p.1 

OAR Box 1208 

Prepped by Ollie Stewart 

Document Number: 

119) ll-E-5 

Docket Number: 

A-89-10 

Printed 5/9/2008 10:08:23 AM Sheet 119 of 127 
... 

LAW OFFICES 

PHILIP J. HARTER 

SUITE 404 

2301 M STREET. N.W. 

WASHINGTON. D.C. 20037 

(202) 887-1033 

FAX: (202) 887.1036 

October 5, 1989 

MEMORAND U 

P.2 

A-89-

41 i 

II-E- 5 

C.JLiJlJJjiji; 

EPA AIR DOCKET 

To: EPA Negotiated Rulemaking Committee on Fugitive Emissions from Equipment 

Leaks and Interested Parties 

Fr: Philip J. Harter 

Re: Minutes of September 27-28 Meeting; Future Meetings 

I enclose the minutes of the September 27-28 meeting that were prepared by Radian 

Corporation under contract to EPA. The minutes also include the documents that were 

distributed at the meeting, the Resource Pool Protocols, and a list of committee members. I am including the revised Draft Organizational Protocols (Attachment 5 to the 

minutes); I hope I captured the spirit of the discussions on Thursday, but please read 

them carefully to be sure. I am also enclosing a slightly expanded list of committee 

members that defines who various committee members represent and staff to whom 

materials should be sent for broad distribution within an organization. 

There will be a workgroup meeting on Tuesday, October 24 at EPA in Durha*m. 

The address is the Mutual Building, 411 W. Chapel Hill Street. It will begin at 10:00. 

The meeting will address technical issues, including what data is available, what data is 

needed, and modeling approaches to MACT. All committee members are welcome. 

The next committee meeting will be on November 6 and 7. It will be at the Picket 

Suite Hotel, 2515 Meridian, Durham, NC 27713; 919-361-4660. A block of rooms has 

been reserved; when making a reservation, say you are with the "EPA Fugitives" meeting. Please call soon to make reservations. The meeting will begin at 10:00 on Monday, November 6 and will run until 5:00; we will begin at 9:00 on Tuesday and conclude at 4:00. 

The committee also scheduled meetings for December 6-7 and January 17-18 at 

places to be determined. 
P.3 

REGULATORY NEGOTIATION MEETING ON FUGITIVE EQUIPMENT LEAKS 

SEPTEMBER 27-28, 1989 

QUALITY HOTEL-CAPITOL HILL 

WASHINGTON, D.C. 

DRAFT MEETING MINUTES 

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

issues discussed and to provide an informal record of decisions as they 

pertain to schedules, action items and preliminary committee directions. 

These summary notes are organized chronologically using the meeting agenda as 

a guideline. All presentation materials distributed during the two-day 

meeting are attached, and include: 

Attachment 1 

Attachment 2 

Attachment 3 

Meeting Agenda 

Attendance List September 27, 1989 

Background Briefing: Handout prepared by EPA 

"Equipment Leak Regulatory Negotiation" 

Attachment 4: List of Committee Members 

Attachment 5: Draft Organizational Protocols (Revised based 

on September 28 discussions) 

Attachment 6: Resource Pool Protocols 

Attachment 7: Negotiation Workshop Agenda:• Outline of topics and 

activities covered in session by Jonathan Marks, 

ENDISPUTE, Incorporated 

Attachment 8: Emission Estimation Briefing: Handout prepared by EPA 

"Proposed Refinements to EPA Procedures for Estimating 

Equipment Leaks" 

Wednesday. September 27 

Background Briefing: 

- Bob Ajax of EPA gave a presentation (Attachment 3) on equipment leaks 

and the role of the Regulatory Negotiation (Reg Neg) Committee. 
P.4 

• As described, the scope of the Reg Neg Committee is to address 

Equipment Leaks with respect to three areas: 

1) Emission Factors and Estimating Techniques 

2) Standards Reflecting MACT 

3) Format for Risk-based Standards 

• EPA will use the Reg Neg agreements on equipment leaks as the 

basis for the proposed rulemaking for the Hazardous Organic 

NESHAP (HON) categories. 

The Reg Neg Committee's mission is to define Maximum Achievable 

Control Technology (MACT) consistent with the technology-based 

standard approach outlined in the Administration's proposed amendments 

to Section 112 of the Clean Air Act [House Bill - H.R. 3030 and Senate 

Bill - S.1490]. 

EPA expects that the standard will apply to sourco categories 

set forth in the proposed Clean Air Act Amendments, instead of 

a limited number of listed pollutants. The standards will be 

technology-based, not risk-based. 

Committee Composition: 

- There was an open discussion involving committee members and 

observers to determine if all possible interests were 

represented by the Reg Neg Committee. There were no additional 

interests identified and no objections to the committee composition. 

The committee members and their affiliations, including the 

facilitator, are listed in Attachment 4. 
P.5 

Four general interests are represented on the Reg Neg Committee: 

1) Industry (including chemicals, 

pharmaceuticals, rubber, and oil) 

2) State/Local Government 

3) Environmental Groups 

4) EPA 

Nicholas Garcia from Office Of Management and Budget is participating 

in the Reg Neg proceedings as an observer. 

Two groups with specific interests were present and expressed a desire 

to participate as observers. These parties include: 

1) The American Petroleum Institute 

2) Independent Liquid Terminals Association 

Organizational Protocol: 

- A draft organizational protocol was distributed and discussed. 

Committee members and observers proposed revisions to several 

clauses, and discussions on those proposed revisions followed. 

Based on the proposed revisions and committee comments, a revised draft 

protocol was distributed on Thursday, September 28. Discussions on 

Thursday continued with recommendations for further revisions. 

Attachment S contains a revised draft protocol reflecting the changes 

proposed in the Thursday, September 28, discussions. 

Resource PooX 

- Resource pool protocols were distributed, and a copy is included 

as Attachment 6. 
P.6 

- A brief overview of the resource pool was provided. The purpose of the 

pool is to provide funds for short-term research or technical support, 

and to defray extraordinary expenses associated with participation in 

the negotiations. 

Workshop on Negotiation 

- Jonathan Marks of ENDISPUTE, Incorporated, conducted a workshop 

on negotiation theory and practice. The workshop agenda is 

included as Attachment 7. 

Thursday. September 28 

Organizational Protocol 

- Discussion continued on specific parts of the draft organizational 

protocol. Phil Harter, the facilitator, agreed to address unresolved 

concerns in a revised draft. Attachment 5 contains the revised draft. 

Work Plan For MACT 

- Discussions were initiated on ways to accomplish the committee's 

mission with respect to defining MACT for equipment leaks. Bob Ajax 

reiterated that the focus of the Reg Neg effort was to define MACT for 

fugitive equipment leak emissions covering HON source categories. MACT 

should be determined using the definitions and guidelines in the 

Administration's proposed Clean Air Act Amendments. The EPA is 

simultaneously following a traditional rulemaking process for 

addressing MACT for process vents, storage and transfer, and wastewater treatment for these same source categories. The successful 

agreement from this Reg Neg will be the basis for equipment leaks 

regulations that will then be combined with standards for the other 

emission points in the HON rulemaking proposal. 
P.7 

EPA presented thoughts on how the MACT development could proceed 

independent of emission factor development work. Because the 

number or percentage of leaks is the parameter that is directly 

measured, a MACT-based performance standard could be defined using 

formats such as number of component leaks or the percentage of 

leaking components. 

Several of the committee members were uncertain whether MACT 

could be developed independent of emission factor development 

work. 

Tom Kittleman of CMA described a conceptual model that could be used to 

develop emission rates. The model would consider factors such as the 

frequency of leaks in each of several leak rate ranges, the relationship between emissions and screening factors, and relationships between 

leak rates and time. Linda Curran of Amoco Oil helped describe the 

approach and noted that Amoco was currently studying a similar modeling 

approach. CMA and EPA agreed to have a technical working meeting on 

October 24 to discuss further details of the CMA model. 

