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 Storage Vessels at Petroleum Refineries 

1. Purpose 

This memorandum documents the costs and environmental impacts associated with technology 

review control options identified for storage vessels at petroleum refineries. 

2. Background 

Storage vessels are used to store liquid and gaseous 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 vessels are used to store compressed 

gases and liquefied gases. Atmospheric storage vessels are typically cylindrical with a vertical 

orientation, and they are constructed with either a fixed roof or a floating roof. Some, generally 

small, atmospheric storage vessels are oriented horizontally. High pressure vessels are either 

spherical or horizontal cylinders. All of the storage vessels in this analysis are aboveground 

storage vessels; underground storage tanks are not considered. 

The Refinery MACT 1 rule (40 CFR part 63, subpart 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 rule 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 kilopascals 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 requires Group 1 storage vessels 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 Pollutants from the Synthetic Organic Chemical 
Technical Memorandum – Technology Review for Storage Tanks at Petroleum Refineries 

November 14, 2012 

2 

Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and 

Wastewater; commonly referred to as the “Hazardous 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 external floating roof with proper seals, an external floating roof 

converted to an internal floating roof with proper 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 included 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 gasketed covers for other roof openings). See 

40 CFR 63.646(c). 

The Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to review 

promulgated standards periodically to ensure that new source performance standards (NSPS) and 

national emissions standards for hazardous air pollutants (NESHAP) reflect advances in 

emissions reduction technology. Specifically, section 112(d)(6) of the CAA states that “[t]he 

Administrator shall review, and revise as necessary (taking into account developments in 

practices, processes, and control technologies), emission standards promulgated under this 

section no less often than every 8 years.” Similarly, 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 control technologies for storage vessels at petroleum 

refineries. This memorandum documents this technology review for storage vessels and 

summarizes the impacts of potential regulatory options identified. 

3. Description of Emission Releases and Controls 

3.1 Fixed Roof Storage Vessels 

Emissions from fixed roof storage vessels (both vertical and horizontal vessels) occur from 

working losses, breathing loses, and leaks. Working losses are the combined emissions from 

filling and emptying the storage vessel. Emissions 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 are 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 pressure to increase; as when filling the storage 

vessel, when the pressure exceeds the relief pressure, the vent opens and vapors are released to 

the atmosphere. Factors that affect the mass of working 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 are emissions caused by vapor expansion and contraction, which 

are the result of changes in temperature and barometric 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 stored material, atmospheric conditions (e.g., daily total solar 
Technical Memorandum – Technology 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 molecular weight. If the stored liquid is maintained at a constant 

temperature, breathing emissions are minimized or eliminated. 

Another potential source of emissions from storage vessels is leaks from various improperly 

closed openings such as defective pressure/vacuum vents and poorly fitting or deteriorated 

gaskets used to seal closure devices for openings such as access hatches. Procedures for 

estimating such emissions are not available. However, factors that affect the mass of these 

emissions are the size and number of openings, the 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 vapors through a closed vent 

system to a control device; or (3) vapor balancing back to the transport vehicle that supplies the 

liquid being added to the storage vessel. The closed vent system to control device and vapor 

balancing approaches generally achieve control levels comparable to, or marginally better than, a 

well controlled internal floating roof (at least for storage vessels that store materials with higher 

vapor pressures). However, a closed vent system and control device is more 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 techniques are not evaluated 

as separate control options in this analysis. 

Leaks from fittings on the fixed roof (e.g., conservation vents, access hatches, and emergency 

pressure relief devices) are another source of emissions. Leaks can be controlled by periodic 

monitoring for leaks and repair of fittings that are found to be leaking. 

3.2 Floating Roof Storage Vessels 

There are two basic types of floating roof tanks: internal floating roof (IFR) tanks and external 

floating roof (EFR) tanks. IFR tanks are essentially 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 losses, 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 supports (no longer floating on the liquid surface), 

emissions also occur due to standing idle losses and filling losses. 

Withdrawal losses occur as the liquid level and floating roof are lowered. Some liquid remains 

on the inner wall of the storage vessel and evaporates. Similarly, liquid that remains on the 

surface of fixed roof support columns in IFR storage vessels will also evaporate. The mass of 

these emissions is a function of the surface area-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 total throughput, and the density of the stored liquid. 
Technical Memorandum – Technology 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 generating 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 estimates the emissions as a function of the type 

of rim seal system (type and number of seals), storage 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 functions. 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 have fixed-roof support columns, ladders, and stub 

drains. Empirical relationships have been developed to estimate 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, and 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 length of seam, the vapor pressure of the stored material, and the 

vapor molecular weight. 

