P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

ll-B-9 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 15 of 132 
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A-98-13 

TO: 

FROM: 

MEMORANDUM 

Project File 

Organic Liquids Distribution NESHAP 

ESD Project No. 96/05 

Bernd Haneke and Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: May 7,1998 

SUBJECT: Site Visit to Plains Terminal and Transfer, Cushing, Oklahoma 

I. Purpose 

The purpose of this site visit was to tour the facility in an effort to educate EPA and 

contractor personnel concerning organic liquids distribution operations and to collect 

information related to air emissions from the operations. This work is in support of the 

development of national emission standards for hazardous air pollutants (NESHAP) for the 

organic liquids distribution (non-gasoline) source category. 

II. Location and Date 

Plains Terminal and Transfer Company 

Route 1 

P.O. Box 595 

Cushing, Oklahoma 74023-9716 

April 21,1998 (1:00 pm - 3:30 pm) 

JST.I.£&& 

EPA AIR DOCKET 

III. Participants 

Plains Terminal and Transfer 

Mr. Pete Geurin - Terminal Manager 

Environmental Protection Agency 

Mr. Steve Shedd - Project Officer, OAQPS/ESD/WCPG 

Research Triangle Park, NC 

Oklahoma Department of Environmental Quality. Air Quality Division 

Ernie D. Smith - Environmental Specialist 

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Site Visit Memo/Plains Terminal and Transfer 

May 7,1998 

Page 2 

Pacific Environmental Services. Inc. (PES. 

Greg LaFlam - Research Triangle Park, NC 

Bernd Haneke - Research Triangle Park, NC 

IV. Pre-Tour Discussion 

Introduction 

EPA Introduction 

After the participants introduced themselves, Steve Shedd, EPA, began the meeting by 

discussing the background of the EPA's regulation of hazardous air pollutant (HAP) emissions. 

Prior to the Clean Air Act Amendments of 1990 (CAAA), regulations were on a basis of 

individual HAP and a limited number of regulations were completed. The CAAA of 1990 

included a HAP list and prescribed that rules be developed for categories of sources (industrial 

types). The stringency of the Organic Liquids Distribution (non-gasoline) rule (for existing 

sources) will be based on "floor" levels of control representing the control achieved by the 

average of the top 12 percent of sources in this category. The standards are slated to be 

proposed in 1990, with promulgation of the final rule in November 2000. 

Mr. Shedd mentioned that the EPA has prepared an industry questionnaire and 

distributed it to a Work Team consisting of stakeholders for their review and comment. The 

questionnaire, when final, will be sent to approximately 160 companies in this industry. He 

also described the EPA's procedures for handling information that the company considers to be 

confidential business information (CBI). The company will have an opportunity to review the 

draft site visit report prepared by the EPA project team, and to comment on its accuracy and to 

identify any CBI. The report with any CBI removed will be made a part of the public record for 

this rulemaking. Mr. Pete Geurin of Plains Terminal and Transfer Corporation was asked to 

identify if any of the information in the conversations and handouts was confidential. No 

information presented was claimed to be confidential by Mr. Geurin. 

Plains Terminal and Transfer Introduction 

Mr. Geurin began his introduction by stating that the Plains facility was built in 1992 

and commenced operations in 1993. Prior to commencing construction of the facility, Plains 

met with various EPA officials in Washington, DC to discuss potential future requirements for 

storage tanks and breakout stations. The facility incorporates many state-of-the-art features 

related to safety and environmental friendliness. For example, all piping is aboveground, 

storage tanks have an HDPE bowl liner and secondary containment, and the facility has its own 

fire protection system. 

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Site Visit Memo/Plains Terminal and Transfer 

May 7,1998 

Page 3 

Mr. Geurin also commented that he felt other facilities should have to maintain their 

facilities in a condition similar to Plains' (level playing field). He illustrated his point by 

showing pictures of storage vessels at other nearby facilities which were clearly leaking oil 

from welding/riveting seams. Mr. Geurin stated that older facilities that are "grandfathered" are 

not as heavily regulated as more modem facilities, and that the older facilities might have a 

price/market advantage due to this. 

