06/01/84
Benzene NESHAPs Guidance
JUNE 1 1984
SUBJECT: Benzene NESHAPs Guidance
FROM: Director
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
TO: Air and Waste Management Division Directors
Regions II, IV, VI-VIII, and X
Air Management Division Directors
Regions I, III, V, and IX
Attached are enforcement guidelines for the benzene NESHAPs,
which is scheduled to be promulgated on June 4, 1984 and which
will regulate benzene equipment leaks from fugitive emission
sources. The guidelines summarize the regulations and address
potential enforcement problems. All Regions should work with
delegated States in identifying affected sources and ensuring
those sources are in compliance with the benzene regulations.
The Stationary Source Compliance Division and the Emission
Standards and Engineering Division have jointly agreed to present
a one day session discussing the benzene NESHAPs, if there is
sufficient interest among Regional personnel. The session is
tentatively scheduled for Washington during the week of June 18.
Please notify Robert Myers at (FTS) 382-2875 if representatives
from your Region would be interested in attending such a meeting.
Edward E. Reich
Attachment
NESHAPS Enforcement Guideline S-28 - Benzene Equipment Leaks
( Fugitive Emission Sources )
Benzene standards are being promulgated under the
National Emission Standards for Hazardous Air Pollutants,
Section 112 of the Clean Air Act. Standards under this
section have already been promulgated for asbestos, beryllium,
mercury, and vinyl chloride, and have been proposed for
arsenic and radionuclides in addition to benzene. OAQPS has
prepared this document to aid in enforcement and implementation
of the benzene NESHAPs. This summarizes the benzene equipment
being regulated and the standards to which this equipment is
subject, and provides guidance on several issues of
enforcement concern.
Background
On June 8, 1977 the Administrator declared benzene a
hazardous air pollutant and a carcinogenic risk to human
health. Standards were later proposed for four sources of
benzene emissions. These sources were benzene equipment
leaks ( fugitive emission sources ), proposed 1/5/81, 46 FR
1165, maleic anhydride plants, ethylbenzene/styrene plants,
and benzene storage vessels. Further analysis has led EPA
to conclude that both the benzene health risks ( annual
leukemia incidence and maximum lifetime risk ) to the public
from the latter three source categories and the potential
reduction in health risks achievable with available control
techniques are too small to warrant action under Section 112
for these three categories. As a result, EPA proposed on March
6, 1984, 49 FR 8386, to withdraw the proposed standards for
these three categories. Because of the magnitude of benzene
fugitive emissions, the projected increase in emissions as a
result of new sources, and the estimated decrease in risks and
emissions achievable through controls, EPA found fugitive benzene
emissions posed a significant risk and should be regulated.
Introduction
Valves, pumps, flanges and other pieces of equipment
are used extensively in the refining and organic chemical
industries to move streams of organic compounds to and from
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various process vessels. Since this type of equipment can
develop leaks, each individual piece is a potential source
of organic compound emissions whenever it handles a process
stream containing such compounds. Benzene fugitive emissions
sources are pieces of equipment handling streams that could
potentially contain benzene. These include sources that
develop leaks after some period of operation due to seal
failure as well as other sources that can emit benzene when
used in specific conditions in the production unit. The
sources that develop leaks due to seal failure are those using
a sealing mechanism to limit the escape of organic compounds
to atmosphere. These include pumps, valves, flanges, relief
valves and compressors. Other types of equipment are potential
benzene fugitive emissions sources for reasons other than
leaking seals. These types of equipment might have the
potential for intermittent benzene emissions because they vent organic
materials that contain benzene to atmosphere, and include sampling
connections, open-ended valves, and product accumulator vessels.
Scope and Applicability
The standard covers new and existing valves, pumps,
compressors, pressure relief devices, sampling connection
systems, open-ended valves or lines, pipeline flanges,
product accumulator vessels, and closed vent systems and
control devices used to comply with the standard. This
equipment is used in the production of benzene and other
chemicals and products, such as maleic anhydride, ethanol,
and pharmaceuticals.
To be covered the equipment must be in benzene service,
i.e., it must contain material with a benzene concentration
of 10 percent or more by weight. See the compliance issues
topic for a discussion of "in benzene service".
Exempted from this standard is equipment located in
process units that produce benzene or benzene mixtures at coke
by-product plants. These will be covered by other regulations.
Additionally, plant sites designed to produce or use benzene in
quantities of 1000 Mg/yr or less are exempt from the standard.
The source owner or operator has the responsibility of demon
strating to EPA's satisfaction that the site is below the 1000
Mg/yr threshold level. Such a demonstration can be accomplished
by engineering analysis as well as by proof of physical limitation
of plant capacity.
- 3 -
Controls for new and existing sources are the same.
In the case of an existing source or a new source which has
an initial startup date preceding the effective date, the
standard applies within 90 days of the effective date, unless
a waiver is granted pursuant to Section 61.11.
EPA estimates the standard will affect equipment located
in approximately 240 existing process units and an expected
70 new process units by 1985. Attachment 1 lists 131 plant
sites EPA has identifies as having the potential to emit
benzene fugitive emissions. This list is not exhaustive and
Regions and States should seek to identify other affected
sites and confirm the accuracy of those listed.
