piping system leak detection and monitoring

8/12/2019 Piping System Leak Detection and Monitoring

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Leaks in a chemical process in-dustries (CPI) facility can runthe gamut from creating acostly waste to prefacing a cat-

astrophic failure.. They can be anannoyance, by creating pools of liq-uid on concrete that can become apossible slipping hazard and house-keeping problem, or a leak that canemit toxic vapors, causing variousdegrees of harm to personnel. Insome cases a leak may be a simple

housekeeping issue that goes intothe books as a footnote indicatingthat a repair should be made whenresources are available. In othercases it can become a violation ofregulatory compliance with statu-tory consequences, not to mentiona risk to personnel safety and thepossible loss of capital assets.

Understanding the mechanismsby which leaks can occur and priori-tizing piping systems to be checkedat specific intervals based on a few

simple factors is not only a prag-matic approach to the preventivemaintenance of piping systems, butis part of a CPIs regulatory com-pliance. This includes complianceunder both the U.S. Environmen-tal Protection Agency (EPA) Clean

Air Act (CAA; 40CFR Parts 50 to52) and the Resource Conservationand Recovery Act (RCRA; 40CFRParts 260 to 299). We will get intomore detail with these regulations,as well as the leak detection andrepair (LDAR) requirement withinthe above mentioned regulations, aswe move through this discussion.

When discussing anything to dowith government regulations, the

terminology quickly turns into analphabet soup of acronyms. Thebox on the right lists, for easy refer-ence, the titles and acronyms thatwill be used in this discussion.

Leak mechanisms

Eliminating the potential for leaksis an integral part of the designprocess that takes place at the veryonset of facility design. It is woveninto the basic precept of the pipingcodes because it is such an elemen-

tal and essential component in theprocess of designing a safe and de-pendable piping system.

Piping systems, as referred tohere, include pipe, valves and otherinline components, as well as theequipment needed to hold, move andprocess chemicals. Why then, if wecomply with codes and standards,and adhere to recommended indus-try practices, do we have to concernourselves with leaks? Quite point-edly it is because much of what we

do in design is theoretical, such asmaterial selection for compatibility,and because in reality, in-processconditions and circumstances donot always perform as expected.

Whether due to human error ormechanical deficiencies, leaks area mechanism by which a containedfluid finds a point of least resistanceand, given time and circumstances,breaches its containment. What welook into, somewhat briefly, are twogeneral means by which leaks canoccur; namely corrosion and me-chanical joint deficiencies.Corrosion. Corrosion allowance

(CA) is used as an applied factorin calculating, among other things,wall thickness in pipe and pressure

vessels. The CA value assigned toa material is theoretical and predi-cated on four essential variables:

material compatibility with thefluid, containment pressure, tem-perature of the fluid and velocityof the fluid. What the determina-tion of a CA provides, given those

variables, is a reasonable guess ata uniform rate of corrosion. Andgiven that, an anticipated loss ofmaterial can be assumed over thetheoretical lifecycle of a pipelineor vessel. It allows a reasonableamount of material to be added intothe equation, along with mechani-cal allowances and a mill tolerancein performing wall thickness cal-culations. The problem is that be-

Feature Report

44 CHEMICAL ENGINEERING WWW.CHE.COM MAY 2014

Cover Story

W. M. (Bill) Huitt

W.M. Huitt Co.

Eliminating the potential for leaks is an integral part

of the design process that takes place at the very

onset of facility design

Piping-System Leak Detection

and Monitoring for the CPIACRONYMS

AVO= Audio/visual/olfactory CAA= Clean Air Act HAP= Hazardous air pollutants

HON= Hazardous organic NESHAP

LDAR= Leak detection and repair

LUST= Leaking underground

storage tank NEIC= National Enforcement

Investigations Center

NESHAP= National EmissionStandard for Hazardous AirPollutants

NSPS= New Source PerformanceStandards

RCRA= Resource Conservation andRecovery Act

SOCMI= Synthetic organic chemicalmanufacturing industry

TSDF = Treatment, storage anddisposal facilities

UST= Underground storage tank

VOC= Volatile organiccompounds


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yond the design, engineering, andconstruction phase of building afacility, the in-service reality of cor-rosion can be very different.

