Technical Support Document August 201 4

Revisions to Texas SIP to Control Volatile Organic Compound Emissions from Storage Tanks

Background

Under the Clean Air Act (CAA)

, EPA promulgated an 8

- hour ozone standard of 0.08 parts per million (ppm), which is more protective than the previous 1

- hour ozone standard (62 FR 38855

, July 18, 1997 ). On April 30, 2004, EPA published designations and classifications for the 1997 8

- hour ozone standard ( 69 FR 23858). The Dallas

- Fort Worth 1997 ozone nonattainment area (DFW area)

, which consists of Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall and Tarrant Counties , was in itially classified as a moderate ozone nonattainment area . The DFW area was reclassified as a serious ozone nonattainment for the 1997 ozone standard (75 FR 79302, December 20, 2010). The Houston

Galveston

- Brazoria ozone nonattainment area ( HGB area ) consists of Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery and Waller counties. The HGB area is classified as a severe ozone nonattainment for the 1997 ozone NAAQS (73 FR 56983, October 1, 2008). The Beaum ont

- Port Arthur area (BPA area) consists of Hardin, Jefferson, and Orange Counties and was redesign ated to attainment for the 1997 ozone standard ( 75 FR 64675 , October 20, 2010).

Volatile organic compounds (VOC s ) and oxides of nitrogen (NOx) are known as “ozone precursors”, as they react with oxygen and sunlight to form ozone. Motor vehicle exhaust and industrial emissions, gasoline vapors and chemical solvents emit NOx and VOCs. Controlling sources of NOx and VOC emissions can lower ozone levels in the ambient air.

Sections 172(c)(1) and 182 of the Clean Air Act require ozone nonattainment areas that are classified as moderate or above for ozone nonattainment to adopt Reasonably Available Control Technology (RACT) requirements for sources that are subject to Control Techniques Guidelines (CTGs) issued by EPA and for “major sour ces” of volatile organic compounds (VO Cs) and nitrogen oxides (NOx). Major sources for areas classified as serious are those that have the potential to emit 50 tons per year (tpy) of VOCs or NOx (CAA 182(c)). RACT is defined as the lowest emissions limitat ion that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility (44 FR 53762

, September 17, 1979).

EPA has issued a number of CTGs and Alternative Control Technique (ACT) Guidelines to assist States in implementing RACT requirements. These documents are available at www.epa.gov/airquality/ozonepollution/SIPToolkit/ctgs.html and provide information on the available control technology for various sour ce categories . CTG s provide control information that provides a “presumptive norm” for RACT for particular source categories. State rules that conform to the “presumptive norm” established in the CTG have generally been approved as RACT.

Two CTGs and one ACT pertain to the VOC storage tank category:

• Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed

- Roof Tanks ( EPA

- 450/2

- 77

- 036 , December 1977 )

• Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Flo ating Roof Tanks ( EPA

- 450/2

- 78

- 047 , December 1978)• Alternative Control Techniques Document

– Volatile Organic Liquid Storage In Floating and

Fixed Roof Tanks ( EPA

- 453/R

- 94

- 001 , January 1994)

EPA previously found that the Texas rules meet RACT requirements for storage tanks in the HGB area

, most recently in 2010 (75 FR 15348, March 29, 2010). EPA a lso previously found that Texas rules for storage tanks met RACT requirements for the DFW area (64 FR 3841, January 26, 1999 and 74 FR 1903, January 14, 2009).

S IP Revision A dopted on December 7, 2011 and Submitted to EPA on January 12, 2012

On December 7, 201 1

, the Texas Commission on Environmental Quality ( TCEQ ) adopted a revision to the SIP and submitted it to EPA on January 12, 2012. The revision pertains to VOC control requirements for storage tanks in the DFW area

, the HGB area, the BPA area and Aransas, Bexar, Calhoun, El Paso, Gregg, Matagorda, Nueces, San P atricio, Travis and Victoria Counties. On January 17, 2012, TCEQ submitted the revised SIP to EPA. The State submittal can be found in the electronic docket (www.regulations.gov, Docket number EPA

- R06

- OAR

- 2012

- 0096). As documented in the submittal, Texas p rovided notice of the proposed revisions and public hearings in Texas newspapers and the Texas Register. Public hearings were held in Arlington, Austin and Houston.

