Attachment 3

Attachment 4

TCEQ-(APDG 6308v2, Revised 09/15) BP-28LAER

Texas Commission on Environmental Quality Air Permits Division

New Source Review (NSR) Boilerplate Special Conditions

This information is maintained by the Chemical NSR Section and is subject to change. Last update was made September 2015. These special conditions represent current NSR boilerplate guidelines and are provided for informational purposes only. The special conditions for any permit or amendment are subject to change through TCEQ case-by-case evaluation procedures [30 TAC 116.111(a)]. Please contact the appropriate Chemical NSR Section management if there are questions related to the boilerplate guidelines.

Fugitives

28LAER Piping, Valves, Pumps, Agitators, and Compressors - Intensive Directed Maintenance - 28LAER

1. Except as may be provided for in the Special Conditions of this permit, the following requirements apply to the above-referenced equipment:

A. The requirements of paragraphs F and G shall not apply (1) where the VOC has an aggregate partial pressure or vapor pressure of less than 0.044 pounds per square inch, absolute (psia) at 68°F or (2) operating pressure is at least 5 kilopascals (0.725 psi) below ambient pressure. Equipment excluded from this condition shall be identified in a list or by one of the methods described below to be made readily available upon request.

The exempted components may be identified by one or more of the following methods:

(1) piping and instrumentation diagram (PID);

(2) a written or electronic database or electronic file;

(3) color coding;

(4) a form of weatherproof identification; or

(5) designation of exempted process unit boundaries.

B. Construction of new and reworked piping, valves, pump systems, and compressor systems shall conform to applicable American National Standards Institute (ANSI), American Petroleum Institute (API), American Society of Mechanical Engineers (ASME), or equivalent codes.

C. New and reworked underground process pipelines shall contain no buried valves such that fugitive emission monitoring is rendered impractical. New and reworked buried connectors shall be welded.

D. To the extent that good engineering practice will permit, new and reworked valves and piping connections shall be so located to be reasonably accessible for leak-checking during plant operation. Difficult-to-monitor and unsafe-to-monitor valves, as defined by Title 30 Texas Administrative Code Chapter 115 (30 TAC Chapter 115), shall be identified in a list to be made readily available upon

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request. The difficult-to-monitor and unsafe-to-monitor valves may be identified by one or more of the methods described in subparagraph A above. If an unsafe to monitor component is not considered safe to monitor within a calendar year, then it shall be monitored as soon as possible during safe to monitor times. A difficult to monitor component for which quarterly monitoring is specified may instead be monitored annually.

E. New and reworked piping connections shall be welded or flanged. Screwed connections are permissible only on piping smaller than two-inch diameter. Gas or hydraulic testing of the new and reworked piping connections at no less than operating pressure shall be performed prior to returning the components to service or they shall be monitored for leaks using an approved gas analyzer within 15 days of the components being returned to service. Adjustments shall be made as necessary to obtain leak-free performance.

Connectors shall be inspected by visual, audible, and/or olfactory means at least weekly by operating personnel walk-through. In addition, all connectors shall be monitored by leak-checking for fugitive emissions at least quarterly using an approved gas analyzer with a directed maintenance program in accordance with items F thru J of this special condition.

In lieu of the monitoring frequency specified above, connectors may be monitored on a semiannual basis if the percent of connectors leaking for two consecutive quarterly monitoring periods is less than 0.5 percent.

Connectors may be monitored on an annual basis if the percent of connectors leaking for two consecutive semiannual monitoring periods is less than 0.5 percent.

If the percent of connectors leaking for any semiannual or annual monitoring period is 0.5 percent or greater, the facility shall revert to quarterly monitoring until the facility again qualifies for the alternative monitoring schedules previously outlined in this paragraph.

The percent of connectors leaking used in paragraph B shall be determined using the following formula:

(Cl + Cs) x 100/Ct = Cp

Where:

Cl = the number of connectors found leaking by the end of the monitoring period, either by Method 21 or sight, sound, and smell.

Cs = the number of connectors for which repair has been delayed and are listed on the facility shutdown log.

Ct = the total number of connectors in the facility subject to the monitoring requirements, as of the last day of the monitoring period, not including non-accessible and unsafe to monitor connectors.