In cooperation with CMA, EPA has developed a fairly comprehensive 

emissions data base covering a number of equipment types and services. 

Preliminary analyses of the data identified few significant 

correlations between hardware and emissions. These preliminary 

analyses are contained in a report prepared for EPA by Radian 

Corporation. EPA will make this report available to interested 

committee members. 

API has recently initiated a study to look into factors affecting 

equipment leak emissions at refineries. 

Because of limited time, and the difficulty of developing a focused 

plan, the committee agreed to delay developing a work plan until the 
P.8 

November meeting. Before the November meeting, EPA and committee 

members will develop a regulatory outline of ideas of possible formats 

for MACT. 

Schedule and Location of Meetings 

- October 24; Durham, North Carolina, EPA/Mutual Building, technical 

working meeting for interested committee members/parties to discuss 

modeling approach to MACT. 

- November 6 and 7; Research Triangle Park, North Carolina, Hotel meeting 

location to be determined, block of rooms will be reserved. 

- December 6 and 7; Location to be determined at the November meeting. 

• January 17 and 18; Location to be determined at the November meeting. 

- Meetings dates for February, March, and April will be determined at the 

November meeting. 

Emission Factors 

- David Markwordt of EPA gave a briefing on equipment leak emission 

estimation procedures and the need for improved QA/QC procedures. 

Recommendations for a joint EPA-industry sampling program were 

proposed. Attachment 8 contains a copy of the presentation handout. 

- There were several questions about the proposed sampling matrix and 

rationale for selection of the number of components to be screened and 

selection of concentration ranges. 
_E_9_ 

- Each of the industry associations agreed to contact their constituents 

in order to identify facilities that are currently planning or carrying 

out screening and bagging measurement programs, and ask for their 

participation in establishing a quality assured data base for use in 

emission factor development. 

Meeting Conclusions and Action Items 

- EPA will distribute its equipment leak data base to committee members 

who have requested it. 

- EPA will distribute the Radian Report. 

- Phil Harter will prepare a revised draft of the Organizational 

Protocol. 

- A technical working meeting will be held in Durham, North Carolina, 

on October 24 at 10:00 a.m. The meeting will be in EPA's 5th floor 

conference room in the NC Mutual Insurance Building at 411 West Chapel 

Hill Street to discuss existing data and the emission model proposed 

by CMA. 

- EPA and other committee members will prepare an outline for developing 

MACT and will be prepared to discuss it at the November meeting. 

- EPA will develop the available phosgene, EO, and Bd data in different 

formats and distribute then in mid-October. 

- CMA will contact its constituents, identify facilities that are 

currently involved in data collection programs, and request their 

participation in the committee's collection program. 
P.10 1 

hTTmUMEMf . 

EKTVIRONMEKITAL PROTECTION AGEKICY 

NEGOTIATING COKMITTSS FOR 

COB3TROL OF FUGITIVS EMISSIONS OF VOCs FROM EQUIPKDSOT LEAKS 

AGENDA 

Wednesday. September 27 

9sOO Call to Orders Introduction of Attendees 

9s15 Background briefings Review of the current rule and 

emission factors; need for revision; potential alternative 

approaches 

10s15 Coffee Break 

10s30 Discussion of the composition of the committees interests 

to be represented 

lis30 Organizational Protocols 

12s00 Resource Pool and its Protocols 

12s30 Lunch Served 

Is30 Introduction to negotiating public policy issues for 

members of the committee and their alternates 

Thursday. September 28 

9s00 Develop a work plan for negotiating MACT 

° Scope of the rule 

° Issues to be negotiated 

« What data is needed for their resolution 

° How is the data to be obtained 

° Hot? is the data to be organized and reviewed 

f preliminarily 

o Order or priority for their discussion 

12s30 Lunch served 

Is00 Emission factorss same issues as for MACT 

4s30 Schedule and location of meetings 

5s00 Adjourn 
P.11 

September 29, 1989 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

COMMITTEE MEMBERS 

Chemicals 

Bruce V. Bowers 302-834-4536 

Standard Chlorine 

P.O. Box 319 

Delaware City, DE 19706 

FAX 

David W. Dunn 409-942-3129 

Sterling Chemical Corp. 

P.O. Box 1311 

Texas City, TX 77592 

FAX: 409-942-3448 

Thomas A. Kittleman 302-366-4718 

Representing Chemical Manufacturers Association 

E.I. DuPont de Nemours & Co. 

Engineering Department 

Louviers Building 

Newark, DE 19714 

FAX: 

Karen Fidler 202-887-1290 

Staff to CMA; send materials for CMA distribution 

Chemical Manufacturers Association 

2501 M Street N.W. 

Washington, DC 20037 

FAX: 202-887-1237 

Environmental 

David Doniger 202-783-7800 

Natural Resources Defense Council 

Suite 300 

1350 New York Avenue NW 

Washington, DC 20005 

FAX: 

Allen Hershkowitz 212-727-4465 

Natural Resources Defense Council 

40 W. 20th Street 

New York, New York 10011 

FAX: 212-727-1773 

J 
P.12 

EPA 

Robert Ajax 919-541-5579 

MD-13 

Environmental Protection Agency 

Research Triangle Park, NC 27711 

FAX: 919-541-5661 

Deborah Dalton 202-382-5495 

PM-223 

Environmental Protection Agency 

401 M Street SW 

Washington, DC 20460 

FAX: 202-382-7883 

Facilitator 

Philip J. Harter 202-887-1033 

Suite 404 

2301 M Street NW 

Washington, DC 20037 

FAX: 202-887-1036 

Oil 

Linda Curran 312-420-4889 

Amoco Oil Company 

Warrenville Road & Mill Street 

Naperville, IL 60540 

FAX: 312-420-3698 

Pharmaceut i ca1s 

Jack Kace 201-235-3774 

Representing the Pharmaceutical Manufacturing Association 

Director, Environmental Affairs 

Hoffmann-LaRoche, Inc. 

340 Kingsland Street 

Nutley, NJ 07110 

FAX: 201-235-7606 

Rubber 

Alfred W. Bickum 216-796-1534 

Representing International Inst, of Synthetic Rubber Producers 

Manager, Value Engineering 

Goodyear 
P.13 

1144 E. Market Street 

Akron, OH 44316 

FAX: 216-796-6459 

State/local Governments 

Gustave Von Bodungen 504-342-9047 

Air Quality Division 

Office of Air Quality and Nuclear Energy 

Department of Environmental Quality 

P.O. Box 44096 

Baton Rouge, LA 70804 

FAX: 504-342-9048 

Anupom Ganguli 818-572-2183 

South Coast Air Quality Management District 

9150 Flair Drive 

El Monte, CA 

FAX: 

Robert V. Majewski 518-457-7688 

NYSDEC 

50 Wolf Road 

Albany, NY 12233-3255 

FAX: 

Les Montgomery 512-451-5711 

Texas Air Control Board 

6330 Highway 290 East 

Austin, TX 78723 

FAX: 512-451-5711 

Harvel Rogers 502-584-8151 

Air Pollution Control District 

914 East Boardway 

Louisville, KY 40204 

FAX: 
P.14 

Draft 

September 29, 1989 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOC FROM EQUIPMENT LEAKS 

ORGANIZATIONAL PROTOCOLS 

PARTICIPANTS 

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

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

negotiations. * 

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

parties permitted under the Committee's charter. 

c. The Negotiating Committee. The Negotiating Committee 

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

designate a Committee Member and an alternate. 

d. Attendance at Meetings. The Committee Member for each 

party or an alternate must make a good faith effort to 

attend each full negotiating session. The Committee 

Member may be accompanied by such other individuals as the 

Committee Member believes is appropriate to represent 

his/her interest. Only the Committee Member or the 

alternate will have the privilege of sitting at the 

negotiating table and of speaking from the floor during 

the negotiations without Committee approval, except that 

(1) any Committee Member may call upon a technical adviser 

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

Federal Advisory Committee Act, any person attending the 

meetings of the Committee may address the Committee if 

time permits. 

e. Constituents' Interests. Committee Members are expected 

to represent the concerns and interests of their 

constituents and to ensure that any agreement developed by 

the Committee is acceptable, to the organization which the 

Committee Member represents. 

