United States 

Environmental Protection 

Agency 

IMPLEMENTATION DOCUMENT FOR THE 

PESTICIDE ACTIVE INGREDIENT 

PRODUCTION NESHAP -

(40 CFR 63, SUBPART MMM) 

EPA-305-B-05-001 

March 2005 

Implementation Document for the 

Pesticide Active Ingredient Production 

NESHAP 

(40 CFR 63, Subpart MMM) 

Prepared for:

Air Compliance Branch

Compliance Assessment and Media Programs Division (CAMPD)

Office of Compliance (OC)

Office of Enforcement and Compliance Assurance (OECA)

U.S. Environmental Protection Agency

Washington, DC 20460

and

Information Transfer and Program Integration Division (ITPID)

Program Implementation and Review Group (PIRG)

Office of Air Quality Planning and Standards (OAQPS)

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Prepared by:

Research Triangle Institute 

3040 Cornwallis Road

Research Triangle Park, North Carolina 27709-2194

What is the legal status of this guide? 

The Office of Air Quality Planning and Standards (OAQPS) and the Office of Enforcement and 

Compliance Assistance (OECA) of the U. S. Environmental Protection Agency (EPA) have reviewed this 

document and approved it for publication. 

When using this document, remember that it is not legally binding and does not replace the final rule -

“National Emission Standard for Hazardous Air Pollutants for Pesticide Active Ingredient Production” 

(published in the Federal Register, 6/23/99, 64 FR 33550 and amended 6/3/02, 9/20/02, and 11/21/02) 

or any State, local or tribal rules that may apply to your facility. 

This document is not intended, nor can you rely on it, to create any rights enforceable by any party in 

litigation with the United States. The EPA may change this document at any time without public notice. 

i 
Thank You 

The document was prepared by a joint partnership among the Environmental Protection Agency 

(EPA, or we), State and local agencies for air pollution control, trade associations, and 

organizations who produce pesticide active ingredients. The development team had the 

following members: 

Alfred Azevedo, WV Office of Air Quality
 
 

Lalit Banker, EPA, OAQPS, ESD
 
 

John A. Dege, DuPont Environmental Center for Excellence
 
 

Richard A. DiMenna, Rohm and Haas Company
 
 

Dianne J. Walker, EPA, PTAB, Region III 
 
 

We thank these people for their participation. Their technical insights, experiences, and 

suggestions were essential to this guide’s development. 

ii 
Table of Contents 

Page 

What is the legal status of this guide? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i 
 
 

List of Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii 
 
 

List of Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii 
 
 

List of Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix 
 
 

Chapter 1 - Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 
 
 

Why should I use this implementation document? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 
 
 

What provisions does this document describe? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 
 
 

Is there anything I should know before using this document? . . . . . . . . . . . . . . . . . . . . . . 1-1 
 
 

How do I get copies of this document? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 
 
 

We want your feedback . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 
 
 

Survey on the Implementation Document for the Pesticide Active Ingredient Production
 
 

NESHAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3 
 
 

Chapter 2 - What this Pesticide Active Ingredient rule covers - An Overview . . . . . . . . . . . . . 2-1 
 
 

Why was this Pesticide Active Ingredient (PAI) rule written? . . . . . . . . . . . . . . . . . . . . . . 2-1 
 
 

How do I know if I am subject to this rule? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 
 
 

What is an affected source? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 
 
 

When do I need to comply? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 
 
 

What pesticide active ingredients are subject to the rule? . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7 
 
 

How does “primary use” differ from “primary product”? . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7 
 
 

How do I determine the primary use of a product? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8 
 
 

What is a pesticide active ingredient (PAI) process unit? . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8 
 
 

What is an integral intermediate? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-9 
 
 

How is “nondedicated” equipment regulated? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10 
 
 

How do I know if a storage vessel is part of a PAI process unit? . . . . . . . . . . . . . . . . . . . 2-11 
 
 

What requirements apply during periods of startup, shutdown, and malfunction? . . . . . . 2-11 
 
 

What provisions in this rule overlap provisions in other rules? . . . . . . . . . . . . . . . . . . . . 2-12 
 
 

What is exempt from the rule? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13 
 
 

Chapter 3 - Complying with requirements for process vents . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 
 
 

What is a process vent? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 
 
 

What process vents does Subpart MMM apply to? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 
 
 

What process vents are exempt? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 
 
 

What compliance options do I have for my Group 1 process vents? . . . . . . . . . . . . . . . . . 3-3 
 
 

How do I show initial compliance with the process vent requirements? . . . . . . . . . . . . . . . 3-8 
 
 

What monitoring must I do for my process vents? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-12 
 
 

What parameters must I monitor? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-12 
 
 

How do I set monitoring parameter limits? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-17 
 
 

iii 
Table of Contents (cont’d) 

Page 

How do I monitor to comply with the alternative standard? . . . . . . . . . . . . . . . . . . . . . . . 3-18 
 
 

How may I average my monitoring parameter values? . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-18 
 
 

What records must I keep for my process vents? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19 
 
 

What reports must I submit for my process vents? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20 
 
 

Checklists for Process Vent Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21 
 
 

Chapter 4 - Complying with requirements for storage vessels . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 
 
 

What is a storage vessel? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 
 
 

What storage vessels are subject to subpart MMM? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 
 
 

What storage vessels are exempt? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 
 
 

What is a “Group 1” storage vessel? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2 
 
 

How do I know if a storage vessel is part of a PAI process unit? . . . . . . . . . . . . . . . . . . . . 4-2 
 
 

What compliance options do I have for my storage vessels? . . . . . . . . . . . . . . . . . . . . . . . 4-3 
 
 

How do I show initial compliance with the storage vessel requirements? . . . . . . . . . . . . . 4-5 
 
 

How do I comply when my control device needs repairs [options 5 (A, B, C, and E)]? . 4-11
 
 

What monitoring must I do for my storage vessels? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-11 
 
 

What records must I keep for my storage vessels? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17 
 
 

What reports must I submit for my storage vessels? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17 
 
 

Checklists for Inspection of Storage Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-19 
 
 

Chapter 5 - Complying with requirements for wastewater systems . . . . . . . . . . . . . . . . . . . . . 5-1 
 
 

What wastewater streams are subject to Subpart MMM? . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 
 
 

What types of wastewater components are subject to Subpart MMM? . . . . . . . . . . . . . . . 5-1 
 
 

What wastewater streams are exempt? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2 
 
 

How do I identify a Group 1 wastewater stream? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2 
 
 

What are my compliance options for wastewater systems? . . . . . . . . . . . . . . . . . . . . . . . . . 5-3 
 
 

What are my emission suppression compliance options? . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4 
 
 

What are my compliance options for air pollution control devices? . . . . . . . . . . . . . . . . . . 5-9 
 
 

What treatment compliance options do I have for my wastewater streams? . . . . . . . . . . . 5-10 
 
 

How do I show initial compliance with the emission suppression compliance 
 
 

requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-13 
 

How do I show initial compliance with the treatment compliance requirements? . . . . . . 5-13 
 

How do I show initial compliance with the control device compliance requirements? . . 5-19
 

What monitoring must I do to comply with the emission suppression requirements for 
 

waste management units? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-22 
 
 

What monitoring must I do for my wastewater treatment unit? . . . . . . . . . . . . . . . . . . . . 5-28 
 
 

What monitoring must I do for my air pollution control device? . . . . . . . . . . . . . . . . . . . 5-28 
 
 

How do I inspect my closed-vent systems? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-30 
 
 

What are my compliance options for heat exchange systems? . . . . . . . . . . . . . . . . . . . . . 5-30 
 
 

What records must I keep for my wastewater systems? . . . . . . . . . . . . . . . . . . . . . . . . . . 5-33 
 
 

What reports must I submit for my wastewater systems? . . . . . . . . . . . . . . . . . . . . . . . . . 5-38 
 
 

Checklists for Wastewater System Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-43 
 
 

iv 
Table of Contents (cont’d) 

Page 

Chapter 6 - Complying with requirements for equipment leaks . . . . . . . . . . . . . . . . . . . . . . . . 6-1 
 

What equipment leaks are regulated by Subpart MMM? . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1 
 

How do I identify equipment subject to the equipment leak provisions? . . . . . . . . . . . . . . 6-1 
 

What equipment is exempt? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2 
 

What compliance options do I have for my equipment leaks? . . . . . . . . . . . . . . . . . . . . . . 6-2 
 

How do I implement a leak detection and repair (LDAR) program under Option 1? . . . . . 6-3 
 

What are the LDAR requirements for Pumps in Light Liquid Service and Agitators in
 

Gas/Vapor Service and Light Liquid Service (Option 1)? . . . . . . . . . . . . . . . . . . . . . . 6-7 
 

What are the LDAR requirements for open-ended valves or lines (Option 1)? . . . . . . . . 6-10 
 

What LDAR requirements apply to valves in gas/vapor or light liquid service 
 

(Option 1)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11 
 

What LDAR requirements apply to compressors (Option 1)? . . . . . . . . . . . . . . . . . . . . . 6-13 
 

What LDAR requirements apply for pressure relief devices in gas/vapor service 
 

(Option 1)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-14 
 

What LDAR requirements apply for sampling connection systems (Option 1?) . . . . . . . 6-15 
 

What LDAR requirements apply for pumps, valves, connectors, and agitators in heavy 
 

liquid service; instrumentation systems; and pressure relief devices in liquid service
 

(Option 1) ?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16 
 

What LDAR requirements apply for connectors in gas/vapor or light liquid service 
 

(Option 1)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-17 
 

What are my compliance requirements for closed-vent systems and control devices
 

(Option 2)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-20 
 

What are my compliance requirements for pressure testing (Option 3)? . . . . . . . . . . . . . 6-22 
 

What are my compliance requirements for alternative monitoring of batch processes 
 

(Option 4)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-24 
 
 

What is required for an alternative standard (Option 5)? . . . . . . . . . . . . . . . . . . . . . . . . . 6-25 
 
 

What are my leak repair requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-26 
 
 

What if equipment is unsafe or difficult to monitor (Options 1, 2, and 4?) . . . . . . . . . . . 6-28 
 
 

What records must I keep for my equipment leaks? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-29 
 
 

What reports must I submit? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-37 
 
 

Checklists for Equipment Leak Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-40 
 
 

Chapter 7 - Sample calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1 
 

What calculations are required by Subpart MMM? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1 
 

How do I calculate uncontrolled process vent emissions? . . . . . . . . . . . . . . . . . . . . . . . . . 7-2 
 

How do I determine if process vents are Group 1 or Group 2? . . . . . . . . . . . . . . . . . . . . . . 7-7 
 

How do I calculate the flow-weighted average flowrate for “large” process vents? . . . . . . 7-8 
 

How do I calculate controlled emissions out of a condenser? . . . . . . . . . . . . . . . . . . . . . . . 7-9 
 

How do I correct concentration measurements to account for supplemental gases? . . . . . 7-11 
 

How do I determine if I have a heat exchange system leak when complying with option 
 

HE1? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-13 
 
 

Chapter 8 - Recordkeeping and reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1 
 
 

What records must I keep? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1 
 
 

v 
Table of Contents (cont’d) 

Page 

What do I have to report and when? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2 
 
 

How can I change the date my reports are due? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2 
 
 

Where do I send my reports? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2 
 
 

Chapter 9 - Other requirements and information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1 
 
 

Who administers this regulation? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1 
 
 

Do I need a title V permit? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-2 
 
 

How do I change my permit to include this rule? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-2 
 
 

What portions of the General Provisions apply? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-3 
 
 

Chapter 10 - Getting additional help . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10-1 
 
 

Whom can I ask for help? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10-1 
 
 

Can I get more information on the Web? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10-3 
 
 

Is there a list of commonly asked questions? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10-4 
 
 

Chapter 11 - Supplemental information for State and local agencies and Tribes . . . . . . . . . . 11-1 
 
 

How many facilities may need to meet emission limits? . . . . . . . . . . . . . . . . . . . . . . . . . . 11-1 
 
 

Who regulates facilities in Indian Country? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-1 
 
 

How much HAP emissions will the rule reduce? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-1 
 
 

vi 
List of Figures 

Page
 

Figure 2-1. Compliance Timeline and Reporting Requirements for Existing
 

Affected Sources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5 
 

Figure 2-2.	 	 Compliance Timeline and Reporting Requirements for New and
 

Reconstructed Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6 
 

Figure 6-1. 	 	Flowchart of monitoring frequencies for connectors . . . . . . . . . . . . . . . . . . . . 6-19 
 
 

List of Tables 

TABLE 3-1. Compliance Options for Process Vents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4 
 

TABLE 3-2. Monitoring Requirements for Air Pollution Control Devices . . . . . . . . . . . . . 3-14 
 

TABLE 4-1. Design and Operating Requirements for Storage Vessels Equipped with a
 

Floating Roof . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7 
 

TABLE 5-1. Performance Testing Requirements for Treatment Units . . . . . . . . . . . . . . . . 5-15 
 

TABLE 5-2. Characteristics to Consider in Design Evaluations for Control Devices . . . . . 5-19 
 

TABLE 5-3. Inspection Requirements for Waste Management Units . . . . . . . . . . . . . . . . . 5-23 
 

TABLE 5-4. Monitoring Requirements for Control Devices . . . . . . . . . . . . . . . . . . . . . . . . 5-29 
 

TABLE 5-5. Recordkeeping Requirements for Wastewater Systems . . . . . . . . . . . . . . . . . 5-34 
 

TABLE 5-6. Information on Wastewater Systems to Include in the Notification of 
 

Compliance Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-38 
 

TABLE 5-7. Information on Wastewater Systems and Heat Exchange Systems to Include in
 

Your Periodic Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-40 
 
 

TABLE 6-1. General Requirements and Exceptions of the Equipment Leak Provisions . . . 6-4
 
 

TABLE 6-2. Recordkeeping Requirements of the Equipment Leak Provisions . . . . . . . . . 6-31 
 
 

TABLE 7-1. Operational and Emissions Data for a PAI Process . . . . . . . . . . . . . . . . . . . . . . 7-1 
 
 

TABLE 8-1. Summary of Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-4 
 
 

TABLE 8-2. Report Due Dates for Existing Affected Sources . . . . . . . . . . . . . . . . . . . . . . 8-10 
 
 

vii 
List of Tables (cont’d) 

TABLE 8-3. Report Due Dates for New Affected Sources . . . . . . . . . . . . . . . . . . . . . . . . . 8-11 
 
 

TABLE 8-4. Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-12 
 
 

TABLE 9-1. General Provisions Applicability to Subpart MMM . . . . . . . . . . . . . . . . . . . . . 9-3 
 
 

TABLE 10-1. EPA Regional Air Division Offices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10-2 
 
 

viii 
List of Acronyms 

ADI Applicability Determination Index 

AMR Actual mass removal 

APCD Air pollution control device 

ATW Air Toxics Website 

BACT Best available control technology 

CAA Clean Air Act 

CFR Code of Federal Regulations 

CEMS Continuous emissions monitoring system 

Cl2 Chlorine 

CMS Continuous monitoring system 

DOT Department of Transportation 

EFR External floating roof 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

Fr Fraction removed 

GPO Government Printing Office 

HAP Hazardous air pollutant 

HCl Hydrochloric acid 

HDPE High density polyethylene 

HON Hazardous Organic NESHAP 

IDS Individual drain system 

IFR Internal floating roof 

LAER Lowest achievable emissions rate 

LDAR Leak detection and repair 

MACT Maximum achievable control technology 

NEPIS National Environmental Publications Internet Site 

NESHAP National Emission Standards for Hazardous Air Pollutants 

NOCSR Notification of compliance status report 

NPDES National Pollution Discharge Elimination System 

NSCEP National Service Center for Environmental Publications 

NSPS New Source Performance Standards 

OECA Office of Enforcement and Compliance Assurance 

PAI Pesticide active ingredient 

POD Point of determination 

PS Performance specification 

PTE Potential to emit 

PUG Process unit group 

QA/QC Quality assurance/quality control 

RCRA Resource Conservation and Recovery Act 

RMR Required mass removal 

SBAP Small Business Assistance Program 

SSMP Startup, shutdown, and malfunction plan 

STAPPA/ State and Territorial Air Pollution Program Administrators and Local Air

 ALAPCO Pollution Control Officials 

TOC Total organic compounds 

ix 
List of Acronyms (cont’d) 

TSDF Treatment, storage, and disposal facility 

TTN Technology Transfer Network 

x 
Chapter 1 - Introduction 

Why should I use this implementation document? 

This document can help facility owners and operators understand the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for Pesticide Active Ingredient (PAI) Production (also known as 

Subpart MMM) by helping you determine: 

C if the rule applies to your facility and process 

C what compliance options are available
 
 

C how to establish initial compliance
 
 

C how to monitor ongoing compliance
 
 

C what records to keep
 
 

C what information to report
 
 

C dates by which you must meet requirements
 
 

C how to perform required calculations 

What provisions does this document describe? 

This document describes the standards and compliance options for process vents, storage vessels, 

wastewater systems, and equipment leaks except for the emissions averaging and pollution prevention 

options. 

Is there anything I should know before using this document? 

When using this document, remember that it does not replace the final rule but summarizes the 

requirements published in the final rule and its 

amendments. You should keep up with any new 

requirements by periodically checking the Federal Keep informed of rule changes, if any, by

Register and the Code of Federal Regulations (CFR). checking the Federal Register. You can download Federal Register notices by going 

to the Government Printing Office (GPO) website at 

www.gpoaccess.gov/fr/index.html. 

You can download a copy of the amended final rule as published in the Code of Federal Regulations at 

the GPO website: www.gpoaccess.gov/cfr/retrieve.html. 

1-1
 
How do I get copies of this document? 

You can get copies of this document in three ways: 

C	 	 EPA’s Office of Enforcement and Compliance Assurance website
 
 

(www.epa.gov/compliance/assistance/sectors/index.html). Look under Pesticide Active
 
 

Ingredients.
 
 

C	 	 National Service Center for Environmental Publications (www.epa.gov/ncepiham/index.htm). 

Look under Online Publications, and then the National Environmental Publications Internet Site 

(NEPIS) and EPA document number 305-B-05-001. 

C	 	 EPA’s Technology Transfer Network Air Toxics Website (www.epa.gov/ttn/atw). Look under 

Rules and Implementation, national emission standards for hazardous air pollutants, pesticide 

active ingredient, or www.epa.gov/ttn/atw/pest/pestpg.html. 

We want your feedback 

To serve you better, we have included a survey on the usefulness of this document. If you would like to 

participate, please fill out the survey on page 1-3 and return it to the address indicated. We will keep your 

responses confidential if you desire, but use them to help us improve future documents. 

Help us publish better documents by filling 

out our survey 

1-2
 
 
_______________________________________________________________________________________________________ 

_______________________________________________________________________________________________________ 

_______________________________________________________________________________________________________ 

_______________________________________________________________________________________________________ 

_______________________________________________________________________________________________________ 

_______________________________________________________________________________________________________ 

Survey on the Implementation Document for the 

Pesticide Active Ingredient Production NESHAP 

Please help us gauge this document’s usefulness by completing this short form. We will keep your responses confidential if you 

desire, but use them to help improve future documents. Check this box if you would like us to keep your responses confidential Q 

1. What type of business do you work for? (check one of the following) 

Manufacturing Q Contractor Q Tribe Q Government (specify Federal, State, local) _______ 

Other __________ 

2. What are your job responsibilities? (check any that apply) 

Facility Operator Q Maintenance Q Facility Manager Q Environmental Staff Q 

Regulator Q Other: ____________ 

3. How did you hear about this implementation document? (check any that apply) 

Co-worker Q EPA TTN via dial up modem Q EPA TTN via the Web Q Other _____________ 

Please check the box under the number that most closely shows your agreement with the following statements 

1= Strongly Agree to 5 = Strongly Disagree 


 

1 2 3 4 5 


 


 


 

own. 
 


 


 

Statement N/A 

The document was timely. 

The document provides a good overview of the rule. 

The document provides the type of information my organization needs to comply. 

The document helped us achieve compliance more quickly than if we had developed our 

We have incorporated parts of this document into our own policy documents. 

The format of this document was well organized and easy to understand. 

4. What did you like about this document or what helped you the most? (be as specific as you can) _____________________ 

5. What did you not like about this document or what helped you the least? (be as specific as you can) __________________ 

6. What would you change about this document (e.g. formats; excluding information or including things that you did not 

see in the document)? _____________________________________________________________________________________ 

7. Overall, did you find this document to be: 

extremely useful Q very useful Q somewhat useful Q not useful at all Q 

8. Other comments: ______________________________________________________________________________________ 

Provide additional comment on the back of this form or on a separate sheet of paper. 

Return survey to: ATTN: Pesticide Active Ingredient Implementation Contact, U.S. Environmental Protection Agency (EPA), Mail 

Code 2223A, 1200 Pennsylvania Avenue, NW, Washington, DC 20460, or fax (202) 564-0050 

1-3
 
[This page intentionally left blank.] 
Chapter 2 - What this Pesticide Active Ingredient rule covers -

An Overview 

Why was this Pesticide Active Ingredient (PAI) rule written? 

The PAI rule was written to reduce hazardous air pollutant (HAP) emissions and achieve the 

environmental benefits intended by the Clean Air Act (CAA) of 1990. 

The rule applies to all organic HAP emissions from facilities subject to the rule. It also applies to 

chlorine and hydrogen chloride emissions, and it applies to particulate matter emissions from 

certain PAI product dryers and bag dumps. Our research indicates that the primary organic HAP 

emissions from PAI production include the following: 

C toluene
 
 

C methanol
 
 

C xylene
 
 

C methyl chloride
 
 

• methylene chloride 

• ethylene dichloride 

• carbon tetrachloride 

• acetonitrile 

How do I know if I am subject to this rule? 

You are subject to this rule if your facility meets all of the following: 

• is a major source of HAP emissions 

• manufactures at least one PAI 

• is not exempt 

Definition. Pesticide Active Ingredient means any material that is an active 

ingredient within the meaning of FIFRA section 2(a); is used to produce an 

insecticide, herbicide, or fungicide end use pesticide, consists of one or more organic 

compounds; and that must be labeled in accordance with 40 CFR part 156. 

2-1
 
Note: PAIs are typically described by North American Industrial Classification System (NAICS) codes 325199 

and 32532; these materials are identified by product classification codes 01, 21, 02, 04, 44, 07, 08, and 16 in 

block 19 on EPA form 3540-16, the Pesticides Report for Pesticide-Producing Establishments. 

You are not subject to this rule if you have a federally enforceable limit on your facility by the 

compliance date of Subpart MMM that restricts your 

emissions to <10 tons/yr of any single HAP and 

<25 tons/yr of all combined HAPs (i.e, in such cases, Your facility is a major source if it can 

your facility would not be classified as a major source potentially emit $10 tons/yr of a single 

under §63.2 of the General Provisions). HAP or $25 tons/yr of all HAPs. 

If your facility is major source, some PAI operations at your facility may still be exempt from the 

rule. These exemptions are listed at the end of this chapter. 

For a list of regulated HAPs, check our Air Toxics Website (ATW) at: 

http://www.epa.gov/ttn/atw/188polls.txt 

What is an affected source? 

Under Subpart MMM, an affected source includes all of the following [§63.1360(a)]: 

C	 	 the facility-wide collection of pesticide active ingredient manufacturing process units 

(PAI process units) that process, use, or produce HAP 

Definition. Process unit means the equipment assembled and connected by pipes or 

ducts to process raw materials and to manufacture an intended product. 

C	 	 waste management units, heat exchange systems, and cooling towers associated with the 

PAI process units described above 

An affected source includes all of the following types of emission points [§63.1360(a) and 

definition of “PAI process unit” in §63.1361]: 

• 	 	 process vents 

See Chapters 3 through 6 for details 

• 	 	 storage vessels 	 about your compliance options for 

• 	 	 wastewater systems 	 these emission points. 

• 	 	 equipment leaks 

2-2 
A new affected source includes either of the following [§63.1360(b)]: 

C	 an affected source, as described above, for which construction or reconstruction started 

after November 10, 1997, or 

C	 any dedicated PAI process unit that meets both of the following criteria: 

<	 construction commenced after November 10, 1997, or reconstruction commenced after 

September 20, 2002 

<	 has the potential to emit 10 tons/yr of any one HAP or 25 tons/yr of combined HAP 

Definition. Dedicated PAI process unit 

that is fixed in place and designed and operated to produce only a single product or coIf you... And... 	 

add a dedicated PAI you have an existing affected source, 

existing affected source and is subject to 

added process unit is less than 10 tons/yr existing source standards 

10, 1997 of individual HAP or 25 tons/yr of total 

process unit is added 

you have an existing affected source, the added dedicated PAI process unit is a 

and the PTE for the added process unit new affected source and subject to the new 

exceeds either HAP threshold (10 or 25 source standards (all other PAI process units 

that were part of the existing affected source 

process unit is added 

you have no existing affected source at regardless of the PTE, your added dedicated 

is added source that is subject to the new source 

standards 

add a PAI process unit you have an existing affected source 
 

that runs in 
 

nondedicated 
 


 

source 
 

the existing affected source and is subject to 

existing source standards regardless of 

whether you also have a dedicated PAI 

process unit that is a new affected source 

you have only a new affected source at 

the new affected source and is subject to new 

unit is added source standards 

you do not have an affected source at the you have constructed an affected source and 

the PAI process unit is subject to new source 

is added, and you had no nondedicated standards 

 means a PAI process unit constructed from equipment 

products. The equipment is not designed to be reconfigured to create different process units, 

and it is not operated with different raw materials so as to produce different products. 

Examples of changes to a facility and the type of standards that would apply are as follows: 

Then... 

your added process unit becomes part of the 

process unit at a major and the potential to emit (PTE) for the 

source after November 

HAP at the time the dedicated PAI 

tons/yr), at the time the dedicated PAI 

remain subject to existing source standards). 

the time the dedicated PAI process unit PAI process unit becomes a new affected 

equipment at a major 

your added PAI process unit becomes part of 

your added PAI process unit becomes part of 

the time the nondedicated PAI process 

time the nondedicated PAI process unit 

equipment on November 10, 1997 

2-3
 
 
If you... And... Then... 

add nondedicated 

source 

dedicated PAI process 

PAI process units at 

an existing affected 

source 

you do not have an affected source at the 

is added, but construction of the 

you already have an existing affected 

you already have an existing affected 

source 

definition of reconstruction 

throughout the entire affected source 

existing affected source and is subject to 

existing source standards 

all PAI process units at the affected source 

of the existing affected source and subject to 

the existing source standards 

new affected source that is subject to new 

source standards, and all other PAI process 

standards 

source, and all PAI process units are subject 

to new source standards 

December 23, 2003. This date 

The effective date is the 

If your affected source is new or reconstructed, except 

for a new affected source that consists of a Some additions to an existing source may be 

subject to existing source standards and 

others may be subject to new source 

standards. See “What is an affected 

source is a dedicated PAI process unit for which 

equipment to a major 

add equipment to a 

unit at a major source 

replace equipment in 

time the nondedicated PAI process unit 

nondedicated equipment began before 

November 10, 1997 

source with nondedicated equipment 

that you use to make PAI’s 

the amount of equipment replaced in a 

dedicated PAI process unit meets the 

the amount of equipment replaced 

meets the definition of reconstruction 

your added PAI process unit becomes an 

remain subject to existing source standards 

the dedicated PAI process unit remains part 

the dedicated PAI process unit becomes a 

units remain subject to existing source 

the affected source becomes a new affected 

When do I need to comply? 

If your facility is an existing affected source, you must comply by 

is 4.5 years after the rule’s effective date of June 23, 1999 [§63.1364(a)]. 

date the final rule was published in the Federal Register. The compliance date in the final rule 

was 6/23/02, but the compliance date was extended by 18 months in amendments published on 

6/3/02. An extension of up to 1 additional year may be requested if time is needed to install 

controls, and it must be submitted 120 days before compliance date. 

reconstructed dedicated PAI process unit, you must 

comply upon startup of your operations or on 6/23/99, 

whichever is later. [§63.1364(b)] If your affected source?” (page 2-2) for more information. 

reconstruction commenced after September 20, 2002 

you must comply upon startup. See Figures 2-1 and 2-2 for detailed compliance timelines. 

2-4
 
 
Existing Affected Sources 

Initial Startup before November 10, 1997 (Rule proposal date) 

Pesticide Active Ingredient (PAI) Rule 

Effective Date June 23, 1999 

* Results of performance tests must be included in the Notification of Compliance Status Report. Therefore, performance tests must be conducted prior to the 

submittal date of the Notification of Compliance Status Report, or within 150 days after startup of an existing affected source if the source begins operationafter the effective date of the rule. (§63.7(a)(2)(iii))

ial Noti 

( (b)) & 

( )(2)) 

li 

Si i 

Pl 

ication of 

(m)) 

i 

liance 

( 

( (f)) 

i i 

) 

l 

( 

i 

/99 

i 

/03 

60 days i 

(n) ... 

i 

( )) 

/ or 

li 

li 

i 

(a)(2)(i)) 

i l

 or 

i 

Init fication 

Report of 

Relevancy 

§63.1368 

§63.9(b 

Comp ance Date 

(§63.1364(a)(l)) 

te-Specif c Test 

an and 

Notif 

Planned 

Performance Test 

(§63.1368 

Initial Not fication 

of Comp 

Status NOCS) 

§63.1368 

Per od c Report 

(§63.1368(g) 

S

Sh

Ma func

§63

Subm t by 

10/23 

or w thin 120 

days after source 

becomes subject 

to rule. 

Must comply by 

12/23 

Submit 

before 

Performance Test* 

Subm t by 

5/21/04 

Submit by 1/17/05 

and every 6 

months thereafter. 

Submit 

and 

m

ther

If you are submitting a 

Then ... 

Precompl ance 

Plan 

§63.1368(e 

Submit by 

9/23 03 

3 months before 

comp ance date. 

Comp ance 

Extens on Request 

(§63.1364 

Subm t no ater than 8/25/03 

120 days before 

compl ance date. 

** Reports are only required if a startup, shutdown, or malfunction occurred during the reporting period. (§63.1368(i)) 

Figure 2-1. Compliance Timeline and Reporting Requirements for Existing Affected Source

2-5 
New and Reconstructed Affected Sources 

Initial Startup after November 10, 1997 (Rule proposal date) 

Pesticide Active Ingredient (PAI) Rule 

Effective Date June 23, 1999 

* Compliance date for a reconstructed dedicated PAI process unit is 9/20/02 or startup, whichever is later. 

** Performance tests shall be conducted within 150 days after the effective date, or within 150 days after startup of a new source that has an initial startup after

the effective date of the rule. (§63.7(a)(2)(i) and (ii))

*** Reports are only required if a startup, shutdown, or malfunction occurred during the reporting period. (§63.1368(i)) 

( 

( )) 

(1) 

i 

Plan 

( (e)) ( )) 

i 

Pl 

Pl 

(m)) 

) 

( 

i 

( (g)) ( 

j 

i 

l of 

Submit 

i 

l 

(n) ... 

Initial Notification 

Report of Relevancy 

§63.1368(b)), 

§63.9(b)(2 , and 

(§63.5(d) 

Precompl ance 

§63.1368 

Compliance Date 

§63.1364(b 

Site-Specif c Test 

an and 

Notification of 

anned 

Performance Test 

(§63.1368 

Initial Notification 

of Compliance 

Status (NOCS 

§63.1368(f)) 

Per odic Report 

§63.1368 

Startu

Shutdow

Malfunction 

§63.136

Submit by 

10/23/99 or within 

120 days after 

source becomes 

sub ect to rule. 

Submit w th the 

application for 

approva 

construction or reconstruction. 

Comply on 6/23/99 

or upon startup, 

whichever is later.* 

60 days 

before 

Performance 

Tests** 

Submit 150 days 

after effective date 

or init al startup. 

Submit 240 days 

after initia NOCS' 

due date and 

every 6 months 

thereafter. 

Submit 240 

after initial 

due date 

every 6 m

thereafte

If you are submitting a 

Then ... 

Figure 2-2. Compliance Timeline and Reporting Requirements for New and Reconstructed Sou

2-6 
What pesticide active ingredients are subject to the rule? 

Subpart MMM applies to only a fraction of all materials that are registered as active ingredients 

within the meaning of Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) section 2(a). 

The materials subject to this rule depend on how they are used. You are subject to 

Subpart MMM if your material: 

•	 meets all of the conditions in the definition of PAI in §63.1361 of Subpart MMM (see 

page 2-1 for the definition of PAI) 

Procedures to determine primary use 

• primarily used” as a PAI	 are described below. 

any 

of PAI in §63.1361] 

•	 

•	 it is used to produce active ingredients that are not identified by product classification 

rodenticides, and water purifiers) 

•	 Primary use 

is a PAI that is subject to this rule. 

•	 Primary product 

concept). 

Definition. Process unit group 

the procedures specified in §63.1360(g). 

is “ 

Your material is not subject to Subpart MMM if it meets of the following criteria: [definition 

it is an inorganic compound 

codes 01, 21, 02, 04, 44, 07, 08, or 16 in block 19 on EPA form 3540-16, the Pesticide 

Report for Pesticide-Producing Establishments (e.g., materials classified as disinfectants, 

How does “primary use” differ from “primary product”? 

The concepts of primary use and primary product serve the following purposes: 

 refers to the predominant end-use application of each material that may be 

used for both PAI and non-PAI purposes. Your primary use will determine if the material 

 refers to the predominant product produced in a process unit group 

(PUG), and is used to determine the applicable requirements for all PAI process units in 

the group. Process unit groups are part of an alternative means of compliance for sources 

with nondedicated equipment that is subject to multiple MACT rules (see “How is 

nondedicated equipment regulated” later in this chapter for a discussion of the PUG 

 means a group of process units that manufacture PAI’s 

and products other than PAI’s by alternating raw materials or operating conditions, or 

by reconfiguring process equipment. A process unit group is determined according to 

2-7
 
 
How do I determine the primary use of a product? 

Your product is “primarily used” as a PAI if more than 50 percent of the projected annual 

production of the product in the 3 years after June 23, 1999, or startup, whichever is later, will be 

used as a PAI [from the definition of “PAI process unit” in §63.1361]. 

If the initial primary use of your product is for non-PAI purposes, you must re-evaluate the 

primary use if there is reason to believe it has changed. 

If the primary use changes from non-PAI to PAI, then the process unit producing that material 

becomes a PAI process unit and is subject to 

Subpart MMM, unless it is already subject to 40 Recordkeeping of the PAI and non-PAI uses is CFR part 63, Subpart F (HON). If your process required if non-PAI uses are the primary use.

unit is subject to Subpart F, you must follow the 

Subpart F requirements, not those in 

Subpart MMM. 

What is a pesticide active ingredient (PAI) process unit? 

A PAI process unit produces either of the following [§63.1361]: 

• a PAI 

• an integral intermediate 

Note: Integral intermediate is defined on page 2-9. You may designate as a PAI process unit any process unit 

that produces an intermediate that is not an integral intermediate [§63.1360(g)] 

Typically, each integral intermediate process and the associated PAI process are separate PAI process units. 

However, if 100 percent of an integral intermediate is used in the production of a single PAI, you may consider 

the entire system to be one PAI process unit [from the definition of process in §63.1361]. 

A PAI process unit is not linked to any specific piece of equipment. Rather, it applies to 

whatever equipment is being used to produce a particular product. For example, if you have two 

distinct process “lines,” both producing the same product, they 

constitute one PAI process unit. Alternatively, you may have See “how is nondedicated 

“nondedicated” equipment that can be configured in different equipment regulated,” for more

ways to make different products as needed. In this case, each information. 

time you make a particular PAI, you may use a different 

reactor, centrifuge, or other equipment, but it is the same PAI 

process unit. Similarly, if the same equipment is used to produce different PAIs at different 

times, it constitutes a different PAI process while it is used to make each of the products. When 

you use the equipment (in the same configuration or a different one) to produce a non-PAI, the 

equipment does not constitute a PAI process unit. 

2-8
 
A PAI process unit can include any of the following [§63.1361]: 

•	 the PAI process (i.e., the processing equipment such as mixing vessels, reactors, and 

distillation units) 

•	 associated storage vessels, as determined under §63.1360(f) 

• connected piping and ducts
 
 

• open equipment used to convey and store liquids, as defined under §63.1362(k)
 
 

•	 associated components such as:
 
 

< pumps
 
 

< compressors
 
 

< agitators
 
 

< pressure relief devices
 
 

< sampling connection systems
 
 

< open-ended valves or lines (process fluid on only one side)
 
 

< valves with process fluid on both sides
 
 

< connectors
 
 

< instrumentation systems
 
 

What is an integral intermediate? 

An integral intermediate is an organic compound that meets all of the following criteria 

[§63.1361]: 

C it is further processed or modified in one or more additional steps to produce a PAI 

C 50 percent or more of the annual production is used in on-site production of one or more 

PAIs
 
 

C it is not stored before the next processing step (see next paragraph)
 
 

C it is not already subject to 40 CFR 63, Subpart F
 
 

2-9
 
 
An intermediate is stored if it is discharged to a storage vessel, and it meets any of the following 

conditions [§63.1361]: 

C	 	 you shutdown the processing equipment that discharges the intermediate to the storage 

vessel before you start up the processing equipment that withdraws the intermediate from 

the storage vessel 

C	 	 you store the intermediate in the vessel for at least 30 days before it is used to make a PAI 

C	 	 the equipment that produces the intermediate is located in a separate building (or 

processing area) than the equipment that uses the intermediate as a feedstock. The control 

equipment cannot be shared by the two processing areas 

How is “nondedicated” equipment regulated? 

The discussion under “What is a PAI process unit,” explained that a PAI process unit is defined 

based on the product being produced, regardless of the equipment. 

However, you may use the same equipment to produce different products (both PAIs and other 

types of compounds) at different times, or there may be overlap of at least some of the equipment 

used to make different products. For this document, this equipment is referred to as 

“nondedicated” equipment, and in some cases Subpart MMM allows you to comply with a 

different MACT rule when you use such equipment to produce a PAI. 

Typically, you must comply with the requirements of Subpart MMM for each PAI process unit. 

However, for PAI process units that are comprised of nondedicated equipment, you may 

determine applicability 

based on the following The purpose of this alternative for nondedicated equipment is to minimize the alternative procedure possibility for overlap between Subpart MMM and other MACT standards (e.g., 

[§63.1360(h)]: pharmaceuticals, polymers and resins, etc.) for equipment used in multiple process 

units. Examples of how to apply the PUG concept are illustrated for several case 

studies in EPA 305-B-04-001. 

Î	 	 First, categorize the nondedicated equipment into one or more process unit groups 

(see the definition of process unit group on page 2-7) 

Ï	 	 Then, determine the primary product for each process unit group (see note below) 

Ð	 	 Finally, for each PAI process unit within a process unit group, you may elect to 

comply with another applicable MACT rule as a means of demonstrating compliance 

with Subpart MMM, under either of the following conditions: 

<	 	if any product produced in the process unit 

group is subject to the pharmaceuticals Exceptions to the Subpart GGG provision 

MACT rule (Subpart GGG of 40 CFR are listed in §63.1360(h)(2). 

part 63), you may elect to comply with 

Subpart GGG [§63.1360(h)(2)] 

2-10
 
<	 	 if the primary product of a process unit group is a material that is subject to another 

MACT rule on June 23, 1999, or date of startup, whichever is later, you may elect to 

comply with that other subpart [§63.1360(h)(3)]. 

Note: Your primary product is the type of product (e.g., pharmaceutical products, PAI’s, etc.) you expect to 

produce for the greatest operating time in the 5-year period following the compliance date or the initial startup 

of the process unit group, whichever is later. Alternatively, if you expect the operating time to be the same for 

two or more process units, your primary product is the product that you expect to produce the greatest amount of 

on a mass basis [§63.1360(h)(1)(iv)]. 

This alternative does not address situations in which the primary product of a process unit group is PAI’s, and 

the other product(s) are not limited to pharmaceuticals. In these situations, you must consult the rule(s) that 

apply to any other products to determine the requirements that apply when you use the equipment to produce 

those products. For example, §63.2535(l)(3)(ii)(B) of the Miscellaneous Organic Chemical Manufacturing 

NESHAP (Subpart FFFF) allows compliance with Subpart MMM for miscellaneous organic chemical 

manufacturing processes within the process unit group if the primary product of the process unit group is 

determined to be pesticide active ingredients. 

How do I know if a storage vessel is part of a PAI process unit? 

In general, your storage vessel is considered part of the process unit that either supplies the 

greatest input to the storage vessel or uses the greatest output from the storage vessel. If this 

process unit is a PAI process unit, the storage vessel is subject to Subpart MMM [§63.1360(f)(2)]. 

Exceptions to this general rule are described in Chapter 4 for each of the following types of 

storage vessels: 

• 	 storage vessels in tank farms 

•	 storage vessels that have equal input to (and/or output 
 


from) two or more processes 
 


• 	 storage vessels for which the use varies or changes 

These procedures are 

essentially the same as those 

in the HON. 

• 	 storage vessels that are subject to other MACT standards on the effective date of Subpart 

MMM 

What requirements apply during periods of startup, shutdown, and 

malfunction? 

You must comply with the emission limits in Subpart MMM at all times, except during periods of 

startup, shutdown, and malfunction if all of the following apply [§63.1360(e)(1)]: 

•	 the startup, shutdown, or malfunction prevents you from complying with any emission 

limit, design, or work practice standard that otherwise applies 

2-11
 
•	 you follow the procedures in your startup, shutdown, and malfunction plan as specified in 

§63.1367(a)(3) 

•	 you implement, to the extent reasonably available, means to prevent or minimize 

emissions (e.g., identify control devices, work practices, pollution prevention measures, 

etc.) in your startup, shutdown, and malfunction plan [§63.1360(e)(4)] 

•	 you submit reports of periods of startup, shutdown, and malfunction as specified in 
 

§63.1368(i) 
 

You may not shut down equipment used to control emissions if the shutdown would cause 

emission limits to be exceeded, except in either of the following circumstances [§63.1360(e)(3)]: 

•	 the control equipment is malfunctioning 

•	 the control equipment would be damaged as a result of a malfunction in the PAI process 

unit. 

What provisions in this rule overlap provisions in other rules? 

Your options in the event that, for a given PAI process unit, the applicability of Subpart MMM 

overlaps with another regulation after the compliance date of Subpart MMM are as follows: 

[§63.1360(i)] 

If, for the following emission Subpart MMM overlaps with the
 
 

point... following rule... Then ...a
 
 

All emission points	 	 Other MACT rules in 40 CFR 
 • Choose, to the extent the subparts are 
 

part 63 (e.g., the HON, 
 consistent, under which subpart you will 
 

pharmaceuticals, etc.)b 
 maintain your records and reports 
 

• For 40 CFR 63, Subpart A (General 

Provisions) check Table 1 of Subpart 

MMM final rule to determine which 

Subpart A requirements apply to your 

emission point 

• Develop a process unit group as 

described in the section “How is 

nondedicated equipment regulated” on 

page 2-10 

I in 40 CFR part 63	 	 either the provisions of 
 

Subpart MMM or the provisions of 
 

Subpart H of 40 CFR part 63 
 

Storage vessels Subpart Kb of 40 CFR part 60 only with the provisions of 
 

(Group 1 and 2) [ Subpart MMM 
 

Equipment leaks Subpart Comply with 

Comply 

NSPS] 

2-12
 

If, for the following emission Subpart MMM overlaps with the 
 

point... following rule... Then ...a 
 

Process vents 	 Subparts III, NNN, or RRR of Comply only with Subpart MMM if the 

40 CFR part 60 [NSPS] 	 process vent subject to the other subpart is 

controlled to 98 percent. 

Otherwise, comply with both Subpart 

MMM and Subparts III, NNN and RRR as 

applicable. 

Subparts AA, BB, and CC of 
 either

40 CFR parts 264 and 265 
 

units [RCRA] 
 in Subpart MMM, or the other subparts. 

all excursions as 

required in §63.1368(g) of Subpart MMM 

40 CFR parts 260 through 272 

[RCRA] 

Process vents, equipment Comply with the monitoring, 

leaks, waste management recordkeeping, and reporting requirements 

However, you must report 

Wastewater streams Comply with whichever rule has the more 

stringent control, testing, monitoring, 

recordkeeping, and reporting requirements 

a Identify which subpart you have chosen to comply with in your Notification of Compliance Status Report as 

required under Subpart MMM. For wastewater streams, keep records of the information used to determine which 

requirements were the most stringent and submit the information to the Administrator if requested to do so. 

b An offsite reloading or cleaning facility that supports railcars or tank trucks that are used in your vapor balancing 

alternative for storage tanks need comply only with the provisions of the subpart of 40 CFR part 63 that applies to 

their facility. 

What is exempt from the rule? 

Section 63.1360(d) specifies that the rule does not apply to any of the following: 

•	 research and development facilities 

•	 PAI process units that are subject to 40 CFR 63, Subpart F 

•	 ethylene production 

•	 coal tar distillation 

•	 stormwater from segregated sewers 

•	 water from fire-fighting and deluge systems, including testing of such systems 

•	 spills 

•	 water from safety showers 

•	 noncontact steam boiler blowdown and condensate 

•	 laundry water 

•	 vessels storing materials that contain no organic HAP or contain organic HAP as
 
 

impurities only
 
 

2-13
 
•	 equipment (e.g., flanges, valves, pumps, etc.) intended to operate in organic HAP service 

for less than 300 hours during the calendar year. (However, you must keep a list of such 

equipment.) 

In addition, under §63.1361, the following are not considered to be part of the PAI process unit: 

•	 formulation of pesticide products (i.e., the mixing or blending of active ingredients with 

each other or inert ingredients) 

•	 QA/QC laboratories 

2-14 
Chapter 3 - Complying with requirements for process vents 

What is a process vent? 

A process vent is a point of emission from processing equipment to the atmosphere or a control 

device [§63.1361]. The vent may be the release point for either of the following: 

•	 an emission stream associated with an individual unit operation, or 

•	 emission streams from multiple unit operations that have been manifolded together into a 

common header. 

Examples of process vents include, but are not limited to, vents on the following: 

•	 condensers used for product recovery 

•	 bottom receivers 

•	 surge control vessels 

•	 reactors 

•	 filters 

•	 centrifuges 

•	 process tanks 

Vents on storage vessels, wastewater 

emission sources, and equipment leaks 

process vents are exempt?” on page 3-2 

for the minimum HAP concentration that 

an emission stream must have to be a 

process vent. 

are not process vents. See “What 

• dryers 

What process vents does Subpart MMM apply to? 

Subpart MMM applies to all process vents that: 

•	 are part of processes at an affected source 

•	 emit organic HAP and/or chlorine (Cl2) and hydrochloric acid (HCl) 

•	 are not exempt 

All process vents (new or existing) are called either “Group 1” process vents or “Group 2” 

process vents. 

Process vents are in Group 1 and are subject to controls if any of the following apply 

[§63.1362(b)(2)(i), (b)(3)(i), (b)(4)(i), (b)(5)(i)]: 

3-1
 
•	 the collective uncontrolled organic HAP emissions from all of the vents in the process are 

greater than 0.15 Mg/yr; or 

•	 the collective uncontrolled HCl/Cl2 emissions from all of the vents in the process are 

greater than 6.8 Mg/yr. 

Note: The uncontrolled HCl/Cl2 threshold includes HCl/Cl2 from the process itself as 

well as HCl/Cl2 created in combustion control devices that are used to control emissions 

of halogenated organic compounds. 

Process vents that do not meet the definition of Group 1 process vents are called Group 2 

process vents. Group 2 process vents do not require controls, but you must calculate the 

uncontrolled emissions for these processes and monitor either the number of batches per year 

(for batch operations) or the operating hours per year (for continuous operations) to demonstrate 

that annual emissions are below the limit for Group 2 processes. 

Note: Particulate matter emissions from process vents also require control if the vents are 

from product dryers that dry a PAI or integral intermediate that is also a HAP or a bag 

dump that is used to add a solid HAP material to the process (excluding HAP present only as 

impurities). 

What process vents are exempt? 

A vent is not a process vent if the undiluted 

and uncontrolled emission stream released
 

through the vent contains less than 50 ppmv 

HAP.
 

If your Group 1 process vents discharge to any of the following control devices, they are exempt
 

from the initial compliance demonstrations, monitoring provisions, and associated recordkeeping
 

and reporting requirements under Subpart MMM [§§63.1362(l), 63.1365(a)(4), and
 

63.1366(b)(1)(ix)(B)]. However, all other Subpart MMM provisions apply for these processes
 

(e.g., requirements to determine applicability and standards for storage tanks, wastewater, and
 

equipment leaks).
 

The definition of process vent in §63.1361 describes ways 

to determine the HAP concentration.
 

• 	 A boiler or process heater burning hazardous waste for which you have: 

<	 	 been issued a final permit for the boiler or process heater under 40 CFR part 270 and 

are complying with the requirements of Subpart H in 40 CFR part 266 

<	 	 certified compliance with the interim status requirements of Subpart H in 40 CFR part 

266. 

3-2
 
 
• 	 A hazardous waste incinerator for which you have: 

<	 	 been issued a final permit for the incinerator under 40 CFR part 270 and you are 

complying with the requirements of Subpart O in 40 CFR part 264 

<	 	 certified compliance with the interim status requirements of Subpart O in 40 CFR 

part 265. 

• 	 A boiler or process heater with a design heat input $44 MW 

•	 A boiler or process heater for which the emission stream is introduced with the primary 

fuel 

What compliance options do I have for my Group 1 process vents? 

Compliance options are categorized by organic HAP emissions and HCl/Cl2 emissions. The 

options are similar for existing and new sources. The main difference is higher percent 

reductions in organic HAP and HCl/Cl2 emissions are required for vents at a new source under 

the following conditions: 

•	 98 percent reduction instead of 90 percent reduction for all organic HAP emissions, not 

just those from “large” vents. 

•	 99 percent reduction instead of 94 percent reduction in HCl/Cl2 emissions if the
 
 

uncontrolled emissions are >191 Mg/yr.
 
 

Compliance options are explained in greater detail below. A summary is available in Table 3-1. 

Organic HAP emissions for “large” vents - Existing Sources 

Each process vent that meets both of the following conditions is subject to more stringent 

organic HAP controls than other vents: 

Procedures to calculate uncontrolled emissions 

•	 Uncontrolled organic HAP emissions are are specified in §63.1365(c)(2).
 
 

>22.68 Mg/yr
 
 

•	 “Low flow” emission stream [i.e., the flow-weighted average flow rate of the vent as 

calculated using equation 1 in §63.1362(b)(2)(ii) is less than or equal to the flow rate 

index calculated using equation 2 in §63.1362(b)(2)(ii)] 

For ease of discussion in this document, we refer to vents that meet these conditions as “large”
 
 

vents, although subpart MMM does not use this or
 
 

any other term to describe these vents. For these See Chapter 7 for example calculations used
 
 

large vents, you have the following five control to identify a large vent.
 
 

options for the organic HAP emissions:
 
 

3-3
 
 
TABLE 3-1. Compliance Options for Process Vents 

If you have And your process 

a(n)... 	 vents are... Then, for... Your compliance options are... a 

Existing 	 Group 1 for each “large” vent • 	 reduce organic HAP emissio ns by 

source 	 organic HAP $98 percent (Option 1) 

(>0.15 Mg/yr/ 

process) • 	 reduce organic HAP emissio ns to 

#20 ppmv (Option 2) 

• 	 use a flare that meets the 

requirements of §63.11(b) 

(Option 3) 

• 	 use the alternative standard (Option 

4) 

• 	 continue reducing HAP emi ssions 

by percentage achieved on or 

before 11/10/97, if that amo unt is 

$90 percent (Option 5) 

not controlled by Option 2, Option 3, 

or Option 4 

(Option 3) 

•	 

(Option 4) 

$98 percent (Option 1) 

any individual vent or any 

vents 

• 

#

• 

(Option 3) 

ns to 

vents, excluding large vents, not 

controlled by Option 2, Option 3, or 

Option 4 

• 

(Option 4) 

$90 p 

(Option 6) 

ercent 

Group 1 for 

HCl/Cl2 

(>6.8 Mg/yr/ 

process) 

any individual vent or any • #20 pp 

(Option 7) 

• 

(Option 8) 

not controlled by Option 7 or 

Option 8 

reduce HCl/Cl2 

$94 percent (Option 9) 

New source Group 1 for 

organic HAP 

(>0.15 Mg/yr/ 

process) 

any individual vent or any • 

#

• 

ns to 

the collective emissions from all vents 

requirements of §63.11(b) 

use the alternative standard 

reduce organic HAP emissions by 

combination of vents, excluding large 

reduce organic HAP emissio 

20 ppmv (Option 2) 

use a flare that meets the 

requirements of §63.11(b) 

the collective emissions from all 

use the alternative standard 

reduce HAP emissions by 

combination of vents 

reduce emissions to 

use the alternative standard 

mv 

the collective emissions from all vents emissions by 

combination of vents 

reduce organic HAP emissio 

20 ppmv (Option 2) 

use a flare that meets the 

3-4
 
 
TABLE 3-1. (cont’d) 

If you have And your process 

a a(n)... vents are... 

Group 1 for any individual vent or any • #

HCl/Cl2 (Option 7) 

(>6.8 Mg/yr/ 

process and 

#191 Mg/yr/ 

• 

(Option 8) 

process) reduce HCl/Cl2 

not controlled by Option 7 or $94 percent (Option 9) 

Option 8 

Then, for... Your compliance options are... 

reduce emissions to 20 ppmv 

combination of vents 

use the alternative standard 

the collective emissions from all vents emissions by 

Group 1 for any individual vent or any • #

HCl/Cl2 (Option 7) 

(>191 Mg/yr/ 

process) • 

(Option 8) 

reduce HCl/Cl2 $99 

not controlled by Option 7 or percent (Option 10) 

Option 8 

New or a source of 

existing #0.01 gr/dscf (Option 11) 

source that is also a HAP 

used to introduce a HAP solid to the #0.01 gr/dscf (Option 11) 

process, excluding HAP present only 

Group 2 for the process no control required, but recordkeeping 

organic HAP 

and/or HCl/Cl2 with the 0.15 Mg/yr threshold for 

6.8 Mg/yr threshold for HCl/Cl2 

reduce emissions to 20 ppmv 

combination or vents 

use the alternative standard 

the collective emissions from all vents emissions by 

the vent from each product dryer that reduce particulate matter emissions to 

particulate matter drys a PAI or integral intermediate 

emissions 

the vent from each bag dump that is reduce particulate matter emissions to 

as impurities 

is required to demonstrate compliance 

organic HAP emissions and the 

emissions 

a For each option, emissions must be routed from the process vent to the control device through a closed-vent 

system. 

3-5
 
 
Option 1: 98% reduction [§63.1362(b)(2)(ii)] 

Reduce total organic HAP emissions by at least 98 weight percent 

Option 2: reduce outlet concentration [§63.1362(b)(2)(iv)(A)] 

Reduce organic HAP emissions to an outlet concentration of #20 ppmv 

Option 3: use a flare [§63.1362(b)(2)(iv)(B)] 

Use a flare that meets the requirements of §63.11(b) (Subpart A General Provisions) to 

control total organic HAP emissions 

Option 4: use alternative standard [§63.1362(b)(6)] 

Reduce total organic HAP emissions to an outlet concentration of #20 ppmv as total organic 

compounds (TOC) if you use a combustion device, or to #50 ppmv as TOC if you use a 

noncombustion device 

Note: The outlet concentration when using a combustion device is the same as for Option 2, 

but the alternative standard requires monitoring with CEMS, whereas Option 2 requires an 

initial performance test (or design evaluation) and monitoring of control device operating 

parameters. 

Option 5: current % reduction [§63.1362(b)(2)(ii)(B)] 

Reduce uncontrolled total organic HAP emissions by at least 90 weight percent if the 

emissions were already reduced by at least 90 weight percent by a control device installed on 

or before November 10, 1997. 

Organic HAP emissions for “all” process vents - Existing Sources 

For all process vents within a process that do not fit the definition of a “large” vent, you have 

four compliance options available. For any individual vent or any combination of vents you 

may comply using Option 2, Option 3, or Option 4 as described above. For the collective 

emissions from all vents not controlled by one of these three options, you must use: 

Option 6: 90% reduction [§63.1362(b)(2)(ii)] 

Reduce uncontrolled organic HAP emissions by at least 90 weight percent 

HCl/Cl2 emissions - Existing Sources 

For uncontrolled HCl/Cl2 emissions, you have three compliance options available. You may 

control any individual process vent or any combination of process vents using: 

3-6
 
Option 7: reduce outlet concentration [§63.1362(b)(3)(ii)] 

Reduce uncontrolled HCl/Cl2 emissions to an outlet concentration of #20 ppmv 

Option 8: use alternative standard [§63.1362(b)(6)] 

Reduce uncontrolled HCl/Cl2 emissions to an outlet concentration of #20 ppmv if you use a 

combustion device to control halogenated organic HAP, or to #50 ppmv if you control 

HCl/Cl2 from the process using a noncombustion device. 

Note: The outlet concentration is the same as for Option 7 if you use a combustion device to 

control halogenated organic compounds, but the alternative standard requires monitoring 

with CEMS, whereas Option 7 requires an initial performance test (or design evaluation) and 

monitoring of control device operating parameters. 

You must control collective uncontrolled HCl/Cl2 emissions from all Group 1 process vents that 

are not controlled by Option 7 or Option 8 using: 

Option 9: 94% reduction [§63.1362(b)(3)(ii)] 

Reduce uncontrolled HCl/Cl2 emissions by at least 94 weight percent 

Organic HAP emissions - New Sources 

For the organic HAP emissions, you have four compliance options available. You may control 

organic HAP emissions from any individual vent or any combination of vents within a process 

using Option 2, Option 3, or Option 4 as described above. You must use Option 1 as 

described above to control the collective emissions from all Group 1 process vents that are not 

controlled using Option 2, Option 3, or Option 4. 

HCl/Cl2 emissions - New Sources 

Your compliance options for your new uncontrolled HCl/Cl2 sources depends on the amount of 

your uncontrolled emissions. The two categories are: (1) $6.8 Mg/yr but <191 Mg/yr and (2) 

$191 Mg/yr. Regardless of the uncontrolled emissions, two of your options are to control any 

individual process vent or any combination of process vents using Option 7 or Option 8 as 

described above. 

If the collective uncontrolled HCl/Cl2 emissions from all of the process vents within a process 

are $6.8 Mg/yr and <191 Mg/yr, your third compliance option is to control the collective 

uncontrolled HCl/Cl2 emissions from all Group 1 process vents that are not controlled by Option 

7 or Option 8 using: 

3-7
 
 
Option 9: 94% reduction [§63.1362(b)(5)(ii)] 

Reduce uncontrolled HCl/Cl2 emissions by at least 94 weight percent 

If, however, your uncontrolled HCl/Cl2 emissions from the sum of all process vents within a 

process are $191 Mg/yr, your third compliance option is to control the collective uncontrolled 

HCl/Cl2 emissions from all Group 1 process vents that are not controlled by Option 7 or Option 8 

using: 

Option 10: 99% reduction [§63.1362(b)(5)(iii)] 

Reduce uncontrolled HCl/Cl2 emissions by at least 99 weight percent 

What compliance options do I have for process vents that emit 

particulate matter? 

You have one compliance option for particulate matter emissions at both existing and new 

sources. The compliance option applies to two types of 

processing equipment: (1) product dryers that dry a 

product or integral intermediate that is also a HAP and (2) 

bag dumps that are used to add a solid material that is also a 

HAP to the process, excluding solid materials that contain 

HAP only as impurities. Your compliance option is: 

Particulate matter emissions from all 

other vents are exempt. 

Option 11: reduce outlet concentration [§63.1362(e)(1) and (2)] 

Reduce uncontrolled particulate matter emissions to outlet concentrations of #0.01 gr/dscf 

How do I show initial compliance with the process vent requirements? 

How you show initial compliance depends on which options you choose and which types of 

activities generate emissions from your processes. 

Typically, to demonstrate initial compliance, you will need to calculate the uncontrolled 

emissions from each activity in your process that generates emissions. The emissions for these 

activities are also called “emission episodes.” You will need the uncontrolled emissions to 

determine whether the process has Group 1 or Group 2 process vents. You also may need 

uncontrolled emissions to: 

•	 determine conditions under which the performance test or design evaluation must be 

performed 

•	 determine whether a control device is “large” or “small” 

•	 use in calculations of the percent reduction for a process 

3-8 
Compliance with Group 2 emission limits 

You demonstrate initial compliance with the Group 2 cutoffs for uncontrolled organic HAP and 

HCl/Cl2 mass emission limits by projecting the annual uncontrolled emissions for the process. 

You do this by performing all of the following: [§63.1365(c)(1)(i), (ii)] 

•	 calculating the uncontrolled emissions for each emission episode within the process 

•	 summing the emissions for all emission episodes from batch operations and multiplying 

by the estimated annual number of batches 

•	 summing the emissions for all emission episodes from continuous operations in the 

process and multiplying by the estimated operating time per year 

Note: One approach would be to estimate emissions from continuous operations on an 

hourly basis and then multiply by the number of operating hours per year. 

Equations for calculating uncontrolled emissions from the following activities are included in 

§63.1365(c)(2)(i)(B) of the rule: 

•	 filling Most of the calculations require you to estimate the HAP 

•	 purging partial pressure. Section 63.1365(c)(2)(i)(A) describes 

options for estimating partial pressure. Chapter 7 •	 heating provides example calculations and references to other 

•	 depressurization documents with additional examples. 

•	 vacuum systems 

•	 gas evolution 

•	 air drying 

If your emissions are due to activities other than 

listed above, you must conduct an engineering 

assessment to determine your emissions 

[§63.1365(c)(2)(ii)]. 

Information and procedures that may be 

used in an engineering assessment are 

described in §63.1365(c)(2)(ii). 

You may also request approval from the Administrator 

to determine emissions from any of the listed activities based on an engineering assessment. 

Compliance with percent reduction options (Option 1, 5, 6, 9, or 10) 

You demonstrate initial compliance with the percent reduction options by doing all of the 

following: 

•	 determine uncontrolled emissions for all emission episodes that are part of the analysis 

•	 determine controlled emissions for these emission episodes 

3-9
 
•	 sum the uncontrolled and controlled emissions and calculate the overall percent reduction 

[§63.1365(c)(1)(iii), (iv)] 

Note: If all process vent emissions from a process are controlled using a single control 

device that achieves at least 98% reductions, and a performance test is conducted over an 

entire batch cycle, then calculating the uncontrolled and controlled emissions for each 

emission episode is not necessary. §63.1365(b)(11)(iii)(D) 

If all process vents from a process are controlled using a single control device, then 

calculating controlled emissions for each emission episode is not necessary. 

You determine uncontrolled emissions as described above. The procedures to determine 

controlled emissions vary depending on whether you use a condenser, a “large” control device, 

or a “small” control device. 

Definition: Large control device means a device that controls 

process vents, and the combined inlet HAP emissions into the 

control device from all sources are $10 tons/yr. 

Definition: Small control device means a device that controls 

process vents, and the combined HAP emissions into the 

control device from all sources are <10 tons/yr. 

For condensers, you calculate controlled emissions for each emission episode by doing both of 

the following: [§63.1365(c)(3)(iii)] 

•	 determine the outlet gas temperature that, when used in the appropriate equation in 

§63.1365(c)(3)(iii), yields controlled emissions at the required percent reduction from 

uncontrolled levels 

•	 measure the outlet gas temperature from the condenser and show that it is less than or 

equal to the temperature used in the calculation 

For control devices other than a condenser, you calculate controlled emissions based on the 

following steps: 

•	 determine whether you have a large control device or a small control device based on the 

total annual inlet uncontrolled HAP emissions 

•	 for a large control device, calculate the control If a small control device becomes a large 

efficiency using a performance test control device, you must then recalculate 

[§63.1365(c)(3)(ii)] the control efficiencies using the results of 

a performance test. 