Corrosion, in the majority ofcases, does not occur in a uniform

manner. It will most frequentlyoccur in localized areas in the formof pits, as erosion at high-impinge-ment areas, as corrosion underinsulation, at heat-affected zones(HAZ) where welding was improp-erly performed, causing a localizedchange to the mechanical or chemi-cal properties of the material, andin many other instances in whichunforeseen circumstances createthe potential for corrosion and theopportunity for leaks in the pipe

itself or in a vessel wall. Becauseof that incongruity, corrosion is ananomaly that, in reality, cannotwholly be predicted.

Corrosion-rate values found invarious published resources on thetopic of material compatibility arebased on static testing in which amaterial coupon is typically set ina vile containing a corrosive chemi-cal. This can be done at varyingtemperatures and in varying con-centrations. After a period of time,

the coupon is pulled and the rateof corrosion is assessed. That is asimplification of the process, butyou get the point. When a materialof construction (MOC) and a po-tentially corrosive chemical cometogether in operational conditions,the theoretical foundation uponwhich the material selection wasbased becomes an ongoing realtimeassessment. This means that duediligence needs to be paid to exam-ining areas of particular concern,depending on operating conditions,such as circumferential pipe weldsfor cracking, high-impingement

areas for abnormal loss of wallthickness, hydrogen stress-corro-sion cracking (HSCC), and others.

The LDAR program does notspecify the need to check anythingother than mechanical joints for po-

tential leaks. Monitoring pipe andvessel walls, particularly at weldsthat come in contact with corrosivechemicals, is a safety considerationand practical economics. Perform-ing cursory examinations for suchpoints of corrosion where the po-tential exists should be made partof any quality assurance or qualitycontrol (QA/QC) and preventivemaintenance program.

Mechanical joints and open-ended pipe. Mechanical joints

can include such joining methodsas flanges, unions, threaded joints,

valve bonnets, stem seals and clampassemblies. It can also includepump, compressor and agitatorseals. Other potential points of tran-sient emissions include open-endedpiping, such as drains, vents, andthe discharge pipe from a pressure-relief device. Any of these joints orinterfaces can be considered poten-tial leak points and require bothmonitoring and record-keeping doc-

umentation in compliance with theEPAs LDAR program.

Mechanical joints can leak due toimproper assembly, insufficient orunequal load on all bolts, improp-erly selected gasket type, sufficientpressure or temperature swingsthat can cause bolts to exceed theirelastic range (diminishing theircompressive load on the joint), andan improperly performed hot-bolt-ing procedure in which in-servicebolts are replaced while the pipelineremains in service. Hot bolting isnot a recommended procedure, butis nonetheless done on occasion.

Pump, compressor and agitatorseals can develop leaks where shaftmisalignment plays a part. If theshaft is not installed within recom-

mended tolerances or if it becomesmisaligned over time there is agood possibility the seal will beginto fail.

The LDAR programPromulgated in 1970 and amendedin 1977 and 1990, the Clean Air

Act requires that manufactur-ers producing or handling VOCsdevelop and maintain an LDARprogram in accordance with therequirements set forth under the

Clean Air Act. This program moni-tors and documents leaks of VOCsin accordance with Method 21 Determination of Volatile OrganicCompound Leaks.

