EPA/450/3-811003a OfficeofAirQuality EPA-450 3-81-003a :t1on Plann1ngand Standards ResearchTnangle Park NC27711 

# VOCEmissions fromVolatile OrganicLiquid Draft EIS StorageTanks

- BackgroundInformation forProposedStandards

Preliminary Draft

### EPA-450/3-81-003a



# VOCEmissionsfromVolatileOrganic LiquidStorageTanks

- BackgroundInformation forProposedStandards

EmissionStandardsandEngineeringDivision

U.S.ENVIRONMENTALPROTECTIONAGENCY OfficeofAir,Noise,andRadiation OfficeofAirQualityPlanningandStandards ResearchTrianglePark,NorthCarolina27711Section 1

2

3

4

5 TABLE OF CONTENTS

SUMMARY 1.1 Regulatory Alternatives 1.2 Environmental Impact. 1.3 Economic Impacts

... INTRODUCTION 2.1 Background and Authority for Standards

.... 2.2 Selection of Categories of Stationary Sources 2.3 Procedure for Development of Standards of 2.4 2.5 2.6 2.7 Performance

. . . . . . . . . . . . . . Consideration ofCosts

.. Consideration of Environmental Impacts. Impact on Existing Sources

..... . Revision of Standards of Performance. VOLATILE ORGANIC LIQUID STORAGE. 3.1 The Volatile Organic Liquid Storage Industry. 3.2 Storage Tanks

...... . 3.3 Baseline Control and Emissions Estimates. 3.4 References

.. CONTROL TECHNIQUES 4.1 Overview

... 4.2 Fixed Roof Tanks. 4.3 Internal Floating RoofTanks. 4.4 External Floating Roof Tanks. 4.5 Vapor Control or Recovery Systems on Fixed Roof Page 1-1 1-1 1-2 1-2

2-1 2-4
2-6 2-8 2-9 2-10 2-11 3-1 3-1 3-3 3-34 3-39 4-1 4-1 4-7 4-9 4-17 Tanks

. . . 4-20 4.6 References. 4-25 MODIFICATION AND RECONSTRUCTION. 5-1 5.1 Provisions for Modifications and Reconstruction 5-1 5.2 Applicabilityto Volatile Organic Liquid Storage. 5-3 (continued)

### TABLE OF CONTENTS (Concluded)
Section 6 REGULATORY ALTERNATIVES AND MODEL PLANTS 6.1 Regulatory Alternatives

7

8 

### 6.2 Model Plants

... ENVIRONMENTAL IMPACTS. 7.1 Introduction

... 7.2 Air Pollution Impacts 7.3 Water Quality and SolidWaste Impacts 7.4 Energy Impact

. . . . . . . . 7.5 Other Environmental Concerns 7.6 References COST ANALYSIS

.. 8.1 Capital Costs 8.2 Annualized Capital Costs. 8.3 Annualized Costs

.. . 8.4 Cost Effectiveness

... . 8.5 Cost ofOther Federal Regulations

. 8.6 Costs and Cost Effectiveness of Controls on an Page 6-1 6-1 6-4 

### 7-1 7-1 7-1 7-5 7-6 7-6 7-7 

### 8-1 8-2 8-18 

### 8-20 8-20 8-21 Individual Tank 8-27

9

APPENDICES8.7 References. 8-34 ECONOMIC IMPACT 9.1 Industry Profile 9.2 Economic Impacts of Regulatory Alternatives 9.3 Regulatory, Inflationary, Socioeconimic, and Small-Business Impact 9.4 References

A B

i i 

### 9-1 9-1 9-30 9-49 9-51

A-1 

### B-1Figure 3-1 3-2 3-3 3-4 3-5 3-6 3-7 3-8
3-9 3-10 3-11 3-12

4-1
4-2
4-3 4-4 9-1 9-2 LIST OF FIGURES

Typical fixed roof tank

... External floating roof tank

. Internal floating roof tanks. Primary seals

.. Rim-mounted secondary seals on external floating roofs

. . . . . . . . . . . . . . . . . . . Metallic shoe seal with shoe-mounted secondary seal Typical flotation devices and perimeter seals for internal floating roofs

............ . Rim mounting of a secondary seal on internal floating roof.

. . . . . . . . . . . . . . . . ... Typical internal floating roof tank cross section Internal floating roof deck fittings

.. Baselinecontrol summary....... . Baseline emissions totals (Mg/yr: 1977 tankpopulation) and numbers oftanks by vapor pressure/tank size region.

. . . . . . . . . . . . . . . . . Emissions rates for alternative equipment types (50 turnovers peryear)

. . . ........ . Emissions rates for alternative equipment types (10 turnovers peryear)

. . . . . . . . . . .. Carbon adsorption unit using steam regeneration Thermal oxidation unit

....... . Organic chemical industry flow chart VOL storage tankmarket for tanks in volume interval as characterized in the economic impact analysis

ii i Page 3-5 3-7 3-8 3-11
3-13 3-14 3-16 3-18 3-20 3-21 3-36

3-38
4-5
4-6 4-22 4-24 9-2
9-33Table 1-1

3-1
3-2
3-3
3-4 3-5
3-6 4-1 4-2
4-3

4-4
4-5
4-6
6-1 6-2 7-1 7-2
8-1
8-2 LIST OF TABLES

Assessment of Environmental, Energy, and Economic Impacts for Each Regulatory Alternative Considered for New VOL Storage Vessels

........... . National Industrial VOL Tank Distribution According to Vapor Pressure (1977)

. . . . . . . . . . . . . . . National Industrial VOL Tank DistributionAccording to Tank Size (1977).

. . . . . . . . . . . . . . . . Statistics for the National Tank Population inVOL Terminal Storage (1979)

........... . Seal Related Factors for External Floating Roof Tanks

. . . . . . . . . . . . . . . . . . ... Typical Number ofColumns as a Function ofTank Diameters

............... . Summary of Deck Fitting Loss Factors (Kf) and Typical Number of Fittings (Nf)

...... . Hierarchy of Equipment Types Based on Emissions Rate. Model Tank Emission Rates for Different Equipment Options

. . . . . . . . . . . . . . . . . . . Effectiveness of Internal and External Floating Roof Tanks Compared to a Fixed Roof Tank for the Model Tank.

. . . . . . . . . . . ....... . 11Controlled11 and 11Uncontrolled11 Internal Floating Roof Deck Fittings

................. . Internal Floating Roof Rim Seal Systems Seal Loss Factors and Control Efficiencies

....... . External Floating RoofTank Seal System Control Efficiencies

..... . Model Terminal

.... . Model Producer/Consumer Fifth-Year Emissions Resulting from the Regulatory Alternatives.

. . . . . . . . . . .... Fifth-Year Emissions Reductions Resulting from the Regulatory Alternatives

..... . Estimated Installed Capital Cost of a Fixed Roof Tank

. . . . . . . . . . . . . . ..... Estimated InstalledCapital Cost of a Noncontact Internal Floating Roof

..... . (continued) iv 1-3
3-2
3-2
3-4
3-28
3-32
3-33 4-3
4-8

4-11
4-12
4-14 4-19 6-6 6-6 7-3 7-4
8-3
8-4Table 8-3
8-4 8-5 8-6 8-7 8-8 8-9 8-10 8-11 8-12 8-13 8-14 8-15 8-16 8-17 8-18
8-19 8-20 8-21 8-22 8-23

8-24 LIST OF TABLES (Continued)

Estimated Installed Cost of aWelded Contact Floating Roofwith Secondary Seals

..... Estimated InstalledCapital Cost of External RoofTanks with Secondary Seals

.. Cost of Regulatory Alternative I . Cost of Regulatory Alternative II. Cost of Regulatory Alternative III Cost of Regulatory Alternative IV. Cost of Regulatory Alternative V . Internal Floating

Cost of External Floating RoofTanks with Primary Seal and Secondary Seal

. . . . . . ........... . Cost of External Floating Roof Tanks with Liquid-Mounted Primary Seal and Secondary Seal

........ . Cost ofVapor Control by IncinerationTechniques Cost ofVapor Recovery by Carbon Adsorption Techniques

......... . Lifetimes ofControl Equipment

. Cost Annualizing Assumptions

.. Federal Laws RegulatingToxic Chemicals. Statutes That May be Applicable to the Manufacture and Storage ofVolatileOrganic Liquids

..._ ..... Proposed Regulations ThatWill Affectthe Chemical Manufacturing Industry

............. . Capital and Annualized Costs for Baseline and Control Equipment for theModel VOL Tank

..... Absolute Cost Effectiveness ofControlling Fixed Roof Tank Emissions from the Model Tank

......... . Incremental Cost Effectiveness between Internal Floating Roof Seal Types in the Model Tank

....... . Incremental Cost Effectiveness ofControllingDeck Seam Emissions in theMode1Tank

. . . . . . . . . Regulatory Alternatives and Incremental Cost Effectiveness ($/Mg) between Regulatory Alternatives in theModel Tank

................ . Incremental Cost Effectiveness between Equipment Specifiedby Each Regulatory Alternative and an External Floating RoofTankwith aMechanical Shoe Seal and a Secondary Seal

.................... . (continued)


### v 8-5 8-6 8-9 8-10 8-11 8-12 8-13
8-14 8-15 8-16
8-17 8-19 8-19 8-22 8-23 8-26 8-28 8-29 8-30 8-31

8-32

8-33Table 9-1 9-2 9-3 9-4 9-5 LIST OF TABLES (Continued)

Resource Use by Producers of Industrial Organic Chemicals (SIC 286)

..... Resource Use by Producers of PlasticsMaterials and Synthetics (SIC 282)

......... . Capital Expenditures and Operating Rates for SIC 286 and SIC 282, 1958-1978

....... . Historical Production and Sales of Industrial Organic Chemicals, 1955-1981

..... . Historical Production and Sales of Plastics and Resins Materials, 1955-1981

..... . 9-6 Export and Import Values of Industrial Organic Chemicals (SIC 286) Excluding Gum and Wood Chemicals (SIC 2861) 9-6 9-7 9-8 9-10 9-11

for SelectedYears Between 1972 and 1981

. . . . . . 9-13 9-7

9-8 Export and Import Values of Plastics Materials and Synthetics (SIC 282) for SelectedYears Between 1972 and 1981

. . . . . . . . . . . . . . . . . . . Industry-wide Market Concentration Based on Capacity Share Data, 1976

........ . 9-9 Geographic Distribution of Establishments, Employees, and Value of Shipments of SIC 286, Industrial Organic 9-13
9-17

Chemicals

......................... 9-18 9-10

9-11 9-12
9-13 9-14 9-15 Geographic Distribution of Establishments, Employees, and Value of Shipments of SIC 282, PlasticsMaterials and Synthetics

. . . . . . . . . . . . .- . . . . . . Total 1982 Merchant Liquid Bulk Capacity, by State Historical Price Data for Industrial Organic Chemicals and Plastics, Resins, and Elastomers, 1955-1981

.... Projection ofVOL Storage Tank Construction--1984to 1988 All Capacities, Vapor Pressures, and Roof Designs Estimated Percentage Distribution ofVOL Storage Tanks by Vapor Pressure and Tank Capacity, 1977

...... . ProjectionofVOL Storage and Construction by Vapor Pressure and Tank Size, 1984-1988

... 9-16 Price Impacts of the Regulatory Alternatives for the 9-20 9-21 9-23 9-28 9-29 9-31 Model Terminal and Model Producer/Consumer 9-37 9-17 Percentage Change in Output Price for the Model Plants Due to the Regulatory Alternatives

. . . . . . . . . . 9-38 9-18 Investment Impacts of Regulatory Alternatives for the Model Independent Terminal and Model Producer/Consumer (103 $1982)

. . . . . . . . . . . . . . . . . . . . . . . . 9-40 (continued) viTable 9-19

9-20

9-21 9-22 LIST OF TABLES (Concluded)

The New Tank Population Impacted by Regulatory Alternative I as a Percentage of the Projected New Tank Population

............... . The NewTank Population Impacted by Regulatory Alternatives II-V as a Percentage ofthe Projected New Tank Population

............... . Additional Nationwide Investment in VOL Storage Required by the Regulatory Alternatives, 1984-1988 Fifth-Year Nationwide Annualized Cost of the Regulatory Alternatives

....... .

vii . .... 9-42

9-43 9-47 9-481. SUMMARY
Standards ofperformance for new stationary sources are established under Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended in 1977. Section 111 directs the Administrator to establish standards of performance for any category of new stationary source of airpollution which 11Causes or contributes significantlyto, airpollutionwhich may reasonably be anticipatedto endanger public health orwelfare. 11 This background information document supports the proposed standards, which would control emissions of volatile organic compounds (VOCs) from vessels that store volatile organic liquids (VOLs). VOL storage vessels are primarily located at chemical manufacturing facilities and bulk storage terminals. These vessels are used for storing a variety of materials, including raw materials, final products, and/or usable byproducts, as well as waste tars, residues, and nonusable byproducts. 1.1 REGULATORY ALTERNATIVES In orderto evaluate the environmental, economic, and energy impacts associatedwith implementation of a standard for VOL storage vessels, the Administrator has examined the impacts of several regulatory alternatives for VOL storage vessels. The VOL regulatory alternatives, in orderof increasingemission control potential, would require that each vessel storing a VOL be equipped with the control technology described
as follows:

• Regulatory Alternative 0

- no additional control overbaseline.

• Regulatory Alternative I - an internal floating roof with a vapor-mounted primary seal (IFRvm).

• Regulatory Alternative II

- an internal floating roofwith a liquid-mountedprimary seal (IFR1m).• Regulatory Alternative III

- an internal floating roofwith a liquid-mountedprimary seal and controlled deck fittings (IFR1 f). m,c • Regulatory Alternative IV

- an internal floating roof with a liquid-mounted primary seal controlled deck fittings, and a continuous secondary seal (IFR1 f ). m,c ,ss • Regulatory AlternativeV - awelded internal floating roof with a liquid-mounted primary seal, controlled deck fittings and a continuous secondary seal ( IFR1 f ). 

### w m,c ,ss 1.2 ENVIRONMENTAL IMPACT The environmental regulatory alternatives are summarized in Table 1-1. None of the alternatives has any adverse environmental impacts. The environmental impacts are discussed in detail in Chapter 7. 1.3 ECONOMIC IMPACTS The economic impacts are also summarized inTable 1-1. None of the alternatives have any potential adverse economic impacts. The economic impacts are discussed in detail in Chapter 9.

1-2....... I w Table 1-1. ASSESSMENT OF ENVIRONMENTAL, ENERGY, AND ECONOMIC IMPACTS FOR EACH REGULATORY ALTERNATIVE CONSIDERED FOR NEWVOL STORAGE VESSELS

Solid Administrative Air Water waste Energy Economic

alternative impact impact impact impact impact Regulatory Alternative0 -2** 0 0 0 0 Regulatory Alternative I +1** 0 0 0 -1** Regulatory Alternative II +2** 0 0 0 -1** Regulatory Alternative III +3** 0 0 0 -1** Regulatory Alternative IV +3** 0 0 0 -1** Regulatory AlternativeV +3** 0 0 0 -3**

aKEY: + Beneficial impact 2 Small impact * Short term impact Adverse impact 3 Moderate impact ** Long term impact 0 No impact 4 Large impact *** Irreversible impact 1 Negligible impact 5 Very large impact2. INTRODUCTION
2.1 BACKGROUND AND AUTHORITY FOR STANDARDS Before standards ofperformance areproposed as a Federal regulation, airpollution control methods available to the affected industry and the associated costs of installing and maintaining the control equipment are examined in detail. Various levels ofcontrol based on different technologies and degrees of efficiency are expressed as regulatory alternatives. Each of these alternatives is studiedby EPA as a prospectivebasis for a standard. The alternatives are investigated in terms oftheir impacts on the economics and well-being ofthe industry, the impacts on the national economy, and the impacts on the environment. This document summarizes the information obtainedthrough these studies
so that interestedpersons will be able to see the information considered by EPA in the development of the proposed standard. Standards ofperformance for new stationary sources are established under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended, hereinafter referredto as the Act. Section 111 directs the Administrator to establish standards ofperformance for any category of new stationary source of airpollutionwhich 11Causes, orcontributes significantlyto, airpollutionwhich may reasonably be anticipated to endanger the public health orwelfare." The Act requires that standards ofperformance for stationary sources reflect 11the degree of emission reduction achievablewhich (taking into consideration the costof achieving such emission reduction, and any nonair quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated for thatcategory of sources. 11 The standards apply only to stationary sources whose construction ormodification commences after regulations are proposed by publication in the Federal Register.The 1977 amendments to the Act altered or added numerous provisions that apply to theprocess of establishing standards ofperformance. 1. EPA is required to review the standards ofperformance every 4years and, ifappropriate, revise them. 2. EPA is authorized to promulgate a standard based on design, equipment, workpractice, oroperational procedures when a standard based on emission levels is not feasible. 3. The term 11standards of performance11 is redefined, and a new term 11technological system ofcontinuous emission reduction11 is defined. The new definitions clarifythatthe control system must be continuous and may include a low-pollutingor nonpollutingprocess or operation. 4. The time between the proposal and promulgation of a standard under Section 111 of the Act may be extended to 6months. Standards ofperformance, by themselves, do not guarantee protection of health orwelfare because they are not designed to achieve any specific airquality levels. Rather, they are designed to reflect the degree of emission limitation achievable through application ofthe best adequately demonstrated technological system of continuous emission reduction, taking into consideration the costof achieving such emission reduction, any nonair quality health and environmental impacts, and energy requirements. Congress had several reasons for including these requirements. First, standardswith a degree of uniformity are needed to avoid situations in which some States may attract industries by relaxing standards relative to other States. Second, stringent standards enhance the potential for long-term growth. Third, stringent standards may help achieve long-term cost savings by avoiding the need for more expensive retrofitting if pollution ceilings are reduced in the future. Fourth, certain types of standards for coal-burning sources can adversely affect the coal market by driving up the price of low-sulfur coal or effectively excluding certain coals from the reserve base because their untreatedpollution potentials are high. Congress does not intendthat new source performance standards contribute to these problems. Fifth, the standard-setting process should create incentives for improved technology.

2-2Promulgation of standards ofperformance does not prevent State or local agencies from adopting more stringent emission limitations for the same sources. States are free under Section 116 of the Act to establish even more stringent emission limits than those established under Section 111 orthose necessary to attain ormaintain the National Ambient Air Quality Standards (NAAQS) under Section 110. Thus, new sources may in some cases be subject to limitations more stringentthan standards ofperformance under Section 111, and prospective owners and operators of new sources should be aware ofthis possibility in planning for such facilities. Asimilar situationmay arisewhen amajor emitting facility is to be constructed in a geographic areathat falls under the provisions for prevention of significantdeterioration of airquality in PartCof the Act. These provisions require, among other things, thatmajor emitting facilities to be constructed in such areas be subjectto best available control technology. The term 11best available control technolog/' (BACT), as defined in the Act, means: an emission limitation based on the maximum degree of reduction of each pollutant subject to regulation under this Act emitted from, orwhich results from, any major emitting facility, which the permitting authority, on a case-by-case basis, taking into account energy, environmental, and economic impacts and othercosts, determines is achievable for such facility through application ofproduction processes and available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control ofeach such pollutant. In no event shall application of 11best available control technology11 result in emissions of any pollutants which will exceed the emissions allowed by any applicable standard establishedpursuantto Sections 111 or 112 of this Act. (Section 169(3)). Although standards ofperformance are normally structured in terms of numerical emission limits where feasible, alternative approaches are sometimes necessary. In some cases, physical measurement ofemissions from a new source may be impractical orexorbitantly expensive. Section 111(h) provides that the Administrator may promulgate a design
or equipment standard in those cases in which it is not feasible to prescribe orenforce a standard ofperformance. For example, emissions of hydrocarbons from storage vessels for petroleum liquids are greatest during tank filling. The nature of the emissions (high concentrations

2-3for shortperiods during filling and low concentrations for longer periods during storage) and the configuration of storage tanks make directemission measurement impractical. Therefore, a more practical approach to standards ofperformance for storage vessels has been equipment specification. In addition, Section 111(j) authorizes the Administratorto grant waivers of compliance to permit a source to use innovative continuous emission control technology. To grantthewaiver, the Administrator must find (1) a substantial likelihood that the technologywill produce greater emission reductions than the standards require, or an equivalent reduction at lower economic, energy, or environmental cost, (2) the proposed system has not been adequately demonstrated, (3) the technology will not cause orcontribute to an unreasonable riskto the public health, welfare, or safety, (4) the governor ofthe Statewhere the source is located consents, and (5) thewaiver will notprevent the attainment ormaintenance of any ambient standard. Awaiver may have conditions attached to ensure that the source will not prevent attainment of any NAAQS. Any such conditionwill have the force of aperformance standard. Finally, waivers have definite end dates and may be terminated earlier ifthe conditions are not met or ifthe system fails to perform
as expected. In such a case, the source may be given up to 3years to meet the standards with amandatory progress**sched~le.** 2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES Section 111 of the Act directs the Adminstrator to listcategories of stationary sources. The Administrator 11shall include a category of sources in such list if in hisjudgment itcauses, or contributes significantlyto, airpollutionwhich may reasonably be anticipatedto endanger public health orwelfare. 11 Proposal and promulgation of standards ofperformance are to follow. Since passage of the Clean Air Amendments of 1970, considerable attention has been given to the development of a system for assigning priorities to various source categories. The approach specifies areas of interestby considering the broad strategyof the Agency for implementing the Clean Air Act. Often, these 11areas11 are actually pollutants emitted



### 2-4by stationary sources. Source categories that emit these pollutants are evaluated and ranked by a process involving such factors as (1) the level of emission control (if any) already required by State regulations, (2) estimated levels of control thatmight be required from standards of performance for the source category, (3) projections of growth and replacement of existing facilities for the source category, and (4) the estimated incremental amount of airpollution that could be prevented in
apreselected future yearby standards ofperformance for the source category. Sources forwhich new source performance standards were promulgated orwere under development during 1977, or earlier, were selected on these criteria. The Act amendments of August 1977 establish specific criteriato be used in determining priorities for all major source categories notyet listed by EPA. These are (1) the quantity of airpollutant emissions that each such categorywill emit orwill be designed to emit, (2) the extentto which each such pollutantmay reasonably be anticipated to endanger public health orwelfare, and (3) the mobility and competitive nature of each such category of sources and the consequent need for nationally applicable new source standards ofperformance. The Administrator is to promulgate standards for these categories according to the schedule referred to earlier. In some cases, itmay not be feasible to immediately develop a standard for a source categorywith a high priority. This situation might occurwhen a program of research is needed to develop control techniques, orbecause techniques for sampling and measuring emissions may require refinement. In developing standards, differences in the time required to complete the necessary investigation for different
source categories must also be considered. For example, substantially
more time may be necessary if numerous pollutants must be investigated from a single source category. Furthermore, even late in the development process, the schedule for completion of a standardmay change. For example, inabilityto obtain emission data from well-controlled sources in time to pursue the development process systematicallymay force a change in scheduling. Nevertheless, priority ranking is, and will continue to be, used to establish the order in which projects are initiated and resources assigned. 2-5Afterthe source category has been chosen, the types of facilities within the source categoryto which the standardwill apply must be determined. Asource category may have several facilities that cause airpollution; emissions from these facilities may vary from insignificant to very expensive to control. Economic studies of the source category and of applicable control technology may show that airpollution control is better served by applying standards to the more severe pollution sources. For this reason, and because there is no adequately demonstrated system for controlling emissions from certain facilities, standards often do not apply to all facilities at a source. For the same reasons, the standards may not apply to all air pollutants emitted. Thus, although a source categorymay be selected to be covered by a standard of performance, all pollutants or facilities within that source category might not be covered by the standards. 2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE Standards ofperformance must (1) realistically reflectbest demonstrated control practice, (2) adequately considerthe cost, the nonair-quality health and environmental impacts, and the energy requirements of such control, (3) be applicable to existing sources that are modified
or reconstructed as well as to new installations, and (4)**m~et** these conditions for all variations of operating conditions being considered anywhere in the country. The objective of a program for developing standards is to identify the besttechnological system of continuous emission reduction that has been adequately demonstrated. The standard-settingprocess involves three principal phases of activity: (1) information gathering, (2) analysis ofthe information, and (3) development of the standardof performance. During the information-gatheringphase, industries are queried through a telephone survey, letters of inquiry, and plant visits by EPA representatives. Information is also gathered from many other sources, and a literature search is conducted. From the knowledge acquired about the industry, EPA selects certain plants atwhich emission tests are conducted to provide reliable data that characterizethe pollutant emissions from well-controlledexisting facilities.

2-6In the second phase of a project, the information about the industry and the pollutants emitted is used in analytical studies. Hypothetical

11model plants11 are defined to provide a common basis for analysis. The model plantdefinitions, national pollutant emission data, and existing State regulations governing emissions from the source category are then used in establishing "regulatory alternatives." These regulatory alternatives are essentiallydifferent levels ofemission control. EPA conducts studies to determine the impact ofeach regulatory alternative on the economics ofthe industry and on the national economy, on the environment, and on energy consumption. From several possibly applicable alternatives, EPA selects the singlemost plausible regulatory alternative as the basis for a standard ofperformance for the source category under study. In the thirdphase of aproject, the selected regulatory alternative is translated into a standardofperformance, which, in turn, iswritten in the form of a Federal regulation. The Federal regulation, when applied to newly constructedplants, will limit emissions to the levels indicated in the selected regulatory alternative. As early as is practical in each standard-settingproject, EPA representatives discuss the possibilities of a standard, and the form it might takewith members ofthe National Air Pollution Control Techniques Advisory Committee. Industry representatives and 9ther interested parties also participate in these meetings. The information acquired in the project is summarized in the background information document (BID). The BID, the standard, and apreamble explaining the standard arewidely circulated to the industry being considered for control, environmental groups, other government agencies, and offices within EPA. Through this extensive reviewprocess, the viewpoints ofexpert reviewers are considered as changes are made to the documentation. A"proposal package" is assembled and sentthrough the offices of EPA AssistantAdministrators for concurrence before the proposed standard is officially endorsed by the EPA Administrator. Afterbeing approved by the EPA Administrator, the preamble and the proposed regulation are published in the Federal Register.

2-7As a part of the Federal Register announcement ofthe proposed regulation, the public is invited to participate in the standard-setting process. EPA invites written comments on the proposal and also holds a public hearing to discuss the proposed standardwith interestedparties. All public comments are summarized and incorporated into a second volume ofthe BID. All information reviewed and generated in studies in support of the standard ofperformance is available to the public in a 11docket11 on file inWashington, D.C. Comments from the public are evaluated, and the standards of performance may be altered in response to the comments. The significant comments and EPA 1s position on the issues raised are included in the 11preamble11 of a promulgation package, which also contains the draft of the final regulation. The regulation is then subjected to another round of review and refinement until it is approved by the EPA Administrator. After the Administrator signs the regulation, itis published as a 11final rule11 in the Federal Register. 2.4 CONSIDERATION OF COSTS Section 317 of the Act requires an economic impact assessmentwith respect to any standard ofperformance established under Section 111 of the Act. The assessment is required to contain an analysis of (1) the costs of compliance with the regulation, including the extent towhich the cost of compliance varies depending on the effective date of the regulation and the development of less expensive ormore efficient methods ofcompliance, (2) the potential inflationary or recessionary effects of the regulation, (3) the effects the regulation might have on small business with respect to competition, (4) the effects of the regulation on consumer costs, and (5) the effects ofthe regulation on energy use. Section 317 also requires that the economic impact assessment be as extensive as practicable. The economic impact of aproposed standard upon an industry is usually addressed both in absolute terms and in terms of the control costs thatwould be incurred as a result of compliancewith typical, existing State control regulations. An incremental approach is necessary because both new and existingplants would be required to comply with

2-8State regulations in the absence of a Federal standard ofperformance. This approach requires a detailed analysis of the economic impact from the cost differential thatwould existbetween aproposed standard of performance and the typical State standard. Air pollutantemissions may cause water pollution problems, and capturedpotential airpollutants may pose a solidwaste disposal problem. The total environmental impact of an emission source must, therefore, be analyzed and the costs determined whenever possible. Athorough study of the profitability and price-settingmechanisms ofthe industry is essential to the analysis so that an accurate estimate ofpotentially adverse economic impacts can be made for proposed standards. Itis also essential to know the capital requirements for pollution control systems already placed on plants so thatthe additional capital requirements necessitated by these Federal standards can be placed in properperspective. Finally, it is necessary to assess the availability of capital to provide the additional control equipment needed to meet the standards ofperformance. 2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS Section 102(2)(C) of the National Environmental PolicyAct (NEPA) of 1969 requires Federal agencies to prepare detailed environmental impact statements on proposals for legislation and othermajor Federal actions significantly affecting the quality of the human environment. The objective ofNEPA is to build into the decisionmaking process of Federal agencies a careful consideration of all environmental aspects of proposed actions. In a number of legal challenges to standards ofperformance for various industries, the United States Court ofAppeals for the District of Columbia Circuit has held that environmental impact statements need not be prepared by the Agency for proposed actions under Section 111 of the Clean Air Act. Essentially, the Court ofAppeals has determined that the best system of emission reduction requires the Administrator to take into account counter-productive environmental effects of aproposed standard, as well as economic costs to the industry. On this basis, therefore, the Court established a narrow exemption from NEPA for EPA determination under Section 111.
2-9In addition to thesejudicial determinations, the Energy Supply and Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically exempted proposed actions under the Clean Air Act from NEPA requirements. According to Section7(c)(1), 11no action taken under the Clean Air Act shall be deemed amajor Federal action significantly affecting the quality of the human environment within the meaning of the National Environmental PolicyAct of 1969. 11 (15 U.S.C. 793(c)(l)) Nevertheless, the Agency has concluded that the preparation of environmental impact statements could have beneficial effects on certain regulatory actions. Consequently, although not legally required to do
so by Section 102(2)(C) ofNEPA, EPA has adopted a policy requiring that environmental impact statements be prepared for various regulatory actions, including standards ofperformance developed under Section 111 of theAct. This voluntarypreparation ofenvironmental impact statements, however, in no way legally subjects the Agency to NEPA requirements. To implement this policy, a separate section in this document is devoted solelyto an analysis of the potential environmental impacts associatedwith the proposed standards. Both adverse and beneficial impacts in such areas as air and water pollution, increased solidwaste disposal, and increased energy consumption are discussed. 2.6 IMPACT ON EXISTING SOURCES Section 111 of the Act defines a new source as 11any stationary source, the construction ormodification ofwhich is commenced11 after the proposed standards are published in the Federal Register. An existing source is redefined as a new source if 11modified11 or 11reconstructed11 as defined in amendments to the general provisions of Subpart Aof 40 CFR Part 60, which were promulgated in the Federal Register on December 16, 1975 (40 FR 58416). Any physical or operational change to an existing facilitywhich results in an increase in the emission rate of any pollutant for which a standard applies is considered amodification. Reconstruction, on the other hand, means the replacement of components of an existing facility to the extent that the fixed capital costexceeds 50 percent of the cost ofconstructing a comparable entirely new source and that itbe technically

2-10and economically feasible to meet the applicable standards. In such cases, reconstruction is equivalent to a new construction. Promulgation of a standard ofperformance requires States to establish standards ofperformance for existing sources in the same industry under Section 111(d) of the Act ifthe standard for new sources limits emissions of a designatedpollutant (i.e., a pollutant forwhich airquality criteria have not been issued under Section 108 orwhich has not been listed as a hazardous pollutant under Section 112). Ifa State does not act, EPA must establish such standards. General provisions outlining procedures for control of existing sources under Section 111(d) were promulgated on November 17, 1975, as Subpart Bof40 CFR Part 60 (40 FR 53340). 2.7 REVISION OF STANDARDS OF PERFORMANCE Congress was aware that the level of airpollution control achievable by any industrymay improve with technological advances. Accordingly, Section 111 ofthe Act provides that the Administrator 11shall, at least every 4years, review and, if appropriate, revise11 the standards. Revisions are made to ensure that the standards continue to reflect the best systems thatbecome available in the future. Such revisions will not be retroactive butwill apply to stationary sources constructedor modified afterthe proposal of the revised standards.

2-113. VOLATILE ORGANIC LIQUID STORAGE
3.1 THE VOLATILE ORGANIC LIQUID STORAGE INDUSTRY Volatile organic liquid (VOL) storage vessels areprimarily located atchemical manufacturing and producing facilities and atbulk liquid transferterminals. An economic description ofthese industries is contained in Section 9.1. The storage ofVOL within these industries is described below. 3.1.1 Industrial Service (Chemical Manufacturing) Tanks are used for storing a varietyoforganic liquids, including raw materials, final products, and/or usable byproducts, as well as waste tars, residues, and otherwastes. Available datawere analyzed to determine the number of tanks in the nation containingvolatile organic liquids.1•2•3The 1977 industrial tankpopulationwas found to be 27,540.4 The vapor pressure of the material to be stored is amajor factor in choosing the tank type to be used. In practice, fixed roof tanks are predominantly used for storingmaterials with vapor pressures up to 34.5 kPa; floating-roof tanks are also used to storematerials in the
same range. Table 3-1 gives the distribution of tanks nationally, according to the vapor pressure oftheVOLs stored in fixed and floating roof tanks. Other factors such as material stability, safety hazards, and multiple use also affectthe choice oftank type for aparticular organic liquid. Table 3-2 gives the national tank distribution by storage capacity for fixed roof and floating roof tanks. 3.1.2 Terminal Service Aterminal is a nonmanufacturing sitethat stores commodities in bulk quantity. Only those terminals that storeVOL were of concern to this study. Telephone directories of selectedcitieswere searched for terminal listings. As a result of this survey, itwas determined that data obtained from the Independent Liquid Terminal Association (ILTA)

### Table 3-1. 

### NATIONAL INDUSTRIAL VOL TANK DISTRIBUTION ACCORDING TO VAPOR PRESSURE (1977)



### Number oftanks nationwide Vapor pressure, (kPa) Fixed-roof Floating-roof
0 

## - 3.5 16,350 170 3.5

- 6.9 3,560 100 6.9- 10.3 1,950 70 10.3

- 34.5 3,800 790 34.5- 58.6 500 40**~58.6** 190 20 

### Total 26,350 1,190 

### Percent ofTotal 95.7 4.3 

### Total
16,520

3,660 2,020 4,590 540 210 27,540

100.