•	 for a small control device, calculate the control 

efficiency using either a performance test or a design evaluation [§63.1365(c)(3)(i)] 

•	 calculate controlled emissions using the uncontrolled emissions and the calculated
 
 

control efficiency
 
 

3-10
 
Note: Both design evaluations and performance tests must be conducted under the most 

challenging conditions for the device. The rule defines the most challenging conditions as 

either absolute or hypothetical peak-case conditions. The procedures for determining the 

absolute or hypothetical peak-case conditions are described in §63.1365(b)(ii). 

The parameters to consider in design evaluations for different types of control devices are 

described in §63.1365(a)(1). 

Compliance with outlet concentration options (Option 2 or 7) 

You demonstrate compliance with the 20 ppmv outlet concentration limit for organic HAP by 

measuring either total organic HAP or TOC [§63.1365(a)(6)]. 

You determine initial compliance with the 20 ppmv outlet concentration limits by testing using 

an applicable EPA method (e.g., M18 for total organic HAP, M25A for TOC, or M26 for HCl) 

under the most challenging conditions for the device [§63.1365(c)(1)(v)]. 

If you combine supplemental gases with the emission stream, you must correct the measured 

concentrations as follows: 

•	 To 3 percent oxygen, if you use a combustion control device [§63.1365(a)(7)(i)]. 

•	 By the ratio of the total flow to the flow without supplemental gases, if you use a
 

noncombustion control device [§63.1365(a)(7)(ii)] 
 

Definition: Supplemental gases means any nonaffected gaseous streams (streams that are not from 

process vents, storage vessels, equipment or waste management units) that contain less than 20 

ppmv TOC and less than 20 ppmv total HCl and chlorine, as determined through process 

knowledge, and are combined with an affected vent stream. Air required to operate combustion 

device burner(s) is not considered a supplemental gas. 

Compliance using a flare (Option 3) 

When you use a flare as your control device, demonstrate initial compliance by doing all of the 

following: 

•	 determine visible emissions using Method 22 of 40 CFR part 60, Appendix A, as 

described in §63.11(b)(4) of the General Provisions (i.e., the flare must produce no 

visible emissions, except for a period not to exceed 5 minutes in a 2-hour observation 

period). 

•	 determine under absolute or hypothetical peak-case conditions, the net heating value of 

gas being combusted and its exit velocity as specified in §63.11(b)(6) through (8) of the 

General Provisions [§63.1365(a)(3), (c)(1)(vii)] 

3-11
 
Compliance with the alternative standard (Option 4 or 8) 

You demonstrate initial compliance with the alternative standard by having the monitoring 

equipment installed and operational on the compliance date (see “How do I monitor to comply 

with the alternative standard” later in this chapter). 

In addition, if you intend to calibrate the monitor using the predominant HAP, you will have to 

use Method 18 to determine the predominant HAP [§63.1365(a)(5), (c)(1)(vi)]. 

Compliance with particulate matter concentration limits (Option 11) 

For bag dumps and product dryers, you demonstrate initial compliance with the outlet 

concentration limit of 0.01 gr/dscf by conducting a performance test using Method 5 of appendix 

A of 40 CFR part 60. [§63.1365(b)(7)] 

What monitoring must I do for my process vents? 

To demonstrate ongoing compliance with the option you selected, you must monitor one or more 

parameters, and you must inspect closed-vent systems for leaks. Typically, your monitoring 

requirements consist of all of the following: 

• Identifying the parameter(s) to monitor 

• Setting site-specific limits for the parameter(s) 

• Averaging the measured values for comparison with the limits 

Each of these steps is discussed in more detail below. 

What parameters must I monitor? 

The specific parameters that you must monitor, and the required frequency of monitoring, will 

depend on the type of control device that you use and if the total inlet HAP emissions going into 

your control device is <0.91 Mg/yr or $0.91 Mg/yr. 

If the total inlet HAP emissions to your control device are <0.91 Mg/yr, you are required to 

conduct a periodic verification that the device is operating properly. 

To provide the verification you must demonstrate on a daily, or more frequent, basis that the 

control device is working as designed. 

One example of an acceptable periodic You describe the verification procedure you intend

verification demonstration is to conduct a daily to use in your Precompliance Plan. 

3-12
 

measurement of the same parameter(s) that must be monitored for larger control devices, as 

described below [§63.1366(b)(1)(i)]. 

Note: The periodic verification does not apply for the alternative standard (Option 4 or 8); 

you must always continuously monitor the outlet concentration(s) using a CEMS. 

If the total inlet HAP emissions to your control device are $0.91 Mg/yr, you must monitor either 

the outlet emission concentration or various operating parameters as described in 

§63.1366(b)(1)(ii) through (xi). These monitoring requirements are summarized in Table 3-2. 

Note: Each monitoring device must be calibrated annually, and the required accuracy of 

each device is specified in §63.1366(b)(1) of the rule. 

3-13
 

TABLE 3-2. Monitoring Requirements for Air Pollution Control Devices 

If you are complying with And the total inlet the following HAP emissions to And you are using compliance options... 

your control device are... 

the following control device... 

Then you must monitor this parameter...a At this frequency... 

A

Options 1, 2, 5-7, <0.91 Mg/yr any control device parameter(s) specified in your at least once per day 9, 10, and 11 approved precompliance plan that 

demonstrate the control device is 

operating as designed 

Options 1, 2, 5-7, $0.91 Mg/yr liquid flow rate into scrubber or 

9, 10, and 11 pressure drop across the scrubber (e.g., any % reduction or outlet concentration option, except the alternative standardb, Option acid gases 

once per day 

4 or 8) 

Condenser Regenerative • • each regeneration cycle 

carbon adsorber since the end of the last 

regeneration), and 

• • each regeneration cycle 

is heated during regeneration, and 

• • 

is cooled, and 

phase of each regeneration cycle 

• • each regeneration cycle • • once per year 

specifications 

3-14
 
 

Scrubber every 15 minutes 

also monitor the pH if the scrubber uses a caustic solution to remove 

condenser outlet gas temperature every 15 minutes 

regeneration frequency (time 

temperature to which the bed 

temperature to which the bed within 15 minutes of 

completing the cooling 

regeneration stream flow, and 

check for bed poisoning 

following manufacturer’s 
TABLE 3-2. (cont’d) 

If you are complying with And the total inlet the following HAP emissions to And you are using compliance options... 

your control device are... 

the following control device... 

Then you must monitor this parameter...a At this frequency... 

A

Nonregenerative < operating time since last • n/a 

carbon adsorber replacement, or 

• monitor TOC concentration in • daily, or at an interval no 

exhaust vent stream for greater than 20 percent of 

breakthrough the time needed to 

consume the total 

working capacity of the carbon under peak-case conditions 

3-15
 
 

incinerator 

Catalytic 

incinerator catalyst bed 

Process heater 

and boiler (except those covered by Option 4) 

Fabric filter continuously 

that provides an output of relative 

any other device part of the request for 

request approval to use approval 

Option 3 $0.91 Mg/yr 

(e.g., using a flare) 

Thermal temperature of gases exiting the every 15 minutes 

combustion chamber temperature difference across the every 15 minutes temperature of gases exiting the every 15 minutes 

combustion chamber 

use a bag leak detection system 

particulate matter emissions 

identify applicable parameters and 

Flare presence of pilot flame every 15 minutes 
TABLE 3-2. (cont’d) 

If you are complying with And the total inlet the following HAP emissions to And you are using 

compliance your control the following Then you must monitor this A

options... device are... control device... parameter...a At this frequency... 

Option 4 or 8 All Any control outlet TOC concentration and/or every 15 minutes 

(e.g., alternative device outlet HCl/Cl2 concentration using 

standard) CEMS meeting PS 8 or 9 of 

Appendix B of Part 60 

a Note that for all control devices, a closed vent system that contains a bypass line that could divert a vent stream away from the cont

monitored for flow in the bypass line every 15 minutes, or the bypass line valve must be secured in the closed position with a car se

configuration, and the seal or closure mechanism must be visually inspected once per month [§63.1366(b)(1)(xiii) and 63.1362(j)]. 

b As an alternative to the specified operating parameters for control devices used to comply with any of the percent reduction or outle

for organic HAP emissions and HCl/Cl2 emissions you may use a continuous emissions monitoring system (CEMS) meeting the req

Performance Specifications (PS) 8 or 9 of Appendix B of Part 60 to monitor TOC and/or HCl/Cl2 every 15 minutes [§63.1366(b)(1)

3-16
 
 
How do I set monitoring parameter limits? 

You establish the limit against which your monitored values for a control device operating 

parameter is compared during the initial compliance 

demonstration [§63.1366(b)(3)(i) and (ii)]. This limit 

will be associated with the most challenging conditions The monitoring parameter limits and your 

for the control device, and is used to demonstrate rationale for these limits are subject to 

review and approval by the Administrator. ongoing compliance. 

If you demonstrate initial compliance by conducting a 

performance test, you establish minimum or maximum monitoring limits based on the average of 

the average values from each of the three test runs [§63.1366(b)(3)(ii)(A)]. 

In addition to setting monitoring limits for the most challenging conditions, you also may set 

additional monitoring limits for less challenging conditions. 

For example, if you use a scrubber to control several process vents within a batch process, you 

must set at least one scrubber liquid flow rate limit, and this limit must be associated with the 

most challenging operating conditions under 

which the initial compliance determination is You must record in a daily schedule or log the conducted. Maintaining the monitored scrubber points at which the parameter limit changes, and flow above this limit at all times demonstrates at least one reading must be taken after each

that the required percent reduction is being met. change, even if the duration associated with that 

However, if the HAP emitted from one vent is limit is less than 15 minutes. 

more soluble than the HAP emitted from other 

vents (i.e., it is a period that does not constitute 

the most challenging conditions for the control device), you may decide to set a lower flow rate 

limit for the time that vent is being controlled. But you must demonstrate that the required level 

would still achieve the required control level. 

To establish monitoring levels for the less challenging conditions, you may supplement the 

performance test results with an engineering 

assessment and/or manufacturers The Precompliance Plan must be submitted for recommendations. Your rationale for the approval at least 6 months before the Compliance

specific level(s) must be provided in your date. See Chapter 8. 

Precompliance Plan. 

Note: Limits are not applicable for flares (option 3) because the monitored parameter, the 

presence or absence of a pilot flame, can not vary over a range. 

Monitoring limits for the alternative standard and for product dryers and bag dumps are 

defined in the standards themselves, and you may not set multiple limits when complying with 

these standards. 

3-17
 
How do I monitor to comply with the alternative standard? 

If you choose to comply with the alternative standard, your monitoring requirements include all 

of the following: [§63.1366(b)(5)] 

•	 use CEMS to monitor outlet TOC and total HCl/Cl2 concentrations at least once every 15 

minutes 

•	 typically, adjust the measured concentrations to account for supplemental gases that are 

added to the emission stream. For combustion devices, you may monitor residence time 

and firebox temperature as an alternative to adjusting the concentration 

•	 use a TOC monitor that meets the requirements of Performance Specification 8 or 9 of 

appendix B of 40 CFR part 60 

•	 install, calibrate, maintain, and operate the monitors in accordance with §63.8 of subpart 

A of 40 CFR part 63 

Note: You do not have to monitor the total HCl/Cl2 concentration if you know that the process 

(or control device) does not generate HCl/Cl2. 

Procedures for adjusting the outlet concentration to account for supplemental gases are 

specified in §63.1365(a)(7), and alternatives to correcting for supplemental gases are 

specified in §63.1366(b)(5)(ii)(A) and (B). 

How may I average my monitoring parameter values? 

Typically, monitored parameter values must be averaged over either a day or a block. A daily 

average is any continuous 24-hour period of your choice - it does not have to be from midnight 

to midnight. 

A block average is only for vents from batch operations, and it is limited to the period of time 

that is, at a maximum, equal to the time from the beginning to the end of a series of consecutive 

batch operations [§63.1366(b)(2)(i) and (ii)]. 

Monitoring values taken during periods of no flow or when venting streams that are not subject 

to the rule should not be considered in either the daily or block averages. To identify periods of 

no flow you must use a flow indicator at the inlet (or outlet) of the control device 

[§63.1366(b)(2)(iii)]. 

Note: Averaging is not applicable for carbon adsorbers (except under option 4, the 

alternative standard), for flares (option 3), and for fabric filters (option 11). 

You must use daily averaging when complying with the alternative standard (option 4 or 8). 

3-18
 
 
How do I inspect my closed-vent systems? 

You must inspect closed-vent systems for leaks initially (by the compliance date) and annually. 

If your closed-vent system is constructed of 

ductwork, you must perform sensory inspections Calibration procedures and other requirements (i.e., use sight, sound, and smell to find for Method 21 inspections are specified in

indications of leaks) and perform inspections §63.1366(h)(3)(iii) through (vi). A leak is defined 

using Method 21 of appendix A in 40 CFR part as a reading more than 500 ppm above 

background levels. 60. If your closed-vent system is constructed of 

hard-piping, only sensory inspections are 

required. [§63.1366(h)(2)(i) and (ii)] 

If necessary, you may designate parts of the closed-vent system as unsafe-to-inspect or difficultto-inspect. These parts of the closed-vent 

system do not have to be inspected on the Conditions that make parts of a closed-vent system schedule described above. However, you must unsafe-to-inspect or difficult-to-inspect are

inspect the unsafe-to-inspect equipment when it specified in §63.1366(h)(6) and (7). 

is safe to do so (but not more frequently than 

annually), and you must inspect the difficult-toinspect equipment at least once every 5 years. You must also have a written plan that states 

when you will perform these inspections. 

Any leaks that you detect while conducting an inspection must be repaired within 15 calendar 

days from the date that you detected the leak, 

and you must make a first attempt at repair 

within 5 calendar days after the leak is detected. You may delay repair if the repair is technically 

After making a repair, you must reinspect the 

equipment using Method 21 to verify that the 

infeasible without a shutdown or if the emissions 

from immediate repair are likely to be greater 

than the emissions from the unrepaired 

equipment.. repair was successful or to determine that the 

equipment is nonrepairable. [§§63.1366(h)(4) 

and 63.1367(f)(4)(iii)] 

Note: You do not have to inspect a closed-vent system that operates under negative pressure. 

What records must I keep for my process vents? 

For all compliance options, you must keep records of each measurement of a continuously 

monitored operating parameter or CEMS reading that demonstrates continuous compliance. 

[§63.1367(b)(1)] See Table 3-2 for a listing of the monitoring requirements. Recordkeeping 

requirements that relate to demonstrating compliance with the process vent standards are 

presented in Chapter 8. 

3-19
 
 
What reports must I submit for my process vents? 

Reporting requirements are presented in Chapter 8. 

3-20
 
Checklists for Process Vent Inspections 

Facility Name: ______________________________________________________ 

Facility Location: ______________________________________________________ 

Facility TRI ID #: ______________________________________________________ 

Inspector: ______________________________________________________ 

Date: ______________________________________________________ 

The table below explains which inspection checklists you should use for determining compliance 

with the process vent requirements. 

And the total inlet HAP And the process vent emission Then use the 

If you 

follow... 

emissions to the control 

device are ... 

streams are conveyed by a closedvent system to ... 

following 

checklistsa: 

Starting on 

page ... 

any option, $ 0.91 Mg/yr 3 3-28 

except 3, 4, 

and 8 a condenser 4 

a regenerative carbon adsorber 5 

a nonregenerative carbon adsorber 6 

7 3-35 

a catalytic incinerator 8 3-37 

a boiler or process heater with a 9 

design heat input of < 44 

a fabric filter 10 3-41 

3 $ 0.91 Mg/yr 11 3-43 

4 or 8 any control device 12 3-45 

any option, < 0.91 Mg/yr 13 3-47 

except 4 and 

8 

a scrubber 

3-30 

3-32 

3-34 

a thermal incinerator 

3-39 

megawatts and for which the 

emission stream is not introduced 

with the primary fuel 

a flare 

all 

any control device 

a Checklists 1 and 2 apply for all options. 

3-21
 
 
Checklist 1: Applicability (All Options)a 

Facility Name: 
 ___________________________________________________________ 
 

Facility Location:
 ___________________________________________________________ 
 

Facility TRI ID #:
 ___________________________________________________________ 
 

Inspector:
 ___________________________________________________________ 
 

Date:
 ___________________________________________________________ 
 

Note: Answer questions 1 through 3 for organic HAP and HCl/Cl2 emissions, and answer question 4 for product 

dryers and bag dumps. §63.1362(b)(2)(i), (3 i), (4 i), (5 i), (e) and (l , §63.1365(a)(4), §63.1366(b)(1)(ix)(B) )( )( )( )

Comments 

1.	 	 Is the total organic HAP and HCl/Cl2 content of your emission G Yes G No 

stream <20 ppmv? 

Note: If you answer “yes” to this question for all emission
 

streams from process vents in a process, do not continue; your
 

process is not subject to control requirements for organic HAP
 

or HCl/Cl2. If you answer “no” for any emission streams from
 

process vents within a process, proceed to question 2.
 

2.	 G Yes G No 

process vents in the process # 0.15 Mg/yr, and are the total 

uncontrolled HCl/Cl2 

process # 6.8 Mg/yr? 

Note: If you answer “yes” to this question, do not continue;
 

your process is not subject to control requirements for process
 


 

3.	 Does your process vent discharge to any of the following 

control devices: 

•	 
 

which you have:
 

<	 G Yes G No 

subpart H; or 

<	 G Yes G No 

•	 

<	 G Yes G No 

part 264, subpart O; or 

<	 G Yes G No 

•	 G Yes G No 

$

•	 G Yes G No 

Are the total uncontrolled organic HAP emissions from all 

 emissions from all process vents in the 

vents. If you answer “no”, proceed to question 3. 

a boiler or process heater burning hazardous waste for 

been issued a final permit under 40 CFR part 270 and 

are complying with requirements of 40 CFR part 266, 

certified compliance with the interim status 

requirements of 40 CFR part 266, subpart H? 

a hazardous waste incinerator for which you have: 

have been issued a final permit under 40 CFR part 270 

and are complying with the requirements of 40 CFR 

have certified compliance with the interim status 

requirements of 40 CFR part 265, subpart O? 

a boiler or process heater with a design heat input 

44 megawatts? 

a boiler or process heater for which the emission stream is 

introduced with the primary fuel? 

3-22
 
Checklist 1: (cont’d) 

Applicability (All Options) 

Comments 

Note: If you answer “yes” to using any of the control devices
 

listed in this question, do not continue; you are exempt from
 

the monitoring and associated recordkeeping and reporting
 

requirements. If you answered “no” to all of the questions,
 

your control device is subject to monitoring and
 

recordkeeping; proceed to checklist 2 for closed-vent systems
 

and to the appropriate checklist for your control device.
 

4.	 G Yes G No 
 


 


 

Note: If you answer “no” to this question, your product dryer
 


 

this question, your product dryer or bag dump is subject to
 

control; proceed to checklist 10.
 

Does the emission stream contain particulate matter from either 

a bag dump that is used to add a HAP raw material or a product 

dryer that drys a HAP product or integral intermediate? 

or bag dump is not subject to control. If you answer “yes” to 

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and Table 3-1. 

3-23
 
 
Checklist 2: Requirements for closed-vent systems (All Options)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements Comments 

Note: Questions 2 through 4 do not apply for a closed-vent system that operates under negative pressure. 

1.	 	 If your closed-vent system has bypass lines that could divert a vent 

stream away from the control device and to the atmosphere, have 

you done one of the following: 

•	 used a flow indicator that takes a reading at least once every 15 G Yes G No 

minutes at the entrance of the bypass line? §63.1362(j) (1) 

•	 performed a monthly visual inspection that the bypass line G Yes G No 

valve is secured in the closed position with a car-seal or a 

lock-and-key type configuration? §63.1362(j) (2) 

Note: Low leg drains, high point bleeds, analyzer vents, open-ended 

valves or lines, rupture disks, and pressure relief valves needed for 

safety purposes are not subject to the monitoring requirements for 

bypass lines. §63.1362(j) 

2.	 	 If your closed-vent system is constructed of ductwork, do you G Yes G No 

conduct annual inspections for leaks using Method 21 in appendix 

A of 40 CFR part 60 and annual sensory inspections (based on 

sight, sound, and smell) for indications of leaks? 

§63.1366(h)(2)(ii)(B) and (C ) 

Note: When using Method 21, a leak is detected if the maximum 
 


reading is at least 500 ppm greater than the background level.
 


Section 63.1366(h) (3)(ii) describes detection instrument 

performance criteria such as response factors, calibration 

procedures, and how to account for background levels. 

3.	 	 If your closed-vent system is constructed of hard-piping, do you G Yes G No 

conduct annual sensory inspections for indications of leaks? 

§63.1366(h) (2)(i)(B) 

4.	 	 After repairing a leak, do you use Method 21 to confirm that the G Yes G No 

leak is successfully repaired or that it is nonrepairable? 

§63.1367(f) (4)(iii) 

3-24 
 
Checklist 2: (cont’d)
 
 

Requirements for closed-vent systems (All Options)
 
 

B. Recordkeeping and Reporting Requirements Comments

Note: Questions 3 through 8 do not apply for a closed-vent system that operates under negative pressure. 

§§63.1366(h) 9) and (10) (

1.	 	 If you use a flow indicator to monitor your closed-vent system 
 

bypass line, do you have all of the following records: 
 

§63.1367(f)(3)(i) 

• 	 hourly flow indicator readings? G Yes G No 

•	 times and durations of periods when the flow indicator is not G Yes G No 
 

operating? 
 

•	 times and durations of periods when the vent stream is diverted G Yes G No 
 

from the control device? 
 

2.	 	 
 

through a bypass line, do you have all of the following 
 

records: (3)(ii) 
 

•	 G Yes G No 
 


 

•	 G Yes G No 
 

bypass line valve position has changed, or the key for a lock-and-
 

key type lock has been checked out? 
 

•	 	 G Yes G No 

3.	 	 G Yes G No 
 

designated as unsafe-to-inspect or difficult-to-inspect, and do the 
 

(1) 
 


 

4.	 	 Do you have a written plan for inspecting the unsafe-to-inspect parts of G Yes G No 
 


 

once per year)? (6)( (1) 
 

5.	 	 Do you have a written plan for inspecting the difficult-to-inspect parts G Yes G No 
 


 

(7)( (2) 

6.	 	 
 

leaks as follows: (2)(i)(B), (ii)(B) (C) 
 

•	 G Yes G No 
 


 

hard-piping? 
 

If you use a seal mechanism to prevent diversion of emission streams 

§63.1367(f)

records that the monthly visual inspections of the seal or closure 

mechanism have been done? 

records of all periods when the seal mechanism is broken, the 

records of any car-seal that has broken? 

Do your records identify all parts of the closed-vent system that you 

records explain why you assigned the designation?: §63.1367(f)

and (2) 

the closed-vent system as frequently as practicable (but not more than 

§§63.1366(h) ii) and 63.1367(f)

of the closed-vent system at least once every 5 years? 

§§63.1366(h) ii) and 63.1367(f)

Do your records indicate that the closed-vent system is inspected for 

§§63.1366(h) , and (ii)

an annual sensory inspection (i.e., visual, audible, or olfactory) for 

indications of leaks if the closed-vent system is constructed of 

3-25
 
 
Checklist 2: (cont’d)
 
 

Requirements for closed-vent systems (All Options)
 
 

B. Recordkeeping and Reporting Requirements Comments

•	 both an annual sensory inspection and an instrument inspection G Yes G No 
 

using Method 21 in appendix A of 40 CFR part 60 if the closed-
 

vent system is constructed of ductwork? 
 

Note: When using Method 21, a leak is detected if the maximum
 

reading is at least 500 ppm greater than the background level.
 

Section 63.1366(h)(3)(ii) describes detection instrument performance
 

criteria such as response factors, calibration procedures, and how to
 

account for background levels.
 

7.	 For each inspection (sensory or Method 21) during which no leaks 

were detected, do you have records of the following: (5) 

•	 G Yes G No 

•	 G Yes G No 

8.	 For each inspection (sensory or Method 21) during which a leak is 
 

detected, do you have the following records: (4) 
 

•	 G Yes G No 

•	 G Yes G No 
 


 

was detected by sensory observation? 
 

•	 G Yes G No 

•	 G Yes G No 


 

(4)(i)
 

•	 G Yes G No 
 


 

•	 
 

the leak was discovered: 
 

< reason for the delay in repair? G Yes G No 
 

< G Yes G No 
 

< expected date of successful repair? G Yes G No 

repair is technically infeasible without a shutdown, or if the 

emissions from immediate repair would be greater than the 

fugitive emissions likely from delay. 

§63.1367(f) 

and (6) 

date of the inspection? 

statement that no leaks were detected? 

§63.1367(f) 

identification of the leaking equipment? 

instrument identification number and operator name or initials (if 

the leak was detected using Method 21), or a record that the leak 

the date the leak was detected? 

the date of the first attempt to repair the leak? 

Note: the first attempt to repair the leak must be no later than 5 

calendar days after the leak is detected. §63.1366(h) 

maximum instrument reading measured by Method 21 after the 

leak is repaired or determined to be nonrepairable? 

all of the following if the leak is not repaired within 15 days after 

name, initials, or other form of identification of the person who 

decided repairs cannot be made without a shutdown? 

Note: delay of repair until the next shutdown is allowed if the 

3-26 
 
Checklist 2: (cont’d)
 
 

Requirements for closed-vent systems (All Options)
 
 

B. Recordkeeping and Reporting Requirements Comments

•	 dates of shutdowns that occur while the equipment is unrepaired? G Yes G No 

•	 date of successful repair of the leak? G Yes G No 

9. Are records retained for at least 5 years? (1) G Yes G No 
 

10.	 all of the following in your Periodic Report: 
 

(2)( 

•	 G Yes G No 
 

control device? 
 

•	 G Yes G No 
 

bypass valve position has changed, or the key to unlock the 
 

bypass line valve was checked out? 
 

•	 G Yes G No 

§63.1367(a) 

Did you submit 

§63.1368(g) iii) and (xi) 

records of all periods when the vent stream is diverted from the 

records of all periods when the seal mechanism is broken, the 

records of inspections during which a leak is detected? 

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-27
 
 
Checklist 3: Requirements for scrubbers (All options except 3, 4, 8, and 11)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirment, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements §63.1366(b) ii) and (2 (1)( ) Comments

1.	 	 Do you monitor scrubber liquid flow rate or pressure drop at least G Yes G No 

once every 15 minutes during the period in which the scrubber is 

controlling HAP from an emission stream? 

2.	 G Yes G No 

3.	 G Yes G No 

percent of the design scrubber liquid flow rate? 

4.	 G Yes G No 

5.	 G Yes G No 

6.	 Do you average the continuous readings over the operating day or G Yes G No 

operating block? 

7.	 G Yes G No 

indicator at the inlet or outlet of the scrubber and do you use it to 

identify periods of no flow? 

B. Comments 

1.	 all of the following in your Notification of 

•	 G Yes G No 

(2) 

•	 G Yes G No 

(3) 

2.	 G Yes G No 

scrubber effluent if you use a caustic solution? (1) 

3.	 Do you keep continuous records of the scrubber inlet flow rate or G Yes G No 

pressure drop? (1) 

Is the monitoring device used to determine the pressure drop certified 

by the manufacturer to be accurate to within a gauge pressure of ± 10 

percent of the maximum pressure drop measured? 

Is the monitoring device used for measurement of scrubber liquid 

flow rate certified by the manufacturer to be accurate to within ± 10 

Is the monitoring device calibrated annually? 

Do you monitor the pH of the effluent scrubber liquid at least once a 

day if the scrubber uses a caustic solution to remove acid emissions? 

If flow to the scrubber can be intermittent, did you install a flow 

 Recordkeeping and Reporting Requirements 

 Did you submit 

 Compliance Status Report: 

results of the initial performance test or design evaluation? 

§63.1368(f) 

documentation to establish a minimum scrubber liquid flow rate 

or pressure drop as a site-specific operating parameter? 

§63.1368(f) 

Do you keep daily (or more frequent) records of the pH of the 

§63.1367(b) 

§63.1367(b) 

3-28
 
 
Checklist 3: (cont’d)
 
 

Requirements for scrubbers (All options except 3, 4, 8, and 11)
 
 

B. Recordkeeping and Reporting Requirements Comments

4.	 	 Do you submit all of the following in your Periodic Reports if 
 

exceedances or excursions are $1 percent of the total operating time 
 

during the reporting period: 
 

§63.1368(g)(2) 

•	 all monitoring data for all operating days or blocks when the G Yes G No 
 

average scrubber inlet flow rate or pressure drop is lower than 
 

the minimum established in your NOCSR or operating permit? 
 

•	 all monitoring data for all operating days or blocks when the G Yes G No 
 

average pH value of the scrubber effluent is lower than the 
 

minimum established in your NOCSR or operating permit? 
 

•	 identification of all operating days when insufficient monitoring G Yes G No 
 

data are collected? 
 

•	 operating logs and operating scenarios for all operating days or G Yes G No 
 

blocks when the scrubber inlet flow rate, inlet pressure drop, or 
 

effluent pH is lower than the minimum established in your 
 

NOCSR or operating permit? 
 

•	 records of the information for CMS required by §63.10(c)(5) G Yes G No 
 

through (13) in subpart A to 40 CFR part 63 (General 
 

Provisions) 
 

5.	 Do you maintain records for 5 years? §63.1367(a) (1) G Yes G No

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-29
 
 
Checklist 4: Requirements for condensers (All options except 3, 4, 8, and 11)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A Monitoring Requirements §63.1366(b) iii) and (2 (1)( ) Comments

1.	 	 Do you measure the condenser outlet gas temperature at least once G Yes G No 

every 15 minutes during the period in which the condenser is 

controlling HAP from an emission stream? 

2.	 ± 2 percent G Yes G No 

whichever is greater? 

3.	 G Yes G No 

4.	 G Yes G No 

operating block? 

5.	 G Yes G No 

indicator at the inlet or outlet of the condenser and do you use it to 

identify periods of no flow? 

B. Comments 

1.	 all of the following in your Notification of 

•	 G Yes G No 

(2) 

•	 G Yes G No 

(3) 

2.	 G Yes G No 

(1) 

3.	 all of the following in your Periodic Reports if 

exceedances or excursions are $

during the reporting period: (2)(ii) 

•	 G Yes G No 

•	 G Yes G No 

data are collected? 

Is the temperature monitoring device accurate to within 

of the temperature measured in degrees Celsius or ± 2.5°C, 

Is the temperature monitoring device calibrated annually? 

Do you average the temperature readings over the operating day or 

If flow to the condenser can be intermittent, did you install a flow 

 Recordkeeping and Reporting Requirements 

Did you submit 

Compliance Status Report: 

results of the calculations to demonstrate initial compliance? 

§63.1368(f) 

documentation to establish the maximum condenser outlet gas 

temperature as a site-specific operating parameter? 

§63.1368(f) 

Do you keep continuous records of the condenser outlet temperature? 

§63.1367(b) 

Do you submit 

1 percent of the total operating time 

§63.1368(g) 

all monitoring data for all operating days or blocks when the 

condenser average outlet temperatures that are higher than the 

maximum established in your NOCSR or operating permit? 

identification of all operating days when insufficient monitoring 

3-30
 
 
Checklist 4: (cont’d)
 
 

Requirements for condensers (All options except 3, 4, 8, and 11)
 
 

B. Recordkeeping and Reporting Requirements Comments

•	 operating logs and operating scenarios for all operating days or G Yes G No 
 

blocks when the condenser average outlet temperature is higher 
 

than the maximum established in you NOCSR or operating 
 

permit? 
 

•	 records of the information for CMS required by §63.10(c)(5) G Yes G No 
 

through (13) in subpart A to 40 CFR part 63 (General 
 

Provisions) 
 

4. Do you maintain records for 5 years? §63.1367(a) (1)	 G Yes G No

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-31
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 5: Requirements for regenerative carbon adsorbers (All options except 3, 4, 8, and 

11)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with the requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring Requirements §63.1366(b) iv) and (2 (1)( ) Comments

1.	 For each regenerative cycle, do you monitor all of the following: 

•	 operating time since last regeneration? G Yes G No 

•	 temperature to which the bed is heated during regeneration? G Yes G No 

•	 temperature to which the bed is cooled, measured within 15 G Yes G No 

minutes of completing the cooling phase? 

G Yes G No •	 regeneration stream flow? 

2.	 ± 2 percent G Yes G No 

whichever is greater? 

3.	 G Yes G No 

the established value (i.e., accurate to within ± 10 percent of the 

reading)? 

4.	 G Yes G No 

annually? 

5.	 Do you conduct an annual check for bed poisoning in accordance G Yes G No 

B. Comments

1.	 	 all of the following in your Notification of 

•	 	 G Yes G No 

(2) 

•	 G Yes G No 

(3) 

2.	 	 G Yes G No 

(1) 

Is the temperature monitoring device accurate to within 

of the temperature measured in degrees Celsius or ± 2.5°C, 

Is the regeneration stream flow monitoring device capable of 

recording the total regeneration stream flow to within ± 10 percent of 

Are the temperature and flow monitoring devices calibrated 

with manufacturer’s specifications? 

 Recordkeeping and Reporting Requirements 

Did you submit 

Compliance Status Report: 

results of the initial performance test or design evaluation? 

§63.1368(f)

documentation to establish the regeneration stream flow, the 

minimum carbon bed regeneration temperature, and the 

maximum cooling phase temperature as site-specific operating 

parameters? §63.1368(f)

Do you keep records of the total regeneration stream mass or 

volumetric flow for each carbon bed regeneration cycle? 

§63.1367(b)

3-32 
Checklist 5: (cont’d)
 
 

Requirements for regenerative carbon adsorbers (All options except 3, 4, 8, and 11)
 
 

B. Recordkeeping and Reporting Requirements Comments

3.	 Do you keep records of the temperature to which the carbon bed is G Yes G No 
 

heated during each carbon bed regeneration? §63.1367(b)(1) 
 

4.	 G Yes G No 
 

cooled after each carbon bed regeneration? (1) 
 

5.	 G Yes G No 

(1) 

6.	 Do you identify all of the following in your Periodic Reports if 
 

exceedances or excursions are $ 
 

during the reporting period: (2) 
 

•	 G Yes G No 
 


 


 

•	 G Yes G No 
 

the carbon bed is heated during regeneration is lower than the 
 


 


 

•	 G Yes G No 
 

the carbon bed is cooled after regeneration is higher than the 
 


 


 

•	 G Yes G No 
 


 


 

G Yes G No •	 operating scenarios and operating logs for operating days or
 


 


 


 

7.	 (1) G Yes G No 

Do you keep records of the temperature to which the carbon bed is 

§63.1367(b) 

Do you keep records of the operating time between regeneration? 

§63.1367(b) 

1 percent of the total operating time 

§63.1368(g) 

all regeneration cycles when the total regeneration stream mass 

or volumetric flow is lower than the minimum flow 

established during your initial compliance demonstration? 

all regeneration cycles during which the temperature to which 

minimum temperature established during your initial compliance 

demonstration? 

all regeneration cycles during which the temperature to which 

maximum temperature established during your initial compliance 

demonstration? 

all instances when the operating time between regeneration 

exceeds the time interval established during your initial 

compliance demonstration? 

blocks when any of the parameters described above are outside 

the limit established during your initial compliance 

demonstration? 

Do you maintain records for 5 years? §63.1367(a) 

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-33
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 6: Requirements for nonregenerative carbon adsorbers (All options except 3, 4, 8, and 

11)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring Requirements §63.1366(b) v) and (2 (1)( ) Comments

1.	 	 Do you replace the carbon bed in the nonregenerative carbon 

adsorption system with fresh carbon on a regular schedule based on 

either of the following: 

•	 monitor the outlet TOC concentration that indicates G Yes G No 

breakthrough? 

• 	 time interval established in your NOCS? 	 	 G Yes G No 

2.	 	 G Yes G No 

conditions? 

B. Comments

1.	 	 G Yes G No 
 

(2) 
 

2.	 	 Do you identify in your Periodic Reports all instances when the G Yes G No 
 


 


 

(2) 
 

3.	 	 G Yes G No 
 

records of readings? (1) 
 

4.	 	 (1) 	 G Yes G No 

If you monitor the TOC concentration, do you take readings daily or 

at an interval no greater than 20 percent of the time required to 

consume the total carbon working capacity under peak-case 

 Recordkeeping and Reporting Requirements 

Did you submit the results of the initial design evaluation in your 

Notification of Compliance Status Report? 63.1368(f)

carbon bed is not replaced within the required time interval based on 

either the outlet TOC concentration or the time period established in 

your NOCSR or operating permit? §63.1368(g)

If you monitor the outlet TOC concentration, do you maintain 

§63.1367(b)

Do you maintain records for 5 years? §63.1367(a)

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-34
 
 
Checklist 7: Requirements for thermal incinerators (All options except options 3, 4, 8, and 11)a 

Facility Name: ________________________________________________________
 
 

Facility Location: ________________________________________________________
 
 

Facility TRI ID #: ________________________________________________________
 
 

Inspector: ________________________________________________________
 
 

Date: ________________________________________________________
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements §63.1366(b) vii) and (2 (1)( ) Comments

1.	 	 Do you measure the outlet gas temperature at least once every 15 G Yes G No 

minutes during the period in which the thermal incinerator is 

controlling HAP from an emission stream? 

2.	 G Yes G No 

or ± 2.5°C, whichever is greater? 

3.	 G Yes G No 

4.	 G Yes G No 

operating block? 

5.	 G Yes G No 

do you use it to identify periods of no flow? 

B. Comments 

1.	 all of the following in your Notification of 

•	 G Yes G No 

(2) 

•	 G Yes G No 

(3) 

2.	 G Yes G No 

(1) 

Is the temperature monitoring device accurate to within 

± 0.75 percent of the temperature measured in degrees Celsius 

Is the temperature monitoring device calibrated annually? 

Do you average the temperature readings over the operating day or 

If flow to the thermal incinerator can be intermittent, did you install 

a flow indicator at the inlet or outlet of the thermal incinerator and 

 Recordkeeping and Reporting Requirements 

Did you submit 

Compliance Status Report: 

results of the initial performance test or design evaluation? 

§63.1368(f) 

documentation to establish the minimum outlet gas temperature 

as a site-specific operating parameter? §63.1368(f) 

Do you keep continuous records of the outlet temperature? 

§63.1367(b) 

3-35 
 

Checklist 7: (cont’d)
 
 

Requirements for thermal incinerators (All options except options 3, 4, 8, and 11)
 
 

B. Recordkeeping and Reporting Requirements Comments

3.	 	 Do you submit all of the following in your Periodic Reports if 
 

exceedances or excursions are $1 percent of the total operating time 
 

during the reporting period: §63.1368(g)(2) 
 

•	 all monitoring data for all operating days or blocks when the G Yes G No 
 

average outlet temperature is lower than the minimum 
 

temperature specified in your NOCSR or operating permit? 
 

•	 identification of all operating days when insufficient monitoring G Yes G No 
 

data are collected? 
 

•	 operating logs and operating scenarios for all operating days or G Yes G No 
 

blocks when the average operating temperature is lower than 
 

the minimum temperature specified in your NOCSR or 
 

operating permit? 
 

•	 records of the information for CMS required by §63.10(c)(5) G Yes G No 
 

through (13) in appendix A of 40 CFR part 63 (General 
 

Provisions)? 
 

4.	 Do you maintain records for 5 years? §63.1367(a) (1) G Yes G No

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-36
 
 
Checklist 8: Requirements for catalytic incinerators (All options except 3, 4, 8, and 11)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements §63.1366(b) viii) and (2 (1)( ) Comments

1.	 	 Do you measure the temperature of the gas stream immediately before G Yes G No 

and after the catalyst bed at least once every 15 minutes during the 

period in which the catalytic incinerator is controlling HAP form an 

emission stream? 

2.	 G Yes G No 

3.	 G Yes G No 

is greater? 

4.	 G Yes G No 

5.	 G Yes G No 

operating block? 

6.	 G Yes G No 

flow indicator at the inlet or outlet of the catalytic incinerator and do 

you use it to identify periods of no flow? 

B. Comments 

1.	 all of the following in your Notification of 

•	 G Yes G No 

(2) 

•	 G Yes G No 

(3) 

2.	 G Yes G No 

catalyst bed? (1) 

Do you calculate the temperature difference across the catalyst bed at 

least once every 15 minutes during the period in which the catalytic 

incinerator is controlling HAP form an emission stream? 

Is the temperature monitoring device accurate to within ± 0.75 percent 

of the temperature measured in degrees Celsius or ± 2.5°C, whichever 

Is the temperature monitoring device calibrated annually? 

Do you average the temperature readings over the operating day or 

If flow to the catalytic incinerator can be intermittent, did you install a 

 Recordkeeping and Reporting Requirements 

Did you submit 

Compliance Status Report: 

results of the initial performance test or design evaluation? 

§63.1368(f) 

documentation to establish the minimum temperature of the gas 

stream immediately before the catalyst bed and the minimum 

temperature difference across the catalyst bed as site-specific 

operating parameters? §63.1368(f) 

Do you keep continuous records of the temperature of the gas stream 

upstream of the catalyst bed and the temperature difference across the 

§63.1367(b) 

3-37
 
 
Checklist 8: (cont’d)
 
 

Requirements for catalytic incinerators (All options except 3, 4, 8, and 11)
 
 

B. Recordkeeping and Reporting Requirements Comments

3.	 	 Do you submit all of the following in your Periodic Reports if 
 

exceedances or excursions are $1 percent of the total operating time 
 

during the reporting period: §63.1368(g)(2) 
 

•	 all monitoring data for all operating days or blocks when the G Yes G No 
 

average upstream temperature is lower than the minimum 
 

temperature specified in your NOCSR or operating permit, or the 
 

average temperature difference across the catalyst bed is lower 
 

than the minimum temperature difference specified in your 
 

NOCSR or operating permit? 
 

•	 identification of all operating days when insufficient monitoring G Yes G No 
 

data are collected? 
 

•	 operating scenarios and operating logs for all operating days or G Yes G No 
 

blocks when the temperatures do not meet the limits specified in 
 

your NOCSR or operating permit? 
 

•	 the information required by §63.10(c)(5) through (13) in appendix G Yes G No 
 

A of 40 CFR part 63 (General Provisions) 
 

3.	 Do you maintain records for 5 years? §63.1367(a) (1) G Yes G No

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-38
 
 
Checklist 9: Requirements for a boiler or process heater (All options, except 3, 4, 8, and 11)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements §63.1366(b) ix) and (2 (1)( ) Comments

1.	 	 Do you monitor the temperature of the gases exiting the combustion G Yes G No 

chamber at least every 15 minutes during the period in which the 

boiler or process heater is controlling HAP from an emission stream? 

2.	 ± 0.75 percent G Yes G No 

or ± 2.5°C, whichever is greater? 

3.	 G Yes G No 

4.	 G Yes G No 

operating block? 

5.	 G Yes G No 

install a flow indicator at the inlet or outlet of the boiler or process 

heater and do you use it to identify periods of no flow? 

B. Comments 

1.	 all of the following in your Notification of 

•	 G Yes G No 

(2) 

•	 G Yes G No 

(3) 

2.	 G Yes G No 

(1) 

Is the temperature monitoring device accurate to within 

of the temperature measured in degrees Celsius 

Is the temperature monitoring device calibrated annually? 

Do you average the temperature readings over the operating day or 

If flow to the boiler or process heater can be intermittent, did you 

Recordkeeping and Reporting Requirements 

Did you submit 

Compliance Status Report: 

results of the initial performance test or design evaluation? 

§63.1368(f) 

documentation to establish the minimum combustion zone 

temperature? §63.1368(f) 

Do you have continuous records of the combustion zone temperature? 

§63.1367(b) 

3-39 
 

Checklist 9: (cont’d)
 
 

Requirements for a boiler or process heater (All options, except 3, 4, 8, and 11)
 
 

B. Recordkeeping and Reporting Requirements Comments

3.	 	 Do you submit all of the following in your Periodic Reports if 
 

exceedances or excursions are $1 percent of the total operating time 
 

during the reporting period: §63.1368(g)(2) 
 

•	 all monitoring data for all operating days or blocks when the G Yes G No 
 

average combustion zone temperature is lower than the minimum 
 

temperature specified in your NOCSR or operating permit? 
 

•	 identification of all operating days when insufficient monitoring G Yes G No 
 

data are collected? 
 

•	 operating scenarios and operating logs for all operating days or G Yes G No 
 

blocks when the average combustion zone temperature is lower 
 

than the minimum specified in your NOCSR or operating permit? 
 

•	 records of the information for CMS required by §63.10(c)(5) G Yes G No 
 

through (13) in appendix A of 40 CFR part 63 (General 
 

Provisions) 
 

4.	 Do you maintain records for 5 years? §63.1367(a) (1) G Yes G No

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-40
 
 
Checklist 10: Requirements for fabric filters (Option 11)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements §63.1366(b) (1)(xi) Comments

1. Do you have a bag leak detection system that provides output of G Yes G No 

relative particulate matter emissions? 

2. 

established during initial calibration? 

G Yes G No 

3. Is the bag leak detector installed in either of the following locations: 

• 

fabric filter? 

G Yes G No 

• G Yes G No 

4. 

• Have you established the relative baseline output level (by 

adjusting the range and averaging period of the device)? 

G Yes G No 

• G Yes G No 

• G Yes G No 

• 

in good operating condition? 

G Yes G No 

• 

specifications and instructions? 

G Yes G No 

5. G Yes G No 

B. Comments 

1.	 

following records: (5) 

•	 G Yes G No 

Does the bag leak detector have an alarm system that sounds when it 

detects an increase in particulate matter emissions over the level 

In each fabric filter compartment or cell of a positive pressure 

downstream of a negative pressure or induced air filter? 

Do you calibrate the bag leak detection system as follows: 

Have you established the alarm set points and alarm delay time? 

Do you adjust the sensitivity or range, averaging period, alarm set 

points, or alarm delay time only as described in your operation 

and maintenance plan? 

If you ever increase the sensitivity by more than 100 percent or 

decrease the sensitivity for more than 50 percent, do you also 

conduct a complete baghouse inspection to demonstrate that it is 

Have you performed other calibration procedures based on 

available guidance from EPA or on the manufacturer’s written 

If the alarm on a bag leak detection system is triggered, do you begin 

to identify the cause of the alarm and take corrective action as 

specified in your corrective action plan within one hour of the alarm? 

Recordkeeping and Reporting Requirements 

For each time the bag leak detection alarm is activated, do you have the 

§63.1367(b) 

date and time? 

3-41 
 

Checklist 10: (cont’d)
 
 

Requirements for fabric filters (Option 11)
 
 

B. Recordkeeping and Reporting Requirements Comments

•	 brief explanation of the cause of the alarm? 	 G Yes G No 

•	 brief description of corrective action taken? 	 G Yes G No 

2.	 (1) 	 G Yes G No 

3.	 G Yes G No 
 


 


 

(1)(xi)( (6) 
 

4.	 Do you have a corrective action plan that describes corrective actions to G Yes G No 
 


 


 

(1)(xi)( (6) 

5.	 G Yes G No 
 

exceedances are $ 
 

reporting period: (2) 
 

6.	 G Yes G No 
 

reports? (2)(viii) 
 

Do you maintain records for 5 years? §63.1367(a) 

Do you have an operation and maintenance plan that describes proper 

operation and maintenance procedures (such as how to adjust the 

sensitivity or range, averaging period, alarm set point, and alarm delay 

time)? §§63.1366(b) F)and 63.1367(e) 

be taken, and the timing of those actions, when the particulate matter 

concentration exceeds the setpoint and activates the alarm? 

§§63.1366(b) G) and 63.1367(e) 

Do you submit bag leak detection records in your Periodic Reports if 

1 percent of the total operating time during the 

§63.1368(g) 

Do you submit updates to your corrective action in your periodic 

§63.1368(g) 

a Option 11 is described in the section “What compliance options do I have for process vents that emit particulate 

matter?” and in Table 3-1. 

3-42
 
 
Checklist 11: Requirements for flares (Option 3)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

1. Monitoring Requirements §63.1366(b) vi) and (2 (1)( ) Comments

1.	 Do you monitor for the presence of the flare pilot flame at least once G Yes G No 

every 15 minutes? 

2.	 G Yes G No 

B. Comments 

1.	 all of the following in your Notification of 

•	 (2) G Yes G No 

•	 G Yes G No 

(3) 

2.	 G Yes G No 

(1) 

3.	 Do you identify all of the following in your Periodic Reports if 

exceedances or excursions are $

during the reporting period: (2) 

•	 G Yes G No 

•	 G Yes G No 

4.	 (1) G Yes G No 

Is the monitoring device calibrated annually? 

Recordkeeping and Reporting Requirements 

Did you submit 

Compliance Status Report: 

results of the initial visible emissions test? §63.1368(f) 

the net heating value of gas being combusted and its exit velocity? 

§63.1368(f) 

Do you maintain records of the continuously monitored data? 

§63.1367(b) 

1 percent of the total operating time 

§63.1368(g) 

all periods when the flare pilot flame was absent? 

all periods when the monitor was not working? 

Do you maintain records for 5 years? §63.1367(a) 

a Option 3 is described in the section “What compliance options do I have for my Group 1 process vents?” and in 

Table 3-1. 

3-43
 
 
Checklist 12: Requirements for alternative standard (Option 4 and 8)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements Comments

1.	 	 Have you installed a CEMS to monitor the outlet TOC concentration G Yes G No 

and/or outlet HCl and chlorine concentration at least once every 15 

minutes during the period in which the control device is controlling 

HAP from an emission stream? §63.1366(b)(5)(i) 

2.	 G Yes G No 

Specification 8 or 9 of appendix B of part 60? (5)(i) 

3.	 G Yes G No 

accordance with §63.8 (the General Provisions in subpart A to 40 CFR 

part 63)? (5)(i) 

4.	 

( (5)(ii) 

•	 2 concentrations to G Yes G No 

•	 G Yes G No 

5.	 G Yes G No 

( (5)(ii) 

•	 2 concentrations to
 

3 percent oxygen, or
 

•	 

6.	 Is the CEMS data reduced to operating day averages? (2) G Yes G No 

7.	 G Yes G No 

indicator at the inlet or outlet of the control device, and do you use it 

to identify periods of no flow? (2)(iii) 

B. Comments 

1.	 G Yes G No 

Does your TOC monitor meet the requirements of Performance 

§63.1366(b) 

Is your TOC monitor installed, calibrated, and maintained in 

§63.1365(b) 

If you introduce supplemental gases to the emission stream before a 

noncombustion device, do you perform both of the following: 

§§63.1365(a) 7) and 63.1366(b) 

adjust the monitored outlet TOC and/or HCl/Cl 

account for the supplemental gases? 

evaluate the volumetric flow rate of all gas streams each time a 

new operating scenario is implemented? 

If you introduce supplemental gases to the emission stream before a 

combustion device, do you perform either of the following: 

§§63.1365(a) 7) and 63.1366(b) 

adjust the monitored outlet TOC and/or HCl/Cl 

monitor residence time and firebox temperature? 

§63.1366(b) 

and (8) 

If flow to the control device can be intermittent, did you install a flow 

§63.1366(b) 

Recordkeeping and Reporting Requirements 

Do you have a written quality control program with protocols for 

various operations including calibration procedures for the monitor? 

§63.8(d) 

3-44 
 

Checklist 12: (cont’d)
 
 

Requirements for alternative standard (Option 4 and 8)
 
 

B. Recordkeeping and Reporting Requirements Comments

2.	 Have you recorded all maintenance and calibration checks performed G Yes G No 

on the CEMS? §63.1367(b)(3) 

3.	 Do you have all of the following records: (4) and 

( 

•	 G Yes G No 

recorded during unavoidable CEMS breakdowns and 

out-of-control periods)? 

•	 G Yes G No 

except for zero (low-level) and high-level checks? 

•	 G Yes G No 

gas audit)? 

•	 G Yes G No 

•	 G Yes G No 

known), and corrective actions taken? 

•	 G Yes G No 

inoperative or out of control? 

•	 G Yes G No 

•	 G Yes G No 

4.	 G Yes G No 

CEMS? (2) 

5.	 all of the following in your Periodic Reports if 

exceedances or excursions are $

during the reporting period: (2) 

•	 G Yes G No 

the average TOC or HCl/Cl2 

•	 G Yes G No 

data are collected? 

•	 operating logs and operating scenarios for operating days when the G Yes G No 

TOC and/or HCl/Cl2 

•	 G Yes G No 

 §63.1367(a) 

63.10(c) 1) through (14) 

all required CEMS measurements (including monitoring data 

the date and time of each period when the CEMS is inoperative 

the date and time of each period when the CEMS is out of control 

(e.g., calibration drift exceeds specification, CEMS fails cylinder 

the date, start time, and end time of each period of excess emissions 

and parameter monitoring exceedances, including those occurring 

during startups, shutdowns, and malfunctions? 

the nature and cause of any malfunction of your monitor (if 

the nature of any repairs or adjustments to a CEMS that was 

the total process operating time during the reporting period? 

all procedures, including calibrations, that are part of your 

quality control program? 

Do you have records indicating that you notified the Administrator at 

least 60 days before conducting a performance evaluation of your 

§63.1368(d) and 63.8(e) 

Do you submit 

1 percent of the total operating time 

§63.1368(g) 

all monitoring data for all operating days or operating blocks when 

 concentrations exceed 20 ppmv for 

combustion devices or 50 ppmv for noncombustion devices? 

identification of all operating days when insufficient monitoring 

 concentration exceeded the 20 ppmv or 50 

ppmv limit? 

the records listed in “3" required by §63.10(c)(5) through (13) 

3-45 
 

Checklist 12: (cont’d)
 
 

Requirements for alternative standard (Option 4 and 8)
 
 

B. Recordkeeping and Reporting Requirements Comments

6.	 	 If you correct concentrations for supplemental gases from a G Yes G No 
 

noncombustion device, do you reevaluate the flow rates of supplemental 
 

gases and affected gas streams after each operating scenario change, 
 

and include the revised flows and the procedures used to estimate them 
 

in your periodic reports? 
 

7.	 Do you maintain records for 5 years? §63.1367(a) (1) G Yes G No 

a Options 4 and 8 are described in the section “What compliance options do I have my my Group 1 process vents?” 
 

and in Table 3-1. 
 

3-46
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 13: Requirements for any control devices that control vent streams containing total 

HAP emissions less than 0.91 Mg/yr (All options except 4 and 8)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. If your approved monitoring procedures are the same as those specified in the rule for a larger 

control device, also fill out the appropriate checklist from among checklists 3 through 11. 

A. Monitoring Requirements §63.1366(b) i) and (2 (1)( ) Comments

1.	 	 Do you periodically verify that the control device is operating properly G Yes G No 

by following the procedures specified in your approved Precompliance 

Plan? 

2.	 	 G Yes G No 

3.	 	 G Yes G No 

4.	 	 G Yes G No 

indicator at the inlet or outlet of the control device and do you use it to 

identify periods of no flow? 

B. Comments 

1.	 	 G Yes G No 
 


 

2.	 	 all of the following in your Periodic Reports if the 
 

exceedances or excursions are $ 
 

during the reporting period: 
 

(2) 

•	 G Yes G No 
 

show the control device is not operating as designed? 
 

•	 G Yes G No 
 


 

3.	 	 (1) 	 G Yes G No 

If the verification procedure includes monitoring a parameter more 

than one time per day, do you average the daily readings? 

Do you calibrate any monitoring instruments according to procedures 

in your approved Precompliance Plan? 

If flow to the control device can be intermittent, did you install a flow 

Recordkeeping and Reporting Requirements 

Did you submit a description of your daily or per batch verification 

procedures in your Precompliance Plan? §63.1368(e) 

Do you submit 

1 percent of the total operating time 

§63.1368(g)

all monitoring data for all operating days or blocks when the data 

identification of all operating days or blocks when insufficient 

monitoring data are collected? 

Do you maintain records for 5 years? §63.1367(a)

a The compliance options are described in the section “What compliance options do I have for my Group 1 process 

vents?” and in Table 3-1. 

3-47
 
 
[This page intentionally left blank.] 
Chapter 4 - Complying with requirements for storage vessels 

What is a storage vessel? 

A storage vessel is a tank or other vessel that is used to store organic liquids that contain one or 

more HAP [§63.1361] 

What storage vessels are subject to subpart MMM? 

Storage vessels that meet all of the following criteria are subject to Subpart MMM: 

•	 meet the definition of a “Group 1” storage vessel [§63.1361] 

•	 are determined to be part of a PAI process unit [§63.1360(f)] 

•	 are not exempt under the definition of storage vessel [§63.1361] 

What storage vessels are exempt? 

Any storage vessels meeting either of the following conditions are not subject to Subpart MMM: 

•	 Group 2 storage vessels 

•	 Vessels that are not part of a PAI process unit 

Note: A Group 2 storage vessel is any vessel that does not meet the definition of a Group 1 storage vessel. 

In addition, your tank or other vessel is not considered to be a storage vessel (Group 1 or 2) if 

any of the following apply [§63.1361]: 

•	 it is permanently attached to a motor vehicle, such as a truck, railcar, barge, or ship 

•	 it is designed to operate with a pressure in excess of 204.9 kilopascals and without 

emissions to the atmosphere 

•	 material stored in the vessel contains no organic HAP or contains organic HAP only as 

impurities 

Definition: Impurity means a substance that is produced coincidentally with the 

product(s), or is present in a raw material. An impurity does not serve a useful purpose in 

the production or use of the product(s) and is not isolated. 

4-1
 
• 	 it is a wastewater storage tank 

• 	 it is a non-wastewater waste tank 

• 	 it is a process tank 

What is a “Group 1” storage vessel? 

If your storage vessel meets any of the following criteria, it is considered a “Group 1” storage 

vessel: [§63.1361] 

And stores material with a maximum true 

Your storage vessel is at ... And has a capacity of... vapor pressure of... 

an existing source $75 m3 	 $ 3.45 kPa 
 

a new source $ 40 m3 	 $ 16.5 kPa 
 

$ 75 m3 	 $ 3.45 kPa 

Note: If you do not wish to determine the maximum true vapor pressure of the material in a storage vessel, 

then you must designate it as a Group 1 storage vessel [§63.1362(c)(1)]. 

How do I know if a storage vessel is part of a PAI process unit? 

Your storage vessel is not part of a PAI process unit (and is not part of the affected source) if it 

is (was) subject to another MACT standard on June 23, 1999 [§63.1360(f)(1)]. 

Your storage vessel is part of a PAI process unit if either of the following apply: 

C	 	 the input to the vessel from the PAI process unit is greater than or equal to the input from 

any other PAI or non-PAI process unit 

C	 	 the output from the vessel to the PAI process unit is greater than or equal to the output to 

any other PAI or non-PAI process unit 

Note: If the greatest input to (or output from) a shared storage vessel is the same for two or more process units, 

including at least one PAI process unit, you may assign the storage vessel to any one of the PAI process units. 

[§63.1360(f)(2)] 

If the process unit(s) the storage vessel is used with varies from year to year, then you determine 

the greatest input or output on either of the following: [§63.1360(f)(4)] 

C	 	 what you actually used the vessel for during the year preceding June 23, 1999 (for
 

existing sources) or
 

4-2
 
C what you expect to use the vessel for in the 5 years after startup (for new storage vessels 

or existing vessels that were not in operation for the year preceding June 23, 1999). 

For storage vessels in tank farms, you use the same procedures described above to determine if 

the storage vessel is part of a PAI process unit, except your analysis is limited to the process 

units for which there is no storage vessel in-between the storage vessel in the tank farm and the 

associated processes (i.e., an “intervening” storage vessel). [§63.1360(f)(3)] 

As an alternative, even if an intervening storage vessel is present, you may assign the 

storage vessel in the tank farm to whichever PAI process send the most material to, or 

receives the most material from, the storage tank in the tank farm. [§63.1360(f)(3)(ii)(C)] 

You must reevaluate if your storage vessel is part of a PAI process unit after any of the 

following occur: [§63.1360(f)(5)] 

C the storage vessel begins receiving material from (or sending material to) another process 

unit 

C the storage vessel ceases to receive material from (or send material to) a PAI process unit 

C there is a significant change in the use of the storage vessel 

What compliance options do I have for my storage vessels? 

For any storage vessel covered under Subpart MMM, you have five compliance options: 

Note: Compliance options for storage vessels are the same for new and existing sources. 

Option 1: Use a fixed roof tank with an internal floating roof (IFR) 

[§63.1362(c)(2)(i)] 

Equip the storage vessel with a fixed roof and internal floating roof 

Option 2: Install an external floating roof (EFR) [§63.1362(c)(2)(ii)] 

Equip the storage vessel with an external floating roof 

Option 3: Convert your external floating roof to an internal floating roof 

[§63.1362(c)(2)(iii)] 

Equip the storage vessel with an external floating roof converted to an internal floating roof 

(i.e., install a fixed roof above an external floating roof) 

4-3
 
Option 4: Vapor balance to a tank truck or railcar [§63.1362(c)(6)]: 

Use a vapor balancing system that is designed and operated to route organic HAP vapors 

displaced from loading of the storage vessel to the railcar or tank truck from which the 

storage vessel is filled. No pressure relief device on the storage vessel, or on the railcar or 

tank truck, may open during loading or as a result of daily temperature changes. 

Note that railcars and tank trucks that deliver HAP to your storage tank must be reloaded and cleaned at a 

facility that either vents emissions from the railcar or tank truck to a control device or vapor balances to the 

storage tank that contains the liquid that is transferred to the railcar or tank truck. 

Option 5: Use a control device that meets any of the following conditions 

[§63.1362(c)(2)(iv)]: 

(A) Percent reduction [§63.1362(c)(2)(iv)(A)] 

Equip the storage vessel with a closed vent system and a control device that reduces 

organic HAP emissions by $95 percent (by weight) 

(B) Reduce outlet concentration to #20 ppmv [§63.1362(c)(2)(iv)(B)] 

Equip the storage vessel with a closed vent system and a control device that reduces 

organic HAP emissions to outlet concentrations of #20 ppmv 

(C) A flare [§63.1362(c)(2)(iv)(C)] 

Equip the storage vessel with a flare that meets the requirements of §63.11(b) (see the 

Subpart A General Provisions) 

(D) Use one of the following as a control device: 

•	 A boiler or process heater with a design heat input These control devices are exempt of 44 megawatts or greater from initial compliance 

•	 A boiler or process heater into which the emission demonstrations and monitoring 

requirements. stream is introduced with the primary fuel [§63.1362(l) and 

•	 An incinerator, boiler, or process heater that is §63.1365(a)(4)(i)(ii)] 

permitted under RCRA 

4-4
 
 
(E) Use the alternative standard [§63.1362(c)(4)] 

Use the alternative standard under §63.1362(c)(4), and route emissions from storage 

vessels to a control device or series of control devices that achieve all of the following 

outlet concentrations: 

• #20 ppmv TOC (as calibrated on methane or the predominant HAP) 

• #20 ppmv total HCl and Cl2 

Note: The outlet concentration limits are the same for options 5B and 5E, but the alternative standard 

requires monitoring with CEMS, whereas Option 5B requires an initial performance test (or design 

evaluation) and monitoring of control device operating parameters. 

For option 5, you are exempt from specification requirements during periods of planned routine maintenance 

of the control device that do not exceed 240 hr/yr [§63.1362(c)(5)]. 

How do I show initial compliance with the storage vessel 

requirements? 

Subpart MMM contains different initial compliance requirements based on the compliance 

options you choose. 

Options 1, 2 or 3: Compliance using internal or external floating roofs 

You demonstrate initial compliance when you use a floating roof by determining if you are in 

compliance with all of the following: 

• floating roof design features
 
 

• operating requirements
 
 

• inspection and measurement requirements (measurements are only for option 2) 

Initial compliance and monitoring requirements for storage vessels equipped with a floating roof 

are specified in §63.119 and §63.120 of Subpart G of the HON as referenced from §63.1365(d) 

and §63.1366. However, Subpart MMM designates different definitions and compliance dates as 

follows: [§63.1365(d)(3)] 

• the definition in §63.1361 applies when the term “storage vessel” is used in §§63.119 and 

63.120. 

