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United States Office of Air Quality EPA-456/D-00-001

Environmental Protection Planning and Standards October 2000

Agency Research Triangle Park, NC 27711 www/epa.gov/ttn/uatw/pest/pestpg.html

DRAFT -IMPLEMENTATION DOCUMENT FOR

THE PESTICIDE ACTIVE INGREDIENT

PRODUCTION NESHAP -

(40 CFR 63, SUBPART MMM)

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Implementation Document for the

Pesticide Active Ingredient Production

NESHAP

(40 CFR 63, Subpart MMM)

Prepared for:

Information Transfer and Program Integration Division (ITPID)

Program Implementation and Review Group (PIRG)

Office of Air Quality Planning and Standards

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711

Prepared by:

Midwest Research Institute 

5520 Dillard Road

Suite 100

Cary, North Carolina 27511-9232

October 2000 (Draft)
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i

What is the legal status of this guide?

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

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

document and approved it for publication.

When using this document, remember that it isn’t legally binding and doesn’t replace the final rule -

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

(published in the Federal Register, 6/23/99, 64 FR 33550) or any State, local or tribal rules that may

apply to your facility.

This document isn’t intended, nor can you rely on it, to create any rights enforceable by any party in

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

This document includes only requirements from the final rule published in the Federal Register 6/23/99,

64 FR 33550.
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Thank You

This draft document was prepared by a joint partnership among the Environmental Protection

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

organizations who produce pesticide active ingredients. At the time of publication, the

development team had the following members:

Alfred Azevedo, WV Office of Air Quality

Lalit Banker, EPA, OAQPS, ESD

John A. Dege, DuPont Environmental Center for Excellence

Richard A. DiMenna, Rohm and Haas Company

Mary E. Rice, EPA, OAQPS, ITPID

Dianne J. Walker, EPA, PTAB, Region III

Ingrid Ward, EPA, OAQPS, ITPID

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

suggestions were essential to this guide’s development.
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Table of Contents

Page

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

List of Figures ............................................................ vi

List of Tables ............................................................. vi

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

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

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

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

We want your feedback .................................................... 2

Survey on the Implementation Document for the Pesticide Active Ingredient Production

NESHAP ............................................................ 3

Chapter 2 - What this Pesticide Active Ingredient rule covers - An Overview ........... 5

Why was this Pesticide Active Ingredient (PAI) rule written? ........................ 5

How do I know if I’m subject to this rule? ...................................... 5

What is an affected source? ................................................. 6

When do I need to comply? ................................................. 7

What pesticide active ingredients are subject to the rule? .......................... 11

How does “primary use” differ from “primary product”? .......................... 11

How do I determine the primary use of a product? ............................... 11

What is a pesticide active ingredient (PAI) process unit? .......................... 12

What is an integral intermediate? ............................................ 13

How is “nondedicated” equipment regulated? .................................. 14

How do I know if a storage vessel is part of a PAI process unit? .................... 15

What requirements apply during periods of startup, shutdown, and malfunction? ........ 15

What provisions in this rule overlap provisions in other rules? ...................... 16

What is exempt from the rule? .............................................. 17

Chapter 3 - Complying with requirements for process vents ....................... 18

What process vents are covered? ............................................ 18

What process vents are exempt? ............................................. 18

What compliance options do I have for my Group 1 process vents? .................. 19

How do I show initial compliance with the process vent requirements? ............... 25

What monitoring must I do for my process vents? ............................... 28

What parameters must I monitor? ........................................... 28

How do I set monitoring parameter limits? ..................................... 33

How may I average my monitoring parameter values? ............................ 34
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Table of Contents (cont’d)

Page

iv

What records must I keep for my process vents? ................................ 34

What reports must I submit for my process vents? ............................... 34

Checklists for Process Vent Inspections ....................................... 35

Chapter 4 - Complying with requirements for storage vessels ...................... 56

What storage vessels are covered? ........................................... 56

What storage vessels are exempt? ........................................... 56

What is a “Group 1” storage vessel? ......................................... 57

How do I know if a storage vessel is part of a PAI process unit? .................... 57

What compliance options do I have for my storage vessels? ........................ 58

How do I show initial compliance with the storage vessel requirements? .............. 59

How do I comply when my control device needs repairs [options 4 (A, B, C, and E)]? .... 65

What monitoring must I do for my storage vessels? .............................. 65

What records must I keep for my storage vessels? ............................... 71

What reports must I submit for my storage vessels? .............................. 71

Checklists for Inspection of Storage Vessels ................................... 73

Chapter 5 - Complying with requirements for wastewater systems .................. 92

What wastewater streams are covered? ....................................... 92

What waste management units are covered? .................................... 93

What wastewater streams are exempt? ........................................ 93

What compliance options do I have for my treatment processes? .................... 96

How do I show initial compliance with the wastewater system requirements? ........... 97

What monitoring must I do for my wastewater systems? .......................... 97

What records must I keep for my wastewater systems? ........................... 98

What reports must I submit for my wastewater systems? .......................... 98

Checklists for Wastewater System Inspections .................................. 99

Chapter 6 - Complying with requirements for equipment leaks .................... 114

What equipment leaks are covered? ......................................... 114

How do I identify equipment subject to the equipment leak provisions? .............. 114

What equipment is exempt? ............................................... 115

What compliance options do I have for my equipment leaks? ...................... 115

How do I implement a leak detection and repair (LDAR) program under Option 1? ..... 116

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

Gas/Vapor Service and Light Liquid Service (Option 1)? ...................... 120

What are the LDAR requirements for open-ended valves or lines (Option 1)? ......... 122

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

(Option 1)? ........................................................ 123

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

(Option 1)? ........................................................ 127

What LDAR requirements apply for sampling connection systems? ................. 128
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Table of Contents (cont’d)

Page

v

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

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

in liquid service? .................................................... 128

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

(Option 1)? ........................................................ 129

What is required for an alternative standard (Option 3)? .......................... 134

What are my leak repair requirements? ....................................... 137

What if equipment is unsafe or difficult to monitor? ............................. 139

What records must I keep for my equipment leaks? ............................. 140

What reports must I submit? .............................................. 146

Checklists for Equipment Leak Inspections ................................... 147

Chapter 7 - Calculations and procedures ...................................... 184

Chapter currently not available

Chapter 8 - Recordkeeping and Reporting .................................... 186

Chapter not complete 

What records must I keep? ................................................ 186

What do I have to report and when? ........................................ 186

How can I change the date my reports are due? ................................ 186

Where do I send my reports? .............................................. 186

Chapter 9 - Other requirements and information ............................... 195

Who administers this regulation? ........................................... 195

Do I need a title V permit? ................................................ 195

How do I change my permit to include this rule? ............................... 196

What portions of the General Provisions apply? ................................ 196

Chapter 10 - Getting additional help ......................................... 197

Whom can I ask for help? ................................................ 197

Can I get more information on the Web? ..................................... 198

Is there a list of commonly asked questions? .................................. 200

Chapter 11 - Supplemental information for State and local agencies and Tribes ...... 201

How many plants may need to meet emission limits? ............................ 201

Are plants in Indian country regulated by the State? ............................. 201

How much HAP emissions will the rule reduce? ................................ 201

Appendix A - Subpart MMM, final rule ...................................... 204

Not available in electronic version of this document, download final rule at

www.epa.gov/ttn/uatw/pest/pestpg.html
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List of Figures

Page

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

Affected Sources. ................................................. 9

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

Reconstructed Sources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

List of Tables

TABLE 3-1. Compliance Options for Process Vents ............................... 20

TABLE 3-2. Monitoring Requirements for Air Pollution Control Devices ............... 30

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

Roof ......................................................... 61

TABLE 5-1. Container Emissions Control Requirements ........................... 95

TABLE 6-1. General Requirements and Exceptions of the Equipment Leak Provisions .... 118

TABLE 8-1. Report Due Dates .............................................. 187

TABLE 8-2. Reporting Requirements ......................................... 189

TABLE 10-1. EPA Regional Air Division Offices ................................. 199
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Chapter 1 - Introduction

Why should I use this implementation document? 

This document can help plant owners and operators understand the Pesticide Active Ingredient (PAI)

Production NESHAP (also known as Subpart MMM) by helping you determine four main things:

C if the rule applies to your plant and process

C what compliance options are available

C what to monitor, record, and report

C dates by which you must meet requirements

Is there anything I should know before using this document?

When using this document, remember that it doesn’t replace the final rule but summarizes the requirements

published in the final rule. You should keep up with

new requirements printed after this date by periodically

checking the Federal Register and the Code of Federal

Regulations (CFR). You can download Federal

Register notices by going to the Government Printing

Office (GPO) website at

www.access.gpo.gov/su_docs/aces/aces140.html. 

We’ve included a copy of the final rule in Appendix A (as published in the Federal Register, 6/23/99, 64

FR 33550), so you can reference the rule while using this document. 

How do I get copies of this document?

You can get copies of this document in four ways:

C EPA’s Unified Air Toxics Website (www.epa.gov/ttn/uatw). Look under Rules and

Implementation, pesticide active ingredient, or www.epa.gov/ttn/uatw/pest/pestpg.html

C Library Services Office, (MD-35), U.S. EPA, Research Triangle Park, NC 27711, or

www.epa.gov/natlibra/ols.html (limited supply)

Keep informed of rule changes, if any, by

checking the Federal Register.
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We want your feedback

To serve you better, we’ve included a survey on the usefulness of this document. If you’d like to

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

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

Help us publish better documents by

filling out our survey
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Survey on the Implementation Document for the

Pesticide Active Ingredient Production NESHAP

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

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

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

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

Other __________

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

Plant Operator Q Maintenance Q Plant Manager Q Environmental Staff Q

Regulator Q Other: ____________

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

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

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

1= Strongly Agree to 5 = Strongly Disagree

Statement 1 2 3 4 5 N/A

The document was timely.

The document provides a good overview of the rule.

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

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

own.

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

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

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

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

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

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

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

see in the document)? _____________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

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

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

8. Other comments: ______________________________________________________________________________________

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

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

Research Triangle Park (RTP) MD-12, Research Triangle Park, NC 27711, or fax (919) 541-2664
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 Chapter 2 - What this Pesticide Active Ingredient rule covers -

 An Overview

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

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

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

The rule applies to all organic HAP emissions. It also applies to chlorine and hydrogen chloride

emissions. Our research indicates that the primary organic HAP emissions from PAI production

include all of the following:

C toluene

C methanol

C xylene

C methyl chloride

• methylene chloride

• ethylene dichloride

• carbon tetrachloride

• acetonitrile

How do I know if I’m subject to this rule?

You’re subject to this rule if your plant meets all of the following:

• is a major source of HAP emissions

• manufactures at least one PAI

• is not exempt

Definition. Pesticide Active Ingredient means any material that

is an active ingredient within the meaning of FIFRA section 2 (a);

is used to produce an insecticide, herbicide, or fungicide end use

pesticide, consists of one or more organic compounds; and that

must be labeled in accordance with 40 CFR part 156.
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Note: PAIs are typically described by North American Industrial Classification System (NAICS) codes 325199

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

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

You’re not subject to this rule if you have an enforceable limit on your facility by the compliance

date of Subpart MMM that restricts your emissions to

<10 tons/yr of any single HAP and <25 tons/yr of all

combined HAPs (i.e, in such cases, your facility

wouldn’t be classified as a major source under §63.2 of

the General Provisions).

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

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

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

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

What is an affected source?

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

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

process units) that process, use, or produce HAP

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

PAI process units described above

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

• process vents

• storage vessels

• wastewater systems

• equipment leaks

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

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

after November 10, 1997, or

C any single PAI process unit that meets all of the following criteria:

Your facility is a major source if it can

potentially emit $10 tons/yr of a single

HAP or $25 tons/yr of all HAPs.

See Chapters 3 through 6 for details

about your compliance options for

these emission points.

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

ducts to process raw materials and to manufacture an intended product.
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< isn’t part of a process unit group

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

< construction started on the unit after November 10, 1997

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

• If you add a single PAI process unit at an existing major source and the potential to emit

for that process unit (with or without enforceable limits) is less than the 10 and 25 tons/yr

thresholds, your process unit becomes part of the existing source and is subject to existing

source standards. See the Summary of Public Comments and Responses (EPA-453/R-98-

011), Section 3.6, for more information [available for download on the UATW Pesticide

Active Ingredient Page].

• If you add a PAI process unit to a facility that did not previously contain a PAI process

unit and you create a process unit group, then your PAI process unit is subject to the

existing source standards of the MACT rule that applies to the primary product of the

process unit group if construction of the equipment in the process unit group started prior

to November 10, 1997 and it has not been reconstructed. See “How is nondedicated

equipment regulated?” for more information.

• If you add equipment to an existing PAI process unit, the PAI process unit remains

subject to the existing source standards.

• If you replace equipment in an existing affected source, the affected source remains

subject to the existing source standards unless the replacements meet the definition of

reconstruction.

When do I need to comply?

If your facility is an existing affected source, you must comply by 6/23/02, which is three years

after the rule’s effective date of 6/23/99 [§63.1364(a)]. The effective date is the date the final rule

was published in the Federal Register. An extension of up to 1 additional year may be requested if

time is needed to install controls, and it must be submitted 120 days before compliance date. 

Definition. Process unit group means a group of process units that manufacture

PAIs and products other than PAIs by alternating raw materials or operating

conditions, or by reconfiguring process equipment. Only process equipment that has

been or could be part of a PAI process unit, because of its function or capacity, is

included in a process unit group.
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If your affected source is new or reconstructed, you

must comply upon startup of your operations or on

6/23/99, whichever is later. [§63.1364(b)] See

Figures 2-1 and 2-2 for detailed compliance timelines.

If your affected source is subject to more than one

standard and you choose to comply with the other standard as allowed by Subpart MMM, your

affected source will need to comply by the compliance date of that standard. See “What provisions

in this rule overlap provisions in other rules?” for more information. 

Some additions to an existing source may

be subject to existing source standards and

others may be subject to new source

standards. See “What is an affected

source?” for more information.
9

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Initial Notification

Report of

Relevancy

(§63.1368(b)) &

(§63.9(b)(2))

Precompliance

Plan

(§63.1368(e))

Compliance

Extension Request

(§63.1364(a)(2)(i))

Compliance Date

(§63.1364(a)(l))

Site-Specific Test

Plan and

Notification of

Planned

Performance Test

(§63.1368(m))

Initial Notification

of Compliance

Status (NOCS)

(§63.1368(f))

Periodic Report

(§63.1368(g))

Startup,

Shutdown,

Malfunction Report

(§63.1368(i))

Submit by

10/23/99

or within 120

days after source

becomes subject

to rule.

Submit by

12/23/01 or

6 months before

compliance date.

Submit no later

than 2/23/02 or

120 days before

compliance date.

Must comply by

6/23/02

Submit 60 days

before

Performance Test*

Submit by

11/20/02 or 150

days after

compliance date

or initial startup

Submit by 7/20/03

or 240 days after

initial NOCS' due

date and every 6

months thereafter.

Submit by 7/20/03

or 240 days after

initial NOCS' due

date and every 6

months

thereafter.**

If you are submitting a(n) ...

Then ...

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

the submittal date of the Notification of Compliance Status Report, or within 180 days after startup of an existing affected source if the source begins

operation after the effective date of the rule. (§63.7(a)(2)(iii))

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

*

**

Existing Affected Sources

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

Pesticide Active Ingredient (PAI) Rule

Effective Date June 23, 1999

Figure 2-1. Compliance Timeline and Reporting Requirements for Existing Affected Sources.
10

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Initial Notification

Report of Relevancy

(§63.1368(b)),

(§63.9(b)(2)), and

(§63.5(d)(1)

Precompliance

Plan

(§63.1368(e))

Compliance Date

(§63.1364(b))

Site-Specific Test

Plan and

Notification of

Planned

Performance Test

(§63.1368(m))

Initial Notification

of Compliance

Status (NOCS)

(§63.1368(f))

Periodic Report

(§63.1368(g))

Startup,

Shutdown,

Malfunction Report

(§63.1368(i))

Submit by

10/23/99 or within

120 days after

source becomes

subject to rule.

Submit with the

application for

approval of

construction or

reconstruction.

Comply on 6/23/99

or upon startup,

whichever is later.

Submit 60 days

before

Performance

Tests*

Submit 150 days

after effective date

or initial startup.

Submit 240 days

after initial NOCS'

due date and

every 6 months

thereafter.

Submit 240 days

after initial NOCS'

due date and

every 6 months

thereafter.**

If you are submitting a(n) ...

Then ...

Performance tests shall be conducted within 180 days after the effective date, or within 180 days after startup of a new source that has an initial startup

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

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

*

**

New and Reconstructed Affected Sources

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

Pesticide Active Ingredient (PAI) Rule

Effective Date June 23, 1999

Figure 2-2. Compliance Timeline and Reporting Requirements for New and Reconstructed Sources.
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What pesticide active ingredients are subject to the rule?

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

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

The materials subject to this rule depend on how they are used. You’re subject to Subpart MMM

if your material is all of the following:

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

5 for the definition of PAI)

• is “primarily used” as a PAI

Your materials aren’t subject to Subpart MMM if they meet any of the following criteria:

• inorganic compounds

• used to produce disinfectants, rodenticides, water purifiers, or any other end-use pesticide

product that’s not also used to produce an insecticide, herbicide, or fungicide end-use

pesticide product

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

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

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

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

is a PAI that’s subject to this rule.

• Primary product refers to the predominant product produced in a process unit group, and

is used to determine the applicable requirements for all PAI process units in the group.

How do I determine the primary use of a product?

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

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

used as a PAI [§63.1361].

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

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

Procedures to determine primary use

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

becomes a PAI process unit and is subject to Subpart MMM,

unless it is already subject to 40 CFR part 63, Subpart F (HON). 

If your process unit is subject to Subpart F, you must follow the

Subpart F requirements, not those in Subpart MMM.

What is a pesticide active ingredient (PAI)

process unit?

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

• a PAI

• an integral intermediate

Note: Integral intermediate is defined on page 13. You may designate as a PAI process unit any process unit

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

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

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

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

A PAI process unit isn’t linked to any specific piece of equipment. Rather, it applies to whatever

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

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

constitute one PAI process unit. Alternatively, you may have

“nondedicated” equipment that can be configured in different

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

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

reactor, centrifuge, or other equipment, but it’s the same PAI

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

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

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

does not constitute a PAI process unit. 

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

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

distillation units)

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

• connected piping and ducts

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

Recordkeeping of the PAI and

non-PAI uses is required if

non-PAI uses are the primary

use.

See “how is nondedicated

equipment regulated,” for more

information. 
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13

• associated components such as:

< pumps

< compressors

< agitators

< pressure relief devices

< sampling connection systems

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

< valves with process fluid on both sides

< connectors

< instrumentation systems

What is an integral intermediate?

An integral intermediate is a compound that meets all of the following criteria [§63.1361]:

C it’s further processed or modified in one or more additional chemical reaction steps to

produce a PAI

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

PAIs

C it’s not stored before the next reaction step (see next paragraph)

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

An intermediate is stored if it’s discharged to a storage vessel, and it meets any of the following

conditions [§63.1361]:

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

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

the storage vessel

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

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

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

equipment can’t be shared by the two processing areas
DRAFT

14

How is “nondedicated” equipment regulated?

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

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

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

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

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

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

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

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

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

determine applicability based on the

following alternative procedure

[§63.1360(h)]:

Î First, categorize the

nondedicated equipment

into one or more process unit groups (see the definition of process unit group)

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

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

with either Subpart MMM or another applicable MACT rule under either of the

following conditions:

< if any product produced in the process unit group is subject to the pharmaceuticals

MACT rule (Subpart GGG of 40 CFR part 63), you may elect to comply with

Subpart GGG [§63.1360(h)(1)] 

< if the primary product of a process unit group is a material that’s subject to another

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

comply with that other subpart [§63.1360(h)(2)].

Note: Your primary product is the product you expect to produce for the greatest operating time in the 5-year

period following the compliance date or the initial startup of the process unit group, whichever is later. 

Alternatively, if you expect the operating time to be the same for two or more process units, your primary

product is the product that you expect to produce the greatest amount of on a mass basis [§63.1360(h)(3)].

The purpose of this alternative for nondedicated equipment is to

minimize the possibility for overlap between Subpart MMM and

other MACT standards (e.g., pharmaceuticals, polymers and

resins, etc.) for equipment used in multiple process units.
DRAFT

15

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

the other product(s) are not limited to

pharmaceuticals. In these situations, you must

consult the rule(s) that apply to any other products to

determine the requirements that apply when you use

the equipment to produce those products.

How do I know if a storage vessel is

part of a PAI process unit?

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

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

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

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

vessels:

• storage vessels in tank farms

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

from) two or more processes

• storage vessels for which the use varies or changes

• storage vessels that are subject to existing MACT standards

If the storage vessel is already subject to another 40 CFR part 63 rule on June 23, 1999, the

storage vessel will belong to the process unit subject to the other rule [§63.1360(f)(1)].

What requirements apply during periods of startup, shutdown, and

malfunction?

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

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

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

otherwise applies

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

§63.1367(a)(3)

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

§63.1368(i)

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

emission limits to be exceeded, except in either of the following circumstances [§63.1363(e)(3)]:

• the control equipment is malfunctioning

Exceptions to the Subpart GGG provision

are listed in §63.1360(h)(1).

These procedures are

essentially the same as those

in the HON.
DRAFT

16

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

unit.

Note: During a startup, shutdown, or malfunction, you are required to implement, to the extent reasonably

available, means to prevent or minimize excess emissions. You must describe the measures you’ll take to

minimize emissions (e.g., identify control devices, work practices, pollution prevention measures, etc.) in your

startup, shutdown, and malfunction plan [§63.1363(e)(4)].

What provisions in this rule overlap provisions in other rules?

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

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

If, for the following emission

point...

Subpart MMM overlaps with the

following rule... Then ...a

All emission points Other MACT rules in 40 CFR

part 63 (e.g., the HON,

pharmaceuticals, etc.)

• Choose, to the extent the subparts are

consistent, under which subpart you’ll

maintain your records and reports

• For 40 CFR 63, Subpart A (General

Provisions) check Table 1 of Subpart

MMM final rule to determine which

Subpart A requirements apply to your

emission point

Equipment leaks Subpart I in 40 CFR part 63 Comply with either the provisions of

Subpart MMM or the provisions of

Subpart H of 40 CFR part 63

Storage vessels

(Group 1 and 2)

Subpart Kb of 40 CFR part 60

[NSPS]

Comply only with the provisions of

Subpart MMM

Process vents Subparts III, NNN, or RRR of

40 CFR part 60 [NSPS]

Comply only with Subpart MMM if the

process vent subject to the other subpart is

controlled to 98 percent.

Otherwise, comply with both Subpart

MMM and Subparts III, NNN and RRR as

applicable.

Process vents, equipment

leaks, waste management

units

Subparts AA, BB, and CC of

40 CFR parts 264 and 265

[RCRA]

Comply either with the monitoring,

recordkeeping, and reporting requirements

in Subpart MMM, or the other subparts.

However, you must report all excursions as

required in §63.1368(g) of Subpart MMM

Wastewater streams 40 CFR parts 260 through 272

[RCRA]

Comply with whichever rule has the more

stringent control, testing, monitoring,

recordkeeping, and reporting requirements
DRAFT

17

a

Identify which subpart you’ve chosen to comply with in your Notification of Compliance Status Report as required

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

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

Note: The applicability requirements described in the section “How is nondedicated equipment regulated?” do

not constitute overlap because no other rule applies to the PAI process units within the process unit group. 

However, for some PAI process units in a process unit group, Subpart MMM specifies that compliance with

provisions in another MACT rule may be used to demonstrate compliance with the requirements of Subpart

MMM.

What is exempt from the rule?

Section 63.1360(d) specifies that the rule doesn’t apply to any of the following:

• research and development facilities

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

• ethylene production

• stormwater from segregated sewers

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

• spills

• water from safety showers

• noncontact steam boiler blowdown and condensate

• laundry water

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

only

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

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

equipment.)

In addition, under §63.1361, the following aren’t considered to be part of the PAI process unit:

• formulation of pesticide products

• QA/QC laboratories
DRAFT

18

Chapter 3 - Complying with requirements for process vents

What process vents are covered?

Subpart MMM covers all process vents that:

• are part of processes at an affected source

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

• are not exempt

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

“Group 2” process vents.

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

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

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

greater than 0.15 Mg/yr

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

greater than 6.8 Mg/yr. 

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

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

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

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

annual emissions are below the limit for Group 2 processes.

What process vents are exempt?

A vent isn’t considered to be either a Group 1 or Group 2 process vent if the undiluted and

uncontrolled emission stream released through the vent contains less than 20 ppmv HAP.

If your Group 1 process vents discharge to any of the

following control devices, they’re exempt from the initial

compliance demonstrations, monitoring provisions, and

associated recordkeeping and reporting requirements

under Subpart MMM [§§63.1362(l), 63.1365(a)(4), and 63.1366(b)(1)(ix)(B)]. However, all

The definition of process vent in

§63.1361 describes ways to determine

the HAP concentration..
DRAFT

19

other Subpart MMM provisions apply for these processes (e.g., requirements to determine

applicability and standards for storage tanks, wastewater, and equipment leaks).

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

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

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

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

266.

• A hazardous waste incinerator for which you’ve:

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

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

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

part 265.

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

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

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

At existing sources, compliance options are categorized by organic HAP emissions and HCl/Cl2

emissions. One set of standards applies to individual process

vents that meet certain criteria, and another set of standards

applies to all of the other process vents within the process. 

Standards for new sources apply only to the sum of all process

vents within a process.

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

Pollution prevention is another

option for process vents at

existing sources. 
DRAFT

20

TABLE 3-1. Compliance Options for Process Vents

If you have

a(n)...

And your process

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

Existing

source

Group 1 for

organic HAP

(>0.15 Mg/yr)

each “large” vent • reduce organic HAP emissions by

$98 percent (Option 1)

• reduce emissions to #20 ppmv as

TOC (Option 2)

• use a flare that meets the

requirements of §63.11(b)

(Option 3)

• use the alternative standard

(Option 4)

• continue reducing HAP emissions

by percentage achieved on or

before 11/10/97, if that amount is

$90 percent (Option 5)

any individual vent or any

combination of vents, excluding large

vents

• reduce emissions to #20 ppmv as

TOC (Option 2)

• use a flare that meets the

requirements of §63.11(b)

(Option 3)

• use the alternative standard

(Option 4)

the collective emissions from all

vents, excluding large vents, not

controlled by Option 2, Option 3, or

Option 4

reduce HAP emissions by $90 percent

(Option 6)

Group 1 for

HCl/Cl2

(>6.8 Mg/yr)

any individual vent or any

combination of vents

• reduce emissions to #20 ppmv

(Option 7)

• use the alternative standard

(Option 8)

the collective emissions from all vents

not controlled by Option 7 or

Option 8

reduce HCl/Cl2 emissions by

$94 percent (Option 9)

New source Group 1 for

organic HAP

(>0.15 Mg/yr)

any individual vent or any

combination of vents

• reduce emissions to #20 ppmv as

TOC (Option 2)

• use a flare that meets the

requirements of §63.11(b)

(Option 3)

• use the alternative standard

(Option 4)

the collective emissions from all vents

not controlled by Option 2, Option 3,

or Option 4

reduce organic HAP emissions by

$98 percent (Option 1)
DRAFT

TABLE 3-1. (cont’d)

If you have

a(n)...

And your process

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

21

Group 1 for

HCl/Cl2

(>6.8 Mg/yr and

#191 Mg/yr)

any individual vent or any

combination of vents

• reduce emissions to #20 ppmv

(Option 7)

• use the alternative standard

(Option 8)

the collective emissions from all vents

not controlled by Option 7 or

Option 8

reduce HCl/Cl2 emissions by

$94 percent (Option 9)

Group 1 for

HCl/Cl2

(>191 Mg/yr)

any individual vent or any

combination or vents

• reduce emissions to #20 ppmv

(Option 7)

• use the alternative standard

(Option 8)

the collective emissions from all vents

not controlled by Option 7 or

Option 8

reduce HCl/Cl2 emissions by $99

percent (Option 10)

New or

existing

source

Group 2 the process no control required, but recordkeeping

is required to demonstrate compliance

with the 0.15 Mg/yr threshold for

organic HAP emissions and the 6.8

Mg/yr threshold for HCl/Cl2 emissions
DRAFT

22

Organic HAP emissions for “large” vents - Existing Sources

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

HAP controls than other vents:

• Uncontrolled organic HAP emissions are >22.68 Mg/yr

• “Low flow” emission stream [i.e., the flow-weighted

average flow rate of the vent as calculated using equation

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

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

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

vents, although subpart MMM does not use this or any other term to describe these vents. For

these large vents, you have the following five control options for the organic HAP emissions:

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

Reduce total organic HAP emissions by at least 98 weight percent

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

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

compounds (TOC)

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

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

total organic HAP emissions

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

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

accordance with the alternative standard

Note: The outlet concentration is the same as for Option 2, but the alternative standard requires monitoring

with CEMS, whereas Option 2 requires monitoring of control device operating parameters.

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

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

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

November 10, 1997 

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

For all process vents within a process that don’t fit the definition of a “large” vent, you have four

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

Procedures to calculate

uncontrolled emissions are

specified in §63.1365(c)(2).
DRAFT

23

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

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

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

Reduce uncontrolled organic HAP emissions by at least 90 weight percent

HCl/Cl2 emissions - Existing Sources

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

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

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

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

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

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

with the alternative standard.

Note: The outlet concentration is the same as for Option 7, but the alternative standard requires monitoring

with CEMS, whereas Option 7 requires monitoring of control device operating parameters.

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

are not controlled by Option 7 or Option 8 using:

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

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

Organic HAP emissions - New Sources

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

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

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

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

using Option 2, Option 3, or Option 4.

HCl/Cl2

 emissions - New Sources

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

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

$191 Mg/yr.

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

$6.8 Mg/yr and <191 Mg/yr, you have three compliance options for the collective HCl/Cl2
DRAFT

24

emissions from all Group 1 process vents. You may control any individual process vent or any

combination of process vents using:

Option 7: reduce outlet concentration [§63.1362(b)(5)(ii)]

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

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

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

with the alternative standard.

Note: The outlet concentration is the same as for Option 7, but the alternative standard requires monitoring

with CEMS, whereas Option 7 requires monitoring of control device operating parameters.

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

are not controlled by Option 7 or Option 8 using:

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

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

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

process are $191 Mg/yr, you have three different compliance options. You may control any

individual process vent or any combination of process vents using:

Option 7: reduce outlet concentration [§63.1362(b)(5)(iii)]

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

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

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

with the alternative standard.

Note: The outlet concentration is the same as for Option 7, but the alternative standard requires monitoring

with CEMS, whereas Option 7 requires monitoring of control device operating parameters.

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

are not controlled by Option 7 or Option 8 using:

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

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

25

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

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

activities generate emissions from your processes.

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

from each activity in you process that generates emissions. The emissions for these activities are

also called “emission episodes.” You will need the uncontrolled emissions to determine whether

the process has Group 1 or Group 2 process vents. You also may need uncontrolled emissions to:

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

performed

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

• use in calculations of the percent reduction for a process

For batch processes, you sum the emissions from all of the emission episodes to calculate the mass

emitted per batch. For continuous processes, you sum the emissions from all of the emission

episodes to calculate the mass emitted per unit time (you may select any time period; 1 hour would

be reasonable).

Equations for calculating emissions from the following activities are included in

§63.1365(c)(2)(i)(B) of the rule:

• filling

• purging

• heating

• depressurization

• vacuum systems

• gas evolution

• air drying

If your emissions are due to activities other than listed

above, you must conduct an engineering assessment to

determine your emissions [§63.1365(c)(2)(ii)].

You may also request approval from the Administrator

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

Most of the calculations require you to estimate the HAP

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

options for estimating partial pressure. 

Information and procedures that may be

used in an engineering assessment are

described in §63.1365(c)(2)(ii).
DRAFT

26

Compliance with Group 2 emission limits

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

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

do this by calculating the uncontrolled emissions for each emission episode within the process,

summing the emissions for all emission episodes in the process, and multiplying by either of the

following: [§63.1365(c)(1)(i), (ii)]

• the estimated annual number of batches for batch processes

• the estimated operating hours per year for continuous processes

Options 1, 5, 6, 9, or 10: Compliance with percent reduction options

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

following:

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

• determine controlled emissions for these emission episodes

• sum the uncontrolled and controlled emissions and calculate the overall percent reduction

[§63.1365(c)(1)(iii), (iv)]

Note: If all emissions are controlled using a single control device, calculating the controlled emissions for

each emission episode is not necessary.

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

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

control device.

