Emissions. APT/Course First Edition. Author. JerryWinberry, EnviroTech Solutions. Designer. Instructional. Cowen, North Carolina State University

Transcription

1 Environmental Programs to Introduction Fugitive Emissions Monitoring Designer Instructional Cowen, North Carolina State University William by North Carolina State University Developed Cooperative Assistance Agreement CT EPA Manual Self-Instructional SI: 380 APT/Course First Edition Author JerryWinberry, EnviroTech Solutions 1.0-2/00

2 part by the United States Environmental Protection under Cooperative Assistance Agreement CT to North Carolina State University. Agency contents of this document do not necessarily reflect the views and policies of the Protection Agency, nor does mention of trade names or commercial products Environmental endorsement or recommendation for use. constitute All rights reserved, including the right of reproduction in whole or in part in any form. Printed on recycled paper in the United States of America. This project has been funded wholly or in 2000 North Carolina State University ii.o-2/o0

3 of Air Pollution Sources Are Fugitive Emissions? 1-2 What Lesson I Self-Test Answers Lesson Affecting Fugitive Emission Monitoring 2-1 Regulations 2-1 Objectives VOC regulations 2?. Fugitive effects of Title and Title III 2-4 leaks regulations under NSPS (40CFR 60) 2-4 Equipment VV: Synthetic Organic Chemicals Manufacturing Industry (SOCMI) 2-5 Subpart GGG: Petroleum refineries 2-6 Subpart KKK: Onshore natural gas processing Subpart DDD: Polymer manufacturing plants 2-6 Subpart leaks regulations under NESHAP (40CFR 61) 2-7 Equipment Vinyl Chloride (40CFR61) 2-8 SubpartF: J: Benzene (40CFR61) 2-8 Subpart V: Fugitive Emission Sources (40CFR61) 2-8 Subpart F (40CFR63) 2-10 Subpart G (40CFR63) 2-10 Subpart H (40CFR63) 2-10 Subpart (40CFR63) 2-11 Subpart covered by HON 2-11 Equipment considerations 2-1 Regulation Introduction to Fugitive Emissions Monitoring Contents Figures vi Course Description vii Lesson 1-1 Introduction What Equipment is Regulated? 1-3 What Source Categories Are Regulated? 1-3 Need For Regulation 13 How Are Fugitive Emissions Detected and Controlled? 1-5 LDAR Inspection Program 1-5 Lesson Self-Test 1-6 timeline 2-2 Philosophical short history of the passage of the CAAA of A Leak detection and repair program /00 iii

4 3 3-1 Lesson VOC Emission Properties 3-1 Fugitive Pollutants 3 Regulated Categories g2 VOC Definitions 3,2 Regulatory 3 Self-Test 3-3 Lesson Lesson 3 Self-Test Answers I Lesson Emission Sources 4-1 Fugitive 4-1 Objectives leaking components 4-1 Major 4-4 Pumps 4-5 Compressors Relief Devices 4-6 Pressure 4-6 Agitators Response Factor (RF) Accuracy 5-5 8, Criteria 5-5 Performance an Analyzer 5-6 Selecting Improvement Program (QIP) 2-12 Quality 2 Self-Test 2-14 Lesson Lesson 2 Self-Test Answers Objectives of Air Pollutants 3 Classification and connectors 4-2 Flanges 4-3 Valves Lesson 4 Self-Test 4-9 Lesson 4 Self-Test Answers Lesson Reference Method 2 gl Federal 5-1 Objectives VOC Analyzers 51 Portable I. Monitor Response Measurement Range Scale Resolution Response time Safety Probe Dimensions 5-4 iv "1.0-2/00

5 Lesson 5 Self-Test Lesson 5 Self-Test Answers Objectives... LDAR and LDAR 61 Level... Maximum leaking valves... Slide Show Scrip... A /00 v Introduction to Fugitive Emissions Monitoring 6 6-I Lesson... and Repair Program 6-1 Detection Leak Scope Review Record Plan 6-3 Inspection Lesson 7-1 Recordkeeping Objectives Leak Requirements Fugitive Requirements for Leaks 7-2 Recordkeeping Reporting NSPS Requirements Reporting Requirements 7-2 Other NSPS 7-3 LDAR Skip-period program A-1... A Appendix B B-1 Appendix... B-1... Checklist LDAR

6 1-I Figure 1-2 Figure 1-3 Figure 2-1 Figure 4-1 Figure 4-2 Figure 4-3 Figure 4-4 Figure 4-5 Figure 4-6 Figure 5-1 Figure 5-2 Figure LDAR Flow Multi-component hand-held analyzer 5-2 vi 1.0-2/00 S1:380 Figures Processing Plant 1-2 Chemical Emissions Impact I-3 Uncontrolled Neg Enforcement 2-12 Reg flanges 4-2 Bolted valve Typical leak points Valve pump assembly 4-5 Centrifugal vessel Agitator shaft..: 4-7 Agitator... hand-held analyzer 5-2 component Single

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8 This course provides introductory level information relating to Fugitive Emissions Monitoring VOC (Volatile Organic Compounds) and VHAP (Volatile Hazardous Air Pollutant) fugitive through the application of a leak detection and repair (LDAR) program. emissions most important aspects of this course are the introduction and definitions/descriptions of terms, processes, and equipment related fugitive VOC and VHAP emissions basic (Throughout the remainder of the course, all references to fugitive emissions will assume 6. Identify the performance specifications for Federal Reference Method /00 vii Introduction to Course Description the source and control of.objectives course is made up of seven lessons that meet the following course objectives: emissions of VOC and VHAP types only.) I. Identify the regulations related to fugitive emissions 2. Identify the sources capable issuing fugitive emissions 3. Identify the equipment capable of issuing fugitive emissions 4. Describe the components of the LDAR (leak detection and repair) program 5. Identify the test equipment used to detect fugitive emissions

