:-. EPA COURSE #380 TECHNIQUES INSPECTION EMISSION SOURCES FOR, FUGITIVE VOC CHECKLIST

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1 :-. EPA COURSE #380 TECHNIQUES INSPECTION FUGITIVE VOC FOR, EMISSION SOURCES CHECKLIST

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3 Environmental Protection Agency U.S. Pollution Training Institute Air FEDERAL REFERENCE METHOD 21 INSPECTION 3. CHECKLIST Course #380 Fugitive Source Inspection TABLE OF CONTENTS 1. AGENCY FIELD INSPECTION CHECKLIST 2. SELF-AUDITING CHECKLIST 4. VENDOR AUDITING CHECKLIST

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5 Environmental Protection Agency U.S. Pollution Training Institute Air Course 0380 Fugitive Source Inspection AGENCY FIELD INSPECTION CHECKLIST

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7 SOURCE IDENTIFICATION 1.1 Name Company Facility Contact Statement Confidentiality Required FIELD INSPECTION NOTEBOOK AGENCY VOC EMISSIONS FUGITIVE 1.2 PREPARATION FOR INSPECTION A licabili of Federal E ui ment Leak Re ulations Which Federal Equipment Leak Regulations applies to the affected facility: Source Performance Standard New Subpart VV- SOCMI Equipment 40CFR60, Subpart GGG- Petroleum Refineries 40CFR60, Subpart KKK- Onshore Natural Gas Processing Plants 40CFR60, 40CFR60, Subpart DDD- Polymer Manufacturing Industry 1.0 LEVEL I CHECKLIST Mailing Address Location of Facility Personnel Facility Manager -:uvironmelltal Manager 2

8 Emission Standards for Hazardous Air Pollutants (NESHAP) National Subpart J- Benzene Equipment Leak 40CFR61, Subpart.F- Vinyl Chloride 40CFR61, Subpart H- Leak Organic Hazardous Air Pollutant (HAP) Equipment 40CFR63, NESHAP Leak Subpart I- Organic HAP Equipment Leak NESHAP for Certain 40CFR63, Conservation and Recovery Act IRC,RA) Resource Subpart BB- Air Emission Standards for Equipment Leaks for. TSDFs 40CFR264, Notification of Construction/Reconstruction Report Repai r notification of construction Initial reconstruction within 30 days of or commencement? of initial startup? Notification of actual startup?. Notification of physical/operational changes to facility? Notification of compliance status? Notification description of the facility's operation and design capacity: Brief of process unit(s) which fall under regulatory requirements Identification that requirements of standard Statement being implemented are of all subject equipment including: List by weight for regulated pollutant at the equipment -Percent fluid state at the equipment (gas/vapor, liquid, two phase fluid). -Process description of source LDAR program Brief for submitting semiannual reports Schedule Engineering diagram of regulated processes within the facility copy of source permit and compare to applicable regulations Obtain copy of previous semi-annual report Obtain submitted on time? -Report signed by facility representative? -Report Processes Subpart'BB- Air Emission Standards for Equipment Leaks for Interim 40CFR265, TSDFs Program Primary emission control (e.g. flare, scrubber, incinerator ere). of equipment (e.g., valves, pumps, flanges etc.) -Type number of regulated equipment -Identification -Process unit where equipment is located of compliance with the standard [e.g., monthly leak detection and repair -Method (LDAR), pump equipped with dual mechanical seals] program Semi-annual Report -Process unit identified?

9 contains information associated with: -Report components monitored? -Total (by type) of components leaked7 -Number of components for which leaks -Number not properly repaired? were of"non-repairable" leaking components? -Identification of leaks not repaired within 15 days? -Summary number -Tag detected -Date -Part of repair reason -Delay unit shutdown technically not feasible -Why "no detectable emissions" equipment number -Compare previous reports with of total components (by type) found leaking? -% % leaking in records to reported results -Check listed repairs and equipment identification along -Check retest requirements -Identification with construction of replacement of equipment or all performance test conductrd during the reporting -Review on all equipment designed period mcct the "skip period" and "no detectable emissions" to Remember to bring [NOTE: copy of at least one semiannual report a the inspection so that the semiannual on data can be spot checked against.in-plant records data.] report the source maintain Does document listing: a list of ID numbers for "difficult-to-monitor" -A components? list of ID numbers for "unsafe-to-monitor" -A components? list of ID numbers for "'skip periods" components? -A -A list ofld numbers for "no detectable emissions" components? Review of Source Leak Detection and Repair Program (I,DAR) statement by the regulated facility associated with -Clear establishment of the LDAR the at the facility along with reference to applicable regulations? program -LDAR document signed by Plant Manager, Environmental Manager, and Maintenance and Manager (if applicable)?.. Production of applicable regulations and identifications -Outline components regulated under those of requirements? of responsibility and chain-of-authority -Identification source LDAR program? for of equipment to be used in the -Identification LDAR program, along with written source (SOPs) for operation, maintenance, and calibration of equipment procedures accordance in Federal Reference Method 21 specifications? with of plant procedures and -Identification reeordkeeping performed within the proper source LDAR program. This information should including: (1) identification.specific who is responsible for tagging of components; (2) who repairs leaking leaking (3) who components; the proper Work Orders; (4) who should acquires the components once leaks retest repaired; (5) who updates are records and schedules based maintenance number of upon specific leak detection and repair -Source (LDAR) submitted and maintained in program files for review and update? source

