P.1 

OAR Box 1338 

Prepped by Ollie Stewart 

Document Number: 

4) ll-E-15 

Docket Number: 

A-89-10 

Printed 6/17/2008 1:48:05 PM Sheet 4 of 105 
P.2 

LAW OFFICES 

PHILIP J. HARTER 

SUITE 404 

2301 M STREET. N.W. 

WASHINGTON, D.C. 20037 

A-89-10 

(202) 887-1033 

FAX: (202) 887.1036 

February 27. 1990 

II-E-1 5 

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MEMORANDU M 

To: EPA Negotiated Rulemaking Committee on Fugitive Emissions from Equipment Leaks and Interested 

Parties 

Fr: Philip J. Harter 

Facilitator (S 

Re: Minutes of February 22-23 Meeting; Future Meetings; Workgroup Meeting 

I enclose the minutes of the February 22-23 meeting that were prepared by Radian Corporation. As 

before, the materials that were distributed at the meeting are attached. I have also enclosed a tentative 

agenda for the meeting. 

The Batch Processing workgroup will meet at 11:00 on Monday, March 26 at the Guest Quarters Hotel 

(formerly the Pickett Suite Hotel), 2515 Meridian Parkway, Research Triangle Park, NC; 919-361-4660, in the 

same room where the full committee will meet the following day. For additional information, contact Cheryl 

Sutterfield of PMA at 202-835-3548. As always, all Committee members and their designees are welcome. 

The next meeting of the Committee will be on March 27-28 at the Guest Quarters Hotel, 2515 

Meridian Parkway, Research Triangle Park, NC; 919-361-4660. This is the same hotel where we have been 

meeting; it changed its name from Pickett Suites on February 1. Since it reduces the price of the meeting 

rooms, please identify yourself as an EPA Fugitive when making reservations. 

The following meeting will be on April 25-26 at The Conservation Foundation, Suite 500, 1250 24th 

Street NW, Washington, DC. Since we will not be meeting at a hotel, we have not booked any rooms for this 

meeting. To facilitate your finding CF and an appropriate hotel, I enclose a map indicating CPs location (it is 

two blocks due north of the Bristol Hotel where we met last time) and a list of hotels in the area. Since that is 

"Earth Week", you may be well advised to make your reservation early. 

All the meetings will begin at 10:00 on the first day and 9:00 on the second. They will run until about 

5:00 on the first day and about 4:00 on the second. As the experience this time indicated, we may well need 

all the time scheduled, so please come prepared to stay for the duration: things often get interesting and time 

consuming at this stage. 
P.3 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS FROM EQUIPMENT LEAKS 

AGENDA FOR MEETING OF MARCH 27-28 

Administrative 

• Introductions 

• Review of the Agenda: additions, subtractions, order 

• Minutes of February meeting: Any major heartburns 

Scope of the Standard 

• Sources included in the negotiations 

• Sources excluded from this standard 

Data 

• Any new data for the Committee's consideration 

• Discussion of data 

• Any additional data being developed or that is essential for the Committee's deliberations 

The Standard 

• MACT 

• Response factors 

• Phasing 

• Incentives 

• De minimis cutoff 

• Miscellaneous points raised at prior meetings 

• Equivalent approaches 

Report of the Batch Processing Workgroup 

Emission Factors 

• Status of modelling approach 

• Matrix approach 

• Correlation curves 

Approaches to assessing the cost of the standard 

Discussion of the Strawman Rule 

Schedule: Future Meetings, Workgroups 
r\r\ 

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UO* 

The Conservation Foundation 

P.4 

The Conservation 

Foundation 

1250 Twenty-fourth Street. NW Washington. DC 20037 USA 202/293-4800 Telex: 64505 PANDA 

Affiliated with World Wildlife Fund 
P.5 

The Conservation Foundation 

: September 1989 

Hotels near The Conservation Foundation's Offices 

Carlyle Suites Hotel 

1731 New Hampshire Avenue, NW 

202/234-3200 

(10-block walk to the office) 

Rate: $69 (mention CF or WWF when calling) 

Dupont Plaza Hotel 

1500 New Hampshire Avenue, NW 

202/483-6000 

(7-block walk to the office) 

Rate: $125-$145 

Government Rate: $78-$98 

Embassy Square Suites (Quality Inn) 

2000 N Street, NW 

202/659-9000 

(4-block walk to the office) 

Rate: $110-125 - including continental breakfast 

Government Rate: $78 

(mention CF or WWF when calling) 

Embassy Suites 

1250 22nd Street, NW 

202/857-3388 

(1-block walk to the office) 

Rate: $164 including full-breakfast and "happy-hour" 

Government Rate: $87 - $139 

Hampshire Hotel 

1310 New Hampshire Avenue, NW 

202/296-7600 

(4-block walk to the office) 

Rate: $90 (mention CF's name when calling) 

Government Rate: $75 

One Washington Circle 

1 Washington Circle, NW 

202/872-1680 

(4-block walk to the office) 

Rate: $99-$150 

Government Rate: $78 

1250 Twenty-fourth Street, NW Washington, DC 20037 USA 202/293-4800 Telex: 64505 PANDA 

Affiliated with World Wildlife Fund 
P.6 

Ramada Renaissance 

1143 New Hampshire Avenue, NW 

202/775-0800 

(4-block walk to the office) 

Rate: $150-$155 

Government Rate: 

St. James Hotel 

950 24th Street, NW 

202/457-0500 

(3-block walk to the office) 

Rate: $115 including continental breakfast (two-night minimum 

stay) 

Government Rate: $77.25 

Tabard Inn 

1739 N Street, NW 

202/785-1277 

(7-block walk to the office) 

Rates: $79-99 including breakfast 

Washington Marriott 

1221 Twenty-Second Street, NW 

202/872-1500 

(2-block walk to the office) 

Rate: $165 

Government Rate: $85 

Westin Hotel 

M and 24th Streets, NW 

202/429-2400 

(Next-door to the office) 

Rates: $165-195 

Government Rate: $110 
P.7 

REGULATORY NEGOTIATION MEETING ON FUGITIVE EQUIPMENT LEAKS 

FEBRUARY 22-23, 1990 

WYNDHAM BRISTOL HOTEL 

WASHINGTON, D.C. 

DRAFT MEETING MINUTES 

These meeting notes summarize issues discussed and provide an informal 

record of administrative and logistical decisions made on schedules and action 

items. All presentation materials distributed during the two-day meeting are 

attached: 

Attachment 

Attachment 

Attachment 

Attachment 

Attachment 

Attachment 

Attachment 

Attachment 

Attachment 

Attachment 

Attachment 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

Meeting Agenda 

Attendees February 23, 1990 

Revisions to January 17-18 meeting notes 

Comparison of Emissions and Emission Factors 

Summary of Data Quality Workgroup 

Percent Leakers at Various Leak Definitions 

Summary of TACB Equipment Surveys 

Pump Seals Information 

Approach to 

Approach to 

Approach to 

the 

the 

the 

Standard 

Standard 

Standard 

Attachment 12 

Attachment 13 

Attachment 14 

Conceptual 

Conceptual 

Conceptual 

Agencies 

Emission Factors Versus Leak Frequency 

Summary of Batch Processes Workgroup 

EPA Strawman Equipment Leaks Regulation 

Harter 

API 

NRDC and State 

Minutes of Previous Meeting 

Ms. Karen Fidler of CMA submitted in writing CMA's suggested 

changes to the minutes of the previous full committee meeting 

(January .17-18, 1990). Changes in the minutes are contained in 

Attachment 3. 

Scope of the Standard 

Mr. Bob Ajax of EPA described the role that this regulatory 

negotiation will play in the Agency's promulgation of a Hazardous 

Organic NESHAP (HON). Under the HON, the Agency intends to 

promulgate standards for controlling toxic emissions from 

equipment leaks, wastewater, process vent, storage, and transfer 

operations for as many as 150 source categories. The negotiating 

committee will develop the generic equipment leaks standard. The 

Agency will estimate environmental, cost, and economic impacts of 

the resulting combined generic standards and promulgate the 

standards under Title III of the expected Clean Air Act revisions. 

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P.8 

Data 

The Agency will distinguish organic chemical processes located in 

refineries or on refinery property, which would be regulated under 

the HON, from petroleum refinery processes that would be excluded 

from the HON. Mr. Larry Goodheart of API offered to assist EPA in 

defining petroleum refinery processes. 

Mr. Ajax initiated a discussion of a de minimis stream 

concentration cutoff below which equipment would be exempt from 

the negotiated standard. Mr. Ajax stated that the concentration 

cutoff of 10 percent (by weight) specified in existing equipment 

leaks regulations should be lowered, since lower concentration 

streams dominate the equipment leak emissions inventory as tighter 

controls have been placed on higher concentration streams. Using 

some of the emission factors listed in Attachment 4, Mr. Ajax 

presented an informal analysis indicating that the bulk of 

equipment leak toxic emissions in SOCMI processes are attributable 

to those streams containing greater than one to five percent toxic 

organies; however, the same conclusion may not be applicable for 

organic chemical processes in refineries, where many streams 

contain less than 10 percent toxic organies. Several committee 

members expressed concern that the emission reduction achievable 

by controlling very low concentration streams may not justify the 

costs of control. 

Mr. Rick Colyer of EPA summarized the conclusions of the workgroup 

meeting that was held in January to identify usable butadiene (BD) 

and ethylene oxide (EO) screening data (See Attachment 5). The 

committee agreed to use data in whole or in part from ten BD and 

nine EO plants. 

The EPA corrected the usable data to adjust for the response 

factor of each monitoring instrument, and presented a revised 

analysis showing the percent leakers by component type for various 

leak definitions (See Attachment 6) . Some committee members 

expressed concern that response factor correction may be difficult 

to perform simultaneously with equipment screening, especially for 

mixed'HAP streams. Mr. Ajax suggested that the highest response 

factor from all streams within a plant may be used as a default 

response factor. While some committee members objected to this 

suggestion, consensus was reached that an accurate, easy-to-use 

methodology for adjusting actual screening values for response 

factor should be developed during future negotiation meetings. 

Mr. Les Montgomery of TACB presented a summary of equipment 

screening surveys from three plants currently complying with a 

regulation in the state of Texas that requires quarterly leak 

detection and repair, directed maintenance, and a 500 ppmv leak 

definition and trigger for maintenance (See Attachment 7) . The 

results indicated that all three plants were able to meet the 

requirements of the regulation while simultaneously lowering the 

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P.9 

number of leaking gas/vapor and light liquid valves and light 

liquid pump seals. Some committee members wanted to examine the 

TACB data in greater detail, including whether or not the 

screening values were corrected for response factors. 

. Several committee members expressed concern about the 

appropriateness of using data from a limited number of chemical 

production processes to set a standard reflecting maximum 

achievable control technology (MACT) for all 191 chemicals listed 

in the proposed Clean Air Act (CAA) amendments. 

Mr. Ajax identified the type of pump seals used at each of the BD 

and EO plants that the committee is using to set the level of the 

standard (See Attachment 8) . 

Leak definition and allowable leakers: MACT 

The committee discussed several combinations of leak definition 

and allowable leak frequencies for use in Phase III of the 

standard. All committee members agreed that the leak definition 

should be high enough to minimize the effects of operator and 

instrument variability while simultaneously providing an 

environmental benefit at a reasonable cost. Discussion focused on 

a leak definition ranging from 250 to 1,000 ppm and an allowable 

limit ranging from about one to three percent. 

Several committee members expressed concern that a leak definition 

below 1,000 ppmv was not appropriate for several reasons. First, 

screening data may be less accurate at lower screening values due 

to increased instrument variability. Second, repair or 

replacement of equipment that emits at yery low concentrations may 

actually increase emissions more than if the equipment had 

remained in service with continual monitoring. 

. Several committee members expressed concern that BD plants would 

not be able to achieve the lowest leak definitions and allowable 

leak frequencies proposed by some committee members. They pointed 

out that many BD plants do not achieve these levels, and that 

individual plant motivation may not provide sufficient impetus for 

achieving MACT. They expressed concern that E0 plants may meet 

lower allowable leak frequencies more easily because they shut 

down more frequently. They asserted that many BD facilities (and 

possible other facilities producing some of the 191 CAA chemicals) 

could suffer economic hardship by having to shut down as 

frequently as EO plants in order to repair leaks. Mr. Ajax stated 

that no information currently exists that suggests BD plants could 

not meet any of the proposed performance levels if the plants 

instituted improved quality assurance procedures. He noted that 

low leak frequencies have been achieved with a 500 ppm LDAR 

program, as shown by the TACB screening surveys that Mr. 