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10 lesson introduces the subject of fugitive emission detection and control. This in this lesson will be amplified with more detailed discussions in the following lessons. presented In discussions of air pollution sources, four terms are routinely used: A stationary point source refers to any place within a source or mobile source. facility from which emissions are source to one several contributing to the air pollution of a given Area refers any of sources be stationary, mobile, or combination of stationary and a may sources Area area. geographic 1 Lesson Introduction material Objectives completion of this lesson, the student should be able to: Upon Identify the source categories that are regulated for fugitive VOC emissions 1. Identify the equipment regulated under fugitive emission standards 2. Describe the components and process steps of a!eak detection and repair (LDAP.) 3. program Sources of Air Pollution sources mobile sources stationary sources point sources area Mobile sources are not included Mobile sources are generally related to transportation. the general parameters for fugitive.emissions and, therefore, will be given no further within in this course. consideration sources define emission sources that are fixed and include all forms and types of Stationary chemical and petroleum processing, power generation, and small business manufacturing, facilities. For a given facility, a stack may be one point source. An emission leak within a possible. is also considered a point source. An automobile or a track would represent a point process mobile /00

11 used because these emissions are neither calculated in the source captured by the emission control equipment/systems, nor are they detected through design, equipment monitoring processes. Since these emissions bypass control equipment,. normal they are also referred to as "uncontrolled emissions." Lesson 1 What Are Fugitive Emissions? term, fugitive emission, as used in air quality control, generally refers to any emission from regulated processes (sources) other than via the designed release point (smoke escaping etc.). point source for a fugitive emission is simply called "a leak." se leaks stack, emissions are most often associated with the equipment necessary for the movement of and fluids and gasses. process term "fugitive" is Figure 1-1 Chemical Processing Plant 1-1 a picture of a chemical processing plant. From the picture you can readily see Figure is milesof are pipes. se pipes have numerous connections to process equipment, there that each connection (and possibly each piece of equipment, point source) represents a and source for a fugitive VOC leak. possible /00

12 pumps valves compressors relief devices pressure (connectors) flanges accumulator vessels product (NSPS), National Emission Standards for Hazardous Pollutants (NESHAP), Standards Organic NESHAP (HON), and Maximum Achievable Control Technology Hazardous Need For Regulation question may arise: "Since fugitive emissions are leaks, it represent only a inconsequential, an accumulation of many leaks from any certainly or group of sources constitutes a source 1-2 provides a glimpse of estimated emissions from three types of sources. It doesn't Figure much inspection to see that in each case, a very large percentage of emission reduction is take possible by eliminating, or reducing, uncontrolled emissions. TotalEmissions Uncontrolled Controlled %Reduction Source Possible Refineries 73,700 tpy 53,900 tpy 19,800 tpy 73 SOCMIs 132,000 tpy 91,500 tpy 40,700 tpy 69 Benzene 11,450 tpy 8,700 tpy 2,750 tpy 75 Total 217,350 tpy 154,100 tpy 63,250 tpy / Introduction What Equipment is Regulated? equipment regulated under fugitive emission standards are: connections sampling ended valves and lines open agitators Each of these pieces of regulated equipment will be described in more detail in following lessons. Source Categories Are Regulated? What any fugitive emission from within a facility governed by New Source Performance Basically, rules is subject to regulation. se sources include SOCMI, petroleum refineries, (MACT) and vinyl chloride facilities. benzene, would follow that they small source of emissions, therefore why must they be regulated?" While any single leak is major release of pollutants into the air. Figure 1-2 Uncontrolled Emissions Impact

13 No ) LEVEL Reviewrecord reportssubmi edby focus for Determine 2 (and Level source Review (on-site) records Yes- Vedfyequipment identified correctly and through source observe physical Conduct 3 inspection Level an(; file Complete reports necessary Leak Agency and Detection /00 Lesson 1 Program Repair Steps) (Process and tagged source -No L;onou wa Yes procedures Yes schedule) No Figure 1-3 LDAR Flow

14 regulations governing fugitive emissions will be described in the next lesson. Techniques for Fugitive VOC Emission Sources. "agency" refers to the regulating authority (state and/or local). agency program should include a Implementation of an agency leak detection checklist designed to optimize agency time and talents performing a source inspection. If all records an d reports are in order as determined by when Level review, then no further review of the source is required at this time. However, if a of the facility. If, then, deficiencies are discovered, the inspector performs a Level 3 through" to verify compliance with the fugitive VOC 1.eak regulations. At this point the inspection going further, it is important to understand that the source is responsible for Before with all applicable regulations. refore, the normal periodic monitoring and compliance testing of all regulated equipment is consultant hired by the source. generally conducted by the source or by an outside. have literally thousands of possible emission points, the agency inspector cannot be emissions to personally inspect every point source at every facility. expected Figure 1-3 provides an overview of the main of an agency LDAR program and it provides a road map for the Internet components presentation that follows. slide Return to your Internet home page and select "Slide Show. presentation providing an overview of an agency LDAR program script/text for the on-line slide presentation is provided in Appendix A Introduction Are Fugitive Emissions Detected and Controlled? How answer to this question is the basis for this self-study course and Course 380 Inspection repair (LDAR) program provides the framework for locating, documenting, and verifying and (fugitive emissions) repairs in affected facilities. It should be noted here that the term leak agency LDAR program is at three levels (Figure 1-3) as follows: implemented Level Pre-inspection record review at the agency office. 1. Level 2: Onsite inspection of source records and a facility walk through and observation.2. Level 3: Onsite inspection with the inspector conducting the monitoring and testing 3. Level review indicated deficiencies, then the inspector goes to the site and performs a the 2 review, including comparison of Level records with on-site records and a "walk- Level source may be required to strengthen its QIP and LDAR programs. Since many source facilities capable of generating fugitive LDAR Program Inspection preface for the material to be presented in the remainder of the let,s course, follow a As an agency inspector on an ideal inspection. You will view an audio/slide /00

