FROM: Jeff Coburn, RTI International

TO: Brenda Shine, EPA/OAQPS/SPPD

FOR: Docket ID No. EPA-HQ-OAR-2010-0682

DATE: November 14, 2012

SUBJECT: Impacts for Control Options for Stor age Vessels at Petroleum Refineries

1. Purpose

This memorandum documents the costs and envi ronmental impacts asso ciated with technology review control options identified for st orage vessels at pe troleum refineries.

2. Background

Storage vessels are used to store liquid and gase ous feedstocks for use in a process and liquid and gaseous products from a process. Most storage vessels are designed for operation at atmospheric or near atmospheric pressures; high pressure vessel s are used to store compressed gases and liquefied gases. Atmospheric storage ve ssels are typically cylindr ical with a vertical orientation, and they are constructe d with either a fixed roof or a floating roof. Some, generally small, atmospheric storage vessels are oriented horizontally. High pressu re vessels are either spherical or horizontal cylinders. All of the storage vessels in this analysis are aboveground storage vessels; underground stor age tanks are not considered.

The Refinery MACT 1 rule (40 CFR part 63, subp art CC) requires “Group 1 storage vessels” to install certain controls to reduce the emissions of organic hazardous air pollutants (HAP) from these storage vessels. The Refinery MACT 1 ru le defines “Group 1 storage vessels” as follows:

Group 1 storage vessel means a storage vessel at an existing source that has a design capacity greater than or equal to 177 cubic meters and stored-liquid maximum true vapor pressure greater than or equal to 10.4 kil opascals and stored-liquid annual average true vapor pressure greater than or equal to 8.3 kilopascals and annual average HAP liquid concentration greater than 4 percent by weight total organic HAP; a storage vessel at a new source that has a design storage capacity greater than or equal to 151 cubic meters and stored-liquid maximum true vapor pressure greater than or equal to 3.4 kilopascals and annual average HAP liquid concentration greater than 2 percent by weight total organic HAP; or a storage vessel at a new source that has a design storage capacity greater than or equal to 76 cubic meters and less than 151 cubic meters and stored-liquid maximum true vapor pressure greater than or equal to 77 kilopascals and annual average HAP liquid concentration greater than 2 percent by weight total organic HAP.

Section 63.646(a) of the Refinery MACT 1 rule re quires Group 1 storage ve ssels to comply with 40 CFR 63.119 through 40 CFR 63.121 of 40 CFR part 63, subpart G (National Emission Standards for Organic Hazardous Air Pollutant s from the Synthetic Organic ChemicalTechnical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

2 Manufacturing Industry for Process Vents, St orage Vessels, Transfer Operations, and Wastewater; commonly referred to as the “Haza rdous Organic NESHAP” or simply “HON”). Under 40 CFR 63.119 through 63.121, storage vessels must be equipped with an internal floating roof with proper seals, an exte rnal floating roof with proper seals, an external floating roof converted to an internal floating roof with prope r seals or a closed vent system routed to a control device that reduces HAP emissions by 95 percent or to 20 parts per million by volume (ppmv). Storage vessels at existing sources that use floating roofs are not required under Refinery MACT 1 to install certain fitting controls include d in 40 CFR 63.1119 of subpart G ( e.g. , gaskets for automatic bleeder vents, slit fabric covers for sample wells, flexible fabric seals or gasketed sliding covers for guidepoles and ga sketed covers for other roof openings). See 40 CFR 63.646(c).

The Clean Air Act (CAA) requires the U.S. Envi ronmental Protection Agency (EPA) to review promulgated standards periodically to ensure th at new source performance standards (NSPS) and national emissions standards for hazardous ai r pollutants (NESHAP) reflect advances in emissions reduction technology. Sp ecifically, section 112(d)(6) of the CAA states that “[t]he Administrator shall review, and revise as ne cessary (taking into acc ount developments in practices, processes, and control technologies), emission standards promulgated under this section no less often than every 8 years.” Sim ilarly, section 111(b)(1)(B ) requires the EPA to review NSPS for a given source category every 8 years, and, if appropriate, revise such standards. As part of its review of the Refinery MACT 1 rule, the EPA is considering developments in practices, processes, and contro l technologies for storag e vessels at petroleum refineries. This memorandum documents this technology review for storage vessels and summarizes the impacts of potentia l regulatory options identified.

3. Description of Emission Releases and Controls

3.1 Fixed Roof Storage Vessels

Emissions from fixed roof storage vessels (bot h vertical and horizonta l vessels) occur from working losses, breathing loses, and leaks. Working losses are the combined emissions from filling and emptying the storage vessel. Emissi ons during filling operations result from an increase in the liquid level in the storage vessel. As the liquid level increases, the pressure inside the tank exceeds the relief pressure and vapors ar e expelled from the storage vessel. Emissions also occur as a result of withdrawing liquid from the storage vessel because some of the stored liquid evaporates to partially saturate the air that is drawn in as the liquid is withdrawn. This increase in the amount of vapor causes the pre ssure to increase; as when filling the storage vessel, when the pressure exceeds the relief pres sure, the vent opens and vapors are released to the atmosphere. Factors that affect the mass of wo rking losses include the saturation level of the pollutant in the vapor space, vapor pressure of the stored material, vapor molecular weight, total throughput, and capacity of the storage vessel.

Breathing (or standing) losses ar e emissions caused by vapor expa nsion and contraction, which are the result of changes in temperature and baro metric pressure. These emissions occur without any changes in the liquid level in the storage vessel. Factors that affect the mass of breathing losses are the vapor pressure of the stor ed material, atmospheric conditions ( e.g. , daily total solarTechnical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

3 insolation and daily range of ambient temperatures ), breather vent pressure and vacuum settings, vessel dimensions, and vapor molecu lar weight. If the stored liquid is maintained at a constant temperature, breathing emissions are minimized or eliminated.

Another potential source of emi ssions from storage vessels is leaks from various improperly closed openings such as defective pressure/vacu um vents and poorly fitting or deteriorated gaskets used to seal closure devices for openi ngs such as access hatches. Procedures for estimating such emissions are not available. Ho wever, factors that affect the mass of these emissions are the size and number of openings, th e vapor pressure of the stored material, and atmospheric conditions such as wind. Some of the breathing and working emissions may also occur through the leak openings rather than the intended vent.

