&EPA

United States Office of Air Quality EPA-450/3-83-006

Environmental Protection Planning and Standards March 1984

Agency Research Triangle Park NC 27711

Air

Guideline Series

Control of Volatile

Organic

Compound Leaks

from Synthetic

Organic Chemical

and Polymer

Manufacturing

Equipment

EPA-450/3-83-006

Guideline Series

Control of Volatile Organic Compound

Leal<s from Synthetic Organic Chemical

and Polymer Manufacturing Equipment

Emission Standards and Engineering Division

u.S. ENVIRONMENTAL PROTECTION AGENCY

Office of Air and Radiation

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711

March 1984
GUIDELINE SERIES.....

The guideline series of reports is issued by the Office of Air Quality Planning and Standards (OAQPS) to

provide information to state and local air pollution control agencies; for example, to provide l~uidanceon the

acquisition and processing of air quality data and on the planning and analysis requisite for the

maintenance of air quality. Reports published in this series will be available-as supplies permit-from the

Library Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North

Carolina 27711, or for a nominal fee, from the National Technical Information Service, 5,285 Port Royal

Road, Springfield, Virginia 22161.

ii
i ; i '

2.4 REFERENCES.

vi

viii

2-20

2-22

3-1

3-1

3-1

3-2

3-2

3-2

3-3

3-4

3-4

3-4

3-7

1-1

2-1

2-3

2-3 ., 2-3

2-8

2-11

2-14

2-15

2-17

2-17

2-17

2-17

2-17

2-18

2-18

. . .'

TABLE OF CONTENTS

. . . '.

PRIMARY CONTROL METHODS . 3.1.1 Individual Component Survey for Leak Detection .. 3.1.2 Repair Methods..•.....

3.1.2.1 Pumps . 3.1.2.2 Compressors..•...

3.1.2.3 Safety/Relief Valves

3.1.2.4 Valves,. . . . . . . . . ... 3.1.2.5 Flanges. . . . • .. .••..

3.1.3 Control Effectiveness of Leak Detection and

Repair Techniques . . . 3.1.4 Open-Ended Lines .

2.3.1 Model Units . 2.3.1.1 Sources of Fugitive Emissions.

2.3.1.2 Model Units Components .... 2.3.1.3 Uncontrolled Fugitive Emission

Estimates. .

FACILITIES AND THEIR EMISS IONS . . . • . . . .

2.2.1 Potential Source Characte~ization and

Description .....•, . 2.2.1.1 Pumps .•....•..

2.2.1.2 Compressors . 2.2.1.3 Process Valves ...•.•

2.2.1.4 Safety Relief Devices.

2.2.1.5 Agitators..•.•.•..

2.2.1.6 Open-Ended Lines .•

2.2.1.7 Sampling Connections •..

2.2.1.8 Flanges.•.....••.

2~3 MODEL UNITS ..

2.2

Chapter 3.0 - EMISSION CONTROL TECHNIQUES ..

3.1

LIST OF TABLES .

LIST OF ,FIGURES.

Chapter 1.0 - INTRODUCTION •.

Chapter 2.0 - PROCESSES AND POLLUTANT EMISSIONS ....

2.1 INTRODUCTION .•.............
TABLE OF CONTENTS (CONTINUED)

3.2 OTHER CONTROL STRATEGIES . . . • • • . . • . •

3.2.1 General . 3.2.2 Allowable Percentage of Valves Leaking •.

3.2.3 Alternative Work Practice for Valves••

. ,.

Page

3-9

3-10

3-12

3-13

3.3 OTHER CONSIDERATIONS. . . . . . . . . . • . . . 3-16

3.3.1 Unsafe and Difficult to Reach Components. . 3-16

3.3.2 Small Process Unit.. 3-16

3.3.3 Unit Turnarounds. . . . . . . . 3-17

4.1 REASONABLY AVAILABLE CONTROL TECHNOLOTY (RACT)

4.2 AIR POLLUTION ••.......•.•....

4.2.1 Development of VOC Emission Levels..... 4.2.2 VOC Emission Reduction. • . . . •

Chapter 5.0 - CONTROL COST ANALYSIS OF RACT ..

5.1 BASIS FOR CAPITAL COST .••.•..•......

5.1.1 Cost of Monitoring Instrument . 5.1.2 Caps on Open-Ended Lines.

5.1.3 Initial Leak Repair. .. . ....•.

5.1.4 Replacement Pump Seals at Initial Repair.

3.4 REFERENCES •••...••

Chapter 4.0 - ENVIRONMENTAL ANALYSIS OF RACT

4.3 WATER POLLUTION. • . .

4.4 SOLID WASTE DISPOSAL

4.5 ENERGY. . •

4.6 REFERENCES.

5.2 BASIS FOR ANNUALIZED COSTS ... 5.2.1 Monitoring Labor..•......

5.2.2 Leak Repair Labor .•......

5.2.3 Maintenance Charges and Miscellaneous

5.2.4 Administrative Costs•.

5.2.5 Capital Charges ...•.......

5.2.6 Recovery Credits•..........

iv

:. . .

. Costs . • • • • Ii •

. '.

3-20

4-1

4-1

4-3

4-3

4-3

4-3

4-6

4-6

4-7

5-1

5-1

5-1

5-1

5-4

5-4

5-6

5-6

5-6

5-6

5-9

5-9

5-9
v

5.4" COST EFFECTIVENESS. 5-13

5.5 REFERENCES. . . . 5-17

APPENDIX A - MAJOR COMMENTS RECEIVED ON THE DRAFT CTG. A-I

A.l NEED AND COVERAGE OF THE CTG . . . . . . . . A-I

A.2 ESTIMATES OF EMISSIONS, EMISSION REDUCTIONS,

AND COSTS. . . . . . . . . . . . . . . A-6

A.3 RACT SELECTION, PROVISIONS, AND EXEMPTIONS. A-16

A.4 REFERENCES. • . . . . . . . . . . . . . . A-27

APPENDIX B - COMMENT LETTERS RECEIVED ON DRAFT CONTROL TECHNIQUES GUIDELINE DOCUMENT. . . . . . . . . . . . . . . . .. B-1

-: .

Page

5-11

5-11

5-11

5-11

5-13

TABLE OF CONTENTS ~CONTINUED)

EMISSION CONTROL COSTS . . 5.3.1 Initial Costs . 5.3.2 Recovery Credits . 5.3.3 Net Annualized Cost .....••..

5.3.4 Differences in Net Annualized Costs

5.3
. .

Table

2-1

2-2

3-1

3-2

3-3

3-4

4-1

4-2

5-1

5-2

5-3

5-4

5-5

5-6

5-7

5-8

5-9

A-I

LIST OF TABLES

EQUIPMENT COUNTS FOR FUGITIVE VOC EMISSION SOURCES

IN SOCMI MODEL UNITS • • . . • • . . . . . • . . . .

EMISSION FACTORS FOR LEAKS FROM PROCESS EQUIPMENT..

INPUT PARAMETERS FOR LDAR MODEL. . . • . . . • . . .

EFFECTIVENESS OF QUARTERLY LEAK DETECTION AND REPAIR

ILLUSTRATION OF A SKIP-PERIOD MONITORING PROGRAM . •.

COST EFFECTIVENESS FOR QUARTERLY LEAK DETECTION AND

REPAIR PROGRAMS FOR PROCESS UNITS PROCESSING SMALL

VOLUMES OF LIGHT LIQUID AND GASEOUS VOC. . • .

ESTIMATED EMISSIONS AND EMISSIONS REDUCTION ON A

MODEL UNIT BASIS • • • • • • • • . . . • . . . .

EMISSION FACTORS FOR SOURCES CONTROLLED UNDER RACT

CAPITAL COST DATA. . . • •

CAPITAL COST ESTIMATES FOR IMPLEMENTING RACT (Thousands of June 1980 Dollars •.•.............

LABOR-HOUR REQUIREMENTS FOR INITIAL LEAK REPAIR UNDER

RACT . • • • • • • • • • . • . . . . • ..

BASIS FOR ANNUALIZED COST ESTIMATES

ANNUAL MONITORING AND LEAK REPAIR LABOR REQUIREMENTS FOR RACT . • . • . .

RECOVERY CREDITS • . . . . . . . . . . . . . . . . ;

ANNUALIZED CONTROL COST ESTIMATES FOR MODEL UNITS UNDER

RACT (Thousands of June 1980 Dollars). . . . '

COST EFFECTIVENESS FOR MODEL UNITS UNDER RACT ..

COST EFFECTIVENESS FOR COMPONENT TYPES IN MODEL

UN IT B • • • • • • • • • • • • • • •

ESTIMATES OF vae EMI S5 IONS FROM SOCML

vi

2-19

2-21

3-6

3-8

3-15

3-18

4-4

4-5

5-2

5-3

5-5

5-7

5-8

5-10

5-12

5-14

5-16

Po-3
Table

A-2

A-3

A-4,

B-2

LIST OF TABLES (CONTINUED)

COSTS FOR COMPONENT TYPES IN MODEL UNITB .

EQUIP~ENT LEAKS OF VOC FROM SYNTHETIC ORGANIC CHEMICAL POL~MER MANUFACTURING: RACT ..•.........

SUMMARY OF PERCENT OF SOURCES DISTRIBUTION CURVES AND

PERCENT OF MASS EMISSIONS CURVES AT VARIOUS ACTION

LEVELS . . . . . . . . . . . .: . . • . .

LIST OF COMMENTERS AND AFFILIATIONS.

vii

Page

A-13

A-15

A-20

B-2
LIST OF FIGURES

Figure

Cost Effectiveness of Quarterly Leak Detection and

Repair of Valves With Varying Leak Frequency - SOCMI·

Un; ts .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..

General Schematic of Process Levels that Make Up

the Organic Chemical Industry. • .•.

Diagram of a Simple Packed Seal •••.

Labyrinth Shaft Seal.

Restrictive-Ring Shaft Seal

Mechanical (Contact) Shaft Seal

Liquid Film Shaft Seal With Cylindrical Bushing

3-11

2-6

2-2

2-4

2-5

2-6

2-7

2-8

2-9

2-10

2-10

2-11

2-12

2-13

2-14

2-16

2-16 , .. .. .. ..

Diagram of a Gate Valve ••

Example of Bellows Seals.•

Diagrams of Valves With Diaphragm Seals.

Diagram of a Basic Single Mechanical Seal

Diagram of a Double Mechanical Seal (Back-to-Back

Arrangement)•.•••••••.•••.•

Diagram of a Double Mechanical Seal (Tandem

Arrangement). • • • • • . ••.

Diaphragm Pump ••.

Diagram of a Spring-Loaded Relief Valve.

Diagram of a Hydraulic Seal for Agitators.

Diagram of Agitator Lip Seal ..

2-1

2-5

2-2

2-3

2-4

2-6

2-7

2-8

2-9

2-10

2-11

2-12

2-13

2-14

2-15

2-16

3-1

viii
1.0 INTRODUCTION

The Clean Air Act Amendments of 1977 require each State in which there

are areas in which the national ambient air quality standards (NAAQS) are

exceeded to adopt and submit revised state implementation plans (SIP's) to

EPA. Revised SIP's were required to be submitted to EPA by January 1, 1979.

States which were unable to demonstrate attainment with the NAAQS for ozone

by the statutory deadline of December 31, 1982, could request extensions for

attainment with the standard. States granted such an extension are required

to submit a further revised SIP by July 1,. 1982.

Section 172(a)(2) and (b)(3) of the Clean Air Act require that

nonattainment area SIP's include reasonably available control techno,logy . (RACT) requirements for stationary sources. As explained in the "General

Preamble for Proposed Rulemaking on Approval of State Implementation Plan

Revisions for Nonattainment Areas," (44 FR 20372, April 4, 1979) for ozone

SIP's, EPA permitted States to defer toe adoption of RACT regulations on a

category of stationary sources of volatile organic compounds (VOC) until

after EPA published a control techniques guideline (CTG) for that voe source

category. See also 44 FR 53761 (September 17, 1979). This delay allowed

the states to make more technically sound decisions regarding the application of RACT.

Although CTG documents review existing information and data concerning

the technology and cost of various control techniques to reduce emissions,

they are, of necessity, general in nature and do not fully account for

unique variations within a stationary source category. Consequently, the

purpose of CTG documents is to provide State and local air pollution control

agencies with an initial information base for proceeding with their own

analysis of RACT for specific stationary sources.

1-1

2.• 0 PROCESSES AND ·PQLLUTANT EMISSIONS

2.1 INTRODUCTION

The discussion presented in this document applies to equipment in

process units operated to produce one or more of the synthetic organic

chemicals listed in Appendix E of the proposed standards of performance for

SOCMI (46 FR 1136, January 5, 1981) ,'methyl tert~butyl ether (MTBE),

polyethylene, polypropylene, and polystyrene. The equipment in process

units in the synthetic organic chemical ma~ufacturing industry (SOCMI) is ." '

similar to equipment in the polymer manufacturing industry. Both industries

process volatile organic compounds. Therefore, the information and

discussion presented in this chapter and subsequent chapters applies equally

to SOCMI plants and polymer plants.

The SOCMI is a segment of the chemical industry consisting of some of

the higher volume intermediate and finished products. The polymer

manufacturing industries to which the discussion in this document applies

are polyethylene,polypropylene, and polystyrene. It should be emphasized

that the discussion in this document is intended to apply to equipment in

process units which manufacture these chemicals.

Most of the SOCMI chemicals produced in the United States are derived

from crude petroleum or natural gas. The ten principal feedstocks used in

the manufacture of organic chemicals are produced primarily in petroleum

refineries. After chemical feedstocks are manufactur~d from petroleum,

natural gas, and other raw materials, they are processed into chemical

intermediates and end-use chemicals (see Figure 2-1). Approximately

12 percent of the plants in the United States produce less than 5,000 megagrams (Mg) annually. Another 12 percent have production capacities in

excess of 500,000 Mg.

2-1
RAW MATERIALS

~DE OIL, CRUDE NATURAL GAS, ETC.)

I,

!

I

I

REFINERIES I

I

L..-__F_U_E_LS__J

CHEMICAL'

FEEDSTOCK

PLANTS

[]FEEDSTOCKS

CHEMICAL -~. '

[JHEMICj~

PLANT:~

<::>

ICH~MlCA~

~~ODUC'~

Figure 2-1. General schematic of process levels that make up

the organic chemical industry.

2-2
The polymer manufacturing industry includes operations which convert

monomer or chemical intermediate materials obtained from the basic

petrochemical industry and the SOCMI into polymer products. Such products

include polyethylene, polypropylene, and polystyrene.

2.2 FACILITIES AND THEIR EMISSIONS

2.2.1 Potential Source Characterization and Description

In this document, fugitive emissions from process units are considered

to be those volatile organic compound (VOC) emissions that result when

process fluid (either gaseous or liquid) leaks from plant equipment. There

are many potential sources of fugitive emissions in a typical process unit.

The following sources will be considered in this chapter: pumps,

compressors, in-line process valves, pressure relief devices, open-ended

valves, sampling connections, flanges, agitators and cooling towers. These

potential sources are described below.

2.2.1.1 Pumps. Pumps are used extensively in process units for the

movement of organic liquids. The centrifugal pump is the most widely used

pump. However, other types, such as the positive-displacement, reciprocating and rotary action, and special canned and diaphragm pumps, are also

used. Chemicals transferred by pumps can: leak at the point of contact

between the moving shaft and stationary casing. Consequently, all pumps

except the shaftless type (canned-motor and diaphragm) require a seal at the

point where the shaft p~netrates the housing in order to isolate the pump's

interior from the atmosphere. 1

Two generic types of seals, packed and mechanical, are currently in use

on pumps. Packed seals can be used on both reciprocating and rotary action

types of pumps. As Figure 2-2 shows, a packed seal consists of a cavity

("stuffing box") in the pump casing filled with special packing material

that is compressed with a packing gland to form a seal around the shaft.

Lubrication is required to prevent the buildup of frictional heat between

the seal and shaft. The necessary lubrication is provided by a lubricant

that flows between the packing and the shaft. 2 Deterioration of the

packing will result in process liquid leaks.

2-3
""'" Stuffing

Box r- Packing V Gland ,

,

x x x x

Fluid c ---------rr- Atmosphere

End 1 End

1'\ I

f Ij"V Possible

L _ Leak

Packing Area

......

,

Fi gure 2-2. Diagram of a simple packed seaJ. 3

Mechanical seals are limited in application to pumps w'ith rotating

shafts and can be further categorized as single and double mechanical seals.

There are many variations to the basic design of mechanical seals, but all

have a lapped seal face between a stationary element and a rotating seal

ring. In a single mechanical seal application (Figure 2-3), the rotatingseal ring and stationary element faces are lapped to a very high degree of

flatness to maintain contact throughout their entire mutual surface area.

As with a packed seal, the seal faces must be lubricated to remove

frictional heat; however, because of its construction, much less lubricant

;s needed.

A mechanical seal is not a leak-proof device. Depending on the

condition and flatness of the seal faces, the leakage rate can bE~ quite low

(as small as a drop per minute) and the flow is often not visually

detectable. In order to minimize fugitive emissions due to seal leakage, an

auxiliary sealing device such as packing can be employed. 4

2-4
2-5

Figure 2-3. Diagram of a basic single mechanical sea1. 5

STATIONARY

ELEMENT

GLAND

RING

. POSSIBLE

~==:Y:::::::::::--LEAK AREA

SHAFT

PUMP

STUFFING

BOX

FLUID ____

END

In a dual mechanical seal application, two seals can be arranged

back-to-back or in tandem. In the back-t9-back arrangement (Figure 2-4),

the two seals provide a closed cavity between them. A seal liquid, such as

water or seal oil, is circulated through the cavity. Because the seal

liquid surrounds the double seal and lubricates both sets of seal faces in

this arrangement, the heat transfer and seal life characteristics are much

better than those of the single seal. In order for the seal to function,

the seal liquid must be at a pressure greater than the operating pressure of

the stuffing box. As a result some seal liquid will leak across the seal

faces. liquid leaking across the inboard face will enter the stuffing box

and mix with the process liquid. Seal liquid going across the outboard face

will exit to the atmosphere. 6

In a tandem dual mechanical seal arrangement (Figure 2-5), the seals

face the same direction. The secondary seal provides a backup for the

primary seal. A seal flush is used in the stuffing box to remove the heat

generated by friction~ The cavity between the two seals is filled with a

buffer or barrier liquid. However, the barrier liquid is at a pressure

lower than that in the stuffing box. Therefore, any leakage will be from
POSSIBLE LEAK __-l'!:f:.~~~I~ INTO SEALING

FLUID

F1.UID END

PRIMARY

SEAL

~--] SECONDARY

SEAL

-GLAND

PLATE

Figure 2-4.

FLUID

END

PRIMARY

SEAL

Figure 2-5.

Diagram of a double mechan}cal seal

(back-to-back arrangement)

BUFFER LIQUID

GL.AND

Pl.ATE

70·17117·1

Diagram of a double ~echanical seal

(tandem arrangement)

2-6
the stuffing box into the seal cavity containing the barrier liquid. Since

this liquid is routed to a c16sed reservoir, proceSs liquJd,that has leaked

into the seal cavity will 'also be transferred to the reservoir. At the

reservoir, the process liquid could vaporize and be emitted to the

atmosphere. To ensure that VOC does not leak from the reservoir, the

reservoir can be vented to a control device. 9

Another type of pump that has been used is the shaftless pump which

includes canned-motor and diaphragm pumps. In canned-motor pumps the cavity

housing the motor rotor and the pump casing are interconn~cted. As a

result, the motor bearings run in the process liquid and all seals are

eliminated. Because the process liquid is the bearing lubricant, abras'ive

solids cannot be tolerated. Canned-motot pumps are being widely: used for

handling organic solvents, organic heat transfer li~uids, light oils, as

well as many toxic or hazardous liquids, or where leakage is an economic

problem. IO

Diaphragm pumps (see Figure 2-6) perform similarly to piston and

plunger pumps. However, the driving member is a flexible diaphragm

fabricated of metal rubber, or plastic. The primary advantage of this

arrangement is the elimination of all packing and seals exposed to the

process liquid. This is an important asset when hazardous or toxic liquids

are handled. ll

DISCHARGE INLET

CHECK VALVE CHECK VALVE

Figure 2-6. Diaphragm pump.12.

2-7
2.2.1.2 Compressors. Gas compressors used in process units are

similar to pumps in that they can be driven by rotary or reciprocating

shafts. They are also similar to pumps in their need for shaft seals to

isolate the process gas from the atmosphere. As with pumps, these seals are

likely to be the source of fugitive emissions from compressors.

Shaft seal~ for compressors may be chosen from several diffE~rent types:

labyrinth, restrictive carbon rings, mechanical contact, and liquid film.

All of these seal types are leak restriction devices; none of them

completely eliminate leakage. Many compressors may be equipped v~ith ports

in the seal area to evacuate gases collecting there.

The labyrinth type of compressor seal is composed of a series of close

tolerance, interlocking IIteeth" which restrict the flow of gas a"long the

shaft. A straight pass labyrinth compressor seal is shown in' Fiqure 2-7.

Many variations in II tooth II design and materials of constructi'on are

available. Although labyrinth type seals have the largest leak potential of

the different types, properly applied variations in "tooth" conf'iguration

and shape can reduce leakage by up to 40 percent over a straight pass type

labyrinth. 13

Figure 2-7. Labyrinth shaft seal. 14

2-8
Restri ctive carbon ri ng seals consist .of multipl e stati onary carbon

rings with close shaft clearances. This type of seal may be operated dry or

with a sealing fluid. Rpstrictive ring seals can achieve lower leak rates

than the labyrinth. 16 A restrictive ring seal is shown in Figure 2-8.

Figure 2-8. Restrictive-ring shaft seal. 15

Mechanical contact seals (shown in Figure 2-9) are similar to the

mechanical seals described for pumps. In this type of seal, clearance

between the rotating and stationary elements is reduced to zero. Oil or

another suitable lubricant is supplied to the seal faces. Mechanical seals

can achieve the lowest leak rates of the types described here, but they are

not suitable for all processing conditions~19

Centrifugal compressors also can be equipped with liquid film seals. A

diagram of a liquid film seal is shown in Figure 2-10. The seal is formed

by a film of oil between the rotating shaft and stationary gland. When the

circulating oil is returned to the oil reservoir, process gas can be

released to the atmosphere. 20 To eliminate release of VOC emissions from

the seal oil system, the reservoir can be vented to a control device.

2-9
CLEAN OIL IN

~i;:~~;r PRESSURE /"BREAKDOWN ! SLEEVE

l!IDo'~ ~'-\: . ,,~\~<;

ATMOSPHERE

CONTAMINATED

OIL OUT

17

Figure 2-9. Mechanical (contact) shaft seal.

CLEAN OIL IN

OIL OUT

OUTER BUSHING

CONTAMINATEO

OIL OUT

INTERNAL

GAS

PRESSURE

Figure 2-10. Liquid film shaft seal with cylindrical bushing. 18

2-10
2.2.1.3 Process'Valves. One of the most common pieces of equipment in

organic chemical plants is the valve. The types of valves commonly used are

control, globe, gate, plug, ball, relief, and check valves. All except the

relief valve (to be discus~ed further below) and check valve are a~tivated

by a valve stem, which may have either a rotational or linear motion,

depending on th~ specific design. This stem requires a seal to isolate the

process fluid inside the valve from the atmosphere as illustrated by the

diagram of a gate valve in Figure 2-11. The possibility of a leak through

this seal makes it a potential source of fugitive emissions. Since a check

valve has no stem or subsequent packing gland, it is not consideredto'be a

potential source of fugitive emissions.

Sealing of the stem to prevent leakage can be achieved by packing

inside a packing gland or a-ring seals. Valves that require the stem to

move in and out with or without rotation must utilize a packing gland.

Conventional packing glands are suited for a wide variety of packing

materials. The most common are various types of braided asbestos that

contain lubricants. Other packing materials include graphite, graphiteimpregnated fibers, and ;tetrafluoroethylene. The packing material used

depends on the valve application and configuration. 21 These conventional

packing glands can be used over a wide range of operating temperatures. At

high pressures these glands must be quite tight to attain a good seal. 22

PACKING

GLAND

~l;ff~-~----:--__.--;.--;:.-7'-=- POSSIBLE

E' LEAK AREAS

PACKING _---7~1ii\

VALVE

STEM

23

Figure 2-11. Diagram of a gate valve.

2-11
Elastomeric O-rings are also used for sealing process valves. These

O-rings provide good sealing but are not suitable where they'e is sliding

motion through the packing gland. Those seals are rarely used in high

pressure service, and operating temperatures are limited by the seal

t . 1 24 rna erla •

Bellows s~als are more effective for preventing process fluid leaks

than the conventional packing gland or any other gland-seal arrangement. 25

This type of seal incorporates a formed metal bellows that makes a barrier

between the disk and body bonnet joint. An example of this seal is

presented in Figure 2-12. The bellows is the weak point of the system and

service life can be quite variable. Consequently, this type of seal ;s

normally backed up with a conventional packing gland and is often fitted

with a leak detector in case of failure. 26

)"

BELLOWS ~_-"'1_'-d

BODY

BONNET

Figure 2-12. 'J7 Example of bellows seals~

2-12
2-13

Figure 2-13. Diagrams of valVes with diaphragm seals.29

,iDIAPHRAGM

( b )

DIAPHRAGM

DISK

A diaphragm may be used to isolate the working parts of the valve and

the environment from the process liquid. Two types of valves which utilize

diaphragms are illustrated in Figures 2-13(a) and (b). As Figure 2-13(b)

shows, the diaphragm may also be used to' control the flow of the process

fluid. In this design, a compressor component pushes the diaphragm toward

the valve bottom, throttling the flow. The diaphragm and compressor are

connected in a manner so that it is impossible for them to be separated

under norma 1 working conditi ons. When the 'di aphragm reaches the valve

bottom, it seals firmly against the bottom, forming a leak-proof seal. This

configuration is recommended for fluids containing solid particles and for

medium-pressure service. Depending on the diaphragm material, this type of

valve can be used at temperatures up to 205°C and in severe acid solutions.

