### SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Draft Final Staff Report Further Reductions of VOC Proposed Rule 1178 Emissions From Storage Tanks

(Previously PR1173.1) 

### At Petroleum Facilities

December 11, October 26, 2001

Deputy Executive Officer Planning, Rule Development, and Area Sources Elaine Chang, DrPH

Assistant Deputy Executive Officer Planning, Rule Development, and Area Sources Laki Tisopulos, Ph.D., P.E.

Authors Minh Pham, P.E. – Air Quality Engineer Eugene Teszler – Air Quality Engineer Kennard Ellis – Air Quality Engineer

Reviewed By Ed Muehlbacher, P.E. – Program Supervisor Frances Keeler – Senior Deputy District Counsel

Contributors Jay Chen, P.E. – Senior Air Quality Engineering Man ager Roger Christopher – Supervisor Air Quality Inspecto r Mike Garibay, P.E. – Senior Air Quality Engineer Xuan Vu, P.E. – Senior Air Quality Engineer Wayne Stredwick – Assistant Air Quality Engineer Mei Wang – Assistant Air Quality Engineer

### SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

Chairman: WILLIAM A. BURKE, Ed.D

Speaker of the Assembly Appointee

Vice Chairman: NORMA J. GLOVER

Council Member, Newport Beach Cities Representative, County of Orange

MEMBERS:

MICHAEL D. ANTONOVICH Supervisor, Fifth District Los Angeles County Representative

HAL BERNSON Council Member, City of Los Angeles Cities Representative, Los Angeles County/Western Region

JANE W. CARNEY Senate Rules Committee Appointee

BEATRICE J. S. LAPISTO-KIRTLEY Council Member, City of Bradbury Cities Representative, Los Angeles County/Eastern Region

RONALD O. LOVERIDGE Mayor, City of Riverside Cities Representative, Riverside County

JON D. MIKELS Supervisor, Second District San Bernardino County Representative

LEONARD PAULITZ Mayor Pro Tem, City of Montclair Cities Representative, San Bernardino County

JAMES W. SILVA Supervisor, Second District Orange County Representative

CYNTHIA VERDUGO-PERALTA Governor’s Appointee

S. ROY WILSON, Ed.D. Supervisor, Fourth District Riverside County Representative

EXECUTIVE OFFICER BARRY R. WALLERSTEIN, D.Env.

### Acknowledgments

District staff would like to acknowledge the contri bution of the following individuals in developing the Proposed Rule 1178. While the Propo sed Rule 1178 and Staff Report may not reflect the opinion of any individual, many recomme ndations of the following members are incorporated in the proposed rule. The time commit ment and contribution of each individual are appreciated.

Joan Niertit and her team SCAQMD Michael Czap and his team SCAQMD

Erik White ARB Susan Livingston BPArco
Marcelo Panelo BPArco

Joe Prawdzik BPArco Maryann Gonzalez BPArco Ryan Rietzel BPArco Gordon Schremp California Energy Commission

Mike Barranco Cenco Refining

Michelle Gablich Chevron Products Co.
Dennis Leonard Chevron Products Co. Rod Spackman Chevron Products Co. Hector Villegas Conservatek Amy Gannon Davenport (for Ultramar Inc.) Royann Winchester Equilon Enterprises, LLC

Stan Holm Exxon Mobil Jerry Engelhardt Kinder Morgan (GATX) Connie More Kinder Morgan (GATX) Larry Kippes Kinder Morgan (GATX) Doug Thompson Paramount Petroleum

Miles Heller Phillips Tosco

Brian Christlieb Phillips Tosco Scott Zerga Phillips Tosco

Dave Hackett Stillwater Associates

Thomas Gieskes Stillwater A ssociates George Morovich Temcor Rob Ferry The TGB Partnership George Gavlik Ultraflote
James Hatchell Ultramar Inc. Craig Moyer Western Independent Refiners Association

Ron Wilkniss Western States Petroleum Association Mike Wang Western States Petr oleum AssociationTable of Contents Final Staff Report

Proposed Rule 1178 December 11, 2001 i 

### TABLE OF CONTENTS

Executive Summary..................................

................................................... ...............................1

Chapter 1 – Background ............................

................................................... .............................1

Legislative Authority .............................

................................................... ................................................... . 1

AQMP Control Measures .............................

................................................... ............................................ 1

District Rules ....................................

................................................... ................................................... ....... 2

Development Process of Proposed Rule 1178 .........

................................................... ............................... 2

Affected Industries ...............................

................................................... ................................................... ... 3

Chapter 2 – Emissions Inventory ...................

................................................... .........................5

Chapter 3 – Control Technology ....................

................................................... ....................... 10

Rim Seal Systems ..................................

................................................... ................................................... 10

Deck Fittings .....................................

