Regulations for FEMS

Establish a rule definition for use by the FEMS Smart System to set monitoring frequencies on the Rule Definition form. Rule definitions are based on regulations. One or more rule definition can be established for each regulation. The combination of the following values defines one unique rule definition:

Just one rule definition should match exactly on these values to avoid conflicting rule applications and to receive maximum performance from the FEMS Smart System.

Include the corresponding leak definition and monitoring and repair requirements in the rule definition. For example, under NSPS, some pumps in light liquid service have a leak definition of 10,000 ppm and must be monitored with an analyzer monthly and visually inspected weekly. If leaking, a repair attempt must be made within five days.  

Each rule definition must be assigned an effective date, which may or may not be the same date as the promulgation date entered on the Regulation Name form. (Effective dates allow you to maintain regulations that have been updated for historical reporting and recordkeeping.) The FEMS Smart System uses the most recent version of the rule definition based on the effective date.

For instruction on how to enter rule definitions, click the following links or use the scroll bar to scan the page.

Establishing Rule Definitions for FEMS Smart System

Component Rule Criteria

To Establish Rule Definitions

Maintenance Frequency Level for Component-Based Rule Criteria

Selecting Equipment Types for Rule Definitions

Aggregate Rule Criteria

Entering Instrument and Visual Inspection Criterion for a Regulation

To Enter Component Leak Criteria for Rule Definitions

Adding General Information for Rule Definitions

Assigning Leak Percentage Calculation Options for Rule Definitions

Defining Phase-In Requirements for Rule Definitions

Defining Repair and Re-monitoring Requirements for Rule Definitions

Entering Rule Criteria for Rule Definitions

 

Tip:  Before beginning, make sure to establish a complete list of the regulations applicable to your facility on the Regulation Name form.

Establishing Rule Definitions for FEMS Smart System

To set up an entity-specific rule definition, establish a new regulation name and select it when setting up the rule definition. For example, assume the "TX Reg V" regulation applies to all the components at your Texas facilities and you want to set up a rule definition for your Houston facility only.

  1. Establish the new regulation name, "TX Reg V - Houston Facility" on the Regulation Name form.

  2. Select the "TX Reg V - Houston facility" regulation when setting up a rule definition.

A copy feature is available for establishing a new rule definition. Change the data that differs from the original (such as the regulation name) to uniquely identify the rule definition.

Assign the rule definition to the components it applies to in the Regulations section of the Tag form. Use the Update Tag Regulations form to assign applicable regulations to groups of components.

The Equipment Category, Equipment Type and Chemical State values defined for the rule definition must match the values defined for the component in order for the system to determine monitoring frequencies for the component based on the rule definition. Use the Tag form to assign equipment categories, equipment types and chemical states to components.

A PPM leak definition and initial frequency must be specified so the system can evaluate the component for compliance. Optional rule definition settings are described below:

For more information about optional rule definition settings, refer to Rule Criteria Processing.

To establish rule definitions

Tip:  Establish regulation names for rule definitions on the Regulation Name form and assign the applicable regulations to each component on the Tag form prior to adding rule definitions. Ensure the Equipment Category, Equipment Type and Chemical State values assigned to each component on the Tag form match the values defined for the rule definition. Use the Update Tag Regulations form to assign applicable regulations and values to groups of components.

  1. Click Data Entry > Regulations > Rule Definition in the Navigation Tree.

    The Rule Definitions list appears.

  2. Click the New button.

    The Rule Definition form is displayed.

  3. Select a Regulation Name for the rule definition from the list.

    Once the rule definition is saved, the regulation name cannot be changed.

  4. Click the Calendar button to change the Effective Date when necessary.

    The current date is the default. The FEMS Smart System uses the most recent version of the rule definition based on the effective date.

  5. Select an Equipment Category from the list.

    The equipment category selected here must match the equipment category for all components associated with the rule definition. Otherwise, the rule definition will not be evaluated for a component with a non-matching equipment category even when the rule definition has been assigned to the component.

