CITY OF PH ILADELPHIA Department of Public Health

Environmental Protection Division Air Management Services



### InterOffice Memo

To: File

From: Laura Nikkel-Dumyahn

Date: February 23, 2016

Subject: 1997 8-Hour RACT Analysis for Plains Products Terminals LLC

Introduction: The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas implement reasonably available control technology (RACT) controls on all major sources of Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx). Philadelphia County is part of the Philadelphia-Wilmi ngton-Atlantic City moderate ozone nonattainment area for the 1997 8-hour ozone NAAQS. This document presents the findings of a RACT evaluation for the 1997 8-hour ozone standard for this facility.

Company Description: The two adjacent bulk liquid storage and distribution terminals formerly known as Maritank and Exxon Mobil are now under one owner, Plains Products Terminals LLC (PPT). The term inals are now operated as one facility because they are contiguous and under a common owner.

Applicability for NOx and VOC RACT: Plains Products Terminals LLC is not a major source of NOx having potential NOx emissions less than 100 tons per year, the major source threshold in Philadelphia County that is applicable to NOx RACT for the 1997 8-hour ozone NAAQS.

Plains Products Terminals LLC is a major source of VOC having potential VOC emissions greater than 50 tons per year, the major source threshold in Philadelphia County that is applicable to VOC RACT for the 1997 8-hour ozone NAAQS.

Plains Products Terminals LLC is subject to the 1-hour RACT for VOC, per the 1-hour RACT Plan Approvals approved under the facility’s previous names: “Maritank Philadelphia, Inc.” Permit # PA-51-5013 (presently, the North Terminal) effective on December 28, 1995 and “Exxo n Company” Permit # PA-51-5008 (presently, the South Terminal) effective May 29, 1995, both approved by EPA into the Pennsylvania State Implementation Plan (SIP) on October 31, 2001 (66 FR 54947 and 66 FR 54936, respectively).

Process Descriptions: The facility’s air emissions sources contribut ing to VOC emissions include the following:

North Terminal

 One (1) 20 MMBTU/hr thermal fluid heater;

 One (1) 4.74 MMBtu/Hr boiler;

 3 petroleum/organic products storage ta nks, each with a capacity greater than or equal to 40,000 gallons:

o T-7 (Tank #15006) with 4,725,000 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

o T-8 (Tank #4007) with 1,260,000 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

o T-12 (Tank #4511) with 1,1417,500 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

 Truck loading process at North Terminal Rack;

 Two (2) recovery tanks, each with a capacity of 8,814 gallons, that store #2 oil and #6 oil recovered from a water

remediation process. Materials are loaded from the tanks into trucks a few times per year.

o T-18 (Recovery Tank #1) with 8,814 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o T-19 (Recovery Tank #2) with 8,814 gallon capacity stores Petroleum/Organic Products(v.p. ≤ 1.5 psi)

 Marine loading of petroleum/organic products with a Reid Vapor Pressure (RVP) of less than 4.0 psi (non-gasolne).

South Terminal

 Six (6) 0.25 MMBTU/hr space heating units (listed as “ins ignificant sources” on Title V Operating Permit V10-025);

 10 petroleum/organic produc ts storage tanks each with a capacity gr eater than or equal to 10,566 gallons;

o P60 (Storage Tank #5460) with 2,279,802 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

o P65(Storage Tank #1965) with 817,572 gallon capacity stores Petroleum/Organic Products (v.p.<=11.1 psi)

o P68(Storage Tank #6768) with 2,752,218 gallon capacity stores Petroleum/Organic Products (v.p.<=11.1 psi)

o P69(Storage Tank #4069) with 1,664,082 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

### 2 o P70(Storage Tank #6070) with 2,482,788 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

o P71(Storage Tank #9771) with 3,975,132 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

o P72(Storage Tank #6072) with 2,588,334 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

o P73(Storage Tank #6073) with 2,516,724 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

o P7(Storage Tank #5407) with 2,253,132 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

o P8(Storage Tank #5408) with 2,256,224 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 11.1 psi)

