P.1 

OAR Box 1338 

Prepped by Ollie Stewart 

Document Number: 

10) ll-E-21 

Docket Number: 

A-89-10 

Printed 6/17/2008 1:48:05 PM Sheet 10 of 105 
r. 

LAW OFFICES 

PHILIP J. HARTER 

SUITE 404 

2301 M STREET. N.W. 

WASHINGTON. D.C. 20037 

A-89-10 

II-E-2 1 

(202) 887-1033 

FAX: (202) 887-1036 

/l?,Ji-JU_J_lJ JiT!: 

FEB! l\m T' w ; 

May 16, 1990 

MEMORANDUM 

To: EPA Negotiated Rulemaking Committee on Fugitive Emissions from Equipment Leaks and Interested 

Parties 

Fr: Philip J. Harter 

Facilitator fii 

Re: Minutes of May 10-11 Meeting; Future Meeting; Batch Workgroup Meeting 

I enclose the minutes of the May 10-11 meeting that were prepared by Radian Corporation. As 

before, the materials that were distributed at the meeting are attached. The agenda for the next meeting is 

rather simple to describe but perhaps more difficult to execute: reach an agreement on an outline of the 

entire rule. Thus, we will address the full range of issues. 

The Batch Processing workgroup will meet at 10:00 on June 1 at the Pharmaceutical Manufacturers 

Association, 1100 Fifteenth Street NW, Washington, DC. As always, all Committee members and their 

designees are welcome. 

The next meeting will on June 6-7. It will be at the Compri Hotel, 4620 S. Miami Boulevard, Morrisville, NC 27560;. 919-941r6066. The hotel is just off Exit 281 on 1-40, which is the second exit from the 

airport on the way to Durham. A block of rooms has been reserved. When calling for reservations, please 

identify yourself as being with "EPA Fugitives". 

The meeting will begin at 10:00 on the first day and 9:00 on the second. It will run until about 6:00 on 

the first day and about 5:00 on the second. As was clear at the last meeting, things often get hairy at the end, 

and it is quite disruptive to lose committee members when the rest are struggling with the big issues. 

Therefore, it is important that all committee members plan to stay the whole time. 

We scheduled another meeting to be held July 17-18 to flesh out the conceptual agreement. But, the 

July meeting will be held only if we reach a conceptual agreement in June: the deadline is upon us. 
P.3 

i .** 

REGULATORY NEGOTIATION MEETING ON FUGITIVE EQUIPMENT LEAKS 

MAY 10-11, 1990 

THE CONSERVATION FOUNDATION 

WASHINGTON, D.C. 

DRAFT MEETING MINUTES 

These meeting notes summarize issues discussed and provide an informal 

record of administrative and logistical decisions made on schedules and action 

items. All presentation materials distributed during the two-day meeting are 

attached: 

Attachment 1 

Attachment 2 

Attachment 3 

Attachment 4 

Attachment 5 

Attachment 6 

Attachment 7 

Attachment 8 

Attachment 9 

Attachment 10 

Attachment 11 

Administrative Note 

Meeting Agenda 

Attendees May 10, 1990 

Revisions to March 27-28 meeting notes 

CMA Memo: Regulatory Exemptions 

CMA Figure: Conceptual Approach for Valves 

CMA Memo: Regulatory Proposal for Valves 

Reasonable Further Progress Criteria 

CMA Figure: Conceptual Approach for Pumps 

CMA Memo: Regulatory Proposal for Flanges 

Batch work group meeting minutes 

EPA Draft Work Plan for Development of OVA Response 

Factors 

Ms. Deborah Dalton of the United States Environmental Protection 

Agency (EPA) reported that the Committee's charter has been 

extended through September 1990, pending approval by the General 

Services Administration (GSA). 

Minutes of Previous Meeting 

The minutes of the previous full committee meeting (March 27-28, 

1990) were discussed. Changes in the minutes suggested by Mr. 

Larry Goodheart [representing the American Petroleum Institute 

(API)] and Mr. Jack Kace [representing the Pharmaceutical 

Manufacturers Association (PMA)] are contained in Attachment 3. 

Scope of the Standard 

Mr. Bob Ajax of EPA, responding to a question from Mr. Goodheart, 

told the committee that the Hazardous Organic NESHAP (HON), of 

which the negotiated standard will be a part, will regulate 150 to 

250 source categories that produce or use as an intermediate any 

of the 191 hazardous air pollutants (HAPs) listed in the proposed 

Clean Air Act amendments. A National Air Pollution Control 

Techniques Advisory Committee (NAPCTAC) meeting discussing the HON 

will probably be held in late summer or fall 1990. 

Mr. Kace noted that the scope of the HON is much broader than the 

scope of the existing EPA New Source Performance Standard (NSPS) 

for equipment leaks (40 CFR Part 60, Subpart W) , which regulates 

378 listed Synthetic Organic Chemical Manufacturing Industry 

(SOCMI) chemicals. 
P.4 

Mr. Goodheart expressed a thought that benzene/toluene/xylene 

(BTX) facilities possibly should be included as a refinery source 

category, not a SOCMI source category. Mr. Ajax responded that 

EPA was defining source categories for the HON outside of the 

negotiation. He indicated that the source categories to be 

regulated would be proposed for comment. He felt BTX units would 

likely be considered as SOCMI sources. 

Exemptions from the Standard 

Committee members discussed possible exemptions from the 

negotiated standard for pilot plants and research and development 

(R&D) facilities. Mr. Kace stated that the Senate clean air bill 

currently excludes pilot plants, while the House bill does not 

clearly address this issue. He recommended a delay in the 

decision to include or exclude pilot plants from trie standard 

until the Congressional language is finalized. Mr. Kace felt that 

pilot plants and R&D facilities should be exempted from the 

standard unless they are part of a major emitting facility. Mr. 

Ajax replied that the equipment leak Maximum Achievable Control 

Technology (MACT) that the committee members are negotiating could 

apply equally well to pilot plants and R&D facilities and that he 

was not clear on the reason (except for a Congressional decision 

or similar broad exemption) to exempt them from the negotiated 

standard. He noted that chemical industry pilot plants can be 

quite large. Mr. Ajax and Mr. Harvel Rogers (representing the 

Jefferson County (Kentucky) Air Pollution Control District) agreed 

that pilot plants and R&D facilities should not be exempted merely 

because the materials produced are not intended for sale. They 

added that any exemption should be based on objective criteria, 

such as size. 

Mr. Tom Kittleman, representing the Chemical Manufacturers 

Association (CMA), discussed CMA's proposed general exemptions 

from the negotiated standard (included in Attachment 4). 

Committee members commented on two proposals to exempt facilities 

with less than a de minimis number of valves or pumps. Mr. Rogers 

recommended combining the proposals to exempt facilities with less 

than a de minimis number of total equipment components (except 

flanges). Mr. Les Montgomery of the Texas Air Control Board 

(TACB) suggested a two-stage exemption criterion whereby 

facilities with less than a de minimis number of equipment 

components (- 50) would be exempt from the standard and facilities 

with an intermediate number of equipment components (- 200) would 

be subject to the standard but not the penalty of more frequent 

monitoring resulting from failure to comply with the standard. 

Mr. Kittleman was interested in the TACB suggestion. Mr. Ajax 

expressed concern that 50 uncontrolled components would represent 

a significant quantity of emissions. 

Committee members also commented on a CMA proposal to exempt 

equipment components in HAP service less than a de minimis time 

period (for example, some components in batch processes or 

components used only in plant start-ups or shutdowns). Committee 

members were not able to agree to a de minimis time limit. 

Committee members discussed exemptions for glass and glass-lined 

pipe, which is used in the pharmaceutical industry. Mr. Ajax felt 

that glass-lined components might be included indefinitely in an 

unrepairable pool. 
._-£. 

Standards for Valves 

Mr. Kittleman presented CMA's regulatory proposals for controlling 

HAP emissions from valves (included as Attachments 5 and 6). 

Comments from committee members are summarized below. 

Phase-in Times 

Committee members discussed the timeline for implementation of the 

standard. Phase 3 of the standard was anticipated to begin five 

to six years from today, according to EPA and CMA recommendations, 

respectively. Mr. David Doniger of the Natural Resources Defense 

Council (NRDC) questioned the rationale for delaying 

implementation of the standard for five years when the standard 

will basically be agreed upon by the end of the negotiations. 

Unrepairable Valve Pool 

While committee members generally agreed with the concept of an 

unrepairable valve pool for valves that repeatedly leak, they 

differed in the implementation time for the pool. Mr. Kittleman 

suggested that the unrepairable valve pool exist for two years or 

two scheduled shutdown periods after Phase 3 begins, whichever is 

longer. Mr. Ajax suggested that the unrepairable valve pool exist 

for two years or two scheduled shutdown periods after promulgation 

of the standard. Mr. Doniger felt that the maximum time allowance 

of two shutdowns was too long. Some members suggested that the 

unrepairable pool only be allowed under a quarterly monitoring 

program and not be used as a means for moving from quarterly to 

semiannual monitoring. 

Reasonable Further Progress Provision 

Mr. Goodheart discussed API's and CMA's thoughts on a QA/QC 

program that would respond to Mr. Ajax's suggestions at the last 

meeting. A draft that was described as demonstrating reasonable 

further progress (RFP) is included as Attachment 7. Action items 

would include participation in a program to identify low-leak 

characteristics, documentation of leak frequency versus several 

parameters like type of valve, valve manufacturer, stream phase, 

and valve age, and verification of a good-faith effort to use lowleaking valves. Mr. Ajax added that a RFP provision should be 

designed to identify the types of components and services in a 

plant that had the highest leak frequencies and include 

replacement of a fraction of facility's valves over time and 

documentation of why leakless equipment could not be applied if 

all other attempts to repair a valve failed. Mr. Rogers felt that 

facilities should verify in some way that a level of effort has 

been expended to try to reduce valve leaks and that a reduction in 

leak frequency has been achieved. Mr. David Dunn of Sterling 

Chemical Company warned that small and intermediate chemical 

producers may have trouble meeting the RFP provisions because of 

insufficient technical staff. Mr. Ajax noted that the requirement 

could be met in part by participating in CMA's POSSEE program. 

