p.1 

OAR Box 1670 

Prepped by Charmelle Mathews 

Document Number: 

3<g ^ ) ll-D-170 

Docket Number: 

A-98-13 

Printed 9/24/2008 11:55:14 AM Sheet 39 of 56 
P.2 

L_ PAKTANK CORPORATION 

August 17, 1998 

Bruce C. Jordan, Director 

Emission Standards Division (MD-13) 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

Attention: Stephen Shedd 

RE: Exxon Chemical Company - Leland Terminal 

O.L.D. Survey 

Dear Mr. Jordan: 

A 98 13 

II-O - no 

2000 West Loop South, Suite 2200 

Houston, Texas 77027-3597 

(713)623-0000 

FAX: (713) 623-4480 

E-Mail: paktank@pakhoedcorp.com 

FILE COPY 

9t>/e£'Gc* 

*• '.'V 

tPAr.lRUOCKF.T 

Enclosed please fmd a completed O.L.D. Survey for the Exxon Leland Terminal. Paktank 

Corporation completed the survey as we are the operator of this terminal for Exxon Chemical 

Company. 

As a supplier to several members of the National Association of Chemical Distributors, Exxon 

believes that some of the information requested by the EPA in this survey should be treated as 

Confidential Business Information (CBI). The following numbered items are our request for 

confidentiality and rationale: 

1: Organic Liquid Handled and HAP Content 

III. HJ\P Constituent: Average Liquid Weight %/ average Vapor Weight % 

RE: MSDS only contains HAPs constituent, not its percent in product 

2: Storage Tank Control Data 

(c) Name(s) of Stored Liquid(s) 

RE: Would provide competitor with tank capacity & throughput for each of our 

trademarked and sole supply products at each distributor or terminal. 

3: Liquid Transfer Operations 

(a) Organic Liquid Transferred through Facility 

RE: Same rationale as no. 2, above. 

Please note that we have enclosed two separate copies of the survey for each facility. One 

copy is complete and stamped Confidential, and the second copy has the confidential 

information deleted. 
P.3 

'.»*> ? 

Bruce Jordan, Director 

August 17, 1998 

Page 2 

Should you have any questions regarding this survey, please contact Thomas Land or me at 

(713) 623-0000. 

Very truly yours, 

~JZ%Z,r/^e<// 

Quirino Q. Wong 

Manager, Environmental Affairs 

On behalf of Exxon Chemical Company - Leland Terminal 

QQW/TDL:rmm 

2_ 
P.4 

Bruce C. Jordan, Director 

Emission Standards Division (MD-13) 

Office of Air Quality Planning and Standards 

U. S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

Attention: Stephen Shedd 

II. GENERAL INFORMATION 

A. Name oflegal owner (i.e., parent company) ofplant: Exxon Chemical Company 

B. Is the company publicly or privately owned? Public 

C. Name oflegal operator ofplant, if different from legal owner: Paktank Corporation 

D. Address oflegal owner/operator (please specify which): Paktank Corporation. 2000 West 

Loop South. Suite 2200. Houston. Texas 77027 

E. Size of company/plant: 

1. Approximate number of employees of the business enterprise that owns this plant, 

including where applicable, the parent company and all subsidiaries, branches, and 

unrelated establishments owned by the parent company: 80.000 

2. Total number of employees ofthe business enterprise that operates this plant: -0-

3. a) Number of employees at the entire plant site 2 

b) Number of employees associated with the organic liquids distribution (nongasoline) operations at this plant: 2 

c) Number of organic liquids distribution operations employees that are contract 

employees 2 

F. Name ofplant: Exxon Chemical Company - Leland Terminal 

G. Street address ofplant: 3500 Mount Misery Road 

City, State, Zip code: Leland. NC 28451 

H. Dun and Bradstreet number: 00-121-3214 

3 
P.5 

2 

I. Latitude and longitude coordinates of plant: 34° 15'28" N 77°22'0" 

J. Name of contact(s) able to answer technical questions about the completed survey: 

Name Thomas Land 

Title Environmental Specialist 

Telephone 713-623-0000 

Name Jason Whichard 

Title Safety. Health & Environmental Specialist 

Telephone 910-799-0144 

A 
P.6 

TABLE 1. ORGANIC LIQUIDS HANDLED AND HAP CONTENT(a) 

(SURVEYED LIQUIDS) 

I. Organic Liquid Name (b) "CBI" See separate report submittal 

II. Properties (use the same reference temperature for a. and b., and indicate temperature.) 

a. Average True Vapor Pressure (psia): 

b. Density (lb/gal): 

c. Reid Vapor Pressure (psia): 

d. Liquid Molecular Weight (lb/lb-mol @ 70°F): 

e. Vapor Molecular Weight (lb/lb-mol @ 70°F): 

0.1413(g). 71.37° F 

747? 

