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United States

Office of Enforcement EPA 300-N-99-014


Environmental Protection and Compliance

Agency Assurance (2201A)

Volume 2, Number 9
Enforcement Alert
Office of Regulatory Enforcement October 1999

Proper Monitoring Essential to Reducing Fugitive


Emissions Under Leak Detection and Repair Programs
ducted by the U.S. Environmental

T he Clean Air Act requires


refineries to develop and imple
ment a Leak Detection and Repair
Protection Agencys (EPA) National

Enforcement Investigations Center

What the Law Requires


Specific requirements for refinery

fugitive emissions are identified in 40

(LDAR) program to control fugitive (NEIC) shows that the number of

CFR Part 60, New Source Perfor

emissions. Fugitive emissions occur leaking valves and components is up

mance Standards (NSPS), and 40

from valves, pumps, compressors, to 10 times greater than had been re-

CFR Parts 61 and 63,

pressure relief valves, flanges, con ported by certain re-

National Emission

nectors and other piping components. fineries (see Table,

Standards for Hazard

Comparison monitoring con Page 2). EPA believes

E
ous Air Pollutants

this great disparity be- PA estimates (NESHAP). Many

tween what refineries


are reporting and what that leaks not State and local air
About EPA is finding may be
agencies incorporate
Enforcement Alert attributable to refiner
found and federal requirements
but some have estab
Enforcement Alert is
ies not monitoring in repaired could be
lished more stringent
published periodically by the the manner prescribed
requirements as au
Office of Regulatory in 40 CFR Part 60, resulting in additional
Enforcement to inform and thorized by law. The
Appendix A, Method
educate the public and regulated
21. volatile organic various regulations re-
community of important quire refineries to
environmental enforcement Federal regulations chemical emissions implement an LDAR
issues, recent trends and require refiners to rou
significant enforcement actions.
program to reduce fu
tinely monitor for leaks of 80 million pounds gitive emissions from
This information should help the and to fix any equip valves, pumps, com
regulated community anticipate ment found leaking. annually. pressors, pressure re-
and prevent violations of federal Failure to identify lief valves, flanges,
environmental law that could leaking equipment re
otherwise lead to enforcement connectors, and other
action. Reproduction and wide
sults in necessary repairs not being piping components.
dissemination of this newsletter made and continuing fugitive emis
Valves are usually the single larg
is encouraged. sions of volatile organic chemicals
est source of fugitive emissions. Emis
(VOCs) and other hazardous chemi
See Page 4 for useful EPA sions from any single piece of equip
cals. EPA estimates that the failure
Websites and additional ment are usually small. Based on the
resources. to identify and repair leaks at petro
large number of equipment compo
leum refineries could be resulting in
Eric V. Schaeffer
nents that can leak and are subject to
additional VOC emissions of 80 mil-
Director, Office of LDAR requirements, however, cumu
Regulatory Enforcement
lion pounds annually. VOCs contrib
lative emissions can be very large. To
ute to ground-level ozone, a principal
Editor: Virginia Bueno obtain a proper reading of emissions
component of smog, which can cause
(202) 564-8684 from leaking components the monitor
bueno.virginia@epamail.epa.gov significant health and environmental
ing equipment must be calibrated cor
(Please email all address and problems.
name changes or subscription
requests for this newsletter.) Continued on page 2

This publication is found on the Internet at http://www.epa.gov/oeca/ore/enfalert


