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OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

%jtf\\-B-2 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 9 of 132 
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A 98 13 

a mm s » (I' D Z. 

a 

MEMORANDUM 

SEP i I 

TO: Steve Shedd, EPA/ESD/WCPG 

Organic Liquids Distribution NESHAP 

ESD Project No. 96/05 i 

! 

FROM: GregLaFlam^C I 

Pacific Environmental Services, Inc. (PES) \ ,_ . , " 

DATE: March 3,1998 

P:\n812 

SUBJECT: Site Visit to the Stolthaven (Perth Amboy) Inc. Bulk Terminal -

Perth Amboy, NJ 

I. Purpose 

The purpose of this site visit was to tour the facility in an effort to collect information 

related to air emissions from the operations. This work is in support ofthe development of 

national emission standards for hazardous air pollutants (NESHAP) for the Organic Liquids 

Distribution (non-Gasoline) source category. 

II. Location and Date 

Stolthaven (Perth Amboy) Inc. 

920 State Street 

P.O. Box 590 

Perth Amboy, New Jersey 08862 

December 18,1997 (1:00 - 3:30 pm) 

III. Participants 

Stolthaven (Perth Amboy) 

James A. Buce, Terminal Manager 

Robert B. Stewart, Manager Terminal Services 

Daniel F. Kelly, Safety Manager 

Environmental Protection Agency 

Steve Shedd - OAQPS/ESD/WCPG 

Research Triangle Park, NC 

Pacific Environmental Services. Inc. (PES^l 

Bemd Haneke, RTP, NC 

Jay Helms, RTP, NC 
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Site Visit Memo/Stolthaven (Perth Amboy) 

March 3,1998 

Page 2 

GregLaFlam, RTP,NC 

IV. Pre-Tour Discussion 

EPA Introduction 

After the participants introduced themselves, Steve Shedd, EPA, began the meeting by 

discussing the background ofthe EPA's regulation of hazardous air pollutant (HAP) emissions. 

Prior to the Clean Air Act Amendments (CAAA) of 1990, regulations were on the basis of 

individual HAP and a limited number of regulations were completed. The CAAA of 1990 

included a HAP list and prescribed that rules be developed for categories of sources (industrial 

types). The stringency ofthe Organic Liquids Distribution (non-Gasoline) rule (for existing 

sources) will be based on "floor" levels of control representing the control achieved by the 

average ofthe top 12 percent of facilities in the category. The standards are slated to be 

proposed in 1999, with promulgation ofthe final rule in November 2000. 

Mr. Shedd mentioned that the EPA has prepared an industry questionnaire and 

distributed it to trade organizations for their review and comment. The questionnaire, when 

final, will be sent to several companies (the number is uncertain) in this industry. He also 

described the EPA's procedures for handling information that the company considers to be 

confidential business information (CBI). The representatives of Stolthaven (Perth Amboy) 

were asked to identify whether any ofthe information in our conversations was confidential. 

No information during the conversations was noted by Stolthaven to be CBI. The company 

will have an opportunity to review the draft site visit report prepared by PES, and to comment 

on its accuracy and to identify any CBI. The report with any CBI removed will be made a part 

of the public record for this rulemaking. 

Facility Description 

The Perth Amboy facility is a bulk storage terminal located on the Raritan River near 

the southern tip of Staten Island. The facility does not perform any manufacturing or packaging 

operations (except for a small amount of butane and alcohol blending), but receives and ships 

out product owned by others on a for-hire basis. The SIC code for the facility is 4226. 

Petroleum product is received by the facility through the Colonial Pipeline and by marine 

vessel (barge and tanker ship). These products are sent out by Buckeye Pipeline or by marine 

vessel. Liquid chemicals are brought into the facility by marine vessel (and some railcar), and 

are sent out primarily by tank truck and railcar. The facility also has a conveyor that handles 

incoming marine shipments of sea salt (used as a water softener) and aragonite (a component in 

glassmaking). 

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Site Visit Memo/Stolthaven (Perth Amboy) 

March 3, 1998 

Page 3 

Petroleum products consist mainly of No. 2 (heating) oil, asphalt, gasoline, Jet A 

(airplane kerosene fuel), and butane. These products are stored in 15 storage tanks. The 

chemicals handled are primarily methanol, ethanol, styrene, plasticizers, glycol-based materials, 

and drinking alcohol. Approximately 80 storage tanks are available for storing chemicals. The 

products handled by the facility are described in more detail in the next subsection, Products 

Handled. 

The facility is situated on approximately 164 acres of property, of which about 50 

percent has been developed. It operates 24 hours per day, 5 days per week, but they are 

available for marine vessel operations on weekends as needed (a fairly frequent occurrence). 