Working and breathing losses from fixed roof storage vessels can be controlled by: (1) installing a floating roof within the fixed roof tank; (2 ) routing displaced vapor s through a closed vent system to a control device; or (3) vapor balancin g back to the transport vehicle that supplies the liquid being added to the storage vessel. The cl osed vent system to control device and vapor balancing approaches generally ach ieve control levels comparable to, or marginally better than, a well controlled internal floating r oof (at least for storage vessels that store materials with higher vapor pressures). However, a cl osed vent system and control device is mo re costly than an internal floating roof (EPA, 1980; EPA, 1984; Randall and Fields, 2000), and vapor balancing may not be feasible for storage vessels that are designed to operate at pressures less than 2.5 pounds per square inch gauge (psig), which is the required set pressure for pressure relief devices under vapor balancing options in current rules; thus, these tec hniques are not evaluated as separate control optio ns in this analysis.

Leaks from fittings on the fixed roof ( e.g. , conservation vents, access hatches, and emergency pressure relief devices) are anot her source of emissions. Leaks can be controlled by periodic monitoring for leaks and repair of f ittings that are found to be leaking.

3.2 Floating Roof Storage Vessels

There are two basic types of floa ting roof tanks: internal floating roof (IFR) tanks and external floating roof (EFR) tanks. IFR tanks are essentia lly fixed roof tanks that also have a cover (“internal roof”) that floats on the liquid surface within the fixed roof tank. EFR tanks have only the roof that floats on the liquid surface. Emissions during normal operations occur due to withdrawal losses, rim seal loss es, and deck fitting losses. In addition, deck seam losses are a source of emissions from IFRs with bolted decks. When the storage vessel is emptied to the point that the floating roof is landed on its s upports (no longer floating on the liquid surface), emissions also occur due to stan ding idle losses and filling losses.

Withdrawal losses occur as the liquid level and floating roof are lowere d. Some liquid remains on the inner wall of the storage vessel and evapor ates. Similarly, liquid that remains on the surface of fixed roof support columns in IFR stor age vessels will also ev aporate. The mass of these emissions is a function of the surface ar ea-to-volume ratio of the storage vessel, the roughness of the wall (which affects the amount of liquid that can cling to the wall after the liquid level drops), the to tal throughput, and the dens ity of the stored liquid.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

4 Rim seal losses are emissions that escape through gaps between the rim seal and the inner wall of the storage vessel. The primary mechanism gene rating rim seal emissions is the wind and thus, rim seal losses for EFR tanks are greater than for IFR tanks. For average fitting seals, an empirical relationship has been developed that es timates the emissions as a function of the type of rim seal system (type and number of seals), st orage vessel construction (riveted or welded), vapor pressure of the stored liquid, average wind speed, and vapor molecular weight (EPA, 1995).

Numerous fittings pass through or are attached to floating roof decks to accommodate structural support components or to allow for operational f unctions. Typical deck fittings include access hatches, gauge floats, gauge-hatch/sample ports, rim vents, deck drains, deck legs, vacuum breakers, and guidepoles. IFR tanks may also ha ve fixed-roof support columns, ladders, and stub drains. Empirical relationships have been developed to estim ate emissions from these deck fittings; these relationships express emissions as a function of the number of each type of fitting, fitting design ( e.g. , type of cover, wiper, gasket, or other features to minimize openings), vapor pressure of the stored material, a nd vapor molecular weight (EPA, 1995).

IFRs with a deck formed from panels bolted together also have emissions through the seams between the panels. These emissions are estimated as a function of the total length of seams, an average emission factor per unit leng th of seam, the vapor pressure of the stored material, and the vapor molecular weight.

After a floating roof is landed on its supports, e ach vacuum breaker is open (if the device is activated when the leg extension associated with the vacuum breaker contacts the floor of the storage vessel). These openings provide a path way for outside air to ci rculate through the vapor space under the landed floating roof and for pollutant vapors to escape. Rim seal gaps and other non-vapor tight deck fittings provi de additional pathways for circ ulation. The three mechanisms that contribute to standing idle losses are: (1 ) breathing losses from the vapor space; (2) wind losses; and (3) clingage losses. The primary f actors affecting the amount of emissions are the amount of time the roof is lande d, the size of the vapor space, and whether th ere is a liquid heel.

Additional emissions are generated when the storag e vessel is refilled to the point of refloating the floating roof. These emissions occur as the vapor is displaced through the vacuum vents and other openings as it is replaced with liquid. Th e quantity of emissions depends on the saturation level in the vapor space. The sa turation level for a vessel with a liquid heel is greater than for a drain dry tank. Wind effects cause the saturation level for a storage vessel with an EFR to be lower than for a storage vessel with an IFR.

Control options for floating roof tanks include installing deck fitting controls (gasketed covers for all opening in the roof, sleeve and wipers fo r guide poles). Table 1 summarizes the typical default fittings used for IFR and EFR tanks as we ll as the more effective deck fitting controls available to reduce emissions from storage vessels. Another possibility is to retrofit an EFR tank by installing a geodesic dome ove r a storage vessel, thereby converting the EFR into an IFR tank.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

5 3.3 Pressure Vessels

Low-pressure tanks (2.5 to 15 psig) have working losses just like fixed roof tanks, but breathing losses generally are prevented. High-pressure tanks are considered closed systems and, if properly maintained and operated, should have virt ually no emissions; there may be low levels of fugitive emissions, and vessels storing liquefied ga ses may be vented periodically to purge inerts.

3.4 Degassing Storage Vessels

All storage vessels must occasionally be shut down for cleaning, maintenance, inspections, or other reasons. If facili ty personnel need to enter the storage vessel, or residual liquid needs to be removed before refilling with a different material , or the storage vessel is to be taken out of service, the storage vessel first may be dega ssed. Degassing means the process of removing stored material vapors from the storage vessel. Historically, these vapors have been vented to the atmosphere. The mass of emissions will vary depending on the size of the vapor space, the vapor pressure of the stored liqui d, the amount of residual liquid in the storage vessel, the degree of saturation in the vapor space when degassing begins, and the vapor molecular weight.

Degassing emissions can be controlled by draw ing vapors from the storage vessel (below the floating roof, if so equipped) to a control devi ce. State and local rules that require degassing controls require operation of the control syst em until the concentration in the storage vessel drops below a threshold level, which varies am ong the rules. For example, Texas requires vapors to be routed to a cont rol device until the volatile orga nic compound (VOC) concentration is less than 34,000 ppmv expressed as methane (o r less than 50 percent of the lower explosive limit), and the South Coast Air Quality Manageme nt District (SCAQMD) requires control until the concentration is le ss than 5,000 ppmv expressed as methane. The required performance of the control devices also varies among existing ru les. For example, Te xas requires the control device to maintain a control efficiency of at least 90 percent, and th e SCAQMD requires control devices to reduce emissions to an outlet concentr ation less than 500 ppmv (TCEQ; SCAQMD, 2008). Typically, facilities control degassing emi ssions by routing vapors to a mobile control device that is owned and operated by an outside contractor. Mob ile control systems that have been used include thermal oxidizer s, refrigerated condensers, and internal combustion engines. Some facilities have installed closed vent systems to convey degassing emissions (as well as breathing and working losses) to permanent onsite control devices such as flares and thermal oxidizers (Moore, 2009). We developed one cont rol option for evaluation in this analysis. Control Option ST8 consists of routing emissions to a mobile thermal oxidizer (operated by a contract service provid er) until the concen tration of organic compounds in the storage vessel are reduced to less than 5,000 ppmv as methane.

