p.1 

OAR Box 1208 

Prepped by Ollie Stewart 

Document Number: 

120) ll-E-6 

Docket Number: 

A-89-10 

Printed 5/9/2008 10:08:23 AM Sheet 120 of 127 
P.2 

;

 *?,_ 

LAW OPPtCHfl 

PHTUP J. HARTER 

SUITE 404 

2301 M STREET. N.W. 

WASHINGTON. O.C. 20037 

(202) 867-1033 

FAX: (202) 687.1 039 

November 13, 1989 

O R A N D U 

ll-E- 6 

fTISJLIx^ 

To: EPA Negotiated Rulemaking Committee on Fugitive Emissions from Equipment 

Leaks and Interested Parties 

Fr: Philip J. Harter 

Re: Minutes of November 6-7 Meeting; Future Meeting; Miscellaneous Materials 

I enclose the minutes of the November 6-7 meeting that were prepared by Radian 

Corporation. As before, the materials that were distributed at the meeting are attached. I have included the revised organizational protocols. (Note they are not 

marked draft: I hope that we have finally put the matter to rest; but, just in case, 

review them carefully to make sure.) I also include a revised list of committee members and those who should receive all the materials distributed to the Committee. The 

other distribution list is of those who have specifically requested to be kept informed 

of the progress of the negotiations. Finally, I have included a "statement" concerning 

the negotiations. Several parties indicated that they had received calls about the negotiations, and it seemed appropriate to prepare a general statement about what the 

Committee is doing. It is largely based on the Federal Register notice, supplemented to 

describe what happened at the meeting. 

The next meeting will begin at 10:00 on Wednesday, December 6 and will conclude 

by 4:00 on Thursday, December 7; it will be held at the Embassy Square Suites Hotel, 

2000 N Street, NW, Washington. NOTE THE CHANGE IN THE LOCATION 

FROM THAT ANNOUNCED DURING THE LAST MEETING. For those who 

wish it, I have reserved a block of rooms at the hotel; the group rate is $95/night, 

which includes breakfast (I am afraid we are subject to "big city" rates in Washington; 

that appears to be as good as we could get), To take advantage of this, please call the 

hotel directly at 800-424-2999, and identify yourself as being with the "EPA Fugitives" 

within the next two weeks. 

The following meeting will be January 17-18 in Durham. We will once again be 

meeting at the Pickett Suites Hotel, 2515 Meridian, Durham, NC 27713; 919-361-4660. 

As before, a block of rooms has been reserved under the name "EPA Fugitives." 
r

) f 

V **-

November 14, 1989 

STATEMENT CONCEKMNG EPA'S I&EGULATOIRY NEGOTIATION 

ON 

CONTROL OF FUGITIVE EMISSIONS OF VOCS FROM EQUIPMENT LEAKS 

Fugitive emissions of toxic chemicals and volatile organic compounds (VOCs) from equipment 

leaks -- such as valves, pumps, and flanges -- are a significant source of air pollution.. Indeed, by some 

estimates, leaks constitute between one and two thirds of all routine, non-accidental emissions from 

chemical plants. Moreover, because they are released near the ground, their impact is 10-40 times 

greater than equal releases from stacks. 

Current regulations basically require that equipment be inspected quarterly for leaks with a 

portable hydrocarbon detector. If concentrations exceed 10,000 ppm the source is identified as a "leaker," and maintenance is required. This approach is known as leak detection and repair" (LDAR). 

The current LDAR program can reduce uncontrolled emissions by about 60-70 percent. The 

actual frequency rate and the associated emissions vary widely, however, as a function of the original 

design of the process unit, such as the number of valves, pumps, and flanges; the age of the process 

unit; design and construction of each component; quality of maintenance; standard operating procedures 

used by the company; training provided to employees; and motivation to ensure low emissions. No one 

is sure just what combination of factors guarantees low emissions notr how to achieve them through 

enforceable regulations. 

In addition, current regulatory approaches do not provide tbe means for calculating the level of 

emissions. Yet the accurate quantification of fugitive emissions from equipment leaks is becoming a high 

priority. Specific emission levels are necessary for baseline and residual risk assessments for raw regulations, for issuiag permits for new facilities, and for establishing appropriate emissions fees. Further, 

companies must report emisaoas uader The Commuasty Rigfat To Kaow Act." Tfeeae figures were 

widely publicized early this summer and sparked considerable pubEc attention m the level of emissions 

of tones and VOCs. 

Not only does the cunent regulatory approach not achieve accurate estisaates off the actual 
P.4 

emissions, it does not provide incentives or credit to firms for establishing programs and facilities to 

achieve the best control. Nor does the approach ensure emission rates that are readily achievable. 

EPA recently convened a regulatory negotiation to address these shortcomings. Representatives of 

EPA; the chemical, petroleum, rubber, and pharmaceutical industries; environmental organizations; and 

state and local governments are working together on the Committee to develop a consensus on a 

proposed rule that would: 

o Revise the emission factors for fugitive emissions of VOCs from equipment leaks, leading to 

a better quantification of the magnitude of the leaks; 

» Develop a new standard based upon best technology and lowest achievable rates for control 

of toxic fugitive organic emissions from equipment leaks for the source categories of that will 

be the subject of EPA's forthcoming HON (Hazardous Organic National Emission Standards 

for Hazardous Air Pollutants); and 

o Develop a format that could be used to implement a risk based standard for toxic organic 

emissions from equipment leaks. Specific risk limits or goals will not be a subject of the 

negotiations, however. 

Thus far the Committee has reviewed conceptual approaches that would provide incentives for 

good performance and disincentives for poor performance to induce the construction and operation of 

high quality, low leak plants. The discussions have involved monitoring strategies, magimiim allowable 

leak frequencies, what constitutes a leak, the regulatory consequences of various findings during a 

monitoring or following a series of monitorings, ways to phase in a new rule, and a number of factors 

that could be taken into account when developing a standard. The Committee has also begun consideration of a couple of approaches for assessing emissions. 
P.5 

REGULATORY NEGOTIATION MEETING ON FUGITIVE EQUIPMENT LEAKS 

NOVEMBER 7-8, 1989 

PICKETT SUITES HOTEL 

RESEARCH TRIANGLE PARK, N.C. 

DRAFT MEETING MINUTES 

The purpose of these meeting notes is to provide an overview of the 

issues discussed in the regulatory negotiation meetings and to provide an 

informal record of decisions as they pertain to schedules, action items, and 

preliminary committee directions. 

Minutes of Previous Meeting 

- The minutes of the previous meeting of the full committee (September 

27-28, 1989) were discussed. Objections to specific provisions and 

phrasing in the minutes of the previous meeting were raised. The role 

of the minutes in the negotiations and their use by the parties was 

discussed. 

Organizational Protocol 

- The draft organizational protocol (September 29, 1989) was discussed. 

The EPA Office of General Counsel has advised that the language in 

paragraph 3.b. of the Protocol should be amended. This amendment would 

reflect the Agency's intention to use the Committee's Agreement as the 

basis for proposed regulations to the extent that the Agreement is 

consistent with the requirements of the Clean Air Act. 

- The language of paragraph 6.e. of the Protocol, concerning the 

rulemaking record, was discussed. Mr. Ajax recommended that the 

statement in the Protocol that the rulemaking record will include "only 
P.6 

such documents as to which no Committee Member objects to including" be 

amended to state that a document will be accepted if a simple majority 

does not object to its inclusion. 

Resource Protocol 

- Ms. Dalton explained that funds under the Resource Protocol agreement 

are available to Committee Members to hire consultants, pay travel 

expenses, and offset certain other expenses involved in participation 

in the regulatory negotiation. Mr. Harter stated that the Committee 

had adopted a policy of using these funds to offset travel expenses for 

those who are not being paid to attend the Committee meetings. 

- Ms. Dalton pointed out that this pool of funds was not fully funded as 

of this meeting because Congress has not adopted a Federal budget. 

When funds are available, they will be administered by the National 

Institute for Dispute Resolution. Committee Members should work with 

Ms. Dalton when funds are required. Requests for funds for consultants 

should be made at least 30 days in advance of need to accommodate the 

time required to process this request. 

Conceptual Approach to MACT Rule 

- One conceptual regulatory approach for the negotiated equipment leaks 

regulation that was discussed would be based on application of quality 

Q^.VtjU  

control P€ffl^r&fflent5 to reduce the number of leaks in a plant. The 

current requirements include a "skip period" approach. The approach 

that was discussed would allow plants to skip inspections if 

consecutive inspections reveal that the number of Teaks is less than a 

stated standard, but would also couple this reward for good performance 

in controlling leaks with a disincentive for plants that are less 

effective in controlling the number of leaks. Under this proposal, 

plants would be required to inspect more frequently if leaks were 

detected in excess of the standard," «i£b-4he frequency of inspection 
P.7 

44uu_£asj_ng as the number of leaks detected increase. The burden of 

these additional inspections would lead a plant to reduce the number of 

leaking components through controls or replacement. 

Texas Air Control Board (TACB1 Regulation 

- Mr. Montgomery and Ms. Hom e presented a discussion of TACB's current 

approach to controlling fugitive emissions as part of its permit 

program for new and modified sources. The basic provisions of the 

regulation are (1) a leak definition of 500 ppm, (2) a directed 

maintenance requirement, (3) quarterly monitoring, and (4) a 

requirement that all new-and replacement pumps and compressors be 

leakless. New valves are not required to be leakless. 

EPA's "Strawman" Eouipment Leak Regulation 

- Mr. Ajax discussed the "strawman" regulation prepared by EPA. This 

strawman was put forth to help describe EPA's interests and was not 

necessarily an EPA position. This regulation would be applicable to 

pumps, valves, flanges, and agitator seals. Other components would be 

subject to the existing VOC equipment leak NSPS. The program would be 

implemented in three phases. 

In Phase I under the strawman regulation, there would be a leak 

detection and repair program with a leak definition set at a high 

value (e.g., 10,000 ppm) and a performance standard based on a 

percentage of leaking components (e.g., 2 percent). In Phase II, 

the leak definition would be lowered (e.g., 500 ppm) and the 

performance standard raised (e.g., 5 percent). 

The Phase III regulation would then shift to a performance 

standard. Screening results would be used to demonstrate 

compliance. The standard could be based on a rolling average to 

account for variability. 
P.8 

Emission Factors 

- Mr. Ajax and Mr. Hess discussed the use of a statistical model to 

determine emission factors for equipment leaks. This discussion was a 

continuation of the work group meeting held on this subject on October 

24, 1989. One model discussed was based on an assumption of a 

log-normal distribution of non-zero equipment screening values and a 

constant ratio between the standard deviation and the mean values. It 

was pointed out that both assumptions need further verification. 

- Mr. Hess stated that the advantages of using a mathematical model to 

estimate emission factors are that (1) the amount of data needed is 

minimized, (2) it is not necessary to accept as appropriate the 

assumptions for individual plant estimates, (3) estimates from 

dissimilar plants do not have to be combined to create emissions 

estimates, and (4) emission estimates can be extended to other 

components. In addition, estimates based on mathematical models can be 

done quickly and cheaply, and can be done for any performance standard 

to be considered. The disadvantages are that (1) the distributions 

will have to be verified, (2) the model is hard to visualize, (3) use 

of the model may reduce the incentive to compile a comprehensive data 

base, and (4) some important variables may be overlooked. A work group 

was established to address the leak rate definition, the assumptions in 

the model, how to treat zero values, how to treat pegged values, and 

correlation in the data. 

Data Availability 

- The availability of equipment screening and bagging data from various 

sources was discussed. Ms. Fidler, Mr. Bergland, Mr. Kace, Mr. 

Goodhart, and Mr. Dunn reviewed efforts by their associations to obtain 

data from their members. 
P.9 

Summary of Existing Bagging Data 

- Mr. Markwordt presented a summary of existing equipment bagging data, 

including data that were used to develop the existing EPA leak 

rate/screening value correlations, and data that were collected 

subsequent to the development of the correlations. The goal is to 

determine by the next meeting what data will be available and to make 

plans at that time for filling data gaps. 

Batch Processing 

- Mr. Kace stated that plants using batch processes, such pharmaceutical 

plants, present a different situation for regulating equipment leaks 

than bulk chemical plants. First, pharmaceutical plants tend to 

produce smaller quantities of chemicals. Second, the products 

manufactured and the processes used differ during the year. Finally, 

because all parts of a batch plant are not in operation at any given 

time, a performance test would take more time and be more costly than 

at a continuous process. Mr. Kace suggested that monitoring a building 

vent might be used as a substitute method for monitoring leaks from 

individual components that are located within a building. 

Next Meeting 

- The next meeting of the Negotiation Committee was scheduled for 

Washington, D.C. on December 6-7, 1889. Mr. Harter will look into 

hotel and meeting room arrangements and communicate with the 

participants. The meeting will be preceded by a plant trip to be 

arranged by CMA. 
November 13, 1989 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOC FROM EQUIPMENT LEAKS 

ORGANIZATIONAL PROTOCOLS 

1. PARTICIPANTS 

a. Interests Represented. Any interest that would be substantially affected by an EPA rule with respect to the 

control of fugitive emissions of volatile organic compounds (VOCs) from equipment leaks may be a party to the 

negotiations. 

b. Additional Parties. After negotiations have begun, additional parties may join the Committee only with the concurrence of the Committee and if within the number of 

parties permitted under the Committee's charter. 

c. The Negotiating Committee. The Negotiating Committee 

shall be composed of one representative from each organization that is a party to the negotiation. Each party may 

designate a Committee Member and an alternate. 

d. Attendance at Meetings. The Committee Member for each 

party or an alternate must make a good faith effort to 

attend each full negotiating session. The Committee Member may be accompanied by such other individuals as the 

Committee Member believes is appropriate to represent 

his/her interest. Only the Committee Member or the alternate will have the privilege of sitting at the negotiating 

table and of speaking from the floor during the negotiations without Committee approval, except that (1) any 

Committee Member may call upon a technical adviser to 

elaborate on a relevant point, and (2) pursuant to the 

Federal Advisory Committee Act, any person attending the 

meetings of the Committee may address the Committee if 

time permits. 

e. Constituents' Interests. Committee Members are expected 

to represent the concerns and interests of their constituents and to ensure that any agreement developed by 

the Committee is acceptable to the organization which the 

Committee Member represents. 

