# &EPA United States OfficeofAirQuality EPA-450/3-83-006 Environmental Protection Planningand Standards March 1984 Agency ResearchTriangle ParkNC27711 Air 

# GuidelineSeries Control of Volatile Organic Compound Leaks from Synthetic OrganicChemical and Polymer Manufacturing Equipment

### EPA-450/3-83-006



# GuidelineSeries
Control ofVolatileOrganicCompound Leal<sfrom 

# SyntheticOrganicChemical and 

# PolymerManufacturing Equipment

Emission Standardsand Engineering Division

u.S. ENVIRONMENTALPROTECTIONAGENCY OfficeofAirand Radiation OfficeofAirQualityPlanningand Standards ResearchTriangle Park, NorthCarolina27711
March 1984GUIDELINE SERIES

..... TheguidelineseriesofreportsisissuedbytheOfficeofAirQualityPlanning andStandards(OAQPS)to provideinformationtostateandlocalairpollutioncontrolagencies;forexample,toprovide**l~uidance** onthe acquisition and processing of air quality data and on the planning and analysis requisite for the maintenanceofairquality.Reportspublishedinthisserieswillbeavailable-assuppliespermit-fromthe LibraryServicesOffice (MD-35), U.S. Environmental ProtectionAgency, ResearchTriangle Park, North Carolina27711, orforanominalfee,fromthe NationalTechnical Information Service, 5,285 PortRoyal Road, Springfield,Virginia22161.

iii ; 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 ComponentSurvey for Leak Detection

.. 3.1.2 Repair Methods..•..... 3.1.2.1 Pumps

. 3.1.2.2 Compressors..•... 3.1.2.3 Safety/ReliefValves 3.1.2.4 Valves,.

. . . . . . . . ... 3.1.2.5 Flanges. . . . •
.. .••.. 3.1.3 Control Effectiveness ofLeak 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 EMISSIONS . . . • . . . . 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 ReliefDevices. 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

Chapter3.0

- EMISSION CONTROL TECHNIQUES

.. 3.1 LIST OFTABLES

. LISTOF,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 ofValves 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 Difficultto 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 

### DevelopmentofVOC 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 ofMonitoring 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 

### SOLIDWASTE DISPOSAL 4.5 ENERGY. . • 4.6 

### REFERENCES.

5.2 BASIS FORANNUALIZED 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 5-9v 

### 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 OFTHE 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 ONDRAFT CONTROLTECHNIQUES 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 OFTABLES

EQUIPMENT COUNTS FOR FUGITIVE VOC EMISSION SOURCES IN SOCMI MODEL UNITS • • . . • • . . . . . • . . . . EMISSION FACTORS FOR LEAKS FROM PROCESS EQUIPMENT

.. INPUT PARAMETERS FOR LDARMODEL. . . • . . . • . . . EFFECTIVENESS OF QUARTERLY LEAKDETECTIONAND REPAIR ILLUSTRATION OFASKIP-PERIOD MONITORING PROGRAM

. •. COST EFFECTIVENESS FOR QUARTERLY LEAKDETECTIONAND 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 ofJune 1980 Dollars •.•............. LABOR-HOUR REQUIREMENTS FOR INITIAL LEAK REPAIR UNDER RACT . • • • • • • • • • . • . . . . • .. 

### BASIS FOR ANNUALIZED COST ESTIMATES ANNUAL MONITORING AND LEAKREPAIR LABOR REQUIREMENTS FOR RACT . • . • .
. RECOVERY CREDITS • . . . . . . . . . . . . . . . . ; ANNUALIZED CONTROL COST ESTIMATES FORMODEL UNITS UNDER RACT (Thousands ofJune 1980 

### Dollars). . . . ' COST EFFECTIVENESS FOR MODEL UNITS UNDER RACT

.. COST EFFECTIVENESS FOR COMPONENT TYPES IN 

### MODEL UNIT B • • • • • • • • • • • • • • • 

### ESTIMATES OF

### vae EMIS5IONS 

### 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-3Table A-2 A-3
A-4,



### B-2 LIST OF TABLES (CONTINUED)

COSTS FOR COMPONENTTYPES IN MODEL UNITB

.**EQUIP~ENT** 

### LEAKS OFVOC FROM SYNTHETIC ORGANIC CHEMICAL**POL~MER** 

### MANUFACTURING: RACT ..•......... SUMMARY OF PERCENT OF SOURCES DISTRIBUTION CURVES AND PERCENT OFMASS EMISSIONS CURVES AT VARIOUS ACTION LEVELS

. . . . . . . . . . . .: . . • . . LIST OF COMMENTERS AND AFFILIATIONS.

vii Page A-13

A-15

A-20 

### B-2LIST OF FIGURES Figure

Cost Effectiveness ofQuarterly Leak Detection and Repair ofValves With Varying Leak Frequency

- SOCMI· Un;ts .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. General Schematic ofProcess Levels that Make Up the Organic Chemical Industry. • .•. Diagram ofa 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 ofa Gate Valve •• Example ofBellows Seals.• Diagrams ofValves With Diaphragm Seals. Diagram ofa Basic SingleMechanical Seal Diagramofa Double Mechanical Seal (Back-to-Back Arrangement)•.•••••••.•••.• Diagram ofa Double Mechanical Seal (Tandem Arrangement). • • • • • . ••. Diaphragm Pump••.

Diagram ofa Spring-Loaded ReliefValve. Diagram ofa Hydraulic Seal for Agitators. Diagram ofAgitator 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 AirActAmendments of 1977 require each State inwhich 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 attainmentwith the NAAQS for ozone by the statutory deadline ofDecember 31, 1982, could request extensions for attainmentwith the standard. States granted such an extension are required to submit afurther revised SIP by July 1,. 1982. Section 172(a)(2) and (b)(3) ofthe Clean AirAct 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 ofState Implementation Plan Revisions for NonattainmentAreas," (44 FR 20372, April 4, 1979) for ozone SIP's, EPA permitted States to defertoe adoption ofRACT regulations on a category of stationary sources ofvolatile 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 ofRACT. Although CTG documents review existing information and data concerning the technology and cost ofvarious control techniques to reduce emissions, they are, ofnecessity, general in nature and do not fully account for unique variations within a stationary source category. Consequently, the purpose ofCTG documents is to provide State and local air pollution control agencies with an initial information base for proceeding with their own analysis ofRACT for specific stationary sources.

1-12 .•0 PROCESSES AND·PQLLUTANTEMISSIONS
2.1 INTRODUCTION The discussion presented in this document applies to equipment in process units operated to produce one ormore ofthe synthetic organic chemicals listed in Appendix Eofthe proposed standards ofperformance 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 polymermanufacturing 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 ofthe chemical industry consisting ofsome 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 ofthe SOCMI chemicals produced in the United States are derived from crude petroleum or natural gas. The ten principal feedstocks used in the manufacture oforganic 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 ofthe plants in the United States produce less than 5,000 megagrams (Mg) annually. Another 12 percent have production capacities in excess of500,000 Mg.

2-1

### RAWMATERIALS**~DE** 

### OIL, CRUDE NATURAL GAS, ETC.) I, ! I



# I REFINERIES 

# I I

L..-

__ 

### F_U_E_LS

__

# J CHEMICAL' FEEDSTOCK

PLANTS

# []**-~** CHEMICAL FEEDSTOCKS

. '

# [J**HEMICj~ PLANT:~**  

## <::>**ICH~MlCA~ ~~ODUC'~** 

Figure 2-1. General schematic ofprocess levels that make up the organic chemical industry.

2-2The 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 offugitive emissions in a typical process unit. The following sources will be considered in this chapter: pumps, compressors, in-line process valves, pressure reliefdevices, 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 oforganic liquids. The centrifugal pump is the mostwidely 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 ofcontact 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 interiorfrom 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 ofpumps. As Figure 2-2 shows, a packed seal consists ofa cavity ("stuffing box") in the pump casing filled with special packing material that is compressedwith a packing gland to form a seal around the shaft. Lubrication is required to prevent the buildup offrictional heat between the seal and shaft. The necessary lubrication is provided by a lubricant that flows between the packing and the shaft.2 Deterioration ofthe 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

......

, Figure 2-2. Diagram ofa 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 ofmechanical 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 avery 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 ofits construction, much less lubricant ;s needed. Amechanical seal is not a leak-proofdevice. Depending on the condition and flatness ofthe seal faces, the leakage rate can**bE~** quite low (as small as a drop perminute) 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

2-42-5 Figure 2-3. Diagram ofabasic 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. Aseal liquid, such as water or seal oil, is circulated through the cavity. Because the seal liquid surrounds the double seal and lubricates both sets ofseal faces in this arrangement, the heat transfer and seal life characteristics are much better than those ofthe 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 liquidwill 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. Aseal 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 fromPOSSIBLELEAK

__**-l'!:f:.~~~I~** INTOSEALING FLUID

F1.UIDEND

PRIMARY SEAL

# ~--]

SECONDARY SEAL -GLAND PLATE

Figure 2-4.

FLUID END

PRIMARY

SEAL Figure 2-5. Diagram ofadoublemechan}cal seal (back-to-back arrangement)

BUFFERLIQUID

GL.AND Pl.ATE

70·17117·1 Diagram ofa double**~echanical** seal (tandem arrangement)

2-6the 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 ofpump 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, orwhere leakage is an economic problem.IO Diaphragmpumps (see Figure 2-6) perform similarly to piston and plunger pumps. However, the driving member is aflexible diaphragm fabricated ofmetal rubber, or plastic. The primary advantage ofthis arrangement is the elimination ofall 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.

2-72.2.1.2 Compressors. Gas compressors used in process units are similarto pumps in that they can be driven by rotary or reciprocating shafts. They are also similarto 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 offugitive 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 ofthese seal types are leak restriction devices; none ofthem completely eliminate leakage. Many compressors may be equipped**v~ith** ports in the seal area to evacuate gases collecting there. The labyrinth type ofcompressor seal is composed ofa series ofclose tolerance, interlocking IIteeth" which restrict the flow ofgas a"long the shaft. Astraight pass labyrinth compressor seal is shown in' Fiqure 2-7. Many variations in IItooth II design and materials ofconstructi'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

2-8Restrictive carbon ring seals consist .ofmultiple stationary carbon rings with close shaft clearances. This type ofseal may be operated dry or with a sealing fluid. Rpstrictive ring seals can achieve lower leak rates than the labyrinth.16 Arestrictive 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 ofseal, 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 ofthe 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 ofoil 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 ofVOC emissions from the seal oil system, the reservoir can be vented to a control device.

2-9CLEAN OILIN**~i;:~~;r** PRESSURE /"BREAKDOWN ! SLEEVE**l!IDo'~ ~'-\:**  .**,,~\~<;**

ATMOSPHERE

CONTAMINATED OILOUT 17 Figure 2-9. Mechanical (contact) shaft seal.

