p.1 

OAR Box 1168 

Prepped by Ollie Stewart 

Document Number: 

101) ll-C-30 

Docket Number: 

A-89-10 

Printed 4/29/2008 11:23:20 AM Sheet 101 of 131 
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ft 

LAW OFFICES 

PHILIP J. HARTER 

SUITE 404 

2301 M STREET. N.W. 

WASHINGTON, D.C. 20037 

(202) 887.1033 

FAX: (202) 887.1036 

L ERA AIR pec:< 

October 5, 1990 

MEMORANDU M 

-> 

To: EPA Negotiated Rulemaking Committee on Fugitive Emissions 

Fr: Philip J. Harter 

Re: Proposed Change in Flange Standard 

CMA has proposed a revision in the flange standard based on 

further analysis and comments from constituent companies after our 

August workgroup meeting. The proposal would provide a company 

with an option: It could (1) follow the rule as currently written 

in which it would have to monitor each flange within 60 days and it 

would have the benefit of an unrepairable pool. Or, (2) the 

company could elect to forgo the unrepairable pool and would not 

have to separately monitor the opened flanges (i.e., they would be 

treated as any other flange for purposes of monitoring). A company 

would have to elect at the outset which option it chooses to 

follow. It may change from one to the other, but only by starting 

anew with annual monitoring. The result of exercising this option 

would be that 0.5% of all flanges in the plant must be below 500 

ppm at all times, and hence the performance requirement is actually 

tighter than the current proposal while affording flexibility. 

CMA's .explanation and proposed change is attached. 

Because time is very short, unless I hear to the contrary by 

Friday, October 12, I will assume you assent to the change. 

Thanks. 
P.3 

October 4, 1990 

As we get more into the details of this plan and get more 

specific plant input on how some of these provisions could 

be carried out, a particular problem area has been 

uncovered. Th© requirements for flanges aro primarily new, 

and w® have made educated guesses about their results. Due 

to ths muoh larger number of flanges than any other 

component, including flanges will have a major effect. 

For the most part, the Committee has taken precautions to 

prevent the costs of (Socuaeatiag controls to overwhelm the 

costs ef the controls* As we get mors and more plant 

feedbeok, ©ne provision stands out as having a burdensome 

recordkeeping requirement even where there would be minimal 

environmental benefit. 

Currently VHAP Systems have no reporting requirements for 

flanges. With the current draft language, each individual 

opened flange in VHAP service will have to be located," 

idantifisd, action taken and recorded, all within a 60 day 

periods This is a multiple step action that will require 

multiple visits to the flange. (This might make it 

necessary to tag flanges even though we were careful to 

sp©ll out in the draft regulation that this would not be 

required.) After a flange haa been opened in the field, 

somebody must figure out which one it is and record the 

.information, At times, it would be very difficult for 

people not involved in the maintenance work to even know 

what pipes go where, since disassembly and reassembly would 

be occurring continuously, somebody would need to check out 

all opened pipes on a regular basis. Large units way 

• 
P.4 

I i ._> _ I i J U 1L"1.' _ • '_IH_.ll Ul ' 

-2-

require a full time "open=f,lange" technician, in fact, lots 

of disassembly can take place away from the process in a 

maintenance work area. 

In addition, consider the discussions we had about partial 

samples versus monitoring all flanges. It would take almost 

ao long to monitor just the opened flanges (i.e. 5-30%) as 

te monitor all flanges. This is the case because of all the 

tim© spent looking for specific opened flanges rather than 

full monitoring. 

Xn actual practice, many plants are leak-checked at or 

baforo start-up. The major difference is the constraint® 

that the documenting and recordkeeping provisions impose. 

This recordkeeping is an unnecessary burden for plants that 

hav© adequate maintenance and work practice procedures -

already in place that have eliminated or greatly minimized 

flange leaks. In fact, the cost and complexity of the 60 

day follow-up monitoring is completely independent of 

emissions. Plants that find no leaks will spend virtually 

as much time and effort on monitoring and recordkeeping as 

plants with a significant fraction leaking. Plants with 

frsquent shutdowns may find themselves monitoring almost 

constantly. 

