P.1 

OAR Box 1338 

Prepped by Ollie Stewart 

Document Number: 

1)11-1-1 

Docket Number: 

A-89-10 

Printed 6/17/2008 1:48:05 PM Sheet 1 of 105 
P.2 

oft?*.*** A-89-10 

,^&^#Anniversary 

II-I-I 

e o 5 P OR " T I o M P.O. Box 201088 

DCN 89-259-038-02 

RCN 259-038-05-01 

FIELD STUDY: ESTIMATING FUGITIVE 

EMISSIONS FROM THE ETHYLENE OXIDE 

PRODUCTION INDUSTRY 

FINAL REPORT 

Austin, TX 78720-1088 

(512)454-4797 

K.M B 0 ff i 

Wl 141001 

' d • <.' ' '" • """ ^ -* T f 

O.f) i 'A \r\r\\ >l''; 

i i . 

Prepared for: 

The Ethylene Oxide Industry Council of 

the Chemical Manufacturers Association 

Prepared by: 

John Randall 

Graham Harris 

Sharon Wevill 

Radian Corporation 

Austin, Texas 

April 1989 
P.3 

TABLE OF CONTENTS 

Page 

Glossary x 

1.0 EXECUTIVE SUMMARY :. 1-1 

2.0 INTRODUCTION AND OVERVIEW 2-1 

2.1 Definition of Fugitive Emissions 2-1 

2.2 Critical Studies of Fugitive Emissions 2-2 

2.3 Previous and Impending Concern with Fugitive Emissions 2-3 

3.0 ETHYLENE OXIDE PRODUCTION AND USE 3-1 

3.1 Ethylene Oxide: The Chemical 3-1 

3.2 Overview of Production and Use 3-1 

3.2.1 Air-Based Oxidation 3-2 

3.2.2 Oxygen-Based Oxidation 3-4 

3.3 Production and Use 3-8 

4.0 MONITORING APPROACH 4-1 

4.1 Overview of Methods Used to Estimate Fugitive Emissions 4-1 

4.1.1 SOCMI Average Emission Factor 4-3 

4.1.2 Screening Test 4-3 

4.1.3 Leak/No Leak Method 4-4 

4.1.4 Stratified Method 4-4 

4.1.5 Correlation Equations 4-6 

4.1.6 Bagging 4-8 

4.1.7 Current Study 4-9 

4.2 Screening Techniques 4-10 

4.3 Calibration 4-11 

4.4 Screening Protocol 4-12 

ii 
P.4 

TABLE OF CONTENTS (Continued) 

4.5 EO Workbook 4-13 

4.5.1 Ethylene Oxide Screening Survey Report Form.... 4-14 

4.5.2 Calibration Data Sheet for Ethylene Oxide 

Screening 4-17 

4.5.3 Drift Test Data Sheet for Ethylene Oxide 

Screening 4-18 

4.6 Quality Control Results 4-18 

5.0 DATA ANALYSIS. 5-1 

5.1 Converting Raw OVA Values to EO-Specific Emission 

Estimates 5-1 

5.2 Summary of Components Studied 5-9 

5.3 Emissions By Component Type and Service Category 5-20 

5.3.1 Valves in Liquid Service 5-28 

5.3.1.1 Screening Measurements 5-28 

5.3.1.2 Emission Estimates 5-33 

5.3.1.3 Plant-Specific Analysis 5-33 

5.3.1.4 Summary 5-38 

5.3.2 Valves in Gas Service 5-39 

5.3.2.1 Screening Measurements 5-39 

5.3.2.2 Emission Estimates 5-43 

5.3.2.3 Plant-Specific Analysis 5-43 

5.3.2.4 Summary 5-49 

5.3.3 Flanges 5-50 

5.3.3.1 Screening Measurements 5-50 

5.3.3.2 Emission Estimates 5-54 

5.3.3.3 Plant-Specific Analysis 5-54 

5.3.3.4 Summary 5-60 

5.3.4 Open-Ended Lines 5-60 

5.3.4.1 Screening Measurements 5-60 

5.3.4.2 Emission Estimates 5-64 

5.3.4.3 Plant-Specific Analysis 5-64 

5.3.4.4 Summary 5-69 

5.3.5 Pumps.. 5-69 

5.3.5.1 Screening Measurements 5-69 

5.3.5.2 Emission Estimates 5-74 

5.3.5.3 Plant-Specific Analysis 5-74 

5.3.5.4 Summary 5-79 

Iii 
P.5 

TABLE OF CONTENTS (Continued) 

Page 

5.3.6 Safety Valves 5-79 

5.3.6.1 Screening Measurements 5-81 

5.3.6.2 Emission Estimates 5-81 

5.3.6.3 Plant-Specific Analysis 5-81 

5.3.6.4 Summary 5-88 

5.3.7 Sealed Flanges 5-88 

5.3.7.1 Screening Measurements 5-88 

5.3.7.2 Emission Estimates 5-88 

5.3.7.3 Plant-Specific analysis 5-90 

5.3.7.4 Summary 5-90 

5.3.8 Sample Points 5-93 

5.3.9 Compressors 5-93 

5.4 Bagging Study. 5-98 

6.0 ETHYLENE OXIDE WORK PRACTICES, OPERATING PROCEDURES, AND 

DESIGN GUIDELINES 6-1 

7.0 REFERENCES 7-1 

APPENDIX 1 

APPENDIX 2 

APPENDIX 3 

APPENDIX 4 

EPA METHOD 21 

ETHYLENE OXIDE FUGITIVE EMISSION MONITORING PROTOCOL 

INDIVIDUAL PLANT SUMMARY DATA TABLES 

EOIC FUGITIVE EMISSION SURVEY 

iv 
LIST OF FIGURES 

Page 

1-1 Locations of Ethylene Oxide Production Facilities 1-4 

1-2 EO Production Facilities: Distribution of Components by 

Screening Values 1-6 

1-3 Comparison of Leak Frequencies: EO Production Facilities Versus 

SOCMI 24-Unit Study 1-7 

1-4 EO Fugitive Emission Study: Contribution of Five Largest Source 

Categories to Total Fugitive Emissions From EO Production 

Facilities Using EO Emission Factors 1-12 

1-5 Ethylene Oxide Fugitive Emission Study: Contribution of Five 

Largest Source Categories to Total Fugitive Emissions From EO 

Production Facilities Using EO or SOCMI Fugitive Emission 

Factors 1-14 

3-1 Schematic of Air-Based Direct Oxidation Process for the 

Production of Ethylene Oxide 3-3 

3-2 Schematic for Oxygen-Based Direct Oxidation for Production of 

Ethylene Oxide 3-6 

4-1 Overview of Fugitive Emission Estimation 4-2 

4-2 Example Screening Data Report Form 4-15 

4-3 Example Calibration Reporting Form 4-19 

4-4 Example Drift Test Report Form. 4-20 

5-1 EOIC/EPA Fugitive Emission Study: EO Production Facilities 

Distribution of Components Sampled 5-11 

5-2 EOIC/EPA Fugitive Emission Study: EO Production Facilities 

Distribution of Equipment by EO Concentration in Line 5-13 

5-3 EO Production Facilities: Distribution of Components by 

Screening Value 5-16 

5-4 EOIC/EPA Fugitive Emission Study: Distribution of EO Screening 

Values for All Liquid Valves 5-30 

5-5 EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for Liquid Valves by EO Concentration 5-31 

5-6 EOIC/EPA Fugitive Emissions Study: Distribution of Liquid Valves 

Sampled by EO Concentration 5-32 
-

EJ—i 

LIST OF FIGURES (Continued) 

Page 

5-7 EOIC/EPA Fugitive Emissions Study: Comparison of Emission Factors 

to EO Concentrations Using Different Calculational Approaches 

for Valves in Liquid Service 5-35 

5-8 EOIC/EPA Fugitive Emissions Study: Comparison Between Twelve 

Plants Studied Using Different Calculation Approaches Average 

Emission Factors for Valves in Liquid Service 5-37 

5-9 EOIC/EPA Fugitive Emission Study: Distribution of EO Screening 

Values for all Gas Valves 5-40 

5-10 EOIC/EPA Fugitive Emission Study: Distribution of Screening 

Values for Gas Valves by EO Concentration 5-42 

5-11 EOIC/EPA Fugitive Emission Study: Distribution of Gas Valves 

Sampled by EO Concentration all Components and "Leakers" 5-44 

5-12 EOIC/EPA Fugitive Emission Study: Comparison of Emission Factors 

To EO Concentration Using Different Calculational Approaches for 

Valves in Gas Service 5-46 

5-13 EOIC/EPA Fugitive Emission Study: Comparison Between Twelve 

Plants Studied Using. Different Calculation Approaches Average 

Emission Factors for Valves in Gas Service 5-48 

5-14 EOIC/EPA Fugitive Emission Study: Distribution of Screening 

Values for all Flanges by EO Concentration 5-51 

5-15 EOIC/EPA Fugitive Emission Study: Distribution of Screening 

Values for Flanges by EO Concentration 5-53 

5-16 EOIC/EPA Fugitive Emission Study: Comparison of Emission Factors 

to EO Concentration Using Different Calculational Approaches For 

Flanges 5-55 

5-17 EOIC/EPA Fugitive Emissions Study: Comparison of Emission Factors 

to EO Concentration Using Different Calculational Approaches for 

Flanges 5-57 

5-18 EOIC/EPA Fugitive Emissions Study: Comparison Between Twelve 

Plants Studied Using Different Calculational Approaches Average 

Emission Factors For Flanges 5-59 

5-19 EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for All Open-Ended Lines 5-61 

5-20 EOIC/EPA Fugitive Emissions Study: Distribution of Open-Ended 

Lines Sampled by EO Concentration 5-63 

vi 
P.8 

LIST OF FIGURES (Continued) 

Page 

5-21 EOIC/EPA Fugitive Emissions Study: Comparison of Emission 

Factors to EO Concentration Using Different Calculational 

Approaches for Open-Ended Lines 5-66 

5-22 EOIC/EPA Emissions Study: Comparison Between Twelve Plants 

Sampled Using Different Calculational Approaches Average 

Emission Factors for Open-Ended Lines. 5-68 

5-23 EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for All Pumps 5-70 

5-24 EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for Pumps by EO Concentration 5-72 

5-25 EOIC/EPA Fugitive Emissions Study: Distribution of Pumps 

Sampled by EO Concentration: All Components and "Leakers" 5-73 

5-26 EOIC/EPA Fugitive Emissions Study: Comparison of Emission Factors 

to EO Concentration Using Different Calculational Approaches for 

Pumps 5-76 

5-27 EOIC/EPA Fugitive Emissions Study: Comparison Between Twelve 

Plants Studied Using Different Calculational Approaches Average 

Emission Factors for Pumps 5-78 

5-28 EOIC/EPA Fugitive Emissions Study: Distribution of Safety Relief 

Valves Sampled by EO Concentration 5-80 

5-29 EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for All Safety Valves 5-83 

5-30 EOIC/EPA Fugitive Emissions Study: Comparison of Emission Factors 

to EO Concentration Using Different Calculational Approaches For 

Safety Relief Valves 5-85 

5-31 EOIC/EPA Fugitive Emissions Study: Comparison Between Twelve 

Plants Sampled Using Different Calculation Approaches Average 

Emission Factors for Safety Relief Valves 5-87 

vii 
P.9 

LIST OF TABLES 

Page 

1-1 Ethylene Oxide Production Plants 1-3 

1-2 Emission Factors for EO Production Facilities Compared With 

Average SOCMI Factors (lb/hr/source) 1-9 

1-3 Summary of Nameplate Capacity and Estimated EO Fugitive Emissions 

From EO Production Facilities 1-11 

3-1 Ranges of Reaction System Variables in the Direct Air Oxidation 

of Ethylene Oxide 3-5 

3-2 Ranges of Reaction System Variable in the Direct Oxygen-OxIdation 

of Ethylene Oxide 3-7 

4-1 EPA Emission Factors in lb/hr/source 4-5 

4-2 Fugitive Emissions Correlation Equations 4-7 

4-3 Summary of Calibration and Drift Test Results 4-21 

5-1 Organic Solvent and Response Factors 5-3 

5-2 Summary of EO Components Studied 5-10 

5-3 Distribution of Components by EO Concentration 5-12 

5-4 Distribution of Raw OVA Screening Values by EO Concentration for 

All Plants and All Components 5-15 

5-5 Distribution of Components by Flaw OVA Screen Value for all Plants 

All Components and All EO Concentrations 5-17 

5-6 Summary of Estimated Ethylene Oxide Fugitive Emission Factors 

For All Plants: Emission Factor Estimates for All Components... .5-19 

5-7 Comparison of OVA Screen Values from this EO Study with those 

Estimated From SOCMI Factors 5-21 

5-8 Summary of Estimated Ethylene Oxide Fugitive Emissions Factors 

For All Participating Plants: Emission Factor Estimates for 

Components with EO Concentration Between IX and 2X 5-22 

5-9 Summary of Estimated Ethylene Oxide Fugitive Emissions Factors 

For All Participating Plants: Emission Factor Estimates for 

Components with EO Concentration Between 2X and 5Z 5-23 

viii 
P.10 

LIST OF TABLES (Continued) 

£&££ 

5-10 Summary of Estimated Ethylene Oxide Fugitive Emission Factors 

For All Participating Plants: Emission Factor Estimates For 

Components With EO Concentration Between 5X and 10Z 5-24 

5-11 Summary of Estimated Ethylene Oxide Fugitive Emission Factors 

For All Participating Plants: Emission Factor Estimates for 

Components with EO Concentration Between 10X and 50X 5-25 

5-12 Summary of Estimated Ethylene Oxide Fugitive Emission Factors for 

All Participating Plants: Emission Factor Estimates for 

Components with EO Concentration Between 50X and 95X 5-26 

5-13 Summary of Estimated Ethylene Oxide Fugitive Emissions Factors 

For All Participating Plants: Emission Factor Estimates For 

Components with EO Concentration Between 95X and 100X 5-27 

5-14 Distribution of Raw OVA Screening Values by EO Concentration For 

Valves in Liquid Service 5-29 

5-15 Distribution of Estimated Fugitive Emission Factors by EO 

Concentration: Emission Factor Estimates for Valves in Liquid 

Service 5-34 

5-16 Comparison of Mean Emission Factors for Valves in Liquid Service 

For Each Plant 5-36 

5-17 Distribution of Raw OVA Screening Values by EO Concentration for 

Valves in Gas Service 5-41 

5-18 Distribution of Estimated Fugitive Emission Factors by EO 

Concentration: Emission Factor Estimates for Valves in Gas 

Service 5-45 

5-19 Comparison of Mean Emission Factors for Valves in Gas Service 

for Each Plant 5-47 

5-20 Distribution of Raw OVA Screening Values by EO Concentration 

for Flanges 5-52 

5-21 Distribution of Estimated Fugitive Emission Factors by EO 

Concentration: Emission Factor Estimates for Flanges 5-56 

5-22 Emission Factors for Flanges for Each Plant Mean Emission 

Factor (All Valves in lb/hr/source) 5-58 

5-23 Distribution of Raw OVA Screening Values by EO Concentration 

for Open-ended Lines 5-62 

ix 
P.11 

LIST OF TABLES (Continued) 

Page 

5-24 Distribution of Estimated Fugitive Emission Factors by EO 

Concentration: Emission FActor Estimates for Open-ended Lines.. 5-65 

5-25 Emission Factors for Open-ended Lines for Each Plant Mean 

Emission Factor Using the Method Listed (lb/hr) 5-67 

5-26 Distribution of Raw OVA Screening Values by EO Concentration 

for Pumps 5-71 

5-27 Distribution of Estimated Fugitive Emission Factors by EO 

Concentration: Emission Factor Estimates for Pumps 5-75 

5-28 Emission Factors for Pumps for Each Plant: Mean Emission 

Factor Using the Method Listed (lb/hr) 5-77 

5-29 Distribution of Raw OVA Screening Values by EO Concentration 

for Safety Valves 5-82 

5-30 Summary of Estimated Ethylene Oxide Fugitive Emission Factors 

for All Participating Plants: Emission Factor Estimates for 

Safety Valves 5-84 

5-31 Emission Factors for Safety Valves for Each Plant: Mean 

Emission Factor Using the Method Listed (lb/hr) 5-86. 

5-32 Distribution of Raw OVA Screening Values by EO Concentration 

for Sealed Flanges : 5-89 

5-33 Distribution of Estimated Fugitive Emission Factors by EO 

Concentration Emission: Factor Estimates for Sealed Flanges 5-91 

5-34 Emission Factors for Sealed Flanges for Each Plant: Mean 

Emission Factor Using the Method Listed (lb/hr) 5-92 

5-35 Distribution of Raw OVA Screening Values by EO Concentration 

for Sample Points 5-94 

5-36 Distribution of Estimated Fugitive Emission Factors by EO 

Concentration: Emission Factor Estimates for Sample Points 5-95 

5-37 Distribution of Raw OVA Screening Values by EO Concentration 

for Compressors 5-96 

5-38 Distribution of Estimated Fugitive Emission Factors by EO 

Concentration: Emission Factor Estimates for Compressors 5-97 

5-39 Summary of Ethylene Oxide Default Zero Bagging Study Results.... 5-100 
P.12 

GLOSSARY 

CMA 

Component 

Correlation Equation 

Default Zero Emission 

Factor 

Default Zero 

Screening Value 

EOIC 

EPA 

Emission Factor 

Heavy Liquid 

High Emitters 

Leak Definition 

Leak Rate 

Leaking Emission 

Factor 

Leaking Source 

Light Liquid 

Chemical Manufacturers Association 

A specific piece of process equipment such as a valve, 

flange, pump, compressor, safety relief valve, etc. 

The equation needed to convert screening values to 

mass emission factors: developed by EPA from field 

data obtained during various fugitive emission 

studies. 

The emission factor associated with a zero screening 

value. 

The screening value back calculated from the zero 

emission factor default using the appropriate 

correlation equation. 

Ethylene Oxide Industry Council • a special program 

panel of the CMA consisting of representatives from 

producers and users of ethylene oxide. 

United States Environmental Protection Agency 

The per component mass emission rate applicable to 

populations of sources, not individual component 

measurements. 

A process liquid with a vapor pressure < 0.04 psia at 

20'C. 

Components with screening values between 1,000 and 

9,999 ppm. 

The monitoring instrument reading selected as the 

trigger value for beginning some action, such as 

maintenance; e.g., 10,000 ppmv is the leak definition 

used by EPA. 

See Mass Emission Rate. 

The per component mass emission rate associated with 

the population of sources with screening values at or 

above the leak definition. 

A source whose screening value is greater than or 

equal to 10,000 ppmv. 

A process liquid with a vapor pressure £0.04 psia at 

20° C. 

xi 
P.13 

Low Emitters 

Mass Emission Rate 

Components with screening values between 100 and 999 

ppm. 

The quantity of volatile organic compound(s) released 

to the atmosphere in terms of total mass per unit 

time. 

Monitoring Instrument 

Non-emitting Source 

Screening Value 

SOCMI 

SOCMI Factors 

Portable hydrocarbon analyzer meeting the performance 

specifications given in Method 21. 

A source whose screening value is less than 10 ppm. 

Monitoring instrument reading generally given in 

concentration units; e.g., ppmv. "* 

Synthetic Organic Chemical Manufacturing Industries. 

Fugitive emission factors developed by EPA for SOCMI 

in 1983. 

Very Low Emitters 

Weighted Average 

Components with screening values between 10 and 99 

ppm. 

The value for each ethylene oxide concentration range 

"weighted" by the number of components in that range. 

The total number of components in the screening value 

range expressed as a percentage of the total number of 

components in all ranges. 

xii 
P.M 

1.0 EXECUTIVE SUMMARY 

The Ethylene Oxide Industry Council (EOIC) initiated this study in 

response to two recent developments. The first was passage of the Superfund 

Amendments Reauthorization Act (SARA) Title III, which required certain 

manufacturers, processors, and users of ethylene oxide (EO) and 300 other 

chemicals to annually report any releases of these chemicals to the 

environment, including air emissions from fugitive and point sources. The 

second influencing development was the U.S. Environmental Protection Agency's 

(EPA) announcement that they were considering establishing a National Emission 

Standard for Hazardous Air Pollutants (NESHAP) for a group of compounds, 

including EO. 

The EOIC believes that the results of the present study can be used 

to provide a better industry-wide estimate of fugitive emissions from ethylene 

oxide (EO) production facilities. When originally estimating air emissions of 

ethylene oxide for the NESHAP regulation, the EPA concluded that a substantial 

fraction was associated with fugitive emissions. These fugitive emission 

estimates were generated from factors developed for refineries (1) and for the 

entire Synthetic Organic Chemical Manufacturing Industry (SOCMI) (2,3). These 

estimates have been acknowledged to be inappropriate for EO because they 

overstate EO fugitive emissions. Both the EOIC and EPA believed that a 

regulation designed to protect the public health should be based on the best 

scientifically- supportable estimates of emissions and that such estimates 

could only come from a complete industry-wide survey. EPA prepared a draft 

protocol (see Appendix 2) that could be used to estimate the emissions of a 

specific chemical resulting from equipment leaks in a specific process unit. 

Fugitive emissions are a category of emissions that represent lowlevel volatile organic compound (VOC) emissions that result from leaks of 

process fluid (either gaseous or liquid) from plant equipment such as valves, 

flanges, pumps, safety valves, and compressors. Because a typical chemical 

process unit may contain thousands of pieces of such equipment, fugitive 

emissions must be considered in any complete emission assessment. 

1-1 
P.15 

Previous studies funded by the US EPA have focused on fugitive 

emissions from refineries (1) and SOCMI (2,3). Although often criticized 

because of their high prediction of emissions for many organic processes, the 

SOCMI fugitive emissions factors continue to be widely used by the EPA in 

promulgating New Source Performance Standards (NSPS), in Control Technology 

Guidelines (CTG) for both the refining and the organic chemical industries, 

and in NESHAPs for specific hazardous air pollutants. 

In December of 1987, members of the EOIC, in cooperation with the 

EPA, decided to conduct fugitive emissions testing at all the EO production 

facilities in the United States. The EOIC contracted Radian Corporation to 

develop the testing procedures, oversee the testing effort conducted by member 

companies, analyze the data, and generate this final report. 

The 12 participants in this study (see Table 1-1 and Figure 1-1) 

included all domestic producers of ethylene oxide in operation at the time of 

the study. The units were sampled during different stages of their operating 

and maintenance cycles. Some units were screened just before a maintenance 

shutdown, some were screened just after completion of a leak-detection and 

repair program, and some were screened just after startup following a 

scheduled maintenance shutdown. There were no special maintenance procedures 

performed prior to or during this study. The EOIC believes that the average 

EO emission factors generated in the 1988 study and summarized in this report, 

are more representative of the fugitive emissions of the total EO production, 

industry than those estimated previously using average SOCMI factors. 

Screening data were obtained from each of the twelve production 

facilities involved in the study. A total of 18,227 components were included 

in the data submitted, of which 664 (less than 4 percent) were listed as 

inaccessible. Of the 17,563 components for which screening data were 

received, 47 percent were valves in liquid service, 19 percent were valves in 

gas service, 27 percent were flanges, sealed flanges, or connectors, and 4 

percent were open-ended lines. The remaining components sampled (2 percent) 

1-2 
P.16 

TABLE 1-1. ETHYLENE OXIDE PRODUCTION PLANTS 

Producer Location 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

Shell Chemical 

Hoechst-Celanese 

PD Glycol (CAIN) 

Dow Chemical 

Union Carbide 

Union Carbide 

Cain Chemical 

Quantum 

Texas Eastman 

Sun R&M 

BASF 

Texaco Chemical 

Geismar, LA 

Clear Lake, TX 

Beaumont, TX 

Plaquemine, LA 

Seadrift, TX 

Taft, LA 

Bayport, TX 

Morris, IL 

Longview, TX 

Claymont, DE 

Geismar, LA 

Port Neches, TX 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMAR 1988, 

1-3 
I 

Vi 

5 .- 12^V* 

1,4,6,11 

Figure 1-1. Locations of Ethylene Oxide Production Facilities 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.18 

included pumps, safety valves, sample points, and compressors. The study 

participants agreed to sample all accessible components except for flanges. 

Approximately one-quarter of the flanges were sampled. 

Fifty-five percent of the components sampled were on lines 

containing greater than 95 percent EO. The remaining components were almost 

equally distributed among lines containing 1 to 2 percent EO (10X), 2 to 10 

percent EO (11X), 10 to 50 percent EO (12X), and 50 to 95 percent EO (12X). 

Screening p<-t?a 

Screening data were collected during the second and third quarters 

of 1988, using an Organic Vapor Analyzer (OVA) and following a standard 

protocol (Appendix 2) approved by all participants, as well as guidelines 

presented in a Workbook prepared by Radian Corporation (4). 

The screening measurements obtained in this study are summarized in 

Figure 1-2. Overall, about 87 percent of the components monitored had 

screening measurements less than 10 ppm, 10 percent were measured at between 

10 and 99 ppm, and 2 percent were between 100 and 9999 ppm. About 0.6 percent 

(102 out of 17,563) of the components screened in this study would be 

classified as 'Leakers.' having OVA screening measurements greater than 10,000 

ppm. None of the sample points, safety valves, or compressors, and only 0.1 

percent of the liquid valves, were found to be leaking, but 1.2 percent of the 

open-ended lines, 1.2 percent of the gas valves, and 4.2 percent of the pumps 

were leaking. Figure 1-3 compares the percentage of leakers found in this 

study to that observed in the original SOCMI 24-Unit study. The number of 

leaking components in every category observed in this study was lower than 

previously found in the SOCMI 24-Unit study, but the difference was most 

significant for liquid valves (0.1 percent versus 6.5 percent). 

The components in low concentration EO service (1 to 2 percent EO), 

which represented fewer than 10 percent of the components sampled, accounted 

for over half (54 out of 102) of the leaking components found in this study. 

1-5 
P.19 

86. 9 y. 

10.3 Z 

< 10 ppm 

y

////A 10-99 ppm 

^SS l 100-999 ppm 

1000-9999 ppm 

>10.000 ppm 

Figure 1-2. EO Production Facilities: Distribution of Components 

by Screening Values 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

1-6 
P.20 

P 

E 

R 

C 

E 

N 

T 

L 

E 

A 

K 

E 

R 

S 

LIQUID GAS SAFETY SAMPLE PUMPS OPEN-END FLANGES COMPRESS 

VALVES VALVES VALVES POINTS LINES 

COMPONENT TYPE 

• • EO UNITS 

V////A 24-UNIT STUDY 

Figure 1-3. Comparison of Leak Frequencies: EO Production Facilities 

Versus SOCMI 24-Unit Study. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988, 

1-7 
P.21 

Emission Estimates 

Estimates of fugitive emissions were calculated from the screening 

data submitted by the 12 EO Producers using the following six methods: 

SOCMI Average Emission Factors; 

SOCMI Leak/No Leak Emission Factors; 

SOCMI Stratified Emission Factors; 

EPA Correlation Equations (EPA default value of 8.17 ppm); 

EPA Correlation Equations (default value of 0 ppm); and 

EPA Correlation Equations (EOIC default values). 

Several participants in this study quantified the leak rates from 

valves in liquid service, valves in gas service, and flanges that had very low 

screening values (near the detection limit) by enclosing the component and 

collecting and analyzing a purge gas stream. New EO-specific default values 

were then developed from these bagging tests for use in the EPA Correlation 

Equations. 

Using the screening data obtained in this study, a new set of EOspecific fugitive emission factors were developed for the components present 

in an EO production facility. These data are presented in Table 1-2, along 

with the average EO/VOC ratio, the average EPA SOCMI Factors and the X 

reduction for each new factor. 

It is important to note that the EOIC Emission Factor represents 

only ethylene oxide emissions from the components in this study. To be 

comparable to the Average SOCMI factor, other VOC emissions should also be 

considered. The concentrations of other VOCs in the streams sampled were 

generally very low and varied for the different component categories. Few of 

the emitting components contained any VOC other than ethylene oxide. The 

ratio of EO to total VOC is shown in Table 1-2 for each component type. This 

varies from 0.778 for valves in gas service to 1.000 for sample points. The 

EOIC emission factors reported in Table 1-2 represent roughly 90 percent of 

the total VOC emissions from sampled components. 

1-8 
P.22 

TABLE 1-2. EMISSION FACTORS FOR EO PRODUCTION FACILITIES COMPARED WITH 

AVERAGE SOCMI FACTORS (LB/HR/SOURCE) 

Component 

Liquid Valves 

Gas Valves 

Safety Valves 

Sample Points 

Pumps 

Open-Ended Lines 

Flanges 

Compressors 

Weighted Average6 

NET Emissions" 

Mean 

EO/VOC Ratio 

0.988 

0.778 

0.920 

1.000 

0.998 

0.894 

0.935 

9.931 

0.932 

Average SOCMI 

Factor 

0.01560 

0.01230 

0.22900 

0.00370 

0.10900 

0.00370 

0.00183 

9,59299 

0.00810 

100X 

EOIC 

Factor 

0.000550 

0.000444 

0.000165 

0.000088 

0.042651 

0.001078 

0.000555 

o,999767 

0.000806 

10X 

Reduction 

(X)' 

96.5 

96.4 

99.9+ 

76.2 

60.9 

70.9 

69.7 

99.8 

• Reduction calculated from: 

X Reduction - SQCM I Va]_ue * 100 

Calculation of the Weighted Average and net emissions was based on the 

actual distribution of components screened in this study, assuming that 

about 25 percent of the flanges were actually sampled (this corresponds to 

a flange-to-valve ratio of 1.6). 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

1-9 
Several significant conclusions can be drawn from this analysis. 

For both gas valves and liquid valves, the EOIC Emission Factor is 28 times or 

96.5X lower than the corresponding EPA SOCMI factor. These components 

represented roughly two-thirds of the total number of components sampled. The 

EOIC Emission Factor for Safety Valves was a factor of 1400 or 99.9+X less 

than the SOCMI factor, and the EOIC Emission Factor for Compressors was equal 

to a factor of 600 or 99.8+X less than the average SOCMI Factor. EOIC 

Emission Factors and SOCMI Emission Factors for some of the other components 

were much closer. For example, for pumps, flanges, and open-ended lines, EOIC 

Emission Factors were equal to 61 percent, 70 percent, and 71 percent, 

respectively, lower than the average SOCMI Emission Factors. The average EOIC 

Emission Factor for flanges was comparable to EOIC Emission Factors for gas 

and liquid valves. 

Overall, the emissions from a typical ethylene oxide production 

facility, calculated using the EOIC Emission Factors, are equal to almost 

exactly ten percent of the emissions estimated using the average SOCMI 

Emission Factors. The estimated EO fugitive emissions for the units 

participating in this study, based on these new EOIC emission factors, are 

summarized in Table 1-3. 

Distribution of Emissions 

Figure 1-4 shows the major contributors to fugitive emissions in a 

typical EOIC Production Facility. The single largest source of fugitive 

emissions in a typical EO Production Facility is leaking pumps (pumps with 

screening values above 10,000 ppm). Only eight leaking pumps were found in 

the present study, yet they account for 30 percent of the total EO emissions. 

Flanges, which represent about 60 percent of the total number of components in 

an EOIC facility, accounted for 40 percent of the total emissions. Overall, 

leaking equipment accounted for about 70 percent of the total emissions 

measured in this study. 

1-10 
P.24 

TABLE 1-3. SUMMARY OF NAMEPLATE CAPACITY AND ESTIMATED EO FUGITIVE EMISSIONS 

FROM EO PRODUCTION FACILITIES 

Plant Name 

Shell Chemical 

Hoescht-Celanese 

PD Glycol (Cain) 

Dow Chemical 

Union Carbide 

Union Carbide 

CAIN Chemical 

Quantum 

Texas Eastman 

Sun R & M 

BASF 

Texaco Chemical 

Location 

Geismar, LA 

Clear Lake, TX 

Beaumont, TX 

Plaquemine, LA 

Seadrift, TX 

Taft, LA 

Bayport, TX 

Morris, IL 

Longview, TX 

Claymont, DE 

Geismar, LA 

Port Neches, TX 

Nameplate 

Production 

Capacity 

(Thousands 

of Metric 

Tons/Year) 

363'-b 

227c 

68' 

204c 

286' 

572* 

204' 

100c 

97' 

55c 

218' 

318c 

EOIC 

Estimated EO 

Fugitive 

Emissions 

(Tons/Year) 

14d 

13* 

4* 

3 

9

d 

10d 

lld 

4* 

9' 

5' 

9' 

14* 

* Reference 5 

b One of two production units out of service at the time of this study. 

e Data obtained directly from producing plant personnel. 

d Based on a stream factor of 95X and an estimated flange count equal to 1.6 

times the number of valves tested (6). 