2. DECISIONMAKING 

a. Consensus. The Committee will operate by consensus, committee decisions will be made only with the concurrence of 
P.11 

all parties represented. 

b. Workgroups. Smaller working groups may be formed to address specific issues and to make recommendations to the 

Committee, working Groups are open to any Committee Member or the member's designee, plus such other individuals 

as the Committee believes would enhance the functioning of 

the Working Groups. Working groups are not authorized to 

make decisions for the Committee as a whole. Their meetings will be held between the full sessions and will be 

scheduled in the same location and time whenever possible. 

All Committee Members will be notified of all working 

group meetings. 

c. Discontinue if unproductive. The Committee may discontinue negotiations at any time if they do not appear productive. 

3. AGREEMENT 

a. Written Statement as Basis for NPRM. The agreement will 

take the form of a written statement that will be signed 

by all Committee Members. EPA will use the written statement as the basis of proposed regulation(s) that will 

apply to sources of emissions that are within the scope of 

the written statement. 

b. Final Rule. So long as it is consistent with the Clean 

Air Act, EPA intends to promulgate a final rule consistent 

with the written statement unless comments submitted in 

response to the Notice of Proposed Rulemaking require 

changes in the proposal. EPA will submit the draft final 

rule to the Committee Members who will have 45 days to 

file comments. 

c. Support for Proposed and Final Rule. The parties other 

than EPA intend to support the proposed and final rule to 

the extent consistent with the written statement. 

FACILITATOR 

A neutral facilitator will work with all the parties to ensure that the process runs smoothly. The facilitator serves 

at the will of the Committee. 

5. MEETINGS 

a. FACA. The negotiations will be conducted under the Federal Advisory Committee Act (FACA). 

b. Open. Meetings. Negotiating sessions will be announced in 

2 
P.12 

the Federal Register prior to the meeting and, consistent 

with FACA requirements, will be open to the public. 

c. Hi-nut®s. The proceedings will not be electronically recorded, but draft minutes of Committee meetings will be 

kept and approved by the Committee. The minutes will be 

made available to the public on request. 

d. Agendas. Meeting agendas will also be developed by consensus. The Committee will determine if information requests are reasonable and relevant. 

e. Impasse. If a deadlock or impasse is declared by any 

party, the facilitator will be available to help the deadlocked parties to try to resolve the impasse. 

f. Caucus. A caucus can be declared at any time. 

6. SAFEGUARDS FOR THE PARTIES 

a. Good Faith. All parties agree to act in good faith in all 

aspects of these negotiations. Specific offers, positions, or statements made during the negotiations may not 

be used by other parties for any purpose outside the nego= 

tiations or as a basis for future litigation. It is the 

intent of the Committee that other attendees of the Committee's meetings also voluntarily comply with this provision in order to support the regulatory negotiation 

process by encouraging the free and open exchange of 

ideas, views, and information prior to achieving consensus. Personal attacks and prejudiced statements will not 

be tolerated. 

b. Right to Withdraw. Any party may withdraw from the negotiations at any time without prejudice. 

c. others' Positions. No party will make public announcements or hold discussions with the press characterizing 

the position of any other party even if that party withdraws from the negotiations. 

d. In.fiQraffifr^fflQo 

(1) All parties agree not to withhold relevant information. If a party believes it cannot or should not 

release such information, it will provide the substance of th© information in some form (such as by 

aggregating data, by deleting non-=relevant confidential information, by providing summaries, or by furnishing it to a neutral consultant to us® or abstract) 

or a general description of it and the reason for not 

providing it directly. Emission data shall b© treated 

as provided by 40 CFR § 2.301 and cannot be considered 
P.13 

confidential. 

(2) Parties will provide information called for by this 

paragraph as much in advance of the meeting at which 

such information is to be used as is reasonably convenient. 

(3) All parties agree not to divulge information shared by 

others in confidence. 

(4) information and data provided to the Committee in 

writing is a matter of a public record. 

(5) Nothing contained in these protocols shall restrict 

EPA's authority pursuant to § 114 of the Clean Air 

Act. 

e. Rulemaking Record. 

(1) Minutes of meetings and any other documents prepared 

or circulated in conjunction with the Negotiation 

shall be placed in a public docket of the negotiations, but shall not be placed in any EPA rulemaking 

docket or considered by EPA as a basis for rulemaking, 

except — 

(a) EPA may submit a list of documents for inclusion 

in a rulemaking docket in support of regulations 

proposed in accordance with the Committee's written statement and may include any such listed 

document in the docket unless more than seven 

Committee members object within thirty days, or 

(b) factual material, data, or aggregations of data 

that is not confidential and that was prepared in 

conjunction with the negotiations and relevant to 

the subject of the negotiations and of the rulemaking. 

(2) This provision does not prevent any party to these 

negotiations from submitting to any EPA rulemaking 

docket any document that such party prepared or otherwise generated for use in this negotiation. But no 

party may make such use of any document prepared or 

generated by any other party for use in this negotiation. 

7. SCHEDULE 

Negotiating sessions will initially be held once each month. 

The first negotiating session will be held September 27-28, 

1989. Unless extended by the Committee, the deadline for 

the negotiations is April 30, 1990. 

4 
P.14 

November 10, 1989 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF-FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

COMMITTEE MEMBERS 

and 

THOSE TO WHOM ALL DISTRIBUTIONS SHOULD BE SENT 

CHEMICALS 

Bruce V. Bowers 302-834-4536 

Standard Chlorine 

P.O. Box 319 

Delaware City, DE 19706 

FAX: 302-834-8191 

David W. Dunn 409-942-3129 

Sterling Chemical Corp. 

P.O. Box 1311 

Texas City, TX 77592 

FAX: 409-942-3448 

Karen Fidler 202-887-1176 

Staff to CMA; send materials for CMA distribution 

Chemical Manufacturers Association 

2501 M Street N.W. 

Washington, DC 20037 

FAX: 202-887-1237 

Thomas A. Kittleman 302-366-4718 

Representing Chemical Manufacturers Association 

E.I. DuPont de Nemours & Co. 

Engineering Department 

Lou vie rs Building 

Newark, DE 19714 

FAX: 
P.15 

ENVIRONMENTAL 

David Doniger 202-783-7800 

Natural Resources Defense Council 

Suite 300 

1350 New York Avenue NW 

Washington. DC 20005 

FAX: 

Allen Hershkowitz 212-727-4466 

Natural Resources Defense Council 

40 W. 20th Street 

New York, New York 10011 

FAX: 212-727-1773 

EPA 

Robert Ajax 919-541-5579 

MD-13 

Environmental Protection Agency 

Research Triangle Park, NC 27711 

FAX: 919-541-5661 

Deborah Dalton 202-382-5495 

PM-223 

Environmental Protection Agency 

401 M Street SW 

Washington, DC 20460 

FAX: 202-382-7883 

Katherine Kaufman 202-475-8950 

Office of Air & Radiation 

ANR-443 

Environmental Protection Agency 

401 M Street SW 

Washington, DC 20460 

FAX: 202-475-9766 

FACILITATOR 

Philip J. Harter 202-887-1033 

Suite 404 

2301 M Street NW 

Washington, DC 20037 

FAX: 202-887-1036 
P.16 

OIL 

Linda Curran 312-420-4889 

Amoco Oil Company 

Warrenville Road & Mill Street 

Naperville. IL 60540 

FAX: 312-420-3698 

Larry Goodheart 415-620-4145 

Representing American Petroleum Institute 

Chevron Corporation 

P.O. Box 1627 

Richmond, CA 94802 

FAX: 415-620-5320 

Ellen Siegler 202-682-8271 

Staff to API; send materials for API distribution 

American Petroleum Institute 

1220 L Street NW 

Washington, DC 20015 

FAX: 

OMB 

Nicolas Garcia 202/395-3084 

Office of Management and Budget 

725 17th Street, N.W. 

NEOB Room 3019 

Washington, D. C. 20503 

FAX 

PHARMACEUTICALS 

Jack Kace 201-235-3774 

Representing the Pharaceutical Manufacturers Association 

Director, Environmental Affairs 

Hoffmann-LaRoche, Inc. 

340 Kingsland Street 

Nutley, NJ 07110 

FAX: 201-235-7606 
P.17 

RUBBER 

Alfred W. Bickum 216-796-1534 

Representing International Inst, of Synthetic Rubber Producers 

Manager, Value Engineering 

Goodyear 

1144 E. Market Street 

Akron, OH 44316 

FAX: 216-796-6459 

STATE/LOCAL GOVERNMENTS 

Gustave Von Bodungen 504-342-9047 

Air Quality Division 

Office of Air Quality and Nuclear Energy 

Department of Environmental Quality 

P.O. Box 44096 

Baton Rouge, LA 70804 

FAX: 504-342-9048 

Anupom Ganguli 818-572-2183 

South Coast Air Quality Management District 

9150 Flair Drive 

El Monte, CA 

FAX: 

Robert V. Majewski 518-457-7688 

NYSDEC 

50 Wolf Road 

Albany, NY 12233-3255 

FAX: 

Les Montgomery 512-451-5711 

Texas Air Control Board 

6330 Highway 290 East 

Austin, TX 78723 

FAX: 512-371-0245 

Harvel Rogers 502-625-6000 

Air Pollution Control District 

Suite 205 

850 Barret Avenue 

Louisville, KY 40204 

FAX: 502-625-5306 
November 13, 1989 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

GENERAL DISTRIBUTION LIST 

William Becker 

Executive Director 

STAPPA/ALAPCO 

Suite 240 

444 N. Capitol .Street NW 

Washington, DC 20001 

Ron Berglund 

Union Carbide 

BOX 8361, 770-320 

So. Charleston, WV 25303 

Daniel Duffey 

Rubber Manufacturers Association 

1400 K Street NW 

Washington, DC 20005 

Stan Edwards 

Energetics, Inc. 

9210 Route 108 

Columbia, MD 21045 

Thomas A. Fee 

National Institute for 

Dispute Resolution 

1901 L Street, N. W. 

Washington, D. C. 20036 

Gerald R. Hill 

Phillips Petroleum Co. 

Bartlesville, OK 74004 

Tim Holden 

Versar Inc. 

6850 Versar Center 

Springfield, VA 22151 

Betsy Lyons 

EPA/GAO 

M-2001 

Waterside Mall 

401 M Street SW 

Washington, DC 20460 
P.19 

Gene Matsumoto 

Johnson Wax Co. 

1525 Howe Street 

Racine, WI 53403 

Aline McKenzie 

Science News 

1719 N Street, N.W. 

Washington, D. C. 20036 

Jeff Nejedly 

Danes & Moore 

7101 Wisconsin Avenue, NW 

Bethesda, MD 20814 

Frank J. Phoenix 

C-E Environmental 

6320 Quadrangle Drive 

Chapel Hill, NC 27514 

John Prokop 

Independent Liquid Terminals Association 

1133 15th Street, N.W. 

Washington, D. C. 20005 

Glenn D. Rives 

Radian Corporation/RTP 

P.O. Box 13000 

Research Triangle Park, NC 27711 

Frank T. Ryan 

Goodyear 

901 15th Street, N.W. 

Washington, D. C. 

Ada Salas 

Hoe Chest Celanese 

50 Meiser Avenue 

Branchburg, NJ 08876 

William Tessmer 

Managing Director 

International Institute of Synthetic Rubber Producers 

Suite 133 

2077 South Gessner 

Houston, TX 77063 

Robert Van Voorhees 

Bryan, Cave, McPheeters & McRoberts 

1015 Fifteenth Street, NW 

Washington, D.C. 20005 

Earl Young 

vice President, Environment and Energy 
P.20 

American Iron and Steel Institute 

Suite 300 

1133 15th Street, N.W. 

Washington, DC 20005 
P.21 

November 14, 1989 

STATEMENT. CONCERNING EPA'S REGULATORY NEGOTIATION 

ON 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

Fugitive emissions of toxic chemicals and volatile organic compounds (VOCs) from equipment 

leaks -- such as valves, pumps, and flanges -- are a significant source of air pollution. Indeed, by some 

estimates, leaks constitute between one and two thirds of all routine, non-accidental emissions from 

chemical plants. Moreover, because they are released near the ground, their impact is 10-40 times 

greater than equal releases from stacks. 

Current regulations basically require that equipment be inspected quarterly for leaks with a 

portable hydrocarbon detector. If concentrations exceed 10,000 ppm the source is identified as a "leaker," and maintenance is required. This approach is known as "leak detection and repair" (LDAR). 

The current LDAR program can reduce uncontrolled emissions by about 60-70 percent. The 

actual frequency rate and the associated emissions vary widely, however, as a function of the original 

design of the process unit, such as the number of valves, pumps, and flanges; the age of the process 

unit; design and construction of each component; quaUty of maintenance; standard operating procedures 

used by the company; training provided to employees; and motivation to ensure low emissions. No one 

is sure just what combination of factors guarantees low emissions notr how to achieve them, through 

enforceable regulations. 

In addition, current regulatory approaches do not provide the means for calculating the level of 

emissions. Yet the accurate quantification of fugitive emissions from equipment leaks is becoming a high 

priority. Specific emission levels are necessary for baseline and residual risk assessments for new regulations, for issuing permits for new facilities, and for establishing appropriate emission fees. Further, 

companies must report emissions under "The Commumty Right To Know Act." These figures were 

widely publicized early this summer and sparked considerable public attention on the level of emissions 

of toxics and VOCs. 

Not only does the current regulatory approach not achieve accurate estimates of the actual 
P.22 

emissions, it does not provide incentives or credit to firms for establishing programs and facilities to 

achieve the best control. Nor does the approach ensure emission rates that are readily achievable. 

EPA recently convened a regulatory negotiation to address these shortcomings. Representatives of 

EPA; the chemical, petroleum, rubber, and pharmaceutical industries; environmental organizations; and 

state and local governments are working together on the Committee to develop a consensus on a 

proposed rule that would: 

o Revise the emission factors for fugitive emissions of VOCs from equipment leaks, leading to 

a better quantification of the magnitude of the leaks; 

» Develop a new standard based upon best technology and lowest achievable rates for control 

of toxic fugitive organic emissions from equipment leaks for the source categories of that will 

be the subject of EPA's forthcoming HON (Hazardous Organic National Emission Standards 

for Hazardous Air Pollutants); and 

o Develop a format that could be used to implement a risk based standard for toxic organic 

emissions from equipment leaks. Specific risk limits or goals will not be a subject of the 

negotiations, however. 

