000 0.00223351175 -6.104 ONOFF 10000 10000 0.00225936678 -6.093 ONOFF 10000 10000 0.00226753152 -6.089 ONOFF 100000 100000 0.00230064411 -6.075 ONOFF 50000 35000 0.00247028939 -6.003 REF 58000 58000 0.00307012610 -5.786 ONOFF 10000 9000 0.00325773383 -5.727 REF 70000 70000 0.00345051256 -5.669 ONOFF 9000 10000 0.00417490701 -5.479 ONOFF 90000 100000 0.00426290484 -5.458 ONOFF 100000 100000 0.00436587136 -5.434 ONOFF 10000 10000 0.00454277420 -5.394 ONOFF 100000 100000 0.00488886873 -5.321 REF 5000 40000 0.00500408237 -5.298 REF 70000 70000 0.00507983308 -5.282 ONOFF 100000 100000 0.00518234600 -5.262 ONOFF 100000 100000 0.00592896671 -5.128 ONOFF 10000 10000 0.00596117209 -5.122 REF 24500 27300 0.00601378935 -5.114 ONOFF 100000 100000 0.00647010796 -5.041 REF 131400 146000 0.00666334029 -5.011 REF 30000 70000 0.00844506940 -4.774 REF 55000 100000 0.00920847319 -4.688 ONOFF 100000 100000 0.01027941577 -4.578 ONOFF 100000 100000 0.01037285675 -4.569 ONOFF 10000 10000 0.01041458768 -4.565 ONOFF 10000 10000 0.01133221446 -4.480 ONOFF 10000 10000 0.01256146240 -4.377 REF 67000 67000 0.01319241586 -4.328 REF 140000 140000 0.01378798875 -4.284 ONOFF 10000 10000 0.01564138619 -4.158 REF 17000 34000 0.01730744806 -4.057

C-76Table C-2-1. BAGGING DATA USED TO DEVELOP PEGGED EMISSION RATES (CONTINUED)

Natural Initial Final Log of Screening Screening Measured Emission Plant Value Value Emission Rate Type (ppmv) (ppmv) Rate(kg/hr) (kg/hr)

ONOFF 100000 100000 0.01835979316 -3.998 REF 100000 100000 0.01882427651 -3.973 ONOFF 45000 45000 0.01897986029 -3.964 REF 76000 69850 0.02037603193 -3.893 REF 100000 100000 0.02065272612 -3.880 ONOFF 10000 10000 0.02356890139 -3.748 REF 87500 87500 0.02427696634 -3.718 REF 100000 100000 0.02519096435 -3.681 REF 39000 39000 0.02586999909 -3.655 ONOFF 100000 100000 0.02691508664 -3.615 REF 70000 70000 0.03012791436 -3.502 ONOFF 10000 10000 0.03019504672 -3.500 ONOFF 10000 10000 0.03919486528 -3.239 ONOFF 10000 10000 0.08274879797 -2.492 ONOFF 100000 100000 0.08523224168 -2.462 ONOFF 10000 10000 0.08567948834 -2.457 ONOFF 100000 100000 0.08933548036 -2.415 ONOFF 100000 100000 0.09434591309 -2.361 ONOFF 100000 100000 0.10369500136 -2.266 REF 70000 70000 0.18793885512 -1.672 ONOFF 100000 100000 0.38088768938 -0.965

N = 88

----------- Equipment Type=VENT SERVICE=G -----------

ONOFF 100000 100000 0.00012972875 -8.950 ONOFF 100000 100000 0.00851719133 -4.766 ONOFF 100000 100000 0.00923206024 -4.685 ONOFF 100000 100000 0.02947428105 -3.524

N=4

----------- Equipment Type=VENT SERVICE=LL -----------

ONOFF 100000 100000 0.00005443164 -9.819 ONOFF 100000 100000 0.00027714778 -8.191 ONOFF 10000 10000 0.00117844507 -6.744 ONOFF 10000 10000 0.00200762043 -6.211

N=4

C-77TABLE C-2-2. PEGGED VOC MASS EMISSION RATES AND 95 PERCENT CONFIDENCE INTERVALS FORREADINGS PEGGED AT 10,000 PPMV DEVELOPED FROM THE COMBINED 1993 REFINERY, MARKETINGTERMINAL, AND OIL AND GAS PRODUCTION OPERATIONS DATAEquipmentType/ServiceSample SizeNormal Statistica(Probability of aLarger NormalStatistic)MeanNaturalLog MassEmissionRateScale BiasCorrectionFactorLower95 PercentConfidenceBound forPeggedEmissionRate (kg/hr)PeggedEmissionRate (kg/hr)Upper95 PercentConfidenceBound forPeggedEmissionRate(kg/hr)MassEmissionRateln MassEmissionRateConnector/All740.5569(0.0000)0.9631(0.0945)-6.06712.240.016680.028360.04821Flange/All240.6790(0.0000)0.9424(0.1899)-5.31217.250.028770.085040.25141Open-EndedLine/All870.2597(0.0000)0.9819(0.6620)-6.37417.780.017970.030310.05110Pump/All120.3985(0.0000)0.8640(0.0519)-4.8699.630.016090.073950.33989Valve/All2230.3740(0.000)0.9774(0.1524)-5.30112.840.047410.064030.08648Otherb/All250.4359(0.0000)0.9506(0.2710)-5.21913.460.026650.072850.19914aThe Normal Statistic is generated by default from SAS--by default the Shapiro-Wilkstatistic is calculated for sample sizes less than 2,000. Probabilities greater than0.05 indicate a normal distribution.bThe "other" equipment type was developed from instruments, loading arms, pressurerelief valves, stuffing boxes, vents, compressors, and dump lever arms. This "other"equipment type should be applied to any equipment other than connectors, flanges,open-ended lines, pumps, or valves.

C-78TABLE C-2-3. PEGGED VOC MASS EMISSION RATES AND 95 PERCENT CONFIDENCE INTERVALS FORREADINGS PEGGED AT 100,000 PPMV DEVELOPED FROM THE COMBINED 1993 REFINERY, MARKETINGTERMINAL, AND OIL AND GAS PRODUCTION OPERATIONS DATAEquipmentType/ServiceSampleSizeNormal Statistica(Probability of a LargerNormal Statistic)MeanNaturalLog MassEmissionRateScale BiasCorrectionFactorLower95 PercentConfidenceBound forPeggedEmission Rate(kg/hr)PeggedEmissionRate (kg/hr)Upper95 PercentConfidenceBound forPeggedEmissionRate (kg/hr)MassEmissionRateln MassEmissionRateConnector/All330.6405(0.0000)0.9579(0.2747)-5.7399.250.013590.029740.06509Flange/All120.8101(0.0106)0.8653(0.0539)-3.9694.470.025150.084390.28317Open-Ended Line/All360.3759(0.0000)0.9444(0.0918)-4.89310.550.036720.079110.17046Pump/Allb------0.16000-Valve/All990.4680(0.0000)0.9519(0.0042)-4.38811.300.089840.140430.21952Other/Allc190.4759(0.0000)0.9140(0.0900)-4.85314.610.033740.114060.38554aThe Normal Statistic is generated by default from SAS--by default the Shapiro-Wilkstatistic is calculated for sample sizes less than 2,000. Probabilities greater than0.05 indicate a normal distribution.bOnly 2 data points were available for the pump emission factor; therefore the ratio ofthe pump/overall 10,000 ppmv emission factor was multiplied by the overall 100,000ppmv emission factor to approximate the pump 100,000 ppmv emission factorcThe "other" equipment type was developed from instruments, loading arms, pressurerelief valves, stuffing boxes, vents, compressors, and dump lever arms. This "other"equipment type should be applied to any equipment other than connectors, flanges,open-ended lines, pumps, or valves.