The revision amended Title 30, Chapter 115 of the Texas Administrative Code (30 TAC 115) to revise §§115.110, 115.112

- 115.117, and 115.119 and add new §§115.111 and 115.118. Table 1 lists the areas covered by the revision and the applicable sections of 3 0 TAC 115, Subchapter B, Division 1 (Storage of Volatile Organic Compounds). A discussion of the changes by TCEQ can be found in Appendix A

– Excerpt from December 23, 2011 Texas Register. The final adopted rule can be found in Appendix B

– 30 TAC 115, Sub chapter B, Division 1 (Storage of Volatile Organic Compounds)

. Table 1. Areas covered by 30 TAC 115, Subchapter B, Division 1

Area Applicable 30 TAC Section DFW and HGB 115.110, 115.111(a), 115.112( e), 115.113, 115.11 4(a), 115.11 5 (a)

, 115.11 6 (a)

, 115.11 7, 115.11 8 (a) , 115.119 BPA, El Paso County 115.110, 115.111( a), 115.112(a ), 115.113

, 115.114(a)

, 115.115(a), 115.116(a) , 115.117, 115.118(a) , 115.119 El Paso County 115.110, 115.111( a), 115.112(a ), 115.113

, 115.114(a)

, 115.115(a), 115.116(a) , 115.117, 115.118(a) , 115.119 Gregg, Nueces, and Victoria Counties 115.110, 115.111( b), 115.112( b), 115.113 , 115.114(b )

, 115.115(b ) (Victoria County only), 115.116(b ) , 115.118(b )

, 115.119 Aransas, Bexar, Calhoun, Gregg, Matagorda, San Patricio and Travis Counties 115.110, 115.111( c), 115.112( c), 115.113 , 115.114(c )

, 115.119Evaluation of Revision

Review of the Revision

Review of the revision found the following that in the DFW area the amendments to the SIP

• Added a new requirement for control of VOC flash emissions from storage tanks in the DFW area that might otherwise emit 50 tpy of VOC or more

• Added new requirements for low

- leaking storage tank fittings in DFW

• Added new requirements to limit situations w hen a floating roof storage tank is allowed to emit VOCs because the roof is not floating on the stored VOC liquid

For the DFW and HGB areas the revision also adds a requirement that the vapor recovery unit used for VOC control must be designed to process all VOC vapor generated by the maximum crude oil and condensate throughput of the storage tank and must transfer recovered vapors to a pipe o r container that is vapor

- tight.

VOC flash emissions occur during transfer of the VOCs from a higher pressure storage tank to a lower pressure tank, reservoir, or other container. Floating roof landing loss emissions occur when the liquid level in a floating roof tank is lowered and the roof rests (lands) on the legs, or supports, rather than on the liquid, severely limiting the VOC control efficiency of the floating roof. The requirements to control flash emissions, use low

- leaking tank fittings and further limit emissions from floating roof storage tanks were previously implemented in the HGB a rea and approved by EPA as RACT (75 FR 15348, March 29, 2010).

The review also found that in the DFW, HGB and BPA areas and in El Paso, Gregg, Nueces and Victoria Counties the amendments to the SIP

• Add an explicit requirement that any flare used for cont rol must be designed and operated according to 40 CFR §60.18(b)

- (f) as amended through December 22, 2008 (115.112(a)(3), 1 15.112(b)(1), 115.112(e)(3)(C))

• Improve monitoring and testing to ensure effectiveness of VOC controls

While the VOC control requirements for storage tanks also apply in Aransas, Bexar, Calhoun, Matagorda, San Patricio and Travis Counties, review of the revision found that it did not substantially change requirements for these counties.

Appendix A discusses all the rule change s. The final adopted rule submitted to EPA can be found in Appendix B.