If failure of the seal occurs, a valve employing a diaphragm seal can become

f f 't' .. 28 a source a Ugl lve emlSS10ns.
2.2.1.4 Safety Relief Devices. Engineering codes require that

pressure-relieving devices or systems be used in applications whey'e the

process pressure may exceed the maximum allowable working pressure~ of the

vessel. The most common type of pressure-relieving device used in process

units ;s the pressure relief valve (Figure 2-14). Typically, $afe~ty relief

valves are sprin~-loaded and designed to open when the process pressure

exceeds a set pressure, allowing the release of vapors or liquids until the

system pressure is reduced to its normal operating level. When the normal

pressure is reattained, the valve reseats, and a seal is again foy·med. 30

The seal is a disk on a seat, and the possibility of a leak through this

seal makes the pressure relief valve a potential source of voe fugitive

emissions. Two potential causes of leakage from safety relief valves are:.

IIs;rrmering or popp;ng,lI a condition due to the system pressure being close

to the set pressure of the valve, and improper reseating of the valve after

a relieving operation. 31

Possible

Leak Area

Process Side

Figure 2-14. Diagram of a spring-loaded relief valve.

2-1L!·
Rupture disks are also common in process units. These disks are made

of a material that ruptures when a set pressure is exceeded, thus allowing

the system to depressurize. The advaritage of a ruptur~ disk is that the

disk seals tightly and does not allow any VOC to escape from the system

under normal operation. However, when the disk does rupture, the system

depressurizes ur,til atmospheric conditions are obtained. This could result

in an excessive loss of product or a corresponding excessive release of

fugitive emissions.

2.2.1.5 Agitators. Agitators are commonly used to stir or blend

chemicals. Like pumps and compressors, agitators may leak organic chemicals

at the point where the shaft penetrates the casing. Consequently, seals are

'required to minimize fugitive emissions from agitators. Four seal

arrangements are commonly used with agitators. These are compression

packing (packed seal), mechanical seals, hydraulic seals, and lip seals. 32

Packed seals for agitators are very similar in design and application to the

packed seals for pumps (Section 2.2.1.1).

Although mechanical seals are more costly than the other three seal

arrangements, they offer a greatly reduced leakage rate to offset their

higher cost. The maintenance frequency of mechanical seals is, also. one33 half to one-fourth that of packed seals. In fact, at pressures greater

than 1135.8 kPa (150 psig), the leakage rate and maintenance frequency are

so superior that the use of packed seals on agitators is rare. 34 As with

packed seals, the mechanical seals for agitators are similar to the design

and application of mechanical seals for pumps (Section 2.2.1.1).

The hydraulic seal (Figure 2-15) is the simplest and least used

agitator shaft seal. In this type of seal, an annular cup attached to the

process vessel contains a liquid that is in contact with an inverted cup

attached to the rotating agitator shaft. The primary advantage of this seal

is that it is a non-contact seal. However, this seal is limited to low

temperatures and pressures and can only handle very small pressure fluctuations. Organic chemicals may contaminate the seal liquid and then be

released into the atmosphere as fugitive emissions. 35

2-15
INVERTED CUP

ANNU.AR CUP

Figure 2-15. Diagram of a hydraulic seal for agitators.~6

Alip seal (Figure 2-16) can be used on a top-entering agitator as a

dust or vapor seal. The sealing element is a spring-loaded elastomer. Lip

seals are relatively inexpensive and easy to install. Once the seal has

been installed the agitator shaft rotates in continuous contact with the lip

seal. Pressure limits of the seal are 2 to 3 psi because it operates

without lubrication. Operating temperatures are limited by characteristics

of the elastomer. Fugitive VOC emissions could be released through this

seal when this seal wears excessively or the operating pressure surpasses

the pressure limits of the seal. 37

Figure 2-16. 38 Diagram of agitator lip seal.

2-16
2.2.1.6 Open-Ended lines. Some valves are installed in a system so

that they function with theddwnstream line open to the atmosphere.

Examples are purge valves, drain valves, and vent valves. A faulty valve

seat or incompletely closed valve would result in leakage through the valve

and fugitive VOC emissions to the atmosphere.

2.2.1.7 Sampling Connections. The operation of a process unit is

checked periodically by routine analyses of feedstocks and products. To

obtain representative samples for these analyses, sampling lines must first

be purged prior to sampling. The purged liquid or vapor is sometimes

drained onto the ground or into a sewer drain, where it can evaporate and

release VOC emissions to the atmosphere.

2.2.1.8 Flanges. Flanges are bolted, gasket-sealed junctions used

wherever pipe or other equipment such as vessels, pumps, valves, and heat

exchangers may require isolation or removal. Normally, flanges are employed

for pipe diameters for 50 mm or greater and are classified by pressure and

face type.

Flanges may become fugitive emission sources when leakage occurs due to

improperly chosen gaskets or a poorly assembled flange. The primary cause

of flange leakage is due to thermal stress that piping or flanges in some

services undergo; this results in the deformation of the seal between the

flange faces. 39

2.3 MODEL UNITS

This section presents model process unit parameters. The model units

were selected to represent the range of processing complexity in the

industry. They provide a basis for determining environmental and cost

impacts of reasonably available control technology (RACT).

2.3.1 Model Units

Available data show that fugitive em~ssions are proportional to the

number of potential sources but are not related to capacity, throughput,

age, temperature, or pressure. 40 Therefore, model units defined for this

analysis represent different levels of process complexity (number of

sources) rather than different unit size.

2-17
2.3.1.1 Sources of Fugitive Emissions. Data from petroleum refineries

indicate that cooling towers are very small sources of vac emission. 41

Differences in operating procedures, such as recirculation of process water,

might result in cooling tower vac emissions, but no data are available to

verify this. Emission rates from agitator seals have not been measured.

Since there are .10 data from simil ar sources in other industries no

estimates of emission rate can be made. Because of these uncertainties,

cooling towers and agitator seals are not included in the Model Units.

2.3.1.2 Model Units Components. In order to estimate emissions,

control costs and environmental impacts for process units on a unit specific

basis, three model units were developed. The equipment components

comprising the model units are shown in Table 2-1. These three model units

represent the range of emission source populations that may exist in SaCMI

process units. The number of equipment components for each model unit was

developed from a data base compiled by IT Enviroscience, Inc (formerly

Hydroscience).43 The data base included equipment source counts from

62 SaCMI plants which produce 35 different chemicals. These plant sites

represent approximately 5 percent of the total existing SeCMI plants and

include large and small capacities, batch and continuous production methods,

and varying levels of process complexity. The source counts for the 35

chemicals include pumps, valves, and compressors. These counts were used in

combination with the number of sites which produce each chemical in order to

determine the average number of sources per site. 44 Hydrosciehce

estimates that 52 percent of existing seCMI plants are similar to the Model

Unit A, 33 percent are similar to B, and 15 percent are similar to C.

Data from petroleum refineries indicate that emission rates of sources

decrease as the vapor pressure (volatility) of the process fluid decreases.

Three classes of volatility have been established based on the petroleum

refinery data. These include gas/vapor service, light liquid service, and

heavy liquid service. 45 The' split between light and heavy 'liquids for the

refinery data is between naphtha and kerosene. Si nce simi 1ar' stream names

may have different vapor pressures, depending on site specific factors, it

is difficult to quantify the light-heavy split. The break point is

2-113
2-19

aReference 42.

bEquipment components in VOC service only.,

c52 percent of existing SOCMI units are similar to model unit A.

33 percent of existing SOCMI units are similar to model unit B.

15 percent of existing SOCMI units are similar to model unit C.

dLight liquid is defined as a fluid with vapor pressure greater than

0.3 kPa at 20°C. This vapor pressure represents the split between

kerosene and naphtha and is based on data presented in Reference 40.

eHeavy liquid is defined as a fluid with vapor pressure less than 0.3 kPa

at 20°C. This vapor pressure represents the split between kerosene and

naphtha and is based on data presented in Reference 40.

fsample, drain, and purge valves.

9Based on 25 percent open-ended valves. Reference 1, pg. IV-3.

Number of Components in Model UnitC

130

13

14

1277

8

320

7400

42

4

4

415

2

104

2400

11

1

1

5 19 60

3 10 31

0 1 1

5 24 73

2 6 20

99 402 1232

131 524 1618

132 524 1618

104

1

26

600

Model Unit Model Unit Model Unit

A . B C

EQUIPMENT COUNTS FOR FUGITIVE VOC EMISSION SOURCES

IN SOCMI MODEL,UNITSa ' TABLE 2-1.

Valves

Gas service

Light liquid service

Heavy liquid service

Pump seals d

Light liquid service

Single mechanical

Double mechanical

Seal less

Heavy liquid servicee

Single mechanical

Packed

Equipment Comporentb

Safety/relief valves

Gas service

Light liquid service

Heavy liquid service

Open-ended linesf

Compressor seals

Sampling connectionsg

Flanges
approximately at a vapor pressure of 0.3 kPa at 20°C. The data collected by

Hydrosci ence \'!ere used to estimate the spl it between gas/vapor and 1i qui d

service for each source.

46 In order to apply emission factors for light \ '

and heavy liquid service, it is assumed that one-half of SOCMI liquid

service sources are in light liquid service. There are no data available on

the actual distrihution of sources in volatility ranges. It is assumed that

all packed seal pumps are in heavy liquid service. This assumption is

reasonable, since more volatile liquid is more suitable for mechanical seal

applications, and newer process units tend to use fewer packed seals.

Sampling connections are a subset of the open-ended valve category.

Approximately 25 percent of open-ended valves are used for sampling

connections. 47 Emissions which occur through the valve stem, gland, and

open-end are included in the open-ended valve category. The emission factor

for sampling connection applies only to emissions which result from sample

purging.

2.3.1.3 Uncontrolled Fugitive Emission Estimates. The development of

uncontrolled fugitive emission factors for SOCMI is described in

Reference 42. The resulting emission factors are shown in Table 2-2.

Generally, the method employed the use of leak/no leak emission factors

derived from data in Reference 40 coupled with leak frequencies from .

Reference 49 to arrive at average emission factors for equipment in SOCMI.

However, there are three exceptions: (1) The gas valve emission factor

reported in Reference 50 for SOeMI units had a smaller confidence interval

associated with it, and it was substituted for the emission factor derived

from data in Reference 40; (2) The emission factor for sampling connections

is based on the amount of sampling purge reported for every 1,000 barrels of

refinery throughputS1 and the average count of sampling connections per

1,000 barrels of refinery throughput reported;52 (3) The emission factor

for open-ended lines represents valve seat leakage only. The emissions

attributable to the valve, such as from around the stem and packing are

accounted for in the valve emission factor.

2-20
TABLE 2-2. EMISSION FACTORS FOR LEAKS FROM PROCESS EQUIPMENT

Equipment

Pump Seals

Light Liquid

Heavy Liquid

Valves

Gas

Light Liquid

Heavy Liquid

Compressor Seals

Safety Relief Valves - Gas

Flanges

Open-ended Lines

Sampling Connections

Reference 48.

2-21

Emission Factors

kg/hrlsource

0.0494

0.0214

0.0056

0.0071

0.00023

0.228

0.104

0.00083

0.0017

0.0150
..-----------_._-------------------------------

2.4 REFERENCES

1. Erikson, D. G., and V. Kalcevic. (IT Enviroscience.) Fugitive

Emissions. In: U. S. Environmental Protection Agency. Organic Chemical Manufacturing Volume 3: Storage, Fugitive and Secondary

Sources. Publication No. EPA-450/3-80-025. December 1980. Report 2,

p. II-2.

2. Reference 1.

3. Reference 1, p. 11-3.

4. Ramsden, J. H. How to Choose and Install Mechanical Seals. Chern. E.,

85(22):97-102. 1978.

5. Reference 1, p. 11-3.

6. Reference 4, p. 99.

7. Reference 4, p. 99.

8. Reference 4, p. 99.

9. Reference 4, p. 99.

10. Perry, R. H., and C. H. Chilton, Chemical Engineers' Handbook, 5th Ed.

New York, McGraw-Hill Book Company, 1973. p. 6-8.

11. Reference 10, p. 6-13.

12. Nurken, R. F. Pump Selection for the Chemical Process Industries,

Chern. E., February 18,1974. p. 120.

13: Nelson, W. E. Compressor Seal Fundamentals. Hydrocarbon Processing, 56(12):91-95. 1977.

14. American Petroleum Institute, "Centrifugal Compressors for General

Refiner! Servicell, API Standard 617, Fourth Edition, November, 1979,

p. 8. Figures reprinted by courtesy of the American Petroleum

Institute.)

15. Reference 14, p. 9.

16. Reference 13.

17. Reference 14.

18. Reference 14.

2-22
2-23

19. Reference 13.

29. Reference 28, p. 121.

Reference 1, p. II-5.

Reference 22, p. 147-148.

Reference 22, p. 148.

Reference 22, p. 148.

Reference 22, p. 148.

Pilulik, A. Manually Operated Valves.

p. 121.

33. Reference 32, p. 105.

34. Reference 32, p. 105.

35. Reference 32, p. 105.

36. Reference 32, p. 106.

37. Reference 32, p. 106.

38. Reference 32, p. 106.

30. Steigerwald, B. J. Emissions of Hydrocarbons to the Atmosphere from

Seals on Pumps and Compressors. Report No.6, PB 216 582, Joint

District, Federal and State Project for the Evaluation of Refinery Emissions. Air Pollution Control District, County of Los Angeles,

California. April 1958. 37 p.

31. Reference 1, p. II-7.

32. Ramsey, W. D. and G. C. Zoller. How the Design of Shafts, Seals and

Impeller Affects Agitator Performance. Chern. E., 83(18):101-108. 1976. .--

20. Reference 1, p. 11-7.

21. Lyons, J. L., and C. L. Ashland, Jr. Lyons· Enclopedia of Valves.

New York, Van Nostrand Reinhold Co., 1975. 290p.

22. Templeton, 'I. C. Valve Installation, Operation and Maintenance.

Chern. E., 78(23)141-149, 1971.

23.

24.

25.

26.

27.
39. McFarland,1. Preventing Flange Fires. Chern. E. Prog., §.§..(B):59-61. 1969.

40. Wetherold, R. G., L. P. Provost, and C. D. Smith (Radian Corporation.) Assessment of Atmospheric Emissions from Petroleum Refining,

Appendix B: Detailed Results. (Prepared for U. S. Environmental

Protection Agency.) Research Triangle Park, N.C. Publication No.

EPA-600/2-BJ-075c. April 1980~

41. Reference 40.

42. U. S. Environmental Protection Agency. Fugitive Emission Sources of

Organic Compounds -- Additional Information on Emissions, Emission,

Reductions, and Costs. Research Triangle Park, N.C. Publication

No. EPA-450/3-82-010. April 1982.

43.

44.

45.

46.

47.

48.

Reference 1, pp. IV-I, 2.

Reference 1, p. II-9-13.

Reference 40, pp. 11-23.

Reference 1, p. II-I0.

Reference 1, p. IV-8.

Reference 42.

49. Blacksmith, J. R., et ale (Radian Corporation.) Problem Oriented

Report: Frequency of Leak Occurrence for Fittings in Synthetic Organic Chemical Plant Process Units. (Prepared for U. S. Environmental

Protection Agency.) Research Triangle Park, N.C~ Publication

No. EPA-600/2-81-003. September 1980.

50. Langley, G. J. and L. P. Provost. (Radian Corporation.) Revision of

Emission Factors for Nonmethane Hydrocarbons from Valves and Pump Seals

in SOCMI Processes - Technical Note. (Prepared for the U. S. Environmental Protection Agency.) Research Triangle Park, N.C.

November 1981.

51. U. S. Environmental Protection Agency. Compilation of Air Pollutant

Emission Factors. Research Triangle Park, N.C. AP-42. February 1980.

52. Powell, D., et al. (PES, Inc.) Development of Petroleum Refinery Plot

Plans. (Prepared for U. S. Environmental Protection Agency.) Research

Triangle Park, N.C. Publication No. EPA-450/3-78-025. June 1978.

2-24
3.0 EMISSION CONTROL TECHNIQUES

Sources of process unit equipment leaks of VOC were identified in

Chapter 2. This chapter discusses the emission control techniques whi'ch are . '

,considered representative of reasonably available control technology (RACT)

for these sources of VOC ~missions. The estimated control effectiveness of

each technique is also presented.

3.1 PRIMARY CONTROL METHODS

leak detection and repair methods can be applied in order to reduce

fugitive emissions from process unit sources. leak detection methods are

used to identify equipment components that are emitting significant amounts

of VOC. Emissions from leaking sources may be reduced by three general

methods: repair, modification, or replacement of the source. In the case

of open-ended lines, however, equipment leaks are treated more effectively

by installation of control equipment.

3.1.1 Individual Component Survey for leak Detection

Each fugitive emission source (pump, valve, compressor, etc.) is

checked for voe leakage in an individual component, survey. The source may

be checked for leakage by visual, audible, olfactory, or instrument

techniques. Visual methods are good for locating liquid leaks, especially

pump seal failures. High pressure leaks may be detected by hearing the

escaping vapors, and leaks of odorous materials may be detected by smell.

Predominant industry practices are leak detection by visual and olfactory

methods. However, in many instances, even very large voe leaks are not

detected by these methods.

Portable hydrocarbon detection instruments are the best method for

identifying leaks of voe from equipment components. The instrument is used

to sample and analyze the air in close proximity to the potential leak

surface by traversing the sampling probe tip over the entire area where

leaks may occur. This sampling traverse is called "monitoring" in

subsequent descriptions. The voe concentration of the sampled air is

3-1
displayed on the instrument meter. The performance criteria for monitoring

instruments and a description of instrument survey methods are given in

Reference Method 21.

The vac concentration at which maintenance is required is called the

"action level. 11 An action level of 10,000 ppmv is considered representative

of RACT. Compor.cnts which have indicated concentrations higher than this

"action level" are marked for repair. Emission data indicate that large

variations in mass emission rate may occur over short time periods for an

individual equipment component.

3.1.2 Repair Methods

The following descriptions of repair methods include only those

features of each fugitive emission'source ('pump, valve, ~tc.) which need to

be considered in assessing the appl icabil ity a~d effectiveness o'f each

method. They are not intended to be complete repair procedures.

3.1. 2.1 Pumps. Many process units have spare pumps whi ch can be

operated while the leaking pump is being repaired. Leaks from packed seals

may be reduced by tightening the packing gland. At some point, the packing

may deteriorate to the point where further tightening would have no effect

or possibly even increase fugitive emissions from the'seal. The packing can

be replaced with the pump out of service. When mechanical seals are

utilized, the pump must be dismantled so the leaking seal can be repaired or

replaced. Dismantling pumps may result in spillage of some process fluid

causing emissions of VOC. These temporary emissions could be greater than

the continued leak from the seal. Therefore, the pump should be f'lushed of

vac as much as possible before opening for seal replacement.

3.1.2.2 Compressors. Leaks from packed seals may be reduced by the

same repair procedure that was described for pumps. Other types of seals

require that the compressor be out of service for repair. Since most

compressors do not normally have spares, repair or replacement of the seal

would require a shutdown of the process. 'If the leak is small, temporary

emissions resulting from a shutdown could be greater than the emissions from

the leaking seal.

3-2
3.1.2.3 Safety/Relief Valves. Emissions of voe from safety/relief

valves, in general, result from leakage of'the voe around the valve seat.

The leakage is most commonly attributable to improper seating of the valve,

initially or after overpressure relieving. There are basically three means

of eliminating voe leaks from safety/relief valves: (1) installation of a

rupture disk in the line prior to the relief valve; (2) connection of the

discharge port of the relief valve to a closed vent system; and (3) use of

soft seat technology such as elastomer "0-:rings. 1I

Used upstream of the safety/relief valve, a rupture disk effectively

seals the process below the set pressure o'f the disk. When this set

pressure is exceeded, the rupture disk will break, allowing the safety/

relief valve to relieve the process overpressure. ASME codes 1 provide for

such installations and set forth the design constraints for installing

rupture disks in conjunction with relief valves. ASME codes also provide

design criteria to prevent potential safety hazards from pressure building

between the disk and valve. 1 For example, a pressure gauge and bleed

valve installed between the disk and relief valve provide an indication of

leakage around the disk and the means to relieve this pressure.

After an overpressure relief, a new rupture disk would have to be

installed to reseal the system. For such an arrangement, it may be

necessary to install a 3-way valve with a parallel relief valve. This would

allow isolation of the rupture disk/relief valve system for disk replacement, while maintaining a backup relief valve in service. A block valve

upstream of the rupture disk/relief valve system will accomplish the same

purpose where safety codes allow the use of a block valve in relief valve

service.

The second method that effectively eliminates voe leaks from safety/

relief valves is connection of the relief valve discharge port to a closed

vent system. Aclosed vent system is composed of piping, connections, and,

where necessary, flow-inducing devices (e.g., fans, compressors); the system

transports gas or vapor to a centrol device such as a flare, incinerator,

boiler, or process heater. In connecting a safety/relief valve to a closed

vent system, any leakage of voe through the seat of the valve will be

destroyed in the control device.

'3-3
The use of soft seat technology in many cases will also eliminate voe

emissions from safety/relief valves due to improper valve seating. An

elastomer "0-ring" can be installed ,so that the valve forms a tight seal

after an overpressure d~scharge. Soft seat technology will not, however,

eliminate VOG emissions due to "simmering" (emissions resulting from

operation too close to the relief valve set pressure).

3.1.2.4 Valves. Most valves have a packing gland which can be

tightened while in service. Although this procedure should decrease the

emissions from the valve, in some cases it may actually increase the

emission rate if the packing is old and brittle or has been overtightened.

Plug-type valves can be lubricated with grease to reduce emissions around

the plug. Some types of valves have no means of in-service repair and must

be isolated from the process and removed for repair or replacement. Other

valves, such as control valves, may be excluded from in-service repair by

operating procedures or safety procedures. In many cases, valves cannot be

isolated from the process for removal. Most control valves have a manual

bypass loop which allows them to be isolated easily, although temporary

changes in process operation may allow isolation in some cases. If a

process unit must be shut down in order to isolate a leaking valve, the

emissions resulting from the shutdown might be greater than the emissions

from the valve if allowed to leak until the next scheduled unit turnaround

which permits isolation for repair.

Depending on site specific factors, it may be possible to repair

process valves by injection of a sealing fluid into the source. Injection

of sealing fluid has been successfully used to repajr leaks from valves in

petroleum refineries in Galifornia. 2

3.1.2.5 Flanges. In some cases, leaks from flanges can ,be l"'educed by

replacing the flange gaskets. Most flanges cannot be isolated to permit

replacement of the gasket. Data from petroleum refineries show that flanges

emit very small amounts of VOC. 3

3.1.3 Control Effectiveness of Leak Detection and Repair Techniques

For some sources of fugitive vae emissions, leak detection and repair

programs provide an effective means of reducing the total vae emitted. A

3-4
control efficiency of a given leak detection and repair program is dependent

upon the program design and several factors associated with the program

design. These factors include:

• monitoring interval;

• action level or leak definition;

• the time interval between detection of a leak and repair; and

• the emissions associated with leaking sources, nonleaking sources,

successfully repaired sources, and unsuccessfully repaired sources.

Leak detection and repair programs have been modeled using a set of

recursive equations to describe the behavior of fugitive emissions. The

model is detailed in a technical note4 and the development of the model is

summarized in the AIO. S Briefly, the leak detection and repair (LOAR)

model examines the distribution of a class (equipment type) of fugitive

emission sources in four categories:

• leaking sources (screening above t~e action level);

• non-leaking and successfully repaired sources (screening below

the action level);

• sources that were leaking and were· not successfully repaired

(these sources cannot be repaired on-line and must await a

turnaround for repair); and

• sources that were leaking, repaired, and exhibited early leak

recurrence.

At each interval, the distribution of sources in these four categories is

adjusted. The average emissions rate is then determined for the class of

sources and is dependent upon this distribution in the categories since each

category is assigned an emissions rate. The LDAR model presents the

emissions reduction at each interval for the interval and as a time-weighted

average over the entire time period since the last turnaround. The latter

values are used in the analyses presented here.

The LDAR model computes the distribution considering a number of

parameters. Table 3-1 lists the parameters on which the simulation results

are based. Also provided in the table are the input values used in modeling

leak detection and repair programs for pumps in light liquid serv1ce and

valves in gas and light liquid services.

3-5
TABLE 3-1. INPUT PARAMETERS FORLDAR MODELa

aSelection of input parameters discussed in Reference 6.

Input Parameter

Emission factor, kg/hr/source

Occurrence rate, percent

Initial leak frequency, percent

Fractional emission reduction from:

(a) unsuccessful repair (b) successful repair

Fraction of sources for which

repair attempts failed

Fraction of repaired sources

exhibiting early leak recurrence

Turnaround frequency, yrs.