Facility Processes 

Plains Terminal and Transfer is a crude oil breakout station that warehouses numerous 

grades of crude oil for various customers. The facility operates 365 day/year, and 24 hr/day. 

Mr. Geurin stated that in his opinion, the facility was running at approximately 85 percent 

capacity, and that level of utilization depended upon various market factors. A throughput and 

storage fee is charged per barrel at the facility. Due to the level of business, Plains is planning 

to construct four additional 250,000 bbl storage tanks in the near future. The facility employs 

10 people. 

All transfer and storage operations are fully automated via computers in the control 

room. The controller at Plains can transfer oil, shut valves, or start/stop mixers in storage 

vessels through the use of a mouse and interactive monitor screen. The computer system 

utilized at Plains has a redundant back-up in case of equipment failure. 

Crude oil enters the facility by either tank truck or pipeline, and all crude exits the 

facility by pipeline. The facility has three clusters of storage vessels, all of which are equipped 

with external floating roofs. In total, there are 18 tanks at the facility. There are two clusters 

each containing seven tanks with individual storage capacities of 100,000 bbl, and an additional 

cluster of four tanks each having a storage capacity of 150,000 bbl (Attachment 1). 

As listed in Attachment 2, the facility stores and transfers significant amounts of crude 

oil. Domestic and foreign crude are handled by the facility. Total throughput at the facility was 

24,593,264 bbl in 1997, with the following breakdown by grade of crude: 

Domestic Sweet -12,275,555 bbl 

Domestic Sour - 7,221,512 bbl 

Foreign Crude - 5,096,197 bbl. 

All storage tanks are equipped with mixers to homogenize crude oil present in the 

vessel. The mixers, consisting of large propellers, also have the ability to sweep the bottom of 

the tank, thereby reducing the amount of sediment that can build up there. Furthermore, 

homogenizing crude oil ensures that all water that enters the tanks with the crude oil also leaves 

with it. 3 
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Site Visit Memo/Plains Terminal and Transfer 

May 7,1998 

Page 4 

As mentioned above, pipelines that connect storage tanks at the Plains facility are 

aboveground. This reduces the risk of crude oil leaks, and provides for better systems 

oversight. Pipelines exiting the Plains facility to other crude oil breakout stations run 

underground. 

The facility stores crude oil for other breakout stations in Cushing. Therefore, its 

longest pipeline is a 24-inch line which connects it to Shell, which is approximately 1.5 miles 

away. The Plains facility also has pipeline connections to Arco, and approximately 10 other 

breakout stations in the Cushing area. 

The Plains facility is a member of the Independent Liquid Terminals Association 

(ILTA) and has a Standard Industrial Classification (SIC) code of 5171, "Petroleum Bulk 

Stations and Terminals." This SIC code was chosen by Plains because the facility does not 

reinject crude oil into any of the main pipelines that run through Cushing. 

Emissions Inventory 

No detailed emissions inventory was available for perusal by the EPA project team. 

Nevertheless, Mr. Ernie Smith, Oklahoma DEQ, was able to provide two essential documents 

(Attachments 3-4): 

1. Evaluation of Permit Application No. 91-095-O 

2. Permit to Operate w/ Specific Conditions, Permit No. 91-095-O. 

In this permit it is estimated that annual VOC emissions at the Plains facility would be 

approximately 19.8 tpy. Of these 19.8 tpy, approximately 10.4 tpy are from storage vessels, 

and the remainder is due to equipment leaks (fugitive emissions). These estimates are based on 

an estimated 18 tank turnovers/year with crude oil having a vapor pressure of 2.9 psia at 60 

degrees Fahrenheit. As was stated previously, no actual emissions data were obtained by the 

EPA project team during its April 21 visit to the facility. 

Control Measures 

As stated above, all of the storage tanks are equipped with external floating roofs. The 

external floating roofs are equipped with primary shoe seals and secondary wiper seals. 