EPA has previously found that the Texas rules meet RACT requirements for floating and fixed roof tanks in the HGB area, most recently in 2010 (75 FR 15348

, March 29, 2010 ). As shown in the table 2

, these revisions improve the rules for controlling VOCs from storage tanks . With these improvements, the rules will contin ue to e nsure the CAA RACT requirements are met.Table 2

. Summary of Substantive C hanges in SIP Revision for 30 TAC 115 Subchapter B, Division 1, Storage of Volatile Organic Compounds Section Amended Amendment Comment s

115.110 Applicability and Definitions Changed title (formerly Definitions) and added

language on areas of applicability: DFW, HGB, BPA, and Aransas, Bexar, Calhoun, El Paso, Gregg, Matagorda, Nueces

, San Patricio

, Travis and Victoria Counties

. Added definitions for Storage capacity, Storage tank and Vapor recovery unit

. Improves clarity

.

115.111 Exemptions Exemptions moved from 115.117

. DFW: The rule

revisions provide an exemption from the new controls on flash emissions for a storage tank or tank battery in the DFW area with a condensate throughput exceeding 3,000 barrels per year on a rolling 12

- month basis from the requirement in §115.112 (e)(4), to control flashed gases if the owner or operator demonstrates, using the test methods specified in §115.117, that uncontrolled VOC emissions from the individual storage tank or from the aggregate of storage tanks in a tank battery are less than 50 tpy on a rolling 12

- month basis (115.111(a)(10)). A similar exemption with a threshold of 25 tpy was added in case the DFW area is reclassified to severe (115.111(a)(1 1 )). CAA 182(c) sets the serious area major stationary source threshold to 50 tpy of VOC

. Consistent with this t he revision lowers the stationary source threshold for major stationary sources in the DFW

area

. As RACT is required for major stationary sources in DFW that emit 50 tpy or more the exemption is allowed. In our approval of the previous revision, which included exemptions, we noted that it improved the TCEQ rules and that our approval would not interfere with any applicable concerning attainment or any other applicable requirement of the CAA including RACT requirements as required by CAA 110(l). (See the Technical Support Document for e

- docket EPA

- R06

- OAR

2007

- 0526 in www.regulations.gov ). 115.112 Control Requirements DFW: New r equirements added for 1) control of

VOC flash emissions from storage tanks in the DFW area that might otherwise emit 50 tpy of VOC or more ( 115.112(e)(1)), 2) low

- leaking storage tank fittings (115.112(e)(2) (A

- J ), and 3) l imit ing situations when a floating roof storage tank is allowed to emit VOCs because the roof is Additional control for major stationary sources in the DFW area. Control was previously found to be RACT in the H GB area. The vapor recovery unit requirement helps ensure it will effectively controlnot floating on the stored VOC liquid (115.112(e)( 2 ) (I) )

. DFW and HGB: requirement added that the vapor recovery unit must be designed to process all VOC vapor generated by the maximum crude oil and condensate t hroughput of the storage tank and must transfer recovered vapors to a pipe or container that is vapor

- tight (115.112(e)(3)(B)). DFW, HGB, BPA, and El Paso, Gregg, Nueces and Victoria Counties: e xplicit requirement that any flare used for control must be de signed and operated according to 40 CFR §60.18(b)

- (f) as amended through December 22, 2008 (115.112(a)(3), 115.112(b)(1), 115.112(e)(3)(C)). emissions. For DFW and HGB the additional vapor recovery unit requirement is an improvement to help

ensure that vapor recovery units will function effectively to capture and transfer the VOC emissions from a storage tank under normal operating conditions. The f lare requirement is an improvement to the VOC control requirement.

115.113 Alternate Control Requirements No change in approved language.

115.114 Inspection Requ irements DFW : updated so that the secondary seal gap

measurement requirement s are the same as for HGB (115.114(a)(2)

, 115.114(a)( 3) and 115.114(a)( 4); references to 115.112(e)(2)(F) and (G) )

. C onsistent with a dditional requirements for DFW.

