P.1 

OAR Box 1338 

Prepped by Ollie Stewart 

Document Number: 

2) 11-1-2 

Docket Number: 

A-89-10 

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

20 th*** * 

'Anniversary 

RADIAN 

CORPORATIO N 

DCN 89-259-039-0 3 

RCN 259-039-05-0 1 

A-89-10 

II-I- 2 

P.O. Box 201088 

Austin, TX 78720-1088 

(5121454-4797 

FUGITIVE EMISSIONS 

FROM THE 1,3-BUTADIENE 

PRODUCTION INDUSTRY: 

A FIELD STUDY 

FINuAL REPORT 

"* 

V i, , I . 1 1 

Prepare d for : 

The 1,3-Butadien e Pane l of 

t h e Chemical Manufacturers Associatio n 

Prepared by: 

John L. Randall 

Graham E. Harris 

Sharon L. Wevill 

Radian Corporation 

Austin, Texas 

April 1989 
P.3 

TABLE OF CONTENTS 

age 

1.0 EXECUTIVE SUMMARY 1-1 

2.0 INTRODUCTION AND OVERVIEW 2-1 

2.1 Definition of Fugitive Emissions 2-1 

2.2 Critical Studies of Fugitive Emissions 2-2 

2.3 Previous and Impending Concern With Fugitive Emissions 2-4 

3.0 1,3-BUTADIENE PRODUCTION AND USE 3-1 

3.1 Properties of 1,3-Butadiene: The Chemical 3-1 

3 .2 Overview of Production and Use 3-2 

3.3 Production and Use 3-6 

4.0 MONITORING APPROACH 4-1 

4.1 Overview of Methods Used to Estimate Fugitive Emissions 4-1 

4.1.1 SOCMI Average Emission Factor 4-3 

4.1.2 Screening Test 4-3 

4.1.3 Leak/No Leak Method 4-5 

4.1.4 Stratified Method 4-5 

4.1.5 Correlation Equations 4-6 

4.1.6 Bagging 4-7 

4.1.7 Current Study 4-9 

4.2 Screening Techniques 4-10 

4.3 Calibration 4-12 

4.4 Screening Protocol 4-12 

4.5 BD Workbook 4-14 

4.5.1 1,3-Butadiene Screening Survey Report Form.... 4-14 

4.5.2 Calibration Data Sheet for 1,3-Butadiene 

Screening 4-18 

4.5.3 Drift Test Data Sheet for 1,3-Butadiene 

Screening 4-18 

4.6 Quality Control Results 4-21 

ii 
P.4 

TABLE OF CONTENTS (Continued) 

5.0 DATA ANALYSIS 5-1 

5.1 Converting Raw OVA Values to BD-Specific Emission 

Estimates 5-1 

5.1.1 Theory 5-1 

5.1.2 Practical Examples 5-4 

5.2 Summary of Components Studied 5-8 

5.3 Emissions By Component Type and Service Category 5-21 

5.3.1 Valves in Liquid Service 5-21 

5.3.1.1 Screening Measurements 5-25 

5.3.1.2 Emission Estimates 5-25 

5.3.1.3 Plant-Specific Analysis 5-29 

5.3.1.4 Summary 5-29 

5.3.2 Valves in Gas Service 5-29 

5.3.2.1 Screening Measurements 5-31 

5.3.2.2 Emission Estimates 5-31 

5.3.2.3 Plant-Specific Analyses... 5-31 

5.3.2.4 Summary 5-36 

5.3.3 Flanges 5-36 

5.3.3.1 Screening Measurements 5-37 

5.3.3.2 Emission Estimates 5-37 

5.3.3.3 Plant-Specific Analyses 5-37 

5.3.3.4 Summary.... 5-42 

5.3.4 Open-Ended Lines 5-42 

5.3.4.1 Screening Measurements 5-42 

5.3.4.2 Emission Estimates 5-45 

5.3.4.3 Plant-Specific Analyses 5-45 

5.3.4.4 Summary 5-45 

5.3.5 Pumps 5-48 

5.3.5.1 Screening Measurements 5-48 

5.3.5.2 Emission Estimates 5-48 

5.3.5.3 Plant-Specific Analyses 5-52 

5.3.5.4 Summary 5-52 

5.3.6 Safety Valves 5-52 

5.3.6.1 Screening Measurements 5-54 

5.3.6.2 Emission Estimates 5-54 

5.3.6.3 Plant-Specific Analyses 5-54 

5.3.6.4 Summary 5-59 

i n 
P.5 

6.0 

7.0 

TABLE OF CONTENTS (Continued) 

Page 

5.3.7 Sample Points 5-59 

5.3.8 Compressors 5-64 

5.4 Bagging Study 5-64 

BUTADIENE WORK PRACTICES, OPERATING PROCEDURES, AND DESIGN 

GUIDELINES: RESULTS OF A 1,3-BUTADIENE PANEL SURVEY 6-1 

REFERENCES 7-1 

APPENDIX 1 

APPENDIX 2 

APPENDIX 3 

APPENDIX 4 

APPENDIX 5 

EPA METHOD 21 

1,3-BUTADIENE FUGITIVE EMISSION MONITORING PROTOCOL 

INDIVIDUAL PLANT SUMMARY DATA TABLES 

BAGGING STUDY DATA 

BUTADIENE FUGITIVE EMISSION SURVEY 

IV 
P.6 

LIST OF TABLES 

Page 

-1-1 Emission Factors for All Components Studied: 1,3-Butadiene 

Production Plant Study 1-3 

1-2 Reduction in Emission Factors for Components in BD Service 1-4 

1-3 Comparison of Leak Frequencies: Bd Panel Study vs SOCMI 

24-Unit Study 1-5 

1-4 Estimated 1,3-Butadiene Production Plant Equipment Leak 

Emissions 1-11 

3-1 Major U.S. Butadiene Uses (1986) 3-4 

3-2 1,3-Butadiene Finished Product Plants and Nameplate 

Capacities in 1986. 3-7 

4-1 EPA Emission Factors in lb/hr/source 4-5 

4-2 Fugitive Emission Correlation Equations 4-7 

4-3 Summary of Calibration and Drift Test Results 4-21 

5-1 Organic Solvents and Response Factors 5-3 

5-2 Summary Distribution of All Components by Plant 5-9 

5-3 Distribution of Components by BD Concentration 5-11 

5-4 Distribution of Raw OVA Screen Values by BD Concentration. 5-12 

5-5 Distribution of Components by Raw OVA Screen Value for all 

Participating Plants All Components and All BD Concentration 5-13 

5-6 1,3-Butadiene Fugitive Emission Survey Summary Report for 

All Plants: Comparison of Mean Emission Factors for All 

Calculation Metnods 5-16 

5-7 Summary of Estimated 1,3-Butadiene Fugitive Emissions for 

All Participating Plants: Emission Estimates for All 

Components 5-18 

5-8 Comparison of OVA Screening Values From the BD Panel Study 

With Those Estimated from SOCMI Factors 5-20 

5-9 Summary of Estimated 1,3-Butadiene Fugitive Emission for 

All Participating Plants: Emission Estimates for Components 

With BD Concentrations Between 5X and 30X 5-22 

5-10 Summary of Estimated 1,3-Butadiene Fugitive Emissions for 

All Plants: Emission Estimates for Components With BD 

Concentrations Between 302 and 90Z 5-23 

v 
P.7 

age 

LIST OF TABLES (Continued) 

5-11 Summary of Estimated 1,3-Butadiene Fugitive Emissions for 

All Plants: Emission Estimates for Components With BD 

Concentrations Between 90X and 100X 5-24 

5-12 Distribution of Raw OVA Screening Values by BD 

Concentration for Valves in Liquid Service 5-26 

5-13 Distribution of Emissions by Butadiene Concentration for 

All Plants: Emission Estimates for Valves in Liquid Service 5-28 

5-14 Emission Factors for Valves in Liquid Service for Each Plant 5-30 

5-15 Distribution of Raw OVA Screening Values by BD Concentration 

for Valves in Gas Service 5-32 

5-16 Distribution of Emissions by Butadiene Concentration for 

Ail Plants: Emission Estimates for Valve in Gas Service... 5-34 

5-17 Emission Factors for Valves in Gas Service for Each Plant. 5-35 

5-18 Distribution of Raw OVA Screening Values by BD 

Concentration for Flanges 5-38 

5-19 Distribution of Emissions by Butadiene Concentration for 

All Plants: Emission Estimates for Flanges 5-40 

5-20 Emission Factors for Flanges for Each Plant 5-41 

5-21 Distribution of Raw OVA Screening Values by BD Concentration 

For Open-Ended Lines 5-43 

5-22 Distribution of Emissions by Butadiene Concentration for 

All Participating Plants: Emission Estimates for Open-Ended 

Lines 5-46 

5-23 Emission Factors for Open-Ended Lines for Each Plant 5-47 

5-24 Distribution of Raw OVA Screening Values by BD 

Concentration for Pumps 5-49 

5-25 Distribution of Emissions by Butadiene Concentration for 

All Plants: Emission Estimates for Pumps 5-51 

5-26 Emission Factors for Pumps for Each Plant 5-53 

5-27 Distribution of Raw OVA Screening Values by BD 

Concentration for Safety Valves 5-55 

vi 
P.8 

LIST OF TABLES (Continued) 

Page 

5-28 Distribution of Emissions by Butadiene Concentration for 

All Plants: Emission Estimates for Safety Valves 5-57 

5-29 Emission Factors for Safety Valves for Each Plant 5-58 

5-30 Distribution of Raw OVA Screening Values by BD 

Concentration for Sample Points 5-60 

5-31 Distribution of Emissions by Butadiene Concentration for 

All Plants: Emission Estimates for Sample Points 5-62 

5-32 Emission Factors for Sample Points for Each Plant 5-63 

5-33 Distribution of Raw OVA Screening Values by BD 

Concentration for Compressors 5-65 

5-34 Distribution of Emission by Butadiene Concentration for All 

Plants: Emission Estimates for Compressors 5-67 

5-35 Emission Factors for Compressors for Each Plant 5-68 

5-36 Summary of Butadiene Default Zero Bagging Study Results... 5-73 

vn 
P.9 

LIST OF FIGURES 

Pagg 

1-1 Comparison of Leak Frequencies of Source Categories at 

Butadiene Production Facilities 1-6 

1-2 Distribution of Components by OVA Screening Value 1-8 

1-3 Percent Contribution of Source Categories to Total BD Emissions 1-9 

1-4 Distribution of BD Emissions and Components by BD Composition 1-10 

3-1 Production and End Uses of Butadiene 3-3 

4-1 Overview of Fugitive Emission Estimation 4-2 

4-2 Example Screening Data Report Form 4-15 

4-3 Example Calibration Reporting Form 4-18 

4-4 Example Drift Test Report Form 4-20 

5-1 Distribution of Selected Components by Raw OVA Screening Value 5-14 

5-2 Distribution of Raw OVA Screening Values for Valves in Liquid 

Service 5-27 

5-3 Distribution of Raw OVA Screening Values for Valves in Gas 

Service 5-32 

5-4 Distribution of Raw OVA Screening Values for Flanges 5-38 

5-5 Distribution of Raw OVA Screening Values for Open-Ended Lines 5-44 

5-6 Distribution of Raw OVA Screening Values for Pumps 5-50 

5-7 Distribution of Raw OVA Screening Values for Safety Valves 5-55 

5-8 Distribution of Raw OVA Screening Values for Sample Points 5-61 

5-9 Distribution of Raw OVA Screening Values for Compressors 5-65 

5-10 Screening to Leak Rate Correlation Examination: Valves in 

Liquid Service in Butadiene Plants 5-69 

5-11 Screening to Leak Rate Correlation Examination: Flanges in 

Butadiene Plants 5-70 

v m 
P.10 

GLOSSARY 

CMA Chemical Manufacturers Association 

Correlation Equation The equation needed to convert screening values to 

mass emission factors: developed by EPA from field 

data obtained during various fugitive emission 

studies. 

Default Zero Emission 

Factor 

Default Zero 

Screening Value 

EPA 

Emission Factor 

The emission factor associated with a zero screening 

value. 

The screening value back calculated from the zero 

emission factor default using the appropriate 

correlation equation. 

United States Environmental Protection Agency 

The per component mass emission rate applicable to 

populations of sources, not individual component 

measurements. 

Heavy Liquid 

High Emitters 

Leak Definition 

Leak Rate 

A process liquid with a vapor pressure < 0.04 psia at 

20° C. 

Components with screening values between 1,000 and 

.9,999 ppm. 

The monitoring instrument reading selected as the 

trigger value for beginning some action, such as 

maintenance; e.g., 10,000 ppmv is the leak definition 

used by EPA. 

See mass emissions rate. 

Leaking Emission 

Factor 

The per component mass emission rate associated with 

the population of sources with screening values at or 

above the leak definition. 

Leaking Source 

Light Liquid 

A source whose screening value is greater than or 

equal to 10,000 ppmv. 

A process liquid with a vapor pressure >0.04 psia at 

20°C. 

Low Emitters 

Mass Emissions Rate 

Components with screening values between 100 and 999 

ppm. 

The quantity of volatile organic compound(s) released 

to the atmosphere in terms of total mass per unit 

time. 

IX 
P.11 

Monitoring Instrument 

Non-emitting Source 

Non-Leakers 

Screening Value 

SOCMI 

SOCMI Factors 

Very Low Emitters 

Weighted Average 

Portable hydrocarbon analyzer meeting the performance 

specifications given in Method 21. 

A source whose screening value is less than 10 ppm. 

Components with screening values less than 10 ppm. 

Monitoring instrument reading generally given in 

concentration units; e.g., ppmv. 

Synthetic Organic Chemical Manufacturing Industries. 

Fugitive emission factors developed by EPA for SOCMI 

in 1983. 

Components with screening values between 10 and 99 

ppm. 

The value for each butadiene range "weighted" by the 

number of components in that range. The total number 

of components in the screening value range expressed 

as a percentage of the total number of components in 

all ranges. 
P.12 

1.0 EXECUTIVE SUMMARY 

This report presents the results of a study conducted by members of 

the Butadiene Special Program Panel of the Chemical Manufacturers Association 

(BD Panel) in cooperation with the U.S. Environmental Protection Agency (EPA) 

to evaluate the emissions resulting from equipment leaks in the 1,3-butadiene 

(BD) production industry. 

The study was initiated to address two needs of the industry. The 

first was to provide better estimates of air emissions of butadiene for 

reporting under the Superfund Amendments and Reauthorization Act (SARA), Title 

III. The second was to respond to EPA's notice of intent to list 1,3-

butadiene as a hazardous air pollutant under Section 112 of the Clean Air Act. 

In its initial evaluation of the BD production industry, EPA concluded that 

emissions of BD may cause a significant risk to the public health. The 

emissions were attributed almost exclusively to equipment leaks that were 

estimated using EPA's average SOCMI emission factors. EPA had established 

these factors after studying equipment leaks from petroleum refineries and 

chemical plants in the late 1970s. The factors are specific to each type of 

component, such as valves and pumps. 

The BD Panel, as well as many other industry organizations, has long 

believed that the use of average SOCMI factors is not appropriate for 

estimating chemical leaks from equipment for specific process units. EPA also 

recognized the need to develop more specific equipment leak information, and 

they prepared a draft protocol (see Appendix 2) that could be used to estimate 

the emissions of a specific chemical resulting from equipment leaks in a 

specific process unit. Working with this draft protocol, the BD Panel worked 

with EPA to establish a procedure to conduct the studies that are the subject 

of this report. The BD Panel contracted Radian Corporation to develop the 

testing procedures, oversee the testing effort conducted by member companies, 

analyze the data, and generate the final report. Thirteen BD production 

facilities, including nine of the eleven finished BD producing facilities in 

the United States, began the study in March 1988. 

1-1 
P.13 

Results 

Data were received on over 44,000 individual components from the 13 

participants. The data covered essentially 100% of the components, except for 

flanges. About 24% of all flanges were screened. A detailed analysis of the 

data appears in Section 5. 

One purpose of the study was to address the issue of the validity of 

the SOCMI leak rate correlations when screening values were below 8.17 ppm. 

This was done by "bagging" sources screened at "zero" to determine an actual 

leak rate. Sufficient data were gathered to establish new lower limit of 

detection (LLD) screening values. No single LLD or default zero value could 

adequately describe all of the sources. Therefore, new default zero values 

were established for each of the four correlation curves previously developed 

by EPA. The new default zero values were used to develop the BD Panel 

emission factors shown in this report. 

Table 1-1 summarizes the average emission factors developed by the 

BD Panel study for each type of component and compares them to the average 

SOCMI factors previously developed by EPA for total VOC emissions and to those 

factors corrected for actual average BD composition in the component (weighted 

SOCMI). The BD Panel Factor values represent the average butadiene specific 

emssion factor (rate) for the average concentration of butadiene for each 

component shown. While the results in Section 5 present data for "Sample 

Points," the present study did not attempt to assess the emissions that result 

from taking a sample. (This is the basis for EPA's average SOCMI factor for 

these components.) The sample point category in the present study was 

considered a subset of the broad category of open-ended lines, and the results 

have been combined in Table 1-1. 

1-2 
P.14 

TABLE 1-1 . EMISSION FACTORS FOR ALL COMPONENTS STUDIED: 1,3-BUTADIENE 

PRODUCTION PLANT STUDY 

Component 

Valve (liquid) 

Valve (gas) 

Safety Valve 

Pump 

Open-Ended Line 

Flange 

Compressor 

Number of 

Components 

23233 

6315 

428 

376 

1784 

11428 

17 

Mean BD 

Cone. (%) 

59.7 

60.2 

56.7 

64.1 

67.9 

61.0 

27.9 

Mean 

Average 

SOCMI 

.01560 

.01230 

.2291 

.1089 

.003700 

.001830 

.50220 

Emission Fact 

(lb/hr/source) 

Weighted 

SOCMI 

.009314 

.007399 

.1300 

.06985 

.002514 

.001116 

.1403 

ors 

BD Panel 

Factor 

.003140 

. .001105 

.02996 

.05634 

.000120 

.000307 

.000004 

SOURCE: BD PuANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988 . 

1-3 
P.15 

As shown in Table 1-2, the present study demonstrated that, with the 

exception of pumps, average emission factors ranged from 73% to 99+% lower 

than what would be expected using EPA's weighted SOCMI factor-approach. The 

emission factor reduction for pumps was 19%. The primary reason for this 

reduction is that the percentage of leaking sources (defined as a screening 

value of >10,000 ppm) was significantly lower than seen in previous EPA 

studies. Table 1-3 and Figure 1-1 compare the leak frequencies found in this 

study with those used by EPA in developing its average SOCMI leak factors. As 

can be seen,.the reduction in leak frequency ranged from a low of 12% for 

pumps to a high of 99.9+% for compressors. The average leak frequency was 

1.8% for the nearly 44,000 components studied. 

While the low percentage of leaking components accounts for a 

significant portion of the reduction when compared with the average SOCMI 

factors, another contributing factor is lower emission rates for all 

components. Over 75% of the components studied had OVA screening values of 

<10 ppm. Figure 1-2 shows the distribution of screening values found in this 

study. 

Analysis of the data shows that the major sources of equipment 

emissions are liquid valves (57%) and pumps (16%). Open-ended lines and 

compressors are insignificant sources (less than 0.2%) of the total BD 

emissions. The remaining equipment leak emissions are distributed roughly 

equally among the remaining components. Figure 1-3 graphically compares the 

percentage of total BD emissions attributable to each component category. 

As would be expected, BD emissions increase as the BD composition 

being handled by the component increases. Figure 1-4 displays the 

distribution of BD emissions in three composition ranges: 5%-30% BD, 30%-90% 

BD, and >90% BD. Also shown is the distribution of the studied components in 

these same concentration ranges. For example, while over 20% of the 

components studied handled streams containing 5%-30% BD, less than 4% of the 

total BD emissions are attributed to those components. 

1-4 
P.16 

TABLE 1-2. REDUCTION IN EMISSION FACTORS FOR COMPONENTS 

IN BD SERVICE 

Component Type 

Weighted SOCMI 

Emission Factor 

(lb/hr/source) 

BD Panel Study 

Emission Factor3 

(lb/hr/source) 

Reduction" 

(%) 

Valve in Liquid Service 

Valve in Gas Service 

Flange 

Open-ended Line 

Pump 

Safety Valve 

Compressor 

0.009314 

0.007399 

0.001116 

0.002514 

0.069852 

0.1300 

0.140321 

0.003140 

0.001105 

0.000307 

0.000120 

0.05634 

0.02996 

0.000004 

66.3 

85.1 

72.5 

95.2 

19.3 

76.9 

99.9+ 

a

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

deductio n (%) calculate d from [1-(BD Panel Value/SOCMI Value)] x 100. 

1-5 
P.17 

TABLE 1-3. COMPARISON OF LEAK FREQUENCIES: BD PANEL 

STUDY VS. SOCMI 24-UNIT STUDY3 

Component 

Valve (liquid ) 

Valve (gas) 

Safety Valve 

Sample Point 0 

Pump 

Open-ended Line 

Flange 

Compressor 

BD Panel Stu 

(%) 

2.35 

1.74 

1.40 

5.00 

7.71 

0.63 

0.11 

0.00 

idy3 SOCMI 24-Unit b 

(%) 

6.5 

11.4 

3.6 

3.9 

8.8 

3.9 

2.1 

9.1 

Reduction 

(%) 

63.8 

. 84.7 

61.1 

-28. 2 

12.4 

83.8 

94.8 

99.9+ 

a

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

b

Source : Reference 8. 

c

Sample points ar e considered as open-ended lines. 

1-6 
n a SOCMI STUDY ^ BD/CMA STUDY 

PER CENT LEAKERS 

1 1.4 z 

0 

8 

6 

4 

2 

-

-

BD/OM A STUDY REPORT 

LIQ 

VALVES 

GAS 

VALVES PUMPS SAFETY 

VALVES 

OPEN-END 

LINES FLANGES COMPRES 

Figur e 1-1 . Comparison of Leak Frequencie s Butadiene Production Facilitie s 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.19 

>10,000 ppm 

1000 - 9999 ppm 

100 - 999 ppm 

10 - 99 ppm 

< 10 ppm 

LEGEND 

BO/OM * J'UO V BCPOR T 

Figure 1-2. Distribution of Components by OVA Screening Value. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

1-8 
P.20 

0-E LINES 0.2% 

S/VALVES

 10 

G/VALVES 5.n/ 

FLANGES u.3% 

PUMPS 16.4% 

L/VALVES 56.7% 

Figure 1-3. Percent Contribution of Source Categories to Total BD Emissions, 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988, 

1-9 
PERCENT OF TOTAL 

i 

o 

60 

50 

40 h 

30 

20 

10 

0 ma 

5-3 0 30 - 90 

COMPOSITION % BD 

90 - 100 

Figure 1-4. Distribution of BD Emissions and Components by BD Composition. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

ho 
P.22 

Table 1-4 shows the total annual BD emissions estimated using the BD 

Panel emission factors developed by this study (see Table 1-1), the equipment 

count at each of the participating facilities and the average BD concentration 

for each component for each plant (see Tables in Appendix 3). Since only a 

sampling of flanges was tested, a scale-up factor for flanges of 1.6 per valve 

was applied to estimate flange emissions except for plants 5, 8, 9, 10, and 13 

where actual flange counts were used. This scale-up factor is the same as 

used by EPA in its original studies (1). Also, an annual stream factor of 95% 

was used for each facility. In Table 1-4, the column titled "Average SOCMI" 

represents the total emissions of VOC using the average SOCMI factors 

developed by EPA. The column titled "Weighted SOCMI" represents the BD 

emissions estimated by correcting the average SOCMI for the actual 

concentration of BD being handled by each component in the facility. The BD 

Panel estimate represents the BD emissions estimated using the average 

emission factors developed in the present study (Table 1-1). Table 1-4 

separates crude BD producers from those producing finished (purified) BD. 

The BD Fugitive Emissions Panel conducted a questionnaire survey of 

industry work practices, operating procedures, and design guidelines in an 

attempt to explain the low fugitive emissions measured in the current study. 

The plants responding to the questionnaire represent 46% of the 1,3-Butadiene 

plants in the U.S. and seem to be generally aware of the improved technology 

and methods avialable for minimizing and responding to leaks of this chem'ical. 

Some of the plants seemed more aware than others of the techniques and 

improved equipment available, but the discrepancy did not seem wide. These 

results are disucssed in greater detail in Section 6. A copy of the 

questionnaire appears in Appendix 5. 

1-11 
P.23 

TABLE 1-4. ESTIMATED 1,3-BUTADIENE PRODUCTION PLANT EQUIPMENT LEAK EMISSIONS 

Plant Location 

Average 

SOCMI Average BD 

(Total VOC) Concentration 

Tons/Yr (%) 

Weighted Panel 

SOCMI Factors 

(BD) (BD) 

Tons/Yr Tons/Yr 

Finished Producers 

Shell Chemical 

Deer Park, TX 

Cain Chemical 

Chocolate Bayou, TX 

Cain Chemical 

Corpus Christi, TX 

Mobil Chemical 

Beaumont, TX 

Exxon Chemical 

Baytown, TX 

Exxon Chemical 

Baton Rouge, LA 

Amoco 

Chocolate Bayou, TX 

Lyondell (ARCO) 

Channelview, TX 

Texaco Chemical 

Port Neches, TX 

191 

138 

59 

78 

159 

a 

292 

377 

1,165 

54 

49 

70 

63 

61 

a 

70 

68 

61 

108 

62 

41 

54 

98 

a 

208 

257 

717 

36 

21 

12 

21 

29 

71 

89 

217 

Union Carbide 

Seadrift, TX 

Union Carbide 

Taft, LA 

Union Carbide 

Texas City, TX 

Dow Chemical 

Freeport, TX 

Crude C )nly Producers 

249 

36 

47 

a 

28 

33 

43 

a 

72 

10 

20 

a 

21 

4 

7 

3 Insufficient data to estimate total emissions. Data used only to estimate 

individual component leaks. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 

1-12 
P.24 

Methods Used 

Data were received from a total of 44,013 individual components from 

13 butadiene production facilities. Estimates of fugitive emissions were then 

calculated using the following six methods: 

• SOCMI Average Emissions Factors; 

• Weighted SOCMI Emission Factors; 

• SOCMI Leak/No Leak Emission Factors; 

• SOCMI Stratified Emission Factors; 

• Correlation Equations (EPA's 8.17 ppm default value and BD 

Panel default value); and 

• Bagging Tests.Seven types of components were included in the 

study. Valves were divided into those in liquid service and 

those in gas service. The other components were flanges, openended lines, pumps, safety valves, sample points, and 

compressors. 

Conclusions 

Data from the present study show that, for the plants studied, 

overall BD emissions attributable to equipment leaks are 81% lower than those 

estimated using EPA's average factor approach. 

1-13 
P.25 

Since the data developed by the present study represent over 80% of 

the finished BD production facilities (9 out of 11 facilities) in the United 

States, covering about 44,000 individual components, the emission factors and 

total facility emissions are the most current and accurate available data. 

Use of this information to estimate potential population exposure will result 

in a more realistic evaluation of the need to regulate 1,3-butadiene under 

Section 112 of the Clean Air Act. 

1-14 
P.26 

2.0 INTRODUCTION AND OVERVIEW 

This document summarizes the results of fugitive emissions testing 

conducted by members of the 1,3-Butadiene Panel of the Chemical Manufacturers 

Association (CMA) in cooperation with the Environmental Protection Agency 

(EPA). The testing was according to a protocol agreed to by all groups (see 

Appendix 2). Radian Corporation was contracted by the Butadiene Panel to 

oversee the testing effort, analyze the data, and generate this industry-wide 

final summary report. 

2.1 Definition of Fugitive Emissions 

In this report, the term fugitive emissions means, specifically, 

leaks of butadiene (BD) from process equipment, including: 

• Pump seals; 

• Compressor seals; 

• Valves; 

• Connections (flanges, threaded fittings, unions, and any other 

pipe-to-pipe connections other than welds); 

• Open-ended lines (that are not securely capped or plugged); 

• Sampling points (treated as open-ended lines in this study); 

and 

• Safety relief valves. 

These components represent mechanical joints, seals, and rotating surfaces 

which in time tend to wear and develop leaks. The leaks are -called fugitive 

leaks because there is no way of accurately predicting their occurrence or 

severity. When the leaking component contains a mixture, it is assumed that 

2-1 
P.27 

the fugitive emissions have the same composition as the material flowing 

through the component. However, unless otherwise indicated, all mass 

emissions data in this report are expressed as BD only, having been corrected 

to exclude any other co-emitted volatile organic compounds (VOC). 

2.2 Critical Studies of Fugitive Emissions 

Industry and government agencies have been concerned about fugitive 

emissions since the mid-1970s. The US EPA funded two large studies of 

fugitive emissions between 1975 and 1983. The first of these focused on 

fugitive emissions from refineries (2). The second focused on the Synthetic 

Organic Chemical Manufacturing Industries (SOCMI) (3,4). The SOCMI study was 

criticized for its.overly high prediction of the emissions from many organic 

chemical facilities, particularly those processing known toxic materials where 

an attempt to reduce emissions was an inherent part of the design and 

operations. Also, the SOCMI study tested only six of the hundreds of possible 

chemical processes, and most of the tested processes were large-commodity 

petrochemical processes. 

Despite these concerns about the refinery and SOCMI fugitive 

emission factors, they nevertheless were widely used, and numerous regulations 

have been based on the data. The US EPA promulgated New Source Performance 

Standards (NSPS) and Control Techniques Guidelines (CTG) for both the refining 

and organic chemical industries using SOCMI fugitive emissions factors. Many 

states adopted regulations in their State Implementation Plans (SIP) based on 

the CTG that apply to existing sources. These are also based on SOCMI 

factors. 

In recent years, the use of the refinery and SOCMI emission factors 

has been extended even further beyond the original test basis. These 

generalized factors have been used to estimate emissions from hazardous waste 

handling, air toxics processing, and other applications—well beyond the 

originally intended uses. The justification for these applications has-been 

that the refinery and SOCMI factors are the best available way to estimate 

2-2 
P.28 

fugitive emissions, since no specific testing has been conducted for these 

other applications. 

