UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 1 

August 14, 1998 

Jeff Crawford 

JOHN F. KENNEDY FEDERAL BUILDING 

BOSTON, MASSACHUSETTS 02203-0001 

Bureau of Air Quality Control 

Department of Environmental Protection 

State House, Station No. 17 

Augusta, ME 04333 

Dear Mr. Crawford: 

The Maine Department of Environmental Protection (DEP) is 

currently proposing revisions to its Chapter 111 "Petroleum 

Liquid Storage Vapor Control" regulation. EPA has reviewed the 

proposed revisions and comments are provided in the Enclosure. 

If you have any questions regarding the enclosed comments, please 

contact Anne Arnold at (617) 565-3166. 

Sincerely, ~- _ ~ _ 

~~ Air Quality ~nr~~ger Planning Unit 

Enclosure 

cc: Carolyn Wheeler, ME DEP 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed with Vegetable OU Based Inks on Recycled Paper (Minimum 25"/o Postconsumer) 
ENCLOSURE 

COMMENTS ON MAINE 1 S PROPOSED REVISIONS TO 

CHAPTER 111 "PETROLEUM LIQUID STORAGE VAPOR CONTROL 11 

1. EPA finds the revisions to Maine's rule acceptable as 

proposed. The state, however, has asked EPA to articulate if 

there are alternatives to the proposed revisions which would also 

be acceptable. According to the New Source Performance Standards 

for storage tanks (40 CFR Part 60 Subpart Kb), tanks with a 

double seal system have the following options: 1) conduct a 

complete inspection every 5 years; or 2)conduct annual visual 

inspections and a complete inspection every 10 years. States can 

adopt similar language for their volatile organic liquid storage 

tank regulations at their discretion. See also "Alternative 

Control Techniques Document: Volatile Organic Liquid Storage in 

Floating and Fixed Roof Tanks" (EPA 453/R-94-001, January 1994). 

2. Once adopted, these revisions should be submitted to EPA as a 

State Implementation Plan (SIP) revision. Since Maine's Chapter 

111 was approved into the Maine SIP prior to 1990, the revised 

Chapter 111 SIP submittal should address the Clean Air Act 

Section 193 Savings Clause. The Savings Clause requires that 

revisions to pre-1990 control requirements result in equivalent 

or greater emissions reductions. 

As noted in a July 3, 1997 letter to DEP, tank inspections which 

involve the degassing and refilling of a storage tank cause 

volatile organic compounds (VOC) to be emitted to the atmosphere. 

EPA has estimated the quantity of VOC emissions resulting from 

this activity. See Appendix B of "Gasoline Distribution Industry 

(Stage I) - Background Information for Promulgated Standards" 

(EPA-453/R-94-002b) . For example, the degassing and refilling of 

a 150 foot diameter tank is estimated to generate approximately 6 

tons of VOC. Since the version of Chapter 111 currently in 

Maine's SIP requires complete inspections to be conducted 

annually, the revisions being proposed and the alternative 

revisions discussed in comment #1 will result in fewer 

degassings, and therefore less emissions, than the current 

Chapter 111 SIP rule. 
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RUG-07-1998 10:37 77826 207 287 764 P.01/04 • . .( 

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6 DEPWTMENT OF ENVIRONMENTAL PRO~TION 

ter 111: PETROLEUM LIQUID STORAGE VAPOR CONTROL 

SUMMARY: This regulation requires all owners of fixed roof storage tanks, 

storing gasoline, crude oil or any petroleum liquid whose vapor pressure is 

greater than 1.52 psia (1 0.5 kilo pascals) to install floating roofs to reduce the 

hydrocarbon vapors lost to the atmosphere . 

This regulation sl-lall be 't'pliea~le applies in all ambient air quality regions of the State of 

Maine. 

This regulation shell aJ:~J:~lo>· applies to all fixed roof storage vessels with capacities greater than 

l 50,000 liters (39,000 gallons) containing volatile petroleum liquids whose true vapor pressure is 

greater than 10.5 kilo pascals ( 1.52 psi a) or a Reid vapor pressure of 4 psi. Such fixed roof 

storage vessels are subject to New Source Performance Standards as of the dates specified in and 

in accordance with the requirements contained in 40 CFR, Part 60, Subparts K, Ka, and Kb. 

C. Section S(B) of this regulation shall apply to all fixed roof storage vessels \vith capacities greater 

than 150,000 liters (39,000 gallons) containin~ ;volatile petroleum liquids whose true vapor 

pressure is greater than 1.0 psia but less than 1.52 psia. 

z. Prohibition. No owner or operator of a fixed roof storage vessel shall permit or suffer the use of 

such vessels unless: 

A. The vessels have been retrofitted with an internal floating roof equipped with a closure seal, or 

seals, to reduce the visual space between the roof edge and tank wall; or the vessels have been 

retrofitted with equally effective alternative control as approved by the Commissioner and the 

United States Environmental Protection Agency; 

B. The vessel is maintained such that there arc no visible holes, tears, or other openings in the seal 

or any seal fabric or materials; 

C. All openings except stub drains are equipped with covers, lids, or seals such that 

( 1) the cover, lid, or seal is in the closed position at all times except when in actual use; &!TEl 

(2) automatic bleeder vents are closed at all times except when the roof is being floated off or 

being landed on the roof leg supports; and 

(3) rim vents, if provided, are set to open only when the roof is being floated off the roof leg 

supports or at the manufach1rer's recommended setting; 

D. Routine inspections are conducted through roof hatches once every six (6) met\\hs month; and 

E. A complete inspection of cover and seal is eeFu.iweted at least eAee per year performed when the 

tank is degassed and cleaned, at a minimum of once in ten (1 0) years for a single seal system and 

a minimum of once in five (5) years for a double seal system. 
AUG-07-1998 10:39 77826 207 287 764 P.02/04 

