P.1 

OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

j^j4) W-E-6 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 74 of 110 
K e g 

A 98 13 

U-E- £ 

MEMORANDUM 

fli 

TO: Steve Shedd 

U.S. EPA/OAQPS/ESD/WCPG 

ESD Project No. 96/05 

FROM: GregLaFlam^ ' 

Pacific Environmental Services, Inc. (PES) 

DATE: May 19,1998 

SUBJECT: March 24,1998 Second Roundtable Meeting on the P-MACT for Organic 

Liquids Distribution (non-Gasoline) Facilities 

I. Purpose 

The purpose of this meeting was to bring together the project Work Team, including the 

EPA and its contractor, to discuss the draft presumptive MACT (P-MACT) document and, as 

time permitted, the industry survey that was going to be sent to organic liquids distribution 

(OLD) facilities. This work is in support of the development of national emission standards for 

hazardous air pollutants (NESHAP) for the Organic Liquids Distribution (non-Gasoline) source 

category. 

II. Location and Date 

U.S. Environmental Protection Agency 

EPA/NC Mutual Building, Room 838 

Durham, North Carolina 

March 24,1998,9:00 am to noon 

III. Participants 

\ 

In person 

Ted Cromwell, Chemical Manufacturers Association 

Bernd Haneke, Pacific Environmental Services, Inc. (PES) 

Cliff Harvison, National Tank Truck Carriers 

Jay Helms, PES 

Charles Hester, PES 

Greg LaFlam, PES 

Norman Morrow, Exxon Chemical Americas 

Steve Shedd, EPA 

Larry Sorells, EPA 

Don Wang, Union Carbide 

Gary Wilson, Marathon Oil Company 
P.3 

Memo - 2nd Roundtable 

May 19,1998 

Page 2 

Phone-in 

Joel Fazzio, International Matex Tank Terminals 

Tom Hmiel, BASF Corporation 

Jordan Jacobsen, Alyeska Pipeline Service Company 

Paul Jann, Dupont 

Brian Neville, Independent Liquid Terminals Association 

Karin Ritter, American Petroleum Institute 

Rick Wright, Ashland Chemical 

The attendance sheet filled out at the meeting is included as Attachment 1. 

IV. Discussion 

A. Presumptive MACT 

EPA Introduction 

After the participants introduced themselves, Steve Shedd began the discussion by 

reviewing the agenda for the meeting (see Attachment 2). He said that the discussion of issues 

and comments on the P-MACT would occur during the EPA's and PES's presentation of the PMACT results. Also, he stated that "next steps" in the project, a topic that was not listed on the 

agenda, would be discussed at the end of the meeting. 

Greg LaFlam referred to the draft P-MACT document that was E-mailed to the Work 

Team on March 19,1998, and apologized for the short review time. He then proceeded to 

review the determinations presented in the document, first covering affected sources and then 

the levels of control currently in place at OLD facilities. 

Affected Sources 

Mr. LaFlam reviewed the four basic categories of affected sources under consideration 

by the EPA project team, as summarized in Section 1.3.1 of the draft P-MACT document (see 

Attachment 3). He pointed out that these categories are similar to the source types discussed at 

the first Roundtable in January 1998. Norman Morrow mentioned that for pipeline facilities, 

the condition "after the point of custody transfer" applies only to petroleum facilities handling 

crude oil or natural gas liquids. He pointed out that chemicals are also handled by pipeline, so 

the description of pipeline facility should be broadened. 

Cliff Harvison asked whether the EPA had looked at cargo tank cleaning operations as 

an emission source. He said that, during these operations, vapors are typically expelled to the 

atmosphere. However, such cleaning is usually performed at separate (non-distribution) 

5L 
P.4 

Memo - 2nd Roundtable 

May 19,1998 

Page 3 

facilities. Mr. Shedd responded that we have not considered this emission source, but will 

investigate whether it should be part of this source category. However, he said it is doubtful 

that the rule would control off-site facilities. 

Gary Wilson asked whether it was a fair assumption to say that this rule will not cover 

any source that is covered by another Federal MACT rule. Mr. Shedd stated that this would be 

true for regulated operations, but some facilities may be only partially covered under other 

MACT rules. For these facilities (refineries or chemical plants), we would not cover any 

emission source already regulated, or that was addressed and the MACT decision was "no 

control", but we will look at any source within those facilities that was not addressed by other 

MACT rules, so long as it is associated with liquid distribution operations. Mr. Shedd pointed 

out that some distribution storage tanks at production facilities appear to have been left out of 

coverage by the Hazardous Organic NESHAP (HON) and the Refinery NESHAP, and we will 

collect information on those tanks to determine MACT. Also, loading racks transferring nongasoline liquids at refineries were left out of the MACT floor determination, and we also will 

collect information on these sources to determine MACT. For facilities controlled by NESHAP 

rules under 40 CFR Part 61 (non-MACT), decisions on appropriate control levels will have to 

be made according to the MACT statutes. 

Current Levels of Control 

Mr. LaFlam then began a review of the section of the P-MACT document on current 

levels of control, as summarized in Table 1-1 of Attachment 2. Mr. Morrow commented that 

the ideal method of determining P-MACT levels is to analyze the number of sources achieving 

various levels of control. The draft document, on the other hand, relies on the number of State 

or local rules requiring different control levels. The EPA should explain their methodology 

more completely, or do some type of weighting process based on the number of sources likely 

to be in each State involved in the P-MACT levels. Mr. Morrow said that this weighting 

procedure is particularly important for P-MACT for fixed roof tanks (FRTs) storing low vapor 

pressure liquids and for the 21 mg/liter emission limit shown for existing source transfer 

operations. The reason is that it seems to be marginal whether these two P-MACT 

determinations reflect true floor levels. For these two P-MACT levels, the appropriate vapor 

pressure and facility throughput cutoffs should be added to reflect the applicability of the rules 

used to arrive at those levels. Mr. Shedd said that we would review all of the rules in the PMACT to make sure that the correct cutoffs are reflected. He also pointed out that, in the 

Miscellaneous Organic NESHAP (MON) development, P-MACT is going to be issued after the 

MACT floors are determined. He felt that the OLD P-MACT should explain that the 

determinations are subject to change after additional information is collected about OLD 

industry practices. 

One participant pointed out that the term "pressure tank" (shown under the FRT, high 
P.5 

Memo - 2nd Roundtable 

May 19,1998 

Page 4 

vapor pressure category) should be defined because various pressures exist within tanks in 

different situations, such as backpressure from a control device. Also, an ASME pressure 

vessel is defined to be 15 psi or above, and a refrigerated pressure vessel operates at 1 psia. 

Two participants pointed out that existing rules contain a lower size cutoff for pressure vessels. 

Mr. Harvison began a discussion of the issue of cargo tank leakage. In Texas, where 

vapor recovery is mandated, operators are drilling holes or installing a "cleanout nipple" to 

comply with the rule, and this is creating a safety hazard because drivers must move around on 

the top of the trucks and are subject to falling. He said that most chemical trailers are the 

stainless steel, "clean bore" (uncompartmented) type (designated MC307 or MC312), and very 

few are equipped for bottom loading or vapor recovery. The DOT annual leak testing 

requirements are contained in Title 49, Part 180 of the CFR. The EPA's Method 27 (vapor 

tightness of cargo tanks) is considered by DOT to be an acceptable substitute to its own test 

methods, and in fact is the method of testing in common use. He also noted that they consider 

the Method 27 test to be more stringent than the DOT test for detecting vapor leakage that 

occurs during the loading of the tank. Mr. Shedd said that the Texas vapor recovery situation 

presents a concern and will need to be addressed; he recommended that the issue be placed on 

the issues list. However, he said that this issue should not affect the P-MACT process. Mr. 

Wright pointed out that, in the Bay Area (California), operators also are "gerry rigging" dome 

covers to comply with vapor recovery requirements. He also thought that Texas might require 

emission controls on tank cleanings. 

The subject of the control of equipment leaks was discussed next. Mr. Wright noted 

that Ashland's Houston facility performs instrument LDAR, and has found that very few 

components typically need repair. Their Bay Area facility has about 3,000 components and, 

again, has found very little leakage (leak definitions are 500 ppmv for pumps, and 100 ppmv 

for the remaining components). Mr. Shedd asked whether there are any data on leak rates for 

components at distribution facilities. Mr. Wilson stated, and others agreed, that the distribution 

components seem more like those at a gasoline distribution terminal (which have lower leak 

rates) than those at a refinery. Mr. Shedd pointed out that there may be a P-MACT for 

equipment leaks at new sources, so we need data to support existing and new source MACT 

floors. In the case of gasoline terminals, the EPA discovered that there is only a slight 

difference (0.2 percent) between emission factors at facilities performing instrument and visual 

LDAR programs. In any case, the industry needs to support their assumption about OLD 

i equipment leak rates with data. 

i 

\ j Paul Jann commented on the P-MACT levels shown for wastewater treatment and 

\ control. He said that the HON specifies cutoffs of HAP concentration and total flow rate that 

« trigger the control requirements in the rule, and these should be added to the P-MACT for this 

emission source. Mr. Shedd said that we would review the HON in more depth and add the 

appropriate applicability criteria to this section. Another participant noted that wastewater 

4-
P.6 

Memo - 2nd Roundtable 

May 19,1998 

Page 5 

should be defined to clarify that it is not meant to include stormwater. 

For blending and packaging operations, Mr. Wright pointed out that Ashland 

Chemical has 60 to 70 facilities in the U.S., and essentially all of them are area sources. Of 

three major sources, one is being rebuilt so that it will emit at less than the major source level, 

and another is a major source for VOC, but not for HAP. The Ashland facilities fill containers 

between 1,000 and 8,500 gallons in capacity. These containers have pressure-vacuum vents, 

and primarily bottom filling is used. The EPA and PES said that they realized that most of 

these operations are likely to be area sources, and they are working with the National 

Association of Chemical Distributors (NACD) to support this assumption and to consider this 

in the industry survey. However, the EPA is still interested in this type of source if it is 

collocated at a distribution plant site. 

Don Wang asked how the Consolidated Air Rule (about to be proposed) would affect 

this rulemaking. Mr. Shedd was not able to respond directly, but said that we would consider 

the CAR language in the OLD rule's proposal and discuss any impacts of the rule with Rick 

Colyer, the EPA lead on the CAR project. In addition, a review will be made of all applicable 

rule language prior to proposal so a decision can be made on the most appropriate language for 

this industry. 

Next Steps 

Mr. Shedd said that the project team would review the comments made at the meeting 

and revise the P-MACT document to reflect the comments. After the changes are made, the 

revised Table 1-1 and Section 5 detailing the P-MACT levels will again be sent out to the Work 

Team for review. Karin Ritter said that API had not had an adequate chance to review the PMACT and collect comments from its member companies. She said that they would supply 

written comments, and suggested a phone call to discuss their concerns in the next week or two. 

She also asked whether a third Roundtable meeting for P-MACT was planned, and Mr. Shedd 

said that this was not likely because no major problems had been found in the P-MACT process 

that need further discussion, and the EPA did not see the need for an additional meeting. 

B. Industry Survey 

The status of the planned industry survey, or information collection request (ICR), was 

discussed. In particular, the adequacy of the mailing list was addressed. Mr. Morrow felt that 

the smaller companies should be represented on the mailing list. Bernd Haneke stated that we 

are planning to add several NACD member companies, many of which may be smaller than the 

chemical manufacturers. Brian Neville stated that the ILTA member representation on the 

mailing list appeared to be adequate. Ms. Ritter said that the list had been sent to API 

members, but little comment had been received. 

$r 
P.7 

Memo - 2nd Roundtable 

May 19,1998 

Page 6 

The instructions that will accompany the survey were discussed next. Mr. Morrow 

pointed out that, in the HON, "rundown" tankage is covered, while "product" tankage is not. 

He suggested that respondents should not have to report on any sources that are already covered 

by the HON. Further, he felt that the survey should ask how many of the facility's tanks are 

already covered under the 40 CFR part 61 benzene rules, subparts Y and BB. Mr. Shedd 

responded that these rules were not based on MACT, and so such tanks would have to be 

included in the survey and the subsequent analysis. One participant asked whether the 

previously discussed emissions or liquid property cutoffs that determine who must respond had 

been changed since our last Team meeting (February 12,1998). Mr. Shedd responded that only 

facilities with actual annual emissions of 5 tpy or greater of a single HAP, or 12.5 tpy or greater 

of a combination of HAP will have to respond. Also, liquids to be surveyed must contain HAP 

of at least 1,000 ppmw and have a total vapor pressure of at least 0.1 psia. 

The survey question related to "percent utilization" of the facility was also discussed. 

Larry Sorells described the basis for the question; however, several participants appeared 

confused as to how this determination should be made for a facility. Mr. Sorells said he would 

expand the current language in the instructions so that respondents would understand the use of 

the data so they could respond appropriately. 