Mr. Goodheart planned to revise the RFP provisions and resubmit 

them to the committee members in approximately one week. 
P.6 

Provisions for Process-Specific Regulations 

The CMA conceptual approach for valves included a provision for 

EPA to rewrite the standard for product processes that cannot meet 

it. Some committee members felt this provision was necessary 

since data from a limited number of chemical processes will be 

used to set a standard reflecting MACT for all 191 chemicals 

listed in the proposed Clean Air Act amendments. Mr. Ajax noted 

that CMA's suggested provision would be triggered before the 

effectiveness of leak control programs was measured. He also felt 

that the provision should not allow non-complying product 

processes to have the benefit of less frequent monitoring by 

redefining the allowable leakers limit. Mr. Kace and Mr. 

Goodheart felt that this restriction would penalize non-complying 

product processes. Mr. Ajax expressed the view that the other 

provisions being negotiated provided full assurance that plants 

following the rules would not be in violation and there is no need 

for an ad hoc standard provision. 

Regulatory Exemptions 

Mr. Kittleman presented proposed exemptions from monitoring and 

maintenance requirements for valves. Subsequent discussion 

focused on three exemptions: valves on streams with vapor 

pressures of 0.05 psia or less at 20°C, valves smaller than two 

inches, and valves on streams with a de minimis concentration of 

HAPs. Several committee members felt the vapor pressure cutoff 

was high; they planned to examine the issue in greater detail 

before the next meeting. Several committee members felt there is 

no objective rationale for exempting valves smaller than two 

inches; this issue will also be revisited at the next meeting. 

Committee members did not agree on a de minimis concentration 

cutoff; suggested proposals ranges from one to five percent. Mr. 

Ajax questioned why separate de minimis concentration cutoffs 

snould be specified for single HAP streams versus HAP mixtures. 

Mr. Kittleman clarified this with an edit to CMA's suggested 

language. 

Leak Definition and Allowable Leakers 

Committee members discussed several combinations of leak 

definitions and allowable leakers limits for valves during Phase 3 

of the standard. Committee members could not agree upon any of 

the proposals. Agreement was reached that Phase 1 of the standard 

would require a LDAR program similar to the existing SOCMI 

equipment standard and that Phase 2 would be identical to Phase 1 

except for a new leak definition of 500 ppmv. Several proposals 

were discussed on the leak frequency criteria for defining 

monitoring frequency during Phase 3 of the standard. Proposals on 

the criteri.on for moving from quarterly to monthly monitoring 

ranged from two percent to four percent. Proposals for moving 

from quarterly to semiannual monitoring ranged from one percent 

to two percent. Proposals for moving from semiannual to annual 

monitoring were 0.5 percent at 500 ppm, one percent at 250 ppm 

and one percent at 500 ppm. Mr. Ajax noted that EPA was 

considering the frequency criteria in the context of the other 

provisions. He felt that the criteria were now more like goals 

without significant penalties. As such, he felt that tight 

numbers were clearly suggested by the Texas and EO data. 
P.7 

Standards for Pumps 

Mr. Kittleman presented CMA's regulatory proposals for controlling 

HAP emissions from pumps (included as Attachment 8 and part of 

Attachment 4). Comments from committee members are summarized 

below. 

Regulatory Exemptions 

The exemptions for pumps were similar to the exemptions for 

valves. Several committee members reiterated their intentions to 

examine the issues of vapor pressure and de minimis concentration 

cutoffs in greater detail. 

Reasonable Further Progress Provisions 

Mr. Ajax was not sure how a RFP provision would be developed for 

pumps. Mr. Rogers suggested that the RFP provision exist for 

three years, after which installation of dual mechanical seals be 

required for non-complying pumps or a "safety valve" be applied 

to non-complying product processes. 

Pumps Handling Food/Medical/Monomer Products 

The CMA conceptual approach for pumps recommends that 

non-complying pumps handling food or medical products or monomers 

be exempt from demonstrating RFP, since concerns with maintaining 

product purity preclude use of control techniques like dual 

mechanical seals with a barrier fluid. Instead, these pumps would 

be subject to weekly visual inspections and timely repair. Mr. 

Ajax questioned why these pumps could not be subject to a LDAR 

program in addition to weekly visual inspections. He also noted 

that a hood ducted to a control device is an alternative to dual 

seals. 

Leak Definition and Allowable Leakers Limits 

Committee members proposed several combinations of leak 

definitions and allowable leakers limits for pumps. Committee 

members could not agree upon any of the proposals. The range of 

leak definitions ranges from 1,000 ppmv to 5,000 ppmv. Mr. Kace 

and Mr. Goodheart expressed concern that many existing pumps will 

exceed any of these leak definitions. Cost to repair these pumps 

could be prohibitive. Mr. Rogers stated that the phase-in period 

before implementation of this standard should allow sufficient 

time to identify pump problems and avoid widespread immediate 

replacement. 

Dual Mechanical Seals 

The CMA proposal would require installation of dual mechanical 

seals (or equivalent control technology unless an appropriate 

exemption is proposed) if a facility cannot demonstrate RFP. Ms. 

Deborah Sheiman of NRDC questioned why facilities would be allowed 

a minimum of three years to install dual mechanical seals when the 

technology, which may represent MACT for pumps, is already used. 

Mr. Dunn stated that the pump proposal may be unfair to small 
P.8 

companies, since installation of dual mechanical seals may be 

prohibitively expensive for them. Mr. Rogers suggested that new 

pumps be required to use dual mechanical seals and that existing 

pumps install dual mechanical seals (if technically feasible) at 

the end of the existing seal life. 

Standards for Flanges 

Mr. Kittleman discussed CMA's regulatory proposals for controlling 

HAP emissions from flanges. (A portion of the discussion is 

included as Attachment 9.) CMA suggested a one-time monitoring of 

all flanges. Remonitoring would be required only if a flange has 

been disturbed. CMA felt that a one-time monitoring would be 

sufficient since flanges do not have moving parts that could lead 

to early failure and that flange data from various studies 

indicate low leak frequencies from flange populations. Mr. Ajax 

responded that the butadiene and ethylene oxide flange data snow 

that unit-specific equipment emissions are dominated by flanges in 

some plants. 

Proposals for LDAR programs were suggested by Mr. Ajax and Mr. 

Robert Majewski, representing several state regulatory control 

agencies. The LDAR programs were similar to the program for 

valves, but with less frequent monitoring requirements. Committee 

members did not agree on a regulatory proposal for flanges. 

Mr. Ajax asked if random sampling for flanges should be 

incorporated into the standard. No one expressed a desire to 

include random sampling of flanges. 

Batch Processing Issues 

Mr. Kace presented results of the batch processing work group 

meeting held on April 24 (included as Attachment 10). The work 

group developed a definition for batch processes. 

Testing requirements for batch processes were discussed. Results 

of a pressure test relating a system pressure drop to equipment 

leak emissions were presented. Mr. Kace stated that the work 

group was attempting to identify an alternative methodology for 

estimating equipment leak frequencies. 

The work group suggested that monitoring of building ventilation 

air and a comparison of the monitoring results to calculated 

allowable equipment emissions be used as an example of an 

equivalent standard in the strawman rule. Mr. Ajax thought it 

would be unnecessary to write specific equivalency standards; 

equivalency would be described in general terms with objective 

criteria (e.g., emissions). 

Miscellaneous Issues 

Committee members discussed the role of instrument response 

factors for correcting observed instrument readings. Mr. Ajax 

felt that there was no technically sound reason to ignore response 

factors. He distributed an EPA draft work plan for determining 

OVA response factors (included as Attachment 11). Mr. Kace 

suggested that EPA also investigate response factors for a few 

mixed HAP streams as well as non-HAPs. Industry members 

emphasized the practical difficulty of requiring response factor 

correction during field testing. 
P.9 

Committee members briefly discussed equivalent approaches to the 

standards for valves, pumps, and flanges. Mr. Kittleman referred 

committee members to a previous submittal (included as Attachment 

6 in the January meeting minutes) for CMA's thoughts about 

equivalent regulatory approaches. 

Committee members discussed recordkeeping and reporting 

requirements for the negotiated standards. Mr. Montgomery 

stressed the logistical need for developing a simple reporting 

format. Mr. Ajax said that the EPA will take the lead in 

developing minimum recordkeeping and reporting requirements. 

Mr. Ajax stated that existing agitator seals will be controlled as 

outlined in the strawman rule (i.e., LDAR). 

Equipment tagging requirements were briefly discussed. Because 

flanges could be difficult to tag, some committee members 

suggested that the flanges be referenced to a nearby valve or 

other equipment component for recordkeeping purposes. 

Action Items 

Mr. Goodheart will revise the reasonable further progress criteria 

and distribute them to all committee members. 

EPA will take the lead in developing minimum recordkeeping and 

reporting requirements. 

Several committee members will examine the following issues in 

greater detail before the next meeting: vapor pressure cutoffs, 

de minimis concentration cutoffs, equipment time-in-use cutoffs, 

the effect of monomers on pump performance, size cutoffs for 

valves, and leak definitions and allowable leak limits for the 

valve, pump, and flange standards. 

The batch work group will continue to examine pressure testing and 

equivalent approaches for complying with the negotiated standard. 

In addition, they will also address in greater detail the issue of 

regulatory exemptions for pilot plants and R&D facilities. 

Future Meetings 

The next meeting of the full committee is scheduled to be held on 

June 6-7, 1990 at the Compri Hotel, located at the intersection of 

Interstate 40 and Miami Boulevard, in Research Triangle Park, 

North Carolina. 

The next meeting of the batch processing work, group is scheduled 

to be held on June 1, 1990 at 10:00 a.m. at the Pharmaceutical 

Manufacturers Association, located at 1100 Fifteenth Street NW, 

Washington, D.C. 