Enforcement Alert
Continued from
page 1 Comparative Monitoring Results
Emissions Potential
rectly and held at the Company NEIC Leak Rate: Rate: Emissions:
component interface Monitoring: Monitoring: Company/ Company/ Undetected
Refinery Valves/Leaks Valves/Leaks NEIC (%) NEIC (lb/hr) Leaks (lb/hr)
where leakage could oc
cur (e.g., at the seal be-
tween the valve stem
A 7,694/170 3,363/354 2.3/10.5 38.8/106.6 67.8
and housing) for a suffi
cient length of time to B 7,879/223 3,407/216 2.8/6.3 44.0/73.5 29.5
obtain a valid measure C 3,913/22 2,008/108 0.6/5.4 18.3/90.1 71.8
ment. D 2,229/26 1,784/24 1.2/1.4 15.5/17.1 1.6
E 5,555/96 2,109/112 0.7/5.3 50.7/125.8 75.1
LDAR Programs
F 42,505/124 3,053/53 0.3/1.7 154.7/382.3 227.6
Should Consist of
G 14,307/226 3,852/236 1.6/6.1 122.2/369.7 247.5
Several
H 20,719/736 3,351/179 3.6/5.3 332.2/469.7 137.5
Processes
I 5,339/9 2,754/84 0.2/3.1 16.9/76.6 59.7
LDAR programs are
generally comprised of J 8,374/78 2,981/55 0.9/1.8 50.8/78.5 27.7
four processes. Regula K 6,997/101 1,658/114 1.4/6.9 56.1/201.2 145.1
tions vary but usually L 12,686/26 3,228/125 0.2/3.8 34.9/84.0 49.1
require refineries to:
M 4,160/40 1,926/222 1.0/11.5 25.7/192.2 166.5
Identify compo N 5,944/29 2,487/106 0.5/4.3 26.1/112.3 86.2
nents to be included in
O 7,181/112 2,897/130 1.6/4.5 60.8/140.9 80.1
the program;
P 8,532/203 4,060/181 2.4/4.5 98.8/167.5 68.7
Conduct routine
monitoring of identified Q 6,640/36 2,608/74 0.5/2.8 30.5/87.5 57.0
components;
Repair any leak Total 170,717/2,266 47,526/2,372 1.3/5.0 (avg) 1,177.0/ 1,598.5
ing components; and 2,775.5
Report monitor
ing results.
Failure to repair components 1.3 percent. The average leak rate de
Compliance issues associated with within specified timeframes; and termined by NEIC and confirmed by
each of these processes have resulted the facilities was 5.0 percent. One ex-
in numerous enforcement actions by Failure to submit quarterly re-
planation for this difference in leak
EPA Regional offices, State agencies, ports and maintain appropriate cali
rates may be found in a report pub
or local air boards, depending on the bration and/or monitoring records.
lished by the Bay Area Air Quality
specific regulations. Common viola Management District (Rule Effec
tions include: Refinery Monitoring tiveness Study). The Bay Area Air
Failure to identify process Reports; What EPA is Quality Management District deter-
units and components that must be Finding mined that when valves were in
monitored; During the past several years, spected at a distance of one centime
ter (0.4 inches) from the component
Failure to follow prescribed NEIC has monitored for leaking com
ponents at refineries. For 17 facilities instead of at the interface with the
monitoring procedures;
investigated by NEIC, the average component, as the regulations require,
Use of incorrect or expired
leak rate reported by the facilities was Continued on page 3
calibration gasses;
OCTOBER 1999 2
Enforcement Alert
Continued from page 2 being emitted each year because re- Improving Leak Detection
finery leaks are not being identified Monitoring Reliability
57 percent of the leaking valves would properly and repaired promptly, as re
Although not required under cur-
be missed when monitoring above the quired by LDAR programs. Signifi
rent LDAR programs, several prac
500 ppm level. cantly and as recognized by industry,
tices appear to improve the reliability
Fugitive emissions account for 22 fugitive emissions can be reduced by
of monitoring data and LDAR com
percent of all emissions from non-re- up to 90 percent if leaks are detected
pliance:
fineries but account for more than 55 and repaired in a timely manner.
Energetic LDAR coordina
percent of all refinery emissions iden
Regulatory Impacts of tors (advocates) with the responsibil
tified in the 1996 Toxic Release In
ity and authority to make things hap-
ventory (TRI). Since TRI includes Inadequate Fugitive
pen;
only reportable hydrocarbons, total Monitoring
fugitive emissions were significantly Continuing education/re-
By not fully identifying all leaking fresher programs for plant operators.
larger than the 33 million pounds then
components, refineries are likely caus Plant operators can have a major im
identified by reporting refineries.
ing the unnecessary release of excess pact on LDAR compliance;
The failure to identify leaks means hydrocarbons. The impacts of these
that they remain unrepaired and will additional hydrocarbon releases may Diligent and well-motivated
continue to release VOCs and hazard result in: monitoring personnel;
ous substances into the atmosphere. Use of a lower than required
Additional VOC emissions
Emission estimates using a 50/50 split leak definition. Several refineries use
between components in gas/light liq that could worsen local or
transboundry smog problems; a leak definition lower than the regu
uid service (see Table, Page 2) sug latory limit. For example, several re-
gest that these 17 refineries annual Under reporting of fugitive fineries use a 500 ppm limit rather than
fugitive emissions could be more than emissions on the annual Toxic Report the regulatory limit of 10,000 ppm;
6,000 tons per year greater than pre ing Inventory;
viously believed. Extrapolating this dif More frequent monitoring
Under reporting of various than required. Rather than monitor
ference to all refineries larger than the
smallest refinery investigated by NEIC TRI chemicals on annual Form R sub- ing annually, some refineries monitor
also suggests that there may be an missions; and quarterly. More frequent monitoring
also may permit lower emissions to
additional 80 million pounds of VOCs Delayed or denied permits for
be reported on the annual Toxic Re-
expansion. porting Inventory and/or Form Rs; and
Most LDAR regulations allow for Established Quality Assur
EPA Policies for decreased monitoring frequency if cer
Reducing, Eliminating ance/Quality Control procedures. Sev
tain performance standards are con
eral refineries have initiated a program
Penalties for sistently achieved. Monitoring fre
to check the monitoring results sub
Self-Policing quency is decreased from quarterly to
mitted by the monitoring team (in-
annual monitoring if less than two per-
EPA has adopted two policies house or contractor).
cent of the valves within a process
designed to encourage the regu EPAs Office of Enforcement and
unit are found leaking. Conversely, if
lated community to comply with Compliance Assurance is encouraged
greater than two percent of the valves
environmental laws. by efforts currently underway by the
are found to be leaking, monitoring
For more information, see must be conducted quarterly. EPA National Advisory Committee on En
EPAs Audit Policy Website at: monitoring showing a greater than two vironmental Policy and Technology
h t t p : / / w w w. e p a . g o v / o e c a / percent leak rate has resulted in re- (NACEPT) petroluem refining
auditpol.html, and the Small Busi fineries reverting back to quarterly workgroup to find more cost-effec
ness Policy at: http:// monitoring. tive ways to identify significant leaks
www.epa.gov/oeca/smbusi.html.
Continued on page 4
OCTOBER 1999 3
EnforcementAlert
United States
Environmental Protection Agency
Office of Regulatory Enforcement
2248A
Washington, D.C. 20460