• November 10, 1997 applies instead of December 31, 1992. 

• June 23, 1999 applies instead of April 22, 1994. 

• the compliance date specified in §63.1364 of Subpart MMM applies instead of the 

compliance date in §63.100 of Subpart F. 

4-5
 
• the “maximum true vapor pressure of the total organic HAP in the stored liquid” is based 

on the Group 1 characteristics defined in §63.1361 rather than the criteria specified in 

Tables 5 and 6 of Subpart G. 

See Table 4-1 (page 4-7) for your floating roof design and operating requirements. You may be 

subject to one or more of the requirements listed depending on the compliance options you 

choose. Initial inspections and measurements are discussed in the section “What monitoring 

must I do?” later in this chapter. 

Option 4: Vapor balancing 

If you use the vapor balancing option to comply with Subpart MMM, you demonstrate initial 

compliance by installing a pressure relief device on the storage vessel that is set to no less than 

2.5 psig. [§63.1362(c)(6)(v)] 

Note that offsite cleaning and reloading facilities must provide you with written certification that they will meet all 

of the requirements of Subpart MMM. [§63.1362(c)(6)(vii)(A)] 

Option 5: Compliance using a control device 

(A) Percent reduction 

If you use the percent reduction option to comply with Subpart MMM, you must demonstrate 

initial compliance by determining the efficiency of the control device based on either of the 

following: 

• performance test data [§63.1365(d)(1)(i)] Sections 63.1365(b)(1) through (11) specify 

• design evaluation [§63.1365(d)(1)(ii)] test methods and procedures. 

Performance test procedures 

If you send emissions from both a storage vessel and process vents to the same control device, 

you may demonstrate initial compliance for the storage vessel using the results of the test you 

conducted to show compliance with the process vent standards, provided that the test showed a 

percent reduction $95 percent [§63.1365(d)(1)(i)(C)]. See “How do I show initial compliance 

with the process vent requirements?” beginning on page 3-8 for more information. 

If you elect to conduct a test specifically for the emissions from the storage vessel, the test must 

be conducted at the reasonably expected maximum filling rate [§63.1365(d)(1)(i)(A)]. 

4-6
 
 
TABLE 4-1. Design and Operating Requirements for Storage Vessels Equipped with a Floating 

If you are complying with ... Then your... Must... And also must... 

Option 1, 2, or 3 floating roof be floating on the liquid surface except under 

the following conditions when being 

(Please note that supported by the leg supports is allowed: you have more • during initial fill 

requirements for • after the vessel has been completely 

these options emptied and degassed further in this • before refilling 

table) 

Option 1 

openings in non-contact IFRs or EFRs access hatches and gauge floats openings in the IFR (except for leg ladder wells 

have gaskets 

project below the liquid surface 

have a gasketed cover 

have a cover or lid with a gasket 

have a slit fabric cover over at least 

90 percent of the opening 

have a gasketed sliding cover 

being floated off or lan• when the roof is be

leg supports 

4-7

•


 
 

automatic bleeder vents 

rim space vents (except for automatic bleeder vents and rim space vents) sleeves, automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains) sample wells 

have gaskets be closed at all times e

be set to open only in t

when the pressure b

exceeds manufactu

be closed at all times e

be closed at all times e
TABLE 4-1. (cont’d) 

If you are complying with ... Then your... Must... And also must... 

penetrations in the IFR for fixed roof have either of the following: columns 

• a flexible fabric sleeve seal • a gasketed sliding cover 

4-8
 
 

Option 2 closure device between the vessel be any one of the following: 

wall and roof edge • and the vessel wall 

b 

•

secondary sealb 

•

Option 1 or 3 closure device between the vessel be any one of the following: 

wall and the roof edge • b and the vessel wall

•••

completely cover the s

a liquid-mounted or metallic shoe 

primary seal with no secondary seal

a vapor-mounted primary seal and a a liquid-mounted or metallic shoe 

primary seal and a secondary seal 

completely cover the s

a vapor-mounted seal

a liquid-mounted seal 

a metallic shoe seal a double seal 
TABLE 4-1. (cont’d) 

If you are complying with ... Then your... Must... And also must... Option 2 or 3 openings in the roof except for the be equipped with a gasketed cover or lid both of the following: 

following: • keep the cover or li• automatic bleeder vents access • rim space vents • cover on each acce

float well must be b

• roof drains air tight when close• leg sleeves 

4-9
 

liquid least 90 percent of the drain opening area guide pole wells have either of the following: 

••

unslotted guide poles slotted guide poles have a gasketed float or other device to close 

roof drains that empty into the stored have a slotted membrane fabric cover over at 

a gasketed sliding cover a flexible fabric sleeve seal 

have a gasketed cap on the end of the pole be kept closed except w

level or taking liquid s

off the liquid surface from the atmosphere 

IFR = internal floating roof EFR = external floating roof 

a Rule references for the information in Table 4-1 are: §63.119(b) for option 1, §63.119(c) for option 2, and §63.119(d) for option 3. b This type of sealing mechanism is allowed only until the first time the storage vessel is emptied and degassed or June 23, 2009, which
Design evaluation procedures 

If you choose to demonstrate initial compliance by conducting a design evaluation, you must 

document how you demonstrate that your control device achieves the required control efficiency 

when the storage vessel is filled at the reasonably expected maximum filling rate. The 

parameters to consider in design evaluations for different types of control devices are described 

in §63.1365(a)(1). 

(B) Outlet concentration 

If you are complying with Subpart MMM using the Sections 63.1365(b)(1) through (11) specify 

outlet concentration option, you demonstrate initial test methods and procedures. 

compliance by conducting a performance test to show 

the outlet TOC or total organic HAP concentration is 

#20 ppmv [§63.1365(a)(6) and (d)(2)]. 

(C) Flare 

When a flare is the control device, you demonstrate initial compliance by doing all of the 

following: 

•	 determining visible emissions using EPA Method 22 of 40 CFR part 60, Appendix A, for 

a 2-hour observation period [§63.1365(a)(3) and (d)(4)]. Flares must produce no visible 

emissions, except for a period of 5 minutes during any 2 consecutive hours [§63.11(b)(4) 

of subpart A] 

•	 determining under absolute or hypothetical peak-case conditions, the net heating value of 

gas being combusted and its exit velocity as specified in §63.11(b)(6) through (8) of the 

General Provisions [§63.1365(a)(3) and (d)(4)] 

(E) The alternative standard 

When using the alternative standard in §63.1362(c)(4), your outlet TOC concentration must be 

#20 ppmv, and the outlet HCl and Cl2 concentration must be #20 ppmv. 

You demonstrate initial compliance with these values by having the monitoring equipment 

operational on the compliance date (see the discussion of monitoring requirements for option 5C 

in the section “What monitoring must I do for my storage vessels?” later in this chapter, [page 

4-16]). In addition, if you intend to calibrate the monitor using the predominant HAP, you will 

have to use EPA Method 18 to determine the predominant HAP [§63.1365(a)(5) and (d)(6)]. 

4-10
 
 
How do I comply when my control device needs repairs [options 5 (A, 

B, C, and E)]? 

Your storage vessel is exempt from Subpart MMM during periods of routine maintenance on the 

storage vessel control device, provided that the routine maintenance does not exceed 240 hr/yr 

(unless you get an extension) [§§63.1362(c)(5) and 63.1365(d)(7)]. 

You demonstrate initial compliance with the provisions by including anticipated periods of 

planned routine maintenance for the first reporting period in the Notification of Compliance 

Status report as discussed in “What do I have to report and when?” in Chapter 8 (page 8-1). 

What monitoring must I do for my storage vessels? 

Your monitoring requirements depend on the compliance option you select. A summary of the 

monitoring requirements for each compliance option follows: 

If you are complying Then your monitoring requirements 

using ... include ... You must monitor at this frequency... 

Option 1, 2 or 3 various inspections and measurements 	 	 typically annually and every time the 

storage vessel is emptied and 

degassed 

Option 5 (A or B) 	 
 


 

and flow rate 
 

Option 5 (C) 	 

Option 5 (E) 	 
 

HCl/Cl2 concentrations 
 

monitor one or more control device every 15 minutes 

operating parameters such as temperature 

monitor presence of pilot flame every 15 minutes 

monitor outlet TOC and, if appropriate, every 15 minutes 

Additional details for each option are provided below. 

Options 1 or 3: Monitoring for internal floating roofs (IFRs) 

If you comply with option 1 or 3, your monitoring requirements are as follows [§63.120(a) as 

cross-referenced from §63.1365(d)(3)]: 

4-11
 
 
If your IFR 	 Then visually For the following According to these 

has a ... inspect the ... failures ... At this frequency... sections of the rule... 

Double-seal IFR, the primary • defects in the IFR each time the vessel §63.120(a)(3)(i) and 

system 

(Option A) 	 

and secondary seal, 

gaskets, slotted 

membranes, and 

sleeve seals, if any 

(i.e., an “internal 

inspection”) 	 

• 	 holes, tears, or other 

openings in the seal 
 

or seal fabric 

• gaskets that no 

longer close off the 

is emptied and 

degassed, 

and at least once 
 

every 5 years after 
 

the compliance date 

(a)(7) 

liquid surface to the 

atmosphere 

• 	 slotted membranes 

with more than 

10 percent open area 

Double-seal secondary seal • at least once every 12 §63.120(a)(3)(ii) and 

system resting on the (a)(4) 

and roof hatches surface of the liquid the initial fill date or (Option B) 	 on the fixed roof or the leg supports 
 

• liquid on the IFR whichever is later 
 

inspection) 
 

• 	 

• 	 holes or tears in the 

seal fabric 

• 	 

the seal and the wall 

of the storage vessel 

	 • §63.120(a)(3)(iii) and 

and secondary seal, (a)(7) • 	 holes, tears, or other gaskets, slotted degassed, and at least openings in the seal once every 10 years 

sleeve seals, if any or seal fabric 

• date 

inspection) longer close off the 

liquid surface to the 

• 	 

10 percent open area 

IFRs that are not 

through manholes months after either 

the compliance date, 

(i.e., an “external” 

detached seal 

visible gaps between 

IFR, the primary defects in the IFR each time the vessel 

is emptied and 

membranes, and 

after the compliance 

(i.e., an “internal” gaskets that no 

atmosphere 

slotted membranes 

with more than 

4-12
 
 
If your IFR Then visually For the following	 According to these 

has a ... inspect the ... failures ... At this frequency... sections of the rule... 

Single-seal IFR and the seal • IFRs that are not at least once every 12 §63.120(a)(2)(i) and 

system through manholes resting on the months after initial (a)(4) 

and roof hatches surface of the liquid fill, or at least once 

on the fixed roof or the leg supports every 12 months 

(i.e., an “external” 

inspection) • liquid on the IFR after compliance date 

•	 detached seal 

•	 holes or tears in the 

seal fabric 

•	 visible gaps between 

the seal and the wall 

of the storage vessel 

IFR, the seal, • §63.120(a)(2)(ii) and 

gaskets, slotted • holes, tears, or other (a)(7) 

openings in the seal degassed, and at least 

sleeve seals, if any or seal fabric once every 10 years 

inspection) • date 

longer close off the 

liquid surface to the 

•	 

10 percent open area 

defects in the IFR each time the storage 

vessel is emptied and 

membranes, and 

(i.e., an “internal” after the compliance 

gaskets that no 

atmosphere 

slotted membranes 

with more than 

Note: Subpart MMM designates some different definitions and compliance dates than are used in §63.120 of 

subpart G. These differences are noted in “How do I show initial compliance with the storage vessel 

requirements” earlier in this chapter. 

Defects and other failures found during annual inspections must be repaired within 45 days after performing the 

inspection (unless you get an extension) [§63.120(a)(4)]. Defects and other failures found in the inspection after 

emptying and degassing the storage vessel must be repaired before refilling the storage vessel with organic HAP 

[§63.120(a)(7)]. 

Option 2: Monitoring for external floating roofs (EFRs) 

If you comply with option 2, your monitoring requirements are as follows [§63.120(b) as crossreferenced from §63.1365(d)(3)]: 

4-13
 
 
For EFRs with the According to this section 

following features... Monitor the following... At this frequency ...a of the rule... 

All EFRs 	 visually inspect the roof, each time the vessel is §63.120(b)(10) 
 

seals, and fittings emptied and degassed 
 

EFR with primary and 	 b gap between vessel during the hydrostatic §63.120(b)(1)(i) 

secondary seals 	 testing of the vessel or 
 


 

whichever occurs last, 
 

and at least every 5 
 

years thereafter 
 

during the hydrostatic §63.120(b)(5) 
 

testing of the vessel or 
 


 

whichever occurs last, 
 

extends above the liquid and at least every 5 
 

surface years thereafter 
 

b gap between vessel annually §63.120(b)(1)(iii) 
 

wall and secondary seal 
 

inspect integrity of secondary annually §63.120(b)(6) 
 

seal and inspect for proper fit 
 

EFR with liquid- b gap between vessel annually §63.120(b)(1)(ii) 
 

mounted or metallic 
 

shoe primary seal and 
 

no secondary sealc 
 

annually §63.120(b)(5)(ii) 

seal 

annually §63.120(b)(5)(i) 

distance that one end of the 

the liquid surface 

measure

wall and primary seal 

by the compliance date, 

inspect integrity of primary 

seal and if using a metallic 

shoe seal, measure the by the compliance date, 

distance the metallic shoe 

measure

measure

wall and primary seal 

inspect integrity of primary 

if a metallic shoe seal is 

used, measure vertical 

metallic shoe extends above 

a All measurements and inspections that must be performed annually must also be performed before the 

compliance date. b Make seal gap measurements according to the method described in §63.120(b)(2) through (b)(4) of subpart G. 

c When secondary seal is added, both the primary and secondary seals must be measured within 90 days and at 

the frequency specified for EFRs with primary and secondary seals [§63.120(b)(1)(iv)]. A secondary seal must 

be added when the vessel is emptied and degassed, or by June 23, 2009 at the latest. [§63.119(c)(1)(iv)] 

Note: Subpart MMM designates some different definitions and compliance dates than those used in §63.120 of 

subpart G. These differences are noted in “How do I show initial compliance with the storage vessel 

requirements” earlier in this chapter. 

If you think performing seal gap measurements and inspection of a vessel may be unsafe, then you may get an 

extension to perform the measurements and inspection or empty and remove the storage vessel from service 

[§63.120(b)(7)]. 

4-14
 
Subpart MMM also requires that you repair defects and other failures identified during 

inspections if you are using option 2. The types of conditions that you must repair and the time 

allowed for the repairs are as follows: 

When you are performing ... And you find that...	 Then, repair the condition ... 

visual inspection of the roof, 
 •	 the external floating roof has defects before refilling the storage 

seals, and fittings after 
 

emptying and degassing the 
 

storage vessel 
 

•	 the primary or secondary seal has holes, 

tears, or other openings in the seal or 

seal fabric 

vessel with organic HAP 

[§63.120(b)(10)(i)] 

•	 gaskets no longer close off the liquid 

surface from the atmosphere 

•	 the slotted membrane has more than 

10 percent open area 

seal gap measurement and 

visual inspection for all 

primary seals 

additional measurement for 

metallic shoe primary seals 

seal gap measurement and 

visual inspection for all 

secondary seals 

•	 

212 cm2 

•	 

•	 

(if used), seal fabric, or seal envelope 

end in the stored liquid and the other end 

liquid surface 

•	 

wall and secondary seal exceeds 2 

•	 

and secondary seal wider than 1.27 cm 

•	 

cover the space between the roof edge 

and the space between the vessel wall 

•	 

in the secondary seal or seal fabric 

(unless you get an extension) 

[§63.120(b)(8)] 

(unless you get an extension) 

[§63.120(b)(8)] 

(unless you get an extension) 

[§63.120(b)(8)] 

21.2 cm 

the total area of gaps between the vessel 

wall and primary seal exceeds 

/meter of vessel diameter 

there are gaps between the vessel wall 

and primary seal wider than 3.81 cm 

there are holes in the mechanical shoe 

the metallic shoe seal does not have one 

extending at least 61 cm above the stored 

the total area of gaps between the vessel 

/meter of vessel diameter 

there are gaps between the vessel wall 

the secondary seal does not completely 

there are holes, tears, or other openings 

within 45 days from the 

measurement or inspection 

within 45 days from the 

measurement or inspection 

within 45 days from the 

measurement or inspection 

Option 4: Vapor Balancing 

If you comply with option 4, you must monitor quarterly (using Method 21) the pressure relief 

valve on the storage vessel. If you obtain a reading of 500 ppmv or greater, you have a leak. 

You must repair leaks within 5 days after the leak is detected. [§63.1362(c)(6)(iv)] 

4-15
 
Option 5: Control Devices 

(A&B) Monitoring for percent reduction or outlet concentration 

The monitoring requirements for your storage vessel percent reduction and outlet concentration 

options are the same as the monitoring requirements for the process vent percent reduction and 

outlet concentration options and vary depending on the control device that you use. Table 3-2 in 

Chapter 3 summarizes the monitoring requirements for the percent reduction and outlet 

concentration options for various control devices [§63.1366(b)(1)]. 

(C) Monitoring for flares 

If you control storage vessel emissions with a flare, you must monitor the presence of the flame. 

Monitoring must be conducted at least once every 15 minutes. You must calibrate the 

monitoring device used to detect the presence of the pilot flame annually [§63.1366(b)(1)(vi)]. 

(E) Monitoring for the alternative standard 

If you choose to comply with the alternative standard, your monitoring requirements include all 

of the following: 

•	 monitor the outlet TOC and HCl/Cl2 concentration at least once every 15 minutes 

Note: You do not have to monitor the total HCl and Cl2 concentrations if you know that the emission stream 

does not contain HCl/Cl2 emissions [§63.1366(b)(5)]. 

•	 adjust the monitored concentrations per §63.1365(a)(7) to account for supplemental
 

gases, if any
 

Note: As an alternative to adjusting monitored concentrations to account for supplemental gases when 

using a combustion device, you may monitor residence time and firebox temperature. 

•	 use a TOC monitor that meets the requirements of Performance Specification 8 or 9 of 

appendix B of 40 CFR part 60 

•	 install, calibrate, maintain, and operate the monitors in accordance with §63.8 of the 

General Provisions 

(D) 	 Monitoring for boilers or process heaters 

You are not required to do any monitoring if you route storage vessel emissions through a 

process heater or boiler that meets the criteria for compliance option 5 (D) (see page 4-4). 

Note: If your process heater or boiler has a design heat input of <44 MW, or the vent streams are not
 
 

introduced with the primary fuel, you must comply with option 5A, 5B, or 5E.
 
 

4-16
 
What records must I keep for my storage vessels? 

Recordkeeping requirements are presented in Chapter 8. 

What reports must I submit for my storage vessels? 

General reporting requirements are presented in Chapter 8. Requirements specific to storage 

vessels are shown in this section. 

Depending on the compliance option you choose, the following notifications may be required: 

If you are You must notify the According to this section 

complying with ... And you do the following ... Administrator... of subpart G... 

Option 1, 2 or 3 	 refill your storage vessels after 30 daysa before §§63.120(a)(5) and 
 

visual inspection of the roof, seals, refilling your vessel (b)(10)(ii) 
 

and fittings each time the vessel is 
 

emptied and degassed 
 

Option 2 	 30 days before §63.120(b)(9) 
 


 


 

a 

For Options 1, 2, and 3

If you are According to this 

Then for ... section of the rule ... 

Option 1 or 3	 	 annual “external” •	 §63.122(d)(1) 
 

inspections during •	 
 

which you detect any •	 description of failure 
 

failures of the control •	 date of and description of repair 
 

•	 
 

applicable 

“internal” inspections •	 §63.122(d)(2) 
 

during which you •	 
 

detect any failures •	 description of the failure 
 

•	 date of and description of repair 

perform seal gap measurements 

performing the 

measurements 

If the inspection prior to refilling is unplanned, the notification may be made at least 7 days before refilling. 

 you must report the following in your periodic reports: 

complying with ... Include the following information ... 

date of inspection 

identification of storage vessel 

equipment date storage vessel was emptied, if 

date of inspection 

identification of storage vessel 

4-17 
If you are 

complying with ... Then for ... 

Option 2 	 seal gaps that exceed 

allowed limits and/or 

any defects or other 

seal failures that you 

detect during 

inspections conducted 

concurrently with the 

seal gap measurement 
 

According to this 

Include the following information ... section of the rule ... 

• date of seal gap measurement §63.122(e)(1) 
 

• raw data obtained in the 
 

measurement 
 

• calculation of total seal gap area 
 

• description of any failures 
 

• date of and description of repair (or 
 

date storage vessel was emptied) 
 

visual inspections of • §63.122(e)(3) 

• 

storage vessels during • description of the failure 

which you detect any • date of and description of repair 

defects or failures 

For Option 4 However, the offsite reloading and cleaning 

For Options 5 (A, B, C and E)

According to the following
 
 

section of the rule...
 
 

Notification of Compliance anticipated periods of planned routine §63.1368(f)(7) 
 

Status report 
 

Periodic reports 	 §63.1368(g)(2)(v) 
 

during the reporting period 
 

and 

anticipated periods of planned routine 

date of inspection 

empty and degassed identification of storage vessel 

, you have no reporting requirements. 

facility must provide both you and EPA a written certification that they will comply with the 

requirements of Subpart MMM. If they comply by venting emissions from the railcar or tank 

truck to a control device, then they must comply with all of the applicable reporting requirements 

in §63.1368 of Subpart MMM. If they vapor balance, no reporting is required. 

, you must also report the following: 

When submitting your... Include information on the ... 

maintenance 

actual periods of planned routine maintenance 

maintenance for the next reporting period 

4-18
 
 
Checklists for Inspection of Storage Vessels 

Facility Name: 
 

Facility Location:
 

Facility TRI ID #:
 

Inspector:
 

Date:
 

There are seven checklists for storage vessels. The table below explains which inspection 

checklists you should use for storage vessels. 

Then use the 

If you follow ... For a storage vessel with... 

following 

checklistsa ... 

Starting on 

page ... 

Option 1 a fixed roof and an internal floating roof 2 4-21 

Option 2 an external floating roof 3 4-25 

Option 3 an external floating roof converted to an 

internal floating roof 

4 

Option 4 vapor balancing 5 4-37 

Option 5(A or B) 

$95% by weight 

or reduces outlet concentrations #20 

6 

(also use checklists 

2 through 9, as 

applicable, in 

Chapter 3) 

4-39 

Option 5(C) a flare 6 

(and checklists 2 

and 10 in Chapter 3) 

4-39 

Option 5(E) 7 

4-32 

a closed-vent system and control device 

that reduces emissions 

ppmv 

emissions routed to a control device to 

meet the alternative standard 

4-40 

a Checklist 1 applies for all options. 

4-19 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 1: Applicability (All Options) 

Facility Name: 
 

Facility Location:
 

Facility TRI ID #:
 

Inspector:
 

Date:
 

Note: 

Comments 

1.	 G Yes G No 

vessel? §63.1361 

Note: If you answer “yes” to this question, proceed to
 


 

is not a storage vessel.
 

2.	 Is your storage vessel part of a PAI process unit? G Yes G No 

Note: If you answer “yes” to this question, proceed to
 


 

storage vessel is not part of the affected source.
 

3.	 Is your storage vessel a Group 1 storage vessel based on any 

one of the following: (1) 

•	 you designated the storage vessel as Group 1? G Yes G No 

•	 $75 m3

 and stores G Yes G No 

$3.45 kPa? 

•	 G Yes G No 

capacity $40 m3 

true vapor pressure $16.5 kPa? 

Note: If you answer “yes” to any of the items in this question,
 

your storage tank is subject to control requirements; proceed
 

to the applicable checklist for the compliance option you
 


 

question, do not proceed; you are exempt from control
 

requirements.
 

 Use this checklist to determine if your tanks or vessels are storage vessels, if your storage vessels are part 

of the affected source, and if storage vessels are subject to control requirements. 

Does your tank or vessel meet the definition of a storage 

question 2. If you answer “no,” do not continue; your vessel 

§63.1360(f) 

question 3. If you answer “no,” do not continue; your 

§63.1362(c) 

the storage vessel has a capacity 

material with a maximum true vapor pressure 

the storage vessel is at a new affected source, has a 

, and stores material with a maximum 

choose. If you answer “no” to all of the items in this 

4-20
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Facility Name: 
 

Facility Location:
 

Facility TRI ID #:
 

Inspector:
 

Date:
 

Note: 

A. Monitoring and Inspection Requirements 

(3) Comments 

Note:	 Questions 3-5 apply for all visual inspections. 

Questions 6-15 

degassed (i.e., “internal” visual inspections). 

1.	 

both of the following apply: (2) 

•	 G Yes G No 

•	 G Yes G No 

and at least once every 10 years? 

2.	 G Yes G No 

either of the following apply: (3) 

•	 
 


 


 


 

5 years, or
 

•	 
 


 


 


 


 


 

3.	 Does the floating roof float on the liquid surface? G Yes G No 

( (4) 


 

surface during initial filling, after the vessel has been
 

completely emptied and degassed, and when completely
 


 

leg supports, the process of filling, emptying, or refilling must
 

be continuous and completed as soon as possible.
 

Checklist 2: Requirements for a storage vessel with an internal floating roof (Option 1) 

 A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

§§63.119(b) and 63.120(a) as crossreferenced from §63.1365(d) 

The monitoring requirements include visual inspections. 

 apply only for visual inspections performed each time the vessel is emptied and 

If the storage vessel is equipped with a single-seal system, do 

§63.120(a) 

Do you perform an “external” visual inspection of the IFR 

and seal at least once every 12 months? 

Do you perform an “internal” visual inspection of the IFR, 

the seal, gaskets, slotted membranes, and sleeve seals (if 

any) each time the storage vessel is emptied and degassed, 

If the storage vessel is equipped with a double-seal system, do 

§63.120(a) 

Do you perform an “internal” visual inspection of the IFR, 

the primary seal, the secondary seal, gaskets, slotted 

membranes, and sleeve seals (if any) each time the storage 

vessel is emptied and degassed, and at least once every 

Do you perform an “external” visual inspection of the IFR 

and the secondary seal at least once every 12 months, and 

do you perform an “internal” visual inspection of the IFR, 

the primary seal, the secondary seal, gaskets, slotted 

membranes, and sleeve seals (if any) each time the vessel is 

emptied and degassed, and at least once every 10 years? 

§§63.119(b) 1) and (2) and 63.120(a) 

Note: The roof is not required to be floating on the liquid 

emptied before being refilled. When the roof is resting on the 

4-21
 
 
Checklist 2: (cont’d)
 
 

Requirements for a storage vessel with an internal floating roof (Option 1)
 
 

A. Monitoring and Inspection Requirements 

(3) Comments 

§§63.119(b) and 63.120(a) as crossreferenced from §63.1365(d) 

4.	 	 Is the IFR in good condition (i.e., free of defects such as G Yes G No 

corrosion or pools of standing liquid)? §63.120(a) 4) and (7) ( 

5.	 Inspect the seal(s). ( 

•	 	 G Yes G No 

•	 G Yes G No 

openings? 

•	 G Yes G No 

storage vessel (i.e., no visible gaps between the seal and 

wall)? 

6.	 G Yes G No 

seal, or a double seala? (3) 

7.	 Inspect deck openings 

•	 If the IFR is non-contact, do the openings in the IFR project G Yes G No 

b? (5)(i) 

•	 G Yes G No 

drains)b? (5)(ii) 

•	 G Yes G No 

access)? (6) 

•	 G Yes G No 

fastened air-tight when closed? (6) 

•	 Do gaskets on IFR opening covers close off the liquid G Yes G No 

(7) 

8.	 

•	 G Yes G No 

being floated off or landed on the roof leg supports)? 

(4) 

•	 b 	 G Yes G No 

(5)(iv) 

•	 G Yes G No 

(7) 

§63.120(a) 4) and (7) 

Is the seal attached to the IFR? 

Is the seal or seal fabric free of holes, tears, or other 

Does the seal make continuous contact with the wall of the 

Is the IFR equipped with a liquid-mounted seal, metallic shoe 

§63.119(b) 

below the stored liquid surface (except automatic bleeder 

and rim space vents) §63.119(b) 

Is each opening in the IFR equipped with a gasketed cover 

(except leg sleeves, automatic bleeder vents, rim space 

vents, column wells, ladder wells, sample wells, and stub 

§63.119(b) 

Is each cover on an IFR opening closed (unless open for 

§63.119(b) 

Are covers on each access hatch and automatic gauge float 

§63.119(b) 

surface from the atmosphere? §63.120(a) 

Inspect automatic bleeder vents 

Are the automatic bleeder vents closed (unless the roof is 

§63.119(b) 

Are the automatic bleeder vents gasketed? 

§63.119(b) 

Do the gaskets close off the liquid surface from the 

atmosphere? §63.120(a) 

4-22
 
 
Checklist 2: (cont’d)
 
 

Requirements for a storage vessel with an internal floating roof (Option 1)
 
 

A. Monitoring and Inspection Requirements 

(3) Comments 

§§63.119(b) and 63.120(a) as crossreferenced from §63.1365(d) 

9.	 Inspect rim space vents 

•	 Are the rim space vents closed (except when either the roof G Yes G No 

is being floated off the roof leg supports, or the pressure 

beneath the rim seal exceeds the manufacturer’s 

recommended setting)? §63.119(a)(6) 

•	 Are the rim space vents gasketed? §63.119(b)(5)(v) G Yes G No 

•	 Do the gaskets close off the liquid surface from the G Yes G No 

atmosphere? §63.120(a)(7) 

10.	 G Yes G No 

90 percent of the opening?b (5)(iii) and 

(7) 

11.	 Does each ladder well have a gasketed sliding cover?b G Yes G No 

(5)(vi) 

12.	 G Yes G No 

flexible fabric sleeve seal or gasketed sliding cover?b 

(5)(vii) 

13.	 G Yes G No 

(7) 

l4.	 G Yes G No 

(7) 

15.	 G Yes G No 

the storage vessel? (7) 

B. §§ 63.122 and 63.123 as cross 

( (2)(xii) Comments 

Note: 

1.	 Did you record the occurrence of each visual inspection? G Yes G No 

2.	 (1) G Yes G No 

3.	 

(1)( (ii) 

•	 	 G Yes G No 

•	 G Yes G No 

Does each sample well have a slit fabric cover over at least 

§63.119(b) 

§63.120(a) 

§63.119(b) 

Does each column well supporting the fixed roof have either a 

§63.119(b) 

Do ladder and column well gaskets close off the liquid surface 

to the atmosphere? §63.120(a) 

If flexible fabric sleeve seals are used for column wells, are the 

fabric sleeves free of defects such as holes, tears, or gaps? 

§63.120(a) 

If repairs were needed, did you complete them before refilling 

§63.120(a) 

Recordkeeping and Reporting Requirements 

referenced by §§ 63.1367(b) 11) and 63.1368(g) 

There are reporting and recordkeeping requirements for visual inspections. 

§63.123(c) 

Do you maintain all records for 5 years? §63.1367(a) 

If you detect a failure during an inspection, do you submit all 

of the following information in your periodic report: 

§63.122(d) ii) and (2) 

date of the inspection? 

identification of all storage vessels with failures? 

4-23 
 
Checklist 2: (cont’d)
 
 

Requirements for a storage vessel with an internal floating roof (Option 1)
 
 

B. §§ 63.122 and 63.123 as cross 

( (2)(xii) Comments 

Recordkeeping and Reporting Requirements 

referenced by §§ 63.1367(b) 11) and 63.1368(g) 

•	 description of the failures? 	 G Yes G No 

•	 either the date and nature of repairs made or the date the G Yes G No 
 

vessel was emptied (if the vessel was not already empty)? 
 

4.	 
 


 


 


 

( (1)(iii) 

•	 	 G Yes G No 

•	 description of the failure? 	 G Yes G No 

•	 G Yes G No 
 

unavailable? 
 

•	 G Yes G No 
 

vessel as soon as possible? 
 

•	 G Yes G No 
 


 

5.	 	 G Yes G No 
 


 

at least 30 days before the vessel was refilled (7 days if the 
 

inspection was unplanned and could not be foreseen 30 days 
 

before refilling)? ( 
 

If your periodic report in “3” shows that you made a repair 

more than 45 days after the failure was found, does your next 

periodic report include documentation of the use of up to two 

30-day extensions and the following information: 

§§63.120(a) 4) and 63.122(d)

identification of the storage vessel? 

documentation that alternate storage capacity was 

schedule of actions taken to make repairs or empty the 

date the storage vessel was emptied and nature of and date 

repair was made? 

If you refilled a storage vessel after it was emptied and 

degassed, did you submit a report notifying the Administrator 

§63.120(a) 5) and (6) 

a If the internal floating roof is equipped, as of November 10, 1997, with a single vapor-mounted seal, then the 

requirement for a liquid-mounted seal, metallic shoe seal, or dual-seal does not apply until the earlier of the 

following dates: (1) the next time the storage vessel is emptied and degassed, or (2) June 23, 2009. b If the IFR did not meet these specifications as of November 10, 1997, the requirement to meet these specifications 

does not apply until the earlier of the following dates: (1) the next time the storage vessel is emptied and degassed, 

or (2) no later than June 23, 2009. 

4-24
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Facility Name: 
 

Facility Location:
 

Facility TRI ID #:
 

Inspector:
 

Date:
 

Note: 	 

A. Monitoring and Inspection Requirements 

(3) Comments 

Note:	 For a dual-seal 

1.	 Does the EFR float on the surface of the stored liquid? G Yes G No 

(3) ) 


 

surface during initial filling, after the vessel has been
 

completely emptied and degassed, and when completely
 


 

leg supports, the process of filling, emptying, and refilling must
 

be continuous and completed as soon as possible.
 

2.	 Is the EFR in good condition (i.e., free of defects such as G Yes G No 

corrosion and pools of standing liquid)? (10)(i) 

3.	 

•	 G Yes G No 

EFR? (6)(i) 

•	 G Yes G No 

openings? (6)(ii) 

•	 Are any gaps between the seal and the wall of the storage
 

vessel less than both of the following: (4)
 

<	 The total area of the gaps is less than 21.2 cm2 G Yes G No 

<	 G Yes G No 

Checklist 3: Requirements for a storage vessel with an external floating roof (Option 2) 

A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate 

“N/A” in the comments column. 

§§63.119(c) and 63.120(b) as crossreferenced from §63.1365(d) 

The monitoring requirements include visual inspections and seal gap measurements. 

system, the secondary seal inspection and gap measurement (questions 3 and 5 through 7) occurs 

annually. Primary seal inspections and gap measurements (questions 4 through 7), and “comprehensive” 

inspections (questions 8 through 16) occur at least every 5 years and every time the storage vessel is 

empty and degassed. For a single-seal system (i.e., an option until 2009 at the latest), the primary seal 

inspection and gap measurement occurs annually, question 3 does not apply, and a “comprehensive” 

inspection is required when the storage vessel is empty and degassed. 

§63.119(c) and (4 

Note: The roof is not required to be floating on the liquid 

emptied before being refilled. When the roof is resting on the 

§63.120(b) 

Inspect the secondary seal and perform seal gap measurements. 

Is the seal continuously attached along the edge of the 

§63.120(b) 

Is the seal and seal fabric free of holes, tears, or other 

§63.120(b) 

§63.120(b)

 per meter 

of vessel diameter? 

The maximum gap width between the vessel wall and 

the seal does not exceed 1.27 cm? 

4-25
 
 
Checklist 3: (cont’d)
 
 


 
 

A. Monitoring and Inspection Requirements 

(3) Comments 

•	 G Yes 

the secondary seal at least once per year? 

(1)(iii) 

mounted or metallic shoe primary seal with no secondary seal, 

you are not required to install a secondary seal until either the 

next time the storage vessel is emptied and degassed or June 

23, 2009, whichever is earlier. 

Requirements for a storage vessel with an external floating roof (Option 2)

§§63.119(c) and 63.120(b) as crossreferenced from §63.1365(d) 

Do you measure the seal gap between the vessel wall and 

§63.120(b)

Note: If, as of November 11, 1997, your EFR has a liquidG No 

4. Inspect the primary seal and perform seal gap measurements. 

•	 Is the primary seal either a metallic shoe or liquid-mounted G Yes G No 

seal? §63.119(c)(1)(ii) 

Note: If your EFR is equipped with a vapor-mounted 
 

primary seal and a secondary seal as of November 11, 
 

1997, then you are not required to install a metallic shoe or 
 

liquid-mounted primary seal until the next time the storage 
 

vessel is emptied and degassed or June 23, 2009, whichever 
 

is earlier. 
 

•	 Does the primary seal form a continuous closure that 
 

completely covers the space between the vessel wall and 
 

EFR such that: §63.120(b)(3) 
 

<	 	 The total area of the gaps is less than 212 cm2 per meter G Yes G No 

of vessel diameter? 

<	 The maximum gap width between the vessel wall and G Yes G No 

the seal does not exceed 3.81 cm? 

•	 Is the seal fabric, seal envelope, or shoe (if a metallic shoe G Yes G No 

seal is used) free of holes, tears, or other openings? 

§63.120(b)(5)(ii) 

•	 	 If the primary seal is a metallic shoe seal: 

<	 	 Does the lower end of the metallic shoe extend into the G Yes G No 

stored liquid? §63.120(b)(5)(i) 

<	 	 Does the upper end of the metallic shoe seal extend a G Yes G No 

minimum vertical distance of 61 cm above the liquid 

surface? §63.120(b)(5)(i) 

<	 Is there a flexible coated fabric that spans the space G Yes G No 

between the metal shoe and the vessel wall? 

•	 If the primary seal is a liquid-mounted seal, is the seal in G Yes G No 

contact with the liquid between the storage vessel wall and 

EFR? definition of liquid-mounted seal in §63.111 

4-26 
 
Checklist 3: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof (Option 2)
 
 

A. Monitoring and Inspection Requirements 

(3) Comments 

§§63.119(c) and 63.120(b) as crossreferenced from §63.1365(d) 

•	 Do you measure the seal gap between the vessel wall and G Yes G No 
 

the primary seal at least every 5 years? §63.120(b)(1)(i) 
 

Note: If your EFR does not have a secondary seal, 

§63.120(b)(1)(ii) specifies the seal gap measurements for 

the primary seal must be once per year. 

5.	 	 
 

apply: 
 

•	 G Yes G No 
 

supports)? (2)(i) 
 

•	 G Yes G No 
 

c inch) 
 


 

the seal? (2)(ii) 
 

•	 G Yes G No 
 


 

(2)(iii) 

6.	 	 G Yes G No 
 

(7) 
 

•	 
 
 


 
 

or 

•	 
 
 


 
 


 

provided you explain why it was unsafe to perform the seal gap
 

measurement or inspection, document that alternate storage
 

capacity is unavailable, and specify a schedule to ensure that
 

the vessel is emptied as soon as practical
 

7.	 	 G Yes G No 

concurrent inspection indicate a failure? (8) 

8.	 	 G Yes G No 

degassed? (10) 

When you measure the seal gaps, if any, do all of the following 

Is the EFR floating (i.e., not resting on the roof leg 

§63.120(b)

Do you measure around the entire circumference of the 

vessel in each place where a 0.32 centimeter (

diameter uniform probe passes freely between the wall and 

§63.120(b)

Do you determine the total surface area of each gap using 

probes of various widths to measure the gap accurately? 

§63.120(b)

If you determine that it is unsafe to perform the seal gap 

measurements, do either of the following apply: §63.120(b)

Do you measure the gaps no later than 30 days after the

determination?

Do you remove the vessel from service within 45 days after

the determination?

Note: You may use up to 2 extensions of the 45-day limit

Do you either repair the seals or empty the storage vessel no 

later than 45 days after the seal gap measurements or 

§63.120(b)

Do you visually inspect the EFR, the primary seal, the 

secondary seal, and fittings each time the vessel is emptied and 

§63.120(b)

4-27
 

Checklist 3: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof (Option 2)
 
 

A. Monitoring and Inspection Requirements 

(3) Comments 

§§63.119(c) and 63.120(b) as crossreferenced from §63.1365(d) 

9. Inspect deck openings. 

•	 If the EFR is non-contact, do the openings in the EFR G Yes G No 
 

project below the stored liquid surface (except automatic 
 

bleeder and rim space vents)? §63.119(c)(2)(i) 
 

Note: If these openings did not provide projections below
 
 

the liquid surface as of November 11, 1997, you are not
 
 

required to comply with this requirement until the next time
 
 

the storage vessel is emptied and degassed or June 23,
 
 

2009, whichever is earlier.
 
 

•	 Is each opening in the EFR equipped with a gasketed cover G Yes G No 
 

that forms a vapor-tight seal (except automatic bleeder 
 

vents, rim space vents, roof drains, and leg sleeves)? 
 

§63.119(c)(2)(ii) 

•	 Is each gasketed cover on any EFR opening closed (unless G Yes G No 
 

open for access)? 
 

•	 Are covers on each access hatch and gauge float well G Yes G No 
 

fastened air-tight when closed? §63.119(c)(2)(iii) 
 

•	 Do gaskets on EFR opening covers close off the liquid G Yes G No 
 

surface from the atmosphere? §63.120(b)(10)(i) 
 

10. 

•	 G Yes G No 
 

being floated off or landed on the roof leg supports)? 
 

(2)(iii) 

•	 G Yes G No 

(2)(v) 

•	 G Yes G No 
 

(10)(i) 
 

11. 

•	 G Yes G No 
 

being floated off the roof leg supports, or the pressure 
 


 

(2)(iv) 
 

•	 (2)(v) G Yes G No 

•	 G Yes G No 
 

(10)(i) 
 

Inspect automatic bleeder vents. 

Are the automatic bleeder vents closed (unless the roof is 

§63.119(c)

Are the automatic bleeder vents gasketed? 

§63.119(c)

Do the gaskets close off the liquid surface from the 

atmosphere? §63.120(b)

Inspect rim space vents. 

Are the rim space vents closed (except when the roof is 

beneath the rim seal exceeds the manufacturer’s 

recommended setting)? §63.119(c)

Are the rim space vents gasketed? §63.119(c)

Do the gaskets close off the liquid surface from the 

atmosphere? §63.120(b)

4-28
 

Checklist 3: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof (Option 2)
 
 

A. Monitoring and Inspection Requirements 

(3) Comments 

§§63.119(c) and 63.120(b) as crossreferenced from §63.1365(d) 

12.	 	 Is each roof drain covered with a slotted membrane fabric that G Yes G No 

covers at least 90 percent of the opening area? 

§63.119(c)(2)(vi) 

13.	 Is each slotted or unslotted guide pole well equipped with G Yes G No 

either a gasketed sliding cover or a flexible fabric sleeve seal 

(2)( 

14.	 Does each unslotted guide pole have on its end a closed G Yes G No 

(2)(viii) 

15.	 Does each slotted guide pole have a gasketed float inside the G Yes G No 

guide pole or other control device that closes off the liquid 

(2)(x) 

16.	 G Yes G No 

(except when open for access)? (2)(xi) 

B. §§ 63.122 and 63.123 as cross-

( (2)(xii) Comments 

1.	 G Yes G No 

(1)( 

2.	 

following: 

• 	 G Yes G No 

• 	 G Yes G No 

• 	 G Yes G No 

3.	 G Yes G No 

inspection? 

4.	 (1) G Yes G No 

5.	 G Yes G No 

(9) 

that closes off the liquid surface from the atmosphere? 

§63.119(c) vii) and (ix) 

gasketed cap that closes off the liquid surface from the 

atmosphere (except when gauging the liquid level or taking 

liquid samples)? §63.119(c) 

surface from the atmosphere? §63.119(c) 

Does each gauge hatch and sample well have a closed gasketed 

cover that closes off the liquid surface from the atmosphere 

§63.119(c)

 Recordkeeping and Reporting Requirements 

referenced by §§ 63.1367(b) 11) and 63.1368(g) 

Do your records indicate that you made seal gap measurements 

and performed a concurrent visual inspection annually for the 

secondary seal and every 5 years for the primary seal? 

§63.120(b) i) and (iii) 

For all seal gap measurements, did you record all of the 

§63.123(d) 

the date of the seal gap measurement? 

the raw data obtained? 

calculations performed? 

Did you record the occurrence of each “comprehensive” visual 

Do you maintain records for 5 years? §63.1367(a) 

Did you notify the Administrator at least 30 days before each 

seal gap measurement? §63.120(b) 

4-29
 
Checklist 3: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof (Option 2)
 
 

B. §§ 63.122 and 63.123 as cross-

( (2)(xii) Comments 

 Recordkeeping and Reporting Requirements 

referenced by §§ 63.1367(b) 11) and 63.1368(g) 

6.	 	 If you detected a failure in the seals during the seal gap 
 

measurement or concurrent visual inspection, did you include 
 

the following in your periodic report: §63.122(e)(1) 
 

•	 the date of the inspection or measurement? 	 	 G Yes G No 

•	 the raw data obtained during the seal gap measurement? G Yes G No 

•	 calculations of the total gap area? 	 	 G Yes G No 

•	 a description of any failure? 	 	 G Yes G No 

•	 the date and nature of the repair or the date the vessel was G Yes G No 
 

emptied? 
 

7.	 
 


 


 


 

( (2) 

•	 	 G Yes G No 

•	 description of the failure? 	 G Yes G No 

•	 G Yes G No 
 

unavailable? 
 

•	 G Yes G No 
 

vessel as soon as possible? 
 

•	 G Yes G No 
 


 

8.	 
 


 

inspection in your periodic report: (3)(ii) 
 

•	 	 G Yes G No 

•	 G Yes G No 

•	 description of the failures? 	 G Yes G No 

•	 	 G Yes G No 

9.	 G Yes G No 
 


 

before the vessel was refilled (7 days if the inspection was 
 

unplanned and could not be foreseen 30 days before refilling)? 
 

(10)(

If your periodic report in “6” shows that you made a repair 

more than 45 days after the failure was found, does your next 

periodic report include documentation of the use of up to two 

30-day extensions and the following information: 

§63.120(b) 8) and §63.122(e)

identification of the storage vessel? 

documentation that alternate storage capacity was 

schedule of actions taken to make repairs or empty the 

date the storage vessel was emptied and nature of and date 

repair was made? 

If you detected a failure during a “comprehensive” visual 

inspection, did you submit the following information about the 

§63.122(e)

date of the inspection? 

identification of all storage vessels with failures? 

date and nature of repair? 

Before refilling an empty and degassed storage vessel, did you 

submit a report to notify the Administrator at least 30 days 

§63.120(b) ii) and (iii) 

4-30 
Checklist 3: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof (Option 2)
 
 

B. §§ 63.122 and 63.123 as cross-

( (2)(xii) Comments 

 Recordkeeping and Reporting Requirements 

referenced by §§ 63.1367(b) 11) and 63.1368(g) 

10.	 	 If you did not empty and remove a storage vessel from service 

within 45 days after determining that it was unsafe to perform 

the seal gap measurement and concurrent inspection of the 

seals, does your next periodic report include the following 

documentation for up to two 30-day extensions: 

§§63.120(b)(7)(ii) and 63.122(e)(2) 

•	 identification of the storage vessel? 	 G Yes G No 

•	 explanation of why it is unsafe to perform the seal gap G Yes G No 

measurements? 

•	 documentation that alternate storage capacity was G Yes G No 

unavailable? 

•	 a schedule of actions taken to make repairs or empty the G Yes G No 

vessel as soon as practical? 

•	 date the storage vessel was emptied and nature of and date G Yes G No 

repair was made? 

4-31
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Facility Name: 
 

Facility Location:
 

Facility TRI ID #:
 

Inspector:
 

Date:
 

Note:	 	 

A. Monitoring and Inspection Requirements ) 

(3) Comments 

Note:	 	 

Questions 3-5 apply to all inspections. Questions 6-15

1.	 	 

both of the following apply: (2) 

•	 G Yes G No 
 


 

•	 G Yes G No 
 


 


 

and degassed, and at least once every 10 years? 
 

2.	 	 G Yes G No 

either of the following apply: (3) 

•	 
 
 


 
 


 
 


 
 

every 5 years, or
 
 

•	 
 
 

floating deck and the secondary seal at least once every 12
 
 


 
 


 
 


 
 


 
 

every 10 years?
 
 

Checklist 4: Requirements for a storage vessel with an external floating roof converted to an 

internal floating roof (Option 3) 

A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate 

“N/A” in the comments column. 

 §§63.119(b) and (c and 63.120(a) as 

cross-referenced from §63.1365(d) 

The monitoring requirements include visual inspections and measurements. 

 apply only for visual inspections performed each 

time the vessel is emptied and degassed (i.e., “internal” visual inspections). 

If the storage vessel is equipped with a single-seal system, do 

§63.120(a)

Do you perform an “external” visual inspection of the 

floating deck and seal at least once every 12 months? 

Do you perform an “internal” visual inspection of the 

floating deck, the seal, gaskets, slotted membranes, and 

sleeve seals (if any) each time the storage vessel is emptied 

If the storage vessel is equipped with a double-seal system, do 

§63.120(a)

Do you perform an “internal”visual inspection of the

floating deck, the primary seal, the secondary seal, gaskets,

slotted membranes, and sleeve seals (if any) each time the

storage vessel is emptied and degassed, and at least once

Do you perform an “external” visual inspection of the

months, and do you perform an “internal” visual inspection

of the floating deck, the primary seal, the secondary seal,

gaskets, slotted membranes, and sleeve seals (if any) each

time the vessel is emptied and degassed, and at least once

4-32
 
 
Checklist 4: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof converted to an internal floating
 
 

roof (Option 3)
 
 

A. Monitoring and Inspection Requirements ) 

(3) Comments 

 §§63.119(b) and (c and 63.120(a) as 

cross-referenced from §63.1365(d) 

3.	 	 Does the floating deck float on the liquid surface? 

§§63.119(b)(1) and (2) and 63.120(a)(4) 

Note: The roof is not required to be floating on the liquid
 

surface during initial filling, after the vessel has been
 

completely emptied and degassed, and when completely
 

emptied before being refilled. When the floating roof is resting
 

on the leg supports, the process of filling, emptying, and
 

refilling must be continuous and completed as soon as
 

possible.
 

G Yes G No 

4.	 	 Is the floating deck in good condition (i.e., free of defects such G Yes G No 

as corrosion or pools of standing liquid)? (

(7) 

5.	 	 Inspect the seal(s). (

•	 	 G Yes G No 

•	 G Yes G No 

openings? 

•	 G Yes G No 

storage vessel (i.e., no visible gaps between the seal and 

wall)? 

6.	 	 G Yes G No 

(3) 


 

single vapor-mounted seal, then you are not required to
 

comply with this provision until the next time the storage vessel
 

is emptied and degassed or June 23, 2009, whichever is
 

earlier.
 

7.	 	 Inspect deck openings. 

•	 If the floating deck is non-contact, do the openings in the G Yes G No 

floating deck project below the stored liquid surface (except 

(2)(i) 

the liquid surface as of November 11, 1997, you are not 

required to comply with this provision until the next time 

the storage vessel is emptied and degassed or June 23, 

2009, whichever is earlier. 

 §63.120(a) 4) and 

§63.120(a) 4) and (7) 

Is the seal attached to the floating deck? 

Is the seal or seal fabric free of holes, tears, or other 

Does the seal make continuous contact with the wall of the 

Is the floating deck equipped with a liquid-mounted seal, 

metallic shoe seal, or a double seal? §63.119(b)

Note: If the IFR is equipped, as of November 11, 1997, with a

automatic bleeder and rim space vents)? §63.119(c)

Note: If these openings did not provide projections below 

4-33 
Checklist 4: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof converted to an internal floating
 
 

roof (Option 3)
 
 

A. Monitoring and Inspection Requirements ) 

(3) Comments 

 §§63.119(b) and (c and 63.120(a) as 

cross-referenced from §63.1365(d) 

•	 Is each opening in the floating deck equipped with a G Yes G No 

gasketed cover that forms a vapor-tight seal (except 

automatic bleeder vents, rim space vents, roof drains, and 

leg sleeves)? §63.119(c)(2)(ii) 

•	 Is each gasketed cover on any deck opening closed (unless G Yes G No 

open for access)? §63.119(c)(2)(ii) 

•	 Are covers on each access hatch and gauge float well G Yes G No 

fastened air-tight when closed? §63.119(c)(2)(ii) 

•	 Do gaskets on deck opening covers close off the liquid G Yes G No 

surface from the atmosphere? §63.120(a)(7) 

8. 	 	 Inspect automatic bleeder vents. 

•	 Are the automatic bleeder vents closed (unless the roof is G Yes G No 

being floated off or landed on the roof leg supports)? 

§63.119(c)(2)(iii) 

•	 Are the automatic bleeder vents gasketed? 	 G Yes G No 

§63.119(c)(2)(v) 

•	 Do the gaskets close off the liquid surface from the G Yes G No 

atmosphere? §63.120(a)(7) 

9.	 	 Inspect rim space vents. 

•	 Are the rim space vents closed (except when either the roof G Yes G No 

is being floated off the roof leg supports, or the pressure 

beneath the rim seal exceeds the manufacturer’s 

recommended setting)? §63.119(c)(2)(iv) 

•	 Are the rim space vents gasketed? §63.119(c)(2)(v) G Yes G No 

•	 Do the gaskets close off the liquid surface from the G Yes G No 

atmosphere? §63.120(a)(7) 

10.	 Is each roof drain covered with a slotted membrane fabric that G Yes G No 

covers at least 90 percent of the opening area? 

§63.119(c)(2)(vi) 

11.	 	 Is each slotted or unslotted guide pole well equipped with G Yes G No 

either a gasketed sliding cover or a flexible fabric sleeve seal 

that closes off the liquid surface from the atmosphere? 

§63.119(c)(2)(vii) and (ix) 

4-34 
Checklist 4: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof converted to an internal floating
 
 

roof (Option 3)
 
 

A. Monitoring and Inspection Requirements ) 

(3) Comments 

 §§63.119(b) and (c and 63.120(a) as 

cross-referenced from §63.1365(d) 

12.	 	 Does each unslotted guide pole have on its end a closed G Yes G No 

gasketed cap that closes off the liquid surface from the 

atmosphere (except when gauging the liquid level or taking 

liquid samples)? §63.119(c)(2)(viii) 

13.	 	 Does each slotted guide pole have a gasketed float inside the G Yes G No 

guide pole or other control device that closes off the liquid 

(2)(x) 

14.	 	 G Yes G No 

(except when open for access)? (2)(xi) 

15.	 	 G Yes G No 

inspections before refilling the storage vessel? (7) 

B. §§ 63.122 and 63.123 as cross 

( (2)(xii) Comments 

Note: 

1.	 Did you record the occurrence of each visual inspection? G Yes G No 

2.	 (1) G Yes G No 

3.	 

(1)( (ii) 

•	 	 G Yes G No 

•	 G Yes G No 

•	 description of the failures? 	 G Yes G No 

•	 G Yes G No 

4.	 

( (1)(iii) 

•	 	 G Yes G No 

•	 description of the failure? 	 G Yes G No 

•	 G Yes G No 

unavailable? 

surface from the atmosphere? §63.119(c)

Does each gauge hatch and sample well have a closed gasketed 

cover that closes off the liquid surface from the atmosphere 

§63.119(c)

Did you complete any repairs of failures detected during 

§63.120(a)

Recordkeeping and Reporting Requirements 

referenced by §§ 63.1367(b) 11) and 63.1368(g) 

There are reporting and recordkeeping requirements for visual inspections. 

§63.123(e) 

Do you maintain all records for 5 years? §63.1367(a)

If you detected a failure during an inspection, did you submit 

the following information in your periodic report: 

§63.122(d) ii) and (2)

date of the inspection? 

identification of all storage vessels with failures? 

either the date and nature of repairs made or the date the 

vessel was emptied (if the vessel was not already empty)? 

If your periodic report in “3” shows that you made a repair 

more than 45 days after the failure was found, does your next 

periodic report include documentation of the use of up to two 

30-day extensions and the following information: 

§§63.120(a) 4) and 63.122(d)

identification of the storage vessel? 

documentation that alternate storage capacity was 

4-35
 

Checklist 4: (cont’d)
 
 

Requirements for a storage vessel with an external floating roof converted to an internal floating
 
 

roof (Option 3)
 
 

B. §§ 63.122 and 63.123 as cross 

( (2)(xii) Comments 

Recordkeeping and Reporting Requirements 

referenced by §§ 63.1367(b) 11) and 63.1368(g) 

•	 schedule of actions taken to make repairs or empty the G Yes G No 

vessel as soon as possible? 

•	 date the storage vessel was emptied and nature of and date G Yes G No 

repair was made? 

5.	 	 G Yes G No 

at least 30 days before the vessel was refilled (7 days if the 

inspection was unplanned and could not be foreseen 30 days 

before refilling)? (

If you refilled a storage vessel after it was emptied and 

degassed, did you submit a report notifying the Administrator 

§63.120(a) 5) and (6) 

4-36
 
 
_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

Facility Name: 
 

Facility Location:
 

Facility TRI ID #:
 

Inspector:
 

Date:
 

Note: 	 

A. Comments 

1.	 G Yes G No 

(6)(iii) 

2.	 Is the pressure relief device on the storage vessel set to $2.5 G Yes G No 

psig? (6)(v) 

3.	 G Yes G No 

Method 21 of 40 CFR, part 60, appendix A? 

(6)(v)(A) 

B. Comments 

1.	 Do you have records that the tank trucks and/or railcars from G Yes G No 

(8) 

2.	 For each pressure relief device leak, do you have records of all 

of the following: (8) 

•	 G Yes G No 

• G Yes G No 

• G Yes G No 

•	 G Yes G No 

•	 G Yes G No 

•	 G Yes G No 

•	 G Yes G No 

the leak is repaired? 

3.	 G Yes G No 

and/or clean tank trucks and railcars that they will either reduce 

the HAP content of displaced vapor by $

(6)(vii)(A) 

4.	 (1) G Yes G No 

Checklist 5: Requirements for a storage vessels using vapor balancing (Option 4) 

A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate 

“N/A” in the comments column. 

Monitoring Requirements 

When a storage vessel is filled from a tank truck or railcar, is a 

vapor collection system connected between them? 

§63.1362(c) 

§63.1362(c) 

Is the pressure relief device monitored quarterly for leaks using 

§63.1362(c) 

Recordkeeping and Reporting Requirements 

which the storage vessel is filled meet U.S. DOT pressure 

requirements in 49 CFR part 180 or 173.31, respectively? 

§63.1367(b) 

§§63.1367(b) 

the instrument identification number? 

the equipment identification number? 

operator name, initials, or identification number? 

date leak was detected? 

date of first repair attempt? 

date of successful repair? 

maximum instrument reading measured by Method 21 after 

Do you have written certification from facilities that reload 

90 percent (and meet 

compliance requirements in Subpart MMM) or vapor balance 

to the tank from which the tank truck or rail car is loaded? 

§63.1362(c) 

Do you maintain records for 5 years? §63.1367(a) 

4-37 
 

_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: 	 	 

A. Comments 

1. G Yes G No 

(5) 

B. Comments 

1.	 	 Do you keep records of periods of planned routine G Yes G No 

(6)(viii) 

2.	 	 G Yes G No 

(2)(v) 

•	 G Yes G No 

during the reporting period? 

•	 G Yes G No 

next reporting period? 

3.	 

(5) 

•	 G Yes G No 

contained both of the following: 

<	 an explanation of why the extension is needed? G Yes G No 

<	 G Yes G No 

exceeded and the date the control device is returned to 

service? 

•	 G Yes G No 

Checklist 6: Requirements for a storage vessel meeting the requirements for a closed-vent 

system and add-on control device (Options 5A, 5B, and 5C) 

A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate 

“N/A” in the comments column. 

Monitoring Requirements 

Was the control device operational at all times except during 

periods of planned routine maintenance? §63.1362(c)

Recordkeeping and Reporting Requirements 

maintenance? §63.1367(b)

Do you submit both of the following in your periodic reports? 

§63.1368(g)

records of actual periods of planned routine maintenance 

anticipated periods of planned routine maintenance for the 

Do both of the following apply each time periods of planned 

routine maintenance exceed 240 hr/yr: §63.1362(c)

you submit an application to the Administrator requesting 

approval of an extension to no more than 360 hr/yr that 

a statement affirming that no material will be added to 

the storage vessel between the time the 240 hr limit is 

you submit the application at least 60 days before the 240 

hr/yr limit is exceeded? 

4-38
 
 
_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

_______________________________________________________________ 

Facility Name: 
 

Facility Location:
 

Facility TRI ID #:
 

Inspector:
 

Date:
 

Note: 	 

A. Comments 

1.	 G Yes G No 

(5) 

2.	 G Yes G No 

3.	 

following: ( (5)(ii) 

•	 2 G Yes G No 

•	 G Yes G No 

4.	 

following: ( (5)(ii) 

•	 2 G Yes G No 

concentrations to 3 percent oxygen? 

•	 G Yes G No 

5.	 Is the CEMS data reduced to operating day averages? G Yes G No 

( 

6.	 G Yes G No 

a flow indicator at the inlet or outlet of the control device, and 

do you use it to identify periods of no flow? 

(2)(iii) 

7.	 G Yes G No 

(5) 

Checklist 7: Requirements for a storage vessel meeting the alternative standard (Option 5E) 

A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. Only question 7 in section A and questions 8 

through 10 in section B of this checklist apply if you have already used checklists 2 and 12 in chapter 3 

for process vents that are controlled with the same control device. If the requirement is not applicable, 

indicate “N/A” in the comments column. 

Monitoring Requirements 

Did you install a CEMS to monitor and record the outlet TOC 

concentration at least once every 15 minutes? §63.1366(b) 

If you are using a combustion control device that generates 

HCl, did you install a CMS to monitor and record the outlet 

HCl concentration at least once every 15 minutes? 

If you introduce supplemental gases to the emission stream 

before a noncombustion device, do you perform both of the 

§§63.1365(a) 7) and 63.1366(b) 

adjust the monitored outlet TOC and/or HCl/Cl 

concentrations to account for the supplemental gases? 

evaluate the volumetric flow rate of all gas streams each 

time a new operating scenario is implemented? 

If you introduce supplemental gases to the emission stream 

before a combustion device, do you perform either of the 

§§63.1365(a) 7) and 63.1366(b) 

adjust the monitored outlet TOC and/or HCl/Cl 

monitor residence time and firebox temperature? 

§63.1366(b) 2) and (8) 

If flow to the control device can be intermittent, did you install 

§63.1366(b) 

Was the control device operational at all times except during 

periods of planned routine maintenance? §63.1362(c) 

4-39
 
 
Checklist 7: (cont’d)
 
 

Requirements for a storage vessel meeting the alternative standard (Option 5E)
 
 

B. Recordkeeping and Reporting Requirements Comments

1. 	 Do you have a written quality control program with protocols G Yes G No 

for various operations, including calibration procedures for the 

monitor? §63.8(d) 

2. 	 

(3) 

3. 	 Do you have records of: ( ( (14) 

• 	 

data recorded during unavoidable CEMS breakdowns and 

out-of-control periods)? 

• 	 

inoperative except for zero (low-level) and high-level 

checks? 

• 	 

control (e.g., calibration drift exceeds specification, CEMS 

fails cylinder gas audit)? 

• 	 

• 	 

known), and corrective actions taken? 

• 	 

period? 