115.115 Monitoring Requirements Moves the monitoring requirements that were

previously located at 115.116. DFW, HGB, BPA, and El Paso County: clarifying language added for monitoring carbon adsorption systems to ensure effectiveness of (115.115(a)(3)). DFW and HG B: added specificity to the requirement for continuous monitoring of a vapor recovery unit to demonstrate effectiveness (115.115(a)(5); reference to 115.112(e)(3)). DFW, HGB, BPA, El Paso County and Victoria County: allows for monitoring of a carbon adsorp tion unit using EPA method 21 once every 7 days to ensure that it is working effectively ( 115.115(a)(3) (A) and 115.115(b)(3) ). Improves monitoring to ensure effectiveness of controls.

115.116 Testing Requirements DFW, HGB, BPA, and El Paso County: specified

testing requirements for 1) an initial control efficiency test for vapor control systems that are not a vapor recovery unit or a flare, 2) retesting for control systems that are modified in a way that could decrease control efficiency, and 3) des ign verification tests of 40 CFR 60.18(f) (115.116(a)). Gregg, Nueces and Victoria Counties: Clarifying language added for 1) an initial control efficiency Improves testing to ensure effectiveness of controls.test for vapor control systems that are not a vapor recovery unit or a flare and 2) design verificat ion tests of 40 CFR 60.18(f) (115.116(b))

. 115.117 Approved Test Methods Test methods previously located in 115.115 are

moved to this section. DFW, HGB, BPA, and El Paso

, Gregg, Nueces and Victoria Cou nties: an allowance added for use of another test method if its validated by 40 CFR 63, Appendix A, Test Method 301 and approved by the TCEQ Executive Director (115.117(10)). 40 CFR 63, Appendix A, Test Method 301 is EPA’s procedures to validate an altern ative test method

.

115.118 Recordkeeping Requirements Recordkeeping r equirements that were previously

in 115.116 are moved to this section. DFW, HGB, BPA, and El Paso County: 1) c larification was added that owner/operators claiming an exemption in 115.111 must maintain sufficient records to show the exemption is allowed (115.118(a)(1))

, 2) recordkeeping was expanded for carbon adsorption systems (115.118 (a) (4)(C)) and 3) an allowance was added for storing records offsite, if they can be provided for review in 24 hours (115.118 (a) (5)). DFW: Recordkeeping requirements for HGB were added (115.118 (a) (6)). Recordkeeping was improved. TCEQ noted that offsite storage of records provides flexibility to owners/operators with unstaffed locations not equipped for r ecord storage.

115.119 Compliance Schedules DFW: Added a provision that if compliance would

require emptying and degassing of the storage tank, compliance can be delayed until the next time the storage tank is emptied and degassed, but no later than December 1, 2021 (115.119(b)(1)(A)). Other compliance dates have passed. The DFW provision is similar to one previously approved for HGB which allowed delay until the next time the storage tank is emptied and degassed, but no later than January 1, 2017. By allowing the delay, additional emissions from emptying and degassing the tanks to install controls may be avoided.

CAA 110(l) Analysis

CAA section 110(l) requires that a SIP revision submitted to EPA be adopted after reasonable notice and public hear ing. Section 110(l) also requires that we not approve a SIP revision if the revision would interfere with any applicable requirement concerning attainment and reasonable further progress, or any other applicable requirement of th e CAA

. Texas adopted the SIP revision after reasonable notice and public hearing . Since the revision strengthens the SIP

, results in new DFW area VOC emission reductions

, implements serious area RACT requirements for the DFW area and continues RACT controls for the HGB area , appro val will not interfere with any applicable requirement of the CAA

.Recommendation

It is recommended that the revision to the Texas SIP be approved because :

• It improve s the rules that were previously approved

• R esult s in additional VOC reductions in DFW area

• Ensures that RACT is met for storage t anks with flash emission s in the DFW area and continues to be met in the HGB area

• Approval would not interfere with any applicable requirement concerning attainment and reasonable further progress or any other app licable requirement of the CA A

Appendices

Appendix A

– Excerpt from December 23, 2011 Texas Register

Appendix B

– 30 TAC 115, Subchapter B, Division 1 (Storage of Volatile Organic Compounds)