DECISIONMAKING 

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

all parties represented. 
P.15 

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

Committee. Working Groups are open to any Committee 

Member or- the member's designee, plus such other 

individuals as the Committee believes would enhance the 

functioning of the Working Groups. Working groups are not 

authorized to make decisions for the Committee as a whole. 

Their meetings will be held between the full sessions and 

will be scheduled in the same location and time whenever 

possible. All Committee Members will be notified of all 

working group meetings. 

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

3. AGREEMENT 

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

take the form of a written statement that will be signed 

by all Committee Members. EPA will use the written 

statement as the basis of proposed regulation(s) that will 

apply to sources of emissions that are within the scope of 

the written statement. 

b. Final Rule. It is EPA's intent to promulgate a final rule 

consistent with the written statement unless comments 

submitted in response to the Notice of Proposed Rulemaking 

require changes in the proposal. EPA will submit the 

draft final rule to the Committee Members who will have 45 

days to file comments. 

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

than EPA intend to support the proposed and final rule to 

the extent consistent with the written statement. 

FACILITATOR 

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

at the will of the Committee. 

MEETINGS 

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

b. Open Meetings. Negotiating sessions will be announced in 

the Federal Register prior to the meeting and, consistent 

with FACA requirements, will be open to the public. 

c. Minutes. The proceedings will not be electronically re-
P.16 

corded, but draft minutes of Committee meetings will be 

kept and approved by the Committee. The minutes will be 

made available to the public on request. 

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

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

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

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

6. SAFEGUARDS FOR THE PARTIES 

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

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

be used by other parties for any purpose outside the 

negotiations or as a basis for future litigation. It is 

the intent of the Committee that other attendees of the 

Committee's meetings also voluntarily comply with this 

provision in order to support the regulatory negotiation 

process by encouraging the free and open exchange of 

ideas, views, and information prior to achieving 

consensus. Personal attacks and prejudiced statements 

will not be tolerated. 

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

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

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

d. Information. 

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

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

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

or a general description of it and the reason for not 

providing it directly. Emission data shall be treated 

as provided by 40 CFR § 2.301 and cannot be considered 

confidential. 

(2) Parties will provide information called for by this 

paragraph as much in advance of the meeting at which 

such information is to be used as is reasonably convenient. 
P.17 

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

others in confidence. 

(4) Information and data provided to the Committee in 

writing is a matter of a public record. 

(5) Nothing contained in these protocols shall restrict 

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

Act. 

e. Rulemaking Record. 

(1) Minutes of meetings and any other documents prepared 

or circulated in conjunction with the Negotiation 

shall be placed in a public docket of the 

negotiations, but shall not be placed in any EPA 

rulemaking docket or considered by EPA as a basis for 

rulemaking, except — 

(a) EPA may submit a list of documents it proposes to 

include in a rulemaking docket and will include 

only such documents as to which no Committee 

Member objects to including, or 

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

prepared in conjunction with the negotiations or 

relevant to the subject of the negotiations and it 

is not confidential. 

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

negotiations from submitting to any EPA rulemaking 

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

party may make such use of any document prepared or 

generated by any other party for use in this negotiation. 

7. SCHEDULE 

Negotiating sessions will initially be held once each month. 

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

1989. Unless extended by the Committee, the deadline for 

the negotiations is April 30, 1990. 
RJJL 

_T_.C_KMT 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COiXKHTTEE 

CONTROL OF FUGITIVE EKHSSIONS OF VOCs FROM _QUIPD_ENT LEAKS 

ATTENDANCE LIST FOR MEETING OF SEPTEMBER 27, 1989 

Bob Ajax 919/541-5579 

U.S. EPA 

MD-13 FAX 919/541-5661 

Research Triangle Park, NC 27711 

Ron Berglund 304/747-4985 

Union Carbide 

BOX 8361, 770-320 

So. Charleston, wv 25303 

Alfred w. Bickum 216/796=1534 

11 SRP 

1144 E. Market Street 

Akron, OH 44316 FAX 216/796-6459 

Gustave Von Bodungen 504/342=9047 

Louisiana Department of 

Environmental Quality 

P. O. Box 44096 

Baton Rouge, LA 70804 FAX 504/342=9048 

Bruce v. Bowers 302/834=4536 

Standard Chlorine of Delaware 

Governor Way Road 

Delaware City, DE 19706 

Rick Colyer 919/541=5262 

US EPA 

SDB (MD=13) FAX 919/541=5661 

Research Triangle Park, NC 27711 

Nancy Cookson 202/887=1241 

Chemical Manufacturers Association 

2501 M Street, N.W. 

Washington, D. C. 20037 

Linda Curran 312/420=4889 

Amoco Oil Company 

Warrenvill© Road _ Mill St. 
P.19 

Naperville, IL 60540 FAX 312=420=3698 

David Dunn 

Sterling Chemicals, Inc. 

P. 0. Box 1311 

Texas City, TX- 77592 

409/942=3129 

Thomas A. Fee 

National Institute for 

Dispute Resolution 

1901 L Street, N. W. 

Washington, D. C. 20036 

202/466=4764 

Karen Fidler 202/887-1290 

Chemical Manufacturers Association 

2501 M street, N.w. 

Washington, D. C. 20037 

Nicolas Garcia 

Office of Management 

and Budget 

725 17th Street, N.W. 

NEOB Room 3019 

Washington, D. C. 20503 

202/395=3084 

Mary Ann Gorko 

DuPont 

P. O. Box 6090 

Newark, DE 19714 

302/366=3011 

Allen Hershkovitz 212/727=4465 

Natural Resources Defense Council 

40 West 20 Street 

New York, NY 10025 FAX 212/727=1773 

J. L. Hess 

DuPont Coapany 

P. 0. Box 6090 

Newark, DE 19714 

302/366=3575 

FAX 302/366=2251 

C. W. Howe 

Chevron 

1700 K Street 

Washington, D. C. 20006 

202/457=5800 
Jack Kace 

Hoffmann La Roche 

340 Kingsland Street 

Nutley, NJ 07110 

201/235-3774 

Katherine Kaufman 202/475=8950 

EPA, Office of Air _ Radiation 

ANR-443 

401 M Street, S.W. 

Washington, D.C. 20460 FAX 202/475=9766 

Chris Kirtz 

US EPA 

PM-223 

401 M Street, SW 

Washington, D. c. 20460 

202/382=7565 

Robert v. Majewski 

NYS DEC 

50 Wolf Road 

Albany, NY 12233=3255 

518/457=7688 

David Markwordt 919/541=0837 

Environmental Protection Agency 

MD-13 FAX 919/541=5663 

Research Triangle Park, NC 27711 

Aline McKenzie 

Science News 

1719 N Street, M.W. 

Washington, D. C. 20036 

202/785=2255 

Lee E. Miller 

Department of Interior 

18th 6 C Streets, M.W. 

Washington, D. C. 20240 

202/343=2293 

Les Montgo_<ary 512/451=5711 

Texas Air Control Board 

6330 Highway 290 E 

Austin, TX 78727 FAX 512/451=5711 

Luis M. Mido 

Bracewell _ Patterson 

2000 K Street, N.W. 

Washington, D. C. 