1 '-' ~ 06-096 DEPARTMENT OF ENVIRONMENTAL PROTECTION 

3. Emission Testing. The determination of compliance under this section may be made by visual 

inspection of the floating cover through the roof hatches by Department staff or other qualified 

representatives of the Department. The source shall be found in compliance if: 

A. The seal has no visible holes, tears, or other openings and is uniformly in place:' around the 

circumference of the cover between the cover and tank well; 

B. The cover is uniformly floating on or above the liquid and there are no visible holes, tears, or 

other openings in the surface of the cover and no liquid is accumulated on the cover; and 

C. All records are being properly maintained. 

4. Transition Schedule. The owner or operator of fixedwroof petroleum storage vessels located in Air 

Quality Control Regions III, IV and V shall have until July I, 1991, to comply with the requirements 

under subsection 2, paragraph A. In Air Quality Control Regions Hl, IV and V, the owner or 

operator of a fixed-roof petroleum storage vessel without a floating roof or other acceptable volatile 

organic compound emission control equipment shall adhere to the increments of progress contained 

in the following schedule and shall report to the department within 15 days ofthe prescribed deadline 

the status of compliance with H-le each increment of progress. 

~· 

A. Final plans for the floating roof, other necessary modifications or other acceptable volatile 

organic compound emission control equipment shall be submitted before November l, 1989. 

B. Contracts for installation of the floating roof, other modifications or other acceptable volatile 

organic compound emission control equipment or purchase orders for component parts shall be 

issued before March I, 1990. 

C. Initiation of on-site construction or installation of acceptable volatile organic compound emission 

control equipment shall begin before July l, 1990. 

D. Final compliance shall be achieved before July 1, 1991. 

5. Records 

A. The owner or operator of a fixed roof storage vessel ~efeEI wRaer the see~..ef governed by this 

regulation shall assure the following records are maintained for a minimum of two years. These 

records shall be available for inspection during normal business hours and copies shall be 

provided to the Commissioner or his representative upon request: 

(I) Reports of the results of inspections conducted under paragraphs (2)(D) and (2)(E); 

(2) A record of the monthly throughput quantities and types of volatile petroleum liquids for 

each storage vessel and period of storage; and 

(3) Records of the average monthly storage temperatures and tl'ue vapor pressures of volatile 

petroleum liquids stored. 

Chapter Ill: Petroleum Liquid Storage Vapor Control 

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AUG-07-1998 10=38 77826 207 287 764 P.03/04 

06-096 '- ""' DEPARTMENT OF ENVIRONMENTAL PROTECTION 

B. The owner or operator of a fixed roof storage vessel with capacity greater than 150,000 liters 

(39,000 gallon:s) containing volatile petroleum liquids whose true vapor pressure is greater than 

I .0 psia but less than 1.52 psia. shall assure the following records are maintained for a minimum 

of two years. These records shall be available for inspection during normal business hours and 

copies :shall be provided to the Commissioner or his representative upon req\lest: 

(l) Records of the average monthly storage temperatures, the type of petroleum liquid, and 

maximum true vapor press\Jres of volatile petroleum liq~dds stored. 

AUTHORITY: 38 M.R.S.A.> Section 585, 585-A 

EFFECTIVE DATE: May 7, 1979 

Amended: September 21, 1988 

Amended; October 3, 1989 

Amended: November 3, 1990 

Amended: 

BASIS STATEMENT 

"' 

Gasoline is a hydrocarbon vapor that aids the formation of ozone in the atmosphere. It is necessary to 

control SIJCh hydrocarbon vapors present in the atmosphere because Maine is violating the federal ozone 

ambient air quality standard. This regulation controls the maximum amount of gasoline emissions so to 

reduce the ozone formed. 

BASIS STATEMENT FOR AMENDMENT OF AUGUST 10,1988 

This amendment expanded the scope of the regulation to include all Ambient Air Quality Control 

Regions in the State. Uncontrolled gasoline storage terminals in the Downeast and Central Maine 

Ambient Air Quality Control Regions have been estimated as emitting over 800 tons of hydrocarbons 

annually. The use of floating roofs and vapor control systems (Chapters 111 and 112) for bulk gasoline 

t~rminals is considered Best Practical Treatment and will reduce emissions by about 94 percent. 

BASIS STATEMENT FOR AMENDMENT OF SEPTEMBER 27,1989 

This amendment corrected certain minor deficiencies identified by the U.S. Environmental Protection 

Agency in the State Implementation Plan and for consistency with State statute. The U.S. Environmental 

Protection Agency also commented on requiring facilities which store more than 39,000 gallons of 

petroleum products with a true vapor pressure greater than 1.0 psi to maintain records of the average 

monthly temperat\Jre and the maximum true vapor pressure. The Department agrees with the comment. 

This will enable the Department to determine if storage tanks storing liquids with vapor pressure close to 

1.52 psi are subject to the regulation. 

Chapter 111: Petroleum Liquid Storage Vapor Control 

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I 'I -..., t.J . 06-096 DEPARTMENT OF ENVIRONMENTAL PROTECTION 

BASIS STATEMENT FOR AMENDMENT OF SEPTEMBER 26, 1990 

During the 114th Session of the Maine Legislature, the Board of Environmental Protection was given the 

authority under 38 M.R.S.A. 585 and 585-A to establish and amend emission standards and regulations to 

implement ambient air quality standards and emission standards. This rule was amended to reflect the 

new authority under statute. No request for public hearing nor colilm~nts were received on the 

reauthorization. 

BASIS STATEMENT FOR AMENDMENT OF 

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Chapter 111: Petroleum Liquid Storage Vapor Control 

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