* Based on a stream factor of 95X and an actual flange count obtained from 

the plant. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988, 

1-11 
P.25 

FLANGES PUMPS LIQUID GAS OPEN-END 

VALVES VALVES LINES 

COMPONENT TYPE 

Total Emissions - 10 : of SOCMI 

Estimates based on a flanga/valve ratio of 1.6 

Figure 1-4. EO Fugitive Emission Study: Contribution of Five Largest Source 

Categories to Total Fugitive Emissions from EO Production 

Facilities Using EO Emission Factors. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

1-12 
P.26 

In the SOCMI 24-Unit Study, the largest source of fugitive emissions 

was leaking valves, which accounted for 40 percent of the total estimated 

SOCMI fugitive emissions. Figure 1-5 compares expected emissions estimated in 

the SOCMI 24-Unit Study with those found in the present study for the five 

major component types. Again, the total emissions from these EOIC facilities 

is about 10 percent of those estimated using the available SOCMI Emission 

Factors. 

Recommendations 

The EOIC believes that the results of this study are the best 

estimate of fugitive emission from the EO production industry. The EOIC 

recommends that the results of the present study be used for any future EO 

Risk Assessment that requires quantification of EO fugitive emissions, and 

that these results serve as the starting point for any possible emission 

reduction programs. 

1-13 
I 

I—' 

£SSS] Al l Other 

<<1. OOO ppm) 

Z?/777\ Hig h Emitter s 

C>1. OOO ppm) 

Laahgr s 

<>10. OOO ppm) 

LIQUID 

VALVES 

GAS 

VALVES 

FLANGES SAFETY 

VALVES 

PUMPS 

COMPONENT TYPE 

Figure 1-5. Ethylene Oxide Fugitive Emission Study: Contribution of 

Five Largest Source Categoreis to Total Fugitive Emissions 

From EO Production Facilities Using EO Or SOCMI Fugitive 

Emission Factors 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.28 

2.0 INTRODUCTION AND OVERVIEW 

This document summarizes the results of fugitive emissions testing 

conducted by members of the Ethylene Oxide Industry Council (EOIC) of the 

Chemical Manufacturers Association (CMA) in cooperation with the Environmental 

Protection Agency (EPA). The testing was conducted according to a protocol 

agreed to by all groups (see Appendix 2). Radian Corporation was engaged by 

the EOIC to oversee the testing effort, analyze the data, and generate this 

industry-wide final summary report. 

2.1 Definition of Fugitive Emissions 

In this report, the term fugitive emissions means, specifically, 

leaks of ethylene oxide (EO) from process equipment, including: 

• Pump seals; 

• Compressor seals; 

• Valves; 

• Connections (flanges, threaded fittings, unions, and any other 

pipe-to-pipe connections other than welds); 

• Sealed flanges (flanges wrapped in insulation and provided with 

a drip tube); 

• Open-ended lines (that are not securely capped or plugged); 

• Sampling points (treated as open-ended lines in this study); 

and 

• Safety relief valves. 

2-1 
P.29 

These components represent mechanical joints, seals, and rotating surfaces, 

which in time tend to wear and develop leaks. The leaks are called fugitive 

leaks because there is no way of accurately predicting their occurrence or 

severity. When the leaking component contains a mixture, it is assumed that 

the fugitive emissions have the same composition as the material flowing 

through the component. However, unless otherwise indicated, all mass 

emissions data in this report are expressed as EO only, having been corrected 

to exclude any other co-emitted volatile organic compounds (VOC). 

2.2 Critical Studies of Fugitive Emissions 

Industry and government agencies have been concerned about fugitive 

emissions since the mid 1970s. The US EPA funded two large studies of 

fugitive emissions between 1975 and 1983. The first of these focused on 

fugitive emissions from refineries (1). The second focused on the Synthetic 

Organic Chemical Manufacturing Industries (SOCMI) (2,3). The SOCMI study was 

criticized for its overly high prediction of the emissions from many organic 

chemical facilities, particularly those processing known toxic materials where 

an attempt to reduce emissions was an inherent part of the design and 

operations. Also, the SOCMI study tested only six of the hundreds of possible 

chemical processes, and most of the tested processes were large-commodity 

petrochemical processes. 

Despite these concerns about the refinery and SOCMI fugitive 

emission factors, they nevertheless were widely used, and numerous regulations 

have been based on the data. The US EPA promulgated New Source Performance 

Standards (NSPS) and Control Techniques Guidelines (CTG) for both the refining 

and organic chemical industries using SOCMI fugitive emissions factors. Many 

states adopted regulations in their State Implementation Plans (SIP) based on 

the CTG that apply to existing sources. These are also based on SOCMI 

factors. 

In recent years, the use of the refinery and SOCMI emission factors 

has extended even further beyond the test basis. These generalized factors 

have been used to estimate emissions from hazardous waste handling, air toxics 

2-2 
P.30 

processing, and other applications well beyond the originally intended uses. 

The justification for these applications has been that the refinery and SOCMI 

factors are the best available way to estimate fugitive emissions, since no 

specific testing has been conducted at such sites. 

2.3 Previous and Impending Concern About Fugitive Emissions 

The present EOIC study was conducted for the following reasons: 

• First, the Superfund Amendments Reauthorization Act (SARA), 

Title III required EO manufacturers to begin reporting each 

year's emissions of EO from both fugitive and point sources. 

• Second, the U.S. EPA announced they were considering developing 

a National Emissions Standard for Hazardous Air Pollutants 

(NESHAP) for EO. EPA is basing the NESHAP risk assessment on 

SOCMI emission factors, although use of these factors will 

result in an overestimation of EO fugitive emissions and 

therefore in an overprediction of the potential health risk. 

The EOIC believes that EPA should consider using the individual 

plant fugitive emissions found in the present study for further 

EO NESHAP evaluations and risk assessments. 

2-3 
P.31 

3.0 ETHYLENE OXIDE PRODUCTION AND USE 

This section gives an overview of Ethylene Oxide and its production 

and use in the United States. 

3.1 Ethylene Oxide 

Ethylene oxide (CAS Number 75-21-8) has the following structural 

formula: 

H H 

I I 

H C C H 

\ / 

0 

It has a molecular weight of 44, a molecular formula of C2H40, a vapor 

pressure of 1305 torr at 25*C, and it is completely soluble in water (5). It 

is highly explosive over a range from 3 percent in air to 100 percent. 

3.2 Overview of Production and Use 

Because ethylene oxide is a highly reactive epoxide, it can be used 

as an intermediate for a wide variety of compounds, as well as for 

sterilization and fumigation. Industrially, most of its reactions involve 

opening the epoxide ring. Ethylene oxide is produced by the direct vapor 

phase oxidation of ethylene over a silver catalyst at 10 to 30 atmospheres of 

pressure at 200 to 300°C. The source of oxygen is either air or high-purity 

oxygen. In 1985, nine of the producers used the oxygen-based process, while 

four used the air-based process (7). The main reaction is as follows: 

H2C - CH2 + 1/2 02 > H2C CH2 

V 

3-1 
P.32 

3.2.1 Air-Based Qxjtat-gn 

A schematic for the air-based ethylene oxidation is shown in Figure 

3-1. While much of the information associated with process technology is 

unavailable, the salient features are summarized below. 

In the first section of the process, air and ethylene are fed into 

the recycle gas stream (which contains untreated starting material returned 

from the main absorber). The recycle stream is fed into a bank of tubular 

main reactors, the number of reactors depending chiefly on the capacity of the 

plant, the activity of the catalyst, and the size of the reactors. In the 

main reactor, the ethylene is oxidized to ethylene oxide, carbon dioxide, and 

water, and includes minor impurities such as formaldehyde and acetaldehyde. 

It is estimated that ethylene conversion to ethylene oxide per pass 

in the main reactors is in the range of 20 to 50 percent. Oxidation 

inhibitors are added to the process to retard carbon dioxide formation. The 

process stream leaving the reactor may contain 1 to 2 mole percent ethylene 

oxide. This hot effluent gas is cooled to around 35 to 40"C and fed to the 

absorber system. 

The main absorber uses cold water to dissolve the ethylene oxide, 

some carbon dioxide, and traces of hydrocarbons and aldehydes. The unabsorbed 

gas is split overhead. The largest portion is used as recycle gas, and to 

cool the effluent stream from the main reactor; the gas then enters the main 

reactor. A much smaller portion of the absorber effluent gas is fed as the 

main stream to the secondary or purge reactor. The effluent from the purge 

reactor exchanges heat with the main stream and is sent to the "purge absorber, 

which operates in the same manner as the main absorber. 

The large portion of the ethylene present in the purge gas from the 

main reactor is reacted in the purge reactor system, but vapors must be vented 

from the main reactor so that inert gases (principally nitrogen and carbon 

dioxide) do not accumulate. In some operations, the ethylene content of the 

vent gas is sufficiently high to make energy recovery economical. 

3-2 
P.33 

Primary 

reactor 

Primary Purge Purgt 

absorber reactor absorber 

n a Catalytic 

i—i converter 

| r~-&] _TL 

[-ISteam^J—Tl pVl | 

=a= wt -•-Air T 

Power 

and 

heat 

recovery 

from vent gas 

pa*> Vent gas 

Oesorber ^_ ^ Stripper I Refiner A 

E$-l T.TTM 

Steam 

Reboiler 

Steam 

<£ c -» Steam 

Ethylene 

oxide 

Waste 

liquid 

Figure 3-1. Schematic of Air-Based Direct Oxidation Process for the 

Production of Ethylene Oxide 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988, 

3-3 
P.34 

The remainder of the process involves purification. The ethylene 

oxide water solution from the absorbers is heat exchanged and sent to the 

desorber, where the ethylene oxide is steam stripped under reduced pressure. 

The ethylene oxide is collected at the top and compressed for further 

purification, while the stripped water is recirculated to the main and purge 

absorbers. 

The ethylene oxide from the desorber still contains some carbon 

dioxide, nitrogen, aldehydes, and traces of ethylene and ethane, and must be 

sent to the stripper. In the stripper, the light gases are separated overhead 

and vented, while the partially purified ethylene oxide is taken from the 

bottom of the stripper and sent to the mid-section of a final refining column. 

The ethylene from the refining section should have a >99.5 percent 

concentration. Thus, the concentration of ethylene oxide will vary from less 

than 1 percent in the reaction end of the system, to nearly 100 percent in the 

final refining column. 

The range of conditions of the Air-Oxidation Process are summarized 

in Table 3-1. 

3.2.2 Oxvgen-Based Oxidation 

A schematic of the oxygen-based process is shown in Figure 3-2. The 

major differences in oxygen- and air-based oxidation processes are almost 

entirely the result of the difference in oxidants. In the oxygen-based 

process, the purge reactor is absent, and a carbon dioxide removal unit and an 

argon vent are added. Because this process uses oxygen instead of air, it 

requires less purge gas to remove the nitrogen, but it still requires removal 

of carbon dioxide and argon. Table 3-2 summarizes the range of the reaction 

system variables. 

3-4 
P.35 

TABLE 3-1. RANGES OF REACTION SYSTEM VARIABLES IN THE DIRECT 

AIR OXIDATION OF ETHYLENE OXIDE' 

Variable Range 

Ethylene, mole X 2-1 0 

Oxygen, mole X . 4- 8 

Carbon dioxide, mole X 5-1 0 

Ethane, mole X 0-1.0 

Temperature, °C 220 - 277 

Pressure, MPa (psi) 1 - 3 (145 - 435) 

Space velocity, h"1 2000 - 4500 

Pressure drop, kPa (torr) 41 - 152 (308 - 1140) 

Conversion, X 20-6 5 

Selectivity or Yield (mole basis X) 63 - 75 

Source: Cawse et al., 1980. 

b The space velocity is the standard volume of the reactant stream fed per 

unit time divided by the volume of reactor space filled with catalyst. 

h - hour 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988, 

3-5 
P.36 

Reactor Absorber 

CO, 

O— 

C O J Absorber Intermediate 0e$ J rbe f 

desorber . 

f Vent a—« Process # ^ ««--"-' a 

o-4jj>y 

5c . 

Steam 

zr 

Nitrogen 

W Steam 

Flasher 

Desorber Strippe Stripper _a_. Vent Refine Refiner r 

K-.-I J^> 

•fT 

Steam 

Reboiler 

Steam 

£ 

o 

Ethylene 

oxide 

,. .«- Steam 

IT 

Waste liquid 

Figure 3-2. Schematic for Oxygen-Based Direct Oxidation for Production 

of Ethylene Oxide. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

3-6 
P.37 

TABLE 3-2. RANGES OF REACTION SYSTEM VARIABLES IN THE DIRECT 

OXYGEN-OXIDATION OF ETHYLENE OXIDE' 

Variable Range 

Ethylene, mole X 15-4 0 

Oxygen, mole X 5-8.5 

Carbon dioxide, mole X 5-1 5 

Ethane, mole X 0- 2 

Argon, mole X 5-1 5 

Nitrogen, mole X 2-6 0 

Methane, mole X 1-6 0 

Temperature, °C 220-275 

Pressure, MPa (psi) 1-2.2 (145 - 319) 

Space velocity, h"1 2000 - 4000 

Conversion, X 7 - 15° 

Selectivity or Yield (mole basis X) 70 - 77 

* Source: Cawse et al., 1980. 

b The space velocity is the standard volume of the reactant stream fed per 

unit time divided by the volume of reactor space filled with catalyst. 

c At 30 mole X ethene. 

h - hour 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

3-7 
P.38 

3.3 Production and Use 

Eleven companies at 13 locations produce ethylene oxide in the 

United States. 2.6 million metric tons were produced in 1985 (5). Most of 

the ethylene oxide is used at the production site to make ethylene glycol, 

glycol ethers, and ethanolamines. Capture feed levels are approximately 90 

percent of actual EO production rates. The breakdown of EO production was 

previously shown in Table 1-3. 

All of the production facilities in service at the time of this 

study participated in the study. The Olin Chemical plant in Brandenburg, KY 

was not in service at the time of the study, but it began production ih the 

summer of 1988. One of the two production units for Shell Chemical in 

Geismar, LA was not in service at the time of this study. 

3-8 
P.39 

4.0 MONITORING APPROACH 

This section gives an overview of the technical approach taken in 

the project, as well as details of the protocol followed by the participating 

member companies. For the protocol, see Appendix 2. 

4.1 Overview of Methods Used to Estimate Fugitive Emissions 

Several steps can be taken to generate a fugitive emissions estimate 

for a specific chemical unit. Figure 4-1 illustrates the overall process. 

For Ethylene Oxide production plants, the potential process fugitive 

emissions sources include valves, pumps, compressors, connectors (flanges, 

sealed flanges, screwed fittings, etc.), open-ended lines, safety valves, and 

sample points. Some of these component types are subdivided into service 

categories that describe the physical state (liquid or gas) and volatility 

range of the material flowing through the component. Valves have been grouped 

into three categories: gas, light liquid, and heavy liquid. Pumps have been 

grouped into two categories: light liquid and heavy liquid. All other sources 

have only one category that covers all types of service. 

The first step in estimating fugitive emissions is to determine the 

population of each type of component in the process area to be monitored. 

This can be accomplished by either an on-the-ground physical inventory or by 

examining accurate P&ID drawing. Once this is done, a plant can select from 

five methods of estimating fugitive emissions. These five methods are 

described below and are typically referred to by the following names: 

SOCMI Average Emission Factors; 

Leak/No Leak Emission Factors; 

Stratified Emission Factors; 

Correlation Equations; and 

Bagging. 

4-1 
Av«c«g« soon 

Caiaaio- Factora 

I 

Avaraga 80QII 

laiaaiaaa Batiaaia 

Baliaa- Baiiaataa 

Laak/Mo Laak 

Hatha* 

Laak/Ha Laak 

Raia.ioaa 

aUliaala 

Ccapanant Coianc by 

BqiaifsanC Typa anal 

tarvica Caiaguiy 

Scraaning 

Haaauiaaama 

i~T~l 

Scraiifia. 

Naiko4 

Stiatifia. 

Baiaaiooa 

•atiaata 

Laak Sal a 

Corralaliana 

Bquatioaa 

SOCMI Coiralacioa 

•quaiiea laiaaloa 

•aliaala 

Corralaciou 

Squatioaa 

ValiaialaaJ 

Baggint 

Maaauraajanca 

Nana Coir-lalion 

Eqaaatioaa Davalopa. 

Haaatira-

-aiaaiooa 

-oil-Specific Carialalioa 

Kquaiioa Esiaaioaa Batiaata 

Figure 4-1. Overview of Fugitive Emission Estimation. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.41 

All five of these methods were applied in this study. Bagging tests were 

optional. 

4.1.1 SOCMI Average Emission Factors 

In the early 1980s, EPA conducted a fugitive emissions study at 24 

plants in the Synthetic Organic Chemical Manufacturing Industry (SOCMI) (3). 

From the results of this study, EPA developed average emission rate factors 

for several components. These factors were published in a recent EPA report 

(8). the representativeness of the data for modern SOCMI facilities is 

questionable in light of current design and maintenance practices, especially 

in plants dealing with potentially toxic chemicals. 

In estimating fugitive emissions for a process area, the number of 

components of each type is multiplied by the average emission factor for that 

component type. The contributions from each component type are added to 

develop the total emission estimate for the process area. 

Note that in this study, permanent sample points were treated as 

open-ended lines since all screening tests were performed without actual 

process sampling. The original EPA database included sample connection 

screening values taken while actual process sample acquisition was in 

progress. 

4.1.2 Screening Test 

All other emission estimation methods require that a screening 

survey be made of the components in the process area to be monitored. 

Screening is a relatively quick measurement method that employs a portable 

detector that indicates whether a source is emitting and gives a rough 

magnitude of the emissions. For measuring total VOCs, portable Flame 

Ionization Detector (FID) instruments like the Century Systems OVA-108 and 

combustibles analyzers such as the TLV Sniffer have been used for screening 

tests. To obtain accurate estimates of the actual VOC screen values, these 

analyzers are calibrated with methane and then challenged with standard gases 

4-3 
of the material to be analyzed to determine the specific response of the 

instrument for that compound. The raw screening data are adjusted to reflect 

such instrument response factors (RFs). Additional corrections to the 

screening data may include adjustments for line composition so that the 

contribution from each compound in the line is properly included. Before 

making a screening measurement, the instrument response to the ambient air 

"near" the component is determined. This background reading is subtracted 

from the screening value to correct for the ambient level of hydrocarbons. 

4.1.3 Leflfc/N9 Leak Method 

After examining all of the data at their disposal, the EPA 

determined that a reasonable approach to estimating fugitive emissions could 

include separate emission factors for leaking components and non-leaking 

components (9,10). Additional work by EPA established a screening value of 

10,000 ppm as the cutoff for declaring a component to be a "leaker" (11). 

The leak/no leak emission factors published by EPA are presented in 

Table 4-1 and are taken from Reference 8. In applying these factors, the 

screening data are first divided by component type and then by screening value 

into leaker or non-leaker categories. The number of components in each 

category is multiplied by the appropriate emission factor. The total emission 

estimate is the sum of all individual category contributions. 

4.1.4 Stratified Method 

Recognizing that the vast majority of components do not leak or have 

very low emissions, the EPA redefined the leak/no leak strategy and developed 

a three-tiered approach. Three ranges of screening values were derived: 0-

1000 ppm, 1001-10,000 ppm, and over 10,000 ppm. Table 4-1 gives the emission 

factors for each component type and service category. The stratified method 

screening value ranges given in Table 4-1, (0 - 999 ppm, 1,000 - 9,999 ppm, 

and > 10,000 ppm) are slightly different from those published by EPA (0 -

1,000 ppm, 1,001 - 10,000 ppm, and >10,000 ppm), the difference being at the 

boundary between ranges, i.e. at 1,000 and 10,000 ppm. The rationale of this 

4-4 
TABLE 4-1. EPA EMISSION FACTORS IN lb/hr/SOURCEfi 

4> 

I 

tn 

Component Type 

Valves 

Valves 

Flanges 

Sealed Flanges 

Open-Ended Lines 

Pumps 

Safety Valves 

Sample Points0 

Compressors 

Service 

Liquid 

Gas 

All 

All 

All 

Liquid 

All 

All 

All 

Average 

SOCMI 

0.015600 

0.012300 

0.001830 

0.001830 

0.003700 

0.108900 

0.229100 

0.003700 

0.502200 

Leak/No Leak 

Screen Value Range 

(ppm) 

<10,000 

0.003770 

0.001060 

0.000130 

0.000130 

0.003300 

0.026400 

0.098500 

0.003300 

0.196900 

>10,000 

0.187800 

0.099400 

0.082700 

0.082700 

0.026300 

0.963000 

3.725000 

0.026300 

3.542000 

Stratified1* 

Screen Value Range 

0 - 999 

0.000617 

0.000310 

0.000044 

0.000044 

0.000290 

0.004360 

0.025100 

0.000290 

0.024900 

(ppm) 

1000-9999 

0.021230 

0.003640 

0.019290 

0.019290 

0.019300 

0.073800 

0.614500 

0.019300 

0.581500 

>10000 

0.187800 

0.099400 

0.082700 

0.082700 

0.026300 

0.963000 

3.725000 

0.026300 

3.542000 

a Values obtained from Table 3-5 in Protocols for Generating Unit-Specific Emission Estimates for 

Equipment Leaks of VOC and VHAP, EPA Report, October, 1988 (Ref 8). 

The screening value ranges shown are slightly different from those published by EPA. Their ranges 

are 0-1000 ppm, 1,001 - 10,000, and >10,000 ppm. The ranges in the table are consistent with the 

leak/no leak strategy and represent a more conservative estimation procedure than that given by EPA. 

Sample points treated as open-ended lines for all purposes. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.44 

study was to use the more conservative approach and include the boundary 

values in the higher emission factor category. This approach then provides 

identical emission estimates for the leak/no leak and stratified methods for 

components with screening values of 10,000 ppm (i.e. for leakers). 

For example, consider a pump with a screening value of 10,000 ppm. 

According to the leak/no leak method, this component leaks at an estimated 

emission rate of 0.963 lb/hr. According to the EPA-specified ranges for the 

stratified method, this pump's estimated emission rate is 0.0738 lb/hr. 

However, using the ranges specified in this study, the pump emission rate by 

the stratified method is 0.963 lb/hr, identical to the leak/no leak estimate. 

The application of these factors follows the pattern of the leak/no 

leak method. The components with screening values in each range are counted. 

These values are then multiplied by the appropriate emission factor and all 

contributions are added to derive the total estimated emissions for the 

process area. 

4.1.5 Correlation Equations 

The data obtained by the EPA during the refinery project (1) and the 

SOCMI project (2,3) included screening values and actual fugitive emission 

rate determinations. Statistical evaluation of the data led to development of 

correlation equations to transform screening values to leak rates for three 

component types in four service categories (8). These were: 

• Valves in light liquid service; 

• Valves in gas service; 

• Flanges, and 

• Pumps. 

The equation for pumps is typically applied to all other categories 

that do not have a specific equation. Table 4-2 shows the four correlation 

equations used in this study; they were taken from Reference 8. 

4-6 
TABLE 4-2. FUGITIVE EMISSIONS CORRELATION EQUATIONS*>b 

Component 

Type Service Correlation Equation0 

Number of 

Data Pairs 

Correlation 

Coefficient 

"Default Zero" 

Emission Rate 

(lb/hr) 

Valve Gas 1.680 x 10"5 x (SCRNVALU)0'

693 

Valve Liquid 3.740 x IO"4 x (SCRNVALU)0470 

Flange All 3.731 x 10"5 x (SCRNVALU)0820 

Other All 1.335 x 10"5 x (SCRNVALU)0898 

99 

129 

52 

52 

0.66 

0.47 

0.77 

0.81 

0.000072 

0.001004 

0.000209 

0.000088 

i 

a Emission estimates are calculated in lb/hr. 

b Taken from Table D-1 in Protocols for Generating Unit-Specific Emission Estimates for Equipment 

Leaks of VOC and VHAP, EPA Report, October, 1988 (Ref 8). 

c SCRNVALU - Maximum OVA screening value in ppm. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.46 

Each of the equations predicts a zero emission rate for screening 

values of zero. During the early fugitive emissions studies, the EPA 

determined the actual emission rates for several components that had zero 

screening values. Working backwards through the correlation equations, EPA 

adopted a "default zero" screening value of 8.17 ppm for all sources. The 

mass emission rates corresponding to 8.17 ppm using the correlation equations' 

are shown in Table 4-2 as "default zero" mass emission rates in lb/hr. 

4.1.6 Sagging 

If unit-specific correlation factors are desired, the next step is 

to obtain quantitative emission rate data from "bagging" tests. A bagging 

test consists of enclosing the component under test in an air-tight Mylar or 

Tedlar or aluminum shroud or bag. Next, a gas stream is pushed through 

(flow-through method) or pulled through (vacuum method) the bag at a measured 

rate. Once equilibrium is established, exhaust gas samples are analyzed for 

temperature and for the species of interest; i.e., EO for this study. This 

bag concentration of EO is then converted to the corresponding mass emission 

rate in lb/hr using Equation 1. 

Mass Emission Rate -

 B ° g TMC * TM * ** * TM (Eq. 1) 

MV 

where: EO Cone - Concentration of EO in the bag in ppm; 

MW - Molecular weight of EO - 44 lb/lb mole; 

MV - Molar volume of EO - 392 ft3/lb mole at 68°F; 

FR - Air flow rate through the bag in ft3/hr; and 

TC - Temperature conversion factor based on the ideal gas law 

to convert FR from its measured value to the corresponding 

flow rate at 68°F. 

4-8 
P.47 

This value is the actual measured rate of EO emissions from the 

component into the atmosphere. The measured emission rates for several 

components are plotted in log-log space against the corresponding screening 

test results. The EPA correlation equation is drawn on the same plot. If 

each of the measured (bagged) data points falls below the EPA curve, then the 

EPA curve will overestimate the mass emission rate from the components tested 

and the EPA correlation equation is considered valid for the process area 

tested. If the measured data points are consistently above the EPA curve, 

then the EPA curve underestimates the actual mass emission rate from the 

components tested, the EPA correlation equation is not valid for the process 

area tested, and a different method for estimating fugitive emissions is 

indicated. In general, four to eight comparative data sets (screening and 

bagging test results) are required to validate the correlation equations. 

If the correlation equations are not valid or if the estimates of 

the emissions are far beyond the levels indicated by initial bagging tests, a 

plant may choose to develop a new unit-specific correlation equation that may 

require as many as 20 to 30 bagging tests per source type/service category. 

The final stage of unit-specific fugitive emission estimation is the 

development of an industry-specific emission factor. This is a factor which, 

when multiplied by the number of sources, gives the estimated emissions from 

these sources. Such an emission factor should be based on a large amount of 

data taken from different units of the same type and at different times during 

the maintenance cycle. 

4.1.7 Current Studv 

All five of the estimation methods described above were employed in 

this study. Screening test data were used from all participating plants to 

derive estimated emissions using the average SOCMI factors, the Leak/No Leak 

factors, the stratified factors, and the correlation equations. Bagging 

tests, which were optional, were conducted at four of the participating 

plants. 

4-9 
P.48 

4.2 Screening Techniques - EPA Method 21 

As applied to the EO fugitive emissions study, screening analysis 

corresponded to a supplemented version of EPA Reference Method 21. A copy of 

the reference method is contained in Appendix 1. 

EPA Method 21 describes a procedure for identifying and screening 

VOC leaks from process equipment. Several performance specifications are 

given in the method. Analytical requirements include: 

• Instrument response factor (RF) must be less than 10 for the 

compound of interest; 

* Instrument response time must be less than 30 seconds; and, 

• Instrument calibration precision must be within 10X. 

Other requirements for the analyzer include: 

• It must contain an internal pump capable of sampling at a rate 

of 0.5 to 3 liters per minute; 

* It must be intrinsically safe; and, 

* It must be calibrated with certified (+2X accuracy) standard 

gases. 

The method describes the procedure for screening valves, 

connectors/flanges, pumps/compressors, pressure-relief devices, process 

drains, open ended lines/valves, seal systems, and access doors. The 

determination of background levels is also described. Finally, the 

measurement of instrument response factors, calibration precision, and 

response times are described. 

4-10 
P.49 

The instrument chosen for the EO fugitives emission study was the 

Foxsboro OVA-108 (Organic Vapor Analyzer). This analyzer is a portable flame 

ionization detector (FID) based instrument. It contains an internal pump that 

draws approximately 1 L/min of sample. The air drawn in with the sample 

provides the air for the flame. The unit is battery powered and has an 

internal hydrogen cylinder with enough fuel for 8 to 10 hours of continuous 

operation. The unit is certified by the manufacturer to be intrinsically 

safe. The analyzer has a logarithmic readout covering the range 1 to 10,000 

ppm. 

A 10-to-l dilution probe is available for the OVA-108 instrument. 

Use of this device allows the instrument to respond to up to 100,000 ppm. 

Dilution probes were typically not used in this study, and components with 

screening values at or above 10,000 ppm were assigned an emission rate equal 

to the leak factor from the Leak/No Leak method. The correlation equations 

for data above 10,000 ppm were not used since the equations were derived from 

data where "pegged sources" (i.e., sources with screening values above 10,000 

ppm) were excluded. 

The OVA responds to many organic compounds in addition to EO. The 

response of the analyzer to a mixture containing EO and other organic 

compounds will be a combination of the response attributable to each 

compound. In general, a weighted basis calculation is used to determine the 

instrument response from a mixture. This is described in more detail later in 

the report. 

4.3 Calibration 

In accordance with EPA Method 21, the OVA instrument must be 

calibrated by adjusting the meter reading with a hydrocarbon-free air source 

and by using a certified standard gas containing approximately 8,000 ppm of 

methane in air. Subsequently, the instrument response to EO in air standards 

is determined using at least three standard gases covering the range of 20 to 

20,000 ppm EO. Instrument response factors for each standard gas were 

determined from the following equation: 

4-11 
P.50 

RF - Actual Concentration/Instrument Response (Eq. 2) 

The data are subjected to a linear least squares analysis. If the 

correlation coefficient exceeds 0.99, the analyzer is judged to have a linear 

response to EO, and the RF for EO is the average RF from the upscale readings. 

For analyzers whose correlation coefficient is less than 0.99, calibration 

curves are developed and used to convert raw OVA values to screening values. 

For this EO study, all calibration data submitted corresponded to correlation 

coefficients greater than 0.99 and average response factors were used for all 

data calculations. 

4.4 Screening Protocol 

Before conducting the field tests, the EOIC and EPA agreed to a 

screening protocol. A copy of this protocol appears in Appendix 2. Key 

provisions are summarized below: 

• All EO producers would participate; 

• All streams containing >1X EO would be included; 

a Components accessible by platform, ladder, or manlift up to 40 

feet above grade would be tested; 

• Components to be tested included: 

-- Valves (all, in both liquid and gas service), 

-- Pumps (all), 

-- Safety Valves not vented to a header system (all), 

-- Open-ended lines unless plugged or blind flanged (all), 

4-12 
£2L 

-- Compressors (all), 

-- Sample Points, except closed loops, plugged lines, and lines 

venting to a control device (all), and, 

-• Connectors, flanges, and sealed flanges (up to about 150 

on a randomly selected basis, but excluding insulated 

flanges); 

• Bagging tests were optional; 

• Bagging tests, if performed, should have included 2 to 8 bags 

per component type/service category; 

• An OVA instrument would be used for screening tests; 

• The CMA Guidance Document published in August, 1988 (12) would 

be followed and no special inspection and maintenance (l&M) 

procedures would be allowed before or during the test period; 

• The QA/QC procedures outlined in the CMA Guidance Document 

would be followed and the results documented; 

• A concurrent industrial hygiene study was recommended; and 

• All parties agreed to accept the results of the study. 

4.5 EO Workbook 

The EOIC contracted Radian Corporation in Austin, Texas to oversee 

the testing effort, analyze the data, and prepare a final report. To 

facilitate uniformity in data collection and to answer any questions 

concerning the screening protocol, an EO Fugitives Workbook (.4) was prepared 

and distributed to all participants at an EOIC workshop held on March 30, 

4-13 
P.52 

1988. Included in the workbook were forms designed to obtain consistent 

screening and QC data from all participants. Data to be collected included 

screening, instrument calibration, and instrument drift. Each of the data 

forms is discussed below. 

4.5.1 Ethylene Oxide Screening Survey Report Form 

Figure 4-2 shows an ethylene oxide screening survey data form. An 

explanation of the data anticipated for each entry is given below: 

• Plant ID - Plant identification information; 

• Instrument ID - Unique identification information describing 

the analyzer used to obtain the data; 

• Analyst's Name - Person collecting the data who should be 

contacted concerning the data; 

• Date • Date of screening test; 

• Background Reading Time - Time of day when the particular data 

sheet was first used; 

• Background Raw Value - OVA analyzer reading in the vicinity of 

the components being tested (see Method 21 for details); 

4-14 
ETHYLENE OX IUK SCHKENINC SURVEY REPORT FORM 

Plant ID 

I nutriment ID 

Analyst Naae 

Phone No. 

Date 

Average RF 

Calibration Curve (Y/N) 

Background Reading 

Tiae 

Uncorrected Value (ppav) 

Seq. 

No. 

Fl otaSheet 

No. 