• 	 All procedures, including calibrations, that are part of your 

4. 	 Do you have records indicating that you notified the 

evaluation of your CEMS? (2) 

5. 	 Did you include in your periodic report a description of the 

period? (6)( (2)(v) 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G No 

G No 

G No 

G No 

G No 

G No 

G No 

G No 

G No 

G No 

Have your recorded all maintenance and calibration checks 

performed on the CEMS? §63.1367(b) 

§§63.1367(a) 4) and 63.10(c) 1)-

All required CEMS measurements (including monitoring 

The date and time of each period when the CEMS is 

The date and time of each period when the CEMS is out of 

The date and start and end time of each period of excess 

emissions and parameter monitoring exceedances occurring 

during startups, shutdowns, malfunctions, and at other 

times? 

The nature and cause of any malfunction of your monitor (if 

The total process operating time during the reporting 

quality control program? 

Administrator at least 60 days before conducting a performance 

§§63.1368(d) and 63.8(e) 

routine maintenance planned for the control device for the next 

reporting period and actually performed in the last reporting 

§§63.1367(b) viii) and 63.1368(g) 

4-40
 

Checklist 7: (cont’d)
 
 

Requirements for a storage vessel meeting the alternative standard (Option 5E)
 
 

B. Recordkeeping and Reporting Requirements Comments

6.	 	 Do you submit all of the following in your periodic reports if 
 

exceedances or excursions are $1 percent of the total operating 
 

time during the reporting period: §63.1368(g)(2) 
 

•	 all monitoring data for all operating days or operating G Yes G No 
 

blocks when the average TOC or HCl/Cl2 concentration 
 

exceeds 20 ppmv for combustion control devices or 50 
 

ppmv for noncombustion control devices? 
 

•	 identification of all operating days when insufficient G Yes G No 
 

monitoring data are collected? 
 

7.	 (1) G Yes G No 
 

8.	 G Yes G No 
 

(6)(viii) 
 

9.	 
 

(2)(v) 

•	 G Yes G No 
 

the reporting period? 
 

•	 G Yes G No 
 

next reporting period? 
 

10.	 
 

(5) 
 

•	 
 
 


 
 

contained both of the following:
 
 

<	 an explanation of why the extension is needed? G Yes G No 

<	 G Yes G No 
 


 

exceeded and the date the storage vessel is returned to 
 

service? 
 

•	 G Yes G No 
 


 

Do you maintain records for 5 years? §63.1367(a)

Do you keep records of periods (i.e., date and time) of planned 

routine maintenance? §63.1367(b)

Do you submit both of the following in your periodic reports: 

§63.1368(g)

records of actual periods of planned routine maintenance for 

anticipated periods of planned routine maintenance for the 

Do all of the following apply each time periods of planned 

routine maintenance exceed 240 hr/yr: §§63.1362(c)

you submit an application to the Administrator requesting

approval of an extension to no more than 360 hr/yr that

a statement affirming that no material will be added to 

the storage vessel between the time the 240 hr limit is 

you submit the application at least 60 days before the 240 

hr/yr limit is exceeded? 

4-41
 
 
[This page intentionally left blank.] 
Chapter 5 - Complying with requirements for wastewater systems 

What wastewater streams are subject to Subpart MMM? 

Subpart MMM applies to “Group 1” wastewater streams that are discarded from a PAI process 

unit that is at an affected source. A “Group 1” wastewater stream is any wastewater stream that 

meets either of the following conditions: [§63.1361] 

•	 Is generated from a PAI process, or a scrubber used to control emissions from a PAI 

process, and contains either: 

<	 	 an annual average concentration of Table 9 compounds of at least 5 ppmw and has an 

average flow rate of 0.02 L/min or greater; or 

Note: Table 9 compounds are compounds listed on Table 9 of subpart G of the HON. 

<	 a total concentration of Table 9 compounds of at least 10,000 ppmw at any flow rate. 

•	 Is generated from a PAI process unit as a result of maintenance activities and contains at 

least 5.3 Mg of Table 9 HAP per individual discharge event. 

Residuals removed from a Group 1 wastewater stream are also subject to Subpart MMM. 

Definition. Residual means any liquid or solid material containing Table 9 

compounds that is removed from a wastewater stream by a waste management 

unit or treatment process that does not destroy organics. 

What types of wastewater components are subject to Subpart MMM? 

Subpart MMM applies to all of the following components of wastewater systems; these 

components are called waste management units: 

•	 wastewater tanks
 
 

Definition. Waste management unit means the
 
 • 	 surface impoundments 	 equipment, structure(s), and/or device(s) used to convey, 

• 	 containers 	 store, treat, or dispose of wastewater streams or residuals. 

• 	 individual drain systems 

• 	 oil-water separators 

Note: treatment processes are a subset of waste management units that remove or destroy the organics in a 

wastewater. 

5-1
 
Subpart MMM also applies to heat exchange systems (see the section “What are my compliance 

options for heat exchange systems?” beginning on page 5-30 for additional information). 

Definition. Heat exchange system 

What wastewater streams are exempt? 

MMM: [§§63.132(a)(3) and 63.1360(d)(4)] 

• 

Group 1 wastewater stream 

• 

• 

• 

• 

• 

• 

• 

(2)] 

•	 

• 	 

flow rate and annual average 

concentration of Table 9 HAP 

representative of actual or anticipated operation of the PAI process unit over a designated 12­

period. 

means any cooling tower system or once-through cooling 

water system (e.g., river or pond water). A heat exchange system can include more than one 

heat exchanger and can include an entire recirculating or once-through cooling system. 

Any wastewater stream that meets any of the following conditions is not subject to Subpart 

Group 2 wastewater streams 

Note: A Group 2 wastewater stream is any wastewater stream that does not meet the definition of a 

wastewater streams that are not part of a PAI process unit 

laundry water 

stormwater from segregated sewers 

water from fire-fighting and deluge systems, including testing of such systems 

spills 

water from safety showers 

noncontact steam boiler blowdown and condensate 

How do I identify a Group 1 wastewater stream? 

You identify Group 1 wastewater streams in either of the following ways: [§63.144(a)(1) and 

designate the streams as Group 1 

If you designate the stream as Group 1, you do not have determine the wastewater stream to do any measurements or calculations. 

To determine the annual average flowrate and annual average concentration, both values must be 

month period. 

The annual average concentration is the total mass of Table 9 compounds 

present in the wastewater stream during the designated 12-month period 

divided by the total mass of the wastewater stream in the same 12-month 

5-2
 
 
You may base the concentration on any of the following: [§63.144(b)] 

•	 process knowledge 

•	 bench scale or pilot scale test data The POD means the point at which a wastewater 

•	 test data from sampling at the point of stream exists the PAI process unit. [§63.1361]
 

determination (POD) or at a location
 

downstream of the POD
 

Note: You may determine the concentration either at the POD or downstream from the POD. If you 

determine the concentration downstream of the POD, you must also make adjustments to account for 

changes (e.g., dilution) caused by combining the Group 1 stream with other streams. 

You may base the flowrate on any of the following: [§63.144(c)] 

•	 knowledge of the wastewater stream 

and/or process	 If you determine or estimate the total volume of 

wastewater, divide by 525,000 minutes to determine 

•	 historical records the annual average flowrate. 

•	 measurement of the flowrate 

Note: You may determine the flowrate either at the POD or downstream from the POD. If you determine the 

flowrate downstream of the POD, you must also make adjustments like those described above for concentration. 

What are my compliance options for wastewater systems? 

You must meet all of the following for Group 1 wastewater streams: 

•	 emission suppression compliance options 

•	 air pollution control device compliance options for vented emissions from covered and 

enclosed waste management units 

• treatment compliance options 

You must meet any of the following for residuals: [§63.138(k)] 

•	 recycle it to a process 

•	 sell it for the purposes of recycling 

•	 return it to the treatment unit 

•	 treat it to reduce the Table 9 HAP by $99 percent 

•	 treat in a RCRA unit 

5-3 
What are my emission suppression compliance options? 

Emission suppression options are techniques for minimizing HAP emissions before the 

wastewater reaches a treatment unit. You have several emission suppression compliance options 

for each type of waste management unit. These options are the same for both existing and new 

sources. 

Note: The only exemption from the emission suppression requirements is for waste management units that are 

also biological treatment units and meet specified requirements for HAP degradation. See the discussion of 

treatment options T3G and T3H in the sections “What treatment compliance options do I have?” beginning on 

page 5-10 and “How do I show initial compliance with the treatment compliance requirements?” beginning on 

page 5-13. [§63.138(a)(3)] 

Wastewater tanks 

If your wastewater tank receives, manages, or treats a Group 1 wastewater stream or residual, 

you have three compliance options if your wastewater tank meets any of the following: 

[§63.133(a)] 

Definition. Wastewater tank means a stationary waste management unit that is designed to 

contain an accumulation of wastewater and residuals and is constructed primarily of nonearthen 

materials which provide structural support. Wastewater tanks used for flow equalization are 

included in this definition. 

•	 tank size $151 m3

 storing wastewater with maximum true vapor pressure $5.2 kPa 

•	 tank size $75 m3

 and <151 m3 storing wastewater with maximum true vapor pressure 

$13.1 kPa 

•	 tanks of any size storing any Group 1 wastewater stream or residual if the tank is used for 

any of the following: 

< heating wastewater 

< treating by means of an exothermic reaction
 

< sparging
 

Your three compliance options for these wastewater tanks are: 

Option WT1: Use a fixed roof and control device [§63.133(a)(2)(i)]. 

Use a fixed roof and a closed-vent system that routes HAP vapors to control device. 

Option WT2: Use a fixed roof and an internal floating roof [§63.133(a)(2)(ii)] 

5-4 
Option WT3: Use an external floating roof [§63.133(a)(2)(iii)]
 

For all other wastewater tanks that receive, manage, or treat a Group 1 wastewater stream, you
 

have four compliance options available. You may comply using option WT1, WT2, or WT3 as
 

described above, or you may comply using:
 

Option WT4: Use a fixed roof [§63.133(a)(1)]
 

Use a fixed roof tank, which may be vented to the atmosphere. 

Surface impoundments 

If your surface impoundment receives, manages, or treats a Group 1 wastewater stream or 

residual, you have two compliance options: 

Definition. Surface impoundment means a waste management unit which is a natural topographic 

depression, manmade excavation, or diked area formed primarily of earthen materials (although it 

may be lined with manmade materials), which is designed to hold an accumulation of liquid wastes 

or waste containing free liquids. A surface impoundment is used for the purpose of treatment, 

storing, or disposing of wastewater or residuals, and is not an injection well. Examples of surface 

impoundments are equalization, settling, and aeration pits, ponds, and lagoons. 

Option S1: Use a cover and control device [§63.134(b)(1)] 

Install a vented cover (e.g., an air supported structure or rigid cover) and a closed vent 

system that routes HAP vapors to an air pollution control device. Keep access hatches, 

sampling ports, and other openings in the cover closed at all times except when it is 

necessary to use the opening for sampling, removal, or for equipment inspection, 

maintenance, or repair. For more information about control device requirements, see “What 

are my compliance options for air pollution control devices?” later in this chapter (page 5-9). 

Option S2: Use a floating flexible membrane cover [§63.134(b)(2)] 

Use a floating flexible cover that meets all of the following design and operational criteria: 

•	 it is designed to float on the liquid surface and form a continuous barrier over the entire 

surface of the liquid 

• 	 is constructed from either: 

<	 	 high density polyethylene (HDPE) that is at least 2.5 millimeters thick 

<	 	 a material or a composite of different materials that have both organic permeability 

properties that are equivalent to those of HDPE and chemical and physical properties 

such that it will last for its intended service life 

5-5
 
•	 it has no visible cracks, holes, gaps, or other open spaces between cover section seams or 

between the edge of the cover and its foundation mountings 

•	 each opening in the cover has a closure device (e.g., an access hatch) that is free of 

visible cracks and other open spaces between the edge of the opening in the cover and the 

closure device; §63.134(b)(2)(vi) specifies factors to consider in selecting suitable 

materials for closure devices 

•	 closure devices are secured in the closed position except when allowed to be open as 

specified in §63.134(b)(2)(vii) 

•	 drains for emergency removal of stormwater are allowed in the cover; these drains must 

have either of the following: 

<	 	 a slotted membrane fabric cover that covers at least 90 percent of the area of the 

opening 

<	 	 a flexible fabric sleeve seal 

Containers 

If your container receives, manages, or treats a Group 1 wastewater stream or residual, you must 

operate and maintain a cover on the container. Other compliance requirements vary depending 

on the size of the container and whether you treat wastewater in the container. 

Definition. Container 

and ships. 

If you treat wastewater in the container, 
 3 
 

$ 0.42 	 No C1 

Yes 	 

No 

Yes 	 

< 0.42 (but >0.1) 

 means any portable waste management unit that has a capacity greater than or 

equal to 0.1 cubic meters in which a material is stored, transported, treated, or otherwise handled. 

Examples of containers are drums, barrels, tank trucks, barges, dumpsters, tank cars, dump trucks, 

Your compliance options for containers are summarized in the following table: 

Capacity of the container, m must it remain open during treatment? Compliance options 

C1 and C3 

C1 or C2 

C3 and either C1 or C2 

5-6 
 
Option C1: Use a cover and inspect for leaks [§63.135(b)(1), (b)(2)(ii), and (b)(3)] 

Operate and maintain a cover, keep the cover and all openings closed except when in use, 

and inspect for leaks. In addition, when you pump a Group 1 wastewater stream into a 

container that has a capacity of at least 0.42 m3

, you must use a submerged fill pipe that 

meets design criteria specified in §63.135(c)(1). See “What monitoring must I do to 

comply with the emission suppression requirements for waste management units?” later 

in this chapter (page 5-22) for more information about the inspection requirements. 

Option C2: Use a cover on containers that meet Department of Transportation 

(DOT) specifications [§63.135(b)(2)(i) and (b)(3)] 

Use a container that meets DOT specifications and testing requirements under 40 CFR 

part 178. Keep the cover and all openings closed except when in use. 

Option C3: Use an enclosure [§63.135(d)] 

If you treat a Group 1 wastewater stream or residual in a container that must remain open 

during treatment, then you must place the container inside an enclosure that has a closed 

vent system to transport organic vapors to a control device. You also must comply with 

either option C1 or C2. See “What are my compliance options for air pollution control 

devices?” later in this chapter (page 5-9) for more information about the requirements for 

control devices. 

Individual drain systems 

If your individual drain system (IDS) receives or manages a Group 1 wastewater stream, then 

you have two compliance options. 

Definition. Individual drain system means the system used to convey wastewater streams or 

residuals to a waste management unit or to discharge or disposal. The term includes: hard piping; all 

process drains and junction boxes; and associated sewer lines, other junction boxes, manholes, 

sumps, and lift stations conveying wastewater streams or residuals. 

Your compliance options for individual drain systems are as follows: 

Option D1: Cover each opening [§63.136(b)] 

Use covers on each opening in the drain system that are designed and operated as follows: 

•	 if the cover is vented, route vapors to a process or through a closed vent system to a 

control device 

5-7
 
 
• 	 keep covers and openings in the covers closed at all times except when necessary to use 

the openings 

[§63.136(e)] 

for the according to 

following part this section of 

of an IDSa ... and if... the rule... 

an individual using either a: §63.136(e)(1) 

drain • wastewater discharge pipe to the drain or the 

• 	 tightly fitting cap or shield around the drain as specified in 

plug §63.136(e)(1)(ii) 

a junction box using a tightly fitting §63.136(e)(2) 

solid cover 	 to a process or transport the vapors through a 

(note that 

if the junction box is filled and emptied by gravity 

flow or it operates with only slight variations in 

liquid level, then venting to the atmosphere is 

allowed if the system is designed as specified in 

(2)(ii)) 

sewer lines 	 keeping covered or N/A §63.136(e)(3) 

enclosed without visible 

gaps or other openings 

See “What are my compliance options for air pollution control devices?” beginning on page 5-9 for 

more information about the requirements for control devices. 

Option D2: Use specified techniques for various parts of the drain system 

Use emission suppression techniques as described in the following table: 

you must suppress 

emissions by... 

you use a water seal, you must design the 

water seal 

your cover is vented, you must route the vapors 

closed vent system to a control device 

§63.136(e) 

to the atmosphere 

a A segregated stormwater sewer system, which is a drain and collection system that you designed and operate for 

the sole purpose of collecting rainfall runoff, is exempt from the requirements for individual drain systems under 

subpart MMM. 

Oil-water separators 

A waste management unit that separates and removes oils, scum, and solids from the wastewater 

by gravity. Most of the separation occurs as the wastewater stream passes through a quiescent 

zone in the unit where oils and scum with specific gravities less than water float to the top of the 

aqueous phase, while heavier solids sink to the bottom. Some of the organic compounds 

contained in the wastewater will partition to the oil phase and then can be removed with the 

skimmed oil, leaving the separated water. 

If your oil-water separator receives, manages, or treats a Group 1 wastewater stream or residual, 

then you have three compliance options: 

5-8
 
Option O1: Use a fixed roof and control device §63.137(a)(1) 

Use a fixed roof and transport organic vapors through a closed-vent system to a control 

device. See “What are my compliance options for air pollution control devices?” below 

on this page for more information about the requirements for control devices. 

Option O2: Use a floating roof §63.137(a)(2) 

Use a floating roof that meets the requirements specified in 40 CFR part 60, subpart 

QQQ §§60.693-2(a)(1)(i), (a)(1)(ii), (a)(2), (a)(3), and (a)(4). 

Note: For those parts of an oil-water separator where you cannot use a floating roof (e.g., over the weir 

mechanism), you must comply with option O1. 

Option O3: Use an equivalent means of reduction §63.137(a)(3) 

You may submit an application requesting approval of an alternative means of reduction 

that is equivalent to the reduction that would be achieved by Option O1 or Option O2. 

Note: You application must include either actual emission test data or an engineering evaluation 

[§63.137(a)(3)(i) and (ii)] 

What are my compliance options for air pollution control devices? 

If you comply with an emission suppression compliance option for waste management units, 

including waste management units that are treatment units, that includes vented covers or 

enclosures, you have five compliance options for the vented emission streams: 

Option A1: Percent reduction [§63.139(c)(1)(i), (2), (4), and (5)] 

Reduce vented organic HAP emissions by $95 percent. 

Option A2: Outlet concentration limit [§§63.139(c)(1)(ii), (2), (4), and (5), and 

63.1362(d)(13)] 

Reduce vented organic HAP emissions to #20 ppmv as TOC. If you combine the emission 

streams with supplemental gases before a vapor recovery system, you must adjust the 

measured HAP concentration to account for the dilution caused by the supplemental gases. 

If you combine the emission stream with supplemental gases prior to a combustion device, 

you must calculate the concentration at 3 percent oxygen. 

Note: This option is not allowed for emissions from surface impoundments and containers if you use a 

noncombustion device. 

5-9
 
Option A3: Specified enclosed combustion device [§63.139(b)(1)(iii)] 

Use an enclosed combustion device that provides a minimum residence time of 0.5 seconds 

at a minimum temperature of 760°C. 

Option A4: Use a flare [§63.139(b)(3)] 

Use a flare that meets the requirements of §63.11(b) (subpart A General Provisions) to 

control organic HAP emissions. 

Option A5: Specified exempted devices [§63.139(d)(4)] 

Use any of the following devices that are exempt from initial compliance, monitoring, 

recordkeeping, and reporting requirements under Subpart MMM: 

• 	 A boiler or process heater burning hazardous waste for which you have: 

<	 	 been issued a final permit for the boiler or process heater under 40 CFR part 270 and 

are complying with the requirements of Subpart H in 40 CFR part 266 

<	 certified compliance with the interim status requirements of Subpart H in 40 CFR part 

266 

• 	 A hazardous waste incinerator for which you have: 

<	 	 been issued a final permit for the incinerator under 40 CFR part 270 and you are 

complying with the requirements of Subpart O in 40 CFR part 264 

<	 certified compliance with the interim status requirements of Subpart O in 40 CFR part 

265 

• 	 A boiler or process heater with a design heat input $44 MW 

•	 A boiler or process heater for which the emission stream is introduced with the primary 

fuel 

What treatment compliance options do I have for my wastewater 

streams? 

Treatment units are techniques that remove or destroy the organics in a wastewater stream. 

Subpart MMM includes several compliance options and specifies how treatment units may be 

used to achieve compliance with one or more of the compliance options. The compliance 

options may be used individually or in combination to achieve the required emission control. 

For all existing sources and most new sources, you have four treatment compliance options for 

wastewater streams: 

5-10
 
Option T1: Reduce outlet concentration to less than 50 ppmw [§63.138(b)(1)] 

Use a treatment unit that discharges HAP at less than 50 ppmw. 

Note: You cannot use biological treatment units or dilution with this option. 

Option T2: Use a design steam stripper [§63.138(d)] 

Use a steam stripper that meets the following specific design and operating requirements: 

•	 minimum active column height of 5 meters 

•	 countercurrent flow configuration with a minimum of 10 

actual trays 

•	 

•	 
 


 

• 

• 
 

[§63.138(e), (f), and (g)] 

For 
 

option... 
 

T3A Group 1 99% 
 

T3B Group 1 weighted average Fr value 
 

T3C 99% 
 

T3D Group 1 weighted average Fr value 
 

T3E Group 1 
 

biological) 
 

T3F Group 1 and Group 2 
 

T3G open or closed biological Group 1 
 

T3H open or closed biological Group 1 and Group 2 
 

You are exempt from initial 

minimum steam flow rate of 0.04 kg/liter of wastewater compliance demonstration 

feed to the column requirements for option T2. 

minimum wastewater feed temperature of 95°C, or 

minimum column temperature of 95°C 

maximum liquid loading of 67,100 liters/hr/m2

operate at atmospheric pressure 

Option T3: Mass reduction 

You have the following eight mass reduction options that vary in their required reductions 

depending on the type of treatment unit you use, the types of wastewater streams that you 

treat, and the specific compliance level: 

You may use the following type of You must reduce the HAP 

treatment unit... in the following streams... By this amount... 

noncombustion, nonbiological 

noncombustion, nonbiological 

combustion Group 1 

combustion 

noncombustion (including closed required mass removal 

closed biological 95% required mass removal 

required mass removal 

95% required mass removal 

5-11
 
If you comply with option T3A or T3C, your treatment unit must reduce the mass of total Table 
 


9 HAP that it receives by at least 99 percent. Generally, this would be a good option to use if the 
 


treatment unit is used only for Group 1 streams that contain HAP with fraction removal (Fr) 
 


values of 0.99. Note that these options are not allowed for biological treatment units. 
 


If you comply with option T3B or T3D, your 
 


treatment unit must achieve an overall Table 9 HAP The Fr values are specified in Table 9 of 
 


mass reduction that is equal to or greater than the subpart G. These values are equivalent to the 
 


mass percentage reduction that would be weighted average of the Fr values for the HAP in the achieved using the design steam stripper.
 
 wastewater stream. For example, if your Group 1
 
 

wastewater stream has one HAP with an Fr value of
 
 

0.99 and an equal amount of a second HAP with an Fr value of 0.95, then your treatment unit 

must achieve an overall reduction of at least 97 percent (see “How do I show initial compliance 

with the treatment compliance options” beginning on page 5-13 for more information). You 

might want to choose one of these options if you treat only Group 1 streams, the HAP in your 

wastewater stream have different Fr values, and you cannot achieve an overall 99 percent 

reduction. These options also are not allowed for biological treatment units. 

To comply with option T3E, you must 

determine the required mass removal The required mass removal is the hourly mass of Table 

(RMR) for each of your Group 1 streams. 9 HAP that must be removed or destroyed in the 

treatment unit. It is determined using weighted average Your treatment unit must then have an Fr values for the Table 9 HAP in the wastewater stream

actual mass removal (AMR) rate that meets (see “How do I show initial compliance with the 

or exceeds the sum of the RMR’s for treatment compliance options” for more information). 

wastewater streams that will be combined 

for treatment. This option may be 

advantageous if you treat both Group 1 and Group 2 streams because the Table 9 HAP in your 

Group 2 streams can contribute to the total mass reduction. This means that the percentage 

reduction achieved by the treatment unit can be lower than for the percentage reduction options. 

Also note that this option is available for biological treatment units only if they are closed units. 

Option T3F is similar to option T3E, except that required mass removal is specified as 95%, it is 

only allowed for closed biological treatment units, and the required mass removal must be 

applied to both the Group 2 and Group 1 streams that are combined for treatment in the 

biological unit. Options T3G and T3H are similar to options T3E and T3F, except that the 

compliance procedures are designed specifically for open biological treatment units. 

Option T4: Use a RCRA unit [§63.138(h)] 

Treat the wastewater in a permitted
 

Resource Conservation and Recovery Act You are exempt from initial compliance
 
 

(RCRA) hazardous waste incinerator, a requirements, monitoring, and associated
 
 

RCRA permitted process heater or boiler, recordkeeping and reporting requirements under 
 

or discharge to a properly permitted Subpart MMM if you comply with option T4. 
 

underground injection well. 

5-12 
For new sources, you have the same four options described above, except you must comply with 

either option T3A, T3B, or T4 if the total mass flow rate of HAP in wastewater from the affected 

source is 2,100 Mg/yr or more. 

Instead of treating the wastewater yourself, you may transfer it to someone else for treatment. 

Whoever agrees to treat the wastewater must comply with the requirements in subpart MMM. 

You must also meet all of the following if you decide to transfer the wastewater to someone else 

for treatment: 

•	 comply with the emission suppression and control device options prior to transfer 

•	 include a notice with the shipment of each Group 1 wastewater stream or residual (or 

each time there is a change in the required treatment) stating that the stream contains 

HAP that are to be controlled as specified in subpart MMM 

•	 obtain written certification from the treatment facility stating that they will comply with 

subpart MMM 

Note: If the wastewater stream contains <50 ppmw of partially soluble HAP, the offsite facility does not 

have to comply with the emission suppression requirements (i.e., covers on waste management units prior 

to the activated sludge unit) if the treatment is performed in a biological treatment unit, and you 

demonstrate that <5 percent of the soluble HAP is emitted prior to the activated sludge unit. See Tables 2 

and 3 to subpart MMM for listings of partially soluble HAP and soluble HAP, respectively. 

[§63.1362(d)(14)] 

How do I show initial compliance with the emission suppression 

compliance requirements? 

You must conduct an initial inspection of waste management units and closed-vent systems that 

transport emissions to control devices. These inspections are identical to inspections that must 

be performed periodically to demonstrate ongoing compliance. To avoid repetition, inspection 

requirements are summarized in “What monitoring must I do to comply with the emission 

suppression requirements for waste management units?” (page 5-22). 

How do I show initial compliance with the treatment compliance 

requirements? 

You must conduct either a design evaluation or a performance test to demonstrate initial 

compliance with treatment compliance Option T1 and all versions of Option T3. 

General Requirements for Performance Tests 

To demonstrate compliance using a performance test, you must meet all of the following: 

[§63.145(a)] 

5-13
 
•	 demonstrate compliance under “representative” conditions for the process(es) 

•	 demonstrate compliance when the treatment unit is operating at representative inlet 

flowrate and concentration 

•	 collect and analyze wastewater samples using the test methods and procedures specified 

in §§63.144(b)(5)(i) through (iii) and 63.1365(b)(8) 

•	 take concentration and flow measurements at the same time 

•	 a test consists of at least 3 test runs, each for a 1-hour period; take samples at
 
 

approximately equally-spaced time intervals over each 1-hour period
 
 

For a performance test of a biological treatment process (Options T3E, T3F, T3G, and T3H), 

you may consider the inlet to the equalization tank to be the inlet to the treatment process if you 

meet all of the following: 

•	 wastewater is conveyed by hard-piping from either the previous treatment process or the 

POD to the equalization tank 

•	 wastewater is conveyed by hard-piping from the equalization tank to the biological 

treatment process (i.e., there are no waste management units between the equalization 

tank and the biological process unit) 

•	 the equalization tank has a fixed roof with a closed vent system transports emissions to 

an air pollution control device 

Specific Performance Test Requirements for Treatment Compliance Options 

Specific requirements for performance tests that you use to demonstrate initial compliance with 

option T1 or any variation of option T3 are specified in §63.145 and summarized in Table 5-1. 

For the mass reduction compliance options, the procedures described in Table 5-1 are for either a 

single treatment unit or a series of treatment units that are connected by hard-piping (i.e., when 

you determine flow rate and concentrations for the treatment unit, the inlet is prior to the first 

treatment unit in the series, and the outlet is the exit from the last treatment unit in the series). 

If you use a series of treatment processes that are not connected by hard-piping, then you must 

apply the procedures in the table to each individual treatment unit in the series and sum the 

resulting reductions from each unit to determine if you are in compliance. 

Note: You do not have to sum the mass reductions from all of the units if each unit is designed to remove 

different HAP. For example, suppose wastewater streams that contain both toluene and methanol are sent to a 

series of treatment units where the first unit removes a mass of toluene that exceeds the Fr value for toluene, 

and the second unit removes a mass of methanol that exceeds the Fr value for methanol. In this case, you can 

do calculations around just the first unit to demonstrate compliance for toluene, and around just the second 

device for methanol. 

5-14
 
TABLE 5-1. Performance Testing Requirements for Treatment Units 

You have demonstrated 

For option... For each test run, determine the... And calculate the... compliance if..

T1 concentration of Table 9 HAP at the average concentration of Table 9 HAP at the outlet of the sum of the 

(noncombustion outlet of the treatment unit the treatment unit over all of the test runs HAP averaged 

and the 3 runs is <5nonbiological ppmw 

treatment units) 

5-15
 

T3A • • the calculated p

$99 

and nonbiological 

• wastewater flowrate entering and 

a 

) 

• 

percent 

T3B • • the calculated p

and nonbiological 

• wastewater flowrate entering and 

a 

) 

• 

or equal to the weighted avera

• the Fr values 

T3C • • the calculated 

destruction effi

unit ) is $99 percent 

• wastewater flowrate entering the • • ) 

• 

unit for Table 9 HAP 

• 

Table 9 HAP concentrations at inlet average mass flow rate of Table 9 HAP entering 

(noncombustion and exit of the treatment unit and exiting the treatment unit over all of the test removal is 

exiting the treatment unit 

runs (use equations WW1 and WW2 

percent removal 

treatment units) 

Table 9 HAP concentrations at inlet average mass flow rate of Table 9 HAP entering 

(noncombustion and exit of the treatment unit and exiting the treatment unit over all of the test removal is grea

exiting the treatment unit 

runs (use equations WW1 and WW2 

percent removal in the treatment unit 

treatment units) flow-weighted average of the Fr values for the 

Table 9 HAP entering the treatment unit (use equation WW8) 

Table 9 HAP concentration in average mass flow rate of Table 9 HAP entering 

(combustion wastewater entering the combustion the combustion treatment unit over all of the test 

treatment units) runs (use equation WW4 

average mass flow rate of Table 9 HAP exiting the 

combustion unit combustion treatment unit in the vented gas stream 

Table 9 HAP concentration in the (use equation WW6 

vented gas stream exiting the destruction efficiency of the combustion treatment combustion unit 

volumetric flowrate of the vented gas 

stream exiting the combustion unit 
TABLE 5-1. (cont’d) 

You have 

For option... And calculate the... 

demonstrated 

For each test run, determine the... compliance if..

T3D 

(combustion 

• Table 9 HAP concentration in 

wastewater entering the combustion 

• average mass flow rate of Table 9 HAP entering 

the combustion treatment unit over all of the test 

the calculated destruction effi

treatment units) 

• 

unit 

Table 9 HAP concentration in the • 

runs (use equation WW4 )

average mass flow rate of Table 9 HAP exiting the 

is greater than oto the flow-wei

vented gas stream exiting the combustion unit ) 

combustion treatment unit in the vented gas stream over all of the test runs (use equation WW6 

average of the Fvalues 

• volumetric flowrate entering the 

combustion treatment unit 

• flow-weighted average of the Fr values for the 

Table 9 HAP entering the combustion treatment 

• volumetric flowrate of the vented gas 

stream exiting the combustion unit • 

unit (use equation WW8) 

destruction efficiency of the combustion treatment 

unit for Table 9 HAP 

5-16
 T3E • • the AMR for th

and closed PODb the HAP Fr values) greater than or 

biological • • 

RMR’s for the 

• 

b 

• 

that are treated 

• 

a 

) 

• 

Table 9 HAP concentration in each RMR for each Group 1 wastewater stream over all 

(noncombustion Group 1 wastewater stream at its of the test runs (use equation WW9, which requires treatment unit i

Table 9 HAP concentration at the inlet sum of the RMR values for all of the Group 1 to the sum of th

treatment units) and outlet of the treatment unit wastewater streams 

flowrate of each Group 1 wastewater 

stream at its POD 

average mass flowrate of Table 9 HAP entering 

and exiting the treatment unit over all of the test 

1 wastewater st

flowrate of wastewater at inlet and 

outlet of the treatment unit 

runs (use equations WW1 and WW2 

difference between the average mass flowrates of 

treatment unit 

Table 9 HAP entering and exiting the treatment unit (this is the actual mass removal [AMR]) 
TABLE 5-1. (cont’d) 

You have 

For option... And calculate the... 

demonstrated 

For each test run, determine the... compliance if..

T3F (closed • Table 9 HAP concentration in each • RMR for each Group 1 and Group 2 wastewater biological 

treatment units) 

Group 1 and Group 2 wastewater

stream at its POD b stream (use equation WW9a; note that the RMR is 95 percent of the mass of HAP in each wastewater 

• 

b flowrate of each Group 1 and Group 2 wastewater stream at its POD • stream) sum of the RMR values for all of the Group 1 and 

• Table 9 HAP concentration at the inlet Group 2 wastewater streams 

and outlet of the treatment unit • average mass flowrate of Table 9 HAP entering 

• 

a 

flowrate of wastewater at inlet and 

outlet of the treatment unit ) 

and exiting the treatment unit over all of the test runs (use equations WW1 and WW2 

• difference between the average mass flowrates of 

Table 9 HAP entering and exiting the treatment 

unit (this is the AMR) 

the AMR for thclosed biologic

treatment unit igreater than the of the RMR’s fof the Group 1 Group 2 wastewstreams that are 

treated in the cl

biological treat

unit 

5-17
 T3G (open or • • the AMR for th

closed biological 

c PODb requires the HAP Fr values) unit is greater t

• 

b 

• 

RMR’s for Gro

• • fraction of Table 9 HAP biodegraded in the 

treated in the 

• 

a 

§63.145(h) and appendix C to 40 CFR part 63) 

• unit 

) 

• 

unit by the average fraction biodegraded)d 

Table 9 HAP concentration in each RMR for each Group 1 wastewater stream over all 

treatment units) 

Group 1 wastewater stream at its of the test runs (use equation WW11, which biological treat

flowrate of each Group 1 wastewater 

stream at its POD 

sum of the RMR values for all of the Group 1 

wastewater streams 

equal to the sum 

Table 9 HAP concentration at the inlet wastewater stre

and outlet of the treatment unit treatment unit (determined using procedures in 

flowrate of wastewater at inlet and 

outlet of the treatment unit average HAP mass flow rate entering the 

biological treat

biological treatment unit over all of the test runs (use equation WW1 

AMR for the biological treatment unit (multiply 

the average mass flow rate entering the treatment 
TABLE 5-1. (cont’d) 

You have demonstrated 

For option... For each test run, determine the... And calculate the... compliance if..

T3H (open or • Table 9 HAP concentration in each • RMR for each Group 1 and Group 2 wastewater the AMR for th

closed biological Group 1 and Group 2 wastewater stream (use equation WW9a; note that the RMR is or closed biolo

treatment units)c stream (that are combined for 95 percent of the mass of HAP in each wastewater treatment unit i

treatment in the treatment unit) at its stream) greater than or 

PODb • sum of the RMR values for all of the Group 1 and to the sum of th

• flowrate of each Group 1 and Group 2 Group 2 wastewater streams RMR’s for all o

wastewater stream at its PODb • average HAP mass flowrate entering the treatment Group 1 and G

• Table 9 HAP concentration at the inlet unit over all of the test runs (use equation WW1) wastewater stre

and outlet of the treatment unit • fraction of the Table 9 HAP biodegraded in the that are treated 

• flowrate of wastewater at inlet and treatment unit (determined using procedures in open or closed 

outlet of the treatment unita §63.145(h) and appendix C to 40 CFR part 63) biological treat

• AMR for the treatment unit (multiply the average unit 

mass flow rate entering the treatment unit by the fraction biodegraded)d 

a Only one measurement is needed if the outlet flow is not greater than the inlet flow. b The determination may be made downstream of the POD if you adjust the measured concentration to account for combination of streac You do not need to conduct a performance test if the biological treatment unit meets the definition of an “enhanced biological treatme

the definition), and at least 99 percent of the Table 9 HAP by weight are included on list 1 in Table 36 to subpart G. d Note that a different calculation is required if the biological treatment unit is part of a series of treatment units and the treatment units 

piping; see equation WW13 in §63.145(f)(5) for more information. 

5-18
 
Design evaluations for Treatment Units [§63.138(j)(1)] 

If you elect to demonstrate initial compliance with a treatment compliance option by conducting 

a design evaluation, you must provide documentation that addresses the operating characteristics 

of the treatment process. The design evaluation also must be based on operation at a 

representative wastewater stream flow rate and a Table 9 HAP concentration under which it 

would be most difficult to demonstrate compliance. 

If you comply with Option T3E, T3F, T3G, or T3H using a closed biological treatment unit, 

you must use a mass balance to determine the AMR in the biological treatment unit as follows: 

•	 step 1: determine mass flow rate of Table 9 HAP entering the biological unit 

•	 step 2: determine mass flow rate of Table 9 HAP exiting the biological unit in the
 
 

discharged wastewater
 
 

•	 step 3: determine the mass flow rate of Table 9 HAP exiting the biological treatment unit 

in the vented gas stream 

•	 step 4: the AMR is calculated by subtracting the values in steps 2 and 3 from the value in 

step 1 

How do I show initial compliance with the control device compliance 

requirements? 

Subpart MMM requires you to conduct either a design evaluation or a performance test for each 

control device you use to comply with Option A1, A2, A3, or A4. 

Design evaluation [§63.139(d)(2)] 

The specific parameters that you must consider in a design evaluation vary depending on the 

type of control device that you use. The requirements are summarized in Table 5-2. 

TABLE 5-2. Characteristics to Consider in Design Evaluations for Control Devices 

If you And you are using 
 


comply the following Then you must consider these 
 


with ...a control device ... characteristics... And establish the following... 
 


option A1 thermal vapor • vent stream composition • design minimum temperature in 
 


or A2 incinerator • constituent concentration combustion zone 
 


• 	 flow rate • design average temperature in 

combustion zone 

• combustion zone residence time 

catalytic vapor • • 

incinerator • the catalyst bed 

• 	 • 

the catalyst bed 

• 

• 

vent stream composition design minimum temperature across 

constituent composition 

flow rate design average temperature across 

design minimum outlet temperature 

design average outlet temperature 

5-19
 
TABLE 5-2. (cont’d) 

If you And you are using 
 

the following 
 

with ...a control device ... characteristics... And establish the following... 
 

comply Then you must consider these 

boiler or process • vent stream composition • design minimum flame zone 

heater • constituent concentration temperature 

• 	 flowrate 	 • design average flame zone 

temperature 

•	 design minimum combustion zone 

residence time 

•	 design average combustion zone 

residence time 

•	 description of method and location 

where the vent stream is introduced 

to the flame zone 

condenser • • 

• 	 	 concentration levels 

• •	 	 

• 	 	 condenser exhaust vent stream 

•	 • 

coolant fluid at the condenser inlet 

and outlet 

regenerative • • 

carbon adsorber • 

• •	 	 

• •	 	 

•	 • 

activated carbon used 

•	 

•	 

regeneration 

•	 

•	 

non-regenerative • • 

carbon adsorber • 

• •	 	 capacity of carbon bed 

• •	 	 

• 	 	 activated carbon 

•	 

scrubber • • 

• 	 	 

• liquid-to-vapor ratio •	 	 

•	 

concentration • 

• 	 	 packing, by section, for a packed 

•	 

constituents with the scrubbing 

liquid 

vent stream composition design outlet organic compound 

constituent concentration 

flowrate design average temperature of the 

relative humidity 

temperature design average temperatures of the 

vent stream composition design exhaust vent stream organic 

constituent concentration compound concentration level 

flow rate adsorption cycle time 

relative humidity number and capacity of carbon beds 

temperature type and working capacity of 

design total regeneration stream mass 

or volumetric flow rate 

design carbon bed temperature after 

design carbon bed regeneration time 

design service life of the carbon 

vent stream composition design exhaust vent stream organic 

constituent concentration compound concentration level 

mass or volumetric flowrate 

relative humidity type and working capacity of 

temperature 

design carbon replacement interval 

vent stream composition design exhaust vent stream organic 

constituent concentration compound concentration level 

type and total number of theoretical 

scrubbing liquid flow rate and and actual trays for a tray column 

type and total surface area of 

temperature 

reaction kinetics of the column 

5-20
 

If you And you are using 

the following 

with ...a control device ... characteristics... And establish the following... 

comply Then you must consider these 

TABLE 5-2. (cont’d) 

Option A3	 	 enclosed none specified

combustion 

device 

none specified 

option A4	 flare • constituent concentration • 

•	 • vent gas exit velocity 

•	 • 

•	 test 

flare tip 

a 
 

beginning on page 5-9.
 

Performance test [§§63.1362(d)(12) and (13), 63.139(d)(1), and 63.145(a), (i), and (j)]
 


 

If you you have according to this 

section of the 

rule... with ...a 

option A1 •	 

process unit operating conditions and when control 

device is operating at a representative inlet flow rate 

and concentration ( If the control device 

operates over several sets of representative 

conditions, test under one set, and supplement test 

results with modeling and/or engineering 

assessment to demonstrate performance over the 

range) 

•	 

organic HAP or TOC concentration 

•	 

entering and existing the control device (use 

• 

option A2 • 

above for option A1 

•	 

option A4	 • 

hour period 

• 

reduction is $95 

percent 

the corrected 

concentration is #20 

specified in 

§63.11(b) 

§§63.145(a) and 

(i), and 

63.1362(d)(12) 

§§63.1362(d)(13) 

and 63.145(a) and 

(i) 

§§63.11(b) and 

63.145(j) 

velocity 

vent gas heating value 

constituent heat of combustion 

flow rate conduct Method 22 visible emissions 

cross-sectional area of the 

 Each option is described in the section “What are my compliance options for air pollution control devices?” 

Your performance testing requirements are summarized in the following table: 

comply demonstrated initial 

then you must ... compliance if... 

conduct the performance test under representative 

Note: 

use specified test methods and procedures to select 

sampling site, determine flow rate, and measure 

calculate mass rate of TOC or total organic HAP 

equations WW16 and WW17) 

calculate the mass percent reduction 

conduct performance test under conditions, and 

using test methods and procedures, as specified 

correct measured outlet TOC or total organic HAP 

concentration to account for supplemental gases 

determine visible emissions using Method 22 for 2-

determine vent stream heating value and exit 

the calculated mass 

ppmv 

you meet the criteria 

a Each option is described in the section “What are my compliance options for air pollution control devices?” 

beginning on page 5-9. 

5-21
 
What monitoring must I do to comply with the emission suppression 

requirements for waste management units? 

Your monitoring requirements consist of a variety of inspections and repairs. The specific 

requirements depend on the compliance option you select. Details for each emission suppression 

compliance option are specified in Table 5-3. 

Note: If your emission suppression compliance option includes a closed vent system and control device, see 

“What monitoring must I do for my air pollution control device?” and “How do I inspect my closed-vent 

systems?” on pages 5-28 through 5-30 for additional information. 

Note: If necessary, you may designate parts of covers, fixed roofs, and enclosures as unsafe-to-inspect or 

difficult-to-inspect. Your requirements for these designated parts of emission suppression devices are the same 

as for sections of closed-vent systems that you designate as unsafe-to-inspect or difficult-to-inspect (see “How do 

I inspect my closed-vent systems?” on page 5-30 for additional information. [§63.1366(h)(6) and (7)] 

5-22
 
 
TABLE 5-3. 

5-23
 

If you have a(n) ... with option...a 

At this frequency... Using... 

wastewater note that initially Method 21 

tank these inspections are not required if your fixed roof is 

maintained under negative pressure) 

sensory 

observations 

varies visual depending on observations 

gaps between the seal and the wall of the wastewater seals and the 

tank as listed in §63.133(g)(1)(i) through (viii) option 

selected 

initially and visual 

§63.120(b)(3)(i) through (4), and inspect the seals for once every 5 observations 

years for the both initially 

floating roof or gaps between the seal and the wall of the and annually wastewater tank as listed in §63.133(g)(1)(i) through for the (viii)) secondary 

seal 

you determine that it is unsafe to perform the seal gap measurement or inspections 

initially and visual 

such as a cracked cover or door observations 

initially and visual 

(e.g., leaving an access door open when not in use) observations 

Inspection Requirements for Waste Management Units 

And you comply 

Then you must ... 

WT1 inspect fixed roof and all openings for leaks ( 

semiannually 

WT2 inspect floating roof in accordance with §63.120(a)(2) 

and (a)(3), and check for control equipment failures such as a rim seal that is detached from the floating roof or number of 

WT3 measure floating roof seal gaps in accordance with 

compliance with design criteria specified in §63.120(b)(5) and (6) (i.e., inspect for control equipment primary seal; failures such as a rim seal that is detached from the 

Note: §63.133(e) specifies procedures to follow if 

WT1, WT2, or inspect wastewater tank for control equipment failures WT3 semiannually 

WT1, WT2, inspect wastewater tank for improper work practices WT3, or WT4 semiannually 
TABLE 5-3. (cont’d) 

If you have a(n) And you comply At this ... with option...a Then you must ... frequency... Using... 

WT1, WT2, repair defects (e.g., improper work practices or control each time a N/A 

WT3, or WT4 equipment failures) within 45 calendar days of detection, defect is 

unless a delay of repair or an extension is allowed detected 

5-24
 
 

surface S1 inspect the cover and all openings for leaks (note that initially Method 21 

these inspections are not required if your cover is maintained under negative pressure) 

sensory 

observations 

S1 or S2 initially and visual 

following defects: observations 

• 

or other closure device open when not in use) 

• 

cover or closure devices) 

repair defects within 45 calendar days of detection, N/A unless a delay of repair is allowed defect is 

detected 

container Method 21 

sensory 

observations 

impoundment 

semiannually 

visually inspect the surface impoundment for both of the 

semiannually 

improper work practices (e.g., leaving an access hatch 

control equipment failures (e.g., cracks or gaps in the 

each time a 

C1 inspect cover and all openings for leaks initially 

semiannually 
TABLE 5-3. (cont’d) 

5-25
 

If you have a(n) ... with option...a 

At this frequency... Using... 

C3 inspect the enclosure and all openings for leaks (note initially Method 21 

that inspections are not required if you maintain the enclosure under negative pressure) 

sensory 

observations 

C1 or C2 inspect the container for both of the following types of initially and visual 

defects: observations • 

or has a crack or gap) 

• 

open when not in use) 

N/A 

defect is 

detection, unless a delay of repair is allowed detected 

individual drain D1 inspect the cover and all openings for leaks (note that initially Method 21 

system you are not required to conduct these inspections if your 

cover is maintained under negative pressure) 

sensory 

observations 

initially and visual 

following types of defects: observations 

• 

or cracked) 

• 

open when not in use) 

And you comply 

Then you must ... 

semiannually 

semiannually 

control equipment failures (e.g., a cover that is broken 

improper work practices (e.g., leaving an access hatch 

repair defects due to control equipment failures and each time a improper work practices within 15 calendar days after 

semiannually 

inspect the individual drain system for both of the 

semiannually 

control equipment failures (e.g., a cover that is broken 

improper work practices (e.g., leaving an access hatch 
TABLE 5-3. (cont’d) 

If you have a(n) At this ... with option...a frequency... Using... 

And you comply 

Then you must ... 

D2 verify that sufficient water is present to maintain each initially and visual 

water seal semiannually observation, 

flow monitoring device, or continuous drip into the drain 

5-26
 
 

inspect tightly fitting caps and plugs on drains for defects initially and visual such as gaps, cracks, or holes observations 

inspect covers on junction boxes for defects such as initially and visual gaps, cracks, or holes observations inspect unburied portion of sewer line for defects such as initially and visual cracks and gaps observations 

D1 or D2 repair defects within 15 calendar days after detection N/A 

unless a delay of repair is allowed defect is 

detected 

oil-water O1 inspect fixed roof an all openings for leaks (note that the initially Method 21 

separator inspection is not required if the fixed roof is maintained 

under negative pressure) 

sensory 

observations 

semiannually semiannually semiannually 

each time a semiannually 
TABLE 5-3. (cont’d) 

If you have a(n) And you comply At this ... with option...a Then you must ... frequency... Using... 

O2 inspect the oil-water separator for control equipment initially and procedures 

failures such as a rim seal that is detached from the every five specified in floating roof or gaps between the seal and the oil-water years for the §60.696(d)(1) separator wall as listed in §63.137(e)(1)(i) through (vi) primary seal, to inspect seals 

and initially and measure and annually seal gaps for the secondary seal 

5-27
 
 

O1 or O2 initially and visual 

practices (e.g., leaving an access door open when not in observations 

use) 

initially and visual 

failures such as a cracked cover or door observations 

N/A 

failures within 45 calendar days of detection unless a defect is 

delay of repair is allowed detected 

inspect the oil-water separator for improper work 

semiannually 

inspect the oil-water separator for control equipment 

semiannually 

repair improper work practices and control equipment each time a 

a The emission suppression compliance options are described on pages 5-4 through 5-9. 
What monitoring must I do for my wastewater treatment unit? 

To demonstrate ongoing compliance with the compliance options for treatment units, you must 

monitor operating parameters for the treatment unit. Subpart MMM specifies the parameters to 

monitor only for steam strippers. For all other treatment units, you must determine both the 

parameters that demonstrate proper operation of the treatment and the frequency at which they 

should be monitored. You must then submit a request for approval to monitor according to that 

plan. The following table summarizes the requirements: 

And you 
 

comply with At this According to this 
 

If you use a ... option...a Then you must ... frequency... section of the rule... 
 

Biological T3E, T3F, Request approval to monitor As specified by §63.1366(b)(1)(vii), 

treatment unit T3G, or appropriate parameters that the permitting §63.143(c) and Table 

T3H demonstrate proper operation of authority 12 to subpart G 

the biological treatment unit 

continuously §63.1366(b)(1)(xii), 

• 	 §63.143(b), and 

or T3E • 	 Table 12 to subpart G 

rate 

• 	 

Any other As specified by §63.1366(b)(1)(xii), 

(or the procedures in §63.8(f)) to §63.143(d), and 

unitb Table 12 to subpart G 

T3E 


 

Steam stripper T1, T2, monitor each of the following: 

T3A, T3B, steam flow rate 

wastewater feed mass flow 

either wastewater feed 

temperature or column 

operating temperature 

T1, T3A, Use your precompliance report 

treatment T3B, T3C, the Administrator 

T3D, or request approval to monitor 

appropriate parameters that 

demonstrate proper operation of 

your treatment process 

a The treatment compliance options are described on pages 5-9 through 5-13. 
 b You may also use this procedure to request approval to monitor parameters for a steam stripper that differ from 

those specified in this table. 
 

What monitoring must I do for my air pollution control device? 

To demonstrate ongoing compliance with compliance options A1, A2, A3, and A4 for air 

pollution control devices, you must monitor one or more operating parameters as specified in 

Table 5-4. 

5-28
 
 
TABLE 5-4. 

And you 
 


 

If you use a ... option... 
 

According to 

At this this section of 

frequencya,b... the rule... 

 Monitoring Requirements for Control Devices 

comply with 

Then you must ... 

Thermal A1, A2, or Monitor firebox temperature Continuously §63.143(e)(1) 
 

incinerator A3 and Table 13 to 
 

subpart G 
 

Boiler or A1, A2, or §63.143(e)(1) 
 

process heater A3 and Table 13 to 
 

subpart G 
 


 


 

with the 
 


 

Catalytic A1 or A2 Do either of the following: 
 

incinerator • 
 

of the catalyst bed 
 

Continuously 	 §63.143(e)(1) 

and Table 13 to 

subpart G 

• 	 

across the catalyst bed 

Condenser A1 or A2 Monitor condenser exit (product Continuously §63.143(e)(1) 
 

and Table 13 to 
 

subpart G 
 

Carbon A1 or A2 Monitor each of the following: Each regeneration §63.143(e)(1) 
 

adsorber • cycle and Table 13 to 
 

(regenerative) subpart G 
 

regeneration 

• 	 

regeneration 

• 	 

Carbon A1 or A2 Daily, or at intervals §63.143(e)(1) 
 

adsorber (non­ concentration at adsorber outlet, or no greater than 20% and Table 13 to 
 

regenerative) of the design carbon subpart G 
 

whichever is greater 

Replace the carbon at a regular At calculated §63.143(e)(1) 

intervals and Table 13 to 

subpart G 

design flow rate and organic 

concentration in the gas stream 

Monitor combustion temperature Continuously 

<44 MW (and 

vent stream is 

not mixed 

primary fuel) 

Monitor temperature upstream 

Install temperature monitors 

upstream and downstream of 

the catalyst bed, and monitor 

the temperature difference 

side) temperature 

Total regeneration stream mass 

or volumetric flow during 

Temperature of carbon bed after 

Temperature of carbon bed 

within 15 minutes of 

completing a cooling cycle 

Monitor organic compound 

replacement interval, 

predetermined interval that is less 

than the time interval 

corresponding to the maximum 

5-29
 

TABLE 5-4. (cont’d) 

And you 
 


comply with 
 


If you use a ... option... Then you must ... 
 


According to 

At this this section of 

frequencya,b... the rule... 

Flare A4 monitor for presence of flame at continuously (with §63.143(e)(1) 
 

the pilot light hourly records) and Table 13 to 
 

subpart G 
 

a As an alternative to any of the parameter monitoring requirements specified in this table, you may instead 

continuously monitor the organic concentration at the outlet of the control device. [§63.143(e)(2)] b You may request approval to monitor parameters other than those specified in this table. [§63.143(e)(3)] 

How do I inspect my closed-vent systems? 

Your inspection requirements for closed-vent systems that are used to transport organic vapors 

from a waste management unit to a control device are the same as for closed-vent systems used 

to transport vapors from a process vent to a control device. Therefore, see “How do I inspect my 

closed-vent systems?” on page 3-19 in chapter 3 for more information. [§63.1366(h)(6) and (7)] 

What are my compliance options for heat exchange systems? 

If you have heat exchange systems (as defined on page 5-2), you have two compliance options. 

These options require you to monitor for leaks and repair leaks that you detect, unless you are 

exempt. The requirements are the same for both existing and new affected sources: 

Exemptions [§63.104(a)(1) through (6)] 

You are exempt from the heat exchange system compliance options if your system meets any of 

the following six conditions: 

•	 The minimum pressure on the cooling water side of the heat exchange system is at least 35 

kPa greater than the maximum pressure on the process side 

•	 There is an intervening cooling fluid, containing less than 5 percent by weight of HAP 

listed in Table 4 to subpart F of part 63, between the process and the cooling water (and the 

intervening fluid is not sent through a cooling tower or discharged). 

•	 You have a once-through heat exchange system that is subject to a National Pollution 

Discharge Elimination System (NPDES) permit with an allowable discharge limit of that is 

either: 

<	 1 ppm or less above influent concentration, or 

<	 10 percent or less above the influent concentration. 

5-30 
•	 You have a once-through heat exchange system that is subject to an NPDES permit that 

includes all of the following: 

<	 	requires monitoring of a parameter(s) or condition(s) to detect a leak of process fluids 

into cooling water, 

<	 	specifies or includes the normal range of the parameter or condition, 

<	 	requires monitoring for the parameter selected as leak indicators no less frequently than 

monthly for the first 6 months and quarterly thereafter, and 

<	 requires you to report and correct leaks to the cooling water when the parameter or 

condition is outside the normal range. 

•	 You have a recirculating heat exchange system that is used to cool process fluids that 

contain less than 5 percent by weight of total HAP listed in Table 4 to Subpart F of part 63. 

•	 You have a once-through heat exchange system that is used to cool process fluids that 

contain less than 5 percent by weight of total HAP listed in Table 9 to Subpart G of part 63. 

Option HE1: Monitor HAP or other representative substances [§63.104(b)] 

Implement a monitoring program for one or more HAP or other representative substances (e.g., 

total HAP, total VOC, one or more speciated HAP, or other compounds) whose presence in 

cooling water indicates a leak. Your monitoring program must be conducted as follows: 

• 	You must monitor monthly for the first 6 months and quarterly thereafter. 

• 	Monitoring of speciated HAP or total HAP refers to the following HAP: 

<	 	HAP listed in Table 4 to Subpart F of part 63, if you have a recirculating heat exchange 

system, or 

<	 HAP listed in Table 9 to Subpart G of part 63, if you have a once-through heat exchange 

system. 

•	 Use any EPA-approved method listed in 40
 
 

CFR part 136 as long as the method is sensitive You may use alternative methods upon
 
 

to concentrations as low as 10 ppm and you approval by the Administrator.
 
 

use the same method for both the entrance and
 
 

exit samples.
 
 

•	 You must collect at least three sets of samples. The samples may be collected at the 

entrance and exit of each heat exchange system or at locations where the cooling water 

enters and exits each heat exchanger or combination of heat exchangers. Entrance and exit 

locations are established as follows: 

5-31
 
 
If you take samples Then the entrance is the And the exit is the point at According to this 

at the... point at which... which... section of the rule... 

entrance and exit of a the cooling water leaves the cooling water is §63.104(b)(4)(i) 

recirculating system the cooling tower prior to introduced to the cooling 

being returned to the tower after being used to 

process equipment cool the process fluid 

entrance and exit of a the cooling water enters the cooling water exits the §63.104(b)(4)(ii) 

once-through heat the plant or the PAI plant or PAI process unit(s) 

exchange system process unit(s) 

entrance and exit of the cooling water enters the cooling water exits the §63.104(b)(4)(iii) 

each heat exchanger the individual heat heat exchanger or group of 

or any combination exchanger or group of heat heat exchangers 

of heat exchangers exchangers 

•	 Calculate the mean entrance concentration and the mean exit concentration. Adjust the 

concentration to correct for any makeup water or evaporative losses, if applicable. 

•	 You have detected a leak if both of the following are true: 

<	 the exit mean concentration is greater than the entrance 

mean concentration based on the results of a one-sided See chapter 7 for a sample 

statistical procedure at the 0.05 level of significance, and calculation. 

<	 the difference between the means is at least 1 ppmw or
 

10 percent of the entrance value, whichever is greater
 

Option HE2: Monitor using a surrogate indicator of leaks [§63.104(c)] 

Monitor one or more surrogate indicators (e.g., ion-specific electrode monitoring, pH, or 

conductivity) or one or more process or other 

conditions that indicate a leak. Under this You must maintain your current monitoring plan option, you must prepare and implement a onsite. If you ever revise your plan, you must also 

monitoring plan that describes the maintain the most recent superceded plan for at least 

procedures that you will use to detect process 5 years from the date of its creation (maintain onsite 

fluid leaks into the cooling water. Include the for at least 6 months). 

following in your plan: 

•	 Description of the parameter(s) or condition(s) to be monitored. 

•	 Explanation of how the selected parameter(s) or condition(s) will reliably indicate a leak. 

•	 The parameter level(s) or condition(s) that constitute a leak, including supporting data and 

calculations. 

Note: Monitoring must be sufficiently sensitive to determine the range of parameter levels or conditions when 

the system is not leaking. 

5-32
 
•	 How frequently you will monitor. 

Note: Frequency must be at least monthly during the first 6 months and at least quarterly thereafter. 

•	 The records you will maintain. 

You have a leak when the monitored parameter(s) or condition(s) exceed the threshold specified 

in your monitoring plan. 

Note: If you identify a leak using a method that is not described in your plan, and the method(s) in your plan 

could not detect the leak, you must revise your plan and document the basis for the changes. The revision must 

be completed within 180 after you discover the leak. 

Leak repair [§63.104(d) and (e)] 

After you detect a leak, you must: 

•	 Repair the leak as soon as practical (but no later than 45 calendar days after you determine 

that you have a leak, unless a delay of repair is allowed), and 

•	 Within 7 calendar days after repairing the leak or startup (whichever is later), confirm that 

the heat exchange system has been repaired. 

A delay of repair is allowed if: 

•	 Equipment is isolated from the process, or 

Reporting requirements for a delay of repair are •	 Repair is technically infeasible without a described in Table 5-7 (page 5-40).
 

shutdown and any one of the following
 

conditions also apply:
 

<	 a planned shutdown is scheduled within the next two months after you determine a delay 

of repair is necessary, 

<	 a shutdown for repair would cause greater emissions than the potential emissions from 

delaying repair, or 

Note: You must calculate emissions according to procedures described in §63.104(e)(2)(i)(A) and (B). 

<	 necessary parts or personnel were not available (for up to a maximum of 120 calendar 

days). 

What records must I keep for my wastewater systems? 

Your recordkeeping requirements for wastewater systems and heat exchange systems are 

presented in Table 5-5 (pages 5-34 through 5-37) and in Chapter 8. 

5-33
 
TABLE 5-5. Recordkeeping Requirements for Wastewater Systems and Heat Exchange Sys

Categories of records are... Then for each... You must keep records of... 

identification Group 2 wastewater stream all of the following: 

records (that is not complying with • process unit identification and description of process unit 

treatment option T3F or • stream identification code T3H) • concentration of Table 9 HAP in ppmw, including documentation of the 

methodology used to determine the concentration 

• flow rate in liters/min 

5-34
 
 

concentration and/or annual average flow rate

based on process knowledge of the annual average flow rate and/or HAP concentration 

wastewater stream transferred offsite for 

with subpart MMM

wastewater tank • 

suppression records 

• 

<< raw data < calculations of width and area of each gap and total gap area 

• 

repair: 

• description of the failure

<<

possible 

wastewater stream that you how process knowledge was used to determine the annual average 

determine to be Group 2 

the notice sent to the treatment operator stating that the wastewater stream or residual contains organic HAP that must be managed and treated in accordance 

treatment 

emission the occurrence of each required inspection (e.g., for leaks, improper work 

practices, and/or control equipment failures, depending on the emission suppression compliance option) 

all of the following for each seal gap measurement (Option WT2 or WT3): 

date of the measurement 

all of the following associated with each decision to use an extension when 

you determine it is unsafe to perform seal gap measurements or you delay 

documentation that alternate storage capacity is unavailable a schedule of actions to complete repair or empty the vessel as soon as 
TABLE 5-5. (cont’d) 

Categories of records are... Then for each... You must keep records of... 

surface impoundment the occurrence of each required inspection for improper work practices and 

control equipment failures 

container individual drain system oil-water separator • 

• 

<< raw data < calculations of gap width and total gap area 

• description of the failure • • 

fixed roof, or enclosure 

Control device records catalytic incinerator, 

condenser, or boiler or process heater <44 MW 

• • 

flare 

5-35
 
 

the occurrence of each required inspection for improper work practices and 

control equipment failures 

the occurrence of each required inspection for improper work practices and 

control equipment failures 

the occurrence of each required inspection for improper work practices and 

control equipment failures 

all of the following for each seal gap measurement: 

date of measurement 

waste management unit all of the following for each delay of repair due to unavailability of parts: 

reason additional time was necessary 

date when repair was completed 

closed-vent system, cover, inspections for leaks, and results of monitoring/inspection of bypass lines, as 

described in “What records must I keep?” in Chapter 8 

thermal incinerator, continuously monitored parameter data (see Table 5-4) 

daily averages of continuously monitored parameter data 

the times and duration of all periods when there is no pilot flame 
TABLE 5-5. (cont’d) 

Categories of records are... Then for each... You must keep records of... 

regenerative carbon all of the following for each regeneration cycle: adsorber • total regeneration stream mass flow 

• temperature carbon bed at end of regeneration • temperature to which the carbon bed is cooled within 15 minutes of 

completing the cooling cycle 

5-36
 
 

nonregenerative carbon • 

adsorber <

<< when the carbon was replaced

•

<< when the carbon was replaced 

boiler and process heater 

zone 

control device that you • 

• 

• 

records • 

• 

••

all of the following if you use an organic monitoring device: 

how the monitoring frequency was determined when the organic concentration was measured 

all of the following if you replace the carbon at a predetermined interval 

how the carbon replacement interval was determined 

any change in the location at which the vent stream is introduced into the flame 

the continuously monitored organic concentration data 

monitor using an organic the daily average of the organic concentration monitor rather than operating parameter monitors 

Treatment unit treatment unit other than a information and actions as approved by the Administrator 

steam stripper each measurement of any operating parameter data 

steam stripper all of the following continuously recorded parameter data: 

steam flow rate 

wastewater feed mass flow rate 

wastewater feed temperature or column temperature 
TABLE 5-5. (cont’d) 

Categories of records are... Then for each... Heat exchange heat exchange system • 

• • • 

other than a leak 

• • • 

You must keep records of... 

system records 

monitoring data that indicate each leak 

date when each leak was detected 

information regarding leaks detected by procedures not in your monitoring 

plan, if you comply with option HE2 

basis for any determinations that monitoring results are due to a condition 

dates of efforts to repair leaks 

method or procedure used to confirm repair of a leak 

date repair was confirmed 

5-37
 
 
What reports must I submit for my wastewater systems? 