C-79APPENDIX C: ATTACHEMENT 3 This attachment lists the bagging data used to develop the default zero emission rates for the combined 1993 petroleum industry data in table C-3-1. Table C-3-2 lists summary statistics for the default zero emission rates.

C-80TABLE C-3-1. BAGGING DATA USED TO DEVELOP DEFAULT ZERO EMISSION RATES

Natural

Log of Measured Emission Plant Screening Emission Rate Type Value (ppmv) Rate(kg/hr) (kg/hr)

----------- Equipment Type=CONNECTOR SERVICE=G -----------

REF 0.00 0.00000000476 -19.163 REF 0.00 0.00000000636 -18.873 REF 0.00 0.00000002555 -17.483 REF 0.00 0.00000023605 -15.259 REF 0.00 0.00000038635 -14.767 REF 0.00 0.00000362959 -12.526

N=6

----------- Equipment Type=CONNECTOR SERVICE=LL -----------

REF 0.00 0.00000000501 -19.112 REF 0.00 0.00000000544 -19.030 REF 0.00 0.00000000739 -18.723 REF 0.00 0.00000000763 -18.691 REF 0.00 0.00000000777 -18.673 MT 0.00 0.00000137993 -13.493 MT 0.00 0.00000177942 -13.239 MT 0.00 0.00000258886 -12.864 MT 0.00 0.00000332328 -12.615 REF 0.00 0.00000470743 -12.266 MT 0.00 0.00000863240 -11.660 MT 0.00 0.00001050395 -11.464

N = 12
----------- Equipment Type=FLANGE SERVICE=G -----------

REF 0.00 0.00000000642 -18.863 REF 0.00 0.00000000709 -18.764 REF 0.00 0.00000007912 -16.352 REF 0.00 0.00000080155 -14.037

N=4

----------- Equipment Type=FLANGE SERVICE=LL -----------

REF 0.00 0.00000000958 -18.464 REF 0.00 0.00000019031 -15.475 REF 0.00 0.00000021919 -15.333 REF 0.00 0.00000021930 -15.333 REF 0.00 0.00000047102 -14.568

N=5

----------- Equipment Type=LOADARM SERVICE=LL -----------

MT 0.00 0.00005125646 -9.879

C-81TABLE C-3-1. BAGGING DATA USED TO DEVELOP DEFAULT ZERO EMISSION RATES (CONTINUED)

Natural Log of Measured Emission Plant Screening Emission Rate Type Value (ppmv) Rate(kg/hr) (kg/hr)

N=1
----------- Equipment Type=OEL SERVICE=G -----------

REF 0.00 0.00000000693 -18.788 REF 0.00 0.00000140955 -13.472 MT 0.00 0.00000303602 -12.705 MT 0.00 0.00000334319 -12.609

N=4

----------- Equipment Type=OEL SERVICE=HL -----------

REF 0.00 0.00000000575 -18.975 REF 0.00 0.00000000583 -18.960 REF 0.00 0.00000001096 -18.329 REF 0.00 0.00000009800 -16.138

N=4

----------- Equipment Type=OEL SERVICE=LL -----------

REF 0.00 0.00000000511 -19.093 REF 0.00 0.00000000540 -19.036 REF 0.00 0.00000076594 -14.082 MT 0.00 0.00000288878 -12.755

N=4
----------- Equipment Type=PRV SERVICE=G -----------

REF 0.00 0.00000000710 -18.763 REF 0.00 0.00000000807 -18.635 REF 0.00 0.00000001125 -18.303

N=3

----------- Equipment Type=PUMP SERVICE=HL -----------

REF 0.00 0.00000002008 -17.723 REF 0.00 0.00000002256 -17.607 REF 0.00 0.00000002315 -17.581 REF 0.00 0.00000002586 -17.471 REF 0.00 0.00000089186 -13.930

N=5

C-82TABLE C-3-1. BAGGING DATA USED TO DEVELOP DEFAULT ZERO EMISSION RATES (CONTINUED)

Natural Log of Measured Emission Plant Screening Emission Rate Type Value (ppmv) Rate(kg/hr) (kg/hr)

----------- Equipment Type=PUMP SERVICE=LL -----------

REF 0.00 0.00000002503 -17.503 REF 0.00 0.00000002714 -17.422 REF 0.00 0.00000005485 -16.719 REF 0.00 0.00000006666 -16.524 REF 0.00 0.00000053647 -14.438 REF 0.00 0.00000186896 -13.190 MT 0.00 0.00000480541 -12.246 MT 0.00 0.00000775832 -11.767 MT 0.00 0.00000998821 -11.514 MT 0.00 0.00001319922 -11.235 MT 0.00 0.00001436632 -11.151 MT 0.00 0.00001653679 -11.010 REF 0.00 0.00002058968 -10.791 MT 0.00 0.00006269164 -9.677

N = 14
----------- Equipment Type=VALVE SERVICE=G -----------

REF 0.00 0.00000000775 -18.676 REF 0.00 0.00000000865 -18.565 REF 0.00 0.00000000940 -18.482 REF 0.00 0.00000000990 -18.431 REF 0.00 0.00000001019 -18.402 REF 0.00 0.00000001420 -18.070 REF 0.00 0.00000002762 -17.405 REF 0.00 0.00000003664 -17.122 REF 0.00 0.00000003966 -17.043 REF 0.00 0.00000004455 -16.927 REF 0.00 0.00000020591 -15.396 REF 0.00 0.00000032682 -14.934 REF 0.00 0.00000032845 -14.929 REF 0.00 0.00000061449 -14.302 REF 0.00 0.00000083416 -13.997 MT 0.00 0.00000125837 -13.586 MT 0.00 0.00000196249 -13.141 MT 0.00 0.00000201696 -13.114 MT 0.00 0.00000208210 -13.082 REF 0.00 0.00000218398 -13.034 MT 0.00 0.00000238633 -12.946 MT 0.00 0.00000798694 -11.738 REF 0.00 0.00000893314 -11.626 REF 0.00 0.00001171097 -11.355 REF 0.00 0.00001563050 -11.066

N = 25

C-83TABLE C-3-1. BAGGING DATA USED TO DEVELOP DEFAULT ZERO EMISSION RATES (CONTINUED)

Natural Log of Measured Emission Plant Screening Emission Rate Type Value (ppmv) Rate(kg/hr) (kg/hr)

