P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

ll-C-7 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 36 of 132 
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A-W-/3 

' * * % UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I KMK ^ uj Office of Air Quality Planning and Standards 

\ -V^l ^ " Research Triangle Park, North Carolina 27711 

DEC 1-01997 %—S 

Mr. T. Ted Cromwell 

Sr. Director, Air Programs 

Regulatory Affairs 

Chemical Manufacturers Association 

1300 Wilson Boulevard 

Arlington, Virginia 22209 

Dear Mr. Cromwell: 

Enclosed with this letter is the U.S. Environmental 

Protection Agency's draft industry survey for the organic liquids 

distribution (non-gasoline) source category. The EPA is 

providing this draft for your review and comments. The survey is 

based on the survey developed for the Refinery NESHAP which was 

extracted from OMB form No. 2060-0239 and formatted to make it 

more relevant to that industry. In your review, we are looking 

for technical corrections and additions to the survey, and also 

for alternate formats and ways of requesting information that 

will simplify the survey, make it more understandable and 

beneficial, and minimize the burden on facilities that are 

responding. 

We also would appreciate your assistance in identifying 

appropriate survey recipients. Currently we have two sources of 

information for facility owners. They are the 1997 Directory of 

the Independent Liquid Terminals Association (ILTA) and the 1997 

Petroleum Terminal Encyclopedia (Oil Price Information Service). 

We also have not determined how to locate and survey smaller 

facilities that blend and/or package organic liquids in 

containers such as drums, gallon and quart containers, etc. To 

some degree (see Table 3 in the survey), we have addressed these 

operations when they are collocated at terminals. However, we 

need aid in requesting the proper information from these 

packaging operations on the enclosed survey and your thoughts on 

a second survey targeted at the facilities not collocated with 

terminals. 

We plan to send this survey out in January 1998, and will be 

continuing to develop the company mailing list until that time. 

Due to our project schedule, we need to receive any comments from 

A 
P.3 

you by January 7, 1998. If you have any questions or would like 

a meeting to discuss this material, please call me at (919) 541-

5397, or Greg LaFlam of Pacific Environmental Services at (919) 

941-0333. 

Your help in making this survey accurate and efficient in 

gathering needed information is appreciated. 

Sincerely, 

Stephen A. Shedd 

Waste and Chemical Processes Group 

Emissions Standards Division 

1 Enclosure 

cc: Steve Shedd (EPA/OAQPS/ESD/WCPG) (w/o enclosure) 

Greg LaFlam (PES) 
P.4 

Enclosure 1 (Draft cover letter and EPA information request for 

Organic Liquids Distribution NESHAP - 12/8/97 revision) 

[Fields below to be filled in from mailing list] 

Dear Mr./Ms. &&&&%-. 

The U.S. Environmental Protection Agency (EPA) is compiling 

detailed information on sources and quantities of hazardous air 

pollutant (HAP) emissions and control techniques. This 

information will be used in setting national emission standards 

for hazardous air pollutants (NESHAP) under Section 112 of the 

Clean Air Act (CAA), as amended in 1990. The standards will 

apply to non-gasoline handling operations at both existing and 

new organic liquids distribution facilities. These standards are 

scheduled to be promulgated by November 2000. The EPA's initial 

step for this endeavor is to collect information on HAP emissions 

and emission reduction techniques in the organic liquids 

distribution industry. Your assistance in providing information 

is critical in developing a regulation that is realistic and 

workable, as well as protective of the environment. 

Enclosure 1 itemizes the information that you are requested 

to submit. The EPA will use the information to quantify HAP 

emissions; define the current status of emission control; and 

assess the environmental, energy, and economic impacts of 

installing and operating feasible emission control techniques. 