The question was raised about a possible workshop (probably in mid-May) to answer 

questions that companies may have on filling out the ICR, and the meeting participants were 

unsure as to the utility of such a workshop. Mr. Shedd said that the project team would pursue 

this idea with API and ILTA to see whether they would be interested in coordinating a 

workshop, since API had suggested such a workshop at the first Roundtable meeting. 

Next Steps 

Mr. Shedd said that a revised draft of the ICR instructions was almost ready, and would 

be sent out to the Team next week for a quick review before finalization. The survey is planned 

to be sent out to companies in the next few weeks (paper copies), and an electronic version will 

also be placed on the EPA's Technology Transfer Network (website). 

& 
P.8 

Attachment 1 -

Attendance Sheet 

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Attachment 2 -

Agenda 

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<=. 
P.11 

U.S. EPA - ORGANIC LIQUIDS DISTRIBUTION RULE 

2nd ROUNDTABLE MEETINGREVIEW OF DRAFT P-MACT 

EPA/NC Mutual Building, 8th Floor Conference Room, Room #838 

Durham, North Carolina 

March 24,1998 

© Call-in number: (919) 541-4485 

Agenda 

9:00-9:15 

9:15-10:00 

Introductions 

Review of Meeting Objectives and Agenda 

Summary of Draft P-MACT Determinations 

- affected sources 

-levels of control 

U.S. EPA 

U.S. EPA/PES 

10:00-11:00 

11:00-12:00 

Discussion of Issues Affecting P-MACT All Participants 

Team Comments and Suggestions for Revising All Participants 

Draft P-MACT Document 

12:00-1:00 Discussion of Other Related Issues 

- draft industry survey 

- storage tanks at production facilities 

- loading racks at refineries 

- survey mailing list 

- coverage and addresses 

- other issues 

All Participants 

1:00 Meeting Adjourn 

IO 
P.12 

Attachment 3 -

Draft P-MACT Document 

n 
P.13 

PRESUMPTIVE MACT FOR 

ORGANIC LIQUIDS DISTRIBUTION 

(NON-GASOLINE) FACILITIES 

DRAFT 

MARCH 19,1998 

Waste and Chemical Processes Group 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 

\2 
P.U 

TABLE OF CONTENTS 

Section Page 

1.0 Overview of the Presumptive MACT Determination 1-1 

1.1 Background 1-1 

1.2 Available Data 1-1 

1.3 Summary of Presumptive MACT 1 -2 

1.3.1 Affected Sources 1-2 

1.3.2 Control Levels for P-MACT 1-3 

2.0 Source Category and Affected Sources 2-1 

2.1 Stand-Alone or Separate Distribution Terminals 2-1 

2.2 Collocated Distribution Facilities 2-2 

2.3 Pipeline Facilities 2-2 

2.4 Compounding/Blending/Packaging Facilities 2-3 

2.5 Affected Sources/Conclusions 2-4 

3.0 Emission Sources 3-1 

3.1 Storage Vessels 3-1 

3.2 Liquid Transfer Operations 3-2 

3.3 Leaks from Equipment Components 3-2 

3.4 Wastewater and Other Wastes 3-2 

3.5 Blending and Packaging Operations 3-3 

4.0 Emission Controls 4-1 

4.1 Storage Vessels 4-1 

4.2 Liquid Transfer Operations 4-1 

4.3 Equipment Components 4-1 

4.4 Wastewater and Other Wastes 4-1 

5.0 Current Control Levels 

5.1 Conclusions on Level of Control 5-1 

5.1.1 Fixed Roof Storage Tanks 5-1 

5.1.2 External Floating Roof Tanks 5-3 

5.1.3 Liquid Transfer Operations 5-6 

5.1.4 Wastewater Treatment 5-7 

5.1.5 Equipment Leaks 5-8 

ii 

1 5 
P.15 

Section Eage 

5.2 Federal Regulations 5-8 

5.3 State/Local Regulations 5-12 

6.0 Summary of Issues and Next Steps 6-1 

6.1 Issues in the NESHAP Development 6-1 

6.2 Next Steps 6-2 

7.0 References 7-1 

Attachments 

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

Facilities (Presentation Format) 

Attachment 2 Memorandum—Summary of State/Local Rules 

in 

| 4~ 
P.16 

DRAFT 3/19/98 

1.0 OVERVIEW OF THE PRESUMPTIVE MACT DETERMINATION 

1.1 Background 

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

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

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

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

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

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

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

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

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

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

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

individual sources. 

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

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

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

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

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

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

best controlled similar source, as determined by the Administrator. 

This document presents options for presumptive maximum achievable control 

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

determinations. It also provides a foundation and blueprint for developing a rule proposal and a 

final NESHAP regulation. 

1.2 Available Data 

The EPA project team considered several available sources of information in preparing 

this P-MACT document. These included a comprehensive literature search and review of 

existing regulations, as well as meetings and other contacts made with companies and trade 

organizations. In addition, an industry survey has been prepared in order to collect detailed 

facility-specific infonnation on current control practices. However, no survey results are 

available for use in setting P-MACT at this time. 

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

1-1 

I < 
P.17 

DRAFT 3/19/98 

Jersey and Philadelphia in December 1997. Since the information obtained on these visits is 

being treated as confidential business information (CBI) pending review by the plant owners, 

detailed information from the visits has not been used to determine P-MACT. 

A comprehensive review of existing and planned regulations affecting this industry was 

undertaken to allow conclusions concerning current levels of control. The results of this review 

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

the next subsection. 

An EPA/industry Roundtable meeting was held on January 21,1998. A second 

meeting/teleconference of the Work Team was held on February 12,1998 to discuss the draft 

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

with a number of other conversations and written communications, provided useful information 

to the project team in the development of this document as well as the survey. 

A detailed industry questionnaire will be sent to companies nationwide in the near future. 

As mentioned earlier, no survey results were available to incorporate into the P-MACT 

document. 

1.3 Summary of Presumptive MACT 

1.3.1. Affected Sources 

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

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

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

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

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

facility types include: 

1. Stand-alone or separate distribution terminals 

2. Distribution activities collocated with petroleum refineries or chemical production 

plants 

3. Pipeline facilities after the point of custody transfer (i.e., downstream of oil and 

gas production operations) 

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

or blends. 

1-2 

If o 
P.18 

DRAFT 3/19/98 

1.3.2 Control levels for P-MACT 

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

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

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

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

stringent, and may be more stringent than~ 

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

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

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

categories or subcategories with fewer than 30 sources." 

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

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

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

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

selecting P-MACT. 

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

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

facilities described above. 

1-3 

& 
P.19 

DRAFT 3/19/98 

TABLE 1-1. SUMMARY OF P-MACT DETERMINATIONS 

(Based on Federal, State.and local air pollution rules) 

Emission Source 

P-MACT 

New Sources Existing Sources 

IIHMH^^HII^BHIHHHi 

A. Fixed Roof Tanks, 

low vapor pressure liquids 

B. Fixed Roof Tanks, high vapor 

pressure liquids 

C. Small Tanks 

D. External Floating Roof Tanks 

(General) 

E. External Floating Roof Tanks 

(Welded) 

> 10k gallons: 

Floating roof, or closed vent 

system controlled at 95% by 

weight. 

> 11 psia: 

Pressure tank with no detectable 

emissions fNDE) 

20k-40k gallons and > 4 psia, an 

> 40k gallons and > 0.75 psia: 

Floating roof, or 95% control by 

weight. 

> 11 psia: 

Pressure tank with NDE, or 95% 

control by weight. 

> 250 gallons: 

Install a permanent submerged fill pipe. 

> 10k gallons: 

Specified roof seal and fittings 

requirements (see Section 

5.1.2.1). 

> 20k gallons and > 1.5 psia; or 

> 40k gallons of any liquids: 

Same seal and fittings requirements as 

for new sources. 

Tanks of welded construction and < 4 psia: 

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

5.1.2.2). 

H. LIQUID TRANSFER 

A. Loading Racks 

B. Cargo Tank Leakage 

> 0.5 psia: 90 % emission 

reduction; 

>1.5 psia: Emission limit of 10 

mg per liter of liquid loaded. 

>1.5 psia: Emission limit of 21 

mg/liter or 90% control by weight, 

whichever is more stringent 

Detailed industry data needed to make a determination. 

III. EQUIPMENT LEAKS 

Detailed industry leak check practice data needed to make a 

determination; see Section 5.1.5. 

Table continued on next page. 

1-4 
DRAFT 3/19/98 

TABLE 1-1. SUMMARY OF P-MACT DETERMINATIONS (Cont.) 

(Based on Federal, State,and local air pollution rules) 

P.20 

Emission Source 

P-MACT 

New Sources Existing Sources 

IV. WASTEWATER TREATMENT AND CONTROL 

Floating roof for wastewater 

storage tanks, or 95% control by 

weight. 

Detailed industry wastewater 

treatment technology data needed to 

make a determination; see Section 

5.1.4. 

tiliiiwwii 

Detailed industry data required to make a determination. 

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

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

is included as Attachment 2. 

1-5 

19 
DRAFT 3/19/98 

2.0 SOURCE CATEGORY AND AFFECTED SOURCES 

In the background information document1 for the EPA's initial source category listing 

under Section 112(c), a preliminary definition of this source category provided that Organic 

Liquids Distribution (non-Gasoline) source category activities are associated with the storage and 

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

from which organic liquids may be obtained for further use and processing. This definition is 

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

makeup of this industry. 

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

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

1. Stand-alone or separate distribution terminals 

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

3. Pipeline facilities after the point of custody transfer 

4. Compounding/blending/packaging plants 

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

Organic Liquids Distribution source category. 

2.1 Stand-Alone or Separate Distribution Termmals 

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

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

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

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

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

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

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

manufacturers, product manufacturers, utilities, and transportation companies. 

Many of these facilities are members of the Independent Liquid Terminals Association 

(ILTA), which maintains a current directory of its associated member facilities2. Stand-alone 

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

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

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

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

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

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

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

2.2 Collocated Distribution Facilities 

Many chemical and petrochemical companies and petroleum refineries may have 

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

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

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

being that these facilities receive their material from a collocated facility. HAP-containing 

liquids may be stored in these facilities and then distributed via the various modes of delivery. 

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

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

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

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

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

future (see also Attachment 1, page 16). 

2.3 Pipeline Facilities 

Two types of pipelines are of interest to the Organic Liquids Distribution source category, 

crude oil pipelines and product (non-gasoline) pipelines. The source category is considered to 

include petroleum pipeline facilities that handle and distribute non-gasoline hydrocarbon liquids 

(containing HAP) after the point of custody transfer from oil and gas production operations. This 

discussion by custody transfer is to match the proposed oil and natural gas rule. • At this time, it is 

believed that the principal liquid of interest at these facilities is crude oil, because of its 

significant vapor pressure and the large volumes that are transported. Pipeline facilities are 

usually subsidiaries of oil and gas producing companies. 

Crude oil pipelines consist of flow lines, crude trunk lines, and breakout stations. Flow 

lines carry oil from the producing field to a treatment and storage facility, referred to as a tank 

battery. Upon being treated, oil is then stored in lease tanks for shipment. Upon leaving a lease 

tank (point of custody transfer), oil moves through gathering lines that transport the oil to large 

tank farms where it is accumulated prior to being transported via long-distance pipelines, 

referred to as crude trunk lines. Crude oil is transported through pipelines by pump stations 

located along their entire length3. 

Breakout tanks occur at many pump stations along pipelines and serve to sort, measure, 

reroute, or store crude oil. These tanks are also used for controlling surge capacities of crude oil. 

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Product pipelines represent another category of the pipeline industry. Product pipelines 

move liquids such as natural gas liquids, gasoline, aviation gasoline, fuel oils, and other organic 

liquids from refineries to storage and distribution facilities/terminals in areas where they will be 

consumed. 

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

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

1, page 13): 

4612 Crude Petroleum Pipelines 

4613 Refined Petroleum Pipelines 

4619 Pipelines, Not Elsewhere Classified 

4789 Transportation Services, Not Elsewhere Classified 

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

petroleum and other liquids, except natural gas. SIC code 4789 represents independently 

operated pipeline terminal facilities, but also "establishments primarily engaged in furnishing 

transportation or services incidental to transportation, not elsewhere classified."4 

2.4 Compounding/Blending/Packaging Facilities 

It is currently thought that facilities exist that compound and blend and distribute organic 

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

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

liquids, which they blend and package into containers ranging from up to about 600 gallons to 

less than 1 gallon. 

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

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

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

see Section 2.2.) 

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

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

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

products."4 Included in the SIC code listing are establishments that distribute solvents, aromatic 

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

Attachment 1, page 15). 