4. Identification of Control Options

As noted previously, Group 1 storage vessels must be equipped with an IFR with proper seals, an EFR with proper seals, or a closed vent system routed to a control device that reduces HAP emissions by 95 percent or to 20 ppmv. Storage vessels at existing sour ces that use floating roofs are not required under Refinery MACT 1 to install certain fitting ( e.g. , gaskets for automatic bleeder vents, slit fabric covers for sample wells, flexible fabric seals or gasketedTechnical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

6 sliding covers for guidepoles, and gasketed cove rs for other roof openings). One control option would be to require these “enhanced fitting cont rols” for all Group 1 stor age vessels. There has been some confusion regarding the terminology of the control requirements as included in the HON (40 CFR part 63, subpart G) and in 40 CFR part 60, subpart Kb; improved storage vessel control requirements were subsequently deve loped in 40 CFR part 63, subpart WW (National Emission Standards for Storage Vessels (Tanks) – Control Level 2). Therefore, Control Option 1 evaluates the impacts of requiri ng enhanced fitting controls fo r storage vessels at existing petroleum refinery facilities as re quired in 40 CFR part 63, subpart WW.

The second control option consid ers changing the applicability thresholds within the Group 1 storage vessel definition. Table 1 provides a comparison of typica l applicability thresholds for storage vessels in the HON; 40 CFR part 60, subpart Kb; and Refinery MACT 1.

Table 1. Comparison of Applicability Thresholds for Storage Vessels

Vessel capacity (cubic meters (m 3 )) Vapor pressure a (kilopascals)
New Sources Existing Sources

HON b 40 CFR part 60, subpart Kb Refinery MACT 1 HON b Refinery MACT 1
38 ≤ capacity<75 c ≥ 13.1 N/A N/A N/A N/A
75 c ≤ capacity <151 ≥ 13.1 ≥ 15 ≥ 77 ≥ 13.1 N/A
151 ≤ capacity <177 ≥ 0.7 ≥ 3.5 ≥ 3.4 ≥ 5.2 N/A
177 ≤ capacity ≥ 0.7 ≥ 3.5 ≥ 3.4 ≥ 5.2 ≥ 10.4 d

a Maximum true vapor pressure at storage temperature.

b HON limits specify maximum true vapor pressure of total organic HAP at storage temperature.

c Refinery MACT 1 threshold is specified as 76 cubic meters (m 3 ) rather than 75 m 3 ; both are expected to indicate a

capacity of 20,000 gallons.

d Refinery MACT 1 also requires that the stored-liquid annu al average true vapor pressure be greater than or equal to

8.3 kilopascals.

As seen in Table 1, Refinery MACT 1 tends to have a higher size thre shold prior to requiring controls or, conversely, Refinery MACT 1 does not require contro ls for smaller-sized storage vessels. The vapor pressure thresh olds also appear to be higher , but Refinery MACT 1 considers total vapor pressure of the mixture (provided th e liquid contains 2 or 4 percent HAP for new or existing sources, respectively) while the HON consid ers only the vapor pressure of total organic HAP. Control Option 2 considered establishi ng a threshold of 1.9 pounds per square inch absolute (psia) (13.1 kilopascals) for st orage vessels between 20,000 and 40,000 gallons in capacity (between 76 and 151 cubic meters (m 3 )) and establishing a th reshold of 0.75 psia (5.2 kilopascals) from storage vessels with a capacity greater or equal to 40,000 gallons (greater than or equal to 151 m 3 ) similar to the HON thresholds.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

7 The final control option (Contro l Option 3) considers additiona l monitoring requirements for storage vessels. The monitoring requirements evaluated include: monitoring of IFR or EFR tanks with EPA Method 21 (of 40 CFR part 60, appendix A-7) or optical gas imaging for fittings; and requiring the use of liquid level overfill warning monitors and roof landing warning monitors.

Additional control op tions such as requiring degassing contro ls or EFR tanks to add a geodesic dome (thereby retrofitting EFR tanks to IFR ta nks) were considered, but based on the impact estimates presented by Randall (2 012), these control options were not co st effective when evaluating VOC emission reductions. As these control options would be less cost effective considering HAP emission reductions, these co ntrol options were dismissed based on the individual model storage vessel analysis presented by Randall (2012) and nationwide impacts for these options were not estimated for devel oped for consideration in this memorandum.

In summary, the control options consider ed in this analysis are as follows:

 Control Option 1: requires enhanced fitting controls for storage vessels as required in 40 CFR part 63, subpart WW.

 Control Option 2: Control Option 1 plus cha nges the applicability thresholds within the Group 1 storage vessel definition.

 Control Option 3: Control Option 2 plus requi res additional monitoring requirements for storage vessels.

5. Emission Estimation Approach

In the first quarter of 2011, the EPA conducted a de tailed information coll ection request (ICR) of the petroleum refining industry. Included in this ICR is inform ation regarding the number of storage vessels (greater than 10,000 gallon capac ity) at the refinery, th e size of each storage vessel, the type of liquid stored (including average vapor pressu re), and the type of storage vessel/controls used for each storage vessel (E PA, 2011). The approach developed to estimate the refinery-specific impacts was to use this detailed information, to the extent practical, without attempting to perform separate model runs using the TANKS software program (TANKS v4.09d) for each individual storage vessel.

We evaluated the impacts of applying the follo wing control option to th e petroleum refinery source category: (1) requiring guid epole controls and other fitti ng controls for existing EFR or IFR tanks; (2) retrofitting certain fixed roof tank s with an IFR equipped with guidepole controls and other fitting controls; and (3) adding additio nal monitoring requirements (including roof landing warning monitors, liquid level overfill wa rning monitors and fixed roof tank monitoring for all other sources). A matrix of model stor age vessels was developed to cover the size of storage vessels and vapor pressures of the materi als stored in these storage vessels, based on the ICR responses. The total VOC emissions for fixe d roof model storage vessels were estimated using TANKS. VOC emissions from model floa ting roof tanks were estimated using the emission equations presented in AP-42 (EPA, 1995) and verified via selected model analysesTechnical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

8 using TANKS. Meteorological data for Houston, Te xas, were used for the emissions estimates. It is difficult to assess the emission reduc tions associated with additional monitoring requirements (Control Option 3), so it was assu med that the monitoring would achieve improve the emission reductions achieved by the added controls by 10 percent.