The information needed for regulatory development is contained in 

the information collection form approved by the Office of 

Management and Budget (OMB No. 2060-0239) . We are sensitive to 

the amount of labor required to respond to this request; 

therefore, to minimize demands on your time, information specific 

to the organic liquids distribution industry has been extracted 

from OMB form No.,2060-0239 and formatted to make it more 

relevant to this industry. Enclosure 1 is the reformatted 

version of the OMB approved form. The OMB approved form is 

available upon request. 
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The authority for the EPA's information gathering is 

included in Section 114 of the CAA (42 U.S.C. 7414) . Enclosure 2 

contains a summary of this authority. You should also be aware 

that any failure to comply with our request is a violation of 

Section 114 and as such is subject to enforcement under Section 

113 (specifically, 113 (d) (1) (B) of the CAA, which provides civil 

penalties of up to $25,000 per day of violation). If you believe 

that disclosure of any specific information that you submit would 

reveal a trade secret, clearly identify such information as 

discussed in the enclosure. Any information subsequently 

determined to constitute a trade secret will be protected under 

18 U.S.C. 1905. If no claim of confidentiality accompanies the 

information when it is received by the EPA, it may be made 

available to the public by the EPA without further notice 

(40 CFR Part 2.203, September 1, 1976). Section 114 of the CAA 

exempts emission data from claims of confidentiality and emission 

data collected may be made available to the public. A 

clarification of what the EPA considers to be emission data is 

contained in Enclosure 3. 

As noted in Enclosure 4, we have designated Pacific 

Environmental Services, Inc. (PES) as an authorized 

representative of the EPA. Therefore, PES has the rights 

discussed above and in Enclosure 2. As an authorized 

representative of the EPA, PES is subject to the provisions of 

42 U.S.C. 7414 respecting confidentiality of methods or processes 

entitled to protection as trade secrets. The PES contract with 

the EPA is No. 68D60013. 

Enclosure 5 summarizes the EPA's policies and procedures for 

handling privileged information and describes EPA contractor 

commitments and procedures for using confidential materials. It 

is the EPA's policy that compliance by an authorized 

representative with the requirements detailed in Enclosure 5 

provides sufficient protection for the rights of submitters of 

privileged information. 
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We request that you return the completed information request 

by [date to be inserted] . If you have any questions regarding 

this request, please contact Mr. Stephen Shedd of my staff at 

(919) 541-5397. 

Sincerely yours, 

Bruce C. Jordan 

Director 

Emission Standards Division 

5 Enclosures 

cc: EPA Regional Office (w/o enclosures 2-5) 

State Air Contact (w/o enclosures 2-5) 
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MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS 

DEVELOPMENT INFORMATION REQUEST 

I. Instructions 

This information request is to be completed for operations 

that comprise the organic liquids distribution (nongasoline) source category at your plant. The source 

category is those activities associated with the storage 

and distribution of organic liquids other than gasoline, at 

sites which serve as distribution points from which organic 

liquids may be obtained for further use and processing. 

This request covers the storage and transfer of organic 

liquids (including equipment leaks), and also considers 

waste and wastewater treatment and disposal practices. 

We are requesting information regarding each compound 

identified as a hazardous air pollutant (HAP) that is used 

in or emitted by any operations, including fugitive 

emission sources, that are part of the organic liquids 

distribution (non-gasoline) source category at your 

facility. Note that, for this survey, we would also like 

information on any gasoline storage and distribution 

activities at each facility in order to completely 

characterize the operations and to understand the total 

emissions picture at the facility. Fill out this 

information request as completely as possible from existing 

information. At a minimum, provide (1) information on the 

presence of HAP emissions and (2) HAP emission estimates 

based on previously obtained test data or on engineering 

calculations, provided there is a basis for such 

calculations. Attachment A includes the EPA's list of 

hazardous air pollutants that you should refer to when 

completing the survey. 

All data and responses should be based on calendar year 

1997 emissions, materials handled, and emission control 

equipment (unless you can justify selection of an alternate 

base year). Please be sure to keep a copy of the completed 

survey for your records. You should also keep copies of 

any notes or calculations you perform in completing the 

survey. If you need more space to complete your response, 

6 
P.8 

please include the additional information in a clearly 

labeled attachment. If you believe there is additional 

information that is not requested in the survey that may be 

helpful to the EPA in developing HAP emission standards for 

this industry, please include this information in a 

separate attachment. 

If you have any questions regarding this request, please 

contact Mr. Stephen Shedd, U.S. EPA, Emission Standards 

Division, at (919) 541-5397. 