10 components; and (5) who notifies management of completion of repairs and leaking source involved with the repair of the leaking components. personnel of data acquisition methods used in the LDAR program, example calculation -Identification "percent leaking components," and discussion of how semiannual reports will be on the appropriate representative of the -Has been notified of the time and date of source intended visit? Yes No auditor's of Representative Contacted Name contacted Date Onsite records review and walk-through inspection? Onsite records review, walk-through, and equipment leak evaluation? inspection materials (i.e., source files, notebook, pen, paper, -Gather etc.) camera safety protection equipment (i.e., hard hat, safety shoes, -Acquire plugs etc.) ear evaluation, acquire and calibrate fugitive VOC equipment and verify proper what type? evaluation, Random monitoring (to cover any/or of the some applicable areas)? HON/NSPS/NESHAP Targeted monitoring (To cover a specific applicable of area arriving at the facility, notice any visible emission from the process. -When Visible emissions? Yes No Where? there any strong odors around the facility? -Are and verified. prepared of a source Quality Improvement Prbgram (QIP)?. Identification Source Notification phone By letter By Record of notification filed 1.2.6,,Prepare Pre-inspection Plan inspection plan containing inspection objectives: -Develop Onsite records review only? -For a Level 3 operation a Level 3 If the process)? Specific Area -Obtain inspection checklist, site map and process drawings of regulated facility 2.0 LEVEL H CHECKLIST 2.1 ARRIVING AT THE FACILITY Walking to the Facility,

11 Yes Describe Sign-in At the Facili. Logbool_r -Always sign-in at the facility reception area. Show plant.personnel your credentials and which you equipment bringing onto the property. are any earneras, sampling equipment -Register the reception area to verify that at are not you company policy. violating about any special safety alerts -Inquire procedures. or 2.2 PRE-INSPECTION MEETING is to inform facility official(s) conference the purpose of the inspection, the of under will be conducted, and the procedures authority be followed, and to any questions they answer The opening conference also offers the inspector the opportunity to completely agency policy and inspection procedures, discuss to provide relevant information and other assistance. The inspector's effective execution of and opening conference often the the tone of sets Inspection objectives Inspection agenda Health and Safety Requirements Facility information verification/blue prints regulated process of Review of records records (i.e., ID of pumps, valves, Equipment relief pressure compressors, etc.) valves, of self-monitoring Records results test of equipment in Records service vacuum of repair dates/re-test dates from Records components leaking ofleakers (i.e., id, instrument Records leak value etc.) Records operator, equipment which is of from the regulations exempt of equipment in "skip" periods Records of weekly "visual inspection" Records pumps of of"unsafe_to_monitor,,, "'difficult-to-monitor," Records "no detectable and equipment emissions" of closed vent systems (i.e., schematics, design Records non-operational periods specification, etc.) Scheduling of Source Personnel Interviews No the inspection Before the refinery, the inspector should at to meet with source representatives directly responsible for arrange source LDAR program. The the of the opening purpose which it may have. the remainder of the inspection. During the pre-inspection meeting, the following items should be discussedi 6

12 Discussion of Inspection Techniques to Be Used Scheduling of Copying Needs particular, the inspector should develop his In her understanding of the or of the refinery to ascertain whether the system has been operation/maintenance operated The inspector should be able to. support of operation and maintenance records of the equipment; Examination inspections and performance checks Weekly previous reporting period; over the site-specific LDAR program; Reviewing comparison ( i.e., correlation of reported leakers, repairs Records regulated to operations and maintenance records, and computer printouts; and components, files to identify missing documents (if any). Reviewing following table should be completed by the inspector in conducting The preliminary meeting. the Any Questions according to permit condition since the last inspection. any conclusions by: Personnel In Attendance

13 2.2.2 In-plant Records Checklist Listing of Affected Equipmen_t the plant have the follow/ng information pertain/ng Does subject equipment in to permanent log? a Compressors Relief Devices in Gas/Vapor Service Pressure Connection Systems Sample Ended Valves Open Lines or Valves Relief Devices in Liquid Service, Flanges, Pressure Other Connectors and Accumulator Vessels Product in Vacuum Service Equipment list of identification numbers for equipment designated A meet "no detectable emissions" compliance to including the owner/operator's authorizing option designation: this Valves Relief Valves Pressure dates of each "'no detectable emissions" The test, including the background level measured during compliance test and the maximum instrument each measured at the equipment reading each test. during ps Relief Devices Pressure list of all valves which A designated "unsafe-to-monitor." are identification number Valve why each valve is Explanation plan for monitoring each valve list of all valves which A designated "difficult-to-monitor." are identification numbers Valve why each valve is difficult Explanation monitor to A plan for monitoring each valve One [NOTE: two of these valves may be field inspected or verify that they to indeed "unsafe or difficult to monitor".] are list of identification numbers for equipment A to the standard: Pumps subject Flanges Vent Systems Closed Pumps Compressors Compressors Valves unsafe-to-monitor

14 the plant have.the following information for two (2) years regarding compliance testing of Does equipment? regulated of regulated components if) of service Type of equipment Location type Component leak values Measured background values Ambient the plant have the following information for two (2) years regarding performance test data Does regulated components? of of equipment Location type Component leak values Measured background values Ambient the plant have the following information in a two year log regarding leaks located Does on compressors, valves, flanges, and other connectors? pumps, instrument and operator identification numbers and the equipment identification The number. date the leak was detected and the dates of each attempt to repair the leak. The methods applied in each attempt to repair the leaks. Repair of"above leak definition" if the maximum instrument reading measured by the Record specified in the CFR atter each attempt is equal to or greater than the leak detection methods of"repair delayed" and the reason for the delay if Record leak is not repaired within 15 a days atter disco,ery of the leak. calendar signature of the owner or operator (or designated) whose decision it The that repair was not be effected without a process shutdown. could Comments: Records of Fugitive VOC Emission Monitorin[, Records of Performance Test Data of regulated components of service Type Leak Equipment limit.

