P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

\ y_t) ll-B-5 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 12 of 132 
_____

BBL^JS 

A 98 13 

MEMORANDUM 

TO: Steve Shedd 

U.S. EPA/OAQPS/ESD/WCPG 

FROM: Bemd Haneke and Greg LaFlam 

Pacific Environmental Services, Inc. 

DATE: August 14,1998 

P:\N819 

M- T3& 

• JLH . | 

SUBJECT: Organic Liquids Distribution (non-Gasoline) NESHAP: Memorandum on 

Subcategorization ofthe OLD Industry 

INTRODUCTION 

In developing standards under Section 112 of the Clean Air Act (Act), the EPA has 

discretion to distinguish or segregate classes, types, and sizes of sources within a source category 

and, conversely, to aggregate among similar sources. Criteria that may be considered in defining 

categories of similar sources include similarities in process operations, emissions characteristics, 

control device applicability, and pollution prevention opportunities.1 

The way in which subcategories are defined is important, because it dictates the basis 

upon which the MACT floor or floors are to be determined. Each subcategory describes the 

"pool" of facilities that is used to determine the MACT floor. In such cases, a separate MACT 

standard may be selected for each subcategory within the source category. 

OVERVIEW OF SUBCATEGORIES 

The organic liquids distribution (non-gasoline) source category includes activities 

associated with the storage and distribution of non-gasoline organic liquids with hazardous air 

pollutant (HAP) content, at sites that serve as distribution points from which organic liquids may 

be obtained for further use and processing. Also, as was proposed in the Oil and Gas Production 

NESHAP proposal (63 FR 6287, February 6, 1998), the oil and natural gas facilities considered 

under the organic liquids distribution (OLD) source category will only include those facilities 

that handle and distribute hydrocarbon liquids after the point of custody transfer. This ensures 

that production operations will not be analyzed and regulated under the OLD NESHAP. The 

term custody transfer as defined in the Oil and Gas proposal means the transfer of hydrocarbon 

liquids, after processing and/or treatment in the producing operations, from storage vessels or 

automatic transfer facilities to pipelines or any other forms of transportation. 
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Based on preliminary information derived from literature searches, industry contacts, and 

site visits, it appears that there are at least four distinct subcategories within the overall OLD 

source category. The differences noted among these subcategories are significant enough to 

warrant individual analysis during the early phases of this rulemaking development. As 

additional information is collected, it will become more apparent as to whether these 

subcategories warrant different MACT floor development and possibly different control 

requirements, and therefore a final determination has not been made. It is expected that future 

site visits and the industry survey will supply important information in making this 

determination. The principal facility types within the four subcategories include: 

1. Separate, or stand-alone, distribution terminals 

2. Pipeline facilities (including only oil and natural gas facilities after the point of custody 

transfer) 

3. Compounding/blending/packaging facilities 

4. Collocated distribution activities (i.e., associated wim refineries or chemical plants). 

What follows is a discussion of each subcategory. We have included, where available, 

information pertaining to the facility sizes and capacities, modes of transfer, emission sources, 

applicable control technologies, and achievable levels of control. A rationale for establishing 

each subcategory, as well as a listing of facilities by State (except Collocated Distribution 

Facilities) in each subcategory is also presented. 

CONTROL TECHNOLOGIES 

This section ofthe memorandum identifies control technologies that are used within the 

organic liquids distribution industry. Rather than list the technologies individually for each 

subcategory, they are presented in this section and referenced throughout the document. Control 

technologies that may be used in the OLD industry will be further discussed and addressed in the 

upcoming Available Control Options memorandum. 

Various control technologies are used to reduce emissions of HAP from the organic 

liquids distribution emission sources. For storage vessels, common control devices include 

thermal or catalytic oxidizers, carbon adsorbers, flares, condensers, and scrubbers. Storage 

vessels may also be fitted with internal or external floating roofs, and vessels may also be 

pressurized or refrigerated. Liquid transfer and loading operations may route their vapors to a 

control device (similar to those mentioned above), or be controlled through the use of vapor 

balancing. Vapor tightness of cargo tanks and vapor handling equipment is enhanced through 

periodic tightness testing. Equipment leaks can be detected and repaired in an instrument or 

visual LDAR program, or by modifying or replacing existing equipment. Air emissions from 

wastewater and semi-solid waste can be controlled by venting them to a control device, use of 

floating roof tanks or vapor-tight covers, and by closed piping or drain controls. 
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Achievable levels of control vary among the types of equipment used. Common control 

technologies for gaseous HAP include thermal and catalytic incineration, flares, adsorption, 

scrubbers, and condensers.2,3 Following is a brief listing and efficiency description of each type 

of control technology. 