### Table 3-2. 

### NATIONAL INDUSTRIAL VOL TANK DISTRIBUTION ACCORDING TO TANK SIZE (1977)



### Number oftanks nationwide Tank size, (m3) Fixed-roof Floating-roof Total
0

- 75 12,270 20 12,290 75

- 150 3,910 30 3,940 150

- 375 3,770 180 3,950 375

- 3,750 5,840 610 6,450 3,750

- 15,000 520 320 840**~15,000** 40 30 70



## -- Total 26,350 1,190 27,540 

### Percent ofTotal 95.7 4.3 100.

3-2would serve as a sufficientapproximation of the national terminal population.5 Sixty-eight ILTA member companies operatemore than 150 terminals. Of these, 82 terminals handle VOLs. Itwas assumed that any terminal storingVOL devoted its entire storage volume toVOL. Statistics for the tanks in the 82 VOL terminals are given in Table 3-3. 3.2 STORAGE TANKS 3.2.1 Types of StorageTanks There are three types of vessels ofconcern in developing standards ofperformance for VOL storage vessels:
1 fixed roof tanks;
1 external floating roof tanks; and
1 internal floating roof tanks. These tanks are cylindrical in shape with the axis orientedperpendicular to the foundation. The tanks are almost exclusively above ground. Below-ground vessels and horizontal vessels (i.e. with the axis parallel tothe foundation) also can be used inVOL service. However, these types ofvessels are much less common in VOL service than the other tank types listed above. For the most part, are less than 100 cubic meters (26,400 gallons) in capacity. Consequently, theircontribution to nationwide VOL storage emissions is minor. Controls applicable to horizontal tanks primarily are limited to closed vent systems and control devices as discussed in Chapter 4. Since their contribution to nationwide emissions is minor, no detailedequipment description is provided for these types of roofs. For a similar reason, no detailedequipment description is provided for pressure vessels. This section, therefore, addresses only fixed roof, external floating and internal floating roof tanks. 3.2.1.1 Fixed RoofTanks. Of currently used tank designs, the fixed-roof tank is the least expensive to construct and is generally considered as the minimum acceptable equipment for the storage ofVOLs. Atypical fixed-roof tank, which is shown in Figure 3-1, consists of a cylindrical steel shell with a cone- or dome-shaped roof that is permanently affixedto the tank shell. Abreathervalve (pressure-vacuum valve), which is commonly installed on many fixed roof tanks, allows the tank to

3-3Table 3-3. STATISTICS FOR THE NATIONAL TANK POPULATION IN VOL TERMINAL STORAGE (1979)

CAPACITY Total capacity in data base: 1.390x 1010 liters (3,670 x 106 gal) Average capacityfor a terminal: 1.78x 108 liters (47 x 106 gal) Median capacity for a terminal: 9.35 x 107 liters (25 x 106 gal) NUMBER OF TANKS Total number oftanks atterminals in database: 4,212 Average number of tanks per terminal: 54 Median number of tanks perterminal: 37.5 SMALLEST TANKa Average size of smallesttank: 1.2x 106 liters (318.9 x 103 gal) Median size of smallesttank: 1.59x 105 liters (42 x 103 gal) AVERAGE TANK SIZE: 3.3x 106**lite~s** (872 x 103 gal) LARGEST TANKb Average size of largest tank: Median size of largesttank: 1.36x 107 liters-(3,599 x 103 gal) 9.22 x 106 liters (2,436 x 103 gal)

aVolume of the smallesttank ateach terminal. bVolume ofthe largest tank at each terminal.

3-4

### GAUGE HATCH



### MANHOLE

Figure 3-1. Typical fixed roof tank.

3-5 

### NOZZLE (FOR SUBMERGED FILL OR DRAINAGE)operate at a slight internal pressure or vacuum. Because this valve prevents the release of vapors only during very small changes in temperature, barometric pressure, or liquid level, the emissions from a fixed roof tank can be appreciable. 3.2.1.2 External Floating Roof Tanks. Atypical external floating roof tank is shown in Figure 3-2. This type of tank consists of a cylindrical steel shell equipped with a deck or roof that floats on the surface of the stored liquid, rising and fallingwith the liquid level. The liquid surface is completely covered by the floating roof except in the small annular space between the roof and the shell. Aseal attached to the roof touches the tankwall (except for small gaps in some cases) and covers the remaining area. The seal slides against the tankwall as the roof is raisedor lowered. 3.2.1.3 Internal Floating Roof Tanks. An internal floating roof tank has both a permanently affixed roof and a roof that floats inside the tankon the liquid surface (contact roof), or supported on pontoons several inches above the liquid surface (noncontact roof). The internal floating roof rises and falls with the liquid level. Typical contact and noncontact internal floating roof tanks are shown in Figures 3-3a and 3-3b, respectively. Contact-type roofs include (1) aluminum sandwich panel roofs with a honeycombed aluminum core floating in contactwith**~the** liquid; (2) resin coated, glass fiber reinforcedpolyester (RFP) buoyant panels, floating in contactwith the liquid; and (3) pan-type steel.roofs, floating in contactwith the liquidwith orwithout the aid ofpontoons. The majority ofcontact internal floating roofs currently inVOL service are steel-pan type or aluminum sandwich panel type. The RFP roofs are less common. Several variations ofthe pan-type contact steel roof exist. The design may include bulkheads, or open compartments, around the perimeter ofthe roof to minimize and/or localize the effects of liquid thatmay leakor spill onto the deck. Alternately, the bulkheads may be covered to form sealed compartments (i.e., pontoons), orthe entirepan may be covered to form a sealed double deck steel floating roof. Construction is generallywelded steel.

3-6• 

### , ·I:t**!~"••** 

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# ..

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### ...... 

# .**--··-~-~** ,_

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,' 

## , 

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...

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Figure 3-2. External floating roof tank (pontoon type). 3-7M&nt\o1e

Peripheral RoofVent

Pri1111rySeal

Manhole 

### a. Contact internal floating roof.

Pontoons

TankSupportColumnwith Column Well



### b. Noncontact internal floating roof.
Figure 3-3. Internal floating roof tanks. 3-8Noncontact-type roofs typicallyconsist of an aluminum deck on an aluminum grid framework supported above the liquid surfaceby tubular aluminum pontoons. The deck skin for the noncontact-type floating roofs typically is constructed of rolled aluminum sheets (about 1.5mwide and 0.58 mm thick). The overlapping aluminum sheets arejoinedby bolted aluminum clamping bars that run perpendicular to the pontoons to improve the rigidity of the frame. The deck skin seams can be metal on metal or gasketed with apolymeric material. The pontoons and clamping bars form the structural frame of the floating roof. The presence of deck seams in the noncontact internal floating roof design contributes to emissions from the internal floating roof tank. Aluminum sandwich panel contact-type internal floating roofs share this design feature. The sandwich panels
arejoinedwith boltedmechanical fasteners that are similar in concept to the noncontact deck skin clamping bars. Steel-pan contact internal floating roofs are constructed ofwelded steel sheets and have no deck seams. Similarly, the resin-coated, reinforced fiberglass panel roofs have no apparent deck seams. The panels are butted and lapped with resin-impregnated fiberglass fabric strips. The significance ofdeck
seams to emissions from internal floating rooftanks is addressed in Chapter 4. It should be recognized thatthe roofphysicallyoccupies a finite volume of space thattakes away from the maximum liquid storage capacity of the tank. When completely full, the floating roof touches or nearly touches the fixed roof. Consequently, the**effectiv~** height ofthe tank decreases, thus limitingthe storage capacity. The reduction inthe effective height varies from about 1to 2feet depending on the type and design of the floating roof employed. All types of internal floating roofs, like external floating roofs, commonly incorporate flexible perimeter seals orwipers that slide against the tankwall as the roof moves up and down. These seals are discussed in detail in Section 3.2.2.2. Circulation vents and an open vent atthe top ofthe fixed roof are generallyprovided to minimize the possibility of hydrocarbon vapors accumulating in concentrations approaching the flammable range.

3-93.2.2 Types of Floating Roof Perimeter Seals 3.2.2.1 External Floating Roof Seals. Regardless of tankdesign, a floating roof requires a closure device to seal the gap between the tankwall and the roofperimeter. Aprimary seal, the lower seal of a two-seal system, can be made from various materials suitable for organic liquids service. The basic designs available for primary seals are (1) mechanical shoe seals, (2) liquid-filled seals, and (3) (vapor- or liquid-mounted) resilient foam log seals. Figure 3-4 depicts these three general types of seals. One major difference in seal system design is theway inwhich the seal is mounted with respect to the liquid. Figure 3-4c shows a vapor space between the liquid surface and seal, whereas, in Figures 3-4a and 3-4d, the seals are resting on the liquid surface. These liquid-filled tube and resilient foam seals are classified as liquid- or vapor-mounted seals depending on their location. Mechanical shoe seals are different in design from liquid-filled or resilient foam log seals and cannot be characterized as liquid- orvapor-mounted. However, because the shoe and envelope combination precludes communication between the annular vapor space above the liquid and the atmosphere (see Figure 3-4b), the performance of amechanical shoe seal is more like that of a liquid-mounted seal than a vapor-mounted seal. 3.2.2.1.1 Mechanical shoe seal. Amechanical shoe seal, otherwise known as a 11metallic shoe seal 11 (Figure 3-4b), is characterizedby a metallic sheet (the 11shoe11 ) 75 to 130 em (30 to 51 in) high held against the vertical tankwall. The shoe is connected by braces to the floating roof and is held tightly againstthewall by springs orweighted levers. Aflexible, coated fabric (the 11enve1ope11 ) is suspended from the shoe seal to the floating roof to form a vapor barrierover the annular space between the roof and the primary seal. 3.2.2.1.2 Liquid-filled seal. Aliquid-filled seal (Figure 3-4a) may be a tough fabric band or envelope filledwith a liquid, or itmay be a flexible polymeric tube 20 em to 25 em (8 inch to 10 inch) in diameter filledwith a liquid and sheathedwith a tough fabric scuff band. The liquid is commonly apetroleum distillate or other liquid thatwill not contaminate the storedproduct ifthe tube ruptures.

3-10

### ran /MetallicWeather Wall r 

### Shield Scuff

Liquid Filled Tube

a. Liquid-filled seal with weather shield.

### MetallicWeather 

# ;f/ Shield

### Ta~~ 1 

### Wall Floating Roof Seal Fabric ResilientFoam Vapor Space 

# U
... l**~** c. Vapor-mounted resilient foamfilled seal withweather shield. 

### TankWall

loatingRoof VaporSpace

b. t1eta111c shoe 

### seal.


### MetallicWeather { Shield

FloatingRoof Seal Fabric ResilientFoam

I 

### I ·-=I 

### d. Liauid-mounted resilientfoamfilled seal with weather shield.

Figure 3-4. Primary sea1s.

3-11Liquid-filled seals are mounted on the product liquid surfacewith no vapor space below the seal. 3.2.2.1.3 Resilient foam-filled seal. Aresilient foam-filled seal is similar to a liquid-filled seal except that a resilient foam log is used in place of the liquid. The resiliency of the foam log permits the seal to adapt itselfto some imperfections in tankdimensions and in the tank shell. The foam log may be mounted above the liquid surface (vapor-mounted) oron the liquid surface (liquid-mounted). Typical vapor-mounted and liquid-mounted seals arepresented in Figures 3-4c and 3-4d, respectively. 3.2.2.1.4 Secondary seals on external floating roofs. Asecondary seal on an external floating roof is a continuous seal mounted on the rim of the floating roof and extending to the tankwall, covering the entireprimary seal. Secondary seals are normally constructed of flexible polymeric materials and mounted such thatthey provide a wiping action againstthetankwall as the roof raises and lowers. Figure 3-5 depicts several primary and secondary seal systems. An alternative secondary seal design incorporates a steel leaf to bridge the gap between the roof and the tankwall. The leaf acts as a compression plate to hold a polymeric wiper against the tankwall. Installedover a primary seal, a secondary seal provides a barrier for

### VOC emissions that escape from the small vapor space between the primary seal and the wall and through any openings or tears in the seal envelope of ametallic shoe seal (Figure 3-5). Although not shown in Figure 3-5, a secondary seal can be used in conjunction with aweather shield as described in the following section. Another type of secondary seal is a shoe-mounted secondary seal. A shoe-mounted seal extends from the top of the shoe to the tankwall (Figure 3-6). These seals do not provide protection against

### VOC leakage through the envelope. Holes, gaps, tears, or other defects in the envelope can permit directcommunication between the saturatedvapor under the envelope and the atmosphere. Wind can enter this space through envelope defects, flow around the circumference ofthe tank, and exit with saturatedor nearly saturated

### VOC vapors.

3-12IIIHiov•no IICOIDUYSIAL

VAPORIIACI



### a. Shoeseal with rim-mounted seconda

### rv sea1.

TANK WWALL IIM-MOUNTEC ( ltCONOUYSlAL 

# -·

fLOATUIGIOOF

RUILlfNTFOAMLOG

VAPGai,ACl



### c. Resilientfoam seal (vapor- nDunted) with rim-mounted secondary seal. ( a.HIOUITID<OIDUYSlAL

ILOATINCiROOF

UQUID-IJLUDTUI£



### b. Liquid-filledseal with rimmounted secondary seal.

d. Resilientfoam seal (liquid- mounted} with rim-rounted secondary seal. Figure 3-5 (a-d). Rim-mounted secondary seals on external floating roofs.3

3-13Figure 3-6. TANK WALL SECONDARYSEAL / (WIPERTYP£1

fLOATINiiROOF VAPORSPACf

3 Metallic shoe seal with shoe-mounted secondary seal.

3-143.2.2.1.5 Weather shield. Aweather shield (Figures 3-4a, 3-4c, and 3-4d) may be installed over the primary seal or theprimary and secondary seals, to protect it, or them, from deterioration caused by debris and exposure to the elements. Typically, aweather shield is an arrangement of overlapping thin metal sheets pivoted from the floating roof to ride against the tankwall. The weather shield, by the nature of its design, is not an effective vapor barrier. For this reason, it differs from the secondary seal. Although the two devices are conceptually similar in design, they are designed for and serve differentpurposes. 3.2.2.2 Internal Floating-RoofTank Seals. Internal floating roofs typically incorporate one of two types of flexible, product-resistant primary seals: resilient foam-filled seals orwiper seals. Similarto those employed on external floating roofs, each ofthese seals closes the annularvapor space between the edge of the floating roof and the tank shell. They are designed to compensate for small irregularities in the tank shell, and allow the roof to move freely up and down in the tankwithoutbinding. 3.2.2.2.1 Resilient foam-filled seal. Aresilient foam-filled seal used on an internal floating roof is similar in design to that described in Section 3.2.2.1.3 for external floating roofs. Two types of resilient foam-filled seals for internal floating roofs are shown in Figures 3-7a and 3-7b. These seals can eitherbe mounted in contact with the liquid surface (liquid-mounted) or several centimeters above the liquid surface (vapor-mounted). Resilient filled sealswork on the principle of expansion and contraction of a resilientmaterial to maintain contactwith the tank shell while accommodating varying annular rim space widths. These seals consistof a core of open-cell foam encapsulated in a coated fabric. The elasticityofthe foam core pushes the fabric into contactwith the tank shell. The seals are attached to a mounting on the deck perimeter and are continuous around the circumference. Urethane coated nylon fabric and polyurethane foam are commonly employed materials. For emission control, it is important that the mounting and radial seal joints be vapor-tight and that the seal be in substantial contactwith the tank shell.6

3-15

### a. Resilientfoam-filled seal (vapor-mounted). Contact internal floatingroof

aluminumsandwich roof)



### --v, Resilientfoam-filled seal

b. 

### Resilientfoam-filled seal (liquid-mounted). /.Resi1

### ientfoam-fi11

### ed sea1**~** L 

### Tankwall / Contactinternal floatingroof**(pan~type** 

### steel roof)



### c. Elastomericwiperseal.

on oon**~** 

### \Metal seal ring Tankwall Note: 

### v- vapor L - liquid Non-contact internal floating roof 

# '

Pontoon!

Figure 3-7. Typical flotation devices and perimeter seals for internal floating roofs. 3-163.2.2.2.2 Primary wiper seals. Wiper seals are commonly used as primary seals for internal floating roof tanks. This type of seal is depicted in Figure 3-7c. Wiper seals generallyconsistof acontinuous annular blade of flexible material fastened to amounting on the deck perimeter, spanning the annular rim space, and contacting the tank shell. The mounting is such that the blade is flexed, and its elasticityprovides a sealing pressure against the tank shell. Avapor space exists between the liquid stockand the bottom ofthe seal; such seals are vapor-mounted. For emission control, it is important thatthe mounting be vapor-tight, thatthe seal be continuous around the circumference, and that the blade be in substantial contactwith the tank shell.6 Two types ofwipers are commonly used. One type consists of a cellular, elastomeric material tapered in cross sectionwith the thicker portion atthe mounting. Buna-N rubber is a commonly-used material. All radial joints in the blade arejoined.6 Asecond type ofwiper seal construction uses a foam corewrapped with a coated fabric. Urethane on nylon fabric and polyurethane foam are common materials. The core provides the flexibility and support while the fabric provides the vapor barrier and wear surface.6 Athird type ofwiper seal consists ofoverlapping segments of seal material (shingle-type seal). Single-type seals differ from thewiper seals discussedpreviously in that they do not provide a continuous vapor barrier. 3.2.2.2.3 Secondary seals for internal floating roof tanks. Secondary seals may be used toprovide some additional evaporative loss control over that achieved by the primary seal. The secondary seal would be mounted to an extended vertical rim plate, above the primary seal, as shown in Figure 3-8. Secondary seals can be eitheran elastomeric wiper seal or a resilient foam-filled seal as described in Sections 3.2.2.2.2 and 3.2.2.2.1, respectively. For a given roof design, the use of a secondary seal further limits the operating capacity of a tank due to the need to avoid interference of the seal with the fixed roof rafters when the tank is filled. Currently, secondary seals are not commonly used on internal floating roof tanks6

.
3-17SECONDARY SEAL

·CONTACT TYPE INTERtlAl. FLOATINGROOF**~-------o~----**

Figure 3-8. Rim mounting of a secondary seal on internal floating roof.8

3-183.2.3 Types of Internal Floating Roof Deck Fittings The majority of Section 3.2.3 largely is from a draftAmerican Petroleum Institutepublication6that is expected to be published in June, 1983. There are numerous fittings thatpenetrate or are attached to an internal floating roof. These fittings serve to accommodate structural supportmembers orto allow for operational functions.6 Across section of an internal floating roof tank showing typical fittings is depicted in Figure 3-9.7 The fittings can be a source of evaporative loss, in that, they require penetrations in the deck. Other accessories are used that do not penetrate the deck and are not, therefore, sources of evaporative loss. The most common fittings with relevance to controllable vapor losses are described in the following sections.6 3.2.3.1 Access Hatches. An access hatch consists of an opening in the deckwith aperipheral vertical well attachedto the deck and a removable cover to close the opening. An access hatch is sized to provide for passage ofworkers and materials through the deck for construction or servicing. The cover can rest directly on thewell, or a gasketed connection can be used to reduce evaporative loss. Bolting the cover to thewell provides further loss reduction. With noncontact decks, thewell should extend down into the liquid stockto seal off the vapor space below the deck.6 Figure 3-lOa depicts_an access hatch that is suitable for use on a steel contact internal floating roof. 3.2.3.2 Column Wells

..The most common fixed roof designs are normally supported from inside the tankby means of vertical columns, which necessarily penetrate the floating deck. (Some fixed roofs are entirely self-supporting and, therefore, have no support columns.) Columns are made of pipewith circularcross sections or of structural shapes with irregular cross sections. The number of columns varies with tank diameter, from aminimum of one to over 50 for very large tanks.6 Figure 3-10b depicts a column well for a built-up column. The columns pass through deck openings with peripheral vertical wells. With noncontact decks, thewell should extend down into the liquid stock. Generally, a closure device exists between the top of the well and the column. Several proprietarydesigns existfor this closure,

3-19w I N 0

### ~ 124>**\~** 11

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1'> 5

2 

# I

Rfl ALl.t.lP(»jT.IfC TYPICAL INTERNAL FLOATING COVER TANK CROSS SECTION**·~**CIICUMflRENTIAL TAN< St£LL TOINllRNALFl.Oo\TER**~CENTER** ROOF VENT WITH REMOVABLE LID TO TAN< BOTTOM TAN< St£l..l**TAN<~** TAN<**~SUPPORT** CO..lMNISl T- FU. NOZZlf {1)OPTIONALT .t.NI< Fa.L LNOlffVSEII 

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### Figure 3-9. AIM SEAL N#J FOAM DAMIPATENT PENOINGJ SERVE AS A VENTILATOfl NOZZLE @TANKROOF SUPPORTCOlUMN ISOLATION WEUISl**~)**SHEllVENTAND OVERFLOW COMBINATION

AH..l SfALISl I""'TENT PENDING>**,~**ELECTRICAL GAOUNDING CAilLES**1~**VERTICAL LA[)[)(,R ISOLATION WEllAND SEAL 1-rf;IFC ROTATION PAEVENTION ASSEMBLY !PATENT PENDINGI ii) IICCESS MANWA.Y THACIUGH IFC.INOT SHOWNJ**(~**FWTATION PONTOONS ?9)STORED PfiOOUCT 21Ji IWOPOSITION SUPPORT LEGS FOR LFC WHfN**·~OTHER** OPTIONS NOT SHOWN FOR CLARITY.

lANOfO ON IANI< 110IIOM PLEASE CONSULT OLfl STAff OF V0 C EMISSION 711PRESSURE AND VIICWM REllff OfVICEISI fOil CONTROt. PAOfESSIONALS IN YOUR REGION

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INSPI:CliON ACCESS AND DlSIGI<oEO TO .ICCOM MOOAIE A PORTABLE fOAM TOWER


### Typical internal floating roof tank cross section.7 IIil 'I ·:

# ~w I N

...... lOPGIRDER

SECTION

## ®:.® lq lp 

## '•' '•l 

# '" Ill 

### a. Access hatch9

DICK.. IT



# -

b. Column well forbuilt-upcolumn 7 G)-TOOH ctIUI'POIIT1.10Air«**CIDECK~** @I-lEAL

• TANK IIOfTOM SPIIOOUCT

## :.:::.-::.~-::.**~=**

c. Roof leg assembly7

Figure 3-10. Internal floating roofdeck fittings.w I N N BOLTIMe FLAMOII TOP AND BOTTOM CURVATURE OF FLARED FITTIMeS PRECLUDES THE POIIIIILITY OF lAMPL! BOTTLES BNAIOIMQ OR CAfCMIMO OM THE SAMPLE WlLLo

tO•**(!~** MM) DIAo PIPI DIAPMRAM WITH8RADIAL ILITI FOR BAMPLIMI OR IAIIMI

d. 

### 10 Samplewell assembly

DECKIHIET

UGGUIDE AIIEMILY

LEG ILUYEAIIEMILY fLOAT ITOP DECK IH£El ===t

fLOATWELL

') II EXISTING GAUGE TAPE AND flOAT



### f. Automatic gauge floatwell assembly7

e. Pressure/vacuumbreakerassembly7 Internal floating roof deck fittings (Continued). Figure 3-10.including slidingcovers and fabric sleeves, which must accommodate the movements of the deck relative to the column as the liquid levels change.6 Asliding cover rests on the upper rim of the column well (which is normally fixed to the roof) and bridges the gap or space between the column well and the column. The cover, which has a cutoutor opening around the column, slides in a vertical direction relative to the column as the roof raises and lowers. At the same time, the cover slides in a horizontal direction relative to the rim of thewell, which is fixed to the roof. Agasket around the rim of the well reduces emissions from this fitting. Aflexible fabric sleeve seal between the rim of thewell and the column (with a cutout or opening to allow vertical motion ofthe seal relative to the columns) similarlyaccommodates limited horizontal motion of the roof relative to the column. Athird design, which is proprietary, is depicted in Figure 3-lOb. This design, in effect, combines the advantages of the flexible fabric sleeve seal with awell thatexcludes all but a small portion ofthe liquid surface from direct communication with the vapor space above the floating roof. 3.2.3.3 Roof Legs orHangerWells. To prevent damage to fittings underneath the deck and to allow for tank cleaning or repair, supports are provided to hold the deck apre-determined distance offthe tank bottom. These supports consistof adjustable or fixed legs attached to the floating deck or hangers suspended from the fixed roof. For adjustable legs or hangers, the load-carryingelement passes through awell or sleeve in the deck. the liquid stock.6 With noncontact decks, thewell should extend into Figure 3-lOc depicts a roof leg assembly. 3.2.3.4 Sample Pipes orWells. Asample well may be provided to allow for sampling of the liquid stock. Typically, thewell is funnelshaped to allow for easy entry of a sample thief. Aclosure is provided, which is typically located atthe lower end of the funnel and which frequently consists allow thiefentry. 6 noncontact decks. of a horizontal piece of fabric slitradially to The well should extend into the liquid stock on Figure 3-lOd depicts a sample well assembly. Alternately, a sample well may consist of a slottedpipe extending into the liquid stock, equipped with an ungasketed or gasketed sliding 6

. cover.

3-233.2.3.5 Vacuum Breakers. When the internal floating deck is eitherbeing landed on its legs or floated off its legs, a vacuum breaker is used to equalize the pressure of the vapor space across the deck. This is accomplished by opening a deckpenetration thatusually consists of awell formed ofpipe or framing on which rests a cover. To the underside of the cover is attached a guided leg of such length that it contacts the tank bottom as the internal floating deck approaches the tankbottom. When in contactwith the tankbottom, the guided leg mechanically opens the breakerby liftingthe cover off the well. When the leg is not contactingthe bottom, the penetration is closed by the
cover resting on thewell. The closure may be with orwithout a gasket between the cover and neck. Since the purpose of the vacuum breaker is to allow the free exchange of air and/or vapor, thewell does not extend appreciablybelow the deck.6 Figure 3-lOe depicts apressure vacuum assembly. The gasket on the underside of the cover, or conversely on the upper rim of thewell, provides a small measure of emission control**(~20** percent emissions reduction) during periods when the roof is free floating and the breaker is closed. 3.2.3.6 Automatic Gauge FloatWells. Gauge floats are used to indicate the level of stockwithin the tank. They usually consist of a float residingwithin awell thatpasses through the floating deck. The float is connected to an indicatoron the exterior of the tank via a tape passingthrough a guide system on the fixed roof. The float rests on the stock surfacewithin thewell. The well is closed by a cover that rests on thewell. Evaporation loss can be reduced by gasketing and/orbolting the connection between the cover and the rim ofthewell. The cablepasses through abushing located atthe center of the cover. As with other similar deck penetrations, the well extends into the liquid stockon noncontact floating decks.6 Figure 3-lOf depicts a bolted automatic gauge float well assembly. 3.2.3.7 LadderWells. Some tanks are equippedwith internal ladders that extend from amanhole in the fixed roof to the tank bottom. The deck opening through which the ladderpasses is constructedwith similar design details and considerations as those for column wells, as discussed in Section 3.2.3.2.6

3-243.2.4 StorageTank Emissions and Emission Equations 3.2.4.1 Fixed-RoofTank Emissions. The major types of emissions from fixed-roof tanks are breathing and working losses. Breathing loss is the expulsion ofvapor from atank vapor space that has expanded or contractedbecause of daily changes in temperature and barometric pressure. The emissions occur in the absence of any liquid level change in the tank.Filling losses are associatedwith an increase ofthe liquid level in the tank. The vapors are expelled from the tankwhen thepressure inside the tank exceeds the reliefpressure as a result of filling. Emptying losses occurwhen the airthat is drawn into the tank during liquid removal saturates with hydrocarbon vapor and expands, thus exceeding the fixed capacityofthe vapor space and overflowing through the pressure vacuum valve. Combined filling and emptying losses are called 11working losses. 11 Emission equations for breathing and working losses were developed for EPA Publication No. AP-42.11 The equations used in estimating emissions rates for fixed roof tanks storingVOL are: LT

## =LB + LW (3-1)
LB = 1.02 X 10-5 M ( p )0

·68 

### D 1•73

### H 0•51T 0•5FCK (3-2) v 14.7-P 

### P c

where, LT

## =total loss (Mg/yr) L

8=breathing loss (Mg/yr) 

## Lw =working loss (Mg/yr) M =molecularweight ofproductvapor (lb/lbmole); 80 assumed

v as a typical value for VOL liquids P =true vapor pressure ofproduct (psia) 

### D =tank diameter (ft) 

### H =average vapor space height (ft): use tank specific values or an assumed value of one-halfthe tank height T 

## =average diurnal temperature change in °F; 20°F assumed as a typical value

3-25Fp =paint factor (dimensionless); 1.0 for clean white paint C =tankdiameter factor (dimensionless): for diameter**~** 30 feet, 

### C= 1 for diameter <30 feet, 

## c=0.0771 0

- 0.0013(02)

- 0.1334 K =product factor (dimensionless)= 1.0for VOL

c V =tankcapacity (gal) 

### N =number ofturnovers peryear (dimensionless) Kn =turnover factor (dimensionless): f t 36 

### K

## =180 +N

or urnovers > , n 6N for turnovers**~** 36, Kn = 1 3.2.4.2 External Floating-RoofTank Emissions. Standing-storage losses, which result from causes other than a change in the liquid level, constitute the major source of emissions from external floating roof tanks. The largestpotential source ofthese losses is an improper fit between the seal and the tank shell (seal losses). As a result, some liquid surface is exposed to the atmosphere. Air flowing over the tank createspressure differentials around the floating roof. Air flows into the annular vapor space on the leeward side and an air-vapormixture flows out on thewindward side. Withdrawal loss is another source of emissions from floating roof tanks. When liquid is withdrawn from a tank, the floating roof is lowered, and awet portion ofthe tankwall is exposed. Withdrawal loss is the vaporization of liquid from the wet tankwall. VOL emissions from external floating roof tanks are estimated using equations based on apilottank study conducted for the EPA by the Chicago Bridge and Iron Company.8 Appendix Cdescribes the development of the emission equations and the associated emission factors. From the equations presentedbelow, it is possible to estimate the total evaporation loss for external floating roof tanks, LT, which is the sum ofthewithdrawal loss, 

## Lw• and the external floating roof seal loss, LsE· These equations in large part are extracted from AP-42.11 However, minor changes have been made to update the equations. (Note: external floating roof tanks have no appreciable losses from fittings.)

3-26LT

## =

# lw + LSE (3-4) 

## Lw

## =4.28 X 10-4QCWL/D (3-5) LSE =K 5VNP*DMv Kc/2205 (3-6) where, LT

## =total loss (Mg/yr) 

## Lw=withdrawal loss (Mg/yr) LSE = seal loss from external floating roof tanks (Mg/yr)

4 =product average throughput (bbl/yr); tankcapacity (bbl/turnover) xturnovers/yr C =productwithdrawal shell clingage factor (bbl/103 ft2); use 0.0015 bbl/103 ft2for VOL in awelded steel tankwith light rust (0.0075 for dense rust) WL =density ofproduct (lb/gal); 7.4 to 8.0 lb/gal assumed as typical range for VOL liquids D 

## =tank diameter (ft) K

5

## =seal factor: obtain from Table 3-4 V =averagewindspeed for the tank site (mph); 10 mph assumed average windspeed N 

## =seal windspeed exponent (dimensionless): obtain from Table 3-4 P* =the vapor pressure function (dimensionless); P* =0.068P/((1 + (1- 0.068P)o·s)2) P =the true vapor pressure of the materials stored (psia) Mv =molecularweight ofproduct vapor (lb/lbmole) Kc =product factor (dimensionless)= 1.0 for VOL 3.2.4.3 Internal Floating RoofTank Emissions. As ambient wind flows over the exterior of an internal floating roof tank, air flows into the enclosed space between the fixed and floating roofs through some ofthe shell vents and out ofthe enclosed space through others. Any VOC vapors that have evaporated from exposed liquid surface and that have not been contained by the floating deckwill be swept out of the enclosed space. Losses ofVOC vapors from under the floating roof occur in one of four ways: (1) through the annular rim space around the perimeter of the floating roof (rim or seal losses); (2) through the openings in the deck required for various types of fittings (fitting losses);

3-27Table 3-4. SEAL RELATED FACTORS FOR EXTERNAL FLOATING ROOF TANKSa

Seal type
Metallic shoe seal Primary seal only With shoe mounted secondary seal With rim mounted secondary seal Liquid mounted resilient seal Primary seal only With weather shield With rim mounted secondary seal Vapor mounted resilient seal Primary seal only With weather shield With rim mounted secondary seal 1.2 0.8 0.2

1.1 0.8 0.7

1.2 0.9 0.2 1.5 1.2 1.0

1.0 0.9 0.4

2.3 2.2 2.6 aBased on emissions from tank seal system with emissions

control devices (roof, seals, etc.) in reasonably good working condition, no visible holes, tears or unusually large gaps between the seals and the tankwall. bKS =seal factor in Equation 3-6. eN= seal windspeed exponent (dimensionless) in Equation 3-6.

3-28(3) through the nonwelded seams formed when joining sections of the deck material (deck seam losses); and (4) through evaporation of liquid lefton the tankwall following withdrawal of liquid from the tank (withdrawal loss). The withdrawal loss from an internal floating roof tank is similar to that discussed in theprevious section for external floating roofs. The other losses, seal losses, fitting losses and deck seam losses, occur not only during the working operations ofthe tankbut also during free standingperiods. The mechanisms and loss rates of internal floating roof tanks was studied in detail by the Chicago Bridge and Iron Company for the American Petroleum Institute.6 The results ofthis work form the basis for internal floating roof emissions discussion. Several potential mechanisms for vapor loss from the rim seal area of an internal floating roof tank can be postulated:
• circumferential vapor movement underneath vapor-mounted rim seals; 

# • vertical mixing, due to diffusion or airturbulence, of the vapor in gaps thatmay existbetween any type of rim seal and the tank shell; 

# • expansion of vapor spaces in the rim area due to temperature orpressure changes; • varying solubility of gases, such as air, in the rim space liquiddue to temperature and pressure changes;
• wicking of the rim space liquid up the tank shell; and • vapor permeation through the sealingmaterial. For external floating roof tanks, wind-generated airmovement across the roof is the dominant factor affecting rim seal loss. In comparison, for freely-vented internal floating roof tanks, inwhich the airmovement is significantly reduced, no clearlydominant loss mechanism can be discerned.6 Vapor permeability is the only potential rim seal area loss mechanism that is readily amenable to independent investigation. Seal fabrics are generally reported to have very low permeability to typical hydrocarbon vapors, such thatthis source of loss is not considered to be significant. However, if a seal material is used that is highly permeable to the

3-29vapor from the stored stock, the rim seal loss could be significantly higher than that estimated from the rim seal loss equation presented later in this section.6 Particularlywhen dealingwith VOL rather than petroleum liquids, attentionmust be paidtotheproperties of the individual compounds being stored. For instance, benzene is suspected of having permeability losses that equal orexceed convective and diffusion losses from the seal.13 Additional permeability data for VOL/seal material combinations must be developed to fully characterizethe significance ofpermeability losses. Permeability is discussed in more detail in Appendix C. The extenttowhich any or all of these mechanisms contributes to the total fitting loss is not known. The relative importance of the various mechanisms probably depends on the type of fitting, the design ofthe fitting seal, and whether or not the deck is in contactwith the stored liquid.6 Floating decks are typicallymade by joining several sections of deck material together, resulting in seams in the deck. To the extent that these seams are not completely vapor tight, theybecome a source of loss. Generally the same loss mechanisms discussed for deck fittings may apply to deck seams.6 Emissions from internal floating roof tanks can be estimated from the following equations6 (Note thatthese equations apply only to freely vented internal floating roof tanks.) where: LT =Lw + Lr + Lf + Ld (3-7) L =the total loss (Mg/yr)

T N F L = (0.943) 

### Qc

## wl [1 +

### C_£___o c )J/2205 w 

### D where D =tank diameter (ft) Nc =number ofcolumns (dimensionless) Fe= effective column diameter (ft); 1.0assumed Lr =the Lf=the 

## * rim seal loss (Mg/yr) = (KrD) P Mv Kc/2205 

## * fitting loss (Mg/yr) = (Ff) P Mv Kc/2205 

## * Ld=thedeck seam loss (Mg/yr) = (Fd Kd 02) P Mv Kc/2205

3-30K =the rim seal loss factor (lb mole/ftyr) that for an r average fitting seal is as follows: Seal system description Vapor-mounted primary seal only Liquid-mounted primary seal only Vapor-mounted primary seal plus Kr (lb mole/ftyr)
6.7 3.0 secondary seal 2.5 1.6 Liquid-mounted primary seal plus secondary seal 0=the tank diameter (ft)



## * P =the vapor pressure function (dimensionless) 

### * P 

## =0.068 P/((1 + (1- 0.068 P)o·s)2) P=the true vapor pressure ofthe material stored (psia) Mv =the average molecularweight of the product vapor (lb/lbmole). Atypical value for VOL liquids is 80 lb/lbmole. Kc =theproduct factor (dimensionless) = 1.0 for VOL 2205 =constant (lb/Mg) Ff=the total deck fitting loss factor (lbmole/yr)


### n 

## =l (N Kf_)

## =

. 1 f. 1= 1 1

where: Nf.= 1 number of fittings of a particular type (dimensionless). Nf. is determined for the 1 specific tankor estimated from Tables 3-5 and 3-6 deck fitting loss factor for a particulartype fitting (lbmole/yr). Kf. is determined for each 1 fitting type from Table 3-6

n =number of different types of fittings (dimensionless)

3-31Table 3-5. TYPICAL NUMBER OF COLUMNS AS A FUNCTION OF TANK DIAMETERS6

Tankdiameter range D (ft)

0 <D< 85 85 <D

## <100 100 <

### D

## <120 120 <

### D

## <135 135 <

### D

## <150 150 <

### D

## <170 170 <

### D

## <190 190 <

### D

## <220 220 <

### D( 235 235 <

### D

## <270 270 <

### D

## <275 275 <D

## <290 290 <

### D

## <330 330 <

### D

## <360 360 <

### D

## <400 Typical number columns, Nc

1 6 7 8 9 16 19 22 31 37 43 49 61 71 81
Note: This table was derived from a survey of users and manufacturers. The actual number of columns in aparticular tankmay vary greatly depending on age, roof style, loading specifications, and manufacturing perogatives. This table should not supersede information based on actual tank data.