Standards
Generic standards for equipment leaks are presented under
subpart V of 40 CFR 61. Subpart J, standards for benzene
equipment leaks, requires that affected sources must meet the
requirements of Subpart V. Two basic control techniques are
employed by the standard to reduce benzene fugitive emissions.
These are leak detection and repair programs in which fugitive
source leaks are located and repaired at regular intervals, and
preventive programs in which potential fugitive sources are
eliminated by either retrofitting with specified controls or
replacement with leakless equipment. A discussion of the
specific standards for each affected piece of equipment follows.
1. Valves.
This is one of the most common pieces of equipment in a refinery
or organic chemical production unit. It ordinarily is activated by a
valve stem requiring a seal to isolate the process fluid from
atmosphere. Since the potential for leaks exists, valves are subject
to regulation.
A monthly leak detection and repair program is required
for valves in gas or liquid service. Gas and liquid service
are defined under Section 61.191. Quarterly monitoring will be
allowed for valves that have been found not to leak for two
successive months. Leak detection is to be performed with a
portable organic vapor analyzer, according to Reference Method
21 of 40 CFR 60, Appendix A. A leak is described as a reading
of 10,000 ppm or greater of organic material. Whenever a
leak is detected the valve must be tagged until repaired and,
at a minimum, must be monitored monthly until a leak is not
detected for two successive months.
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Initial repair of the leak must be attempted within 5
days, and the repair must be completed within 15 days.
Initial repair includes, but is not limited to, the following
best practices where practicable:
(1) tightening of bonnet bolts;
(2) replacement of bonnet bolts;
(3) tightening of packing gland nuts; and
(4) injection of lubricant into lubricated packing.
See Section 61.192-7(e).
An annual leak detection and repair program is required
to be developed and followed if the valves are difficult to
monitor. The description of this program must be kept in a
readily accessible location. Difficult to monitor valves
are those that would require elevating the monitoring personnel
more than two meters above any permanent available support
surface. Valves that cannot be safely monitored by the use
of step ladders could be classified as difficult to monitor.
For valves which are unsafe to monitor, an owner or
operator is required to develop and follow a plan that defines
a leak detection and repair program conforming with the
routine monitoring requirements of the standard as much as
possible, with the understanding that monitoring should not
occur during unsafe conditions. Unsafe to monitor valves
are defined as those that could, as demonstrated by the
owner or operator, expose monitoring personnel to imminent
hazards from temperature, pressure, or explosive process
conditions. There should be very few valves in benzene
service that are unsafe to monitor.
Two alternative standards are available for valves in
gas/vapor and liquid service. The first alternative
specifies a two percent limitation as the maximum percent of
valves leaking within a process unit, determined by an initial
performance test and a minimum of one performance test annually
thereafter. Process unit is defined at Section 61.191. This
alternative could be met by implementing any type of program and
engineering controls chosen at the discretion of
- 5 -
the owner or operator. If the percentage of valves leaking
is higher than two percent, the process unit is in violation.
If owners or operators decide they no longer wish to comply
with this alternative, they must submit written notice to
EPA accepting compliance with the monthly/quarterly leak
detection and repair program.
The second alternative standard specifies two skip-period
leak detection and repair programs. Under this option an
owner or operator upon notifying EPA can skip from monthly/
quarterly monitoring to something less frequent after
completing a specified number of consecutive monitoring intervals with
the percentage of valves leaking equal to or less than 2.0. Under the
first program, after two consecutive quarterly periods with fewer than
two percent of valves leaking, an owner or operator may skip to
semiannual monitoring. Under the second program after 5 consecutive
quarterly periods with fewer than two percent of valves leaking, annual
monitoring may be adopted. An owner or operator cannot adopt
semiannual monitoring and then proceed directly to annual monitoring by
claiming one period of semiannual monitoring substitutes for two
quarterly periods. If the owner or operator finds the two percent level
is exceeded, he or she must revert to monthly/quarterly leak detection
and repair. If EPA finds the two percent level is exceeded, an
evaluation of compliance should occur. This alternative differs from
the first alternative because the type of compliance program chosen
musts be leak detection and repair, rather than a program at the
discretion of the owner or operator.
An owner or operator electing to comply with the provisions
of either of these options must notify the Administrator 90 days
before implementing the option.
Delay of repair for equipment for which leaks have been
detected is allowed under certain circumstances. See Section 61.192-
10. There are two general circumstances where repair delays
for pumps, compressors and closed-vent systems, as well as for
valves, are allowable. The first is where repair is technically
or physically infeasible without a process unit shutdown,
defined as a work practice or operational procedure stopping
production. The use of spare equipment and technically
feasible bypassing of equipment without stopping production
are not process unit shutdowns. Repair must occur before
the end of the next process unit shutdown; hence, only one
- 6 -
shutdown may be passed before repair is always required.
Repair is required during scheduled shutdowns of any duration
and during unscheduled shutdowns of over 24 hours.
The second general circumstance where repair delay is
allowed is if the equipment is isolated from the process and
no longer contains benzene in concentrations greater than
ten percent.
Delay of repair specifically for valves is allowed
beyond a process unit shutdown when unforeseeable circumstances
deplete valves used for repair. The valve assembly supplies
must have been sufficiently stocked before the supplies were
depleted. In this case delay of repair beyond the next
process unit shutdown will not be allowed unless the next
process unit shutdown occurs sooner than six months after
the first shutdown. Delay of repair for valves is also
allowed if the owner or operator can show that leakage of
purged material resulting from immediate repair would be
greater than the fugitive equipment leaks likely to result
from delay of repair, and that when repairs are effected,
the purged material is destroyed or recovered in a control
device.