15 expected date of successful repair of the leak if The leak is not repaired within 15 calendar a after discovery of the leak. days The date of successful repair of the leak. valves complying with the "skip period leak detection For repair" compliance option, does the plant have and permanent log containing: a schedule for monitoring A percent of valves found leaking during each monitoring The period _.Example of calculation for determining present skip period and compressors that Pumps equipped with a dual mechanical seal system are have sensors to detect failure of the seal system, the must fluid system, barrier both. The following information or should be in a permanent log regarding these types of pumps and compressors: each compressor, the design criterion (or For chosen to monitor) and parameter explanation of that criterion. an Any changes to this criterion and the reasons for the changes Records of Visual,Inspection of Pumpn the plant have the following information for Does (2) years regarding compliancewith two visual inspection of regulated pumps? weekly of pump Location of inspection Date Comments:, Skip Periods each pump, the design criterion (or For chosen to monitor) and parameter explanation of that criterion. an Comments: of pump of Service Type Initials of inspector 10

16 the total number of components in each category and calculate the Determine cent leakers in per category. each the total number of regulated components in each group (i.e., valves, Calculate pump etc.) flanges, Valves Flanges "leakers" and "skip periods" being met? addressing Valves Connectors "Difficult-to-monitor" Review of Source Fugitive VOC Monitoring Equipment Records Examine the source logbooks associated with the fugitive V0C monitors. the source maintain logbooks for monitoring equipment? Does the logbooks contain the following information: Do name Operator ID number Monitor of calibration gases Identification of applicable response factors (RFs) List precision data results Calibration time data results Response of the logs may also reveal noncompliance due to improper Examination inadequate recording or Facilities are in direct noncompliance under the following situations: procedures. frame Failure to develop a schedule to observe visual emissions from flares (benzene Failure to record periods when the control device is not operating (benzene NESHAP) Calculation of Leakers Pumps Connectors Calculate the total number of"leakers" in each group. Are the regulations Flanges Pumps "Unsafe-to-monitor" Records Review Summary, Failure to report leaks and dates of repair Failure to report the reason for delaying repair of leaks past allotted time an 11

17 records leak testing and repair data Facilities logs but fails to report information in semiannual reports in records periods of noncompliance for Facility and vent systems but only control results of annual emission tests. reports in-plant logs and records should be The for inconsistencies with the information examined to the regulatory agencies in the initial presented semiannual.reports. Some typical and inconsistencies are as follows: reporting is Following list of questions the inspector should be a to answer at the conclusion of the record inspection: able Are in-plant records being properly kept and semiannual reports being properly are submitted? Is the equipment in the facility that should be subject the standard being treated to such? as When detected leaks not repaired in the required time frame, are the delays justifiable in accordance with the are provisions? COMMENTS 12

18 blueprints corr, espond with site area? Plant components identified properly and documented Regulated blueprints? on detection performed by facility personnel at random selected components Leak according to Federal Reference Method 2.17 perfomed "hissing" sounds at regulated components? Any and "unsafe-to-monitor" equipment properly labeled and "Difficult-to-monitor" in the records? identified check the following components based upon the records review (Level 2): Spot devices (verify compliance) Exempt are being used as a control device, inspect for "no visible emissions" flares as determined by Federal Reference Method 22. the "walk-through" inspection has been completed; the inspector should conduct Once exit an The exit interview serves to summarize the findings of the inspection (Level and 2). interview. During the exit interview, the following topics should be covered: of Inspection Data Review of Findings Summary of Findings Discussion of Confidential Business Information Declaration 2.3 WALK-THROUGH INSPECTION The walk-through inspection should be performed with the plant personnel. Select an area that been previously inspected and observe the hasn't using their own fugitive VOC leak source monitor to evaluate.various pieces of regulated equipment. During the walk-through, detection note the following: visual leaks associated with observed pumps? Any smells or odors in regulated area? Unusual leaking components Recently detectable emissions" components "No 2.4 LEVEL 2 EXIT INTERVIEW Additional Informational Needs Comments 13

19 3.0 LEVEL 3 CHF, CKLIST tfilgld SCREENING) Instrument Type: 1. Manufacturer and Model: 2. Serial Number: 3. Calibration Gas: 4. Instrument Lower Limit of Detection (ppmv):. 5. Saturation Point of Instrument Without Dilution Probe: 6. Was a dilution probe used? Yes No 7. Can instrument scale read +/- 5% of leak definitions? 8. No Yes 9. Does instrument include a pump capable of ½ to 1/3 of 1 L/rain? Yes No Has response factors (RFs) for the instrument been determined? 1. No 2. Are the Yes factor < 10? Yes..No response Report response factor: 3. Has a response time(rt) test been performed 4. No Yes Is the response time </= 30 Seconds? Yes No 5. Report response time: 6. Have there been any changes to the sample pumping 7. or flow configuration since the system time test? Yes No response Has a calibration precision test been co--mpleted? 8. No Yes Report date of last calibration precision 9. test: 10. Is calibration precision </= 10 % of calibration gas value? Yes No Is a zero gas used 1. a first step in calibrating the detector? Yes No as For calibration gas: 2. -Has it been certified by the manufacturer to be +/- 2 shelf life? -Reported Are the standards re-analyzed 3. replaced after shelf life? or 3.1 BACKGROUND INFORMATION Company Address Number Telephone Name Tester 3.2 INSTRUMENT INFORMATION 3.3 INSTRUMENT PERFORMANCE General Information Calibration Gas % accurate? 14