................................................... ................................................... ..... 10

Domed External Floating Roof Tanks ................

................................................... .................................. 11

Internal Floating Roof Tanks.......................

................................................... .......................................... 12

Vapor Recovery or Vapor Control Systems ...........

................................................... ............................. 12

Pressure Vacuum Vents .............................

................................................... ............................................. 12

Chapter 4 – Proposed Rule 1178 ....................

................................................... ....................... 13

Applicability......................................

................................................... ................................................... ..... 13

Definitions .......................................

................................................... ................................................... ....... 13

Requirements ......................................

................................................... ................................................... ... 13

Other Requirements ................................

................................................... ................................................ 15

Chapter 5 – Emission Reductions ...................

................................................... ...................... 18

Upgrading Rim Seals ...............................

................................................... ................................................ 18

Upgrading Roof Fittings ...........................

................................................... .............................................. 18

Domed Roofs .......................................

................................................... ................................................... ... 19

Internal Floating Roof Tanks, Vapor Control or Vapo r Recovery Systems ................................ ..... 19

Pressure Vacuum Vents .............................

................................................... ............................................. 20

Chapter 6 – Cost and Cost Effectiveness Analysis ..

................................................... ............... 22

Cost Information ..................................

................................................... ................................................... . 22

Cost Effectiveness Analysis .......................

................................................... ............................................. 25

Incremental Cost Effectiveness Analysis............

................................................... .................................. 30

Chapter 7 – Impact Assessment .....................

................................................... ........................ 32

Environmental Impact Assessment ...................

................................................... .................................... 32Table of Contents Final Staff Report

Proposed Rule 1178 December 11, 2001 ii Socioeconomic Assessment ..........................

................................................... ........................................... 32

Disruption of Production ..........................

................................................... .............................................. 32

Refineries ........................................

................................................... ................................................... ........ 32

Non-refineries ....................................

................................................... ................................................... .... 33

Gasoline Cost Impact to Consumer ..................

................................................... .................................... 34

Comparative Analysis ..............................

................................................... ............................................... 34

Chapter 8 – Comments and Responses ................

................................................... .................. 36

Applicability......................................

................................................... ................................................... ..... 36

Definitions .......................................

................................................... ................................................... ....... 40

External Floating Roof Tanks ......................

................................................... .......................................... 44

Domed External Floating Roof Tanks ................

................................................... .................................. 50

Schedule of Installing Domed Roofs ................

................................................... ..................................... 53

Fixed Roof Tanks ..................................

................................................... ................................................... 55

Operator Inspection................................

................................................... ................................................. 5 8

Test Methods and Procedures .......................

................................................... ......................................... 60

Exemption .........................................

................................................... ................................................... ..... 64

Emission Reductions and Cost Effectiveness Analysis

.................................................. ....................... 65

Appendix A - List of Affected Facilities

Appendix B - Emission Reductions

Appendix C - Cost Effectiveness Analysis

Appendix D - Impact Study on Doming of External Flo ating Roof Tanks

Appendix E - Comparative Analysis

Appendix F -Study on Storage Tanks and Atmospheric Pressure Relief DevicesExecutive Summary Final Sta ff Report

Proposed Rule 1178 EX- 1 December 11, 2001 

## Executive Summary

Proposed Rule 1178 1 - Further Reduction of VOC Emissions From Storage Tanks at Petroleum Refineries has been developed to implement Phase 1 of the 1999 Air Quality Management Plan (AQMP) Control Measure FUG-05 – Further Emission Re ductions from Large Fugitive VOC Sources, and portions of the Control Measure FUG-03 – Further Emission Reduction s from Floating Roof Tanks, and portions of the Control Measure FUG-04 – Further Emission Reductions from Fugitive Sources.

The purpose of the Proposed Rule 1178 is to further reduce emissions of volatile organic compounds (VOCs) from storage tanks at petroleum fa cilities with annual VOC emissions of more than 40,000 lbs (20 tons). The provisions of the Proposed Rule 1178 apply to petroleum facilities operating storage tanks that have design capacity equal to or greater than 75,000 liters (19,815 gallons) and are used to store materials wi th a true vapor pressure of greater than 5 mm Hg (0.1 psi) absolute under actual storage conditio ns.

The petroleum facilities subject to the Proposed Ru le 1178 include facilities engaged in the production, refining, storage, transfer or distribu tion of crude petroleum or petroleum products as

defined in the Standard Industrial Classification f or crude petroleum and natural gas (SIC code 1311), petroleum refining (SIC code 2911), petroleu m bulk stations and terminals (SIC code 5171), or other related industries (e.g., SIC codes 4226, 4612, 4613, 4923 and 5541).