CLEAN OILIN

OILOUT OUTER BUSHING

CONTAMINATEO OILOUT INTERNAL GAS PRESSURE
Figure 2-10. Liquid film shaft seal with cylindrical bushing.18

2-102.2.1.3 Process'Valves. One ofthe most common pieces ofequipment in organic chemical plants is the valve. The types ofvalves commonly used are control, globe, gate, plug, ball, relief, and check valves. All except the reliefvalve (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 ofa gate valve in Figure 2-11. The possibility ofa leak through this seal makes it apotential source offugitive emissions. Since acheck valve has no stemor subsequent packing gland, it is not consideredto'be a potential source offugitive emissions. Sealing ofthe stem to prevent leakage can be achieved by packing inside apacking gland or a-ring seals. Valves that require the stem to move in and out with orwithout rotation must utilize a packing gland. Conventional packing glands are suited for awide variety ofpacking materials. The most common are various types ofbraided 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 awide range ofoperating temperatures. At high pressures these glands must be quite tight to attain agood seal.22

PACKING GLAND**~l;ff~-~----:-**

# -__. --;.--;:.-7'-=-POSSIBLE E' LEAK AREAS PACKING**_---7~1ii\**

VALVE STEM
23 Figure 2-11. Diagram ofa gate valve.

2-11Elastomeric O-rings are also used for sealing process valves. These O-rings provide good sealing but are not suitablewhere 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 ofseal incorporates aformed metal bellows that makes abarrier between the disk and body bonnetjoint. An example ofthis seal is presented in Figure 2-12. The bellows is the weak point ofthe 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 aleak detector in case offailure.26 )"

BELLOWS**~_-"'1_'-d** BODY BONNET

Figure 2-12. 'J7 Example ofbellows**seals~**

2-122-13 Figure 2-13. Diagrams ofvalVes with diaphragm seals.29 ,iDIAPHRAGM

( b ) DIAPHRAGM

DISK Adiaphragmmay be used to isolate the working parts ofthe valve and the environment from the process liquid. Two types ofvalves which utilize diaphragms are illustrated in Figures 2-13(a) and (b). As Figure2-13(b) shows, the diaphragmmay also be used to'control theflow ofthe process fluid. In this design, a compressor component pushes the diaphragmtoward the valve bottom, throttling the flow. The diaphragm and compressor are connectedin amanner so that it is impossible for them to be separated undernorma1 working conditions. When the'diaphragm 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 diaphragmmaterial, this type of valve can be used at temperatures up to 205°C and in severe acid solutions. Iffailure ofthe 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 ReliefDevices. 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~** ofthe vessel. The most common type ofpressure-relieving device used in process units ;s the pressure reliefvalve (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 ofvapors or liquids until the systempressure is reduced to its normal operating level. When the normal pressure is reattained, the valve reseats, and a seal is againfoy·med.30 The seal is a disk on a seat, and the possibility ofa leak through this seal makes the pressure reliefvalve a potential source of

### voe fugitive emissions. Two potential causes ofleakage from safety reliefvalves are:.

IIs;rrmering or popp;ng,lI acondition due to the system pressure being close to the set pressure ofthe valve, and improper reseating ofthe valve after
arelieving operation.31

Possible LeakArea

Process Side Figure 2-14. Diagram ofa spring-loaded reliefvalve.

2-1L!·Rupture disks are also common in process units. These disks are made ofamaterial that ruptures when a set pressure is exceeded, thus allowing the system to depressurize. The advaritage ofa**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 ofproduct ora corresponding excessive release of fugitive emissions. 2.2.1.5 Agitators. Agitators are commonly used to stir orblend chemicals. Like pumps and compressors, agitators may leak organic chemicals at the pointwhere 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 otherthree seal arrangements, they offer a greatly reduced leakage rate to offsettheir higher cost. The maintenance frequency ofmechanical seals is, also. one33 halfto 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 ofpacked seals on agitators is rare.34 As with packed seals, the mechanical seals for agitators are similar to the design and application ofmechanical 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 ofseal, an annular cup attached to the process vessel contains aliquid that is in contactwith an inverted cup attached to the rotating agitator shaft. The primary advantage ofthis 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

2-15INVERTEDCUP

ANNU.ARCUP

Figure 2-15. Diagram ofa hydraulic seal for

### agitators.~6
Alip seal (Figure 2-16) can be used on a top-entering agitator as a dust orvapor 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 contactwith the lip seal. Pressure limits ofthe seal are 2to 3 psi because it operates without lubrication. Operating temperatures are limited by characteristics ofthe elastomer. Fugitive VOC emissions could be released through this seal when this seal wears excessively or the operating pressure surpasses the pressure limits ofthe seal.37

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

2-162.2.1.6 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. Afaulty 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 ofa process unit is checked periodically by routine analyses offeedstocks 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-sealedjunctions 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 offlange leakage is due to thermal stress that piping or flanges in some services undergo; this results in the deformation ofthe 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 ofprocessing 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 ofpotential sources but are not related to capacity, throughput, age, temperature, or pressure.40 Therefore, model units defined for this analysis represent different levels ofprocess complexity (number of sources) rather than different unit size.

2-172.3.1.1 Sources ofFugitive Emissions. Data from petroleum refineries indicate that cooling towers are very small sources ofvac emission.41 Differences in operating procedures, such as recirculation ofprocess water, might result in cooling towervac emissions, but no data are available to verify this. Emission rates from agitator seals have not been measured. Since there are .10 data from similar sources in other industries no estimates ofemission rate can be made. Because ofthese 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 aunit 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 ofemission source populations that may exist in SaCMI process units. The number ofequipment components for each model unitwas developed from adata 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 ofthe total existing SeCMI plants and include large and small capacities, batch and continuous production methods, and varying levels ofprocess 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 ofexisting seCMI plants are similar to the Model Unit A, 33 percent are similar to B, and 15 percent are similar to C. Data from petroleumrefineries indicate that emission rates ofsources decrease as the vapor pressure (volatility) ofthe process fluid decreases. Three classes ofvolatility 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. Since simi1ar' 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

2-1132-19 aReference 42. bEquipment components in VOC service only.,
c52 percent ofexisting SOCMI units are similarto model unit A.

33 percent ofexisting SOCMI units are similar to model unit B. 15 percent ofexisting SOCMI units are similar to model unit C. dLight liquid is defined as afluid 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 afluid 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 ofComponents 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 Sealless Heavy liquid servicee Single mechanical Packed Equipment Comporentb

Safety/reliefvalves Gas service Light liquid service Heavy liquid service Open-ended linesf Compressor seals Sampling connectionsg Flangesapproximately at avapor pressure of0.3 kPa at 20°C. The data collected by Hydroscience\'!ere used to estimate the split between gas/vapor and 1iquid service for each source.46 In order to apply emission factors for light
\ ' and heavy liquid service, it is assumed that one-halfofSOCMI liquid service sources are in light liquid service. There are no data available on the actual distrihution ofsources 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 ofthe open-ended valve category. Approximately 25 percent ofopen-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 ofleak/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 associatedwith it, and itwas substituted for the emission factor derived from data in Reference 40; (2) The emission factor for sampling connections is based on the amount ofsampling purge reported for every 1,000 barrels of refinery throughputS1 and the average count of sampling connections per 1,000 barrels ofrefinery 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.

2-20TABLE 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 ReliefValves

- 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 ofthe American Petroleum Institute.) 15. Reference 14, p. 9. 16. Reference 13. 17. Reference 14. 18. Reference 14.

2-222-23 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 ofHydrocarbons to the Atmosphere from Seals on Pumps and Compressors. Report No.6, PB 216 582, Joint District, Federal and State Project for the Evaluation ofRefinery Emissions. Air Pollution Control District, County ofLos Angeles, California. April 1958. 37 p. 31. Reference 1, p. II-7. 32. Ramsey, 

### W. D. and 

### G. C. Zoller. How the Design ofShafts, 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 ofValves. 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 ofAtmospheric 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 ofLeak 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 ofAir Pollutant Emission Factors. Research Triangle Park, N.C. AP-42. February 1980. 52. Powell, D., et al. (PES, Inc.) Development ofPetroleum 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 ofprocess unitequipment leaks ofVOC were identified in Chapter2. This chapterdiscusses the emission control techniques whi'ch are



### . ' 

### ,considered representative ofreasonably available control technology (RACT)

for these sources ofVOC**~missions.** 

### The estimated control effectiveness of each technique is also presented. 3.1 PRIMARY CONTROLMETHODS leak detection and repairmethods 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 ofVOC. Emissions from leaking sources may be reduced by three general methods: repair, modification, orreplacement ofthe source. In the case ofopen-ended lines, however, equipment leaks are treatedmore effectively by installation ofcontrol 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 ofodorous 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 bestmethod 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 areawhere leaks may occur. This sampling traverse is called "monitoring" in subsequent descriptions. The

## voe concentration ofthe sampled air is

3-1displayed on the instrumentmeter. The performance criteria formonitoring instruments and a description ofinstrument surveymethods are given in Reference Method 21. The

### vac concentration atwhich maintenance is required is called the "action level. 11 An action level of 10,000 ppmv is considered representative ofRACT. 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 RepairMethods The following descriptions ofrepairmethods include only those features ofeach fugitive emission'source ('pump, valve,**~tc.)** which need to be considered in assessing the applicability**a~d** effectiveness o'feach method. They are not intended to be complete repair procedures. 3.1.2.1 Pumps. Many process units have spare pumps which can be operatedwhile 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
orpossibly even increase fugitive emissions from the'seal. The packing can be replacedwith the pump out ofservice. 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 ofsome process fluid causing emissions ofVOC. These temporary emissions could be greater than the continued leakfrom 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 repairprocedure that was described for pumps. Othertypes ofseals require that the compressor be out of service for repair. Since most compressors do not normally have spares, repair or replacement ofthe seal would require a shutdown ofthe process. 'Ifthe leak is small, temporary emissions resulting from a shutdown couldbe greater than the emissions from the leaking seal.

3-2

### 3.1.2.3 Safety/ReliefValves. 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 ofthe valve, initially or afteroverpressure relieving. There are basically threemeans ofeliminating

## voe leaks from safety/reliefvalves: (1) installation ofa rupture disk in the line priorto the reliefvalve; (2) connection ofthe discharge port ofthe reliefvalve to aclosed vent system; and (3) 

### use of soft seat technology such as elastomer

## "0-:rings. 1I 

### Used upstream ofthe safety/reliefvalve, arupture disk effectively seals the process below the setpressure o'fthe disk. When this set pressure is exceeded, the rupture diskwill break, allowing the safety/ reliefvalve to relieve the process overpressure. ASME codes1 

### provide for such installations and setforth the design constraints for installing rupture disks in conjunction with reliefvalves. ASME codes also provide design criteria to prevent potential safety hazards from pressure building between the disk and valve.1 

### For example, apressure gauge and bleed valve installed between the disk and reliefvalve provide an indication of leakage around the disk and themeans to relieve this pressure. After an overpressure relief, anew rupture diskwould have to be installed to reseal the system. For such an arrangement, itmay be necessary to install a 3-way valvewith aparallel reliefvalve. This would allow isolation ofthe rupture disk/reliefvalve systemfor disk replacement, while maintaining abackup reliefvalve in service. 