3-32Table 3-6. SUMMARY OF DECK FITTING LOSS FACTORS (Kf) AND TYPICAL NUMBER OF FITTINGS (Nf)6

Deck fitting type 1. Access Hatch a. Bolted cover, gasketed b. Unbolted cover, gasketed c. Unbolted cover, ungasketed 

### 2. Automatic Gauge FloatWell a. Bolted cover, gasketed b. Unbolted cover, gasketed c. Unbolted cover, ungasketed 3. Co1umn We11 a. Built-up column-sliding cover, gasketed b. Built-up column-slidingcover, ungasketed c. Pipe column-flexible fabric sleeve seal d. Pipe column-sliding cover, gasketed e. Pipe column-sliding cover, ungasketed 4. Ladder We11 a. Sliding cover, gasketed b. Sliding cover, ungasketed 5. Roof Leg or HangerWell a. Adjustable b. Fixed 6. Sample Pipe orWell a. Slottedpipe-sliding cover, gasketed b. Slottedpipe-slidingcover, ungasketed c. Sample well-slit fabric seal, 10% open area 7. Stub Drain*, l-inch diameter 8. Vacuum Breaker a. Weighted mechanical actuation, gasketed b. Weighted mechanical actuation, ungasketed Deck fitting loss factor, K (lbmole/yt)

1.6 11 25

5.1 15 28

33 47 10 19 32 56 76

7.9 0

44 57 12

1.2

0.7 0.9 

### *Not used on welded, contact internal floating decks. ** D

## =tank diameter (ft). 3-33 Typical number of fittings, (Nf) 1

1

(see Table 3-5)

1

D 02 ** (5 + 10 + 600)

1Fd =the deck seam length factor (ft/ft2)

=**0.~5,** for a deck constructed from continuous metal sheets with a 7ft spacing between seams

=0.33, for a deck constructed from rectangularpanels 

### 5ft by 7.5 ft

=0.20, an approximate value for use when no construction details are known
Kd =the deck seam loss factor (lbmole/ftyr)

=0.34 for non-welded roofs

=0for welded decks
3.3 BASELINE CONTROL AND EMISSIONS ESTIMATES The baseline control level is setby state regulations that affect VOL storage vessels. The control requirements are setforth in the State implementation plans (SIP). Atypical SIP requires tanks with capacities greater than 40,000 gallons**(~150** m 3) storingmaterial with vapor pressures greaterthan 1.5psia**(~10.5** kPa), but less than 11 psia**(~76.6** kPa), to have a floating roof. For this group of tanks, baseline control is assumed to be the noncontact internal floating roofwith a vapor-mounted primary seal, because it is the least costlymeans of complying with the SIPs. Atypical SIP requires tanks with capacities greaterthan 40,000 gallons**(~150** m 3) storing liquids with vapor pressures greater than 11 psia**(~76.6** kPa) to either have vapor recovery systems or to be constructed as high pressure vessels. Therefore, vapor recovery is assumed to be the baseline control for this group of tanks. Texas contains an estimated 35 percent ofthe total national VOL tankpopulation and has an atypical SIP. Texas requires tanks with capacities greaterthan 25,000 gallons**(~95** m 3) storingVOL with a vapor pressure greater than 0.5 psia**(~3.5** kPa) but less than 11 psia**(~76.6** kPa)

3-34to have a floating roof. Tanks with capacities greaterthan 25,000 gallons**(~95** m 3) storingVOL with vapor pressures greater than 11 psia (276 kPa) must have a vapor recovery system. Texas contains such a significant portion of the tank population that this difference in cutoff sizemust be considered in the baseline control level. Therefore, in addition to the floating roofs in all tanks with capacities greaterthan 40,000 gallons**(~150** m 3) and storingVOL with vapor pressures between 1.5 and 11 psia**(~10.5** and 76.6 kPa), it is assumed that 35 percent ofthe tanks with capacities between 25,000 gallons and 40,000 gallons**(~95** m 3to 150 m 3) storingVOL with vapor pressures between 0.5 psia and 11.5psia**(~3.5** to 76 kPa) will be constructedwith noncontact internal floating roofs with vapor-mounted primary seals in the absence of a standard ofperformance. It is further assumed that 35 percent ofthe tanks that have capacities between 25,000 gallons and 40,000 gallons**(~95** m 3and 150m3) storing VOL with vapor pressures greaterthan 11 psia**(~76.6** kPa), will be constructedwith vapor recovery systems or stored inpressure vessels. This is in addition to the vapor recovery systems orpressure vessels for all tanks greaterthan 40,000 gallons**(~150m )**  and storingVOL with vapor pressures exceeding 11 psia (76.6 kPa). The remaining 65 percent of the tanks that have capacities between 25,000 gallons**(~95m )**  and 40,000 gallons**(~150** m 3) and storingmaterials with vapor pressures between 0.5 and 1.5psia**(~3.5** and 10.5 kPa) are assumed to be uncontrolled, fixed-roof tanks. It is assumed that every tank smallerthan 25,000 gallons**(~95** m 3) and every tank storingmaterial with a vapor pressure less than 0.5psia**(~3.5** kPa) will be constructed as an uncontrolled, fixed-roof tank. Figure 3-11 summarizes the baseline control assumptions. The total VOC emission rate from VOL storage vessels is estimated to be 37,800 Mg/yr based on the 1977 tankpopulation described in Section 3.1and the baseline control levels. This estimate assumes that currently existing or developing state regulations are fully implemented
on the 1977 tankpopulation. Included in this emissions total are an estimated 34,000 Mg/yr ofVOC emitted from fixed roof tanks and an estimated 3,800Mg/yr ofVOC from floating roof tanks. The 37,800 Mg/yr emissions total is broken down among the three vapor-pressure/tank-size

3-35w I w 0) Ill a.

...... ex: => V) V)

...... ex: a.. ex: 0 a.. ;; 1.0I No controlsrequired

0.5 - baseline isassumed to be fixed-rooftanks Texas requires vapor control orpressurevessels

- baseline is assumed to be 35% vapor control systems or pressure vessels, 65% fixed-roo'ftanks Typical SIPs require vapor control or pressurevessels

- baseline is assumed to be vaporcontrol orpressure vessels



# --

# ----------·---------------

Texas requires controls

- baseline isassumed tobe 35% noncontact internal floating-roof tanks, 65% fixed-roof tanks Typical SIPs requirecontrols -baselineisassumed to be 100% noncontact internal floating-roof tanks

## o~-----L------~----~------~------~-------------------- 30 35 40 20 25 TANKVOLUME (103gallons)


### Figure 3-11. Baseline control summary.regions that comprise the baseline control level scenario in Figure 3-12. Note that the number of tanks storing liquids with vapor pressures greaterthan 58.7 kPa (8.5 psia) is less than 1percentof the tank population. These tanks have very**littl~** effect on the estimated number of tanks and emissions listed in Figure 3-12.

3-37

# - - 

# .. a.



### .... ac:**~** 

### ., .,
.... ac: A. ac: 0 A. c( > 11,0

1.0 Numberoftanks Fixed roof 1,871 Floating roof 1.007 Total 2,878 Emissions**-~** 13,100 __§QQ 13,900

TANKVOLUME (103gallons) Emissions Number oftanks (!1!9/yr) Fixed roof 0 0 Floatingroof 2,786 3,000 Total 2,786 3,000



### Figure 3-12. Baseline emissions totals (mg/yr; 1977 tank population) and numbers oftanks by vapor pressure/tank size region.

3-383.4 REFERENCES 1. Erickson, D. G. Emission Control Options for the SyntheticOrganic Manufacturing Industry; (Unpublished draft submitted in fulfillment of EPA Contract No. 68-02-2577). Hydroscience, Inc. Knoxville, Tennessee. October 1978. 97 p. 2. Radian, Inc. The Revised Organic Chemical Producers Data Base System, Final Interim Report; (Submitted in fulfillment of EPA Contract No. 68-03-2623.) Austin, Texas. March 1979. 3. Booz, Allen, and Hamilton, FosterD. Hydrocarbon Emissions Control to the Manufacturing Chemists Association. December 1977. Snell Division. Cost of U.S. Chemical Industry (SIC 28). Florham Park, New Jersey.
4. Memorandum from Rockstroh, M. A., TRW to Moody, W. T., TRW. February 1, 1980. 5. International Liquid Terminals Association. Bulk Liquid Terminals and Storage Facilities, 1979 Directory. Washington, D.C. 1979. 85 p. 6. The American Petroleum Institute (API) DraftDocument, Evaporation Loss from Internal Floating Roof Tanks. API Publication 2519. Third Edition. 1982. 7. RFI Services Corporation. The Woodlands, Texas. Figures extracted from promotional literaturewith the permission ofthe company. 8. U.S. Environmental ProtectionAgency. Measurements of Benzene Emissions from a Floating-RoofTestTank. Report No. EPA-450/3-79-020. Research Triangle Park, North Carolina. June 1979. 9. Brown Boilerand TankWorks, Ltd. Franklin, Pennsylvania. Figure extracted from promotional literaturewith the permission of the company. 10. Ultraflote Corporation. Houston, Texas. Figure extracted from promotional literaturewith thepermission ofthe company. 11. U.S. Environmental ProtectionAgency. Compilation ofAir Pollution Emission Factors. Report No. AP-42; Supplement 12, Research Triangle Park, North Carolina. April 1981. 12. TRW Environmental Division, Background Documentation for Storage of Organic Liquids. EPA Contract No. 68-02-3174. Research Triangle Park, N.C. May 1981. 13. U.S. Environmental Protection Agency, DraftVolume II Background Information Document for Benzene Storage Hazardous Air Pollutant Standards, EPA 450/ , January 1983. 3-394. CONTROL TECHNIQUES
This section describes the control techniques applicable to emissions of volatile organic compounds (VOC) from the storage of volatile organic liquids (VOL). It should be recognized that the emission sources in this industry are 11un-traditional 11 in the sense thatthey do not have exhaust streams that normally are controlled by add-on control devices. Consequently, the evaluation of control techniques is not a straight-forward process of identification, testing and direct comparison of a series of add-on devices. Rather, it is the comparison of alternative tank types and equipment options that can be selected for use in storingVOL. 4.1 OVERVIEW As discussed in Chapter 3, there are three major types of vessels used to storeVOL: fixed roof tanks, internal floating roof tanks, and external floating roof tanks. In addition, optional equipment designs existwithin each major tanktype (e.g. seal design, roof fabrication fittings closure). Each tank type and equipment option has its own associated emissions rate. In effect, there is a spectrum of equipment options, with a corresponding spectrum of emission rates. The control techniques to be evaluated are these alternative storage vessel equipment types. The major equipment options that affect emissions from the storage ofVOL include:
1 the tanktype: fixed roof, internal floating roof, orexternal floating roof;
1 the floating roof deck type: welded orbolted (pertinent to internal floating roof tanks only);1 the floating roofprimary seal location: liquid- or vapor-mounted (pertinent to internal and external floating roof tanks);
• the types of deck fittings: controlled or uncontrolled (pertinent to internal floating roof tanks only); 1 the floating roof seal system: primary seals only or primary and secondary seals (pertinent to internal and external floating roof tanks); and
1 the use of add-on vapor control techniques: incinerators, adsorbers, or refrigeratedcondensers (pertinent to fixed roof tanks only). Considering the optional types of equipment that can be used to storeVOL, a hierarchy of equipment alternatives can be developed based on emission rate. This hierarchy, in order of decreasing emission rates, is listed inTable 4-1. The types of storage vessel equipment listed inTable 4-1 are described in detail inChapter 3. Chapter 3 also outlines equations for estimating the emission rate for each ofthe major tanktypes and the equipment options that are available. These equations and the testdata used to develop the equations (discussed in Appendix C) form the basis for evaluatingthe effectiveness of the control techniques discussed in this chapter. The hierarchy of equipment options presented in Table 4-1 suggests thatthe emission rate of each control option relative to the others remains constant over all situations thatmay be found in the VOL storage industry. This is the case among the internal floating roof tanks, fixed roof tanks, and external floating roof tanks with liquid-mounted primary and secondary seals (Options 1, 3-7, and 9 inTable 4-1). For the most part, the relationship also holds true over the range of conditions (e.g. vapor pressure, number ofturnovers, etc.) commonly found in the industry for the vapor recovery or control and for the external floating roof tank, vapor-mounted primary and secondary seal (Options 2and 8 in Table 4-1). The ranking ofthese two options, however, does vary with the tank size and the vapor pressure ofthe material stored. To illustrate the relative emission rates ofthe equipment options, the total emission rates for each option for a range of tank sizes (100 to 10,000 m 2) has

4-2Table 4-1. HIERARCHY OF EQUIPMENT TYPES BASED ON EMISSIONS RATEa
Control

Option Equipment description
1 Fixed roof tank (baseline) 2b External floating roof tank, vapor-mounted primary and secondary seals 3 Internal floating roof tank, bolted construction (contactor noncontact), vapor-mounted primary seal only, with uncontrolled deck fittings 

### 4 Internal floating roof tank, bolted construction (contact or noncontact), liquid-mounted primary seal only, with uncontrolled deck fittings 5 Internal floating roof tank, boltedconstruction (contact or noncontact), liquid-mounted primary seal only, with controlled deck fittings 6 Internal floating roof tank, boltedconstruction (contactor noncontact), liquid-mounted primary and secondary seals, with controlled deck fittings 7 Internal floating roof tank, welded construction (steel pan or FRP deck), liquid-mounted primary and secondary seals, with controlled deck fittings 8b Fixed roof tankwith thermal oxidation, carbon adsorption or refrigerated condenser add-on vapor recovery equipment 9 External floating roof tank, deck types are welded construction, liquid-mounted primary and secondary seals, controlled deck fittings are not applicable Abbreviated notation Fixed roof tank EFRvm,ss

IFR b lm,cf,ss

IFR w lm,cf,ss

Vapor recovery orcontrol

EFRlm,ss

alisted in order of decreasing emission rates; Control Option 1

possessing the largest emission rate and Control Option 9possessing the smallest emission rate. bThe rank based on emissions rate for this option varies depending on

the specificparameters (e.g., number ofturnovers, tank size) of the tank being considered. 4-3been calculated and plotted in Figures 4-1 and 4-2. Figures 4-1 and 4-2 are for tanks with 50 and 10 turnovers peryear, respectively. The plotted emission rates are for a storedVOL with a vapor pressure (in liquid and condensed vapor phase) of 34.5 kPa (5 psia). (See Figures 4-1 and 4-2.) Apart from the intrinsic emission-affecting characteristics of each tank type and equipment option, the emission rate from all storage vessel types is affected by the vapor pressure of the material stored and the frequency of tankturnovers. The impact ofthe vapor pressure and the turnover rate on the emission rate, however, varies among the three major tank types. Consequently, the hierarchy of equipment-types, or the relative emission rates of the various equipment types, can be affected by these variables. Comparison of Figures 4-1 and 4-2 illustrates the effects of turnovers. The tank scenarios, for which emission rates areplotted, are identical in these figures exceptfor the turnover rate. Figure 4-1 is for tanks experiencing 50 turnovers peryear and Figure 4-2 is for tanks experiencing 10 turnovers peryear. It can be
seen that decreasing the annual turnover rate from 50 to 10 decreases the emission rate for fixed roof tanks and fixed roof tanks with vapor recovery or control systems; conversely, the turnover rate has very littleeffect on internal and external floating roof tank emission rates: consequently, the higher the turnover**rate~** the larger the difference between fixed roof and floating roof tank emission rates. The rank or relative effectiveness of fixed roof tanks equippedwith vapor recovery or control devices is adversely affected by an increase in the turnover rate (i.e., the relative effectiveness as a control technique decreases). The effects that the vapor pressure of the storedVOL has on the relative emission rates of the equipment options are not illustratedby Figure 4-1. As the vapor pressure of the stored liquid increases, the emission rates from both fixed and floating roof tanks increase. However, the vapor pressure functions in the equations used to estimate losses from fixed and floating roof tanks differ, and, therefore, the percent increase in floating roof tankemissions is greater than thepercent

4-4s.... >, 

# - C'l ::E:
Q) -+J ro 0::: VI**~** 0 .,.... Ill Ill .,.... E w 1,000

100 -(1)

10

-(2) -(3) 1.0 -(5) -(6) -(4)

0.1

10 100 1,000 10,000 Tank Capacity (M3) Figure 4-1. Emissions rates for alternative equipment types (50 turnovers peryear; vapor pressure= 1.0psia). 4-5s.... >,

........ en ::E:

.......... QJ +-> <a a::: Vl s;; 0 .,.... Vl Vl .,.... E l.J..J 

### 1,000

100

10

-(2) --(3) 

### 1.0 --(5) -(6) -(4)



### 0.1

0.01 10 100 1,000 10,000 Tank Capacity (M3) Figure 4-2. Emissions rates for alternativeequipment types (10 turnovers peryear; vapor pressure= 1.0 psia). 4-6increase in fixed roof tankemissions for a similar increment in vapor pressure. (Note that this trend may reverse above 8.5psia depending on the ratio of fixed roof tank breathing losses toworking losses.) Consequently, an increase in vapor pressure decreases the difference between fixed and floating roof tank emission rates. This is opposite to the effectofthe turnover rate. Within the range ofconditions commonly found in VOL storage vessels, however, neitherthe effectof the vapor pressure nor the turnover rate changes the rank ofthe fixed roof tank and floating roof tank equipment options. Because the emission rate from all types oftanks is affectedby a number of tank variables (i.e., vapor pressure, tank size, turnovers, the nature oftheVOL), a singlemodel tank is used as a common basis for evaluating effectiveness. The model tank has the following characteristics:
• tank diameter- 9.1m(30ft);
• tank height- 9.1m(30ft);
• tank capacity

- 606m3 (160,000 gallons); • vapor pressure of the VOL stored- 6.9 kPa (1 psia); • density ofVOL stored

- 7.4 lb/gallon;
• molecularweight of theproduct vapor - 80 lb/lbmole; and • turnover rate

- 50 peryear. The emissions associatedwith the model tank under each equipment option have been estimatedwith the equations presented in Chapter 3 and listed for comparison inTable 

### 4-2. The significance of these emission estimates are discussed in the following sections. 

### 4.2 FIXED ROOF TANKS Afixed roof tank is the minimum acceptable equipment currently employed for the storage ofVOL. The discussion of control techniques, therefore, will relate the effectiveness of alternative storage equipment types to the effectiveness of fixed roof tanks. Working and breathing losses normally incurred from the storage ofVOL in fixed roof tanks can be reduced in any of the following ways: (1) by the installation of an internal floating roofwith rim seals;

4-7+:> I CX> Fixed roof tank Breathing Working

Losses Losses

0.88 5.34 

### Table 4-2. MODEL TANK EMISSION RATES FOR DIFFERENT EQUIPMENT OPTIONS1 (Mg/yr)

Sea1 1 osses Type Emission Vapor-mounted 0.128 Liquid-mounted 0.058 Vapor-mounted 0.048 with secondary Liquid-mounted with secondary 0.031 Internal floating roof tank Fitting losses Case Emission
Uncontrollei Centro11ed3 0.21 0.11 Deck losses Rooftype Emission

Bolted Welded 0.04 0.0 Internal and external f1oating roof tank Working losses

0.03

1Model tankparameters: 160,000 galloncapacity 30 feet in diameter; 30 feet in height 1psia vapor pressureofthe material stored 80 lbs/lbmolemolecularweight of theproduct as liquidproduct and as condensed vapor 50 turnoversperyear 7.4 lb/gallondensity External floating rooftank Seal losses Type Emission Vapor-mounted 4.59 Liquid-mounted 0.21 Vapor-mounted 1.52 with secondary Liquid-mounted 0.034 with secondary Metallic shoe 0.727 Metallic shoe 0.038 with secondary

2uncontrolled assumes: (1) access hatch, with ungasketed, unbolted cover; (2) automatic gauge floatwell, with ungasketed, unbolted cover;

(3) 1-built-upcolumn well, with ungasketed slidingcover; (4) ladderwell, with ungasketed slidingcover; (5) 10-adjustableroof legs; (6) !-samplewell with slit fabric seal (10% open area); (7) 7-one inch diameter stubdrains; and (8) !-vacuumbreakerwith gasketedweighted mechanical actuation. 3controlled assumes: (1) !-access hatch, with gasketed, boltedcover; (2) !-automaticgauge float well, with gasketed, boltedcover; (3) 1-pipe

column with flexible fabric sleeve seal; (4) !-ladderwell, with gasketed slidingcover; (5) 10-adjustable roof legs; (6) sample well with slit fabric seal (10% open area); (7) 7-one inch diameter stub drains; and (8) vacuum breaker, with gasketedweightedmechanical actuation.(2) by the construction of an external floating roof tankwith liquid-mounted primary and secondary seals in lieu of a fixed roof tank; and (3) by the installation and use of a vapor recovery system (e.g., carbon adsorption or refrigeratedcondensation) or a vapor control system (e.g., incineration). This listdefines only the major types of control techniques applicable to the storage ofVOL. Optional equipment designs that influence the effectiveness ofminimizing VOL emissions existwithin each major type of control technique. The following sections discuss the relative effectiveness of these equipment options. 4.3 INTERNAL FLOATING ROOF TANKS Internal floating roof tanks with rim seal systems emit less VOC per unit of storage than fixed roof tanks. In new and replacement tank situations, internal floating roof tanks can be constructed in lieu of fixed roof tanks. In this sense they are a control technology for fixed roof tanks. Internal floating roofs also can be used directly as a control device for existing fixed roof tanks. This requires minor modifications to the tank shell (e.g., cutting roof vents). Depending on the type of roof and seal system selected, an internal floating roof in the model fixed roof tankwill reduce the emission rate by 93.4 to 97.3 percent. An internal floating roof, regardless of design, reduces the area of exposed liquid surface in the tank. Reducing the area of exposed liquid surface, in turn, decreases the evaporative losses. The largest emissions reduction available from the control options is achieved by the presence of the floating roof vapor barrier thatprecludes direct communication between a large portion of the liquid surface and the atmosphere. All internal floating roofs share this design benefit. The relative effectiveness of one internal floating roof design over another, therefore, is a function of how well the floating roof can be sealed. From an emissions standpoint, the most basic internal floating roof design is the noncontact, bolted, aluminum, internal floating roofwith a single vapor-mounted wiper seal. As discussed in Section 3.2.4.3,

4-9there are four types of losses from this roof design. These losses with an estimate oftheir respective loss from the model tank are as (1) rim or seal losses; (2) fitting losses; percentage follows: 32% 

### 51% (3) deck seam losses; and 10% (4) withdrawal losses. 7% contributions to the total

With the exception ofwithdrawal losses, which are inherent in all internal floating roof designs, the losses listed above can be reduced by employing roofs with alternative design features. Table 4-3 lists alternative floating roof equipment designs and the model tankemission rate associatedwith each type of equipment. Table 4-3 is calculated from the emission estimates in Table 4-2 by adding the appropriate emission components for each case. The following sections elaborate on the alternative equipment that can be employed on internal floating roofs. The discussion is arranged according to the major emissions categories. 4.3.1 Controls for Fitting Losses Fitting losses occur through the penetrations in an internal floating deck. Penetrations existto accommodate the various types of fittings that are required for proper operation of an internal floating roof. Fitting losses can be controlledwith gasketing anq sealing techniques,
orby the substitution of a lower emitting fitting type that serves the same purpose. Table 4-4 lists the fitting types that are pertinentto emissions and an abbreviated description ofthe equipment that is considered to be representative of 11uncontrolled11 fittings and 11controlled11 fittings. Certain fitting types are not amenable to control. These are not listed inTable 4-4. Section 3.2.3provides a more detailed description of the various fitting types and the 11control techniques11 thatcan be applied. The effectiveness of fitting 11controls11 at reducing the overall emission rate is a function of the number of fittings of each type that
are employed on a given tank. On the model tank, which is representative of a typical medium sized tank, fitting 11controls11 reduce the total

4-10Table 4-3. EFFECTIVENESS OF INTERNAL AND EXTERNAL FLOATING ROOF TANKS COMPARED TO AFIXED ROOF TANK FOR THE MODEL TANK1

Internal or external floating rooftank Reduction over type2 Total**emissio~** fixed roof tank Fixed roof tank Case Equipment rate (Mg/yr) emission rate
Total emission rate 1 biFRvm 0.408 93.4% 6.22 Mg/yr (Working loss= 5.34) 2 biFRvm,cf 0.308 95.0% (Breathing loss=0.88) 3 IFR b vm,cf,ss 0.228 96.3% 4 biFRlm 0.338 94.6% 5 biFRlm,cf 0.238 96.2% 6 IFR b lm,cf,ss 0.211 96.6% 7 IFR w lm,cf,ss 0.171 97.3% 8 EFR4 vm 4.62 25.7% 9 EFR4 vm,ss 1.55 75.1% 10 EFR4 lm 0.24 96.1% 11 4 EFRlm,ss 0.064 99.0% 12 EFR4 ms 0.76 87.8% 13 EFR4 ms,ss 0.068 98.9% 1Model tank is 160,000 gallons capacity; 30 feet in diameter, 30 feet in

height, 1psiavapor pressure, 80 lb/lbmole molecular weight ofproduct and condensed product vapor and 50 turnovers peryear. 2Nomenclature explanation

- biFR

- The subscriptborwindicates a

bolted orwelded roof deck;

### IFRv~~8f~gtes an internal floating roof type; EFR indicates an external floating roof tanktype; the subscriptvm, lm, orms indicates a vapor-mounted, liquid-mounted ormetallic shoe primary seal; the subscriptcf indicates controlledfittings as described inthe notes of Table 4-2; lackof the cf subscript indicates uncontrolled fittings; the subscript ss indicates a rim-mounted secondary seal; a lackofthe ss subscript indicates that no secondary seal is employed. 3sum of seal loss, fitting loss, deck loss and working loss from Table 4-2. 4External floating roofs are all welded construction and do not incur

appreciable deck seam losses. 4-11Deck fitting type

1. Access hatch

2. Automatic gauge float well
3. Column well

4. Ladder well 5. Sample pipe or well

6. Vacuum breakerTable 4-4. 11CONTROLLED11 AND 11UNCONTROLLED11 INTERNAL FLOATING ROOF DECK FITTINGS Equipment descriptions Uncontrolled Controlled Unbolted, ungasketed cover*; Bolted, gasketed cover or unbolted, gasketed cover Unbolted, ungasketed cover*; Bolted, gasketed cover or unbolted, gasketed cover Built-up column-sliding cover, ungasketed*; built-up column-sliding cover, gasketed; pipe column-sliding cover, ungasketed; or pipe column-sliding cover, gasketed Ungasketed sliding cover* Slottedpipe-slidingcover, ungasketed; or slottedpipe-sliding cover, gasketed Weighted mechanical actuation, ungasketed* Pipe column-flexible fabric sleeve seal

Gasketed sliding cover Sample well with slit fabric seal, 10% open area* Weighted mechanical actuation, gasketed *The fittings assumed in the uncontrolled case for estimating the effectiveness of fittings controls are marked with a single asterisk in the above table. This fittings scenario is representative of no single tank, but rather is the composite ofwhat is estimatedbased on a survey of users and manufacturers to be typical of fittings on the majority of tanks currently in service. Note that the sample well with split fabric seal was used in the 11uncontrolled11 case for calculating emissions because itis in common use. Itwas also used in the ••controlled11 case because it is the lowest emitting fitting type.

4-12fitting loss by about 48 percent. Since fitting losses are about 51 percent of the total internal floating roof tank loss (i.e., for an IFRvm case), the fitting 11controls11 reduce the overall internal floating roof tank emission rate by about 25 percent over the IFR without fitting controls. vm The additional emission reduction obtained by controlling fitting emissions increases the control efficiencyofthe IFR from 93.4percent to 95.0 percentover a fixed roof tank as the base case. 4.3.2 Controls for Seal Losses Internal floating roof seal losses can be minimized in either of two ways ortheircombination: (1) by employing liquid-mounted primary seals instead ofvapor-mounted seals; (2) by employing secondary wiper seals in addition toprimary seals. All seal systems should be designed, installed and maintained to minimize the gap between the seals and the tank shell. The testdata discussed inAppendix Csupport the general conclusion that seal losses increase rapidlywhen the seal gap exceeds 63.5 square centimeters per meter of tank diameter (3 in2/ftdiameter). Below this level, the effectof seal gap on seal loss is much less pronounced. The effectiveness of alternate internal floating roof seal systems can be evaluatedthrough inspection of the rim seal loss factors (K )

- r that have been developed based on test data (summarized in Appendix C) for estimating losses for various seal systems. These factors are listed in Table 4-5. (Note these factors are for sealswith average gaps.) Also listed in Table 4-5 are control efficiency and incremental control efficiencyestimates. The control efficiencyestimates (column 3 in Table 4-5) indicate the effectiveness of the various seal systems at reducing emissions over the level achieved by a vapor-mounted primary seal. (Note thatthe vapor-mounted primary seal is assumed to be the baseline control level toprovide acommon basis of comparison.) The incremental control efficiency estimates (column 4 inTable 4-5) demonstrate the effectiveness ofeach seal system relative to the next less stringent seal system (i.e., the next higher emitting seal system). These efficiencies are calculated directly from the Kr values.

4-13

### Table 4-5. 

### INTERNAL FLOATING ROOF RIM SEAL SYSTEMS SEAL LOSS FACTORS AND CONTROL EFFICIENCIES

Seal loss control K 

### efficiency related Incremental Seal system ( 1 b-mo1 &!ft-yr) to baseline control efficiency Vapor-mounted 6.7 

### IFR baseline (0%) 

### primary seal only Liquid-mounted 3.0 55% 55% 

### primary seal only Vapor-mounted primary and 2.5 63% 17% 

### secondary seals Liquid-mounted primary and 1.6 76% 36% 

### seconadary seals

4-14Application of a liquid-mounted primary and secondary seal system in place of a vapor-mounted primary seal would reduce seal losses an estimated 76 percent. On the model tank, where these seal losses represent roughly one-thirdofthe total loss from the tank (i.e., biFR case), vm this 76% reduction in seal losses translates to a 24% reduction in the total loss from the floating roof tank. Relative to fixed roof tank emissions, the additional control provided by the liquid-mounted primary and secondary seal system over the vapor-mounted primary seal system increases the effectiveness ofthe internal floating roof from 95.0 percent to 96.2 percent. (See Case 2vs. Case 5 in Table 4-3.) The currently available emissions test data suggest thatthe location ofthe seal (i.e., vapor- or liquid-mounted) and the presence of a secondary seal are theprimary factors affecting seal losses. Aliquidmounted primary seal has a lower emissions rate and thus a higher control efficiency, than a vapor-mounted seal. Asecondary seal, be it in conjunctionwith a liquid- or avapor-mounted primary seal, provides an additional level of control. The emission test data (addressed in Appendix C) and the corresponding equations for estimating emissions (presented in Chapter 3) indicate thatthe type of seal employed (i.e., resilient tube seal, liquid-filled seal, etc.) plays a less significant role in determining the emissions rate. The type of seal is important only to the extent that the seal must be suitable for the particular application to which it is applied. For instance, a blade-type, elastomeric, wiper seal is commonly employed as a vapor-mounted primary seal or as a secondary seal for an internal floating roof. Because of its shape and materials ofconstruction, this seal may not be suitable for use as a liquid-mounted primary seal. Resilient foam-filled tube and wedge shaped seals, on the other hand, can be used as both liquidand vapor-mounted seals. Section 3.2.2provides additional information on the types of seals that are suitable for various applications. The pointtobe made here, however, is thatthe seal type has a small impact on seal losses relative to the impact of the location ofthe seal and thepresence of a secondary seal. Appendix Caddresses the test data pertinent to this conclusion.

4-154.3.3 Deck Seam Losses Depending on the type of floating roof employed, deck seam losses can contribute to the total loss from an internal floating roof. For themodel tank used as abasis for comparison throughout this section (i.e., biFRvm), deck seam losses are 10% ofthe total loss. When seal losses and fitting losses are controlled, the relative contribution to the total loss from deck seams increases. In the case of a bolted, noncontact, internal floating roofwith liquid-mounted primary seals, controlleddeck fitting losses, and secondary seals (biFR1 f ), m,c ,ss deck seam losses contribute about 20 percentof the total loss. Deck seam losses are inherent in several floating roof types. Any roof constructed of sheets orpanels fastened by mechanical fasteners (bolted) is expected to experience deck seam losses. Two roof types were testedto determine deck seam losses (seeAppendix C). The first was a bolted, aluminum, noncontact roof and the second was a bolted, aluminum panel-type, contact roof. The design of the mechanical fasteners employed on these two roof types varies significantly. In addition,
one roof type floats above the liquid surfacewhile the other floats in contactwith the liquid surface. Despite these differences, the seams on these two roof types were found to emit at roughly the same rate per meter of seam. Deck seam losses, therefore, are considered to be a function ofthe length of the seams only and not the type of the seam or its position relative to the liquid surface. The control for deck seam losses is achieved by selection of a roof type with vapor-tight deck seams. The welded deck seams on steel pan roofs are vapor tight. Also, it is likelythatthe fiberglass lapped seams of a glass fiber reinforcedpolyester roof (FRP) are vapor tight as long as the permeabilityofthe liquidthrough the seam lapping materials is negligible. Some manufacturers provide gaskets for bolted metal deck seams. Deck seam gaskets alsomay retard deck seam losses by providing an additional barrierto diffusion and otherpossible deck
seam loss mechanisms. The permeabilityof the liquid through the gasketing material also would be a factor. No test data are available to evaluate the effects of gaskets on deck seam losses.