Table 1 provides a listing of keyelements that should be containedin an LDAR program. Those ele-ments are described as follows:Written LDAR compliance.Com-pile a written procedure declaringand defining regulatory require-ments that pertain to your specific

facility. This should include record-keeping certifications; monitoringand repair procedures; name, title,and work description of each person-nel assignment on the LDAR team;required procedures for compilingtest data; and a listing of all processunits subject to federal, state andlocal LDAR regulations.Training. Assigned members ofthe LDAR team should have someexperience base that includes workperformed in or around the types of

piping systems they will be testingand monitoring under the LDARprogram. Their training should in-clude familiarization with Method21 and also training as to the cor-rect procedure for how to examinethe various interface connectionsthey will be testing. They shouldalso receive training on the testinstrument they will be using andhow to enter the test data in theproper manner. All of this needs tobe described in the procedure.

LDAR audits. An internal auditteam should be established to en-sure that the program is being car-

CHEMICAL ENGINEERING WWW.CHE.COM MAY 2014 45

TABLE 1. ELEMENTS OF A MODEL LDAR PROGRAM

Written LDAR compliance First attempt at repair

Training Delay of repair compliance assurance

LDAR audits Electronic monitoring and storage of data

Contractor accountability QA/QC of LDAR data

Internal leak definitions Calibration/calibration drift assessment

Less frequent monitoring Records maintenance


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Cover Story


ried out on a routine basis in an ef-ficient and comprehensive mannerin accordance with the written pro-cedures. A third-party audit team is

brought in every few years to con-firm that internal audits are beingcarried out in the proper mannerand that all equipment that shouldbe included in the monitoring islisted as such. It also ensures thatthe tests are being carried out prop-erly and that the test results areentered properly.Contractor accountability.When selecting an outside con-tractor to perform internal LDARaudits for a facility or when bring-

ing in an outside contractor to in-spect the work of the internal auditteam, it is recommended that thecontract be written in a mannerthat places appropriate responsi-bility on that contractor. In doingso there should be penalties de-scribed and assessed as a resultof insufficient performance or in-accurate documentation of pre-scribed testing and documentationprocedures. Expectations shouldbe well defined and any deviation

from those prescribed norms by athird-party contractor should con-stitute a breach of contract. In allfairness, both parties must under-stand exactley what those expecta-tions are.

Internal leak definitions. Inter-nal leak definitions are the maxi-mum parts per million, by volume(ppmv) limits acceptable for valves,connectors and seals, as defined bythe CAA regulation governing a fa-cility. For example, a facility may be

required to set an internal leak-def-inition limit of 500 ppm for valvesand connectors in light liquid or gas/

vapor fluid service and 2,000 ppminternal leak definition for pumpsin light liquid or gas/vapor fluidservice. Light liquid is definedas a fluid whose vapor pressure isgreater than 0.044 psia at 68F.

Less frequent monitoring.Undersome regulations it is allowed thata longer period between testing isacceptable if a facility has consis-tently demonstrated good perfor-mance (as defined in the applicableregulation). For example, if a facil-

ity has consistently demonstratedgood performance under monthlytesting, then the frequency of test-ing could be adjusted to a quarterly

test frequency.First attempt at repair.Upon de-tection of a leak, most rules will re-quire that a first attempt be madeto repair the leak within five daysof detection; if unsuccessful, any fol-low-up attempts need to be finalizedwithin 15 days. Should the repairremain unsuccessful within the 15-day time period, the leak must beplaced on a delay of repair list anda notation must be made for repairor component replacement during

the next shutdown of which theleaking component is a part.

Delay of repair compliance as-surance.Placing a repair item onthe delay of repair list gives assur-ances that the item justifiably be-longs on the list, that a plan existsto repair the item, and that partsare on hand to rectify the problem.It is suggested that any item beinglisted in the delay of repair list au-tomatically generate a work orderto perform the repair.