Montgomery provided. 

cao.027a 
P.10 

A discussion arose as to which plants should constitute the basis 

for MACT. One suggestion was that all of the EO plants reflect 

MACT, since they appear to be well controlled relative to the 191 

CAA chemicals. Several committee members disagreed, saying that 

only the best-controlled plants should reflect MACT, and a few of 

the EO plants could not be considered best-controlled. 

Conceptual Approach to the Standard 

Several draft frameworks for the equipment leaks standard were 

proposed (See Attachments 9, 10, and 11). In general, the basis 

is a quarterly LDAR program for valves, with a 250 to 1,000 ppmv 

leak definition. The maximum allowable leak frequency in the 

proposals ranged from less than one (for annual sampling) to three 

percent. More frequent monitoring would be required if a plant 

exceeds the allowable leak frequency (or some multiple of the 

allowable leak frequency) and less frequent monitoring would be 

permitted if a plant performs better than the allowable leak 

frequency (or some fraction of the allowable leak frequency). 

1

 This concept is based, in part, on the statistical, quality 

assurance type sampling plan suggested previously by CMA. EPA and 

some other committee members felt that, in order to use less 

frequent monitoring, plants should demonstrate performance below 

the allowable leak frequency. Other committee members felt that 

the cost benefits associated with less frequent monitoring provide 

sufficient incentive for plants to perform below the allowable 

leak frequency, so a performance level below the allowable leak 

frequency should not be specified. 

Committee members discussed the issue of a "death penalty" for 

plants that continually demonstrate noncompliance with the 

standard. Several committee members suggested a "close and 

repair" penalty rather than creating a "non-compliance" approach. 

Several committee members expressed concern that no one on the 

negotiating committee can predict whether all of the plants 

producing the 191 CAA chemicals will be able to comply with the 

proposed standard, and that there should be a "safety valve" 

allowing non-complying plants to remain in operation if they are 

demonstrating ^improvement. Mr. Ajax indicated that EPA's interest 

was in achieving low emissions - not penalties or closures. 

Consistent with that, he suggested that the committee might build 

in a requirement for continual progress at plants that did not 

initially meet the limit with monthly LDAR. 

Industry members discussed awards for plants demonstrating 

exemplary performance, including tax credits, emission credits, in 

toto emission reduction, and less frequent inspection audits. Mr. 

Ajax agreed to look into the possibility of "awards" but thought 

that the other suggestions were probably beyond the negotiation 

scope. 

cao.027a 
P.11 

Committee members agreed that the issue of random sampling should 

be abandoned for the purposes of this negotiated regulation. 

Mr. Phil Harter reminded the committee members that several 

miscellaneous issues raised by CMA at previous meetings will need 

resolution at future negotiation meetings. 

Committee members discussed procedures for determining equivalent 

approaches to the proposed standard. While specific procedures 

were not agreed upon, the committee members committed to defining 

equivalence clearly. 

Emission Factors 

Mr. Robert Pahel-Short of EPA presented a series of figures 

illustrating the relationship between emission factors and leak 

frequency for various equipment types and leak definitions (See 

Attachment 12). The committee members agreed that these types of 

figures will be useful for estimating emission factors. 

Mr. Kittleman reported that no further work has been performed on 

the conceptual emission factors model. 

Batch Processing 

Mr. Bob Rowland, representing PMA, reported on the February 21, 

1990 work group meeting on batch processes (See Attachment 13). 

The work group members are working on an alternate standard for 

batch processes that they feel will be based upon the standard 

being developed for continuous processes. They drafted a 

definition of batch processes to identify the processes that would 

be subject to the alternate standard. The five test procedures 

presented in the January meeting by PMA are needed to provide 

industry flexibility, so the standard should permit their use. An 

alternate standard should not require dual mechanical seals for 

pumps, since their use is limited in pharmaceutical and other 

batch processes. 

The following issues still need to be resolved by the batch work 

group: 1) determining how time in use for batch components will 

influence the alternate standard; 2) determining how response 

factors will be used for batch equipment, which may be in many 

different chemical services and is often moved throughout the 

plant; 3) determining a definition for pilot plants and deciding 

whether they should be included in the standard; and 4) 

determining how batch plants will be required to maintain records 

of compliance. 

cao.027a 
P.12 

Action Items 

At the next meeting of the full committee, standards for pumps and 

flanges will be examined in greater detail. 

Mr. Goodheart expressed concern with the possibility of awarding 

credit for taking equipment out of service. They will address 

this issue at the next committee meeting. 

CMA indicated they were preparing material on the cost impacts of 

a standard and will distribute this soon. 

Committee members will continue to refine the conceptual approach 

and the scope of the standard, including leak definition, 

allowable leak frequency, de minimis concentration cutoff, use of 

response factors, a "death penalty" for non-complying plants, and 

procedures for determining equivalency. 

Future Meetings 

Batch Processes Workgroup: March 26, 1990 at 11:00 a.m., Guest 

Quarters Hotel, Research Triangle Park, NC 

The next meeting of the full Negotiation Committee is scheduled to 

be held in Research Triangle Park, NC on March 27-28, 1990 at the 

Guest Quarters Hotel, 2515 Meridian Parkway. 

April 25 and 26: Washington, D.C. at the Conservation Foundation, 

Suite 500, 1250 24th Street NW. 

cao.027a 
P.13 

ATTACHMENT 1 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

AGENDA FOR MEETING OF FEBRUARY 23-23 

Administrative 

• Introductions 

• Review of the Agenda: additions, subtractions, order 

• Minutes of January meeting: Any major heartburns 

Scope of the Standard 

• Sources included in the negotiations 

• Sources excluded from this standard 

• Oe minimis cutoff 

Data 

• Report of the Data Workgroup 

• Discussion of data 

• Additional data: availability and requirements 

Leak definition and allowable leakers: MACT 

i- Conceptual Approach to the Standard 

• Phasing 

• Incentives (bottom line of boxes) 

• Exit criteria (right column of boxes) 

• Miscellaneous points raised at prior meetings 

• Sampling strategies 

• Procedures for determining equivalent approaches 

Report of the Batch Processing Workgroup 

Emission Factors 

• Status of modelling approach 

• Matrix approach 

Approaches to assessing the cost of the standard 
P.M 

ATTACHMENT 2 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

ATTENDEES LIST FOR MEETING OF FEBRUARY 22 - 23, 1990 

NAME 

Robert Majewski 

Al Bickum 

Gus VonBodungen 

Harvel Rogers 

Deborah Dal ton 

Philip Harter 

Bob Ajax 

David Dunn 

Tom Kittleman 

Allen Hershkowitz 

Larry Goodheart 

Meredith Miller 

Bruce Grumstrup 

Rick Colyer 

Walt Brenner 

Karen Fidler 

Ed Moretti 

Mary Ann Gorko 

David Markwordt 

Ron Berglund 

Bob Hinkson 

Bob Rowland 

Ellen Siegler 

Scott Throwe 

Kathy Kaufman 

Robert Pahel-Short 

Les Montgomery 

Bruce Bowers 

Bob Fegley 

Karin Ritter 

Dorothy Bowers 

Cheryl Sutterfield 

Leigh Marks 

Richard Moench 

David Gustafson 

Nancy Cookson 

Kenneth Mulhoi land 

Gerald R. Hill 

Betsy Lyons 

Bruce C. Davis 

David Berengut 

Steve Smith 

AFFILIATION 

NESCAUM 

IISRP 

Louisiana DEQ-Air Quality 

JCAPCD 

EPA - Reg Neg Project 

Facilitation 

U. S. EPA 

Sterling Chemicals, Inc. 

CMA (DuPont) 

NRDC 

API (Chevron) 

Fisher Controls 

Fisher Controls 

EPA/OAQPS 

Sun Co. 

CMA 

Radian Corp. - RTP 

DuPont 

EPA/OAQPS 

Union Carbide 

Mobay Synthetics 

Pfizer Inc. 

API 

EPA/OAQPS/SSCD 

EPA/OAR/OPAR 

EPA/OAQPS 

TACB 

Standard Chlorine 

EPA/OPPE 

API 

Merck Company 

PMA 

Eli Lilly 

Eli Lilly 

Dow 

CMA 

DuPont 

Phillips Petroleum 

GAO 

Exxon Chemical 

DuPont 

Amoco 
P.15 

ATTACHMENT 3 

REVISIONS TO JANUARY MINUTES 

Second bullet under Data (Page 3) 

Some committee members expressed concern over the appropriateness 

of the data for selecting a leak definition and percent allowable 

leakers noting evidence that some data appear to have been rounded 

or truncated. Committee members were requested to review the data 

in detail prior to deciding on the data subset to use in 

establishing the level of the standard. Frequency plots of the 

data will be distributed during the week of January 22 with the 

intent of discussing the data in detail in an interim workgroup 

meeting. Further discussions of the data by the full committee 

was postponed until the February meeting. The workgroup meeting 

on the data base is scheduled for Wednesday, January 31 at 10:00 

at the EPA's Durham, North Carolina office (Mutual Building), in 

the 9th floor conference room. 

Third bullet under Data (Page 3) 

. Several committee members said there was a sufficient quantity of 

data that were not questionable to allow positions on the level of 

the standard to be formulated. A suggestion was made that a leak 

definition of 50 ppm and 4 to 5 percent leak frequency was 

supported for valves and flanges taking into account that some of 

the data is suspect. One proposal was that the committee begin by 

considering a leak definition at the lowest practical 

concentration, which should logically begin at instrument 

detection levels. 

First bullet under Conceptual Approach (Page 4) 

An analysis of the conceptual LDAR approach discussed in the 

December meeting was presented that compared a monthly base to a 

quarterly base program (Attachment 9) . Specifically, the analysis 

evaluated two elements for monthly and quarterly base programs: 
P.16 

1) the probability of failing an inspection, and 2) the number of 

inspections required per year. During the presentation there was 

discussion about the number of program levels a plant would have 

to fall back if they sampled annually and found an unacceptable 

leak level. There was a consensus that a plant should not be 

required to go all the way back to the base monitoring frequency 

in those circumstances. 
P.17 

ATTACHMENT 4 

COMPARISON OF EMISSIONS 

asasaaiaaeaaasasssassBasasaasEssssssssaaasasassssssssssBasaaasasBsasssassBsssaeasasaaaflaaaBBeaaaaaDaBaas a 

Equipment 

Component 

Number of 

Components 

(SOCMI Avg 

Model Uncont 

Plant B) Ref 

Emissions (kg/hr) 

Avg Avg Ref Avg SOCMI Sterling 500 ppm 50 ppm 

Uncont (Monthly (Monthly Benzene and and 

SOCMI LDAR) LDAR) . Oata 5% SX 

Gas Valves 

Light Liquid 

Valves 

Pumps 

Flanges 

Compressors 

Open-ended 1ines 

Pressure-relief 

devices 

Sampling 

connection sys. 

Total 

o,i37 

402 10.7736 2.2512 2.90887 0.60782 0.12301 1.37082 0.111354 

524 5.7116 3.7204 2.34176 1.52536 0.16034 0.446972 0.385664 

29 3.306 1.4326 1.29595 0.56158 0.02494 0.003016 0.001131 

2400 0.6 1.992 0.6 1.992 0.048 0.9072 0.7992 

2 1.272 0.456 0 0 0 0 0 

226 0.5198 0.3842 0 0 0 0 0 

42 6.72 4.368 0 0 0 0 0 

104 0 1.56 0 0 0 0 0 

28.903 16.1644 7.14658 4.68677 0.3563 2-r72S008 1.297349 

COMPARISON OF EMISSION FACTORS 

:s333sa=33sss==sssssssasa3Bssascncasa=33DOS33 

Emission Factor (kg/hr/source) 

Equipment 

Component 

Gas Valves 

Light Liquid 

Valves 

Pumps 

Flanges' 

Compressors 

Open-ended 1 

Pressure-rel 

ines 

ief 

devices (gas) 

Avg 

Uncont 

Ref 

0.0268 

0.0109 

0.114 

0.00025 

0.636 

0.0023 

0.16 

Avg Avg Ref Avg SOCMI Sterling 500 ppm 50 ppm 

Uncont (Monthly (Monthly Benzene and and 

SOCMI LDAR) LDAR) Data 5% 5X 

o.oooill 

0.0056 0.00724 0.00151 0.00031 4*40341 0.000277 

0.0071 0.00447 0.00291 0.00031 0.00085 0.000736 

0.0494 0.04469 0.01936 0.00086 0.0001 3.9E-05 

0.00083 0.00025 0.00083 2E-05 0.00038 0.000333 

0.228 0 0 0 0 

0.0017 0 0 0 0 

0.104 0 0 0 0 

Sampling N/A 0.015 0 0 0 0 

connection sys. 
P.18 

ATTACHMENT 5 

RECOMMENDATIONS OF THE "DATA" SUBCOMMITTEE 

The following recommendations were reached by the subcommittee examining 

the ethylene oxide (EO) and butadiene (BD) data for acceptability. The basis 

for rejection of any data is that the data (or lack of) differed markedly from 

the data patterns of the other plants. We cannot conclude the data are 

"wrong", based on what was reported, but have identified those we believe to 

be highly suspect, and are recommending that the Reg Neg Committee give these 

data low weighting, if any, in selecting the basis for the standards. The 

numbers discussed below are in terms of the values not adjusted for response 

factor, except for E07. 