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

following:

• measure the outlet gas temperature from the condenser [§63.1365(c)(3)(iii)]

• calculate controlled emissions using the measured temperature in the appropriate equation

in §63.1365(c)(3)(iii)

Definition: Large control device means a device that

controls process vents, and the combined inlet HAP emissions

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

Definition: Small control device means a device that

controls process vents, and the combined HAP emissions into

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

27

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

following steps:

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

total annual inlet uncontrolled HAP emissions

• for a large control device, calculate the control

efficiency using a performance test

[§63.1365(c)(3)(ii)]

• for a small control device, calculate the control

efficiency using either a performance test or a

design evaluation [§63.1365(c)(3)(i)]

• calculate controlled emissions using the uncontrolled emissions and the calculated control

efficiency

Note: Both design evaluations and performance tests must be conducted under the most challenging conditions

for the device. The rule defines the most challenging conditions as either absolute or hypothetical peak-case

conditions. The procedures for determining the absolute or hypothetical peak-case conditions are described in

§63.1365(b)(ii).

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

§63.1365(a)(1).

Options 2 or 7: Compliance with outlet concentration options

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

applicable EPA method (e.g., M18 or M25A for TOC or M26 for HCl) under the most challenging

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

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

concentrations as follows:

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

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

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

If a small control device becomes a large

control device, you must then recalculate

the control efficiencies using the results of

a performance test.

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

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

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

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

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

28

Option 3: Compliance using a flare

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

following:

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

in §63.11(b)(4) of the General Provisions

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

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

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

Option 4 or 8: Compliance with the alternative standard

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

equipment operational on the compliance date (see the discussion of monitoring requirements for

the alternative standard).

In addition, if you intend to calibrate the monitor using the predominant HAP, you’ll have to use

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

What monitoring must I do for my process vents?

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

parameters. Typically, your monitoring requirements consist of all of the following:

• Identifying the parameter(s) to monitor

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

• Averaging the measured values for comparison with the limits

Each of these steps is discussed in more detail below.

What parameters must I monitor?

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

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

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

If the total inlet HAP emissions to your control device is <0.91 Mg/yr, you’re required to conduct

a periodic verification that the device is operating properly.
DRAFT

29

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

control device is working as designed. 

One example of an acceptable periodic verification demonstration is to conduct a daily

measurement of the same parameter(s) that must

be monitored for larger control devices, as

described below [§63.1366(b)(1)(i)].

Note: The periodic verification doesn’t apply for the alternative standard (Option 4 or 8); you must always

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

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

the outlet emission concentration or various operating parameters as described in

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

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

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

You describe the verification procedure you

intend to use in your Precompliance Plan.
30

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

If you’re

complying with

the following

compliance

options...

And the total inlet

HAP emissions to

your control

device are...

And you’re using

the following

control device...

Then you must monitor this

parameter...a At this frequency...

According to these

sections of the rule...

Options 1, 2, 5-7,

9, and 10

<0.91 Mg/yr any control device parameter(s) specified in your

approved precompliance plan that

demonstrate the control device is

operating as designed

at least once per day 63.1366(b)(1)(i)

Options 1, 2, 5-7,

9, and 10

(e.g., any %

reduction or

outlet

concentration 

$0.91 Mg/yr Scrubber liquid flow rate into scrubber or

pressure drop across the scrubber

every 15 minutes 63.1366(b)(1)(ii)

option, except the

alternative

standardb, Option

4 or 8)

also monitor the pH if the scrubber

uses a caustic solution to remove

acid gases

once per day 63.1366(b)(1)(ii)

Condenser condenser outlet gas temperature every 15 minutes 63.1366(b)(1)(iii)

Regenerative

carbon adsorber

• regeneration frequency (time

since the end of the last

regeneration), and

• each regeneration cycle 63.1366(b)(1)(iv)

• temperature to which the bed

is heated during regeneration,

and

• each regeneration cycle

• temperature to which the bed

is cooled, and

• within 15 minutes of

completing the cooling

phase of each

regeneration cycle

• regeneration stream flow, and • each regeneration cycle
31

TABLE 3-2. (cont’d)

If you’re

complying with

the following

compliance

options...

And the total inlet

HAP emissions to

your control

device are...

And you’re using

the following

control device...

Then you must monitor this

parameter...a At this frequency...

According to these

sections of the rule...

• check for bed poisoning

following manufacturer’s

specifications

• once per year

Nonregenerative

carbon adsorber

• operating time since last

replacement, or

• n/a

• monitor TOC concentration in

exhaust vent stream for

breakthrough

• daily, or at an interval no

greater than 20 percent of

the time needed to

consume the total

working capacity of the

carbon under peak-case

conditions

63.1366(b)(1)(v)(A)

Thermal

incinerator

temperature of gases exiting the

combustion chamber

every 15 minutes 63.1366(b)(1)(vii)

Catalytic

incinerator

temperature difference across the

catalyst bed

every 15 minutes 63.1366(b)(1)(viii)

Process heater

and boiler (except

those covered by

Option 4)

temperature of gases exiting the

combustion chamber

every 15 minutes 63.1366(b)(1)(ix)(A)

any other device identify applicable parameters and

request approval to use

part of the request for

approval

63.1366(b)(4)

Option 3

(e.g., using a

flare)

$0.91 Mg/yr Flare presence of pilot flame every 15 minutes 63.1366(b)(1)(vi)
32

TABLE 3-2. (cont’d)

If you’re

complying with

the following

compliance

options...

And the total inlet

HAP emissions to

your control

device are...

And you’re using

the following

control device...

Then you must monitor this

parameter...a At this frequency...

According to these

sections of the rule...

Option 4 or 8

(e.g., alternative

standard)

All Any control

device

outlet TOC concentration and/or

outlet HCl/CL2 concentration

using CEM meeting PS 8 or 9 of

Appendix B of Part 60

every 15 minutes 63.1366(b)(5)

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

monitored for flow in the bypass line every 15 minutes, or the bypass line valve must be secured in the closed position with a car seal or lock and key type

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

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

you may use a continuous emission monitor (CEM) meeting the requirements of Performance Specifications (PS) 8 or 9 of Appendix B of Part 60 to

monitor TOC and/or HCl/Cl2 every 15 minutes [§63.1366(b)(1)(x)].
DRAFT

33

How do I set monitoring parameter limits?

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

parameter is compared during the initial compliance

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

be associated with the most challenging conditions for the

control device, and meeting it will demonstrate ongoing

compliance at all times.

If you demonstrate initial compliance by conducting a

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

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

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

additional monitoring limits for less challenging conditions.

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

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

challenging operating conditions under which the

initial compliance determination is conducted. 

Maintaining the monitored scrubber flow above

this limit at all times demonstrates that the required

percent reduction is being met at all times. 

However, if the HAP emitted from one vent is

more soluble than the HAP emitted from other

vents (i.e., it is a period that doesn’t constitute the

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

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

still achieve the required control level.

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

performance test results with an engineering

assessment and/or manufacturers

recommendations. Your rationale for the specific

level(s) must be provided in your Precompliance

Plan.

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

of a pilot flame, can not vary over a range.

Monitoring limits for the alternative standard are defined in the standard itself, and you may not set multiple

limits when complying with the alternative standard.

The monitoring parameter limits and your

rationale for these limits are subject to

review and approval by the

Administrator.

You must record in a daily schedule or log the

points at which the parameter limit changes, and

at least one reading must be taken after each

change, even if the duration associated with that

limit is less than 15 minutes.

The Precompliance Plan must be submitted for

approval at least 6 months before the Compliance

date. See Chapter 8.
DRAFT

34

How may I average my monitoring parameter values?

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

average is any continuous 24-hour period of your choice - it doesn’t have to be from midnight to

midnight. 

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

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

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

Monitoring values taken during periods of no flow or when streams that aren’t subject to the rule

shouldn’t be considered in either the daily or block averages. To identify periods of no flow you

must use a flow indicator at the inlet (or outlet) of the control device [§63.1366(b)(2)(iii)].

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

for flares (option 3).

What records must I keep for my process vents?

To avoid repetition, all of your recordkeeping requirements are presented in Chapter 8. 

What reports must I submit for my process vents?

To avoid repetition, all of your reporting requirements are presented in Chapter 8. Requirements

specific to storage vessels are also shown in this section.
DRAFT

35

Checklists for Process Vent Inspections

Facility Name: ______________________________________________________

Facility Location: ______________________________________________________

Facility TRI ID #: ______________________________________________________

Inspector: ______________________________________________________

Date: ______________________________________________________

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

with the process vent requirements.

If you

follow...

And the total inlet HAP

emissions to the control

device are ...

And the process vent emission

streams are conveyed by a closedvent system to ...

Then use the

following

checklistsa:

Starting on

page ...

any option,

except 3, 4,

and 8

$ 0.91 Mg/yr a scrubber 3 6

a condenser 4 8

a regenerative carbon adsorber 5 9

a nonregenerative carbon adsorber 6 11

a thermal incinerator 7 12

a catalytic incinerator 8 13

a boiler or process heater with a

design heat input of < 44 

megawatts and for which the

emission stream is not introduced

with the primary fuel

9 15

3 $ 0.91 Mg/yr a flare 10 16

4 all any control device 11 17

any option,

except 4 and

8

< 0.91 Mg/yr any control device 12 19

a

 Checklists 1 and 2 apply for all options.
DRAFT

36

Checklist 1: Applicability (All Options)

Facility Name: ___________________________________________________________

Facility Location: ___________________________________________________________

Facility TRI ID #: ___________________________________________________________

Inspector: ___________________________________________________________

Date: ___________________________________________________________

Note: If you answer “yes” to either question 1 or question 2, don’t continue; your process

vent isn’t covered. If you answer “yes” to using any of the control devices in question 3,

don’t continue; you are exempt from the monitoring and associated recordkeeping and

reporting requirements. §63.1362(b)(2)(i), (3)(i), (4)(i), (5)(i), and (l), §63.1365(a)(4),

§63.1366(b)(1)(ix)(B)

Comments

1. Are the total uncontrolled organic HAP emissions from all

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

uncontrolled HCl/Cl2 emissions from all process vents in the

process # 6.8 Mg/yr?

G Yes G No

2. Is the HAP content of your emission stream < 20 ppmv? G Yes G No

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

control devices:

• a boiler or process heater burning hazardous waste for

which you’ve:

< been issued a final permit under 40 CFR part 270 and

are complying with requirements of 40 CFR part 266,

subpart H; or 

< certified compliance with the interim status

requirements of 40 CFR part 266, subpart H?

• a hazardous waste incinerator for which you’ve:

< have been issued a final permit under 40 CFR part

270 and are complying with the requirements of 40

CFR part 264, subpart O; or 

< have certified compliance with the interim status

requirements of 40 CFR part 265, subpart O?

• a boiler or process heater with a design heat input

$44 megawatts?

• a boiler or process heater for which the emission stream is

introduced with the primary fuel?

G Yes

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

G No
DRAFT

37

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

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements Comments

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

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

you done one of the following:

• used a flow indicator that takes a reading at least once every

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

• secured the bypass line valve in the closed position with a

car-seal or a lock-and-key type configuration? §63.1362(j)(2)

G Yes

G Yes

G No

G No

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

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

safety purposes are not subject to the monitoring requirements for

bypass lines. §63.1362(j)

2. If you secure the bypass line valve in the closed position as

specified in question 6, do you visually inspect the seal or closure

mechanism monthly to ensure the valve is maintained in the closed

position? §63.1362(j)(2)

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

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

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

§63.1367(f)(1)

• hourly flow indicator readings?

• times and durations of periods when the flow indicator is not

operating?

• times and durations of periods when the vent stream is diverted

from the control device?

G Yes

G Yes

G Yes

G No

G No

G No
DRAFT

Checklist 2: (cont’d)

Requirements for closed-vent systems (All Options)

38

B. Recordkeeping and Reporting Requirements Comments

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

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

records: §63.1367(f)(2)

• records that the monthly visual inspections of the seal or closure

mechanism have been done?

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

bypass line valve position has changed, or the key for a lock-andkey type lock has been checked out?

• records of any car-seal that has broken?

G Yes

G Yes

G Yes

G No

G No

G No

3. Are records retained for at least 5 years? §63.1367(a)(1) G Yes G No

4. Did you submit all of the following in your Periodic Report:

§63.1368(g)(2)(iii)

• records of all periods when the vent stream is diverted from the

control device?

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

bypass valve position has changed, or the key to unlock the bypass

line valve was checked out?

G Yes

G Yes

G No

G No
DRAFT

39

Checklist 3: Requirements for scrubbers (All options except 3, 4, and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements §63.1366(b)(1)(ii) and (2) Comments

1. Do you monitor scrubber liquid flow rate or pressure drop at least

once every 15 minutes during the period in which the scrubber is

controlling HAP from an emission stream?

G Yes G No

2. Is the monitoring device used to determine the pressure drop

certified by the manufacturer to be accurate to within a gage pressure

of ± 10 percent of the maximum pressure drop measured?

G Yes G No

3. Is the monitoring device used for measurement of scrubber liquid

flow rate certified by the manufacturer to be accurate to within ± 10

percent of the design scrubber liquid flow rate?

G Yes G No

4. Is the monitoring device calibrated annually? G Yes G No

5. Do you monitor the pH of the effluent scrubber liquid at least once a

day if the scrubber uses a caustic solution to remove acid emissions?

G Yes G No

6. Do you average the continuous readings over the operating day or

operating block?

G Yes G No

7. If flow to the scrubber can be intermittent, did you install a flow

indicator at the inlet or outlet of the scrubber and do you use it to

identify periods of no flow?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit all of the following in your Notification of

 Compliance Status Report:

• results of the initial performance test or design evaluation? 

§63.1368(f)(2)

• documentation to establish a minimum scrubber liquid flow

rate or pressure drop as a site-specific operating parameter? 

§63.1368(f)(3)

G Yes

G Yes

G No

G No

2. Do you keep daily (or more frequent) records of the pH of the

scrubber effluent if necessary? §63.1367(b)(1)

G Yes G No

3. Do you keep continuous records of the scrubber inlet flow rate or

pressure drop? §63.1367(b)(1)

G Yes G No
DRAFT

Checklist 3: (cont’d)

Requirements for scrubbers (All options except 3, 4, and 8)

B. Recordkeeping and Reporting Requirements Comments

40

4. Do you submit all of the following in your Periodic Reports if

exceedances or excursions are $1 percent of the total operating time

during the reporting period:

§63.1368(g)(2)

• all monitoring data for all operating days or blocks when the

average scrubber inlet flow rate or pressure drop is lower than

the minimum established in your NOCSR or operating permit?

• all monitoring data for all operating days or blocks when the

average pH value of the scrubber effluent is lower than the

minimum established in your NOCSR or operating permit?

• identification of all operating days when insufficient

monitoring data are collected?

G Yes

G Yes

G Yes

G No

G No

G No

5. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
DRAFT

41

Checklist 4: Requirements for condensers (All options except 3, 4, and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A Monitoring Requirements §63.1366(b)(1)(iii) and (2) Comments

1. Do you measure the condenser outlet gas temperature at least once

every 15 minutes during the period in which the condenser is

controlling HAP from an emission stream?

G Yes G No

2. Is the temperature monitoring device accurate to within ± 2 percent

of the temperature measured in degrees Celsius or ± 2.5EC,

whichever is greater?

G Yes G No

3. Is the temperature monitoring device calibrated annually? G Yes G No

4. Do you average the temperature readings over the operating day or

operating block?

G Yes G No

5. If flow to the condenser can be intermittent, did you install a flow

indicator at the inlet or outlet of the condenser and do you use it to

identify periods of no flow?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit all of the following in your Notification of

Compliance Status Report:

• results of the calculations to demonstrate initial compliance? 

§63.1368(f)(2)

• documentation to establish the maximum condenser outlet gas

temperature as a site-specific operating parameter?

§63.1368(f)(3)

G Yes

G Yes

G No

G No

2. Do you keep continuous records of the condenser outlet temperature? 

§63.1367(b)(1)

G Yes G No

3. Do you submit all of the following in your Periodic Reports if

exceedances or excursions are $1 percent of the total operating time

during the reporting period: §63.1368(g)(2)(ii)

• all monitoring data for all operating days or blocks when the

condenser average outlet temperatures that are higher than the

maximum established in your NOCSR or operating permit?

• identification of all operating days when insufficient monitoring

data are collected?

G Yes

G Yes

G No

G No

4. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
DRAFT

Checklist 4: (cont’d)

Requirements for condensers (All options except 3, 4, and 8)

42
DRAFT

43

Checklist 5: Requirements for regenerative carbon adsorbers (All options except 3, 4, and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements §63.1366(b)(1)(iv) and (2) Comments

1. For each regenerative cycle, do you monitor all of the following:

• operating time since last regeneration?

• temperature to which the bed is heated during regeneration?

• temperature to which the bed is cooled, measured within 15

minutes of completing the cooling phase?

• regeneration stream flow?

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

2. Is the temperature monitoring device accurate to within ± 2 percent

of the temperature measured in degrees Celsius or ± 2.5EC,

whichever is greater?

G Yes G No

3. Is the regeneration stream flow monitoring device capable of

recording the total regeneration stream flow to within ± 10 percent

of the established value (i.e., accurate to within ± 10 percent of the

reading)?

G Yes G No

4. Are the temperature and flow monitoring devices calibrated

annually?

G Yes G No

5. Do you conduct an annual check for bed poisoning in accordance

with manufacturer’s specifications?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit all of the following in your Notification of 

Compliance Status Report:

• results of the initial performance test or design evaluation?

§63.1368(f)(2)

• documentation to establish the regeneration stream flow, the

minimum carbon bed regeneration temperature, and the

maximum cooling phase temperature as site-specific operating

parameters? §63.1368(f)(3)

G Yes

G Yes

G No

G No

2. Do you keep records of the total regeneration stream mass or

volumetric flow for each carbon bed regeneration cycle?

§63.1367(b)(1)

G Yes G No
DRAFT

Checklist 5: (cont’d)

Requirements for regenerative carbon adsorbers (All options except 3, 4, and 8)

B. Recordkeeping and Reporting Requirements Comments

44

3. Do you keep records of the temperature to which the carbon bed is

heated during each carbon bed regeneration? §63.1367(b)(1)

G Yes G No

4. Do you keep records of the temperature to which the carbon bed is

cooled after each carbon bed regeneration? §63.1367(b)(1)

G Yes G No

5. Do you keep records of the operating time between regeneration? 

§63.1367(b)(1)

G Yes G No

6. Do you identify all of the following in your Periodic Reports if

exceedances or excursions are $1 percent of the total operating time

during the reporting period: §63.1368(g)(2)

• all regeneration cycles when the total regeneration stream mass

or volumetric flow is lower than the minimum flow 

established during your initial compliance demonstration?

• all regeneration cycles during which the temperature to which

the carbon bed is heated during regeneration is lower than the

minimum temperature established during your initial

compliance demonstration?

• all regeneration cycles during which the temperature to which

the carbon bed is cooled after regeneration is higher than the

maximum temperature established during your initial

compliance demonstration?

• all instances when the operating time between regeneration

exceeds the time interval established during your initial

compliance demonstration?

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

7. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
DRAFT

45

Checklist 6: Requirements for nonregenerative carbon adsorbers (All options except 3, 4, and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements §63.1366(b)(1)(v) and (2) Comments

1. Do you replace the carbon bed in the nonregenerative carbon

adsorption system with fresh carbon on a regular schedule based on

either of the following:

• monitor the outlet TOC concentration that indicates 

breakthrough?

• time interval established in your NOCS?

G Yes

G Yes

G No

G No

2. If you monitor the TOC concentration, do you take readings daily or

at an interval no greater than 20 percent of the time required to

consume the total carbon working capacity under peak-case

conditions?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit the results of the initial design evaluation in your

Notification of Compliance Status Report? 63.1368(f)(2)

G Yes G No

2. Do you identify in your Periodic Reports all instances when the

carbon bed is not replaced within the required time interval based on

either the outlet TOC concentration or the time period established in

your NOCSR or operating permit? §63.1368(g)(2)

G Yes G No

3. If you monitor the outlet TOC concentration, do you maintain

records of readings? §63.1367(b)(1)

G Yes G No

4. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
DRAFT

46

Checklist 7: Requirements for thermal incinerators (All options except options 3, 4, and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements §63.1366(b)(1)(vii) and (2) Comments

1. Do you measure the outlet gas temperature at least once every 15

minutes during the period in which the thermal incinerator is

controlling HAP from an emission stream?

G Yes G No

2. Is the temperature monitoring device accurate to within 

± 0.75 percent of the temperature measured in degrees Celsius

or ± 2.5EC, whichever is greater?

G Yes G No

3. Is the temperature monitoring device calibrated annually? G Yes G No

4. Do you average the temperature readings over the operating day or

operating block?

G Yes G No

5. If flow to the thermal incinerator can be intermittent, did you install

a flow indicator at the inlet or outlet of the thermal incinerator and

do you use it to identify periods of no flow?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit all of the following in your Notification of 

Compliance Status Report:

• results of the initial performance test or design evaluation? 

§63.1368(f)(2)

• documentation to establish the minimum outlet gas temperature

as a site-specific operating parameter? §63.1368(f)(3)

G Yes

G Yes

G No

G No

2. Do you keep continuous records of the outlet temperature?

§63.1367(b)(1)

G Yes G No

3. Do you submit all of the following in your Periodic Reports if

exceedances or excursions are $1 percent of the total operating time

during the reporting period: §63.1368(g)(2)

• all monitoring data for all operating days or blocks when the

average outlet temperature is lower than the minimum

temperature specified in your NOCSR or operating permit?

• identification of all operating days or blocks when insufficient

monitoring data are collected?

G Yes

G Yes

G No

G No
DRAFT

Checklist 7: (cont’d)

Requirements for thermal incinerators (All options except options 3, 4, and 8)

B. Recordkeeping and Reporting Requirements Comments

47

4. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
DRAFT

48

Checklist 8: Requirements for catalytic incinerators (All options except 3, 4, and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements §63.1366(b)(1)(viii) and (2) Comments

1. Do you measure the temperature of the gas stream immediately before

and after the catalyst bed at least once every 15 minutes during the

period in which the catalytic incinerator is controlling HAP form an

emission stream?

G Yes G No

2. Do you calculate the temperature difference across the catalyst bed at

least once every 15 minutes during the period in which the catalytic

incinerator is controlling HAP form an emission stream?

G Yes G No

3. Is the temperature monitoring device accurate to within ± 0.75 percent

of the temperature measured in degrees Celsius or ± 2.5EC, whichever

is greater?

G Yes G No

4. Is the temperature monitoring device calibrated annually? G Yes G No

5. Do you average the temperature readings over the operating day or

operating block?

G Yes G No

6. If flow to the catalytic incinerator can be intermittent, did you install a

flow indicator at the inlet or outlet of the catalytic incinerator and do

you use it to identify periods of no flow?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit all of the following in your Notification of

Compliance Status Report:

• results of the initial performance test or design evaluation?

§63.1368(f)(2)

• documentation to establish the minimum temperature of the gas

stream immediately before the catalyst bed and the minimum

temperature difference across the catalyst bed as site-specific

operating parameters? §63.1368(f)(3)

G Yes

G Yes

G No

G No

2. Do you keep continuous records of the temperature of the gas stream

upstream of the catalyst bed and the temperature difference across the

catalyst bed? §63.1367(b)(1)

G Yes G No
DRAFT

Checklist 8: (cont’d)

Requirements for catalytic incinerators (All options except 3, 4, and 8)

B. Recordkeeping and Reporting Requirements Comments

49

3. Do you submit all of the following in your Periodic Reports if

exceedances or excursions are $1 percent of the total operating time

during the reporting period: §63.1368(g)(2)

• all monitoring data for all operating days or blocks when the

average upstream temperature is lower than the minimum

temperature specified in your NOCSR or operating permit, or the

average temperature difference across the catalyst bed is lower

than the minimum temperature difference specified in your

NOCSR or operating permit?

• identification of all operating days or blocks when insufficient

monitoring data are collected?

G Yes

G Yes

G No

G No

4. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
DRAFT

50

Checklist 9: Requirements for a boiler or process heater (All options, except 3, 4, and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements §63.1366(b)(1)(ix) and (2) Comments

1. Do you monitor the temperature of the gases exiting the combustion

chamber at least every 15 minutes during the period in which the

boiler or process heater is controlling HAP from an emission stream?

G Yes G No

2. Is the temperature monitoring device accurate to within 

± 0.75 percent of the temperature measured in degrees Celsius

or ± 2.5EC, whichever is greater?

G Yes G No

3. Is the temperature monitoring device calibrated annually? G Yes G No

4. Do you average the temperature readings over the operating day or

operating block?

G Yes G No

5. If flow to the boiler or process heater can be intermittent, did you

install a flow indicator at the inlet or outlet of the boiler or process

heater and do you use it to identify periods of no flow?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit all of the following in your Notification of 

Compliance Status Report:

• results of the initial performance test or design evaluation? 

§63.1368(f)(2)

• documentation to establish the minimum combustion zone

temperature? §63.1368(f)(3)

G Yes

G Yes

G No

G No

2. Do you have continuous records of the combustion zone temperature? 

§63.1367(b)(1)

G Yes G No

3. Do you submit all of the following in your Periodic Reports if

exceedances or excursions are $1 percent of the total operating time

during the reporting period: §63.1368(g)(2)

• all monitoring data for all operating days or blocks when the

average combustion zone temperature is lower than the minimum

temperature specified in your NOCSR or operating permit?

• identification of all operating days or blocks when insufficient

monitoring data are collected?

G Yes

G Yes

G No

G No

4. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
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Checklist 10: Requirements for flares (Option 3)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

1. Monitoring Requirements §63.1366(b)(1)(vi) and (2) Comments

1. Do you monitor for the presence of the flare pilot flame at least once

every 15 minutes?

G Yes G No

2. Is the monitoring device calibrated annually? G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit all of the following in your Notification of 

Compliance Status Report:

• results of the initial visible emissions test? §63.1368(f)(2)

• the net heating value of gas being combusted and its exit velocity? 

§63.1368(f)(3)

G Yes

G Yes

G No

G No

2. Do you maintain records of the continuously monitored data? 

§63.1367(b)(1)

G Yes G No

3. Do you identify all of the following in your Periodic Reports if

exceedances or excursions are $1 percent of the total operating time

during the reporting period: §63.1368(g)(2)

• all periods when the flare pilot flame was absent?

• all periods when the monitor was not working?

G Yes

G Yes

G No

G No

4. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
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Checklist 11: Requirements for alternative standard (Option 4 and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements §63.1366(b)(2) and (5) Comments

1. Have you installed a CEMS to monitor the outlet TOC concentration

and/or outlet HCl and chlorine concentration at least once every 15

minutes during the period in which the control device is controlling

HAP from an emission stream?

G Yes G No

2. Is the TOC monitor installed, calibrated, and maintained to meet the

requirements of Performance Specifications 8 or 9 of appendix B of

part 60?

G Yes G No

3. Is the monitoring device calibrated at a minimum with quarterly

cylinder gas audits?

G Yes G No

4. If supplemental gases are introduced before the control device, is the

monitored concentration corrected?

G Yes G No

5. Is the CEMS data reduced to operating day or operating block

averages?

G Yes G No

6. If flow to the control device can be intermittent, did you install a flow

indicator at the inlet or outlet of the control device, and do you use it

to identify periods of no flow?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do your records show that you calibrate your monitor in accordance

with your quality control program? 

§§63.1366(b)(3) and 63.8(d)

G Yes G No

2. Have your recorded all maintenance and calibration checks performed

on the CEMS? §63.1367(b)(3)

G Yes G No
DRAFT

Checklist 11: (cont’d)

Requirements for alternative standard (Option 4 and 8)

B. Recordkeeping and Reporting Requirements Comments

53

3. Do you have all of the following records: §63.1367(a)(4)

• all required CEMS measurements (including monitoring data

recorded during unavoidable CEMS breakdowns and 

out-of-control periods)?

• the date and time of each period when the CEMS is inoperative

except for zero (low-level) and high-level checks?

• the date and time of each period when the CEMS is out of control

(e.g., calibration drift exceeds specification, CEMS fails cylinder

gas audit)?

• the date and start and end time of each period of excess emissions

and parameter monitoring exceedances occurring during startups,

shutdowns, malfunctions, and at other times?

• the nature and cause of any malfunction of your monitor (if

known), and corrective actions taken?

• the total process operating time during the reporting period?

• all procedures, including calibrations, that are part of your 

quality control program?

G Yes

G Yes

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

G No

G No

4. Do you have records indicating that you notified the Administrator at

least 60 days before conducting a performance evaluation of your

CEMS? §63.1368(d)

G Yes G No

5. Do you submit all of the following in your Periodic Reports if

exceedances or excursions are $1 percent of the total operating time

during the reporting period: §63.1368(g)(2)

• all monitoring data for all operating days or operating blocks when

the average TOC or HCl/Cl2 concentrations exceed 20 ppmv?

• identification of all operating days when insufficient monitoring

data are collected?

G Yes

G Yes

G No

G No

6. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
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Checklist 12: Requirements for any control devices that control vent streams containing total HAP

emissions less than 0.91 Mg/yr (All options except 4 and 8)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance. If your approved monitoring procedures are the same as those specified in the rule for a larger

control device, also fill out the appropriate checklist from among checklists 3 through 10.

A. Monitoring Requirements §63.1366(b)(1)(i) and (2) Comments

1. Do you periodically verify that the control device is operating properly

by following the procedures specified in your approved Precompliance

Plan?

G Yes G No

2. If the verification procedure includes monitoring a parameter more

than one time per day, do you average the daily readings?

G Yes G No

3. Do you calibrate any monitoring instruments according to procedures

in your approved Precompliance Plan?

G Yes G No

4. If flow to the control device can be intermittent, did you install a flow

indicator at the inlet or outlet of the control device and do you use it to

identify periods of no flow?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Did you submit a description of your daily or per batch verification

procedures in your Precompliance Plan? §63.1368(e)

G Yes G No

2. Do you submit all of the following in your Periodic Reports if the

exceedances or excursions are $1 percent of the total operating time

during the reporting period:

§63.1368(g)(2)

• all monitoring data for all operating days or blocks when the data

show the control device is not operating as designed?

• identification of all operating days or blocks when insufficient

monitoring data are collected?

G Yes

G Yes

G No

G No

3. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No
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DRAFT

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Chapter 4 - Complying with requirements for storage vessels

What storage vessels are covered?

Storage vessels that meet all of the following criteria are covered under Subpart MMM:

• meet the definition of a “Group 1” storage vessel [§63.1361]

• are determined to be part of a PAI process unit [§63.1360(f)] 

• aren’t exempt under the definition of storage vessel [§63.1361]

What storage vessels are exempt?

Any storage vessels meeting either of the following conditions aren’t subject to Subpart MMM:

• Group 2 storage vessels

• Vessels that aren’t part of a PAI process unit

Note: A Group 2 storage vessel is any vessel that doesn’t meet the definition of a Group 1 storage vessel.

In addition, your tank or other vessel isn’t considered to be a storage vessel (Group 1 or 2) if any

of the following apply [§63.1361]:

• it’s permanently attached to a motor vehicle, such as a truck, railcar, barge, or ship

• it’s designed to operate with a pressure in excess of 204.9 kilopascals and without

emissions to the atmosphere

• material stored in the vessel contains no organic HAP or contains organic HAP only as

impurities

• it’s a wastewater storage tank

• it’s a non-wastewater waste tank

• it’s a process tank

Definition: Impurity means a substance that is produced coincidentally with the

product(s), or is present in a raw material. An impurity does not serve a useful purpose

in the production or use of the product(s) and is not isolated.
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57

What is a “Group 1” storage vessel?

If your storage vessel meets any of the following criteria, it’s considered a “Group 1” storage

vessel: [§63.1361]

Your storage vessel is

at ... And has a capacity of...

And stores material with a maximum true

vapor pressure of...

an existing source $75 m3 $ 3.45 kPa

a new source $ 40 m3 $ 16.5 kPa

$ 75 m3 $ 3.45 kPa

Note: If you don’t wish to determine the maximum true vapor pressure of the material in a storage vessel,

then you must designate it as a Group 1 storage vessel [§63.1362(c)(1)].

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

Your storage vessel isn’t part of a PAI process unit (and is not part of the affected source) if it’s

subject to another MACT standard on June 23, 1999 [§63.1360(f)(1)].

Your storage vessel is part of a PAI process unit if either of the following apply:

C the input to the vessel from the PAI process unit is greater than or equal to the input from

any other PAI or non-PAI process unit

C the output from the vessel to the PAI process unit is greater than or equal to the output to

any other PAI or non-PAI process unit

Note: If the greatest input to (or output from) a shared storage vessel is the same for two or more process

units, including at least one PAI process unit, you may assign the storage vessel to any one of the PAI process

units. [§63.1360(f)(2)]

If the process unit(s) the storage vessel is used with varies from year to year, then you determine

the greatest input or output on either of the following:

C what you actually used the vessel for during the year preceding June 23, 1999 (i.e., for

existing sources)

C what you expect to use the vessel for in the 5 years after startup (i.e., for new storage

vessels or existing vessels that were not in operation for the year preceding June 23, 1999).