A meeting of the full committee is scheduled to held on July 17-

18, 1990 in Washington, D.C. (location to be announced). 
P.10 

ATTACHMENT 1 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATED RULEMAKING 

'•-_' CONCERNING 

CONTROL OF FUGITIVE EMISSIONS FROM EQUIPMENT LEAKS 

AGENDA FOR MEETING OF MAY 10-11 

ADMINISTRATIVE 

• Inductions into Lame Duck Society 

• Introductions 

• Extension of the Charter 

Hotel reservations for June Meeting: Compri Hotel; 919-941-6066; block reserved for "EPA Fugitives" 

Lunch on Friday 

Review of the Agenda: additions, subtractions, order 

Minutes of March meeting: Any major heartburns 

SCOPE OF THE STANDARD 

• BTX Facilities 

• Exemptions 

VALVES 

• u^ny new proposals, thoughts, or discussions with respect to conceptual approach 

• Unrepairable component set-aside 

• Reasonable further progress/QAQC 

• "Safety Valve" for process-specific regulations 

• Exemptions from monitoring and maintenance requirements 

• Response factors 

FLANGES 

• Conceptual approach 

• Exemptions from monitoring and maintenance requirements 

PUMPS 

• Discussion of basic data 

• Conceptual approach 

• "Safety Valve" for process-specific regulations 

• Exemptions from monitoring and maintenance requirements 

OTHER EQUIPMENT 

• Type of equipment 

• Conceptual approach 
P.11 

ATTACHMENT 2 

ENVIRONMENTAL PROTECTION AGENCY 

NEGOTIATING COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOCs FROM EQUIPMENT LEAKS 

ATTENDEES LIST FOR MEETING OF MAY 10, 1990 

NAME 

Ed Moretti 

Bill Grimley 

Bruce Davis 

Jerry M. Schroy 

Raymond A. Collins 

Leigh Marks 

Jan Meyer 

Walter Brenner 

Scott Throwe 

Don Piehn 

Miriam Lev-On 

Ron Berglund 

David Markwordt 

Glenn Rives 

Kathy Kaufman 

Rick Colyer 

Ellen Siegler 

Bruce Grumstrup 

Karen Fidler 

Karin Ritter 

Mary Ann Gorko 

Robert Majewski 

David Dunn 

Robert Ajax 

Tom Kittleman 

Harvel M Rogers 

Les Montgomery 

Philip Harter 

Deborah Dal ton 

Jack Kace 

Deborah Sleiman 

Al Bickum 

Linda Curran 

L.T. Goodheart 

Gus VonBodungen 

Chuck Knebl 

Fred Dimmick 

Kathy Bailey 

Bob Strieter 

Bill Schikora 

Meredith Miller 

Maureen Healey 

Charles Bennett 

Michael Mahoney 

David Gustafson 

Desi M Chari 

John Kitchen 

Edwin (Bill) Carpenter 

Cheryl Sutterfield 

AFFILIATION 

Radian Corporation 

EPA 

Exxon Chemical Company 

Monsanto Company 

Eli Lilly & Company 

Eli Lilly & Company 

EPA 

SUN Company 

EPA 

John Crane, Inc. 

ARCO 

Union Carbide 

EPA 

Radian 

EPA 

EPA 

API 

Fisher Controls Company 

CMA 

API 

DuPont 

NESCAUM 

Sterling Chemicals, Inc. 

U.S. EPA 

CMA (DuPont) 

Jefferson Co. APCD (Law Env.) 

Texas Air Control Board 

Facilitator 

EPA 

PMA (Hoffmann La Roche) 

NRDC 

IISRP (Goodyear) 

Amoco Oil Company 

API/Chevron 

LA DEQ-Air Quality 

Bus. Publ. Toxic Materials News 

EPA/OAQPS/RTP 

CMA 

API 

Chevron 

Fisher Controls 

Soc. of the Plastics Ind. 

Ashland Petroleum 

Pfizer Inc. 

Dow Chemical 

Safety-Kleen Corp 

DuPont 

Durametallic (STLE) 

PMA 
P.12 

ATTACHMENT 3 

REVISIONS TO MARCH MEETING MINUTES 

First bullet under Scope of the Standard (page 1) 

• Mr. Larry Goodheart, representing API, reported that API is 

awaiting data from several refineries that may impact the scope of 

the equipment leaks standard. He requested a delay in the 

discussion of the scope of the standard until API receives those 

data. 

Second bullet, third paragraph under Ancillary Factors of the Standard 

(page 5) 

• The workshop also plans to discuss a LDAR frequency for batch 

components based on time in use of the components. Future 

discussions include the possible exclusions of pilot plants into 

the standard, alternative test methods, and a de minimis time in 

use cutoff. 
P.13 

ATTACHMENT 4 

iza 

CHEMICAL MANUFACTURERS ASSOCIATION 

May 7, 1990 

TO: Equipment Leaks Regulatory Negotiation Committee 

FROM: Karen K. Fidler ^G^W^ / 

SUBJECT: Regulatory Exemptions. 

Attached are CMA's suggestions for the following types of 

regulatory exemptions: 

1) Exemptions from monitoring and maintenance 

requirements for pumps. 

2) General exemptions from equipment leak 

regulations. 

2501 M Street, NW. Washington. DC 20037 202-887-1100 Telex 89617 (CMA WSH) 
P.14 

GENERAL EXEMPTIONS FROM EQUIPMENT LEAK REGULATION 

Exemption Rationale 

1) Facilities that emit less than 

10 tpy of a single HAP or 

25 tpy of all HAP. 

Consistent with CAA Legislation. 

2) Facilities with less than 

valves in HAP service. 

Exempt from valve and flange 

requirements based on de 

minimis emissions. 

3) Facilities with less 

than pumps in HAP service. 

Exempt from pump requirements 

based on de minimis emissions. 

«) Pilot facilities emitting less 

than tpy. 

Pilot facility operations can be 

highly variable as well as shortlived-* making routing monitoring 

requirement difficult to 

implement. 

5) Empty equipment. Does not emit HAP. 

6) Components in HAP service less 

than months* including 

temporary connections. 

Potential to emit HAP is low; 
Exemption 

Pumps equiped with closed-vent 

system to a control device 

Pumps in unmanned plant sites 

Pumps in vacuum service 

Pumps on streams with 

aggregate partial pressure 

or vapor pressure of 0.05 

psia or less at 20 C 

Pumps on streams that average 

less than _ X by weight HAP 

mixture and X by weight of 

any pure HAP 

Pumps on streams handling HAP's 

for which no monitoring method 

is available 

PUMPS 

EXEMPTIONS FROM MONITORING AND MAINTENANCE REQUIREMENTS 

Current Regulations 

EPA TACB 

40CFR61.242-21f) 

40CFR61.242-2(g) 

40CFR61.242-11e) 28 HID, paragraph A 

28 MID, paragraph A 

40 CFR61.241Cb) 28 MID, paragraph A 

Method 21 

RATIONALE 

Emissions are captured and controlled by 

95% or more. 

Exempt from weekly visual inspections; 

however, periodic monitoring wffch screening 

instrument still required. 

Equipment in vacuum service generally do 

not leak to atmosphere. 

Focuses efforts on VOC and chemicals of 

greatest concern. 

Focuses efforts on the most significant 

emissions sources. 

Monitoring methods must be developed 

before leak detection programs can be 

applied to these compounds. 

*0 
BASIS: 

1. THISCHART APPUES TO A PROCESS UNIT 

2. AVERAGE OP TWO CONSBCUTIVB MONITORINO 

-PERIODS (AT SPECIFIED LEAK RATE) ARB REQUIRED TO 

CHANGE (INCREASB OR DECREASE) IHE MONITORING 

FREQUENCY IN PHASED! 

3. PHASE II AND in LEAK DEFINITION IS 500 BASED ON 

METHOD 21. 

• FOR 2 YEARS OR 2 SCHEDULED SHUTDOWN PERIODS 

AFTER PHASB ID BEGINS. WHICHEVER IS LONGER. 

COMPONENTS FOR WHICH ALL RBPAIR ATTEMPTS FAILED 

WILL NOT BE COUNTED WHEN CALCULATING % LEAKERS 

START 

YEAR 2 

PHASE I LDAR 

10,000 PPM 

NORF 

YEAR 5 

I 

VALVES 

PHASE II LDAR 

500 PPM 

NORF 

ES3SSS52SSS 

<2% FOR 2 CONSEC. 

PERIODS. OPTION TO 

ELECT VOLUNTARY 

EXIT 

<xxx><x>Wsy>^^ 

—<4%-

MONTHLY 

ALL VALVES 

L-YESI 

->4%- QUARTERLY 

ALL VALVES 

>4% OR 

REASONABLE 

FURTHER 

PROGRESS 

(SEE ATTACHED) 

>2% 

OR 

PROCESS SPECIFIC 

REGULATIONS 

(SEE ATTACHED) 

— I — 

<2% 

CANNOT RETURN TO 

PHASE I OR II 

SEMI-ANNUAL 

ALL VALVES 

-r 

> U% 

<\5% IL 

> 

> 

o 

m 

Ol 

-<05%-

->0J%-

ANNUAL 

ALL VALVES 

X 

SEMI-ANNUAL 

OF 25% VALVES 
P.17 

ATTACHMENT 6 

CHEMICAL MANUFACTURERS ASSOCIATION 

May 3, 1990 

TO 

FROM 

SUBJECT 

Equipment Leaks Regulatory Negotiating Committee 

Karen Fidler 

Regulatory Proposal for Valves 

Attached are CMA's suggestions on the following elements of the 

regulatory framework for valves discussed by the Committee at the March 

26-27 Reg-Neg meeting: 

1) Unrepairable Component Set-Aside. 

2) Reasonable Further Progress Criteria. 

3) Provision for Process-Specific Regulations. 

4) Exemptions from Monitoring and Maintenance Requirements. 