5.1 Model Floating Roof Tanks

The first distinction made in the model floating roof tank matrix was whether the storage vessel was an IFR tank or an EFR tank. The ICR stor age vessel information i ndicated the type of floating roof tank and guidepoles (IFR or EFR; slotted, solid, or contro lled guidepole), but did not include specifics on the roof construction. EFRs were assumed to have pontoon decks with welded seams, a primary mechanical shoe seal, and a rim-mounted secondary seal. IFRs were assumed to be non-self supporting, have bolted deck s, and have a primary mechanical shoe seal with no secondary seal.

The ICR storage vessel information was initiall y sorted by type of fl oating roof, liquid type (crude oil, gasoline, naphtha, and miscellane ous other liquids), and storage vessel size. However, the various liquids had large ranges of vapor pressures, and the median storage vessel capacity and turnover rates (for se lected storage vessel capacity ranges) were very similar for the different liquid types. As VOC emissions were expected to be primarily depending on the vapor pressure rather than the liquid type , vapor pressure ranges were used to sort the data rather than liquid type. Based on the size of the storage vessel, the vapor pre ssure of the stored liquid, and the controls used on the storage vessel, a matrix of 64 model IFR tanks (4 tank sizes × 4 vapor pressures × 4 control scenarios) and 64 model EFR tanks were developed. Table 2 presents a summary of the model storage vess el matrix parameters; following is a description of the basis for these parameters.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

9 Table 2. Model Storage Vessel Parameters

Matrix/Model Model Parameter/Value

Tank Size Diameter (ft) a Tank Capacity (MMgal) a Turnovers Tank Capacity Range (MMgal) 1) Small Tank 46 0.45 20 0 to 1 2) Medium Tank 126 3.3 20 >1 to 5 3) Large Tank 190 8.0 20 >5 to 17 4) Huge Tank 260 22 20 >17

Vapor Pressure Actual Vapor Pressure

(psia) MolWt Vapor (g/mol) a Liq. Density Vapor Pressure Range (psia) 1) Methyl ethyl ketone 1.43 72 6.7 0.75 to 1.9 2) Gasoline RVP6 3.59 69 5.6 >1.9 to 5 3) Gasoline RVP10 6.25 66 5.6 >5 to 8 4) Gasoline RVP14 9.02 62 5.6 >8
Control Scenario Guidepole (GP) Type Other Fitting Controls 1) Baseline slotted guidepole Slotted GP, ungasketed Default b 2) Baseline solid guidepole Solid GP, ungasketed Default b 3) Baseline controlled guidepole Solid GP: gasketed with pole sleeve c Default b

4) Controlled guidepole & fittings All fittings (except roof legs) gasketed

a ft = feet; MMgal = million gallons; MolWt = molecula r weight of stored liquid; g/mol = grams per mole.

b Default “other fittings” for EFR t anks are: gasketed access hatch; ung asketed automatic gauge float well;

gasketed vacuum breaker; gasketed access gauge-hatch/samp ling well; and gasketed rim vent. Default “other fittings” for IFR tanks are: ungasketed access hatch ; ungasketed automatic gauge float well; ungasketed column well; ungasketed ladder well; gasketed vacuum breaker; and sampling well with slit fabric seal.

c Controlled slotted guidepoles have gasketed cover with pole wiper and sleeve. The emissions from controlled

slotted guidepoles were nearly identical to emissions fr om controlled solid guidepoles, so no distinction was made regarding the type of guidepole controlled.

The model storage vessel sizes were selected base d on a review of the ICR data and the median storage vessel sizes for selected storage vessel capacity ranges; the “ huge” model storage vessel was primarily included to better model the very large crude oil storage vessels. The median turnover rate for different sized st orage vessels with different mate rial stored were consistently approximately 20 per year, so this value wa s selected for all model storage vessels.

Vapor pressure ranges were selected to cover the range of actual vapor pressures reported for EFR and IFR tanks and considering vapor pressure thresholds in Re finery MACT 1 as well as in Control Option 2. A surrogate chemical or substan ce was selected that had a true vapor pressure near the midpoint of the range for the ambient conditions of the chosen meteorological locations (Houston, Texas). Methyl ethyl ke tone (vapor pressure of 1.43 psia) was selected for the low vapor surrogate for this analysis as it has a vapor pressure approximately in the midpoint of liquids stored that have vapor pressure between 0.75 and 1.9 psia. Gasoline Reid Vapor PressureTechnical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

10 (RVP) 6, 10, and 14 were selected as the medi um-low, medium-high, and high vapor pressure surrogates, respectively.

The ICR information on floating roof controls fo cused on guidepole controls. Respondents were provided the following three options to character ize their guidepole control status: slotted guidepole; solid guidepole; or controlled guidep ole. For other fittings, the TANKS default fitting settings were used. For both IFRs and EF Rs, the roof legs were ungasketed. Previous analysis indicated that these fitting controls are not cost effective and these fittings are not required to be gasketed in 40 CFR part 63, subpart WW. For EFRs, the only fitting that was not controlled (gasketed) using the de fault fitting settings is the au tomatic gauge float well. For IFRs, the following fittings were not controlled using the defau lt fitting settings of TANKS: column well(s); ladder well; automatic gauge float well; and access hatch.

The available control codes for fl oating roof controls did not sp ecify if the controlled guidepole was originally slotted or solid. Therefore, for the controlled gu idepole at baseline (Control Scenario 3), an assumption was required as to the type of guidepole (solid or slotted). If the guidepole was uncontrolled at baseline (Control S cenario 1 or 2), one could potentially develop separate post-control scenarios and provide separate emission reduction estimates based on the type of guidepole controlled. However, based on initial TANKS modeling runs, the emissions from controlled slotted guidepoles were nearly identical to the emissions projected for the same storage vessel with a controlled solid guidepole. Given the lack of detail available for guidepole type under Control Scenario 3 and the lack of si gnificant differences in the emissions resulting from the storage vessels after applying the guide pole controls required by the uniform standards, all controlled guidepoles were assumed to be so lid guidepoles for the purposes of the emission estimates. This assumption greatly simplifie d the emission impact modeling while having limited impact on the accuracy of th e analysis. As described later, costs of applying controls did consider the type of guidepole that had to apply controls.

