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OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

2) ll-A-1 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 2 of 132 
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A 98.1 3, 

PRESUMPTIVE MACT FOR 

ORGANIC LIQUIDS (NON-GASOLINE) 

DISTRIBUTION FACILITIES 

JUNE 9,1998 

t 

I » l I 

Waste and Chemical Processes Group 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 
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TABLE OF CONTENTS 

Section Page 

1.0 Overview of the Presumptive MACT Determination 1-1 

1.1 Background 1-1 

1.2 Available Data 1-1 

1.3 Summary of Presumptive MACT 1 -2 

1.3.1 Affected Sources 1-2 

1.3.2 Control Levels for P-MACT 1-3 

2.0 Source Category and Affected Sources 2-1 

2.1 Stand-Alone or Separate Distribution Terminals 2-1 

2.2 Collocated Distribution Facilities , 2-2 

2.3 Pipeline Facilities 2-2 

2.4 Compounding/Blending/Packaging Facilities 2-3 

2.5 Affected Sources/Conclusions 2-4 

3.0 Emission Sources 3-1 

3.1 Storage Vessels 3-1 

3.2 Liquid Transfer Operations 3-2 

3.3 Leaks from Equipment Components 3-2 

3.4 Wastewater and Other Wastes 3-2 

3.5 Blending and Packaging Operations 3-3 

4.0 Emission Controls 4-1 

4.1 Storage Vessels 4-1 

4.2 Liquid Transfer Operations 4-1 

4.3 Equipment Components 4-1 

• 4.4 Wastewater and Other Wastes 4-1 

5.0 Current Control Levels 5-1 

5.1 Existing Levels of Control 5-1 

5.1.1 Fixed Roof Storage Tanks 5-1 

5.1.2 External Floating Roof Tanks 5-3 

5.1.3 Liquid Transfer Operations 5-5 

5.1.4 Wastewater Treatment 5-8 

5.1.5 Equipment Leaks 5-9 

5.1.6 Blending and Packaging 5-9 

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TABLE OF CONTENTS (Concluded) 

Section P_ag£ 

5.2 Federal Regulations 5-9 

5.2.1 Hazardous Organic NESHAP (HON) (subparts F, G, H, I) 5-9 

5.2.2 Petroleum Refinery NESHAP (subpart CC) 5-10 

5.2.3 Proposed Oil/Natural Gas Distribution/Transmission 

NESHAP (subparts HH.HHH) 5-10 

5.2.4 Gasoline Distribution NESHAP (subpart R) 5-11 

5.2.5 Benzene Emissions from Storage Vessels NESHAP 

(40 CFR 61, subpart Y) 5-11 

5.2.6 Marine Vessel Loading NESHAP (subpart Y) 5-11 

5.2.7 Benzene Waste Operations NESHAP (subpart FF) 5-11 

5.2.8 Benzene Transfer Operations NESHAP (subpart BB) 5-12 

5.2.9 Miscellaneous Organic NESHAP (MON) [pre-proposal] 5-12 

5.3 State/Local Regulations 5-12 

6.0 Summary of Issues and Next Steps 6-1 

6.1 Issues in the NESHAP Development 6-1 

6.2 Next Steps 6-2 

7.0 References 7-1 

Attachments 

Attachment 1 Presumptive MACT for Organic Liquids (non-Gasoline) Distribution 

Facilities (Presentation Format) 

Attachment 2 Memorandum-State Rules Summary 

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1.0 OVERVIEW OF THE PRESUMPTIVE MACT DETERMINATION 

1.1 Background 

Section 112 of the Clean Air Act (the Act) mandates that the EPA promulgate national 

emission standards for hazardous air pollutants (NESHAP) on a timely basis. In response to 

Section 112(c), the EPA published an initial list of hazardous air pollutant (HAP) source 

categories in the Federal Register on July 16,1992 (57 FR 31576). This list included Organic 

Liquids Distribution (non-Gasoline) as one ofthe categories of major sources for which 

standards were to be developed and promulgated in the year 2000. The Act further requires that 

the NESHAP for each listed source category require sources to adopt maximum achievable 

control technology (MACT) to reduce emissions of HAP. §112(d). If the EPA fails to meet this 

deadline by more than 18 months, Section 112 (j) includes a "hammer" provision requiring that 

operating permits for major sources contain HAP emission limitations determined to be 

equivalent to MACT. The equivalency determinations are to be made on a case-by-case basis for 

individual sources. 

Section 112(g) requires case-by-case MACT determinations for sources where no 

applicable emission limitations for HAP material have been established. The final rule 

governing Section 112(g) case-by-case MACT determinations for constructed or reconstructed 

sources was published in the Federal Register on December 27,1996 (61 FR 68384). This rule 

requires case-by-case MACT for new and reconstructed major sources to be consistent with "new 

source MACT'; i.e., no less stringent than the emission control that is achieved in practice by the 

best controlled similar source, as determined by the EPA Administrator. 

The source category for which standards are to be developed in this rulemaking is organic 

liquids distribution (non-gasoline). The initial source category description includes activities 

associated with the storage and distribution of organic liquids other than gasoline that have a 

HAP content. This document presents options for presumptive maximum achievable control 

technology (P-MACT) to serve as a resource for States that must make case-by-case MACT 

determinations under Section 112(g). It also provides background and support information for 

developing a rule proposal and a final NESHAP regulation. 

1.2 Available Data 

The EPA project team (EPA and EPA contractor staff) considered several available 

sources of information in preparing this P-MACT document. These included a comprehensive 

literature search and review of existing regulations, as well as meetings and other contacts with 

companies and trade organizations. In addition, an industry survey has been prepared and was 

sent in April 1998 to several companies in this industry in order to collect detailed facilityspecific information on current control practices. However, no survey results were available for 

use in reaching the P-MACT conclusions in this document. 

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The project team made site visits to three organic liquids distribution facilities in New 

Jersey and Philadelphia in December 1997, and four visits in Oklahoma and Texas in April 1998. 

Since the information obtained on these visits is being treated as confidential business 

information (CBI) pending review by the plant owners, detailed information from the visits has 

not been used to determine P-MACT. 

A comprehensive review of regulations affecting this industry was also undertaken to 

allow the team to make conclusions concerning current levels of control. The results of this 

review served as the principal source of information in developing the P-MACT levels 

summarized in the next subsection. 

Two Roundtable meetings ofthe EPA/States/industry Work Team were held, on January 

21 and March 24,1998. The second Roundtable was held to discuss comments ofthe Work 

Team on the draft P-MACT document that had been circulated for comment. Comments were 

received and subsequently incorporated into the document, which served to improve the clarity 

ofthe document and the information presented to support the P-MACT conclusions. A 

meeting/teleconference ofthe Work Team was also held on February 12,1998 to discuss the 

draft industry survey questionnaire under development within the Agency. These discussions, 

along with a number of other conversations and written communications, were used by the 

project team in completing both this document and the industry survey. 

Attachment 1 is a revised and updated version of a presentation made by the EPA at the 

first EPA/States/industry Roundtable meeting. 

1.3 Summary of Presumptive MACT 

1.3.1 Affected Sources 

The intial source category description for this project indicated that the category would 

consist of activities associated with the storage and distribution of non-gasoline liquids with 

HAP content, at sites that serve as distribution points from which organic liquids may be 

obtained for further use and processing. The EPA project team has investigated the types of 

facilities that may operate within this broad industry description. For the P-MACT effort, a 

decision was made to consider the following facility types: 

1. Stand-alone or separate liquid distribution terminals; 

2. Distribution activities collocated with petroleum refineries or chemical production 

plants; 

3. Pipeline facilities (including crude oil and natural gas liquids pipelines after the 

point of custody transfer); and 

4. Facilities that compound, mix, or blend liquids, and may package these liquids 

or blends. 

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The project team will continue to work with industry to define all ofthe specific types of 

operations that should be included in this source category. 

1.3.2 Control Levels for P-MACT 

Section 112(d) ofthe Act requires that the emission standards for new sources "shall not 

be less stringent than the emission control that is achieved in practice by the best controlled 

similar source, as determined by the Administrator." Standards for existing sources "may be less 

stringent than standards for new sources in the same category or subcategory but shall not be less 

stringent, and may be more stringent than— 

(A) the average emission limitation achieved by the best performing 12 percent ofthe 

existing sources... for categories and subcategories with 30 or more sources, or 

(B) the average emission limitation achieved by the best performing 5 sources... for 

categories or subcategories with fewer than 30 sources." 

As noted in the previous subsection, data on the control levels in effect at specific organic liquids 

distribution facilities were not available for making a presumptive MACT determination. 

However, the review of Federal, State, and local regulations currently in effect for sources in this 

category or similar categories supports the control levels in effect and therefore was used for 

selecting P-MACT. 

Based on this regulatory review and other information as discussed in Section 1.2, Table 

1-1 summarizes the preliminary P-MACT control levels for the emission sources at the affected 

facilities listed above in subsection 1.3.1. 

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TABLE 1-1. SUMMARY OF P-MACT DETERMINATIONS FOR 

ORGANIC LIQUIDS DISTRIBUTION SOURCES 

BASED ON FEDERAL, STATE, AND LOCAL AIR POLLUTION RULES 

Emission Source 

P-MACT 

New Sources Existing Sources 

I. STORAGE VESSELS 

A. Fixed Roof Tanks, 

low vapor pressure liquids 

B. Fixed Roof Tanks, high vapor 

pressure liquids 

C. Top Loaded Tanks 

D. External Floating Roof Tanks 

(General) 

E. External Floating Roof Tanks 

(Welded) 

> 10k gallons and > 1.9 psia, or 

> 20k gallons and > 1.5 psia, or 

> 40k gallons and > 0.15 psia: 

Floating roof, or closed vent 

system controlled at 95% by 

weight. 

> 11 psia: 

Pressure tank with no detectable 

emissions (NDE) or 95 % control 

by weight. No floating roofs. 

<40k gallons and > 0.5 psia: 

Install a permanent submerged fill 

pipe or perform bottom loading. 

> 10k gallons and > 1.9 psia, or 

> 20k gallons and > 1.5 psia, or 

> 40k gallons and > 0.15 psia: 

Specified roof seal and fittings 

requirements (see Section 5.1.2.1). 

> 20k gallons and > 1.5 psia, oj» 

> 40k gallons and > 0.5 psia: 

Floating roof, or closed vent system 

controlled at 95% by weight 

>25k gallons and > 11 psia: 

Pressure tank with NDE, or 95% 

control by weight. No floating roofs. 

> 580 gallons - 40k gallons and >1.5 

psia: 

Install a permanent submerged fill 

pipe or perform bottom loading. 

20k-40k gallons and > 1.5 psia, or 

> 40k gallons and > 0.5 psia: 

Specified roof seal and fittings 

requirements (see Section 5.1.2.1). 

Tanks of welded construction and < 4 psia: 

No secondary seal required if specified primary seals in use (see Section 

5.1.2.2). 

II. LIQUID TRANSFER 

A. Loading Racks, > 20k gallons 

loaded per day at entire facility 

averaged over a rolling thirty-day 

| period 

> 0.5 psia: 10 mg/liter emission 

limit; 

>1.5psia: 10 mg/liter emission 

limit or 98% emission reduction. 

>0.5 psia: 90% emission reduction. 

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TABLE 1-1. (Concluded) 

Emission Source 

P-MACT 

New Sources Existing Sources 

II. LIQUID TRANSFER (Cont.) 

B. Cargo Tank Leakage DOT test or EPA Method 27.* DOT test, possibly EPA Method 27." 

IH. EQUIPMENT LEAKS 

Pumps, Valves, and Flanges Detailed industry leak check practice data needed to make a 

determination; see Section 5.1.5. 

IV. WASTEWATER TREATMENT AND CONTROL 

A. Wastewater Storage Tanks 

B. Individual Drain Systems 

C. Oil-Water Separators 

>20k: Fixed roof required 

>20k and >1.9 psia or 

>40k and >0.75 psia: 

Fixed roof and 95% control by 

weight. 

Vapor suppression on individual 

drain system openings. 

Fixed roof and 95% control by 

weight or a floating roof. 

Detailed industry wastewater 

treatment technology data needed to 

make a determination; see Section 

5.1.4. 

V. BLENDING 

Blending Operations Detailed industry data required to make a determination; see Section 5.1.6. 

Further industry information is needed in order to determine prevalence of cargo tank testing and the relative 

stringency of DOT tests and the EPA's Method 27 (vapor tightness) testing. 

The development of these preliminary P-MACT control levels is described in Section 5 

of this document. A memorandum presenting summaries ofthe State rules reviewed for this 

document is included as Attachment 2. 

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2.0 SOURCE CATEGORY AND AFFECTED SOURCES 

In the background infonnation document (1) for the EPA's initial source category listing 

under Section 112(c) ofthe Act, a preliminary description of this source category provided that 

organic liquids distribution (non-gasoline) source category activities are associated with the 

storage and distribution of non-gasoline liquids with HAP content, at sites that serve as 

distribution points firom which organic liquids may be obtained for further use and processing. 

This description is very broad, and the rest of this section is devoted to providing more detail in 

defining the makeup of this industry. 

Facility types that the EPA project team is currently evaluating within the broad category 

description include (see also Attachment 1, page 10): 

1. Stand-alone or separate distribution terminals; 

2. Collocated distribution activities (i.e., associated with refineries or chemical plants); 

3. Pipeline facilities (including crude oil and natural gas liquids pipelines after the point 

of custody transfer); and 

4. Compounding/blending/packaging plants. 

Following is a brief discussion of each type of facility being considered within the overall 

organic liquids distribution source category. 

2.1 Stand-Alone or Separate Distribution Terminals 

Stand-alone distribution terminals are commercial bulk liquid loading terminals that 

typically have storage tanks, as well as piping and equipment to transfer the liquids. These 

terminals receive, store, and distribute organic liquids throughout the United States. Modes of 

transportation for stand-alone terminals include, but are not limited to, oceangoing tankers, tank 

barges, tank trucks, tank railcars, containers, and pipelines. The commodities handled at these 

terminals include a variety of chemicals, crude oil, fuel oils, refined petroleum products, animal 

fats and oils, and other liquids. Customers of these terminals include oil producers, chemical 

manufacturers, product manufacturers, utilities, and transportation companies. 