Values Selected

Pumps, Valves, Valves,

Light Liquid Gas Li9ht Liquid

0.0494 0.0056 0.007

10.2 3.8 3.8

8.8 11.4 6.5

0 0.626 0.626

0.972 0.977 0.977

0 0.1 0.1

0 0.14 0.14

2 2 .2

3-6
Some of the key input values used in modeling leak detection and repair

programs were the product of an EPA study of the effect of maintenance on

VOC emissions from valves and pumps. The leak occurrence rates used in the

lDAR model were developed based on data collected in six SOCMI process

units. For valves, simple on-line maintenance techniques were the basis of

the estimates for emission reduction due to unsuccessful repair, the

emission reduction due to successful repair, and the fraction of maintained

valves exhibiting early leak recurrence. The 29 percent success rate for

attempted valve repair de,termined in the Maintenance Study was not used in

examining the effectiveness of leak detection and repair. This low value

was the result of only simple on-line maintenance techniques, such as

tightening bolts and packing. Under a rule, maintenance was determined to

be more effective; and, based on documented studies, a 90 percent success

rate of attempted valve repair was selected.

For examination of leak detection and repair programs for pumps, all

seal repair attempts were assumed to be successful. Maintenance failures

were assumed to be resultant from the mechanical aspects of the pump; these

problems would be treated under normal maintenance programs. The emission

reduction associated with successful repair (97.2 percent) is based on the

reduction from the leaking emission factor for pumps to the nonleaking

emission factor for pumps (see Chapter 2 of the AID).

Using the inputs given in Table 3-1, a quarterly leak detection and

repair plan was examined' for valves in gas service and light liquid service;

a quarterly leak detection and repair program was also considered for pumps

in light liquid service. The effectiveness values for these programs are

given in Table 3-2; also shown in the table are the corresponding emission

reductions for the three model units.

3.1.4 Open-Ended lines

Fugitive emissions from open-ended lines result from leakage through

the seat of the valve prior to the open-ended line. Leakage of vac to the

atmosphere from open-ended lines is most effectively prevented by installation of caps. plugs, and double block-and-bleed valves downstream of the

open-end. Where a double block-and-bleed arrangement is used, the upstream

3-7
TABLE 3-2. EFFECTIVENESS OF QUARTERLY LEAK DETECTION AND REPAIR

Equipment Type

Pumps (Light Li~uid)

Valves

Gas

Li ght Li qui d

Safety/Relief Valves (Gas)

Effectiveness, Percent

Emission Reduction,

Per Source, kg/yr

141

31

27

403

Compressor Sea1s 32. gC 657----- aEffectiveness estimated using the LDAR model.

bEffectiveness estimated using the ABCD model adjusted with the results of

the LDAR model for valves in gas service:

Effectiveness = ABCDS~RV X(LDAR gas valves)

, ABCD gas valves

The effectiveness estimates using the A~CD model are presented in

Reference 6.

cEffectiveness estimated using the ABCD model adjusted with the results of

the LDAR model for pumps:

Effectiveness = ABCDcompressors x (LDARpumps)

ABCDpumps

The effectiveness ~stimates using the ABCD model are presented in

Reference 6.

",

3-8
valve must be closed first to ensure product is not trapped between the two

valves; expansion of trapped chemical may leak through valve stems.

The control efficiency of using these techniques depends upon valve

seat leakage, frequency of valve use, and the amount of material trapped

between the upstream valve and the closing device (i.e., cap, plug, second

valve, etc.). oro estimate the overall effectiveness 6f using these

techniques, the annual emissions can be estimated for a leaking open-ended

line that is used about ten times annually and is otherwise closed by a cap,

plug, etc. A leaking open-ended line results in about 100 kg VOC emitted to

the atmosphere annually.7 Assuming that about 0.1 kg VOC is trapped

between the valve and enclosing device, and all of this is lost each time

the open end is operated, about 1 kg VOC would be emitted annually for the

ten times the valve is used. This relates to 99 percent efficiency; but due

to the conservative nature of this estimate, an efficiency of 100 percent

has been used to estimate the emissions reduction attributed to closing

open-ended lines.

3.2 OTHER CONTROL STRATEGIES

This section discusses two fugitive emission control strategies for

valves in gas service and valves in light liquid service other than the.

quarterly leak detection and repair procedures discussed above. Consideration of alternative control strategies for valves is pertinent because

valves account for such a large percentage of th~ components to be monitored

(about 90 percent in the model process units). Furthermore, valve leaks in

general occur slowly with gradual failure of the sealing mechanism. And the

history of leak behavior for populations of valves indicates how leaks will

occur in a valve population in the future.· Such historical leak data

permit less frequent monitoring for valve populations with a low probability

of leaking in the near term. However, alt~rnative control strategies are

not pertinent for other components (pumps, compressors, safety/relief

valves). These other equipment types exhibit more unpredictable failure,

with failure generally being instantaneous. In addition, these other

components are relatively few in number, a fact which prohibits the

application of statistical sampling plans.
These strategies should be considered alternatives to quarterly leak

detection and repair to allow plants the flexibility to meet a lE!vel of

performance using control procedures considered most appropriate by that

plant. Plants which currently have relatively few leaking valves because of

good design or existing control procedures would be most likely to benefit

fl~om these stra:egies if they were included in regulations adopted by a

State agency. Thus, these alternative control strategies might be included

in State regulations as alternative standards to quarterly leak detection

and repair. Before implementing one of these alternative control

strategies, however, an owner or operator should be required to notify the

Director of the State agency.

3.2.1 General

The emission reduction and annualized cost of a quarterly leak

detection and repair program depend in part on the number of valves found

leaking during inspections. Since about 90 percent of the components to be

monitored in a process unit are valves, most of the cost of detecting leaks

in a process unit can be attributed to valves. In general "few leaks mean

VOC emissions are low. Consequently, the amount of VOC emissions that could

be reduced through a leak detection and repair program and the product

recovery credit associated with the program would be small~ As a result,

the annualized cost of a leak detection and repair program for a process

unit increases as the number of leaks detected and repaired decreases.

On an individual component basis, valves have a lower emission rate

than other equipment components (Table 2-2) and have a percentage leak rate

which is lower than most other components. As the percent of valves found

leaking decreases, the product recovery credit decreases. The direct cost

for monitoring, however, remains the same because the number of valves which

must be monitored remains nearly the same. Therefore, the cost effectiveness (annualized cost per megagram of emissions controlled) of a leak

detection and repair program varies with the number of valves (or the

percent of valves) which l~ak within a process unit.

Figure 3-1 presents the cost effectiveness of a ,quarterly leak

detection and repair program for valves as a function of the initial percent

J··10
4 6 2

3-11

Leak frequency, percent

Cost effectiveness of quarterly leak detection and

repair of valves with varying leak frequency - .

socm units.

Figure 3-1.

o

Q+-----------~~=:-----------'--

2,000

.,.,; 0'1

::E:

........

iA-

.. Vl

Vl

QJ

c:

QJ

.... > 1,000

+->

U

QJ

4-

4-

QJ

..,

Vl

0

U
of valves found leaking. Because it is part of the cost of the overall

implementation of RACT controls and is not specifically part of the valve

control costs, the cost of the monitoring instrument is not included in the

costs of the leak detection and repair programs represented in the figure.

There is no precise breakpoint in the cost effectiveness curve shown in

Figure 3-1. However, EPA judges that the cost effectiveness of quarterly

leak detection and repair becomes unreasonably high at average leak

frequencies less than one percent. Based on this judgement, an allowable

percentage of valves leaking was determined that reflects the average of

one percent of valves leaking.

A process unit averaging one percent of valves leaking will sometimes

have less than one percent of valves leaking and sometimes have more than

one percent leaking. Statistically, if a process unit averaged one percent

of valves leaking, then the percent of valves found leaking during a random

annual inspection should exceed two percent less than five percent of the

time. In other words, if a random annual inspection indicated that no more

than two percent of valves are leaking, the probability is greater than

ninety-five percent that an average of one percent of valves leaking is

actually being achieved in practice. Therefore, two percent of valves found

leaking is a reasonable criterion to judge the applicability of alternative

control strategies for valves.

3.2.2 Allowable Percentage of Valves Leaking

A State regulation incorporating an alternative control strategy based

on an "allowable percentage of valves leaking" would require a process unit

to limit the number of valves leaking at any time to a certain percentage of

the number of valves to be monitored. As discussed above, it appears that

two percent of valves 1eaki ng represents a reasonable perfonnanc(:! 1eve1 for

an allowable percentage of valves leaking.

This type of regulation would require the owner or operator to conduct

a performance test at least once a year by the applicable test mt~thod.

Additional performance tests could be requested by the State. A performance

test would consist of monitoring all valves in gas service and in light

liquid service and of attempting to repair any valves which are ~Ieaking.
This type of regulation for valves would not affect the monitoring plans set

for other types of equipment, however. The percentage of valves found

leaking during the inspection (prior to attempted maintenance) would be

determined by dividing the number of valves for which a leak was detected by

the number of v~lves monitored. Valves that are not monitored because they

are known to be leaking (e.g., valves that are awaiting shutdown for rep'air)

are included as leaking valves in the total count of monitored valves. If

the results of a performance test showed that the percentage of valves

leaking was greater than the s,elected performance level of valves leaking

(e.g., two percent), then the process unit would be in violation of the

State regulation.

Incorporating this type of alternative control strategy in the State

regulation would provide the flexibility of a performance standard.

Compliance with the regulation could be achieved by the method deemed most

appropriate by the plant for each process unit. The plant could implement

the quarterly leak detection and repair program for valves to comply with

the regulation or it could implement a program of its choosing for valves to

comply with the performance level in the regulation.

3.2.3 Alternative Work Practice for Valves

A State regulation incorporating an alternative control strategy for

valves based on IIskip-period" monitoring would require that a process unit

attain a IIgood performance level" on a continual basis in terms of the

percentage of leaking valves. As discussed above, it appears that two

percent of valves leaking represents a "g60d performance level. 1I

This type of regulation would require the owner or operator to begin

with implementation of a quarterly leak detection and repair program for

valves. If the desired "good performance level" of two percent of valves

leaking ~as attained for valves in gas service and light liquid service for

a certain number of consecutive quarters, then one or more of the subsequent

quarterly leak detection and repair periods for these valves could be

skipped. This strategy is generally referred to as "skip-period"

monitoring. All other equipment components would not skip monitoring

intervals; they would be subject to their. required monitoring intervals.
If implementation of the quarterly leak detection and repair program

showed that two percent or less of the valves in gas service and valves in

light liquid service were leaking for 1 consecutive quarters, then m

quarterly inspections may be skipped. If the next inspection pE!riod also

showed that the IIgood per.formance level" was being achieved, thEm m

quarterly inspections could be skipped again. When an inspection showed the

"good performance level l' was not being achieved, then quarterly inspections

of valves would be reinstituted. If 1 consecutive quarterly inspections

then showed again that the good performance level was being achieved, then m

quarterly inspections could be skipped again.

As mentioned above, two percent of valves leaking repre~ent:s a good

level of performance. Table 3-3 illustrates hO\'I a "skip-per.iod" monitoring

program might be implemented in practice. In this case, the "good

performance level" must be met for five consecutive quarters (i=:5) before

three quarters of leak detection could be skipped (m=3). If the quarterly j

leak detection and repair program showed that two percent or less of the

valves in gas service and valves in light liquid service in a process unit

were leaking for each of. five consecutive quarters, then three quarters

could be skipped following the fifth quarter in which the percent of these

valves leaking was less than the "good performance level." After an

additional three quarters were skipped, all valves would be monitored again

on the fourth quarter. This strategy would permit a process unit that has

consistently demonstrated it is meeting the "good performance level" to

monitor valves in gas service and valves in light liquid service annually

instead of quarterly.

Another strategy would permit monitoring for two consecutive quarters

and skipping to semiannual monitoring. If in two consecutive quarterly

periods the good performance level of two percent (or less) of valves

leaking is achieved, then a process unit could skip to semiannual monitoring

with 90 percent certainty that the good performance level would be met in

all periods. Using skip period monitoring, a process unit could develop and

implement its own leak detection and repair procedures or install valves

with lower probabilities of leaking, thereby optimizing labor and capital

costs required to achieve a good level of performance.
TABLE 3-3. ILLUSTRATION OF A SKIP-PERIOD MONITORING PROGRAM~

Leak Leak Rate Of Quarterly Good

Detection Valves During Action Taken Performance

Period Period (%) (Monitor vs. Skip) Level Achieved?

1 3.1 Monitor No

2 0.8 Monitor Yes'l

3 1.4 Monitor Yes 2

4 1.3 Monitor Yes 3

S 1.9 Monitor Yes 4

6 0.6 Monitor Yes Sb

7 Skip - 1

8 Skip - 2

9 Skip - 3

10 3.8 Monitor No 4c

11 1.7 Monitor Yes 1

12 loS Monitor Yes 2

13 0.4 Monitor Yes 3

14 1.0 Monitor Yes 4

15 0.9 Monitor Yes Sb

16 Skip - 1

17 Skip - 2

18 Skip - 3

19 0.9 Monitor Yes 4d

20 Skip - 1

21 Skip - 2

22 Skip - 3

23 1.9 Monitor Yes 4d

ai=S, m=3, good performance level of 2 percent.

bFifth consecutive quarter below 2 percent means 3 quarters of monitoring

may be skipped.

cPercentage of leaks above 2 percent means quarterly monitoring reinstituted.

d

Percentage of leaks below 2 percent means' 3 quarters of monitoring may be

skipped.

3-15
3.3 OTHER CONSIDERATIONS

This section identifies and discusses other considerations that a State

agency may wish to address when drafting a regulation. These considerations

include components which are unsafe or difficult to reach, small process

units, and unit turnaround.

3.3.1 Unsafe and Difficult to Monitor Components

Some components might be considered unsafe to monitor because of

process conditions such as extreme temperatures or pressures. A State

agency may wish to require less frequent monitoring i,ntervals for these

components because of the potential danger which may be presented to

monitoring personnel. For example, some valves might be monitored at times

when process conditions are such that the valves are not operating under

extreme temperatures or pressures as would be found in high pressure polymer

reactors.

Some valves may be difficult to monitor because access to the valve

bonnet is restricted or the valves are located in elevated areas. These

valves might be reached by the use of a ladder or scaffolding. Valves which

could be reached by the use of a ladder or which would not require

monitoring personnel to be elevated higher than two meters would be

monitored quarterly. However, if the monitoring of certain valves would

require the use of scaffolding or would require the elevation of monitoring

personnel higher than two meters above permanent support surfaces, these

valves might be exempted from quarterly monitoring provided they are

monitored annually.

3.3.2 Small Process Unit

Some process units have so few components to be monitored that the cost

effectiveness of a quarterly leak detection and repair 'program fOlr those

process units would be high. A ~tate agency may wish to consider such

process units "small" and exempt them from compliance with a regulation.

The total cost of a leak detection and repair program would consist of

the capital cost of VOC detection instruments and the cost of labor for leak

detection and repair. The cost of VOC detection instruments would be the

same for all sizes of process units, but the cost of labor for leak

3-16
detection and repair would depend on the number of components to be

monitored. As the number of components to be monitored decreases, 'both the

labor cost and the recovery credit associated with VOC emission reduction

decrease. This results in a lower total cost. However, since the cost of

the VOC detection instruments is fixed, a leak detection and repair program

becomes less cost effective as the number of components subject to

monitoring decreases.

Valves in light liquid service and valves in gas service are the

greatest percentage (about 90 percent) of the components which would be

subject to monitoring in a typical process unit. In addition, the number of

valves in gas service and light liquid service can be used as a crude

indicator of the total ~umber of components in a process unit which would be

subject to monitoring.

Table 3-4 shows the cost effectiveness for quarterly leak detection and

repair of valves in process units processing small quantities of light

liquid and gaseous VOC. Using the processing rates at the optional cost

effectiveness cutoff levels as a guideline, States may wish to consider

exempting process units designed for processing small volumes of light

liquid and gaseous VOC from regulations requiring control of fugitive VOC

emissions.

3.3.3 Unit Turnarounds

A State agency might wish to consider a provlslon in its regulations

which would allow the agency Director to order an early unit shutdown for

repair of leaking components in cases where the percentage of leaking

components awaiting repair at unit turnaround becomes excessive. Use of

such a provision, however, must be carefully considered in terms of the

emissions reduction achievable and the costs to the process unit in

production down-time and repair cost.

Alternative methods of treating delay of repair could also be

considered by a State or local agency in reducing the cumulative number of

unrepairable equipment components. For instance, delays of repair to the

3-17
TABLE 3-4. COST EFFECTIVENESS FOR QUARTERLY LEAK DETECTION

AND REPAIR PROGRAMS FOR PROCESS UNITS PROCESSING

SMALL VOLUMES OF LIGHT LIQUID AND GASEOUS VOC

Cost-Effectiveness

($/Mg)

500

1,000

1,500

2,000

3-18

Volume Light Liquid And Gaseous VOC

Processed (Mg/Yr)

3,660

1,850

1,210

890
next scheduled process unit shutdown (or turnaround) could be allowed under"

circumstances where it is technically infeasible to repair the component

in-place/on-line (i.e., without a unit shutdown) or where replacement parts

have been depleted from once-sufficient inventory. By requiring records of

delays and reasons for delays, State enforcement officers would be supplied

with the data necessary to determine compliance.

3-19
3.4 REFERENCES

1. Part UG - General Requirements (Section VIII, Division I.) In: ASME

Boiler and Pressure Vessel Code, An American National Standa:rd.

New York, The American Society of Mechanical Engineers, 1977'. p. 449.

2. Teller, James H. Advantages Found in On-line leak Sealing. Oil and Gas

Journal, 77 (29) :54··59, 1979.

3. Wetherold, R. G., l. P. Provost, and C. D. Smith. (Radian Corporation.) Assessment of Atmospheric Emissions from Petroleum Refining, 'Appendix B:

Detailed Results. (Prepared for U. S. Environmental Protection Agency.) Research Triangle Park, N.C. Publication No. EPA-600/2-80-075c.

April 1980.

4. Williamson, H. J., et ale (Radian Corporation.) Model for Evaluating the Effects of Leak Detection and Repair Programs on Fugitive Emissions.

Technical Note DCN 81-290-403-06-05-03. September 1981.

5. U. S. Environmental Protection Agency. Fugitive Emission Sources of

Organic Compounds - Additional Information on Emissions, Emission

Reductions; and Costs. Research Triangle Park, N.C. Publication

No. EPA-450/3-82-010. April 1982.

6. Reference 5.

7. Reference 5.

3··20
4.0 ENVIRONMENTAL ANALYSIS OF RACT

This chapter discusses the environmental impacts that would result from

implementing reasonably available control technology (RACT), which is

presented in Section 4.1. The primary emphasis is a quantitative assessment

of VOC emissions in the absence of RACT (baseline emissions) and after

implementation of RACT. The impacts of RACT upon water quality, solid

waste, and energy consumption are also addressed in this chapter.

4.1 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) PROCEDURES

Reasonably available control technology (RACT) procedures for equipment

leaks of vac in SOCMI and polymer manufacturing include capping of openended lines and quarterly leak detection arid repair of pumps, valves,

compressors, and safety/relief valves. Routine instrument monitoring of

flanges, connections, and equipment in heavy liquid service is not

necessary. However, any component that appears to be leaking, on the basis

of sight, smell, or sound, should be repaired. In addition, difficult-tomonitor valves may require less frequent monitoring than the quarterly plan

considered as RACT for valves in gas or light liquid service. Small process

units (e.g., units processing small quantities of light liquid and gaseous

VOC) may be exempted from implementing routine leak detection and repair

programs on the basis of cost effectiveness for these small units (see

Table 3-4). Other exemptions might include process units processing only

heavy liquid VOC or processing only non-Vae and equipment operating under a

vacuum.

Leak detection should consist of quarterly monitoring the following

components in VOC service with an organic detection instrument: pumps in

light liquid service, valves in light liquid service, valves in gas service,

compressors, and safety/relief valves in gas service. However, states may

choose monthly monitoring for pumps instead of quarterly monitoring, because

the cost effectiveness ratio associated with monthly monitoring is more

attractive than the cost effectiveness ratio for quarterly monitoring.

Pumps in light liquid service should also be visually inspected weekly for

indications of leaks. Safety/relief valves should also be monitored after

each overpressure relief to ensure the valve has properly reseated.

4-1-
Compressor seals shoul d be monitored quarterly; however, 'soml: pl ant

owners and operators may experience difficulty in reducing concentrations of

organi c compounds to 1ess than 10 ,000 ppmv. Moreover, repa it- of compressor

seals often necessitates a potential or complete process unit shutdown

because compressors are generally not spared. Consequently, plants may find

it preferabl e to install a compressor vent control system. HOWeVE!r,

retrofitting existing compressors with these systems may POSE! a safety

problem. Because of the problems associated with quarterly monitoring or

with installation of equipment controls in certain cases, RAeT for

compressors, therefore, will be determined on a case-by-case basis. The

estimates of emission reductions for compressors in this chapt~r are based

on implementing a quarterly leak detection and repair program.

The organics detection instrument and the monitoring method E!mployed

should be EPA Reference Method 21 or an equivalent State method. A source

is considered leaking if monitoring results in an instrument reading of

10,000 ppmv or greater. A soap solution may be applied to certain equipment

as a preliminary screening technique for leakage. A soap score equivalent

to 10 ,000 ppmv is not specifi ed in this gui de' i ne document because' soap

scoring is not applicable to all source types and because it involves a

subjective evaluation of bubble formation over a specified period of time.

However, states may wish to allow plant owners or operators to use the soap

score method based on a correlation between soap scoring and instrument

readings for sour~es where soap scoring is applicable. Leaking components

should be repaired within 15 days of the date the leak is detected. Repair

should be considered as reduction of the measured organics concentration

below 10,000 ppmv. Leaking components which cannot be repaired without a

unit shutdown should be repaired at the next unit turnaround.

RACT should be applicable only to components in VOC service. A

component is considered in VOC service if it contains ten percent or greater

voe by weight. A VOC is any organic compound which participates in

atmospheric photochemical reactions. For the purpose of this, document, a

light liquid is defined as a fluid with a vapor pressure greater than

0.3 kPa at 20°C. A component should be considered in light liquid service
if it contacts a fluid containing greater than ten percent by weight light

liquid. A component should be considered in gas service if it contains

process fluid that is in the gaseous state at operating conditions.

4.2 AIR POLLUTION

Implementation of RACT would reduce VOC fugitive emissions from process

units. A significant benefi,cial impact on air pollution emissions would

result. The hourly and arinual emissions from each model unit before and

after control by RACT are presented in Table 4-1. There would be no adverse

air pollution impacts associated with RACT.

4.2.1 Development of VOC Emission Levels

The uncontrolled emission factors for process unit equipment were

previously presented in Chapter 2 (Table 2-2). Emission factors were

developed for those sources that would be controlled. by the implementation

of RACT. These controlled fugitive emission levels were calculated by

multiplying the uncontrolled emissions from this equipment by a control

efficiency. The control efficiency is determined by several factors which

are described and presented in Chapter 3. The controlled VOC emission

factors for each source are presented in Table 4-2.

In calculating the total fugitive emissions from model units controlled

under RACT, the uncontrolled and controlled emission factors were used.

These emission factors were multiplied by the equipment source inventories

for each model unit.

4.2.2 VOC Emission Reduction

The emission reduction expected from the implementation of RACT can be

determined for each model unit. The emission reduction is the difference

between the amount of fugitive emissions before RACT is implemented and the

amount of fugitive emissions after RACT is implemented. These amounts are

presented in Table 4-1. The reduction in emissions for the model units

after RACT would be implemented is 37 percent.

4.3 WATER POLLUTION

Implementation of RACT would result in no adverse water pollution

impacts because no wastewater is involved in monitoring and leak repair.

A-3
TABLE 4-1. ESTIMATED EMISSIONS AND EMISSIONS REDUCTION

ON A MODEL UNIT BASIS

Estimated Emissions Estimated Emissions Averagl2 Percent

~kf/hr ) (MT/yr) Reduction From

Level of Mo e Unit Mode Unit Uncontrolled

Control A B C A B C Level

Uncontrolled 4.5 17.2 53.7 39 150 470

RACT 2.8 10.9 34.0 25 96 300 37

. 4-4
TABLE 4-2~ EMISSION FACTORS FOR SOURCES CONTROLLED UNDER RACT

Uncontrolled

Emission Source

Inspection

Interval

Uncontrolled

Emission Factor,a

kg/hr

Control

Efficiencyb

Controlled

Emission Factor,c

kg/hr

Pumps Light Liquid Service

Valves

Gas Service

Light Liquid Service

Safety/Relief Valves

Gas Service

, f' Compressors

01

Quarterly 0.0494 0.33 0.0333

Quarterly 0.0056 0.64 0.0020

Quarterly 0.0071 0.44 0.0040

Quarterly 0.104 0.44 0.0580

Quarterly 0.228 0.33 0.153

aFrom Table 2-2.

bControl efficiency estimated based on LDAR m~del results with inputs detailed in the AID. For

compressors and safety/relief valves (gas service), the control efficiency estimates were made

using results of the ABCD model adjusted with results of the LDAR model for comparable equipment

types, as discussed in Section 3.1.3. References 1, 2, 3.

cControlled emission factor = uncontrolled emission factor x [1 - (control efficiency)].
Some liquid chemicals may already be leaking and entering the wastewater

system as runoff. A beneficial impact on wastewater would result from

implementation of RACT since liquid leaks are found and repaired. This

impact, however, cannot be quantified because no applicable data on liquid

leaks are available.

4.4 SOLID WASTE DISPOSAL

The quantity of solid waste generated by the implementation of RACT

would be insignificant. The solid waste generated would consist of used

valve packings and components which are replaced.

4.5 ENERGY

The implementation of RACT calls for an emission control technique that

requires no additional energy consumption for any of the model un'it sizes.

A beneficial impact would be experienced by saving VOC which has been

heated, compressed, or pumped.

4-6
4.6 REFERENCES

1. U. S. Environmental Protection Agency. VOCo Fugitive Emissions in

Synthetic Organic Chemicals Manufacturing Industry - Background Information for Proposed Standards. Research Triangle Park, N. C.