Location 

PaSID 

Coap 

Type 

Service Category/Process Streaa 

Coap 

Size* Coap 

(in.) Category* Phase 

EO 

X 

_ Screening Value 

Solvent OVA BO 

Naae/ Reading Specific 

Wt. X (ppav) (ppav) Comment 

»<<|.i 1.1...I 

Figure 4-2. Example Screening Data Report Form 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

Ol 

co 
P.54 

• Average RF - Average of response factor data from the latest 

multipoint calibration using EO standard gases (if the 

correlation coefficient was >0.99); 

• Calibration Curve (Y/N) - A space to indicate whether a 

calibration curve was needed to convert raw OVA values to 

screening values (typically not used by the participants in 

this survey); 

• Seq. No. - Sequence number used to keep track of the order of 

component testing (typically not used by participants); 

• Flow Sheet No. - Plant-specific identification information; 

• Location P&ID - Plant-specific identification information; 

a Component Type - Type of component being screened. For this 

study the protocol designated the following component types: 

-- Valves (VLV) 

-- Pumps (PMP) 

-- Connectors or flanges (FLN) 

-- Safety Valves (SV) 

-• Open-Ended Lines (OEL) 

-- Compressors (COM) 

-- Sample Points (SP), and 

-- Sealed Flanges (SF) 

• Size - Size of the component itself or the size of the line 

feeding into the component; 

• Component Category - Description of the type of component being 

tested; e.g., ball, globe, butterfly, etc. for valves; 

• Phase - Phase of the stream in the component (liquid or gas); 

4-16 
P.55 

• EO X - Percent by weight of EO in the stream (>1 X for this 

survey); 

• Solvent Name - Name of the major organic solvent for mixed 

streams; 

• Solvent X - Percent by weight of the major solvent named above; 

• OVA Reading (ppm) • Raw OVA screen value, uncorrected for 

instrument response, stream composition, or background; 

• EO Specific (ppm) • Results of EO specific screen tests such as 

sorbent tubes; and 

• Comments - Space for any observations or other comments 

concerning the specific component being tested. 

In actual practice, the spaces for response factor and calibration 

curve were not used, since most participants provided raw calibration and 

other QC data to be included in the data analysis. Sequence numbers, flow 

sheet numbers, and location P&ID data were all placed in the data base as 

plant identification information only. Final sequence numbers were assigned 

by the computer so that each component was uniquely identified in the data 

base. Many plants submitted secondary solvent names and percentages with 

their data. The data base and calculations for all the plants were expanded 

to have the capability for including as many as two organic solvents. 

4.5.2 Calibration Data Sheet for Ethylene Oxide Screening 

The EO workbook requested that the plants calibrate their analyzers 

daily using a methane standard of approximately 8,000 ppm. Included in the 

instrument calibration procedure* is a method for adjusting the instrument zero 

and "full scale" response. The plants were to determine the analyzer response 

to three standard gases containing approximately 20 ppm, 200ppm, and 2,000 ppm 

4-17 
P.56 

EO in air. For each standard, the instnunent response factor was to be 

determined using Eq.2 (see Section 4.3) and the instrument linearity 

determined using a linear least squares analysis. If the correlation 

coefficient was greater than 0.99, the instrument was considered linear and 

the RF was the average of the three upscale RF values. If the correlation 

coefficient was less than 0.99, a calibration curve was generated for 

converting the raw OVA values to VOC screening values. Figure 4-3 shows an 

analyzer calibration sheet. 

The participants varied considerably in adhering to the request 

concerning calibration. Most plants complied fully with the request. Two 

plants did not submit calibration data. 

4.5.3 Drift Test Data Sheet for Ethylene Oxide Screening 

The EO workbook requested that participants challenge their 

analyzers with one of the calibration standards three times a day (at the 

beginning, in the middle, and at the end of the day) to determine if the 

analyzer response was drifting. They were to recalibrate the instruments if 

more than 20X error was found. Figure 4-4 shows an analyzer drift test report 

form. Zero response drift (if any) was handled by the "zero" procedure as 

part of the daily calibration procedure. 

As with the calibrations, the plants varied considerably in adhering 

to this request. Drift test data were not received from three plants. 

4.3 Quality Control Results 

Virtually all instruments for which methane calibration data were 

submitted were found to be operating properly and achieving a methane response 

factor of 1.00. The results of the individual plant EO calibration and drift 

tests appear in Appendix 3. A summary table showing the range of results for 

each plant is presented in Table 4-3. 

4-18 
CALIBRATION DATA SHEET FOR ETHYLENE OXIDE SCREENING 

Plant ID 

Instrument ID 

Analyst Name 

Certified Methane Concentration 

Certified EO Concentrations 

Date Time 

Methane 

Reading 

(PP"> 

Low Medium High 

Blank Standard Standard Standard 

Reading Response Response Response 

(ppa) (ppa) (PP«) (ppa) R 

Low Medium High Average 

RF RF RF RF Commenta 

VO 

a) K - correlation coefficient 

Figure 4-3. Example Calibration Reporting Form 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
DRIFT TEST DATA SHEET FOR ETHYLENE OXIDE SCREENING 

Plant ID 

Instrument ID 

Analyst Naae 

ro 

o 

Date 

Nominal 

Gaa 

Cone, 

(ppmv) 

Pre Test 

Cone. Xa 

(ppav) Error 

Mid Test 

Cone. Xa 

(ppav) Error 

Post Test 

Cone. Xa 

(ppav) Error Cowmenta 

, _, certified cone- measured cone. .__ 

a) % error = x 100 

certified cone. 

Figure 4-4. Example Drift Test Report Form 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

Ul 

oo 
TABLE 4-3. SUMMARY OF CALIBRATION AND DRIFT TEST RESULTS 

Plant 

1 

2 

2 

3 

4 

5 

6 

7 

7 

8 

9 

0 

10 

11 

12 

Instr 

1 

2 

1 

2 

1 

2 

Rang* of 

Low Laval RF'a 

2.03 

4.76 

0.73 

1.00 

2.73 

4.00 

0.93 

1.11 

0.99 

0.99 

1.30 

1.11 

- 2.39 

- 4.76 

MH 

- 0.73 

- 1.17 

- 3.14 

- 5.00 

- 0.95 

- 1.11 

NM 

- 1.07 

- 1.21 

- 1.30 

- 1.18 

m 

Rang* of 

Mid Laval RF'a 

2.00 

3.10 

1.86 

1.36 

2.22 

2.50 

4.00 

2.06 

1.11 

1.00 

1.18 

1.77 

2.22 

- 2.85 

- 5.72 

- 2.09 

- 1.96 

- 2.50 

- 2.86 

- 5.00 

- 2.06 

- 1.12 

KM 

- 1.18 

- 1.18 

- 1.77 

- 2.22 

KM 

Rang* of 

High Laval RF'a 

2.61 

2.00 

2.22 

2.50 

3.81 

1.99 

1.08 

1.14 

1.18 

1.78 

2.22 

- 2.96 

KM 

MN 

- 2.00 

- 2.50 

- 2.50 

- 4.00 

- 2.10 

- 1.11 

KM 

- 1.14 

- 1.18 

- 1.78 

- 2.22 

KM 

Rang* of 

Appliad RF'a 

2.10 -

5.00 -

1.70 -

1.56 -

1.85 -

2.58 -

3.94 -

2.08 -

1.10 -

2.46 -

1.11 -

1.19 -

1.59 -

2.22 -

1.92 -

2.50 

5.70 

2.13 

1.56 

2.00 

2.83 

4.67 

2.06 

1.11 

2.46 

1.11 

1.19 

1.59 

2.22 

1.92 

Rang* of 

Correlation 

Co-Efflcianta 

0.9993 

0.9998 

0.9980 

0.9999 

0.9997 

0.9999 

0.9999 

0.9999 

0.9999 

0.9992 

0.9999 

- 0.9998 

NM 

NM 

- 0.8998 

- 0.9999 

- 0.9999 

- 1.0000 

- 0.9999 

- 1.0000 

NM 

- 0.9999 

- 0.9999 

- 0.9992 

- 0.9999 

NM 

Ranga of 

Drift Taata 

(X 

0.27 

0.35 

9.40 

0.00 

0.00 

0.00 

0.00 

0.00 

0.10 

1.60 

5.00 

0.00 

Drift) 

- 14.00 

- 3.20 

- 12.70 

- 15.00 

- 0.00 

- 18.09 

- 2.90 

' 4.30 

- 0.37 

m* 

- 10.87 

- 17.00 

MM 

- 0.00 

KMNo calibration or drift taat data wara aubalttad with tha aeraanlng data, 

waa appliad. 

An RF aqual to tha avaraga of all data in hand at tha tima 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMER 1988. 

co 
P.60 

The individual plant EO calibration data were initially examined for 

linearity of response using a linear least squares analysis of the multipoint 

data. The correlation coefficients shown in Table 4-3 range from 0.9992 to 

1.0000. As described earlier, if the resulting correlation coefficient was 

greater than 0.99, the instrument was considered linear and, in general, the 

average EO response factor was used to calculate results. In some instances, 

the low RF was not used to determine the RF to be applied. In all cases where 

this was done, the low-calibration RF was much lower than the medium- and 

high-level RF. The net result of not using these data was a conservative 

calculation routine that provided for screening values that were potentially 

higher than might otherwise have been calculated. 

Periodically, the analyzers were tested for drifting response. The 

results for these drift tests (shown in Table 4-3) range from 0.00 to 18.09X. 

All of the results are within the 20X drift acceptability limits originally 

recommended by the EOIC Workbook 

4-22 
P.61 

5.0 DATA ANALYSIS 

This section contains a description of the data analysis methods and 

a brief summary description of the data submitted by each participating 

company. 

5.1 Converting Raw OVA Values to EO-Soecific Emission Estimates 

5.1.1 Tfreoyy 

The data sheets requested background OVA values, along with raw 

screening values and stream composition data for the components tested. If 

the Raw OVA screen value was equal to or greater than 10,000 ppm, as defined 

by EPA, then the component was declared to be a leaker (11) and the emissions 

contribution from the Leak/No Leak table (Table 4-1) was assigned for all , 

remaining data analysis purposes to that component; i.e. the screening to leak 

rate correlation equations were not used to calculate an alternate emission 

estimate for these "pegged" sources. For all non-leakers, a screening value 

corresponding to the total VOC emissions was derived and a fugitive emissions 

estimate was made according to the following guidelines: 

• Corrected screen value - The background OVA value was 

subtracted from the raw screening value to obtain a corrected 

screening value. This corrected OVA value was set to zero if 

the calculated value was less than zero. 

• VOC screen value - The corrected screening value was adjusted 

to account for line composition and instrument response factors 

using Equation 3; 

VOC Corraetad 

Scraan . f(EQX«EQ RF) + (S0L1X«S0L1 RF) + (S0L2X*S0L2 RF)1 Scraan (Eq. 3) 

(EO X + SOLI X -l- S0L2 Z) Valua 

5-1 
P.62 

where: EOX is the weight percentage of EO in the component under test (a 

slight error in overall results is obtained since the screening 

instrument responses are on a mole percent basis); 

EO RF is the instrument response factor for ethylene oxide derived 

from the data supplied with the screening test results (see 

individual plant data contained in Appendix 3); 

S0L1X and S0L2X are the two major organic solvents listed on the 

data sheet (only those that would have an OVA response were 

included); and 

SOLI RF and S0L2 RF are the published response factors for solvent 1 

and solvent 2, each at an OVA meter reading of 10,000 ppm (12) (see 

Table 5-1 for compound names and RF values used in the 

calculations); 

• Average SOCMI emissions estimate • The estimated VOC mass 

emissions for each component were calculated from the average 

SOCMI emissions factor previously shown in Table 4-1; 

• EO Weight Fraction - The weight fraction of EO in the stream 

was calculated from Equation 4: 

EO WT FRAC -

 ES 2 (Eq / 4 ) 

EO WT FRAC - (E Q x + SQL 1 x + SQL 2 x ) 

Leak/No Leak Emission Estimate - The VOC screening value for 

each component was assessed to determine if the component was 

leaking (i.e., >10,000 ppm). The appropriate emission factor 

from Table 4-1 was selected and corrected for the EO weight 

fraction to determine the EO emission rate. For components 

with a RAW OVA value of 10,000 ppm or greater, the LEAK 

emission factor was assigned automatically before correction 

for EO weight fraction. 

5-2 
P.63 

TABLE 5-1. ORGANIC SOLVENT AND RESPONSE FACTORS* 

g = i ' " ' =^ -

s ——^-— . • 

Compound RF 

Acetetaldehyde Same as for EO 

Butanol 1.44 

Ethane 0.65 

Ethanol 1.78 

Ethylene 0.71 

Methane 1.00 

* Taken from US EPA Response Factors of VOC Analyzers at a Meter Reading of 

10,000 ppm for Selected Organic Compounds. Publication No. EPA-600/2-81-

051, 1981 (Ref 13). 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-3 
P.64 

• Stratified Emission Estimate - The VOC screening value for each 

component was compared with the low range of 0 to 999 ppm, a 

mid-range of 1000 to 9999, and the high range of 10000 ppm or 

more. The appropriate emission factor from Table 4-1 was 

selected and corrected for EO weight fraction to estimate the 

EO fugitive emissions. For components with a RAW OVA value of 

10,000 ppm or greater, the HIGH emission factor was 

automatically assigned and then corrected for the weight 

fraction of EO in the stream. 

• Calculated Emission Estimate - For components declared to be 

leakers because their RAW OVA value was 10,000 ppm or more, the 

appropriate LEAK contribution from the LEAK/NO LEAK table was 

selected for the calculated emissions estimate. For all other 

components, the VOC screening value was used in the correlation 

equations from Table 4-2 and the resultant emissions corrected 

for EO weight fraction to determine the EO fugitive emission 

estimate. For components with a VOC screening value below 8.17 

ppm, the EPA-specified lower limit of 8.17 ppm default value 

was used in the calculation. 

Calculations were made using the correlation equations and allowing 

the screening value to be as low as 0 ppm (shown as LLD-0 throughout the 

remainder of this report). In many cases, the OVA screening value and 

background OVA value were identical, leading to a corrected screening value of 

0 ppm. 

An additional calculation was made using the default zero mass 

emission factors developed from several "zero screening" components bagged 

during this study in four plants. This topic is described in greater detail 

in Section 5.4. The resulting correlation curve (EOIC) used the individual 

EOIC default zero emission factors as the lower limit of emissions. New EOIC 

emission factors were developed for only three classes of components: valves 

in liquid service, valves in gas service, and flanges. There was insufficient 

data to develop a new EOIC default zero emission factor for pumps and other 

5-4 
P.65 

components. The EPA default emission factors, corrected for EO weight 

fraction, were used for pumps and other components. 

5.1.2 Practical Examples 

This section provides detailed descriptions of the calculations used 

for several combinations of components, screening values, and line 

compositions. 

Example 1: 

Component Type - Valve in liquid service; 

Raw Screening Value - >10,000 ppm; 

Background OVA Value - 3 ppm; 

EOX - 60X; 

EO RF - 1.20; 

Solvent 1 - Water - non-VOC; 

EO Weight Fraction - 100X; 

The average SOCMI emission estimate for this component comes 

directly from Table 4-1 and is 0.0156 lb/hr; 

The Leak/No Leak emission estimate is taken directly from the 

leak column of Table 4-1 and is 0.1878 lb/hr. Note that since 

this component gave a "pegged" OVA screen value, it is declared 

to be a "leaker" and no corrections are made for instrument RF; 

and 

5-5 
P.66 

• All other emission estimates (stratified and all correlation 

curves) are assigned the same leak value (0,1878 lb/hr) as 

above. 

Example 2: 

• Component Type - Valve in gas service; 

• Raw Screening Value - 2,000 ppm; 

• Background OVA - 3 ppm; 

EOX - 35X; 

EO RF - 1.11; 

• Solvent 1 - Ethane at 20X (remaining solvent - water and fixed 

gases totalling 45X); 

EO Weight Fraction - ( 3 5 | * 100 - 64X 

35 + 20 

The average SOCMI estimated emission rate from Table 4-1 is 

0.0123 lb/hr; 

The corrected OVA value - 2,000 - 3 - 1997 ppm; 

The VOC screen value -

1997 x (0.35 * 1.11 + 0.20 * 0.65) - 1,883 ppm 

(.35 + .20) 

where: 0.65 is the RF for ethane as given in Table 5-1. 

5-6 
P.67 

• The Leak/No Leak estimated emissions are 64X of 0.001060 -

0.000678 lb/hr. Since 1,883 ppm is less than the 10,000 ppm 

level necessary for a leaker, this component is considered to 

be a non-leaker, and the 0.001060 lb/hr contribution for total 

VOC is appropriate. 

• The stratified method estimated emissions are 64X of 0.003640 -

0.002330 lb/hr. The 1,883 ppm VOC screening value falls in the 

mid-level strata. 

• For the correlation curve, the 1,883 ppm VOC screening value is 

substituted into the gas phase valve equation of Table 4-2 to 

give a total VOC emissions estimate of 0.003125 lb/hr. The EO 

portion of this is 64X, or 0.002000 lb/hr. Since this is well 

above the default zero values (of both EPA and the EOIC), no 

further corrections are necessary, and all correlation curve 

results are the same 0.00200 lb/hr. 

Example 3: 

• Component Type - Flange; 

• Raw Screening Value - 5 ppm; 

• Background OVA - 3 ppm; 

EOX - 4X; 

EO RF - 1.56; 

• Solvent 1 - Ethylene at 11X (water and fixed gases totalling 

85X); 

EO Weight Fraction - ( 4 ) * 100 - 27X 

\4 + Hi 

5-7 
P.68 

The average SOCMI emissions estimate is 0.00183 lb/hr; 

The corrected OVA value - 5-3 - 2 ppm; 

The VOC screen value -

9 v (.0* * l.M + , U * .71) _, , «7 nT,m 

2 x (.04 + .11)

 ll8 7 Pp m 

The Leak/No Leak estimate - .000130 x .27 - 0.000351 lb/hr; 

The stratified method estimate - 0.000044 x .27 - 0.000012 

lb/hr; 

Through straight forward application of the correlation 

equation, the correlation curve gives a preliminary estimate of 

0.0000623 lb/hr. A EO-specific value of 0.0000168 lb/hr is 

obtained by multiplying by the fraction (0.27); 

Since the initial screening value is below the 8.17 ppm lower 

limit allowed by EPA, the correlation curve (EPA) emission 

estimate is taken as the default value from Table 4-2 (0.000205 

lb/hr) corrected for EO weight fraction (0.27) to give 0.000055 

lb/hr. 

The correlation curve (LLD-0) gives the 0.0000168 lb/hr 

emission estimate described above. 

The correlation curve (EOIC) emission value is 0.0000168 lb/hr 

(as calculated above) since this value is higher than the EOIC 

default value for flanges (0.000000352 lb/hr as described in 

Section 5.4). 

5-8 
P.69 

5.2 Summary of Components Studied 

Survey data from a total of 18,227 individual components were 

received from 12 ethylene oxide production facilities. These data are 

summarized by plant in Table 5-2. Fewer than 4X (664) of the components were 

inaccessible. Figure 5-1 illustrates the distribution of accessible 

components. Of the 17,563 accessible components, 47.5X (8326) were valves in 

liquid service, 19X (3306) were valves in gas service, 27X (4742) were 

flanges, and 4X (754) were open-ended lines. The remaining 2.5X (435) 

comprised a combination of sealed flanges, pumps, safety valves, sample 

points, and compressors. 

The production of EO proceeds by stages from the crude chemical in a 

mixture with water to the finished product. The concentration of EO increases 

steadily throughout this process. The temperature, pressure, and other 

operating conditions vary throughout the different stages of the production 

process. To investigate whether differences in emissions resulted from 

differences in plant operations, the data were studied as a function of the 

following ranges of EO concentration: 

IX to 2X; 

2X to 5X, 

5X to 10X; 

10X to 50X; 

50X to 95X; and 

Greater than 95X. 

Table 5-3 and In Figure 5-2 show the distribution of components by EO 

concentration. The upper portion of Table 5-3 shows the actual numbers of 

components of each type (i.e., the number of valves in liquid service, the 

number of valves in gas service, etc.) in each of the six EO concentration 

ranges. The bottom portion of Table 5-3 shows the percentage of each type of 

component in each of the six EO concentration ranges.- For example, the 294 

valves in liquid service in the EO range of IX to 2X represent 3X of the total 

number of liquid Valves (8326) tested in the study. 

5-9 
TABLE 5-2. SUMMARY OF EO COMPONENTS STUDIED 

Kjs 

I 

Plant 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

TOTAL 

Liquid 

Valves 

933 

1107 

233 

380 

709 

756 

878 

694 

883 

456 

525 

772 

8326 

Gas 

Valves 

573 

408 

132 

154 

388 

406 

433 

72 

107 

110 

111 

412 

3306 

Flanges 

104 

177 

115 

144 

158 

408 

151 

328 

1276 

706 

150 

1025 

4742 

Sealed 

Flanges 

0 

0 

0 

0 

0 

99 

5 

0 

0 

0 

1 

0 

105 

OpenEnded 

Lines 

141 

361 

37 

0 

2 

0 

62 

0 

3 

127 

1 

0 

754 

Pumps 

26 

25 

8 

0 

17 

4 

19 

15 

19 

11 

24 

22 

190 

Safety 

Valves 

5 

0 

4 

0 

43 

25 

6 

0 

1 

21 

0 

0 

105 

Sample 

Points 

15 

0 

8 

0 

3 

0 

4 

0 

0 

0 

0 

0 

30 

Compressor 

0 

1 

0 

0 

0 

4 

0 

0 

0 

0 

0 

0 

5 

Accessible 

Total 

1797 

2099 

537 

678 

1320 

1702 

1558 

1109 

2289 

1431 

812 

2231 

17563 

Inaccessible 

34 

48 

0 

0 

35 

46 

0 

0 

308 

5 

1 

187 

664 

Total 

1831 

2147 

537 

678 

1355 

1748 

1558 

1109 

2597 

1436 

813 

2418 

18227 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

o 
P.71 

8326 

3306 

195 

105 

4847 

784 

II I I I I I VALVES (LIQ) 

V////X VALVES CGAS5 

PUMPS 8, COMPRESS 

OPEN END LINE & SP 

s^^^l FLANGES & SF 

SAFETY VALVES 

Figure 5-1. EOIC/EPA Fugitive Emission Study: EO Production Facilities: 

Distribution of Components Sampled 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988, 

5-11 
P.72 

TABLE 5-3. DISTRIBUTION OF COMPONENTS BY EO CONCENTRATION 

Component Type 

Valve (Liquid) 

Valve (Gas) 

Flange 

Sealed Flange 

Open-ended Line 

Pump 

Safety Valve 

Sample Point 

Compressor 

Total Number: 

Component Type 

Valve (Liquid) 

Valve (Gas) 

Flange 

Sealed Flange 

Open-ended Line 

Pump 

Safety Valve 

Sample Point 

Compressor 

Weighted Average 

1X-2X 

294 

772 

581 

1 

20 

7 

39 

0 

1 

1715 

1X-2X 

3 

23 

12 

1 

2 

4 

37 

0 

20 

X: 10 

Number of 

2X-5X 

415 

741 

343 

0 

148 

8 

2 

4 

1 

1662 

2X-5X 

5 

23 

7 

0 

20 

4 

2 

13 

20 

9 

Comoonents In EOX Ranee 

5X-10X 

245 

38 

95 

1 

15 

8 

3 

3 

0 

408 

Percentaee 

5X -10X 

3 

1 

2 

1 

2 

4 

3 

10 

0 

2 

10X-50X 

912 

421 

530 

2 

152 

28 

10 

4 

0 

2059 

50X-95X 

1042 

333 

617 

13 

51 

39 

11 

2 

3 

2111 

of Comoonents 

10X-50X 

11 

13 

11 

2 

20 

15 

10 

13 

0 

12 

; 

i 

( 

>95X 

5418 

L001 

2576 

88 

368 

100 

40 

17 

0 

9608 

Total 

8326 

3306 

4742 

105 

754 

190 

105 

30 

5 

17563 

In. EQX, Ra^ee 

50X-< 

13 

10 

13 

12 

7 

21 

10 

7 

60 

12 

J5X >95X 

65 

30 

55 

84 

49 

52 

38 

57 

0 

55 

a Weighted average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-12 
P.73 

55 Z 

12 Z 

10 Z 

9 Z 

14 Z 

E 

EOi > 95 Z 

EOi 50-95 Z 

E ^ 3 EO. 5 - 50 Z 

V777Z\ EO. 2 - s z 

EO. 1 - 2 Z 

Figure -5-2. EOIC/EPA Fugitive Emission Study: EO Production Facilities 

Distribution of Equipment by EO Concentration in Line 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-13 
P.74 

The weighted average data in Table 5-3 give the total number of 

components in the EO concentration range expressed as a percentage of the 

total number of components. For example, the 2,059 components with EO between 

10X and 50X represent 12X of the 17,563 components tested. A simple 

arithmetic average of the data in the 10X to 50X column is 10.6X. 

Fifty-five percent of the components tested in this study were in 

lines containing 95X or more EO. Approximately equal numbers of components 

tested were in the EO concentration ranges of 1X-2X (10X), 2X-5X (9X), 10X-50X 

(12X), and 50X-95X (12X). The concentration range of 5X-10X EO contained only 

2X of the number of components tested. 

Table 5-4 shows a distribution of the tested components in each EO 

concentration range by raw OVA screening value. The OVA screening values 

cover a six-decade range from 0 ppm to 10,000 ppm or more. The upper portion 

of Table 5-4 shows the number of components in each category, while the lower 

portion shows the percentage of the total contained in each range. The 

percentage values are illustrated in Figure 5-3. Most components had very low 

screening values. Slightly over 20X of all components had screening values of 

0 ppm. About 87X had screening values below 10 ppm and almost 98X had 

screening values below 1000 ppm. For all components studied, the number of 

leakers (screening value of 10,000 ppm or more) averaged 0.58X. 

Table 5-5 shows a distribution of the tested components for each 

component type in each raw OVA screening value range (without regard to EO 

concentration). The upper portion of Table 5-5 shows the number of components 

in each category, while the lower portion shows the percentage of the total 

contained in each range. Some general observations can be made from these 

results. Overall, the percentage of components having screening values of 

less than 10 ppm varied from a high of 93X for safety valves to a low of 60X 

for pumps and compressors. At the other end of the scale, the percentage of 

leakers varied from a high of 4.2X for pumps to a low of OX for compressors, 

safety valves, and sample points. More detailed results and a discussion of 

each component type will appear in the following sections of this report. 

5-14 
P.75 

TABLE 5-4. DISTRIBUTION OF RAW OVA SCREENING VALUES BY EO CONCENTRATION FOR 

ALL PLANTS AND ALL COMPONENTS 

Ethyler ie Oxide 

Concentration 

IX TO 

2X TO 

5X TO 

10X TO 

SOX TO 

95X TO 

TOTAL 

(ALL EC 

Ethyler 

2X 

5X 

10X 

50X 

95X 

100X 

) RANGES) 

te Oxide 

Concentration 

IX TO 

2X TO 

5X TO 

10X TO 

50X TO 

95X TO 

2X 

5X 

10X 

50X 

95X 

100X 

Weighted Average" 

Number ( 

0-9 

ppm 

1506 

1254 

352 

1621 

1805 

8720 

15258 

af Components in 

10-99 

ppm 

92 

296 

43 

386 

264 

730 

1811 

Screeninz Value Ranee 

100-999 

ppm 

37 

77 

10 

44 

27 

86 

281 

Percentaee of Comoonents 

0-9 ppm 

87.81 

75.45 

86.27 

78.73 

85.50 

90.76 

86.88 

10-99 ppm 

5 

17 

10 

18 

12 

7 

10. 

36 

81 

54 

75 

51 

60 

31 

1000-

ppm 

26 

28 

2 

5 

10 

40 

111 

>9999 

ppm 

54 

7 

1 

3 

5 

32 

102 

In Screenine Value Ranee 

100-

2 

4 

2 

2 

1 

1. 

999 

.16 

.63 

.45 

.14 

.28 

.90 

60 

ppm 

1000-

9999 ppm 

1.52 

1.68 

.49 

.24 

.47 

.42 

.63 

Total 

1715 

1662 

408 

2059 

2111 

9608 

17563 

>9999 ppm 

3.15 

.42 

.25 

.15 

.24 

.33 

.58 

Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-15 
P.76 

8 6 . 9 Z 

1 0 . 3 Z 

< 10 ppm 

Y////A 10-99 ppm 

^S^NSSl 100-999 ppm 

1000-999 9 ppm 

>10.00 0 ppm 

Figure 5-3. EO Production Facilities: Distribution of Components 

by Screening Values 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-16 
P.77 

TABLE 5-5. DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR ALL PLANTS 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

Component Type 

Number of Components in Screening Value Ranee 

0-9 

ppm 

10-99 

ppm 

100-999 

ppm 

1000-

ppm 

>9999 

ppm Total 

Valve (liq) 7508 717 

Valve (gas) 2826 327 

Safety Valve 98 6 

Sample Point 27 3 

Sealed Flange 88 11 

Pump 114 32 

Open-Ended Line 575 108 

Flange 4019 606 

Compressor 3 1 

Total 15258 1811 

67 

70 

1 

0 

0 

30 

48 

64 

1 

281 

22 

43 

0 

0 

2 

6 

14 

24 

0 

111 

12 

40 

0 

0 

4 

8 

9 

29 

0 

102 

8326 

3306 

105 

30 

105 

190 

754 

4742 

5 

17563 

Component Type 

Percentage of Components In Screening Value Ranee 

1000-

0-9 ppm 10-99 ppm. 100-999 ppm 9999 ppm >9999 ppm 

Valve (liq) 

Valve (gas) 

Safety Valve 

Sample Point 

Sealed Flange 

Pump 

Open-Ended Line 

Flange 

Compressor 

Weighted Average* 

90.18 

85.48 

93.33 

90.00 

83.81 

60.00 

76.26 

84.75 

60.00 

86.88' 

8.61 

9.89 

5.71 

10.00 

10.48 

16.84 

14.32 

12.78 

20.00 

10.31 

.80 

2.12 

.95 

0.00 

0.00 

15.79 

6.37 

1.35 

20.00 

1.60 

.26 

1.30 

0.00 

0.00 

1.90 

3.16 

1.86 

.51 

0.00 

.63 

.14 

1.21 

0.00 

0.00 

3.81 

4.21 

1.19 

.61 

0.00 

.58 

* Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-17 
Estimated emissions were developed for each of the 17,563 components 

using each of the estimation methods previously described. The mean (average) 

emission factor for each component type is shown in Table 5-6. In general, 

the progression of estimates as one proceeds from left to right in the table 

involves increasingly more sophisticated methods of estimating fugitive 

emissions. The average SOCMI estimate takes into account only the number of 

components and the average SOCMI value from the EPA study conducted about 10 

years ago. The mean EO amount is the average of the EO concentration 

expressed as a percentage of all VOC in the lines, i.e., the weight fraction 

of EO. The leak/no leak value divides the components into leakers or 

non-leakers, based on the OVA screening value, applies the appropriate 

emissions factor for each component, and corrects for the weight fraction of 

EO. The stratified emissions method partitions the components into three 

categories, depending on OVA screening value, applies the appropriate emission 

factor, and corrects for EO weight fraction. All other emissions estimates 

use the EPA correlation equations (previously given in Table 4-2) with 

different "default values". A default or lower level of detection (LLD) of 

8.17 ppm is specified by the EPA, based on the data set that they have. Many 

EOIC member companies expressed their belief that the correlation calculation 

should be based on the actual value obtained, i.e., allowing the LLD to go to 

0 if that was reported. As mentioned earlier, almost 20X of the screening 

values were zero after background correction. Finally, the results of bagging 

tests conducted during this study provided adequate data to derive new and 

individual EOIC "default zero" emission estimates for flanges and both types 

of valves (liquid and gas service). The details of this bagging study are 

presented later, along with the new default zero emissions values (Section 

5.4). Table 5-6 shows the average emissions estimates allowing>each of these 

default zero values. Mean emission factor summary reports (similar to Table 

5-6) for each plant appear in Appendix 3. These mean emissions factors will 

be discussed further in the following sections that cover each component type 

separately. 

5-18 
TABLE 

Component Type 

Valve (liquid) 

Valve (gas) 

Safety Valve 

Sample Point 

Sealed Flange 

Pump 

Open-Ended Line 

Flange 

Compressor 

5-6. SUMMARY OF ESTIMATED 

Number of 

Components 

8326 

3306 

105 

30 

105 

190 

754 

4742 

5 

Mean Raw 

OVA Screen 

Value 

(ppm) 

31 

285 

8 

4 

455 

2701 

450 

226 

63 

Mean EO 

Amount 

<-> 

98.8 

77.8 

92.0 

100.0 

99.2 

99.8 

89.4 

93.5 

83.1 

ETHYLENE 

EMISSION 

Average 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.001830 

.108900 

.003700 

.001830 

.502200 

OXIDE FUGITIVE EMISSIONS FACTORS 

FACTOR ESTIMATES FOR 

Mean 

Leak/ 

No Leak 

.004034 

.001358 

.090664 

.003300 

.004061 

.075649 

.003274 

.000470 

.163688 

Emission Factors 

Stratified 

Emission 

.001001 

.000794 

.028717 

.000290 

.004163 

.058462 

.000956 

.000466 

.020700 

FOR ALL 

ALL COMPONENTS 

(All Values in 

Correlation 

Curve (EPA) 

.001393 

.000494 

.000165 

.000088 

.005266 

.042651 

.001078 

.000714 

.000767 

lb/hr/source) 

Correlation 

Curve 

(LLD-0) 

.000550 

.000444 

.000095 

.000000 

.005096 

.042602 

.001023 

.000555 

.000714 

PLANTS: 

Correlation 

Curve (EOIC) 

.000550 

.000444 

.000165 

.000086 

.005096 

.042651 

.001078 

.000555 

.000767 

Ol 

I 

a-a 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

CO 
P.80 

The data in Table 5-6 show the average or mean OVA screening value 

for each component type in this study. Table 5-7 compares these values with 

the corresponding average values from the previous EPA fugitive emissions 

studies. The average SOCMI values were calculated using the correlation 

equations presented in Table 4-2. 