2. Pumps -
A pump normally has a shaft that requires a seal to isolate
the process fluid from atmosphere. Packed and mechanical shaft
seals are most common. If the seal becomes imperfect due to
wear, compounds being pumped leak.
Requirements for pumps are similar to those for valves,
a monthly leak detection and repair program is required, with
detection determined by Reference Method 21. Alternatively,
dual mechanical seals may be used under conditions specified
at Section 61.192-2(d). Each pump must be visually inspected
weekly for indications of liquid dripping from the pump seal.
A reading of at least 10,000 ppm or indication of liquids
dripping is a leak.
Initial pump leak repair must be attempted within five
days and completed within 15. Delay of repair is allowed
for pumps that cannot be repaired without a process unit
shutdown and a delay of up to six months after leak detection
is allowed when the owner or operator determines that repair
requires use of a dual mechanical seal system with barrier
fluid system. Any pump equipped with a closed-vent system
capable of capturing and transporting any leakage from the
seal to a control device is exempt from the requirements.
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3. Compressors -
Compressors have a shaft that requires a seal to isolate
the process gas from atmosphere. The potential for a leak
through this seal makes it a potential source of benzene
emissions. The standard requires the use of seals with
barrier fluid systems that prevent leakage. The barrier
fluid system must be equipped with a sensor that will
detect failure of the seal or barrier fluid system. Sensors
must be checked daily or have an alarm. If the sensor detects
a failure, a leak is detected. Leaks must be repaired within 15
days. A compressor is exempt from the above if it is equipped
with a closed-vent system transporting leaks to a control device,
or it satisfies the no detectable emissions provision at Section
61.192-3(i).
4. Pressure relief devices in gas/vapor service.
The standard requires no detectable emissions, which
is a reading of less than 500 ppmv above background based
on Reference Method 21. As an alternative, compliance may
be achieved by use of a rupture disk system or closed-vent
system capable of capturing and transporting leakage from
the pressure relief device to a control device, such as a
flare. This standard does not apply to discharge during
overpressure relief, but the relief device must be returned
to a nondetectable emissions status within five days of such
a discharge. Additionally, relief valve simmering (wherein
the system pressure is close to valve set pressure) is not
allowed.
5. Sampling Connection System -
Product quality and process unit operation is checked
periodically by analysis of feedstocks, intermediates, and
products. To obtain representative samples for these analyses,
sampling lines generally are purged first. If this flushing
liquid purge is not returned to the process, it could be
drained onto the ground or into a process drain, where it
would evaporate and release benzene to atmosphere.
The standard provides for closed-purge sampling to
eliminate emissions due to purging by either returning the
purge material directly to the process or by collecting the
purge in a collection system generally closed to the
atmosphere and disposing of it in an appropriately designed
control device. Closed-vent vacuum systems connected to a
control device and in-situ sampling systems are also allowed.
- 8 -
6. Open-Ended Valves or Lines -
Some valves are installed in a system so that they function
with the downstream line open to atmosphere. A faulty valve seat
or incompletely closed valve would cause leakage through the valve.
The use of caps, plugs, or any other equipment that will effect
enclosure of the open end is required. If a second valve is used,
the standard requires the upstream valve to be closed first. This
prevents the trapping of process fluid between the two valves.
7. Product Accumulator Vessels, Flanges, Pressure Relief
Devices in Liquid Service -
Product accumulator vessels are utilized with fractionation
columns, and may be vented directly or indirectly to atmosphere.
Flanges are gasket-sealed junctions which may develop seal leaks.
Pressure relief devices are designed to release a product material
from distillation columns and other pressurized systems during
emergency or upset conditions.
The standard for product accumulator vessels effectively
requires venting accumulator emissions to a control device,
or use of a closed-vent system. Flanges and pressure relief
devices in liquid service are excluded from routine leak
detection and repair requirements, but if leaks are detected
by visual, audible or olfactory techniques, they are subject
to the same allowable repair interval as applies to valves
and pumps.
8. Closed-Vent Systems and Control Devices -
Control devices will be used to reduce benzene equipment
leaks captured and transported through closed-vent systems.
Reference Method 21 requires that closed-vent systems be checked
visually to ensure there are no leaks where they would not be
expected ( e.g., in pipes ) and also requires the monitoring of
connections that are expected to leak occasionally.
Enclosed combustion devices, such as incinerators,
catalytic incinerators, boilers, or process heaters must be
designed to reduce emissions vented to them with an efficiency
of 95% ro greater or provide a minimum residence time of
0.50 seconds at a minimum temperature of 760. C. Vapor
recovery systems such as carbon adsorbers or condensation
units must be designed and operated to recover the organic
vapors vented to them with an efficiency of 95% or greater.
As an alternative the use of smokeless flares designed
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for and operated with no visible emissions is allowed. Specific
flare conditions established at Section 61.192-11(d) and Section
61.195(e) must be met and destruction efficiency must be over 95%.
Equipment purges from valves, pump seals, compressor seals,
pressure relief devices, sampling connection systems, and
product accumulator vessels must be vented to a system complying
with the requirements of the control device portion of the
standard.