 Fugitive emissions from light liquids and gasoline from pumps, valves, & flanges;

 23 storage tanks each with a capacity each less than 4,725, 000 gallons (listed as “insig nificant sources” on Title V

Operating Permit V10-025);

o P5(Storage Tank #5) with 1,995,586 gallon capacity stores Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o P10(Storage Tank #10) with 10,038 gallon capacity stores Additive/ Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o P13(Storage Tank #13) with 10,038 gallon capacity stores Additive/ Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o P14(Storage Tank #14) with 9,500 gallon capacity st ores Additive/ Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o P15(Storage Tank #15) with 9,500 gallon capacity st ores Additive/ Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o P16(Storage Tank #16) with 3,000 gallon capacity st ores Additive/ Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o PTBN4(Storage Tank #TBN4) with 9,500 gallon capacity stores Additive/ Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o PTBN5(Storage Tank #TBN5) with 9,500 gallon capacity stores Additive/ Petroleum/Organic Products (v.p. ≤ 1.5 psi)

o P104 is 15 Small Storage Tanks (includes USTs, ≤ 500 gallon capacity) store ASTs non-volatile fuel

 Tank cleaning and repair (listed as “insignifican t sources” on Title V Operating Permit V10-025);

 Lubricity additive systems, one at the North Terminal and one at the South Terminal (both listed as “insignificant sources”

on Title V Operating Permit V10-025);

 Truck loading process at South Terminal Rack.

The facility’s control devices, which are used for em issions from truck loading, include the following:

 One (1) Vapor Incinerator (at North Terminal loading rack)

 One (1) Carbon Absorption Vapor Recovery Unit equipped with two (2) carbon beds (at South Terminal loading rack)

RACT Evaluation At the time of the 1-hour ozone RACT determination, the follo wing sources were existing and evaluated in Maritank: Shore tank cleaning; fugitive emission from valves, flanges, and pu mps; marine vessel loading; barge cleaning plant; washwater treatment system; two #2 fuel oil fired boilers as part of heating system, Boiler A (30 MMBTU/hr) and Boiler B (7 MMBTU/hr); truck loading operations at rack s; and truck loading operations at five recovery tanks. RACT source-specific requirements, per 25 PA Code 129.91-92, were specified into a 1995 RACT Plan Approval (# PA-51-5013), issued in December 28, 1995 and approved into the SI P by EPA on October 31, 2001 (66 FR 54 947) for the following VOC sources at Maritank: fugitive emissions, dock transfer st ation (where currently marine loading op erations take place), the two #2 fuel oil fired boilers of 30 MMBTU/hr and 7 MMBTU/hr (Boilers A and B, respectively), and the truck loading operations.

At the time of the 1-hour ozone RACT determination for Exxon, RACT for fugitive emissions from pumps, valves, and flanges was evaluated and approved into the RACT Permit # PA-51-5008 issued on May 29, 1995 and approved into the SIP by EPA on October 31, 2001 (66 FR 54936 and 40 CFR 51.2020(d)(1) and (c)(156)(i)(B)( 4 )).

The following 1-hour RACT sources have been shut down:

 Barge cleaning activity

 Water treatment plant

 Shore tank cleaning

Additionally, Boilers A and B (30 MMBTU/hr and 7 MMBTU/hr, respectively) addressed under 1-hour RACT were replaced in 2009 by two new boilers of 20 MMBtu/Hr and 4.74 MMBtu/Hr, respectively.

Presumptive RACT: The following sources are covered by presum ptive RACT provisions of 25 PA Code 129.93, as specified in the “Regulation”

column of the tables below.

Boilers

### 3 These boilers replaced Boilers A and B (30 MMBTU/hr and 7 MMBTU/hr, respectivel y), which were addressed in the 1- hour RACT Plan Approval . Both replacement boilers are applicab le to Presumptive RACT regulations.

