# MDE MARYLAND DEPARTMENT OF THE ENVIRONMENT 1800 Washin g ton Boul e vard • Baltimor e MD 21230 410-537-3000 • 1- 8 00-6 3 3-6101 • www.md e .state.md.us

Mart in 0' M a ll e y Governor Anthony G. B row n L i eut e nan t G ov e rn or



### Mr

. Shawn M. Garvin Regional Admini st ra t or (3RAOO) U.S. E nvironmen ta l Protection Agency Reg i on Ill 1650 Arch Street Philadelphia PA 19103- 2 029

## ~ 4; 

### kt:.AA>Y'l Dear 

## 7 .

_ a rVi n : Robert M. Summe rs. P h .D. S e c reta r y



### The purpose of thi s le tte r is to submit the enclosed i s State Implementation Plan (SIP) Revision # 14- 05 concerning a mendments to 2 6.11.13 Control of Gaso li ne and Volatile Organic Compound Storage and Handing. This S IP revision provides an alternat i ve equiv a lent vapor recovery method for the transfer of h i gh v a por pressure ma t erials and amends i ncorrect references from regul a t i ons .04 and .05.

The Not i ce of Proposed Action was published in the M a ryl a nd R e gi ste r on April 1 8, 2014. A public hearing was held on June 3, 2014. The action was adop te d on July 2 , 2 014. The Notice of Final Action was published on July 11, 2 014 and the action becam e e ffective on July 21 , 2014. All required administra l ive procedures were followed throughou t the adop t ion process.

I certify that the electronic copy of this SIP submitt a l (compact d i sk enclosed) is an exact duplicate of the official hard copy. If you have any ques t ions concerning this SIP action, please feel free to call me at (410) 537-3 084 or Mr. George (T a d) S. Aburn, Jr., D i rector of the Air and Rad i ation Management Adm i n i strat i on, a t (410) 537-3255.
Sincerely,

# b Robert M. Summers, Ph.D. Secretary

Enclosure

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# 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 co llect 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 C alvert, 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 c ounties.
(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) Testi ng. (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 schedu led 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 pr escribed 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 Statio nary 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 b ulk 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 instal led, 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 balan ce 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 st orage 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 loade d 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/squ are 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 disconnec tion 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 t he 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.0 5 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), whi ch 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 certi fication 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 condi tions 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) Subm it 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 EnvironmentPROPOSED 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 typ ically 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 Ad ministration; • Regional offices of the Department in Cumberland and Salisbury;PROPOSED ACTION ON REGULATIONS 491

MARYLAND REGISTER, VOLUME 41, ISS UE 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 Complian ce 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 railro ad 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 

# T E C H N I C A L 

# S U P P O R T 

# D O C U M E N T

Department of the Environment 

# Amendments to COMAR 26.11.13.04 and .05 Control of Gasoline and Vo latile 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 a nd Handling - Alternative Compliance Procedures for Transloading Operations
COMAR 26.11.13.04 establishes requirements fo r 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 disc onnects 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 ha ndling of other flammable liquids (such as Hexane) in tank trucks is not so clearly defined for the lo ading connections and an alternative to the requirement of utilizing dry disconnects on tr ansfer equipment was needed by affected
sources. The development of COMAR 26.11.13.04E - Al ternative Compliance Procedures are based upon technical and economic analysis of the transloading operations between rail tank cars and cargo tank truc ks. 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 connecti ons that automatically close upon disconnection can be met for these specific operations.

