Document rB6XmNv4eJj1VbnLxJm1QnzE0

...... .......... . ll l-l II11 ll-l li-M -........... Hi I| HIM Mil'mu ........... ................................... r.:Pitip:.Mrim*iiiH|m*tT^;fn*iimtitw*inrt*Tif^w*^ii|i|||FIin|iWi*1i*rWll|l|lllil|limfl||(liP||l!|PP|JlfHPmmillflHHTM 111 ffIfIT1 hffPI11TM1 i Wl 111 |T111II FITITIttH Hfl+I HI T i*m?rpiTl^tyltiHpiMHpi*>H1tlhHKli' 11 11 : ............|l|,fL.M.-l.|n|IL............H.|.-.|.ri.,l-. r| I , I I ................. III-.. h'mIiIi:: hn-ir nn:iiini+inMini: VAB.0001019634 kwlhuUtlwMlUiuLh I 11. :111 - 111 i i 11 i ii i 11 i 11 -1 h .111 ii i; -1 r| 11 ii -i 11 i -i-|: 11 -i11 111111 111 . i. i: 11 i i i m 11 I................. .-if-'i .................................... 11111 i-111;11;11111;i|-Mti11:1111i|~ni 11111Hf I t H. * \ * i- VAB.0001019635 AUDIT FORM DATE: 7 XMM ) SYSTEM BEING AUDITED I 2>lPfcgS AUDIT MO. 8 f I -- _____________________ AUDITORS 8 ^ - ft >w4A;nE , W - B. Qs| ETTI 1 2 Find safety to see what ideas they have about things you should look for in your audil tinq documentation about the svstem: Not A. Process Flow Diagram B. P & I Diagrams C. Class NAM Design D. Operating Procedures (/ E. Maintenance Procedures F. Mechanical Design & Construction Files 6. Plant Location Lists^ / H. Plot Plans I. EPA Rules J. OSHA Rules / K. Vista Standards L. Previous Audits M `Psernctrio I>dWfrt*5* \/ / J v/ / ^^ * * *v\ CsO' VAB.0001019636 3. Interview three people separately who are familiar with the system you're auditing. Learn from them how the system works and their concerns about the system. PPP oXXfccXuA ,, Ni v^cU, (). Cv)fKXJsw> cMruX " y'tiuPv. Adw* Adwuf M^tzA Is it operated as the operating procedures (design, etc.) say it is supposed to be operated? If no, what's different? Hes iwv) 5. Is it us.d per the appropriate OSHA, EPA, or Vista standards? Yes/No VAB.0001019637 Brainstorm possible problems with the system. brainstorm list. Z. Uy 1> . Nit? 'fc+A VCxe^Uvi A/V* -Al^A/L* Xu iwjW iw^v^vi vJTrviL OX^l^vo Attach the JU&$k/) C^jvv* Do any of the problems identified in your brainstorming list make it unsafe? Me f VAB.0001019638 mV f f AT What needs to be done as follow-up to this audit? changes need to be made? -kf\ tft f(Ua Ct^MAO What 2-, 3. 9. When should this A Jf&Cn C'tTM yto Why? MMJt 3. 9zbXl^Mi / ^4- Ajrtbv A A4 {CtiLys Jm,u; * VAB.0001019639 To _ From Calculation Sheet \ SomcxT >c. ^rnLioto()i So.! /* f s\j l LoCe^W o.c.V Mc*\st. a. e^cx io<-: ft. PtlxSS ____ k rar<AM^gr goW- Made By Date Page V3-20G-S r dovyv f>WW: \, /* UOcAt, u^of <- arcte* ~ ?\ -or <x\\ Uys y>k>Ct & \j<xX<2> 2. UJrfie and ZS90& pe^a/ir o/J _______?t ng/sJ61. END (V. Let W l DL. K' ecorCt' O'* Job No. Title __i> /Kr__ Co/ ^fy of Q o ox ^eLY- Lv^ VAB.QQQ1019640 HAZARDOUS EMISSIONS 120:1025 the Administrator within 4ft days of mixtures may be di lees than 10 percent of the time tho effective data of these regulations, rectly used to propers a chromato- exempt from the requirements of unless a waiver of oomUtonns is grant- traafti calibration curve as described in f 41.242-4 of Subpart V. provided the ad under lftl.ll, or the pramgm hns section 7.S of Test Method 104. The re open-ended valves or lines are ad Imm tppravid tht Adtanit9lBf quirements tan section 5.2.3.I. and dressed in the monitoring system re doaa not request a Niht oft tho an* S.2J.2. of Test Method 104 for certifi quired by paragraph (bxftxi) of this gram. Approval oft a program oral ho cation oft cylinder standards and for section. The Administrator may apply ifttBted wf ttM AtelsMntv pravMtod cethMtohment and verification of cali this imeimrtHii* to other existing open- ha finds: bration standards are to be followed. ended valves or lines that are demon <A> Tho location, and number of (ID ftar each pros-- unit subject to strated to require significant retrofit points to be monitored and tho fre this subpart, a formal teak decoction cost to comply with the requirements quency of monitoring provided for In and repair program shall be imple of 161.242-4 of Subpart V. tho program are snraptahto when they an conrand with tiki number of plooss oft equipment in vinyl chloride service end rise and physical