0.3191 

106.16 

III. HAP Constituents (ofthe organic liquid listed above): 

HAP Constituent (c) 

1,4 dimethyibehzene '-'-

 ?>

 '" 

CAS No. 

106-42-3 

Average Liquid 

Weight % 

99.7% 

Average Vapor 

Weight % 

(Note: Insert lines as required to list all HAP constituents in the organic liquid. Make sufficient copies ofthis 

sheet to list all your organic liquids and their HAP constituents.) 

a). Do not list wastewater in this table (for wastewater, refer to Tables 4 and 5). 

b). Provide the complete name for the organic liquid being reported. Ifthe liquid is pure HAP, 

refer to Attachment A and use the name or CAS number shown. For organic liquids referenced 

in Table 8, the family name ofthe liquid may be used in lieu of listing each individual blend. 

c). List all the HAP constituents present in the organic liquid identified in item I. Refer to 

Attachment A for a complete HAP name and CAS No. listing. 

6 
TABLE 2. STORAGE TANK CONTROL DATA 

G^ 

Tank ID 

Code 

(a) 

T-2149 

Tank Capacity 

(gal) 

(b) 

CBI 

Name(s) of Stored 

Liquid(s) 

(c) 

CBI 

• 

Annual 

Throughput 

(gal/yr) 

(d) 

CBI 

Roof 

Configuration 

(e) 

FXR 

Floating Roof 

Tank Only: 

Seal Type 

ffl 

Tank Roof 

Fittings 

(g) 

Add-on 

Control 

Device 

00 

N 

Applicable Air 

Regulations 

(0 

Pre-k 

See end of table for footnotes. 

TJ 
TABLE 3. LIQUID TRANSFER OPERATIONS 

-a 

Organic Liquid 

Transferred through 

Facility 

(a) 

CBI 

Incoming Type 

of Transport 

Vehicle or 

Container 

(b) 

PL 

Loading Rack ID 

Code 

(c) 

Loading Arm 

ID Code 

(d) 

Outgoing 

Typeof 

Transport 

Vehicle or 

Container 

(b) 

PL 

Annual Volume 

of Transferred 

Liquid 

(gal/yr) 

CBI 

Method of 

Loading or 

Unloading 

(e) 

BTM 

Average 

Loading or 

Unloading 

Rate 

per Arm 

(gal/min) 

CBI 

Vapor 

Control 

Device 

(0 

Control 

Device 

Efficiency 

(g) 

See end of table for footnotes. 

TJ 

00 
TABLE 4. WASTEWATER FLOW RATES AND DRAIN CONTROLS 

CO 

Source of OLD 

Wastewater 

(a) 

N/A 

Total Flow 

Rate 

(gal/yr) 

HAP Name 

(b) 

HAP Concentration 

in Water (ppmw) 

(c) 

Number of Drains 

with Emission 

Suppression 

(d) 

Number of Drains 

without Emission 

Suppression 

(d) 

a). OLD = Organic Liquids Distribution. Select the codes that best describe the points of wastewater generation (insert codes as required and 

provide a full description): 

TC =tank cleanings 

LR =loading racks (identify the specific racks using the same rack codes as in footnote "a" of Table 3. 

LC = 

line cleanings 

LB =liquid blending/packaging operations 

OT =other, please provide full description (use extra sheet, if necessary). 

b). List the principal HAPs typically present in each wastewater stream. 

c). Estimated annual average concentration during periods of nominal flow in ppmw. 

d). Emission suppression controls reduce emissions from drain pipes and include, but are not limited to, water seal pots and p-traps. 