1. Thermal incineration is a widely used air pollution control technique in which organic 

vapors are oxidized at high temperatures. Thermal incineration can achieve a wide 

range of destruction efficiencies, but is typically capable of achieving 98 to 99+ 

percent. 

2. In catalytic incineration, organic vapors are oxidized with the help of a catalyst. 

Catalytic incinerators can achieve HAP destruction efficiencies up to about 95 percent. 

3. Flares use open flame to oxidize organic gases during normal operations at facilities. 

Regulatory requirements dictate that flares have a 98 percent destruction efficiency. 

4. Adsorption is a commonly used control technology in which hydrocarbons and other 

compounds are selectively adsorbed on activated carbon, silica gel, alumina, or 

polymeric media. Removal efficiencies of 95 percent or better are achievable with 

adsorption. 

5. Absorption (scrubbers) control emissions by selectively transfening one or more 

components of a gas mixture into a relatively nonvolatile liquid. The efficiency of 

scrubbers is highly dependent on several design parameters, but efficiencies up to 98 

percent are possible. 

6. Condensers are a separation technology in which one or more volatile components of 

a vapor mixture are separated by a gas-to-liquid phase change. The efficiency of a 

condenser depends on the temperature at which it is operated (lower temperatures 

achieve greater control), and the nature ofthe organic gases that are passed through it. 

Control efficiencies of 90 percent or better are achievable. 

SUBCATEGORY DESCRIPTION 

Separate (Stand-Alone^! Distribution Terminals 

Separate (stand-alone) distribution terminals are commercial bulk liquid terminals that 

typically have storage tanks, as well as piping and equipment to transfer the liquids. These 

terminals receive, store, and distribute organic liquids throughout the United States. Modes of 

transportation for stand-alone terminals include, but are not limited to, ocean-going tankers, tank 

barges, tank trucks, tank railcars, and pipelines. The commodities handled at these facilities 

include a variety of organic liquid chemicals, crude oil, fuel oils, petroleum products, animal fats 

3 
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Memo to Steve Shedd 

August 13,1998 

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and oils, and omer liquids. Customers of these terminals include oil producers, chemical 

manufacturers, product manufacturers, utilities, local and State governments, as well as the 

Federal Government and transportation companies. 

Information on separate distribution terminals was derived from the 1997 Independent 

Liquid Terminals Association (ILTA) directory.4 According to the ILTA, there are at least 400 

independent bulk liquid terminals within the United States that handle chemicals and petroleum 

products other than fuel oils, and these have a total storage capacity exceeding 277,680,000 

barrels (1.16 x 10'° gallons). Other potential sources for obtaining further terminal information 

include 1997 Petroleum Terminal Encyclopedia and the 1997 Petroleum Supply Americas 

directories. 

A search of applicable Standard Industrial Classification (SIC) codes5 was performed in 

order to profile the OLD industry. The findings are summarized in Table 1 (the new equivalent 

NAICS codes are also shown). Based on discussions and meetings withTLTA member 

companies, it is possible that SIC code 4226 is the most widely used code in the bulk liquid 

distribution terminals industry. At one facility that the EPA project team visited, SIC 5171 was 

used. 

A size distribution of ILTA member facilities indicates that a large majority of facilities 

have a small number of storage tanks. Table 2 presents a breakdown of ILTA member facilities 

by number of tanks. As can be seen from this table, the preponderance of facilities have between 

1 and 30 tanks, accounting for 77.6 percent of all facilities in the United States. Facilities with 

more than 100 tanks are relatively few, totaling 6.3 percent. 

A distribution of ILTA member facilities in the United States indicates that Texas and 

California (each 7.9 percent ofthe total) have the most facilities. Other States having a large 

number of ILTA facilities include Arkansas (12), Georgia (24), Illinois (18), Louisiana (18), and 

North Carolina (15). Table 3 presents a more detailed analysis ofthe geographic distribution of 

ILTA member facilities. 