For all component types except flanges and sample points, which were 

treated the same as open-ended lines, a reduction in mean screening values was 

seen in this study. Since virtually all screening tests of sample points were 

performed when the sample points were not in use for sampling, they 

corresponded more closely to uncapped open-ended lines than to the "in use" 

sample points of previous EPA studies. 

For those components for which screening value reductions were 

recorded, the reductions ranged from 14.3X for open-ended lines to 99.9+X for 

compressors and safety valves. The principal reasons for these reduced 

emissions are probably improved plant design criteria, operations, and 

maintenance programs. Section 6 of this report discusses other possible 

explanations for these reductions. 

The relation between fugitive emission factors and EO concentration 

was explored by determining mean emission factors for each component type in 

each of six EO concentration ranges. These factors are shown in Tables 5-8 

through 5-13. The effect, if any, of EO concentration on mean emission 

factors will be discussed in the following sections as it pertains to 

individual component types. 

5.3 Emissions By Component Type and Service Category 

Fugitive emissions in the chemical industry are considered to be 

those volatile organic compound (VOC) emissions that result when process fluid 

(either liquid or gas) leaks from the plant equipment. Eight types of 

components were included in this study. Valves were further separated into 

valves in liquid service and valves in gas service. This section presents the 

data for each of these nine categories. 

5-20 
P.81 

r 

TABLE 5-7. COMPARISON OF OVA SCREEN VALUES FROM THIS EO STUDY WITH THOSE 

ESTIMATED FROM SOCMI FACTORS 

Component Type 

SOCMI 

(ppm)' 

2815 

13650 

115 

525 

22700 

51900 

525 

124500 

EO Study 

(ppm) 

31 

285 

226 

450 

2701 

8 

4 

63 

Reduction 

(X)b 

98.9 

97.9 

-96.5 

14.3 

88.1 

99.9+ 

99.2 

99.9+ 

Valve (Liquid) 

Valve (Gas) 

Flange 

Open-Ended Line 

Pump 

Safety Valve 

Sample Point 

Compressor 

• SOCMI screen value derived from the correlation equation given in Table 4-2. 

b Reduction calculated from: 

SOCMI Value - EOIC Value 

X Reduction * 100 

SOCMI Value 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-21 
TABLE 5-8. SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR ALL PARTICIPATING 

PLANTS: EMISSION FACTOR ESTIMATES FOR COMPONENTS WITH EO CONCENTRATION BETWEEN IX 

AND 2X 

Component Type 

Valva (liquid) 

Valva (gas) 

Safety Valva 

Sealed Flange 

Pump 

Open-Ended Line 

Flange 

Compressor 

Number of 

Componenta 

294 

772 

39 

7 

20 

581 

1 

Maan Raw 

OVA Scraan 

Value 

(ppa) 

39 

639 

2 

92 

113 

1401 

10 

Mean EO 

Amount 

(X) 

84.2 

68.5 

82.9 

100.0 

100.0 

70.6 

15.7 

Average 

SOCMI 

.015600 

.012300 

.229100 

.108900 

.003700 

.001630 

.502200 

Mean Emission Factors 

Leak/ 

No Leak 

.003799 

.001921 

.081636 

.026400 

.003300 

.001900 

.030840 

Stratified 

Emission 

.001156 

.001439 

.020803 

.004360 

.001241 

.001948 

.003900 

(All Values in 

Correlation 

Curve (EPA) 

.001518 

.001066 

.000073 

.000812 

.000959 

.002111 

.000017 

lb/hr/source) 

Correlation 

Curve 

(LLD-0) 

.000851 

.001023 

.000007 

.000753 

.000691 

.001986 

.000017 

Correlation 

Curve (EOIC) 

.000852 

.001024 

.000073 

.000812 

.000959 

.001987 

.000017 

tn 

I 

ro 

ro 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

oo 
TABLE 5-9. SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR ALL 

PARTICIPATING PLANTS: EMISSION FACTOR ESTIMATES FOR COMPONENTS WITH 

EO CONCENTRATION BETWEEN 2X AND 5X 

Component Type 

Valva (liquid) 

Valva (gaa) 

Safety Valva 

Sample Point 

Pump 

Open-Ended Line 

Flange 

Compressor 

Number of 

Components 

415 

741 

2 

4 

8 

148 

343 

1 

Maan Raw 

OVA Screen 

Value 

(ppm) 

33 

150 

8 

3 

44 

81 

113 

300 

Mean EO 

Amount 

(X) 

65.6 

37.3 

16.2 

100.0 

100.0 

49.3 

70.2 

100.0 

Average 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

.502200 

Mean 

Leak/ 

No Laak 

.004047 

.000733 

.015990 

.003300 

.026400 

.001627 

.000376 

.196900 

Emission Factors 

Stratified 

Emission 

.001091 

.000472 

.004075 

.000290 

.004360 

.000160 

.000622 

.024900 

(All Values in lb/hr/source) 

Correlation 

Curve (EPA) 

.001516 

.000277 

.000014 

.000088 

.000782 

.000151 

.000754 

.003554 

Correlation 

Curve 

(LLD-0) 

.000714 

.000253 

.000008 

.000000 

.000725 

.000118 

.000656 

.003554 

Correlation 

Curve (EOIC) 

.000714 

.000254 

.000014 

.000088 

.000782 

.000151 

.000656 

.003554 

I 

ro 

la> 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988 

I 
TABLE 5-10. SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR ALL 

PARTICIPATING PLANTS: EMISSION FACTOR ESTIMATES FOR COMPONENTS WITH 

EO CONCENTRATION BETWEEN 5X AND 10X 

Component Type 

Valva (liquid) 

Valva (gaa) 

Safety Valva 

Sample Point 

Sealed Flange 

Pump 

Open-Ended Line 

Flange 

Number of 

Componenta 

245 

38 

3 

3 

1 

8 

IS 

95 

Maan Raw 

OVA Screen 

Value 

(ppm) 

S 

48 

3 

2 

2 

IS 

3 

16S 

Mean EO 

Amount 

(X) 

100.0 

46.5 

100.0 

100.0 

100.0 

100.0 

100.0 

73.0 

Average 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.001830 

.108900 

.003700 

.001830 

Mean Emission Factors (All Values in lb/hr/source) 

Laak/ Stratified 

No Laak Emission 

.003770 .000617 

.000493 .000144 

.098500 .025100 

.003300 .000290 

.000130 .000044 

.026400 .004360 

.003300 .000290 

.000196 .000137 

Correlation 

Curve (EPA) 

.001081 

.000043 

.000088 

.000088 

.000209 

.000230 

.000109 

.000351 

Correlation 

Curve 

(LLD-0) 

.000190 

.000016 

.000000 

.000000 

.000000 

.000153 

.000027 

.000235 

Correlation 

Curve (EOIC) 

.000191 

.000016 

.000088 

.000088 

.000000 

.000230 

.000109 

.000235 

tn. 

I 

K> 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

oo 
TABLE 5-11. SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSION FACTORS FOR ALL PARTICIPATING 

PLANTS: EMISSION FACTOR ESTIMATES FOR COMPONENTS WITH EO CONCENTRATION BETWEEN 10X 

AND 50X 

Component Type 

Valva (liquid) 

Valva (gas) 

Safety Valva 

Sample Point 

Sealed Flange 

Pump 

Open-Ended Line 

Flange 

Number of 

Components 

912 

421 

10 

4 

2 

28 

152 

530 

Mean Raw 

OVA Screen 

Value 

(ppm) 

20 

11 

6 

3 

8 

85 

192 

22 

Maan EO 

Amount 

(X) 

98.6 

69.7 

100.0 

100.0 

100.0 

100.0 

99.8 

98.3 

Average 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.001830 

.108900 

.003700 

.001830 

Mean Emission Factora 

Leak/ 

No Leak 

.003920 

.001057 

.098500 

.003300 

.000130 

.026400 

.003748 

.000128 

Stratified 

Emission 

.000836 

.000323 

.025100 

.000290 

.000044 

.011800 

.001053 

.000080 

(All Values in lb/hr/source) 

Correlation 

Curve (EPA) 

.001351 

.000104 

.000093 

.000088 

.000209 

.001809 

.001093 

.000443 

Correlation 

Curve 

(LLD-0) 

.000595 

.000043 

.000028 

.000000 

.000058 

.001764 

.001033 

.000296 

Correlation 

Curve (EOIC) 

.000595 

.000043 

.000093 

.000088 

.000058 

.001809 

.001093 

.000296 

tn 

I 

io 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

oo 
TABLE 5-12. SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSION FACTORS FOR ALL PARTICIPATING 

PLANTS: EMISSION FACTOR ESTIMATES FOR COMPONENTS WITH EO CONCENTRATION BETWEEN 50X 

AND 95X 

Component Type 

Valva (liquid) 

Valva (gas) 

Safety Valve 

Sample Point 

Sealed Flange 

Pump 

Open-Ended Line 

Flange 

Compressor 

Number of 

Componenta 

1042 

333 

11 

2 

13 

39 

51 

617 

3 

Maan Raw 

OVA Screen 

Value 

(ppm) 

39 

53 

3 

4 

4 

57 

3400 

22 

2 

Mean EO 

Amount 

(X) 

97.8 

99.0 

100.0 

100.0 

100.0 

99.2 

91.2 

99.7 

100.0 

Average 

SOCMI 

.013600 

.012300 

.229100 

.003700 

.001830 

.108900 

.003700 

.001830 

.302200 

Mean Emission Factors (All Values in lb/hr/source) 

Leak/ Stratified 

No Leak Emission 

.004218 .001241 

.001640 .000902 

.098300 .023100 

.003300 .000290 

.000130 .000044 

.026178 .006104 

.003730 .001433 

.000263 .000240 

.196900 .024900 

Correlation 

Curve (EPA) 

.001316 

.000417 

.000088 

.000088 

.000209 

.000803 

.001439 

.000463 

.000088 

Correlation 

Curve 

(LLD-0) 

.000716 

.000332 

.000002 

.000000 

.000013 

.000738 

.001386 

.000308 

.000000 

Correlation 

Curve (EOIC) 

.000716 

.000332 

.000088 

.000088 

.000013 

.000803 

.001439 

.000309 

.000088 

tn 

I 

io 

Os 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

-• 

bo 

co 
TABLE 5-13. SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR ALL PARTICIPATING 

PLANTS: EMISSION FACTOR ESTIMATES FOR COMPONENTS WITH EO CONCENTRATION BETWEEN 95X AND 

100X 

Component Type 

Valva (liquid) 

Valve (gaa) 

Safety Valva 

Sample Point 

Sealed Flange 

Pump 

Open-Ended Line 

Flange 

Number of 

Components 

5418 

1001 

40 

17 

88 

100 

368 

2576 

Mean Raw 

OVA Screen 

Value 

(ppm) 

31 

144 

17 

4 

543 

5075 

332 

70 

Mean EO 

Amount 

(X) 

100.0 

100.0 

100.0 

100.0 

100.0 

100.0 

100.0 

100.0 

Average 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.001830 

.108900 

.003700 

.001830 

Mean Emission Factors (All 

Leak/ Stratified 

No Leak Emission 

.004042 .000985 

.001453 .000723 

.098500 .039835 

.003300 .000290 

.004821 .004959 

.120060 .104390 

.003675 .001179 

.000290 .000237 

Values in lb/hr/source) 

Correlation 

Curve (EPA) 

.001375 

.000419 

.000308 

.000088 

.006247 

.080079 

.001441 

.000522 

Correlation 

Curve 

(LLD-0) 

.000498 

.000353 

.000234 

.000001 

.006076 

.080031 

.001379 

.000343 

Correlation 

Curve (EOIC) 

.000498 

.000353 

.000308 

.000088 

.006077 

.060079 

.001441 

.000343 

tn 

I 

N> 

^1 SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

oo 
P.88 

5.3.1 Valves in Liquid Service 

There were 8,326 valves in liquid service included in the study, 

representing 47.4X of all the accessible components studied. More than 65X of 

the liquid service valves were on lines containing greater than 95X EO. Only 

3.5X contained 1-2X EO. 

5.3.1.1 Screening Measurements 

The distribution of raw OVA screening values for valves in liquid 

service for each of the EO concentration ranges is shown in Table 5-14 and 

illustrated in Figure 5-4. The range of 0 to 9 ppm represents non-emitting 

components, while components with screening values >9999 ppm are considered to 

be leakers. Components with screening values between 1000 ppm and 9999 ppm 

are referred to as high emitters; those with screening values between 100 and 

999 ppm are low emitters; and those components with'screening values between 

10 and 99 ppm are very low emitters. 

Overall, 0.14X of the tested liquid service valves were found to be 

leaking. Twenty-two (0.26X) were high emitters. There were 67 valves (0.80X) 

in the low-emitter category and 8.6X in the very-low-emitter category. Nonemitting or non-leaking liquid service valves included 7,508 components, or 

90.2X. 

The original SOCMI database included 6.5X leaking liquid service 

valves (6). The remaining components were either high or low emitters. The 

0.14X of liquid service valves found leaking in this study represents a 

reduction of 97.8X from the SOCMI value. Figure 5-5 compares the screening 

values of liquid service valves containing more than 95X EO with the screening 

values of valves with less than 95X EO. The EO concentration does not appear 

to cause significant differences in the distribution. Figure 5-6 compares the 

distribution by EO line concentration of liquid service valve "leakers" with 

5-28 
P.89 

TABLE 5-14. DISTRIBUTION OF RAW OVA SCREENING VALUES 

VALVES IN LIQUID SERVICE 

Ethylene Oxide 

Concentration 

IX TO 2X 

2X TO 5X -

5X TO 10X 

lOX TO 50X 

50X TO 95X 

95X TO 100X 

TOTAL 

(ALL EO RANGES) 

Ethylene Oxide 

Concentration 

IX TO 2X 

2X TO 5X 

5X TO 10X 

10X TO 50X 

50X TO 95X 

95X TO 100X 

Weighted Average" 

Number, 

0-9 

ppm 

280 

379 

223 

742 

898 

4986 

7508 

of Components in ! 

BY EO CONCENTRATION FOR 

Screenine Value Ranee 

10-99 100-999 

ppm 

12 

30 

19 

159 

127 

370 

717 

ppm 

1 

4 

3 

9 

10 

40 

67 

Percentage of Components 

0-9 ppn 

95.24 

91.33 

91.02 

81.36 

86.18 

92.03 

90.18 

i 10-99 ppm 

4.08 

7.23 

7.76 

17.43 

12.19 

6.83 

8.61 

1000-

ppm 

0 

1 

0 

1 

5 

15 

22 

>9999 

ppm 

1 

1 

0 

1 

2 

7 

12 

In Screenine Value Ranee 

100-999 

.34 

.96 

1.22 

.99 

.96 

.74 

.80 

ppm 

1000-

9999 ppm 

0.00 

.24 

0.00 

.11 

.48 

.28 

.26 

Total 

294 

415 

245 

912 

1042 

5418 

8326 

>9999 ppm 

.34 

.24 

0.00 

.11 

.19 

.13 

.14 

Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-29 
All 

(8326 Valves) 

P.90 

90.2 % 

0. 14 Z 

0.80 Z 

0.26 % 

8. 6 Z 

< 10 ppm 

10 - 100 ppm 

'////A 100 - 1000 ppm 

1000 - 10000 ppm 

II I I I 1 II > 10000 0 pp m 

Figure 5-4. EOIC/EPA Fugitive Emission Study: Distribution of EO Screening 

Values for All Liquid Valves 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-30 
P.91 

EOi > 95 Z 

(5418 Valves) 

EOi < 95 Z 

(2908 Valves) 

92 % 

86. 7 % 

0. 17 % 6. 24 7. 

0. 93 r. 

11.9 % 

< 10 ppm 

10 - 100 ppm 

7////A 100 - 1000 ppm 

1000 - 10000 ppm 

11 I I I I II > 1000 0 pp m 

Figure 5-5. EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for Liquid Valves by EO Concentration 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-31 
P.92 

ALL COMPONENTS 

(8326 Valves) 

LEAKERS 

(12 Valves) 

1 2 . 5 % 

6 5 Z 

14 % 16. 7 % 

8. 3 Z 

8. 3 Z 

8. 3 '/. 

5 8 Z 

EOi 1 - 2 Z 

V777771 EO. 2 - 5 X 

E53S3 EO. 5 - 50 X 

I I I I I II EOi 50-95 % 

EO. > 95 Z 

Figure 5-6. EOIC/EPA Fugitive Emissions Study: Distribution of Liquid Valves 

Sampled by EO Concentration 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-32 
P.93 

that of all liquid service valves. Again, no significant differences are 

apparent. Sixty-five percent of all liquid service valves and 58X of leaker 

liquid service valves are on lines containing greater than 95X EO. 

5.3.1.2 Emission Estimates 

The mean emission factors for all valves in liquid service was 

developed by each of the estimation methods previously described. The average 

emission factors (Table 5-6) calculated by each of the methods are lower than 

the SOCMI factor for liquid service valves; the factor calculated by the 

Leak/No Leak approach is 74.IX lower than the SOCMI factor and that calculated 

by the correlation equation with the EOIC default value is 96.5X lower. 

To further examine emission rates as a function of EO concentration, 

separate mean emission factors were developed for liquid service valves in the 

six EO concentration ranges previously discussed. These are presented in 

Table 5-15 and Figure 5-7. The results confirm that emission factors for 

valves in liquid service do not vary directly with EO concentration. 

5.3.1.3 Plant-Specific Analysis 

Separate mean emission factor estimates for each of the twelve 

production facilities are given in Table 5-16 and illustrated in Figure 5-8. 

In Figure 5-8, the plants are ranked according to increasing emission factors. 

The data presented show several significant trends. These include the 

following: 

5-33 
TABLE 5-15. DISTRIBUTION OF ESTIMATED FUGITIVE EMISSION FACTORS BY EO CONCENTRATION: 

ESTIMATES FOR VALVES IN LIQUID SERVICE 

EMISSION FACTOR 

Component Type 

IX to 2Z 

21 to SX 

SX to 10Z 

10X to SOX 

SOX to 95X 

95X to 100Z 

Umber of 

Components 

294 

41S 

245 

912 

1042 

5418 

Maan Raw 

OVA Screen 

Value 

(ppm) 

39 

33 

S 

20 

39 

31 

Mean EO 

Amount 

(X) 

84.2 

95.6 

100.0 

98.6 

97.8 

100.0 

Average 

SOCMI 

.015600 

.015600 

.015600 

.015600 

.015600 

.015600 

Mean Emission Factors (All Values in 

Leak/ Stratified 

Ho Leak Emission 

.003799 .001156 

.004047 .001091 

.003770 .000617 

.003920 .000836 

.004218 .001241 

.004042 .000985 

Correlation 

Curve (EPA) 

.001518 

.001516 

.001081 

.001351 

.001516 

.001375 

lb/hr/source) 

Correlation 

Curve 

(LLD-0) 

.000851 

.000714 

.000190 

.000595 

.000716 

.000498 

Correlation 

Curve (EOIC) 

.000852 

.000714 

.000191 

.000595 

.000716 

.000498 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

tn 

I 

to 

Tl 

CO 

I* 
o. IOOOo. 0100-

tn 

tn 

Q> 

o 55 M 

O eg 3 

CO O CO 

se> 

§£< 

X) 

H 

v_^0.0010- * -

0.0001 

Figure 5-7. 

SOCMI 

Facto r 

Q— ee e 

IK 

EO 

Average 

1-2 * 2-SX 5-1O+ X 10-SO + X SO-OSX 

EO CONCENTRATION 

»BS+ X AVC SOCMI 

D 

-AO. 10O0 

, OlOO 

0010 

O. 0001 

CORR CURVE (EPA) 

LEAK/NO LEAK 

STRATIFIED 

CORR CURVE (1 ) 

CORR CURVE (EOIC) 

EOIC/EPA Fugitive Emissions Study: Comparison of Emission Factors 

to EO Concentrations Using Different Calculational Approaches 

for Valves in Liquid Service 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 
P.96 

TABLE 5-16. COMPARISON OF MEAN EMISSION FACTORS FOR VALVES IN 

LIQUID SERVICE FOR EACH PLANT 

Plant 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

Mean Emi 

SOCMI 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

0.015600 

Relative Std. Dev. 

ssion Factor 

Leak/ 

No Leak 

0.003716 

0.003695 

0.003770 

0.004254 

0.003709 

0.004082 

0.004396 

0.005046 

0.004151 

0.004174 

0.003770 

0.003770 

9.5X 

Usine the 

Stratified 

0.000719 

0.000661 

0.000705 

0.001110 

0.000782 

0.001165 

0.001303 

0.002076 

0.001035 

0.001163 

0.000774 

0.000617 

38.8X 

Method Listed 

Correlation 

Curve (EPA) 

0.001118 

0.001101 

0.001162 

0.001510 

0.001210 

0.001552 

0.001501 

0.002234 

0.001476 

0.001835 

0.001167 

0.000994 

24.5X 

(lb/hr/source) 

Correlation 

Curve 

(LLD - 0) 

0.000199 

0.000378 

0.000202 

0.000529 

0.000383 

0.000645 

0.000593 

0.001288 

0.000907 

0.001403 

0.000213 

0.000000 

75.OX 

Correlation 

Curve (EOIC) 

0.000200 

0.000378 

0.000202 

0.000530 

0.000383 

0.000645 

0.000593 

0.001289 

0.000908 

0.001403 

0.000213 

0.000000 

78. 3X 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-36 
P.97 

0 

z tact eg a 

M c. o 

to o «a 

M O M 

X<£ 

U Ua >_. 

_-

0.01 

0.003- * 

0.00JC 

o. ooos- -

0.0001 

H 1 1 1 h H I 1 1 »-

SOCMI 

Factor 

-©-— 

H h 

\ / 

H 1 1 1 1 1 1 1 1 1 I r 

"0.0100 

H h 

.0010 

O. 0001 

#12 #2 #1 #3 #11 #5 AVG #9 #7 #4 #6 #10 #8 SOCMI 

PLANT NUMBER • CORR CURVE (EPA) 

O LEAK/NO LEAK 

• ••••••• STRATIFIED 

...->.— CORR CURVE (1) 

A CORR CURVE (EOIC) 

Figure 5-8. EOIC/EPA Fugitive Emissions Study: Comparison Among Twelve 

Plants Studied Using Different Calculation Approaches: 

Average Emission Factors for Valves in Liquid Service 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-37 
P.98 

• The variation between the factors for the plants with the 

lowest and highest emissions (plants 2 and 8 respectively) was 

approximately 30X using the Leak/No Leak method. This 

corresponds to a ratio of 1.4 between the highest and lowest 

rates. Using all other methods, Plant 12 reported the lowest 

emission factor estimates. The ratio of the highest to lowest 

emission factor using the other estimation methods was 3.4 for 

the stratified method, 2.2 for the correlation curve (EPA), and 

"not defined" for the correlation curve (EOIC) (lowest 

estimated factor was 0 lb/hr for plant 12). 

• The Leak/No Leak estimated factors were generally 3 to 10 times 

higher than those estimated by the stratified method or by the 

correlation curve (EPA). However, the ratio was the lowest for 

plants with the higher emission factors. 

• The emission factors estimated using the correlation curve 

(EPA) were consistently higher than the factors estimated using 

the stratified method and the other correlation curves. 

However, among the plants with higher emission factors, the 

differences were small. 

5.3.1.4 Summary 

Overall, based on an analysis of all 8,326 valves in liquid service 

included in this study, the following conclusions can be drawn: 

• The average number of leaking components found in this study is 

97.8X less than the number found leaking in the previous 

studies; 

• The mean estimated emission factor developed for valves in 

liquid service using the correlation curve with new EOIC 

default values is 96.5X lower than the SOCMI emission factor; 

5-38 
P.99 

• Emission factors estimated using the correlation curve method 

with EOIC default values show most clearly the differences 

among the 12 plants studied in this project; 

• The maximum difference in estimated emission factors among the 

12 plants varies from 30X using the Leak/No Leak method to an 

undefined factor using the correlation curve method with the 

EOIC default value; and 

• For valves in liquid service, there appears to be no direct 

relation between EO concentration in the line and the estimated 

emission factor. 

5.3.2 Valves in Gas Service 

There were 3,306 valves in gas service included in this study, 

representing 18.8X of all the components studied. Slightly over 30X of the 

valves were on lines containing more than 95X EO. About 23X of the valves 

were on lines containing between 1 and 2X EO. 

5.3.2.1 Screening Measurements 

Figure 5-9 shows the distribution of screening values for all gas 

service valves. Table 5-17 and Figure 5-10 show the distribution of OVA 

screening values for several EO concentration ranges. Overall, 1.21X (40 

valves) were measured as leaking. This represents a 90.2X reduction from the 

11.4X of leaking gas service valves found in the original SOCMI database. 

There were 1.3X (43 valves) in the high-emitter class, 2.12X (70 valves) in 

the low-emitter class, and 9.89X (327 valves) in the very-low-emitter class. 

More than 85X (2826 valves) were not emitting. 

5-39 
P.1 

ALL GAS VALVES 

3306 

85.5% 

1 . 2 Z 

1 . 3 Z 

< 10 ppm 

10 - 100 ppm 

>m '/////A 100 - 1000 ppr 

1000 - 10000 ppm 

> 10000 ppm 

Figure 5-9. EOIC/EPA Fugitive Emission Study: Distribution of EO Screening 

Values for all Gas Valves 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-40 
P.2 

TABLE 5-17. DISTRIBUTION 

VALVES IN GAS 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to 5Z 

5Z to 10X 

10X to 50X 

50X to 95X 

95X to 100Z 

Total 

(all EO Ranges) 

Ethylene Oxide 

Concentration 

IX TO 2X 

2X TO 5X 

5X TO 10X 

10X TO 50X 

50% TO 95X 

95Z TO 100X 

Weighted Average* 

Number 

0-9 

ppm 

661 

518 

28 

378 

309 

932 

2826 

OF RAW OVA 

SERVICE 

SCREENING VALUES 

of Components 

10-99 

ppm 

46 

169 

7 

36 

17 

52 

327 

Percentage of 

0-9 ppm 

85.62 

69.91 

73.68 

89.79 

92.79 

93.11 

85.48 

10-< 

5 

22 

18 

8 

5 

5 

9. 

BY EO CONCENTRATION FOR 

in Screening Value 

100-999 

ppm 

17 

31 

2 

6 

5 

9 

70 

Components In Sc 

J 9 ppm 

96 

81 

.42 

55 

11 

19 

89 

100-999 

2.20 

4.18 

5.26 

1.43 

1.50 

0.90 

2.12 

1000-

ppm 

17 

18 

1 

1 

1 

5 

43 

Range 

>9999 

ppm 

31 

5 

0 

O 

1 

3 

40 

Total 

772 

741 

38 

421 

333 

1001 

3306 

reenine Value Ranee 

ppm 

1000-

9999 ppm 

2 

2 

2 

0 

0 

0 

1. 

20 

43 

63 

24 

30 

50 

30 

>9999 ppm 

4.02 

0.67 

0.00 

0.00 

0.30 

0.30 

1.21 

a Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-41 
P.3 

EOi 1 - 2 X 

(774 Volvos) 

EOi 2 - 5 X 

C739 Volvos) 

EOi > 5 X 

C1791 Valves) 

70 Z 

35. 9 z 

92 Z 

22. 7 Z 

< 10 ppm 

%8%ff 10 - 100 ppm 

Y///A 100 - 1000 ppm 

1000 - 10000 ppm 

Hi I I H > 10000 ppm 

Figure 5-10. EOIC/EPA Fugitive Emission Study: Distribution of Screening 

Values for Gas Valves by EO Concentration 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-42 
P.4 

Figure 5-11 shows the distribution of all gas service valves and 

leaking gas service valves as a function of EO concentration. According to 

the figure, streams containing 1-2X EO account for only 23.4X of all gas 

service valves and yet gas valves with 1-2X EO account for 78X of the leaking 

gas service valves. 

5.3.2.2 Emission Estimates 

Mean emission factors for valves in gas service were developed using 

each of the estimation methods (Table 5-6). The reduction in emission factor 

varied from 89.OX for the leak/no leak approach to 96.42 using the correlation 

curve with the EOIC default value. 

Separate mean emission factors were developed for each of the six EO 

concentration ranges. These are shown in Table 5-18 and Figure 5-12. Both 

the table and the figure show that the emission factors varied considerably 

with EO concentration. There is a pronounced dip in the middle of the EO 

concentration range. 

5.3.2.3 pj,ant-Specjfl,c Analysis 

Separate mean emission factor estimates for the 12 participating 

plants are shown in Table 5-19 and illustrated in Figure 5-13. Several trends 

are apparent in the data for valves in gas service, as the following points 

show: 

• The estimated emission factors for the plants varied widely. 

Using the Leak/No Leak method, the ratio of the highest to 

lowest emission factor was 10.8. The ratio of the highest to 

lowest estimated emission factor was 16.6 using both the 

stratified method and the correlation curve (EPA). Using the 

correlation curve (EOIC), a ratio of the highest to lowest 

emission factor could not be calculated since the estimated 

emission factor from plant 8 was zero lb/hr/source. 

5-43 
P.5 

ALL GAS VALVES 

C 3306 VALVES) 

22.« 

LEAKERS 

(40 Valves) 

13.9% 

23. 4 Z 11.5 X 

10.1% 30.3% 

12.5 X 

EOi 1 - 2 Z 

77777A EO. 2- 5 z 

^^^s l EOi 5 - 50 Z 

I 1 1 I I II EO. 50-9 5 % 

EO. > 9 5 Z 

Figure 5-11. EOIC/EPA Fugitive Emission Study: Distribution of Gas Valves 

Sampled by EO Concentration al l Components and "Leakers" 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-44 
TABLE 5-18. DISTRIBUTION OF ESTIMATED FUGITIVE EMISSION FACTORS BY EO CONCENTRATION: 

FACTOR ESTIMATES FOR VALVES IN GAS SERVICE 

EMISSION 

Ul 

I 

Ol 

Component Type 

IX TO 21 

2X TO SZ 

SX TO 10X 

10X TO SOX 

50X TO esx 

8SX TO 1001 

Number of 

Components 

772 

7*1 

38 

421 

333 

1001 

Maan Raw 

OVA Screen 

Value 

(ppm) 

8S9 

ISO 

48 

11 

53 

144 

Mean EO 

Amount 

(X) 

68.5 

37.3 

46.5 

99.7 

99.0 

100.0 

Average 

SOCMI 

.012300 

.012300 

.012300 

.012300 

.012300 

.012300 

Maan 

Leak/ 

Ho Leak 

.001921 

.000733 

.000493 

.001057 

.001640 

.001433 

Emission Factora (All Values in 

Stratified 

Emission 

.001439 

.000472 

.000144 

.000325 

.000902 

.000723 

Correlation 

Curve (EPA) 

.001068 

.000277 

.000043 

.000104 

.000417 

.000419 

lb/hr/source) 

Correlation 

Curve 

(LLD-0) 

.001023 

.000253 

.000016 

.000043 

.000352 

.000353 

Correlation 

Curve (EOIC) 

.001024 

.000254 

.000016 

.000043 

.000352 

.000353 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

b> 
P.7 

0. 1000 

0.0100-|-

o 

2 U 

O W 3 

H « O 

n o n 

w H v. 

M o u 

U ba \ 0. 0010' 

J3 

0.0001--

0.00001 

S0CMI 

Factor 

E0 

.Average 

1-2X 2-SX 3-10X 10-S0Z S0-0SX »Q5X 

E0 CONCENTRATION 

AVB S0CM -+-I 

-•-0.0100 

-0. 1000 

3.0010 

"0.0001 

a. ooooi 

- • — C0RR CURVE (EPA) 

-O LEAK/NO LEAK 

a - STRATIFIED 

_«.„. C0RR CURVE (1) 

._ CORR CURVE (EOIC) 

Figure 5-12. EOIC/EPA Fugitive Emissions Study: Comparison of Emission 

Factors with EO Concentration Using Different Calculational 

Approaches for Valves in Gas Service 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-46 
P.8 

TABLE 5-19. COMPARISON OF MEAN EMISSION FACTORS FOR VALVES IN GAS SERVICE 

FOR EACH PLANT 

Plant 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

Mean 

SOCMI 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

0.012300 

Relative Std. Dev. 