VOC emissions for each model storage vesse l were estimated using TANKS program calculations using Houston, Texas meteorology data. Tables 3 and 4 provide the emission estimates and the number of storage vessels associ ated with each model storage vessel for the model EFR tanks and the model IFR tanks, respectively.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

11 Table 3. Model External Floating Roof Tank Emission Impacts

Model Tank Size/Liquid Stored VOC Emissions at Baseline (lb/yr per tank) a VOC Emissions with all Fitting Controls (lb/yr per tank) Number of Tanks in Class Nationwide VOC Emission Reductions (tpy) a Small Capacity Tank 1) Methyl ethyl ketone a. Slotted guidepole 6,050 560 15 41 b. Solid guidepole 3,615 560 41 63 c. Controlled guidepole 645 560 32 1.4 2) Gasoline RVP6 a. Slotted guidepole 15,700 1,379 28 200 b. Solid guidepole 9,350 1,379 65 259 c. Controlled guidepole 1,604 1,379 58 6.5 3) Gasoline RVP10 a. Slotted guidepole 29,600 2,570 23 311 b. Solid guidepole 17,615 2,570 35 263 c. Controlled guidepole 3,000 2,570 32 6.9 4) Gasoline RVP14 a. Slotted guidepole 47,200 4,080 8 172 b. Solid guidepole 28,100 4,080 19 228 c. Controlled guidepole 4,770 4,080 27 9.3 Medium Capacity Tank 1) Methyl ethyl ketone a. Slotted guidepole 6,860 1,368 24 66 b. Solid guidepole 4,425 1,368 57 87 c. Controlled guidepole 1,455 1,368 52 2.3 2) Gasoline RVP6 a. Slotted guidepole 17,680 3,356 102 731 b. Solid guidepole 11,328 3,356 227 905 c. Controlled guidepole 3,580 3,356 154 17 3) Gasoline RVP10 a. Slotted guidepole 33,280 6,245 94 1,270 b. Solid guidepole 21,290 6,245 174 1,310 c. Controlled guidepole 6,670 6,245 195 41 4) Gasoline RVP14 a. Slotted guidepole 53,000 9,915 60 1,290 b. Solid guidepole 33,900 9,915 90 1,080 c. Controlled guidepole 10,600 9,915 202 69 (Continued)Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

12 Table 3. Model External Floating Roof Tank Emission Impacts (Continued)

Model Tank Size/Liquid Stored VOC Emissions at Baseline (lb/yr per tank) VOC Emissions with all Fitting Controls (lb/yr per tank) Number of Tanks in Class Nationwide VOC Emission Reductions (tpy) Large Capacity Tank 1) Methyl ethyl ketone a. Slotted guidepole 7,550 2,063 6 16 b. Solid guidepole 5,113 2,063 19 29 c. Controlled guidepole 2,143 2,063 18 0.7 2) Gasoline RVP6 a. Slotted guidepole 6,180 2,020 44 92 b. Solid guidepole 4,400 2,020 78 93 c. Controlled guidepole 2,230 2,020 94 10 3) Gasoline RVP10 a. Slotted guidepole 36,370 8,320 55 771 b. Solid guidepole 24,380 8,320 42 337 c. Controlled guidepole 9,760 8,320 97 70 4) Gasoline RVP14 a. Slotted guidepole 57,900 13,180 22 492 b. Solid guidepole 38,800 13,180 14 179 c. Controlled guidepole 15,500 13,180 70 81 Huge Capacity Tank 1) Methyl ethyl ketone a. Slotted guidepole 8,460 2,967 0 0 b. Solid guidepole 6,024 2,967 1 1.5 c. Controlled guidepole 3,055 2,967 6 0.3 2) Gasoline RVP6 a. Slotted guidepole 21,370 7,050 10 72 b. Solid guidepole 15,020 7,050 12 48 c. Controlled guidepole 7,275 7,050 22 2 3) Gasoline RVP10 a. Slotted guidepole 40,060 13,025 3 41 b. Solid guidepole 28,070 13,025 6 45 c. Controlled guidepole 13,450 13,025 19 4 4) Gasoline RVP14 a. Slotted guidepole 63,700 20,600 1 22 b. Solid guidepole 44,600 20,600 5 60 c. Controlled guidepole 21,300 20,600 8 3

a lb/yr = pounds per year; tpy = tons per year.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

13 Table 4. Model Internal Floating Roof Tank Emission Impacts

Model Tank Size/Liquid Stored VOC Emissions at Baseline (lb/yr per tank) VOC Emissions with all Fitting Controls (lb/yr per tank) Number of Tanks in Class Nationwide VOC Emission Reductions (tpy) Small Capacity Tank 1) Methyl ethyl ketone a. Slotted guidepole 1,315 1,100 42 4.5 b. Solid guidepole 1,292 1,100 53 5.1 c. Controlled guidepole 1,250 1,100 31 2.3 2) Gasoline RVP6 a. Slotted guidepole 3,342 2,790 76 21 b. Solid guidepole 3,284 2,790 89 22 c. Controlled guidepole 3,170 2,790 71 13.5 3) Gasoline RVP10 a. Slotted guidepole 6,275 5,240 44 23 b. Solid guidepole 6,140 5,240 47 21 c. Controlled guidepole 5,960 5,240 59 21 4) Gasoline RVP14 a. Slotted guidepole 10,000 8,340 32 27 b. Solid guidepole 9,830 8,340 25 19 c. Controlled guidepole 9,500 8,340 40 23 Medium Capacity Tank 1) Methyl ethyl ketone a. Slotted guidepole 4,280 3,890 23 4.5 b. Solid guidepole 4,260 3,890 38 7.0 c. Controlled guidepole 4,220 3,890 23 3.8 2) Gasoline RVP6 a. Slotted guidepole 10,920 9,900 71 36 b. Solid guidepole 10,870 9,900 87 42 c. Controlled guidepole 10,760 9,900 69 30 3) Gasoline RVP10 a. Slotted guidepole 20,540 18,600 61 59 b. Solid guidepole 20,430 18,600 68 62 c. Controlled guidepole 20,220 18,600 71 58 4) Gasoline RVP14 a. Slotted guidepole 32,750 29,650 35 54 b. Solid guidepole 32,570 29,650 31 45 c. Controlled guidepole 32,200 29,650 58 74 (Continued)Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

