MDE 

MARYLAND DEPARTMENT OF THE ENVIRONMENT 

1800 Washington Boulevard • Baltimore MD 21230 

410-537-3000 • 1-800-633-6101 • www.mde.state.md.us 

Martin 0' Malley 

Governor 

Anthony G. Brown 

Lieute nant Governor 

Mr. Shawn M. Garvin 

Regional Administrator (3RAOO) 

U.S. Environmental Protection Agency 

Region Ill 

1650 Arch Street 

Philadelphia PA 19103-2029 

~ 4; kt:.AA>Y'l Dear 7 . _ arVin: 

Robert M. Summers. Ph.D. 

Secretary 

The purpose of this letter is to submit the enclosed is State Implementation Plan (SIP) Revision # 14-

05 concerning amendments to 26.11.13 Control of Gasoline and Volatile Organic Compound Storage 

and Handing. This SIP revision provides an alternative equivalent vapor recovery method for the 

transfer of high vapor pressure materials and amends incorrect references from regulations .04 and 

.05. 

The Notice of Proposed Action was published in the Maryland Register on April 1 8, 2014. A public 

hearing was held on June 3, 2014. The action was adopted on July 2, 2014. The Notice of Final 

Action was published on July 11, 2014 and the action became effective on July 21 , 2014. All required 

administral ive procedures were followed throughout the adoption process. 

I certify that the electronic copy of this SIP submittal (compact disk enclosed) is an exact duplicate of 

the official hard copy. If you have any questions concerning this SIP action, please feel free to call me 

at (410) 537-3084 or Mr. George (Tad) S. Aburn, Jr., Director of the Air and Radiation Management 

Administration, at (410) 537-3255. 

Sincerely, 

b Robert M. Summers, Ph.D. 

Secretary 

Enclosure 

Recycled l'illll1' www. Mde.state.md.us TIY Uscn; 1-l!(Xl-7lS-225X 

Via T}'Ia d Relay Service 
Final text COMAR 26.11.13.04 & .05 

effective July 21, 2014

.04 Loading Operations.

A. Bulk Gasoline Terminals.

(1) Standards. The owner or operator of a bulk gasoline terminal shall:

(a) Equip the loading system with a vapor control system designed to collect all vapors and control at least 90 percent of 

all vapors from the loading racks, and emissions from the loading rack may not exceed:

(i) 0.29 pound of VOC per 1,000 gallons (35 milligrams per liter) of gasoline or VOC loaded in Areas III and IV and 

Calvert, Cecil, Charles, and Frederick counties; or

(ii) 0.67 pounds of VOC per 1,000 gallons (80 milligrams per liter) of gasoline or VOC loaded in Area I and 

Caroline, Dorchester, Kent, Queen Anne's, St. Mary's, Somerset, Talbot, Wicomico, and Worcester counties.

(b) Design and operate the vapor control system and the gasoline loading equipment so that during loading:

(i) The gasoline tank truck pressure does not exceed 18 inches of water, and vacuum does not exceed 6 inches of 

water; and

(ii) There are no gasoline leaks in the system when tested by the method referenced in §A (3) (a) of this regulation 

during loading or unloading operations.

(c) Equip the loading rack with a top submerged or bottom loading system.

(2) Compliance and Record Keeping.

(a) Testing.

(i) Vapor control systems shall be tested for compliance with §A (1) (a) of this regulation once every 5 years, during 

the period between May and September 15.

(ii) The owner or operator shall notify the Department not less than 15 days before the scheduled test date, and 

notification shall contain a copy of the test protocol.

(iii) A copy of the test results shall be submitted to the Department not more than 60 days after the test date.

(b) The owner or operator shall keep a record of all maintenance and repairs performed on the vapor recovery unit for 2 

years, and make these records available upon request by the Department.

(3) Test Procedures.

(a) Testing for leak-tight conditions, as required in §A(1)(b)(ii) of this regulation, shall be conducted as prescribed in 

Method 1008 of the Department’s Technical Memorandum 91-01, “Test Methods and Equipment Specifications for Stationary 

Sources” January 1991, as amended through Supplement 3 (October 1, 1997), which is incorporated by reference in COMAR 

26.11.01.04C.

(b) The test procedures to determine mass emission rate compliance as required in §A(1)(a) of this regulation, shall be as 

prescribed in Method 1009 of the Department’s Technical Memorandum 91-01, “Test Methods and Equipment Specifications for 

Stationary Sources” January 1991, as amended through Supplement 3 (October 1, 1997), which is incorporated by reference in 

COMAR 26.11.01.04C.

B. Bulk Gasoline Plants.
(1) Applicability. Section B (2) of this regulation applies to a person owning or operating a bulk gasoline plant with a daily 

throughput of 4,000 gallons (15,140 liters) or greater.

(2) Equipment Standards.

(a) The owner or operator of a bulk gasoline plant shall:

(i) Equip the loading rack with a vapor balance system which shall be properly installed, maintained, and used;

(ii) Equip the loading rack with a top submerged or bottom loading system; and

(iii) Comply with the leak-tight requirements as specified in §A (1) (b) of this regulation.

(b) Stage I Vapor Recovery. A person who owns or operates a bulk plant may not cause or permit gasoline to be 

unloaded from a tank truck or trailer into a stationary storage tank unless the loading system is equipped with a vapor balance line 

that shall be properly installed, maintained, and used.

C. Small Storage Tanks.

(1) Applicability. This section applies to a person who owns or operates:

(a) A gasoline storage tank that has a tank capacity greater than 2,000 gallons but less than 40,000 gallons; or

(b) A gasoline tank truck used to transfer gasoline into a storage tank that is listed in §C (1) (a) of this regulation.

(2) Stage I Vapor Recovery. An owner or operator of a gasoline tank truck or an owner or operator of a stationary storage 

tank subject to this regulation may not cause or permit gasoline to be loaded into a stationary tank unless the loading system is 

equipped with a vapor balance line that is properly installed, maintained, and used.

D. General Standards. A person may not cause or permit gasoline or VOC having a TVP of 1.5 psia (10.3 kilonewtons/square 

meter) or greater to be loaded into any tank truck, railroad tank car, or other contrivance unless the:

(1) Loading connections on the vapor lines are equipped with fittings that have no leaks and that automatically and 

immediately close upon disconnection to prevent release of gasoline or VOC from these fittings; and

(2) Equipment is maintained and operated in a manner to prevent avoidable liquid leaks during loading or unloading 

operations.

E. Alternative Compliance Procedures. In lieu of satisfying the requirements of §D (1) of this regulation, a person may\

instead utilize:

(a) An overhead loading rack installation which transfers VOC other than gasoline having a TVP of 1.5 psia (10.3 

kilonewtons/square meter) from railroad tank car to tank trucks, or vice versa, using drip pans and other spill control equipment 

to limit the release of any product during post loading disconnections and any one of the following control practices or 

combination thereof:

(i) Walking the hose clear of fluids;

(ii) Running a pump to clear the line of fluids; or

(iii) Application of inert gas to clear the line of fluids; or

(b) An alternative equivalent vapor containment method approved by the Department and the EPA as a revision to the 

Maryland State Implementation Plan.
05 Gasoline Leaks from Tank Trucks.

A. Equipment Standards. A person may not allow a gasoline tank truck to be filled or emptied unless the tank has been 

certified as capable of sustaining a pressure change of not more than 3 inches of water in 5 minutes when pressurized to a gauge 

pressure of 18 inches of water (4,479 kilonewtons/square meter), or evacuated to a gauge pressure of 6 inches of water (1,493

kilonewtons/square meter), during a test, according to the procedure referenced in §B (2) of this regulation.

B. Method of Compliance. A person who owns or operates a gasoline tank truck subject to this regulation shall:

(1) Conduct a certification test annually, in accordance with the test method referenced in §B (2) of this regulation;

(2) Use the certification test procedures as prescribed in Method 1007 of the Department’s Technical Memorandum 91-01,

“Test Methods and Equipment Specifications for Stationary Sources” January 1991, as amended through Supplement 3 (October 

1, 1997), which is incorporated by reference in COMAR 26.11.01.04C; and

(3) Complete any needed repairs, and retest within 15 days of the original test date.

C. Determination of Compliance.

(1) A person who owns or operates a gasoline tank truck shall display the certification test expiration date on the truck. This 

expiration date shall be placed near the Department of Transportation Certification plate required by 40 CFR §178.340-10B.

(2) The Department may at any time monitor gasoline tank trucks for leak-tight conditions using the procedures described 

in Method 1008 of the Department’s Technical Memorandum 91-01, “Test Methods and Equipment Specifications for Stationary 

Sources” January 1991, as amended through Supplement 3 (October 1, 1997),which is incorporated by reference in COMAR 

26.11.01.04C.

D. Record Keeping and Reporting.

(1) A person who owns or operates a gasoline tank truck shall:

(a) Maintain records of all tests, repairs, and retests for at least 2 years after the respective dates of completion;

(b) Submit to the Department, upon request, copies of certification test records from tests required in Regulation .04A 

(3) (a) of this chapter.

(2) The records shall contain the following information:

(a) Gasoline tank truck tank number;

(b) Date of test;

(c) Date and type of repair, if applicable;

(d) Date of retest, if applicable;

(e) The initial test pressure and the time of the reading;

(f) The final test pressure and the time of the reading;

(g) The initial test vacuum and the time of the reading;

(h) The final test vacuum and the time of the reading.
FINAL ACTION ON REGULATIONS 

800

MARYLAND REGISTER, VOLUME 41, ISSUE 14, FRIDAY, JULY 11, 2014 

Title 26 

DEPARTMENT OF THE 

ENVIRONMENT 

Subtitle 08 WATER POLLUTION 

26.08.05 Certification of State Water Quality 

Laboratories 

Authority: Environment Article, Title 9, Subtitle 10, Annotated Code of 

Maryland 

Notice of Final Action 

[14-081-F-I] 

On June 12, 2014, the Secretary of the Environment adopted the 

repeal of existing Regulations .01—.16 and new Regulations .01—

.18 under COMAR 26.08.05 Certification of State Water Quality 

Laboratories. This action, which was proposed for adoption in 41:7 

Md. R. 435—441 (April 4, 2014), has been adopted as proposed. 

Effective Date: July 21, 2014. 

ROBERT M. SUMMERS, Ph.D. 

Secretary of the Environment 

Subtitle 11 AIR QUALITY 

26.11.13 Control of Gasoline and Volatile 

Organic Compound Storage and Handling 

Authority: Environment Article, §§1-101, 1-404, 2-101—2-103, 2-301—2-

303, 10-102, and 10-103, Annotated Code of Maryland 

Notice of Final Action 

[14-108-F] 

On June 18, 2014, the Secretary of the Environment adopted 

amendments to Regulations .04 and .05 under COMAR 26.11.13 

Control of Gasoline and Volatile Organic Compound Storage 

and Handling. This action, which was proposed for adoption in 41:8 

Md. R. 490—491 (April 18, 2014), has been adopted as proposed. 

Effective Date: July 21, 2014. 

ROBERT M. SUMMERS, Ph.D. 

Secretary of the Environment 
PROPOSED ACTION ON REGULATIONS 

490

MARYLAND REGISTER, VOLUME 41, ISSUE 8, FRIDAY, APRIL 18, 2014

Title 26 

DEPARTMENT OF THE

ENVIRONMENT 

Subtitle 11 AIR QUALITY 

26.11.13 Control of Gasoline and Volatile 

Organic Compound Storage and Handling 

Authority: Environment Article, §§1-101, 1-404, 2-101—2-103, 2-301—2-

303, 10-102, and 10-103, Annotated Code of Maryland 

Notice of Proposed Action 

[14-108-P]

The Secretary of the Environment proposes to amend Regulations 

.04 and .05 under COMAR 26.11.13 Control of Gasoline and 

Volatile Organic Compound Storage and Handling.

Statement of Purpose 

The purpose of this action is to provide an alternative equivalent 

vapor recovery method for the transfer of high vapor pressure 

materials and to amend incorrect references. 

This action will be submitted to the U.S. Environmental Protection 

Agency (EPA) for approval as part of Maryland’s State 

Implementation Plan. 

