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OAR Box 1168 

Prepped by Ollie Stewart 

Document Number: 

95) ll-C-24 

Docket Number: 

A-89-10 

Printed 4/29/2008 11:23:20 AM Sheet 95 of 131 
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DRAFT RFP OUTLINE 

For Discussion 

A-89-10 

FEB I4I99I 

II-C-2 4 

a:RFP 

I EPA AIR DOC 

OPTION 1 -- PERFORMANCE OF A PRESCRIBED IMPROVEMENT PROGRAM (The concept 

here is that adherence to the program represents compliance regardless of the 

emission results. The strong expectation is for continual emission 

reductions.) 

I. Data Collection 

A. Data shall be collected for each pump and/or valve beginning in 

phase II for each process that anticipates employing the RFP 

provision. 

B. Data shall include leak rate, service (constituents, temperature, 

pressure, other stream variables), and equipment parameters 

(design, material, manufacturer, etc.) 

II. Data analysis 

A. Leak rate data shall be analyzed to determine the services and 

equipment that have poorer than average (ie., the poorest 50%) 

emission performance. This analysis shall be completed for each 

process not later that the first year of phase III and shall 

continue for each year that the RFP provision is exercised.. 

B. The data (including any data obtained in on-line trials) shall be 

analyzed to determine the equipment parameters that are associated 

with the best emission performance for specific services. This may 

utilize data from a single process, or may use data that are 

combined from a number of processes, plants, or companies (eg., 

POSSEE). The initial analysis using two quarters or more of data 

shall be completed before the end of year one of phase III. The 

analysis shall be repeated each year the RFP provision is 

exercised. 

III. Action Plan 

A. Develop and implement a purchasing, specification, maintenance plan 

for the affected equipment not later than the end of year one of 

phase III. The plan shall include the data and analysis performed 

in II. B.,and shall document how these will be used to identify 

the best equipment and maintenance to achieve leak reductions. 

B. Replacement requirements: 

1. After the first year of the waiver period, all equipment that 

is replaced (for whatever reason) shall be replaced with equipment 

identified as a best performer in step II. B. If the replacement 

equipment of choice has exhibited performance that is significantly 

different that that of leak-free equipment, the reason that leakfree equipment was not selected shall be documented. 
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2. After the first year of the waiver period, 20% of the 

components that were identified as having worse than average 

performance and which can be replaced without shutdown, shall be 

replaced each year. The replacement components shall have been 

identified as best performers in step II. B. 

Document same as Chevron's 2.A.3. 

IV. On-1ine Trials 

Any corporation employing more than persons and operating one or 

more process units having more than 500? valves and flanges shall 

undertake a trial valve evaluation program (ie., limited in-plant use of 

specific components), beginning at the start of phase III, and designed 

to test and evaluate the performance of equipment having the potential 

for low or no-leak performance. The program shall include a minimum of 

components and shall include valve that are inherently leakless 

ie., consistantly below 25ppm (5% of the leak definition). 

OPTION 2 - DEMONSTRATION OF FURTHER PROGRESS (Under this option, compliance 

would be demonstrated by progress toward the "monthly criterion".) 

I. This option would essentially involve an ad hoc performance limit to be 

achieved by the end of the first year of phase III. The limit might be 

half way between the previous two quarter's performance and the "monthly 

trigger level". At the end of the second year of phase III, the source 

must comply with the monthly monitoring requirement until it qualifies 

for quarterly monitoring. 

II. This option would be provided for under the waiver provisions of the Act. 

III. Application for a waiver would require, in addition to the commitment to 

reasonable further progress, a description of the program that is being 

put in place and which provides a reasonable expectation that the RFP 

performance will be achieved. 

IV. The Option 1 program would not be available to a source that has 

undertaken Option 2 and failed to meet the "monthly trigger level". (If 

option 1 were available at the end of an option 2 trial, there is no 

reason for a source to employ option 1 without first trying option 2. 

This would be so even if there were no expectation of achieving the 

monthly trigger level. As such, the benefits of the option 1 program 

would be lost for two years.)