Many of these facilities are members ofthe Independent Liquid Terminals Association 

(ILTA), which maintains a current directory of its associated member facilities (2). Stand-alone 

terminal Standard Industrial Classification (SIC) codes fall predominantly under Major Group 

42, Industry Group Number 4220, SIC code 4226, "Special Warehousing and Storage, Not 

Elsewhere Classified." Other SIC codes identified by the EPA project team include 4491, 

"Marine Cargo Handling", 5169, "Chemicals and Allied Products, Not Elsewhere Classified," 

5171 "Petroleum Bulk Stations and Terminals," and 5172 "Petroleum and Petroleum Products 

Wholesalers, except Bulk Stations and Terminals." For a more detailed presentation of 

applicable SIC codes, refer to Attachment 1, page 14. 

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2.2 Collocated Distribution Facilities 

Many chemical and petrochemical companies and petroleum refineries may have 

distribution facilities in the form of tank farms and pipelines that are collocated (contiguous and 

under common control) with the manufacturing facilities. These distribution facilities would 

serve similar functions to those described in the stand-alone terminal source, the only difference 

being that these facilities may receive their material from the collocated plant site. HAPcontaining liquids may be stored in these facilities and then distributed via the various modes of 

delivery. 

At present, applicable SIC codes for collocated distribution facilities are thought to fall 

under the Major Group 51, which includes SIC code 5169, "Chemicals and Allied Products, Not 

Elsewhere Classified." It is conceivable that there may be some overlap in SIC codes with 

facilities regulated by the Hazardous Organic NESHAP (HON) and/or the Refinery NESHAP. A 

further determination and identification of applicable SIC codes will be performed in the future 

(see also Attachment 1, page 16). 

2.3 Pipeline Facilities 

Two types of pipelines are of interest to the organic liquids distribution source category, 

crude oil pipelines and product (non-gasoline) pipelines. Product pipelines may carry either 

refined petroleum products or liquid chemicals. The source category is considered to include 

crude oil and natural gas liquids pipeline facilities that handle and distribute non-gasoline 

hydrocarbon liquids (containing HAP) after the point of custody transfer from oil and gas 

production operations. At this time, it is believed that the principal liquid of interest at these 

facilities is crude oil, because of its significant vapor pressure and the large volumes that are 

transported. Pipeline facilities are often subsidiaries of oil and gas producing companies. 

The proposed Oil and Gas MACT rule would apply to those sources upstream from the 

point of custody transfer for crude oil and natural gas liquids pipelines. The proposed Oil and 

Gas MACT activities consist ofthe various facilities used to recover and treat hydrocarbons from 

production wells. These sources include the processing, storage, and transportation of 

hydrocarbons to the point of custody transfer. Custody transfer means the transfer of 

hydrocarbon liquids, after processing and/or treatment in the producing operations, from storage 

vessels or automatic transfer facilities to pipelines or any other forms of transportation. As 

mentioned above, the Organic Liquids Distribution MACT category is likely to include crude oil 

and natural gas liquids pipelines downstream ofthe custody transfer, as well as all other organic 

liquid pipelines. These pipelines are described as line pipe, valves, and other appurtenances 

connected to line pipe, pumping units, metering and delivery stations, and breakout tanks. 

Breakout tanks are storage vessels used to relieve surges in a pipeline or to receive and store 

crude oil transported by the pipeline for reinjection and continued transportation by pipeline. 

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Product pipelines move liquids such as gasoline, aviation gasoline, fuel oils, and other 

organic liquids from refineries or chemical plants to storage and distribution facilities/terminals 

in areas where they will be consumed or transferred. 

Applicable SIC codes for the pipeline industry primarily include Major Groups 46 and 

47, Industry Group Numbers 4610 and 4780, and the following four codes (see also Attachment 

1, page 13): 

4612 Crude Petroleum Pipelines 

4613 Refined Petroleum Pipelines 

4619 Pipelines, Not Elsewhere Classified 

4789 Transportation Services, Not Elsewhere Classified 

The first three SIC codes relate to facilities that are engaged in the pipeline transportation of 

petroleum and other liquids, and do not cover natural gas transmission. SIC code 4789 

represents independently operated pipeline terminal facilities, but also "establishments primarily 

engaged in furnishing transportation or services incidental to transportation, not elsewhere 

classified" (3). 

2.4 Compounding/Blending/Packaging Facilities 

Some distribution facilities exist that compound and blend and distribute organic liquids 

with HAP content. The EPA project team is currently attempting to identify and locate facilities 

that fall under this broad category. Many of these facilities store HAP-containing liquids, which 

they blend and package into containers ranging from 600 gallons or more to less than 1 gallon. 

Blending and packaging operations may be carried out at separate (dedicated) facilities, or they 

may be collocated with a general distribution terminal operation. (In turn, the distribution 

terminal may be collocated with a petroleum refinery or a chemical production plant; see Section 

2.2.) 

Applicable SIC codes for this industry segment primarily include Major Group 51, SIC 

code 5169, "Chemicals and Allied Products, Not Elsewhere Classified." These are 

"establishments primarily engaged in the wholesale distribution of chemicals and allied 

products" (3). Included in the SIC code listing are establishments that distribute solvents, 

aromatic chemicals, acids, and also facilities such as chemical bulk stations and terminals (see 

also Attachment 1, page 15). 

To locate and identify stand-alone facilities, the EPA project team has contacted the 

National Association of Chemical Distributors (NACD) and has reviewed the organization's 

member directory (4). Telephone interviews with and site visits to some of these facilities have 

been initiated and will be continued. The project team expects that the industry survey will 

provide information on the emissions and controls in this industry segment. 

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2.5 Affected Sources/Conclusions 

The EPA project team has decided to retain the broad description ofthe organic liquids 

distribution (OLD) source category at this point in the project so as not to inadvertently exclude 

some sources of HAP emissions. This description is expected to be improved as additional 

information is gathered on the industry. As a supplement to the general description, specific 

facility types and activities will be described in order to identify the affected sources. At this 

time, data are still being collected to identify and locate the stand-alone and collocated sources of 

interest. The team is not planning to include within the OLD rule emission sources regulated 

under the Marine Vessel Loading MACT or other existing MACT rules. 

Several existing final (and one proposed) MACT rules have been examined to determine 

the sources that would potentially be affected by the OLD standards. For example, at chemical 

manufacturing plant sites storage vessels associated with a chemical process unit are generally 

already covered by existing regulations, such as 40 CFR Part 63, Subpart F (the Hazardous 

Organic NESHAP). However, certain tanks and loading racks used to distribute liquids into or 

out ofthe same plant site are typically not covered by any MACT standard. The OLD standards 

would likely apply to such unregulated tanks and transfer operations. 

The focus ofthe project is on major sources at this time. These are defined under Section 

112 of the Act as "any stationary source or group of stationary sources located within a 

contiguous area and under common control that emits or has the potential to emit considering 

controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per 

year or more of any combination of hazardous air pollutants." The EPA's listing of HAP source 

categories showed the OLD category as a major source category, but not as an area source 

category. Under §112(c)(3), standards may be warranted for area sources in the case of a finding 

of adverse effects to human health or the environment. The EPA plans to perform a finding for 

OLD area sources as required in the Act, to determine whether they present a threat of adverse 

effects. 

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3.0 EMISSION SOURCES 

Information collected to date confirms the initial presumption ofthe EPA project team 

that emission sources at organic liquids distribution (non-gasoline) facilities are generally similar 

to emission sources in certain industries studied under previous NESHAP. Facilities with these 

similarities include petroleum refineries, chemical production plants, and bulk gasoline 

terminals. These facility types have the following emission sources in common: 

1. Storage vessels; 

2. Liquid transfer activities (loading racks); 

3. Leaks from equipment components (pumps, valves, etc.); 

4. Wastewater and waste collection and treatment; and 

5. At some facilities, blending and packaging activities may also constitute a separate 

source of emissions. 

In many cases, the source descriptions, emission estimation techniques, and control 

technology determinations made for these other standards may have applicability to OLD 

sources. This type of information is being studied for the other NESHAP industries with these 

emission sources and that may have collocated liquid distribution activities. The five categories 

of emission sources mentioned above presently are considered to be the principal OLD emission 

sources, and are described in the following sections. It should be stressed that only equipment 

and activities that are involved in the distribution of organic liquids are considered part ofthe 

category. At collocated chemical production plant sites, for example, equipment and tanks 

associated with a production process should already be regulated by existing MACT (such as the 

HON) and would therefore typically not be included as an OLD source. 

3.1 Storage Vessels 

The focus of this discussion is storage vessels that participate in liquid distribution, and 

not process tanks. Two basic categories of distribution storage vessels are found at OLD 

facilities: 

1. Storage vessels at terminals or other distribution operations, and 

2. Breakout tanks at pipeline stations. 

At stand-alone or separate liquid terminals or at distribution operations collocated with a 

production plant site (chemical production plant or petroleum refinery), storage tanks receive 

incoming organic liquids and distribute them back out ofthe facility. Modes of transport 

include: inland waterway barges, tanker (oceangoing) vessels, tank trucks, railway tankcars, and 

pipelines. 

Petroleum pipelines (discussed in Section 2.3) are used to transport crude oil and 

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petroleum products after the point of custody transfer from oil production operations. At the 

pipeline pump stations, breakout tanks are used for surge capacity, sorting, measuring, rerouting, 

and temporary storage. These breakout tanks receive liquid from the pipeline, and then reinject it 

for continued transportation by pipeline or to other terminals in the local area. 

Storage tank emissions result from breathing and working losses. Flash losses from 

crude oil may also occur; however, industry has contended that flashing is unique to the crude oil 

extraction process, where the crude is "live" and releases entrained or dissolved gases while in 

storage (5). 

3.2 Liquid Transfer Operations 

Hazardous air pollutants may be emitted from delivery vessels being loaded at a facility 

as vapors present in the tank are displaced by the incoming liquid. These emissions may consist 

of vapors remaining from a previous cargo, or may be generated from the liquid being loaded, or 

a combination of both. In controlled systems, the vapors are routed to a fixed roof storage tank 

(vapor balance system) or to a vapor control device. Fugitive (vapor leakage) emissions at 

controlled loading racks can also occur due to leakage points in the transport tank or the facility's 

vapor collection system. 

3.3 Leaks from Equipment Components 

The pumps, compressors, valves, and other equipment components in the lines that 

transport the liquids can develop liquid or vapor leaks from which HAP may be emitted. 

Emission factors have been developed for several types of facilities, and a number of Federal 

regulations address this emission source (see Section 5.2). 

3.4 Wastewater and Other Wastes 

Wastewater is generated due to tank and line cleanings, spills, liquid blending or 

packaging operations, rainwater drainage, or other sources. Wastewater is processed at some 

distribution facilities through several types of treatment systems, including clarification units and 

gravity separators. If such water is exposed to the atmosphere (in uncovered culverts, separators, 

sumps, or other collection devices), the HAP constituents in the water can be released as air 

emissions. The project team is continuing to investigate emission sources and potential controls, 

and expects to rely on the industry survey for cJata pertinent to this industry. 

Other waste containing HAP (such as semi-solid sludge) may be generated from the same 

type of sources mentioned above for wastewater, as well as other sources. This waste is often 

stored in closed containers, and then shipped offsite for treatment at a specialized off-site 

treatment facility. These wastes are also frequently regulated under existing hazardous waste 

regulations. Information is being collected on the types and amounts of semi-aqueous waste, and 

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on whether it constitutes a significant air emission source while at the distribution facility. 

3.5 Blending and Packaging Operations 

Specific HAP emission points and emission rates in liquid blending and packaging 

operations are not presently known. Furthermore, only limited data and information are 

available on the products resulting from the mixing/blending operations. It is believed that the 

transfer of liquids between containers may constitute an emission source similar to the emissions 

discussed for cargo tanks in Section 3.2. Additional sources may involve the other sources 

previously described; i.e., storage tanks, leaks from piping and equipment components, 

wastewater, and other wastes. The project team is continuing to gather information on the details 

of these operations. 

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4.0 EMISSION CONTROLS 

The emission sources discussed in Section 3 are subject to a variety of control measures, 

as mandated by existing Federal, State, and local air regulations. This section describes the 

principal emission controls that have been observed to be in use for OLD operations. Section 5 

will discuss the levels of control required under existing regulations. 

4.1 Storage Vessels 

The populations of fixed-roof and floating roof type storage vessels used within the 

organic liquids distribution industry have not yet been established. Emissions from fixed-roof 

tanks can be reduced by using a vapor control system to capture hydrocarbons that escape as 

breathing or working losses. In these systems, vapors are routed through piping to a control 

device. Another common control approach is the installation of an internal or external floating 

roof that includes seals around the perimeter and sometimes other controls on fittings to 

minimize emissions. For high vapor pressure liquids, pressurized or refrigerated tanks are often 

used to contain the material and prevent emissions (see also Attachment 1, page 25). 

4.2 Liquid Transfer Operations 

Liquid transfer into tank trucks, railcars, or smaller containers can be controlled through 

the use of submerged filling, a vapor collection and control system, or by balancing the vapors 

back to the vessel that supplied the liquid (except pipelines). In these vapor collection systems, 

care must be exercised to ensure that vapors are not lost due to leakage. A requirement for vapor 

tightness maintenance and testing has been a component of most liquid transfer regulations. 

These provisions apply to both the facility equipment and the mobile cargo tank. They are 

intended to ensure that collected vapors are not lost through leaking connectors, valves, and 

piping (see also Attachment 1, page 25). 

4.3 Equipment Components 

The primary control options available for reducing emissions due to equipment leaks 

include modifying or replacing existing equipment with leakless equipment, and implementing a 

leak detection and repair (LDAR) program. An LDAR program typically consists of periodic 

inspection of components for leaks using a portable hydrocarbon detector. An alternative to 

instrument LDAR used by some companies and specified in some rules is a routine visual 

inspection program (see also Attachment 1, page 25). 