----------- Equipment Type=VALVE SERVICE=HL -----------

REF 0.00 0.00000000660 -18.836 REF 0.00 0.00000000665 -18.828 REF 0.00 0.00000001034 -18.387 REF 0.00 0.00000001058 -18.364 REF 0.00 0.00000001345 -18.124 REF 0.00 0.00000001638 -17.927 REF 0.00 0.00000004990 -16.813 REF 0.00 0.00000005393 -16.736 REF 0.00 0.00000005530 -16.710 REF 0.00 0.00000240865 -12.936 REF 0.00 0.00001479770 -11.121 REF 0.00 0.00002881475 -10.455 REF 0.00 0.00003605008 -10.231

N = 13
----------- Equipment Type=VALVE SERVICE=LL -----------

REF 0.00 0.00000000467 -19.182 REF 0.00 0.00000000637 -18.871 REF 0.00 0.00000000664 -18.830 REF 0.00 0.00000000691 -18.791 REF 0.00 0.00000000834 -18.602 REF 0.00 0.00000000976 -18.445 REF 0.00 0.00000000997 -18.423 REF 0.00 0.00000001104 -18.322 REF 0.00 0.00000001198 -18.240 REF 0.00 0.00000002004 -17.725 REF 0.00 0.00000002139 -17.660 REF 0.00 0.00000002191 -17.636 REF 0.00 0.00000002793 -17.394 REF 0.00 0.00000005696 -16.681 REF 0.00 0.00000007503 -16.405 REF 0.00 0.00000048449 -14.540 REF 0.00 0.00000053602 -14.439 MT 0.00 0.00000103293 -13.783 MT 0.00 0.00000112977 -13.693 REF 0.00 0.00000192842 -13.159 MT 0.00 0.00000195101 -13.147 MT 0.00 0.00000195727 -13.144 MT 0.00 0.00000220253 -13.026 REF 0.00 0.00000233299 -12.968 REF 0.00 0.00000234795 -12.962 REF 0.00 0.00000312302 -12.677 REF 0.00 0.00000683117 -11.894

C-84TABLE C-3-1. BAGGING DATA USED TO DEVELOP DEFAULT ZERO EMISSION RATES (CONTINUED)

Natural Log of Measured Emission Plant Screening Emission Rate Type Value (ppmv) Rate(kg/hr) (kg/hr)

REF 0.00 0.00000696181 -11.875 REF 0.00 0.00000698812 -11.871 REF 0.00 0.00001664883 -11.003

N = 30

C-85TABLE C-3-2. DEFAULT ZERO VOC MASS EMISSION RATES AND 95 PERCENT CONFIDENCE INTERVALSDEVELOPED FROM THE COMBINED 1993 REFINERY AND MARKETING TERMINAL DATAaEquipmentType/ServiceSampleSizeNormal Statisticb(Probability of aLarger NormalStatistic)Mean lnMassEmissionRateScale BiasCorrectionFactorLower95 PercentConfidenceBound forDefault ZeroEmissionRate (kg/hr)Default ZeroEmissionRate (kg/hr)Upper95 PercentConfidenceBound forDefault ZeroEmissionRate (kg/hr)MassEmissionRateln MassEmissionRateConnector/All180.7177(0.0001)0.8302(0.0034)-15.55042.721.64E-067.54E-063.47E-05Flange/All90.8137(0.0296)0.8687(0.1173)-16.3543.947.39E-083.11E-071.31E-06Open-Ended Line/All120.7232(0.0009)0.7909(0.0061)-16.24522.703.19E-072.00E-061.25E-05Pump/All190.5942(0.0000)0.8532(0.0065)-14.18434.975.81E-062.42E-051.01E-04Valve/All680.5178(0.0000)0.8764(0.0000)-15.41538.383.95E-067.75E-061.52E-05Otherc/All40.6297(0.0000)0.6691(0.0045)-16.39552.163.91E-093.95E-064.00E-03aNo default zero data were collected from oil and gas production facilitiesbThe Normal Statistic is generated by default from SAS--by default the Shapiro-Wilkstatistic is calculated for sample sizes less than 2,000. Probabilities greater than0.05 indicate a normal distribution.cThe "other" equipment type were developed from instruments, loading arms, pressurerelief valves, stuffing boxes, vents, compressors, and dump lever arms. This "other"equipment type should be applied to any equipment other than connectors, flanges,open-ended lines, pumps, or valves.

C-86APPENDIX C: ATTACHMENT 4 Because it would be impractical to list all of the screening data used to develop emission factors, this attachment summarizes the 1993 marketing terminal and oil and gas production operations screening data sets. Figures C-4-1 through C-4-4 are plots of the distribution of screening values for marketing terminals and figures C-5-5 through C-5-10 are plots of the distribution of screening valves for oil and gas production operations.

C-87Figure C-4-1. Distribution of Connector Screening Values for Marketing Terminals

C-88Figure C-4-2. Distribution of Other Screening Values for Marketing Terminals

C-89Figure C-4-3. Distribution of Pump Screening Values for Marketing Terminals

C-90Figure C-4-4. Distribution of Valve Screening Values for Marketing Terminals

C-91Figure C-4-5. Distribution of Connector Screening Values for Oil and Gas Operations

C-92Figure C-4-6. Distribution of Flange Screening Values for Oil and Gas Operations

C-93Figure C-4-7. Distribution of Open-Ended Line Screening Values for Oil and Gas Operations

C-94Figure C-4-8. Distribution of Pump Screening Values for Oil and Gas Operations

C-95Figure C-4-9. Distribution of Valve Screening Values for Oil and Gas Operations

C-96Figure C-4-10. Distribution of Other Screening Values for Oil and Gas Operations

C-97APPENDIX D: RESPONSE FACTORSAPPENDIX D

RESPONSE FACTORS

The response factors presented in table D-1 were taken from two separate sources. The response factors at an actual concentration of 10,000 ppmv are from the EPA document entitled, "Response Factors of VOC Analyzers Calibrated with Methane for Selected Organic Chemicals," EPA-600/2-81-002 (September 1980). The document presents results of analytical tests performed to determine the response factors at 10,000 ppmv of two portable monitoring instruments--the Foxboro OVA-108 and the Bacharach TLV-108. Both instruments were calibrated with methane. The response factors at a concentration of 500 ppmv are from the document entitled "Method 21 Evaluation for the HON, "90-ME-07)" (March 1991) prepared for the Emission Measurement Branch of the U.S. Environmental Protection Agency. This document presents the results of analytical tests performed to determine the response factors at an actual concentration of 500 ppmv of several emission monitors including the Foxboro OVA-108, two of Foxboro OVA-128 units, the Heath Detecto-PAK III, and the HNU Systems HW-101. The two Foxboro OVA-128 instrument response factors are presented in the table to indicate the variability of individual instruments. To determine the response factor for the OVA-128, the average of the two instrument response factors should be used. All of the instruments except the HNU HW-101 were calibrated with methane. The HNU HW-101 was calibrated with benzene. A dashed line in table D-1 indicates that the study did not test that particular chemical. If the emission monitor did not respond to a chemical, N/R was recorded to indicate no response. Operators of portable leak detection devices should be thoroughly familiar with their instrumentation. Even under the best of circumstances, no two analyzers will perform exactly the same and the effect of changes in instrument parameters upon accuracy can be significant. Other external quality controls, such as a checklist for periodically noting battery condition,