1. Drop: BD2 Examination of the raw data sheets for this plant 

revealed severe calibration problems that cannot be 

corrected or adjusted. 

BD9 No data points recorded below 1000 ppm. Data below 1000 

appear to have been treated as "0". 

E010 No data points recorded below 8000 ppm. 

2. The subcommittee could find no problems with data in several other plants, 

but notes that there are gaps between certain ranges. Several subcommittee 

representatives were concerned that these gaps indicated rounding problems, 

and could affect the level of the standards, should the basis for these levels 

lie within the ranges of concern. The subcommittee recommends that these 

plants be given only very light consideration in these ranges. These were: 

BD3 between 500 and 1000 ppm, 

BD7 between 100 and 1000 ppm, and 

E07 between 250 and 2500 ppm. 

3. The subcommittee agrees that the data from the rest of the plants are 

acceptable. 
CONTROL OF EMISSIONS FROM EQUIPMENT LEAKS DATA QUALITY 

WORK GROUP MEETING ATTENDEES LIST FOR MEETING OF 

JANUARY 31, 1990 

P.19 

NAME 

Rick Colyer 

Jan Meyer 

Jim Sample 

Karin Ritter 

Karen Fidler 

David Gustafson 

Harvel Rogers 

David Markwordt 

David Berengut 

Mary Ann Gorko 

Robert Pahel-Short 

Al Wehe 

Ed Moretti 

ORGANIZATION 

EPA/OAQPS 

EPA/SDB/OAQPS 

API (consultant) 

API 

CMA 

DOW/CMA 

Jefferson Co./APCD 

EPA/OAQPS/CPB 

DuPont 

DuPont . 

EPA/OAQPS 

EPA/OAQPS 

Radian Corporation 

TELEPHONE 

(919)541-5262 

(919)541-5254 

(703)255-2159 

(202)682-8472 

(202)887-1176 

(517)636-2953 

(502)625-6000 

(919)541-0837 

(302)366-3943 

(302)366-3011 

(919)541-5310 

(919)541-5623 

(919)541-9100 
P.20 

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P.22 

ATTACHMENT 7 jj^X -Qp\.^Tfy<s*t{ 

DOW CHEMICAL U.S.A. 

OC-708 

February 15, 1990 

TEXAS OOERATICH-.S 

FREEPORT TEXAS 7?541 

m 

?•-<• 

Les Montgomery, P.E., Director 

Technical Support and Regulation 

Development Program 

Texas Air Control Board 

6330 Highway 290 East 

Austin, TX 78723 

Dear Mr. Montgomery: 

28MID INFORMATION REQUEST 

The information request has been completed for all completed quarters of 

monitoring data. Monitoring was initiated earlier than required by permit 

so that the data is from February 1989 through December 1989. In 

interpreting the data it may be useful to know that the valves in the plant 

are primarily quarter-turn rotating valves rather than gate valves. Eaual 

performance may not be achievable with sliding stem valves. The data was 

collected with an OVA-108 analyzer which was calibrated according to Method 

21. As I am sure that you realize, that method requires calibration with a 

standard near 10,000 ppm. Therefore although it is a reliable indicator of 

concentrations between 10,000 ppm and 500 ppm it is not an accurate method 

to gather data for readings below 500 ppm. 

If you have any questions concerning this data please call James Davenport 

at (409) 238-7877. 

Sincerely yours, 

James Davenport 

Environmental Specialist 

JWD.33/to 

Enclosure 

=Qualitv=, 

Pcffonnanct 

A N OPERATING UNIT OF THE DO W CHEMICAL COMPAN Y Means More At POv. 
P.23 

**Please Complete One Form For Each Quarter of Monitoring Data** 

28MID FUGITIVE MONITORING 

LEAKS DETECTED FORM 

Date of Monitoring Data: FEB-MARCH 1989, FIRST QUARTER 1989 

Concentration of Leak Definition: 500 ppmv 

Records of Actual Leak Concentration Available: X Yes No 

If Yes, Please Provide Type of Processes Monitored: 

PHENOL / ACETONE PRODUCTION 

List Main Toxic Chemicals being Detected: 

1) PHENOL 4) ACETONE 

2) CUMENE 5) 

3) CUMENE HYDROPEROXIDE 6) 

Component Leaks: 

NO. NO. 

EQUIPMENT/ COMPONENTS COMPONENTS 

SERVICE TESTED LEAKING 

VALVES 

Gas / Vapor 7 0 

Light Liquid 1172 42 

Heavy Liquid 0 0 

RELIEF VALVES 

Gas / Vapor 46 0 

COMPRESSOR SEALS 

Gas / Vapor 0 0 

PUMP SEALS 

Light Liquid 125 21 

Heavy Liquid 0 0 

FLANGES 

Gas / Vapor 0 0 

Light Liquid 0 0 

Heavy Liquid 0 0 
P.24 

••Please Complete One Form For Each Quarter of Monitoring Data** 

28MID FUGITIVE MONITORING 

LEAKS DETECTED FORM 

Date of Monitoring Data: SECOND QUARTER 1989 

Concentration of Leak Definition: 500 ppmv 

Records of Actual Leak Concentration Available: X 

If Yes, Please Provide Type of Processes Monitored 

PHENOL / ACETONE PRODUCTION 

Yes No 

List Main Toxic Chemicals being Detected 

1) PHENOL 

2) CUMENE 

3) CUMENE HYDROPEROXIDE 

Component Leaks: 

4) ACETONE 

5) 

6) 

EQUIPMENT/ 

SERVICE 

NO. 

COMPONENTS 

TESTED 

NO. 

COMPONENTS 

LEAKING 

VALVES 

Gas / Vapor 

Light Liquid 

Heavy Liquid 

RELIEF VALVES 

Gas / Vapor 

COMPRESSOR SEALS 

Gas / Vapor 

•7 

1171 

0 

0 

4 

0 

PUMP SEALS 

Light Liquid 

Heavy Liquid 

125 

0 

0 

0 

FLANGES 

Gas / Vapor 

Light Liquid 

Heavy Liquid 

0 

0 

0 

0 

0 

0 
P.25 

**Please Complete One Form For Each Quarter of Monitoring Data** 

2SMID FUGITIVE MONITORING 

LEAKS DETECTED FORM 

Date of Monitoring Data: THIRD QUARTER 198.9 

Concentration of Leak Definition: 500 ppmv 

Records of Actual Leak Concentration Available: X Yes No 

If Yes, Please Provide Type of Processes Monitored: 

PHENOL / ACETONE PRODUCTION 

List Main Toxic Chemicals being Detected: 

1 ) PHENOL 

2) CUMENE 

4) 

5) 

3) CUMENE HYDROPEROXIDE 6) 

Component Leaks: 

EQUIPMENT/ 

SERVICE 

VALVES 

Gas / Vapor 

Light Liquid 

Heavy Liquid 

NO. 

COMPONENTS 

TESTED 

7 

1171 

0 

ACETONE 

' 

NO. 

COMPONENTS 

LEAKING 

0 

20 

0 

RELIEF VALVES 

Gas / Vapor 0 0 

COMPRESSOR SEALS 

Gas / Vapor 0 0 

PUMP SEALS 

Light Liquid 125 6 

Heavy Liquid 0 0 

FLANGES 

Gas / Vapor 0 0 

Light Liquid 0 0 

Heavy Liquid 0 0 
P.26 

**Please Complete One Form For Each Quarter of Monitoring Data** 

28MID FUGITIVE MONITORING 

LEAKS DETECTED FORM 

Date of Monitoring Data: FOURTH QUARTER 1989 

Concentration of Leak Definition: 500 ppmv 

Records of Actual Leak Concentration Available: X Yes No 

If Yes, Please Provide Type of Processes Monitored: 

PHENOL / ACETONE PRODUCTION 

List Main Toxic Chemicals being Detected: 

1) PHENOL 4) 

2) CUMENE 5) 

3) CUMENE HYDROPEROXIDE b) 

Component Leaks: 

NO. 

EQUIPMENT/ COMPONENTS 

SERVICE TESTED 

VALVES 

Gas / Vapor 7 

Light Liquid 1171 

Heavy Liquid 0 

ACETONE 

NO. 

COMPONENTS 

LEAKING 

0 

0 

0 

RELIEF VALVES 

Gas / Vapor 0 0 

COMPRESSOR SEALS 

Gas / Vapor 0 0 

PUMP SEALS 

Light Liquid 125 5 

Heavy Liquid 0 0 

FLANGES 

Gas / Vapor 0 0 

Light Liquid 0 0 

Heavy Liquid 0 0 
P.27 

UC 149- i 

UNION 

CARBIDE INTERNAL CORRESPONDENCE 

r>. O. OOX Ol , TCKAC ClTV , TKKAC JJiOO 

To: February 20, 1990 

Mr. Les Montgomery 

Program Director 

Technical Support and Regulatory Development 

Texas Air Control Board 

Austin Texas 

Dear Mr. Montgomery: 

Please find attached the performance data you requested for the 28 MID leak 

detection program at. our 0X0 facility here at 7$X«S City. 

I would like to point out that there are 37 pumps 1n the Building 45/79 and 83 

0X0 units program. The 28 MID proqram started 1n May nf 1989 at. the 0X0 

facility. Thus the 37 pumps were monitored only twice (74 samplings) during 

the second quarter of 1989 as compared to three times (111 samplings] during 

the following quarters 

There are come practical limitations to the progeam beyond what the data can 

ninrtmtn I mniild,hn.hinnv Tn rmnnui w llmltatlnn^ with vniir nff1r.fi nfi 

yuur cuiivei'iiftnce. If there are any jjuoetlsno-cp- it-1 can-to- ot. unji.tiuij.'.. 

please call me at ('409')' 9¥8'-3i'86. 

Very Truly Yours 

tyji-^ 

H. G. Dorbln 

Environmental A1r Coordinator 
P.28 

0£/ifi/9 3 1 5 ; <3<t S **<>' ' i't w H * o . w* c tf_ 

BUILniNGS 45 . 79 , AND 83 

2ND QUARTER OF 1989 

NUMBER OF COMPONENTS NUMBBR OP COMPONKNTS 

MONITORED PER QUARTER LEAKING 

VALVE SERVICE 

LIGHT LIQUID &$8 JL4 

OAS Ai _0 

HBAVY LIQUID _ £ __> 

SAFETY VALVE 

LIOHT LIQUID .J. _fl 

OAS _14 _ 2 

HBAVY LIQUID _<_ _J_ 

PUMPS SERVICE 

LIOHT LIQUID J.4 -15 

OAS _fi _$> 

HBAVY LIQUID _0 _fi 

FLANGES 

LIOHT LIQUID li.Q0.E_ST,. „ ] 

OAS _9QEST, _P_ 

HBAVY LIQUID _ 0 _J_ 

3RD QUARTER OF 1989 -

VALVE SERVICE 

LIOHT LIQUID fill _?_ 

OAS J J _fi 

HEAVY LIQUID __Q _fi 

SAFETY VALVE 

LIOHT LIQUID _J __Q 

OAS J 4 _ 1 

HEAVY LIQUID _ft _fi 

PUMPS SERVICE 

LIOHT LIQUID H I J J 

OAS _fi _j_ 

HEAVY LIQUID _0 _fl 

FLANGES — -

LIGHT LIQUID 1500EST. _J_ 

OAS 90BST. _fi 

HEAVY LIQUID _fi __0 

4TII QUARTER OF 1989 

VALVE SERVICE 

LIOHT LIQUID feifi __1 

OAS JU _ i 

HEAVY LIQUID _ft _..Q. 