Chapter 8 describes the notifications and reports that you may need to submit, and the dates 

when they must be submitted. Most of the information about wastewater systems that you will 

need to submit must be included in the following reports: 

•	 notification of compliance status report 

•	 periodic reports 

Notification of compliance status report 

You must include information related to wastewater systems in your notification of compliance 

status report as described in Table 5-6. 

TABLE 5-6. Information on Wastewater Systems to Include in the Notification of

a Compliance Status Report 

Include all of the following information in your notification of According to this 
 


For each... compliance status report... section of the rule... 
 


Group 2 wastewater all of the identification records listed in Table 5-5 §63.146(b)(1) 
 


stream 
 


wastewater stream •	 process unit identification §63.146(b)(2) and 

that contains Table 9 •	 Table 15 to subpart G 

HAP •	 

•	 

•	 

of the following: 

<

< concentration of Table 9 HAP 

•	 

•	 

•	 

•	 

treatment unit that •	 §63.146(b)(4) and 

•	 Table 17 to subpart G 

treats a Group 1 •	 

residual •	 

waste management •	 §63.146(b)(5) and 

unit that receives or •	 Table 18 to subpart G 

•	 

residual Group 2) 

description of process unit 

wastewater stream identification 

Group status (Group 1 or Group 2) 

statement that you designated the stream as Group 1 or both 

wastewater stream flowrate 

treatment compliance option used 

type of treatment unit(s) 

waste management unit identification 

intended control device for vented streams 

treatment unit identification 

receives, manages, or description of the treatment unit 

identification of all wastewater streams treated by the 

wastewater stream or treatment unit 

parameters to be monitored to demonstrate ongoing 

compliance 

identification of the waste management unit 

description of the was management unit 

manages a Group 1 identification of each wastewater stream received or 

wastewater stream or managed by the waste management unit (Group 1 and 

5-38
 
 
TABLE 5-6. (cont’d) 

Include all of the following information in your notification of According to this 
 

For each... compliance status report... section of the rule... 
 

residual removed • identification of the residual §63.146(b)(6) and 

from a Group 1 • description of the residual Table 19 to subpart G 

wastewater stream • identification of the wastewater stream from which the 

residual is removed 

• 	 treatment unit from which the residual originates 

• 	 fate of the residual (i.e., sold, returned to process, returned 

to waste management unit or treatment unit, or $99 percent 

destruction of the Table 9 HAP using nonbiological unit) 

• 	 all of the following if you reduce the Table 9 HAP by $99 

percent: 

< identification of device used 

< description of device used 

< efficiency of device, including information to substantiate 

the stated efficiency 

flare • §63.146(b)(7)(i) 
 

• 
 

suppression 
 


 

• 	 

non-flare control • §63.146(b)(7)(ii) 
 

device used to • 
 


 

< the design evaluation, including supporting 
 


 

<	 

biological • §63.146(b)(8)(i) 
 

unit 
 

• 	 

supporting calculations 

steam stripper that §63.146(b)(2)(i) 
 

is not a design steam in Table 5-5 
 

stripper 
 

 used to comply flare design 

with an emission results of initial compliance determination (visible emissions 

readings, heat content determinations, flow rate 

compliance option measurements, and exit velocity determination) 

times and durations of all periods during the initial 

compliance determination when the pilot flame was absent 

or the monitor was not operating 

the operating range for each parameter to be monitored 

either of the following from the initial compliance 

comply with an determination: 

emission suppression 

compliance option documentation 

the results of the performance test (operating ranges for 

process and control parameters, value of parameters being 

monitored, and applicable supporting calculations) 

 treatment the operating range for parameters to be monitored as 

approved by the Administrator 

results of the initial measurements of the parameters 

approved by the Administrator and any applicable 

the operating range for the parameters to be monitored as listed 

5-39
 
 
TABLE 5-6. (cont’d) 

According to this 

For each... section of the rule... 

nonbiological, non- §63.146(b)(80(ii) 

steam stripper 

for which you 

request approval to 

other than those 

specified in 

Table 5-5 

waste management §63.146(b)(9) 

unit or treatment 

unit • 

• 

following: 

<

<

< applicable supporting calculations 

a

Periodic report 

periodic reports as described in Table 5-7. 

TABLE 5-7. 

Periodic Report 

According to this 

section of the 

If you have... For which you... periodic reports... rule... 

a waste identified a • §63.146(c) 

management unit • 

that receives, failure during an the failure 

inspection • description of the failure 

a Group 1 • description of the nature of the repair 

wastewater stream • date of repair 

or residual 

Include all of the following information in your notification of 

compliance status report... 

the operating range of parameters to be monitored 

treatment unit, and 

any steam stripper 

monitor parameters 

either of the following used to demonstrate ongoing 

compliance: 

 used to comply design evaluation, including supporting documentation 

with a treatment results of the performance test, including all of the 

compliance option 

operating ranges of parameters 

value of each parameter being monitored 

 The reporting requirements in this table for treatment units do not apply to design steam strippers or RCRA units. 

You must include the information about wastewater systems and heat exchange systems in your 

Information on Wastewater Systems and Heat Exchange Systems to Include

 in Your 

Then include the following information in your 

date of the inspection 

control equipment identification of the waste management with 

manages, or treats 

5-40
 
Table 5-7. (cont’d) 

According to this 
 

section of the 
 

If you have... For which you... periodic reports... rule... 
 

Then include the following information in your 

a wastewater tank used a 30-day • explanation of why it was unsafe to perform §63.146(g)
 
 

complying with extension to the inspection or seal gap measurement 
 
 

option WT3 continue using the • statement that alternate storage capacity was 
 
 

tank more than 45 unavailable 

days after • a schedule of actions to ensure the tank is 

determining it is emptied as soon as possible 

unsafe to inspect 

or perform seal 

gap 

measurements 

a wastewater tank use a 30-day • description of the failure §63.146(g) 
 

that failed an extension to • 
 

inspection for continue using the not available 
 

tank beyond 45 • 
 

practices or control days after 
 

detecting the 
 

defect 

a closed-vent 
 

system with a 
 

bypass line suppression 
 

option 

either of the following:	 	 §63.1368(g)(2)(iii) 

•	 	

•	 

position or the seal has been changed 

a thermal • §63.146(e)(1), 

incinerator, Table 20 to subpart 

catalytic rangec G, and 

incinerator, boiler option A1, A2, or • §63.1368(g)(2)(ii) 

or process heater, A3b data were collected 

or condensera • 

data were not collected for an excursion, as 

defined in §63.1366(b)(7) 

a flarea §63.146(e)(1) and 

option A4b absent Table 20 to subpart 

G 

a regenerative	 	 • §63.146(e)(1) and 

carbon adsorbera	 	 Table 20 to subpart 

preestablished rangec G 

option A1 or A2b • list all operating days when insufficient 

•	 

data are not collected for an excursion, as 

defined in §63.1366(b)(7) 

statement that alternate storage capacity was 

improper work a schedule of actions to ensure the control 

equipment will be repaired or the vessel will 

equipment failures be emptied as soon as possible 

comply with any 

emission times and durations of all periods when the 

vent stream is diverted through the bypass or 

the flow monitor is not working 

results of monthly inspections that show the 

bypass line valve has moved to the diverting 

monitor operating daily average of continuously monitored 

parameters to parameter that is outside its preestablished 

comply with 

list all days when insufficient monitoring 

duration of each period when monitoring 

comply with duration of all periods when all pilot flames are 

monitor operating identify all regeneration cycles when a 

parameters to monitored parameter is outside its 

comply with 

monitoring data are collected 

duration of each period when monitoring 

5-41
 

Table 5-7. (cont’d) 

If you have... For which you... periodic reports... 

According to this 

section of the 

rule... 

Then include the following information in your 

any control use an organic monitoring results for each operating day §63.146(e)(2) 
 

devicea monitoring device during which the daily average concentration 
 

was outside the preestablished rangec 
 

a biological 

d preestablished rangec 

§63.146(d)(1) 

a steam stripper 

option T1, T2, 

T3Ed 

c 

§63.146(d)(2) 

a treatment unit 

other than a 

biological unit or 

option T1, T3A, 

or T3Ed 

during which the daily average value of any 

§63.146(d)(3) 

a control device or 

treatment unit 

you request 

approval of 

procedures not 

specified in 

subpart MMM 

option) 

§63.146(f) 

a heat exchange 

system 

have invoked the 

delay of repair 

provisions in 

§63.104(e) 

• 

• 

• 

• (note that if 

the reason for the delay is that you estimated 

that the shutdown for repair would cause 

more emissions than from delaying repair, 

you must include the emission estimation 

calculations) 

• 

expected date of repair, and 

• 

leak was successfully repaired. 

§§63.104(f)(2) and 

63.1368(l) 

treatment unit 

comply with 

option T3E, T3F, 

T3G, or T3H 

results of measurements that indicate the 

biological treatment unit was outside of the 

comply with 

T3A, T3B, or 

the monitoring results for each operating day 

when the daily average value of any monitored 

parameter is outside the preestablished range 

steam stripper 

comply with 

T3B, T3C, T3D, 

the monitoring results for each operating day 

monitored parameter approved by the 

Administrator is outside the approved range 

monitoring 

(any treatment 

information as specified by the Administrator 

indication that a leak is present, 

date the leak was detected, 

identify whether the leak has been repaired, 

reason(s) for the delay of repair 

if the leak remains unrepaired, identify the 

if you repaired the leak, identify the date the 

a You must include the specified information in your periodic report only if the conditions specified in 

§63.1368(g)(2)(ii) are met. 

b Each compliance option is described in the section “What are my compliance options for air pollution control 

devices?” beginning on page 5-9. 

c You determine the preestablished range as part of your initial compliance demonstration and document the values 

in your notification of compliance status report or operating permit. 

d Each treatment option is described in the section “What treatment compliance options do I have for my wastewater 

streams?” beginning on page 5-10. 

5-42
 
Checklists for Wastewater System Inspections 

Facility Name: 
 ______________________________________________________ 

Facility Location: 
 ______________________________________________________ 

Facility TRI ID #: 
 ______________________________________________________ 

Inspector: 
 ______________________________________________________ 

Date: 
 ______________________________________________________ 

The table below explains which inspection checklists you should use for waste management 

units and emission suppression equipment that manage, store, or treat Group 1 wastewater 

streams. 

Starting on 

If you use a ... That is controlled using ... Then use these checklists ... page ... 

wastewater a fixed roof with a closed-vent 

tanka 

an external floating roof (Option 

) 

a fixed roof with an internal floating 

an external floating roof converted to 

an internal floating roof (Option 

) 

surface a cover with a closed-vent system

a routed to a control device (Option 

S1) 

(Option S2) 

containera	 a cover (Option C1 or C2) 

a cover and enclosure with a closedcontrol device (Option C3) 

individual	 a cover and, if vented, routed to a 

drain system	 process or through a closed-vent 

D1) 

water seal controls or a tightly fitting 

cap or plug for drains, tightly fitting 

solid covers for junction boxes (or 

covers vented to a control device) or 

closed sewer lines (Option D2) 

checklists 1 and 6 in this chapter and 5-45 and 5-56 

see next table for checklists specific 

to the control device 

checklist 1in this chapter and section 5-45 and 4-25 

A of checklist 3 in Chapter 4 

checklist 1 in this chapter and section 5-45 and 4-21 

A of checklist 2 in Chapter 4 

checklist 1 in this chapter and section 5-45 and 4-22 

A of checklist 4 in Chapter 4 

checklist 1 in this chapter	 5-45 

checklists 2 and 6 in this chapter and 5-46 and 5-56 

see next table for other checklists 

checklists 2 and 6 in this chapter 

checklists 3 and 6 in this chapter and 5-48 and 5-56 

see next table for checklists specific 

to the control device 

checklists 4 and 6 in this chapter and 5-50 and 5-56 

see next table for checklists specific 

to the control device 

checklist 4 in this chapter (and 5-50 and 5-56 

checklist 6 for any vented covers) 

system routed to a control device 

(Option WT1) 

WT3 

roof (Option WT2) 

WT2 

a fixed roof (Option WT4) 

impoundment 

a floating flexible membrane cover 

vent system to route emissions to a 

system to a control device (Option 

5-46 and 5-56 

checklists 3 and 6 in this chapter 5-48 and 5-56 

5-43
 
 
 Starting on 

If you use a ... That is controlled using ... Then use these checklists ... page ... 

oil-water a fixed roof and closed-vent system checklists 5 and 6 in this chapter and 5-53 and 5-56 

separator routed to a control device (Option see next table for checklists specific 

O1) to the control device 

a floating roof (Option O2) 5-53 

a 

[§63.138(a)(3)] 

The table below explains which checklists you should use for control devices: 

Then use the following 

Starting on pages... 

a scrubber 

a condenser 2 and 4 

a regenerative carbon adsorber 2 and 5 3-24 and 3-32 

a nonregenerative carbon adsorber 2 and 6 3-24 and 3-34 

2 and 7 3-24 and 3-35 

a catalytic incinerator 2 and 8 3-24 and 3-37 

a boiler or process heater with a design heat input of 2 and 9 3-24 and 3-39 

a flare 2 and 11 3-24 and 3-43 

Then use these checklists 

in this chapter: Starting on page... 

7 5-58 

8 5-60 

8 5-60 

checklist 5 in this chapter 

 You are exempt from the emission suppression requirements if the waste management unit is also a biological 

treatment unit that meets the biodegradation requirements of treatment option T3G or T3H. 

The wastewater system emission streams are conveyed by a 

closed-vent system to the following control device ... checklists from Chapter 3: 

2 and 3 3-24 and 3-28 

3-24 and 3-30 

a thermal incinerator 

<44 megawatts or for which the emission stream is not 

introduced with the primary fuel 

The table below identifies the checklists you should use for treatment units: 

For the following treatment units... 

Steam stripper (including design steam stripper) 

Biological treatment unit 

Other types of treatment units 

Use checklist 9 (page 5-61) for heat exchange systems. 

5-44 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 1: Requirements for all wastewater tanks (emission suppression compliance options 

WT1, WT2, WT3, and WT4)a 

Facility Name: 
 


Facility Location:
 


Facility TRI ID #:
 


Inspector:
 


Date:
 


Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring and Inspection Requirements Comments 

1.	 	 Are all openings (e.g., access hatches, sampling ports, and gauge G Yes G No 

wells) closed (e.g., covered by a lid) except when in use (e.g., it is in 

use during wastewater sampling or removal or for equipment 

maintenance, inspection, or repair) (Option WT1, WT2, WT3, or 

WT4)? §63.133(f) 

B. Comments 

1. 	 Do you keep all records for at least 5 years? G Yes G No 

2. 	 G Yes G No 
 


 

(1) 
 

3. 	 G Yes G No 
 


 

(1) 
 

4. 	 G Yes G No 
 


 


 

inspection for leaks? (1) 
 

5. 	 If your wastewater tank is equipped with an IFR or EFR (Option G Yes G No 
 


 

inspection of the seals? (1) 
 

6. 	 For each inspection of the wastewater tank during which a control 
 


 

or EFR, do you record and report the following in your next Periodic 
 


 

• Date of the inspection 	 G Yes G No 

• G Yes G No 

• Description of the failure? 	 G Yes G No 

• Description of the nature of the repair? 	 G Yes G No 

• 	 G Yes G No 

a

5-45 

Recordkeeping and Reporting Requirements 

§63,1367(a) 

Do you record the occurrence of each semiannual visual inspection 

of wastewater tanks for improper work practices (Option WT1, 

WT2, WT3, or WT4)? §63.147(b)

Do you record the occurrence of each semiannual visual inspection 

of wastewater tanks for control equipment failures (Option WT1, 

WT2, or WT3)? §63.147(b)

If your wastewater tank is equipped with a fixed roof and emissions 

are vented through a closed-vent system to a control device (Option 

WT1), do you record the occurrence of each semiannual visual 

§63.147(b)

WT2, or WT3), do you record the occurrence of each periodic 

§63.147(b)

equipment failure was identified, including detached seals for an IFR 

Report (Option WT1, WT2, or WT3): §63.146(c) 

Identification of the wastewater tank having the failure? 

Date the repair was made? 

 The emission suppression compliance options for wastewater tanks are described in the section “What are my 

emission suppression compliance options?” beginning on page 5-4. 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 2: Requirements for all surface impoundments (emission suppression compliance 

options S1 and S2)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring and Inspection Requirements Comments 

Answer questions in 

1.	 	 

(1), (c)( )(2) 

•	 Are all access hatches and other openings closed except when in G Yes G No 

•	 G Yes G No 

lids, covers, and doors are not cracked, gapped, or broken)? 

•	 G Yes G No 

2.	 	 

(2) 

•	 G Yes G No 

the liquid surface? 

•	 G Yes G No 

following: 

<	 	 high density polyethylene with a thickness of at least 2.5
 
 


 
 

<	 	 
 
 

integrity for the intended service life of the floating cover?
 
 

•	 G Yes G No 

•	 does each opening in the cover have a closure device that when G Yes G No 

•	 G Yes G No 

§63.134(b)(2)(vii)? 

5-46
 

Note: Answer questions in item “1" if you comply with the requirements 

to cover surface impoundments in §63.134(b)(1). 

item “2" if you comply with the requirements for a floating flexible 

membrane cover in §63.134(b)(2). 

If you use a cover on a surface impoundment (Option S1), are all of 

the following requirements met: §63.134(b) 1), and (c

use (e.g., it is in use during wastewater sampling or removal or 

for equipment maintenance, inspection, or repair)? 

Is all control equipment functioning properly (e.g., seals, joints, 

Is the cover used at all times when a Group 1 wastewater or 

residual is in the surface impoundment, except during removal of 

treatment residuals or closure of the surface impoundment? 

If you use a floating flexible membrane cover on a surface 

impoundment (Option S2), are all of the following requirements met: 

§63.134(b)

is the cover floating on the liquid surface over the entire area of 

is the floating flexible membrane cover made out of either of the 

millimeters, or

a material that has an equivalent organic permeability and

is the floating flexible membrane cover free of visible cracks, 

holes, gaps, or other open spaces between cover section seams or 

between the cover and its foundation mountings? 

closed leaves no visible cracks, holes, gaps, or other open spaces? 

is each closure device closed except as allowed in 
Checklist 2: (cont’d)
 
 

Requirements for all surface impoundments
 
 

A. Monitoring and Inspection Requirements Comments 

•	 are closure devices made of suitable materials to minimize G Yes G No 

exposure of organic HAP to the atmosphere, considering factors 

specified in §63.134(b)(2)(vi)? 

•	 if the floating membrane cover has emergency drains for storm G Yes G No 

water removal, are they equipped with either of the following: 

<	 	 a slotted membrane fabric cover that covers at least 90
 
 

percent of the area of the opening, or
 
 

<	 	 a flexible fabric seal? 

B. Recordkeeping and Reporting Requirements (Option S1 or S2) Comments 

1.	 Do you keep all records at least 5 years? §63.1367(a) 	 G Yes G No 

2.	 G Yes G No 
 


 

(1) 

3.	 G Yes G No 
 


 

(1) 

4.	 
 


 

the following in your next Periodic Report: 
 

•	 Date of the inspection 	 G Yes G No 

•	 G Yes G No 

•	 Description of the failure? 	 G Yes G No 

•	 Description of the nature of the repair? 	 G Yes G No 

•	 	 G Yes G No 

Do you record the occurrence of each semiannual visual inspection 

of surface impoundments for improper work practices? 

§63.147(b) 

Do you record the occurrence of each semiannual visual inspection 

of surface impoundments for control equipment failures? 

§63.147(b) 

For each inspection of the surface impoundment during which a 

control equipment failure was identified, do you record and report 

§63.146(c) 

Identification of the surface impoundment having the failure? 

Date the repair was made? 

a The emission suppression compliance options for surface impoundments are described in the section “What are my 

emission suppression compliance options?” beginning on page 5-4. 

5-47
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 3: Requirements for all containers (emission suppression compliance options C1, C2, 

and C3)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring and Inspection Requirements Comments 

1.	 	 For containers with capacity greater than or equal to 0.1 but less 

than or equal to 0.42 cubic meters, do you meet all of the following 

requirements (Option C1 or C2): §63.135(b)(2) and (3) 

•	 do the containers have covers? 	 	 G Yes G No 

•	 are the covers and all openings closed (e.g., covered by a lid) G Yes G No 

except when in use (e.g., an opening is in use during filling, 

removal, inspection, sampling, or pressure relief events related to 

safety)? 

•	 is all control equipment functioning properly (e.g., covers and G Yes G No 

doors are not cracked, gapped, or broken)? 

•	 either of the following: 	 	 G Yes G No 

<	 	 do the containers meet the DOT specifications and testing
 
 

requirements (Option C2)?
 
 

<	 do you inspect the covers for leaks as specified in
 
 

§63.1366(h) (Option C1)?
 
 

2.	 	 For containers with capacity greater than 0.42 cubic meters, do you 

meet all of the following requirements (Option C1): §63.135(b)(1), 

(b)(3), and (c) 

•	 do the containers have covers? 	 	 G Yes G No 

•	 do you fill the containers using a submerged fill pipe that does G Yes G No 

not extend more than 6 inches or within two fill pipe diameters of 

the bottom of the containers? 

•	 are the covers and all openings closed (e.g., covered by a lid) G Yes G No 

when not in use (e.g., an opening is in use if it is used for the 

submerged fill pipe, wastewater removal, inspection, sampling, or 

pressure relief events related to safety)? 

•	 is all control equipment functioning properly (e.g., covers and G Yes G No 

doors are not cracked, gapped, or broken)? 

5-48
 
 
Checklist 3: (cont’d) 

Requirements for all containers 

A. Monitoring and Inspection Requirements Comments 

3.	 	 For containers that have a capacity greater than or equal to 0.1 cubic G Yes G No 

meters, are used to treat a Group 1 wastewater stream or residual, 

and it is necessary that the containers be open during treatment, are 

the containers located within an enclosure that has a closed-vent 

system to transport emissions to a control device (Option C3)? 

§63.135(d) 

B. Recordkeeping and Reporting Requirements (Option C1, C2, or C3) Comments 

1.	 Do you keep all records for at least 5 years? §63.1367(a)(1) G Yes G No 

2.	 G Yes G No 
 

(1) 
 

3.	 G Yes G No 
 

(1) 
 

4.	 
 

identified, do you record and report the following in your next 
 

Periodic report: 
 

• Date of the inspection	 G Yes G No 

• 	 G Yes G No 

• Description of the failure?	 G Yes G No 

• Description of the nature of the repair?	 G Yes G No 

• 	 G Yes G No 

5.	 G Yes G No 
 

your facility? (1) 
 

Do you record the occurrence of each semiannual visual inspection 

of containers for improper work practices? §63.147(b) 

Do you record the occurrence of each semiannual visual inspection 

of containers for control equipment failures? §63.147(b) 

For each inspection during which a control equipment failure was 

§63.146(c) 

Identification of the container having the failure? 

Date the repair was made? 

Do you have a record of the capacity of each container maintained at 

§63.1368(f) 

a The emission suppression compliance options for containers are described in the section “What are my emission 

suppression compliance options?” beginning on page 5-4. 

5-49
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 4: Requirements for all individual drain systems (emission suppression compliance 

options D1 and D2)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring and Inspection Requirements Comments 

and sewers in §63.136(e) through (g). 

1.	 	 

all

(Option D1): 

•	 G Yes G No 

(5) 

•	 G Yes G No 

ports, and gauge wells) kept closed except when in use (e.g., an 

( )(1) 

•	 G Yes G No 

condition? (5) 

2.	 	 

all

(Option D2): 

•	 G Yes G No 

trap, s-trap) or a tightly-fitting cap or plug? (1) 

•	 G Yes G No 

in the water seal? (1)(i) 

Note: Answer only the questions in item “1" if you comply with the 

requirements to cover each opening in an individual drain system in 

§63.136(b) through (d). Answer only questions in items “2" through “4" 

if you comply with the alternative requirements for drains, junction boxes, 

If you cover each opening in your individual drain system (with or 

without a closed-vent system to route emissions to a control device 

or to a process), do you meet of the following requirements 

is the individual drain system designed and operated to segregate 

the vapors within the system from other drain systems and the 

atmosphere? §63.136(b)

are the cover and all openings (e.g., access hatches, sampling 

opening is in use during sampling, removal, or equipment 

maintenance, inspection, or repair)? §63.136(b) 1) and (c

are the cover and all openings maintained in good 

§63.136(b)

If you do not comply with the cover requirements described in item 

“1", do you meet of the following requirements for drains 

is each drain equipped with either water seal controls (e.g., p-

§63.136(e)

for each drain equipped with a water seal, is water always present 

§63.136(e)

5-50
 
 
Checklist 4: (cont’d)
 
 

Requirements for all individual drain systems
 
 

A. Monitoring and Inspection Requirements Comments 

•	 if a water seal is used on a drain receiving a Group 1 process G Yes G No 
 

wastewater stream, do you meet either of the following 
 

requirements: §63.136(e)(1)(ii) 
 

<	 	 does the drain pipe discharging the wastewater extend below
 
 

the liquid surface in the water seal, or
 
 

<	 	 is a flexible shield (or other enclosure which restricts wind
 
 

motion) installed that encloses the space between the pipe
 
 

discharging the wastewater and the drain receiving the
 
 

wastewater?
 
 

3.	 
 

all of the following for junction boxes (Option D2): 
 

•	 G Yes G No 
 


 

(2) 

•	 either of the following: G Yes G No 

<	 
 


 

(2)(i) 

<	 (2)(ii) 

%	 

%	 
 


 

%	 is a water seal installed at the entrance or exit of the 
 

junction box? 
 

(2)( 

allowed as an alternative to venting to a process or control 

device only if the junction box is filled and emptied by 

gravity flow or it is operated with no more than slight 

fluctuations in the liquid level. 

4.	 
 


 

(3) 

•	 	 G Yes G No 

•	 G Yes G No 
 


 

If you do not comply with the cover requirements described in item 

“1", do you meet 

are junction boxes equipped with tightly fitting solid covers 

(vented or unvented) that are free of gaps, cracks, or holes? 

§63.136(e) 

if the covers are vented, do you meet 

is the vent pipe connected to a closed-vent system that 

transports emissions to a process or control device, or 

§63.136(e) 

do you meet all of the following: §63.136(e) 

is the vent pipe at least 90 centimeters in length? 

is the diameter of the vent pipe less than 10.2 

centimeters? 

Note: the design requirements in §63.136(e) ii) are 

If you do not comply with the cover requirements described in item 

“1", do you meet both of the following for your sewers (Option D2): 

§63.136(e) 

are your sewer lines covered or enclosed? 

are the covers and enclosures free of gaps, cracks, or other 

openings to the atmosphere? 

5-51
 
 
Checklist 4: (cont’d)
 
 

Requirements for all individual drain systems
 
 

B. Recordkeeping and Reporting Requirements Comments

Note: Answer questions in items “1" through “4" if you comply with the 
 

requirements to cover each opening in an individual drain system in 
 

§63.136(b) through (d). Answer questions in items “1" and “5" if you 
 

comply with the alternative requirements for drains, junction boxes, and 
 

sewer lines in §63.136(e) through (g). 
 

1. Do you keep all records for at least 5 years (Option D1 or D2)? G Yes G No 

§63.1367(a) 

2. G Yes G No 

D1)? (1) 

3. G Yes G No 

(Option D1)? (1) 

4. 

identified, do you record and report the following in your next 

periodic report (Option D1): 

< date of the inspection G Yes G No 

• G Yes G No 

< description of the failure? G Yes G No 

< description of the nature of the repair? G Yes G No 

< G Yes G No 

5. 

boxes, and sewer lines, do you keep all of the following records 

(Option D2): 

• G Yes G No 

installed? ( (1) 

• G Yes G No 

of water supply to the drain? (1)( 

• G Yes G No 

holes in the cover? ( (1) 

• G Yes G No 

of the unburied portion of each sewer line to ensure that there are 

( (1) 

Do you record the occurrence of each semiannual visual inspection 

of the individual drain systems for improper work practices (Option 

§§63.136(c) and 63.147(b) 

Do you record the occurrence of each semiannual visual inspection 

of the individual drain systems for control equipment failures 

§§63.136(c) and 63.147(b) 

For each inspection during which a control equipment failure was 

§§63.136(c) and 63.146(c) 

identification of the individual drain system having the failure? 

date the repair was made? 

If you comply with the separate requirements for drains, junction 

documentation of the occurrence of each semiannual inspection 

of drains to ensure that caps or plugs are in place and properly 

§§63.136(f) 1) and 63.147(b) 

documentation of the occurrence of each semiannual verification 

§§63.136(e) ii) and 63.146(c) 

documentation of the occurrence of each semiannual inspection 

of junction boxes to ensure that there are no gaps, cracks, or other 

§§63.136(f) 2) and 63.147(b) 

documentation of the occurrence of each semiannual inspection 

no cracks or gaps that could result in air emissions? 

§§63.136(f) 3) and 63.147(b) 

a The emission suppression compliance options for individual drain systems are described in the section “What are 

my emission suppression compliance options?” beginning on page 5-4. 

5-52 
 
_________________________________________________________ 

_________________________________________________________ 

_________________________________________________________ 

_________________________________________________________ 

_________________________________________________________ 

Checklist 5: Requirements for all oil-water separators (emission suppression compliance options 

O1 and O2)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring and Inspection Requirements Comments 

§63.137(a)(1). 

1.	 	 Is the floating roof is resting on the liquid surface of the stored G Yes G No 

(1)( (3) 

2.	 	 G Yes G No 

corrosion and pools of standing liquid)? (1)(ii) 

3.	 	 	 G Yes G No 

4.	 	 all 

•	 G Yes G No 

(1)(iv) 

•	 G Yes G No 

deck? (1)(iii) 

•	 
 
 

floating roof and the oil-water separator wall, except as allowed
 
 

by both of the following: (1)( 
 
 

(1)(ii)
 
 

<	 	 the total gap area between the separator wall and the G Yes G No 

<	 	 G Yes G No 

5.	 	 

•	 G Yes G No 

seal? (1)(i) 

•	 G Yes G No 

used) free of holes, tears, and other openings? (1)(iv) 

5-53
 

Note: Answer questions in items “1" through “8" if you comply with the 

requirements for Option O2 to use a floating roof in §63.137(a)(2). 

Answer questions in items “8" and “9" if you comply with the 

requirements for Option O1 to use a fixed roof and closed-vent system in 

material, except during abnormal conditions (i.e., low flow rate)? 

§§63.137(e) i) and 60.693-2(a)

Is the floating roof is in good condition (i.e., free of defects such as 

§63.137(e)

Is a secondary seal installed above the primary seal? 

Does the secondary seal meet of the following requirements: 

is the seal and seal fabric free of holes, tears, an other openings? 

§63.137(e)

is the seal continuously attached along the edge of the floating 

§63.137(e)

does the seal completely cover the space between the edge of the

§§63.137(e) vi) and

60.693-2(a)

secondary seal does not exceed 6.7 square centimeters per 

meter of the separator wall perimeter? 

the maximum gap width between the separator wall and the 

seal does not exceed 1.3 centimeters at any point? 

Does the primary seal meet all of the following requirements: 

is the primary seal a liquid-mounted seal or a mechanical shoe 

§60.693-2(a)

is the seal fabric, seal envelope, or shoe (if a metallic shoe is 

§63.137(e)
Checklist 5: (cont’d)
 
 

Requirements for oil-water separators
 
 

A. Monitoring and Inspection Requirements Comments 

•	 if the primary seal is a liquid-mounted seal (e.g., foam or liquid- G Yes G No 

filled seal), is the seal in contact with the liquid between the wall 

of the oil-water separator and the floating roof? 

§60.693-2(a)(i)(A) 

•	 is the seal continuously attached along the edge of the floating G Yes G No 

deck? §63.137(e)(1)(iii) 

•	 does the primary seal form a continuous closure that completely
 

covers the annular space between the wall of the oil-water
 

separator and the edge of the floating roof, except as allowed by
 

both of the following: §§63.137(e)(1)(v) and 60.693-2(a)(1)(i)(B)
 

and (C)
 

<	 	 is the total area of gaps between the wall of the oil-water G Yes G No 

separator and the primary seal are less than 67 square 

centimeters per meter of the separator wall perimeter? 

<	 	 the maximum gap width between the wall of the oil-water G Yes G No 

separator and the seal is less than 3.8 centimeters at all 

points? 

6.	 G Yes G No 

with either of the following: (4) 

•	 
 

the drain opening area, or
 

•	 

7.	 Are all openings in the floating roof equipped with a gasketed cover, G Yes G No 

(2) 

8.	 Are gaskets, joints, lids, covers, and doors in good condition (i.e., not G Yes G No 

cracked, gapped, or broken)? (1)(vii) 

9.	 Are all openings kept closed except when in use (e.g., an opening is G Yes G No 

(1)( 

B. Comments 

1.	 Do you keep all records for at least 5 years (Option O1 or O2)? G Yes G No 

2.	 If you use a floating roof (Option 2), do records indicate all of the 

following: 

•	 G Yes G No 

secondary seal? ( (1) 

•	 G Yes
 

( (1)
 

If the floating roof is equipped with one or more emergency roof 

drains for removal of stormwater, is each emergency roof drain fitted 

§60.693-2(a) 

a slotted membrane fabric cover that covers at least 90 percent of 

a flexible fabric sleeve seal? 

seal, or lid, which is kept closed at all times, except during 

inspections and maintenance? §60.693-2(a) 

§63.137(e) 

in use during sampling, removal of material, inspection, 

maintenance, or repair)? §63.137(b) ii) and (d) 

Recordkeeping and Reporting Requirements 

§63.1367(a) 

that seal gap measurements are performed annually for the 

§§63.137(c) 2) and 63.147(b) 

that seal gap measurements are performed every 5 years for the 

primary seal? §§63.137(e) 1) and 63.147(b) 

5-54
 
 
Checklist 5: (cont’d)
 
 

Requirements for oil-water separators
 
 

B. Recordkeeping and Reporting Requirements Comments

• 	 that all of the following information is recorded for each seal gap G No 
 

measurement: §63.147(b)(3) G Yes 
 

< date of measurement? G Yes 
 

< raw data obtained? G Yes 
 

< calculations performed? G No 
 

G No 

G No 

3. 	 G Yes G No 
 


 

O2)? (1) 
 

4. 	 G Yes G No 
 


 

O2)? (1) 
 

5. 	 
 

identified, do you record and report all of the following in your next 
 

periodic report (Option O1 or O2): 
 

• 	 G Yes G No 

• 	 G Yes G No 

• 	 description of the failure? G Yes G No 

• 	 description of the nature of the repair? G Yes G No 

• 	 G Yes G No 

6. 	 
 

all of the following in your next periodic report (Option O2): 
 

• 	 G Yes G No 

• 	 G Yes G No 

• 	 G Yes G No 

Do you record the occurrence of each semiannual visual inspection 

of oil-water separators for improper work practices (Option O1 or 

§§63.137(d) and 63.147(b) 

Do you record the occurrence of each semiannual visual inspection 

of oil-water separators for control equipment failures (Option O1 or 

§§63.137(e) and 63.147(b) 

For each inspection during which a control equipment failure was 

§§63.137(e) and 63.146(c) 

date of the inspection 

identification of the oil-water separator having the failure? 

date the repair was made? 

When your seal gap measurements indicate a failure, do you include 

date of measurement? 

raw data obtained? 

calculations performed? 

a The emission suppression compliance options for oil-water separators are described in the section “What are my 

emission suppression compliance options?” beginning on page 5-4. 

5-55
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 6: Requirements for covers, fixed roofs, and enclosures that are used in emission 

suppression compliance options 

Facility Name: 
 

Facility Location: 
 

Facility TRI ID #: 
 

Inspector: 
 

Date: 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring and Inspection Requirements Comments 

Note: Inspections for leaks are not required if you maintain your cover, 

fixed roof, or enclosure (and the closed-vent system that is connected to it) 

under negative pressure. 

1. 	 G Yes G No 

fixed roof, and enclosure for leaks? (2)(iii)(B) 

2. 	 G Yes G No 

is successfully repaired or that it is nonrepairable? 

(4)(iii) 

B. Comments 

1.	 	 Do you keep all records for at least 5 years? 

2.	 	 Do your records identify all parts of the covers, fixed roofs, and 

enclosures that you designated as unsafe to inspect or difficult to 

inspect, and do the records explain why you assigned the 

designation? (

3.	 	 Do you have a written plan for inspecting the unsafe-to-inspect parts 

of the covers, fixed roofs, and enclosures as frequently as 

practicable? (6)( (1) 


 

year.
 

4.	 	 Do you have a written plan for inspecting the difficult-to-inspect 

years? (7)( (2) 

5.	 	 For each inspection during which no leaks are detected, do you 

records all of the following: (6) 

• 	 

• 	 

6.	 For each inspection during which a leak is detected, do you have the 

following records: (4) 

• 	 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G No 

G No 

G No 

G No 

G No 

G No 

G No 

Do you conduct semiannual sensory-based inspections of each cover, 

§63.1366(h)

After repairing a leak, do you use Method 21 to confirm that the leak 

§63.1367(f)

Recordkeeping and Reporting Requirements 

§63.1367(a) 

§63.1367(f) 1) and (2) 

§§63.1366(h) ii) and 63.1367(f)

Note: The inspections do not need to be more frequent than once per

parts of covers, fixed roofs, and enclosures at least once every 5 

§§63.1366(h) ii) and 63.1367(f)

§63.1367(f)

date of the inspection?

a statement that no leaks were detected?

§63.1367(f)

identification of the leaking equipment?

5-56 
Checklist 6: (cont’d)
 
 

Requirements for covers, fixed roofs, and enclosures
 
 

B. Recordkeeping and Reporting Requirements Comments

• 	 the date the leak was detected? 	 G Yes G No 

• 	 the date of the first attempt to repair the leak? 	 G Yes G No 

Note: The first attempt to repair the leak must be no later than 5 
 

calendar days after the leak is detected. §63.1366(h)(4)(i) 
 

• 	 maximum instrument reading measured by Method 21 after the G Yes G No 
 

leak is repaired or determined to be nonrepairable? 
 

• 	 all of the following if the leak is not repaired within 15 calendar 
 

days after the leak was discovered: 
 

<	 reason for the delay? G Yes G No 
 

<	 name, initials, or other form of identification of the person G Yes G No 
 

who decided repairs cannot be made without a shutdown? 
 

<	 expected date of successful repair? G Yes G No 
 

Note: Delay of repair until the next shutdown is allowed if the 
 


repair is technically infeasible without a shutdown, or if the 
 


emissions from immediate repair would be greater than the 
 


fugitive emissions likely from delay. 
 


• 	 dates of shutdowns that occur while the equipment is unrepaired? G Yes G No 

• 	 date of successful repair of the leak? 	 G Yes G No 

7. 	 G Yes G No 
 

leak is detected in your next periodic report? (2)( 
 

) 

Did you submit the records in “6" of all inspections during which a 

§63.1368(g) iii) and 

(xi 

5-57
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 7: Requirements for steam strippers (treatment compliance options T1, T2, T3A, T3B, 

and T3E)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring and Inspection Requirements Comments 

1.	 	 If you have a design steam stripper (Option T2), does it meet all of 

the following requirements: §63.138(d) 

•	 is the minimum active column height at least 5 meters? G Yes G No 

•	 does the countercurrent flow configuration have at least 10 actual G Yes G No 

trays? 

•	 is the steam flow rate at least 0.04 kilograms of steam per liter of G Yes G No 

wastewater feed? 

•	 is the temperature of the wastewater feed to the steam stripper (or G Yes G No 

the column temperature) at least 95°C? 

•	 is the wastewater liquid loading no greater than 67,100 liters per G Yes G No 

hour per square meter? 

•	 does it operate at nominal atmospheric pressure? 	 	 G Yes G No 

B. Recordkeeping and Reporting Requirements (Options T1, T2, T3A, T3B, or T3E) Comments

1.	 	 Do you keep all records for at least 5 years? §63.1367(a) G Yes G No 

2.	 	 

(5) 

•	 

•	 

•	 

Note: You do not have to monitor these parameters if you request
 

and receive approval to monitor alternative parameters.
 

3.	 	 

in “2"? 

G Yes 

G Yes 

G Yes 

G Yes 

G No 

G No 

G No 

G No 

Do you keep records of the continuous monitoring data for all of the 

following parameters: §63.147(b)

steam flow rate? 

wastewater feed mass flow rate? 

either wastewater feed temperature or column temperature? 

Do you keep records of the daily averages of each of the parameters 

§63.147(d) 

5-58
 
Checklist 7: (cont’d) 

Requirements for steam strippers 

B. Recordkeeping and Reporting Requirements (Options T1, T2, T3A, T3B, or T3E) Comments

4.	 	 For each inspection during which a control equipment failure was 
 

identified, do you record and report the following in the Periodic 
 

report: §63.146(c) 
 

•	 date of the inspection 	 	 G Yes G No 

•	 identification of the treatment unit? 	 	 G Yes G No 

•	 description of the failure? 	 	 G Yes G No 

•	 description of the nature of the repair? 	 	 G Yes G No 

•	 date the repair was made? 	 	 G Yes G No 

5.	 all of the following in your Periodic Reports if 
 

exceedances or excursions are $ 
 

during the reporting period: (2) 
 

•	 G Yes G No 
 


 


 

•	 G Yes G No 
 


 

•	 operating logs and operating scenarios? 	 G Yes G No 

Do you submit 

1 percent of the total operating time 

§63.1368(g) 

all monitoring data (including daily averages) for all operating 

days or blocks when the average of a monitored parameter is 

outside the range specified in your NOCSR or operating permit? 

identification of all operating days or blocks when insufficient 

monitoring data are collected? 

a The treatment compliance options for steam strippers are described in the section “What treatment compliance 

options do I have for my wastewater streams?” beginning on page 5-10. 

5-59
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 8: Requirements for treatment units other than steam strippers (treatment compliance 

options T1 and all versions of T3)a 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. All questions apply to option T1 and all versions of option T3, unless noted. 

A. Monitoring and Inspection Requirements Comments 

1.	 	 Are monitoring devices present to conduct monitoring that was G Yes G No 

approved by the Administrator or permitting authority? §63.143(c) 

and (d) 

B. Recordkeeping and Reporting Requirements Comments

1.	 	 Do you keep all records for at least 5 years? §63.1367(a) G Yes G No 

2.	 	 Do you have records of monitoring approved by the Administrator or G Yes G No 
 


permitting authority? §63.147(b)(4) 
 


3.	 	 If any of the parameters are monitored continuously, do you keep G Yes G No 
 


records of the daily averages? §63.147(d) 
 


4.	 	 If you use a biological treatment unit and you comply with Option G Yes G No 
 


T3G or T3H), do you have records of the Fbio determination? 
 


5.	 	 Do you submit all of the following in your Periodic Reports if 
 


exceedances or excursions are $1 percent of the total operating time 
 


during the reporting period: §63.1368(g)(2) 
 


•	 all monitoring data (including daily averages) for all operating G Yes G No 
 


days or blocks when the average of a monitored parameter is 
 


outside the range specified in your NOCSR or operating permit? 
 


•	 identification of all operating days or blocks when insufficient G Yes G No 
 


monitoring data are collected? 
 


•	 operating logs and operating scenarios? 	 	 G Yes G No 

a The treatment compliance options for all treatment units are described in the section “What treatment compliance 

options do I have for my wastewater streams?” beginning on page 5-10. 

5-60
 
 
Checklist 9: Requirements for heat exchange systems (compliance options HE1 and HE2)a 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: Use section A of this checklist to determine if your heat exchange system is subject to control 
 

requirements. If it is, then a “yes” response to a question in section B of this checklist means compliance with 
 

that requirement, and a “no” response means noncompliance with the requirement. If the requirement is not 
 

applicable, indicate “N/A” in the comments column. 
 

A. Applicability Comments 

1.	 	 Does your heat exchange system meet any of the following 

conditions? §63.104(a) 

•	 Is the minimum pressure on the cooling water side of the heat G Yes G No 

exchange system at least 35 kPa greater than the maximum 

pressure on the process side? 

•	 Do you use an intervening fluid between the process and the G Yes G No 

cooling water where the intervening fluid meets both of the 

following: 

<	 	 contains less than 5 percent by weight of HAP listed in
 
 

Table 4 to subpart F of 40 CFR part 63, and
 
 

<	 	 is not sent through a cooling tower or discharged? 

•	 Do you have a once-through heat exchange system that is subject G Yes G No 

to an NPDES permit with an allowable discharge limit that is 

either 1 ppm or less above the influent concentration or 10 

percent or less above the influent concentration? 

•	 Do you have a once-through heat exchange system that is subject G Yes G No 

to an NPDES permit that includes all of the following: 

<	 	 requires monitoring of a parameter(s) or condition(s) to 
 
 

detect a leak of process fluids into cooling water, and
 
 

<	 	 specifies or includes the normal range of the parameter(s) or 
 
 

condition(s), and
 
 

<	 	 requires monitoring for the parameter(s) no less frequently 
 
 

than monthly for the first 6 months and quarterly thereafter, 
 
 

and
 
 

<	 requires you to report and correct leaks to the cooling water 

when the parameter or condition is outside the normal G Yes G No range? 

•	 Do you have a recirculating heat exchange system that is used to 
 
 

cool process fluids that contain less than 5 percent by weight of
 
 

total HAP listed in Table 4 to subpart F of part 63?
 
 

5-61
 
 
Checklist 9: (cont’d)
 
 

Requirements for heat exchange systems
 
 

A. Applicability Comments 

•	 Do you have a once-through heat exchange system that is used to G Yes G No 

cool process fluids that contain less than 5 percent by weight of 

total HAP listed in Table 9 to subpart G of part 63? 

Note: If you answer “yes” to any of the questions in this section,
 
 

do not continue; your heat exchange system is exempt from
 
 

control requirements. If you answer “no” to all of the questions
 
 

in this section, proceed to the questions in section B.
 
 

B. Recordkeeping and Reporting Requirements Comments

1.	 Do you keep all records for at least 5 years? §63.1367(a) G Yes G No 

2.	 

includes all of the following: (1) 

•	 G Yes G No 

•	 G Yes G No 

reliably indicate a leak? 

•	 G Yes G No 

including supporting data and calculations? 

•	 G Yes G No 

•	 G Yes G No 

3.	 

(1) 

•	 G Yes G No 

•	 G Yes G No 

•	 G Yes G No 

•	 G Yes G No 

•	 G Yes G No 


 

repair provisions are in effect.
 

If you comply with option HE2, do you have a monitoring plan that 

§63.104(c) 

description of the parameter(s) or condition(s) to be monitored? 

explanation of how the selected parameter(s) or condition(s) will 

the parameter level(s) or condition(s) that constitute a leak, 

your monitoring frequency? 

the records that you will maintain? 

When you detect a leak, do you have all of the following records: 

§63.104(f) 

identification of the leak? 

date when the leak was detected? 

date(s) of efforts to repair the leak? 

the method or procedure used to confirm repair of the leak? 

date the repair was confirmed? 

Note: confirmation of repair is not applicable while delay of 

5-62
 
Checklist 9: (cont’d)
 
 

Requirements for heat exchange systems
 
 

B. Recordkeeping and Reporting Requirements Comments

4.	 If you have delayed repair of a leak, do you have documentation for G Yes G No 
 

either of the following, along with a schedule for completing the 
 

repair as soon as practical: §63.104(e)(2) 
 

•	 the basis of a determination that a shutdown for repair would
 
 

cause greater emissions than the emissions likely to result from
 
 

delaying repair, or
 
 

•	 evidence that the necessary parts or personnel were not available
 
 

to make the repair?
 
 

Note: Documentation is not necessary if you isolate the
 
 

equipment from the process, or if you have a planned shutdown
 
 

scheduled within the next 2 months after you determine that a
 
 

delay of repair is necessary. §63.104(e) introductory text and
 
 

(e)(1)
 
 

5.	 all of the following in your Periodic Reports if you 
 

(2) 
 

•	 	 G Yes G No 

•	 	 G Yes G No 

•	 whether or not the leak has been repaired? 	 G Yes G No 

•	 	 G Yes G No 

•	 G Yes G No 
 

either of the reasons listed in question B.4? 
 

•	 G Yes G No 
 

repaired) or the date the leak was successfully repaired? 
 

Do you submit 

delay repair of a leaking heat exchange system: §63.104(f) 

Identification of the leak? 

date the leak was detected? 

reason(s) for any delay of repair? 

documentation of emissions estimates, if repair is delayed for 

either the expected date of repair (if the leak has not yet been 

a The compliance options for heat exchange systems are described in the section “What are my compliance options 

for heat exchange systems?” beginning on page 5-30. 

5-63
 
 
[This page intentionally left blank.] 
Chapter 6 - Complying with requirements for equipment leaks 

What equipment leaks are regulated by Subpart MMM? 

Subpart MMM regulates equipment leaks from equipment in “organic HAP service.” The 

equipment leak provisions apply to all of the following types of equipment [§63.1363(a)(1)]: 

• pumps 

•	 compressors 

• agitators	 

Definition: “In organic HAP service 

fluid that is at least 5 percent organic HAP by weight. 

” means that the 

equipment component either contains or contacts a 

• pressure relief devices 

• sampling connection systems
 
 

• open-ended valves or lines
 
 

• valves 

• connectors 

• instrumentation systems 

If you have equipment subject to both Subpart MMM and other air regulations under 40 CFR 

parts 60 or 61, you are only required to comply with Subpart MMM [§63.1362(a)(2)]. 

Equipment leak provisions apply at all times except when the lines of a non-operating PAI 

process unit are drained and depressurized [§63.1360(e)(2)]. 

How do I identify equipment subject to the equipment leak 

provisions? 

You must identify each piece of equipment that is subject to the equipment leak provisions so it 

can be distinguished from equipment not subject to the provisions. You do not have to 

physically tag the equipment unless you wish to do so. Instead, you can mark the equipment on 

a plant site plan, in log entries, or by designating process boundaries with waterproof 

identification. [§63.1363(a)(7)] 

Note: If you make changes to the process or equipment subject to the leak detection requirements, you must 

update the equipment identification, if needed, within 15 calendar days of the end of each monitoring period for 

that component. 

6-1
 
Leaks are detected by sight, sound, odor, or monitoring. When a leak is detected, you must 

attach a visible, weatherproof identification to the leaking equipment. The identification may be 

removed under either of the following circumstances: [§63.1363(a)(10)] 

•	 after the leak has been repaired if the equipment is not a valve in light liquid or gas/vapor 

service 

•	 when no leak is detected by follow-up monitoring on a valve in light liquid or gas/vapor 

service 

Follow-up monitoring for valves is described in 

§63.1363(e)(7)(iii) of subpart MMM. 

What equipment is exempt? 

All of the following are exempt from the equipment leak provisions [§63.1363(a)(5) through 

(9)]: 

•	 lines and equipment that do not contain process fluids 

•	 utilities and other nonprocess lines that do not combine their materials with process fluids 

they serve 

•	 bench-scale processes 

•	 equipment in vacuum service 

•	 equipment in organic HAP service less than 300 hours per year 

What compliance options do I have for my equipment leaks? 

For equipment in organic HAP service, you have the following five compliance options: 

Option 1: Use a leak detection/repair program [§63.1363(b), (c), (d), and (e); and 

sections of Subpart H referenced from §63.1363(b)] 

Implement a leak detection and repair (LDAR) program. 

Option 2: Use enclosed equipment and transport emissions through a closedvent system to a control device [§63.1363(b)(3)(ii), §63.172, and §63.179] 

Capture equipment leak emissions and transport them through a closed-vent system to a 

control device. This option applies to an entire process unit that is enclosed, and emissions 

are transported through a closed-vent system to a control device. It also applies to pumps, 

6-2
 
 
agitators, compressors, pressure relief devices, and sampling connection systems that are 

equipped with a closed-vent system to transport leaking liquid, emissions, or samples to a 

control device (or a process). 

Option 3: Use pressure testing [§63.1363(b)(3)(iv), §63.178(b)] 

Pressure test the process to demonstrate compliance for equipment for which periodic 

monitoring would be required under option 1. Also comply with the option 1 requirements 

for compressors, pressure relief devices in gas/vapor service, open-ended valves and lines, 

and sampling connection systems. 

Option 4: Alternative monitoring for batch processes [§63.1363(b)(3)(iv), 

§63.178(c)] 

Implement an LDAR program as in option 1, except the monitoring frequency may be 

reduced for some batch components that operate less than 75 percent of the time. 

Option 5: Alternative means of emission limitation [§63.1363(b)(2), §63.177] 

Apply for permission to use an alternative equipment, design, or operational requirement or 

work practice standard. 

The requirements and exceptions for all of the options as applied to different types of equipment 

are summarized in Table 6-1 (page 6-4). Additional details are also provided later in this 

chapter. 

How do I implement a leak detection and repair (LDAR) program under 

Option 1? 

Your requirements under an LDAR program depend on what type of equipment you are using. 

The LDAR program is broken down into the following eleven categories: 

• pumps in light liquid service 

Definition. In light liquid service means that a piece of equipment in organic HAP service contains a 

liquid that meets all of the following conditions: 

(1)	 The vapor pressure of one or more of the organic compounds is greater than 0.3 kPa at 20°C; 

(2)	 The total concentration of the pure organic compounds constituents having a vapor pressure 

greater than 0.3 kPa at 20°C is equal to or greater than 20 percent by weight of the total 
 


process stream; and 
 


(3)	 The fluid is a liquid at operating conditions. 
 


(Note: Vapor pressures may be determined by the methods described in 40 CFR 60.485(e)(1).) 

6-3
 
TABLE 6-1. General Requirements and Exceptions of the Equipment Leak Provisions 

Except for...a 

For the following equipment... Your equipment leak requirements are... 

Pumps in light liquid service and • quarterly monitoring for leaks (or • unsafe to monitor or inaccessible equipment 

agitators in gas/vapor service and in monthly if calculated percent leaking • pumps/agitators with dual mechanical seal light liquid service pumps exceeds specified level) system with barrier fluid (Option 1) • weekly visual inspections • pumps/agitators with no externally actuated 

• repair of leaks shaft 

• pumps/agitators with closed-vent systems 

and control devices 

• pumps/agitators at unmanned sites 

6-4
 
 

Open-ended valves or lines seal valves or lines with a cap, blind • 

(Option 1) flange, plug, or a second valve 

••

capped or equipped with a double block and bleed system 

Valves in gas/vapor service and light • • 

liquid service • • 

(Option 1) of percent leaking valves

•

Compressors • • 

(Option 1) that includes barrier fluid system control devices 

• • 

reading of <500 ppm 

Pressure relief devices in gas/vapor • 

service (Option 1) • 

disks 

a closed-purge, closed-loop, or closed-vent 

(Option 1) system without purge 

valves/lines designed to open automatically 

in emergency 

valves/lines containing materials which 

would autocatalytically polymerize 

valves/lines that would be hazardous if 

initial monitoring for leaks unsafe and difficult to monitor valves 

repeat monitoring based on calculation inaccessible valves 

repair of leaks 

equip compressors with a seal system compressors with closed-vent systems and 

repair of leaks compressors with leak detection instrument 

leak detection instrument reading of <500 pressure relief devices with closed-vent ppm (except during pressure releases) systems and control devices 

pressure relief devices with upstream rupture 

Sampling connection systems in-situ sampling systems and sampling systems 
TABLE 6-1. (cont’d) 

Except for...a 

For the following equipment... Your equipment leak requirements are... 

Pumps, valves, connectors, and • monitor equipment when sensory potential leaks that are repaired before 

agitators in heavy liquid service; detection methods provide evidence of monitoring 

instrumentation systems; and potential leaks 

pressure relief devices in liquid • repair of leaks 

service (Option 1) 

6-5
 
 

Connectors in gas/vapor service and • • 

in light liquid service • broken seal 

(Option 1) of percent leaking connectors • 

• 

• • • • 

Enclosed equipment with closed- • percent reduction, outlet concentration, 

vent systems and control devices • 40 CFR part 264, subpart BB, or in 40 CFR 

(Option 2) • part 265, subpart BB 

• 

Pressure testing • pressure testing is not required for routine seal 

(Option 3) reconfigured breaks that are unrelated to reconfiguration of 

• • 

Monitoring for batch processes • 

(Option 4) as required by option 1 valves and agitators that are not operated full 

• • 

initial monitoring for leaks connectors that have been opened or have a 

repeat monitoring based on calculation 

screwed connectors with a small inside 

repair of leaks diameter 

ceramic or ceramic-lined connectors 

unsafe and difficult to monitor connectors 

inaccessible connectors 

credits for removed connectors 

control devices subject to monitoring, 

or equipment operating requirements reporting, and recordkeeping requirements in 

monitoring for use of bypass lines 

inspections 

repair of leaks 

pressure test each time equipment is 

pressure test at least annually if the equipment 

equipment is not reconfigured 

repair leaks and retest 

apply equipment standards and monitor monitoring frequency may be reduced for 

monitor after reconfiguration time 

repair leaks 

a Note that equipment exempted from the general requirements often still must meet specified design criteria, must be monitored less fr

other requirements. Details are presented later in this chapter. 
• agitators in gas/vapor service and light liquid service 

Definition. In gas/vapor service means that a piece of 

equipment in organic HAP service contains a gas or 

vapor at operating conditions. 

• open-ended valves or lines 

• valves in gas/vapor or light liquid service 

• compressors 

• pressure relief devices in gas/vapor service 

• sampling collection systems 

• pump, valves, connectors and agitators in heavy liquid service 

Definition. In heavy liquid service means that the piece 

of equipment in organic HAP service is not in gas/vapor 

or light liquid service. 

• instrumentation systems 

• pressure relief devices in liquid service 

• connectors in gas/vapor service and in light liquid service 

Note: Equipment in gas/vapor and light liquid service are subject to different requirements than equipment in 

heavy liquid service. 

For most equipment, you implement an LDAR program by monitoring in accordance with one 

or both of the following procedures: 

• by using Method 21 as specified in §63.1363(b)(3)(v) and §63.180 of the HON 

• by visual or other sensory means of detection 

The frequency of Method 21 monitoring for pumps in light liquid service, valves in gas vapor 

service or light liquid service, and connectors in gas/vapor service or light liquid service 

depends on how many leaked in the preceding 

monitoring period(s). You have the option of 

how to group processes for use in calculating Definition. A group of processes means all of the 

equipment associated with processes in a building, the percentage of these components that leak. processing area, or facility-wide. A group of You have even more grouping possibilities processes may consist of a single process.

for valves because you may establish groups 

using subsets of the valves within groups of 

6-6 
processes, as long as less than 2 percent of the valves in the overall group of processes from 

which the subsets were created are leaking (see requirements for subgrouping in “What LDAR 

requirements apply to valves in gas/vapor or light liquid service (Option 1)?” for more 

information). 

For other equipment, your LDAR program consists of work practice procedures or equipment 

design requirements. 

Additional details of LDAR programs for each of the eleven categories of equipment are 

provided later in this chapter. 

What are the LDAR requirements for Pumps in Light Liquid Service 

and Agitators in Gas/Vapor Service and Light Liquid Service 

(Option 1)? 

Requirements for pumps and agitators under Option 1 include all of the following [§63.1363(c)]: 

• monitor equipment for leaks using Method 21 

• perform visual inspections 

• repair leaks 

In addition, pumps and agitators with specific design or operational features are exempt from 

some of these requirements. The requirements and exemptions are detailed below. 

Monitoring for leaks 

You must monitor for leaks at least once each quarter using the monitoring method described in 

§63.180(b) of subpart H [§63.1363(c)(2)(i)]. This method requires you to use a leak detection 

instrument. Your equipment is considered leaking if you get any of the following instrument 

readings: [§63.1363(c)(2)(ii)] 

• $10,000 ppm for agitators 

• $2,000 ppm for pumps 

You must calculate the percentage of pumps that leak using the procedure outlined in 

§63.1363(c)(4). Prior to the first monitoring period 

you must decide what groups of processes to 

develop (see page 6-6 for the definition of “group of 

processes”). You then calculate the percent leakers 

in each group of processes for each monitoring 

period. 

You do not have to calculate the percentage 

of agitators that are leaking. 

6-7
 
 
You must monitor all of the pumps in the group of processes monthly if (based on a 1-year 

rolling average) either of the following apply: 

•	 10 percent or more of the pumps in
 
 

the group of processes leak 
 


•	 three or more pumps in the group of 
 


processes leak (if the group of 
 


processes has less than 30 pumps)
 
 

You may return to quarterly monitoring after the 1-
 


 

year rolling average value drops below 10 percent (or 

less than 3 pumps leak). 

All pumps in organic HAP service must be included in the calculation of percent leaking pumps, 

except for the following: 

•	 pumps designed with no externally actuated shaft penetrating the pump housing
 
 

[§63.1363(c)(6)]
 
 

•	 all pumps in a group of processes if more than 90 percent of the pumps in the group of 

processes are either of the following: [§63.1363(c)(9)] 

< equipped with a dual mechanical seal system that includes a barrier fluid system 

< designed with no externally actuated shaft penetrating the pump/agitator housing 

•	 pumps that you designate as difficult to monitor 

•	 pumps that are in compliance with option 2 

Note: Pumps that are excluded from the percent leaking calculation also never have to be monitored more 

frequently than quarterly. 

Visual inspections 

Each pump and agitator must be checked weekly by visual inspection for signs of liquids 

dripping from the pump or agitator seal. If you notice signs of liquids dripping from the seal, 

you must do either of the following: [§63.1363(c)(2)(iii)] 

•	 stop the liquid from dripping 

•	 monitor the pump or agitator using a leak detection instrument (follow the procedure 

specified in §63.180(b) to determine if you have a leak; you have a leak if the instrument 

reading is $10,000 ppm for agitators or $2,000 ppm for pumps) 

Repair of leaks 

You must repair leaks as soon as possible after they are detected, unless a delay of repair is 

allowed. See “What are my leak repair requirements?” for more information. 

6-8
 
 
Exceptions 

There are several exemptions to the requirements for implementing an LDAR program for 

Pumps in Light Liquid Service and Agitators in Gas/Vapor Service and Light Liquid Service. 

Exemptions include all of the following: 

Pumps that are difficult to monitor and agitators that are unsafe or difficult to monitor ­

•	 Equipment that is unsafe or difficult to monitor is subject to special monitoring 

requirements instead of the quarterly or monthly monitoring described above, and pumps 

that are difficult to monitor also are excluded from the calculation of the percent leaking 

pumps. See “What if equipment is unsafe or difficult to monitor?” (page 6-28) for more 

information. 

