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8.10
BACT FOR FUGITIVE EMISSIONS OF HYDROCARBONS
As a condition of this permit, the applicant will development and
implement a plan to control fugitive emissions of hydrocarbons from the
proposed facility. A detailed written description of the plan must be made
available upon request by the Regional Administrator. Moreover, the plan
must be fully implemented within 180 days following initial plant startup.
As a minimum, the plan will include the following work practice and
equipment specifications:
- A leak detection and repair program will be implemented to reduce
emissions from equipment leaks. The following specifications,
criteria, and requirements will be built into the monitoring program.
a) Within 180 days of initial plant startup all components will be
monitored for leaks with a VOC detection device. In addition,
periodic monitoring of specific components will be performed
according to the following frequencies.
i) monitor with a VOC detection device at least once every 365
days:
- open ended pipes which have been fitted with closure
devices in accordance with Part 4 of this section, and
- process drains (if a leak is detected, the equipment
causing the organic discharge to the stream will be
identified and repaired).
ii) Monitor with a VOC detection device at least once every 90
days:
- valves in gas service,
- compressors and other components with rotating shafts in
gas service,
- reciprocating compressors and all other components with
reciprocating shafts in gas service,
- safety relief valves in gas service,
- safety relief valves in liquid service which are
shielded such that visual inspection cannot identify
leaks, and
- seal oil degassing vents.
iii) Monitor visually at least once every seven days:
- valves in liquid service,
- pumps and other components with rotating shafts in
liquid service,
- reciprocating pumps and other components with
reciprocating shafts in liquid service, and
- safety relief valves in liquid service.
b) The instrumentation and procedures used in the monitoring program
will conform to or be the equivalent of the test method in
Appendix B of the document, Control of Volatile Organic Compound
Leaks from Refinery Equipment (EPA-450/2-78-036).
c) A leak will be defined as emission of VOC to the atmosphere as a
result of
i) the dripping of liquid volatile organic compounds, and/or
ii) the detection of 10,000 ppm by volume measured as hexane at
the surface of (or as close as possible to) the potential
source with a portable VOC detection instrument.
d) All leaks will be repaired within five calendar days of the time
they are located. Repair of a component is defined as:
i) No dripping of liquid volatile organic compounds, and
ii) No concentration of volatile organic compounds in excess of
1,000 ppm by volume measured as hexane within one centimeter
of the leak source with a portable VOC detection instrument.
e) Records will be kept of each leak detected and the subsequent
maintenance performed on that leak. One way to comply with this
requirement is to keep a survey log as is described in Section
6.3.2 of the document referenced in Part (b) above. Whatever
system is used, records will contain sufficient information to
identify specific components within the plant. Records will be
maintained for a period of at least two years. In addition, when
a leak is found an easily identifiable waterproof tag bearing the
date the leak was located will be affixed to the components. This
tag will remain until the leak is repaired.
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f) All components in the service of VOC within the plant, except
flanges, will be made readily distinguishable from components not
in VOC service. This can be accomplished with an identifiable
marking of some kind.
g) Reports on the results of the leak detection and repair program
will be submitted to the Regional Administrator within 60 days of
each anniversary of initial plant startup. As a minimum this
report will include a discussion of the total number and type of
leaks repaired and a detailed description of leaks which were not
repaired within the five day time limit. The latter will include
sufficient detail to enable tracing the identity of each leak to
the plant records kept in accordance with the preceding
requirement (e). In addition to the annual reports, brief
quarterly reports, listing all leaks not repaired during the five
day limit, will be submitted to the Regional Administrator within
15 days of the end of of each 90 day period following initial
plant startup. The fourth quarterly report can be incorporated
into the annual report.
- Compressors, pumps and other components with rotating shafts will be
equipped with double mechanical seals.
- Safety relief valves handling VOC will be fitted with rupture discs in
the lines which precede them such that the relief valves are in series
with and follow the rupture discs,
or
safety relief valves in gas service handling VOC will be vented to a
flare, recovery, or some other means of control and safety relief
valves in liquid service handling VOC will be equipped with catch
basins or some other device which directs liquids discharged during
process upsets back to the process, to a control device or to disposal.
No more than ten percent by weight of the material discharged from each
safety relief valve will be emitted to the atmosphere.
- Open ended pipes will be equipped with caps, plugs; blind flanges,
second valves or other closure devices which will be removed or opened
only while the pipe is in use.
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- Cooling water in all non-contact condensers, heat exchangers and better
heat transfer equipment in VOC service will be maintained at a pressure
which exceeds the pressure of the VOC in the same piece of equipment by
ten percent,
or
the total organic carbon content of cooling water will be monitored at
the inlet to all cooling towers at least once every 90 days. If the
organic content is found to exceed ten ppm by weight, the equipment
which is leaking organics to the cooling water will be identified and
repaired. Testing will be in accordance with the approved methods for
total organic carbon outlined in 40 CFR 136.