Publication No. EPA-450/3-80-033a. November 1980.

2. U. S. Environmental Protection Agency. Fugitive Emission Sources of

Organic Compounds - Additional Information on Emissions, Emission

Reductions, and Costs. Research Triangle Park, N. C. Publication No.

EPA-450/3-82-010. April 1982.

3. Memorandum from Stelling, John, Radian Corporation, to SOCMI Fugitives NSPS File. March 5, 1982. 1 p. Estimated effectiveness of leak

detection and repair programs for pressure relief devices.

4-7

5.0 CONTROL COST ANALYSIS OF RACT

The costs of implementing reasonably available control technology

(RACT) for controlling fugitive emissions of volatile organic compounds

(VOC) from process units are presented in this chapter. Capital costs,

annualized costs, and the cost effectiveness of RACT are presented. These

costs have been developed for the model units presented in Chapter 2. All

costs presented in this chapter have been updated to second quarter 1980

dollars.

5.1 BASIS FOR CAPITAL COSTS

Capital costs represent the total cost of starting a leak detection and

repair program in existing process units. The capital costs for the implementation of RACT include the purchase of VOC monitoring instruments, the

purchase and installation of caps for all open-ended lines, and initial leak

repair. The cost for initial leak repair is included as a capital cost

because it is expected to be greater than leak repair costs in subsequent

quarters and is a one-time cost.

The basis for these costs is discussed below and presented in

Table 5-1. Capital cost estimates for model units under RACT are presented

in Table 5-2. Labor costs were computed using a charge of $18 per laborhour. This rate includes wages plus 40 percent for related administrative

and overhead costs. 1

5.1.1 Cost of Monitoring Instrument

The cost of a VOC monitoring instrument includes the cost of two

instruments. One instrument is intended to be used as a spare. The cost

of $4,600 for a portable organic vapor analyzer was obtained from a

manufacturer. 2 .

5.1.2 Caps on Open-Ended Lines

Fugitive emissions from open-ended lines and valves can be controlled

by installing a cap, flange, or second valve to the open end. These pieces

of equipment are all included in the definition of a cap for an open-ended

· 5-1
TABLE 5-1. CAPITAL COST DATA

Cost Value

Used in Analysis

Item (June 1980 Dollars)

Monitoring Instrument 2 x 4600 =9200/model unit

Caps for Open-Ended Lines 53/line

4,5,6

Cost Basis Reference

Based on cost of single mechanical seal, assuming 50 percent credit for old

seal. June 1980 cost

determined from 1978 cost of

$113/seal and the ratio of

indices {331.8/268.1}.

One instrument used as a spare 2

Based on cost for 1" screw-on 3

type valve. Cost June 1980 =

$35. Installation =1 hour at

$l8/hour.

Replacement Seal 140/seal

U1

,

N
TABLE 5-2. CAPITAL COST ESTIMATES FOR IMPLEMENTING RACTa

(Thousands of June 1980 Dollars)

aBased on cost data presented in Table 5-1.

bNumber of open-ended lines from Table 2-1.

cInitial leak detection and repair costs are treated as capital costs since

they are incurred only once.

dIncludes screening and repair labor charges.

eRepair costs are industry-averaged per unit and, therefore, consider

fractional repairs. Equipment repair was not rounded to whole component repairs.

Capital Cost Item

1. Monitoring Instruments b

2. Caps for Open-ended Lines c d

3. Initial Leak Detection and Repair' ,e, e

4. Initial Pump Repair Costs (Replacement Seals)

Total

5-2

Model Unit Costs

A B C

9.2 9.2 9.2

5.5 22.0 67.9

1.1 4.2 13.0

0.1 0.4 1.1

15.9 35.8 91.2
•

line. The cost of a cap for an open-ended lines is based on a cost of $35

for a one-inch screw-on type globe valve. This cost was supplied by a large

distributor.? A charge of $18 for one hour of labor is added to $35 as

the cost for installing one cap. Therefore, the total capital cost for

installing a cap on an open-ended line is $53.

Caps, plugs, and blind flanges can be used at much less cost; the

capital cost of installing these enclosures range from about $0.40 per plug

for 1/4-inch hex head plugs to about $26 per 2-inch blind flange. Costs for

I-inch components range from about $1.20 per plug to $5.20 per cap.8,9,10

Ninety-two percent of the open-ended lines surveyed in one study were less

than 2-inches in diameter. ll Therefore, the cost estimate of $53 per

open-ended line is conservative given the prevalence of small sizes and

alternative enclosing devices.

5.1.3 Initial Leak Repair

The implementation of RACT will begin with an initial inspection which

will result in the discovery of leaking components. The number of initial

leaks is expected to be greater than the number found in subsequent inspections. Because initial leak repair is a one-time cost, it is treated as a

capital cost. The number of initial leaks was estimated by mUltiplying the

percentage of initial leaks per component type by the number of components

in the model unit under consideration. Fractions were not rounded up to the

next highest integer, thus resulting in industry-averaged values. The

repair time for fixing leaks is estimated to be 16 hours for a purnp seal,

40 hours for a compressor seal, and 1.13 hours for a valve. The repair time

for fixing compressor seals includes the cost of a new seal. These requirements are presented in Table 5_3. 12 The initial repair co~t was determined

by taking the product of the number of initial leaks, the repair time, and

the hourly labor cost of $18.

5.1.4 Replacement Pump Seals at Initial Repair

As with the initial leak detection discussed in the previous section,

the cost of initial seal replacements for pumps in light liquid sE~rvice is a

one-time cost and is treated as a capital cost. A replacement seal cost of

$140 per seal is based on the cost of a single mechanical seal and assumes a

5-~·
TABLE 5-3. LABOR-HOUR REQUIREMENTS FOR INITIAL LEAK REPAIR UNDER RAeT
50 percent cost credit for the seal being replaced. The number of initial

leaks per model unit is the percentage of initial leaks multiplied by the

number of pumps (light liquid service) in the model unit. To present

industry-averaged values for each model units, the fractional rep,airs

required were not rounded to the next integer.

5.2 BASIS FOR ANNUALIZED CaSTS

Annualized costs represent the yearly cost of operating a leak

detection and repair program and the cost of recovering the initial capital

investment. This includes credits for product saved as the result of the

control program. The basis for the annualized costs is presented in

Table 5-4.

5.2.1 Monitoring Labor

The implementation of RACT requires visual and instrument monitoring of

potential sources of fugitive vac emissions. The monitoring labolr-hour

requirements for RACT are presented in Table 5-5. The labor··hour requirements were calculated by taking the product of the time required to monitor,

the number of components in a model unit, and the number of times the

component is monitored each year. The monitoring times for the various

components are presented in Table 5-5. They are 0.5 man-minute for visual

inspection, 2 man-minutes for valves, 10 man-minutes for pump seals, 16 manminutes for safety/relief valves, and 20 minutes for compressor sl~als.21

Monitoring labor costs were calculated based on a charge of $18 pl~r hour.

5.2.2 Leak Repair Labor

Labor is needed to repair leaks which develop after initial repair.

The estimated number of leaks and the labor-hours required for repair are

given in Table 5-5. The repair time for each component is the same as

presented for initial leak repair. Leak repair costs were calculated based

on a charge of $18 per hour.

5.2.3 Maintenance Charges and Miscellaneous Costs

The annual maintenance charge for caps is estimated to be five percent

of their capital cost. 22 The annual cost of materials and labor for

maintenance and calibration of monitoring instruments is estimated to be

$3,000. 23 ,24,25 An additional miscellaneous charge of four percent of

5-6
5-7

TABLE 5-4. BASIS FOR ANNUA~IZED COST ESTIMATES

L (estimated number of leaking

components per model ¥nit x

rep§ir time)hx $18/hr x

1.4 x 0.163

$429/Mg VOC i

0.163 x capita~a

0.23 x capital

0.04 x capital: 0.04 x capital

$18/hourf

0.40 x (monitoring + repair labor)9

0.05 xdcapital C

$3,000

Fro~ Reference 15.

From Reference 15.

- Caps on open-ended lines - Monitoring instruments

aTen year life, ten percent interest.

bSix year life, ten percent interest.

cFrom Reference 15.

dIncludes materials and labor for maintenance and calibration. Reference 15.

Cost index = 247.3 T 223.5 (Reference 16 and 17).

eFrom Reference 15.

fIncludes wages plus 40 percent for labor-related administrative and overhead

costs. Cost (June 1980) from Reference 1~

gFrom Reference 15.

hInitial leak repair amortized for ten years at ten percent interest.

iReferences 18, 19, 20. Producer price index ratio = 327.3/228.8.

- Caps on open-ended lines - Monitoring instruments

3. Annual miscellaneous charges

(taxes, insurance, administration)

7. Recovery credits

4. Labor charges

5. Administrative and support costs

for implementing RACT

1. Capital recovery factor for capital

charges

- Caps on open-ended lines - Monitoring instruments

2. Annual maintenance charges

6. Annualized charge for initial

leak repairs
aReference 26, 27.

. b.lonltoring labor hours" (Monitoring time) x (Number of clllllponents) x (Fraction Monitored); the fraction monitored annually is an output of the LDM

model.

cFractional leaks considered and provided as an output of the LDAR model.

dLeak repair labor hours" (Repair tin~) x (Estimated number of leaks).

eThe occurrence of leaks from safety/relief valves is dependent upon the frequency of operation of the safety/relief valves. No estimates of required repairs have been presented; however, any leak that is detected in the absence of a RACT requirement would be repaired under normal plant maintenance

practices. Reference 21.

fReference 27.

TABLE 5-5. ANNUAL MONITORING AND LEAK REPAIR LABOR REQUIREMENTS FOR RAeT

Valves (Gas) .99 402 1232

Valves (Light Liquid) 131 524 1618

Safety/Relief Valves (Gas) 11 42 130

leak Repair Labor Hours

ReXuired Annuallld B C

Leak ReplIlr MOnitoring

labor Hours

Frllctfon Rexulred Annuallyb Fraction

Honitorerl •8 C Repa Ired

Monitoring ROnHoring

Tillle Pel

Source,

Han-Hin

InstruRlent 10 4 5.3 19 61 0.394 3.2 11.4 35.9 16a 50 183 574

Visual 0.5 52 3.5 13 39

Instrument 2 3.94 13.0 53 162 0.186 18.4 74.7 229 l.Ua 21 B4 259

Instl"Ulllent 2 3.94 17.2 69 212 0.186 24.4 97.4 301 1.13a 28 110 340

Instrument 16 4 11.7 45 139 e e -

e e _e e _e - - - - Instrument 20 4 1.3 2.7 10.7 0.394 0.4 O.B 3.2 40f 16 32 126

52 202 624 115 409 1299

2 8

8 29 91

Number Of

CQlIIlonents

Per Hodel Unit Type Of

A e C- Monitoring

PUI\lS (I.ight liqUid)

Compressor Seals

TOTAl

Source Type

U,

I

CO
capital cost for taxes, insurance, and associated administrative costs is

added for the monitoring instruments and caps.

5.2.4 Administrative Costs

Administrative and support costs associated with the implementation ofc

RACT are estimated to be 40 percent of the sum of monitoring and leak repair

labor costs. The administration and support costs include recordkeeping and

reporting requirement costs.

5.2.5 Capital Charges

The life of caps for open-ended lines is assumed to be ten years and

the life of monitoring instruments is assumed to be six years. The cost of

repair initial leaks was amortized over a ten-year period since it is a

one-time cost.

The capital recovery is obtained from annualizing the installed capital

cost for control equipment. The installed capital cost is annualized by

using a capital recovery factor (CRF). The CRF is a function of the

interest rate and useful equipment lifetime. The capital recovery can be

estimated by multiplying the CRF by the total installed capital cost for the

control equipment. This equation for the capital recovery factor is:

CRF = i(l + i)n

(1 + i)n - 1

where i = interest rate, expressed as a decimal

n = economic life of the equipment, years

The interest rate used was ten percent (June 1980). The capital recovery

factors and other factors used to derive annualized charges are presented in

Table 5-4.

5.2.6 Recovery Credits

The reduction of VOC fugitive emissions results in saving a certain

amount of vec which would otherwise be lost. The value of this vec is a

recovery credit which can be counted against the cost of a leak detection

and repair program. The recovery credits for each model unit are presented

in Table 5-6. The VOC saved is valued in June 1980 dollars at

$429/M9. 28 ,29,30

5-9
TABLE 5-6. ·RECOVERY CREDITS

Uncontrolled Emissions Emission Recoverleda

Model Emissions, Under RACT, Reduction, Product Value, Unit Mg/yr Mg/yr Mg/yr $/yr

A 39 25 14 6,200

B 151 96 55 24,000

C 470 300 170 74,000

aBased on an average price of $429/Mg.

5-10
5.3 EMISSION CONTROL COSTS

This section will present and discuss the emission control costs of

implementing RACT for each of the three model units. Both the initial costs

and the annualized costs are included.

5.3.1 Initial Costs

The cost of initially implementing RACT consists of capital costs and

initial leak repair. The capital cost of $9,200 for two monitoring instruments is the same for all model unit sizes. Caps for open-ended lines will

cost $5,500 for model unit A, $22,000 for model unit B, and $67,900 for

model unit C. The one-time initial leak repair cost is $1,200 for model

unit A, $4,600 for model unit B, and $14,100 for model unit C. The total

initial capital costs for implementing RACT are $15,900 for model unit A,

$35,800 for model unit B, and $91,200 for model unit C.

5.3.2 Recovery Credits

The value of VOC saved each year as a result of implementing RACT is

included as an annual credit against the net annualized costs. The implementation of RACT will result in saving $6,200 worth of VOC annually in

model unit A, $24,000 worth of VOC in model unit B, and $74,000 worth of VOC

in model unit C.

5.3.3 Net Annualized Cost

The net annual cost for controlling emissions is the difference between

the total annualized cost and the annual recovery credit for each model

unit. Net annualized control cost estimates for model units under RACT are

presented in Table 5-7. Capital cost data were previously presented in

Table 5-1.

For model unit A, the annualized capital charges are $3,200 and the

total annual operating costs are $11,500. Product recovery credits total

$6,200. The net annualized cost for model unit A is $5,600.

The annualized capital charges for model unit Bare $6,500 and the

total annual operating costs are $28,000. The recovery credit is $24,000

per year; thus, the net annualized cost for model unit B is $4,300.

5-11
------------------------:----------

TABLE 5-7. ANNUALIZED CONTROL COST ESTIMATES FOR MODEL UNITS

UNDER RACT (Thousands of June 1980 Dollars)

Model Unit

Cost Item A B C

Annualized Capital Charges

l. Control Equipment

a. Instrument 2.11 2.11 2.11

b. Caps 0.90 '3.58 11.01

2. Initial Leak Repair 0.21 0.76 2.38

Subtotal 3.22 6.45 15.50

Operating Costs

l. Maintenance Charges

a. Instrument 3.00 :3.00 3.00

b. Caps 0.28 1.10 3.38

2. Miscellaneous (taxes, insurance,

administration)

a. Instrument 0.37 0.37 0.37

b. Caps 0.22 0.8H 2.71

3. Replacement seals 0.24 0.88 2.77

4. Labor a

a. Monitoring labor b 0.94 3. 6~~ 11.23

b. Leak repair labor c 2.06 7.36 23.38

c. Plant and payroll overhead 1.20 4.39 13.84 --- Subtotal 8.31 21.60 60.68

Total Before Credit 11.53 28.05 76.18

Recovery Credits 6.19 23.76 73.88

Net Annualized Cost 5.34 4.29 2.30

aSum of labor hours for monitoring in Table 5-5 multiplied by $18/hour.

bSum of labor hours for leak repairs in Table 5-5 multiplied by $18/hour.

CBased on 40 percent of monitoring labor plus leak repair labor costs.

5-12
Model unit C has annualized capital charges of $16,500 and total

operating expenses of $76,200. The recovery credit is $74,000 per year.

The net annualized cost for model unit C is $2,300 for controlling fugitive

VOC emissions.

5.3.4 Differences in Net Annualized Costs

The cost for RACT is different for each model unit. The cost for caps

for open-ended lines varies because the number of open-ended lines is

different for each model unit. Because the larger model units have more

components, more labor-hours are needed for monitoring and leak repair. For

this reason, labor costs will increase as model unit size increases.

5.4 COST EFFECTIVENESS

Cost effectiveness is the annualized cost per megagram of VOC

controlled annually. The cost effectiveness of RACT for each model unit is

the net annualized cost for implementing RACT divided by the emission

reduction gained under RACT. The cost effectiveness of RACT is summarized

in Table 5-8.

The implementation of RACT on model unit A results in a net annualized

cost of $5,400. The emission reduction associated with RACT is 14.4 Mg/yr,

resulting in a cost effectiveness of $370/Mg.

The implementation of RACT in the case of model unit B results in a net

annualized cost of $4,300. The emission reduction associated with RACT is

55.4 Mg/yr and the cost effectiveness is $77/Mg.

The implementation of RACT in the case of model unit C results in a net

annualized cost of $2,300. Th€ emission reduction associated with RACT is

172 Mg/yr. Therefore, the cost effectiveness is $13/Mg.

A comparison of the cost effectivene~s of RACT for each model unit

reveals that cost effectiveness improves as model unit size increases. The

strong influence of recovery credits and the constant charge for monitoring

instruments regardless of model unit are responsible for the increase in

cost effectiveness.

5-13
.----~----------------------------~----------~

TABLE 5-8. COST EFFECTIVENESS FOR MODEL UNITS UNDER RACT

Model Unita

A B C

Annualized Cost Before Credit ($1000) 11.53 28.05 76.18

Annual Recovery Credit ($1000) 6.19 23.76 73.88

Net Annualized Cost ($1000) 5.34 4.29 2.30

Total VOC Reduction (Mg/yr) 14.4 55.4 172

Cost Effectiveness ($/Mg VOC) 370 77 13

a(XXX) = net credit.

5-14
The cost effectiveness of RACT for each component type in Model Unit B

is presented in Table 5-9. The cost effectiveness of RACT by component for

the other model units is the same since there are no economies of scale

associated with the control techniques and since the cost of the monitoring

instrument is not con~idered for this individual component analysis. Thus,

the individual cost effectiveness values by component presented in Table 5-9

for Model Unit B are the same as the by-component cost effectiveness values

for other model units. The overall cost effectiveness values for the three

model units differ as a result of the fixed cost for the monitoring

instrument. The cost of the monitoring instrument cannot be attributed to

any single type of component since all components are monitored by the

instrument. Therefore, the cost for each component does not include the

cost of the monitoring instrument. The cost effectiveness for RACT for

pumps and compressors is higher than other. components due to the additional

costs required for leak repair.

5-1S
TABLE 5-9. COST EFFECTIVENESS FOR C01~PONENT TYPES IN MODEL UNIT B

Annualized Annual Net Total VOC Cost

Number Of Cost Befora Recovery Annualizeg Reduction Effectiveness

Component Components Credit ($) Credit ($) Cost ($) (Mg/yr) ($/Mg)

Pumps (Light LiqUid)b 29 6,670 1,750 4,920 4.08 1,200

Valves

Gas Servi ce 402 3,670 5,400 (1,730) 12.6 (140)

Light Liquid Service 524 4,650 6,140 (1,490) 14.3 (100)

Safety/Relief Valves 42 1,130 7,260 (6,130) 16.9 (360)

Open-ended linesc 415 5,560 2,650 2,910 6.18 470

Compressors 2 890 560 330 1.31 250

<..n

(21) I

...... TOTAL UNIT (Without 1,414 22,570 23,760 (1,190) 55.4

Q) Instrument Cost)

TOTAL UNIT (With 1,414 28,050 23,760 4,290 55.5 77

Instrument Cost)

aOoes not include cost of monitoring instrument, unless otherwise noted.

bThe net cost associated with monthly monitoring of pumps is lower than the net cost shown for

quarterly monitoring of pumps. The lower net cost associated with monthly monitoring results

from higher emission reductions and, therefore, higher recovery credits. The following cost

figures are applicable to monthly monitoring for pumps:

Annualized cost before credit = 8,439

(gross cost) ($)

Emission reduction (Mg/yr) = 7.6

Annual recovery credit ($) = 3,277

Net annualized cost ($) = 5,162

Cost effectiveness ($/Mg) = 680

cCost for caps on lines only. Not monitored under RACT.

-~ - - . - . . . - - - - - - -- - - - - - - - - -
5-17

5.5 REFERENCES

4. U. S. Environmental Protection Agency. Fugitive Emission Sources of

Organic Compounds - Additional Information on Emissions, Emission

Reductions, and Costs. Research Triangle Park, N.C. Publication

No. EPA-450/3-82-010. April 1982.

Economic Indicators. Chemical Engineering. Volume 86, Number 7.

March 26, 1979.

Economic Indicators. Chemical Engineering. Volume 87, Number 21.

October 20, 1980.

Reference 3.

11. Memorandum from Hustvedt, K. C., U. S. Environmental Protection Agency,

to SOCMI Fugitive NSPS File. January 5, 1982. 9p. Summary of HI

Survey Data Compiled on 15 July 1980: Open-ended Valves (Vent, Drain,

Sample) by Size.

12. Letter with attachments from J. M. Johnson, Exxon Company, U.S.A., to

Robert T. Walsh, U. S. Environmental Protection Agency. July 28, 1977.

13. Reference 4.

14. State of California Air Resources Board. Emissions from Leaking Valves, Flanges, Pump and Compressor Seals, and Other Equipment at Oil

Refineries. April 1978. p. V-18.

5.

7.

1. Letter with attachments from Texas Chemical Council to Walt Barber,

U. S. Environmental Protection Agency. June 30, 1980.

2. Purchase order from GCA/Technology Division to Analabs/Foxboro,

North Haven, Connecticut. July 3, 1980.

3. Telecon. Samuel Duletsky, GCA Corporation with Dave Myer, Piedmont

Hub, Greensboro, N.C. September 25, 1980. Price of III screw-on type

valve.

8. Richardson Engineering Services, Inc. Process Plant Construction

Estimating Standards, Volume 3. Solana Beach, California. 1982.

9. Economic Indicators. Chemical Engineering. Volume 89, Number 21.

October 18, 1982.

10. Reference 6.

6.
15. Environmental Protection Agency. Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment. Publication No.

EPA-450/2-78-036, OAQPS No. 1.2-11. June 1978.

16. Economic Indicators. Chemical Engineering. Volume 86, Number 2.

January 15, 1979.

17. Economic Indicators. Chemical Engineering. Volume 87, Number 19.

September 22, 1980.

18. Reference 4.

19. Reference 5.

20. Reference 6.

2!. Reference 12.

22. Reference 15.

23. Reference 15.

24. Reference 16.

25. Reference 17.

26. Reference 4.

27. Reference 12.

28. Reference 4.

29. Reference 5.

30. Reference 6.

5-18
APPENDIX A

MAJOR COMMENTS RECEIVED ON THE DRAFT CTG

APPENDIX A

MAJOR COMMENTS RECEIVED ON THE DRAFT CTG

Twenty-two comment letters were received on the August 1981 draft CTG

distributed in December 1981. Some of the, comments received addressed the new

source performance standards (NSPS) for equipment leaks of VOC in SOCMI.

These comments are considered only within the technical content of the CTG;

that is, the technical aspects of the comments are considered, whereas the

regulatory decisions concerning NSPS are not addressed.

In April 1982, EPA published Fugitiv~ Emission Sources of Organic

Compounds -- Additional Information on Emissions, Emission Reductions, and

Costs (EPA-450j3-82-010), or AID. The AID represents EPA's current understanding of equipment leaks of VOC and contains the methodology for examining

emissions, emission reductions, and costs. The AID served as the primary

reference in revising cost and emission estimates presented in this document.

Out of the 22 comment letters, the following major comments were identified as having appeared several times or as having cited issues that resulted

in revisions to the CTG. The comment letters are given in their entirety in

Appendix B. The 20 comments identified in this appendix are addressed specifically with reference to the final CTG. The following comment areas are

discussed here:

(1) Need and coverage of the CTG;

(2) Estimates of emissions, emission reductions, and costs; and

(3) RACT selection, provisions, and exemptions;

A.l NEED AND COVERAGE OF THE CTG

Comment: Some commenters [#3; #9; #15]* said that SOCMI fugitive emissions

are minor sources of VOC, and that there is, therefore, no need for the CTG.

The need for the CTG was further mitigated they said, by the fact that

fugitive emissions of VOC from SOeMI were already near the level EPA hopes to

A-I
achieve through control techniques outlined in Chapter 4. They based their

argument on a comparison of estimates of controlled emissions based on

petroleum refinery data and uncontrolled emissions based on SOCMI data.

Response: Emissions of vac from SOCMI represent a significant source of VOC

emissions to the atmosphere. EPA estimates that 540 Gg/yr of VOC (540,000

Mg/yr) of VOC are emitted to the atmosphere from all sources in SOCMI (see

Table A-I). This estimate of emissions is based on detailed studies of

individual process source types including air oxidation processes, distillation operations, storage operations, carrier gas processes, equipment leaks,

and secondary sources. 540 Gg/yr of VOC is a significant quantity of VOC to

be emitted as air pollution. This quantity is large in absolute terms and is

large relative to other VOC source categories. Fugitive emissions of VOC from

SOCMI are estimated to be approximately 190 Gg/yr, thus contributing a large

proportion of VOC emissions within the SOCMI source category.

The commenters' comparison of emission estimates indicates confusion over

the purpose for CTG's and EPA's approach in developing them. EPA's intent is

not to set a regulatory goal. Rather, the intent is to provide St,ate and

local air pollution control agencies with information for determining

reasonably available control technology (RACT) for specific stationary

sources.