To locate and identify these facilities, the EPA project team has contacted the National 

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Association of Chemical Distributors (NACD) and is reviewing the organization's member 

directory5. Telephone interviews with and site visits to these facilities are also planned for a later 

point in time. The project team expects that the industry survey will provide information on the 

emissions and controls in this industry segment. 

2.5 Affected Sources/Conclusions 

The EPA project team has decided to retain the broad definition of the organic liquids 

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

sources of emissions. However, this definition is expected to be improved as additional 

information is gathered on the industry. As a supplement to the definition, specific facility types 

and activities will be described in order to identify the affected sources. At this time, data are 

still being collected to identify and locate the stand-alone and collocated sources of interest. 

The focus of the project is major sources. These are defined under Section 112 of the Act 

as "any stationary source or group of stationary sources located within a contiguous area and 

under common control that emits or has the potential to emit considering controls, in the 

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

any combination of hazardous air pollutants." The EPA's listing of HAP source categories listed 

the OLD category as a major source category, but not as an area source category. However, the 

EPA plans to perform a finding for OLD area sources, to determine whether they present a threat 

of adverse effects to human health or the environment. Under §112(c)(3), standards may be 

warranted for area sources in the case of a finding of adverse effects to human health or the 

environment. 

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3.0 EMISSION SOURCES 

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

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

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

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

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

1. Storage vessels 

2. Liquid transfer activities (loading racks) 

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

4. Wastewater and waste collection and treatment. 

At the facilities that blend or package liquids, these blending and packaging activities may also 

constitute a separate source of emissions. 

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

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

sources. This type of infonnation is being studied for several other NESHAP industries with 

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

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

emission sources, and are described in the following sections. 

3.1 Storage Vessels 

Two basic categories of storage vessels are found at OLD facilities: 

1. Liquid storage tanks at terminals or other distribution operations 

2. Breakout tanks at pipeline stations 

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

production facility (chemical production or petroleum refinery), storage tanks receive incoming 

organic liquids and distribute them back out of the facility. Modes of transport include: inland 

waterway barges, tanker (oceangoing) vessels, tank trucks, railway tankcars, and pipelines. 

Petroleum pipelines are used to transport crude oil and petroleum products after the point 

of custody transfer from oil production operations. At the pipeline pump stations, "breakout 

tanks" are used for surge capacity, sorting, measuring, rerouting, and temporary storage. These 

breakout tanks receive liquid from the pipeline, and then return it back to the same pipeline. 

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

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

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

storage6. 

3.2 Liquid Transfer Operations 

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

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

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

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

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

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

vapor collection system. 

3.3 Leaks from Equipment Components 

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

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

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

regulations address this emission source (see Section 5.2). 

3.4 Wastewater and Other Wastes 

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

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

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

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

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

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

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

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

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

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

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

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

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

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3.5 Blending and Packaging Activities 

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

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

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

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

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

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

other wastes. The project team is presently gathering information on the details of these 

operations. 

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4.0 EMISSION CONTROLS 

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

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

principal emission controls believed to be in use for OLD operations. Section 5 will discuss the 

levels of control required under existing regulations. 

4.1 Storage Vessels 

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

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

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

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

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

roof that includes seals around the perimeter and sometimes other fitting controls to minimize 

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

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

4.2 Liquid Transfer Operations 

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

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

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

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

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

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

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

piping (see also Attachment 1, page 25). 

4.3 Equipment Components 

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

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

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

inspection of components for leaks using a hydrocarbon analyzer. An alternative to instrument 

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

program (see also Attachment 1, page 25). 

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4.4 Wastewater and Other Wastes 

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

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

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

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

also Attachment 1, page 30). 

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

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

handling that the waste is exposed. 

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5.0 CURRENT CONTROL LEVELS 

The presumptive MACT (P-MACT) determination is derived from a thorough review 

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

Orgamc Liquids Distribution NESHAP. Specific source information will be provided from the 

planned industry survey. The determinations for existing sources in this P-MACT are based 

on an average of the top 12 percent of the standards in the State regulations reviewed. The 

determinations in this document for P-MACT for new sources are based on the most stringent 

State or Federal regulation requirements for similar emission sources. Section 112(d) states 

that standards for new and existing sources must be derived from "the emission control that is 

achieved in practice by the best controlled similar source." Again, little current industry 

practice information is available at each source; therefore, this P-MACT has been derived 

from control levels found in Federal, State, and local regulations that apply to similar 

industries. 

5.1 Conclusions on Level of Control 

5.1.1 Fixed Roof Storage Tanks 

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

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

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

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

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

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

NESHAP (HON), Benzene Storage NESHAP, and the Storage Vessel NSPS (40 CFR 60, 

subpart Kb). In most cases the State regulations apply to the entire State, while others apply 

only in certain areas of the State, such as urban areas that are nonattainment for ozone. The 

top 12 percent, in terms of stringency, of the storage vessel regulations were regulations for 

urban or nonattainment areas. The distribution of State standards is as follows: 

Top 12% (5 of 51 rules) - > 19,800 gallons and > 1.5 psia; or 

> 39,630 gallons and > 0.5 psia: 

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

Top 25% (13 of 51 rules, also equivalent to 40 CFR 60, subpart Kb) -

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DRAFT 3/19/98 

> 20,000 gallons and < 40,000 gallons and >4 psia; or 

> 40,000 gallons and > 0.75 psia: 

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

Top 35% (18 of 51 rules) - > 40,000 gallons and > 1.5 psia: 

Pressure tank, floating roof, or vapor control at 95% by weight. 

The requirements of the Storage Vessel NSPS, subpart Kb, are noted above. Rim seals 

must consist of a liquid mounted seal, mechanical shoe seal, or a vapor-mounted primary seal 

plus secondary seal. Several of the fittings on the tank also have control requirements under 

Subpart Kb. The MACT standards for storage vessels in the HON and the Benzene Emissions 

from Storage Vessels (Benzene Storage) NESHAP require a floating roof or a closed vent 

system vented to a control device at 95 percent emission reduction for any storage tank 

> 10,000 gallons. The HON requirements are for storage tanks associated with a process unit 

which hold any organic HAP as listed in Table 2 of 40 CFR 63, subpart F. The Benzene 

NESHAP standards are for the storage of benzene within a specified range of specific 

gravities. 

Based on these Federal, State, and local regulations, P-MACT for new sources is 

equivalent to a floating roof or 95% emission reduction for organic HAP liquids stored in 

storage tanks > 10,000 gallons. For existing sources, P-MACT is equivalent to the average of 

the top 12% of the state regulations as shown above. 

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

The determination for high vapor pressure organic liquids storage is based on 15 State 

regulations, and augmented by the HON, the Benzene Storage NESHAP, the Storage Vessel 

NSPS (subpart Kb), and the Storage Vessel NESHAP (subpart WW) which is yet to be 

proposed. All of the regulations reviewed considered any organic liquid > 11 psia to fit the 

definition of a "high vapor pressure" or "extremely volatile" liquid. The most stringent rules 

(top 20 percent) consisted of one urban area rule (San Diego) and two statewide rules 

(Colorado and New Mexico). The distribution of these standards is as follows: 

Top 20% (3 of 15 rules) - Operate a pressure tank with no detectable emissions 

Top 50% (4 of 15 rules) - Pressure tank or vapor control at 90% efficiency 

Top 75% (4 of 15 rules) - Vapor control at 85% efficiency 

The unproposed 40 CFR 63, subpart WW NESHAP for storage vessels requires that all 

pressure tanks operate with no detectable organic emissions. The requirements of the NSPS 

for Storage of Organic Liquids, 40 CFR 60, subpart Kb are to operate a closed vent system, 

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with no detectable organic emissions, that is routed to a control device to reduce emissions by 

95 %. The MACT standards for storage vessels in the HON and the Benzene Storage 

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

emissions. 

Based on these Federal, State and local regulations, P-MACT for the storage of high 

vapor pressure liquids (> 11 psia) for new sources is to operate a pressure tank with no 

detectable emissions. For existing sources, P-MACT is to operate a pressure tank with no 

detectable emissions or a vapor control system at 95% by weight emission reduction. 

5.1.1.3 Small Fixed Roof Storage Vessels 

The P-MACT level for small tanks that are top loaded was derived from 10 State 

regulations. Eight of the ten regulations are statewide regulations. The top 10 percent 

consists of the Chicago-Area, Illinois regulation. The remaining standards are as follows: 

Top 10% (1 of 10 rules) - > 250 gallons; Orgamc liquids; Top loaded: 

Equipped with a permanent submerged fill pipe. 

Top 50% (4 of 10 rules)- > 1,000 gallons and organic liquids > 1.5 psia; Top loaded: 

Equipped with a permanent submerged fill pipe. 

No Federal regulations with regard to small storage tanks have been located at present. 

Based on the 10 State regulations reviewed, P-MACT for new and existing sources is 

the same as for the top 10% listed above; i.e., a permanent submerged fill pipe installed in all 

top loaded stationary tanks >250 gallons. 

5.1.2 External Floating Roof Tanks 

Within the State and regional regulations, nine of which were reviewed for the purpose 

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

standards. The first category is the general standards. Second are exemptions and standards 

for welded tanks. Lastly, standards exist that apply to tanks used to store produced crude oil 

and condensate prior to lease custody transfer. 

5.1.2.1 General Standards 

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

listed below is similar among the Federal (HON, subpart WW, and subpart Kb) and State 

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regulations. The external floating roof seal requirements in the rules reviewed are as follows: 

For petroleum liquid storage: 

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

the floating roof to the tank wall; 

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

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

3. For vapor-mounted primary seals, the accumulated area of individual gaps (>0.125 

inch) between the secondary seal and the tank wall, must not exceed 1.0 square inch 

per foot of diameter; 

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

remain floating on the liquid at all times. 

For non-petroleum organic liquid storage: 

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

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

tank wall; 

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

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

extending from the floating roof to the tank wall; 

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

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

4. For vapor-mounted primary seals, the accumulated area of individual gaps (> 0.125 

inch) between the secondary seal and the tank wall, must not exceed 1.0 square inch 

per foot of diameter; 

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

remain floating on the liquid at all times. 

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

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

off or landed on the roof supports. 

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

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

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

equipped with a gasket. 

Because of the similarity in the seal and fittings requirements among the Federal and 

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State rules, the distribution of standards shown below is based on tank volume and vapor 

pressure cutoffs. The general external floating roof tank standards are distributed by 

stringency as follows: 

Top 10% (1 rule, New York) - > 20,000 gallons and > 1.5 psia; or 

> 40,000 gallons: Roof seal and fittings requirements as listed above. 

Top 40% (3 rules) - > 40,000 gallons: Roof seal and fittings requirements as listed 

above. 

Top 50% (1 rule) - > 40,000 gallons and > 1.0 psia: Roof seal and fittings 

requirements as listed above. 

Top 60% (1 rule) - > 40,000 gallons and > 1.5 psia: Roof seal and fittings 

requirements as listed above. 

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

is the application of the above listed seal and fittings requirements to storage of organic HAP 

liquids in storage tanks > 10,000 gallons. For existing sources, P-MACT is the average of the 

top 10 percent of the State regulations as shown above; that is, the aforementioned seal and 

fittings requirements apply to storage tanks > 20,000 gallons storing liquids > 1.5 psia, and to 

tanks >40,000 gallons storing any organic liquids. 

5.1.2.2 Tanks of Welded Construction 

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

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

or a metallic-type shoe seal was determined from a review of the CTG for Petroleum Liquid 

Storage in External Floating Roof Tanks and eight regional and statewide regulations. Each of 

these regulations has the same standard: 

Top 100% (all 8 rules) - All external floating roof tanks of welded construction 

containing petroleum liquids < 4 psia: No secondary seal is required if the 

primary seal is a liquid-mounted foam seal, liquid-mounted liquid-filled type 

seal, metallic-type shoe seal, or equivalent. 

5.1.2.3 Produced Crude Oil and Condensate Storage 

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

Vessel NSPS (40 CFR 60, subpart Kb), 18 statewide, and 2 regional/urban regulations 

(Chicago Area and District of Columbia) allow an exemption from regulation for external 

floating roof tanks < 420,000 gallons which store produced crude oil or condensate prior to 

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lease custody transfer. The source category for this NESHAP is likely to not include crude oil 

and condensate prior to lease custody transfer because they are currently proposed to be 

controlled under the Oil and Gas MACT rule; therefore, no P-MACT exemption is needed for 

such tanks. 

5.1.3 Liquid Transfer Operations 

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

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

equipment. 

5.1.3.1 Loading Racks 

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

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

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

subpart Y), and 25 State regulations. Some State regulations contain provisions based on 

vapor emissions control by percent reduction, while others are based on an emission limitation 

in units of mg/L or lb/1,000 gallons loaded. The determination of relative stringency is 

complex, and varies depending on the uncontrolled emission factor of the liquids in question. 

