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OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

gJ95) II-E-17 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 85 of 110 
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MEMORANDUM 

A-%-13 

ii-e - n 

TO: Martha Smith 

U.S. EPA/OAQPS/ESD/WCPG 

ESD Project No. 96/05 

FROM: Bernd Haneke and Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: August 24,1999 

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SUBJECT: Meeting with GATX and the Independent Liquid Terminals 

Association (ILTA) 

I. Purpose 

The purpose ofthis meetmg was to meet with GATX and the ILTA to discuss the 

Model Plants memo, and other issues of concern regarding the Organic Liquids Distribution 

(O.L.D.) NESHAP. 

II. Location and Date 

U.S. Environmental Protection Agency 

EPA/NC Mutual Building, 10th Floor Conference Room 

Durham, North Carolina 

August 19,1999,1:00 pm to 3:00 pm 

III. Participants 

Jim Bailey, Houston Fuel Oil Terminal Company 

Bernd Haneke, PES, Inc. 

Greg LaFlam, PES, Inc. 

Usha Mehra, GATX, Inc. 

John Prokop, ILTA 

Gary Roesch, NOCO Energy Group 

Martha Smith, OAQPS/ESD/WCPG 

IV. Discussion 

After the participants introduced themselves, Mr. Prokop, ILTA, gave a brief overview 

ofthe ILTA, its members, functions, and purpose. He stated that nationwide, there are 500 

ILTA member terminals, which account for over 12,000 storage tanks and a storage capacity 
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Memo-ILTA Meeting 

August 24,1999 

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exceeding 294-300 million barrels. Additionally, ILTA member facilities are storing over 

3,000 different chemical products. He also added that exclusive of major oil companies, there 

are currently approximately 100 terminals that are not part ofthe ILTA. Mr. Prokop also 

mentioned that the 159 ILTA member terminals are distributed among the following states: 

California 37 terminals 

Illinois 27 terminals 

Louisiana 18 terminals 

New York 15 terminals 

New Jersey 13 terminals 

Washington 11 terminals 

Texas 38 terminals. 

After the brief introduction by Mr. Prokop, Mr. LaFlam requested to know how many, 

or alternatively, what percentage ofthe ILTA member facilities are major sources. Mr. Prokop 

referred to Usha Mehra, GATX, for a reply. Ms. Mehra and Mr. Prokop responded that the 

major source status was very much dependent upon the business activity of a particular year, 

and therefore any fixed number, or estimate would be very difficult to make. It was stated that 

ITLA member facilities are very flexible in their business practices, something which Mr. 

Prokop referred to as the "distribution miracle". It was estimated by the ILTA representatives 

that a fair number of major sources exist witbjn the continental U.S. Ms. Mehra also added that 

terminals would desire to attain MACT applicability criteria on any given year to accomodate 

potential clients and their organic liquids. 

Survey Data Issues 

Ms. Mehra next addressed O.L.D. MACT survey data issues. She mentioned that only 

13 percent ofthe respondents, or 32 facilities are terminals in SIC code 42. She also mentioned 

that the survey data base is dominated by facilities with primary SIC codes 28 and/or 29. Ms. 

Mehra mentioned that the ILTA and its member facilities are very concerned about being 

"lumped in with the big boys". The ILTA's concern, voiced by Ms. Mehra, was that terminals 

are not as profitable as chemical/petrochemical manufacturers or petroleum refineries and 

would therefore carry a higher burden to accomodate MACT control costs. 

The ILTA stated that it believes that its member facilities cannot be lumped in with 

other SIC codes (primarily 28, 29) as business practices are completely different. The ILTA 

therefore requests a subcategorization scheme for its member facilities. Additionally, Ms. 

Mehra mentioned that she was hoping that the O.L.D.'s applicability criteria will require a 

facility to have actual emissions totaling 10 tpy for a single HAP, or 25 tpy for a combination of 

HAP. A similar scheme basing applicability on actual emissions is being used in 40 CFR 63, 

subpart Y (Marine Vessel Loading MACT). The EPA responded that it had not yet decided on a 

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Memo-ILTA Meeting 

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subcategorization scheme, but that any information sent to it by the ILTA would be evaluated. 

Additionally, the EPA stated that it did not see a reason to deviate from the 10/25 tpy HAP 

applicability criteria. 

Wastewater Issues/Concerns 

The ILTA next mentioned that based on the December 1998 roundtable, it was very 

concerned with the way in which the EPA was proposing to regulate O.L.D. derived/produced 

wastewater. Ms Mehra was asked by a member ofthe EPA/PES project team what she 

considers to be the main sources of O.L.D. derived wastewater. A consultation between Ms. 

Mehra, Mr. Bailey, and Mr. Roesch revealed that the principal sources of O.L.D. wastewater 

are: 

• Tank cleanings 

• Hydrostatic testwater 

• Water in manifold areas 

• Condensation of water in tanks. 

Ms. Mehra went on to say that these sources of wastewater are intermittent, and usually low in 

volume. Furthermore, she added, no process wastewaters are generated by O.L.D. operations. 

The ILTA also mentioned that very few terminals actually have wastewater treatment facilities, 

but that some facilities treat wastewater generated by clients. Therefore, very few ILTA 

member terminals have RCRA permits to store or treat wastewater containing hazardous waste. 