2.3 Previous and Impending Concern About Fugitive Emissions 

The present BD fugitive emissions study was conducted for the 

following reasons: 

• First, the Superfund Amendments Reauthorization Act (SARA), 

Title III required BD manufacturers to begin reporting each 

year's emissions of BD from both fugitive and point sources. 

• Second, the U.S. EPA announced they were considering developing 

a National Emission Standard for Hazardous Air Pollutants 

(NESHAP) for BD. EPA is basing the NESHAP risk assessment on 

SOCMI emission factors, although use of these factors will 

result in an overestimation of BD fugitive emissions and 

therefore in an overprediction of the potential health risk. 

The BD panel believes that EPA should consider using the 

individual plant fugitive emissions found in the present study 

for further BD NESHAP evaluations and risk assessments. 

2-3 
P.29 

3.0 1,3-BUTADIENE PRODUCTION AND USE 

This section gives an overview of 1,3-Butadiene and its production 

and use in the United States. 

3.1 Properties of 1.3-Butadiene 

1,3-butadiene has the following structural formula: 

H H H H 

\ I I / 

C - C - C - C 

/ \ 

H H 

It has a molecular weight of 54 and a molecular formula of C4H6. 

3.2 Overview of Production and Use (5) 

According to the Chemical and Engineering News. June 8, 1987, 

butadiene is the 34th largest commodity chemical produced in the United 

States. Production in 1987 is estimated to have been approximately 11.9 

billion pounds worldwide and 2.7 billion pounds in the U.S. Most butadiene ts 

extracted from a mixed butenes stream (crude butadiene), which is a byproduct 

of ethylene production. This route accounts for approximately 95X of domestic 

and 85% of worldwide production. 

In the U.S., there are approximately 30 ethylene plants located in 6 

states. The crude butadiene streams from these facilities (30-60% butadiene, 

depending on ethylene plant feedstock) are processed in extraction units 

located in Texas and Louisiana. Some crude butadiene is imported from 

overseas to supplement the domestic supply. The extraction plants use an 

extraction solvent such as dimethylformamide or acetonitrile to produce highpurity (>99.0X) butadiene monomer. These plants are typical petrochemical 

facilities. They are out-of-doors and, because of the extraction solvent 

toxicity and butadiene's flammability, fully contained. The butadiene is 

handled as a liquified compressed gas. 

3-1 
P.30 

Butadiene consumption in 1987 was estimated to be 12.0 billion 

pounds worldwide and 3.3 billion pounds in the U.S. As in most years, U.S. 

demand exceeded supply; therefore, approximately 500 million pounds of 

butadiene monomer were imported. 

Figure 3-1 shows that butadiene is a relatively large volume product 

produced as a coproduct of ethylene manufacture. Its major end use is in the 

production of various polymers used to make tires and nylon. 

Table 3-1 lists the major uses of butadiene: the manufacture of 

styrene-butadiene rubber, polybutadiene rubber, and other polymers. The only 

major non-polymer end use is for the manufacture of adiponitrile, a nylon 

intermediate. There are also several small-volume chemical uses for 

butadiene, e.g., the production of sulfolane, an industrial extraction 

solvent. Butadiene consumption is dominated by the rubber industry; about 72Z 

of all butadiene use is for rubber of one type or another. Of the remainder, 

about 11X is used for nylon; 10X for latex (paper coating, carpet backing); 5X 

for ABS resins, and 2% for all others. 

Historically, there has been little overlap between producers of 

butadiene monomer and its users. The producers are generally major 

petrochemical companies, and the butadiene extraction plant is a small piece 

of a very large complex. The users are generally companies associated 

directly with supplying the end user (e.g., tire manufacturers) with raw 

material. Most sites are relatively small and the butadiene-consuming process 

is a significant portion of the site activity. Since mid 1987, there have 

been no companies in the U.S. that are both major producers and consumers of 

butadiene. 

3-2 
Standalone 

Ethylene 

Production 

Integrated 

Ethylene 

Production 

On-Purpose 

Crude BD 

Production 

Imported 

Crude BD 

Imported 

Butadiene 

Barge 

Pipeline 

Pipeline 

Butadiene 

Extraction 

Ship 

Ship 

r -

ABS 

Resins 

SBR 

and 

Polybutadlene 

Chloroprene 

and 

Nitrile Rub. 

Adiponitrile 

Pipe, Conduit, Etc. 

Auto Parts 

Appliance, Equipment 

Parts 

Tires 

Hoses, Belts 

Seals, Gaskets 

Hoses, Belts 

Adhesives 

Seals, Gaskets 

Nylon 

SB 

Latex 

-*• Carpet Backing 

-*- Coatings 

Other 

^ Footwear 

Adhesives 

Chemical Intermediates 

Figure 3-1. Production and End Uses of Butadiene. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.32 

TABLE 3-1. MAJOR U.S. BUTADIENE USES (1986) 

Styrene-Butadiene Rubber 32.7 

Polybutadlene Rubber 22.3 

Adiponitrile 12.5 

Styrene-Butadiene Latex 9.9 

Chloroprene 6.6 

ABS Resins 4.4 

Nitrile Rubber 2.7 

Other, Including Export 3.9 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

3-4 
P.33 

The following points summarize the outlook for the butadiene 

industry during the next several years (6): 

• Domestic butadiene consumption is expected to grow at an 

average annual rate of 0. 8X; 

• Domestic (co-product) production is expected to grow at an 

average annual rate of 2.3X; 

• Since domestic production will grow faster than demand, imports 

will gradually decline but not be eliminated; 

• Imports (or on-purpose domestic production) will continue to be 

needed until about 1995, when co-produced butadiene will be 

adequate to meet demand; 

• Butadiene production (since it will be a by-product of ethylene 

manufacture) will be independent of demand; and 

• After domestic crude butadiene production exceeds demand, the 

crude butadiene production will probably not be reduced, but 

some of the surplus will be disposed of in some alternative 

manner (i.e., as a fuel or feedstock). 

3-5 
Butadiene monomer is transported to consumers in a variety of ways, 

including pipeline, barge, tank car, and tank truck. Since butadiene is a gas 

at ambient temperature, it is handled as a liquified gas under pressure during 

transportation. During transport, production, or use, butadiene is stored 

either in pressurized vessels or as a refrigerated liquid. 

3.3 Production and Use 

Eight companies produce finished 1,3-butadiene at 11 locations in 

the United States. Sixteen hundred and eight thousand metric tons were 

produced by these facilities in 1985. A breakdown of finished 1,3-butadiene 

production in the U.S. is shown in Table 3-2. The Dow plant at Freeport, 

Texas was a finished product facility in 1985 but had been converted to crude 

production only by the time of this study. 

All of the production facilities in service at the time of this 

study except for Texas Petrochemical participated in the study. The Shell 

facility at Norco, Louisiana was not in service at the time of the study. 

3-6 
P.35 

TABLE 3-2. 1,3-BUTADIENE FINISHED PRODUCT PLANTS AND NAMEPLATE 

CAPACITIES IN 1986' 

Producer Location 

Annual Capacity 

(thousands of 

metric tons) 

AMOCO 

CAIN 

CAIN 

EXXON CHEMICAL 

EXXON CHEMICAL 

LYONDELL (ARCO) 

MOBIL CHEMICAL 

SHELL CHEMICAL" 

SHELL CHEMICAL 

TEXACO CHEMICAL 

TEXAS PETROCHEMICAL" 

CHOCOLATE BAYOU, TX 

CHOCOLATE BAYOU, TX 

CORPUS CHRISTI, TX 

BATON ROUGE, LA 

BAYTOWN, TX 

CHANNELVIEW, TX 

BEAUMONT, TX 

NORCO, LA 

DEER PARK, TX 

PORT NECHES, TX 

HOUSTON, TX 

81 

73 

100 

159 

113 

215 

36 

227 

114 

254 

236 

Total: 1608 

a Taken from Reference 6. 

b Out of service at the time of this study. 

e Company did not participate in this study. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

3-7 
P.36 

4.0 MONITORING APPROACH 

This section gives an overview of the technical approach taken in 

the project, as well as details of the protocol followed by the participating 

member companies. The protocol appears in Appendix 2. 

4.1 Overview of Methods Used to Estimate Fugitive Emissions 

Several steps can be taken to generate a fugitive emissions estimate 

for a specific chemical unit. Figure 4-1 illustrates the overall process. 

For 1,3-butadiene production plants, the potential process fugitive 

emissions sources include valves, pumps, compressors, connectors (flanges, 

screwed fittings, etc.), open-ended lines, safety valves, and sample points. 

Some of these component types are subdivided into service categories that 

describe the physical state (liquid or gas) and volatility range of the 

material flowing through the component. Valves have been grouped into three 

categories: gas, light liquid, and heavy liquid. Pumps have been grouped into 

two categories: light liquid and heavy liquid. All other sources have only 

one category that covers all types of service. 

The first step in estimating fugitive emissions is to determine the 

population of each type of component in the process area to be monitored. 

This can be accomplished by either an on-the-ground physical inventory or by 

examining accurate P&ID drawings. Once this is done, a plant can select from 

five methods of estimating fugitive emissions. These five methods are 

described below and are typically referred to by the following names: 

SOCMI Average Emission Factors; 

Leak/No Leak Emission Factors; 

Stratified Emission Factors; 

Correlation Equations; and 

Bagging. 

4-1 
Component Count by 

Equipaent Type and 

Service Category 

Screening 

Meeaureaente 

Average SOQil 

Eaieeion Fact or a 

-PI 

Leak/No Leak 

Method 

Avatage SOCMI 

Eaieaiooe Eatiaate 

Stratified 

He I hod 

Leak/No Leak 

Eaieaiona 

Eatiaate 

Leak Bate 

Correlatione 

Equet iona 

Stratified 

Eaiaaiona 

Eatiaate 

SOCMI Correlation 

Equation Eaiaaion 

Eatiaate 

lagging 

Heaaureaente 

Correlation 

Equations 

Validated 

New Correlation 

Equations Developed 

Btfined Eatiaataa 

Heaaured 

Eaieeiona 

Unit-Specific Correlation 

Equation Eaietiona Eatiaate 

Figure 4-1. Overview of Fugitive Emission Estimation. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.38 

All five of these methods were applied in this study. Bagging tests were 

optional. 

4.1.1 SOCMI Average Emission Factors 

In the early 1980s, EPA conducted a fugitive emissions study at 24 

plants in the Synthetic Organic Chemical Manufacturing Industry (SOCMI) (4). 

From the results of this study, EPA developed average emission rate factors 

for several components. These factors were taken from a recent EPA draft 

report (7). The representativeness of the data for modern SOCMI facilities is 

questionable in light of current design and maintenance practices, especially 

in plants dealing with potentially toxic chemicals. 

In estimating fugitive emissions for a process area, the number of 

components of each type is multiplied by the average emission factor for that 

component type. The contributions from each component type are added to 

develop the total emission estimate for the process area. 

Note that in this study, fixed sample points (lines) were treated as 

open-ended lines since all screening tests were performed without actual 

sampling being in progress. The original EPA database included sample 

connection screening values taken while actual sample acquisition was in 

progress. 

4.1.2 Screening Test 

All other emission estimation methods require that a screening 

survey be made of the components in the process area to be monitored. 

Screening is a relatively quick measurement method that employs a portable 

detector that indicates whether a source is emitting and gives a rough 

magnitude of the emissions. For measuring total VOCs, portable Flame 

Ionization Detector (FID) instruments like the Century Systems OVA-108 and 

combustibles analyzers such as the TLV Sniffer have been used for screening 

tests. To obtain accurate estimates of the actual VOC screen values, these 

analyzers are calibrated with methane and then challenged with standard gases 

4-3 
P.39 

of the material to be analyzed to determine the specific response of the 

instrument for that compound. The raw screening data are adjusted to reflect 

such instrument response factors (RFs). Additional corrections to the 

screening data may include adjustments for line composition so that the 

contribution from each compound in the line is properly included. Prior to 

making a screening measurement, the instrument response to the ambient air 

"near" the component is determined. This background reading is subtracted 

from the screening value to correct for the ambient level of hydrocarbons. 

4.1.3 Leak/No Leak Method 

After examining all of the data at their disposal, the EPA 

determined that a reasonable approach to estimating fugitive emissions could 

include separate emission factors for leaking components and non-leaking 

components (8,9). Additional work by EPA established a screening value of 

10,000 ppm as the cutoff for declaring a component to be a "leaker" (10). 

The leak/no leak emission factors published by EPA are presented in 

Table 4-1 and are taken from Reference 7. In applying these factors, the 

screening data are first divided by component type and then by screening value 

into leaker or non-leaker categories. The number of components in each 

category is multiplied by the appropriate emission factor. The total emission 

estimate is the sum of all individual category contributions. 

4.1.4 Stratified Method 

Recognizing that the vast majority of components do not leak or have 

very low emissions, the EPA redefined the leak/no leak strategy and developed 

a three-tiered approach. Three ranges of screening values were derived: 0-

1000 ppm, 1001-10,000 ppm, and over 10,000 ppm. Table 4-1 gives the emission 

factors for each component type and service category. The stratified method 

screening value ranges given in Table 4-1, (0 - 999 ppm, 1,000 - 9,999 ppm, 

and _> 10,000 ppm) are slightly different from those published by EPA (0 -

1,000 ppm, 1,001 - 10,000 ppm, and >10,000 ppm), the difference being at the 

boundary between ranges, i.e. at 1,000 and 10,000 ppm. The rationale of this 

4-4 
TABLE 4-1. EPA EMISSION FACTORS IN lb/hr/SOURCEfl 

i 

Component Type 

Valves 

Valves 

Flanges 

Sealed Flanges 

Open-Ended Lines 

Pumps 

Safety Valves 

Sample Points0 

Compressors 

Service 

Liquid 

Gas 

All 

All 

All 

Liquid 

All 

All 

All 

Average 

SOCMI 

0.015600 

0.012300 

0.001830 

0.001830 

0.003700 

0.108900 

0.229100 

0.003700 

0.502200 

Leak/No Leak 

Screen Value Range 

(ppm) 

>10,000 

0.187800 

0.099400 

0.082700 

0.082700 

0.026300 

0.963000 

3.725000 

0.026300 

3.542000 

<10,000 

0.003770 

0.001060 

0.000130 

0.000130 

0.003300 

0.026400 

0.098500 

0.003300 

0.196900 

Stratifiedb 

Screen Value Rang 

0 - 999 

0.000617 

0.000310 

0.000044 

0.000044 

0.000290 

0.004360 

0.025100 

0.000290 

0.024900 

(ppm) 

1000-9999 

0.021230 

0.003640 

0.019290 

0.019290 

0.019300 

0.073800 

0.614500 

0.019300 

0.581500 

e 

>10000 

0.187800 

0.099400 

0.082700 

0.082700 

0.026300 

0.963000 

3.725000 

0.026300 

3.542000 

a Values obtained from Table 3-5 in Protocols for Generating Unit-Specific Emission Estimates for 

Equipment Leaks of VOC and VHAP, EPA Report, October, 1988 (Ref 7). 

The screening value ranges shown are slightly different from those published by EPA. Their ranges 

are 0-1000 ppm, and >10,000 ppm. The ranges in the table are consistent with the leak/no leak 

strategy and represent a more conservative estimation procedure than that given by EPA. 

c Sample points treated as open-ended lines for all purposes. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

o 
P.41 

study was to use the more conservative approach and include the boundary 

values in the higher emission factor category. This approach then provides 

identical emission estimates for the leak/no leak and stratified methods for 

components with screening values of 10,000 ppm (i.e. for leakers). 

For example, consider a pump with a screening value of 10,000 ppm. 

According to the leak/no leak method, this component leaks at an estimated 

emission rate of 0.963 lb/hr. According to the EPA-specified ranges, this 

pump's stratified method estimated emission rate is 0.0738 lb/hr. However, 

using the ranges specified in this BD Panel study, the pump emission rate by 

the stratified method is 0.963 lb/hr, identical to the leak/no leak estimate. 

The application of these factors follows the pattern of the leak/no 

leak method. The components with screening values in each range are counted. 

These values are then multiplied by the appropriate emission factor and all 

contributions are added to derive the total estimated emissions for the 

process area. 

4.1.5 Correlation Equations 

The data obtained by the EPA during the refinery project (2) and the 

SOCMI project (3,4) included screening values and actual fugitive emission 

rate determinations. Statistical evaluation of the data led to development of 

correlation equations to transform screening values to.leak rates for three 

component types in four service categories (7). These were: 

• Valves in light liquid service; 

• Valves in gas service; 

• Flanges, and 

• Pimps. 

The equation for pumps is typically applied to all other categories 

that do not have a specific equation. Table 4-2 shows the four correlation 

equations used in this study; they were taken from Reference 7. 

4-6 
TABLE 4-2. FUGITIVE EMISSIONS CORRELATION EQUATIONS*«b 

Component 

Type Service Correlation Equation** 

"Default Zero" 

Number of Correlation Emission Rate 

Data Pairs Coefficient (lb/hr) 

Valve Gas 1.680 x 10*5 x (SCRNVALU)0693 

Valve Liquid 3.740 x IO"4 x (SCRNVALU)0470 

Flange All 3.731 x 10"5 x (SCRNVALU)0820 

Other All 1.335 x 10"5 x (SCRNVALU)0898 

99 

129 

52 

52 

0.66 

0.47 

0.77 

0.81 

0.000072 

0.001004 

0.000209 

0.000088 

i 

a Emission estimates are calculated in lbs/hr. 

° Taken from Table D-l in Protocols for Generating Unit-Specific Emission Estimates for Equipment 

Leaks of VOC and VHAP, EPA Report, October, 1988 (Ref 7). 

c SCRNVALU - Maximum OVA screening value in ppm. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.43 

Each of the equations predicts a zero emission rate for screening 

values of zero. During the early fugitive emissions studies, the EPA 

determined the actual emission rates for several components that had zero 

screening values. Working backwards through the correlation equations, EPA 

adopted a "default zero" screening value of 8.17 ppm for all sources. The 

mass emission rates corresponding to 8.17 ppm using the correlation equations 

are shown in Table 4-2 as "default zero" mass emission rates in lb/hr. 

4.1.6 Bagging 

If unit-specific correlation factors are desired, the next step is 

to obtain quantitative emission rate data from "bagging" tests. A bagging 

test consists of enclosing the component under test in an air-tight Mylar or 

Tedlar or aluminum shroud or bag. Next, an air stream is pushed through 

(flow-through method) or pulled through (vacuum method) the bag at a measured 

rate. Once equilibrium is established, exhaust air samples are analyzed for 

temperature and for the species of interest; i.e., BD for this study. This 

bag concentration of BD is then converted to the corresponding mass emission 

rate in lb/hr using Equation 1. 

_ . . BD Cone * MW * FR * TC .„ ,, Mass Emission Rate = rzz (Eq. 1) 

nv 

where: 

BD Cone = Concentration of BD in the bag in ppm; 

MW = Molecular weight of BD = 54 lb/lb mole; 

MV = Molar volume of BD = 392 ft3/lb mole at 68°F; 

FR = Air flow rate through the bag in frvhr; and 

TC = Temperature conversion factor based on the ideal gas law to 

convert FR from its measured value to the corresponding flow 

rate at 68°F. 

This value is the actual measured rate of BD emissions from the 

component into the atmosphere. The measured emission rates for several 

components are plotted in log-log space against the corresponding screening 

test results. The EPA correlation equation is drawn on the same plot. If 

4-8 
P.44 

each of the measured (bagged) data points falls below the EPA curve, then the 

EPA curve will overestimate the mass emission rate from the components tested 

and the EPA correlation equation is considered valid for the process area 

tested. If the measured data points are consistently above the EPA curve, 

then the EPA curve underestimates the actual mass emission rate from the 

components tested, the EPA correlation equation is not valid for the process 

area tested, and a different method for estimating fugitive emissions is 

indicated. In general, four to eight comparative data sets (screening and 

bagging test results) are required to validate the correlation equations. 

If the correlation equations are not valid or if the estimates of 

the emissions are far beyond the levels indicated by initial bagging tests, a 

plant may choose to develop a new unit-specific correlation equation that may 

require as many as 20 to 30 bagging tests per source type/service category. 

The final stage of unit-specific fugitive emission estimation is the 

development of an industry-specific emission factor. This is a factor which, 

when multiplied by the number of sources, gives the estimated emissions from 

these sources. Such an emission factor should be based on a large amount of 

data taken from different units of the same type and at different times during 

the maintenance cycle. 

4.1.7 Current Study 

All five of the estimation methods described above were employed in 

this study. Screening test data were used from all participating plants to 

derive estimated emissions using the average SOCMI factors, the Leak/No Leak 

factors, the stratified factors, and the correlation equations. Bagging 

tests, which were optional, were conducted at three of the participating 

plants. 

4-9 
P.45 

4.2 Screening Techniques 

As applied to the BD fugitive emissions study, screening analysis 

corresponded to a supplemented version of EPA Reference Method 21. A copy of 

the reference method is contained in Appendix 1. 

EPA Method 21 describes a procedure for identifying and screening 

VOC leaks from process equipment. Several performance specifications are 

given in the method. Analytical requirements include: 

• Instrument response factor (RF) must be less than 10 for the 

compound of interest; 

• Instrument response time must be less than 30 seconds; and, 

• Instrument calibration precision must be within 10%. 

Other requirements for the analyzer include: 

• It must contain an internal pump capable of sampling at a rate 

of 0.5 to 3 liters per minute; 

i 

• It must be intrinsically safe; and, 

• It must be calibrated with certified (^2% accuracy) standard 

gases. 

The method describes the procedure for screening valves, 

connectors/flanges, pumps/compressors, pressure-relief devices, process 

drains, open ended lines/valves, seal systems, and access doors. The 

determination of background levels is also described. Finally, the 

measurement of instrument response factors, calibration precision, and 

response times are described. 

4-10 
P.46 

The instrument chosen for the BD fugitives emission study was the 

Foxsboro OVA-108 (Organic Vapor Analyzer). This analyzer is a portable flame 

ionization detector- (FID-) based instrument. It contains an internal pump 

that draws approximately 1 L/min of sample. The air drawn in with the sample 

provides the air for the flame. The unit is battery powered and has an 

internal hydrogen cylinder with enough fuel for 8 to 10 hours of continuous 

operation. The unit is certified by the manufacturer to be intrinsically 

safe. The analyzer has a logarithmic readout covering the range 1 to 10,000 

ppm. 

A 10-to-l dilution probe is available for the OVA-108 instrument. 

Use of this device allows the instrument to respond to up to 100,000 ppm. 

Dilution probes were typically not used in this study, and components with 

screening values at or above 10,000 ppm were assigned an emission rate equal 

to the leak factor from the Leak/No Leak method. The correlation equations 

for data above 10,000 ppm were not used since the equations were derived from 

data where "pegged sources" (i.e., sources with screening values above 10,000 

ppm) were excluded. 

The OVA responds to many organic compounds in addition to BDr. The 

response of the analyzer to a mixture containing BD and other organic 

compounds will be a combination of the response attributable to each 

compound. In general, a weighted basis calculation is used to determine the 

instrument response from a mixture. This is described in more detail later in 

the report. 

4.3 Calibration 

In accordance with EPA Method 21, the OVA instrument must be 

calibrated by adjusting the meter reading with a hydrocarbon-free air source 

and by using a certified standard gas containing approximately 8,000 ppm of 

methane in air. Subsequently, the instrument response to BD in air standards 

is determined using at least three standard gases covering the range of 20 to 

20,000 ppm BD. Instrument response factors for each standard gas were 

determined from the following equation: 

4-11 
P.47 

RF = Actual Concentration/Instrument Response (Eq. 2) 

The data are subjected to a linear least squares analysis. If the 

correlation coefficient exceeds 0.99, the analyzer is judged to have a linear 

response to BD, and the RF for BD is the average RF from the upscale readings. 

For analyzers whose correlation coefficient is less than 0.99, calibration 

curves are developed and used to convert raw OVA values to screening values. 

For this BD study, all calibration data submitted corresponded to correlation 

coefficients greater than 0.99 and average response factors were used for all 

data calculations. 

4.4 Screening Protocol 

Before conducting the field tests, the 1,3-Butadiene Panel and EPA 

agreed to a screening protocol. A copy of this protocol appears in Appendix 

2. Key provisions are summarized below: 

• More than 90% of the U.S. production capacity of BD would 

participate; 

• All streams containing >5% BD would be included; 

• Components accessible by platform, ladder, or manlift up to 40 

feet above grade would be tested; 

• Components to be tested included: 

— Valves (all, in both liquid and gas service), 

— Pumps (all), 

— Safety Valves not vented to a header system (all) , 

— Open-ended line s unless plugged or blind flanged (all) , 

4-12 
P.48 

— Compressors (all), 

— Sample Points except closed loops, plugged lines, and lines 

venting to a control device (all), and, 

— Connectors and flanges (up to about 150 on a randomly 

selected basis, but excluding insulated flanges); 

• Bagging tests were optional; 

• Bagging tests, if performed, would include 2 to 9 bags per 

component type/service category; 

• An OVA instrument would be used for screening tests; 

• Either the vacuum or blow-through technique would be used for 

bagging tests; 

• The CMA Guidance Document published in August, 1988 (11) would 

be followed and no special inspection and maintenance (I&M) 

procedures would be allowed before or during the test period; 

• The QA/QC procedures outlined in the CMA Guidance Document 

would be followed and the results documented; 

• A concurrent industrial hygiene study was recommended; and 

• All parties agreed to accept the results of the study. 

4.5 BD Workbook 

The 1,3-Butadiene Panel contracted Radian Corporation in Austin, 

Texas to oversee the testing effort, analyze the data, and generate a final 

report. To facilitat e uniformity in data collection and to answer any 

questions concerning the screening protocol, a BD Fugitives Workbook (12) was 

4-13 
P.49 

prepared and distributed to all participants at a 1,3-Butadiene Panel workshop 

on held April 26, 1988. Included in the workbook were forms designed to 

obtain consistent screening and QC data from all participants. Data to be 

collected included screening, instrument calibration, and instrument drift. 

Each of the data forms is discussed below. 

4.5.1 1,3-Butadiene Screening Survey Report Form 

Figure 4-2 shows a 1,3-Butadiene screening survey data form. An 

explanation of the data anticipated for each entry is given below: 

• Plant ID - Plant identification information; 

• Instrument ID - Unique identification information describing 

the analyzer used to obtain the data; 

• Analyst's Name - Person collecting the data who should be 

contacted concerning the data; 

• Date - Date of screening test; 

• Background Reading Time - Time of day when the particular data 

sheet was first used; 

• Uncorrected Value - OVA analyzer reading in the vicinity of the 

components being tested (see Method 21 for details); 

• Average RF - Average of response factor data from the latest 

multipoint calibration using BD standard gases (if the 

correlation coefficient was >0.99); 

• Calibration Curve (Y/N) - A space to indicate whether a 

calibration curve was needed to convert raw OVA values to 

screening values (typically not used by the participants in 

this survey); 

4-14 
Plant ID 

Inetruaent 10 

Analyat Naae 

Phone No. 

Oate 

Average RF 

Calibration Curve (Y/N) 

Laat Date Screened 

Background Reading 

Tiae 

Uncorrected Value (ppav) 

Flow 

Seq.- Sheet Location 

No. No. P&ID 

Service Category/Proceaa Streaa 

Coap BD Solvent 

Coap Sixe* Coap Ht. Naae/ 

Type (in.) Category* Phaae Z Ut. Z 

Screening Value 

OVA BD 

Reading Specific * 

(ppav) (ppav) Coaaent 

•Optional Figur e 4-2 . Example Screening Data Report Form. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

Ul 
P.51 

• Seq. No. - Sequence number used to keep track of the order of 

component testing (typically not used by participants); 

• Flow Sheet No. - Plant-specific identification information; 

• Location P&ID - Plant-specific identification information; 

• Component Type - Type of component being screened. For this 

study the protocol designated the following component types: 

— Valves (VLV); 

— Pumps (PMP); 

— Connectors or flanges (FLN); 

— Safety Valves (SV); 

— Open-Ended Lines (OEL); 

— Compressors (COM); and 

— Sample Points (SP). 

• Size - Size of the component itself or the size of the line 

feeding into the component; 

• Component Category - Description of the type of component being 

tested; e.g., ball, globe, butterfly, etc. for valves; 

• Phase - Phase of the stream in the component (liquid or gas); 

• BD % - Percent by weight of BD in the stream (>5% for this 

survey); 

• Solvent Name - Name of the major organic solvent for mixed 

streams; 

• Wt. % - Percent by weight of the major solvent named above; 

4-16 
P.52 

• OVA Reading (ppm) - Raw OVA screen value, uncorrected for 

instrument response, stream composition, or background; 

• BD Specific (ppm) - Results of BD specific screen tests such as 

sorbent tubes; and 

• Comments - Space for any observations or other comments 

concerning the specific component being tested. 

In actual practice, the spaces for response factor and calibration 

curve were not used, since most participants provided raw calibration and 

other QC data to be included in the data analysis. Sequence numbers, flow 

sheet numbers, and location P&ID data were all placed in the data base as 

plant identification information only. Final sequence numbers were assigned 

by the computer so that each component was uniquely identified in the data 

base. Many plants submitted secondary solvent names and percentages with 

their data. The data base and calculations for all the plants were expanded 

to have the capability for including as many as two organic solvents. 

4.5.2 Calibration Data Sheet for 1,3-Butadiene Screening 

The BD workbook requested that the plants calibrate their analyzers 

daily using a methane standard of approximately 8,000 ppm. Included in the 

instrument calibration procedure is a procedure for adjusting the instrument 

zero "full-scale" response. The plants were to determine the analyzer 

response to three standard gases containing approximately 20 ppm, 200ppm, and 

2,000 ppm BD in air. For each standard, the instrument response factor was to 

be determined using Eq.2 (see Section 4.3) and the instrument linearity 

determined using a linear least squares analysis. If the correlation 

coefficient was greater than 0.99, the instrument was considered linear and 

the RF was the average of the three upscale RF values. If the correlation 

coefficient was less than 0.99, a calibration curve was generated for 

converting the raw OVA values to VOC screening values. Figure 4-3 shows an 

analyzer calibration sheet. 