Electronic monitoring and stor-age of data. Entering leak-testdata into an electronic databasesystem will help in retrieving suchdata and in utilizing them in waysthat help provide reports highlight-ing areas of greater concern to areasof lesser concern. Such informationcan help direct attention and re-sources away from areas of leastconcern, while mobilizing resourcesto areas of greater concern. This en-ables a much more efficient use of

information and resources.QA/QC of LDAR data. A wellwritten LDAR program will includea QA/QC procedure defining theprocess by which it is assured thatMethod 21 is being adhered to, andthat testing is being carried out inthe proper manner and includes theproper equipment and components.This also includes the maintenanceof proper documentation.Calibration/calibration-driftassessment. LDAR monitoringequipment should be calibrated inaccordance with Method 21. Cali-bration-drift assessment of LDAR

monitoring equipment should bemade at the end of each monitor-ing work shift using approximately500 ppm of calibration gas. If, after

the initial calibration, drift assess-ment shows a negative drift of morethan 10% from the previous cali-bration, all components that weretested since the last calibrationwith a reading greater than 100ppm should be re-tested. Re-test allpumps that were tested since thelast calibration having a reading ofgreater than 500 ppm.

Records maintenance. Internalelectronic record-keeping and re-porting is an essential component to

a well-implemented LDAR program.It is an indication to the NEIC thatevery effort is being made to complywith the regulations pertinent to afacility. It provides ready access tothe personnel associated with theprogram, the test data, leak repairreports and so on.

Testing for leaksResults, when using a leak detec-tion monitor, are only as accurateas its calibration and the manner in

which it is used. Calibration is dis-cussed in the next section, Method21. To use the monitor correctly, theauditor will need to place the nozzleor end of the probe as close as pos-sible to the flange, threaded joint, orseal interface as follows: In the case of a flange joint test:

180 deg around perimeter of theflange joint at their interface

In the case of a threaded joint test:180 deg around perimeter of inter-face of the male/female fit-up

If it is a coupling threaded at bothends, check both ends 180 degaround the perimeter

If it is a threaded union, thencheck both ends and the body nut180 deg around the perimeter

In the case of a valve test:180 deg around perimeter ofall end connections if anythingother than welded180 deg around perimeter ofbody flange180 deg around perimeter ofbody/bonnet interface180 deg around perimeter ofstem packing at stem


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In the case of a rotating equipment

shaft seal test: 180 deg around theperimeter of the interface of theseal and the shaft

Method 21Method 21, under 40 CFR Part 60,

Appendix A, provides rules withrespect to how VOCs are moni-tored and measured at potentialleak points in a facility. Those po-tential leak points include, but arenot limited to: valves, flanges andother connections; pumps and com-

pressors; pressure-relief devices;process drains; open-ended valves;pump and compressor seals; de-gassing vents; accumulator vessel

vents; agitator seals and access doorseals. It also describes the requiredcalibration process in setting up themonitoring device. Essentially anymonitoring device may be used aslong as it meets the requirementsset forth in Method 21.

Cylinder gases used for calibrat-ing a monitoring device need to be

certified to be within an accuracyof 2% of their stated mixtures. It isrecommended that any certificationof this type be filed in either digitalform or at the very least as a hardcopy. There should also be a speci-fied shelf life of the contents of thecylinder. If the shelf life is exceeded,the contents must be either re-ana-lyzed or replaced.

Method 21 goes on to define howto test flanges and other joints, aswell as pump and compressor sealsand various other joints and inter-faces with the potential for leaks.There are two gases required for

calibration. One is referred to as a

zero gas, defined as air with lessthan 10 ppmv (parts per millionby volume) VOC. The other cali-bration gas, referred to as a refer-ence gas, uses a specified referencecompound in an air mixture. Theconcentration of the reference com-pound must approximately equalthe leak definition specified in theregulation. The leak definition, asmentioned above, is the thresholdstandard pertinent to the govern-ing regulation.