TJ 

CO 
TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL (a) 

-0 

OLD Wastewater 

Treatment Unit 

Total Number of 

Units on Site 

(c) 

No. of Uncovered 

Units that Vent to 

the Atmosphere (d) 

No. of Covered 

Units that Vent to 

the Atmosphere (d) 

No. of Units that 

Vent Emissions to a 

Control Device 

Control Device 

(e) 

Source of Wastewater (b): Not Applicable 

CatleMonVaHs 

Manholes 

Junction Boxes 

Sumps/Catch Basins 

Lift Stations 

Storage Tanks 

(0 

N/A 

N/A 

N/A 

N/A 

N/A 

Treatment Units 

Oil/Water Separators 

Air Flotation Systems 

Coagulation/Precipitation 

Units 

Sand Filtration Unit 

Equalization Units 

N/A 

N/A 

N/A 

N/A 

N/A 

See end of table for footnotes. 

TJ 

O 
TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL (a) (Continued) 

0 

OLD Wastewater 

Treatment Unit 

Total 

Number of 

Units on Site 

(0 

No. of Uncovered 

Units that Vent to 

the Atmosphere 

(d) 

No. of Covered 

Units that Vent to 

the Atmosphere 

(d) 

No. of Units that 

Vent Emissions to a 

Control Device 

Control Device 

(e) 

Source of Wastewater (b): Not Applicable 

Treatment: Units 

Oxidation Ponds 

Activated Sludge Units 

Trickling Filters 

Clarifiers 

Filter Presses 

Strippers 

Effluent/Recycle Pond 

Rotating Biological 

Contractors 

Ship Off Site 

GO 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

0 

See end of table for footnotes. 
TABLE 6. SEMI-AQUEOUS WASTE COLLECTION AND CONTROL (a) 

Type of Waste 

(b) 

Not Applicable 

Waste Generation 

Rate 

(tons/year) 

(c) 

Waste Collected in 

a Closed System? 

(Yes/No) 

(d) 

Method of On-Site 

Storage 

(e) 

Waste Treated or 

Disposed of OnSite? (Yes/No) 

ffl 

Method of On-Site 

Treatment or 

Disposal 

(g) 

Control Device on 

Treatment or 

Disposal Unit 

(h) 

See end of table for foomotes. 

TJ 

to 
P.13 

10 

TABLE 7. EQUIPMENT LEAK CONTROL DATA 

1. Is there a formal, periodic equipment leak detection and repair (LDAR) program? Yes • No X 

Comments: 

2. Please indicate which Federal/State/local rules require an LDAR program at this facility: 

aV N/A 

b). 

c). 

3. If a formal equipment LDAR program has been implemented at your plant, provide the following information: 

Definition ofa Leak* 

Leak Detection Methodb 

Leak Response Time0 

E 

B 

5/15 

a). Leak definition codes: 

A = 500 ppmv 

E = Sensory detection 

D = Bubble formation 

b). Leak detection codes: 

A = EPA Method 21 (vapor detector) 

B = Sight (e.g., drips), smell, sound 

C = Gas detection/alarm system 

C = 10,000 ppmv 

B= 1,000 ppmv 

OT = Other (specify) 

D = Soap water application 

E = None 

OT = Other 

c). Provide the maximum allowable time after detection to begin and complete repair ofa leak. 

IJ) 
bz 

n 

TABLE 7. EQUIPMENT LEAK CONTROL DATA (Concluded) 

Equipment 

Component 

Valves 

Compressors 

Flanges 

Pumps 

Sampling Connections 

Pressure relief valves 

(to atmosphere) 

Inspection 

Frequency 

(a) 

40 

-

109 

1 

-

-

Total 

Equipment 

Count 

40 

-

109 

1 

— 

-

Equipment 

Count in 

LDAR 

Program 

0 

-

0 

0 

-

-

Equipment 

Count in 

LDAR with 

HAP Service 

0 

-

0 

0 

-

-

Equipment Counts 

with Mechanical 

Control Devices 

(b) 

0 

--

0 

0 

-

-

Equipment Counts with a 

Closed Vent System 

(c) 

0 

— 

0 

0 

— 

— 

Closed Vent 

System Control 

Device 

(d) 

0 

-

0 

0 

-

-

a). Inspection Frequency Codes: 

M = Monthly 

A = Annually 

OT = Other (specify) 

T = One time only 

Q = Quarterly 

E = After equipment change 

b). Provide equipment counts for equipment in HAP service with mechanical control devices such as: seal-less valves, pumps with dual mechanical 

seals and a barrier fluid, compressors with mechanical seals and a barrier fluid, and pressure relief valves with rupture disks. 

c). Provide equipment counts for equipment with a vapor collection and recovery (closed vent) system. 

d). Use the same control device codes and formats as in footnote "h" of Table 2. 