20 of cylinder standards: Manufacturer Is the mixture accurate to within +/- 2 %? Yes No A. B. Are the standards replaced each day of use? Yes No Assemble and start-up VOC analyzer. 1. Allow the instrument to warm-up. 2. Zero internal calibration procedure. 3. Introduce calibration gas into sample probe. 4. Response Factor Calibrate with reference compound. 1. Obtain/prepare known standard of the organic species to be measured. 2. Introduce standard to analyzer/record observed meter reading.. 3. Introduce zero air until a stable reading is obtained.. 4. Repeat 3 and 4 twice more to obtain three measurements. 5. Calculate 3 individual and 1 average response factors. 6. Was a published response factor used? Yes No 7. Calibration Precision Make three measurements by alternately using 1. gas and zero Calculate calibration algebraic difference between meter reading 3. known value. and Response Time Introduce zero gas into sample probe. 1. When meter has stabilized, switch quickly to specified calibration gases.. 2. Measure time from switching to 90 % of final stable reading.. 3. Repeat twice more. 4. Calculate average response time GENERAL GUIDELINES FOR SYSTEM OPERATION USING A PID ANALYZER Assembly/Startup Install probe assembly. 1. Test power (battery) level. 2. Turn on electronics and very lamp operation Calibration Procedure Checklist 5. Adjust meter readout to correspond to calibration gas value Instrument Evaluation Procedures calibration gas. specified Record meter reading Calculate calibration precision (%). 4. Leak-check sample line. 15

21 Set electronic zero-and alarm levels (if applicable).. 5. Set zero using background (<10 6. VOC) air. ppm Calibrate using reference, 7. other suitable calibration compound at or concen- tration a 80% of the leak detection defmition. approximately Fugitive Leak Detection Inspection of Regulated Components Placement of Probe,3, Place sample probe at 1. to be measured and perform fugitive leak inspection source an on source (as described in Method 21)" and record results "individual Field Test Data Sheet (mds). on Following is 2. brief description on how to locate the probe for individual a to record maximum leak components rates. move the probe around the periphery of the packing Also, addition, the valve housing of multi-part assemblies In should be screened at all points where leaks could occur. Place the probe at the outer edge of the flange-gasket Connectors: and sample the circumference interface the flange. It may be impossible to get of the flange- to leak because the probe cannot get between the gasket flange edges. interface these two the only alternative is to get close In as physically possible cases, the as to For threaded connectors, the threaded connector interface must be Record the maximum value as the screening value. Compressors, and Agitators: Pumps, Pumps, and agitators are compressors, where the shaft exits the housing. Sample along the circumference screened of shaft-seal interface by holding the probe the close to the shaft as possible as a piece of Tygon tubing to the end of the probe (attach prevent accidental to If the housing of the pump, or agitator prevents sampling all the way.around the seal, sample all compressor, portions. All other joints accessible the pump, compressor, or agitator housing on screening value. Record the maximum reading as the Relief Valves: Because of their design and function, Pressure relief valves pressure be approached with extreme caution and should not be tested in must times of process upsets or any other time when activation seems likely. an enclosed extension, with horn, place the probe inlet at approximately the or of the exhaust area. Only the probe tip should be placed in the horn. Ira center hole" is accessible, test at that location also. Record the maximum reading "weep the screening value. as 3.3.._.2 Place the probe Valves: close as possible to where the stem exits the packing as and move the probe around the circumference. The gland reading is maximum the screening value. gland take-up flange seat. Record the maximum value as the screening value. interface. screened. damage to the rotating shaft and instrument probe). that could leak should also be sampled. For devices 16

22 Lines and Vents: Emissions from most other components leak Open-ended regularly shaped openings. If the opening is less than 1 inch in diameter, through diameter), screen in the center of the hole and.around the hole. Periodically recheck zero setting using background (zero) air. 3. Avoid direct measurement of obvious leaks to avoid gross contamination 4. the instrument. of Periodically check battery level and visually lamp operation. 5. Perform a single point calibration of the fugitive VOC analyzer every three (3) hours of 6. The single point cheek should be within +/- 10 % operation. a full multipoint calibration or be performed and the data collected between the last good calibration and this must must be suspect. calibrations 7. Check ambient background readings every 3-hours and record on the FTDS. Shutdown of Fugitive VOC Analyzer Place instrument in a standby position. 1. Routine Maintenance Charge or replace batteries. 1. Replace/clean particle filter. 2. Replace charcoal filter (dilution system). 3. Quali.tyControl/Performance Verification Procedures Check background (zero) air reading several times each day and after each high level 1. measurement. Check calibration daily using calibration compound at level 2. the leak detection near definition. Check air flow daily (observing instrument flow meter) and whenever any maintenance is 3. ) before performing measurements, Literature values may be used, but compound not recommended because of differences between instruments. are Check calibration precision for three replicate determinations every three months 6. each use, whichever is longer. or Check response time before performing leak detection measurements and whenever 7. are made in the air flow, detector, changes electronic portions of the instrument. or a single reading in the center is sufficient. For larger openings (up to 6 inches in Components than 6 inches, screen across the opening every 3 inches. Record the greater value as the screening value. maximum 2. Shut off electronics. Replace/clean lamp cell window. 4. Replace lamp Leak-check sample flow system. on the sample flow system. performed Leak-check air flow system daily (less frequently if 4. problems are observed no historically). Check instrument response factor for regulated compound (relative to reference 5. 17