2501 M Street. NW, Washington, OC 20037 202-887-1100 Telex 89617 (CMA WSH) 
P.18 

Reasonable Further Progress Criteria 

The Reasonable Further Progress (RFP) demonstration is an option 

for the individual process unit when it can not meet the Phase 3 

performance goals. The RFP demonstration would document how the plant 

is striving to meet the performance goals. The elements of the RFP 

demonstration should include: 

1) Documentation of the efforts by the plant to review 

technology options for replacing leaking components. 

2) Documentation of the extent to which replacement 

technology has been used to reduce leaks. 

3) Schedule and plans for future application of replacement 

technology to reduce leaks. 

4) Documentation of quality assurance/quality control 

(QA/QC) procedures used in the specification, inspection, and testing 

of components prior to installation. 

5) Documentation of plant efforts to minimize the components 

on a list for repair at the next turnaround. 

6) Documentation of how plant has attempted to assure that 

off-line repair readiness is maintained In the event of an unplanned 

shutdown. 
P.19 

Unrepairable Component Set-Aside 

Often, leaking components cannot be repaired successfully without 

taking the equipment off-line. To avoid excess emissions and cost 

impacts associated with shutting down equipment to repair it, these 

components should be placed on a list for repair at the next 

turnaround. Some plants and processes operate continuously for up to 

eight years between scheduled turnarounds. For such plants, it is 

possible to accumulate a pool of unrepairable components in excess of 

the Phase 3 performance targets. 

Recognizing that it will take several years and several 

turnarounds for plants to gain enough experience with new technologies 

and practices to meet the Phase 3 performance targets, plants should 

not be penalized with more frequent monitoring requirements because of 

unrepairable component accumulations during the initial stages of a 

leak reduction program. 

Accordingly, the regulation should contain the following 

provisions for an unrepairable component set aside. 

1) Until 2 years or 2 scheduled shutdowns have 

passed (whichever is longer) after 

Phase 3 begins, unrepairable components will be excluded 

from calculation of % leaking components. 

2) This exclusion applies to process units that are unable 

to meet the Phase 3 quarterly monitoring performance 

targets. 
P.20 

Provisions for Process Specific Regulations 

Recognizing that some source categories may have problems 

achieving the Phase 3 performance targets, the regulation should 

contain provisions for EPA to develop process-specific regulations when 

needed. The need for process-specific regulations would become 

apparent at the beginning of Phase 3 when the majority of individual 

facilities within a source category are unable to meet the Phase 3 

performance targets. The provisions for process-specific regulations 

should include: 

1) Source categories may apply for an alternative 

process-specific regulation if fewer than 10% of 

facilities in the source category (or 3 if the total 

number of facilities in the source category is less than 

30) are meeting the Phase 3 performance targets. 

2) Facilities within the source category must provide 

adequate data and other information to demonstrate the 

need for an alternative standards and to serve as the 

basis for setting the new standard. 

3) EPA must propose and take comments on the alternative 

standards and on any negative determination made in 

response to source category applications. 
P.21 

Exemptions Froa Monitoring and Maintenance Requirements 

Attached is a table listing exemptions from monitoring and 

maintenance requirements that should be included in the regulation for 

valves. Each of these exemptions appear in EPA's and/or TACB's 

existing regulations for equipment leaks. 
Exemption 

VALVES 

EXEMPTIONS FROM MONITORING AND MAINTENANCE REQUIREMENTS 

Current Regulations 

EPA TACB Rationale 

Inaccessible and/or 

Unsafe-to-Monitor Valves 

Valves on equipment in 

vacuum service 

Valves on streams with 

aggregate partial 

pressure or vapor 

pressure of 0.05 psia 

or less at 20 C 

Valves smaller than 2 

inches 

Valves on streams that 

average less than X 

by weight HAP mixture 

and % by weight of 

any pure HAP. 

Valves on streams 

handling HAPs for 

where no monitoring 

method is available 

(i.e., inorganic 

vapors on metal salts) 

40 CFR 61.242-7(g) 

40 CFR 61.242-l(e) 

28 MID, paragraph D 

28 MID, paragraph A 

28 MID, paragraph A 

40 CFR 61.241(b) 

28 MID, paragraph A 

28 MID, paragraph A 

Method 21 

Monitoring components that are 

inaccessible and/or unsafe-tomonitor pose unnecessary risk 

to plant personnel. 

Equipment in vacuum service 

generally do not leak to 

atmosphere. 

Focuses efforts on VOC and 

chemicals of greatest concern. 

Focuses efforts on line sizes 

of greatest concern. 

Focuses efforts on the most 

significant emissions sources. 

Monitoring methods must be 

developed before leak detection 

programs can be applied to 

these compounds. 
P.23 

ATTACHMENT 7 

REASONABLE FURTHER PROGRESS CRITERIA 

Date: May 10, 1990 

BACKCRO0ND 

The elements of reasonable further progress were discussed at 

the May 10 regulatory negotiating meeting. As a result* of the 

discussions, modifications/clarifications of the industry 

proposal follow. 

DISCUaSSION 

The Reasonable Further Progress (RFP) demonstration is an 

option for the individual process unit when it can not aoet the 

Phase 3 performance goals. The RFP demonstration would document 

hova- the plant is striving to neet the perfonmance goals. The 

elements of the RFP demonstration should include: 

1. Low Emission Performance Technology Review 

Action Items for this review shall include: 

A. Participate in an intor -coapany or intra~company 

program which reviews the emission performance of 

coapononts. Tho program shall include an wf-fort to 

relate equipment, process and operating variables to 

emissions performance. The CMA Plant Organizational 

Software System for Emissions from Equipment 

(POSSEE) is an example of an effort to review* the 

details related to emission performance for 

equipment emissions. The results of this effort 

shall provide details on the appropriate technology 

and operating practice changes needed in the plant 

to achieve low. emission performance. In addition, 

this effort will provide information on 

technology/operating practices where emissions are 

difficult to control. 

B. Analyze the emission performance data and determine 

which iix of technology and operating practices will 

result in the low emission performance goals set by 

these standards. 

C. Implement the technology and operating options 

identified by the eaission performance review. At a 

minimum, these options could include items such as: 

1. Early plant trials to establish the success or 

failure of potential technology or operating 

changes. If possible the trials shall be 

conducted on equipment which is accessible 

prior* to turn around. 
P.24 

2.. Low-emission per-forfcsnero Lculiftotogy trial s for 

- '-_ unrepair abl e cvmputttrtj.ts to test new technology 

a s follows, to be installe d a t a turn around: 

a. 50 |^nx«it of (ati>*pai tabl e valves. 

b . At least one unrepairable* pump. 

2. Develop *od Pwplcaent th e Quality Coatrol and Quality 

Assurance Procedures to Achieve Low Emission Perforra«*iveft 

Action It<-.«s for this review shall include: 

A. Based on the infui-wetion gained froi* the Low 

Emission £t*ifor»&nce Techaelosy Review, the plan t 

shal l develop and implem*.**! changes to it s equipaea l 

pairchasiag, specif ication . ia*.:p^tion .aad testin g 

practice s to assur e tha t low emission performance 

technology aud o^eiatia g practice s ar e inoorpoi-«*tod 

int o th e plant business practio?t>. 

3. Iff^fltKR^iitation P-l&ns aad Schedule for Achieving Low 

E&ttission Perfor&aftce 

Tiie plan s aftd scheduler for achieving lav emission 

performance ahall include th e following elemeatu: 

A. (lew the pt**ut will wininrize the member of cempoixmts 

on a tur n arouad list for repair. 

8. Sow the plao t will assur e thai uff-4in e r<s-pair 

readiness is maintetined in the event of an unplajou**4 

turnaround. 

C. The schedule and plans for the instal l a t iu» of low 

emission (<« fu**»KHn.T technology. 

D. D©eumeai><*tiofi of the opet-Ating* practice s and th e 

i-alcrted trainin g to aichiuvo low. oaissi-wi 

perf <JI iiixntca>. 

In tin; cv*snt tha t l-.We RFP desoA&fcratic* ds*?t>* not xtrsult 

in th e achiev*:ui&**«4i* uf th e pe ; f unaaab-e goals of the 

staadard, and no further technolagy or v**fi*ating 

impi-ov^m*?;*!-. ar e passible , thc a th e facilit y shall remaiz 

ia quarterl y leak detectiGn ami repair with bi -asaual 

review of technology- ad*-*«v>?>iic*vt.s. 
i?-'; H--£?J 'tii^B'^iW^M^' *''.$$?> PUMPS 

->20%-

>10% <10%OR2PUMPS 

>5% <5% OR ONE PUMP 

ANNUAL 

FOOD/MEDICAL 

PRODUCT PURITY 

MONOMERS 

YES 

NO i 

DEMONSTRATE 

REASONABLE 

FURTHER 

PROGRESS 

(See attached) 

I 

AFTER 3 YEAR 

DUAL MECH 

SEALS OR 

EQUIVALENT 

WEEKLY 

VISUAL 

OBSERVATIONS 

(^SsiRVABL>\ 

V^DRIP^-^ 7 

r 

YES 

APPROPRIATE 

REPAIR 

1 

OTHER 

EXEMPTIONS 

IAS APPROPRIATE 

NO 

> 

> 

o 

m 

oo 
P.26 

ATTACHMENT 9 

CHEMICAL MANUFACTURERS ASSOCIATION 

May 7, 1990 

TO: Equipment Leaks ReguLator ReguLatory Negotiatio 1 n Committee 

FROM: Karen K. Fidler 

SUBJECT: Regulatory Proposal for Flanges 

Attached is the following information prepared by CMA pertaining 

to the regulatory framework for flanges discussed by the Committee at 

the March 26-27 Reg-Neg meeting: 

1) Analysis of flange emissions presented by 

Ron Berglund of Union Carbide Corporation 

at March 26-27 meeting. 

2) Description of basis for CMA's proposal for 

flanges at March 26-27 meeting. 

3) Suggested exemptions from monitoring and 

maintenance requirements for flanges. 