Return this information request and any additional information 

to: 

Bruce C. Jordan, Director 

Emission Standards Division (MD-13) 

U. S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Attention: Stephen Shedd 

II. General Information 

A. Name of legal owner of plant: ; 

B. Name of legal operator of plant, if different from 

legal owner: 

C. Address of legal owner/operator (please specify 

which): 

D. Size of company: 

Approximate number of employees of the business 

enterprise that owns this plant, including where 

applicable, the parent company and all 

subsidiaries, branches, and unrelated 

establishments owned by the parent company (answer 

may be given using the following ranges: 0-100; 
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101-250; 251-500; 501-750; 751-1,000; 1,001-1,500; 

and >1,500): 

2. Number of plant employees associated with the 

organic liquids distribution (non-gasoline) 

operation: 

E. Name of plant: 

F. Street address of plant: 

Latitude and longitude coordinates of plant: 

H. Name of contact(s) able to answer technical questions 

about the completed survey: 

Name Name 

Title Title 

Telephone Telephone 

III. Plant Operations 

A. Provide an plot plan of the entire facility within the 

fenceline. This figure should clearly indicate all 

storage tanks and their identifier codes, product 

loading or transfer areas, product flow lines, and 

wastewater drains and treatment areas. Use the same 

terminology/codes in identifying facility equipment as 

you will use in completing Tables 1 through 9 in 

Section IV. 

B. Provide a brief written description of the facility's 

operations. List the categories (gasoline, refined 

petroleum, solvents, glycols, etc.) of organic liquid 

materials handled during the base year, and the 

approximate volume throughput of each type of material, 

Also describe all activities that generate HAP 

emissions, including the storage, transfer, handling, 

8 
P.10 

and processing (such as blending or packaging) of the 

materials, as well as wastewater and other waste 

handling. Again, use consistent terminology and codes 

between the plot plan, the written description, and 

Tables 1 through 9 in Section IV. 

IV. HAPs--Emissions and Controls 

A. Complete Tables 1 through 9 for the HAP emission points 

and control techniques that exist at the facility. 

Sample entries are shown (in bold print) in several of 

the tables. Where necessary, make sufficient copies of 

blank tables to provide space for complete responses. 

Guidance to help you fill out these tables is provided 

below: 

1. Table 1--Enter a code for each organic liquid 

stored, handled, or loaded at the facility. This 

includes both pure liquids (e.g., benzene, 

methanol) and any liquid mixtures with an organic 

liquid content, such as wastewater. Codes are 

given for several potential liquids. Where known, 

include the requested liquid properties and the 

identity and concentration of HAPs present in the 

liquid. 

2. Table 2--Enter a code for each storage tank with 

greater than 10,000-gallon («250-barrel) capacity. 

Show each organic liquid stored in each tank during 

the base year, using the same liquid codes as used 

for Table 1. For each add-on control device used 

to control vapor emissions from storage tanks, fill 

out Table 8 for that type of device. 

3. Table 3--Enter each loading rack/loading arm that 

transfers organic liquids to tank trucks, railcars, 

barges, or tanker ships. We are also interested in 

operations that package these liquids into smaller 

containers, such as 55-gallon drums, 1-gallon or 1-

quart cans, etc. As in Table 2, fill out Table 8 

for each control device used to control vapor 

emissions from liquid transfers. 
P.11 

4. Table 4--List the principal sources of wastewater 

generation, using the supplied codes or your own 

description. Estimate the annual flow rate from 

each source. Drains are the individual entryways 

. to conduits that move water to storage or 

treatment. 

5. Table 5--In this table we wish to learn how 

wastewater is collected and treated at your 

facility(ies). For each wastewater source as 

listed in Table 4, list the number of collection 

units or treatment approaches applicable to each 

source. The last four columns request information 

on whether and how air emissions from each area are 

controlled. As in Tables 2 and 3, fill out Table 8 

for each control device used to control vapor 

emissions from wastewater. 