Background 

COMAR 26.11.13.04 establishes requirements for the use of 

automatic disconnections for the transfer of gasoline and VOCs with 

a total vapor pressure greater than 1.5 psia. Automatic disconnections 

are typically referred to in the industry as dry disconnects. Affected 

sources in Maryland do use dry disconnects on transfer equipment 

used for the handling of gasoline and fuel grade ethanol products 

(which have vapor pressures of greater than 1.5 psia). These products 

are typically transported in tank trucks meeting the U.S. Department 

of Transportation (US DOT) specifications as a MC306 or MC406 

type cargo tank. The fuel industry has adopted the use of dry 

disconnect fittings for loading and unloading hose applications. 

Affected sources are limited to using dry disconnects on these 

products to accommodate the tank truck connection fittings on the 

MC306/406 cargo tanks. 

The handling of other flammable liquids in tank trucks is not so 

clearly defined for the loading connections. These products are 

handled in US DOT MC407 cargo tanks. The motor carrier and 

chemical industries do not have an industry standard for the hose 

connections and trailer fittings beyond regulated safety venting 

devices. Sources that transfer fuels and liquids do not operate the 

motor carrier fleets or direct or coordinate the tank truck set up or 

maintenance. As such affected sources are required to have a high 

degree of flexibility as to the product and vapor return connections 

necessary to safely transfer the ordered product. The daily variation 

for tank truck connection type and size make the development of a 

standard transfer hose connection challenging. Many motor carriers 

use a variation of a cam lock “quick connector” type fitting to allow 

them to meet the end receiver transfer connections. Affected sources 

in Maryland maintain an inventory of the most commonly used 

connections to meet daily operating conditions. 

Affected sources in Maryland typically only transfer one product 

with a vapor pressure greater than 1.5 psia at a Baltimore facility. 

This product is hexane, for which typically approximately 1.5 million 

gallons are transferred annually. This product is transferred using 

vapor balance, which has an estimated combined capture and control 

efficiency of 98.7 percent using EPA AP-42 factors. The total volatile 

organic compounds (VOC) emissions associated with this transfer are 

estimated as approximately 114 pounds. 

This transfer quantity equates to approximately 53 tank cars of 

material, and approximately 215 truckloads of material. The tank 

trucks that are used to transport this material are not equipped with 

fittings that will accommodate dry disconnects. Because these tank 

trucks are not owned or operated by transfer facilities, it is outside of 

affected sources control to equip the tank trucks with such fittings. 

Sources Affected and Location 

The amendments affect the TRANSFLO Terminal Services, Inc. 

facility located in Baltimore City. 

Requirements 

The amendments provide an alternative equivalent vapor recovery 

method for the transfer of high vapor pressure materials that must be 

approved by the Department and the EPA. 

Expected Emissions Reductions 

Minimal emission reductions from existing sources in Maryland 

are expected as a result of adopting the proposed amendments. Air 

quality emission benefits will continue to be maintained with the help 

of custom procedures in place as an alternative to the use of dry 

disconnects for the transfer of high vapor pressure materials. The 

affected facility has developed a custom transloading operation for 

high vapor pressure materials such as hexane that involves an 

elevated platform, vapor balance and a “fail-closed” configuration 

which turns off the pump and ceases flow should there be a leaking 

connection, valve, or hose. Liquid pump(s) are used to empty the 

hoses upon completion of the transfer operation which minimizes 

releases to the environment (i.e., spills and evaporation). 

Comparison to Federal Standards 

There is no corresponding federal standard to this proposed action. 

Estimate of Economic Impact 

The proposed action has no economic impact. 

Economic Impact on Small Businesses 

The proposed action has minimal or no economic impact on small 

businesses. 

Impact on Individuals with Disabilities 

The proposed action has no impact on individuals with disabilities. 

Opportunity for Public Comment 

The Department of the Environment will hold a public hearing on 

the proposed action on June 3, 2014 at 10 a.m. at the Department of 

the Environment, 1800 Washington Boulevard, 1st Floor Conference 

Rooms, Baltimore, Maryland 21230-1720. Interested persons are 

invited to attend and express their views. Comments may be sent to 

Randy Mosier, Chief, Regulation Development Division, Air and 

Radiation Management Administration, Department of the 

Environment, 1800 Washington Boulevard, Suite 730, Baltimore, 

Maryland 21230-1720, or emailed to randy.mosier@maryland.gov. 

Comments must be received not later than June 3, 2014, or be 

submitted at the hearing. For more information, call Randy Mosier at 

(410) 537-4488. 

Copies of the proposed action and supporting documents are 

available for review at the following locations: 

• The Department of the Environment’s website at: 

http://www.mde.state.md.us/programs/regulations/air/Pages/req

comments.aspx 

• The Air and Radiation Management Administration; 

• Regional offices of the Department in Cumberland and 

Salisbury; 
PROPOSED ACTION ON REGULATIONS 

491

MARYLAND REGISTER, VOLUME 41, ISSUE 8, FRIDAY, APRIL 18, 2014 

• All local air quality control offices; and

• Local health departments in those counties not having 

separate air quality control offices. 

Anyone needing special accommodations at the public hearing 

should contact the Department’s Fair Practices Office at (410) 537-

3964. TTY users may contact the Department through the Maryland 

Relay Service at 1-800-735-2258. 

.04 Loading Operations. 

A. Bulk Gasoline Terminals. 

(1) — (2) (text unchanged) 

(3) Test Procedures. 

(a) Testing for leak-tight conditions, as required in 

§A(1)(b)(ii) of this regulation, shall be conducted as prescribed in 

Method 1008 of the Department’s Technical Memorandum 91-01, 

“Test Methods and Equipment Specifications for Stationary Sources”

[(]January 1991[)], as amended through Supplement 3 (October 1, 

1997), which is incorporated by reference in COMAR 26.11.01.04C. 

(b) The test procedures to determine mass emission rate 

compliance as required in §A(1)(a) of this regulation, shall be as 

prescribed in Method 1009 of the Department’s Technical 

Memorandum 91-01, “Test Methods and Equipment Specifications 

for Stationary Sources” [(]January 1991[)], as amended through 

Supplement 3 (October 1, 1997), which is incorporated by reference 

in COMAR 26.11.01.04C. 

B. — D. (text unchanged) 

E. Alternative Compliance Procedures. In lieu of satisfying the 

requirements of §D(1) of this regulation, a person may instead 

utilize: 

(a) An overhead loading rack installation which transfers 

VOC other than gasoline having a TVP of 1.5 psia (10.3 

kilonewtons/square meter) from railroad tank car to tank trucks, or 

vice versa, using drip pans and other spill control equipment to limit 

the release of any product during post loading disconnections and 

any one of the following control practices or combination thereof: 

(i) Walking the hose clear of fluids; 

(ii) Running a pump to clear the line of fluids; or 

(iii) Application of inert gas to clear the line of fluids; or 

(b) An alternative equivalent vapor containment method 

approved by the Department and the EPA as a revision to the 

Maryland State Implementation Plan. 

.05 Gasoline Leaks from Tank Trucks. 

A. (text unchanged) 

B. Method of Compliance. A person who owns or operates a 

gasoline tank truck subject to this regulation shall: 

(1) (text unchanged)

(2) Use the certification test procedures as prescribed in 

Method 1007 of the Department’s Technical Memorandum 91-01, 

“Test Methods and Equipment Specifications for Stationary Sources” 

[(]January 1991[)], as amended through Supplement 3 (October 1, 

1997), which is incorporated by reference in COMAR 26.11.01.04C; 

and 

(3) (text unchanged) 

C. Determination of Compliance. 

(1) (text unchanged) 

(2) The Department may at any time monitor gasoline tank 

trucks for leak-tight conditions using the procedures described in 

Method 1008 of the Department’s Technical Memorandum 91-01, 

“Test Methods and Equipment Specifications for Stationary 

Sources”, January 1991, as amended through Supplement 3 (October 

1, 1997),which is incorporated by reference in COMAR 

26.11.01.04C. 

D. (text unchanged)

ROBERT M. SUMMERS, Ph.D. 

Secretary of the Environment 

Title 33 

STATE BOARD OF 

ELECTIONS 

Subtitle 10 VOTING SYSTEMS —

SYSTEM REQUIREMENTS AND 

PROCEDURES 

33.10.02 AccuVote-TS

Authority: Election Law Article, §§2-102(b)(4), 2-202(b), 9-102(b) and (i), 

11-308, and 11-403(a)(1), Annotated Code of Maryland 

Notice of Proposed Action 

[14-103-P]

The State Board of Elections proposes to amend Regulation .07

under COMAR 33.10.02 AccuVote-TS. This action was considered 

by the State Board of Elections at its February 27, 2014, meeting, 

notice of which was given in accordance with State Government 

Article, §10-506(c), Annotated Code of Maryland. 

Statement of Purpose 

The purpose of this action is to clarify the procedure for 

determining the voting unit allocation to include the State

Administrator with consultation with the local boards. 

Comparison to Federal Standards 

There is no corresponding federal standard to this proposed action. 

Estimate of Economic Impact 

The proposed action has no economic impact. 

Economic Impact on Small Businesses 

The proposed action has minimal or no economic impact on small 

businesses. 

Impact on Individuals with Disabilities 

The proposed action has no impact on individuals with disabilities. 

Opportunity for Public Comment 

Comments may be sent to Erin Perrone, Administrative Assistant, 

State Board of Elections, P.O. Box 6486, Annapolis, MD 21401-

0486, or call 410-269-2845, or email to erin.perrone@maryland.gov, 

or fax to 410-974-2019. Comments will be accepted through May 19, 

2014. A public hearing has not been scheduled. 

.07 Number of Voting Units; Privacy Booths. 

A. Number of Voting Units Required. 

(1) For a regularly scheduled primary or general election, the 

[local board shall provide each polling place with: 

(a) The greater of: 

(i) One voting unit for each 200 registered voters 

assigned to a precinct, plus an additional voting unit for every 

fractional part of that number; or 

(ii) Two voting units; and 

(b) At least one voting unit with accessible voting 

equipment] State Administrator, in consultation with the local 

boards, shall determine the number of voting units assigned to each 

precinct. 
1

TECHNICAL SUPPORT DOCUMENT

Department of the Environment 

Amendments to COMAR 26.11.13.04 and .05 

Control of Gasoline and Volatile Organic Compound 

Storage and Handling

3-05-14 

Table of Contents 

I. TSD Summary pg. 2 

II. Fact Sheet pg. 3 

Purpose of the New Regulations/Amendments 

Submission to EPA as Revision to Maryland's SIP (or 111(d) Plan, or Title V 

Program) 

Background 

Affected Sources 

Requirements (Regulation Details) 

Expected Emissions Reductions 

Comparison to Federal Standards 

Economic Impact on Affected Sources, the Department, other State Agencies, 

Local Government, other Industries or Trade Groups, the Public 

Economic Impact on Small Businesses 

II. Proposed Regulation pg. 5 

III. Appendices pg. 6 

Appendix A – October 26, 2011 letter from TRANSFLO Inc. to MDE 

Appendix B – April 12, 2012 letter from TRANSFLO Inc. to MDE – 

Equivalency Determination and Additional Information Submittal 

Appendix C – October 8, 2013 Hexane Transfer and Emissions Worksheet 
2

TSD Summary for Amendments to COMAR 26.11.13 - Control of Gasoline and 

Volatile Organic Compound Storage and Handling - Alternative Compliance 

Procedures for Transloading Operations 

COMAR 26.11.13.04 establishes requirements for the use of automatic disconnections 

for the transfer of gasoline and VOCs with a total vapor pressure greater than 1.5 psia. 

Affected sources in Maryland do use dry disconnects on transfer equipment used for the 

handling of gasoline and fuel grade ethanol products (which have vapor pressures of 

greater than 1.5 psia). The handling of other flammable liquids (such as Hexane) in tank 

trucks is not so clearly defined for the loading connections and an alternative to the 

requirement of utilizing dry disconnects on transfer equipment was needed by affected 

sources. 

The development of COMAR 26.11.13.04E - Alternative Compliance Procedures are 

based upon technical and economic analysis of the transloading operations between rail 

tank cars and cargo tank trucks. Existing COMAR standards for cargo tank trucks that 

transfer gasoline, ethanol and other fuels are able to be met by industry as these 

operations and equipment are standardized throughout the affected industry. COMAR 

regulation 26.11.13.04D for loading connections that automatically close upon 

disconnection can be met for these specific operations. 