Total storage capacity of ILTA member facilities varies greatly. The smallest facility has 

a total storage capacity of 2,700 barrels (113,400 gal), whereas the largest facility has a total 

capacity of 12,500,000 barrels, or 525,000,000 gallons. The average total storage capacity of all 

ILTA member facilities in the United States is 703,054 barrels (29,528,268 gal). Table 4 

includes a listing ofthe 10 largest ILTA member facilities by storage capacity. 

Modes of liquid transfer at these facilities include marine vessel (tanker ship and barge), 

tank truck, railcar, pipeline, and their associated equipment. The HAP emission sources at these 

facilities include: 

1. Storage vessels 

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August 13,1998 

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2. Liquid transfer and loading 

3. Equipment leaks 

4. Wastewater and other wastes 

The Aerometric Information Retrieval System Database (AIRS) was queried on 

applicable SIC codes for the separate/stand-alone distribution terminals. The search within AIRS 

was further refined by querying only for facilities emitting volatile organic compounds (VOC). 

The AIRS database threshold is 100 tpy VOC/yr, so it does not provide information on HAP 

emissions and sources that would be major due to HAP emissions. Thus, in effect, the AIRS 

database is not a good source for obtaining information about separate/stand-alone distribution 

terminals. Table 5 summarizes the results ofthe AIRS database query. 

Control technologies that may be used in the separate/stand-alone distribution terminal 

industry were described in the Control Technologies section. 

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TABLE 1. SEPARATE/STAND-ALONE INDUSTRY PROFILE 

BASED ON SIC CODES5 

Major 

Group 

42 

44 

51 

Industry Group 

Number 

4220 

4490 

5160 

5170 

SIC Code 

4226 

4491 

5169 

5171 

5172 

NAICS Code 

Equivalent 

49319 

48831/2 

42269 

454311 

42272 

Industry Category 

Motor Freight Transportation and 

Warehousing 

Public Warehousing and Storage 

Special Warehousing and Storage, Not 

Elsewhere Classified 

Water Transportation 

Services Incidental to Water 

Transportation 

Marine Cargo Handling 

Wholesale Trade-Non Durable Goods 

Chemicals and Allied Products 

Chemicals and Allied Products, Not 

Elsewhere Classified 

Petroleum and Petroleum Products 

Petroleum Bulk Stations and Terminals 

Petroleum & Petroleum Products 

Wholesalers, except Bulk Stations and 

Terminals 

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TABLE 2. FACILITY SIZE DISTRIBUTION8 

Size Distribution 

(No. of Tanks) 

1-10 

10-20 

20-30 

30-40 

40-50 

50-60 

60-70 

70-80 

80-90 

90-100 

100-110 

110-115 

Total 

Total Number of 

Facilities 

166 

88 

39 

28 

6 

8 

6 

4 

6 

4 

4 

19 

378 

Percent of Total (%) 

44 

23 

10 

8 

1.5 

2 

1.6 

1 

1.6 

1 

1.1 

5 

100 

"Represents member facilities ofthe Independent Liquid Terminals Association (ILTA) 

that may distribute HAP-containing organic liquids. 

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TABLE 3. GEOGRAPHIC DISTRIBUTION OF ILTA MEMBER FACILITIES 

State 

Alabama 

Arizona 

Arkansas 

California 

Colorado 

Connecticut 

Washington DC 

Delaware 

Florida 

Georgia 

Illinois 

Indiana 

Iowa 

Kansas 

Kentucky 

Louisiana 

Maryland 

Massachusetts 

Minnesota 

Mississippi 

Missouri 

Nebraska 

Nevada 

New Jersey 

New Mexico 

| New York 

Number of 

Facilities 

8 

6 

12 

30 

2 

4 

2 

3 

17 

24 

18 

13 

10 

9 

7 

18 

11 

1 

5 

6 

11 

12 

3 

10 

1 

6 

Percent of 

Facilities 

Nationwide 

2 

2 

3 

8 

0.5 

1 

0.5 

0.8 

4.5 

6 

4.7 

3 

2.6 

2 

1.8 

4.7 

2.9 

0.3 

1.3 

1.6 

2.9 

3 

0.8 

2.6 

0.3 

1.6 

Total Number of 

Tanks 

61 

87 

106 

997 

30 

58 

8 

34 

225 

423 

862 

236 

184 

125 

81 

723 

167 

22 

99 

70 

115 

217 

69 

1,428 

5 

195 

Percent of Tanks 

Nationwide 

0.6 

0.8 

1 

9.6 

0.3 

0.6 

0.1 

0.3 

2.2 

4 

8.3 

2.3 

1.8 

1.2 

0.8 

6.9 

1.6 

0.2 

1 

0.7 

1.1 

2.1 

0.7 

13.7 

0.1 

1.9 

% 
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TABLE 3. GEOGRAPHICAL DISTRIBUTION OF ILTA MEMBER FACILITIES 

(Concluded) 

