New Mexico Air Quality Bureau

NEW MEXICO AIR QUALITY BUREAU

NSR & TV: MONITORING PROTOCOL

VOC/HAPS LDAR FUGITIVE MONITORING AT NEW MEXICO SOURCES

Version: April 19, 2017

[NOTE: Each permit writer shall review and adjust the requirements below according to the specific facility circumstances. Frequently for VOC emissions, hourly limits are likely to not be appropriate. If this is the case, permit writers should indicate this in the emission limit table and clarify with a footnote such as “ * indicates hourly emission limits are not appropriate for this operating situation.”

A facility may have multiple sections of a facility that are subject to different requirements depending on when the components were constructed or reconstructed. For example, one facility may have sections subject to no NSPS or MACT, a section subject to NSPS KKK, and a section subject to NSPS OOOO. For these cases, multiple fugitive conditions may be required.

The unit numbers need to be clearly identified in each condition, especially if the facility is subject to multiple conditions for different areas of the facility.

Units NOT subject to Federal LDAR regulations

[NOTE – The condition below corresponds to the scenario addressed in column B in the decision tree.]

1. Chemical Analysis/Equipment Countand Leak Monitoringfor Fugitive VOC Equipment not Subject to a federal NSPS or MACT leak detection regulation (Unit(s) FUGX, FUGY, etc.)[25 & < 100 TPY Facility Wide Fugitives, units not subject to federal LDAR regulations]

1. The instrument shall be calibrated before each day of its use by the procedures specified in RM 21.
2. The instrument shall be calibrated with zero air (less than 10 ppm of hydrocarbon in air); and a mixture of methane or n-hexane and air at a concentration of about, but less than, 10,000 ppm methane or n-hexane.
3. If an instrument reading of 10,000 ppm or greater of methane or n-hexane is measured, a leak is detected.

1. The instrument must comply with the specifications, the daily instrument checks, and the leak survey requirements at 40 CFR §60.18(i)(1) – (3).
2. If any emissions are imaged by the optical gas instrument, a leak is detected.

[NOTE – The condition below corresponds to the scenario addressed in column C in the decision tree.]

1. Leak Detection and Repair Program for fugitive equipment in VOC service not subject to a Federal NSPS or MACTleak detection regulation(Unit(s) FUGX, FUGY, etc.)[ 100 TPY Facility Wide Fugitives]

1. The instrument shall be calibrated before each day of its use by the procedures specified in RM 21.
2. The instrument shall be calibrated with zero air (less than 10 ppm of hydrocarbon in air); and a mixture of methane or n-hexane and air at a concentration of about, but less than, 10,000 ppm methane or n-hexane
3. If an instrument reading of 10,000 ppm or greater methane or n-hexane is measured, a leak is detected

1. The instrument shall comply with the specifications, the daily instrument checks and the leak survey requirements at 40 CFR §60.18(i)(1) – (3).
2. If any emissions are imaged by the optical gas instrument, a leak is detected.

[NOTE – There are no standard conditions proposed at this time that correspond to the scenario addressed in column D in the decision tree.]

Units Subject to One or More Federal LDAR Regulations

[NOTE – The conditions below correspond to the scenario addressed in column E in the decision tree.]

1. 40 CFR 60, Subpart VV (Unit(s) X, Y, and Z) [Equipment at Synthetic Organic Chemicals Manufacturing Industry Plants subject to NSPS VV]

1. 40 CFR 60, Subpart VVa (Unit(s) X, Y, and Z) [Equipment at Synthetic Organic Chemicals Manufacturing Industry Plants subject to NSPS VVa]

1. 40 CFR 60, Subpart GGG (Unit(s) X, Y, and Z) [Equipment at Petroleum Refineries subject to NSPS GGG]

1. 40 CFR 60, Subpart GGGa (Unit(s) X, Y, and Z) [Equipment at Petroleum Refineries subject to NSPS GGGa]

1. 40 CFR 60, Subpart KKK (Unit(s) X, Y, and Z)[Equipmentand compressors at Onshore Natural Gas Processing Plants subject to NSPS KKK]

1. 40 CFR 60, Subpart OOOO (Unit(s) X, Y, and Z) [Equipment at Onshore Natural Gas Processing Plants subject to NSPS OOOO]

1. 40 CFR 60, Subpart OOOOa (Unit(s) X, Y, and Z) [Equipment at Onshore Natural Gas Processing Plants subject to NSPS OOOOa]

1. 40 CFR 60, Subpart OOOOa (Unit(s) X, Y, and Z) [Collection of fugitive emissions componentsat well sites and compressor stationsspecified at §60.5365a(i) and (j)subject to NSPS OOOOa]

1. 40 CFR 63, Subpart CC (Unit(s) X, Y, and Z) [Equipment in organic HAP service at Petroleum Refineries subject to MACT CC]

1. 40 CFR 63, Subpart HH (Unit(s) X, Y, and Z) [Ancillary equipment and Compressors at Natural Gas Processing Plants subject to MACT HH]

Background:

How emissions were determined is key to establishing monitoring. Usually, fugitive leaks are calculated based on an emission factor for each component, the number of components, and the concentration of the pollutant inside the component.