### Ablock valve upstreamofthe rupture disk/reliefvalve systemwill accomplish the same purposewhere safety codes allow the use ofablock valve in reliefvalve service. The secondmethod that effectively eliminates

## voe leaks from safety/ reliefvalves is connection ofthe reliefvalve discharge port to aclosed vent system. 

### Aclosed vent system is composed ofpiping, connections, and, where necessary, flow-inducing devices (e.g., fans, compressors); the system transports gas orvapor to acentrol device such as aflare, incinerator, boiler, or process heater. In connecting a safety/reliefvalve to aclosed vent system, any leakage of

## voe through the seat ofthe valve will be destroyed in the control device.

'3-3The use ofsoft seat technology in many cases will also eliminate

### voe emissions from safety/reliefvalves due to improper valve seating. An elastomer "0-ring" can be installed,so that the valve forms atight 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 reliefvalve set pressure). 3.1.2.4 Valves. Most valves have a packing gland which can be tightenedwhile in service. Although this procedure should decrease the emissions from the valve, in some cases it may actually increase the emission rate ifthe 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 ofvalves 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 amanual bypass loop which allows them to be isolated easily, although temporary changes in process operation may allow isolation in some cases. Ifa process unit must be shut down in order to isolate aleaking valve, the emissions resulting from the shutdown might be greater than the emissions from the valve ifallowed to leakuntil 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 ofa sealing fluid into the source. Injection ofsealing fluid has been successfully used to repajr leaks from valves in petroleumrefineries 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 ofthe gasket. Data from petroleum refineries show that flanges emit very small amounts ofVOC.3 3.1.3 Control Effectiveness ofLeak Detection and RepairTechniques For some sources offugitive 

### vae emissions, leak detection and repair programs provide an effective means of reducing the total 

### vae emitted. A

3-4

### control efficiency ofa given leak detection and repair program is dependent upon the programdesign and several factors associatedwith the program design. These factors include:

• monitoring interval;

• action level or leak definition;

• the time interval between detection ofaleak and repair; and

• the emissions associatedwith leaking sources, nonleaking sources, successfully repaired sources, and unsuccessfully repaired sources. Leak detection and repairprograms have been modeled using a set of recursive equations to describe the behavioroffugitive emissions. The model is detailed in atechnical note4and the development ofthe model is summarized in the AIO.S Briefly, the leak detection and repair (LOAR) model examines the distribution ofaclass (equipment type) offugitive 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 thatwere leaking andwere·not successfully repaired (these sources cannot be repaired on-line and must await a 

### turnaround for repair); and

• sources thatwere leaking, repaired, and exhibited early leak recurrence. At each interval, the distribution ofsources 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 LDARmodel presents the emissions reduction at each interval for the interval and as atime-weighted average overthe entire time period since the last turnaround. The latter values are used in the analyses presented here. The LDARmodel computes the distribution considering anumberof 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.

3-5TABLE 3-1. INPUT PARAMETERS FORLDARMODELa

aSelection ofinput 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 ofsources forwhich repair attempts failed Fraction ofrepaired 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 ofthe key input values used in modeling leak detection and repair programs were the product ofan EPA study ofthe effect ofmaintenance on VOC emissions from valves and pumps. The leak occurrence rates used in the lDARmodel were developed based on data collected in six SOCMI process units. Forvalves, 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 ofmaintained valves exhibiting early leak recurrence. The 29 percent success rate for attempted valve repairde,termined in the Maintenance Studywas not used in examining the effectiveness ofleak detection and repair. This low value was the result ofonly simple on-line maintenance techniques, such as tightening bolts and packing. Under arule, maintenancewas determined to bemore effective; and, based on documented studies, a90 percent success rate ofattempted valve repairwas selected. Forexamination ofleak detection and repairprograms for pumps, all seal repair attempts were assumed to be successful. Maintenance failures were assumed to be resultant from the mechanical aspects ofthe 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 Chapter2ofthe AID). Using the inputs given in Table 3-1, aquarterly leak detection and repairplan was examined'for valves in gas service and light liquid service; aquarterly leak detection and repair programwas 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 ofthe valve prior to the open-ended line. Leakage of

### vac to the atmosphere from open-ended lines is most effectively prevented by installation ofcaps. plugs, and double block-and-bleed valves downstreamofthe open-end. Where adouble block-and-bleed arrangement is used, the upstream

3-7

### TABLE 3-2. EFFECTIVENESS OFQUARTERLY LEAKDETECTION AND REPAIR

EquipmentType Pumps (Light**Li~uid)** 

### Valves Gas Li

### ght Li

### quid Safety/ReliefValves (Gas) Effectiveness, Percent Emission Reduction, Per Source, kg/yr
141

31 27 403 

### CompressorSea1s 32.gC 

### 657



### ----- aEffectiveness estimated using the LDARmodel. 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 LDARmodel 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 oftrapped chemical may leak through valve stems. The control efficiency ofusing these techniques depends upon valve seat leakage, frequency ofvalve use, and the amount ofmaterial trapped between the upstream valve and the closing device (i.e., cap, plug, second valve, etc.). oro estimate the overall effectiveness 6fusing these techniques, the annual emissions can be estimated for aleaking open-ended line that is used about ten times annually and is otherwise closed by acap, plug, etc. Aleaking open-ended line results in about 100 kg VOC emittedto the atmosphere annually.7 Assuming that about 0.1 kg VOC is trapped between the valve and enclosing device, and all ofthis 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 percentefficiency; but due to the conservative nature ofthis 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 otherthan the. quarterly leak detection and repair procedures discussed above. Consideration ofalternative control strategies for valves is pertinent because valves account for such alarge percentage of**th~** 

### components to be monitored (about 90 percent in the model process units). Furthermore, valve leaks in general occur slowlywith gradual failure ofthe sealing mechanism. And the history ofleakbehaviorfor populations ofvalves indicates how leaks will occur in avalve population in the future.· Such historical leak data permit less frequent monitoring for valve populations with alow probability ofleaking in the near term. However,**alt~rnative** 

### control strategies are not pertinentfor other components (pumps, compressors, safety/relief valves). These otherequipmenttypes exhibitmore unpredictable failure, with failure generally being instantaneous. In addition, these other components are relatively few in number, afact 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

### alE!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 ifthey 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 ofthese alternative control strategies, however, an owner or operator should be required to notify the Director ofthe State agency. 3.2.1 General The emission reduction and annualized cost ofa quarterly leak detection and repair program depend in part on the number ofvalves found leaking during inspections. Since about 90 percent ofthe components to be monitored in aprocess unit are valves, most ofthe cost ofdetecting leaks in a process unit can be attributed to valves. In general"few leaks mean VOC emissions are low. Consequently, the amount ofVOC emissions that could be reduced through a leak detection and repair program and the product recovery credit associatedwith the programwould be**small~** As a result, the annualized cost ofa leak detection and repair program for a process unit increases as the number ofleaks detected and repaired decreases. On an individual component basis, valves have a lower emission rate than otherequipment components (Table 2-2) and have apercentage leak rate which is lower than most other components. As the percent ofvalves found leaking decreases, the product recovery credit decreases. The direct cost formonitoring, however, remains the same because the number ofvalves which must be monitored remains nearly the same. Therefore, the cost effectiveness (annualized cost permegagram ofemissions controlled) of aleak detection and repair program varies with the number ofvalves (or the percent ofvalves) which**l~ak** within a process unit. Figure 3-1 presents the cost effectiveness ofa,quarterly leak detection and repair program for valves as afunction ofthe initial percent

J··106 4 2

3-11 

### Leak frequency, percent Cost effectiveness ofquarterly leak detection and repair ofvalves 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 Uofvalves found leaking. Because it is part ofthe cost ofthe overall implementation ofRACT controls and is not specifically partofthe valve control costs, the cost ofthe monitoring instrument is not included in the costs ofthe 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, EPAjudges that the cost effectiveness ofquarterly leakdetection and repair becomes unreasonably high at average leak frequencies less than one percent. Based on this judgement, an allowable percentage ofvalves leaking was determined that reflects the average of
one percent ofvalves leaking. Aprocess unit averaging one percent ofvalves leaking will sometimes have less than one percent ofvalves leaking and sometimes have more than
one percent leaking. Statistically, ifa process unit averaged one percent ofvalves leaking, then the percent ofvalves found leaking during a random annual inspection should exceed two percent less than five percent ofthe time. In otherwords, ifa random annual inspection indicated that no more than two percent ofvalves are leaking, the probability is greater than ninety-five percent that an average ofone percent ofvalves leaking is actually being achieved in practice. Therefore, two percent ofvalves found leaking is a reasonable criterion to judge the applicability ofalternative control strategies for valves. 3.2.2 Allowable Percentage ofValves Leaking AState regulation incorporating an alternative control strategy based
on an "allowable percentage ofvalves leaking" would require a process unit to limit the number ofvalves leaking at any time to a certain percentage of the number ofvalves to be monitored. As discussed above, it appears that two percent ofvalves 1eaking represents a reasonable perfonnanc(:! 1eve1 for
an allowable percentage ofvalves leaking. This type ofregulation would require the owner or operator to conduct
a performance test at least once ayear by the applicable test**mt~thod.** Additional performance tests could be requested by the State. Aperformance testwould consist ofmonitoring all valves in gas service and in light liquid service and ofattempting to repair any valves which are**~Ieaking.**

### This type ofregulation for valves would not affect the monitoring plans set for other types ofequipment, however. The percentage ofvalves found leaking during the inspection (prior to attemptedmaintenance) would be determined by dividing the number ofvalves for which a leakwas 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 ofmonitored valves. If the results ofaperformance test showed that the percentage ofvalves leaking was greater than the s,elected performance level ofvalves leaking (e.g., two percent), then the process unit would be in violation ofthe State regulation. Incorporating this type ofalternative control strategy in the State regulation would provide the flexibility ofaperformance standard. Compliancewith the regulation could be achievedby the method deemedmost appropriate by the plant for each process unit. The plant could implement the quarterly leak detection and repair programfor valves to complywith the regulation or it could implement aprogram ofits choosing for valves to comply with the performance level in the regulation. 3.2.3 Alternative Work Practice for Valves AState regulation incorporating an alternative control strategy for valves based on II

### skip-period" monitoring would require that aprocess unit attain a II

### goodperformance level" on acontinual basis in terms ofthe percentage ofleaking valves. As discussed above, it appears that two percent ofvalves leaking represents a "g60d performance level. 1I 

### This type ofregulation would require the owner or operator to begin with implementation ofaquarterly leak detection and repair programfor valves. Ifthe desired "good performance level" oftwo percent ofvalves leaking**~as** 

### attained for valves in gas service and light liquid service for acertain number ofconsecutive quarters, then one ormore ofthe subsequent quarterly leakdetection 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; theywould be subject to their.requiredmonitoring intervals.Ifimplementation ofthe quarterly leak detection and repair program showed that two percent or less ofthe valves in gas service and valves in light liquid service were leaking for

### 1 consecutive quarters, then m quarterly inspections may be skipped. Ifthe next inspection pE!riod also showed that the IIgoodper.formance level" was being achieved, thEm m quarterly inspections could be skipped again. When an inspection showed the "good performance levell' was not being achieved, then quarterly inspections ofvalves 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 ofvalves leaking**repre~ent:s** a good level ofperformance. Table 3-3 illustrates hO\'Ia "skip-per.iod" monitoring programmight be implemented in practice. In this case, the "good performance level" must be met for five consecutive quarters (i=:5) before three quarters ofleak detection could be skipped (m=3). Ifthe quarterly

j leak detection and repair program showed that two percent or less ofthe valves in gas service and valves in light liquid service in aprocess unit
were leaking for each of.five consecutive quarters, then three quarters could be skipped following the fifth quarter in which the percent ofthese valves leaking was less than the "goodperformance level." After an additional three quarters were skipped, all valves would bemonitored again
on the fourth quarter. This strategywould permit aprocess unit that has consistently demonstrated it is meeting the "good performance level" to monitorvalves in gas service and valves in light liquid service annually instead ofquarterly. Another strategy would permitmonitoring for two consecutive quarters and skipping to semiannual monitoring. Ifin two consecutive quarterly periods the good performance level oftwo percent (or less) ofvalves leaking is achieved, then aprocess unit could skip to semiannual monitoring with 90 percent certainty that the good performance level would be met in all periods. Using skip periodmonitoring, aprocess unit coulddevelop and implement its own leak detection and repair procedures or install valves with lowerprobabilities ofleaking, thereby optimizing labor and capital costs required to achieve a good level ofperformance.