Pumps or agitators with special design features - 

•	 Pumps or agitators equipped with a dual mechanical seal system that includes a barrier 

fluid system are exempt from the quarterly or monthly monitoring provisions in 

§63.1363(c)(2) provided that all of the following are performed: [§63.1363(c)(5)] 

<	 	 your dual mechanical seals meet one of the following criteria: 

 ̃	 	are operated with a barrier fluid pressure that is always greater than the 

pump/agitator stuffing box pressure 

 ̃	 	are equipped with a barrier fluid degassing reservoir connected by a closed-vent 

system to a control device 

 ̃	 	are equipped with a closed-loop system that purges the barrier fluid into a process 

stream 

<	 	 the barrier fluid is not in light liquid service 

<	 	 each barrier fluid system has a sensor that will detect failure of the seal system, the 

barrier fluid system, or both. The sensor must be observed daily or have an alarm 

(unless the pump is at an unmanned plant site). 

<	 	 each pump/agitator must be visually inspected each week to see if liquids are dripping 

from the pump/agitator seal. If liquids are dripping, you must either stop the drips or 

monitor the seal with a leak detection instrument to determine if there is a leak of 

organic HAP in the barrier fluid. You have a leak if the instrument reads 

$10,000 ppm for agitators or $2,000 ppm for pumps, and you must repair the leak as 

described in “What are my leak repair requirements?” (page 6-26). 

<	 	 you have determined the criteria that you will use to indicate failure of the seal 

system, the barrier fluid system, or both. If a leak is detected based on your criteria 

6-9
 
then you must repair the leak as described in “What are my leak repair requirements?” 

(page 6-26). 

Note: Pumps with dual mechanical seals also must be included in the percent leaking calculation 

•	 Any pump or agitator designed with no externally actuated shaft penetrating the 

pump/agitator housing is exempt from all of the monitoring, visual inspection, repair, and 

calculation of percent leaking pumps provisions. [§63.1363(c)(6)] 

•	 Pumps and agitators with a closed-vent system that captures and transports leaking 

material from the seals to a process or control device are complying with option 2 and are 

exempt from the monitoring, visual inspection, repair, and calculation of percent leaking 

pumps provisions under option 1. [§63.1363(c)(7)] 

•	 Pumps and agitators at unmanned plant sites are exempt from weekly visual inspections 

and daily sensor observations (for pumps/agitators with dual mechanical seal and barrier 

fluid systems). However, each pump/agitator must be visually inspected at least monthly 

or more frequently if possible. [§63.1363(c)(8)] 

What are the LDAR requirements for open-ended valves or lines 

(Option 1)? 

You comply with the LDAR requirements for open-ended valves or lines under Option 1 by 

sealing the open end using any of the following devices: [§63.1363(d)(1)(i)] 

•	 a cap 

•	 a blind flange 

•	 a plug 

•	 a second valve 

The mechanism you use to seal the open end must meet both of the following: 

[§63.1363(d)(1)(ii)] 

•	 it must be in use at all times except:
 
 

< during operations requiring process fluid flow through the valve or line
 
 

< during maintenance
 
 

< during repair
 
 

•	 it must be in place within 1 hour after any of the excepted periods listed above 

Note: If you use a second valve, you must close the valve on the process fluid end before closing the second 

valve. [§63.1363(d)(2)] 

If you use a double block and bleed system, you may leave the bleed valve or line open during operations that 

require venting the line between the block valves. [§63.1363(d)(3)] 

6-10
 
Exemptions 

You do not have to comply with the requirements to seal the open-ended valve or line if any of 

the following situations apply to the open-ended valve or line: [§63.1363(d)(4) through (6)] 

•	 it contains material which would autocatalytically polymerize 

•	 it contains material which could cause a safety hazard if capped or equipped with a double 

block and bleed system 

•	 it is designed to open automatically as part of an emergency shutdown system in the event 

of a process upset 

What LDAR requirements apply to valves in gas/vapor or light liquid 

service (Option 1)? 

For valves in gas/vapor or light liquid service you must implement an LDAR program by doing 

all of the following steps: 

Step 1: Identify your valves: 

•	 identify all valves in PAI process units [§63.1363(a)(7)] 

Step 2: Identify valves subject to special monitoring requirements: 

•	 identify each valve that meets one of the following conditions: [§63.1363(f)] 

< is unsafe to monitor For more information, see “What if equipment 

< is difficult to monitor is unsafe or difficult to monitor?” 

Step 3: Perform initial monitoring: 

•	 monitor all valves (except those identified in Step 2) using a leak detection instrument 

within 1 year after the compliance date (e.g., by 12/23/04). Use Method 21 as specified in 

§63.180(b) of subpart H. [§63.1363(e)(2) and (e)(3)(i)] 

Step 4: Repair all leaks 

•	 if you find a leaky valve, you must repair it as soon as possible, unless a delay of repair is 

allowed. See “What are my leak repair requirements?” (page 6-26) for more information. 

Note: You have a leak if the instrument reading is 500 ppm or greater [§63.1363(e)(3)(ii)]. 

•	 re-monitor the valve within 3 months of repair, but you do not need to include these
 
 

monitoring results in the calculation of percent leakers described in Step 5
 
 

[§63.1363(e)(7)(iii) and (e)(6)(ii)]
 
 

Note: Days when a valve is not in organic HAP service are not included in the 3-month period. 

6-11 
Step 5: Calculate your percentage of leaking valves 

•	 calculate the percentage of leaking valves in a group of valves, excluding nonrepairables 

Your choices for groups 
 

consist of any 
 

[§63.1363(b) and (e)(6)(i)] 
 

The results of these calculations are used to 

determine the frequency of subsequent 

monitoring, as described in Step 6. 

<	 

<	 

<	 

instructions on how to create a subgroup) 


 

(6)( 
 

nonrepairable 

[§63.1363(e)(6)(iv)] 

Step 6: 

•	 

And the percentage of According to 
 

valves you have for all leaking valves in the group §63.1363(e)(6)(iii) and this 
 

groups is... or subgroup is...a every...b section of the rule... 
 

$250 	 $2 percent 
 

<2 percent 
 

<1 percent 
 

§63.1363(e)(4)(i) 

§63.1363(e)(4)(ii) 

§63.1363(e)(4)(iii) 

§63.1363(e)(4)(iv) 

2 years 	 §63.1363(e)(4)(v) 

<250 	 §63.1363(e)(9) 

<1 percent 	 §63.1363(e)(4)(iii), 

(e)(4)(iv), (e)(4)(v), and 

2 years 	 (e)(9) 

<0.5 percent 

<0.25 percent 

<0.5 percent 

<0.25 percent 

[§63.1363(e)(6)(ii)]. You may define groups 

that are most appropriate for your site-specific 

circumstances. 

 combination of the following: 

create a group of all the valves from a single process 

create a group of all the valves from multiple processes 

create multiple subgroups of all the valves from multiple processes (see page 6-13 for 

Note: To create or revise groups of processes after the implementation date, you must revise your permit 

[§63.1363(e) i)]. 

To calculate the percentage of leaking valves in a group or subgroup, you may exclude 

 valves (up to 1 percent of the total number of valves in the group or subgroup), 

except you must include the nonrepairable valve as a leaking valve in the calculation of percent 

leakers for the first monitoring period after you identify it as leaking. 

 Continuous monitoring for leaks 

After your initial round of monitoring, you must monitor for leaks as follows: 

If the total number of Then you must 

monitor at least once 

month 

3 months 

6 months 

12 months 

no determination required 3 months 

6 months 

12 months 

a	 	 Percentages are averaged from the data collected during the previous two monitoring periods if the group or 

subgroup was monitored every year or every 2 years, and percentages are averaged from the previous three 

monitoring periods if the group or subgroup was monitored every 1 month, 3 months, or 6 months. 

[§63.1363(e)(6)(iii)] b	 	 All valves that you find to be leaking must be repaired and remonitored within 3 months as specified in step 4. 

[§63.1363(e)(7)] 

6-12 
Your requirements for subgrouping valves include all of the following: 

•	 you may subgroup valves within a group of processes if less than 2 percent of the valves 

in the group leaked in the last monitoring period [§63.1363(e)(5)(i)] 

•	 you must check for compliance with the 2 percent cutoff for the group every 6 months 

[§63.1363(e)((5)(iii)] 

•	 anytime you find more than 2 percent in the group to be leaking, you must revert to
 

monitoring the group as a whole (i.e., monitor all of the valves in the group monthly)
 

[§63.1363(e)(5)(iii)]
 

•	 when you create subgroups, you must include in the most frequently monitored subgroup 

all valves that meet either of the following conditions [§63.1363(e)(5)(ii)(A)]: 

< those with less than 1 year of monitoring data
 
 

< those that have not been monitored in the last 12 months
 
 

•	 you may move any valve from a less frequently monitored subgroup to a more frequently 

monitored subgroup if you take all of the following actions before and after the move 

[§63.1363(e)(5)(ii)(B)]: 

<	 	 before the move: monitor the valve during the most recent monitoring period for the 

less frequently monitored subgroup 

<	 after the move: include the first monitoring results in your next calculation of the 

percentage leaking valves for the less frequently monitored subgroup 

•	 you may move a valve from a more frequently monitored subgroup to a less frequently 

monitored subgroup if the valve has not 

leaked for the period of the less Nonrepairable valves may not be moved to a less frequently monitored subgroup frequently monitored subgroup.

[§63.1363(e)(5)(ii)(C)] 

Note: Additional recordkeeping and reporting is required for valves in subgroups [§63.1363(e)(5)(iv) and 

(v)]. See Table 6-2 in the section “What records must I keep for my equipment leaks?” (page 6-31) and the 

section “What reports must I submit” (page 6-37) for more information. 

What LDAR requirements apply to compressors (Option 1)? 

To comply with the LDAR requirements for compressors (option 1), you must do all of the 

following: 

•	 equip your compressors with a seal system that includes a barrier fluid system and meets 

any one of the following [§63.164(a) and (b)]: 

<	 it is operated with the barrier fluid pressure greater than the compressor stuffing box 

pressure 

6-13
 
<	 	 it is equipped with a barrier fluid system degassing reservoir that is routed to a process 

or connected by a closed-vent system to a control device 

<	 	 it is equipped with a closed-loop system that purges the barrier fluid directly into a 

process stream 

Note: the barrier fluid must not be in light liquid service. 

• 	 equip the barrier fluid system with a sensor that will detect a system failure [§63.164(d)] 

• 	 determine a criterion for the sensor that indicates the failure [§63.164(e)(2)] 

•	 observe the sensor daily or equip it with an alarm (this requirement does not apply if the 

compressor is located at an unmanned plant site)[§63.164(e)(1)] 

Note: you have a leak if the sensor detects a failure [§63.164(f)] 

•	 repair leaks as soon as possible, unless a delay of repair is allowed. See “What are my 

leak repair requirements?” (page 6-26) for more information. 

Exceptions 

The LDAR requirements do not apply to compressors in organic HAP service if you do any of 

the following: 

•	 comply with option 2 by equipping the compressor with a closed-vent system to capture 

and transport leaks back to a process or to a control device [§63.164(h)] 

•	 designate that the compressor operates with an instrument reading of less than 500 ppm 

above background based on monitoring using Method 21 at all of the following times 

[§63.164(i)]: 

< when you make the designation
 
 

< annually
 
 

< any other time requested by the Administrator
 
 

What LDAR requirements apply for pressure relief devices in 

gas/vapor service (Option 1)? 

To comply with the LDAR requirements for pressure relief devices in gas/vapor service (option 

1), you check your devices for leaks after each pressure release as follows: [§63.165(b)] 

•	 return the pressure relief device to normal operating condition as soon as possible, but not 

more than 5 days after the pressure release, unless a delay is allowed. See “What are my 

leak repair requirements?” (page 6-26) for more information. 

6-14
 
•	 monitor the pressure relief device within 5 days after the pressure release (and the 

pressure relief device has been returned to organic HAP service) using a leak detection 

instrument 

•	 the instrument reading must be less than 500 ppm above background 

Note: To measure leaks, use Method 21 and the procedures specified in §63.180(c) of subpart H. You may 

either adjust the instrument reading to account for background levels, or you may directly compare the reading 

to the 500 ppm limit. 

Exceptions 

You are exempt from the LDAR requirements for pressure relief devices in gas/vapor service if 

either of the following apply: 

•	 you comply with Option 2 by capturing emissions from releases and transporting them 

through a closed-vent system to a process or control device. [§63.165(c)] 

•	 if your pressure relief device is equipped with a rupture disk upstream of the pressure 

relief device, and you replace the rupture disk as soon as possible (but no more than 5 

days) after a pressure release. [§63.165(d)] 

What LDAR requirements apply for sampling connection systems 

(Option 1)?

To comply with the LDAR requirements for sampling connection systems (option 1), you must 

meet certain design requirements. Each of 

your sampling connection systems must You do not have to collect or capture gases displaced have a closed-purge, closed-loop, or during filling of the sample containers. [§63.166(a)]. 

closed-vent system that does one of the 

following: [§63.166(b)]: 

•	 returns purged process fluid directly to the process line 

•	 collects and recycles purged process fluid to a process 

•	 captures and transports purged process fluid to a control device 

•	 collects, stores, and transports purged process fluid to a waste management unit, TSDF, or 

permitted waste management facility 

Note: Your waste management unit must meet the control requirements specified in subpart G for Group 1 

wastewater (see Chapter 5 for details) if the purged process fluid contains any of the HAP listed in Table 9 to 

subpart G. 

6-15
 
 
Exceptions 

The following sampling systems are exempt from the LDAR requirements for sampling 

connection systems: [§63.166(c)] 

•	 in-situ sampling systems 

•	 sampling systems without purges 

all of the following [§§63.1363(b)(2) and 63.169]: 

•	 

• 

Monitoring for leaks 

either of 

•	 

•	 
 

Follow Method 21 and the procedures described in §63.180(b).
 

A leak is detected for ... 

agitators 10,000 ppm 

2,000 ppm 

valves 500 ppm 

connectors 500 ppm 

500 ppm 

pressure relief devices 500 ppm 

What LDAR requirements apply for pumps, valves, connectors, and 

agitators in heavy liquid service; instrumentation systems; and 

pressure relief devices in liquid service (Option 1)?

To comply with the LDAR requirements for pumps, valves, connectors, and agitators in heavy 

liquid service; instrumentation systems; and pressure relief devices in liquid service under 

Option 1 you must do 

monitor equipment for leaks 

repair leaks 

Both types of requirements are detailed below. 

If you see, hear, notice an odor, or otherwise detect a potential leak, then you must do 

the following: 

consider the equipment to be leaking 

monitor for leaks within 5 days of noticing the potential leak using a leak detection 

instrument. 

The following table summarizes instrument readings that are considered to be a leak: 

If the instrument reading is ... 

pumps handling polymerizing monomers 5,000 ppm 

pumps in food or medical service 

instrumentation systems 

6-16 
Repair of leaks 

You must repair leaks as soon as possible after they are detected, unless a delay of repair is 

allowed. See “What are my leak repair requirements?” (page 6-26) for additional details. 

Repair of potential leaks means any of the following: [§63.169(c)(3)] 

•	 you can no longer see, hear, smell, or otherwise detect the potential leak 

•	 you see no bubbles at potential leak sites during a leak check with soap solution 

•	 the system will hold a test pressure 

What LDAR requirements apply for connectors in gas/vapor or light 

liquid service (Option 1)? 

To comply with the LDAR requirements for connectors (option 1), you must do all of the 

following: 

Step 1: Identify your connectors 

Identify all connectors in PAI process units [§63.1363(a)(7)] 

Step 2: Identify connectors subject to special monitoring requirements 

Identify each connector that meets one of the following conditions [§63.1363(f)]: 

•	 unsafe to monitor 

For more information, see “What if equipment is unsafe 

•	 difficult to monitor or difficult to monitor?” (page 6-28) 

•	 inaccessible 

•	 ceramic or ceramic-lined 

Step 3: Perform initial monitoring 

Monitor all connectors (except those designated in Step 2 ) [§63.174(b)(1) and (2)]: 

•	 by December 23, 2004 for existing sources 

•	 within 12 months after initial startup or by December 23, 2004, whichever is later, for 

new sources 

Step 4: Repair the leak 

Repair leaks as soon as possible, unless a delay of repair is allowed [§63.174(d)]. See 

“What are my leak repair requirements?” (page 6-26) for more information. 

6-17
 
Step 5: Calculate your percentage of leaky connectors 

Calculate the percentage of leaking connectors in a group of processes using the 

procedures specified in §63.174(i). See page 6-6 for a definition of “group of processes”. 

Step 6: Continuous monitoring for leaks 

After the first year of monitoring, determine your required monitoring frequency for each 

group of processes using the flowchart in figure 6-1. [§63.1363(b)(3)(iii)(C) through (G)] 

Step 7: Repair leaks 

Repair leaks as soon as possible as specified in step 4. 

Exceptions to the above LDAR requirements for connectors apply for the following connectors: 

•	 connectors that have been opened 

•	 screwed connectors 

•	 eliminated connectors 

Monitoring connectors that have been opened 

You have two options for monitoring of connectors that have been opened or have a broken 

seal [§63.174(c)(1)]: 

•	 Monitor the connector for leaks when it is reconnected or within the first 3 months after it 

is returned to organic HAP service. If a leak is detected, it must be repaired (unless it is 

determined to be nonrepairable). 

•	 Choose not to monitor the connector. If you choose not to monitor the connector, then you 

cannot count nonrepairables in your calculation of the percentage that are leaking. 

Note: You may switch between the two monitoring alternatives for connectors that have been opened or 

have a broken seal, provided the switch is at the end of the current monitoring period, and that it is reported 

in your periodic report. You must complete initial monitoring in the new alternative no later than 12 months 

after you report the switch. 

Monitoring for screwed connectors 

For screwed connectors with an inside diameter of 2 inches or less installed before November 

10, 1997, you may do all of the following as an alternative to the procedure described above for 

connectors that have been opened: [§63.174(c)(2)] 

•	 Comply with the requirements for connectors in heavy liquid service in §63.169 of the 

subpart H (i.e., if you detect evidence of a leak by sight, sound, odor, or other means, then 

either repair the connector or monitor to determine if repair is needed). 

6-18
 
Use this flowchart for each

group of processes

Monitor all connectors in the group of processes 

within one year after the compliance date.

Did > 0.5% of 

A your connectors leak Yes Monitor all connectors in the group of processes once during the next year. Return 

in the monitoring to A at the end of the year to determine the subsequent monitoring frequency. 

period? 

No B 

Did > 0.25% of 

your connectors leak Yes Your new required monitoring frequency is at least once in 4 years. You must 

in the monitoring monitor 40% of the connectors in the group of processes in the first 2 years. 

period? 

No 

Your new required monitoring Return to A Did > 1% of Did > 0.5% of frequency is at least once in 8 to determine your connectors leak your connectors leak years. You must monitor 50% No in the full 4-year No subsequent in the full 4-year 

period? period? monitoring 

of processes in the first 4 years. 

of the connectors in the group 

frequency 

Yes Yes 

Did > 1% of You must revert to annual your connectors leak Your new required monitoring 

in the first 4-year Yes monitoring for all connectors in the frequency is once every 2 years. At 

period? group of processes. Return to the end of the 2-year period, return A at the end of the year to xxx to 

No 

A to determine the subsequent determine the subsequent monitoring frequency. monitoring frequency. 

l

i Yes 

Did > 0.5% of 

your connectors eak 

n the first 4-year 

period? 

You must revert to monitoring every 

2 years for all connectors in the 

 at the end of the 2-year period 

monitoring frequency. 

A 

group of processes. Return to

to determine the subsequent 

No 

0.35% of 

l

i Yes 

No 

Did >

your connectors eak 

n the first 4-year 

period? 

You must revert to monitoring once 

every 4 years for 

all connectors in the group of 

B 

procedures.

processes. Go to for the 

Monitor the remaini

the 8-year period. Return to at the end of the 8-year period to A

ng 50% of connectors in the second 4 years of 

determine the subsequent monitoring frequency. 

Figure 6-1. Flowchart of monitoring frequencies for connectors. 

6-19 

Figure 6-1. Flowchart of monitoring frequencies for connectors. 

6-19 

No

Use this flowchart for each 

group of processes

Monitor all connectors in the group of processes 

within one year after the compliance date.

Did > 0.5% of 

your connectors leak

in the monitoring

period?

A Monitor all connectors in the group of processes once during the next year. Return 

to at the end of the year to determine the subsequent monitoring frequency. Yes A

Did > 0.25% of 

your connectors leak

in the monitoring

period?

No

Your new required monitoring frequency is at least once in 4 years. You must 

monitor 40% of the connectors in the group of processes in the first 2 years. Yes

B

Your new required monitoring 

frequency is at least once in 8 

years. You must monitor 50% 

of the connectors in the group 

of processes in the first 4 years.

No

Did > 1% of 

your connectors leak

in the first 4-year 

period?

Did > 1% of 

your connectors leak

in the full 4-year

period?

Did > 0.5% of 

your connectors leak

in the full 4-year

period?

Return to

to determine 

subsequent 

monitoring 

frequency

A

No No

Did > 0.5% of 

your connectors leak

in the first 4-year 

period?

Did > 0.35% of 

your connectors leak

in the first 4-year 

period?

No

You must revert to annual 

monitoring for all connectors in the 

group of processes. Return to

 at the end of the year to xxx 

determine the subsequent 

monitoring frequency.

Yes Your new required monitoring 

frequency is once every 2 years. At 

the end of the 2-year period, return 

to to determine the subsequent 

monitoring frequency.

A A

You must revert to monitoring every 

2 years for all connectors in the 

group of processes. Return to

 at the end of the 2-year period 

to determine the subsequent 

monitoring frequency.

A

Yes Yes

Yes

You must revert to monitoring once 

every 4 years for

all connectors in the group of 

processes. Go to for the 

procedures.

Yes

B

Monitor the remaining 50% of connectors in the second 4 years of 

the 8-year period. Return to at the end of the 8-year period to 

determine the subsequent monitoring frequency.

No A
•	 Monitor for leaks within the first 3 months after the screwed connector is returned to organic 

HAP service after having been opened or having the seal broken. Leaks must be repaired as 

described in “What are my leak repair requirements?” 

Monitoring for connectors you eliminate 

If you eliminate a connector subject to repeat monitoring, you may take credit for elimination 

of the connector if all of the following requirements are met [§63.174(j)]: 

•	 The connector was welded after November 10, 1997 

•	 The integrity of the weld is demonstrated by Method 21 monitoring, X-ray testing,
 
 

acoustic monitoring, hydrotesting, or other method
 
 

•	 Welds created after November 10, 1997 but before June 23, 1999 are monitored or tested 

by 3 months after the compliance date 

•	 Welds created after June 23, 1999 are monitored or tested within 3 months after being 

welded 

•	 If an inadequate weld is found or the connector is not welded completely around the
 

circumference, the connector is not exempt from the monitoring requirements
 

What are my compliance requirements for closed-vent systems and 

control devices (Option 2)? 

Requirements for closed vent systems and control devices under Option 2 include all of the 

following [§§63.1363(b)(3)(ii), 63.172, and 63.179]: 

•	 operating requirements of closed-vent systems and control devices 

•	 inspections of closed-vent systems 

•	 repair of leaks in closed-vent systems 

•	 monitoring of control devices 

•	 monitoring of bypass lines 

In addition, there are exemptions to these requirements for specific types of equipment. Each of 

these requirements and related exemptions are detailed below. 

6-20
 
 
Operating requirements 

Closed-vent systems and control devices must be operating whenever organic HAP emissions 

are being vented [§63.172(m)]. The table below summarizes the standards for control devices 

(these requirements are not applicable if you transport emissions from equipment to a process): 

If you operate a(n)... 	 Then meet... Or meet... Or meet... 

Recovery or recapture $95 percent 20 ppmva 
 


device reduction 
 


(e.g., condenser, 
 


absorber, etc.) 
 


Enclosed combustion $95 percent 20 ppmv (dry basis, 3 minimum residence time of 0.5 
 


device reduction percent O2) sec. at 1400°F (760°C) 
 


Flare 	 	 the requirements of 
 


§63.11(b) 
 


a The 20 ppmv standard is not applicable if you are using option 2 for an enclosed process unit. 

Inspections for closed-vent systems 

You must conduct both initial and annual inspections of closed-vent systems. [§63.172(f) and 

(g)] 

If your closed-vent system is made of hard-piping, you must perform an initial inspection using a 

leak detection instrument, and you must 

perform annual sensory inspections to check for §63.180(b) of subpart H specifies how you must indications of leaks based on sight, sound, or	 	 conduct inspections using a leak detection odor.	 	 instrument. You have a leak if the instrument 

reading is >500 ppm above background. 

If your closed-vent system is made of duct 

work, you must use a leak detection instrument 

in both your initial and annual inspections [§63.172(f) and (g)]. 

Note: You do not have to inspect parts of a closed-vent system that are unsafe to monitor or difficult to monitor. 

See “What if equipment is unsafe or difficult to monitor?” for more information. [§63.1363(b)(3)(ii)(A)] 

You also do not have to monitor your closed-vent system if you operate and maintain it at negative pressure. 

However, you must install at least one pressure measurement device that can be read from a readily accessible 

location to verify that negative pressure is maintained in the closed-vent system when the control device is 

operating. [§63.1363(b)(3)(ii)(B)] 

6-21
 
 
Repair leaks 

All leaks in your closed-vent system that you detect by sensory inspections or by using a leak 

detection instrument must be repaired as soon as possible, unless a delay of repair is allowed. 

See “What are my leak repair requirements?” (page 6-26) for more information. 

Monitoring control devices 

You must monitor your control device to ensure that it is operated and maintained as designed. 

You must select the parameter or parameters to monitor and keep a record that explains why 

each parameter was selected for monitoring. See “Records for closed-vent systems (Option 2)” 

in “What records must I keep for my equipment leaks?” (page 6-29) for more information. 

[§§63.172(e) and 63.1363(g)(7)(i)(D)] 

Note: This requirement does not apply if you transport emissions to a process instead of a control device. 

If your control device is subject to monitoring, recordkeeping, and reporting requirements in 40 CFR part 264, 

subpart BB, or in 40 CFR part 265, subpart BB, then you may choose whether to comply with the monitoring, 

recordkeeping, and reporting requirements of this rule or the requirements in 40 CFR parts 264 or 265. You 

must identify which option you choose in your periodic report [§63.172(n)]. 

Monitoring bypass lines 

If your closed-vent system has bypass lines that could divert a vent stream away from the control 

device and to the atmosphere, you must do one of the following [§63.172(j)]: 

•	 Use a flow indicator at the entrance of the bypass line. The flow indicator must take a 

reading at least once every 15 minutes and you must keep records of the readings. See 

“records for closed-vent systems (Option 2)” in “What records must I keep for my 

equipment leaks?” for more information 

•	 Secure the bypass line valve in the non-diverting position with a car-seal or a 

lock-and-key type configuration. You must visually inspect the seal or closure 

mechanism monthly to ensure the valve is maintained in the non-diverting position 

Note: You do not have to comply with the bypass monitoring requirements for low leg drains, high point bleeds, 

analyzer vents, open-ended valves or lines, and pressure relief valves that are needed for safety purposes. 

[§63.172(j)(3)] 

What are my compliance requirements for pressure testing 

(Option 3)? 

If you comply with the requirements for pressure testing, you are exempt from the option 1 

monitoring provisions for all of the following: [§§63.1363(b)(3)(iv) and 63.178(b)] 

•	 pumps in light liquid service 

•	 valves in gas/vapor service and in light liquid service 

6-22 
•	 pumps, valves, connectors, and agitators in heavy liquid service; instrumentation 
 


systems; and pressure relief devices in liquid service 
 


•	 agitators in gas/vapor service and in light liquid service 

•	 connectors in gas/vapor service and light liquid service 

You must comply with the Option 1 requirements for all of the following: 

• sampling connection systems
 
 

• open-ended valves or lines
 
 

•	 compressors 

•	 pressure relief devices in gas/vapor service 

You must also comply with the Option 2 requirements if closed-vent systems are used to 

capture and transport leaking or purged material to a process or control device from any of the 

following equipment: 

•	 pumps 

•	 agitators 

•	 compressors 

•	 pressure relief devices 

•	 sampling connection systems 

For exempt process equipment, you must pressure test the equipment train for leaks each time
 
 

the equipment is reconfigured for
 
 

production of a different product. Pressure If you pressure test, process equipment must be tested testing is not required for routine seal using either of the procedures specified in:
 
 

breaks, such as changing hoses or filters,
 
 P §63.180(f) for pressure or vacuum loss
 
 that are unrelated to reconfiguration. You 

must pressure test at least once per year. P §63.180(g) for a test using a liquid
 
 

[§63.178(b)(1)]
 
 

6-23 
For pressure tests using a liquid... 

The pressure changes at a rate greater than there are indications of liquids dripping 

6.9 kilopascals (1 psig) in 1 hour or 

or if there is other evidence of fluid loss. 

if there is visible, audible, or olfactory 

evidence of fluid loss 

batch processes (Option 4)? 

•	 

<	 [§63.178(c)(1)] 

 ̃ valves in gas/vapor or light liquid service 

 ̃ agitators in gas/vapor or light liquid service 

(3)(iv)(B) 

(3)( 

<	 

•	 

[§63.178(c)(3)(i)] 

equipment. 

•	 

any of the following [§63.178(c)(2)]: 

•	 organic HAP 

•	 an acceptable surrogate volatile organic 

	 monitor for equipment leaks using a leak 

detection instrument. 

•	 any other detectable gas or vapor 

6-24 

You have a leak if: [§63.178(b)(3)] 

For pressure or vacuum tests... 

If you detect a leak, you must repair it and retest the equipment before start-up of the process. 

See “What are my leak repair requirements?” (page 6-26) for more information. 

What are my compliance requirements for alternative monitoring of 

If you elect to comply with the alternative monitoring for batch equipment, you must do all of 

the following: 

comply with all of the compliance requirements for option 1 except: 

 less frequent monitoring may be possible for both of the following: 

Note: Pumps must be monitored quarterly or monthly as specified in option 1, and connectors must be 

monitored annually or on a less frequent schedule as specified in option 1. [§§63.1363(b) 

and 63.178(c) ii)] 

different reasons for delay of repair are allowed. See “What are my leak repair 

requirements?” (page 6-26) for more information 

monitor for equipment leaks within 30 days after process startup when you have 

reconfigured the equipment for the production of a new product. 

Note: These monitoring results after a process startup can not be used in determining percent leaking 

perform monitoring that requires use of a leak detection instrument when the batch 

equipment is in use with 

§63.180(b) of subpart H specifies how to 

compound which is not an organic HAP 
You may monitor batch valves and agitators at the following reduced frequencies 

[§63.178(c)(3)(iii)]: 

monthly quarterly 

0 to <25 percent of the year quarterly annually annually 

25 to <50 percent of the year quarterly annually 

50 to <75 percent of the year 

75 to 100 percent of the year quarterly 

If the equipment is operated ... And the monitoring frequency required for a continuous process is... 

semiannually 

Then you must monitor your batch process... 

semiannually 

bimonthly three times semiannually 

monthly semiannually 

The monitoring frequencies specified in the table above can be adjusted to accommodate your 

process operations. You may monitor anytime during the monitoring period (e.g., month, 

quarter, year), provided the monitoring is conducted within a reasonable time after monitoring 

was last completed. For example, if the equipment is not operating during the scheduled 

monitoring period, the monitoring can be done during the next period when the process is 

operating. [§63.178(c)(3)(iv)] 

What is required for an alternative standard (Option 5)? 

You (and manufacturers of equipment used to control equipment leaks) may apply for 

permission to use alternative means of emission limitation (e.g., alternative standard) to comply 

with the equipment leak standards in subpart MMM. An “Alternative emission limit” is a way 

of reducing emissions other than the equipment, design, or operational requirements or work 

practice standards in Subpart MMM’s equipment leak provisions. Some general conditions must 

be met when you apply for alternative means of emission limitation, including all of the 

following: [§63.177(b), (c), and (e)]: 

•	 you are responsible for collecting and verifying emission performance test data for an 

alternative limit 

Note: You may offer a unique approach to demonstrate the effectiveness of your alternative [§63.177(d)] 

•	 the Administrator will compare test data or the demonstrated emission reduction for the 

alternative means of emission limitation to test data or emission reduction for the 

required PAI equipment leak standards 

•	 if the PAI standard is a work practice, you must commit in writing to work practices that 

provide the same or better emission reductions than required by Subpart MMM and you 

must demonstrate the that you are meeting the emission reduction standard for at least a 

1-year period. 

6-25
 
 
•	 the Administrator may condition the permission on requirements that may be necessary 

to ensure operation and maintenance to achieve the same or greater emission reduction as 

the Subpart MMM equipment leak standards 

What are my leak repair requirements? 

Your leak repair and delay of repair requirements under Options 1, 2, 3, and 4 are detailed 

below: 

Option 1 

Rule references for Option 1 leak repair provisions are: 

(3) for pumps in light liquid service and agitators in gas/vapor or light

 liquid service 

(7) for valves in gas/vapor or light liquid service 

(1) for pressure relief devices in gas/vapor service 

) for pumps, valves, connectors, and agitators in heavy liquid service; 

)( ) for connectors in gas/vapor of light liquid service 

Activities listed in 

According to... 

pumps/agitators in light liquid •	 tightening of packing gland nuts 	 §§63.1363(c)(3) 

service or heavy liquid service •	 and 63.169(d)
 


 

valves in gas/vapor service, light • tightening of bonnet bolts §§63.1363(e)(8) 
 

liquid service, or heavy liquid • and 63.169(d) 
 

service 
 

•	 tightening of packing gland nuts 

•	 

§63.1363(c) 

§63.1363(e) 

§63.164(g) for compressors 

§63.165(b) 

§63.169(c) and (d

 instrumentation systems; and pressure relief devices in liquid service 

§63.174(d) and (h 2) and (3 

You must repair leaking equipment as soon as possible after leaks are detected. A first attempt 

to repair the leak must be made within 5 days after the leak is detected. 

Subpart MMM as first attempts to repair leaks from pumps and valves are summarized as 

follows: 

For the following equipment... First attempts to repair leaks include... 

ensuring the seal flush is operating at design 

pressure and temperature 

replacement of bonnet bolts 

injection of lubricant into lubricated packing 

Leaks must be fully repaired within 15 days after detection. However, you may delay repair of 

leaking equipment under any of the following circumstances [§63.171]. 

6-26
 
•	 If the repair is technically infeasible without a process unit shutdown. You may delay 

repair until the end of the next process unit shutdown [§63.171(a)]. 

•	 If equipment is isolated from the process and does not remain in organic HAP service 

[§63.171(b)] 

•	 If emissions of material purged from valves, connectors, or agitators during immediate 

repair would be greater than the fugitive emissions likely to result from delay of repair. 

When the repair is performed the purged material must be collected and destroyed or 

recovered in a control device [§63.171(c)]. 

•	 If pump repair requires replacing the existing seal with a new system that will better meet 

the requirements of Option 1 or that meets Option 2. The repair must be completed as 

soon as possible but not more than 6 months from the time when the leak was detected 

[§63.171(d)]. 

•	 If valve assembly replacement is necessary during a process unit shutdown, but valve 

assembly supplies are not on hand. You may not delay repairs beyond the next process 

unit shutdown, unless a third shutdown will occur within 6 months from the first process 

unit shutdown [§63.171(e)]. 

Option 2 

Leaks in your closed-vent system must be repaired as soon as possible after leaks are detected. 

A first attempt to repair the leak must be made within 5 days after the leak is detected. Leaks 

must be fully repaired within 15 days after detection. However, you may delay repair of leaks in 

closed-vent systems only if either of the following applies: [§63.172(h) and (i)] 

•	 the repair is technically infeasible without a process unit shutdown 

•	 if you determine that emissions resulting from immediate repair would be greater than the 

fugitive emissions likely to result from delaying the repair 

A delayed repair must be completed by the end of the next process unit shutdown. [§63.172(i)] 

Option 3 

If you detect a leak during pressure testing, you must repair the leak and retest the equipment 

before start-up of the process. If the equipment fails the retest or the second of two consecutive 

pressure tests, it must be repaired as soon as possible, but no later than 30 days after the second 

pressure test. [§63.178(b)(4)] 

Delaying repair of leaking equipment is allowed under option 3 if the replacement equipment 

is not available and both of the following conditions are met: [§63.178(d)] 

•	 equipment supplies (which were sufficiently stocked) have been depleted 
 


6-27 
 

• the repair is made no later than 10 days after delivery of the replacement equipment 

Option 4 

If you detect a leak when monitoring a batch process under option 4, you must repair the leak as 

soon as possible. Generally, repairs must be made no later than 15 days after you detected the 

leak. However, delaying repair of leaking equipment is allowed under the same conditions as for 

option 3. [§63.178(c)(4) and (d)] 

What if equipment is unsafe or difficult to monitor? (Options 1, 2, 

and 4) 

If you designate the following equipment as unsafe to monitor, difficult to monitor, or 

inaccessible, the equipment is exempt from the general equipment leak requirements listed in 

Table 6-1 in “What compliance options do I have for my equipment leaks?” (page 6-4): 

[§63.1363(f)] 

•	 pumps in light liquid service and agitators in gas/vapor service and in light liquid 

service 

•	 valves in gas/vapor service and in light liquid service 

•	 closed-vent systems 

•	 connectors in gas/vapor service and in light liquid service 

Equipment that is unsafe to monitor 

You may designate valves, connectors, agitators, and any part of a closed-vent system as unsafe 

to monitor if you determine that monitoring personnel would be exposed to an immediate danger 

if you comply with the equipment leak monitoring requirements. If you designate equipment as 

unsafe to monitor, then you must have a written plan that requires monitoring of the equipment 

as frequently as possible during safe-to-monitor times. You do not have to monitor more 

frequently than the periodic monitoring schedule that would apply of the equipment were not 

unsafe to monitor. [§63.1363(f)(2)] 

Equipment that is difficult to monitor 

You may designate valves, agitators, pumps, or any part of a closed-vent system as difficult to 

monitor if you determine that either of the following are true: [§63.1363(f)(3)(i)] 

•	 the equipment can not be monitored without elevating the monitoring personnel more 

than 2 meters above a support surface 

•	 the equipment is not accessible at anytime in a safe manner 

6-28 
If you designate equipment as difficult to monitor, then you must follow a written plan that 

requires monitoring of the equipment at least once per calendar year. At a new source, you may 

designate no more than 3 percent of each type of equipment as difficult to monitor. No limits 

apply to the percentage of equipment that can be designated as difficult to monitor at an existing 

source, as long as it meets the applicable criteria. [§63.1363(f)(3)(ii) and (iii)] 

Inaccessible connectors and ceramic or ceramic-lined connectors 

You may designate a connector as inaccessible if it is any of the following: [§63.1363(f)(4)(i)] 

•	 buried 

•	 insulated in a manner that prevents access to the equipment by a monitor probe 

•	 obstructed by equipment or piping that prevents access to the equipment by a monitor 

probe 

•	 unable to be reached from a wheeled scissor-lift or hydraulic-type scaffold which would 

allow access to equipment up to 7.6 meters above the ground 

•	 not able to be accessed at any time in a safe manner to perform monitoring. Examples of 

unsafe access are: 

< access requiring a wheeled scissor-lift on unstable or uneven terrain 

< access requiring a motorized man-lift basket in areas where an ignition potential 

exists 

< access near hazards such as electrical lines
 
 

< access that would risk damage to equipment
 
 

Ceramic or ceramic-lined connectors may be treated as inaccessible connectors [§63.1363(f)(1)]. 

At an existing source, you may designate any connector as inaccessible if it meets the applicable 

criteria. At a new source, you may designate no more than 3 percent of connectors as 

inaccessible. [§63.1363(f)(4)(ii)] 

Inaccessible connectors observed by sight, sound, odor, or other means to be leaking must be 

repaired as soon as possible. See “What are my leak repair requirements?” (page 6-26) for more 

information. [§63.1363(f)(4)(iii)] 

What records must I keep for my equipment leaks? 

You must keep the following types of records depending on the type of equipment you use and 

the compliance option you choose: [§63.1363(g)] 

•	 general records (identification of equipment, records of exemptions, etc.) 

•	 records of visual inspections 

6-29 
•	 monitoring records 

•	 records of pressure tests 

•	 records of compressor and pressure relief valve compliance tests 

•	 records for closed-vent systems 

•	 records for components in heavy liquid service 

•	 records of exempt components 

•	 records pertaining to the division of valves in gas/vapor service and light liquid service 

into process subgroups 

Specific records in all of these categories are identified in Table 6-2 (page 6-31). 

You only need one recordkeeping system, even you have more than one group of processes 

subject to the equipment leak requirements. Keep records at the plant site in hard copy or 

electronic form. All records must be kept for at least 5 years. At a minimum, the most recent 2 

years of records must be retained onsite. The remaining 3 years of records may be retained 

offsite. You may keep the records on microfilm, a computer, computer disks, magnetic tape 

disks, or on microfiche. [§§63.1363(g)(1), 63.1367(a)(1), and 63.10(b)(1) of subpart A]. 

6-30
 
 
TABLE 6-2. Recordkeeping Requirements of the Equipment Leak Provisions 

Categories of records Then for the following 

under each option are... equipment... You must keep records of... 

General equipment equipment in organic HAP • identification of equipment 

identification records service less than 300 hr/yr • information, data, and analysis used to make the determination (All options)

6-31
 
 

• 

than individually)

•

• 

service • 

identification records (Options 1 and 4) 

)

pressure relief devices in • 

gas/vapor service 

•

rupture disks 

valves, connectors, and agitators • 

that you designate as unsafe to in each of these categories 

• 

all equipment in organic HAP list of equipment identification numbers (note that the total service for 300 hr/yr or more number of connectors in an area may be listed as a group rather (except instrumentation systems) 

updates to the list after equipment changes (make updates within 

15 days after then end of monitoring periods for equipment that is monitored periodically) 

equipment in heavy liquid list of identification numbers as specified above 

information, data, and analysis used to determine that the 

equipment is in heavy liquid service 

Equipment-specific instrumentation systems list of identification numbers for each instrumentation system (note 

that you do not need to identify each component in an instrumentation system

compressors list of identification numbers for compressors that you designate as 

operating with a leak detection instrument reading of less than 500 ppm above background 

list of identification numbers for pressure relief devices that will 

be operated with a leak detection instrument reading of less than 500 ppm above background 

list of identification numbers for pressure relief devices that have 

list of identification numbers for the equipment that you designate 

monitor; and valves, agitators, a copy of your written plan that specifies the frequency for 

and pumps that you designate as monitoring this equipment difficult to monitor 
TABLE 6-2. (cont’d) 

Categories of records Then for the following 

under each option are... equipment... You must keep records of... 

valves that you assign to • identification of which valves are assigned initially to each subgroups subgroup 

• identification of valves that are reassigned and when they were 

reassigned 

6-32
 
 

Design criteria records • 

(Options 1 and 4) and/or barrier fluid system 

• ••

Monitoring records connectors and valves in 

(Options 1 and 4) gas/vapor and light liquid 

service 

• • 

receive credit in the percent connectors leaking calculation 

• 

detected using a leak detection • 

• •••

be non-repairable 

• 

is delayed beyond 15 days after • 

the date the leak was detected unrepaired

dual mechanical seal systems for identify design criteria that indicate failure of the seal system 

pumps, agitators, and 

compressors an explanation of the design criteria 

any changes to the design criteria the reasons for any changes to the design criteria 

your schedules for monitoring these types of equipment with a leak detection instrument 

connectors that you remove list of the connectors removed from or added to the process from a process so that you can documentation of the integrity of the weld for all removed 

all equipment when leaks are the instrument and the equipment identification number 

the operator name, initials, or identification number 

instrument date the leak was detected 

date of the first attempt to repair the leak 

date of successful leak repair maximum instrument reading measured by the leak detection 

instrument after the leak is successfully repaired or determined to 

all equipment when leak repair reason for the delay 

dates of process shutdowns during the time the equipment is 
TABLE 6-2. (cont’d) 

Categories of records Then for the following 

under each option are... equipment... You must keep records of... 

opened connectors for which • identification of the connectors that were disturbed since the last 

you comply with the monitoring monitoring period 

specified in §63.174(c)(1)(i) • date of follow-up monitoring 

• monitoring results (i.e., leak detection instrument reading) 

6-33
 
 

• 

as operating with leak detection • 

• 

pressure relief devices in gas/vapor service that are returned to operating with pressure releases 

Visual inspection occurrence and date of inspection 

records agitators in gas/vapor and light(Options 1 and 4) liquid service

compressors that you designate dates of tests to verify compliance 

measured background level during tests 

instrument readings less than maximum leak detection instrument reading during tests 500 ppm above background, and instrument readings less than 500 ppm above background after pumps in light liquid service and 
TABLE 6-2. (cont’d) 

6-34
 
 

Categories of records Then for the following 

under each option are... equipment... You must keep records of... 

control device recordsa 

Closed vent system and 

control devices 

all closed vent systems and • schematics, design specifications of the control device, and piping 

and instrumentation diagrams 

(Option 2) • dates and descriptions of any changes in the design specifications 

• for a flare: the design (i.e., steam assisted, air assisted, or 

nonassisted), and the results of the compliance demonstration 

required by §63.11(b) 

• a description of the parameter or parameters monitored to ensure 

that control devices are operated and maintained as designed, and an explanation of why each parameter was selected for the monitoring 

• dates and durations when monitoring results show control device 

is not operating as designed 

• dates and durations when the control device monitor is not 

working 

• dates and durations of startups and shutdowns of control devices • inspections for closed vent systems that do not operate under 

negative pressure: 

< if no leaks were detected, record the date of the inspection 

and state that no leaks were detected 

< if leaks were detected, by either sensory observations or 

using a leak detection instrument, record the same information described above for leaks detected using a leak detection instrument under option 1 

• results of bypass line monitoring when using a flow indicator: 

< hourly flow indicator records < times and durations of periods when the flow indicator was 

not operating 

< times and durations of periods when flow was diverted from 

the control device 
TABLE 6-2. (cont’d) 

Categories of records Then for the following 

under each option are... equipment... You must keep records of... 

each enclosed process • identification of the process 

• identification of the HAP handled by the enclosed process • schematic of the process, enclosure, and the closed vent system • description of the system used to create a negative pressure in the 

enclosure 

6-35
 
 

• 

and pressure relief devices equipped with closed vent parts of a closed vent system • 

that you designate as unsafe to • 

Pressure test records • (Option 3) that is pressure tested the calendar year 

• • 

pressure test 

• 

• 

that does not pass two • consecutive pressure tests (i.e., it • is not successfully repaired after • a leak is detected in the first test) • 

• • 

pumps, agitators, compressors, identification numbers for all such equipment systems 

a list of the designated parts of the closed vent system 

a written plan for monitoring these parts of the closed vent system 

monitor or difficult to monitor 

each process equipment train identification of each product, or product code, produced during 

dates of each pressure test 

the test pressure, and the pressure drop observed during each any evidence of fluid loss detected by sight, sound, or odor 

each process equipment train date of each pressure test 

date of each leak repair attempt 

repair methods applied in each attempt to repair the leak 

the reason for the delay of repair 

the expected date for delivery of the replacement equipment the actual date of delivery of the replacement equipment 

the date of successful repair 
TABLE 6-2. (cont’d) 

Categories of records Then for the following 

under each option are... 

• 

frequency records for with option 4 

batch processes • (Option 4) specified in §63.178(c)(3)(i) 

• • 

a 

equipment... You must keep records of... 

Adjusted monitoring each batch process complying identification of equipment added to the process since the last 

monitoring period 

date of monitoring for equipment added in reconfiguration as 

instrument reading if a leak is detected during monitoring of 

added equipment, or statement indicating that monitoring was performed if no leak is detected 

the portion of time during the year that the equipment for which 

the monitoring frequency is adjusted is in use in the PAI process (e.g.,records of the time in use for individual pieces of equipment or average time in use for the process unit) 

 If you convey emissions to a process instead of to a control device, you are subject only to the requirements for closed vent systems. 

6-36
 
 
What reports must I submit? 

Chapter 8 describes the notifications and reports that you may need to submit, and the dates 

when they must be submitted. The information that you will need to submit about equipment 

leaks is described below. Most of the information that you will need to submit must be included 

in the following reports: 

• notification of compliance status report 

• periodic reports 

If you decide to subgroup valves, you must also notify the Administrator at least 30 days before 

the beginning of the next monitoring period. In the notification, you must identify the processes 

that will be subgrouped and the valves that will be assigned to each subgroup. 

[§63.1363(e)(5)(v)] 

Notification of compliance status report 

You must include the following information specific to equipment leaks in your notification of 

compliance status report: 

According to this section of 

For each... You must include the following information... the rule... 

group of processes •	 	 	 §63.1363(h)(2)(i) 

(all options) •	 	 
 


 


 

•	 

process in • §63.1363(h)(2)(ii)
 
 


 
 

option 3 • 
 
 

enclosed process • §63.1363(h)(2)(iii)
 
 

• 
 
 

option 2 pressure in the enclosure
 
 

•	 

identification of the group of processes 

approximate number of each type of equipment (e.g., 

pumps, valves, etc.) in organic HAP service, excluding 

those in vacuum service 

specific method of compliance 

identification of products or product codes for PAI’s 

compliance with made in the pressure-tested equipment

planned schedule for pressure testing when the

equipment is configured for production of PAI’s 

identification of each enclosed process 

complying with a description of the system used to create a negative

a description of the control device used to control 

emissions 

Periodic report 

You must include the following information about equipment leaks in your periodic reports: 

6-37 
According to the 

If you comply Include the following information in your periodic following sections of 

with... Then for... reports... the rule... 

Option 1 or 4	 valves in • §63.1363(e)(5)(vi), 

gas/vapor or • (h)(3)(ii)(A), 

light liquid • (h)(3)(ii)(B), and 

service • (h)(3)(ii)(K) 

•	 

•	 

•	 

calculation for groups of processes that have 

subgroups 

•	 

• §63.1363(h)(3)(ii)(C), 

liquid service • (D), and (K) 

•	 

•	 

•	 

was started, if applicable 

agitators in • §63.1363(h)(3)(ii)(C)
 

gas/vapor or • and (D)
 

light liquid • 
 

service
 

	 • §63.1363(h)(3)(ii)(E),
 

•	 (F), and (J) 

•	 

connectors in • §63.1363(h)(3)(ii)(G),
 

gas/vapor or • (H), and (L)
 

light liquid • 
 

service • 
 

•	 

•	 

applicable 

pressure relief §63.1363(h)(3)(ii)(J) 

device in 

gas/vapor 

service 

all types of • §63.1363(h)(3)(ii)(I) 

• 

technically infeasible 

Option 2	 results of all annual inspections §63.1363(h)(3)(ii)(J) 

total number that leaked 

total number monitored 

percent that leaked 

total number not repaired 

number that are nonrepairable 

all valve reassignments among subgroups 

results of semiannual percent-leakers 

a statement indicating the start of monthly 

monitoring, if applicable 

pumps in light total number that leaked 

total number monitored 

percent that leaked 

total number not repaired 

a statement that a monthly monitoring program 

total number that leaked 

total number monitored 

total number not repaired 

compressors total number that leaked 

total number not repaired 

results of all monitoring to demonstrate that 

compressors operate with instrument readings 

<500 ppm above background 

total number that leaked 

total number monitored 

percent that leaked 

number that were not repaired 

number that are nonrepairable 

statement identifying a change in method of 

connector monitoring for opened connectors, if 

results of all monitoring after a pressure release 

reasons for any delay of repair 

equipment explanation of why a process shutdown was 

closed vent 

systems 

6-38
 
 
According to the 

If you comply Include the following information in your periodic following sections of 

with... Then for... reports... the rule... 

Option 3 	 • §63.1363(h)(3)(iii)(A), 

•	 (B), and (C) 

•	 

or two consecutive tests failed 

all types of reasons for any delay of repairs §63.1363(h)(3)(iii)(D) 

closed-vent results of all annual inspections §63.1363(h)(3)(iii)(E) 

All options 	 §63.1363(h)(3)(iv) 

the process identification of process equipment train 

number of pressure tests conducted 

number of pressure tests where either the retest 

equipment 

systems 

all equipment any change to information that you submitted in 

your notification of compliance status report 

6-39
 
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklists for Equipment Leak Inspections 

Facility Name: 
 

Facility Location: 
 

Facility TRI ID #: 
 

Inspector: 
 

Date: 
 

Note: This table explains which inspection checklists you should use for determining 

compliance with the equipment leak requirements. 

Then use these 

Option checklists: Starting on pages ... 

1 

gas/vapor service and in light liquid service 

1 and 2 6-41 and 6-43 

Open-ended valves or lines 1 and 3 6-41 and 6-48 

Valves in gas/vapor service and light liquid 

service 

1 and 4 6-41 and 6-49 

1 and 5 6-41 and 6-53 

Pressure relief devices in gas/vapor service 

1 and 7 6-41 and 6-59 

pressure relief devices in liquid service 

1 and 8 6-41 and 6-60 

Connectors in gas/vapor service and in light liquid 

service 

1 and 9 6-41 and 6-63 

2 1 and 10 6-41 and 6-68 

3 1 and 11 6-41 and 6-73 

4 1 and 12 (and all of 2 

through 9 that are 

applicable) 

6-41 and 6-75 

For the following equipment... 

Pumps in light liquid service and agitators in 

Compressors 

1 and 6 6-41 and 6-57 

Sampling connection systems 

Pumps, valves, connectors, and agitators in heavy 

liquid service; instrumentation systems; and 

Closed-vent systems and control devices 

Equipment in process that is pressure tested 

Equipment in process that complies with 

alternative monitoring for batch processes 

6-40
 

Checklist 1: Applicability and Identification of Equipment 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to question A.1 in this checklist means the equipment is not subject to the equipment 

leak requirements in subpart MMM; all other equipment in PAI processes is subject to subpart MMM. A “yes” 

response to a question in section B of this checklist means compliance with that requirement, and a “no” response 

means noncompliance with the requirement. 

A. Applicability Comments 

1.	 	 Do you have equipment that is used as follows: 

§63.1363(a)(1), (5), (6), and (8) 

•	 in vacuum service? 	 G Yes G No 

•	 in bench-scale processes? 	 G Yes G No 

•	 that do not contain process fluids (e.g., utilities and heating G Yes G No 

and cooling systems that do not combine their materials 

with process materials)? 

•	 not in organic HAP service? 	 G Yes G No 

B. Review Records and Inspection Comments 

1.	 	 Do your records identify each piece of equipment covered by 

the equipment leak provisions (i.e., that are in organic HAP 

service as part of a PAI process) using any combination of the 

following methods: §63.1363(a)(7) 

•	 physically tagging the equipment 	 G Yes G No 

•	 marking the equipment on a plant site plan 	 G Yes G No 

•	 marking the equipment in log entries 	 G Yes G No 

•	 designating process boundaries with waterproof 
 G Yes G No 

identification
 

•	 another appropriate method for identifying equipment G Yes G No 

Note: connectors do not need to be individually identified if all 
 

of the connectors in an area are identified as a group and the 
 

number of connectors is identified. 
 

You do not need to identify individual components in
 
 

instrumentation systems.
 
 

Other checklists list specific components that must be 
 

separately identified because they meet a specific design or 
 

operating characteristic. 
 

6-41
 
 
Checklist 1: (cont’d)
 
 

Applicability and Identification of Equipment
 
 

B. Review Records and Inspection Comments 

2.	 	 Do you have records identifying all equipment in organic HAP G Yes G No 

service for <300 hr/yr? §63.1363(g)(9) 

Note: this equipment is not subject to any other requirements
 

under subpart MMM.
 

6-42
 
________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 2: Requirements for pumps in light liquid service and agitators in gas/vapor and in 

light liquid service (Option 1) 

Facility Name: 
 

Facility Location: 
 

Facility TRI ID #: 
 

Inspector: 
 

Date: 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring, Inspection, and Design Requirements Comments 

1.	 	 Did you monitor for leaks from each pump and agitator using 

the method in §63.180(b)? §63.1363(c)(2)(i) 

Note: pumps and agitators without an externally actuated
 

shaft penetrating the pump or agitator housing are exempt
 

from the monitoring requirement.
 

G Yes G No 

2.	 	 G Yes G No 

agitator seal? (2)(iii) 


 

but the pumps and agitators must be inspected at least monthly.
 

Pumps and agitators without an externally actuated shaft
 

penetrating the pump or agitator housing are exempt from the
 

inspection requirement.
 

3.	 	 Did you calculate the percent of leaking pumps using the 

procedure outlined in §63.1363(c)(4): 

•	 G Yes G No 

•	 G Yes G No 

processes)? 

•	 G Yes G No 


 

quarter after startup do not have to be included in the percent
 

leaking calculation for that monitoring period.
 

You do not have to calculate percent leakers for pumps in a
 


 

externally actuated shaft penetrating the pump housing and/or
 

dual mechanical seals with a barrier fluid system.
 

Have you performed weekly visual inspections of each pump 

and agitator (including those equipped with dual mechanical 

seals) for indications of liquids dripping from the pump or 

§63.1363(c)

Note: weekly inspections are not required for unmanned sites,

determine all groups of processes before the end of the first 

monitoring period? 

calculate 1-year rolling average of percent leakers (or only 

the number leaking if there are <30 pumps in a group of 

determine the total number of pumps in a group of 

processes as the sum of all pumps in organic HAP service? 

Note: leaking pumps in a continuous process in the first

group of processes if >90% of the pumps in the group have no

6-43
 
Checklist 2: (cont’d)
 
 

Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service
 
 

A. Monitoring, Inspection, and Design Requirements Comments 

4.	 	 Did you monitor each pump monthly if (based on a 1-year G Yes G No 
 

rolling average) the greater of either: §63.1363(c)(4)(ii) 
 

•	 10 percent of the pumps in a group of processes leak, or 

•	 three pumps in a group of processes leak 

Note: you may return to quarterly monitoring after a 1-year
 

rolling average no longer meets either of these conditions.
 

5.	 G Yes G No 
 


 

specified in your written plan? 
 

6.	 
 

seal have all of the following: (5) 
 

•	 G Yes G No 

<	 a barrier fluid pressure that is always greater than the
 


 

<	 a barrier fluid degassing reservoir connected by a
 


 

•	 
 

process stream
 

•	 G Yes G No 

•	 G Yes G No 
 


 

7.	 G Yes G No 
 


 

(5)(v) 

8.	 G Yes G No 
 

seal during a weekly visual inspection, did you do either of the 
 

following: (2)( )(5)( 
 

•	 

•	 

9.	 
 


 

following: (10) 
 

•	 G Yes G No 
 


 

•	 G Yes G No 
 

the leak was repaired? 
 

For pumps and agitators that you have designated as unsafe to 

monitor or difficult to monitor, do you monitor at the frequency 

§63.1363(f) 

Does each pump and agitator equipped with a dual mechanical 

§63.1363(c) 

a barrier fluid system that meets one of the following: 

pump/agitator stuffing box pressure, or 

closed-vent system to a control device, or 

a closed-loop system that purges the barrier fluid into a 

a barrier fluid that is not in organic HAP service? 

a sensor that will detect failure of the seal system, the 

barrier fluid system, or both? 

For each pump and agitator with dual mechanical seals, do you 

check the sensor daily, or does it have an alarm? 

§63.1363(c) 

When you observe liquids dripping from a pump or agitator 

§63.1363(c) iii) and (c iv) 

stop the liquids from dripping, or 

monitor for leaks using a leak detection instrument? 

When you detected a leak based on the results of monitoring 

with a leak detection instrument, did you do both of the 

§63.1363(a) 

attach a visible, weatherproof identification to the leaking 

pump or agitator? 

leave the identification on the pump or agitator until after 

6-44
 
Checklist 2: (cont’d)
 

Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service
 

B. Leak Repair Requirements Comments

1.	 When you detected a leak, did you do both of the following: 

§63.1363(c)(3) 

•	 make your first attempt to repair the leak within 5 days G Yes G No 

after detecting it? 

•	 either fully repair the leak within 15 days after detecting it, G Yes G No 

or delay repair for any of the reasons in question 2? 

Note: first attempts to repair leaking pumps include tightening
 

of packing gland nuts and ensuring the seal flush is operating
 

at design pressure and temperature.
 

2.	 If you delayed repair, was it for one of the following reasons: G Yes G No 

§§63.1363(b)(3)(i), (c)(3)(i), and 63.171 

•	 the repair was technically infeasible without a process unit
 

shutdown, or
 

•	 you determined that repair personnel would be exposed to
 

an immediate danger if attempting to repair without a
 

process unit shutdown, or
 

•	 the equipment was isolated from the process and did not
 

remain in organic HAP service, or
 

•	 emissions purged from the equipment during immediate
 

repair would be greater than emissions resulting from
 

delaying the repair and using a control device to reduce the
 

emissions, or
 

•	 pump repair requires replacement of the existing seal with a
 

new system that will better meet the PAI rule requirements?
 

§63.1363(c)(3) 

3.	 If you determined that a repair was technically infeasible or G Yes G No 

would expose repair personnel to an immediate danger without 

a process unit shutdown, did you complete the repair by the 

end of the next process unit shutdown? §63.1363(b)(3)(i)(A) 

and (B) as cross referenced by §63.1363(c)(3)(i) 

4.	 If you determined that emissions purged from an agitator G Yes G No 

during immediate leak repair would be greater than emissions 

resulting from delaying the repair, did you use a control device 

to reduce emissions generated during agitator leak repair (or 

otherwise collect and destroy purged material)? §63.171(c) as 

cross referenced by §63.1363(c)(3)(i) 

5.	 If you determined that pump repair required replacement of the G Yes G No 

existing seal with a new system to better meet the PAI rule 

requirements, did you repair the leak less than 6 months from 

the time when the leak was detected? §63.171(d) as cross 

referenced by §63.1363(c)(3) 

6-45
 
Checklist 2: (cont’d)
 
 

Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service
 
 

C. Recordkeeping and Reporting Requirements Comments

1. 	 Do your records include any updates to identification numbers G Yes G No 

prepared as specified in checklist 1 for pumps and agitators 

subject to the LDAR requirements (option 1)? 

§63.1363(g)(2)(i)(A) 

Note: updates must occur within 15 days after the conclusion 
 

of the monitoring period during which the changes occurred. 
 

2. 

(2)(v) 

• G Yes G No 

• your explanation of the design criteria G Yes G No 

• 

changes 

G Yes G No 

3. 

(2)(vi) 

G Yes G No 

4. Do your records include the occurrence and date of each 

(3) 

G Yes G No 

5. For each leak that you detected, have you recorded: 

(4) 

• G Yes G No 

• G Yes G No 

• G Yes G No 

• G Yes G No 

• 

40 CFR part 60, appendix A, after leak is successfully 

G Yes G No 

• 

after leak detection: 

< reason for the delay? G Yes G No 

< dates of process shutdowns that occur while the G Yes G No 

Do your records include the following information for each 

sensor that is used to detect failure of the seal system and/or 

barrier fluid system for pumps and agitators that have a dual 

mechanical seal system: §63.1363(g) 

design criteria that indicate failure of the seal system, the 

barrier fluid system, or both 

any changes to the design criteria and the reasons for the 

Do your records include a list of pumps and agitators 

designated as unsafe to monitor or difficult to monitor, and do 

you have a written plan for monitoring or inspecting this 

equipment? §63.1363(g) 

weekly visual inspection for leaks in pumps and agitators? 

§63.1363(g) 

§63.1363(g) 

the instrument and the equipment identification number and 

the operator name, initials, or identification number? 

date the leak was detected? 

date of the first attempt to repair the leak? 

date of successful leak repair? 

maximum instrument reading measured by Method 21 of 

repaired or determined to be non-repairable? 

all of the following if repairs were delayed beyond 15 days 

equipment is unrepaired? 

6-46
 
 
Checklist 2: (cont’d)
 
 

Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service
 
 

C. Recordkeeping and Reporting Requirements Comments

6.	 	 Did you include the following in your periodic report for each 

monitoring period during the 6-month reporting period? 

