Leak Detection & Repair. Supersedes: 02/07/12 (Rev. 01) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

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1 Procedure No.: PA Page: 1 of 11 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date New Procedure needed for leak detection and repair VB 07/08 01 Update to procedure per NSR Requirements MS 02/12 02 Update to reference site LDAR Plan under related AH 08/15 documents and section regarding Closed Vent Systems

2 Procedure No.: PA Page: 2 of PURPOSE 1.1. This procedure describes the Leak Detection and Repair (LDAR) program at the Port Arthur Site. The purpose of this program is to satisfy the TCEQ and EPA regulatory requirements for monitoring equipment components in VOC and VHAP service for fugitive emissions, to conduct a directed maintenance program, to maintain records, to provide required reporting and recordkeeping Fugitive emissions are losses of volatile organic compounds (VOC) and volatile hazardous air pollutants (VHAP) through the sealing mechanism that separates the process fluid in equipment from the environment. In contrast to emissions from point sources (stacks/vents), fugitive emissions emanate from a variety of non-point sources in process operations, primarily in the form of leakage Regulations were conceived to minimize exposure and detrimental effects due to fugitive emissions being dispersed from plant sites by significantly reducing leakage. The site s standards define a concentration of 500 ppm as the level at which a component is considered to be leaking. First attempts at repair of leaking components must be performed within five (5) calendar days and, if not successful, other attempts must be made so the component is repaired within fifteen (15) calendar days. 2. DEFINITIONS 2.1. Closed vent system: A system that is not open to the atmosphere and that is composed of piping, ductwork, connections, and, if necessary, flow-inducing devices that transport gas or vapor from a piece or pieces of equipment to a control device or back into the process Connector: A flanged, screwed, or other joined fitting used to connect two pipelines or a pipeline and a piece of equipment. Joined fittings welded completely around the circumference of the interface are not considered connectors for the purpose of this regulation Directed Maintenance: For all maintenance on equipment which is covered by this procedure activity must be done simultaneously by the use of an approved gas analyzer such that a minimum concentration of leaking VOC is obtained for each component being maintained.

3 Procedure No.: PA Page: 3 of DEFINITIONS cont d 2.4. Equipment: Each pump, compressor, agitator, pressure relief device, sampling connection system, open-ended valve or line, valve, connector, product accumulator vessel, and instrumentation system in organic hazardous air pollutant or volatile organic compound service; any control device required to comply with the regulation First attempt at repair: To take action for the purpose of stopping or reducing leakage of organic material to the atmosphere In gas/vapor service: Equipment in organic HAP or VOC service, which contains a gas or vapor at operating conditions In heavy liquid service: Equipment in organic HAP or VOC service, which is not in gas/vapor service or light liquid service In light liquid service: Equipment in organic HAP or VOC service which contains a liquid that meets the following conditions: The vapor pressure of one or more of the organic hazardous air pollutants is greater that 0.3 kilopascals ( psi) at 20 C. The total concentration of the pure organic constituents having a vapor pressure greater than 0.3 kilopascals ( psi) at 20 C is equal to or greater than 20 percent by weight of the total process stream. The fluid is a liquid at operating conditions In liquid service: A piece of equipment in organic HAP or VOC service which is not in gas/vapor service In organic hazardous air pollutant service OR in organic HAP service: Equipment that either contains or contacts a liquid or gas that has at least a 5 percent by weight total organic hazardous air pollutant components on an annual average basis Instrumentation system: A group of equipment components used to convey a sample of process fluid to analyzers and instruments for the purpose of determining process-operating conditions (e.g., composition, pressure, flow, etc.). Only valves nominally 0.5 inches and smaller, and connectors nominally 0.75 inches and smaller in diameter can be considered instrumentation systems. Valves and connectors greater than the specified nominal sizes are not considered part of instrumentation systems and must be monitored individually.

4 Procedure No.: PA Page: 4 of DEFINITIONS cont d LAER Directed Maintenance: Lowest Achievable Emission Rate fugitive monitoring program. The Directed Maintenance F.E. program specified by the TCEQ in the Port Arthur NSR permits Liquids dripping: Any visible leakage from the seal including dripping, spraying, misting, clouding, and ice formation. Indications of liquid dripping include puddling or new stains that are indicative of an existing evaporated drip Method 21: EPA guideline on monitoring including procedures and instrumentation Open-ended valve or line: Any valve, except pressure relief valves, having one side of the valve seat in contact with process fluid and one side open to atmosphere, either directly or through open piping Organic hazardous air pollutant (Organic HAP or OHAP): Any of the 112 chemicals listed in Appendix A of this Site Procedure Sampling connection system: An equipment assembly within a process unit used during periods of representative operation to take samples of the process fluid. Equipment used to take non-routine grab samples is not considered a sampling connection system Screwed connector: A threaded pipe fitting where the threads are cut on the pipe wall, and the fitting requires only two pieces to make the connection Shutdown: The cessation of operating, a reactor, a distillation unit, or the emptying and degassing of a storage vessel Source: Any set of emission points located within a contiguous area under common control that emits or has the potential to emit organic HAPs or VOCs Volatile organic compound (VOC): Any compound of carbon or mixture of carbon compounds, excluding: carbon dioxide, carbonic acid, carbon monoxide, ethane and methane