### TABLE 3-3. ILLUSTRATION OF ASKIP-PERIOD MONITORING**PROGRAM~** 

### Leak Leak Rate Of Quarterly Good Detection Valves During Action Taken Performance

Period Period 

### (%) (Monitorvs. 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 of2percent. bFifth consecutive quarter below 2percent means 3quarters ofmonitoring

may be skipped. cPercentage ofleaks above 2percentmeans quarterly monitoring reinstituted. d

### Percentage ofleaks below 2percent means' 3quarters ofmonitoring may be

skipped.

3-15

### 3.3 OTHER CONSIDERATIONS This section identifies and discusses otherconsiderations that a State agencymaywish to address when drafting aregulation. These considerations include components which are unsafe or difficultto 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. AState agencymaywish to require less frequent monitoring i,ntervals for these components because ofthe potential dangerwhich may be presented to monitoring personnel. Forexample, some valves might bemonitored 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 monitorbecause access to the valve bonnet is restricted or the valves are located in elevated areas. These valves mightbe reached by the use ofa ladder or scaffolding. Valves which couldbe reached by the use ofa ladder orwhich would not require monitoring personnel to be elevated higher than two meters would be monitored quarterly. However, ifthe monitoring ofcertain valves would require the use ofscaffolding orwould require the elevation ofmonitoring personnel higherthan 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 ofaquarterly leak detection and repair'program fOlr those process units would be high. A**~tate** 

### agency maywish to consider such process units "small" and exempt them from compliancewith aregulation. The total costofaleakdetection and repair programwould consistof the capital cost ofVOC detection instruments and the cost oflabor for leak detection and repair. The cost ofVOC detection instruments would be the
same for all sizes ofprocess units, but the cost oflabor for leak

3-16detection and repairwould depend on the number ofcomponents to be monitored. As the number ofcomponents to be monitored decreases,'both the labor cost and the recovery credit associatedwith VOC emission reduction decrease. This results in alower total cost. However, since the cost of the VOC detection instruments is fixed, aleak detection and repair program becomes less cost effective as the number ofcomponents subjectto monitoring decreases. Valves in light liquid service and valves in gas service are the greatest percentage (about 90 percent) ofthe components which would be subject to monitoring in atypical process unit. In addition, the numberof valves in gas service and light liquid service can be used as a crude indicator ofthe total**~umber** ofcomponents in aprocess unit whichwould be subject to monitoring. Table 3-4 shows the cost effectiveness for quarterly leak detection and repair ofvalves in process units processing small quantities oflight liquid and gaseous VOC. Using the processing rates at the optional cost effectiveness cutofflevels as a guideline, States may wish to consider exempting process units designed for processing small volumes oflight liquid and gaseous VOC from regulations requiring control offugitive VOC emissions. 3.3.3 Unit Turnarounds AState agencymightwish to consider aprovlslon in its regulations which would allow the agency Director to order an early unit shutdown for repair ofleaking components in cases where the percentage ofleaking components awaiting repair at unit turnaround becomes excessive. Use of such aprovision, however, must be carefully considered in terms ofthe emissions reduction achievable and the costs to the process unit in production down-time and repair cost. Alternativemethods oftreating delay ofrepair could also be considered by a State or local agency in reducing the cumulative number of unrepairable equipment components. For instance, delays ofrepair to the

3-17

### TABLE 3-4. COST EFFECTIVENESS FOR QUARTERLYLEAKDETECTION AND REPAIRPROGRAMS FOR PROCESS UNITS PROCESSING SMALL VOLUMES OFLIGHTLIQUID 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 aunit shutdown) orwhere 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. PartUG

- General Requirements (Section VIII, Division I.) In: ASME Boilerand Pressure Vessel Code, An American National Standa:rd. New York, The American Society ofMechanical 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.) AssessmentofAtmospheric Emissions from PetroleumRefining,'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 ofLeakDetection and Repair Programs on Fugitive Emissions. Technical Note DCN 81-290-403-06-05-03. September 1981. 5. U. S. Environmental ProtectionAgency. 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··204.0 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 ofVOC emissions in the absence of RACT (baseline emissions) and after implementation of RACT. The impacts ofRACT 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 ofopenended lines and quarterly leak detection aridrepair ofpumps, valves, compressors, and safety/reliefvalves. 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 oflight liquid and gaseous VOC) may be exempted from implementing routine leak detection and repair programs on the basis ofcost 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 ofquarterly 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/reliefvalves in gas service. However, states may choose monthly monitoring for pumps instead ofquarterly 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 ofleaks. Safety/reliefvalves should also be monitored after each overpressure reliefto ensure the valve has properly reseated.
4-1-

### Compressor seals shouldbe monitored quarterly; however, 'soml: plant owners and operators mayexperience difficulty in reducing concentrations of organiccompounds to 1

### ess than 10,000 ppmv. Moreover, repait- 

### ofcompressor seals often necessitates apotential orcomplete process unit shutdown because compressors are generally not spared. Consequently, plants may find itpreferableto install acompressorvent control system. HOWeVE!r, retrofitting existing compressors with these systems may POSE! a safety problem. Because ofthe problems associatedwith quarterlymonitoring or with installation ofequipment controls in certain cases, RAeT for compressors, therefore, will be determined on acase-by-case basis. The estimates ofemission reductions for compressors in this**chapt~r** 

### are based on implementing aquarterly leak detection and repair program. The organics detection instrument and themonitoring method E!mployed shouldbe EPAReference Method 21 or an equivalent State method. Asource is considered leaking ifmonitoring results in an instrument reading of 10,000 ppmv orgreater. Asoap solutionmay be applied to certain equipment as apreliminary screening technique for leakage. Asoap score equivalent to 10,000 ppmv is not specified in this guide'ine documentbecause' soap scoring is not applicable to all source types and because it involves a subjective evaluation ofbubble formation over a specified period oftime. However, states maywish to allowplant owners oroperators to use the soap scoremethodbased on acorrelation between soap scoring and instrument readings for**sour~es** 

### where soap scoring is applicable. Leaking components should be repairedwithin 15 days ofthe date the leak is detected. Repair shouldbe considered as reduction ofthe measured organics concentration below 10,000 ppmv. Leaking components which cannot be repairedwithout a unit shutdown shouldbe repaired at the next unit turnaround. RACT should be applicable only to components in VOC service. A component is considered in VOC service ifit contains ten percent orgreater 

### voe byweight. AVOC is any organic compoundwhich participates in atmospheric photochemical reactions. Forthe purpose ofthis,document, a light liquid is defined as afluid with avapor pressure greaterthan 0.3 kPa at 20°C. Acomponent should be considered in light liquid service

### ifit contacts afluid containing greater than ten percentbyweight light liquid. Acomponent should be considered in gas service ifit contains process fluid that is in the gaseous state at operating conditions. 4.2 AIR POLLUTION Implementation ofRACTwould reduce VOC fugitive emissions from process units. Asignificantbenefi,cial impact on air pollution emissions would result. The hourly and arinual emissions from each model unitbefore and after control by RACT are presented in Table 4-1. Therewould be no adverse airpollution impacts associated with RACT. 4.2.1 Development ofVOC Emission Levels The uncontrolled emission factors for process unit equipmentwere previously presented in Chapter2 (Table 2-2). Emission factors were developed for those sources thatwould be controlled.by the implementation ofRACT. These controlled fugitive emission levels were calculated by multiplying the uncontrolled emissions from this equipmentby acontrol 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 ofRACT can be determined for each model unit. The emission reduction is the difference between the amount offugitive emissions before RACT is implemented and the amount offugitive emissions after RACT is implemented. These amounts are presented in Table 4-1. The reduction in emissions for the model units after RACTwould be implemented is 37 percent. 4.3 WATER POLLUTION Implementation ofRACTwould 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 AMODEL 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 UNDERRACT

Uncontrolled Emission Source Inspection Interval Uncontrolled Emission Factor,a kg/hr Control Efficiencyb Controlled Emission Factor,c kg/hr Pumps LightLiquid Service Valves Gas Service LightLiquid Service Safety/ReliefValves 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

aFromTable 2-2. bControl efficiency estimatedbasedon LDAR

### m~del results with inputs detailed in the AID. For

compressors and safety/reliefvalves (gas service), the control efficiencyestimates weremade using results oftheABCDmodel adjustedwith results ofthe LDARmodel for comparable equipment types, as discussed in Section 3.1.3. References 1, 2, 3. cControlledemission factor

### =uncontrolledemission factor x[1

- (control efficiency)].

### Some liquid chemicals may already be leaking and entering the wastewater systemas runoff. Abeneficial impact on wastewaterwould result from implementation ofRACT since liquid leaks are found and repaired. This impact, however, cannotbe quantifiedbecause no applicable data on liquid leaks are available. 

### 4.4 SOLIDWASTEDISPOSAL The quantity ofsolidwaste generated by the implementation ofRACT would be insignificant. The solidwaste generatedwould consist ofused valve packings and components which are replaced. 

### 4.5 ENERGY The implementation ofRACT calls for an emission control technique that requires no additional energy consumption for any ofthe model un'it sizes. Abeneficial impactwould be experiencedby saving VOC which has been heated, compressed, orpumped.

4-6

### 4.6 REFERENCES 1. U. S. Environmental Protection Agency. VOC

o

### 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. Memorandumfrom Stelling, John, Radian Corporation, to SOCMI Fugitives NSPS File. March 5, 1982. 1 p. Estimated effectiveness ofleak detection and repair programs for pressure reliefdevices.