For storage vessels in tank farms, you use the same procedures described above to determine if

the storage vessel is part of a PAI process unit, except your analysis is limited to the process units
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58

for which there is no storage vessel in-between the storage vessel in the tank farm and the

associated processes.

You must reevaluate if your storage vessel is part of a PAI process unit after any of the following

occur:

C the storage vessel begins receiving material from (or sending material to) another process

unit

C the storage vessel ceases to receive material from (or send material to) a PAI process unit

C there is a significant change in the use of the storage vessel

What compliance options do I have for my storage vessels?

For any storage vessel covered under Subpart MMM, you have four compliance options:

Note: Compliance options for storage vessels are the same for new and existing sources.

Option 1: Use a fixed roof tank with an internal floating roof (IFR) [§63.1362(c)(2)(i)] 

Equip the storage vessel with a fixed roof and internal floating roof

Option 2: Install an external floating roof (EFR) [§63.1362(c)(2)(ii)]

Equip the storage vessel with an external floating roof

Option 3: Convert your external floating roof to an internal floating roof

[§63.1362(c)(2)(iii)]

Equip the storage vessel with an external floating roof converted to an internal floating roof

(i.e., install a fixed roof above an external floating roof)

Option 4: Use a control device that meets any of the following conditions: 

[§63.1362(c)(2)(iv)]:

 (A) Percent reduction [§63.1362(c)(2)(iv)(A)]

Equip the storage vessel with a closed vent system and a control device that reduces organic

HAP emissions by $95 percent (by weight)
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59

 (B) Reduce outlet concentration to #20 ppmv TOC [§63.1362(c)(2)(iv)(B)]

Equip the storage vessel with a closed vent system and a control device that reduces organic

HAP emissions to outlet concentrations of #20 ppmv as TOC

(C) A flare [§63.1362(c)(2)(iv)(C)]

Equip the storage vessel with a flare that meets the requirements of §63.11(b) (see the

Subpart A General Provisions)

(D) Use one of the following as a control device:

• A boiler or process heater with a design heat input of

44 megawatts or greater

• A boiler or process heater into which the emission

stream is introduced with the primary fuel

• An incinerator, boiler, or process heater that is

permitted under RCRA

(E) Use the alternative standard [§63.1362(c)(4)]

Use the alternative standard under §63.1362(c)(4), and route emissions from storage vessels

to a control device or series of control devices that achieve all of the following outlet

concentrations:

• #20 ppmv TOC (as calibrated on methane or the predominant HAP)

• #20 ppmv total HCl and Cl2

Note: The outlet concentration limits are the same for options 4B and 4E, but the alternative standard

requires monitoring with CEMS, whereas Option 4B requires monitoring of control device operating

parameters.

For option 4, you’re exempt from specification requirements during periods of planned routine maintenance

of the control device that don’t exceed 240 hr/yr [§63.1362(c)(5)].

How do I show initial compliance with the storage vessel requirements?

Subpart MMM contains different initial compliance requirements based on the compliance options

you choose.

These control devices are

exempt from initial compliance

demonstrations and monitoring

requirements.

[§63.1362(l) and

§63.1365(a)(4)(i)(ii)]
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Options 1, 2 or 3: Compliance using internal or external floating roofs

You demonstrate initial compliance when you use a floating roof by determining if you’re in

compliance with all of the following:

• floating roof design features

• operating requirements

• inspection and measurement requirements

 Initial compliance and monitoring requirements for storage vessels equipped with a floating roof

are specified in §63.119 and §63.120 of Subpart G of the HON as referenced from §63.1365(d)

and §63.1366. However, Subpart MMM designates different definitions and compliance dates as

follows: 

• the definition in §63.1361 applies when the term “storage vessel” is used in §§63.119 and

63.120.

• November 10, 1997 applies instead of December 31, 1992.

• June 23, 1999 applies instead of April 22, 1994.

• The compliance date specified in §63.1364 of Subpart MMM applies instead of the

compliance date in §63.100 of Subpart F

See Table 4-1 (page x) for your floating roof design and operating requirements You may be

subject to one or more of the requirements listed depending on the compliance options you choose. 

Initial inspections and measurements are discussed in the section “What monitoring must I do?”

later in this chapter.
61

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

If you’re

complying with ... 

And your roof has the following 

features...

Then you must meet these design

requirements... And also meet these operating requirements...

Option 1, 2, or 3

(Please note that

you have more

requirements for

these options

further in this

table)

the floating roof itself be floating on the liquid surface except when

being supported by the leg supports is allowed

be supported by leg supports only under the

following conditions:

• during initial fill

• after the vessel has been completely

emptied and degassed 

• before refilling

the process of filling, emptying, or refilling

must be continuous and be as soon as possible

automatic bleeder vents have gaskets be closed at all times except when the roof is

being floated off or landed on the leg supports

openings not in contact with IFRs or

EFRs (except for automatic bleeder

vents and rim space vents)

project below the liquid surface

rim space vents have gaskets set to open only in the following conditions:

• when the roof is being floated off the roof

leg supports 

• when the pressure beneath the rim seal

exceeds manufacturer's specifications

access hatches and gauge floats have a gasketed cover be closed at all times except for access

Option 1 openings in the IFR (except for leg

sleeves, automatic bleeder vents, rim

space vents, column wells, ladder

wells, sample wells, and stub drains)

have a cover or lid with a gasket be closed at all times except for access

sample wells have a slit fabric cover over at least

90 percent of the opening
62

TABLE 4-1. (cont’d)

If you’re

complying with ... 

And your roof has the following 

features...

Then you must meet these design

requirements... And also meet these operating requirements...

ladder wells have a gasketed sliding cover

penetrations in the IFR for fixed roof

columns

have either of the following:

• a flexible fabric sleeve seal 

• a gasketed sliding cover

Option 2 closure device between the vessel wall

and roof edge

have all of the following:

• there must be two seals 

• the primary seal must be a metallic shoe

or liquid-mounted seal

• both seals must completely cover the

space between the EFR and the vessel

wall

Option 1 or 3 closure device between the vessel wall

and the roof edge

any one of the following:

• a liquid-mounted seal

• a metallic shoe seal 

• a double seal
63

TABLE 4-1. (cont’d)

If you’re

complying with ... 

And your roof has the following 

features...

Then you must meet these design

requirements... And also meet these operating requirements...

Option 2 or 3 openings in the roof except for the

following:

• automatic bleeder vents

• rim space vents

• roof drains

• leg sleeves

be equipped with a gasketed cover or lid both of the following:

• keep the cover or lid closed except for

access

• cover on each access hatch and each gauge

float well must be bolted or fastened to be

air tight when closed

roof drains that empty into the stored

liquid

have a slotted membrane fabric cover over at

least 90 percent of the drain opening area

guide pole wells have either of the following:

• a gasketed sliding cover 

• a flexible fabric sleeve seal

unslotted guide poles have a gasketed cap on the end of the pole keep the cap closed except when gauging the

liquid level or taking liquid samples

slotted guide poles have a gasketed float or other device to close

off the liquid surface from the atmosphere

IFR = internal floating roof EFR = external floating roof

a Rule references for the information in Table 4-1 are: §63.119(b) for option 1, §63.119(c) for option 2, and §63.119(d) for option 3.
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64

Option 4: Compliance using a control device

 (A) Percent reduction

If you use the percent reduction option to comply with Subpart MMM, you must demonstrate

initial compliance by determining the efficiency of the control device based on either of the

following:

• performance test data [§63.1365(d)(1)(i)]

• design evaluation [§63.1365(d)(1)(ii)]

Performance test procedures:

If you send emissions from both a storage vessel and process vents to the same control device, you

may demonstrate initial compliance for the storage vessel using the results of the test you

conducted to show compliance with the process vent standards, provided that the test showed a

percent reduction $95 percent [§63.1365(d)(1)(i)(C)].

If you elect to conduct a test specifically for the emissions from the storage vessel, the test must be

conducted at the reasonably expected maximum filling rate [§63.1365(d)(1)(i)(A)].

Design evaluation procedures: 

If you choose to demonstrate initial compliance by conducting a design evaluation, you must

document how you demonstrate that your control device achieves the required control efficiency

when the storage vessel is filled at the reasonably expected maximum filling rate. The parameters

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

§63.1365(a)(1).

(B) Outlet concentration

If you’re complying with Subpart MMM using the outlet concentration option, you demonstrate

initial compliance by conducting a performance test to

show the outlet TOC concentration is #20 ppmv

[§63.1365(a)(6) and (d)(2)].

 (C) Flare

When a flare is the control device, you demonstrate initial compliance by doing all of the

following:

Sections 63.1365(b)(1) through (11) specify

test methods and procedures.

Sections 63.1365(b)(1) through (11) specify

test methods and procedures.
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65

• determining visible emissions using EPA Method 22 of 40 CFR part 60, Appendix A, for a

2-hour observation period [§63.1365(a)(3) and (d)(4)]. Flares must produce no visible

emissions, except for a period of 5 minutes during any 2 consecutive hours [§63.11(b)(4)

of subpart A]

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

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

General Provisions [§63.1365(a)(3) and (d)(4)]

(E) The alternative standard

When using the alternative standard in §63.1362(c)(4), your outlet TOC concentration must be

#20 ppmv, and the outlet HCl and Cl2 concentration must be #20 ppmv. 

You demonstrate initial compliance with these values by having the monitoring equipment

operational on the compliance date (see the discussion of monitoring requirements for the

alternative standard later in this chapter, [page x]. In addition, if you intend to calibrate the

monitor using the predominant HAP, you will have to use EPA Method 18 to determine the

predominant HAP [§63.1365(a)(5) and (d)(6)].

How do I comply when my control device needs repairs [options 4 (A,

B, C, and E)]?

Your storage vessel is exempt from Subpart MMM during periods of routine maintenance on the

storage vessel control device, provided that the routine maintenance does not exceed 240 hr/yr

[§63.1365(d)(7)].

You demonstrate initial compliance with the provisions by including anticipated periods of planned

routine maintenance for the first reporting period in the Notification of Compliance Status report

as discussed in “What reports must I submit”of this chapter.

What monitoring must I do for my storage vessels?

Your monitoring requirements depend on the compliance option you select. A summary of the

monitoring requirements for each compliance option follows:
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66

If you’re complying

using ...

Then your monitoring requirements

include ...

You must monitor at this frequency...

Option 1, 2 or 3 various inspections and measurements typically annually and every time the

storage vessel is emptied and

degassed

Option 4 (A or B) monitor one or more control device

operating parameters such as temperature

and flow rate

every 15 minutes

Option 4 (C) monitor presence of pilot flame every 15 minutes

Option 4 (E) monitor outlet TOC and, if appropriate,

HCl/Cl2 concentrations

every 15 minutes

Additional details for each option are provided below.

Options 1 or 3: Monitoring for internal floating roofs (IFRs)

If you comply with option 1 or 3, your monitoring requirements are as follows [§63.120(a) as

cross-referenced from §63.1365(d)(3)]:

If your IFR has

a ...

And you visually

inspect the ... Then monitor... For ...

According to these

sections of the rule...

Double-seal

system

(Option A)

IFR, the primary

and secondary seal,

gaskets, slotted

membranes, and

sleeve seals (if any)

each time the vessel

is emptied and

degassed,

and at least once

every 5 years after

the compliance date

• defects in the IFR §63.120(a)(3)(i) and

(a)(7)

• holes, tears, or other

openings in the seal

or seal fabric

• gaskets that no

longer close off the

liquid surface to the

atmosphere

• slotted membranes

with more than

10 percent open area
DRAFT

If your IFR has

a ...

And you visually

inspect the ... Then monitor... For ...

According to these

sections of the rule...

67

Double-seal

system

(option B)

secondary seal

through manholes

and roof hatches on

the fixed roof.

at least once every

12 months after

initial fill, or at least

once every 12

months after the

compliance date

• IFRs that aren’t

resting on the surface

of the liquid or the

leg supports

• liquid on the IFR

• detached seal

• holes or tears in the

seal fabric

• visible gaps between

the seal and the wall

of the storage vessel

§63.120(a)(3)(ii)

and (a)(4)

IFR, the primary

and secondary seal,

gaskets, slotted

membranes, and

sleeve seals (if any)

each time the vessel

is emptied and

degassed, and at

least once every 10

years after the

compliance date, the

primary and

secondary seals,

gaskets, slotted

membranes, and

sleeve seals (if any)

• defects in the IFR

• holes, tears, or other

openings in the seal

or seal fabric

• gaskets that no

longer close off the

liquid surface to the

atmosphere

• slotted membranes

with more than

10 percent open area

§63.120(a)(3)(iii)

and (a)(7)

a single-seal

system

IFR and the seal

through manholes

and roof hatches on

the fixed roof

at least once every

12 months after

initial fill, or at least

once every 12

months after

compliance date

• IFRs that aren’t

resting on the

surface of the liquid

or the leg supports

• liquid on the IFR

• detached seal

• holes or tears in the

seal fabric

• visible gaps between

the seal and the wall

of the storage vessel

§63.120(a)(2)(i) and

(a)(4)
DRAFT

If your IFR has

a ...

And you visually

inspect the ... Then monitor... For ...

According to these

sections of the rule...

68

IFR, the seal,

gaskets, slotted

membranes, and

sleeve seals (if any)

each time the

storage vessel is

emptied and

degassed, and at

least once every 10

years after

compliance date

• defects in the IFR

• holes, tears, or other

openings in the seal

or seal fabric

• gaskets that no

longer close off the

liquid surface to the

atmosphere

• slotted membranes

with more than

10 percent open area

§63.120(a)(2)(ii)and

(a)(7)

Note: Subpart MMM designates some different definitions and compliance dates than are used in §63.120 of

subpart G. These differences are noted in §63.1362(d)(2)(i), (iv), and (v).

Conditions found during annual inspections must be repaired within 45 days after performing the inspection

(unless you get an extension) [§63.120(a)(4)]. Conditions found in the inspection after emptying and degassing

the storage vessel must be repaired before refilling the storage vessel with organic HAP [§63.120(a)(7)].

Option 2: Monitoring for external floating roofs (EFRs)

If you comply with option 2, your monitoring requirements are as follows [§63.120(b) as crossreferenced from §63.1365(d)(3)]:

For EFRs with the

following features... Monitor the following... At this frequency ...a

According to this section

of the rule...

All EFRs visually inspect the roof,

seals, and fittings

each time the vessel is

emptied and degassed

§63.120(b)(10)

EFR with primary and

secondary seals

measureb gap between vessel

wall and primary seal

during the hydrostatic

testing of the vessel or

by the compliance date,

whichever occurs last,

and at least every 5

years thereafter

§63.120(b)(1)(i)

measureb gap between vessel

wall and secondary seal

annually §63.120(b)(1)(iii)

inspect integrity of primary

seal

every 5 years §63.120(b)(5)

inspect integrity of secondary

seal and inspect for proper fit

annually §63.120(b)(6)
DRAFT

For EFRs with the

following features... Monitor the following... At this frequency ...a

According to this section

of the rule...

69

EFR with liquidmounted or metallic

shoe primary seal and

no secondary sealc

measureb gap between vessel

wall and primary seal

annually §63.120(b)(1)(ii)

inspect integrity of primary

seal

annually §63.120(b)(5)(ii)

if a metallic shoe seal is

used, measure vertical

distance that one end of the

metallic shoe extends above

the liquid surface

annually §63.120(b)(5)(i)

a All measurements and inspections that must be performed annually or every 5 years must also be performed

before the compliance date.

b Seal gap measurements are made according to the method described in §63.120(b)(2) through (b)(4) of subpart

G.

c When secondary seal is added, both the primary and secondary seals must be measured within 90 days and at

the frequency specified for EFRs with primary and secondary seals [§63.120(b)(1)(iv)].

Note: Subpart MMM designates some different definitions and compliance dates than those used in §63.120 of

subpart G. These differences are noted in §63.1362(d)(2)(i), (iv), and (v).

If you think performing seal gap measurements and inspection of a vessel may be unsafe, then you may get an

extension to perform the measurements and inspection or empty and remove the storage vessel from service

[§63.120(b)(7)].

Subpart MMM also requires that you repair defects identified during inspections if you’re using

option 2. The types of conditions that you must repair and the time allowed for the repairs are as

follows:

When you’re performing ... And you find that... Then, repair the condition ...

visual inspection of the roof,

seals, and fittings after

emptying and degassing the

storage vessel

• the external floating roof has defects

• the primary or secondary seal has holes,

tears, or other openings in the seal or

seal fabric

• gaskets no longer close off the liquid

surface from the atmosphere

• the slotted membrane has more than

10 percent open area

before refilling the storage

vessel with organic HAP

[§63.120(b)(10)(i)]
DRAFT

When you’re performing ... And you find that... Then, repair the condition ...

70

seal gap measurement and

visual inspection for all

primary seals

• the total area of gaps between the vessel

wall and primary seal exceeds

212 cm2/meter of vessel diameter

• there are gaps between the vessel wall

and primary seal wider than 3.81 cm

• there are holes in the mechanical shoe

(if used), seal fabric, or seal envelope

within 45 days from the

measurement or inspection

(unless you get an extension)

[§63.120(b)(8)]

additional measurement for

metallic shoe primary seals

the metallic shoe seal doesn’t have one

end in the stored liquid and the other end

extending at least 61 cm above the stored

liquid surface

within 45 days from the

measurement or inspection

(unless you get an extension)

[§63.120(b)(8)]

seal gap measurement and

visual inspection for all

secondary seals

• the total area of gaps between the vessel

wall and secondary seal exceeds

21.2 cm2/meter of vessel diameter

• there are gaps between the vessel wall

and secondary seal wider than 1.27 cm

• the secondary seal does not completely

cover the space between the roof edge

and the space between the vessel wall

• there are holes, tears, or other openings

in the secondary seal or seal fabric

within 45 days from the

measurement or inspection

(unless you get an extension)

[§63.120(b)(8)]

Option 4: Control Devices

(A&B) Monitoring for percent reduction or outlet concentration

The monitoring requirements for your storage vessel percent reduction and outlet concentration

options are the same as the monitoring requirements for the process vent percent reduction and

outlet concentration options and vary depending on the control device that you use. Table 3-2 in

Chapter 3 summarizes the monitoring requirements for the percent reduction and outlet

concentration options for various control devices [§63.1366(b)(1)].

(C) Monitoring for flares

If you control storage vessel emissions with a flare, you must monitor the presence of the flame. 

Monitoring must be conducted at least once every 15 minutes. You must calibrate the monitoring

device used to detect the presence of the pilot flame annually [§63.1366(b)(1)(vi)].

(E) Monitoring for the alternative standard
DRAFT

71

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

the following:

• monitor the outlet TOC and HCl/Cl2 concentration at least once every 15 minutes

• adjust the monitored concentrations to account for supplemental gases, if any

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

appendix B of 40 CFR part 60

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

General Provisions

Note: You don’t have to monitor the total HCl and Cl2 concentration if you know that the control device does not

generate HCl/Cl2 [§63.1366(b)(5)].

Procedures for correcting the outlet concentrations to account for supplemental gases are specified in

§63.1365(a)(7).

(D) Monitoring for boilers or process heaters

You’re not required to do any monitoring if you route storage vessel emissions through a process

heater or boiler that meets the criteria for compliance option 4 (D).

What records must I keep for my storage vessels?

To avoid repetition, all of your recordkeeping requirements are presented in Chapter 8. 

What reports must I submit for my storage vessels?

To avoid repetition, all of your reporting requirements are presented in Chapter 8. Requirements

specific to storage vessels are also shown in this section.

Depending on the compliance option you choose, the following notifications may be required:

If you’re complying

with ... And you do the following ...

You must notify the

Administrator...

According to this section

of subpart G...

Option 1, 2 or 3 refill your storage vessels after visual

inspection of the roof, seals, and

fittings each time the vessel is

emptied and degassed

30 daysa before

refilling your vessel

§§63.120(a)(5) and

(b)(10)(ii)
DRAFT

If you’re complying

with ... And you do the following ...

You must notify the

Administrator...

According to this section

of subpart G...

72

perform seal gap measurements 30 days before 

performing the

measurements

§63.120(b)(9)

a If the inspection prior to refilling is unplanned, the notification may be made at least 7 days before refilling.

For Options 4 (A, B, C and E), you must also report the following:

When submitting your... Include information on the ...

According to the following

section of the rule...

Notification of Compliance

Status report

anticipated periods of planned routine

maintenance

§63.1368(f)(7)

Periodic reports actual periods of planned routine maintenance

during the reporting period

and

anticipated periods of planned routine

maintenance for the next reporting period

§63.1368(g)(2)(v)

Note: §63.122 of subpart G contains additional reporting requirements for storage vessels. These reporting

requirements were inadvertently omitted from the text of Subpart MMM published on June 23, 1999. However,

Subpart MMM will be revised before the compliance date to include the §63.122 reporting requirements for

storage vessels.
DRAFT

73

Checklists for Inspection of Storage Vessels

Facility Name: 

Facility Location:

Facility TRI ID #:

Inspector:

Date:

There are five checklists for storage vessels. The table below explains which inspection

checklists you should use for storage vessels.

If you follow ... For a storage vessel with...

Then use the

following

checklistsa ...

Starting on

page ...

Option 1 a fixed roof and an internal floating

roof

2

Option 2 an external floating roof 3

Option 3 an external floating roof converted to an

internal floating roof

4

Option 4(A or B) a closed-vent system and control device

that reduces emissions $95% by weight

or reduces outlet concentrations #20

ppmv as TOC

Chapter 3,

checklists 3 through

9, as applicable

Option 4(C) a flare Chapter 3,

checklist 10

Option 4(E) emissions routed to a control device to

meet the alternative standard

5

a

 Checklist 1 applies for all options.
DRAFT

74

Checklist 1: Applicability (All Options)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance. If the requirement is not applicable (N/A), leave blank.

Comments

1. Does your tank or vessel meet the definition of a storage

vessel? §63.1361

G Yes G No

2. Is your storage vessel part of a PAI process unit? §63.1360(f) G Yes G No

3. Did you designate the storage vessel as a Group 1 vessel, or

did your determine that the vessel meets Group 1 criteria?

§63.1362(c)(1)

G Yes G No
DRAFT

75

Checklist 2: Requirements for a storage vessel with an internal floating roof (Option 1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance. If the requirement is not applicable (N/A), leave blank.

A. Monitoring and Inspection Requirements §63.120(a) as cross-referenced from

§63.1365(d)(3) Comments

Note: The monitoring requirements include visual inspections and measurements. Questions 3-5 apply for all

visual inspections. Questions 5-15 apply only for visual inspections performed each time the vessel is

emptied and degassed.

1. If the storage vessel is equipped with a single-seal system: 

§63.120(a)(2)

• Do you visually inspect the IFR and seal at least once every

12 months? 

G Yes G No

• Do you visually inspect the IFR, the seal, gaskets, slotted

membranes, and sleeve seals (if any) each time the storage

vessel is emptied and degassed, and at least once every 10

years?

G Yes G No

2. If the storage vessel is equipped with a double-seal system, do

either of the following apply: §63.120(a)(3)

• Do you visually inspect the IFR, the primary seal, the

secondary seal, gaskets, slotted membranes, and sleeve seals

(if any) each time the storage vessel is emptied and

degassed, and at least once every 5 years?

G Yes G No

• Do you visually inspect the IFR and the secondary seal at

least once every 12 months, and do you visually inspect the

IFR, the primary seal, the secondary seal, gaskets, slotted

membranes, and sleeve seals (if any) each time the vessel is

emptied and degassed, and at least once every 10 years?

G Yes G No

3. Does the floating roof float on the liquid surface? 

§63.120(a)(4) and (7)

Note: The roof is not required to be floating on the liquid

surface during initial filling, after the vessel has been

completely emptied and degassed, and when completely

emptied before being refilled.

G Yes G No

4. Is the IFR in good condition (i.e., free of defects such as

corrosion or pools of standing liquid)? §63.120(a)(4) and (7)

G Yes G No
DRAFT

Checklist 2: (cont’d)

Requirements for a storage vessel with an internal floating roof (Option 1)

A. Monitoring and Inspection Requirements §63.120(a) as cross-referenced from

§63.1365(d)(3) Comments

76

5. Inspect the seal(s) §63.120(a)(4) and (7)

• Is the seal attached to the IFR?

• Is the seal or seal fabric free of holes, tears, or other

openings?

• Does the seal make continuous contact with the wall of the

storage vessel (i.e., no visible gaps between the seal and

wall)?

G Yes

G Yes

G Yes

G No

G No

G No

6. Is the IFR equipped with a liquid-mounted seal, metallic shoe

seal, or a double seal? §63.119(b)(3)

G Yes G No

7. Inspect deck openings

• If the IFR is non-contact, do the openings in the IFR project

below the stored liquid surface (except automatic bleeder

and rim space vents)? §63.119(a)(5)(i)

• Is each opening in the IFR equipped with a gasketed cover

(except automatic bleeder vents, rim space vents, column

wells, ladder wells, sample wells, and stub drains)? 

§63.119(a)(5)(ii)

• Is each cover on an IFR opening closed (unless open for

access)? §63.119(a)(6)

• Are covers on each access hatch and automatic gauge float

fastened air-tight when closed? §63.119(a)(6)

• Do gaskets on IFR opening covers close off the liquid

surface from the atmosphere? §63.120(a)(7)

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

8. Inspect automatic bleeder vents

• Are the automatic bleeder vents closed (unless the roof is

being floated off or landed on the roof leg supports)? 

§63.119(a)(4)

• Are the automatic bleeder vents gasketed? 

§63.119(a)(5)(iv)

• Do the gaskets close off the liquid surface from the

atmosphere? §63.120(a)(7)

G Yes

G Yes

G Yes

G No

G No

G No
DRAFT

Checklist 2: (cont’d)

Requirements for a storage vessel with an internal floating roof (Option 1)

A. Monitoring and Inspection Requirements §63.120(a) as cross-referenced from

§63.1365(d)(3) Comments

77

9. Inspect rim space vents

• Are the rim space vents closed except when either: 

§63.119(a)(6)

< the roof is being floated off the roof leg supports ?

< the pressure beneath the rim seal exceeds the

manufacturer’s recommended setting?

• Are the rim space vents gasketed? §63.119(a)(5)(v)

• Do the gaskets close off the liquid surface from the

atmosphere? §63.120(a)(7)

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

10. Does each sample well have a slit fabric cover over at least

90 percent of the opening? §63.119(a)(5)(iii) and

§63.120(a)(7)

G Yes G No

11. Does each ladder well have a gasketed sliding cover? 

§63.119(a)(5)(vi)

G Yes G No

12. Does each column well supporting the fixed roof have either a

flexible fabric sleeve seal or gasketed sliding cover? 

§63.119(a)(5)(vii)

G Yes G No

13. Do ladder and column well gaskets close off the liquid surface

to the atmosphere? §63.120(a)(7)

G Yes G No

l4. If flexible fabric sleeve seals are used for column wells, are the

fabric sleeves free of defects such as holes, tears, or gaps? 

§63.120(a)(7)

G Yes G No

15. If repairs were needed, did you complete them before refilling

the storage vessel?

G Yes G No

B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross

referenced by §§ 63.1367(??) and 63.1368(g)(2)(??) Comments

Note: There are reporting and recordkeeping requirements for visual inspections. 

1. Did you record the occurrence of each visual inspection? 

§63.123(c)

G Yes G No

2. Do you maintain all records for 5 years? §63.1367(a)(1) G Yes G No
DRAFT

Checklist 2: (cont’d)

Requirements for a storage vessel with an internal floating roof (Option 1)

B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross

referenced by §§ 63.1367(??) and 63.1368(g)(2)(??) Comments

78

3. If you detected a failure during an inspection, did you submit

all of the following information in your periodic report: 

§63.122(d)(1)(ii)

• date of the inspection?

• identification of all storage vessels with failures?

• description of the failures?

• either the date and nature of repairs made or the date the

vessel was emptied (if the vessel was not already empty)?

G Yes 

G Yes

G Yes

G Yes

 

G No

G No

G No

G No

4. If your periodic report in “3” shows that you made a repair

more than 45 days after the failure was found, does your next

periodic report include documentation of the use of up to two

30-day extensions and the following information: 

§63.122(d)(1)(iii)

• identification of the storage vessel?

• description of the failure?

• documentation that alternate storage capacity was

unavailable?

• schedule of actions taken to make repairs or empty the

vessel as soon as possible?

• date the storage vessel was emptied and nature of and date

repair was made?

G Yes 

G Yes

G Yes

G Yes 

G Yes

G No

G No

G No

G No

G No

5. If you refilled a storage vessel after it was emptied and

degassed, did you submit a report notifying the Administrator

at least 30 days before the vessel was refilled? §63.120(a)(5)

G Yes G No
DRAFT

79

Checklist 3: Requirements for a storage vessel with an external floating roof (Option 2)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring and Inspection Requirements §63.120(b) as cross-referenced from

§63.1365(d)(3) Comments

Note: The monitoring requirements include visual inspections and seal gap measurements. 

1. Do you measure the seal gap between the vessel wall and the

primary seal at least every 5 years? §63.120(b)(1)(i)

G Yes G No

2. Do you measure the seal gap between the vessel wall and the

secondary seal at least once per year? §63.120(b)(1)(iii)

Note: If your EFR does not have a secondary seal,

§63.120(b)(1)(ii) specifies the seal gap measurements for the

primary seal must be once per year.

G Yes G No

3. Do you measure the seal gaps, if any, when the EFR is not

resting on the roof leg supports? §63.120(b)(2)(i)

G Yes G No

4. Do you measure the seal gaps, if any, around the entire

circumference of the vessel in each place where a

0.32 centimeter (c inch) diameter uniform probe passes freely

between the wall and the seal? §63.120(b)(2)(ii)

G Yes G No

5. Do you determine the total surface area of each gap using

probes of various widths to measure the gap accurately? 

§63.120(b)(2)(iii)

G Yes G No

6. If you determine that it is unsafe to perform the seal gap

measurements, do either of the following apply: §63.120(b)(7)

• Do you measure the gaps no later than 30 days after the

determination?

or

• Do you remove the vessel from service within 45 days after

the determination?

Note: You may use up to 2 extensions of the 45-day limit

provided you explain why it was unsafe to perform the seal gap

measurement or inspection, document that alternate storage

capacity is unavailable, and specify a schedule to ensure that

the vessel is emptied as soon as practical.

G Yes

G Yes

G No

G No
DRAFT

Checklist 3: (cont’d)

Requirements for a storage vessel with an external floating roof (Option 2)

A. Monitoring and Inspection Requirements §63.120(b) as cross-referenced from

§63.1365(d)(3) Comments

80

7. Do you repair the seals no later than 45 days after the seal gap

measurements indicate a failure (or empty the storage vessel)? 

§63.120(b)(8)

G Yes G No

8. Do you visually inspect the EFR, the primary seal, the

secondary seal, and fittings each time the vessel is emptied and

degassed? §63.120(b)(10)

G Yes G No

9. Does the EFR rest on the surface of the stored liquid? 

§63.120(c)(3)

Note: The roof is not required to be floating on the liquid

surface during initial filling, after the vessel has been

completely emptied and degassed, and when completely

emptied before being refilled.

G Yes G No

10. Is the EFR in good condition (i.e., free of defects such as

corrosion and pools of standing liquid)? §63.120(b)(10)(i)

G Yes G No

11. Is there a secondary seal installed above the primary seal? 

§63.120(b)(6)(i)

G Yes G No

12. Inspect deck openings.

• If the EFR is non-contact, do the openings in the EFR

project below the stored liquid surface (except automatic

bleeder and rim space vents)? §63.119(c)(2)(i)

• Is each opening in the EFR equipped with a gasketed cover

that forms a vapor-tight seal (except automatic bleeder

vents, rim space vents, roof drains, and leg sleeves)? 

§63.119(c)(2)(ii)

• Is each gasketed cover on any EFR opening closed (unless

open for access)?

• Are covers on each access hatch and gauge float well

fastened air-tight when closed? §63.119(c)(2)(iii)

• Do gaskets on EFR opening covers close off the liquid

surface from the atmosphere? §63.120(b)(10)(i)

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
DRAFT

Checklist 3: (cont’d)

Requirements for a storage vessel with an external floating roof (Option 2)

A. Monitoring and Inspection Requirements §63.120(b) as cross-referenced from

§63.1365(d)(3) Comments

81

13. Inspect automatic bleeder vents.

• Are the automatic bleeder vents closed (unless the roof is

being floated off or landed on the roof leg supports)? 

§63.119(c)(2)(iii)

• Are the automatic bleeder vents gasketed? 

§63.119(c)(2)(v)

• Do the gaskets close off the liquid surface from the

atmosphere? §63.120(b)(10)(i)

G Yes

G Yes

G Yes

G No

G No

G No

14. Inspect rim space vents.

• Are the rim space vents closed except when: 

§63.119(c)(2)(iv)

< the roof is being floated off the roof leg supports? 

< the pressure beneath the rim seal exceeds the

manufacturer’s recommending setting?