  6. Click the check box for all Chemical States (Light Liquid, Heavy Liquid, or Vapor) that apply to the rule definition.

    The chemical states selected here must match the chemical states for all components associated with the rule definition. Otherwise, the rule definition will not be evaluated for a component with a non-matching chemical state even when the rule definition has been assigned to the component.

  7. Expand the Equipment Types section when necessary and select an Equipment Types Option.

    The equipment types associated with the equipment category selected have been automatically added to this section. Select specific equipment types by choosing the Available Equipment Types and clicking the right arrow button. Remember, the equipment types selected here must match the equipment types for all components associated with the rule definition. Otherwise, the rule definition will not be evaluated for a component with a non-matching equipment type even when the rule definition has been assigned to the component.

    Tip:  You can remove an equipment type from the Selected Equipment Types list by selecting it and clicking the left arrow button.

  8. Enter additional information in the General Information, Phase-In Requirements, Rule Criteria, Component Leak Criteria, Leak Percentage Calculation Options, Repair Requirements, and Re-monitoring Requirements sections.

  9. Click the Save button on the form.

  10. Repeat steps 2 through 9 to add other rule definitions.

Selecting Equipment Types for Rule Definitions

An equipment type is a specific classification within an equipment category. For instance, under the equipment category of valves, equipment types are butterfly, gate, or control. Equipment categories and types are assigned to components on the Tag form. The equipment types for each component associated with a rule definition must be defined in the Equipment Types section of the Rule Definition form. Otherwise, the rule definition will not be evaluated for the component when the FEMS Smart System determines monitoring frequencies.

To select equipment types

  1. Locate the regulation on the Rule Definition list, click the link to open the Rule Definition form, and expand the Equipment Types section, if necessary.

  2. Assign either All Equipment Types to use all of the equipment types for the rule definition or Only the Equipment Types Selected Below... to view the equipment types and to choose specific equipment types for the rule definition by clicking the appropriate option.

  3. Select the desired types from the Available Equipment Types list and click the right arrow button.  

    Tip:  Use the CTRL or SHIFT keys on the keyboard to select multiple types. You can remove an equipment type from the Selected Equipment Types list by selecting it and clicking the left arrow button.

  4. Click Save on the Rule Definition form.

Entering Instrument and Visual Inspection Criterion for a Regulation

Document the leak definition a regulation requires to be used when determining if components in a particular equipment category and chemical service are leaking in the General Information section on the Rule Definition form. Leak definitions are the maximum concentration at which a material can be found to be leaking. For example, the leak definition specified by NSPS for valves in light liquid or vapor is 10,000 ppm by volume.

Leak definitions are important for determining components' regulatory compliance. When assigning the applicable regulation(s) to each component, the system determines from these regulations what the lowest leak definition is. For example, if a federal regulation imposes a leak definition of 500 ppm, and a state regulation specifies a leak definition of 1,000 ppm for the same type of component, the system assumes 500 ppm is the lowest leak definition. The benefit is it can compare the "worst case" leak definition against monitoring data collected to ensure compliance with every applicable regulation.

Note:  Leak definitions for Closed Vent System (CVS) and No Detectable Emissions (NDE) are also considered when determining the lowest leak definition.

If entering regulatory requirements for an equipment category that must be visually inspected, indicate the frequency at which the visual inspection must be performed. For example, NESHAP requires visual inspection of certain pumps on a weekly basis. This information helps to schedule runs.   

Adding General Information for Rule Definitions

The General Information section on the Rule Definition form is used to define regulatory monitoring (instrument inspection) and visual inspection criteria. A leak definition and initial frequency are required for both compliance methods. A separate leak definition and frequency can be specified for CVS and/or NDE components. Typically, when a visual inspection is required, regulatory monitoring is also required. Even in cases where a visual inspection is the only requirement, a technician who sees a component visually leaking might quantify the leak with an analyzer and enter instrument readings. The system needs a leak definition and initial frequency to determine if the component is in compliance.

For regulatory monitoring, separate frequencies for components identified as Unsafe to Monitor and Difficult to Monitor can be defined. A calendar- or skip period-based approach for determining monitoring periods can be specified in the General Information section. The FEMS Smart System uses the approach specified when evaluating monitoring performance against rule criteria and when setting dates for frequency changes. For more information about both types of approaches, refer to Calendar- and Skip Period-Based Approach for Monitoring Periods.