State 

North Carolina 

North Dakota 

Ohio 

Oklahoma 

Oregon 

Pennsylvania 

Puerto Rico 

South Carolina 

South Dakota 

Tennessee 

Texas 

Virginia 

Washington 

West Virginia 

Wisconsin 

Wyoming 

Total 

Number of 

Facilities 

15 

3 

11 

.5 

7 

7 

2 

5 

9 

10 

30 

14 

6 

2 

4 

1 

378 

Percent of 

Facilities 

Nationwide 

4 

0.8 

2.9 

1.3 

1.8 

1.8 

0.5 

1.3 

2 

2.6 

8 

3.7 

1.6 

0.5 

1 

0.3 

100 

Total Number of 

Tanks/State 

203 

73 

179 

62 

316 

365 

96 

88 

179 

169 

1,712 

154 

152 

10 

25 

17 

10,427 

Percent of Tanks 

Nationwide 

2 

0.7 

1.7 

0.6 

3 

3.5 

1 

0.8 

1.7 

1.6 

16 

1.5 

1 

0.1 

0.2 

0.2 

100 

Source: 1997 ILTA Member Directory. 

°l 
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August 13,1998 

Page 10 

TABLE 4. THE TEN LARGEST ILTA MEMBER FACILITIES BY 

TOTAL STORAGE CAPACITY 

Facility Name 

IMTT 

GATX Terminals Corp. 

IMTT 

Houston Fuel Oil Term. Co. 

Paktank Corporation 

GATX Terminals Corp. 

GATX Terminals Corp. 

Intercontinental Term. Co. 

ST Services 

GATX Terminals Corp. 

Location 

Bayonne, New Jersey 

Pasadena, Texas 

St. Rose, Louisiana 

Houston, Texas 

Deer Park, Texas 

Carteret, New Jersey 

Norco, Louisiana 

Deer Park, Texas 

Piney Point, Maryland 

Carson, California 

Storage Capacity 

Gallons 

525,000,000 

518,133,000 

379,278,102 

298,830,000 

280,770,000 

274,176,000 

269,304,000 

247,002,000 

224,700,000 

195,342,000 

Barrels 

12,500,000 

12,336,500 

9,030,431 

7,115,000 

6,685,000 

6,528,000 

6,412,000 

5,881,000 

5,350,000 

4,651,000 

Source: 1997 ILTA Member Directory. 

TABLE 5. POTENTIAL SEPARATE/STAND-ALONE FACILITIES REPORTED 

IN AIRS DATABASE BY SIC CODE 

SIC CODE 

4226 

4491 

5169 

5171 

5172 

Total 

Industry Type 

Special Warehousing and Storage 

Marine Cargo Handling 

Chemicals and Allied Products, NEC 

Petroleum Bulk Stations&Terminals 

Petroleum Products, NEC 

n/a 

Number of 

Facilities 

30 

7 

2 

235 

1 

275 

VOC Emissions 

(tpy) 

19,707 

2,078 

380 

79,707 

202 

102,074 

Source: AIRS Database, U.S. EPA. 

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Pipeline Facilities 

Pipeline facilities are usually subsidiaries of oil and gas producing companies. Two types 

of pipelines comprise this source category, crude oil pipelines and product (non-gasoline) 

pipelines. Products transported may consist of refined petroleum or manufactured liquid 

chemicals. 

As of 1997, there were approximately 168 companies operating pipelines throughout the 

continental United States, Alaska, and Hawaii.5-

6

 These 168 companies were operating 

approximately 1,010 individual pipeline facilities within the same geographic locales. The States 

with the most pipeline facilities include Texas, California, and Pennsylvania. For a more 

detailed presentation of pipeline facilities, refer to Table 6. Table 7 presents the 10 largest 

pipeline operating companies as of 1996. 