For other flammable VOC contai ning liquids the standards fo r transloading connections on cargo tank trucks have not been st andardized. COMAR 26.11.13.04E Alternative Compliance Procedures provide the operationa l flexibility where connections on cargo tank trucks have not been standardized and ad aptive connections that automatically close are not available.
Different commodity materials are involved in transloading operati ons between rail tank car and cargo tank truck. These operations pr ovide considerable tr ansportation 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 materi als with vapor pressure greater than 1.5 psia. Affect ed sources in Maryland ty pically only transfer one product, Hexane, with a va por 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 tr ansloading 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 shoul d 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 en vironment (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 Vo latile 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 Mary land'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 fo r 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 referre d to in the industry as dry disconnects. Affected sources in Maryland do use dry disc onnects 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 pr oducts are typically transporte d in tank trucks meeting the U.S. Department of Transportation (US DO T) 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 sour ces 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 ta nk trucks is not so cl early defined for the loading connections. These products are ha ndled 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 moto r carrier fleets or dire ct or coordinate the tank truck set up or maintenance. As such a ffected sources are required to have a high degree of flexibility as to the product and va por return connections necessary to safely transfer the ordered product. The daily variation for tank tr uck connection type and size make the development of a standard tran sfer hose connection challenging. Many motor carriers use a variation of a cam lock “quick c onnector” type fitting to allow them to meet the end receiver transfer c onnections. Affected sources in Maryland maintain an inventory of the most commonly used connect ions to meet daily operating conditions.

### 4 Affected sources in Maryland typically only transfer one pr oduct with a va por pressure greater than 1.5 psia at a Baltimore facility. This product is hexane, for which typically approximately 1.5 million gallons are transfer red 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 appr oximately 53 tank cars of material, and approximately 215 truckloads of material. The ta nk trucks that are us ed to transport this material are not equipped with fittings that will accommodate dry disconnects. Because these tank trucks are not owned or operated by tr ansfer 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 Termin al Services, Inc. f acility located in Baltimore City.
Requirements
These amendments provide an alternative equiva lent vapor recovery method for the transfer of high vapor pressure materials th at must be approved by the Department and the EPA.
Expected Emissions Reductions
Air quality emission benefits will be achieved by providing an alternativ e to the use of dry disconnects for the transfer of high vapor pres sure materials. The affected facility has developed a custom transloading operation for high vapor pressure materials such as hexane that involves an elevated platform, va por balance and a “fail- closed” configuration which turns off the pump and ceases flow shoul d 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 en vironment (i.e., spills and evaporation).
Economic Impact on Affected Sources, th e 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 th e definition of “small business.”
Is there an Equivalent Federal Standard to this Proposed Regulatory Action?
There is no corresponding federal st andard 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 Vo latile 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 Tec hnical Memorandum 91-01, "Tes t 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 determin e mass emission rate compliance as requi red in §A(1)(a) of this regulation, shall be as prescribed in Method 1009 of the Depart ment's Technical Memorandu m 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 re quirements of §D(1), a person may instead utilize: (a) An overhead loading rack installation which trans fers VOC other than gasoline having a TVP of 1.5 psia (10.3 kilonewtons/square meter) from railroad tank car to t ank trucks, or vice versa, using drip pans and other spill control equipment to limit the releas e 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 truc k subject to this regulation shall: (1) (text unchanged) (2) Use the certification test proce dures as prescribed in Method 1 007 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 m onitor gasoline tank trucks for leak- tight conditions using the procedures described in Method 1008 of the Depa rtment'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 2 6 , 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 TRANS FLO Terminal Services, Inc. (TRANSFLO). This equivalency determination was discussed with you via telephone on October 25, 2011 1



### . This equivalency determination is requested for the requirements of COMAR 26.22.13.04D, which states:
General Standards. A person may not cause o r 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 n o 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 ope rations. 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 fitting s 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 procedure s 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 op erations. 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 z ero ( 0 ) situations requiring additional attention associated with the approximately 8 , 7 5 0 transfer operations (i.e., indi vidual 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 Transport ation (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 accommo date 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 tan ks. 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 coordin ate 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 conne ctions 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 p ump 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, TRANSF LO has transferred one product with a vapor pressure greater than 1.5 psia at the Baltimore facilit y. This product is hexane, for which approximately 220 thousand gallons were transferred during this 12

- month period. This product is transferred using vap or balance, which has an estimated combined capture and control efficiency of 98.7 percent 2



### . 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 w ho 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 li quid 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 environmen t (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 conversatio n, 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 liq uid 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 200 8

.

### MDE October 26 , 2011

Ms. Suna Yi Sariscak

Page 4 of 4 O n behalf of TRANSFLO, we appreciate your consideration of t his 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

- 13 37

.