Cp = the percentage of leaking connectors for the monitoring period.

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Each open-ended valve or line shall be equipped with an appropriately sized cap, blind flange, plug, or a second valve to seal the line. Except during sampling, both valves shall be closed. If the isolation of equipment for hot work or the removal of a component for repair or replacement results in an open ended line or valve, it is exempt from the requirement to install a cap, blind flange, plug, or second valve for 72 hours. If the repair or replacement is not completed within 72 hours, the permit holder must complete either of the following actions within that time period;

(1) a cap, blind flange, plug, or second valve must be installed on the line or valve; or

(2) the open-ended valve or line shall be monitored once for leaks above background for a plant or unit turnaround lasting up to 45 days with an approved gas analyzer and the results recorded. For all other situations, the open-ended valve or line shall be monitored once by the end of the 72 hours period following the creation of the open ended line and monthly thereafter with an approved gas analyzer and the results recorded. For turnarounds and all other situations, leaks are indicated by readings of 500 ppmv and must be repaired within 24 hours or a cap, blind flange, plug, or second valve must be installed on the line or valve.

F. Accessible valves shall be monitored by leak checking for fugitive emissions at least quarterly using an approved gas analyzer with a directed maintenance program. Non accessible valves shall be monitored by leak-checking for fugitive emissions at least annually using an approved gas analyzer with a directed maintenance program. Sealless/leakless valves (including, but not limited to, welded bonnet bellows and diaphragm valves) and relief valves equipped with a rupture disc upstream or venting to a control device are not required to be monitored. For valves equipped with rupture discs, a pressure-sensing device shall be installed between the relief valve and rupture disc to monitor disc integrity. All leaking discs shall be replaced at the earliest opportunity but no later than the next process shutdown. A check of the reading of the pressure-sensing device to verify disc integrity shall be performed at least quarterly and recorded in the unit log or equivalent. Pressure-sensing devices that are continuously monitored with alarms are exempt from recordkeeping requirements specified in this paragraph.

The gas analyzer shall conform to requirements listed in Method 21 of 40 CFR part 60, appendix A. The gas analyzer shall be calibrated with methane. In addition, the response factor of the instrument for a specific VOC of interest shall be determined and meet the requirements of Section 8 of Method 21. If a mixture of VOCs is being monitored, the response factor shall be calculated for the average composition of the process fluid. A calculated average is not required when all of the compounds in the mixture have a response factor less than 10 using methane. If a response factor less than 10 cannot be achieved using methane, than the instrument may be calibrated with one of the VOC to be measured or any other VOC so long as the instrument has a response factor of less than 10 for each of the VOC to be measured.

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A directed maintenance program shall consist of the repair and maintenance of components assisted simultaneously by the use of an approved gas analyzer such that a minimum concentration of leaking VOC is obtained for each component being maintained. Replaced components shall be re-monitored within 15 days of being placed back into VOC service.

G. All new and replacement pumps, compressors, and agitators shall be equipped with a shaft sealing system that prevents or detects emissions of VOC from the seal. These seal systems need not be monitored and may include (but are not limited to) dual pump seals with barrier fluid at higher pressure than process pressure, seals degassing to vent control systems kept in good working order, or seals equipped with an automatic seal failure detection and alarm system. Submerged pumps or sealless pumps (including, but not limited to, diaphragm, canned, or magnetic-driven pumps) may be used to satisfy the requirements of this condition and need not be monitored.

All other pump, compressor, and agitator seals shall be monitored with an approved gas analyzer at least quarterly.