6. Table 6--Non-aqueous waste (semi-solid material, or 

sludge) may contain and emit HAP during storage, 

handling, or treatment. Identify each individual 

type of waste, and provide information on how the 

waste is collected and treated. As in Tables 2, 3, 

and 5, fill out Table 8 for each control device 

used to control air emissions from non-aqueous 

waste. 

7. Table 7--Identify the number of each type of 

equipment component by type of service (selecting 

the most prevalent service for each component). 

LDAR programs involve a formal leak survey of 

components on a fixed schedule (and may include a 

non-instrument, visual program). As in Tables 2, 

3, 5, and 6, fill out Table 8 for each control 

device used to control vapor emissions from 

equipment components. 

8. Table 8--Complete the applicable section of Table 8 

for each air pollution control device in use at the 

facility. Fill in the requested parameters if 

known, but even if you do not know the values, at 

least identify the presence of the device by 

returning a table showing the type of device and 

the emission sources that it controls. Be specific 

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when listing the emission sources; e.g., Tanks 1, 

2, 3, and 7; Loading Racks 1-5 and 11-15; all OilWater Separators; and so forth. 

l l 
P.13 

TABLE 1. ORGANIC LIQUIDS HANDLED AND HAP CONTENT(a) 

Organic Liquid Code (b): J TO 

Liquid Molecular Weight (lb/lb-mole): , 92 

Vapor Molecular Weight ,9 2 

(lb/lb-mole): 

Average True Vapor Pressure of Liquid (psia): , 0.3 

OR ! 

Reid Vapor Pressure of Liquid (RVP): . 

Average Liquid Density (Lb/Gal): , 7.3 

Avg. Temperature of Liquid Transferred (°F): , 60 

Name of HAPs Present in Liquid . Avg. HAP Concentration in Liquid (ppmw or percent) 

1,3-Butadiene , 

Acrylonitrile . 

Benzene . 

Cumene , 

Ethylbenzene . 

Ethylene dichloride . 

Ethylene glycol , 

Ethylene oxide . 

Formaldehyde . 

Methanol , 

m-Xylene , 

o-Xylene . 

Phenol , 

p-Xylene , 

Styrene . 

i 
P.14 

8 

TABLE 1. ORGANIC LIQUIDS HANDLED AND HAP CONTENT(a) (Continued) 

Toluene j 100% 

Vinyl chloride , 

(ti j 

1 ' 

a) For any liquid property or HAP content that is unknown, enter

 ttUK" on 

the corresponding blank. 

b) Select the organic liquid name that describes the material stored: 

AS = asphalt 

AV = aviation gasoline 

BZ = benzene 

CR = crude oil 

DI = diesel/distillate fuel 

JF = jet fuel (JP-4, etc.) 

JK = jet kerosene/kerosene 

LO = lube oil 

MG = motor vehicle gasoline 

13 
P.15 

9 

TABLE 1. ORGANIC LIQUIDS HANDLED AND HAP CONTENT(a) (Concluded) 

NA = naphtha 

OG = oxygenates (MTBE, other) 

RF = residual fuel oil 

BU 

AC 

CU 

EB 

ED 

EG 

EO 

FO 

ME 

MX 

OX 

PH 

PX 

ST 

TO 

VA 

VC 

XX 

0 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

1,3 -butadiene 

acrylonitrile 

cumene 

ethyl benzene 

ethylene dichloride 

ethylene glycol 

ethylene oxide 

formaldehyde 

methanol 

m-Xylene 

o-Xylene 

phenol 

p-Xylene 

styrene 

toluene 

vinyl acetate 

vinyl chloride 

slop oil/transmix/waste product 

other, please specify 

c) Provide the names of any additional HAPs not listed. 