4-7

### 5.0 CONTROL COSTANALYSIS OFRACT
The costs ofimplementing reasonably available control technology (RACT) for controlling fugitive emissions ofvolatile organic compounds (VOC) from process units are presented in this chapter. Capital costs, annualized costs, and the cost effectiveness ofRACT 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 aleak detection and repairprogram in existing process units. The capital costs for the implementation ofRACT include the purchase ofVOC monitoring instruments, the purchase and installation ofcaps 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 greaterthan 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 acharge of$18 per laborhour. This rate includes wages plus 40 percent for related administrative and overhead costs.1 5.1.1 Cost ofMonitoring Instrument The cost ofaVOC monitoring instrument includes the cost oftwo instruments. One instrument is intended to be used as a spare. The cost of$4,600 for a portable organic vapor analyzerwas 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 acap, flange, or second valve to the open end. These pieces ofequipment are all included in the definition ofacap for an open-ended

·5-1

### TABLE5-1. CAPITALCOSTDATA

CostValue UsedinAnalysis Item (June 1980Dollars) Monitoring Instrument 2 x4600

## =9200/model unit Caps forOpen-EndedLines 53/line

4,5,6 CostBasis Reference

Basedon costofsingle mechanical seal, assuming 50 percentcreditforold seal. June 1980 cost determinedfrom 1978 costof $113/seal and the ratio of indices {331.8/268.1}. One instrumentused as aspare 2 Basedon costfor 1" screw-on 3 type valve. CostJune 1980

## = $35. Installation

## =1 hourat $l8/hour. 140/seal Replacement Seal

U1 

## , N

### TABLE 5-2. CAPITAL COST ESTIMATES FOR IMPLEMENTING RACTa (Thousands ofJune 1980 Dollars)

aBased on cost data presented in Table 5-1. bNumberofopen-ended lines fromTable 2-1. cInitial leak detection and repair costs are treated as capital costs since

they are incurred only once. dIncludes screening and repair laborcharges. eRepaircosts are industry-averaged perunit and, therefore, consider

fractional repairs. Equipment repairwas 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 RepairCosts (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 ofacap for an open-ended lines is based on a cost of$35 for a one-inch screw-on type globe valve. This costwas supplied by alarge distributor.? Acharge of$18 for one hour oflabor is added to $35 as the cost for installing one cap. Therefore, the total capital costfor installing a cap on an open-ended line is $53. Caps, plugs, and blind flanges can be used atmuch less cost; the capital cost ofinstalling 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 ofthe 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 ofRACTwill beginwith an initial inspection which will result in the discovery ofleaking components. The number ofinitial leaks is expected to be greater than the number found in subsequent inspections. Because initial leak repair is aone-time cost, it is treated as a capital cost. The numberofinitial leaks was estimated bymUltiplying the percentage ofinitial leaks percomponent type by the number ofcomponents in the model unit under consideration. Fractions were not rounded up to the nexthighest integer, thus resulting in industry-averaged values. The repairtime for fixing leaks is estimated to be 16 hours for a purnp seal, 40 hours for acompressor seal, and 1.13 hours for avalve. The repair time for fixing compressor seals includes the cost ofanew seal. These requirements are presented in Table 5_3.12 The initial repair

### co~t was determined by taking the product ofthe numberof 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 ofinitial seal replacements for pumps in light liquid**sE~rvice** is a one-time cost and is treated as a capital cost. Areplacement seal cost of $140 per seal is based on the cost ofa single mechanical seal and assumes a**5-~·**

### TABLE5-3. LABOR-HOURREQUIREMENTS FOR INITIALLEAKREPAIRUNDERRAeT50 percent cost credit for the seal being replaced. The number ofinitial leaks permodel unit is the percentage ofinitial leaks multiplied by the number ofpumps (light liquid service) in the model unit. To present industry-averaged values for each model units, the fractional rep,airs requiredwere not rounded to the next integer. 5.2 

### BASIS FORANNUALIZED CaSTS Annualized costs represent the yearly cost ofoperating a leak detection and repair program and the cost ofrecovering the initial capital investment. This includes credits for product saved as the result ofthe control program. The basis for the annualized costs is presented in Table 5-4. 5.2.1 Monitoring Labor The implementation ofRACT requires visual and instrumentmonitoring of potential sources offugitive

### 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 ofthe time required to monitor, the numberofcomponents in amodel unit, and the number oftimes the component is monitored eachyear. The monitoring times for the various components are presented in Table 5-5. They are 0.5 man-minute for visual inspection, 2man-minutes for valves, 10 man-minutes for pump seals, 16 manminutes for safety/reliefvalves, 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 RepairLabor Labor is needed to repair leaks which develop after initial repair. The estimated number ofleaks 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 acharge of$18 per hour. 5.2.3 Maintenance Charges and Miscellaneous Costs The annual maintenance charge for caps is estimated to be five percent oftheir capital cost.22 The annual cost ofmaterials and labor for maintenance and calibration ofmonitoring instruments is estimated to be $3,000.23,24,25 An additional miscellaneous charge offour percent of

5-65-7 TABLE 5-4. BASIS FOR**ANNUA~IZED** COST ESTIMATES

L (estimated number ofleaking components permodel ¥nit x rep§ir time)hx $18/hr x 1.4 x0.163 $429/Mg VOCi 0.163 x**capita~a** 0.23 xcapital

0.04 xcapital: 0.04 xcapital $18/hourf
0.40 x (monitoring + repair labor)9 0.05 xdcapitalC $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 repairsaReference 26, 27.

.b.lonltoringlaborhours" (Monitoringtime) x(Numberofclllllponents) x(FractionMonitored); thefractionmonitoredannually is anoutputoftheLDM

model. cFractional leaks consideredandprovidedas anoutputoftheLDARmodel. d Leak repairlaborhours" (Repair**tin~)** x(Estimatednumberofleaks). eTheoccurrenceofleaksfromsafety/reliefvalves is dependentuponthefrequencyofoperationofthe safety/reliefvalves. Noestimates ofrequired

repairs havebeenpresented; however, anyleakthatis detected in theabsenceofaRACTrequirementwouldberepairedundernormal plantmaintenance practices. Reference21. fReference 27. 

### TABLE5-5. ANNUALMONITORINGANDLEAKREPAIRLABORREQUIREMENTS FORRAeT

Valves (Gas) .99 402 1232 Valves (LightLiquid) 131 524 1618 Safety/ReliefValves (Gas) 11 42 130 leakRepair LaborHours ReXuiredAnnuallld B C LeakReplIlr MOnitoring laborHours Frllctfon RexulredAnnuallyb Fraction Honitorerl •8 C RepaIred Monitoring ROnHoring

TilllePel 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 NumberOf CQlIIlonents PerHodel Unit TypeOf A 

### eC- Monitoring PUI\lS (I.ightliqUid)

CompressorSeals TOTAl SourceType

U, I COcapital 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 ofthe sumofmonitoring and leak repair labor costs. The administration and support costs include recordkeeping and reporting requirement costs. 5.2.5 Capital Charges The life ofcaps for open-ended lines is assumed to be ten years and the life ofmonitoring instruments is assumed to be sixyears. 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 afunction ofthe 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 ofthe equipment, years The interest rate usedwas ten percent (June 1980). The capital recovery factors and otherfactors used to derive annualized charges are presented in Table 5-4. 5.2.6 Recovery Credits The reduction ofVOC fugitive emissions results in saving a certain amountof

### vec which would otherwise be lost. The value ofthis 

### vec is a recovery creditwhich can be counted against the cost ofa 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, UnderRACT, 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.

5-105.3 EMISSION CONTROL COSTS This section will present and discuss the emission control costs of implementing RACT for each ofthe three model units. Both the initial costs and the annualized costs are included. 5.3.1 Initial Costs The cost ofinitially implementing RACT consists ofcapital 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 ofVOC saved each year as a result of implementing RACT is included as an annual credit against the net annualized costs. The implementation ofRACT will result in saving $6,200 worth ofVOC annually in model unit A, $24,000 worth ofVOC in model unit B, and $74,000 worth ofVOC 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. Formodel 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 Ais $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 peryear; thus, the net annualized cost for model unit Bis $4,300.

5-11

## ------------------------:----------

TABLE 5-7. ANNUALIZED CONTROL COST ESTIMATES FORMODEL UNITS UNDER RACT (Thousands ofJune 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 laborb 0.94 3.**6~~** 

### 11.23 b. Leak repairlabor 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 NetAnnualized Cost 5.34 4.29 2.30

aSumoflaborhours formonitoring in Table 5-5 multiplied by $18/hour. bSumoflabor hours for leak repairs in Table 5-5 multiplied by $18/hour. CBased on 40 percent ofmonitoring labor plus leak repair laborcosts.

5-12Model unit Chas annualized capital charges of$16,500 and total operating expenses of $76,200. The recovery credit is $74,000 peryear. The net annualized cost for model unit Cis $2,300 for controlling fugitive VOC emissions. 5.3.4 Differences in Net Annualized Costs The cost for RACT is differentfor each model unit. The cost for caps for open-ended lines varies because the number ofopen-ended lines is different for each model unit. Because the largermodel 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 ofVOC controlled annually. The cost effectiveness ofRACT for each model unit is the net annualized cost for implementing RACT divided by the emission reduction gained under RACT. The cost effectiveness ofRACT is summarized in Table 5-8. The implementation ofRACT on model unit Aresults 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 ofRACT in the case ofmodel unit Bresults in a net annualized cost of$4,300. The emission reduction associatedwith RACT is 55.4 Mg/yr and the cost effectiveness is $77/Mg. The implementation ofRACT in the case ofmodel unit Cresults 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. Acomparison ofthe cost**effectivene~s** ofRACT for each model unit reveals that cost effectiveness improves as model unit size increases. The strong influence ofrecovery credits and the constant charge for monitoring instruments regardless ofmodel unit are responsible for the increase in cost effectiveness.

5-13**.----~----------------------------~----------~**



### TABLE 5-8. COST EFFECTIVENESS FORMODEL UNITS UNDER RACT

Model Unita A 

### B C Annualized CostBefore 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 ofRACT for each component type in Model Unit B is presented in Table 5-9. The cost effectiveness ofRACT by component for the othermodel units is the same since there are no economies of scale associatedwith the control techniques and since the cost ofthe 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 Bare the same as the by-component cost effectiveness values for othermodel units. The overall cost effectiveness values for the three model units differ as a result ofthe fixed cost for the monitoring instrument. The cost ofthe monitoring instrument cannot be attributed to any single type ofcomponent since all components are monitored by the instrument. Therefore, the cost for each component does not include the cost ofthe 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

### TABLE5-9. 

### COSTEFFECTIVENESS FOR**C01~PONENT** 

### TYPES INMODELUNITB
Annualized Annual Net Total VOC Cost NumberOf CostBefor

# a Recovery Annualizeg Reduction Effectiveness Component Components Credit ($) 

### Credit ($) 

### Cost ($) 

### (Mg/yr) ($/Mg) Pumps (LightLiqUid)b 29 6,670 1,750 4,920 4.08 1,200 

### Valves Gas Service 402 3,670 5,400 (1,730) 12.6 (140) 

### LightLiquid Service 524 4,650 6,140 (1,490) 14.3 (100) 

### Safety/ReliefValves 42 1,130 7,260 (6,130) 16.9 (360) 

### Open-endedlinesc 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 ofmonitoring instrument, unless otherwise noted. b

The net costassociatedwithmonthlymonitoring ofpumps is lowerthan the net cost shown for quarterly monitoring ofpumps. The lowernet cost associatedwith monthlymonitoring results from higheremission reductions and, therefore, higherrecovery credits. The following cost figures are applicable tomonthlymonitoring for pumps: Annualizedcostbeforecredit 

### = 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. Notmonitored 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 ofHI Survey Data Compiled on 15 July 1980: Open-ended Valves (Vent, Drain, Sample) by Size. 12. Letterwith attachments from J. M. Johnson, Exxon Company, U.S.A., to RobertT. Walsh, U. S. Environmental Protection Agency. July 28, 1977. 13. Reference 4. 14. State ofCaliforniaAirResources Board. Emissions from Leaking Valves, Flanges, Pump and Compressor Seals, and Other Equipment at Oil Refineries. April 1978. p. V-18. 5.