4.4 Wastewater and Other Wastes 

Control of HAP emissions from wastewater can be achieved by venting the clarifier 

(where used) to a vapor control system and enclosing the separator with a floating roof (liquid 

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contact) or vapor-tight cover (non-contact). Other control methods include the use of closed 

piping (versus open trenches or viaducts) and drain controls, such as p-traps and water seals (see 

also Attachment 1, page 30). 

For semi-aqueous waste (e.g., sludge), control would consist of limiting direct exposure 

to the atmosphere through storage ofthe waste in sealed containers, and limiting the time during 

handling that the waste is exposed. 

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5.0 CURRENT CONTROL LEVELS 

The presumptive MACT (P-MACT) determinations are derived from a comprehensive 

review of the current Federal and State regulations applicable to emission points of concern for 

the Organic Liquids Distribution NESHAP. At the present time, limited source-specific 

information (derived from site visits) is available. More specific source information will be 

derived from responses to the recent industry survey. The determinations for existing sources in 

this P-MACT are based on an average ofthe top 12 percent of potentially affected facilities. To 

determine the percentage of affected facilities, the percentage of facilities within the States with 

the most stringent rules were added together. The facility percentages were derived from the 

distribution, by State, ofthe membership ofthe ILTA (2) and from two current publications, the 

Petroleum Terminal Encyclopedia (6) and Petroleum Supply Americas (7). 

The P-MACT determinations presented in this section for new sources are based on the 

most stringent existing State, local, or Federal regulation requirements for similar emission 

sources. Section 112(d) ofthe Act states that standards for new sources must be derived from 

"the emission control that is achieved in practice by the best controlled similar source." As 

stated above, little current industry practice information is available at each source; therefore, this 

P-MACT has been derived from control levels found in Federal, State, and local regulations that 

apply to industries with similar emission sources. 

5.1 Existing Levels of Control 

5.1.1 Fixed Roof Storage Tanks 

In general, the stringency of storage tank regulations varies depending on several 

factors, which include vapor pressure cutoffs, storage tank volume cutoffs, floating roof rim 

seal requirements, floating roof fittings seal requirements, and vapor control/reduction 

requirements. 

5.1.1.1 Low Vapor Pressure (< 11 psia) Organic Liquids Fixed Roof Storage 

For storage vessels containing low vapor pressure organic liquids, P-MACT was 

derived from 51 State regulations, and augmented with provisions from the Hazardous Organic 

NESHAP (HON), the Benzene Emissions from Storage Vessels (Benzene Storage) NESHAP, 

and the Volatile Organic Liquid Storage Vessel NSPS (40 CFR 60, subpart Kb). 

The MACT standards for storage vessels in the HON and the Benzene Storage 

NESHAP require a floating roof or a closed vent system vented to a control device at 95 

percent emission reduction for any storage tank > 10,000 gallons. The HON requirements are 

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for storage tanks associated with a process unit which hold any organic HAP liquid > 1.9 psia 

stored in storage tanks > 10,000 gallons, > 1.5 psia stored in tanks > 20,000 gallons, or 

> 0.15 psia stored in tanks > 40,000 gallons. The Benzene Storage NESHAP standards are for 

the storage of benzene within a particular range of specific gravities. 

New Sources 

The HON is the most stringent regulation reviewed with respect to low vapor pressure 

organic liquids; therefore, P-MACT for new sources is equivalent to a floating roof tank or 95 

percent emission reduction for organic HAP liquids > 1.9 psia stored in storage tanks 

> 10,000 gallons, > 1.5 psia stored in tanks > 20,000 gallons, or >0.15 psia stored in tanks 

>40,000 gallons. 

Existing Sources 

The most stringent of the reviewed State storage vessel regulations were seven 

California District rules, the Chicago-Area Illinois regulation, and the Colorado regulation. 

These rules are believed to affect at least 12 percent ofthe OLD industry; therefore, P-MACT 

for existing sources is as follows: 

> 19,800 gallons and > 1.5 psia; or 

> 39,630 gallons and > 0.5 psia: 

Must have a floating roof or vapor control at 95 percent by weight. 

5.1.1.2 High Vapor Pressure (> 11 psia) Organic Liquids Fixed Roof Storage 

The P-MACT determination for high vapor pressure organic liquids storage is based on 

20 State regulations, and augmented by the HON, the Benzene Storage NESHAP, and the 

Storage Vessel NSPS (subpart Kb). All of the regulations reviewed considered any organic 

liquid > 11 psia to fit the definition of a "high vapor pressure" or "extremely volatile" liquid. 

The requirements of subpart Kb and the HON are to operate a closed vent system 

routed to a control device to reduce emissions by 95 percent on any tank > 20,000 gallons 

(NSPS) or > 10,000 gallons (HON) used for the storage of any organic liquid > 11 psia. 

Additionally, the MACT standards for storage vessels in the HON and the Benzene Storage 

NESHAP require that if a pressure vessel is used, it must have no detectable organic 

emissions. 

New Sources 

P-MACT for new sources is, however, set at a level based on two California district 

rules (El Dorado and Placer County), since these rules do not contain any tank size cutoffs. 

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Any storage tank storing organic liquids > 11 psia is required to operate a closed vent system 

routed to a control device to reduce emissions by 95 percent. If a tank used to store organic 

liquids > 11 psia is a pressure tank, it must operate with no detectable emissions. 

Existing Swrces 

In general, the most stringent State rules consist of California District rules, the 

Colorado rule, and the Texas rule. Based on these State and local regulations, P-MACT for 

existing sources applies to tanks >25,000 gallons used for the storage of organic liquids >11 psia. 

These tanks must be connected to a closed vent system routed to a control device that reduces 

emissions by 95 percent. It is important to note that P-MACT for existing sources is less 

stringent than the NSPS (subpart Kb). 

5.1.1.3 Top Loaded Storage Vessels 

The P-MACT level for top loaded storage vessels is derived from 15 State regulations. 

The most stringent State regulations consist of several California District (Placer County and 

Bay Area) rules, which form the basis for the new source P-MACT. The Louisiana 

regulation, the Oklahoma rule, the Kentucky rule, and one Federal rule, 40 CFR part 52, 

subpart O, which applies to several counties in Illinois, have similar standards for top loaded 

permanent storage tanks. These rules set the P-MACT level for existing sources. No other 

Federal regulations addressing top loaded storage tanks have been located for this analysis. 

New Sources 

P-MACT for new sources is bottom loading or a permanent submerged fill pipe for all 

stationary storage tanks <40,000 gallons used to store organic liquids with a vapor pressure >0.5 

psia. Based on the two California District rules mentioned above, there is no lower size limit for 

the affected tanks. 

Existing Sources 

Based on the 15 State regulations and 1 Federal regulation reviewed, P-MACT for 

existing sources is a permanent submerged fill pipe installed in all top loaded stationary tanks 

> 580 gallons that are used to store liquids with a vapor pressure > 1.5 psia. 

5.1.2 External Floating Roof Tanks 

Within the 10 State and regional regulations that were reviewed for the purpose of 

determining P-MACT for external floating roof tanks, there are several categories of 

standards. The first category is the general standards for typical external floating roof tanks. 

Second are standards and exemptions for welded tanks. Finally, there are standards and 

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exemptions that apply to tanks used to store produced crude oil and condensate prior to lease 

custody transfer. 

5.1.2.1 General Standards 

The stringency of the control requirements for external floating roof tank rim seals as 

listed below is the same among the Federal (HON and subpart Kb) and the State regulations. 

A summary of the external floating roof seal requirements in the Federal and State rules 

reviewed is as follows: 

For petroleum liquid storage: 

1. Tank must be fitted with a continuous rim-mounted secondary seal extending 

from the floating roof to the tank wall; 

2. All seal closure devices must have no visible tears or openings in the fabric and 

be intact and uniformly in place around the circumference of the floating roof; 

3. For vapor-mounted primary seals, the accumulated area of individual gaps 

(> 0.125 inch) between the secondary seal and die tank wall, must not exceed 

1.0 square inch per foot of diameter; 

4. Except during loading which begins when the tank is empty, the floating roof is 

to remain floating on the liquid at all times.1 

For non-petroleum organic liquid storage: 

1. For tanks equipped with a mechanical shoe primary seal, the tank must be fitted 

with a continuous rim-mounted secondary seal extending from the floating roof 

to the tank wall; 

2. For tanks equipped with a vapor-mounted primary seal, the tank must be fitted 

with a liquid-mounted primary seal and a continuous rim-mounted secondary 

seal extending from the floating roof to the tank wall; 

3. All seal closure devices must have no visible tears or openings in the fabric and 

be intact and uniformly in place around the circumference of the floating roof; 

4. For vapor-mounted primary seals, the accumulated area of individual gaps 

(> 0.125 inch) between the secondary seal and the tank wall, must not exceed 

1.0 square inch per foot of diameter; 

5. Except during loading which begins when the tank is empty, the floating roof is 

to remain floating on the liquid at all times.1 

1

 Currently under consideration is allowance for the floating roof to sit down on its legs 

for relatively short periods with the addition of recordkeeping for those time periods. 

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The external floating roof fittings requirements for organic liquid storage are: 

1. Automatic bleeder vents are to be closed at all times except when the roof is 

floated off or landed on the roof supports; 

2. Emergency roof drains are to be provided with slotted membrane fabric covers, 

or equivalent which cover at least 90 percent of the area of the opening; and 

3. Each automatic bleeder vent (vacuum breaker vent) and rim space vent must be 

equipped with a gasket. 

New and Existing Sources 

Based on the Federal, State, and local regulations reviewed, P-MACT for new and 

existing sources is the application of the above listed seal and fittings requirements to storage 

of organic HAP liquids in external floating roof storage tanks. The same tank size and vapor 

pressure cutoffs applicable to the low vapor pressure fixed roof storage tanks (Section 5.1.1.1) 

apply to these tanks. 

5.1.2.2 Tanks of Welded Construction 

The exemption of welded tanks from the requirement for a secondary seal on external 

floating roofs equipped with a liquid-mounted foam seal, liquid-mounted liquid-filled type seal, 

or metallic-type shoe seal was determined from a review ofthe Control Techniques Guidelines 

(CTG) for Petroleum Liquid Storage in External Floating Roof Tanks and six State regulations 

(Texas, Louisiana, Maryland, Washington, South Carolina, and Indiana). The CTG and each of 

these regulations has the same standard: 

For all external floating roof tanks of welded construction containing petroleum liquids 

< 4 psia, no secondary seal is required if the primary seal is a liquid-mounted foam seal, liquidmounted liquid-filled type seal, metallic-type shoe seal, or equivalent. 

5.1.2.3 Produced Crude Oil and Condensate Storage 

The CTG for Petroleum Liquid Storage in External Floating Roof Tanks, the Volatile 

Organic Liquid Storage Vessel NSPS (40 CFR 60, subpart Kb), 18 State rules, and 2 

regional/urban regulations (Chicago Area and District of Columbia) allow an exemption from 

regulation fof external floating roof tanks < 420,000 gallons that store produced crude oil or 

condensate prior to lease custody transfer. The source category for the Organic Liquids 

Distribution NESHAP is likely to not include crude oil and condensate prior to lease custody 

transfer because these liquids are currently proposed to be controlled under the Oil and Gas 

MACT rule; therefore, no P-MACT exemption is needed for such tanks. 

5.1.3 Liquid Transfer Operations 

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P-MACT was investigated for both of the emission sources under liquid transfer: 

loading rack vapor collection, and vapor leakage from cargo tanks and vapor collection 

equipment. 

5.1.3.1 Loading Racks 

The P-MACT determination for loading rack vapor collection was derived from the 

HON, Benzene Transfer Operations NESHAP (40 CFR 61, subpart BB), Gasoline Distribution 

NESHAP (40 CFR 63, subpart R), Marine Vessel Loading Operations NESHAP (40 CFR 63, 

subpart Y), and 30 State regulations. 

Some of the existing standards are based on vapor emission control on the basis of 

percent reduction, while others are based on a mass emissions limitation in units of mg/liter 

(L) or lb/1,000 gallons loaded. The determination of relative stringency is complex, and 

varies depending on the uncontrolled emission factors for the liquids in question. This 

emission factor in turn is a function of the vapor pressure of the liquid. For transfer of higher 

vapor pressure liquids, an emission limit standard would be more stringent. For lower vapor 

pressure liquids transfer, emissions reduction on a weight percentage basis is more stringent. 

This issue will be investigated further for the principal liquids of interest in the OLD category. 

Most Federal and State regulations have a 20,000 gallons per day (averaged over a 

continuous 30-day period) throughput cutoff. If the entire facility exceeds this limit, it must 

comply with the respective standard; if not, it is exempted from the standard. 

The most stringent organic liquid transfer operation regulation identified is the 

California-Sacramento rule, for which the standard is an emission limit of 10 mg/L for any 

transfer operations for organic liquids with a vapor pressure >0.5 psia. 

The HON standards for transfer operations of organic HAP with a vapor pressure 

> 1.5 psia state that new sources must have a vapor recovery system that reduces emissions by 

at least 98 percent, and existing sources must reduce emissions by 97 percent. The Gasoline 

Distribution NESHAP and the Refinery NESHAP have die same emission limit, 10 mg/L for 

gasoline transfer operations. The Benzene Transfer Operations NESHAP requires 98 percent 

emission reduction for any organic liquid that is at least 70 percent benzene, by means of a 

vapor-tight vapor recovery system. The Marine Vessel NESHAP requires 98 and 97 percent 

emission reduction for new and existing sources, respectively, for transfer of any organic 

liquid with a vapor pressure > 1.5 psia. 

New Sources 

P-MACT for new sources has three parts. First, it applies to any facility that transfers 

an average of > 20,000 gallons per day over a continuous 30-day period. Next, for organic 

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liquids >0.5 psia, the emission limit is 10 mg/L based on the California-Sacramento rule. 

Lastly, for organic liquids > 1.5 psia, 98 percent emission reduction (the HON) or an 

emission limit of 10 mg/L (California-South Coast and San Joaquin) applies depending upon 

which is more stringent for the specific liquid transferred. 