14 
10 

TABLE 2. STORAGE TANK CONTROL DATA 

Tank 

ID 

Code 

(a) 

1-A 

1-A 

1-B 

1-B 

1-C 

Tank 

Capacity 

(Bbl) 

(b) 

20,000 

u 

24,000 

w 

12,500 

Name of 

Stored 

Liquid 

(c) 

AG 

JF 

T 

X 

L 

Annual 

Throughput 

(Bbl/Yr) 

60,000 

120,000 

40,000 

50,000 

50,000 

Roof 

Configuration 

(d) 

CEF 

M 

IFR 

« 

FXR 

Floating 

Roof 

Tanks 

Only: 

Seal Type 

(e) 

MS3 

u 

LM3 

u 

— 

Tank Roof 

Fittings 

(f) 

AHBG, GFWBG, VBG 

u 

M 

U 

— 

Add-on 

Control 

Device 

(g) 

C 

u 

u 

u 

— 
P.17 

11 

TABLE 2. STORAGE TANK CONTROL DATA (Continued) 

a) Provide a unique identifier code for each tank (e.g., A-l, B-1). 

b) Provide the maximum capacity for each tank. 

c) Use the same organic liquid codes as in footnote b of Table 1. 

d) Select the storage tank roof configuration: 

FXR = fixed roof 

IFR = internal floating roof 

EFR = external floating roof 

CEF = external floating roof converted to an internal floating 

roof. 

e) For floating roof tanks, enter the floating deck seal type: 

VMl = vapor-mounted primary seal only 

VM2 = vapor-mounted primary seal with weather shield 

VM3 = vapor-mounted primary seal with rim-mounted secondary seal. 

LMl = liquid-mounted primary seal only 

LM2 = liquid-mounted primary seal with weather shield 

LM3 = liquid-mounted primary seal with rim-mounted secondary seal 

MSI = mechanical shoe primary seal only 

MS2 = mechanical shoe primary seal with weather shield 

MS3 = mechanical shoe primary seal with rim-mounted • secondary seal 

0 = other (please specify type). 

f) For floating roof tanks, select the codes that best describe the types 

of roof fittings in place: 

GPWUU = guide pole well, unslotted, ungasketed sliding coverGPWUG= 

guide pole well, unslotted, gasketed sliding cover 

GPSWSUN = guide pole/sample well, slotted, ungasketed sliding cover, 

without float 

GPSWSUF = guide pole/sample well, slotted, ungasketed sliding 

cover, with float 

GPSWSGN = guide pole/sample well, slotted, gasketed sliding cover, 

without float 

GPSWSGF = guide pole/sample well, slotted, gasketed sliding cover, 

with float 

AHBG = access hatch, bolted, gasketed 

AHUU = access hatch, unbolted, ungasketed 

AHUG = access hatch, unbolted, gasketed 

GFWUU = gauge-float well, unbolted, ungasketed 

16 
P.18 

12 

TABLE 2. STORAGE TANK CONTROL DATA (Concluded) 

GFWUG = gauge-float well, unbolted, gasketed 

GFWBG = gauge-float well, bolted, gasketed 

GHSWG = gauge-hatch/sample well, gasketed 

GHSWU = gauge-hatch/sample well, ungasketed 

VBG = vacuum breaker, gasketed 

VBU = vacuum breaker, ungasketed 

g) Select the code(s) that best describe control systems, if any, used to 

control vapors emitted from any part of the tank, including rim seals, 

fittings, etc.: 

VCS1 = vapor collection system venting to a vapor/liquid absorption 

unit (scrubber) 

VCS2 = vapor collection system venting to an incinerator/boiler 

VCS3 = vapor collection system venting to a flare 

VCS4 = vapor collection system venting to a vapor/solid adsorption 

unit 

VCS5 = vapor collection system venting to a condenser 

B = ground level burner or thermal oxidizer 

C = catalytic oxidizer 

0 = other, please provide a full description (use extra sheet) 

N = none. 

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13 

TABLE 3 . LIQUID TRANSFER OPERATIONS 

Rack Arm 

ID Code (a) ID Code (b) 

Organic Liquid 

Transferred 

Through Arm (c) 

Type of 

Transport 

Vehicle or 

Container 

Filled (d) 

Annual 

Volume of 

Transferred 

Liquid 

(Gal/Yr) 

Method of 

Loading (e) 

Average 

Loading 

Rate 

(Gal/Min) 

Vapor 

Control Device (f) 

Control 

Device 

Efficiency (g) 

1 

1 

1 

2 

OC 

1-1 

1-2 

1-2 

2-1 

BZ 

TO 

MX 

MG 

T 

T 

R 

500,000 

400,000 

600,000 

1,000,000 

SUB 500 

500 

500 

200 

VCS1 

VCS2 

95(EJ) 