D-1fuel pressure, post-survey calibration checks, etc., will support the validity of the data. An audit program testing both the operator and the analyzer should be a requirement whenever a situation warranting an exacting determination of a fugitive emission is encountered. In general, the response factors follow the pattern which would be predicted for increasing flame ionization detector response with increasing hydrocarbon character for the molecule. The sequence of compounds methyl chloride, methylene chloride, chloroform, and carbon tetrachloride exhibits progressively decreasing response on the OVA detectors (response factors ranging from 2 to 12) as the substitution on the methyl carbon atom increases (i.e., decreasing hydrocarbon character for the molecule). In general, increasing electronegativity of the substituent decreases the system response: methyl chloride, response factor approximately 2; methyl bromide, response factor approximately 5; iodomethane, response factor approximately 8. Carbon tetrachloride exhibits a response factor of 12 or more, but tetrachloroethylene has a response factor of 2 or less. The lack of carbon-hydrogen bonds in tetrachloroethylene is apparently compensated by the presence of a site of unsaturation in the molecule (chlorobenzene, response factor 0.60 vs. trichlorobenzene, response factor of 12 or greater). The difficulty of obtaining a reproducible and useful response factor for compounds of insufficient volatility such as nitrobenzene, m-cresol, and oxygenated compounds such as acrylic acid demonstrates that there is a point dictated by vapor pressure or possibly boiling point where an accurate measurement cannot be made using the portable field analyzers. With compounds which are not very volatile, the portable field analyzers can be usedonly qualitatively, at best; if a large amount of the compound is present in the air, the compound will be observed but not with a proportionate quantitative response.