Emission 

Leak/ 

No Leak 

0.001341 

0.000780 

0.000262 

0.000948 

0.001144 

0.001550 

0.000940 

0.001060 

0.001775 

0.001023 

0.002832 

0.002492 

51.6X 

Factor Using the Method Li 

Stratified 

0.000790 

0.000237 

0.000130 

0.000277 

0.000582 

0.001238 

0.000330 

0.000310 

0.001176 

0.000329 

0.002155 

0.001753 

81.9X 

Correlation 

Curve (EPA) 

0.000467 

0.000076 

0.000089 

0.000064 

0.000201 

0.001154 

0.000124 

0.000071 

0.001000 

0.000123 

0.001173 

0.001103 

98.6X 

sted (lb/hr/; 

Correlation 

Curve 

source) 

Correlation 

LLD - 0 Curve (EOIC) 

0.000416 

0.000030 

0.000077 

0.000001 

0.000152 

0.001126 

0.000066 

0.000000 

0.000959 

0.000087 

0.001109 

0.001033 

112.OX 

0.000417 

0.000031 

0.000077 

0.000001 

0.000153 

0.001127 

0.000066 

0.000000 

0.000959 

0.000088 

0.001109 

0.001033 

114.6X 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-47 
P.9 

o. oiooo--

22 

(0 O 

SB 

as <a 

U fta \ 

Va 0. 00100--

r-1 0. 

0. oooto- -

0. 

0.00001 

^ 1 1 1 1 1 I 1 - H r H h 

SOCMI 

Factor 

EO 

Average 

.01000 

.00100 

.00010 

#4 #8 #2 #3 #7 #10 #5 #1 Avg #6 #9 #12#US0CM I 

PLANT NUMBER 

O.0OO0! 

CORR CURVE (EPA) 

LEAK/NO LEAK 

• ••••• •• STRATIFIED 

»... CORR CURVE (1) 

A CORR CURVE (EOIC) 

Figure 5-13. EOIC/EPA Fugitive Emission Study: Comparison Among Twelve 

Plants Studied Using Different Calculation Approaches: 

Average Emission Factors for Valves in Gas Service 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-48 
P.10 

• The emission factors calculated using the Leak/No Leak method 

were 2 to 3 times higher than those calculated by the 

stratified method. This ratio was lower in plants with higher 

emission factors. 

• The estimated emission factors consistently decline from the 

left-hand to the right-hand columns in Table 5-19. For the 

plants with relatively high emission factors, however, the 

decline is much less pronounced than for those with lower 

emission factors. 

• Plant emission factors varied and the differences become more 

noticeable as the "allowable" emission factor decreased; i.e., 

from left to right in both Table 5-19 and Figure 5-13. 

5.3.2. 4 Snnrniflpy 

Overall, based on the analysis of 3,306 valves in gas service 

included in this study, the following conclusions can be drawn: 

• These were 90.2X fewer leaking gas service valves in this study 

than the original SOCMI study. 

• The percentage of leaking gas service valves is 10 times higher 

than in the percentage of leaking liquid phase valves. 

• The percentage of high emitter gas phase valves is 5 times 

higher than the percentage of high emitter liquid phase valves. 

• The percentage of low emitter gas phase valves is more than 3 

times as high as the percentage of low emitter liquid phase 

valves. 

• The emissions from gas service valves vary with the EO 

concentration in the process line. 

5-49 
P.11 

• The mean estimated emission factor for gas service valves 

calculated using the correlation curve with the EOIC default 

value is 96.4X lower than the SOCMI emission factor. 

* Emission factors estimated using the correlation curve method 

with EOIC default value most clearly show the differences among 

the twelve plants included in this study. 

5.3.3 Flanges 

There were 4,742 flanges included in this study. The protocol 

required that only a small percentage of the flanges in a plant be tested. 

The formula used for determining the number of flanges to be tested was: 

n - N(l-0.05)**(50/N) (Eq. 5) 

where: N - the number of flanges in the tested area 

This series converges to a maximum number of about 150 components to 

be tested as the number of flanges increases. Sealed flanges were considered 

to belong in a different category and will be treated separately later in this 

report. 

Of the flanges tested, more than 54X were on lines containing 

greater than 95X EO. About 12X were on lines containing 1-2X EO. 

5.3.3.1 Screening Measurements 

Figure 5-14 shows the distribution of screening values for all 

flanges. Table 5-20 and Figure 5-15 shows the distribution of OVA screening 

values for several EO concentration ranges. The percentage of leaking flanges 

was 0.61X (29 flanges), which represents a reduction of 71.OX from the 2.IX 

of leaking components in the SOCMI study. High emitters comprised 0.51X (24 

flanges) of the total, while low emitters made up 1.35X (64 flanges) and very 

5-50 
ALL FLANGES 

4742 

P.12 

8 4 . 7 Z 

12. 8 Z 

• 10 ppm 

aaaaaa io - ioo ppm 

Y///A 100 - 1000 ppm 

1000 - 10000 ppm 

II I II 1 II > 1000 0 pp m 

Figure 5-14. EOIC/EPA Fugitive Emission Study: Distribution of Screening 

Values for all Flanges by EO Concentration 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-51 
P.13 

TABLE 5-20. DISTRIBUTION OF RAW OVA SCREENING VALUES BY EO CONCENTRATION 

FOR FLANGES 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to 5X 

5X to 10X 

10X to SOX 

50X to 95X 

95X to 100X 

Total 

(All EO Ranges) 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to 5X 

5X to 10X 

10X to 50X 

SOX to 95X 

95X to 100X 

Weighted Average3 

Number of Conroonents 

0-9 

ppm 

504 

246 

73 

364 

509 

2323 

4019 

in Screening Value 

10-99 100-999 

ppm 

30 

73 

16 

153 

101 

233 

606 

ppm 

17 

17 

4 

12 

5 

9 

64 

Percentage of Comoonents 

0-9 ppm 

86.75 

71.72 

76.84 

68.68 

82.50 

90.18 

84.75 

10-99 ppm 

5.16 

21.28 

16.84 

28.87 

16.37 

9.05 

12.78 

1000-

ppm 

8 

6 

1 

1 

2 

6 

24 

Range 

>9999 

ppm 

22 

1 

1 

0 

0 

5 

29 

Total 

581 

343 

95 

530 

617 

2576 

4742 

In Screening Value Range 

100-999 

2.93 

4.96 

4.21 

2.26 

0.81 

0.35 

1.35 

ppm 

1000-

9999 ppm 

1 

1 

1 

0 

0 

0 

0. 

38 

75 

05 

19 

32 

23 

51 

>9999 ppm 

3.79 

0.29 

1.05 

0.00 

0.00 

0.19 

0.61 

Weighted Average - Total nvunberof components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-52 
P.M 

EOi 1 - 2 X 

<582 FLANGES) 

EOi 2 - 95 X 

(1584 Flangas) 

EOi > 95 X 

C2576 Flanges) 

75 X 

87 % 90 Z 

22 % 

** 10 ppm 

10 - 100 ppm 

100 - 1000 ppm 

1000 - 10000 ppm 

I I 1 I I II > 1000 0 pp m 

Figure 5-15. EOIC/EPA Fugitive Emission Study: Distribution of Screening 

Values for Flanges by EO Concentration 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-53 
P.15 

low emitters were 12.78X (606 flanges) of the total. The non-emitting class 

comprised 84.75X (4019 flanges) of all flanges tested. Figure 5-16 

illustrates the distribution of all flanges and leaking flanges by EO 

concentration. Seventy-five percent of the leaking flanges were on lines 

containing 1-2X EO. Lines with more than 95X EO had 17X of the measured 

leaking flanges. The other 7X of leaking flanges were on lines containing 

2-10X EO. There were no leaking flanges on lines with 10-95X EO. 

5.3-3.2 Emission Estimates 

The average emission factors for flanges calculated by the other 

methods were all lower than the SOCMI emission factor (see Table 5-6). 

However, the estimated emission factors are fairly constant; the highest 

(0.000714 lb/hr/source using the correlation curve (EPA) was only 1.5 times 

higher than the lowest factor (.000466 lb/hr using the stratified method). 

The correlation curve (EOIC) emission factor of 0.000555 lb/hr/source is 69.7X 

lower than the SOCMI emission factor. 

Mean emission factors for each of the EO concentration ranges were 

developed and are presented in Table 5-21 and illustrated in Figure 5-17. 

These data clearly show that flanges in the lines containing 1-2X EO have much 

higher emission factors than flanges in all other lines. The ratios of the 

emission factors in the 1-2X EO concentration range to those in the next 

highest concentration (2-5X EO lines) varied from 5.05 for the Leak/No Leak 

method to 2.8 for the correlation curve (EPA). As seen in Figure 5-17, each 

emission rate curve is a relatively smooth function, showing a rapid decline 

followed by a relatively straight line (or small increase) as the EO 

concentration increases. 

5.3.3.3 Plant-Specific Analvsis 

Emission factors for the 12 participating plants are shown in Table 

5-22 and in Figure 5-18. Using all the estimation methods, plants 1, 11, and 

12 have noticeably higher emission factors than the other plants. In general, 

there is a wide distribution of emission factors among the plants. 

5-54 
P.16 

ALL FLANGES 

C4742 FLANGES) 

LEAKERS 

(28 LEAKERS) 

13 Z 7 Z 

13 Z 

75 X 

2.3Z 

54 Z 

18 Z 

EOi 1 - 2 Z 

V7777?i EO. 2 - 5 z 

F ^ 3 EO. 5 - 50 Z 

EO. 50-95 Z 

EO. > 95 X 

E 

Figure 5-16. EOIC/EPA Fugitive Emission Study: Comparison of Emission Factors 

With EO Concentration using Different Calculational Approaches 

For Flanges 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-55 
TABLE 5-21. DISTRIBUTION OF ESTIMATED FUGITIVE EMISSION FACTORS BY EO CONCENTRATION: 

EMISSION FACTOR ESTIMATES FOR FLANGES 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to SX 

SX to 10X 

10X to SOX 

50X to 95X 

95X to 100X 

Number of 

Component* 

581 

343 

95 

530 

617 

2576 

Mean Raw 

OVA Screen 

Value 

(ppm) 

1401 

113 

16S 

22 

22 

70 

Mean EO 

Amount 

(X) 

70.6 

70.2 

73.0 

98.3 

99.7 

100.0 

Average 

SOCMI 

.001630 

.001830 

.001830 

.001830 

.001830 

.001830 

Mean 

Leak/ 

No Leak 

.001900 

.000376 

.000196 

.000128 

.000263 

.000290 

Emission Factors 

Stratified 

Emission 

.001948 

.000622 

.000157 

.000080 

.000240 

.000257 

(All Values in 

Correlation 

Curve (EFA) 

.002111 

.000754 

.000351 

.000443 

.000463 

.000522 

lb/hr/source) 

Correlation 

Curve 

(LLD-0) 

.001986 

.000656 

.000235 

.000296 

.000308 

.000343 

Correlation 

Curve (EOIC) 

.001987 

.000656 

.000235 

.000296 

.000309 

.000343 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

Ol 

I 

Ol 

Ov 
P.18 

0.0100' 

o. ooio- -

HI 

o 

z u 

o w n 

H « o 

w o w 

W (r> \ 

H U h 

X<£ 

W ba V . 

J3 

o. oooi--

SOCMI 

Factor 

E0 

Average 

0.00001+ 

o 1-2X 2-5X S-10X — H ~ 

10-SOX 30-83X 

4-

>ssx AVG 

4-

-0.0100 

.0010 

.0001 

SOCMI 

0.00001 

EO CONCENTRATION 

• CORR CURVE (EPA) 

O — LEAK/NO LEAK 

••••a- STRATIFIED 

H-—CORR CURVE (1) 

A CORR CURVE (EOIC) 

Figure 5-17. EOIC/EPA Fugitive Emissions Study: Comparison of Emission 

Factors to EO Concentration Using Different Calculational 

Approaches For Flanges 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-57 
P.19 

TABLE 5-22. EMISSION FACTORS FOR FLANGES FOR EACH PLANT MEAN EMISSION 

FACTOR (ALL VALVES IN LB/HR/SOURCE) 

Plant 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

Mean Emi 

SOCMI 

0.00183 

0.00183 

0.00183 

0.00183 

0.00183 

0.00183 

0.00183 

0.00183 

0.00183 

0.00183 

0.00183 

0.00183 

Relative Std. Dev. 

ssion Factor 

Leak/ 

No Leak 

0.001705 

0.000117 

0.000093 

0.000126 

0.000202 

0.000629 

0.000126 

0.000130 

0.000198 

0.000128 

0.001231 

0.001097 

110.5X 

• Using the 

Stratified 

0.001814 

0.000040 

0.000048 

0.000043 

0.000397 

0.000683 

0.000187 

0.000044 

0.000162 

0.000126 

0.001659 

0.001049 

118.8% 

Method Listed 

Correlation 

Curve (EPA) 

0.002173 

0.000205 

0.000179 

0.000198 

0.000843 

0.000848 

0.000335 

0.000205 

0.000386 

0.000637 

0.001608 

0.001246 

83.5X 

(lb/hr/source} 

Correlation 

Curve 

(LLD - 0) 

0.002005 

0.000053 

0.000034 

0.000000 

0.000697 

0.000736 

0.000146 

0.000000 

0.000249 

0.000533 

0.001422 

0.001044 

106.7X 

Correlation 

Curve (EOIC) 

0.002005 

0.000054 

0.000034 

0.000000 

0.000697 

0.000736 

0.000146 

0.000000 

0.000249 

0.000534 

0.001422 

. 0.001044 

111.4X 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-58 
P.20 

0.01000-

0.00900" 

9) 

O 

2 U 

223 

w o n 

H U h 

Uia N 

0.00100-+-

0.00030" 

0. 00020* * 

0.0001C 

0.00001' 

H \ 1 r H 1 1 1 1- 4.01000 

.00100 

.00010 

+-J-+ \ h O. 00001 

# 3 # 2 # 4 # 8 # 7 # 9 #1 0 AVG # 6 # 5 #1 2 #1 1 #1 SOCMI 

PLANT NUMBER CORR CURVE (EPA) 

LEAK/NO LEAK 

n . . . STRATIFIED 

• — - CORR CURVE (1) 

^ CORR CURVE (EOIC) 

Figure 5-18. EOIC/EPA Fugitive Emissions Study: Comparison Among Twelve 

Plants Studied Using Different Calculational Approaches: 

Average Emission Factors for Flanges 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-59 
P.21 

5.3.3.4 Summary 

Based on an analysis of the 4,742 flanges included in this study, 

the following conclusions seem appropriate: 

• There were 71X fewer leaking flanges found in this study than 

in the SOCMI study. 

• The mean emission factor for flanges in this study is 69.7X 

lower chan the SOCMI emission factor. 

• Three quarters of the leaking flanges were in lines containing 

1-2X EO. 

• There were no leaking flanges in lines containing more than 10X 

EO. 

» There are significant differences in emission factors among the 

plants participating in this study. 

5.3.4 Open-Ended Lines 

There were 754 open-ended lines tested in this study. Almost half 

(48.8X) were on lines with more than 95X EO, while only 2.7X were on lines 

with 1-2X EO. 

5.3.4.1 Screening Measurements 

Figure 5-19 illustrates the distribution of screening values for all 

open-ended lines. The distribution of screening values for all EO 

concentration ranges is shown in Table 5-23 and illustrated in Figure 5-20. 

There were 1.19X (9 open-ended lines) with screening values of 10,000 ppm or 

more. This represents a reduction of 69.5X from the 3.9X leaking open-ended 

lilies in the SOCMI study. All leaking open-ended lines in this study were on 

lines containing 10X or more EO. More than 76X (575 open-ended lines) were 

non-emitters. 

5-60 
P.22 

ALL OPEN-ENDED LINES 

754 

76.3% 

14.3 X 

< 10 ppm 

10 - 100 ppm 

V///A 100 - 1000 ppr 3m 

1000 - 10000 ppm 

WW > 10000 ppm 

Figure 5-19. EOIC/EPA Fugitive Emissions Study: Distribution of EO 

Screening Values for All Open-Ended Lines 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-61 
P.23 

TABLE 5-23. DISTRIBUTION OF RAW OVA SCREENING VALUES BY EO CONCENTRATION 

FOR OPEN-ENDED LINES 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to 5X 

5X to 10X 

10X to 50X 

50X to 95X 

95X to 100X 

Total 

(All EO Ranges) 

Number 

0-9 

ppm 

17 

100 

14 

109 

41 

294 

575 

of Components in Screening Value 

10-99 

ppm 

1 

23 

1 

30 

4 

49 

108 

100-999 

ppm 

1 

22 

0 

9 

3 

13 

48 

1000-

ppm I-I 3 

0 

2 

1 

7 

14 

Range 

>9999 

ppm 

0 

0 

0 

2 

2 

5 

9 

Total 

20 

148 

15 

152 

51 

368 

754 

Percentage of Components In Screening Value Ranee 

Ethylene. Oxide 

Concentration 

IX to 2X 

2X to 5X 

5X to 10X 

10X to 50X 

50X to 95X 

95X to 100X 

Weighted Average" 

0-9 ppm 

85.00 

67.57 

93.33 

71.71 

80.39 

79.89 

76.26 

10-99 ppm 

5.00 

15.54 

6.67 

19.74 

7.84 

13.32 

14.32 

100-999 ppm 

5.00 

14.86 

0.00 

5.92 

5.88 

3.53 

6.37 

1000-

9999 ppm 

5.00 

2.03 

0.00 

1.32 

1.96 

1.90 

1.86 

>9999 ppm 

0.00 

0.00 

0.00 

1.32 

3.92 

1.36 

1.19 

Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-62 
P.24 

ALL OPEN-ENDED LINES 

754 

2 2 . 1 X 

6.BX — 

19. 6 X 

•Z~*£x2^Z& 2. 6 % 

48. 8 X 

EOi 1 - 2 X 

V777Z\ EO. 2- 5 X 

^sS^sl EOi 5 - 5 0 X 

I II I III EO. 50-9 5 X 

EO. > 9 5 X 

Figure 5-20. EOIC/EPA Fugitive Emissions Study: Distribution of Open-Ended 

Lines Sampled by EO Concentration 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-63 
P.25 

5.3.4.2 Emission Estimates 

As previously shown in Table 5-6, the mean estimated emission 

factors for open-ended lines were lower than the SOCMI factor. The Leak/No 

Leak factor was 11.5X lower than the SOCMI factor and the stratified factor 

was 74.2X lower than the SOCMI factor. The correlation curve with the EOIC 

default value produced an emission factor 70.8X lower than the SOCMI value. 

Emission factors for each EO concentration range calculated by each 

of the estimation methods are shown in Table 5-24 and Figure 5-21. Except in 

the 2-5X EO range, the Leak/No Leak factors seem to be independent of EO 

concentration. In general, the emission factors decline from left to right in 

the table, indicating that the emissions come from a relatively few emitting 

components. 

5.3.4.3 Plant-Specific Analvsis 

Emission estimates for individual plants are shown in Table 5-25 and 

Figure 5-22. Four of the plants did not report any screening values for openended lines. The testing protocol specifically exempted open-ended lines that 

were capped. 

Half of the plants (1, 9, 10, and 11) show a trend of relatively 

high emission factors using all estimation methods. Plants 2 and 7 show a 

decline in emissions using the methods from left to right in the table, but 

not the rapid decline seen for other components. Plants 3 and 5 show the same 

relatively rapid decline for open-ended lines that appears for other 

components. This rapid decline seems to indicate that relatively few 

components are emitting at relatively high levels. The emissions from highemitting open-ended lines are rather constant throughout the estimation 

methodology. However, as the emission level is allowed to decline (moving 

left to right in the table), a steady decline indicates few or no emissions 

from the sources involved. 

5-64 
TABLE 5-24. DISTRIBUTION OF ESTIMATED FUGITIVE EMISSION FACTORS BY EO CONCENTRATION: 

EMISSION FACTOR ESTIMATES FOR OPEN-ENDED LINES 

Ethylene Oxide 

Concentration 

IX to 21 

2X to SX 

SX to 10X 

10X to SOX 

SOX to 9SX 

9SX to 100X 

dumber of 

Cooponenta 

20 

148 

IS 

1S2 

51 

368 

Mean Raw 

OVA Screen 

Value 

(ppm) 

115 

81 

3 

192 

3400 

332 

Mean EO 

Amount 

(X) 

100.0 

49.3 

100.0 

99.8 

91.2 

100.0 

Average 

SOCMI 

.003700 

.003700 

.003700 

.003700 

.003700 

.003700 

Mean Emission Factor* (All Values in lb/hr/aource) 

Leak/ Stratified 

No Leak Emission 

.003300 .001241 

.001627 .000160 

.003300 .000290 

.003748 .001033 

.003730 .001453 

.003675 .001179 

Correlation 

Curve (EPA) 

.000959 

.000151 

.000109 

.001093 

.001439 

.001441 

Correlation 

Curve 

(LLD-0) 

.000891 

.000118 

.000027 

.001033 

.001386 

.001379 

Correlation 

Curve (EOIC) 

.000959 

.000151 

.000109 

.001093 

.001439 

.001441 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

ut 

I 

Os 

po 

0) 
P.27 

0. 1000-t0.0100+ 

22g 

w o n 

w0£ > 0.001C 

X <JS 

Wfca X. 

J3 

0.0001 + 

o. aoooi' 4- 4-

SOCMI 

Factor 

EO 

Average 

•a. tooo 

.0100 

.0010 

.0001 

•a. ooooi 

"1-2X 2-SX 3-1 OX 10-SOX 30-OS3C »83X 

EO CONCENTRATION 

SOCMI 

Q CORR CURVE (EPA) 

*~ LEAK/NO LEAK 

D '" STRATIFIED 

-•—- CORR CURVE (1) 

- A— CORR CURVE (EOIC) 

Figure 5-21. EOIC/EPA Fugitive Emissions Study: Comparison of Emission 

Factors to EO Concentration Using Different Calculational 

Approaches for Open-Ended Lines 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-66 
P.28 

TABLE 5-25. EMISSION FACTORS FOR OPEN-ENDED LINES FOR EACH PLANT 

MEAN EMISSION FACTOR USING THE METHOD LISTED (LB/HR)' 

Plant 

Number 1-1 2 

3 

5 

7 

9 

10 

11 

Mean Emi 

SOCMI 

0.003700 

0.003700 

0.003700 

0.003700 

0.003700 

0.003700 

0.003700 

0.003700 

Relative Std. Dev. 

ssion Factor 

Leak/ 

No Leak 

0.003102 

0.003220 

0.002735 

0.003300 

0.003251 

0.003300 

0.003793 

0.003300 

8.4X 

Using the 

Stratified 

0.001510 

0.006590 

0.000240 

0.000290 

0.000592 

0.006227 

0.001499 

0.000290 

116.2X 

Method Listed 

Correlation 

Curve (EPA) 

0.002479 

0.000600 

0.000133 

0.000086 

0.000403 

0.004842 

0.001457 

0.004470 

99.8X 

(lb/hr/source) 

Correlation 

Curve Correlation 

LLD - 0 Curve (EOIC) 

0.002436 

0.000542 

0.000068 

0.000018 

0.000323 

0.004785 

0.001416 

0.004470 

103.6X 

. 0.002480 

0.000601 

0.000134 

0.000088 

0.000405 

0.004844 

0.001458 

0.004470 

106.6X 

a The testing protocol specifically exempted capped open-ended lines from 

being .tested. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-67 
P.29 

0.01000-

C 0.00100 + 

fl> 

u 

z u 0 « a 

MIX 0 

01 O M 

« H N. 

H O h 

XaSj J5 

Mlia S 

aQ 

a oooio--

aooaoi. 

H r 4 r 4 1 1 h 

H 1 1 1 1 1 1 h + 4 r 

H fSOCMI 

Factor 

+ H r 

O.01000 

.0010 0 

.00010 

O. 00001 

#4 #6 #8 #12 #5 # 3 #7 #2 AVG #10 #1 #11 #9 SOCMI 

PLANT NUMBER 

—-•-—CORR CURVE (EPA) 

— O LEAK/NO LEAK 

• •••••• STRATIFIED 

—p.... CORR CURVE (1) 

.. A_. CORR CURVE (EOIC) 

Figure 5-22. EOIC/EPA Emissions Study: Comparison Among Twelve Plants 

Sampled Using Different Calculation Approaches: 

Average Emission Factors for Open-Ended Lines 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-68 
P.30 

5.3.4. 4 Symttiflrv 

The following conclusions can be drawn from the data concerning the 

754 open-ended lines reported in this study: 

• Those were 69.5X fewer leaking open-ended lines found in this 

study than in the SOCMI study. 

• There were no leaking open-ended lines on lines containing 

less than 10X EO. 

• The correlation curve using the EOIC default value predicts an 

emission factor 70.8X lower than the SOCMI emission factor. 

• The emission factors for the various plants showed 

different trends, indicating that significant differences 

exist among plants. 

5.3.5 ?umps 

There were 190 pumps included in this study. Almost 53X were on 

lines with more than 95X EO, while 3.7X were on lines with 1-2X EO. About 73X 

of the pumps were on lines with more than 50X EO. 

5.3.5.1 Screening Measurements 

Figure 5-23 illustrates the distribution of screening values for all 

pumps. Table 5-26 and Figure 5-24 show the distribution of screening values 

as a function of EO concentration. Figure 5-25 shows the distribution of all 

pumps and leaking pumps by EO concentration. All 8 (4.21X) of the leaking 

pumps were on lines containing more than 95X EO. The 4.21X of leaking pumps 

represents a reduction of 52.2X from the 8.8X leaking pumps found in the SOCMI 

study. Pumps showed the highest percentage of leaking components in the 

5-69 
P.31 

ALL PUMPS 

190 

6 0 X 

mm 4.2* 

3 . 2 X 

16. 8 X 15.8% 

< 10 ppm 

10 - 100 ppm 

Y///A 100 - 1000 ppm 

1000 - 10000 ppm 

I'llll H > 10000 ppm 

Figure 5-23. EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for All Pumps 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-70 
P.32 

TABLE 5-26. 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to 5X 

5X to 10X 

10X to 50X 

SOX to 95X 

95X to 100X 

Total 

(All EO Ranges) 

DISTRIBUTION OF RAW 

FOR PUMPS 

Number 

0-9 

ppm 

5 

6 

7 

15 

22 

59 

114 

OVA 

of Components 

10-99 

ppm I-I 0 

0 

5 

12 

14 

32 

SCREENING VALUES 

in Screening Val 

100-999 

ppm I-I 2 I-I 8 

4 

14 

30 

1000-

ppm 

0 

0 

0 

0 I-I 5 

6 

BY 

ue 

EO CONCENTRATION 

Range 

>9999 

ppm 

0 

0 

0 

0 

0 

8 

8 

Total 

7 

8 

8 

28 

39 

100 

190 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to 5X 

5X to 10X 

10X to 50X 

50X to 95X 

95X to 100X 

Weighted Average* 

Percentage 

0-9 ppm 

71.43 

75.00 

87.50 

53.57 

56.41 

59.00 

60.00 

of Components In Screening Value 

10-99 ppm 

14.29 

0.00 

0.00 

17.86 

30.77 

14.00 

16.84 

100-999 

14.29 

25.00 

12.50 

28.57 

10.26 

14.00 

15.79 

p p m 

1000-

Range 

9999 ppm >9999 ppm 

0.00 

0.00 

0.00 

0.00 

2.56 

5.00 

3.16 

0.00 

0.00 

0.00 

0.00 

0.00 

8.00 

4.21 

a Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-71 
P.33 

EOi < 95 X 

(90 Pumps) 

EOi > 95 X 

CI00 Pumps) 

61 Z 59 Z 

1 Z 

18 Z 

14 Z 

20 Z 14 Z 

< 10 ppm 

10 - 100 ppm 

/^</ 3 100 - 1000 ppm 

1000 - 10000 ppm 

I I 1 I I II > 1000 0 pp m 

Figure 5-24. EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for Pumps by EO Concentration 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-72 
P.34 

ALL PUMPS 

CI90 PUMPS) LEAKERS 

CS PUMPS) 

19 Z 

4 Z 

1 0 0 x 

5 3 X 

EOi 1 - 2 Z 

V777771 EO, 2 - 5 Z 

^ ^ i EO. 5 - 50 X 

I I I I I II EO. 50-95 Z 

TM ~ EOi > 95 Z 

Figure 5-25. EOIC/EPA Fugitive Emissions Study: Distribution of Pumps 

Sampled by EO Concentration: All Components and "Leakers' 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-73 
P.35 

present study. All of the high emitters were on lines containing more than 

95X EO. The non-emitting class contained 60X of the pumps measured. The lowand very-low-emitter classes contained about 16X each. 

5.3.5.2 Emission Estimates 

The mean emission factors shown in Table 5-6 for pumps that were 

calculated using all the other methods are lower than the SOCMI factor, but 

the reduction is not as dramatic as for the components discussed previously. 

The estimated emission factor of 0.042651 lb/hr/source using the correlation 

curve with the EOIC default value is about 60.8X less than the SOCMI emission 

factor for pumps. 

Table 5-27 and Figure 5-26 show the mean emission factors for each 

EO concentration range by each estimation method. These data show clearly 

that the major emissions for pumps were from lines containing more than 95X 

EO. The data for the EO ranges with less than 10X EO show the relatively 

rapid decline associated with mostly non-leaking components. However, the 

lines containing more than 95X EO show relatively constant emission rates, 

regardless of the method used. This indicates that the emisions are dominated 

by the leaking components. 

5.3.5.3 Plant-Specific Analvsis 

Table 5-28 and Figure 5-27 show the emission factors for each plant 

calculated by all of the estimation methods. There is wide variation in the 

factors. Most plants show a declining emission factor going from left to 

right in the table, which seems to indicate mostly non-emitting components. 

Only four plants reported leaking pumps. 

5-74 
TABLE 5-27. DISTRIBUTION OF ESTIMATED FUGITIVE EMISSION FACTORS BY EO CONCENTRATION: 

EMISSION FACTOR ESTIMATES FOR PUMPS 

Ethylene Oxide 

Concentration 

IX to 21 

2X to SX 

51 to 10X 

10X to SOX 

SOX to 9SX 

95X to 100X 

Number of 

Component! 

7 

8 

a 28 

39 

100 

Mean Raw 

OVA Screen 

Value 

(ppm) 

92 

44 

IS 

83 

57 

S07S 

Mean EO 

Amount 

(X) 

100.0 

100.0 

100.0 

100.0 

99.2 

100.0 

Average 

SOCMI 

. 108900 

. 108900 

.108900 

.108900 

.108900 

.108900 

Mean 

Leak/ 

No Leak 

.026400 

.026400 

.026400 

.026400 

.026178 

.120060 

Emission Factora 

Stratified 

Emission 

.004360 

.004360 

.004360 

.011800 

.006104 

.104390 

(All Values in 

Correlation 

Curve (EPA) 

.000812 

.000782 

.000230 

.001809 

.000803 

.080079 

lb/hr/source) 

Correlation 

Curve 

(IXD-0) 

.000753 

.000725 

.000153 

.001764 

.000758 

.080031 

Correlation 

Curve (EOIC) 

.000812 

.000782 

.000230 

.001809 

.000803 

.080079 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

Ln 

I 

sjx 
P.37 

0. 1000--

• y 0.0100" 

o 

2 la 

O CO 3 

M a o 

W O (8 

M H \ 

M U U S a*a Xt 

W (»a \ 0.0010" 

XI 

o. ooooi-r 

SOCMI 

Factor 

-•0.010 0 

EO 

Average 

-+• 

1-21 2-SX ' S-IOZ 10-SOt S0-95X >03X 

EO CONCENTRATION 

. 1000 

"0.0010 

- -o. ooo I 

O.00001 

SOCMI 

^~C0RR CURVE (EPA) 

O LEAK/NO LEAK 

••••••• STRATIFIED 

----».—CORR CURVE (1) 

A CORR CURVE (EOIC) 

Figure 5-26. EOIC/EPA Fugitive Emissions Study: Comparison of Emission 

Factors to EO Concentration Using Different Calculational 

Approaches For Pumps 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-76 
P.38 

TABLE 5-28. EMISSION FACTORS FOR PUMPS FOR EACH PLANT: 

MEAN EMISSION FACTOR USING THE METHOD LISTED (LB/HR) 

Mean Emission Factor Using the Method Listed (lb/hr/source) 

Correlation 

Plant Leak/ Correlation Curve Correlation 

Number SOCMI No Leak Stratified Curve (EPA) (LLD - 0) Curve (EOIC) 

1 

2 

3 

5 

6 

7 

8 

9 

10 

11 

12 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

0.108900 

Relative Std. Dev. 

