PES 

A MACTEC COMPANY,.s.-.-----­ -/-­

~~­ _­ .e---- --~.”..-”---~ \ -”- .-

To: Organic Liquids Distribution NESHAP Docket 

From: Ken Meardon, Pacific Environmental Services 

Date: August 5,2003 

Subject: MACT Floor Analysis for Storage Tanks 

Pacific EnvironmentalServices, Inc. 

5001 South Miami Boulevard,Suite 300 

P.O. BOX 12077 

ResearchTriangle Park, NC 27709 

Office: 919/941-0333 Fax: 919/941-0234 

Home Page: www.mactec.com 

The purpose of this memorandum is to present the MACT floor analysis for storage tanks. 

The tanks used in the floor analysis are presented in Attachment 1. The tanks used in this 

analysis are only those tanks identified in the “Baseline Emissions and Emissioi?Reductions” 

memorandum that have the necessary information (e.g., capacity, HAP vapor pressure) to be 

included in the floor analysis. 

There are 855 tanks in the promulgation dahbase and 659 tanks in the floor analysis. The 

top performing 12% of tanks is represented by the top 103 tanks for the entire database or the top 

79 tanks based on the tanks for which sufficient information is available to analyze the controls 

applied to the tanks. In either case, the top performing 79 and 103 tanks are represented by fixed 

roof tanks with add-on controls, fixed roof tanks with internal floating roofs, and tanks with 

external floating roofs achieving at least 95 percent emission reduction. There are at least 227 of 

these tanks in the database. 

In analyzing the MACT floors for storage tanks, we arrayed the information based on 

tank size and HAP vapor pressure of the liquid(s) being stored. This is a well-documented 

approach for analyzing storage tanks. Tanks with smaller capacities storing liquids with lower 

vapor pressures have lower emissions than tanks with larger capacities storing liquids with higher 

vapor pressures. Table 1 presents the data for the best controlled tanks (those achieving at least 

95% control with add-on controls and those tanks with the best internal and floating roofs) and 

the total number of tanks for five tank capacity ranges and up to six vapor pressure ranges within 

each capacity range. 

Table 2 presents the data in three broad capacity ranges: less than 5,000 gallons, 5,000 to 

50,000 gallons, and 50,000 gallons or more. For the two larger capacity ranges, the vapor 

pressure ranges are divided into 4 ranges: <0. 1, 0.1 to 4.9, 1.9 to C4.0, and 24.0. 
MACT Floor Analysis for Storage Tanks 

page 2 

TABLE 1. PROMULGATION ANALYSIS - STORAGE TANKS 

(NonCrude 2 5% HAP and Crude Oil; 95+% Control Efficiency)

1 Capacity I vapor Comments on Controlled Tank Counts (gallons) Pressme Range Total 

<5,000 <o. 1 0 I 12 

0.1 to <4.0 0, 18 

->4.Q 0 0 

5,000 to <o. B 0 9 

0.1 to 4.9 I 0 7 1 

1.9 to <4.0 0 12 

I ->4.0 1 2 195% fixed roof 

10,000 to <o.I 0 5 

<20,000 0.1 to <0.5 

0.5 to <0.75 

0.75 to -4.9 

1.9 to <4.0 

20,000 to <o. 1

I <50,000 1 0.1 to <0.5 

0 1 

0 3 ~ ~~ 

0 7 

I 24.0 1 3 compliant IFR 

250,000 <o. 1 9 1 fixed roof tank at 295%; rest compliant 

132 floating rooftanlts

1 5 fixed roof tanks at 295% reduction; rest 0.1 t0<0.5 I 64 I 159 1 compliant floatina1 

roof tanks I I 1 

0.5 to c0.75 I 14 i 33 I compliant floating roof tanks 1I 

0.75 to<I.9 I 34 I 76 1 4 fixed roof tanks at 295% reduction; rest 

compliant floating roof tanks 1 

1.9 to c4.0 91 115 compliant floating roof tanks 

->4.0 9 17 compliant floating roof tanks ~ ~

I a11 1 227 I 659 

2 
MACT Floor Analysis for Storage Tanks 

Page 3 

TABLE 2. FLOOR ANALYSIS FOR STORAGE TANKS 

HAP Vapor Cumulative Counts Is there a floor for 

Capacity Pressure Range (gallons) (psia) Controlled high vapor pressure) Existing 

0 30 

5,000 to 

<50,000 0.1 to 4.9 

1.9 to <4.0 

250,000 

0.1 to C1.9 112 268 1211400 YES YES 

1.9 to <4.0 91 115 212 I515 YES YES 

24.0 9 17 221 I532 YES YES 

As seen in Table 2, none of the storage tanks with capacities of less than 5,000 gallons are 

controlled. Similarly, none of the storage tanks with capacities of less than 50,000 gallons are 

controlling liquids whose HAP vapor pressure is less than 0.1. Thus, for these tanks, there are no 

additional emission reduction floors for existing or new tanks identified. 

About 40% of all tanks with capacity of 50,000 gallons or more are controlled by at least 

95% by add-on control devices or they are equipped with the best internal or external floating 

roofs. Floors for both existing and new tanks are identified for these tanks at all vapor pressure 

ranges. 

For the tanks in the 5,000 to <50,000 gallon capacity ranges, we looked at the ratio of 

cumulative number of the best controlled tanks to total tanks as the HAP vapor pressure 

increased. For existing tanks, only when the HAP vapor pressure reached at least 4.0 psia were 

there sufficient tanks being controlled to identify a MACT floor. Below 4.0 psia, the floor for 

existing tanks is identified as no additional emission reduction. For new tanks, control is 

identified for tanks storing liquids with a HAP vapor pressure as low as 0.1 psia. This sets the 

floor for new tanks in this capacity range. For new tanks with capacities between 5,000 and 

50,000 gallons, no additional emission reduction floor was identified for tanks storing liquids 

with a HAP vapor pressure of less than 0.1 pia. 

For existing storage tanks in the 5,000 to <50,000 gallons capacity range, the sixth facility 

represents the median facility. This facility is achieving a 95% reduction. 

For existing storage tanks with capacities of 50,000 gallons or greater, the median 

facilities for all of the vapor pressure ranges is represented by the best performing internal or 

external floating roof tank. The performance of these tanks varies based on the liquid being 

stored, but generally achieves at least 95% reduction. 

3 
ATTACHMENT 1 

STORAGE TANKS FOR FLOOR ANALYSIS 
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