15 Lesson /00

16 1. Fugitive emissions are generally identified with which of the following sources: (True/False) Emissions from a stack, if not within specifications/limits, are classified as 2. emissions. fugitive (True/False) Fugitive (uncontrolled) emissions need to be regulated since they represent 4. than twice the emissions from controlled sources. more 1.0-3/ Introduction Lesson 1 Self-Test a. Mobile source b. Stationary source c. Both a andb a. True b. False Fugitive emissions are governed under which of the following regulations? 3. HON a. b. MACT c. NESHAP d. NSPS e. All of the above a. True b. False 5. Which level(s) of an LDAR inspection are conducted at the agency location? a. Level b. Level 2 c. Level 3 d. Level and2 e. Level 2 and3 6. Which level(s) of an LDAR inspection are conducted at the source location? a. Level b. Level 2 c. Level 3 d. Level and2 e. Level 2 and 3 A walk-through inspection is conducted as part of a Level inspection. 7. Level a. b. Level 2 c. Level 3 d. Level and2 e. Level 2 and3

17 3. e 4. a 5. a 6. e /00 Lesson 1 Lesson 1 Self-Test Answers 1. b 2. b 7. b

18 level ozone is a pervasive pollution problem throughout the United States. Ozone is Ground readily in the atmosphere by the reaction of volatile organic compounds, or VOCs, oxides formed of nitrogen (NOx), heat and ultraviolet light, which are most abundant in the summer. from motor vehicles, power plants, other sources of combustion and natural sources emitted lightning and biological processes in the soil. VOCs are emitted from a variety of including including motor vehicles, chemical plants, refineries, factories, consumer and commercial sources other industries and natural (biogenic) sources. products, emissions into the atmosphere in order to minimize the ground-level concentrations of ozone Objectives completion of this lesson, the student should be able to: Upon Identify major programs and regulations related to fugitive emission monitoring 1. Identify regulations pertaining to the fugitive emissions 2. the National Emission Standards for Hazardous Air Pollutants (NESHAPs) and the (NSPS), Organic NESHAP (HON). Under these regulations, various industries are Hazardous 1.0-2/ Lesson Affecting Fugitive Emission Regulations Monitoring NOx is purpose of this lesson is to provide an "overview" of the regulations affecting fugitive VOC 3. Define or describe the function/purpose of LDAR and QIP VOC regulations Fugitive control of fugitive VOC emissions from equipment leaksare found in various EPA regulations. A majority of them are found in the New Source Performance Standards affected and must control their fugitive VOC emissions.

19 Operating Permit NAAQS Ambient Air National Quality Standards NESHAP Emission Standards for National Achievable Control Maximum HON Organic NESHAP Hazardous meet the NAAQS standards throughout the United States, EPA To the NSPS program to regulate the emissions of pollutants from new sources. established through State Implementation Plans (SIPs) that incorporate all to control fugitive emissions from the Synthetic Organic Chemical Manufacturing established (SOCMI) industry account for more than 35 % of the total VOC emissions within Industry the extensive laboratory testing that required to prove that the chemical was Lesson 2 following chart shows the interrelationship of the fugitive VOC regulations. Interrelationship of Fugitive VOC Regulations NSPS Permit Applications and New Source Perfomance Approvals Standards Hazardous Air Pollutamts Benzene NESHAP I Technology MACTStandards NAAQS have been in effect for over 30 years and apply to six criteria pollutants: carbon (CO), lead (Pb), nitrogen dioxide (NO2), Sulfur Dioxide (SO2) ozone (O3), and monoxide particulate matter (PM,_.5). program was implemented to prevent new pollution problems from developing and to NSPS air quality as the Nation's industrial base is replaced. Existing sources are regulated enhance federal programs. regulations, together intended are to minimize the emissions of VOCs from All working in regulated processes. As an example, the HON regulations were leaks equipment that industry. timeline Philosophical development of the regulations from the early 1970's until the present has changed early NSPS standards were performance base-standards, where the "philosophically." available control technology (BACT) was applied to control both criteria and nonbest pollutants. As the air toxic problem increased in the US during the middle to late criteria the EPA required sources to install better pollution control devices at their facilities 1970s, the NESHAP regulations. objective was to control HAP emissions to a "zero through level of protection" for the population. However, the NESHAP program has regulated risk few HAPs due to 1.0-2/00 2-2

20 regulated facilities. Regulations Affecting Fugitive Emission Monitoring y are asbestos, mercury, beryllium, vinyl chloride, benzene, and arsenic. radionuclides, March31, 1971 Asbestos March 31, 1971 Mercury March 31, 1971 Beryllium Radionuclides Dec. 27, 1979 lack of the ability to control HAP emissions from industrial sources, continued of the NAAQS, increased emissions from automobiles, and the growing violations with long-range transport of SO _/NOx and acid rain, resulted in Congress concerns the Clean Air Act Amendments of 1990 (CAAA of 1990). passing were eleven titles associated with the CAAA of re and Title III, Hazardous Air Nonattainment control of fugitive VOCs will help in reaching and maintaining the the for ozone. NAAQS all criteria pollutants. Of that, 38 areas are nonattainment for ozone based upon the for ozone 8-hour standard of 0.12 ppm. [Nonattainment designations based on pre-existing 188 HAPs which are known to cause suspected of causing cancer or other serious human health effects or ecosystem or HAPs are emitted from literally thousands of sources including large stationary damage. facilities (i.e., power plants), medium industrial chemical facilities of the industrial and small area sources like the neighborhood dry cleaners. SOCMI, 1.0-2/ carcinogenic. To date, there are only seven (7) NESHAPs that are regulated at selected Chloride Dec. 24, 1975 Vinyl June8, 1977 Benzene Arsenic June5, 1980 A short history of the passage of the CAAA of 1990 two titles that affect the control of fugitive VOCs are: Title I, Pollutants (HAPs). Titles of the CAAA of 1990 Title Nonattainment Title II Mobile Sources/Clean Fuels Title III Hazardous Air Pollutants Title IV Acid Rain Title V Permits Title.VI Ozone Depletion/Global Warming Miscellaneous, Research, Enforcement Titles VII-XI Under Title I, As of September 1998, 130 areas are still designated nonattainment the revised 8-hour ozone standard of ppm will not be designated until late 2000.] With reference to Title III, the CAAA of 1990 list