23 closing conference is held with the facility The at the conclusion of the record and leak screening inspections. personnel conference is mainly designed The answer questions the facility to may identify confidential information, have, obtain last minute details and information and order to complete the mandatory inspection in The impector should keep the closing report. weaknesses and strengths within the identify Remember, determination of compliance should be program. aider leaving the facility and made have an opportunity to review you opportunity to make confidentiality claims on documents collected by the inspector. such as technical guidelines, referring questions resources concerns to other personnel, and discussing problems and possible solutions will indicate and the facility a professionalism that will to reflect favorably on the inspector and the regulatory agency. 4.0.CLOSING CONFERENCE brief, refrai n from making compliance judgement and cover the following topics: conference Review of Inspection Data- Identify fill in any gaps in the data collected and clear up any inconsistencies conceming technical and so a determination of compliance data be made can a later date. at Summary of Findings- Review the adequacy of the LDAR program and established data. all Discussion/Evaluation of Source LDAR Program- any inspection-related Answer from the facility personnel but politely refrain question making on-the-spot judgements Concerning facility from or enforcement consequences. Provide compliance to recommendations facility on how they might/reprove their the based upon your review. program Declaration of Confidential Business Information- Facility should be given the officials It is the responsibility to inspector's all information claimed confidential and note the materials accordingly. handle Additional Information Needs- At this time, make for acquiring other data needs that arrangements not available during the inspection.. were a final note, it should be emphasized that it As the nspector is responsbthty to establish and maintain s working relationship with the facility. Offering a suggesting available or 18

24 REFERENCE METHOD 21 FEDERAL SURVEY LOG SHEET MONITOR Analyzer Serial No. Calibrated? LEAK DETECTION AND REPAIR Date Time Inspector 19

25 Environmental Protection Agency U.S. Pollution Training Institute Air Course #380 Fugitive Source Inspection SELF-AUDITING CHECKLIST

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27 LEVEL I FACILITY AUDIT 1.0 SOURCE IDENTIFICATION 1.1 Name Company Address Mailing "Environmental Manager CHECKLIST SELF-AUDITING FOR Applicability of Federal Equipment Leak Redatior Which Federal Equipment Leak Regulations applies to the affected facili.ly: Source Performance Standards New Subpart VV- SOCMI Equipment 40CFR60, Subpart GGG- Petroleum Refineries 40CFR60, Subpart KKK- Onshore Nalural Gas Processing Plants 40CFR60, 40CFR60, Subpart DDD- Polymer Manufacturing Indust- FUGITIVE VOC EMISSIONS Location of Facility Title Phone Personnel. Name -Facility Manager LDAR Facility Manager 1.2 PREPARATION FOR INSPECTION 2

28 Emission Standards for Hazardous Air Pollutants (NESHAP) National Subpart J- Benzene Equipment Leak 40CFR61, Subpart F- Vinyl Chloride 40CFR61, H- Leak Organic Hazardous Air Pollutant (HAP) Equipment 40CFR63,Subpart NESHAP Leak Subpart I- 40CFR63, Conservation and Recovery Act (RCRA) Resource Subpart BB- Air Emission Standards for Equipment Laks for TSDFs 40CFR264, Subpart BB- Air Emission Standards for Equipment Leaks for Interim 40CFR265, TSDFs Program of physical/operational changes to facility? Notification of compliance status? Notification Unit where equipment is located -Process by weight for regulated pollutant at the equipment -Percent fluid state at the equipment (gas/vapor, liquid, two phase fluid). -Process of compliance with the standard [e.g., monthly leak detection and repair -Method (LDAR), pump equipped with dual mechanical seals] program description of source LDAR program Brief for submitting semiannual reports Schedule diagram of regulated processes within the facility Engineering Organic HAP Equipment Leak NESHAP for Certain Processes Process Description and Verification Brief description of the facility's operation and design capacity. Identification of process unit(s) which fall under regulatory requirements emission control (e.g. flare, scrubber, incinerator etc) Primary that requirements of standard are being implemented Statement List of all subject equipment including: of equipment (e.g., valves, pumps, flanges etc.) -Type number of regulated equipment -Identification