4-16Selection of awelded roof rather than a bolted roofwill eliminate deck seam losses. The elimination of deck seam losses improves the overall effectiveness relative to a fixed roof tank of an internal floating roofwith liquid-mounted primary seals, secondary seals and controlled fitting losses from a 96.6 to 97.3 percentcontrol efficiency (see Case 6vs. Case 7 inTable 4-3). 4.4 EXTERNAL FLOATING ROOF TANKS External floating roof tanks emit less VOC per unit of storage capacitythan fixed roof tanks. Depending on the rim seal system employed, they also can emit less VOC per unit of storage capacity than internal floating roof tanks. In the sense that external floating roof tanks may be used in place of fixed or floating roof tanks in new or replacement tank situations, they represent a control technology for the storage of VOL. External floating roof tanks do not experience the fitting losses
ordeck seam losses that occurwith most internal floating roof tanks. The external floating roof tanks are constructed almost exclusivelyof welded steel. This accounts for the absence of deck seam losses. Further, because ofthe roof design, few ifany deck penetrations are necessary to accommodate fittings. Penetrations in an external floating roof tank generally are needed only for some types of antirotation guides and emergency liquiddrains. These fitting types are not employed on all external floating roofs. Because the number of deck penetrations in an external floating roof is small relative to the number in an internal floating roof, fitting losses from external floating roof tanks are assumed to be negligible. No emission testdata, however, are available to verify this assumption. Rim seal losses and withdrawal losses that are similar in nature to those experienced by internal floating roof tanks, do occurwith external floating roof tanks. The only difference in this respectbetween external floating roofs and internal floating roofs is that the external floating roof seal losses are believedto be dominated by wind induced mechanisms.1 Withdrawal losses in external floating roof tanks, as with internal floating roof tanks, are entirely a function ofthe turnover rate and

4-17inherent tank shell characteristics. No control measures have been identified that are applicable to withdrawal losses from floating roof tanks. Rim seal losses from external floating roof tanks vary depending on the type of seal system employed. As with internal floating roof rim seal systems, the location ofthe seal (i.e., vapor- or liquid-mounted) is themost important factor affectingthe effectiveness of resilient seals for external floating roof tanks. Liquid-mounted seals aremore effective than vapor-mounted seals at reducing rim seal losses. Metallic shoe seals, which commonly are employed on only external floating roof tanks, are more effective than vapor-mounted resilient seals but less effective than liquid-mounted resilient seals. The relative effectiveness ofthe various types of seals can be evaluatedby analyzing the seal factors (Ks factor and wind velocity exponent, N) contained in Table 3-4 oftheprevious chapter. These seal factors were developed on the basis of emission tests conducted on a pilot scaletank. The results ofthe emission tests are published in an American Petroleum Institute bulletin.3 To compare the relative effectiveness of the alternate seal systems, the seal factors were used with an assumed wind velocity (10 MPH) to generate directly comparable emission factors. These factors 1 which have meaning only in comparison to one another, are listed in Table 4-6 for alternative seal systems. In addition, the table contains control efficiencies (relative tothe least effective seal system) and incremental control efficiencies (relative ,to the next higher emitting seal system) calculated directly from the emission factors. From the information in Table 4-6, it is clear that vapor-mounted primary seals on external floating roof tanks are significantly less effective than liquid-mounted ormetallic shoe primary seals. Further, secondary seals provide an additional measure of control. Considering the model tankthat is used as a basis of comparison throughout this chapter, an external floating roof tank with liquid-mounted primary seals has about the same effectiveness as an internal floating roof tankwith liquid-mountedprimary seals and controlled fitting losses (see Case 10 vs. Case 5in Table 4-3). An external floating roof

4-18Table 4-6. EXTERNAL FLOATING ROOF lANK SEAL SYSTEM CONTROL EFFICIENCIES

Seal system description Vapor-mounted resilient primary seal only Vapor-mounted resilient primary seal and secondary seal Metallic shoe primary seal only Metallic shoe primary seal with a shoemounted wiper seal Liquid-mounted resilient primary seal only Metallic shoe primary seal with rim-mounted secondary seal Liquid-mounted resilient primary seal with rimmounted secondary seal Emissiogs factor N Ks (10)
239

80

38
13

11

2.0

1.8 Seal loss control b efficiency

EFR assumed baseline seal

technology 66%

84%
95%

95%
99%

99% Incremental seal loss controt

efficiency

66%

53%

66%
Negligible difference 

### 82%
Negligible difference

aFor well designed seal systems with 11average11 gaps between the seal and

the tank shell. Calculated from the Ks and Nvalues listed in Table 3-4. bRim seal loss control efficiency relative to the least effective seal

alternative. cRim seal loss control efficiency relative to the next less effective

seal alternative.

4-19tankwith liquid-mounted primary and secondary sealsyields the highest level of control achievablewith the floating roof tanktechnology. A welded internal floating roof tankwith liquid-mountedprimary and secondary seals and controlled fitting losses reduces emissions over the fixed roof tank level by about 97.3 percent (see Case 7 inTable 4-3). An external floating roof tankwith liquid-mounted primary and secondary seals exceeds this control level and achieves an estimated 99.0 percent reduction inemissions over the fixed roof tank level. The percentage reduction in emissions over the fixed roof tank casewill vary, of course, with tank characteristics (e.g., tank size, vapor pressure of material stored). The external floating roofwith liquid-mounted primary and secondary seals, however, remains the most effective floating roof tank technology from an emissions reduction standpoint. Itmust be recognized that this conclusion, as with all the conclusions in this chapter about the relative effectiveness of floating roof designs, is based on the results of emission tests conducted on a pilot scale tank (summarized in Appendix C). The testprogram was extensive in nature, but caution must be exercisedwhen extrapolating results and conclusions to full size facilities thatcan be influencedby a large number of factors thatcannot be easilycontrolled in a real**environmen~** (e.g., wind speed, temperature, etc.). 4.5 VAPOR CONTROL OR RECOVERY SYSTEMS ON FIXED ROQF TANKS Losses from fixed roof tanks can be reduced by collectingthe vapors and either recovering or oxidizing theVOC. In a typical vapor control system, vapors remain in the tank until the internal pressure reaches a preset level. Apressure switch, which senses the pressure buildup in the tank, then activates blowers to collect and transfer the vapors through a closed vent system. Aredundant blower system is provided in this service to ensure that no vapors will be released to the atmosphere in the event of a primary blower malfunction. The closed vent system ducts the vapors to a recovery oroxidizer unit. To prevent flashbacks from the control equipment, the vapors in the closed vent system from the tankmay be saturated above the upper explosive limit in a saturator. Other safetyprecautions also are exercised such

4-20as nitrogen blanketing and use of flame arrestors. The particular precautions employed vary widely depending on the design of individual systems and the operating preference of individual companies. 4.5.1 Carbon Adsorption Although there is littlecommercial operating experience for VOL applications ofcarbon adsorption, carbon adsorption for recovery of otherorganic vapors has been demonstrated, and the application of this technology toVOL recovery should not be difficult.4 The general principle of adsorption is described below to facilitate the description of a carbon adsorption unit. Carbon adsorption uses the principle of carbon's affinity for nonpolar hydrocarbons to remove VOC from the vapor phase. Activated carbon is the adsorbent; theVOC vapor thatwill be removed from the airstream is referredto as the adsorbate. The VOC vapor is adsorbed by
a physical process at the surface of the adsorbent. The proposed VOC carbon adsorption unit consists of aminimum of two carbon beds plus a regeneration system. Two or more beds are necessary to ensure that one bed will be available for use while the other is being regenerated. The carbon beds can be regenerated using either steam or vacuum (Figure 4-3). In steam regeneration, steam is circulatedthrough the bed, raising the VOC vapor pressure. The vaporized VOC is thus removed with the steam. The steam-VOC mixture is condensed, usuallyby an indirectcoolingwater stream, and routed to a separator. The VOL is then decanted and returned to storage, and the contaminated water is sentto the plantwastewater system for treatment. Cooling water, electricity, and steam are the required utilities for a steam regeneration system. The othermethod of regeneratingthe carbon, vacuum regeneration, is performed by pulling a high vacuum on the carbon bed. The VOC vapor desorbed by this process is condensed and returnedto storage. 4.5.2 Oxidation Units Thermal and catalytic oxidizers have been used successfullyto dispose ofVOC vapors in other industries. Thermal oxidation is the most directmeans ofVOC vapor disposal, uses the fewest moving parts and is the simplest to operate. The vapor mixture is injected via a

4-21**~** I N N 

### Carbon Bed

Afr-Yapor• • • • l C 

### Mixture I I I 

### I 

### I I I 

### I

# ~ Thermal

Purge Carbon Bed WaterSeal

SteamSupply or VacuumPump

Air-VaporRecycle Cooler

Water
Separator

Figure 4-3. Carbon adsorption unitusing steam regeneration. I

...

### Recoveredburnermanifold into the combustion area ofthe incinerator. Pilot burners provide the ignition source, and supplementally fueled burners add heat when required. The amount of combustion air needed is regulated by temperature-controlled dampers. Figure 4-4 shows a typical thermal oxidation unit. Flashbackprevention and burner stabilitycan be achieved by saturating the vapors with a suitable hydrocarbon to a concentration above the upper explosive limit. In addition, two water seal flame arrestors can be used to ensure that flashbacks do notpropagate from the burner to the rest of the closed vent system. As mentioned, safetypractices and equipment vary widely depending on system design and the operating preference of individual companies. Asignificantadvantage of thermal oxidizers is thatthey can dispose of awide range ofVOLs. Fuel consumption and catalyst repacement are the major cost factors in consideringthermal and catalytic oxidation. 4.5.3 RefrigeratedVent Condensers Arefrigerated vent condenser collects the VOL vapors exiting through the vents and condenses them. The vents open and close as the pressure within the tank increases and decreases. Pressurechanges
occurwhen the tank is being filled or emptied, orwhen the temperature changes. Condensers are designed to handle the maximum flow rate expected at any given time, which usually occurs during filling. Freezing of moisture or VOL is handled by a defrost-separation-recovery system. The efficiency ofvent condensers depends upon the vapor concentration and the condensing temperature. 4.5.4 Control Efficiencies ofVapor Recovery or Control Systems The carbon adsorption vapor control system is estimatedto reduce emissions from the VOL storage vessel by approximately 98 percent. This efficiency is based on a measured carbon adsorption unit efficiencyof 98 percentduring gasoline loading operations.5 The thermal oxidation vapor control system is estimatedto reduce emissions from the VOC storage vessel by approximately 98 percent. This efficiency is based on a measured thermal oxidation unit efficiencyof 98 percentduring awide variety of operations.6•7 At very low flow rates, or at low VOC inlet concentrations, somewhat less than 98 percent of the VOC vapors leaving the storage vessel may be incinerated. 4-23

## OUTLETVAPOR

PILOT 

# BURNER FUEL c _,.-**~STACK**



## MAINBURNER. 

# FUEL

# VAPOR~~ 8URNEn

## ~:**.,...~ ~o----4**  AIR DAMPER 

### WATER**SEAL-~**



### Figure 4-4. Thermal oxidation unit.4

4-24 

# . • 

## VOL VAPOR 

# SOURCE4.6 REFERENCES 1. The American Petroleum Institute (API), Draft Document, Evaporation Loss from Internal Floating Roof Tanks, API Publication 2519, Third Edition, 1982. 2. McAllister, Dr. R. Memorandum to the Volatile Organic Liquid Storage Standard Docket (No. A-80-51) regardingpermeability losses through seal materials and deck seal loss mechanisms. Dated February 1983. 3. Evaporation Loss from External Floating RoofTanks. Bulletin No. 2517. American Petroleum Institute. Washington, D.C. 1980. 4. U.S. Environmental ProtectionAgency, Evaluation of Control Technology from Benzene TransferOperations, Research Triangle Park, North Carolina, EPA-450/3-78-018, April 1978. 5. Letter from McLaughlin, Nancy D., U.S. Environmental Protection Agency to D. Ailor, TRW Inc. Comments on the benzene storage model plants package. May 3, 1979. 6. Letterand attachments from D. C. Mascone, EPA/CPB, toJ. R. Farmer, EPA. June 11, 1980. Memo concerning thermal incineratorperformance for NSPS. 7. U.S. Environmental ProtectionAgency. Organic Chemical Manufacturing, Volume 4: Combustion Control Devices. Research Triangle Park, North Carolina. Publication No. EPA-450/3-80-026. December 1980.

4-255. MODIFICATIONS AND RECONSTRUCTION
Afterthe new source performance standards (NSPS) have been promulgated in accordance with Section lll of the Clean AirAct, as amended, all affected facilities will include those facilities constructed, modified, or reconstructed after the date ofpromulgation. The NSPS could also apply to an existing facility as defined in 40 CFR 60.2. An existing facilitywould become an affected facility if itwere determined to be modified or reconstructed. This chapterdescribes the conditions under which an existing facilitywould become subject to the standards of performance. The enforcement division ofthe appropriate EPA regional officewould make the final determination as towhether a sourcewere modified or reconstructed and would therefore become an affected facility. This chapter also defines potential modifications and reconstructions. 5.1 PROVISIONS FOR MODIFICATIONS AND RECONSTRUCTION 5.1.1 Definition ofModification It is important that these provisions be understood before considering examples ofpotential modifications. Section 60.14 defines modification as follows: "Except as provided under paragraphs (e) and (f) of this section, any physical or operational change to an existing facilitywhich results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies shall be considered a modificationwithin the meaning of Section 111 of the Act. Upon modification, an existing facility shall become an affected facility for each pollutantto which a standard applies and for which there is an increase in the emission rate to the atmosphere. 11 Paragraph (e) lists certainphysical oroperational changes that
are not consideredmodifications, regardless of any changes in the emission rates. These changes are:l. Routine maintenance, repair, and replacement. 2. An increase in the production rate not requiring a capital expenditure as defined in Section 60.2. 3. An increase inthe hours of operation. 4. Use of an alternative fuel or raw material if, prior to the standard, the existing facility was designed to accommodate thatalternate fuel or raw material, except for conversion to coal requiredfor energy consideration. 5. The addition or use of any system ordevice whose primary function is the reduction of airpollutants, exceptwhen an emission control system is removed or replaced by a system considered to be less efficient. 6. The relocation orchange in ownership of an existing facility. Paragraph (b) specifies that an increase in emissions is defined in kilograms per hour and delineates the methods for determining the increase, including the use of emission factors, material balances, continuous monitoring systems, and manual emission tests. Paragraph (c) affirms that the addition of an affected facility to a stationary source does not make any other facility within that source subject to standards of performance. Paragraph (f) simply provides for superseding any conflictingprovisions. 5.1.2 Definition of Reconstruction Section 60.15 regarding reconstruction states:

11Ifan owner or operatorof an existing facility proposes to replace components, and the fixed capital cost of the new components exceeds 50 percentof the fixed capital cost that would be required to construct a comparable entirely new facility, he shall notifythe Administrator of the proposed replacements. The noticemust be postmarked 60 days (or as soon as practicable) before construction ofthe replacements is commenced

...11 The reconstruction provision of the regulation prevents an owner or operator from continuously replacing an operatingprocess, except for support structures, frames, housing, etc. in an attempt to avoid compliance with NSPS.

5-25.2 APPLICABILITY TO VOLATILE ORGANIC LIQUID STORAGE This section outlines the applicability of the modification provisions to existingplants and describes the applicability of reconstruction to this industry. This is only a general discussion of changes thatwould require an existing facility to comply with the standard. The final determinationwould be made by the appropriate EPA regional office on a case-by-case basis. 5.2.1 Modification Examples Few, ifany, modifications can be made to a storage vessel. Because replacement of frame, housings, and supporting structureswould not increase emissions from a storage vessel, such a replacementwould not constitute amodification. For the purposes of applicabilityof these CAA provisions to a storage vessel, a change in the stored liquid from a reactive VOC non-emitting liquidto a reactiveVOC emitting liquiddoes not constitute an operational change; the vessel operationwould be identical for all liquids. Achange of liquids, therefore, does not constitute amodification. 5.2.2 Reconstruction Examples The reconstruction provision ofthe regulation is relatively straightforward in that, regardless of the VOC emission rate, an existing facility may become an affected facility ifthe fixed capital costof new components exceeds 50 percentof the fixed capital cost of a comparable, entirely new facility. It is expected that only under catastrophic circumstances (e.g., total destruction of the storage vessel by fire or explosion, collapse of an external floating roof or collapse of a fixed roof) would a facility be affected by the NSPS reconstruction provision. Because associated structures (frames, housing, etc.) are not part of a tank, replacement of such a structurewould not constitute a reconstruction.

5-36. REGULATORY ALTERNATIVES AND MODEL PLANTS
This chapterdefines control options that are to be evaluated as regulatory alternatives in developing standards ofperformance for the storage ofvolatile organic liquids (VOL). The technologies that constitute the control options are applicable to specific storage vessel types. A regulatory alternative refers to apotential requirement that aparticular control technology or an array oftechnologies (acontrol option) be applied to all new, modified, and reconstructed storage vessels. In evaluatingthe economic impacts ofthe regulatory alternatives, model plants are employed. Both the regulatory alternatives and the model plants arepresented in this chapter. 6.1 REGULATORY ALTERNATIVES The methodology for selecting the Best Demonstrated Technology (BOT) for VOL storage vessels focuses on the impacts and costs of applying control options to specific tanktypes. Discussions of this methodology and the selection ofBOT are contained in thepreamble. The nationwide environmental and economic impacts of BOT, however, must be evaluated. Therefore, in orderto structure and toperform these analyses, potential control options thatmight comprise BOT have been arrayed into regulatory alternatives. Three criteriawere used to selectcontrol options for evaluation
as regulatory alternatives. They are: 1. Potential emission reduction; 2. Cost; and 3. Applicability. In Chapter 4the potential control technologies thatmay reasonably constituteBOT are identified. Table 4-2 presents thepotential emission reduction obtained by various equipment types on various emission sources,and Table 4-3 presents the emission reduction obtained over a fixed roof tank baseline. In Chapter 8, Tables 8-20 through 8-24 presentthe individual tank cost effectiveness analysis ofpotential control technologies for BOT. To analyze the impacts of regulatory alternatives, the emissions from the baseline (no additional Federal regulation) must be calculated. Therefore, Regulatory Alternative 0would require no additional equipment over currently required controls and represents theVOL baseline. All emissions and costs of subsequent regulatory alternatives are analyzed relative to the baseline data. Current regulations (the baseline) allow fixed roof storage vessels to be constructed in certain size and vapor pressure ranges. Because BOT could involve internal floating roof tanks, itwas decided to examine the impacts of requiring that fixed roof tanks be constructed as internal floating roof tanks. As the tables in Chapter 4demonstrate, building new internal floating roof tanks with vapor-mounted primary seals and typical fittings inplace of fixed roof tanks, provides a 93 percent emission reduction in the model storage vessel. (The model vessel is described in Chapter 4.) This is equivalent to the level ofcontrol requiredby the NSPS for petroleum liquid storage vessels. This equipment (internal floating roof, vapor-mounted primary seal, and uncontrolled fittings) was selected as Regulatory Alternative I. Internal floating roof tanks have four emission sources. These are: 1. Rim seal losses; 2. Fitting losses; 3. Deck seam losses; and 4. Working losses. Equipment thatwill reduce emissions from these sources is available. Therefore, potential emission reductions from these sources were examined for the development of regulatory alternatives. As demonstrated in Chapter 4, equipping internal floating roof tanks with liquid-mounted primary seals instead of vapor-mounted primary sealswould provide an additional emissions reduction by decreasing the rim seal losses. To examine the impacts of this equipment, Regulatory

6-2Alternative II would require each tankto be equippedwith an internal floating roofwith a liquid-mountedprimary seal butwould allow uncontrolled fittings. This alternativewould reduce fixed roof tank emissions by 95 percent. The next more stringent control optionwould require an emission reduction from the fittings on internal floating roof tanks. To examine the impacts of this equipment, RegulatoryAlternative III is formulated by requiring thatthe internal floating roofbe equipped with a liquid mounted primary seal and controlled fittings. This alternativewould reduce fixed roof tank emissions by about 96 percent. At this point in the development of regulatory alternatives all the emission sources of the internal floating roofwith the exception of working losses and deck seams have been controlled. There are no equipment controls forworking losses, so no regulatory alternative to examine the impacts ofcontrolling these losses could be developed. In examining controls for deck seams, the information presented inTables 8-21 and 8-22 demonstrates that it is more costeffective to require a further emission reduction from the rim seal area than from deck seams. To examine this, RegulatoryAlternative IV was formulated by requiringthat an internal floating roofbe equipped with a liquid-m9untedprimary seal and a secondary seal and with controlled fittings. This group of control technologies reduces the fixed roof tank emissions_by about 97 percent. Regulatory Alternative Vrequires that deck seam emissions be reduced through the use ofwelded decks in addition to the equipment requiredby Alternative IV. This array ofequipment reduces fixed roof tank emissions by about 97 percent. At this point in the development of regulatory alternatives all of the emissions sources from internal floating roof tanks have been reduced to the greatestpossible extent. Therefore, other control options that do not involve internal floating roofs were examined. Tanks could be equipped with vapor control recovery systems. Such a systemwould be expected to provide about 95 percentemission reduction. This system is not as efficientas the control equipment required by RegulatoryAlternatives IV and Vand is much more costly. Therefore, vapor control or recovery systems were rejected as a regulatory alternative.

6-3External floating roof tanks with liquid-mounted ormechanical shoes primary seals and a secondary seal were examined as a possible regulatory alternative. External floating roof tanks are only available in size ranges that are generally larger than the size range of most VOL tanks; 59 percent ofVOL storage vessels are projected to have diameters less than 6meters. For these reasons external floating roof tanks were not selected for evaluation as a regulatory alternative. In summary, the regulatory alternativeswould require that each vessel storing a VOL be equipped with the control technology described
as follows:

• Regulatory Alternative 0- no additional control over baseline.

• Regulatory Alternative I - an internal floating roofwith a vapor-mounted primary seal (IFRvm).

• Regulatory Alternative II

- an internal floating roofwith a liqud-mounted primary seal (IFR1m).

• Regulatory Alternative III

- an internal floating roofwith a liquid-mountedprimary seal and controlleddeck fittings (IFR1 f). m,c • Regulatory Alternative IV

- an internal floating roof with a liquid-mountedprimary seal controlleddeck fittings, and a continuous secondary seal (IFR1 f ). m,c ,ss • Regulatory AlternativeV - awelded internal floating roof with a liquid-mounted primary seal, controled deck fittings and a continuous secondary seal ( IFR1 f ). w m,c ,ss 6.2 MODEL PLANTS Model plants are developed for use in evaluating the worst-case economic impacts that the regulatory alternatives may have on affected industries. ForVOL storage, as is discussed in Chapter 7, nationwide impacts areprojected from an extrapolation of the 1977 tank volume and vapor pressure distribution as presented in Section 3.1. The model plants described in this chapter are used to evaluate potential adverse economic impacts on individual plants. (The economic impact analyses

6-4are presented in Chapter 9.) Because there is a greaterpotential adverse economic impact upon small facilities, small plants or facilities are selectedas worse-case examples. The model plants consist of a model terminal and amodel producer/consumer. These model plants are based on actual facilities that have parameters suitable for use in the economic impact analysis. 6.2.1 Model Terminal The model terminal data arepresented in Table 6-1. These data are formatted to facilitate comparison with the nationwide VOL storage terminal statistics presented in Chapter 3 (seeTable 3-3). The model has roughly as many vessels as the average terminal. However, for the most part, the vessels in the model terminal are smaller in size than the vessels in the average terminal. In general, small vessels are more expensive per unit volume of storage capacity to control than larger vessels. Also, the volume ofmaterial thatpasses through the model terminal is small. Because ofthis, the additional costs that result from the implementation of regulatory alternatives are higher on a per-volume-throughput basis. Finally, as a general rule, any small business faces higher costs ofcapital than a large corporation. It is assumed that the model terminal operates as an independent facility and would, therefore, face these higher costs ofcapital. 6.2.2 Model Producer/Consumer The model producer/consumer represents a small chemical manufacturing facility. It is assumed that a small facility is likely to be more severely affectedby the regulatory alternatives under consideration. The model producer/consumer facility consists of small vessels and produces small amounts of an inexpensive product. The lower product priceminimizes potential recovery credits associatedwith the installation ofcontrols. The model producer/consumer data are presented inTable 6-2. The model facility produces fewer than 4.54x 106 kilograms peryear (107 pounds peryear) of aproduct that sells for $0.35 per kilogram ($0.16 per pound). Both theproduction capacity and product price for the model producer/consumer are smallerthan the average capacity and price for organic chemicals estimated from the Organic Chemical Producters Data Base (see Chapter 9). 6-5Table 6-1. MODEL TERMINAL

Terminal capacity

- 14,000m 3**(~3.6** x 106 gal) Number of tanks

- 48 Volume of smallest tank

- 3.8m 3**(~1,000** gal) Average tank volume

- 300 m 3**(~80** 

### x 103 gal) Volume of largesttank

- 2,300 m 3**(~600** 

### x 103 gal) Average number of annual turnovers pertank

- 2.9 Terminal throughput

- 39,000 m 3**(~10,000** x 103 gal)

Table 6-2. MODEL PRODUCER/CONSUMER

Plantproduction capacity

- <4.5 

### x106 kg/year (<107 lb/yr) Plant tankcapacity

- 2,000 m 3**(~530** 

### x 103 gal) Number of tanks

- 11 Average tankvolume

- 190 m 3**(~50** 

### x 103 gal) Volume of largesttank

- 330 m 3**(~88** 

### x 103 gal) Volume of smallest tank

- 14m3**(~4,000** gal)

6-67. ENVIRONMENTAL IMPACTS
7.1 INTRODUCTION This chapterdiscusses the fifth-year environmental impacts of each regulatory alternativepresented in Chapter 6. The fifth-year impacts
are the impacts thatwould be incurredby the new, modified, and reconstructed facilities constructedduring the five years following implementation ofthe regulatory alternatives. In these analyses, a base year of 1983 is assumed (i.e., the regulatory alternativeswould be in force starting in 1983). The nationwide impacts that are evaluated include:
• airpollution impacts;
• water pollution impacts;
• energy impacts; and • other environmental concerns. The nationwide impacts are developed from the number of affected facilities (i.e., VOL storage vessels) projected to be constructed during the fiveyears following the baseline date. Chapter 9explains the derivation of a bivariate distribution, by tank size and vapor pressure ofthe VOL stored, of the numbers of affected facilities that are projectedto be constructedbetween 1983 and 1988. The potential environmental impacts ofthe regulatory alternatives are estimatedwith this bivariate distribution of affected facilities and the knowledge of the baseline control levels (discussed in Section 3.3) thatwould result in the absence ofperformance standards. 7.2 AIR POLLUTION IMPACTS Adoption of any of the regulatory alternatives will reduce VOC emissions in theyears following the implementation. The magnitudeof the emissions reductions to be achieved by the regulatory alternatives is estimatedbased on the estimated five-year total number of affected new and replacement tanks to be constructed, the tank size vapor pressure percentage distribution discussed in Chapter 9, and the equations for predictingemissions from the various VOL storage vessel equipment types (presented in Section 3.2). An average emission rate for tanks in each tank size/vaporpressure interval in the distribution is calculatedby using the average capacity of the interval, the average vapor pressure ofthe interval, and the average number of tank turnovers for the tank size range. The emissions pertank in the interval are then multiplied by the number of tanks in the tank size/vaporpressure interval. The total emissions rate for a given regulatory alternative is determined by summing across the tank size/vaporpressure intervals. This procedure is repeated for the baseline control level and each regulatory alternative. Emissions reductions are determined by subtracting the baseline emissions rate from the emissions rate for each regulatory alternative. Table 7-1 and 7-2 listthe emission rates and emission reductions, respectively, associatedwith each regulatory alternative. The emission values in the tables are in megagrams peryear, reflectingthe annual emissions oremission reduction from the affected facilities that are projectedto be constructed during the fiveyears following the baseline date (1983-1988). Each table provides estimates for ten alternate tank size/vaporpressure cutoff levels. For example, row two ofTable 7-1 provides emission estimates assuming that the minimum tank size affected by the regulation is 75 m 3 (20,000 gallons) and the minimum vapor pressure affectedby the regulation is 3.5 kPa (0.5 psia). Aprojected 3,749 tanks will be constructed in the fiveyears following 1983 that are above these cutoff conditions and, therefore, would be affected by an NSPS that implemented cutoffs atthese levels. The tanks regulated at this cutoffwill emit 10,845Mg/yr under the baseline control level, 2,502 Mg/yr under Regulatory Alternative I and so forth for the remaining regulatory alternatives. Referring toTable 7-2 for this same cutoff, Regulatory Alternative I will effecta 8,343 Mg/yr reduction inVOC emissions; Regulatory Alternative II will effecta 8,780 Mg/yr reduction in VOC emissions, and so forth for the remaining regulatory alternatives.

7-2-.....J I w Table 7-1. FIFTH-YEAR EMISSIONS RESULTING FROM THE REGULATORY ALTERNATIVES

Cutoff Leve1 Tank Size/Vapor Pressure Emissions for Each Regulatory Alternative (Mg/yr) Number of

m

3/kPa 1000 gal/psia Affected Baselineb Facilitiesa Ic lid IIIe IVf vg
0/0 0/0 16,086 22,171 4,272 3,659 2,540 2,308 2,047 75/3.5 20/0.5 3,748 10,845 2,502 2,065 1,498 1,333 1,110 75/6.9 20/1.0 2,686 7,009 2,273 1,871 1,357 1,205 997 75/10.3 20/1.5 2,027 2.960 2,032 1,670 1,211 1,074 885 114/3.5 30/0.5 3,167 9,685 2,245 1,841 1,354 1,201 985 114/6.9 30/1.0 2,287 5,993 2,046 1,673 1,230 1,089 887 114/10.3 30/1.5 1,726 2,072 1,832 1,495 1,099 972 789 151/3.5 40/0.5 2,945 9,240 2,148 1,757 1,300 1,152 939 151/6.9 40/1.0 2,138 5,610 1,961 1,601 1,183 1,047 848 151/10.3 40/1.5 1,628 1,762 1,762 1,436 1,060 937 757

aThe number of new, modified, and reconstructed storage vessels thatmeet the and, therefore, would be affected by the regulatory alternatives. respective cutoffcriteria bbiFR and fixed roof tankmixed baseline (see Section 3.3). vm c IFR d b vm biFRlm e IFR f b lm,cf IFR b lm,cf,ss g IFR w lm,cf,ss....... I .p. Table 7-2. FIFTH-YEAR EMISSIONS REDUCTIONS RESULTING FROM THE REGULATORY ALTERNATIVES

Cutoff Level Emissions Reduction Obtained by Each Regulatory Alternative Tank Size/Vapor Pressure (Mg/yr) Number of

m

3/kPa 1000 gal/psia Affected Facilitiesa Baselineb Ic lid Ille IVf vg
0/0 0/0 16,086 0 17,899 18,512 19,631 19,863 20,124 75/3.5 20/0.5 3,748 0 8,343 8,780 9,347 9,512 9,735 75/6.9 20/1.0 2,686 0 4,736 5,138 5,652 5,804 6,012 75/10.3 20/1.5 2,027 0 928 1,290 1,749 1,886 2,075 114/3.5 30/0.5 3,167 0 7,440 7,844 8,331 8,484 8,700 114/6.9 30/1.0 2,287 0 3,947 4,320 4,763 4,904 5,106 114/10.3 30/1.5 1,726 0 240 577 973 1,100 1,283 151/3.5 40/0.5 2,945 0 7,092 7,483 7,940 8,088 8,301 151/6.9 40/1.0 2,138 0 3,649 4,009 4,427 4,563 4,762 151/10.3 40/1.5 1,628 0 0 326 702 825 1,005

a The number of new, modified, and reconstructed storage vessels thatmeet the respective cutoff criteria and, therefore, would be affectedby the regulatory alternatives. bbiFRvm and fixed roof tankmixed baseline (see Section 3.3). c IFR d b vm biFRlm e IFR f b lm,cf IFR b lm,cf,ss g IFR w lm,cf,ss7.3 WATER QUALITY AND SOLID WASTE IMPACTS The control technologies selected as regulatory alternatives do not generatewastewater or solidwaste during their operation as control devices. During tankturnarounds and periods when tanks are not in service, however, wastewater and solidwaste may be generated. Inspection and maintenance operations can generate both wastewater and liquid/solid wastes that require treatment or special disposal techniques. Most major inspections and/or repairs require thatthe vessel be cleaned and degassed. The concern is thatthe environment inside the tankbe free ofpotential explosive and toxic hazards priorto introducingpersonnel for inspections or repairs. Cleaning and degassing generally involves the following steps1 1. Removing residual productwith a vacuum truck; 2. Lossening rust scale, ifpresent, with high pressurewater and removing debris; 3. Washing the tankwith high pressurewater and detergents; and 4. Rinsing the tankwith water. The residual product constitutes awaste that, depending on the nature of the VOL stored in the tank, may have to be disposed ofwith conventional solidwaste disposal techniques or as a hazardous waste in compliance with the requirements of the Resource Conservation and Recovery Act (RCRA). The washwater, again depending on the nature ofthe VOL stored, constitutes wastewater for treatment in conventional wastewater treatment systems, or sometimes hazardous waste for disposal in compliance with RCRA. Another degassing methodology involves the application of a sustained forced draftto the interiorof the vessel for a sufficient period to evaporate all residual product. This technique generally involves no wastewater or hazardous solidwaste disposal. However, air emissions do result. For the most part, tank degassing and the resultantwaste impacts
occur irrespective ofthe regulatory alternatives. On the average, tanks are cleaned, degassed and inspected on about a 10-yearcycle.

7-57.4 ENERGY IMPACT The control technologies selected for the regulatory alternatives do not increase thepower or other energy requirements ofthe VOL storage vessels. Therefore, no energy impacts are attributable to the regulatory alternatives. 7.5 OTHER ENVIRONMENTAL CONCERNS 7.5.1 Irreversible and Irretrievable Commitment of Resources The regulatory alternativeswould notpreclude the development of future control options nor would they curtail any beneficial use ofthe environment. No long-term environmental losses would result from the regulatory alternatives. 7.5.2 Environmental Impact ofDelayed Standards The only environmental impact associatedwith a delay in proposing and promulgating the standardwould be an increase in VOC emissions from storage tanks attributable to the construction of new tanks.

7-67.6 REFERENCES 1. Memorandum from J. L. Shumaker toW. Moody ofTRW Environmental Division regarding Retrofit IRF and Degassing Costs, December 21, 1982.

7-78. COST ANALYSIS
This chapter summarizes the cost analysis data. Installed capital costs are presented in Section 8.1 for the types of equipment specified in the regulatory alternatives outlined in Chapter 6. For each type of equipment, costestimates are presented for the range oftank sizes commonly employed in the storage of volatile organic liquids (VOL). Cost data also arepresented for several control alternatives (external floating roof tanks and vapor control equipment) that are considered in Chapter 6but that are not selected as regulatory alternatives. In addition to the cost estimates for individual tank size/control alternative combinations, the aggregate cost impacts from applying the regulatory alternatives to the model plants are estimated. Sections 8.1 through 8.4 presentestimates of the capital costs, annualized costs, and cost effectiveness for model terminal and model producer/consumer facilities. Model plants are discussed in detail inChapter 6. All costs are calculated as average costs over the costofthe baseline control level presented in Section 3.3. For the purposes of the cost analysis presented in this chapter, all tanks with a capacity greaterthan orequal to 75 cubic meters (20,000 gallons) and storing a liquidwith atrue vapor pressure**g~eater** than or equal to 3.5 kilopascals (0.5psia) are assumed to be affected by the regulatory alternatives. Because the model terminal and model producer/consumer facilities will not be used to evaluate the effectiveness ofthe regulatory alternatives in controlling emissions, no emission information is presented in this chapter. The cost analysis follows aprescribed approach. Capital costs, which representthe initial investment for control equipment and installation, are estimated based on vendor quotes and EPA documents. From these estimates, correlations and factors have been developed to approximate capital costs for the range of tank sizes commonly used in the industry. The capital cost is annualized by applying a capital recovery charge, which is based on an estimatedequipment lifetime and the interest rate on the capital, and by adding costs for taxes andinsurance. The total annualized cost, excluding product recovery credits, attributable to each regulatory alternative is estimatedby adding operating costs to the annualized capital cost. The total annualized cost, includingproduct recovery credits, is estimatedby subtracting the value ofthe recovered product from the annualized costs. Cost effectiveness is the total annualized cost divided by the emission reductions obtained by applying each regulatory alternative. 8.1 CAPITAL COSTS The capital costs for the regulatory alternatives are based on cost estimates obtained from industryvendors and EPA reports.1•2•3 Vendors were contacted and asked to provide estimates of the costs to construct fixed roof tanks, external floating roof tanks, and secondary seals, as well as the costto install internal floating roofs in fixed roof tanks. (See Tables 8-1, 8-2, 8-3, and 8-4.) Internal floating roof cost data
are based on a fourth-quarter 1982 survey ofequipment manufacturer•s prices. Other costestimates are based on data collected in a similar
manner in late 1979 and early 1980. These estimates have been scaled based on Chemical Engineering general cost indexes4 to reflect secondquarter 1982 dollar estimates. All capital costs are at leastequivalent to study estimates C:3o percent accuracy). The capital costof an internal floating roof depends mainly upon the liquid surface area. Therefore, the capital costs for these devices
are given only as a function of the tank diameter, which is directly related to surface area. The cost of a fixed roof tank, however, is a function ofthe volume capacityofthe tank*. Tank and roof costs

An estimating technique has been developed to relate tankvolume to tank height and diameter and thereby aidthe comparison of fixed roof tankcosts to floating roof costs. The formula is based on the fact that tank heights generally increase in about 2.62 meter (8 foot) increments (due to the width of sheet steel) and that for other than small tanks, the height to diameter ratio rarely exceeds unity in industrypractice. The formula, which has been used in the development ofthe capital costtables, is as follows: Tank capacity (V) Tank height (H) Tank diameter 

### (D)

in cubic meters in meters in meters 0-45 2.62**(4V)~** 46-91 5.25 0

## = 92-307 7.87 rrH 308-1,136 10.5 1,137-11,590 13.1 >11,590 15.7 8-2Tank volume, (m3)

75 150 250 500 1,000 5,000 10,000 Table 8-1. ESTIMATED**INSTALLED C~PITAL**  COST OF AFIXED ROOF TANK ' (second-quarter 1982 dollars)

Tank diameter, (m)
4.3 4.9 6.4 7.8 11.0 22.0 31.2 Tagkb cost ' ($)
13,300 19,900 26,700 39,800 59,400 150,400 224,300
aEstimated from the equation: Cost ($1000)

## =0.883

## v 0

·577; where, V

## =tankvolume in cubic meters; with correlation coefficient r2 >0.99. This equationyields-first-quarter 1980 costestimates thatwere**scale~** by a factor of 1.25 to reflect second-quarter 1982 prices. bExcluding the costofthe foundation, land, etc. that are

not affected by the regulatory alternatives.