Existing Sources 

P-MACT for existing sources is for facilities that transfer >20,000 gallons per day 

(averaged over a continuous 30-day period), and consists of an emission reduction of 90 percent 

for organic liquids with a vapor pressure >0.5 psia. This is based on the Texas and California 

(South Coast, San Joaquin, and Bay Area) regulations. Presently, there is not enough 

information to make a more stringent control level determination for organic liquids >1.5 psia. It 

is likely that the information obtained through the industry survey will provide the basis for a 

MACT floor determination for organic liquids >1.5 psia to supplement the standard for organic 

liquids >0.5 psia, 

5.1.3.2 Vapor Leakage 

Control requirements for vapor leakage from controlled liquid transfer operations have 

been specified in several State rules, the Tank Truck CTG, the Bulk Gasoline Terminal NSPS, 

and the Gasoline Distribution NESHAP. These standards and guidance consist of an annual 

vapor tightness test for cargo tanks and leak testing in the field using a combustible gas detector. 

The vapor tightness requirements by the States and the EPA have primarily addressed gasoline 

transfer operations, and typically apply to tank trucks. The applicability of this type of emission 

control to non-gasoline liquids, and to railcars handling any type of liquid, is variable. The 

Gasoline Distribution NESHAP does apply to railcars loading gasoline at affected facilities. 

Industry has stated that vapor collection and control is rarely applied to the transfer of chemicals, 

but it is required under some circumstances in parts of California, Texas, and possibly other 

States. 

The Department of Transportation (DOT) requires a periodic hydrostatic or pneumatic 

pressure test for cargo tanks. In general, the DOT cargo tank requirements are safety related and 

apply to the prevention of liquid losses, rather than vapor emissions. The current industry 

practice for cargo tanks equipped to perform vapor recovery or vapor balancing is to perform the 

EPA Method 27 test to certify the tank for vapor tightaess. Method 27 would only be performed 

on tanks that are equipped and required to perform vapor recovery or vapor balancing, which in 

turn would be determined by the loading rack (transfer) requirements. Industry has stated that 

Method 27 is considered to be an acceptable substitute for the DOT testing. 

At this time, the applicability ofthe current vapor tightness control levels to general 

orgamc liquids distribution is uncertain. The project team will be collecting additional 

information, and then performing analyses of floor control levels and emission reduction 

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potential from these measures. 

5.1.4 Wastewater Treatment 

The determination related to air emissions from wastewater during collection and 

treatment is based on a review of seven current statewide wastewater regulations. In general, 

the State wastewater regulations are case-specific and industry-specific. Thus, they may not be 

applicable to distribution facilities in the OLD source category. In order to develop 

appropriate MACT standards for wastewater, the project team intends to collect additional 

information with respect to current industry wastewater processes and control measures. 

The HON and the Benzene Waste Operations and Oil-Water Separator NESHAP offer 

some guidance for evaluating the best current control performance in wastewater treatment 

operations. The HON standards for wastewater storage, drain systems (junction box or 

drains), treatment systems, and oil-water separators are based upon wastewater that meets the 

following requirements for new and existing sources: 

1. Contains > 10 ppmw total volatile organic HAPs (listed in Table 8 of subpart F) 

and has a flow rate >0.02 liters/minute (new sources); or 

2. Contains > 1,000 ppmw total volatile organic HAPs (listed in Table 9 of 

subpart F) and has a flow rate > 10 liters/minute (new and existing 

sources); or 

3. Contains > 10,000 ppmw total volatile organic HAPs (listed in Table 9 of 

subpart F) at any flow rate. 

New Sources 

The wastewater operations of the facilities in the organic liquids distribution source 

category are likely to have similarities to those at a HON-regulated production facility or a 

refinery; therefore, P-MACT for new sources includes standards for four categories: 

wastewater storage tanks, individual drain systems, treatment systems, and oil-water 

separators. 

The first wastewater storage tank requirement is a fixed roof for any tank > 20,000 

gallons used to store wastewater, as defined above. The second is a fixed roof and closed vent 

system routed to a control device at 95 percent emission reduction for tanks > 20,000 which 

store wasterwater > 1.9 psia. The third requirement level is a fixed roof and closed vent 

system routed to a control device at 95 percent emission reduction for tanks > 40,000 which 

store wasterwater >0.75 psia. Individual drain systems are required to be designed to 

minimize vapor emissions while also minimizing the potential for explosion. Oil-water 

separators must have either a fixed roof with a closed vent system routed to a control device to 

reduce emissions by 95 percent or a floating roof. 

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Existing Sources 

Currently, the practices of the source category are not known in sufficient detail to 

develop P-MACT for wastewater treatment for existing sources. The industry survey results 

are expected to provide the detailed information needed to determine the appropriate control 

levels. 

5.1.5 Equipment Leaks 

The equipment (pumps, valves, flanges, etc.) at facilities in the organic liquids 

distribution source category is assumed to be similar to certain equipment at a chemical 

production, refinery, or gasoline distribution facility. Facilities regulated under the HON and 

the Refinery NESHAP (with higher-emitting equipment) have full instrument LDAR 

requirements, while facilities under the Gasoline Distribution NESHAP (with lower-emitting 

equipment) have a visual (sight, sound, and smell) leak check standard. 

The project team has not determined which type of leak detection program requirement 

(or whether any requirement) is appropriate for the equipment at OLD sources. Data and 

information on the emission rates from this equipment and the current practices within the 

source category are needed. Information on current leak detection practices is expected to be 

collected in the industry survey. The EPA will work with industry to determine leakage and 

emission rates from this equipment. 

5.1.6 Blending and Packaging 

Specific rules affecting blending and packaging activities directly have not been 

identified; therefore, no P-MACT determination for this emission source has been made. The 

team plans to collect additional infonnation through site visits, other contacts with industry 

and trade groups, and the industry survey of individual facilities. Analyses of floor levels of 

control and potential emissions reduction will be performed using this information. 

5.2 Federal Regulations 

Below are brief summaries of several existing or proposed Federal air rules that may 

apply or have similar control levels and technologies to the distribution facilities in this source 

category. 

5.2.1 Hazardous Organic NESHAP (HON) (subparts F, G, H, I) 

The HON applies to chemical manufacturing process units that are: (1) part of a major 

source as defined in section 112 of the Act; (2) produce as a primary product a SOCMI chemical 

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listed in Table 1 of subpart F; and (3) use as a reactant or manufacture as a product or by-product 

or co-product one or more ofthe organic HAPs listed Table 2 of subpart F. Among other things 

the HON sets control requirements for storage vessels and transfer operations. 

The storage vessel provisions do not apply to the following: (1) pressure vessels designed 

to operate in excess of 204.9 kPa (29.7 psia); (2) vessels with capacities smaller than 38 m3 

(10,000 gallons); (3) wastewater tanks; and (4) vessels storing liquids that contain organic HAPs 

only as impurities. The storage provisions require that one ofthe following control systems be 

applied: (1) an internal floating roof with proper seals and fittings; (2) an external floating roof 

with proper seals and fittings; (3) an external floating roof converted to an internal floating roof 

with proper seals and fittings; or (4) a closed-vent system that vents to a 95 percent efficient 

control device or that transports gases back into the process. 

Transfer operations are defined as the loading of liquid products that are on the list of 

organic HAPs from a transfer rack into a tank truck or railcar. The transfer provisions do not 

apply to the loading of liquid organic HAPs at an operating pressure in excess of 204.9 kPa (29.7 

psia); loading of marine vessels; racks loading liquid organic HAPs only as impurities ; or racks 

loading liquid organic HAPs if emissions are returned to a storage vessel in a vapor balancing 

system. The transfer provisions require control of transfer racks to achieve 98 percent organic 

HAP reduction or an outlet concentration of 20 ppmv. Combustion devices or product recovery 

devices may be used to comply with this requirement. Alternatively, vapor balancing systems 

may be used. 

5.2.2 Petroleum Refinery NESHAP (subpart CC) 

The Petroleum Refinery NESHAP applies to petroleum refining units, all gasoline 

loading racks classified under Standard Industrial Classification (SIC) code 2911, all marine 

vessels loading operations located at petroleum refinery, and all storage vessels and equipment 

leaks associated with a bulk gasoline terminal or pipeline breakout station under SIC code 2911 

located within a contiguous area and under common control with a refinery. 

New storage tanks are required to have floating roofs with primary and secondary seals if 

the tank fits either ofthe two following scenarios: (1) tank capacity >40,000 gallons, true vapor 

pressure (TVP) >0.5 psia, and HAP liquid concentration >2%; or (2) tank capacity >20,000 

gallons and <40,000 gallons, TVP >11.1 psia, and HAP liquid concentration >2%. 

For gasoline loading racks, if the SIC code is 2911, or the loading rack is contiguous and 

under common control, then the facility must comply with the Gasoline Distribution NESHAP 

(subpart R). Loading operations into marine vessels at refinery facilities must comply with the 

Marine Vessel Loading NESHAP (subpart Y). 

5.2.3 Proposed Oil/Natural Gas Distrib./Transmission NESHAP (subparts HH, HHH) 

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Examples of facilities include, but are not limited to, well sites, satellite tank batteries, 

central tank batteries, graded pad sites, and natural gas processing plants. A facility typically is 

(1) a natural gas compressor station that receives natural gas via pipeline from an underground 

natural gas storage operation, from a condensate tank battery, or from a natural gas processing 

plant; or (2) an underground natural gas storage operation. 

The EPA is describing the organic liquids distribution (non-gasoline) source category as 

including those facilities that distribute hydrocarbon liquids after the point of custody transfer. 

From the language in these proposed rules and preamble, the organic liquids distribution 

category will have to account for some ofthe facilities that have a relationship to the operations 

covered by subparts HH and HHH. 

5.2.4 Gasoline Distribution NESHAP (subpart R) 

Subpart R applies to bulk gasoline terminals and pipeline breakout stations that are part 

of a major source as defined in section 112 ofthe Act. A bulk gasoline terminal or pipeline 

breakout station with SIC code 2911 is subject to this rule. 

The emissions to the atmosphere from the vapor collection and processing systems due to 

the loading of gasoline cargo tanks must not exceed a 10 mg/L emission limit. The storage 

vessel requirements are similar to 40 CFR 60, subpart Kb requirements. 

5.2.5 Benzene Emissions from Storage Vessels NESHAP (subpart Y) 

40 CFR 61, subpart Y applies to storage vessels that store benzene having a specific 

gravity within a specified range. A designated source is subject this rule as well as to the 

provisions of 40 CFR 60, subpart Kb. The provisions of this rule specify that a designated 

source with a storage capacity greater than 10,000 gallons must have an internal floating roof, an 

external floating roof, or a closed vent system with a control device. If a storage vessel is 

equipped with a closed vent system and a control device, the control device must reduce inlet 

benzene emissions by at least 95 percent. 

5.2.6 Marine Vessel Loading NESHAP (subpart Y) 

40 CFR 63, subpart Y applies to marine vessel loading operations that are part of a major 

source as defined in section 112 of the Act. The provisions apply to commodities with a true 

vapor pressure >1.5 psia, and specify that there must be ship-to-shore compatibility, vapor tight 

connections, and a vapor collection system. New and existing facilities must reduce HAP 

emissions after vapor collection by 98 and 97 percent by weight, respectively. 

5.2.7 Benzene Waste Operations NESHAP (subpart FF) 

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The provisions of this NESHAP apply to chemical manufacturing plants, coke by-product 

recovery plants and petroleum refineries at which the total annual benzene quantity from tiie 

facility waste is greater than 10 megagrams per year. Each tank in which the waste stream of 

water content less than 10 percent is placed must maintain a fixed-roof, closed-vent system and 

a control device with emission reduction at 95 percent. 

5.2.8 Benzene Transfer Operations NESHAP (subpart BB) 

The affected facility to which this subpart applies is the total of all loading racks at which 

benzene any liquid containing 70 percent benzene is loaded into tank trucks, railcars, or marine 

vessels at each benzene production facility and each bulk terminal. Dedicated loading racks at 

which benzene-laden waste, gasoline, crude oil, natural gas, or petroleum distillates are loaded 

are exempt. Each loading rack must be equipped with a vapor collection system from which the 

collected vapors are routed to a control device to reduce the emission by 98 percent by weight. 

5.2.9 Miscellaneous Organic NESHAP (MON) [pre-proposal] 

With the promulgation ofthe Miscellaneous Organic NESHAP by the year 2000, the 

EPA intends to propose a single set of emission standards that will apply to more than 20 listed 

source categories of HAP. Industries with SIC code 28 will be affected by this regulation, as will 

organic chemical processes described by SIC codes 282,284,285,286,287,289, and 386. The 

rule will affect facilities that use batch organic processes. 

The MON is expected to cover source categories including: chlorinated paraffins 

production, carbonyl sulfide production, explosives production, hydrazine production, 

photographic chemicals production, and rubber chemicals production. It will also cover process 

vents for batch reactors used in producing organic chemicals listed in Table 1 of 40 CFR Part 63, 

subpart F (Hazardous Organic NESHAP), and HAP emissions from synthetic organic chemical 

manufacturing industry (SOCMI) processes using HAP only as a solvent. Furthermore, the 

MON will cover the production of pesticide intermediates not covered by the Agricultural 

Chemicals NESHAP, and production of by-products, co-products and intermediates not 

considered primary products under the NESHAP for Group I and Group IV polymers and resins. 

In addition, the MON will cover those product processes identified by the EPA based upon 

information gathered which includes alcohols, oil additives, etc., and other product processes not 

identified by any other MACT standard. 

5.3 State/Local Regulations 

The list of State and local regulations that apply to emission sources that occur in the 

organic liquids distribution industry was discussed earlier and is discussed in more detail in 

Attachment 2-Summary of State/Local Regulations. 

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6.0 SUMMARY OF ISSUES AND NEXT STEPS 

6.1 Issues in the NESHAP Development 

The EPA project team and the Work Team have identified several issues that need to be 

addressed during the standards development process. The most significant issues center around 

the definition ofthe OLD industry, and the specific facilities, operations, and liquids that need to 

be covered by the standards. Some ofthe key issues are discussed below (see also Attachment 1, 

pages 29 and 30). The remainder of this section briefly addresses the next steps in the regulatory 

process. 