They handle both domestic and international shipments (Europe, Japan, and the Caribbean). 

The berth for ships has a depth of 11.3 meters (37 feet). The approximate number loaded and 

unloaded per year, by delivery mode, are about: 

~ 30,000 tank trucks 

~ 3,500 railcars 

60 tanker ships 

250 barges 

Within the facility is a subset of storage tanks owned by Eastman Chemical Company 

(constructed in 1984-85). These tanks are adjacent to one another and are surrounded by a 

shelter which is partially open on the sides. Three of these tanks are internal floating roof 

tanks, while the remainder are fixed roof. Eastman Chemical owns all ofthe chemicals stored 

in these tanks. Some proprietary blending of ethyl alcohol based materials is performed at the 

Eastman facility. A diagram or plot plan ofthe complete facility was requested during the visit, 

but this was not available. 

Storage tanks range in capacity from 76 m3 (20,000 gallons) to 47,700 m3 (300,000 

barrels). They consist of cone roof, specialty dome roof, and internal floating roof (aluminum 

pan deck) tanks, and Mr. Buce stated that they generally comply with NSPS requirements 

(Subpart K, Ka, or Kb). Asphalt is stored in two insulated, heated tanks. The 42 tanks at the 

Eastman Chemical facility are mostly 189 m3 (50,000-gallon) tanks, with a few 378 m3 

(100,000-gallon) tanks. During the discussion, the EPA/PES team requested a complete 

inventory ofthe facility's storage tanks showing the level of control applied to each tank 

(floating roof and fittings seal types, etc.). This inventory was not available during the visit. 

Products Handled 

Company representatives distributed a listing of all ofthe liquid product handled by the 
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Site Visit Memo/Stolthaven (Perth Amboy) 

March 3,1998 

Page 4 

facility in 1996 (Enclosure 1). Separate inventories are shown for the "main terminal" (first 

page) and the Eastman Chemical facility (second page). 

For the main terminal, petroleum products were stored in 15 of the 55 available tanks, 

and accounted for about 75 percent ofthe total throughput. Product breakdown was gasoline/ 

blendstock at 88.5 percent, asphalt at 6.0 percent, and Jet A fuel at 5.5 percent. 

Chemicals, in 35 storage tanks, accounted for the remaining 25 percent ofthe product 

handled by the main terminal. Methanol (used primarily for making windshield washer fluid) 

was the primary chemical, comprising 27 percent of all chemicals handled. 

In 1996, the Eastman Chemical facility handled only chemicals in its 42 storage tanks. 

The Eastman activities accounted for 11 percent ofthe chemicals, and 3.0 percent of all liquids, 

handled at the combined facility. 

Control Measures 

The company has incorporated certain control measures to reduce air emissions of 

volatile petroleum and chemical products at the Stolthaven facility. Three specific control 

systems are in use: an open flare, an enclosed combustion system, and a combination wet 

scrubber/carbon canister system. 

The flare controls emissions from two storage tanks that contain styrene. (This will 

soon be increased to three styrene tanks.) In 1996,48,500 m3 (407,000 barrels) of styrene were 

loaded (marine receipts) and controlled by the flare. The company representatives said that the 

flare was designed to satisfy certain operating parameter requirements in the New Jersey 

regulations, which they said are intended to ensure 99+ percent control efficiency. No test 

results on the flare are available. They further said that monitoring and recordkeeping 

requirements on the flare are minimal (i.e., no monitoring is performed on the flare). 

The enclosed combustion system, supplied by IT-McGill (now John Zink Company), is 

used to control petroleum vapors displaced during marine vessel loading of gasoline. (This 

control is required under the marine vessel loading NESHAP.) This system is approximately 

2.4 meters (8 feet) in diameter and is situated adjacent to the flare. The combustor is computer 

controlled to ensure consistent temperature and other operational parameters. 

The facility loads a variety of chemicals at 15 tank truck loading racks, including 

acrylates, which present a serious odor problem due to their extremely low odor threshold (2 to 

3 ppb). To provide odor control (and not in response to any regulatory requirements), the 

facility uses a wet scrubber with a caustic-amine scrubbing medium on the acrylate loadings. 

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Site Visit Memo/Stolthaven (Perth Amboy) 

March 3, 1998 

Page 5 

The scrubber is followed by a series of activated carbon canisters. Loadings of 

tetrahydrofluorin (THF), a paint solvent which is highly flammable and hygroscopic, are 

controlled through vapor balancing ofthe vapors back into the storage tank. Loadings of 

products other than acrylates and THF are not subject to any control methods. 