202/828=5826 

FAX 202/223=1225 

3 
Robert Pahel-Short 919/541-5310 

EPA, OAR, OAQPS, ESD, SDB 

MD-13 

Research Triangle Park, NC 27711 

Frank J. Phoenix 919/493-2471 

C-E Environmental 

6320. Quaarangle Drive 

Chapel Hill, NC 27514 

John Prokop 202/659=2301 

ILTA 

1133 15th Street, N.W. 

Washington, D. C. 20005 FAX 466=4166 

Glenn D. Rives 919/541=9100 

Radian Corporation/RTP 

P. O. Box 13000 

Research Triangle Park, NC 27711 

Robert E. Rosensteel 919/541=5608 

EPA 

MD-13 

Research Triangle Park, NC 27711 

Frank T. Ryan 202/682=9250 

Goodyear 

901 15th Street, N.W. 

Washington, D. C. FAX 202/682=1537 

Ellen Siegler 202/682=8271 

American Petroleum Institute 

1220 L Street, N.W. 

Washington, D. C. 20015 

Bob Strie£®_ 202/682=8337 

American Petroleum Institute 

1220 L Street, N.W. 

Washington, D. C. 20005 

Scott Throwe 202/382=2811 

EPA/SSCD EN=341 

401 M Street, S.W. 

Washington, D. C. 20460 
P.22 

Robert VanVoorhees 202/289=6100 

Bryan, Cave, McPheeters 6 McRoberts 

1015 Fifteenth Street, NW 

Washington, D.C. 20005 FAX 202/789=5454 

W. H. Walsh 302/366=3045 

DuPont Company 

1385 Louviers Bldg/Engineering Dept. 

Newark, DE 19714=6090 FAX 302/366=6595 
P.23 

i » 

ATTACHMENT 3 SEP 5 » 

Equipment Leak Regulatory Negotiation 

1. Significance of Equipment Leaks 

2. Negotiation Scope 

- Emission Factors; estimating techniques 

- Standards reflecting MACT 

- Format for Risk-based Standards 
P.24 

SIGNIFICANCE OF EQUIPMENT LEAK 

EMISSIONS 

1. SARA 313 Data: 

Air fugitive emissions reported - 390,000 tpy 

Air point source emissions reported - 840,000 tpy 

2. Relative ground level impact of fugitive 

vs. stack emissions 

- fugitive emission impact is about 10 to 40 

times greater than impact resulting from equal 

releases of stack emissions. 
SIGNIFICANCE OF EQUIPMENT LEAK 

EMISSION 

3. The need for quantification 

- Community right-to-know responsibilities 

- Litigation exposure 

- Case-by case permitting/emission fees 

- Waste minimization initiatives 

- Protection of health 

4. Regulatory Directions 

- The Administration's proposed amendments to 

§112 of the Clean Air Act lists 191 chemicals to be 

regulated: 

(1) in phase 1, to reduce emissions to levels 

achieveable with maximum achieveable control 

technology (MACT) and, 

(2) in phase 2, to eliminate unreasonable risk. 
I 

Porlodfcaly 

AHfn-ttn Compliant* 

I i 

Exemption from MACT upon 

demonstrate! ol voluntary 

00% emission reduction 

t 

1 

Exemption from MACT 

upon demonstration ol 

•negtipiMo-risIt 

J 

Ustol 

Hazardous 

PoUutants 

* * ^ P*«OMI_ 

Adi or (MM* 

I 

Publish Major 

Souroe Category 

UsUnEB. 

r 

Title III 

Air Toxics 

EPA ranking crt 

uouroa categorise 

Regulatory Agenda 

(10 M M c—tpoi'm wMn ^~ 

2 MM , 2S% tnUiin 4 M«tt. 

xM_ion-l 2S% wthin / Mtri. 

•nd dacition- on «l mrnwanf 

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I 

Promulgate standards to protect adoquahrty 

agansl "unreasonable risk* considering 

cost, technical toasibity. and healfrUsed 

risks 

States Issue 

Operating Permits 
THE EMISSION FACTOR / 

ESTIMATING TECHNIQUE ISSUE 

1. Direct measurement of equipment leaks is 

impractical 

2. Indirect measurement methods are available 

- Accuracy is related to complexity. 

- The simplest approaches have poor accuracy. 

- The more accurate available approaches are costly. 

- Available methods are least accurate at the best 

controlled plants. 

3. Needed improvements 

- Better correlations for low leak rate facilities 

- More accurate emission factors based on the simplest 

possible screening techniques. 

- Emission factors that can be used to relate compliance 

test results to emissions. 
Emission F< 

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P.31 

Development of Standards that reflect MACT 

1. The principle regulatory approach is leak 

detection and repair (LDAR). 

- LDAR is a work practice/maintenance standard. 

- LDAR is assumed to achieve an estimated percentage 

reduction in baseline emissions. 

EQUIPMENT 

COMPONENT 

Pump Seals 

Packed and Mechanical 

Valves 

Gas 

Liquid 

Flanges 

CONTROL EFF. 

(percent) 

60.8 

73.0 _ 

59.0 

0.0 
P.32 

SUMMARY OF CURRENT LDAR STANDARDS 

(SOCMI NSPS) 

• PUMPS IN LL SERVICE AND VALVES IN GAS/LL SERVICE 

• Monthly leak detection and repair 

- Leak = 10,000 ppm or greater 

- Repair within 15 days, first attempt within 5 days 

• Or "leakless" equipment 

- No detectable emissions = less than 500 ppm 

- Annual monitoring 

• ALTERNATIVE STANDARDS FOR VALVES 

• 2 percent leakers (performance standard not to be 

exceeded) 

• Skip period LDAR (work practice standard) 

• PUMPS AND VALVES IN HL SERVICE / 

PRESSURE RELIEF DEVICES IN LL OR HL SERVICE / 

FLANGES AND OTHER CONNECTORS 

• Monitor for leak if evidence of leak is found 

• Leak = 10,000 ppm or greater 

• Repair within 15 days, first attempt within 5 days 

• COMPRESSORS / SAMPLING CONNECTION SYSTEMS / 

OPEN-ENDED LINES 

• No detectable emissions and specified equipment 

• CLOSED VENT SYSTEMS - no detectable emissions 

• CONTROL DEVICES - 95 percent reduction 

LL = Light liquid HL = Heavy liquid 
P.33 

Development of Standards that reflect MACT 

2. The actual control approaches and 

emissions at many facilities are probably 

much different than the above 

assumptions. 

- Best controlled plants emit less than estimates for typical 

plants with LDAR alone. 

- Best control likely consists of combinations of original plant 

design, component design and materials, operating and 

maintenance practices, leak detection programs, etc. 

- Current regulatory approaches AQ ng-t; provide inrantivfls or 

credit for the types of programs thatachieve best control. 

- Regulatory approaches are not available mat would assure 

achievement of quantifiable, low emission rates. 

3. Need - A regulatory approach that will reduce 

emissions to levels achieveable with the best 

control technology. 
ESTIMATES OF CONTROL EFFECTIVENESS 

FOR GAS VALVES IN BENZENE SERVICE 

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P.35 

Development of Standards that reflect MACT 

4. Possible solutions 

- More effective LDAR, possibly using a lower leak definition 

- Limits on the percent leaking components; or on the 

emissions per component 

- Limits on emissions; or on the number of leaking 

components per facility 

- A combination of the above, (e.g., use of LDAR initially 

with a sliding scale emission limit to be met at some future 

time) 
EXAMPLE OF A COMBINED "CAP" & TECHNOLOGY LIMIT 

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pe-go 14 
Format for Risk-based Standards 

- This issue pertains to the format of a standard for 

equipment leaks that would assure the additional emission 

reduction to protect public health from unreasonable risk. 

- This issue arises because current approaches based on 

technology produce differing results depending upon such 

factors as number of components. 

- The goal is a regulatory format that could be used by 

EPA to "cap" emissions. (The level or stringency is not to 

be considered in this negotiation.) 