Industry description. The current description of this source category is focused primarily 

on stand-alone or separate distribution operations (i.e., not collocated with a chemical 

manufacturer or a petroleum refinery), which may consist either of a bulk liquid terminal or a 

pipeline facility. In contrast to terminals, pipeline facilities exist along a pipeline, receiving 

product and returning it for continued transportation by pipeline. 

The issue concerns the extent ofthe collocated distribution operations that should be 

included in this source category, and whether there are additional types of facilities or operations 

not already considered that should be included in the category. These additional facihties may be 

either stand-alone or collocated with a facility whose primary function is not liquid distribution. 

Another issue concerns whether liquids consumed at the distribution facility (e.g., fuels) should 

be included in the regulatory coverage. Additionally, members ofthe Roundtable team requested 

further refinement or definitions of tiie terms "distribution" and "custody transfer." 

Impact of existing rules. Several Federal NESHAP standards have been promulgated or 

are under development (see Section 5.1) that affect the manufacture and handling of HAPcontaining organic liquids. A continued focus is to investigate liquid distribution activities not 

already regulated or planned for regulation under these other standards. Conversely, the team 

wishes to avoid duplicating any MACT requirements already in effect or planned for sources in 

this or similar industries. Examples are distribution storage and related liquid handling 

operations at refineries and chemical plants. 

Major/area source determination. A determination ofthe number of major sources in the 

category has not been made. Due to the apparent large number of area sources, the project team 

will need to investigate how to define out ofthe rule as many area sources as possible to lessen 

the need for permitting of area sources. Also, area sources will have to be analyzed and a 

regulatory determination will have to be made, since §112(c)(3) ofthe Act requires that area 

sources be regulated if they present "a threat of adverse effects to human health or the 

environment." 

6-1 

31 
P.32 

6/09/98 

Additional data gathering. Data gathering for the P-MACT development and for the 

eventual development ofthe NESHAP has produced useful information, but additional data are 

needed to fully define the industry and perform the analyses to support emission standards. 

These analyses will include options for industry subcategorization, model plant development, 

baseline emissions estimates, MACT control levels determination, and control technology 

assessments. The project team expects results from the industry survey and continued contacts 

with the Work Team to be useful in providing this information. 

Technical issues that were identified for future resolution include: 1) the equipment 

necessary to properly collect vapors displaced from tank tracks and other containers needs to be 

identified and analyzed; 2) the emission rates from controlled and uncontrolled equipment leaks 

from pumps and valves specifically for this source category need to be quantified; 3) the 

difference between setting mass versus percent reduction limits for displacement losses from 

transfer operations needs to be analyzed; 4) the level of control for leakage from cargo tanks and 

containers needs to be identified and quantified, including the difference between DOT and EPA 

(Method 27) standards; and 5) multi-HAP content data for petroleum products and chemical 

blends are needed. 

6.2 Next Steps 

Review of existing regulations, plant visits, and Roundtable meetings with industry and 

State representatives will be used to better define the source category and its affected sources, 

and to address other regulatory and technical issues. 

Results from the industry survey will be analyzed for the purpose of performing the 

analyses needed to develop and support MACT standards for this category. The EPA project 

team will continue to collect data and information in order to refine the industry profile and 

define the facility types and emission sources that need to be included under the MACT 

standards. Additional site visits will be made with the purpose of gathering further information 

and understanding the range of facility types. The project team will be meeting with the industry 

and regulatory stakeholders as necessary to discuss issues in this rule development. 

A major project milestone and work effort will be the analysis and summary of responses 

to the industry survey. This analysis is expected to occur in the summer and fall of 1998. The 

development of MACT floors and drafting of a rule proposal will follow this analysis effort. 

6-2 

^ 
P.33 

6/09/98 

7.0 REFERENCES 

1. U.S. Environmental Protection Agency. 1992. Documentation for Developing the 

Initial Source Category List-Final Report. OAQPS, Research Triangle Park, 

North Carolina. 

2. 1997 ILTA Directory, Independent Liquid Terminals Association. Washington, D.C. 

3. Office of Management and Budget. 1987. Standard Industrial Classification Manual. 

National Technical Information Service, Springfield, Virginia. 

4. 1997 NACD Directory, National Association of Chemical Distributors. Arlington, 

Virginia. 

5. Letter from Young, Priscilla J., American Petroleum Institute, to Bruce Jordan, U.S. 

EPA/ESD. May 24,1995. RE: Removing the Crude Oil Transportation Sector from the 

National Emission Standards for Hazardous Air Pollutants for Oil & Natural Gas 

Production Facilities. 

6. Newton, Denise, et al. Petroleum Terminal Encyclopedia. Oil Price Information Service 

(Stalsby/Wilson). Rockville, Maryland. 1997. 

7. Newton, Denise, et al. Petroleum Supply Americas. Oil Price Information Service. 

Lakewood, New Jersey. 1997. 

7-1 

33 
P.34 

Attachment 1 

PRESUMPTIVE MACT FOR 

ORGANIC LIQUIDS (NON-GASOLINE) 

DISTRIBUTION FACILITIES 

JUNE 1998 REVISED 

EPA PRESENTATION 

FROM FIRST ROUNDTABLE MEETING 

Waste and Chemical Processes Group 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 

3H 
P.35 

OVERVIEW 

Standards Development Process 

Presumptive MACT 

• MACT 

• Project Schedule 

Affected Sources 

• Definition of Source Category 

• Industry Profile 

Model Plants/Facilities 

Emissions and Controls 

• HAP Emissions 

• Emission Controls 

Current Control Levels (MACT Floors) 

Issues/Questions 

2 

rt 
P.36 

STANDARDS DEVELOPMENT 

PROCESS 

3 

3^ 
P.37 

PRESUMPTIVE MACT IS... 

[MACT = maximum achievable control technology] 

• An estimate of what MACT would be, based on a 

review of currently available information 

• Assists State and local agencies in making caseby-case MACT determinations 

• Not a regulation - offered only for guidance and 

information 

• A starting point for the MACT standard 

development process 

4 
P.38 

STATUTORY REQUIREMENTS 

Promulgation of national emission standards 

for hazardous air pollutants (NESHAP) for 

listed source categories is required under 

§112(d) ofthe Clean Air Act 

Organic Liquids Distribution (Non-Gasoline) is 

a listed major source category under §112(c) 

[Federal Register, 57 FR 31576, July 16,1992] 

Promulgation of standards is required by 

November 2000 

5 

33 
P.39 

STATUTORY REQUIREMENTS 

(2) 

• "Major Source" means any stationary source or 

group of stationary sources located within a 

contiguous area and under common control that 

emits or has the potential to emit, considering 

controls, in the aggregate, 10 tons per year of any 

hazardous air pollutant (HAP) or 25 tons per year 

of any combination of HAP 

• "Area Source" means any stationary HAP source 

that is not a major source 

• "New Source" means a stationary source, the 

construction or reconstruction of which is 

commenced after the Administrator first proposes 

regulations under §112 establishing an emission 

standard applicable to such source 

• "Existing Source" means any stationary source 

other than a new source 
P.40 

STATUTORY REQUIREMENTS 

(3) 

Minimum level of standards ("MACT floor") 

• For existing sources, the standard shall be at 

least as stringent as the average emission 

limitation achieved by the best performing 12 

percent of existing sources, or, in the case of 

categories with less than 30 sources, the 

average emission limitation achieved by the 

best performing 5 sources 

• For new sources, the standard shall be at least 

as stringent as the emission control achieved 

in practice by the best controlled similar 

source 

Ho 
P.41 

CURRENT PROJECT SCHEDULE 

Event Date 

Kickoff Meetings 

Plant Visits 

Initial Roundtable 

(Work Team) 

September 24-25,1997 

Dec. 1997 - Apr. 1998 

January 21,1998 

Second Roundtable 

(discuss draft P-MACT) March 24,1998 

Issue P-MACT Report June 1998 

Continue on Standards 

Development Process July 1998 

Rule Proposal 

Rule Promulgation 

September 1999 

November 2000 

8 
P.42 

AFFECTED SOURCES 

9 
P.43 

HOW IS THE SOURCE CATEGORY 

DEFINED? 

Initial Source Category Description: 

Activities associated with the storage and distribution of nongasoline organic liquids with HAP content, at sites that serve as 

distribution points from which organic liquids may be obtained 

for further use and processing. 

From the Oil and Gas Production MACT rule proposal, 

includes petroleum pipeline facilities that handle and distribute 

hydrocarbon liquids after the point of custody transfer. 

Facility Types Include: 

• Stand-alone or separate distribution terminals 

• Collocated distribution activities (i.e., associated with 

refineries or chemical plants) 

• Compounding/blending/packaging plants 

- separate facilities [not covered under 

Miscellaneous Organic NESHAP (MON)] 

- collocated with stand-alone or collocated distribution 

activities 

• Pipeline facilities (non-gasoline HAP liquids) 

10 
P.44 

Organic Liquids Distribution 

Facilities Industry 

CHEMICALS 

Chemical 

Manufacturing 

(SOCMI) 

Consumer 

(Retail) 

Packaging/Distribution 

Facility 

PETROLEUM 

Domestic 

Oil/Gas 

Production 

Petrochemical 

Manufacturing 

i 

Facilities using 

chemicals as 

feedstocks 

Consumer 

(Retail) 

I 

Packaging/ 

Distribution 

Facility 

i 

Packaging/ 

Distribution 

Facility 

Petroleum 

Refining 

Consumer 

(Retail) 

Foreign 

Crude Oil 

- Intermediate Distribution Fadlity 

11 
P.45 

HOW IS THE SOURCE CATEGORY DEFINED? 

(2) 

Which processes and equipment are covered? 

• All HAP emission sources at distribution facilities 

• Possible distribution sources: 

- Storage tanks 

- Liquid transfer 

- truck 

- railcar 

- pipeline 

- Equipment leaks 

- Wastewater collection and treatment (air emission 

aspects) 

Which liquids? 

Synthetic organic HAP chemicals 

Petrochemicals 

Crude oil or other unrefined petroleum liquids 

Refined petroleum (non-gasoline) 

Other liquids with volatile HAP content (e.g., wastes and 

wastewater) 

12 
INDUSTRY PROFILE-BASED ON SIC CODES 

-tr 

Major Group Industry 

Group 

Number 

SIC 

Code' 

NAICS 

Code 

Facility Type" Total No. of 

Establishments1* 

Size Distribution 

by No. of Employees1* 

<50 >50 >100 

PIPELINES 

HS-wy*A^S*n\ 

fSiJ-'SS /-; 

., A* . •*. . , .. ' • 

4610 

4780 

*S"' & !$< 

4612 

4613 

4619 

4789 

'/f'.',.yr,„< 

48611 

48691 

48699 

W&si*. 

488999 

W^-y/'&CS&S-^r&tfM-t. S'/S{S$Ci>ft&, 

Pipelines, Except Natural Gas 

Crude Petroleum Pipelines 

Refined Petroleum Pipelines 

Pipelines, Not Elsewhere Classified 

/ '"s/8V i,''iu$^r't."''S'i>"' y-tztiP/tiS '•ys.\''' tjy"'i'^"< 

/x^1T«^ «. SS 

Miscellaneous Services Incidental to 

Transportation 

Transp. Services, Not Elsewhere Classified 

838 

59 

2,349 

%;ss* 

93% 

100% 

•ii/ ' V * 

92% 

S>&£' 

4% 

SS'"--

5% 

'• * * -

3% 

> -' , _" 

3% 

13 
INDUSTRY PROFILE-BASED ON SIC CODES (CONTINUED) 

Major Group Industry 

Group 

Number 

SIC 

Code' 

NAICS 

Code 

Facility Type* Total No. of 

Establishments1* 

Size Distribution 

by No. of Employees'1 

<50 >50 >100 

STAND-ALONE TERMINALS 

As •>',, ' ' Ss 

S '",:4%!SsS-

******* * '% */*% 

"'' ' -.-44,*'>**S' 

"- rat"'•••i"/-

"**'JJ" \ " * '* S* • 

S-" ' " 

/s**s * * 

{*•%*•** "V ** ; 'Its/ "' '"*'! * * * * • 

4220 

'S'"''''" 

4490 

i'"' ,s "*Vi 

' '; '.is,,, ',. 

5160 

5170 

\~>, '/,.s 

*. . *.. 

4226 

'>';""S\ 

4491 

" is. 

5169 

5171 

5172 

•r"S'-s . ' v ! 

;*"}•',''''>*£'• 

,-y'*.{'< i •• 

,, ,S '/ ' y, f,i^ 

* * S. 

49319 

-r. .""" 

- -< - i 

48831/2 

",,''"" /s 

41169 

454311 

42272 

' 'Sf- *-• *" " '"hi^ti^_t__jJt_J_ff' ->S'' '">, ' •' - -

Public Warehousing and Storage 

Special Warehousing and Storage, Not 

Elsewhere Classified 

>t^ s s^mdt tmmfotftAi&ss\;;/ /;' 

Services Incidental to Water Transportation 

Marine Cargo Handling 

'/'AS'A' '\'"""<S, S"'2J '' .FiU.P" ''%''' ''", ""• ' 

^ ^ ^ .. 

Chemicals and Allied Products 

Chemicals and Allied Products, Not 

Elsewhere Classified 

Petroleum and Petroleum Products 

Petroleum Bulk Stations and Terminals 

Petroleum & Petroleum Products 

Wholesalers, except Bulk Stations and 

Terminals 

' ',' s , ',' s ' ' 

* ** f J A * 

1,479 

6,742 

854 

14,436 

10,695 

14,636 

10,562 

3,864 

• / ' ' ' 

93% 

& <r 

95% 

78% 

* * * 

97% 

97% 

97% 

97% 

97% 

4% 

•••••< ' % , » 

' "s>isi' 

s s + $5 ^ 

2% 

10% 

*"''/'' 

2% 

2% 

2% 

3% 

2% 

3% 

..<., i . 