For transfer of high vapor pressure liquids, an emission limit standard would be more 

stringent. For low vapor pressure liquids transfer, emissions reduction on a weight percentage 

basis is more stringent. This issue will be investigated further for the principal liquids of 

interest in the OLD category. For the purpose of P-MACT, the following is considered to be 

the stringency distribution of the current standards: 

Top 5% (California, South Coast) - Organic liquids >0.5 psia: 

Vapor control at 90% by weight 

Organic liquids >1.5 psia: 

10 mg/L (0.08 lb/1,000 gallons) emission limit 

Top 10% (California, Bay Area) - Organic liquids > 1.5 psia; 21 mg/L 

(0.17 lb/1,000 gallons) emission limit, or vapor control at 90%, whichever is 

more stringent. 

Top 15% (Texas-Houston) - Organic liquids >0.5 psia: Vapor control at 90% 

Top 35% - Organic liquids > 1.5 psia: Vapor control at 95% 

Top 50% - Organic liquids > 1.5 psia: Vapor-tight vapor balance system 

Top 75% - Organic liquids: Submerged loading required. 

The HON standards for transfer operations of organic HAP state that new sources must 

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have a vapor recovery system that reduces emissions by 98 percent. For existing sources, the 

emissions must be reduced by 97 percent. The Gasoline Distribution NESHAP and the 

Refinery NESHAP set the same emission limit, 10 mg/L for gasoline transfer operations. The 

Benzene Transfer Operations NESHAP requires 98 percent emission reduction of any organic 

liquid that is at least 70 percent benzene, by means of a vapor-tight vapor recovery system. 

The Marine Vessel NESHAP requires 98 and 97 percent emission reduction of any organic 

liquid > 1.5 psia for new and existing sources, respectively. Emissions limitations specified in 

the bulk terminal CTG and the NSPS for bulk gasoline terminals are 80 mg/L and 35 mg/L, 

respectively. 

P-MACT for new sources is a requirement of 90% emission reduction for organic 

liquids >0.5 psia, and an emission limit of 10 mg/L for organic liquids > 1.5 psia. P-MACT 

for existing sources applies to organic liquids > 1.5 psia, and consists of a requirement of 90% 

emission reduction or an emission limit of 21 mg/L of liquid loaded, whichever is more 

stringent. 

5.1.3.2 Vapor Leakage 

Control requirements for vapor leakage from controlled liquid transfer operations have 

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

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

test for tank trucks (and sometimes railcars) and leak testing using a combustible gas detector. 

In addition to these requirements, DOT requires periodic hydrostatic pressure testing of tank 

vehicles. The vapor tightness requirements by the States and the EPA have primarily 

addressed gasoline transfer operations. 

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

organic liquids distribution is unknown. The project team will be collecting additional 

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

potential from these measures. 

5.1.4 Wastewater Treatment 

The determination related to air emissions from wastewater during collection and 

treatment is based on a review of seven current statewide wastewater regulations. Four State 

regulations have standards for oil-water separators that handle >200 gallons/day of 

wastewater containing any volatile organic compunds >0.5 psia. In general, the State 

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

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

appropriate MACT standards for wastewater, more information will be obtained by the project 

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team with respect to current industry wastewater technologies and processes. 

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

guidance for evaluating the best current control performance in wastewater treatment 

operations. The HON standards for wastewater separators, drain systems, treatment systems, 

and surface impoundments are based upon wastewater which: 

1. contains > 10 ppmw total volatile organic HAPs and has a flow rate >0.02 

liters/minute; or 

2. contains > 10,000 ppmw at any flow rate. 

The wastewater operations of the facilities in the. Organic Liquids Distribution source 

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

therefore, P-MACT for new sources is the requirement for a floating roof or control device at 

95 percent emission reduction for wastewater, as defined above, in storage tanks. Currently, 

the practices of the source category are not known in sufficient detail to develop P-MACT for 

wastewater treatment for existing sources. The upcoming industry survey is expected to 

provide the detailed information needed to determine the appropriate control levels. 

5.1.5 Equipment Leaks 

The equipment at facilities in the Organic Liquids Distribution source category are 

assumed to be similar to those at a HON, Refinery, or Gasoline Distribution facility. The 

HON and Refinery NESHAP have full instrument LDAR requirements, while the Gasoline 

Distribution NESHAP has a visual leak check standard. It is not known presently, which 

standard is more reasonable for the Organic Liquids Distribution P-MACT, therefore there is 

no P-MACT determination for new sources. To determine the equipment leak standards for 

existing sources, more detailed information as to the current practices within the source 

category is needed. These data are expected to be collected in the planned industry survey. 

5.1.6 Blending and Packaging 

Specific rules affecting blending and packaging activities directly have not been 

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

Additional information is planned to be collected through site visits, other contacts with 

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

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

5-8 

^U 
P.38 

DRAFT 3/19/98 

5.2 Federal Regulations 

Below are brief summaries of several Federal rules that may apply or have similar control 

levels and technologies to the distribution facilities in this source category. 

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

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

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

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

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

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

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

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

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

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

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

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

with proper seals and fittings; or (4) a closed vent system with a 95 percent efficient control 

device. 

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

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

apply to the loading of liquid organic HAPs at an operating pressure in excess of 204.9 kPa (27.9 

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

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

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

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

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

may be used. 

5.2.2 Petroleum Refinery NESHAP (subpart CC) 

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

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

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

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

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

5-9 

ST-
P.39 

DRAFT 3/19/98 

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

the tank fits either of the two following scenarios: (1) tank capacity >40,000 gallons, TVP >0.5 

psia, and HAP liquid concentration >2%; or (2) tank capacity >20,000 gallons and <40,000 

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

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

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

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

Marine Vessel Loading NESHAP (subpart Y). 

5.2.3 Oil/Natural Gas Distribution/Transmission NESHAP (subparts HH,HHH) 

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

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

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

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

plant; or (2) an underground natural gas storage operation. Facilities involved in the organic 

liquids distribution (non-gasoline) sector of the petroleum industry include (but are not limited 

to) gathering stations, trunk-line stations, and station storage vessel farms. 

The EPA is to defining the Organic Liquids Distribution (Non-Gasoline) source category 

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

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

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

covered by Subparts HH and HHH. 

5.2.4 Gasoline Distribution NESHAP (subpart R) 

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

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

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

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

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

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

5.2.5 Benzene Emissions from Storage Vessels NESHAP (40 CFR 61 subpart Y) 

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

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

5-10 

5S 
P.40 

DRAFT 3/19/98 

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

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

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

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

benzene emissions by at least 95 percent. 

5.2.6 Marine Vessel Loading NESHAP (40 CFR 63 subpart Y) 

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

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

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

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

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

5.2.7 Benzene Waste Operations NESHAP (subpart FF) 

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

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

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

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

a control device with emission reduction at 95 percent. 

5.2.8 Benzene Transfer Operations NESHAP (subpart BB) 

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

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

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

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

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

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

5.2.9 Oil-Water Separator NESHAP (subpart VV) 

The Oil-Water Separator NESHAP regulates the air emissions from an oil-water separator 

or organic water separator for which another subpart of 40 CFR parts 60,61, or 63 references the 

use of this subpart for such air emission control. The provisions apply to separators that have 

fixed roofs, floating roofs, or separators vented to a control device to reduce the emissions by 95 

percent by weight. 

5-11 

3^ 
P.41 

DRAFT 3/19/98 

5.2.10 Storage Vessel NESHAP (subpart WW) 

The Storage Vessel NESHAP regulates air emissions from storage vessels for which 

another subpart of 40 CFR parts 60,61, or 63 references the use of this subpart for such air 

emission control. The provisions apply to storage vessels using internal or external floating 

roofs, or closed vents systems and a flare or other control device. The provisions also apply to 

pressurized storage vessels. 

5.2.11 Miscellaneous Organic NESHAP (MON) 

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

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

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

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

The rule will affect facilities that use batch organic processes. 

The MON will cover source categories including: chlorinated paraffins production, 

carbonyl sulfide production, explosives production, hydrazine production, photographic 

chemicals production, and rubber chemicals production. It will also cover process vents for 

batch reactors used in producing organic chemicals listed in Table 1 of 40 CFR Part 63 Subpart F 

(Hazardous Organic NESHAP), and HAP emissions from synthetic organic manufacturing 

industry (SOCMI) processes using HAP only as a solvent. Furthermore, the MON will cover the 

production of pesticide intermediates not covered by the Agricultural Chemicals NESHAP, and 

production of by-products, co-products and intermediates not considered primary products under 

the NESHAP for Group I and Group IV polymers and resins. In addition, the MON will cover 

those product processes identified by the EPA based upon information gathered which includes 

alcohols, oil additives, etc., and other product processes not identified by any other MACT 

standard. 

5.3 State/Local Regulations 

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

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

Attachment 2-Summary of State/Local Regulations. 

5-12 

4D 
P.42 

DRAFT 3/19/98 

6.0% SUMMARY OF ISSUES AND NEXT STEPS 

6.1 Issues in the NESHAP Development 

The EPA project team has identified several issues that need to be addressed during the 

standards development process. The most significant issues center around the definition of the 

OLD industry, and the specific facilities, operations, and liquids that need to be covered by the 

standards. Some of the key issues are discussed below (see also Attachment 1, pages 29 and 30). 

The remainder of this section briefly addresses the next steps in the regulatory process. 

Industry definition. The current definition of this source category includes stand-alone or 

separate distribution operations (i.e., not collocated with a chemical manufacturer or a petroleum 

refinery), which may consist either of a bulk liquid terminal or a pipeline facility. In contrast to 

terminals, pipeline facilities exist along a pipeline, receiving product and returning it to the same 

pipeline. 

The issue concerns whether there are collocated distribution operations that should be 

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

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

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

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

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

already regulated or planned for regulation under these other standards. Conversely, we wish to 

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

similar industries. Examples are distribution, storage, and handling operations at refineries and 

chemical plants. 

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

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

to investigate how to define out of the rule as many area sources as possible to lessen the need 

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

determination will have to be made, since §112(c)(3) of the Act requires that area sources be 

regulated if they present "a threat of adverse effects to human health or the environment." 

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

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

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

6-1 

4-1 
P.43 

DRAFT 3/19/98 

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

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

assessments. The project team expects the industry survey and continued contacts with the Work 

Team to be useful in providing this information. 

6.2 Next Steps 

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

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

and to address other regulatory and technical issues. 

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

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

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

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

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

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

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

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

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

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

6-2 

4-2-
P.44 

DRAFT 3/19/98 

7.0 REFERENCES 

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

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

North Carolina. 

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

3. Kennedy, John L. 1993. Oil and Gas Pipeline Fundamentals. 2nd Edition. PennWell 

Publishing Company, Tulsa, Oklahoma. Pages 28-33,37-40. 

4. Office ofManagement and Budget. 1987. Standard Industrial Classification Manual. 

National Technical Information Service, Springfield, Virginia. 

5. 1997 NACD Directory, National Association of Chemical Distributors. Arlington, 

Virginia. 

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

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

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

Production Facilities. 

7-1 

4~3 
P.45 

Attachment 1 

PRESUMPTIVE MACT FOR 

ORGANIC LIQUIDS DISTRIBUTION 

(NON-GASOLINE) FACILITIES 

REVISED EPA PRESENTATION 

FROM FIRST ROUNDTABLE MEETING 

Waste and Chemical Processes Group 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 

& if\ ft 1 

4& 

^° ;*• 
P.46 

OVERVIEW 

Standards Development Process 

Presumptive MACT 

• MACT 

• Project Schedule 

Affected Sources 

• Definition of Source Category 

• Industry Profile 

• Model Plants/Facilities 

Emissions and Controls 

• HAP Emissions 

• Emission Controls 

Current Control Levels (MACT Floors) 

Issues/Questions 

2 

4 ^ 
P.47 

STANDARDS DEVELOPMENT 

PROCESS 

3 

4^ 
P.48 

PRESUMPTIVE MACT IS... 