The pipeline manifold consists of four pumps and 58 valves. The four electrically 

driven pumps are rated at the following horsepower and capacities: 

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Site Visit Memo/Plains Terminal and Transfer 

May 7,1998 

Page 5 

TABLE 1. PUMP INFORMATION 

Pump 

1 

2 

3 

4 

Horsepower 

500 

600 

375 

175 

Capacity (bbl/hr) 

12,000 

14,000 

6,500 

3,750 

The facility also has an underground oil/water separator which treats contact storm 

water. It is emptied approximately once a year, and at each emptying approximately 40 bbl of 

oil are removed from it. 

There is no formal leak detection and repair (LDAR) program at the Plains facility. In 

part because of the age of the facility, there have not been many problems associated with 

equipment leaks and failures. Mr. Geurin did mention that an operator drives through the 

facility at least three times a day to inspect pipelines and tanks for visible signs of leaks. 

Regular maintenance is also performed on valves once every 6 months, or as required by 

Department of Transportation (DOT) regulations. Any leaks that are encountered are fixed as 

soon as possible. 

V. Plant Tour 

A tour by vehicle was conducted by Mr. Geurin. The first stop of the tour was at a 

storage vessel (T1600). The EPA project team was permitted to climb up on the tank and 

inspect the secondary wiper seals. Mr. Geurin also took the team on a tour of the external 

floating roof. Following this Mr. Geurin showed the team the pontoons on which the external 

floating roof rested. 

The next stop was at the manifold of the facility. Pumps, valves, and pipelines were 

observed here, as well as the underground API oil/water separator. The whole manifold area 

appeared to be in good condition, and was very well kept. 

The last stop of the tour was at the fire water pond. Mr. Geurin showed the EPA project 

team where the overflow of the storm water retention pond entered the fire water pond, as well 

as the pumping system for fire water. 

Following the stop at the fire water pond, Mr. Geurin briefly drove by a truck unloading 

rack. At this site crude oil is from local production wells is transferred from tank trucks into 

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Site Visit Memo/Plains Terminal and Transfer 

May 7, 1998 

Page 6 

fixed roof storage tanks (four to five loads per day) for eventual transfer to the larger external 

floating roof tanks. 

VI. Post-Tour Discussion 

Following the tour of the facility, the group met briefly to finish the meeting. The EPA 

project team did not have any questions, nor did Mr. Geurin, so the meeting was concluded. 

VII. Action Items 

During the meeting, the EPA project team requested the following information: 

1. An emission inventory of the Plains facility detailing emissions of VOC and HAP for 1997 

2. The emission factors used to calculate fugitive emissions. 

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ATTACHMENT 1 

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ATTACHMENT 2 

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January 

February 

March 

April 

May 

June 

July 

August 

September 

October 

November 

December 

PLAINS TERMINAL & TRANSFER 

_ 

Dorn Swt 

1,292,789 

1,114,395 

1,276,930 

1,551,928 

1,813,210 

529,025 

880,507 

67,026 

1,023,779 

1,269,670 

240,173 

1,216,123 

12,275,555 

I997THRUPUT 

Sour 

769,349 

542,080 

810,236 

142,748 

556,273 

600,181 

381,827 

688,972 

806,860 

821,602 

724,185 

377,199 

7,221,512 

Foreign 

209,266 

339,896 

0 

860,150 

389,253 

823,119 

716,676 

214,107 

155,806 

172,269 

903,375 

312,280 

5,096,197 

Total 

2,271,404 

1,996,371 

2,087,166 

2,554,826 

2,758,736 

1,952,325 

1,979,010 

970,105 

1,986,445 

2,263,541 

1,867,733 

1,905,602 

24,593,264 

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ATTACHMENT 3 

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DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY DIVISION 

MEMORANDUM: March 3, 1994 

TO: Joyce D. Sheedy, Acting Director, Permits Section 

THROUGH: Peer Review 

FROM: David Schutz, Environmental Engineer 

SUBJECT: Evaluation of Permit Application No. 91-095-0 

Plains Marketing & Transporation* 

(Formerly Sunnybrook Transmission, Inc.) 