SAFETY VALVE 

LIOHT LIQUID _ 1 _fi 

OAS JL4 _fl 

HEAVY LIQUID Jfc , 0 

PUMPS SERVICE 

LIOHT LIQUID LU - 1 

OAS _J0 _Q 

HEAVY LIQUID _0 _0 

FLANOES 

LIOHT LIQUID L559MT ._Q 

OAS ._.5»QEST, _..Q 

HEAVY LIQUID 1_> __Q 
P.29 

, .' . .••• ,.,t . .-...' .'••••, 

/'..>.• r.-a'.-'/f. /;,.,• /.'/.v.' 

Iil.->:>!i-l-ll. 7.V .*•"•''.'/ 

February 19, 1990 

Lea Montgomery, P.E., Director 

Technical Support and Regulation 

Development Program 

Texas Air Control Board 

6330 Hwy. 290 East 

Austin, TX 78723 

Re- Request for Information on Leak Frequency of Equipment 

Regulated by General Permit Provision 2AMID 

Dear Mr Mongomery: 

Pleas?* find attached tho 28 MID leak reports:-you requested from our 

facility. We appreciate the extension you allowed to compile this 

d«\a. In order not to delay you any further, we are faxing the 

requested informal'ion to you. Color copies of the graphs w.i.1.1 

follow. 

We have included frequency distribution graph?; that should prove 

useful to you. 

Some notes are in order: 

l) Liquid drips are counted ae 10,000 ppm .leaks on the graphs 

2; The counts of equipment monitored are approximate. Exact 

counts are imbedded in our database, but owing to the short 

time available, we provide estimates. 

If you have questions, pleasa feel free to c&ll me at (713)-920-

4316. 

Charles Barfielrt 

Sr. Process Engineer 

Pasadena Cumene Plant 

CEB:2 2C:pa 

D. E. Hamilton 

K. A. Konderla 

K. K. Robinson 

b. V. GhoJson 
P.30 

• -•»••» 

••Please Complate Ona Form For Each Quartar of Monitoring Datt **.• 

28KXD FUGITIVE NONITOtXtro 

UUX8 DBTBCTB) FOAM 

Data Of Monitoring Datai 3rd Quarter - 1988 

•**" ^m—11 n-rt '•rr^a.'Sn 

Concentration of Laak Definition* 500 ppmv 

Records of Actual Laak Concentration Availablei Jf_ 

If. Yet, Please Provide Type of Proceeeee Monitoredi 

Synthetic Organic Chemical MFC Process (Cimene Plant) 

Lift Main Toxic Chemioals being Detected* 

Yes Mo 

lienzene 

Lumene 2) 

Component LeeOcst 

«*M««« ~ >*ia aacy CtntUtvao^ a 4) 

S) 

6) 

EQUIPMENT/ 

Service 

VALVES 

Gae / V&por 

Light Liquid 

Heavy Liquid 

X&hTW VALVBS 

Qaa / Vapor 

COMPRESSOR 8SAL<£ ' 

Gae / Vapor 

:•>::«? SEALS* 

Light Liquid 

Heavy Liquid 

'.'.ANC^S'' 

c;aa / Vcpo: 

1*3 he. Liquid 

'••jo«vv ;,.v.n:id 

NO. 

COMPONENTS 

TESTED 

26S 

1,248 

0 

-12-

JL 

o 

»+*MMm**,mmmmit* iwa •'•1i.lLilfc.wn., 

-i*'.*v.( r..., 

no. 

COMPONENTS 

LBAXtNO 

0 

3 

•»*aW 

0 

Flang * loaks sra thor-e discover*;.1, duiriny vhn que <•".'.?./ 

j yft*v pr.toi* -:.o th * T^r. i t <.•*.• in ? bein g rojiorted . 
P.31 

» » • . • ».. • 

**Piea»o Complete One Form For Each Quarter of Monitoring Data* 

28MID FUGITIVE MOHIVOBXNQ 

LKAK8 DBTIOTB) FORM 

Oata of Monitoring Data? 4th Quarter - 198S 

u**w*-*.T,\'vp'Mjaj*« 

Concentration of Lea)c Definitiont 500 ppmv 

Records of Actual Leak Concentration Available! x yea __. No 

Tf Yes, Please Provide Type of Processes Monitored % «_-fc____^. 

Synthetic Organic Chemical MFC Process (Cumene Plant) 

List- Main Toxic Chemicals being Detectedt 

I) Benzer.e 4) 

2} Curifcne 5) 

* -r ••- • - - - • - ' ~-> - • - • ^ ' <»M>WMP»*M»i'Wi'iiw — »• raw• • .cut.'^.-^ • 

;••) 6 ) 

Component Leakst 

NO. no. 

EQUIPMENT/ COMPONENTS C0KPOM8KTS 

Service TESTED LEAKING 

VALVES 

Gat / Vapor 236 2 

Light Liquid 1,181 <£ 

Heavy Liquid 0 _... 0 

«I* M 

Mr-UXT VALVSS 

Gas / Vapor 

COMPRESSOR SEALS 

Gas / Vapor 

'"*• Light Liquid 19 <2 M 

Heavy Liquid Q., JJ «. 

;:..ANGEy-L 

•'Jas / Vapor j) _,_?. « 

Light Liquid ?_„ 

.'.••;r.vv Liquid _ „JL 

- -Flange leaks av& those dia-.jwered du/fin*/ tha quarr.di' 

•:^> y^fii- prior to the r.or.i tarin g bsinq report^. 
P.32 

IT. 1 •• 

**Pleaae Complete One Form For Each Quartar of Monitoring Data** 

28KXD FUGITIVE MOHITO&XHO 

L.tAK8 DHTICTIU FORM 

Date Of Monitoring Datat 1st Quarter - 1989 ' . 

concentration of Leak Definition! 500 ppmv 

Records of Actual Leak Concentration Available-? _>L Vet _ , No 

If Yes, Pleaae Provide Type of Processes Monitoredt 

—,-^i^lhoti c Or^nic.Chenical Mr Process (Cumene Plant) 

List Main Toxic Chemicals being Detected; 

-*J~e- rrtv«.-.•*-

\) _Benzene 

2) Cumene 

m-.~..-.-aJX*c.-. 4) 

3) 

6) 

Component Leakst 

EQUIPMENT/ 

Service 

VALVE3 

Gas / Vapor 

Light Liquid 

Heavy Liquid 

RELIEF VALVSS 

Gae / Vapor 

COMPRESSOR 8SAL£i " 

Gas / Vapor 

NO. 

COMPONENTS 

TESTED 

250 

1,181 

^MP SEALS 

Light 

Heavy 

GA3 /' 

LL^l'.t 

• ""; it V' V 

Liquid 

Liquid 

rr^.-.-. .-.— 

Liquid 

Liqu.i-3 

19, 

0 

0 

0 

0 

Kri» ^ . «..-

'timmm IJ-IIIT"I - -"1 • u*..i 

NO. 

COMPONENTS 

LEAKING 

40 

JL 

L 

0 

Flange loaVs are r.K.cse discovered during th«s cjo*..vv,ftr ; * 

.v prio r to tb«* •••on Iter in*/ beir.o r«port.ftd. 
P.33 

"Please Complete One Form Por Each Quarter of Monitoring Data** 

2 SKID FUGITIVE MOBXTQftXVQ 

LBAX8 DBTBCTg) FORM 

Date of Monitoring Datai 2nd Quarter - 1989 

Concentration of Laak Definitiont 500 ppmv 

Record* of Actual Leak Concentration Available* _£_ 

If Yes, Pleaae Provide Type of Processes Monitoredt 

Synthetic Organic Chemical MFC Process (Cumene Plant) 

Yes Nc 

•*'«^we^»*'»M . -r>WWfc»M 

List Main Toxic Chemicals being Detected* 

1) _Ben.zene 

2) Cioene 

•i) 

Component Leakst 

EQUIPMENT/ 

Service 

V?.LVES 

Gas / Vapor 

Light Liquid 

Heavy Liquid 

RELIEF VALVSS 

Gas / Vapor 

COMPRESSOR SEALS 

Gaa / Vapor 

4) 

5) 

6) 

NO. 

COMPONENTS 

TESTED 

256 

1,181 

0 

0 

PL'MP SEALS 

Ligh t Liqui d 

Heavy LiqvJ.6 

Gas / Vapor 

19 

0 

0 

_ L _ 

0 

< tlM0^ *, .jfc— f>*«. 1 f — CO*^ 'Tja SUTrnffi 

» IN I* —ni*n I ' I tf.•» 

••'—***rf« ihilMJ- • 

ia»iM«^»>. i auv. rr.-: 

NO. 

COMPONENTS 

LSAXIVQ 

35 

MnM.-A l 

0_ 

o 

Flange loaXft ar«? thoat discyvor«d during Urn qneirtu;; ..• 

tr.« year prior t2 tl\» monitoring be.lncj rtperted< 
P.34 

••Pleas* Complete One form For Each Quarter of Monitoring Data** 

28XXD FDGITIV1 MONITOR!*! 

LSAX8 DBT1CTED FORM 

Pate of Monitoring Data! 3 rci Quarter 1989 

Concentration of Leak Definition! 500 pp»v 

Records of Actual Leak Concentration Avallabiai jc_ Yes 

if Yes.- Pleaae Provide Type of Processes Monitoredi _ 

Synthetic Organic Chemical MFG Process (Cunene Plant) 

No 

List Main Toxi c Chemicals 

1} Benzene 

2) Cumene 

3) 

Component Leaksi 

EQUIPMENT/ 

i Servic e 

VALVES 

Gas / Vapor 

Ligh t Liqui d 

Heavy Liqui d 

RELIEF VALVES 

Gas / Vapor 

COMPRESSOR SEALS" 

Gas / Vapor 

?UMI> SEALS 

Ligh t Liqui d 

fieavy Liqui d 

-': AKSSS 1 • 

'•^is > v^pcs." 

L..cht Liqui d 

H:**'ry liqui d 

1

 being Detectedt 

4) 

, 5) . 

6) 

NO. 

COMPONENTS 

TESTED 

268 

1,248 

0 

M 0 

0 

JL9_ 

0 _ _ 

0 

_ Jj40 ^ 

.....0 

NO. 

COMPONENTS 

LEAKING 

2 

39 

0 

i

 0 

0 

] 

().,_ _ _ 

0 

0 

IWJUHI W itr ' 

<L ...... 

- Flango leak? ar* thctjp disjcsvured during th* qc^rtc/r 

:.v v

, !'sr

 prio r to the rc.?.'.ti:rin$ being reported. 
P.35 

«*v * < • w% 

"Pleas e Complete One Porn For Each Quarter of Monitoring Data*** 

28M2D FDOITIVB MDHITOIHWO 

LEAKS DETECTED FORM 

Date Of Monitoring Datai 4t.h Quarter - 1989 ^ 

Concentration of Leak Definitiont 500 ppmv 

Records of Actual Leak Concentration Availablei x yes _ _ No 

If Yes, Pleaae Provide Type of Processes Monitoredt 

Synthetic Organic Chemical MFG Process (Cumene Plant) 

j zs%**± ^.<f» n i 

List Main Toxic Chemiaala being Detectedt 

1) Benzene 4) 

£1 Cuncne f}) 

i i • r r --i—i 1 •> t mm. 1 1'i'Tt i — T ~ v r «»*»i^i^^ " 

:>.) __ 6) 

Component LeaksJ 

EQUIPMENT/ 

Service 

VALVES 

Gaa / Vapor 

Light Liquid 

Heavy Liquid 

RELIEF VALVES 

Gas / Vapor 

NO. 

COMPONENTS 

TESTED 

256 • 

1J81 

0 

0 

NO. 

COMPONENTS 

LEAKING 

7 

8 

0 

0 

COMPRESSOR SEALS 

Gaa / Vapor 

PUMP SEAL8 

Light Liquid 

'Heavy Liquid 

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PUM

P SEAL INFORMATION FOR BUTADIENE FACILITIES 

SM = Single mechanical Seal 

DM = Dual Mechanical Seal 

P = Packed Seal 

Plant ID 

Number 

Pump 

Seal 

Type 

BD1 Did not identify type of pump seal 

BD -3 All SM 

BD-4 

Al 1 DM 

BD5 Screening values provided in one package; 

Pump seal info provided in second package; 

Company provided different ID numbers in the packages, 

so there is no way to associate SV and seal type. 