Comment: There were some comments [#7; #8; #20J received on the coverage of

equipment leaks by other regulations. One commenter stated that the control

techniques recommended in the CTG were already in place for vinyl chloride

plants under National Emission Standards for Hazardous Air Pollutants

(NESHAP). Other commenters discussed the potential overlap in regulations set

forth by EPA and OSHA. One commenter said that new regulations would be

redundant considering the existence of OSHA regulations. Another stated that

for some chemical plants OSHA already has standards governing equipment leaks

of VOC. For example, the commenter said that acrylonitrile plants are subject

to strict workplace exposure limits set by OSHA.

A-2
TABLE A-1. ESTIMATES OF VOC EMISSIONS FROM SOCMI~

Category Gg/yr Percent of Total

Fugitive emissions 189 35

Distillation operations 140 26

Air oxidation processes 110 20

VOL storage operations 47 8

Carrier gas processes 32 6

Secondary &misc. emissionsb 26 5

Revised total VOC emissions 544 100

aEstimates for process emission sources estimated using best available

information from current standards development programs (25 October 1982).

Reference 1.

bSecondary and miscellaneous emissions estimated as 5 percent of the total

of the other sources.

A-3
Response: As discussed in Chapter 1, Control Techniques Guidelines (CTG) are

designed to assist states in bringing non-attainment areas into compliance

with national ambient air quality standards by providing them control .

technology information. Their role is distinct from that of OSHA regulations

and national emission standards for hazardous air pollutants {NESHAP).

NESHAP are developed to control poll utants that are hazardous because'

they are carcinogens or the cause of other serious diseases. Some of the

individual SOCMI chemicals have been identified as hazardous air pollutants

and some SOCMI units may be affected by NESHAP regul ations. HOWE!Ver, SOCMI

VOC emissions as a class have not been identified as hazardous pollutants, and

therefore, are not subject to NESHAP. Therefore, there is still a need for

the CTG. The CTG is consistent with both NSPS and NESHAP with respect to the

equipment covered. There is no duplication of efforts required by the eTG;

equipment covered by NSPS or NESHAP is exempt from the CTG since the equipment

is already controlled to a higher degree under these other programs.

Many of the chemicals covered by the CTG are also listed in Table Z-I,

Toxic and Hazardous Substances, in the general provisions for OSHA (29 CFR

1910.1000), and some of these chemicals are also covered by more specific

health standards under OSHA. As a consequence, the eTG and the OSHA standards

may affect the same equipment in VOC service. However, this possibility also

does not negate the need for the CTG.

Control techniques described in the CTG serve to limit mass emission

rates directly; OSHA standards for toxic chemicals generally do not. Under

OSHA, control of emission sources may include substitution with less hazardous

materials, process modification, worker rotation, process or work,er isolation,

ventilation controls, or modification of work practices. These controls

reduce occupational exposures, but they do not necessarily reduce the mass

rate of VOC emissions to the atmosphere. Relying on indirect controls that

mayor may not reduce emissions that would degrade air quality would be an

unreasonable approach to reducing emissions of VOC. However, in some

instances, control of emissions provided by OSHA requirements may be

sufficiently effective to allow an alternative standard (e.g., ,pel~centage of

valves leaking) to be met. Furthermore, the need for CTG controls can be

A-4
eliminated for certain sources under specific circumstances. For example, the

quarterly monitoring requirement for a pump seal could be eliminated if the

pump is equipped with dual mechanical seals with a non-VOC barrier fluid

system/degassing reservoir connected to a ~losed vent system.

Comment: Several [#8; #13; #16; #21; #22J commenters recommended deletion of

styrene-butadiene latex from the list of processes covered by the CTG.

Commenters pointed out the fact that styrene-butadiene latex plants consist of

fewer reactors and ancillary equipment than styrene-butadiene crumb rubber

plants, although the equipment is of a similar type. Therefore, fugitive

emissions should be similar in magnitude or lower. Since the crumb rubber

processes were deleted from the list, it seemed appropriate to the commenters

to delete the latex rubber processes;

Commenters further pointed out the fact that the production of styrenebutadiene latex is less than 15 percent of the production of styrene-butadiene

crumb rubber. This comparatively low production rate was considered further . . justification for deleting styrene-butadiene latex from the list, since it is

a small part of the total styrene-butadiene production.

Another point made in support of deleting styrene-butadiene latex was the . .

fact that most gas valves in styrene-butadiene plants are in vacuum service,

so they would not be sources of fugitive emissions.

Some commenters continued their argument that neither polymer nor resin

manufacturers are similar to the chemical producers in SaCMI. Specifically, a

number of commenters stated that styrene-butadiene latex plants are not like

the remaining plants in SOCMI. Furthermore, the commenters said there were no

styrene-butadiene plants in the SOCMI data base. The commenters, therefore,

concluded that the saCMI data base was not representative of their particular

industry segment.

Response: In the August 1981 draft CTG, four categories of polymers and

resins were included for coverage under this CTG: polyethylene, polypropylene, polystyrene, and styrene-butadiene latex. Other polymers and resins

were dropped from consideration under the CTG for equipment leaks of vac prior

A-5
~--------------------------------:-------------

to the distribution of the draft CTG. EPA has also removed styrene-butadiene

latex from the list of affected chemicals. Thus, this CTG covers only

polyethylene, polypropylene, and polystyrene from the polymers and resins

category. However, in the future EPA will consider recommending RACT for

equipment leaks of vac from units producing the polymers and resins not on the

final list.

The decision to drop styrene-butadiene latex from consideration at this

time is not based on the inapplicability of SOCMI data or RACT to styrenebutadiene latex units. The data base presented in the AID (on which the final

CTG is based) is comprised of data on equipment leaks of VOC in SOCMI. The

data were collected from a variety of SaCMI process types and are considered

representative of VOC emissions from equipment found in chemical and polymer

plants. The data, therefore, are deemed applicable to those equipment types

found in styrene-butadiene latex units. However, in order to allow further

consideration of the processing equipment in various polymer and resin

manufacturing units, styrene-butadiene latex (along with several other

polymers and resins) are not included in the scope of this CTG.

In addition to these considerations made for polymers and resins, EPA has ,

further evaluated coverage of the CTG since the draft document was released

for comment. Methyl tert-butyl ether (MTBE) is a relatively new, high-growth

organic chemical that has gained prominence as a gasoline additivE~, replacing

lead-based additives. MTBE was not produced in large quantities commercially

when the SaCMI list of organic chemicals was originally composed. Because

MTBE is a large volume organic chemical with a high growth rate and because it

is produced in the same synthetic organic chemical plants current"ly covered by

the CTG, MTBE is being added to the list of organic chemicals covered by the

CTG.

A.2 ESTIMATES OF EMISSIONS, EMISSION REDUCTIONS, AND COSTS

Comment: Commenters [#2; #5; #6; #7; #9; #13; #15; #16; #17; #18;, #19; #20;

#21; #22J objected to the application of fugitive emissions data collected in

petroleum refineries to SOCMI and polymer processes. The commentE!rS said that

A-6
fugitive emissions from SOCMI are lower in terms of both leak frequency and

mass emission rate. Several reasons for the differences were given including

smaller unit sizes, lower temperatures and pressures, more expensive products,

more toxic products, and chemicals whose leaks are self-sealing such as

polymers. They referred to fugitive emissions data generated in SOCMI as

evidence of the lower emissions from SOCMI processes when compared to

petroleum refineries. Commenters said that the data showed the differences

between the industries and recommended the use of SOCMI data exclusively.

Commenters [#3; #5; #9; #13; #16; #17; #20; #22J further objected to the

use of refinery data on technical grounds. They cited differences in

calibration gases and screening instruments used in studies of the industry

and differences in response factors of different chemicals as reasons that

data generated in petroleum refineries should not be considered relevant to

SOCMI.

Response: EPA's analysis of fugitive emissions data is extensively documented

in Fugitive Emission Sources of Organic Compounds -- Additional Information on

Emissions, Emission Reductions, and Costs (EPA-450j3-82-010, April 1982). As

the Additional Information Document (AID)2relates, EPA reviewed all available

fugitive emissions data from SOCMI as well as from petroleum refineries. EPA

determined that the best studies on which emission estimates for SOCMI

emission sources could be based were the Refinery Assessment Study3 and the

SOCMI Twenty-four Unit Study.4 EPA considered these data sets to show

differences between the SOCMI data and the petroleum refinery data. The

assessment of differences and similarities between the data sets was not

clearcut. There were some apparent differences, but they could not be

explained conclusively. The differences may be due to factors mentioned by

the commenters. It is impossible to tell because there are so many variables.

It seemed illogical that on the average, identical equipment handling similar

organic compounds would behave differently. However, EPA determined that the·

differences, as indicated by the data, were evident. Because of the

differences, EPA decided that an adjustment of the emission factors used

previously was warranted.

A-7
After considering alternative approaches, EPA concluded that the best

method of arriving at a complete set of emission factors for equipment leaks

was by using leak frequencies determined in the SOCMI 24-UnitStudy to weight

the emission factors determined in the Refinery Assessment Study. The

resulting emission factors are presented in Chapter 2.

The technical considerations cited by the commenters refer to the

monitoring instruments, calibrants, and procedures used in the different

studies of fugitive VOC emissions. These considerations are examined in

detail in the AID. The differences in measurement methods and response

factors cited by the commenters were considered by EPA and were not found

significant. The variability seen in repeat sampling of the same source was

23 percent. 5 This variability is in the same range as the 30 percent

difference seen in response between the TLV-hexane system and the OVA-methane

systems at the 10,000 ppmv action level. 6 Because the variability in repeat

sampling is so similar to the differences in response at 10,000 ppmv, the data

can be used interchangeably within ±30 percent at the action level.

Furthermore, laboratory experiments measuring variation in response

factors for a number of organic chemicals indicated that 90 percent of the

chemicals tested had responses between 0.1 and 10. 7,8,9 When considered in

analyzing leak frequencies,10 the response factor variation, however, did

not product significant changes in the overall percent leaking estimates

resulting from the SOCMI 24-Unit Study.

As presented in Section 4.1, RACT requires the use of a VOC detection

instrument and monitoring method in accordance with EPA Reference Method 21 or

an equivalent State method. An instrument reading of 10,000 ppmv is used as

the definition of a leak. Soaping is permitted for some sources as a

prescreening tool, but this technique, where applicable, must be supplemented

with instrument screening if leaks are indicated using soaping. Soaping is an

additional element of RACT beyond that presented in the draft CTG.

Comment:

estimates

Referring

Commenters [#9; #14; #17; #19] disagreed with contl~ol efficiency

for leak detection and repair programs presented in the draft eTG.

to the ABCD model calculations, commenters said that thE: occurrence

A-8
and recurrence function used to derive the ~-factor was not supportable and

should be revised. They recommended a time series model which could be used

in calculating a B-factor. They also felt that the repair effectiveness

(D-factor) should be lower than the figure used in the draft CTG.

Response: The control efficiencies presented in the draft CTG for leak

detection and repair programs were estimated using the ABCD model. These four

factors, when taken together, considered the maximum emissions reduction

potential (A) and accounted for other factors such as delay of repair (C),

emissions reduction to a non-zero emissions ;level (D) and the occurrence and

recurrence of leaks and the number of non-repairable leaks between monitoring

inspections (B). Of these factors, the B-factor involved the most subjective

consideration; the selection of the value for the B-factor was based on the

engineering judgement that the rates for occurrenceirecurrenceinon-repairable

leaks were non-linear with respect to monitoring interval.

The commenters are partially correct in stating that occurrence rates

should be linear. Occurrence rates have been found to be essentially linear

in the studies of fugitive emissions reported in the Maintenance Study. 11

In this report, the leak occurrence rate is described by an exponential

distribution model and the leak recurrence rate i~ described by a mixed

distribution model, which incorporates an exponential model to describe

long-term leak recurrences. Both models are non-linear in format. But, as

applied to the data collected in these studies, the models result in a nearly

linear relationship with time. In fact, only slightly non-linear leak

occurrence and recurrence rates for valves are noted when considering a

monitoring interval of one year.

Analysis of the results of the Maintenance Study led to the development

of a new model describing leak detection and repair programs.' This model is

described in detail in a Technical Note12 and in the AID. The Leak

Detection and Repair (LDAR) model is based on a set of recursive equations

describing leaks from equipment in terms of four categories:

A-9
(1) Nonleaking equipment (screening < action level),

(2) Leaking equipment (screening action level),

(3) Leaking equipment which cannot be repaired on-line and are

awaiting a process unit shutdown for repair, and

(4) Repaired equipment that exhibit early leak recurrence.

Three emission rates describe these four categories; a single em';ssion rate is

used to describe equipment in the last two categories listed.

In describing these various categories, the LDAR model requ'ires more

information than the ABCD model. This information includes repa'ir

effectiveness, emissions reduction for successful repair, and em'issions

reduction for unsuccessful repair. These data are available for pumps in

light liquid service and for valves in gas and light liquid service; their

selection is detailed in the AID and summarized in Chapter 3.

The LDAR model is the preferred predictor of leak detection and repair

effectiveness where the detailed information is available because the

resulting estimates are based on experimental data rather than engineering

judgment alone. But the ABCD model remains a viable method of estimating the

effectiveness of programs for equipment types for which these data are not . available. To refine the ABCD estimate for such equipment types, the results

of the LDAR model for comparable equipment types may be applied. For example,

detailed leak occurrence and repair data have not be generated for safety/

relief valves in gas service. By comparing LDAR results to ABCD results for

valves in gas services, the ABCD results for safety/relief valves can be

adjusted to yield a refined estimate for leak detection and repair programs

applied to safety/relief valves. The AID discusses this refinement procedure

for safety/relief valves in additional detail. This is the same approach

taken in estimating the effectiveness of leak detection and repair for

compressors. a '

aEffectiveness1 = ABCDI x

ASTIJ2

For safety/relief valves in

for valves in gas service.

results for compressors due

(LDAR Effectivness)2

gas service, comparisons were made with results

Comparisons to pumps were used to adjust ABCD

to similarities in sealing mechanisms.

'A-IO
Comment: Two commenters [#9; #14J specifically cited fugitive emission

testwork in supporting their comments on the: occurrence rate and recurrence

rate assumed in computing the control efficiency of leak detection and repair

techniques. One commenter said that for valves the occurrence rate varies

with the leak frequency and that the data in· the SOCMI studies are biased to

the high side of the leak frequency spectrum. Recurrence of leaks was

estimated, according to the commenter, using an extremely sparse data set,

resulting in a recurrence rate of questionable utility. To support the same

claims, the other commenter cited values determined in a fugitive emission

study in a high density polyethylene plant.

Response: Occurrence and recurrence of leaks was embodied in the 8-factor of

the ABCD model for fugitive emissions. An improved model, the LDAR model, is

now the basis for estimates of emissions and emission reductions for valves

and pumps operating under leak detection and repair programs. However, the

LDAR model requires data which are unavailable for some other equipment types.

As discussed in the previous response, the LDAR model is used in conjunction

with the ABCD model for those sources (compressors, safety/rel~ef valves). i

The inputs used for occurrence and recurrence in the LDAR for pumps and

valves were documented and explained in detail in the AID. EPA chose the best

values available for these input parameters. Occurrence rate estimates for

valves were available from two studies. First, the Maintenance Study had

occurrence rate estimates developed from tests in three SOeMI processes.

Estimates were presented for each type of process (vinyl acetate, cumene, and

ethylene) and by service (gas, light liquid). An overall estimate for all

units was also developed. Second, the Allied HOPE Study13 presented

occurrence rate estimates for valves in a high density polyethylene unit. Due

to some inconsistencies noted in this study and due to the broader range of

processes covered by the Maintenance Study, occurrence rates generated in the

Maintenance Study were considered to be the best available estimates of

occurrence rates for valves. Because the confidence intervals for the

occurrence rates for individual process units showed substantial overlap

(i.e., the occurrence rates for the process units were not significant

A-ll
different), the overall 3D-day occurrence rate of 1.3 percent was selected as

an input to the LDAR model. The Maintenance Study showed that about 14

percent of all repaired valves started to leak again within 5 days of repair.

The only other recurrence rate data is from the Allied HOPE Study. However,

that study does not provide information for early failures. Therefore, early

leak recurrence rate data from the Maintenance Study were used for input to

the model.

As shown in the AID, the only occurrence rate data available for pumps

are from the Maintenance Study. This occurrence rate was adjusted to account

for pump seal replacement which normally occurs. The resulting 3D-day

occurrence rate input is 3.4 percent. Because leaking pump seals are usually

taken off-line and replaced with new seals, a successful repair rate of

100 percent was used, and the early leak recurrence rate was taken as O. The

leak recurrence rate equals the leak occurrence rate.

Comment: Several comments [#3; #4; #6; #9J were received regarding the

estimated costs associated with RACT requirements. Several comments concerned

increased cost effectiveness estimates resultant from increased costs and

decreased emission reduction estimates. One commenter stated that the capital

costs estimated for RACT did not include the costs of initial survey

inspections and repair. Other commenters felt that monitoring time estimates

for valves were underestimated and that this time did not include preparation

time and travel time between sources. Another commenter cited several causes

of the "unrealistic" cost estimates: a low interest rate, a low overhead

charge, and an underestimate of valve size.

Response: The costing methodology for controlling equipment leaks of VOC was

reviewed in detail in the AID. Costing techniques and cost assumptions were

discussed for equipment control techniques as well as for leak detection and

repair programs. The methodology presented in the AID has been applied to the

cost estimates presented in Chapter 5. The revised estimates of costs are

higher than those presented in the draft eTG. The annualized costs of RACT

for model unit B presented in Table A-2 result from use of these assumptions.

A-12
TABLE A-2. COSTS FOR COMPONENT TYPES IN MODEL UNIT B

Annualized Annual Net Total VOC Cost

Number Of Cost Befor~ Recovery Annualizeg Reduction Effectiveness

Component Components Credit ($) Credit ($) Cost ($) (Mg/yr) ($/Mg)

Pumps (Light Liquid)b 29 6,670 1,750 4,920 4.08 1,200

Valves

Gas Service 402 3,670 5,400 (l,730) 12.6 (140)

Light Liquid Service 524 4,650 6,140 - (1,490) 14.3 (100)

Safety/Relief Valves 42 1,130 7,260 (6,130) 16.9 (360)

Open-ended Linesc 415 5,560 2,650 2,910 6.18 470

Compressors 2 890 560 330 1. 31 250

J::> TOTAL UNIT (Without (1-,190) (21) I

l-' 1~414 22,570 23,760 55.4

(..oJ Instrument Cost)

TOTAL UNIT (With 1~414 28,050 23,760 4,290 55.5 7-7 In~trument Cost)

aOoes not include cost of monitoring instrument~ unless otherwise noted.

bThe net cost associated with monthly monitoring of pumps is lower than the net cost shown for

quarterly monitoring of pumps. The lower net cost associated with monthly monitoring results

from higher emission reductions and, therefore, higher recovery credits. The following cost

figures are applicable to monthly monitoring for pumps:

Annualized cost before credit = 8~439

(gross cost) ($)

Emission reduction (Mg/yr) = 7.6

Annual recovery credit ($) = 3,277

Net annualized cost ($) = 5,162

Cost effectiveness ($/Mg) = 680

cCost for caps on lines only. Not monitored under RACT.
Also, the cost effectiveness, or the ratio of the annualized contl"ol cost to

the emissions reduction achieved, is presented in Table A-3, along with the

estimated control efficiency of each selected RACT. Although these costs are

higher, they are reasonable costs and cost effectiveness of control.

As in the draft CTG, where leak detection and repair programs have been

selected as RACT, the cost of the initial screening and repair of leaking

equipment components has been capitalized. These costs are assume!d to be

amortized at 10 percent interest over a ten year period (a 2-year period is

used for replacement seals). A six-year amortization period was used for

capitalizing monitoring instruments. The 10 percent interest rate used is

conservative in that it represents a real rate of return after taxes and not

merely a typical interest rate.

The monitoring time estimates for valves were examined in the AID. The

2 man-minutes per valve monitoring time used was based on informat:ion provided

by Exxon Company, USA. 14 It is a process unit-wide average value and is the

most reasonable estimate available in the absence of data to the contrary.

The 40 percent overhead rate was found to be low by some commenters who

suggested 100 percent would better reflect an overhead charge. The labor

charge of $18 per hour includes a 40 percent charge for labor-related administrative and overhead costs. An additional 40 percent rate is applied to the

$18 per hour rate to account for the administrative and support costs

associated with implementation of RACT. These two charges taken together

amount to a cumulative 96 percent total overhead charge rate.

A one-inch valve size was selected as the basis of the capital costs for

control of open-ended lines. A survey of the data on which the model units

were based showed that approximately 92 percent of the valves in the process

units surveyed were two-inch diameter or smaller. Moreover, the one-inch

valve size was used to estimate the cost of controlling open-ended lines only.

The costs of controlling emissions from open-ended lines are based on

installing a second valve. Plugs, caps, or blind flanges are also expected to

be used to control open-ended lines; the costs of these materials are similar

or less than the costs of one-inch valves. In most cases, therefore, the

control cost based on these equipment would be much lower than estimated for

use of a second valve.

A-l4: ,1

.1
TABLE A-3. EQUIPMENT LEAKS OF VOC FROM SYNTHETIC ORGANIC CHEMICAL AND

POLYMER MANUFACTURING: RACT

Average Cost

Equipment

Average Control Effectivenessb Effectiveness, (with credit),

Type Control Technique Percent $/Mg

Pumps (light liquid Quarterly leak detection &repair 33 1~200

service)

Valves (gas and light Quarterly leak detection &repair 51 (114 )d

liquid service)

Safety/relief valves Quarterly leak detection &repair 44 (360)c

(gas service)

, I

.....

CJ1 Open-ended lines Equipment 100 470

Compressors Quarterly leak detection &repair 33 250

aControl effectiveness of leak detection and repair programs is based on results of LOAR model,

either solely or in combination with the ABCD model results.

bCosts are 2Q1980 and assume $429/Mg recovery credit for VOC saved or recovered as a result of

implementing the control technique.

cParentheses indicate net savings resulting from the credit value of the saved/recovered VOC.
A.3 RACT SELECTION, PROVISIONS, AND EXEMPTIONS

Comment: Commenters [#4; #5; #9; #14; #19J called the 2 percent good

performance level arbitrary and said that it was too low for RACT. Values

offered as more realistic levels of good performance were 4 percent and 10 to

12 percent. It was also recommended that flexibility be offered plants in

setting good performance levels.

Response: As discussed in previous responses and in Chapter 3, estimating the

effectiveness of leak detection and repair in reducing VOC emissions resulting

from equipment leaks has been facilitated for some equipment types by the LDAR

model. The LDAR model has been used to examine the costs and effectiveness of

leak detection and repair for valves eXhibiting varying initial leak frequencies (see Section 3.2.1). As shown ;n Figure 3-1, the cost effectiveness of

quarterly leak detection and repair for valves become unreasonablE~ around

1 percent leaking initially in a process unit. As discussed in Chapter 3, a

performance level of 2 percent leaking would ensure that most units would be

achieving around 1 percent leaking. Therefore, an alternative to periodic

leak detection and repair for valves could be a performance level of 2 percent

leaking in a process unit.

The selection of a performance level based on the percentage of valves

leaking was not a question of technical achievability of such a pE~rformance

level. The selection was based on the high cost effectiveness associated with

routine (quarterly) leak detection and repair of valves in model units

exhibiting low leak frequency. This type of alternative standard not only

allows low-leak units an exemption from routine monitoring where it is not

cost-effective, but it also provides an incentive to units exhibiting higher

leak frequencies to attain the performance level by means of installing better'

equipment or improving their current maintenance practices.

In addition, skip-period monitoring plans, discussed in Section 3.2.2,

may provide another mechanism for achieving a performance level at minimal

monitoring. Under such plans, monitoring requirements can be minimized for

individual process units that seek to maintain a given performance level of

percent of valves leaking.

A-H;
Comment: One commenter (#20]· stated that the CTG should relate only to photochemically reactive VOC. And priorities should be established to control only

those substances determined to be photochemically reactive based on the

documented differences in photodegradation rates and ozone yield of various

organic compounds. Other comments [#5; #9] referred to the definition of VOC

given in the proposed NSPS. One commenter stated that the definition included

nonphotochemically reactive organic compounds that do not contribute to ozone

formation. Another commenter felt that the definition should be clarified and

rely on Reference Method 21 in determining if a compound should be considered

a VOC. Moreover, he felt that the limitations of the detection instruments

should be accounted for in the definition of VOC.

Response: Volatile organic compounds (VOC) are any organic compounds which

participate in atmospheric photochemical reactions. At present, the

Administrator has identified only the following organic chemicals as

nonreactive organic chemicals:

• methane

• ethane

• l,l,l-trichloroethane

• methylene chloride

• trichlorofluoromethane

• dichlorodifluoromethane

• chlorodifluoromethane

• trifluoromethane

• trichlorotrifluoroethane

• dichlorotetrafluoroethane

• chloropentafluoroethane

The RACT requirements discussed in this CTG. are applicable to equipment that

are "in VOC service,I' which is defined as containing at least 10 percent vac

by weight. In determining whether a piece of equipment is "in vac service,"

the organic chemicals listed above as nonreactive organic compounds may be

excluded from the total VOC determined by the appropriate reference methods.

A-17
The definition of "in VOC service" is a means of determining if a piece

of equipment is subject to RAeT requirements. Once the determination is made

that a piece of equipment is "in VOC service," the requirements of RACT stand

alone and do not rely on the definitio~ of VOC.