2501 M Street. NW. Washington. DC 20037 202-887-1100 Telex 89617 (CMA WSH) 
P.27 

BASIS FOR CMA's PROPOSAL FOR FLANGES 

At March 26-27 Meeting 

Flanges 

CMA believes it may be helpful to other Committee members to know what 

industry's basic beliefs about leakage from flanges are and why we have 

these beliefs. 

We believe that once connections are properly made, it is unlikely that 

a leak will occur for a long time. Unlike pumps and valves, there 

should be no mechanical action on flanges which could lead to early 

failure. Flange data from various screening studies verify this 

belief. The similarity of flange screening results across diverse 

industry sectors also supports the contention that there is no 

performance difference due to maintenance practices. 

We believe that flange emissions are low even though they dominate the 

number of components. At the last meeting, potential emission factors 

for flanges were presented. We have reviewed those factors and believe 

they significantly overestimate flange emissions due to over-prediction 

at the high emission end. 

For example, all flange data were based on partial samples. With 

partial samples, there is always the risk that the sample will not be 

representative for one reason or another. As it turns out, the 

emission rate for one flange at one plant was estimated in an 

inappropriate way that probably gave a high prediction. The effect of 

this one flange on the resulting emission factor estimates was enormous 

and leads to anomalous conclusions. 

It will be some time before all the information necessary to arrive at 

a good emission factor for flanges is available. We expect to have 

opportunities to discuss the subject in greater detail before that time. 

Likewise, we believe that the emission factors presented at the last 

meeting also over predicted at the low end such that a high portion of 

the emission estimates comes from the "default zeros." For instance, 

about one-third of the emissions using what we believe to be the best 

estimate for a plant at 1% above 500 ppm is due to flanges at the 

default zero. Indeed, some of the plants in the study had no emissions 

above the default zero. We don't believe the default zero itself is 

realistic; nonetheless, the obvious conclusion is that there is little 

that can be done to reduce these flange emissions whether these 

emissions are real or imagined. 

In short, we believe there is very little to be gained by any flange 

monitoring requirement. 
P.28 

Flanges 2 

At the. last meeting, we proposed a way to focus a flange monitoring 

program-on those components most likely to leak (i.e. those recently 

disassembled for maintenance). It appears to be industry practice to 

open about 10 to 20% of the flanges during a maintenance "turnaround". 

We discussed this with plant people in three companies and got 

basically the same answer from all. For instance, some 

process-specific numbers are given below. 

Process No. 

1 

2 

3 

4 

5 

6 

No. of Flanges 

Opened During 

Turnaround 

367 

90 

378 

414 

150 

290 

Total Number 

of Flanges in 

Process 

1,730 

700 

1,820 

1,730 

700 

1,338 

We still believe that a one-time monitoring of all flanges and 

follow-up screening of only those that have been opened, would be 

effective emission control approach. We recognize, however, that this 

approach was not well received by some committee members. Indeed, some 

industry people prefer monitoring all flanges, rather than have the 

recordkeeping hassles of selective monitoring. By the next meeting, we 

will have a specific proposal to make. 

No matter how that proposal is structured, we don't believe it is 

appropriate to think in terms of the same types of monHorJng 

frequencies considered for valves. 
P.29 

CMA ANALYSIS OF FUGITIVE EMISSIONS 

FROM FLANGES AND CONNECTORS 

Prepared By 

Ronald Berglund 

Union Carbide Corporation 

For Presentation Before 

THE ENVIRONMENTAL PROTECTION AGENCY NEGOIIA11NG COMMITTEE FOR 

CONTROL OF FUGITIVE EMISSIONS OF VOC FROM EQUIPMENT LEAKS 

March 26-27, 1990 
P.30 

Introduction 

Flanges and other connectors comprise the single largest class of 

fugitive emission sources 1n a process unit, often representing 601 of the 

total components 1n a unit. Flanges are gasket-sealed junctions used to join 

pipe and other equipment such as valves, vessels and pumps. Flanges are 

usually used on pipes of sizes of 2 Inches or greater 1n diameter. For pipe 

sizes less than 2 inches, other types of connectors such as threaded 

connections and nut-and-ferrule connections are usually used (1). 

Hhile flanges will comprise the greatest number of fugitive emission 

sources 1n a typical process unit, 1t 1s generally agreed that emissions from 

Individual flanges will be small relative to other emission sources (2). 

Using the Average EPA SOCMI factors, 1t would be expected that emissions from 

a typical flange would comprise less than IX of that from a pump, or one tenth 

that from a valve. The difference between a non-1eaklng flange (screening 

value less than 10,000 ppm) and a non-1eaklng valve or pump 1s even greater. 

In the bagging studies conducted around refineries, 1t was estimated that 

leakage from a flange would be about 21 of that from a valve (3). Yet, 

despite the small emissions associated with flanges, continued concern has 

been raised over the exclusion of these components 1n the existing fugitive 

emission regulations. 

Recent Studies on Fiances 

In the recent Industrywide fugitive emissions studies in the acrolein, 

phosgene, butadiene, and ethylene oxide production industries (4,5), over 

35,000 flanges and connectors were monitored. Because of the large number of 

flanges 1n a unit, each participating unit was required to only sample a 

percentage of its flanges (15 to 301) (6). Some units sampled all of their 

flanges, but, overall, it 1s expected that between one quarter and one third 

of the flanges 1n these industries were Included in this population. 
P.31 

The screening values for flanges for the four Industry groups are 

summarized In Figure 1. As expected, very few leaking flanges were found 1n 

these studies. For the ethylene oxide and butadiene Industries, 14,705 

flanges were monitored; 901 of the flanges had screening values less than 10 

ppm, with only 0.261 of the flanges 'Leaking' (screening values above 10,000 

ppm), and 0.61 having screening values above 1,000 ppm. 

Previously, it was reported that 2.11 of the flanges monitored 1n the 

SOCMI program had screening values above 10,000 ppm. However, 1n the earlier 

refinery studies, no leaking flanges were found (out of 2,000 screened), and 

only 3.11 of the flanges had screening values above 200 ppm. Clearly, leakage 

from flanges has always been low. 

Causes of Fugitive Emissions from Flanges 

According to the EPA (1,2), flanges and other connectors may leak 

Volatile Organic Chemicals (VOC) as a result of: 

- improperly selected gaskets 

- poorly assembled flanges 

- poorly assembled nut-and-ferrule combinations, or 

- cross-threaded pipe connections 

All of these causes should be apparent shortly after installation. 

The EPA has also Indicated that the major cause of VOC leakage from 

flanges and other connectors 1s deformation of sealing surfaces as a result of 

thermal stress (2). Other causes of leakage from flanges might be improper 

design or application, stress on the joint through external loading, weak or 

poorly located supports, or chemical or environmental corrosion. 

As with any other piece of equipment, the rate of appearance of leakage 

from a flange can generally be expected to follow reliability principles. 
P.32 

Reliability 

Reliability (7) is "the probability that a component will perform U s 

Intended function, satisfactorily, for its Intended life when operating under 

specified conditions." Such a definition can be seen as a probabilistic 

concept Involving a product's planned use, its operating environment and time, 

and can only be expressed as a probability. Several types of data are needed 

to assess product reliability: cumulative operating time, number of failures, 

and conditions present at the time of each failure. From a fugitive emissions 

standpoint, the term 'failure' will be left undefined. But, historically, 1t 

could mean (a) the complete failure of the component, and resulting severe 

leakage, (b) a component with a screening value above 10,000 ppm, or (c) a 

component with a screening value above some lower level. 

In the broadest sense, only two types of information are required to 

calculate the overall reliability of a component: 1) total number of failures 

1n the period of Interest, and 2) total cumulative operating time for that 

component. The most common unit of reliability 1s the Mean Time to Failure 

(MTTF). If the component can be repaired, a term Mean Time Between Failure 

(MTBF) may also be used (8). The mean time between failure 1s the mean time 

that a component can be expected to operate before 1t falls (leaks). In this 

analysis, a term, the Mean Time Between Leaks (MTBL) will be used to estimate 

the expected leak rate for a flange 1n the ethylene oxide or butadiene 

industries. 

A term, the Reliability Function would represent the probability that a 

component will survive to a given time, given It has survived to the present. 

For any leak definition, the reliability function would represent the fraction 

of components which have not begun to leak during the appropriate monitoring 

period. 

The Reliability Function, R(t), can be defined by the relationship: 

R(t) - exp (-t/MTBL) 

where t 1s the time period over which the leaks had accumulated. 
P.33 

5 

While the failure rate curve (the 'bath-tub' curve in Figure 2) 

includes failures appearing during both the Initial break-In period and the 

later wear-out period, the reliability equation applies to the flat middle 

portion of the failure rate curve where the failure rate 1s constant, and 

would be a cumulative representation of all failures up to that time (Figure 

3 ) . This portion of the curve represents the design failure rate for the 

specific product as present during Its useful life in the operating unit. 

Example: Flanges 

Some Insights on expected leakage from uncontrolled flanges can be 

developed by applying the concepts of Reliability to the flange monitoring 

data obtained 1n the ethylene oxide and butadiene fugitive emissions studies. 

This data represents fugitive emissions from flanges which have not been 

regularly monitored. It is estimated that they have been 1n place for about 

five years, with minimum checking for leakage. The results from these studies 

are summarized below: 

Screening Value 

Ranoe. com 

MO.OOO 

> 1.000 

> 100 

1 In 

Caifiaany 

0.261 

0.321 

0.611 

Total 1 Above 

Level 

0.261 

0.581 

1.201 

While it 1s recognized that a good proportion of the leakage would 

appear during the break-In period, shortly after installation, and could be 

detected and repaired at that time, a worst case assumption would be to assume 

that the leakage will accumulate regularly over a five-year period. In this 

case, a Mean Time Between Leak (MTBL) can be calculated from the above data, 

using the relationship: 

Fraction Leaking - 1 - exp [-t/(MTBD] 
P.34 

*" 

While the failure rate curve (the 'bath-tub' curve in Figure 2) 

includes failures appearing during both the initial break-In period and the 

later wear-out period, the reliability equation applies to the flat middle 

portion of the failure rate curve where the failure rate 1s constant, and 

would be a cumulative representation of all failures up to that time (Figure 

3 ) . This portion of the curve represents the design failure rate for the 

specific product as present during Its useful life 1n the operating unit. 