Crude Oil Storage Facility 

Sec. 23-17N-5E 

Near Cushing In Lincoln County, Oklahoma 

Plains Marketing has applied for a permit to operate 18 new hydrocarbon storage 

tanks at their Cushing facility. All of the tanks are external floating roof 

designs, and store crude oil with a vapor pressure of 2.9 psia at 6^F. Tanks 

Nos. 100-1400 are 100,000 barrels (4.2 million gallons) capacity, while Tanks 

Nos. 1500-1800 are 150,000 barrels (6.3 million gallons) capacity. The new 

sources are summarized below: 

Parameter 

Contents 

Color 

Capacity, gallons 

Height, feet 

Diameter, feet 

Avg. Vapor Pressure, psia 

Annual Turnovers 

Design 

VOC Emissions, 

TPY per tank 

Total VOC Emissions, TPY 

All Tanks in a Category 

Fugitive VOC Emissions 

Tank Equipment, for Tanks 100-1800 

Tanks No. 100-

crude oil 

white 

4.2 million 

48 

120 

2.9 

18 

EFR 

0.50 

•1400 Tank No. 1500-1800 

crude oil 

white 

6.3 million 

48 

150 

2.9 

18 

EFR 

0.60 

7.0 2.4 

TOTAL EMISSIONS 

TPY 

10.4 

19,8 

Annual emissions of VOC have been estimated by AF42 factors to be 20.0 TPY. 

this emissions level, the new tanks are a minor source. 

At 

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NSPS is applicable to the project. Subpart Kb applies to volatile organic 

liquids storage vessels (including petroleum liquids storage vessels) for which 

construction, reconstruction, or modification commenced after July 23, 1984, 

and which have a capacity of 10,567 gallons (40 cubic meters) or more. 40 CFR 

60.112b specifies that vessels with a design capacity greater than or equal to 

39,980 gallons containing a VOL that, as stored, has a maximum true vapor 

pressure greater than or equal to 0.75 psia but less than 11 psia shall have 

one of the following vapor control devices: an external fixed roof in 

combination with an internal floating roof; an external floating roof; a closed 

vent system to a control device (flare, condenser, or absorber); or an 

equivalent system. 

Subpart Kb specifies the following standards for external floating roofs. The 

floating roof must be floating on the liquid surface except during initial fill 

or when the vessel is completely emptied. The floating roof must be equipped 

with closure devices between the wall of the vessel and the edge of the 

floating roof; for an external floating roof, two seals (primary and secondary) 

are required. Each opening in a non-contact floating roof is to provide a 

projection below the liquid surface. Each opening in the floating roof except 

for leg sleeves, automatic bleeder vents, rim space vents, column wells, ladder 

wells, and stub drains is to be equipped with a cover or lid which is to be 

closed at all times except when the device is in actual use. Automatic bleeder 

vents shall be equipped with a gasket. Rim space vents shall be equipped with a 

gasket. The sample wells shall have a slit fabric cover which covers at least 

90% of the opening. The secondary seal shall be at least 24 inches above the 

liquid surface. 

The secondary seal on an external floating roof shall be checked at least 

yearly for gaps. The secondary seal gap area to tank circumference ratio shall 

not exceed 1 square inch per foot of tank diameter nor shall any gap exceed 0.5 

inches. The primary seal gap area to tank circumference ratio shall not exceed 

10 square inch per foot of tank diameter nor shall any gap exceed 1.5 inches. 

In addition to NSPS Subpart Kb, the tanks are subject to OAC 310:200-37-15. OAC 

310:200-37-15 requires the owner or operator of any new stationary organic 

materials storage vessel containing a VOL with a true vapor pressure as stored 

of 1.5 psia or more to be operated with a floating roof or equally efficient 

means of organic vapor loss control. NSPS Subpart Kb is more stringent that 

this rule and is, therefore, applicable. 

PSD is not applicable to the facility. PSD affects major new sources and major 

modifications at existing sources. Petroleum transfer and storage units with a 

combined capacity of 300,000 barrels or more are defined as major sources at an 

emissions level of 100 TPY of VOC. Emissions from this facility have been 

estimated at 20 TPY. This emissions level is less than the level of 

significance for PSD. 