layout of the plant (B) It contains a definition of lsafc which Is acceptable when compared with the background concentrations of vinyl chloride in the areas of the plant to be monitored by the vinyl chloride monitoring system. Measurements of background concentrations of vinyl chloride In the areas oft the plant to be monitored by the vinyl chloride moni toring system ere to baIncluded with the deentpifton of the program. The definition of leak for a given plant may vary among the different areas within the plant and is also to change over thee as background concentra tions in the plant are reduced. <C) It contains an acceptable plan of action to be taken whan a leak to de tected. (D) It provides for an acceptable calibration end maintenance - schedule for the vinyl chloride monitoring inttm end Bortahle- awCwMJM'iaiMt de- toetor. ftor the vinyl monitor tag aytern, a dally span check is to be conducted with a roncentteflon of vinyl chloride ogual to the concentra tion defined as a leak according: to paragraph (bXSXlXB) oft this section. The calibration to to be done with either (1) A calibration cm mixture pre pared from the gases specified in sec tions 5.2.1. end 5.2.2. of Test Method 104 and in accordance with section 7.1 of TSat Method 106, nr (2) A calibration pi cylinder itind* ard containing the appropriate con centration of vinyl chloride. The gas composition of the calibration gas cyl inder standard, to to have bean certi mented eanatotasit with Subpart V of this pert, except as provided In para graph (bxiXitti of this section. This program to to be implemented within 90 days of the effective date of these regulations, unices a waiver of compli ance to granted under 141.11. Except as provided in pangpnpli (bXftXUXE) of this section, aa owner or operator hah bo exempt Cram 161.342-l(d). 101.242-7 (a), (b), and (c). 141.244. and 141.247 of Bubpnrt V of this part for any Drocuaeunitin which tu* uerOSQftftflftr o looftditto^^iOoKvoo Jo stretod to be tern 'than 2.0 percent. In accordance with th* I (A) A perforins line teat as hi paragraph (bXftXilXB) of this tften stall be eoasflmdedliiiftlolly within Mini: aft the- aiMtiM date- aft these mmnmm ilm imtfifc BAmml ff, flttMftttA tar thft AtaitalitnftfiffL (B) 9m neb performance tact, a of eggriir-Mneteentk which- ever to teen oft the tatair vatvea In VOC <aa defined In | PMii of Sub port W of Part ift) within the procam we Mmft> bt rendnmiy seiealed and' esdtmad wBMp;* waste by the methods nwMbl in j iUtofteb) of this part. If an hutnanani tssdlng oft 10.000 ppm er greater to measured, a teak to detected. The tegtepmviwitago shall be detarwbaad by Pvtaag the number bf valves hi TOC service far which teaks are dataatad by the number of tested valves la VOC service. CO St a teak to detected, it shall be repaired In accordance with 141.242-7 (d) and (e) of Bubpnrt V of this part. (D) The results of the performance test shill be eubmOted ln writing to the Admhdetntar in the first quarter ly repert foBowing the performance (ft) Zaproom wastewater. Vinyl chlo ride emtsteons to the atmosphere from Inprocam wastewater are to be reduced ss follows: (1) The concentration of vinyl chlo ride In each Inprocess wastewater stream containing greater than 10 ppm vinyl chloride measured Immedi ately as it leaves a piece of equipment and before beingmixed with any other lnpraesm wastewater stream is to be reduced to no more than 10 ppm by ualgfat before being mixed with any other InpKwmta* wastewater stream wtelsb eoUMMI tern than 10 ppm vinyl cMastdee* befow being exposed to atmowstarat buftnre holnc WMMstat trratment orocMK or Hmnmm hBliw AftmtoArmmA iititrUltBfl || ft dt j^uk . JlIilM - - Mam atooh QOttlJB ^ta .^mmn apply to water which to used to dto- p1mo. vinyl from equipment before It to opened to the atmoaphere hi aoeerdanow with 16l.44(aX2) or pataompb <bX6) of this section, but doaa not apply to water which to used to waah' out equipment after the equipment has ahreedy been opened to with fglBftfeXft) or paragraph (bX6) of thto section. (ID Any vinyl chloride removed from the tnprocees^ wastewater In accord ance with paragraph (bxftxi) of this seetkm to to be ducted through a con trol system from which the concentra tion of vinyl chloride in the exhaust gases does not exceed 10 ppm (average for 9-hour period); or equivalent as provided in 141.40. [61.65(b)(9)(H) revised by 51 FR 34908. September 30. 