Thus far the Committee has reviewed conceptual approaches that would provide incentives for 

good performance and disincentives for poor performance to induce the construction and operation of 

high quality, low leak plants. The discussions have involved monitoring strategies, maximum allowable 

leak frequencies, what constitutes a leak, the regulatory consequences of various findings during a 

monitoring or following a series of monitorings, ways to phase in a new rule, and a number of factors 

that could be taken into account when developing a standard. The Committee has also begun consideration of a couple of approaches for assessing emissions. 
P.23 

& 

CHEMICAL MANUFACTURERS ASSOCIATION 

November 3, 1989 

TO: Equipment Leaks Regulatory Negotiation Committee 

The Chemical Manufacturers Association (CMA) offers the following 

thoughts on a conceptual regulatory approach for the negotiated 

equipment leaks regulation. Our thoughts are presented in two forms. 

First, we describe a conceptual framework for equipment leak 

regulations that CMA believes will result in sound, effective 

regulations. Second, we present the characteristics that CMA believes 

the negotiated regulation should embody. 

CMA believes it is inappropriate at this time to recommend 

quantitative levels for regulatory parameters such as leak definitions 

and allowable leak frequencies. Instead, we urge the Committee to 

first focus on selection of a regulatory approach. 

CMA looks forward to discussing our enclosed thoughts with you at 

the Committee Meeting on November 6-7. 

2501 M Street. NW. Washington. DC 20037 202-887-1100 Telex 89617 (CMA WSH) 
P.24 

CHEMICAL MANUFACTURERS ASSOCIATION 

CONCEPTUAL FRAMEWORK FOR EQUIPMENT LEAK REGULATIONS 

CMA believes it is constructive for purposes of this regulation to 

view a tight, i.e. low leak, plant as a high quality plant and a high 

leak plant as a low quality plant. The objective of this regulation is 

to get people to build and operate high quality plants. Only new high 

quality plants should be built, and existing low quality operations 

should be modified to improve their quality. As a result, we view this 

as a classical "quality control" problem and believe quality control 

principles should be applied. 

Experience with quality control for products has taught us some 

important lessons. One important lesson is that you can't inspect 

quality into a product. Quality must be built into a product or a 

plant and retained through diligent operation and maintenance. 

Inspection gives you feedback on how good quality is and will 

demonstrate a failure of the quality process. Inspection cannot stop 

the production of #efects. If you are producing a low quality product, 

you will need a lot of inspection to achieve an acceptable defect 

shipment rate. If you are producing a high quality product, the 

inspections are neeessary only to make sure quality doesn't deteriorate. 

In this regulation, our objective should be to prevent leakage 

from occurring, not to plug leaks as they occur. A regulation that 

relies solely on frequent monitoring to control a leaking process will 

allow more leakage than infrequent monitoring of a high quality plant. 

So the problem is, how can we build, operate, and maintain high quality 

processes? The industry is so diverse that any attempt to set 

specifications for equipment or process operating procedures would be 

next to impossible. Therefore, CMA believes it is the task of this 

negotiation to arrive at a regulation based on a format that will lead 

industry to build, operate, and maintain high quality processes. 

There is more than one way that a regulation could be structured 

to lead toward highe>r quality processes. Attached are eight specific 

characteristics the chemical industry believes should be embodied in a 

regulation. CMA believes a future regulation should allow a variety of 

approaches to desonsftrate compliance as the existing regulation now 

does. In fact, thetfe may be advantages to retaining some of the 

concepts in thre existing regulation. 

CMA believes the eight characteristics in the attachment can best 

be incorporated by modifying two of the existing regulatory approaches; 

Skip Period and Work Space Exposure Evaluation. Both are work practice 

approaches that will assure amy selected level of performance. The 

concept of a work practice/performance standard is important to 

industry. 

The Skip Period Approach would require a process to achieve a 

designated performance level, e.g. less than 2% leaking, by adjusting 

the monitoring frequency. The concept was presented to the National 
P.25 

Air Pollution Control Techniques Advisory Committee (NAPCTAC) when the 

existing regulation was being considered. A copy of that presentation 

is attached. In our view, the major drawback with skip period, as it 

exists in the present regulation, is that it provides a carrot, but no 

stick. A plant can perform poorly and still use quarterly Leak 

Detection and Repair (LDAR). Industry could live with a simple LDAR 

rule. Hbwever, that requirement has the the basic drawbacks of 

unpredictability and lack of incentive to retain effective practices. 

In short, the performance quality could actually decrease if more 

effective practices are supplanted by reliance on LDAR only. 

CMA believes the existing skip-period provisions can easily be 

revised to become an efficient performance standard if the rule is 

expanded. In other words, a process that demonstrates good performance 

could still monitor less frequently, but one that does not, would have 

to monitor more frequently, e.g. quarterly to monthly, monthly to 

biweekly, biweekly to weekly. The latter is not required in the 

existing regulations. When process quality improves, monitoring could 

decrease again as good performance is demonstrated. Thus, each process 

would end up monitoring as frequently as necessary to meet the good 

performance level. It would be possible to do less monitoring by 

improving process quality in any way that would work, i.e. specify 

better equipment, do more frequent maintenance, etc. If something 

didn't work, the monitoring requirement wouldn't change. 

The Work Space Exposure Evaluation approach is based on the 

principle that, in some situations, the first impact and the highest 

potential exposures from fugitive emissions will be in the work space. 

If a plant can demonstrate that work space controls will insure process 

quality, maintaining those controls should constitute compliance. (For 

instance, monitoring the air discharge from a building might be as good 

as monitoring the equipment in th© building.) The primary incentive to 

industry is that one set of procedures could be used to demonstrate 

compliance with both worker and public exposure. Within this approach, 

it is conceivable that some other typ® of monitoring would be done 

continuously or more frequently that would be practical for LDAR. An 

equivalency provision is included in the existing regulation, but it is 

so rigid that it is virtually unusable. 

In conclusion, CMA believes this regulation should be structured 

to encourago tho construction, operation, and maintenance of high 

quality, i.a. lc** ? look, processes. W® have suggested two ways to do 

this that would bo supported by the chemical industry. We believe the 

regulatory frasowork should ba identified before quantitative levels 

for regulatory parameters are considered. After we have identified a 

workable regulatory framework, we should then determine the most 

appropriate numbers for leak definition and good performance. 
P.26 

"fT 

CHEMICAL MANUFACTURERS ASSOCIATION 

CHARACTERISTICS FOR NEGOTIATED EQUIPMENT LEAK STANDARDS 

CHARACTERISTIC 1; 

Rationale: 

CHARACimRISiflC 2: 

Rationale: 

CHARACTERISTIC 3: 

Rationale: 

The regulation should provide for predictable 

compliance. 

It is important that affected facilities know with 

certainty that they can design a program that will 

allow them to comply with the regulatory 

requirements. These requirements should be framed 

in such a way that violation because of statistical 

quirks will not occur. For example, CMA would 

prefer not to see violation based on a fixed 

percentage of leaking components not to be exceeded 

on a one-time or rolling average basis. Inability 

to predict compliance with certainty is the primary 

reason facilities historically have not taken 

advantage of similar alternative compliance 

demonstration provisions in existing equipment leak 

regulations. 

The regulation should provide maximum flexibility 

in achieving specified results. 

It is important for affected facilities to have 

flexibility in achieving a specified performance 

level. Corporations and plant facilities approach 

leak reductions in different ways to accommodate 

unique characteristics while still achieving 

equivalent performance levels. For example, 

equipment, design, or operating and maintenance 

practices may provide ways to comply but other 

app-foa*ehes may be equally (or more) effective 

and less costly: In fact, performance at some 

plants may worsen if current practices are 

replaced by a single set of rigid requirements. 

The regulation should retain concepts in the 

existing equipment leak regulations to the extent 

practicable. 

Concept's in the existing regulations such as 

moniitoring components to demonstrate compliance are 

well understood by industry and state and local 

agen*eie"s. Retention of such concepts in future 

regulations will serve to minimize confusion in 

their implementation. For example, regulatory 

requirements that measure compliance by specific 

equipment and design requirements instead of 

monitoring, are less understood and implementation 

is more likely to be problematic. 
CHARACTERISTIC 4: 

Rationale: 

CHARACTERISTIC 5: 

Rationale: 

CHARACTERISTIC 6: 

Rationale: 

CHARACTERISTIC 7: 

Rationale: 

The regulation should achieve predictable, 

quantifiable emission results. 

The current regulatory approach based on leak 

detection and repair (LDAR) does not result in 

quantifiable emission levels. Therefore, plants 

that perform poorly may continue to perform poorly 

as long as. procedural, i.e., LDAR, requirements are 

met. Although CMA acknowledges that LDAR has been 

an acceptable regulatory approach, CMA feels that a 

quantifiable performance standard that ensures 

consistent good performance is a worthy objective. 

The regulations should provide incentives for good 

performance and disincentives for poor performance. 

The current regulatory approach based on LDAR 

provides no incentive for good performance or 

disincentive for poor performance. Incorporating 

such incentives and disincentives are important for 

ensuring that maximum emission reductions are 

achieved and more effective controls are sought. 

The regulation should, after a phase in period, 

provide for immediate corrective action for poor 

performance and reward for good performance. 

Issuing a violation when the good performance 

level is exceeded will not directly or immediately 

insure an emission reduction. This is especially 

true where a plant is unclear about the best way to 

achieve good performance. As a result, issuing 

such violations can result in significant 

expenditures that do not improve performances by 

both the regulated and the regulators. In 

contrast, th® requirement for more intensive 

monitoring is not only a penalty but forces an 

immediate corrective action. Conversely, with 

clear ground rules for reduced monitoring, a plant 

will know what the incentives are for demonstrating 

and continuing good performance. Such a sliding 

scale monitoring requirement directs resources 

toward environmental improvement. 

The regulation should be framed in a way to 

avoid unduly penalizing small facilities. 

Small facilities have fewer numbers of equipment 

components that have the potential to leak. The 

regulation should recognize that the potential for 

significant emissions totals froa such facilities 

are less than for larger facilities. Regulatory 

approaches based on a fixed percentage of leaking 

components affect 

i 
P.28 

small facilities more stringently, in that 

relatively fewer leaking components can exceed the 

pecformance level. 

CHARACTERXSIEIC 8: The regulations should provide incentives for 

designs which reduce the number of components with 

the potential to leak.. 

Rationale: One approach that plants may use to reduce 

equipment leaks is to to incorporate designs with 

fewer components that have the potential to leak. 

The regulation should not only provide incentives 

for plants to incorporate such designs, but also 

guard against disincentives. For example, a 

performance standard based on % of components 

leaking actually becomes more stringent as the 

numfeer of potentially leaking components are 

reduced. 
P.29 

E. I. du Pont de Nemours & Co. 

Statement on 

STATISTICAL INSPECTION PLANS FOR MONITORING 

FUGITIVE EMISSIONS FROM LEAKING VALVES. 

Prepared By 

R. D. Snee and T. A. Kittleman 

Engineering Departnent 

for 

Presentation to 

National Air Pollution Control Techniques Advisory Conunittee 

April 16-17, 1980 

Hilton Hotel, Raleigh, NC 
P.30 

|| KfRI ...l. I|JI 

STATISTICAL INSPECTION PLANS FOR MONITORING 

ru<yTIVE EMISSION S FROM LEAKIN G VALVE S 

1 . Int rod-jet ion 

The NAPCTA C is reviewing fugitive emission s monitorin g 

proposal s for benzene and general volatile organic compounds . 

Althoug h the logic of the comment s we wish to make today 

applie s to both monitorin g plans , our presentatio n addresse s 

t he requirement s for general volatile organic compounds . 

EPA's proposal would require that all valves, pumps , compressors , etc . be checked on a regular basis (i.e. monthly or 

quarterly) . While regular check s on some units is certainly 

appropriate , it seenvs that requiring 100?o inspection of all 

units at each screenin g period is overly conservativ e and 

unnecessaril y costly particularl y when it can be shown that 

the leak frequency of some units is very low. It is reasonable to ask, therefore , whether data on unit performanc e and 

statistica l sampling procedure s can be used to reduce the 

costs of screenin g for leaking units and still provide an 

adequat e margi n of protection . 

Our comment s are aime-d at two aspect s of the sampling 

requirement : 1) The base sampling period and 2) The 

desirabilit y of incorporatin g statistica l sampling plans 

to achieve a high degree of protectio n while minimizin g 

costs . Our following discussio n illustrate s an inspection 

plan for valves . The plan is general , however , and work s 

equally well for pumps , compressors , etc . 
P.31 

2. Base Sampling Period 

We believ e the proposed monthl y sampling requiremen t is 

encessiv e and questio n whether the environmenta l benefit s 

c an justif y the high relativ e cost s of a monthly , as opposed 

to a quarterly sampling frequency . Du Pont has reported 

cost s of S3 to ti per sample . In vinyl acetate produc -

tion at our La Porte Plant an EPA contracto r recently 

sampled 1232 valves . This sample by 10 means covere d the 

entir e plant . For instance , units associate d with this 

product , such as refining , and "inaccessible " valves were 

not sampled . Nonetheless , at S3 per sample , a monthly 

samplin g requirement as opposed to a quarterly one, would 

add about S30M annuall y to the cost to sample only these 

valves . We questio n whether these costs could justify what 

we beleiv e would be a small emissio n reduction . Unfo.r t unat el > 

emissio n rate da^a are not yet available from this sampling 

program , let alone one comparin g the effect s of monthly 

v ersu s «qua r t er 1 y sampling . However , the data that are 

availabl e do clearl y show that the percentag e of leakers is 

much less than reported for petroleu m refineries . 