SIC codes that apply to the pipeline industry predominantly fall under Major Group 46, 

Industry Group Number 4610, with the following 4-digit codes: 

1. 4612~Crude Petroleum Pipelines 

2. 4613 --Refined Petroleum Pipelines 

3. 4619-Pipelines, Not Elsewhere Classified. 

Some pipelines may also fall under Major Group 47, Industry Group Number 4780, SIC code 

4789-Transportation Services, Not Elsewhere Classified. 

The AIRS database was queried for VOC forthe above listed SIC codes and Table 8 is 

summary ofthe results. As was the case for the separate/stand-alone distribution terminals, only 

facilities emitting at least 100 tpy of VOC are included in the database. 

Compared to other modes, pipelines can transport liquids at very low cost and have very 

large capacities. In 1990 alone, interstate pipelines delivered 6.6 billion barrels of crude oil and 

4.8 billion barrels of products.8 By 1995, the number increased to 12.8 billion barrels (5.37 x 

10" gal) of crude oil and products, and fell slightly in 1996 to 12.6 billion barrels (5.29 x 10" 

gal).9 A breakdown ofthe latter figure reveals that in 1995, 6.95 billion barrels (2.92 x 10" gal) 

of crude oil and 5.91 billion barrels (2.48 x 10" gal) of products were distributed through 

interstate pipelines. 

Of interest to the Organic Liquids Distribution NESHAP are breakout stations and tank 

farms because they may be the highest source of emissions from pipeline operations. Breakout 

tanks occur at many stations along pipelines and serve to sort, measure, reroute, and store crude 

oil. These tanks are also used for controlling surge capacities of crude oil. Currently, there are 

approximately 9,000 such tanks in the industry. Eight thousand of these tanks range in size from 

1,000 barrels (42,000 gal) to 100,000 barrels (420,000 gal).10 Most of these storage tanks are 

thought to be external floating roof tanks." 

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TABLE 6. PIPELINE FACILITIES BY STATE 

State 

Alabama 

Alaska 

Arizona 

Arkansas 

California 

Colorado 

Connecticut 

Florida 

Georgia 

Hawaii 

Idaho 

Illinois 

Indiana 

Iowa 

Kansas 

Kentucky 

Louisiana 

Maine 

Maryland 

Massachusetts 

Michigan 

Minnesota 

Mississippi 

Missouri 

Number of 

Pipeline 

Facilities 

24 

5 

11 

14 

71 

10 

10 

9 

45 

5 

8 

40 

35 

34 

19 

9 

17 

4 

13 

6 

34 

17 

13 

22 

Percent of 

Total 

2.4 

0.5 

1.0 

1.4 

7.0 

1.0 

1.0 

0.9 

4.5 

0.5 

0.8 

4.0 

3.5 

3.4 

1.9 

0.9 

1.7 

0.4 

1.3 

0.6 

3.4 

1.7 

1.3 

2.2 

State 

Montana 

Nebraska 

Nevada 

New Jersey 

New Mexico 

New York 

North Carolina 

North Dakota 

Ohio 

Oklahoma 

Oregon 

Pennsylvania 

South Carolina 

South Dakota 

Tennessee 

Texas 

Utah 

Virginia 

Washington 

Washington DC 

West Virginia 

Wisconsin 

Wyoming 

Total 

Number of 

Pipeline 

Facilities 

10 

14 

6 

23 

22 

43 

35 

6 

45 

19 

8 

54 

20 

9 

29 

92 

3 

39 

14 

3 

2 

32 

7 

1,010 

Percent of 

Total 

1.0 

1.4 

0.6 

2.3 

2.2 

4.3 

3.5 

0.6 

4.5 

1.9 

0.8 

5.4 

2.0 

0.9 

2.9 

9.1 

0.3 

3.9 

1.4 

0.3 

0.2 

3.2 

0.7 

100 

Source: 1997 Petroleum Terminal Encyclopedia. 

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Page 13 

TABLE 7. THE TEN LARGEST INTERSTATE LIQUIDS PIPELINES BY MILEAGE 

AND TRUNKLINE TRAFFIC 

Company 

Koch Pipelines Inc. 

Amoco Pipeline Co. 

Mid-America Pipeline Co. 

Williams Pipeline Co. 

Mobil Pipe Line Co. 

Exxon Pipeline Co. 