Example: Flanges 

Some insights on expected leakage from uncontrolled flanges can be 

developed by applying the concepts of Reliability to the flange monitoring 

data obtained in the ethylene oxide and butadiene fugitive emissions studies. 

This data represents fugitive emissions from flanges which have not been 

regularly monitored. It 1s estimated that they have been 1n place for about 

five years, with minimum checking for leakage. The results from these studies 

are summarized below: 

Screening Value 

Range. DDID 

>10.000 

> 1,000 

> 100 

1 in 

Cateqory 

0.261 

0.321 

0.611 

Total 1 Above 

Level 

0.261 

0.581 

1.201 

While 1t 1s recognized that a good proportion of the leakage would 

appear during the break-in period, shortly after Installation, and could be 

detected and repaired at that time, a worst case assumption would be to assume 

that the leakage will accumulate regularly over a five-year period. In this 

case, a Mean Time Between Leak (MTBL) can be calculated from the above data, 

using the relationship: 

Fraction Leaking - 1 - exp [-t/(MTBD] 
P.35 

Using this equation, with the above data, and assuming that t 1s five 

years for the units included in the study, the following table can be 

developed: 

Screening Value 1 In or MTBL Percent Exceeding 

Range, ppm above level Years Per Year 20 Year 

>10,000 0.261 1922 yrs 0.051 1.001 

> 1,000 0.581 860 yrs 0.111 2.301 

> 100 1.201 414 yrs 0.241 4.701 

These observed leaks are representative of these Industries during a 

time when they had no comprehensive fugitive emissions control program for 

flanges (although severe leaks were rapidly repaired). Considering that the 

representative time that the components were In the unit would be of the order 

of five years, this table presents the fraction of components that would be 

expected to begin to leak (at various levels) at the end of a year, five 

i 

years, or over a twenty-year cycle for the unit. 
EPA Study (24 Plants) 

Ethylene Oxide Industry (12 Plants) 

Butadiene Industry (13 Plants) 

Acrolein Industry (2 Plants) 

Phosgene Industry (13 Plants) 

(*100ppm) (»1,000 ppm) (>10.000) 

Screening Values 

Rgure 1: A Comparison of Leak Frequencies for Ranges In Acrolein, 

Butadiene, Ettiytene Oxide and Phosgene Industries 

Relative to the Orginbal EPA Studies 
P.37 

-HEN- -

EQUIPMENT 

LEAKAGE 

t 

O 

z 

55 

5 

OC 

u 

BR.EAK-IN 

PERIOD 

NORMAL 

OPERATING 

PERIOD 

WEAROUT 

PERIOD 

TIME 

RGURE 2: Typical Life Characteristic Curve 

For a Population of Ranges 

(The 'Bathtub' Curve) 

CUMULATIVE 

LEAKAGE 

(NO REPAIR) 

1 

O 

z 

V) a 

c 

u 

z 

i y"" Je 

/ • 

/ 

/ ! / a / / | 

7 | / | / • / / 

..,- ' 

/ 

' 

BREAK-IN 

PERIOD 

NORMAL 

OPERATING 

PERIOD 

WEAROUT 

PERIOD 

TIME 

RGURE 3: Cumulative Leakage 

.For a Population of Flanges 
Exception 

FLANGES 

EXEMPTIONS FROM MONITORING AND MAINTENANCE REQUIRENENTS 

Current Regulations 

EPA TACB 

Inaccessible and/or unsafe-toaionitor flanges. 

Insulated flanges 

40CFR61.242-7(g) 28 MID, paragraph D 

Equipment body flanges 

Flanges on oquipaont In 

vecuua service 

Flanges on streeas with 

partial pressure or vapor 

pressure of 0.05 psia or 

loss at 20 C 

Flanges saaller than 2 inches 

Flanges on stroaas that average 

less than _X by weight HAP 

Mixture and X by weight of any 

pure HAP 

40 CFR61.242-l(e) 28 MID, paragraph A 

28 HID, paragraph A 

40 CFR61.241(b) 

28 HID, paragraph A 

28 HID, paragraph A 

Flanges on streaas handling HAPS 

for which no Monitoring Method 

is available 

Method 21 

RATIONAL 

Monitoring cpaponents that are 

inacceslble and/or unsafe-to-aonitor 

pose unnecessary risk to plapt 

personnel. 

Insulation plays an iaportant role in 

assuring stabler energy-efficient 

operation of processes and equipment. 

Reaoval and replaceaent of insulation 

can interfere with plant operation as 

well as result in substantial cost 

penalties. In seen cases, reaoval of 

insulation aay lead to foraation of 

leaks froa gasket aaterials. 

Depending on size and location, these 

aay be extreaely difficult to Monitor 

using portable detectors. 

Equipaent in vacuua service generally 

do not leak to ataosphere. 

Focuses efforts on V0C and cheaicals of 

greatest concern. 

Focuses efforts on line sizes of 

greatest concern. 

Focuses efforts on the aost significant 

aaission sources. 

Monitoring aethods aust be developed 

before leak detection prograats can be 

applied to these coapounds. 
P.39 

ATTACHMENT 10 

Batch Workgroup Meeting Minutes - April 24, 1990 

Attendees 

Jack Kace 

Bob Rowland 

Rich Vaccaro 

Leigh Marks 

Raymond Collins 

Leonar £. Samuelson 

Laura Greninger 

Al Bickum 

Mary Legatski 

Cheryl Sutterfield 

Hoffmann-La Roche Inc. 

Pfizer 

American Cyanamid 

Eli Lill y 

Eli Lill y 

Bristol-Myers Squibb 

Sterling Drug 

IISRP 

SOCMA 

PMA 
P.40 

Batch Workgroup Meeting Minutes 

April 24, 1990 

The definition of batch process equipment was agreed to. Batch Process 

equipment is defined as process equipment which is fed intermittently 

or discontinuously. Processing then occurs in this equipment after which 

the equipment is generally emptied. Only batch process equipment in use 

with a hazardous air pollutant less than 80% of the total available time 

(8,760 hours/year) is eligible for treatment under Section 4b of this 

rule. 

The testing requirement for batch process equipment was discussed. The 

suggested addition to Section 4b of the Strawman. was: The following 

requirements apply to batch process equipment that is in use with a 

hazardous air pollutant during any part of the calendar year. Facilities 

that have both continuous and batch processes may choose to monitor 

according to the continuous . facility ' requirements specified above, or 

choose to have their fugitive components on batch process equipment subject 

to the requirements below: 

1. A pressure test prior to operation of the batch process equipment 

with a hazardous air pollutant. The process equipment should be 

pressurized with air or nitrogen, although water may be used in high 

pressure testing. The system should be pressurized to the maximum 

operating pressure for the period of the test. A leak is defined 

as a pressure drop of more than 0.33 PSIG/15 min. Any system that 

.leaks must be repaired and retested prior to start up of the process. 

Any system that fails the retest must be repaired within 30 days unless 

it can be documented that the replacement part is unavailable. In 

the latter case, the repair must be made within 10 days of the delivery 

date of the replacement part. 

2. Screening level testing of components covered by this rule when the 

batch process equipment is in use with either the hazardous air 

pollutant or an acceptable surrogate. An acceptable surrogate is 

any volatile organic compound not on the hazardous air pollutant list, 

or any detectable gas. The testing frequency shall be determined 

by multiplying the average time in use with a hazardous air pollutant 

in the previous year, expressed as a percentage of total available 

time (8,760 hours/year), by the testing frequency specified for 

continuous process equipment in Section IV. For example, if the 

requirements 1n Section IV would dictate quarterly testing, a system 

with 252 usage would test annually. The facility must maintain written 

records to document the time in use. 

A calculation done by representatives of Eli Lilly & Company on a typical 

batch pharmaceutical process was discussed (a copy 1s attached). The 

calculation demonstrates a rough equivalency between the pressure test 

and the "allowable" fugitive losses from continuous systems. 
P.41 

Three other issues of interest to the group were discussed which may also 

impact on continuous process equipment. These are: 

• An exemption for Research & Development (R&D) facilities. R&D facilities 

including pilot plants, could be covered by this rule if located at 

the same site as a production facility. The proposed addition to Section 

1 of the Strawman is: This rule does not apply to laboratory facilities 

including research pilot plants. Research pilot plants are facilities 

used to run larger scale versions of laboratory experiments which appear 

to hold the promise of a new product or a better way to manufacture 

an existing product. Pilot Plants may be either single-purpose or 

multipurpose. The single-purpose facility is designed to test a single 

process or produce a single product, often over a short time period, 

and may possibly be used again after the experiment. Multipurpose 

research pilot plants on the other hand are intended to remain in use 

indefinitely and are often found to contain a variety of equipment 

which can be configured in many different combinations depending upon 

the experiment to be conducted. The pilot plant will produce material 

primarily for the purpose of R&D, rather than for sale. 

• It was suggested that monitoring of building ventilation air and a 

comparison of the monitoring results to calculated allowable fugitive 

emissions be used as an example of an equivalent standard in section 

4c of the Strawman. If the ventilation air is treated in a control 

device, the fugitive emissions should not be regulated under this 

section, but the emissions from the control device should be regulated 

under the point source program. 

• A section 1(d) be added to the Strawman stating: 

The provisions of this sub-part apply to any process whose fugitive 

components are in use with a HON chemical more than 20% of the calendar 

year. 