3. Skip-Perio d Inspectio n Plan s 

There are statistica l inspectio n plans which work for any 

base period and provid e adequat e protectio n against leaks 

b ut minimiz e cost by allowin g reduced inspectio n when good 

J 
P.32 

- 3 -

performance is present. We believe the Skip-Period Inspection 

Plans have merit for this purpose . These plans assume that 

a populationr of N valves will be monitored on a periodic 

basis (i.e. monthly or quarterly) . The plans call for all \ 

valves to be inspected in a given period. If acceptable 

performance is found in ± successive periods then one or 

more periods may be skipped depending on the desired level 

of protection . This approach rewards the plant for good 

performanc e (i.e. few leaks) and forces the plant to increase 

the level of inspection when an unacceptable number of leaks 

are found. It also insures that all valves are inspected 

perlodically . 

The Skip-Period Inspection Plan is based on skip-lot inspection plans which have been used in the quality control field 

for more than 25 years (Dodge 1955) . The single-level plan 

h as four basic steps : 

1. Inspect a group of N valves of a particular class or 

type for ^ successive periods . 

2. If performance is aceptable , inspect the group of N 

valves in only £ fraction of the following periods . 

3. Return to inspection of all valves in all periods when 

unacceptable performanc e is found. 

4. Fix all leaks found. 
P.33 

The values of i and f are selected to give the desired level 

of protection . Several alternative plans'are given in Table 1 

For illustrative purposes we will consider the plen with is2 

and f=1/2. This plan states that if acceptable performance 

is found in 2 successive periods , then the population of 

valves can be inspected in every second period (i.e. inspect 

in periods 2, 4, 6, ...) . Of course, as soon as unacceptable 

performanc e is found the plan requires that inspection be 

done in all periods until acceptable performance has been 

found once more in 2 successive periods . If this plan is 

used, on the average, the population of valves will have 

acceptabl e performance at least 9 0?; of the time. 

It is important to.recogniz e that there are other skip-period 

inspection plans which provide the same level of protection 

and use the presence of good performanc e to reduce the 

amount of inspection . In particular we recommend tne 

Multi-Level Inspection plans developed by Lieberman and 

Solomon (1955 ) and ® related set of plans described in 

Department of Defens e Handbook H=106 (also see lreson and 

Biedenbende r 1958) . The9e plans switch back and forth 

2 3 

between different levels of inspection (ie, f, f , f ,...) 

depending on the performanc e of the valves. The single-level 

skip-perio d plan (Table 1) uses only one level of inspection 

(ie, f) and returns to inspection in all periods if poor 

performanc e is found in ony period . The single level pl©n 
P.34 

p |iipiipn*ii «1'i» 

- 5 -

is illustrated here because of its simplicity. We feel, 

however , that any plan which gives an equivalent level of 

protect ion. should <b»e acceptable. 

Both the single-le*vel and multi-level inspection plans place 

• lower limit on the average percent of the time that the 

population of valves will have acceptable performance . The 

protection level is high because all leaks are fixed when 

detected and, when performance is poor, all valves are 

inspected in all periods . 

4. Definition of good Performance 

The skip-period inspection plan will work with any definition 

of "good performanee" . A maximum fraction of valves leaking 

and/or a maximum number of leaks per plant could define good 

performance . We stab mit that a group of valves is performing 

well if less tfcan !?• of them are leaking. According to the 

plan discussed earlier (1:2 , fs1/2) a group of N values 

would be inspected every second period if not more than 2% 

of the valves were leaking in two successive period. 

(Figure 1 shows how this particular plan would operate. ) 

Under this plan, on the average, the population of valves 

would have 2%, or fewer, leaks at least 90?; of the time. 

Skip-period plans c*n also be used in situations where good 

performanc e is defin-ed a-s a maximum number of leaks, MAXL, 

(KMAXLjOl. If the ic2, fsl/2 plan were used, then, on the 

average , the populatio n of N valves would have MAXL, or 

fewer, leaks at leaat 90 % of the time. 
P.35 

- 6 -

5. Group Definition and Protection Level 

As inspection data are collected it will become (apparent 

that the leak frequency will vary with the different types 

of valves . It is cexta.inly appropriate to group the valves 

into different categories according to leak, frequency (e.g. 

leak frequently, leak sometimes, rarely leak) . It is also 

possible to have different inspection plans for the different 

groups . In the end, the objective is to focus the. inspection 

effort where the leaks occur most often. 

It is also appropriate to vary the protection level depending 

on the effects of the leaking chemical . Certainly hazardous 

chemicals may require a higher protection level than chemicals 

which are relatively nontoxic . Plans can also be developed 

for protection levels other than 90 percent (Sheesley 1973) . 

6. Assumptlons 

The skip-period plan assumes, as does any inspection plan, 

that if a valve is not a leaker it will not leak for the 

entire period. It is also assumed that the leak frequencies 

of the different periods are independent of each other. 

This assumption may not be appropriate ; however, major leaks 

will carry over and be detected in the next period. 
P.36 

- 7 -

References 

Dodge, H. f.. (1955) , "Skip-Lot sampling plan", Industrial 

Quality, Control, 11 , No. 5, 3-5. 

Ireson, W. G. and Siendenhender, R. E. (1958), "Review of 

Department of Defense Handbook H-106, 'Multiple-level 

continuous sampling procedures'", Indust rial Qual ity 

Control , jj>, No. 4, 10-15. 

Leiberman, G. 0. arwj Solomon, H. (1955) , "Multi-level 

continuous sampling plans", Annals of Mathematical 

Statistics,. Ji , 616-704 . 

"Multi-level continuous sampling procedures and tables of 

inspection by attributes", Inspection and Quality 

Control HaffHjb.60 j ( I nteri m) H-106, October 1958, Office 

of the Assistant Secretary of Defense (Supply and 

Logistics) , Washington, D.C. 

Sheesley, j*. H. (1975) , "A computer program to evaluate 

Dodge's continuoms sampling plans", Journal of Quality 

Technology , 7,, 4 3 <*- 4 5 . 

R. D. Snee 

4/10/80 
P.37 
lfl* 'P'i :-al ''ff-"11 ' '-

P.38 

TABLE 1 

ALTIiNATa^E SKIP-PERIOD INSPECTION PLANS -

# Successive 

Periods Ingpxejfted 

fraction of 

Pgr^ods Inspected 

Lower Limit On 

Percent of Time With 

Acceptable Performance 

2 

4 

5 

6 

12 

1/2 

1/3 

1/4 

1/5 

1 /14 

90 

90 

90 

90 

90 
P.39 

Model Approach to Estimating Emissions 

Details of th© model simulation presented at the October 24, 1989 

technical meeting are attached. This approach estimates emissions 

for valves. Extensions to the model which were not discussed in 

the meeting are also suggested*. A basic understanding of what is 

being attempted here (an understanding at the level reached during 

the 10/24/89 technical meeting) is assumed. 

Details are given for one leak rate definition (10,000 ppm) and 

one phase (liquid). Similar analysis was done for other leak rate 

definitions and for gas. 

The steps followed for the simulation are given in Table 1 with the 

following subsections: 

* Preliminary Work 

* Midrange Estimates 

*"* Zero and Pegged Estimates 

* Combining Estimates 

*** Extensions of Model 

Data sets used for each step are listed in Table 2. Equations used 

are given in Table 3. Extensions to the model are given in Table 4, 

Assumptions made are given in Table 5. 
Table 1 

PROCEDURE FOR ESTIMATING TOTAL EMISSIONS 

PRELIMINARY WORK 

Calculate the mean, standard deviation (std) and cv 

(std/raean^lOO) for actual screening values from data set 1. 

Check whether the cv is constant for all data sets. 

Test the lognormal assumption for each data set. 

In general, the definition for lognormal is as follows: 

X is distributed as lognormal(mu,sigma) if and only if 

ln(X) is distributed as normal(mu,sigma). Mu and sigma 

refer to the mean and standard deviation of ln(x). 

Estimated sigma for the lognormal distribution with the cv 

calculated above using the following relationship: 

mean(X) >=> ©,:'

6(mu<-sigaa<:''s2/2) 

variance(X) <=> (e^M 2au<-sig®a<"<:*2) )*(Q***( sigma*"^)-!) 

from this it can be derived that 

sigma «*> sqrt( ln( (cv/100)ft*2+l)) 

Using sigma, the leak rate definition, and percent leaks, mu can 

be found iteratively. Find au such that; 

Pr(x > leak rate |mu,sigaa) <**> fc leaks 

Try any au and adjust up or down as needed to obtain the correct 

% leaks. (Trial and error was used, a aore sophisticated method 

could be used.) 

MIDRANGE 

Given mu and sigma found above, four sets of 1000 screening 

values each were readonly generated froa the lognormal distribution 

for each % leaks. This gave twelve simulations for a leak rate 

definition. 

Using the IFA correlations, eaissions were estimated for each of 

the simulated screening values. 

The average emissiono were calculated for each of the 12 

siaulations for a given leak rate definition. 

Saoothing was done to get one estimate for each percent leaks of 

interest by regressing average emissions on % leaks for the 12 

data points. Each equation was then used to estimate emissions 

for that leak rate/percent leaks combination. 
P.41 

ZEROS AND PEGGED 

Using data set 1, the percent zeros, percent pegged, and percent 

leaking were calculated. Using these 5 data points, regression 

was used to estimate the linear relationship between percent 

leaks and percent zeros and the linear relationship between 

percent leaks and percent pegged. (See Figures 1 and 2 for 

examples.) 

Using data sets 2 and 3, the emissions from zeros and pegged 

valves were estimated. (Note that the separate estimates for 

gas and liquid were not made for pegged valves. The estimate 

applied to both.) 

Using the relationship between fc zeros and fc leaks, the percent 

of zero valves was estimated. Similarly, the fc pegged was 

estimated. 

For zeros, the default value was also calculated by using a 

screening value of 8 in the EPA correlations. 

COMBINING ESTIMATES 

Total eaissions were estimated using equation 2 for both the 

default leak rate for zeros and the leak rate estimated using 

bagging data 
P.42 

Table 2 

Data Sets and Definitions used for Emissions Estimates 

Data sets 

Only valve data were used for estimates 

Data Set 1 - Data used to estimate distribution values 

for simulation and to estimate the relationship 

between fc leaks and both fcpegged and fczeros 

DuPont Data (5 sets) 

Data Set 2 - Data to estimate leak rate for zeros 

Acrolein data 

Alabama Study data 

Butadiene data 

Ethylene Oxide data 

Vista Study data 

Maintenance Study Data 

Data Set 3 - Data to estimate leak rate for pegs 

Maintenance Study Data 

Definitions 

Zero - Less than the limit of detection 

Default Zero Leak Rate - Use screening value of 8 in EPA equations 

Peg - Screening value greater than 100,000 

. 
P.43 

Table 3 

Equations used for Emissions Estimates 

1) EPA Equations for estimating leak rate from screening value 

Gas Emissions -*** 3 . 766M IO** ( -5. 35+0 . 693'!'log( SV) ) ) 

Liquid Emissions -**> 8.218*(10**(-4.34+0.470*log(SV))) 

2) Total Emissions ° 

(

fc zeros fc pegged fc aid-range \ 

<*EF(zero) + *EF( pegged) + *EF(aid-range) 

100 100 100 y 

3) Adjusted Emissions ° (Emissions at inspection + Base emissions)/2 

1 / 

o - *> I Total Eaissions froa Table 2 + 2

 V 

fczero (fcaidrange-fcleaks) 

& EF(zero) + * EF(nonleakers) 

100 100 

1000 « :— 

(fcsero + fcaidrange - fcleaks) 

TMl 
P.44 

Table 4 

Possible Extensions of the Model 

Not' Introduced at the October 24, 1989 meeting 

Total emissions were adjusted to allow for repairs 

assuming that after screening, leaks are repaired and 

then leak at the average rate of nonleakers. Equation 3 

was used for this calculation. 

Assuming the model plant splits from Table 3-5 in the 

AID study total emissions from valves and from all, 

sources were estimated by finding the proportion of 

emissions due to valves and the proportion of valves to 

other sources, then adjusting the amount of eaissions 

according to the proportions found. 

J 
P.45 

Table 5 

Assumptions for Emissions Estimates 

1. Screening values are distributed lognormally 

2. The simulation used the same shape distribution for liquid 

and gas screening values. Separate EFA equations were used 

for liquid and gas valves. 

3. Different chemicals leak at the saae rate. Data were coabined 

regardless of the cheaical being screened. 

4. Data were coabined regardless of the screening or bagging 

method used to gather it. 

5. Pegged screening values have the saae leak rate for gas and 

liquid. 

6. After screening, leaks are r 

rate of nonleakers. 

Emission 

Rate 

paired and then leak at the average 

At Screening 

Tabled Value 

Base 

I ' 2" 

Inspection Period 

Base <*** Average of nonleakers 
Figure 1 

Regression of Percent Pegged on Percent Leaking 

r 

c 

e 

n 

t 

P 

e 

e 

d 

2.40 

1.60 

0.80 

0.0 

x 

0.00 t x x 

-. 

"ef, 

X 

X 

2.0 4.0 6.0 8.0 

percent leaks 

10.0 
p 

e 

r 

c 

e 

n 

t 

z 

e 

r 

o 

s 

x 

90 

75 

60 -• 

<^ 

Figure 2 

Regression of Percent Zeros on Percent Leaking 

x 

x 

x 

0.0 2.0 0 6.0 

percent leaks 

8.0 10.0 
P.48 

Advantages and Disadvantages of Model Approach to 

Estimating Emissions 

Advantages 

* Minimize amount of data needed 

* Data can be used more efficiently to validate assumptions 

rather than to generate plant estimates. 

* Emission rate curves can be generated without the need for 

many plant estimates 

* Data collection can be directed to areas where inforaation 

is most needed 

* It is not necessary to accept as appropriate assumptions that went 

into different plant estimates 

* Unifora assuaptions can be aade across all plants 

* Individual assuaptions for a plant estiaate can be broken down 

and considered independently in light of data from all plants 

* Data froa all plants can be coabined to coae up with the 

best assuaptions 

ft Sensitivity to various assuaptions can be tested. 

* Eaissions estimates froa dissimilar plants do not have to be combined 

to create eaissions estiaate curves. 