3% 

1 2 % 

'-'' '» 

1% 

1% 

1% 

< 1 % 

1% 

14 
INDUSTRY PROFILE-BASED ON SIC CODES (CONTINUED) 

Major Group Industry 

Group 

Number 

SIC 

Code' 

NAICS 

Code 

Facility Type' Total No. of 

Establishments'* 

Size Distribution 

by No. of Employees'* 

<50 >50 >100 

COMPOUNDING AND PACKAGING FACILITIES 

f'SZkts'im, 

yiiiiiin u LIHJ-W-T I 

V' *•*,*' ^ y*S 

S'S'K '>'''cM*$lSS^ WWUUUMUU ___£___ 

<"'4'*'**AS'/ 

: *"•> * i**f>* i *•* zbSSi 

5160 Chemicals and Allied Products 14,436 97% 2% 

5169 42269 Chemicals and Allied Products, Not 

Elsewhere Classified 

10,695 97% 2% 1% 

5170 Petroleum and Petroleum Products 14,636 2% 

4^ 5171 454311 Petroleum Bulk Stations and Terminals 10,562 97% 3% <1% 

5172 42272 Petroleum & Petroleum Products 

Wholesalers, except Bulk Stations and 

Terminals 

3,864 97% 2% 1% 

" miiii i 

* Sj.**' 

S?f"S'* 

p%ss 

4780 Miscellaneous Services Incidental to 

Transportation 

2,349 92% 5% 

4783 488991 Packing and Crating 

15 
INDUSTRY PROFILE-BASED ON SIC CODES (CONCLUDED) 

Major 

Group 

Industry 

Group 

Number 

SIC 

Code" 

NAICS 

Code 

Facility Type" Total No. of 

Establishments1* 

Size Distribution 

by No. of 

Employees1" 

<50 >50 >100 

COLLOCATED DISTRIBUTION FACILITIES (e.g., with chemical or petrochemical facilities)4 

syA, A, ai S'Zr'fsZ 

• '/ y j ' > „S/r ^y 

\f>AAi:s,..^. 

mmmm 

f¥m^sty%^>^s^pwtsS'- '4"\AS*'/<-

't'SS,-

5160 Chemicals and Allied Products 14,436 97% 2% 1 % 

5 5169 42269 Chemicals and Allied Products, Not 

Elsewhere Classified 

10,695 97% 2% 1 % 

"Standard Industrial Classification Manual, 1987 (Office of Management and Budget) 

hCounty Business Patterns, 1995 (Bureau of the Census) 

Note: This table is not yet complete; the project team is still evaluating these facilities. Depending upon the 

outcome of these evaluations, some SIC codes may be added to or deleted from this table at a later 

point in time. 

16 
P.50 

INDUSTRY PROFILE 

(2) 

Model Industry 

Stand-Alone Organic Liquid Facilities2 

Primary SIC codes: 4226,5169,5171 

• Primary States by Total Storage Capacity: 

State 

Texas 

Louisiana 

New Jersey 

California 

Illinois 

Capacity (barrels) 

55,582,440 

29,383,594 

29,252,303 

24,329,888 

9,881,577 

Range in number of storage tanks: 

1 to 420 + 

Percent of Total 

21% 

11% 

11% 

9% 

4% 

Range in total storage capacity of individual facilities: 

2,700 to 12,500,000 barrels 

Modes of transportation 

- marine vessel (tanker ship, barge) 

- tank truck 

- railcar 

- pipeline 

2Based on membership listing for the Independent Liquid Terminals 

Association (ILTA). 

17 

60 
P.51 

INDUSTRY PROFILE 

(3) 

Collocated Organic Liquid Facilities (e.g., associated 

with petroleum refineries or chemical plants) 

• SIC codes probably not similar to stand-alone facilities 

• Model plant data still being collected 

Pipeline Facilities 

• Primary SIC codes: 4612,4613 

• Model plant data still being collected 

Blending/Compounding/Packaging Facilities 

Primary SIC codes: 5169,5171,5172 

• Probably exist as part of liquid terminal operations 

• Stand-alone facilities may not be major sources 

• Some major source facilities and collocated sites may be 

covered under the Miscellaneous Organic NESHAP 

(MON) 

• Model plant data still being collected 

18 
P.52 

EMISSIONS AND CONTROLS 

19 

5^ 
P.53 

EMISSION FACTORS 

Emissions Calculations 

- HAP content 

- Models/methods for estimating emissions 

- Parameters: volume, loading method, 

vapor pressure, etc.) 

HAP Content 

- Pure compound (100% HAP) 

- Mixtures (partial HAP content) 

- petroleum liquids 

- diluted pure HAP chemicals 

- properties of several HAP liquids are shown 

in the following table 

20 
EXAMPLE ORGANIC LIQUIDS WITH HAP CONTENT 

0\ 

Stored Liquid True Vapor 

Pressure 

Temp. 

°F 

Annual Volume HAP Concentration in 

Vapors (g/mJ) 

Range Average 

Number of Data 

Points 

•S'Mm^msmm^m^mm^Msss^m^smAsphalt 

Aviation Gasoline 

Alkylate 

Crude Oil 

Diesel/Distillate 

Gasoline 

Heavy Gas Oil 

Jet Fuel (JP-4) 

Jet Kerosene 

Naphtha 

Reformates 

Residual Fuel Oil 

Recovered Slop 

Oil 

0.002 

3.50 

4.92 

3.42 

0.07 

6.47 

0.08 

1.22 

0.07 

3.19 

3.48 

0.07 

1.46 

280 

66.8 

76 

86 

72 

69 

104 

68 

74 

72 

72 

144 

145 

fr. 

7 

? 

2.64x10" gal/yr 

7.13x10'° gal/yr 

1.18x10" gal/yr 

7 

7 

7.60x10* gal/yr 

7 

• 

7 

1.65x10>° gal/yr 

7 

? 

7 

7 

• 

7 

7 

7 

7 

7 

7 

• 

7 

7 

31.72 

15.51 

115.77 

52.09 

11.55 

130.66 

24.75 

73.20 

8.5 

92.50 

91.16 

110 

52.75 

14 

16 

28 

74 

74 

137 

38 

24 

45 

70 

53 

37 

40 

See end of table for footnotes. 

21 
EXAMPLE ORGANIC LIQUIDS WITH HAP CONTENT (Continued) 

Stored Liquid True Vapor 

Pressure 

Temp. 

°F 

Annual Volume HAP Concentration in 

Vapors (g/mJ) 

Range Average 

Number of Data 

Points 

, j,/ ' * A'<,'Z'K?A''s »,',r^"i*srs<";'t/y'<''s:;z/'s>'\'?ss',? "? S,,'^'i'Sss-s^s'i r/}*'V'A's}''/ "*'"'<, *>*''"'v^ i,' /V f/';*«/"'W j ''»'i's, ;','„ ", 

Acrylonitrile 

Aniline 

Benzene 

Bisphenol-A 

Bis (2-ethylhexyl) 

phthalate 

1,3 Butadiene 

Caprolactam 

Chloroform 

Cumene 

Ethylbenzene 

Ethylene glycol 

Ethylene dichloride 

Ethylene oxide 

Formaldehyde 37% 

Isophorone 

Maleic anhydride 

1.71 

0.02 

1.54 

n/a 

7 

36.05 

0.97 

0.19 

0.27 

0.19 

0.00 

1.25 

14.7 

7 

0.07 

0.77 

70 

95 

70 

n/a 

7 

70 

356 

50 

70 

79 

70 

70 

51 

7 

70 

53 

3,300x10* lb/yr 

1,305x10* Ib/yr 

1,740x10* Ib/yr 

1,600x10* Ib/yr 

257x10* lb/yr 

3,700x10* Ib/yr 

1,800x10* lb/yr 

935x10* Ib/yr 

5,240x10* Ib/yr 

13,040x10* Ib/yr 

5,600x10* Ib/yr 

19,600x10* lb/yr 

6,500x10* lb/yr 

7,900x10* Ib/yr fr. 

490x10* Ib/yr 

7 

7 

7 

7 

7 

7 

7 fr. e- 7 

7 

7 

7 

? 

7 

7 

fr. 

7 

7 

7 

7 

• 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

n/ad 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

See end of table for footnotes. 

22 
EXAMPLE ORGANIC LIQUIDS WITH HAP CONTENT (Concluded) 

ITS 

Stored Liquid 

MTBE 

Methanol 

Methylchloroform 

Methylene chloride 

Methyl methacrylate 

Methyl ethyl ketone 

Methyl isobutyl ketone 

Perchloroethylene 

Phenol 

Phthalic anhydride 

Styrene 

Toluene 

Vinyl acetate 

Vinyl chloride 

o-xylene 

p-xylene 

True Vapor 

Pressure 

4.74 

1.93 

1.9 

7.39 

0.62 

1.46 

0.04 

0.36 

0.01 

0.19 

0.19 

0.45 

1.87 

14.7 

0.10 

0.14 

Temp. 

°F 

70 

70 

68 

70 

75 

70 

70 

77 

70 

50 

93 

70 

70 

6.8 

70 

70 

Annual Volume 

8,140x10* lb/yr 

11,100x10* lb/yr 

335x10* lb/yr 

375x10* Ib/yr 

1,372x106 Ib/yr 

584x10* Ib/yr 

7 

4,100x10* Ib/yr 

4,100x10* lb/yr 

820x10* Ib/yr 

7,622x10* lb/yr 

698x10* Ib/yr 

2,112x10* lb/yr 

9,463x10* Ib/yr 

675x10* Ib/yr 

4,779x10* lb/yr 

HAP Concentration in 

Vapors (g/ms) 

Range 

7 

7 fr. 

? 

7 

• 

7 

? 

7 

• 

? 

7 

7 fr. 

7 ••a 

7 

• 

7 

Average 

7 

7 

7 

7 

7 fr. 

7 

7 

7 

7 

7 

7 

• 

7 

7 fr. 

7 

Number of Data 

Points 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

'Industry survey results for the Petroleum Refineries NESHAP, prepared by Radian Corporation, August 10,1993. 

bChemical and Engineering News, June 1996, and Chemcyclopedia 1996; all annual volumes are based upon 1995 data. Methylene 

chloride and methylchloroform annual volumes are based upon 1994 data. 

'National Petroleum News, Mid-June 1995. 

d

n/a stands for not applicable. 

23 
P.57 

EMISSION FACTORS 

(2) 

Models and Methods 

- Storage tanks 

- AP-42, Section 7.1 (TANKS3 software) 

- Liquid transfer 

- AP-42, Section 5.2 

- Equipment leaks 

- emission factors available for chemical production 

facilities 

- factors for petroleum refineries 

- factors for gasoline marketing operations 

- Wastewater air emissions 

- collection and treatment system model (Water 8) 

Facihty Parameters (established as part ofthe model 

industry) 

24 
P.58 

EMISSION CONTROLS 

Storage Vessels 

• Route vapors to control device 

- oxidizer (thermal or catalytic) <98% control> 

- carbon adsorption <9S% controt> 

-flare <98%contro> 

-condenser <95%control> 

- scrubber <95% control> 

• Floating roof (internal or external) 

- rim seal types and fitting controls 

• Pressurized or refrigerated tanks 

Liquid Transfer/Loading 

• Route vapors to control device 

- devices similar to storage vessel controls 

• Vapor-tight vessels (trucks, railcars) 

• Vapor balancing 

Equipment Leaks 

• Modify or replace existing equipment 

• Leak detection and repair (LDAR) program 

(instrument or visual program) 

Wastewater 

• Vent to a control device 

• Floating roof or vapor-tight cover 

• Closed piping 

• Drain controls (p-traps, water seals, etc.) 

25 
P.59 

CURRENT CONTROL LEVELS 

Information on potential levels of control is being 

obtained from: 

• Federal NESHAP (40 CFR Parts 61 and 63) 

Petroleum Refinery NESHAP (subpart CC) 

Gasoline Distribution NESHAP (subpart R) 

Oil & Natural Gas Production/Natural Gas Transmission 

& Storage NESHAP (subparts HH, HHH) [proposed] 

Marine Vessel Loading NESHAP (subpart Y) 

Hazardous Organic NESHAP (HON) (subparts F, G, H, I) 

Miscellaneous Organic NESHAP (MON) [pre-proposal] 

Storage Vessel NESHAP (subpart WW) [pre-proposal] 

Oil-Water Separators (subpart W) 

Benzene Storage Vessel NESHAP (40 CFR 61, subpart Y) 

Benzene Waste Operations NESHAP (40 CFR 61, subpart 

FF) 

Off-Site Hazardous Waste NESHAP (subpart DD) 

Benzene Transfer Operations NESHAP (40 CFR 61, 

subpart BB) 

Federal NSPS Rules (40 CFR Part 60) 

• Storage Vessels (subpart Kb, etc.) 

• Bulk Gasoline Terminals (subpart XX) 

26 

5°V 
P.60 

CURRENT CONTROL LEVELS 

(2) 

Industry Data 

• Plant visits 

- several visits were made in December 1997 and April 

1998, and more are planned 

• Survey responses 

- detailed survey: 

• sent to a limited number of facilities 

• specific facility types 

• specific types of liquids (cutoffs for vapor 

pressure and HAP content) 

• operations not covered by other MACT rules 

facility size *50% of 10/25 tpy HAP 

criteria 

27 

Co 
P.61 

CURRENT CONTROL LEVELS 

(3) 

State/Local Rules (Examples) 

• Storage Vessels - California and Illinois rules 

among the most stringent 

• tanks > 10,000 gallons, > 1.9 psia, QL 

• tanks > 19,800 gallons, > 1.5 psia, QL 

• tanks > 39,630 gallons, > 0.5 psia: 

floating roof or vapor control at 95% by weight 

• any capacity, > 11 psia: 

pressure tank with no detectable organic emissions 

or vapor control at 95% by weight 

• Transfer Operations -Texas and California rules 

among the most stringent 

• > 0.5 psia: vapor control at 90% (Texas-Houston) 

• Wastewater Operations - The HON, Connecticut, 

Virginia, and Hawaii rules among the most 

stringent 

• tanks > 20,000 gallons: Fixed Roof 

• tanks > 20,000 gallons, > 1.5 psia, fir 

• tanks > 40,000 gallons, > 0.5 psia: 

floating roof or vapor control at 95% by weight 

• Individual Drain Systems: Vapor Suppression 

28 

(A 
P.62 

ISSUES/QUESTIONS 

Which facilities/emission sources should be 

included in the source category? 