BD- 6 

BD- 7 

BD-B 

Al 1 

A l l 

A l l 

SM followed by P 

DM SM 

BD-10 

> 

> 

o 

Only info provided indicates that 

the seals are NOT DM. 

BD- U 

BD-12 

Al 1 SM 

Pump 30021 

Pump 30022 

Pump 30255 

Pump 30480 

Pump 30548 

Pump 30659 

Pump 30665 

Pump 30720 

Pump 30721 

Pump 30791 

Pump 30818 

Pump 30851 

Pump 30914 

Pump 30915 

Pump 30923 

Pump 30924 

Pump 30925 

Pump 30944 

Pump 30945 

Pump 30946 

0 ppmv - DM 

0 ppmv - DM 

O ppmv - DM 

423.15 ppmv - SM 

14476.2 ppmv - SM 

0 ppmv - DM 

0 ppmv - DM 

- 0 ppmv - DM 

- 0 ppmv - DM 

- 13693.15 ppmv 

- 265.05 ppmv -

- 0 ppmv - SM 

- 0 ppmv - DM 

- 0 ppmv - DM 

- O ppmv - DM 

- O ppmv - DM 

- 0 ppmv - DM 

-- 0 ppmv - DM 

- 0 ppmv - DM 

- 0 ppmv - DM 

m oo 

SM 

SM 
PUMP SEAL INFORMATION FOR ETHYLENE OXIDE FACILITIES 

SM = Single mechanical Seal 

DM = Dual Mechanical Seal 

P = Packed Seal 

Plant 

ID 

Number 

Pump 

Seal 

Type 

EO-1 Pump 11671 - 685 ppm - Sealless 

Pump 11811 - 73 ppm - Sealless 

23 others SM 

EO-2 

EO-3 

EO-4 

EO-5 

EO-6 

EO-7 

EO-8 

EO-9 

All SM 

Only info 

the seals 

All SM 

All DM 

Pump 1112 

Pump 1131 

Pump 1186 

Pump 1203 

Pump 1607 

Pump 32209 

Pump 32230 

Pump 32299 

16 others 

All DM 

All DM 

All DM 

provided indie 

ar& 

- 0 

- 0 

- 0 

- 0 

- 0 

NOT DM. 

ppmv - DM 

ppmv - DM 

ppmv - DM 

ppmv - DM 

ppmv - DM 

- 0 ppmv - DM 

- 0 ppmv - DM 

- 0 ppmv - DM 

SM 
P.43 

ATTACHMENT 9 

Monthly LDAR 

All Components 

2< AL 

1> AL 

L... 

Quarterly LDAR 

All Components 

2< AL 

1> AL 

Semiannual LDAR 

Random Sample 

All Components 

2< 0.5AL 

1> 

2< 

0.5AL 

Annual LDAR 

Random Sample 

AL 

>x yrs. 

1> AL 

Alternative Approach 

Annual LDAR 

All Components 

3< AL 

1> AL 

Alternative Approach 

Annual LDAR 

All Components 
P.44 

FEB 17 '90 13=00 CHEVROlRESEflCHCO P. l 

ATTACHMENT 10 

Transmitting letter LTG-Membera, Equipment Leaks Regulatory 

Negotiation Committee, "Draft Framework," dated 

i 

BVBowers-1 

DWDunn-1 

KFidler-1 

TAKittleman-1 

DDoniger-1 

AHershkowitz-1 

RAjax-1 

DDalton-1 

KKaufman-1 

PJHarter-1 

NGaraia-1 

JKaca-1 

AWBickum-1 

GVBodungen-1 

AGanguli-1 

RVMajewski-1 

LMontgomery-1 

HRogera-l 

CBennett-1 

MLev-On-1 

LCurran-1 

ESiegler-1 

DGealy-1 

KRitter-1 

DRuaaell-l 

JHill-1 

WJMulligan-1 

DGDale-1 

RDEdwards-1 

JJMojcher-1 

RJKlett-1 

DFVanDerZanden-1 

LTGoodheart-1 

File-1 

WOtmAHtMfTTAt 

Chtyron 
P.45 

FEB 17 '90 13:01 CHEVRONREbEACHCO P. 2 

Chivro ctiivror n 

^ 0 Chevron Research and Technology Company 

Draft Framework 

Members, Equipment Leaks 

Regulatory Negotiation Committee: 

At the last Reg/Neg meeting, there was a good deal of discussion 

concerning the framework for the final rule. As shown on 

Attachment No. 1, Chevron would like to propose a draft framework 

that is very similar to the skip-period approach but also 

attempts to address other issues of concern to the committee. 

The basic plan calls for quarterly inspection and maintenance 

(I4M) of all components, whenever monitoring results indicate 

that the performance level of the facility is not meeting the 

performance standard, monthly monitoring, instead of quarterly, 

of all components is triggered. 

Chevron believes that monthly monitoring will be such a significant burden for plants that there will be ample economic 

justification for facilities to improve performance. For 

example, a monthly inspection and maintenance program for a small 

-refinery with 50,000 components would cost in excess of $1.5 

million annually. Increasing the expense of I&M programs will 

provide an economic incentive for facilities to improve performance-by emphasizing total quality control programs and 

capital investment of new leakless technology where appropriate. 

In an earlier Reg/Neg meeting, a draft framework was discussed 

which included a provision of annual monitoring if plants 

achieved a performance level greater than one-half the standard. 

It is our opinion that the final rule should not include a 

separate provision for performance beyond Maximum Achievable 

Control Technology (MACT), but there should be incentives built 

into the framework for improving performance. In the draft 

framework, we have included a performance-based incentive for 

plants to reduce inspection and maintenance operating expenses. 

For plants who can improve performance level below the standard 
P.46 

rEB 17 '90 13:02 CHEVRONREbEPCHCO p-3 

Members, Equipment Leaks 

Regulatory Negotiation Comm. -2-

for three consecutive semi-annual monitoring periods (1.5 years), 

only annual inspection and monitoring would be required. A plant 

will have to demonstrate excellent performance to achieve annual 

monitoring. A statistical analysis of the monitoring plan 

indicates that for a facility to be confident that it could 

achieve a performance level better than the standard for three 

consecutive periods, the performance of the plant would have to 

be significantly below the standard. Again the driving force for 

improving performance is economics. Using the same example as 

described above, a small refinery with an annual inspection and 

monitoring program would have its inspection and maintenance 

operating expenses reduced to approximately $100,000 per year; a 

savings of $1.4 million. This type of approach satisfies the 

intent of the rule for providing incentives for improving plant 

performance beyond the standard. 

Leak Definition 

Chevron feels strongly that the Reg/Neg Committee should develop 

a leak definition for MACT baaed on a strong technical justification. At the last meeting, a leak definition of 50 ppm was 

proposed to the committee. We feel strongly that a 50-ppm leak 

definition is not appropriate based on the following technical 

rationale: 

1. Data Adequacy. In developing a performance standard for MACT 

that includes both the leak definition and the percent leaking 

equipment, the Reg/Neg Committee must have confidence in the data 

being uaad"to establish the standard. Attachment No. 2 represents a graph of constant emissions as a function of leak definition and percent leaking. A MACT standard can be developed based 

on either a low leak definition, such as 50 ppm, and a higher 

percent leaking or a higher leak definition, such as 1000 ppm, 

with a lower percent leaking. From a standpoint of having 

statistical confidence in the data, there is more variability in 

the data at the low leak definitions than at higher leak definitions, (See Figure 1, coefficient of variation versus concentration.) Therefore, we would recommend that a higher leak 

definition, such as 1000 ppm, be adopted to ensure confidence in 

the data. 

2, Measurement Variability. Measuring fugitive emissions is not 

a precise science. In developing a leak definition for MACT, the 

concept of statistical confidence in the data must be considered. 

The OVA-108 is an analyzer specifically designed for fugitive 

emission1 monitoring of organic leaks. It has been known since 
P.47 

FEB 17 '90 13=03 CHEVRONRESEftCHCO P. 4 

Members, Equipment Leaks 

Regulatory Negotiation Comm. -3-

the start of various fugitive emissions monitoring programs using 

a leak definition of 10,000 ppm, that these results are not 

reproducible in the field. Variability would be even more 

pronounced for a significantly lower leak definition, such as 

50 ppm. 

In any analytical process, there is variability built into the 

equipment, calibration procedures, etc., which form the basis for 

the Method Detection Limit (MDL) -of the process. There are a 

number of factors that affect the MDL for screening fugitive 

emissions from equipment. These are described below. 

a. The OVA-108's maximum accuracy is only +/-20%. This is 

stated in the operating manual for the OVA-108. 

b. Temperature changes introduce additional Inaccuracies. 

The accuracy is +/-20% within the temperature range of 50'F to 

104*F. The OVA-108 is required to be used under the various 

regulatory program schedules as frequently as monthly. Plant and 

seasonal conditions are frequently greater than 104'p and certainly during winter, temperatures drop below 50*F in most 

facilities. 

c. Changes in relative humidity introduce additional variability. The operating manual for the OVA states that the 

accuracy for a relative humidity range of 5% to 95% is 20%. This 

is in addition to other inaccuracies of the instrument. 

i 

d. -In the process of screening equipment, there is error in. 

the procedure used by the technician in analyzing the equipment. 

For example, if the same technician measured the same piece of 

equipment several times in a row, different values would be 

obtained. This is a measure of the reproducibility of the data. 

e. The response factors are nonlinear. The response factors 

that are published by EPA are those for screening values near the 

leak definition of 10,000 ppm. The response factors for significantly lower screening values are different. For a given 

compound with a response factor greater than 100% at a leak 

definition of 10,000 ppm, the response factor at lower screening 

value may be less than 100%. Response factors have been 

established only .for pure streams. There is no record that any 

response factors have been established for multicomponent 

streams. Due to the nonlinear nature of the response factors of 

the pure streams, it cannot be assumed that response factors for 
P.48 

FEB 17 '90 13:04 CHEVRONRESEACHCO P. 5 

Members, Equipment Leaks 

Regulatory Negotiation Comm. -4-

mixtures would be additive. EPA Method 21 should be updated to 

reflect problems associated with the measurement of multicomponent streams. 

The MDL applies only to a specific analytical process. When one 

considers a more global assessment of the variability involved 

when many plants across the country are conducting monitoring 

programs with many technicians, all with different levels of 

training, using different analyzers and procedures, etc., the 

variability is further compounded, Taking global variability 

into account leads to a concept known as the Practical 

Quantification Level (PQL). (See Figure 2.) The PQL is 

typically 3-10 times the MDL and represents the level of an 

analytical procedure which ensures statistical confidence in the 

data being obtained. It should be the goal of the Reg/Neg to 

develop a leak definition that is above the PQL of the screening 

process to ensure confidence of the data being collected. At the 

current leak definition of 10,000 ppm, variability due to analytical and procedures is a small percentage of the overall screening value. However, when the leak definition is reduced to lower 

values, such as 50 ppm, this measurement error is very significant. We would anticipate that a leak definition of 50 ppm 

would not be greater than the PQL for the screening process. 

3. Repairabllitv. An important factor to consider in setting 

the leak definition is the repairability of the equipment, with 

a low leak definition of 50 ppm, certain plant equipment, such as 

control valves in dynamic service, will not be able to comply 

with the-standard. Other equipment will" not be able to be 

repaired at the low leak definition but will be replaced which 

will increase the cost of the standard. In many cases when 

repairing valves leaking at the 50 ppm level, there would be more 

emissions resulting from the maintenance procedure than had the 

valve remained in service with continual monitoring. 

We look forward to discussing these issues with you at the next 

meeting of the Reg/Neg Committee. If you have any questions or 

comments, please call L. T. Goodheart, at (415) 620-4145. Thanks. 