29 copy of Obtain permit and compare to applicable regulations source copy of previous semi-annual Obtain report submitted -Report time? on signed by facility representative? -Report contains information associated with: -Report components monitored? -Total (by type) of components.leaked? -Number of components for which leaks -Number not properly repaired9 were -Identification of" non-repatrable detected -Date -Part leaking components? of repair -Delay reason unit shutdown technically -Why feasible not "no detectable emissions" equipment number with -Compare reports -% of total previous (by type) found leaking? components % leaking in records to reported results -Check listed repairs and equipment identification along With -Check requirements retest of construction -Identification replacement of equipment or all performance test conducted during the reporting -Review on all equipment period designed to meet the "skip period" and "no detectable emissions" Review the previous [NOTE: semiannual reports to spot checked against in-plant two data.] records the source maintain Does document listing: a list of ID numbers for "difficult-to-monitor" -A components? list ofld numbers for "unsafe-to-monitor" -A -A list ofld components? for skip periods components? numbers -A list of ID numbers for "no detectable emissions" components? Review of Source Leak Detection and Re air Pro ram DAR source specific leak detection and repair -Written (LDAR) submitted and maintained in program files for review and update? source statement by the management supporting -Clear LDAR program at the facility along the reference to applicable regulations? with LDAR document signed by Plant Manager, Environmental -Written and Maintenance and Production Manager Manager, applicable)? (if of applicable regulations and identifications -Outline components regulated under those of requirements? Semi-annual Report -Process unit identified? of leaks not repaired within 15 days? -Summary number -Tag

30 of responsibility and chain-of-authority for source LDAR program clearly -Identification in written LDAR source specific document? stated of monitoring equipment to be used in the source LDAR program, along. -Identification written procedures (SOPs) for operation, maintenance, and calibration of equipment in with with Federal Reference Method 21 specifications? accordance of plant procedures and proper recordkeeping performed within the source -Identification LDAR program. This information should including: (1) identification of who is specific for tagging leaking components; (2) who repairs leaking components; (3) who responsible the proper Work Orders; (4) who should retest the components once leaks are acquires (5) who updates maintenance records and schedules based upon number of repaired; components; and (5) who notifies management of completion of repairs and source leaking involved with the repair of the leaking components. personnel of data acquisition methods used in the LDAR program, example calculation -Identification "percent leaking components,'" and discussion on how semiannual reports will be of the plant have the following information pertaining to subject equipment in a permanent Does log? list of identification numbers for equipment subject to the standard: A Pumps Valves Relief Devices in Liquid Service, Flanges, and Other Connectors --Pressure Accumulator Vessels Product in Vacuum Service Equipment list of identification numbers for equipment designated to meet "no detectable A compliance option including the owner/operator's authorizing this designation: emissions" Valves Relief Valves Pressure dates of each "no detectable emissions" compliance test, including the background The measured during each test and the maximum instrument reading measured at the equipment level and verified. prepared Identificati6n of a Written source Quality Improvement Program (QIP)? Records Review Listing of Affected Equipment Compressors Relief Devices in Gas/Vapor Service Pressure Connection Systems Sample Ended Valves or Lines Open Flanges.Vent Systems Closed Pumps Compressors each test. during Pumps Compressors Valves

31 Relief Devices Pressure list of all valves which A designated "unsafe-to-monitor." are identification, number Valve why each valve is Explanation plan for monitoring each valve A per cent in category. Per Identify within regulatio Yes No cent list of all valves which A designated "difficult-to-monitor." are identification numbers Valve why each valve is difficult _Explanation monitor to plan for monitoring each valve A Identify per cent in category. Per cent within regnlations= es No Records of Fugitive VOC Emission Monitorin. the plant have the following information for Does (2) years regarding compliance testing of two equipment? regulated of regulated components ID of service _Type of equipment Location type Component leak values Measured background values tambient.review the data file for one monitoring route within the process unit. during the route for monitor technician and time stamps. Note monitoring counts Does the number of component counts reasonable for the time stamped. [Note: Federal Reference Method seem requires that ira leak is detected, then 21 must leave the monitor probe One the maximum reading for twice the at of components sniffed reasonable? Number stamp for monitoring components and between Time reasonable? components Records of Performance Test Data the plant have the following information for Does (2) years regarding performance test data two regulated components? of unsafe-to-monitor One [NOTE: two of these valves should be field inspected or veri that they to indeed "unsafe or difficult to monitor".] are Comments: 1_ response time of the monitoring system.]

32 of regulated components ID of service Type leak values Measured background values Ambient the plant have the following information in a two year log regarding leaks located on Does compressors, valves, flanges, and other connectors? pumps, instrument and operator identification numbers and the equipment identification The number. date the leak was detected and the dates of each attempt to repair the leak. The methods applied in each attempt to repair the leaks. Repair of"above leak definition" if the maximum instrument reading measured by the Record specified in the CFR after each attempt is equal to or greater than. the leak detection methods of"repair delayed" and the reason for the delay if a leak is not repaired within 15 Record days after discovery of the leak. calendar signature of the owner or operator (or designated) whose decision it was that repair The not be effected without a process shutdown. could expected date of successful repair of the leak if a leak is not repaired within 15 The days after discovery of the leak. calendar valves complying with the "skip period leak detection and repair" compliance option, does For plant have a permanent log containing: the schedule for monitoring A percent of valves found leaking during each monitoring period The and compressors that are equipped with a dual mechanical seal system must have sensors Pumps detect failure of the seal system, the barrier fluid system, or both. The following information to shouldbe in a permanent log regarding these types of pumps and compressors: of equipment Location type Component Leak Loe Records limit. The date of successful repair of the leak. Comments: Skip Periods Log Records Example of calculation for determining present skip period