Conoco Pipe Line Co. 

Texaco Pipeline Inc. 

Colonial Pipeline Co. 

Shell Pipeline Co. 

Total-1996 

Percent of Total Facilities 

Mileage 

17,601 

10,533 

7,632 

7,296 

6,915 

6,615 

5,867 

5,539 

5,349 

5,169 

78,516 

46.34 

Company 

Colonial Pipeline Co. 

Lakehead Pipe Line Co. 

BP Pipelines (Alaska), Inc. 

Explorer Pipeline Co. 

Plantation Pipe Line Co. 

Shell Pipe Line Corp. 

Exxon Pipeline Co. 

TE Products Pipeline Co. 

Amoco Pipeline Co. 

ARCO Trans. Alaska, Inc. 

Total-1996 

Percent of Total Facilities 

Trunkline traffic, 

million bbl-miles 

710,115 

388,748 

224,980 

136,201 

129,273 

115,736 

109,683 

103,223 

90,536 

89,221 

2,097,716 

7.48 

Source: Oil and Gas Journal, August 4, 1997. 

TABLE 8. PIPELINE FACILITIES REPORTED IN AIRS DATABASE BY SIC CODE 

SIC Code 

4612 

4613 

4619 

4789 

' Total 

Industry Type 

Crude Petroleum Pipe Lines 

Refined Petroleum Pipe Lines 

Pipe Lines, NEC 

Transportation Services, NEC 

n/a 

Number of 

Facilities 

35 

31 

1 

4 

71 

VOC Emissions (tpy) 

8,613 

8,263 

236 

1,642 

18,754 

Source: AIRS Database, U.S. EPA. 

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Specific types of pipeline facilities identified by the American Petroleum Institute (API) 

in a 1997 emission factor project12 are: 

1. Originating pump stations 

2. Booster pump stations 

3. Breakout pump stations 

4. Central shipping stations 

5. Terminals. 

Within these facilities, API inventoried and surveyed the following component categories 

for fugitive emissions: 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

Threaded connections 

Tubing connections 

Flanges 

Valves 

Open ended lines 

Pressure relief valves 

Pump seals 

Miscellaneous 

Furthermore, these components were oftentimes grouped as follows: header, meter loop, pump, 

tank farm, and sump area. It is believed that die principal source of emissions from pipelines 

comes from the filling of tanks at breakout stations. 

Applicable control technologies and achievable levels of control are thought to be similar 

to those described in the Control Technologies section. 

Compounding/Blending/Packaging Facilities 

Facilities exist within the United States diat compound and blend and distribute organic 

liquids witii HAP content. Many of these facilities store HAP-containing liquids, which they 

blend in containers up to about 8,500 gallons in size, and package into containers ranging from 

up to about 600 gallons to less than 1 gallon. 

Blending and packaging operations may be carried out at separate (dedicated) facilities, 

or they may be collocated with a general distribution terminal operation. In turn, a distribution 

terminal that includes these activities may be collocated with a chemical production plant or a 

petroleum refinery. 

Applicable SIC codes for this industry segment primarily include Major Group 51, SIC 

code 5169, "Chemicals and Allied Products, Not Elsewhere Classified." These are 

H 
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Memo to Steve Shedd 

August 13,1998 

Page 15 

"establishments primarily engaged in me wholesale distribution of chemicals and allied 

products." Included in diis SIC code are establishments that distribute solvents, aromatic 

chemicals, and acids, and also facilities such as chemical bulk stations and terminals. The AIRS 

database lists only two facilities that emit 100 tpy/yr of VOC or more. In total, tiiese two 

facilities emit 380 tpy VOC/yr. 

The National Association of Chemical Distributors (NACD) is a trade organization that 

represents facilities that are involved in compounding and blending of chemicals. The NACD 

represents companies that are involved in (among others): 

1. Liquid custom blending and packaging 

2. Laboratory reagents and fine chemicals 

3. Organic and related solvents. 

While the NACD directory13 lists its member companies, it does not provide any information on 

the numbers and locations of specific facilities owned or operated by those companies. The 

NACD has informed the EPA project team that some of its largest member facilities include: 

1. Van Waters and Rogers, Inc. 

2. Holland Chemical International 

3. Ellis and Everard (US Holdings) Inc. 

4. Chemcentral Corporation 

5. SOCO Chemical, Inc. 

Table 9 provides a listing of companies that perform blending and packaging operations. 