Monitoring devicesA portable VOC-monitoring devicewill typically be equipped with arigid or flexible probe. The end ofprobe is placed at the leak inter-face of a joint, such as a flange,threaded connection or coupling,or at the interface of a pump, com-pressor, or agitator seal where itinterfaces with the shaft. With itsintegral pump, the device, whenswitched on, will draw in a contin-

uous sample of gas from the leak-interface area into the monitoringdevice. The instruments responseor screening value is a relativemeasure of the samples concentra-tion level. The screening value isdetected and displayed in parts permillion by volume, or if the instru-ment is capable and the degree ofaccuracy needed, in parts per bil-lion by volume (ppbv).

The detection devices operate ona variety of detection principles.The most common are ionization,infrared absorption and combus-tion. Ionization detectors operate

by ionizing a sample and then mea-suring the charge (that is, numberof ions) produced.

Two methods of ionization cur-

rently used are flame ionizationand photoionization. The flame ion-ization detector (FID) theoreticallymeasures the total carbon contentof the organic vapor sampled. Thephotoionization detector (PID)uses ultraviolet light to ionize theorganic vapors. With both detec-tors, the response will vary withthe functional group in the organiccompounds. PIDs have been used todetect equipment leaks in processunits in SOCMI facilities, particu-

larly for compounds such as form-aldehyde, aldehydes and other oxy-genated chemicals that typically donot provide a satisfactory responseon a FID-type unit.

Operation of the non-dispersiveinfrared (NDIR) detector is basedon the principle that light absorp-tion characteristics vary dependingon the type of gas. Because of this,NDIR detection can be subject tointerference due in large measureto such constituents as water vapor

and CO2, which may absorb lightat the same wavelength as the tar-geted compound. This type of detec-tor is typically confined to the de-tection and measurement of singlecomponents. Because of that pro-clivity, good or bad, the wavelengthat which a certain targeted com-pound absorbs infrared radiation,having a predetermined value, ispreset for that specific wavelengththrough the use of optical filters. Asan example, if the instrument was

set to a wavelength of 3.4 microm-eters, the device could detect andmeasure petroleum fractions, suchas gasoline and naphtha.

The combustion-type analyzer isdesigned to measure either thermalconductivity of a gas or the heat pro-duced as a result of combustion of thegas. Referred to as hot-wire detectorsor catalytic oxidizers, combustion-type monitors are nonspecific forgas mixtures. If a gas is not readilycombustible, similar in compositionto formaldehyde and carbon tetra-chloride, there may be a reduced re-sponse or no response at all.

160,000

140,000

120,000

142,7

09

2002 2003 2004 2005 2006

Fiscal year

National Cleanup Backlog

2007 2008 2009 2010 2011

136,2

65

129,8

28

191,2

42

113,9

19

108,7

66

102,7

98

100,1

65

93,1

23

87,983

100,000

80,000

Natio

nalbacklog

(confirmedreleas

es,cleanupscompleted)

60,000

40,000

20,000

0

FIGURE 1. Progress is slowly being made to clean up leaking underground storagetanks under the RCRA program


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Cover Story


Due to the variability in the sen-sitivity of the different monitoringdevices, the screening value doesnot necessarily indicate the actual

total concentration at the leak in-terface of the compound(s) beingdetected. The leak interface is theimmediate vicinity of the jointbeing tested the point at whichthe end of the probe is placed. Re-sponse factors (RFs), determinedfor each compound by testing ortaken from reference sources, thencorrelate the actual concentrationof a compound to that of the con-centration detected by the moni-toring device. As mentioned previ-

ously, the monitoring device mustfirst be calibrated using a certifiedreference gas containing a knowncompound at a known concentra-tion, such as that of methane andisobutylene. RFs at an actual con-centration of 10,000 ppmv havebeen published by the EPA in adocument entitled Response Fac-tors of VOC Analyzers Calibratedwith Methane for Selected OrganicChemicals.

