Guidelines for Implementation of Alternative Standards
NSPS Subpart VV, GGG, and KKK
(Valves in gas/vapor and light liquid service)

There are two alternative standards for valves in Subpart VV (which are also referenced in Subparts GGG and KKK), one of which may be chosen instead of monthly monitoring.

I. Allowable percentage of valves leaking (Section 60.483-1)

1. Owner or operator must initially notify the Administrator that he has elected to comply with the allowable percentage of valves leaking ninety days before implementing the alternative standard.

Leak percentage cannot be greater than 2.0 percent with the percentage determined by dividing the number of valves for which leaks are detected by the number of valves in gas/vapor and light liquid service within the affected facility.

2. Performance tests must be conducted initially upon choosing this option and then annually thereafter.

3. Results of a performance test indicating a number of leaking valves greater than 2.0 percent is viewed similarly to a failed stack test - it is an enforceable violation.

This provision is the quickest way to get to annual monitoring - but it carries some risk.

II. Skip Period leak detection and repair (Section 60.483-2)

1. An owner or operator must notify the Administrator of the alternative work practice selected 90 days before implementing either of the alternative work practices.

2. An owner or operator must initially comply with the normal provisions of Section
60.482-7.

This requirement is that all valves must be monitored monthly except that any valve for which a leak is not detected for two successive months may be monitored the first month of every quarter, beginning with the next quarter. (This is then referred to as the quarterly leak detection period.)

3. Then by Section 60.483-2, the owner or operator may elect to comply with one or the other of the two work practice options.

OPTION 1 - If after two consecutive quarterly leak detection periods, less than 2.0 percent of the total valves are leaking, then one of the quarterly leak detection periods may be skipped and reports made semi-annually. (This is basically six full months of monitoring before switching to semi-annual.)

OPTION 2 - If after five consecutive quarterly leak detection periods less than 2.0 percent of the total valves are leaking, then three quarterly leak detection periods may be skipped and reports made annually. (This is basically 15 full months of monitoring before switching to annual.)

4. In either case, the owners must keep a record of the percent valves found leaking during each leak detection period. If the percent leaking is greater than 2.0 percent, then the owner must return to monthly monitoring but can again elect to use the alternative work practices (starting from scratch again).

5. An owner or operator cannot utilize option one (semi-annual) and then go to option two (annual) without first going back to five consecutive monitoring periods.

6. The alternative standards options are applicable only to valves - pumps, compressors, and relief devices remain subject to the provisions of Section 60.487.

This provision requires a longer period of time to get to semi-annual or annual monitoring, but holds no enforcement risk.

DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION

VOC MONITORING SUMMARY REPORT
INSTRUCTION SHEET

GENERAL: The initial report is due six months after start-up of the affected facility. Summary reports are then due semi-annually thereafter.

SECTION I: Complete as indicated for the reporting period.

SECTION II: Complete as indicated.

SECTION III: Summarize leak checks as indicated for each month of the six month period. For example, if 6 valve leaks were identified and all were repaired, then Section II(c) would read 6 and Section II(d) would read 0. If, however, of the 6 valve leaks, two were not repaired within 15 calendar days, then Section II(d) would read 2 and the reasons would be identified in Section V.

SECTION IV: Complete as indicated.

SECTION V: Complete as indicated: Certain repair delays are allowed according to Section 60.482-9 of Subpart VV (referenced from Subpart KKK ) if process shut-downs are not feasible. This section should reference these reasons. A delay code can be used if a code explanation sheet is included. For example:

ISO - May be used to indicate that leaking equipment is isolated and not in process service.

SECTION VI: Identify equipment whose exempt status has changed and the reason for the change referencing the appropriate section of the subpart. For example: A pump equipped with a closed vent system capable of transporting any leakage to a control device is exempt per Section 60.482-2(f) of Subpart VV.

SECTION VII: Identify equipment changes, additions, or deletions that occur since the initial report was submitted.

SEMI-ANNUAL SUMMARY REPORT
VOC MONITORING

I. GENERAL INFORMATION