14 Table 4. Model Internal Floating Roof Tank Emission Impacts (Continued)

Model Tank Size/Liquid Stored VOC Emissions at Baseline (lb/yr per tank) VOC Emissions with all Fitting Controls (lb/yr per tank) Number of Tanks in Class Nationwide VOC Emission Reductions (tpy) Large Capacity Tank 1) Methyl ethyl ketone a. Slotted guidepole 8,012 7,340 8 2.7 b. Solid guidepole 7,990 7,340 3 1.0 c. Controlled guidepole 7,950 7,340 1 0.3 2) Gasoline RVP6 a. Slotted guidepole 20,500 18,730 13 11.5 b. Solid guidepole 20,440 18,730 8 6.8 c. Controlled guidepole 20,330 18,730 5 4.0 3) Gasoline RVP10 a. Slotted guidepole 38,550 35,200 23 39 b. Solid guidepole 38,440 35,200 6 9.7 c. Controlled guidepole 38,200 35,200 3 4.5 4) Gasoline RVP14 a. Slotted guidepole 61,400 56,130 20 53 b. Solid guidepole 61,300 56,130 2 5.2 c. Controlled guidepole 60,950 56,130 20 48 Huge Capacity Tank 1) Methyl ethyl ketone a. Slotted guidepole 13,650 12,500 0 0 b. Solid guidepole 13,630 12,500 0 0 c. Controlled guidepole 13,590 12,500 0 0 2) Gasoline RVP6 a. Slotted guidepole 34,760 31,770 2 3.0 b. Solid guidepole 34,700 31,770 0 0 c. Controlled guidepole 34,600 31,770 0 0 3) Gasoline RVP10 a. Slotted guidepole 65,300 59,670 3 8.4 b. Solid guidepole 65,200 59,670 0 0 c. Controlled guidepole 65,000 59,670 0 0 4) Gasoline RVP14 a. Slotted guidepole 104,100 95,080 0 0 b. Solid guidepole 103,830 95,080 0 0 c. Controlled guidepole 103,600 95,080 0 0Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

15 5.2 Model Fixed Roof Tanks

Control Option 2 considers requiring storage vess els of 20,000 gallons capacity or more but less than 40,000 gallons in capacity to be controlled if the maximum true vapor pressure of the stored liquid is 1.9 psia or greater; th ese storage vessels at existing s ource petroleum refineries are not currently required to be cont rolled under Refinery MACT 1. A 30,000 gallon model fixed roof tank was used to estimate the impacts for this group of storage vessels . Three model liquids were used for this storage vesse l to represent the ra nge of potential liquids exceeding the vapor pressure threshold (gasoline RVP6 for vapor pr essures from 1.9 to 5 psia; gasoline RVP10 for vapor pressures from 5 to 8 psia; and gasoline RV P13.5 for vapor pressures greater than 8 psia).

Control Option 2 also considers re quiring storage vessels of 40,000 ga llons capacity or greater to be controlled if the maximum true vapor pressure of the stored li quid is 0.75 psia or greater. Currently, Refinery MACT 1 does not require contro l for any storage vessels with a capacity less than 46,760 gallons, and it only requires control of storage vessels greater than 46,760 gallons capacity when the maximum true vapor pressure exceeds 1.5 psia (or the annual average vapor pressure exceeds 1.2 psia). A 44,000 gallon capacity model fixed roof tank was used to estimate the impacts for storage vessels between 40,000 and 46,760 gallons. Four model liquids were used for this model fixed roof tank: the thre e liquids used for the 30,000 gallon model fixed roof tank plus a low-volatile compound (2,2,4-trimethyl pentane) for vapor pressures from 0.75 to 1.5 psia. This low-volatile compound was also used to estimate the impacts for uncontrolled fixed roof tanks greater than 46,760 gallons. The fi xed roof tanks reported in the Refinery ICR ranged up to 6-million gallons capacity. A 300,000 gallon model fixed roof tank was used to project the impacts for storage vessels between 46,760 gallons and 1-million gallons capacity and a 2.5-million gallon model fixed roof tank was us ed to project the impacts for storage vessels between 1- and 6-million gallons capacity.

Table 5 summarizes the emission estimates for the model fixed roof tanks and storage vessels retrofitted with an IFR with appropriate fit ting controls (as require d under Control Option 1).Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

16 Table 5. Model Fixed Roof Storage Vessel Impacts

Model Tank Size/Liquid Stored VOC Emissions from Model Fixed Roof Tank (lb/yr per tank) VOC Emissions from Tank Retrofitted with IFR (lb/yr per tank) Number of Tanks in Class Nationwide VOC Emission Reductions from Tank

Retrofit

(tpy) 30,000 Gallon Capacity Tank 1) Gasoline RVP6 6,320 1,380 14 34.6 2) Gasoline RVP10 11,200 2,590 3 12.9 3) Gasoline RVP13.5 a 16,850 4,140 a 7 44.5 44,000 Gallon Capacity Tank 1) 2,2,4-Trimethylpentane 3,520 480 8 12.1 2) Gasoline RVP6 8,930 1,470 1 3.7 3) Gasoline RVP10 Did not model 0 0 4) Gasoline RVP13.5 a 23,500 4,400 a 2 19.1 300,000 Gallon Capacity Tank 1) 2,2,4-Trimethylpentane 22,100 800 53 565 2.5-MM Gallon Capacity Tank 1) 2,2,4-Trimethylpentane 171,000 2,200 25 2,110

a IFR emissions were estimated for Gasoline RVP14. Th is may slightly underestimate the emission reductions

from this surrogate stored liquid.

3.3 HAP Content of Stored Liquids

The ICR also contained information regarding the t ype of liquid stored in the storage vessel. As noted previously, a given liquid t ype, such as gasoline, naphtha, and crude oil often exhibits a wide range of vapor pressures. Therefore, the ac tual vapor pressure of the stored material was used as the key parameter for assessing the VOC emissions from the storage vessel (along with storage vessel size and type of controls). Howeve r, the liquid type was e xpected to significantly impact the HAP content of the emitted VOC. For example, the HAP content of VOC emitted from a benzene storage vessel is expected to be 100 percent, while the HAP content of VOC emitted from gasoline is expected to be approxi mately 5 percent (Schaffner and Coburn, 2011). Therefore, the type of liquid stored in the storage vessel was used to determine the HAP emission reductions. Table 6 presents the assumed HAP cont ent (fraction by weight) of the VOC emitted for storage vessels as a function of the type of liquid stored.

The factors presented in Table 6 were developed based on profe ssional judgment considering the HAP content of VOC emitted from gasoline an alysis (Schaffner and Coburn, 2011) and the stream composition data reported for various refinery process streams an d products (API, 2002). While factors were developed for all liquid types included in the ICR, many of these liquid types are not stored in storage vessels with IFRs or EFRs. The predom inant liquids stored in IFR orTechnical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

17 EFR tanks with vapor pressures exceeding 0.75 psia are crude oils, unfinished oils – naphtha or lighter, finished and unfinished motor gaso line, aromatics – benzene, and slop oil.