5 Procedure No.: PA Page: 5 of DEFINITIONS cont d Acronyms CAA: Clean Air Act CD: Control device CFR: Code of Federal Regulations CVS: Closed vent system EPA: Environmental Protection Agency FE: Fugitive Emissions HAP: Hazardous air pollutant HON: Hazardous organic national emission standards for hazardous air pollutants LDAR: Leak detection and repair NESHAP: National emission standards for hazardous air pollutants NSPS: New source performance standards OHAP: Organic hazardous air pollutant OEL: Open Ended Lines OVA: Olfactory, Visual, and Audio SOCMI: Synthetic organic chemical manufacturing industry 3. SCOPE 3.1. Compliance Requirements Summary Fugitive Emissions New Component Monitoring will be performed within the first 15 days of being placed into service per NSR permit requirements. This monitoring will be performed by an approved monitoring contractor New Component re-monitoring will be performed within the first month This monitoring will be performed by an approved monitoring contractor Quarterly Monitoring or if a leak is discovered monitoring will be performed the following month Monitor all components that are scheduled Semi-Annually Monitor all components that are scheduled

6 Procedure No.: PA Page: 6 of SCOPE cont d 3.1. Compliance Requirements Summary cont d For Leaker Repair As Needed 1 st attempts of repair. Directive Maintenance Follow up monitoring, as required. Follow up documentation of leakers Operations Personnel Daily Visual inspection of fugitive emission components. Report leaks to the F.E. Contractor or Shift Coordinator Open Ended Line Inspections If any Open Ended Lines are found they must be reported to the Fugitive Emissions contractor for documentation. The discovered Open Ended Line must be plugged, capped, or blinded immediately As Needed Ensure leaks are repaired within the 5 day 1 st attempt and the 15 day repair timing. 4. PROCEDURE 4.1. Maintenance Concerns All maintenance is done by directed maintenance (TCEQ LAER program) First attempts to repair must be made within 5 calendar days and the component re-monitored. If not repaired with the first attempt so that the TVA reading is less than 500 ppm, the component must be repaired and re-monitored within 15 calendar days. The 15 days is from the initial leak date.

7 Procedure No.: PA Page: 7 of PROCEDURE cont d 4.1. Maintenance Concerns cont d If an olfactory, visual or audible leak is discovered from any component, it must be monitored with an TVA within 5 days. Repairs and re-monitoring must be complete within 15 days Components that are not in service but still containing process fluid must be monitored along with the other components If the repair of a component would create more emissions than the repair would eliminate, the repair may be delayed until the next shutdown. Pumps must be repaired within 6 months even if a plant shutdown is not scheduled within this time frame Except for safety pressure relief valves, no valves shall be installed or operated at the end of a pipe or line containing VOC unless the end of a pipeline is sealed with a second valve, a blind flange, a plug or a cap. The sealing device may be removed only while a sample is being taken or during maintenance operations, and when closing the line, the upstream valve shall be closed first New and reworked valves and piping connections shall be so located to be reasonably accessible for leak checking during plant operation. Valves elevated more than two meters above a support surface will be considered non-accessible New and reworked piping connections shall be welded or flanged. Screwed connections are permissible only on new piping smaller than two inches in diameter After completion of any job all Open Ended Lines must be capped, plugged, or blinded.

8 Procedure No.: PA Page: 8 of PROCEDURE cont d 4.2. Recordkeeping Closed Vent Systems A. Design Requirements must be recorded and kept in a readily accessible location: Detailed schematics, design specifications, and piping and instrumentation diagrams. The dates and descriptions of any change in the design specifications. A description of the parameter or parameters monitored to ensure that control devices are operated and maintained in conformance with their design and an explanation of why that parameter was selected for the monitoring. Periods when the closed vent system and control devices are not operated as designed, including periods when a flare pilot light do not have a flame. Dates of startups and shutdowns of the closed vent systems and control devices. B. This information must be retained and updated and be available if an inspector requests to see it. C. Please see the site LDAR Plan for details regarding closed vent system inspections Other Recordkeeping Requirements The following lists are created one time to be kept on file by the F.E. Contractor and then updated as changes are made. After the initial task of building the lists, they must be maintained to include all new or deleted items: A list of tag #'s for components in a closed vent system. This list must be signed by your unit designated person A list of tag #'s for pressure relief devices. A list of tag #'s for equipment in vacuum service. "In vacuum service" means that equipment is operating at an internal pressure which is at least 5 kpa below ambient pressure. A list of unsafe to monitor valve tag #'s. A list of difficult to monitor valve tag #'s. A list of pumps in VOC service.