• Are the rim space vents gasketed? §63.119(c)(2)(v)

• Do the gaskets close off the liquid surface from the

atmosphere? §63.120(b)(10)(i)

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

15. Is each roof drain covered with a slotted membrane fabric that

covers at least 90 percent of the opening area? 

§63.119(c)(2)(vi)

G Yes G No

16. Is each unslotted guide pole well equipped with either a

gasketed sliding cover or a flexible fabric sleeve seal that closes

off the liquid surface from the atmosphere? §63.119(c)(2)(vii)

G Yes G No

17. Does each unslotted guide pole have on it’s end a closed 

gasketed cap that closes off the liquid surface from the

atmosphere (except when gauging the liquid level or taking

liquid samples)? §63.119(c)(2)(viii)

G Yes G No

18. Does each gauge hatch and sample well have a closed gasketed

cover that closes off the liquid surface from the atmosphere

(except when open for access)? §63.119(c)(2)(xi)

G Yes G No
DRAFT

Checklist 3: (cont’d)

Requirements for a storage vessel with an external floating roof (Option 2)

A. Monitoring and Inspection Requirements §63.120(b) as cross-referenced from

§63.1365(d)(3) Comments

82

19. Inspect the secondary seal and perform seal gap measurements.

• Is the seal continuous and completely covering the space

between the EFR and vessel wall? §63.120(b)(6)(i)

• Are there no holes, tears, or other openings in the seal or

seal fabric? §63.120(b)(6)(ii)

• Are there no visible gaps between the seal and the wall of

the storage vessel such that: §63.120(b)(4)

< The total area of the gaps is less than 21.2 cm2 per meter

of vessel diameter?

< The maximum gap width between the vessel wall and

the seal does not exceed 1.27 cm?

G Yes

G Yes 

G Yes 

G Yes

G No

G No 

G No 

G No

20. Inspect the primary seal and perform seal gap measurements. 

• Is the primary seal either a metallic shoe or liquid-mounted

seal? §63.119(c)(1)(ii)

• Does the primary seal form a continuous closure that

completely covers the space between the vessel wall and

EFR such that: §63.120(b)(3)

< The total area of the gaps is less than 212 cm2 per meter

of vessel diameter?

< The maximum gap width between the vessel wall and

the seal does not exceed 3.81 cm?

• Is the seal fabric, seal envelope, or shoe (if a metallic shoe

seal is used) free of holes, tears, or other openings? 

§63.120(b)(5)(ii)

• If the primary seal is a metallic shoe seal:

< Does the lower end of the metallic shoe extend into the

stored liquid? §63.120(b)(5)(i)

< Does the upper end of the metallic shoe seal extend a

minimum vertical distance of 61 cm above the liquid

surface? §63.120(b)(5)(i)

< Is there a flexible coated fabric that spans the space

between the metal shoe and the vessel wall?

• If the primary seal is a liquid-mounted seal, is the seal in

contact with the liquid between the storage vessel wall and

EFR?

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes 

G Yes

G No

G No 

G No 

G No 

G No 

G No 

G No

G No
DRAFT

Checklist 3: (cont’d)

Requirements for a storage vessel with an external floating roof (Option 2)

83

B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross

referenced by §§ 63.1367(??) and 63.1368(g)(2)(??) Comments

1. Do your records indicate that you made seal gap measurements

annually for the secondary seal and every 5 years for the

primary seal? §63.120(b)(1)(i) and (iii)

G Yes G No

2. Did you record the date of the seal gap measurement, the raw

data obtained, and calculations performed? §63.123(d)

G Yes G No

3. Did you record the occurrence of each visual inspection after a

storage vessel was emptied and degassed?

G Yes G No

4. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No

5. If you detected a failure in the seals, did you include the

following in your periodic report: §63.122(e)(1) and (e)(3)(ii)

• the date and results of the inspection?

• the date and results of seal gap measurements?

• the date and nature of the repair or the date the vessel was

emptied?

G Yes

G Yes

G Yes

G No

G No

G No

6. If your periodic report in “5” shows that you made a repair

more than 45 days after the failure was found, does your next

periodic report include documentation of the use of up to two

30-day extensions and the following information: 

§63.120(b)(8) and §63.123(e)(2)

• identification of the storage vessel?

• description of the failure?

• documentation that alternate storage capacity was

unavailable?

• schedule of actions taken to make repairs or empty the

vessel as soon as possible?

• date the storage vessel was emptied and nature of and date

repair was made?

G Yes 

G Yes 

G Yes 

G Yes 

G Yes

G No

G No

G No 

G No 

G No

7. If you detected a failure during a visual inspection, did you

submit the following information about your visual inspection

in your periodic report: §63.123(e)(3)(ii)

• date of the inspection?

• identification of all storage vessels with failures?

• description of the failures?

• date and nature of repair ro date when the vessel was

emptied?

G Yes 

G Yes 

G Yes

G Yes

G No

G No

G No

G No
DRAFT

Checklist 3: (cont’d)

Requirements for a storage vessel with an external floating roof (Option 2)

B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross

referenced by §§ 63.1367(??) and 63.1368(g)(2)(??) Comments

84

8. If you refilled a storage vessel after it was emptied and

degassed, did you submit a report showing that you notified the

Administrator at least 30 days before the vessel was refilled? 

§63.120(b)(10)(ii)

G Yes G No
DRAFT

85

Checklist 4: Requirements for a storage vessel with an external floating roof converted to an

internal floating roof (Option 3)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring and Inspection Requirements §63.120(a) as cross-referenced from

§63.1365(d)(3) Comments

Note: The monitoring requirements include visual inspections and measurements.

Questions 3-5 apply to all inspections. Questions 6-14 apply only for visual inspections performed each

time the vessel is emptied and degassed.

1. If the storage vessel is equipped with a single-seal system: 

§63.120(a)(2)

• Do you visually inspect the floating deck and seal at least

once every 12 months? 

G Yes G No

• Do you visually inspect the floating deck, the seal, gaskets,

slotted membranes, and sleeve seals (if any) each time the

storage vessel is emptied and degassed, and at least once

every 10 years?

G Yes G No

2. If the storage vessel is equipped with a double-seal system, do

either of the following apply: §63.120(a)(3)

• Do you visually inspect the floating deck, the primary seal,

the secondary seal, gaskets, slotted membranes, and sleeve

seals (if any) each time the storage vessel is emptied and

degassed, and at least once every 5 years?

G Yes G No

• Do you visually inspect the floating deck and the secondary

seal at least once every 12 months, and do you visually

inspect the floating deck, the primary seal, the secondary

seal, gaskets, slotted membranes, and sleeve seals (if any)

each time the vessel is emptied and degassed, and at least

once every 10 years?

G Yes G No

3. Does the floating deck rest on the liquid surface? 

§63.120(a)(4) and (7) 

Note: The roof is not required to be floating on the liquid

surface during initial filling, after the vessel has been

completely emptied and degassed, and when completely

emptied before being refilled.

G Yes G No
DRAFT

Checklist 4: (cont’d)

Requirements for a storage vessel with an external floating roof converted to an internal floating roof

(Option 3)

A. Monitoring and Inspection Requirements §63.120(a) as cross-referenced from

§63.1365(d)(3) Comments

86

4. Is the floating deck in good condition (i.e., free of defects such

as corrosion or pools of standing liquid)? §63.120(a)(4) and

(7)

G Yes G No

5. Inspect the seal(s). §63.120(a)(4) and (7)

• Is the seal attached to the floating deck?

• Is the seal or seal fabric free of holes, tears, or other

openings?

• Does the seal make continuous contact with the wall of the

storage vessel (i.e., no visible gaps between the seal and

wall)?

G Yes

G Yes

G Yes

G No

G No

G No

6. Is the floating deck equipped with a liquid-mounted seal,

metallic shoe seal, or a double seal? §63.119(b)(3)

G Yes G No

7. Inspect deck openings.

• If the floating deck is non-contact, do the openings in the

floating deck project below the stored liquid surface (except

automatic bleeder and rim space vents)? §63.119(c)(2)(i)

• Is each opening in the floating deck equipped with a

gasketed cover that forms a vapor-tight seal (except

automatic bleeder vents, rim space vents, roof drains, and

leg sleeves)? §63.119(c)(2)(ii)

• Is each gasketed cover on any deck opening closed (unless

open for access)? §63.119(c)(2)(ii)

• Are covers on each access hatch and gauge float well

fastened air-tight when closed? §63.119(c)(2)(ii)

• Do gaskets on deck opening covers close off the liquid

surface from the atmosphere? §63.120(a)(7)

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

8. Inspect automatic bleeder vents.

• Are the automatic bleeder vents closed (unless the roof is

being floated off or landed on the roof leg supports)? 

§63.119(c)(2)(iii)

• Are the automatic bleeder vents gasketed? 

§63.119(c)(2)(v)

• Do the gaskets close off the liquid surface from the

atmosphere? §63.120(a)(7)

G Yes 

 

G Yes

G Yes

G No

 

G No

G No
DRAFT

Checklist 4: (cont’d)

Requirements for a storage vessel with an external floating roof converted to an internal floating roof

(Option 3)

A. Monitoring and Inspection Requirements §63.120(a) as cross-referenced from

§63.1365(d)(3) Comments

87

9. Inspect rim space vents.

• Are the rim space vents closed except when either: 

§63.119(c)(2)(iv)

< the roof is being floated off the roof leg supports?

< the pressure beneath the rim seal exceeds the

manufacturer’s recommending setting?

• Are the rim space vents gasketed? §63.119(c)(2)(v)

• Do the gaskets close off the liquid surface from the

atmosphere? §63.120(a)(7)

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

10. Is each roof drain covered with a slotted membrane fabric that

covers at least 90 percent of the opening area? 

§63.119(c)(2)(vi)

G Yes G No

11. Is each unslotted guide pole well equipped with either a

gasketed sliding cover or a flexible fabric sleeve seal that closes

off the liquid surface from the atmosphere? §63.119(c)(2)(vii)

G Yes G No

12. Does each unslotted guide pole have on it’s end a closed 

gasketed cap that closes off the liquid surface from the

atmosphere (except when gauging the liquid level or taking

liquid samples)? §63.119(c)(2)(viii)

G Yes G No

13. Does each gauge hatch and sample well have a closed gasketed

cover that closes off the liquid surface from the atmosphere

(except when open for access)? §63.119(c)(2)(ix)

G Yes G No

14. Did you complete any repairs of failures detected during

inspections before refilling the storage vessel?

G Yes G No

B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross

referenced by §§ 63.1367(??) and 63.1368(g)(2)(??) Comments

Note: There are reporting and recordkeeping requirements for visual inspections.

1. Did you record the occurrence of each visual inspection? 

§63.123(e)

G Yes G No

2. Do you maintain all records for 5 years? §63.1367(a)(1) G Yes G No
DRAFT

Checklist 4: (cont’d)

Requirements for a storage vessel with an external floating roof converted to an internal floating roof

(Option 3)

B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross

referenced by §§ 63.1367(??) and 63.1368(g)(2)(??) Comments

88

3. If you detected a failure during an inspection, did you submit

the following information in your periodic report: 

§63.122(d)(1)(ii)

• date of the inspection?

• identification of all storage vessels with failures?

• description of the failures?

• either the date and nature of repairs made or the date the

vessel was emptied (if the vessel was not already empty)?

G Yes 

G Yes

G Yes

G Yes

G No

G No

G No

G No

4. If your periodic report in “3” shows that you made a repair

more than 45 days after the failure was found, does your next

periodic report include documentation of the use of up to two

30-day extensions and the following information: 

§63.122(d)(1)(iii)

• identification of the storage vessel?

• description of the failure?

• documentation that alternate storage capacity was

unavailable?

• schedule of actions taken to make repairs or empty the

vessel as soon as possible?

• date the storage vessel was emptied and nature of and date

repair was made?

G Yes 

G Yes 

G Yes 

G Yes 

G Yes

G No

G No

G No 

G No

G No

5. If you refilled a storage vessel after it was emptied and

degassed, did you submit a report notifying the Administrator

at least 30 days before the vessel was refilled? §63.120(a)(5)

G Yes G No
DRAFT

89

Checklist 5: Requirements for a storage vessels meeting the alternative standard (Option 4E)

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements Comments

1. Did you install a CEMS to monitor and record the outlet TOC

concentration at least once every 15 minutes? §63.1366(b)(5)

G Yes G No

2. If you are using a combustion control device that generates

HCl, did you install a CMS to monitor and record the outlet

HCl concentration at least once every 15 minutes?

G Yes G No

3. Is the monitoring device calibrated at a minimum with

quarterly cylinder gas audits? §63.1366(b)(5)

G Yes G No

4. If supplemental gases are introduced before the control device,

is the monitored concentration corrected? §63.1366(b)(5)

G Yes G No

5. Is the CEMS data reduced to operating day or operating block

averages? §63.1366(b)(2)

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do your records show that you calibrate your monitor in

accordance with your quality control program?

§§63.1366(b)(3) and 63.8(d)

G Yes G No

2. Have your recorded any maintenance performed on the

CEMS?§63.1367(b)(3)

G Yes G No
DRAFT

Checklist 5: (cont’d)

Requirements for a storage vessels meeting the alternative standard (Option 4E)

B. Recordkeeping and Reporting Requirements Comments

90

3. Do you have records of: §§63.1367(a)(4) and 63.10(c)(1)-(14)

• All required CEMS measurements (including monitoring

data recorded during unavoidable CEMS breakdowns and

out-of-control periods)?

• The date and time of each period when the CEMS is

inoperative except for zero (low-level) and high-level

checks?

• The date and time of each period when the CEMS is out of

control (e.g., calibration drift exceeds specification, CEMS

fails cylinder gas audit)?

• The date and start and end time of each period of excess

emissions and parameter monitoring exceedances occurring

during startups, shutdowns, malfunctions, and at other

times?

• The nature and cause of any malfunction of your monitor (if

known), and corrective actions taken?

• The total process operating time during the reporting

period?

• All procedures, including calibrations, that are part of your

quality control program?

G Yes

G Yes

G Yes

G Yes

G Yes

G Yes 

G Yes

G No

G No

G No 

G No

G No

G No 

G No

4. Have you recorded all maintenance and calibration checks

performed on the CEMS? §63.1367(b)(3)

G Yes G No

5. Do you maintain records for 5 years? §63.1367(a)(1) G Yes G No

6. Did you notify the Administrator at least 60 days before

conducting a performance evaluation of your CEMS?

§§63.1368(d) and 63.8(e)(2)

G Yes G No

7. Did you include in your periodic report a description of the

routine maintenance planned for the control device for the next

reporting period and actually performed in the last reporting

period? §§63.1367(b)(6)(viii) and 63.1368(g)(2)(v)

G Yes G No

8. Do you submit all of the following in your periodic reports if

exceedances or excursions are $1 percent of the total operating

time during the reporting period: §63.1368(g)(2)

• all monitoring data for all operating days or operating

blocks when the average TOC or HCl/Cl2 concentration

exceeds 20 ppmv?

G Yes G No

• identification of all operating days when insufficient

monitoring data are collected?

G Yes G No
DRAFT

Checklist 5: (cont’d)

Requirements for a storage vessels meeting the alternative standard (Option 4E)

91
DRAFT

92

Chapter 5 - Complying with requirements for wastewater systems

What wastewater streams are covered?

Subpart MMM covers “Group 1” wastewater streams that are discarded from a PAI process unit

that is at an affected source. A “Group 1” wastewater stream is any wastewater stream that meets

either of the following conditions: [§63.1361]

• Is generated from a PAI process and contains either:

< contains an annual average concentration of Table 9 compounds of at least 5 ppmw and has an

average flow rate of 0.02 L/min or greater; or

Note: Table 9 compounds are those compounds listed on Table 9 of subpart G of the HON.

< contains a total concentration of Table 9 compounds of at least 10,000 ppmw at any flow rate.

• Is generated from a PAI process unit as a result of maintenance activities and contains at least

5.3 Mg of HAP per individual discharge event.

Subpart MMM also covers residuals removed from a Group 1 wastewater stream.

What types of wastewater components are covered?

Wastewater systems consist of the following three types of components, each with specific compliance

requirements:

• Waste management units

• Treatment processes

Note: treatment processes are a subset of waste management units that remove or destroy the organics in a

wastewater.

• Air pollution control devices

Definition. Residual means any liquid or solid material containing Table 9

compounds that is removed from a wastewater stream by a waste management

unit or treatment process that does not destroy organics.

Definition. Waste management unit means the equipment, structure(s), and/or

device(s) used to convey, store, treat, or dispose of wastewater streams or residuals.
DRAFT

93

What waste management units are covered?

Subpart MMM covers all of the following waste management units:

• wastewater tanks

• surface impoundments

• containers

• individual drain systems

• oil-water separators

What wastewater streams are exempt?

Any wastewater stream that meets any of the following conditions is not subject to Subpart MMM:

[§§63.132(a)(3) and 63.1360(d)(4)]

• Group 2 wastewater streams

• wastewater streams that are not part of a PAI process unit

• laundry water

• storwater from segregated sewers

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

• spills

• water from safety showers

• noncontact steam boiler blowdown and condensate

Note: A Group 2 wastewater stream is any wastewater stream that does not meet the definition of a Group 1

wastewater stream.

What are my compliance options for waste management units?

You have several emission suppression compliance options for the different types of waste

management units. 

Wastewater tanks

Definition. Wastewater tank means a stationary waste management unit that is

designed to contain an accumulation of wastewater and residuals and is

constructed primarily of nonearthen materials which provide structural support. 

Wastewater tanks used for flow equalization are included in this definition.
DRAFT

94

If your wastewater tank receives, manages, or treats a Group 1 wastewater stream or residual, you

have three compliance options if your wastewater tank meets either of the following: [§63.133(a)]

• tank size $151 m3 storing wastewater with maximum true vapor pressure $5.2 kPa

• tank size $75 m3 and <151 m3 storing wastewater with maximum true vapor pressure

$13.1 kPa

• tanks of any size storing any Group 1 wastewater stream or residual if the tank is used for

any of the following:

< heating wastewater

< treating by means of an exothermic reaction

< sparging

Your three compliance options for these wastewater tanks are:

Option 1: Use a fixed roof and control device [§63.133(a)(2)(i)].

Use a fixed roof and a closed-vent system that routes HAP vapors to control device.

Option 2: Use a fixed roof and an internal floating roof [§63.133(a)(2)(ii)]

Option 3: Use an external floating roof [§63.133(a)(2)(iii)]

For all other wastewater tanks that receive, manage, or treat a Group 1 wastewater system, you

must use a fixed roof tank (or any of the above options). [§63.133(a)(1)].

Surface impoundments

A waste management unit which is a natural topographic depression, manmade excavation, or

diked area formed primarily of earthen materials (although it may be lined with manmade

materials), which is designed to hold an accumulation of liquid wastes or waste containing free

liquids. A surface impoundment is used for the treatment, storing, or disposing of wastewater or

residuals, and is not an injection well. Examples of surface impoundments are equalization,

settling, and aeration pits, ponds, and lagoons. The control requirements of wastewater tanks

holding Group 1 process wastewater include the following:

1. Use a cover and a closed-vent system that routes organic HAP vapors to a control device. 

2. Use a floating flexible membrane which must float on the surface of the liquid and form a

continuous barrier over the entire surface area of the liquid. Requirements are given for the

fabrication of the membrane material. The flexible floating membrane must be installed

properly, have a closure device, and emergency cover drains. The closure device must
DRAFT

95

minimize exposure of HAP’s to the atmosphere, and be operated according to specified work

practices.

Containers

Any portable waste management unit that has a capacity greater than or equal to 0.1 cubic meters

in which a material is stored, transported, treated, or otherwise handled. Examples of containers

are drums, barrels, tank trucks, barges, dumpsters, tank cars, dump trucks, and ships. The control

requirements of containers holding Group 1 process wastewater are dependent on container

capacity. Table X provides the container capacity with a corresponding summary of control

requirements.

TABLE 5-1. Container Emissions Control Requirements

Capacity (m3) Control Requirements

0.1 # capacity < 0.42 Container must meet DOT specifications and testing requirements

under 49 CFR Part 178; or 

The cover and all openings must be maintained without leaks as

specified in §63.148 of subpart G

$ 0.42 The cover and all openings must be maintained without leaks as

specified in §63.148 of subpart G; and

Submerged fill pipes which meet specifications (e.g., fill pipe outlet

can extend no more than six inches or within two fill pipe diameters

of the bottom of the container) must be used; and 

Emissions of organic HAP’s must be reduced using an enclosure. 

The enclosure must be operated with a closed-vent system routed to

a control device.

Individual drain systems

Stationary waste management units used to convey wastewater streams or residuals to a waste

management unit or to discharge or disposal. The term includes: hard piping; all process drains

and junction boxes; and associated sewer lines, other junction boxes, manholes, sumps, and lift

stations conveying wastewater streams or residuals. The control requirements of individual drain

systems holding Group 1 process wastewater include the following:

1. Reduce emissions of organic HAP’s using a cover on each opening in the individual drain

system and, if vented, a closed vent system that routes organic HAP vapors to a process or

control device.

2. Reduce emissions of organic HAP’s using drains equipped with water seal controls or a tightly

fitting cap or plug which are operated according to specified work practices; and junction

boxes equipped with a cover and, if vented, a closed-vent system that routes organic HAP

vapors to a process or a control device. Junction boxes that are fed by gravity or are operated
DRAFT

96

with slight fluctuations in the liquid level are not required to use a closed-vent system routing

emissions to a process or control device. Instead the vent pipe is to be operated according to

specified equipment standards and work practices.

Oil-water separators

A waste management unit that separates and removes oils, scum, and solids from the wastewater

by gravity. Most of the separation occurs as the wastewater stream passes through a quiescent

zone in the unit where oils and scum with specific gravities less than water float to the top of the

aqueous phase, while heavier solids sink to the bottom. Some of the organic compounds contained

in the wastewater will partition to the oil phase and then can be removed with the skimmed oil,

leaving the separated water. The control requirements of oil-water separators holding Group 1

process wastewater include the following:

1. Reduce emissions of organic HAP’s using a fixed roof and a closed-vent system that routes

organic HAP vapors to a process or control device.

2. Reduce emissions of organic HAP’s using a floating roof. Where a floating roof is infeasible,

such as over a weir mechanism, a fixed roof and closed-vent system routed to a control device

may be used

3. Use an equivalent means of approved emission limitation.

What compliance options do I have for my treatment processes?

Treatment processes are techniques that remove or destroy the organics in a wastewater stream. 

Subpart MMM includes several compliance options and specifies how treatment processes may be

used to achieve compliance with one or more of the compliance options. The compliance options

may be used individually or in combination to achieve the required emission control.

For any new or existing sources, you have seven compliance options for wastewater streams:

Option 1: Reduce, by removal or destruction, the total concentration of Table 9 compounds

to less than 50 ppmw. [Note: cannot use biological treatment processes or dilution

with this option]

Option 2: Use a design steam stripper with specific design and operating requirements.

Option 3: Use a waste management unit or treatment process to reduce, by removal or

destruction, the total mass flow rate of Table 9 compounds by at least 99 percent.
DRAFT

97

Option 4: Use a waste management unit or treatment process to reduce, by removal or

destruction, the mass flow rate of each Table 9 compounds by at least the fraction

removal (Fr) values specified in Table 9.

Option 5: Use a waste management unit or treatment process to achieve the required mass

removal (RMR) of Table 9 compounds.

Option 6: Use a biological treatment unit that achieves a RMR of at least 95 percent for all

compounds listed on Table 9. [Note: all Group 1 and Group 2 wastewater streams

entering the biological treatment unit that are subject to subpart F must be included

in the demonstration of 95 percent removal]

Option 7: Treat the wastewater in a permitted Resource Conservation and Recovery Act

(RCRA) hazardous waste incinerator, a RCRA permitted process heater or boiler, 

or discharge to a properly permitted underground injection well.

For new sources, you have the following compliance option in addition to the six compliance

options identified above:

Option 8: Reduce the mass flow rate of Table 9 compounds from all wastewater streams by

99 percent if the total mass flow rate from the source is 2,100 Mg/yr or more.

How do I show initial compliance with the wastewater system

requirements?

What monitoring must I do for my wastewater systems?

Your monitoring requirements depend on the compliance option you select. Details for each

options are provided later in this chapter. A summary of the monitoring requirements for each

compliance option is as follows:

If you comply with ... your monitoring requirements include ... at this frequency...

options 1, 2 or 3 various inspections and measurements 

option 4 no monitoring required
DRAFT

98

Note 1: The PAI rule designates some different definitions and compliance dates than are used in

§63.120 of subpart G. These differences are noted in §63.1362(d)(2)(i), (iv), and (v).

Note 2: Conditions found during annual inspections must be repaired within 45 days after

performing the inspection (unless you get an extension) §63.120(a)(4)]. Conditions found in the

inspection after emptying and degassing the storage vessel must be repaired before refilling the

storage vessel with organic HAP {§63.120(a)(7)].

Note 2: If you think performing seal gap measurements and inspection of a vessel may be unsafe,

then you may get an extension to perform the measurements and inspection or empty and remove

the storage vessel from service [§63.120(b)(7)].

What records must I keep for my wastewater systems?

To avoid repetition in every chapter, all of your recordkeeping requirements are presented in

Chapter 8.

What reports must I submit for my wastewater systems?

To avoid repetition in every chapter, all of your reporting requirements are presented in Chapter 8.
DRAFT

99

Checklists for Wastewater System Inspections

Facility Name: ______________________________________________________

Facility Location: ______________________________________________________

Facility TRI ID #: ______________________________________________________

Inspector: ______________________________________________________

Date: ______________________________________________________

The table below explains which inspection checklists you should use for waste management

systems.

If you use a ... That is controlled using ... Then use these checklists ... Starting on

 page ...

wastewater tank a cover with a closed-vent system routed

to a control device (see next table)

Chapter 3, checklist 2 (see

next table) 

an external floating roof Chapter 4, checklist 3

a fixed roof with an internal floating roof Chapter 4, checklist 2

an external floating roof converted to an

internal floating roof

Chapter 4, checklist 4

surface

impoundments

a cover with a closed-vent system routed

to a control device (see next table)

2 and Chapter 3, checklist 2

(see next table) and

checklists 3 through 9 as

applicable

a floating flexible membrane cover 2

containers a cover 3

individual drains a cover and, if vented, routed to a process

or through a closed-vent system to a

control device(see next table)

4 and Chapter 3, checklist 2

(see next table) and

checklists 3 through 9 as

applicable

water seal controls or a tightly fitting cap

or plug for drains, tightly fitting solid

covers for junction boxes, and covers or

enclosures for sewer lines

4

oil-water

separators

a fixed roof and closed-vent system

routed to a control device (see next table)

5 and Chapter 3, checklist 2

(see next table) and

checklists 3 through 9 as

applicable

a floating roof 5
DRAFT

100

The table below explains which checklists you should use for control devices.

The wastewater system emission streams are conveyed by a closedvent system to the following control device ...Then use the following checklists from

Chapter 3:

a scrubber 3

a condenser 4

a regenerative carbon adsorber 5

a nonregenerative carbon adsorber 6

a thermal incinerator 7

a catalytic incinerator 8

a boiler or process heater with a design heat input of at least

44 megawatts or for which the emission stream is introduced with

the primary fuel

9

a flare 10

For the following compliance options... Then use these checklists:

Reduce the concentration of Table 9 compounds to less than 50 ppmw 1 and 2

Use a steam stripper with specific design and operating requirements 1 and 3

Reduce the mass flow rate of Table 9 compounds by at least 99 percent 1 and 4

Reduce the mass flow rate of Table 9 compounds by an amount equal to or

greater thant he fraction removed (Fr) value in Table 9

1 and 5

If a source using biotreatment for at least one wastewater stream that is

Group 1 for Table 9 compounds, achieve a required mass removal greater

than or equal to 95 percent for Table 9 compounds

1 and 6

Treat with permitted Resource Conservation and Recovery Act (RCRA)

units or by discharging to a permitted underground injection well

1 and 11
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101

Checklist 1: Requirements for all wastewater tanks

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring and Inspection Requirements Comments

1. Do you inspect all openings (e.g., access hatches, sampling ports, and

gauge wells) to make sure they are maintained in a closed position

(e.g., covered by a lid) when not in use (e.g., during sampling,

equipment maintenance, inspection, or repair)?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do you record the occurrence of each semiannual visual inspection

for improper work practices?

G Yes G No

2. Do you record the occurrence of each semiannual visual inspection

for control equipment failures?

G Yes G No

3. For each inspection during which a control equipment failure was

identified, do you record and report the following in the

Periodic Report:

• Date of the inspection

• Identification of the wastewater tank, surface impoundment,

container, individual drain system, or oil-water separator having

the failure?

• Description of the failure?

• Description of the nature of the repair?

• Date the repair was made?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
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102

Checklist 2: Requirements for all surface impoundments

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

1. Monitoring and Inspection Requirements Comments

1. Do you inspect all access hatches and all other openings to make sure

they are closed when not in use?

G Yes G No

2. Do you inspect all control equipment to make sure it is 

functioning properly (e.g., seals, joints, lids, covers, and doors are not

cracked, gapped, or broken)?

G Yes G No

3. For surface impoundments with floating flexible membrane covers, is

the floating flexible membrane cover made out of one of the

following:

• high density polyethylene with a thickness of no less

than 2.5 millimeters; or

• a material that has an equivalent organic permeability 

and integrity for the intended service life of the floating cover

G Yes G No

3. For surface impoundments with floating flexible membrane covers,

are all openings equipped with closure devices such that there are no

visible cracks, holes, gaps, or other open spaces between the

perimeter of the cover opening and the closure device when it is

closed?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do you record the occurrence of each semiannual visual inspection

for improper work practices?

G Yes G No

2. Do you record the occurrence of each semiannual visual inspection

for control equipment failures?

G Yes G No
DRAFT

Checklist 2: (cont’d)

Requirements for all surface impoundments

B. Recordkeeping and Reporting Requirements Comments

103

3. For each inspection during which a control equipment failure was

identified, do you record and report the following in the next

Periodic Report:

• Date of the inspection

• Identification of the wastewater tank, surface impoundment, 

container, individual drain system, or oil-water separator having

the failure?

• Description of the failure?

• Description of the nature of the repair?

• Date the repair was made?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
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104

Checklist 3: Requirements for all containers

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

1. Monitoring and Inspection Requirements Comments

1. For containers with capacity greater than or equal to 0.1 but less

than or equal to 0.42 cubic meters, do you meet all of the following

requirements:

• the container meets existing DOT specifications and 

testing requirements or the requirements of § 63.148 of

subpart G?

• the cover and all openings are maintained in a closed 

position (e.g., covered by a lid) when not in use (e.g., 

during filling)?

G Yes

G Yes

G No

G No

2. For containers with capacity greater than 0.42 cubic meters, do you

meet all of the following requirements:

• the container is equipped with a submerged fill pipe that does not

extend more than 6 inches or within two fill pipe diameters of

the bottom of the container while the container is being filled?

• the cover and all openings are maintained in a closed position

(e.g., covered by a lid) when not in use (e.g., during filling)?

G Yes

G Yes

G No

G No

2. Whenever a container with capacity greater than or equal to 0.1 cubic

meters is open, is it located within an enclosure that is routed by a

closed-vent system to a control device?

G Yes G No

3. Is all control equipment functioning properly (e.g., covers and doors

are not cracked, gapped, or broken)?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do you record the occurrence of each semiannual visual inspection

for improper work practices?

G Yes G No

2. Do you record the occurrence of each semiannual visual inspection

for control equipment failures?

G Yes G No
DRAFT

Checklist 3: (cont’d)

Requirements for all containers

B. Recordkeeping and Reporting Requirements Comments

105

3. For each inspection during which a control equipment failure was

identified, do you record and report the following in the next Periodic

report:

• Date of the inspection

• Identification of the wastewater tank, surface impoundment,

container, individual drain system, or oil-water separator having

the failure?

• Description of the failure?

• Description of the nature of the repair?

• Date the repair was made?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

4. Do you keep a record of the capacity of each container maintained at

your facility if applicable?

G Yes G No
DRAFT

106

Checklist 4: Requirements for all individual drain systems

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

1. Monitoring and Inspection Requirements Comments

1. For individual drain systems with control equipment including a

cover with or without a closed-vent system routed to a control device

or to a process, do you meet all of the following requirements:

• the individual drain system is designed and operated to segregate

the vapors within the system from other drain systems and the

atmosphere?

• the cover and all openings (e.g., access hatches, sampling ports,

and gauge wells) are maintained in a closed position when not in

use (e.g., during sampling, equipment maintenance, inspection,

or repair)?

• the cover and all openings are maintained in good 

condition?

G Yes

G Yes

G Yes

G No

G No

G No

5. Do you meet all of the following requirements for drains:

• each drain is equipped with either water seal controls 

(e.g., p-trap, s-trap) or a tightly-fitting cap or plug?

• for each drain equipped with a water seal, there is water in the

water seal?