For the one (1) 20 MMBtu/Hr boiler, the presumptive RACT requirement is the performance of annual adjustments or tuneups of the boiler, and keeping corresponding records. For the one (1) 4.74 MMBtu/Hr boiler, the presumptive RACT requirement is the installation, operation, and maintena nce of the boiler as per the manufacturer’s specifications.

Space Heating Units

For the six (6) < 250,000 Btu/Hr boiler, the presumptive RACT re quirement is the installation, operation, and maintenance of the boiler as per the manufacturer’s specifications.

Fugitive Emissions (both North and South terminals)

Fugitive process emission leaks ar e covered by the regulation, AMR V, Section XIII. As per AMR V Section XIII(1), no person shall cause, suffe r, allow or permit volatile organic compounds (VOC) to be emitted from leaking flanges, gaskets, seals, connections, joints, fittings or other process equipment components not involving moving parts, nor shall any person cause, suffer, allow or permit VOC to be emitted from leaking valves, pumps, compressors, safety pressure relief devices or other process equipment components involving moving parts such that:

 The VOC emission from any leaking process equipment component results in a VOC

in air concentration of 10,000 parts per million by volume (ppmv), or greater, when measured by test methods approved by the Department.

At the time of the 1-hour RACT determination, fugitive emi ssions were identified as VOC so urces in both Maritank and Exxon. Additionally, under the SIP-approve d 1-hr RACT plan approval s, each facility was required to monitor, detect, and repair leaks from all valves, pumps, and flanges processing all liquids, including non-VOC liquids. The SIP-approved 1-hr RACT plan approvals for Maritank and Exxon include the following condition (Condition 2A in both permits):

 “The facility will implement quarterly visible leak det ection and repair (LDAR) program for all pumps, valves, and

flanges in VOC service.”

Since AMR V, Section XIII has specific leak thresholds, AMS finds it is more stringent than the LDAR requirement approved as 1-hour RACT. Thus , the requirements in AMRV Section XIII will supersede the LDAR requirements, specified in the SIP. Consequently, AMS proposes to revise the existi ng requirements in the SIP for fugitive emissions to “shall comply with AMR V Section XIII.”

CTG RACT [i.e. Applicable to EPA Control Technique Guideline (CTG)]: The following sources are covered by regulations approved in the SIP to address RACT consistent with EPA’s Control Technique Guidelines (CTGs), or CTG RACT regulations, as sp ecified in the “CTG RACT Regu lation” column of the table

below:

13 Storage Tanks with capacities ≥ 40,000 gallons and containing VOCs with vapor pressure > 1.5 psi

### 4 For the thirteen (13) storage tanks with capacities greater than 40,000 gallons, since each unit stores petroleum/organic products with a vapor pressure ≤ 11 psi, the RACT requirement is the installati on of an external or an internal floating roof,

in accordance with 25 PA Code 129.56(a)(1).

Case-by-Case RACT Analysis: Loading at the Recovery Tanks There were five recovery tanks identif ied in the Maritank RACT Plan Approval. At the time of the 1-hour RACT determination, the five recovery tanks in Maritank stored mate rial recovered from the Barge Cleaning Plant. When the tanks were full at capacity, the recovered barge cl eaning material was loaded from the tanks into trucks and hauled away. Under the 1995 RACT Plan Approval (condition 2E), the facility is require d to connect the tanks to its existing vapor recovery system to recover any vapors from organic materials being loaded from trucks. According to the 1994 RACT Proposal submitted by Maritank, the uncontrolled PTE for truck loading at the recovery tanks was 2 tpy VOC. Assuming a combined collection and control efficiency of 90%, which is consistent with the organic material loading vapor recovery requirements of AMR V, Section V.B and 25 Pa Code Section 129.81, adding vapor recovery made the recovery tank truck loading PTE 400 lbs/yr

VOC.