§63.1363(h)(3)(ii)(C), (D), (I), and (K) 

•	 the number of pumps and agitators for which leaks were G Yes G No 

detected? 

•	 the total number of pumps and agitators monitored? G Yes G No 

•	 the percent leaking pumps? 	 	 G Yes G No 

•	 the number of pumps and agitators for which leaks were not G Yes G No 

repaired? 

•	 the facts that explain any delay of repairs and, where G Yes G No 

appropriate, why a process shutdown was technically 

infeasible? 

•	 if applicable, a statement that a monthly monitoring G Yes G No 

program was initiated because a 1-year rolling average 

showed more than 10 percent of pumps in light liquid 

service (or three pumps if three is greater than 10 percent) 

were leaking? 

7.	 G Yes G No 

(3)(iv) 

8.	 Do you keep all records for at least 5 years? G Yes G No 

When any of the information regarding pumps and agitators in 

your notification of compliance status report changes, do you 

include the revised information in your next periodic report? 

§ 63.1363(h) 

§63.1367(a) 

6-47 
 

Checklist 3: Requirements for open-ended valves or lines (Option 1) 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Operating Requirements Comments 

1.	 Have you equipped open-ended valves or lines with a cap, G Yes G No 

blind flange, plug, or a second valve? §63.1363(d)(1)(i) 

2.	 G Yes G No 

either: (ii) 

•	 operations require flow of process fluid through the
 

open-ended valve or line, or
 

•	 

3.	 G Yes G No 

activities in question 2? (1)(ii) 

4.	 If you equipped open-ended valves or lines with a second G Yes G No 

valve, have you ensured that the valve on the process fluid end 

is closed before the second valve is closed? (2) 

B. Comments 

1.	 G Yes G No 

as specified in checklist 1 for open-ended valves or lines 

(2)(i)(A) 


 

of the monitoring period during which the changes occurred.
 

2.	 G Yes G No 

report? (3)(iv) 

3.	 Do you keep all records for at least 5 years? G Yes G No 

Does the open end remain sealed at all times except when 

§63.1363(d(1) 

maintenance or repair is being conducted? 

Did you replace the seal within 1 hour after completion of the 

§63.1363(d) 

§63.1363(d)

 Recordkeeping and Reporting Requirements 

If necessary, have you updated identification numbers prepared 

subject to the LDAR requirements (option 1) to reflect 

equipment changes? §63.1363(g) 

Note: updates must occur within 15 days after the conclusion 

When any of the information regarding open-ended valves and 

lines in your notification of compliance status report changes, 

do you include the revised information in your next periodic 

§63.1363(h) 

§63.1367(a) 

6-48 
 

Checklist 4: Requirements for valves in gas/vapor service and light liquid service (Option 1) 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements Comments 

1.	 	 Did you monitor for leaks from valves using the method in G Yes G No 

§63.180(b) by no later than 1 year after the compliance date 

(e.g., by December 23, 2004 for existing sources)? 

§63.1363(e) (2) 

2.	 Have you assigned valves to groups of processes or subgroups G Yes G No 

according to the procedures outlined in §63.1363(e)(5) and (6)? 

3.	 G Yes G No 

subgroup according to the procedures specified in 

§63.1363(e)(5) and (6)? 

4.	 G Yes G No 

valves in your group or subgroup based on the percent leakers 

calculated in question 3? (4) 

5.	 G Yes G No 

(5)(iii) 

)(6)(ii) 

6.	 If you subgroup valves and the overall group of processes from G Yes G No 

which the subgroups were developed has $2 percent leakers, 

(5)(iii) 

7.	 G Yes G No 

in your written plan? 

8.	 

following: (10) 

•	 G Yes G No 

valve? 

•	 G Yes G No 

Have you determined the percent leakers for the group or 

Do you determine the length of your next monitoring period for 

§63.1363(e) 

If you subgroup valves, do you determine the overall 

performance of valves in the group of processes from which the 

subgroups were developed every 6 months? §63.1363(e) 

and (e 

do you stop using the subgroups and monitor all of the valves 

in the group of processes monthly? §63.1363(e) 

For valves that you have designated as unsafe to monitor or 

difficult to monitor, do you monitor at the frequency specified 

§63.1363(f) 

When you detected a leak based on the results of monitoring 

with a leak detection instrument, did you do both of the 

§63.1363(a) 

attach a visible, weatherproof identification to the leaking 

leave the identification on the valve until after it was 

monitored as specified in §63.1363(e)(7)(iii) (i.e., within 3 

months after successful repair)? 

6-49
 
 
Checklist 4: (cont’d)
 
 

Requirements for valves in gas/vapor service and light liquid service
 
 

B. Leak Repair Requirements Comments

1.	 When you detected a leak, did you do both of the following: 

§63.1363(e)(7) and (8) 

•	 make your first attempt to repair the leak within 5 days G Yes G No 
 

after detecting the leak? 
 

•	 either fully repair the leak within 15 days after detecting it, G Yes G No 
 

or delay repair for any of the reasons in question 2? 
 

Note: first attempts to repair leaking valves include tightening
 
 

or replacement of bonnet bolts, tightening of packing gland
 
 

nuts, and injection of lubricant into lubricated packing.
 
 

2.	 If you delayed repair, was it for one of the following reasons: G Yes G No 

(3)( )(7)(i) 

•	 
 

shutdown, or
 

•	 
 


 

process unit shutdown, or
 

•	 
 


 

•	 
 


 

delaying the repair and using a control device to reduce the
 


 

•	 
 


 

3.	 G Yes G No 
 


 


 

end of the next process unit shutdown? (3)(i)(A) 
 

) (7)(i) 
 

4.	 G Yes G No 
 


 


 


 

(7)(i) 
 

5.	 G Yes G No 
 


 


 


 


 

(7)(i) 
 

§§63.1363(b) i), (e , and 63.171 

the repair was technically infeasible without a process unit 

you determined that repair personnel would be exposed to 

an immediate danger if attempting to repair without a 

the equipment was isolated from the process and did not 

remain in organic HAP service, or 

emissions purged from the equipment during immediate 

repair would be greater than emissions resulting from 

emissions, or 

valve assembly supplies are not on hand and valve 

replacement is needed during a process unit shutdown? 

If you determined that a repair was technically infeasible or 

would expose repair personnel to an immediate danger without 

a process unit shutdown, did you complete the repair by the 

§63.1363(b) 

and (B as cross referenced by §63.1363(e) 

If you determined that emissions purged from a valve during 

immediate leak repair would be greater than emissions 

resulting from delaying the repair, did you use a control device 

to reduce emissions generated during leak repair? §63.171(c) 

as cross referenced by §63.1363(e) 

If valve assembly supplies were not on hand during a process 

unit shutdown when valve replacement was needed, did you 

replace the valve assembly during the next process unit 

shutdown (unless a third shutdown occurred within 6 months 

from the first process unit shutdown)? §63.171(e) as cross 

referenced by §63.1363(e) 

6-50
 
 
Checklist 4: (cont’d)
 
 

Requirements for valves in gas/vapor service and light liquid service
 
 

B. Leak Repair Requirements Comments

6.	 	 If you made repairs to valves, did you monitor the valves at G Yes G No 

least once while the valves were in organic HAP service within 

the first 3 months after the repairs were made (in addition to the 

monitoring that verifies repair was successful)? 

§63.1363(e)(7)(iii) 

C. Recordkeeping and Reporting Requirements Comments

1. 	 Do your records include any updates to identification numbers G Yes G No 

prepared as specified in checklist 1 for valves subject to the 

equipment leak requirements? §63.1363(g)(2)(i)(A) 

Note: updates must occur within 15 days after the conclusion 
 

of the monitoring period during which the changes occurred. 
 

2. 

(2)(i)(B) 

G Yes G No 

3. 

(5)(iv) 

• which valves are assigned to each subgroup? G Yes G No 

• G Yes G No 

• which valves have been reassigned and when they were 

reassigned? 

G Yes G No 

• 

for the group of processes? 

G Yes G No 

4. 

valves earlier than 30 days before the beginning of the 

participating processes and the valves assigned to each 

subgroup.) (5)(v) 

G Yes G No 

5. Do your records include a list of valves that you designated as 

(2)(vi) 

G Yes G No 

6. For each leak that you detected, have you recorded: 

(4) 

• G Yes G No 

• G Yes G No 

• G Yes G No 

• G Yes G No 

Do your records include a valve monitoring schedule? 

§63.1363(g) 

Do your records include all of the following information 

pertaining to assignment of valves to process subgroups: 

§63.1363(e) 

monitoring results and calculations made for each subgroup 

for each monitoring period? 

results of the semiannual overall performance calculation 

Did you notify the Administrator of the decision to subgroup 

monitoring period? (The notification must identify the 

§63.1363(e) 

unsafe to monitor or difficult to monitor, and do you have a 

written plan for monitoring or inspecting this equipment? 

§63.1363(g) 

§63.1363(g) 

the instrument and the equipment identification number and 

the operator name, initials, or identification number? 

date the leak was detected? 

date of the first attempt to repair the leak? 

date of successful leak repair? 

6-51 
 
Checklist 4: (cont’d)
 
 

Requirements for valves in gas/vapor service and light liquid service
 
 

C. Recordkeeping and Reporting Requirements Comments

•	 maximum instrument reading measured by Method 21 of G Yes G No 
 

40 CFR part 60, appendix A, after leak is successfully 
 

repaired or determined to be non-repairable? 
 

•	 all of the following if repairs were delayed beyond 15 days
 

after leak detection:
 

<	 reason for the delay? 	 G Yes G No 

<	 dates of process shutdowns that occur while the GYes G No 
 

equipment is unrepaired? 
 

7.	 Did you include all of the following in your periodic report for 
 


 

(3)(ii)(A), (B), (I) ) 

•	 	 G Yes G No 

•	 	 G Yes G No 

•	 	 G Yes G No 

•	 G Yes G No 
 


 

•	 G Yes G No 
 

appropriate, why a process shutdown was technically 
 

infeasible? 
 

•	 G Yes G No 
 


 

group of processes that has subgroups? 
 

8.	 
 

report: (5)(vi) 
 

•	 G Yes G No 
 

period? 
 

•	 G Yes G No 

9.	 G Yes G No 
 


 


 

(3)(iv) 

10.	 Do you keep all records for at least 5 years? G Yes G No 

each monitoring period during the 6-month reporting period? 

§63.1363(h) , and (K 

the number of valves with leaks detected? 

the total number of valves monitored? 

the percent leakers? 

the number of valves with leaks that were not repaired and 

the number of those valves that are non-repairable? 

the facts that explain any delay of repairs and, where 

if applicable, a statement that a monthly monitoring 

program was initiated if 2 percent or more valves leak in a 

Did you include the following information in your periodic 

§63.1363(e) 

valve reassignments that occurred during the reporting 

results of the semiannual overall performance calculation? 

When any of the information regarding valves in your 

notification of compliance report changes, do you include the 

revised information in you next periodic report? 

§63.1363(h) 

§63.1367(a) 

6-52 
 
Checklist 5: Requirements for compressors (Option 1) 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Design and Monitoring Requirements Comments

1.	 	 Are your compressors equipped with a seal system that G Yes G No 
 

includes a barrier fluid system to prevent leaks of process fluid 
 

to the atmosphere? §63.164(a) 
 

Note: this requirement does not apply to compressors that you 
 
 

designate as operating with a leak detection instrument
 
 

reading of less than 500 ppm above background.
 
 

2.	 	 G Yes G No 

•	 operated with the barrier fluid pressure greater than the
 
 


 
 

•	 
 
 


 
 


 
 

•	 
 
 

fluid directly into a process stream
 
 

3.	 	 Is each barrier fluid in heavy liquid service? G Yes G No 

4.	 	 G Yes G No 
 


 


 

5.	 	 G Yes G No 
 


 


 

6.	 	 
 


 


 


 


 

•	 upon designation? 	 G Yes G No 

•	 	 G Yes G No 

•	 G Yes G No 

Does each compressor seal system meet any of the following: 

§63.164(b) 

compressor stuffing box pressure, or 

equipped with a barrier fluid system degassing reservoir 

that is routed to a process or fuel gas system or connected 

by a closed-vent system to a control device, or 

equipped with a closed-loop system that purges the barrier 

§63.164(c) 

Is the barrier fluid system equipped with a sensor that will 

detect failure of the seal system, barrier fluid system, or both 

the seal and barrier fluid system? §63.164(d) 

Have you observed the barrier fluid system failure sensor daily 

(unless the sensor has an alarm or the equipment is at an 

unmanned plant site)? §63.164(e) 

For each compressor that you designated to operate with an 

instrument reading of less than 500 ppm above background, 

have you monitored using a leak detection instrument to 

demonstrate compliance with the 500 ppm limit at all of the 

following times:. §63.164(i) 

annually? 

any other times requested by the Administrator? 

6-53 
 

Checklist 5: (cont’d) 

Requirements for compressors 

A. Design and Monitoring Requirements Comments

7.	 	 When your sensor detected a failure (i.e., a leak), did you do 

both of the following: §63.1363(a)(10) 

•	 attach a visible, weatherproof identification to the leaking G Yes G No 

compressor? 

•	 leave the identification on the compressor until after the G Yes G No 

leak was repaired? 

B. Leak Repair Requirements Comments

1.	 	 When a sensor detects a failure, did you do both of the 

following: §63.164(g) 

•	 make your first attempt to repair the leak within 5 days G Yes G No 

after detecting it? 

•	 either fully repair the leak within 15 days after detecting it, G Yes G No 

or delay repair for any of the reasons in question 2? 

2.	 If you delayed repair, was it for one of the following reasons: G Yes G No 

(3)(i)(A) ) ( 

•	 
 

shutdown?
 

•	 
 


 

process unit shutdown?
 

•	 
 


 

3.	 G Yes G No 

end of the next process unit shutdown? (3)(i)(A) 

) (1) 

C. Comments 

1.	 G Yes G No 

(2)(i)(A) 

2.	 G Yes G No 

(2)(ii)(B) 

§§63.1363(b) and (B , 63.164(g) 1), and 63.171 

the repair is technically infeasible without a process unit 

you determined that repair personnel would be exposed to 

an immediate danger if attempting to repair without a 

the equipment was isolated from the process and does not 

remain in organic HAP service? 

If you determined that a repair was technically infeasible or 

would expose repair personnel to an immediate danger without 

a process unit shutdown, did you complete the repair by the 

§63.1363(b) 

and (B as cross referenced by §63.164(g)

 Recordkeeping and Reporting Requirements 

If necessary, have you updated identification numbers prepared 

as specified in checklist 1 for compressors subject to the LDAR 

requirements (option 1) to reflect equipment changes? 

§63.1363(g) 

Do your records include identification numbers for 

compressors that you designated as operating with an 

instrument reading of less than 500 ppm above background 

§63.1363(g) 

6-54 
 

Checklist 5: (cont’d) 

Requirements for compressors 

C. Recordkeeping and Reporting Requirements Comments

3.	 	 Do your records include all of the following information for 
 

each sensor used to detect failure of the compressor system 
 

and/or barrier fluid system: §63.1363(g)(2)(v) 
 

•	 design criteria that indicates failure of the seal system G Yes G No 
 

and/or the barrier fluid system? 
 

•	 your explanation of the design criteria? 	 	 G Yes G No 

•	 any changes to the design criteria and the reasons for the G Yes G No 
 

changes 
 

4.	 For each leak that you detected, did you record: 

(4) 

•	 	 G Yes G No 

•	 	 G Yes G No 

•	 	 G Yes G No 

•	 G Yes G No 
 

40 CFR part 60, appendix A, after leak is successfully 
 


 

•	 G Yes G No 
 

leak discovery and the reason for the delay? 
 

•	 
 

after leak detection
 

<	 reason for the delay? 	 G Yes G No 

<	 dates of process shutdowns that occur while the G Yes G No 
 


 

5.	 Did you record all of the following for each test used to 
 


 

(6) 
 

•	 	 G Yes G No 

•	 	 G Yes G No 

•	 	 G Yes G No 

§63.1363(g) 

date the leak was detected? 

date of the first attempt to repair the leak? 

date of successful leak repair? 

maximum instrument reading measured by Method 21 of 

repaired or determined to be non-repairable? 

whether the repair is delayed for more than 15 days after 

all of the following if repairs were delayed beyond 15 days 

equipment is unrepaired? 

demonstrate compliance with the 500 ppm limit for designated 

compressors: §63.1363(g) 

date of each test? 

measured background level? 

maximum instrument reading? 

6-55 
 
Checklist 5: (cont’d) 

Requirements for compressors 

C. Recordkeeping and Reporting Requirements Comments

6.	 	 Do you include all of the following in your periodic report for 

each monitoring period during the 6-month reporting period? 

§63.1363(h)(3)(ii)(E), (F), and (J) 

•	 the number of compressors for which leaks were detected? G Yes G No 

•	 the number of compressors for which leaks were not G Yes G No 

repaired? 

•	 the facts that explain any delay of repairs and, where G Yes G No 

appropriate, why a process shutdown was technically 

infeasible? 

•	 the results of all monitoring to show compliance with the G Yes G No 

500 ppm limit for compressors designated to operate below 

500 ppm? 

7.	 G Yes G No 

(3)(iv) 

8.	 Do you keep all records for at least 5 years? G Yes G No 

When any of the information regarding compressors in your 

notification of compliance status report changes, do you 

include the revised information in you next periodic report? 

§63.1363(h) 

§63.1367(a) 

6-56 
 

Checklist 6: Requirements for pressure relief devices in gas/vapor service (Option 1) 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring Requirements Comments 

Note: You are exempt from the requirements for pressure relief devices in gas/vapor service if your pressure 

relief device is routed to a process. § 63.165(c) 

1.	 	 Do your pressure relief devices have either: §§63.165(a) and G Yes G No 

63.165(d) 

•	 a leak detection instrument reading of less than 500 ppm 
 


above background (except during pressure releases) when
 


monitored using the method in §63.180(c), or 
 


•	 a rupture disk upstream of the pressure relief device? 

2.	 Following a pressure release, do you either: G Yes G No 

•	 
 

pressure release and return of the pressure relief device to
 


 


 

•	 
 

within 5 days following the pressure release? 
 

Note that if you install a rupture disk, you are exempt from
 

monitoring for 500 ppm.
 

B. Comments 

1.	 G Yes G No 

as specified in checklist 1 for pressure relief devices subject to 

changes? (2)(i)(A) 

2.	 G Yes G No 

relief devices that are either of the following: 

(2)(iii) 

•	 
 


 

•	 

monitor your pressure relief device within 5 days after a 

organic HAP service to ensure a reading of less than 500 

ppm above background, or §63.165(b) 

place a rupture disk upstream of your pressure relief device

 §63.165(d)

 Recordkeeping and Reporting Requirements 

If necessary, have you updated identification numbers prepared 

the LDAR requirements (option 1) to reflect equipment 

§63.1363(g) 

Do your records include identification numbers for pressure 

§63.1363(g) 

subject to the LDAR requirement to operate with an 

instrument reading of <500 ppm, or 

equipped with rupture disks? 

6-57 
 
Checklist 6: (cont’d)
 
 

Requirements for pressure relief devices in gas/vapor service
 
 

B. Recordkeeping and Reporting Requirements Comments

3.	 	 Did you record all of the following for each test used to 

demonstrate compliance with the 500 ppm operating limit: 

§63.1363(g)(6) 

• date of each test?	 	 G Yes G No 

• measured background concentration?	 	 G Yes G No 

• maximum instrument reading?	 	 G Yes G No 

4.	 G Yes G No 

periodic report? (3)(ii)(J) 

5.	 G Yes G No 

report? (3)(iv) 

6.	 Do you keep all records for at least 5 years? G Yes G No 

Have you included the results of monitoring with a leak 

detection instrument after pressure releases in your next 

§63.1363(h) 

When any of the information regarding pressure relief devices 

in your notification of compliance status report changes, have 

you included the revised information in your next periodic 

§63.1363(h) 

§63.1367(a) 

6-58 
 
Checklist 7: Requirements for sampling connection systems (Option 1) 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Design Requirements Comments 

Note: In-situ sampling systems and sampling systems without purges are exempt from the requirements for 

sampling connection systems. §63.166(c) 

1.	 Do each of your sampling connection systems have a closed- G Yes G No 

purge, closed-loop, or closed-vent system? §63.166(a) 

2.	 G Yes G No 

one of the following: 

•	 
 


 

•	 

•	 capture and transport purged process fluid to a control
 

device, or
 

•	 
 


 

facility?
 

B. Comments 

1.	 G Yes G No 

(2)(i)(A) 

2.	 G Yes G No 

periodic report? (3)(iv) 

3.	 Do you keep all records for at least 5 years? G Yes G No 

Do the closed-purge, closed-loop, or closed-vent systems do 

§63.166(b) 

return the purged process fluid directly to the process line 

from which it was removed, or 

collect and recycle purged process fluid to any process, or 

collect, store, and transport purged process fluid to a waste 

management unit, TSDF, or permitted waste management

 Recordkeeping and Reporting Requirements 

If necessary, have you updated any identification numbers 

prepared as specified in checklist 1 for sampling connection 

systems subject to the LDAR requirements (option 1) to reflect 

equipment changes? §63.1363(g) 

When any of the information regarding sampling connection 

systems in your notification of compliance status report 

changed, did you include the revised information in your next 

§63.1363(h) 

§63.1367(a) 

6-59 
 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

________________________________________________________ 

Checklist 8: Requirements for pumps, valves, connectors, and agitators in heavy liquid service; 

instrumentation systems; and pressure relief devices in liquid service (Option 1) 

Facility Name: 
 
 

Facility Location:
 
 

Facility TRI ID #:
 
 

Inspector:
 
 

Date:
 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

A. Monitoring Requirement Comments 

1.	 	 After detecting a potential leak by sensory observations, do you G Yes G No 

either: §63.169(a) and (c)(3) 

•	 monitor for leaks using the method in § 63.180(b) within
 
 

5 days after the potential leak is detected, or
 
 

•	 repair the leak such that any of the following are true: 

•	 you can no longer see, hear, smell, or otherwise detect
 
 

the potential leak, or
 
 

•	 you see no bubbles at potential leak sites during a leak
 
 

check with soap solution, or
 
 

•	 the system will hold a test pressure? 

2.	 	 

following: (10) 

•	 G Yes G No 

•	 G Yes G No 

was repaired? 

B. Comments 

1.	 	 

(1) ) 

•	 G Yes G No 

after detecting it? 

•	 G Yes G No 

or delay repair for any of the reasons in question 2? 


 
 

include tightening or replacement of bonnet bolts, tightening of
 
 

packing gland nuts, and injection of lubricant into lubricated
 
 


 
 

include tightening of packing gland nuts and ensuring the seal
 
 

flush is operating at design pressure and temperature.
 
 

When you detected a leak based on the results of monitoring 

with a leak detection instrument, did you do both of the 

§63.1363(a)

attach a visible, weatherproof identification to the leaking 

equipment? 

leave the identification on the equipment until after the leak 

Leak Repair Requirements 

When you detected a leak, did you do both of the following: 

§63.169(c) and (2

make your first attempt to repair the leak within 5 days 

either fully repair the leak within 15 days after detecting it, 

Note: examples of first attempts to repair leaking valves

packing. Examples of first attempts to repair leaking pumps

6-60
 
 
Checklist 8: (cont’d)
 
 

Requirements for pumps, valves, connectors, and agitators in heavy liquid service; instrumentation
 
 

systems; and pressure relief devices in liquid service
 
 

B. Leak Repair Requirements Comments

2.	 If you delayed repair, was it for one of the following reasons: G Yes G No 

§§63.1363(b)(3)(i), 63.171, and 63.169(c)(1) 

•	 the repair was technically infeasible without a process unit
 
 

shutdown, or
 
 

•	 you determined that repair personnel would be exposed to
 
 

an immediate danger if attempting to repair without a
 
 

process unit shutdown, or
 
 

•	 the equipment was isolated from the process and did not
 
 

remain in organic HAP service, or
 
 

•	 emissions purged from valves, connectors, or agitators
 
 

during immediate repair would be greater than emissions
 
 

resulting from delaying the repair and using a control
 
 

device to reduce the emissions, or
 
 

•	 pump repair required replacement of the existing seal with
 
 

a new system that will better meet the PAI rule
 
 

requirements, or
 
 

•	 valve assembly replacement was necessary during a process
 
 

unit shutdown, but valve assembly supplies were not on
 
 

hand even though they had been sufficiently stocked before
 
 

being depleted?
 
 

3.	 technically infeasible or G Yes G No 
 

would expose repair personnel to an immediate danger 
 


 

by the end of the next process unit shutdown? 
 

(3)( (1) 

4.	 valves, G Yes G No 
 

connectors, or agitators 
 


 


 

during leak repair? 
 

(1) 
 

5.	 pump G Yes G No 
 


 


 


 

(1) 
 

6.	 If valve G Yes G No 
 


 


 


 


 

(1) 
 

If you determined that a repair was 

without a process unit shutdown, did you complete the repair 

§§63.1363(b) i) and 63.169(c) 

If you determined that emissions purged from 

 during immediate leak repair would 

be greater than emissions resulting from delaying the repair, 

did you use a control device to reduce emissions generated 

§63.171(c) as cross referenced by 

§63.169(c) 

If you determined that repair required replacement of the 

existing seal with a new system to better meet the PAI rule 

requirements, did you repair the leak less than 6 months from 

the time when the leak was detected? §63.171(d) as cross 

referenced by §63.169(c)

 assembly supplies were not on hand during a process 

unit shutdown when valve replacement was needed, did you 

replace the valve assembly during the next process unit 

shutdown (unless a third shutdown occurred within 6 months 

from the first process unit shutdown)? §63.171(e) as cross 

referenced by §63.169(c) 

6-61
 
 
Checklist 8: (cont’d)
 
 

Requirements for pumps, valves, connectors, and agitators in heavy liquid service; instrumentation
 
 

systems; and pressure relief devices in liquid service
 
 

C. Recordkeeping and Reporting Requirements Comments

2. 	 If necessary, have you updated equipment identification G Yes G No 

numbers prepared as specified in checklist 1 to reflect any 

equipment changes? §63.1363(g)(2)(i)(A) and (iv) 

3. For each leak that you detected, have you recorded: 

(4) 

• G Yes G No 

• G Yes G No 

• G Yes G No 

• G Yes G No 

• 

40 CFR part 60, appendix A, after leak is successfully 

G Yes G No 

• 

after leak detection: 

< reason for the delay? G Yes G No 

< dates of process shutdowns that occur while the G Yes G No 

4. 

your next periodic report? (3)(iv) 

G Yes G No 

5. Do you keep all records for at least 5 years? G Yes G No 

§63.1363(g) 

the instrument and the equipment identification number and 

the operator name, initials, or identification number? 

date the leak was detected? 

date of the first attempt to repair the leak? 

date of successful leak repair? 

maximum instrument reading measured by Method 21 of 

repaired or determined to be non-repairable? 

all of the following if repairs were delayed beyond 15 days 

equipment is unrepaired? 

When any of the information in your notification of compliance 

status report regarding equipment in heavy liquid service, 

instrumentation systems, or pressure relief devices in liquid 

service changed, did you include the revised information in 

§63.1363(h) 

§63.1367(a) 

6-62
 
 
Checklist 9: Requirements for connectors in gas/vapor service and in light liquid service (Option 

1) 

Facility Name: 
 ________________________________________________________ 

Facility Location:
 ________________________________________________________ 

Facility TRI ID #:
 ________________________________________________________ 

Inspector:
 ________________________________________________________ 

Date:
 ________________________________________________________ 

Note: 

A. Monitoring and Inspection Requirements Comments 

1.	 G Yes G No 

2.	 G Yes G No 

•	 
 

sources, or (1)
 

•	 
 


 

June 23, 2000)? (2)
 

3.	 G Yes G No 

4.	 

your percent leaking calculation, were all of the following 

•	 G Yes G No 

•	 G Yes G No 

•	 G Yes G No 

•	 G Yes G No 


 

welded completely around the circumference, you can not
 

eliminate the connector from the monitoring requirements.
 

A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. 

Did you monitor for leaks from each connector using the 

method in §63.180(b)? §63.174(a) 

Did you perform initial monitoring of all connectors either: 

within 12 months after the compliance date at existing 

§63.174(b) 

within 12 months after initial start-up at new sources 

(except that it does not have to be completed earlier than 

§63.174(b) 

Have you determined your percent leaking connectors using the 

methods in §63.174(i)? 

If you elected to take credit for elimination of a connector in 

requirements met: §63.174(j) 

The connector was welded after November 10, 1997? 

The integrity of the weld was demonstrated by Method 21 

monitoring, X-ray testing, acoustic monitoring, 

hydrotesting, or other method? 

Welds created after November 10, 1997 but before June 23, 

1999 were monitored or tested by 3 months after the 

compliance date? 

Welds created after June 23, 1999 were monitored or tested 

within 3 months after being welded? 

Note: If the weld is inadequate, or the connector was not 

6-63
 
 
Checklist 9: (cont’d)
 
 

Requirements for connectors in gas/vapor service and in light liquid service
 
 

A. Monitoring and Inspection Requirements Comments 

5.	 	 Have you performed repeat monitoring at the time intervals G Yes G No 
 

below that apply to you: §63.1363(b)(3)(iii) 
 

•	 each year (or every 2 years) if your percent leaking
 
 

connectors is $0.5%, or
 
 

•	 every 4 years if your percent leaking connectors is $0.25 to
 
 

0.5%, or
 
 

•	 every 8 years if your percent leaking connectors is <0.25%? 

Note: the periodic monitoring after the initial survey is not
 

required for certain screwed connectors (see question 8).
 

6.	 or G Yes G No 
 

have a using one of the following two options: 
 

(1)( 

•	 
 


 


 


 

•	 
 

connector as nonrepairable?
 

7.	 
 

question 6, did you do both of the following: (1)(iii) 
 

•	 G Yes G No 
 

(and you reported the switch)? 
 

•	 G Yes G No 
 


 

8.	 screwed connectors with an G Yes G No 

(2) 

•	 
 


 

liquid service), or
 

•	 
 

has the seal broken:
 

<	 
 

connector is returned to organic HAP service, and
 

<	 

9.	 G Yes G No 

your written plan? 

Have you monitored connectors that have been opened 

broken seal 

§63.174(c) i) and (ii) 

Monitored the connector for leaks when it is reconnected or 

within the first 3 months after it is returned to organic HAP 

service. If a leak was detected, you repaired the leak 

(unless it is determined to be nonrepairable), or 

Did not monitor the connector and did not count the 

If you switched between the two monitoring alternatives in 

§63.174(c) 

Make the switch at the end of the current monitoring period 

Complete initial monitoring in the new alternative no later 

than 12 months after you reported the switch? 

If you elected not to monitor 

inside diameter of 2 inches or less that were installed before 

November 10, 1997, have you done one of the following: 

§63.174(c) 

complied with the requirements of §63.169 of subpart H 

(i.e., the same requirements as for connectors in heavy 

both of the following each time the connector is opened or 

monitored for leaks within the first 3 months after the 

repaired leaks detected by the monitoring? 

For connectors that you have designated as unsafe to monitor 

or inaccessible, do you monitor at the frequency specified in 

§63.1363(f) 

6-64
 
Checklist 9: (cont’d)
 
 

Requirements for connectors in gas/vapor service and in light liquid service
 
 

A. Monitoring and Inspection Requirements Comments 

10.	 	 When you detected a leak based on the results of monitoring 

with a leak detection instrument, did you do both of the 

following: §63.1363(a)(10) 

•	 attach a visible, weatherproof identification to the leaking G Yes G No 

connector? 

•	 leave the identification on the connector until after it was G Yes G No 

monitored and determined to be not leaking if you comply 

with §63.174(c)(1)(i), or until the leak was repaired if you 

comply with §63.174(c)(1)(ii)? 

B. Leak Repair Requirements Comments

1.	 	 When you detected a leak, did you do both of the following: 

§63.174(d) 

•	 make your first attempt to repair the leak within 5 days G Yes G No 
 

after detecting it? 
 

•	 either fully repair the leak within 15 days after detecting it, G Yes G No 
 

or delay repair for any of the reasons in question 2? 
 

2.	 If you delayed repair, was it for one of the following reasons: G Yes G No 

(3)( 

•	 
 

shutdown, or
 

•	 
 


 

process unit shutdown, or
 

•	 
 


 

•	 
 


 

delaying the repair and using a control device to reduce the
 


 

3.	 G Yes G No 
 


 


 

end of the next process unit shutdown? (3)(i)(A) 
 

) 
 

4.	 G Yes G No 
 


 


 


 


 

§§63.1363(b) i), 63.171, and 63.174(d) 

the repair was technically infeasible without a process unit 

you determined that repair personnel would be exposed to 

an immediate danger if attempting to repair without a 

the equipment was isolated from the process and did not 

remain in organic HAP service, or 

emissions purged from the connector during immediate 

repair would be greater than emissions resulting from 

emissions? 

If you determined that a repair was technically infeasible or 

would expose repair personnel to an immediate danger without 

a process unit shutdown, did you complete the repair by the 

§63.1363(b) 

and (B as cross referenced by §63.174(d) 

If you determined that emissions purged from a connector 

during immediate leak repair would be greater than emissions 

resulting from delaying the repair, did you use a control device 

to reduce emissions generated during leak repair? §63.171(c) 

as cross referenced by §63.174(d) 

6-65
 
 
Checklist 9: (cont’d)
 
 

Requirements for connectors in gas/vapor service and in light liquid service
 
 

C. Recordkeeping and Reporting Requirements Comments

1. 	 Do your records include updates to the list of identification G Yes G No 

numbers prepared as specified in checklist 1 for connectors 

subject to LDAR requirements (option 1)? 

§63.1363(g)(2)(i)(A) 

2. 

(2)(i)(B) 

G Yes G No 

3. Do your records include a list of connectors that you 

connectors? (2)(vi) 

G Yes G No 

4. 

leaking calculation, do you have records of both of the 

following: (2)(vii) 

• 

process? 

G Yes G No 

• 

connectors? 

G Yes G No 

5. For each leak that you detected, have you recorded: 

(4) 

• G Yes G No 

• G Yes G No 

• G Yes G No 

• G Yes G No 

• 

40 CFR part 60, appendix A, after leak is successfully 

G Yes G No 

• 

after leak detection: 

< reason for the delay? G Yes G No 

< dates of process shutdowns that occur while the G Yes G No 

• G Yes G No 

Do your records include a schedule for monitoring connectors? 

§63.1363(g) 

designated as unsafe to monitor or inaccessible, and do you 

have a written plan for monitoring or inspecting these 

§63.1363(g) 

If you have taken credit for removed connectors in your percent 

§63.1363(g) 

a listing of connectors removed from or added to the 

documentation of the integrity of the weld for removed 

§63.1363(g) 

the instrument and the equipment identification number and 

the operator name, initials, or identification number? 

date the leak was detected? 

date of the first attempt to repair the leak? 

date of successful leak repair? 

maximum instrument reading measured by Method 21 of 

repaired or determined to be non-repairable? 

all of the following if repairs were delayed beyond 15 days 

equipment is unrepaired? 

identification of connectors in gas/vapor and light liquid 

service disturbed since the last monitoring period (unless 

you use the option for not monitoring open connectors 

during the monitoring period). 

6-66
 
Checklist 9: (cont’d)
 
 

Requirements for connectors in gas/vapor service and in light liquid service
 
 

C. Recordkeeping and Reporting Requirements Comments

6.	 	 Did you include the following in your periodic report for each 

monitoring period during the 6-month reporting period: 

§§63.1363(h)(3)(ii)(G), (H), (I), and (L) 

•	 the number of connectors in gas/vapor or light liquid G Yes G No 

service for which leaks were detected as described? 

•	 the total number of connectors monitored? 	 	 G Yes G No 

•	 the percent leaking? 	 	 G Yes G No 

•	 the number of connectors in gas/vapor or light liquid G Yes G No 

service for which leaks were not repaired, and the number 

of those that are determined non-repairable? 

•	 the facts that explain any delay of repairs and, where G Yes G No 

appropriate, why a process shutdown was technically 

infeasible? 

•	 if applicable, notification of a change in connector G Yes G No 

monitoring alternatives for connectors that have been 

opened or have broken seals? 

7.	 G Yes G No 

report regarding connectors changed, did you include the 

(3)(iv) 

8.	 Do you keep all records for at least 5 years? G Yes G No 

When any information in your notification of compliance status 

revised information in your next periodic report? 

§63.1363(h) 

§63.1367(a) 

6-67 
 

Checklist 10: Requirements for closed-vent systems and control devices (Option 2) 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Operating Requirements Comments 

1.	 	 Have you operated your closed-vent system and control device G Yes G No 

at all times when organic HAP emissions are being vented? 

§63.172(m) 

2.	 If you operate a recovery or capture device (e.g., condenser, G Yes G No 

$95 percent reduction or 

#


 

enclosed the process unit.
 

3.	 G Yes G No 

either $95 percent reduction, # o

F 

(760o

C)? 

4.	 G Yes G No 

§63.11(b)? 

5.	 G Yes G No 

§63.179 

B. Monitoring and Inspection Requirements Comments 

1.	 G Yes G No 

based on sight, sound, or odor? (1)(ii) 


 

operates under negative pressure.
 

2.	 G Yes G No 

of duct work, did you conduct annual inspections using a leak 

§63.180(b)? (2)( 


 

operates under negative pressure.
 

absorber, etc.), have you met either 

20 ppmv? §63.172(b) 

Note: The 20 ppmv standard is not applicable if you have 

If you operate an enclosed combustion device, have you met 

20 ppmv (dry basis, 3 percent 

oxygen), or a minimum residence time of 0.5 sec. at 1400 

§63.172(c) 

If you operate a flare, have you met the requirements of 

§63.172(d) 

If you have enclosed a process unit, do you maintain your 

enclosure under negative pressure at all times? 

If your closed-vent system is made of hard-piping, did you 

perform annual sensory inspections for indications of leaks 

§63.172(f) 

Note: the inspection is not required if the closed-vent system 

If your vapor collection system or closed-vent system is made 

detection instrument according to the procedures in 

§63.172(f) ii) and (g) 

Note: the inspection is not required if the closed-vent system 

6-68
 
Checklist 10: (cont’d)
 
 

Requirements for closed-vent systems and control devices
 
 

B. Monitoring and Inspection Requirements Comments 

3.	 If your closed-vent system has bypass lines that could divert a G Yes G No 

vent stream away from the control device and to the 

atmosphere, have you done one of the following: §63.172(j) 

•	 Used a flow indicator that takes a reading at least once
 
 

every 15 minutes at the entrance of the bypass line, or
 
 

•	 Secured the bypass line valve in the non-diverting position
 
 

with a car-seal or a lock-and-key type configuration?
 
 

Note: Low leg drains, high point bleeds, analyzer vents,
 

open-ended valves or lines, and pressure relief valves needed
 

for safety purposes are not subject to the monitoring
 

requirements for bypass lines. §63.172(j)(3)
 

5 

4.	 If you secured the bypass line valve in the non-diverting G Yes G No 

position as specified in question 3, did you visually inspect the 

(2) 

G Yes G No 

(3)(ii)(B) 

C. Comments 

1.	 

•	 

after detecting it? 

•	 

or delay repair for any of the reasons in question 2? 

2.	 If you delayed repair, was it for one of the following reasons: 

•	 

shutdown, or 

•	 

3.	 

by the end of the next process unit shutdown? 

G Yes G No 

G Yes G No 

G Yes G No 

G Yes G No 

seal or closure mechanism monthly to ensure the valve is 

maintained in the non-diverting position? §63.172(j) 

If your closed-vent system is designed to operate below 

atmospheric pressure, have you installed a pressure 

measurement device in a readily accessible location? 

§63.1363(b) 

Leak Repair Requirements 

When you detected a leak, did you do both of the following: 

§63.172(h) 

make your first attempt to repair the leak within 5 days 

either fully repair the leak within 15 days after detecting it, 

§63.172(i) 

the repair was technically infeasible without a process unit 

emissions resulting from immediate repair of the leak 

would be greater than the fugitive emissions likely to result 

from delay of repair? 

If you determined that a repair was technically infeasible 

without a process unit shutdown, did you complete the repair 

§63.172(i) 

6-69 
Checklist 10: (cont’d)
 
 

Requirements for closed-vent systems and control devices
 
 

D. Recordkeeping and Reporting Requirements Comments

1. 	 Do your records of identification numbers prepared as specified 

in checklist 1 indicate each component in the following 

categories of equipment that are equipped with a closed-vent 

system and comply with option 2: §63.1363(g)(2)(ii)(A) 

• pumps in light liquid service? 

• agitators in gas/vapor and light liquid service? 	 G Yes G No 

• compressors? 	 G Yes G No 

• 	 pressure relief devices in gas/vapor service? G Yes G No 

G Yes G No 

2. If necessary, do your records include updates to the list of 

(2)(i)(A) 

G Yes G No 

3. 

(2)(vi) 

G Yes G No 

4. 

have you recorded: ( (iii)(B) 

• 

applicable)? 

G Yes G No 

• G Yes G No 

• G Yes G No 

• G Yes G No 

• 

40 CFR part 60, appendix A, after leak is successfully 

G Yes G No 

• 

< reason for the delay? G Yes G No 

< dates of process shutdowns that occur while the G Yes G No 

identification numbers prepared as specified in checklist 1 to 

reflect any equipment changes? §63.1363(g) 

Do your records identify parts of closed-vent systems that you 

designated as unsafe to monitor or difficult to monitor, and do 

you have a written plan for monitoring or inspecting this 

equipment? §63.1363(g) 

When your sensory inspections or monitoring using a leak 

detection instrument identified a leak in a closed vent system, 

§63.1363(g) 4) and (7) 

the instrument and the equipment identification number and 

the operator name, initials, or identification number (if 

date the leak was detected? 

date of the first attempt to repair the leak? 

date of successful leak repair? 

maximum instrument reading measured by Method 21 of 

repaired or determined to be non-repairable? 

all of the following if repair was delayed: 

equipment is unrepaired? 

6-70
 
 
Checklist 10: (cont’d)
 
 

Requirements for closed-vent systems and control devices
 
 

D. Recordkeeping and Reporting Requirements Comments

5.	 	 If you use a flow indicator to monitor your closed-vent system 
 

bypass line, do you have all of the following records: 
 

§63.172(j) 

•	 hourly flow indicator readings? 	 	 G Yes G No 

•	 times and durations of periods when the flow indicator was G Yes G No 
 

not operating? 
 

•	 times and durations of periods when the vent stream was G Yes G No 
 

diverted form the control device? 
 

6.	 Do your records include all of the following design and 
 

control devices: 
 

(7)(i) 

•	 G Yes G No 
 


 

•	 G Yes G No 
 

specifications? 
 

•	 G Yes G No 
 


 


 

•	 G Yes G No 
 


 


 


 

7.	 If you enclose a process, do you keep records of all of the 
 

following: (10) 
 

•	 G Yes G No 
 

handles? 
 

•	 G Yes G No 
 


 

•	 G Yes G No 
 

pressure in the enclosure? 
 

8.	 Do your records include all of the following operational 
 


 

(7)(ii) 

•	 G Yes G No 
 

control devices are not operated as designed, as indicated 
 


 


 

•	 G Yes G No 

•	 G Yes G No 
 

devices? 
 

performance documentation for 

§63.1363(g) 

detailed schematics, design specifications of the control 

device, and piping and instrumentation diagrams? 

the dates and descriptions of any changes in the design 

for flares: a description of the flare design (i.e., steam 

assisted, air assisted, or nonassisted) and the results of the 

compliance demonstration required by §63.11(b)? 

a description of the parameter or parameters monitored to 

ensure that control devices are operated and maintained as 

designed and an explanation of why each parameter was 

selected for the monitoring? 

§63.1363(g) 

identification of the process and the organic HAP it 

a schematic of the process, enclosure, and closed-vent 

system? 

a description of the system used to create a negative 

information for closed vent systems and control devices: 

§63.1363(g) 

dates and durations when the closed-vent systems and 

by the monitored parameters (including periods when a 

flare pilot light system does not have a flame)? 

dates and durations when the monitor is not operating? 

dates and durations of startups and shutdowns of control 

6-71
 
 
Checklist 10: (cont’d)
 
 

Requirements for closed-vent systems and control devices
 
 

D. Recordkeeping and Reporting Requirements Comments

9.	 	 If you detect no leaks during an visual inspection of a closed G Yes G No 

vent system, do you keep a record that the inspection was 

performed, the date of the inspection, and a statement that no 

leaks were detected? §63.1363(g)(7)(iii)(A) 

10.	 Do your periodic reports include the following for each 

(3)(ii) 

•	 G Yes G No 

was technically infeasible? 

•	 G Yes G No 

11.	 G Yes G No 

ave you identified in your periodic report whether you are 

•	 40 CFR part 264, subpart BB, or in 40 CFR part 265,
 

subpart BB, or
 

•	 

12.	 G Yes G No 

periodic report? (3)(iv) 

13.	 Do you keep all records for at least 5 years? G Yes G No 

monitoring period during the 6-month reporting period: 

§63.1363(h) 

the facts that explain any delay of repairs of a closed vent 

system and, where appropriate, why a process shutdown 

the results of all monitoring to show compliance with the 

provisions for inspections of closed vent systems? 

For any control device that is subject to RCRA requirements, 

complying with the monitoring, recordkeeping, and reporting 

requirements in either: §63.172(n) 

subpart MMM (the PAI rule)? 

When any of the information in your notification of compliance 

status report regarding equipment equipped with a closed vent 

system, closed-vent systems, enclosures, or control devices 

changed, did you include the revised information in your next 

§63.1363(h) 

§63.1367(a) 

6-72 
 
Checklist 11: Requirements for pressure testing (Option 3) 

Facility Name: ________________________________________________________ 
 

Facility Location: ________________________________________________________ 
 

Facility TRI ID #: ________________________________________________________ 
 

Inspector: ________________________________________________________ 
 

Date: ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 
 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 
 

comments column. 
 

A. Monitoring and Inspection Requirements Comments 

1.	 	 Do you perform pressure testing each time the equipment is G Yes G No 

reconfigured for production of a different product (using the 

procedures in §63.180(f) for pressure or vacuum loss or 

§63.180(g) for a test using liquid)? §63.178(b)(1) 

Note: After equipment is reconfigured, only the new or 
 
 

disturbed equipment must be pressure tested. Also, pressure 
 
 

testing is not required for routine seal breaks.
 
 

2.	 G Yes G No 

pressure test at least once per year? (1)(iii) 

B. Comments 

1.	 If you detected a leak during pressure testing, did you do one of G Yes G No 

the following: (4) 

•	 
 

start-up, or
 

•	 
 


 

2.	 

•	 G Yes G No 

•	 G Yes G No 

been depleted? 

•	 G Yes G No 

C. Comments 

1.	 Do you have records of all of the following: (5) 

•	 G Yes G No 

during the calendar year? 

•	 G Yes G No 

Regardless of how often equipment is reconfigured, do you 

§63.178(b) 

Leak Repair Requirements 

§63.178(b) 

repair the leak and retest the equipment before process 

repair the leak within 30 days after the second pressure test 

if the equipment failed the second test? 

If you delayed repair of leaks for equipment in a process that 

was pressure tested, did all the following circumstances apply : 

§63.178(d) 

replacement equipment was not available? 

equipment supplies (which were sufficiently stocked) have 

the repair is made no later than 10 days after delivery of the 

replacement equipment? 

 Recordkeeping and Reporting Requirements 

§63.1363(g) 

identification of each product, or product code, produced 

identification of equipment in the process on a plant site 

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

6-73
 
 
Checklist 11: (cont’d) 

Requirements for pressure testing 

C. Recordkeeping and Reporting Requirements Comments

• 	 the dates of each pressure test, the test pressure, and the G Yes G No 

pressure drop observed during the test? 

• 	 records of any evidence of fluid loss detected by sight, G Yes G No 

sound, or odor? 

• 	 all of the following information if a process equipment train 

failed two consecutive pressure tests (this information must 

be kept for 2 years): 

< The dates of each pressure test and leak repair attempt? G Yes G No 

< Repair methods applied in each attempt to repair the G Yes G No 

leak? 

< The reason for the delay of repair? G Yes G No 

< The expected date for delivery of the replacement G Yes G No 

equipment? 

< The actual date of delivery of the replacement G Yes G No 

equipment? 

< The date of successful repair? G Yes G No 

2. Does your periodic report include all of the following 

(3)(iii) 

• G Yes G No 

• G Yes G No 

• 

failed either the retest or two consecutive pressure tests? 

G Yes G No 

• G Yes G No 

• G Yes G No 

3. 

status report regarding pressure testing changed, did you 

(3)(iv) 

G Yes G No 

4. Do you keep all records for at least 5 years (except as noted 

above)? 

G Yes G No 

information: §63.1363(h) 

product process equipment train identification? 

the number of pressure tests conducted? 

the number of pressure tests where the equipment train 

explanation for any delay of repair? 

the results of all monitoring to determine compliance with 

the standards for inspection of closed-vent systems? 

When any of the information in your notification of compliance 

include the revised information in your next periodic report? 

§63.1363(h) 

§63.1367(a) 

6-74
 
 
Checklist 12: Requirements for alternative monitoring of batch processes (Option 4) 

Facility Name: 
 ________________________________________________________ 
 

Facility Location:
 ________________________________________________________ 
 

Facility TRI ID #:
 ________________________________________________________ 
 

Inspector:
 ________________________________________________________ 
 

Date:
 ________________________________________________________ 
 

Note: A “yes” response to a question in this checklist means compliance with that requirement, and a “no” 

response means noncompliance with the requirement. If the requirement is not applicable, indicate “N/A” in the 

comments column. Also use checklists 2 through 9 for each type of equipment in the process, except where 

questions in this checklist conflict (e.g., use this checklist for the delay of repair requirements, and there is no first 

attempt at repair requirements under option 4). 

A. Monitoring and Inspection Requirements Comments 

1.	 	 Did you monitor batch equipment for leaks when equipment is 

in organic HAP use or use with an acceptable surrogate or 

detectable gas or vapor in accordance with both of the 

following intervals: §63.178(c)(3) 

•	 within 30 days of process start-up each time the equipment G Yes G No 

is reconfigured for production of a new product? 

•	 at the frequencies specified in §63.178(c)(3)(iii)? G Yes G No 

B. Leak Repair Requirements Comments

1. 	 When you detected a leak, did you repair the leak within no G Yes G No 

more than 15 days after the leak was detected (unless you met 

the delay of repair provisions)? §63.178(c)(4) 

2. If you delayed repair of leaks, did all the following 

• G Yes G No 

• 

been depleted? 

G Yes G No 

• G Yes G No 

C. Comments 

1.	 G Yes G No 

(2)(viii) 

2.	 G Yes G No 

period? (4)(viii) 

circumstances apply: §63.178(d) 

replacement equipment was not available? 

equipment supplies (which were sufficiently stocked) have 

the repair is made no later than 10 days after delivery of the 

replacement equipment? 

 Recordkeeping and Reporting Requirements 

Do your records include a list of equipment added to batch 

processes since the last monitoring period? 

§63.1363(g) 

Do your records include the monitoring date and results for 

equipment added to a batch process since the last monitoring 

§63.1363(g) 

6-75
 
 
Checklist 12: (cont’d)
 
 

Requirements for alternative monitoring of batch processes
 
 

C. Recordkeeping and Reporting Requirements Comments

3.	 Do your records demonstrate the proportion of time during the G Yes G No 
 

calendar year that the equipment is in use for a process or 
 

processes subject to subpart MMM? §63.1363(g)(5)(ii) 
 

Note: Examples of suitable documentation are records of time
 

in use for individual pieces of equipment or average time in use
 

for the process unit.
 

These records are only required for equipment for which you
 

adjust the monitoring frequency.
 

4.	 G Yes G No 
 


 


 

your next periodic report? (3)(iv) 
 

5.	 Do you keep all records for at least 5 years? G Yes G No 

When any of the information in your notification of compliance 

status report regarding processes for which you comply with 

option 4 changed, did you include the revised information in 

§63.1363(h) 

§63.1367(a) 

6-76 
Chapter 7 - Sample calculations 

The specific 

•	 

individual process vents Uncontrolled process vent emissions are used to determine if a 

•	 process has Group 1 or Group 2 process vents. 

flowrate for “large” process
 

vents
 

•	 

•	 

•	 

The 

TABLE 7-1. 

lb/batch

Duration of Total HAP 

Type of discharged per 

process vent event batch chloride lb/yra 

Reactor charging 15 200 gal 0.034 21 
 

displaced 
 

heatup 180 b 0.097 58 

What calculations are required by Subpart MMM? 

Subpart MMM requires a variety of calculations to demonstrate compliance. 

calculations that you must conduct depend on the design and operation of your affected source 

and the compliance options you choose. For example, you may be required to calculate any of 

the following five items: 

Uncontrolled emissions from 

Flow-weighted average 

Controlled emissions at the outlet of condensers that are control devices 

Supplemental gas correction for compliance with outlet concentration limits 

Difference between inlet and outlet concentrations of a substance in cooling water used 

in heat exchange systems 

Examples of these five calculations are provided in this chapter and in cited references. 

calculations of process vent emissions are based on the data for a fictional process provided in 

Table 7-1. These data are not intended to represent any particular process and are not 

necessarily even physically viable. The data were created only for the purpose of illustrating the 

types of calculations that may be required by Subpart MMM. 

 Operational and Emissions Data for a PAI Process 

HAP emissions, 

Amount of gas 

Emission emission event, methanol methylene emissions, 

min/batch 

0.128 lbmole air 

7-1 
 
TABLE 7-1. (cont’d) 

HAP emissions, 

Duration of Amount of gas 

lb/batch 

Total HAP 

Type of 

process vent 

Emission 

event 

emission event, 

min/batch 

discharged per 

batch 

methanol methylene 

chloride 

emissions, 

lb/yra 

Extraction charge 75 1,200 gal 0.19 114 

material from displaced 

reactor 

charge 30 400 gal 0.063 9.9 5,978 

extraction displaced 

solvent 

Holding charging 60 850 gal 0.25 0.19 264 
 

tank for displaced 
 

aqueous 
 

phase 
 

Crystallizer charging 45 700 gal 0.2 9 5,520 
 

for organic displaced 
 

phase 
 

Centrifuge charging 45 700 gal 0.2 9 5,520 
 

for organic displaced 
 

phase 
 

Dryer air drying 180 3,000 scfm 20 180 120,000 

a 

b

 Annual emissions based on 600 batches per year.

 See example 7.4 for the calculation of this value. 

How do I calculate uncontrolled process vent emissions? 

Section 63.1365(c)(2) specifies equations to use to estimate uncontrolled emissions from 7 types 

of emission events. Examples illustrating the use of each of these equations are presented in 

“Methods for Estimating Air Emissions From Chemical Manufacturing Facilities.” This 

document, currently in draft form, is chapter 16 of volume II in the Emission Inventory 

Improvement Program series, and it may be downloaded from EPA’s CHIEF page at: 

www.epa.gov/ttn/chief/eiip/techreport/index.html#review (Look under Volumes and Chapters 

under review). Example calculations for displacement and heatup emission events for the 

process described in Table 7-1 are also presented below. Examples 7.1 and 7.2 calculate vapor 

displacement emissions from charging material to a vessel using Equation 9 to subpart MMM, 

which is written as follows: 

n V

E = R T) × ∑ ( )( P MW ) i i ( )( i =1 

7-2 
 
where: 

E = mass of HAP emitted 
 


V = volume of gas displaced from the vessel 
 


R = ideal gas law constant 
 


Pi

 = partial pressure of the individual HAP 
 


n = number of HAP compounds in the emission stream
 
 

MWi

 = molecular weight of individual HAP in the emission stream
 
 

Section 63.1365(c)(2)(i)(D) in Subpart MMM specifies two alternative procedures for estimating 

emissions from heating the contents of a 

vessel to temperatures less than the 

boiling point. One approach uses the 

procedures and equations described in 

§63.1365(c)(2)(i)(D)(1) and (2) of 

Subpart MMM. The second approach is 

specified in §63.1365(c)(2)(i)(D)(4) and 

uses equations 15 through 17 in 

§63.1365(c)(2)(i)(D)(4) and equation 14 

in §63.1365(c)(2)(i)(D)(1 

Note that equations 14 through 17 in Subpart MMM are 

written for situations where HAP are the only volatile 

equations must include those compounds as well as the HAP. 

use the second approach in such a situation. 

components in the vessel. If other compounds are also 

volatile (e.g., water), then the partial pressure terms in the 

Example 7.3 in this chapter (see page 7-6) illustrates how to 

), which are written as follows: 

⎛
 ⎛ n ⎞ ⎜ ⎜ P ⎟ T − ∑ Pi,1 ⎟

⎞

i =1 ⎟ E =
 MW HAP ×
 ⎜

⎜ Navg 

×
 ln⎜ n ⎟ −
 (nHAP ,2 −
 nHAP ,1 )

⎟

⎟

⎜ ⎜ ⎜

⎝ PT − ∑ Pi ,2 ⎟

⎠
 ⎟ ⎝ i=1 ⎠

V PT ( )( ) ⎛
 1 1 ⎞

N = × ⎜ + ⎟ avg 2R ⎝
 T1 T2 ⎠

n n 

(n 

V
 V 

HAP ,2 −
 nHAP ,1 ) =
 

( )( R T1 R T ) 2 ) 

× ∑ Pi,2 − ( )( ×
 ∑ Pi,1 

i =1 i =1 

n 

∑ {[( ) Pi T1 

+
 ( ) Pi T 2
 ] ×
 MWi }

MWHAP =
 i =1
 


n 
 

∑ [( ) 
 Pi T1 

+
 ( ) Pi T 2 ] i=1 

where: 

MW

E = mass of HAP emitted 
 


HAP = average molecular weight of HAP compounds 
 


N = average gas space molar volume during the heating process avg 

PT = total pressure in the vessel 

7-3 
Pi,1 = partial pressure of individual HAP compounds at T1 

n 

n 

Pi,2 = partial pressure of individual HAP compounds at T2
 
 

HAP,1 = number of moles of total HAP in the vessel headspace at T1
 
 

HAP,2 = number of moles of total HAP in the vessel headspace at T2
 
 

V = volume of free space in the vessel 

R = ideal gas law constant 
 


T1 = initial temperature of the vessel contents, absolute 
 


T2 = final temperature of the vessel contents, absolute 
 


n = number of HAP compounds in the emission stream 

Example 7.1: Displacement emissions (one liquid phase) 

Table 7-1 indicates that 200 gallons of methanol are charged to the reactor. The following data 

and assumptions were used in estimating the methanol emissions from this event: 

•	 Assume 800 gal of water (370 lbmole) and 200 gal of non-HAP organic compounds (20 

lbmole) are added before the 200 gal (40 lbmole) of methanol. Therefore, the methanol 

mole fraction is 0.095 when the charging is complete. 

•	 Temperature of the reactor contents is 25°C. 

•	 Assume vapor space is in equilibrium with the final liquid mixture for the entire time 

methanol is being charged. 

•	 Vapor pressure of methanol at 25°C is 125 mmHg. 

•	 Estimate partial pressure of methanol using Raoult’s law and the final composition of 

material in the reactor as follows: 

Pmethanol = (xmethanol )( Methanol vapor pressure ) 

= ( . )( 0 095 125 mmHg)

= 11 9 . mmHg

•	 Estimate methanol emissions using Equation 9 in Subpart MMM as follows: 

3 (200gal )( ft / 7 48 . . gal )(11 9 mmHg )(32 lb / lbmole ) E = (999 ft 3 ⋅ mmHg / lbmole K ⋅
 
 )(298 K)

= 0 034 . lb / batch

7-4 
Example 7.2: Displacement emissions (two liquid phases) 

Table 7-1 indicates that the reactor output and 400 gal of methylene chloride are charged to the 

extractor. The following data and assumptions are used to estimate the methylene chloride and 

methanol emissions while the methylene chloride is charged: 

•	 Methylene chloride is charged after the material from the reactor has been charged. 

•	 Assume contents of reactor are still at an elevated temperature of 37°C when the 

methylene chloride is added. 

•	 Vapor pressure of methylene chloride at 37°C is 677 mmHg. 

•	 Vapor pressure of methanol at 37°C is 228 mmHg. 

•	 Since methylene chloride forms a separate phase, estimate HAP partial pressures 

assuming equilibrium between the vapor space and each phase separately 

< for the methylene chloride phase, assume no material is extracted while methylene 

chloride is being added so that partial pressure of methylene chloride is the same as the 

pure component vapor pressure. 

< for the water/methanol/other organic compounds phase, assume some of the 

methanol was consumed in the reactor so that the methanol mole fraction is now about 

0.05. Using Raoult’s law, the partial pressure of methanol is estimated to be about 

11.4 mmHg. 

•	 Estimate methylene chloride emissions using Equation 9 in Subpart MMM as follows: 

(400gal )( ft 3 / 7 48 . gal )(677 mmHg)(85lb / lbmole ) E = (999 ft 3 ⋅ mmHg / lbmole ⋅ K)(310 K) 

= 99 . lb / batch 

•	 Estimate methanol emissions using Equation 9 in subpart MMM as follows: 

3 (400gal )( ft / 7 48 . . gal )(11 4 mmHg)(32 lb / lbmole ) E = (999 ft 3 ⋅ mmHg / lbmole ⋅ K)(310 K) 

= 0 063 . lb / batch 

7-5 
Example 7.3: Heatup emissions 

Table 7-1 indicates that the reactor contents are heated after all 

of the raw materials have been added, and heat is applied for 3 

hours. The following additional data and assumptions are used 

to estimate the methanol emissions during this event: 

• The vessel contents are heated from 25°C to 37°C. 

• The reactor headspace is 5,000 gallons. 

• Vapor pressure, mole fraction, and partial pressure data: 

See page 7-3 for equations 14 

through 17 in Subpart MMM. 

Initial conditions at T1 (25°C) Final conditions at T2 (37°C) 

vapor liquid partial vapor liquid partial 

Condensable pressure, mole pressure, pressure, mole pressure, 

component mmHg fractiona mmHgb mmHg fractionc mmHg 

water 24 0.858 20.3 47 0.858 40.3 

methanol 125 0.095 11.9 228 0.095 21.7

a Assume the balance is other organic compounds that have negligible vapor pressure.
 
 b Partial pressures calculated using Raoult’s law.
 
 c Assume the vessel contents reach 37°C before any significant reaction occurs so that the mole 
 


fractions at the initial and final temperatures are equal (the temperature is then maintained at 37°C 
 


until the reaction is complete). 
 


•	 Estimate Navg using equation 16 as follows: 

(5 000 gal )( ft 3 / 7 48 . gal )(760 mmHg) ⎛ 1 1 ⎞

N = ,	 × ⎜ + ⎟ avg ( )(999 ft 3 2
 
 ⋅ mmHg / lbmole ⋅ K) ⎝ 298 K 310 K ⎠

= 1 673 . lbmole

• Estimate (nHAP,2-nHAP,1) using equation 17 as follows: 

(, 5 000 	 gal)( ft . 3 / 7 48 gal) 40 3 mmHg + 21 7 mmHg) 3 (n . HAP ,2 − nHAP ,1 ) = (999 ft ⋅ mmHg / lbmole ⋅ K)(310 K) 

× (. 	 

(, . 5 000 gal)( ft 3 / 7 48 gal) − 20 3 mmHg + 11 9 . mmHg) (999 ft 3 ⋅ mmHg / lbmole ⋅ K)(298 K) 

× (. 