4-17 
CALIBRATION DATA SHEET FOR 1.3-BUTADIENE SCREENING 

Plant ID 

Instrument ID Certified Methane Concentration 

Analyst Name Certified BD Concentrations 

Low Medium High 

Methane Blank Standard Standard Standard 

Reading Reading Response Response Response Low Medium High Average 

Date Time (ppm) (pf*) (ppm) (ppm) (ppm) R RF RF RF RF Comments 

**-

i 

i - * oo 

a) R = correlation coefficient 

Figure 4-3. Example Calibration Reporting Form. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.54 

The participants varied considerably in their adherence to the 

request concerning calibration. Most plants complied fully with the request. 

Three plants did not submit calibration data. 

4.5.3 Drift Test Data Sheet for 1,3-Butadiene Screening 

The BD workbook requested that participants challenge their 

analyzers with one of the calibration standards three times a day (at the 

beginning, in the middle, and at the end of the day) to determine if the 

analyzer response was drifting. They were to recalibrate the instruments if 

more than 20% error was found. Figure 4-4 shows an analyzer drift test report 

form. Zero response drift (if any) was handled by the "zero" procedure as 

part of the daily calibration procedure. 

As with the calibrations, the plants varied considerably in adhering 

to this request. Drift test data were not received from three plants. 

4.6 Quality Control Results 

Virtually all instruments for which methane calibration data were 

submitted were found to be operating properly and achieved a methane response 

factor of 1.00. The results of the individual plant BD calibration and drift 

tests appear in Appendix 3. A summary table showing the range of results for 

each plant is presented in Table 4-3. 

The individual plant BD calibration data were initially examined for 

linearity of response using a linear least squares analysis of the multipoint 

data. The correlation coefficients shown in Table 4-3 range from 0.9982 to 

0.9999. As described earlier, if the resulting correlation coefficient was 

greater than 0.99, the instrument was considered linear and, in general, the 

average BD response factor was used to calculate results. In some instances, 

the low RF values were not used to determine the RF to be applied. In these 

cases, the variability in the low range RF was well above the variability for 

the other ranges and well above the variability of all other plants. 

4-19 
Plant ID 

Instrument ID 

Analyst Name 

DRIFT TEST DATA SHEET FOR 1.3-BUTADIENE SCREENING 

Date 

Nominal 

Gas 

Cone, 

(ppmv) 

Pre Test 

Cone. Z 

(ppmv) Error 

Mid Test 

Cone. Z 

(ppmv) Error 

Post Test 

Cone. Z 

(ppmv) Error Coo ments 

N3 

O 

. -, certified cone- measured cone, 

a) % error = •— x 100 

certi f ied rone. 

Figure 4-4. Example Drift Test Report Form. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.56 

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4-21 
P.57 

Periodically, the analyzers were tested for drifting response. The 

results for these drift tests (shown in Table 4-3) range from 0 to 18%. All 

of the results are within the 20% drift acceptability limits originally 

recommended by the BD Workbook. 

4-22 
P.58 

5.0 DATA ANALYSIS 

This section contains a description of the data analysis methods and 

summary descriptions of the data submitted by the participating plants. 

5.1 Converting Raw OVA to BD-Specific Emission Estimates . 

The theory behind converting raw data to emission estimates is first 

presented in this section, then three examples are given. 

5.1.1 Theory 

The data sheets requested background OVA values, along with raw 

screening values and stream composition data for the components tested. If 

the Raw OVA screening value was equal to or greater than 10,000 ppm, as 

defined by EPA, then the component was declared to be a leaker (10) and the 

emissions contribution from the Leak/No Leak table (Table 4-1) was assigned 

for all remaining.data analysis purposes to that component; i.e., the 

screening-to-leak rate correlation equations were not used to calculate an 

emission estimate for these "pegged" sources. For all non-leakers, a 

screening value corresponding to the total VOC emissions was derived and a 

fugitive emissions estimate was made according to the following guidelines; 

• Corrected screen value - The background OVA value was 

subtracted from the raw screening value to obtain a corrected 

screening value. This corrected OVA value was set to zero if 

the calculated value was less than zero. 

• VOC screen value - The corrected screening value was adjusted 

to account for line composition and instrument response factors 

using Equation 3; 

(Eq. 3) 

VOC Corrected 

Screen = [(BD% x BD RF) + (S0L1Z x SOLI RF) + (S0L2% x S0L2 RF)] * Screen 

(BD % + SOLI % + S0L2 %) Value 

5-1 
P.59 

where:. BD% is the percentage of BD in the component under test; 

BD RF is the instrument response factor for butadiene 

derived from the data supplied with the screening test 

results (see individual plant RF data given in Appendix 

3 ); 

S0L1% and SOL2% are the two major organic solvents listed 

on the data sheet (only those that would have an OVA 

response were included); 

SOLI RF and S0L2 RF are the published response factors for 

Solvent 1 and Solvent 2, each at an OVA meter reading of 

10,000 ppm (13) (see Table 5-1 for the compound names and 

RF values used in the calculations). 

• Average SOCMI Emissions Estimate - The estimated VOC mass 

emissions for each component were calculated from the direct 

application of the average SOCMI emissions factor previously 

shown in Table 4-1. 

• BD Weight Fraction - The weight fraction of BD in the stream as 

listed on the data sheets. For this study, we assumed that all 

streams contained 100%*organic compounds. 

• Weighted SOCMI Emissions Estimate - The estimated BD emissions 

derived from multiplying the average SOCMI (Total VOC) emission 

estimate by the fraction of BD in the stream. 

• Leak/No Leak Emission Estimate - The VOC screening value for 

each component was assessed to determine if the component was 

leaking (i.e., 2.10*000 ppm). The appropriate emission factor 

from Table 4-1 was selected and corrected for the BD weight 

fraction to determine the BD emission rate. For components 

5-2 
P.60 

TABLE 5-1. ORGANIC SOLVENTS AND RESPONSE FACTORS8 

Compound RF 

1-BUTENE .5 6 

3-METHYL-l-BUTENE .5 6 

ACETONITRILE .95 

ACETYLENE .39 

BENZENE .29 

CIS-1-BUTENE .5 6 

DMF 4.1 9 

ETHANE .6 5 

ETHYLENE .7 1 

ISO-1-BUTYLENE .56 

ISO BUTANE .41 

METHANE 1.0 0 

METHYL ACETYLENE .3 9 

MIXED C3'S .6 8 

MIXED C4»S .55 

MIXED C5'S .5 2 

N-BUTuANE .50 

PROPANE .5 5 

PROPYLENE .7 7 

SEAL OIL (O-DCB) .6 8 

VINYL ACETYLENE .3 9 

a

 Source: Reference 13. 

5-3 
P.61 

with a RAW OVA value of 10,000 ppm or greater, the Leak 

emission factor was assigned automatically before correction 

for BD weight fraction. 

• Stratified Emission Estimate - The VOC screening value for each 

component was compared with the low range of 0 to 999 ppm, a 

mid-range of 1000 to 9999, and the high range of 10,000 ppm or 

more. The appropriate emission factor from Table 4-1 was 

selected and corrected for BD weight fraction to estimate the 

BD fugitive emissions. For components with a RAW OVA value of 

10,000 ppm or greater, the HIGH emission factor was 

automatically assigned and then corrected for the weight 

fraction of BD in the stream. 

• Calculated Emission Estimate - For components declared to be 

leakers because their RAW OVA value was 10,000 ppm or more, the 

appropriate Leak contribution from the Leak/No Leak table was 

selected for the calculated emissions estimate. For all other 

components, the VOC screening value was used in the correlation 

equations from Table 4-2 and the resultant emissions corrected 

for BD weight fraction to determine the BD fugitive emission 

estimate. For components with a VOC screening value below 8.17 

ppm, the EPA-mandated lower limit of 8.17 ppm was used in the 

calculation. 

An additional calculation was made using default zero mass emission 

rates derived from bagging data collected from several "zero screening" 

components in two plants. This topic is discussed in greater detail in 

Section 5.4. 

5.1.2 Practical Examples 

This section provides detailed descriptions of the calculations used 

for several combinations of components, screening values, and line 

compositions. 

5-4 
P.62 

Example 1: 

• Component Type = Valve in liquid service; 

• Raw Screening Value = >10,000 ppm; 

• Background OVA Value = 3 ppm; 

• BD% = 55%; 

• BD RF = 2.76; 

• Solvent 1 = Mixed C4's at 45%; 

• The average SOCMI emission estimate for this component comes 

directly from Table 4-1 and is 0.0156 lb/hr; 

• The weighted SOCMI emission estimate is 55% (note BD% = 55%) of 

the standard SOCMI value, or 0.00858 lb/hr); 

• The Leak/No Leak emission estimate is taken directly from Table 

4-1 and is 0.1878 lb/hr. Note that since this component gave a 

"pegged" OVA screen value, it is declared to be a "leaker" and 

no corrections are made for instrument RF or line composition; 

and 

• All other emission estimates (stratified and correlation 

curves) are assigned the same leak value (0.1878 lb/hr) as 

above. 

Example 2: 

• Component Type = Valve in gas service; 

• Raw Screening Value = 2,000 ppm; 

5-5 
P.63 

• Background OVA = 3 ppm; 

• BD% =40%; 

• BD RF = 2.76; 

• Solvent 1 = Mixed C4's at 60%; 

• The average SOCMI estimated emission rate from Table 4-1 is 

0.0123 lb/hr; 

• The weighted SOCMI estimated emission rate is 0.01^3 x 0.40 

0.00492 lb/hr; . 

• The corrected OVA value = 2,000 - 3 = 1997 ppm; 

• The VOC screen value = 

1997 x (0.40 x 2.76 + 0.60 x 0.55) = 2.864 ppm 

(.40 + .60) 

where: 0.55 is the RF for mixed C4's as given in Table 5-1. 

• The Leak/No Leak estimated emissions are 40% of 0.001060 = 

0.000424 lb/hr. Since 2,864 ppm is less than the 10,000 ppm 

level necessary for a leaker, this component is considered to 

be a non-leaker, and the 0.001060 lb/hr contribution for VOC is 

appropriate. 

• The stratified method estimated emissions are 40% of 0.003640 = 

0.001456 lb/hr. The 2,864 ppm VOC screening value falls in the 

mid-level strata. 

5-6 
P.64 

• For the correlation curve, the 2,864 ppm VOC screening value is 

substituted into the gas phase valve equation of Table 4-2 to 

give a total VOC emissions estimate of 0.004178 lb/hr. The BD 

portion of this is 40%, or 0.001671 lb/hr. Since this is well 

above the default zero values (of both EPA and the BD Panel), 

no further corrections are necessary. 

Example 3: 

Component Type = Flange; 

Raw Screening Value = 5 ppm; 

Background OVA = 3 ppm; 

BD% =7% ; 

BD RF = 2.76; 

Solvent 1 = 1-Butene at 93%; 

The average SOCMI emissions estimate is 0.00183 lb/hr; 

The weighted SOCMI emission estimate is 0.00183 x 0.07 

0.000JL28 lb/hr; 

The corrected OVA value = 5-3 = 2 ppm; 

The VOC screen value = 

(.07 x 2.76 + .93 x 0.56) , .. 

2 x (.07 + .93) = 1<4 3 Pp m 

The Leak/No Leak estimate = .000130 x .07 = 0.000009 lb/hr; 

5-7 
P.65 

• The stratified method estimate = 0.000044 x .07 = 0.000003 

lb/hr; 

• Through straight forward application of the correlation 

equation, the correlation curve gives a preliminary estimate of 

0.0000500 lb/hr. A BD-specific value of 0.0000035 lb/hr is 

obtained by multiplying by the BD weight fraction (0.07); 

• The estimated emissions value calculated from the correlation 

curve is also less than the BD Panel default value (0.0001788 

lb/hr) from this study (details are presented in Section 5.4 of 

this report). Therefore, the correlation curve (BD Panel 

default) estimate of 0.0001788 lb/hr would apply to the 

component for this method. Note that no correction for % BD is 

made since the BD Panel default zero values are already 

specific for BD. 

5.2 Summary of Components Studied. 

Screening data from a total of 44,013 individual components were 

received from 13 butadiene production facilities. These data are summarized 

by plant in Table 5-2. Fewer than 1% (432) of the components were 

inaccessible. Of the 43,581 accessible components, 53.3% (23,233) were valves 

in liquid service, 14.5% (6,315) were valves in gas service, 26.2% (11,428) 

were flanges, and 4.0% (1,744) were open-ended lines. The remaining 2.0% 

(821) comprised a combination of pumps, safety valves, sample points, and 

compressors. 

The production of BD proceeds by stages from the crude chemical 

through purification to the finished product. The concentration of BD 

increases steadily throughout this process. The temperature, pressure, and 

other operating conditions vary throughout the. different stages of the 

production process. To investigate whether differences in emissions resulted 

from differences in plant operations, the data were studied as a function of 

the following ranges of BD composition: 

5-8 
TABLE 5-2. SUMMARY DISTRIBUTION OF ALL COMPONENTS BY PLANT 

Ul 

I 

sO 

Plant 

No. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

Total 

Liquid 

Valves 

1,718 

1,311 

501 

767 

1,373 

480 

2,471 

1,884 

266 

412 

135 

3,521 

8,394 

23,233 

G« as 

Valves 

1 

1 

6 

627 

191 

218 

116 

836 

555 

,059 

580 

62 

14 

48 

313 

,696 

,315 

Flanges 

2 

6 

11 

213 

21 

918 

150 

62 

0 

150 

181 

158 

147 

136 

,534 

,758 

,428 

OF >enEnded 

Lines 

1. 

1, 

47 

0 

0 

0 

5 

0 

12 

3 

0 

11 

0 

666 

0 

744 

Pumps 

34 

21 

9 

25 

17 

14 

67 

20 

3 

6 

0 

63 

97 

376 

Safety 

Valves 

3 

16 

2 

0 

10 

13 

0 

71 

9 

4 

0 

33 

267 

428 

Sample 

Points 

16 

1 

20 

0 

0 

0 

3 

0 

0 

0 

0 

0 

0 

40 

Compressors 

0 

0 

0 

0 

1 

0 

2 

0 

0 

0 

0 

0 

14 

17 

Accessible 

Total 

2,658 

1,561 

1,668 

1,058 

2,304 

1,062 

3,764 

2,739 

498 

594 

319 

8,130 

17,226 

43,581 

Inaccessible 

137 

0 

0 

0 

0 

0 

76 

2 

1 

0 

0 

0 

216 

432 

Total 

2,795 

1,561 

1,668 

1,058 

2,304 

1,062 

3,840 

2,741 

499 

594 

319 

8,130 

17,442 

44,013 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
• 5% to 30%; 

• 30% to 90%; and 

• 90% to 100%. 

Table 5-3 shows the distribution of components by BD concentration. The upper 

portion of Table 5-3 shows the actual numbers of components of each type 

(i.e., the number of valves in liquid service, the number of valves in gas 

service, etc.) in each of the three BD concentration ranges. The bottom 

portion of Table 5-3 shows the percentage of each type of component in each of 

the three BD concentration ranges. For example, the 5,163 valves in liquid 

service in the BD range of 5% to 30% represent 22.22% of the total number of 

liquid valves (23,233) tested in the study. More than 32 percent of the 

components tested in this study were in lines containing 90% or more BD. 

About 47.percent of the components tested were in the BD concentration range 

of 30% to 90%. The concentration range of 5%-30% BD contained about 20% of 

the number of components tested. 

Table 5-4 shows a distribution of the tested components in each BD 

concentration range by raw OVA screening value. The OVA screening values 

cover a five-decade range from 10 ppm to 10,000 ppm or more. The upper 

portion of Table 5-4 shows the number of components in each category, while 

the lower portion shows the percentage of the total contained in each range. 

The data indicate the large number of components with very low screening 

values. Over 67% of all components in each BD concentration range have 

screening values at or below 9 ppm, i.e., essentially at or below the EPA 

"default zero" screening value. More than 92% of all components in each BD 

range had screening values below 100 ppm. 

Table 5-5 shows a distribution of the tested components for each 

component type in each raw OVA screening value range (without regard to BD 

concentration). The upper portion of Table 5-5 shows the number of components 

in each category, while the lower portion shows the percentage of the total 

contained in each range. The percentage values are shown graphically in 

Figure 5-1. Some general observations can be made from these results. 

5-10 
P.68 

TABLE 5-3. DISTRIBUTION OF COMPONENTS BY BD CONCENTRATION 

NUMBER OF COMPONENTS IN BD CONCENTRATION RANGE 

Component Type 5% - 30% 30% - 90% 90% - 100% Total 

Valve (Liquid) 

Valve (Gas) 

Flange 

Open-Ended Line 

Pump 

Safety Valve 

Sample Point 

Compressor 

Total Number: 

5163 

1728 

1700 

211 

73 

99 

8 

14 

10373 

2141 

6340 

1046 

152 

206 

11 

3 

7697 

2446 

3388 

487 

151 

123 

21 

0 

23233 

6315 

11428 

1744 

376 

428 

40 

17 

8996 20272 14313 43581 

Component Type 

Percentage of Components In BD Concentration Range 

5% - 30% 30% - 90% 90% - 100% 

Valve (Liquid) 

Valve (Gas) 

Flange 

Open-Ended Line 

Pump 

Safety Valve 

Sample Point 

Compressor 

WEIGHTED AVERAGE %: 

22.22 

27.36 

14.88 

12.10 

19.41 

23.13 

20.00 

82.35 

44.65 

33.91 

55.47 

59.98 

40.43 

48.13 

27.50 

17.65 

33.13 

38.73 

29.65 

27.92 

40.16 

28.74 

52.50 

0.00 

20.64 46.52 32.84 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-11 
P.69 

TABLE 5-4 . DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD CONCENTRATION 

Butadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

Total 

(all BD Ranges) 

Butadiene 

Concentration 

Number 

0-9 ppm 10-

5949 

16245 

10747 

32941 

of Components 

99 ppm 

2361 

3048 

2891 

8300 

Percentage of 

0-9 ppm 10-99 

Ln 

100 to 

999 ppm 

306 

292 

261 

859 

Components 

ppm 

Screening 

1000 to 

9999 ppm 

250 

323 

191 

764 

Value Range 

•9999 

ppm 

130 

364 

223 

717 

in Screening Value Rar 

100 to 

999 ppm 

1000 

9999 

to 

ppm 

Total 

8996 

20272 

14313 

43581 

ge 

>9999 

ppm 

5% t o 30% 66.13 

30% t o 90% 80.14 

90% t o 100% 75.09 

Weighted Average 3 75.59 

26.24 

15.04 

20.20 

19.04 

3.40 

1.44 

1.82 

1.97 

2.78 

1.59 

1.33 

1.75 

1.45 

1.80 

1.56 

1.65 

a

 Weighted Average means tha t the value for each BD range was "weighted" by 

the number of components in tha t range . An alternativ e way of looking a t 

this value is tha t i t is the tota l number of components in the screening 

value range expressed as a percentage of the tota l number of components in 

a l l ranges. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-12 
P.70 

TABLE 5-5 . DISTRIBUTION OF COMPONENTS BY RAW OVA SCREENING VALUE FOR ALL 

PARTICIPATING PLANTS ALL COMPONENTS AND ALL BD CONCENTRATIONS 

Number of Comp 

Component Type 0-9 ppm 10-99 ppm 

onents in Screening Value Range 

100 t o 1000 t o >9999 

999 ppm 9999 ppm ppm Tota l 

Valve (liq ) 15735 5775 

Valve (gas) 4260 1644 

Safety Valve 368 44 

Sample Point 12 15 

Pump 174 116 

Open-Ended Line 1692 31 

Flange ' 10686 672 

Compressor 14 3 

Total Number: 32941 8300 

606 

174 

8 

8 

23 

5 

35 

0 

859 

571 

127 

2 

3 

34 

5 

22 

0 

764 

546 

110 

6 

2 

29 

11 

13 

0 

717 

23233 

6315 

428 

40 

376 

1744 

11428 

17 

43581 

Percentage of Components in Screening Value Range 

100 t o 1000 t o >9999 

Component Type 0-9 10-99 ppm 999 ppm 9999 ppm ppm ppm 

Valve (liq ) 

Valve (gas) 

Safety Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Weighted Average3 

67.73 

67.46 

85.98 

30.00 

46.28 

97.02 

93.51 

82.35 

24.86 

26.03 

10.28 

37.50 

30.85 

1.78 

5.88 

17.65 

2.61 

2.76 

1.87 

20.00 

6.12 

0.29 

0.31 

0.00 

2.46 

2.01 

0.47 

7.50 

9.04 

0.29 

0.19 

0.00 

2.35 

1.74 

1.40 

5.00 

7.71 

0.63 

0.11 

0.00 

75.59 19.04 1.97 1.75 1.65 

3

 Weighted Average means tha t the value for each BD range was "weighted" by 

the number of components in tha t range. An alternat e way of looking a t this 

value is tha t i t is the tota l number of components in the screening value 

range expressed as a percentage of the tota l number of components in al l 

ranges. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-13 
P.71 

C 

s 

£ 

100 

90 -

80 -

70 -

60 -

2" 

s 

o 50-1 

40 -

30 

20 -

10 -

<10 ppm 

s 

§ 

p Ul 

o 

<100 ppm <1000 ppm -< 10,000 ppm 

OVA Screening Value, ppm 

< 10.000 ppm 

Valve (liq) 

Valve (gas) 

Pump 

Open-Ended Line 

| | Range 

Figur e 5-1 . Distributio n of Selecte d Components by Raw OVA Screening Value 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-14 
P.72 

Overall, the percentage of components having screening values of less than 10 

ppm varied from a high of 97% for open-ended lines to a low of 30% for sample 

points. At the other end of the scale, the percentage of leakers varied from 

a high of 7.7% for pumps to a low of 0% for compressors. More detailed 

results and a discussion of each component type will appear in the following 

sections of this report. 

Estimated emissions were determined for all of the 43,581 accessible 

components reported in this study. Each of the estimation methods previously 

described was included. The mean or average value for each component type and 

service category was determined. These mean values are shown in Table 5-6. 

In general, the progression of estimates as one proceeds from left to right in 

the table involves increasingly more sophisticated methods of estimating 

fugitive emissions. The average SOCMI estimate takes into account only the 

number of components and the average SOCMI value from the EPA study conducted 

about 10 years ago. The weighted SOCMI values simply correct the average 

SOCMI values for the percentage of BD in the lines. The leak/no leak value 

divides the components into leakers or non-leakers, based on the OVA screening 

value, applies the appropriate emissions factor for each component, and 

corrects for the percentage of BD. The stratified emissions method partitions 

the components into three categories, depending on OVA screening value, 

applies the appropriate emission factor, and corrects for BD composition. All 

other emissions estimates use the EPA correlation equations (previously given 

in Table 4-2) with different "default values". 

A default or lower level of detection (LLD) of 8.17 ppm is specified 

by the EPA, based on the data set that they have generated. Early in this 

study, many member companies expressed their belief that a more appropriate 

LLD would be either 2 or 1 ppm. Also, some members believed that the 

correlation calculation should be based on the actual value obtained, i.e., 

allowing the LLD to go to 0 if that was reported. Finally, the results of 

bagging tests conducted during this study provided adequate data to derive new 

and individual "default zero" emission estimates for each of the four 

5-15 
TABLE 5-6. 1,3-BUTADIENE FUGITIVE EMISSIONS SURVEY SUMMARY REPORT FOR ALL PLANTS: 

COMPARISON OF MEAN EMISSION FACTORS FOR ALL CALCULATION METHODS 

Component Type 

Valve (liq) 

Valve (gas) 

Safety Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Number of 

Components 

23233 

6315 

A 28 

40 

376 

1744 

11428 

17 

Mean OVA 

Screen 

Value 

(ppm) 

1507 

1109 

1035 

2416 

2841 

431 

60 

4 

ESTIMATED EMISSION FACTORS 

Average 

SOCMI 

Emission 

Factor 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

.502200 

Weighted 

SOCMI 

Emission 

Factor 

.009314 

.007399 

.129953 

.002470 

.069852 

.002514 

.001116 

.140321 

Leak/ 

No Leak 

Emission 

Factor 

.005591 

.002060 

.085197 

.002703 

.089865 

.002336 

.000164 

.055016 

USING 1KB METHODS LISTED 

Calculated 

Stratified 

Emission 

Factor 

.003988 

.001636 

.045755 

.002684 

.080111 

.000335 

.000129 

.006957 

Calculated 

Emission 

Factor 

LLD=8 ppx 

.003619 

.001141 

.030005 

.002657 

.056372 

.000177 

.000257 

.000025 

— ALL VALUES ARE IN lB/hr/SOURCB 

Calculated 

Emission 

Factor 

LLD-2 ppm 

.003476 

.001326 

.029590 

.002643 

.060397 

.000147 

.000174 

.000008 

Calculated 

Emission 

Factor 

LLD=1 ppm 

.003405 

.001321 

.029584 

.002641 

.060393 

.000139 

.000157 

.000005 

Calculated 

Emission 

Factor 

LL0=0 pf» 

.003221 

.001312 

.029577 

.002639 

.060388 

.000130 

.000135 

.000001 

Calculated 

Emission 

Factor 

BD Panel* 

.003140 

.001105 

.029960 

.002640 

.056339 

.000120 

.000307 

.000004 

Reduction 

rt) 

79.9 

91.0 

86.9 

28.6 

48.3 

96.8 

83.2 

99.9+ 

Default zero values were determined separately for valve s in liquid service , valve s in gas service , flanges, and open-ended line s (others). 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 
P.74 

component types that have correlation equations. The details of this bagging 

study are presented later, along with the new default zero emissions values 

(Section 5.4 and Table 5-36). Table 5-6 shows the average emissions estimates 

allowing each of these default zero values. 

Except for permanent sample points, the value for each component 

decreases going from left to right in Table 5-6. This shows the improvement 

afforded by each of the more sophisticated estimation methods. However, the 

correlation equation values using the new default zero from this study are 

slightly higher than the values derived when actual zero emissions were 

allowed. The overall reduction in estimated emissions achieved using the 

correlation equations with BD Panel defaults, as compared with the average 

SOCMI emissions, is shown in Table 5-6 in the last column. The level of 

reduction ranges from 28.6% for sample points to 99.99+% for compressors. 

Without a screening survey, a plant's best way to estimate fugitive 

emissions of BD would involve simply correcting the average SOCMI estimates 

for BD concentration. The best emission estimate method, however, is a 

screening survey followed by application of the correlation equations. The 

EPA specifies a default value of 8.17 ppm. The present study has developed 

new default values. Emission estimates obtained by each of the four methods 

t 

are reported throughout the remainder of this report so that the results may 

be compared. 

The upper portion of Table 5-7 compares the mean emission factors 

(in lb/hr/source) by each method for each component type included in the 

study. The lower portion of Table 5-7 shows the total estimated emissions (in 

lb/hr) for each component type. This represents a rough estimate of the 

fugitive emissions of 1,3-Butadiene produced by the plants participating in 

this study. 

5-17 
1 

00 

TABLE 5-7 . SUMMARY OF ESTIMATED 1 

EMISSION ESTIMATES FOR 

Component 

Type 

Valve (liq ) 

Valve (gas) 

Safet y Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Component N 

Type C 

Valve (liq ) 

Valve (gas) 

Safet y Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Number of 

Components 

23233 

6315 

428 

40 

376 

1744 

11428 

17 

umber of 

omponent s 

23233 

6315 

428 

40 

376 

1744 

11428 

17 

Hean Raw 

OVA Screen 

Value 

(ppm) 

1507 

1109 

1035 

2416 

2841 

431 

60 

4 

Mean Raw 

OVA Screen 

Value (ppm) 

1507 

1109 

1035 

2416 

2841 

431 

60 

4 

Flange emissio n multiplie d by 4.1 4 which 

Total annual emission s based on a stream 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. 

,3-BUTADIENE FUGITIVE EMISSIONS FOR ALL PARTICIPATING PLANTS: 

ALL COMPONENTS 

Mean BD 

Amount 

(%) 

59. 7 

60. 2 

56.7 . 

66. 8 

64. 1 

67. 9 

61. 0 

27. 9 

Mean BD 

Amount 

(%) 

59. 7 

60. 2 

56. 7 

66. 8 

64. 1 

67. 9 

61. 0 

27. 9 

Mean Emission Factor s (All Values in lb/hr/source ) 

Average Weighted Correlatio n Correlatio n Curve 

SOCMI SOCMI Curve (EPA) BD Panel 

.015600 .009314 .003619 .00314 0 

.01230 0 .007399 .001141 .001105 

.22910 0 .129953 .030005 .02996 0 

.00370 0 .002470 .002657 .00264 0 

.108900 .069852 .056372 .05633 9 

.00370 0 .002514 .000177 .00012 0 

.00183 0 .001116 .000257 .000307 

.50220 0 .140321 .000025 .00000 4 

BD Panel 

Tota l Emissions (All Value s In lb/hr ) Estimated 

Correlatio n Annual 

Average Weighted Correlatio n Curve Emissions 

SOCMI SOCMI Curve (EPA) (BD Panel) (tons/yr) 3 

362.3238 0 216.3834 8 84.0840 4 72.9620 8 303.595 2 

77.6745 0 46.7262 2 7.20438 6.97941 29.041 3 

98.0548 0 55.6199 8 12.84235 12.8229 9 53.356 5 

0.1480 0 0.0987 9 0.1062 9 0.1055 9 0.439 4 

40.9464 0 26.2643 9 21.19601 21.1832 8 88.143 6 

6.4528 0 4.38391 0.30793 0.2089 0 0.869 i 

20.9132 4 12.7566 9 2.93540 3.50987 60.462 9 

8.5374 0 2.38545 0.00043 0.0000 6 0.000 3 

BD Panel Tota l Estimated Annual Emissions (Tons/yr ) 535.9084 s 

assune s tha t the number of flange s = 1.6 time s the number of valves, 

facto r of 95X. 

