Chemical Engineering May 2014 - 48

Cover Story
Table 2 - fedeRal RegulaTions ThaT RequiRe a foRmal ldaR
PRogRam WiTh meThod 21
40 CfR
Due to the variability in the sensitivity
of the different monitoring
devices, the screening value does
not necessarily indicate the actual
total concentration at the leak interface
of the compound(s) being
detected. The leak interface is the
immediate vicinity of the joint
being tested - the point at which
the end of the probe is placed. Response
factors (RFs), determined
for each compound by testing or
taken from reference sources, then
correlate the actual concentration
of a compound to that of the concentration
detected by the monitoring
device. As mentioned previously,
the monitoring device must
first be calibrated using a certified
reference gas containing a known
compound at a known concentration,
such as that of methane and
isobutylene. RFs at an actual concentration
of 10,000 ppmv have
been published by the EPA in a
document entitled " Response Factors
of VOC Analyzers Calibrated
with Methane for Selected Organic
Chemicals. "
Method 21 requires that any selected
detector meet the following
specifications:
* The VOC detector should respond
to those organic compounds being
processed (determined by the RF)
* Both the linear response range
and the measurable range of the
instrument for the VOC to be
measured and the calibration gas
must encompass the leak definition
concentration specified in the
regulation
* The scale of the analyzer meter
must be readable to ±2.5% of
the specified leak definition
concentration
* The analyzer must be equipped
with an electrically driven pump
so that a continuous sample is
provided at a nominal flowrate of
between 0.1 and 3.0 L/min
* The analyzer must be intrinsically
safe for operation in explosive
atmospheres
* The analyzer must be equipped
with a probe or probe extension
not to exceed 0.25 in. outside diameter
with a single end opening
for sampling
Part subpart
60 VV
Regulation Title
SOCMI VOC Equipment Leaks NSPS
60 DDD Volatile Organic Compound (VOC) Emissions from the Polymer
Manufacturing Industry
60 GGG Petroleum Refinery VOC Equipment Leaks NSPS
60 KKK
61 J
61 V
63 H
63 I
63 J
63 R
Onshore Natural Gas Processing Plant VOC Equipment
Leaks NSPS
National Emission Standard for Equipment Leaks (Fugitive
Emission Sources) of Benzene
Equipment Leaks NESHAP
Organic HAP Equipment Leak NESHAP (HON)
Organic HAP Equipment Leak NESHAP for Certain Processes
Polyvinyl Chloride and Copolymers Production NESHAP
Gasoline Distribution Facilities (Bulk Gasoline Terminals and
Pipeline Breakout Stations)
63 CC Hazardous Air Pollutants from Petroleum Refineries
63 DD
63 SS
63 TT
63 UU
63 YY
Hazardous Air Pollutants from Off-Site Waste and Recovery
Operations
Closed Vent Systems, Control Devices, Recovery Devices
and Routing to a Fuel Gas System or a Process
Equipment Leaks - Control Level 1
Equipment Leaks - Control Level 2
Hazardous Air Pollutants for Source Categories: Generic
Maximum Achievable Control Technology Standards
63 GGG Pharmaceuticals Production
63 III
Hazardous Air Pollutants from Flexible Polyurethane Foam
Production
63 MMM Hazardous Air Pollutants for Pesticide Active Ingredient
Production
63 FFFF
Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
63 GGGGG Hazardous Air Pollutants: Site Remediation
63 HHHHH Hazardous Air Pollutants: Miscellaneous Coating Manufacturing
65
F
264 BB
265 BB
Consolidated Federal Air Rule - Equipment Leaks
Equipment Leaks for Hazardous Waste TSDFs
Equipment Leaks for Interim Status Hazardous Waste TSDFs
Federal regulations
There are federal regulations that
pertain to monitoring for VOCs
and require the implementation of
a formal LDAR program in concert
with the rules of Method 21. There
are other federal regulations that
require the rules of Method 21, but
do not require a formal LDAR program.
Tables 2 and 3 list those various
regulations.
It is the manufacturer's responsibility
to make the proper determination
as to what regulations it needs
to comply with. Those specific regulations,
coupled with the Method 21
requirements, will define the LDAR
48 ChemiCal engineering www.Che.Com may 2014
program and help establish a comprehensive
and detailed procedure.
RCRA
The Solid Waste Disposal Act of
1965 was amended in 1976 to include
the Resource Conservation
and Recovery Act (RCRA), which
encompassed the management of
both hazardous waste and solid
waste. Prompted further by an ever
increasing concern of underground
water contamination, this act was
again amended in 1984 to address
underground storage tanks (USTs)
and associated underground piping
under Subtitle I. This Amendment
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