21 key feature associated with Title is: a new round.of updating the SIPs and federal plans (FIPs) to outline how the nonattainment areas are to achieve the implementation for ozone. This means tighter emission controls for VOCs, both fugitive and NAAQS source, at existing and new facilities. point Under Title III, the EPA has provided a to be applied to minimize exposure from the 188 HAPs to a risk level of in controls of getting cancer (10-6 risk). 1,000,000 control of fugitive VOCs from affected facilities are implemented through two major as documented in the Code of Federal Regulations (CFR), the NSPS and regulations NESHAP programs. see how the control of VOC emissions are implemented within the regulatory Let's of the Environmental Protection Agency (EPA). framework NAAQS Ambient Air National Quality Standards NESHAP Emission Standards for National NSPS Source Perfomance New Standards MACT Achievable Control Maximum HON Organic NESHAP Hazardous /00 Lesson 2 effects of Title I and Title III list of designated substances to be regulated by In addition, the Agency can require additional applying MACT to the affected facility. Interrelationship of Fugitive VOC Regulations Permit Operating Applications and Permit Standards Approvals Hazardous Air Pollutamts Benzine NESHAP Technology

22 Subpart DDD: Regulations Affecting Fugitive Emission Monitoring Polymer Manufacturing Industry Subpart W: Synthetic Organic Chemicals Manufacturing Industry (SOCMI) Subpart VV defines the leak detection and repair (LDAR) program that is Requirements for first attempt to repair equipment when a leak is detected 2. 5 days) and maximum days to repair (15 days) (within Stated recordkeeping and reporting requirements associated with site specific 7. program LDAR 8. List of specific chemical VOCs regulated under Subpart VV chemical makeup of the processing fluid "evaporates to greater than 10 % at connectors, and agitators) which are in contact with the process fluid sampling the definition of "light liquid service" is regulated for fugitive emissions meeting Title 40 ( Environment), Part 60 (New Source Performance Standards), EPA Under regulated fugitive VOC emissions from process equipment in the following subparts: has Subpa VV: SOCMI Subpa GGG: Petroleum Refineries Onshore Natural Gas Processing SubpaaKKK: the for all regulations containing requirements for controlling fugitive VOC "backbone" emissions. the items included in Subpart VV are: Among Standards for process equipment in "light liquid service." Exemptions for pumps with barrier fluids. Stated maximum percent (3%) allowed for "difficult-to-monitor" valves 4. Alternative standards (skip periods) allowed for well controlled fugitive 5. if they represent < 2.0 %. emissions Guidance on implementing Method 21 test procedures 6. Subpart GGG: Petroleum refineries refineries Petroleum defined in the equipment leak standard applicable to them are "... any facility engaged in producing gasoline, kerosene, distillate fuel oils, as; oils, lubricants, or other products through the distillation, cracking, or residual of unfinished petroleum derivatives." reforming GGG addresses compressors and the group of all the equipment within a Subpart unit that is in "light liquid service for fugitive VOC emissions if the process 150 C." All components (i.e., valves, flanges, pumps, compressors, pressure relief valves, under this regulation /00

23 KKK: Onshore natural gas processing Subpart KKK for Onshore Natural Gas Processing also contains leak detection Subpart engaged in the extraction of natural gas liquids from field gas, KKK specifically includes any compressor station, dehydration units, Subpart units, or liquefied natural gas unit if it is located at an onshore natural gas sweetening at 150 C. In addition, the same valves and flanges are regulated under this 10% as they have been in previous subparts. subpart leaks regulations under NESHAP (40CFR 61) Equipment previously noted, the control of fugitive VOCs is implemented through two major As. regulations, the NSPS and NESHAP programs. Permit Operating Applications and Permit NAAQS Ambient Air National Quality Standards NESHAP Emission Standards for National NSPS Source Perfomance New Standards MACT Achievable Control Maximum HON Organic N SHAP Hazardous /00 Lesson 2 requirements. Natural gas processing plants are defined as "...processing(sites) fractionation of mixed natural gas liquids to natural gas products or both." processing plant. definition of"in VOC service" is the same as that found under the petroleum refinery subpart. Subpart DDD: Polymer manufacturing plants to the other subparts, Subpart DDD defines "...in light liquid service" and Similar to those polymer manufacturing plants that produce polypropylene, applies polystyrene, and copolymers. percent evaporated is greater than polyethylene Interrelationship of Fugitive VOC Regulations Approvals Standards Hazardous Air Pollutamts Benzine NESHAP Technology

24 now look at the regulations found under the NESHAP program that addresses Let's leaks of fugitive VOCs. equipment subparts that contain fugitive VOC equipment leak standards, under 40CFR61, Those are: Subpart F: Vinyl Chloride Subpart V: Fugitive Emissions Sources (VHAP Equipment Leaks) because they are carcinogens or cause other serious diseases. dichloride, vinyl chloride, and one or more polymers containing any fraction ethylene polymerized vinyl chloride. of primary effect of Subpart F implementation was to require a leak definition, and repair provisions for valves and flanges in vinyl schedule, service. chloride Research and development facilities using < 50 gallons and not regulated 1. Equipment in vacuum service and not regulated 2. Less stringent recordkeeping and reporting requirements if number of leaking 3. are < 2% of the total population valves applies to pumps, compressors, pressure relief devices, sampling benzene) systems, open-ended valves or lines, valves, and flanges and other connection This standard applies to individual pieces of equipment that is in connectors. service. benzene include: Exemptions Plant design < 1,100 tons/yr 1. No equipment in benzene service in the process 2. Coke by-product plants / Regulations Affecting Fugitive Emission Monitoring Subpart J: Benzene Remember, NESHAP regulations were developed to control pollutants that are hazardous Subpart F: Vinyl Chloride (40CFR61) F of 40CFR61, the vinyl chloride standards, affects plants that produce Subpart specific monitoring As with other regulations, there are several exemptions. y 'include: Subpart J: Benzene (40CFR61) standard for fugitive emissions for equipment in benzene service (10% by weight 4. Equipment in vacuum service