For other flammable VOC containing liquids the standards for transloading connections 

on cargo tank trucks have not been standardized. COMAR 26.11.13.04E Alternative 

Compliance Procedures provide the operational flexibility where connections on cargo 

tank trucks have not been standardized and adaptive connections that automatically close 

are not available. 

Different commodity materials are involved in transloading operations between rail tank 

car and cargo tank truck. These operations provide considerable transportation cost and 

emission savings, allowing for the majority of the transportation to be performed by rail, 

with the last few miles being accomplished by truck. 

1. Vapor balance practices are used to transload materials with vapor pressure 

greater than 1.5 psia. Affected sources in Maryland typically only transfer one 

product, Hexane, with a vapor pressure greater than 1.5 psia at a Baltimore 

facility. The amendments to COMAR 26.11.13 allows for better control of VOC 

emissions and hazardous air pollutants (HAPs), and as a result, provides air 

quality benefits and reduces worker exposure to HAPs. With vapor balance 

practices, safety standards are also met. A vapor balance system has a control 

efficiency of approximately 98.7%. 

The alternative compliance procedures for transloading operation for high vapor pressure 

materials involve an elevated platform, vapor balance and a “fail-closed” configuration 

which turns off the pump and ceases flow should there be a leaking connection, valve, or 

hose. Liquid pump(s) are used to empty the hoses upon completion of the transfer 

operation which minimizes releases to the environment (i.e., spills and evaporation). 
3

Facts About...

Department of the Environment 

Amendments to COMAR 26.11.13.04 and .05 

Control of Gasoline and Volatile Organic Compound 

Storage and Handling

11/05/13 

Purpose of New Regulation/Amendment 

The primary purpose of this amendment is to provide an alternative equivalent vapor 

recovery method for the transfer of high vapor pressure materials and to amend incorrect 

references from regulations .04 and .05. 

Submission to EPA as Revision to Maryland's SIP (or 111(d) Plan, or Title V 

Program) 

This action will be submitted to the U.S. Environmental Protection Agency (EPA) for 

approval as part of Maryland's State Implementation Plan. 

Background 

COMAR 26.11.13.04 establishes requirements for the use of automatic disconnections 

for the transfer of gasoline and VOCs with a total vapor pressure greater than 1.5 psia. 

Automatic disconnections are typically referred to in the industry as dry disconnects. 

Affected sources in Maryland do use dry disconnects on transfer equipment used for the 

handling of gasoline and fuel grade ethanol products (which have vapor pressures of 

greater than 1.5 psia). These products are typically transported in tank trucks meeting the 

U.S. Department of Transportation (US DOT) specifications as a MC306 or MC406 type 

cargo tank. The fuel industry has adopted the use of dry disconnect fittings for loading 

and unloading hose applications. Affected sources are limited to using dry disconnects on 

these products to accommodate the tank truck connection fittings on the MC306/406 

cargo tanks. 

The handling of other flammable liquids in tank trucks is not so clearly defined for the 

loading connections. These products are handled in US DOT MC407 cargo tanks. The 

motor carrier and chemical industries do not have an industry standard for the hose 

connections and trailer fittings beyond regulated safety venting devices. Sources that 

transfer fuels and liquids do not operate the motor carrier fleets or direct or coordinate the 

tank truck set up or maintenance. As such affected sources are required to have a high 

degree of flexibility as to the product and vapor return connections necessary to safely 

transfer the ordered product. The daily variation for tank truck connection type and size 

make the development of a standard transfer hose connection challenging. Many motor 

carriers use a variation of a cam lock “quick connector” type fitting to allow them to meet 

the end receiver transfer connections. Affected sources in Maryland maintain an 

inventory of the most commonly used connections to meet daily operating conditions. 
4

Affected sources in Maryland typically only transfer one product with a vapor pressure 

greater than 1.5 psia at a Baltimore facility. This product is hexane, for which typically 

approximately 1.5 million gallons are transferred annually. This product is transferred 

using vapor balance, which has an estimated combined capture and control efficiency of 

98.7 percent using EPA AP-42 factors. The total volatile organic compounds (VOC) 

emissions associated with this transfer are estimated as approximately 114 pounds. 

This transfer quantity equates to approximately 53 tank cars of material, and 

approximately 215 truckloads of material. The tank trucks that are used to transport this 

material are not equipped with fittings that will accommodate dry disconnects. Because 

these tank trucks are not owned or operated by transfer facilities, it is outside of affected 

sources control to equip the tank trucks with such fittings. 

Sources Affected and Location 

This amendment affects the TRANSFLO Terminal Services, Inc. facility located in 

Baltimore City. 

Requirements 

These amendments provide an alternative equivalent vapor recovery method for the 

transfer of high vapor pressure materials that must be approved by the Department and 

the EPA. 

Expected Emissions Reductions 

Air quality emission benefits will be achieved by providing an alternative to the use of dry 

disconnects for the transfer of high vapor pressure materials. The affected facility has 

developed a custom transloading operation for high vapor pressure materials such as 

hexane that involves an elevated platform, vapor balance and a “fail-closed” configuration 

which turns off the pump and ceases flow should there be a leaking connection, valve, or 

hose. Liquid pump(s) are used to empty the hoses upon completion of the transfer 

operation which minimizes releases to the environment (i.e., spills and evaporation). 

Economic Impact on Affected Sources, the Department, other State Agencies, Local 

Government, other Industries or Trade Groups, the Public

The proposed amendment will not incur an economic impact on affected sources, the 

Department, trade association or the public. 

Economic Impact on Small Businesses 

The affected sources do not fit the definition of “small business.” 

Is there an Equivalent Federal Standard to this Proposed Regulatory Action? 

There is no corresponding federal standard to this proposed action. 
5

Attached Document: Proposed Regulation 

Downloaded 7/31/13 

Draft 2/14/14 

Title 26 DEPARTMENT OF THE ENVIRONMENT 

Subtitle 11 AIR QUALITY 

Chapter 13 Control of Gasoline and Volatile Organic Compound Storage and 

Handling 

Authority: Environment Article,§§1-101, 1-404, 2-101—2-103, 2-301—2-303, 10-102, and 10-103, 

Annotated Code of Maryland 

.01 — .03 (text unchanged) 

.04 Loading Operations. 

A. Bulk Gasoline Terminals. 

(1) — (2) (text unchanged) 

(3) Test Procedures. 

(a) Testing for leak-tight conditions, as required in §A(1)(b)(ii) of this regulation, shall be conducted as 

prescribed in Method 1008 of the Department's Technical Memorandum 91-01, "Test Methods and Equipment 

Specifications for Stationary Sources" [(]January 1991[)], as amended through Supplement 3 (October 1, 1997), which 

is incorporated by reference in COMAR 26.11.01.04C. 

(b) The test procedures to determine mass emission rate compliance as required in §A(1)(a) of this regulation, 

shall be as prescribed in Method 1009 of the Department's Technical Memorandum 91-01, "Test Methods and 

Equipment Specifications for Stationary Sources" [(]January 1991[)], as amended through Supplement 3 (October 1, 

1997), which is incorporated by reference in COMAR 26.11.01.04C. 

B. — D. (text unchanged) 

E. Alternative Compliance Procedures. In lieu of satisfying the requirements of §D(1), a person may instead utilize: 

(a) An overhead loading rack installation which transfers VOC other than gasoline having a TVP of 1.5 psia 

(10.3 kilonewtons/square meter) from railroad tank car to tank trucks, or vice versa, using drip pans and other spill 

control equipment to limit the release of any product during post loading disconnections and any one of the following 

control practices or combination thereof: 

(i) Walking the hose clear of fluids; 

(ii) Running a pump to clear the line of fluids; 

(iii) Application of inert gas to clear the line of fluids; or 

(b) An alternative equivalent vapor containment method approved by the Department and the EPA as a 

revision to the Maryland State Implementation Plan. 

.05 Gasoline Leaks from Tank Trucks. 

A. (text unchanged) 

B. Method of Compliance. A person who owns or operates a gasoline tank truck subject to this regulation shall: 

(1) (text unchanged)

(2) Use the certification test procedures as prescribed in Method 1007 of the Department's Technical 

Memorandum 91-01, "Test Methods and Equipment Specifications for Stationary Sources" [(]January 1991[)], as 

amended through Supplement 3 (October 1, 1997), which is incorporated by reference in COMAR 26.11.01.04C; and 

(3) (text unchanged) 

C. Determination of Compliance. 

(1) (text unchanged) 

(2) The Department may at any time monitor gasoline tank trucks for leak-tight conditions using the procedures 

described in Method 1008 of the Department's Technical Memorandum 91-01, "Test Methods and Equipment 

Specifications for Stationary Sources", January 1991, as amended through Supplement 3 (October 1, 1997),which is 

incorporated by reference in COMAR 26.11.01.04C. 

D. (text unchanged)

.06 — .08 (text unchanged) 
6

Appendix A – October 26, 2011 letter from TRANSFLO Inc. to MDE 
Mitchell J. Hait, Ph.D., P.E., Inc.

404 Sebastian Square, St. Augustine, Florida 32095 

(904) 494-4200

October 26, 2011

Ms. Suna Yi Sariscak

Unit Lead Engineer

Chemical Unit

Air Quality Permits Program

Air and Radiation Management Administration

Maryland Department of the Environment

1800 Washington Boulevard

Baltimore, Maryland 21230

RE: Air Permit to Operate Renewal – TRANSFLO Baltimore, Maryland Facility, Permit ID 

510-03103 – Equivalency Determination

Dear Ms. Sariscak:

This letter requests an equivalency determination for the operations currently performed by

TRANSFLO Terminal Services, Inc. (TRANSFLO). This equivalency determination was 

discussed with you via telephone on October 25, 20111. This equivalency determination is 

requested for the requirements of COMAR 26.22.13.04D, which states:

General Standards. A person may not cause or permit gasoline or VOC having a TVP of 1.5

psia (1.3 kilonewtons/square meter) or greater to be loaded into any tank truck, railroad tank 

car, or other contrivance unless the:

(1) Loading connections on the vapor lines are equipped with fittings that have no leaks 

and that automatically and immediately close upon disconnection to prevent release of 

gasoline or VOC from those fittings; and

(2) Equipment is maintained and operated in a manner to prevent avoidable liquid leaks 

during loading or unloading operations.

TRANSFLO performs value added commodity transfer operations for their clients. TRANSFLO 

does not own or operate either the tank cars or the tank trucks that are used to transport the 

materials that are transloaded at the facility. Similarly, TRANSFLO does not own the materials

that are transferred. Typically, TRANSFLO owns the equipment used to transfer the materials, 

 

1 Teleconference with Ms. Lisa Wiedemann, TRANSFLO HSE&Q Project Manager, Ms. Suna Yi Sariscak, MDE, and 

Dr. Mitchell Hait, consultant to TRANSFLO. 
MDE October 26, 2011

Ms. Suna Yi Sariscak

Page 2 of 4

although in certain situations TRANSFLO will use customer owned equipment (provided the 

equipment meets or exceeds TRANSFLO’s internal requirements). This distinction of ownership 

of the tank cars and tank trucks is an essential element of the reason for this request.

The tank cars and tank trucks are designed to have certain types of fittings, which are considered 

industry standard for a particular type of product (commodity) or classification of tank car or tank 

truck. TRANSFLO is limited by the various available fittings (e.g., locations, sizes, and types) 

that are on the various tank cars and tank trucks. TRANSFLO has developed loading procedures 

that balance the Health, Safety, Environment, and Quality concerns associated with their value 

added transloading operations. TRANSFLO believes that these procedures are amongst the best, if 

not the best, in their industry.

COMAR 26.22.13.04D requires the transfer of materials with a vapor pressure of at least 1.5 psia 

using fittings that have automatic disconnections, and to maintain and operate the fittings to 

prevent avoidable liquid leaks. After a transfer of material is complete, TRANSFLO procedures 

include clearing the hoses of material to prevent a release. TRANSFLO procedures also include

performing daily sensory (i.e., visual and olfactory) inspections of their transfer operations to 

identify possible leaks, and to correct these leaks prior to proceeding with transfer operations. 