Official Business
Penalty for Private Use $300

Continued from page 3 designed to encourage the expeditious


testing of computer associated hard- Useful Websites
ware and software that may be poten-
through new technology that allows tially vulnerable to Y2K problems. EPA's Technical Web site for
Information Transfer and Sharing
for quick identification of the most sig- Under this policy, which was pub- Related to Air Pollution Topics:
nificant losses. Meanwhile, however, lished in the Federal Register on March http://www.epa.gov/ttn/
the regulated industry is expected to 10, 1999, EPA intends to waive 100 Toxics Release Inventory (TRI):
comply fully with existing LDAR re- percent of the civil penalties and rec- http://www.epa.gov/opptintr/tri/
quirements. ommend against criminal prosecution
EPA Home Page:
Contact Ken Garing, National for environmental violations resulting http://www.epa.gov/epahome
Enforcement Investigations Cen- from Y2K testing designed to identify
and eliminate Y2K-related malfunctions. National Enforcement Investigations
ter, (303)236-6658;Email: Center:
garing.ken@epa.gov; Tom Ripp, To receive the policys benefits (e.g., http://www.epa.gov/oeca/oceft/neic/
Office of Compliance, Manufac- waiver of penalties due to testing), regu- index.html
lated entities must address specific cri-
turing, Energy and Transportation EPCRA Hotline: 1-800-424-9346. For
teria and conditions identified in the
Division, (202564-7003;Email: callers in the DC area, please call
policy. (703) 412-9810. Also, the TDD is (800)
ripp.tom@epamail.epa.gov; or Jim 553-7672.
Jackson, Office of Regulatory En- For more about the Y2K
forcement, Air Enforcement Divi- Enforcement Policy, contact Gary Office of Regulatory Enforcement
Jonesi, Office of Regulatory http://www.EPA.gov/oeca/ore.html
sion, (202) 564-2002;Email:
jackson.james@epamail.epa.gov. Enforcement, (202) 564-4002 or E-
EPA Compliance Assistance
mail: jonesi.gary@epa.gov. Centers: http://www.epa.gov/
oeca/mfcac.html
EPAS Y2K Enforcement
Policy Small Business Gateway:
http://www.epa/gov/smallbusiness
EPAs Y2K Enforcement Policy is

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