8-3co I +=- Tank diameter, (m)

5 10 15 20 25 30 Table 8-2. ESTIMATED INSTALLED CAPITAL COST OF ANONCONTACT INTERNAL FLOATING ROOF3 (fourth-quarter 1982 dollars)

Costwith Costwith liquid-mounted liquid-mounted primary seal, Basic Costwith primary seal controlleddeck roof liquid-mount

## 0 d and cantroll**e~** fittings and d costa primary seal deck fittings secondary seal

($) ($) ($) ($)
6,280 6,320 6,320 7,620 11,600 11,680 11,680 14,300 17,000 17,120 17,120 21,000 22,300 22,460 22,460 27,600 27,700 27,900 27,900 34,400 33,000 33,250 33,250 41,000 aEstimated from the equation: Cost ($)

## =1,069 D+939; where, D

## =tank diameter in meters; with the

correlation coefficient r2 = 0.889. This correlation generates installed costestimates for an aluminum noncontact internal floating roofwith a vapor mounted wiper type seal. bThe additional costofthe

## liquid-mounte~ primary seal over an elastomeric

## ~iper seal is estimated to

be $2.60 per linearmeter of circumference based on quotes from one vendor. cControlled deck fittings include a gasketed, boltedcover, access hatch; a gasketed, boltedcover

automatic gauge floatwell; pipe columns with a flexible fabric sleeve seals; a gasketed sliding cover for the ladderwell; a sample well with a split fabric seal and 10% open area; and aweighted, mechanical actuation, gasketed, vacuum breaker. Based on vendor estimates, the additional cost of controlled fittings over the costofthe normally installed deck fittings is negligible. dCost of secondary seal is estimatedto be $85 per

### l~near meter of tank circumference. This is the

average price of 13 seals from 8different vendors.Table 8-3. ESTIMATED INSTALLED COST OF AWELDED**~ONTACT** INTERNAL FLOATING ROOF WITH SECONDARY SEALS (fourth-quarter 1982 dollars)

Tank

## ~~~~a diameter (m) ($)

5 15,900 10 30,000 15 44,000 20 58,100 25 72,100 30 86,100 aThe basic costof the roof and primary seal is estimated from the

equation: cost ($1000)

## =1.91 + 2.54D; where Dequals the tankdiameter in meters with the correlation coefficient r2

## =0.883. The additional costof a secondary seal is estimatedbased on the factor, $85 per linear meter ofcircumference. The secondary seal cost is the average price of 13 seals from 8different vendors.

8-5Table 8-4. ESTIMATED INSTALLED CAPITAL COST OF EXTERNAL FLOATING ROOF TANKS WITH SECONDARY SEALS5•6•7 (second-quarter 1982 dollars)

Tank Tank**Tan~** b volume, diameter, cost '

(m3) (m) ($)
75 4.3 22,100 150 4.9 32,300 250 6.4 42,300 500 7.8 61,900 1,000 11.0 89,900 5,000 22.0 218,000 10,000 31.2 319,000
aCost oftank estimated from the equation: Cost ($1000)

## =1.54

### v 0

·552; where, V

## =tank volume in cubic meters; with the correlation coefficient r2

## =0.98. This equationyields first-quarter 1980 cost estimates tijat were scaledby a 1.25 factor to reflect second-quarter 1982 dollars. bThe additional cost of the

### secondar~ seal is estimatedto be $85 per

linearmeter of roof circumference.



### 8-6are not relatedto the vapor pressure of the material stored in the range of products potentially affectedby aVOL storage regulation (i.e.**<~11** psia). For each type of equipment (i.e., internal floating roof, fixed rooftank, etc.) an equation ofpredicted capital costswas derived from the available data (vendor quotes). These equations are used in all subsequent cost analyses. Table 8-1presents costs for fixed roof tanks. These are installed capital costs including the cost ofmaterials, transportation, labor, testing, and othervendor-incurred costs associatedwith erection ofthe tank. The estimates assume that a suitable location and foundation are available. Examples of the costs that are excluded include the costof land, providing utilities to the site, and a concrete foundation. Such costs are fixed and constant irrespective ofpossible regulations for VOL storage vessels. Since they do not affectthe regulatory decisions, they are not considered in the cost analysis. Table 8-2presents installedcostestimates for internal floating roofs with successivelymore stringent (i.e. lower emitting ) alternative equipment. As discussed in Chapter 4, noncontact roofs are constructed ofprimarilyaluminum materials. The basic roof casted in the table is equipped with a single, vapor-mounted, wiper type, deck perimeter seal (primary seal). The next casted alternative is a liquid-mounted, resilient tube, primary seal inplace of the vapor-mounted wiper type seal. The third alternative includes the liquid-mounted primary seal, but adds

11controls 11 to certain deck fittings. Deck fittings and the 11controls11 for deck fittings are described in Chapter 3and Chapter4, respectively. Briefly, 11controls11 for deck fittings are gaskets for covers, sleeve seals for support columns and the use of a sample well with a split fabric seal inplace of a slotted sample pipe. The installation and use of 11controlled11 fittings has a negligible effecton the costof the floating roof. The small additional costofgaskets and seals**C~$200)** is offsetby the savings from installing a sample well instead of a slotted sample pipe ($100 to $300).8 Also, 11controlled11 fittings are not expected to significantly increase operatingcosts of internal floating roofs. The final alternative casted inTable 8-2 combines all

8-7thepreceding alternatives. It includes a liquid-mounted primary seal,

11Controlled11 deck fittings and awiper type secondary deck perimeter seal (secondary seal). Table 8-3 presents the estimated installedcost ofwelded contact internal floating roofs (steel pan) with secondary seals. The primary seal included in these costestimates is ametallic shoe seal, a liquidmounted resilienttube seal, or awiper type seal. Vendor quotes for steel pan roofs with each of these seal types were correlated to produce an 11average11 or 11typical 11 roof cost function (see Table 8-3). The roof is constructedof steel. Larger roof sizes include auxiliarypontoon flotation. Table 8-4presents estimates of the installed capital cost of external floating roof tanks. It is important to realize thatthese costs include the tank shell in addition to the roof. The cost of control over the fixed roof tank baseline costs is the difference between the external floating roof costs (Table 8-4) and the fixed roof tank cost (Table 8-1) for equivalent tank sizes. The tanks costed in Table 8-4 include primary and secondary seal costs. The primary seals are either liquid-mounted or vapor-mounted resilienttube seals. For external floating roof tanks, the location ofthe primary seal (i.e. vapor- or liquid-mounted) does not significantly affect the roof cost. The incremental cost of the control alternatives can be approximated from the estimates contained in Tables 8-1 through 8-4. The comparison ofcontrol qlternative costs, however, must be made for tanks of equivalent diameter orvolume. Care must also be taken to ensure that comparisons are made between equivalenttypes of equipment, i.e., roof cost versus roof cost ortankcostversus tank cost. Tables 8-5 through 8-13 present the costs of applying Regulatory Alternatives I-V, the external floating roof control options, and the vapor control alternatives to the model terminal and the model producer/consumer facilities. The model plants are discussed in Chapter 6 and described in Appendix D. Although the model plants contain a number of tanks (terminal, 48 tanks; producer/consumer, 11 tanks), the regulatory alternatives affect only a fraction of the respective tankpopulations. The majority of tanks are exempted on the basis of size and vapor

8-8Table 8-5. COST OF REGULATORY ALTERNATIVE I* (fourth-quarter 1982 dollars)

Cost parameters Capital cost Annualized capital charges Annual taxes, insurance and administration Operating costs Maintenance Inspection Total annualized costwithout productrecovery credits Total annualized costwith product recovery credits @$460/Mg Cost effectiveness in dollars per megagram VOC emssions reduction Model terminal

56,000

6,580 2,240

2,800 560
12,180

7,530
744 Model producer/ consumer

15,800

1,860
630

790 160 3,440

2,090
714

*Noncontact internal floating roofwith a vapor-mounted primary seal.

8-9Table 8-6. COST OF REGULATORY ALTERNATIVE II* (fourth-quarter 1982 dollars)

Cost parameters Capital cost Annualized capital charges Annual taxes, insurance and administration Operating costs Maintenance Inspection Total annualized costwithout product recovery credits Total annualized costwith product recovery credits @$460/Mg Cost effectiveness in dollars per megagram ofVOC emissions reduction Model terminal 56,600

6,670 2,260

2,830 570 12,330

7,480
710 Model producer/ consumer

16,000

1,890
640

800 160 3,490

1,610
395
*Noncontact internal floating roofwith a liquid-mounted primary seal.

8-10Table 8-7. COST OF REGULATORY ALTERNATIVE III* (fourth-quarter 1982 dollars)

Cost parameters Capital cost Annualized capital charges Annual taxes, insurance and administration Operating costs Maintenance Inspection Total annualized costwithout product recovery credits Total annualized costwith product recovery credits @$460/Mg Cost effectiveness in dollars per megagram ofVOC emissions reduction Model terminal

56,600

6,670 2,260

2,830 570 12,330

7,190
644 Model producer/ consumer 16,000

1,890
640

800 160 3,490

533

87

*Noncontact internal floating roofwith liquid-mounted primary seal and

gasketed deck fittings.

8-11Table 8-8. COST OF REGULATORY ALTERNATIVE IV* (fourth-quarter 1982 dollars)

Cost parameters Capital cost Annualized capital charges Annual taxes, insurance and administration Operating costs Maintenance Inspection Total annualized costwithout product recovery credits Total annualized costwith product recovery credits @$460/Mg Cost effectiveness in dollars per megagram ofVOC emissions reduction Model termina1

71,830

9,130 2,870

3,590 720 16,310

11,010
957 Model producer/ consumer 23,210

3,050
930

1,160 230 5,370

2,230
326

*Noncontact internal floating roofwith liquid-mounted primary seal,

secondary seal and gasketed deck fittings.

8-12Table 8-9. COST OF REGULATORY ALTERNATIVE V* (fourth-quarter 1982 dollars)

Cost parameters Capital cost Annualized capital charges Annual taxes, insurance and administration Operating costs Maintenance Inspection Total annualized costwithout product recovery credits Total annualized costwith product recovery credits @$460/Mg Cost effectiveness in dollars per megagram ofVOC emissions reductin Model terminal
184,800

22,400

7,390

9,240 1,850
40,880

35,500

3,040 Model producer/ consumer 90,800 11,000

3,630

4,540 910
20,080

16'770

2,330

*Welded contact internal floating roofwith liquid-mountedprimary seal,

secondary seal and gasketed deck fittings.

8-13Table 8-10. COST OF EXTERNAL FLOATING ROOF TANKS WITH PRIMARY SEAL AND SECONDARY SEAL

(second-quarter 1982 dollars)

Cost parameters Capital cost Annualized capital charges Annual taxes, insurance and administration Operating costs Maintenance Inspection Total annualized costwithout product recovery credits Total annualized costwith product recovery credits @$460/Mg Cost effectiveness in dollars per megagram ofVOC emissions reduction

aCosts above the baseline control cost. Model terminal 150,920a

18,420

6,040

7,550 1,500 33,510

b

b Model producer/ consumer 47,210a

5,900 1,890

2,360 470 10,620

b

b

bExternal floating roofs do not reduce emissions beyond the baseline level.

Therefore, no emissions reduction credits exist. Emissions rates for both the model terminal and the model producer/consumer are expected to increase. Consequently, cost effectiveness for the alternative is undefined.

8-14Table 8-11. COST OF EXTERNAL FLOATING ROOF TANKS WITH LIQUID-MOUNTED PRIMARY SEAL AND SECONDARY SEAL (second-quarter 1982 dollars)

Model Cost parameters terminal Capital cost 150,920* Annualized capital charges 18,420 Annual taxes, insurance and administration 6,040 Operating costs Maintenance 7,550 Inspection 1,500 Total annualized costwithout product recovery credits 33,510 Total annualized costwith product recovery credits @$460/Mg 29,350 Cost effectiveness in dollars per ton ofVOC emissions reduction 3,250

*Costs above the baseline control cost.

8-15 Model producer/ consumer

47,210*

5,900 1,890

2,360 470 10,620

10,400 21,990Table 8-12. COST OF VAPOR CONTROL BY INCINERATION TECHNIQUES (second-quarter 1982 dollars)

Cost parameters Capital cost Annualized capital charges Annual taxes, insurance and administration Operating costs Maintenance Labor Energy Total annualized costwithout product recovery credits Total annualized costwith product recovery credits @$460/Mg Cost effectiveness in dollars per megagram ofVOC emissions reduction Model terminal

631,000a,b 114,000 4,100

31,600 27,200

4,900 181,800

c 15,500 Model producer/ consumer 631,000a,b 114,000 4,100

31,600 27,200

4,900 181,800

c 20,700
aCost estimates assume one incineration unit and saturatorper facility

(see Chapter 4). bBased on a first-quarter

### 19~0 estimate scaledby a 1.25 factor to reflect

second-quarter 1982 prices. cBecause there are no recovery credits, the cost is equal to the total

annualized costwithout product recovery credits.

8-16Table 8-13. COST OF VAPOR RECOVERY BY CARBON ADSORPTION TECHNIQUES (second-quarter 1982 dollars)

Cost parameters Capital cost Annualized capital charges Annual taxes, insurance and Administration Operating costs Maintenance Labor Energy Total annualized costwithout product recovery credits Total annualized costwith product recovery credits @$460/Mg Cost effectiveness in dollars per megagrams ofVOC emissions reduction Model terminal

631 oooa,b ' 114,000 4,100

31,600 45,000 60,000 255,000

249,600

21,280 Model producer/ consumer
631 oooa,b ' 114,000 4,100

31,600 45,000 60,000 255,000

250,970

28,650
aAssumes one unitper facility sized for 0.142 standard3m 3/s of saturated vapor diluted to 25% LEL for a total of 8.0 standardm/s. bBased on a first-quarter 1980 estim4te scaledby a factor of 1.25 to

reflect second-quarter 1982 prices.

8-17pressure. Four tanks (2 fixed roof and 2floating roof tanks) are affected by the regulatory alternatives in the model producer/consumer plants. The model terminal has five affectedtanks (4 fixed roof and 1floating roof tank). These tanks can be identifiedby inspection of Appendix Dwith an understanding of the baseline control level described in Section 3.3. The base capital costof all storage vessels atthe model terminal is 1.07million dollars, and the base capital costof storage vessels atthe model producer/consumerplant is 0.25 million dollars. As mentioned previously, these costs do not include foundation costs, land costs or othercosts that are not affected by the regulatory alternatives. The cost of a vapor control system is a function ofthe vapor flow rate to the system. This flow rate is controlled by the rate atwhich liquids arepumped into the tank and not by tank diameter orvolume. No cost tables are presented for vapor recovery. The capital costs of installinga carbon adsorption orthermal oxidation vapor control system to reduce volatile organic compound (VOC) emissions from the model plants are estimated from information supplied by EPA reports.1•2 (See Tables 8-12 and 8-13.) It is assumed that each system is sized for a stream of saturated vapor at0.142 standard cubic meters per second (0.142 standardm 3/s). Because of the large size of the vapor control systems, it is assumed that only one system is needed for each model facility. However, because ofproduct compatibility oroperatingproblems, actual facilities might need more than one unit; therefore, the cost estimates are almost certainly low. 8.2 ANNUALIZED CAPITAL COSTS The capital cost for each regulatory alternative is annualized assuming the useful equipment lifetimes listed in Table 8-14. In estimating the annualized capital cost for the equipment, it is assumed the capital is borrowed at a 10 percent real interest rate. Based on the estimated equipment lifetimes and the assumed interest rate, annualized capital costs are estimatedwith the capital recovery factor method.

8-18Table 8-14. LIFETIMES OF CONTROL EQUIPMENT

Device Lifetime (yrs)
Tank and floating roof Secondary seals Carbon adsorber Thermal oxidizer 20 10 10 10 aCapital recovery factor determined by the equation: CRF =i(1 + i)n/(1 + i)n

- 1; where i =the annual interest rate and n=the equipment lifetime. Capital**Recove~y** Factor
0.11746 0.16275 0.16275 0.16275

Table 8-15. COST ANNUALIZING ASSUMPTIONS

Item Charge
Tax, insurance, and administration 4% of capital cost Maintenance 5% ofcapital cost Inspection 1% of capital cost Interest rate 10% Labor $16/hr Natural gas $3.00/109J Electricity $0.04/kWh Energy otherthan natural gas orelectricity $2.50/109J8.3 ANNUALIZED COSTS The annualized costwithoutproduct recovery credits is calculated by adding the annualized capital charges to the costs for taxes, insurance and administration (4 percent of the capital costs) and the operating costs. Operating costs include the yearlymaintenance charge of 5percent ofthe capital cost, and an inspection charge of 1percent of the capital cost. (See summary inTable 8-15.) The factors used to estimate the cost of taxes and administration (4 percent) and maintenance costs (5 percent) are based on operating experience ofthe Hydroscience Company.9 In respect to vapor control systems, utility expenses are estimated using electricitycosts of$0.04per kilowatt-hour, natural gas costs of $3.00 per 109joules, and other energy costs of $2.50 per 109joules. Emission monitoring costs were included in the annualized estimates for a flame ionization hydrocarbon detector at $4,500, for a flow measurement device at $2,500, and for bottled gas to operate the flame ionization detector at $2,625 peryear. These monitoring costswere annualized for
a charge of $3,750 peryear. Additionally, it is assumed that 500 hours ofoperating labor at $16 per hour will be required to operate and maintain the emission monitoring system. The total annualized costwith product recovery credits is calculated by accounting for the value of any recovered product. The recovered productwas castedbased on aweighted average product value of roughly 100 synthetic organic chemicals. Aprice of $460/megagram represents the weighted average product value (1978 average scaledto 1982 dollars with a factor of 1.55 based on the Chemical Engineering Journal Industrial Chemical Producer•s Price Index). The amount of recovered productwas assumed equal to the emissions difference between the baseline emissions and each regulatory alternative, except for thermal oxidation. Because the thermal oxidation unit destroys VOC vapors, no recovery credits were assumed. 8.4 COST EFFECTIVENESS The cost effectiveness of a regulatory alternative is defined as the cost permetric ton ofVOC removed. The average productprice of

8-20$460/megagram was used in these calculations to quantify credits for recovered product thatwould be lost under the baseline conditions. The costeffectiveness values presented in Table 8-5 through 8-13 are in units ofdollars permegagram ofVOC determined by dividingthe total annualized costby the emission reduction achieved by a regulatory alternative orcontrol technique. 8.5 COST OF OTHER FEDERAL REGULATIONS There are awide variety of Federal statutes that affectthe manufacture and storage of volatile organic liquids. Table 8-16 lists 12 Federal statutes that control human and environmental exposure to toxic chemicals.10 The same statutes will also apply to volatile organic liquids (VOLs). Regulatory action required by these statutes controls the chemicals in products and wastes, ambient and occupational environments, chemical identification, chemical sources, and the handling, discharge, and ultimate disposal ofchemicals. These regulations will cause an outlayof capital by the chemical manufacturing industry. Total spending for pollution control by the chemical industry in 1979 was expected to be $639 million.11 Costs to specific segments ofthe industry, however,
are difficult to distinguish on the basis ofpublished data. The costs of the proposed regulations are difficultto estimate because of the lack of available information regarding the content of the final regulations. This section summarizes the available data on costs imposed upon the chemical manufacturing and storage industries by Federal regulations and discusses the impact ofthese costs on their operations. Regulatory statutes that apply to manufacturers and users of VOLs are listed inTable 8-17. This list includes the statutes from Table 8-16, in addition to several others, and brieflydescribes the provisions, requirements, and regulatory concerns of each statute.12 The last column lists and describes the approximate costs of the statutes. In some cases, this column is blankbecause relevant costdata could not be found. Most of the costs available are for the general chemical industry and are not subdivided into costs for handlers ofVOLs. However, Table 8-17 does show thatthese costs are considerable. Other indirect costs, such as the 11abandonment11 of new chemicals, and decreases in

8-21Table 8-16. FEDERAL LAWS REGULATING TOXIC CHEMICALS

Title
Toxic Substance Control Act of 1976 Food, Drug, and Cosmetic Act, as amended in 1976 Occupational Safety and Health Act of 1980 Consumer Product SafetyAct of 1970 Marine Protection, Research and Sanctuaries Act of 1972 Federal PesticideAct of 1978 Clean Air Act, as amended in 1977 Federal Water Pollution Control Act, amended as Clean Water Act of 1977 Safe DrinkingWater Act of 1974 Resource Conservation and Recovery Act of 1976 Hazardous Materials TransportationAct of 1970 National Environmental Policy Act of 1969

8-22 Abbreviation Public Law No.
TSCA 94-469 FDCA 94-295
OSHA 91-596 CPSA 92-573 Ocean Dumping 92-532
FPA 95-396 CAA 95-95 FWPCA 92-500 CWA 95-217 SDWA 93-523 RCRA 94-580 HMTA 91-458 NEPA 91-190

### Table 8-17. STATUTES THAT MAY BE APPLICABLE TO THE MANUFACTURE 

### AND STORAGE OF VOLATILE ORGANIC LIQUIDS

Statute
Toxic Substances Control Act

Food, Drug, and Cosmetic Act Occupational, Safety, and

Health Act

Consumer Product SafetyAct Marine Protection, Research and

SanctuariesAct Federal PesticideAct

Clean Air Act and Amendments Applicableprovision, regulation, or requirement of statute

• Premanufacture notification • Labelling, recordkeeping • Reporting requirements • Toxicity testing

• Consumer use ofchemicals

• Walking-working surface standards • Means ofegress standards • Occupational health and environmental control standards • Hazardous material standards • Personal protectiveequipment standards • General environmental control standards • Medical and first aid standards • Fireprotection standards • Compressed gas and compressed air equipment • Welding, brazing, and cutting standards

• Consumer use of chemicals

• Ocean dumping permits • Recordkeeping and reporting

• Consumer use ofchemicals

• State Implementation Plans • Nationa: Emission Standards For Hazardous Air Pollutants • New sourceperformance standards: Air oxidation Volatileorganic liquidstorage • PSD constructionpermits • Nonattainment constructionpermits 

### (continued}

8-23 Approximate costs incurred

• General reportingrule (Section S(a)) is expected to initially cost chemical manufacturers about $6 million. EPA estimates the cost will be $420 for each**l~emical** a manufacturerproduces.

• Costs for entire chemical industry projectedto be $100-200 millionper year. Preinventory notification 17 cost: $1,200-1,500per chemical.

• $220/yearperworker.18

• About $256 million lostdue to**cance1latio~ or**  suspension of pesticides.

• About $249 million spent by entire**chemical ~ndustry**  for airpollution control.Statute
CleanWaterAct

Safe DrinkingWater Act
Resource Conservation and

Recovery Act

Hazardous Materials

1ransportationAct National Environmental Policy

Act Coastal Zone Management Act

Power Plant and Industrial

Fuel Use Act Table 8-17. Concluded

Applicableprovision, regulation or requirement of statute

• Dischargepermits • Effluent limitations guidelines • New source performance standards • Control ofoil spills and discharges • Pretreatment requirements • Monitoring and reporting

_• Permitting of industrial projects that impinge on wetlands or publicwaters • Environmental impact statements

• Requires underground injection control permits

• Permits for treatment, storage, and disposal ofhazardous liquids. • Establishes system totrack hazardous wastes • Establishes recordkeeping, labelling, and monitoring system for hazardous wastes • Superfund

• Requires environmental impact statements
• Allows states to veto Federal permits forplants tobe sited in coastal zones
• Prohibits new, major, industrial power plants, which utilize fuel oil ornatural gas



### 8-24 Approximate costs incurred

• Increased annual costs topesticide manufacturers, causedby regulations, under Sections 301 and 304, would range between 0.2 and 2 percent ofthe revenues from pesticidechemicals. Profitability would be**reduc~B** for some manufacturers.

• Total annual costof $243 million incurredby organic chemical, pesticide, and explosives industries tocomply wi!§ EPA hazardous waste regulations.

• Another source estimates $414 million total expenditureby entirechemical**in~~stry** forwater pollutioncontrol.

• Only one out ofthemore than 500 surfacedumps and landfillswould meet RCRA standards. Over $1**bill~2n 2eeded**  to upgrade the others. '

• Proposed that $400 million of $6 billion superfundcome from annual industry fees on oil, chemical,**a2~** heavy metal industries. Partof fund would come from fee, not to exceed $5 perton on chemicals. Fund applies only topastdisposal practices.

• Waste disposal costs are expected to rise from $1.50-$5.00 per to24 to over $50 per ton under RCRA.innovation, productivity, job opportunities, and 11incentive for entrepreneurial initiative, 11 are not easilyquantified and are excluded.13•14 In addition, health and economic benefits ofthe regulations are not considered.15 The economic impact of these regulations on the chemical industry is not fully quantified. The Council on Environmental Quality reported in 1979 thatthe economic health of this industry is betterthan most and that few plantclosings are expected solelybecause ofthe costs of compliance with standards and regulations.25 A1978 study by EPA 1s Office of SolidWaste Management found, with regard to regulations concerning hazardous wastes, that 11Certain individual segments of the industrywill be subjectto more severe impacts than the industry as a whole, but no plant closureswill result directly from the regulations."26 In contrast, a survey sponsored by the Chemical SpecialtiesManufacturers Association reported that 14 percentofthe firms surveyed saidthat present and upcoming EPA regulations could cause them to close. Nine percent saidthat EPA rules could cause a change of ownership. The survey stressedthat the greatest difficultycaused by the regulations would be increased operatingcosts, followed by reporting and recordkeeping requirements and increasedcapital costs.13 Partof this discrepancy in the perceived impact of Federal regulations may be reduced through the efforts of the Interagency Regulatory Liaison Group (IRLG). The IRLG intends to stronglyemphasize the coordination of regulations being developed by member groups and will also emphasize the economic analysis ofthe proposed regulations. Agencies participating in the IRLG include EPA, the Occupational Safety and Health Administration, the Consumer Product SafetyCommission, the Food and Drug Administration, and the Food Safety and Quality Service.27 Alistof currentlyproposed regulations thatwill affectthe chemical industry is given inTable 8-18.28 The economic impact of these regulations will be unclear until their final forms are determined from a number of regulatory alternatives. Studies of the economic effects ofmany of these regulations are underway atthis time.

8-25Table 8-18. PROPOSED REGULATIONS THATWILL AFFECT THE CHEMICAL MANUFACTURING INDUSTRY

Agency
DOL-OSHA DOL-OSHA
EPA-OANR
EPA-OANR

EPA-OANR

EPA-OPTS

EPA-OPTS
EPA-OWWM (as listed in the Calendar of Federal Regulations)

Title of regulation Page No. in calendar
Chemical Warning Systems 68278 Safety standard forwalking and working 68283 surfaces National Emission Standards for 68239 Hazardous Air Pollutants- Benzene Policy and Procedures for Identifying, 68292 Assessing, and Regulating Airborne Substances Posing a Risk of Cancer Regulations for the prevention of 68244 significant deterioration resulting from hydrocarbons for carbon monoxide, nitrogen oxides, ozone, and lead Rules and notice forms for premanu- 68294 facture notificationof new chemical substances Standards and Rules for Testing of 68297 Chemical Substances and Mixtures Hazardous waste regulations: Core 68299 regulations to control hazardous solid waste from generation to final disposal

8-268.6 COSTS AND COST EFFECTIVENESS OF CONTROLS ON AN INDIVIDUAL TANK This section presents the costs and cost effectiveness of controlling an individual tank. The tank selected for analysis is the model tank presented in Chapter4, Section 1. Emissions from the possible configurations of the model tank are presented inTable 4-2. The capital and annualized cost (withoutproduct recovery credits) of controls are presented inTable 8-19. Both the absolute costeffectiveness and the incremental cost effectivenesswill be discussed. The absolute cost effectiveness is defined as the total annualized costof a particular control option minus the value ofproduct recovery credit (the differenceyieldingthe net annualized cost), divided by the total emissions reduction achieved by going from no control to that control option. Incremental costeffectiveness is defined as the difference in net annualized costbetween two control options, divided by the difference in emission reduction between the same two options. Table 8-20 presents the absolute costeffectiveness ofbuildingthe model tankas a new internal floating roof tank in place of a fixed roof tank. Table 8-21 presents the incremental cost effectiveness ofcontrolling seal emissions from an internal floating roof. Table 8-22 presents the incremental cost effectiveness ofcontrollingdeck seam emissions by the
use ofwelded decks. Consistentwith the assumption used previously in this chapter, the costof controlling fittings is assumed to be zero; the costeffectiveness of these controls is, therefore, zero. Based on the above information, Table 8-23 presents the incremental cost effectiveness between the regulatory alternatives. Because it is possible to replace a fixed roof tankwith an external floating roof, an analysis ofthe internal floating roof equipment requirements ofthe regulatory alternatives was made relative to an external floating roof tankwith a mechanical shoe seal and a secondary seal. Table 8-24presents the incremental costeffectiveness ofbuildingthe model tank as an external floating roof tankwith amechanical shoe primary seal and a secondary seal instead ofthe equipment required by each regulatory alternative.



### 8-271. 2.

3. 4. 5.
6. Table 8-19. CAPITAL AND ANNUALIZED COSTS FOR BASELINE AND CONTROL EQUIPMENT FOR THE MODEL VOL TANK
Capital Cost Annualized Cost Item ($) ($)
Fixed roof tank 35,600 7,750 External floating rooftank 52,900 11,500 with mechanical shoe primary seal only Bolted deck 10,700 2,330 Welded deck 25,100 5,460 Secondary seal for internal or 2,440 640 external floating rooftank Liquid-mounted primary seal 75 17

8-28Table 8-20. ABSOLUTE COST EFFECTIVENESS OF CONTROLLING FIXED ROOF TANK EMISSIONS FROM THE MODEL TANK

Emissions Cost Effectiveness Tank Type/Equipment (Mg/yr) ($/Mg)
I. Fixed roof tank 6.22 1
II. Internal floating roof tank A. Bolted deck, vapor- 0.41 41 mounted primary seal, uncontrolled fittings B. Bolted deck, liquid- 0.34 39 mounted primary seal, uncontrolled fittings 

## c. Bolted deck, liquid- 0.24 32 mounted primary seal, controlled fittings 0. Bolted deck, liquid- 0.21 137 mounted primary seal and secondary seal, controlled fittings E. Welded deck, liquid- 0.17 650 mounted primary seal and secondary seal controlled fittings III. External floating roof tank 0.068 390 with mechanical shoe primary seal and secondary seal
1Not applicable.



### 8-2900 I w 0 

### Base Case

Vapor-mounted Liquid-mounted 1Not applicable. Table 8-21. INCREMENTAL COST EFFECTIVENESS BETWEEN INTERNAL FLOATING ROOF SEAL TYPES IN THE MODEL TANK

End Case Vapor-mounted with Secondary Liquid-mounted Liquid-mounted with Secondary ($/Mg) 7,640 1 ($/Mg) 

### credit 1 ($/Mg) 6,840 23,400

### Table 8-22. INCREMENTAL COST EFFECTIVENESS OF CONTROLLING DECK SEAM EMISSIONS IN THE MODEL TANK

Base Case End Case
Bolted deck Welded deck

8-31 

### Incremental Cost Effectiveness ($/Mg)
77,90000 I w N 0
2

- 

### Table 8-23. REGULATORY ALTERNATIVES AND INCREMENTALCOST EFFECTIVENESS ($/Mg) BETWEEN REGULATORY ALTERNATIVES IN THE MODEL TANK

RegulatoryAlternative
I II III IV ($/Mg) ($/Mg) ($/Mg) ($/Mg) ($/Mg) 

### v
FR 41 biFRvm credit biFRlm 0 biFRlm,cf 23,400 biFRlm,ss,cf 77,900 IFR w lm,ss,cf


# - - 1Hotation is as follows:

FR =fixed rooftank IFR =internal floating rooftank b=bolteddeck w=welded deck lm=liquid-mounted primary seal vm =vapor-mounted primary seal ss

### =secondary seal cf

### =controlled fittings 2

Ho controls required. 

# - - -Table 8-24. INCREMENTAL COST EFFECTIVENESS BETWEEN EQUIPMENT SPECIFIED BY EACH REGULATORY ALTERNATIVE AND AN EXTERNAL FLOATING ROOF TANKWITH AMECHANICAL SHOE SEAL AND ASECONDARY SEAL Regulatory alternative as base case Emission reduction Equipment1 Number
0 FR I biFRvm II biFRlm III biFRlm,cf IV IFR b lm,ss,cf 

### v IFR w lm,ss,cf 1Notation is as follows:

FR =fixed roof tank IFR =internal floating roof tank EFR =external floating roof tank b =bolteddeck w =welded deck lm =liquid-mountedprimary seal vm =vapor-mounted primary seal ms =mechanical shoe primary seal ss =secondary seal cf=controlled fittings (Mg)
6.15 0.34 0.27 0.17 0.14 0.10 Cost**effecti~eness** ($/Mg)
390 5,700 7,210 11,700

9,660

NA3

2

The annualized costwithout product recovery credit is calculatedas follows: Annualized cost= (costofexternal floating roof tank+costof secondary seal)

- (cost of fixed roof tank+ cost ofcontrols). 3Regulatory Alternative Vis more expensive than the EFR control option.

Therefore, cost effectiveness is undefined. ms,ss

8-338.7 REFERENCES 1. Basdekis, H. S. Emissions Control Options for the Synthetic Organic Chemicals Manufacturing Industry; (draftdocument submittedto EPA). Hydroscience, Inc. Knoxville, Tennessee. February 1980. 100 

### p. 2. Blackburn, J. W. Emissions Control Options for the Synthetic Organic Chemicals Manufacturing Industry; (draftdocument submitted to EPA). Hydroscience, Inc. Knoxville, Tennessee. December 1979. 120 p. 3. Memoranda from Shumaker, J.L. to Moody, W. ofTRW Environmental ProtectionAgency, dated October 11, 1982. Summarizing costdata from 11 equipment manufacturers and the correlation of data into general equipment costequations. 4. 11Economic Indicators11 Chemical Engineering, May 19, 1980, January 22, 1980, and October 4, 1982. 5. Telecon. Hyatt, Terry, Pittsburgh, Des Moines with Rockstroh, Margaret, TRW. May 19, 1980. Costs ofcone roof tanks, external floating-roof tanks, and secondary seals. 6. Letter from Rutland, McBarnett, GATX, to Guidetti, R., TRW. December 3, 1979. Costs for external floating-roof tanks and cone roof tanks. 7. Telecon. Stilt, George, Pittsburgh Des Moines with May, George, TRW. April 10, 1980. Costs ofexternal floating roof tanks and secondary seals. 8. Memorandum regarding internal floating roof deck fittings costs from 

### J. Shumaker toW. Moody, TRW Environmental Division, Research Triangle Park, NC. November 8, 1982. 9. Erickson, 0. G. Draft Storage and Handling Report; Emission Control Options for the SyntheticOrganic Chemicals Manufacturing Industry. Hydroscience, Inc. prepared for the U.S. Environmental Protection Agency, Research Triangle Park, NC. Contract No. 68-02-2577. October 1978. 10. Unit Process Guide to Organic Chemical Industries, Vol. 1. Science Publishers, Inc. Ann Arbor, Michigan. 11. News Flashes. Chemical Engineering. 86:12. 1979. p. 77. 12. U.S. Environmental ProtectionAgency. VOC Fugitive Emissions in SyntheticOrganic Chemicals Manufacturing Industry- Background Information for Proposed Standards; (Preliminarydraft). Research Triangle Park, North Carolina. March 1980. p. 8-25, 8-26.