D-2D-3TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMVActual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101b75-07-0AcetaldehydeLL----8.419.967.955.366.0764-19-7Acetic AcidLL1.835.70----------108-24-7 Acetic anhydrideLL1.362.89----------67-64-1 AcetoneLL0.791.22----------75-86-5 Acetone cyanohydrinHL3.427.84----------75-05-08 AcetonitrileLL0.941.171.201.241.271.27N/R98-86-2 AcetophenoneHL10.9854.862.712.622.432.923.0775-36-5Acetyl chlorideLL1.992.59----------74-86-2 AcetyleneG0.3711.95----------107-02-8 AcroleinLL----6.256.695.643.712.7379-10-7Acrylic acidLL4.6536.9510.51c10.81c9.63c8.61c8.91c107-13-1 AcrylonitrileLL0.962.701.551.581.561.473.04AlleneG0.555.78----------107-18-6 Allyl alcoholLL0.94----------107-5-1 Allyl chlorideLL----2.772.732.511.561.4671-41-0cAmyl alcohol, N-HL0.691.78----------AmyleneLL0.311.03----------62-53-3 AnilineHL----14.44c20.45c22.68c14.71c15.23c100-66-3 AnisoleLL0.922.69----------100-52-7 BenzaldehydeHL2.366.30----------TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-4Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101b71-43-2BenzeneLL0.211.070.560.540.500.381.00100-47-0BenzonitrileHL2.249.13----------98-88-4 Benzoyl ChlorideHL6.406.60----------100-44-7 Benzyl ChlorideHL4.204.871.431.421.210.951.3410-86-0BromobenzeneLL0.361.16----------75-25-2 BromoformLL----5.906.715.685.120.62106-99-0Butadiene, 1,3-G0.376.002.412.692.371.682.15106-97-8Butane, N-G0.380.68----------71-36-3 Butanol, N-LL1.432.80----------78-92-2 Butanol, Sec-LL0.701.26----------75-65-0 Butanol, Tert-S0.442.19----------106-98-9 Butene, 1-G0.512.97----------111-76-2 Butoxyethanol, 2-c----19.37c26.11c24.69c13.93c9.23c123-86-4 Butyl acetateLL0.601.30----------141-32-2 Butyl acrylate, N-LL0.641.98----------142-96-1 Butyl ether, N-LL2.702.66----------Butyl ether, Sec-LL0.261.13----------109-73-9 Butylamine, N-LL0.631.91----------13952-84-6 Butylamine, Sec-LL0.671.50----------75-64-9 Butylamine, Tert-LL0.581.80----------98-06-6 Butylbenzene, Tert-HL1.276.42----------TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-5Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101b123-72-8Butyraldehyde, N-LL1.391.89----------107-92-6 Butyric acidHL0.744.58----------109-74-0 ButyronitrileLL0.461.33----------75-1-50 Carbon disulfideLL--2.9633.8753.06N/R 57.060.7156-23-5Carbon tetrachlorideLL----12.0715.9913.7211.113.06463-58-1Carbonyl SulfideG -- --103.95N/RN/RN/R3.14107-20-0 ChloroacetaldehydeLL13.405.07----------79-04-9 Chloroacetyl chlorideLL----1.861.931.661.283.21108-90-7ChlorobenzeneLL0.360.880.620.600.540.381.0675-00-3ChloroethaneG0.672.16----------67-66-3 ChloroformL4.488.772.062.381.911.383.35Chloromethyl methylether----7.779.767.524.281.6525167-80-0 Chlorophenol, 0-HL3.335.87----------50% Chloroprene/xylene----1.461.471.270.771.37Chloropropene, 1-LL0.590.86----------Chloropropene, 3-LL0.751.24----------108-41-8 Chlorotoluene, M-LL0.430.92----------95-49-9 Chlorotoluene, O-LL0.451.05----------106-43-4 Chlorotoluene, P-LL0.521.15----------95-48-7 Cresol, O-S0.953.98----------TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-6Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101b108-39-4Cresol, M-LL----75.60c115.20cN/R N/R N/R106-44-5Cresol, P-S -- --N/RN/RN/RN/RN/R4170-30-0 CrotonaldehydeLL1.328.54----------98-82-8 CumeneLL1.9212.492.051.821.550.791.87110-82-7CyclohexaneLL0.360.72----------108-93-0 CyclohexanolHL0.824.92----------108-94-1 CyclohexanoneLL1.503.99----------110-83-8 CyclohexeneLL0.401.84----------108-91-8 CyclohexylamineLL0.471.38----------124-18-5 DecaneHL0.000.20----------123-42-2 Diacetone alcoholHL1.530.98----------431-03-8 DiacetylLL1.612.81----------Dichloro-1-propene,2,3-LL61.5134.34----------541-73-1 Dichlorobenzene, M-HL0.661.89----------95-50-1 Dichlorobenzene, O-HL0.701.22----------75-34-3 Dichloroethane, 1,1-LL0.771.80----------107-06-2 Dichloroethane, 1,2-LL0.952.08----------540-59-0 Dichloroethylene, 2-LL1.311.93----------540-59-0 Dichloroethylene,TRANS, 1,2LL1.131.86----------111-44-4 Dichloroethyl etherc----22.12c25.10c24.48c16.88c8.79cTABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-7Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101bDichloromethaneLL2.263.63----------Dichloropropane, 1,2-LL1.031.80----------542-75-6 Dichloropropene, 1,3-----2.032.081.931.231.1825167-70-8 DiisobutyleneLL0.241.39----------Dimethoxy ethane, 1,2-LL1.281.43----------68-12-2 Dimethylformamide, N,N-LL3.892.956.426.387.207.095.7357-14-7Dimethylhydrazine, 1,1-LL1.042.742.682.843.002.892.2967-68-5DimethylsulfoxideHL0.004.88----------123-91-1 Dioxane, 1,4-LL1.581.233.744.273.603.211.66106-89-8EpichlorohydrinLL1.722.022.302.412.071.271.95106-88-7Epoxybutane, 1,2-----2.672.542.161.892.6874-84-0EthaneG0.570.73----------64-17-5 EthanolLL2.04------------110-80-5 Ethoxy ethanol, 2-LL1.681.613.554.093.502.021.70141078-6Ethyl acetateLL0.843.13----------141-97-9 Ethyl acetoacetateHL3.023.13----------140-88-5 Ethyl acrylateLL0.72--2.492.642.181.161.0975-00-3Ethyl chlorideG -- --1.681.841.651.102.38105-39-5Ethyl chloroacetateLL1.971.47----------60-29-7 Ethyl EtherLL0.971.11----------100-41-4 EthylbenzeneLL0.703.140.770.760.660.511.08TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-8Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101b74-85-1EthyleneG0.524.49----------106-93-4 Ethylene dibromide----2.032.222.031.360.98107-06-2Ethylene dichlorideLL----1.371.591.411.191.42107-21-1Ethylene glycolc----24.8139.39N/R 33.1310.9175-21-8 Ethylene oxideG2.722.432.402.772.401.816.61107-15-3EthylenediamineLL1.782.46----------64-18-6 Formic AcidLL34.8733.21----------Formalin (37%formaldehyde/H2O)----18.8331.3927.6616.504.04556-52-5GlycidolLL8.425.23----------142-82-5 HeptaneLL0.300.75----------87-68-3 Hexachlorobutadienec----16.28c22.99c18.06c14.56c19.34c100-54-3 Hexane, N-LL0.310.721.421.491.330.931.49592-41-6Hexene, 1-LL0.392.92----------HydroxyacetoneLL8.709.34----------74-88-4 Iodomethane----8.068.767.354.590.7275-28-5IsobutaneG0.300.61----------115-11-7 IsobutyleneG2.426.33----------540-84-1 IsooctaneLL----1.051.050.890.560.9878-79-5IsopreneLL0.38------------78-59-1 Isophoronec----28.8040.71N/R 29.6917.76TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-9Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101b67-63-0IsopropanolLL0.901.35----------108-21-4 Isopropyl acetateLL0.681.25----------75-29-6 Isopropyl chlorideLL0.620.99----------590-86-3 IsovaleraldehydeLL0.552.04----------141-79-7 Mesityl oxideLL1.123.12----------78-85-3 MethacroleinLL1.273.10----------79-41-4 Methacrylic acidHL0.716.61----------67-56-1 MethanolLL5.691.8813.2417.34N/R 21.734.59111-90-0Methoxy-ethanol, 2-LL2.702.199.61c9.87cN/R 7.91c2.80c79-20-9 Methyl acetateLL1.801.76----------74-99-7 Methyl acetyleneG0.533.92----------74-83-9 Methyl bromideG -- --3.713.833.462.431.4774-87-3Methyl chlorideG1.752.451.972.381.971.271.7778-93-3Methyl ethyl ketoneLL0.571.121.781.841.591.192.92107-31-3Methyl formateLL3.471.93----------60-34-4 Methyl hydrazineLL----5.475.505.745.443.93108-10-1Methyl isobutyl ketoneLL----1.651.691.400.981.4680-62-6Methyl methacrylateLL0.992.362.022.161.810.921.84Methyl tert-butylketone----1.231.251.030.721.69108-11-2Methyl-2-pentanol, 4-LL1.701.94----------TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-10Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101bMethyl-2-pentanone, 4-LL0.491.54----------Methyl-3-butyn-2-OL, 2-LL0.51------------109-87-5 MethylalLL1.461.41----------100-61-8 Methylaniline, N-HL4.135.25----------108-87-2 MethylcyclohexaneLL0.380.85----------Methylcyclohexene, 1-LL0.332.22----------75-09-2 Methylene chlorideLL2.263.631.671.721.410.842.0677-75-8MethylpentynolLL1.172.82----------98-83-9 Methylstyrene, A-LL10.2431.46----------110-91-8 MorpholineLL0.921.93----------98-95-3 NitrobenzeneHL29.7740.6116.41c16.52cN/R 26.01c19.98c79-24-3 NitroethaneLL1.402.54----------75-52-5 NitromethaneLL3.325.25----------24332-01-4 Nitropropane, 2-LL1.061.771.861.911.601.063.29111-84-2Nonane-NLL1.625.54----------111-65-9 OctaneLL1.042.06----------Phenol (90% carboxylicacid)LL----16.3844.8947.01N/R 71.06109-66-0 PentaneLL0.420.62----------109-06-8 Picoline, 2-LL0.341.17----------74-98-6 PropaneG0.880.63----------TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-11Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101b123-38-6PropionaldehydeLL1.191.654.014.273.952.534.7979-09-4Propionic acidLL1.343.51----------71-23-8 Propyl alcoholLL0.911.55----------103-65-1 Propylbenzene, N-LL0.445.97----------115-07-1 PropyleneG0.792.80----------78-87-5 Propylene dichlorideLL----1.491.481.260.841.3775-56-0Propylene oxideLL0.801.152.022.141.781.263.0975-55-8Propyleneimine, 1,2-----1.751.521.531.332.31110-86-1PyridineLL0.411.17----------100-42-5 StyreneLL4.1636.831.101.080.930.571.3696-09-3Styrene OxideL -- --2.612.492.062.613.0379-34-5CTetrachloroethane,1,1,1,2-LL3.006.52----------Tetrachloroethane,1,1,2,2-LL6.0614.141.641.691.661.141.52127-18-4TetrachloroethyleneLL3.1611.461.772.091.721.200.74108-88-3TolueneLL0.332.320.870.870.760.571.25120-82-1Trichlorobenzene, 1,2,41.350.3912.5516.71N/R 18.6616.5871-55-6 Trichloroethane, 1,1,1-LL0.792.411.091.161.030.701.8579-00-5Trichloroethane, 1,1,2-LL1.263.681.191.271.110.791.3379-01-6TrichloroethyleneLL0.943.352.262.602.141.251.0996-18-4Trichloropropane,1,2,3-LL0.952.23----------TABLE D-1. RESPONSE FACTORS AT ACTUAL CONCENTRATIONS OF 10,000 PPMV AND 500 PPMV (Cont.)