The facility is also not subject to NESHAPS as there will be no emissions, of 

any pollutant subject to regulation under 40 CFR 61 except for benzene. Benzene 

is present in amounts less than 10% by weight, the de minimis level for NESHAPS; 

Subpart J. 

/ * > 
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Seal gap tests were conducted on the 18 vessels between November 11, 1993 and 

February 28, 1994. Gap testing showed the tanks to be in compliance with the 

requirements of NSPS Subpart Kb. 

The applicant has demonstrated compliance with applicable air pollution control 

rules and regulations. Ambient air quality standards are not threatened at the 

site. Approval is recommended. 

/z/schutz/files.wp/tanks/plainsTanks 

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Administrative Summary 

Date Application Received: January 10, 1994 

Date of Administrative Completeness Review: January 10, 1994 

Time Tolled: 52 Days 

Chargeable Time: March 3 to present 

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crude oil 

white 

4.2 million 

48 

120 

2.9 

18 

EFR 

0.500 

-1800 

TPY 

10.4 

crude oil 

white 

6.3 million 

48 

150 

2.9 

18 

EFR 

0.600 

PERMIT TO OPERATE 

AIR POLLUTION CONTROL FACILITY 

SPECIFIC CONDITIONS 

PERMIT NO. 91-095-O 

The permittee is authorized to operate in conformity with the specifications 

submitted to Air Quality on July 24, 1991, with supplemental information 

received January 10, 1994, and analyzed in AQD's Evaluation of Permit 

Application No. 91-095-O dated March 3, 1994. Continuing operations under this 

permit constitutes acceptance of, and consent to, the conditions contained 

herein: 

1. Points of emissions and emissions limitations: 

Parameter Tanks No. 100-1400 Tank No. 1500-1800 

Contents 

Color 

Capacity, gallons 

Height, feet 

Diameter, feet 

Avg. Vapor Pressure, psia 

Annual Turnovers 

Design 

VOC Emissions, 

TPY per tank 

Fugitive VOC Emissions 

Tank Equipment for Tanks 100-1800 

2. The permittee shall be permitted to operate the new vessels 24 hours per 

day, 365 days per year, 8,760 hours per year. 

3. The new tanks are subject to federal New Source Performance Standards, 40 

CFR 60 Subpart Kb, and shall comply with all applicable standards. 

4. The external floating roof shall be floating on the liquid surface at all 

times except during initial fill and during those intervals when the storage 

vessel is completely emptied or subsequently emptied and refilled. When the 

roof is resting on the leg supports, the process of filling, emptying, or 

refilling shall be continuous and shall be accomplished as rapidly as possible. 

5. Each opening in the external floating roof except for rim space vents and 

automatic bleeder vents shall provide a projection below the liquid surface. 

Except for automatic bleeder vents, rim space vents, roof drains, and leg 

sleeves, each opening in the floating roof is to be maintained in a closed 

position (i.e., no visible gaps) except when in actual use. 

6. Automatic bleeder vents are to be closed at all times when the roof is 

floating except when the roof is being floated off or landed on the roof leg 

supports. 

7. Rim space vents are to be set to open only at the manufacturer's recommended 

setting or when the external floating roof is not floating. 

8. Two seals shall be installed, a primary mechanical shoe seal or 

liquid-mounted seal and a secondary seal which completely covers the annular 

space between the floating roof and the tank shell. 

9. The primary seals shall be checked every 5 years. The secondary seal on an 

external floating roof shall be checked at least yearly for gaps. The secondary 

seal gap area to tank circumference ratio shall not exceed 1 square inch per 

foot of tank diameter nor shall any gap exceed 0.5 inches. The primary seal gap 

area to tank circumference ratio shall not exceed 10 square inch per foot of 

tank diameter nor shall any gap exceed 1.5 inches. 

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10. The owner or operator shall visually inspect the floating roof, the primary 

seal, the secondary seal, gaskets, slotted membranes (if present), and sleeve 

seals (if present) each time the storage vessel is emptied and degassed. If the 

floating roof has defects, the primary seal has holes, tears, or other openings 

in the seal or seal fabric; or the secondary seal has holes, tears, or other 

openings in the seal or seal fabric; or the gaskets no longer close off the 

liquid surface from the atmosphere; or the slotted membrane has more than 10% 

open area, the owner or operator shall repair the items as necessary so that 

none of the conditions specified in this paragraph exists before refilling the 

storage vessel with volatile organic liquid (VOL). In no event shall 

inspections conducted in accordance with this provision occur at intervals 

greater than five (5) years. 