[MACT = maximum achievable control technology] 

An estimate of what MACT would be, based on a 

review of currently available information 

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

Not a regulation - offered only for guidance and 

information 

A starting point for the MACT standard 

development process 

4 

A© 
P.49 

STATUTORY REQUIREMENTS 

Promulgation of national emission standards 

for hazardous air pollutants (NESHAP) for 

listed source categories is required under 

§112(d) of the Clean Air Act 

Organic Liquids Distribution (Non-Gasoline) is 

a listed major source category under §112(c) 

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

Promulgation of standards is required by 

November 2000 

5 
P.50 

STATUTORY REQUIREMENTS 

(2) 

"Major Source" means any stationary source or 

group of stationary sources located within a 

contiguous area and under common control that 

emits or has the potential to emit, considering 

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

hazardous air pollutant (HAP) or 25 tons per year 

of any combination of HAP 

"Area Source" means any stationary HAP source 

that is not a major source 

"New Source" means a stationary source, the 

construction or reconstruction of which is 

commenced after the Administrator first proposes 

regulations under §112 establishing an emission 

standard applicable to such source 

"Existing Source" means any stationary source 

other than a new source 

go 
P.51 I 1 

STATUTORY REQUIREMENTS 

(3) 

Minimum level of standards ("MACT floor") 

• For existing sources, the standard shall be at 

least as stringent as the average emission 

limitation achieved by the best performing 12 

percent of existing sources, or, in the case of 

categories with less than 30 sources, the 

average emission limitation achieved by the 

best performing 5 sources 

• For new sources, the standard shall be at least 

as stringent as the emission control achieved 

in practice by the best controlled similar 

source 

^ \ 
P.52 

CURRENT PROJECT SCHEDULE 

Event Pate 

Kickoff Meetings 

Plant Visits 

September 24-25,1997 

Dec. 1997 - Apr. 1998 

Initial Roundtable 

(Work Team) January 21,1998 

Second Roundtable 

(discuss draft P-MACT) March 24,1998 

Third Roundtable 

(review final P-MACT, 

if needed) 

Rule Proposal 

Rule Promulgation 

May 20,1998 

Issue P-MACT Report June 1998 

Continue on Standards 

Development Process July 1998 

September 1999 

November 2000 

8 

a 2-
P.53 

AFFECTED SOURCES 

53 
P.54 

HOW IS THE SOURCE CATEGORY 

DEFINED? 

Initial Source Category Description: 

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

distribution points from which organic liquids may be obtained 

for further use and processing. 

From the oil and gas production rule proposal, includes 

petroleum facilities that handle and distribute hydrocarbon 

liquids after the point of custody transfer. 

Facility Types Include: 

• Stand-alone or separate distribution terminals 

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

refineries or chemical plants) 

• Compounding/blending/packaging plants 

- separate facilities [not covered under 

Miscellaneous Organic NESHAP (MON)] 

- collocated with stand-alone or collocated distribution 

activities 

• Pipeline facilities (non-gasoline HAP liquids) 

10 

5^ 
P.55 

Organic Liquids Distribution 

Facilities Industry 

CHEMICALS 

Chemical 

Manufacturing 

(SOCMI) 

Consumer 

(Retail) 

Packaging/Distribution 

Facility 

PETROLEUM 

Domestic 

Oil/Gas 

Production 

Petrochemical 

Manufacturing 

Foreign 

Crude Oil 

Petroleum 

Refining 

i 

Facilities using 

chemicals as 

feedstocks 

Consumer 

(Retail) 

I 

Consumer 

(Retail) 

Packaging/ 

Distribution 

Facility 

Packaging/ 

Distribution 

Facility 

Intermediate Storage Facility 

11 

55 
P.56 

HOW IS THE SOURCE CATEGORY DEFINED? 

(2) 

Which processes and equipment are covered? 

• All HAP emission sources at distribution facilities 

• Possible sources: 

- Storage tanks 

- Liquid transfer 

- truck 

- railcar 

- pipeline 

- Equipment leaks 

- Wastewater collection and treatment (air emission 

aspects) 

Which liquids? 

Synthetic organic HAP chemicals 

Petrochemicals 

Crude oil or other unrefined petroleum liquids 

Refined petroleum (non-gasoline) 

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

wastewater) 

12 
INDUSTRY PROFILE-BASED ON SIC CODES 

J. 

Major Group 

t- , >;4iXx, X - \ 

Industry 

Group 

Number 

x 

4610 

' 

4780 

SIC 

Code* 

V- - -" 

• * -• **S 

• f *•. . 

4612 

4613 

4619 

* * ' " " •*_ 

4789 

NAICS 

Code 

"""•X H 's 

48611 

48691 

48699 

' J** * 

488999 

Facility Type* 

PIPELINES 

\' -'' $}j&\n&>lfaf^tl&Utfr\'Q$&', ; / 

Pipelines, Except Natural Gas 

Crude Petroleum Pipelines 

Refined Petroleum Pipelines 

Pipelines, Not Elsewhere Classified 

'';-; \<„ ^)ransport8^o»$eryic«« '/' •/ 

Miscellaneous Services Incidental to 

Transportation 

Transp. Services, Not Elsewhere Classified 

Total No. of 

Establishments'* 

v % •. -f' ' ******* '- ' * * 

838 

59 

*\ * ** * * 

** * * 

2,349 

Size Distribution 

by No. of Employees'* 

<50 >50 >100 

V 

*•.<, •••_ *• 

93% 

100% 

k

"\:.^ * 

92% 

* * 

4% 

jf * * 

* * * 

5% 

\ . 

3% 

s ^ < 

3% 

13 
INDUSTRY PROFILE-BASED ON SIC CODES (CONTINUED) 

Major Group 

-, 

^ ' '•-,' , /•„• 

- , » J. » ' ..' . „ 

' _ _ " »' f 

• 

Industry 

Group 

Number 

•* *** *", 

', ',** s ** 

4220 

4490 

5V . sv 

5160 

5170 

SIC 

Code* 

\*f * * * *. ** *" 

/ * * ^''•'••M* 

:** ** * > **'Sy* 

4226 

4491 

* . * *. * 

*-•**- y, s /' 

... '' .* y 

5169 

5171 

5172 

NAICS 

Code 

s' 

'//f, ', "f, 

49319 

*' '*' 

*** ** *** ,

y 

48831/2 

42269 

454311 

42272 

Facility Type* 

STAND-ALONE TERMINALS 

•* * ** *****, ** • ' ' ****', * s^r*Ss*,y y +ft *y / ' // ' 

Public Warehousing and Storage 

Special Warehousing and Storage, Not 

Elsewhere Classified 

" '< -; ' > 'Waf6t^_*aW*p&Mtioti'';', ?' ' . ' 

* * * *.* * ' * * *"* r'' * 

Services Incidental to Water Transportation 

Marine Cargo Handling 

* , , * * * * * f 

Chemicals and Allied Products 

Chemicals and Allied Products, Not 

Elsewhere Classified 

Petroleum and Petroleum Products 

Petroleum Bulk Stations and Terminals 

Petroleum & Petroleum Products 

Wholesalers, except Bulk Stations and 

Terminals 

Total No. of 

Establishments" 

'''•-, "'{' if* 

*f , fw ****** * * + **m**m*/ 

1,479 

6,742 

854 

14,436 

10,695 

14,636 

10,562 

3,864 

Size Distribution 

by No. of Employees'* 

<50 >50 >100 

. * /r * 

"**** 

*• , i , ***> 

* ****** 

• * * * 

93% 

,„_„,•„•'••- • 

95% 

78% 

97% 

97% 

97% 

97% 

97% 

4% 

_ \ ' ', 

2% 

10% 

2% 

2% 

2% 

3% 

2% 

''' ' 

3% 

S * *•. : 

3% 

12% 

* **** * * 

1% 

1% 

1% 

<1% 

1% 

14 
J] 

-0 

Major Group 

i 

\ 

-* * Si- . . 

"'- -'-V. < 

INDUSTRY PROFILE-BASED ON SIC CODES (CONTINUED) 

Industry 

Group 

Number 

SIC 

Code* 

NAICS 

Code 

Facility Type* Total No. of 

Establishments'* 

COMPOUNDING AND PACKAGING FACILITIES 

^ 

5160 

5170 

' - i 

4780 

"' * 

5169 

5171 

5172 

t " ''<s' 

f ' * f 

** ** ** * ** 

4783 

v - * " 

42269 

454311 

42272 

488991 

5 ; " •' ; " ' — '""- , • 

Y Wb<>le_^6TiFad^N<_todttra1jleG6__i» 

Chemicals and Allied Products 

Chemicals and Allied Products, Not 

Elsewhere Classified 

Petroleum and Petroleum Products 

Petroleum Bulk Stations and Terminals 

Petroleum & Petroleum Products 

Wholesalers, except Bulk Stations and 

Terminals 

' > ,' s " ' ^ ' i' A / , ' , , , 

Miscellaneous Services Incidental to 

Transportation 

Packing and Crating 

v . '• . •. t . / ,. 

14,436 

10,695 

14,636 

10,562 

3,864 

•:'•.' . i ' f t 

2,349 

Size Distribution 

by No. of Employees'* 

<50 >50 >100 

97% 

97% 

97% 

97% 

97% 

' * 

* ' V 

92% 

s •• 

2% 

2% 

2% 

3% 

2% 

* - * •.* 

5% 

1% 

1% 

1% 

<1% 

1% 

* * - • 

2% 

15 
INDUSTRY PROFILE-BASED ON SIC CODES (CONCLUDED) 

Major 

Group 

Industry 

Group 

Number 

SIC 

Code8 

NAICS 

Code 

Facility Type" Total No. of 

Establishments1* 

Size Distribution 

by No. of 

Employeesb 

<50 >50 >100 

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

' 51' *; ' 

5160 

* * * * . _/•.. 

5169 

* "s ' *s s 

42269 

WMeSate Tri'd^'di_dnrat)ie'Godd$' 

* r * * 

Chemicals and Allied Products 

Chemicals and Allied Products, Not 

Elsewhere Classified 

14,436 

10,695 

* "*% "•****• 

97% 

97% 

\ -'-,'s- - . 

2% 

2% 

. .. fs' 

-

1% 

1% 

0 

0 

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

bCounfy Business Patterns, 1995 (Bureau of the Census) 

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

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

point in time. 

16 
P.61 

INDUSTRY PROFILE 

(2) 

Model Industry 

Stand-Alone Organic Liquid Facilities1 

Primary SIC codes: 4226,5169,5171 

• Primary States by Total Storage Capacity: 

State 

Texas 

Louisiana 

New Jersey 

California 

Illinois 

Capacity (barrels) 

55,582,440 

29,383,594 

29,252,303 

24,329,888 

9,881,577 

Range in number of storage tanks: 

1 to 420 + 

Percent of Total 

21% 

11% 

11% 

9% 

4% 

Range in total storage capacity of individual facilities: 

2,700 to 12,500,000 barrels 

Modes of transportation 

- marine vessel (tanker ship, barge) 

- tank truck 

- railcar 

- pipeline 

'Based on membership in the Independent Liquid Terminals 

Association (ILTA). 

17 

6M 
INDUSTRY PROFILE 

(3) 

Collocated Organic Liquid Facilities (e.g., associated 

with petroleum refineries or chemical plants) 

• SIC codes probably not similar to stand-alone facilities 

• Model plant data still being collected 

Pipeline Facilities 

Primary SIC codes: 4612,4613 

• Model plant data still being collected 

Blending/Compounding/Packaging Facilities 

Primary SIC codes: 5169,5171,5172 

• Probably exist as part of liquid terminal operations 

• Stand-alone facilities may not be major sources 

• Some major source facilities and collocated sites may be 

covered under the Miscellaneous Organic NESHAP 

(MON) 

• Model plant data still being collected 

18 
P.63 

EMISSIONS AND CONTROLS 

19 
P.64 

EMISSION FACTORS 

Emissions Calculations 

- HAP content 

- Models/methods for estimating emissions 

- Parameters: volume, loading method, 

vapor pressure, etc.) 

HAP Content 

- pure compound (100% HAP) 

- mixtures (partial HAP content) 

- petroleum liquids 

- diluted pure HAP chemicals 

- properties of several HAP liquids are shown 

in Tables 1 and 2 

20 
TABLE 1. ORGANIC LIQUIDS WITH HAP CONTENT 

Stored Liquid 

" ;-

Asphalt 

Aviation Gasoline 

Alkylate 

Crude Oil 

Diesel/Distillate 

Gasoline 

Heavy Gas Oil 

Jet Fuel (JP-4) 

Jet Kerosene 

Naphtha 

Reformates 

Residual Fuel Oil 

Recovered Slop 

Oil 

True Vapor 

Pressure 

0.002 

3.50 

4.92 

3.42 

0.07 

6.47 

0.08 

1.22 

0.07 

3.19 

3.48 

0.07 

1.46 

Temp. 

°F 

Annual Volume HAP Concentration in 

Vapors (g/m3) 

Range Average 

'.••:•: ••; . ^ . - , , 

T ,.. MixtutesCOBtaffttinjg;ISAl"'6 ^.s ;- '- -

280 

66.8 

76 

86 

72 

69 

104 

68 

74 

72 

72 

144 

145 

? 

7 

7 

2.64xl0u gal/yr 

7.13xl010 gal/yr 

1.18xl0u gal/yr 

7 

7 

7.60xl08 gal/yr 

7 

7 

1.65xl010 gaVyr 

7 

7 

7 

9 

• 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

31.72 

15.51 

115.77 

52.09 

11.55 

130.66 

24.75 

73.20 

8.5 

92.50 

91.16 

110 

52.75 

Number of Data 

Points 

* * _ • '*,;* , ' 

. * 

•. * . % ** y v s. % 

14 

16 

28 

74 

74 

137 

38 

24 

45 

70 

53 

37 

40 

See end of table for footnotes. 