Closed-vent systems must be designed and operated with no
detectable emissions, as indicated by an instrument reading of
below 500 ppm above background and by visual inspections. See
Section 61.195(c). They shall be monitored initially, annually, and
at other times requested by the Administrator. Leaks must be
repaired as soon as practicable, but not later than 15 days
after detection, with a first attempt no later than five days
after detection.
Equivalent Means of Emission Limitation
Each owner or operator may apply to the Administrator
for determination of equivalence for any means of emission
limitation that achieves a reduction at least equivalent to
the reduction achieved by the required controls. Guidelines
for the determination of equivalence are provided at Section
61.194(b) and (c). Acceptance of such an equivalent method
must be approved by the Administrator and published in the
Federal Register. Such a request applies to pumps, compressors,
sampling connection systems, open-ended valves or lines,
valves, pressure relief devices, product accumulator vessels
and closed-vent systems and control devices. Such requests
should be forwarded to the Emission Standards and Engineering
Division ( ESED ) for review and approval.
No Detectable Emissions
Pumps pursuant to Section 61.192-2(e), compressors pursuant to
Section 61.192-3(i) and valves pursuant to Section 61.192-7(f) may
be designated for not detectable emissions, indicated by a Method 21
instrument reading of less than 500 ppm above background.
These pieces of equipment would be exempt from other
requirements, as specified. Pressure relief devices in gas/vapor
service and closed-vent systems must be designed for and operated with
no visible emissions, with compliance determined by Method 21.
Compliance of flares with the no visible emissions standard, as provided
at Section 61.192-11(d), shall be determined by Reference Method 22.
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Performance tests shall be conducted a minimum of once per
year, except for pressure relief devices and flares. Pressure
relief devices shall be tested no later than five calendar days
after each pressure release. Flares shall be monitored with an
appropriate heat sensor, such as a thermocouple, to ensure the
presence of a flame. Also, flares must be a smokeless operation,
as evidenced by visible emissions for a maximum of 5 minutes
in any 2-hour period.
Reporting Requirements
Reporting requirements, described under Section 61.197, are of
two types. The first is an initial report, and the second a
series of semiannual reports. An initial report must be
submitted within 90 days of the effective date for existing
sources or new sources having an initial startup date
preceding the effective date. For new sources with a startup
date after the effective date. For new sources with a startup
date after the effective date, the initial report must be
submitted with the application for approval of construction, as
described in Section 61.07.
Receipt of the initial report is essential for ensuring
compliance with this standard. The report must specify equipment
identification number and process unit identification, type of
equipment, percent by weight benzene in the equipment fluid,
process fluid state ( gas/vapor or liquid ), and method of
compliance with the standard ( monthly leak detection, no
detectable emissions, etc. ).
Semiannual reports of leak detection and repair efforts
within a process unit are required. The reports must include
the number of leaks occurring within the process unit during
the reporting period, the number of leaks that could not be
repaired within 15 days, and the general reasons for
unsuccessful or delayed repair past 15 days. Reports may be
photocopies of reports under other regulations, provided the
informational requirements of Section 61.197 are satisfied.
Recordkeeping Requirements
These are specified at Section 61.196. Each leak shall be
identified and tagged, and this must be retained until the
leak is repaired. When each leak is detected, records should
be kept of the equipment and operator identification numbers,
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dates for detection and repair, method of repair, and any reason
for delay of repair. These must be kept for two years.
Recordkeeping pertaining to the design requirements for closed-
vent systems and control devices must be recorded in a log and
kept in a readily accessible location. This recordkeeping
includes detailed schematics, design specifications, a
description of the parameters monitored to ensure proper control device
operation and maintenance, periods when the closed-vent system and
control devices were not operated as designed, periods when a flame
pilot light did not have a flame, and dates of startups and shutdowns of
the systems. Additionally, records must be kept explaining why valves
have been classified as unsafe or difficult to monitor and providing
plans for monitoring such valves. Records must be kept showing analyses
demonstrating that equipment is not in benzene service.
Compliance Issues
Compliance is determined by review of records required by
Section 61.196, review of performance test results, and inspections
( EPA/State leak detections ) using the methods and procedures
specified in Section 61.195. There are, however, several potential
compliance issues for which guidance is provided here.
1. For purposes of determining the percent benzene content,
Section 61.195(d) provides that ASTM Method D-2267 shall be used or an
owner or operator may use engineering judgment to demonstrate
that the percent benzene content does not exceed 10 percent by
weight. In case of a dispute the ASTM method takes precedence.
It should be noted that each piece of equipment within a process
unit that can conceivably contain equipment in benzene service
is presumed to be in benzene service unless an owner or operator
demonstrates otherwise. For a piece of equipment to be considered
not in service, it must be determined that the percent benzene
content can be reasonably expected never to exceed ten percent
by weight. The burden is on the owner or operator to show
equipment is not in benzene service.
2. Several benzene equipment standards require that
the owner or operator develop, based on design considerations and
operating experience, a criterion indicating system failure.