- Options are 

- A cap on the number of leaking components 

- A cap on the total emissions 

i 15 
col 

col 

Relationship between Negotiation Topics 

Develop a standard reflecting 

MACT in a format that allows 

accurate quantification 

(a) 

MACT standard 

I 

Emissions 

Develop Accurate Emission 

Factors that can be used 

with limited sampling data 

Develop a regulatory format 

that can be applied to achieve 

risk goals 

Format for Performance Cap 

Emissions Cap 

(a) If MACT is expressed in terms of emissions, then development of emission factors may be critical path 
-__ . 

__*»__ _ 

Calculate emission factors (curves) 

using leak frequency distributions 
Develop MACT Standard Considerations in the Development of an MACT Standard 

Performance Data 

- Phosgene, EO, BD 

- 24 unit study 

- other data 

Factors effecting performance 

• Equipment 

• O&M, Inspection 

• Fixed monitors 

- Training, other 

Feasibility, Costs 

Schedule/learning curve 

New vs Existing Sources 

Interests 

• Predictable emission results 

• Reflect MACT 

- Enforceable 

- Regulatory consistency (e.g. State 

permitting, SARA reporting) 

- Incentives for better design 

- Flexibility 

- Minimize administrative burdens 

• Predictable compliance 

- Timing consistant with 

technology/learning curve 

Industry Profile 

Possible MACT Options 

- Format 

- Stringency 

- Averaging time 

- Compliance schedule 

- Interim requirements 

- Compliance sampling; 

statistical approach 

• Reporting requirements 

- Exemptions/different stds. 

= new vs existing 

= dilute streams 

= low throughput 

- unique processes 

_ _ _ 

Baseline conditions 

National Impacts 

Standards 

Combine with Process, 

Storage. Wastewater Stds. 

for HON categories 
® 

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Comparison of Emission Factors 

Light Liquid Valves 

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P.43 

Emission Factors (kg/hr/source) 

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P.45 

..TT/_(__M_MT 4 

September 27, 1989 

ENVIRONMENTAL PROTECTION AGENCY 

. . NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

COMMITTEE MEMBERS 

Ch@_icals 

Bruce V. Bowers 

Standard Chlorine 

P.O. Box 319 

Delaware City, DE 19706 

FAX 

David Dunn 

Sterling Chemical Corp. 

P.O. Box 1311 

Texas City, TX 77592 

FAX: 

Thomas A. Kittleman 

E.I. DuPont de Nemours & Co, 

Engineering Department 

Louviers Building 

Newark, DE 19714 

FAX. 

302=834-4536 

409-942=3129 

302-366-4718 

En vi r o___e__ta 1 

David Doniger 

Natural Resources Defense Council 

Suite 300 

1350 New York Avenue NW 

Washington, DC 20005 

FAXs 

Allen Hershkowitz 

Natural Resources Defense Fund 

40 w. 20th Street 

New York, Net. York 10011 

FAXS 212-727-1773 

202-783-7800 

212-727-4465 

EPA 

Robert Ajax 

MD-13 

Environmental Protection Agency 

Research Triangle Park, NC 27711 

919=541-5579 
P.46 

FAXs 919-541=5661 

Deborah Dalton 202=382=5495 

PM-223 

Environmental Protection Agency 

401 M Street SW 

Washington, DC 20460 

FAX: 202-382-7883 

Facilitator 

Philip J. Harter 202=887=1033 

Suite 404 

2301 M Street NW 

Washington, DC 20037 

FAXS 202-887-1036 

oil 

Linda Curran 312=420-4889 

Amoco Oil Company 

Warrenville Road 6 Mill Street 

Naperville, IL 60540 

FAXs 312-420=3698 

Pharmaceuticals 

Jack Kace 201=235-3774 

Director, Environmental Affairs 

Hoffmann-LaRoche, Inc. 

340 Kingsland Street 

Nutley, NJ 07110 

FAXS 201-235-7606 

Rubb@_ 

Alfred W. Bickum 216=796=1534 

Manager, Value Engineering 

Goodyear 

FAXs 216=796=6459 

State/local gov®_r____®__'t 

Gus Von Bodungen 504=342=9047 

Air Quality Division 

Office of Air Quality and Nuclear Energy 

Department of Environmental Quality 

P.O. Box 94096 
P.47 

Baton Rouge, LA 70804 

FAXS 504-342-9048 

Anupom Ganguli 818=572=2183 

South Coast Air Quality Management District 

9150 Flair Drive 

El Monte, CA 

FAX: 

Bob Majewski 518=457-7688 

NYSDEC 

50 Wolf Road 

Albany, NY 12233-3255 

FAXs 

Les Montgomery 512=451-5711 

Texas Air Control Board 

6330 Highway 290 East 

Austin, TX 78723 

FAXs 512-451-5711 

Harvele Rogers 502=584=8151 

Air Pollution Control District 

914 East Boardway 

Louisville, KY 40204 

FAXs 
P.48 

ATTACHMENT 5 

Reserved for Draft Organizational Protocols 
P.49 

_.T_.__iJ__T 

Draft 

September 18, 1989 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

RESOURCE POOL PROTOCOLS 

lc PURPOSE OF THE POOL 

a. To provide funds for short-term research, technical analysis, and other support for the Committee as a whole and 

for individual participating interests. 

b. To defray extraordinary expenses of participation for 

parties who would otherwise not be able to participate in 

the negotiations. 

2. PROTOCOLS FOR USING THE POOL 

a. Group Decisionss The group as a whole will decide what 

short-term research, technical analysis, and other information should be funded through the pool. Any party may 

object to the need for such research, technical analysis, 

information or support. In this case, the facilitator 

will determine whether there is sufficient group consensus 

that the work should nonetheless be undertaken. 

b. Contractor Managements Contractors for research will be 

selected by a representative working group with the approval of the Negotiating Committee as a whole. The resource pool working group shall be responsible fors 

(1) identifying potential contractors, with a preference 

for competitive bids taking into account the size, 

complexity, and time required for delivery of any such 

contract; 

(2) explaining the reasons for selecting a particular 

contractor; 

(3) preparing relevant work orders describing the specific 

work product of the contractor and the schedule for 

its delivery; 

(4) ensuring the satisfactory performance of work; and 
P.50 

(5) recommending that the Advisory Committee's Executive 

Secretary authorize disbursement. 

c. Request from Individual Parties: The Committee may, to 

the extent the law allows, provide a party with funds from 

the resource pool for travel and per diem, retaining expert consultants, or conducting short-term research that 

will enable that party to better express its needs and 

position and to judge the information provided by other 

parties. 

(1) A party requesting such funds shall make a showing to 

the Committee of reasons for need. 

(2) The recipient of such funds shall provide an accounting for their use to Committee. 

3. MANAGEMENT OF THE POOL 

The Resource Pool will be managed by the National Institute 

for Dispute Resolution. The Advisory Committee's Executive 

Secretary will transmit requests to pay for services that 

are authorized by the Committee. The Institute will distribute appropriate funds in response to such requests. The 

Institute will not be responsible for the quality of work 

received or the vendor selected. 
P.51 

ATFA©HSWii_T 7 

Fugitive Emissiomis Regulatory Negotiation. Workshop 

Presented by 

Jonathan B. Marks 

ENDISPUTE, Incorporated 

September 27, 1989 

12:45- 1p.m. 

1 p.m. - 5:30 p.m. 

1:00- 1:50 p.m. 

1:50 p.m. - 2:40 p.m. 

2:40 p.m. - 3:30 p.m 

Thinking About Negotiating a Proposed Rule --

What Can We Learn from Negotiation Theory 

and Past Regulatory Negotiations? 

Putting Theory and Experience Into Practice — 

Three Exercises and Debriefings. 

Win as Much as You Can 

° Exercise 

° Debriefing. 

3:30 - 4:30 p.m. 