95(EJ) 

95(EJ) 

90(ST) 

CO 
P.20 

14 

TABLE 3. LIQUID TRANSFER OPERATIONS (Concluded) 

a) Provide a unique identifier code for each loading rack or other 

filling equipment. 

b) Provide a unique identifier code for each loading arm in a rack or 

equipment unit. 

c) Use the same organic liquid codes as in footnote b of Table 1. 

d) Select the type of transport vehicle loaded or container filled: 

T = tank truck 

R = tank car (railroad) 

B = barge 

T = tanker ship 

SC = small container (1 gallon or less; specify size) 

MC = medium container (>1 gal., <55 gal.; specify size) 

LC = large container (55 gal. drum or larger; specify size). 

e) Select the method of loading material: 

SPL = splash (top) 

SUB = top submerged 

BTM = bottom loading. 

f) Use the same control device codes as in footnote g of Table 2. 

g) Basis for control device efficiency estimate: 

SA = sampling and analysis 

EJ = engineering judgment 

ST = source test. 

19 
P.21 

15 

TABLE 4. WASTEWATER FLOW RATES AND DRAIN CONTROLS 

Source of 

Wastewater 

(a) 

Organic Liquid Content 

(b) Total Flow 

Rate 

(Gal/Yr) 

Number of 

Drains with 

Emission 

Suppression 

(c) 

Number of 

Drains without 

Emission 

Suppression 

(c) 

a) 

b) 

Select the codes that best describe the points of wastewater 

generation: 

TD 

SR 

LR 

LB 

0 

tank drains (identify the specific tanks using the same 

tank codes as in footnote a of Table 2) 

stormwater runoff 

loading racks (identify the specific racks using the 

same rack codes as in footnote a of Table 3 

liquid blending/packaging operations 

other, please provide full description (use extra 

sheet, if necessary). 

List the principal organic liquids typically present in each 

wastewater stream. 

c) Emission suppression controls reduce emissions from drain pipes 

and include, but are not limited to, water seal pots and p-traps. 

20 
16 

TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL(a) 

ro 

Wastewater Treatment Unit 

Collection Units: 

Manholes 

Junction Boxes 

Sumps/Catch Basins 

Lift Stations 

Storage Tanks 

(f) 

Treatment Approaches: 

Oil/Water Separators 

Air Flotation Systems 

Coagulation/ Precipitation 

Units 

Sand Filtration Unit 

No. of No. of No. of Units 

Uncovered Covered that Vent 

Units that Units that Emissions to 

Total Number Vent to the Vent to the a Control Control Device 

Source of Wastewater of Units Atmosphere Atmosphere Device (e) 

(b) (c) (d) (d) 

ro 

ro 
17 

TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL(a) (Continued) 

ro 

Wastewater Treatment Unit 

Equalization Units 

Treatment Approaches: 

Oxidation Ponds 

Activated Sludge Units 

Trickling Filters 

Clarifiers 

Filter Presses 

Strippers 

Stormwater Retention 

Effluent/ Recycle Pond 

Rotating Biological 

Contactors 

Ship Off Site 

(0 

Total Number 

Source of Wastewater of Units 

(b) (c) 

No. of 

Uncovered 

Units that 

Vent to the 

Atmosphere 

(d) 

No. of 

Covered 

Units mat 

Vent to the 

Atmosphere 

(d) 

No. of Units 

that Vent 

Emissions to 

a Control 

Device 

. } 

Control Device 

(e) 

ro 

co 
P.24 

18 

TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL (a) 

(Concluded) 

a) Include all wastewater collection and treatment units and any control 

devices controlling vapor emissions from such units. Do not report 

information on drains in this table; report drain information in Table 

4. 

b) Enter the sources of wastewater in the same row as the collection units 

and treatment systems in use at the facility. Use the same codes as in 

footnote a of Table 4, or your own description. 

c) Enter the total number of each type of collection unit and treatment 

system for each wastewater source. 

d) A unit should be considered covered if it has emission suppression 

devices in place. 

e) For each collection unit or treatment system vented to a control device, 

list the device and fill out the applicable section of Table 8. Use the 

same control device codes as in footnote g of Table 2. 

f) Provide the name(s) and other information for any additional wastewater 

collection unit(s) present at the facility. 

g) Provide the name(s) and other information for any additional wastewater 

treatment approach(es) used at the facility. 