Table 6. HAP Content of Vapor by Type of Liquid Stored

Liquid Type ID from ICR Liquid Type Description HAP Content of Vapor 1, 2 Unstabilized crude oil, Stabilized crude oil 0.05 3, 4 Ethane, Ethylene 0 5, 6 Propane, Propylene 0 7, 9 Normal Butane, Isobutane 0 8, 10 Butylene, Isobutylene 0.01 11, 12, 13, 14 Unfinished Oils – any type 0.05 15, 16 Finished Motor Gasoline – Reformulated, Conventional 0.05 17, 18 Motor Gasoline Blending Components – Reformulated, Conventional 0.05 19 Aviation Gasoline – Finished and Blending Components 0.05 20 Special Naphthas (solvents) 0.05 21, 22 Kerosene-type Jet Fuel, Kerosene 0.1 23, 24, 25 Distillate Fuel O il – any sulfur content 0.1 26, 27, 28 Residual Fuel Oil – any sulfur content 0.1 29, 30, 31 Lubricants (total), Asphalt and Road Oil Wax 0.1
32 Still Gas 0.05 33 Petrochemical Feedstocks – Naphtha <401 °F end-point a 0.05
34 Petrochemical Feedstocks - Other Oils ≥ 401 °F end-point a 0.1 35, 36, 37, 38 Aromatics – any 1 40, 41, 42 Sour water, Slop oil, Other wastewater 0.1 99 Other (specify) 0.05

a °F = degrees Fahrenheit.

6. Cost Estimation Approach

Cost impacts were developed using the costs of specific controls as developed by Randall (2012). These costs were based on vendor quot es received in 2010 and 2011. Although these costs are predominately in 2010 dollars, the impact s for other petroleum refinery sources were determined in 2009 dollars. Given the low infla tion across this time period, it was assumed that the costs from Randall (2012) could be used with out correction to estimate the storage vessel control costs in 2009 dollars. The specific cont rol costs applied for th e floating roof fitting controls and the fixed roof re trofits are described below.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

18 6.1 Fitting Control Costs for Model Floating Roof Tanks

The control costs are specific to the type of fittin g and do not vary with the type of liquid stored or the vapor pressure of the liquid stored. For most of the fittings, particul arly those that are not gasketed using the TANKS default fitting characte ristics, there is only one fitting per storage vessel regardless of the size of th e storage vessel. The only unga sketed fitting (using the default TANKS fittings) that is dependent on the size of the storage vessel is column wells for IFR tanks. Table 7 summarizes the cost of controls per grouping of model storage vessels.

Table 7. Costs for Controls by Model Floating Roof Tanks (2009$)

Grouping of Model Tanks Total Capital Cost per Tank ($) Total Annualized Cost per Tank ($/yr) All EFR tanks with slotted guidepoles $6,400 $960 All EFR tanks with solid guidepoles $1,350 $200 All EFR tanks with controlled guidepoles $400 $60 Small IFR tanks with slotted guidepoles $3,100 $460 Medium IFR tanks with slotted guidepoles $6,950 $1,040 Large IFR tanks with slotted guidepoles $13,000 $1,950 Huge IFR tanks with slotted guidepoles $22,900 $3,430 Small IFR tanks with solid guidepoles $2,700 $400 Medium IFR tanks with solid guidepoles $6,550 $980 Large IFR tanks with solid guidepoles $12,600 $1,890 Huge IFR tanks with solid guidepoles $22,500 $3,370 Small IFR tanks with controlled guidepoles $1,750 $260 Medium IFR tanks with controlled guidepoles $5,600 $840 Large IFR tanks with controlled guidepoles $11,650 $1,745 Huge IFR tanks with controlled guidepoles $21,550 $3,230

6.2 Retrofit Costs for Model Fixed Roof Tanks

The costs of retrofitting a fixed roof tank with an IFR are dependent only on the diameter of the original fixed roof tank. Additiona l costs were also applied to upgr ade the deck fittings to have all gasketed covers and a pole wi per for an unslotted guidepole. Table 8 summarizes the retrofit costs for the model fixed roof tanks.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

19 Table 8. Costs for Fixed Roof Tank Retrofits (2009$)

Tank Capacity Tank Diameter (ft) Total Capital Cost ($ per tank) Total Annualized Cost Prior to VOC Recovery Credit ($/yr per tank) 30,000 Gallon Capacity Tank 16 32,400 6,470 44,000 Gallon Capacity Tank 18.45 33,900 6,770 300,000 Gallon Capacity Tank 38.2 49,240 9,840 2.5-MM Gallon Capacity Tank 88 114,100 22,800

In addition to the control costs, these newly retr ofitted storage vessels wo uld be newly subject to the inspection requirements for fl oating roof tanks under Refinery MACT 1. The annual cost for these inspections is estimated to be $250 per tank per year. As there are 112 storage vessels that would require retrofittin g, there is an additional inspection cost of $28,000 per year associated with the fixed roof tank retrofits.

6.3 Monitoring Costs

The additional monitoring requirements consid ered under Control Option 3 and the projected burden for these requirements are summarized in Table 9

.

Table 9. Additional Monitoring Costs for Storage Vessels (2009$)

Grouping of Model Tanks [#Tanks in Grouping] Total Capital

Cost ($/tank) Total Annualized Cost ($/yr/tank) Existing IFR and EFR Tanks Above Thresholds [3,751] Roof landing warning monitors $2,277 $1,053 Liquid level overfill warning monitors $2,277 $560 Total $4,554 $1,613 Fixed Roof Tanks Retrofitted with IFR (newly controlled due to change in thresholds) [112] Roof landing warning monitors $2,277 $1,053 Liquid level overfill warning monitors $2,277 $560 Total $4,554 $1,613 Fixed Roof Tanks Vented to Control System [278] Roof fitting monitoring $160 Closed vent system monitoring $70
Total $230Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

20 6.4 VOC Recovery Credit

Upon applying the storage vessel controls, the VO C that was formerly lost as emissions now remains in the storage vessel and ca n be either directly sold as pr oduct or used to make product. While the recovery credit could be assessed as a function of the type of liquid stored, this greatly complicates the analysis. A VOC recovery credit of $560 per t on of VOC recovered (approximately $1.75/gallon) was used as a generi c value for petroleum liquids (Lucas, 2008). While the price of petroleum liquids fluctuates significantly from year to year, this recovery credit is consistent with the average price of petroleum products in 2009 and is a conservatively low estimate considering the price of petroleum products from 2006 through 2011 (EIA, 2012).