8-3413. Chemical Specialties Manufacturers Cite EPA as Having Biggest Economic Effect. Chemical Regulation Reporter. November 2, 1979. p. 1317. 14. Jellinek Says EPA Will Use Authority to Compel Disclosure of PMN Information. Chemical Regulation Reporter. January 11, 1980. p. 1586. 15. Nader Group Scores Industry Figures on Costs, Benefits of Health Regulations. Chemical Regulation Reporter. October 12, 1979. p. 1107. 16. EPA Estimates TSCA Reporting Role Would Cost Chemical Industry $6 Million. Chemical Regulation Reporter. Bureau ofNational Affairs, Inc. January 11, 1980. p. 1585. 17. Proprosal of Premanufacture Notification Notice Form and Provision of Rules 40 CFR, Part 720.44(201). Washington, D.C. U.S. Government PrintingOffice. October 16, 1979. 18. Arthur Anderson and Co. Cost of Government Regulation Study. Washington, D.C. March 1979. 19. Cost of Pesticide Cancellations, Suspensions 11Nominal, 11 EPA Report Says. Chemical Regulation Reporter. February 29, 1980. p. 1794. 20. EPA Water Act Regulations for Pesticide IndustryUpheld. Chemical Regulation Reporter. May 18, 1979. p. 220-221. 21. RCRA Waste Disposal Discussed. Chemical Regulation Reporter. April 27, 1979. p. 93. 22. Union Carbide Sees $2 Billion Price to**Upgrad~** Storage Ponds Under RCRA. Chemical Regulation Reporter. April 27, 1979. p. 98. 23. Government Considers $6 Billion Fund. Chemical Regulation Reporter. May 4, 1979. p. 119. 24. Disposal Costs for HandlingWastes Outlinedby Consultant at Conference. Chemical Regulation Reporter. September 21, 1979. p. 982. 25. Environmental Quality, The Ninth Annual Report of the Council on Environmental Quality. Council on Environmental Quality. Washington, D.C. December 1978. 26. Study Reports Costs of Complying with Anticipated EPA Regulations. Chemical Regulation Reporter. 1978. p. 272. 27. Economic Analyses, Coordination to be Emphasized by IRLG in 1980-1981. Chemical Regulation Reporter. January 11, 1980. p. 1590. 28. Calendar of Federal Regulations. Federal Register, 44:230. November 29, 1979.
8-35

### 9. ECONOMIC IMPACT
9.1 INDUSTRY PROFILE 9.1.1 Introduction The industryprofile describes the economic characteristics of industries that store volatile organic liquids (VOLs). Its purpose is to provide background**infor~ation** 

### necessary to formulate and execute the economic impact analysis of Section 9.2. The discussion begins by identifying and describing the industries ofinterest: those involved inVOL production, VOL consumption, and VOL storage atmerchant terminals. Information on the basic supply and demand conditions ofthese industries, includingproduction and sales levels and inputs into theirproduction activities, is presented in the basic conditions subsection. Three subsections are then devoted to a discussion of the structure, conduct, and performance of firms inthe three industry segments ofinterest.* The section concludes with apresentation ofthe methodology and results for projectingthe nationwide VOL storagetankpopulation for the 1984-1988period. 9.1.2 Identificationand Description ofVOL-Storing Industries 9.1.2.1 VOL Producers. Figure 9-1 is a flowchart ofthe organic chemicals industry from raw feedstocks to endproducts. VOL manufacturers are partofthis industry, which is complex because many chemicals itmanufactures subsequently areused toproduce other chemicals. Hegman, for example, estimates that intraindustry shipments constitute as much as two-thirds oftotal sales inthe organic chemical industry.2 

### This phenomenon frequently results in double counting ofthe output ofprimary and intermediate chemicals and hampers accuratemeasurement ofproduction and sales. Manufacturers ofVOLs are classified in the three-digit standard industrial classification (SIC) code 286, Industrial Organic Chemicals. This *For the**benchr.~rk** 

### definition of these terms and their role in economic

analysis, see Reference 1.\.0 t I') I Coal**~** I Feedstock PrimaryOrganic Chemical•

r.troleunt Ethylen•

Pro1tylent

.Naphtha

GasOil

CoalTar, Butadiene light011

Benune Ethane Propane Butane p·Xylene 

# Lr Methanol Natural Gas I rlalllclllll

Oy•ttirlft and Plgmef111

Industrial**~** 0fgenlc Chemicals

Solventl

Rubber Procenlng Chemlcela

Pesllcldn IJ I Organic**Chamle~~l** MalorConstrmlno EndUse Products lndunrleo

rer.h•olnu. llulhllnoonol Comlrur.llun, lrllnt,mtlnlluu, lltUIIWWArttl, Furniture,and AtlllllftiiCet Apparel, Uphohtery Fabric, TireCord
Industrialend Consumer Cleaning Compound•

Tires, Belting,Hote

Ethicaland Proprietary Drugs

Crops

Figure9-1. Organicchemicalindustryflow chart.2

### category also includes establishments primarilyengaged in the manufacture of some nonvolatile and solid chemicals. For example, SIC 286 

### includes establishments**prim~rily** 

### engaged in the manufacture of fabricated rubber and explosives. While establishments primarilyengaged in the manufacture of industrial organic chemicals are classifiedin SIC 286, 

### establishments classified in other SIC industries produce these chemicals as secondary products. Approximately 20 percent of all industrial organic chemicals are produced inestablishments not classified in SIC 286.3 9.1.2.2 

### VOL Consumers. Industries in SIC 28, 

### Chemicals and Allied Products, consume the largest amount of VOLs. The largestconsuming industry is alsotheproducing industry: SIC 286, 

### Industrial Organic Chemicals. Other important consuming industries are SIC 282, 

### PlasticsMaterials and Synthetics; SIC 283, 

### Drugs; SIC 284, 

### Soaps, Cleaners, and ToiletGoods; and SIC 287, Agricultural Chemicals. Booz, Allen, and Hamilton, Inc., conducted a survey of organic emissions to identifywhich consuming industries store significant amounts ofVOLs. The survey indicates that industrial organic chemical producers, who in most cases are also VOL consumers, accounted for 64 

### percentof VOL emissions from storage tanks.4 

### It also indicates thatan additional 20 percentof all VOL emissions from storage tanks within the chemical industry originated in SIC 282, PlasticsMaterials and Synthetics. Other consuming industries each generate less than 5percent of storage tank emissions and are not considered further here. Flows ofindustrial organic chemicals are traced from SIC 286, Industrial Organic Chemicals, to other industries, based on U.S. Department of Commerce 1972 

### input/outputtables. 5

### * Major consumers of industrial organic chemicals not included in SIC 28 

### are SIC 22, 

### TextileMill Products; SIC 30, Rubber and Miscellaneous Plastics Products; and SIC 24, 

### Lumber andWood Products. The major types ofchemicals provided tothese users are dyes, lakes, toners, creosote oil, rubber-processing chemicals, and plasticizers. Shipments of *Industrial organic chemicals are included in two input/outputcommodity

groups: Industrial Organic and Inorganic Chemicals, and Gum andWood Chemicals. The commodity-by-commodity input/outputtable lists thepercentage oftotal U.S. output ofthe above chemicals consumed by producers of other**co~~odities.** 

### Any commodity that accepted 1

### percentor more ofthe flow ofoutput ofeither industrial organic and inorganic chemicals orgum and wood chemicals was included inthe 1972 

### Census ofManufactures under the appropriate industrygroup. Data on consumpt1on of industr1al organic chemicals appear in the input/outputtable on materials consumed by 

### kind.

9-3

### these products amounted to$701 million in 1972, or about 6.1percentoftotal industry shipments from SIC 286.6 

### Because the amount is so small, storage of chemicals outside of SIC 28 has been disregarded. Another user is SIC 516, Wholesale Trade ofChemicals and AlliedProducts, whose establishments purchase chemicals for repackaging and reselling. Industry contacts indicatethatthe storage tanks used by distributors typically have less than 75 m 3 

### capacity.7 

### Because this capacity is less than the cutoffs considered under each regulatory alternative, this profile does not includewholesale distributors. 9.1.2.3 VOL Storage Terminals. Data on storage services are difficult to collect for three reasons. First, most of the small private-merchant terminals that storeVOLs do not report financial data publicly. Second, many ofthe largerpubliclytraded companies aggregate data on chemical storage serviceswith data from other accounting units orwith data from storage of othercommodities, making it impossible to assess the financial and economic performance ofVOL storage enterprises from a specific SIC code. Data on chemical storage services are included in SIC 4226, Special Warehousing and Storage Not Elsewhere Classified, along with data on merchantwarehousing of other commodities such as petroleum, whiskey, and furs. Thus, datareported forthis category inthe 1972 Census ofBusiness Services do not represent chemical storage services as such. Furthermore, because establishments are classified by theirprimary functions and because chemical storage is usually a secondary function, data on much ofthe chemical storage industryare contained in SIC industrycategories otherthan SIC 4226. Proprietaryor captive terminals, ifused as storagepoints ratherthan as wholesale distribution centers, areclassifiedas auxiliaryestablishments forwhich no revenues or other statisticsare reported. For this report, information on bulkchemical storagewas obtained from a trade association, the Independent LiquidTerminals Association (ILTA). Members ofthis organization range from a merchant terminal operatorwith 1terminal comprised of7tanks to an operatorwith 14 terminals and a total of 1,469 tanks. Fewterminal operators report revenues or other statistics and, of those who do, statistics for chemical storage are combined with statistics for otheroperations. 8 

### For specific information, nine liquidterminal operators were contacted. No statisticswere collectedon proprietary terminals.

9-4

### 9.1.3 Basic Conditions This section addresses supply conditions, which are determined largelyby technological considerations, and demand conditions, which depend primarily on product attributes. 9.1.3.1 Supply Conditions. Employment, assets, and costs of materials for industrial organic chemicals between 1972 and 1977 are provided inTable 9-1. Total e:nployment in the industrial organic chemical industry increased about 12 percentover this 5-yearperiod. Assets also have increased since 1972. Expenditures on materials have tripled, largely because of the increased cost ofpetroleum-based raw materials. Resource use in Plastics Materials and Synthetics (SIC 282) is presented in Table 9-2. In contrastto the industrial organic chemical industry, this industryis becom.ing more capital intensive. Total employment fell by almost 3 percentbetween 1972 and 1977, and the number ofproductionworkers declined by over4

### percent. Over roughly the same period, the value of assets increased 38 percent. Between 1972 and 1977, expenditures on materials increased dramatically, by over 130 percent, primarily because of increased fuel and feedstock prices. Capital**ex~enditures** 

### and operating rates for the VOL-producing and VOLconsuming industries are presented inTable 9-3, in both current and constant dollars, fortheyears 1958 to 1978. Expenditures by VOL producers declined for someyears priorto 1972. When oil prices increa_sed sharply in 1973, expenditures started to grow again in real terms, risingby almost 200 

### percent over 5years. 

### Atrade survey indicated that these new expenditures were for improvements in old plants and process efficiency gains rather than for new capital assets. 1

# ° Capital expenditures in SIC 282, Plastics Materials and Synthetics, have increased steadily since 1958 as demand for plastics has grown. The most dramatic growth occurred after 1973, when plastics and resins companies began large expansion programs, afterwhich expenditures declined as companies invested inprocess improvements. 9.1.3.2 Demand Conditions. 9.1.3.2.1 VOL producers and consumers. Demand forVOL storage services depends upon demand for VOL chemicals and upon the inventory and distribution practices of VOL 

### producers and consumers. VOL producers and consumers choose to hold inventories, onsite or in terminals, to facilitate production and

9-5

### TABLE 9-1. RESOURCE USE BY PRODUCERS OF INDUSTRIAL ORGANIC CHEMICALS (SIC 286)9


### Production Cost of a Assetsa,b Employment workers materials ,b Year (103) 

### (103) 

### ($106) 

### ($106)


### 1972 136.5 87.9 5,514.4 12,490.9 1973 137.8 89.2 6,488.4 13,258.9 1974 135.2 88.2 10,608.8 14,068.3 1975 137.3 86.4 11,765.7 16,360.3 1976 141.8 90.3 14,713.9 18,972.9 1977 152.8 97.9 17,607.7 

### N/A
aCurrentdollars. bThe adjective "current" or "nominal" describes the measurement of an economic

magnitude in currentprices; i.e., prices pertaining to theyear inquestion. When currentor nominal values are compared for differentyears, no account is taken ofgeneral price inflation or deflation. By contrast, the adjective 11

### real" or 11

### constant11 

### refers to attempts to measure economic magnitudes by the quantityof real goods and services they command; i.e., with the general rate of inflation deducted to record the real command over resources.

9-6

### TABLE 9-2. RESOURCE USE BY PRODUCERS OF PLASTICS MATERIALS AND SYNTHETICS (SIC 282)9


### Production Cost of Employment workers materialsa Assetsa Year (103) 

### (103) 

### ($106) 

### ($106)


### 1972 161.9 116.0 4,854.9 9,468.5 1973 164.1 118.6 5,310.6 10,090.6 1974 169.8 121.8 8,521.9 11,268.3 1975 150.3 104.0 8,591.7 12,220.3 1976 152.8 107.0 10,687.5 13,047.7 1977 157.1 111.1 11,552.6 

### N/A

aCurrentdo11ars.



### 9-7TABLE 9-3. CAPITAL EXPENDITURES AND OPERATING RATES FOR SIC 286 AND SIC 282, 1958-1978 Implicitprice**Ca~ital ex~enditures**  {$106) deflator, gross SIC 286 SIC 282 Operating rates

private fixed Constant Constant for SIC 28, investmentsA nonresidential Currentb dollars**dollar~** (1972) Currentb dollars**dollar~** (1972) percentage of d nameplate capacity 1958 70.6 413.2 585.3 112.3 159.1 1%9 72.0 314.0 436.1 91.2 12G.7 1960 72.2 405.9 562.2 147.0 203.6 1961 71.8 457.2 636.8 206.8 288.0 1962 72.3 353.4 488.8 186.9 258.5 1963 72.9 513.4 704.3 240.7 330.2 1964 73.6 738.0 1,002.7 270.6 367.7 1965 74.5 737.5 989.9 472.0 731.8 1966 76.8 981.2 1,277.6 515.8 671.6 1967 79.3 937.9 1,182.7 436.5 550.4 1.0 1968 82.6 997.8 1,208.0 381.0 461.3 85 I (X) 1969 86.6 861.4 994.7 409.0 472.3 84 1970 91.3 1,030.2 1,128.4 396.7 434.5 80 1971 96.4 949.5 985.0 453.5 470.4 81 1972 100.0 831.6 831.6 693.9e 693.9e 85 1973 103.8 1,005.6 968.8 829.8 799.4 88 1974 115.3 1,689.4 1,465.2 1,327.4 1'151.3 81 1975 132.3 2,119.8 1,602.3 1,439.5 1,088.1 78 1976 138.7 2,684.4 1,935.4 1,368.6 986.7 78 1977 146.0 3,510.9 2,404.7 1,271.0 870.5 76 1978


## -- -- -- 

# -- -- 83

a bReference 11. cReferences 12, 9. dConstant dollars calculatedby dividing current dollars by the price deflator and multiplying by 100.

Reference 13. eBeginning in 1972, a category (Plastics Materials) was reclassified into SIC 282, causing the series

prior to 1972 to be inconsistentwith the series from 1972 to 1977.sales; i.e., they accept the cost of holding some VOL inventory in exchange for improved**c~erating** productivity and sales. For both producers and consumers,**inve~tories** are held in bulk due to economies of scale in storage. Table 9-4 presents data on production and sales of industrial organic chemicals fer**~he** period 1955 to 1981. Production of industrial organic chemicals increased at an average annual rate of 6percent from 1955 to 1974. However, fol1owing the sharp rise in oil prices in 1974 and the decreasing demand for cheoicals during the 1975 recession, 1975 production declinedto 85 percentofthe previous year 1s output. Production declined again slightly in 1976 as producers and consumers bothtriedto reduce inventories. With economic recovery, production of industrial chemicals increased, rising to 90 percent ofthe 1974 output in 1978 and surpassing the 1974 level thereafter. Physicai sales followed a similarpattern, increasing at a 6 percent average annual growth rate from 1955 to 1973. However, rapidly increasing feedstock prices in 1974 resulted in higher chemical prices. In 1975, the physical sales volume dropped to 80 percent of 1973 levels, as the impact of higher real prices was compounded by the 1975 recession. Physical sales further declined in 1976 to77 percent of their 1973 level, began to grow**~gain** in 1977, and rose in 1978 to 83 percent of the 1973 peak. The 1973 peak was matched in 1979, but physical sales weakened again in 1980 and 1981.**Phy~** sical sales of industrial organic chemicals consistently have represented about 50 percent ofproduction over the period 1955 to 1978. The other50 percent is·captivelyconsumed. Between 1S73 and 1981, current dollar sales increasedmuch more rapidly than did outputand physical sales volumes. In some years, dollar sales increased as chemical prices rose even though production and physical sales volumes decreased. Dollar sales increasedover 50 percent in 1974, while the physical sales volume fell 3.7 percent. Revenues changed very little as the volume ofphysical sales fell sharplybetween 1974 and 1975. In 1976, dollar sales began**~o** grow again. Table 9-5 contains production and sales data for plastics and resins materials, the largestVOL consumer. From 1955 to 1973, production and physical sales grew at an annual average of over 10 percent. In 1974, sharply risingprices for raw materials reduced outputby 15 percent although the physical sales volume grew by over 11 percent. In 1975, physical sales fell

9-9Year
1955 1956 1957 1958 1959 1950 1961 1962 1963 1965 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 TABLE 9-4. HISTORICAL PRODUCTION AND SALES**~F** INDUSTRIAL ORGANIC CHEMICALS, 1955-198114
Ratio of b PhysicBl physical Production sales sales to

(106 Mg) (106 Mg) production
23.5 11.9 50.6 27.8 12.6 45.3 26.7 12.7 47.6 24.9 11.9 47.8 25.0 12.3 49.2 27.1 12.9 47.6 27.6 13.4 48.6 30.1 14.2 47.2 32.5 15.1 46.5 36.3 17.5 48.2 40.1 19.0 47.4 44.3 20.8 46.9 45.7 21.7 47.5 51.4 24.7 48.0 56.8 27.4 48.6 57.8 28.1 47.5 57.7 28.6 46.3 65.6 33.3 50.8 69.9 36.2 51.8 71.8 34.9 48.6 61.0 29.0 47.5 61.9 27.9 45.1 61.2 29.1 47.5 64.6 30.0 46.4 82.1 36.3 44.2 77.8 34.9 44.9 77.5 33.8 43.6 Dollab c sales ' ($106) 2,811 3,008 3,097 3,039 3,498 3,672 4,040 4,082 4,210 4,697 5,182 5,762 6,359 7,047 7,277 7,381 7,592 8,558 10,049 15,245**15~355** 16,455 17,945 19.397 26,007 29,057 30,995

2These data reflect some double counting due to the interindustry trade balready noted.

These figures are developed by aggregatir.g data in the following International Trade Commission industrial categories: tar, tar crudes, cyclic intermediates, dyes, lakes and toners, flavor and perfume materials, rubber-processing chemicals, plasticizers, pesticides, miscellaneous end-use chemicals, and miscellaneous cyclic and acyclic chemicals. Priorto 1975, data on chemicals in the latter categorywere reported as Miscellaneous Synthetic Organic Chemicals. Figures for 1976 through 1978 are not strictly comparable to figures for otheryears due to a change in one product classification. The original classification was restored in 1979. cDollar sales are presented in current dollars. 

### 9-10Year
1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 TABLE 9-5. HISTORICAL PRODUCTION AND SALES OF PLASTICS AND RESINS MATERIALS, 1955-198114a
Ratio of b PhysicBl physical Production sales sales to

(106 Mg) (106 Mg) production
2.6 2.4 92 2.9 2.6 90 3.0 2.7 90 3.1 2.8 90 3.9 3.5 90 4.1 3.6 88 4.3 3.9 91 5.0 4.5 90 5.5 4.7 85 6.1 5.3 87 6.9 5.9 86 7.9 6.8 86 8.0 6.9 86 9.4 8.2 87 10.7 9.0 84 10.7 9.5 89 11.7 10.2 87 14.0 12.3 88 16.4 14.6 89 13.9 16.3 117 13.4 11.3 84 15.9 12.9 81 18.3 15.4 84 20.2 16.9 84 21.7 18.5 85 19.5 16.7 86 20.6 17.9 87 Dollar; c sales ' ($106) 1,651 1,730 1,811 1,819 2,333 2,351 2,427 2,658 2,770 2,930 3,346 3,658 3,547 3,880 4,235 4,298 4,541 5,353 6,644 9,416 8,461 10,148 12,822 14,224 17,705 18,291 19,597

aThese data reflect some double counting due to the interindustrytrade

already noted. bThese figures are based on the summation of two International Trade

Commission categories: plastics and resins materials, and elastomers (synthetic rubber). cDollar sales arepresented in current dollars.

9-11by 30 percent as price increases and the 1975 recession sharply reduced demand for plastics and resins. Manufacturers reduced 1975 production by only 3.6 percent, howeve;, allowing inventories to increase. In 1976, the physical sales volume increased again as general economic activity in the United States began to rise. Physical sales continued to grow in 1977 and exceeded the previous (1974)**pe~k** level from 1978 through 1981. Dollar sales of plastics and resins grew 14.3 percent annually between 1975 and 1978 as producers of automobiles and other durable goods, responding to rising energyprices, sought to replace heaviermaterials (e.g., steel and glass) with**lig~ter** weight plastics. Although prices ofplastics and resins also increased, potentially adverse impacts ofthose price increases on demand for these materials were offsetby sharply risingprices for substitute commodities, steel and glass, which are alsomanufactured by energy-intensive production processes. The combined effectof the increasedphysical sales volume and risingprices substantially increased dollar sales between 1974 and 1981.International trade is another potentially important component of demand. Specific data on the import and export ofVOLs is not available. The following discussion therefore presents international trade data for Industrial Organic Chemicals (SIC 286) and Plastics Materials and Synthetics (SIC 282). International trade data on tank storage services are also unavailable. Table 9-6 presents data on exports and imports of industrial organic chemicals for theyears 1972-1981. Comparing these datato dollar sales data indicates that a substantial and, over this time period, growing portion of sales is for export. Imports of industrial organic chemicals have been growing at about the same rate as have industry sales but aremuch smaller than the level ofexports, so trade in industrial organic chemicals has contributed**favora~ly** to the U.S. balance oftrade. Table 9-7 presents data on exports and imports ofplastics materials and synthetics. These data also indicate a favorable balance of trade. Growth in the value ofboth exports and imports has just kept pace with the value of industry shipment. International competition in Plastics Materials and Resins (SIC 2821), however, is expected to erode favorable trade balances that sector currentlymaintains.l6 9.1.3.2.2 VOL storage terminals. Chemicals are stored in terminals for

9-12

### TABLE 9-5. EXPORT AND IMPORT VALUES OF INDUSTRIAL ORGANIC CHEMICALS (SIC 286) EXCLUDING GUM AND WOOD CHEMICALS (SIC 2861)

FOR SELECTED YEARS BETWEEN 1972 AND 198115


### Year Exports Imports
1972 1,073.1 448.6 1977 2,879.4 1,094.8 1978 3,812.9 1,484.2 

### 1979 5,493.9 1,784.7 1980 6,292.1 2,008.7 1981 6,500.0a 2,050.0a
aEstimated.

TABLE 9-7. EXPORT AND IMPORT VALUES OF PLASTICS MATERIALS AND SYNTHETICS (SIC 282) FOR SELECTED YEARS BETWEEN 1972 AND 198116


### Year Exports Imports
1972 766.9 273.2 1977 1,751.6 385.6 1978 1,973.5 509.6 1979 3,181.2 513.8 1980 3,973.5 521.2 1981 3,861.2a 597.8a
aEstimated.

9-13short periods partly because of the need for transshipment: changes in the mode oftransportation between origin and final destination. Chemicals often
are moved in large bulk shipments to a distribution centerby barge or rail car. These large shipments are then partitioned into smaller lots for transportby truckto areas not served by barge or rail. The amount of transshipment undertaken depends upon locations (origin and destination), alternative transportation costs, product stability, and storage costs. Terminals are operated on a proprietarybasis and by independent companies. Proprietaryterminals are owned and operated exclusively by chemical producers
as part of their distribution systems. Independently operated facilities, often calledmerchant terminals, provide storage services on a contract basis. The merchant terminals lease capacity to chemical producers nearmarkets not served by appropriate proprietary terminals and atpoints where transshipment
occurs. They may also be used by producers when extra storage capacity is required on a short-term basis. Most terminal operations store other liquid and dry bulk commodities in addition toVOLs. Liquids likepetroleum, fats, fertilizers, and dry goods of many types commonly are stored at terminals. Depending on the terminal's location, chemicals account for 5to 25 percentof a facility's bulkliquid capacity and a slightly greaterpercentage of revenues from bulk liquid storage.9 At any given time a small percentage of a terminal's capacitywill hold VOLs. Conversion of a tank from another use to_VOL storage is possible butrequires purging ofthetank, an expensive and time-consuming process undertaken only about once every 5to 10 years. Therefore, most tanks are believedtobe in designated service as far as VOL storage is concerned. 9.1.4 Market Structure Issues addressed in the market structure section of this profile include vertical integration, market concentration, geographic distribution of plants, and barriers to entry. 9.1.4.1 Vertical Integration. Afirm that produces raw materials or fabricated inputs used in the production of its primary output or that engaged in further processingof its primary output is said to be vertically integrated. Vertical integration is apparent among firms that produce, consume, and store VOLs.9.1.4.1.1 VOL producer and consumer firms. The relationship between a

9-14firm's production cost and output price is affected, among other things, by the extent towhich the industry is vertically integrated. Within VOL production and consumption, vertical integration is extensive. Captive consumption ofVOLs averaged about 52 percent of total output during the period 1955 to 1978, a ratio that varied only slightly from year toyear (see Table 9-4). Vertical integration ofVOL production and consumption extends to storage services. In addition to proprietary storage at the production site, many large firms establishproprietary terminals that can serve the needs of nearby markets quickly. Because VOL producers and consumers manufacture a range of non-VOL products, proprietary terminals also provide storage for other chemical and petroleum products (e.g., fuels). When proprietary storage capacity is not available, merchant terminals are leasedto store these chemicals. 9.1.4.1.2 Merchant terminals. Many merchant terminal companies are proprietorships orpartnerships, some with only a single-terminal, and many are vertically integrated into distribution or repackaging services. Petroleum distributors are the most typical type ofmerchants providingchemical storage. Afew operators are large, international corporations with many terminals in the United States and abroad. Typically, these large firms are integrated vertically into distribution and other transportation services. 9.1.4.2 Market Concentration. Market concentration addresses the issue ofwhether individual market participants exercise economic power. Typically, market concentration indicates the share of businessheld by leading firms in
an industry. Concentration ratios based on the four largestproducers in an industry are citedmost frequently. Hundreds ofVOL chemicals exist, covering awide variety of production characteristics, output levels, applications and, consequently, market conditions. Many VOL chemicals (e.g., formaldehyde and alcohols) are manufactured by a relatively large number of firms through various processes. The products have a wide range of end uses inwhich substitutematerials often can be used. These markets therefore tend to be highly competitive. OtherVOL chemicals (e.g., succinonitrile and isoamylene) are manufactured by a small number ofproducers (in some cases, only one) and have no close substitutes in their end uses. In these markets, producers may be able to influence market prices considerably, at least in the short run. The precise degree ofmarket concentration in VOL production and consump9-15tion is difficult to evaluate because itvaries considerably among products. However, a general assessment of the industry-wide situationmay be made based
on capacity share datapresented inTable 9-8. These data suggest that no one company or group of companies dominates the industry. In 1976, the top 4 companies owned only 18percentoftotal VOL capacity and the top 20 firms owned 45.39 percent oftotal VOL capacity. 9.1.4.3 Geographic Distribution of Plants. 9.1.4.3.1 VOL producers. The location ofVOL storage is extremely important to determinate its commercial value. Table 9-9 contains 1972 and 1977 data on geographic distribution ofproduction sites of industrial organic chemicals.* VOLs are produced in almost every region of the country.t Most of theplants are small, employing fewer than 20 workers. The largestplants
are clustered in the South near raw material supplies and in the Middle Atlantic States close to industries that use the finished products. The 1977 statistics suggest that three changes may have taken place in the VOL-producing and VOL-consuming industries. First, a shift inthe location ofplants is apparent among different regions of the country. These data indicate that the number of plants in theMiddle Atlantic and West North Central States is declining and that a large portion of the new plants are being constructed in the EastNorth Central andWest South Central States. Second, plant size, as measured by the number of employees, appears to be increasing. In each of the three sectors comprising SIC 286, Industrial *Industry definitions for SIC 2861, SIC 2865, and SIC 2869 used by the Bureau

of the Census do not correspond precisely to definitions of the organic chemicals industry used by the International Trade Commission. Thus, data presented in Table 9-9 are not strictlycomparable with datapresented in Table 9-4. tGeographic regions as defined by the Bureau ofthe Census are: NORTHEAST

New England States: Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont. Middle Atlantic States: New York, New Jersey, and Pennsylvania. NORTH CENTRAL East North Central States: Ohio, Indiana, Illinois, Michigan, and Wisconsin. West North Central States: Minnesota, Iowa, Missouri, North Dakota, South Dakota, Nebraska, and Kansas. SOUTH South Atlantic States: Delaware, Maryland, District of Columbia, Virginia, West V1rginia, North Carolina, South Carolina, Georgia, and Florida. East South Central States: Kentucky, Tennessee, Alabama, and Mississippi. West South Central States: Arkansas, Louisiana, Oklahoma, and Texas. WEST Mountain States: Montana, Idaho, Wyoming, Colorado, New Mexico, Arizona, Utah, and Nevada. Pacific States: Washington, Oregon, California, Hawaii, and Alaska.

9-16!\umber 

### of firms 

### Top 4 Top 8 Top 20 Top 40 TABLE 9-8. INDUSTRY-WIDE MARKET CONCENTRATION BASED ON CAPACITY SHARE DATA, 197617

Percent Estimated Percent

### of of firms capacity (Mg) industry capacity


### 0.72 58,751.8 18.3 1.43 91,820.6 28.6 3.58 145,752.34 45.39 7.17 186,681.62 58.14

9-17

### TABLE 9-9. GEOGRAPHIC DISTRIBUTIONOF ESTABLISHMENTS, EMPLOYEES, AtlO VALUE OF SHIPMENTS OF SIC 286 lNDUSfHIAL ORGANIC**CH~MlCALS B'** **ud** I
zs.a. - -- -----
- ----- - --- ---- ---- -- --- -- -**--·"'"-'""'"'---=~-===z:;"** Establishments Establishments With Value of With Value of SIC Locatlonb 20 ormore**Employrc~** shfpnwnls 20 ormore Employees shfpmrnts code Vcnr Tot.11 employees 

### oo:•> ($lOG) Year Tol11l employees (10:1)**(~]Qfl)** 20Gl 1972 Unlled Stales 139 41 !1.9 332.3 1977 119 37 4.0 391.J Mlcldlo llllnnlfc lll 

# , 0.2 10.0 West North Central 33 7 o.n 27.3 25 6 South Atlantic 32 12 2.7 171.0 18 8 East South Central 16 9 1.6 86.9 1 1 West South Central 22 4 0.3 21.2 23 4 >0.2 >9.0 Pacific 6 3 0.2 11.1 3 2 2865 1972 United States 173 117 28.2 2,044.5 1977 191 127 35.7 5,637.0 New England 11 7 1.2 60.5 10 4 Middle Atlantic 66 47 12.7 698.6 68 45 16.7 1,933.8 1.0 East North Central 29 21 >2.5 33 23 I West North Central 4 1 0.15-0.25 

### ,_. South Atlantic 24 18 4.8 368.5 27 21 CX> East South Central 10 7 1.4 185.6 7 7 West South Central 18 13 2.2 324.4 16 13 Pacific 9 3 0.15-0.25 8 5 All other States 2869 1972 United States 514 295 101.7 9,179.1 1977 569 346 112.3 24,232.8 New England 33 15 5.8 212.3 29 18 Middle Atlantic 141 83 21.4 1,457.7 135 81 16.2 2,318.3 East North Central 82 45 >2.5 96 50 West North Central 21 6 t-:-o-2.49 20 6 South Atlantic 69 41 13.7 1,164.8 70 50 East South Central 30 18, 8.2 666.5 32 24 West South Central 87 65 34.7 4,393.6 110 83 45.7 14,075.9 Mountain 5 3 0.25-0.49 5 3 l'aclfic 46 19**~2.5** 42 19 3.6 552.2 A

11 other States aBlanks represent datawithheld to avoid disclosing figures for individual companies. bGeographic divisions as definedby the Bureau ofthe Census are listedfn the text.Organic Chemicals, the percentage of large plants increased. Third, a shift in resources away from SIC 2861, Gum and Wood Chemicals, to SIC 2869, Industrial Organic Chemicals Not Elsewhere Classified, is apparent. The former industry lost 20 plants and the latter gained 55 plants in 5years. 9.1.4.3.2 VOL consumers. The geographic distribution ofVOL consumers is presented inTable 9-10. In general, plants in this industry (SIC 282, Plastics Materials and Synthetics) are largerthan VOL-producing plants are; over75 percent of SIC 282 firms employ more than 20 workers. Overall, the industry is not as geographicallyconcentrated as the industrial organic chemical industry is; but a high proportion of the plants are located in the Middle Atlantic, South Atlantic, and East North Central States. 9.1.4.3.3 Terminals. Data on capacity ofmerchant storage terminals, by State, are presented inTable 9-11. Over half (51 percent) of ILTA members are located inTexas, Louisiana, and New Jersey. These data must be interpreted cautiouslywith respect toVOL storage, however, because capacity estimates includemany large petroleum storage tanks. Although data on proprietary storage are not available, major oil firms that also produceVOLs often use theirpetroleum distributionterminals to handie chemicals. Many of these terminals, along with a number ofterminals owned by chemical producers, are located along the inlandwaterway system that
covers the North Central and Southern States. 9.1.4.4 Barriers to Entry. Although entry into and departure from the principal industries storingVOL could not be measured directly, some general comments are appropriate about conditions facing firms consideringentry into the industry. Entry can take two forms. First, a chemical producer or consumer can enterby acquiringtanks for proprietary storage or vertical integration. These firms face apparently surmountable barriers ofcapital formation, expertise, and local laws and standards. Astorage facility requires expenditures for tanks, land, and concrete pads. Support services, labor, and maintenance must be provided. Such firms also must find ordevelop expertise in managing storage operations.. Before construction of the facility
can begin, permits must be obtained from Federal, State, and local Government agencies, and construction usually must conform to standards setby private organizations. All ofthese barriers can be overcome ifthe internal rate of return on the investment is sufficiently attractive. Alternatively, many firms can bypass legal barriers to entry by purchasing an established storage facility.
9-19\0 I N 0 TABLE 9-10. GEOGRAPIIIC DISTRII3UTION OF ESTAOLISIIMENTS, EMPLOYEES, /\NO VALUE OF 

### SHIPMENTS OF SIC 282, 

### PLASTICS MATERIALS AND SYNTIIETICS2°•2ta**-......-.:-;~ --~~-::-:-_:----~----=~~-=---** **-~-:;.:** -- .,..........., ________, Establishments With 20 ormore Employees Value of shipments SIC code Year Locationb Total employees (103) ($106) Year Total
2821 1972

2822 1972

2823 1972

2824 1972 United States New England Middle Atlanllc East North Central West North Central South Atlantic East South Central West South Central Pacific United States

East North Central South Atlantic East South Central West South Central Pacific United States

Middle Atlantic East North Central South Atlantic East South Central United States

New England Middle Atlantic South Atlantic East South Central EastNorth Central 323 30 66 00 12 35 18 35 46 59 13 7 3 18 8 20

6 1 8 3 60

6 35 15 263 28 53 64 11 27 15 31 35 34

5 6 3 16

2 14 4 1 1 2 54

4 35 14 54.8 >2.5 >2.5 >2.5 1:-o-2,49 >2.5

4.5 >2.5 Co-2.49

11.8 1.0-2.49 0.5-.99 1.0-2.49 >2.5 0.25-0.49 19.0 >2.5 1.0-2.49 1.0-2.49 1.0-2.49 76.3 0.25-4.9

54.6 21.3 4,478.2

333.4

1,089.4

627.9

3,601.4
2,636.2

950.6 1977

1977

1977

1977

aBlanks representdatawithheld to avoiddisclosing figures for individual companies. bGeographfc divisions as definedby the Bureau ofCensus are listed in the text. 397 34 01 81 11 54 23 44 59 63 11 3 14

10

1 5 2 66

3 2 43 12

1 Establishments Wlth 20 ormore Employees employees (103) 310

25 G!i 63

8 46 19 36 43 30

3 3 13

10 1 5 2 58

3 1 41 12

1 57.2

10.0

15.9

74.0 Value of shipments

($lOG) 10,8111.2

1,863.3

998.9

6,379.7TABLE 9-11. TOTAL 1982 MERCHANT LIQUID BULK CAPACITY, BY STATE8

State
Alabama Arizona Arkansas Ca1ifornia Colorado Connecticut Delaware Florida Georgia I11inois Indiana Iowa Kansas Kentucky Louisiana Maryland Michigan Minnesota Mississippi Missouri Nebraska Nevada New Jersey New York North Carolina North Dakota Ohio Oklahoma

.Oregon

Pennsylvania South Dakota Tennessee Texas Virginia Washington West Virginia Wisconsin Total Total capacity (m3)

337,269

24,009 72,989 1,428,962 12,100 550,459 184,758 294,198 663,982 1,866,126 135,180 781,948 291,471 4,055 4,001,388 260,190

39,988 581,719 154,548 239,763 273,035 8,268 4,230,975 1,464,066 409,807 126,271 257,501 440,876 429,917 1,416,862 156,186 133,823 5,944,659 20,218 187,886 120,840

64,939 27,617,231

9-21 Share of total U.S. capacity (%)
1.22 0.09 0.26 5.17 0.04 1.99 0.67 1.06 2.40 6.76 0.49 2.83 1.06 0.01 14.51

0.94 0.14 2.11 0.56 0.87 0.99 0.03 15.32

5.30 1.48 0.46 0.93 1.60 1.56 5.13 0.57 0.48 21.53

0.07 0.68 0.44 0.24 100.00Potential merchant terminal operators face similar barriers, among them capital formation, which is often more difficult for the small business than for the larger business. Also, capital formation may be more difficult for new terminal operators than for existing operators wishing to expand their operations but is not anticipated to represent a barrier sufficientto prevent entry into the industry. 9.1.5 Market Conduct This sectionfocuses on pricingbehavior in the industrial organic chemicals and merchant terminals industries. The observations could be helpful for assessing theprice impacts of the proposed new sourceperformance standard (NSPS). 9.1.5.1**Che~ical** Pricing. VOL producers and consumers manufacture many chemicals embracing awide variety of characteristics. Potential for substitution and/or intermediate competition varies considerably from chemical to chemical. In general, though, aprice-induced incentive to substitute is diminished by thefact thatgood substitutes.are frequently alsoVOLs. The substitutes are therefore also subjectto cost and price changes relatedto a storage standardor other common factors. Table 9-12 presents price data for industrial organic chemicals and plastics, resins, and elastomers materials from 1955 to 1981. These data indicate that during the era of stable, low-energy prices from 1955 to 1973, chemical prices remainec stable incurrentterms and declined slightly in constantterms. Following the rapid increase in energy prices in the fall of 1973 and in 1974, the average currentprice oforganic chemicals rose sharplyand continuedto increase between 1975 and 1981. However, constantprices increased at a much slower rate thandid currentprices. Data inTable 9-12 also indicate thatboth current and constantprices for plastics and resins declinedduring the period 1955 to 1972 as energy prices remained stable and production technology improved. However, the sharp increase in**ra~ ~aterial**  prices in 1973 resulted in a 29 percent increase in currentprices for those products between 1973 and 1974. The productprices of the industry again increased substantiallybetween 1974 and 1975. Thereafter, the rate atwhich currentprices increased slowed, and real prices remained stable between 1975 and 1977. Between 1977 and 1981, the real price of plastics, resins, and elastomers fell.