Method 21 requires that any se-

lected detector meet the followingspecifications: The VOC detector should respond

to those organic compounds beingprocessed (determined by the RF)

Both the linear response rangeand the measurable range of theinstrument for the VOC to bemeasured and the calibration gasmust encompass the leak defini-tion concentration specified in theregulation

The scale of the analyzer meter

must be readable to 2.5% ofthe specified leak definitionconcentration

The analyzer must be equippedwith an electrically driven pumpso that a continuous sample isprovided at a nominal flowrate ofbetween 0.1 and 3.0 L/min

The analyzer must be intrinsi-cally safe for operation in explo-sive atmospheres

The analyzer must be equippedwith a probe or probe extensionnot to exceed 0.25 in. outside di-ameter with a single end openingfor sampling

Federal regulations

There are federal regulations thatpertain to monitoring for VOCsand require the implementation ofa formal LDAR program in concertwith the rules of Method 21. Thereare other federal regulations thatrequire the rules of Method 21, butdo not require a formal LDAR pro-gram. Tables 2 and 3 list those vari-ous regulations.

It is the manufacturers responsi-bility to make the proper determina-tion as to what regulations it needsto comply with. Those specific regu-lations, coupled with the Method 21requirements, will define the LDAR

program and help establish a com-

prehensive and detailed procedure.

RCRAThe Solid Waste Disposal Act of1965 was amended in 1976 to in-clude the Resource Conservationand Recovery Act (RCRA), whichencompassed the management ofboth hazardous waste and solidwaste. Prompted further by an everincreasing concern of undergroundwater contamination, this act wasagain amended in 1984 to addressunderground storage tanks (USTs)and associated underground pipingunder Subtitle I. This Amendment

TABLE 2 FEDERAL REGULATIONS THAT REQUIRE A FORMAL LDARPROGRAM WITH METHOD 21

40 CFR Regulation Title

Part Subpart

60 VV SOCMI VOC Equipment Leaks NSPS

60 DDD Volatile Organic Compound (VOC) Emissions from the Poly-mer Manufacturing Industry

60 GGG Petroleum Refinery VOC Equipment Leaks NSPS

60 KKK Onshore Natural Gas Processing Plant VOC EquipmentLeaks NSPS

61 J National Emission Standard for Equipment Leaks (FugitiveEmission Sources) of Benzene

61 V Equipment Leaks NESHAP

63 H Organic HAP Equipment Leak NESHAP (HON)

63 I Organic HAP Equipment Leak NESHAP for Certain Processes

63 J Polyvinyl Chloride and Copolymers Production NESHAP

63 R Gasoline Distribution Facilities (Bulk Gasoline Terminals andPipeline Breakout Stations)

63 CC Hazardous Air Pollutants from Petroleum Refineries

63 DD Hazardous Air Pollutants from Off-Site Waste and RecoveryOperations

63 SS Closed Vent Systems, Control Devices, Recovery Devicesand Routing to a Fuel Gas System or a Process

63 TT Equipment Leaks Control Level 1

63 UU Equipment Leaks Control Level 2

63 YY Hazardous Air Pollutants for Source Categories: GenericMaximum Achievable Control Technology Standards

63 GGG Pharmaceuticals Production

63 III Hazardous Air Pollutants from Flexible Polyurethane FoamProduction

63 MMM Hazardous Air Pollutants for Pesticide Active IngredientProduction

63 FFFF Hazardous Air Pollutants: Miscellaneous Organic ChemicalManufacturing

63 GGGGG Hazardous Air Pollutants: Site Remediation

63 HHHHH Hazardous Air Pollutants: Miscellaneous Coating Manufac-turing

65 F Consolidated Federal Air Rule Equipment Leaks

264 BB Equipment Leaks for Hazardous Waste TSDFs

265 BB Equipment Leaks for Interim Status Hazardous Waste TSDFs


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regulates the construction, moni-toring, operating, reporting, record-keeping, and financial respon-sibility for USTs and associatedunderground piping that handlepetroleum and hazardous fluids.