Sincerely yours, 

L. T. Goodheart 

LTG:oom/cif/11608 

Encl. - Figures 1 and 2 

Attachments 1 and 2 
P.49 

"EB 17 '90 13:05 CHEVPONRESEACHCO 

Recommendation for Phase III of 

Equipment Leak Regulations for Valveyess I 

Leak Definition •« 1000 ppm 

If > Allowable Leakers 

in one quarter 

If > allowable leaks, 

ih one period 

Monthly monitoring 

of all components 

If < Allowable Leakers 

in 2 consecutive months i 

Starting point of the regulation 

is quarterly monitoring 

of all components 

Quarterly monitoring 

of all components 

If £ Allowable Leakers 

in 2 consecutive quarters 

1 

Semi-annual monitoring 

of all components 

If < .Allowable Leakers 

in 3 consecutive 

semi-annual periods 

1 

Annual monitoring 

of all components 

If > allowable leakers 

in one period 

Note: Alternative approaches to the 

monitoring requirements shown in 

this figure should also be permitted 

where demonstrated to be equivalent 

These may include random partial 

sampling, area and building vent 

monitoring, and other approaches. 

Attachment No. 1 
n 

ATTACHMBNT 2 

a i 

% Leaking Gas Valves at 50 & 1000 ppm Leak Defnitioii 

(3 

I 

n 

8 9 10 11 

Plant 

12 13 14 15 16 17 18 19 20 

in m 

m 

X' 

n 

i 
P.51 

"EB 17 '^ 0 13:0 7 CHEVROfNRESEftCHCO P.3 

Figure 1 

TYPICAL DETECTION & QUANTITATION 

LEVELS OF CONSTITUENTS 

Concentration 

Practical Quantitation 

Limit (PQL) 

Method Detection 

Umit (MDL) 

Instrument Detection 

limit(IDL) 

Time 
S* !?',t:l'» 

D 

+ + + 

(%) uoucucA jo luopijj*^ 

S'd 

; 

0jH3y3S3aN0dA3H3 80:ET 06. Ll 833 
P.53 

ATTACHMENT 11 

Date: 22 February 1990 

To: Fugitive Emissions Regulatory Negotiations Committee 

From: Gus von Bodungen (La.), Allen Hershkowitz (NRDC), Bob 

Majewski (NY), Les Montgomery (Tx), Harvel Rogers 

(JCAPCD). 

Re: Proposed leak definition, leak frequency allowance and 

monitoring protocol. 

During the last seven months we have together or individually 

assessed the data brought forth during these committee meetings, 

toured a variety of the SOCMI facilities, interviewed managers 

responsible for LDAR at these facilities, discussed issues 

related to this reg neg with members of the committee and others 

in ^attendance during committee meetings and consulted with our 

various and diverse constituencies to help us determine the 

following regulatory proposal for existing facilities. In light 

of the fact that comparatively few new "grassroots" facilities 

will be built in the foreseeable future relative to the amount of 

processing capacity that now exists, we view this section of the 

forthcoming proposed rule as particularly important. 

Existing facilities: Standards for pumps, valves, flanges and 

agitator seals: 

The provisions of this section apply to facilities that 

commenced construction before (date of proposal).... 

(a) Phase 1: LDAR. On and after (90 days from the date of 

promulgation) pumps and valves must meet current leak 

-detection and repair (LDAR) requirements as described in 40 

CFR 61.242-2 (pumps) and 61.242-7 (valves). In addition, 

flanges and agitator seals must meet parallel requirements 

to valves [regulatory language to be worked on]. Other 

applicable provisions would include 61.242-10 (Delay of 

repair), 61.243-1 and -2 (Alternative standards for valves) 

and 61.244 (Alternative means of emission limitation). 

[These other provisions would also apply to flanges.] 

(b) Phase 2: LDAR. On and after 12 months from the start of 

Phase 1 pumps, valves, flanges and agitator seals must meet 

the same requirements as (a) above except that a leak is 

defined as an instrument reading of 250 ppmv as measured 

according to Method 21, and a leak repair is not required 

for leaks less than 1000 ppmv. "No detectable emissions" 

is redefined as (0.5 x 250 ppmv). [Standards for other 

equipment, e.g. compressors, pressure relief devices, etc., 

described in 40 CFR Subpart V, would also be revised to be 

consistent with the redefinitions here.] 
P.54 

(c) Phase 3: On and after 12 months from the start of Phase 

2 the following numbers of allowable leakers will apply for 

the specified equipment (Phase 2 LDAR requirement will not 

apply in Phase 3): 

(1) For valves: at a leak definitios of 250 ppmv, no 

more than 2 percent valve leaks or 1 valve leaking, 

whichever is greater; 

(2) For pumps: at a leak definition of 250 ppmv, no 

more than 2 percent pump leaks or 1 pump leaking, 

whichever is greater; 

(3) For flanges: at a leak definition of 250 ppmv, no 

more than 2 percent flange leaks or 1 flange leaking, 

whichever is greater; 

(4) For agitator seals: at a leak definition of 250 

ppmv, no more than 2 percent agitator seal leaks or 1 

agitator seal leaking, whichever is greater; 
Monitoring Protocol 

P.55 

1 inspectio n 

@ 2% leakers 

v I Monthly Inspection J r 

close and 

repair after 

four months 

9 >250 ppmv << 

2% leakers 

f*-

>250 ppmv 

2 consecutive inspections 

9 <250 ppmv @ 2% leakers 

=?. 

/ J Quarterly Inspection 1 £. 

-> b1 inspection >250 ppmv 9 1% 

leakers 

2 consecutive inspections 

9 <250 ppmv 9 1% leakers 

-(—J Semiannual Inspection 

1 inspection 

leakers 

f 

>250 ppmv 9 0.5% 

2 consecutive inspections 

9 <250 ppmv 9 0.5% 

leakers 

Annual Inspection 

m

" f j 
Response Factor Adjustment and Emission Calculations 

ADJ_SV = SCREENJ/AL * 

> 

(PCTCHEM * CHEM_REF + PCT.SOL1 * SOL1_REF + PCT_SOL2 * SOL2_REF) ^ 

(PCT_CHEM + PCTSOL1 + PCT_SOL2) 

FOR GAS VALVES: 

0.693 

EF_KG_8PPM = (1/2.2) * 0.0000168 * (ADJ_SV) 

if ADJ_SV <= 8 ppm then EF_KG_8PPM = 0.000033 

if ADJ_SV>= 10,000 ppm then EF_KG_8PPM = 0.0452 

EF_KG_8PPM, EF_KG_6PPM, EF_KG_4PPM, EF_KG_2PPM and EF_KG_0PPM are in unils of kg/hr/source 

> 

o 

m 

ro 
Correlation of Emission Factors vs %Leakers 

Gas Valves in EO & BD Units 

0.005 

CD 

O 

•5 0.004 

o 

CO 

_§> 0.003 

CO 

o 

o 

03 

LL 

c 

o 

"CO 

CO 

"E 

LU 

0.002 

0.001 -

a 

n 

a 

a! 

. ^rnean + 2s = 0.000520 

. J / D 

- — -jm - -g — — <—mean + Is = 0.000430 '-Qodan. n \ mean=0.000341 

n 

D 

a 

10 15 

Percent Leakers at 500 ppm 

20 25 
Correlation of Emission Factors vs %Leakers 

Gas Valves in EO & BD Units 

0.005 

o 

o 

CO 

CO 

k_ 

o 

••—» 

o 

03 

Li_ 

c 

o 

"co 

CO 

E 

UJ 

0.002 

0.001 

0 

-

-

-

• ^ 

_ 

/mean + 2s = 0.000529 

• i/n/mean + Is = 0.000403 

!^-Lfliean = 0.000277 

[£]. ...•—: D_J 

D

 D 

• 

• 

• 1 

• 

• 

• 

1 

10 20 30 

Percent Leakers at 50 ppm 

40 
Estimated EO/BD Emission Factors for various default zero values 

(kg/hr/source) 

8 ppm 4 ppm 0 ppm # of units 

5 %leakers & 500 

gas valves 

liquid valves 

pumps 

flanges 

ppm 

5 %leakers & 50 ppm 

gas valves 

liquid valves 

pumps 

flanges 

0.000341 

0.000853 

0.000104 

0.000378 

0.000277 

0.000736 

0.000039 

0.000333 

0.000331 

0.000761 

0.000092 

0.000348 

0.000265 

0.000639 

0.000021 

0.000296 

0.000319 

0.000556 

0.000079 

0.000313 

0.000248 

0.000422 

0.000000 

0.000252 

12 

11 

5 

14 

6 

9 

1 

9 

Tl 

Ul 

CO 
Correlation of Emission Factors vs %Leakers 

Gas Valves in EO & BD Units 

0.005 

CD 

O 

3 0.004 

o 

CO 

SP 0.003 -

co 

o 

g 0.002 

Li. 

</) 0.001 

"E 

LU 

0 

-

-. 

-

-

a i 

D 

D 

a ^> 

i 

• 

i 

• ^s 

• 

i 

10 15 

Percent Leakers at 500 ppm 

20 25 
Correlation of Emission Factors vs %Leakers 

Gas Valves in EO & BD Units 

0.005 

<D 

o 

3 0.004 

o 

CO 

_§> 0.003 

CO 

o 

g 0.002 

$ 0.001 

E 

LU 

10 20 30 

Percent Leakers at 50 ppm 

40 

TJ 

C7) 
Correlation of Emission Factors vs %Leakers 

Gas Valves in EO Units 

0.0035 

O 0.003 

3 

O 

CO 0.0025 -

CO 

o 

o 

03 

LL 

c 

o 

CO 

CO 

E 

LU 

0.002 -

0.0015 -

0.001 -

0.0005 

oto 

4 6 8 10 

Percent Leakers at 500 ppm 

12 14 
Correlation of Emission Factors vs %Leakers 

Gas Valves in EO Units 

0.0035 

O 0.003 

O 

{2 0.0025 

^ 0.002 

co 

o 

"5 0.0015 

03 

0ma 

5 10 15 20 

Percent Leakers at 50 ppm 

25 
Correlation of Emission Factors vs %Leakers 

Gas Valves in EO & BD(10,11,12 only) Units 

0.005 

CD 

O 

o 

CO 

0.004 -

_§> 0.003 

co 

o 

g 0.002 

c 

g 

<8 0.001 

E 

LU 

-

-

-

-

-

„ 

9^n 

i 

"/n 

i 

D y^ 

i 

/ ^ 

I 

0 10 15 

Percent Leakers at 500 ppm 

20 25 

O) 
Correlation of Emission Factors vs %Leakers 

Gas Valves in EO & BD (10,11,12 only) Units 

0.005 

CD 

O 

3 0.004 

o 

CO 

3 0.003 -

CO 

o 

g 0.002 

LL 

<0 0.001 

*E 

LU 

OffiB 

10 15 20 25 

Percent Leakers at 50 ppm 

30 35 
Correlation of Emission Factors vs %Leakers 

Liquid Valvns in EO & BD Units 

CD 

O 

13 

O 

CO 

0.012 

0.01 

0.008 -

D) 

CO 

O 

"o 

03 

LL 

C 

g 

"co 

~ 0.002 

LU 

0.006 

0.004 

5 10 15 20 

Percent Leakers at 500 ppm 

25 
Correlation of Emission Factors vs %Leakers 

Liquid Valves in EO Units 

0.0012 

<D 

rsour< (kg/hr/ Factors 

c issio 

b 

LU 

0.0011 

0.001 

0.0009 

0.0008 

0.0007 

0.0006 

0.0005 

0.0004 

• 

-D-

• 

• 

0.5 1 1.5 

Percent Leakers at 500 ppm 

• 

• 

L 
Correlation of Emission Factors vs %Leakers 

Liquid Valves in EO & BD (10,11,12 only) Units 

0.012 

10 15 

Percent Leakers at 500 ppm 

20 25 

oo 
Correlation of Emission Factors vs %Leakers 

Liquid Valves in EO & BD (10,11,12 only) Units 

<D O 

O 

CO 

0.012 

0.01 

0.008 -

O) 