Comment: Several commenters [#5; #9; #10; #20] took exception to the

selection of 0.3 kPa as the vapor pressure breakpoint separating light liquid

and heavy liquid services. They felt this selection was arbitra~y and that

other choices would have more relevance to the chemical industry. The

commenters presented alternative choices based on:

(1) the vapor pressure at 20°C corresponding to the concentration

equivalent of the leak definition (action level);

(2) the split between gasoline and kerosene (1.5 psia or 10 percent of

the ASTM distillation point); and

(3) the vapor pressure at operating conditions (with light liquids

defined below the vapor pressure of 760 mm Hg at operat'ing

conditions).

Response: EPA's analysis of fugitive emission rates and vapor pressures has

shown that substances with vapor pressure of 0.3 kPa and higher have

significant emission rates while those with lower vapor pressures are not as

significant. This vapor pressure (0.3 kPa) represents the split between

kerosene and naphtha and is the criterion used by EPA to distinguish between , '

light liquid and heavy liquid substances. The split was made to concentrate

effort in a leak detection and repair program on the sources with the largest

potential to leak.

Comment: Various comments [#6; #18] dealt with the selection of 10,000 ppmv

as the leak definition. One commenter felt 10,000 ppmv was a satisfactory

leak definition for all sources, except valves in gas/vapor service. He

recommended 100,000 ppmv for gas valves. Another commenter suggested that

100,000 ppmv should be used for all sources based on an improved cost

1\-lG
effectiveness. The commenter stated that the control efficiency of leak

detection and repair techniques would be nearly the same for leaK definitions

of 100,000 and 10,000 ppmv. Other commenters felt that 10,000 ppmv was too

low a leak definition and that the definition should be based on a mass

emission rate equivalent.

Response: One consideration in selecting 10,000 ppmv as the leak definition

for eq~ipment leaks of VOC was the monitorihg instrument characteristics.

Data on which the CTG is based were collected using hydrocarbon detectors that

are readily available. These instruments provide a direct measurement of

organics concentrations up to 10,000 ppmv;in order to measure higher , '

concentrations with the instruments most commonly used, additional care and

calibration for devices such as dilution probes are required to obtain

reliable results. And as a result, additional costi are associated with

measuring concentrations higher than 10,000 ppmv. Although instruments that

directly measure higher concentrations of organics may be available in the

future, the monitoring requirements are based on the least complicated and

best established portable hydrocarbon detection technique currently available.

Table A-4 presents a summary of the percent of sources screening above

the action level (leak definition) for various action levels (an indication of

the number of leaks) and percent of mass emissions attributable to these

action levels for valves. Analysis of the results from the Maintenance Study

demonstrates that a significant quantity of mass emissions would be detected

with an action level of 10,000 ppmv instead of 100,000 ppmv for the SOCMI

sources tested. In addition, an analysis of leak detection and repair

programs based on 10,000 ppmv and 20,000 ppmv action levels indicate that

improved cost effectiveness and greater emissions reduction is associated with

the 10,000 ppmv program. IS EPA sees the opportunity to control these leaks

as a significant opportunity for cost~effective emission control.

Comment: The monitoring requirements of the draft guidelines were said to be

overly restrictive and excessive [#3; #6; ~9; #18J. Several commenters

recommended annual monitoring instead of the quarterly scheme presented in the

J\-19
TABLE A-4. SUMMARY OF PERCENT OF SOURCES DISTRIBUTION CURVE§ AND

PERCENT OF MASS EMISSIONS CURVES AT VARIOUS ACTION LEVELS

Percent of Sources Screening Aboveb Percent of Mass Emissions Attr~bgtable

to Sources Screening Above ' 10,000 20,000 40,000 100,000 10,000 20,000 40,000 100,000

Valves

Gas

Ethylene 15 12 10 7 94 90 84 71

Cumene 16 13 10 6 94 89 83 69

Vinyl Acetate 3.7 2.8 2.0 1.2 90 84 77 62

Light Liquid :l':"~

!

Ethylene 26 22 18 13 89 83 75 60 r·~

'-" Cumene 12 9 6 4 80 71 61 45

Vinyl Acetate 0.2 0.1 0.1 ° 25 16 10 4

Pump Seals

Light Liquid Ethylene 30 24 18 12 96 92 86 73

Cumene 14 11 8 5 89 83 75 61

Vinyl Acetate 1.7 1.0 0.5 0.2 67 57 46 31

aCurves are based on models derived from data collected during 24-unit SOCMI study. h

uScreening values ;n ppmv.

cThese values were based on the original leak rate/screening value correlations presented in the

Maintenance Study and have not been changed to reflect the new correlations developed in the

Technical Note on the revision of SOCMI emission factors. Based on a comparison of empirical data, these values are not expected to change significantly.
draft CTG. They based their recommendation on improved cost effectiveness of

an annual monitoring plan. One of these comments suggested that for valves

monitoring frequency could be increased for units where annual monitoring

failed to achieve an allowable percentage of valves leaking.

Response: Section 4.1 presents RACT for equipment leaks of VOC in synthetic

organic chemical and polymer manufacturing plants. RACT procedures include

quarterly leak detection and repair of pumps in light liquid service, valves

in gas service, valves in light liquid service, safety/relief valves in gas

service, and compressors. However, states may choose to implement monthly

monitoring for pumps because the cost effectiveness ;s 1]10re attractive than

the cost effectiveness for quarterly ~onitoring. RACT also includes installation of ·plugs, caps, blind flanges, etc. for open-ended lines. The environmental impacts of RACT are presented for model units in Chapter 4 and the cost

impacts are given for model units in Chapter 5. The costs, emission

reductions, and cost effectiveness of RACT are reasonable.

Alternative programs for monitoring valves are also allowed as RACT

requirements. Under such programs, RACT can be met by meeting a performance

level of 2 percent leaking in a process unit. This provision allows specific

programs to be tailored to individual process units,. provided an annual

performance test demonstrates 2 percent or less leaking. Another alternative

program for valves allows implementation of skip-period monitoring techniques;

these programs are also discussed in Chapter. 3. ·Either of these approaches

has the.potential to reduce monitoring frequency and cost of valve leak

detection and repair in individual process units.

Quarterly leak detection and repair has also been retained as the basis

of RACT for safety/relief valves in gas service (see response to comment later

in this appendix) and for compressors. Since RACT applies to existing

compressors, EPA believes additional provisi~ns should be considered for

compressors. Leak detection and repair may not always be an effective

technique for compressors. For instance, leak detection and repair is not

applJcable if the compressor seal cannot be repaired below the action level

· A-21
(10,000 ppmv) or cannot be repaired on-line (i.e., the seal can only be

repaired during a process unit shutdown). If leak detection and l"E~pair is not

applicable to an existing compressor, equipment should be installed as the

control technique. An example of the equipment to be used is a mechanical

seal system with a non-VaC barrier fluid and degassing reservoir connected to

a control device (e.g., flare). Another example of equipment is a seal area

enclosure that is vented to a control device. In some instance~, neither leak

detection and repair nor equipment are feasible due to prohibitive costs or

safety considerations. Under these circumstances, a waiver from the RACT

requirements could be considered on a case-by-case basis.

Comment: Referring to comments submitted on the NSPS, commenters [#16; #17;

121; #22] stated that emissions and emissions reduction potential were lower

than presented because of the current use of flares. They cited a study of

flares by Siegel to support their contention that flares can achieve 99+

percent destruction of vac.

Response: Flares have not been presented in the CTG as a control device for

destroying voe collected from various sources. The eTG focuses on the

application of leak detection and repair for reducing emissions rather than

equipment. As the commenters state 9 however, flares are effective in

eliminating vae emissions for certain equipment types. For exampll~, vae

emitted through the seat of a safety/relief valve are effectively (~liminated

if the discharge of the safety/relief valve is vented to a control device,

such as a flare. Where flares are used to control vac emissions from

safety/relief valves, there is greater potential for emissions reduction from

the uncontrolled leak rate than can be achieved through leak d~tpction and

repair techniques. Flares are also effective in eliminating vae emissions

from pump seals and compressor seals when used in combination with mechanical

seal/barrier fluid/degassing reservoir systems. Thus, flares are allowed for

control of equipment leaks from pumps, compressors, and safety/rel';ef valves

in ljeu of instrument monitoring.

A-22
Comment: Commenters [#7; #9; #10; #15J not~d that EPA had made allowances for

inaccessible and unsafe-to-monitor valves. However, they asked that further

consideration be given to exempting unsafe-to-monitor and inaccessible valves

completely from periodic monitoring requirements.

Response: EPAls view is that inaccessible and unsafe to monitor valves should

be monitored as often as practicable because of the potential for finding

leaks and reducing emissinns. EPA does not consider annual monitoring or

monitoring at shutdown to be an unreasonable burden for inaccessible and

unsafe to monitor valves. However, as indicated in Section 3.3.1, the

difficulties of monitoring inaccessible and unsafe to monitor valves should be

considered. For example, difficult-to-monitor valves might be exempted from

routine quarterly monitoring provided they are monitored annually. The extent

of the consideration is left to the discretion of the state and local agencies

administering regulations based on leak detection and repair programs.

Comment: Two commenters [#4; #7J expressed concerns with different aspects of.

safety/relief valves. One commenter felt that monitoring of safety/relief

valves was unwarranted since serious injury could result if a safety/relief

valve should relieve while being monitored. The commenter said that such

monitoring presented an undue safety hazard to personnel. Another commenter

discussed the use of block valves upstream of safety/relief valve. Acknowledging their existence in the industry, the commenter stressed that such

valves are typically locked open. Furthermore, in his plant, only authorized

personnel could unlock this kind of block valves and the personnel must remain

with the block valve until it is again locked open.

Response: EPA has examined the monitoring requirements for safety/relief

valves in gas service and does not consider the quarterly monitoring requirements to be burdensome or unwarranted. Safety/relief valves are routinely

inspected as a part of normal safety and maintenance procedures to ensure the

set ~ressure is correct. The quarterly monitoring requirement of RACT may

increase the frequency of this ordinary monitoring practice, but the

A-23
precautions taken during current safety/relief valve inspections are expected

to be used during quarterly monitoring.

The intent of the RACT selected for safety/relief valves is to eliminate

the large amounts of VOC that can be emitted through the valve if 'it does

not seat properly after an overpressure release. Therefore, as part of any

emissions reduction program for safety/relief valves, EPA believes that

monitoring should follow every overpressure relief within 5 days of the

relief. This is to ensure the valve has reseated properly.

EPA also considered the existence of current systems in use in the

industry. For example, many safety/relief valves are already connl:cted to

closed vent systems (e.g., flare headers) for safe disposal of emergency

release gases. Under such a system, there would be no required monitoring.

Some process units do have block valves installed upstream of s.afety/relief

valves, as one commenter described. While this is not recommended practice,

it is an acceptable procedure under engineering standards. An impl~ovement

over this arrangement is the use of a V-valve with parallel relief systems.

This arrangement ensures a safety/relief system is in-service at a'il times and

allows ready repair of one of the safety/relief valves.

Comment: The 15 day interval allowed for delay of repair was said to be too

short, espec~ally in those cases where repair parts had to be ordered [#4;

#9J. One commenter said that 30 to 45 days should be allowed in such cases to

obtain parts. And in commenting on the NSPS, commenters requested a delay in

repair to the next process unit shutdown for repair where parts had to be

ordered. This would provide time to obtain repair materials and to schedule

maintenance work.

Response: Delay of repair for leaking sources can significantly impact

emission reductions achievable under leak detection and repair programs. EPA

expects most on-line/in-place repairs to 'be effected quickly. The requirements of RACT allows a I5-day repair interval to provide time for those

technically feasible repairs to be made; a I5-day interval provides ample time

for such repairs without sacrificing a large amount of emissions reduction.

A-24
For the remaining leaks that are not technically feasible on-line or in-place,

delay of repair is allowed to the next process unit turnaround.

Comment: Several commenters [#6; #10; #14] objected to the statement that

State enforcement officers might request a unit with an excessive numbers of

leaks to shutdown before their scheduled shutdown. They said that shutdowns

could cause more emissions than allowing the leaks to continue and that the

shutdowns could result in excessive energy use.

Response: The intent of requesting a process unit shutdown for repair of an

excessive number of leaks is to promote the use of sophisticated repair

techniques (such as sealant injection) in process units with demonstrated

excessive leaks. Certainly, any decision to request a process unit shutdown

for repair of an excessive number of leaks prior to a scheduled shutdown must

be carefully considered, taking into account the potential costs of an early

shutdown. Similar provisions for early shutdown have previously been

presented in a CTG model rule for petroleum refining fugitive VOC emissions

(EPA-450/2-79-004).16 In lieu of requesting an unscheduled process unit shutdown to repair an excessive number of leaks, State and local agencies may

consider including specific provisions for delay of repair of various equipment types .. Under this approach, a delay of repair beyond the repair interval

(15 days) would only be allowed if repair is technically infeasible without a

process unit shutdown and if spare parts for repair have been depleted (after

being sufficiently stocked). Records of the reasons for delay of repair could

then be used to aid State enforcement officers in determining compliance.

Comment: Several comments [#5; #6; #9; #12; #14; #18] were received asking

for exemptions. Exemptions were requested for small production quantities,

for units with few fugitive emissions sources, and for small diameter lines

and valves.

Resp~nse: State and local control agencies may wish to include exemptions

for plants or process units. Exemptions would most likely be designed to

A-25
prevent high cost effectiveness ratios for vac control. As discussl:d in

Chapter 3, such exemptions might be based on quantities of light liquid and

gaseous vac processed. An exemption based on the number of equipment components in a process unit is another possibility, but it is more appropriately

addressed in terms of quantity of light liquid and gaseous vac proc(~ssed.

Other suggested exemptions are for equipment in vacuum service and for process

units processing only heavy liquids or non-VaC. EPA has no documentation of

fugitive emission rates varying with line size. Thus, there is no justification for an exemption from monitoring requirements based on line size.

Comment: The recordkeeping and reporting requirements of the draft eTG were

said to be excessive [#3; #9; #16]. Further, the time estimated to handle

these tasks was found to be insufficient. ane commenter felt that tagging and

logging all leaks was unjustified and cost-ineffective~ esp~cially where

on-the-spot repairs are successful. Another commenter, however, stated that

the draft eTG did not provide any discussion of the reporting and rlecordkeeping requirements.

Response: EPA sees no way of implementing and administering leak detection

and repair programs without some recordkeeping. The level of reporting and

recordkeeping the state and local air pollution agencies will require has not

been discussed in the CTG. However, an a11 owance was' made for recordkeepi ng

and reporting in the cost analysis.

Tagging and logging equipment that cannot be repaired on-'Iine/in-place is

an effective means of handling those components that must await a process unit

shutdown for repair. Such recordkeepingis a necessary tool in establishing

alternative leak detection and repail~ programs, such as a percent leaking

requirement or a skip-period monitoring plan. Furthermore, this type of

recordkeeping would be beneficial to State enforcement officers considering a

request of unscheduled process unit shutdown for repair of an excessive number

of leaks. For these reasons, records should be maintained of all leaks. In

the ~ase of effective on-the-spot repair, tagging is not considered productive

for the quarterly leak detection and repair programs selected as RAeT; for the

reasons cited above, however, maintaining records is necessary.

A-26
A.4 REFERENCES

1. Memorandum from Stelling, J. H. E., Radian Corporation, to SOCMI

Fugitive NSPS file. November 1, 1982. 11 p. Estimates of VOC

emissions from SOCMI.

2. U. S. Environmental Protection Agency. fugitive Emission Sources of

Organic Compounds -- Additional Informa't;ion on Emissions, Emission

Reductions, and Costs. Research Triangle Park, N.C. Publication No.

EPA-450/3-82-010. April 1982.

3. Wetherold, R. G., l. P. Provost, and C.D. Smith. (Radian

Corporation.) Assessment of Atmospheric Emissions from Petroleum

Refining, Appendix B: Detailed Results. (Prepared for U. S. Environmental Protection Agency.) Research Triangle Park, N.C., Publication

No. EPA-600/2-80-075c. April 1980.

4. Blacksmith, J. R., et ale (Radian Corporation.) Problem Oriented

Report: Frequency of Leak Occurrence for Fittings in Synthetic Organic

Chemical Plant Process Units. (Prepared for U. S. Environmental

Protection Agency.) Research Triangle Park, N.C. Publication No.

EPA-600/2-81-003. September 1980.

5. Langley, G. J. and R. G. Wetherold. (Radian Corporation.) Evaluation

of Maintenance for Fugitive VOC Emissions Control. (Prepared for

U. S. Environmental Protection Agency.) Research Triangle Park, N.C.

Publication No. EPA-600/52-81-080. September 1980.

6. DuBose, D. A. and G. E. Harris. (Radian Corporation.) Response Factors of VOC Analyzers to a Meter Reading of 10,000 ppmv for Selected

Organic, Chemicals. (Prepared for U. S. Environmental Protection

Agency.) Research Triangle Park, N.C. Publication No.

EPA-600/2-81-051. March 1981.

7. Reference 6.

8. Reference 6.

9. DuBose, D. A., G. E. Brown and G. E. Harris. (Radian Corporation.)

Response of Portable VOC Analyzers to Chemical Mixtures. (Prepared for

U. S. Environmental Protection Agency.) Research Triangle Park, N.C.

Publication No. EPA-600/2-81-110. June 1981.

10. Langley, G. J., et ale (Radian Corporation.) Analysis of SOCMI VOC

Fugitive Emissions Data. (Prepared for U. S. Environmental Protection

Agency.) Research Triangle Park, N.C. Publication No.

EPA-600/2-81-111. June 1981.

11. Reference 5.
12. Williamson, H. J., et al. (Radian Corporation.) Model for Evaluating the Effects of Leak Detection and Repair Programs on Fugitive Emissions. Technical Note DCN 81-290-403-06-05-03. September 1981.

13. Harvey, C. M. and A. C. Nelson. (PEDCo Environmental, Inc.) VOC

Emission Data - High Density Polyethylene Process Unit. (Prepared for

U. S. Environmental Protection Agency.) Research Triangle Park, N.C.

Publication No. EPA-600/2-81-109. June 1981.

14. Letter and attachments from Johnson, J. M., Exxon Company, to

Walsh, R. T., EPA:CPB. July 28, 1977. 14 p. Review of "Control of

Hydrocarbon from Miscell aneous Refinery Sources" draft report.

15. Memorandum from Stelling, John, Radian Corporation, to SOCMI Fugitives NSPS File. November 1, 1982. 4 p. Cost effectiveness of leak

detection and repair programs using different-leak definitions.

16. Capone, S. V. and M. Petroccia. (GCA Corporation.) Guidance to State

and Local Agencies in Preparing Regulations to Control Volatile Organic Compounds from Ten Stationary Source Categories. (Prepared for . U. S. Environmental Protection Agency.) Research Triangle Park, N.C.

Publication No. EPA-450/2-79-004. September 1979.

1.-2[;
APPENDIX B

COMMENT LETTERS RECEIVED ON DRAFT

CONTROL TECHNIQUES GUIDELINE DOCUMENT

APPENDIX 8

This appendix contains letters received commenting on the draft control

techniques guidelines document for fugitive emissions from synthetic organic

chemical, polymer, and resin manufacturing plants. Twenty-two letters were

received from industry representatives and trade groups. Table 8-1 contains

a listing of the commenters and their affiliations.

B-1
2

TABLE B-1. LIST OF COMMENTERS AND AFFILIATIONS

Comment No. Commenter and Affiliation

1* Mr. W. M. Reiter, Corporate Director

Corporate Environmental Affairs·

Allied Corporation P.O. Box 2332R

Morristown, New Jersey 07960

*EPA response attached.

Mr. Henry L. Ramm

Environmental Engineer Government and Regul atory Affa i lOS Dept.

Rohm and Haas Company Independence Mall West

Philadelphia, Pennsylvania 19105

3

4

5

6

7

Mr. D. E. Park, Director

Environmental Affairs

Ethyl Corporation

P.O. Box 341

Baton Rouge, Louisiana 70821

Mr. J. J. Moon, Manager Environmental and Consumer Protection

Division

Phillips Petroleum Company Bartlesville, Oklahoma 7400~

Mr. John T. Barr

Air Products &Chemicals, Inc.

Box 538

Allentown, Pennsylvania 18105

Mr. J. C. Edwards, Manager Clean Environment Program

Tennessee Eastman Company

Eastman Kodak

Kingsport, Tennessee 37662

Mr. Allen R. Ellett, Environmental

Specialist

Environmental Affairs and Product Safety

The Standard Oil Company

Midland Building Cleveland, Ohio 44115

B-2
Comment No. Commenter and Affiliation

TABLE B-1. LIST OF COMMENTERS AND AFFILIATIONS (Continued)'

8 Mr. James W. Lewis, Manager

Special Environmental Projects

The BF Goodrich Company

Chemical Group

6100 Oak Tree Boulevard

Cleveland, Ohio 44131

9 Mr. A. H. Nickolaus

Texas Chemical Council

1000 Brazos, Suite 200

Austin, Texas 78701

B-3

Mr. F. M. Parker, Environmental Coordinator

Chevron U.S.A., Inc.

575 Market Street

San Francisco, California 94105

Mr. R. B. Tabakin, Manager

Environmental Affairs

American Cyanamid Company

One Cyanamid Plaza

Wayne, New Jersey 07470

Mr. E. J. Burkett, Manager Corporate Environmental Engineering The Goodyear Tire &Rubber Company Akron, Ohio 44316

Mr. W. F. Blank, Manager Pollution Control

Corporate Environmental Affairs

Allied Chemical

P.o. Box 2332R

Morristown, New Jersey 07960

Mr. H. R. Norsworthy, Manager-Manufacturing

Synpol, Inc.

P.O. Box 667

Port Neeches, Texas 77651

Mr. Thomas V. Malorzo

Senior Regulations Analyst Diamond Shamrock Corporation 717 North Harwood Street

Dallas, Texas 75201

10

12

11

13

14

15
TABLE B-1. LIST OF COMMENTERS AND AFFILIATIONS (Contin~ed)

Comment No. Commenter and Affil iation

16

17

18

19

20

21

22

Mr. A. H. King, P.E.

Environmental Consultant

The Firestone Tire &Rubber Company 1200 Firestone Parkway Akron, Ohio 44317

Mr. R. W. Fourie, Manager Environmental Programs, Shell Oil Company One Shell Plaza

P.O. Box 4320

Houston, Texas 77210

Mr. William P. Gulledge

Manager, Environmental/Scientific Programs Chemical Manufacturers Association

2501 MStreet, N.W.

Washington, D.C. 20037

Mr. Steven A. Tasher

Legal Department E.I. du Pont de Nemours &Company, Inc.

Wilmington, Delaware 19898

Mr. C. D. Malloch

Regulatory Management Director

Monsanto Company 800 N. Lindbergh Boulevard

St. Louis, Missouri 63166

Mr. Bonner L. laFleur, Chairman

Environmental Impact Committee, Southern

Rubber Group P.O. Drawer 1361

Lake Charles, louisiana 70602

Mr. M. J. Rhoad

Managing Director

International Institute pf Synthetic Rubber Producers, Inc.

2077 South Gessner Road

Houston, Texas 77063

8-4
B-5

I have just initiated review of the draft CTG entitled, "Control

of Volatile Organic Compound Fugitive Emissions from Synthetic Organic

Chemical, Polymer, and Resin Manufacturing Equipment."

Further, the document does not use available SOCMI and Polymer plant data contributed by your contracts and industry sources (e.g.

Allied Corp6ratton). The failure to use available control techniques

data is contrary to§108 of the Clean Air Act. I quote from §108(b)(1)

." '\ 'j ,Pi - "'"

December 23, 1981

Allied Corporation

Corporate Environmental Affairs

P.o.' Box 2332R

Morristown, New Jersey 07960

( ( '-

lISimultaneously with the issuance of criteria under

subsection (a), the Administrator shall, after consultation with appropriate advisory committees and

Federal departments' and agencies, issue to the

States and appropriate air pollution control

agencies infonnation on air pollution control techniques, which information shall include data

relating to the cost of installation and operation,

energy requirements, emission reduction benefits,

and environmental impact of the emission control

technology. Such information shall include such

data as are available on avai.1able technology and

alternative methods of prevention and control of

air pollution. Such information shall also

include data on alternative fuels, rocesses, and

operating methods which wi 1 result in elimination

of significant reduction of emissionsll•

(Emphasize added)

I am somewhat disturbed, as it appears that the contributions that

were made by NAPCTAC committee members and in some cases your comments

apparently have been completely disregarded in the preparation of this

document. I recognize that the CTG is labelled draft, however, our

comments were provided many months ago. Further, the release of such

a flawed document to the States and EPA Regions constructs a foundation for improper and technically unsound control assessments. I

recognize that this is not a "final" document, however, the label

"draftll may be lost in the pressure of pennitting.

Mr. Don R. Goodwin, Director

Emission St~ndards and Engineering Division (MD-13)

Office of Air Quality Planning and Standards

u. S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Dear Don: .

~!.UED
Don Goodwin, EPA 2

My specific concerns are as follows:

1) The document does not reflect the constructive comments made by

NAPCTAC members.

2) The document does not reflect the advances made by EPA in their

study of fugitive emission problems. ~a collected:by Radian

Corporati on of nume rous SOCMI pl ants has been ent i rtiL.!!egl ected. _ The contribution made by Allied Corporation and other - industr1al firms directly to EPA and via trade organizations

has not been included.

3) Our concern relative to the handling of safety valv~s has be~n disregarded. This document again supports the

installation of a block valve before the safety valve~ a. step

which could eliminate insurance coverage for the facility and

more significantly, jeapordize the lives of many workers.

4) The document can be misinterpreted by the local regulator to the

point where he might include flanges, agitator seals, and

emissions from secondary sources such as cooling towers for control.