See Section 61.192-2(d)(5) for pumps and Section 61.192-3(e)(2) for
compressors. The valve standard requires at Section 61.19107(g) that
the owner or operator have written plans for monitoring unsafe-to-
monitor-valves during safe periods and at Section 61.192-7(h) that
the owner
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or operator have written plans for monitoring difficult-to-
monitor valves at least once per year. Although none of these
plans requires EPA approval, all must be accessible to inspection
personnel. Should the plan appear inadequate, inspectors may
request development of a new plan or a performance test when
applicable to ensure compliance is being achieved. If the
plan is obviously inadequate ( intentionally inadequate ), a
violation should be pursued.
3. The standard for closed-vent systems and control
devices at Section 61.192-11(e) requires that owners and
operators of control devices used to comply with the standard
monitor their control devices to ensure they are operated and
maintained in conformance with their designs. No monitoring
parameters are suggested; however, the owner or operator must
achieve 95% control and the parameter selected must indicate this.
The Synthetic Organic Chemical Manufacturing Industry
promulgation Background Document ( EPA 450/3-30-033b, June 1982,
Appendix B ) provides acceptable monitoring parameters and
equipment. These include operating temperature or flowrate
of fugitive emission vent streams for incinerators, flow
recorders to verify steam flow for boilers, thermocouples or
ultraviolet beam sensors for flares, temperature and specific
gravity of the adsorbing liquid for adsorbers, offgas exit
temperature for condensers, and carbon bed temperature and
steam flow recorders for carbon adsorbers. See Attachment II.
Whatever parameter is chosen, the owner or operator should
be aware that EPA can require an engineering evaluation at
any time to ensure the parameter is appropriate with the
standard.
4. The general provisions at Section 61.10 and 61.11 allow
EPA to grant a waiver from a benzene standard for a period of up to
two years, if the owner or operator of an existing source subject
to that standard is unable to operate in compliance with the
standard. Most benzene requirements are in the form of work
practice standards, and waivers from these standards would not
be appropriate. However, certain provisions may require retrofitting
of controls. These include standards for compressors ( mechanical
seals with barrier fluid systems ) pressure relief devices ( rupture
disk systems or closed-vent systems to flares ), and product accumulator
vessels ( must vent
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emissions to a control device or use a closed-vent system ).
In cases where retrofit controls are necessary, requests for
waivers should be examined on a case-by-case basis. Although
ESED believes installation of controls should typically take
no more than one year, individual situations may require
additional time.
Attachment I
Table 9-1. REFINERIES AND ORGANIC CHEMICAL MANUFACTURING
SITES WITH BENZENE FUGITIVE EMISSION POTENTIAL
Benzene-Related
Products Capacity
Plant City/State At Site (Gg/yr)
1. Allied Chemical Geismar, LA Et 340
2. Allied Chemical Moundsville, WV NiBz 25.
3. American Cyanamid Bound Brook, NJ NiBz 48
4. American Cyanamid Willow Island, WV NiBzc 34.
5. Amerada Hess St. Croix, VI Bz 217
6. American Hoechst Baton Rouge, La EtBz 526.
St NDg
7. American Hoechst Bayport, TX EtBzd 469.
Std 409
8. American Petrofina Port Arthur, TX Bz 67.
(of Texas)
9. American Petrofina Big Spring, TX Bz 194
Cyx 35.
EtBze 20
St 41.
10. American Petrofina Groves, TX Et 9
( Cosden Oil/Petrogas )
11. American Petrofina/ Beaumont, TX Bz 73
Union Oil of CA Cyx 88.
12. Ashland Oil Ashland, KY Bz 214
Cu 181.
Cyx NDg
13. Ashland Oil Neal, WV MAN 27.
14. Ashland Oil North Tonawanda, NY Bz 77
15. Atlantic Richfield Beaver Valley, PA St 200.
( Kobuta )
16. Atlantic Richfield Channelview, TX Bzc 107
Et (2 units) 1179.
9-2
17. Atlantic Richfield Wilmington, CA Bz 40
Et 45.
18. Atlantic Richfield Houston, TX Bzc 140
( ARCO/Polymers ) Et 227.
EtBz 61
St 54.
19. Atlantic Richfield Port Arthur, TX EtBz 114
( ARCO/Polymers )
20. Charter Houston, TX Bz 17
International EtBz 16.
21. Chemetics Geismar, LA NiBz 173
International
22. Chemplex Clinton, IO Et 227.
23. Cities Service Lake Charles, LA Bz 83
Et (2 units) 400
24. Clark Oil Blue Island, IL Cu 50.
25. Coastal States Gas Corpus Christi, TX Bz 234
Cue 64.
26. Commonwealth Oil Penuelas, PR Bz 618
Cyx 117
EtBze 73.
27. Continental Oil Baltimore, MD LAB 122
28. Continental Oil Lake Charles, LA Et 302
29. Core-Lube Danville, IL BSA NDg.
30. Corpus Christi Corpus Christi, TX Bzd 100
Petrochemicals Etd 544
31. Cos-Mar, Inc. Carrville, LA EtBz 690.
St 590
32. Crown Central Pasadena, TX Bz 77
33. Denka ( Petrotex ) Houston, TX MAN 23
34. Dow Chemical Bay City, MI Bz 100
Et 86.
9-3
35. Dow Chemical Freeport, TX Bz 167
Et (5 units) 1136
EtBz 794
St 658.
36. Dow Chemical Midland, MI C1Bz 129
EtBze 249
St 181.