• if a water seal is used on a drain receiving a Group 1 process

wastewater stream, then do you meet one of the following

requirements:

< the drain pipe discharging the wastewater extends below the

liquid surface in the water seal; or

< a flexible shield (or other enclosure which restricts wind

motion) is installed that encloses the space between the pipe

discharging the wastewater and the drain receiving the

wastewater?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
DRAFT

Checklist 4: (cont’d)

Requirements for all individual drain systems

107

1. Monitoring and Inspection Requirements Comments

3. Do you keep junction boxes equipped with tightly fitting solid covers,

and, if vented, equipped with a vent pipe meeting all of the following

requirements if applicable:

• the vent pipe is connected to a closed vent system that is routed

to a process or control device?

• if the junction box is filled and emptied by gravity flow or is

operated with no more than slight fluctuations in the liquid level

and you vent the junction box to the atmosphere, do you meet all

of the following requirements:

< the vent pipe is at least 90 centimeters in length?

< the vent pipe does not exceed 10.2 centimeters in diameter?

< a water seal is installed at the entrance or exit of the junction

box that restricts ventilation in the individual drain system

and between components in the individual drain system?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

4. Do you meet all of the following requirements for sewer lines if

applicable:

• sewer lines covered or enclosed so that no visible 

gaps or cracks in joints, seals, or other emission interfaces

exist?

• sewer lines are not open to the atmosphere?

G Yes

G Yes

G No

G No

B. Recordkeeping and Reporting Requirements Comments

1. Do you record the occurrence of each semiannual visual inspection

for improper work practices?

G Yes G No

2. Do you record the occurrence of each semiannual visual inspection

for control equipment failures?

G Yes G No

3. For each inspection during which a control equipment failure was

identified, do you record and report the following in the next Periodic

Report:

• Date of the inspection

• Identification of the wastewater tank, surface impoundment,

container, individual drain system, or oil-water separator having

the failure?

• Description of the failure?

• Description of the nature of the repair?

• Date the repair was made?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
DRAFT

Checklist 4: (cont’d)

Requirements for all individual drain systems

B. Recordkeeping and Reporting Requirements Comments

108

4. If you use a drain, junction box, or sewer line as an alternative, 

do you keep all of the following records:

• documentation of the occurrence of each semiannual inspection

of drains to ensure that caps or plugs are in place and properly

installed; or

• documentation of the occurrence of each semiannual verification

of water supply to the drain?

• documentation of the occurrence of each semiannual inspection

of junction boxes to ensure that there are no gaps, cracks, or

other holes in the cover?

• documentation of the occurrence of each semiannual inspection

of the unburied portion of each sewer line to ensure that there are

no cracks or gaps that could result in air emissions?

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No
DRAFT

109

Checklist 5: Requirements for all oil-water separators

Facility Name: _________________________________________________________

Facility Location: _________________________________________________________

Facility TRI ID #: _________________________________________________________

Inspector: _________________________________________________________

Date: _________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

1. Monitoring and Inspection Requirements Comments

1. Is the floating roof is resting on the liquid surface of the stored

material, unless the floating roof is resting on the roof leg supports

because the oil-water separator has just been emptied and degassed or

the tank is partially or completely emptied before being subsequently

refilled or degassed?

G Yes G No

2. Is the floating roof is in good condition (i.e., free of defects such as

corrosion and pools of standing liquid)?

G Yes G No

3. Is a secondary seal installed above the primary seal? G Yes G No

4. If a secondary seal is installed, do you inspect the secondary seal

according to all of the following requirements:

• the secondary seal is continuous and completely covers the

annular space between the floating roof and the separator wall?

• there are no holes, tears, or other openings in the seal or seal

fabric?

• the seal is not detached from the floating deck?

• there are no visible gaps between the seal and the wall of the oilwater separator except as specified below?

• perform seal gap measurement of the secondary seal according to

the following requirements:

< the total gap area between the separator wall and the

secondary seal does not exceed 6.7 square centimeters per

meter of the separator wall perimeter?

< the maximum gap width between the separator wall and the

seal does not exceed 1.3 centimeters at any point?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
DRAFT

Checklist 5: (cont’d)

Requirements for all oil-water separators

110

1. Monitoring and Inspection Requirements Comments

5. Do you inspect the primary seal according to the following

requirements:

• the primary seal is a liquid-mounted seal?

• there are no holes, tears, or other openings in the seal fabric, seal

envelope, or shoe (if a metallic shoe seal is used)?

• if the primary seal is a liquid-mounted seal (e.g., foam or liquidfilled seal), the seal is in contact with the liquid between the wall

of the oil-water separator and the floating roof?

• the seal is not detached from the floating roof?

• the primary seal forms a continuous closure that completely

covers the annular space between the wall of the oil-water

separator and the edge of the floating roof, except as described

below?

• perform seal gap measurements of the primary seal according to

the following requirements:

< the total gap area between the separator wall and the

secondary seal does not exceed 67 square centimeters per

meter of the separator wall perimeter?

< the maximum gap width between the separator wall and the

seal does not exceed 3.8 centimeters at any point?

G Yes

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

G No

6. If the floating roof is equipped with one or more emergency roof

drains for removal of stormwater, is each emergency roof drain fitted

with a slotted membrane fabric cover that covers at least 90 percent

of the drain opening area or a flexible fabric sleeve seal?

G Yes G No

7. Are all openings in the floating roof equipped with a gasketed cover,

seal, or lid, which is maintained in a closed position at all times,

except during inspections and maintenance?

G Yes G No

8. Are no gaskets, joints, lids, covers, or doors cracked, gapped, or

broken?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do you record the occurrence of each semiannual visual inspection

for improper work practices?

G Yes G No

2. Do you record the occurrence of each semiannual visual inspection

for control equipment failures?

G Yes G No
DRAFT

Checklist 5: (cont’d)

Requirements for all oil-water separators

B. Recordkeeping and Reporting Requirements Comments

111

3. For each inspection during which a control equipment failure was

identified, do you record and report the following in the next Periodic

report:

• Date of the inspection

• Identification of the wastewater tank, surface impoundment,

container, individual drain system, or oil-water separator having

the failure?

• Description of the failure?

• Description of the nature of the repair?

• Date the repair was made?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
DRAFT

112

Checklist 6: Requirements for design steam strippers

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring and Inspection Requirements Comments

1. Is the minimum active column height at least 5 meters? G Yes G No

2. Does the countercurrent flow configuration have a minimum of 10

actual trays?

G Yes G No

3. Is the minimum steam flow rate 0.04 kilograms of steam per liter of

wastewater feed?

G Yes G No

4. Is the minimum wastewater feed temperature tot he steam 

stripper 95 degrees Celsius?

G Yes G No

5. Is the maximum liquid loading 67,100 liters per hour per square

meter?

G Yes G No

6. Does the design steam stripper operate at nominal atmospheric

pressure?

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do you keep records of the steam flow rate, wastewater feed mass

flow rate, and wastewater feed temperature?

G Yes G No

2. Do you record the occurrence of each semiannual visual inspection

for control equipment failures?

G Yes G No

3. For each inspection during which a control equipment failure was

identified, do you record and report the following in the Periodic

report:

• Date of the inspection

• Identification of the wastewater tank, surface impoundment,

container, individual drain system, or oil-water separator having

the failure?

• Description of the failure?

• Description of the nature of the repair?

• Date the repair was made?

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
DRAFT

113
DRAFT

114

Chapter 6 - Complying with requirements for equipment leaks

What equipment leaks are covered?

Subpart MMM regulates equipment leaks from equipment in “organic HAP service.” The

equipment leak provisions apply to all of the following types of equipment [§63.1363(a)(1)]:

• pumps

• compressors

• agitators

• pressure relief devices

• sampling connection systems

• open-ended valves or lines

• valves

• connectors

• instrumentation systems

If you have equipment subject to both Subpart MMM and other air regulations under 40 CFR

parts 60 or 61, you’re only required to comply with Subpart MMM [§63.1362(a)(2)].

Equipment leak provisions apply at all times except when the lines of a non-operating PAI process

unit are drained and depressurized [§63.1360(e)(2)].

How do I identify equipment subject to the equipment leak provisions?

You must identify each piece of equipment covered by the equipment leak provisions so it can be

distinguished from equipment not subject to the provisions. You do not have to physically tag the

equipment unless you wish to do so. Instead, you can mark the equipment on a plant site plan, in

log entries, or by designating process boundaries with waterproof identification.[§63.1363(a)(7)] 

Note: If you make changes to the process or equipment subject to the leak detection

requirements, you must update the equipment identification, if needed, within 15 calendar

days of the end of each monitoring period for that component. 

Definition: “In organic HAP service” means that the

equipment component either contains or contacts a

fluid that’s at least 5 percent HAP by weight.
DRAFT

115

Leaks are detected by sight, sound, odor, or monitoring. When a leak is detected, you must attach

a visible, weatherproof identification to the leaking equipment. The identification may be removed

under either of the following circumstances:

• after the leak has been repaired if the equipment is not a valve or connector in light liquid

or gas/vapor service

• when no leak is detected by follow-up monitoring on a valve or connector in light liquid or

gas/vapor service [§63.1363(a)(10)]

What equipment is exempt?

All of the following are exempt from the equipment leak provisions [§63.1363(a)(5) through (9)]:

• lines and equipment that don’t contain process fluids

• utilities and other nonprocess lines that don’t combine their materials with process fluids

they serve

• bench-scale processes

• equipment in vacuum service

• equipment in organic HAP service less than 300 hours per year

What compliance options do I have for my equipment leaks?

For equipment in organic HAP service, you have the following two compliance options:

Option 1: Use a leak detection/repair program [§63.1363(b), (c), (d), and (e); and sections

of Subpart H referenced from §63.1363(b)]

Implement a leak detection and repair (LDAR) program.

Option 2: Use enclosed equipment [§63.1363(b)(3)(ii), §63.172, and §63.179]

Enclose the equipment and transport emissions through a closed vent system to a control

device.

Option 3: Use pressure testing [§63.1363(b)(3)(iv), §63.178]

Follow-up monitoring is described in §63.1363 (e)(7)(iii) of subpart

MMM for valves and §63.174(e) of subpart H for connectors.
DRAFT

116

The requirements and exceptions for all of the options as applied to different types of equipment

are summarized in Table 6-1 (page x). Additional details are also provided later in this chapter.

How do I implement a leak detection and repair (LDAR) program under

Option 1?

Your requirements under an LDAR program depend on what type of equipment you’re using. The

LDAR program is broken down into the following eleven categories:

• pumps in light liquid service

• agitators in gas/vapor service and light liquid service

• open-ended valves or lines

• valves in gas/vapor or light liquid service

• compressors

• pressure relief devices in gas/vapor service

• sampling collection systems

• pump, valves, connectors and agitators in heavy liquid service

Definition. In gas/vapor service means that a piece of equipment in organic HAP service

contains a gas or vapor at operating conditions.

Definition. In light liquid service means that a piece of equipment in organic HAP service

contains a liquid that meets all of the following conditions:

(1) The vapor pressure of one or more of the organic compounds is greater than 0.3 kPa at 

20EC;

(2) The total concentration of the pure organic compounds constituents having a vapor

pressure greater than 0.3 kPa at 20EC is equal to or greater than 20 percent by weight

of the total process stream; and 

(3) The fluid is a liquid at operating conditions.

Definition. In heavy liquid service means that the

piece of equipment in organic HAP service isn’t in

gas/vapor or light liquid service.
DRAFT

117

• instrumentation systems

• pressure relief devices in liquid service

• connectors in gas/vapor service and in light liquid service

Note: Equipment in gas/vapor and light liquid service are subject to different requirements than equipment in

heavy liquid service.

For most equipment, you implement an LDAR program by monitoring using Method 21 in

accordance with one or both of the following procedures:

• the procedures specified in §63.1363(b)(3)(v) and §63.180 of the HON

• by visual or other sensory means of detection

For other equipment, your LDAR program consists of work practice procedures or equipment

design requirements.

Additional details of LDAR programs for each of the eleven categories of equipment are provided

later in this chapter.
118

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

For the following equipment... Your equipment leak requirements are... Except for... According to this

section of the rule...

Pumps in light liquid service and

agitators in gas/vapor service and in

light liquid service

(Option 1)

• quarterly monitoring for leaks

• monthly monitoring based on

calculation of percent leaking pumps

• weekly visual inspections

• repair of leaks

• unsafe to monitor or inaccessible

equipment

• pumps/agitators with dual mechanical

seal system with barrier fluid

• pumps/agitators with no externally

actuated shaft

• pumps/agitators with closed-vent

systems and control devices

• pumps/agitators at unmanned sites

§63.1363(c)

Open-ended valves or lines

(Option 1)

seal valves or lines with a cap, blind

flange, plug, or a second valve

• valves/lines designed to open

automatically in emergency

• valves/lines containing materials

which would autocatalytically

polymerize

• valves/lines that would be hazardous if

capped or equipped with a double

block and bleed system

§63.1363(d)

Valves in gas/vapor service and light

liquid service

(Option 1)

• initial monitoring for leaks

• repeat monitoring based on calculation

of percent leaking valves

• repair of leaks

• unsafe and difficult to monitor valves

• inaccessible valves

§63.1363(e)

Compressors

(Option 1)

• equip compressors with a seal system

that includes barrier fluid system

• repair of leaks

• compressors with closed-vent systems

and control devices

• compressors with leak detection

instrument reading of <500 ppm

§63.164

Pressure relief devices in gas/vapor

service 

(Option 1)

leak detection instrument reading of <500

ppm (except during pressure releases)

• pressure relief devices with closed-vent

systems and control devices

• pressure relief devices with upstream

rupture disks

§63.165
119

TABLE 6-1. (cont’d)

For the following equipment... Your equipment leak requirements are... Except for... According to this

section of the rule...

Sampling connection systems

(Option 1)

a closed-purge, closed-loop, or closedvent systemin-situ sampling systems and sampling

systems without purge

§63.166

Pumps, valves, connectors, and

agitators in heavy liquid service;

instrumentation systems; and pressure

relief devices in liquid service

(Option 1)

• monitoring of equipment with potential

leaks

• repair of leaks

potential leaks that are repaired before

monitoring

§63.169

Connectors in gas/vapor service and in

light liquid service

(Option 1)

• initial monitoring for leaks

• repeat monitoring based on calculation

of percent leaking connectors

• repair of leaks

• connectors that have been opened or

have a broken seal

• screwed connectors with a small inside

diameter

• ceramic or ceramic-lined connectors

• unsafe and difficult to monitor

connectors

• inaccessible connectors

• credits for removed connectors

§63.174 with changes

described in

§63.1363(b)(3)(iii)

Closed-vent systems and 

control devices

 (Option 2)

• percent reduction, outlet concentration,

or equipment operating requirements

• monitoring for use of bypass lines

• inspections

• repair of leaks

control devices subject to monitoring,

reporting, and recordkeeping

requirements in 40 CFR part 264, subpart

BB, or in 40 CFR part 265, subpart BB

§63.172 with changes

described in

§63.1363(b)(3)(ii)
DRAFT

120

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

Agitators in Gas/Vapor Service and Light Liquid Service (Option 1)?

Requirements for pumps and agitators under Option 1 include all of the following [§63.1363(c)]:

• monitor equipment for leaks using Method 21

• perform visual inspections

• repair leaks

In addition, there are exemptions to these requirements for specific types of equipment. All

requirements and exemptions are detailed below.

Monitoring for leaks:

You must monitor for leaks each quarter using the monitoring method described in §63.180(b) of

subpart H [§63.1363(c)(2)(i)]. This method requires you to use a leak detection instrument. Your

equipment is considered leaking if you get any of the following instrument readings: 

[§63.1363(c)(2)(ii)]

• $10,000 ppm for agitators

• $2,000 ppm for pumps

You must calculate the percentage of pumps that leak using the procedure outlined in

§63.1363(c)(4). This percentage is based on the groups of processes that you develop before the

first monitoring period. You must monitor each pump monthly if (based on a 1-year rolling

average) any of the following apply:

• 10 percent or more of the pumps in a group of processes leak

• three or more pumps in a group of processes leak

All pumps in organic HAP service, except those in compliance under option 2, must be included in

the percent leaking calculation

However, you don’t have to determine the percent leaking pumps for a process if more than

90 percent of the pumps in a group of processes are either of the following: [§63.1363(c)(9)]

< equipped with a dual mechanical seal system that includes a barrier fluid system

< designed with no externally actuated shaft penetrating the pump/agitator housing

Note: You do not have to calculate the percentage of agitators that are leaking.
DRAFT

121

Visual inspections: 

Each pump and agitator must be checked weekly by visual inspection for signs of liquids dripping

from the pump or agitator seal. A leak is detected if you notice signs of liquids dripping from the

seal. [§63.1363(c)(2)(iii)]

Repair of leaks: 

You must repair leaks as soon as possible after they are detected. See “What are the leak repair

requirements?” for more information.

Exceptions:

There are several exemptions to the requirements for implementing an LDAR for Pumps in Light

Liquid Service and Agitators in Gas/Vapor Service and Light Liquid Service. Exemptions include

all of the following:

Pumps that are unsafe or difficult to monitor -

• You aren’t required to monitor equipment that’s unsafe or difficult to monitor or is

inaccessible. See “What if equipment is unsafe or difficult to monitor?” for more

information.

Pumps or agitators with special design features - 

• Pumps or agitators equipped with a dual mechanical seal system that includes a barrier

fluid system are exempt from the monitoring, visual inspection, and repair provisions in

§63.1363(c)(2) and (3) provided that all of the following are performed: [§63.1363(c)(5)]

< your dual mechanical seals meet be one of the following criteria:

 ̃ are operated with a barrier fluid pressure that is always greater than the

pump/agitator stuffing box pressure 

 ̃ are equipped with a barrier fluid degassing reservoir connected by a closed-vent

system to a control device

 ̃ are equipped with a closed-loop system that purges the barrier fluid into a process

stream

< the barrier fluid isn’t in light liquid service

< each barrier fluid system has a sensor that will detect failure of the seal system, the

barrier fluid system, or both. The sensor must be observed daily or have an alarm

(unless the pump is at an unmanned plant site).
DRAFT

122

< each pump/agitator must be visually inspected each week to see if liquids are dripping

from the pump/agitator seal. If liquids are dripping, the seal must be monitored with a

leak detection instrument to determine if there’s a leak of organic HAP in the barrier

fluid. A leak is detected if the instrument reads $10,000 ppm for agitators or

$2,000 ppm for pumps.

< you’ve determined the criteria that you’ll use to indicate failure of the seal system, the

barrier fluid system, or both. If a leak is detected based on your criteria then you must

repair the leak as described in “What are the leak repair requirements?” of Chapter 6.

• Any pump or agitator designed with no externally actuated shaft penetrating the

pump/agitator housing is exempt from the monitoring and repair provisions. However, the

weekly visual inspection requirements apply for these pumps/agitators. [§63.1363(c)(6)]

• Pumps and agitators in compliance under option 2 are exempt from the monitoring, visual

inspection, repair, and calculation of percent leaking pumps provisions. [§63.1363(c)(7)]

• Pumps and agitators at unmanned plant sites are exempt from weekly visual inspections

and daily sensor observations (for pumps/agitators with dual mechanical seal and barrier

fluid systems). However, each pump/agitator must be visually inspected at least monthly or

more frequently if possible. [§63.1363(c)(8)]

What are the LDAR requirements for open-ended valves or lines

(Option 1)?

You comply with the LDAR requirements for open-ended valves or lines under Option 1 by

sealing the open end using any of the following devices: [§63.1363(d)(1)(i)]

• a cap

• a blind flange

• a plug

• a second valve

The mechanism you use to seal the open end must meet both of the following: 

[§63.1363(d)(1)(ii)]

• it must be in use at all times except:

< during operations requiring process fluid flow through the valve or line

< during maintenance

< during repair

• it must be in place within 1 hour after any of the excepted periods listed above
DRAFT

123

Note: If you use a second valve, you must close the valve on the process fluid end before closing the second

valve [§63.1363(d)(2)].

If you use a double block and bleed system, you may leave the bleed valve or line open during operations that

require venting the line between the block valves.

Exemptions:. 

You don’t have to comply with the requirements to seal the open-ended valve or line if any of the

following situations apply to the open-ended valve or line: [§63.1363(d)(4) through (6)]

• it contains material which would autocatalytically polymerize

• it contains material which could cause a safety hazard if capped or equipped with a double

block and bleed system

• it’s designed to open automatically as part of an emergency shutdown system in the event of

a process upset

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

service (Option 1)?

For valves in gas/vapor or light liquid service you must implement an LDAR program by doing of

all of the following steps:

Step 1: Identify your valves:

• identify all valves in PAI process units [§63.1363(a)(7)]

Step 2: Identify valves subject to special monitoring requirements:

• identify each valve that meets one of the following conditions: [§63.1363(f)]

< is unsafe to monitor

< is difficult to monitor

< is inaccessible

Step 3: Perform initial monitoring:

• monitor all valves (except those identified in Step 2) within 1 year after the compliance date

(e.g., by 6/23/03). [§63.1363(e)(2) and (e)(3)(i)]

Step 4: Repair all leaks

• if you find a leaky valve, do all three of the following:

Note: A leak exists if the instrument reading is 500 ppm or greater [§63.1363(e)(3)(ii)].

For more information, see “What are the LDAR

requirements for unsafe to monitor, difficult to

monitor, and inaccessible equipment?” 
DRAFT

124

< repair the leaking valve no later than 15 calendar days after you identify the leak

[§63.1363(e)(7)(i)]

< attempt to repair the leaking valve no later than 5 calendar days after detecting the leak

[§63.1363(e)(7)(ii)]. Examples of first attempts at repair include all of the following: 

[§63.1363(e)(8)]

 ̃ tightening of bonnet bolts

 ̃ replacement of bonnet bolts

 ̃ tightening of packing gland nuts

 ̃ injection of lubricant into lubricated

packing

< re-monitor the valve within 3 months of repair, but you don’t need to include these

monitoring results in the calculation of percent leakers described in Step 5

[§63.1363(e)(7)(iii) and (e)(6)(ii)]

Step 5: Calculate your percentage of leaking valves

• calculate the percentage of leaking valves in a group of valves, excluding nonrepairables

[§63.1363(e)(6)(ii)]. You may define groups

that are most appropriate for your site-specific

circumstances. Your choices for groups consist

of any combination of the following: 

[§63.1363(b) and (e)(6)(i)]

< create group of all the valves from a single process

< create a group of all the valves from multiple processes

< create multiple subgroups of all the valves from multiple processes

Note: You may not create subgroups of valves from a single process. Procedures for subgroups are described

on page x. To create or revise groups or subgroups after the implementation date, you must revise your permit

[§63.1363(e)(6)(i)].

To calculate the percentage of leaking valves in a group or subgroup, you may exclude

nonrepairable valves (up to 1 percent of the total number of valves in the group or subgroup)

[§63.1363(e)(6)(iv)].

Step 6: Continuous monitoring for leaks

• After your initial round of monitoring, you must monitor for leaks as follows:

You may delay repair under certain

situations [§63.1363(b)(3)(i) and §63.171]. 

For more information, see “When may I

delay repair?” 

The results of these calculations are used

to determine the frequency of subsequent

monitoring, as described in Step 6.
DRAFT

125

If the total

number of valves

you have for all

groups is...

And the percentage of

leaking valves in the

group or subgroup isa...

Then you must monitor at least

once every

b

...

According to

§63.1363(e)(6)(iii) and this

section of the rule...

$250 $2 percent

<2 percent

<1 percent

<0.5 percent 

<0.25 percent

month

3 months

6 months

12 months

2 years

§63.1363(e)(4)(i)

§63.1363(e)(4)(ii)

§63.1363(e)(4)(iii)

§63.1363(e)(4)(iv) 

§63.1363(e)(4)(v)

<250 no determination

required

3 months §63.1363(e)(9)

<1 percent

<0.5 percent

6 months 

12 months

§63.1363(e)(4)(iii),

(e)(4)(iv), and (e)(9)

a Percentages are averaged from the data collected during the previous two monitoring periods if the group or

subgroup was monitored every year or every 2 years, and percentages are averaged from the previous three

monitoring periods if the group or subgroup was monitored every 1 month, 3 months, or 6 months.

b All valves that you find to be leaking must be repaired and remonitored 

Your requirements for subgrouping valves include all of the following:

• you may subgroup valves within a group of processes if less than 2 percent of the valves in

the group leaked in the last monitoring period [§63.1363(e)((5)(i)]

• you must check for compliance with the 2 percent cutoff for the group every 6 months

[§63.1363(e)((5)(iii)]

• anytime you find more than 2 percent in the group to be leaking, you must revert to

monitoring the group as a whole (i.e., monitor all of the valves in the group monthly)

[§63.1363(e)(5)(iii)]

• when you create subgroups, you must include in the most frequently monitored subgroup all

valves that meet either of the following conditions [§63.1363(e)(5)(ii)(A)]:

< those with less than 1 year of monitoring data

< those that haven’t been monitored in the last 12 months

• you may move any valve from a less frequently monitored subgroup to a more frequently

monitored subgroup if you take all of the following actions before and after the move

[§63.1363(e)(5)(ii)(B)]:

< before the move: monitor the valve during the most recent monitoring period for the

less frequently monitored subgroup

< after the move: include the first monitoring results in your next calculation of the

percentage leaking valves for the less frequently monitored subgroup (as well as in the

calculation for the more frequently monitored subgroup)
DRAFT

126

• you may move a valve from a more frequently monitored subgroup to a less frequently

monitored subgroup if the valve has not leaked for the

period of the less frequently monitored subgroup

[§63.1363(e)(5)(ii)(C)]

Note: You must conduct more recordkeeping and reporting for

subgroups than for groups of processes [§63.1363(e)(5)(iv), (v), and (vi)]. 

See _____ for more information.

What LDAR requirements apply to compressors (Option 1)?

To comply with the LDAR requirements for compressors (option 1), you must do all of the

following:

• equip your compressors with a seal system that includes a barrier fluid system and meets

any one of the following [§63.164(a) and (b)]:

< it’s operated with the barrier fluid pressure greater than the compressor stuffing box

pressure

< it’s equipped with a barrier fluid system degassing reservoir that’s routed to a process or

connected by a closed-vent system to a control device

< it’s equipped with a closed-loop system that purges the barrier fluid directly into a

process stream

Note: the barrier fluid must not be in light liquid service.

• equip the barrier fluid system with a sensor that will detect a system failure [§63.164(d)]

• determine a criterion for the sensor that indicates the failure [§63.164(e)(2)]

• observe the sensor daily or equip it with an alarm (this requirement does not apply if the

compressor is located at an unmanned plant site)[§63.164(e)(1)]

Note: you have a leak if the sensor detects a failure [§63.164(f)]

• repair leaks within the following timeframe [§63.164(g)]:

< your first attempt at repair must occur within 5 working days after you detect a leak

< you must complete the repair within 15 calendar days after you detect a leak, unless a

delay of repair is allowed

Nonrepairable valves may not

be moved to a less frequently

monitored subgroup.
DRAFT

127

Exceptions: 

The LDAR requirements don’t apply to compressors in organic HAP service if you do any of the

following:

• equip the compressor with a closed vent system to capture and transport leaks back to a

process or to a control device [§63.164(h)]

• designate that the compressor operates with an instrument reading of less than 500 ppm

above background based on monitoring using Method 21 at all of the following times

[§63.164(i)]:

< when you make the designation

< annually

< any other time requested by the Administrator

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

service (Option 1)?

To comply with the LDAR requirements for pressure relief devices in gas/vapor service (option 1),

you check your devices for leaks after each pressure release. Your pressure relief devices must

have a leak detection instrument reading of less than 500 ppm above background, except during

pressure releases. 

Section 63.180(c) of subpart H specifies how to measure for leaks [§63.165(a)]. After each

pressure release [§63.165(b)]:

• the pressure relief device must be returned to less than 500 ppm as soon as possible

• you must monitor the relief device within 5 days of the pressure release and return of the

relief device to organic HAP service to ensure an instrument reading of less than 500 ppm

Exceptions: 

You are exempt from the LDAR requirements for pressure relief devices in gas/vapor service if

either of the following apply:

• you comply with Option 2 [§63.165(c)].

• if your pressure relief device is equipped with a rupture disk upstream of the pressure relief

device, and you replace the rupture disk as soon as possible (but no more than 5 days) after

a pressure release [§63.165(d)].
DRAFT

128

What LDAR requirements apply for sampling connection systems?

(Option 1)

To comply with the LDAR requirements for sampling connection systems (option 1), you must

meet certain design requirements. Your sampling connection systems must have a closed-purge,

closed-loop, or closed-vent system. You aren’t required to capture gases displaced during filling

of sample containers[§63.166(a)]. Closed-purge, closed-loop, or closed-vent systems must do one

of the following: [§63.166(b)]:

• return purged process fluid directly to the process line

• collect and recycle purged process fluid to a process

• capture and transport purged process fluid to a control device

• collect, store, and transport purged process fluid to a waste management unit, TSDF, or

permitted waste management facility

Exceptions: 

In-situ sampling systems and sampling systems without purges are exempt from the LDAR

requirements for sampling connection systems.

What LDAR requirements apply for pumps, valves, connectors, and

agitators in heavy liquid service; instrumentation systems; and

pressure relief devices in liquid service? (Option 1)

To comply with the LDAR requirements for pumps, valves, connectors, and agitators in heavy

liquid service; instrumentation systems; and pressure relief devices in liquid service under Option 1

you must do all of the following [§§63.1363(b)(2) and 63.169]:

• monitor equipment for leaks

• repair leaks

In addition, there are exemptions to these requirements for specific types of equipment. All

requirements and exemptions are detailed below.

Monitoring for leaks: 

If you see, hear, notice an odor, or otherwise detect a potential leak, then you must monitor for

leaks within 5 days using the method described in §63.180(b). This method requires use of a leak

detection instrument to monitor the potential leak. The following table summarizes what is

considered to be a leak:
DRAFT

129

A leak is detected for ... If the instrument reading is ...

agitators 10,000 ppm

pumps handling polymerizing monomers 5,000 ppm

pumps in food or medical service 2,000 ppm

valves 500 ppm

connectors 500 ppm

instrumentation systems 500 ppm

pressure relief devices 500 ppm

Repair of leaks:

You must repair leaks as soon as possible after they are detected. See “What are the leak repair

requirements?” for additional details.

Exceptions:

You are not required to monitor for leaks if you repair potential leaks. Repair of potential leaks

means any of the following:

• you can no longer see, hear, smell, or otherwise detect the potential leak

• you see no bubbles at potential leak sites during a leak check with soap solution

• the system will hold a test pressure

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

liquid service (Option 1)?

To comply with the LDAR requirements for connectors (option 1), you must do all of the

following:

Step 1: Identify your connector

• identify all connectors in PAI process units [§63.1363(a)(7)]
DRAFT

130

Step 2: Identify connectors subject to special monitoring requirements

• identify each connector that meets one of the following conditions [§63.1363(f) and

§63.174(f), (g), and (h)]:

< unsafe to monitor

< difficult to monitor

< inaccessible

Step 3: Perform initial monitoring

• Monitor all connectors (except those designated in Step 2 ) [§63.174(b)]:

< by June 23, 2003 for existing sources

< within 12 months after initial startup or by June 23, 2003, whichever is later, for new

sources

Step 4: Repair the leak

• Repair leaks within the following timeframe [§63.174(d)]:

< you must complete the repair no later than 15 calendar days after you identify a leak,

unless a delay of repair is allowed.

< your first attempt at repair must be no later than 5 calendar days after you detect the

leak

Step 5: Calculate your percentage of leaky connectors

• Calculate the percentage of leaking connectors in a group of processes using the procedures

specified in §63.174(i)

Step 6: Continuous monitoring for leaks

• After the first year of monitoring, determine your required monitoring frequency as follows:

For more information, see “What are the LDAR

requirements for unsafe to monitor, difficult to

monitor, and inaccessible equipment?” 
DRAFT

131

If, during the last

monitoring period,

the percentage of

connectors that

leak is...

Then your

required

monitoring

frequency for

the next period

must be no less

than...

And you must

monitor...

However, if the

percentage leaking

is...

Then you must

increase the

monitoring

frequency for the

group toa...

According to this

section of the

rule...

$0.5 percent once per year all

connectors

during the

year

§63.1363(b)(3)

(iii) and

§63.174(b)(3)(i)

$0.25 percent to

<0.5 percent

once every 4

years

40 percent in

the first

2 years

$0.5 and

<1.0 percent in the

first 2-year period

or the full 4-year

period

once every

2 years

§63.1363(b)(3)

(iii)(C) and (D)

$1.0 percent in the

first 2-year period

once per year §63.1363(b)(3)

(iii)(E)

<0.25 percent once every 8

years

50 percent in

the first

4 years

$0.35 and

<0.5 percent in the

first 4-year period

once every

4 years (with

40 percent

monitored in the

first 2 years)b

§63.1363(b)(3)

(iii)(C) and (F)

$0.5 and

<1.0 percent in the

first 4-year period

once every

2 years

§63.1363(b)(3)

(iii)(D) and (F)

$1.0 percent in the

first 4-year period

once per year §63.1363(b)(3)

(iii)(E) and (F)

a You may return to the 4-year and 8-year monitoring frequencies if less than 0.5 percent and 0.25 percent,

respectively, are leaking in this monitoring period [§63.1363(b)(3)(iii)(D) and (E)]. However, except as

specified in footnote b, if $0.5 percent are leaking, you must monitor once per year [§63.174(b)(3)(i)].

b

If $0.5 percent and less than 1.0 percent are leaking in the full 4-year period, your next monitoring period

must be 2 years [§63.1363(b)(3)(iii)(C)].