23 
19 

TABLE 6 . NON-AQUEOUS WASTE COLLECTION AND CONTROL (a) 

to 

»** 

Type of 

Waste 

(b) 

Waste Generation 

Rate 

(Tons/Yr) 

(c) 

Waste Collected in a 

Closed System? 

(Yes/No) 

(d) 

Method of OnSite Storage 

(e) 

Waste Treated or 

Disposed of OnSite? 

(Yes/No) 

(0 

Method of OnSite Treatement 

or Disposal 

(g) 

Control Device 

on Treatment or 

Disposal Unit 

(h) 
P.26 

20 

TABLE 6. NON-AQUEOUS WASTE COLLECTION AND CONTROL (Continued) 

a) Non-aqueous waste is considered to contain between 10 and 90 percent 

solids. 

b) Select the waste code that best describes the non-aqueous waste type: 

AP = oil-water separator sludge 

Bl = biotreatment sludge 

HC = contaminated soil 

OT = oily trash and debris 

SO = slop oil emulsions 

SS = sump/sewer clean-out sludge 

B = tank bottoms 

ZZ = other, please specify (use extra sheet, if necessary). 

c) List the annual non-aqueous waste generation rate in tons per year. 

d) Identify (Yes or No) whether the waste is collected in a closed vapor 

collection system. A closed system has equipment to prevent or 

minimize waste contact with the atmosphere, such as: vapor recovery 

systems, enclosed pipes, or collection units with covers. 

e) Select the storage code that best describes the method by which nonaqueous waste is stored on-site prior to treatment or disposal: 

.AA = open tanks 

BB = fixed roof tanks 

CC = floating roof tanks 

DD = sealed DOT containers (55 gallon drums, 110 gallon bins, 

etc.) 

EE = open roll-off boxes 

FF = covered roll-off boxes 

GG = open ponds 

HH = covered ponds 

II = open pile 

J J = covered pile 

KK = other, please specify (use extra sheet, if necessary). 

f) Identify whether waste is treated or disposed of On-Site (Yes) or 

transported Off-Site for treatment and/or disposal within 90 days of 

generation (No) . 

25 
21 

TABLE 6. NON-AQUEOUS WASTE COLLECTION AND CONTROL (Concluded) 

g) If waste is treated or disposed of On-Site, select the treatment 

and/or disposal code(s) that best describe(s) how the waste is managed 

(if more than one code is applicable, separate multiple codes with a 

comma) : 

LF = land burial 

LT = land treatment/farming 

DW = dewatering 

ST = solidification/stabilization 

Bl = biotreatment 

IN = incineration/thermal destruction 

RE = recycled 

O = other, please specify (use extra sheet, if necessary). 

h) Use the same control device codes as in footnote g of Table 2. 
22 

TABLE 7. EQUIPMENT LEAK CONTROL DATA 

Leak Definition(a) 

Equipment 

Component 

HAP 

Equipment 

Service 

(b) 

Total 

Equipment 

Count 

Equipment 

Count in 

LDAR 

Program 

Leak 

Repair 

Response 

Time 

(c) 

LDAR 

Monitoring 

Frequency 

(Times/Yr) 

Equipment Counts 

with Mechanical 

Control Devices 

(d) 

Equipment 

Counts with 

a Closed 

Vent 

System(e) 

Closed Vent 

System Control 

Device 

(0 

Valves 

Compressors 

Flanges 
23 

TABLE 7. EQUIPMENT LEAK CONTROL DATA (Continued) 

\ 3 

X) 

Equipment 

Component 

Open-ended lines 

Sampling 

connections 

Pressure relief 

valves 

Leak 

HAP Equipment Repair LDAR Equipment Counts Equipment Closed Vent 

Equipment Total Count in Response Monitoring with Mechanical Counts with System Control 