<"* Extensions to other coaponents 

*** Provides an efficient framework for estimating eaissions from 

other component types 

* May be able to fill in where there are few data for other 

coaponents 

* Siaulation can be done quickly and cheaply 

* Siaulation can be done for any performance standard to be considered 

Disadvantages 

**- A uniform cv and a lognormal distribution will need to be verified 

* Harder to visualize 

* May reduce incentive to compile more complete data base 

* As with any "canned" approach, some important variable may b© 

overlooked 
P.49 

/)4M4**s >it"t*%__» 

% 

EXAS AIR CONTROL BOAR 

6330 HWY. 290 EAST, AUSTIN, TEXAS 78723, 512/451-5717 D 4 Ki 

2.£crp*>/) 

DICK WHrnTNGTON, PE. 

CHAIRMAN 

BOB G.BAILEY 

VICE CHAIRMAN 

ALLEN ELI BELL 

EXECUTIVE DIRECTOR 

October 10, 1989 

E C E I V E D. 

OCTil I^S 

JOHN L. BLAIR 

MARCUS M. KEY, M.D. 

OTTO R. KUNZE. PhJ3., PE. 

HUBERT OXFORD, HI 

WILUAM H. QUORTRUP 

C H . RIVERS 

MARY ANNE WYATT 

M'MMMIMIT PROGRAM 

To: Members of the Negotiating Committee for Control of 

Fugitive Emissions of VOC from Equipment Leaks 

This is in response to Mr. Bob Ajax's request at the September Committee meeting that Committee members provide an 

outline of proposed elements which would make up an "ideal" 

fugitive emissions regulation. In addition, he requested 

that I provide information on the Texas Air Control Board's 

current approach to controlling fugitive emissions as part 

of its permit program for new and modified sources. 

Attachments I through TV are designed to convey some insight into the control of fugitive emissions through the 

agency's permit program. Attachment I consists of a brief 

description of the agency's approach along with copies of 

the most recent versions of standard "General Provisions" 

that are included in appropriate permits. Attachment II 

consists of a handout used in conjunction with our Permits 

Workshops. Attachment III provides some insight into our 

experience in implementing General Provision 28MID, which 

represents the most stringent level of control currently 

being implemented by the agency, by providing information 

on permits for new and modified process units which included the provision. The list is designed to be representative of our experience, but may not be comprehensive 

in that it is based on a survey of individual permit engineers rather than a comprehensive review of all our 

files. Attachment IV outlines our approach in dealing with 

fugitive emissions from relief valves. 

with regard to the design of an "ideal" fugitive emission 

regulation. General Provision 28MID probably best reflects 

our understanding of a fruitful direction to head. We 

believe that key elements that make 28MID effective in 

minimizing fugitive emissions are (1) requiring all new and 

replacement pumps and compressors to be leakless, (2) the 

use of a lover action level or leak definition of 500 ppm, 

and (3) the use of directed maintenance to ensure maximum 

effectiveness in all repair and maintenance activities. 

The program has been fairly well accepted by companies 

because (1) application of the program results in much 
P.50 

-2-

lower predicted fugitive emissions of toxic compounds based 

on current TACB methodologies, and (2) compliance is determined by factors ever which the companies have control 

rather than an externally applied limit on the "percent 

leakers," which might be exceeded even at a diligent plant 

site due to statistical variations in leak rates. 

One direction the Committee might consider to encourage 

companies to push the limits of current technology and work 

practices in minimizing fugitive emissions is to ensure 

that the fugitive emission estimation methodology adopted 

by the Committee provides a mechanism for collecting plantspecific data to demonstrate lower emission rates. In this 

era of public disclosure through SARA Section 313 reporting, this could provide substantial incentive for emission 

reductions beyond what would be achievable through technology, work practise, arad performance standards developed to 

be broad enough t© cover the variety of process types that 

produce fugitive emissions. 

Please let me know if you have any questions regarding the 

information I have provided. I look forward to seeing you 

at the next Committee meeting. 

Sincerely, 

MUGHAL 3I W BY 

n mmm 

Les Montgomery, P.E., Director 

Technical Support and 

Regulation Development Program 

Enclosures 

cc: Mr. Gerald Pentenot, Chief, Air Programs Branch, U. S. 

Environmental Protection Agency, Region 6, Dallas 

bcc with attachments: 

op, P. 

*l P.E., Permits Division 

Wayne Burnop, P.E., Technical Services Division 

bcc w/o attachments: 

Steve Spaw, P.E., Deputy Executive Director 

Jim Myers, P.E., Director, Enforcement Program 

Lawrence Pewitt, P.E., Director, Permits Division 

Sam Crowther, P.E., Permits Division 

Paul Henry, P.E., Director, Technical Services 

Division 

JLM/gem/board/file (REGNEG2.JLM) 
P.51 

Attachment I 

**\l 1 -fDescription of Fugirtrv-e/lmission Control 

Requirements Implemented 

as Part of the 

Texas Air Coatxo-1 Board's 

Permit Program 

The Texas Air Control Board's (TACB) Permit Division implements a volatile organic compound (VOC) fugitive emission 

control program that makes use of standardized "General 

Provisions" designed to achieve several different levels of 

control (see 28M, 28MD, and 28MID which are enclosed). 

General Provision 28M is the most basic level and is used 

in permits requiring application of best available control 

technology. General Provision 28MD improves upon 28M by 

increasing the monitoring frequency from quarterly to 

monthly and by requiring a "directed" maintenance" program 

in which the individual repairing a leaking component uses 

an analyzer dtdring the repair'to. ensure that a minimum 

concentration of leaking VOC is obtained. 28MD is considered acceptable to meet lowest achievable emission rate 

(LAER) in refineries for components other than those handling toxic materials such as benzene. 

General Provision 28HID is the one'most likely to be of 

interest to the Negotiating Committee. 28MID is the most 

stringent program and is used in permits for the chemical 

industry when application of LAER is required or in any 

permit when toxic materials are involved. The key 

strengths of 28MID are reliance on.a lowered leak definition of 500 ppm and the use of the "directed maintenance" 

program which ensures effective repairs. Current TACB 

staff opinion ia that these two factors are far more important than monitoring frequency in ensuring minimum emissions so quartetly~mor|ltor^|g'is allowed in 28MID. 

Because 28MID ia a rilSti^eiy.new"type of fugitive emission 

monitoring and repair program, the staff has not been able 

to rely on historical data in estimating the resulting 

fugitive emission*. Provision I of"28MID is designed to 

ensure that data that may help in derivation of emission 

factors is collected at process units implementing 28MID 

(On 10/2/89, Bob Ajax asked us to see if any such data is 

available - we are checking with affected companies). 

Until sufficient data is collected and analyzed, the Permits Division relies on "stratified" emission factors for 

the 0-1,000 ppm leak range to estimate the resulting emissions. It is assumed that the average emissions for components affected by 28MID are equal to the average for 

components with screening values less than 1,000 ppm at the 

plants (other than ethylene plants) used to derive the 

"SOCMI" emission factors. 
P.52 

GENERAL PROVISIONS' 28MIO 

3/89 

Piping, Valves, Flanges, Pumps and Compressors i_ 

Service - Intensive Directed Maintenance 

Except as may be provided for in the special provisions of this 

permit, the following requirements apply to the above referenced 

equipment. 

A. These provisions shall not apply (1) where the 

concentration in the stream is less than percent by 

weight, or (2) where the volatile organic comoounas (VOC) have 

an aggregate partial pressure or vapor pressure of less than 

0.05 psia at 20*c or (3) to piping and valves smaller than two 

inches nominal size or (4) operating pressure is at least 5 

kilopascals (0.725 psi) below ambient pressure. Eauipment 

excluded from this provision shall be identified in a list to 

be made available upon request. 

8. Construction of new and reworked piping, valves, pump and 

compressor systems shall conform to applicable ANSI, API, ASME 

or equivalent codes. 

C. New and reworked underground process pipelines shall contain 

no buried valves such that fugitive emission monitoring is 

rendered impractical. 

0. To the extent that good engineering practice will permit, new 

and reworked valves and piping connections shall be so located 

to be reasonably accessible for leak-checking during plant 

operation. Non-accessible valves shall be identified in a 

11st to be made available upon request. 

E. New and reworked piping connections shall be welded or 

flanged. Screwed connections are permissible only on piping 

smaller than two-inch diameter. No later than the next 

scheduled quarterly monitoring after initial installation or 

replacement, all new or reworked connections shall be gas 

tested or hydraullcally tested at no less than normal operating pressure and adjustments'made as necessary to obtain leakfree performance. Flanges shall be inspected by visual, 

audible and/or olfactory means at least weekly by operating 

personnel walkthrough. 

Each open-ended valve or line shall be equipped with a cap, 

blind flange, plug or a second valve. 

F. Accessible valves shall be monitored by leak-checking for 

fugitive emissions at least quarterly using an approved gas 

analyzer with a directed maintenance program. Sealless/ 

leakless valves (Including but not limited to bellows and 
P.53 

GENERAL PROVISIONS 

28MI0 

3/89 

diaphragm valves) and relief valves equipped with a rupture 

disc or venting to a control device are not required to be 

monitored. For valves equipped with rupture discs, a pressure 

gauge snail be installed between the relief valve and rupture 

disc to monitor disc integrity. All leaking discs shall be 

replaced at the earliest opportunity but no later than the 

next process shutdown. 

A directed maintenance program shall consist of the repair and 

maintenance of components assisted simultaneously by the use 

of an approved gas analyzer such that a minimum concentration 

of leaking VOC is obtained for each component being mam -

tainea. 

G. All new and replacement pumps and compressors shall be 

equipped with a shaft sealing system that prevents or detects 

emissions of VOC from the seal. These seal systems need not 

be monitored and may include but are not limited to dual pump 

seals with barrier fluid at higher pressure than process 

pressure, seals degassing to vent control systems kept in good 

working order or seals equipped with an automatic seal failure 

detection and alarm system. Submerged pumps or sealless pumps 

(including but not limited to diaphragm, canned or magnetic 

driven pumps) may be used to satisfy the requirements of this 

provision and need not be monitored. 

All other pump and compressor seals emitting VOC shall be 

monitored with an approved gas analyzer at least quarterly. 

H. (Damaged or leaking valves, flanges, compressor seals and pump 

seals found to be emitting VOC in excess of 500 ppmv or found 

by visual inspection to be leaking (e.g. dripping liquids) 

shall be tagged and replaced or repaired. Every reasonable 

effort shall be made to repair a leaking component, as specified in this paragraph, within 15 days after the leak is 

found. If the repair of a component would require a unit 

shutdown the rep-air may be delayed until the next scheduled 

shutdown. All leaking components which cannot be repaired 

until a scheduled shutdown shall be identified for such repair 

by tagging. The Executive Director, at his discretion, may 

"equire early unit shutdown or other appropriate action based 

the number and severity of tagged leaks awaiting shutdown. 

I. ne results of the required fugitive monitoring and maintenance program shall be made available to the Executive 

Oirector or his designated representative upon request. 

Records shall indicate appropriate dates, test methods, 
P.54 

GENERAL PROVISIONS 

28MI0 

3/89 

J. 

instrument readings, repair results and corrective actions 

taken. Records of flange inspections are not required unless 

a leak is detected. 

Compliance with the requirements of this provision does not 

assure compliance with requirements of TAC8 Regulation V, an 

applicable New Source Performance Standard or an applicable 

National Emission Standard for Hazardous Air Pollutants and 

does not constitute approval of alternative standards for 

these regulations. 
P.55_ 

GENERAL PROVISIONS 28MD 

9/89 

Piping, Valves, Flanges, Pumps and Compressors J_n Volatile Organic 

Compound (VOC) Service _ Directed Maintenance 

A. These provisions shall not apply (1) where the VOC has an 

aggregate partial pressure or vapor pressure of less than 0.5 

psia at 100°F or at maximum process operating temperature if 

less than 100°F, or (2) to piping and valves smaller than two 

inches nominal size or (3) where the operating pressure is at 

least 5 kilopascals (0.725 psi) below ambient pressure. 

8. Construction of new and reworked piping, valves and pump and 

compressor systems shall conform to applicable ANSI, API, ASME 

or equivalent codes. 

C. New and reworked underground process pipelines shall contain 

no buried valves such that fugitive emission monitoring is 

rendered impractical. 

0. To the extent that good engineering practice will permit, new 

and reworked valves and piping connections shall be so located 

to be reasonably accessible for leak-checking during plant 

operation. Non-accessible valves shall be identified in a 

list to be made available upon request. 

E. New and reworked piping connections shall be welded or 

flanged. Screwed connections are permissible only on piping 

smaller than two-ineh diameter. No later than the next 

scheduled monthly monitoring period after initial installation 

or replacement, all new or reworked connections shall be gas 

tested or hydraulIcally tested at no less than normal 

operating pressure and adjustments mad© as necessary to obtain 

leak-free performance. Flanges shall be Inspected by visual, 

audible and/or* olfactory means at least weekly by operating 

personnel walk-through. 

Each open-ended valve or line shall be equipped with a cap, 

blind flange, plug or a second valve. 

F. Accessible valv©s shall b© monitored by leak-checking for 

fugitive emissions at least monthly using an approved gas 

analyzer. Sealless/leakless valves (including but not limited 

to bellows and dlaphrapi valves) and relief valves equipped 

with a rupture* disc upstream or venting to a control device 

are not required to be monitored. For valves equipped with 

rupture discs, a pressure gauge shall be Installed between the 

relief valve and rupture disc to monitor disc integrity. All 

leaking discs shall be replaced at the earliest opportunity 

but no later than the next process shutdown. 
P.56 

GENERAL PROVISIONS 

28M0 

9/89 

G. Except as may be provided for in the special provisions of 

this permit, all pump and compressor seals shall be monitored 

with an approved gas analyzer at least monthly or be equipped 

with a shaft sealing system that prevents or detects emissions 

of VOC from the seal. Seal systems designed and operated to 

prevent emissions or seals equipped with an automatic seal 

failure detection and alarm system need not be monitored. 

Seal systems that prevent emissions may include but are not 

limited to dual pump seals with barrier fluid at higher 

pressure than process pressure or seals degassing to vent 

control systems kept in good working order. 

Submerged pumps or sealless pumps (including but not limited 

to diaphragm, canned or magnetic driven pumps) may be used to 

satisfy the requirements of this provision and need not be 

monitored. 