D-12Actual Concentration:10,000 ppmVActual Concentration: 500 ppmVCAS No.#Compound NameVolatilityClassFoxboroOVA - 108aBacharachTLVaFoxboroOVA - 108aFoxboroOVA - 128aFoxboroOVA - 128aHeathDP IIIaHNUHW - 101b121-44-8TriethylamineLL0.461.410.470.490.480.350.73108-05-4Vinyl acetateLL1.313.993.633.362.801.482.07593-60-2Vinyl bromideG -- --2.142.412.331.681.3775-01-4Vinyl chlorideG0.651.102.032.112.111.762.18Vinyl propionateLL0.940.70----------75-35-4 Vinylidene chlorideLL1.152.382.732.972.611.791.70106-42-3Xylene, P-LL2.275.350.890.880.740.540.93108-38-3Xylene, M-LL0.303.560.890.890.750.540.9695-47-6Xylene, O-LL0.361.400.950.950.800.601.09N/R = No responsea= Calibrated with methane in air.b= Calibrated with benzene in air.c= Volatility problem with compound.APPENDIX E

SELECTION OF SAMPLE SIZE FOR SCREENING CONNECTORSAPPENDIX E

SELECTION OF SAMPLE SIZE FOR SCREENING CONNECTORS

In estimating emissions for a given process unit, all equipment components must be surveyed for each class of components. The one exception to this "total component screening" criterion is the category of connectors. Note however, that if the process unit is subject to a standard which requires the screening of connectors, then all connectors must be screened. In typical process units, connectors represent the largest count of individual equipment components, making it costly to screen all components. The purpose of this appendix is to present a methodology for determining how many connectors must be screened to constitute a large enough sample size to identify the actual screening value distribution of connectors in the entire process unit. Please note that the sampling is to be a random sampling throughout the process unit. The basis for selecting the sample population to be screened is the probability that at least one "leaking" connector will be in the screened population. The "leaker" is used as a representation of the complete distribution of screening values for the entire class of sources. The following binomial distribution was developed to approximate the number of connectors that must be screened to ensure that the entire distribution of screening values for these components is represented in the sample:

n ≥ N × {1 - (1 -p) 1/D ] (E-1)

where:

N = Number of connectors;
D = (fraction of leaking connectors) × N; and

p ≥ 0.95.

E-1Refer to figure E-1, which shows the fraction of leaking connectors at several leak definitions based on currently available data. Since the fraction of leaking connectors will most likely not be known prior to screening, the leaking fraction at the intersection of the SOCMI average emission factor line and applicable leak definition line on figure F-1 can be used to estimate what the fraction of leaking connectors will be. Entering this value into equation E-1 for at least a 95 percent confidence interval (p = 0.95) will give the minimum number of connectors that need to be screened. A larger sample size will be required for units exhibiting a lower fraction of leaking

connectors. After ’n’ connectors have been screened, an actual leak frequency should be calculated as follows:
Leaking frequency = Number of leaking connectors (E-2) n
Then, the confidence level of the sample size can be calculated using the following equation, based upon a hypergeometric distribution:

P=1- (N-D’)! (N-n)! (E-3) N! (N-D’-n)!

where:
N = Total population of connectors;
n = Sample size; and

D’ = Number of leaking connectors × N n
If ’p’ calculated in this manner is less than 0.95, then a less than 95 percent confidence exists that the screening value distribution has been properly identified. Therefore, additional connectors must be screened to achieve a 95 percent confidence level. The number of additional connectors required to satisfy the requirement for a 95 percent confidence level can be calculated by solving Equation (E-1) again, using the leak frequency calculated in Equation (E-2), and subtracting the

E-2Figure E-1. Fraction of Leaking Connectors at Several Leak Definitions

E-3original sample size. After this additional number of connectors have been screened, the revised fraction of leaking components and the confidence level of the new sample size (i.e., the original sample size plus the additional connectors screened) should be recalculated using Equation (E-3). The Agency requires sufficient screening to achieve a 95 percent confidence level, until a maximum of 50 percent of the total number of connectors in the process unit have been screened. The EPA believes that 50 percent of the total connector population is a reasonable upper limit for a sample size. If half of the total number of connectors are screened, no further connector screening is necessary, even if a 95 percent confidence level has not been achieved.

E-4APPENDIX F

REFERENCE METHOD 21

(Code of Federal Regulations, Title 40, Part 60, Appendix A. Reference Method 21, Determination of Volatile Organic Compound Leaks. Washington, D.C., U.S. Government Printing Office. Revised June 22, 1990.)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

F-1concentration and the local ambient concentration is determined. A difference based on the meter readings of less than a concentration 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.

F-23.1.2 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 meter readings

F-3during 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.

F-4e. Process Drains - For open drains, place the probe inlet as near as possible to the 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 periphery.
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, Accumulator Vessel 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

F-5liquid leakage. Sources that have these conditions present must be surveyed using the instrument technique of section 4.3.1 or 4.3.2.

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 algebraic difference 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.

F-64.4.3 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.

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.

F-7APPENDIX G

DEVELOPMENT OF LEAK RATE VERSUS FRACTION LEAKING EQUATIONS AND DETERMINATION OF LDAR CONTROL EFFECTIVENESSAPPENDIX G

The purpose of this appendix is to provide additional information on the approach used to develop the average leak rate versus fraction leaking equations presented in chapter 5.0. Also, background information is presented on the determination of control effectiveness of LDAR programs at SOCMI process units and refinery process units.

G.1 DEVELOPMENT OF AVERAGE LEAK RATE VERSUS FRACTION LEAKING EQUATIONS In chapter 5.0, tables 5-4 and 5-5 present equations that predict average leak rate based on the fraction leaking at SOCMI process units and refinery process units, respectively. Equations are presented for gas valves, light liquid valves, light liquid pumps, and connectors, and each of the equations are plotted in figures 5-1 through 5-8. The equations are expressed in the following format:

Average Leak Rate = (Slope × Fraction Leaking) + Intercept

The average leak rate has units of kilograms per hour per source. The fraction leaking is the fraction of sources that screen greater than or equal to the applicable leak definition. The leak definition is the screening value at which a leak is indicated. (For example an equipment leak regulation may have a leak definition of 10,000 ppmv.) Equations were developed for several possible leak definitions. Using the applicable equation, if it is known what percentage of sources screen greater than or equal to the leak definition, then an overall average leak rate for all sources can be estimated. If the fraction leaking before and after an LDAR program is implemented are known, then the average leak rates before and after the program can be determined. These average leak rates before and after the program are used to calculate the control efficiency of the program.

G-1The leak rate versus fraction leaking equations were developed using the following procedure: STEP 1: Determine average emission factors for (1) screening values greater than or equal to the applicable leak definition, and (2) screening values less than the applicable definition. STEP 2: The average emission factor for screening values less than the leak definition is the intercept in the equation. STEP 3: The average emission factor for screening values greater than or equal to the leak definition minus the average emission factor for screening values less than the leak definition is the slope in the equation. An example of the above steps is presented for gas valves in a SOCMI process units for a leak definition of 10,000 ppmv. From table 2-4 the gas valve > 10,000 ppmv emission factor is 0.0782 kg/hr and the <10,000 ppmv factor is 0.000131 kg/hr. Thus, the equation relating average leak rate to fraction leaking for SOCMI gas valves with a leak definition of 10,000 ppmv is as
follows:

Avg Leak Rate (kg/hr) = [(0.0782-0.000131) × FL] + 0.000131 = (0.0781 × FL) + 0.000131

where:
FL = Fraction leaking.