Exceptions to the above LDAR requirements for connectors apply for the following connectors:

Monitoring connectors that have been opened:

You have two options for monitoring of connectors that have been opened or have a broken

seal [§63.174(c)]:

• Monitor the connector for leaks when it is reconnected or within the first 3 months after it is

returned to organic HAP service. If a leak is detected, it must be repaired (unless it is

determined to be nonrepairable).
DRAFT

132

• Choose not to monitor the connector. If you choose not to monitor the connector, then you

cannot count nonrepairables in your calculation of the percentage that are leaking.

Note: You may switch between the two monitoring alternatives for connectors that have been opened or

have a broken seal, provided the switch is at the end of the current monitoring period, and that it’s

reported. You must complete initial monitoring in the new alternative no later than 12 months after you

report the switch.

Monitoring for screwed connectors:

For screwed connectors with an inside diameter of 2 inches or less installed before November 10,

1997, you may do all of of the following as an alternative to the procedure described above

[§63.174(c)(2)]:

• Comply with the requirements for connectors in heavy liquid service in §63.169 of the HON

(i.e., if you detect evidence of a leak by visual, audible, olfactory, or other means, then

either repair the connector or monitor to determine if repair is needed).

• Monitor for leaks within the first 3 months after the screwed connector is returned to

organic HAP service after having been opened or having the seal broken. Leaks must be

repaired as described in “What are the leak repair requirements?”

Monitoring for connectors you eliminate:

If you eliminate a connector subject to repeat monitoring, you may take credit for elimination of

the connector if all of the following requirements are met [§63.174(j)]:

• The connector was welded after November 10, 1997

• The integrity of the weld is demonstrated by monitoring, X-ray testing, acoustic monitoring,

hydrotesting, or other method

• Welds created after November 10, 1997 but before June 23, 1999 are monitored or tested

by 3 months after the compliance date

• Welds created after June 23, 1999 are monitored or tested within 3 months after being

welded

• If an inadequate weld is found or the connector is not welded completely around the

circumference, the connector is not exempt from the monitoring requirements

What are my compliance requirements for closed-vent systems and

control devices (Option 2)?

Requirements for closed vent systems and control devices under Option 2 include all of the

following [§§63.1363(b)(3)(ii), 63.172, and 63.179]:

• operating requirements

• inspections
DRAFT

133

• monitoring of bypass lines

In addition, there are exemptions to these requirements for specific types of equipment. All

requirements and exemptions are detailed below.

Operating requirements:

Closed-vent systems or control devices must be operating whenever organic HAP emissions are

being vented [§63.172(m)]. The table below summarizes the standards for closed-vent systems

and control devices:

If you operate a... Then meet... Or meet... Or meet...

Recovery or recapture

device

(e.g., condenser,

absorber, etc.)

$95 percent reduction 20 ppmv*

Enclosed combustion

device

$95 percent reduction 20 ppmv (dry basis, 3

percent O2)

minimum residence time

of 0.5 sec. At 1400EF

(760EC)

Flare the requirements of

§63.11(b)

*The 20 ppmv standard is not applicable if you meet the alternative standards for enclosed-vent process units.

Inspections:

If the closed-vent system is made of hard-piping you must perform an initial inspection and annual

visual inspections for visible, audible, or olfactory

indications of leaks. 

If your vapor collection system or closed-vent

system is made of duct work, your must conduct

an initial inspection and annual inspections

[§63.172(f) and (g)].

Monitoring of bypass lines:

If your closed-vent system has bypass lines that could divert a vent stream away from the control

device and to the atmosphere, you must do one of the following [§63.172(j)]:

• Use a flow indicator at the entrance of the bypass line. The flow indicator must take a

reading at least once every 15 minutes and you must keep records of the readings. Records

shall be generated as specified in §63.118(a)(3) of subpart G

§63.180(b) of subpart H specifies how you must

conduct initial inspections for hard-piping and

duct work and annual inspections for duct work. 
DRAFT

134

• Secure the bypass line valve in the non-diverting position with a car-seal or a lock-and-key

type configuration. You must visually inspect the seal or closure mechanism monthly to

ensure the valve is maintained in the non-diverting position

Exceptions: 

If your control device is subject to monitoring, recordkeeping, and reporting requirements in 40

CFR part 264, subpart BB, or in 40 CFR part 265, subpart BB, then you may choose whether to

comply with the monitoring, recordkeeping, and reporting requirements of this rule or the

requirements in 40 CFR parts 264 or 265. You must identify which option you choose in your

periodic report [§63.172(n)].

Instead of the completing the initial and annual inspections, you may design a closed-vent system

to operate below atmospheric pressure. The system must be equipped with a pressure

measurement device that can be read from a readily accessible location to verify that negative

pressure is maintained in the closed-vent system when the control device is operating

[§63.1363(b)(3)(ii)(B)].

You aren’t required to inspect equipment that is unsafe or difficult to monitor or is inaccessible. 

(See “What if equipment is unsafe or difficult to monitor?” for additional information).

Low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and pressure relief

valves needed for safety purposes aren’t subject to the monitoring requirements for bypass lines

[§63.172(j)(3)].

What is required for an alternative standard (Option 3)?

You may apply for permission to use alternative emission limit (e.g., alternative standard) to meet

compliance with 3. 

An “Alternative emission limit “ is a way of reducing emissions other than the equipment,

design, or operational requirements or work practice standards in Subpart MMM’s equipment

leak provisions. Some general conditions must be met when you apply for alternative means of

emission limitation, these include all of the following: [§63.177(b) and (c)]:

• you’re responsible for collecting and verifying emission performance test data for an

alternative limit 

• the Administrator will compare test data or the demonstrated emission reduction for the

alternative means of emission limitation to test data or emission reduction for the required

PAI equipment leak standards

• if the PAI standard is a work practice, you must commit in writing to work practices that

provide the same or better emission reductions than required by Subpart MMM and you

must demonstrate the that you’re meeting the emission reduction standard for at least a

1-year period.
DRAFT

135

• the Administrator may condition the permission on requirements that may be necessary to

ensure operation and maintenance to achieve the same or greater emission reduction as the

Subpart MMM equipment leak standards

You (or your leak control equipment manufacturer - why just the manufacturer, why not

consultants, etc.?) may offer a unique approach to demonstrate the alternative emission limit 

[§63.177(d) through (e)]. 

You may do all of the following under the alternative standards:

• conduct pressure testing for leaks on batch or non-batch equipment [§63.178 with

changes described in §63.1363(b)(3)(iv)]

• monitor batch equipment for leaks [§63.178 with changes described in §63.1363(b)(3)(iv)]

• enclosure of process units so that all emissions from equipment leaks are vented through a

closed-vent system to a control device [§63.179]

Pressure testing:

If you comply with the requirements for pressure testing in the section, you’re exempt from the

monitoring provisions for all of the following [§63.178(b)]:

• pumps in light liquid service

• valves in gas/vapor service and in light liquid service

• pumps, valves, connectors, and agitators in heavy liquid service; instrumentation systems;

and pressure relief devices in liquid service

• agitators in gas/vapor service and in light liquid service

• connectors in gas/vapor service and light liquid service

For non-exempt process equipment, you must pressure test the equipment train for leaks each

time the equipment is reconfigured for

production of a different product. 

Pressure testing isn’t required for routine seal

breaks, such as changing hoses or filters. You

must pressure test at lest once per year

[§63.178(b)(1)].

Leaks are detected if [§63.178(b)(3)]:

Process equipment must be tested using either of the

procedures specified in:

P §63.180(f) for pressure or vacuum loss

P §63.180(g) for a test using a liquid
DRAFT

136

For pressure or vacuum tests... For pressure tests using a liquid...

The pressure changes at a rate greater than 6.9

kilopascals (1 psig) in 1 hour

or

if there’s visible, audible, or olfactory evidence of

fluid loss

there are indications of liquids dripping

or 

if there’s other evidence of fluid loss.

If you detect a leak, you must repair it and retest the equipment before start-up of the process. 

See “What are the leak repair requirements?” (page x) for more information.

Monitoring batch equipment for leaks:

If you elect to monitor batch equipment for leaks to show compliance, you must comply with the

requirements specified in “How do I comply” [§63.178(c)(1)]. You must monitor the batch

equipment for leaks when equipment is in use with any

of the following [§63.178(c)(2)]:

• organic HAP 

• an acceptable surrogate volatile organic

compound which is not an organic HAP

• any other detectable gas or vapor

Each time the equipment is reconfigured for the production of a new product, you must monitor

the equipment for leaks within 30 days of process start-up. Initial monitoring can’t be used in

determining percent leaking equipment [§63.178(c)(3)(i)]. 

Connectors must be monitored in accordance with the requirements in §63.174 of Subpart H

[§63.178(c)(3)(ii)].

Batch equipment other than connectors must be monitored at the following frequencies

[§63.178(c)(3)(iii)]:

If the equipment is operated ... And the monitoring frequency required for a continuous process is...

monthly quarterly semiannually

Then you must monitor your batch process...

0 to <25 percent of the year quarterly annually annually

25 to <50 percent of the year quarterly semiannually annually

50 to <75 percent of the year bimonthly three times semiannually

75 to 100 percent of the year monthly quarterly semiannually

§63.180(b) of subpart H specifies how to

monitor for equipment leaks.
DRAFT

137

The monitoring frequencies specified in the table above can be adjusted to accommodate your

process operations. You may monitor anytime during the monitoring period (e.g., month, quarter,

year), provided the monitoring is conducted within a reasonable time after monitoring was last

completed. For example, if the equipment is not operating during the scheduled monitoring

period, the monitoring can be done during the next period when the process is operating

[§63.178(c)(3)(iv)].

Enclosed-vented process units.

Process units enclosed so that all emissions from equipment leaks are vented through a closed-vent

system to a control device are exempt from Subpart MMM equipment leak requirements. 

However, you must maintain the enclosure under a negative pressure at all times while the process

unit is in operation to ensure that all emissions are routed to a control device [§63.179].

What are my leak repair requirements?

You must repair leaking equipment as soon as possible after leaks are detected. A first attempt to

repair the leak must be made within 5 days after the leak is detected. Activities listed in Subpart

MMM as first attempts to repair leaks from certain equipment are summarized as follows:

For the following equipment... First attempts to repair leaks include... According to...

pumps/agitators in light liquid

service

• tightening of packing gland nuts

• ensuring the seal flush is operating at design

pressure and temperature

§63.1363(c)(3)

valves in gas/vapor or light liquid

service

• tightening of bonnet bolts

• replacement of bonnet bolts

• tightening of packing gland nuts

• injection of lubricant into lubricated packing

§63.1363(e)(8)

pumps, valves, connectors, and

agitators in heavy liquid service;

instrumentation systems; and

pressure relief devices in liquid

service

• tightening of the packing gland nuts

• ensuring that the seal flush is operating at

design pressure and temperature

• tightening or replacement of valve bonnet bolts

• injection of lubricant into lubricated packing

§63.169(d)

Leaks must be fully repaired within 15 days after detection. However, you may delay repair of

leaking equipment under any of the following circumstances [§63.171].
DRAFT

138

• If the repair is technically infeasible without a process unit shutdown. You may delay

repair until the end of the next process unit shutdown [§63.171(a)].

• If equipment is isolated from the process and doesn’t remain in organic HAP service

[§63.171(b)]

• If emissions of material purged from valves, connectors, or agitators during immediate

repair would be greater than the fugitive emissions likely to result from delay of repair. 

When the repair is performed the purged material must be collected and destroyed or

recovered in a control device [§63.171(c)].

• If pump repair requires replacing the existing seal with a new system that will better meet

the requirements of Subpart MMM . The repair must be completed as soon as possible but

not more than 6 months from the time when the leak was detected [§63.175(d)].

• If valve assembly replacement is necessary during a process unit shutdown, but valve

assembly supplies aren’t on hand. You may not delay repairs beyond the next process unit

shutdown, unless a third shutdown will occur within 6 months from the first process unit

shutdown [§63.171(e)].

Valves in gas/vapor or light liquid service must be monitored at least once within the first

3 months after repairs are made. Days when a valve isn’t in organic HAP service aren’t included

as part of this 3-month period [§63.1363(e)(7)].

Option 2:

You may delay a repair of leaks in closed-vent systems and control devices only if either of the

following applies: [§63.172(h)]

• the repair is technically infeasible without a process unit shutdown

• if you determine that emissions resulting from immediate repair would be greater than the

fugitive emissions likely to result from delaying the repair

The repair must be completed by the end of the next process unit shutdown [§63.172(i)].

Option 3:

If you detect a leak when monitoring batch processes under the alternative standard, you must

repair the leak within no more than 15 days after it is detected [§63.178(c)(4)]. If you detect a

leak during pressure testing under the alternative standard, you must repair the leak and retest the

equipment before start-up of the process. If the equipment fails the retest or the second of two

consecutive pressure tests, it must be repaired as soon as possible, but no longer than 30 days after

the second pressure test. 

Delay of leaking equipment repair is allowed under the alternative standard, if the replacement

equipment is not available and both of the following conditions are met [§63.178(d)]:
DRAFT

139

• Equipment supplies (which were sufficiently stocked) have been depleted

• The repair is made no later than 10 days after delivery of the replacement equipment

What if equipment is unsafe or difficult to monitor?

If you designate the following equipment as unsafe to monitor, difficult to monitor, or inaccessible,

the equipment is exempt from the general equipment leak requirements listed in Table 6-1 in

“How do I comply?”: [§63.1363(f)]

• pumps in light liquid service and agitators in gas/vapor service and in light liquid service

• valves in gas/vapor service and in light liquid service

• closed-vent systems and control devices

• connectors in gas/vapor service and in light liquid service

Equipment that’s unsafe to monitor:

Equipment may be designated as unsafe to monitor if you determine that monitoring personnel

would be exposed to an immediate danger if you comply with the equipment leak monitoring

requirements. If you designate equipment as unsafe to monitor, then you must have a written plan

that requires monitoring of the equipment as frequently as possible during safe-to-monitor times. 

You do not have to monitor more frequently than the periodic monitoring schedule that would

apply of the equipment were not unsafe to monitor [§63.1363(f)(2)].

Equipment that is difficult to monitor:

Equipment may be designated as difficult to monitor if you determine that either of the following

are true: [§63.1363(f)(3)(i)]

• the equipment can’t be monitored without elevating the monitoring personnel more than

2 meters above a support surface

• the equipment isn’t accessible at anytime in a safe manner

Rule references for the leak repair provisions are:

§63.1363(c)(3) for pumps in light liquid service and agitators in gas/vapor or light

 liquid service

§63.1363(e)(7) for valves in gas/vapor or light liquid service

§63.164(g) for compressors 

§63.169(c) and (d) for pumps, valves, connectors, and agitators in heavy liquid service;

 instrumentation systems; and pressure relief devices in liquid service

§63.172(h) and (i) for closed-vent systems and control devices

§63.174(d) and (h)(2) and (3) for connectors in gas/vapor of light liquid service

§63.178 for alternative means of emission limitation
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140

If you designate equipment as difficult to monitor, then you must follow a written plan that

requires monitoring of the equipment at least once per calendar year [§63.1363(f)(3)(iii)]. Any

equipment may be designated as difficult to monitor at an existing source. At a new source, you

may designate no more than 3 percent of each type of equipment as difficult to monitor

[§63.1363(f)(3)(ii)]. 

Inaccessible equipment and ceramic or ceramic-lined connectors. 

You may designate a connector, agitator, or valve as inaccessible if it’s any of the following

[§63.1363(f)(4)(i)]:

• buried

• insulated in a manner that prevents access to the equipment by a monitor probe

• obstructed by equipment or piping that prevents access to the equipment by a monitor

probe

• unable to be reached from a wheeled scissor-lift or hydraulic-type scaffold which would

allow access to equipment up to 7.6 meters above the ground

• not able to be accessed at any time in a safe manner to perform monitoring. Examples of

unsafe access are: 

< access requiring a wheeled scissor-lift on unstable or uneven terrain

< access requiring a motorized man-lift basket in areas where an ignition potential exists

< access near hazards such as electrical lines

< access that would risk damage to equipment

Ceramic or ceramic-lined connectors may be treated as inaccessible connectors [§63.1363(f)(1)]. 

At an existing source, you may designate any connector, agitator, or valve as inaccessible if it

meets the applicable criteria. At a new source, you may designate no more than 3 percent of each

type of equipment as inaccessible [§63.1363(f)(4)(ii)]. 

Inaccessible equipment observed by sight, sound, odor, or other means to be leaking must be

repaired as soon as possible. See “What are the leak repair requirements?” [§63.1363(f)(4)(iii)].

What records must I keep for my equipment leaks?

You must keep the following types of records depending on the type of equipment you use: 

[§63.1363(g)]

• general records (identification of equipment, records of exemptions, etc.)

• records of visual inspections
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141

• monitoring records

• records of pressure tests

• records of compressor and pressure relief valve compliance tests

• records for closed-vent systems

• records for components in heavy liquid service

• records of exempt components

• records of alternative means of compliance determination

You must also keep records pertaining to the division of valves in gas/vapor service and light liquid

service into process subgroups. Specific recordkeeping procedures are identified below [Need to

convert the info below to a table]

You only need one recordkeeping system, even you have more than one group of processes

subject to the equipment leak requirements. Keep records at the plant site in hard copy or

electronic form [§63.1363(g)(1)]. 

General recordkeeping:

Except for records of pressure tests, the following information pertaining to all equipment subject

to the equipment leak requirements must be recorded [§63.1363(g)(2)]:

• identification numbers for equipment (except instrumentation systems) subject to the

equipment leak requirements [§63.1363(g)(2)(i)]

Note : Connectors (except inaccessible connectors) do not need to be individually identified if all the

connectors in an area are identified as a group and the number of connectors is indicated.

 You must complete the list for each type of equipment by the time you complete the initial survey required

for that component. The list of identification numbers must be updated within 12 days after each

monitoring survey to incorporate any equipment changes.

• a schedule for monitoring connectors and valves in gas/vapor or light liquid service

[§63.1363(g)(2)(i)]

• identification numbers for equipment with a closed-vent system and control device that

isn’t subject to the equipment leak monitoring requirements [§63.1363(g)(2)(ii)]

• identification numbers for compressors that you designate as operating with an instrument

reading of less than 500 ppm above background (these compressors are exempt from the

monitoring requirements) [§63.1363(g)(2)(ii)]

• identification numbers for pressure relief devices in gas/vapor service subject to the

equipment leak provisions and pressure relief devices with rupture disks

[§63.1363(g)(2)(iii)]
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• identification of instrumentation systems subject to the equipment leak provisions

[§63.1363(g)(2)(iv)]

• the following information for each dual mechanical seal system installed on a pump in light

liquid service, agitator in gas/vapor or light liquid service, or compressor

[§63.1363(g)(2)(v)]:

< design criteria that indicates failure of the seal system, the barrier fluid system, or both

< your explanation of the design criteria

< any changes to the design criteria and the reasons for the changes

• a list of equipment designated as unsafe to monitor, difficult to monitor, or inaccessible and

a copy of the plan for monitoring or inspecting this equipment [§63.1363(g)(2)(vi)]

• a list of connectors removed from and added to the process if you plan to use the net

credits for removed connectors when calculating the percent leaking connectors

[§63.1363(g)(2)(vii)]

• documentation of the integrity of the weld for any removed connectors if you use the credit

for removed connectors [§63.1363(g)(2)(vii)]

• a list of equipment added to batch processes since the last monitoring period if elect to

monitor batch processes using alternative means of emission limitation

[§63.1363(g)(2)(viii)]

Records of visual inspections:

You must document that visual inspections for leaks from pumps in light liquid service and

agitators in gas/vapor and light liquid service were conducted [§63.1363(g)(3)]. Visual inspection

records must contain the date and document monitoring of leaking equipment identified during the

visual inspections (except for records of pressure tests). Keep these records for 5 years. 

Monitoring records:

When each leak is detected you must record all of the following: [§63.1363(g)(4)]

• the instrument and the equipment identification number and the operator name, initials, or

identification number

• date the leak was detected, date of the first attempt to repair the leak, and date of

successful leak repair

• if post-repair monitoring is required, maximum instrument reading measured by Method 21

of 40 CFR part 60, appendix A, after leak is successfully repaired or determined to be nonrepairable

• whether the repair is delayed for more than 15 days after leak discovery and the reason for

the delay
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Note: You may develop a written procedure that identifies the conditions that justify a delay of repair. The

written procedures may be included as part of you startup/shutdown/malfunction plan (required by

§63.1367(a)) or may be part of a separate document maintained at the plant site. Reasons for delay of

repair may be documented by citing the relevant sections of the written procedure. If delay of repair was

caused by depletion of stocked parts, you must have documentation that the spare parts were sufficiently

stocked onsite before depletion and the reason for depletion.

• if repairs were delayed, dates of process shutdowns that occur while the equipment is

unrepaired

• identification of connectors in gas/vapor and light liquid service disturbed since the last

monitoring period (unless you use the option for not monitoring open connectors during

the monitoring period). Connector identification may be maintained either by list, location,

or tagging. 

• date and results of follow-up monitoring for open or disturbed connectors. If identification

of disturbed connectors is made by location, then all connectors within the designated

location must be monitored

• date and results of monitoring done when using alternative means of emission limitation for

batch processes for equipment added to a batch process since the last monitoring period. If

no leaking equipment is found, you must record that the inspection was performed. 

Records of the actual monitoring results are not required

• copies of periodic reports if records are not maintained on a computerized data base

capable of generating summary reports from the records

Keep all records for 5 years. At a minimum, the most recent 2 years of records must be retained

onsite. The remaining 3 years of records may be retained off site. You may keep the records on

microfilm, a computer, computer disks, magnetic tape disks, or on microfiche. [§63.10(b)(1) of

subpart A]

Records of pressure tests:

If you show compliance with the equipment leak provisions by pressure testing process equipment

and supply lines between storage and processing areas, then you’re exempt from the requirements

to keep all of the following: [§63.1363(g)(5)]

• general records 

• records of visual inspections

• monitoring records

• records of compressor and pressure relief valve compliance tests

Instead, you must maintain records of all of the following information:

• identification of each product, or product code, produced during the calendar year. It is

not necessary to identify individual items of equipment in the process equipment train.
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• records of the portion of time during the year the equipment is in use in the PAI process

(e.g., records of time in use for individual pieces of equipment or average time in use for

the process unit). These records aren’t required if you don’t adjust monitoring frequency

by the time in use.

• identification of equipment. Physical tagging of the equipment is not required. Equipment

in a process subject to recordkeeping provisions may be identified on a plant site plan, in

log entries, or by other appropriate methods.

• the dates of each pressure test, the test pressure, and the pressure drop observed during the

test.

• records of any evidence of fluid loss detected by sight, sound, or odor.

• when a process equipment train does not pass two consecutive pressure tests, all of the

following information must be recorded in a log and kept for 2 years:

< the dates of each pressure test and leak repair attempt

< repair methods applied in each attempt to repair the leak

< the reason for the delay of repair

< the expected date for delivery of the replacement equipment and the actual date of

delivery of the replacement equipment

< the date of successful repair

Records of compressor and pressure relief valve compliance tests: 

You must record the dates and results of all of the following [§63.1363(g)(6)]

• each compliance test required for compressors

• the monitoring after a pressure release for each pressure relief device in gas/vapor service.

The results you record must include the measured background level and maximum instrument

reading at each piece of equipment during each compliance test.

Records for closed-vent systems.

You must keep records, for the life of the equipment, of the design specifications and performance

demonstrations, including all of the following: [§63.1363(g)(7)(i)]

• detailed schematics, design specifications of the control device, and piping and

instrumentation diagrams

• the dates and descriptions of any changes in the design specifications

• the flare design (i.e., steam assisted, air assisted, or nonassisted) and the results of the

compliance demonstration
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145

• a description of the parameter or parameters monitored to ensure that control devices are

operated and maintained as designed and an explanation of why each parameter was

selected for the monitoring

You must keep all of the following operational records of closed-vent systems and control devices

for 5 years: [§63.1363(g)(7)(ii)]

• dates and durations when the closed-vent systems and control devices are not operated as

designed, as indicated by the monitored parameters. Include periods when a flare pilot

light system does not have a flame

• dates and durations when the monitor is not operating

• dates and durations of startups and shutdowns of control devices

You must keep for 5 years all of the following records of inspections of closed-vent systems:

[§63.1363(g)(7)(iii)]

• if no leaks are detected during the inspection, a record that the inspection was performed,

the date of the inspection, and a statement that no leaks were detected

• if leaks are detected during the inspection, the information specified in the above section on

“monitoring records” must be recorded

Records for components in heavy liquid service:

You must record information and analyses used to determine that a piece of equipment is in heavy

liquid service. The determination must include an analysis or demonstration that the process fluids

do not meet the criteria of “in light liquid or gas/vapor service.” 

Examples of information that could document that a fluid is not “in light liquid or gas/vapor

service” include records of chemicals purchased for the process, analyses of process stream

composition, engineering calculations, or process knowledge [§63.1363(g)(8)].

Records of exempt components:

You must record identification of equipment that is in organic HAP service less than 300 hr/yr. 

Equipment may be identified by list, location, or other method [§63.1363(g)(9)].

Records of alternative means of compliance determination:

If you choose to comply with the alternative emission limit for enclosed-vent process units, you

must maintain all of the following records: [§63.1363(g)(10)]

• identification of the processes and the organic HAP they handle

• a schematic of the process, enclosure, and closed-vent system.
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146

• a description of the system used to create a negative pressure in the enclosure to ensure

that all emissions are routed to the control device

Records for valves in gas/vapor service and light liquid service.

 If you divide your valves by process subgroups, then you must keep records of all of the

following: [§63.1363(e)(5)(iv)]

• which valves are assigned to each subgroup

• monitoring results and calculations made for each subgroup for each monitoring period

• which valves are reassigned and when they were reassigned

• results of the semiannual overall performance calculation

You must notify the Administrator of the decision to subgroup valves no later than 30 days before

the beginning of the next monitoring period. In the notification, you must identify the participating

processes and the valves assigned to each subgroup.[§63.1363(e)(5)(v)]

What reports must I submit?

To avoid repetition, all of your reporting requirements are presented in Chapter 8.
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147

Checklists for Equipment Leak Inspections

Facility Name: 

Facility Location:

Facility TRI ID #:

Inspector:

Date:

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

with the equipment leak requirements. 

For the following equipment... Then use these checklists:

Pumps in light liquid service and agitators in gas/vapor service and in light

liquid service

1 and 2

Open-ended valves or lines 1 and 3

Valves in gas/vapor service and light liquid service 1 and 4

Compressors 1 and 5

Pressure relief devices in gas/vapor service 1 and 6

Sampling connection systems 1 and 7

Pumps, valves, connectors, and agitators in heavy liquid service;

instrumentation systems; and pressure relief devices in liquid service

1 and 8

Closed-vent systems and control devices 1 and 9

Connectors in gas/vapor service and in light liquid service 1 and 10

Equipment meeting alternative means of emission limitation 1 and 11
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148

Checklist 1:

Identification of Equipment

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring and Inspection Requirements Comments

1. Did you label each piece of equipment covered by the

equipment leak provisions using any of the following methods:

• physically tagging the equipment

• marking the equipment on a plant site plan

• marking the equipment in log entries

• designating process boundaries with waterproof

identification

• another appropriate method for identifying equipment

§63.1363(a)(7)

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

2. If you made changes to equipment subject to the leak detection

requirements, did you update the equipment identification in

question 1 (if needed) within 15 calendar days of the end of the

monitoring period for the component? §63.1363(a)(7)

G Yes G No

3. If a leak was detected, did you attach a visible, weatherproof

identification to the leaking equipment? §63.1363(a)(10)

G Yes G No

4. Did the identification in question 4 remain on the equipment

until either:

• after the leak was repaired for equipment other than valves

or connectors in light liquid or gas/vapor service

• no leak was detected by follow-up monitoring for valves or

connectors in light liquid or gas/vapor service 

§63.1363(a)(10)

G Yes

G Yes

G No

G No
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149

Checklist 2: Requirements for pumps in light liquid service and agitators in gas/vapor and in light

liquid service (Option 1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring and Inspection Requirements Comments

1. Did you monitor for leaks using the method in §63.180(b)?

§63.1363(c)(2)(i)

G Yes G No

2. Did you calculate the percent of leaking pumps using the

procedure outlined in §63.1363(c)(4)?

G Yes G No

3. Did you monitor each pump monthly if (based on a 1-year

rolling average) the greater of either:

• 10 percent of the pumps in a group of processes leak

• three pumps in a group of processes leak §63.1363(c)(4)

G Yes G No

4. Have you performed weekly visual inspections of each pump

and agitator for indications of liquids dripping from the pump

or agitator seal? §63.1363(c)(2)(iii)

G Yes G No

5. Have you done the following for each pump or agitator

equipped with a dual mechanical seal:

• ensured that the dual mechanical seal has either:

< a barrier fluid pressure that is always greater than the

pump/agitator stuffing box pressure

< a barrier fluid degassing reservoir connected by a

closed-vent system to a control device

< a closed-loop system that purges the barrier fluid into a

process stream

• observed the barrier fluid system failure sensor daily

(unless the sensor has an alarm or the equipment is at an

unmanned plant site)

• visually inspected each pump/agitator weekly and

monitored for leaks if liquids are dripping from the seal

• repaired any leaks

• included the pump in the calculation of percent leaking

pumps §63.1363(c)(5)

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
DRAFT

Checklist 2: (cont’d)

Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service

A. Monitoring and Inspection Requirements Comments

150

6. Have you done the following for each pump or agitator

designed with no externally actuated shaft penetrating the

pump/agitator housing:

• performed weekly visual inspections for indications of

liquids dripping from the pump or agitator seal

• included the pumps in the calculation of percent leaking

pumps §63.1363(c)(6)

G Yes

G Yes

G No

G No

7. Have you visually inspected each pump or agitator at

unmanned plant sites at least once per month? §63.1363(c)(8)

G Yes G No

B. Leak Repair Requirements Comments

1. Was a first attempt to repair the leak made within 5 days after

the leak was detected? First attempts to repair leaks include:

• tightening of packing gland nuts

• ensuring the seal flush is operating at design pressure and

temperature §63.1363(c)(3)

G Yes G No

2. Did you fully repair the leak within 15 days after it was

detected, unless any of the following circumstances applied:

• the repair was technically infeasible without a process unit

shutdown

• the equipment was isolated from the process and did not

remain in organic HAP service

• emissions purged from the equipment during immediate

repair would be greater than emissions resulting from

delaying the repair and using a control device to reduce the

emissions

• pump repair requires replacement of the existing seal with

a new system that will better meet the PAI rule

requirements §63.1363(c)(3)

G Yes G No

3. If you determined that a repair was technically infeasible

without a process unit shutdown, did you complete the repair

by the end of the next process unit shutdown?

§63.1363(b)(3)(i)(A) as cross referenced by §63.1363(c)(3)

G Yes G No

4. Use of a control device is necessary if you determined that

emissions purged from equipment during immediate leak

repair would be greater than emissions resulting from delaying

the repair. Did you use a control device to reduce emissions

generated during leak repair? §63.171(c) as cross referenced

by §63.1363(c)(3)

G Yes G No
DRAFT

Checklist 2: (cont’d)

Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service

B. Leak Repair Requirements Comments

151

5. If you determined that pump repair required replacement of the

existing seal with a new system to better meet the PAI rule

requirements, did you repair the leak less than 6 months from

the time when the leak was detected? §63.171(d) as cross

referenced by §63.1363(c)(3)

G Yes G No

C. Recordkeeping and Reporting Requirements Comments

1. Do your records include identification numbers for pumps and

agitators subject to the equipment leak requirements?

§63.1363(g)(2)(i)(A)

G Yes G No

2. Have you updated the list of identification numbers in question

1 within 15 days after each monitoring survey to incorporate

any equipment changes? §63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include identification numbers for pumps and

agitators with a closed-vent system and control device that are

not subject to the equipment leak monitoring requirements?

§63.1363(g)(2)(ii)(A)

G Yes G No

4. Do your records include the following information for each

dual mechanical seal system installed on a pump or agitator:

• design criteria that indicates failure of the seal system, the

barrier fluid system, or both

• your explanation of the design criteria

• any changes to the design criteria and the reasons for the

changes §63.1363(g)(2)(v)

G Yes

G Yes

G Yes

G No

G No

G No

5. Do your records include a list of equipment designated as

unsafe to monitor, difficult to monitor, or inaccessible and a

plan for monitoring or inspecting this equipment?