9 Procedure No.: PA Page: 9 of NOTE: These lists are kept electronically and they are maintained by the F.E. Contractor. 4. PROCEDURE cont d 4.4. Federal Title 40 Part 60 Subpart VV NSPS Exemptions Equipment in vacuum service Pumps equipped with dual mechanical seal systems that include a barrier fluid system that is not in VOC service Compressors with a seal system that includes a barrier fluid system with sensors, or are equipped with a closed vent system Liquids with a vapor pressure less than 0.3 kpa at 20 C In mixtures, the total concentration of the pure components having a vapor pressure greater than 0.3 kpa at 20 C is less than 20 % by weight Training & Document Management Training Requirements A. Affected personnel will be trained initially on this program. Refresher training will be provided as needed and this procedure is available to all for review. 5. RESPONSIBILITIES 5.1. Port Arthur Site Responsibilities Furnish Fugitive Emission (F.E.) contractor with updated P&IDS and Line/Drum chemical speciation. Please note the recordkeeping requirements Furnish F.E. contractor a list of all pumps and what type they are, such as dual seal with barrier fluid. They will inspect pumps weekly and maintain documentation of the inspection in each area. Keep records for three years; send the records to the EHS Specialist as requested Inspect Pump/Flanges weekly. No documentation is necessary unless a leak is discovered. Immediately contact the F.E. contractor if a leak is observed.

10 Procedure No.: PA Page: 10 of RESPONSIBILITIES cont d Under the LAER Directed Maintenance program, all repairs that are made, with the exception of replacement or new equipment, must be done with the F.E. Contractor present for immediate re-monitoring Operations or F.E. Contractor will perform a first attempt repair at the time of monitoring on components that are found leaking. The repaired component will be re-monitored at that time. F.E. Contractor will perform first attempts according to the IPR EMS First Attempt Procedure ONLY Repair any leakers that were not repaired with the first attempt within 15 calendar days Communicate to the F.E. contractor the method of repair and the date repaired for all leakers within 15 days If leaking components are placed on a shutdown list, inform the F.E. Contractor and sign the shutdown form stating the reason why. The F.E. contractor will NOT place any component on the shutdown list without Port Arthur staff approval EHS Manager Responsibilities The EHS Manager has overall responsibility for this program but can delegate the oversight of the F.E. Contractor program to one or more of the EHS Specialists. Be familiar with the regulations concerning fugitive emissions. Stay abreast of forthcoming Fugitive Emissions issues. Act as consultant to the site on Fugitive Emissions questions. Retain Report for three years for regulatory review.

11 Procedure No.: PA Page: 11 of RESPONSIBILITIES cont d 5.3. Fugitive Emissions Monitoring Contractor Responsibilities Furnish Port Arthur Specific trained personnel. Furnish monitoring instruments and calibration gasses. Calibrate TVA daily according to Method 21. Certify TVAs quarterly. Maintain records of calibrations and certifications. Upload and download from computer all components being monitored. Monitor for fugitive emissions according to Method 21. Interface with Operations for additions and deletions of VOC components, which require tagging so that the component lists stay up to date. Manage monitoring data, component lists, shutdown lists, repair logs, etc. to ensure compliance. Interface with EHS Manager/Maintenance for getting repairs completed within required time limit. Re-monitor to ensure leaking component is repaired. First attempt remonitoring immediately after first attempt at repair is done to be no later than five days. Re-monitoring for other repaired components within 15 calendar days. Furnish leaker and shutdown tags. Furnish EHS designee with all Semi-Annual reports of all monitoring for the previous six months. Assure that all new components be monitored within the first 30 days of its initial service. Must supply the environmental department with annual speciated totals Document Management The F.E. Contractor will supply all forms necessary to document fugitive monitoring and maintain the completed forms and required reports This procedure will be reviewed and updated as needed at least every three (3) years. 6. RELATED DOCUMENTS PA A List of Hazardous Air Pollutants (HAP) PA B Visual Leak Control Chart PA C Leak Detection And Repair Process Site Leak Detection and Repair (LDAR) Plan