4:30 - 5:30 p.m. 

Coalition Game 

° Three Party Negotiation Exercise 

° Debriefing 

Dirtystuff Simulation Preparation 

° Read Dirtystuff Regulatory 

Negotiation Exercise 

• Meetings of Those Playing Role of 

Each Party in Negotiation 

Negotiation Exercise — The Dirtystuff 

Rule. 

Dirtystuff Debriefing 

Pulling Together the Lessons of the 

Workshop 
P.52 

_%\_cur 

ATTACHMENT 8 

Equipment Leak Regulatory Negotiation 

Proposed Refinements To EPA Procedures 

For Estimating Equipment Leak Emissions 

EPA Presentation 

by 

Mr. David Markwordt 

Emission Standard Division 

U.S. Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 

September 28, 1989 
P.53 

ORGANIZATION OF PRESENTATION 

Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 
P.54 

ORGANIZATION OF PRESENTATION 

Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

Needed Improvements To Procedures 

Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 
P.55 

OVERVIEW OF EPA EMISSIONS 

ESTIMATION PROCEDURES 

EPA Protocol Presents 5 Methodologies 

For Estimating Equipment Leak Emissions 

• Average Emission Factors 

Leak/No-Leak Emission Factors 

Stratified Emission Factors 

EPA Correlations 

Unit-Specific Correlations 
P.56 

ORGANIZATION OF PRESENTATION 

Overview of EPA Emissions Estimation 

Procedures 

-Current Concerns With Procedures 

- Needed Improvements To Procedures 

Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 
P.57 

CURRENT CONCERNS WITH PROCEDURES 

- Questionable Accuracy Of Available 

Estimation Procedures, Especially At 

Well-Controlled Plants 

- Many Plants Forced To Bag To 

Achieve Realistic Emissions Estimates 
P.58 

•3 

___ 

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P.59 

ORGANIZATION OF PRESENTATION 

Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 
P.60 

NEEDED IMPROVEMENTS TO PROCEDURES 

Larger Database of Screening and Bagging Data 

• Additional Data At Low Screening Values 

• Additional Data Collected With Adequate 

QA/QC 

- Better Correlations 

Reduces Need For Plants To Bag 
P.61 

ORGANIZATION OF PRESENTATION 

- Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

- Method To Achieve Needed Improvements: 

Proposed Equipment. Screening and Bagging 

Data Collection Program 

• Purpose 

• Proposed Strategy 

• Highlights Of Proposed QA/QC 

Data Collection Program 

• Overview Of Existing Screeening 

And Bagging Data 

• Proposed Sampling Matrix 

• Practical Issues Related to Data 

Collection 
P.62 

ORGANIZATION OF PRESENTATION 

- Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

- Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 

• Purpose 

• Proposed Strategy 

• Highlights Of Proposed QA/QC 

Data Collection Program 

• Overview Of Existing Screeening 

And Bagging Data 

• Proposed Sampling Matrix 

• Practical Issues Related to Data 

Collection 
P.63 

PROPOSED QA/QC EQUIPMENT SCREENING 

AND BAGGING DATA COLLECTION PROGRAM 

- Purpose 

Improve Methodology And Tools 

For Quantifying Equipment Leak 

Emissions, Especially In The Low 

Screening Value Range 
P.64 

ORGANIZATION OF PRESENTATION 

- Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

- Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 

• Purpose 

• Proposed Strategy 

• Highlights Of Proposed QA/QC 

Data Collection Program 

• Overview Of Existing Screeening 

And Bagging Data 

• Proposed Sampling Matrix 

• Practical Issues Related to Data 

Collection 
P.65 

PROPOSED QA/QC EQUIPMENT SCREENING 

AND BAGGING DATA COLLECTION PROGRAM 

- Proposed Strategy 

• Develop QA/QC Guidelines For Field 

Screening And Bagging 

• Collect Equipment Screening And 

Bagging Data 

- Light Liquid Valves 

- Gas Valves 

- Pumps 

- Light Liquid Flanges 

- Gas Flanges 

• Develop New Correlations 
P.66 

ORGANIZATION OF PRESENTATION 

- Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

- Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 

• Purpose 

• Proposed Strategy 

• Highlights Of Proposed QA/QC 

Data Collection Program 

• Overview Of Existing Screeening 

And Bagging Data 

• Proposed Sampling Matrix 

• Practical Issues Related to Data 

Collection 
P.67 

HIGHLIGHTS OF PROPOSED QA/QC 

DATA COLLECTION PROGRAM 

- QA/QC Guidelines For Screening 

• Use Of One Model Of Screening Instrument 

At All Participating Facilities (Foxboro OVA 

Has Been Selected For This Proposed Program) 

• Use Of Two Screening Instruments Per Facility 

- One instrument Dedicated To Low Screening 

Value Range 

- One instrument Dedicated To Mid- And Upper 

End Of Screening Value Range 

• Use Of A Dilution Probe For Equipment Screening 

> 10,000 ppmv 

• Develop Separate Response Curves For Each 

Screening Instrument 

• Minimum Two-Point Calibration Of OVA 

• Independent Observer To Ensure Compliance 

With QA/QC Procedures 
P.68 

HIGHLIGHTS OF PROPOSED QA/QC 

DATA COLLECTION PROGRAM 

- QA/QC Guidelines For Bagging 

• Use Of A Laboratory Analytical Instrument To 

Analyze Bag Samples 

• Minimum Two-Point Calibration Of Laboratory 

Analytical Instrument 

• Accuracy Checks 

• Blind Standards 

• Blow-Through Bagging Technique 
P.69 

ORGANIZATION OF PRESENTATION 

- Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

- Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 

• Purpose 

• Proposed Strategy 

• Highlights Of Proposed QA/QC 

Data Collection Program 

• Overview Of Existing Screeening 

And Bagging Data 

• Proposed Sampling Matrix 

• Practical Issues Related to Data 

Collection 
P.70 

PROPOSED QA/QC EQUIPMENT SCREENING 

AND BAGGING DATA COLLECTION PROGRAM 

Available Screening And Bagging Data 

From Refinery Assessment Study 

• Summary Of Data Collected

 r 

- Purpose Was To Evaluate Emissions 

Over Entire Range Of Screening Values 

- Low End Of Screening Value Range 

Determined To Have Small Effect On 

Total Emissions; Therefore, Data 

Collection At Mid- And Upper Range 

Of Screening Values Was Emphasized 

- Flange Bagging Data Used To Develop 

EPA Correlation For Flanges 

• Comparison Of QA/QC Procedures To 

Proposed QA/QC Guidelines 
Equipment 

Type 

Valves 

Valves 

Valves 

Valves 

0. E. Lines 

i Pump Seals 

Pump Seals 

Compressors 

Compressors 

Flanges 

Drains 

Relief Valves 

SCREENING DATA FROM EPA REFINERY ASSESSMENT 

Service 

Gas/Vapor 

Light Liquid 

Heavy Liquid 

Hydrogen 

All 

Light Liquid 

Heavy Liquid 

Hydrocarbon 

Hydrogen 

All 

All 

Gas/Vapor 

Number 

of. 