9-22Year
1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 TABLE 9-12. HISTORICAL PRICE DATA FOR INDUSTRIAL ORGANIC CHEMICALS AND PLASTICS, RESINS, AND ELASTOMERS, 1955-1981
Industrial organic
· chemicals Average unit prices Currenta Constantb

((l:/kg) (¢/kg)
24 24 24 26 28 28 30 29 28 27 27 28 29 29 27 26 27 26 28 44 53 59 62 65 72 83 92 27 27 26 27 30 30 32 30 30 28 28 28 29 28 25 24 23 22 21 28 31 33 32 32 31 32 32 Plastics, resins, and elastomers Average unit price Currenta

(¢/kg)
69 67 67 65 67 65 62 59 59 55 57 54 51 47 47 45 45 44 45 58 75 79 83 84 96 110 109 b Constant (¢/kg)
79 74 72 69 70 69 66 63 62 58 59 54 51 46 44 41 39 37 35 37 44 44 44 41 42 42 38 Producer price

# !~~~~a~~:r:!~ 86.6 90.0 92.8 93.8 94.6 94.7 94.4 94.5 94.3 94.8 96.3 99.0 100.0 102.6 106.2 110.2 113.8 117.9 129.2 154.1 171.1 179.0 190.1 204.2 228.8 261.5 286.0 aAverage unitpricewas calculated from Tables 9-4 and 9-5 as total sales

value divided by total sales quantity. Rounding may make convertedvalues appear inconsistent. bConstantprices, measured by 1967 dollars, were calculated by dividing the

average constantunitprice ofthe chemicals by theproducerprice index for all manufactured goods. cReferences 11, 22.

9-23

### 9.1.5.2 MerchantTerminal Storage Pricing. Results of a telephone survey of nine merchant terminal operators suggesttwo general pricing schemes are practiced. Under the simpler method, the terminal charges a fee (often calledathroughput fee) for each unit of chemical thatpasses through its storage tanks.* Individual terminals adjust throughput fees to reflect variations in quality of storage serviceprovided to the customer and inphysical properties ofthe chemical to be stored. Under the more complex pricing system, the terminal charges abasic fixed fee for the duration of the storage contractto recover fixed costs associated with the terminal 1

### s storage facilities and costs associatedwith handling a minimum voluoe ofthroughput.t Ifthroughput exceeds the level on which the minimum charge isbased, theterminal levies an additional per-unitcharge on the additional volume of chemicals it handles to cover the costofadditional labor, energy, and materials inputs. Often, as the volume ofthroughput and the number oftank turnovers (throughput divided by tankcapacity) increase, thepricechargedby the terminal for additional throughput is reduced, reflecting economies of scale in handling large numbers ofturnovers.t Companies apparentlyvary the fixed fee they charge accordingtomarket conditions so discounts may be offeredwhen demand for storage services is low. Payment for additional throughput services ismade intwo parts. Half ofthe throughput rate is collected as the chemicals are unloaded from trucks, rail cars, or barges into the storagetank and the remainder is collected as *For example, a 

### customer may require storage for 1.5millionQ/yr ofmethyl

alcohol. Ifthethroughput rate for methyl alcohol is 3¢/!, 

### the total annual costto the customer of storingthis volume is $45,000. tUsuallytheminimum throughput represents four complete turnovers of the

rented storagetanks 1 

### volume. If a 1-million-litertankis rentedby a customer, the customerwill be able to store up to 4million liters in thetank in any givenyearbefore incurring additional charges. TAn example of the second pricing scheme is as follows. The annual rental fee

for storingmethyl alcohol in a 250,000-litertankmight be $30,000. If annual throughput exceeds 1**million~** 

### (i.e., the chemicals in the tank are turned overmore than four times), a surcharge of**2¢/~** 

### ofchemicals might be leviedfor the next 500,000**~** 

### of throughput. The surcharge might be lowered to**1.5¢/~** 

### for all annual throughput exceeding 1.5**million~­** 

### Thus, iftotal annual throughput is 

### 1.5**million~.** 

### total terminal revenues might be $40,000. If throughput rises to 2**million~.** 

### terminal revenues might increaseto $47,000. ·



### 9-24

### the chemicals leave storage. The basic fee is collectedwhile the tank is used.Other storage pricing systems may be used in addition to the two methods described here butwere not identified in the survey, which covered only approximately 10 percent of all merchant terminal operators. Details ofthe pricingpolicies used by the remaining.90 percent ofVOL merchant terminals were not available. Finally, itshould be noted that virtuallyevery storage contract is unique because ofthe large number of services offered by terminals to customers. Variables that affectbasic rates and throughput surcharges include options thatmay be added to atank (e.g., floating roofs, nitrogen blankets, refrigeration, insulation, steam heating, special linings, auxiliary pumps, vapor recovery systems, and other pollution control devices), modes of transportation, length ofcontracts,* age of tanks,t and corrosivity and toxicity ofchemicals.+ Additional services add to storage costs, which are passed directlyto the customer in the contract. 9.1.6 Market Performance 9.1.6.1 VOL Producers' and Consumers' Financial Characteristics. Two recent EPA reports presented data and results of an analysis on fiscal year (FY) 1977 financial data for a sample of 100 chemical firms.23•24 

### Itwas estimated that the average aftertaxcost ofcapital measured in currentdollar terms for chemical firms was 10.81percent. Ifcapital costs are distributed normally, 95 percent ofthe industry firms face aftertaxcapital costs ranging from 8.95 to 12.67 percent. 9.1.6.2 Merchant Terminals' Financial Characteristics. Afinancial profile ofterminal services could not be developed because (1) 

### financial data are not providedby many firms and (2) 

### data on the terminal operations of vertically integratedfirms are not reported separately from otheroperations on Security and Exchange Commission (SEC) 10K forms.
*The basic rate ofa 1-yearcontract is likelyto be higherthan thatof a

15-yearcontractdue to the capital recovery factory. tinTexas, State regulations require different designs on tanks builtbefore

and after 1976. +Corrosivity requires relining ofthe tanks, and toxicityrequires special

handling equipment and techniques.

9-259.1.7 ProjectedNew and Reconstructed VOL Storage Tanks: Calendar Years 1984-1988 The projection for new and reconstructedtanks has two components: tanks that replace retiringtanks and tanks that increase total storage capacity. The projection 1s methodology and results for each component are discussed separately below. Replacement tanks were projected by three steps. First, the number of • tanks in place in each of theyears 1954-1977 has been estimated by using the Federal Reserve Board index of organic chemical production as a proxy ofVOL chemical production capacity during the 1954-1977 period.25 '26 This index has been smoothed through regression procedures,* and the total number of VOL tanks in place for each of theyears is computed based on the regression equation and 1977 data on the number ofVOL storage tanks. 27'28 Inherent in this procedure is the assumption thatthe ratio of storage capacity to production capacity is constant. Second, a tank age profile for 1977 has been constructedby using a recursive procedure that assigns ages to tanks based upon the number oftanks existing in the prioryears as established in the first step of thismethodology. 1. Additional assumptions required for this procedure are as follows: Atank1s economic life is assumed to be 20 years, an assumption consistentwith the tank costmethodology of Chapter 8. 2. During the initial year (1954) of the recursiveprocess the age of tanks was uniformly distributed between 1 and 20 years. This assumption is fairly arbitrary but, because the number of tanks estimated in 1954 (3,800) is estimated to be less than 14 percent ofthe total number in 1977 (27,540), alternate assumptions are unlikely to produce substantially different results. 3. All obsolete (20-year old) tanks were replaced and new tanks purchased at the beginning of each year. This assumption is necessary simply because the recursive procedure is a discrete approximation
*The smoothed data are thepredictedvalues of the index with a log linear

specification: In Yt

# =.079 t. In Yt is the natural logarithm ofthe production index foryear t (t= 1954 to 1977), and .079 is estimated through least squares procedures with the regression line constrainedto pass through the observation for 1977.

9-26of a continuous process. Alternate assumptions, including refinements in the time interval used, are also unlikely to produce substantially different results. The recursive procedureworks as follows: given the age distribution of tanks in 1954 (assumption 2 above), age all existing tanks 1year, compute the number of replacement tanks required in 1955 (the number of tanks that have aged to 21), compute the number of new tanks required in 1955 (the difference between the total tanks in 1955 and 1954), and construct an age distribution of tanks in 1955. This process is repeatedyear by year until an age distribution of tanks for 1977 has been generated. The third step inprojections oftankreplacement for 1984-1988 is to use the 20-year economic life assumption and the age distribution oftanks in 1977 to compute the number oftanks in each of the projectionyears. That is, each tanks in the 1977 age profile thatwill be 21 years old in a projectionyear will be replaced in thatyear. These results indicate that4,900 replacement tanks will be constructed during the period 1984-1988 (see row 1 of Table 9-13). Projected VOL storage tanks construction that adds new capacity nationwide is based upon forecasted growth of the organic chemicals industry. The Federal Reserve Board index of organic chemical production, extrapolated to the 1984-1988 period from data for the period 1954 to 1977, indicates an average annual growth rate of about 7.9 percent. Chemical industry observers from the American Chemical Societyand the U.S. Department of Commerce have independently indicated some apparent slackening in long-term growth in the organic chemicals sector and aprobably more realistic growth rate of4to 6percent for theprojectionperiod.29•3° On this basis, 5percent annual growth in the organic chemicals industry and proportionate increases intankand production capacities are assumed toproject new capacity tanks (see row 2ofTable 9-13). Over the period 1984-1988, 10,200 new capacity tanks are projected. By comparison, a 7.9 percentgrowth rate from 1977 would have resulted in a projection of 21,620 new capacity tanks in the period. Total new tank construction in the projectionperiod is shown in row 3 of Table 9-13. Finally, theprojection of new tanks during 1984-1988 is disaggregatedby capacity and vapor pressure. 

### A1977 survey of VOL storage tanks provided an estimatedpressure and volume distribution for the tanks (seeTable 9-14 for a summary).31 •32 This percentage distribution tablewas secularmultiplied by

9-27l.O I N cc TABLE 9-13. PROJECTION OF VOL STORAGE TANK CONSTRUCTION--1984 TO 1988 ALL CAPACITIES, VAPOR PRESSURES, AND ROOF DESIGNS

Tanks 1984 1985 1986 1.987 1988 Total number of new tanks built 1,030 1,100 1,170 1,250 1,340 nationwide to replace retiring, existing tanks Total number of new tanks built 1,850 1,940 2,030 2,140 2,240 nationwide to supplement existing VOL storage capacity atan annual growth rate of 5percent Total number of new tanks built 2,880 3,040 3,200 3,390 3,580 nationwide--replacementplus 5percent new capacity growth

---- ------ - -- -- -- -- - - ---- - - -- -- ---- - - - - ------ -- =.::- -_-;.:::=:-=.-: Total (1984-1988) 4,900

10,200

16,090

### TABLE 9-14. 

### ESTIMATED PERCENTAGE DISTRIBUTION OF VOL**~TORAGE** 

### TANKS BY VAPOR PRESSURE AND TANK CAPACITY, 1977


### VaEor Eressure (KPa) Capacity 0- 3.5- 6.9- 10.3- 34.5- 

### (m3) 3.5 6.9 10.3 34.5 58.6 >58.6 

### TOTAL
0-75 27.98 6.55 3.22 5.14 1.23 0.39 44.51 75-150 9.26 1.58 0.93 2.32 0.03 0.13 14.25 150-375 8.94 1.68 1.17 2.28 0.19 0.06 14.32 375-3,750 12.84 2.98 1.58 5.59 0.46 0.16 23.61 3,750-15,000 1.12 0.36 0.35 1.10 0.09 0.00 3.02**~15,000** 0.03 0.00 0.07 0.19 0.00 0.00 0.29 

### TOTAL 60.17 13.15 7.32 16.62 2.00 0.75 100.00


### aThe original percentage distribution table covers 24 

### volume intervals and 18



### pressure intervals. This table summarizes the distribution table for relevant, aggregate intervals ofboth volume and pressure. All computations of economic impact were performed using the intervals and data of the original distributiontable.

9-29the projected new tanktotals ofTable 9-13 toyield volume and pressure intervals for the period 1984-1988.* Table 9-15 shows the summary results of this multiplication for all new tanks projected for 1984-1988. This application of the estimated 1977 tank distribution assumes the VOL storage tank distribution by vapor pressure and tank sizewill remain constant over time. All projections described in this subsection are based on assumptions and data described above. While they are as accurate as the data and assumptions permit, changes in the economy, technological advances, development of competitive substitutes, discovery of new product uses, and changes in market stability may affect actual industrygrowth. Such occurrences are difficultto anticipate. These projections reflectthe most probable scenario and are the best possible, given the data available. 9.2 ECONOMIC IMPACTS OF REGULATORY ALTERNATIVES This sectionpresents the estimated impacts of the regulatory alternatives on the users ofVOL storage tanks. Six regulatory alternatives are considered, the first ofwhich is the baseline case from which the impacts are measured. In general, the alternatives are increasingly more stringentmoving from the baseline to Regulatory Alternative V. The economic impacts considered in turn are: the impact on the price of the outputof the two model plants, the impact on investment in the two model plants, the impact on investment in VOL storage nationwide and the impact on the annual costs ofVOL storage nationwide. 9.2.1 Product Price Impacts Estimates ofthe impact ofthe regulatory alternatives on product prices have been developed based on two model plants: an independent storage terminal and a VOL chemical producer/consumer. The tank requirements and other characteristics ofthesetwo facilities are described in detail in Chapter 6. They were selected for analysis because it is believed that theywould experience relatively greater than average cost impacts as a result of the imposition of any of the regulatory alternatives. Before turning to the estimates, a brief description of the general approach and assumptions is first presented. In the long-run the market price of aproductproduced by a competitive industry is equal to the average cost, including a normal return on investment, *There are 24 volume intervals and 18 vapor pressure intervals in the original

percentage distribution table.

9-30TABLE 9-15. PROJECTION OF VOL STORAGE TANK CONSTRUCTION b BY VAPOR PRESSURE AND TANK SIZE, 1984-1988a,
Capacity (m3)
0-75 75-150 150-375 375-3,750 3,750-15,000**~15,000** TOTAL 

## o3.5 3.5- 6.9
4,500 1,050 1,490 250 1,440 270 2,070 180 480 60 10 0 9,680 2,120 Vapor pressure (KPa) 6.9- 10.3- 34.5- 10.3 34.5 58.6 >58.6

520 830 150 370 190 370 250 900

60 180 10 30 1,180 2,670 200 10 30 70 20

0 320 60 20 10 30

0 0 120 TOTAL
7,160 2,290 2,300 3,890 490

50 16,090
aThe original percentage distribution table covers 24 volume intervals and 18

pressure intervals. This table summarizes the distribution table for relevant, aggregate intervals of both volume and pressure. All computations of

beconomic impactwere performed using the intervals and data ofthe original

distributiontable. Rows and columns may not sum to totals due to rounding.

9-31of**ne~** facilities. This is because firms will not choose to build a new facilityunless they anticipate that the market pricewill be sufficientto cover all costs. Thus, the change in the average operating cost of a new facility due to an NSPS is the bestpointestimate of the long-runproduct price impact ofthe regulatory alternatives under consideration. In a case such as that presented here, where the model facilities utilizedwould be expectedto experience greaterthan typical cost increases, the average industryprice effects measured inthis way would be overstated. As documented in Chapter 8, all the regulatory alternatives exceptthe baselinewill increase tankfabrication costs. This increase in cost can be taken as the increase in the price of tanks to the VOL tank users based on the
same logic as outlined above. For a constant cost tank industry, as illustrated in Figure 9-2, this increase in average costs will show up as a vertical shift in a horizontal supply curve from Sto S'. The price oftanktype i in year twill rise from PtoP'. nowever, the long-run impacts of the regulatory alternatives on the price ofVOL storage services cannot be simply calculated from this price change alone. This is because the regulatory alternatives considered here impact services and performance, as well as the price of the tanks. In principle, at least, these impacts can affectthe cost of storage services in three ways: they reduce the effective capacity of a tankdue to the insertion of an internal roof; they reduce storage capacity requirements because they improve storageefficiency, and they reduce VOL vaporization and, hence, 

### VOL losses. The first impact is mechanical in origin: an internal floating roof occupies 1 to 2 feet of vertical space in a storage tank, thus decreasing the effective capacity of the tank. The capacityreduction is inversely related to the heightofthe tank and ranges between 6and 12 percent of capacity for a 75-m3 tankthat is 16 feet high and between 2 and 4percent of volume for a 20,000-m3 tankthat is 48 feet high. Thus, everything else being equal, this feature of the regulatory alternatives would tend to increase the number of tanks impacted as more tanks would be needed to store a given**velum~** ofVOL. Second, the reduction in VOL vaporization accompanying the regulatory alternativeswill affect the capacity requirements of VOL starers. Specifically, the use ofmore efficienttanks means that less VOL will be needed to serve given production ormarketing requirements. Thus, everything else being

9-32 

# '$/Tank



### P' a c 

## -------+--f----S'

p b d 

## s

Tanks/Year

Figure9-2. VOLstoragetankmarketfortanksinvolumeinterval i ascharacterizedintheeconomicimpactanalysis.



### 9-33equal, this feature of the regulatory alternatives would tend to decrease the number of tanks impacted. Fewer tanks would be needed to store a given volume ofVOL. The magnitude ofthe reduction in tank requirements will depend on the effectiveness of vapor emissions reduction and the relationship between storage tank capacity and VOL use. Assuming a capacity to throughput ratio of 0.4 and the equipment effectiveness described in Chapter 7, the requirement for tank storage capacitywould be reduced by roughly 1 percent. The proposed regulatory alternatives therefore initiate two influences on storage costs thatwork in opposite directions. Since the magnitudes of these influences are thought to be relatively small as well as contrary, no attempt is made to adjust estimates ofVOL storage tank requirements to account for them in each regulatory alternative. The final impact is also technical in origin but has important economic implications. In particular, since the additional equipment required by the regulatory alternatives will reduce the amount ofVOL vaporized, fewer valuableVOLs will be lost to the atmosphere. Therefore, thisquality improvement in the tanks will at leastpartially offset any increase in the price of the tanks. This consideration is incorporated into the analysis. With this background, the mechanics of the procedure used to develop theprice impacts in next discussed. The change in the price ofVOL storage services was estimated for both model plants using Equation 9-1:

where 20 k

0 + k1

## =ITC + ! [(1

- G)(P · 

### Q - C) + G·Dt] (1 + r)-t , t=1 k

0

## =initial incremental investment k1= incremental investment inyear 10 discounted tothe present ITC

# =the investment tax credit (10 percent}

r

## =real after tax rate of discount (10 percent) t =year (1,2,3,

..., 20) 

### Q

## =annual output P

## =change inprice

9-34 (9-1)C

## =incremental annual operating cost G

# =tax rate (49 percent) Dt

## =straight line depreciation in year t, with an assumed 20 year commercial life for floating roofs and 10 year commercial life for seals. Equation 9-1 is afinancial balance equation that states thatthe present value of the investment and operating costs required by the regulatory alternative must be equal to the presentvalue of the stream of revenues. By solving the equation for P, one obtains the change in the price ofthe product
or service required ifthe plantor terminal operator is to achieve a return on investment for themandated equipment that is competitivewith other investment opportunities. The genercl features of the financial balance computation are as follows. The firm obtains a 10 percent investment tax credit on the equipment purchase. The computation is done on an after tax basis where the income tax rate is49 percentof net revenues. All revenues are in constant 1982 dollars, so the 10 percentrate ofdiscount selected for this analysis is a constant (or real) aftertax rate. A10 percent rate ofdiscount is consistentwith that employed in Chapter 8for annualization of capital costs. As discussed in Section 

### 9.1, financial data for 1978 from a sample of 100 chemical companies shows an average after tax rate of returnof 10.81percent. Given the inflationary economic environment of 1978, the real rate of return to the firms would likely have been somewhat less that 10 percent. Using a real after tax discount rate that is arguably high tends to overstatetheprice impact ofthe regulatory alternatives. Finally, a 20-year commercial life for tanks was assumed in keeping with the analysis of Chapter 8. Parameters assumed in the use of Equation 9-1 include a model terminal throughput rate of 39 x 106kg/year and amodel VOL producer/consumer output of 80 percentof a production capacity of4.5 x 106 kg/year. Capital costs and operating expenses are taken from Chapter 8. Equation 9-1was solved both without and**~ith** adjustments allowing a $460/Mg emission savings creditto be subtracted from operating costs for each model plant. The $460/Mg figure is based upon aweighted average price of organic chemicals computed for 1978 production and prices as inflated to 1982 dollars by a chemical producers

9-35price index.* The projectedprice impacts on 

### VOL storage services of the regulatory a1ternatives with and without the emission savings credit are shown in Table 9-16. As was anticipated, the price impacts increasewith increases in the stringency of the regulatory alternatives. Recognition of the value of emission savings reduces the price impacts somewhat. To help place these values in perspective, the price impacts were divided through by the estimatedproductprice and multiplied by 100 to obtain estimates ofthe percentage change in theproductprices for the two model plants. S460/Mg was used to estimate theproduct price ofthe model producer/consumer and $0.01/kgwas used as the average storage charge of the model independent terminal. This later value is based upon an estimated capital cost of the model terminal, inclusive of land and tank foundations, of$1.72 x 106 1982 dollars and operating costs equal to 7percentof the capital costs. The 1¢/kg figure was determined by applying these costs to Equation 9-1 and solving for price. This capital cost is probably very conservative since itexcluded the purchase and installation cost ofpumps, piping, gauges, etc., that ordinarily constitute a substantial portion of the capital expenses of a storage terminal. If higher capital costs were used, the computed price of storagewould be higher, and the percentage change inprice due to the regulatory alternatives would be even lower. Table 9-17 presents the estimated percentage changes in

### VOL storageprices and 

### VOL output prices. These percentages are very small for the model producer/
consumer since 

### VOL storage is such a small part of his costs. The percentage change in the average price of storage at the model terminal is somewhat higher, ranging from 3.7 to 4.3percent for RegulatoryAlternatives 

### I through 

### IV and 11.8percentfor Regulatory Alternative

### Vwithan emission savings credit. 9.2.2 Investment Impacts The investment impacts of the regulatory alternatives for the model plant and 

### VOL storage industry are provided below. 9.2.2.1 Model Plant Investment Impacts. As reported in Chapter 8, the installed capital costof

### VOL storage tanks alone for the model terminal is *The 1978 weighted average pricewas obtained from Reference 24. Inflation to

1982 was performed using the Industrial Chemical Procedures PriceIndex from the Chemical Engineering Journal. The adjustment is documented 

### in Reference 33.

9-36RegulatoryTABLE 9-16. PRICE IMPACTS OF THE REGULATORY ALTERNATIVES FOR THE MODEL TERMINAL AND MODEL PRODUCER/CONSUMER
Model independent Model producer/ terminal consumer

(¢/kg) (¢/kg) Without With Without With emission emission emission emission

savings savings alternative credit**saving~** credit credit**saving~** credit

I 0.049 0.037 0.15 0.11 II 0.050 0.038 0.17 0.11 

### III 0.051 0.038 0.20 0.11 

### IV 0.056 0.043 0.23 0.14



## v 0.132 0.118 0.72 0.63
aThe emission savings credit is calculated in Chapter 8 based on a price

for VOL of $460/Mg ($ 1982).

g
...37

### TABLE 9-17. 

### PERCENTAGE CHANGE IN OUTPUT PRICE FOR THE MODEL PLANTS DUETO THE REGULATORY ALTERNATIVES

Model independent Mode1 produEer/ terminala consumer Without With Without With emission emission emission emission Regulatory savings savingc savings savingc alternative credit credit credit credit

I 4.9 3.7 0.3 0.2 II 

### 5.0 3.8 0.4 0.2 

### III 5.1 3.8 0.4 0.2 IV 5.6 4.3 0.5 0.3



## v 13.2 11.8 1.6 1.4
aThe averageprice of storageper kg was assumed tobe $0.01 ($ 1982). bThe average price ofVOL was assumed to be $460/Mg ($ 1982). cThe emission savings credit is calculated in Chapter 8based on a price



### ofVOL_of $460/Mg ($ 

### 1982).

9-381.07 million in 1982 dollars. The installed capital cost of the storage tanks alone of the model chemical producer/consumerwas estimated to be 0.25 million 1982 dollars. Incremental capital costs were computed for each of the model plants for each of the regulatory alternatives. These costs, previously presented in**Chap~er** 8, are consolidated in Table 9-18. They show additional investment requirements of between 56 and 185 thousand 1982 dollars for the independentterminal and between 16 and 91 thousand 1982 dollars for the model producer/consumer ofVOLs. 9.2.2.3 Hationwide Investment Impacts. Nationwide impacts depend on the volume and vaporpressure characteristics of new tanks in each year of analysis. Therefore, the first step in the estimation of the nationwide investment impact of regulatory alternatives is to estimate the number of new tanks thatwould be subject to VOL regulations byyear, t; by volume interval, i; and by pressure interval, p. As described in Subsection 9.1.7, this is done by scalar multiplication of each of the annual projections of new tanks from Subsection 9.1.7 by a percentage distribution table containing estimates ofthe percentage of tanks ineach volume and pressure interval based upon the 1977 survey of VOL storage tanks.27'28 The resulting values,

### T~P, are the number ofVOL tanks inyear t, volume interval i, and pressure interval pthat are projected to be subjectto regulation. In conjunction with the baseline conditions of Chapter 3, these values
arethen used to estimate the impacted tankpopulation of each regulatory alternative. The impacted tankpopulation is thatportionof the new tank population in any yearthatwill actually undergo design changes and experience cost increases under each regulatory alternative. The impacted tankpopulation for any regulatory alternative, year, and volume interval is found by summing

### T~p values over appropriate pressure intervals and by scaling by appropriate baseline assumptions. For example, the summation overvapor pressures for the volume interval 95 m 3 to 115 m 3 under Regulatory Alternative I excludes VOL tanks whose vapor pressures are less**than~** 3.5 kPa because they are lower than the 3.5-kPa baseline cutoff. In addition, this summation scales the number of remaining tanks inthe volume interval by 0.65 because the baseline assumes that 35 percent of the new VOL storage tanks in that interval would be builtwith internal floating roofs even without Regulatory Alternative I. The resulting value,

### T~, is the estimated number of tanks in volume interval i and year t that are impacted by Regulatory Alternative I.

9-39

### TABLE 9-18. INVESTMENT IMPACTS OF REGULATORY ALTERNATIVES FOR THE MODEL INDEPENDENT TERMINAL AND MODEL PRODUCER/ CONSUMER (103 

### $1982) Re9ulatory Model independent Model producer/ alternatives terminal consumer
3c.seline 1,070.0 250.0 I 56.0 15.8 II 

### 56.6 16.0 III 56.6 16.0 IV 71.8 23.2 

### v 184.8 90.8

9-40Table 9-19 shows the tankpopulation impacted by Regulatory Alternative I
as a percent of the projected new VOL storage tankpopulation. Of course, the actual number oftanks impacted will vary by year. Table 9-20 presents similar data for Regulatory Alternatives II through V. The percentages are the same for each ofthese four regulatory alternatives because they cover the same volume and pressure ranges and because the baseline conditions assume that
none ofthese technologies would have otherwise been adopted. Calculationof

### T~ is therefore based on the number of new storage tanks projected in Subsection 9.1.7. The projections were developed in the absence of
an NSPS for storage tanks. With higher prices for aproduct, due, for example to an NSPS, quantity demanded typically decreases. The decision to treat demand as constant in any givenyear is based upon the following analysis. Apure number calledthe elasticity of demand can be used to relate changes in the price of tanks to changes in the quantity of tanks demanded. More specifically, the elasticity of demand for tanks,**~T'** is the ratio of the proportionate change in quantity due to a proportionate change in pricewhere otherprices, technology, etc., are held constant.* AlfredMarshall proposed four determinants ofthe demand elasticity for any factor ofproduction, such
as VOL storage tanks, within an industry. As modified to reflect a two-factor, constant-returns-to-scaleproduction technology by Layard and Walters,34 the

- price elasticity,**~T'** ofVOL production, consumption, or storage varies directlywith the following: 1. The elasticity of demand**C~v)** for VOLs, VOL products, or VOL storage. 2. The elasticity of substitution, ST Y' question, T, and the other factor, Y. ' between the factor in
3. The share of tanks in the production cost so long as the elasticity of demand for VOLs, VOL products or VOL storage,**~V'** exceeds the elasticity of substitution of the factors, ST y· 

### , 4. The supply elasticity of the other factor, Ey, used to produce VOLs, VOL products, orVOL storage.
*The elasticityof demand is sometimes referred to as the own-price elasticity

of demand to distinguish it from the influence of otherprices and income changes that can affect demand. Itmay be defined mathematically as 

## = oTD

.

### f ,where Tn is the rate atwhich tanks are demanded and Pis nT 

### aP T the**pri~e** of tanks.

9-41TABLE 9-19. THE NEW TANK POPULATION IMPACTED BY REGULATORY ALTERNATIVE I AS APERCENTAGE OF THE PROJECTED NEW TANK POPULATION
Tank volume (m3)a
75b to 95 95 to 150 150 to 375 375 to 3,750 3,750 to 15,000 >15,000 Percentage of new tankpopulation Tanks with vapor pressure Tanks with vapor pressure

between 3.5 and 10.3 kPa greaterthan 10.3 kPa
2.73c 1.47c 1.85 0 2.95 0 0.46 0 0.05 0
aThe sixvolume intervals presented here are aggregates. Calculations

areperformed using the correspondingpercentages from the 24 volume intervals ofthe 1977 survey.27•28 bTanks with volume less that 75 m 3 are below the minimum cutoffpoint consideredfor Regulatory Alternative I. cThe percentages of projected new tankpopulation for tanks with volume

capacities between 75 and 95 m 3 and between 95 and 150 m 3 are for all tanks having vapor pressure greaterthan 3.5 kPa.

9-42TABLE 9-20. THE NEW TANK POPULATION IMPACTED BY REGULATORY ALTERNATIVES II-V AS APERCENTAGE OF THE PROJECTED NEW TANK POPULATION Percentage of new tankpopulation Tank volume (m3)a Tanks with vapor pressures Tanks with vapor pressures

75b to 95 95 to 150 150 to 375 375 to 3,750 3,750 to 15,000 >15,000 between 3.5 and 10.3 kPa greaterthan 10.3 kPa

2.85 4.56 0.71 0.07 2.53d 6.22d 1.19d

.0.19d

aThe sixvolume intervals presented here are aggregates. Calculations

areperformed using the correspondingpercentages from the 24 volume intervals ofthe 1977 survey. 27•28 bTanks with volume less that 75m3 are below the minimum cutoffpoint

sideredfor this Regulatory Alternative I. concThe percentages of projected new tankpopulation for tankswith volume

capacities between 75 and 95 m 3 and between 95 and 150 m 3 are for all tanks having vapor pressure greaterthan 3.5 kPa. dThe baseline control assumptions specifythattanks with volume greater

than 150 m 3 and vapor pressures greater than 76 kPa have vapor control systems or are pressure**~essels.** Since the upper vapor pressure interval ofthe 1977 sample intervals covered all tanks with vaporpressures greater than 59 kPa, therewas no basis in the sample datato distinguish between tanks in that interval with vapor pressures greater than 76 kPa and those with vapor pressure less than 76 kPa. Aworking assumption that all the tanks in the upper interval had pressures between 59 and 76 kPa was adopted. Only a small number oftanks was affectedby the assumption (0.22percent of thetotal VOL tankpopulation).