SUMMER 1988. 
P.76 

Note that the last column shows the estimated emissions in tons per 

year for each component, assuming 24 hour a day operation, 365 days a year, 

running 95% of the time. An additional assumption was made for flanges, only 

a percentage of which were tested in this study. For the industry, a flange 

scale-up factor of 4.14 was applied to the data. This factor was determined 

by assuming that the number of flanges was equal to 1.6 (Ref 1) times the 

total number of valves (liquid service plus gas service) in the plants and by 

determining the ratio of the total number of flanges to the number of measured 

flanges. Individual summary estimates (similar to Table 5-7) for each of the 

plants appear in Appendix 3. Where data were available for individual plants, 

actual flange counts were used to determine the scale up factor. 

The data in Tables 5-6 and 5-7 show the average or mean OVA 

screening value for each component type in this study. Table 5-8 compares 

these values with the corresponding average values from the previous EPA 

fugitive emissions studies. The average SOCMI values were calculated using 

the correlation equations presented in Table 4-2. 

For all component types except sample points, which were treated the 

same as open-ended lines, a reduction in mean screening values was seen in 

this study. Since virtually all screening tests of sample points were 

performed when the sample points were not in use for sampling, they 

corresponded more closely to uncapped open-ended lines than to the "in use" 

sample points of previous EPA studies. 

For those components for which screening value reductions were 

recorded, the reductions ranged from 17.9% for open-ended lines to 99.9+% for 

compressors. The principal reasons for these reduced emissions are probably 

improved plant design criteria, operations, and maintenance programs. Section 

6 of this report discusses other possible explanations for these reductions. 

5-19 
P.77 

TABLE 5-8. COMPARISON OF OVA SCREENING VALUES FROM THE BD PANEL STUDY WITH 

THOSE ESTIMATED FROM SOCMI FACTORS 

Component Type 

SOCMI3 

(ppm) 

BD Panel 

(ppm) 

Reduction 

(%) 

Valve (Liquid) 

Valve (Gas) 

Sample Point 

Safety Valve 

Pump 

Open-Ended Line 

Flange 

Compressor 

2815 

13650 

525 

51900 

22700 

525 

115 

124500 

1507 

1109 

2416 

1035 

2841 

431 

60 

4 

46.5 

91.9 

-360.2 

98.0 

87.5 

17.9 

47.8 

99.9+ 

a SOCMI screening values derived from the correlation equation given 

in Section 4. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-20 
P.78 

The relation between fugitive emissions and BD concentration was 

explored by determining mean emission factors for each component type in each 

of three BD percentage ranges. The first range included components containing 

5% to <30% BD, which covers all of the production and the beginnings of the 

purification stages. The second range included all components with 30% to 

<90% BD, which covers all purification stages of the production process. The 

third range included components containing 90% or more BD, which covers all 

pure BD services lines. Mean emission factors and total emissions of 

components in these three ranges are shown in Tables 5-9, 5-10, and 5-11. 

For most components, the effect of increasing the BD concentration 

is clearly a noticeable increase in BD emissions. An increase in the average 

emission factor is found for virtually every component type when the BD 

concentration increases from 5% to 30% to 30%-90%. For every component except 

valves in gas service and sample points, increased emission factors are found 

when the BD concentration increases from 30% to 90% to >90%. The mean emission 

factor for components in the 5%-30% BD range is about 8 times higher than the 

mean emission factor for components in the >90% BD range. 

5.3 Emissions By Component Type and Service Category 

Fugitive emissions in the chemical industry are considered to be 

volatile organic compounds (VOC) emissions that result when process fluids 

(either liquid or gas) leak from plant equipment. Seven types of components 

were included in this study: valves, pumps, flanges, open-ended lines, safety 

valves, sample points, and compressors. Valves were further separated into 

valves in liquid service and valves in gas service. This section presents the 

data for each of these eight categories. 

5.3.1 Valves in Liquid Service 

There were 23,233 valves in liquid service included in this study, 

representing 53.31% of all components tested. 

5-21 
TABLE 5-9. SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR ALL PARTICIPATING PLANTS: 

EMISSION ESTIMATES FOR COMPONENTS WITH BD CONCENTRATIONS BETWEEN 5% AND 30% 

Component Type 

Valve (liquid) 

Valve (gas) 

Safety Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Components 

5163 

1728 

99 

8 

73 

211 

1700 

14 

Mean Raw 

Screen 

Value (p 

1236 

682 

2031 

172 

2127 

604 

36 

2 

OVA 

pm) 

Mean BD 

Amount (Z) 

14.3 

14.0 

12.5 

16.5 

13.9 

23.0 

16.4 

19.6 

Mean 

Average 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

.502200 

Emission Factors 

Weighted 

SOCMI 

.002231 

.001719 

.028561 

.000611 

.015136 

.000852 

.000299 

.098646 

(All Value6 in 

Correlation 

Curve (EPA) 

.000701 

.000146 

.005661 

.000536 

.005754 

.000122 

.000064 

.000018 

lb/hr/ 

Cor 

source) 

relation Curve 

(BD Panel) 

.000608 

.000138 

.005653 

.000531 

.005747 

.000105 

.000206 

.000004 

5-2 NJ 

Component Type 

Valve (liquid) 

Valve (gas) 

Safety Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Number of 

Components 

5163 

1728 

99 

8 

73 

211 

1700 

14 

Mean Raw OVA 

Screen 

Value (ppm) 

1236 

682 

2031 

172 

2127 

604 

36 

2 

Mean BD 

Amount (Z) 

14.3 

14.0 

12.5 

16.5 

13.9 

23.0 

16.4 

19.6 

Total 

Average SOCMI 

80.54280 

21.25440 

22.68090 

0.02960 

7.94980 

0.78070 

3.11100 

7.03080 

We 

BD 

Emissions (All 

ighted SOCMI 

11.52096 

2.96999 

2.82755 

0.00488 

1.10490 

0.17967 

0.50891 

1.38105 

Panel Total 

Values in lb/h 

Correlation 

Curve (EPA) 

3.62006 

0.25281 

0.56048 

0.00429 

0.42001 

0.02577 

0.10864 

0.00025 

Estimated Annual 

r) 

Correlation Curve 

(BD Panel) 

3.14071 

0.23922 

0.55969 

0.00424 

0.41955 

0.02185 

0.10052 

0.00003 

Emissions (Tons/Ye 

BD Panel 

Estimated Annual 

Emissions 

(Ton 6/Year) 

13.0685 

0.9954 

2.3289 

0.0177 

1.7457 

0.0923 

9.4772 

0.0002 

ar) 27.7259° 

Total annual emissions based on a stream factor of 95Z. 

Flange emissions multiplied by 6.49 which assumes that the number of flanges = 1.6 time6 the number of valves. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 
I 

Nu 

Cu 

Tu^BLE 5-10. SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR ALL PLANTS: 

EMISSION ESTIMATES FOR COMPONENTS WITH BD CONCENTRATIONS BETWEEN 

30% AND 90% 

Component Type 

Valve (liquid ) 

Valve (gas) 

Safet y Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Components 

10373 

2141 

206 

11 

152 

1046 

6340 

3 

Mean Raw 

Screen 

OVA 

Value (ppm) 

1807 

1939 

82 

8393 

4387 

482 

13 

13 

Mean BD 

Amount (Z) 

54. 9 

55. 1 

54. 2 

47. 2 

55. 5 

66. 6 

54. 7 

66. 7 

Mean 

Average 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

.502200 

Emission Factors 

Weighted 

SOCMI 

.008561 

.006776 

.124092 

.001746 

.060446 

.002464 

.001001 

.334800 

(All Value s in 

Correlatio n 

Ci rve (EPA) 

.00355 0 

.001638 

.008253 

.003872 

.06373 2 

.00015 0 

.000186 

.000059 

lb/ h 

C 

r/source ) 

correlation Curve 

(BD Panel) 

.003101 

.001605 

.00821 0 . 

.00386 3 

.063701 

.00009 4 

.00024 8 

.00000 2 

Component Type 

Valve (liquid ) 

Valve (gas) 

Safet y Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Number of 

Components 

10373 

2141 

206 

11 

152 

1046 

6340 

3 

Mean Raw OVA 

Screen 

Value (ppm) 

1807 

1939 

82 

8393 

4387 

482 

13 

13 

Mean BD 

Amount (Z) 

54. 9 

55. 1 

54. 2 

47. 2 

55. 5 

66. 6 

54. 7 

66. 7 

Tota l 

Average SOCMI 

161.81880 

26.3343 0 

47.1946 0 

.04070 

16.5528 0 

3.8702 0 

11.6022 0 

1.50660 

Emissions (All 

Weighted SOCMI 

88.8020 5 

14.5079 9 

25.5629 8 

0.0192 0 

9.1877 8 

2.57698 

6.34934 

1.00440 

BD Panel 

Value s in lb/hr ) 

Correlatio n 

Curve (EPA) 

36.8265 3 

3.50657 

1.70003 

0.0425 9 

9.6872 8 

0.1566 0 

1.17861 

0.0001 8 

Estimated Annual 

Correlatio n Curve 

(BD Panel) 

32.1639 0 

3.4372 1 

1.69133 

0.0424 9 

9.6825 7 

0.0982 5 

1.57541 

0.0000 1 

Emissions (Tons 

BD Panel 

Estimated Annual 

Emissions 

(Tons/Year) 

133.834 0 

14.302 2 

7.037 6 

0.176 8 

40.289 2 

0.4088 . 

20.7147 

0.000 0 

/Year ) 216.7634 8 

Total annual emission s based on a stream facto r of 95Z. 

Flange emission s multiplie d by 3.1 6 which assumes that the number of flange s = 1.6 time6 the nimiber of valveB. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

00 
TABLE 5-11. SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR ALL PLANTS: 

EMISSION ESTIMATES FOR COMPONENTS WITH BD CONCENTRATIONS BETWEEN 90% 

AND 100% 

Component Type 

Valve (liquid ) 

Valve (gas) 

Safet y Valve 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Components 

7697 

2446 

123 

21 

151 

487 

3 388 

Mean Raw 

Screen 

OVA 

Value (ppm) 

1285 

684 

1829 

139 

1630 

248 

160 

Mean BD 

Amoun t (Z) 

96. 7 

97. 2 

96. 6 

96. 1 

97. 3 

90. 3 

95. 1 

Mean 

Average 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

Emission Factor s 

Weighted 

SOCMI 

.015079 

.011958 

.221378 

.003557 

.105773 

.003341 

.001741 

(All 

Cc 

Ct 

Value s in 

rrelatio n 

rve (EPA) 

.005669 

.00140 8 

.086031 

.00282 9 

.073435 

.00025 8 

.00048 6 

lb/hr / source ) 

Correlatio n Curve 

(BD Panel) 

.004892 

.00135 0 

.085951 

.00280 3 

.073385 

.00018 2 

.000467 

U i 

1 

4> 

Component Type 

Valv e (liquid ) 

Valv e (gas ) 

Safet y Valv e 

Sample Point 

Pump 

Open-Ended Lin e 

Flange 

Number of 

Component 6 

7697 

2446 

123 

21 

151 

487 

3388 

Mean Raw OVA 

Screen 

Valu e (ppm) 

1285 

684 

1829 

139 

1630 

248 

160 

Mean BD 

Amount (Z) 

96. 7 

97. 2 

96. 6 

96. 1 

97. 3 

90. 3 

95. 1 

Tot 

Average SOCMI 

120.0732 0 

30.0858 0 

28.1793 0 

0.0777 0 

16.4439 0 

1.8019 0 

6.2000 4 

a l Emissions (Al l 

Weighted SOCMI 

116.0604 7 

29.2482 4 

27.2294 5 

0.0747 0 

15.9717 1 

1.6272 6 

5.8984 5 

Value s i n lb/ h 

Correlatio n 

Curve (EPA) 

43.6374 5 

3.4450 0 

10.5818 4 

0.0594 1 

11.0887 2 

0.1255 6 

1.6481 4 

r ) 

Correlatio n Curv e 

(BD Panel ) 

37.6574 7 

3.3029 8 

10.5719 7 

0.0588 6 

11.0811 5 

0.0884 7 

1.5835 2 

BD Panel Estimate d Annual Emissions (Tons/Year) 

BD Pane l 

Estimate d Annua l 

Emissions 

(Tons/Year) 

156.692 8 

13.743 7 

43.990 0 

0.244 9 

46.108 7 

0.368 1 

31.561 3 

292.7095 8 

Total annual emission s based on a stream facto r of 95Z. 

Flange emission s multiplie d by 4.7 9 which assumes that the number of flange s = 1.6 time s the nmbe r of valves. 

SOURCE:' BD PANE1 FUGITIVE EMISSIONS STUDY. SUMMER 1988. 

00 
P.82 

5.3.1.1 Screening Measurements 

The distribution of raw OVA screening values for valves in liquid 

service for each of the BD percentage ranges is shown in Table 5-12 and 

illustrated in Figure 5-2. • The range of 0 to 9 ppm represents non-emitting 

components, while components with screening values >9999 ppm are considered to 

be leakers. Components with screening values between 1000 ppm and 9999 ppm 

are referred to as high emitters; those with screening values between 100 and 

999 ppm are low emitters; and those components with screening values between 

10 and 99 ppm are very low emitters. 

For valves in liquid service, there were 546 or 2.35% in the leaker 

category, u^n additional 571 or 2.61% were in the high emitter category. More 

than 95% of the valves in liquid service were in the low emitter, very low 

emitter, or non-emitting category. For this component type and service 

category, the percentage of leakers is not strongly affected by BD 

concentration. The percentage of components that are low and high emitters, 

decreases as the amount of BD increases. 

As previously shown in Table 1-3,. the original SOCMI database 

included 6.5% leaking liquid service valves. The level found in this study 

was 2.35%, which represents a reduction of 63.8%. 

5.3.1.2 Emission Estimates 

Table 5-13 shows the distribution of emission factors and total 

emissions for all valves in liquid service for each BD concentration range. 

The increase in emissions with increaseing BD concentration is evident. The 

reduction in emission factors between the average SOCMI method and the BD 

Panel decreases as the BD concentration rises. The mean BD Panel emission 

factor estimate for all valves in liquid service was 0.003140 lb/hr/source 

(see Table 5-7), which is a reduction of 79.9% from the average SOCMI emission 

factor estimate. 

5-25 
P.83 

TABLE 5-12. 

Butadiene 

DISTRIBUTION OF RAW 

FOR VALVES IN LIQUID 

Number < 

Concentration 0-9 ppm 

5% t o 30% 

30% t o 90% 

90% t o 100% 

TOTAL 

Butadiene 

3109 

7612 

5014 

15735 

DVA SCREEN 11 

SERVICE 

TO VALUES BY 

af Components in Screening

 1 

10 t o 

99 ppm 

1551 

2041 

2183 

5775 

Percentage of 

Concentration 0-9 ppm 

5% t o 30% 

30% t o 90% 

90% to 100% 

60.22 

73.38 

65.14 

Weighted Average 67.73 

10 

99 

30 

19 

28 

24 

100 t o 

999 ppm 

218 

203 

185 

606 

Components : 

to 

ppm 

.04 

.68 

.36 

.86 

100 

999 

4 

1 

2 

2 

1000 

9999 

m S 

t o 

ppm 

22 

96 

.40 

61 

183 

241 

147 

571 

7alue 

to 

ppm 

creening 

BD CONCENTRATION 

> Range 

>9999 ppm 

Val 

1000 t o 

102 

276 

168 

546 

ue Range 

9999 ppm 

3. 

2. 

1. 

2. 

54 

32 

91 

46 

. 

>9999 

1. 

2. 

2. 

2. 

98 

66 

18 

35 

TOTAL 

5163 

10373 

7697 

23233 

ppm 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-26 
P.84 

67.73% 

^Ntaki^iti V "— 2.35% 

" - : : -^S? » "2.46% 

*.-:'.'•:-:'::/ 2.61% 

' 24.86% 

...... 

!•&&$ & 

*y.'-::•:• 

< 10 ppm 

10 • 99 ppm 

100 • 999 ppm 

1000 • 9999 ppm 

> 9999 ppm 

Figure 5-2. Distribution of Raw OVA Screening Values for Valves in Liquid 

Service 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988, 

5-27 
TABLE 5-13. DLSTRIBUTUION OF EMISSIONS BY BUTADIENE CONCENTRATION FOR ALL PLANTS: 

EMISSION ESTIMATES FOR VALVES IN LIQUID SERVICE 

Butadiene 

Concentration 

5% t o 30Z 

30Z t o 90Z 

90Z t o 100Z 

Number of 

Components 

5163 

10373 

7697 

Mean Raw 

OVA Screen 

Value 

(ppm) 

1236 

1807 

1285 

Mean BD 

Amount 

(X) 

14. 2 

57. 5 

96. 6 

Mean 

Average 

SOCMI 

.015600 

.015600 

. .015600 

Em issio n Factor s 

Weighted 

SOCHI 

.002231 

.008561 

.015079 

(All Values in 

Correlatio n 

Curve (EPA) 

.000701 

.003550 

.005669 

lb/hr/source ) 

Correlatio n Curve 

BD Panel 

.00060 8 

.003101 

.00489 2 

t_n 

I 

NJ 

OO 

Butadiene 

Concent rat ion 

5% t o 30Z 

30% t o 90% 

90% t o 100% 

Number of 

Component s 

5163 

10373 

7697 

Me 

OVA 

Val 

an Raw 

Screen 

ue (ppm) 

1236 

1807 

1285 

Mean BD 

Amount 

(%) 

14.2 

57. 5 

96. 6 

Tot 

Average 

SOCMI 

80.54280 

161.81880 

120.07320 

BD Panel 

al Emissions 

Weighted 

SOCMI 

11.52096 

88.80205 

116.06047 

(All Value s In 

Correlatio n 

Curve (EPA) 

3.62006 

36.8265 3 

43.6374 5 

lb/hr ) 

Correlatio n 

Curve 

(BD Panel) 

3.14071 

32.1639 0 

37.65747 

Total Estimated Annual Emissions (Tons/yr ) 

BD Panel 8 

Annual 

Emissions 

(tons/yr) -

13.068 5 

133.834 0 

156.692 8 

303.5952 ° 

Total annual emissions based on a stream factor of 95%. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1968. 
P.86 

5.3.1.3 Plant-Specific Analyses 

Table 5-14 presents separate emission factors developed for each of 

the 13 plants participating in this study. The BD Panel estimated emission 

factors vary from 0.000474 lb/hr/source to 0.005700 lb/hr/source. This 

represents a ratio of 12.03. Overall, the variability among plants is 

reflected by a relative standard deviation of 45.2%. In general, the data do 

not indicate a widespread variation in emissions between plants. 

5.3.1.4 Summary 

Overall, the following conclusions can be drawn about the 23,233 

valves in liquid service included in this study: 

• The percentage of leaking components found in this study is 

about 1/3 that found in the SOCMI study. 

• The amount of BD emitted from a component is a function of the 

concentration of BD in the component; 

• Estimated emission factors vary little from plant to plant; and 

• Present data show that the emission factor estimated in the 

present study are about 80% lower than seen in the SOCMI study. 

5.3.2 Valves in Gas Service 

There were 6315 valves in gas service included in this study, 

representing 14.49% of all components. 

5-29 
P.87 

TABLE 5-14 . EMISSION FACTORS FOR VALVES IN LIQUID SERVICE FOR EACH PLANT 

Plant 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

Relative Std. 

Mean Emission 

Average 

SOCMI 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

Dev. 

Factors Using 

Weighted 

SOCMI 

0.008456 

0.006884 

0.011021 

0.010938 

0.009174 

0.009678 

0.011630 

0.003827 

0.004588 

0.006493 

0.005990 

0.010820 

0.009880 

39.1% 

the Method Listed 

CORR Curve 

(EPA) 

0.003608 

0.003353 

0.003723 

0.002086 

0.004211 

0.002151 

0.005359 

0.001053 

0.005896 

0.003697 

0.000779 

0.003538 

0.003852 

45.3% 

(lb/hr/source) 

CORR Curve 

(BD Panel) 

0.003350 

0.002990 

0.003260 

0.002086 

0.003826 

0.002116 

0.004688 

0.000859 

0.005700 

0.003362 

0.000474 

0.002903 

0.003264 

45.2% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-30 
P.88 

5.3.2.1 Screening Measurements 

The distribution of raw OVA screening measurements for valves in gas 

service for each of the BD concentration ranges is shown in Table 5-15 and 

illustrate d in Figure 5-3. There were 110 or 1.74% leaking components of this 

type. About 2% (127 valves) were in the category of high-emitters. Almost 

96% of the gas service valves were in the low-emitter, very-low-emitter or 

non-emitter categories. The number of leaking valves in gas service does not 

appear to be strongly related to BD concentration. However, the number of 

valves in gas service in the high-emitter and low-emitter categories appears 

to be related to the amount of BD in the component. 

As previously shown (Table 1-3), the original SOCMI database 

included 11.4% leaking gas service valves. The 1.74% of leaking components 

found in this study represents a reduction by 84.7% from the historica l level. 

5.3.2.2 Emission Estimates 

Table 5-16 shows the distribution of emission factors and tota l 

emissions for all valves in gas service for each BD concentration range. The 

average emission factors increase tenfold from the 5%-30% BD concentration 

range to the 30%-90% BD concentration range. However, at the >90% BD range, a 

decrease in the estimated mean emission factor is observed. The mean BD Panel 

emission factor for all valves in gas service was 0.001105 lb/hr/source (see 

Table 5-7), which is a reduction of 91.02% from the average SOCMI emission 

factor. 

5.3.2.3 Plant-Specific Analyses 

Table 5-17 present the separate emission factor estimates developed 

for each of the 13 participating plants. The BD Panel estimated emission 

factors vary from 0.004526 lb/hr/source to 0.000014 lb/hr/source. Overall, 

the relative standard deviation for these data is 84.3%, suggesting a high 

degree of variability among plants. 

5-31 
P.89 

TABLE 5-15. DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION FOR 

VALVES IN GAS SERVICE 

Butadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

TOTAL 

, 

Butadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

Number 

0-9 ppm 

1059 

1345 

1856 

4260 

of Concentration 

10 to 

99 ppm 

532 

627 

485 

1644 

Percentage of 

0-9 ppm 

61.28 

62.82 

75.88 

Weighted Average 67.46 

in 

100 to 

999 ppm 

69 

57 

48 

174 

Screening Value Range 

1000 

9999 

Concentration 

10 to 

99 ] 

30 

29 

19 

26 

3pm 

.79 

.29 

.83 

.03 

100 

999 

3 

2. 

1 

2 

to 

ppm 

99 

66 

96 

76 

49 

52 

26 

127 

in S 

to 

ppm >9999 

19 

60 

31 

110 

creening Val 

100C 

9999 

2. 

2. 

1. 

2. 

to 

ppm 

84 

43 

06 

01 

ppm TOTAL 

1728 

2141 

2446 

6315 

ue Range 

>9999 ppm 

1.10 

2.80 

1.27 

1.74 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-32 
P.90 

67.461 

26.03* 

< 10 ppm 

10 • 99 ppm 

v{&*-^*i l 100-999 ppm 

^H^^ H 1000-9999 ppm 

[ *..V-%»| > " " PPm 

Figure 5-3. Distribution of Raw OVA Screening Values for Valves 

in Gas Service. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-33 
TABLE 5-16. DISTRIBUTION OF EMISSIONS BY BUTADIENE CONCENTRATION FOR ALL PLANTS: 

EMISSION ESTIMATES FOR VALVE IN GAS SERVICE 

Butadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

Number of 

Components 

1728 

2141 

2446 

Mean Raw 

OVA Screen 

Value 

(ppm) 

682 

1939 

684 

Mean BD 

Amount 

(%) 

14.0 

55.1 

97.2 

Mean Em 

Average 

SOCMI 

.001230 

.001230 

.001230 

ission Factors 

Weighted 

SOCMI 

.001719 

.006779 

.011958 

(All Values in lb/hr/source) 

Correlation 

Curve (EPA) 

.000146 

.001638 

.001408 

Correlation Curv 

(BD Panel) 

.000138 

.001605 

.001350 

Ul 

I 

•cButadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

Number of 

Components 

1728 

2141 

2446 

Mean Raw 

OVA Screen 

Value (ppm) 

682 

1939 

684 

Mean BD 

Amount 

(%) 

14.0 

55.1 

97.2 

Tot 

Average 

SOCMI 

21.25440 

26.33430 

30.08580 

BD Panel 

al Emissions 

Weighted 

SOCMI 

2.96999 

14.50799 

29.24824 

(All Values In 

Correlation 

Curve (EPA) 

0.25281 

3.50657 

3.44500 

lb/hr) 

Correlation 

Curve 

(BD Panel) 

0.23922 

3.43721 

3.30298 

Total Estimated Annual Emissions (Tons/yr) 

...••••-...-..—i . • • . • •.— . . . — . . . * — - • • - -.— — 

BD Panel8 

Annual 

Emissions 

(tons/yr) 

0.9954 

14.3022 

13.7437 

29.0413° 

Total annual emissions based on a 6tream factor of 95%. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 

*• 

co 
P.92 

TABLE 5-17. EMISSION FACTORS FOR VALVES IN GAS SERVICE FOR EACH PLANT 

Plant 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

Mean Emission 

Average 

SOCMI 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

Relativ e Std.Dev. 

Factors Using 

Weighted 

SOCMI 

0.008258 

0.004265 

0.008533 

0.009456 

0.008838 

0.008045 

0.007633 

0.002904 

0.005430 

0.004999 

0.005258 

0.007575 

0.007739 

28.4% 

the Method Listed 

CORR Curve 

(EPA) 

0.001696 

0.000855 

0.001029 

0.001029 

0.000994 

0.000488 

0.000902 

0.002167 

0.004547 

0.003703 

0.000040 

0.000994 

0.000987 

82.5% 

(lb/hr/source ) 

CORR Curve 

(BD Panel) 

0.001665 

0.000837 

0.000991 

0.001029 

0.000952 

0.000455 

0.000860 

0.002156 

0.004526 

0.003678 

0.000014 

0.000954 

0.000943 

84.3% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-35 
P.93 

5.3.2.4 Summary 

Based on data from the 6315 valves in gas service included in this 

study, the following overall conclusions can be drawn: 

• The amount of BD emitted from a gas service valve usually 

varies with the BD concentration in the valve; 

• The variability in emission factors* among plants is higher than 

for valves in liquid service but is still relatively low; and 

• Current data show that the emission factor estimated in the 

present study for valves in gas service is about 91% times 

lower than the average SOCMI emission factor estimate. 

• The percentage of leaking valves in gas service is 85% lower 

than seen in the SOCMI study. 

5.3.3 Flanges 

There were 11,428 flanges included in this study, which amounts to 

about 26% of the total components studied. The protocol required that only a 

small percentage of the flanges in each plant be tested. The formula used for 

determining the minimun number of flanges to be tested was: 

n = N(l-0.05)**(50/n) 

where: N =.total number of flanges in the tested area; and 

n = the number of flanges to be tested. 

As the total number of flanges present in the area increases, this series 

converges to a maximum of about 150 flanges to be tested. For the purposes of 

estimating total plant-wide emissions, the number of flanges in a plant was 

assumed to be 1.6 times (Ref 1) the number of valves (liquid and gas service) 

5-36 
P.94 

when the actual number of flanges was not known. Where the number of flanges 

was knVown, the actual number was used. 

5.3.3.1 Screening Measurements 

Table 5-18 and Figure 5-4 show the distribution of raw OVA screening 

values for flanges for each of the BD ranges. The number of leaking flanges 

was only 13, or 0.11%. This represents a reduction of 94.8% from the 2.1% 

leakers found during the SOCMI study. High emitters constituted another 22, 

or 0.19%. Non-emitters, very low emitters, and low emitters constituted 99.8% 

of all flanges. The relation between the number of flanges in an OVA range 

and the amount of BD present is not clear. 

5.3.3.2 Emission Estimates 

Table 5-19 shows the distribution of mean emission factors and total 

emissions for flanges. The data in Table 5-19 show that the mean emission 

factor for flanges is influenced by the concentration of BD in the flange 

since the mean rate varies from 0.000206 lb/hr/source in the 5%-30% BD 

concentration range to 0.000248 lb/hr/source for the 30%-90% BD concentration 

range to 0.000467 lb/hr/source for the flanges containing >90% BD. The BD 

Panel estimated mean emission factor for all flanges was 0.000307 lb/hr/source 

(see Table 5-7), which is 83.22% lower than the average SOCMI emission factor. 

The estimated annual emissions are determined by multiplying the raw data by 

a factor of 4.14 to account for the ratio of existing to tested flanges, 

assuming that there are 1.6 times as many flanges as valves (liquid and gas 

service) (Ref. 1). 

5.3.3.3 Plant-Specific Analyses 

The estimated emission factors for flanges in each participating 

plant are shown in Table 5-20. The BD Panel emission factors vary from 

0.000179 lb/hr/source to 0.001901 lb/hr/source, which corresponds to a ratio 

of 10.6. The data also show widespread variability in the mean emission 

factor for flanges among the plants. 

5-37 
P.95 

TABLE 5-18. DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD CONCENTRATION FOR 

FLANGES 

Butadiene 

Concentration 

5% TO 30% 

30% TO 90% 

90% TO 100% 

TOTAL 

Number 

0-9 ppm 

1472 

5993 

3221 

10686 

of Concentration in 

10 to 

99 ppm 

213 

314 

145 

672 

100 to 

999 ppm 

6 

18 

11 

35 

Screening Val 

1000 to 

9999 ppm 

7 

11 

4 

22 

ue Range 

>9999 ppm 

2 

4 

7 

13 

TOTAL 

1700 

6340 

3388 

11428 

Bi itadiene 

Concent 

5% 

30% 

90% 

TO 

TO 

TO 

ration 

30% 

90% 

100% 

WEIGHTED AVERAGE 

Percenta 

0-9 

86 

94. 

95 

93 

ppm 

59 

53 

07 

51 

ge of Concentration in 

10 

99 

12 

4 

4 

5 

to 

ppm 

53 

95 

.28 

88 

100 

999 

0. 

0. 

0. 

0. 

to 

ppm 

35 

28 

32 

31 

Screening Value 

1000 

9999 

0. 

0. 

0. 

0. 

to 

ppm 

41 

17 

12 

19 

Range 

>9999 ppm 

0. 

0. 

0. 

0. 

12 

06 

21 

11 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 

5-38 
P.96 

.19 % 

< 10 ppm 

10 - 99 ppm 

100 - 999 ppm 

1000-9999 ppm 

1

» . v . » 

K ' \ ; '»'»'' > 9999 ppm 

93.5U 

Figure 5-4. Distribution of Raw OVA screening Values for Flanges 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-39 
Ul 

I 

•po 

TABLE 5-19 . DISTRIBUTION OF EMISSIONS BY BUTADIENE CONCENTRATION FOR ALL PLANTS: 

EMISSION ESTIMATES FOR FLANGES 

Butadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

Number of 

Components 

1700 

6340 

3388 

Mean Raw 

OVA Screen 

Value 

(PP») 

36 

13 

160 

Mean BD 

Amount 

(%) 

16.4 

54.7 

95.1 

Mean Em 

Average 

SOCMI 

.001830 

.001830 

.001830 

ission Factors 

Weighted 

SOCMI 

.000299 

.001001 

.001741 

(All Values in lb/hr/source) 

Correlation 

Curve (EPA) 

.000064 

.000186 

.000486 

Correlation Curv 

(BD Panel) 

.000206 

.000248 

.000467 

Butadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

Number of 

Components 

1700 

6340 

3388 

Mean Raw 

OVA Screen 

Value (ppm) 

36 

13 

160 

Mean BD 

Amount 

(%) 

16.4 

54.7 

95.1 

Total 

Average 

SOCMI 

3.11100 

11.60220 

6.20004 

BD Panel 

Emissions 

Weighted 

SOCMI 

.50891 

6.34934 

5.89845 

(All Values In 

Correlation 

Curve (EPA) 

.10864 

1.17861 

1.64814 

lb/hr) 

Correlation 

Curve 

(BD Panel) 

.35094 

1.57541 

1.58352 

Total Estimated Annual Emissions (Tons/yr) 

BD Panel8 

Annual 

Emissions 

(tons/yr) 

6.0455^ 

27.13897 

27.2785 

60.4629* 

All emission values multiplied by 4.14 which assumes that the number of flanges = 1.6 times the number of valves. 

Total annual emissions based on a stream factor of 95% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 
P.98 

TABLE 5-20 . EMISSION FACTORS FOR FLANGES FOR EACH PLANT 

Plant 

Number 

1 

2 

3 

4 

5 

7 

8 

9 

10 

11 

12 

13 

Relative Std. 

Mean Emission 

Average 

SOCMI 

0.001830 

0.001830 

0.001830 

0.001830 

0.001830 

0.001830 

0.001830 

0.001830 

0.001830 

0.001830 

0.001830 

0.001830 

Dev. 

Factors Using 

Weighted 

SOCMI 

0.000949 

0.000973 

0.001254 

0.001059 

0.000979 

0.001264 

0.000555 

0.000604 

0.000793 

0.000468 

0.001232 

0.001106 

29.5% 

the Method Listed 

CORR Curve 

(EPA) 

0.001841 

0.000416 

0.000563 

0.001093 

0.001057 

0.000211 

0.000154 

0.000226 

0.000261 

0.000055 

0.000141 

0.000191 

104.7% 

(lb/hr/source) 

CORR Curve 

(BD Panel) 

0.001901 

0.000467 

0.000594 

0.001135 

0.001117 

0.000239 

0.000268 

0.000327 

0.000346 

0.000179 

0.000179 

0.000244 

91.4% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-41 
P.99 

5.3.3.4 Summary 

Based on the 11,428 flanges reported in this study, the following 

conclusions can be drawn: 

• The rate of BD leakage from flanges depends on the 

concentration of BD in the flange; 

• The percentage of leaking and high-emitting flanges is much 

smaller than the corresponding percentage of leaking and highemitting valves; 

• Mean emission factors vary considerably among plants; and 

• Current data show that the emission factor for flanges 

estimated in the present study is about 83% lower than that 

estimated by the SOCMI study. 

5.3.4 Open-Ended Lines 

There were 1,744 open-ended lines included in this study, 

corresponding to 4.0% of all components tested. The BD panel sampling 

protocol specifically excluded testing open-ended lines that were capped or 

blind flanged. 

5.3.4.1 Screening Measurements 

The distribution of raw OVA screening values for open-ended lines as 

a function of BD composition is shown in Table 5-21 and illustrated in Figure 

5-5. Eleven (0.63%) of these were leakers, while 5 (0.29%) were high 

emitters. More than 99% of the open-ended lines were either non-leakers, very 

low emitters, or low emitters. The effects of BD concentration on screening 

values is not clear. The 0.63% leakers represents a reduction of 83.8% from 

the 3.9% leaking open-ended lines found during the SOCMI study. 

5-42 
P.1 

TABLE 5-21 . DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD CONCENTRATION FOR 

OPEN-ENDED LINES 

Butadiene 

Concentration 

5% TO 30% 

30% TO 90% 

90% TO 100% 

TOTAL 

Number 

0-9 ppm 

194 

1027 

471 

1692 

of Components in Screening Value 

10 to 

99 ppm 

8 

11 

12 

31 

100 to 

999 ppm 

3 

1 

1 

5 

1000 to 

9999 ppm 

3 

2 

0 

5 

Range 

>9999 

3 

5 

3 

11 

ppm TOTAL 

211 

1046 

487 

1744 

Butadiene 

Concentration 

Percentage of Components in Screening Value Range 

0-9 ppm 

10 to 

99 ppm 

100 to 

999 ppm 

1000 to 

9999 ppm >9999 ppm 

5% TO 30% 

30% TO 90% 

90% TO 100% 

91.94 

98.18 

96.71 

3.79 

1.05 

2.46 

1.42 

0.10 

0.21 

1.42 

0.19 

0.00 

1.42 

0.48 

0.62 

Weighted Average 97.02 1.78 0.29 0.29 0.63 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-43 
P.2 

\ 

. _ .L„. •63•^^ 

&fcitai^—.29% 

-^-v-x-r-j "*"••*•. 2 9% 

^ ^ y "^^*" 1.78% 

B B ^ 

< 10 ppm 

10-99 ppm 

100-999 ppm 

1000-9999 ppm 

> 9999 ppffl 

97.02% 

Figure 5-5. Distribution of Raw OVA Screening Vlaues for Open-Ended Lines 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 

5-44 
P.3 

5.3.4.2 Emission Estimates 

Table 5-22 presents mean emission factors and total emissions for 

open-ended lines for each BD percentage range. While a discernible trend is 

indicated, the variation of emission factors with BD concentration is not 

clear. The overall mean emission factor for all open-ended lines was 0.000120 

lb/hr/source (see Table 5-7), which is 96.76% times lower than the average 

SOCMI emission factor. 

5.3.4.3 Plant-Specific Analyses 

Table 5-23 shows the separate emission factors developed for openended lines for each plant. Note that seven (more than half) of the plants 

did not report any data for open-ended lines. While most plants gave no 

explicit explanation, some indicated that company policy required that all 

open-ended lines be capped or otherwise plugged when not in use. Capped or 

plugged open-ended lines were specifically exempted from the screening 

protocol. 

The data for open-ended lines varied considerably. The mean 

emission factor varied from 0.000002 lb/hr/source to 0.004341 lb/hr/source. 

Such wide variability is also shown by the 118% relative standard deviation in 

these data. 

5.3.4.4 Summary 

• The relation between the number of components in a given 

screening value range and BD concentration is not clear; 

• The relation between mean emission factors and BD concentration 

is not clear; 

• The percentage of leaking and high-emitting open-ended lines is 

very small compared with valves; 

5-45 
TABLE 5-22. DISTRIBUTION OF EMISSIONS BY BUTADIENE CONCENTRATION FOR ALL PARTICIPATING PLANTS: 

EMISSION ESTIMATES FOR OPEN ENDED LINES 

Butadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

Number of 

Components 

211 

1046 

487 

Mean Raw 

OVA Screen 

Value 

(ppm) 

604 

482 

248 

Hean BD 

Amount 

(%) 

23.0 

66.6 

90.3 

Mean Em 

Average 

SOCMI 

.003700 

.003700 

. .001700 

ission Factors 

Weighted 

SOCHI 

.000852 

.002464 

.003341 

(All Values in lb/hr/ 

Correlation 

Curve (EPA) 

.000122 

.000150 

.000258 

Co 

source) 

rrelation Curv 

(BD Panel) 

.000105 

.000094 

.000182 

Ul 

I 

.po*> Butadiene 

Concent rat ion 

5% to 30% 

30% to 90% 

90% to 100% 

Number of 

Components 

211 

1046 

487 

Mean Raw 

OVA Screen 

Value (ppm) 

604 

482 

248 

Mean BD 

Amount 

(%) 

23.0 

66.6 

90.3 

Total 

Average 

SOCHI 

.78070 

3.87020 

1.80190 

Emissions 

Weighted 

SOCMI 

.17967 

2.57698 

1.62726 

(All Values In 

Correlation 

Curve (EPA) 

.02577 

.15660 

.12556 

lb/hr) 

Correlation 

Curve 

(BD Panel) 

.02218 

.09825 

.08847 

BD Panel8 

Annual 

Emissions 

(tons/yr) 

0.0923 

0.4088 

0.3681 

BD Panel Tota l Estimated Annual Emissions (Tons/yr ) 0.869 2 

Total annual emission s based on a *-• • earn facto r of 95%. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 

j*. 
JP^STABLE 5-23. EMISSION FACTORS FOR OPEN-ENDED LINES FOR 

Mean Emission Factors Using 

Plant 

Number 

1 

5 

7 

8 

10 

12 

Relative Std. Dev. 

Average 

SOCMI 

0.003700 

0.003700 

0.003700 

0.003700 

0.003700 

0.003700 

Weighted 

SOCMI 

0.001227 

0.002457 

0.003222 

0.001998 

0.001887 

0.002550 

30.6% 

the Method Listed 

CORR Curve 

(EPA) 

0.001501 

0.000321 

0.004402 

0.000048 

0.003099 

0.000089 

115.0% 

EACH PLANT 

(lb/hr/source) 

CORR Curve 

(BD Panel) 

0.001487 

0.000291 

0.004341 

0.000002 

0.003072 

0.000031 

117.8% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-47 
P.6 

• Mean emission factors among plants varied considerably; 

• Current data show that the emission factors for open-ended 

lines seen in the present study are almost 97% lower than the 

SOCMI emission factors; and 

• The percentage of leaking open-ended lines is 84% lower than 

seen in the SOCMI study. 

5.3.5 Pumps 

There were 376 pumps reported in this study. This constitutes 0.86% 

of the total number of components. 

5.3.5.1 Screening Measurements 

Table 5-24 and Figure 5-6 show the distribution of raw OVA screening 

values and BD concentration for pumps. Twenty-nine, or 7.71%, of these pumps 

were leakers, while 34, or 9.04%, were high-emitting pumps. An additional 23, 

or 6.12%, were in the category of low emitters, while 116, or 30.85%, of the 

pumps were very low emitters. Only 174, or 46.28%, of all pumps were nonleakers. The relation between screening value and BD concentration is 

unclear. The 7.71% leaking pumps represents a 12.4% reduction from the 8.8% 

of leaking components found in the SOCMI study. 

5.3.5.2 Emission Estimates 

Table 5-25 gives the distribution of mean emission factors and total 

emissions for pumps. These data clearly show an increase in emission factors 

with BD concentration. The overall mean emission factor for all pumps was 

0.056339 lb/hr/source (see Table 5-7), which is 48.27% lower than the average 

SOCMI factor. 

5-48 
P.7 

TABLE 5-24. DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD CONCENTRATION FOR 

PUMPS 

Bu1 radiene 

Concentration 

5% 

30% 

90% 

TO 

TO 

TO 

30% 

90% 

100% 

TOTAL 

Number 

0-9 ppm 

32 

83 

59 

174 

of Components in Ser 

10 to 

99 ppm 

26 

32 

58 

116 

100 to 

999 ppm 

6 

7 

10 

23 

eening 

1000 

9999 

7 

14 

13 

34 

Value 

to 

ppm 

Range 

>9999 

2 

16 

11 

29 

ppm TOTAL 

73 

152 

151 

376 

Butadiene 

Concentration 

Percentage of Components in Screening Value Range 

10 to 100 to 1000 to 

0-9 ppm 

10 to 

99 ppm 

100 to 

999 ppm 

1000 to 

9999 ppm >9999 ppm 

5% TO 30% 

30% TO 90% 

90% TO 100% 

43.84 

54.61 

39.07 

35.62 

21.05 

38.41 

8.22 

4.61 

6.62 

9.59 

9.21 

8.61 

2.74 

10.53 

7.28 

Weighted Average 46.28 30.85 6.1 2 9.0 4 7.7 1 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-49 
P.8 

46.28Z 

30.85Z 

6.12Z 

< 10 ppm 

10 -99 ppm 

100 -999 ppm 

1000-9999 ppm 

> 9999 ppm 

7.71Z 9.04Z 

Figure 5-6. Distribution of Raw OVA Screening Values for Pumps 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-50 
TABLE 5-25. DISTRIBUTION OF EMISSIONS BY BUTADIENE CONCENTRATION FOR ALL PLANTS: 

EMISSION ESTIMATES FOR PUMPS 

Butadiene 

Concentration 

Number of 

Components 

Hean Raw 

OVA Screen 

Value 

(ppn) 

Mean BD 

Amount 

(%) 

Mean Emission Factors (All Values in lb/hr/source) 

Average Weighted Correlation Correlation Curve 

SOCMI SOCMI Curve (EPA) (BD Panel) 

5% to 30% 

30Z to 90% 

90% to 100% 

73 

152 

151 

2127 

4387 

1630 

13.9 

55.5 

97.1 

.108900 

.108900 

.108900 

.015136 

.060446 

.105773 

.005754 

.063732 

.073435 

.005747 

.063701 

.073385 

I 

Butadiene 

Concentration 

5% t o 30% 

30% t o 90% 

90Z t o 100% 

Total annual 

Number of 

Components 

73 

152 

151 

emission s bas e 

Mean Raw 

OVA Screen 

Value (ppm) 

2127 

4387 

1630 

d on a stream 

Mean BD 

Amount 

(%) 

13. 9 

55. 5 

97. 1 

facto r of 

Total 

Average 

SOCMI 

7.9497 0 

16.55280 

16.44390 

BD Panel 

95%. 

Emissions 

Weighted 

SOCMI 

1.10490 

9.1877 8 

15.97171 

Total Estimat 

(All Value s In 

Correlatio n 

Curve (EPA) 

0.42001 

9.6872 8 

11.0887 2 

ed Annual Emis 

lb/hr ) 

Correlatio n 

Curve 

(BD Panel) 

0.41955 

9.68257 

11.08115 

sions (Tons/yr ) 

BD Panel 8 

Annual 

Emissions 

(tons/yr ) 

1.7457 

40.289 2 

46.108 7 

88.1436" 

SOURCE: BD PANEL FUGITIVE HUSSIONS STUDY. SUMMER 1988. 

*0 

CO 
P.10 

5.3.5.3 Plant-Specific Analyses 

Separate emission estimates for each participating plant are given 

in Table 5-26. The rates vary from 0.000135 lb/hr/source to 0.139400 

lb/hr/source, representing a ratio of 1033 between the highest and lowest 

rates. The variability among plant emission factors is quite high. 

5.3.5.4 Summary 

The data for the 376 pumps included in this study support the 

following conclusions: 

• The percentage of leaking and high-emitting pumps is higher 

than for all other component types; 

• The emission factors for pumps are a function of BD 

concentration in the pump; 

• The emission factor developed from this study is 48% lower than 

the average SOCMI emission factor; and 

• Emission factors vary considerably among plants. 

5.3.6 Safety Valves 

There were 428 safety valves reported in this study, or 0.98% of the 

components. The protocol specifically excluded all safety valves that vented 

to a common header leading to a pollution control device. 

5-52 
P.11 

TABLE 5-26. EMISSION FACTORS FOR PUMPS FOR EACH PLANT 

Plant 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

12 

13 

Relativ e Std. 

Mean Emission 

Average 

SOCMI 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

Dev. 

Factors Using 

Weighted 

SOCMI 

0.070176 

0.051287 

0.075141 

0.082067 

0.070593 

0.068451 

0.078262 

0.040298 

0.048424 

0.055539 

0.077198 

0.067253 

20.4% 

the Method Liste d 

CORR Curve 

(EPA) 

0.046176 

0.040792 

0.001409 

0.139400 

0.000168 

0.004365 

0.111660 

0.077255 

0.000177 

0.081892 

0.047415 

0.027860 

95.9% 

(lb/hr/source ) 

CORR Curve 

(BD Panel) 

0.046173 

0.040764 

0.001398 

0.139400 

0.000135 

0.004365 

0.111613 

0.077240 

0.000165 

0.081857 

0.047366 

0.027813 

96.0% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-53 
P.12 

5.3.6.1 Screening Measurements 

The distribution of raw OVA screening values for each BD 

concentration range for safety valves in shown in Table 5-27 and illustrated 

in Figure 5-7. Six components comprising 1.40% of all safety valves tested 

were found to be leaking. This represents a 61.1% reduction from the 3.6% of 

leaking components found in the SOCMI study. Two valves (0.47%) were high 

emitters. Almost 98% of all safety valves were either non-emitters, very low 

emitters, or low emitters. The effects of BD concentration on the number of 

components in each screening value range are not evident. 

5.3.6. 2 Emission Estimates 

Table 5-28 shows the mean emission factors and tota l emissions for 

safety valves. The mean emission factors for the 5%-30% BD and 30%-90% BD 

ranges are almost identical, while the factor for the >90% BD range is more 

than 10 times higher. The BD Panel mean emission factor for al l safety valve s 

was 0.029960 lb/hr/sourc e (see Table 5-7), which is 86.9% lower than the 

average SOCMI emission factor . 

5.3.6. 3 Plant-Specifi c Analyses 

Table 5-29 shows the separate mean emission factors developed for 

safety valve s for each plant. The mean values range from 0.000005 

lb/hr/sourc e to 0.102453 lb/hr/source . Wide variabilit y in emission factors 

is also evident in the table , as shown by the 226.6% relativ e standard 

deviation in the data. 

5-54 
P.13 

TABLE 5-27. DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD CONCENTRAITON FOR 

SAFETY VALVES 

Butadiene 

Concentration 

5% TO 30% 

30% TO 90% 

90% TO 100% 

TOTAL. 

Number 

0-9 ppm 

67 

182 

119 

368 

of Components in 

10 to 

99 ppm 

26 

17 

1 . 

44 

100 to 

999 ppa 

4 

4 

0 

8 

Screening Val 

1000 to 

9999 ppm 

0 

2 

0 

2 

ue Range 

>9999 ppm 

2 

1 

3 

6 

TOTAL 

99 

206 

123 

428 

Butadiene 

Concentration 

Percentage of Components in Screening Value Range 

10 to 100 to 1000 to 

0-9 ppm 99 ppm 999 ppm 9999 ppm >9999 ppm 

5% TO 30% 

30% TO 90% 

90% TO 100% 

67.68 

88.35 

96.75 

26.26 

8.25 

0.81 

.4.04 

1.94 

0.00 

0.00 

0.97 

0.00 

2.02 

0.49 

2.44 

Weighted Average 85.98 10.28 1.87 0.47 1.40 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-55 
P.14 

< 10 ppm 

J 10-99 ppm 

vM$ffl «»-999ppm 

1000-9999 ppm 

i ^VjVJ > 9999ppm 

Figure 5-7. Distribution of Raw OVA Screening Values for Safety Valves, 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-56 
TABLE 5-28. DISTRIBUTION OF EMISSIONS BY BUTADIENE CONCENTRATION FOR ALL PLANTS: 

EMISSION ESTIMATES FOR SAFETY VALVES 

Butadiene 

Concentration 

Number of 

Componente 

Mean Raw 

OVA Screen 

Value 

(PP") 

Mean BD Mean Emission Factors (All Values in lb/hr/source) 

Amount Average Weighted Correlation Correlation Curve 

(%) SOCMI SOCMI Curve (EPA) (BD Panel) 

5% to 30% 

30% to 90% 

90% to 100% 

99 

206 

123 

2031 

82 

1829 

12.5 

54.2 

96.6 

.229100 

.229100 

.229100 

.028561 

.124092 

.221378 

.005661 

.008253 

.086031 

.005653 

.008210 

.085951 

Oi 

I 

Oi 

^4 Butadiene 

Concentration 

5% t o 30% 

30% t o 90% 

90% t o 100% 

Number of 

Components 

99 

206 

123 

Mean Raw 

OVA Screen 

Value (ppm) 

2031 

82 

1829 

Mean BD 

Amount 

(%) 

12. 5 

54. 2 

96. 6 

Tot 

Average 

SOCMI 

22.6809 0 

47.1946 0 

28.1793 0 

BD Panel 

al Emissions 

Weighted 

SOCMI 

2.82755 

25.56298 

27.22945 

(All Value s In 

Correlatio n 

Curve (EPA) 

0.5604 8 

1.70003 

10.5818 4 

lb/hr ) 

Correlatio n 

Curve 

(BD Panel) 

0.5596 9 

1.69133 

10.57197 

Tota l Estimated Annual Emissions (Tons/yr ) 

BD Panel 

Annual 

Emissions 

(tons/yr ) 

2.328 9 

7.037 6 

43.990 0 

53.3565® 

Total annual emissions based on a stream factor of 95%. 

SOURCE: BD PANEL FUGITIVE HUSSIONS STUDY. SUMMER 1988. 

*0 
P.16 

TABLE 5-29. EMISSION FACTORS FOR SAFETY VALVES FOR EACH PLANT 

Plant 

Number 

1 

2 

3 

5 

6 

8 

9 

10 

12 

13 

Relativ e Std. 

Mean Emission 

Dev. 

• i • 

Average 

SOCMI 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

Factors Using 

Weighted 

SOCMI 

0.051929 

0.098656 

0.103095 

0.137460 

0.192444 

0.085709 

0.044293 

0.078467 

0.137738 

0.144045 

42.6% 

the Method Liste d 

CORR Curve 

(EPA) 

0.000041 

0.102482 

0.000139 

0.000053 

0.000082 

0.003247 

0.000027 

0.000126 

0.000327 

0.041043 

226.1% 

(lb/hr/source ) 

CORR Curve 

(BD Panel) 

0.000038 

0.102454 

0.000129 

0.000005 

0.000023 

0.003221 

0.000012 

0.000102 

0.000277 

0.040991 

226.6% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-58 
P.17 

5.3.6.4 Summary 

Conclusions drawn from the 428 safety valve data points are as 

follows: 

• The relation between BD concentration and emission 

characteristics (both the number and severity of emitters) is 

not clear; 

• Emissions vary considerably among plants; 

> 

• Current data show that emission factor for safety valves seen 

in the present study is 87% lower than the SOCMI factor; and 

• The percentage of leaking safety valves is 61% lower in the 

current study than found in the SOCMI study. 

5.3.7 Sample Points 

Forty sample points were reported in this study. Since in every 

case testing was performed while the sample point was inoperative, these 

components were compared with open-ended lines. The small number of 

components corresponds to only 0.09% of the total components studied. Table 

5-30 and Figure 5-8 show the distribution of raw OVA screening values for 

sample points in each BD concentration range. Table 5-31 shows the mean 

emission factors and total emissions corresponding to sample points. Table 

5-32 indicates that data were received from four plants and that a substantial 

spread in emission factors occurred among the plants. Overall, data are 

insufficient to fully evaluate the emission characteristics of sample points. 

5-59 
P.18 

TABLE 5-30. DISTRIBUTION 

SAMPLE POINTS 

Number 

Butadiene 

Concentration 0-9 ppm 

5% TO 30% 

30% TO 90% 

90% TO 100% 

TOTAL 

3 

2 

7 

12 

OF RAW OVA SCREENING VALUES BY 

of Components in Screening Val 

10 to 

99 ppm 

4 

4 

7 

15 

100 to 

999 ppm 

0 

2 

6 

8 

1000 to 

9999 ppm 

1 

1 

1 

3 

BD 

ue 

CONCENTRATION 

Range 

>9999 ppm 

0 

2 

0 

2 

FOR 

Total 

8 

11 

21 

40 

Butadiene 

Concentration 

Percentage of Components in Screening Value Range 

10 to 100 to 1000 to 

0-9 ppm 99 ppm 999 ppm 9999 ppm >9999 ppm 

5% TO 30% 

30% TO 90% 

90% TO 100% 

37.50 

18.18 

33.33 

50.00 

36.36 

33.33 

a. 00 

18.18 

28.57 

12.50 

9.09 

4.76 

0.00 

18.18 

0.00 

Weighted Average 30.00 37.50 20.00 7.50 5.0 0 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-60 
P.19 

37.50Z 

30.00% 

S.00Z 

I I < 10 ppm 

[ ••--*--'•• > j 10 • 99 ppm 

fejaSKffl 100*999ppm 

11^1 1 1000-9999 ppm 

l'///*V'/-j >9999ppm 

20.00Z 

Figure 5-8. Distribution of Raw OVA Screening Values for Sample Points 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 

5-61 
TABLE 5-31. DISTRIBUTION OF EMISSIONS BY BUTADIENE CONCENTRATION FOR ALL PARTICIPATING PLANTS: 

EMISSION ESTIMATES FOR SAMPLE POINTS 

Butadiene 

Concentration 

Number of 

Componentt 

Mean Raw 

OVA Screen 

Value 

(ppm) 

Hean BD Mean Emission Factors (All Values in lb/hr/source) 

Amount Average Weighted Correlation Correlation Curve 

(%) SOCMI SOCMI Curve (EPA) (BD Panel) 

5% to 30% 

30% to 90% 

90% to 100% 

8 

11 

21 

172 

8393 

139 

16.5 

47.2 

96.1 

.003700 

.003700 

.003700 

.000611 

.001746 

.003557 

.000536 

.003872 

.002829 

.000531 

.003863 

.002803 

Oi 

I 

as 

to Butadiene 

Concentration 

5% to 30% 

30% to 90% 

90% to 100% 

Total annual 

Number of 

Components 

8 

11 

21 

emissions bat 

Mean Raw 

OVA Screen 

Value (ppm) 

172 

8393 

139 

jed on a stream 

Hean BD 

Amount 

(%) 

16.5 

47.2 

96.1 

factor of 

Tot 

Average 

SOCMI 

.02960 

.04070 

.07770 

BD Panel 

95%. 

al Emissions 

Weighted 

SOCMI 

.00488 

.01920 

.07470 

Total Estima 

(All Values In 

Correlation 

Curve (EPA) 

.00429 

.04259 

.05941 

lb/hr) 

Correlation 

Curve 

(BD Panel) 

.00425 

.04249 

.05886 

ted Annual Emissions (Tons/yr) 

BD Panel8 

Annual 

Emissions 

(tons/yr) 

.0177 

.1768. 

.2449 

.4394° 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY. SUMMER 1988. 
P.21 

TABLE 5-32. EMISSION FACTORS FOR SAMPLE POINTS FOR EACH PLANT 

Plant 

Number 

Mean Emission Factors Using the Method Listed (lb/hr/source) 

Average 

SOCMI 

Weighted 

SOCMI 

CORR Curve 

(EPA) 

CORR Curve 

(BD Panel) 

1 

2 

3 

7 

0.003700 

0.003700 

0.003700 

0.003700 

0.002037 

0.000259 

0.002893 

0.002689 

0.002338 

0.000007 

0.003434 

0.000069 

0.002329 

0.000007 

0.003411 

0.000034 

Relative Std. Dev. 52.6% 101.0% 102.1% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-63 
P.22 

5.3.8 Compressors 

Data concerning 17 compressors were received from three plants in 

this study. As seen in Table 5-33 and Figure 5-9, the compressors were either 

non-leakers or very low emitters. Table 5-34 shows the overall reduction in 

mean emission factors from those estimated by the SOCMI method. The limited 

data in Table 5-35 show the variation in mean emission factors among the three 

reporting plants. Overall, not enough data from compressors were available to 

fully evaluate their fugitive emission characteristics during the production 

of 1,3-Butadiene. 

5.4 Bagging Study 

Optional bagging tests were conducted at three plants in conjunction 

with the screening studies. The results of all the bagging tests are 

presented in Appendix 4. These bagging tests can potentially be used for two 

purposes. The non-zero-screening source data can be used to check the SOCMI 

screening-to-leak rate correlations for applicability and to develop new 

correlations (if necessary). The zero-screening source data can be used to 

develop better default zero values. 

The non-zero-screening bagging data are plotted for liquid valves 

and for flanges in Figure 5-10 and 5-11, respectively, along with the SOCMI 

correlation line. In order to use linear regresion analysis techniques, the 

data are plotted in log-log space. Two types of data are plotted. The "plus 

signs" are bagging data expressed as total VOC, while the "diamonds" are 

bagging data expressed as butadiene. The points that look like "filled 

diamonds" are for 100% BD streams where the total VOC and BD bases are the 

same. 

5-64 
P.23 

TABLE 5-33 . DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD CONCENTRATION FOR 

COMPRESSORS 

Butadiene 

Concentration 

5% TO 30% 

30% TO 90% 

TOTAL 

Number 

0-9 ppm 

13 

1 

14 

of Compt 

10 to 

99 ppm 

1 

2 

3 

anents 

100 

999 

0 

0 

0 

in S 

to 

ppm 

creening Value 

1000 to 

9999 ppm 

0 

0 

0 

Range 

>9999 ppm 

0 

0 

0 

TOTAL 

14 

3 

17 

Butadiene 

Concentration 

Percentage of Components in Screening Value Range 

10 to 100 to 1000 to 

0-9 ppm 

10 to 

99 ppm 

100 

999 ppm 9999 ppm >9999 ppm 

5% TO 30% 

30% TO 90% 

92.86 

33.33 

7.14 

66.67 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

Weighted Average 82.35 17.65 0.00 0.00 0.00 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988 . 

5-65 
P.24 

1000-9999 ppm 

,*.••- • I > 9999ppm 

17.65Z 

82.35Z 

Figure 5-9. Distribution of Raw OVA Screening Values for Compressors. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-66 
TABLE 5-54 . IH.STRLBUTION OF EMISSIONS BY BUTADIENE CONCENTRATION FOR ALL, PIuANTS: 

EMISSION ESTIMATES FOR COMPRESSORS 

Butadiene 

Concentration 

Mean Raw 

OVA Screen -Mean BD 

Number of Value Amount 

Components (ppm) (%) 

Mean Emission Factors (All Values in lb/hr/source ) 

Average Weighted Correlation Correlation Curve 

SOCMI SOCMI Curve (EPA) (BD Panel) 

5% t o 30% 

30% t o 90% 

14 

3 

2 

13 

19.6 

66.7 

.502200 

.502200 

.098646 

.334800 

.000018 

.000059 

.000004 

.000002 

I 

ON Butadiene 

Concentration 

5% to 30% 

30% to 90% 

Number of 

Components 

14 

3 

Mean Rau 

OVA Screen 

Value (ppm) 

2 

13 

Mean BD 

Amount 

(%) 

19.6 

66.7 

Total 

Average 

SOCMI 

7.03080 

1.50660 

Emissions 

Weighted 

SOCMI 

1.38105 

1.00440 

(All Values In 

Correlation 

Curve (EPA) 

0.00025 

0.00018 

lb/hr) 

Correlation 

Curve 

(BD Panel) 

.00005 

.00001 

BD Panel8 

Annual 

Emissions 

(tons/yr) 

.0002 

.0000 

BD Panel Total Estimated Annual Emissions (Tons/yr) .0003 

Total annual emissions based on a stream factor of 95%. 

SOURCE: BD PANEL FUGITIVE HUSSIONS STUDY. SUMMER 1988. 
P.26 

TABLE 5-35. EMISSION FACTORS FOR COMPRESSORS FOR EACH PLANT 

Plant 

Number 

Mean Emission Factors Using the Method Listed (lb/hr/source) 

Average 

SOCMI 

Wei ght ed 

SOCMI 

CORR Curve 

(EPA) 

CORR Curve 

(BD Panel) 

5 

7 

13 

0.502200 

0.502200 

0.502200 

0.100440 

0.376650 

0.109408 

0.000025 

0.000066 

0.000019 

0.000025 

0.000002 

0.000002 

Relative Std. Dev. 65.5% 57.0% 137.4% 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-68 
P.27 

- 1 -

a: 

i 

03 

.J 

< 

K 

2 

O 

IA 

(/> 

9 

- 2 -

- 3 -

- 4 -

- 5 -

- 6 

SCREENING TO LEAK RATE CORRELATION EXAMINATION 

VALVES IN LIQUID SERVICE IN BUTADIENE PLANTS 

Correlation Equation 

Experimental Data Expressed as VOC 

Experimental Data Expressed as BO o 

o 

+ o 

+ o 

i » -

3 4 

LOG SCREEN VALUE (ppm) 

Figure 5-10. Screening t o Leak Rate Correlation Examination: Valves 

in Liquid Service in Butadiene Plants 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-69 
P.28 

U*. 

(D 

(iJ 

O 

(A 

U 

8 

-1. 5 

SCREENING TO LEAK RATE CORRELATION EXAMINATION 

FLANGES IN BUTADIENE PLANTS 

- 2 -

-2.5 -

- 3 -

-5. 5 -

+ 

o 

Correlation Equation 

Experimental Data Expressed as VOC 

Experimental Data Expressed as 8D 

0.8 1.2 1.6 

i o i ° |0 •» o 

2 2.4 2.8 

LOG SCREEN VALUE (ppm) 

i 

12 

—J— 

3.6 

Figure 5-11. Screening to Leak Rate Correlation Examination: Flanges in 

Butadiene Plants 

SOURCE: BD PuANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-70 
P.29 

All of the measurements for the bagging were reported as butadiene. 

Where the line concentration of BD was also reported, it was possible to 

convert the data to a total VOC basis. The total VOC basis is most 

appropriate for comparison to the SOCMI correlations, since the SOCMI data on 

which the correlations are based are total VOC. It also should be noted that 

the screening instrument reacts to total VOC, not just to butadiene, so the 

correlation should be stronger when expressing screening and bagging data on 

the same basis. When the correlation is then applied to estimate emission 

rates, the VOC emission rate that results is adjusted to a butadiene basis by 

applying the butadiene weight % factor. 

The SOCMI correlation for liquid service valves appear to adequately 

represent the plotted data. A new correlation line fitted to the butadiene 

data would probably have a slightly higher slope, but a lower intercept, than 

the SOCMI correlation line. There are three data points plotted along the 

bottom axis that are anomalous. These points were reported with zero 

emissions as determined by bagging, despite screening values that ranged from 

1,000 to over 10,000 ppm. An emissions value of 10E-6 was substituted for the 

reported zero value to allow them to be plotted on the log scale (log[0] is 

insoluble). Possible explanations for the anomalous results are that the 

emissions were largely non-butadiene or that the sources were not re-screened 

just before and after bagging to insure that the screening value had hot 

changed. Even including these anomalous data, the existing SOCMI correlation 

line appears to adequately represent the BD data. 

The SOCMI (refinery) correlation for flanges does not represent the 

BD flange data very well. Only three points fell above the correlation line, 

while 14 points fell below it. It should be noted, however, that seven of the 

points falling below the line are of the anomalous type noted in the 

discussion of liquid valves (i.e., high screening values with zero measured 

emissions rates). There do not appear to be sufficient data to develop a new 

correlation for flanges in BD service at this time. Based on these initial 

bagging results and the significant impact that flanges emissions have on 

total fugitive emissions estimates, however, further bagging of flanges and 

possible development of a new correlation should be considered in the future. 

5-71 
P.30 

The zero-screening sources were analyzed to determine whether new 

default zero values could be developed. The default zero concept was 

developed by EPA to account for the fact that bagging measurements are more 

sensitive than screening measurements in detecting low-level leakage. About 

10 gas valves that screened at "zero" (i.e., no difference between the maximum 

screening value and the ambient background concentration) were bagged in the 

SOCMI study and found to have non-zero leak rates. The average leak rate for 

these sources was calculated, and that value was used to determine the 

equivalent screening value by applying the correlation backwards (from leak 

rate to screening value instead of from screening value to leak rate). The 

results of this analysis was a "default zero" screening value of 8.17 ppm that. 

EPA recommended for use for all source categories. 

The bagging data for zero-screening sources is presented in Appendix 

4 as part of the total bagging data and in individual summaries for each 

source type. For each source type and/or correlation equation, the measured 

emissions rates for the zero-screening sources were averaged. That average 

emission rate can be used directly to estimate the emissions from zeroscreening sources. The average values were also backed through the 

correlations to arrive at default zero screening values. The results of these 

calculations are presented in Table 5-36. The default zero emission rates 

range from 0.000000812 lb/hr/source for valves in gas service to 0.001788 

lb/hr/source for flanges. That corresponds to a range of default zero 

screening values of 0.013 to 6.75 ppm, respectively, for the same two source 

types. The default zero values in Table 5-36 were used for all calculations 

presented under the column titles of "Correlation Curve (BD Panel)" or 

"Calculated Emission Rate (BD Panel)." 

Note that different defaults are given for each source type with its 

own correlation. An attempt was made to lump the data to arrive at a single 

default zero value similar to the EPA value of 8.17 ppm. It was determined, 

however, that no single default value could adequately describe all of the 

sources. It should be recalled that EPA arrived at a single value largely 

because all of the available test data were from one source type. 

5-72 
P.31 

TABLE 5-36. SUMMARY OF BUTADIENE DEFAULT ZERO BAGGING STUDY RESULTS 

Equipment 

Type 

Valve 

Valve 

Flange 

Open-Ended 

Line3 

Service 

Category 

Liquid 

Gas 

All 

All 

Number 

Data Pa 

4 

8 

7 

2 

of 

lirs 

"Default Zero" 

Screening Value 

(ppm) 

0.0032 

0.0130 

6.7500 

0.1400 

Zero Screening 

Value Emission Factor 

(lb/hr/Source) 

0.000025030 

0.000000812 

0.000178800 

0.000002269 

Default value for open-ended lines used for all other components except 

valves and flanges. 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-73 
P.32 

6.0 BUTADIENE WORK PRACTICES, OPERATING PROCEDURES, AND DESIGN 

GUIDELINES: RESULTS OF A 1,3-BUTADIENE SURVEY 

As other sections of this report demonstrate, current overall 

industry fugitive emissions of 1,3-butadiene are lower than those estimated 

previously by EPA using the SOCMI emission factors. The 1,3-Butadiene Panel 

decided to conduct an industry survey of work practices, operating procedures, 

and design guidelines in an attempt to explain the low fugitive emissions 

measured in the current study. This section of the report summarizes the 

responses to the survey. A copy of the questionnaire may be found in Appendix 

5. 

Of the 13 butadiene plants participating in the current study, six 

(or 46X) sent complete response to the questionnaire. All the responding 

plants monitor fugitive emissions of 1,3-butadiene. All six plants stated 

that the potential for BD leaks was a concern during the design of the BD 

process. 

In response to questions number four and five, concerning the 

programs used for general and specific leak detection, all six of the plants 

said they use a combination of visual observation and automatic alarm-sounding 

system that monitor certain BD equipment such as pumps and compressors. Three 

plants have routine leak inspection and maintenance programs. Two plants use 

TLV sniffers or OVAs to monitor gas valves, compressors, and relief valves 

every quarter. One plant has tagged all BD components and regularly enters 

screening information in a database. 

In response to question number six about special procedures used to 

check for, prevent, and reduce the effects of leaks, five of the six plants 

cited combinations of the following procedures: 

• Following codes and specifications; 

• Employees training; 

• Visual inspection; 

• Bubble-testing flanges; 

6-1 
P.33 

Pressure testing; 

Tightness testing of valves; 

VOC monitoring with detectors; 

Use of double-sealed pumps; 

Seals vented to flare; 

Closed loop sampling points; 

Use of special packing material; and 

Plugging of all open-ended lines. 

Two plants said they have no formal inspection program, but, informally, they 

require immediate repair of leaks detected by the BD monitoring system. Leaks 

that cannot be repaired immediately are repaired within three days. 

Three plants said they have a written leak inspection program. One 

plant gave the details of their program, which includes the use of logbooks, 

TLV sniffers, and computerized records. One plant said they follow Texas Air 

Control Board Regulations (TACB). One plant said they have no written 

procedures, and one plant did not answer this question. 

All six plants responded to the questions concerning on-line 

maintenance and repair procedures for leaking equipment. All said that leaks 

are isolated and repaired immediately when possible. On-line repairs are made 

for low-risk leaks and emergencies. Equipment for which a spare exists is 

removed from service. Clamps and tightening are used for repairing small 

leaks on line. One plant cited the use of sealant on flanges and valves. Two 

of the plants said they evaluate each case individually. 

Two plants said that Q2 leaks that expose plant personnel to BD are 

acceptable. Decisions about shutting down the plant to repair major leaks are 

made case by case; all the plants have contingency shut-down plans. All the 

plants considered toxicity, leak potential, explosion potential, product 

savings, and energy loss when designing the BD process and selecting 

equipment. 

6-2 
P.34 

All six plants responded to questions about the use of specific leak 

detection equipment, the testing of components before installation, and 

quality control measures to reduce the potential for leaks. Five plants 

specifically mentioned following standard engineering codes and process design 

specifications. Three plants said they inspect the equipment and services of 

their vendors. One plant cited the use of double seals on pumps and keeping 

the use of screw pipe fittings to a minimum. One plant has a training program 

for contractors. All the plants use hydrostatic testing and/or gas pressure 

testing. Four plants cite the use of x-ray testing of welds, and two plants 

use ultrasonics to test equipment for structural flaws. Two plants stated 

that components are tested for tightness before installation. 

In response to the question about equipment changes made to reduce 

leaks, three plants listed combinations of the following: 

• Use of dual seals on pumps with a vent to a flare; 

• Replacement of all asbestos materials; 

« 

• Use of improved packing materials; and 

• Replacement of tank car sliptube gauges with magnetic gauges. 

One respondent said that their plant was relatively new and modern; therefore, 

few changes had been made. They had made some changes in metallurgy to reduce 

corrosion and erosion. One respondent said that no changes had been needed. 

In summary, the plants responding to the questionnaire, representing 

46Z of the 1,3-butadiene plants in the U.S., seem to be mostly aware of the 

improved technology and methods available for minimizing and responding to 

leaks of this toxic chemical. Some of the plants seemed more aware than 

others of the techniques and improved equipment available, but the discrepancy 

did not seem wide. 

6-3 
7.0 REFERENCES 

1. Fugitive Emission Sources of Organic Compounds — Additional 

Information on Emissions. Emission Reduction, and Costs. EPA-450/3-

32-010, U.S. Evnironmental Protection Agency, Office of Air Quality 

Planning and Standards, Research -Triangle Park, NC, April 1982. 

2. Radian Corporation. Assessment of Amospheric Emissions from 

Petroleum Refining. EPA-600/2-80-075, U.S. Environmental Protection 

Agency, Research Triangle Park, NC, 1980. 

3. Langley, G.J. and R.G. Wetherhold. Evaluation of Maintenance for 

Fugitive VOC Emissions Control. EPA-600/52-81-080, U.S. 

Environmental Protection Agency, Research Triangle Park, NC, May 

1981. 

4. Blacksmith, J.R., et al. Problem-Oriented Report: Frequency of 

Leak Occurrence for Fittings in Synthetic Organic Chemical Plant 

Process Units. EPA-600/2-81-003, U.S. Environmental Protection 

Agency, Research Triangle Park, NC, September 1980. 

5. CMAI, Inc., 1987 World Butadiene Analysis. June. 1987. 

6. Butadiene Overview and Responses to OSHA Inquiry Regarding Rule 

Making for Occupational Exposure to 1.3-Butadiene. Appendix III. 

Prepared for CMA by CMAI, December 22. 1986. 

7. Protocols for Generating Unit-Specific Emission Estimates for 

Equipment Leaks of VOC and HAP. EPA 450/3-88-010, U.S. 

Environmental Protection Agency. OAQPS, Research Triangle Park, NC, 

October 1988. 

7-1 
P.36 

8. Fugitive Emission Sources of Organic Compounds - Additional 

Information on Emissions, Emission Reductions, and Costs. EPA450/3-82-010, U.S. Environmental Protection Agency, Research 

Triangle Park, NC, April 1982. 

9. Stelling, J.H.E. Emission Factors for Equipment Leaks of VOC and 

HAP. EPA-450/3-86-002, U.S. Environmental Protection Agency, 

Research Triangle Park, NC, January 1986. 

10. Dimmick, W. F. and K.C. Hustvedt. "Equipment Leaks of VOC: Emissions 

and Their Control." Paper No. 84-62.1 presented at the 77th Annual 

Meeting of the Air Pollution Control Association, San Francisco, CA. 

June 24-29. 1984. 

11. Chemical Manufacturer's Association (CMA). Guidance for Estimating 

Fugitive Emissions. Washington. DC. July 1987. 

12. Radian Corporation, Austin, TX. Workbook for Estimating Ethylene ' 

Oxide Fugitive Emissions. March 1988. 

13. Response Factors of VOC Analyzers at a Meter Reading of 10.000 ppmv 

for Selected Organic Compounds. EPA-600/2-81-051. U.S. 

Environmental Protection Agency, 1981. 

7-2 
P.37 

APPENDIX 1 

EPA METHOD 2 1 
P.38 

31—Dmucnunoa or VQUOBM 

Omaune Cunwuiw IMAM* 

1. AvpttcmMUtg and Prtnetpf Ll Applicability. This method applie

s to 

the determination of volatile organic eom-

pouad (VOO leaks from proeias equipment. 

Th«* saunas include, bat an not limited 

to. valvea. flanges and other eonneetlene. 

sad compressors, pr—un relief de-

process drains, open-ended valvea. 

vents, annnnnlarnr vassal vasts, agitator 

•aalSa "*^ aooaas door teals. 

Li Principle. A portable Instrument Is 

used to detect VOC leaks tna individual 

. Tha Immunol it detector type ts not 

but It mast meat tha tpodfloe-

ttans sad performance ertterla rrmfitned In 

Section 3. A leak definition concentration 

based on a ref ennoo ocmpound Is tpeclflod 

In each applicable regulation. This prooedun is lateadsd to locate and classify leaks 

only, and Is not to ba used as a direct aeaa* 

un of mass "—«—*—• rates fnm Individual 

IMteUtoiu 

2J, Leak Definition Concentration. The 

local VOC concentration at tha surface of a 

leak source that indicates that a VOC amis-

i (leak) is present. The leak definition Is 

• reading based on a nf • 

3J Reference Compound. The VOC wa-

des selected ss an Instrument calibration 

i for specification of the leak definition 

(Mr example: If a leak defi-

nition concentration to 10.000 ppmv sa 

suits tn a local concentration that yields a 

meter reading of 10.000 an an Inairiiuisni 

calibrated with OMtbane would be classified 

as a leak. In this cample, tha leak defini-

tion is 10400 ppmv. and the ref • 

BMffifl tat BBfltgyannOfle J 

U Calibration Oas. The VOC i 

used to adjust the instrument meter reading 
P.39 

ft. 60, App. A, Math. 21 40 CK Ch. I (7.147 Mtmn) 

to a known value. The calibration gas is usn* a. The hisliiiiiiaiil response (acton tor tha 

ally the reference orwnpounrt at a conoentra. indtvtdal T-«~« T to be measured mm. 

don approximately equal to tha leak dcflnl- be lam than 10. ^ ^ 

Uon concentration. b. The instrument response thae must be 

3.4 NO Detectable Tmfton The local equal to or lam than 30 seconds. The rZ 

VOC concentration at tha surface of a leak cponee time must be determined tor the hv 

source that indicates that a VOC emission strumeat configuration to bo used during 

, , . •»**.

 Bd1t

» •> ad *» ?**"** c The calibration predion must be equal 

for instrument arm ana tmperieet repro- & v ]mm m,- IQ w^—M-t «f the ««'n~Mdudbillty. e dltfenaoo between the source , L ~H ~ P"W» « " * cauoratian 

surtsosooiKonyttonsa^locsiMblent d. The evaluation praoedun for each p* 

is oavorauDoov A aiixcroaoo ••••••i.. <• - «. — . . "^ 

i meter routings of lam **— a con- ^?^^J^J!W , , a a *

c

y *"*" 

naurngs mj^sManajwn. ^ p^og^ag, tmattkm Requirereadability specification ImMntse that a 

VOC emission (leak) is not present, trot ex- . »» A rssponos factor must be detarmtnad 

ample. If the leak definition tn a regulation for each compound that Is to bo measured. 

Is 10.000 ppmv, than the allowable tnereeee either by tasting or tram reference souraei. 

tn surface concentration versus local amM> *he reepanss factor tests an nquiied 

eat Tintif«—*»w would bo 500 ppmv baaed before placing the analyser into sarttoe. but 

an the Inimimonf meter readings.)

 d 0

 Bat have to be repeated at subsequent ta2J neeponss Factor. The ratio of the tarvalo. 

known concentration of a VOC uumpuuud b. The rallhratinn precision test must be 

to the ubeemd motor reading whan mess completed prior to placing the analyser into 

und using sn Instrument calibrated wtth service, and at subsequent 3-month Intervals 

the reference compound iporlftod In the ap- or at the next use whichever is later, 

plication regulation. e. The response time test is required prior 

10 Calibration Precision. The degree of to placing the tusuumsut into service. If a 

between measurements of the modification to the sample r*""*iPl**f system 

i known value, expressed as the relative or flow configuration Is made that would 

of tha avenge difference be- chance tha rasponss ttma. a now test Is rathe meter readings sad the kaown quired prior to further use. 

concentration to the known concentration. 3 j Calibration aaaaa. Tha monitoring ta2.7 Rasponss Time. The time interval strament to calibrated In terms of parts per 

from a step change in VOC concentration at million by volume (ppmv) of the "''"" t 

tha input of tha ssmplinc systsm to the compouad specified In the applicable regotima at which 90 percent of the correspond- tattcn. The "all»mtHpn gaam required tor 

ing final value la reached as displayed on monitoring and Instrument performance 

the instrument readout meter. evaluation an a sen gas (air. lam than 10 

3. apparatus ppmv VOO and a calibration gas in air mix3.1 Mim'»"»tng litviiimf

 tar* approximately equal to the leak doflai3.1.1 rTparlfkisflons

 Uo n

 «P-*rtfl*

>

 " the regulation. If cylinder a. Tha vo c tmnmunt iiaf tm <ttaii f«. calibration gas mlxturee an used, they must 

•. 1 am »ww «nn » fmnwriar • « •» ^ umijrxed and certified by the manufacturer to be wtthm ±2 percent aoeuney, and 

a shelf life must be specified. Cylinder 

catalytic oxidation, flams Uwitmrtwi, infra- ^m******** ?^TM£??,?,.?" 

red abaorstion. and p*^**-*-TT«—»«<•- placed at the end of the specified shelf Ute. 

b. The Tmr « «n»n be fapaM* of Alternately. calibration taaes may be precpond to the compounds being 

Detector types which may meet this requirement include, but an not limited to. 

• UM if^MaWfU^M <imoentrat1ftn P*ndby the user according to any accepted 

ttT*»1fiTi1 in the ngH,,H,m gaseous standards preparation procedure 

cit e scale of the instrument meter shall ^J^^l^^SS^^r t bo rssilshls to xS percent of the —»—«~« ** pereent. prepared stanaaros must oe wlnkdStot^coDoe^^aiL

 W ~U J

~ placed each day of use unices It can be demd. The instrument shall be equipped wtth S£^2L2 £

 ,ta

«

,ld

»

a oB

 °° "

 aat 00BUr 

a pump ao that a continuous sample Is pr» aunng swago. _, 

vtdsd to the detector. The «*—«»»«• T~*nplt calibrations may oe penuiuieo using a 

flow rata shall be tt to 3 Utan per minute. confound

 otn*»-r

}**? .**• ^•TMno» «°°> 

e. The Instrument shall be Intrinsically pound if a conversion factor is determined 

ssiet«omi^rtaexplostnatm«^ ^ '» £* 'tZT'i^0"

9

??* " H2? HS 

ss 'Mlrwl by the applicable OAA. stand- nsultlag meter readings dunag source surante (14. National Electrical Code by the

 v *,> c*n

_°* converted to reference cornNational Pin Prevention Association). pound results. 

3.1 J Performance Criteria. 4. Procedure* 
P.40 

4.1 Prefect Preparations. Perform the Instrument evaluation procedures given In 

Section 4.4 If the evaluation requirements of 

Section 3.U have not been met. 

O Calibration Procedures. Assemble and 

start up the VOC analyser according to the 

manufacturer's instructions. After the tppropriate warmup period and sere internal 

calibration procedure, introduce the calibration gas Into the Instrument sample probe. 

Adjust the Instrument meter readout to correspond to the calibration gas value. 

NOCK If the meter readout cannot be adjusted to tha proper value, a malfunction of 

the analyser is Indirsted and corrective actions an necessary bet on use. 

4J Individual Source Surveys. 

4.3.1 Type I-Laak Definition Baaed on 

Concentration. Place the probe inlet at the 

surface of the component Interface when 

leakage could occur. Move the probe alone 

the Interface periphery white obssrvtng the 

Instrument readout. If aa increased meter 

reading is observed, slowly sample the laterface where leakage is Indirsted until tha 

•"*"• • meter i sailing Is obtained. Lean 

the probe ialet at this marlnum reading U> 

cation for approximately two times the Instrumsnt response time. It the maximum 

observed mater reading is greater than tha 

leak definition In tha appUcable regulation, 

record aad report the results as specified la 

the regulation reporting requirements. Cs* 

smplss of tha application of this general 

technique to specific equipment types aw; 

a. Vaivss The moot common source of 

leaks from valvea Is at tha seal between the 

stem and housing. Place the probe at the 

interface when the stem exits the packing 

gland "*** "flir1^ the stem »*—*wft'iy* 

Also, place the prose at the Interface of the 

gland take-up flange 

the parlphary. In 

valve bousincs of multipart ssssmhly at tha 

surfaoe of all lntarfaeao whan a leak could 

b. Fiances and Other 

welded flanges, plan the i 

of the^ 

warns) CasTCeilaaiSatSs1 

lOf I 

-Por 

i at the outer 

Interface 

of tha 

•tmanant joints 

(such ss threaded connectlone) wtth a similar traveree. 

e. Pumps and Compreeeors—Conduct a circumferential traverse at the outer surf see 

of the pump or eompneeor shaft aad seal 

Interface. If the source Is a rotating shaft, 

position the probe inlet within 1 em of the 

•haft seel Interface for the survey. If the 

bousing configuration prevents a complete 

traverse of the shaft periphery, sample all 

icrecelhls portions. Sample all other Joints 

on the pump or rnniprsssor housing when 

leakage could occur. 

d. Pressure Relief Devices The configuration of most pressure relief devices prevents 

PI. 60, Aff. A. Mnth. 21 

apllng at the sealing seat Interface, rot 

those dsvtces equipped with an enclosed extension, or horn, place the probe Inlet st approximately the center of the exhaust area 

to the atmosphere. 

e. Process Drains Par open drains, place 

the probe Inlet at approximately the center 

of the area open to the atamephere. Por 

covered drains, place the probe at the surface of the cover interface aad conduct a peripheral traverse. 

f. Open-Ended Lines or Valvae—Place the 

probe Inlet at approximately the center of 

the opening to tha atmosphere. 

g. Seal System Degassing Vents snd Accumulator Vents—Place the probe lalet at approximately the center of the opening to 

the atmosphere. 

h. Aoceos Door Seal*—'Place the probe 

inlet at the surfscs of the door seal lnterrace and conduct a peripheral traverse. 

4JJ Type n-"No Detectable Emission". 

Determine the local ambient concentreUon around tha source by movtng the probe 

inlet randomly upwind and downwind at a 

distance of one to two meters from the 

source. If an Interference exists wtth this 

determination due to a nearby omission or 

leak, the local ambient concentration may 

be determined at iHifsnraa closer to the 

source, but in no case ahall tha distanos be 

Ism than 25 centimeters. Then mora the 

probe inlet to the surfaoe of tha aouree and 

determine tha concentration described In 

4J.1. Tha difference between then concentrations determiaee whether then an no 

detectable smlsstnns Record aad report the 

raauits as spodflod by tha regulation. 

Por tbooe eeeee when tha regulation requires a specific device Installation, or that 

sperlfled vena be ducted or piped to a central device, tha existence of than conditions 

shall be visually confirmed. Whan the regulation also requires that no detectable emissions exist, visual observations ***** sampling 

surveys are required. Examples of this technlquean: 

(a) Pump or Compressor Seals If applicable, determine the type of shaft seal. Preform a survey of the local ana ambient 

VOC concentration and determine If detectable emission! exist ss dsscrlbsd above. 

(b) Seal System Degassing Vents. Accumulator Vessel Vents. Pressure Relief Devices— 

If applicable, ubasns whether or not the applicable <*tfrtit.f or piping »»•— Also, determine If sny sources exist in the ducting or 

piping when emissions could occur prior to 

the control device. If the required ducting 

or piping exists and then an no sources 

when the innlsslnnt could bo vented to the 

atmoaphen prior to the contrel device, then 

it la preoumsd that no detectable emissions 

sre pfteent. If there are sources la the ducting or piping where wnlseloni could be 

vented or sources where leaks could occur. 
P.41 

Ft. 60, App. A, Moth. 22 40 CFR Ch. I (7-147 IdHtan) 

the sampling surveys dsscribsd In this para- 4.4J Calibration Precision. Make a total 

graph shall be used to determine if detecta- of three measurements by alternately uslna 

ble amissions exist. tan gas and tha specified calibration nL 

4JJ Alternative Screening Procedure. A Record the meter readings, r»trtlatr ^ 

sereenlac procedure based on the formation avenge algebraic difference between the 

of bubbtaa in a soap solution that to sprayed motor readings sad the known value. Divide 

on a potential leak source amy be used for this avenge difference by the known eallthoee souress that do not hare continuously bratlon value and mutlply by 100 to exprsm 

moving porta, that, do not hare surface torn- the moulting calibration precision ss a per 

peraturee grsatsr than the boiling point or —nTarr 

loos than tha traostng point of the soap solu* 4. 0 TTssnonss Time Introduce tare •». 

Uon. that do not have open areas to the at- into the Instrument -"pi« probe. When 

mosphere that the soap solution cannot the meter resiling has stabilised, switch 

brtdga or that do not exhibit evidence of quickly to the nrftflvtl '-'"rrathm ssa 

liquid leakage. Sources that hare then eon- Measure the •*•'"» from switching to whtn 

dlttons present must be surveyed using the 90 potent of the

 nn*i stable reading is at. 

Instrument teehnlquee of 4.3.1 or 4J.2. tainod. Perfuiut *>«*» test sequence three Spray a soap solution over all potential times aad record the results. r

»

lmMint the 

leak mums The soap solution may be a avenge response "~» 

commercially available leak detection solu. . „„,_ . 

Uon or may be prepared using concentrated •»• ototuoropttw 

detergen a squeeaat anbottl d water e my. b Ae usepressur d to dispone e sprayesr th oer span9.1 DuBoas w Pactor. DJL s of VO. anC Analyser d OX Hareta s at a Mete . Re. r 

solution. Obssrve the potential leak sitae to Reading of 10.000 ppmv for Selected Organdetermine If any bubblaa an formed. If no ic Compounda. UA Environmental Proteeabssrvsd. the souree ts pro> Uon Agency. Rseeareh Triangle Park. NC. 

sumsd to ban ao detectable emissions or Publication Na SPA 900/3-41-001. Ssptsmleaks ss applicable. If any bubblae are ob> bar lML 

served, the instrument techniques of 4J.1 or 5J Brown. OX, et al. Reaponaa Pacton 

O l shaU be used to determine if a leak of VOC Analysers Calibrated with Methane 

or if the souree has detectable emie- for Selected Organic Compounda. OS. Envte^QQeBfl&sVasl Pl^OwSsWUOO JkftOCJti RflaMsssTCQ TH" 

4.4 Instrument Evaluation Procedures. At angle Park. NC Publication Na EPA 000/3-

the

 >'i-w

"*t of the liiiiniinsnf perform- 81422. May 1MI. 

evaluation test, assemble snd start up 5 j DuBoee. DJL. et al. Rasponss of Pottthe taatrumsnt smonllng to the manufao- able VOC Aaalysere to Chemical Mixtures, 

turer's Instructions for recommended JJA Environmental Protection Agency, Rewarmup period - and preliminary adjust- March Triangle Park. NC Publication Na 

EPA 000/2-41-110. September 1M1. 4.44 Respanos Motor. Calibrate tha tastrumsnt wtth the ref erenoe compound sa 

specified In the applicable regulation. Por 

each organic spedea that la to be measured 

during Individual source surveys, obtain or 

prepare a known staadard ta air at a coneentntion of tminiilmsislf 80 tww t of 

the applicable leak definition ualsm limited 

by volatility or explostvtty. In then eases, 

a standard at 90 percent of the 

oncentratton. or 70 percent of 

the lower exploatre limit, reepectlvely. Ia> 

troduee this mixture to the analyser and 

record the obasrved meter reading. Intro* 

duoe sera air until a stable reading la obtained. Make a total of three measurements 

by alternating betweea the known mixture 

and sere air. Calculate the responn (actor 

for each repetition and the average response factor. 

Alternatively. If responn factors ban 

boon published for the compounds of interest for the instrument or detector type, the 

response factor determination is not re* 

quired, snd exist mg results may be referenced. Examplae of published responn factors for flame ianhntlon and catalytic oxidation detectors are included In Section 8. 
P.42 

APPENDIX 2 

1.3-BUTADIENE 

FUGITIVE EMISSION MONITORING 

PROTOCOL 
P.43 

24/15/1998 10:55 CHEMICAL MFG ASSOC 202 887 1237 P.02 

DRAFT 

1,3 - BUTADIENE 

FUGITIVE EMISSION MONITORING 

PROTOCOL 

(4/4/88 ) 

1.0 The study will consider all butadiene production facilitiea 

in the United States. Over 90* of the production capacity 

of butadiene is represented by companies that are members 

of the CMA's Butadiene Panel. 

2.0 The study will evaluate fugitive emissions using the four 

approaohes described in Sections 2.2 thru 2.5 of the EPA's 

draft "Protocol for Generating Unit- Specific Emission 

Estimates for Equipment Leaks of VOC and VHAP", dated 

December, 1987, and the "CMA Guidance Por Estimating 

Fugitive Emissions". As an c?tion, some producers may 

choose to develop unit-specific emission correlations -

see Section 9.0, below. If unit specific correlations are 

not developed for the low end of the concentration profile, 

a default value of 8 ppm should be used. 

3.0 All equipment in streams oontaining greater than 5% 

butadiene by weight that are accessible by platform, ladder 

or maalift device up to 40 feet above grade will be 

screened according to the following: 

3.1 Valves — All. 

3.2 Connectors — (includes flanges and screwed fittings) 

Use the following equation to determine the quantity 

(n) to be screened-

(50/N) 

n = N[l -.05 ] 

where N = the number of process conneotors. 

a 

100 

500 

1000 

2000 

3000 

A 

77 

129 

139 

144 

148 

Selection of the connectors to be tested should be 

random. 

Do not include insulated ones due to safety 

considerations. 

If you have a small number of connectors it would be 

wise to screen all of them. 
P.44 

04/15/1988 10:53 CHEMICAL MFC ASSOC 202 887 1237 P.33 

3.3 Pumps — All. On dual seal pumps, the outboard seal 

and/or the barrier fluid reservoir vent (if vented to 

the atmosphere) should be sampled. 

3.4 8afety valves — All, not discharged to a header system 

with an abatement device or protected by a rupture 

disk. 

3.5 Open Ended Lines — All terminal valves and open ended 

lines will be tested except those plugged or blind 

flanged. 

3.6 Compressors -- All. Each seal is separate measurement. 

3.7 Sample Points — Sample points should be screened as 

valves and/or open-ended lines, aa appropriate. A 

description of the method of sampling (e.g. evaauated 

cylinder, closed loop) should be provided. 

4.0 Instruments An Organic Vapor Analyzer, OVA, calibrated 

to methane, will be used. Adjustment must be made for 

appropriate response factor and to assure that the readings 

are compatible with EPA correlations of leak-rate vs. 

concentration (EPA Document Appendix D). The CMA 

contractor will develop response factors for use by the 

facilities performing the study. 

5.0 The procedures in the SPA guidance document (Sections 3.3 

and 3.4) will be followed as close as possible. Absolutely 

no special maintenance should be done prior to testing . 

Testing should not be done in foul weather. The testing 

should be done without interruption. Some of the testing 

will be witnessed by EPA if at all possible. 

Consideration should be given by the locations to having 

State agency personnel also witness the study. Auxiliary 

data including physical state (gas or liquid) and 

butadiene composition should be collected on each 

component. If the unit being tested is under a state 

equipment leak detection and repair program, or under the 

SOCMI New Source Performance Standard the program should be 

described in a separate document and the dates given of the 

last survey. 
P.45 

04/15/1988 10:54 CHEMICAL MFG ASSOC 202 887 1237 P.04 

6.0 The quality assurance measures listed in the EPA guidance 

document (Section 3.5) must be followed. 

7.0 It is recommended that an industrial hygiene survey be made 

during the period of time that the fugitive emission testing 

is being conducted. 

8.0 All participating companies will conduct the screening 

studies upon which the data analysis will be based. 

9.0 Aa a study option, some companies may ohoose to perform 

bagging studies. If done, these studies would follow the 

testing protocols outlined in the SPA and CMA guidance 

documents cited in Section 2, above; 

9.1 Generally 2-9 bags (most likely being 6) will be 

required for each of the source/service types 

listed below: 

- Gas valves 

- Light liquid valves 

- Flanges or other connectors 

- Light liquid pumps 

- Safety valvea 

- Open end lines 

- Compressors 

If the correlation curves developed by this method 

do not agree with the published correlation curves, 

more bagging may be required to develop a data base 

adequate for EPA usage of these new curves. 

9.2 It is suggested that, if bagging is performed by 

any of the participants, the low value or "zero" 

screening components should be emphasized in order 

to avoid the 8 ppm default required by SPA. 

9.3 The vacuum or blow through method of bagging may 

be used. The CMA guidance document should be 

followed as closely as possible. 

10.0 This project will be known as the cooperative CMA Butadiene 

Panel/EPA Butadiene Fugitive Emissions Study. The results 

of the study will be accepted by all parties. 
P.46 

RADIAN 

APPENDIX 3 

INDIVIDUAL PLANT 

SUMMARY DATA TABLES 
P.47 

TABLE M- 1 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 1 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gae) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

1718 

627 

3 

16 

34 

47 

213 

MEAN RAU 

OVA SCREEN 

VALUE 

<«»> 

787 

97* 

11 

5188 

2037 

4681 

1004 

MEAN -

BO 

AMOIMT 

(X) 

54.2 

67.1 

22.7 

55.1 

64.4 

33.1 

51.9 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

WEIGHTED 

SOCMI 

.008456 

.008258 

.051929 

.002037 

.070176 

.001227 

.000949 

CORRELATION 

CURVE 

(EPA) 

.003608 

.001696 

.000041 

.002338 

.046176 

.001501 

.001841 

CORRELATION 

CURVE 

(BO PANEL) 

.003350 

.001665 

.000038 

.002329 

.046173 

.001487 

.001901 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUPMER, 1988 
TABLE A4-2 DISTRIBUTION OP COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 1 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

TOTAL 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

1044 

429 

1 

4 

5 

25 

159 

10 -99 ppm 

293 

97 

2 

6 

7 

11 

43 

100 -999 ppm 

197 

51 

0 

4 

8 

4 

2 

1000 -9999 ppm 

165 

38 

0 

1 

12 

4 

7 

>9999 ppm 

19 

12 

0 

1 

2 

3 

2 

TOTAL 

1718 

627 

3 

16 

34 

47 

213 

1667 459 266 227 39 2656 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

60.77 

68.42 

33.33 

25.00 

14.71 

53.19 

74.65 

10-99 ppa 

17.05 

15.47 

66.67 

37.50 

20.59 

23.40 

20.19 

100-999 ppm 

11.47 

8.13 

0.00 

25.00 

23.53 

8.51 

.94 

1000 -9999 ppm 

9.60 

6.06 

0.00 

6.25 

35.29 

8.51 

3.29 

>9999 ppm 

1.11 

1.91 

0.00 

6.25 

5.88 

6.38 

.94 

62.72 17.27 10.01 8.54 1.47 
TABLE A4-3 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 1 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 630 163 97 108 11 1009 

30X TO 90X 316 152 75 51 10 604 

90X TO 100X 721 144 94 68 18 1045 

TOTAL 1667 459 266 227 39 2658 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT - - - -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 62.44 16.15 9.61 10.70 1.09 

30X TO 90X 52.32 25.17 12.42 8.44 1.66 

90X TO 100X 69.00 13.78 9.00 6.51 1.72 

WEIGHTED AVERAGE 62.72 17.27 10.01 8.54 1.47 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
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P.51 

TABLE A4-5 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 2 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (Ifq) 

VALVE (gaa) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

FLANGE 

NUMBER 

OF 

COMPONENTS 

1311 

191 

16 

1 

21 

21 

MEAN RAU 

OVA SCREEN 

VALUE 

(PP"> 

443 

476 

636 

10 

1079 

481 

MEAN • 

BO 

AMOUNT 

(X) 

44.1 

34.7 

43.1 

7.0 

47.1 

53.1 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.001830 

WEIGHTED 

SOCMI 

.006884 

.004265 

.098656 

.000259 

.051287 

.000973 

CORRELATION 

CURVE 

(EPA) 

.003353 

.000855 

.102482 

.000007 

.040792 

.000416 

CORRELATION 

CURVE 

(BO PANEL) 

.002990 

.000837 

.102454 

.000007 

.040764 

.000467 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
TABLE A4-6 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 2 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

COMPONENT 

TYPE 0-9 ppm 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

FLANGE 

1073 

132 

11 

0 

14 

18 

106 

35 

3 

1 

1 

2 

54 

11 

1 

0 

3 

0 

29 

6 

0 

0 

1 

0 

49 

7 

1 

0 

2 

1 

1311 

191 

16 

1 

21 

21 

TOTAL 1248 148 69 36 60 1561 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

FLANGE 

0-9 ppm 

81.85 

69.11 

68.75 

0.00 

66.67 

85.71 

10 -99 ppm 

8.09 

18.32 

18.75 

100.00 

4.76 

9.52 

100 -999 ppm 

4.12 

5.76 

6.25 

0.00 

14.29 

0.00 

1000 -9999 ppm 

2.21 

3.14 

0.00 

0.00 

4.76 

0.00 

>9999 ppm 

3.74 

3.66 

6.25 

0.00 

9.52 

4.76 

79.95 9.48 4.42 2.31 3.84 
TABLE A4-7 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 2 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 533 116 51 25 29 754 

30X TO 90X 322 32 14 11 20 399 

90X TO 100X 393 0 4 0 11 408 

TOTAL 1248 148 69 36 60 1561 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 70.69 15.38 6.76 3.32 3.85 

30X TO 90X 80.70 8.02 3.51 2.76 5.01 

90X TO 100X 96.32 0.00 .98 0.00 2.70 

WEIGHTED AVERAGE 79.95 9.48 4.42 2.31 3.84 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER. 1988 
P.54 

TABLE A4-B PLANT 2 OAILY CALIBRATION AND DRIFT DATA 

INSTRUMENT NO. 1 

DATE 

5/24/38 

S/2S/88 

5/26/88 

LOH 

LEVEL 

RF 

2.00 

1.90 

1.80 

HED 

LEVEL 

RF 

2.33 

2.22 

2.22 

HIGH 

LEVEL 

RF 

1.43 

1.43 

1.33 

APPLIED 

RF 

1.93 

1.83 

1.78 

CORRELATION 

DRIFT 

TEST 

COEFFICIENT (Z DRIFT) 

0.9994 

0.9993 

0.9994 

0.00 

0.00 

0.00 

INSTRUMENT NO. 2 

OATE 

3/24/88 

3/26/88 

3/31/88 

6/01/88 

6/03/88 

6/06/88 

6/07/88 

6/08/88 

LOH 

LEVEL 

RF 

3.63 

3.83 

4 

HED 

LEVEL 

RF 

3.34 

3.36 

3.92 

HI6H 

LEVEL 

RF 

1.43 

1.43 

1.34 

APPLIED 

RF 

2.87 

2.87 

2.93 

2.93 

2.93 

3.13 

3.13 

3.13 

DRIFT 

CORRELATION TEST 

COEFFICIENT (Z DRIFT) 

0.9987 0.00* 

0.00 

0.9987 0.00 

0.00 

0.00 

0.9987 8.33 

0.00 

0.00 
P.55 

TABLE A4-9 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 3 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

FLANGE 

NUMBER 

OF 

COMPONENTS 

501 

218 

2 

20 

9 

918 

MEAN RAU 

OVA SCREEN 

VALUE 

<PP") 

280 

132 

12 

677 

76 

37 

MEAN -

BO 

AMOUNT 

(X) 

70.6 

69.4 

45.0 

78.2 

69.0 

68.5 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.001830 

WEIGHTED 

SOCMI 

.011021 

.008533 

.103095 

.002893 

.075141 

.001254 

CORRELATION 

CURVE 

(EPA) 

.003723 

.001029 

.000139 

.003434 

.001409 

.000563 

CORRELATION 

CURVE 

(BO PANEL) 

.003260 

.000991 

.000129 

.003411 

.001398 

.000594 

SOURCE: BO PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
TABLE A4-10 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 3 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

COMPONENT 

TYPE 0-9 ppm 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

FLANGE 

371 

172 

1 

8 

3 

820 

84 

32 

1 

5 

3 

77 

28 

10 

0 

4 

3 

15 

8 

2 

0 

2 

0 

4 

10 

2 

0 

1 

0 

2 

501 

218 

2 

20 

9 

918 

TOTAL 1375 202 60 16 15 1668 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

FLANGE 

0-9 ppm 

74.05 

78.90 

50.00 

40.00 

33.33 

89.32 

10 -99 ppm 

16.77 

14.68 

50.00 

25.00 

33.33 

8.39 

100 -999 ppm 

5.59 

4.59 

0.00 

20.00 

33.33 

1.63 

1000 -9999 ppm 

1.60 

.92 

0.00 

10.00 

0.00 

.44 

>9999 ppm 

2.00 

.92 

0.00 

5.00 

0.00 

.22 

82.43 12.11 3.60 .96 .90 
TABLE A4-11 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 3 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT --- : 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 82 3 1 0 0 86 

SOX TO 90X 494 103 29 7 9 642 

90X TO 100X 799 96 30 9 6 940 

TOTAL 1375 202 60 16 15 1668 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 95.35 3.49 1.16 0.00 0.00 

30X TO 90X 76.95 16.04 4.52 1.09 1.40 

90X TO 100X 85.00 10.21 3.19 .96 .64 

WEIGHTED AVERAGE 82.43 12.11 3.60 .96 .90 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
P.58 

TABLE A4-12 PLANT 3 DAILY CALIBRATION ANO DRIFT DATA 

DATE 

3/16/88 

3/16/88 

3/17/88 

3/17/88 

5/18/88 

3/18/88 

3/19/88 

3/19/88 

LOH 

LEVEL 

RF 

4.83 

9.70 a 

2.43 a 

4.83 

3.23 

4.83 

4.83 

4.83 

HED 

LEVEL 

RF 

4.12 

4.30 

4.12 

4.59 

4.30 

4.04 

4.39 

4.70 

HIGH 

LEVEL 

RF 

1.32 

1.33 

1.51 

1.58 

1.53 

1.58 

1.49 

1.53 

APPLIED 

RF 

3.50 

3.37 

3.49 

3.67 

3.02 

3.49 

3.58 

3.70 

CORRELATION 

DRIFT 

TEST 

COEFFICIENT (Z DRIFT) 

0.9984 

0.9983 

0.9984 

0.9983 

0.9983 

0.9985 

0.9982 

0.9982 

NH b 

NH b 

NH b 

NH b 

NH b 

NH b 

NH b 

NH b 

a) Data not uiid to calculati appliid RF. A valui of 4.85 M I 

subititutid at a riasonabli ntiaati of thi loa livil RF. 

b) Siparati iultipoint calibration! w n pirforiid tuici a day. 
P.59 

TABLE A4-13 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 4 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

PUMP 

FLANGE 

NUMBER 

OF 

COMPONENTS 

767 

116 

25 

150 

MEAN RAU 

OVA SCREEN 

VALUE 

<PP»> 

80 

182 

2055 

218 

MEAN • 

BD 

AMOUNT 

(X) 

70.1 

76.9 

75.4 

57.9 

AVERAGE 

SOCMI 

.015600 

.012300 

.108900 

.001830 

WEIGHTED 

SOCMI 

.010938 

.009456 

.082067 

.001059 

CORRELATION 

CURVE 

(EPA) 

.002086 

.001029 

.139400 

.001093 

CORRELATION 

CURVE 

(BO PANEL) 

.002086 

.001029 

.139400 

.001135 

SOURCE: BO PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
TABLE A4-14 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 4 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

COMPONENT 

TYPE 0-9 ppm 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

PUMP 

FLANGE 

0 

0 

0 

0 

757 

114 

18 

144 

3 

0 

1 

3 

2 

0 

1 

1 

5 

2 

5 

2 

767 

116 

25 

150 

TOTAL 1033 14 1058 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

PUMP 

FLANGE 

0 -9 ppm 

0.00 

0.00 

0.00 

0.00 

10--99 ppm 

98.70 

98.28 

72.00 

96.00 

100 -999 ppm 

.39 

0.00 

4.00 

2.00 

1000 -9999 ppm 

.26 

0.00 

4.00 

.67 

>9999 ppm 

.65 

1.72 

20.00 

1.33 

WEIGHTED AVERAGE 0.00 97.64 66 38 1.32 

*D 

b> 
TABLE A4-15 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 4 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 0 124 1 2 2 129 

30X TO 90X 0 518 5 1 8 532 

90X TO 100X 0 391 1 1 4 397 

TOTAL 0 1033 7 4 14 1058 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT - -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 0.00 96.12 .78 1.55 1.55 

30X TO 90X 0.00 97.37 .94 .19 1.50 

90X TO 100X 0.00 98.49 .25 .25 1.01 

WEIGHTED AVERAGE 0.00 97.64 .66 .38 1.32 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER. 1988 

*o 

b> 
P.62 

TABLE A4-16 PLANT 4 DAILY CALIBRATION AND DRIFT DATA 

DATE 

7/01/88 

7/05/88 

7/07/88 

7/06/88 

LOH 

LEVEL 

RF 

1.90 

1.90 

3.80 

1.58 

HED 

LEVEL 

RF 

2.29 

2.29 

3.15 

4.90 

HIGH 

LEVEL 

RF 

2.02 

2.01 

3.16 

2.71 

APPLIED 

RF 

2.07 

2.07 

4.04 

3.06 

DRIFT 

CORRELATION TEST 

COEFFICIENT (Z DRIFT) 

0.9999 0.00 

0.9999 0.00 

0.9994 0.00 

0.9989 0.00 
P.63 

TABLE A4-17 SUMMRY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 5 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

NUMBER 

OF 

COMPONENTS 

1373 

836 

10 

17 

5 

62 

1 

W AN RAW 

OVA SCREEN 

VALUE 

(*•> 

1320 

523 

5 

22 

2011 

218 

21 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY 

MEAN • 

BD 

AMOUNT 

(X) 

58.8 

71.9 

60.0 

64.8 

66.4 

53.5 

20.0 

SUMMERr lVoo 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.108900 

.003700 

.001830 

.502200 

WEIGHTED 

SOCMI 

.009174 

.008838 

.137460 

.070593 

.002457 

.000979 

.100440 

CORRELATION 

CURVE 

(EPA) 

.004211 

.000994 

.000053 

.000168 

.000321 

.001057 

.000025 

CORRELATION 

CURVE 

(BO PANEL) 

.003826 

.000952 

.000005 

.000135 

.000291 

.001117 

.000025 
TABLE A4-18 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 5 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE ppm 

493 

531 

10 

0 

0 

16 

0 

10-•99 ppm 

769 

278 

0 

16 

4 

42 

1 

100 -999 ppm 

46 

15 

0 

1 

0 

1 

0 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

25 

3 

0 

0 

0 

2 

0 

40 

9 

0 

0 

1 

1 

0 

1373 

836 

10 

17 

5 

62 

1 

TOTAL 1050 1110 63 30 51 2304 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

0-9 ppm 

35.91 

63.52 

100.00 

0.00 

0.00 

25.81 

0.00 

10-99 ppm 

56.01 

33.25 

0.00 

94.12 

80.00 

67.74 

100.00 

100-999 ppm 

3.35 

1.79 

0.00 

5.68 

0.00 

1.61 

0.00 

1000-9999 ppm 

1.82 

.36 

0.00 

0.00 

0.00 

3.23 

0.00 

>9999 ppm 

2.91 

1.08 

0.00 

0.00 

20.00 

1.61 

0.00 

45.57 48.18 2.73 1.30 2.21 
TABLE A4-19 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 5 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 189 221 12 5 10 437 

30X TO 90X 405 534 30 17 22 1008 

90X TO 100X 456 355 21 8 19 859 

TOTAL 1050 1110 63 30 51 2304 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT - -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 43.25 50.57 2.75 1.14 2.29 

30X TO 90X 40.18 52.98 2.98 1.69 2.18 

90X TO 100X 53.08 41.33 2.44 .93 2.21 

WEIGHTED AVERAGE 45.57 48.18 2.73 1.30 2.21 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER. 1988 
P.66 

TABLE A4-20 PLANT 5 DAILY CALIBRATION AND DRIFT DATA a) 

LOH 

LEVEL 

RF 

HED 

LEVEL 

RF 

HIGH 

LEVEL 

RF 

APPLIED 

RF 

DRIFT 

CORRELATION TEST 

DATE COEFFICIENT (Z DRIFT) 

ALL DATA 1.73 

a) A iix point calibration H I pirforiid on 9/29/88. aftir thi fiild 

••aiuriiints wi n coiplitid. Daily Hithani calibration and drift 

chick data taken during thi fiild tisting indicatii that thi 

initruiint did not drift siginificantly during thi tu t piriod. 
P.67 

TABLE A4-21 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 6 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

SAFETY VALVE 

PUMP 

NUMBER 

OF 

COMPONENTS 

480 

555 

13 

14 

MEAN RAU 

OVA SCREEN 

VALUE 

(PP»> 

202 

231 

2 

772 

SOURCE: BO PANEL FUGITIVE EMISSIONS STUDY 

MEAN • 

BO 

AMOUNT 

(X) 

62.0 

65.4 

84.0 

62.9 

SUMMER, 1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.108900 

WEIGHTED 

SOCMI 

.009678 

.008045 

.192444 

.068451 

CORRELATION 

CURVE 

(EPA) 

.002151 

.000488 

.000082 

.004365 

CORRELATION 

CURVE 

(BD PANEL) 

.002116 

.000455 

.000023 

.004365 
TABLE A4-22 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 6 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

COMPONENT 

TYPE 0-9 ppm 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

26 

394 

10 

0 

340 

130 

3 

9 

82 

22 

0 

2 

32 

7 

0 

3 

0 

2 

0 

0 

480 

555 

13 

14 

TOTAL 430 482 106 42 1062 

COMPONENT 

TYPE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

5.42 

70.99 

76.92 

0.00 

70.83 

23.42 

23.08 

64.29 

17.08 

3.96 

0.00 

14.29 

6.67 

1.26 

0.00 

21.43 

0.00 

.36 

0.00 

0.00 

WEIGHTED AVERAGE 40.49 45.39 9.98 3.95 .19 
TABLE A4-23 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 6 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 128 177 36 20 0 361 

30X TO 90X 41 46 4 2 0 93 

90X TO 100X 261 259 66 20 2 608 

TOTAL 430 482 106 42 2 1062 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT - -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 35.46 49.03 9.97 5.54 0.00 

30X TO 90X 44.09 49.46 4.30 2.15 0.00 

90X TO 100X 42.93 42.60 10.86 3.29 .33 

WEIGHTED AVERAGE 40.49 45.39 9.98 3.95 .19 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
P.70 

TABLE A4-24 PLANT 6 DAILY CALIBRATION ANO DRIFT DATA a) 

LOH HED HIGH DRIFT 

LEVEL LEVEL LEVEL APPLIED CORRELATION TEST 

DATE RF RF RF RF COEFFICIENT (Z DRIFT) 

ALL DATA 1.82 

a) No calibration data M I lubiittid by thii plant. 

Thi riiponu factor un d Mai dirivid froi aviraging all of thi calibration 

data riciivid at thi ti n of data intry. 
P.71 

TABLE A4-25 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 7 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

NUM8ER 

OF 

COMPONENTS 

2471 

1059 

3 

67 

12 

150 

2 

MEAN RAW 

OVA SCREEN 

VALUE 

(«•> 

390 

202 

26 

1445 

1683 

31 

20 

MEAN • 

BO 

AMOUNT 

(X) 

74.6 

62.1 

72.7 

71.9 

87.1 

69.1 

75.0 

AVERAGE 

SOCMI 

.015600 

.012300 

.003700 

.108900 

.003700 

.001830 

.502200 

WEIGHTED 

SOCMI 

.011630 

.007633 

.002689 

.078262 

.003222 

.001264 

.376650 

CORRELATION 

CURVE 

(EPA) 

.005359 

.000902 

.000069 

.111660 

.004402 

.000211 

.000066 

CORRELATION 

CURVE 

(BO PANEL) 

.004688 

.000860 

.000034 

.111613 

.004341 

.000239 

.000002 

SOURCE: BO PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
TABLE A4-26 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 7 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE ppm 

13 

316 

0 

0 

0 

0 

0 

10--99 ppm 

2269 

705 

3 

52 

10 

146 

2 

100-999 ppm 

64 

12 

0 

2 

0 

3 

0 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

44 

10 

0 

4 

0 

1 

0 

81 

16 

0 

9 

2 

0 

0 

2471 

1059 

3 

67 

12 

150 

2 

TOTAL 329 3187 81 59 108 3764 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

0-9 ppm 

.53 

29.84 

0.00 

0.00 

0.00 

0.00 

0.00 

10-99 ppm 

91.83 

66.57 

100.00 

77.61 

83.33 

97.33 

100.00 

100 -999 ppm 

2.59 

1.13 

0.00 

2.99 

0.00 

2.00 

0.00 

1000--9999 ppm 

1.78 

.94 

0.00 

5.97 

0.00 

.67 

0.00 

>9999 ppm 

3.28 

1.51 

0.00 

13.43 

16.67 

0.00 

0.00 

8.74 84.67 2.15 1.57 2.87 
TABLE A4-27 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 7 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -----

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO SOX 0 332 3 7 2 344 

30X TO 90X 106 1209 38 30 50 1433 

90X TO 100X 223 1646 40 22 56 1987 

TOTAL 329 3187 81 59 108 3764 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -- - -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 0.00 96.51 .87 2.03 .58 

30X TO 90X 7.40 84.37 2.65 2.09 3.49 

90X TO 100X 11.22 82.84 2.01 1.11 2.82 

WEIGHTED AVERAGE 8.74 84.67 2.15 1.57 2.87 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
P.74 

TABLE A4-28 PLANT 7 DAILY CALIBRATION AND DRIFT DATA 

DATE 

7/05/88 

7/08/88 

LOH 

LEVEL 

RF 

1.00 

1.83 

HED 

LEVEL 

RF 

0.97 

1.51 

HIGH 

LEVEL 

RF 

0.87 

0.98 

DRIFT 

APPLIED CORRELATION TEST 

RF COEFFICIENT (Z DRIFT) 

1.20 a 0.9999 NH 

. 1.20 a 0.9999 NH 

a) Host fiild iiaiuriiinti Mi n prior to 7/08/88. 

An RF of 1.2 Mhich ii thi aviragi of all calibration data M M 

appliid to all raH OVA icriining valuii. 
P.75 

TABLE A4-29 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 8 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

1884 

580 

71 

20 

3 

181 

MEAN RAW 

OVA SCREEN 

VALUE 

<«•> 

1210 

3684 

1483 

1050 

10 

15 

t* 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY 

MEAN • 

BO 

AMOUNT 

(X) 

24.5 

23.6 

37.4 

37.0 

54.0 

30.3 

«uMJP-MEKf lTOw 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.108900 

.003700 

.001830 

WEIGHTED 

SOCMI 

.003827 

.002904 

.085709 

.040298 

.001998 

.000555 

CORRELATION 

CURVE 

(EPA) 

.001053 

.002167 

.003247 

.077255 

.000048 

.000154 

CORRELATION 

CURVE 

(BO PANEL) 

.000859 

.002156 

.003221 

.077240 

.000002 

.000268 
TABLE A4-30 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 8 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

COMPONENT 

> TYPE 0-9 ppm 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

933 

283 

31 

8 

0 

88 

834 

212 

33 

7 

3 

90 

67 

37 

5 

3 

0 

2 

20 

24 

1 

0 

0 

1 

30 

24 

1 

2 

0 

0 

1884 

580 

71 

20 

3 

181 

TOTAL 1343 1179 114 46 57 2739 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

VuunrunE.ni 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

49.52 

48.79 

43.66 

40.00 

0.00 

48.62 

10 -99 ppm 

44.27 

36.55 

46.48 

35.00 

100.00 

49.72 

100 -999 ppm 

3.56 

6.38 

7.04 

15.00 

0.00 

1.10 

1000 -9999 ppm 

1.06 

4.14 

1.41 

0.00 

0.00 

.55 

>9999 ppm 

1.59 

4.14 

1.41 

10.00 

0.00 

0.00 

49.03 43.04 4.16 1.68 2.08 
TABLE A4-31 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 8 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 915 1003 72 22 30 2042 

SOX TO 90X 428 176 42 24 27 697 

TOTAL 1343 1179 114 46 57 2739 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 44.81 49.12 3.53 1.08 1.47 

SOX TO 90X 61.41 25.25 6.03 3.44 3.87 

WEIGHTED AVERAGE 49.03 43.04 4.16 1.68 2.08 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
TABLE A4-32 PLANT 8 DAILY CALIBRATION AND DRIFT DATA 

P.78 

DATE 

6/18/88 

6/19/88 

6/20/88 

6/21/88 

6/22/88 

6/23/88 

6/24/88 

6/29/88 

LOH 

LEVEL 

RF 

3.33 

3.33 

3.33 

3.33 

3.33 

3.33 

3.33 

3.33 

NED 

LEVEL 

• RF 

2.36 

2.96 

2.96 

2.96 

2.36 

2.96 

2.36 

2.96 

HI6H 

LEVEL APPLIED 

RF 

2.92 

2.41 

2.92 

2.44 

2.32 

2.92 

2.48 

2.48 

CORRELATION 

COEFFICIENT 

0.9996 

0.9992 

0.9996 

0.9993 

0.9996 

0.9996 

0.9999 

0.9999 

DRIFT 

TEST 

(Z DRIFT) 

10.00 

14.00 

18.00 

8.00 

0.00 

9.00 

11.00 

NH 
P.79 

TABLE A4-33 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 9 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (flat) 

SAFETY VALVE 

PUMP 

FLANGE 

NUMBER 

OF 

COMPONENTS 

266 

62 

9 

3 

158 

MEAN RAW 

OVA SCREEN 

VALUE 

<Pf»> 

9527 

9948 

16 

28 

63 

SOURCE: BO PANEL FUGITIVE EMISSIONS STUDY 

MEAN • 

BO 

AMOUNT 

(X) 

29.4 

44.1 

19.3 

44.5 

33.0 

SUMMER, 1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.108900 

.001830 

WEIGHTED 

SOCMI 

.004588 

.005430 

.044293 

.048424 

.000604 

CORRELATION 

CURVE 

(EPA) 

.005896 

.004547 

.000027 

.000177 

.000226 

CORRELATION 

CURVE 

(BD PANEL) 

.005700 

.004526 

.000012 

.000165 

.000327 
TABLE A4-34 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

COMPONENT 

TYPE 0-9 ppm 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

FLANGE 

189 

41 

8 

1 

145 

10 

3 

0 

2 

4 

26 

6 

1 

0 

6 

13 

6 

0 

0 

3 

28 

6 

0 

0 

0 

266 

62 

9 

3 

158 

TOTAL 384 19 39 22 34 498 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

FLANGE 

0-9 ppm 

71.05 

66.13 

88.89 

33.33 

91.77 

10-•99 ppm 

3.76 

4.84 

0.00 

66.67 

2.53 

100--999 ppm 

9.77 

9.68 

11.11 

0.00 

3.80 

1000 -9999 ppm 

4.89 

9.68 

0.00 

0.00 

1.90 

>9999 ppm 

10.53 

9.68 

0.00 

0.00 

0.00 

77.11 3.82 7.83 4.42 6.83 
TABLE A4-35 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 9 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 122 4 13 9 13 161 

30X TO 90X 262 15 26 13 21 337 

TOTAL 384 19 39 22 34 498 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT - - -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 75.78 2.48 8.07 5.59 8.07 

30X TO 90X 77.74 4.45 7.72 3.86 6.23 

WEIGHTED AVERAGE 77.11 3.82 7.83 4.42 6.83 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 

00 
P.82 

TABLE A4-36 PLANT 9 DAILY CALIBRATION AND DRIFT DATA 

OATE 

7/09/88 

7/06/88 

7/07/88 

7/08/88 

LOH 

LEVEL 

RF 

2.86 

3.33 

3.33 

3.07 

HED 

LEVEL 

RF 

2.67 

2.67 

2.67 

2.63 

HIGH 

LEVEL 

RF 

1.67 

1.67 

1.67 

1.67 

APPLIED 

RF 

2.40 

2.96 

2.96 

2.46 

DRIFT 

CORRELATION TEST 

COEFFICIENT (Z DRIFT) 

0.9999 NH 

0.9999 0.00 

0.9999 0.00 

0.9996 0.00 
P.83 

TABLE A4-37 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 10 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

412 

14 

4 

6 

11 

147 

MEAN RAW 

OVA SCREEN 

VALUE 

<PP»> 

2693 

1578 

60 

1674 

18283 

150 

SOURCE: BO PANEL FUGITIVE EMISSIONS STUDY 

MEAN • 

BD 

AMOUNT 

(X) 

41.6 

40.6 

34.3 

51.0 

51.0 

43.3 

SUMCR, 1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.108900 

.003700 

.001830 

WEIGHTED 

SOCMI 

.006493 

.004999 

.078467 

.055539 

.001887 

.000793 

CORRELATION 

CURVE 

(EPA) 

.003697 

.003703 

.000126 

.081892 

.003099 

.000261 

CORRELATION 

CURVE 

(BO PANEL) 

.003362 

.003678 

.000102 

.081857 

.003072 

.000346 
TABLE A4-38 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 10 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 

137 

7 

1 

4 

5 

75 

10 •99 ppa 

221 

5 

2 

1 

3 

68 

100-999 ppm 

21 

0 

1 

0 

0 

3 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

15 

1 

0 

0 

1 

0 

18 

1 

0 

1 

2 

1 

412 

14 

4 

6 

11 

147 

TOTAL 229 300 25 17 23 594 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

33.25 

50.00 

25.00 

66.67 

45.45 

51.02 

10 -99 ppm 

53.64 

35.71 

50.00 

16.67 

27.27 

46.26 

100 -999 ppm 

5.10 

0.00 

25.00 

0.00 

0.00 

2.04 

1000 -9999 ppm 

3.64 

7.14 

0.00 

0.00 

9.09 

0.00 

>9999 ppm 

4.37 

7.14 

0.00 

16.67 

18.18 

.68 

38.55 50.51 4.21 2.86 3.87 
TABLE A4-39 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 10 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO SOX 0 121 10 6 9 146 

30X TO 90X 229 179 15 11 14 448 

TOTAL 229 300 25 17 23 594 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT --- - -- -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 0.00 82.88 6.85 4.11 6.16 

30X TO 90X 51.12 39.96 3.35 2.46 3.13 

WEIGHTED AVERAGE 38.55 50.51 4.21 2.86 3.87 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER. 1988 

loi 
P.86 

TABLE A4-40 PLANT 10 DAILY CALIBRATION AND DRIFT DATA 

DATE 

6/28/88 

6/29/88 

LOH 

LEVEL 

RF 

2.00 

3.07 

HED 

LEVEL 

RF 

2.36 

2.99 

HIGH 

LEVEL 

RF 

1.67 

1.67 

APPLIED 

RF 

2.08 

2.43 

DRIFT 

CORRELATION TEST 

COEFFICIENT (Z DRIFT) 

0.9999 0.00 

0.9996 0.00 
P.87 

TABLE A4-41 SUMMARV OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 11 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

MEAN RAW MEAN -

NUMBER OVA SCREEN BD CORRELATION CORRELATION 

COMPONENT OF VALUE AMOUNT AVERAGE WEIGHTED CURVE CURVE 

TYPE COMPONENTS (ppa) (X) SOCMI SOCMI (EPA) (BO PANEL) 

VALVE (liq) 135 143 38.4 .015600 .005990 .000779 .000474 

VALVE (gaa) 48 52 42.8 .012300 .005258 .000040 .000014 

FLANGE 136 7 25.6 .001830 .000468 .000055 .000179 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
TABLE A4-42 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 11 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -~-

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 39 92 0 3 1 135 

VALVE (gas) 8 33 6 1 0 48 

FLANGE 80 56 0 0 0 136 

TOTAL 127 181 6 4 1 319 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT - -

TYPE 0-9 ppm 10-99 ppm 100--999 ppm 1000-9999 ppm >9999 ppm 

VALVE (liq) 28.89 68.15 0.00 2.22 .74 

VALVE (gas) 16.67 68.75 12.50 2.08 0.00 

FLANGE 58.82 41.18 0.00 0.00 0.00 

WEIGHTED AVERAGE 39.81 56.74 1.88 1.25 .31 

co 
TABLE A4-43 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 11 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 126 97 6 4 1 234 

30X TO 90X 1 84 0 0 0 85 

TOTAL 127 181 6 4 1 319 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT --- -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 53.85 41.45 2.56 1.71 .43 

30X TO 90X 1.18 98.82 0.00 0.00 0.00 

WEIGHTED AVERAGE 39.81 56.74 1.88 1.25 .31 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
P.90 

TABLE A4-44 PLANT 11 DAILY CALIBRATION AND DRIFT DATA 

DATE 

6/01/88 

6/02/88 

6/03/88 

6/06/88 

6/07/88 

LOH 

LEVEL 

RF 

0.99 

0.79 

1.98 

0.99 

HED 

LEVEL 

RF 

1.00 

1.02 

0.93 

0.93 

HI6H 

LEVEL 

RF 

1.00 

0.99 

0.93 

0.98 

APPLIED 

RF 

1.04 a 

1.04 a 

1.04 a 

1.04 a 

DRIFT 

CORRELATION TEST 

COEFFICIENT (Z DRIFT) 

0.9999 13.70 

0.9999 4.80 

0.9999 9.70 

3.80 

0.9999 7.00 

a) Thi responn factor un d nn an aviragi of all data bicausi no datii 

Niri givin for tost of thi icriining data shifts. Thi riiulting 

aviragi valui of 1.04 had a itandard diviation of 0.29. 
P.91 

TABLE A4-45 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 12 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

3521 

313 

33 

63 

1666 

2534 

MEAN RAW 

OVA SCREEN 

VALUE 

<PP») 

1602 

2003 

61 

6921 

180 

0 

MEAN • 

BO 

AMOUNT 

(X) 

69.4 

61.6 

60.1 

70.9 

68.9 

67.3 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.108900 

.003700 

.001830 

WEIGHTED 

SOCMI 

.010820 

.007575 

.137738 

.077198 

.002550 

.001232 

CORRELATION 

CURVE 

(EPA) 

.003538 

.000994 

.000327 

.047415 

.000089 

.000141 

CORRELATION 

CURVE 

(BD PANEL) 

.002903 

.000954 

.000277 

.047366 

.000031 

.000179 

SOURCE: BO PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
TABLE A4-46 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

12 

COMPONENT 

TYPE 0-9 ppm 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

3336 

294 

32 

52 

1662 

2534 

0 

0 

0 

0 

0 

0 

18 

4 

0 

0 

1 

0 

106 

9 

1 

7 

0 

0 

61 

6 

0 

4 

3 

0 

3521 

313 

33 

63 

1666 

2534 

TOTAL 7910 23 123 74 8130 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE <llq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

94.75 

93.93 

96.97 

82.54 

99.76 

100.00 

10 -99 ppm 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

100 -999 ppm 

.51 

1.28 

0.00 

0.00 

.06 

0.00 

1000 -9999 ppm 

3.01 

2.88 

3.03 

11.11 

0.00 

0.00 

>9999 ppm 

1.73 

1.92 

0.00 

6.35 

.18 

0.00 

97.29 0.00 .28 1.51 .91 

*• 

CO 
TABLE A4-47 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 12 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 706 0 4 6 3 719 

30X TO 90X 5137 0 14 88 64 5303 

90X TO 100X 2067 0 5 29 7 2108 

TOTAL 7910 0 23 123 74 8130 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 98.19 0.00 .56 .83 .42 

30X TO 90X 96.87 0.00 .26 1.66 1.21 

90X TO 100X 98.06 0.00 .24 1.38 .33 

WEIGHTED AVERAGE 97.29 0.00 .28 1.51 .91 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 

Tl 

CO 

co 
P.94 

TABLE A4-48 PLANT 12 DAILY CALIBRATION AND DRIFT DATA 

LOH 

LEVEL 

RF 

HED 

LEVEL 

RF 

HI6H 

LEVEL 

RF 

APPLIED 

RF 

DRIFT 

CORRELATION TEST 

DATE COEFFICIENT (Z DRIFT) 

2.22 a 

a) No calibration data Mai lubiittid by thii plant. 

Thi riiponii factor uiid M I an aviragi of all data froi nini other 

plants. Thi riiulting aviragi valui of 2.22 had a standard 

diviation of 0.73 or 33.1Z. 
P.95 

TABLE A4-49 SUMMARY OF ESTIMATED 1,3-BUTADIENE FUGITIVE EMISSIONS FOR PLANT 13 

EMISSION ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gaa) 

SAFETY VALVE 

PUMP 

FLANGE 

COMPRESSOR 

NUMBER 

OF 

COMPONENTS 

8394 

1696 

267 

97 

6758 

14 

MEAN RAW 

OVA SCREEN 

VALUE 

(PP"> 

2195 

1219 

1217 

3598 

50 

0 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY 

MEAN • 

BO 

AMOUNT 

(X) 

63.3 

62.9 

62.9 

61.8 

60.4 

21.8 

SUMMER, 1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.108900 

.001830 

.502200 

WEIGHTED 

SOCMI 

.009880 

.007739 

.144045 

.067253 

.001106 

.109408 

CORRELATION 

CURVE 

(EPA) 

.003852 

.000987 

.041043 

.027860 

.000191 

.000019 

CORRELATION 

CURVE 

(BD PANEL) 

.003264 

.000943 

.040991 

.027813 

.000244 

.000002 
TABLE A4-50 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 13 

ALL COMPONENTS AND ALL BD CONCENTRATIONS 

TOTAL 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

FLANGE 

COMPRESSOR 

0-9 ppm 

8081 

1653 

263 

87 

6751 

14 

10--99 ppm 

0 

0 

0 

0 

0 

0 

100--999 ppm 

0 

0 

0 

0 

0 

0 

1000-9999 ppm 

109 

20 

0 

6 

3 

0 

>9999 ppm 

204 

23 

4 

4 

4 

0 

TOTAL 

8394 

1696 

267 

97 

6758 

14 

16849 138 239 17226 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

FLANGE 

COMPRESSOR 

0-9 ppm 

96.27 

97.46 

98.50 

89.69 

99.90 

100.00 

10 -99 ppm 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

100 -999 ppm 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

1000 -9999 ppm 

1.30 

1.18 

0.00 

6.19 

.04 

0.00 

>9999 ppm 

2.43 

1.36 

1.50 

4.12 

.06 

0.00 

97.81 0.00 0.00 .80 1.39 
TABLE A4-51 DISTRIBUTION OF RAW OVA SCREENING VALUES BY BD COMPOSITION 

ALL COMPONENTS FOR PLANT 13 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT ---- - — --._----_ _._ 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

5X TO 30X 2518 0 0 36 20 2574 

30X TO 90X 8504 0 0 68 119 8691 

90X TO 100X 5827 0 0 34 100 5961 

TOTAL 16849 0 0 138 239 17226 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

5X TO 30X 97.82 0.00 0.00 1.40 .78 

30X TO 90X 97.85 0.00 0.00 .78 1.37 

90X TO 100X 97.75 0.00 0.00 .57 1.68 

WEIGHTED AVERAGE 97.81 0.00 0.00 .80 1.39 

SOURCE: BD PANEL FUGITIVE EMISSIONS STUDY SUMMER, 1988 
P.98 

TABLE A4-92 PLANT 13 DAILY CALIBRATION AND DRIFT DATA 

LOH 

LEVEL 

RF 

HED 

LEVEL 

RF 

HI6H 

LEVEL 

RF 

APPLIED 

RF 

DRIFT 

CORRELATION . TEST 

DATE COEFFICIENT (Z DRIFT) 

2.22 a 

a) No calibration data M I subiittid by thii plant. 

Thi riiponii factor un d M I an aviragi of all data froi nini othir 

plants. Thi riiulting aviragi valui of 2.22 had a standard 

diviation of 0.73 or 33.1Z. 
P.99 

APPENDIX 4 

BAGGING STUDY DATA 
P.1 

TABLE 

COMPONENT 

TYPE 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

FLN 

BUTADIENE BA66IN6 DATA 

BD ORGANIC 

PHASE (Z) SOLVENT 

L lOOZ NONE 

L 1001 NONE 

8 

L 24Z BENZENE 

L 24Z BENZENE 

CORR 

SCREEN 

VALUE 

(ppi) 

0 

0 

0 

0 

0 

0 

7 

77 

132 

148 

163 

269 

269 

322 

387 

437 

369 

380 

588 

802 

1449 

2019 

BA6 

TEHP 

(dtq F) 

63 

77 

88 

88 

FLOU 

RATE 

(il/iin) 

2000 

2000 

1190 

1130 

BA6 

CONC 

(ppi) 

0 

4 

0 

404 

2490 

CALCULATED 

HASS 

FLON 

(Ib/hrl 

O.OOOE+OO 

O.OOE+OO 

O.OOE+OO 

O.OOE+OO 

O.OOE+00 

O.OOE+00 

1.78E-04 

1.31E-03 

2.03E-03 

2.23E-03 

2.43E-03 

3.67E-03 

3.67E-03 

4.23E-03 

1.19E-03 

3.46E-03 

6.78E-03 

6.B9E-03 

6.96E-03 

B.98E-03 

1.46E-0? 

4.39E-03 

HEASUREO 

HASS 

FLON 

(lb/hr) 

O.OOOE+OO 

4.99E-04 

O.OOE+00 

2.41E-06 

3.01E-04 

O.OOE+00 

2.49E-04 

O.OOE+00 

O.OOE+00 

1.13E-03 

1.04E-O3 

O.OOE+00 

O.OOE+OO 

1.93E-04 

1.82E-04 

O.OOE+OO 

O.OOE+00 

1.69E-04 

O.OOE+OO 

O.OOE+00 

1.30E-03 

1.12E-03 
P.2 

TABLE BUTADIENE BA66IN6 DATA 

COHPONENT 

TYPE 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

VLV 

PHP 

PHP 

OEL 

OEL 

PHASE 

8 

6 

6 

8 

6 

6 

8 

8 

8 

S 

6 

6 

6 

6 

L 

L 

L 

L 

BO 

(Z) 

lOOZ 

lOOZ 

lOOZ 

1001 

24Z 

24Z 

24Z 

24Z 

1001 

1001 

lOOZ 

lOOZ 

lOOZ 

1001 

1001 

1001 

1001 

1001 

ORGANIC 

SOLVENT 

NONE 

NONE 

NONE 

NONE 

BENZENE 

BENZENE 

BUTENES 

BUTENES 

NONE 

NONE 

NONE 

NONE 

NONE 

NONE 

NONE 

NONE 

NONE 

NONE 

SCREEN 

VALUE 

(ppi) 

0 

0 

0 

B 

21 

S89 

946 

1472 

1683 

1689 

2038 

2211 

3363 

4379 

3770 

3793 

3972 

9267 

9397 

12332 

13109 

30229 

0 

0 

0 

0 

0 

0 

0 

0 

17 

67 

730 

989 

1333 

1642 

20 

141 

0 

0 

BA8 

TEHP 

' FLON 

RATE 

(dig F) (il/iin) 

86 

80 

76 

86 

86 

84 

77 

77 

84 

80 

93 

82 

84 

89 

73 

83 

82 

77 

2000 

2000 

2000 

2000 

1130 

1130 

3000 

1130 

2000 

2000 

2000 

2000 

2000 

2000 

2000 

2000 

2000 

2000 

BA6 

CONC 

(ppi) 

4 

8 

93 

68 

1144 

1682 

1911 

3670 

4723 

862 

0 

0 

4 

a 

363 

28210 

4 

4 

CALCULATED 

HASS 

FLON 

(lb/hr) 

O.OOE+OO 

O.OOE+00 

O.OOE+OO 

9.68E-04 

1.36E-03 

7.30E-03 

9.37E-03 

1.13E-02 

2.93E-03 

1.23E-02 

1.33E-02 

1.40E-02 

4.08E-03 

4.62E-03 

2.19E-02 

2.20E-02 

3.34E-03 

2.74E-02 

2.7BE-02 

3.16E-02 

3.44E-02 

4.77E-02 

O.OOE+00 

O.OOE+00 

O.OOE+00 

O.OOE+00 

O.OOE+OO 

O.OOE+00 

O.OOE+00 

O.OOE+00 

1.18E-04 

3.09E-04 

1.62E-03 

2.00E-03 

2.74E-03 

2.84E-03 

1.98E-04 

1.14E-03 

O.OOE+OO 

O.OOE+00 

HEASURED 

HASS 

FLON 

(lb/hr) 

2.17E-06 

4.68E-06 

3.42E-05 

3.91E-03 

3.04E-04 

3.32E-03 

1.44E-03 

O.OOE+OO 

3.04E-04 

4.39E-02 

O.OOE+OO 

4.82E-03 

7.61E-04 

3.17E-03 

6.31E-02 

3.71E-02 

1.40E-03 

6.34E-03 

2.36E-01 

O.OOE+00 

2.72E-03 

5.00E-04 

O.OOE+00 

O.OOE+00 

O.OOE+00 

O.OOE+00 

O.OOE+00 

O.OOE+OO 

2.18E-06 

4.32E-06 

6.13E-04 

8.38E-04 

1.38E-03 

3.14E-03 

2.30E-03 

6.86E-03 

2.13E-04 

1.63E-02 

2.19E-06 

2.33E-06 
P.3 

TABLE - . BUTADIENE BAGGING DATA FOR VALVES IN LIQUID SERVICE 

Component 

Type Phase BD (%) 

Organic 

Solvent 

Screen 

Value 

(ppm) 

Calculated 

Mass Flow 

(lb/hr) 

Measured 

Mass Flow 

(lb/hr) 

Valve 

Valve 

Valve 

Valve 

L 

L 

L 

L 

100% 

100% 

100% 

100% 

None 

None 

None 

None 

0 

0 

0 

0 

0.00E+00 

0.00E+00 

0.00E+00 

9.68E-04 

2.17E-06 

4.68E-06 

5.A2E-05 

3.91E-05 

(Average) Default Mass Flow Rate = 2503E-05 lb/hr 

Default Screening Value = 0.0032 ppm 
P.4 

TABLE BUTADIENE BAGGING DATA FOR VALVES IN GAS SERVICE 

Component 

Type 

Valve 

Valve 

Valve 

Valve 

Valve 

Valve 

Valve 

Valve 

Phase 

G 

G 

G 

G 

G 

G 

G 

G 

BD (%) 

100% 

100% 

100% 

100% 

Organic 

Solvent 

None 

None 

None 

None 

Screen 

Value 

(ppm) 

0 

0 

0 

0 

0 

0 

0 

0 

Calculated 

Mass Flow 

(lb/hr) 

0.00E+00 

0.00E+00 

0.00E+00 

0.00E+00 

0.00E+00 

0.00E+00 

0.00E+00 

0.00E+00 

Measured 

Mass Flow 

(lb/hr) 

0.00E+00 

0.00E+00 

O.OOE+00 

O.OOE+00 

O.OOE+00 

O.OOE+OO 

2.18E-06 

4.32E-06 

(Average) Default Mass Flow Rate - 8.119E-07 lb/hr 

Default Screening Value - 0.013 ppm 
P.5 

TABLE BUTADIENE BAGGING DATA FOR FLANGES 

Component 

Type 

Flange 

Flange 

Flange 

Flange 

Flange 

Flange 

Flange 

Phase 

G 

G 

G 

L 

G 

L 

G 

BD (%) 

100% 

100% 

Organic 

Solvent 

None 

None 

Screen 

Value 

(ppm) 

0 

0 

0 

0 

0 

0 

0 

Calculated 

Mass Flow 

(lb/hr) 

0.000E+00 

0.00E+00 

0.00E+O0 

0.00E+00 

0.00E+00 

O.OOE+OO 

1.78E-04 

Measured 

Mass Flow 

(lb/hr) 

0.000E+00 

4.99E-04 

O.OOE+OO 

2.41E-06 

5.01E-04 

O.OOE+00 

2.49E-04 

(Average) Default Mass Flow Rate = 1.788E-04 lb/hr 

Default Screening Value = 6.75 ppm 
P.6 

TABLE BUTADIENE BAGGING DATA FOR OTHER COMPONENTS 

Screen Calculated Measured 

Component Organic Value Mass Flow Mass Flow 

Type Phase BD (%) Solvent (ppm) (lb/hr) (lb/hr) 

Open Ended 

Line L 

Open Ended 

Line L 

100% 

100% 

None 

None 

0.00E+00 

0.00E+00 

2.19E-06 

2.35E-06 

(Average) Default Mass Flow Rate = 2.269E-06 lb/hr 

Default Screening Value = 0.14 ppm 
P.7 

APPENDIX 5 

BD FUGITIVE EMISSIONS SURVEY 
P.8 

BD FUGITIVE EMISSIONS SURVEY: 

WORK PRACTICES/OPERATION PROCEDURES/DESIGN GUIDELINES 

IN THE BUTADIENE PRODUCTION INDUSTRY 

Survey Guidelines 

These questions will be used by the contractor and the Butadiene Panel to 

explain the low fugitive emissions results observed in our fugitive emissions 

study and to serve as a starting point for discussing programs to assure low 

fugitive emissions from butadiene facilities through the Butadiene Panel. In 

accord with our ongoing cooperative agreement with the U.S. Environmental 

Protection Agency, the EPA will have access to the reported programs, and will 

participate in discussing the results. 

It is expected that a response to the questions will require more 

discussion than can be provided on this survey form. Please attach the 

additional response, as needed. It is also recommended that programs or 

guildelines, which are in writing, be included in the response to this survey. 

GENERAL 

What is the name plate capacity of the BD Production Facility? 

Summarize the number of components in the unit that contain 

butadiene. 

<1X 2 to 10X »10X 

Gas Valves 

Liquid Valves 

Gas Flanges 

Liquid Flanges 

Pumps 

Compressors 

Open-Ended Lines 

Connectors 

Sample Points 

Safety Relief Valves 

If the concentration of butadiene changes through the production unit, 

explain the spatial distribution of the concentrations. Please attach a 

diagram if appropriate. 

3. Existing Regulations 

Summarize the number of components above that are monitored under an 

existing state/federal/local fugitive emissions program. 

<ll 2 to 10X »10X 

Gas Valves 
P.9 

Liq Valves 

Gas Flanges 

Liq Flanges 

Pumps 

Compressors 

Open-ended Lines 

Connectors 

Sample Points 

Safety Relief Valves 

MONITORING PROGRAMS 

Please present a detailed summary of any program that you 

have that will tell when a leak has occurred «von though it 

may not identify the specific piece of equipment leaking 

(area monitoring, strong odor, etc.). Please discuss number, 

location, frequency, etc., and provide a diagram if possible. 

Once a leak is believed to exist, describe the mechanism you 

use to identify the specific equipment leaking (organic 

analyser, soap bubbles, alarms, etc.). 

6. Discuss tha special procedures that you use to check or 

prevent equipment types from leaking, or minimi7.0 the impact 

of a leak. Discuss the components to which th<»*« programs 

would apply. 

Gas Valves 

Liq Valves 

Gas Flanges ._ 

H q Flanges 

Pumps 

Compressors 

Open-ended Lines 

Connectors 

Sample Points 

Safety Relief Valves 

Do you have a written requirement in your process operating 

procedures relating to leak inspection? Please 

describe. (If possible, please attach.) To what portion of 

the unit, or components, does it apply? 
P.10 

Please answer the following questions with respect to this written 

program? 

a. How much of the unit is covered under the inspection 

program? 

All 

Components on streams with EO greater than % 

Components on Critical Parts of the unit? 

Please describe in detail. 

b. What is the normal inspection frequency (i.e., 8 hr, 

24 hr, weekly, etc.)? 

c. During inspection, what is the mechanism used to 

determine that a leak has occurred? 

d. How is the specific leaky component identified? 

e. How are records of the inspection maintained? 

Do you also have an informal procedure for leak inspection? 

Describe how it complements the written program outlined 

above. 

Please discuss the following amis with rnspnct to thn informal 

program. 

a. How much of the unit is covered under thn inspection 

program? 

All 

Components on stream with EO greater than 7, 

Components on Critical Parts of the unit? 

Please describe in detail. 

b. What is the normal inspection frequency (i.e., 8 hr, 

24 hr, weekly, etc.)? 

c. During inspection, what is the mechanism used to 

determine that a leak has occurred? 
P.11 

d. How is the specific leaky component identified? 

e. How are records of the inspection maintained? 

9. After process shut-down, describe any special leak checks 

performed before start-up. 

10. After process shut-down, describe any special leak checks 

performed after start-up. 

MAINTENANCE 

11. Describe the procedure you use to maintain/correct or repair 

equipment when a leak is found? Discuss if the maintenance 

is: 

Immediate 

Within 

At Next Shutdown 

12. Describe how on-line maintenance is done on equipment likely 

to leak. 

13. If repairs cannot be completed on-line or are unsuccessful is 

there a plan to shut down a portion of the units for repair? 

Please describe. 

Discuss how the seriousness of the leak relates to the repair time. 

PROCESS DESIGN AND EQUIPMENT SPECIFICATIONS 

14. Are the potential for equipment leaks a factor in process 

design? 
P.12 

Please describe how the following factors affect equipment design. 

Toxicity 

Explosion potential 

Product loss 

Energy Savings 

15. Please describe how the use of specific components are 

impacted by equipment leak potential. 

Consider the following factors: 

a. Describe how the toxic or explosive potential of this 

chemical is taken into account in design specifications. 

b. Describe the conditions under which special design 

specifications (ASTM for example) would be used in this 

unit (temperature, pressure, percentage in line, etc.). 

c. Are vendors' operations periodically inspected to insure 

product quality? 

d. Are components from the vendor periodically tested for 

leak tightness? 

16. Discuss how components are tested before installation in this 

process? 

17. Discuss any other quality control steps taken during 

construction to assure low leakage potential (i.e., weld 

x-ray and interpretation, check valve packing, pressure or 

hydrostatic testing, special installation guidelines, etc.) 

18. Since beginning operation, discuss any equipment changes that 

have been made to reduce leaks (i.e., use of improved valve 

packing, changing of gaskets, replacements of one brand of 
valves with another valve type). Discuss If notable 

reduction in equipment leakage resulted from the changes.