Since the 1-hour RACT plan approval was issued, the Barge Cleaning Plant was shut down and three of the recovery tanks were removed. The remaining two recovery tanks now store a recovered mixture of #2 and #6 oil (both with a RVP well below 4 psi) and water from a groundwater remediation proce ss. When the tanks fill up, the recovered mixture of oil and water is loaded into trucks and hauled away. As provided by the facility, this usually happens two or three times per year. Assuming a potential throughput of 105,768 gal/yr combined for loading at the remaining two recovery tanks (completely unloading each tank 6 times per year, which is more than double the usual throughput) and using the loading loss equation in Section 5.2 of AP-42, the PTE for truck loading at the recovery tanks is 1.2 lbs/yr VOC without accounting for vapor recovery. This is based on the vapor pressure of #2 oil (the highest emitting component) and the AP-42 loading loss factor of 0.01 lb/1000 gal for #2 oil, calculated using the saturation factor table and loading loss equation in Chapter 5 of AP-42

Manual.

Product Throughput

Each Time a

Tank is Emptied (Gallons) Number o f

Times a

Tank is Emptied per Year Thoughput (Gallons/yr) Chemical Vapor

Pressure (psia) M,

Molecular Weight S, Saturation

Factor T, Annual Average Temp (deg F) LL, Emission

Factor (lb/1000 gals) Annual

Emissions (tons/year)

#2 Oil/#6

Oil/Water

Mixture (assumes #2 oil for properties) 8,814 12 (assuming

6 for each

recovery tank) 105,768 0.074 130 0.6 60 0.01 0.0006 Unit Description Capacity (Gallons) CTG RACT Regulation

T-7 Tank #15006 ( ≥ 10,566 gallons) 4,725,000 25 PA Code 129.56

T-8 Tank #4007 ( ≥ 10,566 gallons) 1,260,000 25 PA Code 129.56

T-12 Tank #4511 ( ≥ 10,566 gallons) 1,417,500 25 PA Code 129.56

P60(S) Storage Tank #5460 ( ≥ 10,566 gallons) 2,279,802 25 PA Code 129.56

P65(S) Storage Tank #1965 ( ≥ 10,566 gallons) 817,572 25 PA Code 129.56

P68(S) Storage Tank #6768 ( ≥ 10,566 gallons) 2,752,218 25 PA Code 129.56

P69(S) Storage Tank #4069 ( ≥ 10,566 gallons) 1,664,082 25 PA Code 129.56

P70(S) Storage Tank #6070 ( ≥ 10,566 gallons) 2,482,788 25 PA Code 129.56

P71(S) Storage Tank #9771 ( ≥ 10,566 gallons) 3,975,132 25 PA Code 129.56

P72(S) Storage Tank #6072 ( ≥ 10,566 gallons) 2,588,334 25 PA Code 129.56

P73(S) Storage Tank #6073 ( ≥ 10,566 gallons) 2,516,724 25 PA Code 129.56

P7(S) Storage Tank #6073 ( ≥ 10,566 gallons) 2,253,132 25 PA Code 129.56

P8(S) Storage Tank #5407 ( ≥ 10,566 gallons) 2,256,224 25 PA Code 129.56

### 5 Due to the changes of the materials at the recovery tanks an d the low potential throughput, the PTE for truck loading at the recovery tanks is currently extremely low, making the value of vapor recovery or any other control negligible. AMS determined that operating the vapor recovery unit and any other control technology on such a small source is both technically and economically unreasonable and that the source is de minimis. The table below shows that without the vapor recovery requirement, the PTE for the current process would be still ev en lower than it was under 1-hour RACT. AMS concludes that there is no need to continue to require the 1- hour RACT level of control for this source.