11. The owner or operator shall notify Air Quality in writing at least 30 days 

prior to filling or refilling of this storage vessel for which inspection is 

required by 40 CFR 60.113b(a) (5) to afford Air- Quality an opportunity to have 

an observer present. If the inspection is not planned and the owner or operator 

could not have known about the inspection 30 days in advance of refilling the 

tank, the owner or operator shall notify Air Quality at least seven days prior 

to refilling the storage vessel. Notification shall be made by telephone 

immediately followed by written documentation demonstrating why the inspection 

was unplanned. Alternatively, this notification including the written 

documentation may be made in writing and sent so that it is received by Air 

Quality at least seven days prior to refilling. 

12. The owner or operator of these storage vessels shall keep records and 

furnish reports as required.by 40 CFR 60.115b(a). Copies of these reports and 

records shall be kept for at least two years following the date on which they 

were made. The owner or operator shall meet the following requirements: 

a. Keep a record of each inspection performed as required by 40 CFR 

60.113b. Each record shall identify the storage vessel on which the 

inspection was performed and shall contain the date the vessel was 

inspected and the observed condition of each component of the control 

equipment (seals, floating roof, and fittings). 

b. After each inspection required by 40 CFR 60.113b that finds holes or 

tears in the seal or seal fabric, or defects in the internal roof, or 

other control equipment defects listed in 40 CFR 60.113b, a report shall 

be furnished to Air Quality within 30 days of the inspection. The report 

shall identify the storage vessel, the reason it did not meet the 

specifications, and each repair made. 

12. The owner or operator shall maintain a record for Tanks Nos. 100-1800 of 

the volatile organic liquid stored, the period of storage and the maximum true 

vapor pressure of that VOL during the respective storage period. Copies of 

these records shall be retained on location for at least two years after the 

dates of recording. 

13. The owner or operator shall keep readily accessible records showing, the 

dimensions of the storage vessels and an analysis showing the capacity of the 

vessels. This record shall be kept for the life of each tank. 

14. Available data on the storage temperature may be used to determine the 

maximum true vapor pressure. For crude oil or refined petroleum products, the 

vapor pressure may be obtained by the following: 

a. Available data on the Reid vapor pressure and the maximum expected 

storage temperature based on the highest expected calendar month average 

temperature of the stored product may be used to determine the maximum 

true vapor pressure from nomographs contained in API Bulletin 2517. 

b. The true vapor pressure of each type of crude oil with a Reid vapor 

pressure less than 13.8 kPa (2.0 psia) or with physical properties that 

10 
P.19 

preclude determination by the recommended method is to be determined from 

available data and recorded if the estimated true vapor pressure is 

greater than 3.5 kPa (0.50 psia). 

15. As specified in 40 CFR 60.7(b), any owner or operator subject to the 

provisions of NSPS shall maintain records of the occurrence and duration of any 

start-up, shutdown, or malfunction in the operation of an affected facility of 

any malfunction of the air pollution control equipment. 

16. As specified in 40 CFR 60.7(d), any owner or operator subject to the 

provisions of NSPS shall maintain a file of all measurements and all other 

information required by this part recorded in a permanent file suitable for 

inspection. This file shall be retained for at least two years following the 

date of such measurements, maintenance, and records. 

17. This is a permit to operate in accordance with and under the authority of 

the Oklahoma Clean Air Act and the regulations promulgated thereunder. It does 

not relieve the holder of the obligation to comply with other applicable 

federal, state, or local statutes, regulations, rules, or ordinances. 

18. The permittee shall keep records of cumulative annual throughput. These 

records shall be maintained in an accessible location for inspection by 

regulatory personnel upon request. Required records shall be retained for a 

period of at least two years following dates of recordings. 

/ < .