7. 1. Letterwith attachments from Texas Chemical Council to Walt Barber, U. S. Environmental Protection Agency. June 30, 1980. 2. Purchase orderfrom 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 ofVolatile Organic Compound Leaks from PetroleumRefinery 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. September22, 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 MAJORCOMMENTS RECEIVED ONTHE DRAFTCTGAPPENDIX 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 ofthe, comments received addressed the new source performance standards (NSPS) for equipment leaks ofVOC in SOCMI. These comments are considered only within the technical content ofthe CTG; that is, the technical aspects ofthe comments are considered, whereas the regulatory decisions concerning NSPS are not addressed. In April 1982, EPA published**Fugitiv~** Emission Sources ofOrganic Compounds
-- Additional Information on Emissions, Emission Reductions, and Costs (EPA-450j3-82-010), or AID. The AID represents EPA's current understanding ofequipment leaks ofVOC 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 ofthe 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 ofthe CTG; (2) Estimates ofemissions, 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 ofVOC, 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 ofVOC from SOeMI were already near the level EPA hopes to

A-Iachieve through control techniques outlined in Chapter4. They based their argument on a comparison ofestimates ofcontrolled emissions based on petroleumrefinery data and uncontrolled emissions based on SOCMI data. Response: Emissions of

### vac from SOCMI represent a significant source ofVOC emissions to the atmosphere. EPA estimates that 540 Gg/yr ofVOC (540,000 Mg/yr) ofVOC are emitted to the atmosphere from all sources in SOCMI (see Table A-I). This estimate ofemissions 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 ofVOC is a significant quantity ofVOC to be emitted as airpollution. This quantity is large in absolute terms and is large relative to otherVOC source categories. Fugitive emissions ofVOC from SOCMI are estimated to be approximately 190 Gg/yr, thus contributing a large proportion ofVOC emissions within the SOCMI source category. The commenters' comparison ofemission estimates indicates confusion over the purpose for CTG's and EPA's approach in developing them. EPA's intent is notto set a regulatory goal. Rather, the intent is to provide St,ate and local airpollution control agencies with information for determining reasonably available control technology (RACT) for specific stationary
sources.
Comment: Therewere 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 CTGwere already in place for vinyl chloride plants underNational Emission Standards for Hazardous Air Pollutants (NESHAP). Othercommenters discussed the potential overlap in regulations set forth by EPA and OSHA. One commenter said that new regulations would be redundant considering the existence ofOSHA regulations. Another stated that for some chemical plants OSHA already has standards governing equipment leaks ofVOC. Forexample, the commenter said that acrylonitrile plants are subject to strictworkplace exposure limits set by OSHA.

A-2

### TABLE A-1. ESTIMATES OFVOC EMISSIONS FROM**SOCMI~** 

### Category Gg/yr Percent ofTotal 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 ofthe total

ofthe other sources.

A-3Response: As discussed in Chapter 1, Control Techniques Guidelines (CTG) are designed to assist states in bringing non-attainment areas into compliance with national ambient airquality standards by providing them control

. technology information. Their role is distinct from that ofOSHA regulations and national emission standards for hazardous air pollutants {NESHAP). NESHAP are developed to control pollutants that are hazardous because' they are carcinogens or the cause ofother serious diseases. Some ofthe individual SOCMI chemicals have been identified as hazardous air pollutants and some SOCMI units may be affected by NESHAP regulations. 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 consistentwith both NSPS and NESHAPwith respect to the equipment covered. There is no duplication ofefforts required by the eTG; equipment covered by NSPS orNESHAP is exempt from the CTG since the equipment is already controlled to a higher degree under these other programs. Many ofthe chemicals covered by the CTG are also listed inTable Z-I, Toxic and Hazardous Substances, in the general provisions for OSHA (29 CFR 1910.1000), and some ofthese chemicals are also covered by more specific health standards underOSHA. As aconsequence, 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 limitmass emission rates directly; OSHA standards for toxic chemicals generally do not. Under OSHA, control ofemission sources may include substitution with less hazardous materials, process modification, worker rotation, process orwork,er isolation, ventilation controls, or modification ofwork practices. These controls reduce occupational exposures, but they do not necessarily reduce the mass rate ofVOC emissions to the atmosphere. Relying on indirect controls that mayormay not reduce emissions thatwould degrade air quality would be an unreasonable approach to reducing emissions ofVOC. However, in some instances, control ofemissions 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-4eliminated for certain sources under specific circumstances. For example, the quarterly monitoring requirement for a pump seal could be eliminated ifthe pump is equipped with dual mechanical seals with anon-VOC barrierfluid system/degassing reservoirconnected to a**~losed** vent system.
Comment: Several [#8; #13; #16; #21; #22J commenters recommended deletion of styrene-butadiene latex from the list ofprocesses 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 ofa 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 ofthe production ofstyrene-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 ofthe total styrene-butadiene production. Another point made in support ofdeleting styrene-butadiene latex was the



# . . fact thatmost gas valves in styrene-butadiene plants are in vacuum service,
so they would not be sources offugitive emissions. Some commenters continued their argument that neither polymer nor resin manufacturers are similar to the chemical producers in SaCMI. Specifically, a number ofcommenters 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 oftheir particular industry segment. Response: In the August 1981 draft CTG, four categories ofpolymers 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 ofvac prior



### A-5**~--------------------------------:-------------**

to the distribution ofthe draft CTG. EPA has also removed styrene-butadiene latex from the list ofaffected chemicals. Thus, this CTG covers only polyethylene, polypropylene, and polystyrene from the polymers and resins category. However, in the future EPAwill consider recommending RACT for equipment leaks ofvac 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 ofSOCMI data or RACT to styrenebutadiene latex units. The data base presented in the AID (on which the final CTG is based) is comprised ofdata on equipment leaks ofVOC in SOCMI. The data were collected from avariety ofSaCMI process types and are considered representative ofVOC 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 ofthe 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 ofthis CTG. In addition to these considerations made for polymers and resins, EPA has

, further evaluated coverage ofthe 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. MTBEwas not produced in large quantities commercially when the SaCMI list oforganic 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 oforganic 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 offugitive emissions data collected in petroleumrefineries to SOCMI and polymer processes. The commentE!rS said that



### A-6fugitive emissions from SOCMI are lower in terms ofboth 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 ofthe loweremissions from SOCMI processes when compared to petroleum refineries. Commenters said that the data showed the differences between the industries and recommended the use ofSOCMI dataexclusively. Commenters [#3; #5; #9; #13; #16; #17; #20; #22J further objected to the
use ofrefinery data on technical grounds. They cited differences in calibration gases and screening instruments used in studies ofthe industry and differences in response factors ofdifferent chemicals as reasons that data generated in petroleum refineries should not be considered relevant to SOCMI. Response: EPA's analysis offugitive emissions data is extensively documented in Fugitive Emission Sources ofOrganic 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 basedwere 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 ofdifferences 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 ofthe differences, EPA decided that an adjustment ofthe emission factors used previouslywas warranted.

A-7After considering alternative approaches, EPA concluded that the best method ofarriving at a complete set ofemission 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 offugitive VOC emissions. These considerations are examined in detail in theAID. 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 ofthe 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 similarto the differences in response at 10,000 ppmv, the data
can be used interchangeablywithin ±30 percent at the action level. Furthermore, laboratory experiments measuring variation in response factors for a numberoforganic chemicals indicated that 90 percent ofthe 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 ofa 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 ofa leak. Soaping is permitted for some sources as a prescreening tool, but this technique, where applicable, must be supplemented with instrument screening ifleaks are indicated using soaping. Soaping is an additional element ofRACT 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-8and 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 aB-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 otherfactors such as delay of repair (C), emissions reduction to a non-zero emissions;level (D) and the occurrence and
recurrence ofleaks and the number ofnon-repairable leaks between monitoring inspections (B). Ofthese factors, the B-factor involved the most subjective consideration; the selection ofthe value for the B-factorwas based on the engineering judgement that the rates for occurrenceirecurrenceinon-repairable leaks were non-linearwith 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 offugitive 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 amixed 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 ofone year. Analysis ofthe results ofthe Maintenance Study led to the development ofanew model describing leak detection and repair programs.' This model is described in detail in aTechnical Note12 and in the AID. The Leak Detection and Repair (LDAR) model is based on a set ofrecursive equations describing leaks from equipment in terms offour categories:



### A-9(1) Nonleaking equipment (screening < action level), (2) Leaking equipment (screening action level), (3) Leaking equipmentwhich cannot be repaired on-line and are awaiting aprocess 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 LDARmodel requ'ires more information than the ABCD model. This information includes repa'ir effectiveness, emissions reduction for successful repair, andem'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 Chapter3. The LDARmodel is the preferred predictor ofleak 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 aviable method ofestimating the effectiveness ofprograms for equipment types forwhich these data are not



## . available. To refine the ABCD estimate for such equipment types, the results ofthe LDARmodel for comparable equipment types may be applied. Forexample, detailed leak occurrence and repairdata have not be generated for safety/ reliefvalves in gas service. By comparing LDAR results to ABCD results for valves in gas services, the ABCD results for safety/reliefvalves can be adjusted to yield a refined estimate for leak detection and repair programs applied to safety/reliefvalves. The AID discusses this refinement procedure for safety/reliefvalves in additional detail. This is the same approach taken in estimating the effectiveness ofleak detection and repair for compressors.a '
aEffectiveness1 

### =ABCDI x 

### ASTIJ 2 For safety/reliefvalves 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-IOComment: 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 ofleak 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 ofthe leak frequency spectrum. Recurrence ofleaks was estimated, according to the commenter, using an extremely sparse data set, resulting in a recurrence rate ofquestionable utility. To support the same claims, the other commenter cited values determined in afugitive emission study in a high density polyethylene plant. Response: Occurrence and recurrence ofleaks was embodied in the 8-factorof the ABCD model for fugitive emissions. An improved model, the LDAR model, is
now the basis for estimates ofemissions and emission reductions for valves and pumps operating under leak detection and repair programs. However, the LDARmodel requires datawhich are unavailable for some other equipment types. As discussed in the previous response, the LDARmodel 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 ofprocess (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-lldifferent), the overall 3D-day occurrence rate of 1.3 percent was selected as an input to the LDARmodel. The Maintenance Study showed that about 14 percent ofall repaired valves started to leak again within 5 days ofrepair. 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 Studywere 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 replacementwhich normally occurs. The resulting 3D-day
occurrence rate input is 3.4 percent. Because leaking pump seals are usually taken off-line and replacedwith new seals, a successful repair rate of 100 percentwas 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 associatedwith 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 thatmonitoring 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 ofthe "unrealistic" cost estimates: a low interest rate, alow overhead charge, and an underestimate ofvalve size. Response: The costing methodology for controlling equipment leaks ofVOC 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 ofcosts are higherthan those presented in the draft eTG. The annualized costs ofRACT for model unit Bpresented in Table A-2 result from use ofthese assumptions.