33 each compressor, the design criterion (or parameter chosen For monitor) and an to of that criterion. explanation Any changes to this criterion and the reasons for the changes. the plant have the following information for two (2) Does regarding compliance with years visual inspection of regulated pumps? weekly of pump ID of Service Type of pump Location of inspection.date the total number of Components in each category and calculate the Determine cent leakers in each per category. the total number of regulated components in each Calculate (i.e., valves, flanges, group etc.) pump Valves Flanges Calculate the total number of"leakers" in each group. Connectors per cent leakers in each category. Calculate Valves._.Flanges each pump, the design criterion (or parameter chosen to monitor) and For explanation an that criterion. of Comments: Records of Visual Inspection of Pumps Initials of inspector 1.2.5'7 Calculation of Leakers PumPS Connectors Are the regulations "leakers" and "skip periods" being met? Yes No addressing Valves Flanges Pumps Pumps Connectors

34 name Operator ID number Monitor of calibration gases Identification of applicable response factors (RFs) List precision data results Calibration time data results Response of the logs may also reveal noncompliance.due to improper Examination inadequate recording or Facilities are in direct noncompliance under the following situations: procedures. Failure to report leaks and dates of repair Failure to report the reason for delaying repair of leaks past an allotted time frame Failure to develop a schedule to observe visual emissions from flares (benzene NESHAP) Failure to record periods when the control.device isnot.operating (benzene the in-plant logs and records for inconsistencies with the information presented to the Review agencies in the initial and semiannual reports. Some typical reporting inconsistencies regulatory Are in-plant records being properly kept and are semiannual reports being submitted? properly When detected leaks are not repaired in the required time frame, are the delays in accordance with the provisions? justifiable Review of Source Fugitive VOC Monitoring Equipment Records Examine the source logbooks associated with the fugitive VOC monitors. the source maintain logbooks for monitoring equipment? Does the logbooks contain the following information: Do Records Review Summary NESHAP) are as follows: Facilities records leak testing and repair data in logs, but fails to report in semiannual reports information Facility records periods of noncompliance forcontrol and vent systems but reports results of annual emission tests. only is a list of questions the auditor should be able to answer at the conclusion of the Following inspection: record Is the equipment in the facility that should be subject to the standard being as such? treated

35 2.1 WALK-THROUGH AUDIT AND OBSERVATION OF VOC SNIFFINC The walk-through audit should be performed with the plant personnel. blueprints correspond with site area? Plant components identified properly and documented Regulated blueprints? on visual leaks associated with observed pumps? Any smells Unusual odors in regulated area? or detection performed by.facility personnel Leak random selected components at according to Federal Reference Method 21? perfomed "hissing" sounds at regulated components? Any and "unsafe-to-monitor" equipment properly labeled "Difficult-to-monitor" and in the records? identified check the following components based Spot the records review (Level 2): upon COMMENTS 2.0 LEVEL 2 FACII,ITY.AUDIT Select an area that hasn't previously inspected and observe the been personnel using their own fugitive VOC leak source monitor to evaluate various pieces of regulated equipment. During detection walk-through, the note the following:

36 2.2.1 O and Model: Manufacturer Number: Serial Gas: Calibration Lower Limit of Detection (ppmv): Instrument Point of Instrument Without Dilution Probe: Saturation a dilution probe used? Yes No Will General Information response factors (RFs) for the instrument been determined? Yes No Has response factors: Record a response time (RT) test been performed Yes Has response time (Seconds): Record there been any changes to the sample pumping system orflow configuration Has date/time of last calibration precision test: Report calibration precision </= 10 % of calibration gas value? Yes Is Calibration Gas (Zero and Span Gases) For zero and span calibration gas: been certified by the manufacturer to be +/- 2 % accurate? -Havethey is the reported shelf life? -What the calibration gases within self-life date? Yes No -Are is the calibration gas (Methane, propane, hexane ) -What gas concentration approximately equal to the leak definition concentration? -Calibration No Yes zero gas has < 10 ppm VOCs Yes No -Certified Are the calibration standards re-analyzed or replaced after shelf life? Observe Facility Calibration Check Procedure Assemble and start-up VOC analyzer. leaking components Recently detectable emissions" components "No devices (verify compliance) Exempt flares are being used as a control device, inspect for "no visible If emissions" as determined by Federal Reference Method OBSERVING SOURCE PERFORMING LDAR SNIFFING WITH VOC ANALYZER VOC INSTRUMENT INFORMATION PLANT Type: Instrument D O O No Can instrument scale read +/- 5% of leak definitions? Yes O Does instrument include a pump capable of 0.10 to 3.0 L/min? Yes No Instrument Performance Are the response factors < 10? Yes No No Is the response time </= 30 seconds? Yes No since the response time test? Yes No Has a calibration precision test been completed? Yes No No 11