£2 0.006 h 

o 

•4—• 

o 

03 

"- 0.004 -

CO 

j= 0.002 

LU 

10 15 20 

Percent Leakers at 50 ppm 

25 30 
Correlation of Emission Factors vs %Leakers 

Flanges in EO & BD Units 

0.0025 

CD 

O 

3 0.002 

o 

CO 

9> 0.0015 -

CO 

o 

g 0.001 

c 

o 

<0 0.0005 

E 

LU 

2 4 6 8 

Percent Leakers at 500 ppm 

10 

T3 
Correlation of Emission Factors vs %Leakers 

Flanges in EO & BD Units 

0.0025 

0 O 

•3 0.002 

O 

CO 

^0.0015 -

co 

o 

g 0.001 

LL 

</> 0.0005 

E 

LU 

4 6 8 10 12 

Percent Leakers at 50 ppm 

14 16 

Tl 
Correlation of Emission Factors vs %Leakers 

Flanges in EO & BD(10,11,12 only) Units 

0.0025 

CD 

O 

O 

CO 

0.002 -

0.001 -

9> 0.0015 -

co 

o 

"o 

03 

LL 

C 

o 

w 0.0005 

E 

LU 

2 3 4 5 

Percent Leakers at 500 ppm 

ro 
Correlation of Emission Factors vs %Leakers 

Flanges in EO & BD(10,11,12 only) Units 

0.0016 

g 0.0014 

g 0.0012 

SZ 

"o) 0.001 

2 0.0008 

o 

o 

** 0.0006 

.9 0.0004 

CO 

CO E 0.0002 UJ 

-

-

-

-

-

-

[3 • 

...• 

D 

I 

irx 

—tJ -

• 

-^"Q 

I 

jj-^-jr*^-"' 

D 

I I 

D 

• " 

I I i 

0 4 6 8 10 12 

Percent Leakers at 50 ppm 

14 16 
Correlation of Emission Factors vs %Leakers 

Pumps in EO & BD Units 

g 0.14 

20 30 40 50 

Percent Leakers at 500 ppm 

60 70 

^i 
Correlation of Emission Factors vs %Leakers 

Pumps in EO & BD Units 

0.16 

g 0.14 -

E 0.02 LU 

20 40 60 

Percent Leakers at 50 ppm 

80 
P.76 

ATTACHMENT 13 

-any process oobtfti rvi a+enals c\<*. mie.r/riiH-^^y 

Or d\sc*s<\ hnucus /* ckdrtLtd +© a. -aroctss unrt-. ^zolaied 

process m^ fke/\ occurs, uot.tct7 f/ie protest unit- is 

trn pti'eo/ prior +*o -t-lie. bc^'mnihc, o£ the. ne.x+ cycle.. 

£ samples ov B^+cU Optro/hoVl 

£> e..5 CY > p-h-*••<. (<i.v\aoca<a«..-
P.77 

' 

/&#// * 

I/O 

£62 

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64/z® 

6D1 

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tot® 

Zol® 

£a& 

Sac 

a 

£ 

(3 

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^MrfAAi of £rhl>Jibj£0)UC£ * 

% desjcsjc* , 

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o 

^ /6.&7 

So. 

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lO. #3 

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SOCG /?/>,*, 

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40.0 

/3.</3 

?,o<? 

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Q,69 

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/ / . / 

i 

i 

1 

i 

i 

'/ $es?t £<?.-itf -T#£<rsJ /test f?-r.-1,0 

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a 

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Co 

s<.J.;c ^a-r - f./!2. 4x 

„UC/*;fej'./v */o U,-e<s° /)/</. $<?;*/$ -",77/ ZtrSO i's<'JS.'0^i 

S£so£s '*0 <..?r4# /?$ •vor £ rf - /?*&'*£& $ M. 
PUM

P SEAL INFORMATION FOR ETHYLENE OXIDE FACILITIES 

SM = Single mechanical Seal 

DM = Dual Mechanical Seal 

P = Packed Seal 

Plant Pump 

ID Seal 

Number Type 

EO-1 Pum

p 11671 - 685 ppm — Sealless 

Pump 11811 - 73 ppm - Sealless 

23 others SM 

EO-2 

EO-3 

EO-4 

EO-S 

EO-6 

EO-7 

EO-8 

EO-9 

All SM 

Only info 

the seals 

AIL SM 

All DM 

Pump 1112 

Pump 1131 

Pump 1186 

Pump 1203 

Pump 1607 

Pump 32209 

Pump 32230 

Pump 32299 16 others 

All DM 

All DM 

All DM 

provided indie 

are - 0 - 0 - 0 - 0 - 0 NOT DM. 

• 

ppmv - DM 

ppmv - DM 

ppmv - DM 

ppmv - DM 

ppmv - DM 

- 0 ppmv - DM - O ppmv - DM - O ppmv — DM 

SM 

"n 

m tu ro CD U) <3 Ul 

-\] 

?0 D 

o 

a-a 

o 

o -H TJ CJ 
f 

Typical 

Product 

Natural Gas 

Condensate 

1550F(68°C) 

Propylene 

90°F (32°C) 

Ethane 

30°F (-1'C) 

.65 _ 

.60 _ 

£* .55 _ 

> 

a. 

a 

o .50 _ 

"o 

CD 

w" .45 _ 

.40 -. 

GRAPH 1 

Dura Seal Guidelines 

Based On Specific Gravity 

And Targeted Maximum 

Emission Levels 

Double (a.c) 

API Plans 53,54 

Tandem(a.b) 

API Plans 

11,13,52 

Single (b) 

API Plans 

11.13,23,32 

1 1 1 

1 1000 10,000 

Leakage to Atmosphere, 

ppm, 1 cm. from source 

Notes: (a) Minimurr 

(b) Floating 

(c) Buffer fl 

with pro 

i seal flush 3 gpm. 

throttle bushing 

uid must be compati 

cess fluid 

ble 

P.79 
P.80 

THREE SINGLE MECHANICAL SEAL PUMPS IN VOS SERVICE HERE SCREENED & BAG6ED TO DETERMINE 

FUGITIVE EMISSION RATES & COSTS FOR CONTROLLING TO < 500 PPM. 

PUMP 

DESIGNATION 

OVA 

SCREENING 

VALUE 

1 PPM 

; vos 

i LB/HR 

1 BAGGING 

1 VALUE 

TYPICAL 

HRS/YR 

vos 

EMISSIONS 

TONS/YR 

APROX. 

COST TO 

CONVERT 

TO DOUBLE 

MECH. SEAL 

COST $/ 

TON VOC 

REDUCTION 

1500. ,008 600. .0024 2000. S 800,000./ 

TON 

755. .00076 1280. .00049 2000. 4,000,000./ 

TON 

38000. 02 700. .007 2000. 300,000./ 

TON 
Draft: 2/13/90 

"STRAWMAN" EQUIPMENT LEAK REGULATION 

(Following is a rough draft for discussion purposes of the Reg Neg Committee of a possible 

regulation for equipment leaks. It includes provisions and concepts that have been identified by 

various committee members, ll is not intended lo represent EPA's or any other single Committee 

member's position, but is intended to reflect a melding of ideas presented so far. There are 

numerous references to existing Subpart V of 40 CFR Part 61 (NESHAP equipment leaks). The 

following language is quasi-regulatory and is presented lo show die sort of detail expected in the 

substantive provisions, not as the final regulatory language, especially references lo Subpart V, where 

wording changes would still be necessary. Any values in blanks are examples only, and do not 

represent consensus. Comments and explanation arc contained in "[]".] 

SCOPE OF STANDARDS Section 1. Application and designation of sources. 

(a) The provisions of this subpart apply to all source categories listed in Appendix . > 

O |We envision these standards to apply lo SOCMI process source categories (and not the typical, ^ _ 

large-scale continuous processing al petroleum refineries), dial use or produce any of the list of ^ t 

chemicals contained in the Clean Air Act Amendments (i.e., die list of 191).] ^3* 

SUBJECT TYPES OF (b) The provisions of this subpart apply to each of the following items of equipment that are TT\ 

EQUIPMENT intended to operate in hazardous organic NESHAP (HON) service: pumps, valves, flanges and other ^ H 

connectors, agitator seals, compressors, pressure relief devices, sampling connection systems, and open- ^ M 

ended valves or lines. m-X 

(The equipment leak standards for the HON, when established, will cover the same «"aV 

equipment as found in Part 61 Subpart V. This negotiation focuses on ihose sources to which leak £ ^ 

detection and repair has been applied, namely pumps and valves; we will also include flanges and 

other connectors, from which emissions become proportionally more significant as emissions from 

other controlled equipment decrease, and agitator seals. Standards for compressors, pressure relief 

devices, sampling connection systems, and open-ended valves or lines will remain unchanged and will 

apply lo HON sources as ihey have applied lo Subpart V sources because these are zero emission 

standards. For simplicity the rest of this draft regulation will deal only with pumps, valves, flanges, 

and agitator seals. For lack of a belter descriptor currently, we will refer to "in HON service" as 

those pieces of equipment associated wilh die HON source categories.] 

TJ 

00 
Draft: 2/13/90 

ORGANIC PERCENT (c) The provisions of this subpart apply to each piece of equipment in HON service containing 

CUTOFF greater than (e.g.. 1) percent by weight of the total of HON chemicals in the process stream. 

[Although in the past, standards have applied to streams containing 10 percent or greater of 

the pollutant covered, it is not clear why this level would be appropriate for diese standards, in light 

of die much lower leak definitions. In addition, as we achieve much lower emissions for those 

higher concentration sources (10 percent or greater), equipment handling those streams less than 10 

percent become proportionally greater emitters, if the standards do not extend to diem. On die other 

hand there may be a need to identify some low level of organies in the equipment, e.g., 1 percent 

total hazardous organies, dial avoids regulation of streams with relatively small contaminant levels.] 

STANDARDS FOR EXISTING Section 2. Existing facilities: Standards for pumps, valves, flanges, and agitator seals. 

UNITS 

The provisions of this section apply to facilities that commenced construction before (date of 

proposal) . The owner or operator of a facility may elect to meet the requirements of a later phase 

during the period in which an earlier phase is effective, provided he notifies the Administrator as 

required in Section 7. 

PHASE I: LDAR; (a) Phase I: LDAR. On and after (e.g., 90 days from the date of promulgation) pumps and 

CURRENT LEAK valves must meet current leak detection and repair (LDAR) requirements as described in 40 CFR 

DEFINITION (10,000 61.242-2 (pumps) and 61.242-7 (valves). In addition, flanges and agitator seals must meet parallel 

PPM) requirements to valves |regulatory language to be worked onj. Other applicable provisions would 

include 61.242-10 (Delay of repair), 61.243-1 and -2 (Alternative standards for valves), and 61.244 

(Alternative means of emission limitation). (These other provisions would also apply to flanges]. 

(This provision is designed to achieve die degree of control that LDAR provides as soon as 

possible, to heighten awareness of leaks and leak control, to assist plants in identifying die sort of 

steps dial will need to be taken to meet die Phase III standards, and to provide time to meet diose 

standards. LDAR will also be applied to flanges and agitator seals die same way it currently applies 

to valves. The definition of a leak and no detectable emissions will remain unchanged during this 

transition. Method X, similar to Method 21, is being developed for these regulations and will belter 

address such things as calibration gas and response factor correction. For simplicity, we will 

continue lo refer to Method 21 here, keeping in mind dial a similar, but new mediod will ultimately 

apply.] 
Draft: 2/13/90 

PHASE II: LDAR; 

TIGHTER LEAK 

DEFINITION 

PHASE III: 

PERFORMANCE 

STANDARDS; 

ALLOWABLE 

LEAKERS 

VALVES 

PUMPS 

FLANGES 

(b) Phase II: LDAR. On and after (e.g.. 18 months from Hie start of Phase I) pumps, valves, 

flanges and agitator seals must meet the same requirements as (a) above, except that a leak is defined as 

an instrument reading of (e.g.. SO) ppmv as measured according to Method 21, and a leak repair is not 

required for leaks less than (e.g., 50-500) ppmv. "No detectable emissions" is redefined as (0.5 x leak 

definition) ppmv. (Standards for other equipment, e.g. compressors, pressure relief devices, etc., 

described in 40 CFR Subpart V, would also be revised to be consistent with the redefinitions here.] 

(This provision represents a lowering of die standard in die form of a lower leak definition. 

Whereas Phase I was designed to assure that a basic leak detection and repair program is started 

early and to focus on die largest leakers, Phase II is designed to expand the program to include 

smaller leaks. To assure dial total emissions arc reduced, il is necessary to address these sources that 

leak at rates much lower than indicated by a 10,000 ppmv monitor reading. Phase II is also intended 

to provide to plant operators die data needed lo determine what combination of practices and 

equipment will be needed to meet specific leak rate targets. This phase also recognizes that die 

"leak" definition need not be the same at which leak repair is required. 

(c) Phase III: On and after (e.g., 18 months from the start of Phase II) the following numbers 

of allowable leakers will apply for the specified equipment (Phase I I LDAR requirement will not apply 

in Phase HI): 

(1) For valves: at a leak definition of (e.g., 50) ppmv, no more than (e.g., 5) percent leaks or 

(e.g., 1) valve leaking, whichever is greater. 