Service Equipment LDAR Time Frequency Control Devices a Closed Device 

(b) Count Program (c) (Times/Yr) (d) Vent (f) 

System(e) 

• 
P.30 

24 

TABLE 7. EQUIPMENT LEAK CONTROL DATA (Concluded) 

a) The VOC concentration level (ppmv) at which equipment components are 

considered' to be leaking in the facility's leak detection and repair 

(LDAR) program (if applicable). Enter "VISUAL" if you have a visual 

leak inspection program. Enter "NONE" if you do not have a formal 

leak program. 

b) Select the equipment service definition that best describes the 

physical state of liquids at operating conditions: 

Gas = process fluids containing HAPs in a gaseous state at 

operating conditions 

LL = process fluids containing HAPs in a liquid state at 

operating conditions with a vapor pressure greater than 

kerosene (0.04 psia at 68 degrees F) 

HL = process fluids containing HAPs in a liquid state at 

operating conditions with a vapor pressure less than 

kerosene. 

c) Indicates the average repair response time (in days) once a leak has 

been discovered. 

d) Provide equipment counts for equipment with mechanical control devices 

such as: sealless valves, pumps with dual mechanical seals and a 

barrier fluid, compressors with mechanical seals and a barrier fluid, 

open-ended lines with caps/plugs/blind flanges, and pressure relief 

valves with rupture disks. 

e) Provide equipment counts for equipment with a vapor collection and 

recovery (closed vent) system. 

f) Use the same control device codes as in footnote g of Table 2. 

29 
P.31 

25 

TABLE 8. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS(a) 

Control Device: Scrubber 

Identifier Code: 

Type of scrubber: 

venturi 

packed bed 

impingement 

other (specify) 

Gas inlet temperature, "F 

Pressure drop, in H„0 

2 

3 

Liquid-to-gas ratio, gal/10 acfm 

Inlet scrubbing liquor: 

PH 

percent solids 

type of alkali added, if any 

rate (lbs/gal) 

Wastewater generation rate, gal/min 

HAP composition of wastewater, mg/{ 

Emission Sources (b) 

30 
P.32 

26 

TABLE 8. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS(a) (Continued) 

Control Device: Incinerator 

Identifier Code: 

Type: 

thermal 

catalytic 

Combustion chamber temperature. °F 

(please note if temperature measurement is not in chamber) 

Excess air, % 

Nominal residence time, s 

Heat recovery: 

recuperative, percent heat recovery 

regenerative, percent heat recovery 

Emission Sources (b) 

Control Device: Flare 

Identifier Code: 

Type: 

no assist 

steam assist 

air assist 

pressure assist 

Location: 

ground 

elevated 

Heat content of vented stream, Btu/scf 

Flare gas exit velocity, ft/s 

Flare tip diameter, in. 

Flare height, ft 

Supplementary fuel for: 

pilot, scfm 

combustion purposes, scfm 

Steam requirement, Ib/hr 

Emission Sources (b) 

31 
P.33 

27 

TABLE 8. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS(a) 

(Concluded) 

Control Device: Carbon Adsorber 

Identifier Code: 

Type of carbon bed and number: 

fixed 

fluidized 

How many pounds of carbon per bed 

Configuration: 

parallel 

serial 

Number of beds on-line 

Number of beds desorbing 

Pressure drop. in. H20 

Gas inlet temperature, °F 

Type of regeneration 

Regeneration time 

Adsorption time 

Emission Sources (b) 

Control Device: Condenser 

Identifier Code: 

Type of condenser: 

surface 

contact Tif contact see scrubbed 

Gas inlet temperature, °F 

Gas outlet temperature, °F 

Emission Sources (b) 

* , • 

a) A separate table should be filled out (after making copies of the 

blank table) for each individual scrubber, incinerator, flare, carbon 

adsorber, or condenser at the facility. For other types of control 

device, provide the most important parameters of operation on a 

separate sheet. 

b) List specific storage tanks, loading racks/arms, and wastewater and 

non-aqueous waste treatment or disposal processes, using ID codes and 

names from Tables 2, 3, 5, and 6. 

32