This circumstance could arise since there is no clear and emphasized

exclusion within the document. Rather there is a rev;E~ of

the losses from such sources with a simple,caveat (difficult

to find) indicating that these areas may not be covered by

the CTG recommendation.

I feel that the document does not reflect a professional

evaluation of the fugitive emission problem associated with polymer and organic chemical plants. Rather it is an attempt to extrapolate

from refinery data. I strongly recommend that you consider--

withdrawing the aocument; or at least clearly indicating to StatE~ and

Federal regulators who have received the document that the dotument in

its present state is not to be used in formulating RAeT.

I will provide chapter by chapter comment as rapidly as poss'ible.

I am taki ng the 1i berty to share these comments with other NAPCTAC

members and sol licit their comments.

Have a Merry Christmas and a Happy New Year.

Ve ry truly you rs,

8e0~)

W. M. Reiter

Corporate Director

Pollution Control

/pab

CC: R. O. Blosser Dr. J. M. Lents

R. J. Castell i R. A. Moon, Jr.

F. Dubro\'/ski W. Reilly

l:'

.. . H. Haskell B• A. Steiner ...

I:. • E. Lemke B-6

.i
'::;;lV

OFFICIAL FILE CO

CY

B-7

,..

D 1982

.._ CONCURRENCES

Second, the draft CTG docur.1ent includes fuaitive emission data from

the synthetic organic cherni ca1 manufacturi ng industry (soon) to the extent

these data had been received, cor.lOlled, and assessed in i-lay 1931, when the

draft docu;:;ent was forwarded to the Office of r·1anaaenent and Budaet for

rev; eVJ under Executi ve Order 12291. SDecifi ca11.'1, -you yJi 11 note' that Tables

A-13, A-14, and A-15 in Aooendix A su~arize SOCiiI fuoitive e~ission data

gathered in etiwlene plants, cumene plants, and vinylWacetate plants. Preli:.;inary assessment of these data sunported extrapolation from the petroleum refin;ns industry to the socrn concernin~ fugitive enissions from process equipment•

Dear Bi 11 :

JAN

UNITED ST" -es ENVIRONMENTAL PROTECTION AG

~tr. W. M. Reiter

Coroorate Director. Pollution Control

CorPorate Environmental Affairs

Allied Corporation

Post Office Box 2332R

I,':err;stown, New Jersey 07960

In response to your letter of December 23, 1931, outlining several

concerns\'fith the draft control techniques guideline (CTG) document

entitled "Control of Volatile Organic Conpound Fugitive Emissions from

Synthetic Organic Chcr.1ical, Polymer, and Resin tlanufacturing Equipment,"

! would like to draw your attention to the following points. First, the

draft CrG document does reflect constructive co~nts made by NP~CTAC menbers.

For exan;;le, the preliminary draft CTG document discussed at the r'~rch 1931

r:hPCTAC Meeting included a model regulation. The NAPCTAC recommended that

model reaulations not be included in CTG documents; and, you will note, a

~odel regulation is not included in the draft CTG document you received.

t.1 so, a nUr:Jber of the NAPCTAC meobers recomended that the CTG document

accor.1lTIOdate a1ternat;ve aoproaches to quarterly i nspect;ons for locating . equipme~t leaks and exemptions for s~al1 orocess plants. Again, you will

note that the draft CTG docu~ent yo~ received acco~dates skip-Deriod monitorino an.:! "an allo~'!able oercentaae of valves leakina" as alternatives

to quarte~lyinspections. In' addition, the docur.1ent accor.r.iodates exer.tptions for s~all process plants with less than a hundred valves in gas and/or

lignt liquid service.

(

,

::::~, ~'gJ:i::,,',:",', :':,''"','::1'" :::::',:",::::.:: :.:::......:...'...... ::::::'.::::.:....::.:::.::::::.,,:::::..::::.,:•..:::

:JATE)-i ./'-:,}:.!! I ,'. , I ,- __ I . . I
2

Since r-~y 1931, additional SOCiU fugitive emission data have beem received

and comoiled. While \'1e have not completed an assessment of these data, it does

appear that some adjustment of various emission factors included in the

draft CTG document may be warranted to reflect differences beb/een the

petroleum refining industry and the SOC~lI. Currently, we plan to complete

our assesswent of these data over the next month or two and then pub1ish a

Federal Reaister notice in the spring summarizing our technical conc'lusions

regarding fugitive emissions in the SOCMI. These conclusions will, of course,

be incorporated in the final CTG document we develop.

Third, your concern relative to the handling of safety valves hi~S not been

disregarded. As I mentioned in my letter of ~~y 12, 1981, we find a nu~ber of

cO:':lpanies, such as Exxon and Union Oil, who routinely fol10\'/ the :practice

outlined in the draft CTG docur.1ent and we find that the ASf·1E Boiler ,and Pressure

Vessel Code pe~its this practice. In addition, I should like to point out

that rather than use a block valve, one could use a three-\'lay val,ve vented

to a second safety relief valve. In this nanner, the process would :alv/ays

have access to a safety relief valve.

Fourth~ we do not think State or local air pollution control agencies could misinterpret the draft CTG document and include flanges, agitator seals,

and cooling tONers in a leak detection program. You will note, for exa~Dle, that these items are not included in the recomnendation for

reasonably available control technolo~y s~3rized on page 4-1 of the

draft CTG document "thich states: IILeak detection should consist of

quarterly monitoring the follO'.'!ing components in voe service with a vac

detection instrument: pumps in light liquid service, valves in light

iiquid service, valves ;~ ~as service, co~pressors, and safety/relief

valves in gas service. 1I

r have tried to indicate that we have accommodated the su9gestions

made tJy cOr;r:1ittee menDers and industry representatives. He nay have

rissec SO:1e and \';e I,.;i 11 r~vi Ct-, your chaDte:r- by-chapter COl!1Ments ca refully w~en they are received.

He arpreciate your in-de:Jth review of our 'technical documents very

ouch. \-!e de our best to provide solid technical work and comments by

these exnerienced in the design' and operation of chemical plants are

essential to this effort.

aest w;sjies for the rtew Year.

Sincerely yours,

bcc: R. O. Blosser

R. J. Castelli

F. Dubrowski

E. H. Haskell

E. E. Lemke

J. ft Lents

R. A. r~oon, Jr.

H. Rei lly

B. A. Steiner

Don R. GOOdHi n

Director

Er.ission Stand~rds and Engin~erin9 Jivisicn

-

8-8
ROHM

~HRRS COMI='ANY

January 8, 1982

Mr. F. Porter

U. S. Environmental Protection Agency

Office of Air Quality and Planning & Standards

Research Triangle Park, NC 27711

Dear Mr. Porter:

The Rohm and Haas Company is a member of the Chemical ~1anufacturers Association, and we support the CMA critique of

draft documents issued for the control of volatile organic

compound fugitive emission from synthetic organic chemical,

polym-er, .and resin manufacturing equipment. As an adjunct to

their review, the following comments are offered.

1. Model Re~ulations in Control Techniques Guidelines (CTG)

Formerly CTGl s containing model regulations tended to be more of

a regulatory'rule than a guidance document because a state

agency, not having the expertise or technical manpower available

to your office, would in many cases' adop~ the model regulatiqn as

listed, even if it was not justified. By not including a model

regulation in the August.1981 draft CTG you are bringing the

document towards its intended purpose of a guidance document.

The state and local agencies have the responsibility for first

line control and should be encouraged to decide what level of

control is necessary. We support the deletion of the model

regulations section.

2. Aooendix B, Tables I and II

Ke agiee with the .Iisting of specific chemicals in Appendix B,

Table I as this explicit listng makes clear exactly what ~~ocesses are referred to. How~ver, as worded, some categories

are not specific. The terms !!acryli~ acid and esters,!!

!! e t han 0 I am i ne s ,11 Phen 0 IsuI f 0 n i c a c ids ,II II pol y but e :1 e s , II

Iltetra:chloroethanes,1I IItoluenesulfonic acids,1I Iltoluidines,1I

'1trichlorobenzenes ll could be construed as covering broad classes

of compounds. It is requested that each compound to be covered

by these rules be listed separately, i.e., lI a crylic acid, ethyl acrylate, butyl acrylate, ethanolamine, diethanolarnine,1I etc.

The more general terms should be deleted.

8-9
.. 3. Data Base for CTG Draft

The data for fugitive emissions from synthetic organic chemical

plants are significantly different, and in many cases lower, than

the oetroleum refiners fugitive emission data base. The draft

CTG sh 0 u I d be rev i sed using' the S0C\1 I da taba s e sot hat the

document is accurate and does mislead the users to develop

unneeded and unproductive emission control regualtions.

H.

&~~ L. Rarrm

Environmental Engineer

Government and Regulatory Affairs Dept.

cm

010121

B-10
---~-----------------------

ETHYL CORPORATION

January 11, 1982

~I-CASC ...CC.. C5S RCPI-Y

, TO:". O. aox 3""

S"'TON ROUG£:, LA.?Ol!l21

Mr. F. L. Porter

Emission Standards and Engineering Division .(MD-13)

Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Dear Mr. Porter;

Re: Control Techniques Guideline: Volatile Organic Compound

Fugitive Emissions from Synthetic Organic Chemical,

Polymer, and Re sin Manufacturing Equipment '

The following is in response to the request for comments on the

dra"ft document (46 FR 59630).

Ethyl Corporation considers the proposed guidelines overly

restrictive and, excessive in record keeping, reporting and monitoring

requirements. The control strategies suggested are extremely difficult

to implement and enforce.

Ethyl's corporate environmental staff have carefully reviewed the

revised draft of these gUidelines and do not 'find 'many significant changes

from the previous document. M.any of the technical weaknesses of the

p:-evious draft have not been corrected.

Fugitive emissions from the Synthetic Organic Chemica Is

Manufacturing Industry are not of large anough magnitude to warrant such

extensive documentation and control. The se· emlssions are by nature

de minimis. The guide line s propose over-regulation of the se emis sions.

Regulc~ions to ~educs such emissions I if necess2.r:" I s::'culd

e sTe.::L s~ clear-::u! obj ective s and specify reduction requiremems. The

mec:::~s :0 achieve t:-1C reduction should be an industry decision.

, The cost estimate in the guide line sis not valid. It is based on

a 10 percent interest rate, which is unrealistic in the present market.

The labor cost ba sed on "wage s plus 40 percent" for overhead is also low.

T:-,e overhead often is 1001, of wages. The total basis for valve cost is a

one-inch globe valve. Many different types and sizes of \{alves are used·

B-11
i,':..r. r • L. l"orter

jam.:.ery 1'1 t 1982

rags 2

in SOCMI. The cost of a valve does not increase linearly a s the size I

but sxponentia 11y. Also I the majority of valve s in service are larger

i:han one inch.

We support the use of the bubble concept for emission control

strategies. This concept could encompass these de minimis fugitive emissions

without the excessive control ,proposed in the gUidelines.

In considering these comments we urge EPA to modify the

guidelines. As proposed I the burden of compliance on industry and enforcement is unduly excessive.

Very truly yours I

ETHU CORPORATION

41£41

D. E. Park I Corporate Director

Environmental Affairs

DEP:jht

8-12 .
PHILLIPS PETROLEUM COMPANY

8-13

BARTLESVILLE. OKLAHOMA 74004

918661·5S56

• January 15, 1982

Coroorate Engineering

JOHN J MOON

Manager. Etwlronment.and Consumer Protection

Section 3.1.2.3 - Most safety/relief valves in chemical plants

relieve into a vapor recoverj system or into a flare system. These

valves should be excluded from the monitoring requirement for volatile

e!:lissions.

If a block valve is installed up stream of a relief valve the

block valve ha~ to be locked open. Only an authorized person can unlock

the ~lcck valve and he has to scay with the block valve uncil it is

aga~n locked open.

8 Section 3.1.3.5 - The reduction efficiency expression A x B x C x

D is misleading. The reference number 8 should be placed after the preceeding sentence chat describes the expression.

Section 2.1 - To state that the equipment in process units in

the synchetic organic chemical manufacturing industry (SOCMI) is similar

to, equipment in the polymer and resin manufacturing ind~try is only

partly true. The polymer and resin plants are basically quite different

from the SOC~I. A SOCMI facility handles gas and/or li~~t liquid through

most of the facility while in a polymer or re~in facility only a small •

part of the facility handles gas and/or light liquids.

Section 3.1.3.3 - The allowable interval before repair of 15 days

does not allow maintenance enough time if parts have to be ordered. I~

is suggested that 30 to 45 days would be more appropriate in these cases.

~~. Fred L. Porter (2)

Emission Standard & Engineering Division (MD-13)

Environmental Protection Agency

Research Triangle Park, NC 27711

Dear 1:-!+. Porter:

Phillips appreciates the opportunity to comment on the draft of

"Control of Volatile Organic Chemical, Polymer, and Resin Manufacturing

Equipment" dated August, 1981 transmitted by your letter of December 1,

1981. After reviewing the draft our comments are as follows:
••_. __ c:.t...6 ••'wi .. t..c:.

?ag~ 2 ¥

J~~car}· 15) 1982

Sac~ion 3.2.2 - The 2% allowable number of valves leaking appears

:0 be ~.realis:ic. Table 3-2 esti~ates 10% of valves in gas service ~~d

21;~ of valves in light liqUid service leak. Table 4-16 "Summar! of Valve

~a~n~enance Test Results" shows t~at only 56.4% of total valves were repa~~ed successfully. These data would seem to indicate that 5 to 6%

wocld be a more appropriate performance level.

Section 5.1 - The capital cost of implementing Reasonable Available Control Technology (RACT) did not include the cost of an initial

survey and inspection of plant components. This survey and inspection

ot a 1~rge facility can be a mammoth job and very costly.

Section 5.3.2 - The amount of recovery credit for VOC saved for

unit C (~211,100) does not agree with the amount stated in Table 5-7

($22..6,730) •

If you have questions on any of the above) please contact A. C.

Oliver a~ (918) 661-5735.

Very truly yours,

lf711~

j;n.'!/ACO/ pkc

8-14
Air Products and Chemicals" Inc.

Box 538, Allentown, PA ,e'05 (2'5)4S'·~9' 1

11 January 1982

Mr; Fred l. Porter

Emission Standards and Engineering Div. (MD-13)

EPA

Research Triangle Park, NC 27711 ,

Dear Mr. Porter:

We 'have reviewed the August 1981 draft 'guideline for Control of Volatile

Organic Compound Fugitive Emissions for Synthetic Organic Chemical, Polymer,

and Resin Manufacturing Equipment, and offer you our comments and suggestions

on this draft.

This draft ,is a useful attempt to provide guidance to regulatory bodies which

are establishing rules on fugitive emissions. It assumes that these regulations

will be prepared, but it 'does not furnish guidance as to which type of emissions

deserve priority treatment; it assumes that all emissions are equally undesirable. This is not correct. The Agency has on several occasions pUblished

documents illustrating the difference in the photodegradation rates and ozone

yie19s of various organic substances. Therefore, it would be helpful to the

agencies considering the need for regulations and the priority to be assigned

to various substances'.to devote a section to this issue. You may remember our

discussion On this point at the RTP hearing in March of last year. See Dqcket

A-79-32.

The primary weakness of this draft is the total dependence on the similarity

between the refining and the chemical industries for the data base. See pages

2-18- 20. In the above-referenced docket,we have submitted comments on the

di spari ty of the two ; ndustri es. II} bri ef, chemi ca1 plants are sma11 er, . operate at lower temperatures and pressures, and process more valuable stream~.

Certainly, the size of a valve or pump has a direct effect on the rate of

leakage to be expected; and thus on its effect on the environment. We realize

the prcblems involved in obtaining representative data for such a variety of O~0ce5se5, but believe that the Agency should not rely totally on data from

the refi nery ; ndustry. You ha\!e data on many cherni ca1 operati ens (see the

EPA;450/3-S0-028 series, for example) and should attempt to apply as accurate

cata as possible, rather than rely on surrogates.

Along this line, we would suggest that the alternative control strategies

discussed in Chapter 3 provide for an exemption from regulation based on size

as well as on the number of valves and pumps. The value of a substance usually

increases as the equi pment size decreases. Thus, the operator has a strong

economic incentive not to lose the material. A cost-effectiveness analysis

would suggest that regulating efforts be concentrated on the larger potential

emitters (page 3-21).

8-15
-2-

:~ :5 for these reasons that we believe that the calculations in Appendix D

are o~erly optimistic and that the projected reductions in emissions will not ~e ~c,ieved on an average basis. The leak rates simply are not representative of ~he entire chemical industry, but of the refinery industry.

We support the concept of the skip-test procedure. We would suggest that the

users of this guide need further assistance in selecting the values for the

monitor-skip periods, however, there should be some discussion of how these

periods are to be chosen, and some illustrations of the effects of choosing other arbitrary values of i and m.

In regard to the 2% fi gure as an index of comp1i ance (page :3-17), ; t can be

seen from table 3-2 that this value depends heavily on the ,service 'in which

the equipment operates. Some fl exi bi 1i ty shaul d be a11 owed for this factor.

Similarly, it would help the regulator to have some further illustrations of

the quantitative effect of alternate repair times (page 3-8).

Another place where more guidance would be useful is in selecting the leak

rate where a forced turnaround would be required. An inexperienced reader

would conclude that a rate above 2% would justify this action. More data on

average and excessive leak rates would be helpful here.

There are several other underlying factors which bear heavily on the effec-:

ti'veness of this control strategy. One is the arbitrary volatility split,

which may have some significance in the refinery industry, but is not relevant

to the chemical industry. Another;,5 the relative response·to the various

substan,ces by the detection instrument. This wide range of s!:nsitivities,

coupled with the difference in photochemical·.reaction rates, produces an"

enormous difference in the actual emissions, and "their impact on the environme:nt, from various' ·substances. It is not clear that a casual reader of this g~ide will be aware of these facts.

We hc~e that these comments will be useful to you as you revise this draft.

The fact that the Agency apparent'ly is choosing not to utilizE! conventional

reguia-:'ory procedures in establishing these regulations makes it important tna~ the guidelines be as accurate, effective, and flexible as possible.

?==:~ :211 us directly if you have any questions regarding these comments and

Very truly yours,

AIR PRODUCTS AND CH~CA7LSI INC.

a. ,.v--I- / -Z/~"IV/1'

Jo /~T ,Barr Re~ tory Response

.'

8-16
Attention Mr. Fred Porter

8-17

January 15, 1982

certain other parts ~n the draft (August, 1981) eTC that

For example:

How~ver, there are

could be improved.

1. The rir.:ift eIG uses the refining i;1dustry data to. esti:18te Syntht:tic

Org.:1'1 ic Ch~rni_ca1 Hanufacturir:g Indus t ry (soon) tlncontro lled fug it i ve

I?:rtissions, control costs) and til.e proposL':d (~jTlission reducticiiS. "l:,e CTG

aSS'.l::1es fu/.;itive emissions in the refining industry represent fugitive

E.L.;:;7:,~;"'N KODAK COr.~PANY • KI~:GS?OiH. TEI;;~ESSEE 37c52 • 6i5 2':6"2111

Ec"1~tr!7~.'l r'-· --,·_:·~Js D. ,·is:on

'3. Ait,::r;1c:te .",:mitoring requ'irel;:(~uts fur ucs.:1£e and d,i£ficult to reach

componen~s.

2. The opportunity to apply alternative control strategies.

4. The eXE::T.pt ion of process units with less than 100 valves in gas service

and' light liquid s~rv~ce freon re3ulations rp.quiring contl.""ol of fllgiti"Je

'lOC .::missions.

Reference: Draf:: (August) 1981) Con,trol Techniques Guidel ine Document for

the Control of Volatile O'rganic Compound Fugitive Emissions from

Synthetic Organic Chemical, Polymer, and Resin Manufacturing

Equipment

1. The exclusion of Chapter Six which contained a model regulation. The

eTG is as its title implies, a guideline and not a regulation.

Therefore, it .is more appropriate to have state specific regulations.

We comnend EPA for making several adjustments in the draft eTG in response

to previous public comments. Adjustments which we support are:

Eastman Kodak Comany is a manufacturet of photographic products, chemicals,

fibers and plastics with major manufacturing facilities in seven states. As

a multistate employer of approximately 100,000 people, we s~pport the

objectives of the Clean Air Act and EPA's efforts to achieve the goals of

this Act. The proposed Control Techniques Guideline (CTG) could have a

significant impact on our operations since Eastman Kodak Company produces

many of the chemicals, polymers, and resins listed in Appendix B of the CTG.

TI1ererore, we have the following comments on the draft Control Techniques

Guideline document.

Emission Standards and Engineering

Division (}ID-13)

Environmental Protection Agency

Research Triangle Park, North Carolina 27711
Emission Standards and Engineering

Division (MD-13)

Page 2

January 15, 1982

emissions in SeCNI. However, in EPA contracted studie.s data have bee~

obtained showing seCMI uncontrolled fugitive emissions are much less

than the refining industry uncontrolled fugit ive emissions. For

example, EPA's Report 600/2-81-111 entitled Analysis of SeCMI vec

Emissions Data v.'hich studies data from 24.process units in the SOCIH,

reveals seCMI fugitive emissions are substantially less than refinery

fugitive emissions. The CTG should be revised to reflect the SOCM! da

now available.

2. The draft CTG suggests that components which have a measurable vec

concentrat ion of 10,000 ppmv or greater should be cons idered leaking

components and repaired. However, the Chemical Man~facturers

Association (CMA) in its comments presented on August 7, 1981, sho';oled

that the control efficiency for a 100,000 ppmv screening value for

valves in gas service was more cost effect ive and· had a control

efficiency near the 10,000 ppmv screening value.

3. The draft eTG suggests a quarterly monitoring schedule. CK~'S August

1981, comments showed that annual monitoring instead of quarterly

monitoring only lowered the cont~ol efficiency by two percent for valv

in gas service. CMA also showed that annual monitoring with a

100,000 ppmv screening value for valves in gas service could be

implemented at a more reasonable cost to industry.

Also, a report on an EPA 10-month study of fugitive emiss~ons at an

Allied Corporation high-density polyethylene unit in Baton Rouge,

Louisiana, ina~cates that a repetitive monitoring program on a quarter

or monthly basis would be far less cost effective and could exceed

$20,000/Mg vec. It was concluded that a repetitive monthly or quarter

program provides no additional benefit and is not cost effective"

4. The \~raft eTG on Page 3-21 suggt;sts a state ,,,-gency:;light ,,,ish to

consider a pt-ovision in their RACT regulations which ,,'auld allow the

..... ~.:-Il..:y <jL:r:.:toL" to order .::.n e::rly 1~,1it s:'utdO'.-m. ,.';'1,,0 011 ?"og~ ,4.-2 the

draft eTG states, "There would be no adverse air pollution irnpacts

associated with MCT. II However, early shutdowns could cause increased

emiss ions during the shuteiown processaver \oJhat ""ould occur if the

proc.::ss '.Here to continue to oper;:>te. Therefore, the dr,aft eTG should

address the economic and environmental effects of early shutdowns.

5. The control cost analysis in the draft eTG us~d nonitoring ~irne

estimates made in 1977. Appendix A on Page A-7 of the draft CTG gives

an average monitoring time of 3.4 person-Dinutes per scucce for a

scr~eni:1g pt",:.gr;:m at 24 SOCHI process units. This .:l'Jec;.{ge ;,..)nitoring

time for the cc~?onents monitored in the SOC~I study ~as ]o"ger th~n ~.

~onitoring time esti~ated in 1977. Therefore, [he cost analysis in th

draft eTG is m~dcrc:st ir::ating l:Jonitoring l.::bor cost.. 11,e cost ·an.:J.~ysis

should use the value of 3.4 person-minutes.

8-18
, ,

F.~ission Standards and Engineering

Jivision (MD-13)

Page 3 ,

Ja'Z'lUary 15, 1982

In su~mary, we suggest the following changes ~n the CTG:

1. An analysis of seCMI fugitive emissions should' be made rather than

relying on refining industry data. Then a decision of 'whether a CTG is

needed for SeCMI could be appropri~tely made. If a CTG is needed, a

cost effectiveness estima'te should be based on SOeMI data.

2. If a CTG is justifiable, the monitoring of valves in gas service should

be performed on an annual bas is with a screening value of 100 ,000 ppmv.

3. The draft CTG should address the economic and environmental effects of

early shutdowns.

4. The cost analysis should utilize a monitoring time of 3.4 person-minutes

per source.

Very truly yours,

F~~ J. C. Edwards

~'~3nager, Clean Environment Program

T~nnessee Eastman Company

Division of Eastman Kodak Company

af

- 8-19
THE STANDARD OIL COMPANY

MIDLAND BLlILDING. CLEVELAND, OHIO 44115

R e !=;'~?ELl

Oii\:::-Olt

ENVIRONM!:N'7':'l ;"FF..:.litS

":'Nj

PRO::JUCT S.:.'ETY

Mr. Fred L. Porter

Environmental Protection Agency

Emissions Standards and Engineering

• Division (MD-13)

Research Triangle Park, NC 27711

January 15, 1982

Subject: Draft CTG - Control of Volatile Organic Compound Fugitive Emissions

from Synthetic Organic Chermical, Polymer, and Resin Manufacturing

Equipment.

Dear Mr. Porter:

The Standard Oil Company of Ohio (Sohio) has reviewed the above cited

,document, and would like to submit the following comments on it.

Basis for Regulation

The guideline appears to be developed based on emission data and rates

determined from the Radian survey of 13 petroleum refineries. On, page 2-20,

lt says that the operation of SOCMI process equipment is not expected to

differ greatly from refinery operatiOl1.S, so emissions would be e:x:pected to· be

simlar. We feel that this ,is not the case. The data summarized in Appendix

A shows that in most cases the percentage of leaking sources in chemical

plants is much less than the percentage of leaking sources in a petroleum

refinery. (See table A-I, page A-l3.) It is our opinion that this table

identifies enough difference to change the economics significantly.