All of the frequencies entered can be used to automatically determine the initial frequency for tags associated with the regulation. Refer to Initial Monitoring Frequency Determination for additional information.

For visual inspections, define the inspection method and frequency, as well as the number of days allowed to attempt an inspection and to repair a leak. The FEMS Smart System assigns the frequency specified to the components that require visual inspections. Frequencies can be viewed in the Compliance section of the Tag form.

To add general Information for a rule definition

  1. Locate the regulation on the Rule Definition list, click the link to open the Rule Definition form, and expand the General Information section, if necessary.

  2. Enter the leak definition for the equipment category and chemical state in the Leak Definition field. This is a required field for regulatory monitoring and visual inspection compliance methods.

  3. Enter the Closed Vent System Leak Definition and/or No Detectable Emissions Leak Definition when part of the regulation.

  4. Select the Preferred Month of Quarter from the list (1, 2, or 3) to indicate which month of the quarter the monitoring event should be scheduled.

  5. Select an Initial Frequency from the list. This is a required field for regulatory monitoring and visual inspection compliance methods. (SS indicates a Smart System frequency.) The list includes the following Smart System frequencies:

  1. Select a Difficult to Monitor Frequency, an Unsafe to Monitor Frequency, a Closed Vent System Frequency, and a No Detectable Emissions Frequency from the list for each field, when applicable.

  2. Determine your facility's preference on how monitoring periods are defined for purposes of evaluating each component's monitoring performance as well as how components are scheduled for monitoring using either the Calendar and Skip Periods approaches. Click either Calendar or Skip Periods to apply the scheduling approach.

  1. Continue to step 9 to enter visual inspection criteria; otherwise, skip to step 13.

  2. Select a Visual Inspection Method from the list.

  3. Select a Visual Inspection Frequency from the list.

    If a frequency is not listed, click the Ellipsis button and add it.

  4. Enter the number of days allowed for a visual inspection in the Visual Days for attempt field.

  5. Enter the number of days allowed to repair a leaker in Visual Days to Repair field.

  6. Click the Save button on the form.

Defining Phase-In Requirements for Rule Definitions

Phase-in leak requirements can be defined for a new component that are separate from the rule definition's standard leak definition and are used when a component leaks during the phase-in period. For example, to satisfy a phase-in frequency requirement that mandates a non-leaking monitoring event for 2 consecutive months, the Monthly frequency is selected and 2 monitoring periods are specified in the Phase In Requirements section on the Rule Definition form.

The FEMS Smart System applies phase-in requirements beginning with the first full and complete monitoring period after the component's install date. Once a component meets the phase-in requirements, it is no longer considered a new component and will not be subject to phase-in criteria again (for that rule definition).

To define phase-in requirements

  1. Locate the regulation on the Rule Definition list, click the link to open the Rule Definition form, and expand the Rule Phase In Requirements section, if necessary.

  2. Select a Phase In Frequency from the list.

  3. Enter the number of consecutive monitoring Periods.

  4. Enter the Phase In Leak Definition for new components.

  5. Click the Save button on the form.

Entering Rule Criteria for Rule Definitions

In the Rule Criteria section on the Rule Definition form, indicate whether a regulation is component- or aggregate-based.

The FEMS Smart System determines which method is applicable based on the rule type specified.

Note:  For detailed information about how the FEMS Smart System uses rule criteria settings, refer to Rule Criteria Processing.

Component Rule

The number of consecutive periods required to change the frequency level from Weekly to Monthly, Monthly to Quarterly, etc. when the component's performance matches the ppm defined for the rule definition are specified in the Rule Criteria section. Consecutive periods represent the number of successive periods the component must be a non-leaker to advance to another frequency level. One instance of the following values defines component-based rule criteria:

Just one rule criteria instance can exist for each frequency defined as the current frequency. For example, once rule criteria is established for the current frequency Monthly, no other rule criteria can be defined with a current frequency of Monthly.