7. Results

Cost and emission reductions were evaluated on a storage vessel-s pecific basis using the data reported by petroleum refineries in the detailed ICR responses. These results were summed to get a total estimate of the costs and emissions reduction for the 148 petroleum refineries that responded to the survey. The cumulative nationwide costs and emission reductions calculated for progressively applying the control options to storage vessels at petroleum refineries are summarized in Table 10 . That is, the impacts presented for Control Option 1 are for applying the enhanced fitting controls (Control Option 1), the impacts presented for Control Option 2 are for applying both the enhanced fitting controls and revising th e definition of Group 1 storage vessels, and the impacts presented for Control Option 3 are for requiring additional monitoring of storage vessels, such as overfil l and roof landing monitors, in a ddition to the controls required under Control Options 1 and 2. The VOC cost eff ectiveness and incrementa l cost effectiveness values for the control opt ions are presented in Table 11

. Table 12 provides similar cost information relative to HAP emission reductions.

Table 10. Nationwide Impacts for Control Options for Storage Vessels at Petroleum Refineries (2009$)

Control Option Total Capital Investment (million $) Total Annualized Costs w/o VOC Credit (million $/ yr) Total Annualized Costs with VOC Credit (million $/ yr) VOC Emissions (tpy) HAP Emissions (tpy) HAP Emission Reductions (tpy) Baseline 29,700 1,960 Control Option 1 $11.9 $1.8 $(4.8) 17,900 1,240 720 Control Option 2 $18.5 $3.1 $(5.0) 15,100 1,050 910 Control Option 3 $36.4 $9.6 $0.56 13,700 960 1,000Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

21 Table 11. VOC Cost Effectiveness for Control Options for Storage Vessels at Petroleum Refineries (2009$)

Control Option VOC Emission Reductions (tpy) VOC Cost Effectiveness

w/o Credits ($/ton) VOC Incremental Cost Effectiveness

w/o Credits ($/ton) VOC Cost Effectiveness with Credits ($/ton) VOC Incremental Cost Effectiveness with Credits ($/ton) Control Option 1 11,800 $150 $150 $(410) $(410) Control Option 2 14,600 $210 $480 $(350) $(80) Control Option 3 16,000 $600 $4,450 $35 $3,840

Table 12. HAP Cost Effectiveness for Control Options for Storage Vessels at Petroleum Refineries (2009$)

Control Option HAP Emission Reductions (tpy) HAP Cost Effectiveness

w/o Credits ($/ton) HAP Incremental Cost Effectiveness

w/o Credits ($/ton) HAP Cost Effectiveness with Credits ($/ton) HAP Incremental Cost Effectiveness with Credits ($/ton) Control Option 1 720 $2,470 $2,470 $(6,690) $(6,690) Control Option 2 910 $3,430 $7,040 $(5,530) $(1,140) Control Option 3 1,000 $9,580 $71,100 $560 $61,500

8. References

API (American Petroleum Institute). 2002. Refinery Stream Speciation . API Publication No. 4723. November 1, 2002.

EIA (U.S. Energy Informati on Administration). 2012. Annual Energy Review 2011 . See particularly Table 5.22. DOE /EIA-0384(2011). Washington, DC: Government Printing Office. September 2012.

EPA (U.S. Environmental Protection Agency). 1980. Organic Chemical Manufacturing Volume 3: Storage, Fugitive, and Secondary Sources . Office of Air Quality Planning and Standards. EPA-450/3-80-025.

EPA (U.S. Environmental Protection Agency). 1984. VOC Emissions from Volatile Organic Liquid Storage Tanks—Background Information for Proposed Standards . Office of Air Quality Planning and Standards. EPA-450/3-81-003a.Technical Memorandum – Technol ogy Review for Storage Tanks at Petroleum Refineries November 14, 2012

22 EPA (U.S. Environmental Protection Agency). TANKS v4.09d Software. www.epa.gov/ttn/chief/sof tware/tanks/index.html

. EPA (U.S. Environmental Protection Agency). 1995. Compilation of Air Pollutant Emission Factors. Volume 1: Stationary Point and Area Sources . AP-42, Fifth Edition. Office of Air Quality Planning and Standards, Research Triangle Park, NC.

EPA (U.S. Environmental Protection Agency). 2011. Petroleum Refinery Database, based on Refinery Information Collection Request (I CR) for Calendar Year 2010. September 2011. Docket Item Nos. EPA- HQ-OAR-2010-0682-0061 through 0069.

Lucas, B. 2008. Memorandum from Bob Lucas, EPA/SPPD, to Project Docket File (EPA Docket No. EPA-HQ-OAR-2003-0146). Cooling Towers: Control Alternatives and Impact Estimates . October 30, 2008. Docket Item No. EPA-HQ-OAR-2003-0146-0143.

Moore, J. 2009. Comments on Chapter 115 Degassing Rules . Letter from J. Moore, Baker Botts, LLP, to E. Lin, Texas Commission on Environmental Quality. December 11, 2009.

Randall, D., and J. Fields. 2000. MACT Floor, Regulatory Alternatives, and Nationwide Impacts for Storage Tanks at Miscellaneous Organic Chemical Manufacturing Facilities

. Memorandum from D. Randall and J. Fields, Mi dwest Research Institute, to MON Project File.

Randall, D. 2012. Memorandum from David Randa ll, RTI International, to Nick Parsons, EPA/OAQPS, for Project Docket File (EPA Docket No. EPA-HQ-OAR-2010-0871). Survey of Control Technology for Storage Vessels and Analysis of Impacts for Storage Vessel Control Options . January 20, 2012. Docket Item No. EPA-HQ-OAR-2010-0871-0027.

Schaffner, K. and J. Coburn. 2011. Memorandu m from Karen Schaffner and Jeff Coburn, RTI International, to S. Shedd and B. Shine, EPA/OAQPS. HAP Content in Vapor Phase of Gasoline: Residual Risk and Technology Revi ew for the Marine Tank Vessel Loading Operations Source Category . March 9, 2011. Docket Item No. EPA-HQ-OAR-2010-0600- 0400.

SCAQMD (South Coast Air Qualit y Management District). 2008. Rule 1149. Storage Tank and Pipeline Cleaning and De gassing. Retrieved from: http://www.aqmd.gov/rules/reg/reg11/r1149.pdf . Last accessed in November 2011.

TCEQ (Texas Commission on Environmental Qual ity). Chapter 115-Control of Air Pollution from Volatile Organic Compounds, Subchapter F: Miscellaneous Industrial Sources, Division 3: Degassing of Storage Tanks, Transport Vessels, and Marine Vessels. Retrieved from: http://www.tceq.texas.gov/assets/publ ic/legal/rules/ru les/pdflib/115f.pdf . Last accessed in November 2011.