Are there significant emission sources at 

compounding and packaging operations? 

Impact of the other Federal air rules 

• Do these rules adequately cover (or will they cover) 

collocated distribution emission sources? 

• Which emission sources in categories that are 

regulated (or will be regulated under other rules) 

should be considered for regulation under the OLD 

standards? 

Impact on or from other media standards 

Water (Benzene Waste NSPS?) 

• Solid waste 

• Other standards? 

• Investigation of these rules is continuing 

29 

6z 
P.63 

ISSUES/QUESTIONS 

(2) 

Major/Area Sources 

• Some owners and operators are small businesses 

- investigating these numbers 

• Must regulate area sources if they present 

"a threat of adverse effects to human health 

or the environment" (§112(c)(3)) 

• Looking into simple mechanisms to distinguish 

area sources from major sources (throughput, 

equipment size, etc.) 

• How does the potential to emit (PTE) concept 

apply to these operations? 

Need additional information to define industry 

and complete industry profile 

• Industry survey 

• Completion of data collection for MACT floor 

determination 

• HAP content of mixtures 

30 

(ft 
P.64 

Attachment 2 

MEMORANDUM 

TO: Steve Shedd 

U. S. Environmental Protection Agency, ESD/WCPG 

FROM: Jay Helms 

Pacific Environmental Services, Inc. (PES) 

DATE: April 24, 1998 

P:\N812 

SUBJECT: Orgamc Liquids Distribution NESHAP: State Rules Summary 

The following tables summarize the State and local regulations reviewed by PES. The 

summary is organized in terms of stringency of regulation. The dashed lines separate 

individual rules, while the solid lines separate groups of rules by stringency level. 

(oH 
P.65 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

State 

California, 

South Coast 

California, 

Bay Area 

California, 

Ventura 

County 

Illinois 

(Chicago) 

California, 

San Diego 

California, 

Ventura 

County 

California, 

Ventura 

County 

California, 

Bay Area 

California, 

San Joaquin 

Colorado 

Indiana 

New York 

Virginia 

Regulation 

463 

8-5-300 

71.2 

218.119-120, 

Subpart B 

61 

71.2 

71.2 

8-5-300 

4623 

5CCR 1001-9 

Reg # 7 

326IAC 8-9 

Section 229 

9 VAC 5-40-

1390 

AoDlicabilitv 

Storage vessels; > 

19,815 gallons; > 

39,630 gallons 

Storage vessels; > 

39,626 gallons 

(150m3) 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; > 

40,000 gallons; 

Plants > 5,000,000 

gal/yr 

Storage vessels; > 

10,000 gallons, < 

20,000 gallons 

Storage vessels; > 

20,000 gallons, < 

40,000 gallons 

Storage vessels; 

>19,813 gallons 

(75m3),< 39,626 

gallons (150m32 

Storage vessels; > 

19,800 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40.000 gallons 

Process/Products 

Organic Liquids; > 1.5 psia; 

> 0.5 psia 

Organic liquids; > 0.5 psia 

Organic liquids; >0.5 psia 

VOL; >0.75 psia VPL: 

> 1.5 psia 

Organic liquids (VOC); 

RVP> 3.0 psia 

Organic liquids; >1.5 psia 

Organic liquids; >1.5 psia 

Organic liquids; > 1.5 psia 

Organic Liquids (including 

crude oil & petroleum 

distillates); > 1.5 psia 

Petroleum liquids; >0.65 psia 

Organic liquids; >0.75 psia, 

<ll.l_psia 

Organic liquids; >1.0 psia 

Petroleum liquids; >1.5 psia 

Standards/Reauirements 1 

External floating roof, internal 

floating-type cover, or vapor 

recovery system (95% by weight) 

Vapor loss control device-95% by 

weight efficiency 

External or internal floating roof 

or vapor recovery system (95% by 

weight) 

VOL: IFR, EFR, or approved 

control device (95% VOC 

reduction or greater-90% if 

installed before 1993). VPL: 

Floating roof or control system at 

85% 

Floating roof or vapor control 

system-95% 

Permanent submerged fill pipe; 

pressure relief valve (90%); 

external or internal floating roof oi 

vapor recovery system (95% by 

weight^ 

Permanent submerged fill pipe; 

external or internal floating roof or 

vapor recovery system (95% by 

weight) 

Vapor loss control device-95% by 

weight efficiency 

Floating roof tank, or vapor 

control system-95% 

Floating roof, vapor recovery 

system, or equivalent 

Various fixed roof requirements 

Floating roof and vapor control 

system 

40 CFR 60, Subpart Kb 

& 
P.66 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Continued) 

1 State 

S. Dakota 

Kentucky 

Arkansas 

Maine 

Nebraska 

Oregon 

Connecticut 

Kentucky 

Connecticut 

Rhode Island 

Mass. 

Regulation 

74:36:07:14 

401 KAR 59:485 

19.10.5.1 

Chapter 111 

340-22-160 

Section 22a-174-

20 

401 KAR 59:050 

Section 22a-174-

20 

11.2 

310 CMR 7.24 

Applicability 

Storage vessels 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>39,000 gallons 

Storage vessels 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Process/Products 

Organic liquids 

Organic liquids 

Petroleum liquids; >1.52 psia 

Petroleum liquids; >1.52 psia 

Organic liquids 

Organic liquids; >1.52 psia 

Organic liquids; >1.5 psia 

Petroleum liquids; >1.5 psia, 

<11.1 psia 

Organic liquids; >1.5 psia, < 

11.0 psia 

Petroleum liquids; >1.52 psia 

Organic liquids; >1.5 psia 

Standards/Reauirementsl 

40 CFR 60, Subpart Kb 

40 CFR 60, Subpart Kb 

40 CFR 60.110-NSPS for 

Storage vessels for Petroleum 

liquids; or floating roof or cover 

Vessels w/ fixed roof; 40 CFR, 

part 60, Subparts K, Ka, & Kb 

Subparts K, Ka 

Floating roof; subparts K, Ka 

Vapor recovery system (95% by 

weight); permanent submerged fill 

pipe 

Extemal floating roof (w/specific 

seals); fixed roof intemal floating 

roof; vapor recovery system (95% 

by weight VOC); or an equivalent 

system 

Fixed roof & floating roof, or 

vapor recovery system (95% by 

weight); permanent submerged fill 

pipe 

Vessels w/ fixed roof; VOC 

reduced by 95% using a vapor 

recovery system 

Submerged fill pipe required; and 

an external floating roof or both a 

pressure tank system & a vapor 

recovery system (95% emission 

reduction) 

u 
P.67 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Continued) 

State 

Kansas 

District of 

Columbia 

Michigan 

Texas 

Florida 

Washington 

North Carolina 

Wisconsin 

Kentucky 

Maryland 

Vermont 

Nevada 

Regulation 

28-19-65 

701 

R 336.1604 

Section 115.112: 

Subchapter A 

62-296.508 

WAC 173-490-

040 

.0925 

NR 419.05 

401 KAR 59:050 

26-11-13.03 

5-253.1 

445B.395 

Applicability 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000jallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>42,000 gallons 

Storage vessels; 

>40,000jallons 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40.000 callons 

Process/Products 

Organic liquids; >1.5 psia 

Petroleum liquids; >1.5 psia 

Organic liquids; >1.52 psia, 

< 11 psia 

Organic liquids; > 1.5 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.52 psia 

Organic liquids; >1.52 psia 

Petroleum liquids; >1.5 psia, 

<11.1 psia 

Organic liquids; >1.5 psia, 

<11.1 psia 

Petroleum liquids; > 1.52 psia 

Organic liquids; > 1.5 psia 

Standards/Reauirements 

Floating roof (< 11.1 psia) or 

vapor control system-90%, or 

equivalent; Pressure tank sealed or 

vented to a vapor control system 

0>U.l psia) 

Pressure tank or vapor loss control 

devices 

Pressure tank, floating cover or 

roof, vapor recovery system (90% 

by weight) 

Floating roof or vapor recovery 

system~90% 

Floating roof 

Floating roof or equivalent 

Floating roof 

Floating roof, vapor condensation 

system, vapor holding tanks, or 

equivalent 

Floating roof or vapor recovery 

system, or their equivalents 

Floating roof, vapor control 

system, pressure tank, or 

equivalent 

Vessels w/ fixed roof must be 

equipped with an internal floating 

roof 

Floating roof (<11 psia) or 

eauivalent; Submerged fl" TMTM 

^ 
P.68 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Continued) 

State 

South Carolina 

New Mexico 

West Virginia 

Wisconsin 

Hawaii 

Arizona 

Missouri 

Utah 

Indiana 

Illinois 

New Jersey 

Oklahoma 

North Carolina 

Penns. 

Regulation 

62.5, part 0 

NMAC 2.37.205 

45-21-27 

NR 420.03 

11-60.1-39 

RI 8-2-710 

10 CSR 10-2.260 

R307-14-2 

326IAC 8-4-3 

218.121, Subpart 

B 

7:27-16.2 

252:100-37-15 

.0518 

129.56-57 

Applicability 

Storage vessels; 

>40,000 gallons 

Storage vessels; > 

250,000 (65,000-

newjgallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000jallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>50,000 gallons 

Storage vessels; 

>40.000 gallons 

Process/Products 

Petroleum liquids; >1.5 psia 

Organic liquids; > 3.0 (1.5-

new) psia, <11.0 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; > 1.52 

gsia, < 11.1 psia 

VOCs;> 1.5 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.52 psia 

Petroleum liquids; > 1.52 

psia; 

Petroleum liquids; >1.5 psia, 

<12.5 psia 

Organic liquids 

Organic liquids 

Organic liquids; >1.5 psia 

VOCs: >1.5 psia 

Standards/Reauirements 

Floating roof or equivalent 

Floating roof; vapor recovery 

system 

External floating roof tanks have 

seal reaquirements; fixed roof 

tanks must have internal floating 

roof or equivalent 

Floating roof, vapor recovery 

system, or equivalent 

Floating roof or a vapor recovery 

& disposal system 

Floating roof or equivalent (if 

liquid>12 gsia} 

Floating roof, vapor recovery 

system, or equivalent 

Floating roof 

Floating roof 

Floating roof 

Miscellaneous; See Table 2A 

Pressure tank, floating roof, vapor 

recovery system, or equivalent 

Pressure tank, floating roof, vapor 

recovery system, or equivalent 

Floating roof or vapor recovery 

svstem-80% 

£>S 
Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Continued) 

State 

New 

Hampshire 

Illinois 

Montana 

New Jersey 

Minnesota 

Alaska 

California, 

San Diego 

Colorado 

New Mexico 

California, 

Ventura 

County 

Indiana 

Kentucky 

Regulation 

Env-A 1204.20 

215.121, Subpart 

B 

17.8.324 

7:27-16.4 

7011.1505 

18 AAC 50.085 

61 

5CCR 1001-9 

Reg #7 

NMAC 2.37.205 

71.2 

326 IAC 8-9 . 

401 KAR 59:050 

Applicability 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>65,000 gallons 

Storage vessels; > 

2,000 gallons 

Storage vessels; > 

2,000 gallons & < 

40,000 gallons 

Storage vessels; 

>378,000 gallons 

Storage vessels 

Storage vessels 

Storage vessels; > 

250,000 gallons 

Storage vessels 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40.000 gallons 

Process/Products 

Organic liquids; >1.52 psia; 

fixed roofs 

Organic liquids >2.5 psia 

Petroleum liquids or Crude; 

>2.5 psia 

Organic liquids 

Petroleum liquids; >1.5 psia, 

< 11.1 psia 

Volatile liquids 

Organic liquids; > 11 psia 

Organic Liquids; > 11 psia 

Organic liquids; >11.0 psia 

Organic liquids; > 11 psia 

Organic liquids >11.1 psia 

Petroleum liquids; >11.1 psia 

Standards/Reauirements 1 

Various seal & vent requirements; 

RACT. 

<12.5 psia-floating roof, >12.5 

psia-vapor recovery system 

consisting of vapor disposal 

system (85%) 

Pressure tank, floating roof (< 13 

psia), vapor recovery system, or 

equivalent 

> 1000 Lb VOC/year: vapor 

control (90%), floating roof, or 

vapor balance system 

Permanent submerged fill pipe; 

floating roof, vapor recovery 

system, or equivalent 

Internal floating roof, closed vent 

system & vapor control-95% 

BACT 

Pressure tank 

Pressure vessel 

Pressure tank; vapor recovery 

system, or equivalent (95% by 

.weiglLQ 

Closed vent system (<500 ppm) 

and an approved control device 

(95% VOC reduction or greater) 

Vapor recovery system-95% by 

weifht. 

