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,

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# ~~**~nr~~ger** Air Quality Planning Unit Enclosure
cc: Carolyn Wheeler, ME DEP

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printedwith Vegetable OU Based Inkson 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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### 8 RUG-07-1998 10:37 77826 207 287 764 P.01/04

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### 6 DEPWTMENTOF ENVIRONMENTAL

# PRO~TION
ter 111: 

### PETROLEUMLIQUID STORAGEVAPORCONTROL SUMMARY: This regulation requires all owners offixed roof storage tanks, storing gasoline, crude 

### oil or any petroleum liquid whose vapor pressure is greater than 1.52 psia (10.5 kilo pascals) to install floating roofs to reduce the hydrocarbon vapors losttothe 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 

### l50,000 liters (39,000 gallons) containing volatile petroleum liquids whosetrue vapor pressure is greater than 10.5 kilo pascals (1.52 psia) or 

### a Reid vapor pressure of4 psi. Such fixed roof storage vessels are subjectto

### New Source Performance Standards as ofthe dates specified in and in accordance with 

### the requirements contained in

### 40 CFR, Part 60, Subparts 

### K, Ka, and Kb. C. Section S(B) ofthis regulation shall apply to all fixed roofstorage vessels\vith capacities greater than 150,000 liters (39,000 gallons)**containin~** ;volatile petroleum liquids whose true vapor pressure is greaterthan 

### 1.0 psiabut lessthan 

### 1.52 psia. 

# z. Prohibition. No owner or operator ofa 

### fixed roof storage vessel shall permit or suffer the use of such vessels unless: A. The vessels have been retrofitted with an internal floating roofequipped with a closure seal, or seals, to reduce the visual space between the roofedge and tank wall; or the vessels have been retrofitted with equally effective alternative control as approved by the Commissioner and the United StatesEnvironmental Protection Agency; B. The vessel is maintained such that there arc no visible holes, tears, or other openings in the seal orany seal fabric or materials; 

### C. All openingsexceptstub drains are equippedwith covers, lids, or seals suchthat (1) the cover, lid, orseal is in the closed position at all times exceptwhen in actual use; 

### &!TEl (2) automatic bleeder vents are closed at all times except when the roof is being floated offor being landed on theroofleg supports; and (3) rim vents, ifprovided, are set to open only when the roof is being floated offthe roof leg supports or atthe manufach1rer's recommended setting; D. Routine inspections are conductedthrough roofhatches onceevery six(6) met\\hs month; and E. A complete inspection ofcover and seal is eeFu.iweted at least eAee peryear performed when the tank is degassed and cleaned, ata minimum ofonce in ten (1 0) years for a single seal system and a minimum ofonce 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 ENVIRONMENTALPROTECTION

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

### made by visual inspection ofthe floating cover through the roof hatches by Department staffor other qualified representatives ofthe 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 coverbetweenthe coverand tankwell; 

### B. The cover is uniformly floating on or above the liquid and there are no visible holes, tears, or other openings in the surface ofthe coverand no liquid is accumulatedon the cover; and C. All records 

### are beingproperly maintained. 4. Transition 

### Schedule. The owner or operator offixedwroofpetroleum 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-roofpetroleum storage vessel without 

### a floating roofor other acceptable volatile organic compound emission control equipment shall adhere to the increments ofprogress contained in the following schedule and shall report to the departmentwithin 15 days ofthe prescribed deadline the status ofcompliancewith 

### H-le each increment ofprogress.**~·** 

### 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 ofthe 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 ofon-site construction or installation ofacceptable volatile organic compound emission control equipment 

### shall begin before July 

### l, 1990. 

### D. Final compliance shall be achieved beforeJuly 1, 1991. 5. Records A. The owneror operatorofa fixed roofstorage vessel**~efeEI** wRaerthe**see~..ef**governed by this regulation shall assure the following records are maintained for a minimum oftwo years. These records shall be available for inspection during normal business hours and copies shall be providedto the Commissioneror his representative upon request: (I) Reports ofthe results ofinspections conducted under paragraphs (2)(D)and (2)(E); (2) A record of

### the monthly throughput quantities and types ofvolatile petroleum liquids for each storage vessel and period ofstorage; and (3) Records ofthe average monthly storage temperatures and tl'ue vapor pressures of volatile petroleum liquids stored.
Chapter Ill: Petroleum Liquid Storage VaporControl 

### ·2-AUG-07-1998 10=38 77826 207 287 764 P.03/04 06-096 

# '- ""' DEPARTMENT OF ENVIRONMENTAL PROTECTION
B. The owner or operator ofa 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 assurethe following records are maintained for a minimum oftwo years. These records shall be available for inspection during normal business hours and copies :shall be provided to the Commissionerorhis representative upon 

### req\lest: (l) Records of the average monthly storage temperatures, the type of petroleum liquid, and maximum true vaporpress\Jres ofvolatile petroleum**liq~dds** stored.
AUTHORITY: 38M.R.S.A.> Section 585, 585-A EFFECTIVE DATE: May 7, 1979 Amended: September21, 1988 Amended; October 3, 1989 Amended: November

### 3, 1990 Amended:

BASISSTATEMENT "' Gasoline is a hydrocarbon vapor that aids the formation ofozone 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 ofgasoline emissions so to reducethe ozone formed. BASIS STATEMENTFORAMENDMENT

### OFAUGUST 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 ofhydrocarbons annually. The 

### use offloating roofs and vapor control systems (Chapters 

### 111 and 

### 112) for 

### bulk gasoline**t~rminals** is considered BestPractical Treatment and will reduce emissions by about 94 percent. BASIS STATEMENTFORAMENDMENT OF SEPTEMBER27,1989 This amendment corrected certain minor deficiencies identified by the U.S. Environmental Protection Agency in the State Implementation Plan and for consistencywith 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 ofthe average monthly temperat\Jre and the maximum true vapor pressure. The Department agrees with the comment. This will enable the Department to determine ifstorage tanks storing liquids with vapor pressure close to 

### 1.52 psi are subjectto theregulation.

Chapter 111: Petroleum Liquid Storage VaporControl
•3 -AUG-07-1998 10:39 77826 207 287 764 P.04/04

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.06-096 DEPARTMENT OF ENVIRONMENTALPROTECTION

BASIS STATEMENTFORAMENDMENT OFSEPTEMBER26, 1990 

### During the 114th Session ofthe Maine Legislature, the Board ofEnvironmental Protection was given 

### the authorityunder

### 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 STATEMENTFORAMENDMENT OF

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Chapter 111: Petroleum Liquid Storage VaporControl -4-