Notice that when applying the above equation if 100 percent of the gas valves screened less than 10,000 ppmv, the equation predicts an average leak rate equal to the <10,000 ppmv factor. Similarly, if 100 percent of sources screened greater than or equal to 10,000 ppmv, the equation predicts an average leak rate equal to the > 10,000 ppmv factor. For SOCMI process units, equations were developed for each of the equipment types for leak definitions of 500 ppmv, 1,000 ppmv, 2,000 ppmv, 5,000 ppmv, and 10,000 ppmv. For each of the leak definitions, the greater than or equal to factors and the less than factors were developed by entering the applicable

G-2screening data from the combined screening data set into the applicable revised SOCMI correlation equation (see appendix B). For example, the <500 ppmv factor for connectors was estimated by entering all connector screening data with values less than 500 ppmv from the combined screening dataset into the revised SOCMI connector correlation equation. The sum of total emissions divided by the number of screening values gives the <500 ppmv connector average emission factor. For refinery process units, equations were developed for each of the equipment types for leak definitions of 500 ppmv, 1,000 ppmv and 10,000 ppmv. The refinery > 10,000 ppmv and <10,000 ppmv emission factors had previously been developed and are presented in table 2-5. The same approach used to develop
the > 10,000/<10,000 ppmv refinery factors was used to develop the factors for leak definitions of 500 ppmv and 1,000 ppmv. This approach involves using information from the Refinery Assessment Study (EPA-600/2-80-075c) on the cumulative distribution of emissions and screening values.

G.2 CONTROL EFFECTIVENESS CALCULATIONS In addition to the equations described in section G.1, chapter 5.0 presents estimated control effectiveness values at SOCMI and refinery process units for control equivalent to: (1) Monthly LDAR program with a leak definition of 10,000 ppmv; (2) Quarterly LDAR program with a leak definition of 10,000 ppmv; and (3) Control equivalent to the LDAR program required by the proposed hazardous organic NESHAP equipment leaks negotiated regulation. Tables G-1 and G-2 summarize how the control effectiveness values of the above LDAR programs were determined for SOCMI and refinery process units, respectively. The approach for calculating the control effectiveness of a LDAR program is discussed in detail in chapter 5.0. The approach involves determining the average leak rate before and after the LDAR program is implemented. The average leak rates before and

G-3TABLE G-1. DETERMINATION OF LDAR CONTROL EFFECTIVENESS AT SOCMI PROCESS UNITSEquipmenttypeControlprogramLeakdefinition(ppmv)Initial leakfraction(percent)Initialleak rate(kg/hr)Steady-state leak fraction after LDARimplemented (percent)Finalleakrate(kg/hr)LDAR controleffectiveness(percent)Immediatelyafter LDARmonit.Immediatelyprior toLDAR monit.CycleaverageLL Valves Monthly100004.30.00400.200.880.54 0.0006484Quarterly100004.30.00400.592.611.60 0.0015961HON reg neg5008.50.00400.002.001.00 0.0005088Gas Valves Monthly100007.50.00600.291.290.79 0.0007587Quarterly100007.50.00600.863.802.33 0.0019567HON reg neg50013.60.00600.002.001.00 0.0004592LL PumpsMonthly100007.50.01990.003.531.77 0.0061369Quarterly100007.50.01990.007.503.75 0.0109245HON reg neg100017.10.01990.008.044.02 0.0050175ConnectorsHON reg neg5003.90.00180.000.500.250.0001393

G-4TABLE G-2. DETERMINATION OF LDAR CONTROL EFFECTIVENESS AT REFINERY PROCESS UNITSEquipmenttypeControlprogramLeakdefinition(ppmv)Initial leakfraction(percent)Initialleak rate(kg/hr)Immediatelyafter LDARmonit.Immediatelyprior toLDAR monit.CycleaverageFinalleak rate(kg/hr)LDAR controleffectiveness(percent)LL ValvesMonthly1000011.0 0.01090.391.72 1.06 0.0025876Quarterly 10000 11.0 0.0109 1.15 5.07 3.11 0.00430 61HON reg neg 500 28.5 0.0109 0.00 2.00 1.00 0.00057 95Gas Valves Monthly 10000 10.0 0.0268 0.36 1.60 0.98 0.00317 88Quarterly 10000 10.0 0.0268 1.06 4.69 2.88 0.00813 70HON reg neg 500 24.0 0.0268 0.00 2.00 1.00 0.00120 96LL Pumps Monthly 10000 24.0 0.1140 0.00 11.28 5.64 0.03597 68Quarterly 10000 24.0 0.1140 0.00 24.00 12.00 0.06300 45HON reg neg 1000 48.0 0.1140 0.00 10.00 5.00 0.01365 88ConnectorsHON reg neg5001.70.000250.000.500.250.0000581

G-5after implementing the LDAR program are estimated by entering the fraction leaking before and after implementing the program into the equations described in section G.1. For SOCMI process units, the fraction leaking before implementing the LDAR program was based on the percentage of equipment screening above the applicable leak definition in the combined SOCMI screening dataset. (See appendix B.) Similarly, the initial fraction leaking for refinery process units was based on data from the Refinery Assessment Study on the percentage of equipment screening above the applicable leak definition. Note that each of the initial leak fractions predict leak rates equal to the applicable SOCMI or refinery average emission factors (tables 2-1 and 2-2) when entered into the applicable equation described in section G.1. In other words, when estimating the control effectiveness for the SOCMI and refinery LDAR programs, it has been assumed that prior to implementing the program equipment leak emissions are equivalent to emissions that would be predicted by the average emission factors. The fraction leaking after implementing the LDAR program is assumed to be the average of the "steady-state" fraction leaking immediately before and after a monitoring cycle (see discussion in chapter 5.0). The following parameters are used to estimate the steady-state leak fractions:
recurrence rate, unsuccessful repair rate, and

occurrence rate. The values used for these parameters are summarized in table G-3 for both SOCMI and refinery process units. The paragraphs below summarize the approach used to determine the above parameters. First, the approach used to determine the parameters in a program with a leak definition of 10,000 ppmv is described. Then, the approach used to determine the parameters in a program equivalent to the proposed hazardous organic NESHAP equipment leaks negotiated regulation is described.

G-6TABLE G-3. PARAMETERS USED TO CALCULATE STEADY-STATE LEAK FRACTION AFTER LDAR PROGRAM IS IMPLEMENTED

Equipment type Control program Leak definition

(ppmv) Recurrence rate a (percent) Unsuccessful repair rate a

(percent) Initial leak fraction b (percent) Occurrence rate c (percent)

PARAMETER VALUES FOR SOCMI PROCESS UNITS

LL Valves Monthly 10000 14 10 4.3 0.68
Quarterly 10000 14 10 4.3 2.03
HON reg neg 500 0 0 8.5 2.00

Gas Valves Monthly 10000 14 10 7.5 1.00
Quarterly 10000 14 10 7.5 2.97
HON reg neg 500 0 0 13.6 2.00

LL Pumps Monthly 10000 0 0 7.5 3.53
Quarterly 10000 0 0 7.5 7.50
HON reg neg 1000 0 0 17.1 8.04

Connectors HON reg neg 500 0 0 3.9 0.50

PARAMETER VALUES FOR REFINERY PROCESS UNITS

LL Valves Monthly 10000 14 10 11.0 1.34
Quarterly 10000 14 10 11.0 3.97
HON reg neg 500 0 0 28.5 2.00
Gas Valves Monthly 10000 14 10 10.0 1.24
Quarterly 10000 14 10 10.0 3.67
HON reg neg 500 0 0 24.0 2.00