1986) (c) The requirements in paragraphs (bXl), (bX2), (bXft), <bX), (bXT) and fied by the manufacturer. The manu test as pert nr the reporting require- (bXft) of this section are to be incorpo facturer must hay reocunmended a iwHmtwn iifa hr each cylinder aftftg6i1.70. rated Into a standard operating proce the dure, and made available upon request so -that *h# concentration dons - not change greater than aft percent from the certified value. The date of gas +**inSU for inspection by the Administrator. The standard operating procedure to to include provisions for measuring cylinder preparation, certified vinyl chloride concentration, end recent mwnfas Mg tug wmt have the vinyl chloride In equipment 4.7ft mi (1,255 gal) ftn volume for which an limit to prescribed in been affixed to the cylinder before | ftl.6ft(bX6Hl) after opening the shipment from the manufacturer to equipment and using Test Method 106, the buyer. If a gas chromatograph to ed on multiple service p***---- mm a portable hydrocarbon detector, or an used aa the vinyl chloride monitoring which operate in vinyl chloride service alternative method. The method of 8-3-90 PuMWwd by THE BUREAU OF NATIONAL AFFAIRS INC.. Washington. O.C. 20037 [tee. 41.45(c)] 33 4 VAB.0001019641 pw 120:1056 FEDERAL. REGULATIONS sources; and the first semiannual period concludes on the last day of the last full month during the 180 days after the effec tive date of a specific aubpart that refer ences this subpart for existing sources. [Corrected by 49 FR 38946, October 2, fill 111 ITicudsift rigs (a)(1) Each pump shall be monitored monthly to detect leaks by the methods specified in 61.245(b), except as provided in 61.242-1 (c) and paragraphs (d), (e) and (0 of this section. VHAP in the barrier fluid. fit) If the monitor reading (taking into account any background readings) indicates the presence of VHAP. n leak is detected. For the purpose of this paragraph, the monitor may be 1984] (2) Each pump shall be checked by calibrated with VHAP, or may employ a "Sensor" means a device that measures visual inspection each calendar week for gas chromatography column to limit the a physical quantity or the change in a indication* of liquid* dripping from the response of the monitor to VHAP, at the physical quantity, such as temperature, pump seal. option of die owner or operator. pressure, flow rate, pH, or liquid level. "Stuffing boa pressure'* means the fluid (liquid or gas) pressure inside the casing (b)(1) If an instrument reeding of 10.000 ppm or greater is measured, a leak is detected. (iii) If an instrument reading of 10,000 ppm or greeter (total VOC) is measured, a leek is detected. .or housing of a piece of equipment, on the process side of the inboard seal. [Added by 34 FR 38073, September 14, 1989] "Volatile hasardous air pollutant" or "VHAP" means a substance regulated under this part for which a standard for equipment leaks of the substance has been proposed and promulgated. Bensene is a VHAP. Vinyl chloride is a VHAP. (2) If there are indications of liquids dripping from the pump seal, a leak is detected. (c)( 1) When a leak is detected, it shall be repeired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 61.242- 10 (2) A lint attempt at repair shall be made no later than fi calendar day* after each leak la detected. (5) Each sensor es described in paragraph (dK3) of this section is checked dally or Is equipped with an audible alarm. (6Hi) The owner or operator determines, based on design considerations and operating experience, criteria applicable to the presence end frequency of drips end the sensor that indicates failure of th seel system, the barrier Quid system. [Amended by 31 FR 34908, September 30, 1986) (d) Eachjpump equipped with a duel mechanical eeai system that includes a barrier field system is exempt from the both. (il) If indications of liquids dripping from die pump seel exceed the criteria 