0.062293 

0.026189 

0.026400 

0.026400 

0.260550 

0.026400 

0.026400 

0.026400 

0.111545 

0.026400 

0.324409 

118.4X 

0.049222 

0.009880 

0.004360 

0.004360 

0.244020 

0.004360 

0.004360 

0.043600 

0.104135 

0.007253 

0.315695 

143.8X 

0.039639 

0.001948 

0.000513 

0.004760 

0.241168 

0.000107 

0.000123 

0.000396 

0.089395 

0.001171 

0.228385 

160.4X 

0.039612 

0.001927 

0.000459 

0.000403 

0.241146 

0.000027 

0.000042 

0.000362 

0.089382 

0.001110 

0.228334 

162.IX 

0.039640 

0.001948 

0.000514 

0.000477 

0.241169 

0.000109 

0.000125 

0.000397 

0.089396 

0.001172 

0.228386 

169.9X 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-77 
P.39 

1. ooooo-

~. 0.1 

O W 3 

M ce o 

M O M 

M 6 la 

x<a 

W fa \ 

JQ 

0.01 

o. ooioo- • 

fl. oooto--

0.00081 

H h H h 

+ 

+-—h 

G—e—ooo o 

Q....Q....Q....Q....QEO 

Avaraga 

SOCMI 

Facto r 

H 1 1 h 4- +• + + H h + 

1.00000 

,10000 

* a. oiooo 

.00100 

.00010 

H h •O. 00001 

# 4 # 7 # 8 (HQ # 5 # 3 #1 1 # 2 # 1 AVG #1 0 #1 2 #6SOCMI 

PLANT NUMBER CORR CURVE (EPA) 

LEAK/NO LEAK 

•D-•• STRATIFIED 

-»--- CORR CURVE (1) 

-A CORR CURVE (EOIC) 

Figure 5-27. EOIC/EPA Fugitive Emissions Study: Comparison .Among 

Twelve Plants Studied Using Different Calculation 

Approaches: Average Emission Factors For Pumps 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-78 
P.40 

5.3.5.4 Sypgarv 

The following conclusions can be drawn from the data concerning the 

190 pumps measured in this study: 

• The number of leaking pumps in this study was 52,2X lower than 

found during the SOCMI study. 

• The mean emission factor calculated from the correlation curve 

with the EOIC default is 60.8X lower than the SOCMI emission 

factor. 

• The emission factor for pumps with >95X EO was two orders of 

magnitude higher than for pumps with other EO concentrations. 

• There is wide variation in the emission factors for pumps among 

the plants; and 

• Four plants accounted for all eight leaking pumps in this 

study. 

5.3,6 Safety Valves 

Figure 5-28 shows the distribution of the 105 safety valves reported 

in this study. The figure shows approximately equal numbers of components 

(37-38X) in the lowest EO concentration range (1-2X) and in the highest EO 

concentration range (>95X). Safety valves vented to a flare or controlled by 

a rupture disk were not monitored ih this study. 

5-79 
P.41 

ALL SAFETY RELIEF VALVES 

105 

2 X 

12 X 

11 X 

38 X 

37 X 

EOi 1 - 2 X 

Y///A EO. 2 - 5 X 

SSS3 EO. 5 - 50 « 

I I I 1 I II EO. 50-95 X 

EO. > 95 X 

Figure 5-28. EOIC/EPA Fugitive Emissions Study: Distribution of Safety 

Relief Valves Sampled by EO Concentration 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-80 
P.42 

5.3.6.1 Screening Measurements 

The distribution of screening values for each EO concentration range 

is shown in Table 5-29 and illustrated in Figure 5-29. No leaking or highemitting safety valves were reported. Only one low-emitting and six very-lowemitting safety valves were reported. The category of non-emitting safety 

valves contained 93.3X of the population. 

5.3.6.2 Emission Estimates 

As expected for a component that basically was found to be nonemitting, the emission factors for safety valves declined rapidly as the 

default value was reduced, i.e., from left to right in Table 5-6. The average 

emission factor calculated using the correlation curve method with the EOIC 

default value was 99.9+X lower than the SOCMI emission factor. The Leak/No 

Leak factor was 60.4X lower and the stratified factor was 87.5X lower than the 

SOCMI factor. 

Mean emission factors calculated by each estimation method for the 

different EO concentration ranges appear in Table 5-30 and are illustrated in 

Figure 5-30. The data contained in both Table 5-30 and Figure 5-30 show 

significant scatter in the results. However, it should be noted that almost 

all the data, especially data from the correlation curves, are near the lowest 

reportable values. 

5.3.6.3 Plant-Specific Analvsis 

Testing of safety valves vented to a control device was specifically 

excluded from the screening protocol. Five plants did not report screening 

values for safety valves. Emission factors for each plant calculated by all 

of the estimation methods are presented in Table 5-31 and illustrated in 

Figure 5-31. Given the basic non-emitting nature of the safety valves in this 

study, no discernible trends could be seen in the data, as shown by the 

straight line curve derived by the Leak/No Leak and stratified methods in 

Figure 5-31. 

5-81 
P.43 

TABLE 5-29. DISTRIBUTION OF RAW OVA SCREENING VALUES BY EO CONCENTRATION 

FOR SAFETY VALVES 

Number of Components in Screening Value Ranee 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to 5X 

5X to 10X 

10X to SOX 

50X to 95X 

95X to 100X 

Total 

(All EO Ranges) 

0-9 

ppm 

39 

1 

3 

8 

11 

36 

98 

10-99 

ppm 

0 r-l 0 

2 

0 

3 

6 

100-999 

ppm 

0 

0 

0 

0 

0 I-I 1 

1000-

ppm 

0 

0 

0 

0 

0 

0 

0 

>9999 

ppm 

0 

0 

0 

0 

0 

0 

0 

Total 

39 

2 

3 

10 

11 

40 

105 

Ethylene Oxide 

Concentration 

Percentage of Components In Screenine Value Range 

1000-

0-9 ppm 10-99 ppm 100-999 ppm 9999 ppm >9999 ppm 

IX to 2X 

2X to 5X 

5X to 10X 

10X to 50X 

50X to 95X 

95X to 100X 

100.00 

50.00 

100.00 

80.00 

100.00 

90.00 

0.00 

50.00 

0.00 

20.00 

0.00 

7.50 

0.00 

0.00 

0.00 

0.00 

0.00 

2.50 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

Weighted Average' 93.33 5.71 .95 0.00 0.00 

Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-82 
P.44 

ALL SAFETY RELIEF VALVES 

105 

93. 3 X 

< 10 ppm 

10 - 100 ppm 

Y////A 100 - 1000 ppm 

1000 - 10000 ppm 

5 3 > IOOOO pp m 

Figure 5-29. EOIC/EPA Fugitive Emissions Study: Distribution of EO Screening 

Values for All Safety Valves 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-83 
TABLE 5-30. SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSION FACTORS FOR ALL 

PARTICIPATING PLANTS: EMISSION FACTOR ESTIMATES FOR SAFETY VALVES 

Ethylene Oxide 

Concentretlon 

IX to 2X 

2X to SX 

SX to 10X 

10X to SOX 

SOX to 9SX 

9SX to 100X 

Number of 

Components 

39 

2 

3 

10 

11 

40 

Mean Raw 

OVA Screen 

Value 

(ppm) 

2 

8 

3 

6 

3 

17 

Mean EO 

Amount 

(X) 

82.9 

16.2 

100.0 

100.0 

100.0 

100.0 

Average 

SOCMI 

.229100 

.229100 

.229100 

.229100 

.229100 

.229100 

Mean 

Leak/ 

No Leak 

.081636 

.015990 

.098500 

.098500 

.098500 

.098500 

Emission Factors 

Stratified 

Emission 

.020803 

.004075 

.025100 

.023100 

.025100 

.039835 

(All Values In 

Correlation 

Curve (EPA) 

.000073 

.000014 

.000088 

.000093 

.000088 

.000308 

lb/hr/source) 

Correlation 

Curve 

(LLD-0) 

.000007 

.000008 

.000000 

.000028 

.000002 

.000234 

Correlation 

Curve (EOIC) 

.000073 

.000014 

.000088 

.000093 

.000088 

.000308 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

in 

I 

00 
P.46 

ssg 

w o a 

s 

0. 1000--

0.0100--

0.001C 

u 

»H aoooi-f0.00001" " 

.000001' 

1 . \ / ,-* • 

• B- •e"' 

.. -D 

SOCMI 

Factor 

*1 

EO 

Average 

1-2X 2-S* 5-1 OX 10-50* 50-SSX >0SS 

EO CONCENTRATION 

AVC SOCMI 

). 1000 

- -0.0100 

.0010 

.0001 

.00001 

000001 

~

T

 CORR CURVE (EPA) 

"• LEAK/NO LEAK 

•••••• STRATIFIED 

-O CORR CURVE (I) 

m CORR CURVE (EOIC) 

Figure 5-30. EOIC/EPA Fugitive Emissions Study: Comparison of Emission 

Factors to EO Concentration Using Different Calculational 

Approaches For Safety Relief Valves 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-85 
P.47 

TABLE 5-31. EMISSION FACTORS FOR SAFETY VALVES FOR EACH PLANT: 

MEAN EMISSION FACTOR USING THE METHOD LISTED (LB/HR) 

Mean Emission Factor Using the Method Listed (lb/hr/source) 

Correlation 

Plant Leak/ Correlation Curve Correlation 

Number SOCMI No Leak Stratified Curve (EPA) (LID - 0) Curve (EOIC) l-l 3 

5 

6 

7 

9 

10 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

0.229100 

Relative Std. Dev. 

0.081614 

0.098500 

0.096626 

0.072191 

0.098500 

0.098500 

0.098500 

10.8X 

0.020797 

0.025100 

0.038329 

0.018396 

0.025100 

0.025100 

0.025100 

22.9X 

0.000072 

0.000086 

0.000286 

0.000063 

0.000086 

0.000134 

0.000093 

61.5X 

0.000012 

0.000000 

0.000213 

0.000000 

0.000000 

0.000134 

0.000029 

141.IX 

0.000073 

0.000088 

0.000288 

0.000065 

0.000088 

0.000134 

0.000095 

65.5X 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-86 
P.48 

1.000000 

t9 

o 

2 U 

o tg 3 

M K 0 n o a 

M O M 

x<a 

0.1 

0.01 

>_. 0.0010OO--

aoooioo" 

0.000010* * 

-\—IQ..--B-

.Q... Q ... a ... Q ...-B ...-• 

•+—I-—I—I - -H'-f- ^ ^ 1 r 

1.000000 

.010000 

. 001000 

.000100 

.000010 

#2 #4 08 #11 #12 #6 #1 #3 #7 #10 #v AVG #5 SOCMI 

PLANT NUMBER —• -•—COR — R CURVE (EPA) 

-O LEAK/NO LEAK 

.n... STRATIFIED 

„. CORR CURVE (1) 

""CORR CURVE (EOIC) 

— A — 

Figure 5-31. EOIC/EPA Fugitive Emissions Study: Comparison Among Twelve 

Plants Sampled Using Different Calculation Approaches: 

Average Emission Factors for Safety Relief Valves 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-87 
P.49 

5.3.6. 4 «fi,iiTiiTi^ry 

The overall conclusion concerning the 105 safety valves reported in 

this study is that safety valves do not contribute significantly to EO 

fugitive emissions from EO production. The average emission factor for safety 

valves was 99.9+X lower than the SOCMI emission factor. No leaking safety 

valves were found in any plant. 

5.3.7 Sealed Flanges 

There were 105 sealed flanges reported in this study. Almost 84X of 

these were on lines containing more than 95X EO. These components were 

originally thought to be somewhat different from normal flanges because 

emissions congregate at the drip tube; therefore, they were treated as a 

separate class. 

5.3.7.1 Screening Measurements 

+ 

Table 5-32 shows the distribution of screening values for each EO 

concentration range. According to the table, all 4 (3.81X) of the leaking and 

both (1.9X) of the high-emitting sealed flanges were on lines containing more 

than 95X EO. There were no low emitting sealed flanges. Eleven (10.5X) of 

the sealed flanges were very low emitters. Almost 84X of the sealed flanges 

were non emitters. 

5.3.7.2 Emission Estimates 

As seen in Table 5-6, virtually all estimation methods yielded 

higher emission factors for sealed flanges than the SOCMI emission factor for 

flanges, which was the only basis for comparison. It was not possible to 

determine from the data whether sealed and ordinary flanges truly differ. 

5-88 
P.50 

TABLE 5-32. DISTRIBUTION OF RAW OVA SCREENING VALUES BY EO CONCENTRATION 

FOR SEALED FLANGES 

Number of Components in Screening Value Range 

Ethylene Oxide 0-9 10-99 100-999 1000- >9999 

Concentration ppm ppm ppm ppm ppm Total 

IX to 2Z 

5X to 10X 

10X to 50X 

50X to 95X 

95X to 100X 

0 

1 

1 

10 

76 

1 

0 

1 

3 

6 

0 

0 

0 

0 

0 

0 

0 

0 

0 

2 

0 

0 

0 

0 

4 

1 

1 

2 

13 

88 

Total 

(All EO Ranges) 88 11 105 

Ethylene Oxide 

Concentration 

Percentage of Components In Screening Value Ranee 

1000-

0-9 ppm 10-99 ppm 100-999 ppm 9999 ppm >9999 ppm 

IX to 2X 

5X to 10X 

10X to 50X 

50X to 95X 

95X to 100X 

0.00 

100.00 

50.00 

76.92 

86.36 

100.00 

0.00 

50.00 

23.08 

6.82 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

2.27 

0.00 

0.00 

0.00 

0.00 

4.55 

Weighted Average* 83.81 10.48 0.00 1.90 3.81 

Weighted Average - Total number of components In a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-89 
P.51 

The most reasonable explanation for the difference between sealed 

flanges and normal flanges is the seal itself and the potential for trapping 

fugitive emissions in the enclosed space. Because of this physical 

constraint, the emissions from sealed flanges might not be swept away from the 

area by winds in the plant and they would therefore be more easily pulled into 

the OVA during testing. For this reason, the correlation curves are not 

applicable to sealed flanges. 

Table 5-33 shows the mean emission factor estimates for each of the 

EO concentration ranges calculated by each method. These data show that the 

major emissions came from sealed flanges on lines with >95X EO. 

5.3.7.3 Plant-Specific Analvsis 

Table 5-34 shows that only 2 of the 12 plants reported data for 

sealed flanges. Plant 6 had significantly higher emission factors for sealed 

flanges than did Plant 7. 

5.3.7.4 Summary 

The conclusions drawn from the limited data concerning sealed 

flanges in this study are the following: 

• Emissions from sealed flanges appeared to be predominantly 

from lines containing more than 95Z EO. 

• Sealed flanges represent a different class of component 

than ordinary flanges, and they should be treated 

separately. 

5-90 
TABLE 5-33. DISTRIBUTION OF ESTIMATED FUGITIVE EMISSION FACTORS BY EO CONCENTRATION: 

EMISSION FACTOR ESTIMATES FOR SEALED FLANGES 

Ethylene Oxide 

Concentration 

IX 

SX 

10X 

SOX 

95X 

to 

to 

to 

to 

to 

2X 

10X 

SOX 

95X 

100X 

Number ot 

Components 

1 

1 

2 

13 

88 

Mean Raw 

OVA Screen 

Value 

(ppm) 

10 

2 

8 

4 

S43 

Mean EO 

Amount 

(X) 

15 

100 

100 

100 

100 

7 

0 

0 

0 

0 

Average 

SOCMI 

.001830 

.001830 

.001830 

.001830 

.001830 

Mean 

Leak/ 

Ho Leak 

.000020 

.000130 

.000130 

.000130 

.004821 

Eml ision Factors 

Stratified 

Emission 

.000007 

.000044 

.000044 

.000044 

.004959 

(All Values in lb/hr/source) 

Correlation 

Curve (EPA) 

.000039 

.000209 

.000209 

.000209 

.006247 

Correlation 

Curve 

(LLD-0) 

.000039 

.000000 

.000058 

.000013 

.006076 

Correlation 

Curve (EOIC) 

.000039 

.000000 

.000058 

.000013 

.006077 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

\n 

I 

J

5 
P.53 

TABLE 5-34. EMISSION FACTORS FOR SEALED FLANGES FOR EACH PLANT: 

MEAN EMISSION FACTOR USING THE METHOD LISTED (LB/HR) 

Mean Emission Factor Using the Method Listed (lb/hr/source) 

Correlation 

Plant Leak/ Correlation Curve Correlation 

Number SOCMI No Leak Stratified Curve (EPA) LLD - 0 Curve (EOIC) 

6 0.001830 

7 0.001830 

0.000629 

0.000130 

0.000683 

0.000044 

0.000848 

0.000205 

0.000736 

0.000057 

0.005402 

0.000057 

Relative Std. Dev. 10.8X 22.9X 61.5X 141.IX 138.5X 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-92 
P.54 

5.3.8 Sample Points 

Thirty sample points, treated as open-ended lines, were reported in 

the survey. Table 5-35 shows the distribution of screening values In the EO 

concentration ranges. According to the table, 90X (27 sample points) were in 

the category of non emitters. The remaining 10X (3 sample points) were in the 

very-low-emitter category. Comparison with the SOCMI database is not 

appropriate since testing during the SOCMI study was conducted during actual 

process sample acquisition. In this EOIC study, no process sample acquisition 

was in progress during the screening tests. 

Overall, there were not enough data to fully evaluate the fugitive 

emissions from this type of component. As seen in Table 5-36, sample points 

experienced very few emissions for every EO concentration range. It appears 

that sample points are insignificant sources of fugitive emissions in EO 

production plants. 

5.3.9 Compressors 

Only five compressors were monitored in this study, because most 

compressors were sealed and could not be tested. Table 5-37 shows the 

distribution of screening values in the EO concentration ranges. Three (60X) 

of the compressors were in the non-emitter category. One (20X) each of the 

compressors was in the low-emitter and very-low-emitter categories. The 

complete lack of leaking compressors represents a 99.9-fX reduction from the 

9.IX leaking compressors found in the SOCMI study. The 0.000767 lb/hr/source 

average emission factor shown in Table 5-6 calculated by the correlation curve 

method with the EOIC default value is 99.8X lower than the SOCMI emission 

factor. Table 5-38 shows the distribution of emission factors with EO 

concentration. 

5-93 
P.55 

TABLE 5-35. DISTRIBUTION OF RAW OVA SCREENING VALUES BY EO CONCENTRATION 

FOR SAMPLE POINTS 

Ethylene Oxide 

Concentration 

2X to 5X 

5X to 10X 

10X to 50X 

50X to 95X 

95X to 100X 

Total 

(All EO Ranges) 

0-9 

ppm 

4 

3 

4 

2 

14 

27 

10-99 

ppm 

0 

0 

0 

0 

3 

3 

100-999 

ppm 

0 

0 

0 

0 

0 

0 

1000-

ppm 

0 

0 

0 

0 

0 

0 

>9999 

ppm 

0 

0 

0 

0 

0 

0 

Total 

4 

3 

4 

2 

17 

30 

Ethylene Oxide 

Concentration 

Percentage of Components In Screening Value Ranee 

1000-

0-9 ppm 10-99 ppm 100-999 ppm 9999 ppm >9999 ppm 

2X to 5X 

5X to 10X 

10X to 50X 

50X to 95X 

95X to 100X 

100.00 

100.00 

100.00 

100.00 

82.35 

0.00 

0.00 

0.00 

0.00 

17.65 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

Weighted Average" 90.00 10.00 0.00 0.00 0.00 

Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-94 
TABLE 5-36. DISTRIBUTION OF ESTIMATED FUGITIVE EMISSION FACTORS BY EO CONCENTRATION: 

EMISSION FACTOR ESTIMATES FOR SAMPLE POINTS 

Ethylene Oxide 

Concentration 

2X to 51 

SX to 10X 

10X to SOX 

50X to 9SX 

95X to 100X 

Number of 

Components 

4 

3 

4 

2 

17 

Mean Raw 

OVA Screen 

Value 

(ppm) 

3 

2 

3 

4 

4 

Mean EO 

Amount 

(X) 

100.0 

100.0 

100.0 

100.0 

100.0 

Average 

SOCMI 

.003700 

.003700 

.003700 

.003700 

.003700 

Mean 

Leak/ 

Ho Leak 

.003300 

.003300 

.003300 

.003300 

.003300 

Emission Factors 

Stratified 

Emission 

.000290 

.000290 

.000290 

.000290 

.000290 

(All Values in 

Correlation 

Curve (EFA) 

.000088 

.000088 

.000088 

.000088 

.000088 

lb/hr/source) 

Correlation 

Curve 

(LLD-0) 

.000000 

.000000 

.000000 

.000000 

.000001 

Correlation 

Curve (EOIC) 

.000088 

.000088 

.000088 

.000088 

.000088 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

in 

I 

vo 

V/i 
P.57 

TABLE 5-37. DISTRIBUTION OF RAW OVA SCREENING VALUES BY EO CONCENTRATION 

FOR COMPRESSORS 

Ethylene Oxide 

Concentration 

Number of Components in Screening Value Range 

0-9 

ppm 

10-99 

ppm 

100-999 

ppm 

1000-

ppm 

>9999 

ppm Total 

IX to 2X 

2X to 5X 

50X to 95X 

0 

0 

3 

1 

0 

0 

0 

1 

0 

0 

0 

0 

0 

0 

0 

1 

1 

3 

Total 

(All EO Ranges) 

Ethylene Oxide 

Concentration 

Percentage of Components In Screening Value Range 

1000-

0-9 ppm 10-99 ppm 100-999 ppm 9999 ppm >9999 ppm 

IX to 2X 

2X to 51 

50X to 95X 

0.00 

0.00 

100.00 

Weighted Average' 60.00 

100.00 

0.00 

0.00 

20.00 

0.00 

100.00 

0.00 

20.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

" Weighted Average - Total number of components in a given EO concentration 

range expressed as a percentage of the total number of components in all 

ranges. 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-96 
TABLE 5-38. DISTRIBUTION OF ESTIMATED FUGITIVE EMISSION FACTORS BY EO CONCENTRATION: 

EMISSION FACTOR ESTIMATES FOR COMPRESSORS 

Ethylene Oxide 

Concentration 

IX to 2X 

2X to SX 

SOX to 95X 

Number of 

Components 

1 

1 

3 

Mean Raw 

OVA Screen 

Value 

(ppm) 

10 

300 

2 

Mean EO 

Amount 

(X) 

15.7 

100.0 

100.0 

Average 

SOCMI 

.502200 

.502200 

.502200 

Mean Emission Factors (All Values in 

Leak/ Stratified Correlation 

Ho Leak Emission Curve (EPA) 

.030840 .003900 .000017 

.196900 .024900 .003554 

.196900 .024900 .000088 

lb/hr/source) 

Correlation 

Curve 

(LLO-0) 

.000017 

.003554 

.000000 

Correlation 

Curve (EOIC) 

.000017 

.003554 

.000088 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

VO 

oo 
P.59 

5.4 Bagging Study 

Optional bagging tests were conducted at four plants in conjunction 

with the screening studies. The results of all the bagging tests are 

presented in Appendix 4. These bagging tests can potentially be used for two 

purposes. The non-zero-screening source data can be used to check the SOCMI 

screening-to-leak rate correlations for applicability and to develop new 

correlations (if necessary). The zero-screening source data can be used to 

develop better default zero values. 

There are not enough non-zero-screening bagging data to develop new 

correlations. There were only nine non-zero-screening sources bagged, and 

those were divided over the four source type/service category correlations 

(valves-gas, valves-liquid, flanges, and pumps/other). 

The zero-screening sources were analyzed to determine whether new 

default zero values could be developed. The default zero concept was 

developed by EPA to account for the fact that bagging measurements are more 

sensitive than screening measurements in detecting low-level leakage. About 

10 gas valves that screened at "zero" (i.e., no difference between the maximum 

screening value and the ambient background concentration) were bagged in the 

SOCMI study and found to have non-zero leak rates. The average leak rate for 

these sources was calculated, and that value was used to determine the 

equivalent screening value by applying the correlation backwards (from leak 

rate to screening value instead of from screening value to leak rate). The 

results of this analysis was a "default zero" screening value of 8.17 ppm that 

EPA recommended for use for all source categories. 

The bagging data for zero-screening sources in this EOIC study is 

presented in Appendix 4 as part of the total bagging data and in individual 

summaries for each source type. For each source type and/or correlation 

equation, the measured emissions rates for the zero-screening sources were 

averaged. That average emission rate can be used directly to estimate the 

emissions from zero-screening sources. The average values were also backed 

through the correlations to arrive at default zero screening values. The 

5-98 
P.60 

results of these calculations are presented in Table 5-39. The default zero 

emission rates range from 0.000000337 lb/hr/source for valves in liquid 

service to 0.00000043 lb/hr/source for valves in gas service. That 

corresponds to a range of default zero screening values of 0.0000004 to 0.005 

ppm, respectively, for the same two source types. The default zero values in 

Table 5-39 were used for all calculations presented under the column titles of 

"Correlation Curve (EOIC)" or "Calculated Emission Rate (EOIC)." 

There was insufficient zero-screening source bagging data for the 

pump/other category. The EPA default of 8.17 ppm is shown for the pump/other 

category. One distinction should be noted between the pump/other category 

default and the three defaults developed using EOIC data. The pump/other 

category default is a total VOC number and the mass emission rates generated 

from it should be adjusted for the fraction of EO in the line to arrive at an 

EO emission estimate. The three EOIC defaults are already EO-specific and 

should not be adjusted for EO fraction in any subsequent calculations. 

Note that different defaults are given for each source type with its 

own correlation. An attempt was made to lump the data to arrive at a single 

default zero value similar to the EPA value of 8.17 ppm. It was determined, 

however, that no single default value could adequately describe all of the 

sources. It should be recalled that EPA arrived at a single value largely 

because all of the available test data were from one source type. 

5-99 
P.61 

TABLE 5-39. SUMMARY OF ETHYLENE OXIDE DEFAULT ZERO BAGGING STUDY RESULTS 

Equipment Type 

Service 

Category 

Number of 

Data Points 

Default Zero 

Screening 

Value 

(ppm) 

Zero Screening 

Value Emission 

Factor 

(lb/hr/source) 

Valve Liquid 

Valve Gas 

Flange All 

Pumps and Others* All 

7 

4 

9 

None 

4.00E-07 

5.00E-03 

3.50E-03 

8.17E+00' 

3.373E-07 

4.295E-07 

3.502E-07 

8.804E-05* 

Default value for pumps and other components taken from published EPA 

documents (Ref. 8) 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY, SUMMER 1988. 

5-100 
P.62 

6.0 ETHYLENE OXIDE WORK PRACTICES, OPERATING PROCEDURES, AND DESIGN 

GUIDELINES: RESULTS OF AN EOIC SURVEY 

As other sections of this report demonstrate, current overall 

industry fugitive emissions of ethylene oxide are considerably lower than 

those estimated previously by EPA using the SOCMI emission factors. The EOIC 

decided to conduct an industry survey of work practices, operating procedures, 

and design guidelines in an attempt to explain the low fugitive emissions 

measured in the current study. This section of the report summarizes the 

responses to the survey. A copy of the questionnaire can be found in Appendix 

5. 

Of the 12 EO plants participating in the study, eight (67X) sent 

complete responses to the questionnaire. All the responding plants monitor 

fugitive emissions of ethylene oxide. All stated that the potential for EO 

leaks was a major concern during the design of the EO manufacturing process. 

In response to question number four concerning programs for general 

leak detection, six of the eight respondents cited visual inspection during 

regular rounds. Six of the eight plants have combustible gas detectors and 

one plant is in the process of evaluating such a system. One plant also 

employs an outside contractor to conduct quarterly surveys, and one does 

quarterly OVA screening for EO and maintains a balanced hydrogen system which 

signals a leak when the hydrogen concentration is high. One plant cited use 

of an H-Nu meter during daily rounds and a gas chromatograph to monitor the 

control room and analyzer building. 

Of the mechanisms the plants use to identify specific leaking 

equipment, the OVA analyzer seems the most popular. Five of the eight 

respondents cited use of the OVA. One plant uses equipment-specific LEL 

detectors and an EO analyzer. One plant uses a TLV sniffer three times a day, 

during every shift. Some of the plants using the OVA also rely on the soap 

bubble technique and visual sighting of ice baLls at leak locations. One 

plant uses a TLV sniffer and an H-Nu monitor during rounds. One plant uses a 

JW "sniffer" and also has painted all EO piping yellow. 

6-1 
P.63 

Six plants responded to the question about special procedures used 

to check for, prevent, or mitigate the effects of leaks. Four cited special 

packing and gaskets for valves, flanges, and sample points, as well as double 

seals for pumps, rupture disks, and ball valves for gas valves. Five of the 

six cap their open-ended lines. One plant discussed the procedure for 

isolating and repairing leaks when they occur, and one cited annual inspection 

of safety valves. One plant said that spare pumps are kept to replace leaking 

pumps and that minor leaks of EO were flushed with water. One plant described 

monthly and quarterly fugitive emissions monitoring as well as regular 

monitoring with a TLV sniffer or H-Nu meter. 

Question number seven asked the plants to describe any written 

requirement they had for inspecting for leaks. Five plants said they had such 

written requirements. Of these five, two said they visually inspect EO 

equipment every four hours and conduct quarterly EO screenings as the state 

requires. Pump seals are checked once a week by one plant and once a month by 

the other. One of the five said they follow state requirements for fugitive 

emission testing, regularly checking components with >10X VOC and streams with 

>10X EO. This plant also checks pump seals once a week, all accessible 

equipment every quarter and all equipment annually. One plant conducts formal 

and informal screening of streams with >1X EO and does quarterly OVA 

inspections. 

Three plants answered "no" to question number seven. One of these 

said that an outside contractor follows their own written protocol, checking 

quarterly for VOCs. This plant checks the gas balance continually. 

All eight plants responded to questions concerning on-line 

maintenance and repair procedures for leaking equipment. All stated that they 

repaired leaks immediately when possible and always if the leak presented a 

safety hazard or if repair was practicable. Leaks that cannot be repaired 

immediately and very small leaks are repaired at the next scheduled plant 

shutdown or turnaround, which may occur as late as five years later. Two 

plants keep spares for all pumps; one plant said that all their pumps for >2X 

6-2 
P.64 

EO service have double gate valves or ball valves. Three plants install leaktight clamps on leaking equipment that cannot be repaired on line. One plant 

keeps fugitive emission checklists and monitors any clamped leaks closely. 

Most of the plants said that portions of their operations or 

equipment can be shut down for repairs of serious leaks. Two plants said they 

consider any EO leak serious enough to fix immediately and that they have 

procedures for isolating EO leaks. All eight plants responding to question 

number 14 said that the potential for equipment leaks, as well as toxicity, 

explosion potential, product loss, and energy savings was considered in the 

design of the ethylene oxide process. One plant specifically said that the 

number of possible leak sources was minimized. Others mentioned following all 

applicable design codes and conducting reliability studies. 

Questions concerning the use of specific leak prevention measures or 

equipment, the testing of equipment before installation, and quality control 

measures were answered by all eight plants. Most plants use pumps with double 

seals; three cited special packing material for gaskets; one cited the use of 

stainless steel piping; one said they use special metallurgy. Most mentioned 

following design specifications and adhering to applicable codes for 

preventing leaks. Three said they inspect the operations of vendors of their 

equipment and one said they plan to begin these inspections. One plant uses 

nitrogen purges of equipment and welded connections, and one uses backlighting 

and chlothane to test their EO equipment. 

All eight plants said they test new or repaired equipment before 

installation or start up; five cited hydrostatic or inert gas testing and the 

other three plants cited pressure testing. Five plants said they x-ray welds 

of all new components. 

6-3 
P.65 

The following methods were cited in answer to question number 18 

about equipment changes the plants have made to reduce leaks: 

• Use of dual mechanical seals and improved gasket materials (7 

plants); 

• Inspection and replacement of gaskets during turnaround (1 

plant); 

• Use of closed loop purging and sampling (1 plant); 

• Switching from carbon steel to stainless steel EO equipment (1 

plant); 

• Minimizing of number of flanges (1 plant); 

• Area monitoring of storage tanks (2 plants); 

• Use of backwelded screw connections (1 plant); and 

• Use of leak detection in analyzer houses (1 plant). 

In summary, the plants that responded to the questionnaire, 

representing 67X of the EO plants in the U.S., seem to be aware of the 

improved technology and methods available for minimizing and responding to 

leaks of this dangerous, highly explosive chemical. Though the respondents 

did not answer the questionnaire in the same detail, the answers were 

sufficient to gain an overall view of the plant practices. Some plants seem 

more aware than others of available techniques and improved equipment, but the 

discrepancy did not appear to be wide. 

6-4 
P.66 

7.0 REFERENCES 

1. Radian Corporation. Assessment of Atmospheric Emissions from 

Petroleum Refining. EPA-600/2-80-075, U.S. Environmental Protection 

Agency, Research Triangle Park, NC, 1980. 

2. Langley, G.J. and R.G. Wetherhold. Evaluation of Maintenance for 

Fugitive VOC Emissions Control. EPA-600/52-81-080, U.S. 

Environmental Protection Agency, Research Triangle Park, NC, May 

1981. 

3. Blacksmith, J.R., et al. Problem-Oriented Report: Frequency of Leak 

Occurence for Fittings in Synthetic Organic Chemical Plant Process 

Units. EPA-600/2-81-003, U.S. Environmental Protection Agency, 

Research Triangle Park, NC, September 1980. 

4. Radian Corporation, Austin, TX. Workbook for Estimating Ethylene 

. Oxide Fugitive Emissions. March 1988. 

5. Conway, R.A., et.al. "Environmental Fate and Effects of Ethylene 

Oxide." In Environ. Sci. Technol. 17. no.2: 107-112, 1983. 