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 TRAN SFLO 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 , 201 2

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 Baltimor e, 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 equi valency determination 1 

### for the TRANS FLO Terminal Services, Inc. (TRANSFLO) Baltimore facility

. Per our telephone conversation 2 

### , 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 cus tom 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 Te lephone conversation of Fe bruary 23, 2012 between Mr. Husain Waheed, Maryland DEP, and Mitchell Hait, TRANSFLO consultant.

### MDE April 1 2 , 201 2

Mr. Waheed and Ms. Sariscak

Page 2 of 6 arrangement involves an elevated platform, and is described in the following text . The primar y environmental benefit from this unloading method is the “fail

- closed” features of th e equipment configuration. This transfer process was developed as a corrective action arising from an incident involving a leaking railcar bottom out let 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 trail ers. Gasoline and fuel grade ethanol is typically transported using MC306/406 specification tank trailers.

The MC 307/407 trailers are typically equipped with a single rear outlet valve and hose connection point at the ground level. Top fittings includ e 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 fo r 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 con nected 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, t he 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 dist ance between critical operations and product control points to ensure maximum operator transfer control and attendance

.
The tr ansfer platform pump would transfer product from the top of the tank car to the bottom of the tank trailer through the dry dis connect 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 p ounds to a typical 30 foot long hose. The hoses would also be a

### MDE April 1 2 , 201 2

Mr. Waheed and Ms. Sariscak

Page 3 of 6

potential source of product spills. Additionally, i t 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 di ffers 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, a nd 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 li mitations. 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 railc ar to the pump, and the second hose connects from the pump to the truck. The cost of each hose equipped with a dr y 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 o f 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 t hat 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 th e 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 $2 1.03 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 approximatel y 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 percent 3



### . The total volatile organic compounds (VOC) emissions as sociated 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 200 8

.

### MDE April 1 2 , 201 2

Mr. Waheed and Ms. Sariscak

Page 4 of 6 Air Quality Impact s 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 handlin g (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 reasonable 4 

### costs. In this particular case, the use of dry disconnects is expected to increase ai r 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 increase s are estimated using the stan dard 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 pot ential 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 c osts 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 w ould 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 1 2 , 201 2

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 elevate d 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. Inc reasing 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 a s waste.

### MDE April 1 2 , 201 2

Mr. Waheed and Ms. Sariscak

Page 6 of 6 Closing

O n behalf of TRANSFLO, we appreciate your consideration of t his 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

- 13 37

.

Sincerely,

Mitchell J. Hait, P.E., Ph.D. Principal / Senior Engineer

cc: Ms. Becky Heilm an , 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)

### Va.por Line

Line Va.por Tight F a.lse Ma.nwa.y

Qj**~** (J

......

### ~ -c c u 0

...... ::::J 

## 5

......

...... 0 (J 1/J _J) 

### x

.;..; 0:::: 

## E

- OMMIID'II i3

- - 0 0 

# -= GRS

a. -· c MJH :::::!! _., N.T.S. 

### Pla.tforM Mounteol PuMp Ra.ilca.r Eoluction Pipe



### 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 FittingsTF 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” tha t 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 fittin gs to fully dr a in 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” c am 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 a n air line and safety vent assembly. (Trailer is set up for air or nitrogen pressu re unload.)TF HS&E 4

- 2

- 12 4 

### False Manway Fitting For Appli cation to Truck Manway

Truck False Manway with:

V apor 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 an d 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 TablesCost Items Cost Factors a 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 FacilityCost Items Cost Factors a Cost ($) Table 1 Dry Disconnect Annual Cost Data, Actual Case (60 Railcars per Year)

DIRECT OPERATING COSTS (DOC): Operating Labor Operator b 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 FacilityCost Items Cost Factors a 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 FacilityCost Items Cost Factors a Cost ($) Table 2 Dry Disconnect Annual Cost Data, Potential Case (200 Railcars per Year)

DIRECT OPERATING COSTS (DOC): Operating Labor Operator b 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 FacilityCost 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 Re lay Service Martin O’Malley Governor Anthony G. Brown Lieutenant Governor