TRANSFLO believes their current methods meet the intent of these requirements. TRANSFLO 

has reviewed their records for the previous two year period, and they had identified zero (0)

situations requiring additional attention associated with the approximately 8,750 transfer 

operations (i.e., individual tank truck loads). This metric is provided to support the assertion that 

TRANSFLO has an active and effective program for leak identification and correction. 

TRANSFLO also performs periodic inspections of hoses and fittings, which they believe to also 

contribute to their successful program.

TRANSFLO is requesting an equivalency determination for the use of the automatic 

disconnections, which are typically referred to in the industry as dry disconnects. TRANSFLO 

does use dry disconnects on transfer equipment used for the handling of gasoline and fuel grade 

ethanol products (which have vapor pressures of greater than 1.5 psia). These products are 

typically transported in tank trucks meeting the U.S. Department of Transportation (US DOT) 

specifications as a MC306 or MC406 type cargo tank. The fuel industry has adopted the use of 

dry disconnect fittings for loading and unloading hose applications. TRANSFLO is limited to 

using dry disconnects on these products to accommodate the tank truck connection fittings on the 

MC306/406 cargo tanks.

The handling of other flammable liquids in tank trucks is not so clearly defined for the loading 

connections. These products are handled in US DOT MC407 cargo tanks. The motor carrier and 

chemical industries do not have an industry standard for the hose connections and trailer fittings 

beyond regulated safety venting devices. As stated above, TRANSFLO does not operate the motor 

carrier fleets or direct or coordinate the tank truck set up or maintenance. As such TRANSFLO is 

required to have a high degree of flexibility as to the product and vapor return connections 

necessary to safely transfer the ordered product. The daily variation for tank truck connection type 

and size make the development of a standard transfer hose connection challenging. Many motor 

carriers use a variation of a cam lock “quick connector” type fitting to allow them to meet the end 

receiver transfer connections. TRANSFLO maintains an inventory of the most commonly used 

connections to meet daily operating conditions. 
MDE October 26, 2011

Ms. Suna Yi Sariscak

Page 3 of 4

Connections on tank cars are also variable based upon tank car owner or shipper tank car 

configuration specifications. Dry disconnect type fittings are not used in the rail industry on tank 

cars. The most typical connections are a threaded fitting of varying sizes. From the threaded 

connection TRANSFLO typically uses an adaptor type fitting for threaded to cam lock to allow 

quick hose connections for product transfers. 

The TRANSFLO transfer procedures and processes use various methods to clear hoses at the end 

of liquid transfers to limit the amount product remaining in any transfer hose. These include 

walking the hose clear, running the pump to clear the line, or application of inert gas to clear the 

line. The use of drip pans and other spill control equipment are intended to further limit the 

release of any product during post loading disconnections.

During the past 12-months, TRANSFLO has transferred one product with a vapor pressure greater 

than 1.5 psia at the Baltimore facility. This product is hexane, for which approximately 220 

thousand gallons were transferred during this 12-month period. This product is transferred using 

vapor balance, which has an estimated combined capture and control efficiency of 98.7 percent2. 

The total volatile organic compounds (VOC) emissions associated with this transfer are estimated 

as approximately 6 pounds. 

This transfer quantity equates to approximately 8 tank cars of material, and approximately 30 

truckloads of material. The tank trucks that are used to transport this material are not equipped 

with fittings that will accommodate dry disconnects. Because these tank trucks are not owned or 

operated by TRANSFLO, it is outside of TRANSFLO’s control to equip the tank trucks with such 

fittings. Additionally, the tank trucks that are used for a particular commodity will vary, based on 

the customer who is receiving the material, the contract carrier’s availability of tank trucks, and the 

like. Because TRANSFLO is limited in using fittings that work with the industry standard trucks, 

TRANSFLO is requesting this equivalency determination. 

For this liquid hexane product, TRANSFLO uses the liquid pump(s) to empty the hoses upon 

completion of the transfer operation. This practice is performed to transfer the maximum practical 

quantity of the customer’s product, and to minimize releases to the environment (i.e., spills and 

evaporation). 

We believe that the combined use of vapor balance and the operational practice of clearing the 

liquid transfer lines is “equivalent” to the COMAR 26.11.13.04D rule requirement. Per our 

conversation, we request that you review this request with the appropriate parties in your agency. 

Should the MDE concur, we request that our operating permit include provisions to use our current 

operational practices of vapor balance combined with clearing the liquid transfer lines as an 

equivalent method of meeting the requirements of COMAR 26.11.13.04D.

 

2 U.S. EPA AP-42, Section 5.2, June 2008. 
MDE October 26, 2011

Ms. Suna Yi Sariscak

Page 4 of 4

On behalf of TRANSFLO, we appreciate your consideration of this equivalency determination. 

Should you have any questions on any of the items in this request, please contact Dr. Mitchell Hait 

at haitinc@gmail.com or (904) 494-4200, or Ms. Lisa Wiedemann of TRANSFLO at 

lwiedemann@transflo.net or (904) 359-1337. 

Sincerely,

Mitchell J. Hait, P.E., Ph.D.

Principal / Senior Engineer

cc: Ms. Lisa Wiedemann, TRANSFLO HSE&Q Project Manager
10

Appendix B – April 12, 2012 letter from TRANSFLO Inc. to MDE – Equivalency 

Determination and Additional Information Submittal 
Mitchell J. Hait, Ph.D., P.E., Inc.

404 Sebastian Square, St. Augustine, Florida 32095 

(904) 494-4200

April 12, 2012

Mr. Husain Waheed

Permitting Manager

Ms. Suna Yi Sariscak

Unit Lead Engineer

Chemical Unit

Air Quality Permits Program

Air and Radiation Management Administration

Maryland Department of the Environment

1800 Washington Boulevard

Baltimore, Maryland 21230

RE: Air Permit to Operate Renewal – TRANSFLO Baltimore, Maryland Facility, Permit ID 

510-03103 – Equivalency Determination Additional Information Submittal

Dear Mr. Waheed and Ms. Sariscak:

This letter provides additional information in support of the rule equivalency determination1for 

the TRANSFLO Terminal Services, Inc. (TRANSFLO) Baltimore facility. Per our telephone 

conversation2, the U.S. EPA had requested additional cost and process information in support of 

our request. This additional information is presented in this letter and attachments. As discussed 

following in this letter, we believe that the use of dry disconnects for the transfer of high vapor 

pressure materials (such as hexane) is unreasonable based on cost, health and safety, and related 

environmental impacts. 

The use of dry disconnects for products such as gasoline and fuel grade ethanol is reasonable, as 

the trucking industry has developed appropriate infrastructure (e.g., connectors on gasoline 

delivery trucks) to provide for ready accommodation and use of these fittings. However, the 

infrastructure is not in place for other materials, such as hexane, as further described in this letter. 

Current Transloading Process Description 

TRANSFLO has developed a custom transloading operation for high vapor pressure materials such 

as hexane that balances environmental, safety, and product quality concerns. This transloading 

 

1 Equivalency determination dated October 26, 2011.

2 Telephone conversation of February 23, 2012 between Mr. Husain Waheed, Maryland DEP, and Mitchell Hait, 

TRANSFLO consultant.
MDE April 12, 2012

Mr. Waheed and Ms. Sariscak

Page 2 of 6

arrangement involves an elevated platform, and is described in the following text. The primary

environmental benefit from this unloading method is the “fail-closed” features of the equipment 

configuration. This transfer process was developed as a corrective action arising from an incident 

involving a leaking railcar bottom outlet valve adapter on a hexane railcar. 

A sketch of the current transloading operation is provided in Attachment 1. Pictures of the transfer 

operation, along with narrative descriptions are included in Attachment 2. These pictures also 

show some of the differences in the U.S. Department of Transportation (DOT) MC306/406 and 

MC307/407 specification tank trailers. As was discussed in the prior RACT equivalency 

determination request, hexane is typically transported using MC307/407 specification tank trailers. 

Gasoline and fuel grade ethanol is typically transported using MC306/406 specification tank 

trailers. 

The MC307/407 trailers are typically equipped with a single rear outlet valve and hose connection 

point at the ground level. Top fittings include a manway, washout connections, and vapor 

recovery valves. These trailers are widely used in chemical transportation and are often reloaded 

with different chemical products for backhauls, increasing the trailer usage and minimizing empty 

highway miles for the motor carrier. These trailers are rarely dedicated to any one product or 

shipper and thus require a high degree of flexibility in valve configuration. 

As a result the trailers are used by a wide variety of chemical and petrochemical shippers and

receivers. The standardization of outlet and hose fittings is not as common as in the gasoline/fuel 

oil business where MC306/406 trailers move between tank farms and motor fuel dispensing 

locations such service stations and convenience stores. While the use of dry disconnect fittings is 

common in the gasoline/motor fuels industry they are not commonly used in general chemical 

transportation.

Product Transfer Involving Dry Disconnects

Assuming that a dry disconnect fitting is to be used, it would be connected to the trailer outlet that 

is located at the bottom of the trailer. Vapor recovery connections and high level alarm overfill 

protection devices are applied to the top of the trailer. Due to pump configuration and piping 

configuration limitations, the use of dry disconnects on the current piping configuration is not 

practical. The loader would be forced to move between the rear of the trailer and the top of the 

transfer unit and railcar. Chemical handling industry best practice is to limit the distance between 

critical operations and product control points to ensure maximum operator transfer control and 

attendance.

The transfer platform pump would transfer product from the top of the tank car to the bottom of 

the tank trailer through the dry disconnect fitting. When full the tank trailer valve would be closed 

and the dry disconnect would be closed. Two serious conditions would then exist:

1. When the dry disconnect fittings on the end of the hose and the truck valve to dry 

disconnect female fitting are separated, the liquid transfer hose would remain full of 

product. The pump cannot clear the hose if the pump is mounted on the top of the 

platform. The trapped liquid would make the hoses difficult to handle due to adding 

approximately 75 pounds to a typical 30 foot long hose. The hoses would also be a 
MDE April 12, 2012

Mr. Waheed and Ms. Sariscak

Page 3 of 6

potential source of product spills. Additionally, it is not good industry practice to 

leave transfer equipment and hoses full of product when not being used.

 

2. When the truck valve to dry disconnect fitting is removed it would contain up to 1 

gallon of product that would require draining, and probably disposal as hazardous 

waste. 

It is important to note that this overall process of transloading material between railcars and trucks 

differs considerably from the transfer of material from a delivery truck to a fixed stationary storage 

tank. For example, if material was to be loaded into a fixed storage tank, the dry disconnect 

adapter would be permanently installed on the storage tank, and not require installation, removal, 

and draining with each load transferred. 

If a ground mounted pump configuration is used, the main concern is the railcar (tank car) 

eduction pipe can no longer be used to fully drain the railcar due to pumping limitations. Hence, 

the bottom valve on the railcar would be utilized for the liquid supply. In the event of a 

component failure, this configuration is “fail-open” as opposed to the “fail-closed” configuration 

of the elevated platform. A secondary concern involves the truck valve to dry disconnect fitting 

that will retain up to one gallon of product that would need to be disposed of as hazardous waste. 

Cost Information

The product transfer involves two product hoses. One hose connects from the railcar to the pump, 

and the second hose connects from the pump to the truck. The cost of each hose equipped with a 

dry disconnect is $1,700, for a total of $3,400. Hoses typically have a lifetime of four years.

The capital costs also involve the purchase of dry disconnect adapters for the receiving truck and 

the railcar false come lid. The railcar false dome lid requires a 3 inch adapter at a cost of $900. 

The truck requires a 4 inch adapter at a cost of $1,000 each. Two adapters are required to assure 

that one adapter will be available for use on site as it is likely that a truck will depart without first 

removing the adapter. 

The use of dry disconnects involves installation and removal of an additional adapter to the 

delivery truck, adding time to the overall process. It is expected that these two steps will add a 

total of 10 minutes to each transfer process (i.e., 5 minutes each for adding and removing the 

adapters). Using a typical operator labor cost of $21.03 per hour, and a 60 percent overhead rate, 

this equates to an additional cost of approximately $5 per load. 

