Eliminating Unpermitted BWON Emissions with Low-Emission Gaskets or Sealants
The prominent leaking equipment is poorly maintained fi xed and internal fl oating roof tanks and equipment associated with oil-water separation (oil-water separators, APIs, CPIs, etc.). The standards, in § 61.643-§ 61.347, § 61.349, expressly state that WMUs must be engineered to operate with No Detectable Emissions (NDE) as indicated by an instrument reading of less than 500 ppmv VOC above background. It is therefore important to mitigate any risk of NDE with the appropriate assets.
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