Maintenance Frequency Level for Component-Based Rule Criteria

A maintenance frequency level must be defined for the strictest frequency, where the current and new frequencies are equal to the strictest frequency for one consecutive period. The maintenance frequency level ensures the system will continue to apply the strictest frequency when the component's performance continues to qualify it for monitoring at the strictest frequency. If a maintenance frequency level does not exist, the initial frequency level will be applied. For example, assume the strictest frequency for a regulation is Annually and the criteria for this frequency has been defined as:

The maintenance frequency level for this example would be defined as:

If the maintenance frequency level did not exist, there would be no criteria for the system to use to evaluate the component at its current frequency, Annually. With the maintenance frequency level defined, the system can determine if the component continues to qualify for monitoring at the strictest frequency. The FEMS Smart System applies the initial frequency when no maintenance frequency criteria has been defined.

Post-Repair Frequency Levels

After a component leaks and has been repaired, the initial frequency can be applied to the component or multiple levels of frequency based on ppm readings can be defined. The ppm reading triggers the frequency setting when multiple frequency levels have been defined. For example, a frequency level can be specified to set the monitoring frequency to Monthly when the component's ppm reading is 1000 at a Weekly frequency. Another level might be defined for a ppm reading of 1000 where the beginning frequency level is Quarterly and the new frequency setting is Monthly. Still another level might be defined for a ppm reading of 500 where the beginning frequency level is Semiannually and the new frequency is Quarterly. Frequency levels are entered in the Component Leak Criteria section.

Aggregate Rule

Components may be grouped by area, subarea, or process unit for percent leaking calculations. (The grouping basis is defined in the Leak Percentage Calculation Options section.) The leak percentage that triggers a frequency change and the number of consecutive periods must be defined. Consecutive periods represent the number of successive periods the percentage of the components that are leaking must be at or below the specified leak percentage in order for the component group to advance to another frequency level. The system uses the current frequency (At Frequency) to determine consecutive periods. For example, if the current frequency is Monthly, one consecutive period is equal to one month; if the current frequency is Quarterly, one consecutive period is equal to three months.

One of the following calculation methods must also be specified for aggregate-based rule criteria:

Required Monitoring Periods

For both averaging calculation methods, a required number of monitoring periods must exist before the FEMS Smart System will evaluate the rule criteria for the component group. The following equation is used to determine required monitoring periods:

(Consecutive Periods + Rolling/Subset Average Calculation Periods) - 1 = Required Periods


The Y value is used for the Subset Average Calculation Periods.

Monitoring Periods of the Same Frequency

Both averaging calculation methods use monitoring periods of different frequencies, e.g., Monthly, Quarterly, Annually, etc., in the calculation. To specify that the periods must be of the same frequency, select the option in the Leak Percentage Calculation Options section. The calculation will be deferred until the number of monitoring periods specified are of the same frequency and the required periods exist. All other rule criteria will continue to be evaluated during the time any calculation is deferred. Using the "Periods must be of the same frequency for leak calculations" option is the equivalent of applying the strictest interpretation of the regulation.

Note:  The "Periods must be of the same frequency for leak calculations" option applies to monitoring periods only. The FEMS Smart System determines consecutive periods based on the current frequency (At Frequency).

Frequency Levels

Define successive or non-successive frequency levels for aggregate-based rules in the Rule Criteria section. Successive levels allow movement to sequential frequency levels only. Non-successive levels allow movement to other frequency levels based on performance. For more information about successive and non-successive levels, refer to Rule Criteria Processing Frequency Levels.

Maintenance Frequency Level for Aggregate-Based Rule Criteria

A maintenance frequency level must be defined for the strictest frequency, where for one consecutive period, the current and new frequencies are equal to the strictest frequency and the leak percentage that triggers a frequency change matches the one for the strictest frequency. The maintenance frequency level ensures the system will continue to apply the strictest frequency when the component group's performance continues to qualify it for monitoring at the strictest frequency. If a maintenance frequency level does not exist, the initial frequency level will be applied. For example, assume the strictest frequency for a regulation is Annually and the criteria for this frequency has been defined as:

The maintenance frequency level for this example would be defined as:

If the maintenance frequency level did not exist, there would be no criteria for the system to use to evaluate the component group at its current frequency, Annually. With the maintenance frequency level defined, the system can determine if the component group continues to qualify for monitoring at the strictest frequency. The FEMS Smart System applies the initial frequency when no maintenance frequency criteria has been defined.