This list is not complete because, as described above, not all of a companies facilities are listed in 

the NACD directory. 

From information gathered to date, railcars and tank trucks represent the predominant 

modes of transfer and conveyance into this type of facility. It is possible that some facilities also 

receive products by pipeline, especially when they are collocated with general distribution 

terminals. Some facilities may also receive liquids by drums or other containers. Outgoing 

modes of transportation may include drums, specialty liquid containers (various sizes), tank 

trucks, railcars, or pipelines. 

Emission sources, applicable control technologies, and achievable levels of control are 

thought to be similar to those described in the Control Technologies section. 

Collocated Distribution Facilities 

Many chemical and petrochemical companies and petroleum refineries may have 

distribution facilities in the form of tank farms and pipelines that are collocated (contiguous and 

under common control) with manufacturing facilities. These distribution facilities would serve 

15 
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Memo to Steve Shedd 

August 13,1998 

Page 16 

similar functions to those described in the separate (stand-alone) terminal source, the only 

difference being that these facilities receive their material from a collocated production facility. 

TABLE 9. COMPOUNDING/BLENDING/PACKAGING FACILITIES BY STATE12 

State 

Alabama 

Arkansas 

California 

Colorado 

Connecticut 

Delaware 

Florida 

Georgia 

Illinois 

Indiana 

Iowa 

Kansas 

Kentucky 

Louisiana 

Maine 

Maryland 

Massachusetts 

Michigan 

Minnesota 

Missouri 

Montana 

Number of 

Facilities 

3 

2 

29 

2 

6 

2 

6 

11 

30 

7 

1 

1 

2 

3 

I 

4 

13 

10 

4 

8 

1 

Percent of 

Total 

1.0 

0.7 

9.5 

0.7 

2.0 

0.7 

2.0 

3.6 

10.0 

2.3 

0.30 

0.3 

0.7 

1.0 

0.3 

1.3 

4.2 

3.3 

1.3 

2.6 

0.3 

State 

Nevada 

New Hampshire 

New Jersey 

New Mexico 

New York 

North Carolina 

Ohio 

Oklahoma 

Oregon 

Pennsylvania 

Rhode Island 

South Carolina 

Tennessee 

Texas 

Utah 

Virginia 

Washington 

West Virginia 

Wisconsin 

Wyoming 

Total 

Number of 

Facilities 

1 

1 

21 

2 

21 

7 

29 

1 

3 

25 

4 

1 

3 

23 

2 

5 

5 

1 

5 

1 

307 

Percent of 

Total 

0.3 

0.3 

6.8 

0.7 

6.8 

2.3 

9.5 

0.3 

1.0 

8.1 

1.3 

0.3 

1.0 

7.5 

0.7 

1.6 

1.6 

0.3 

1.6 

0«3 

100 

Source: 1997 NACD Directory. 

/fe 
P.18 

Memo to Steve Shedd 

August 13,1998 

Page 17 

HAP-containing liquids may be stored in these facilities and then distributed via the various 

modes of transfer/delivery. 

At present, applicable SIC codes for collocated distribution facilities are considered to 

fall under Major Group 51, which includes SIC code 5169, "Chemicals and Allied Products, Not 

Elsewhere Classified." It is conceivable tiiat there may be some overlap in SIC codes with 

facilities regulated by the Hazardous Organic NESHAP (HON) and/or the Refinery NESHAP. 

The investigation of applicable SIC codes will continue as the industry definition is further 

refined. 

It is currently thought that emission sources at collocated distribution facilities are similar 

to those in the separate (stand-alone) distribution facility subcategory. It is also assumed that 

applicable control technologies and achievable levels of control are similar to those described in 

the Control Technologies section. 

CONCLUSIONS 

The industry subcategories discussed in this memorandum were selected based on 

differences in technical characteristics among the facilities in those subcategories. These 

differences include liquid types, modes of transfer, facility locations, and likelihood of available 

controls (such as may occur at a collocated facility). No specific conclusions can be drawn at 

this time concerning the need for different control standards among these facility types. An 

analysis of results from the industry survey will be made to determine whether separate MACT 

floors are appropriate for the individual subcategories. 

n 
P.19 

\ Memo to Steve Shedd 

August 13,1998 

Page 18 

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2