To further reduce evaporative emission losses and m inimize leaks, the Proposed Rule 1178 establishes the following requirements for external floating roof tanks, internal floating roof tanks, fixed roof tanks and pressure-vacuum vents.

Proposed Requirements for External Floating Roof Ta nks

 For facilities exceeding 20 tons annual VOC emissio ns for emission inventory year 2000, By by July 1, 20 02 2003 , retrofit each deck opening with covers that are g asketed and/or bolted, and with sleeves and wipers , and retrofit rim seal systems with the best avail able rim seal systems for external floating roof tanks containing materia ls with true vapor pressure <3psia. Facilities with annual VOC emissions exceeding 20 tons for any emission inventory year subsequent to 2000 will have one year to compl y with these requirements after becoming subject to the rule.

1 Public Notice and Public Workshop for the Proposed Rule 1178 are the Public Notice and Public Worshop for the Proposed Rule 1173.1. Upon request of the facilities subject to the Proposed Rule 1173.1, District Staff has change d the number of the proposed rule from 1173.1 to 1178 after the Public Workshop.Executive Summary Final Sta ff Report

Proposed Rule 1178 EX- 2 December 11, 2001  By July 1, 2003, retrofit rim seal systems with the best available rim seal systems on external floating roof tanks containing materials with true vapor pressure <3psia. The best available rim seal system is a liquid mounted or mechanical s hoe primary seal and a rim mounted secondary seal

.

 For facilities exceeding 20 tons annual VOC emissio ns for emission inventory year 2000, By by January 1, 200 6 8 , retrofit all external floating roof tanks containing materials h aving true vapor pressure greater than or equal to 3 psia with domed roofs, upgrading rim seal systems and deck fittings. Facilities with annual VOC emissions exceeding 20 tons for any emission inventory year subsequent to 2000 will hav e six years to comply with these requirements after becoming subject to the rule.

Proposed Requirements for Internal Floating Roof Ta nks

For facilities exceeding 20 tons annual VOC emissio ns for emission inventory year 2000, w W hen the tank is scheduled for emptying and degassing, b ut no later than January 1, 2007, retrofit each deck opening with covers that are gasketed and/or b olted, and with sleeves and wipers to further reduce evaporative losses. Facilities with annual VOC emissions exceeding 20 tons for any emission inventory year subsequent to 2000 will hav e five years to comply with these requirements after becoming subject to the rule.

Proposed Requirements for Fixed Roof Tanks and Pres sure-Vacuum Vents

For facilities exceeding 20 tons annual VOC emissio ns for emission inventory year 2000, N n o later than January 1, 2007, convert the fixed roof tanks containing materials with true vapor pressure greater than or equal to 0.1 psia that are currently vented to the atmosphe re to internal floating roof tanks or external floating roof tanks . Alternatively, the operator may choose to vent these tanks to a vapor control system or vapor recovery sy stem having at least 95% control efficiency , or to fuel gas system. In addition, the operator shall maintain all pressure-vacuum vents to meet 500 ppm measured in accordance with E PA Method 21. Facilities with annual VOC emissions exceeding 20 tons for any emission in ventory year subsequent to 2000 will have five years to comply with these requirements after becoming subject to the rule.

No later than January 1, 2007, maintain all pressur e

- vacuum vents to meet 500 ppm measured in

accordance with EPA Metho d 21 and have a set point that is set to within 10% of the maximum allowable working pressure of the roof or at least 0.5 psig to further reduce evaporative losses.

To facilitate implementation uniformity, the provis ions for record keeping, reporting, and selfinspecting of Proposed Rule 1178 are designed in a similar fashion to District Rule 463 and Title

V.Executive Summary Final Sta ff Report

Proposed Rule 1178 EX- 3 December 11, 2001 Exemption

Several exemptions are allowed in the rule. Most i mportant exemptions are 1) exempt crude oil tanks from doming requirements, 2) facilities with emission cap equal to or less than 20 tons per year shall be exempt from the rule requirements, an d 3) tanks with true vapor pressure limits less than 3 psia shall be exempt from doming requirement s.

Estimates of Emission Reductions

The total emission reductions for this proposed rul e are estimated to be 1.4 0 7 tons per day where:

 0.0 2 1 ton per day is associated with upgrading the rim s eal systems for external floating roof tanks,

 0.18 ton per day is associated with upgrading deck fittings for external and internal floating roof tanks,

 0.89 0.95 ton per day is associated with installing domed ro ofs on external floating roof tanks containing organic liquids with vapor pressures gre ater than or equal to 3 psia, excluding crude oil tanks,

 0.17 ton per day is associated with retrofitting fi xed roof tanks containing organic liquids with vapor pressures greater than 1 psia that are curren tly vented to the atmosphere,

 0.15 ton per day is associated with maintaining PV vents to achieve 500 ppm leak threshold.