LL Pumps Monthly 10000 0 0 24.0 11.28
Quarterly 10000 0 0 24.0 24.00
HON reg neg 1000 0 0 48.0 10.00

Connectors HON reg neg 500 0 0 1.7 0.50

a The recurrence rate and unsuccessful repair rate for valves and pumps in LDAR programs with a leak

definition of 10,000 ppmv was obtained from the SOCMI Fugitives AID (EPA-450/3-82-010). For the HON reg neg, a simplifying assumption was made that the recurrence rate and unsuccessful repair rate equal zero percent for all equipment types.
b The initial leak fraction for SOCMI process units is based on the combined screening dataset. The initial

leak fraction for refinery process units is based on data collected in the Refinery Assessment Study (EPA-600/2-8--075c).

c The occurrence rate for LDAR programs with a leak definition of 10,000 ppmv is calculated as a function of

the initial leak fraction. The relationship is based on data collected in the Six Unit Maintenance Study (EPA-600/S2-081-080). The equations for valves and pumps are as follows: Valve 30 Day Occurrence rate = 0.0976 * leak fraction + 0.264. Pump 30 Day Occurrence rate = 0.47 * leak fraction. The quarterly occurrence rate is approximately 3 times the 30-day occurrence rate. In cases where the quarterly occurrence rate exceeded the initial leak fraction, it was set equal to the initial leak fraction. The occurrence rate for the HON reg neg LDAR programs is set equal to the performance level, except for pumps in SOCMI process units. For pumps in SOCMI process units the occurrence rate is calculated using the equation above.

G-7G.2.1 LDAR Program with Leak Definition of 10,000 ppmv

. Estimates for the recurrence rate and unsuccessful repair rate were obtained from the Fugitive Emissions Additional Information document (EPA-450/3-82-010). In this document, data collected for LDAR programs with a leak definition of 10,000 ppmv were summarized. It was concluded that the recurrence rate for valves was 14 percent and the unsuccessful repair rate for valves 10 percent. It was assumed that all pumps are replaced with a
new seal and for that reason the recurrence rate and unsuccessful repair rate for pumps were both assumed equal to zero percent (i.e., all pumps are successfully repaired and leaks do not recur). Data were unavailable for connectors for an LDAR program with a leak definition of 10,000 ppmv, and, for this reason, control efficiency for connectors in an LDAR program with a leak definition of 10,000 ppmv have not been estimated. Estimates for the occurrence rate were based on data collected in the Six Unit Maintenance Study (EPA-600/S2-081-080). Data from this study indicated that the occurrence rate is a function of the initial leak fraction. For valves this relationship was expressed by the following equation:

OCC valve = 0.0976 (LF) + 0.264 where:

OCC valve = Monthly occurrence rate for valves; and

LF = Initial leak fraction.

For pumps, the relationship was as follows:
OCC pump = 0.47 × LF
where:

OCC pump = Monthly occurrence rate for pumps; and

LF = Initial leak fraction.

G-8For both pumps and valves, the monthly occurrence rate was used to estimate the quarterly occurrence rate using the following equation: Q = M + M (1 - M) + M {1 - [M + M (1 - M)]}

where:
M = Monthly occurrence rate; and Q = Quarterly occurrence rate.

Note that in cases where the estimated quarterly occurrence rate exceeded the initial leak fraction, it was set equal to the initial leak fraction. G.2.2 Control Equivalent to the LDAR Program Required by the Proposed Hazardous Organic NESHAP Equipment Leaks Negotiated Regulation For each of the equipment types, the proposed hazardous organic NESHAP LDAR program requirements include a performance level requirement. This performance level specifies the allowable leak fraction once the program is in place. For example, the performance level for valves is 2 percent. Because the proposed hazardous organic NESHAP rule contains the performance level requirement and because limited data are available on LDAR programs with the leak definitions of the proposed hazardous organic NESHAP rule, simplifying assumptions were made when estimating the recurrence rate, unsuccessful repair rate, and occurrence rate. For each of the equipment types, it was assumed that the recurrence rate and unsuccessful repair rate were equal to zero percent. These two parameters have the least impact on the predicted control efficiency. For valves and connectors, the proposed hazardous organic NESHAP rule allows for reduced monitoring frequency if the leak fraction remains below the performance level. For this reason, it was assumed that process units would monitor valves and connectors at whatever monitoring frequency (i.e., monthly, quarterly, annually, etc.) that allows them to meet the performance level. Thus, for valves and connectors the

G-9occurrence rate was set equal to the performance level. Note that in cases where process units remain below the performance level this may overestimate the occurrence rate. However, this is offset by the assumption that the recurrence rate and unsuccessful repair rate are equal to zero percent. For pumps the proposed hazardous organic NESHAP rule requires monthly monitoring. For this reason the occurrence rate was calculated using the same equation for pumps as presented in section G.2.1 for LDAR programs with a leak definition of 10,000 ppmv. Note, however, that the initial leak fraction used in the equation was the leak fraction associated with the leak definition of the proposed hazardous organic NESHAP rule (1,000 ppmv). For refineries, the predicted occurrence rate for pumps exceeded the performance level, and for this reason the occurrence rate was set equal to the performance level.

G-10TECHNICAL REPORT DATA (Please read Instructions on the reverse before completing)

1. Report No. EPA-453/R-95-017 2. 3. RECIPIENT’S ACCESSION NO.

4. TITLE AND SUBTITLE 1995 Protocol for Equipment Leak Emission Estimates 5. REPORT DATA November 1995

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S) David L. Epperson 8. PERFORMING ORGANIZATION REPORT NO. DCN: 95-652-015-55-05

9. PERFORMING ORGANIZATION NAME AND ADDRESS Radian Corporation P.O. Box 13000 Research Triangle Park, NC 27709 10. PROGRAM ELEMENT NO.

11. CONTRACT/GRANT NO. 68-D1-0117, WA 155

12. SPONSORING AGENCY NAME AND ADDRESS Director, Office of Air Quality Planning and Standards U.S. Environmental Protection Agency Research Triangle Park, N.C. 27711 13. TYPE OF REPORT AND PERIOD COVERED

14. SPONSORING AGENCY
EPA/200/04

15. SUPPLEMENTARY NOTES Project Officer is David W. Markwordt, Mail Drop 13 (919)-541-0837

16. ABSTRACT The report presents standard protocols for estimating mass emissions from equipment leaks. Different approaches for estimating equipment leak emissions are described and several topics relevant to estimating equipment leak emissions (such as speciating emissions) are addressed. Information on how to perform a screening survey at a process unit is presented. Information on how a process unit can collect equipment leak rate data by enclosing individual equipment pieces and measuring mass emissions is provided. Also, information if provided that can be used to estimate the control efficiency of equipment leak control techniques. The document will help facilities generate accurate plant-specific equipment leak emission estimates.

17. KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group

Synthetic Organic Chemical Manufacturing Petroleum Refining Organic Compounds Fugitive Emissions Equipment Leaks Response Factors Screening Data Bagging Data Leak Detection and Repair

18. DISTRIBUTION STATEMENT Release to Public 19. SECURITY CLASS (This Report) Unclassified 21. NO. OF PAGES 400

20. SECURITY CLASS (This page)

Unclassified 22. PRICE

EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE