OAR Box 1168 

Prepped by Ollie Stewart 

Document Number: 

68) lll-B-3 

Docket Number: 

A-89-10 

Printed 4/29/2008 11:23:18 AM Sheet 68 of 131 

p.1 
P.2 

^ ^ Y 

CORPORATIO N 

MEMORANDUM 

lin n m A-89-10 

II-B-3 

FEB |/f 091 

TO: Bob Ajax, EPA/SDB j 

FROM: Ed Moretti, Radian/RTP j EP A AIR DOCKE T j 

DATE: October 12, 1989 

SUBJECT: Qualitative Analysis of Equipment Design Specifications and Work 

Practices for Butadiene, Ethylene Oxide, and Phosgene Facilities 

The purpose of this memorandum is to summarize the results of a 

qualitative analysis of the equipment design specifications and work 

practices for butadiene (BD), ethylene oxide (EO), and phosgene facilities. 

From Figure 1, the BD and EO facilities having the highest and lowest 

leak frequencies for gas valves were identified. One EO and three BD 

facilities were grouped as high-leaking facilities and one BD and three EO 

facilities were grouped as low-leaking facilities. Three phosgene 

facilities also were selected for comparison to the BD and EO facilities. 

The following equipment design specifications and work practices were 

analyzed: 

• gas valve body material; 

• gas valve packing material and shape; 

• gas valve manufacturer; 

• gas valve type; 

• gas valve age; 

• gas valve maintenance frequency; 

• plant area monitoring systems; 

• non-specific equipment monitoring (e.g., plant walkthroughs with a 

portable organics detector, visual inspections of equipment); 

• component-specific leak detection and repair; 

• extent of on-line repair; 

• recourse for unsuccessful on-line repair; 

• miscellaneous equipment design specifications and emission reduction 

strategies; 

• minimization of leaks as a factor in plant construction; 

t leak testing of pre-installed equipment; 

• QA/QC steps for reducing leaks during plant construction; and 

• equipment changes made to reduce equipment leaks. 

Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park, N.C. 27709/(919)541-9100 

. 
>» 

u 

c 

4) 

tr 

« i_ 

_L 

-_. 

o 

ID 

_J 

10 ~I 

1 

8 -j 

7 H 

4 H 

2 -! 

Leak Frequency 

Gas Valves 

e5 

"i i i i i i i i—i—i—i—i—i—r - ^ 

P-int, 

pur if 

K il-.iK.li m _ e6e4p6p8e1e2b7p2p4p1p10p7p5e7p9p li p 3 e8e3b6e10b4b5b9b3b8b2b1b12e9b1b10 

Plant 

Figure 1. 
P.4 

These parameters were requested by the EPA in a letter sent to BD, EO, and 

phosgene producers. 

Table 1 provides a qualitative analysis of the gas valve information 

listed above. Few differences can be observed among the facilities. 

Preliminary observation of the information yields the following: 

o most low-leak and phosgene facilities appear to use higher 

percentages of stainless steel gas valves than high-leak facilities; 

and 

o low-leak and phosgene facilities appear to use higher percentages of 

plug gas valves than high-leak facilities. In the phosgene 

facilities, plug valves account for more than half of all gas valve 

types. 

Table 2 summarizes the remaining work practices and equipment design 

specifications information listed above. These parameters encompass all 

equipment types, not gas valves only. Again, few differences can be 

observed among the plants. Preliminary observation of the information 

yields the following: 

o low-leak facilities appear to be slightly more conscientious in 

their non-specific equipment monitoring. Two low-leak facilities 

perform periodic plant walkthroughs with a portable organics 

detector (one high-leak facility also performs this activity), and 

visual inspections appear to be slightly more frequent at low-leak 

and phosgene facilities; 

o EO facilities tend to shut down leaking equipment immediately after 

an unsuccessful on-line repair attempt, while BD facilities do not 

remove the equipment from service but include the leaking equipment 

on a shutdown work list; and 

o low-leak and phosgene facilities provided more thoughtful responses 

to the questions regarding: 1). QA/QC steps for reducing leaks 

during plant construction and 2) equipment changes to reduce 

equipment leaks. Low-leak and phosgene facilities appear more 

conscientious about reducing equipment leak emissions by providing 

operator training on proper operation practices and by experimenting 

with different equipment designs and construction materials. 
Table 1. 

QUALITATIVE ANALYSIS OF F0LLO--U. 114 LETTER 

Gas Valves 

Body llaterial 

Packing 

llaterial and 

Shape 

Manufacturer 

Valve Type 

Age 

Maintenance 

Frequency 

BD-10 

201 SS 

801 CS 

331 each 

Asbestos, 

Graphite, 

and Teflon 

14 diff. oaouf. 

981 6ate 

21 Control 

11-15 yr 

OirectedAs needed 

High BD 

BD-ll 

201 SS 

801 CS 

1001 Asbestos 

1001 Square 

Majority Saith, 

Henry Vogt 

301 Gate 

601 61obe 

51 Ball 

SI Control 

901 16-20 yr 

101 > 20 yr 

OirectedAs needed 

60-12 

201 SS 

801 CS 

U l Teflon 

881 GraphiteAsbestos 

11 Plastic 

18 diff. aanuf. 

Majority Vogt, 

Saith 

641 Gate 

51 Globe 

201 Ball 

111 Control 

121 11-15 yr 

881 > 20 yr 

DirectedAs needed 

High E0 

. EO-9 

301 SS 

701 CS 

1001 teflon 

1001 Square 

901 Slith-Vogt 

101 Assorted 

801 Gate 

101 Ball 

101 Control 

401 6-10 yr 

601 16-20 yr 

DirectedAs needed 

Lou BD 

BD-7 

21 SS 

981 CS 

951 Asbestos 

51 Asbestos/ 

Graphite 

15 diff. unuf. 

971 Gate 

31 Ball 

101 0-5 yr 

171 6-10 yr . 

731 16-20 yr 

DirectedAs needed 

ED-1 

1001 SS 

871 Graphite 

71 Teflon 

61 Unknoun 

171 Saith, 131 

Ladish, U l Kit. , 

101 Bonney, 

9 others 

761 Gate, 71 

Needle, 41 Plug, 

21 Check, 21 

Ball, 81 Control 

14X 0-5 yr 

61 6-10 yr 

801 16-20 yr 

OirectedAs needed 

LOR E0 

EB-2 

571 SS 

431 CS 

561 Teflon 

441 Graphite 

541 Square 

341 O-Ring 

Unknown 

501 Sate 

281 Ball 

171 Needle 

41 Globe 

611 0-5 yr 

41 6-10 yr 

341 11-15 **r 

OirectedBuarterly 

EO-4 

21 SS 

981 Forged Steel 

1001 Teflon 

201 each Vogt, 

Saith, Crane, 

Poeell, Nalaorth 

1001 Gate 

1001 11-15 yr 

DirectedAs needed 

Phosgene 

P-3 

91 SS 

911 CS 

841 Teflon 

161 TFE 

871 Vee 

131 Braid 

441 Tufline 

U I Jaae-bury 

101 Durco 

10 other lanuf. 

521 Plug, 201 Ball 

U I Bate, Bl Needle 

41 BellOHS, 21 6lobe 

11 Control 

161 0-5 yr 

101 11-15 yr 

741 16-20 yr 

Unknonn 

Phosgene 

P-5 

401 SS 

601 CS 

1001 Teflon 

1001 Square 

Ourco, Hills 

NcCanna, 

Tufline 

801 Plug 

151 Ball 

51 Control 

1001 < 5 yr 

Annually 

Phosgene 

P-10 

921 SS 

BI Forged Steel 

1001 Teflon 

621 Ourco 

81 Vogt 

301 tlnknoun 

621 Plug 

81 Gate 

301 Angle 

Uoknoan 

Unknonn 
Table 2. 

QUALITATIVE ANALYSIS OF FOLLON-UP 114 LETTER 

Gas Valves 

Area Monitoring 

Systea 

Non-specific 

Equipaent 

Monitoring 

Componentspecific LDAR 

Extent al 

on-line repair 

Recourse for 

unsuccessful 

on-line repair 

BD-10 

80 Gas detectors 

at 80 locations 

throughout plant 

Taice daily 

visual inspection 

of operating 

equipaent 

Weekly visual 

inspection of 

puaps 

6V - Monitored 

once per qtr. per 

state reg 

LV - Monitored 

once per yr per 

state reg 

Puaps - Monthly 

TLV aonitoring 

Coapooents under 

Bz NESHAP are 

aonitored per 

that reg 

Valves -

Tighten packing 

bolts 

Flanges -

Tighten flange 

bolts 

Reaove equipaent 

froa service, if 

possible; if not, 

add to shutdoan 

aork list 

High BD 

BD-U 

BO Bas detectors 

at 80 locations 

throughout plant 

Daily visual 

inspection of 

coaponents 

Coaponents under 

Bi NESHAP are 

aonitored per 

that reg 

Valves -

Tighten packing 

bolts; inject 

sealant 

Flanges -

Tighten flange 

bolts 

Include on a 

shutdoan aork 

list 

BD-12 

80 Gas detectors 

at BO locations 

throughout plant 

Taica daily 

visual inspection 

of coaponents 

Coaponents under 

Bz NESHAP are 

aonitored per 

that reg 

Valves -

Tighten packing 

bolts 

Include on a 

shutdoan aork 

list 

High EO 

£0-9 

Visual inspection 

of all puaps 

several tiaes 

per shift 

Nalkthrough aith 

portable detector 

once per shift 

6V >101 EO -

Monitored once 

per qtr. per 

state reg 

LV >10I EO -

Monitored once 

per yr. per 

state reg 

Flanges -

Tighten flange 

bolts 

Unit or part of 

unit is shut 

doan ieaediately 

and equipaent 

is repaired 

Loa BD 

BD-7 

45 Gas detectors 

at 45 locations 

throughout plant 

Visual inspection 

of coaponents 

taice per shift 

Coaponents under 

Bz NESHAP are 

aonitored per 

that reg 

Valves -

Tighten packing 

Reaove equipaent 

froa service per 

standard safety 

procedures; 

repaired by 

trained craftsaen 

EO-1 

37 6as detectors 

at 37 locations 

throughout plant 

Daily aalkthrough 

aith IMu to ensure 

aabient readings 

< 50 ppav 

GC for continuous 

aonitoring of 

control rooa and 

analyzer building 

Valves -

Monitored 

eonthly/quarterly 

aith TLV 

Puaps - Monitored 

aeekly aith TLV 

Consultant 

retained to claap 

leaking equip, 

to stop leak 

until shutdoan 

Reaove equipaent 

froa service to 

repair leak 

Loa E0 

EO-2 

6as detectors 

throughout 

plant 

Meekly visual 

inspection of 

puaps 

Valves, Puaps -

Monitored 

quarterly by 

contractor 

Periodic 

aonitoring of 

flanges by 

operating crea 

Puaps -

Saitch to 

spare 

Shut doan 

affected portions 

of plant and 

repair leak 

Phosge 

E0-1 P-3 

Halkthrough 

aith TLV once 

per shift 

• 

Valves - Tighten 

packing bolts 

Flanges -

Tighten flange 

gasket 

Puaps - Saitch 

to spare 

Plant is shut 

doan if severe 

leaks cannot be 

repaired 

e Phosgene 

P-5 

Phosgene 

P-10 

Visual, olfactory 

inspection of 

plant once 

every tao hours 

Phosgene badges 

aorn by all 

eaployees 

Flanges -

Tighten flange 

bolts 

Puaps and 

Agitators -

Adjust seals 

Unit is shut 

doan coapletely, 

leaking coaponent 

is evacuated; 

aashed, dried, 

then repaired 

•a 

len 
Table 2 (Continued). 

QUALITATIVE ANALYSIS OF FOLLON-UP 114 LETTER (continuedl 

Gas Valves 

_____=__=_!_____ 

Equipaent design 

specifications 

(or eaission 

reduction and 

aiscellaneous 

eaission 

reduction 

strategies 

==__=________==_==_ 

BD-10 

None given 

_=______;___________-_ 

High BD 

BD-U 

None given 

__-=_=________._________s________ = : 

High EO 

BD-12 E0-9 

None given Puaps -.Dual 

seals aith 

barrier fluid; 

pressure alara in 

control rooa if 

inner seal leaks 

Valves - All are 

disasseabled 

prior to 

installation 

to verify valve 

stea packing and 

to ensure tbat a 

-_____==_==____=__ 

Loa BD 

BD-7 

Use of coapaoyapproved specs. 

for construction 

aethods and 

aaterials 

Use of skilled 

craftsaen for 

repairs 

Operator training 

to detect and 

react to leaks 

nea gasket aeeting Puaps - Tandra 

specifications is 

installed 

Flanges/Conn. -

Gaskets have 

aelded tabs to 

verify use of 

proper gasket; 

flanges are 

torqued aith 

torque arench; 

Open-ended LinesAll are plugged 

prior to placing 

in service 

Relief Valves -

Reaoved froa unit 

seals aith 

pressure alaras; 

eaissions 

relieve to flare 

systea 

Relief Valves - . 

Relieve to flare 

systea 

Closed-loop 

saapling systeas 

and tested annually; 

rescreened after 

release to ensure 

proper reseating 

Compressors -

Nitrogen buffer 

to prevent 

ataospheric 

leakage; all are 

overhauled every 

five years 

___-=--___3=__--- _ 

EO-1 

Puaps - Gas 

aonitors on 

seals; currently 

installing 

sealless puaps 

Valves -

Tighten packing 

if screening 

values exceed 

300 ppa; 

Grafoil ribbon 

packing in al l 

valves 

Flanges -

Stainless steel, 

Grafoil-filled 

gaskets aith 

inner and 

outer rings 

Open-ended LinesDouble valves 

=__=____=__=___=__ 

Loa EO 

EO-2 

Compressors -

Barrier gas 

Tao aechanics 

accoapany 

contractor 

during screening 

and fi * leaks 

ieaediately, 

if possible 

___==_______=__z____=: 

E0-4 

Open-ended LinesCaps or plugs 

required 

Flanges -

Teflon-filled, 

spiral-mund 

gaskets 

Valves -

Teflon valve 

packings and 

Teflon valve 

bonnet gaskets 

=S_______=__3=__ 

Phosgene 

P-3 

_________ ________ 

Phosgene 

P-5 

__=____-=_________=_ 

Phosgene 

P-10 

Puaps - Dual 

aechanical seals 

aith pressure 

indicators on 

the inner seal 

Relief Valves -

Socks placed over 

relief stack to 

indicate if i t 

has bloan 

Agitator Seals -

Dual aechanical 

seals aith 

barrier fluid 

TJ 

^1 
Table 2 (Continued) 

DUALITATIVE ANALYSIS OF FOUON-UP 114 LETTER 

Gas Valves 

Miniaization of . 

leaks a (actor 

in plant design?. 

Leak testing 

before 

installation? 

OA/PC steps lor 

reducing leaks 

during plant 

construction 

Equipaent 

changes to 

•educe equipaent 

leaks 

BD-10 

No 

All coaponents 

None given 

None given 

High BD 

BD-II 

No 

All coaponents 

None given 

None given 

BD-12 

Yes 

All coaponents 

None given 

None given 

High EO 

EO-9 

Yes 

All coaponents 

Hiniaize (langes 

None given 

Loa BD 

BD-7 

Yes 

All coaponents 

Nelds are: 

I-rayed and 

dye-checked. 

Hydrostatic 

testing 

Ultrasonic 

testing 

Miniaization of 

fittings - aore 

aelded connections 

Metal, spiral-

•ound gaskets 

for flanges 

Send relief valve 

discharges to 

flare systea 

EO-1 

Yes 

All coaponents 

nitrogen pressure 

tested folloaed 

by soap bubble 

testing 

Visual inspection 

of aork 

Spot I-rays of 

aelds 

Spot hydrostatic 

testing of equip 

Replaced tao 

puaps aith 

sealless puaps 

aith good results 

Reduce nuaber 

of flanges 

ahere possible 

Reaove 

unnecessary 

bleed valves 

Loa EO 

EO-2 

Yes 

All coaponents 

Nelds are 

I-rayed 

All equip, and 

piping is 

leak tested 

aith inert 

gas or 

hydrostatically 

tested 

Outside bolting 

services to 

tighten critical , 

large flanges 

Screaed 

connections are 

backaelded 

EO-4 

Yes 

All coaponents 

'Leak reduction 

over the past 

10-15 years has 

been driven by 

OSHA regulations 

and area 

aonitoring' 

Phosgene 

P-3 

' 

Phosgene 

P-5 

Phosgene 

P-10 

Yes 

All coaponents 

Training of 

aaintenance and 

construction 

personnel to 

use proper 

installation 

procedures 

Hydrostatic . 

testing of all 

piping systeas 

Replaced glass 

pipe aith 

Teflon-lined 

steel pipe 

Installed 

Teflon-lined 

valves, gaskets, 

puaps 

Revised piping 

systea to reduce 

nuaber of flanges 

Installed dual 

aechanical seals 

on puaps 

Increased operator 

knoaledge through 

training on 

proper operation 

practices 

00