The facility does not employ any type of wastewater treatment system, as allowed under 

its State permit. Several tanks are used for storage of hazardous material from tank washings, 

which is disposed of off-site within 90 days of generation. The company representatives were 

not able to provide the volumes of waste generated, but said that the facility's annual report to 

the State of New Jersey was due to be submitted in the near future. The EPA/PES team 

requested to receive a copy of this report after it was submitted to the State. 

V. Plant Tour 

At the conclusion ofthe discussion summarized in Section IV above, Mr. Steward took 

the EPA/PES team on a tour ofthe facility. 

The first area observed consisted ofthe two insulated storage tanks containing asphalt 

which is heated to 149°C (300°F). The team then saw the loading racks where THF is bottom 

loaded into tank trucks, and also viewed the ship loading dock. Sea salt conveyed from ships is 

stored on the ground in a specific area, and finds use as a water softening chemical. Morton 

Salt operates a small packaging facility on site. The flare and the enclosed combusion system 

were then observed, but not in any detail. 

The boiler house for the asphalt heating contains four boilers: two 6 million Btu units 

and two 1.5 million Btu units. Pumps for the Buckeye Pipeline were then seen; this pipeline 

conveys No. 2 oil and Jet A fuel out ofthe facility. 

At the Eastman Chemical facility, all chemicals are received in railcars and are 

unloaded from the top ofthe tank car. A 10-acre area ofthe facility has been permitted for 

additional storage tanks. There presently are 16 tanks in this area, with acrylate storage in 5 of 

the tanks. The tank truck loading racks for acrylates utilize an inflatable "donut" to seal the top 

loading adapter to the truck's tank, preventing the release of fugitive vapor emissions. 

VI. Post-Tour Discussion/Action Items 

The discussion following the plant tour was brief. Mr. Buce said that the EPA and PES 

were welcome to call the facility with any followup questions. 

£T 
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RBS/CME/1 

TANK# 

1 

2 

3 

4 

5 

6 

7 

9 

10 

11 

12 

12 

13 

13A 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

•26 

27 

28 

29 

32 

34 

35 

36 

37 

38 

39 

40 

43 

44 

45 

46 

47 

48 

49 

49 

50 

51 

212 

215 

216 

219 

220 

•*** 

rHRUPU96.XLS/0: 

STOLTHAVEN PERTH AMBOY INC 

ANNUAL VOLUME THRU-PUTS 1996 

MAIN TERMINAL 

PRODUCT 

METHYL ALCOHOL 

JET A (3 MONTHS) 

GASOLINE / BLENDSTOCK (9 MONTHS) 

JET A (3 MONTHS) 

GASOLINE / BLENDSTOCK ( 9 MONTHS) 

METHYL ALCOHOL 

JET A (3 MONTHS) 

GASOLINE / BLENDSTOCK (9 MONTHS) 

METHYL ALCOHOL 

GASOLINE/BLENDSTOCK 

EMPT Y (12 MONTHS) 

GASOLINE / BLENDSTOCK 

GASOLINE / BLENDSTOCK 

STYRENE ( 1 MONTH) 

CYCLOHEXANE ( 3 MONTHS) 

ETHYL ALCOHOL (190* PROOF) 

ETHYL ALCOHOL (200* PROOF) 

METHYL ALCOHOL 

GASOLINE / BLENDSTOCK 

GASOLINE / BLENDSTOCK 

GASOLINE / BLENDSTOCK 

GASOLINE / BLENDSTOCK 

GASOLINE / BLENDSTOCK 

STYRENE 

STYRENE 

ISOPROPYL ALCOHOL 99% 

STYRENE 

PROPYLENE GLYCOL IND. 

ASPHALT (AC-10 BLEND) 

ASPHALT (AC-20 BLEND) 

GASOLINE / BLENDSTOCK 

GASOLINE / BLENDSTOCK 

ASPHALT (AC-20 BLEND) 

ASPHALT (AC-20 BLEND) 

ETHYL ALCOHOL (190* PROOF) 

PROPYLENE GLYCOL METHYL ETHER (6 MONTHS) 

EMPT Y (12 MONTHS) 

CYCLOHEXANE ( 3 MONTHS) 

PROPYLENE GLYCOL IND. 

EMPT Y (12 MONTHS) 

CAUSTIC SODA 50% 

ISOPROPYL ALCOHOL 

METHYL ALCOHOL 

PROPYLENE GLYCOL USP 

PROPYLENE GLYCOL USP 

DIPROPYLENE GLYCOL (FRAGRANCE) 

DIPROPYLENE GLYCOL (FRAGRANCE) 

PROPYLENE GLYCOL METHYL ETHER (7 MONTHS) 

DIPROPYLENE GLYCOL METHYL ETHER (5 MONTHS) 

PROPYLENE GLYCOL METHYL ETHER ACETATE 

TETRAHYDROFURAN 

NEOPENTYL GLYCOL 

2 - ETHYLHEXYL ACRYLATE 

ETHYL ACRYLATE 

BUTYL ACRYLATE 

METHYL ACRYLATE 

TRANSFERRED FROM TKS #29 & #32 INTO TK #26 

RECEIPT VOLUME 

(BBLS.) 