1-hour RACT PTE (w/ vapor recovery) 1997 8-hour RACT PTE (w/o vapor recovery) Net Change

400 lbs/yr VOC 1.2 lbs/yr VOC -398.8 lbs/yr VOC

AMS is requesting to remove from the SIP the vapor recovery control requirement for the truck loading at the recovery tanks. As shown above, AMS concludes that removal of this control measure from the SIP will not have any negative impacts to air quality in light of the current use of the recovery tanks, and t hus will not interfere with attainment of the NAAQS. Any future modifications of the loading operations at the recovery tanks will require a permit application and modification, and AMS

will address RACT at that time.

Marine Loading (North Terminal) Marine loading was referred to as the do ck transfer station in the 1-hour RACT plan approval. For the marine loading process, the facility was required to cease loading of gasoline after September 28, 1994, per th e 1-hour RACT plan approval for Maritank. By definition, under 25 PA Code 121.1, gasolin e is any petroleum distillate having a Reid vapor pressure (RVP) of 4 pounds per square inch (psi) (28 kilopascals) or greater and which is a liquid at standard temperature and pressure. Thus, AMS interprets this requirement to restrict marine loading of any organic liquids with RVP > 4.0 psi.

Number 2 Fuel Oil is the highest VOC emitting material that is loaded at the marine loading station, so emissions

calculations are based on the AP-42 loadin g loss factor of 0.012 lb/1000 gal for No. 2 Oil, calculated using the saturation factor table and loading loss equation in Chapter 5 of AP-42 Manual. The maximum number of hours per year experienced for marine loading operations is 4,380 hours due to the process of ships entering, exiting, and connecting to the loading dock. Therefore, the potential emissions from marine loading are 6.6 tpy.

Product Thoughput (Gallons/ hr) Hours Thoughput (Gallons/yr) Mode

and

Direction Rack ID Chemical Vapor Pressure (psia) M,

Molecular Weight S,

Saturation

Factor T, Annual Average Temp (deg F) LL, Emission

Factor (lb/1000 gals) Emissions (tons)

Distillate Fuel Oil #2 (diesel) 252,000 4,380 1,103,760,000 Barge North Dock -

Marine 0.0074 130 0.5 60 0.012 6.6

To determine RACT, AMS evaluated the feasibility of adding eac h of the following available VOC controls on the marine loading operations: thermal oxidation, ca rbon adsorption, bior eactor, wet scrubbers, and cond ensation via refrigeration.

Technical Feasibility: Thermal Oxidation- Technically Feasible Thermal Oxidation is a process in which the hydrocarbons in a gas stream are combusted to form carbon dioxide and water at an elevated temperature. Thermal Oxida tion efficiency is governed by temperat ure, time, and turbulence. To achieve effective combustion, the organics in the gas stream must be raised 100°F or more above their ignition temperature and held at that temperature for 0.3 to 1.0 seconds. In addition, the gas stream must be sufficiently mixed for good oxidation to occur. An auxiliary fuel is required to ensure the temperature is ma intained for proper combustion. There are essentially two types of incinerators: thermal and catalytic. Each type is considered technically feasible for the marine loading operation. However, for cost analysis purposes, only thermal incineration is consid ered since the relative cost of the two types are similar.

Carbon Adsorption- Technically Feasible Adsorption is an emission control technology in which the cont aminant gas stream passes though a bed of solid particles and then diffuses from the gas to the bed and is held onto the me dia by attractive forces. The adso rptive capacity of the solid for the gas tends to increase with the gas phase concentration, molecular weight, diffusivity, polarity, and boiling point. Typical adsorbent media in use include activated carbon, silica gel, ac tivated alumina, synthetic zeolites, fuller's earth, and other clays. Of these choices, this RACT analysis considers onl y the use of activated carbon because it is a commonly used adsorbent for VOCs. Carbon adsorption is considered technically feasible for the marine loading operation.