During calendar year 2011, TRANSFLO has transferred one product with a vapor pressure greater 

than 1.5 psia at the Baltimore facility. This product is hexane, for which approximately 1.67

million gallons were transferred during this 12-month period. This product is transferred using 

vapor balance, which has an estimated combined capture and control efficiency of 98.7 percent3. 

The total volatile organic compounds (VOC) emissions associated with this transfer are estimated 

as approximately 127 pounds. This quantity is approximately 60 railcars, or 180 truckloads of 

hexane. Potential costs are estimated based on a potential throughput of 200 railcars per year. 

 

3 U.S. EPA AP-42, Section 5.2, June 2008. 
MDE April 12, 2012

Mr. Waheed and Ms. Sariscak

Page 4 of 6

Air Quality Impacts

The dry disconnects are designed to minimize liquid leaks during the connection and 

disconnection of hoses during transfer operations. To fully realize these benefits, the receiving 

container (in this case cargo truck) needs to be equipped with the dry disconnect fittings. As 

discussed previously, the use of dry disconnects for the transfer of hexane at the Baltimore facility 

will likely increase air quality emissions, as opposed to decrease the emissions. The increase will 

be due to the handling (e.g., draining and transfer operations) of residual liquid that remains in the 

dry disconnect adapter (fitting), pump, and liquid lines. 

Cost Effectiveness

Typically a cost effectiveness value is expressed in terms of cost (e.g., dollars) per quantity (e.g., 

ton) of air emissions reduced. For example, cost effectiveness values in the range of $5,000 to 

$7,000 per ton of VOC emissions reduced are considered reasonable4costs. 

In this particular case, the use of dry disconnects is expected to increase air quality emissions, as 

opposed decreasing emissions. This increase in emission leads to a negative value for cost 

effectiveness, which would not be considered a reasonable cost. 

Per the request of the MDE, annualized cost increases are estimated using the standard U.S. EPA 

control equipment cost format. The values presented following are the additional costs associated 

with the use of dry disconnects. The detailed cost data are provided in Tables 1 through 3 of 

Appendix 3. Table 1 provides the actual case for annualized costs, which is $3,676 per year based 

on 60 railcars per year. Table 2 provides the potential case for annualized costs, which is $6,256

per year based on 200 railcars per year. Table 3 provides underlying site specific cost data, such as 

the capital recovery cost based on the four year equipment lifetime, and operator labor costs. 

These costs do not include the likely cost for product waste disposal, which is discussed in the 

following section. 

Other Environmental, Health and Safety, and Quality Concerns

As discussed previously, the current equipment configuration provides a “fail-closed” 

configuration. Should there be a leaking connection, valve, hose, or other component, the flow 

ceases when the pump is turned off. The dry disconnects would likely cause a change in the 

configuration of the transfer, as discussed previously. Two options for the transfer were identified 

earlier in this letter.

For the transfer option that uses the elevated platform, the pump would not be able to clear the 

hoses at the end of the transfer due to the dry disconnect fittings. Hence, the product hoses would 

be full of liquid at the end of the operation. Assuming a 30 foot product hose (typical length), 

approximately 11 gallons of liquid product will be retained, adding approximately 75 pounds to 

the weight of each hose. This material retention would violate TRANSFLO’s established 

operating procedures. It also introduces the following concerns:

 

4 Reasonable in the sense of RACT or BACT control technology evaluation. The cost effectiveness determination is a

case-by-case evaluation, with no bright line for establishing cost controls. The cost values expressed are typical based 

on general experience, and are not intended to imply what would be considered reasonable in this particular situation. 
MDE April 12, 2012

Mr. Waheed and Ms. Sariscak

Page 5 of 6

1. Health and safety concerns associated with the handling of a heavy hose;

2. The addition of a male segment of the dry disconnect to the false dome will add weight to 

the false dome lid, and will decrease the clearance to the “bathtub” spill containment 

structure on the top of the truck. The added weight and reduced clearance adversely affect 

worker ergonomic issues. This item is compounded with the elevated platform having 

restricted space.

3. Product hold up in the hose has the potential to add to product quality and cross 

contamination issues;

4. Clearing of product lines would be accomplished away from the receiving vessel, and the 

product cleared would likely be disposed of as hazardous waste, considerably increasing 

the amount of hazardous waste generated from the site;

5. The truck valve to dry disconnect fitting will retain up to one gallon of product that would 

need to be disposed of as hazardous waste; 

6. Increasing the likelihood of spills and leaks due to the additional number of valves and 

handling issues with the hoses and the fitting that will likely retain liquid; and,

7. Cost of the product itself that is retained in the hoses and potentially disposed of as waste. 
MDE April 12, 2012

Mr. Waheed and Ms. Sariscak

Page 6 of 6

Closing

On behalf of TRANSFLO, we appreciate your consideration of this equivalency determination. 

Should you have any questions on any of the items in this request, please contact Dr. Mitchell Hait 

at haitinc@gmail.com or (904) 494-4200, or Ms. Becky Heilman of TRANSFLO at 

bheilman@transflo.net or (904) 359-1337. 

Sincerely,

Mitchell J. Hait, P.E., Ph.D.

Principal / Senior Engineer

cc: Ms. Becky Heilman, TRANSFLO HSE&Q Project Manager

Ms. Jan Barnes, Director, HSE&Q

Attachments

1 – Current Transloading Configuration (Sketch)

2 – Transloading Equipment and Fittings

3 – Cost Data Tables
Attachment 1 – Current Transloading Configuration (Sketch)
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General Arrangement- Hexane 

Mitchell J. Hait, Ph.D., p .E., Inc. t-------==-T=-=-=ran=s=-=load--=--ln=-g o_:pe:....__ratlo_ns __ ---! 

TRANSFLO Tannlnallen1cae, Inc. 

Baltlrncn, Maryland 

FIGURE: 

1 
Attachment 2 – Transloading Equipment and Fittings
TF HS&E 4-2-12 1

TRANSFLO Terminal Services

Transloading Equipment and Fittings

Typical Transfer Platform

This unit has stairs to allow loaders to access top of tank car without climbing ladder. Tools and 

fittings are stored on top of unit. Unit has two “wings” that fold out to access tank car and truck. 

Hose jib holds hoses and limits need to pull hoses up car and across to truck. Pump is mounted on 

platform to increase suction capacity on partially loaded tank cars. Top mounted pump also allows 

hoses and fittings to fully drain by gravity into truck or rail tank car post loading. 
TF HS&E 4-2-12 2

Truck- MC407 Cargo Tank (trailer)

 

 MC 407 Trailer- no bottom fittings in center of trailer. MC306/406 trailer- multiple outlets.

MC407 tank trailer- single compartment, 

typically 5000-8000 gal. capacity.

These have a single rear outlet with truck 

valve.

If a dry disconnect was required it would 

have to be a 3” cam lock to dry disconnect 

adaptor fitting as these trucks do not use dry 

disconnect fittings. This would trap liquid 

inside fitting once pump was stopped and 

valves closed. 

Side view showing no belly valves on 

sides of trailers unlike a MC306 

gasoline type trailer.
TF HS&E 4-2-12 3

Truck fittings:

MC 407 Truck top connections:

All fitting in a “bath tub” for spill 

control.

Primary opening is large manway 

secured with screw type dogs.

Other fitting is an air line and safety 

vent assembly.

(Trailer is set up for air or nitrogen 

pressure unload.)
TF HS&E 4-2-12 4

False Manway Fitting For Application to Truck Manway

Truck False Manway with:

Vapor Recovery connection

Liquid tube insert connection

False manway “ears cutouts” for 

truck dogs to secure to truck.

Underside of false manway showing 

sealing gasket.

These fittings are stored on the top of 

the transfer platform for ease of 

handling and moving to the top of the 

tank truck.
TF HS&E 4-2-12 5

Rail tank car connections

Rail tank car adaptor fittings

2” threaded to cam lock male fitting 

(liquid)

1” threaded to cam lock male fitting 

(vapor return)

These fittings are stored on the top of 

the transfer platform.

Rail tank car fittings

Vacuum relief device

2” liquid eduction line valve

1” air/vapor valve
Attachment 3 – Cost Data Tables
Cost Items Cost Factorsa

Cost ($) 

DIRECT CAPITAL COSTS (DCC):

Purchased Equipment Cost (PEC)

Hoses w/ dry disconnects (two hoses 

total) John Scheeter, TRANSFLO $3,400

Rail Car Adapter 4" (two) John Scheeter, TRANSFLO $2,000

Manway Adapter 3" (one) John Scheeter, TRANSFLO $900

Auxiliary equipment Not Applicable $0

Total Equipment $6,300

Instrumentation and Controls Not Applicable $0

Freight 5% of "Total Equipment" $315

Taxes State / Local sales tax $378

Total PEC: $6,993

Direct Installation Costs (DIC)

Foundation and Structure Support 0% of PEC $0

Handling & Erection 0% of PEC $0

Electrical 0% of PEC $0

Piping 0% of PEC $0

Insulation for Ductwork 0% of PEC $0

Painting 0% of PEC $0

Total DIC: $0

Total DCC: PEC + DIC $6,993

INDIRECT CAPITAL COSTS (ICC):

Engineering 10% of PEC $699

Construction and Field Expenses 0% of PEC $0

Contractor Fees 0% of PEC $0

Start-up (Procedures) 2% of PEC $140

Performance Test 0% of PEC $0

Contingencies 3% of PEC $210

Total ICC: $1,049

TOTAL CAPITAL INVESTMENT (TCI): DCC + ICC $8,042

Table 1

Dry Disconnect

Annual Cost Data, Actual Case (60 Railcars per Year)

4/11/2012 TRANSFLO Baltimore Facility
Cost Items Cost Factorsa

Cost ($) 

Table 1

Dry Disconnect

Annual Cost Data, Actual Case (60 Railcars per Year)

DIRECT OPERATING COSTS (DOC):

Operating Labor

Operatorb 10 min / load x 600 loads / year x 

operator cost $/hr $701

Supervisor 15% of operator cost $105

Maintenance 

Labor Not Applicable

$0

Materials 100% of "Maintenance Labor" $0

Replacement Parts, Hoses / Valves (4-year lifetime)

Replacement Labor Included in "Maintenance Labor"

$0

Hoses / Disconnects (annualized) PEC * CRF $2,064

Utilities

Not Applicable Not Applicable $0

Total DOC: $2,871

INDIRECT OPERATING COSTS (IOC):

Overhead 60% of "Operating Labor", 

"Maint. Labor", & "Maint. 

Materials" $484

Property Taxes 1% of TCI $80

Insurance 1% of TCI $80

Administration 2% of TCI $161

Total IOC: $805

CAPITAL RECOVERY COSTS (CRC): Not Applicable (included in 

above) $0

ANNUALIZED COSTS (AC): DOC + IOC + CRC $3,676

Footnotes:

a

 Unless otherwise specified, factors and cost estimates reflect OAQPS Cost Manual, Section 6, Chapter 3, Sixth edition. 

b Operator labor based on incremental time required to connect / disconnect dry disconnect adapters on trucks

4/11/2012 TRANSFLO Baltimore Facility
Cost Items Cost Factorsa

Cost ($) 

DIRECT CAPITAL COSTS (DCC):

Purchased Equipment Cost (PEC)

Hoses w/ dry disconnects (two hoses 

total) John Scheeter, TRANSFLO $3,400

Rail Car Adapter 4" (two) John Scheeter, TRANSFLO $2,000

Manway Adapter 3" (one) John Scheeter, TRANSFLO $900

Auxiliary equipment Not Applicable $0

Total Equipment $6,300

Instrumentation and Controls Not Applicable $0

Freight 5% of "Total Equipment" $315

Taxes State / Local sales tax $378

Total PEC: $6,993

Direct Installation Costs (DIC)

Foundation and Structure Support 0% of PEC $0

Handling & Erection 0% of PEC $0

Electrical 0% of PEC $0

Piping 0% of PEC $0

Insulation for Ductwork 0% of PEC $0

Painting 0% of PEC $0

Total DIC: $0

Total DCC: PEC + DIC $6,993

INDIRECT CAPITAL COSTS (ICC):

Engineering 10% of PEC $699

Construction and Field Expenses 0% of PEC $0

Contractor Fees 0% of PEC $0

Start-up (Procedures) 2% of PEC $140

Performance Test 0% of PEC $0

Contingencies 3% of PEC $210

Total ICC: $1,049

TOTAL CAPITAL INVESTMENT (TCI): DCC + ICC $8,042

Table 2

Dry Disconnect

Annual Cost Data, Potential Case (200 Railcars per Year)

4/11/2012 TRANSFLO Baltimore Facility
Cost Items Cost Factorsa

Cost ($) 

Table 2

Dry Disconnect

Annual Cost Data, Potential Case (200 Railcars per Year)

DIRECT OPERATING COSTS (DOC):

Operating Labor

Operatorb 10 min / load x 600 loads / year x 

operator cost $/hr $2,103

Supervisor 15% of operator cost $316

Maintenance 

Labor Not Applicable

$0

Materials 100% of "Maintenance Labor" $0

Replacement Parts, Hoses / Valves (4-year lifetime)

Replacement Labor Included in "Maintenance Labor"

$0

Hoses / Disconnects (annualized) PEC * CRF $2,064

Utilities

Not Applicable Not Applicable $0

Total DOC: $4,483

INDIRECT OPERATING COSTS (IOC):

Overhead 60% of "Operating Labor", 

"Maint. Labor", & "Maint. 