Emissions from chemical plants will vary depending on the chemical feedstocks

and products. Some plants, such as acrylonitrile plants curr~ntly have very

strict work place limits under OSHA, and hence must be careful to repair

leaks to avoid high worker exposure. Other plants produce chemic.als which

tend to polymerize, and "self seal" small leaks. Based on these

considerations chemical plants are not similar to petroleum refineries and

should not be regulated as such.

8-20
Inaccessible Sources

Relief Valves

Use of Draft Reports

January 15, 1982

THE STANDARD Oil COMPANY

- 2 -

Pump Seal Requirements

In Chapter 2 references 1, 30, and 40, Chapter 3 reference 3, Chapter 4

reference 2, and Chapter 6 reference 5 are all draft reports. If these

reports were never issued as final reports, they should not be quoted in a

document that will be used to develop regulations. The use of these

documents creates a "house of cards" on which the regulations will be based.

The guideline mentions that some sources in a chemical plant are

inacces,sible, and should not have to' be monitored as frequently as accessible

sources. We feel that it is dangerous to be standing on a ladder while

monitoring inaccessible valves, and that it would also take appreciably more

time to monitor these sources than the normally accessible sources. This

would seriously impac~ the economics of the !equirement to monitor these

sources at all. We would recommend removing the requirement that these

s9urces be monitored. .

Flanges

Flanges are not a source of leaks. This has be~n shown in both refinery And

chemical plant surveys. Any reference to monitoring these should be removed

from the guidelines.

B-21

The guideline mentions monitoring relief valves. This poses a health and

safety hazard to the monitoring team, as if a valve were to relieve as a team

was monitoring it, serious, injury may result. This may happen at any time,

since these valves are designed to automatically vent during upset or

overpressure events. We feel that any attempt to require monitoring safety

valves is unwarranted, and these references should be removed from the

guideline.

Double mechanical seals are not feasible on all pumps in a chemical plant, as

the barrier fluid will cont~inate the process stre~ if the seal leaks.

Tandem s'eals (double mechanical seals in which the barrier fluid is not under

pressure) are allowed if the seal oil is degassed and incinerated. This is a

very costly approach, because it is doubtful if enough seals will be leaking

at any given time to support combustion. Therefore, the incinerator would

have to cC\ntinuously fire alternate fueL Significant amounts of other

gasseous air pollutants (SOX, NOx, TSP) would be generated to control a

rather insignificant amount of hydrocarbons. We feel that this requirement

should be eliminated based on cost and these other environmental impacts.
THE STANDARD OIL COMPANY

- 3 - January 15, 1982

Sohio appreciates this opportunity to comment on this draft guideline. If

you have any questions "concerning these comments, please contact: me at

(216) 575-5136.

Sincerely,

Allen

(j}1J-~ R. Ellett

Environmental Specialist

ARE/dmb

"8-22
Attention: Mr. Fred Porter

Dear Mr. Porter:

~B-23

Chemical

3520 Vinyl Chloride

Synthetic Organic Chemicals Manufacturing Industry

OCPDB No.

Table I:

Styrene-Butadiene Latex

?c''!:' ':inyl c":':lcr:'de, ~his request: :'5 ;ased upon the fact that fug:itive

-=:-:5S:'·=~S :::c= :~~s ~:-:·ccss are a::-ead:" regulated by thE; ~~aticnal Emis-

;:.'.::: S::a::.ca:-ci ,:0:- ::aza:-cic'-.!s .':'.ir :E=cllutants - Vinyl Chloride, 40 C'F'!I.. 61.65

.'.:). ::"'1€: fugiti·,,·e ,e::-.issic:'"lS :rcT:'". :he \Tin:-l chloride process a!"E alreac:..-

s:~ingently cu~trolled and all the controls listed in the subject support

CCC'-,:7le71t Ci~e already in place. Therefore, no further c.ontrol can be

e~?ected by application of the ~;CT controls contained in the subject

ciocu~ent. The potential duplication of reporting would be burdensome and

and serve no purpose.

?cr stvrene-butadiene latex. our recuest is based UDon the sr.~ll potential

:~r \'OC fu~itive e~ission r~duction~ and associated' costs for this small

~~~~ction.- \,e assu~e ~~e onl~ reason stvrene-butaciene latex is still

:is:ed in Table II is.oecause· the ~,ency~ ~as developing a eTG document for

:~is precess. ~5e base this assu~?tion on the fact that styrene-butadiene

Emission Standards and 'Engineering Division (}ID-13)

U. S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Re: Draft CTG·Document: Control of voe Fugitive Emissions from

Synthetic Organic Chemical, Pol)~er, and Resin Manufacturing

Equipment. August, 1981

Table II: Polyner and Resin ~anufacturing Industry

January II, 1982

i~e =~Good!jchCompany

Chern/eel GrOIJ;."

6',0: 00>' Tree ooulevcrd

C;e\'e::::~c. Ohio ~4131

16.t.~ 7·600~

we appreciate the opportunity to comment on the subject document. We

respectfully submit these comments pursuant to your letter of December

~l, 1981 and the Federal Register notification of December 7,1981.

~:Our comments are directed to Page B-6 of Appendix B, List of Chemicals

'Defining Synthetic Organic Chemical, Polymer and Resin Manufacturing

. Industries. ~e request that the following chemicals be deleted from

this list:
?a£e 2

"::a:::.uary 11, 1982

co?olyrners ~ere listed in the January, 1981, draft fugitive guideline

::ocu::;lent.

At that' time, both styrene-butadiene crumb rubber and styren1a-butadiene

latex ~ere included in the CTG document "Control of Volatile Organic

Co~pound Emissions from Manufacture of Styrene-Butadiene Cop1olymer".

Ho't~ever, the SBR crumb rubber category was dropped from the document

pursuant to our testimony at the April 29, 1981 National Air Pollution

Control Technique Advisory Committee (NAPCTAC) meeting. The additional

controls were not cost effective.

Fugitive emissions associated with the styrene-butadiene latex manufacture

are from styrene unloading/charging pumps, butadiene unloading/charging

pu~ps, and flanges and valves in the liquid lines between the storage

tanks and the reactorS. These emissions are similar to the emissions

frow the emulsion crumb rubber process. We believe, therefore, that

the Agency should eliminate styrene-butadiene latex since styrenebutadiene' crumb rubber w.as deleted from the category and the, fugitive

e~issions from the t~o processes are similar.

Sincerely,

THE BFGOODRICB COMPA~~

CHEHICAL GROUP

O~Ah. ~J ~~r'~ 1:mes w. Le~is Manager, Special Environmental

Projects

J~'J../des

8-24
1000 SRAZOS, SUITE 200. AUSTIN, TEXAS 78701-2476. (512) 477-4465

January 15, 1982

Emission Standards and Engineering Division (MD-13)

Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Attention: Fred Porter (2)

RE: Comments On The Draft CTG::

Fugitive Emissions From Synthetic

Organic Chemical, Polymer & Resin

Manufacturing Equipment

46 FR 59630, December 7, 1981

. Dear Mr. Porter:

Attached are the Texas Chemical Council's comments on the

. su~ject fugitive emission control guideline.

.- Sincerely Yours,

()./I.~

A.H. Nickolaus

Chairman, CTG Subcommittee

CC: J. S. Matey - C!-1A

-, J. S:'enknecht - Dow

J. D. Martin - ~nion Carbide

J. B. Cox - Exxon

Roger Wallis - TACB

Air Policy Co~ittee

TCC Files

Attach::ients

8-25
---------------------------'------'

COMMENTS BY mE TEXAS CHEMICAL C01JNCIl

ON THE

DRAFT CONTROL 'rECHNIQUE GUIDELINE (CTG).

FOR TEE CO~~Ol OF VOLATILE ORGA!~IC COMPOUND FUGITIVE ~1ISSIONS

nOM STh'"1'HETIC ORGANIC CHEMICAL, POLYMER & 'RESIN MFG. EQUIPMENT LDATED AUGUST l!~

!he Texas Chemical Counc:il (TCC) is an association· of' 85 che!I1ical

companies having more than 67,000 etllployees in Texas and representing

approximately 90% of the chemical industry in the state. Thus the draft CTG

for the control of volatile organic compound (VOC) fugitive e~ssions is of

vital concern to us.

The draft CTG does not fulfill its stated purpose (Chapter 1) to

l1~eview existing information and data concerning technology and costs for

fugitive emission control in the Syo.thetic Organic Chemical Industry (SOCMI)".

It is based on data from petroleum refineries and does not incorporate the

SO~I data (Ref. 1-8) developed specifically for this purpose:. These SOCMI

data show: " -

.- leak frequencies and ~ates in the chemical industry are different

from, and significantly less than, petroleum refiniIlg so the proposed

control strategies are largely inappropriate •

•• "Uncontrolledl1 emission levels are sufficiently close to the controlled

levels sought by the EPA so' that a eTG may be unnecessary.

• !he cost of emission control is greatly understated.

Thus the draft: CTG needs extensive revision to make i1: accurate

an~ technically sound.

Most of the deficiencies in this document have been discussed in

the previous TCC comments listed in Table 1. The discussion follc)'wing

3u~rizes and/or references those that are especially pertinent. Since

extensive reference is made to our Jl.lly 27,1981 comments (:-:.e£. 17) on the

SOc:.-l1 studies, a copy of them is attached (see Attachment 1). Also 0 ,

re=e~ence numbers 1 through 16 in 'this letter have been kept: the same as t~ose i~ our July 2ith comment to help avoid confusion.

8-26
'.

- 2 -

. I. wny The CTG Should Be Redone

The EPA's approach to fugitive emission control is based on certain

key conditions and suppositions. Several of these are not in agreement with

the facts developed in the SOCMIstudies. The differences and consequences

are discussed in Attachment 1. Also see page t~o of Ref. 10 and pages 25-

29"of Ref. 11 for a further discussion of screening values relative to the

definition of a leak.

In addition to the comments already made, we continue to be puzzled

by the data shown in Figure 3-7.of the Maintenance Study (Ref. 1) in which

a control sample group o'f 60 valves actually decreased 'in emission rate

over a median 77 day period. This is contrary to the EPA's theory of leak

occurrence, and we would appreciate an explanation.

We have also reviewed the High-Density Polyethylene Plant data

(Ref. 8) and in addition to concluding that more frequent inspection and

monitoring did not reduce the percentage of valves leaking (Ref. 17), we

note the percentage of valves leaking is high also. These data indicate a

good performance level of .2% of valves leaking is too stringent for RACT

(See Figure 1). '

we believe the discussion in Attachment 1 gives ample reason for

redoing this CIG. We note that although the SOCMI Screening Study (Ref.

2) was published in September 1980, the SO~I Maintenance' Stuciy (Ref. 1)

~n. May ~~o~. . ,- ana" tne·.~.a~ys~s ,\- - . ~tu ... dyeI. (R" 3 " 7) i T '9°' ,0, n _uue ~~, ~=t or.e

SOCMI data point was used in this draft CTG publ~shed in August 1981 to

estimate SO~I emissions, to develop a SOCMI control strategy, or to

estimate SOC~I concrol costs. 'The latest references in Cnapters II and

III are 1979. The C~~ and TCC comments in March 1981 on the preliminary

draft CTG were almost completely ignored.

If model plants are to be used" a set more representative of SOCMI

should be developed. These should give greater consideration to a wide

range of leak frequencies and to the relationships summarized on page 5

of Ref. 3, 6, and 7. Contrary to the statement in Par. 2.3.1 of the CTG

the ~odel units do not represent different levels of process complexity.

~ach contains the saoe co~ponents in almost the same ratios; the only

difference is in the numbers of each. Further, in Table 11-3 of the

reference they are based on (Ref. 1 in Chapter 2), Model Units A, B,

and C are identified as Small, Medium, and Lar2e Model Planes.

II. Is A CTG Needed?

In Reference 18 the w~ estimated that SOC~I emissions ba5ed on

5001I data are probably less than 30% of EPA's estimat:e base", on petroleu:n

refinery data. Their comments on this are quoted on the following page,

and their complete submission is attached (Attachment II) for your review.

B-27
.'

.

. - 3 -

"Using the data f't'om Table I we calculated a SOCMI emi.ssions

total of 55 gg/yr. However, the BID using refine't'y data

estimated SOCMI fugitiv'e emissions of 200 ggJyr. This furth(aT.'

confirmed p't'evious ~~ asse't'tions that SOCMI emissions are

approximately 30 percent of the refinery emissions. This is .

true, even though emissions are calculated using only delta

from the "high leak" processes - ethylene, vinyl acetate and

cumene. The actual SOCMI industry is in large part comprised,

of "low" and "non-leak" processes. Of the approximately 1,000

SOCMI plants in the data base, the ethylene and cumene plants

represent less than 5 percent of the total numb~r.'

'If emissions were calculated using a true mix of the plants,

including "loT.o1" and "non-leakll processes, the SOCMI emi.ssion,s·

would be considerably below 55 gg/yr. In fact, the uncontrolled

SOeM! emissions might well app't'oach EPA's proposed 't'egulatory

goal of 26 ggJyr. We conclude the p~esent uncont't'olled fugi.tive

emissions from SOCMI are de minimis. The data from these reports

demonstrate no real need for the NSPS or the CTG. 1I

The TCC agrees with CMA.'s conclusions, and we urge the EPA t:o

.seriously reappraise the need for this CTG.

II!. Control Costs Are Greatly Underestimated

Th~ analysis of R.A.CT cont.rol costs in Chapter 5 greatl)~ '..!!ldE~!"­

es~ica~e them. Using screening times and leak" rates based on SOGMI dat~

in Refere~ce 2 we' estimate the mi.n~num cost of EPA's proposed prc'gram

for ~odel Unit B to be $980/Mg VOC instead of a $247/Mg credit - a

difference of $1227/Mg. Details and basis for our estimate are :shown

i:l Table 2.

!~, ~~~ent On EPA's ~~CT Recommendations

In Chapters 3 and 4 the CTG makes various recommendations o:f TN'hat

~hey consider to be reasonably available control technology (RACT). The

,TCC ;'eJ.ieves that in. many if not most cases. existing SOCMI !llaintenanc.e

a~d operating practices result in emission level~ equal to or better than

!?~r s ?roposed program. For this reason any R...\CT recommendeltion the EP.4.

cakes should allow these prac.~ices to continue. The TCe also believes

~ha~ ~i£ferences between the SOC~I data in Re£ere~ces 1 thrcJugh 8 and the

basis used by the EPA in developing their proposed control strategy are

such chat the whole strategy should be re-analyzed. However, ~e are

pessi~stic about this being done, so our comments and recommendations

follo~~g are intended to make the best of what the EPA has recommended,

:lot to endorse them.

8-28
- 4 -

A. MonitorL~g Freauency

1. We recommend the basic monitoring frequency be once per year

with those units that do not achieve an "allowable percentage of

'valves leaking" increasing their frequency to' semi-annually or

quarterly.

2. We also recommend that those units which meet this good

performance level for two or three annual inspections be allowed

to drop the program entirely - provided they continue their same

general operating and maintenance practices. -

3. We also recommend the program start with an initial monitoring

and that the second monitoring o~e year later be used to determine

if a unit must start a more frequent monitoring period. Starting

this way would give a plant time to assess their situation, make

feasible engineering and operati~g improvements, or gear up for

more frequent monitoring. Since we believe most SOCMI units

will pass the initial screening test, a great deal of unnecessary

".Jork will be avoided. After the second annual monitoring, 'units

would go from semi-annual or quarterly to annual periods and vice

versa per the skip-period monitoring plan in Section 3.2.3 or

some appropriate modification of it.

B. Allowable Percentage Of Valves Leaking

The CTG mentions a two percent allowable percentage of val~es

leaking asa reasonable performance level. This is the same as

the NSPS and is too low for RACT. It should be on the order of

4% or higher and based on a valid cost-effectiveness analysis,

SOCMI maintenance effectiveness, the high-density polyethylene

data, etc. This number is critical to the reasonableness of aACT

and should be set'based on mass emissions and the best computer

analysis of SOCMI data.

C. Action Level (Leak Definition)

The EPA ~as recommended 10,000 ppm ~r greater observed during

~onitoring as the definition of a leak. From the start the TCC

has argued that this level is too low and extensive comments and

reasons ~ave been set forth in Reference 10 (page 2) and

Reference 11 (pages 25-29). We recommend the EPA define a leak

in terms of a component's' mass emission rate and that they not

specify a sirigle rate. for the CTG but give the states a choice of

several. The concentration level corresponding to the mass

emission rate for the chemicals in question could then be usee

for screening purposes. Giving states a choice of several levels

would let them tailor a control plan to fit their needs.

B-29
- 5 -

D. Capuing Of Ouen-Ended Lines

Okay. See comments page 24 of Reference 11.

E. Weekly Pump Ins'Dection

Okay. See counnents page 18 of Reference 11. "

F. Allowable Internal Before Repair

Generally okay. See comments on possible delay beyond

scheduled unit shutdown on pages ,18-21 of Reference 11.

G. Definition Of Light Liquid

Based on petroleum. refining splits, a light liquid i.s

defined as one having a vapor pressure greater than 0.3 kPa

(0.044 psia) at 200 C. We believe a more rational basis·

would be in terms of the vapor pressure at 20°C that eqt:lals

the concentration units equivalent to the action level. For

example, for the EPA's proposed 10,000 ppm level this would

be 0.01 atmospheres or 1.0 kPa (0.147 psia).

H. Unsafe & Difficult To Reach COmPonents

'. The discussion of this in Par.' 3.3.1 suggests tnat J:or

safety reasons the state may wish to· require ~!requE~

monitoring of cert~in components in hazardous service. This

has been added based on TCC/CMA comments but doesn't. qu:Lte

capture our concern. Certain processes are carried out at

such extreme conditions that access is not allowed anyt:lme

the unit is in operation. Thus monitoring while the unit: is

in operation is not possible. This and some a1ternativi:

monitoring possibilities are discussed on page 33 elf Ref. 11.

I. Exclusion For Small Valves

Par. 2.3.1 of the CTG states that fugi~ive emissions are

no'C related to capacity, throughput, age, temperature, or

pressure. We do not find this s'Cated in the reference

document (Ref. 14, pages 11-49). What ~e did find ~as a

statement that source and stream types could be gr(:>uped such

'Chat three equations were adequate for predicting leak rates

from screened sources (see pages 11-12). But this is not

quite the same and in Reports 3,6 and i significant e£=ects

~ere found for pressure and ambient temperature when

analyzing SOCMI data.

8-30

I

"I""
~/rtg

- 6 -

Further we have recent data relevant to valve size from a

refinery hydroprocessing unit handling light hydrocarbons at

high pressures and temperatures - out of some 5,000 valves

screened, 200 leaked (>10,000 ppmv) but none of these were in

valves 2" or smaller although there were numerous valves 2"

and smaller in the unit. We request the EPA to re-analyze

their data specifically on this point to determine if small

size valves can't be excluded from the monitoring requirement.

A. H. Nickolaus

January 14, 1982

8-31
REFERENCES

1. "Evaluation of Ma.in~enance for Fugitive VOC Emissions Control", EPA-600/52-8l-080,

May, 1981.

2. Blacksmith, Harris, and Langley, "Frequency of Leak Occurrence for Fittings in

Synthet:.ic Organic Chemical Plant Proce.ss Units", September, 1980'. ,

3., 6.;, & 7.

"Analysis of SOCMI VOC Fugitive Emissj.ons Da~a", EPA-:600/2-8l-lll, June, 1981.

4.

5.

8.

9.

10.

ll.

13.

14.

,.. .!..') •

.. , .t.O ..

17.

18.

"Response Factors of VOC Analyzers at a Meter Reading 10,000 ppmv for Selected

Org~ic Compounds", EPA-600/2-8l/-5l, March, 1981.

"Response of Portable VOC Analyzers to Chemical Mixtures", EPA--600./2-8l-ll0,

June., 1981.

'~VOC Fugitive Emissions Data - High Density Polyethylene Process Unit", EPA600/2-81-109, June, 1981.

"Flare Sampling and •.malysis Methods Deve19pment - Nineteenth Monthly Progress

Repor~", April 1-30, 1981.

"Texas Chemical Council Comments on EPA's Preliminary Draft CTG Fo'!' Control of

VOLatile Organic Fugitive Emissions From Synthetic Organic Chemical, Polymer?

And Resin Manufacturing Equipment" given by A. H. Nickolaus at the March 17-18,

1981 National P.ir Pollution Control Technical Advisory Committee (NAPCTAC)

meeting.

--. CMA & TCe, "Comments of The Chemical :Hanufactur~rs Association and Tne Texas Che~cal Council on EPA's Proposed NSI)S for VOC Fugitive Emission Source~ Under

Ihe Clean Air Act,'Docket No. A-79-32", April 6,1981.

Letter: A. H. Nicko1aus (TCC) to Don R. Goodwin (EPA), "Draft Control Technique

Guideline Document For Control of VOC Emissions From Manufacture of Polyethylene,

Polypropylene, and Polystyrene Resins, May 29, 1981, Page 3.

"voc Fugitive Emissions in SOCMI-BID e'or Proposed Standards", EPA-·4,50/3-80-033a,

;:';ovember, 1980.

'~tM~ssion Factors and ,Frequency of Leak Occurrence for Fittings in Refiner;

?:-ocess Units", E?A-600/2-79-·044, February, 1979.

Ba.sed on emission rates in Table 4-4 of the BID (Ref. 14) a.nd the n,UZlber or

valves in gas and light liquid service in the Model B plant (Table 6-1 or the

BID) •

A. R. Nicko1aus (TCC) to Central Docket Section (A-130) Attn: Docke,t No. ~-i9-32, "RE: Proposed VOC Fugitive Emission Regulations For SO~I Sources,

COII:::i::ents on Reports No.1 thru 8 (46 FR 21789, A~ril 14, 1981)", J'uly 27, 1981.

J. S. ~a~ey (Chemical Manufacturers Association) to Central Docket Section

(A-130) Attn: Docket: No, A-79-32, "RE: Proposed ... VOC Fugiti'lle Emission

Sources ••• April 14, 1981 Review of Background Reports", August 7, 1981.

8-3-2
May 17 t °1979

February 1, 1980

June 30 t 1980

July 28, 1980

July 30, 19.8'0

March 3, 1981

March 17, 1981

March 23, 1981

April 6, 1981

June 12, 1981

Jt!ly 27, 1981

.AHN!rtg

1-14-82

TA:BLE r

TEXAS CHEMICAL COUNCIL (TCC) COMMENTS

TO IRE EPA DURING THE DEVELOPMENT

OF VOC FUGITIVE EMISSIONS MONITORING REGULATIONS

Letter From H. H. McClure (TCC) to David R. Patrick (EPA).

Comments on the March 1979 Hydroscience Report on

Fugitive Loss Control Option.

Letter From H. R. McClure (TCC) to Jack R. Farmer (EPA).

Comments on the Draft Background Information Document. \

Letter From TCC to EPA. Comments on the Draft BID and

Recommended SOCMI Standard.

Letter From H. H. McClure (TCC) to Walter Barber (EPA).

"Texas Chemical Counc~l Data On Capital 'Creep'''.

Letter From H. H. McClure (TCC) to Walter Barber (EPA).

"TCC/EfA_Conference on Proposed SOOl1 Fugitive Emission

NS'PS".

TCC Testimony At the Public Hearing on the SOCMI Fugitive

Emissions Monitoring NSPS.

-- TCC Testimony at the March 17-18, 1981 NAPCTAC Meecing

on the Preliminary Draft- CTG. •

TCC C1a~ifying Comments on Questions Raised at the NAPCTAC

Meeting. Letter From:A. H. Nickolaus (TCC) to

Don R. Goodt.7in (EPA). '

CMA!TCC Joint ·Written Comment on the Proposed NSPS

(Docket No. A-79-32). i

Letter From A. H. Nicko1aus (TCC) to Don R. Goodwin (EPA)

on Questions Raised at the Petroleum Refining NSPS Review

before the NAPCTAC on June 3, 1981.

TCC Comments on the SOCMI Studies to Docket No. A-79-32.

/
TABLE 2

COST EFFECTIVENESS FOR MODEL UNIT B

CTG

TABLES 5-6,10

VOC EMISSIONS, MG/YR

"UNCONTROLLED11

CONTROLLED

REDUCTION

260

90.4

169.6

78

50.9 ---

27.1

A.~'UAL COSTS BEFORE CREDITS

PUMPS

VALVES

GAS

LIGHT LIQUID

SAFETY/P.ELnF VALVES

OPEN-ENDED VALVES

GAS SERVICE

LIGHT LIQUID SERV~CE

HEAVY LIQUID SERVICE

COH?3.ESSORS

INSTRUMEJ.'f! COSTS

TOT_~

RECOVERY CREDIT @ $410/MG

~n· COST

COST EFFECTI~ESS, $/MG

$9,4.86 $9,486

1,836 4,168

1,771 4,020

1,128 1,128

698 1,584

3,532 8,018

2,535 2,535

1,240 1,240

5,494 ---1,494 _

$27,720 $37,673

$69,540 $11,111

($41,823) $26,562

(247) 980

E~ssi6ns: 30r. of eTG Based on SOCMI Data - See Attachment 2.

Monitoring Time: 1:7 Man-minutes Per Component - Table 2-2 Rei. 2.

Labor Efficiency: 757. Based on ~~erience, Allows Time for Training, Safety

Meetings, Breaks, Etc.

~L~tenance Efficiency: 71.3% per Ref. 1

B-34