= 0 0617 . lbmole 

7-6 
• 	 Estimate MWHAP using equation 14 as follows: 

(11 9 . +
 21 7. )(32 lb / lbmole 
 )(. + 20 3 +
 40 3 18 . )( lb / lbmole ) MW = HAP 	 (11 9 . +
 21 7 . )(. + 20 3 +
 40 3. ) 

=
 23lb / lbmole 

• 	 Estimate emissions of all condensable compounds using equation 14 (without MWHAP) 

as follows: 

⎛	 ⎛ 760 mmHg −
 (. 20 3 mmHg +
 11 9 . mmHg) ⎞
 ⎞

E =
 ⎜ 1 673 . lbmole ×
 ln ⎜	 ⎟ − 0 0617 lbmole ⎟ ⎝
	 ⎝
 760mmHg −
 (. 40 3 mmHg +
 21 7 . mmHg)⎠
 . ⎠

=
 0 00846 . lbmole condensable components / event 

•	 If all of the condensable compounds were HAP, we could multiply the total lbmoles 

emitted by MWHAP to estimate the total mass of HAP emitted. For this example, 

however, only one condensable component (methanol) is HAP. Therefore, we can use 

the average of the initial and final partial pressures to determine the fraction of the 

emissions that is methanol. The average water partial pressure is 30.3 mmHg, and the 

average methanol partial pressure is 16.8 mmHg. Therefore, 64 percent of the total 

lbmoles emitted is water and 36 percent is methanol. The total mass of methanol 

emitted is then estimated as follows: 

E = (. 0 00846 	 total lbmole )(0 36 . )(32 lb / lbmole ) 

=
 0 097 . lb methanol emitted / batch 

How do I determine if process vents are Group 1 or Group 2? 

According to the definition of “Group 1 process vent” in §63.1361 of Subpart MMM, all of the 

process vents in a process are Group 1 if the sum of the organic HAP emissions from all process 

vents is at least 0.15 Mg/yr (330 lb/yr) and/or the sum of the HCl and Cl2 emissions is at least 

6.8 Mg/yr (15,000 lb/yr). For the example process described by the data in Table 7-1, the 

emission streams from each unit operation are process vents because their HAP concentrations 

are greater than 50 ppmv (see definition of process vent in §63.1361). All of these process vents 

also are Group 1 process vents because the total annual emissions of organic HAP are well above 

0.15 Mg/yr. 

Note: Although the process itself generates no HCl or Cl2, if the methylene chloride 

emissions are controlled using an incinerator, you would need to determine the amount of 

HCl generated by burning the methylene chloride. If that amount (plus any from the 

process itself) exceeds 6.8 Mg/yr, which it would for the dryer emissions in the example 

7-7
 
process, then you would have to meet the control requirements for HCl and Cl2 in §63.1362 

of Subpart MMM. 

How do I calculate the flow-weighted average flowrate for “large” 

process vents? 

At existing sources, process vents that meet certain criteria are subject to more stringent control 

requirements than other process vents (see “What compliance options do I have for my Group 1 

process vents?” on page 3-3). To determine which process vents are subject to the more 

stringent control requirement, Subpart MMM requires you to calculate the flow-weighted 

average flowrate of process vents using equation 1 in §63.1362(b)(2). If this value is less than or 

equal to the flowrate calculated using equation 2 in §63.1362(b)(2), then you must reduce 

organic HAP emissions from the process vent by 98 percent. In practice, the calculation is only 

required for vents with uncontrolled organic HAP emissions that exceed 50,000 lb/yr because the 

flowrate calculated using equation 2 is only realistic (i.e., a positive value) for higher emission 

rates. Equations 1 and 2 are written as follows: 

n 

D FRi ∑ ( )( ) i 

FR = i =1 Eq.1 a n 

∑ Di 

i =1 

FR = 0 02 . × (HL) − 1 000 , Eq. 2

where: 

FRa = flow-weighted average flowrate for the vent, scfm
 
 

Di

 = duration of each emission event, min
 
 

FRi

 = flowrate of each emission event, scfm
 
 

n = number of emission events 

FR = calculated flowrate, scfm 

HL = annual uncontrolled organic HAP emissions, lb/yr, as defined in §63.1361 

For the example process in Table 1, only the dryer vent has uncontrolled organic HAP emissions 

that exceed 50,000 lb/yr. Since there is only one emission event associated with this vent, the 

flow-weighted average flowrate for the vent is simply the actual flowrate out of the dryer, or 

3,000 scfm. The next step is to compare this value to the flowrate calculated using equation 2 as 

follows: 

FR = (. , 0 02)(HL) − 1 000 

= (. , , 0 02)(120 000 lb / yr ) − 1 000 

= 1 400 , scfm 

7-8 
Since the actual flowrate (3,000 scfm) is greater than the value calculated using equation 2, the 

dryer vent is not a “large” vent and is not subject to the 98 percent control requirement. 

The equation 1 calculation would be more complicated if the process vent consists of numerous 

types of emission events. For example, the reactor process vent in Table 7-1 consists of two 

emission events. Similarly, if vents from multiple vessels are connected to a common manifold 

for discharge from a single point, then the collective emission stream is the process vent. For 

example, if the emissions from the extraction vessel and crystallizer in Table 7-1 are combined, 

then the process vent consists of the combined stream. In both of these scenarios for the process 

in Table 7-1 there would be no need to calculate the flow-weighted average flowrates because 

we know the total uncontrolled emissions are less than 50,000 lb/yr. However, the following 

calculation for the reactor vent in Table 7-1 is presented to illustrate the procedure for using 

equation 1: 

n 

D FRi ∑ ( )( ) i 

FR = i =1 

a Di 

(15 min)(1 78 . scfm ) + (180 min)(0 3 . scfm ) = 15min + 180min 

= 0 41 . scfm 

Note: In this calculation, the 200 gallons displaced during charging is equal 26.7 ft3,, or 

an average flowrate of 1.78 scfm over the 15-minute charging period. Also, the 0.128 

lbmole of air displaced as the reactor contents are heated is equal to 50 standard cubic 

feet. For saturated conditions at the final reactor temperature, the partial pressures of 

water and methanol in the reactor are 40.3 mmHg and 21.7 mmHg, respectively. Thus, the 

total amount of displaced gas is 54 standard cubic feet. Over the 180 minutes that the 

reactor is heated, the average discharge rate is about 0.3 scfm. 

How do I calculate controlled emissions out of a condenser? 

Section 63.1365(c)(3)(iii) of Subpart MMM describes procedures and equations to calculate 

controlled emissions at the outlet of a condenser. For example, use equations 29 and 12 in 

Subpart MMM to calculate emissions from a condenser used to control emissions from a heatup 

event. Equations 29 and 12 read as follows: 

n 

∑ Pi 

E = ∆ η ×

i=1 

m × MWHAP Eq. 29 

PT − ∑ Pj 

j=1 

7-9 
V ⎡⎛ Pa1 ⎞
 ⎛
 Pa 2 ⎞ ⎤

∆ η = ⎢⎜ ⎟ − ⎜ ⎟ ⎥ Eq. 12 R ⎣⎝
 T1 ⎠
 ⎝
 T2 ⎠ ⎦
 

where: 

E = mass of HAP emitted 

)0 = moles of noncondensable gas displaced 

PT = pressure in the receiver 

Pi

 = partial pressure of the individual HAP at the receiver temperature 

Pj

 = partial pressure of the individual condensable compounds at the receiver 

temperature
 
 

n = number of HAP compounds in the emission stream
 
 

V = volume of free space in the vessel
 
 

R = ideal gas law constant
 
 

Pa1 = initial noncondensable gas pressure in the vessel
 
 

Pa2 = final noncondensable gas pressure in the vessel
 
 

T1 = initial temperature of vessel contents (absolute)
 
 

T2 = final temperature of vessel contents (absolute) 
 


Example 7.4: Condenser-controlled reactor heatup emissions 

Suppose emissions during heatup of the reactor in Table 7-1 are routed to a condenser that is 

operated at 10°C. The following data and assumptions were used in estimating the controlled 

methanol emissions for this emission event: 

•	 The headspace volume of the reactor is 5,000 gal. 

•	 Example 7.3 presents partial pressures at the initial and final reactor temperatures. Use 

these values in equation 12 to calculate )0 as follows: 

(5,000 gal)( ft 3 / 7 48 . gal ) ∆ η = 999 ft 3 ⋅ mmHg / lbmole ⋅ K
 

×
 

⎡⎛ 760 −
 20 3 . −
 11 9 . mmHg)⎞
 ⎛
 760 −
 40 3 . −
 21 7 . mmHg ⎞ ⎤ ⎢⎜ ⎟ − ⎜ ⎟ ⎥ ⎣⎝
 298K ⎠
 ⎝
 310 K ⎠ ⎦
 

=
 0128 . lbmole air 

•	 The water and methanol vapor pressures at the condenser receiver temperature of 10°C 

are 9 mmHg and 54 mmHg, respectively. 

•	 Assuming the methanol and water are the only components in the receiver and they are 

present in the same ratio as in the reactor during heatup (i.e., 90 percent water and 10 

percent methanol), then water and methanol partial pressures for the receiver are 8.2 

mmHg and 5.4 mmHg, respectively. 

7-10
 
•	 Calculate the methanol emissions using equation 29 as follows (note that since 

methanol is the only HAP, Pi

 and MWHAP simplify to the applicable values for 

methanol): 

5 4.. E = 0128 . ×
	 × 32 760 −
 (8.2 +
 5 4. )

=
 0 03 . lb methanol / batch 

How do I correct concentration measurements to account for 

supplemental gases? 

If you elect to comply with an outlet concentration limit for process vents or storage tanks, you 

may have to adjust the measured concentration to account for dilution caused by combination of 

the affected vent streams with other gas streams 

(i.e., “supplemental gases”) that are not subject	 If you comply with the alternative standard (Option 

4 or 8 in chapter 3), then you have alternatives to to control. See the discussion for options 2, 4, 7, the supplemental gas correction. See “How do I and 8 in the section “How do I show initial monitor to comply with the alternative standard?”

compliance with the process vent requirements?” on page 3-18 for more information.. 

beginning on page 3-8 for the definition of 

“supplemental gases” and the compliance requirements. The specific correction methodology 

depends on whether the control device is a combustion device or a noncombustion device. 

For combustion devices, you must correct the measured concentration to 3 percent oxygen using 

equation 7 in §63.1365(a)(7)(i) to Subpart MMM as follows: 

⎛
 17 9 . ⎞

C =
 C ⎜ ⎟ Eq.7 c m ⎝
 20 9 . −
 %O2d ⎠
 

where: 

Cc = concentration of TOC, total organic HAP, or total HCl and chlorine corrected to 3 

percent oxygen, dry basis, ppmv 

Cm = total; concentration of TOC, total organic HAP, or total HCl and chlorine in the 

vented gas stream, average of samples, dry basis, ppmv 

%O2d = concentration of oxygen measured in vented gas stream, dry basis, percent by 

volume 

7-11
 
For noncombustion devices, correct the measured concentration to account only for the specific 

amount of supplemental gases add using equation 8 in §63.1365(a)(7)(ii) to Subpart MMM as 

follows: 

⎛ V + V ⎞ s a C =
 C ⎜ ⎟ Eq. 8 a m ⎝
 Va ⎠
 

where: 

Ca = corrected outlet TOC, total organic HAP, or total HCl and chlorine concentration, 

dry basis, ppmv 

Cm = actual TOC, total organic HAP, or total HCl and chlorine concentration measured 

at the control device outlet, dry basis, ppmv 

Va = total volumetric flow rate of affected streams vented to the control device 

Vs = total volumetric flow rate of supplemental gases 

Example 7.5: Supplemental gas correction for combustion device 

Suppose that some of the process vents in Table 7-1 are controlled using a thermal incinerator 

and you plan to comply with the 20 ppmv outlet concentration limit (Option 2 in chapter 3). You 

must conduct a performance test to demonstrate compliance with the concentration limit. The 

test is conducted under the absolute peak-case condition, which is determined to be the 

maximum 1-hr loading to the incinerator. Since your system design includes the introduction of 

a small amount of supplemental air under these conditions, you also measure the oxygen content 

of the outlet gas stream at the same time you measure the total organic HAP concentration (as 

specified in §63.1365(a)(7)(i)(C) of Subpart MMM). If you found the average of the measured 

organic HAP concentrations to be 8 ppmv, and the average O2 concentration was 17 percent, 

would you be in compliance with the outlet concentration emission limit? Use equation 7 to 

Subpart MMM as follows: 

⎛ 17 9 . ⎞ Cc


 =
 8 ×
 ⎜

⎝
 20 9 . −
 17⎟

⎠
 

=
 37 ppmv 

Therefore, the process vent would not be in compliance with the 20 ppmv outlet concentration 

limit. 

Example 7.6: Supplemental gas correction for noncombustion device 

Suppose the process vents in example 7.5 were routed to a noncombustion device. The average 

measured outlet concentration from the performance test is 13 ppmv, the average process vent 

flowrate is 2 scfm, and you measure the supplemental gases flow rate to be 0.4 scfm. Correct the 

measured concentration using equation 8 to Subpart MMM as follows: 

7-12
 
2 0 4 . 13 ×
 

⎛ + ⎜

⎝

⎞

⎟

⎠ Ca 
 2 =

= 15 6 . ppmv 

This system would be in compliance with the 20 ppmv outlet concentration limit. 

How do I determine if I have a heat exchange system leak when 

complying with option HE1? 

The section “What are my compliance options for heat exchange systems?” beginning on page 

5-30 indicates that a leak is detected under option HE1 when the exit mean concentration is 

determined to be greater than the entrance mean concentration using a one-sided statistical test at 

the 0.05 level of significance, and the amount by which the exit is greater is at least 1 ppmw or at 

least 10 percent of the entrance concentration, whichever is greater. 

Example 7.7: Checking heat exchange system for leaks 

Suppose you have collected the following HAP concentration data for your heat exchange 

system (note that you must collect at least three sets of samples): 

Entrance concentration, Exit concentration, 

Sample number ppmw ppmw

 1 18 24

 2 23 26

 3 28 28 

Mean 23 26 

Step 1: The first step is to check the arithmetic difference between the entrance and exit means. 

In this example, the difference is 3 ppmw, which exceeds both of the criteria (1 ppmw and 10 

percent of the entrance mean). Therefore, we must proceed to step 2 to determine if there is a 

statistically significant difference between the means. 

Step 2: The second step is to determine if there is a statistical difference between the means at 

the 0.05 level of significance. In this example our null hypothesis is that the two means are 

equal. Since our sample size is small, we have an equal number of entrance and exit samples, 

and we are assuming the population is normally distributed, the statistical procedure to use is the 

T statistic for differences between means: 

7-13
 
( X1 − X 2 ) − do T = and

S (/ 1 n1 ) + (1/ n2 ) p 

ν = n1 + n2 − 2 and 

S1

2 S22 

S 2 (n − 1)( ) + (n − 1)( ) 1 2

p = and

n1 + n2 − 2 

n n ⎞ 2

n∑ Xi − ⎜

⎛

∑ Xi ⎟

⎠

Si 

2 = i =1 ⎝ i =1 

nn ( − 1)

where: 

T = T statistic value
 

X&1
 = mean exit concentration of the sample

&X2


 = mean entrance concentration of the sample 

do = difference between the means for the null hypothesis (zero in this case) 

S = pooled sample standard deviation (square root of the pooled sample variance) p 

S

n1 = number of exit samples
 

n2 = number of entrance samples
 

< = degrees of freedom
 2 = pooled sample variance 

S

p
 

i 

2
 = sample variances (i=1 for exit and i=2 for entrance)
 

Xi

 = individual entrance and exit sample concentrations
 

The entrance sample variance is: 

2 ( )( 2 3 182 + 23 + 282

) − (18 + 23 + 28) 2 = 33 − 1) Sent ( )( 

= 25 

The exit sample variance is: 

2 ( )( 2 3 242 + 26 + 282

) − (24 + 26 + 28) 2 S = exit ( )( 33 − 1) 

= 4 

7-14
 
The pooled sample variance is: 

S 2 (3 1 25 − )( ) + (3 1 4 − )( ) = p 332 + −

= 14 5 . 

The pooled standard deviation is the square root of the pooled sample variance, or 3.80. 

The T statistic is then: 

(26 − 23) − 0

T = . ( . )( / / 3 8 1 3 + 1 3)

05 

= 0 965 . 

In this example, we have 4 degrees of freedom. According to tabulated values of the T statistic, 

for 4 degrees of freedom and a 0.05 level of significance, the critical region is T>2.132. Since 

our calculated T is outside the critical region, we accept the null hypothesis and conclude that the 

exit and entrance means are not statistically different. 

Since the means are not statistically different, the heat exchange system in this example does not 

have a leak under Subpart MMM. 

7-15
 
[This page intentionally left blank.] 
Chapter 8 - Recordkeeping and reporting 

What records must I keep? 

You will need to keep several types of records to 

document compliance with various requirements in the You must retain all records for at least 5 

rule. Most of the records that you will need to keep are years. [§§63.10(b)(1) and 63.1367(a)(1)] 

listed in Table 8-1 (page 8-4). 

In addition to these records, you must also develop both of the following written plans and 

maintain the plans onsite: 

•	 a startup, shutdown, and malfunction plan 

(SSMP) that describes procedures you will You must keep superceded versions of the 

follow during such events and describes SSMP as well as the current version. 

[§§63.1367(a)(3) and 63.6(e)(3)(v)] actions you will take to correct
 
 

malfunctions [§63.1367(a)(3)]
 
 

•	 a plan for inspecting all parts of a closed-vent system, cover, fixed-roof, or enclosure 

that you designate as either unsafe-to-inspect or difficult-to-inspect 

[§§63.1366(h)(6)(ii) and (7)(ii) and 63.1367(f)(1) and (2)] 

If you use a fabric filter to comply with particulate matter emission limits for a bag dump or 

product dryer (see “What compliance options do I have for process vents that emit particulate 

matter?” on page 3-6 for applicability), then you must also develop and maintain the following 

plans: 

•	 an operation and maintenance plan that describes 

proper operation and maintenance procedures for If you are required to develop these the fabric filter and bag leak detector. plans, they must be submitted with your 

precompliance plan (see Table 8-4 on 

•	 a corrective action plan that describes corrective page 8-12 for information to include in 

actions to be taken (and the timing of those your precompliance plan. 

actions) when the particulate matter [§63.1368(e)(6)] 

concentration exceeds the setpoint and activates 

the bag leak detector alarm. 

If you comply with option HE2 for a heat exchange system, you must develop and maintain a 

monitoring plan (see page 5-32 for a description of the information to include in your monitoring 

plan). 

8-1
 
What do I have to report and when? 

You will need to complete several different notifications and reports based on the types of 

emission points at your facility and the compliance options you choose. The term “reports” is 

used in this section to include both notifications and reports. Tables 8-2 and 8-3 (pages 8-10 and 

8-11) show what reports you must submit and when they are due. Table 8-4 (page 8-12) gives 

you details about what should be included in these reports. 

How can I change the date my reports are due? 

Under the General Provisions, §63.10(a)(5), you may request a change in the date you submit 

your reports. You and your EPA Regional Office or State, local, or Tribal agency for air 

pollution control (from now on referred to as “State”) must mutually agree to the change, and the 

change can not affect the frequency that you report. For example, semiannual reports for an 

existing source are required in January and July of each year, beginning in 2005. You may 

request that these dates be changed to some other time frame, such as one that coincides with 

your title V operating permit notifications. This does not change your reporting frequency since 

you are still submitting your semiannual reports twice per year. 

Changes to reporting dates can begin 1 year after the compliance date (that is, reports required 

after 12/23/04 can be changed). Reports due before 12/23/04 can not be changed and must be 

reported by the date shown in Table 8-2. Contact your State for more information. 

Where do I send my reports? 

The General Provisions §63.9(a) and §63.10(a) require you to submit reports to your State or 

your EPA Regional Office or both (dual reporting). Whom you send your reports to depends on 

whether your State has been granted the authority to implement the PAI Production NESHAP. 

You will need to submit reports in one of the following ways: 

•	 to your EPA Regional Office if your State has not been delegated the authority to 

implement and enforce the PAI Production NESHAP 

•	 to you State with a copy to your EPA Regional Office, if your State has been granted 

delegation and we have not waived the dual reporting requirement 

•	 to your State if it has been granted delegation and we have waived the dual reporting 

requirement 

Not all State agencies have been granted delegation. Also, as of this publication, our Region I, 

III, VIII, and X offices have not waived the dual reporting requirement under §63.9 and §63.10. 

8-2
 
 
This means if your facility is in one of the following Regions, you will need to submit your 

reports to your State, local, or Tribal agency and the EPA Regional Office: 

• Region I (CT, ME, MA, NH, RI, VT) 

• Region III (DE, MD, PA, VA, WV, District of Columbia) 

• Region VIII (CO, MT, ND, SD, UT, WY) 

• Region X (AK, ID, WA, OR) 

You will find a list of our Regional Offices and their addresses in Chapter 10. 

You should check with your EPA Regional Office or State for the latest information about 

submitting reports. 

8-3
 
 
TABLE 8-1. Summary of Recordkeeping Requirementsa,b,c 

And for 

For each... To comply with... which... You must keep records of all of the following... 

Facility that is not The applicability determination subject to subpart MMM 

8-4
 
 

Facility that is subject to A schedule or log of operating scenarios updated daily or, at a 

subpart MMM 

operation 

You develop • 

process unit establish the process unit group, and any subsequent 

groups for processes that • are subject to overlapping the process unit group 

• 

with other rules product for the process unit group 

Process at a subject The use as a • 

facility that produces a PAI is not the • fraction of the total production used as a PAI 

(

and has other uses frequently.) 

Dedicated PAI process the applicability construction 

unit PAI process unit 

required by after 11/10/97 §63.1360(b)(2) or 

reconstruction after 9/20/02 

Startup, shutdown, and • 

• • 

specified in the SSMP were followed, or a description of actions taken that are not consistent with the SSMP 

minimum, each time a different operating scenario is put into 

a listing of the PAI and non-PAI process units used to 

additions to or deletions from the list 

the operating time for each process unit used in a 

determination or redetermination of the primary product for 

requirements each determination and redetermination of the primary 

total production 

material that is a PAI primary use Note that these records must be kept semiannually or more 

number of turnovers for each storage tank that is assigned to the 

determination commenced 

commenced 

occurrence and duration of each malfunction of process 

malfunction event operations or of air pollution control equipment 

occurrence and duration of each malfunction of continuous 

monitoring systems 

all information necessary to demonstrate that procedures 
And for 

For each... To comply with... which... 

TABLE 8-1. (cont’d) 

You must keep records of all of the following... 

PAI process • results of initial calculation of uncontrolled and controlled 

organic HAP and HCl/Cl2 emissions from process vents (note 

that these calculations are not required if the conditions in 

§63.1365(b)(11)(iii)(D)(1) or (2) are met) 

• the ongoing number of batches per year for a batch process • the ongoing number of operating hours for a continuous 

process 

• the ongoing number of batches and operating hours for a 

process with both batch operations and continuous operations 

• a description of absolute or hypothetical peak-case operating 

conditions under which performance testing of an APCD for 

batch process vents is conducted 

8-5
 
 

PAI process with Group The daily rolling annual calculation of uncontrolled organic 

2 process vents 

Option 5A, 5B, 

percent reduction or 5C, or 5E outlet concentration standard for storage tanks 

Storage tank for which Option 4 • 

vapor balancing • alternative • 

pressure relief vent 

Storage tank for which Option 1, 2, or 3 • each inspection required by §63.120(a), (b), and (c), as 

you use a floating roof 

in the periodic report, as described in Table 8-3.) 

•

(Option 2) 

HAP emissions 

APCD used to meet a Each period of planned routine maintenance of the APCD 

DOT certifications of vapor tightness of tank trucks and 

you comply with the railcars that deliver material to the storage tank 

the setting of the pressure relief vent on the storage tank 

results of the quarterly leak detection monitoring of the 

applicable. (See “What monitoring must I do for my storage 

to comply with the vessels?” in Chapter 4 for information on the frequency of emission standards inspections. Also note that when defects are detected during 

an inspection, information about the defect must be included 

each seal gap measurement for external floating roofs 
And for 

For each... To comply with... which... 

TABLE 8-1. (cont’d) 

You must keep records of all of the following... 

Wastewater stream • HAP concentrations 

• flowrate 

All options for PV; options 5A, 

standard 5B, 5C, or 5E for 

ST; and options A1, A2, A3, or operating ( see the section “What records must I keep for my 

process vents?” in Chapter 3 and Table 5-5 in Chapter 5 for parameters that must be recorded for certain APCD) See Table 5-5 in Chapter 5 

options 

standard 

See Table 5-5 in Chapter 5 

technique for wastewater suppression 

options 

8-6
 
 

APCD used to comply All maintenance performed on the APCD with an emission 

A4 for WW 

You monitor an parameter 

Each measurement of the APCD operating parameter 

Note: 

Treatment unit used to All treatment comply with a wastewater emission 

Emission suppression All emission 

streams 
8-7
 
 

And for 

For each... To comply with... which... 

TABLE 8-1. (cont’d) 

You must keep records of all of the following... 

CEMS used to comply Option 4 or • calibration checks 

with the alternative option 8 for PV; • maintenance of the CEMS 

standard for process option 5E for ST • all of the following information required by §63.10(c)(1) 

vents and/or storage through (14): tanks < all required CEMS measurements, including data recorded 

during periods of unavoidable CEMS breakdowns and outof-control periods 

< date and time of each period when the CEMS was 

inoperative, except for zero (low-level) and high-level checks 

< date and time of each period when the CEMS was out of 

control (e.g., calibration drift exceeded specification or CEMS failed cylinder gas audit) 

< date, start time, and end time of each period of excess 

emissions and parameter monitoring exceedances, 

including identification of those during periods of startup, 

shutdown, and malfunction. 

< the nature and cause of any malfunction, if known, and any 

corrective actions taken 

< the nature of any repairs or adjustments to a CEMS that 

was inoperative or out of control 

< the total process operating time during the reporting period < all procedures, including calibrations, that are part of your 

quality control program 

Bag leak detector used Option 11 for PV • 

• 

• description of corrective action taken 

fabric filter 

date and time of each bag leak detection alarm 

to monitor particulate brief explanation of the cause of the alarm HAP emissions from a 
8-8
 
 

And for 

For each... To comply with... which... 

TABLE 8-1. (cont’d) 

You must keep records of all of the following... 

Inspection of a closed- All options for a leak was 

vent system, cover, PV; options 5A, detected 

fixed-roof, or enclosure 5B, 5C, or 5E for 

ST; and options A1, A2, A3, A4, and all emission suppression options for WW 

• identification of the leaking equipment 

• instrument identification number and operator name (if the 

leak was detected using Method 21), or an indication that the 

leak was detected by sensory observations 

• date the leak was detected • date of the first attempt to repair the leak • maximum instrument reading measured using Method 21 

after the leak is repaired or determined to be nonrepairable 

• all of the following if the leak is not repaired within 15 days 

after the leak was discovered 

< reason for the delay in repair < name, initials, or other identification of the person who 

decided repair cannot be made without a shutdown 

< expected date of successful repair 

• dates of shutdowns that occur while the equipment is 

unrepaired 

• date of successful repair of the leak 

no leak was • 

discovered • 

All options for • 

fixed-roof, cover, or PV; options 5A, as unsafe- or difficult-to-inspect 

enclosure with 5B, 5C, or 5E for • 

ST; and options inspect 

designate as unsafe- or A1, A2, A3, A4, difficult-to-inspect 

suppression 

date of the inspection 

statement that no leaks were detected 

Closed-vent system, identification of all parts of the equipment that you designate 

explanation of why the equipment is unsafe- or difficult-toequipment that you 

and all emission options for WW 
8-9
 
 

And for 

For each... To comply with... which... 

TABLE 8-1. (cont’d) 

You must keep records of all of the following... 

Closed-vent system or All options for You use a flow • hourly flow indicator records 

vapor collection system PV; options 5A, indicator in the • times and durations of each period when the vent stream is that contains a bypass 5B, 5C, or 5E for bypass line diverted line that could divert a ST; and options • times and durations of each period when the flow indicator 

vent stream away from A1, A2, A3, and was not operating 

an APCD 

You use a seal • 

prevent • diversion broken, the bypass line valve position has changed, or the key 

for a lock-and key type lock has been checked out 

• 

The records as specified in Table 6-2 

A4 for WW 

occurrence of the monthly inspection of the seal or closure 

mechanism to mechanism 

occurrence of each period when the seal mechanism is 

each time a car-seal has been broken 

LDAR program for equipment leaks 

a Note that all records must be retained for at least 5 years. [§63.1367(a)(1)] b The section “What provisions are described in this document?” on page 1-1 indicates that this document does not describe the require

averaging and pollution prevention compliance options. Therefore, the recordkeeping associated with those options is not included in th

c If you have a new affected source, §63.1367(a)(5) requires you to comply with the application for approval of construction or reconstr

of the General Provisions. This requirement is not highlighted in this table because it, like all of the requirements in the General Provis

Chapter 9 of this document. 
TABLE 8-2. Report Due Dates for Existing Affected Sourcesa 

Then submit the report According to this 

If you need to submit a(n) . . . before . . . section of the rule... 

Initial Notification Report 10/23/99 §63.1368(b) 

(120 days after the effective date) 

Application for Approval of As soon as practicable before reconstruction §§63.1368(c) and 

Construction or Reconstruction if 63.5(d) 

reconstructing after 6/23/02 ( 

date) 

6/23/03 §63.1368(e) 

( 

8/25/03 §§63.1368(n) and 

(120 days before the compliance date) 63.1364(a)(2) 

§63.1368(d) 

evaluation, or with the notification of the 

60 days before the test §63.1368(m) 

Test Plan 

5/21/04 §63.1368(f) 

Report (150 days after the compliance date) 

1/17/05 §63.1368(g) and (l) 

11/20/04) 

(240 days after the Notification of 

if you comply with the alternative Compliance Status Report) 

standard and you have excess 

(1)( 

January 17 and July 17 of every year §63.1368(g) and (l) 

Reports (60 days after each 6-month reporting 

period) 

Startup, Shutdown, and Malfunction 

Reports reports 

§63.1368(j) 

reports 

Notification of Process Change §63.1368(h) 

report, except reports are due at least 60 days 

before either of the following: 

• 

• 

is to commence 

effective 

Precompliance Plan 

6 months before the compliance date) 

Compliance Extension Request 

Notification of continuous monitoring At least 60 days before the performance 

system performance evaluation 

performance test 

Notification of Performance Test and 

Notification of Compliance Status 

Initial Semi-annual Periodic Report (include information from 5/21/04 ­

Note: Quarterly reporting is required 

emissions [§63.1368(g) ii)] 

Subsequent Semi-annual Periodic 

Semi-annually – can submit with the periodic §63.1368(i) 

Equipment Leak Reports Semi-annually – submit with the periodic 

Semiannually – submit with the next periodic 

any change in an activity described in the 

precompliance report, or 

any change in status of a control device 

from small to large 

a Note that the first semiannual reporting period begins on the date the notification of compliance status report is 

due. 

8-10
 
TABLE 8-3. Report Due Dates for New Affected Sourcesa 

Then submit the report According to this 

If you need to submit a(n) . . . before . . . section of the rule... 

Initial Notification Report 120 days after initial startup, or with the §63.1368(b) 

application for approval of construction 

or reconstruction 

Application for Approval of Construction As soon as practicable before the §§63.1368(c) and 

or Reconstruction construction or reconstruction is planned 63.5(d) 

§63.1368(e) 

date 

§63.1368(d) 

evaluation is scheduled to begin, or with 

At least 60 days before the test §63.1368(m) 

Plan 

§63.1368(f) 

b 240 days after the notification of §63.1368(g) and (l) 

you comply with the alternative standard 

and you have excess emissions 

(1)( 

Reportsb §63.1368(g) and (l) 

Startup, Shutdown, and Malfunction §63.1368(i) 

Reports 

report is required if you take an action 

that is inconsistent with your SSMP 

§63.1368(j) 

reports 

Notification of Process Change §63.1368(h) 

periodic report, except reports are due at 

• 

• 

to commence 

Precompliance plan At least 6 months before the compliance 

Notification of continuous monitoring At least 60 days before the performance 

system performance evaluation 

the notification of performance test 

Notification of Performance Test and Test 

Notification of Compliance Status Report 150 days after the compliance date 

Initial Semi-annual Periodic Report 

compliance status report is due 

Note: Quarterly reporting is required if 

[§63.1368(g) ii)] 

Subsequent Semi-annual Periodic semiannually–60 days after the end of the 

applicable semiannual reporting period 

Semiannually–can be submitted with the 

periodic reports, except an immediate 

Equipment Leak Reports Semiannually–submit with the periodic 

Semiannually–submit with the next 

least 60 days before scheduled 

implementation of either of the following: 

any change in an activity described in 

the precompliance report, or 

any change in status of a control device 

from small to large 

a Note that Subpart MMM also includes reporting requirements for the emissions averaging option that are not 

described in this document. [§63.1368(k)] 

b Note that the first semiannual reporting period begins on the date the notification of compliance status report is 

due. 

8-11 
8-12
 
 

TABLE 8-4. Reporting Requirements a 

If you are submitting Aca(n) . . . Then submit by . . . And include the following information, as applicable . . . se

Request for Compliance 120 days before the Extension (existing compliance date source) 

Note that you may submit a 

Description of the controls to be installed to comply with Subpart §§MMM 63Compliance schedule, including dates by which each step towards compliance will be achieved, including at a minimum: request after this date if a 

need arose after this date • Date by which contracts for emission control systems or and the need arose due to process changes for emission control will be awarded, or the circumstances beyond your date by which orders will be issued for the purchase of reasonable control component parts to accomplish emission control or process 

changes, 

If you installed BACT or • Date by which on-site construction, installation of emission technology required to meet LAER before June 23, control equipment, or a process change will be initiated, 1999, then you may submit • Date by which on-site construction, installation of emission the request not later than control equipment, or a process change is to be completed, and October 21, 1999 • Date by which final compliance is to be achieved 

Description of interim emission control steps that will be taken during the extension period, including milestones to assure proper operation and maintenance of emission control and process equipment Statement indicating whether you are requesting an extension of other applicable requirements (e.g., performance testing requirements) If you installed BACT or technology to meet LAER, include all information needed to demonstrate to the Administrator’s satisfaction that these controls apply to the HAP that must be controlled under Subpart MMM 
TABLE 8-4. (cont’d) 

If you are submitting Aca(n) . . . Then submit by . . . And include the following information, as applicable . . . seInitial Notification Reportb 120 days after the effective date or 120 days after rule 

applies to your facility 

Your name and address. Address (physical location) of your facility.

§6

Identification of the relevant standard (i.e., 40 CFR part 63, Subpart MMM and your compliance date. Brief description of nature, size, design, and method of operation. Identify each point of emission for each HAP. Statement of whether you are a major or area source. 

8-13
 
 

Application for Before construction or §6

Approval of reconstruction Notification of your intent to construct or reconstruct. Construction or Reconstruction Address (physical location) of your facility. 

Identify the standard you are subject to (i.e., 40 CFR part 63, Subpart MMM). Date that you expect to start construction or reconstruction. Date that you expect to finish construction or reconstruction. Anticipated date of initial startup. 

under (2). 

(3). 

Your name and address. Type and amount of HAP you are emitting or expect to emit. For construction: description of proposed nature, size, design, method of operation and emission controls and other information 

§63.5(d)

For reconstruction: brief description of the facility, parts to be replaced and emission controls and other information under §63.5(d)
TABLE 8-4. (cont’d) 

If you are submitting Aca(n) . . . Then submit by . . . And include the following information, as applicable . . . sePrecompliance Plan 3 months before Requests for approval to use alternative monitoring parameters. §6

compliance data Description of your daily or per batch demonstrations to verify that 

control devices with inlet HAP emissions <1 ton/yr are operating as designed. Data and rationale used to set monitoring parameter levels for conditions other than the peak case. Your pollution prevention demonstration summary. Data and rationale for engineering assessments. Your operation and maintenance plan and corrective action plan for fabric filters that are monitored with bag leak detectors. 

8-14
 
 

Notification of At least 60 days before the §§

performance test and test Your test plan, including all of the following: test plan 

• • • • •

audits that include the opportunity for on-site evaluation by the 

Notification of your intent to conduct a performance test. 

summary of the test program, 

the test schedule, 

data quality objectives (i.e., pretest expectations of precision, 

accuracy, and completeness of data), 

internal quality assurance (QA) program, including at a 

minimum, the activities planned by routine operators and analysts to assess test data precision (e.g., sampling and analysis of replicate samples), and 

 external QA program, including at a minimum, application of 

plans for a test method performance audit during the performance test (i.e., analysis of blind audit samples provided by the Administrator in order to provide a measure of test data bias); the external QA program may also include systems Administrator of instrument calibration, data validation, sample logging, and documentation of quality control data and field maintenance activities. 
TABLE 8-4. (cont’d) 

8-15
 

If you are submitting Ac

se

Notification of 150 days after the Compliance Status Report 

§6

analyses, design evaluations or other calculations used to Operating scenarios; i.e., all of the following for each PAI process unit: 

••••

• description of operating and/or testing conditions for any

control devices

Descriptions of absolute or hypothetical peak-case operating and/or testing conditions for control devices 

a(n) . . . Then submit by . . . And include the following information, as applicable . . . 

compliance date 

Your emission profile (required by §63.1365(b)(11)(iii)) 

Results of applicability determinationsResults of emission profiles, performance tests, engineering demonstrate compliance Anticipated periods of planned routine maintenance for control devices used to comply with Option 5A, B, C, or E for storage tanks Information for processes subject to the equipment leak provisions as described in “What reports must I submit” in Chapter 6. Descriptions of monitor devices, monitoring frequencies, and the values of monitored parameters (and all supporting data and calculations) established during the initial compliance determination. 

identification of each process vent and wastewater POD, 

emission episodes and their durations for each process vent, level of control and control devices, calculations and engineering analyses required to demonstrate

compliance

Identification of emission points subject to overlapping requirements with other rules, and the authority under which you will comply. 
TABLE 8-4. (cont’d) 

8-16
 

If you are submitting Ac

se

Semi-annual PeriodicReports than 60 days after the end 

period 

units. anticipated to be produced for use as a PAI in the 3 years after either June 23, 1999, or startup, whichever is later. 

§§anth

Beginning and ending dates of the reporting period. Brief description of the PAI process units.in Subpart MMM.

Date of the latest CMS audit.

period.

••

•

reporting period into those that are due to startup/shutdown,causes, and other unknown causes.

a(n) . . . Then submit by . . . And include the following information, as applicable . . . 

Semi-annually no later of the 6-month reporting 

Identification of emission points that discharge to exempt RCRA Percentage of total production from a PAI process unit that is Records of the initial process units used to create each PUG. 

Your company name and address. Identification of each HAP that you monitor at your affected source. 

Applicable emission and operating parameter limitations specifiedMonitoring equipment manufacturer(s) and model numbers.Total operating time of your affected source during the reportingSummary of emissions data or operating parameter data (dependingon which you monitor) including all of the following:

total duration of excess emissions during the reporting period, total duration of excess emissions expressed as a percent of the

total operating time during the reporting period,

breakdown of the total duration of excess emissions during the

control equipment problems, process problems, other known
TABLE 8-4. (cont’d) 

8-17
 

If you are submitting Ac

se

•••

assurance/quality control calibrations, other known causes, and other unknown causes. 

Description of any changes to any of the following since the last reporting period: 

• ••

The percentage of the total production in the reporting period used §63.1368(g)(2)(ii): 

•• duration of excursion ••

<

inoperative, except for zero (low-level) and high-level checks, 

a(n) . . . Then submit by . . . And include the following information, as applicable . . . 

CMS performance summary including all of the following: 

total CMS downtime during the reporting period, 

total duration of CMS downtime expressed as a percent of the 

total source operating time during the reporting period, 

breakdown of total CMS downtime during the reporting period 

that is due to monitoring equipment malfunctions, nonmonitoring equipment malfunctions, quality 

CMS processes 

controls 

as a PAI if the primary use of the material is not as a PAI All of the following if the length of time for exceedances, excursions, and/or CEMS downtime exceeded limits specified in 

all monitoring data for the day(s) in question 

operating logs for days when parameter averages are outside 

the levels stated in the notification of compliance status report 

the following information required by §63.10(c)(5) through 

(13) if you use a CEMS: 

date and time of each period when the CEMS was 
TABLE 8-4. (cont’d) 

8-18
 

If you are submitting Ac

se

<

control (e.g., calibration drift exceeded specification or CEMS failed cylinder gas audit, 

<

identification of those during periods of startup, shutdown, 

<

known, and any corrective actions taken, 

<

inoperative or out of control, and 

<

If a bypass line is equipped with a flow indicator, records of all an APCD. changed, or the key to unlock the bypass line valve was checked out. 

••• no excursions • no CEMS were inoperative, out-of-control, repaired, or

adjusted.

a(n) . . . Then submit by . . . And include the following information, as applicable . . . 

date and time of each period when the CEMS was out of date, start time, and end time of each period of excess emissions and parameter monitoring exceedances, including and malfunction, the nature and cause of any malfunction of the monitor, if the nature of any repairs or adjustments to a CEMS that was the total process operating time during the reporting period. 

The information listed in Table 5-7 for wastewater systems and heat exchange systems periods when a vent stream is diverted to the bypass line instead of If you use a seal mechanism to prevent diversion of a vent stream through a bypass line instead of an APCD, records of all periods when the seal mechanism is broken, the bypass valve position has Statements documenting all of the following as applicable: 

no excess emissions no exceedances of a parameter 
TABLE 8-4. (cont’d) 

8-19
 

If you are submitting Ac

se

Malfunction Reports with the periodic reports, 

is required when actions taken differ from procedures described in the SSMP 

using an APCD (Option 5A, 5B, 5C, or 5E): 

•

during the subject reporting period, and

•

APCD during the next reporting period.

equipped with floating roofs, as applicable. Records specified in Table 8-1 for each inspection of a closed-vent detected. Both of the following for each process unit group: 

•

and

•

Updates to the corrective action plan for any bag leak detection

certifying the accuracy of the report. Date of the report. 

§6

Table 8-1 63of the report for which procedures in the SSMP were not followed and indicate exceedances are believed to have occurred 

a(n) . . . Then submit by . . . And include the following information, as applicable . . . 

Startup, Shutdown, and Semi-annually–can submit 

except an immediate report 

Both of the following if you control emissions from storage tanks 

actual periods of planned routine maintenance of the APCDanticipated periods of planned routine maintenance of the

Information specified in §63.122(d) through (f) for storage tanks system, cover, fixed-roof, or enclosure during which a leak was 

records of any process units added to the process unit group,

results of any redetermination of the primary product. 

system required by §63.1366(b)(1)(xi).Name, title, and signature of the responsible official who is

Startup, shutdown, and malfunction records as described in Name, title, and signature of person who is certifying the accuracy Each immediate report must also explain circumstances of the event 

whether any excess emissions and/or parameter monitoring 
TABLE 8-4. (cont’d) 

8-20
 

If you are submitting Aca(n) . . . Then submit by . . . And include the following information, as applicable . . . seEquipment Leak Semi-annually--submit See “What reports must I submit” in Chapter 6. §§Reports with the periodic reports 63Notification of Process With the periodic report, Any of the following information, as applicable: §6

Change except as noted • A brief description of the process change 

in Table 8-2 • A description of any modifications to standard procedures or 

quality assurance procedures 

• Revisions to any of the information reported in the original 

notification of compliance status report 

• Information required by the notification of compliance status 

report for changes involving the addition of processes or equipment 

a Note that Subpart MMM also includes reporting requirements for the emissions averaging option that are not described in this documeb If you have a new affected source that is subject to the special requirements under §63.6(b)(3) or (4), you must notify the Administrat

obligations under those sections by the due date of the initial notification report. 
Chapter 9 - Other requirements and information 

Who administers this regulation? 

Your State or local agency for air pollution control, or your EPA Regional Office, will regulate 

you. If your facility is in Indian Country, and your eligible Tribe or your EPA Regional Office 

will regulate you. You may be regulated by one or more agencies depending on whether they 

have been granted delegation of this rule. 

Definition. An eligible Tribe means “a Tribe that has been 

determined by the EPA to meet criteria for being treated in the 

same manner as a State, pursuant to the regulations 

implementing section 301(d)(2) of the Act.” 

Not all States have been granted delegation, or, if they have been granted delegation, they may 

not have been delegated all portions of the rule. Our EPA Regional Offices may also have 

retained certain rights even after delegation (for example, you may continue to have dual 

reporting requirements as explained in Chapter 8). 

The EPA has not delegated authority to approve any of the following: [§63.1369(c)] 

•	 alternatives to the applicability requirements in §63.1360, standards in §§63.1362 and 

63.1363, and compliance dates in §63.1364 

Note: Where these sections of Subpart MMM reference another subpart, the cited provisions will be 

delegated according to the delegation provisions of the referenced subpart. This includes cited provisions 

that are modified by provisions in Subpart MMM. 

•	 major alternatives to any of the test methods required by Subpart MMM, in accordance 

with §63.7(e)(2)(ii) and (f) 

•	 major alternatives to any of the monitoring 
 


required by Subpart MMM, in accordance with 
 


§63.8(f)	
 


•	 major alternatives to any of the recordkeeping
 

Major alternatives to test methods, 

monitoring, and recordkeeping and 

reporting requirements are defined in 

§63.90. 

and reporting required by Subpart MMM, in accordance with §63.10(f)

 You should check with your EPA Regional Office or State for the latest information. 

9-1 
Do I need a title V permit? 

You will need a title V permit if you are subject to the Pesticide Active Ingredient NESHAP 

since, under title V, you must get a permit if your facility is a major source. The Pesticide 

Active Ingredient NESHAP applies to major sources. 

To determine if your facility is a major source, you will need to calculate your HAP emissions 

from your entire facility, not just your PAI production operations. If you do not have federally 

enforceable limits in a State permit, you must calculate your emissions by determining your 

potential emissions. If you need help determining if your facility is a major source or what your 

potential emissions are, see the definitions in the Operating Permits Rule §70.2, or visit our title 

V policy and guidance page at www.epa.gov/ttn/oarpg/t5main.html. 

How do I change my permit to include this rule? 

If you have already been issued a final title V permit and you have three or more years left on 

your permit, your permitting authority will reopen your permit within 18 months of the 

publication date of the final rule or final amendments. If you have less than three years left on 

your permit, update your permit during your renewal period. If your permit has not been issued 

in final form, update your application or draft permit. 

To summarize, your options are as follows: 

If a new rule is effective1,2 Then . . . 
 


and you have . . . 
 


not been issued a final title V permit update your permit application or draft permit 

less than three years left on your permit update your title V permit during renewal 

three or more years left on your permit your permitting authority will reopen your permit within 18 

months after the publication date of the final rule or final 

amendments 

1 The rules’ effective date is the date the final rule is published in the Federal Register (which is 6/23/99 for this 

rule). 2 This also applies if existing rules are modified and final amendments are published in the Federal Register. 

Title V permitting rules may change after the publication of this document. Keep abreast of any 

changes by checking the Federal Register or visit our title V websites at 

www.epa.gov/ttn/oarpg/t5main.html and www.epa.gov/oar/oaqps/permits/. 

9-2
 
 
What portions of the General Provisions apply? 

The General Provisions were published in the Federal Register on March 16, 1994 (Volume 59, 

page 12408) and apply to all NESHAP, including the Pesticide Active Ingredient NESHAP. 

This means that when you became subject to this rule, you also became subject to the General 

Provisions. Some sections in this rule override the General Provisions. Table 1 to Subpart 

MMM and Table 9-1 in this chapter identify which sections of the General Provisions apply to 

this rule and which do not. 

TABLE 9-1. General Provisions Applicability to Subpart MMM 

Applies to

Reference to Subpart A subpart MMM Comment 
 


§ 63.1(a)(1) Yes Additional terms are defined in § 63.1361 
 

§ 63.1(a)(2) - (3) 
 

§ 63.1(a)(4) Yes Subpart MMM (this table) specifies
 

applicability of each paragraph in subpart A to

subpart MMM 

§ 63.1(a)(5) N/A Reserved 

§ 63.1(a)(6) - (7) 

§ 63.1(a)(8) No 

§ 63.1(a)(9) N/A Reserved 

§ 63.1(a)(10) - (14) Yes 

§ 63.1(b)(1) No § 63.1360 specifies applicability 

§ 63.1(b)(2) - (3) 

§ 63.1(c)(1) Yes 	 Subpart MMM (this table) specifies the

applicability of each paragraph in subpart A to

sources subject to subpart MMM 

§ 63.1(c)(2) No Area sources are not subject to subpart MMM 
 

§ 63.1(c)(3) N/A Reserved 
 

§ 63.1(c)(4) - (5) 
 

§ 63.1(d) N/A 
 

§ 63.1(e) Yes 
 

§ 63.2 Yes 
 

when overlap between subparts A and MMM
 

occurs, subpart MMM takes precedence. 
 

§ 63.3 Yes Other units used in subpart MMM are defined
 

in that subpart 
 

§ 63.4(a)(1) - (3) 
 

Yes 

Yes 

Discusses State programs 

Yes 

Yes 

Reserved 

Additional terms are defined in § 63.1361;

Yes 

9-3
 
TABLE 9-1. (cont’d) 

Applies to

Reference to Subpart A subpart MMM Comment 

§ 63.4(a)(4) N/A	 Reserved 

§ 63.4(a)(5) - (c) 

§ 63.5(a) 

§ 63.5(b)(1) 

§ 63.5(b)(2) 

§ 63.5(b)(3) - (5) 

§ 63.5(b)(6) 

§ 63.5(c) 

§ 63.5(d) - (e) 

§ 63.5(f)(1) 

§ 63.5(f)(2) 

§ 63.6(a) 

§ 63.6(b)(1) - (2) 

§ 63.6(b)(3) - (4) 

§ 63.6(b)(5) 

§ 63.6(b)(6) 

§ 63.6(b)(7) 

§ 63.6(c)(1) - (2) 

§ 63.6(c)(3) - (4) 

§ 63.6(c)(5) 

§ 63.6(d) 

§ 63.6(e) 

§ 63.6(f) 

Yes	 

"stationary source" in §63.5(a)(1) of subpart A

with "affected source" 

N/A Reserved 

No	 

N/A	 

Yes 

Yes	 Except replace "source" in § 63.5(f)(1) of

subpart A with "affected source" 

Yes 

No 

N/A Reserved 

Yes Except replace "source" in

§ 63.6(c)(1)-(2) of subpart A with "affected

source" 

Reserved 

Yes 

N/A 

Yes	 

subpart MMM apply during startup and

shutdown for batch processes; therefore, these

activities would not be covered in the startup, 

Yes	 

subpart MMM also apply during startup and

shutdown for batch processes 

Yes 

Except replace the terms "source" and 

Yes 

Yes 

§ 63.1360(g) specifies requirements for 

determining applicability of added PAI

equipment 

Reserved 

Yes 

§63.1364 specifies compliance dates 

Yes 

Yes 

Yes 

N/A 

Reserved 

Except § 63.1360 specifies that the standards in 

shutdown, and malfunction Plan 

Except § 63.1360 specifies that the standards in 

9-4
 
TABLE 9-1. (cont’d) 

Applies to

Reference to Subpart A subpart MMM Comment 

§ 63.6(g) Yes	 	 An alternative standard has been proposed;

however, affected sources will have the 

opportunity to demonstrate other alternatives to 

the Administrator 

§ 63.6(h) 

§ 63.6(i)(1) 

§ 63.6(i)(2) 

§ 63.6(i)(3) - (14) 

§63.6(i)(15) 

§ 63.6(i)(16) 

§ 63.6(j) 

§ 63.7(a)(1) 

§ 63.7(a)(2)(i) - (vi) 

§ 63.7(a)(2)(vii) - (viii) 

§ 63.7(a)(2)(ix) - (c) 

§ 63.7(d) 

§ 63.7(e)(1) 

§ 63.7(e)(2) 

§ 63.7(e)(3) 

§ 63.7(e)(4) 

§ 63.7(f) 

§ 63.7(g)(1) 

§ 63.7(g)(2) 

§ 63.7(g)(3) 

§ 63.7(h) 

§ 63.8(a)(1) - (2) 

No Subpart MMM does not contain any opacity or 

Yes	 Except replace "source" in

§ 63.6(i)(2)(i) and (ii) of subpart A with

"affected source." 

Yes 

N/A	 

Yes 

Yes 

Yes 

Yes	 

N/A 

Yes 

§ 63.7(d) of subpart A with "affected source" 

Yes 

sources 

Yes 

Yes Except § 63.1365 specifies less than 3 runs for

certain tests 

Yes 

Yes 

Yes	 Except §63.1368(a) specifies that the results of 

N/A	 Reserved 

Yes 

visible emissions standards 

Yes 

Reserved 

§ 63.1368 specifies that test results must be 

submitted in the Notification of Compliance 

Status due 150 days after the compliance date 

Reserved 

Yes 

Except replace "source" in 

§63.1365 contains test methods specific to PAI 

the performance test be submitted with the 

Notification of Compliance Status report 

Yes 

Yes 

9-5 
 

TABLE 9-1. (cont’d)

Reference to Subpart A

Applies to

subpart MMM Comment

9-6

§ 63.8(a)(3) N/A Reserved

§ 63.8(a)(4) Yes

§ 63.8(b)(1) Yes

§ 63.8(b)(2) No §63.1366 specifies CMS requirements

§ 63.8(b)(3) - (c)(3) Yes Except the submittal date of the immediate

startup, shutdown, and malfunction reports for

CMS events shall be 2 days as in

§63.6(e)(3)(iv)

§ 63.8(c)(4) No §63.1366 specifies monitoring frequencies 

§ 63.8(c)(5) - (8) No

§ 63.8(d) - (f)(3) Yes

§ 63.8(f)(4) Yes Except § 63.1368(b) specifies that requests

may also be included in the Precompliance

report

§ 63.8(f)(5) Yes

§ 63.8(f)(6) No Subpart MMM does not require CEM's

§ 63.8(g) No § 63.1366 specifies data reduction procedures

§ 63.9(a) - (d) Yes

§ 63.9(e) No

§63.9(f) No Subpart MMM does not contain opacity and

visible emission standards

§ 63.9(g) No

§ 63.9(h)(1) Yes

§63.9(h)(2)(i) Yes Except § 63.1368(a)(1) specifies additional

information to include in the Notification of

Compliance Status report

§63.9(h)(2)(ii) No § 63.1368 specifies the Notification of

Compliance Status report is to be submitted

within 150 days after the compliance date

§ 63.9(h)(3) Yes

§ 63.9(h)(4) N/A Reserved

§ 63.9(h)(5) - (6) Yes

§ 63.9(i) Yes

§ 63.9(j) No §63.1368(h) specifies procedures for

notification of changes
TABLE 9-1. (cont’d) 

Reference to Subpart A 

Applies to

subpart MMM Comment 

§ 63.10(a) - (b)(1) Yes 

§ 63.10(b)(2) No 

§ 63.10(b)(3) 

§ 63.10(c) Yes 

§ 63.10(d)(1) 

§ 63.10(d)(2) 

§ 63.10(d)(3) No 

§ 63.10(d)(4) Yes 

§ 63.10(d)(5) Yes Except that actions and reporting for batch

processes do not apply during startup and

shutdown 

§ 63.10(e)(1) - (2)(i) 

§63.10(e)(2)(ii) No Subpart MMM does not include opacity 

§63.10(e)(3) Yes 

§ 63.10(e)(4) No 

§ 63.10(f) Yes 

§ 63.11 - § 63.15 Yes 

§63.1367 specifies recordkeeping requirements 

Yes 

Yes 

Yes 

Subpart MMM does not include opacity and

visible emission standards 

Yes 

monitoring requirements 

Subpart MMM does not include opacity 

monitoring requirements 

9-7
 
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Chapter 10 - Getting additional help 

Whom can I ask for help? 

You can go to a lot of places for help, including all of the following: 

C your State, local or Tribal agency for air pollution control 

C

C local, regional, or National Trade Associations 

C your EPA Regional Office 

State and local contacts 

to the STAPPA/ALAPCO website (www.4cleanair.org) The 

standards for toxic air pollutants, ozone, etc.) at the State and local level. 

If you have questions about this rule, you should 

contact your State, local or Tribal agency before 

stringent than Federal requirements. 

your State’s Small Business Assistance Program (SBAP) 

 can change frequently. To get the most current contact information, go 

 and then the membership directory. 

directory will give you the latest contact points for major air programs (that is, emission 

calling the EPA. Their rules may be more 

Many States have a Small Business Assistance Program. If you are a small business and do 

not know who your SBAP is, you can call EPA's Clean Air Technology Center Hotline at (919) 

541-0800 or visit EPA’s SBAP at www.epa.gov/ttn/sbap for help. 

Contact numbers for EPA’s Regional Air Division Offices may also change frequently. To 

obtain the most up-to-date information, you may want to visit your Regional Office’s website. 

Table 10-1 lists each of our Regional Offices, the Air Toxics Division Phone and Address, and

the Regions Internet home page. Make all written inquiries to the attention of “NESHAP (insert

rule name) Contact.” 

10-1
 
 
TABLE 10-1. EPA Regional Air Division Offices 

EPA Regional Office - MACT Implementation Contact Division Information* 

EPA Region States Division Phone and Division Phone /

Covered Address RO Home Page 

Region I	 CT, ME, MA, Office of Ecosystem Protection (OEP) (617) 918-1510 
 

NH, RI & VT 1 Congress Street, Suite 1100 www.epa.gov/region1 Boston, MA 02114-2023 

Region II	 

Rico & Virgin

Islands 

Region III	 

Region IV	 

TN 

Region V	 

MN & OH 

Region VI	 

& TX 

Region VII	 

NE 

Region VIII	 

Region IX	 

& Guam 

Region X	 

OR 

Division of Enforcement and Compliance Assurance

290 Broadway

21st Floor 

Air Protection Division, 3AP111 

1650 Arch Street 

Atlanta Federal Center 

Air and Radiation Division 

77 West Jackson Blvd. 

Division (6EN)

1445 Ross Avenue 

Air, RCRA and Toxics Division 

901 North 5th 

66101 

Environmental Justice (ECEJ)

999 18th Street 

Air Division 

75 Hawthorne Street 

Air and RCRA Compliance Unit 

1200 Sixth Avenue 

(212) 637-3735 

www.epa.gov/region2 

(215) 814-2056 

www.epa.gov/region3 

(404) 562-9077 

www.epa.gov/region4 

(312) 353-2212 

www.epa.gov/region5 

(214) 665-7250/

(214) 665-7220 

www.epa.gov/region6 

(913) 551-7020 

www.epa.gov/region7 

(303) 312-7028/

(303) 312-6294 

www.epa.gov/region8 

(415) 744-1219 

www.epa.gov/region9 

(206) 553-1505 

www.epa.gov/region10 

NJ, NY, Puerto 

DE, MD, PA, 

VA, WV & DC 

AL, FL, GA, KY, 

MS, NC, SC & 

IL, IN, MI, WI, 

AR, LA, NM, OK 

IA, KS, MO & 

CO, MT, ND, 

SD, UT & WY 

AZ, CA, HI, NV, 

American Samoa, 

AK, ID, WA & 

Attention: NESHAP (MACT) Contact 

New York, NY 10007-1866 

Philadelphia, PA 19103-2029 

Air, Pesticides and Toxics Management Division 

61 Forsyth Street 

Atlanta, GA 30303-3104 

Chicago, IL 60604-3507 

Compliance Assurance & Enforcement 

Dallas, TX 75202-2733 

 Street 

Kansas City, KS 

Office of Enforcement, Compliance and 

1 Denver Place, Suite 500 

Denver, CO 80202-2405 

San Francisco, CA 94105 

Seattle, WA 98101 

* Information subject to change without notice. For the latest information, please visit the Regional Office Website. 

10-2
 
 
Can I get more information on the Web? 

You can get a wealth of information on the World Wide Web (WWW). Some of the more 

popular ways to get information on this rule include: 

C	 EPA’s Air Toxics Website (www.epa.gov/ttn/atw) 

You can download copies of preambles, regulations, background information documents, 

policy memos, and other guidance materials here. All rule pages can be found under the

Rules and Implementation page. Pesticide active ingredient can be found under

www.epa.gov/ttn/atw/pest/pestpg.html. 

C	 EPA’s Applicability Determination Index (ADI)

(http://www.epa.gov/compliance/assistance/applicability/index.html)

EPA responds to written inquiries about the broad range of NSPS and NESHAP

regulatory requirements as they pertain to a specific source. These inquiries may 

question whether a regulation applies to a specific source, or may relate to the 

construction, reconstruction, modification, testing, monitoring, recordkeeping or 

reporting requirements contained in the regulation as it applies to a specific source. 

C	 OECA Compliance Assistance Centers (http://www.epa.gov/epahome/business.htm)

You can find information on compliance with federal regulations at this site. There are 

centers for printing, automotive services and repair, agriculture, metal finishing 

industries, the chemical industry, printed wiring board manufacture, transportation, and 

local governments. 

C	 STAPPA/ALAPCO home page (http://www.4cleanair.org)

STAPPA/ALAPCO is the State and Territorial Air Pollution Program Administrators 

(STAPPA) and Local Air pollution Control Officials (ALAPCO) organization.

STAPPA/ALAPCO has members representing each State and local agency for air 

pollution control. 

You can get air pollution information at this site, including a document entitled 

“Communicating Air Quality: A Compendium of Resources.” It lists educational 

materials on air pollution that State and local agencies have created. 

•	 National Service Center for Environmental Publications (NSCEP) home page at 

(http://www.epa.gov/ncepihom) maintains hard and electronic copies of EPA documents. 

Additional copies of this document may be obtained free of charge via this website or 

ordered by phone at 1-800-490-9198. 

•	 MACT Case Studies for Pharmaceuticals Production, PAI Production, and 

Miscellaneous Organic Chemical Manufacturing (EPA 305-B-04-001). This document 

may be downloaded from www.epa.gov or ordered from NSCEP. 

•	 National Environmental Compliance Assistance Clearinghouse

(http://cfpub.epa.gov/clearinghouse/). This website provides quick access to compliance 

assistance tools, contacts, and planned activities from U.S. EPA, its partners, and other 

compliance assistance providers. 

10-3
 
Is there a list of commonly asked questions? 

For a list of questions and answers about the final rule, you will find EPA’s “National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for Pesticide Active Ingredient Production: 

Summary of Public Comments and Responses, May, 1999 (EPA-453/R-98-011) useful. You can 

download the document by going to our ATW Pesticide Active Ingredient page at 

www.epa.gov/ttn/atw/pest/pestpg.html. 

10-4
 
 
Chapter 11 - Supplemental information for State and

local agencies and Tribes 

How many facilities may need to meet emission limits? 

According to information we collected in 1995, we estimated that approximately 78 pesticide 

active ingredient production facilities might be affected by this rule. 

EPA’s “Enabling Document: Source Identification Procedures for 

Sources Subject to Regulations Under Section 112(d) of the Clean Air 

Act as Amended in 1990”, September 20, 1996 (otherwise known as the 

“Cookbook”), can help you identify the steps you can take to locate 

more sources. 

You can download the cookbook by going to 

www.epa.gov/ttn/atw/eparules.html, scroll down until you see “MACT 

Implementation Strategy.” The cookbook is in Appendix G of this 

document. 

Who regulates facilities in Indian Country? 

The Clean Air Act authorizes the Administrator to treat an Indian tribe in the same manner as a 

state for the Clean Air Act if specifically enumerated criteria in 40 CFR 49.3 are met. The EPA 

encourages tribes to develop the capacity to administer section 112(d) programs and to request 

delegation. Where such programs approval does not exist, the EPA Regional Office is the 

regulatory authority. State programs are not applicable in Indian country unless EPA

specifically delegated such authority to a particular state. 

How much HAP emissions will the rule reduce? 

We estimate that full implementation of the rule will reduce HAP emissions by about 2,760 tons 

annually. This represents about a 65 percent reduction from baseline levels prior to 

promulgation of the rule. About 47 percent of the reduction is from process vents, 37 percent is 

from wastewater, and the remainder is from equipment leaks and storage tanks. 

11-1