21 
TABLE 1. ORGANIC LIQUIDS WITH HAP CONTENT (Continued) 

0 

Stored Liquid True Vapor 

Pressure 

Temp. 

°F 

Annual Volume HAP Concentration in 

Vapors (g/m3) 

Range Average 

Number of Data 

Points 

•

JV„ :-.>/.- :ftl^^t:^Z>* w**?^ -'./i^r^f^ 

Acrylonitrile 

Aniline 

Benzene 

Bisphenol-A 

Bis (2-ethylhexyl) 

phthalate 

13 Butadiene 

Caprolactam 

Chloroform 

Cumene 

Ethylbenzene 

Ethylene glycol 

Ethylene dichloride 

Ethylene oxide 

Formaldehyde 37% 

Isophorone 

Maleic anhydride 

1.71 

0.02 

1.54 

n/a 

7 

36.05 

0.97 

0.19 

0.27 

0.19 

0.00 

1.25 

14.7 

7 

0.07 

0.77 

70 

95 

70 

n/a 

7 

70 

356 

50 

70 

79 

70 

70 

51 

7 

70 

53 

3,300x10s lb/yr 

1,305x10* lb/yr 

1,740x10s lb/yr 

1,600x10* lb/yr 

257x10* lb/yr 

3,700x10* lb/yr 

1,800x10* lb/yr 

935x10* lb/yr 

5,240x10* lb/yr 

13,040x10* lb/yr 

5,600x10* lb/yr 

19,600x10* lb/yr 

6,500x10* lb/yr 

7,900x10* lb/yr 

7 

490x10* lb/yr 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

7 

? 

7 

7 

7 

• 

7 

7 

7 

7 

7 

7 

7 

7 

9 

• 

7 

7 

n/ad 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

See end of table for footnotes. 

22 
TABLE 1. 

Stored Liquid 

MTBE 

Methanol 

Methylchloroform 

Methylene chloride 

Methyl methacrylate 

Methyl ethyl ketone 

Methyl isobutyl ketone 

Perchloroethylene 

Phenol 

Phthalic anhydride 

Styrene 

Toluene 

Vinyl acetate 

Vinyl chloride 

o-xylene 

p-xylene 

ORGANIC LIQUIDS WITH HAP CONTENT (Continued) 

True Vapor 

Pressure 

4.74 

1.93 

1.9 

7.39 

0.62 

1.46 

0.04 

0.36 

0.01 

0.19 

0.19 

0.45 

1.87 

14.7 

0.10 

0.14 

Temp. 

°F 

70 

70 

68 

70 

75 

70 

70 

77 

70 

50 

93 

70 

70 

6.8 

70 

70 

Annual Volume 

8,140x10* lb/yr 

11,100x10* lb/yr 

335x10* lb/yr 

375x10* lb/yr 

1,372x106 lb/yr 

584x10* lb/yr 

9 

• 

4,100x10* lb/yr 

4,100x10* lb/yr 

820x10* lb/yr 

7,622x10* lb/yr 

698x10* lb/yr 

2,112x10* lb/yr 

9,463x10* lb/yr 

675x10* lb/yr 

4,779x10* lb/yr 

HAP Concentration in 

Vapors (g/m1) 

Range 

7 

7 

7 

7 

7 

7 

7 

? 

7 

? 

9 

9 

7 

7 

7 

7 

Average 

7 

7 

7 

7 

7 

7 

? 

7 

7 

7 

9 

• 

? 

7 

7 

7 

7 

Number of Data 

Points 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

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

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

chloride and methylchloroform annual volumes are based upon 1994 data. 

'National Petroleum News, Mid-June 1995. 

d

n/a stands for not applicable. 

23 
P.68 

EMISSION FACTORS 

(2) 

• Models and Methods 

- Storage tanks 

- AP-42, Section 7.1 (TANKS3 software) 

- Liquid transfer 

- AP-42, Section 5.2 

- Equipment leaks 

- emission factors available for chemical production 

facilities 

- factors for petroleum refineries 

- factors for gasoline marketing operations 

- Wastewater air emissions 

- collection and treatment system model (Water 8) 

• Facility Parameters (established as part of the model 

industry) 

24 

G>9> 
P.69 

EMISSION CONTROLS 

Storage Vessels 

• Route vapors to control device 

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

- carbon adsorption <95% controt> 

-flare <98%control> 

- condenser <95% control> 

- scrubber <95% controt> 

• Floating roof (internal or external) 

- rim seal types and fitting controls 

• Pressurized or refrigerated tanks 

Liquid Transfer/Loading 

• Route vapors to control device 

- devices similar to storage vessel controls 

• Vapor-tight vessels (trucks, railcars) 

• Vapor balancing 

Equipment Leaks 

• Modify or replace existing equipment 

• Leak detection and repair (LDAR) program 

(instrument or visual program) 

Wastewater 

• Vent to a control device 

• Floating roof or vapor-tight cover 

• Closed piping 

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

25 
P.70 

CURRENT CONTROL LEVELS 

Information on potential levels of control is being 

obtained from: 

• Federal NESHAP (40 CFR Part 63) 

Refinery NESHAP (subpart CC) 

Gasoline Distribution NESHAP (subpart R) 

Oil/Natural Gas Production/Transmission 

(subparts HH, HHH) [proposed] 

Marine Vessel Loading NESHAP (subpart Y) 

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

Miscellaneous Organic NESHAP (MON) [pre-proposal] 

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

Oil-Water Separators (subpart W ) 

Benzene Storage Vessels (40 CFR 61, subpart Y) 

Benzene Waste Operations NESHAP (40 CFR 61, subpart 

FF) 

Off-Site Hazardous Waste NESHAP (subpart DD) 

Benzene Transfer NESHAP (40 CFR 61, subpart BB) 

NSPS Rules (40 CFR Part 60) 

• Storage Vessels (subpart Kb, etc.) 

• Bulk Gasoline Terminals (subpart XX) 

26 
P.71 

CURRENT CONTROL LEVELS 

(2) 

Industry Data 

• Plant visits 

- several visits were made in December 1997, 

and more are planned 

• Survey responses 

- detailed survey: 

• sent to a limited number of facilities 

• specific facility types 

• specific types of liquids (cutoffs for vapor 

pressure and HAP content) 

• operations not covered by other MACT rules 

facility size *50% of 10/25 tpy HAP 

criteria 

27 
P.72 

CURRENT CONTROL LEVELS 

(3) 

State/Local Rules (Examples) 

• Storage Vessels - California and Illinois rules 

among the most stringent 

tanks > 19,800 gallons, > 1.5 psia, or 

tanks > 39,630 gallons, > 0.5 psia: 

• floating roof or vapor control at 95% by weight 

any capacity, > 11 psia: 

• pressure tank with no detectable organic emissions 

• pressure tank with no detectable organic emissions 

or vapor control at 95% by weight 

• Transfer Operations -Texas, Alaska, and 

California rules among the most stringent 

• Organic liquids: emissions limit = 0.17 lb/1,000 

gallons (21mg/liter) (California, Bay Area) 

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

• > 1.5 psia: emission limit = 0.08 lb/1,000 gallons 

(lOmg/liter) (Alaska, California, South Coast) 

Wastewater Operations - Connecticut, Virginia, 

and Hawaii rules among the most stringent 

• > 200 gallons (VOC>1.5 psia)/day: vapor control 

at 95% (Connecticut, Virginia) 

• > 200 gallons (VOC>0.5 psia)/day: floating roof 

tank (Hawaii) 

28 
P.73 

ISSUES/QUESTIONS 

What facilities/emission sources should be 

included in the source category? 

Are there significant emission sources at 

compounding and packaging operations? 

Impact of the other Federal air rules 

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

collocated distribution emission sources? 

• Which emission sources in categories that are 

regulated (or will be regulated under other rules) 

should be considered for regulation under the OLD 

standards? 

Impact on or from other media standards 

Water (Benzene Waste NSPS?) 

• Solid waste 

• Other standards? 

• Investigation of these rules is continuing 

29 
ISSUES/QUESTIONS 

(2) 

Major/Area Sources 

• Some owners or operators are small businesses 

- investigating these numbers 

• Must regulate area sources if they present 

"a threat of adverse effects to human health 

or the environment" (§ 112(c)(3)) 

• Looking into simple mechanisms to distinguish 

them from major sources (throughput, equipment 

size, etc.) 

• How does the potential to emit (PTE) concept 

apply to these operations? 

Need additional information to define industry 

and complete industry profile 

• Industry survey 

• Completion of data collection for MACT floor 

determination 

• HAP content of mixtures 

30 
P.75 

Attachment 2 

MEMORANDUM 

TO: Steve Shedd 

U. S. Environmental Protection Agency, ESD/WCPG 

FROM: Jay Helms 

Pacific Environmental Services, Inc. (PES) 

DATE: February 9, 1998 

P:\N812 

SUBJECT: Organic Liquids Distribution NESHAP: State Rules Summary 

The following is a summary of the State and local regulations reviewed by PES. The 

summary is organized in terms of stringency of regulation and grouped into percentages. 

Storage Vessels 

Low vapor pressure organic liquids storage (51 rules): 

Top 12% -> 19,800 gallons and > 1.5 psia; or 

> 39,630 gallons and > 0.5 psia; 

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

Top 25% - > 20,000 gallons and < 40,000 gallons and >4 psia; or 

> 40,000 gallons and > 0.75 psia; 

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

Top 35% ->40,000 gallons; > 1.5 psia; Pressure tank, floating roof, or vapor control-95% 

Top 50% ->40,000 gallons; > 1.5 psia; Pressure tank, floating roof, or vapor control-90% 

Top 80% - Miscellaneous requirements ranging in tank size and vapor pressure cutoffs; 

Requirements range from vapor control at 80% to floating roofs. 

High vapor pressure (> 11.0 psia) organic liquids storage (15 rules): 

Top 12% - Pressure Tank with no detectable organic emissions 

Top 50% - Pressure tank with no detectable organic emissions or vapor control-90% 

Top 75% - Vapor control-85% 

**AU of the regulations reviewed considered any organic liquid > 11.1 psia to be a "high 

vapor pressure" or "extremely volatile" liquid. 

External floating roof tanks (10 rules): 

Top 12% - > 20,000 gallons; > 4 psia; Primary and secondary seals required. 

Top 50% - > 40,000 gallons; > 4 psia; Primary and secondary seals required. 

-qs 
P.76 

Attachment 2 

Memo to Steve Shedd 

February 9, 1998 

Page 2 

Small Tanks (10 rules): 

Top 12% - > 250 gallons; Organic liquids; If the tank is top loaded, it must be equipped with 

a permanent submerged fill pipe. 

Top 50% - > 580 gallons; > 1.5 psia; If the tank is top loaded, it must be equipped with a 

permanent submerged fill pipe. 

Large tanks for produced crude oil or condensate prior to lease custody transfer (18 

rules): 

Top 12% - < 422,400 gallons; Exemption from regulation 

Top 50% - < 416,000 gallons; Exemption from regulation 

Welded tanks (8): 

Top 100% - All tanks containing petroleum liquids < 4 psia; If the tank is of welded 

construction, no secondary seal is required if the primary seal is a mechanical-shoe, liquid 

mounted, metallic-type shoe seal, or equivalent. 