^ 
P.70 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Continued) 

State 

Michigan 

Texas 

Wisconsin 

New Jersey 

Illinois 

Minnesota 

Wyoming 

New York 

South Carolina 

Washington 

Michigan 

Illinois 

Illinois 

Oklahoma 

Kentucky 

Regulation 

R 336.1605 

Section 115.112: 

Subchapter A 

NR 420.03 

7:27-16.2 

218.121, Subpart 

B 

7011.1505 

Section 229 

62.5, part P 

WAC 173-490-

201 

R 336.1623 

215.124, Subpart 

B 

215.122 & 

218.122, Subpart 

B 

252:100-39-48 

401 KAR 59:050 

Applicability 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>25,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

> 1,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; > 

2,000 gallons & < 

40,000 gallons 

Storage vessels; 

>65,000 gallons 

Storage vessels; 

>20,000 gallons 

Storage vessels; 

>39,600 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels 

Storage vessels; > 

250 gal 

Storage vessels; 

<40,000 gallons 

Storage vessels; 

>580 gallons 

Process/Products 

Organic liquids; >11 psia 

Organic liquids; > 11 psia 

Petroleum liquids; >11.1 psia 

Organic liquids; > 13.0 psia 

Petroleum liquids; >12.5 psia 

Petroleum liquids; >11.1 psia 

Petroleum liquids; RVP>5 

lbs 

Organic liquids; >4.0 psia 

External Floaters 

Extemal Floaters 

Petroleum liquids; >1.0 psia, 

but < 11 psia 

Petroleum liquids 

Organic material 

Organic liquids 

Petroleum liquids; >1.5 psia 

Standards/Reauirements 

Pressure tank, vapor recovery 

system-90%, or equivalent 

Submerged fill pipe and vapor 

recovery system-90% 

Vapor recovery system or 

equivalent 

Vapor control system at 90% by 

weight 

Vapor recovery system consisting 

of vapor disposal system (85%) 

Permanent submerged fill pipe; 

vapor recovery system, or 

equivalent 

Pressure tank 

Various seal & vent requirements 

Various seal requirements 

Various seal requirements 

External floating roof tanks: 

various seal requirements 

External floating roof tanks: 

various seal requirements 

Permanent submerged fill pipe 

> 400 gallons-submerged pipe or 

bottom fill; >2000 gallons-vapor 

control system £90% by weigh^ 

Permanent submerged fill pipe 

to 
P.71 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Continued) 

I State 

North Dakota 

Arizona 

California, 

Bay Area 

New Jersey 

Wisconsin 

Georgia 

Florida 

Illinois 

Kansas 

Indiana 

Washington 

Virginia 

Morth Carolina 

Illinois 

Regulation 

33-15-07-01 

R18-2-905 

8-5-300 

7:27-16.4 

NR 419.05 

VV 

62-296.508 

215.123, Subpart 

B 

28-19-65 

326IAC 8-4-3 

WAC 173-490-

201 

9 VAC 5-40-

1390 

.0925 

215.123, Subpart 

B 

Applicability 

Storage vessels; 

> 1,000 gallons 

Storage vessels; 

<40,000jallons 

Storage vessels; 

<39,626 gallons 

(150 m3) 

Storage vessels; > 

2,000_gallons 

Storage vessels; > 

1000 gallons 

Storage vessels; 

>4,O0O gallons 

Storage vessels; 

<422,400 gallons 

Storage vessels; 

<422,400 gallons 

Storage vessels; 

<422,400 gallons 

Storage vessels; 

<420,000 gallons 

Storage vessels; 

<420,000 gallons 

Storage vessels; 

<420,000 gallons 

Storage vessels; 

<416,000 gallons 

Storage vessels; 

<378,000 gallons 

Process/Products 

Organic liquids 

Petroleum liquids 

Organic liquids; >0.5 psia 

Organic liquids 

Organic liquids; >1.52 psia 

Organic liquids 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Crude & condensate prior to 

lease custody transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced oil or condensate in 

crude oil gathering 

Standards/Requirements 1 

Permanent submerged fill pipe 

Submerged filling device 

Permanent submerged fill pipe 

Permanent submerged fill pipe 

Permanent submerged fill pipe 

Permanent submerged fill pipe 

Exempt 

Exempt 

Exempt 

Exempt 

Exempt 

Exempt 

Exempt 

Exempt 

*\v 
P.72 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Concluded) 

State 

Indiana 

South Carolina 

Washington 

Maryland 

Regulation 

326IAC 8-4-3 

62.5, part P 

WAC 173-490-

201 

26-11-13.02 

Applicability 

Storage vessels 

Storage vessels 

Storage vessels 

Storage vessels 

Process/Products 

Petroleum liquids; < 4.0 psia 

Petroleum liquids; >1.5 psia, 

<4psia 

Petroleum liquids; >1.5 psia, 

<4psia 

Petroleum liquids; >1.5 psia, 

<4nsia 

Standards/Reauirements 

Vessel of welded construction, 

having proper closure device 

If the tank is a welded tank, no 

other control is necessary 

If the tank is a welded tank, no 

other control is necessary 

If the tank is a welded tank, no 

other control is necessary 

7 ^ 
Attachment 2 

STATE REGULATIONS SUMMARIES, TRANSFER OPERATIONS 

State 

California, 

South Coast 

California, 

San Joaquin 

Alaska 

California, 

Bay Area 

Texas 

Oklahoma 

New Jersey 

California, 

San Joaquin 

Louisiana 

Oklahoma 

California, 

Ventura 

County 

Connecticut 

Wisconsin 

Regulation 

462 

4624 

18 AAC 50.090 

8-6-300 

Section 115.211-

: Subchapter C 

252:100-39-48 

7:27-16.5 

4624 

33:111:2107 

252:100-37-16 

71.3 

Section 22a-174-

20 

NR 419.05 

Applicability 

TT/railcar transfer 

operations; > 20,000 

gallons/day 

TT/railcars: Class 1 

(>20k gal/day). 

Class2(4k-20k 

__ -MML 

Transfer operations; 

> 15 million 

gallons.year 

Transfer operations 

• Transfer operations 

Transfer operations 

Transfer operations; 

6,000,000 

gallons/year thruput 

Transfer operations; 

> 20,000 gallons/day 

Transfer operations; 

> 20,000 gallons/day 

Transfer operations; 

> 40,000 gallons/day 

Transfer Operations 

>20,000 gallons/day; 

> 150,000 

gallons/year 

Transfer operations; 

> 10,000 gallons/day 

Transfer operations; 

>40.000 gallons/dav 

Process/Products 

Organic liquids; > 1.5 psia 

Organic liquids; > 1.5 psia 

Volatile liquids 

Organic liquids 

Organic liquids; > 0.5 psia 

Organic liquids 

Organic liquids 

Organic liquids; > 1.5 psia 

Organic liquids; > 1.5 psia 

Organic liquids 

Organic liquids; > 1.5 psia 

Organic liquids; >1.5 psia 

Organic liquids; >1.52 psia 

Standards/Reauirements 

Vapor recovery and/or disposal 

system = 0.29 lb VOC/1,000 

gallons organic liquid transferred; 

after Feb. 1998-0.08 lb 

VOC/1,000 gallons organic liquid 

transferred 

Class 1: 0.08 lb/1,000 gal. Class 

2: 95% by weight 

lOmg/L emission limit 

21 mg/L emission limit 

Vapor recovery system (90%) or 

vapor balance system 

ab(d)sorption system-90% by 

weight; vapor handling systemdisposal efficiency of 95%. 

95% by weight VOC emission 

reduction 

95% by weight efficient reduction 

ofVOCs 

Vapor collection system-90% 

Vapor collection system or bottom 

loading with closed hatches; 

Disposal—90% by weight by 

means of a vapor liquid absorber 

system. 

Bottom loaded vapor recovery 

system including a vapor 

return/condenstion system or a . 

vapor disposal system at 90% by 

weight 

Vapor collection adaptor; vapor 

tight seal 

Vapor collection & disposal 

svstem 

-ft 
P.74 

Attachment 2 

STATE REGULATIONS SUMMARIES, TRANSFER 

OPERATIONS (Continued) 

State Regulation Applicability Process/Products Standards/Requirements 

Texas Section 115.211 - Transfer operations 

: Subchapter C 

Michigan R 336.1609 Transfer operations; 

>5,000,000 

gallons/year 

throughput^ 

Organic liquids; > 1.5 psia Vapor-tight vapor recovery system 

Organic liquids; > 1.5 psia Vapor recovery system; 0.7 

lb/1000 gallons emission limit 

Massachusetts 310 CMR 7.24 Transfer Operations; 

CM,MB,MV,PV, 

SM Bulk Plants 

Organic material > 1.5 psia Vapor balance system required; 

transfer must take place through a 

submerged fill pipe 

New Mexico NMAC 2.37.205 Transfer operations 

Massachusetts 310 CMR 7.24 Transfer Operations; 

U Bulk Terminals 

Organic liquids; > 1.5 psia Loading arm with a vapor 

collection adapter; a means to 

prevent organic compound drainge 

_ from loading device 

Organic liquids; > 1.5 psia Vapor collection & disposal 

system required; 80 mg/liter 

emission limit 

California, 

Ventura 

County 

71.3 Transfer operations Organic liquids; > 0.5 psia Submerged fill pipe, or bottom 

loading 

Illinois 218.122, Subpart TT/railcar transfer 

(Chicago) B operations; >40,000 

gallons/day 

Organic liquids; >2.5 psia if Emission limit of 8 Ibs/hr, 

no odor nuisance submerged loading, or equivalent 

North Dakota 33-15-07-01 Transfer operations; 

> 20,000 gal/day 

Organic liquids Submerged filling arm or other 

North Carolina .0948 Transfer operations; 

> 20,000 gal/day 

Organic liquids; > 1.5 psia Submerged loading through 

bottom loaders or equivalent 

Colorado 5CCR 1001-9 Transfer operations; 

Reg # 7 >56 gallons 

VOCs Submerged or bottom loading; 

top-fill pipe to within 6 inches of 

the bottom ofthe tank 

Wisconsin NR 419.05 Transfer operations; 

< 40,000 gal/day 

Organic liquids; > 1.52 psia Submerged fill pipe extending to 

within 6 inches ofthe tank (vessel) 

bottom 

California, 71.3 Transfer Operations 

Ventura >20,000 gallons/day; 

County > 150,000 

gallons/year 

Organic liquids; > 0.5 psia Overfill protection system 

New Mexico NMAC 11.65.II.6 Transfer operations Organic liquids; > 15.0 psia Emission limit-2.21bs/6,000 

gallons loaded; same for > 1.5 psia 

&.< 15.0psia, if>l,000 

gallons/month (unless there is a 

vapor emission control system) 

Louisiana 33:111:2107 Transfer operations; 

Marine vessels 

Organic liquids; >1.5 psia; 

>100 tons/yr uncontrolled 

emissions 

Vapor collection system-90%; 

Barge-Crude=30mg/L; Shipcrude=12mcr/L 

7Y 
Attachment 2 

STATE REGULATIONS SUMMARIES, TRANSFER 

OPERATIONS (Concluded) 

State Regulation 

Massachusetts 310 CMR 7.24(8) 

Rhode Island 

Maine 

New Jersey 

California, 

San Diego 

California, 

San Diego 

Oklahoma 

Michigan 

32.2 

Chapter 600 

7:lE-3 

61 

61 

252:100-37-16 

R 336.1706 

Applicability 

Transfer operations 

Transfer operations 

Transfer operations 

Transfer operations 

Transfer Operations; 

Both mobile 

transport and 

stationary storage 

tank > 550 gallons 

Transfer operations; 

mobile transport 

tank > 550 gallons 

Transfer operations; 

< 40,000 gal/day 

Transfer operations; 

>5,000,000 

gallons/year 

throughput 

Process/Products 

Marine vessel previous 

cargo—organic liquid 

Marine vessel previous 

cargo—organic liquid 

Petroleum liquids 

Pipelines 

Organic liquids 

Organic liquids 

Trucks (vessels); > 200 

gallons 

Crude Oil > 1.5 psia 

Standards/Rea uirements 

95% emission reduction by 

recovery device or 98% by weight 

by combustion device; and 2 

lb/1,000 bbls emission limit 

VOC reduced by 95% by weight; 

98% by weight if a control device 

is used 

Miscellaneous minor requirements 

Conform to 49 CFR 195, 

"Transportation of Liquids by 

Pipeline" 

Equipped with a submerged fill 

pipe; 95% by weight VOC 

90% by weight of VOC; 0.29 lb 

VOC/1,000 gallons loaded; 

pressure may not exceed 18 inches 

of water 

Aggregate loading pipes equipped 

to fill-97% submergence must be 

maintained 

Vapor recovery system; 0.7 

lb/1000 gallons emission limit; or 

submerged fill pipe 

7<> 
P.76 

Attachment 2 

STATE REGULATIONS SUMMARIES, WASTEWATER OPERATIONS 

State 

Virginia 

Washington 

Montana 

North 

Dakota 

Hawaii 

Maryland 

Louisiana 

Califomia, 

Ventura 

County 

California, 

Bay Area 

Maryland 

North 

Carolina 

New Jersey 

New Jersey 

South 

Carolina 

Arizona 

Regulation 

9 VAC 5-40-1390 

WAC 173-490-

040 

17.8.324 

33-15-07-01 

11-60.1-40 

26-11-13.06 

Section 2153: 

Subchapter M 

71.3 

8-5-328 

26-11-13.06 

.0518 

7:lE-2 

7:1 E-4 

62.5, part O 

RI 8-2-905 

Applicability 

Wastewater 

Separators 

Wastewater 

Separators 

Wastewater 

Separators; >200 

gal/day 

Wastewater 

Separators; >200 

gal/day 

Wastewater 

Separators; >200 

gal/day 

Wastewater 

Separators; >200 

gal/day 

SIC Codes: 28-21, 

23,24,33,34,36, 

65,69,79 & 49-52, 

53,59. 

Delivery Vessels 

Wastewater; Tank 

Cleaning 

Waste 

Waste 

Process/Products 

Any petroleum liquid => 

kerosene in volatility 

Any volatile organic liquid 

VOCs; > 0.5 psia 

VOC; > 1.5 psia 

VOC Wastewater - storage, 

handling, transfer, or 

treatment. 

Organic liquids 

Organic liquids; >0.5 psia 

VOC 

Photochemically reactive 

VOC 

Storage, transfer, equipment leaks 

Storage, transfer, equipment leaks 

Equipment leaks 

Pumps & 

compressors 

Tanks 

VOC 

Standards/Requirements 

Vapor control system-95% 

Floating roof or fixed & sealed 

solid cover 

Floating roof or a vapor recovery 

& disposal system 

Floating roof, a vapor recovery & 

vapor disposal system, or 

equivalent 

Floating roof or a vapor recovery 

& vapor disposal system 

Floating roof, a vapor recovery 

system, or equivalent 

Reduce the VOC content ofthe 

stream by 90 percent (85 percentfor biotreatment units) & reduce 

the VOC content to less than 100 

ppm by weight. Also, various 

requirements for WW storage 

tanks. 

Vapor recovery system; pressurevacuum relief device; secondary 

overfill protection; loading 

connector/adapter 

Liquid balancing; 90% by weight 

efficiency 

Cannot discharge >200 lbs unless 

the discharge is reduced by 85% 

Cannot discharge >40 lbs unless 

the discharge is reduced by 85% 

See the rule 

Submit a DPCC plan, 

demonstrating compliance with 

7:lE-2 

Monthly inspection through the 

roof hatch; complete inspection of 

cover & seal whenever tank is 

emptied or non-operational for a 

year 

Mechanical seals or equivalent 

7£