25 V: Fugitive Emission Sources (40CFR61) Subpart all equipment that is in contact with the process fluid that is at least 10% by Covers weight a VOC or VHAP addresses LDAR program requirements similar to those found in Subpart Standard of40cfr60, NSPS. VV Operating Permit NAAQS Ambient Air National Quality Standards NESHAP Emission Standards for National Standards MACT Achievable Control MaximL m MACT regulations (Maximum Available Control Technology), as the name implies, the use of modern/current technology in control equipment to achieve the requires Lesson 2 Now let's look at the MACT standards under the NESHAP program. Interrelationship of Fugitive VOC Regulations NSPS Permit Applications and New Source Perfomance Standards Approvals Hazardous Air Pollutamts Benzine NESHAP Technology Hazardous Organic NESHAP maximum HAPs emission reduction possible /00 2-8

26 CAAA of 1990 established a 10-year schedule for MACT standard promulgation for 4 years (4-year bin), an additional 25 percent not later than the 7 th year (7-year bin) first the remaining 50 percent not later than the tenth year (10-year bin) of the program. and Year Bin: Dry Cleaners (Subpart M) 2 YearBin: Aerospace (Subpart GG) 4 YearBin: Lead Smelting (Subpart X) 7 Year Bin: Industrial Boilers 10 (Subpart M) HON Vessels (Subpart Y) Marine let's look at the regulations under the NESHAP program form the Hazardous Finally, NESHAP (HON) regulations. Organic Operating Permit NAAQS Ambient Air National NESHAP Emission Standards for National Standards MACT Achievable Control Maximum HON Organic NESHAP Hazardous Regulations Affecting Fugitive Emission Monitoring than 173 source categories. Under this schedule, EPA is to promulgate certain more standards in the first 2 years of the program (2-year bin), about 25 percent in the MACT (Subpart XX) Shipbuilding Turbines Stationary Interrelationship of Fugitive VOC Regulations ;tandards Quality New Source Perfomance _ NSPS Permit Applications and Standards Approvals Hazardous Air Pollutamts Benzine NESHAP Technology HON regulations can be found in 40CFR63 in Subparts F, G, H, and I, and address (4) major categories involved with the SOCMI program. y are: four /00

27 F (40CFR63) Subpart F contains provisions for determining applicability of the HON, definitions, Subpart G (40CFR63) Subpart G defines the specific control, monitoring, reporting, and recordkeeping Subpart Subpart H (40CFR63) H defines fugitive VOC equipment leaks and emissions from SOCMI Subpart provides the definition for non-socmi processes subject to the negotiated HON regulates emissions of 111 of the 188 listed organic HAPs as identified in the of In addition, the HON also lists 21 specific compounds that are CAAA polycyclic organic matter. a minimum, the provisions of Subparts F; G, and H apply to chemical manufacturing At units that: process Manufacture as a primary product one or more of the chemicals listed in Table of 1. F; and Subpart tons/year, then the requirements under the HON do not apply 1,100 If chemical process uses only heavy liquid in production, the HON requirements do 2. apply. not Beverage alcohol production facilities are not regulated. 3. Equipment that is not in "VOC service" is not regulated 4. Equipment that is in vacuum service is not regulated 5. Lesson 2 and general procedures for testing, compliance, reporting, and recordkeeping. for SOCMI process vents, transfer operations, storage vessels, and requirements streams. wastewater Subpart I (40CFR63) Subpart regulation. Use as a reactant or manufacture as a product, by-product, or co-product, one or more 2. the organic hazardous air pollutants listed in Table 2 of Subpart F. of are several exemptions associated with the $OCMI regulations. y are: re If production capacity for those chemicals listed in Table of Subpart F is less than I /00

28 gas stream, the following equipment is Pumps Valves Connectors/flanges Compressors Agitators vent systems and control devices Closed Regulations Affecting Fugitive Emission Monitoring subject to the HON rule: considerations Regulation that the HON regulation covers 453 organic chemical manufacturing processes Remembering EPA formed a refore, groups, state and local agencies, and a environmental "-Performance L target "!o Y!s Figure 2-1 Reg Neg Enforcement covered by HON Equipment the process is in contact with VOCs/VHAPs that are at least 5% of the composite If 385 facilities that produce any of the chemicals listed in Table of Subpart F, EPA rule and were faced with the question, "Can a simple set of rules apply to all SOCMI industrial makers answer is obviously "No," the rules must be flexible. rule must achieve facilities?" fugitive emission levels from regulated facilities and equipment and yet be consistent lower with MACT requirements committee of interested parties (EPA, regulated community, facilitator) so that the concerned parties could negotiate directly to resolve issues and gain a consensus for publication of a final rule. This type of rule making is referred to as "Regulation Negotiation (Reg Neg)." Prior to Reg Neg, EPA would set the emission standard and it was the source's responsibility to meet that standard or face the penalty. Yes No Q Penalty '-Reynard " /00