Transfer Operations (25 rules): 

Top 12% - Organic liquids > 1.5 psia; 10 mg/L emission limit 

Top 15% - Organic liquids; 21 mg/L emission limit 

Top 35% - Organic liquids > 1.5 psia; Vapor control-95% 

Top 50% - Organic liquids > 1.5 psia; Vapor tight vapor balance system 

Top 75% - Organic liquids; Submerged loading required 

Wastewater (7): 

Top 12% - Any tank which contains wastewater must be equipped for vapor control-95% 

Top 50% - Wastewater storage tanks with >200 gallons of wastewater/day; Floating roof 

required 

Top 80% - Liquid balancing (dilution) to < 0.5 psia, or reduce VOC concentration by 90% 

^Lf i 
Attachment 2 

P.77 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

State 

California, 

South Coast 

California, 

Bay Area 

California, 

Ventura 

County 

Illinois 

(Chicago) 

California, 

San Diego 

California, 

Ventura 

County 

California, 

Ventura 

County 

California, 

Bay Area 

California, 

San Joaquin 

Colorado 

Indiana 

New York 

Virginia 

Regulation 

463 

8-5-300 

71.2 

218.119-120, 

Subpart B 

61 

71.2 

71.2 

8-5-300 

4623 

5CCR 1001-9 

Reg #7 

326IAC 8-9 

Section 229 

9 VAC 5-40-

1390 

Applicability 

Storage vessels; > 

19,815 gallons; > 

39,630 gallons 

Storage vessels; > 

39,626 gallons 

Q50m3) 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; > 

40,000 gallons; 

Plants > 5,000,000 

gal/yr 

Storage vessels; > 

10,000 gallons, < 

20,000 gallons 

Storage vessels; > 

20,000 gallons, < 

40,000 gallons 

Storage vessels; 

>19,813 gallons 

(75m3),< 39,626 

gallons (150m32 

Storage vessels; > 

19,800 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40.000 gallons 

Process/Products 

Organic Liquids; > 1.5 psia; 

> 0.5 psia 

Organic liquids; > 0.5 psia 

Organic liquids; >0.5 psia 

VOL; >0.75 psia VPL: 

>1.5 psia 

Organic liquids (VOC); 

RVP> 3.0 psia 

Organic liquids; >1.5 psia 

Organic liquids; >1.5 psia 

Organic liquids; > 1.5 psia 

Organic Liquids (including 

crude oil & petroleum 

distillates); > 1.5 psia 

Petroleum liquids; >0.65 psia 

Organic liquids; >0.75 psia, 

<ll.ljjsia 

Organic liquids; >1.0 psia 

Petroleum liquids; >1.5 psia 

Standards/Reauirements 

External floating roof, internal 

floating-type cover, or vapor 

recovery system (95% by weight) 

Vapor loss control device-95% by 

weight efficiency 

External or internal floating roof 

or vapor recovery system (95% by 

weight) 

VOL: IFR, EFR, or approved 

control device (95% VOC 

reduction or greater-90% if 

installed before 1993). VPL: 

Floating roof or control system at 

85% 

Floating roof or vapor control 

system-95% 

Permanent submerged fill pipe; 

pressure relief valve (90%); 

external or internal floating roof oi 

vapor recovery system (95% by 

weight^ 

Permanent submerged fill pipe; 

external or internal floating roof or 

vapor recovery system (95% by 

weight) 

Vapor loss control device-95% by 

weight efficiency 

Floating roof tank, or vapor 

control system-95% 

Floating roof, vapor recovery 

system, or equivalent 

Various fixed roof requirements 

Floating roof and vapor control 

system 

40 CFR 60, Subpart Kb 

n 
Attachment 2' 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Cont.) 

State 

S. Dakota 

Kentucky 

Arkansas 

Maine 

Nebraska 

Oregon 

Connecticut 

Kentucky 

Connecticut 

Rhode Island 

Mass. 

Regulation 

74:36:07:14 

401 KAR 59:485 

19.10.5.1 

Chapter 111 

340-22-160 

Section 22a-174-

20 

401 KAR 59:050 

Section 22a-174-

20 

11.2 

310 CMR 7.24 

Applicability 

Storage vessels 

Storage vessels; 

>40,000jallons 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>39,000 gallons 

Storage vessels 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Process/Products 

Organic liquids 

Organic liquids 

Petroleum liquids; >1.52 psia 

Petroleum liquids; >1.52 psia 

Organic liquids 

Organic liquids; >1.52 psia 

Organic liquids; >1.5 psia 

Petroleum liquids; >1.5 psia, 

<11.1 psia 

Organic liquids; >1.5 psia, < 

11.0 psia 

Petroleum liquids; >1.52 psia 

Organic liquids; >1.5 psia 

Standards/Reauirements 

40 CFR 60, Subpart Kb 

40 CFR 60, Subpart Kb 

40 CFR 60.110-NSPS for 

Storage vessels for Petroleum 

liquids; or floating roof or cover 

Vessels w/ fixed roof; 40 CFR, 

part 60LSubparts I^Ka, & Kb 

Subparts K, Ka 

Floating roof; subparts K, Ka 

Vapor recovery system (95% by 

weight); permanent submerged fill 

pipe 

External floating roof (w/specific 

seals); fixed roof internal floating 

roof; vapor recovery system (95% 

by weight VOC); or an equivalent 

system 

Fixed roof & floating roof, or 

vapor recovery system (95% by 

weight); permanent submerged fill 

pipe 

Vessels w/ fixed roof; VOC 

reduced by 95% using a vapor 

recovery system 

Submerged fill pipe required; and 

an external floating roof or both a 

pressure tank system & a vapor 

recovery system (95% emission 

reduction) 

^e 
Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Cont.) 

State 

Kansas 

District of 

Columbia 

Michigan 

Texas 

Florida 

Washington 

North Carolina 

Wisconsin 

Kentucky 

Maryland 

Vermont 

Nevada 

Regulation 

28-19-65 

701 

R 336.1604 

Section 115.112: 

Subchapter A 

62-296.508 

WAC 173-490-

040 

.0925 

NR 419.05 

401 KAR 59:050 

26-11-13.03 

5-253.1 

445B.395 

Applicability 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000j»allons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>42,000 gallons 

Storage vessels; 

>40,000jallons 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40.000 gallons 

Process/Products 

Organic liquids; >1.5 psia 

Petroleum liquids; >1.5 psia 

Organic liquids; >1.52 psia, 

< 11 psia 

Organic liquids; > 1.5 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.52 psia 

Organic liquids; >1.52 psia 

Petroleum liquids; >1.5 psia, 

<11.1 psia 

Organic liquids; >1.5 psia, 

<11.1 psia 

Petroleum liquids; >1.52 psia 

Organic liquids; >1.5 psia 

Standards/Requirements 

Floating roof (< 11.1 psia) or 

vapor control system-90%, or 

equivalent; Pressure tank sealed or 

vented to a vapor control system 

(> 11.1 psia) 

Pressure tank or vapor loss control 

devices 

Pressure tank, floating cover or 

roof, vapor recovery system (90% 

by weight) 

Floating roof or vapor recovery 

system-90% 

Floating roof 

Floating roof or equivalent 

Floating roof 

Floating roof, vapor condensation 

system, vapor holding tanks, or 

equivalent 

Floating roof or vapor recovery 

system, or their equivalents 

Floating roof, vapor control 

system, pressure tank, or 

equivalent 

Vessels w/ fixed roof must be 

equipped with an internal floating 

roof 

Floating roof (<11 psia) or 

equivalent: Submerged fill pipe 

-=*-< _ 
P.80 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Cont.) 

State 

South Carolina 

New Mexico 

West Virginia 

Wisconsin 

Hawaii 

Arizona 

Missouri 

Utah 

Indiana 

Illinois 

New Jersey 

Oklahoma 

North Carolina 

Penns. 

Regulation 

62.5, part 0 

NMAC 2.37.205 

45-21-27 

NR 420.03 

11-60.1-39 

R18-2-710 

10 CSR 10-2.260 

R307-14-2 

326IAC 8-4-3 

218.121, Subpart 

B 

7:27-16.2 

252:100-37-15 

.0518 

129.56-57 

Applicability 

Storage vessels; 

>40,000 gallons 

Storage vessels; > 

250,000 (65,000-

new)gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000jallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000jallons 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>50,000 gallons 

Storage vessels; 

>40.000 gallons 

Process/Products 

Petroleum liquids; >1.5 psia 

Organic liquids; > 3.0 (1.5-

new) psia, <11.0 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.52 

gsia, < 11.1 psia 

VOCs; > 1.5 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.5 psia 

Petroleum liquids; >1.52 psia 

Petroleum liquids; >1.52 

psia; 

Petroleum liquids; >1.5 psia, 

<12.5 psia 

Organic liquids 

Organic liquids 

Organic liquids; >1.5 psia 

VOCs: > 1.5 psia 

Standards/Requirements 1 

Floating roof or equivalent 

Floating roof; vapor recovery 

system 

External floating roof tanks have 

seal reaquirements; fixed roof 

tanks must have internal floating 

roof or equivalent 

Floating roof, vapor recovery 

system, or equivalent 

Floating roof or a vapor recovery 

& disposal system 

Floating roof or equivalent (if 

liquid>12 gsia} 

Floating roof, vapor recovery 

system, or equivalent 

Floating roof 

Floating roof 

Floating roof 

Miscellaneous; See Table 2A 

Pressure tank, floating roof, vapor 

recovery system, or equivalent 

Pressure tank, floating roof, vapor 

recovery system, or equivalent 

Floating roof or vapor recovery 

svstem-80% 

8o 
P.81 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Cont.) 

State 

New 

Hampshire 

Illinois 

Montana 

New Jersey 

Minnesota 

Alaska 

California, 

San Diego 

Colorado 

New Mexico 

California, 

Ventura 

County 

Indiana 

Kentucky 

Regulation 

Env-A 1204.20 

215.121, Subpart 

B 

17.8.324 

7:27-16.4 

7011.1505 

• 

18 AAC 50.085 

61 

5CCR 1001-9 

Reg # 7 

NMAC 2.37.205 

71.2 

326IAC 8-9 

401 KAR 59:050 

Applicability 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>65,000 gallons 

Storage vessels; > 

2,000 gallons 

Storage vessels; > 

2,000 gallons & < 

40,000 gallons 

Storage vessels; 

>378,000 gallons 

Storage vessels 

Storage vessels 

Storage vessels; > 

250,000 gallons 

Storage vessels 

Storage vessels; 

>39,000 gallons 

Storage vessels; 

>40.000 gallons 

Process/Products 

Organic liquids; >1.52 psia; 

fixed roofs 

Organic liquids >2.5 psia 

Petroleum liquids or Crude; 

>2.5 psia 

Organic liquids 

Petroleum liquids; > 1.5 psia, 

< 11.1 psia 

Volatile liquids 

Organic liquids; > 11 psia 

Organic Liquids; > 11 psia 

Organic liquids; >11.0 psia 

Organic liquids; > 11 psia 

Organic liquids > 11.1 psia 

Petroleum liquids; > 11.1 psia 

Standards/Requirements 

Various seal & vent requirements; 

RACT. 

<12.5 psia-floating roof, >12.5 

psia-vapor recovery system 

consisting of vapor disposal 

system (85%) 

Pressure tank, floating roof (< 13 

psia), vapor recovery system, or 

equivalent 

> 1000 Lb VOC/year: vapor 

control (90%), floating roof, or 

vapor balance system 

Permanent submerged fill pipe; 

floating roof, vapor recovery 

system, or equivalent 

Internal floating roof, closed vent 

system & vapor control~95% 

BACT 

Pressure tank 

Pressure vessel 

Pressure tank; vapor recovery 

system, or equivalent (95% by 

weight^ 

Closed vent system (<500 ppm) 

and an approved control device 

(95% VOC reduction or greater) 

Vapor recovery system-95% by 

veight, . 

P. 
P.82 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Cont.) 

State 

Michigan 

Texas 

Wisconsin 

New Jersey 

Illinois 

Minnesota 

Wyoming 

New York 

South Carolina 

Washington 

Michigan 

Illinois 

Illinois 

Oklahoma 

Kentucky 

Regulation 

R 336.1605 

Section 115.112: 

Subchapter A 

NR 420.03 

7:27-16.2 

218.121, Subpart 

B 

7011.1505 

Section 229 

62.5, part P 

WAC 173-490-

201 

R 336.1623 

215.124, Subpart 

B 

215.122 & 

218.122, Subpart 

B 

252:100-39-48 

401 KAR 59:050 

Applicability 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>25,000jgallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

> 1,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; > 

2,000 gallons & < 

40,000 gallons 

Storage vessels; 

>65,000 gallons 

Storage vessels; 

>20,000 gallons 

Storage vessels; 

>39,600jallons 

Storage vessels; 

>40,000 gallons 

Storage vessels; 

>40,000 gallons 

Storage vessels 

Storage vessels; > 

250 gal 

Storage vessels; 

<40,000 gallons 

Storage vessels; 

>580 pallons 

Process/Products 

Organic liquids; >11 psia 

Organic liquids; > 11 psia 

Petroleum liquids; >11.1 psia 

Organic liquids; > 13.0 psia 

Petroleum liquids; >12.5 psia 

Petroleum liquids; >11.1 psia 

Petroleum liquids; RVP>5 

lbs 

Organic liquids; >4.0 psia 

External Floaters 

External Floaters 

Petroleum liquids; >1.0 psia, 

but < 11 _psia 

Petroleum liquids 

Organic material 

Organic liquids 

Petroleum liquids; > 1.5 psia 

Standards/Reauirements 

Pressure tank, vapor recovery 

system-90%, or equivalent 

Submerged fill pipe and vapor 

recovery system-90% 

Vapor recovery system or 

equivalent 

Vapor control system at 90% by 

weight 

Vapor recovery system consisting 

of vapor disposal system (85%) 

Permanent submerged fill pipe; 

vapor recovery system, or 

equivalent 

Pressure tank 

Various seal & vent requirements 

Various seal requirements 

Various seal requirements 

External floating roof tanks: 

various seal requirements 

External floating roof tanks: 

various seal requirements 

Permanent submerged fill pipe 

> 400 gallons—submerged pipe or 

bottom fill; >2000 gallons-vapor 

control sy_stem £90% by weight} 

Permanent submerged fill pipe 

ftZ-
P.83 

Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Cont.) 