Tn© advantage to industry for the follow-up monitoring is 

that it establishes the nonrepairable pool (2%). 
P.5 

RECOMMENDATION 

We proposls-that plants, willing to exercise the option of giving 

up the nonrepairable pool, not be required to do the follow-up 

monitoring for opened flanges (i.e. § XX.X2-13(c) on page 33 of the 

September 26 draft). 

More specifically we propose changing the current (c) to (c)(1) 

and adding two new subsections: 

(c)(2) A process unit may exercise an option not to do this 

monitoring along with relinquishing the unrepairable pool 

and using Cn=0 in the equation on pp. 35 and 36. 

(c)(3) A process unit may not go from option (1) or (2) to the 

other without starting back again with annual monitoring. 

f

j-^y. ~>r* ,• .* J 

Exercising this option will limit a plant to no more than 0.5% 

instead of 2.0 + 0.5% exceeding 500 ppm. This option, while 

providing more flexibility, will also be more stringent. 
October 4, 1990 

P.6 

we get more into the details of this plan and get more 

specific plant input on how some of these provisions could 

be carried out, a particular problem area has been 

uncovored. The requirements for flanges ar® primarily new, 

and we have made educated guesses about their results. Due 

to the much larger number of flanges than any other 

component, including flanges will have a major effect. 

For the most part, the Committee has taken precautions to 

prevent the costs of documenting controls to overwhelm the 

costs of the controls. Ae we get more and more plant 

feadbaok, ene provision Btande out as having a burdensome 

recordkeeping requirement even where there would be minimal 

environmental benefit. 

Currently VHAP Systems have no reporting requirements for 

flanges. With the current draft language, each individual 

opened flange in VHAP service will have to be located,' 

identified, action taken and recorded, all within a 60 day 

period. This is a multiple step action that will require 

multiple visits to the flange. (This might make it 

necessary to tag flanges even though we were careful to 

spell out in the draft regulation that this would not be 

required.) After a flange has been opened in the field, 

somebody must figure out which one it is and record the 

.information, At times, it would be very difficult for 

people not involved in the maintenance work to even know 

what pipes go where, since disassembly and reassembly would 

be occurring continuouslyu somebody would need to check out 

all opened pipes on a regular basis. Large units may 
P.7 

-2-

roquire a full time "open-flange" technician. in fact, lots 

of disassembly can take place away from the process in a 

maintenance* work area. 

In addition, consider the discussions we had about partial 

samples vorsus monitoring all flanges. It would take almost 

as long to monitor just the opened flanges (i.e. 5-30%) as 

to monitor all flanges. Thie is the case because of all the 

tiaa spent looking for specific opened flanges rather than 

full monitoringo 

Sn actual practice, many plants are leak°checked at or 

boforo start-up. The major difference is the constraint® 

that the documenting and recordkeeping provisions impose. 

This recordkeeping is an unnecessary burden for plants that 

hav© adequate maintenance and work practice procedures 

already in place that have eliminated or greatly minimized 

flange leaks. In fact, the cost and complexity of the 60 

day follow=up monitoring is completely independent of 

emissions. Plants that find no leaks will spend virtually 

as much time and effort on monitoring and recordkeeping as 

plants with a significant fraction leaking. Plants with 

fr®quent shutdowns may find themselves monitoring almost 

constantly. 

Tho advantage to industry for the follow=up monitoring is 

that it establishes the nonrepairable pool (2%). 

________ 
P.8 

RECOMMENDATION 

We propo5e-that plants, willing to exercise the option of giving 

up the nonrepairable pool, not be required to do the follow-up 

monitoring for opened flanges (i.e. § XX.X2-13(c) on page 33 of the 

September 26 draft). 

More specifically we propose changing the current (c) to (c)(1) 

and adding two new subsections: 

(c)(2) 

(c)(3) 

A process unit may exercise an option not to do this 

monitoring along with relinquishing the unrepairable pool 

and using Cn=0 in the equation on pp. 35 and 36. 

A process unit may not go from option (1) or (2) to the 

other without starting back again with annual monitoring. 

u .*-"/ 

Exercising this option will limit a plant to no more than 0.5% 

instead of 2.0 + 0.5% exceeding 500 ppm. This option, while 

providing more flexibility, will also be more stringent.