H. Damaged or leaking valves, flanges, compressor seals and pump 

seals found to be emitting VOC in excess of 10,000 ppmv or 

found by visual inspection to be leaking (e.g. dripping 

liquids) shall be tagged and replaced or repaired. Every 

reasonable effort shall be made to repair a leaking component, 

as specified in this paragraph, within 15 days after the leak 

is found. If the repair of a component would require a unit 

shutdown, the repair may be delayed until the next scheduled 

shutdown. All leaking components which cannot be repaired 

until a scheduled shutdown shall be identified for such repair 

by tagging. The Executive Oirector, at his discretion, may 

require early unit shutdown or other appropriate action based 

on the number and severity of tagged leaks awaiting shutdown. 

I. The results of the required fugitive monitoring and 

maintenance program shall be made available to the Executive 

Director or his designated representative upon request. 

Records shall Indicate appropriate dates, test methods, 

instrument readings, repair results and corrective actions 

taken. Records of flange inspections are not required unless 

a leak is detected. 

J. Compliance with the requirements of this provision does not 

assure comp11ance with requirements of TACB Regulation V, an 

applicable New Source Performance Standard or an applicable 

National Emtsslon Standard for Hazardous A1r Pollutants and 

does not constitute approval of alternative standards for 

these regulations. 
P.57 

GENERAL PROVISIONS 28M 

9/89 

Piping. Valves, Flanges, Pumps and Compressors in Volatile Organic 

Compound"!VOC) Service 

A. These provisions shall not apply (1) where the VOC has an 

aggregate partial pressure or vapor pressure of less than 0.5 

psia at 100°F or at maximum process operating temperature if 

less than 100°F, or (2) to piping and valves smaller than two 

inches nominal size or (3) where the operating pressure is at 

least 5 kilopascals (0.725 psi) below ambient pressure. 

B. Construction of new and reworked" piping, valves and pump and 

compressor systems shall conform to applicable ANSI, API, ASME 

or equivalent codes. 

C. New and reworked underground process pipelines shall contain 

no buried valves such that fugitive emission monitoring is 

rendered impractical. 

D. To the extent that good engineering practice will permit, new 

and reworked valves and piping,connections shall be so located 

to be reasonably accessible for leak-checking during plant 

operation. Non-accessible valves shall be identified in a 

11st to be made available upon request. 

E. New and reworked piping connections shall be welded or 

flanged. Screwed connections are permissible only on piping 

smaller than two-Inch diameter. No later than the next 

scheduled quarterly monitoring period after initial installation or replacement, all new or reworked connections shall be 

gas tested or hydraulically tested at no less than normal 

operating pressure and adjustments made as necessary to obtain 

leak-free performance. . Flanges shall be inspected by visual, 

audible and/or olfactory means at least weekly by operating 

personnel walk-through. 

Each open-ended valve or line shall be equipped with a cap, 

blind flange, plug or a second valve. 

F. Accessible valves shall be monitored by leak-checking for 

fugitive emissions at least quarterly using an approved gas 

analyzer. Sealless/leakless valves (Including but not limited 

to bellows and diaphragm valves) and relief valves equipped 

with a rupture disc upstream or venting to a control device 

are not required to be monitored. For valves equipped with 

rupture discs, a pressure gauge shall be installed between the 

relief valve and rupture disc te mnitor disc Integrity. All 

leaking discs shall be replaced at the earliest opportunity 

but no later than the next process shutdown. 
P.58 

GENERAL PROVISIONS 

28M 

9/89 

G. Except as may be provided for in the special provisions of 

this permit, all pump and compressor seals shall be monitored 

with an approved gas analyzer at least quarterly or be 

equipped with a shaft sealing system that prevents or detects 

emissions of VOC from the seal. Seal systems designed and 

operated to prevent emissions or seals equipped with an 

automatic seal failure detection and alarm system need not be 

monitored. Seal systems that prevent emissions may include 

but are not limited to dual pump seals with barrier fluid at 

higher pressure than process pressure or seals degassing to 

vent control systems kept in good working order. 

Submerged pumps or sealless pumps (including but not limited 

to diaphragm, canned or magnetic driven pumps) may be used to 

satisfy the requirements of this provision and need not be 

monitored. 

H. Damaged or leaking valves, flanges, compressor seals and pump 

seals found to be emitting VOC in excess of 10,000 ppmv or 

found by visual inspection to be leaking (e.g. dripping 

liquids) shall be tagged and replaced or repaired. Every 

reasonable effort shall be made to repair a leaking component, 

as specified in this paragraph, within 15 days after the leak 

is found. If the repair of a component would require a unit 

shutdown, the repair may be delayed until the next scheduled 

shutdown. All leaking components which cannot be repaired 

until a scheduled shutdown shall be identified for such repair 

by tagging. The Executive Director, at his discretion, may 

require early unit shutdown or other appropriate action based 

on the number and severity of tagged leaks awaiting shutdown. 

I. The results of the required fugitive monitoring and maintenance program shall be made available to the Executive 

Director or lis designated representative upon request. 

Records shall indicate appropriate dates, test methods, 

instrument readings, repair results and corrective actions 

taken. Records of flange inspections are not required unless 

a leak 1s defected. 

J. Fugitive emission monitoring required by TACB Regulation V, an 

applicable New Source Performance Standard (NSPS), Title 40 

Code of Federal Regulations Part 60 (40 CFR 60) or an applicable National Emission Standard for Hazardous A1r Pollutants 

(NESHAP'S) (40 CFR 61) may be used in He u of Items F through I 

of this provision. 

Compliance with the requirements of this provision does not 

assure compliance with requirements of TACB Regulation V, NSPS 

or NESHAPS and does not constitute approval of alternative 

standards for these regulations. 
P.59 

ATTACHMENT II 

w p

. 3 PERM I TS 

3-Z2-9 9 AJORKSHOP 

VOC "UGITVE S 

A. ^OC-fugitive source Regulations 

i . Pef *.,-.erv 

a . "ACS Regulatio n V - Brazoria . Dallas , Z l Paso , 3aiveston , 

Gregg , -arris , JeHersan . Nueces . :>anqe .

 r ar--ant . 

•'ictori a 

o . MSPS GGG 

c . NESHAPS J fo r Senzen © 

d .

 r ftCB Permi t Provision s 

2. Gn-snore Natural Gas P-ocessinq Plants 

-*. "ACE Regulation V - Harris 

o. -SPS •'*'< 

c . "ACS Permi t Provision s 

SOCMI 

a . "-C S ^equ.acio n v - Harri s 

2 . -iSFS v v 

c. NESHAPS - far vCM, J -for Benzene 

a. "ACE ^ermit P-avisions 

9. 'luant:'-/:-; -near, troi led Emissions 

1.

 aefinerv - ap-42 rable °.l-2 

.1. >3as Processing -. from EPA-43(2/3-93-007, page 2-9 

valves: 1.126 Ia/dav/seurcs 

Peiier Valves: ^.Vi 

anen-endea lines: 1.17 

comoressor seals: 39.7 

oumo seals: 3.Z 

flanges and connections: .037 

Note - -actors ars for total hydrocarbons so for vQC emissions 

you havo to multiply bv tio mole fraction non-methane, 

non-stnano 

- Comoressor seal factor *our times higher than *3/92 Doc 

3. SOCMI - average* SOCMI factors from EPA-450/3-82-<aiffl. -. 2-62 

-• "AC2 "reaerived" SOCMI /»/o rthyiene -:: an: :aca 

and SOCMI witn just etnyiene slant data 

- uso factors on attached tablo 

"•cte - 2-i.£3Q strati Tiaa a.-.o i3n-;.'aser •sccurs are 

only accoetadle under conditions ceocribod in 

Section 3 of this outline.' 

Note - EPA/CMA Protocol <Leak/No Leafc, Stratified. Plant 

soecific correlation) is generally NOT ACCEPrABLE -.**r 

TACB Permits Docouao o*f inhorent problows with 

individualized aooroaches in cermits. 
P.60 

fT 

3 . 2 0 f 4 

4. JO NOT ESTIMATE

 r;JG I". VES -or: !nQ cuicance "cn* £.=A ) 

a. Par tubing size ime s and eauismen; **on-oipinq tvoe 

- i tt ma s 

3. where the coerati.-ig pressure a t laasc .3.7 asi :SIQ M 

amoient pressure NSPS* 

c. where -he VOC r-as an aggregate partial pressure or 

less than 0.002 PS I 

d. -homogeneous water solutions 

Options for reducing Fugitive VOC Emissions 

1. Options chosen deoenas on the reason ror ^eduction 

a. Satisfy BACT 

b. Reduce amoient air impacts to aoorovaoie level 

C. Avoia "eaerai PSD/non-attainment -eviews 

2. Methods af fugitive vOC reductions 

a. Eliminate Emissions ov Eauipment Sceci f ica c::r* 

i" Relief valves - vent to Piare 

- Equip with Rupture Disk Upstream 

2) Pumps - Barrier Pluid at Higher

 3ressure 

- barrier

 £luid seal pot venting to flare 

- Canned 

- Magnetic Drive 

- Diapnragm 

r ' Valves - Seilows 

- Diapnragm 

4) rlanges - wold 

2" Compressors - enclosed distance 3ieces and c-anxcase 

venting to -Mare 

, b. Peauce emissions 

1 " Eauipmont 

3) Inspection Maintenance 

a) Peur KS V criteria 

- what has to bo monitored, psia or type material 

- frequency at monitoring, 

quarter ly/mon***!- L v/arn^a i .y 

- leak dQ'f ini tion , * ppmv 

- directed (D) or non-directed (ND) 

b) different arograms (valves. :UP*3S ana icmoressars) 

- NSPS : .0.03 psi, CJ/M-3KI=/(A, laeaa ppmv, ND 

- NESHAPS: 7. compound, 3/R-skio/A, 10000 ppmv, ND 

- - s g •! J . »• T / psi , . — •• -i ~ 'i • - — - . .-i-i*. .: p .TW , .J 

- 28Ms >@.S psi, a/Q/Q. 10000 ppmv, NO 

- 2SMD: **0.3 psi. M/M/M, '.0000 ppmv, 3 

- ZSMIDs >0.0S/compound soocific. 

•3/Q/Q, 520 ppmv, D 

(Notos 28MID is undor review by TACB and TCC, 

"CC recommondod leak is 10®@> 

2) Ambient Monitoring is NOT gonorally accepted as 

eouivalent to I&F1 bocausQ tho lack of correlation 

.botwoon am&ionfc monitored vaiuoo and actual emiooion 

ratoo or leak froeuencv 
P.61 

3 . 3 O f 4 

juantir'vin g Pugitiv e E/nissic n Reduction 

-. Choices 

*. ) Camo.ay. - Quantitative, calculate ana test pata 

2) Sim.ole - Cuaiitative, consistent, Pafenaaaie estimate 

p. "ACS takes the = impi.e Approach 

1 .' Ref inerys 

a) SACT - Reg v, NSPS, NESHAPS. Permit Provision 2SM 

- 757. reduction over AP-a*? 

b) uAEP - Permit Provision 29MD 

- 907. -eduction over AP-42 

c) Impacts, aenzene only - 28MID 

- estimate with 0-1000 stratified -actors 

2) Gas Plants 

a> SACT - Peg v. NSPS, 28M 

- "'27. -ecuction z^/Qr EPA

 ractor<= 

b' _.AEP/ ." ""IPACT3 - ha experience 

3) SOCMI 

a) SACT - Reg V, NSPS. NESHAPS, 28M 

-.727. reduction 

b) _AER/Impacts - 28MID 

- stratified factors 0-1000 

c) might consider 28MD with 90% reduction '-jr 

pornoou-as like ethylene and propylene 

4) Specific taxic/odorous/low vapor pressure materials 

a) 212, NH3. -CN, HF, H2S 

I&M provision similiar to attacned 

emission estimates 0-1000 stratifiea 

b) Material with vapor orossuro < 0.0147 pgia 

I&M: pnvsical inspection only 

no imoacts analysis 

emission estimates 0-1000 stratified 

c) Material with vapor pressure 0.0147 - a. 1.47 psia 

if impacts acceptable 

"&M: physical inspection only 

emission estimates SOCMI non-ieaKer 'actors 

if further reduction dosirea 

I&M: 23MID 

emission estimatos >0-l0@S stratifiea 

.moiiflen: -ISi'v.D general iy mien ~-z ..nsac:** ir.ai/sis 

- <or moaifications tho entire slant would nave to 

implement 29MID to avoid impacts analysis 

6) Calculate emissions for all sources cut claim 

reduction only for sourcoa actually inspoctod 

a) flanges: C3% -eduction

 (ar physical inspection 
P.62 

P. 4 of 4 

uMA/EPA Soecific Comoounc/p1 ant studies 

_ a) Butaaiene. Ethylene Oxide and Ph a S q e n e 

b) *"uitip_e plant pataoase -or carrelafp-s 

i- \ 

"ACB mav Pe wiiling to use the resulting 

por-eiations if data is complete and 

corresponding eouioment and I&M specifications 

are defined - w© will seo. 

Information needed in the applicati 

on 

a. ""abu.ate source count by source type 

b. Show factors used 

p. =how -eduction claimed 

3. Hoeciate by chemical 

l ' Qualitatively by grouping ranges of compositions 

2) Cuanitatively by calculating each source individually 

e. If a modification snow existing, new and total not just new 

f. 5ee attached examples af acceptable methods 
Egjioo fl fpcnosiroCC 

WoBvea 

D"ooa(p SG/S*DQ 

CooptrGusotr 

SQOBO 

PtrsooofltrQ 

FBotregeo 

©rjuotro—EtraaDoaO 

Saopfi flung 

(CffiBB-DGCttfloiraa 

SecrwflcQ 

LflgOoG: B.fl<goafl<rO 

OOsmwj; [LfldgooM 

[LflsOott (Uq-oofldQ 

(Eoo^Woipotr 

Cas Vapor 

Light Liquid 

Meavy Liquid 

Mfl 

ABU 

Average 

SOCMH 

SOCHI 

FUCinrDWE- EMIISSDON FACTORS 

Kp/OOtr^SmoDO-ce 

SOCMI SOCMI 

W/O C? C2 ONLY 

.0056 

(U.OO70 

©.<Q>$94 

(D.<0)204 

0.0017 

0.00023 

0.00003 

0.000 7 

0.0050 

0.0027 

0.0030 

0.0003 

0.0396 

0.0225 

0.228 

0.104 

0.0013 

0.00023 

0.00003 

0.0018 

0.0150 

0.0073 

0.0212 

0.00023 

0.1240 

0.0141 

0.228 

0.104 

0.00241 

0.00236 

0.00003 

0.0034 

0.015 0 

Stratifie d 

O-OOOO ppmv 

0.0001 4 

(-97.5 ) 

1 

0.00028* 

(-96.0 ) 

0.0002 3 

NonLeaker 

0.00048 

0.00171 

0.00023 

(-56.0 ) 

(-02.2) 

0.00012 

(-55.0 ) 

0.0114* 

(-89.0 ) 

0.00002 

0.00 0 0 3 

(-92.3 ) 

0.0120 

0.0135 

0.0894 

0.0447 

0.00006 

0.0015 

jiTEs . 