After a floating roof is landed on its supports, each 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 pathway for outside air to circulate 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 provide additional pathways for circulation. 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 factors affecting the amount of emissions are the 

amount of time the roof is landed, the size of the vapor space, and whether there is a liquid heel. 

Additional emissions are generated when the storage 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. The quantity of emissions depends on the saturation 

level in the vapor space. The saturation 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 for guide poles). Table 1 summarizes the typical 

default fittings used for IFR and EFR tanks as well 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 over a storage vessel, thereby converting the EFR into an IFR 

tank. 
Technical Memorandum – Technology 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 virtually no emissions; there may be low levels of 

fugitive emissions, and vessels storing liquefied gases 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 facility 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 degassed. 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 liquid, 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 drawing vapors from the storage vessel (below the 

floating roof, if so equipped) to a control device. State and local rules that require degassing 

controls require operation of the control system until the concentration in the storage vessel 

drops below a threshold level, which varies among the rules. For example, Texas requires 

vapors to be routed to a control device until the volatile organic compound (VOC) concentration 

is less than 34,000 ppmv expressed as methane (or less than 50 percent of the lower explosive 

limit), and the South Coast Air Quality Management District (SCAQMD) requires control until 

the concentration is less than 5,000 ppmv expressed as methane. The required performance of 

the control devices also varies among existing rules. For example, Texas requires the control 

device to maintain a control efficiency of at least 90 percent, and the SCAQMD requires control 

devices to reduce emissions to an outlet concentration less than 500 ppmv (TCEQ; SCAQMD, 

2008). Typically, facilities control degassing emissions by routing vapors to a mobile control 

device that is owned and operated by an outside contractor. Mobile control systems that have 

been used include thermal oxidizers, 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 control option for evaluation in this analysis. 

Control Option ST8 consists of routing emissions to a mobile thermal oxidizer (operated by a 

contract service provider) until the concentration 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 sources 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 gasketed 
Technical Memorandum – Technology Review for Storage Tanks at Petroleum Refineries 

November 14, 2012 

6 

sliding covers for guidepoles, and gasketed covers for other roof openings). One control option 

would be to require these “enhanced fitting controls” for all Group 1 storage 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 developed 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 requiring enhanced fitting controls for storage vessels at existing 

petroleum refinery facilities as required in 40 CFR part 63, subpart WW. 

The second control option considers changing the applicability thresholds within the Group 1 

storage vessel definition. Table 1 provides a comparison of typical 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 (m3)) 

Vapor pressurea (kilopascals) 

New Sources Existing Sources 

HONb

40 CFR 

part 60, 

subpart Kb

Refinery 

MACT 1 HONb

Refinery 

MACT 1 

38 ≤ capacity<75c ≥13.1 N/A N/A N/A N/A 

75c ≤ 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 ≥10.4d

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 (m3) rather than 75 m3; both are expected to indicate a 

capacity of 20,000 gallons. d

 Refinery MACT 1 also requires that the stored-liquid annual 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 threshold prior to requiring 

controls or, conversely, Refinery MACT 1 does not require controls for smaller-sized storage 

vessels. The vapor pressure thresholds also appear to be higher, but Refinery MACT 1 considers 

total vapor pressure of the mixture (provided the liquid contains 2 or 4 percent HAP for new or 

existing sources, respectively) while the HON considers only the vapor pressure of total organic 

HAP. Control Option 2 considered establishing a threshold of 1.9 pounds per square inch 

absolute (psia) (13.1 kilopascals) for storage vessels between 20,000 and 40,000 gallons in 

capacity (between 76 and 151 cubic meters (m3

)) and establishing a threshold 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 m3

) similar to the HON thresholds. 
Technical Memorandum – Technology Review for Storage Tanks at Petroleum Refineries 

November 14, 2012 

7 

The final control option (Control Option 3) considers additional 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 options such as requiring degassing controls or EFR tanks to add a geodesic 

dome (thereby retrofitting EFR tanks to IFR tanks) were considered, but based on the impact 

estimates presented by Randall (2012), these control options were not cost effective when 

evaluating VOC emission reductions. As these control options would be less cost effective 

considering HAP emission reductions, these control 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 developed for consideration in this memorandum. 