Materials" $1,451

Property Taxes 1% of TCI $80

Insurance 1% of TCI $80

Administration 2% of TCI $161

Total IOC: $1,773

CAPITAL RECOVERY COSTS (CRC): Not Applicable (included in 

above) $0

ANNUALIZED COSTS (AC): DOC + IOC + CRC $6,256

Footnotes:

a

 Unless otherwise specified, factors and cost estimates reflect OAQPS Cost Manual, Section 6, Chapter 3, Sixth edition. 

b Operator labor based on incremental time required to connect / disconnect dry disconnect adapters on trucks

4/11/2012 TRANSFLO Baltimore Facility
Cost Item Comments

Sales Tax 6.00% Percent http://www.baltimorecountymd.gov/Agencies/ec

onomicdev/gateway/countygov/taxes.html

Labor

Operator $21.03 Dollars per hour

J. Scheeter TRANSFLO, $70 k / yr loaded, 60% 

OH rate per EPA Cost Manual

Maintenance $21.03 Dollars per hour

J. Scheeter TRANSFLO, $70 k / yr loaded, 60% 

OH rate per EPA Cost Manual

Utilities

Electricity $0.148 Dollars per kWh Not Used

Capital Recovery Factors (CRF):

Hoses

 (4 year life, 7% interest)

0.2952 Annual $ per Capital $

Note - Operator and Maintenance labor use the same rates as workers are cross trained.

TABLE 3

SITE-SPECIFIC COST DATA

Cost Factor and Units

4/11/2012 TRANSFLO Baltimore Facility
31

Appendix C – October 8, 2013 Hexane Transfer and Emissions Worksheet 
Table 1: Current Volumes / Railcars / Trucks

Baltimore, Maryland

Hexane Transfer

October 2013

Actual and Potential Transfer and Emission Rates

This worksheet provides annual throughput rates for supporting information to

the MDE Rule Amendment Fact Sheet

Parameter Value Units Notes / Source

Annual Hexane Transfer (Actual) 1,474,529 Gallons / year CY 2012

Annual Hexane Transfer (Actual) 1,326,332 Gallons / year 4/1/2012 through 3/31/2013

Annual Hexane Transfer (Actual) 1,330,681 Gallons / year 9/1/2012 through 8/31/2013

Average recent annual volume 1,377,181 Gallons / year Average of above values

Maximum volume, rounded up 1,500,000 Gallons / year CY 2012

Truck volume 7,000 gallons / truck Greg Rhoads

Trucks per year 215 Trucks / year (gal/yr) / (gal/truck)

Railcar volume 28,500 gallons / railcar typical

Railcars per year 53 railcars/year (gal/yr) / (gal/railcar)

Actual Emissions (Based on rounded up recent maximum value)

VOC Emission Factor (uncontrolled) 5.848314 lb / kgal AP-42 Section 5.2, Eqn. 1

Annual uncontrolled VOC emissions 8,772 lb / year AP-42 Section 5.2, Eqn. 1

Control efficiency (vapor balance) 98.7% percent AP-42 Section 5.2, NSPS level for truck inspection

Controlled VOC emissions 114 lb / year Uncontrolled * ( 1 - control efficiency)

Potential Emissions

Annual Hexane Transfer (Potential) 4,200,000 Gallons / year Based on 600 trucks / year, 7,000 gallons per truck

Annual uncontrolled VOC emissions 24,563 lb / year AP-42 Section 5.2, Eqn. 1

Control efficiency (vapor balance) 98.7% percent AP-42 Section 5.2, NSPS level for truck inspection

Controlled VOC emissions 319 lb / year Uncontrolled * ( 1 - control efficiency)

Table 1: Actual / Potential Throughput and Emissions Page 1 of 1
MARYLAND DEPARTMENT OF THE ENVIRONMENT 

1800 Washington Boulevard  Baltimore MD 21230 

410-537-3000  1-800-633-6101 

 Robert M. Summers, Ph.D. Secretary 

 Recycled Paper www.mde.state.md.us TTY Users 1-800-735-2258 

 Via Maryland Relay Service 

 

Martin O’Malley 

Governor 

Anthony G. Brown 

Lieutenant Governor 

 April 17, 2014 

CERTIFICATE OF PUBLICATION 

This is to certify that the “Maryland Department of the Environment (MDE) Notice of Public 

Hearing/Comment Period Concerning Proposed Amendments to Regulation .04 and .05 under COMAR 

26.11.13 Control of Gasoline and Volatile Organic Compound Storage and Handling” was published on 

MDE’s web site on April 17, 2014. It will remain posted on the site until June 4, 2014. The notice with a 

link to a technical supporting document may be found in the following web address: 

http://www.mde.state.md.us/programs/regulations/air/Pages/reqcomments.aspx

Web publication of the notice was at the request of Carolyn A. Jones, Regulations Coordinator of the Air and 

Radiation Management Administration of MDE. 

 By: 

 DIANA ALEGRE 

 MDE Webmaster 

 

Attachments: 

Copy of web page as published. 
Public Hearings, Meetings and Request for Comments

http://www.mde.state.md.us/programs/regulations/air/Pages/reqcomments.aspx[4/17/2014 2:16:34 PM]

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Air & Radiation Regulations Public Hearings, Meetings and Request for Comments

The Maryland Department of the Environment gives notice of Public Hearing/Comment Period Concerning

Proposed Amendments to Regulation .04 and .05 under COMAR 26.11.13 Control of Gasoline and Volatile Organic

Compound Storage and Handling

The Maryland Department of the Environment gives notice of public hearing/comment period concerning the following proposed action:

Amendments to Regulation .04 and .05 under COMAR 26.11.13 Control of Gasoline and Volatile Organic Compound Storage

and Handling to provide an alternative equivalent vapor recovery method for the transfer of high vapor pressure materials and to amend

incorrect references from regulations .04 and .05.

The regulatory actions listed above will be submitted to the U.S. EPA for approval as revisions to Maryland's State Implementation Plan.

The full text of the proposed amendments will appear in the Maryland Register at

http://www.dsd.state.md.us/MDRegister/mdregister.aspx on April 18, 2014.

Download the Technical Support Document here.

A public hearing on this action will be held on June 3, 2014 at 10 a.m. at the Department of the Environment, 1800 Washington

Boulevard, 1st Floor Conference Rooms, Baltimore, Maryland 21230-1720.

Comments must be received by 5 pm on June 3, 2014.

For more information or to submit comments, call/e-mail/ fax:

Randy Mosier, Chief, Regulation Development Division

Air Quality Planning Program

Air and Radiation Management Administration

Department of the Environment

1800 Washington Boulevard, Suite 730, Baltimore, Maryland 21230-1720

Telephone: (410) 537-4488

Email: randy.mosier@maryland.gov

Fax: (410) 537-4223

Notice of this hearing has been published in the Baltimore Sun; Cecil Whig; Cumberland Times-News; Frederick News-Post; Saint Mary's

Enterprise; Salisbury Daily Times; and the Washington Post.

PLEASE NOTE THAT BEGINNING OCTOBER 1, 2014, ALL PUBLIC HEARING NOTICES REGARDING REGULATION CHANGES WILL BE POSTED

SOLELY ON THE DEPARTMENT’S WEBSITE.

Randy Mosier may also be contacted to arrange for the receipt of future public hearing notices.

The Maryland Department of the Environment gives notice of Public Hearing/Comment Period Concerning

Proposed Changes to COMAR 26.11.09 Amendments for Biomass Fuel-Burning Equipment

The Maryland Department of the Environment gives notice of public hearing/comment period concerning the following proposed action:

Amendments to Regulation .01,.04, .06 & .07 under COMAR 26.11.09 Control of Fuel-Burning Equipment, Stationary Internal

Combustion Engines, and Certain Fuel-Burning Installations and new Regulation .12 Standards for Biomass Fuel-Burning

Equipment Equal to or Greater Than 350,000 Btu/hr under COMAR 26.11.09. The primary purpose of amendments and new

regulation are to:

1. Incorporate the definition of biomass into Regulation .01;

2. Establish that the provisions from regulations .04 Prohibitions of Certain New Fuel-Burning Equipment, .06 Control of Particulate

Matter, and .07 Control of Sulfur Oxides from Fuel-Burning Equipment do not apply to fuel-burning equipment installed after

March 1, 2014 that burns only biomass fuels;

3. Establish new regulation .12 Standards for Biomass Fuel-Burning Equipment

Equal to or Greater Than 350,000 Btu/hr which sets NOx and PM standards and requirements for biomass equipment where

federal standards are not established; and

4. Amend incorrect references from regulations .09 and .10.

Download the Technical Support Document

The regulatory actions listed above will be submitted to the U.S. EPA for approval as revisions to Maryland's State Implementation Plan.

The full text of the proposed amendments will appear in the Maryland Register at http://www.dsd.state.md.us/MDRegister/mdregister.aspx

on January 24, 2014.

Technical support documents and additional information are available on the Maryland Department of the Environment's website at the

following address: 

http://www.mde.state.md.us/programs/regulations/air/Pages/reqcomments.aspx

Public hearings on these actions will be held on February 26, 2014 at 10 a.m. at the Department of the Environment, 1800 Washington

Boulevard, 1st Floor Conference Rooms, Baltimore, Maryland 21230-1720.

Comments must be received by 5 pm on February 26, 2014.

For more information or to submit comments, call/e-mail/ fax:

Randy Mosier, Chief, Regulation Development Division

Air Quality Planning Program

Air and Radiation Management Administration

Department of the Environment

Maryland.gov Phone Directory State Agencies Online Services

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Public Hearings, Meetings and Request for Comments

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1800 Washington Boulevard, Suite 730, Baltimore, Maryland 21230-1720

Telephone: (410) 537-4488

Email: randy.mosier@maryland.gov

Fax: (410) 537-4223

Randy Mosier may also be contacted to arrange for the receipt of future public hearing notices.