Additional Leak Percentage Calculation Options

Leak calculations can be based on the total components in service in the group or just the total components monitored in the group. Repair delay or removed component credits can be applied. Define the values for these options in the Leak Percentage Calculation Options section.

To enter rule criteria

  1. Locate the regulation on the Rule Definition list, click the link to open the Rule Definition form, and expand the Rule Criteria section, if necessary.

  2. Select a Rule Type option.

    Any rule criteria already defined for the rule type selected is displayed as a line item.

  3. Click Add a new (Rule Type) Criteria.

    The Rule Criteria form is displayed.

  4. Review the Rule Criteria options and verify the appropriate one is selected.

  5. Select the beginning frequency level from the list in the At Frequency field.

  6. Enter a number that represents the leak performance percentage in the Trigger % field for aggregate-based criteria. Otherwise, leave this field blank.

  7. Enter the number of Consecutive Periods required to satisfy rule criteria before changing to the new frequency level.

  8. Select the New Frequency level from the list.

  9. Use the guidelines below to select a Calculation Method for aggregate-based criteria. Otherwise, continue to step 10.

  1. Click OK to return to the Rule Definition form.

    The rule criteria is displayed as a line item. Change existing rule criteria using the Edit button adjacent to the line item.

  2. Repeat steps 2 through 10 to add other criteria.

    Remember to add criteria for a maintenance frequency level after entering criteria for the strictest frequency.

  3. Click the Save button on the form.

Tip:  For component-based rule types, define the frequency to use when a component leaks in the Component Leak Criteria section. For aggregate-based rule types, assign options that affect leak percentage calculations in the Leak Percentage Calculation Options section.

To enter component leak criteria for rule definitions

For component-based rule types, define the frequency to use when a component leaks in the Component Leak Criteria section of the Rule Definition form. The FEMS Smart System will either use the initial frequency defined for the rule definition or determine the frequency based on the ppm reading levels specified. Follow the steps below to add ppm reading levels.

  1. Locate the rule definition on the Rule Definitions list, click the rule link to open the Rule Definition form, and expand the Component Leak Criteria section if necessary.

    This section is only available for component-based rule types, as defined in the Rule Criteria section.

  2. Select the Frequency Based on PPM Reading option.

  3. Click Add a new PPM Reading Level.

  4. Enter the PPM Reading.

  5. Select the beginning frequency level from the list in the At Frequency field.

  6. Select the New Frequency from the list.

  7. Click OK to return to the Rule Definition form.

    The component leak criteria is displayed as a line item. Change existing component leak criteria using the Edit button adjacent to the line item.

  8. Repeat steps 2 through 7 to add other levels.

  9. Click the Save button on the form.

Assigning Leak Percentage Calculation Options for Rule Definitions

For aggregate-based rule types, options that affect leak percentage calculations for process units, subareas, or areas are assigned in the Leak Percentage Calculation Options section on the Rule Definition form. The process unit option is the default. The Grouping Basis setting is combined with the regulation name, effective date, equipment category, equipment type and chemical state defined for the rule definition to determine the component group for calculating leak percentages. It is recommended that no edits be made to this setting once the rule definition has been used by the FEMS Smart System. Changing the grouping basis is the equivalent of setting up a new component group; the frequency history accumulated for the group is invalidated, the monitoring frequency is reset, and rule evaluation starts over.

Indicate whether all of the components in service in a group or just the components in a group that were monitored are to be part of the calculation and specify repair delay and removed component credits in the Leak Percentage Calculation Options section. Select the Periods must be of same frequency for leak calculations option and the calculation methods defined in the Rule Criteria section will be deferred until the number of monitoring periods specified are of the same frequency. For additional information about leak percentage calculation methods, refer to Entering Rule Criteria for Rule Definitions.