29 Improvement Program (QIP) Quality QIP enables plants failing to meet base performance levels to eventually achieve the desired levels without incurring penalties or being in noncompliance. Overall, this Q1P program involves the source gathering background information, determining technologies to replace the poor performing equipment, and replacing the superior equipment with the superior equipment until the base performance is achieved. do not like to be forced into a QIP program because it requires by law to replace sources with superior technology and the fact that it is the Agency dictating the components requirement that a leak detection and repair (LDAR) program be established at a Lesson illustrates the enforcement path for Reg Neg rules. Under "Reg Neg," a source Figure receive rewards if they exceed emission reduction targets. traditional penalty is still may place if targets are not met. When targets are not met, the source must implement a stricter in program and develop a Quality Improvement Plan (QIP) which documents how monitoring source is to bring the system back within compliance. If a QIP is developed and the the penalty may be avoided. executed, emission reduction (by replacement of existing components with superior achieves without lengthy enforcement action. technology) However, program. detection and repair program Leak important element of the final HON rule,, developed under Reg Neg, was the An facility. LDAR is the backbone of the fugitive emission monitoring and regulated activities. LDAR will be discussed in more detail in following lessons. enforcement 1.0-2/

30 1. Which of the following standards is the oldest? NAAQS c. NESHAP d. hazardous air pollutant definitions appear in 5. SOCMI regulations appear in Part of 40CFR60 Regulations Affecting Fugitive Emission Monitoring 6. Fugitive emission source equipment/components are defined in Part Lesson 2- Self-Test HON a. MACT b. NSPS e. date, how many NESHAPs are regulated? To a. None b. 7 c. 26 d. 34 e. >50 of the CAAA a. Title b. Title II Title III c. Title IV d. e. Title V of the CAAA MACT standard is found in a. Title I b. Title II c. Title III d. Title IV e. Title V a. VV b. GGG c. KKK d. DDD of 40CFR61 a. C b. F c. J d. N e. V /00

31 (True/False)RegNeg provides an avenue for a source to avoid penalties if extra effort is 7. to meet targets. made /00 Lesson 2 a. True b. False

32 1. C 3. c 4. c 5. a 6. e 7. a Regulations Affecting Fugitive Emission Monitoring 1.0-2/ Lesson 2- Self-Test Answers

33 Lesson /

34 type and quantity of pollutant allowed to be emitted. the equipment required to minimize the emissions. control Regulations even specify the type of refore, an inspector needs to know the nature and type of emissions that are regulated in Objectives completion of this lesson, the student should bc able to: Upon Identify typical compounds that are regulated under the fugitive VOC emissions 3. regulations Classification of Air Pollutants two basic physical forms of air pollutants are particulate matter and gases. includes small solid or liquid particles such as dust, smoke, mists, and fly ash. matter is one that is emitted into the atmosphere directly from the source of the pollutant pollutant retains the same chemical form after release. An example of a primary pollutant is the and emissions of sulfur dioxide from a secondary pollutant is one that undergoes a chemical change once it reaches the A reaction in the atmosphere of organic vapors with sunlight and oxides of atmosphere. nitrogen to form ozone is an example of a secondary pollutant. further identified air pollutants as criteria pollutants and non-criteriapollutants. Criteria EPA are the six pollutants identified under NAAQS ( CO, 03, SO _, particulate matter, pollutants 3 Lesson VOC Emission Properties Fugitive ambient air contains hundreds, if not thousands, of air pollutants that may be detrimental to regulations that regulate the emission of air pollutants are very specific concerning health. order to do the job correctly. Define/describe the terms associated with fugitive VOC emission activities 1. Identify the different classifications of air pollutants 2. Particulate Gases include substances such as carbon monoxide, sulfur dioxide, and.volatile organic compounds (VOCs). contain combination of organic and inorganic Both particulate matter and gases constituents. A primary Pollutants are classified as either primary pollutants or secondary pollutants. fossil-fueled-fired steam generator /00

35 and Pb). Non-criteria pollutants are all pollutants other than specified as criteria under NO2, NAAQS. non-criteria pollutants through the NESHAP program. In 1983, the SOCMI for identified an additional set of non-criteria pollutants for emission control. regulations part of the CAAA of 1990, EPA published two more lists of non-criteria pollutants to As reviewed. Title contains a list of non-criteria VOCs that were believed to take part in be complex atmospheric chemistry in the formation of ozone, while Title III contains a the of non-criteria VOCs that are defined as Hazardous Air Pollutants (HAPs). list 1994 Hazardous Organic NESHAPS (HON) rule adds two morehap lists of pollutants (Subpart F, Tables and 2) that must be reviewed in determining the regulated Categories VOC on vapor pressure, EPA has classified VOCs in Based Very Volatile: temperature of the process stream can affect the category under which a is a modifying term used, as you will see in the following definitions, to indicate Service the gas or fluid is associated with subject" process or product. that VOC service refers to equipment containing or contacting a process fluid that is at least In % VOC (reactive organic) by weight. This NSPS regulation applies only to those 10 in VOV service. compounds gas/vaporservice refers to equipment that contains process fluid in the gaseous or In state at operating conditions. vapor,4ir Polh tants (HAPs) are those constituents listed in Title III Hazardous /00 Lesson 3 Pollutants Regulated 1970 Clean Air Act established NAAQS and sampling methodologies for Criteria pollutants. In addition, the Act established emission limits and monitoring methodology applicability of the HON regulations. four categories: >380mmHg Volatilei Hg mm 10E-1 to 10E-7 mmhg Semi-volatile: Non-volatiles: <IOE-7 mmhg VOC will fall. Definitions Regulatory the regulations there are terms and definitions important to monitoring fugitive Within emissions. In the following text, some of the frequently used terms are briefly defined. organic compounds (VOCs), as defined under NSPS/SOCMI regulations, are any Volatile organic compound that participates in atmospheric photochemical reactions. reactive Volatile hazardo ts air pollutant (VHAP) applies to benzene and vinyl chloride service. of the CAAA of 1990.