This practice, according to Ms. Mehra, is not typical for the industry. Most wastewater 

generated by O.L.D. operations at terminals is shipped offsite to a commercial treatment, 

storage, and disposal facility (TSDF). 

Ms. Smith, EPA, informed the ILTA and its representatives that the EPA was not 

planning on regulating wastewater generated by O.L.D. operations. Ms. Smith stated that the 

survey did not yield enough usable information for the EPA to set MACT floors for HAP 

emissions from wastewater. She also stated that the a potential future regulation might address 

wastewater at terminals. 

LDAR Concerns/Issues 

The ILTA expressed its concerns regarding the unofficial EPA position to require 

instrument monitoring at O.L.D. operations. The ILTA stated that emissions from equipment at 

terminals are very low and do not warrant the expensive instrument monitoring which the EPA 

proposes to require for the entire O.L.D. industry. Ms. Mehra stated that gasoline distribution 

terminals are not required to perform instrument momtoring, and that gasoline has an average 

• vapor pressure in excess of most liquids handled at O.L.D. terminals. 

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Memo-ILTA Meeting 

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As an example, Mr. Jim Bailey, Houston Fuel Oil Terminal Company, remarked that 

oftentimes the EPA's Method 21 will not detect leaks. Instead, leaking equipment can often be 

spotted visually, as is the case for equipment handling crude oil. Furthemore, Mr. Bailey added 

that he was required to perform weekly instruments using both Method 21 and AVO (as a 

condition of his operating permit from the State of Texas). 

Ms. Mehra stated that the States of New Jersey, Texas, and California require terminals 

to conduct instrument monitoring on equipment. In Texas, both audiovisual and instrument 

monitoring are conducted due to Federal and State requirements as some facilities. The ILTA 

stated that it was hoping to avoid this type of situation with the O.L.D. MACT. 

Ms. Smith responded by stating that she is not opposed to AVO monitoring of 

equipment at O.L.D. terminals, but, she added, she would need information regarding leak 

frequencies and LDAR programs at terminals in the U.S. Ms. Mehra responded that she might 

be able to conduct a quick survey of LDAR programs at terminals. The information obtained 

from this survey would be forwarded to the EPA for consideration. The information provided 

to the EPA would include: 

• Operating conditions 

• Actual leak rates and frequencies 

• Equipment emission factors commonly used at terminals 

Ms. Mehra also added that it is in the best business interests of terminals to have minimal 

equipment leaks. The ILTA informed the EPA that terminals are allowed by their customers to 

have a 0.25 percent product loss. This low percentage does not make it in the best interest ofa 

facility to lose product through equipment leaks, transfer operations, or storage tanks. 

The ILTA representatives were also questioned by the EPA/PES project team on the use 

of compressors at terminals. Compressors were reported to the EPA in O.L.D. service, but their 

specific function is not known. The ILTA representatives responded that compressors are used 

to produce compressed air, which is used to clean lines, test hoses, and for optimizing boiler 

performance. They also stated that compressors are not used to directly transfer organic liquids 

at terminals. 

Proposed Rule and Cutoffs 

The ILTA inquired what the future O.L.D. MACT would regulate. It was informed that 

the following emission points would potentially be regulated by the O.L.D. MACT: 

• Storage vessels 

• Transfer operations 

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Memo-ILTA Meeting 

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• Containers (55 gallons or larger) 

• Equipment leaks. 

Mr. LaFlam stated that the EPA was currently considering HAP percentage cutoffs in lieu ofa 

vapor pressure cutoffs to determine which liquids would be regulated. Ms. Mehra opposed this 

because many client companies do not provide them with complete product infonnation ofthis 

sort, rather they provide ranges of HAP. Therefore, she stated that it would be very difficult for 

ITLA member terminals to determine which liquids to regulate, and when. Furthermore, she 

stated that it would be easier for facilities to comply with vapor pressure cutoffs or throughput 

cutoffs as are used in cunent rules. 

Ms. Mehra was asked by the EPA what she would consider an acceptable transfer rack 

or business throughput. She did not have a ready answer but refened to various State rules for 

guidance. Ms. Mehra also mentioned that due to business practices, a 30-day rolling average of 

throughputs would be beneficial. She was also informed that the survey data base used by the 

EPA to set MACT floors did not yield any usable transfer rack throughputs. 

Conclusion of Meeting 

The ILTA inquired what the topics of conversation would be at the next roundtable 

meeting, which is to be held on October 5,1999 at the EPA in RTP, North Carolina. The ILTA 

representatives were informed that likely topics would include elements ofa draft rule, 

comments on the Model Plants memo, rule impacts, and other issues that are to be determined. 

The EPA also informed the ILTA that it will be sending out an informational package to the 

stakeholder group on or around September 15,1999. 

Ms. Mehra proceeded to summarize the major points discussed at the meeting. 

Following this, the meeting was adjourned. 

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OLD - MACT MEETING EPA & ILTA 

AUGUST 19,1999,1p.m. 

RTP, NC. 

• ILTA Industry overview - John Prokop, ILTA 

• OLD - MACT, Survey data issues - Usha Mehra, GATX 

• Proposal for categorization of OLD Regulation - Usha Mehra, GATX 

• Status of LDAR flexibilities and wastewater collection control issues in OLD Rule - EPA 

• Miscellaneous issues 

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