Distribution: 

Attendees 

Mr. R. Ajax 

Mr. P. Harter 
•-ft'H't! 

mm: I ill ii- i I I _! j ' j -

r Z ° 

- - S 3 \ r 

HZ 
P.43 

EQUIVALENCY COMPARISON 

"Allowable" VOC leakage from fugitive components in typical pharmaceutical 

batch system based on continuous emissions and EPA emission factors (from 

page 1 of calculations). 

1.531b/hour x 8,760 hours/year = 13,403 lbs/year 

Leakage from typical batch system that results in 1 PSIG drop in 15 minutes 

is 18.5 lbs/hour (also page 1 of calculations). > 

(18.5 lb/hour) (4.5 hours/lot) (449 lots/year) **• 37,379 lbs/year 

If this loss had been 1/3 PSIG in 15 minutes, the loss would have 

corresponded to roughly the 13,403 lbs/year cited above. A pressure loss 

of 1/3 PSIG in 15 minutes in this sytem demonstrates equivalency. 
P.44 

PRESSURE TEST EQUIVALENCY 

Evaluation completed by CPI Plants and Eli Lilly 

April 20, 1990 

System : 4 process tanks and associated piping 

LEAK RATE CALCULATED FROM EPA EMISSION FACTORS 

Single mechanical seal pumps 

Agitators 

Gas valves 

Liquid valves 

Flanges 

Total leak rate 

Emission 

Factor 

0.0083 36 kg/hr 

0.008336 kg/hr 

0.000317 kg/hr 

0.001099 kg/hr 

0.003012 kg/hr 

0.6937 kg/hr 

1.53 lb/hr 

• # 

Comp 

9t 

onents 

2 

4 

27 

49 

193 

LEAK RATE CALCULATED FROM SYSTEM EVACUATION : 

Volume • 1229 cu ft 

Temperature = 20 C 

Initial Pressure • 20 psig 

Case 1 : Assume 1 psig pressure loss in 15 minutes 

Leak Rate =18.5 lb/hr 

Case 2 : Assume 1 psig loss with 1.53 lb/hr leak rate 

Time • 3 hours 

Case 3 : Assume 1.53 lb/hr leak in 15 minutes 

Pressure loss a 4.5 mmHg 

tf 

_J 
P.45 

*************************** * 

*ELI LILLY VENT EMISSIONS * 

************************** * 

PROCESS OPERATION: 

STEP: 

JOB NO.:9381 

DATE: 4/19/90 

BY: KDD 

REV.l 

EVACUATION w/o CONDENSER (IDEAL MIXTURES) 

EQUIVALENCY SYSTEM PRESSURE TEST 

(1 PSIG PRESSURE DROP IN 15 MIN.) 

VAPOR PRESSURE CHART (mm Hg) 

METHYLENE 

CHLORIDE 

M.W. 

ANTOINE COEFF.: 

a 

b 

c 

84.933 

16.3029 

2622.44 

-41.7 

PROCESS CALCULATIONS 

1. DETERMINE LIQUID/VAPOR COMPOSITION IN THE REACTOR WHICH DETERMINES 

THE VAPOR COMPOSITION GOING TO ATMOSPHERE. 

METHYLENE 

CHLORIDE 

INPUT THE FOLLOWING DATA MARKED WITH AN (*): 

•POUNDS PRESENT 10 RESIDUAL 

IN VESSEL 

•TEMPERATURE(degC) 

•INITIAL SYSTEM 

PRESSURE (mmHg) 

•FINAL SYSTEM 

PRESSURE (mmHg) 

20 

1795 (20 PSIG) 

1743 (19 PSIG) 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

#MOLES 0.117739 

TOTAL MOLES 0.117739 

LIQUID 1 

MOLE FRACTION 

INITIAL CONDITIONS: 

v> 
P.46 

TEMPERATURE(deg K) 293 

VAPOR PRESSURE 

(mmHg) 

IDEAL K 

VAPOR MOLE 

FRACTION(yi) 

calculated 

TOTAL yi 

calculated 

yi corrected 

(w/o INERTS) 

TOTAL yi 

corrected 

Pvp^xi 

(ppVOC) 

TOTAL 

Pvp^xi 

FINAL CONDITIONS: 

IDEAL K 

VAPOR MOLE 

FRACTION(yi) 

calculated 

TOTAL yi 

calculated 

yi corrected 

(w/o INERTS) 

TOTAL yi 

corrected 

Pvp+xi 

(ppVOC) 

TOTAL 

Pvp^xi 

353.3307 

0.196841 

0.196841 

0.196841 

1 

1 

353.3307 

353.3307 

0.202714 

0.202714 

0.202714 

1 

1 

353.3307 

353.3307 

o 

++++++++++++++++++++++++++++++++++++++++++ 

AT THIS POINT, THE NITROGEN MOLES/HR SHOULD BE CALCULATED FOR THE 

SPECIFIC STEP AND THE TOTAL MOLES OF SOLVENT CALCULATED. THE TOTAL MOLES 

OF SOLVENT MULTIPLIED BY Yi WILL GIVE INDIVIDUAL MOLES OF EACH COMPONENT 
P.47 

IN THE VAPOR PHASE IN EQUILIBRIUM AT A SPECIFIC PRES! 

2. CALCULATE THE #/HR OF INERTS BEING DISPLACED. 

METHYLENE 

CHLORIDE 

INPUT THE FOLLOWING DATA MARKED WITH AN (•): 

• M.W. OF INERT 29 

•EVACUATION TIME 15 

(MINS) 

•VAPOR SPACE, CF 1229 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

PARTIAL PRESSURE 1441.669 

OF INERT(mmHg) 

INITIALLY 

PARTIAL PRESSURE 1389.669 

OF INERT(mmHg) 

FINALLY 

LN(PPi/PPf) 0.036735 

LOG MEAN 1415.510 

PARTIAL PRESSURE 

y inerts 0.803158 

INITIALLY 

y inerts 0.797285 

FINALLY 

MOLES OF INERTS 0.218334 

DISPLACED 

#/HR INERTS 25.32678 

DISPLACED 

3. CALCULATE THE VOC RATE OUT OF THE VESSEL. 

METHYLENE 

CHLORIDE 

++++-H-+++++++++++++++++++++++++++++++++++++H 

THE COMPUTER WILL CALCULATE THE FOLLOWING: 

# VOC 4.628785 

#/HR VOC 18.51514 

^ 
P.48 

' a • 

r+++++++++++++++++++++-. 

••PRESS F9 TO CALCULATE 

TOTAL # VOC 4.628 7 
P.49 

ATTACHMENT 11 

DRAFT 

GENERAL WORK PLAN 

DETERMINATION OF OVA RESPONSE FACTORS FOR ORGANIC 

COMPOUNDS LISTED IN THE CLEAN AIR ACT 

AND 

EVALUATION OF ALTERNATE INSTRUMENTATION FOR COMPOUNDS 

WHICH ARE NOT RESPONSIVE TO THE OVA 

Work Assignment 12 

Contract No. 68D90054 

Prepared for: 

Mr. K. William Grimley 

Work Assignment Manager 

Emission Measurement Branch 

U. S. Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 

Prepared by: 

Radian Corporation 

Post Office Box 13000 

Research Triangle Park, North Carolina 27709 

April 16, 1990 
P.50 

SECTION 1 

SUMMARY OF THE WORK ASSIGNMENT 

Background 

Investigations of fugitive Volatile Organic Compound (VOC) emissions have 

gained attention over the past several years due to concern for release of toxic air 

components and ozone precursors. Several research efforts have been conducted to 

measure fugitive emission levels and to assess the effectiveness of proposed control 

schemes. Leaks around pipe flanges, valves, and seals are of primary interest. uAn 

action level for leak detection of 10,000 ppm has been set by the U. S. Environmental 

Protection Agency. A screening procedure has been developed for measurement of 

VOC at this concentration close to the leak site. 

Several studies have also been conducted on leak detection equipment. Most 

measurements are made with a portable hydrocarbon detector, primarily the Century 

Systems "OVA 108." While the OVA 108 will respond to almost any combustible 

material, the instrument exhibits different sensitivities to various types of hydrocarbons 

and substituted organic chemicals. The "response factor" is a correction factor which 

quantifies these differences in sensitivity. 

The Toxic Waste Release Inventory (TRI), published in the February 1988 

Federal Register, contains a listing of 309 chemicals which must be reported when 

intentional or accidental releases into the environment occur. The proposed Clean Air 

Act contains a list of approximately 190 chemicals which will be regulated. Fugitive 

emissions fall under a proposed Hazardous Organic NESHAP (HON) and a regulatory 

level of 500 ppm has been proposed by EPA for leak detection. This new regulatory 

level and the list of chemicals in the Clean Air Act pose two problems: 

• published response factors for OVA are available for concentrations 

between 1000 and 10,000 ppm. Response factors at 500 ppm must be 

determined for each of the compounds to be regulated. 
P.51 

•. many of the compounds on the Clean Air Act list do not respond to the 

OVA or have response factors outside the range of 0.3 to 3.0. 

Appropriate instrumentation to measure these compounds must be 

selected and evaluated if these compounds are to be regulated. 

Objectives 

This work assignment has the following objectives: 

1) to define a list of compounds of interest to the Environmental Protection 

Agency for the regulation of fugitive emissions; 

2) to complete a compilation of published OVA response factors for the 

compounds of interest which will aid in the assessment of instrument to 

instrument variability; 

3) to determine OVA response factors for as many of the compounds of 

interest as possible at a level of 500 ppm and to assess whether 

instruments consistently conform to published response factors; and 

4) to select and evaluate an appropriate instrument for the determination of 

compounds of interest which do not respond to the OVA. 

Approach 

Task 1 

The definition of the compounds of interest must be done by the Environmental 

Protection Agency. Appendix A shows the compounds which are listed in the proposed 

Clean Air Act. Inorganic compounds and others are listed in a separate table. 