A-12

### TABLE A-2. COSTS FOR COMPONENTTYPES 

### IN MODEL UNITB
Annualized Annual Net Total VOC Cost Number Of Cost**Befor~** 

### Recovery Annualizeg Reduction Effectiveness Component Components Credit ($) 

### Credit ($) 

### Cost ($) 

### (Mg/yr) ($/Mg) Pumps (LightLiquid)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/ReliefValves 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**1~414** 

### 22,570 23,760 55.4 l-' (..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 ofmonitoring

### instrument~ unless otherwise noted. b

The net cost associatedwithmonthlymonitoring ofpumps is lowerthan the net cost shown for quarterlymonitoring ofpumps. The lower net cost associatedwith monthlymonitoring results fromhigheremission reductions and, therefore, higher recovery credits. The following cost figures are applicable to monthlymonitoring for pumps: Annualized costbefore credit 

### =**8~439** 

### (gross cost) ($) Emission reduction (Mg/yr) 

### = 7.6 Annual recovery credit ($) 

### = 3,277 Net annualized cost ($) 

### = 5,162 Costeffectiveness ($/Mg) 

### = 680 cCost for caps on lines only. Notmonitored under RACT.Also, the cost effectiveness, or the ratio ofthe annualized contl"ol cost to the emissions reduction achieved, is presented in Table A-3, along with the estimated control efficiency ofeach selected RACT. Although these costs are higher, they are reasonable costs and cost effectiveness ofcontrol. As in the draft CTG, where leak detection and repair programs have been selected as RACT, the cost ofthe initial screening and repairofleaking equipment components has been capitalized. These costs are assume!d to be amortized at 10 percent interest over aten year period (a 2-yearperiod is used for replacement seals). Asix-year amortization periodwas used for capitalizing monitoring instruments. The 10 percent interest rate used is conservative in that it represents a real rate ofreturn after taxes and not merely a typical interest rate. The monitoring time estimates for valves were examined in the AID. The 2man-minutes pervalve monitoring time used was based on informat:ion provided by Exxon Company, USA.14 It is aprocess unit-wide average value and is the most reasonable estimate available in the absence ofdata to the contrary. The 40 percent overhead rate was found to be low by some commenters who suggested 100 percentwould better reflect an overhead charge. The labor charge of$18 perhour includes a40 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 associatedwith implementation ofRACT. These two charges taken together amount to a cumulative 96 percent total overhead charge rate. Aone-inch valve sizewas selected as the basis ofthe capital costs for control ofopen-ended lines. Asurvey ofthe data on which the model units were based showed that approximately 92 percent ofthe valves in the process units surveyed were two-inch diameter or smaller. Moreover, the one-inch valve sizewas used to estimate the cost ofcontrolling open-ended lines only. The costs ofcontrolling emissions from open-ended lines are based on installing a second valve. Plugs, caps, orblind flanges are also expected to be used to control open-ended lines; the costs ofthese materials are similar
or less than the costs ofone-inch valves. In most cases, therefore, the control cost based on these equipmentwould be much lower than estimated for use ofa second valve.

A-l4: ,1 .1

### TABLEA-3. EQUIPMENTLEAKS OFVOC FROM SYNTHETIC ORGANIC CHEMICALAND POLYMERMANUFACTURING: RACT
Average Cost Equipment Average Control Effectivenessb Effectiveness, (with credit), Type Control Technique Percent $/Mg Pumps (light liquid Quarterly leakdetection

### &repair 33**1~200** 

### service) Valves (gas and light Quarterly leak detection

### &repair 51 (114)d liquid service) Safety/reliefvalves 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 ofleakdetection and repairprograms is based on results ofLOARmodel,

either solely orin combinationwith the ABCDmodel results. bCosts are 2Q1980 and assume $429/Mg recovery creditfor VOC saved or recovered as aresult of

implementing the control technique. cParentheses indicate net savings resulting fromthe creditvalue ofthe saved/recovered VOC.A.3 RACT SELECTION, PROVISIONS, AND EXEMPTIONS
Comment: Commenters [#4; #5; #9; #14; #19J called the 2percent good performance level arbitrary and said that itwas too low for RACT. Values offered as more realistic levels ofgood performance were 4percent and 10 to 12 percent. Itwas 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 ofleak detection and repair in reducing VOC emissions resulting from equipment leaks has been facilitated for some equipment types by the LDAR model. The LDARmodel has been used to examine the costs and effectiveness of leakdetection 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 of2percent leaking would ensure that most units would be achieving around 1 percentleaking. Therefore, an alternative to periodic leak detection and repair for valves could be a performance level of2percent leaking in a process unit. The selection ofa performance level based on the percentage ofvalves leaking was not a question oftechnical achievability of such a**pE~rformance** level. The selection was based on the high cost effectiveness associated with routine (quarterly) leak detection and repair ofvalves in model units exhibiting low leak frequency. This type ofalternative standardnot 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 leakfrequencies to attain the performance level by means of installing better' equipment or improving their currentmaintenance practices. In addition, skip-period monitoring plans, discussed in Section 3.2.2, may provide anothermechanism 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 ofvalves leaking.

A-H;Comment: One commenter (#20]·statedthat 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 ofvarious organic compounds. Other comments [#5; #9] referred to the definition ofVOC 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 ifa compound should be considered
aVOC. Moreover, he felt that the limitations ofthe detection instruments should be accounted for in the definition ofVOC. 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 ofequipment 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-17The definition of "in VOC service" is ameans ofdetermining ifapiece ofequipment is subject to RAeT requirements. Once the determination is made that apiece ofequipment is "in VOC service," the requirements ofRACT stand alone and do not rely on the**definitio~** ofVOC.
Comment: Several commenters [#5; #9; #10; #20] took exception to the selection of0.3 kPa as the vapor pressure breakpoint separating light liquid and heavy liquid services. They felt this selection was**arbitra~y** and that otherchoices 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 ofthe 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 of760 mmHg at operat'ing conditions). Response: EPA's analysis offugitive emission rates and vapor pressures has shown that substances with vapor pressure of0.3 kPa and higher have significantemission 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 splitwas made to concentrate effort in a leak detection and repair programon 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 commenterfelt 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\-lGeffectiveness. The commenter stated that the control efficiency ofleak 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 aleak definition and that the definition should be based on amass emission rate equivalent. Response: One consideration in selecting 10,000 ppmv as the leak definition for**eq~ipment** leaks ofVOC 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 directmeasurement 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 oforganics 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 ofthe percent ofsources screening above the action level (leak definition) for various action levels (an indication of the number ofleaks) and percent ofmass emissions attributable to these action levels for valves. Analysis ofthe results from the Maintenance Study demonstrates that a significant quantity ofmass 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 ofleak 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 associatedwith 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 ofthe 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

### TABLEA-4. SUMMARYOFPERCENTOFSOURCESDISTRIBUTIONCURVE§AND PERCENTOFMASS EMISSIONSCURVESATVARIOUSACTIONLEVELS

PercentofSources ScreeningAboveb PercentofMass Emissions**Attr~bgtable** 

### to Sources ScreeningAbove ' 10,000 20,000 40,000 100,000 10,000 20,000 40,000 100,000 

### Valves GasEthylene 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 arebased onmodels derived from data collected during 24-unit SOCMI study. h 

### uScreening values ;n ppmv. cThese values were based on the original leakrate/screening value correlations presented in the

Maintenance Study and have notbeen changed to reflectthe new correlations developed in the Technical Note on the revision ofSOCMI emission factors. Based on acomparison ofempirical data, these values are notexpected to change significantly.draft CTG. They based their recommendation on improved cost effectiveness of
an annual monitoring plan. One ofthese comments suggested that for valves monitoring frequency could be increased for units where annual monitoring failed to achieve an allowable percentage ofvalves leaking. Response: Section 4.1 presents RACT for equipment leaks ofVOC in synthetic organic chemical and polymermanufacturing plants. RACT procedures include quarterly leak detection and repair ofpumps in light liquid service, valves in gas service, valves in light liquid service, safety/reliefvalves in gas service, and compressors. However, states may choose to implementmonthly monitoring for pumps because the costeffectiveness ;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 ofRACT are presented for model units in Chapter 4and the cost impacts are given for model units in Chapter 5. The costs, emission reductions, and cost effectiveness ofRACT are reasonable. Alternative programs for monitoring valves are also allowed as RACT requirements. Under such programs, RACT can be met by meeting aperformance level of2percent leaking in aprocess unit. This provision allows specific programs to be tailored to individual process units,.provided an annual performance test demonstrates 2percent or less leaking. Another alternative program for valves allows implementation ofskip-periodmonitoring techniques; these programs are also discussed in Chapter.3. ·Either ofthese approaches has the.potential to reduce monitoring frequency and cost ofvalve leak detection and repair in individual process units. Quarterly leak detection and repair has also been retained as the basis ofRACT for safety/reliefvalves 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 repairmay not always be an effective technique for compressors. For instance, leak detection and repair is not applJcable ifthe 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). Ifleak detection and**l"E~pair** is not applicable to an existing compressor, equipment should be installed as the control technique. An example ofthe equipment to be used is amechanical seal systemwith a non-VaC barrier fluid and degassing reservoir connected to a control device (e.g., flare). Another example ofequipment 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, awaiver 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 ofthe current use offlares. They cited a study of flares by Siegel to support their contention that flares can achieve 99+ percent destruction ofvac. 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 ofleak 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 ofa safety/reliefvalve are effectively**(~liminated** ifthe discharge ofthe safety/reliefvalve is vented to a control device, such as a flare. Where flares are used to control vac emissions from safety/reliefvalves, 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 ofequipment leaks from pumps, compressors, and safety/rel';efvalves in ljeu ofinstrument monitoring.

A-22Comment: 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 bemonitored as often as practicable because ofthe 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 ofmonitoring inaccessible and unsafe to monitor valves should be considered. For example, difficult-to-monitor valves might be exempted from routine quarterlymonitoring provided they are monitored annually. The extent ofthe consideration is left to the discretion ofthe 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/reliefvalves. One commenter felt thatmonitoring of safety/relief valves was unwarranted since serious injury could result ifa 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 ofblock valves upstream ofsafety/reliefvalve. 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 ofblock 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/reliefvalves are routinely inspected as apart ofnormal safety and maintenance procedures to ensure the set**~ressure** is correct. The quarterly monitoring requirement ofRACTmay increase the frequency ofthis ordinary monitoring practice, but the

A-23precautions taken during current safety/reliefvalve inspections are expected to be used during quarterly monitoring. The intent ofthe RACT selected for safety/reliefvalves is to eliminate the large amounts ofVOC that can be emitted through the valve if 'it does not seatproperly after an overpressure release. Therefore, as part ofany emissions reduction program for safety/reliefvalves, EPA believes that monitoring should follow every overpressure reliefwithin 5days ofthe relief. This is to ensure the valve has reseated properly. EPA also considered the existence ofcurrent systems in use in the industry. For example, many safety/reliefvalves are already connl:cted to closed vent systems (e.g., flare headers) for safe disposal ofemergency release gases. Under such a system, there would be no required monitoring. Some process units do have block valves installed upstream ofs.afety/relief valves, as one commenter described. While this is not recommended practice, it is an acceptable procedure under engineering standards. An**impl~ovement** overthis arrangement is the use ofa V-valve with parallel relief systems. This arrangement ensures a safety/reliefsystem is in-service at a'il times and allows ready repair ofone ofthe safety/reliefvalves.
Comment: The 15 day interval allowed for delay ofrepairwas 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 ofrepair 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 ofRACT 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 ofemissions reduction.

A-24For the remaining leaks that are not technically feasible on-line or in-place, delay ofrepair is allowed to the next process unit turnaround.