Bioreactor- Technically Infeasible

### 6 There are several different types of bior eactors from soil beds or bio-filters to bio-trickling filters and bio-scrubbers. Typically used for odor control, bioreactor s can be used to oxidize VOCs. For a bioreactor to be effective, the contaminant stream needs to be consistent in composition and maintained above 60°F. The marine vessel operation at Plains is not continuous and the site average annua l temperature is below 60°F (i.e. 54-56°F), so this control option is considered technically infeasible based on the batch nature of the loading process and the site average temperature.

Wet Scrubbers- Technically Infeasible Wet scrubbers use absorption to remove pollutants from a gas stream into a liquid stream. In the absorption process, the organics in the gas stream are dissolved into a liquid solvent. The limiting factors as a primary control technique involve the availability of a suitable solvent and the solubility of the organic. To control emissions from marine loading, the terminal would require a nonvolatile organic solvent. In addition, the sizing of the scrubber and fo otprint for support equipment (circulation pumps, blowers, and scrubbing liquid storage and blowdown system for refresh of the scrubber liquid) and the possible need for redundancy would be a major design consideration for the limite d space of the dock area. Based on these considerations, this control option is considered technically infeasible

.

Condensation- Technically Infeasible Refrigeration units are basically "heat pumps, " absorbing heat on the "cold side" of th e system and releasing heat on the "hot side" of the system.



### A refrigerated condenser is a viable control option if:

- the air stream is saturated with the organic compound

- the organic vapor containment system limits air flow

- required air flow does not overload a refrigeration system with heat

- only one organic compound is emitted

In addition to the fact that the marine vessel loading operation may handle multiple compounds and the air stream is only considered to be 50 percent saturated, refrigerated units have extensive energy requirements, are unreliable, and may require

additional controls due to low efficiencies. Based on thes e considerations, refrigerated condensation is considered technically infeasible

.

In conclusion, AMS only found thermal oxidation and carbon adsorption to be technically feasible options for controlling

VOC emissions of marine loadin g at Plains Product Terminal.

Cost Feasibility: The following table summarizes the estimated control effectiveness for the technically feasible controls:

Control VOC Emissions (tpy) Estimated Control

Effectiveness VOC Reduction (tpy) Total Annualized Cost (per year) Cost Effectiveness (per ton)

Thermal Oxidation 6.6 98% 6.5 $727,094.44 $110,165.82 Carbon Adsorption 6.6 95% 6.3 $132,774.58 $20,117.36 A breakdown of the costs for these two options can be found in Appendix A.

AMS therefore determines that no availabl e controls are technically or economica lly reasonable as RACT for marine vessel loading. In addition to the existing RACT requirements, including the prohibition of loading gasoline, AMS is proposing an emissions limit of 6 tpy VOC from marine vessel loading of liq uids with RVP greater of equal to 4 psi to represent VOC RACT under the 1997 8-hour ozone standard for the marine vessel loading operations in Plains Products Terminals.

Tank Cleaning and Repair The tanks are degassed approximately every 10 years and the degassing occurs for about 24 hours for out of service inspections. Only a few of the tanks are degassed at the sa me time. Using a methodology from the San Diego Air Pollution Control District to calculate emissions from this process, the highest annual VOC emissions from degassing are 9.27 tons per year. For Plain Products, degassing of three of its tanks is schedule to occur in 2021.

Tank cleaning PTE calculations for Year 2021: Tank # Capacity (bbls) Product Stored Tank Diameter Degassing Emissions (tons) 15003 150000 gas going to Asphalt 48x150 5.25

5460 54000 ethanol 48x90 1.90 6072 60000 gasoline 48x95 2.12

SUM: 9.27

### 7 Thermal oxidation could be used to control emissions to 90% effectiveness. The cost to control these emissions is $30,000 per tank per event based on a vendor quote. The cost to control these degassing events during a particular year is $90,000 (as three tanks will be scheduled for cleaning). The cost effectiven ess to control these emissions is $9,700 per ton. Thus it is not cost effective to control the degassing emissions under RACT.