37. Dow Chemical Orange, TX Et 375
38. Dow Chemical Plaquemine, LA Bzd 200
Et (2 units) 545.
39. Dupont Beaumont, TX NiBz 159
40. Dupont Gibbstown, NJ NiBz 110.
41. Dupont Orange, TX Et 374
42. Eastman Kodak Longview, TX Et 580.
43. El Paso Natural Gas Odessa, TX Et NDg
Etbz 125
St 68.
44. El Paso Products/ Odessa, TX Et 236
Rexene Polyolefins Stc 47.
45. Exxon Baton Rouge, LA Bz 234
Et 816
EtBz NDg
St NDg.
46. Exxon Baytown, TX Bz 200
Cyx 147
Etc
36.
47. First Chemical Pascagoula, MS NiBz 152
48. Georgia-Pacific Houston, TX Cu 340.
49. Getty Oil Delaware City, DE Bz 37
9-4
50. Getty Oil El Dorado, KA Bz 43
Cu 61.
51. B.F. Goodrich Calvert City, KY Et 136
52. Goodyear Tire and Bayport, TX Hgn 5.
Rubber
53. Gulf Coast Olefins Taft, LA Etc 218
54. Gulf Oil Alliance, LA Bz 224
55. Gulf Oil Donaldsonville, LA EtBz 313
St 272.
56. Gulf Oil Philadelphia, PA Bz 124
Cu 209.
57. Gulf Oil Chemicals Cedar Bayou, TX Et (2 units) 719
58. Gulf Oil Chemicals Port Arthur, TX Bzc 134
Cu 204
Cyx 106
Et(2 units) 558.
59. Hercules McGregor, TX C1Bzf 0.05
60. Howell San Antonio, TX Bz NDg
61. ICC Industries Niagara Falls, NY C1Bz 11
62. Independent Regining Winnie, TX Bz 10.
Corp.
63. Jim Walter Resources Birmingham, AL BSA NDg
64. Kerr-McGee Corp. Corpus Christi, TX Bz 53
65. Koppers Bridgeville, PA MAN 15
66. Koppers Cicero, IL MAN 5
67. Koppers Petrolic, PA Rcnol 16
68. Marathon Oil Texas City, TX Bz 23
Cue 95.
69. Mobay Chemical New Martinsville, WV NiBz1 61
9-5
70. Mobil Oil Beaumont, TX Bz 200
Et 410.
71. Monsanto Alvin, TX Cuc 340
( Chocolate Bayou ) Etc 285
EtBz 27
LAB 102.
72. Monsanto Sauget, IL C1Bz 80
NiBz 5.
73. Monsanto St. Louis, MO MAN 48
74. Monsanto Texas City, TX Bz 284
Et 45
EtBz 744
St 680.
75. Montrose Chemical Henderson, NV C1Bz 32
76. National Distillers Tuscola, IL Et 181
( U.S.I. )
77. Nease Chemical State College, PA BSAe NDg.
78. Northern Morris, IL Et 400
Petrochemical
79. Olin Corporation Brandenburg, KY Et 50
80. Oxirane Channelview, TX EtBz 525
St 454.
81. Pennzoil (Atlas) Shreveport, LA Bzc 49
82. Phillips Petroleum Borger, TX Cyx 104
EtBz NDg
83. Phillips Petroleum Pasadena, TX Et 13.
84. Phillips Petroleum Sweeny, TX Bz 33
Cyx 250
Et (3 units) 973.
9-6
85. Phillips Puerto Guayama, PR Bz 367.
Rico
Cyxc 212
86. Puerto Rico Penuelas, PR Et 454.
Olefins
87. PPG Natrium WV C1Bz NDg
88. PPG New Martinsville, WV C1Bz 64.
89. Quintana-Howell Corpus Christi, TX Bzc 23
90. Reichhold Chemicals Elizabeth, NJ MAN 14
91. Reichhold Chemicals Morris, IL MAN 20.
92. Reichhold Chemicals Tuscaloosa, AL BSA NDSg
93. Rubicon Geismar, LA NiBz 170.
94. Shell Chemical Houston, TX Et 590
95. Shell Oil Deer Park, TX Bzc 301.
Cu 326
Et 681.
96. Shell Chemical Norco, LA Bzd 133
Etd 681.
97. Shell Oil Odessa, TX Bz 40.
98. Shell Oil Wood River, IL Bz 150
99. Specialty Organics Irwindale, CA C1Bz 2.
100. Standard Chlorine Delaware City, DE C1Bz 125
101. Standard Chlorine Kearny, NJ C1Bz 7.
102. Standard Oil (CA)/ El Segundo, CA Bz 77
Chevron Chemical Cu 45.
103. Standard Oil (CA) Pascagoula, MS Bz NDg
Chevron
104. Standard Oil (CA) Richmond, CA Bz NDg.
Chevron
105. Standard Oil (IN)/ Alvin, TX Et (2 units) 907
Amoco
9-7
106. Standard Oil (IN)/ Texas City, TX Bz 284
Amoco Cu 14
EtBz 386
St 381.
107. Standard Oil (OH)/ Marcus Hook, PA Bz 27.
BP Oil
108. Stauffer Chemical Henderson, NV BSA 4.
109. Sun Oil Corpus Christi, TX Bz 127
Cu 113
Et 9
EtBz 61
St 54.