61.242-1 Standards: Csacral. requirements of paragraphs (a) end (b) established in paragraph (d)(6)(i) of this (a) Each owner or operator subject to of this stettan. provided the following the provisions of this subpart shall demon requirements era met: section, or if. baaed on the criteria established in paragraph (d)(6H0 of this strate compliance with the requirements [61.242-2(d) introductory text emended section, the sensor indicates failure of of 61.242-1 to 61.242-11 for each new by 55 FR 28348, July 10, 1990] the seal system, the barrier fluid system, and existing source as required in 40 CFR 61.03, except as provided in 61.243 and 61.244. (b) Compliance with this subpart will be determined by review of records, review of performance test results, and inspection using the methods and procedures speci fied in 61.245. <1> Each dual mechanical seal system Ik <1> Operated with the barrier fluid at a pressure that is at all times greater than the pump stuffing box pressure; or (11) Equipped with a barrier fluid de gassing reservlor that Is connected by a cloeed-vent system to a control or both, e leak is detected. (ill) When e leak Is detected. It shell be repaired as soon es practicable, but no later than IS calendar days after It is .detected, except as provided fat 161.242- 10 (iv) A first attempt at repair shell be made no later then five calender days after each leek is detected. (c) (1) An owner or operator may re quest a determination of alternative means of emission limitation to the requirements of 61.242-2, 61.242-3, 61.242-5. 61.2426, 61.242-7, 61.242-8, 61-242-9 and 61242-11 as provided in 61.244. [61.242-1(c)(1) corrected by 49 FR 38946. October 2. 1984] (2) If the Administrator makes a deter mination that a means of emission limita tion is at least a permissible alternative to the requirements of .61.242-2, 61.242-3, 61.242- 5, 61.242-6, 61.242-7. 61.242-8, 61.242- 9 or 61.242-11, an owner or opera tor shall comply with the requirements of that determination._____________________ (d) Each piece of equipment to which this subpart applies shall be marked in such a manner that it can be distinquished readilyjrpm other pieces of equipment. (e) Equipment that is in vacuum service is excluded from the requirements of 61.242-2, to 61.242-11 if it is identified as required in 61.246(e)(3). device that complies with the require ments of 61.242-11; or (ill) Equipped with a system that purges the barrier fluid into a process stream with aero VHAP emissions to atmosphere, (e) Any pump that ia designated, as described in 61.246(e)(2), for no de tectable emissions, as indicated by an Instrument reading of less than 500 ppm above background, is exempt from the requirements of paragraphs (2) The barrier fluid is not in VHAP (a), (c). and (d) if the pump: service and, if the pump is covered by standards under 40 CFR Part 60. is not in VOC service. (1) Has no externally actuated shaft penetrating the pump housing, (3) Bach barrier fluid system is equipped with a senior that will detect failure of the seal system, the barrier fluid system, or both. (4) Bach pump is checked by visual inspection each calendar week for indi (2) Is demonstrated to be operating with no detectable emissions, as indi cated by an Instrument reading of less than 500 ppm above background, as measured by the method specified in 51.245(c). and cations of liquids dripping from the (3) Is tested for compliance with pump seal. paragraph (eX2) initially upon desig [61.242-2(d)(4)(i) -- (Hi) added. (5) and (6) revised by 55 FR 28348, July 10, 1990] (i) If there are indications of liquid dripping from the pump seal at the time r.f die weekly inspection, the pump shall nation, annually, and at other times requested by the Administrator. (f) If any pump is equipped with a closed-vent system capable of captur ing and transporting any leakage from the seal or seals to a control device that complies with the requirements be monitored es specified in 161.245 to of 51.242-11, It is exempt from the determine the presence of VOC and requirements of paragraphs (iMe). Environment Reporter (See. 61.241-2(1)] VAB.0001019642 A K VAB.0001019644 A o