Comment: Several commenters [#6; #10; #14] objected to the statement that State enforcement officers might request aunitwith 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 ofrequesting aprocess unit shutdown for repair ofan excessive number ofleaks 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 ofan excessive number ofleaks 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 CTGmodel rule for petroleum refining fugitive VOC emissions (EPA-450/2-79-004).16 In lieu ofrequesting an unscheduled process unit shutdown to repair an excessive number ofleaks, State and local agencies may consider including specific provisions for delay ofrepair ofvarious equipment types

..Under this approach, a delay ofrepair beyond the repair interval (15 days) would only be allowed ifrepair is technically infeasible without a process unit shutdown and if spare parts for repair have been depleted (after being sufficiently stocked). Records ofthe reasons for delay ofrepair 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 wouldmost likely be designed to

A-25prevent high cost effectiveness ratios for

## vac control. As discussl:d in Chapter 3, such exemptions might be based on quantities oflight liquid and gaseous vac processed. An exemption based on the number ofequipment components in aprocess unit is another possibility, but it is more appropriately addressed in terms ofquantity oflight 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 ofthe draft eTGwere 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 ofthe reporting and rlecordkeeping requirements. Response: EPA sees no way ofimplementing and administering leak detection and repair programs without some recordkeeping. The level ofreporting and recordkeeping the state and local air pollution agencies will require has not been discussed in the CTG. However, an a11owance was'made for recordkeeping and reporting in the cost analysis. Tagging and logging equipmentthat cannot be repaired on-'Iine/in-place is
an effective means ofhandling those components that must await aprocess 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 ofunscheduled process unit shutdown for repair ofan excessive number of leaks. For these reasons, records should be maintained of all leaks. In the**~ase** ofeffective on-the-spot repair, tagging is not considered productive for the quarterly leak detection and repair programs selected as RAeT; forthe
reasons cited above, however, maintaining records is necessary.

A-26A.4 REFERENCES 1. Memorandum from Stelling, J. H. E., Radian Corporation, to SOCMI Fugitive NSPS file. November 1, 1982. 11 p. Estimates ofVOC emissions from SOCMI. 2. U. S. Environmental Protection Agency. fugitiveEmission 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 ofAtmospheric 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.) ProblemOriented Report: Frequency ofLeak 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 ofMaintenance 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 ofVOC Analyzers to aMeter 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 ofPortable 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 ofSOCMI 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 ofLeak 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 fromMiscellaneous Refinery Sources" draft report. 15. Memorandumfrom Stelling, John, Radian Corporation, to SOCMI Fugitives NSPS File. November 1, 1982. 4p. Cost effectiveness ofleak 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 fromTen 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
COMMENTLETTERS 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 ofthe commenters and their affiliations.

B-12 TABLE B-1. LIST OFCOMMENTERS 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 Regulatory AffailOS 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-2Comment 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 OakTree 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 GoodyearTire 

### &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

15TABLE B-1. LISTOF COMMENTERS AND AFFILIATIONS**(Contin~ed)** Comment No. Commenter and Affiliation
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. BonnerL. laFleur, Chairman Environmental Impact Committee, Southern Rubber Group P.O. Drawer 1361 Lake Charles, louisiana 70602 Mr. M. J. Rhoad Managing Director International Institute pfSynthetic Rubber Producers, Inc. 2077 South Gessner Road Houston, Texas 77063

8-4B-5 I have just initiated review of the draft CTG entitled, "Control ofVolatile 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 EnvironmentalAffairs P.o.'Box2332R Morristown, NewJersey07960 

## ( (

'-

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 emissions ll
• (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:

.

# ~!.UEDDon Goodwin, EPA 2

My specific concerns are as follows: 1) The document does not reflect the constructive comments made by NAPCTACmembers. 2) The document does not reflect the advances made by EPA in their study of fugitive emission problems.**~a** collected:by Radian Corporation of numerous SOCMI plants has been entirtiL.!!eglected.

_ 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 ablock 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 aprofessional 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 taking the 1iberty to share these comments with other NAPCTAC members and sollicit their comments. Have a Merry Christmas and aHappy New Year. Very truly yours,

# 8e0~) W. M. Reiter Corporate Director Pollution Control /pab CC: 

### R. O. Blosser Dr. J. M. Lents 

### R. J. Castelli R. 

### A. Moon, Jr. 

### F. Dubro\'/ski 

### W. Reilly l:' H. Haskell B• 

### A. Steiner 

# ..

# .

... 

### E. Lemke I:. • 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 chernica1 

### manufacturing industry 

### (soon) to the extent these data had been received, cor.lOlled, and assessed in i-lay 1931, when 

### the draftdocu;:;entwas forwarded to the Office of

### r·1anaaenent and Budaet for rev;eVJ

### under Executive Order 12291. 

### SDecifica11.'1,

-

### you yJi11 

### note'thatTables 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 ofthese data sunported extrapolation from the petroleum refin;ns industry to the

## socrn**concernin~** 

### fugitive enissions from process equipment• DearBi11: JAN UNITED ST"

### -es ENVIRONMENTAL PROTECTION AG**~tr.** 

### W. M. Reiter Coroorate Director. Pollution Control CorPorate Environmental Affairs Allied Corporation PostOffice Box 2332R I,':err;stown, NewJersey 07960



### In response to your letterofDecember 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 

### drawyour attention to the following points. First, the draft CrG documentdoes reflectconstructive**co~nts** 

### made by**NP~CTAC** 

### menbers. For exan;;le, the preliminary draft CTG document discussed at the**r'~rch** 1931 

### r:hPCTACMeeting included amodel 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 documentyou received. t.1

### so, a nUr:Jber of

### the NAPCTACmeobers recomended that the CTG 

### document accor.1lTIOdate a1

### ternat;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 ofvalves leakina" as alternatives to**quarte~lyinspections.** 

### In'addition, the docur.1ent accor.r.iodates exer.tptions for**s~all** 

### process plants with less than ahundred valves in gas and/or lignt liquid service. (
,

# ::::~,**~'gJ:i::,,',:",',**

# :':,'' "','::1'":::::',:",::::.:::.:::..
....:
...'..

.... ::::::'.::::.:
....::.:::.::::::.,,:::::
..::::.,:•..:::
:JATE)-i ./'-:,}:.!! 

### I ,'. , I ,-

__ I

. . I2
Since**r-~y** 1931, additional SOCiU fugitive emission data have beem received and comoiled. While \'1e have not completed an assessment ofthese data, it does appear that some adjustment ofvarious emission factors included in the draft CTG documentmay be warranted to reflect differences beb/een the petroleumrefining industry and the**SOC~lI.** Currently, we plan to complete our assesswent ofthese data over the nextmonth 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, 

### ofcourse, be incorporated in the final 

### CTG documentwe develop. Third, your concern relative to the handling 

### of safety valves**hi~S** not been disregarded. As I mentioned in my letterof**~~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 reliefvalve. In this nanner, the process would :alv/ays have access to a safety reliefvalve.**Fourth~** 

### we do not think State or local air pollution control agencies 

### couldmisinterpret 

### 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 consistof 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 

## rhave 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,.;i11**r~vi** Ct-, your chaDte:r-by-chapter COl!1Ments carefully**w~en** they are received. He arpreciate your in-de:Jth review ofour'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. Reilly B. A. Steiner Don R. GOOdHin 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 CTGls 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,!! !!ethan0Iami ne s ,11 Phen0IsuIf0n i c acids ,II IIpolybute:1e 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., lIacrylic 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

# s h0uId be revised using' the S0C\1I database sothat 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 Resin 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 ChemicaIs Manufacturing Industry are not of large anough magnitude to warrant such extensive documentation and control. These· emlssions are by nature de minimis. The guidelines propose over-regulation of these emissions.**Regulc~ions** to**~educs** such emissions I if necess2.r:" I s::'culd esTe.::L**s~** clear-::u! objectives and specify reduction requiremems. The**mec:::~s** :0 achieve t:-1C reduction should be an industry decision.

, The cost estimate in the guidelinesis not valid. It is based on a 10 percent interest rate, which is unrealistic in the present market. The labor cost based on "wages 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-11i,':..r. r• L. l"orter jam.:.ery 1'1 t 1982 

### rags 2

in SOCMI. The cost of a valve does not increase linearly as the size I but sxponentia11y. Also I the majority of valves 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 JOHNJ MOON Manager. Etwlronment.andConsumerProtection

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 Ax 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.** ASOCMI 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 re**pa~~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

8-14AirProductsandChemicals" Inc. Box538,Allentown, PA,e'05**(2'5)4S'·~9'** 1

11 January 1982

Mr; Fred 

### l. Porter EmissionStandards and Engineering Div. (MD-13) EPA ResearchTriangle Park, NC 27711 , DearMr. 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 onthis draft. This draft,is a useful attempt to provide guidance to regulatory bodies which are establishing rules on fugitive emissions. Itassumes thatthese regulations will be prepared, but it'does notfurnish guidance as towhichtype ofemissions 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 lastyear. 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 disparity of the two ;ndustries. II} brief, chemica1 plants are sma11er,
. operate at lowertemperatures andpressures, andprocess 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 refinery ;ndustry. You ha\!e data on many chernica1 operatiens (see the EPA;450/3-S0-028 series, for example) and should attempt to apply as accurate cata as possible, ratherthan 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 ofasubstance usually increases as the equipment size decreases. Thus, the operator has a strong economic incentive not to lose the material. Acost-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, butofthe refinery industry. We support the concept ofthe 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 otherarbitrary values ofi andm. In regard to the 2% figure as an index of comp1iance (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 flexibi1ity shauld be a11owed for this factor. Similarly, it would help the regulator to have some further illustrations of the quantitative effectofalternate repairtimes (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 andexcessive leakrates wouldbe 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 ofthese 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 ifyou have any questions regarding these comments and

Very trulyyours, AIR PRODUCTS AND**CH~CA7LS**I INC.



# a/**~"IV** .,.v--I- -Z/ /1'

### /~ Jo T ,Barr

# Re~ tory Response

.'

8-16Attention 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.:1'1ic**Ch~rni_ca** 1 Hanufacturir:g Industry (soon) tlncontrolled fugitive 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.ption 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 Guideline 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 27711Emission 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 fugitive 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 concentration of 10,000 ppmv or greater should be considered 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 effective 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 emissions 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 Aon 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 basis 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 ofEastman Kodak Company af

-8-19THE 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.

8-20Inaccessible 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,

# (j}1J-~ Allen R. Ellett Environmental Specialist
ARE/dmb

"8-22Attention: Mr. Fred Porter Dear Mr. Porter:**~B-23** Chemical Vinyl Chloride 3520 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!jch**  Company Chern/eelGrOIJ;." 6',0:00>'Treeooulevcrd**C;e\'e::::~c.** Ohio**~4131**

1**6.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**

8-241000SRAZOS, SUITE200.AUSTIN,TEXAS78701-2476. (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. EQUIPMENTLDATED 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 petroleumrefineries 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, petroleumrefiniIlg 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). Also0 ,**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)

. . ,- " ,\- - . ... d (R" 3 " 7) i T '9°'**~n** May**~~o~.** ana**tne·.~.a~ys~s ~tu**  yeI. ,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 Care identified as Small, Medium, and Lar2e Model Planes.

II. Is ACTG 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 200C. 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

8-31REFERENCES 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 Bplant (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.
8-3-2May 17 t °1979

February 1, 1980

June 30t 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 FromH. 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 FromH. 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 FORMODEL 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