### April 17, 2014

CERTIFICATE OF PUBLICATION

This is to ce rtify that the “Maryland Departme nt of the Environment (MDE) Notice of Public Hearing/Comment Period Concerning Proposed Amen dments 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 poste d on the site until June 4, 2014. The notice with a link to a technical supporti ng document may be found in the following web address:
http://www.mde.state.md.us/programs/re gulations/air/Pages/reqcomm ents.aspx Web publication of the notice was at th e request of Carolyn A. Jones, Regul ations Coordinator of the Air and Radiation Management Ad ministration 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] Sign In

Regulations

Emergency Regulations Proposed Regulations Adopted Regulations Regulations in

Development Public Hearings, Meetings and

Request for

Comments Air & Radiation Regulations Home 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

email friend print page HOME MARYLANDER BUSINESS RESEARCH CENTER NEWSROOMPublic 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] 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.

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u t u r e p u b l i c h e a r i n g n o t i c e s
.

P L E A S E N O T E T H A T B E G I N N I N G O C

T O B E R 1 , 2 0 1 4 , A L L P U B L I C H E A R I N G N O

T I C E S R E G

A R D I N G R E G U L A T I O N C H A N G E S W I L L B E P O S T E D S O L E L

Y O N T H E D E P A R

T M E N T ’ S W E B S I T E

.

M a r s h a K e n n e d y M D E
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y P l a n n i n g P r o g r a m m a r s h a
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- 5 3 7

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- 5 3 7
- 4 2 2 3Mr. Randy Mosier Chief, Regulation Development Administration Marylnnd Departmen t of the Environment 1800 Washing t on Boulevard Baltimore, MD 21230

STATE CU<ADll'tGJiOI JSE REVIE W I'RQCES

S t ofe Application ldenllner: MD20140422-0273 April24, 2014

P r oject Oesct·iptlon: Amendments to Regulation :

. 04 nnd .05 u nder COMA R 26

. 11

. 13 Con t rol of Gasoline and Volati l e Organic Compound Storage and Handling Commen t s by S prn on 06/03/2014 and Pub l ic Hea r ing a t I 0 a

. m

. MOE , 1800 Washington B l vd. lsi Fir. P r oject Location: Maryland C l cal'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 !oca l governments.

Notice of your a pp l ication is being provided to State and local public officials through t he llrtergo••ermuenlnl Monitor. which is a database of pro j ec t s received by the State Clear i nghouse for Intergovernm e ntal A ss istance. This information may be viewed at hltp :// pflnnin&

. mar:x.lan.d.&Qv / emjrq!Ublki

. The project ha s b e en a s signed a uniq u e State Application Identifier that should be "sed o n all documents and corre s pondence

. A "Project Status F orm" lm s been enclosed and should be completed and ret u rned after you re ceive n o t i c e th a t your proj ect w as approved or not approved

. 

### A

ll MlRC requirements have been met in nc c ordat t ce with Code ofMarylnnd Regulations (COMAR 34

. 02

. 01.04 -. 06) and this concludes th e review proces s for the above referenced project

. If you need assistance or have questions , contact the State Clearinghou se staff noted above at 410-767-4490 or through e-mail at nasrin

. mhman @ maryland.gov

. Thank you for y our cooperation with the MIRC process.
Sincer e ly,

L

inda C

. Janey, J

. D ., Assistant Secretary

P.S. Grefll News!! Your project may he eligible to be " FasiTradced"through th 11 Stale permitting pro c esses

. F o f'more informat i on. go to :**f111R;Jj~p.w,tJU10!/qnd,rortwor</prv1/fi!SitrgcJ;f .**  LCJ:NR
cc : M a rsha Kennedy

I UJ 2 '1

J

_

NM

. NI:.'Wdor:

Merlin O ' Malley

. Govemor An thony G Brown

. U

. Gove r nor R ic hard Ebefharl Hal

. AI CP. Secr eta r y Amanda Stakem Conn

. Esq , Depuly Secrotary

301 Weot Preston Street Sui t e 1101 Baltimore Mary l and 21201 Tel •t o

. 767 4500 To ll Free 1 877 767 6272 • TIY users Ml'lryland Relay Planning Maryla n d gov