9-43

### The lower these factors, the lower nT and, consequently, the less the quantity oftanks demanded will adjustto changes in the price of tanks. Each of these four considerations is discussed below for VOL storage tanks. First, as suggested by the relatively stable physical output in the face of rapidly rising prices in the industrial organic chemicals and plastics industries during the late 1970s (seeTables 9-4 and 9-5), the demand elasticity for VOLs, as a group, is probably fairly small. The qualifier 11

### as a group11 

### is**i~portant** in 

### this context sincemost substitutes for the VOLs that do have good substitutes in particularapplications are also likelyto be VOLs. Storage of the substitutes would therefore also be subjectto the standards. Second, the elasticityof substitution for bulkVOL storage is very small because alternative, low-cost means of providing the same service is not readilyapparent.* This is especiallythe case with terminals since storage is theirprincipal purpose. Most bulkVOL storage tanks either already have been or, under the regulatory alternatives, are about to be affectedby standards of this type. Therefore, it is not feasible to substitute uncontrolled tanks for controlled tanks. The cost advantage enjoyed by large tanks (see Chapter 8) 

### probablywill also sharply limit substitution of uncontrolled small-volume tanks for the large-volume tanks affectedby the regulatory alternatives. Finally, VOL storage service is a crucial part ofthe production and consumption ofVOLs in that it is nearly a fixed component of aplant design. Third, the share ofVOL storage costs in the production ofVOLs orVOL products is also likelyto be small. Inthe model producer/consumerplant described in Chapter 6, 

### capital costs forVOL storage comprise between 2 

### and 11 percent of total capital costs (depending on the regulatory alternative) and atmostjustover 1percentot total annual capital and operating costs. However, inthe case ofVOL storage terminals the share oftankcosts in total costs is likelyto be somewhat higher. Fourth, although the elasticityof supply for other factors used with VOL storagetanks ismore problematic, recentworld experience suggests that for *The elasticityof substitution is ameasure of the proportionate change in

the use of different factors ofproduction in response to a proportionate change in the price ratio of those factors. In effect, itmeasures the feasibility and desirability of substituting one factor for another. There are a number.ofdifferentexpressions for the elasticityof substitution, all fairly cumbersome. The interested reader is referred to Reference 34.

9-44at least in one critical input category for VOL producers, that ofpetroleum feedstocks, the supply is relativelyprice inelastic.* Based upon these considerations, this economic impact analysis adopts the working assumption that the demand for VOL storage tanks is perfectly inelastic within the range of relevant tankprices. This demand condition is depicted in Figure 9-2 as demand curve D. In the event of a rise in theprice oftanks from Pto P', the demand for tanks and, hence, the number of impacted VOL stori age tanks will remain unchanged at the rate Tt peryear. This characterization of tankdemand is recognized to be extreme in the sense that, as noted above,
one usually observes at least some reduction in demand in response to price increases for most commodities. However, there are no publicly available data
on the prices and quantities ofVOL storage tanks that can be used to estimate the elasticity of demand for storage tanks. Furthermore, if demand is treated
as perfectly inelastic, the likely direction of any error associatedwith this assumption is known. That is, the impact of each ofthe regulatory alternatives
on the cost ofVOL storage is overestimated since if any nonzero elasticity of demand is used fewer new tanks would be projected and subject to the standards and additional cost. As illustratedby demand schedule 02 in Figure 9-2, the economic analysis allows for economic growth by specifying a shift in the demand for VOL storage tanks over time. As the economy grows, therewill be some growth in the demand for VOL chemicals and, hence, for new and rep1acement VOL storage tanks. The magnitude ofthis growth between periods t and t+l is reflected in the demand curves for the respective periods and the differenceTi+l

-

### T~ . The 5 percent growth rate in new tank capacity demand and the tank replacement schedule, adopted for theprojections in Section 9.1, are also adopted as the quantitative basis for these shifts in demand. As discussed above, data on the impacted VOL tankpopulation for each regulatory alternative, year, pressure interval and volume interval determine the value

### ofT~ in Figure 9-2. The regression equations of cost against volume estimated in Chapter 8for each regulatory alternative are then used to deter- *The elasticity of supply is defined analogously to the elasticity of demand:

the ratio of a proportionate change in the quantity supplied to a proportionate change in the supply price. For a discussion see Reference 35.

9-45mine the change in theprice of a tank in thatvolume interval, p• - P.* Multiplying

### T~ by p• - Pgives an estimate ofthe area P1abP in Figure 9-2. This is the estimated investment impact, in 1982 dollars, of the particular regulatory alternative in question on tanks in the given volume interval in theyear t. These values are then summed over all the volume intervals to obtain the nationwide investment impact of the regulatory alternative inyear t. Finally, annual investment values for theyears 1984-1988 are summed to obtain an estimate of the cummulative nationwide investment impact for the projection period. Table 9-21 presents the resulting data on nationwide investment impacts for each regulatory alternative using this methodology. For comparison, the estimated investment in new VOL tanks covered by the baseline conditions (>75
m

3 and >3.5 KPa) exclusive of vapor recovery equipment orpressure vessel costs is also included. The investment impacts for Regulatory Alternatives II and III are the same because they are estimated in Chapter 8 to have the same impact on the cost of a tank. 9.2.3 Nationwide Annualized Cost Impacts The total annual cost of each of the regulatory alternatives is dependent
on the number of new tanks put in place over the fiveyearperiod and the change in the annualized cost ofeach tank. The annualized cost represents the annual financial obligations imposed by the regulatory alternative on purchasers of VOL storage tanks. In particular,**fifth-y~ar** costs include payments relatedto the regulatory alternatives inthe fifthyear for debt and operating expenses associatedwith tanks purchased in each of the 4previous years as well as those expenses newly incurreddue to tankpurchases in the fifthyear. These costs, in constant 1982 dollars, are presented in the second column of Table 9-22. They range from 3.3million dollars for RegulatoryAlternative I tojustover 26 million dollars for Regulatory Alternative V. *The change in price in this analysis is equivalent to a change in cost since

tank fabricators will not contractto build new tanks unless their costs are covered by theprice (see subsection 9.2.1 above). For those regression equations expressed in terms ofdiameter, an equivalent volumetric relationshipwas derived using a correspondence between diameter and height suggested by Reference 36. The change inthe costorprice for any volume interval is estimated by using the mid-point ofthat interval in the regression equation. For the interval that is unboundered (>15,000 m 3), a volume of20,000 m 3 was used.

9-46TABLE 9-21. ADDITIONAL NATIONWIDE INVESTMENT IN VOL STORAGE REQUIRED BY THE REGULATORY ALTERNATIVES, 1984-1988
Estimated investment Additional b under baselin5 nationwide investment assumptionsa, ($106
, constant 1982 dollars) ($106
, constant Year 1982 dollars) I II & III 

### IV 

## v
1984 41.94 2.70 2.75 4.70 21.67 1985 43.86 2.87 2.93 4.96 22.69 1986 44.31 2.93 2.99 5.04 22.97 1987 45.92 3.07 3.14 5.27 23.84 1988 52.04 3.39 3.46 5.86 26.84 1984-1988 224.57 14.84 15.16 25.54 116.13

aan estimate of the nationwide investment thatwould be made in newtanks

with volumes >75 m 3 containing liquids with vapor pressures >3.5 kPa without implementation of any of the regulatory alternatives. This estimate is exclusive of any investment in vapor recovery equipment or pressure vessels. bAnnual values are not dicounted to the present.

9-47Regulatory alternative


### I II 

### III

IV



## v TABLE 9-22. FIFTH-YEAR NATIONWIDE ANNUALIZED COST OF THE REGULATORY ALTERNATIVES Fifth-year annualized cost ($106
, constant 1982 dollars) Without With emission emission

savings savinga credit credit
3.25 -0.56 3.34 -0.67 3.34 -1.01 6.11 1.68 26.14 21.61
aCredit computed using a

### VOL price of $460/Mg.

9-48As discussed above, the tanks impacted by the regulatory alternatives will also generate some additional economic benefits for tank users because they reduce vaporization ofvaluable VOLs. The tank owners are betteroffby the amount of emissions reductions times the value ofthe chemical saved. Nationwide emissions reductions for each regulatory alternative in the fifth year after promulgation are estimated in Chapter 7. The $460/Mg estimate of the value ofVOL was applied to these emissions reductions to obtain an estimate ofthe nationwide economic benefit ofthis emissions reduction to VOL tankusers in 1988. The resulting emission savings creditwas then applied against annualized costs; the results are shown in column 3ofTable 9-22. On
a nationwide basis, the first three regulatory alternatives produce net economic benefits in 1988 when an emission savings credit is included in the calculation. The fact that the nationwide annual costs are negative is not inconsistentwith the finding ofpositive costs ofthese alternatives for the two model plants since the model plants were selected so as to exhibit a greater than average economic impact. 9.3 REGULATORY, INFLATIONARY, SOCIOECONOMIC, AND SMALL-BUSINESS IMPACTS 9.3.1 ExecutiveOrder 12291 Executive Order 12291 requires the conduct of a regulatory impact analysis (RIA) of a proposed regulation ifthe regulation is likely to result in 1. An annual effect on the economy of $100 million ormore. 2. Amajor cost orprice increase for consumers; individual industries; Federal, State, or local government agencies; or geographic regions. 3. Significant adverse effects on competition, employment, investment, productivity, innovation, or abilityof United States-based enterprises to compete with foreign-based enterprises in domestic or foreign markets. Estimated nationwide investment impacts on tankpurchases listed inTable 9-21 show that, for all years from 1983 through 1988 and all regulatory alternatives, the investment impactwould be substantially less than $100 millionper year. When the capital costs associatedwith the regulatory alternatives are annualized and credit is given for reduction in VOL vaporization, it is estimated that the first three regulatory alternatives actuallygenerate nationwide cost savings in 1988 (see Table 9-22). Regulatory Alternatives IV and V show nationwide annualized cost increases after credit for emission savings of

9-49$1.61 x 106 and $21.61 x 106
, respectively. These are very small figures compared to the investment and sales levels ofVOL storing industries. Percentage price increases for the model terminal are higher than those for a model producer/consumer but were still less than 5percent for Regulatory Alternatives I through IV afteremission savings credits. Regulatory Alternative Vwas estimated to increase the price of storage at the model terminal by 13.2percentwithout an emissions reduction credit and by 11.8percentwith such a credit. Based on these results, the proposed standards do not qualify as major regulatory alternatives under the criteria enumerated above: the annual effect on the economy is substantially less than $100 x 106
, the price impacts
are small, and the standardwill not have a significant effect on the operation ofthe domestic economy or its international trade. Therefore, a regulatory impact analysis and associated benefit/cost calculations need not be performed. While this is the case, itis still worthwhile to note, in a qualitative fashion, the benefits againstwhich the costs discussed above should be balanced. The standardswill reduce the rate of emission ofVOLs to the atmosphere. These compounds are precursors of photochemical oxidants, particularly ozone. The EPA publication Air QualityCriteria for Ozone and Other Photochemical Oxidants37 explains the effects of exposure to elevated ambient concentrations of oxidants. (The problem of ozone depletion of the upper atmosphere and its relationtothis standard are not addressed here.) These effects include 1. Human health effects. Ozone exposure has been shown to cause increased rates of respiratory symptoms such as coughing, wheezing, sneezing, and short-breath; increased rates of headache, eye-irritation and throat irritation; and increases in the number of red blood cells. One experiment links ozone exposure to damage to human chromosomes. 2. Vegetation effects. Reduced crop yields as a result of damges to leaves and/orplants have been shown for several crops including citrus, grapes, and cotton. The reduction in crop yieldswas shown to be linkedto the level of duration of ozone exposure. 3. Materials effects. Ozone exposure has been shown to accelerate the deterioration oforganic materials such as plastics and rubber (elastomers), textile dyes, fibers, and certainpaints and coatings.

9-50

### 4. Ecosvstem effects. Continued ozone expoure has been shown to be linked to the disappearance oftrees such as Ponderosa and JeffreyPines and death of predominant vegetation. Hence continuedozone exposure places a stress on the ecosystem. In addition to reducing the severityofthe physical and biological effects enumerated above, the regulatory action is likely to improve the aesthetic and economic value ofthe environment through, for example, beautification of natural and undeveloped land because of increasedvegetation, improved visibility, and reduced incidence of noxious odors. 9.3.2 The Regulatory FlexibilityAct The Regulatory FlexibilityAct requires the conduct of aregulatory flexibilityanalysis (RFA) if a substantial number of small firms are significantly adversely impacted by the regulatory alternatives examined. In Chapter 6, the model independentterminal and model producer/consumer were identified as small facilities. The economic impact of regulatory alternatives on these facilities was not found to be significant. 9.4 REFERENCES

1. Scherer, F.M. Industrial Market Structureand Economic Performance. Chicago, Rand McNally College Publishing Company, 1980. 2. Hegman, George B. In: World Outlook for Petrochemicals. Cambridge, Arthur D. Little, Inc., August 1978. p. 7. 3. U.S. Department of Commerce, Bureau of the Census. 1977 Census ofManufactures. Part 2, SIC Major Groups 27-34. U.S. Government Printing Office. Washington, DC. 1981. p. 28F-13. 4. 

### Booz, Allen, and Hamilton, Inc. Cost ofHydrocarbon Emissions Control to the U.S. Chemical Industry (SIC 28). ExhibitVI-6. Florham Park, 

### NJ. December 1977. 5. 

### U.S. Department of Commerce, Bureau of Economic Analysis. 1972 InputOutput Tables: Structure ofthe U.S. Economy. U.S. Government Printing Office. Washington, DC. 6. U.S. Department of Commerce, Bureau ofthe Census. 1972 Census ofManufactures. Volume 11, Industrial Statistics, Part 2, 

### SIC Major Group 27-34. U.S. Government PrintingOffice. Washington, DC. p. 28F-13-28F-15. August 1976. 7. Memorandum from Hart, Marge, National Association of Chemical Distributors, to Rockstroh, Margie, TRW, Inc. 1980. 8. Independent Liquid Terminals Association. 1982 Bulk LiquidTerminals Directory, 7th Edition. Washington, DC. 1982. 99 

### p. 9. Reference 3, 

### p. 28F-5, 288-5. 10. Fallwell, William F. Chemical Capital Spending to Turn up in 1979. Chemical and Engineering News. 56:10-12. December 11, 1978.

9-51

### 11. U.S. Department of Commerce, Bureau of the Census. Business Statistics, 1977. U.S. Government Printing Office. Washington, DC. 1979. p. 46. 12. Reference 6, p. 28F-5, 288-5. 13. Operating Rate. Chemical and Engineering News. 56:59. June 11, 1979. 14. U.S. International Trade Commission. U.S. Production and Sales--Synthetic Organic Chemicals (fortheyears 1955 through 1981). Table 1. U.S. Government Printing Office. Washington, DC. 15. U.S. Department ofCommerce, Bureau of Industrial Economics. 1982 U.S. Industrial Outlook. U.S. Government PrintingOffice. Washington, DC. January 1982. p. 102-103. 16. Reference 15, p. 120, 141, 316. 17. Radian Corporation. Organic Chemical Producers Data Base, 1976. Research Triangle Park, NC. Contract No. 68-02-2623. 1978. 18. Reference 6, p. 28F-8, 28F-9. 19. Reference 3, p. 28F-7, 28F-8. 20. Reference 6, 

### p. 288-7, 288-8. 21. Reference 3, p. 28B-8, 28B-9. 22. U.S. Department of Labor, Bureau of Labor Statistics. Producer Prices and Price Indexes. Supplements 1978-1982 (data for 1977 to 1981). U.S. Government Printing Office. Washington, DC. 23. U.S. Environmental ProtectionAgency. VOC Fugitive Emissions in Synthetic Organic Chemicals Manufacturing Industry-Background Information for Proposed Standards. Research Triangle Park, NC. EPA-450/3-80-033a. November 1980. p. 9-1-9-36, E-1-E-11. 24. U.S. Environmental Protection Agency. Fugitive Emission Sources of Organic Compounts--Additional Information on Emissions, Emission Reductions, and Costs. Research Triangle Park, NC. EPA-450/3-82-010. April 1982. p. A-1-A-23. 25. Federal Reserve Statistical Release Industrial Production, G.12.3. Board ofGovernors ofthe Federal Reserve System. Washington, DC. 1954-1977 (monthly). 26. Predicasts, Inc. Predicasts Basebook. Cleveland, OH. 1960-1980. 27. Hydroscience, Inc. Emissions Control Options for the SyntheticOrganic Chemicals Manufacturing Industry: Storage Handling Report. Knoxville, TN. March 1979. 28. Letter from Rockstroh, M.A., TRW, Inc., to Smith, V., RTI. July 10, 1980. 29. Telecon. Anderson, Don, RTI, with Greek, Bruce, American Chemical Society. October 29, 1982. 30. Telecon. Anderson, Don, RTI, with Pfann, Harry, Department of Commerce. October 29, 1982. 31. Letter from Rockstroh, M.A., TRW, toMoody, W.T., TRW. February 1, 1980. 32. Radian, Inc. The Revised Organic Chemical Producers Data Base System, Final Interim Report. Austin, Texas. EPA Contract No. 68-03-2623. March 1979.
9-5233. Letter from Shumaker, J., TRW, to Morris, G.E., RTI. January 3, 1983. 34. Layard, P.R.G., and A.A. Walters. Microeconomic Theory. New York, McGraw-Hill Book Company, 1978. p. 260-270. 35. Reference 33, p. 221-230. 36. Memorandum from Moody, W.T., TRW, to Morris, G.E., RTI, December 17, 1982. 37. Air Quality Criteria for Ozone and other Photochemical oxidants. 

### U.S

.. Environmental Protection Agency. Publication No. EPA-600/8-78-004. April 1978.

9-53

### APPENDIX A - EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENTA1. Literature Review November 1978

November 22, 1978

December 1979

January 1980
January 1980
January 1980
January 1980

January 1980
January 1980

January 1980 Hydroscience Inc. Emission Control Options for the Synthetic Organic Chemicals Industry

- Storage and Handling Report, October, 1979. Letterwith attached report from Kern, R. C. November 22, 1978, Ultraflote, to R. K. Burr, EPA:CPB, Hydrocarbon Emission Loss Measurements on a 20 Foot Diameter PilotTestTankwith an Ultraflote and a CBI Weathermaster Internal Floating Roof. Letter and attachment from Lee, B., Radian Corporation, to Moody, W. T., TRW:EED. November 30, 1979. Letter transmitting updated version ofthe report generated August 1978 from the Organic Chemical Producers Data Base. Evaporation Loss in the Petroleum Industry

- Causes and Control, Evaporation Loss Committee, American Petroleum Institute, February 1959. Evaporation Loss from Floating-RoofTanks, Evaporation Loss Committee, American Petroleum Institute, February 1962. Petrochemical Evaporation Loss from Storage Tanks, Division of Refining, American Petroleum Institute, November 1969. Venting Atmospheric and Low-Pressure Tank (Nonrefrigerated and Refrigerated), Refining Department, American Petroleum Institute, December 1973. Use of Internal Covers and Covered Floating Roofs to Reduce Evaporation Loss, American Petroleum Institute, 1976. Measurement and Determination ofHydrocarbon Emissions in the Course of Storage and Transfer in Above-Ground Fixed Cover Tanks With and Without FloatingCovers, BMI-DGMK Projects 4590-10 and 4590-11, Translated for EPA by Literature Research Company, 1976. Hydrocarbon Emissions from Floating Roof Petroleum Tanks, Western Oil and Gas Association, January 1977.



### A-2January 1980

February 1980

February 1980
February 1980
February 1980

April 1980

March 1980
June 1980

June 1980

June 1980

June 1980 Cost of Hydrocarbon Emissions Control to the U.S. Chemical Industry (SIC 28), Volumes I and II, Manufacturing Chemists Association, December 1977. Control ofVolatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks, EPA-450/2-77-036, EPA:CPB, December 1977. Evaluation ofHydrocarbon Emissions from Petroleum Liquid Storage, EPA-450/3-78-012, R. K. Burr, EPA:CPB, March 1978. Suggested Emission Factors for Fixed-Roof StorageTanks, A. L. Wilson, EngineeringScience, Inc., November 13, 1978. Control ofVolatileOrganic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks, EPA-450/2-78-047, EPA:CPB, December 1978. The Revised Organic Chemical Producers Data Base System, EPA ContractNo. 68-02-2623 (Radian Corporation), A. Jefcoat, EPA:IERL, March 31, 1979. Comments on the 11BMI-DGMK11 Report, J. Zabaga, Mobile Oil Company, June 16, 1978. Bulk Liquid Terminals and Storage Facilities, Independent LiquidTeTminals Association, 1979 (Directory). Emissions Control Options for the Synthetic Organic Chemicals Manufacturing Industry, Thermal Oxidation, (Draft), EPA Contract No. 68-02-2577, EPA:ESED, December 1979. Emissions Control Options for the Synthetic Organic Chemicals Manufacturing Industry, Carbon Adsorption (Draft), EPA Contract No. 68-02-2577, EPA:ESED, February 1980. Emissions Control Options for the Synthetic Organic Chemicals Manufacturing Industry, Thermal Oxidation Supplement (Draft), EPA ContractNo. 68-02-2577, EPA:ESED, February 1980.

A-3A2. Information from Other Sources January 1979

April 1979

September 1979

October 1979

December 1979

December 1979

March 1980

March 1980

March 1980
April 1980 H. F. Ellenburg, Instrumentation Products Co., to l. Hayes, TRW:EED, December 20, 1978, letter with enclosed information on vapor recovery systems for storage tanks and solventtransfer facilities. T. W. Mix, Merix Corporation to R. K. Burr, EPA:CPB, April 21, 1979, letterwith enclosed summary print-out of input and output losses of above-ground gasoline tanks on farms. B. Lee, Radian Corporation, toW. T. Moody, TRW:EED, August 31, 1979, Letterwith enclosed information from the Organic Chemical Producers Data Base. J. 

### K. Walters, American Petroleum Institute, to R. 

### K. Burr, EPA:CPB, September 14, 1979, letter with enclosed technical comments of the American Petroleum Institute on the draft report "Measurement ofBenzene Emissions from a Floating RoofTest Tank." M. Rutland, GATX, toR. Guidetti, TRW:EED, December 3, 1979, letterconcerning budgetary prices for standardAPI-650 Cone RoofTanks and Floating RoofTanks. E. B. Dees, TRW:EED, toM. R. Frega, Frega Associates, Inc., December 6, 1979, Letter requesting information to be used in an industry profile for volatile organic liquids storage. H. Reiss, Altech Industries, Inc., to G. May, TRW:EED, February 26, 1980, letterwith summarized budget price information. T. P. Tremblay, Chicago Bridge

### &Iron Company, toW. T. Moody, TRW:EED, February 27, 1980, Letterconcerningprice differentials Weathermaster Floating RoofTank versus cone roof tank-revision 1.0. T. T. Fung, Systems Division, to M. A. Rockstroh, TRW:EED, March 14, 1980, Letterconcerning acetone storage tank emissions control study. J. J. Dechant, Brown Boiler

### &TankWorks,/Ltd., toTRW:EED, March 27, 1980, Letterconcerning quotationwith budget figures in orderto erect acetone storage tanks. A-4May 1980

May 1980

June 1980

June 1980

June 1980

June 1980

July 1980

July 1980

October 1982 to December 1982 January 1983 J. R. Farmer, EPA:CPB, to R. L. Stuart, Monsanto Company, April 28, 1980, Letter with enclosed background information to supportthe volatile organic liquids regulation with attached list of addressees. Comments on the Volatile Organic Liquids Background Information, H. D. Kerfman,GATX, May 1980. L. P. Hughes, Mobay Chemical Corporation, toW. T. Moody, TRW:EED, May 29, 1980, Letterwith enclosed responses regarding possibletankemission recovery systems. Dr. F. S. Lisella, Department of Health and Human Services, to

### J. R. Farmer, EPA:CPB, June 2, 1980, Letter commenting on the draft copy ofVolatile Organic Compound Emissions from Volatile Organic Liquid StorageTanks. R. E. Kinghorn, R.F.I. Services Corp., to W. T. Moody, TRW:EED, June 9, 1980, Letter concerning prices for conventional cone roof tanks constructedto API 650 code. T. P. Tremblay, Chicago Bridge

### &Iron Company, toW. T. Moody, TRW:EED, June 22, 1980, Letterconcerning price differentials Weathermaster Floating Roof Tank versus cone roof tank. 

### R. Harrison, Western Oil and Gas Association, to J. R. Farmer, EPA:ESED, June 27, 1980, Letter commenting on the draft document "VolatileOrganic Compound Emissions from Volatile Organic Liquids StorageTanks. 11 J. K. Walters, American Petroleum Institute, to J. R. Farmer, EPA:ESED, June 30, 1980, Letter commenting on the draft document 11Vo1 atile Organic Compound Emissions from Volatile Organic Liquids Storage Tanks. 11 Updated costs of control equipment obtained from 15 vendors. W. F. O'Keefe, American Petroleum Institute (API) to S. R. Wyatt, EPA:ESED, Letter concerning emissions calculations (including final API Bulletin 2519 evaporation loss from internal floating roof tanks). 

### A-5A3. Emission Source Measurement May 1979

June 1979
August 1979

March 1982 Emission Measurements on a Floating Roof PilotTestTank, R. J. Laverman, Chicago Bridge

### &Iron Company, May 16, 1979. Measurement ofBenzene Emissions from a Floating RoofTestTank, EPA-450/3-79-020, R. K. Burr, EPA:CPB, June 1979. Hydrocarbon Emission Measurements of Crude Oil on the 20 Foot Diameter Floating Roof PilotTestTank, 

### R. J. Laverman, Chicago Bridge

### &Iron Company, August 15, 1978. Testing Program toMeasure Hydrocarbon Emissions From AControlled Internal Floating RoofTank, for American Petroleum Institute Committee on Evaporative Loss Measurement TaskGroup 2519, 

### R. J. Laverman, T. 

### J. Haynie, and J. F. Newbury, Chicago Bridge

### &Iron Company, March 1982.

A-6A4. Plant and Other RelatedTrips November 14-17, 1978
November 15, 1978

November 15, 1978 August 14, 1980 August 20, 1980 August 21, 1980 August 26, 1980 Trip to Hydroscience Inc., to discuss data base and Phase I report. Trip to Exxon Chemicals, Baton Rouge, Louisiana, to obtain information on the rail car loading facility. Trip to Gilmore Maxine Services, Baton Rouge, Louisiana, to inspecta barge cleaning facility. Trip to Conoco Chemical, Baltimore, Maryland, to inspect avapor recovery system. Trip to Vulcan Materials, Geismar, Louisiana, to inspect avapor recovery system. Trip toAmoco Chemical, Texas City, Texas, to inspect a vapor recovery system. Trip to Dow Chemical, Midland, Michigan, to inspect two vapor recovery systems.

A-7AS. Meetings with Industry March 20, 1979
August 9, 1979
September 2, 1982

December 15, 1982

January 26, 1983 Meeting with Dow Chemical Corporation to discuss small vessel**(~20,000** gallon) control techniques and industrytrends. Meeting with the Chemical Manufacturers Association to discuss the regulatory approach and control technologies. Meeting with the American Petroleum Institute to discuss 1) the analytical approach used by API in developing storage vessel emission factors for the Bulletin 2519 11Evaporative Loss from Internal Floating RoofTanks"; 2) the EPA approach for emission factors development; and 3) the effect of roof configuration upon emissions. Meeting with the American Petroleum Institute to discuss EPA study and review of internal floating roof vessel emissions and the API testingprogram. Meeting with the American Petroleum Institute (API) to discuss the new API testing preliminary data available on floating roof vessel emissions.

A-8A6. Reports and Review Process December 14, 1978

January 29, 1979

March 14, 1979
August 1979 November 29, 1979
January 18, 1980

March 26, 1980
June 20, 1980 October 1980 December 3, 1980
December 1980 April 2, 1981 October 1981
March 1983 J. L. Shumaker, EPA:CPB, toV. Smith, Research Triangle Institute, Letterconcerning the finalization of SOCMI tobe used in all generic standards. E. C. Pulaski, TRW:EED, toV. Smith, Research Triangle Institute, Letterwith enclosed model facilities for synthetic organic chemical storage facilities. R. C. Weber, EPA:CPB, to E. Pulaski, TRW:EED, Letter confirming deletion of Handling portion or SOCMI Storage and Handling NSPS. Decision to expand SOCMI storage to VOL. W. T. Moody, TRW:EED, to the Volatile Organic Liquids Docket Files, Memo with an attached selection ofModel Facilities. W. T. Moody, TRW:EED, to the Volatile Organic Liquids Docket Files, Memo concerning tanks involved in industrial organics. Model Plants and Regulatory Alternatives are finalized. Decision on the basis ofthe standard. Working Group Review. National Air Pollution Control Techniques Advisory Committee Meeting. Steering Committee Review. AssistantAdministrator Review. Package withdrawn from reviewprocess and returned to OAQPS. Steering Committee review of the revised standardbased upon newly available emissions information.



### A-9

### APPENDIX B - INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONSOJ I N Table B-1. INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS Agency Guidelines for Preparing LocationWithin the Background Information Document (BID) Regulatory Action Environmental Impact Statements (39 FR 37419)
1.

2. Background, description, and purpose ofthe regulatory alternatives and the statutory authority. The relationship to other actions and proposals significantly affected by the regulatory alternatives. Industry affectedby the regulatory alternatives. Specificprocesses affected by the regulatory alternatives. Applicable control technologies

Alternatives to the action. The regulatory alternatives from which standards will be chosen are summarized in Chapter 1, Section 1.1.

To the extentpossible, otherEPA regulations and OSHA regulations which apply to the affected industries are detailed in Chapter 8, Section 8.5 and are considered in the economic impact study in Chapter 9. The industry and emission sourceswithin the industry affected by the regulatory alternatives are listed in Chapter 3. The specific processes and facilities affectedby the regulatory alternatives are summarized in Chapter 3, Section 3.2. The control technologieswhich can be applied to reduce VOC emissions from storage tanks and the emission reductions which have been achieved by these control technologies are described in detail in Chapter4. The various categories of alternatives to the actions which were considered are listed below.

a. Alternative regulatory approaches. The alternative approaches for regulatingVOC emissions under Section 111 of the Clean Air Act are outlined in Chapter 6. b. Alternative control devices. The alternative control devices that could be required by the regulatory alternatives and the reasons for selecting these particular alternatives are outlined in Chapter4. (continued)OJ I w Agency Guidelines for Preparing Regulatory Action Environmental Impact Statements (39 FR 37419) Agency's comparative evaluation ofthebeneficial and adverse environmental, health, social, and economic effects ofeach reasonable alternative.

3. Environmental impact ofthe regulatory alternatives.

a. Primary impact. Primary impacts are those that can be attributed directly to the action, such as reduced levels of specific pollutants brought about by a new standard and the physical changes that occur in the various media with this reduction. Table B-1. Continued
LocationWithin the Background Information Document (BID)

a. Adiscussion of the Agency's comparative evaluation of the various alternative regulatory approaches for VOC emissions from VOC storage vessels can be found in Chapter 7, 8, and 9.
b. Asummary ofthe beneficial and adverse environmental effects of the regulatory alternatives can be found in Chapter 7. Adetailed description ofthe costof each alternative control level, including the capital and annualized costs, can be found in Chapter 8. The socioeconomic impacts of the regulatory alternatives includingpotential plantclosures and maximum price increases in consumer products, can be found in Chapter 9.

Air impact analysis shows theprimary impacts in Chapter 7, 'section 7.2.

(continued)OJ I +::> Agency Guidelines for Preparing Regulatory Action Environmental Impact Statements (39 FR 37419)
b. Secondary impact. Secondary impacts are indirect or induced impacts. For example, mandatory reduction of specific pollutants brought about by a new standard could result in the adoption of control technology that exacerbates anotherpollution problem and would be a secondary impact. 4. Other considerations.

a.

b. Adverse impacts which cannot be avoided should a regulatory alternative be implemented.

Irreversible and irretrievable commitments of resources that would be involvedwith the regulatory alternatives, should one be implemented. Table B-1. Concluded

LocationWithin the Background Information Document (BID)

Other environmental impacts of the individual controls that can be used tomeet the regulatory alternatives are identified qualitatively in Chapter 7, Sections 7.3, 7.4, and 7.5. The secondary water impacts of the alternative control levels are quantified in Chapter 7, Section 7.3. The energy consumption impact of the alternative control levels is quantified in Chapter 7, Section 7.4.

Asummary of the potential adverse environmental and health impacts of the regulatory alternatives and a discussion of the significance of each impact can be found in Chapter 7. ·Factors which already existto eliminate some of the potential adverse impacts are identified. Those adverse impacts that are unavoidable are also identified, along with any steps which can be taken tominimize them. Irreversible and irretrievable resources thatwould be involved in the proposed action are discussed in Chapter 7, Section7.5.1.eNVIRONMENTAl' PROTECTION**AG~NCY** DALLAS, TEXA**~** 

# LIBRARYl.a.u.·u.

- TECHNICALREPORTDATA "•n

...**'••v•~:rwfA** (PleasereadJnsrrucnonsu•: therc1aubeforecomplrringl (:JRQTfCTION REPORTNO. ,2. 3 RECIPIENT'SACCESSION NOAGENCY



### EPA-450/3-81-003a

--- TITLE ANDSUBTITLE 5 REPORT DATE • ' ! I**~C'** 'lT)(A

• "'o< ,..**~:,** ... : 

## s VOC Emissions from Volatile Organic Liquid Storage 6 PERFORM11'.1G ORGANIZATI()riJR,A]l 

### Tanks

- Background Information for Proposed Standards

### l~~- 

# y AUTHOR(SI 8. PERFORMING ORGANIZATION REPGRT NO

PERFORMINGORGANIZATION NAMEANDADDRESS 10.PROGRAM ELEMENT NO.



### Office ofAir Quality Planning and Standards Environmental ProtectionAgency 11.CONTRACT/GRANTNO. 

### Research Triangle Park, North Carolina 27711 68-02-3063

.SPONSORINGAGENCY NAMEANDADDRESS 13.TYPE OF REPORTANDPERIODCOVERED



### DAA forAir Quality Planning and Standards Draft Office ofAir, Noise, and Radiation 14.SPONSORINGAGENCY CODE 

## u.s. Environmental ProtectionAgency EPA/200/04 Research Triangle Park, North Carolina 27711

.SUPPLEMENTARY NOTES

.ABSTRACT



### Standards ofPerformance for the control ofVOC emissions from Volatile Organic Liquid (VOL) storage tanks are being proposed under the authority ofSection 111 of the Clean Air Act. These standards would apply to all new and'existing storage tanks having acapacityof75 cubic meters or larger, which are to be used for the storageofVOL. This document contains background information and environmental and economic impact assessments ofthe regulatory alternatives considered in developing the proposed standards

.



### .

-- KEY WORDSAND DOCUMENTANALYSIS DESCRIPTORS b.IDENTIFIERS/OPEN ENDEDTERMS (. COSATlheld/Group 

### irpollution t:.qu1pment stanaara )llution control Standards ofPerformance torage tanks Air Pollution Control 13 B 

### Jntactfloating roofs 1emica1manufacturing plants JlatileOrganic Compounds )latileOrganic Liguids Jlk Liauid Terminals DISTRIBUTIONSTATEMENT 19.SECURITY CLASS (ThisRepon) 21 NO.OF PAGES 

### Unclassified 199 Unlimited 20 SECURITY CLASS (ThiSpage) 22. PRICE 

### Unclassified
AForm2220-J {Rev."-771 PREVIOUS EDITION IS OBSOLETE