In summary, the control options considered 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 changes the applicability thresholds within the 

Group 1 storage vessel definition. 

 Control Option 3: Control Option 2 plus requires additional monitoring requirements for 

storage vessels. 

5. Emission Estimation Approach 

In the first quarter of 2011, the EPA conducted a detailed information collection request (ICR) of 

the petroleum refining industry. Included in this ICR is information regarding the number of 

storage vessels (greater than 10,000 gallon capacity) at the refinery, the size of each storage 

vessel, the type of liquid stored (including average vapor pressure), and the type of storage 

vessel/controls used for each storage vessel (EPA, 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 following control option to the petroleum refinery 

source category: (1) requiring guidepole controls and other fitting controls for existing EFR or 

IFR tanks; (2) retrofitting certain fixed roof tanks with an IFR equipped with guidepole controls 

and other fitting controls; and (3) adding additional monitoring requirements (including roof 

landing warning monitors, liquid level overfill warning monitors and fixed roof tank monitoring 

for all other sources). A matrix of model storage vessels was developed to cover the size of 

storage vessels and vapor pressures of the materials stored in these storage vessels, based on the 

ICR responses. The total VOC emissions for fixed roof model storage vessels were estimated 

using TANKS. VOC emissions from model floating roof tanks were estimated using the 

emission equations presented in AP-42 (EPA, 1995) and verified via selected model analyses 
Technical Memorandum – Technology Review for Storage Tanks at Petroleum Refineries 

November 14, 2012 

8 

using TANKS. Meteorological data for Houston, Texas, were used for the emissions estimates. 

It is difficult to assess the emission reductions associated with additional monitoring 

requirements (Control Option 3), so it was assumed 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 storage vessel information indicated the type of 

floating roof tank and guidepoles (IFR or EFR; slotted, solid, or controlled 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 decks, and have a primary mechanical shoe seal 

with no secondary seal. 

The ICR storage vessel information was initially sorted by type of floating roof, liquid type 

(crude oil, gasoline, naphtha, and miscellaneous 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 selected 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 pressure 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 vessel matrix parameters; following is a description of the basis 

for these parameters. 
Technical Memorandum – Technology 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 Defaultb

2) Baseline solid guidepole Solid GP, ungasketed Defaultb

3) Baseline controlled guidepole Solid GP: gasketed with pole 

sleevec

Defaultb

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

gasketed 

a

 ft = feet; MMgal = million gallons; MolWt = molecular weight of stored liquid; g/mol = grams per mole. b

 Default “other fittings” for EFR tanks are: gasketed access hatch; ungasketed automatic gauge float well; 

gasketed vacuum breaker; gasketed access gauge-hatch/sampling 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 from controlled solid guidepoles, so no distinction was 

made regarding the type of guidepole controlled. 

The model storage vessel sizes were selected based 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 storage vessels with different material stored were consistently 

approximately 20 per year, so this value was 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 Refinery MACT 1 as well as in 

Control Option 2. A surrogate chemical or substance 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 ketone (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 Pressure 
Technical Memorandum – Technology Review for Storage Tanks at Petroleum Refineries 

November 14, 2012 

10 

(RVP) 6, 10, and 14 were selected as the medium-low, medium-high, and high vapor pressure 

surrogates, respectively. 

The ICR information on floating roof controls focused on guidepole controls. Respondents were 

provided the following three options to characterize their guidepole control status: slotted 

guidepole; solid guidepole; or controlled guidepole. For other fittings, the TANKS default 

fitting settings were used. For both IFRs and EFRs, 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 default fitting settings is the automatic gauge float well. For 

IFRs, the following fittings were not controlled using the default fitting settings of TANKS: 

column well(s); ladder well; automatic gauge float well; and access hatch. 