6. Fugitive Emission Sources of Organic Compounds--Additional 

Information on Emissions. Emission Reduction, and Costs. EPA-450/3-

32-010, U.S. Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Research Triangle Park, NC, April 1982. 

7. Markwordt, D.W. Sources of Ethylene Oxide Emissions. EPA-450/3-85-

014, U.S. Environmental Protection Agency, Office of Air Quality 

Planning and Standards (OAQPS), Research Triangle Park, NC, April 

1985. 

7-1 
P.67 

8. Protocols for Generating Unit-Soeciftc Emission Estimates for 

Equipment Leaks of VOC and HAP. EPA 450/3-88-010, U.S. Environmental 

Protection Agency, OAQPS, Research Triangle Park, NC, October 1988. 

9. Fugitive Emission Sources of Organic Compounds - Additional 

Information on Emissions. Emission Reductions, and Costs. EPA450/3-82-010, U.S. Environmental Protection Agency, Research 

Triangle Park, NC, April 1982. 

10. Stalling, J.H.E. Emission Factors for Equipment Leaks of VOC and 

HAP. EPA-450/3-86-002. U.S. Environmental Protection Agency, 

Research Triangle Park, NC, January 1986. 

11. Dimmick, W. F. and K.C. Hustvedt. "Equipment Leaks of VOC: Emissions 

and Their Control." Paper No. 84-62.1 presented at the 77th Annual 

Meeting of the Air Pollution Control Association, San Francisco, CA. 

June 24-29, 1984. 

12. Chemical Manufacturers Association (CMA). Guidance for Estimating 

Fugitive Emissions. Washington, DC. July 1987. 

13. Response Factors of VOC Analyzers at a Meter Reading of 10.000 ppmv 

for Selected Organic Compounds. EPA-600/2-81-051, U.S. 

Environmental Protection Agency, 1981. 

7-2 
P.68 

APPENDIX 1 

EPA METHOD 2 1 
P.69 

(ovVounu 

I 

UAppOeadUUtandPnnetpta 

Ll AppUrmbUlty. Thla aachod tpollaa to 

the datarainattaa of volatile orgaalo compound (VOO laaka from praam equlpmant. 

Thaea aoureaa Indude. but an oat Uaitad 

to, Tatvaa. 

r«Uef de> 

Lat Modsfe A r—***'•* liMtraaant is 

UMd to dataet VOC laaka tnm ladMdual 

. Tha tastramant detactor typa ta not 

but it anat maat tha martftra 

Haas tad partocBanea erttartm rrnitttnad ta 

S. A lea* aMtititym 

la aach applfcahlo nmlaaoa. This 

dura la Intandad to locate and daaalfy la 

oal)r. aad la not to ba uaad aa a dlnet i 

ura of maaa — «—*— rataa m m Individual 

tlWuWr n 

U Laak Oaftntttai Coaeaaaicioa. The 

local VOC eonommion at tha surfaea of a 

laak amine that ladkaua that a VOC amts> 

Hon (laak) ta praaast. Tha laak rtartnlOm. la 

looarafCompound, Tha VOC i 

calibration 

i of tha laak dafliHtkw 

If alaahdafW 

la 10.000 ppm* M 

B thatr*> 

sultt la a looal ooaeentntiaa that rtaMa a 

aetar raadtas af 10.000 aa aa laatramaat 

calflmtad wtth mathana would ba daaatflad 

w a laak. IB tha) aaamale. tholaak daflal» 

tloa la IM0O PBORT. aad tha nf a 

pound la aocbana.) 

U Calibration Oaa. Tha VOC i 

uaad to adjuat tha toatrumam aacar nadtac 
P.70 

Pt. M, App* A, Mat*. 21 

to a known value. Tho calibration caa is ua » avThal 

ally tho nfaranea '•"••panaini u * la^'ft—*- tndtrtdal 

ttoa iutamlnnnl/ aqual ta tho laak deflat* ba lam thaa id. 

14 NO Dataetahlo Twill nn Tho local aqual to or lam thaa M aocoada. Tho £l 

VOCeanoanttatian u tho aorfaoa of a laak opoene Oaa aiat ba datamtaad for tha £ 

(laak) ta not preecnt. Sam boctcound VOC taatt**

 00Bfli,,,1*JflO

 *• **

 a"* *"*• 

^.J!u!ETr$tu! aay a** M , aad to aoeooa* a. Tho <min**km ms in mm ba equal . "f.T T ZZZZ *• " l m **••

 l 0

 P«nee t <•* *&• eaUbnai; dnriniiity. a duiaraam between tha wuiuo mmmwmiam. ~~ i and tha local i 

la datamtaad. A 

i at lam thaa a < 

a tho 

'Tff—»*•? thaa a 

VOC aaiaaa (laak) ta not praaast. (Far as> 

aaata. tf the laak definition a a i 

la l^OOOppmf^thaa tho allowable I 

oat conoantntion would ba * » ppav' 

a j Hmponai Factor. Tho ratio of tho 

known concentration of a VOC nomnminrl > Tha attention prarialoB tarn oa a ba 

unri urtac aa tnttrwaani ca minted wtth arvtoe. and a aubooqocnt »-aonth tatanaa 

tho nfaraaca compound ipoctflod a tho ap- or a tho aaxt uaa whtnhatar ta laur. 

plication regulation, a Tha raaponaa Oaa taa la raqulrad prior 

X* Calibration Piei'lctou. Tha degree ol a plaetag tho tantramoat lata nrrtoa. If a 

B_TBB9JBJQ^ OWWW^X ^BW^^^VBMBBaal OS wflB ^BDB^DQBHflmB wO tfl 0 fl^^^^BBm o|¥WMn*To_r BWOBUM 

aaaknawa value, espnaaad a the relative or flow configuration Is aada that would 

tha oatar readlaa and tha known qulrad prior to funhar uae. 

i a tha known concentration. J J Calibration Ooaaa. Tho monitoring in. 

XI Hapona Time. Tho ttao Intarval mmuaui la callhntad a tonaa af porta pa 

(Ha a Map change a VOC concentration a minion by volume (ppmv) bf tho nfannca 

the Input of the ampltnc tyaam to the compound aedflad tn tha applleaMo regotiae tt which M percent of tha corraepaaoV laticn. Tho ealibntion taam raqulnd tat 

lac flaal value ta reached a displayed aa ma^m-^aj n a inatrumant perfonnance 

tho luaiumaiu readout oatar. evaluation an a sen caa (air. lea than io 

a. atpponaa ppmv VOO and a calibration caa tn air mix* 

1.1 Mimlt'tT1"* Inatrumant. *"*• oPBrndaateiy equal a tho leak deflat3.1.1 TnemnnenniM Oaa ipactflad a tho regulation. If cylinder 

a. Tho VOC I "" 

a the 

typa which may oa a thn rv> 

ealibntion caa atixtune an uaad. they muat 

bo aaalyaad aad eertlfled by tho mannfao» 

tunr a ba wttha sa i 

,__ _ laaaalaiala^ gfjg fgf gga< UoUtOd tO, * (hOif llfO BUB t bO tPOCtflad. CyUBdCT 

oualrtki «»«a«a.»«a» Hmm*m laatMjM. \m*rm. atandarda au a ba either reanalywd or re* 

T?7i!*mffttnTiL ^nhmrrtnntailnn ^ ^ placed a the end of the ipedfled ahdf life. 

b. Tho msnnii i «*-»! bo capable of Alternately, calibration caea aay be pre* tho Ink itflnKttHi ~inmnT-M'ni pond by the uaa according a any aonpted 

_____ hi ti»a» remlatka. caaeouo standarda preparation procedure 

c Tho acalo oltthelaatrument meter shall that wta yield a mature aeeurma a wttha bo ——•— a £9 M— t of tho ->—•«•»•« ** percent Prepared standarda muat be re> 

Htfc <WTntWw "-mnvn^rn ——*** placed each day ofuae ualaa It can be deo> 

d. Tho taatnaont Hall be equipped wtth oMPygjaa t degradation dom not occur 

a ouaa a that a eoatlnuoua aasl e ta ore* ouragwaaw. 

vUtadto tho detector ^^~-<--I--T^ Callbnttm may bo port owned uting a 

flow m e ahall bo v* to 3 Uten per minute. «•»*" •

 t__'* h

_

l

 *•_•

 n?*n

-*' "•_' 

a. Tho inatrumant ihaa be inti—ta-n- pouad If a eonvenun lector ta determined 

afe fa o££*Sa Solve ^£ M tZ^Lt^^^QS^Ll^ ^ 

a jTftnri by tho applkabla Tff a ftaaaV reeultina meter reamno ounasaune rartrda "I , National ffltf^rl'ii riwte by tho nya caa be converted to reference COB* 

National Fire Prevention Aaaortattoa), vomd raauia 

3.U Performance Criteria. 
P.71 

InvaTewaenlaM Prated*** A«engy Pt. M , k+p. A, Moth. 31 

4.1 Pretea Preparations. Perform tho la* sampling u tha sealing seat Interface. For 

strument evaluation proeeduna liven a thaa dcvtca equipped wtth an endoaod ex* 

Section 4.4 If tho evaluation requlnaena of tension, or horn, place the probe Inlet at apSeetton J.U haa not been met. proximately the center of the exhaust area 

4-1 Calibration Proeeduna. Aaaable and a the atmosphere. 

start up tho VOC analyar according a tho e. Proeea ntalna l*nr open drains, place 

manufacturer's instructions. After tho ao- tho probe lata a approximately the center 

propriaa waraup period and tan Internal of tho area open a the atmosphere. For 

calibration procedure, introduce the calibre covered dralna. place the probe at the surtion caa a a the Instrument sample probe, (ace of the cover interface and conduct a po» 

Adjust the Instrument meter readout to cor- rtpbonl travene. 

respond a the calibration caa value. L Opon-bdod Una or Valves-Place the 

Not— If tho meter readout cannot bo aoV probe inlet u approximately tho center of 

Justed a tho proper value, a malfunction of the opening a the atmosphere, 

the analyser la Indicated and corrective ao> g. Seal System Daggering Vents and Accutlono an noceeaary before use. mutator Vena—Ptaca tho probe Inlet a >»> 

4J Individual Source Surveys. proximately tho center of the opening a 

4A1 Typo I-Laak Definition Based on the atmoephere. 

/ - m T^miuei piece tho probe inlet a the &» Aecem Ooor Saois—Piece tho probe 

surface of tho Tiptiw * interface when thlat a tha surface of tho door teal Interleakage could occur. Move the probe along fan and eondua a peripheral tnvene. 

the interface periphery while obeerrtng the U l Type n-"No Detectable finlaticn". 

instrument readout. If an Increased meter Oeteraao tho local ambient concentrerending Is obeerred. slowly sample the later* tion around tho aoune by moving tho probe 

fan whan leakage la Indicated until tho Inlet randaaly upwtnd and downwind u a 

•——•««• meter reading ta obtained. Leave mtaiwo of one a two meten (n a tho 

tho probe inlet u thia ~***—«» reading lo- source. If an Interference exists wtth this 

cation f a approximately two Umes tha la- determination duo a a nearby stnterton or 

strument raponia time. If tha maximum lak. tho local amaant concentration may 

ubeervsd m a reading Is crater thaa tha oe determined a rtletanna etooer a the 

leak definition a the applicable regulation, aoune. but a no eaas shall tho rtlrawo be 

record aad report tho reautta a ipoctflod a l«" thaa 2* centimetera. Than move the 

the regulation reporting requirements. Bx- probo lnkt a tho surface of the aoune and 

of tho apptmtton of this general determine tho ronoentntlcn JaocrlbsJ a 

jus a apodfie equipment typnuc O.I . Tho different between then cancanValvao—The moa *—••»•» source of tratione datemiaa whetha then are no 

from valva Is u the teal between tho detectable wilalnna Beoord and report tho 

and »aa"-a.a| pim tho probe u Ua reeulU a aodfled by the regulation. 

Interface whan tho stem exia tho packing For thorn caea when the regulation re. 

gland and ample tho stem circumference, qulra a spedfle device Installation, a that 

Alao. piam the prabo tt the tatcrfaa of the specified vena be ducted or piped to a conpacking eland take-up Sanaa seat aad tro* devtoa. tho extstena of thsa conditions 

staple tha periphery. IB "MffTi. survey ahall bo visually confirmed Whoa the reguvatve housagi of multipart aasaoaiy u tho laticn also requlns that no detectable emlsof aU tatertaea when a laak could 

surveys an required. Biampla of this tech* 

aad Other Ciniiianilma Tm nlqaoanc 

> flanges, place tha probe a the outer (a) Pump a Coapraaaa Seals If appliesof tho fiance natal interface and bla. determine tho typo of shaft seel. Pre. 

tho dreuatferena of tho flange, fom a survey of tho local area ambient 

Saotple other typa of aonpamanant Joiaa VOC ccncantratlon and determine tf detect-

(sash a threaded annoctlona) wtth a i 

lar uasoieo. <b) Seal System Degassing Vents. Accumue. Pumpa and Coaprssson Condnet a dr> lata Vessel Vena. Praesun Relief! 

cnafaranrlal travene u tha ouar surface If appUnhlo. nbarva whether a not the ap. 

of tho puap a eeaa-oesa thaft and seal pllcable ducting a piping exists, Also, deter* 

Interface. If the toura is a rotating shaft, mme if any sourca exla in tha ducting or 

poattioa the probe talot wttha I ca of the piping when emtalnns could occur prior a 

theft aal Interface f a the surrey. If tho tho control device. If tho required ducting 

housing configuration prevena a canplaa a piping cxisa and then an no sourca 

travene of tho shaft periphery, ample att whan the vmlsslmis could bo vented to the 

•ceaaatble porUona, Saaplo aU other Joiaa ataoaphan prior a tho control device, then 

on tho puap a naiuuoosm housing when It ts m ooumail that no doteeublo emtaalons 

leakage could ooeur. an prannt, If then an sourca a the ductd. Praesun Relief Devices-T*e configure, lag a piping when emttsiwis could bo 

tion of oaa pressun relief devtca prevena vented a sourca when leaks could occur. 
P.72 

Ft. M, Amp. A, Math. Tk 40 O l Ok I (7-1-47 Ummi) 

tho aaapUag surreys Jssulbsd la this para- 4.4J CaUbratioa Precision. Make a total 

graph ahall bo uaad a determine if detects- of three measurements by alternately uah* 

bis emissions exist. a n gas and tho iptrtflfi calibration CML 

4JJ Alternattn Screening Procedure. A Record tho meter reartlnci Calculate-the 

Timing pnoodun baaed on tho formation avenge algebraic dlftenaa between the 

of bubbia tne map solution that la sprayed outer readtaa and tho known value. Divide 

on a potential leak soune may bo uaad f a this avenge dltferenes by the known call, 

thorn sourca that do not have continuously bmtion value and autiply by 100 a txpnm 

moving para, that do not nan surface tea* tho resulting ealibntion precision a a per! 

iieianiia greaar than

 tKt>

 >»a«<iH»<» poat a cmtaso. ^^ 

lea thaa tho fraailng point of tha soap solo- 4.4J Reaponn Tha*. Introdua a n — 

UOSL that do not have open anea a tha at. a w the Instrument fT* * probe. When 

ntuaphen that tho soap sotutica anaot the oata reading haa itahlllart swtteh 

bridge, a that do not exhibit evidence of quickly a tho iptriflr1 •—upturn nT 

IS*** laakaam Sourca that haa then cop. Measure tho time from switching a whin 

dltieae preeent must bo surveyed using tho go rr'T^nt of tho **«*i stable reading ts at. 

Instrument torhnhnia of 4A1 a LXX talnad. Perform thia tea mritnrt thns* 

Spny a soap solutioa over att potential timm ,-Q- record tho laaulta Caleulateth. laak sourest Tho soap solutioa aay bo a 7ZZJZZ-ZZZZ JZL^^ v*«w»a too iaaia i»i.iia» anii&hie leak ilecmioii toln> -"**^" - «—•—» 

MHasn^Miaaao y •*^o^* a a^^^n i^v^^w^^^wai ^^m^r _ a_jay^^^^^^ ^ 

Ucn a may be prepared using concentrated ».*w«aon»«y 

detergent and waar. A praesun sprayw a 11 DuBoee. D-A» and OX Han-is. Re* 

a squeen bottle may bo ussdw dispense the sponat Facton of VOC Aaalyan et a Meter 

solution. Obeerre tho potential leak sita a narttng of 1(UM» ppmv f a Selected Organdetermine If any bobbin an formed. If ao le Compoiinrta. UA tevtmnaaatal Prateebubbla an observed, the soune la on* tion Agency, naanh Triangle Park, N C 

suaed to tarn ho detectable imlalons a PubUcatioe No. OA 900/3-41-03L Septemleaka a appllraMo If aay bubbla an ob> bw lSU. 

served, tho Instrument tachalqoa of 4J.1 a SJ Brown. OX. a aL nastiians Facton 

4JJ shatt be ussd a dsteimlne tf a laak of VOC Aaalyan CaUhntod wtth Methane 

exists, a tf tho aoune haa detectahte cats- f a Selected Orgaaa Compound*. VA Bnvisiona. a applicable. ranaantal Protection Agency. Reeeareh Tri. 

4.4 Instrument evaluation Procedures. Aft angle Fait. NC Publication No. SPA 800/3-

the beginning of tho luauuiaeut perform, si-033. May 1901. 

ana evaluation test, ssaambto aad start up 34 DuBooa. D.A. a aL naajisiss of Porttha laarumoat according a Uamenufao- to* VOC Analyian a Chemical Mlxtura. 

Instructions for recommended TJJ, Birlrunmental Protection Agency. Reperiod aad preliminary adjum- MBRH Triangle Park. NC Publication No. 

AM,m _„ , . _ __ WA«00/a-«l-UO.September 1ML 

4.4a Rapcnn Factor. Callbna the awtth tho nf a 

In tho appiia 

into atda that is a be 1 

during Individual aoano surreys, obtala a 

prepare a kaowa standard a air ataao> 

tha *nrll~ Va leak deflaitioa unlea limited 

by volatility a exploetvtty. Ia than caaaa. 

pnpon a itsndard a 90 pawani of the 

the tow explain limit, rsopectivwiy. Introdua this mlxtun a tho aaalyar aad 

rooord tho obeerved oata reeding. Intro, 

dna asm air until a stable reading la obtained. Make a total of three 1 

by alternating between tho 

and sen air. Calculate tho ; 

f a eeoh repetition aad tha 

spoeoo factor. 

Alternatively. If reepona facton han 

been publlahod f a the crwnprwnrte of later* 

est f a tho Instrument a deteear typo, the 

roopoan factor determination Is not required, aad existing reoults aay bo referenced. Kxamola of publlahod rteponaa facton f a flame Irnitratlon aad catalytic oxidation detecton an included in Section 3. 
P.73 

APPENDIX 2 

ETHYLENE OXIDE FUGITIVE 

EMISSION MONITORING PROTOCOL 
P.74 

/•

 r sly 

FTHYTy Mg CQdDE 

FUGITIVE SESSION JCNITORING 

PROTOCOL 

1.0 The study will consider all Ethylene Oxide Production facilities in 

the United States (10 total). All facilities are members of CMA's 

Ethylene Oxide Industrial Council. Ethoxalators and sterilization 

facilities could be addressed in a follow-up study. 

2.0 Ccnponents in streams containing greater than 1% ethylene oxide by 

weight that are accessible by platform, 1 arirter or manlift device up 

to 40 feet above grade/ will be screened according to the following: 

2.1 Valves — All. 

2.2 Connectors — (includes flanges and screed fittings) Use the 

following equation to determine tha.quantity (n) to be screened: 

n-au-.os'50TM, ,a**/u 

where N • the matter of process connectors. 

N 

100 

500 

1000 

2000 

3000 

2 % 

n 

77 

129 

139 

144 

146 

270 sn /or-f 

21/2- *>* 

Selection of the connectors to be tested should be random. 

Do not include insulated ones due to safety considerations. 

If you have a snail number or connectors it would be wise to screen 

all of then. 

2.3 Puras — All. 

2.4 Safety Valves — All, not discharged to a header system. 

2.5 Ooen Ended Lir.es — All terminal valves and open ended lines will 

be tested except those plugged or blind flanged. 

2.6 Cataressors — All. 

2.7 Sample Points — All sample points will be tested except those 

with a closed loop system, plugged or vented to a control device. 
P.75 

3.0 BC3ZC ante s are encouraged to oollect bag samples, though it is not 

required as part of this ouupm.ati.vbj ayieeusaiL with the EPA. Leak 

rata data for flanges with ncndatectabls screening values (< 8 ppm) 

would be particularly useful. Die EEA 'default value' for this 

category is unacceptably high. 

4.0 If a member oanpany wishes to oollect bag sasples, specific 

guidlines can be found in tha QSk Fugitive Emissions Guidance 

Manual. Such data is needed by CMA for new correlation development 

and emission factor assessment. Should bagging data be collected, 

• CMA rsoonnends that 2-8 bags (with the most LUcaly being 6) be 

collected for each of the source/service types n**-*^ below. 

• Flanges • Light T.^- H Pumps 

• Light Ll qnl ri Vfclves e Gas Valves 

• Open Bided Lines • Safety Valves 

4.1 If the pihlHiert correlation curves ant found to neither be 

adequate or conservative via an initial bagging (via the testing 

protocol outlined in the Q A guidance document), then more bagging 

may be required if a specific >rir.alatlan far the source category 

is desired (see CMA Guidance fYminaut far specifics) • Depending 

upcn initial test results, tha number of source/service types to be 

4.2 Gnecally, CMA inn nineties that two bags within each source/service 

type mentioned in 4.1 above be oollectd within each of the 

following screening ranges: 

than the instrument's lcwer limit of detection, UD(ie,zeros) 

• The highest screening values or ones dos s to the highest (but 

not act ths instrument's saturation point) 

• Serening values near (tut not below) ths instruments U D 

• Screening values above ths insrummt's saturation point. 

5.0 Instruments — An Organic Vapor Analyzer, OVA, will be used, (Fcxbcro 

Miran IA will be evaluated for its applications and limits). Adjustments 

must be made for appropriate response factors. 

6.0 Ths vaccra method of bagging will be used. 

7.0 The O A guidance dccument will be followed as close as possible. 

Absolutely no special maintenance should be done prior to testing. 

Testing should not be done in foul weather. The testing should be 

done without interruption. Some of tho testing should be witnessed bv 

EPA if at all possible. Auxiliary data should also be collected on 

each cccscnent tested. All screening values must be adjusted for 

response factors. 

8.0 The quality assurance measures listed in the C-tA guidance document must 

be followed-. The QA/QC will be submitted to S A prior to testing. 

Proper docunentation is essential. 
P.76 

9.0 It is reccnmended that industrial hygiene data be collected during 

the period of time the fugitive emissions testing is being done 

This vculd further support the findings of the fugitive emissions' 

testing. 

10.0 This project will be known as the cooperative OCV - EOIC / EPA 

Ethylene Oxide Fugitive Bnissions Study. The results of the studv 

will be accepted by all parties. 
P.77 

APPENDIX 3 

INDIVIDUAL PLANT SUMMARY DATA TABLES 
TABLE A3-1 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 1 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (tlq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

933 

573 

5 

15 

26 

HI 

104 

MEAN RAW 

OVA SCREEN 

-

SOURCE: EOIC FUGITIVE EMISSIONS STUDY 

VALUE 

<W»> 

13 

105 

4 

4 

559 

363 

283 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

98.6 

75.8 

82.9 

100.0 

99.5 

74.2 

89.9 

1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

........ ... 

LEAK/ 

NO LEAK 

.003716 

.001341 

.081614 

.003300 

.062293 

.003102 

.001705 

STRATIFIED 

EMISSION 

.000719 

.000790 

.020797 

.000290 

.049222 

.001510 

.001814 

CORRELATION 

CURVE 

(EPA) 

.001128 

.000468 

.000073 

.000088 

.039640 

.002480 

.002176 

CORRELATION 

CURVE 

(LLD - 0) 

.0001*9 

.000416 

.000012 

0.000000 

.039612 

.002436 

.002005 

CORRELATION 

CURVE 

(EOIC) 

.000200 

.000417 

.000073 

.000088 

.039640 

.002480 

.002005 

^1 

oo 
TABLE A3-2 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 1 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 

769 

508 

4 

12 

8 

87 

89 

10-99 ppm 

153 

40 

1 

3 

7 

21 

12 

100 -999 ppm 

7 

14 

0 

0 

9 

25 

0 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

4 

8 

0 

0 

1 

6 

1 

0 

3 

0 

0 

1 

2 

2 

933 

573 

5 

15 

26 

141 

104 

TOTAL 1477 237 55 20 1797 

VEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

82.42 

88.66 

80.00 

80.00 

30.77 

61.70 

85.58 

10-99 ppm 

16.40 

6.98 

20.00 

20.00 

26.92 

14.89 

11.54 

100--999 ppm 

.75 

2.44 

0.00 

0.00 

34.62 

17.73 

0.00 

1000 -9999 ppm 

.43 

1.40 

0.00 

0.00 

3.85 

4.26 

.96 

>9999 ppm 

0.00 

.52 

0.00 

0.00 

3.85 

1.42 

1.92 

82.19 13.19 3.06 1.11 .45 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER. 1988 

co 
P.80 

.ANT 1 DAILY CALIBRATION AND DRIFT DATA 

DATE 

i/10/88 

711/88 

712/88 

•713/88 

714/88 

/17/89 

/18/88 

/19/88 

LOW 

LEVEL 

RF 

2.05 

•2.3? 

BED 

LEVEL 

RF 

2.09 

2.00 

2.33 

2.52 

2.85 

t.ai 

2.JQ 

n ca i.JC 

HIGH 

LEVEL 

RF 

2.61 

2.96 

APPLIED 

RF 

2.10 

2.10 

2.30 

2.50 

2.50 

2.50 

2.50 

2.50 

CORRELATION 

COEFFICIENT 

0.9998 

0.9993 

DRIFT 

TEST 

( I DRIFT) 

m 

12.30 

1.30 

0.80 

14.00 

6.80 

0.27 

3.07 
TABLE A3-4 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 2 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) . 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

NUMBER 

Of 

COMPONENTS 

SOURCE: EOIC FUGITIVE 

1107 

408 

25 

381 

177 

1 

EMISSIONS 

MEAN RAW 

OVA SCREEN 

STUDY 

VALUE 

<PP") 

5 

31 

78 

634 

5 

300 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

98.0 

73.6 

99.2 

91.0 

. 90.0 

100.0 

1988 

AVERAGE 

SOCMI 

.01S600 

.012300 

.108900 

.003700 

.001830 

.502200 

1 

LEAK/ 

NO LEAK 

.003695 

.000780 

.026189 

.003220 

.000117 

.196900 

STRATIFIED 

EMISSION 

.000661 

.000237 

.009880 

.000659 

.000040 

.024900 

CORRELATION 

CURVE 

(EPA) 

.001109 

.000077 

.001948 

.000601 

.000208 

.003554 

CORRELATION 

CURVE 

(LLD - 0) 

.000378 

.000030 

.001927 

.000542 

.000053 

.003554 

CORRELATION 

CURVE 

(EOIC) 

.000378 

.000031 

.001948 

.000601 

.000054 

.003554 

-o 
TABLE A3-5 DISTRIBUTION OF COMPONENTS BY RAV OVA SCREEN VALUE FOR PLANT 2 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE ppm 

1075 

331 

12 

336 

164 

0 

10-99 ppm 

26 

62 

7 

28 

11 

0 

100 -999 ppm 

5 

12 

6 

12 

2 

1 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 

VALVE (gas) 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

1 

3 

0 

1 

0 

0 

0 

0 

0 

4 

0 

0 

1107 

408 

25 

381 

177 

1 

TOTAL 1918 134 38 2099 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

PUMP 

OPEN ENDED LINE 

FLANGE 

COMPRESSOR 

0-9 ppm 

97.11 

81.13 

48.00 

88.19 

92.66 

0.00 

10--99 ppm 

2.35 

15.20 

28.00 

7.35 

6.21 

0.00 

100-999 ppm 

.45 

2.94 

24.00 

3.15 

.1.13 

100.00 

1000--9999 ppm 

.09 

.74 

0.00 

.26 

0.00 

0.00 

>9999 ppm 

0.00 

0.00 

0.00 

1.05 

0.00 

0.00 

91.38 6.38 1.81 .24 .19 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER, 1988 

oo 
P.83 

, -ANT 2 DAILY CALIBRATION AND DRIFT OATA 

4STRUHENT 

DATE 

i/10/88 

•711/88 

713/88 

NC. 1 

LO« 

LEVEL 

RF 

4.76 

RED 

LEVEL 

RF 

5.10 

5.65 

5.72 

HIGH 

LEVEL 

RF 

APPLIED 

RF 

5.00 

5.60 

5.70 

CORRELATION 

COEFFICIENT 

DRIFT 

•TEST 

(.1 DRIFT! 

3.20 

1.00 

Ct T e 

STRUMENT NO. 2 

LOH 

LEVEL 

DATE RF 

/li/88 

'12/88 

/13/88 

ro 

LEVEL 

RF 

1.86 

1.36 

2.09 • 

HIGH 

LEVEL 

RF 

APPLIED 

RF 

1.70 

2.13 

2.10 

CORRELATION 

COEFFICIENT 

.DRIFT 

TEST 

(I DRIFT! 

9.40 

12.70 

NH 
TABLE A3-7 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 3 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

233 

132 

4 

8 

8 

37 

115 

SOURCE: EOIC FUGITIVE EMISSIONS 

MEAN RAW 

OVA SCREEN 

STUDY 

VALUE 

<PP"> 

12 

106 

2 

2 

39 

33 

21 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

100.0 

18.0 

100.0 

100.0 

100.0 

82.9 

71.8 

1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

' 

LEAK/ 

NO LEAK 

.003770 

.000262 

.098500 

.003300 

.026400 

.002735 

.000093 

STRATIFIED 

EMISSION 

.000705 

.000130 

.025100 

.000290 

.004360 

.000240 

.000048 

CORRELATION 

CURVE 

(EPA) 

.., .001171 

.000089 

.000088 

.000088 

.000514 

.000134 

.000182 

-

CORRELATION 

CURVE 

(LLD - 0) 

.000202 

.000077 

0.000000 

0.000000 

.000459 

.000068 

.000034 

CORRELATION 

CURVE 

(EOIC) 

.000202 

.000077 

.000088 

.000088 

.000514 

.000134 

.000034 

OD 
TABLE A3-8 DISTRIBUTION OF COMPONENTS BY RAV OVA SCREEN VALUE FOR PLANT 3 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 

225 

125 

4 

6 

5 

33 

113 

10-99 ppm 

2 

1 

0 

0 

0 

2 

0 

100-999 ppm 

5 

4 

0 

0 

3 

1 

1 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

1 

1 

0 

0 

0 

1 

1 

0 

1 

0 

0 

0 

0 

0 

233 

132 

4 

8 

8 

37 

115 

TOTAL 513 14 537 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

96.57 

94.70 

100.00 

100.00 

62.50 

89.19 

98.26 

10-99 ppm 

.86 

.76 

0.00 

0.00 

0.00 

5.41 

0.00 

100 -999 ppm 

2.15 

3.03 

0.00 

0.00 

37.50 

2.70 

.87 

1000--9999 ppm 

.43 

.76 

0.00 

0.00 

0.00 

2.70 

.87 

>9999 ppm 

0.00 

.76 

0.00 

0.00 

0.00 

0.00 

0.00 

95.53 .93 2.61 .74 .19 

SOURCE: EOIC FUGITIVE EMISSIONS .STUDY SUMMER. 1988 

lco 
P.86 

PLANT 3 DAILY CALIBRATION AND DRIFT DATA 

DATE 

5/2/88 

5/3/88 

5/4/88 

LOH 

LEVEL 

RF 

0.73 

MED 

LEVEL 

RF 

1.96 

1.79 

1.56 

HIGH 

LEVEL 

RF 

2.00 

APPLIED 

RF 

• 1.56 

1.56 

1.56 

CORRELATION 

COEFFICIENT 

0.9998 

DRIFT 

TEST 

IX DRIFT! 

10.00 

15.00 

0.00 
TABLE A3-10 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 4 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

MEAN RAW MEAN : 

NUMBER OVA SCREEN EO CORRELATION CORRELATION CORRELATION 

COMPONENT OF VALUE AMOUNT AVERAGE LEAK/ STRATIFIED CURVE CURVE CURVE 

TYPE COMPONENTS (ppm) (X) SOCMI NO LEAK EMISSION (EPA) (LLD - 0) (EOIC) 

VALVE (liq) 380 31 100.0 .015600 .004254 .001110 .001520 .000529 .000530 

VALVE (gas) 154 5 89.4 .012300 .000948 .000277 .000065 .000001 .000001 

FLANGE 144 4 96.6 .001830 .000126 .000043 .000202 0.000000 .000000 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMNER, 1988 

oo 
TABLE A3-11 DISTRIBUTION OF COMPONENTS BY RAV OVA SCREEN VALUE FOR PLANT 4 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT - - --

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 375 3 1 0 1 380 

VALVE (gas) 153 0. 1 0 0 154 

FLANGE 144 0 0 0 0 144 

TOTAL 672 3 2 0 1 678 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

VALVE (liq) 98.68 .79 .26 0.00 .26 

VALVE (gas) 99.35 0.00 .65 0.00 0.00 

FLANGE 100.00 0.00 0.00 0.00 0,00 

WEIGHTED AVERAGE 99.12 .44 .29 0.00 .15 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER, 1988 
P.89 

1ANT 4 DAILY CALIBRATION AND DRIFT DATA 

BATE 

3/10/88 

Vtl/88 

712/88 

)/13/88 

LOW 

LEVEL 

RF 

1.00 

1.11 

1.17 

1.11 

BED 

LEVEL 

RF 

2.50 

2.22 

? *?? 