(2) For pumps: at a leak definition of (e.g., 50) ppmv, no more than (e.g., .5) percent leaks or 

(e.g., 1) pump leaking, whichever is greater. 

(3) For flanges: at a leak definition of (e.g., 50) ppmv, no more than (e.g.. 5) percent leaks or 

(e.g.. 1) flange leaking, whichever is greater. 

(The performance standards are expressed in terms of percent or number of allowable leakers 

and not emissions, because leaks are a parameter dial can be directly and easily measured whereas 

mass fugitive emissions are noL Although die relationship between percent leaks and emissions is 

not precise, percent leaks are the best indirect indicator of mass emissions. Therefore il makes sense 

to specify a performance standard in terms of leaks. The above structure also allows for different 

leak definitions for different components. The standards also allow for small component counts. For 

example, if the standard for pumps were 5 percent leakers, and a facility had only 8 pumps, die 

standard would be the minimum allowable number of leakers instead of a percent. 
Draft: 2/13/90 

INITIAL 

SCREENING 

INITIAL 

FREQUENCY 

REPAIR A 

COMPONENT 

PERCENT 

LEAKER 

CALCULATION 

Other provisions currcndy in Subpart V will still apply such as those for difficult and unsafe 

to monitor equipment; delay of repair; and alternative means of emission limitation.] 

(5) All components in subparagraphs (l)-(4) shall be screened within 90 days after (the onset of 

Phase III) using the test methods and procedures in Section 5. 

(6) The results in subparagraph (5) of this paragraph shall be used to determine the initial 

screening frequency for each type of component, as specified in Section 4. 

(7) If a screening value greater than (e.g.. 50-500) ppmv is found, it must be repaired within 15 

days, with a first attempt at repair within 5 days. 

[It makes sense to repair a component that can be repaired wilh reasonable assurance dial 

greater leakage would not result. Thus the repair trigger screening value is higher than the leak 

definition.] 

(8) Percent leaking components shall be calculated according to the following formula: 

L% = ((# of leakers)/(baseline)) * 100 

where # of leakers = number of components with screening value greater than the specified leak 

definition 

STANDARDS 

FOR OTHER 

EQUIPMENT 

STANDARDS FOR NEW 

UNITS 

baseline =(number of components screened) + ( 0.5 x number of components taken out 

of service in an active unit subsequent to the initial screening performed as required in 

(c)(5) of this section) 

(d) Standards for other equipment covered by this subpart remain unchanged. 

Section 3. New facilities: standards for pumps, valves, flanges and agitator seals. 

The provisions of this section apply to facilities that commenced construction after (date of 

proposal) . 
Draft: 2/13/90 

PUMPS AND 

AGITATOR SEALS 

(a) For pumps and agitator seals: at a leak definition of (e.g., 50) ppmv, no more than (e.g., 3) 

percent leaks or (e.g., 1) component leaking, whichever is greater. 

VALVES AND 

FLANGES 

INITIAL SCREENING 

INITIAL FREQUENCY 

REPAIR A 

COMPONENT 

SCREENING FREQUENCY 

VALVES 

MONTHLY 

(b) For valves and flanges: at a leak definition of (e.g.. 50) ppmv, no more than (e.g., 3) percent leaks 

or (e.g.. 1) component leaking, whichever is greater. 

(3) Percent leaking components shall be calculated according to the following formula: 

L% = ((# of leakers)/(TC)) * 100 

where # of leakers = number of components with screening value greater than the specified leak 

definition 

TC =number of components screened 

(c) All components in paragraphs (a) and (b) shall be screened within 90 days after the date of 

startup using the test methods and procedures in Section 5. 

(d) The results in paragraph (c) of this paragraph shall be used to determine the initial 

screening frequency for each type of component, as specified in Section 4. 

(e) If a screening value greater than (e.g.. 50-500) ppmv is found, it must be repaired within 15 

days, with a first attempt at repair within 5 days. 

Section 4. Screening frequency. 

Based on the results of screening required in Section 2(5), Section 3(c), and this section, the 

following screening frequencies apply: 

(a) Valves. 

(1) Greater than the number of allowable leakers, except as provided in paragraphs (3) and (4) 

below: monthly screening of all components for at least 2 consecutive months. If 2 consecutive 

screenings are each less than or equal to the number of allowable leakers, the frequency in paragraph 

(2) below will apply. 
Draft: 2/13/90 

QUARTERLY 

SEMIANNUAL 

ANNUAL 

FLANGES 

QUARTERLY 

ANNUAL 

BIENNIAL 

PUMPS AND 

AGITATOR SEALS 

MONTHLY 

QUARTERLY 

(2) Equal to or less than the number of allowable leakers: quarterly screening of all 

components, except as provided in paragraphs (3) and (4) below. 

(3) Equal to or less than the number of allowable leakers for 2 consecutive quarterly or annual 

screenings: semiannual screening of all components, except as provided in paragraph (4) below. If a 

source exceeds the number of allowable leakers during a semiannual screening, the frequency specified 

in paragraph (2) applies. 

(4) Less than 0.5 times the number of allowable leakers for 2 consecutive quarterly or 

semiannual screenings: annual screening of all components. If a source exceeds the number of 

allowable leakers during an annual screening, the frequency specified in paragraph (2) applies. 

(b) Flanges. 

(1) Greater than the number of allowable leakers: quarterly screening of all components for at 

least 2 consecutive quarters. If 2 consecutive screenings are each less than or equal to the number of 

allowable leakers, the frequency in paragraph (2) below will apply. 

(2) Equal to or less than the number of allowable leakers: annual screening of all components, 

except as provided in paragraph (3) below. 

(3) Less than 0.5 times the number of allowable leakers for 2 consecutive annual screenings: 

biennial screening of all components. 

(c) Pumps and agitator seals. 

(1) Greater than the number of allowable leakers: monthly monitoring of all components for at 

least 2 consecutive months. 

(2) Equal to or less than the number of allowable leakers: quarterly monitoring of all 

components. 
Draft: 2/13/90 

ALTERNATIVE STANDARDS: 

RANDOM SAMPLING 

REPAIR A 

COMPONENT 

ALTERNATIVE STANDARDS: 

BATCH PROCESSES 

Section 4a. Alternative standards for valves and flanges: random sampling. 

(a) The owner or operator of a facility may choose to screen a random sample of components 

instead of screening all components as required in paragraphs 4(a)(3) and (4), and 4(b)(2) and (3). 

(b) [This paragraph will describe the random sample selection scheme. We envision a random 

sample scheme very similar to dial used in the woodstoves standards, copies of which have been distributed 

to the negotiating committee. Basically, (his scheme identifies a minimum number of items to sample and 

establishes the numbers that indicate both a "pass" or a "fail". Components are sampled sequentially from a 

starting point until the number of leakers found eidier indicates a "pass" or a "fail". The minimum and 

maximum numbers lo be screened, and die numbers indicating "pass" and "fail" will be published in die rule. 

Once a facility reaches an indicator of "pass" or "fail", il cannot continue unless all components in die facility 

are sampled. In addition, the alternative standard cannot be used to advance to less frequent monitoring; i. e., 

If one is sampling randomly for a semiannual frequency, he cannot use the results to advance to annual 

sampling. 

Several start points would be pre-identified prior to die random selection process. Conceptually, a 

sampling route through the entire plant would be identified which would be divided into roughly equidistant 

starting points, not lo exceed 10. A start point would dien be randomly selected using a well-known and 

widely available "generator", such as die last number in die Dow Jones Industrial Average close for the 

second Wednesday of die mondi. Screenings would then be performed within X days after that date. 

Finally, this section would specify that air components previously found leaking and repaired would 

be included in die sample, irrespective of ils location.] 

(c) If a screening value greater than (e.g.. 50-500) ppmv is found, it must be repaired within 15 

days, with a first attempt at repair within 5 days. 

Section 4b. Alternative standards: batch processes. 

[This section would describe alternative standards developed for batch processes, if any. These 

standards could replace all or part of a phase.] 

oo 
Draft: 2/13/90 

EQUIVALENT STANDARDS 

ENFORCEMENT 

SCREENINGS 

TEST METHODS 

Section 4c. Equivalent standards. 

[This section would describe criteria for determining equivalence. It is generally agreed dial any 

approach for determining equivalence would be based on emissions, i.e., the equivalent standard 

would have lo demonstrate that equal or greater emission reduction would be achieved compared with 

die published standard.] 

Section 4d. Enforcement screenings. 

(a) At any time, the Administrator may require the owner or operator of a plant to perform a 

screening of all or a random sample of components as described in section 4a(b). 

(b) The results of any screening required by paragraph (a) above will be used to determine the 

subsequent screening frequency as described in Section 4. 

Section 5. Test methods and procedures. 

(a) The test methods and procedures contained in 61.245 apply (substituting the applicable leak 

and organic concentration definitions as specified above). 

(b) Screening results shall be adjusted for response factor of the instrument by either: 

(1) Applying the highest response factor that would be found in any of the process streams of 

the process unit to all screening values for that unit regardless of the chemical component mix, or 

(2) Applying individual response factors to each screening value for the specific chemical mix 

found in the piece of equipment screened. 

(3) Adjusted screening values shall be calculated according to the following formula: 

SVA = |(HO% x HO RF) + Z (SOLn% x SOLn RF)( x fSV» • SV.I 

(HO% + I (SOLn% + SOLn%)) 

where SVA = the adjusted screening value 

HO% = percentage of the hazardous organic in the equipment being screened 
CURRENT 

REQUIREMENTS 

APPLY 

RANDOM SAMPLE 

REQUIREMENTS 

REPORTING 

Draft: 2/14/90 

HO RF = the instrument response factor for the hazardous organic in the equipment 

being screened 

SOLn% = percentages of each of the n solvents in the equipment screened 

SOLn RF = response factor for each of n solvents in the equipment screened 

SV0 = observed screening value 

SV„ = background screening value 

(4) Individual compound response factors shall be determined directly for the specific instrument 

used in the screening according to the procedure in Method X. Published response factors may not be 

used in determinine adjusted screening values. 

(Response factors are not only a function of the type or model of instrument used but are also 

instrument specific, even among instruments of die same model. It is important to calculate die 

instrument-specific response factors for this reason. According to the current Method 21, an average 

of diree calculated response factors would be used (Section 4.4.1)J 

6. Recordkeeping. 

(a) The current recordkeeping requirements of 61.246 shall apply. 

[This will be revised to include flanges and agitator seals, which will have requirements similar to 

valves.] 

(b) An owner or operator choosing to employ random sequential screening as described in 

Section 4a must maintain records that 

(1) Identify the entire sampling route, including location of all starting points, and location and 

type of each component, prior to the initial random screening, and 

(2) Identify the start point of each screening, the number of components screened, the number 

of leaking components, and identity of each component found leaking. 

Section 7. Reporting. 
Draft: 2/13/90 

CURRENT 

REQUIREMENTS AND 

LEAKER 

INFORMATION 

NOTIFICATION OF 

ADVANCED PHASE 

IMPLEMENTATION 

(a) The same reporting requirements contained in 61.247 apply. In addition to the information 

requested in 61.247(b), this report shall identify those sources (e.g., valves in liquid service, valves in gas 

service, etc.) found leaking, the percent leakers of each type of source, and the total number of each 

type of source tested. 

(b) An owner or operator who wishes to implement a later phase than required at the current 

time must notify Ihe Administrator at least 30 days prior to the initial screening required in Section 

2(c)(5). 

NOTIFICATION OF 

LESS FREQUENT 

MONITORING 

NOTIFICATION OF 

ALTERNATIVE 

STANDARD 

(c) An owner or operator who wishes to use the results of a screening performed in Section 4 to 

go to less frequent monitoring, must notify the Administrator in writing at least 30 days prior to 

screening. 

(d) An owner or operator wishing to use an alternative standard must notify the Administrator 

in writing at least 30 prior to implementing the alternative standard. 

FORM OF SUBMITTAL 

OF SCREENING 

INFORMATION 

(e) All reports shall be submitted to EPA on electronic media (e.ghard copy. floppy diskettes) as well as 

[Emissions data are needed by die source and by several EPA programs for a number of 

purposes. Computer-generated information would be much more easily accessible and analyzed. It 

makes sense, therefore, to pursue die development of an electronic data format that could meet the 

various needs.] 

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