37 the instrument to warm-up for 15 minutes: Allow Observe contractor leak check analyzer. Leak? Yes No Observe facility operator has checked flow through tip of analyzer. Flow between rate L/rain? Yes No zero gas at the entrance of the probe Introduce allow the instrument to stabilize until and constant reading is obtained. Adjust a zero reading. to introduce calibration Now into the entrance of the probe and allow the instrument gas stabilize until to constant reading is obtained. Adjust a calibration gas value. to Record digital display/meter reading for each and calibration gas on Calibration Data zero (CDF)_ Form calibration algebraic difference between digital display/meter Calculate and known value. reading calibration precision (%).. Calculate precision should be Calibration 10% of the calibration gas value. < Factor (If Aoolieable) Response with reference compound Calibrate concentration of 80% of applicable leak at standard known standard of organics Obtain/prep be measured. to standard to analyzer. Record observed digital/meter Introduce reading. zero air until Introduce stable reading is obtained. a twice Repeat to obtain three measurements. more three (3) individual and Calculate (1) average response factors. one response factor Calculated 10? Yes No < Response Tirng Introduce zero gas into instrument probe. t When meter has stabilized, switch quickly specified calibration gases (80% of to leak standard)_ applicable Audit Gas Challenge Obtain Exxon_Mobil plant specific audit cylinder containing 500 gas ppm. Now introduce ExxonMobil calibration (500 ppm methane) into the entrance of the probe.and gas the instrument to stabilize until allow constant reading is obtained. a Record digital display/meter reading for each and calibration gas on Calibration Data zero (CDF) Form t D n Make three additional measurements by alternately-using gas and specified calibration zero gas. Yes.._No Was a published response factor used' Yes N Measure time from switching from gas to 90 % of final stable reading. zero Repeat twice more. Calculate average response time. Calculated response time equal to less than 30 seconds? Yes.. No or Introduce ExxonMobil zero at the entrance of the probe and allow the instrument gas stabilize until to constant reading is obtained. a Make two additional measurements by alternately using gas and specified calibration zero gas. 12

38 calibration algebraic difference between digital display/meter reading Calculate known value. and Calculate calibration precision (%). Calibration precision should be < 10% of the calibration gas value. Yes No Assembly/Start-up Observe facility personnel install probe: made of stainless steel? -Probe extension ( 2 inches) applied to probe tip? -Teflon of probe measured to meet specifications of not to exceed ¼ inch OD? -Tip Observe facility personnel verify power (battery) level. o Observe facility personnel turn on electronics and very operation of detector (i.e., lamp or FID). Observe facility personnel leak-check system from entrance of probe Observe facility personnel verify flow through VOC analyzer is between L/rnin Observe facility personnel set electronic zero and alarm levels (if applicable). Observe Background Concentration Verify background concentration acquired and recorded on Audit Field Test Data Sheet (ATDS). Update AFTDS with observed values every three (3) hours Scheduled Route Verify that facility operator has correct scheduled ronte identified in software of analyzer plotted on route map, or Placement of Probe leak inspection on an "individual source (as described below)" and record results on fugitive AFTDS. Observe that probe is placed at the source for "two times" the observed instrument time before final concentration is recorded by the instrument. response Following is a brief description of proper probe location for individual regulated.in determining maximum leak rate. components Place the probe as close as possibl e to where the stem exits the packing gland Valves: move the probe around the circumference. The maximum reading is the and flange seat. up at all points where leaks could occur. screened screening value on the AFTDS Observe Startup and Operation of Facility VOC Analyzer a Observe Facility Personnel Performing Fugitive Leak Detection Inspection o Observe that the facility operator places probe at source to be measured and perform screening value. Leave the probe at this location for twice the observed response time of the analyzer. Move the probe around the periphery of the packing gland take- In addition, the valve housing of multi-part assemblies should be Record the maximum value as the 13

39 Place the probe at the edge of the flange-gasket interface Connectors: sample the circumference of and flange. It may be impossible the get to the flange-gasket leak to because the probe interface get between the two flange edges. cannot only alternative is to get the close as physically possible to the interface. as threaded connectors, the threaded connector interface must be screened. Pumps, Compressors, and Agitators: In these cases, compressors, and agitators Pumps, are along the circumference of the Sample interface by holding the probe shaft-seal close to the shall as possible (attach as piece of Tygon tubing a the end of the probe to prevent accidental damage to the to If the housing of the pump, compressor, or prevents sampling all the agitator around theseal, sample all accessible portions way other joints All the pump, compressor, or agitator housing that on leak should could be sampled..once again, when also maximum reading is a leave the probe at that position for twice value), response time. the maximum value as the screening value on the AFTDS. Relief Valves: Because of their design and function, Pressure relief valves must be approached with pressure caution and should not be tested in times of extreme process upsets or any other time when activation seems likely. For devices with an enclosed or horn, place the probe inlet atapproximately extension, center of the exhaust the Only the probe tip should be placed in the horn. Ira "weep hole" area. accessible, is at that location also. Once again, when test maximum reading is a value), leave the probe (screening that position for twice the.response time. at the maximum value as the screening value on the AFTDS. Lines and Vents: Emissions from Open-ended other components leak through most shaped openings. If the opening is less than 1 inch in diameter, regularly single a larger openings (up to 6 inches in diameter), For in the center of the hole and around the hole. Components screen than 6 greater reading in the center is sufficient. inches. Once again, when a maximum (screening value), leave the probe observed that position for twice the at the maximum value Record the screening value on the AFTDS. as Ooeration of VOC Analyzer bservinl Periodically observe that the facility n rechecks zero setting using background operator air. (zero) Insure facility operator avoids direct n of obvious leaks to avoid gross measurement of the instrument. contamination Periodically have facility operator check battery level o operation of and analyzer every three (3) hours of operation. The single point check should be within +/- 10 For Once again, a maximum reading is observed (screening value), when the probe at that position leave twice the response time. Record the maximum for as the screening value value on the AFTDS. screened where the shaft exits the housing. rotating shaft and instrument probe). observed (screening Record the observed Record inches, screen across the opening every 3 reading is response time. detector Observe the facility operator perform single point calibration of the fugitive VOC a 14