Plants 

13 

13 

13 

13 

13 

13 

13 

13 

13 

13 

13 

13 

Total 

0-200 

ppm 

411 

596 

456 

77 

100 

174 

229 

30 

16 

1,973 

211 

94 

4,367 

STUDY 

Number of Screened 

200-IK 

ppm 

33 

70 

21 

8 

7 

79 

24 

11 

8 

29 

18 

11 

319 

1K-10K 

ppm 

47 

142 

7 

22 

12 

104 

28 

13 

17 

17 

14 

23 

446 

Sources 

>10K 

ppm 

71 

104 

1 

28 

10 

113 

11 

72 

33 

11 

12 

12 

478 

Total 

562 

912 

485 

135 

129 

470 

292 

126 

74 

2,030 

255 

140 
BAGGING DATA FROM EPA REFINERY ASSESSMENT STUDY 

Equipment 

Type 

Valves 

Valves 

Valves 

Valves 

Open-ended Lines 

Pump Seals 

Pump Seals 

Compressors 

Compressors 

Flanges 

Drains 

Relief Valves 

Service 

Gas/Vapor 

Light Liquid 

Heavy Liquid 

Hydrogen 

All 

Light Liquid 

Heavy Liquid 

Hydrocarbon 

Hydrogen 

All 

All 

Gas/Vapor 

Number 

of 

Plants 

13 

13 

13 

13 

13 

13 

13 

13 

13 

13 

13 

13 

Total 

0-200 

ppm 

6 

17 

4 

2 

1 

7 

4 

0 

3 

6 

5 

11 

66 

Number of Bagged 

200-1K 

ppm 

31 

68 

20 

7 

7 

75 

23 

7 

8 

29 

18 

11 

304 

1K-10K 

ppm 

46 

141 

7 

22 

12 

104 

28 

10 

17 

17 

14 

23 

441 

Sources 

>10K 

ppm 

71 

104 

1 

28 

10 

110 

11 

72 

32 

10 

12 

12 

473 

Total 

154 

330 

32 

59 

30 

296 

66 

89 

60 

62 

49 

57 

• _ 
P.73 

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P.74 

CC_>AB!_Ca OP QA/QC PR0CEDU8ES FHOS EHI STIMG STUDIES TO PROPOSED QA/QC GUIDELINES 

Screening/Bogging Study 

Refinepy 

Assessment 

Study 

SOCHI 

24-Unit 

Study 

6-Unit 

Mointenonco 

Study 

80/EO 

Pons I 

Studies 

QA/QC GuidsUrws for Screening 

Use of on OVA fpp screening 

Uso of two OVA'o (Ono low rongo 

ono (aid- to high rongo) 

Uso of o dilution probo 

0eveI op separate responso 

curve fop eoch OVA 

Hininoc- two-point 

colibrotion of OVA 

Drift Cheeks 

Irtdspondont Observer 

QA/QC Gufdolines for Begging 

Uso of laboratory 

anolyticol instrurant •••• 

Minimus tuo-point colibrotion 

of anolyticol instriosont 

Accuracy Chocks 

Blind Stcrtdordo 

X (Note 1) X (Note 2) 

X (Noto 4) 

X (Note 4) 

X (Note 4) 

Blow-through Technique 

Indeporetesit Oteopvor 

X (Noto 3) X (Mote 4) 

Noto 1: An OVA uoo used to obtain tho initial screening voluo for eoch component. A TLV uao used to obtain the 

screening voluoo during bogging. 

Noto 2: Both on OVA ond o TLV tsoPO used. Tho opithsotie moon of tho ttso pecdingo obtoinod fpo_> the OVA and the 

TLV uoo rocordod oo tho oboopved screening voluo for eoch componont. 

Noto 3: Used fop largo looks. 

Note 4: Used by scsa plants. 

Additional QA/QC procedures thot uepe popfonftod duping the 24-Unit SOCMI Study ond tho 6-Unit Maintenance 

Study inciudo: 

o Repoot screening ond replicoto screening duping the 24-Unit SOCMI Study: and 

o RGpoot screening end pepoot bogging during the 6-Unit ttointononeo Study. 
P.75 

PROPOSED QA/QC EQUIPMENT SCREENING 

AND BAGGING DATA COLLECTION PROGRAM 

- Available Screening And Bagging Data 

From SOCMI Studies 

• Summary Of Data Collected 

- Purpose Of Bagging Study Was To 

Determine Effect Of Maintenance On 

Emission Reduction 

- Large Number Of Sources That Were 

Screened At Low End Of Screening 

Value Range Were Determined To Have 

Small Effect On Total Emissions 

- Most Screening Data Collected At Low 

End Of Screening Value Range 

(0-1,000 ppmv) 

- Most Bagging Data Collected At Mid- And 

Upper End Of Screening Value Range 

(5,000-40,000 ppmv) 

- EPA Correlations For Light Liquid Valves, 

Gas Valves, And Pumps Developed 

From These Bagging Data 

• Comparison Of QA/QC Procedures To 

Proposed QA/QC Guidelines 
SCREENING DATA FRON SOCMI 24-UNIT STUDY 

Equipment 

Type 

Flanges 

Flanges 

Flanges 

Process Drains 

Process Drains 

Process Drains 

0. E. Lines 

0. E. Lines 

0. E. Lines 

Agitator Seals 

Agitator Seals 

Agitator Seals 

Relief Valves 

Relief Valves 

Relief Valves 

Valves 

Valves 

Valves 

Pumps 

Pumps 

Compressors 

Service 

Gas/Vapor 

Light Liquid 

Heavy Liquid 

Gas/Vapor 

Light Liquid 

Heavy Liquid 

Gas/Vapor 

Light Liquid 

Heavy Liquid 

Gas/Vapor 

Light Liquid 

Heavy Liquid 

Gas/Vapor 

Light Liquid 

Heavy Liquid 

Gas/Vapor 

Light Liquid 

Heavy Liquid 

Light Liquid 

Heavy Liquid 

Gas/Vapor 

Number 

of 

Plants 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

24 

Total 

Number of Screened Sources 

O I K 

ppm 

1,336 

2,812 

607 

77 

491 

26 

845 

3,309 

469 

5 

8 

1 

75 

66 

3 

7,943 

16,320 

3,606 

514 

93 

27 

38,633 

1K-10K 

ppm 

41 

50 

0 

4 

16 

0 

24 

153 

2 

1 

0 

0 

7 

1 

0 

623 

803 

11 

76 

2 

0 

1,814 

>10K 

ppm 

66 

35 

0 

2 

20 

2 

54 

141 

6 

1 

0 

0 

3 

2 

0 

1,102 

1,171 

15 

57 

2 

2 

2,681 

Total 

1,443 

2,897 

607 

83 

527 

28 

923 

3,603 

477 

7 

8 

1 

85 

69 

3 

9,668 

18,294 

3,632 

647 

97 

29 
BAGGING DATA FRON SOCNI 6-UNIT MAINTENANCE STUDY 

Equipment 

Type 

Valves 

Valves 

Pumps 

Service 

Gas/Vapor 

Light Liquid 

Light Liquid 

Number 

of 

Plants 

6 

6 

6 

Total 

0-1K 

ppm 

51 

52 

11 

114 

Number of 

1K-10K 

ppm 

72 

109 

14 

195 

Bagged Sources 

>10K 

ppm 

186 

199 

39 

424 

Total 

309 

360 

64 
P.78 

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P.79 

• 

CGMPAA1S0M Of QA/QC 

QA/QC Guideline* for Screening 

Use of an OVA for screening 

Use of two OVA's (One low rang* 

one aid- to high range) 

Uaa of a dilution prob* 

Develop separate response 

curve for each OVA 

Minimus two-point 

calibration of OVA 

Drift Checks 

Independent Observer 

QA/QC Guidelines for Bagging 

Us* of laboratory 

analytical instruaent 

Minimus two-point calibration 

of analytical inetruaent 

Accuracy Checks 

Blind Standards 

Blow*through Technique 

Independent Observer 

PROCEDURES FROM EXISTING STUDIES TO PROPOSED QA/QC GUIDELINES 

Screening/Bagging study 

Refinery SOCMI 6-Unit BO/EO 

Assessment 24-Unit Maintenance Panel 

Study study Study Studies 

X (Note 1) X X (Note 2) x 

X X X x (Note 4) 

X X X X 

X x 

X 

X X X (Noto 4) 

X X X (Note 4) 

X X 

X

 sX (Note 3) X (Note 4) 

Note 1: An OVA waa uaad to obtain tha initial screening valua for eeeh coejponent. A TLV waa used to obtain the 

screening values during bagging. 