110. Sun Oil Marcus Hook, PA Bz 97
111. Sun Oil Toledo, OH Bzc 164
112. Sun Oil Tulsa, OK Bz q30
Cyxc 83.
113. Sun-Olin Claymont, DE Et 109
114. Tenneco Chalmette, LA Bz 33
EtBz 16
115. Tenneco Fords, NJ MAN 12.
116. Texaco Port Arthur, TX Bz 150
Cyxc 117
Et 454.
117. Texaco Westville, NJ Bz 117.
118. Texaco/Jefferson Bellaire, TX Et 240
Chemical
119. Texaco/Jefferson Port Neches, TX Et 1238.
Chemical
9-8
120. Union Carbide Institute, WV EtBz NDg
LAB 64
St NDg.
121. Union Carbide Penuelas, PR Bz NDFg
Cu 290
Et 454.
122. Union Carbide Seadrift, TX Et 546
EtBz 154
St 136.
123. Union Carbide Taft, LA Bzc 234
Et 500
124. Union Carbide Texas City, TX Et 546.
125. Union Carbide Torrance, Ca Et 73
126. Union Oil of CA Lemont, IL Bz 57.
127. Union Pacific/ Corpus Christi, TX Bz 33
Champlin Cud NDg.
Cyx 65
128. U.S. Steel Neville Island, PA MAN 38
129. USS Chemicals Houston, TX Et 227
130. Vertac/Transvaal Jacksonville, AR C1Bz NDg
131. Witco Chemical Carson, CA LAB 20.
aBSA = Benzenesulfonic Acid Hgn = Hydroguinone
Bz = Benzene LAB = Linear.
CLBz = Chlorobenzene Alkylbenzene
Cu = Cumene MAN = Maleic Anhydride
Cyx = Cyclohexane NiBz = Nitrobenzene.
Et = Ethylene Rcnol = Resorcinol
EtBz = Ethylbenzene St = Styrene.
9-9
biannual capacities for each product were obtained from the following
sources (effective date of capacity in parentheses):
BSA - Ref. 3 (January 1977)
Bz - Refs. 3 (January 1977), 14
CLBz - Refs. 4 (January 1977), 13, 14
Cu - Ref. 9 (January 1979), 13, 14
Cyx - Ref. 2 (November 1976), 3 (January 1977)
Et - Refs. 5 (1977 year-end), 15 (June 1979), 11, 13, 14, 33
EtBz - Ref. 10 (January 1979)
Hgn - Capacity estimate from industry (1979)
LAB 9 Ref. 8 (June 1978)
MAN 9 Ref. 3 (January 1977)
NiBz - Refs. 7, 32
Rcnol - Ref. 6
St- Refs. 1 (1977 year-end), 14
c Product unit under expansion
d Product unit under construction
e Product unit on standby or not currently in use
f Product unit in engineering phase
g No data available
9-10
Attachment II
APPENDIX B MONITORING METHODS
The standards require that some fugitive emission vent streams be
vented through a closed vent system to a control device ( that is
designed and operated for greater than 95% control ), such as an
incinerator, flare, boiler, or process heater: The standards also
require that the control device be monitored to ensure that it is
properly operated and maintained. This appendix presents methods
for monitoring control devices: incinerators, boilers and process
heaters, flares, or product recovery equipment, such as condensers or
carbon adsorbers.
Incinerators
Incinerators must be maintained and operated properly if the
standard is to be achieved on a continuous basis. The operating
parameters that affect performance are temperature, type of compound
being incinerated, residence time, inlet concentration, and flow regime.
Of these variables, the last two have the smallest effect on the
performance of an incinerator. Residence time is a design criterion
and is not easily altered after the incinerator is constructed, unless,
of course, the vent stream flowrate is changed. At temperatures above
760.C, the type of compound being burned has little effect on the
efficiency of combustion.
Continuous monitoring of the incinerator inlet and outlet would be
preferred because it would provide a continuous, direct measurement of
actual emissions and destruction efficiently. However, EPA is aware of
no continuous monitor being used to measure total VOC at incinerators
which control fugitive vent streams, probably because each of the many
different compounds would have to be identified separately and their
concentrations determined. Such a monitoring system would be extremely
complex for the determination of individual component concentration and
mass flow rates. Moreover, it would be relatively expensive since both
inlet and outlet monitors are required to verify that a certain
destruction efficiency is maintained.
B-1
Monitoring of the incinerator operating temperature provides a
reliable measure of the efficiency of the incinerator in destroying
organic compounds. Both theoretical calculations and results of
monitoring or performance tests show that lower incinerator operating
temperatures can cause a significant decrease in VOC destruction
efficiency. Temperature recorders are relatively inexpensive, costing
less than $5,000 installed. They are easily and cheaply operated.
Given the large effect of temperature on efficiency and the reasonable
cost of temperature monitors, EPA believes that temperature is clearly
easy to monitor and would provide some measure of the uniformity of the
operation of the incinerator.
Where a combustion device is used to incinerate only waste VOC
streams (and not multiple waste streams from the process unit), flowrate
can also be an indirect indication of changes in destruction efficiency
since it relates directly to residence time in the combustion device.
Flowrates of fugitive emission vent streams are typically small and
thus would probably be ducted with other larger streams to the same
incinerator. Under these circumstance, the vent stream flowrate (for
fugitive emissions) may not always give a reliable indication of the
residence time of the fugitive emission vent stream in the incinerator.