§63.1363(g)(2)(vi)

G Yes G No

6. Do your records include documentation that visual inspection

for leaks in pumps and agitators were conducted, including

both:

• the date if the inspection

• documentation of monitoring performed on leaking

equipment identified during the inspection §63.1363(g)(3)

G Yes G No
DRAFT

Checklist 2: (cont’d)

Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service

C. Recordkeeping and Reporting Requirements Comments

152

7. If you detected a leak, have you recorded:

• the instrument and the equipment identification number

and the operator name, initials, or identification number

• date the leak was detected, date of the first attempt to repair

the leak, and date of successful leak repair

• if post-repair monitoring is required, maximum instrument

reading measured by Method 21 of 40 CFR part 60,

appendix A, after leak is successfully repaired or

determined to be non-repairable

• whether the repair is delayed for more than 15 days after

leak discovery and the reason for the delay

• if repairs were delayed, dates of process shutdowns that

occur while the equipment is unrepaired 

• copies of periodic reports if records are not maintained on a

computerized data base capable of generating summary

reports from the records §63.1363(g)(4)

G Yes 

G Yes 

G Yes 

G Yes

G Yes

G Yes

G No 

G No 

G No 

G No

G No

G No

8. Do your records include information and analyses used to

determine that a piece of equipment is in heavy liquid service

(i.e., not “in light liquid or gas/vapor service” and therefore not

subject to equipment leak requirements)? §63.1363(g)(8)

G Yes G No

9. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No

10. Did you include the following in your periodic report for each

monitoring period during the 6-month reporting period?

• the number of pumps and agitators for which leaks were

detected, the percent leakers, and the total number of

pumps and agitators monitored

• the number of pumps and agitators for which leaks were

not repaired

• the facts that explain any delay of repairs and, where

appropriate, why a process shutdown was technically

infeasible

• if applicable, the initiation of a monthly monitoring

program if more than 10 percent of pumps in light liquid

service (or three pumps if three is greater than 10 percent)

leak §63.1363(h)(3)(ii)

G Yes 

G Yes 

G Yes 

G Yes

G No 

G No 

G No 

G No

11. Did you include any change in the Notification of Compliance

Status report in your periodic report? § 63.1363(h)(3)(iv)

G Yes G No
DRAFT

Checklist 2: (cont’d)

Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service

153
DRAFT

154

Checklist 3: Requirements for open-ended valves or lines (Option 1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Operating Requirements Comments

1. Have you equipped open-ended valves or lines with a cap,

blind flange, plug, or a second valve? §63.1363(d)(1)(i)

G Yes G No

2. Does the open end remain sealed at all times except when

either:

• operations require flow of process fluid through the

open-ended valve or line

• maintenance or repair is being conducted §63.1363(d)(1)(ii)

G Yes G No

3. Did you replace the seal within 1 hour after completion of the

activities in question 2? §63.1363(d)(1)(ii)

G Yes G No

4. If you equipped open-ended valves or lines with a second

valve, have you ensured that the valve on the process fluid end

is closed before the second valve is closed? §63.1363(d)(2)

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do your records include identification numbers for open-ended

valves or lines subject to the equipment leak requirements?

§63.1363(g)(2)(i)(A)

G Yes G No

2. Have you updated the list of identification numbers in question

1 as needed to incorporate any equipment changes?

§63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No

4. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
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Checklist 4: Requirements for valves in gas/vapor service and light liquid service (Option 1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements Comments

1. Did you perform initial monitoring for leaks using the method

in §63.180(b) by no later than 1 year after the compliance date

(e.g., by June 23, 2003 for existing sources)? §63.1363(e)(2)

G Yes G No

2. Have you assigned valves to process groups or subgroups

according to the procedures outlined in §§63.1363(e)(5) and

(6)?

G Yes G No

3. Have you determined the overall performance of valves in each

group every 6 months according to the procedures in

§§63.1363(e)(5)(iii) and (e)(6)(ii)?

G Yes G No

4. If your overall performance is $2 percent leaking valves, have

you performed monitoring at the appropriate frequency

(frequencies are specified in §63.1363(e)(5)(vii) and

(e)(6)(iii))?

G Yes G No

B. Leak Repair Requirements Comments

1. Was a first attempt to repair the leak made within 5 days after

the leak was detected? First attempts to repair leaks include:

• tightening or replacement of bonnet bolts

• tightening of packing gland nuts

• injection of lubricant into lubricated packing

§63.1363(e)(7)(ii) and (e)(8)

G Yes G No
DRAFT

Checklist 4: (cont’d)

Requirements for valves in gas/vapor service and light liquid service

B. Leak Repair Requirements Comments

156

2. Did you fully repair the leak within 15 days after it was

detected, unless any of the following circumstances applied:

• the repair was technically infeasible without a process unit

shutdown

• the equipment was isolated from the process and did not

remain in organic HAP service

• emissions purged from the equipment during immediate

repair would be greater than emissions resulting from

delaying the repair and using a control device to reduce the

emissions

• valve assembly supplies are not on hand and valve

replacement is needed during a process unit shutdown

§§63.1363(b)(3)(i) and 63.171(b) through (e) as cross

referenced by §63.1363(e)(7)(i)

G Yes G No

3. If you determined that a repair was technically infeasible

without a process unit shutdown, did you complete the repair

by the end of the next process unit shutdown?

§63.1363(b)(3)(i)(A) as cross referenced by §63.1363(e)(7)(i)

G Yes G No

4. Use of a control device is necessary if you determined that

emissions purged from equipment during immediate leak

repair would be greater than emissions resulting from delaying

the repair. Did you use a control device to reduce emissions

generated during leak repair? §63.171(c) as cross referenced

by §63.1363(e)(7)(i)

G Yes G No

5. If valve assembly supplies were not on hand during a process

unit shutdown when valve replacement was needed, did you

replace the valve assembly during the next process unit

shutdown (unless a third shutdown occurred within 6 months

from the first process unit shutdown)? §63.171(e) as cross

referenced by §63.1363(e)(7)(i)

G Yes G No

6. If you made repairs to valves, did you monitor the valves at

least once while the valves were in organic HAP service within

the first 3 months after the repairs were made?

§63.1363(e)(7)(iii)

G Yes G No

C. Recordkeeping and Reporting Requirements Comments

1. Do your records include identification numbers for valves

subject to the equipment leak requirements?

§63.1363(g)(2)(i)(A)

G Yes G No
DRAFT

Checklist 4: (cont’d)

Requirements for valves in gas/vapor service and light liquid service

C. Recordkeeping and Reporting Requirements Comments

157

2. Have you updated the list of identification numbers in question

1 within 15 days after each monitoring survey to incorporate

any equipment changes? §63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include a valve monitoring schedule?

§63.1363(g)(2)(i)(B)

G Yes G No

4. Do your records include all of the following information

pertaining to assignment of valves to process subgroups:

• which valves are assigned to each subgroup

• monitoring results and calculations made for each subgroup

for each monitoring period

• which valves are reassigned and when they were reassigned

• results of the semiannual overall performance calculation

§63.1363(e)(5)(iv)

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

5. Did you notify the Administrator of the decision to subgroup

valves earlier than 30 days before the beginning of the

monitoring period? (The notification must identify the

participating processes and the valves assigned to each

subgroup.) §63.1363(e)(5)(v)

G Yes G No

6. Do your records include a list of equipment designated as

unsafe to monitor, difficult to monitor, or inaccessible and a

plan for monitoring or inspecting this equipment?

§63.1363(g)(2)(vi)

G Yes G No

7. If you detected a leak, have you recorded:

• the instrument and the equipment identification number

and the operator name, initials, or identification number

• date the leak was detected, date of the first attempt to repair

the leak, and date of successful leak repair

• if post-repair monitoring is required, maximum instrument

reading measured by Method 21 of 40 CFR part 60,

appendix A, after leak is successfully repaired or

determined to be non-repairable

• whether the repair is delayed for more than 15 days after

leak discovery and the reason for the delay

• if repairs were delayed, dates of process shutdowns that

occur while the equipment is unrepaired 

• copies of periodic reports if records are not maintained on a

computerized data base capable of generating summary

reports from the records §63.1363(g)(4)

G Yes 

G Yes 

G Yes 

G Yes

G Yes

G Yes

G No 

G No 

G No 

G No

G No

G No
DRAFT

Checklist 4: (cont’d)

Requirements for valves in gas/vapor service and light liquid service

C. Recordkeeping and Reporting Requirements Comments

158

8. Do your records include information and analyses used to

determine that a piece of equipment is in heavy liquid service

(i.e., not “in light liquid or gas/vapor service” and therefore not

subject to equipment leak requirements)? §63.1363(g)(8)

G Yes G No

9 Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No
DRAFT

Checklist 4: (cont’d)

Requirements for valves in gas/vapor service and light liquid service

C. Recordkeeping and Reporting Requirements Comments

159

10. Did you include the following in your periodic report for each

monitoring period during the 6-month reporting period?

• the number of valves with leaks detected, the percent

leakers, and the total number of valves monitored

• the number of valves with leaks that were not repaired and

the number of those valves that are non-repairable

• the facts that explain any delay of repairs and, where

appropriate, why a process shutdown was technically

infeasible

• if applicable, the initiation of a monthly monitoring

program if 2 percent or more valves leak §63.1363(h)(3)(ii)

G Yes 

G Yes 

G Yes 

G Yes

G No 

G No 

G No 

G No

11. Did you include the following information in your periodic

report:

• valve reassignments occurring during the reporting period

• results of the semiannual overall performance calculation

§63.1363(e)(5)(vi)

G Yes 

G Yes

G No 

G No 

12. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
DRAFT

160

Checklist 5: Requirements for compressors (Option 1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Design Requirements Comments

1. Are your compressors equipped with a seal system that

includes a barrier fluid system to prevent leaks of process fluid

to the atmosphere? §63.164(a)

G Yes G No

2. Is the compressor seal system:

• operated with the barrier fluid pressure greater than the

compressor stuffing box pressure

• equipped with a barrier fluid system degassing reservoir

that is routed to a process or fuel gas system or connected

by a closed-vent system to a control device

• equipped with a closed-loop system that purges the barrier

fluid directly into a process stream §63.164(b)

G Yes

G Yes

G Yes

G No

G No

G No

3. Is the barrier fluid in heavy liquid service? §63.164(c) G Yes G No

4. Is the barrier fluid system equipped with a sensor that will

detect failure of the seal system, barrier fluid system, or both

the seal and barrier fluid system? §63.164(d)

G Yes G No

5. Have you observed the barrier fluid system failure sensor daily

(unless the sensor has an alarm or the equipment is at an

unmanned plant site) §63.164(e)

G Yes G No

6. Have you tested compressors designated to operate with an

instrument reading of less than 500 ppm above background to

ensure compliance with the 500 ppm limit upon designation

and annually. §63.164(i)

G Yes G No
DRAFT

Checklist 5: (cont’d)

Requirements for compressors

161

B. Leak Repair Requirements Comments

1. Was a first attempt to repair the leak made within 5 days after

the leak was detected? §63.164(g)

G Yes G No

2. Did you fully repair the leak within 15 days after it was

detected, unless any of the following circumstances applied:

• the repair was technically infeasible without a process unit

shutdown §63.1363(b)(3)(i)(A) as cross referenced by

§63.164(g)(1)

• the equipment was isolated from the process and did not

remain in organic HAP service §63.171(b) as cross

referenced by §63.164(g)(1)

G Yes G No

3. If you determined that a repair was technically infeasible

without a process unit shutdown, did you complete the repair

by the end of the next process unit shutdown?

§63.1363(b)(3)(i)(A) as cross referenced by §63.164(g)(1)

G Yes G No

C. Recordkeeping and Reporting Requirements Comments

1. Do your records include identification numbers for

compressors subject to the equipment leak requirements?

§63.1363(g)(2)(i)(A)

G Yes G No

2. Have you updated the list of identification numbers in question

1 to incorporate any equipment changes? §63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include identification numbers for

compressors with a closed-vent system and control device that

are not subject to the equipment leak monitoring requirements?

§63.1363(g)(2)(ii)(A)

G Yes G No

4. Do your records include identification numbers for

compressors that you designate as operating with an

instrument reading of less than 500 ppm above background

(these compressors are exempt from the monitoring

requirements) §63.1363(g)(2)(ii)(B)

G Yes G No

5. Do your records include the following information for each

compressor:

• design criteria that indicates failure of the seal system, the

barrier fluid system, or both

• your explanation of the design criteria

• any changes to the design criteria and the reasons for the

changes § 63.1363(g)(2)(v)

G Yes

G Yes

G Yes

G No

G No

G No
DRAFT

Checklist 5: (cont’d)

Requirements for compressors

C. Recordkeeping and Reporting Requirements Comments

162

6. If you detected a leak, did you record:

• the instrument and the equipment identification number

and the operator name, initials, or identification number

• date the leak was detected, date of the first attempt to repair

the leak, and date of successful leak repair

• if post-repair monitoring is required, maximum instrument

reading measured by Method 21 of 40 CFR part 60,

appendix A, after leak is successfully repaired or

determined to be non-repairable

• whether the repair is delayed for more than 15 days after

leak discovery and the reason for the delay

• if repairs were delayed, dates of process shutdowns that

occur while the equipment is unrepaired 

• copies of periodic reports if records are not maintained on a

computerized data base capable of generating summary

reports from the records §63.1363(g)(4)

G Yes 

G Yes 

G Yes 

G Yes

G Yes

G Yes

G No 

G No 

G No 

G No

G No

G No

7. Did you record the dates and results (including the measured

background level and maximum instrument reading for each

compressor) of each test to demonstrate compliance with the

500 ppm limit for designated compressors? §63.1363(g)(6)

G Yes G No

8. Do your records include information and analyses used to

determine that a piece of equipment is in heavy liquid service

(i.e., not “in light liquid or gas/vapor service” and therefore not

subject to equipment leak requirements)? §63.1363(g)(8)

G Yes G No

9. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No

10. Did you include the following in your periodic report for each

monitoring period during the 6-month reporting period?

• the number of compressors for which leaks were detected

• the number of compressors for which leaks were not

repaired

• the facts that explain any delay of repairs and, where

appropriate, why a process shutdown was technically

infeasible

• the results of all monitoring to show compliance with the

500 ppm limit for compressors designated to operate below

500 ppm §63.1363(h)(3)(ii)

G Yes 

G Yes 

G Yes 

G Yes

G No 

G No 

G No 

G No
DRAFT

Checklist 5: (cont’d)

Requirements for compressors

C. Recordkeeping and Reporting Requirements Comments

163

11. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
DRAFT

164

Checklist 6: Requirements for pressure relief devices in gas/vapor service (Option 1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirements Comments

Note: You are exempt from the requirements for pressure relief devices in gas/vapor service if your pressure

relief device is routed to a combustion unit or is equipped with a closed-vent system and control device.

§ 63.165(c)

1. Do your pressure relief devices have a leak detection

instrument reading of less than 500 ppm above background

(except during pressure releases) when monitored using the

method in §63.180(c)? §63.165(a)

G Yes G No

2. Following a pressure release:

• Did you return the pressure relief device to less than 500

ppm above background as soon as possible? §63.165(b)

• Did you either:

< monitor your pressure relief device within 5 days after

a pressure release and return of the pressure relief

device to organic HAP service to ensure a reading of

less than 500 ppm above background §63.165(b)

< place a rupture disk upstream of your pressure relief

device within 5 days following the pressure release

§63.165(d)

G Yes 

G Yes

G No 

G No

B. Recordkeeping and Reporting Requirements Comments

1. Do your records include identification numbers for pressure

relief devices subject to the equipment leak requirements?

§63.1363(g)(2)(i)(A)

G Yes G No

2. Have you updated the list of identification numbers in question

1 within 15 days after each monitoring survey to incorporate

any equipment changes? §63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include identification numbers for pressure

relief devices with a closed-vent system and control device that

are not subject to the equipment leak monitoring requirements?

§63.1363(g)(2)(ii)(A)

G Yes G No

4. Do your records include identification numbers for pressure

relief devices subject to the equipment leak provisions and

pressure relief devices with rupture disks? §63.1363(g)(2)(iii)

G Yes G No
DRAFT

Checklist 6: (cont’d)

Requirements for pressure relief devices in gas/vapor service

B. Recordkeeping and Reporting Requirements Comments

165

5. Do your records include the dates and results (including

measured background concentration and maximum instrument

reading) of monitoring after pressure releases at each pressure

relief device? §63.1363(g)(6)

G Yes G No

6. Do your records include information and analyses used to

determine that a piece of equipment is in heavy liquid service

(i.e., not “in light liquid or gas/vapor service” and therefore not

subject to equipment leak requirements)? §63.1363(g)(8)

G Yes G No

7. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No

8. Did you include the results of all monitoring to show

compliance with the 500 ppm limit in your periodic report for

each monitoring period during the 6-month reporting period?

§63.1363(h)(3)(ii)

G Yes G No 

9. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
DRAFT

166

Checklist 7: Requirements for sampling connection systems (Option 1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Design Requirements Comments

Note: In-situ sampling systems and sampling systems without purges are exempt from the above requirements

for sampling connection systems.

1. Do each of your sampling connection systems have a closedpurge, closed-loop, or closed-vent system? §63.166(a)G Yes G No

2. Do the closed-purge, closed-loop, or closed-vent systems do

one of the following:

• collect and recycle purged process fluid to a process

• capture and transport purged process fluid to a control

device

• collect, store, and transport purged process fluid to a waste

management unit, TSDF, or permitted waste management

facility §63.166(b)

G Yes G No

B. Recordkeeping and Reporting Requirements Comments

1. Do your records include identification numbers for sampling

connection systems subject to the equipment leak

requirements? §63.1363(g)(2)(i)(A)

G Yes G No

2. If necessary, have you updated the list of identification

numbers in question 1 to incorporate any equipment changes?

§63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No

4. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
DRAFT

167

Checklist 8: Requirements for pumps, valves, connectors, and agitators in heavy liquid service;

instrumentation systems; and pressure relief devices in liquid service (Option 1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring Requirement Comments

1. After detecting a potential leak, did you either:

• monitor for leaks using the method in § 63.180(b) within

5 days after the potential leak is detected 

• repair the leak such that any of the following are true:

< you can no longer see, hear, smell, or otherwise detect

the potential leak

< you see no bubbles at potential leak sites during a leak

check with soap solution

< the system will hold a test pressure

§63.169(a) and (c)(3)

G Yes G No

B. Leak Repair Requirements Comments

1. Was a first attempt to repair the leak made within 5 days after

the leak was detected? First attempts to repair leaks include:

• tightening of packing gland nuts

• ensuring the seal flush is operating at design pressure and

temperature

• tightening or replacement of valve bonnet bolts

• injection of lubricant into lubricated packing §63.169(c)(2)

and (d)

G Yes G No
DRAFT

Checklist 8: (cont’d)

Requirements for pumps, valves, connectors, and agitators in heavy liquid service; instrumentation

systems; and pressure relief devices in liquid service

B. Leak Repair Requirements Comments

168

2. Did you fully repair the leak within 15 days after it was

detected, unless any of the following circumstances applied:

• the repair was technically infeasible without a process unit

shutdown

• the equipment was isolated from the process and did not

remain in organic HAP service

• emissions purged from the equipment during immediate

repair would be greater than emissions resulting from

delaying the repair and using a control device to reduce the

emissions

• pump repair requires replacement of the existing seal with

a new system that will better meet the PAI rule

requirements

• valve assembly supplies are not on hand and valve

replacement is needed during a process unit shutdown

§§ 63.1363(b)(3)(i)(A) and 63.171 as cross referenced by

§63.169(c)(2)

G Yes G No

3. If you determined that a repair was technically infeasible

without a process unit shutdown, did you complete the repair

by the end of the next process unit shutdown? §63.171(a) as

cross referenced by § 63.169(c)(2)

G Yes G No

4. Use of a control device is necessary if you determined that

emissions purged from equipment during immediate leak

repair would be greater than emissions resulting from delaying

the repair. Did you use a control device to reduce emissions

generated during leak repair? §63.171(c) as cross referenced

by §63.169(c)(2)

G Yes G No

5. If you determined that pump repair required replacement of the

existing seal with a new system to better meet the PAI rule

requirements, did you repair the leak less than 6 months from

the time when the leak was detected? §63.175(d) as cross

referenced by §63.169(c)(2)

G Yes G No

6. If valve assembly supplies were not on hand during a process

unit shutdown when valve replacement was needed, did you

replace the valve assembly during the next process unit

shutdown (unless a third shutdown occurred within 6 months

from the first process unit shutdown)? §63.171(e) as cross

referenced by §63.169(c)(2)

G Yes G No
DRAFT

Checklist 8: (cont’d)

Requirements for pumps, valves, connectors, and agitators in heavy liquid service; instrumentation

systems; and pressure relief devices in liquid service

169

C. Recordkeeping and Reporting Requirements Comments

1. Do your records include identification numbers for equipment

(except instrumentation systems) subject to the equipment leak

requirements? (Note that connectors do not need to be

individually identified if all the connectors in an area are

identified as a group and the number of connectors is

indicated.) §63.1363(g)(2)(i)(A)

G Yes G No

2. Have you updated the list of identification numbers in question

1 within 15 days after each monitoring survey to incorporate

any equipment changes? §63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include identification of instrumentation

systems subject to the equipment leak requirements?

§63.1363(g)(2)(iv)

G Yes G No

4. If you detected a leak, have you recorded:

• the instrument and the equipment identification number

and the operator name, initials, or identification number

• date the leak was detected, date of the first attempt to repair

the leak, and date of successful leak repair

• if post-repair monitoring is required, maximum instrument

reading measured by Method 21 of 40 CFR part 60,

appendix A, after leak is successfully repaired or

determined to be non-repairable

• whether the repair is delayed for more than 15 days after

leak discovery and the reason for the delay

• if repairs were delayed, dates of process shutdowns that

occur while the equipment is unrepaired 

• copies of periodic reports if records are not maintained on a

computerized data base capable of generating summary

reports from the records §63.1363(g)(4)

G Yes 

G Yes 

G Yes 

G Yes

G Yes

G Yes

G No 

G No 

G No 

G No

G No

G No

5. Do your records include information and analyses used to

determine that a piece of equipment is in heavy liquid service?

§63.1363(g)(8)

G Yes G No

6. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No

7. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
DRAFT

170

Checklist 9: Requirements for closed-vent systems and control devices (Option 2)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Operating Requirements Comments

1. Have you operated your closed-vent system and control device

at all times when organic HAP emissions are being vented?

§63.172(m)

G Yes G No

2. If you operate a recovery or capture device (e.g., condenser,

absorber, etc.), have you met either $95 percent reduction or

20 ppmv? (The 20 ppmv standard is not applicable if you meet

the alternative standards for enclosed-vent process units.)

§63.172(b)

G Yes G No

3. If you operate an enclosed combustion device, have you met

either $95 percent reduction, 20 ppmv (dry basis, 3 percent

oxygen), or a minimum residence time of 0.5 sec. At 1400oF

(760oC)? §63.172(c)

G Yes G No

4. If you operate a flare, have you met the requirements of

§ 63.11(b)? §63.172(d)

G Yes G No

B. Monitoring and Inspection Requirements Comments

1. If your closed-vent system is made of hard-piping, did you

perform an annual visual inspection for visible, audible, or

olfactory indications of leaks? §63.172(f)(1)(ii)

G Yes G No

2. If your vapor collection system or closed-vent system is made

of duct work, did you conduct an annual inspection according

to the procedures in §63.180(b)? §63.172(f)(2)(ii) and (g)

G Yes G No

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

vent stream away from the control device and to the

atmosphere, have you done one of the following:

• Used a flow indicator that takes a reading at least once

every 15 minutes at the entrance of the bypass line.

• Secured the bypass line valve in the non-diverting position

with a car-seal or a lock-and-key type configuration.

§63.172(j)

Note: Low leg drains, high point bleeds, analyzer vents,

open-ended valves or lines, and pressure relief valves needed

for safety purposes are not subject to the monitoring

requirements for bypass lines. §63.172(j)(3)

G Yes G No
DRAFT

Checklist 9: (cont’d)

Requirements for closed-vent systems and control devices

B. Monitoring and Inspection Requirements Comments

171

4. If you secured the bypass line valve in the non-diverting

position as specified in question 3, did you visually inspect the

seal or closure mechanism monthly to ensure the valve is

maintained in the non-diverting position? §63.172(j)(2)

G Yes G No

5 If you design a closed-vent system to operate below

atmospheric pressure (instead of completing inspections), have

you equipped the system with a pressure measurement device

that can be read from a readily accessible location to verify that

negative pressure is maintained when the control device is

operating? §63.1363(b)(3)(ii)(B)

G Yes G No

C. Leak Repair Requirements Comments

1. Was a first attempt to repair the leak made within 5 days after

the leak was detected? §63.172(h)(1)

G Yes G No

2. Did you fully repair the leak within 15 days after it was

detected, unless any of the following circumstances applied:

• the repair was technically infeasible without a process unit

shutdown

• emissions resulting from immediate repair of the leak

would be greater than the fugitive emissions likely to result

from delay of repair §63.172(h)(2)(i)

G Yes G No

3. If you determined that a repair was technically infeasible

without a process unit shutdown, did you complete the repair

by the end of the next process unit shutdown? §63.172(i)

G Yes G No

D. Recordkeeping and Reporting Requirements Comments

1. Do your records include identification numbers for closed-vent

systems and control devices subject to the equipment leak

requirements? §63.1363(g)(2)(i)(A)

G Yes G No

2. Have you updated the list of identification numbers in question

1 within 15 days after each monitoring survey to incorporate

any equipment changes? §63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include a list of equipment designated as

unsafe to monitor, difficult to monitor, or inaccessible and a

plan for monitoring or inspecting this equipment?

§63.1363(g)(2)(vi)

G Yes G No
DRAFT

Checklist 9: (cont’d)

Requirements for closed-vent systems and control devices

D. Recordkeeping and Reporting Requirements Comments

172

4. If you detected a leak, have you recorded:

• the instrument and the equipment identification number

and the operator name, initials, or identification number

• date the leak was detected, date of the first attempt to repair

the leak, and date of successful leak repair

• if post-repair monitoring is required, maximum instrument

reading measured by Method 21 of 40 CFR part 60,

appendix A, after leak is successfully repaired or

determined to be non-repairable

• whether the repair is delayed for more than 15 days after

leak discovery and the reason for the delay

• if repairs were delayed, dates of process shutdowns that

occur while the equipment is unrepaired 

• copies of periodic reports if records are not maintained on a

computerized data base capable of generating summary

reports from the records §63.1363(g)(4)

G Yes 

G Yes 

G Yes 

G Yes

G Yes

G Yes

G No 

G No 

G No 

G No

G No

G No

5. If you use a flow meter to monitor your closed-vent system

bypass line, do your records include the flow meter readings?

§63.172(j)

G Yes G No

6. Do your records include all of the following design and

performance documentation:

• detailed schematics, design specifications of the control

device, and piping and instrumentation diagrams

• the dates and descriptions of any changes in the design

specifications

• the flare design (i.e., steam assisted, air assisted, or

nonassisted) and the results of the compliance

demonstration

• a description of the parameter or parameters monitored to

ensure that control devices are operated and maintained as

designed and an explanation of why each parameter was

selected for the monitoring §63.1363(g)(7)(i)

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No
DRAFT

Checklist 9: (cont’d)

Requirements for closed-vent systems and control devices

D. Recordkeeping and Reporting Requirements Comments

173

7. Do your records include all of the following operational

information:

• dates and durations when the closed-vent systems and

control devices are not operated as designed, as indicated

by the monitored parameters. Include periods when a flare

pilot light system does not have a flame

• dates and durations when the monitor is not operating

• dates and durations of startups and shutdowns of control

devices §63.1363(g)(7)(ii)

G Yes

G Yes

G Yes

G No

G No

G No

8. Do your records include all of the following inspection

information:

• if no leaks are detected during the inspection, a record that

the inspection was performed, the date of the inspection,

and a statement that no leaks were detected

• if leaks are detected during the inspection, the information

specified in question 4 must be recorded §63.1363(g)(7)(iii)

G Yes

G Yes

G No

G No

9. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No

10. Did you include the following in your periodic report for each

monitoring period during the 6-month reporting period?

• the facts that explain any delay of repairs and, where

appropriate, why a process shutdown was technically

infeasible

• the results of all monitoring to show compliance with the

provisions for inspections of closed vent systems

§63.1363(h)(3)(ii)

G Yes 

G Yes

G No 

G No 

11. Have you identified in your periodic report whether you are

complying with the monitoring, recordkeeping, and reporting

requirements in either:

• 40 CFR part 264, subpart BB, or in 40 CFR part 265,

subpart BB 

• the PAI rule §63.172(j)

G Yes G No

12. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
DRAFT

174

Checklist 10: Requirements for connectors in gas/vapor service and in light liquid service (Option

1)

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring and Inspection Requirements Comments

1. Did you monitor for leaks using the method in §63.180(b)?

§63.174(a)

G Yes G No

2. Did you perform initial monitoring of all connectors either:

• within 12 months after the compliance date at existing

sources §63.174(b)(1)

• within 12 months from initial start-up (or by no later than

12 months after the date of promulgation of subpart MMM)

at new sources §63.174(b)(2)

G Yes G No

3. Have you determined your percent leaking connectors using the

methods in §63.174(i)?

G Yes G No

4. Have you performed repeat monitoring at the time intervals

below that apply to you:

• each year if your percent leaking connectors is $0.5%

• every 4 years if your percent leaking connectors is $0.25 to

0.5%

• every 8 years if your percent leaking connectors is <0.25%

• every 2 years if your percent leaking connectors is 0.5 to

<1% § 63.174(b)(3)

G Yes G No

5. Have you monitored connectors that have been opened or have

a broken seal using one of the following two options:

• Monitored the connector for leaks when it is reconnected or

within the first 3 months after it is returned to organic HAP

service. If a leak was detected, you repaired the leak

(unless it is determined to be nonrepairable).

• Didn’t monitor the connector and didn’t count the

connector as nonrepairable. §63.174(c)(1)(i) and (ii)

G Yes G No
DRAFT

Checklist 10: (cont’d)

Requirements for connectors in gas/vapor service and in light liquid service

A. Monitoring and Inspection Requirements Comments

175

6. If you switched between the two monitoring alternatives in

question 5, did you do both of the following:

• Make the switch at the end of the current monitoring

period (if the switch is reported)

• Complete initial monitoring in the new alternative no later

than 12 months after you reported the switch

§63.174(c)(1)(iii)

G Yes

G Yes

G No

G No

7. For each screwed connector with an inside diameter of 2 inches

or less installed before November 10, 1997, have you done one

of the following

• performed repeat monitoring as described in question 4

• complied with the requirements of §63.169 of subpart H

• monitored for leaks within the first 3 months after the

screwed connector is returned to organic HAP service after

having been opened or having the seal broken and making

necessary repairs §63.174(c)(2)

G Yes G No

8. If you took credit for elimination of a connector, were all of the

following requirements are met:

• The connector was welded after November 10, 1997

• The integrity of the weld was demonstrated by monitoring,

X-ray testing, acoustic monitoring, hydrotesting, or other

method

• Welds created after November 10, 1997 but before June 23,

1999 were monitored or tested by 3 months after the

compliance date

• Welds created after June 23, 1999 were monitored or tested

within 3 months after being welded

• If an inadequate weld was found or the connector was not

welded completely around the circumference, the connector

was not exempted from the monitoring requirements

§63.174(j)

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

B. Leak Repair Requirements Comments

1. Was a first attempt to repair the leak made within 5 days after

the leak was detected? §63.174(d)

G Yes G No
DRAFT

Checklist 10: (cont’d)

Requirements for connectors in gas/vapor service and in light liquid service

B. Leak Repair Requirements Comments

176

2. Did you fully repair the leak within 15 days after it was

detected, unless any of the following circumstances applied:

• the repair was technically infeasible without a process unit

shutdown

• the equipment was isolated from the process and did not

remain in organic HAP service

• emissions purged from the equipment during immediate

repair would be greater than emissions resulting from

delaying the repair and using a control device to reduce the

emissions §§63.1363(b)(3)(i) and 63.171 as cross

referenced by §63.174(d)

G Yes G No

3. If you determined that a repair was technically infeasible

without a process unit shutdown, did you complete the repair

by the end of the next process unit shutdown?

§63.1363(b)(3)(i)(A) as cross referenced by §63.174(d)

G Yes G No

4. Use of a control device is necessary if you determined that

emissions purged from equipment during immediate leak

repair would be greater than emissions resulting from delaying

the repair. Did you use a control device to reduce emissions

generated during leak repair? §63.171(c) as cross referenced

by § 63.174(d)

G Yes G No

C. Recordkeeping and Reporting Requirements Comments

1. Do your records include either:

• identification numbers of connectors subject to the

equipment leak requirements

• identification of groups of connectors and the number of

connectors in each group §63.1363(g)(2)(i)(A)

G Yes G No

2. Have you updated the list of identification numbers in question

1 within 15 days after each monitoring survey to incorporate

any equipment changes? §63.1363(g)(2)(i)(A)

G Yes G No

3. Do your records include a schedule for monitoring connectors?

§63.1363(g)(2)(i)(B)

G Yes G No

4. Do your records include a list of equipment designated as

unsafe to monitor, difficult to monitor, or inaccessible and a

plan for monitoring or inspecting this equipment?