De Minimis Sources: 23 Storage Tanks (each with a capacity each less than 4,725,000 gallons) Each of the tanks has a PTE of less than 1.0 tpy of VOC. Based on AMS permitting and engineering knowledge, AMS determines that installing any control technology on such sm all sources is both technically and economically unreasonable.

Truck Loading (both North and South terminals, formerly only Maritank) Truck loading now occurs at both the North and South Terminals. Truck loading had previously only occurred at the North Terminal (formerly Maritank), but now there are truck loadin g operations at the South Term inal as well since Plains’ acquisition of the property. Truck loading occurs at the racks and occurs at the two recovery tanks a few times per year.

The South Terminal has a 200 million gallons per rolling 12-month limit on distillate loading from the Title V/State Operating Permit No. V10-025, which results in a PTE of less than 2.1 tpy VOC emissions. The North Terminal truck loading has a 101 million gallons per rolling 12-month capacity on distillate loading, from a Title V Operating Permit Application from 1997, which results in a PTE of less than 1.1 tpy VOC emissions. Based on AMS permitting and engineering knowledge, AMS determines that installing any control technology on such small sources is both technically and economically unreasonable.

Truck Loading at the Recovery Tanks As described above, truck loading at the recovery tanks has a PTE of 1.2 lbs/yr VOC. Based on AMS permitting and engineering knowledge, AMS determines that installing any control technology on such small sources is both technically and economically unreasonable.

Lubricity Additive System North Terminal Rack an d Lubricity Additive System South Terminal Rack The lubricity additive systems each have a PTE less than 1.0 tpy of VOC. Based on AM S permitting and engineering knowledge, AMS determines that installing any control tech nology on such small sources is both technically and economically unreasonable.

Storage Tanks with capacities ≤ 40,000 gallons and containing VOCs with vapor pressure < 1.5 psi For the two (2) storage tanks with capacities of 8,814 gallons storing recovered #2 and #6 oil from historic groundwater remediation, the PTE from both storage and loading are well below 1 tpy VOC. Based on AMS permitting and engineering knowledge, AMS determines that installing any control tech nology on such small sources is both technically and economically unreasonable.

Conclusions and Recommendations: The two RACT permits for the former Maritank (Permit # PA -51-5013) and Exxon (Permit # PA-51-5008) will be replaced with one permit for Plains Products Terminals, the current owner. Air Management Services proposes that compliance with AMR V, Section XIII represen t VOC RACT under the 1997 8-hour ozone standard for the fugitive emissions in Plains Products Terminals LLC. The quarterly LDAR program is rem oved. The marine loading will continue to be limited to loading organic lquids with a RVP less than 4 psi and is now subject to a limitation of 6.6 tpy VOC emissions. The vapor recovery requirement for truck loading at the recovery racks is removed. All other significant VOC emitting sources are either covered by presumptive RACT, are applicable to CTG regulations, or are determined to be de minimis. The vapor recovery requirement from the recovery tanks is being removed. All shut down sources are being removed.

2/23/16

Edward Wiener, Chief of Source Registration Date

### 8 Appendix A The following are the cost analyses for the two feasible control options for marine vessel loading emissions, thermal oxidation and carbon adsorption:

Thermal Oxidation – Total Capital Investment

Thermal Oxidation – Total Annual Cost

Thermal Oxidation – Cost Summary

Based on a vendor quote for another project, the capital cost for the incinerator is estimated to be $1,245,705.77 and the annual operating costs are $727,094.44 per year. Thermal oxidation would cost $110,165.82 per ton of VOC.

### 9 Carbon Adsorption – Total Capital Investment

Carbon Adsorption – Total Annual Cost

Carbon Adsorption – Cost Summary

Based on the EPA Cost Control Manual, the capital cost for pu rchased carbon is estimated to be $68,982.90 and the annual operating costs are $132,774.58 per year. The cost per ton or VOC is $20,117.36/ton.

Based on the current permitted values, the technically feasible controls for marine loading are not cost effective and thus no control device is required.

### 10