36 Fugitive VOC Emission Properties is important to note that the definitions are general. actual values used in determining It a gas or fluid is in a given "service" may vary according to the regulation under whether which it is being applied /00 3-3

37 Lesson 3.O-2/O0 3-4

38 Fugitive VOC Emission Properties 1. A pollutant that changes pi'operties once released into the atmosphere is a Criteria pollutant a. Non-criteria pollutant b. Primary pollutant c. Secondary pollutant d. 2. six pollutants identified in NAAQS are identified as Criteria pollutant a. Non-criteria pollutant b. Primary pollutant c. Secondary pollutant d. False b. All regulated pollutants are identified in one composite list in the (True/False) regulations. True a. Self-Test Lesson 3 e. VOC e. VOC 3. (True/False) VOCs are classified as a primary pollutant. a. True b. False /00

39 b. 3. b. 4. Lesson 3 Lesson 3 Self-Test Answers ]. d /00

40 by the equipment used in.these industries. Objectives completion of this lesson, the student should be able to: Upon refineries and synthetic organic chemical manufacturing industries (SOCMI) have Petroleum of piping and numerous components through which process gases, liquids, and vapors are miles relief devices; diaphragms, etc.) in these facilities can leak gases or liquids into the pressure leaks of light or volatile organic compounds (VOCs) are a concern with environment. Flanges/connectors Valves Pumps Compressors relief devices Pressure agitators Those components are: thermal stresses, vibrations, effects of corrosion (both within the system and from outside conditions), and mechanical wear that the components are subjected to account atmospheric will be briefly described and, where possible, the leak points will be identified components illustrated. and 4 Lesson Emission Sources Fugitive focus of this lesson is to identify the source of fugitive emissions both by industry type and Identify the facilities/industries most prone/susceptible to emitting fugitive emissions 1. Identify equipment defined in the regulations as sources for fugitive emissions For each piece of equipment identify the point(s) where fugitive emissions originate transported (flow). process transport components (valves, fittings, pumps, compressors, to their effect on air quality. Fugitive emissions are estimated to be responsible for over respect percent of the total VOC emissions from refineries and SOCMI sources. 50 leaking components Major NESHAP, and HON regulations identify the components in the process transport NSPS, function that are to be inspected for fugitive emissions (leaks). for the development of leaks and the unwanted emissions. In the remainder of this lesson the 1.0-2/00 4-1

41 but three common methods are welds, flanges, and threaded fittings. together, Many piping connections are welded when disassembly of connections will be I. Proper welds are practically leak proof connections, but they may fail process equipment where disassembly for maintenance may be required. and connections are usually used for piping carrying flammable or other Flanged materials because they are stronger and leak less than screwed fittings. hazardous connections are bolted together with a gasket material, usually made of Flanged the flanges due to thermal stresses, faulty gaskets or improper tightening of bolts. Threaded fittings are used for joining small diameter piping (under two inches in 3. Threaded connections are prone to leaking when they are disassembled diameter). connections can also break more easily, especially when stepped Threaded or subjected to some other heavy load. on /00 Lesson 4 and connectors Flanges are many ways of joining piping sections and process transport equipment re unnecessary. corrode. or Bolted flanges (Figure 4-1) are a common type of connection used for pipes, valves, 2. Teflon, graphite, or polymer material, between the flanges. Leaks can occur between In practice, flanges are rarely found to leak and are relatively small sources of emissions. regularly. Figure 4-1 Bolted flanges

42

43 Valves are used to control flow rate, turn a exist and are employed in refineries and SOCMI facilities. valve design, the leak points in a handle tc the disc or gate to control the flow. components and forms the passage route for the gas or liquid. provides for manual operation of the valve. handle or hydraulic mechanisms rather than by a handle. electrical Fugitive Emission Sources flow on or off, switch flows along different bonnet may be bolted, breechlocked, or screwed to the body. common and are sealed to the body using a most Figure 4-2 However, regardless of the stem transfers the action of the body of a valve houses the valve Typical valve parts of a typical valve Bolted bonnets are the Valves Many valve designs routes of piping, or control the direction of flow of gases or liquids. valve are basically the same for all designs. valves make up more than 90 % of the process components that must be checked Process leaks. Of the total fugitive VOC emissions from a refinery process, valves account for more than 35 % of those emissions and of those valves, approximately 85 % of for VOC emissions are from valves controlling gas streams. fugitive of a valve include the body, disc or gate, stem, bonnet, packing or seal, and the Parts as illustrated in Figure 2-I. disc or gate of the valve directly contacts the flow handle and permits or restricts the flow of the fluid or gas. packing or seal the stem and provides a barrier between the process liquids and gasses and the surrounds atmosphere. bonnet houses the packing or seal and supports the stem. outside Some valves may be operated by are illustrated in figure 4-2. gasket /00

44 include: valves stem at the exit from the housing. Valve Figure 4-3 identifies three common leak points on a Pumps are mechanical devices that impart energy to a Pumps Potential areas of fugitive VOC emissions from to transport a liquid from one location to another. Two of the more common types power pumps found in the petroleum and SOCMI industries are: of pumps Centrifugal displacement pumps. Positive Centrifugal pumps have a pressure to the fluid. rotating impeller that provides kinetic energy and static A positive displacement pump operates on the same principle as a tire pump Lesson 4 can develop in valves from thermal stresses, vibrations, corrosion, valve stem Leaks packing material failure, and wear. se effects can lead to the misalignment distortion, and distortion of sealing surfaces. Valve stems are packed with laminated hydrocarbon plastics, and synthetic materials that fail over time and graphite, a passageway for the emissions. provides gasket. Due to extensive wear and operation, the gasket material Bonnet/housing become worn and provide a can area for leaking VOC emissions. possible flange/connector to intake and output pipe. Valve valve. Figure 4-3 Valve leak points fluid, and are used to provide the and the shaft motion is in and out, driving a piston in the pump cylinder/housing /00