"ac Joh n St us 

trDna troacoOBQcro im (patratrtittlhiQsilQ aero Ctll.Q perrce-ratt: fl-*ic(rea<3ao aitr decrease® Ccroa averag e SOCMI factora . 

(Radian) these ars correct numbers 5-9-88„ 11:30 a.D. 

From CMA Draft Protocol 

(except G/V, Light & Heavy Liquid Flanges, SOCHI W/O C2 + C2 only added ffrona 1-15-87 meeting' summary.) 
P.64 

8. Piping, Valves, Pumps, and Compressors in C12 Service 

A. All operating practices and procedures shall conform to the 

recommended design and safety practices specified by the 

Chlorine Institute Guidelines for C^-

B. Audio, olfactory and visual checks for hydrogen chloride and 

Cl2 leaks within the operating area shall be made every four 

hours. ' • • 

C. Immediately, but no later than one hour upon detection of a 

leak, plant personnel' shall take the following actions: 

1. Iseiat© the leak. 

2. Corem^nci repair or replacement of the leaking component. 

3. Us© a leak collection/containment system to prevent the 

leak until repair or replacement can be made if immediate 

repair is not possible. 

Records shall be maintained at the plant site of all repairs 

and replaegffltgnts mad@. These records shall be made available 

to representatives of the TACS upon request. 
Source* Stree a 

Coaposition 

PI finned SOD)! 

Nuaeop Eaission 

ot? Foctop 

Sourees (lb/hp/soupee ) 

Cont pel 

Method 

Central 

Efficiency 

($) 

Control 1G-*J 

Eaissions 

(1b/np)(tea/yp) 

FU6ITM EMISSION SOUSCES IH VOC SERVICE HITH USS THAU 10$ C2'S 

Valvos: gas/vapep 

light liquid 

heavy liquid 

Puop light liquid 

Seals: heavy liquid 

Mango: gas/vapep 

light liquid 

heavy liquid 

Open Ended Valves . 

BoHof Valves 

Cocsppossep seals 

Drains 

Saoplo Connections 

230 0.0113 

617 0.01S7 

131 O.OOOS 

17 0.1089 

4 0.0472 

544 O.0O39 

1117 O.OOOS 

193 0.00008 

207 0.0042 

43 0.2293 

2 0.3027 

29 0.0027 

24 0.033 

A 

A 

A 

A 

A 

73$ 

73$ 

75$ 

73$ 

73$ 

363 

30% 

30$ 

vm 

nono 

F 

0$ 

Subtotal fop Fugitivo Eaission SOUPCQS without C2 

FUGITIVE EMISSION SOUSCES IH VOC SERVICE HITH 10$ OS HOSE C2'S 

Valvos: gas/vapep 

light liquid 

hoovy liquid 

light liquid 

Seals: heavy liquid 

Flange: gas/vaoep 

light liquid 

hoovy liquid 

Open Ended Valvos 

BoHof Valvoa 

Ceoppossep soala 

Opsins 

Sergio Ceanoctiens 

413 

213 

0 

4 

0 

0.018 

0.0467 

O.OOOS 

0.273 

0.031 

1091 0.0033 

399 0.0032 

0 0.00688 

339 

61 

26 

IS 

17 

0.0974 

0.2213 

0.S&7 

0.0927 

0.033 

A 

A 

A 

A 

A 

73$ 

73$ 

73$ 

73$ 

30$ 

30$ 

36$ 

neat** 

F 

0$ 

108$ 

0.707 3.618 

2.422 10.607 

0.017 0.072 

0.463 2.627 

0.047 0.287 

1.483" 

0.391 

0.008 

0.009 

0.009 

0.069 

0.078 

0.06S 

6.S&T" 

1.712 

0.836 

0.689 

0.009 

0.069 

5.618 24.697 

1.632 7.238 

2.543 11.143 

0.009 0.069 

0.273 1.1S6 

0.089 0.0S9 

4.048 17.721 

1.432 6.361 

0.089 0.SS3 

0.009 0.669 

0.089 0.6S9 

0.089 0.069 

0.027 0.118 

o.ee© 0.S6S 

S«jM@«al fop Fugitive* Eaission Soureos oitft C2 9.SS7 43.787 

ooooooooooooooooooooooooooooooaooooooooooooooooooaQOQaooooooooQoooooooooooooaooooooooaooooooooooo 

Tota l of Fugitivo Eaissions fop Afeeva Soupeos 15.813 63.394 

Assuaptions: 1 . "I n VOC sopvico0 i s dofinod as containing 10$ OP SSFO VOCs on a weight basis . 

2. SOCHI eaission facteps fop C2's apply whon a flea stpoea contains 10$ OF COFC 

C2's on a cslo basis. 

3. Count fop valves and flangos in hydpee&rbon sopvico but net in VOC soFvieo is 

ppovidod fop information only. 

4. Count fop al l SOUPCOS is basod on pocont otftylono projects of siaila p dosign. 

Bofopeneo: Kollegg Job 6262 

5. Piping spoeificatiens dictate piping cennoctiens 2° and boleo to be soefcot welded. 

Contpel Methods: A. Ouaptoply loab dotoctien and rcpoip ppe-f rm. 

8. guartGPly loafe dotoct*ien and repaip ppegpao. 

C. Opon endod valvos capped OP blinded . 

0 . BoHo f valvos connected t e tho flapo systea . 

t. CoaopessoF jea l lests centime ; m d r.T/ele. ts priests . 
P.66 

COMPONENT 

PROPYLENE 

VAPOR VALVES 

LIQUID VALVES - . 

SAMPLE CONN. 

COMPRESSORS 

RVS 

VAPOR FLANGES 

LIQUID FLANGES 

ALLYL CHLORIOE 

VAPOR VALVES 

LIQUID VALVES 

SAMPl£CONN. 

COMPRESSORS 

RVS 

VAPOR FLANGES 

UOUID FIANGSS 

HEAVY ENOS 

VAPOR VALVES 

UQUID VALVES 

SAMPLE CONN. 

COMPRESSORS 

RVS 

VAPOR FUDGES 

UOUIO FLANGES 

LIGHT ENOS 

VAPOR VALVES 

UQUIO VALVES 

SAMPLE CONN. 

COMPRESSORS 

RVS 

VAPOR PLANGES 

UQUIO FUNGESNET COUNT 

OLO 

403 

1671 

23 

1 

11 

1352 

4737 

140 

332 

0 

0 

0 

414 

1000 

39 

125 

4 

0 

0 

125 

375 

SI 

71 

2 

0 

0 

153 

213 

NET COUNT 

NEW 

47 

.166 

1 

0 

0 

143 

497 

7 

22 

0 

0 

0 

21 

66 

-

15 

15 

1 

0 

0 

46 

45 

• 

0 

0 

0 

0 

0 

0 

0 

NET COUNT 

TOTAL 

450 

1837 

29 

1 

2 

1495 

5234 

PROPYLENE 

147 

354 

0 

0 

0 

435 

1066 

AO 

54 

140 

5 

0 

0 

171 

420 

HEAVY ENOS 

51 

71 

2 

0 

0 

153 

213 

LIGHT ENOS 

FACTOR 

• /HR/COMP | 

(<1000 PPM*. 

0.00031 

0.00062 

0.00290 

0.02496 

0.02513 

0.00004 

0.00004 

TOTAL a 

f<1000 PPM"i 

0.00031 

0.00062 

0.00290 

0.02496 

0.02513 

0.00004 

0.00004 

TOTAL a 

U1000 PPM1 

0.00031 

0.00062 

0.00290 

0.02496 

0.02513 

0.00004 

0.00004 

TOTAL a 

(<1000 PPM) 

0.00031 

0.00062 

0.00290 

0.02496 

0.02513 

0.00004 

0.00004 

TOTAL a 

EMISSIONS 

LBS/HR 

0.14 

1.14 

0.08 

0.02 

0.05 

0.06 

0.21 

1.71 

0.05 

0.22 

0.00 

0.00 

0.00 

0.02 

0.04 

0.33 

0.02 

0.09 

0.01 

0.00 

0.00 

0.01 

0.02 

0.14 

0.02 

0.04 

0.01 

0.00 

0.00 

0.01 

0.01 

0.08 

EMISSIONS 

TPY 

0.81 

4.99 

0.37 

0.11 

0.22 

0.26 

0.92 

7.48 

0.20 

0.96 

0.00 

0.00 

0.00 

0.08 

0.19 

1.42 

0.07 

0.3ft 

0.06 

0.00 

0.00 

0.03 

0.07 

0.62 

0.07 

0.19 

0.03 

0.00 

0.00 

0.03 

0.04 

I 0.35 

"Net" count means actual component count multiplied by the percentage of flow 

through it that is the constituent whose emissions are being estimated. That is, if the 

flow through a component is 30% EDC, and 70% VCM, it is counted as 0.3 in the EDC 

emissions table and 0.7 in the VCM emissions table. 
ATTACHMENT II I 

APPLICATION OF FUGITIVE KIOMITOKIMG C3ITM IMTEMSIVE DIRECTED D3AIMTEMAMCE 

GEMERAL PROVISION 28C3ID 

Issue * 

Dat e 

Applie d 

9/11/8 7 

4J/17/89 

4/18/8 9 

7/7/8 9 

<t© KtetJ Proc 

C-18072 

C-1881S 

C-18817 

C-18950 

Cq-Rraj^if ftflfSliae 

e@® SDonilbs 

Polysa r Gulf Coast , In c 

Phillip s 6<S Company 

Chemical Researc h & 

Licencin g Company 

Dow Chemical U.S.A. 

Im* Klodlifficaitioini too Ezsistimngj ttJiraitts 

5/12/8 8 R-4825A Georgi a Gulf Corporatio n 

9/16/88 R-8758 Mobil Chemical 

ynUt mm 

Tornac Rubber 

Ethylene Unit 33 

Pilot Plant 

hydrocarbons 

Unit . 

Cumene Plant 

Provision** 

GP6 Early Vers. 

Pollutants*** 

VOC 

Chlorobenzene 

GP6 28MID (3/89) VOC, Benzene 

GP6 28MID (1/88)*' 

GP3 Chemical List 

VOC 

24 Compound List 

GP7 28MID (3/89) VOC, Benzene, 

SP13 Gas Analyzer Ethylene, 

Calibration Propylene 

GP6 28MID (1/88) 

SP3 Modifies to 

3/89 28E3ID 

Polyethylene Plant GP8 28MID (1/88) 

VOC, Benzene 

VOC, Polyethylene, Ethylene, 

Hexane 

* Issue date is the date 28MID (3/89) or at similar intensive directed maintenance program was put 

in the permit. 

a* Provision indicates the General Provision (GP) and/or Special Provision (SP) that enacts 28MID 

(3/89) or an earlier or modified version. 

ao* Pollutants notes specific air contaminants affected by the fugitive provision. 
Issue* 

Date Number Company Name Unit Name Provision** Pollutants*** 

12/33/88 R-9085 Union Carbide Chemical 

& Plastics Company, Inc. 

Oxo-800 GP6 28MXD (1/88) 

SP2 Modifies to 

3/89 28MXD 

Butyraldehyde 

Butanol, VOC 

w/10$ above 

3/10/89 X-16231 Texaco Chemical Company 

6/10/89 R-8444 

7/5/89 C-6382 

PPG Industries 

Dow Chemical U.S.A. 

7/6/89 C-18775 Nalco Chemical Company 

8/7/89 C-6283 Halterman, Ltd. 

Pilot Plant 

Chloroformate 

Expansion 

GC 28MXD (1/88)' 

GP7 28MID (3/89) 

Ethylene Amines GP7 28MID (3/89) 

Unit Expansion SP4 VCM Recovery 

Unit4 

Oxylation/Resin GP7 28MID (3/89) 

Unit 

Superfractionation GP7 28MID (3/89) 

6 Storage Facility 

Ethylene Oxide 

1, 2 Butylene 

Oxide 

Pivalyol 

Chloride 

Vinyl 

Chloride 

Ethylene Oxide 

VOC, Approved 

Chem. List has 

120-4- compounds 

* Issue date is the date 28MID (3/89) or at similar intensive directed maintenance program was put 

in the permit. 

** Provision indicates the General Provision (GP) and/or Special Provision (SP) that enacts 28MID 

(3/89) or an earlier or modified version. 

*** Pollutants notes specific air contaminants affected by the fugitive provision. 
Issue* 

Date dumber Company Name Unit Name Provision** Pollutants*** 

8/15/88 R-1272A Sterling Chemical Acrylonitrile 

Production 

GP8 28MID (1/881 

SP2 Modifies to 

vers, similar 

to 28MID (3/89) 

Acrylonitrile 

(AN), V0C/10S AN 

8/18/88 R-343' Dow Chemical U.S.A. Phenol Plant GP6 28 MID (1/88) 

SP4 Modifies to 

3/89 28MID 

VOC, Benzene 

Phenol',, Acetone 

1 This was an early version suggested by the company using 1,000 ppra^ leaker, but no specific directed 

maintenance. 

2 This was the version of 28MID drafted in January of 1988 (1/88)- with the exception that the monthly 

testing had been changed to quarterly. 

3 The Special Provision 13 references EPA -methodology for gas analyzer calibration. 

4 The Special Provision 4 notes the General Provision 7 only applies to the VCM recovery unit. 

5 The action level is 1,000 ppm rather than 500 ppmw. 

6 This is a general condition placed in an exemption rather than a provision in a permit. 

* Issue date is the date 28MID (3/89) or at similar intensive directed maintenance program was put 

in the permit. 