- Sampling ports and procedures will be designed to prevent any VOC
emissions from purging sample lines and sample vessels. Also, samples
of volatile organic chemicals will be disposed of properly following
analysis. One way to comply with this requirement is to institute
closed loop sampling and to incinerate samples following analysis.
- Waste water separators will be equipped with sealed covers which
totally enclose the compartment liquid contents. These can be solid,
fixed roofs or floating roofs. Also, any gauging devices will include
a projection into the liquid or some other device to eliminate the
escape of vapors when the gauge is not in active service.
- Vacuum systems will be equipped such that non-condensibles from
hotwells, condensers, accumulators and other parts of the system are
vented to a flare, an incinerator, a fire box, a flue gas system, a
recovery system or some other means of control.
- Pressurized process units handling VOC will be vented to a flare, or
some other means of control during depressurization for unit
maintenance. Controlled venting will continue until the vessel's
internal pressure reaches the pressure drop across the control device
or five psig, whichever is less.
- Any tank truck or rail car loading facility having a throughput greater
than 76,000 liters (20,000 gallons) per day of volatile organic
compounds averaged over any 30-day period, will be equipped with a
vapor
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recovery system [ILLEGIBLE] vent gasses to at least 3447 pascals
(0.5 psia). Connections on vapor balance systems will be vapor
tight.
- Storage of volatile organic compounds will comply with the provisions
of the proposed standards of performance for petroleum liquid storage
vessels dated May 18, 1978 (proposed 40 CFR 60 Subpart Ka) with the
exception that the capacity size cut-off will be 94,635 liters (25,000
gallons) instead of 151,416 liters (40,000 gallons) and the lower limit
applicability on true vapor pressure will be 3.45 kilopascals (0.5
psia) instead of 10.35 kilopascals (1.5 psia). Also any uninsulated
tank exterior surfaces exposed to the sun will be painted white.
Furthermore, all fixed roof tanks not controlled by a vapor recovery
system will be equipped with a conservation vent which will be
inspected and maintained yearly to insure proper operation. Finally,
all storage tanks with a capacity exceeding 3785 liters (1000 gallons),
except pressure vessels and tanks with vapor recovery systems, will be
equipped with permanent submerged fill pipes.
EXEMPTIONS
Specifically excluded from the requirements of BACT for Fugitive
Emissions of Hydrocarbons are all pieces of equipment handling commercial
natural gas.
Any component which has no potential to emit VOC to the atmosphere, is
exempt from monitoring requirements. For example, a compressor which is
totally enclosed and vented to a flare system or a safety relief valve which
discharges to a flare system does not have to be monitored with a VOC
detection device.
EQUIVALENT TECHNOLOGY
Any technology shown to the satisfaction of the Regional Administrator
to be the equivalent of the work practices and equipment specifications in
this section can be substituted, with the Regional Administrator's written
permission, for the requirements of Parts 1 - 11.
DEFINITIONS
For the purposes of this section the following terms are defined.
- Volatile Organic Compounds (VOC) are compounds of carbon
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(excluding carbon monoxide, carbon dioxide, carbonic acid,
metallic carbides or carbonates, ammonium carbonate, ethane, and
methane) that have a true vapor pressure greater than 130 pascals
(0.0188 pounds per square inch).
- A Component is any piece of equipment capable of leaking VOC to
the atmosphere which includes but is not limited to pumps,
compressors, pipeline valves, safety relief valves, seal oil
degassing vents, open ended pipes and process drains.
- Open Ended Pipes are those which are preceded by valves or other
closure devices capable of leaking VOC to the atmosphere.
Exceptions are safety relief valves and bleeder valves in double
block and bleeder valve systems.
- Commercial Natural Gas is a mixture of gaseous hydrocarbons,
chiefly methane, used as a fuel and obtained from a company
licensed to dispense such gasses.
- Gas Service for components is defined as the VOC being gaseous at
the conditions that prevail in the facility during normal
operations. Similarly, Liquid Service for components is defined
as the VOC being liquid at the conditions which prevail during
normal operations.
- A cover on a waste water separator is considered to be sealed if
the concentration within one centimeter of the lip or the surface
of the tank does not exceed 10,000 ppm by volume measure as hexane
with a VOC detection device. A fixed roof will be measure at the
surfaces which join the roof to the walls of the compartment. A
floating roof tank will be measured along the plane across the
upper edge of the walls of the compartment.
- Fugitive Emission are emissions of VOC due to equipment leaks,
process upsets, sampling procedures, process turnarounds, and
storage and transfer of materials. Also included in the
definition of Fugitive Emissions are VOC emissions from wastewater
separators and vacuum systems.
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