HIGH 

LEVEL 

RF 

2.50 

? 7? 

L*LL 

1 ?? 

APPLIED 

RF 

2.00 

1.35 

1.87 

1.35 

CORRELATION 

COEFFICIENT 

0.9980 

0.9999 

0.9999 

0.9999 

DRIFT 

TEST 

(I DRIFTS 

0.00 

0.00 

0.00 

0.00 
TABLE A3-13 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 5 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

709 

388 

43 

3 

17 

2 

158 

SOURCE: EOIC FUGITIVE EMISSIONS 

MEAN RAW 

OVA SCREEN 

STUDY 

VALUE 

<«*> 

14 

86 

14 

2 

24 

4 

150 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

98.4 

79.6 

98.1 

100.0 

100.0 

100.0 

82.6 

1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.108900 

.003700 

.001830 

LEAK/ 

NO LEAK 

.003709 

.001144 

.096626 

.003300 

.026400 

.003300 

.000202 

STRATIFIED 

EMISSION 

.000782 

.000582 

.038329 

.000290 

.004360 

.000290 

.000397 

CORRELATION 

CURVE 

(EPA) 

.001219 

.000201 

.000288 

.000088 

.000477 

.000088 

.000846 

CORRELATION 

CURVE 

(LLD - 0) 

.000383 

.000152 

.000213 

.000004 

.000403 

.000018 

.000697 

CORRELATION 

CURVE 

(EOIC) 

.000383 

.000153 

.000288 

.000088 

.000477 

.000088 

.000697 

CO 
TABLE A3-14 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 5 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 

683 

343 

41 

3 

15 

2 

147 

10-99 ppm 

10 

28 

1 

0 

0 

0 

5 

100-999 ppm 

14 

8 

1 

0 

2 

0 

3 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

2 

8 

0 

0 

0 

0 

2 

0 

1 

0 

0 

0 

0 

1 

709 

388 

43 

3 

17 

2 

158 

TOTAL 1234 44 28 12 1320 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

96.33 

88.40 

95.35 

100.00 

88.24 

100.00 

93.04 

10-99 ppm 

1.41 

7.22 

2.33 

0.00 

0.00 

0.00 

3.16 

100 •999 ppm 

1.97 

2.06 

2.33 

0.00 

11.76 

0.00 

1.90 

1000 -9999 ppm 

.28 

2.06 

0.00 

0.00 

0.00 

0.00 

1.27 

>9999 ppm 

0.00 

.26 

0.00 

0.00 

0.00 

0.00 

.63 

93.48 3.33 2.12 .91 .15 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER. 1988 

CO 
cn cn cn cn 

»>- cn -*»» <.~4 

ta ro ro c-4 

ro t-a t-a t-a 

ro ro ro ro 

ro ro t-a ro 

o o 

-o -o 

-a -43 

-43 -43 

-O -43 

-43 -a 

CO 

C-4 -

o 

3J m ca 

TO m m 

;*j m cn 

C3 C3 

m ^> 
TABLE A3-16 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 6 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN (b/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SEALED FLANGE 

PUMP 

FLANGE 

COMPRESSOR 

NUMBER 

OF 

COMPONENTS 

756 

406 

25 

99 

4 

408 

4 

MEAN RAW 

OVA SCREEN 

VALUE 

<«» ) 

31 

975 

1 

482 

2514 

342 

4 

MEAN -

EO 

AMOUNT 

(X) 

95.4 

46.0 

73.3 

99.1 

100.0 

60.0 

78.9 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.001830 

.108900 

.001830 

.502200 

............ 

LEAK/ 

NO LEAK 

.004082 

.001550 

.072191 

.004299 

.260550 

.000629 

.155385 

STRATIFIED 

EMISSION 

.001165 

.001238 

.018396 

.004413 

.244020 

.00)683 

.019650 

CORRELATION 

CURVE 

(EPA) 

.001561 

.001155 

.000065 

.005575 

.241169 

.000850 

.000070 

CORRELATION 

CURVE 

(LLD - 0) 

.000645 

.001126 

0.000000 

.005402 

.241146 

.000736 

.000004 

CORRELATION 

CURVE 

(EOIC) 

.000645 

.001127 

.000065 

.005402 

.241169 

.000736 

.000070 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER, 1988 

co 
TABLE A3-17 DISTRIBUTION OF COMPONENTS BY RAV OVA SCREEN VALUE FOR PLANT 6 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 

738 

301 

25 

86 

2 

350 

3 

10- 99 ppm 

7 

49 

0 

7 

1 

22 

1 

100-999 ppm 

8 

14 

0 

0 

0 

17 

0 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SEALED FLANGE 

PUMP 

FLANGE 

COMPRESSOR 

1 

14 

0 

2 

0 

7 

0 

2 

28 

0 

4 

1 

12 

0 

756 

406 

25 

99 

4 

408 

4 

TOTAL 1505 87 39 24 47 1702 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SEALED FLANGE 

PUMP 

FLANGE 

COMPRESSOR 

0-9 ppm 

97.62 

74.14 

100.00 

86.87 

50.00 

85.78 

75.00 

10-99 ppm 

.93 

12.07 

0.00 

7.07 

25.00 

5.39 

25.00 

100 -999 ppm 

1.06 

3.45 

0.00 

0.00 

0.00 

4.17 

0.00 

1000--9999 ppm 

.13 

3.45 

0.00 

2.02 

0.00 

1.72 

0.00 

>9999 ppm 

.26 

6.90 

0.00 

4.04 

25.00 

2.94 

0.00 

88.43 5.11 2.29 1.41 2.76 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER, 1988 

CO 
cn cn cn 

•~-v- *-- —- cn cn cn cn cn cn 

^Ln^ui^-fx^^-f * 

o - o o 

O .*» <=> 

- o o 

- o o 

- a o 

o o <=> - o c> 

o o <=> - o o 

o o o - o o> 

o o o - o o 

• o o o o o o> o- r o o 

» m a 

r n 

33 m 

z^a rn cn 

IT3 IT3 C3 C3 

m ya 

-ri TO 
TABLE A3-19 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 7 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

SEALED FLANGE 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

878 

433 

6 

4 

5 

19 

62 

151 

SOURCE: EOIC FUGITIVE EMISSIONS 

MEAN RAW 

OVA SCREEN 

STUDY 

VALUE 

<«» ) 

41 

58 

4 

4 

11 

6 

31 

24 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

99.9 

90.9 

100.0 

100.0 

100.0 

100.0 

98.5 

97.0 

1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.003700 

.001830 

.108900 

.003700 

.001830 

LEAK/ 

NO LEAK 

.004396 

.000994 

.098500 

.003300 

.000130 

.026400 

.003251 

.000126 

STRATIFIED 

EMISSION 

.001303 

.000330 

.025100 

.000290 

.000044 

.004360 

.000592 

.000187 

CORRELATION 

CURVE 

(EPA) 

.001511 

.000125 

.000088 

.000088 

.000209 

.000109 

.000405 

.000338 

CORRELATION 

CURVE 

(LLO - 0) 

.000593 

.000066 

0.000000 

0.000000 

.000057 

.000027 

.000323 

.000146 

CORRELATION 

CURVE 

(EOIC) 

.000593 

.000066 

.000088 

.000088 

.000057 

.000109 

.000405 

.000146 

Tl 

CO 
TABLE A3-20 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 7 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 

763 

326 

6 

4 

1 

17 

56 

119 

10-99 ppm 

108 

95 

0 

0 

4 

2 

4 

29 

100 -999 ppm 

2 

7 

0 

0 

0 

0 

1 

2 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

SEALED FLANGE 

PUMP 

OPEN ENDED LINE 

FLANGE 

3 

4 

0 

0 

0 

0 

1 

1 

2 

1 

0 

0 

0 

0 

0 

0 

878 

433 

6 

4 

5 

19 

62 

151 

TOTAL 1292 242 12 1558 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

SAMPLE POINT 

SEALED FLANGE 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

86.90 

75.29 

100.00 

100.00 

20.00 

89.47 

90.32 

78.81 

10-99 ppm 

12.30 

21.94 

0.00* 

0.00 

80.00 

10.53 

6.45 

19.21 

100-999 ppm 

.23 

1.62 

0.00 

0.00 

0.00 

0.00 

1.61 

1.32 

1000-9999 ppm 

.34 

.92 

0.00 

0.00 

0.00 

0.00 

1.61 

.66 

>9999 ppm 

.23 

.23 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

82.93 15.53 77 58 19 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER. 1983 
P.98 

PLANT 7 DAILY CALIBRATION AND DRIFT OATA 

INSTRUMENT 

DATE 

5/24/68 

5/24/88 

NO. 1 

LOW 

LEVEL 

RF 

0.95 

to 

LEVEL 

RF 

2.06 

HISH 

LEVEL 

RF 

2.10 

1.9? 

DRIFT 

LEVEL APPLIED CORRELATION TEST 

RF COEFFICIENT (I DRIFT! 

2.08 0.999? 0.00 

4.30 

INSTRUMENT NO. 2 

DATE 

5/10/88 

5/11/88 

5/12/88 

LOH 

LEVEL 

RF 

1.11 

1.11 

1.11 

.1E0 

LEVEL 

RF 

1.11 

1.11 

1.12 

HISH 

LEVEL 

RF 

1.08 

i.ll 

1.11 

APPLIED 

RF 

1.10 

l.ll 

l.ll 

CORRELATION 

COEFFICIENT 

0.9999 

1.0000 

0.9999 

DRIFT 

TEST 

il DRIFT! 

0.37 

o.to 

0.10 
TABLE A3-22 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 8 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

PUMP 

FLANGE 

NUMBER 

OF 

COMPONENTS 

694 

72 

15 

328 

SOURCE: EOIC FUGITIVE EMISSIONS 

MEAN RAW 

OVA SCREEN 

STUDY 

VALUE 

<PP» 

129 

0 

2 

0 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

98.7 

100.0 

100.0 

100.0 

1988 

AVERAGE 

SOCMI 

.015600 

.012300 ' 

.108900 

.001830 

1 

LEAK/ 

NO LEAK 

.005046 

.001060 

.026400 

.000130 

STRATIFIED 

EMISSION 

.002076 

.000310 

.004360 

.000044 

CORRELATION 

CURVE 

(EPA) 

.002243 

.000072 

.000125 

.000209 

CORRELATION 

CURVE 

(LLD • 0) 

.001288 

0.000000 

.000042 

0.000000 

CORRELATION 

CURVE 

(EOIC) 

.001289 

.000000 

.000125 

.000000 
TABLE A3-23 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 8 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 670 9 6 5 4 694 

VALVE (gas) 72 0 0 0 0 72 

PUMP 14 1 0 0 0 15 

FLANGE 328 0 0 0 0 328 

TOTAL 1084 10 6 5 4 1109 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT ---

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

VALVE (llq) 96.54 1.30 .86 .72 .58 

VALVE (gas) 100.00 0.00 0.00 0.00 0.00 

PUMP 93.33 6.67 0.00 0.00 0.00 

FLANGE 100.00 0.00 0.00 0.00 0.00 

WEIGHTED AVERAGE 97.75 .90 .54 .45 .36 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER, 1988 
P.2 

PLANT B DAILY CALIBRATION AND DRIFT DATA 

LOW 

LEVEL 

RF 

BED 

LEVEL 

RF 

HIGH 

LEVEL 

RF 

APPLIED 

RF 

CORRELATION 

COEFFICIENT 

DRIFT 

TEST 

DATE (l DRIFT! 

ALL 2.46 . NH NR 

a! No calibration or drift data was subaitted with the screening data 

An average RF of 2.46 which was calculated fraa all data subaitted 

up to the tiae that this data was handled was applied. 
TABLE A3-25 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 9 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN tb/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

883 

107 

1 

19 

3 

1276 

SOURCE: EOIC FUGITIVE EMISSIONS 

MEAN RAW 

OVA SCREEN 

. 

STUDY 

VALUE 

<«*> 

30 

116 

15 

44 

669 

33 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

99.0 

80.7 

100.0 

100.0 

100.0 

97.1 

1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.229100 

.108900 

.003700 

.001830 

1 

LEAK/ 

NO LEAK 

.004151 

.001775 

.098500 

.026400 

.003300 

.000198 

STRATIFIED 

EMISSION 

.001035 

.001176 

.025100 

.004360 

.006627 

.000162 

CORRELATION 

CURVE 

(EPA) 

.001485 

.001000 

.000134 

.000397 

.004844 

.000389 

CORRELATION 

CURVE 

(LLD - 0) 

.000907 

.000959 

.000134 

.000362 

.004785 

.000249 

CORRELATION 

CURVE 

(EOIC) 

.000908 

.000959 

.000134 

.000397 

.004844 

.000249 

TJ 

CO 
TABLE A3-26 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 9 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 

746 

91 

0 

10 

2 

1071 

10-99 ppm 

133 

11 

1 

8 

0 

188 

100-999 ppm 

2 

3 

0 

1 

0 

11 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

0 

1 

0 

0 

1 

4 

2 

1 

0 

0 

0 

2 

883 

107 

1 

19 

3 

1276 

TOTAL 1920 341 17 2289 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

84.48 

85.05 

0.00 

52.63 

66.67 

83.93 

10 -99 ppm 

15.06 

10.28 

100.00 

42.11 

0.00 

14.73 

100 -999 ppm 

.23 

2.80 

0.00 

5.26 

0.00 

.86 

1000--9999 ppm 

0.00 

.93 

0.00 

0.00 

33.33 

.31 

>9999 ppm 

.23 

.93 

0.00 

0.00 

0.00 

.16 

83.88 14.90 .74 .26 .22 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER. 1988 
P.5 

PLANT 9 DAILY CALIBRATION AND DRIFT DATA 

INSTRUMENT 

DATE 

5/2/88 

5/3/88 

5/4/88 

5/5/88 

5/6/88 

NO. I 

LGW 

LEVEL 

RF 

1.02 

1.09 

0.99 

1.07 

MED 

LEVEL 

RF 

1.18 

1.00 

HIGH 

LEVEL 

RF 

1.14 

APPLIED 

RF 

CORRELATION 

COEFFICIENT 

0.9999 

DRIFT 

TEST 

(7. DRIFT) 

NN 

9.50 

1.60 

10.87 

3.30 

INSTRUMENT NO. 2 

DATE 

3/3/88 

5/4/88 

5/5/88 

5/6/B8 

LOU 

LEVEL 

RF 

1.21 

1.13 

0.99 

1 a 05 " 

MED 

LEVEL 

RF 

1.18 

HISH 

LEVEL 

RF 

1.18 

APPLIED 

RF 

1.19 

1.19 

1.19 

1.19 

CORRELATION 

COEFFICIENT 

0.9999 

DRIFT 

TEST 

! I DRIFT) 

m 

5.00 

17.00 

12.00 
TABLE A3-28 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 10 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

OF 

COMPONENTS 

456 

110 

21 

11 

127 

706 

SOURCE: EOIC FUGITIVE EMISSIONS 

MEAN RAW 

OVA SCREEN 

STUDY 

VALUE 

<Pf»> 

59 

21 

7 

1093 

324 

43 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

100.0 

96.5 

100.0 

100.0 

98.5 

98.4 

1988 

AVERAGE 

SOCNI 

.015600 

.012300 

.229100 

.108900 

.003700 

.001830 

' 

LEAK/ 

NO LEAK 

.004174 

.001023 

.098500 

.111545 

.003793 

.000128 

STRATIFIED 

EMISSION 

.001163 

.000329 

.025100 

.104135 

.001499 

.000126 

CORRELATION 

CURVE 

(EPA) 

.001842 

.000124 

.000095 

.089396 

.001458 

.000639 

CORRELATION 

CURVE 

(LLD - 0) 

.001403 

.000087 

.000029 

.089382 

.001416 

.000533 

CORRELATION 

CURVE 

(EOIC) 

.001403 

.000088 

.000095 

.089396 

.001458 

.000534 
TABLE A3-29 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 10 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE ppm 

188 

69 

18 

1 

59 

348 

10-99 ppm 

256 

37 

3 

4 

53 

332 

100-999 ppm 

9 

4 

0 

5 

8 

22 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

2 

0 

0 

0 

4 

4 

1 

0 

0 

1 

3 

0 

456 

110 

21 

11 

127 

706 

TOTAL 683 685 48 10 1431 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SAFETY VALVE 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

41.23 

62.73 

85.71 

9.09 

46.46 

49.29 

10 -99 ppm 

56.14 

33.64 

14.29 

36.36 

41.73 

47.03 

100 -999 ppm 

1.97 

3.64 

0.00 

45.45 

6.30 

3.12 

1000 -9999 ppm 

.44 

0.00 

0.00 

0.00 

3.15 

.57 

>9999 ppm 

.22 

0.00 

0.00 

9.09 

2.36 

0.00 

47.73 47.87 3.35 .70 35 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER. 1988 

TJ 

^1 
P.8 

PLANT 10 DAILY CALIBRATION AND DRIFT DATA, 

LQM 

EVEL 

RF 

KEO 

LEVEL 

RF 

HISH 

LEVEL 

RF 

APPLIED 

RF 

CORRELATION 

COEFFICIENT 

DRIFT 

TEST 

DATE (I DRIFT) 

ALL 1.30 1.77 1.78 1.59 0.9992 NH 
TABLE A3-31 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 11 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (liq) 

VALVE (gas) 

SEALED FLANGE 

PUMP 

OPEN ENDED LINE 

FLANGE 

NUMBER 

Of 

COMPONENTS 

525 

111 

1 

24 

1 

150 

SOURCE: EOIC FUGITIVE EMISSIONS 

MEAN RAW 

OVA SCREEN 

STUDY 

VALUE 

<«*»> 

18 

179 

8 

84 

300 

90 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

100.0 

100.0 

100.0 

100.0 

100.0 

100.0 

1988 

AVERAGE 

SOCNI 

.015600 

.012300 

.001830 

.108900 

.003700 

.001830 

' 

LEAK/ 

NO LEAK 

.003770 

.002832 

.000130 

.026400 

.003300 

.001231 

STRATIFIED 

EMISSION 

.000774 

.002155 

.000044 

.007253 

.000290 

.001659 

CORRELATION 

CURVE 

(EPA) 

.001176 

.001174 

.000209 

.001172 

.004470 

.001611 

CORRELATION 

CURVE 

(LLD - 0) 

.000213 

.001109 

0.000000 

.001110 

.004470 

.001422 

CORRELATION 

CURVE 

(EOIC) 

.000213 

.001109 

.000000 

.001172 

.004470 

.001422 

CO 
TABLE A3-32 DISTRIBUTION OF COMPONENTS BY RAV OVA SCREEN VALUE FOR PLANT 11 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 

504 

101 

1 

17 

0 

135 

10-

-. 

99 ppm 

10 

4 

0 

2 

0 

7 

100-999 ppm 

8 

3 

0 

4 

1 

6 

1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 

VALVE (gas) 

SEALED FLANGE 

PUMP 

OPEN ENDED LINE 

FLANGE 

3 

2 

0 

1 

0 

2 

0 

1 

0 

0 

0 

0 

525 

111 

1 

24 

1 

150 

TOTAL 758 23 22 812 

WEIGHTED AVERAGE 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 

VALVE (llq) 

VALVE (gas) 

SEALED FLANGE 

PUMP 

OPEN ENDED LINE 

FLANGE 

0-9 ppm 

96.00 

90.99 

100.00 

70.83 

0.00 

90.00 

10--99 ppm 

1.90 

3.60 

0.00 

8.33 

0.00 

4.67 

100 -999 ppm 

1.52 

2.70 

0.00 

16.67 

100.00 

4.00 

1000--9999 ppm 

.57 

1.80 

0.00 

4.17 

0.00 

1.33 

>9999 ppm 

0.00 

.90 

0.00 

0.00 

0.00 

0.00 

93.35 2.83 2.71 .99 .12 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER, 1988 

TJ 

o 
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r o r o r o r o 

r o r o r o r o 

r o r o r o r o 

o o o o 

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o o o 

r n 

PO m m 

-ri i— tz> 

zo r n cn 

DC* 

- n zo 

~n r n 

.—. r— 

c-i :x> 

•--• —i 

m •—• 

a : ca 

H U l T l 
TABLE A3-34 SUMMARY OF ESTIMATED ETHYLENE OXIDE FUGITIVE EMISSIONS FACTORS FOR PLANT 12 

EMISSION FACTOR ESTIMATES FOR ALL COMPONENTS 

MEAN EMISSION FACTORS (ALL VALUES IN Ib/hr/SOURCE) 

COMPONENT 

TYPE 

VALVE (Mq ) 

VALVE (gas) 

PUMP 

FLANGE 

NUMBER 

OF 

COMPONENTS 

SOURCE: EOIC FUGITIVE 

772 

412 

22 

1025 

MEAN RAW 

OVA SCREEN 

EMISSIONS STUDY 

VALUE 

<P|W) 

0 

891 

21409 

768 

SUMMER, 

MEAN -

EO 

AMOUNT 

(X) 

100.0 

100.0 

100.0 

100.0 

1988 

AVERAGE 

SOCMI 

.015600 

.012300 

.108900 

.001830 

' 

LEAK/ 

NO LEAK 

.003770 

.002492 

.324409 

.001097 

STRATIFIED 

EMISSION 

.000617 

.001753 

.315695 

.001049 

CORRELATION 

CURVE 

(EPA) 

.001004 

.001104 

.228386 

.001250 

CORRELATION 

CURVE 

(LLD - 0) 

0.000000 

.001033 

.228334 

.001044 

CORRELATION 

CURVE 

(EOIC) 

.000000 

.001033 

.228386 

.001044 

to 
TABLE A3-35 DISTRIBUTION OF COMPONENTS BY RAW OVA SCREEN VALUE FOR PLANT 12 

ALL COMPONENTS AND ALL EO CONCENTRATIONS 

NUMBER OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT 

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm TOTAL 

VALVE (llq) 772 0 0 0 0 772 

VALVE (gas) 406 0 0 2 4 412 

PUMP 13 0 0 4 5 22 

FLANGE 1011 0 0 2 12 1025 

TOTAL 2202 0 0 8 21 2231 

PERCENTAGE OF COMPONENTS IN SCREEN VALUE RANGE 

COMPONENT -

TYPE 0-9 ppm 10-99 ppm 100-999 ppm 1000-9999 ppm >9999 ppm 

VALVE (llq) 100.00 0.00 0.00 0.00 0.00 

VALVE (gas) 98.54 0.00 0.00 .49 .97 

PUMP 59.09 0.00 0.00 18.18 22.73 

FLANGE 98.63 0.00 0.00 .20 1.17 

WEIGHTED AVERAGE 98.70 0.00 0.00 .36 .94 

SOURCE: EOIC FUGITIVE EMISSIONS STUDY SUMMER. 1988 
P.M 

PLANT 12 DAILY CALIBRATION AND DRIFT DATA 

LOW 

VEL 

RF 

NED 

LEVEL 

RF 

HIGH 

LEVEL 

RF 

APPLIED 

RF 

CORRELATION 

COEFFICIENT 

DRIFT 

TEST 

DATE ll DRIFT) 

ALL 1.92 m 

No calibration ar drift data *as subaitted with the screening data 

An average RF ot 1.92 calculated iraa all data subaitted 

up to the tiae that this data was handled was applied. 
P.15 

-APPENDIX 4 

BAGGING STUDY DATA 
P.16 

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P.17 

TABLE 

Component 

Type 

Valve 

Valve 

Valve 

Valve 

Valve 

Valve 

Valve 

(Average) 

A4-2. 

Phase 

L 

L 

L 

L 

L 

L 

L 

Default 

Default 

ETHYLENE 

EO 

(X) 

100 

50 

50 

100 

50 

1.5 

OXIDE BAGGING DATA 

Organic 

Solvent 

None 

H20 

H20 

None 

H20 

H,0 

90 

Mass Flow Rate -

Screening Value -

Screen 

Value 

(ppm) 

4 

8 

8 

4 

8 

5 

5 

3.373E-07 

0.0000004 

FOR VALVES IN LIQUID SERVICE 

Bag 

Cone. 

(ppm) 

<2 

<2 

<2 

<2 

<2 

1 

1 

lb/hr 

Calculated 

Mass Flow 

(lb/hr) 

7.18E-05 

9.94E-05 

9.94E-05 

7.18E-05 

9.94E-05 

7.97E-05 

7.97E-05 

Measured 

Mass Flow 

(lb/hr) 

4.54E-07 

4.39E-07 

4.39E-07 

4.60E-07 

4.74E-07 

3.65E-08 

5.87E-08 

• 
P.18 

TABLE A4-3. ETHYLENE OXIDE BAGGING DATA FOR VALVES IN GAS SERVICE 

Component 

Type 

Valve 

Valve 

Valve 

Valve 

(Average) 

Phase 

G 

G 

G 

G 

Default 

Default 

EO 

(X) 

3 

20 

20 

3 

Mass Fl 

Organic 

Solvent 

Loop Gas 

None 

None 

Loop Gas 

ow Rate -

Screening Value -

Screen 

Value 

(ppm) 

8 

4 

4 

8 

4.295E-07 

0.005 ppm 

Bag 

Cone. 

(ppm) 

<2 

<2 

<2 

<2 

lb/hr 

Calculated 

Mass Flow 

(lb/hr) 

7.10E-05 

4.39E-05 

4.39E-05 

7.10E-05 

Measured 

Mass Flow 

(lb/hr) 

4.60E-07 

4.00E-07 

4.54E-07 

4.04E-07 
P.19 

TABLE A4-4. ETHYLENE OXIDE BAGGING DATA FOR FLANGES 

Component 

Type 

Flange 

Flange 

Flange 

Flange 

Flange 

Flange 

Flange 

Flange 

Flange 

(Average) 

Phase 

G 

G 

G 

L 

L 

L 

L 

L 

L 

EO 

(X) 

20 

20 

50 

100 

100 

100 

50 

1.5 

90 

Organic 

Solvent 

None 

None 

H20 

None 

None 

H20 

H20 

Default Mass Flow Rate -

Default Sc reenini 5 Value -

Screen 

Value 

(ppm) 

4 

4 

8 

5 

4 

4 

8 

5 

5 

3.502E-07 

0.0035 

Bag 

Cone. 

(ppm) 

<2 

<2 

<2 

<2 

<2 

<2 

<2 

1 

1 

Calculated 

Mass Flow 

(lb/hr) 

1.16E-04 

1.16E-04 

2.05E-04 

1.40E-04 

1.16E-04 

1.16E-04 

2.05E-04 

1.40E-04 

1.40E-04 

Measured 

Mass Flow 

(lb/hr) 

3.86E-07 

3.62E-07 

4.39E-07 

3.93E-07 

4.60E-07 

4.72E-07 

5.08E-07 

5.75E-08 

7.46E-08 
P.20 

APPENDIX 5 

EOIC FUGITIVE EMISSION SURVEY 
P.21 

EOIC FUGITIVE EMISSIONS SURVEY: 

WORK PRACTICES/OPERATING PROCEDURES/DESIGN GUIDELINES 

IN THE ETHYLENE OXIDE PRODUCTION INDUSTRY 

Survey Guidelines 

These questions will be used by the contractor and the Ethylene 

Oxide Industry Council to explain the low fugitive emissions results 

observed in our fugitive emissions study and to serve as a starting 

point for discussing programs to assure low fugitive emissions from 

ethylene oxide facilities through the Ethylene Oxide Industry Council. 

In accord with our ongoing cooperative agreement with the U.S. 

Environmental Protection Agency, the EPA will have access to the 

reported programs, and will participate in discussing the results. 

It is expected that a response to the questions will require more 

discussion than can be provided on this survey form. Please attach the 

additional response, as needed. It is also recommended that programs 

or guidelines, which are in writing, be included in the response to 

this survey. 

GENERAL 

1. What is the name plate capacity of the EO Production Facility? 

2. Summarize the number of components in the unit that contain 

ethylene oxide. 

< IX 2 to 10* » 107. 

Gas Valves . 

Liq Valves 

Gas Flanges 

Liq Flanges 

Pumps ' ; 

Compressors ; 

Open-ended Lines 

Connectors 

Sample Points 

Safety Relief Valves 

If the concentration of ethylene oxide changes through the 

production unit, explain the spatial distribution of the 

concentrations. Please attach a diagram if appropriate. 

3. Existing Regulations 

Summarize the number of components above that are monitored under 

an existing state/federal/local fugitive emissions program. 

< 1% 2 to 101 » 10% 

Gas Valves 
P.22 

Liq Valves 

Gas Flanges 

Liq Flanges 

Pumps 

Compressors 

Open-ended Lines 

Connectors 

Sample Points 

Safety Relief Valves 

MONITORING PROGRAMS 

Please present a detailed summary of any progrnm that yon 

have that will tell when a leak has occurred evrtn though It 

may not identify the specific piece of equipment leaking 

(area monitoring, strong odor, etc.). Please discuss number, 

location, frequency, etc., and provide a diagram if possible. 

5. Once a leak is believed to exist, describe the mechanism you 

use to identify the specific equipment leaking (organic 

analyser, soap bubbles, alarms, etc.). 

Discuss the special procedures that you use to check or 

prevent equipment types from leaking, or minimize the impact 

of a leak. Discuss the components to which these programs 

would apply. 

Gas Valves . 

Liq Valves 

Gas Flanges 

Liq Flanges 

Pumps 

Compressors 

Open-ended Lines 

Connectors 

Sample Points 

Safety Relief Valves 

Do you have a written requirement in your process operating 

procedures relating to leak inspection? Please 

describe. (If possible, please attach.) To what portion of 

the unit, or components, does it apply? 
P.23 

Please answer the following questions with respect to this written 

program? 

a. How much of the unit is covered under the inspection 

program? 

All 

Components on streams with EO greater than % 

Components on Critical Parts of the unit? 

Please describe in detail. 

b. What is the normal inspection frequency (i.e., 8 hr, 

24 hr, weekly, etc.)? 

c. During inspection, what is the mechanism used to 

determine that a leak has occurred? 

d. How is the specific leaky component identified? 

e. How are records of the inspection maintained? 

8. Do you also have an informal procedure for leak inspection? 

Describe how it complements the written program outlined 

above. 

Please discuss the following areas with respect to thn informal 

program. 

a. How much of the unit is covered under thn inspection 

program? 

All 

Components on stream with EO greater than % 

Components on Critical Parts of the unit? 

Please describe in detail. 

b. What is the normal inspection frequency (i.e., 8 hr, 

24 hr, weekly, etc.)? 

c. During inspection, what is the mechanism used to 

determine that a leak has occurred? 
P.24 

d. How is the specific leaky component identified? 

e. How are records of the inspection maintained? 

9. After process shut-down, describe any special leak checks 

performed before start-up. 

10. After process shut-down, describe any special leak checks 

performed after start-up. 

MAINTENANCE 

11. Describe the procedure you use to maintain/correct or repair 

equipment when a leak is found? Discuss if the maintenance 

is: 

Immediate 

Within 

At Next Shutdown 

12. Describe how on-line maintenance is done on equipment likely 

to leak. 

13. If repairs cannot be completed on-line or are unsuccessful is 

there a plan to shut down a portion of the units for repair? 

Please describe. 

Discuss how the seriousness of the leak relates to the repair time. 

PROCESS DESIGN AND EQUIPMENT SPECIFICATIONS 

14. Are the potential for equipment leaks a factor in process 

design? 
P.25 

Please describe how the following factors affect equipment design. 

Toxicity 

Explosion potential 

Product loss 

Energy Savings 

15. Please describe how the use of specific components are 

impacted by equipment leak potential. 

Consider the following factors: 

a. Describe how the toxic or explosive potential of this 

chemical is taken into account in design specifications. 

b. Describe the conditions under which special design 

specifications (ASTM for example) would be used in this 

unit (temperature, pressure, percentage in line, etc.). 

e. Are vendors' operations periodically inspected to insure 

product quality? 

d. Are components from the vendor periodically tested for 

leak tightness? 

16. Discuss how components are tested before installation in this 

process? 

17. Discuss any other quality control steps taken during 

construction to assure low leakage potential (i.e., weld 

x-ray and interpretation, check valve packing, pressure or 

hydrostatic testing, special installation guidelines, etc.). 

18. Since beginning operation, discuss any equipment changes that 

have been made to reduce leaks (i.e., use of improved valve 

packing, changing of gaskets, replacements of one brand of 
P.26 

valves with another valve type). Discuss If notable 

reduction in equipment leakage resulted from the changes.