As of 2011, there were 590,104active tanks and 1,768,193 closedtanks in existence in the U.S. Of thestill active tanks, 70.9% were undersignificant operational compliance.This means that they were usingthe necessary equipment required

by current UST regulations to pre-vent and detect releases and wereperforming the necessary UST sys-tem operation and maintenance.

In 1986, the Leaking Under-ground Storage Tank (LUST) TrustFund was added to the RCRA pro-gram. The trust financing comesfrom a 0.1 tax on each gallon ofmotor fuel (gasoline, diesel or bio-fuel blend) sold nationwide. TheLUST Trust Fund provides capitalto do the following:

Oversee cleanups of petroleum re-leases by responsible parties

Enforce cleanups by recalcitrantparties

Pay for cleanups at sites wherethe owner or operator is unknown,unwilling, or unable to respond,or those that require emergencyaction

Conduct inspections and other re-lease prevention activities

In Figure 1 the progress beingmade by the program can readilybe seen. In 2002, RCRA was lookingat 142,709 LUST sites sites thatwere flagged for cleanup. Through-out the following nine years, 2002

through 2011, 54,726 of those siteswere cleaned, leaving 87,983 stilltargeted for cleanup.

Within the RCRA program thereare requirements that impact de-sign, fabrication, construction, loca-tion, monitoring and operation ofUSTs and associated undergroundpiping. The EPA has provided anumber of sites on the internet thatprovide a great deal of informationon the various CFR Parts. 40 CFRPart 260 contains all of the RCRA

regulations governing hazardouswaste identification, classification,generation, management and dis-posal.

Listed wastes are divided into thefollowing group designations: The F group non-specific source

wastes found under 40 CFR261.31

The K group source-specificwastes found under 40 CFR261.32

The P and U group discarded

commercial chemical productsfound under 40 CFR 261.33

Characteristic wastes, which exhibitone or more of four characteristicsdefined in 40 CFR Part 261 SubpartC are as follows: Ignitability, as described in 40

CFR 261.21 Corrosivity, as described in 40

CFR 261.22 Reactivity, as described in 40 CFR

261.23 Toxicity, as described in 40 CFR

261.24Table 4 provides a listing of ad-

ditional CFR parts that further

TABLE 3 FEDERAL REGULATIONS THAT REQUIRE THE USE OF METHOD 21BUT NOT A FORMAL LDAR PROGRAM

40 CFR Regulation Title

Part Subpart

60 XX Bulk Gasoline Terminals

60 QQQ VOC Emissions from Petroleum Refinery Wastewater Systems

60 WWW Municipal Solid Waste Landfills

61 F Vinyl Chloride

61 L Benzene from Coke By-Products

61 BB Benzene Transfer

61 FF Benzene Waste Operations

63 G Organic Hazardous Air Pollutants from SOCMI for ProcessVents, Storage Vessels, Transfer Operations, and Wastewater

63 M Perchloroethylene Standards for Dry Cleaning

63 S Hazardous Air Pollutants from the Pulp and Paper Industry

63 Y Marine Unloading Operations

63 EE Magnetic Tape Manufacturing Operations

63 GG Aerospace Manufacturing and Rework Facilities

63 HH Hazardous Air Pollutants from Oil and Gas ProductionFacilities

63 OO Tanks Level 1

63 PP Containers

63 QQ Surface Impoundments

63 VV Oil/Water, Organic/Water Separators

63 HHH Hazardous Air Pollutants from Natural Gas Transmission andStorage

63 JJJ Hazardous Air Pollutant Emissions: Group IV Polymers andResins

63 VVV Hazardous Air Pollutants: Publicly Owned Treatment Works

65 G CFAR Closed Vent Systems264 AA Owners and Operators of Hazardous Waste Treatment, Stor-

age, and Disposal Facilities Process Vents

264 CC Owners and Operators of Hazardous Waste Treatment,Storage and Disposal Facilities Tanks, Surface Impound-ments, Containers

265 AA Interim Standards for Owners and Operators of HazardousWaste Treatment, Storage, and Disposal Facilities ProcessVents

265 CC Interim Standards for Owners and Operators of HazardousWaste Treatment, Storage, and Disposal Facilities Tanks,Surface Impoundments, Containers

270 B Hazardous Waste Permit Program Permit Application

270 J Hazardous Waste Permit Program RCRA Standardized Per-mits for Storage Tanks and Treatment Units


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Feature Report


Cover Story

define the regulations under theResource Conservation and Recov-ery Act.