State 

North Dakota 

Arizona 

California, 

Bay Area 

New Jersey 

Wisconsin 

Georgia 

Florida 

Illinois 

Kansas 

Indiana 

Washington 

Virginia 

North Carolina 

Illinois 

Regulation 

33-15-07-01 

RI 8-2-905 

8-5-300 

7:27-16.4 

NR 419.05 

VV 

62-296.508 

215.123, Subpart 

B 

28-19-65 

326IAC 8-4-3 

WAC 173-490-

201 

9 VAC 5-40-

1390 

.0925 

215.123, Subpart 

B 

Applicability 

Storage vessels; 

>1,000 gallons 

Storage vessels; 

<40,000jallons 

Storage vessels; 

<39,626 gallons 

(150 m3) 

Storage vessels; > 

2,000jallons 

Storage vessels; > 

1000 gallons 

Storage vessels; 

>4,000 gallons 

Storage vessels; 

<422,400 gallons 

Storage vessels; 

<422,400 gallons 

Storage vessels; 

<422,400 gallons 

Storage vessels; 

<420,000 gallons 

Storage vessels; 

<420,000 gallons 

Storage vessels; 

<420,000 gallons 

Storage vessels; 

<416,000 gallons 

Storage vessels; 

<378,000 gallons 

Process/Products 

Organic liquids 

Petroleum liquids 

Organic liquids; >0.5 psia 

Organic liquids 

Organic liquids; >1.52 psia 

Organic liquids 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Crude & condensate prior to 

lease custody transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced crude oil & 

condensate prior to custody 

transfer 

Produced oil or condensate in 

crude oil gathering 

Standards/Requirements 

Permanent submerged fill pipe 

Submerged filling device 

Permanent submerged fill pipe 

Permanent submerged fill pipe 

Permanent submerged fill pipe 

Permanent submerged fill pipe 

Exempt 

Exempt 

Exempt 

Exempt 

Exempt 

Exempt 

Exempt 

Exempt 

P>Z 
Attachment 2 

STATE REGULATIONS SUMMARIES, STORAGE VESSELS 

(Cont.) 

P.84 

State Regulation Applicability Process/Products Standards/Requirements 

Indiana 326IAC 8-4-3 Storage vessels Petroleum liquids; < 4.0 

psia 

Vessel of welded 

construction, having proper 

closure device 

South 62.5, part P Storage vessels 

Carolina -

Petroleum liquids; >1.5 

psia, <4 psia 

Ifthe tank is a welded tank, 

no other control is necessary 

Washington WAC 173- Storage vessels 

490-201 

Petroleum liquids; >1.5 

psia, <4 psia 

Ifthe tank is a welded tank, 

no other control is necessary 

Maryland 26-11 -13.02 Storage vessels Petroleum liquids; >1.5 

psia, <4 psia 

Ifthe tank is a welded tank, 

no other control is necessary 

8^ 
P.85 

Attachment 2 

STATE REGULATIONS SUMMARIES, TRANSFER OPERATIONS 

(Cont.) 

State 

California, 

South Coast 

California, 

San Joaquin 

Alaska 

California, 

Bay Area 

Texas 

Oklahoma 

New Jersey 

California, 

San Joaquin 

Louisiana 

Oklahoma 

California, 

Ventura 

County 

Connecticut 

Wisconsin 

Regulation 

462 

4624 

18 AAC 50.090 

8-6-300 

Section 115.211-

: Subchapter C 

252:100-39-48 

7:27-16.5 

4624 

33:111:2107 

252:100-37-16 

71.3 

Section 22a-174-

20 

NR 419.05 

Applicability 

TT/railcar transfer 

operations; > 20,000 

gallons/day 

TT/railcars: Class 1 

(>20k gal/day). 

Class2(4k-20k 

ja!/2s_L 

Transfer operations; 

> 15 million 

gallons.year 

Transfer operations 

- Transfer operations 

Transfer operations 

Transfer operations; 

6,000,000 

gallons/year thruput 

Transfer operations; 

> 20,000 gallons/day 

Transfer operations; 

> 20,000 gallons/day 

Transfer operations; 

> 40,000 gallons/day 

Transfer Operations 

>20,000 gallons/day; 

> 150,000 

gallons/year 

Transfer operations; 

> 10,000 gallons/day 

Transfer operations; 

>40.000 eallons/dav 

Process/Products 

Organic liquids; > 1.5 psia 

Organic liquids; > 1.5 psia 

Volatile liquids 

Organic liquids 

Organic liquids; > 0.5 psia 

Organic liquids 

Organic liquids 

Organic liquids; > 1.5 psia 

Organic liquids; > 1.5 psia 

Organic liquids 

Organic liquids; > 1.5 psia 

Organic liquids; >1.5 psia 

Organic liquids; > 1.52 psia 

Standards/Reauirements 1 

Vapor recovery and/or disposal 

system=0.291bVOC/l,000 

gallons organic liquid transferred; 

after Feb. 1998-0.08 lb 

VOC/1,000 gallons organic liquid 

transferred 

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

2: 95% by weight 

lOmg/L emission limit 

21 mg/L emission limit 

Vapor recovery system (90%) or 

vapor balance system 

ab(d)sorption system-90% by 

weight; vapor handling systemdisposal efficiency of 95%. 

95% by weight VOC emission 

reduction 

95% by weight efficient reduction 

of VOCs 

Vapor collection system-90% 

Vapor collection system or bottom 

loading with closed hatches; 

Disposal-90% by weight by 

means of a vapor liquid absorber 

system. 

Bottom loaded vapor recovery 

system including a vapor 

retum/condenstion system or a 

vapor disposal system at 90% by 

weight 

Vapor collection adaptor; vapor 

tight seal 

Vapor collection & disposal 

svstem 

P^ 
P.86 

Attachment 2 

STATE REGULATIONS SUMMARIES, TRANSFER 

OPERATIONS (Cont.) 

State Regulation Applicability Process/Products Standards/Requirements 

Texas Section 115.211- Transfer operations 

: Subchapter C 

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

Michigan R 336.1609 Transfer operations; 

>5,000,000 

gallons/year 

Jhroughj)i£ 

Organic liquids; >1.5 psia Vapor recovery system; 0.7 

lb/1000 gallons emission limit 

Massachusetts 310 CMR 7.24 Transfer Operations; 

CM,MB,MV,PV, 

SM Bulk Plants 

Organic material > 1.5 psia Vapor balance system required; 

transfer must take place through a 

submerged fill pipe 

New Mexico NMAC 2.37.205 Transfer operations' Organic liquids; > 1.5 psia Loading arm with a vapor 

collection adapter; a means to 

prevent organic compound drainge 

from loading device 

Massachusetts 310 CMR 7.24 Transfer Operations; 

U Bulk Terminals 

Organic liquids; > 1.5 psia Vapor collection & disposal 

system required; 80 mg/liter 

emission limit 

California, 

Ventura 

County 

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

loading 

Illinois 218.122, Subpart TT. railcar transfer 

(Chicago) B operations; >40,000 

gallons/day 

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

no odor nuisance submerged loading, or equivalent 

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

>J20,000_gaVday>__ 

Organic liquids 

North Carolina .0948 Transfer operations; 

> 20,000 gal/day 

Organic liquids; > 1.5 psia 

Submerged filling arm or other 

Submerged loading through 

bottom loaders or equivalent 

Colorado 5CCR 1001-9 Transfer operations; 

Reg # 7 >56 gallons 

VOCs Submerged or bottom loading; 

top-fill pipe to within 6 inches of 

the bottom of the tank 

Wisconsin NR 419.05 Transfer operations; 

< 40,000 gal/day 

Organic liquids; >1.52 psia Submerged fill pipe extending to 

within 6 inches of the tank (vessel) 

bottom 

California, 71.3 Transfer Operations 

Ventura >20,000 gallons/day; 

County > 150,000 

gallons/year 

Organic liquids; > 0.5 psia Overfill protection system 

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

gallons loaded; same for >1.5 psia 

&< 15.0 psia, if> 1,000 

gallons/month (unless there is a 

vapor emission control system) 

Louisiana 33:111:2107 Transfer operations; 

Marine vessels 

Organic liquids; >1.5 psia; 

>100 tons/yr uncontrolled 

emissions 

Vapor collection system-90%; 

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

QLs> 
Attachment 2 

STATE REGULATIONS SUMMARIES, TRANSFER 

OPERATIONS (Cont.) 

State Regulation 

Massachusetts 310 CMR 7.24(8) 

Rhode Island 

Maine 

New Jersey 

California, 

San Diego 

California, 

San Diego 

Oklahoma 

Michigan 

32.2 

Chapter 600 

7-.1E-3 

61 

61 

252:100-37-16 

R 336.1706 

Applicability 

Transfer operations 

Transfer operations 

Transfer operations 

Transfer operations 

Transfer Operations; 

Both mobile 

transport and 

stationary storage 

tank> 550 gallons 

Transfer operations; 

mobile transport 

tank > 550 gallons 

Transfer operations; 

< 40,000 gal/day 

Transfer operations; 

>5,000,000 

gallons/year 

throughout 

Process/Products 

Marine vessel previous 

cargo-organic liquid 

Marine vessel previous 

cargo-organic liquid 

Petroleum liquids 

Pipelines 

Organic liquids 

Organic liquids 

Trucks (vessels); > 200 

gallons 

Crude Oil > 1.5 psia 

Standards/Reauirements 

95% emission reduction by 

recovery device or 98% by weight 

by combustion device; and 2 

lb/1,000 bbls emission limit 

VOC reduced by 95% by weight; 

98% by weight if a control device 

is used 

Miscellaneous minor requirements 

Conform to 49 CFR 195, 

"Transportation of Liquids by 

Pipeline" 

Equipped with a submerged fill 

pipe; 95% by weight VOC 

90% by weight of VOC; 0.29 lb 

VOC/1,000 gallons loaded; 

pressure may not exceed 18 inches 

of water 

Aggregate loading pipes equipped 

to fill—97% submergence must be 

maintained 

Vapor recovery system; 0.7 

lb/1000 gallons emission limit; or 

submerged fill pipe 

PT3 
Attachment 2 

STATE REGULATIONS SUMMARIES, WASTEWATER OPERATIONS 

State 

Virginia 

Washington 

Montana 

North 

Dakota 

Hawaii 

Maryland 

Louisiana 

California, 

Ventura 

County 

California, 

Bay Area 

Maryland 

North 

Carolina 

New Jersey 

New Jersey 

South 

Carolina 

Arizona 

Regulation 

9 VAC 5-40-1390 

WAC 173-490-

040 

17.8.324 

33-15-07-01 

11-60.1-40 

26-11-13.06 

Section 2153: 

Subchapter M 

71.3 

8-5-328 

26-11-13.06 

.0518 

7:1 E-2 

7:lE-4 

62.5, part O 

RI 8-2-905 

Applicability 

Wastewater 

Separators 

Wastewater 

Separators 

Wastewater 

Separators; >200 

gal/day 

Wastewater 

Separators; >200 

gal/day 

Wastewater 

Separators; >200 

gal/day 

Wastewater 

Separators; >200 

gal/day 

SIC Codes: 28-21, 

23,24,33,34,36, 

65,69,79 & 49-52, 

53,59. 

Delivery Vessels 

Wastewater; Tank 

Cleaning 

Waste 

Waste 

Process/Products 

Any petroleum liquid => 

kerosene in volatility 

Any volatile organic liquid 

VOCs; > 0.5 psia 

VOC; > 1.5 psia 

VOC Wastewater - storage, 

handling, transfer, or 

treatment. 

Organic liquids 

Organic liquids; >0.5 psia 

VOC 

Photochemically reactive 

VOC 

Storage, transfer, equipment leaks 

Storage, transfer, equipment leaks 

Equipment leaks 

Pumps & 

compressors 

Tanks 

VOC 

Standards/Requirements 

Vapor control system-95% 

Floating roof or fixed & sealed 

solid cover 

Floating roof or a vapor recovery 

& disposal system 

Floating roof, a vapor recovery & 

vapor disposal system, or 

equivalent 

Floating roof or a vapor recovery 

& vapor disposal system 

Floating roof, a vapor recovery 

system, or equivalent 

Reduce the VOC content of the 

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

the VOC content to less than 100 

ppm by weight. Also, various 

requirements for WW storage 

tanks. 

Vapor recovery system; pressurevacuum relief device; secondary 

overfill protection; loading 

connector/adapter 

Liquid balancing; 90% by weight 

efficiency 

Cannot discharge >200 lbs unless 

the discharge is reduced by 85% 

Cannot discharge >40 lbs unless 

the discharge is reduced by 85% 

See the rule 

Submit a DPCC plan, 

demonstrating compliance with 

7:lE-2 

Monthly inspection through the 

roof hatch; complete inspection of 

cover & seal whenever tank is 

emptied or non-operational for a 

year 

Mechanical seals or equivalent 

P^R