The available control codes for floating roof controls did not specify if the controlled guidepole 

was originally slotted or solid. Therefore, for the controlled guidepole 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 Scenario 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 significant differences in the emissions resulting 

from the storage vessels after applying the guidepole controls required by the uniform standards, 

all controlled guidepoles were assumed to be solid guidepoles for the purposes of the emission 

estimates. This assumption greatly simplified the emission impact modeling while having 

limited impact on the accuracy of the 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 vessel 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 associated with each model storage vessel for the 

model EFR tanks and the model IFR tanks, respectively. 
Technical Memorandum – Technology 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 – Technology 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 – Technology 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 – Technology 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 0 
Technical Memorandum – Technology Review for Storage Tanks at Petroleum Refineries 

November 14, 2012 

15 

5.2 Model Fixed Roof Tanks 

Control Option 2 considers requiring storage vessels 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; these storage vessels at existing source petroleum refineries are not 

currently required to be controlled 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 vessel to represent the range of potential liquids exceeding the vapor 

pressure threshold (gasoline RVP6 for vapor pressures from 1.9 to 5 psia; gasoline RVP10 for 

vapor pressures from 5 to 8 psia; and gasoline RVP13.5 for vapor pressures greater than 8 psia). 

Control Option 2 also considers requiring storage vessels of 40,000 gallons capacity or greater to 

be controlled if the maximum true vapor pressure of the stored liquid is 0.75 psia or greater. 

Currently, Refinery MACT 1 does not require control 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 three liquids used for the 30,000 gallon model fixed roof 

tank plus a low-volatile compound (2,2,4-trimethylpentane) 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 fixed 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 used 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 fitting controls (as required under Control Option 1). 
Technical Memorandum – Technology 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 RVP13.5a 16,850 4,140a 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 RVP13.5a 23,500 4,400a 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. This 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 type of liquid stored in the storage vessel. As 

noted previously, a given liquid type, such as gasoline, naphtha, and crude oil often exhibits a 

wide range of vapor pressures. Therefore, the actual 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). However, the liquid type was expected 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 approximately 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 content (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 professional judgment considering the 

HAP content of VOC emitted from gasoline analysis (Schaffner and Coburn, 2011) and the 

stream composition data reported for various refinery process streams and 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 predominant liquids stored in IFR or 
Technical Memorandum – Technology 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 gasoline, 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 Oil – 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-pointa 0.05

34 Petrochemical Feedstocks - Other Oils ≥401 °F end-pointa 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 quotes received in 2010 and 2011. Although these 

costs are predominately in 2010 dollars, the impacts for other petroleum refinery sources were 

determined in 2009 dollars. Given the low inflation across this time period, it was assumed that 

the costs from Randall (2012) could be used without correction to estimate the storage vessel 

control costs in 2009 dollars. The specific control costs applied for the floating roof fitting 

controls and the fixed roof retrofits are described below. 
Technical Memorandum – Technology 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 fitting and do not vary with the type of liquid stored 

or the vapor pressure of the liquid stored. For most of the fittings, particularly those that are not 

gasketed using the TANKS default fitting characteristics, there is only one fitting per storage 

vessel regardless of the size of the storage vessel. The only ungasketed 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. Additional costs were also applied to upgrade the deck fittings to have 

all gasketed covers and a pole wiper for an unslotted guidepole. Table 8 summarizes the retrofit 

costs for the model fixed roof tanks. 
Technical Memorandum – Technology 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 retrofitted storage vessels would be newly subject to 

the inspection requirements for floating 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 retrofitting, 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 considered 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 $230 
Technical Memorandum – Technology Review for Storage Tanks at Petroleum Refineries 

November 14, 2012 

20 

6.4 VOC Recovery Credit 

Upon applying the storage vessel controls, the VOC that was formerly lost as emissions now 

remains in the storage vessel and can be either directly sold as product 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 ton of VOC recovered 

(approximately $1.75/gallon) was used as a generic 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-specific 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 the definition of Group 1 storage 

vessels, and the impacts presented for Control Option 3 are for requiring additional monitoring 

of storage vessels, such as overfill and roof landing monitors, in addition to the controls required 

under Control Options 1 and 2. The VOC cost effectiveness and incremental cost effectiveness 

values for the control options 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 1,000 
Technical Memorandum – Technology 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 Information 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 – Technology 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/software/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 (ICR) 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, Midwest Research Institute, to MON Project 

File. 

Randall, D. 2012. Memorandum from David Randall, 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. Memorandum 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 Review 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 Quality Management District). 2008. Rule 1149. Storage Tank 

and Pipeline Cleaning and Degassing. Retrieved from: 

http://www.aqmd.gov/rules/reg/reg11/r1149.pdf. Last accessed in November 2011. 

TCEQ (Texas Commission on Environmental Quality). 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/public/legal/rules/rules/pdflib/115f.pdf. Last 

accessed in November 2011.