§63.1363(g)(2)(vi)

G Yes G No
DRAFT

Checklist 10: (cont’d)

Requirements for connectors in gas/vapor service and in light liquid service

C. Recordkeeping and Reporting Requirements Comments

177

5. Do your records include a list of connectors removed from or

added to the process if you used credits for removed connectors

when calculating the percent leaking connectors?

§63.1363(g)(3)

G Yes G No

6. Do your records include documentation of the integrity of the

weld for any removed connectors if you use the credit for

removed connectors? § 63.1363(g)(2)(vii)

G Yes G No

7. If you detected a leak, have you recorded:

• the instrument and the equipment identification number

and the operator name, initials, or identification number

• date the leak was detected, date of the first attempt to repair

the leak, and date of successful leak repair

• if post-repair monitoring is required, maximum instrument

reading measured by Method 21 of 40 CFR part 60,

appendix A, after leak is successfully repaired or

determined to be non-repairable

• whether the repair is delayed for more than 15 days after

leak discovery and the reason for the delay

• if repairs were delayed, dates of process shutdowns that

occur while the equipment is unrepaired 

• identification of connectors in gas/vapor and light liquid

service disturbed since the last monitoring period (unless

you use the option for not monitoring open connectors

during the monitoring period). Connector identification

may be maintained either by list, location, or tagging. 

• date and results of follow-up monitoring for open or

disturbed connectors. If identification of disturbed

connectors is made by location, then all connectors within

the designated location must be monitored

• copies of periodic reports if records are not maintained on a

computerized data base capable of generating summary

reports from the records §63.1363(g)(4)

G Yes 

G Yes 

G Yes 

G Yes

G Yes

G Yes

G Yes

G Yes

G No 

G No 

G No 

G No

G No

G No

G No

G No

8. Do your records include information and analyses used to

determine that a piece of equipment is in heavy liquid service

(i.e., not “in light liquid or gas/vapor service” and therefore not

subject to equipment leak requirements)? §63.1363(g)(8)

G Yes G No

9. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No
DRAFT

Checklist 10: (cont’d)

Requirements for connectors in gas/vapor service and in light liquid service

C. Recordkeeping and Reporting Requirements Comments

178

10. Did you include the following in your periodic report for each

monitoring period during the 6-month reporting period?

• the number of connectors in gas/vapor or light liquid

service for which leaks were detected as described, the

percent of connectors leaking, and the total number of

connectors monitored

• the number of connectors in gas/vapor or light liquid

service for which leaks were not repaired, identifying the

number of those that are determined non-repairable

• the facts that explain any delay of repairs and, where

appropriate, why a process shutdown was technically

infeasible

• if applicable, notification of a change in connector

monitoring alternatives for connectors that have been

opened or have broken seals §63.1363(h)(3)(ii)

G Yes 

G Yes 

G Yes 

G Yes

G No 

G No 

G No 

G No

11. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
DRAFT

179

Checklist 11: Requirements for equipment meeting alternative means of emission limitation

Facility Name: ________________________________________________________

Facility Location: ________________________________________________________

Facility TRI ID #: ________________________________________________________

Inspector: ________________________________________________________

Date: ________________________________________________________

Note: A “yes” response to all questions in this checklist means compliance, and a “no” response means

noncompliance.

A. Monitoring and Inspection Requirements Comments

Note: There are three types of alternative standards for equipment leaks: (1) pressure testing of batch or nonbatch equipment [§63.178 with changes described in §63.1363(b)(3)(iv)], monitoring of batch equipment for

leaks [§63.178 with changes described in §63.1363(b)(3)(iv)], or (3) enclosure of process units so that all

emissions from equipment leaks are vented through a closed-vent system to a control device [§63.179]. Question

1 applies for pressure testing, question 2 applies for monitoring batch equipment for leaks, and question 3 applies

for enclosure of process units.

1. Did you perform pressure testing at the following intervals

using the procedures in § 63.180(f) for pressure or vacuum loss

or § 63.180(g) for a test using liquid?

• each time the equipment is reconfigured for production of a

different product

• at lest once per year § 63.178(b)(1)

G Yes

G Yes

G No

G No

2. Did you monitor batch equipment for leaks when equipment is

in organic HAP use or use with an acceptable surrogate or

detectable gas or vapor and at the following intervals:

• within 30 days of process start-up each time the equipment

is reconfigured for production of a new product

• at the frequencies specified in § 63.178(c)(3)(iii)

§63.178(c)(3)

G Yes

G Yes

G No

G No

3. For process units enclosed so that all emissions from

equipment leaks are vented through a closed system and

control device, did you maintain the process unit enclosure

under negative pressure at all times? §63.179

G Yes G No

B. Leak Repair Requirements Comments

Note: Questions 1 and 3 apply for pressure testing and questions 2 and 3 apply for monitoring of batch

equipment for leaks.

1. If you detected a leak during pressure testing under the

alternative standard, did you do one of the following:

• repair the leak and retest the equipment before process

start-up

• repair the leak within 30 days after the second pressure test

if the equipment failed the second test §63.178(b)(4)

G Yes G No
DRAFT

Checklist 11: (cont’d)

Requirements for equipment meeting alternative means of emission limitation

B. Leak Repair Requirements Comments

180

2. If you detected a leak when monitoring batch processes under

the alternative standard, did you repair the leak within no more

than 15 days after the leak was detected (unless you met the

delay of repair provisions)? §63.178(c)(4)

G Yes G No

3. If you delayed repair of leaks under the alternative standard,

did all the following circumstances apply :

• replacement equipment was not available

• equipment supplies (which were sufficiently stocked) have

been depleted

• the repair is made no later than 10 days after delivery of the

replacement equipment §63.178(d)

G Yes

G Yes

G Yes

G No

G No

G No

C. Recordkeeping and Reporting Requirements Comments

Note: Questions 1, 2, 3, 4, 8, and 9 apply for monitoring of batch equipment for leaks, questions 5, 6, 8, and 9

apply for pressure testing, and questions 7, 8, and 9 apply for enclosed vent processes.

1. Do your records include identification numbers for equipment

subject to the equipment leak requirements?

§63.1363(g)(2)(i)(A)

G Yes G No

2. Have you updated the list of identification numbers in question

1 within 15 days after each monitoring survey to incorporate

any equipment changes? §63.1363(g)(2)(i)(A)

G Yes G No

3 Do your records include a list of equipment added to batch

processes since the last monitoring period? §63.1363(g)(2)(viii)

G Yes G No

4 Do your records include the monitoring date and results for

equipment added to a batch process since the last monitoring

period? §63.1363(g)(4)(viii)

G Yes G No
DRAFT

Checklist 11: (cont’d)

Requirements for equipment meeting alternative means of emission limitation

C. Recordkeeping and Reporting Requirements Comments

181

5. If you show compliance with the equipment leak provisions by

pressure testing equipment, have you maintained records of all

of the following:

• identification of each product, or product code, produced

during the calendar year

• the portion of time during the year the equipment is in use

in the PAI process. (These records are not required if you

do not adjust monitoring frequency by the time in use.)

• identification of equipment on a plant site plan, in log

entries, or by other appropriate methods.

• the dates of each pressure test, the test pressure, and the

pressure drop observed during the test

• records of any evidence of fluid loss detected by sight,

sound, or odor

• all of the following information if a process equipment

train failed two consecutive pressure tests (this information

must be kept for 2 years):

< The dates of each pressure test and leak repair attempt

< Repair methods applied in each attempt to repair the

leak

< The reason for the delay of repair

< The expected date for delivery of the replacement

equipment and the actual date of delivery of the

replacement equipment

< The date of successful repair §63.1363(g)(5)

G Yes

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No

G No

6. Does your periodic report include all of the following

information:

• product process equipment train identification

• the number of pressure tests conducted

• the number of pressure tests where the equipment train

failed either the retest or two consecutive pressure tests

• explanation for any delay of repair

• the results of all monitoring to determine compliance with

the standards for inspection of closed-vent systems

§63.1363(h)(3)(iii)

G Yes

G Yes

G Yes

G Yes

G Yes

G No

G No

G No

G No

G No
DRAFT

Checklist 11: (cont’d)

Requirements for equipment meeting alternative means of emission limitation

C. Recordkeeping and Reporting Requirements Comments

182

7. If you comply with the alternative means of emission limitation

for enclosed-vent processes, have you maintained records of all

of the following:

• identification of the processes and the organic HAP they

handle

• a schematic of the process, enclosure, and closed-vent

system.

• a description of the system used to create a negative

pressure in the enclosure to ensure that all emissions are

routed to the control device §63.1363(g)(10)

G Yes

G Yes

G Yes

G No

G No

G No

8. Do your records include identification (by list, location, or

other method) of equipment that is in organic HAP service less

than 300 hr/yr? §63.1363(g)(9)

G Yes G No

9. Did you include any change in the Notification of Compliance

Status report in your periodic report? §63.1363(h)(3)(iv)

G Yes G No
DRAFT

183
DRAFT

184

Chapter 7 - Calculations and procedures

NOT AVAILABLE
DRAFT

185
DRAFT

186

Chapter 8 - Recordkeeping and Reporting

NOT COMPLETE 

What records must I keep?

What do I have to report and when?

You will need to complete several different notifications and reports based on the types of

emission points at your facility and the compliance options you choose. The term “reports” is used

in this section to include both notifications and reports. Table 8-1 (page 187) shows what reports

you must submit and when they are due. Table 8-2 (page 189) gives you details about what should

be included in these reports.

How can I change the date my reports are due?

Where do I send my reports?
DRAFT

187

TABLE 8-1. Report Due Dates

If you have . . . And need to submit a(n) . . . Then submit the report

before . . .

An existing affected source Initial Notification Report [§63.1368(b)] 10/23/99

(120 days after the effective date)

Application for Approval of Construction or

Reconstruction if reconstructing after 6/23/02

(effective date) [§§63.1368(c) and 63.5(d)]

Precompliance Plan [§63.1368(e)] 12/23/01

(6 months before the compliance

date)

Compliance Extension Request

[§§63.1368(n) and 63.1364(a)(2)]

2/23/02

(120 days before the compliance

date)

Notification of continuous monitoring system

performance evaluation [§63.1368(d)]

Notification of Performance Test and Test

Plan [§63.1368(m)]

60 days before the test

Notification of Compliance Status Report

[§63.1368(f)]

11/20/02

(150 days after the compliance

date)

Initial Semi-annual Periodic Report

[§63.1368(g)]

7/20/03 (include information

from 11/20/02 - 5/20/03)

Note: Quarterly reporting is required if you

comply with the alternative standard and you

have excess emissions [§63.1368(g)(1)(ii)]

(240 days after the Notification

of Compliance Status Report)

Subsequent Semi-annual Periodic Reports

[§63.1368(g)]

1/20/04 (include information

from 5/21/03 - 11/19/03)

7/20/04 (include information

from 11/20/03 - 5/20/04)

(60 days after each 6-month

period)

Startup, Shutdown, and Malfunction Reports

[§63.1368(j)]

Semi-annually – can submit with

the Periodic reports

Equipment Leak Reports [§63.1368(j)] Semi-annually – submit with the

Periodic reports

Reports of Heat Exchange Systems

[§63.1368(e)]

Semi-annually – submit with the

Periodic reports
DRAFT

If you have . . . And need to submit a(n) . . . Then submit the report

before . . .

188

Reports of Emissions Averaging

[§63.1368(k)]

Not clear – should be with each

Periodic report

Notification of Process Change [§63.1368(h)] Quarterly – submit with the

Periodic report or on 4/20 or

10/20

A new affected source Initial Notification Report

Application for Approval of Construction or

Reconstruction

Precompliance plan

Notification of continuous monitoring system

performance evaluation

Notification of Performance Test and Test

Plan

Notification of Compliance Status Report

Initial Semi-annual Periodic Report

Subsequent Semi-annual Periodic Reports

Startup, Shutdown, and Malfunction Reports

Equipment Leak Reports

Reports of Heat Exchange Systems

Notification of Process Change
189

TABLE 8-2. Reporting Requirements

If you are submitting

a(n) . . .

then submit buy . . . and include the following information . . . according to these sections

of the rule . . .

Initial Notification

Report

120 days after the effective

date or 120 days after rule

applies to your facility

Name and address of owner or operator.

Address (physical location) of the facility.

Compliance date.

Brief description of nature, size, design, and method of operation.

Identify each point of emission for each hazardous air pollutant.

Statement of whether you’re a major or area source.

§63.1368(b); §63.9(b)

Application for

Approval of

Construction or

Reconstruction

Before construction or

reconstruction

Applicant’s name and address.

Notification of intent to construct or reconstruct.

Address (physical location) of the facility.

Identify the standard you’re subject to.

Date that you expect to start construction or reconstruction.

Date that you expect to finish construction or reconstruction.

Type and amount of HAP you’re emitting or expect to emit.

For construction, description of proposed nature, size, design,

method of operation and emission controls and other information

under §63.5(d)(2).

For reconstruction, brief description of the facility, parts to be

replaced and emission controls and other information under

§63.5(d)(3).

§63.1368(c); §63.5(d)
190

TABLE 8-2. (cont’d)

If you are submitting

a(n) . . .

then submit buy . . . and include the following information . . . according to these sections

of the rule . . .

Precompliance Plan 6 months before

compliance data

Requests for approval to use alternative monitoring parameters.

Description of your daily or per batch demonstrations to verify

that control devices with inlet HAP emissions <1 ton/yr are

operating as designed.

Data and rationale used to set monitoring parameter levels for

conditions other than the peak case.

Your Pollution Prevention Demonstration Summary.

Data and rationale for engineering assessments.

Your Operation and Maintenance Plan for fabric filters that are

monitored with bag leak detectors.

§63.1368(e)

Notification of

Compliance Status

Report

150 days after the

compliance date

Results of applicability determinations

Results of emission profiles, performance tests, engineering

analyses, design evaluations or other calculations used to

demonstrate compliance

Anticipated periods of planned routine maintenance for control

devices used to comply with Option 4A, B, C, or E for storage

vessels

Provide the following information for each group of processes

subject to the equipment leak provisions: [§63.1363(h)(2)(i)]

• identification of the group of processes.

• approximate number of each equipment type (e.g., valves,

pumps) in organic HAP service, excluding equipment in

vacuum service.

• method of compliance with the standard (e.g., “monthly leak

detection and repair” or “equipped with dual mechanical

seals”).

Provide the following information for each process subject to the

equipment leak requirements for pressure testing: 

§63.1368(f)
191

TABLE 8-2. (cont’d)

If you are submitting

a(n) . . .

then submit buy . . . and include the following information . . . according to these sections

of the rule . . .

[§63.1363(h)(2)(ii)]

• products or product codes subject to the equipment leak

provisions

• planned schedule for pressure testing when equipment is

configured for production of products subject to the equipment

leak provisions

Provide the following information for each process subject to the

equipment leak requirements for enclosed-vent process units: 

[§63.1363(h)(2)(iii)]

• process identification

• a description of the system used to create a negative pressure

in the enclosure and the control device used to comply with the

requirements for closed-vent systems and control devices

Semi-annual Periodic

Reports

Semi-annually no later

than 60 days after the end

of the 6-month reporting

period

§63.1368(g)

Startup, Shutdown, and

Malfunction Reports

§63.1368(i)

Equipment Leak

Reports

Semi-annually--submit

with the Periodic reports

• the number of valves in gas/vapor or light liquid service for

which leaks were detected, the percent leakers, and the total

number of valves monitored

• the number of valves in gas/vapor or light liquid service for

which leaks were not repaired and the number of those valves

that are non-repairable

• the number of pumps in light liquid service and agitators in

gas/vapor or light liquid service for which leaks were detected,

§63.1363(h)(3)(ii)
192

TABLE 8-2. (cont’d)

If you are submitting

a(n) . . .

then submit buy . . . and include the following information . . . according to these sections

of the rule . . .

the percent leakers, and the total number of pumps and

agitators monitored

• the number of pumps in light liquid service and agitators in

gas/vapor or light liquid service for which leaks were not

repaired

• the number of compressors for which leaks were detected

• the number of compressors for which leaks were not repaired

• the number of connectors in gas/vapor or light liquid service

for which leaks were detected as described in §63.174(a), the

percent of connectors leaking, and the total number of

connectors monitored

• the number of connectors in gas/vapor or light liquid service

for which leaks were not repaired, identifying the number of

those that are determined non-repairable

• the facts that explain any delay of repairs and, where

appropriate, why a process shutdown was technically

infeasible.

• the results of all monitoring to show compliance with the

provisions for:

< compressors designated to operate with an instrument

reading on less than 500 ppm [§63.164(i)]

< pressure relief devices in gas/vapor service operated with

an instrument reading of less than 500 ppm [§63.165(a)]

< inspections of closed vent systems [§63.172(f)]

• if applicable, the initiation of a monthly monitoring program if

more than 10 percent of pumps in light liquid service (or three

pumps if three is greater than 10 percent) leak or if 2 percent

or more valves leak.
193

TABLE 8-2. (cont’d)

If you are submitting

a(n) . . .

then submit buy . . . and include the following information . . . according to these sections

of the rule . . .

• if applicable, notification of a change in connector monitoring

alternatives for connectors that have been opened or have

broken seals.

You must submit the following information in your periodic

reports for valves in gas/vapor service and light liquid service:

• valve reassignments occurring during the reporting period

• results of the semiannual overall performance calculation

§63.1363(e)(5)(vi)

If you elect to conduct pressure tests according to §63.178(b),

your Periodic report must include all of the following

information:

• product process equipment train identification

• the number of pressure tests conducted

• the number of pressure tests where the equipment train failed

either the retest or two consecutive pressure tests

• explanation for any delay of repair

• the results of all monitoring to determine compliance with the

standards for inspection of closed-vent systems

§63.1363(h)(3)(iii)

If any of the information you submitted in the Notification of

Compliance Status report changes, you must describe the change

in the next Periodic report.

§63.1363(h)(3)(iv)

Reports of Emissions

Averaging

§63.1368(k)

Notification of Process

Change

§63.1368(h)
DRAFT

194
DRAFT

195

Definition. An eligible Tribe means “a Tribe that has been

determined by the EPA to meet criteria for being treated in

the same manner as a State, pursuant to the regulations

implementing section 301(d)(2) of the Act.”

Chapter 9 - Other requirements and information

Who administers this regulation?

Your State or local agency for air pollution control, or your EPA Regional Office, will regulate

you. If your plant is in Indian Country, and your eligible Tribe or your EPA Regional Office will

regulate you. You may be regulated by one or more agencies depending on whether they’ve been

granted delegation of this rule. 

Not all States have been granted delegation, or, if they have been granted delegation, they may not

have been delegated all portions of the rule. Our EPA Regional Offices may also have retained

certain rights even after delegation (for example, you may continue to have dual reporting

requirements as explained in Chapter 8). You should check with your EPA Regional Office or

State for the latest information.

Do I need a title V permit?

You’ll need a title V permit if you’re subject to the Pesticide Active Ingredient NESHAP since,

under title V, you must get a permit if your facility is a major source. The Pesticide Active

Ingredient NESHAP applies to major sources.

To determine if your facility is a major source, you’ll need to calculate your HAP emissions from

your entire facility, not just your foam operations. If you don’t have federally enforceable limits in

a State permit, you must calculate your emissions by determining your potential emissions. If you

need help determining if your facility is a major source or what your potential emissions are, see

the definitions in the Operating Permits Rule §70.2, or visit our title V policy and guidance page at

www.epa.gov/ttn/oarpg/t5main.html.
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How do I change my permit to include this rule?

If you’ve already been issued a final title V permit and you have three or more years left on your

permit, your permitting authority will reopen your permit within 18 months of the publication date

of the final rule or final amendments. If you have less than three years left on your permit, update

your permit during your renewal period. If your permit hasn’t been issued in final form, update

your application or draft permit.

To summarize, your options are as follows:

If a new rule is effective1,2

and you have . . . 

Then . . . 

not been issued a final title V permit update your permit application or draft permit

less than three years left on your permit update your title V permit during renewal

three or more years left on your permit your permitting authority will reopen your permit within 18

months after the publication date of the final rule or final

amendments

1 The rule’s effective date is the date the final rule is published in the Federal Register (which is 6/23/99 for this

rule).

2 This also applies if existing rules are modified and final amendments are published in the Federal Register.

Title V permitting rules may change after the publication of this document. Keep abreast of any

changes by checking the Federal Register or visit our title V websites at

www.epa.gov/ttn/oarpg/t5main.html and www.epa.gov/oar/oaqps/permits/.

What portions of the General Provisions apply?

The General Provisions were published in the Federal Register on March 16, 1994 (Volume 59,

page 12408) and apply to all NESHAPs, including the Pesticide Active Ingredient NESHAP.

This means that when you became subject to this rule, you also became subject to the General

Provisions. Some sections in this rule override the General Provisions. You’ll find that Table 1 of

the final rule shows you which sections of the General Provisions apply to this rule and which

don’t. General Provision requirements, except for notification and reporting are not addressed in

this document. 
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If you have questions about this rule, you should

contact your State, local or Tribal agency before

calling the EPA. Their rules may be more

stringent than Federal requirements.

Chapter 10 - Getting additional help

Whom can I ask for help?

You can go to a lot of places for help, including all of the following:

C your State, local or Tribal agency for air pollution control

C your State’s Small Business Assistance Program (SBAP)

C local, regional, or National Trade Associations

C your EPA Regional Office

State and local contacts can change frequently. To get the most current contact information, go

to the STAPPA/ALAPCO website (www.4cleanair.org) and then the membership directory. The

directory will give you the latest contact points for major air programs (that is, emission standards

for toxic air pollutants, ozone, etc.) at the State and local level.

Many States have a Small Business Assistance Program. If you’re a small business and don’t

know who your SBAP is, you can call EPA's Control Technology Center Hotline at (919) 541-

0800 or visit EPA’s SBAP at www.epa.gov/oar/oaqps/sbap for help.

Contact numbers for EPA’s Regional Air Division Offices may also change frequently. To obtain

the most up-to-date information, you may want to visit your Regional Office’s website. Table

10.1 lists each of our Regional Offices, the Air Toxics Division Phone and Address, and the

Regions Internet home page. Make all written inquiries to the attention of “NESHAP (insert rule

name) Contact.”
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Can I get more information on the Web?

You can get a wealth of information on the World Wide Web (WWW). Some of the more popular

ways to get information on this rule include:

C EPA’s Unified Air Toxics Website (www.epa.gov/ttn/uatw) 

You can download copies of preambles, regulations, background information documents,

policy memos, and other guidance materials here. All rule pages can be found under the

Rules and Implementation page. Pesticide active ingredient can be found under

www.epa.gov/ttn/uatw/pest/pestpg.html.

C EPA’s Applicability Determination Index (ADI)

(http://es.epa.gov/oeca/eptdd/adi.html) 

EPA’s Office of Enforcement and Compliance Assurance (OECA) posts memos dealing

with applicability and compliance at this site.

C OECA Compliance Assistance Centers (http://www.epa.gov/epahome/business.htm)

You can find information on compliance with federal regulations at this site. There are

centers for printing, automotive services and repair, agriculture, and metal finishing

industries. We plan to add centers for the chemical industry, printed wiring board

manufacture, transportation, and local governments.

C STAPPA/ALAPCO home page (http://www.4cleanair.org)

STAPPA/ALAPCO is the State and Territorial Air Pollution Program Administrators

(STAPPA) and Local Air pollution Control Officials (ALAPCO) organization. 

STAPPA/ALAPCO has members representing each State and local agency for air pollution

control. 

You can get air pollution information at this site, including a document entitled

“Communicating Air Quality: A Compendium of Resources.” It lists educational

materials on air pollution that State and local agencies have created.
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TABLE 10-1. EPA Regional Air Division Offices

EPA Regional Office - MACT Implementation Contact 

Division Information*

EPA Region States

Covered

Division Phone and

 Address

Division Phone /

RO Home Page

Region I CT, ME, MA,

NH, RI & VT

Office of Environmental Stewardship (SEA) or

Office of Ecosystem Protection (CAP)

1 Congress Street, Suite 1100

Boston, MA 02114-2023

Attention: NESHAP (MACT) Contact

(617) 918-1510

www.epa.gov/region1

Region II NJ, NY, Puerto

Rico & Virgin

Islands

Division of Environmental Planning and Protection 

290 Broadway

21st Floor

New York, NY 10007-1866

(212) 637-3735

www.epa.gov/region2

Region III DE, MD, PA,

VA, WV & DC

Air Protection Division, 3AP111

1650 Arch Street

Philadelphia, PA 19103-2029

(215) 814-2056

www.epa.gov/region3

Region IV AL, FL, GA, KY,

MS, NC, SC &

TN

Air, Pesticides and Toxics Management Division

Atlanta Federal Center

61 Forsyth Street

Atlanta, GA 30303-3104

(404) 562-9077

www.epa.gov/region4

Region V IL, IN, MI, WI,

MN & OH

Air and Radiation Division

77 West Jackson Blvd.

Chicago, IL 60604-3507

(312) 353-2212

www.epa.gov/region5

Region VI AR, LA, NM,

OK & TX

Multimedia Planning and Permitting Division (6PD)

or Compliance Assurance & Enforcement 

Division (6EN)

1445 Ross Avenue

Dallas, TX 75202-2733

(214) 665-7250/

(214) 665-7220

www.epa.gov/region6

Region VII IA, KS, MO &

NE

Air, RCRA and Toxics Division

901 North 5th Street

Kansas City, KS 66101

(913) 551-7020

www.epa.gov/region7

Region VIII CO, MT, ND,

SD, UT & WY

Office of Enforcement, Compliance and

Environmental Justice (ECEJ) or

Office of Partnerships and Regulatory Assistance

(OPRA)

999 18th Street

1 Denver Place, Suite 500

Denver, CO 80202-2405

(303) 312-7028/

(303) 312-6294

www.epa.gov/region8

Region IX AZ, CA, HI, NV,

American Samoa,

& Guam

Air Division

75 Hawthorne Street

San Francisco, CA 94105

(415) 744-1219

www.epa.gov/region9

Region X AK, ID, WA &

OR

Office of Air Quality

1200 Sixth Avenue

Seattle, WA 98101

(206) 553-1505

www.epa.gov/region10

 * Information subject to change without notice. For the latest information, please visit the Regional Office Website.
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Is there a list of commonly asked questions?

For a list of questions and answers about the final rule, you’ll find EPA’s “National Emission

Standards for Hazardous Air Pollutants (NESHAP) for Pesticide Active Ingredient Production: 

Summary of Public Comments and Responses, May, 1999 (EPA-453/R-98-011) useful. You can

download the document by going to our UATW Pesticide Active Ingredient page at

www.epa.gov/ttn/uatw/pest/pestpg.html.
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EPA’s “Enabling Document: Source Identification Procedures for

Sources Subject to Regulations Under Section 112(d) of the Clean Air

Act as Amended in 1990”, September 20, 1996 (otherwise known as

the “Cookbook”), can help you identify the steps you can take to locate

more sources.

You can download the cookbook by going to

www.epa.gov/ttn/uatw/eparules.html, scroll down until you see “MACT

Implementation Strategy.” The cookbook is in Appendix G of this

document.

Chapter 11 - Supplemental information for State and 

local agencies and Tribes

How many plants may need to meet emission limits?

According to information we collected in 1995, we estimated that approximately 78 pesticide

active ingredient production plants might be affected by this rule.

You will find a list of the facilities that may be affected by the rule on the following page. We’ve

included the list as a reference for you, not as an official or complete list of regulated plants.

Are plants in Indian country regulated by the State?

Generally, State rules aren’t enforceable in Indian country. When we delegate authority to States

under section 112(d), the authority to regulate doesn’t extend to Indian country unless the

delegation agreement says so.

We encourage tribes to develop the capacity to administer section 112(d) programs and to request

delegation. If we don’t delegate the authority to carry out section 112(d) rules to an eligible Tribe,

the EPA Regional Office will be the regulatory authority.

How much HAP emissions will the rule reduce?

We estimate that full implementation of the rule will reduce HAP emissions by about 2,760 tons

annually. 
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Company name City State

American Cynamid Co. Hannibal MO

Buckman Laboratories

Inc.

Cadet MO

Farmland Industries St. Joseph MO

FMC Corporation Bessemer City NC

Occidental Chemical Castle Hayne NC

Zeneca Inc. Perry OH

Du Pont Manati PR

Eastman KodakTennessee EastmanKingsport TN

Great Lakes Chemical

Corp.

Newport TN

Olin Corp. Charleston TN

Zeneca Inc. Mt. Pleasant TN

Dow Chemical Freeport TX

Du Pont LaPorte TX

ISK Biotech Corp. Houston TX

Sandoz Agro Inc. Beaumont TX

Schenectady International Freeport TX

Zeneca Inc. Pasadena TX

Cytec Industries Willow Island WV

Du Pont Belle WV

PPG Industries New

Martinsville

WV

Rhone-Poulenc Ag. Co. Institute WV

Union Carbide South

Charleston

WV

Company name City State

Ciba Geigy McIntosh AL

Du Pont Axis AL

Zeneca Inc. Bucks AL

Arkansas Eastman

Division

Magness AR

Ethyl Corporation Magnolia AR

Great Lakes

Chemical Corp.

El Dorado AR

Dow Chemical Pittsburg CA

Zeneca Inc. Richmond CA

Uniroyal Chemical Naugatuck CT

Monsanto Co. Muscatine IA

Abbott Labs North

Chicago

IL

Lonza Inc. Mapleton IL

Monsanto Co. Sauget IL

Morton

International

Ringwood IL

Riverdale Chemical

Co.

Chicago

Heights

IL

Vulcan Chemicals Wichita KS

Elf Atochem N.A.,

Inc.

Carrollton KY

Ciba Geigy St. Gabriel LA

Uniroyal Geismar LA

FMC Corp. Ag.

Chem. Group

Baltimore MD

Anderson

Development

Company

Adrian MI

Dow Chemical Midland MI

SUBSET OF MAJOR SOURCES INCLUDED IN THE PESTICIDE

ACTIVE INGREDIENT MANUFACTURING INDUSTRY

[excerpted from Proposed BPD]

Below is a list of potential sources that manufacture pesticide active ingredients and

which may be subject to this subpart. This list should not be considered all inclusive as

sources who are not on this list may also be subject to the NESHAP. In addition,

sources identified in list may no longer be subject to the NESHAP.
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Estimated National HAP Emission Reductions

[Pending]
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Appendix A- Subpart MMM, final rule

(Copy of rule can be found at www.epa.gov/ttn/uatw/pest/pestpg.html)
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TECHNICAL REPORT DATA

1. REPORT NO. 2. 3. RECIPIENT'S

4. TITLE AND SUBTITLE

Implementation Document for the Pesticide Active

Ingredient Production NESHAP (40 CFR 63,

Subpart MMM)

5. REPORT DATE

 October 2000

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S)

Midwest Research Institute (MRI)

Ingrid Ward, EPA/OAQPS/ITPID/PRG

8. PERFORMING ORGANIZATION REPORT NO.

 

9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.

11. CONTRACT/GRANT NO.

68D30008

12. SPONSORING AGENCY NAME AND ADDRESS

 Office of Air Quality Planning and Standards

 Office of Air and Radiation

 U.S. Environmental Protection Agency

13. TYPE OF REPORT AND PERIOD COVERED

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14. SPONSORING AGENCY CODE

 EPA/200/04

15. SUPPLEMENTARY NOTES

 Project Officer is Carolyn Wigington, Mail Drop 13 (919-541-5374)

 Work Assignment Manager is Ingrid Ward, Mail Drop 12 (919-541-0300)

16. ABSTRACT

National emissions standards to control emissions of HAP from major sources producing

pesticide active ingredients were published in Federal Register 6/23/99, 64 FR 33550. This

document contains information to help State and local agencies for air pollution control, as well

as the regulated community, carry out these standards. The document summarizes the

NESHAP requirements and inspection checklists, and example notification and reporting

forms. The document also provides information on where to submit reports, go to for

additional help and applicability of foam sources to such things as General Provisions and Title

V. A copy of the rule is provided in hard copy format. An electronic version of this document

can be download at www.epa.gov/ttn/uatw/pest/pestpg.html. 

17. KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI

Air pollution Title III

Air pollution control NESHAP

National emissions standards Compliance

Hazardous air pollutants 40 CFR 63

Pesticide Active Ingredient Subpart MMM

Air pollution control

18. DISTRIBUTION STATEMENT

 Unlimited

19. SECURITY CLASS (Report)

 Unclassified

21. NO. OF PAGES

205

20. SECURITY CLASS (Page)

 Unclassified

22. PRICE

no cost