Repair Delay Credits

A credit for a component with a repair delay status in the current monitoring period that was identified as non-repairable in a prior monitoring period may be applied during the current monitoring period depending on the reason for the non-repairable status, and provided repair delay credits are allowed by the regulation. Valid repair delay reasons for repair delay credits are:

Any component initially identified as non-repairable in the current monitoring period cannot be counted as a credit during the current monitoring period.

Typically, a maximum number of credits can be applied during one monitoring period. The FEMS Smart System subtracts the number of credits, up to the maximum specified, from the number of leakers when calculating the leak percentage for aggregate-based rule criteria.

Removed Component Credits

A credit for the components removed from a component group may be applied when allowed by the regulation. The FEMS Smart System subtracts the number of components added during a monitoring period from the total number of components removed and multiplies that result by the removed component credit multiplier. The credit is added to the component group when calculating the leak percentage for aggregate-based rule criteria.

To assign leak percentage calculation options

Caution:  The Grouping Basis (areas, subareas, process units) setting is combined with the regulation name, effective date, equipment category, equipment type, and chemical state defined for the rule definition to determine the component group for calculating leak percentages. It is recommended that no edits be made to this setting once the rule definition has been used by the FEMS Smart System. Changing the grouping basis is the equivalent of setting up a new component group; the history accumulated for the group is invalidated, the monitoring frequency is reset, and rule evaluation starts over.

  1. Locate the rule definition on the Rule Definitions list, click the rule link to open the Rule Definition form, and expand the Leak Percentage Calculation Options section if necessary.

  2. Select a Grouping Basis.

    It is recommended that no edits be made to this setting once the rule definition has been used by the FEMS Smart System. Changing the grouping basis is the equivalent of setting up a new component group; the history accumulated for the group is invalidated, the monitoring frequency is reset, and rule evaluation starts over.

  3. Select the Total Components or Total Components Monitored option.

  4. Click the check box when Periods must be of the same frequency for leak calculations.

  5. Click the Allow Repair Delay Credit check box when applicable and enter the Maximum Repair Delay Credit.

  6. Click the Allow Removed Component Credit check box when applicable and enter the Removed Component Credit Multiplier.

  7. Click the Save button on the form.

Defining Repair and Re-monitoring Requirements for Rule Definitions

In the Repair Requirements section on the Rule Definition form, regulatory requirements for repairing leaking components can be defined. Typically, regulations require that an initial repair be attempted within 5 days, a full repair be made within 15 days. and the component be tagged as a leaker after a repair for 60 days. These are the default repair requirements that can be used or changed as necessary.

As an alternative, repair requirements based on PPM readings can be defined. Multiple levels can be set up for different readings.

After a leak is repaired, the following requirements can be defined for a component:

To define repair and re-monitoring requirements

  1. Locate the rule definition on the Rule Definitions list, click the rule link to open the Rule Definition form, and expand the Repair Requirements section if necessary.

    To enter re-monitoring requirements only, skip to step 8.

  2. Review the default values in the Days for First Attempt, Allowed Days to Repair and Days for Leak Tag Removal fields. Make any necessary changes.

  3. Click Add a New PPM Reading Level to set up repair requirements based on PPM readings.

    The Repair Requirement Based on PPM Reading form is displayed.

  4. Type the PPM Reading.

  5. Enter a number that represents length of time in the Time for First Attempt and Allowed Time to Repair fields, e.g., enter 1 for one hour, 2 for two days, etc. Then select a Unit of time from the list.

    If the appropriate unit is not listed, click the Ellipsis button and add it.

  6. Click OK to return to the Rule Definition form.

    The PPM repair level is displayed as a line item. Change existing repair levels using the buttons adjacent to the line item.

  7. Repeat steps 3 through 6 to add another level.

  8. Expand the Re-monitoring Requirements section to specify when a component should be monitored after it has been repaired and re-tested. Otherwise, skip to step 11.

  9. Enter the start of the re-monitoring time period by typing a number that represents length of time (e.g., 1 for one hour, 2 for two days, etc.) in the first field and selecting a unit of time from the list.

  10. Enter the end of the re-monitoring time period by typing a number that represents length of time (e.g., 1 for one hour, 2 for two days, etc.) in the last field and selecting a unit of time from the list.

  11. Click the Save button on the form.