Contact the Office | Accessibility | Privacy Notice

1800 Washington Boulevard, Baltimore, MD 21230 | (410) 537-3000
7/2/2014 Maryland.govMail - RE: Notice of Public Hearing/Comment Period

https://mail.google.com/mail/?ui=2&ik=a38dde8ea8&view=pt&cat=Carolyn%20Jones%2FTransflo%20Regs.&search=cat&th=14570feabb2e89fe&siml=14570fea... 1/2

Tiachia Soto -MDE- <tiachia.soto@maryland.gov>

RE: Notice of Public Hearing/Comment Period

1 message

Marsha Kennedy -MDE- <marsha.kennedy@maryland.gov> Thu, Apr 17, 2014 at 2:41 PM

To: John Benedict <John.A.Benedict@wv.gov>, Ali Mirzakhalili <ali.mirzakhalili@state.de.us>, Angelo Bianca

<angelo.bianca@maryland.gov>, Brian Hug <brian.hug@maryland.gov>, Cecily Beall <cecily.beall@dc.gov>,

christopher cripps <Cripps.christopher@epa.gov>, Cristina Fernandez <Fernandez.cristina@epa.gov>, Dave

Campbell <campbell.dave@epa.gov>, David Arnold <arnold.david@epa.gov>, David Talley <talley.david@epa.gov>,

Diana Esher <esher.diana@epa.gov>, Donna Mastro <mastro.donna@epa.gov>, Horacio Tablada

<horacio.tablada@maryland.gov>, Jay Sakai <jay.sakai@maryland.gov>, Jed Miller <jed.miller@maryland.gov>,

"Joyce E. Epps" <jeepps@state.pa.us>, Karen Irons <karen.irons@maryland.gov>, Kathleen Cox

<cox.kathleen@epa.gov>, Kathy Kinsey <kathy.kinsey@maryland.gov>, Lee Currey <lee.currey@maryland.gov>,

Marcia Ways <marcia.ways@maryland.gov>, Maryland Clearinghouse <clearinghouse@mdp.state.md.us>, MDE DL

All MDE Field Office Personnel <DLAllMDEFieldOfficePersonnel_MDE@maryland.gov>, Michael Dowd

<mgdowd@deq.virginia.gov>, Mike Gordon <gordon.mike@epa.gov>, Randy Mosier <Randy.Mosier@maryland.gov>,

Robert Summers <robert.summers@maryland.gov>, Sharon McCauley <mccauley.sharon@epa.gov>, Sophia

Richardson <srichardson@mdp.state.md.us>, Susan Douglas <susan.douglas@maryland.gov>

Cc: Carolyn A Jones -MDE- <carolyna.jones@maryland.gov>, Eddie Durant -MDE- <eddie.durant@maryland.gov>,

Husain Waheed -MDE- <husain.waheed@maryland.gov>, Kathleen Wehnes -MDE-

<kathleen.wehnes@maryland.gov>, Diane Franks -MDE- <diane.franks@maryland.gov>, Tiachia Soto -MDE-

<tiachia.soto@maryland.gov>

MARYLAND DEPARTMENT OF THE ENVIRONMENT

AIR & RADIATION MANAGEMENT ADMINISTRATION

NOTICE OF PUBLIC HEARINGS/COMMENT PERIODS

The Maryland Department of the Environment gives notice of public hearings/comment periods concerning the

following proposed action:

Amendments to Regulation .04 and .05 under COMAR 26.11.13 Control of Gasoline and Volatile

Organic Compound Storage and Handling to provide an alternative equivalent vapor recovery method for

the transfer of high vapor pressure materials and to amend incorrect references from regulations .04 and .05.

The regulatory actions listed above will be submitted to the U.S. EPA for approval as revisions to Maryland's

State Implementation Plan.

The full text of the proposed amendments will appear in the Maryland Register at http://www.dsd.state.md.us/

MDRegister/mdregister.aspx on April 18, 2014.

Public hearing notice, technical support documents and additional information are available on the Maryland

Department of the Environment's website at the following address:
7/2/2014 Maryland.govMail - RE: Notice of Public Hearing/Comment Period

https://mail.google.com/mail/?ui=2&ik=a38dde8ea8&view=pt&cat=Carolyn%20Jones%2FTransflo%20Regs.&search=cat&th=14570feabb2e89fe&siml=14570fea... 2/2

http://www.mde.state.md.us/programs/regulations/air/Pages/reqcomments.aspx

A public hearing on this action will be held on June 3, 2014 at 10 a.m. at the Department of the

Environment, 1800 Washington Boulevard, 1 st Floor Conference Rooms, Baltimore, Mary land 21230-

17 20.

Comments must be received by 5 pm on June 3, 2014.

For more information or to submit comments, call/e-mail/ fax:

Randy Mosier, Chief, Regulation Development Division

Air Quality Planning Program

Air and Radiation Management Administration

Department of the Environment

1800 Washington Boulevard, Suite 7 30, Baltimore, Mary land 21230-17 20

Telephone: (410) 537 -4488

Email: randy .mosier@mary land.gov

Fax: (410) 537 -4223

Randy Mosier may also be contacted to arrange for the receipt of future public hearing notices.

PLEASE NOTE THAT BEGINNING OCTOBER 1 , 2014, ALL PUBLIC HEARING NOTICES REGARDING

REGULATION CHANGES WILL BE POSTED SOLELY ON THE DEPARTMENT’S WEBSITE.

Marsha Kennedy

MDE-ARMA Air Quality Planning Program

marsha.kennedy@maryland.gov

1800 Washington Boulevard

Baltimore, MD 21230

Phone: 410-537-4079

Fax: 410-537-4223
Mr. Randy Mosier 

Chief, Regulation Development Administration 

Marylnnd Department of the Environment 

1800 Washington Boulevard 

Baltimore, MD 21230 

STATE CU<ADll'tGJiOI JSE REVIEW I'RQCES 

Stofe Application ldenllner: MD20140422-0273 

April24, 2014 

Project Oesct·iptlon: Amendments to Regulation: .04 nnd .05 under COMA R 26. 11 .13 Control of Gasoline and Volatile 

Organic Compound Storage and Handling Comments by S prn on 06/03/2014 and Public Hearing at I 0 a.m. MOE, 

1800 Washington Blvd. lsi Fir. 

Project Location: Maryland 

Clcal'inghol•sc Contact: Nasrin Rnhmnn 

Dear Mr. Mosier: 

Thank you for submitting your project for intergovernmental review. Par1icipalion in the Maryland Intergovernmental Review 

and Coordination (MIRC) process helps ensure project consistency with plans, programs, and objectives of State agencies and 

!ocal governments. 

Notice of your application is being provided to State and local public officials through the llrtergo••ermuenlnl Monitor. which 

is a database of proj ects received by the State Clearinghouse for Intergovernmental Assistance. This information may be 

viewed at hltp://pflnnin&.mar:x.lan.d.&Qv/emjrq!Ublki . The project has been assigned a unique State Application Identifier that 

should be "sed on all documents and correspondence. 

A "Project Status Form" lms been enclosed and should be completed and returned after you receive notice that your project was 

approved or not approved. 

All MlRC requirements have been met in nccordattce with Code ofMarylnnd Regulations (COMAR 34.02.01.04 -.06) and this 

concludes the review process for the above referenced project. If you need assistance or have questions, contact the State 

Clearinghouse staff noted above at 410-767-4490 or through e-mail at nasrin.mhman@maryland.gov. Thank you for your 

cooperation with the MIRC process. 

Sincerely, 

Linda C. Janey, J.D., Assistant Secretary 

P.S. Grefll News!! Your project may he eligible to be "FasiTradced"through th11 Stale permitting processes. Fof'more 

information. go to: f111R;Jj~p.w,tJU10!/qnd,rortwor</prv1/fi!SitrgcJ;f . 

LCJ:NR 

cc: 

Marsha Kennedy 

I UJ2'1 J _NM.NI:.'Wdor: 

Merlin O 'Malley. Govemor 

Anthony G Brown. U . Governor 

Richard Ebefharl Hal . AICP. Secretary 

Amanda Stakem Conn. Esq , Depuly Secrotary 

301 Weot Preston Street Suite 1101 Baltimore Maryland 21201 

Tel •to. 767 4500 Toll Free 1 877 767 6272 • TIY users Ml'lryland Relay Planning Maryland gov 
o) ______________ sustainab/e __ Attainab/e 

Maryland Department of Planning 

PROJECT STATUS FORM 

Please complete this form and return it to the State Clearinghouse upon receiRI of notificatiru! that the project has been 

approved or not npproved by the approving IUithority. 

TO: Maryland State Clen•·inghousc 

Maryland Department of Planning 

30 I West Preston Street 

Room 1104 

Bait imore, MD 2120 I· 2305 

FROM: ~--~------~~~~-­

(Nnme of person completing this form.) 

RE: State Application Identifier: MD201404Z2·0273 

DATE ------~-------­ (Pieasc fill in the date fonn completed) 

PHONE: --·--------- (Area Code & Phone number) 

Project DesCI'iiJtion: Amendments to Regulation: .04 and .05 under COMAR 26.11.13 Control of 

Gasoline 1111d Volatile OrgaBic Compound Storage and Handling Comments by S pm on 

06/03/2014 and Public Hearing at 10 a.m. MDE, 1800 Washington Blvd. 1st Fir. 

PROJECT APPROVAL 

This project/plan was: 0 AIIIJI'OVCd 0 Approved wllh Modification 

----------- Nnmc of AtJfJroving Authority: Date Approved: 

FUNDING APPROVAL. 

The funding (if applicable) has been approved for the JJet•iod of: 

,201 __ to ,lOJ __ as follows: 

FederalS: Local$: State$: I jOther $: 

- I 

OTHER 

0 Further comment or explanation Is attached 

Marlin 0 Malley. Governor 

Anthony G Brown. Lt Governor 

Richard Eberhart Hall, AICP. Secretary 

Amarlda Stakem Conn. Esq , Deputy Socrelmy 

MDPCH·1F 301 West Preston Street Suite 1101 Baltimore M111yland 21201 

Tel 410 767.4500 Ton Free 1 877 767.6272 nv users Mtuyland Relay · Planning Ma•yland.gov 
1

Statement of the Air and Radiation Management Administration

Department of the Environment 

for the

Public Hearing Relating to 

Proposed Amendments to Regulations .04 and .05 under COMAR 26.11.13 Control of 

Gasoline and Volatile Organic Compound Storage and Handling.

held on June 3, 2014

Baltimore, MD

My name is Husain Waheed. I am a Senior Regulatory and Compliance Engineer with the 

Regulation Development Division of the Air and Radiation Management Administration, 

Department of the Environment. 

This public hearing is being held pursuant to the requirements of 40 CFR Section 51.102 

and Sections 2-301 et.seq. of the Environment Article, Annotated Code of Maryland. It is also 

being held in conformance with the State Administrative Procedures Act under the State 

Government Article, beginning at Section 10-101.

Notice of this hearing appeared in the:

Maryland Register on April 18, 2014;

MDE's website from April 17, 2014 to June 4, 2014;

Baltimore Sun on April 18, 2014; 

Saint Mary's Enterprise on April 18, 2014;

Frederick News-Post on April 18, 2014;

Cecil Whig on April 18, 2014;

Salisbury Daily Times on April 18, 2014;

Cumberland Times-News on April 18, 2014; and the

Washington Post on April 17, 2014. 

Copies of these notices were submitted for the record.

Copies of the proposed amendments, new regulation and supporting documents were 

submitted for review to the State Clearinghouse and are also submitted at this time into the 

hearing record. Copies of the proposed new amendments and supporting documents were made 

available for public inspection at the Air and Radiation Management Administration offices in 

Baltimore, Cumberland, and Salisbury, and at all local health departments or local air quality 

control offices.

The purpose of today's hearing is to give the public an opportunity to comment on 

proposed amendments to COMAR 26.11.13. 

Summary:

The purpose of this action is to provide an alternative equivalent vapor recovery method for the 

transfer of high vapor pressure materials and to amend incorrect references.
2

COMAR 26.11.13.04 establishes requirements for the use of automatic disconnections for the 

transfer of gasoline and VOCs with a total vapor pressure greater than 1.5 psia. Automatic 

disconnections are typically referred to in the industry as dry disconnects. Affected sources in 

Maryland do use dry disconnects on transfer equipment used for the handling of gasoline and fuel 

grade ethanol products (which have vapor pressures of greater than 1.5 psia). These products are 

typically transported in tank trucks meeting the U.S. Department of Transportation (US DOT) 

specifications as a MC306 or MC406 type cargo tank. The fuel industry has adopted the use of dry 

disconnect fittings for loading and unloading hose applications. Affected sources are limited to using 

dry disconnects on these products to accommodate the tank truck connection fittings on the 

MC306/406 cargo tanks.

The handling of other flammable liquids in tank trucks is not so clearly defined for the loading 

connections. These products are handled in US DOT MC407 cargo tanks. The motor carrier and 

chemical industries do not have an industry standard for the hose connections and trailer fittings 

beyond regulated safety venting devices. Sources that transfer fuels and liquids do not operate the 

motor carrier fleets or direct or coordinate the tank truck set up or maintenance. As such affected 

sources are required to have a high degree of flexibility as to the product and vapor return 

connections necessary to safely transfer the ordered product. The daily variation for tank truck 

connection type and size make the development of a standard transfer hose connection challenging. 