107,962.64 

372,022.54 

997.148.83 

158,653.77 

334,753.52 

551,626.99 

67,213.07 

898,244.06 

476.179.82 

1,762,295.31 

-

850,005.53 

1,043,299.52 

31,245.77 

47.885.96 

25.387.12 

31,321.32 

74,232.04 

491,105.62 

459,672.54 

1.964,761.50 

2.382,564.54 

794,455.50 

247,285.04 

100,837.78 

55.496.44 

59.361.57 

26.446.19 

41.15 

676,156.59 

956,088.55 

1.379.790.1B 

328.108.56 

307,167.17 

44,297.37 

9,852.38 

-

22,852.62 

63,860.34 

-

65,089.81 

3,023.80 

3,023.80 

31.433.03 

30,412.41 

13,162.36 

15,165.23 

11.433.88 

2,677.27 

10,991.18 

7,392.95 

3,338.59 

27,683.75 

4,801.57 

46,363.93 

27.379.79 

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18,503.052.77 

..07.97/PAGE 1 

Co 
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STOLTHAVEN PERTH AMBOY INC 

ANNUAL VOLUME THRU-PUTS 1996 

TANK* 

101 

102 

103 

104 

105 

106 

107 

108 

109 

110 

111 

112 

113 

114 

115 

116 

117 

118 

119 

120 

121 

122 

123 

124 

125 

126 

127 

128 

129 

130 

131 

132 

133 

134 

135 

136 

137 

138 

139 

142 

EASTMAN FACILITY 

PRODUCT 

PG-MONOMETHYL ETHER ACETATE 

ETHYLENE GLYCOL MONOPROYL ETHER 

METHYL N-PROPYL KETONE 

2 - ETHYLHEXANOIC ACID 

ISOBUTYL ALCOHOL 

ISOBUTYL ISOBUTYRATE 

PG-MONOMETHYL ETHER 

ESTER ALCOHOL 

N-PROPYL ALCOHOL 

ETHYL 3 - ETHOXYPROPIONATE 

SDA-3C ALCOHOL (200* PROOF.) 

2 - BUTOXYETHANOL ACETATE 

ISBUTYL ACETATE 

ETHYL ACETATE 99% 

METHYL N-ANYL KETONE 

DI ISOBUTYL KETONE 

DIETHYLENE GLYCOL MONOBUTYL ETHER 

DI BUTYL PHTHALATE 

DI ETHYL PHTHALATE 

2. 2 - DIMETHYL -1,3 - PROPANEDIOL 

TRIMETHYL PENTANEDIOL ISOBUTYL 

DIOCTYL PHTHALATE 

DI - 2 ETHYLHEXYL ADIPATE 

DIOCTYL TEREPHTHALATE 

ISPROPYL ALCOHOL 99% 

N-PROPYL ACETATE 

DENATURED ALCOHOL III (200° PROOF.) 

ETHYL ACETATE 99% 

METHYL ISOBUTYL KETONE 

SDA - 3A ALCOHOL (200° PROOF.) 

ISOPROPYL ALCOHOL 

METHYL ALCOHOL 

N - BUTYL ACETATE 

GLACIAL ACETIC ACID 

ACETIC ANHYDRIDE 

2 - ETHYL HEXANOL 

DIOCTYL PHTHALATE 

ETHYLENE GLYCOL MONOBUTYL ETHER 

N - BUTYL ALCOHOL 

PROPYLENE GLYCOL - USP 

RECEIPT VOLUME 

(BBLS.) 

7,889.65 

3,546.42 

3.397.79 

12.602.79 

5.174.48 

1,631.71 

2,145.69 

29,637.68 

21,127.48 

3,770.44 

25,580.08 

1,496.82 

4,777.65 

41.364.19 

10.187.38 

2.405.98 

4.919.50 

6.354.50 

7.724.47 

24,933.33 

42,455.18 

3,236.49 

6,318.70 

20,172.90 

19,799.88 

16,077.46 

3,172.03 

9,635.91 

10,596.14 

9,544.57 

1.003.60 

176.43 

35,314.16 

35.736.39 

21.025.91 

12.802.39 

36.735.26 

20,405.76 

17,577.55 

16.441.95 

558,896.69 

RBS/CME/THRUPU96.XLS/02.07.97/PAGE 2 

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