TJ 
P.15 

12 

TABLE 8. COMPOUNDING/BLENDING/PACKAGING OPERATIONS 

Parti. N/A 

Product Name 

(a) 

Not Applicable 

Chemical Composition 

(b) 

Annual Quantity 

Produced 

(gal) (c) 

Does a chemical 

reaction take place? 

(d) 

Applicable 

Regulations 

(e) 

a). 

b). 

c). 

d). 

e). 

Provide the product names resulting from blending, compounding, and packaging operations. 

Names must match those provided in Table 1. For families of blends, include only the family 

name listed in Table 1. 

Provide the names ofthe raw materials (must match Table 1) that are used to blend/compound 

the product. 

Provide the annual quantities ofthe products produced. 

Specify whether a chemical reaction takes place during the compounding or blending of 

organic liquids (i.e., yes-compounding, no-blending, etc.). 

Please identify any regulations (pertaining to air emissions) that apply to the 

compounding/blending operation. 

Part II. 

The questions below are facility-wide, and do not need to be answered on a product-by-product basis. 

Please answer the following questions with as much detail as possible. Insert sheets as necessary. 

1. Provide a description ofthe principal methods/mechanisms used for blending/compounding. 

Provide a detailed description of any mechanisms of vapor balancing or other vapor emission 

control utilized for these processes (e.g., submerged fill). 

;4 
P.16 

13 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

Control Device: Scrubber (b) 

Identifier Code(dV N/A 

Type ofscrubber: 

venturi 

packed bed 

impingement 

other (specify) 

Gas inlet temperature,

 CF 

Pressure drop, in. H,0 

Liquid-to-gas ratio, gal/103 acfm 

Inlet scrubbing liquor: 

PH 

percent solids 

type of alkali added, if any 

rate (lb/gal) 

Wastewater generation rate, gal/min 

HAP composition of wastewater, mg/l 

1. 

2. 

3. 

4. 

5. 

6. 

Emission Sources (c) 

See end of table for foomotes. 

)S 
P.17 

14 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Incinerator (b) 

Identifier Code Cdl: N/A 

Type: 

thermal 

catalytic 

Combustion chamber temperature, °F 

(please note if temperamre measurement is not in chamber) 

Excess air, % 

Nominal residence time, s 

Heat recovery: 

recuperative, percent heat recovery 

regenerative, percent heat recovery 

Emission Sources (c) 

1. 

2. 

3. 

4. 

5. 

6. 

See end of table for footnotes. 

)b 
P.18 

15 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Flare (b) 

Identifier Code (d): Not applicable 

Type: 

no assist 

steam assist 

air assist 

pressure assist 

Location: 

ground 

elevated 

Heat content ofvented stream, Btu/scf 

Flare gas exit velocity, ft/s 

Flare tip diameter, in. 

Flare height, ft 

Supplementary fuel for: 

pilot, scfm 

combustion purposes, scfm 

Steam requirement, lb/hr 

Emission Sources (c) 

1. 

2. 

3. 

4. 

5. 

6. 

See end of table for footaotes. 

n 
P.19 

16 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Carbon Adsorber (b) 

Identifier Code (d): N/A 

Type of carbon bed and number: 

regenerative non-regenerative 

fixed 

fluidized 

How many pounds of carbon per bed 

Configuration: 

" parallel 

serial 

Number of beds on-line 

Number of beds desorbing 

Pressure drop, in. H,0 

Gas inlet temperature, °F 

Type of regeneration 

Regeneration time 

Adsorption time 

1. 

2. 

3. 

4. 

5. 

6. 

Emission Sources (c) 

See end of table for foomotes. 

/8 
17 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Condenser (b) 

Identifier Code (d): >I/A 

Type of condenser: 

surface 

contact Tif contact, see scrubberl 

Gas inlet temperature, °F 

Gas outlet temperature, °F 

1. 

2. 

3. 

4. 

5. 

6. 

Emission Sources (c) 

See next page fpr footnotes. 

/<?