H. Damaged or leaking valves, connectors, compressor seals, pump seals, and agitator seals found to be emitting VOC in excess of 500 parts per million by volume (ppmv) or found by visual inspection to be leaking (e.g., dripping process fluids) shall be tagged and replaced or repaired. A first attempt to repair the leak must be made within 5 days. Records of the first attempt to repair shall be maintained. A leaking component shall be repaired as soon as practicable, but no later than 15 days after the leak is found. If the repair of a component would require a unit shutdown that would create more emissions than the repair would eliminate, the repair may be delayed until the next scheduled shutdown. All leaking components which cannot be repaired until a scheduled shutdown shall be identified for such repair by tagging. A listing of all components that qualify for delay of repair shall be maintained on a delay of repair list. The cumulative daily emissions from all components on the delay of repair list shall be estimated by multiplying by 24 the mass emission rate for each component calculated in accordance with the instructions in 30 TAC 115.782 (c)(1)(B)(i)(II). The calculations of the cumulative daily emissions from all components on the delay of repair list shall be updated within ten days of when the latest leaking component is added to the delay of repair list. When the cumulative daily emission rate of all components on the delay of repair list times the number of days until the next scheduled unit shutdown is equal to or exceeds the total emissions from a unit shutdown as calculated in accordance with 30 TAC 115.782 (c)(1)(B)(i)(I), the TCEQ Regional Manager and any local programs shall be notified and may require early unit shutdown or other appropriate action based on the number and severity of tagged leaks awaiting shutdown. This notification shall be made within 15 days of making this determination.

I. Records of repairs shall include date of repairs, repair results, justification for delay of repairs, and corrective actions taken for all components. Records of instrument monitoring shall indicate dates, times, test methods, and instrument readings. The instrument monitoring record shall include the time that monitoring took place for

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no less than 95% of the instrument readings recorded. Records of physical inspections shall be noted in the operator’s log or equivalent.

J. Compliance with the requirements of this condition does not assure compliance with requirements of 30 TAC Chapter 115, an applicable New Source Performance Standard (NSPS), or an applicable National Emission Standard for Hazardous Air Pollutants (NESHAPS), and does not constitute approval of alternative standards for these regulations.

K. In lieu of the monitoring frequency specified in paragraph F, valves in gas and light liquid service may be monitored on a semiannual basis if the percent of valves leaking for two consecutive quarterly monitoring periods is less than 0.5 percent.

Valves in gas and light liquid service may be monitored on an annual basis if the percent of valves leaking for two consecutive semiannual monitoring periods is less than 0.5 percent.

If the percent of valves leaking for any semiannual or annual monitoring period is 0.5 percent or greater, the facility shall revert to quarterly monitoring until the facility again qualifies for the alternative monitoring schedules previously outlined in this paragraph.

L. The percent of valves leaking used in paragraph K shall be determined using the following formula:

(Vl + Vs ) x 100/Vt = Vp

Where:

Vl = the number of valves found leaking by the end of the monitoring period, either by Method 21 or sight, sound, and smell.

Vs = the number of valves for which repair has been delayed and are listed on the facility shutdown log.

Vt = the total number of valves in the facility subject to the monitoring requirements, as of the last day of the monitoring period, not including nonaccessible and unsafe to monitor valves.

Vp = the percentage of leaking valves for the monitoring period.

M. Any component found to be leaking by physical inspection (i.e., sight, sound, or smell) shall be repaired or monitored with an approved gas analyzer within 15 days to determine whether the component is leaking in excess of 500 ppmv of VOC. If the component is found to be leaking in excess of 500 ppmv of VOC, it shall be subject to the repair and replacement requirements contained in this special condition.

TCEQ – Control Efficiencies for TCEQ Leak Detection and Repair Programs Revised 07/11 (APDG 6129v2)

Control Efficiencies for TCEQ Leak Detection and Repair Programs

Equipment/Service 28M 28RCT 28VHP 28MID 28LAER Audio/Visual/Olfactory1

Valves

Gas/Vapor 75% 97% 97% 97% 97% 97%

Light Liquid 75% 97% 97% 97% 97% 97%

Heavy Liquid2 0%3 0%4 0%4 0%4 0%4 97%

Pumps

Light Liquid 75% 75% 85% 93% 93% 93%

Heavy Liquid2 0%3 0%3 0%5 0%6 0%6 93%

Flanges/Connectors

Gas/Vapor7 30% 30% 30% 30% 97% 97%

Light Liquid7 30% 30% 30% 30% 97% 97%

Heavy Liquid 30% 30% 30% 30% 30% 97%

Compressors 75% 75% 85% 95% 95% 95%

Relief Valves (Gas/Vapor)

75% 97% 97% 97% 97% 97%

Open-ended Lines8 75% 97% 97% 97% 97% 97%

Sampling Connections

75% 97% 97% 97% 97% 97%

1. Audio, visual, and olfactory walk-through inspections are applicable for inorganic/odorous and low vapor pressure compounds such as chlorine, ammonia, hydrogen sulfide, hydrogen fluoride, and hydrogen cyanide.