Simple indication of fugitive emission vent stream flowrate to the
incinerator does, however, provide verification that VOC is being routed
to the incinerator. Flow recorders, at an estimated installed cost of
less than $2,000, are inexpensive and require little maintenance.
Therefore, since flow recorders provide verification that organics-
laden streams are being routed to the incinerator for destruction and
they are inexpensive, flowrate is also a reasonable parameter to monitor
the constancy of performance of an incinerator. Flow recorders should
be installed, calibrated, maintained, and operated according to the
manufacturer's specifications.
Boilers
If a fugitive emissions vent is piped to the flame zone of a boiler
(or process heater), it is only necessary to know that the boiler (or
heater) is operating and that the waste gas is flowing to the boiler (or
heater). Records presently maintained for plant operation, such as
stream production
B-2
records, would indicate operation. Flow recorders could be installed to
verify flow of the vent stream to the boiler (or heater). For smaller
heat producing units (less than 44 MW (150 million Btu/hr heat input)),
combustion temperature should also be recorded to enable verification
of optimum operation. Boilers (or heaters) with heat input design
capacities greater than 44 MW would not be required to install
temperature recorders. These larger units always operate at high
temperatures (GT 110.C) and stable flowrates to avoid upsets and to
maximize steam generation rates. Records that indicate onstream time
would be sufficient for these larger boilers (or heaters).
Flares
Because flares are not enclosed combustion devices, it is not
practically feasible to measure combustion parameters continuously.
Temperatures and residence times are more variable throughout the
combustion zone for flares than for enclosed devices and, therefore,
such measurements would not necessarily provide a good indicator of
flare performance even if measurable. Monitoring of flow rate to the
flare is generally unacceptable from a safety point of view since the
flow measurement would present an obstruction in an emergency vent
line. As a result, flare operation is usually verified by examination
of more prominent characteristics.
The typical method of verifying continuous operation of a flare is
visual inspection. However, if a flare is operating smokelessly, it
can be difficult to determine if a flame is present, and it may take
several hours to discover. The presence of a flame can be determined
through the use of a heat sensing device, such as a thermocouple or
ultra-violet (U-V) beam sensor on a flare's pilot flame. The loss or
absence of a flame would be indicated by a low temperature measurement.
The cost of available thermocouple sensors ranges in price from $800
to $3,000 per pilot. (The more expensive sensors in this price range
have elaborate automatic relight and alarm systems.) Thermocouples
used on flares may, however, burn out if not installed properly.
The cost of a U-V sensor is approximately $2,000. A U-V system is
not as accurate as a thermocouple in indicating the presence of a
flame. The U-V beam is influenced by ambient infrared radiation that
B-3
could affect the accuracy. Furthermore, interference between different
U-V beams makes it difficult to monitor flares with multiple pilots.
By design, U-V sensors are primarily used to verify the existence of
flames within enclosed combustion devices. Therefore, based on cost and
applicability, EPA believes thermocouples provide adequate verification
of flare operation.
Product Recovery Equipment
Three types of product recovery equipment which might be used in
controlling fugitive emissions vents are adsorbers, condensers, and
carbon adsorbers.
Two operating parameters are the primary determinants of product
recovery device operation for an adsorber: the temperature and specific
gravity of the adsorbing liquid. Facilities which have installed an
adsorber to recover product which otherwise would be lost will generally
monitor a parameter which indicates the degree of saturation of the
absorbing liquid with respect to the product. Specific gravity is
commonly used for this purpose. Devices for measuring the temperature
and specific gravity are available reasonable cost. The estimated one-
time combined capital investment for such equipment is $8,000. It is
considered reasonable for an operator of a process unit to install,
calibrate, maintain, and operate according to manufacturer's
specifications the requisite devices to monitoring continuously
temperature and specific gravity or such alternate parameters which
would indicate the degree of saturation of the adsorbing liquid.
In contrast, the exit temperature of the offgas is the primary
determinant of the efficiency of a condenser. Again, suitable
temperature recorders are available at a reasonable cost. The estimated
one-time capital investment is $3,000. A record of the outlet
temperature would verify that the condenser is properly operated and
maintained. EPA believes an operator can install, operate, calibrate
and maintain according to the manufacturer's specifications a
temperature recorder to verify proper operation of a condenser.
The operation of a carbon absorber can be monitored by the carbon
bed temperature and the amount of steam used to regenerate the bed.
Steam flow
B-4
meters and temperature recorders are available at reasonable cost. The
estimated one-time capital investment for such equipment is $10,000.
These parameters could be monitored to reflect whether the carbon
adsorption unit has been consistently operated and properly maintained.
Therefore, EPA believes that an operator of a carbon adsorber used as a
pollution control or product recovery device could install, calibrate,
maintain, and operate according to manufacturer's specifications an
integrating steam flow recorder and a carbon bed temperature recorder.
Some operators may install vent stream analyzers to aid in maximizing
the recovery of organic compounds. No widely accepted performance
specifications have been developed for such analyzers. If an analyzer
is installed without a recorder, the vent stream should be sampled at
the end of the adsorption cycle (at least once during every 4 hours of
operation) and the concentration recorded as a means of verifying that
operational modes remain consistent with the conditions under which the
performance test was conducted.
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