# o)

______________ sustain ab/e

__ Attain ab/e 

### Maryland Department of Planning



### PROJECT STATUS FORM

Please complete this form and return it to the State C learinghouse 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 ------~-------­**  (Piea s c fill in the date fonn completed)

PHONE:

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

Project DesCI'iiJtion: Amendments to Regu l ation :

. 04 and

. 0 5 under COMAR 26

. 11.13 C ontrol of Gasoline 1111d Volatile Or g aB i c Compound Storage and Handling Comments by S pm on 06 / 03/2014 and Public Hearing at 10 a.m. MD E, 1800 Washington B l vd. 1st Fir

.

PROJECT APPROVAL

This projec t /plan was: 

# 0 AIIIJI'OVCd 0 A p proved wllh Modification



## -- -- ------ - Nnmc o f AtJfJroving A u t hority: Date Approved:

FUNDING APPR O VAL.

The funding (if app li cable) has been a p proved for the JJet•iod of:
,201

__ to ,lOJ

__ as follows:

FederalS: Local$: State$: I j O ther $:

- I

OTHER 

# 0 Further comment or explanation Is attached

Marlin 0 Malley

. Governor Anthony G Brown

. Lt Governor Richard Eberhart Hal l, AICP. Secretary Amarlda Stakem Conn. Esq , Dep u ty 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 · Plann i ng 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 an d Handling.

held on June 3 , 201 4 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.

Thi s 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 o n April 18 , 201 4 ; MDE's website from April 1 7 , 201 4 to June 4 , 201 4 ; Baltimore Sun on April 18 , 201 4 ; Saint Mary's Enterprise on April 18 , 201 4 ; Frederick News

- Post on April 18 , 201 4 ; Cecil Whig on April 18 , 201 4 ; Salisbury Daily Times on April 18 , 201 4 ; Cumberland Times

- News on April 18 , 201 4 ; and the Washington Post on April 17 , 201 4

. Copies of these notices were submitted for the re cord.
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 docume nts 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 t o 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 inco rrect 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 industr y 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 transporte d 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 l imited 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 operat e 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 prod uct. 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 receive r 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 ps ia 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 perc ent 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 tru ckloads 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 source s control to equip the tank trucks with such fittings.
Maryland's S tate Implementation Plan (S IP )

Th ese amendments and new regulation wil l be submitted to the U.S. Environmental Protection Agency (EPA) for approval as part of Maryland's SIP.

Consider ation 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) 921-55552



### 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



### For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555,, 

### 5 ' 

### 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

1 2 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

For The Record , Inc. 

### (30 1) 870-8025
- 

### www. ftrinc. net
- (800) 921-5555**:. :~·.**  

### 6



### 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

For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555**fo!·~··.** 7



### 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.

For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555**':'- ·.**  

### 8



### 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

For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-55559



### 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

For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555·- · 

### 10

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.

For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555

### ..


## . 

# , 11

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

For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555

### 12

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

For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555

# MARYLAND DEPARTMENT OF THE ENVIRONMENT

1800 Washington Boulevard  

## Baltimore MD 21230 410

- 537

- 3000  

## 1

- 800

- 633

- 6101  

## www.mde.state.md.us

Recycled Paper 

### www. mde.state.md.us TTY Users 1

- 800

- 735

- 2258 Via Maryland Relay Service Robert M. Summers, Ph.D.

Secretary Martin O’Malley Governor Anthony G. Brown Lieutenant Governor



## NO COMMENTS WERE RECEIVED

DURING THE 30

- DAY COMMENT PERIOD

# MARYLAND DEPARTMENT OF THE ENVIRONMENT

1800 Washington Boulevard  

## Baltimore MD 21230 410

- 537

- 3000  

## 1

- 800

- 633

- 6101  

## www.mde.state.md.us

Recycled Paper 

### www. mde.state.md.us TTY Users 1

- 800

- 735

- 2258 Via Maryland Relay Service Robert M. Summers, Ph.D.

Secretary Martin O’Malley Governor Anthony G. Brown Lieutenant Governor



## NO ONE ATTENDED THE PUBLIC HEARING