45 of the type of pump, the fluid being moved inside a Regardless the atmosphere. Isolation is achieved in two basic manners: from Fugitive Emission Sources pump must be isolated Using a seal at the interface between the pump and the shaft. Leaks may occur at the 1. of contact between the shaft and the "seal/stationary casting point Using a magnetic coupling between the pump and the drive source (centrifugal 2. In this case, the motor shaft and the pump shaft are two separate shafts pumps). coupled magnetically and no seal is Figure 4-4 packing are the focal point for leaks. addition to the shaft/bearing interface, the pump, like the valve, has a body constructed In at least two pieces and held together with bolts. Although not as subject to leaking, the of has the potential. It is interesting to note in figure 4-4 that the pump housing is body to minimize fugitive VOCs, making it very difficult to monitor the pump insulated required. Centrifugal pump assembly the illustration (Figure 4-4), the motor, motor shaft, and shaft coupling are of no In when looking for leaks. interface of the pump shaft and the bearing or concern housing joints /00 4-5

46 Compressors are used to compress and transport gases. Compressors From a "leak" standpoint, a relief devices [also called pressure relief valves (PRVs) or pressure vacuum Pressure (PV valves)] are valves that are made to release pressure from a vessel or relieve a valves exceeds a set pressure, allowing the release of vapor or liquids into the pressure When the normal pressure is re-attained, the valve reseats and a seal is again atmosphere. pressure, so they become a source of fugitive VOC emissions. to the set pressure of the valve close reseating of the valve after a relieving operation Improper Pressure relief valves that vent to a Agitators are used to stir or blend chemicals. Agitators figure 4-5, the size of a typical agitator vessel can be observed. Leak points on the In are the connections for the process fluid/gasses entering and leaving the vessel and vessel Lesson 4 is the same as a pump. Mechanically, they are similar to pumps in that they compressor generally either reciprocating or centrifugal. Once again, the major source of are emissions is the shaft and the compressor housing. Pressure Relief Devices vacuum on a vessel. y prevent damage to equipment and are safety feature on most vessels in a refinery. codes require the use of pressure relieving devices or systems in applications Engineering the process pressure may exceed the maximum allowable working pressure of the where vessel. Typically, relief valves are spring-loaded and designed to open when the system formed. Sometimes pressure relief devices will not close properly after they release only potential area of leaks with a PRV is the "sealing seat" of the valve which is enclosed in a pipe system (or horn) to allow release of pressure. Monitoring for fugitive VOC emissions would occur at the seating of the valve. causes of leaks in a PRV: Possible or popping:" A condition that occurs when the system pressure comes "Simmering Corrosion or degradation of the valve seat. flair header or are.equipped with upstream rupture disks need not be screened. Like pumps and compressors, agitators may leak organic chemicals at the point where the shaft penetrates the casing. Consequently, seals are required to minimize fugitive emissions. shaft of the agitator may either be horizontal or vertical. the interface with the shaft and the vessel /00

47 Figure 4-5 Agitator vessel Fugitive Emission Sources a platform at the top or'the agitator, the shaft is seen at tile interface point with the From possible fugitive emission point is clearly visible, and is being monitored in vessel. Figure 4-6 Agitator shaft 1.0-2/ this illustration (Figure 4-6).

48 know what is to be monitored. next lessons will introduce how monitoring is to be we implemented. Lesson 4 This lesson has introduced the major components subject to fugitive emission monitoring. Now /00

49 Disk/gate c. Packing d. Fugitive Emission Sources Of the three connection methods listed below, which is the most common in refinery and 2. facilities? SOCMI Bolted flange a. Threaded fitting b. Shaft coupling e. (True/False) components and leak points on a compressor are essentially the same as 4. those for a (True/False) most likely point for a leak on an agitator is at the bearing (interface) of 6. agitator shaft with the vessel. the Lesson 4 Self-Test Which of the following components of a valve would not be susceptible to leaking? I. Body/flange a. b. Bonnet e. Stem c. Weld Which of the following pump components should be examined for leaks? 3. impeller a. Motor shaft b. Pump casing c. d. Pump shaft pump. a. True b. False 5. Which of the following pressure relief valve conditions is not a fugitive leak? a. Corrosion of the valve seat b. Excessive/extreme pressure in the system on which the valve is installed Improper reseating of the valve c. Simmering or popping d. a. True b. False 1.0-2/00 4-9

50 1. C Lesson 4 Self-Test Answers Lesson /

51 various fugitive emission regulations (NSPS, NESHAP, HON, & SIPs) require the use of Reference Method 21 (FRM 21) for determining whether a component leak meets the Federal definition found within the individual regulations. It is therefore important to become leak with FRM 21. familiar of analyzers available for the inspector to use in evaluating equipment leaks. number not all of these monitors meet the specifications of FRM 21. However, re are a 2. Identify the specifications that apply to analyzing equipment under FRM 21 Federal Reference Method 21 can be found in 40 CFR 60, Appendix A. Source Performance Standards (NSPS) and Appendix A contains the Federal Reference New that must be used in determining emission compliance with in the limits specified in the Methods equipment. FRM 21 does not recommend specific analyzers or manufacturers, but it does process analyzer performance specifications define VOC Analyzers Portable VOC analyzers take two basic forms:. Portable A single hand-held units (Figure 5-1) containing all the instrumentation in one unit. 1. is extracted, conditioned, analyzed, and reported within one assembly. sample multi-component unit (Figure 5-2) that separates the inlet from the analytical section 2. the system by way of an umbilical cord. This approach allows greater flexibility in of 1.0-2/ Lesson Reference Method 21 Federal Objectives completion of this Upon the student should be able to: lesson, Identify the basic requirements of Federal Reference Method CFR 60 covers the NSPS. FRM 21 specifies that a hand-held instrument is to be used in determining VOC leaks from reaching "hard-to-monitor" regulated equipment.

52 Figure 5-1 Figure 5-2 Lesson 5 Single component hand-held analyzer Multi-component hand-held analyzer 1.0-2/00 5-2