However, the list of organic compounds presently includes pesticides and other 

compounds which are not amenable to any methodology which involves measurement of 

volatile compounds. Entries on the list such as "glycol ethers" or "cresols" must be better 

defined in order to permit determination of a response factor. Other compounds such 

as diazomethane cannot be handled as a pure compound. Hydrazine, not an organic 

cah.OOSop 
P.52 

compound, is Usted among organic compounds. The list of compounds from the Clean 

uAir Act provides a starting point but a clear defimtion of organic compounds to be 

regulated must be made. Radian will assist EPA in the preparation of the list of 

compounds of interest by providing chemical data such as vapor pressures and any other 

chemical characteristics which EPA may require in formulating a list of compounds to 

be regulated. 

Task ,2 

When the compounds of interest have been defined, the compilation of published 

data which has been begun by Radian will be completed. This compilation consists of a 

table of the response factors which have been determined experimentally by Radian 

using at least two OVA instruments and a range of concentrations, as well as response 

factors determined by the manufacturer of the instrumentation. The literature available 

for compilation of response factors includes: 

1) response factors determined by The Foxboro Company, the manufacturers 

of the instrumentation used in the field for leak measurements (Model 

OVA 108) 

2) various reports written by Radian and/or TRW of studies to determine 

response factors of VOC analyzers 

a) "Response Factors of VOC Analyzers Calibrated with Methane for 

Selected Organic Chemicals." EPA Report Number 600/2-81-002. 

EPA Contract No. 68-02-3171-01. Prepared by G. E. Brown, D. A. 

DuBose, W. R. Phillips, and G. E. Harris, Radian Corporation, 

Austin, Texas. 

b) "Volatile Organic Compound Response Characterization for Flame 

Ionization Analyzers." EPA Contract No. 68-02-3545. Prepared by 

M. Hartman, A. Blackard, and C. Stackhouse, TRW, Energy and 

Environmental Division, Research Triangle Park, North Carolina. 

c) "Response Factors of VOC uAnalyzers at a Meter Reading of 10,000 

ppmv for Selected Organic Compounds." EPA Report Number 

600/2-81-051. EPA Contract No. 68-02-3171-28. Prepared by D. 

A. DuBose and G. E. Harris, Radian Corporation, Austin, Texas. 

cah.00Sop 
P.53 

*» 

d) "Response of Portable VOC Analyzers to Chemical Mixtures." EPA 

Report Number 600/2-81-110. EPA Contract No. 68-02-3171-28. 

Prepared by D. A. DuBose, G. E. Brown, and G. E. Harris, Radian 

Corporation, Austin, Texas. 

e) "Field Study: Estimating Fugitive Emissions from the Ethylene 

Oxide Production Industry." Prepared for The Ethylene Oxide 

Industry Council of the Chemical Manufacturers Association. 

Prepared by J. Randall, G. Harris, S. Wevill, Radian Corporation, 

Austin, Texas. April 1989. 

f) "Fugitive Emissions from the 1,3-Butadiene Production Industry: A 

Field Study." Prepared for The 1,3-Butadiene Panel of the 

Chemical Manufacturers Association. Prepared by J. L. Randall, G. 

E. Harris, S. L. Wevill, Radian Corporation, Austin, Texas. April 

1989. 

These sources were used to assemble a preliminary table of OVA response factors 

available from the literature. To complete a compilation of published response factor 

data, Radian will revise this preliminary table to include all of the compounds of interest 

(as defined by EPA) and include any additional information available for response 

factors for compounds of interest determined at different concentration levels and on 

different instruments. In addition, the response factors available from sources (e) and 

(f) will be examined and an attempt will be made to assess the day-to-day variation of 

response factors and the instrument-to-instrument variations. 

Task 3 

To provide a compilation of response factors for all of the compounds of interest at 

the regulatory level, Radian will determine OVA response factors for the compounds of 

interest at a level of 500 ppm. Experimental procedures used to determine response 

factors are straightforward, requiring that a calibrated instrument be used to sample a 

gas of known concentration. The response factor is then defined as the ratio of the 

actual concentration to the concentration indicated on the meter. Two instruments will 

be used in the testing to check for normal variance between individual instruments and 

to check for any operating problems. The OVA is a portable flame ionization detector 

cah.008op 
P.54 

(FID) with a gas chromatograph option. In the total hydrocarbon mode which is used 

for fugitive emission screening, the chromatograph column is bypassed and the sample 

gas is introduced directly to the detector. The unit is battery-powered and has its own 

hydrogen cylinder with enough fuel for 8 to 10 hours of continuous operation. The unit 

is certified intrinsically safe for operation in Class I, Groups A, B, C, D, Division I 

hazardous locations by Factory Mutual and BASEEFA. The readout on the OVA-108 is 

logarithmic and has a range from 1 to 10,000 ppmv. The range on the OVA-128 is 

linear and has three ranges: 0-10 ppmv, 0-100 ppmv, and 0-1000 ppmv. The 

instrumentation will be calibrated against methane "Class A" standards, so that all 

response factors will be determined relative to methane. Methane is easily available, 

volatile, and is used as the factory calibration standard for the OVA. Also, most of the 

response factors which are available from the literature were determined relative to 

methane. 

Determination of response factors requires that gas samples of known 

concentration be prepared. Concentrations of chemicals which are liquids at room 

temperature will be calculated gravimetrically, from a measured weight of the liquid 

injected into a measured volume of "zero-grade" (hydrocarbon-free) air. Concentrations 

of chemicals which are gases at room temperature will be calculated volumetrically. 

Sample preparation will require preparation of canisters, preparation of standards from 

liquids, or preparation of standards from gases. The standard gas mixtures used for this 

study will be prepared or collected in chemically-inert canisters. Canisters are inert and 

resistant to adsorption or permeation, and can be equipped with two valves to facilitate 

flushing between runs. 

Obtaining response factor data from the prepared standards will be 

straightforward. Instruments to be tested will be connected to a manifold to allow all of 

the instruments to sample from the same stock standard, which will be diluted to a level 

of 500 ppm. The canisters will be cleaned and blanked between uses to insure against 

compound carryover, and the sampling manifold will be flushed with zero-grade air 

between samples to reduce any cross-contamination. At the completion of flushing, the 

cah.008op 
P.55 

zero-grade air will be routed through the manifold to the instruments to allow them to 

be zeroed. All of the instruments to be tested will be connected to the same manifold 

to allow simultaneous testing in the most efficient manner possible. The instruments 

proposed for testing include: 

1) 2 OVA-128 instruments. The full-s-cale reading of 1000 ppm seems ideal 

for a test level of 500 ppm, which should be approximately mid-scale. 

2) 1 OVA 108 instrument. The OVA 108 is very common and in current use, 

and will no doubt continue to be used even when the regulatory level is 

changed from 10,000 ppm to 500 ppm. One of these instruments is 

included for the sake of comparability to the OVA 128. 

3) 1 HNU. The HNU is a portable trace gas analyzer which measures a wide 

range of organic and inorganic compounds by photoionization detection. 

Applications for which the HNU is recommended include non-methane 

hydrocarbons, aromatics, and most chlorinated solvents. Chlorinated 

solvents are one area where the OVA performs poorly, because the flame 

ionization detector shows a low response to chlorinated solvents, if any 

response at all is obtained. 

4) 1 MIRAN. The MIRAN Portable Ambient Air Analyzer is a portable 

infrared gas analyzer which can perform air measurements against a library 

of OSHA-cited gases. The infrared detector is responsive to virtually all 

organic, plus some inorganic, gases and vapors which absorb infrared 

energy in the 2.5 to 14.5 micrometer region of the infrared spectrum. For 

example, the MIRAN responds to oxygenated compounds such as 

formaldehyde and halogenated compounds such as carbon tetrachloride, 

both of which respond poorly to the OVA. However, the MIRAN may 

suffer from a wider range of response factor values due to its operating 

principle. 

The proposed manifold is shown schematically in Figure 1. When the test vapor 

is flowing through the manifold, readings will be repeated as frequently as possible. 

Radian's estimate is that chemical testing can be performed at a rate of four chemicals 

per testing day. 

cah.OOSop 
AIR 

MASS FLOW 

CONTROLLER 

FOR 

DILUTION 

HEAT TRACED 

LINE 

EXIT 

ROTAMETER 

Figure 1. Schematic of testing equipment. 

*D 
P.57 

.*> • 

This battery of instrumentation will be evaluated for the compounds of interest to 

EPA for regulation. Response factors will be determined relative to methane at a level 

of 500 ppmv. Data obtained will be formatted for straightforward presentation and 

statistically evaluated. 

Quality assurance checks will be performed throughout the program. A standard 

gas will be read at intervals by each instrument in use, independently of the routine 

calibrations. Quality assurance will be achieved on data transmittal by adherence to 

strict procedures for data entry and data verification. Data will be entered into a 

computerized database to allow production of both tabular and graphic presentations of 

data, as appropriate. Computer output will be validated by experimental staff, who will 

verify the data and check for anomalies. 

If there are still compounds for which no response has been obtained from any of 

the instrumentation tested, a literature search will be undertaken to identify appropriate 

instrumentation for these compounds. A test program for existing instrumentation or an 

instrumentation development/construction program can be developed when compounds 

and appropriate techniques or instrumentation are identified. 

Since many or most of the materials to be tested will be hazardous, explosive, 

flammable, or carcinogenic, a comprehensive Health and Safety Plan will be required. 

In summary, the activities which will be performed under this work assignment 

are: 

• identification/determination of the appropriate list of compounds of 

regulatory interest to EPA; 

• compilation of a table of OVA response factors available from literature 

sources, with some assessment, if possible, of instrument-to-instrument 

variation and stability over time. 

• determination of response factors at 500 ppm for the compounds 

determined to be of regulatory interest to EPA. 

cah.OOSop 8 ' ,' 
P.58 1 

V r sH'f 

evaluation of HNU and MIRAN for applicability to those compounds 

which do not show an OVA response. 

identification of appropriate methodology for measurement of the 

compounds (if any) which do not respond to any of the techniques 

evaluated in this program. 

The project organization, description of the tasks, estimated project costs, and 

major milestones are discussed in the following sections of this Work Plan. 

oh.008op