** Provision indicates the General Provision (GP) and/or Special Provision (SP) that enacts 28MID 

(3/89) or an earlier or modified version. 

*** Pollutants notes specific air contaminants affected by the fugitive provision. 
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P.71. 

ATTACHMENT IV 

m 'EXAS AIR CONTROL BOAR" 

6330 HWY. 290 EAST. AUSTIN. TEXAS 78723. 512/431-5711 

DICK WHnTINCTON, P.E. 

CHAIRMAN 

BOB C. BAILEY 

VICE CHAIRMAN 

ALLEN ELI BELL 

EXECUTIVE DIRECTOR 

JOHN L BLAIR 

MARCUS M. KEY. M.O. 

OTTO R. KUNZE. Ph.D., P.E. 

HUBERT OXFORD, III 

WILUAM H. QUORTRUP 

CH. RIVERS 

MARY ANNE WYATT 

August 2, 1989 

Mr, William E. Jacobs 

Environmental Manager 

GAP CHEMICALS CORPORATION 

Post Office Sox 2141 

Texas City, Texas 77592-2141 

Dear Mr. Jacobs; 

Re; Relief Valve Requirements 

This is 

of emiss 

response. 

in response to your letter dated March 8. 1989 regarding control 

ions from relief valves. I apologize for the delay in our 

We have two emission issues related to safety relief valves.* fugitive 

emissions and upset related emissions. For each, both best available 

control technology (SACT) and approvable emission impacts must be 

achieved. 

The fugitive emissions can be controlled by, in order of preference, 

venting the valves to a flare (982 control), installing an upstream 

rupture disc (1002) or by implementing a fugitive inspection and 

maintenance program (752). Upset or emergency emissions may be controlled by, also in order of preference, relieving to a flare or by 

process interlocks that rapidly shut off steam, feed, etc. as a result 

of pressure buildup. 

Our conventional Provision 32M (enclosed) requires that all relief 

valves be routed to a flare (982 efficient), incinerator (99.52 

efficient) or a recovery system (952 efficient). We prefer the SACT 

approach that all relief valves relieve to a flare system or equivalent 

without exceptions for pipe size or vapor pressures,because this takes 

care of both fugitive and upset emissions- If these controls can be 

shown to be technically or economically unreasonable, then the applicant 

must propose some other method of control for fugitives and upset emissions-
Mr. William E. Jacobs.. 2 August 2, 1989 

When relief valve vents are not routed to an abatement system, then the 

next most preferable fugitive emission control is a rupture disc upstream which essentially eliminates fugitive emissions. Where this 

option is not feasible, we would agree to implementation of a quarterly 

inspection and maintenance program using a leak definition of 500 ppmv. 

To address upset emissions when relief streams are not routed to an 

abatement system, we would request special process instrumentation/ 

interlocks that would prevent pressure buildup or at least minimize the 

frequency, magnitude and duration of the relief or a multiple relief 

valve system in which smaller relief valves, triggered at lower pressures, are routed to a flare. 

In addition, for relief valves not routed to abatement systems, including those protected by a rupture disc, we would require dispersion 

modeling of the uncontrolled emissions during reliefs to demonstrate 

acceptable impacts. If impacts from normal relief situations or from 

major process upsets are unacceptable then an improved dispersion 

alternative may be considered to obtain acceptable impacts. For some 

explosive or toxic gases, emergency scrubbing may be an option. 

There may be some cases where the relief emissions are so small that any 

BACT concern is unwarranted and that relief of the system's contents to 

the atmosphere would be expected to have no adverse impacts. These ' 

cases would be considered on their merits case-by-case in a permit 

review. 

We have been asking for rupture discs upstream of relief valves for 

about 10 years. Some applicants have raised the concern identified in 

your letter that a pinhole leak in the disc could lead to doubling the 

relief pressure of the system- This was and is of great concern to us 

as well which is why the pressure gauge has been required as a means of 

verifying disc integrity. We understand there are also rupture discs 

available with electronic monitoring of disc integrity. 

For your information, some applicants have identified a concern about 

pieces of disc lodging in a relief valve and preventing the valve from 

closing properly following relief- We have no follow-up information 

that confirms that this happens significantly in practice. Also, some 

applicants have preferred to put the safety valve upstream of the disc 

to avoid tne disc fragment problem. However, we understand that this is 

not feasible in services highly corrosive to the relief valve 

components. 

We have many permittees who have been required to control relief valve 

emissions as described. Certainly we would welcome further insights, 

specific technical information or experience that you could share with 

us. 
P.73 

Mr. William E. Jacobs 3 August 2, 1989 

Thank you for your interest in air pollution control. Let me know if 

you have further questions. 

Sincerely, 

fj.\ 

Sam Crowther, P.E. 

Chief, Chemical Section 

Enclosure 
P.74 

EQUIPMENT LEAK REGULATORY NEGOTIATION 

Revisions to EPA Correlations for 

Estimating Equipment Leak Emissions 

EPA Presentation 

by 

Mr. David Markwordt 

Emission Standard De vision 

U.S. Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 
P.75 

ORGANIZATION OF PRESENTATION 

- Background for Development of EPA Correlations 

- Need for Additional Bagging Data 

- Summary of Equipment Bagging Data 

- Proposed Sampling Matrix for Bagging 

- Comparison of Equipment Bagging Data 
P.76 

BACKGROUND FOR DEVELOPMENT 

OF EPA CORRELATIONS 

- Gas Valves, Light Liquid Valves, Pumps 

o All bagging data from SOCMI 6-Unit Maintenance 

Study used except: 

- Screening values < 10 ppmv 

- Screening values > 100,000 ppmv 

- Finite screening value but non-detectable 

mass emission rate 

- Flanges 

o One correlation developed for all flanges 

o Bagging data from Refinery Assessment Study used 
P.77 

NEED FOR ADDITIONAL BAGGING DATA 

- Gas Valves, Light Liquid Valves, Pumps 

o Existing SOCMI bagging data < 500 ppmv should 

be discarded and new bagging data collected 

- Screening values < 500 ppmv are uncertain because: 

o Screening instruments calibrated to 10,000 ppmv 

o Instrument readout accurate to S% of calibration 

(500 ppmv) 

o Existing SOCMI bagging data >500 ppmv should be retained 

- Sufficient QA/QC guidelines for bagging 
P.78 

NEED FOR ADDITIONAL BAGGING DATA 

- Flanges 

o New correlations should be developed for entire range 

of screening values (0 - 100,000 ppmv) 

- Bagging data from Refinery Assessment Study do not meet 

proposed EPA QA/QC guidelines for bagging 

o Separate correlations for gas flanges and light liquid flanges 
SUMMARY OF EQUIPMENT BAGGING DATA 

Eaui pment 

Type 

Screen!nq 

Val ue 

<ppmv> 

Number of Data Pairs 

SOCMI 6-Unit 

Mai ntenancs 

Studv 

Butadi ene/ 

Ethylene O K ids 

Study 

Union Carbide 

Acrolein 

Study 

Alabama 

Consor t i um 

Study 

Vulcan 

Chemi cal 

Study 

Gas Valves 

Li qht Li qui d 

Valves 

Pumps 

GaB Flanqos 

Liqht Liquid 

Flanqes 

O 

l-lO 

IO-IOO 

IOO-I.OOO 

1,000-10,000 

> 10,000 

O 

l-lO 

10-100 

100-1,000 

1,000-10,000 

> 10,000 

0 

l-lO 

10-100 

1OO-1.OOO 

1,000-10.000 

> 10,000 

O 

l-lO 

10-100 

100-1,000 

1,000-10.000 

> 10,000 

O 

l-lO 

10-100 

100-1,000 

1,000-10.000 

> 10,000 

13 

5 

24 

61 

101 

97 

0 

1 

14 

39 

0 

O 

O 

O 

O 

O 

O 

O 

O 

O 

O 

O 

B 

5 

2 

3 

3 

O 

O 

1 

1 

1 

1 

O 

O 

3 

O 

O 

2 

6 

1 

IO 

2 

O 

4 

1 

TT 

O 

O 

o 

o 

o 

o 

o 

o 

o 

4 

1 

O 

1 

O 

o 

6 

o 

2 

O 

1 

O 

o 

o 

IT 

o 

o 

o 

o 

o 

1 

o 

o 

O 

o 

O 

2 

o 

O 

o 

o 

o 

o 

O TT 

O 

O 

O 

1 

3 

9 

2 4 

7 6 

3 

8 

4 

2 

14 

6 

O "~1 

1 

O 

1 

2 

. 2 

2 4 

O 

O 

O 

O 

O 

O 

O 

o 

o 

o 

o 

o 

o 

o 

o 

o 

o 

24 

O 

O 

O 

O 

O 
P.80 

SUMMARY OF EQUIPMENT BAGGING DATA 

- SOCMI 6-Unit Maintenance Study 

- CMA Butadiene and Ethylene Oxide Panel Studies 

- Union Carbide Acrolein Study 

- Alabama Consortium Study 

- Vulcan Chemical Study 

- Refinery Assessment Study 

Ongoing 

- Union Carbide (Taft, LA) Study 
P.81 

PROPOSED SAMPLING MATRIX FOR BAGGING 

Previous sampling matrix designed to maximize amount 

of bagging data collected; targeted toward overall 

evaluation of curves 

Revised sampling matrix designed to ease burden of data 

collection and focus on areas of uncertainty 
P.82 

PROPOSED SAMPLING MATRIX FOR BAGGING 

Gas Valves, Light Liquid Valves, Pumps 

o Minimum of 30 bags in screening value range of 0 - 1,000 ppmv 

o Recommendation: 40 bags (Allows for elimination of 

bags of unacceptable or questionable quality) 

o Calibrate one screening instrument to 100 ppmv (Allows for 

accurate concentration readings down to 5 ppmv) 

o Calibrate second screening instrument to 1,000 ppmv 

or 10,000 ppmv 
P.83 

PROPOSED SAMPLING MATRIX FOR BAGGING 

Flanges 

o Minimum of 30 bags in screening value range of 0 - 100,000 ppmv 

o Existing correlation developed from 52 bags 

o Existing SOCMI correlations for GV, LLV, and Pumps 

developed from 99, 129, and 52 bags respectively 
P.84 

- i 

PROPOSED SAMPLING MATRIX FOR BAGGING 

- Plant Selection 

o Strive to collect data from a wide variety of chemicals 

J 
P.85 

COMPARISON OF EXISTING SOCMI 

BAGGING DATA TO OTHER BAGGING DATA 

- Preliminary Assumption 

o Existing SOCMI bagging data > 500 ppmv is 

of sufficient quality to retain for 

proposed revisions to EPA correlations 

J 
P.86 

COMPARISON OF EXISTING SOCMI 

BAGGING DATA TO OTHER BAGGING DATA 

- Methodology for Comparison 

o Qualitative Analysis of Other Databases 

- Bagging data < 500 ppmv will be discarded if 

if screening instrument was calibrated to 10,000 ppmv 

- Use engineering judgement to discard other bagging data 

if they are not of comparable or superioir quality to 

existing SOCMI data 
P.87 

COMPARISON OF EXISTING SOCMI 

BAGGING DATA TO OTHER BAGGING DATA 

o Quantitative Analysis 

- Revise EPA correlations to include only those 

components screening between 500 and 100,000 ppmv 

- Add new data to existing data and develop second 

set of correlations 

- Compare correlations and associated confidence 

intervals per EPA Protocol 

o If correlations are similar, merge new bagging 

data into existing SOCMI data 

o If correlations are not similar, retain only the 

SOCMI bagging data 
i •*-

SUMMARY OF EQUIPMENT BAGGING DATA 

BS=SSZS==S S w 

_, 

• 

Equipment 

Typa 

Gas ValVQ B 

Light Liquid 

Valvoo 

Pumps 

G as Flangos 

Light Liquid 

Flongoo 

Screeni nq 

(ppmv) SOCMI 6-Unit 

Mai 

O 

l-lO 

10-100 

100-300 

500-1,OOO 

1,000-10,000 

> 10.000 

O 

1-10 

10-100 

100-500 

500-1,OOO 

1,OOO-10,OOO 

> 10,OOO 

O 

l-lO 

10-100 

100-300 

300-1,OOO 

1,000-10,000 

> 10,ooo 

o 

l-lO 

10-100 

100-300 

SOO-1,ooo 

1,000-10,000 

> 10,ooo 

o 

1-10 

10-100 

100-500 

300-1,OOO 

1,000-10,000 

> 1O.OOO 

ntanance 

Study 

13 

3 

5 

13 

1 1 

61 

141 

1 

3 

9 

14 

IO 

76 

97 

6 

1 

6 

1 

3 

14 

39 

> 0 

O 

o 

o 

o 

o 

0 

0 

0 

o 

0 

0 

0 

o 

Butadi ene/ 

Ethylene Oxide 

Study 

a 

5 

2 

1 

2 

3 

0 

3 

8 

4 

O 

2 

14 

3 

O 

1 

1 

1 

0 

1 

o 

4 

4 

0 

0 

3 

0 

0 

2 

6 

1 

6 

4 

2 

O 

Number ol Data Pairs 

Union Carbide Alabama 

Acrolein Consortium 

Study St 

4 

1 

0 

0 

0 

0 

0 

6 

0 

1 

O 

0 

1 

o 

0 

0 

0 

o 

0 

0 

o **"""• 

4 

1 

0 

o 

1 

o 

o 

6 

0 

2 

O 

O 

1 

0 

udy 

O 

O 

O 

O 

O 

O 

O 

2 

2 

O 

1 

•5 

O 

1 

o 

o 

0 

0 

o 

0 

2 

0 

O 

0 

O 

O 

o 

Vulcan Vista 

Chemical Chemical 

Study 

0 

O 

O 

<o 

O 

0 

O 

24 

O 

O 

O 

O 

O 

O 

O 

O 

O 

O 

0 

O 

O 

O 

O 

0 

O 

0 

O 

o 

24 

O 

O 

n 

o 

o 

o 

Study 

12 

O 

0 

O 

0 

O 

O 

15 

O 

0 

O 

O 

O 

O 

O 

0 

O 

0 

O 

0 

0 

16 

O 

O 

=. O 

0 

O 

0