Many motor carriers use a variation of a cam lock “quick connector” type fitting to allow them to 

meet the end receiver transfer connections. Affected sources in Maryland maintain an inventory of 

the most commonly used connections to meet daily operating conditions.

Affected sources in Maryland typically only transfer one product with a vapor pressure greater than 

1.5 psia at a Baltimore facility. This product is hexane, for which typically approximately 1.5 million 

gallons are transferred annually. This product is transferred using vapor balance, which has an 

estimated combined capture and control efficiency of 98.7 percent using EPA AP-42 factors. The 

total volatile organic compounds (VOC) emissions associated with this transfer are estimated as 

approximately 114 pounds. 

This transfer quantity equates to approximately 53 tank cars of material, and approximately 215 

truckloads of material. The tank trucks that are used to transport this material are not equipped with 

fittings that will accommodate dry disconnects. Because these tank trucks are not owned or operated 

by transfer facilities, it is outside of affected sources control to equip the tank trucks with such 

fittings. 

Maryland's State Implementation Plan (SIP) 

These amendments and new regulation will be submitted to the U.S. Environmental Protection 

Agency (EPA) for approval as part of Maryland's SIP.

Consideration of Comments

The Department will consider all comments before making a decision to adopt these amendments 
3

and new regulation.
ORIGINAL· 

··! 1 

1 MARYLAND DEPARTMENT OF THE ENVIRONMENT 

2 AIR AND RADIATION MANAGEMENT ADMINISTRATION 

3 

4 

5 PUBLIC HEARING CONCERNING 

6 PROPOSED AMENDMENTS TO COMAR 26.11.13 

7 CONTROL OF GASOLINE AND VOLATILE ORGANIC 

8 COMPOUND STORAGE AND HANDLING 

9 

10 

11 The hearing in the above matter commenced on 

12 Tuesday, June 3, 2014, at the MOE Headquarters, 

13 Montgomery Park, 1800 Washington Boulevard, Baltimore, 

14 Maryland. 

15 

16 BEFORE: RANDY MOSIER, Hearing Officer 

17 

18 Reported by: Jen Metcalf 

19 

20 

21 

For The Record, Inc. 

(30 1) 870-8025 - www. ftrinc. net - (800) 921-5555 
2 

1 A P P E A R A N C E S 

2 

3 ON BEHALF OF THE MARYLAND DEPARTMENT OF THE ENVIRONMENT: 

4 

5 RANDY MOSIER, CHIEF 

6 Regulations Development Division 

7 Air and Radiation Management 

8 Maryland Department of the Environment 

9 1800 Washington Boulevard, Suite 730 

10 Baltimore, Maryland 21230 

11 

12 HUSAIN WAHEED 

13 Senior Regulatory and Compliance Engineer 

14 Regulations Development Division 

15 Air and Radiation Management Administration 

16 Maryland Department of the Environment 

17 1800 Washington Boulevard, Suite 730 

18 Baltimore, Maryland 21230 

19 

20 

21 

For The Record, Inc. 

(301) 870-8025- www.ftrinc.net- (800) 921-5555 
3 

1 I N 0 E X 

2 

3 Speaker: Page : 

4 Opening Remarks, Randy Mosier, MOE 4 

5 Hearing Statement, Husain Waheed, MOE 5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

For The Record, Inc. 

(301) 870-8025- www.ftrinc.net- (800) 921-5555 
4 

1 P R 0 C E E D I N G S 

2 

3 MR. MOSIER: Good morning. On behalf of the 

4 Department of the Environment and the Air and Radiation 

5 Management Administration, I would like to welcome you to 

6 this public hearing. 

7 My name is Randy Mosier and I am the Chief of 

8 the Regulations Development Division for the Air and 

9 Radiation Management Administration. I will serve as 

10 hearing officer for today's hearing. 

11 I would like to ask all of you in attendance 

1 2 today to please sign in, if you haven't already done so. 

13 This will help us to keep an accurate record of the 

14 people who p a rticipate in the hearing. Also, copies of 

15 our regulation proposal, support documents, and the 

16 Department's statement are available on the table for 

17 your information. 

18 This hearing concerns Air Quality Regulations 

19 found in the Code of Maryland Regulations, Title 26, 

20 Subtitle 11, Air Quality. The Secretary of the 

21 Department proposes to make Amendments to Regulations .04 

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' 

1 and .05 under COMAR 26.11.13, Control of Gasoline and 

2 Volatile Organic Compound Storage and Handling. 

3 The purpose of this hearing is to give you the 

4 opportunity to comment on this action. 

5 The Opportunity for Public Comment for this 

6 proposed action appeared in the Maryland Register, Volume 

7 41, Issue 8, Page 490-491 on April 18, 2014. 

8 The hearing will proceed in the following 

9 order. First, Mr. Husain Waheed will make a statement on 

10 behalf of the Air and Radiation Management 

11 Administration. After Mr. Waheed is finished, I will 

12 call on any elected official or government official who 

13 wants to make a statement. Then, I will call upon anyone 

14 else who indicated on the sign-in sheet that he or she 

15 would like to make a statement. 

16 When giving your statement, please identify 

17 yourself and your affiliation, and give your statement 

18 loudly and clearly. Are there any questions? 

19 (No response . ) 

20 MR. MOSIER: I will now call on Mr. Waheed. 

21 MR. WAHEED: My name is Husain Waheed. I am a 

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1 Senior Regulatory and Compliance Engineer with the 

2 Regulation Development Division of the Air and Radiation 

3 Management Administration, Department of the Environment, 

4 and I am submitting the hearing statement for the record. 

5 

6 Statement of the Air and Radiation 

7 Management Administration 

8 Department of the Environment 

9 for the Public Hearing Relating to 

10 Proposed Amendments to Regulations .04 and .05 

11 under COMAR 26.11.13 Control of Gasoline and Volatile 

12 Organic Compound Storage and Handling. 

13 held on June 3, 2014 

14 Baltimore, MD 

15 My name is Husain Waheed. I am a Senior 

16 Regulatory and Compliance Engineer with the Regulation 

17 Development Division of the Air and Radiation Management 

18 Administration; Department of the Environment . 

19 This public hearing is being held pursuant to 

20 the requirements of 40 CFR Section 51.102 and Sections 2-

21 301 et.seq. of the Environment Article, Annotated Code of 

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1 Maryland. It is also being held in conformance with the 

2 State Administrative Procedures Act under the State 

3 Government Article, beginning at Section 10-101. 

4 Notice of this hearing appeared in the: Maryland 

5 Register on April 18, 2014; MOE's website from April 17, 

6 2014 to June 4, 2014; Baltimore Sun on April 18, 2014; 

7 Saint Mary's Enterprise on April 18, 2014; Frederick 

8 News-Post on April 18, 2014; Cecil Whig on April 18, 

9 2014; Salisbury Daily Times on April 18, 2014; Cumberland 

10 Times-News on April 18, 2014; and the Washington Post on 

11 April 17, 2014. Copies of these notices were submitted 

12 for the record. 

13 Copies of the proposed amendments, new 

14 regulation and supporting documents were submitted for 

15 review to the State Clearinghouse and are also submitted 

16 at this time into the hearing record. Copies of the 

17 proposed new amendments and supporting documents were 

18 made available for public inspection at the Air and 

19 Radiation Management Administration offices in Baltimore, 

20 Cumberland, and Salisbury, and at all local health 

21 departments or local air quality control offices. 

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1 The purpose of today's hearing is to give the 

2 public an opportunity to comment on proposed amendments 

3 to COMAR 26.11.13. 

4 Summary: 

5 The purpose of this action is to provide an 

6 alternative equivalent vapor recovery method for the 

7 transfer of high vapor pressure materials and to amend 

8 incorrect references. 

9 COMAR 26.11.13.04 establishes requirements for 

10 the use of automatic disconnections for the transfer of 

11 gasoline and VOCs with a total vapor pressure greater 

12 than 1.5 psia. Automatic disconnections are typically 

13 referred to in the industry as dry disconnects. Affected 

14 sources in Maryland do use dry disconnects on transfer 

15 equipment used for the handling of gasoline and fuel 

16 grade ethanol products (which have vapor pressures of 

17 greater than 1.5 psia). These products are typically 

18 transported in tank trucks meeting the U.S. Department of 

19 Transportation (US DOT) specifications as a MC306 or 

20 MC406 type cargo tank. The fuel industry has adopted the 

21 use of dry disconnect fittings for loading and unloading 

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1 hose applications. Affected sources are limited to using 

2 dry disconnects on these products to accommodate the tank 

3 truck connection fittings on the MC306/406 cargo tanks. 

4 The handling of other flammable liquids in tank 

5 trucks is not so clearly defined for the loading 

6 connections. These products are handled in US DOT MC407 

7 cargo tanks. The motor carrier and chemical industries 

8 do not have an industry standard for the hose connections 

9 and trailer fittings beyond regulated safety venting 

10 devices. Sources that transfer fuels and liquids do not 

11 operate the motor carrier fleets or direct or coordinate 

12 the tank truck set up or maintenance. As such affected 

13 sources are required to have a high degree of flexibility 

14 as to the product and vapor return connections necessary 

15 to safely transfer the ordered product. The daily 

16 variation for tank truck connection type and size make 

17 the development of a standard transfer hose connection 

18 challenging. Many motor carriers use a variation of a 

19 cam lock "quick connector" type fitting to allow them to 

20 meet the end receiver transfer connections. Affected 

21 sources in Maryland maintain an inventory of the most 

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1 commonly used connections to meet daily operating 

2 conditions. 

3 Affected sources in Maryland typically only 

4 transfer one product with a vapor pressure greater than 

5 1.5 psia at a Baltimore facility. This product is 

6 hexane, for which typically approximately 1.5 million 

7 gallons are transferred annually. This product is 

8 transferred using vapor balance, which has an estimated 

9 combined capture and control efficiency of 98.7 percent 

10 using EPA AP-42 factors. The total volatile organic 

11 compounds (VOC) emissions associated with this transfer 

12 are estimated as approximately 114 pounds. 

13 This transfer quantity equates to 

14 approximately 53 tank cars of material, and 

15 approximately 215 truckloads of material. The tank 

16 trucks that are used to transport this material are not 

17 equipped with fittings that will accommodate dry 

18 disconnects. Because these tank trucks are not owned or 

19 operated by transfer facilities, it is outside of 

20 affected sources control to equip the tank trucks with 

21 such fittings. 

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1 Maryland's State Implementation Plan (SIP) 

2 These amendments and new regulation will be 

3 submitted to the U.S. Environmental Protection Agency 

4 (EPA) for approval as part of Maryland's SIP. 

5 Consideration of Comments 

6 The Department will consider all comments 

7 before making a decision to adopt these amendments and 

8 new regulation. 

9 

10 MR. MOSIER: Let the record show that no one 

11 has come to attend the public hearing. This will 

12 conclude the public hearing regarding proposed amendments 

13 to Regulations .04 and .05 under COMAR 26.11.13, Control 

14 of Gasoline and Volatile Organic Compound Storage and 

15 Handling. Let the record reflect that it is now 10:10 

16 a.m. and this hearing is officially concluded. 

17 (Whereupon, the hearing was concluded) 

18 

19 

20 

21 

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1 CERTIFICATE OF COURT REPORTER 

2 

3 I, Jen Metcalf, do hereby certify that the 

4 foregoing transcription was reduced to typewriting via 

5 audiotapes recorded by me; that I am neither counsel for, 

6 nor related to, nor employed by any of the parties to the 

7 case in which these proceedings were transcribed; that I 

8 am not a relative or employee of any attorney or counsel 

9 employed by the parties hereto, nor financially or 

10 otherwise interested in the outcome of the action. 

11 

12 

13 

14 

15 

16 JEN METCALF 

17 Court Reporter 

18 

19 

20 

21 

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Martin O’Malley

Governor

Anthony G. Brown

Lieutenant Governor

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Robert M. Summers, Ph.D.

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Martin O’Malley

Governor

Anthony G. Brown

Lieutenant Governor

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