Final remarksI am fervently against overregula-tion and watch with keen interestthe unfolding debate occurring onCapitol Hill over the amendmentto the Toxic Substances Control

Act (TSCA) for example. But theimproved safety, clean air, cleanwater, and cost savings realizedfrom the CAA and RCRA programsare four major returns on invest-ment that come back to a manufac-turer from the investment in a good

leak-detection program. Whethermonitoring and repairing leaksabove ground, in accordance withthe CAA, or below ground, in accor-dance with the RCRA, it is, simplyput, just good business. As alludedto at the outset of this article, leaksin hazardous-fluid-service pip-ing systems have served, in manycases, as an early-warning indicatorof something much worse to come.

At the very least, such leaks cancontribute to air pollution, ground-

water contamination, lost productrevenue, housekeeping costs, and arisk to personnel a few things wecan all live without.

Edited by Gerald Ondrey

Author

W. M. (Bill) Huitthas beeninvolved in industrial pip-ing design, engineering andconstruction since 1965. Posi-tions have included design en-gineer, piping design instruc-tor, project engineer, projectsupervisor, piping depart-ment supervisor, engineeringmanager and president of W.

M. Huitt Co. (P.O. Box 31154,St. Louis, MO 63131-0154;

Phone: 314-966-8919; Email: [email protected]), a piping consulting firm founded in 1987.His experience covers both the engineering andconstruction fields and crosses industry linesto include petroleum refining, chemical, petro-chemical, pharmaceutical, pulp & paper, nuclearpower, biofuel and coal gasification. He has writ-ten numerous specifications, guidelines, papers,and magazine articles on the topic of pipe designand engineering. Huitt is a member of the In-ternational Society of Pharmaceutical Engineers(ISPE), the Construction Specifications Institute(CSI) and the American Society of Mechani-cal Engineers (ASME). He is a member of theB31.3 committee, a member of three ASME-BPEsubcommittees and several task groups, ASMEBoard on Conformity Assessment for BPE Certi-fication where he serves as vice chair, a member

of the American Petroleum Institute (API) TaskGroup for RP-2611, serves on two corporate spec-ification review boards, and was on the AdvisoryBoard for ChemInnovations 2010 and 2011 amulti-industry conference & exposition.

TABLE 4 RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)INFORMATION

40 CFR Part Regulation Title

260 Hazardous Waste Management System: General

261 Identification and Listing of Hazardous Waste

262 Standards Applicable to Generators of Hazardous Waste

264 Standards for Owners and Operators of Hazardous Waste Treat-

ment, Storage and Disposal Facilities

265 Interim Status Standards for Owners and Operators of HazardousWaste Treatment, Storage and Disposal Facilities

266 Standards for the Management of Specific Hazardous Wastesand Specific Types of Hazardous Waste Management Facilities

267 Standards for Owners and Operators of Hazardous Waste Facili-ties Operating Under a Standardized Permit

270 EPA Administered Permit Programs: The Hazardous Waste PermitProgram

272 Approved State Hazardous Waste Management Programs

273 Standards for Universal Waste Management

279 Standards for the Management of Used Oil

280 Technical Standards and Corrective Action Requirements forOwners and Operators of Underground Storage Tanks (UST)

281 Approval of State Underground Storage Tank Programs

282 Approved Underground Storage Tank Programs

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