2. Monitoring components in heavy liquid service is not required by any of the 28 Series LDAR programs. If monitored with an instrument, the applicant must demonstrate that the VOC being monitored has sufficient vapor pressure to allow reduction.

3. No credit may be taken if the concentration at saturation is below the leak definition of the monitoring program (i.e. (0.044 psia/14.7 psia) x 106 = 2,993 ppmv versus leak definition = 10,000 ppmv).

4. Valves in heavy liquid service may be given a 97% reduction credit if monitored at 500 ppmv by permit condition provided that the concentration at saturation is greater than 500 ppmv.

5. Pumps in heavy liquid service may be given an 85% reduction credit if monitored at 2,000 ppmv by permit condition provided that the concentration at saturation is greater than 2,000 ppmv.

6. Pumps in heavy liquid service may be given a 93% reduction credit if monitored at 500 ppmv by permit condition provided that the concentration at saturation is greater than 500 ppmv.

7. If the applicant decides to monitor connectors using an organic vapor analyzer (OVA) at the same leak definition as valves, then the applicable valve reduction credit may be used instead of the 30% reduction credit. If this option is chosen, the applicant shall continue to perform the weekly physical inspections in addition to the quarterly OVA monitoring.

8. The 28 Series quarterly LDAR programs require open-ended lines to be equipped with an appropriately sized cap, blind flange, plug, or a second valve. If so equipped, open-ended lines may be given a 100% control credit.

Attachment 5

Attachment 6

ACRONYM DESCRIPTION

ADU Atmospheric Distillation Unit

AWP Alternate Work Practice

bbl Barrels

BCP Best Combustion Practices

BHP Brake Horse-Power

BWON Benzene Waste Operations NESHAP

CEMS Continuous Emission Monitoring System

CFR Code of Federal Regulations

CMS Continuous Monitoring System

CO Carbon Monoxide

CPMS Continuous Parameter Monitoring System

CRU Catalytic Reforming Unit

CT Cooling Tower Cell

DHT Distillates Hydrotreater Unit

ELDAR Enhanced Leak Detection and Repair

EP Emission Point

EU Emission Unit

FGCD Fuel Gas Combustion Devices

FRT Fixed Roof Tank

HAP Hazardous Air Pollutant

HC Hydrocarbon

HYK Hydrocracker Unit

H2S Hydrogen Sulfide

IFR Internal Floating Roof

IFRT Internal Floating Roof Tank

lb pounds

LDAR Leak Detection and Repair

LPG Liquefied Petroleum Gas

MACT Maximum Achievable Control Technology (40 CFR 63)

MMbtu Million British Thermal Units

NDAC North Dakota Administrative Code

NDCC North Dakota Century Code

NESHAP National Emission Standards for Hazardous Air

Pollutants (40 CFR 61)

NHT Naphtha Hydrotreater Unit

NMHC Non-Methane Hydrocarbons

NOx Oxides of Nitrogen

NSPS New Source Performance Standards (40 CFR 60)

OGI Optical Gas Imaging

OVA Olfactory, Visual, and Audible

OWS Oily Water Separator

PM Particulate Matter

ACRONYM DESCRIPTION

PM2.5 Particulate Matter under 2.5 microns

PM10 Particulate Matter under 10 microns

FPM Filterable Particulate Matter

CPM Condensable Particulate Matter

ppm parts per million

ppmv parts per million by volume

PTC Permit to Construct

RFG Refinery Fuel Gas

SCR Selective Catalytic Reduction

SFP Submerged Fill Pipe

SOx Sulfur Oxides

SRU Sulfur Recovery Unit

TAB Total Annual Benzene

TRS Total Reduced Sulfur

ULNB Ultra-Low NOX Burner

ULSD Ultra-Low Sulfur Diesel

VDU Vacuum Distillation Unit

VOC Volatile Organic Compounds

VOL Volatile Organic Liquids

VRU Vapor Recovery Unit

WWTP Waste Water Treatment Plant