Not* 2: Both an OVA and a TLV were used. Tha arithmatic mean of tha two readings obtained froa the OVA and the 

TLV waa recorded as tha observed screening valua for each component. 

Note 3: Used for larg* leaks. 

Nota 4: Used by so w plants. 

Additional QA/QC procedures that ware parformad during the 24-Unit SOCMI Study and tha 6-Unit Maintenance 

Study include: 

o Repeat screening and replicate screening during the 24-Unit SOCMI Study: snd 

o Repast screening and repeat bagging during the 6-Unit Maintenance Study. 
P.80 

PROPOSED QA/QC EQUIPMENT SCREENING 

AND BAGGING DATA COLLECTION PROGRAM 

-Available Screening And Bagging Data From 

Butadiene And Ethylene Oxide Panel Studies 

• Summary Of Data Collected 

- Purpose Was To Provide Better 

Estimates Of Air Emissions For 

Butadiene And Ethylene Oxide Industries 

- Limited Bagging Data 

• Comparison Of QA/QC Procedures To 

Proposed QA/QC Guidelines 
SCREENING DATA FRON BUTADIENE AND ETHYLENE OXIDE PANEL STUDIES 

Equipment 

Type 

Valve 

Valve 

Pump Seals 

Flanges 

Relief Valves 

Sample Points 

Open-ended Lines 

Compressors 

Service 

i 

Gas/Vapor 

Light Liquid 

Light Liquid 

All 

Gas/Vapor 

All 

All 

All 

Number 

of 

Plants 

22 

22 

22 

22 

22 

22 

22 

22 

Total 

Number of Screened Sources 

0-1K 

ppm 

8.561 

24,787 

363 

11,987 

520 

41 

652 

21 

46,932 

1K-10K 

ppm 

302 

982 

79 

108 

10 

9 

48 

1 

1,539 

>10K 

ppm 

138 

508 

31 

41 

7 

2 

14 

0 

741 

Total 

9,001 

26,277 

473 

12,136 

537 

52 

714 

22 

• _ 

bo 
BAGGING DATA FRON BUTADIENE AND ETHYLENE OXIDE PANEL STUDIES 

Equipment 

Type 

Service 

; 

Gas/Vapor 

Light Liquid 

Light Liquid 

All 

Gas/Vapor 

All 

All 

All 

Number 

of 

Plants 

Number of Bagged Sources 

O I K 

ppm 

15 

15 

2 

17 

0 

0 

2 

0 

1K-10K 

ppm 

6 

16 

2 

15 

0 

0 

0 

0 

>10K 

ppm 

0 

3 

0 

0 

0 

0 

0 

0 

Total 

21 

34 

4 

32 

0 

0 

2 

0 

Valve 

Valve 

Pump Seals 

Flanges 

Relief Valves 

Sample Points 

Open-ended Lines 

Compressors 

Total 51 39 
P.83 

< 

CCWPAJJISOM 0* QA/QC PROCEDURES FROM EXISTING STUDIES TO PROPOSSD QA/QC GUIDELINES 

_ 

QA/OC Guidelines for Screening 

Use of an OVA for screening 

Use of two OVA's (One low range 

one mid- to high range) 

Use of s dilution probe 

Develop separata response 

curve for each OVA 

Minimus two-point 

calibration of OVA 

Drift Checks 

Independent Observer 

QA/QC Guidelines for Bagging 

Use of laboratory 

analytical inetruaent 

Minimus two-point calibration 

of analytical instruaent 

Accuracy Checks 

Blind Standarda 

Blow-through Technique 

Independent Observer 

Screening/Bagging Study 

Refinery SOCHI 6-Unit BO/EO 

Assessment 24-Unit Maintenance Panel 

Study Study Study Studies 

_ 

x (Note 1) x x (Note 2) x 

X x x x (Note 4) 

xxx x 

X x 

X 

x x x (Note 4) 

X X X (Note 4) 

X X 

X 

x (Note 3) x (Note 4) 

Note 1: An OVA waa used to obtsin tha initisl screening vslue for each component. A TLV waa uaad to obtain the 

screening values during begging. 

Note 2: Both an OVA and a TLV were used. The srithmetic mean of the two readings obtained from the OVA and the 

TLV waa recorded as the observed screening vslue for each component. 

Note 3: Used for large leaks. 

Nota 4: Uaad by soma plants. 

Additional QA/OC procedures thst 

Study include: 

o Repeet screening and 

o Repeat screening and 

were performed during the 24-Unit SOCMI Study snd the 6-Unit Maintenance 

replicste screening during the 24-Unit SOCNI Study: and 

repeat bagging during the 6-Uoit Maintenance Study. 
P.84 

ORGANIZATION OF PRESENTATION 

- Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

- Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 

• Purpose 

• Proposed Strategy 

• Highlights Of Proposed QA/QC 

Data Collection Program 

• Overview Of Existing Screeening 

And Bagging Data 

• Proposed Sampling Matrix 

• Practical Issues Related to Data 

Collection 
P.85 

PROPOSED QA/QC EQUIPMENT SCREENING 

AND BAGGING DATA COLLECTION PROGRAM 

Sampling Matrix For Proposed Data 

Collection Program 

• Screening Value Ranges Developed 

From Frequency Distribution Of Sources 

Screened During The Butadiene And 

Ethylene Oxide Studies 

• Recommended Number Of Components 

To Be Bagged Per Screening Value Range 

Were Developed Statistically From A Desire 

To Maximize Sample Size While Minimizing 

Sample Error 

• Matrix Emphasizes Low End Of Screening 

Value Range While Simultaneously Striving 

For Adequate Sample Sizes In Mid- And 

Upper Ranges Of Screening Values 
S«PLM miHX FOR PROPOSED EPA QA/QC SCREEM MD BA£GIWG DATA COLLECTION PROGRAM 

Service Screetmimig Value Suggested 

Klyrfner of 

Baggedl Sources 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

80 

Mi_m_etr of 

Existing 

Data Points * 

7 

12 

13 

159 

202 

22 

9 

7 

107 

186 

0 

2 

7 

20 

39 

4 

_ 

0 

3 

0 

2 

6 

1 

12 

0 

Valve Light Liquid 

ve 

light Liquid 

Raimge Gas/Vapotr 

Range Light Liqui 

0 

1-10 

10-100 

100-10,000 

0 

1-10 

10-100 

100-10,000 

>1C 

1-1 

1-10 

10-100 

100-10,000 

1-10 

10-100 

100-10,000 

>10,000 

* From SOCMI 6-Unit Maintenance Study and BD and FO PTM_ I <__.__ 

Ref.ner. _, u wer e oot inched b eL j 5r__ ^.nS'^,. . QVq c guideline s 

IOD 
P.87 

ORGANIZATION OF PRESENTATION 

- Overview of EPA Emissions Estimation 

Procedures 

- Current Concerns With Procedures 

- Needed Improvements To Procedures 

- Method To Achieve Needed Improvements: 

Proposed Equipment Screening and Bagging 

Data Collection Program 

• Purpose 

• Proposed Strategy 

• Highlights Of Proposed QA/QC 

Data Collection Program 

• Overview Of Existing Screeening 

And Bagging Data 

• Proposed Sampling Matrix 

• Practical Issues Related to Data 

Collection 
P.88 

PROPOSED QA/QC EQUIPMENT SCREENING 

AND BAGGING DATA COLLECTION PROGRAM 

- Practical Issues Related To Data Collection 

Need To Ensure An Equitable Distribution 

Of Sources Among The Tested Plants 

Need To Be Aware That Population Of 

Pumps is Small, And We May Have Trouble 

Finding Enough Pumps To Bag In 5 

Discrete Screening Value Ranges 

Recommend Segregating Flanges By Service 

(Light Liquid And Gas/Vapor)