Cost Effectiveness Analysis

Staff has performed a cost effectiveness analysis f or this proposed rule to provide a cost effectiveness for each control measure, and an over all cost effectiveness for the entire proposed rule. The cost effectiveness for the entire propos ed rule is $ 11,473 9,583 2, 3 per ton VOC reduced.

As required under state law, staff has also determi ned an incremental cost effectiveness of an alternative control option that meets the reduction objective of the rule. For this alternative control scenario, described at the end of Chapter 6 of this report, the cost effectiveness is

2 Specifically for doming, the cost effectiveness abo ve represents the doming of 195 external floating r oof tanks containing

materials with TVP ≥ 3 psia at refineries and non-refineries, excluding crude oil tanks. For doming, the cost effectivene ss includes cost of domed roofs as installed, cost for obtainin g permits, project management cost, loss-of-use cos t, annual maintenance cost, annual insurance and property taxes, annual emissio n savings, product savings, and self-inspection sav ings. The cost effectiveness for tanks containing crude oils were about $62,000 per ton VOC reduced.

3 The risk of having fire on domed external floating roof tanks is low, much lower than on external flo ating roof tanks. However,
for an extreme worst case scenario, where cost of a fire suppression system is included, the cost effe ctiveness factor would be $10,974 per ton VOC reduced in comparison to $9,583 per ton VOC reduced where the cost of a fire suppr ession system is not
included.Executive Summary Final Sta ff Report

Proposed Rule 1178 EX- 4 December 11, 2001 $ 19,855 21,536 per ton VOC reduced, and the incremental cost effe ctiveness is $ 113,375 121,330 per ton VOC reduced.Chapter 1 – Background Final taff Re port

Proposed Rule 1178 1 December 11, 2001 

## Chapter 1 – Background

Legislative Authority

The California Legislature created the Air Quality Management District (District) in 1977 (the Lewis-Presley Air Quality Management Act, Health an d Safety Code Section 40400 et seq.) as the agency responsible for developing and enforcing air pollution control rules and regulations in the South Coast Air Basin (Basin). By statute, the District is required to adopt an Air Quality Management Plan (AQMP) demonstrating compliance wit h all state and federal ambient air quality standards for the Basin (Health and Safety Code Section 40460(a)). In addition, the District must adopt rules and regulations that impl ement the AQMP (Health and Safety Code Section 40440(a)).

Proposed Rule 1178 will implement the first phase o f the 1999 Air Quality Management Plan (AQMP) Control Measure FUG-05 – Further Emission Re ductions from Large Fugitive VOC Sources, and portions of the Control Measure FUG-03 – Further Emission Reduction s from Floating Roof Tanks, and portions of the Control Measure FUG-04 – Further Emission Reductions from Fugitive Sources. A total of 2.9 t ons/day of reductions are expected by the end of 2008 when all three phases of the Control Measur e FUG-05 are implemented. These VOC

emission reductions are needed to contribute toward s achieving attainment of the national ambient air quality standard for ozone Section 182( b)(1)(A) of the federal CAA.

The AQMP Control Measures and District Rules applic able to fugitive VOC emissions are briefly described below.



### AQMP Control Measures

FUG-03 - Further Emission Reductions from Floating Roof Tanks

Presently, Rule 463 places exemptions on both tank capacity and vapor pressure of the organic
solvent stored. This control measure directs Distr ict staff to quantify emissions associated with the storage tanks that are currently exempt from Ru le 463, and if the emissions are significant, District staff will proceed with identifying the ap propriate control options and addressing the
cost effectiveness.

FUG-04 - Further Control of Emissions from Fugitive Sources

This control measure is designed to control fugitiv e VOC emissions from petroleum and chemical-related industries, including refineries, oil and gas production fields, natural gas processing plants and pipeline transfer stations.

FUG-05 - Further Emission Reductions from Large Fug itive VOC Sources

This control measure focuses on reducing emissions from the top 100 fugitive VOC-emitting facilities. The top VOC-emitting facilities target ed in this control measure consist mainly of

refineries. It should be noted that control measur e FUG-05 also includes control of VOC fugitive emissions from chemical plants and manufac turing facilities. The major coating and solvent operations are addressed separately under c ontrol measure CTS-08.Chapter 1 – Background Final taff Re port

Proposed Rule 1178 2 December 11, 2001 

### District Rules There are currently two District rules regulating f ugitive VOC emissions:

Rule 463
Organic Liquid Storage was adopted in 1977 and rece ntly amended in 1994. It applies to any aboveground stationary tank with a capacity of 75,0 00 liters (19,815 gallons) or greater used for storage of organic liquids and any aboveground tank with a capacity between 950 liters (251 gallons) and 75,000 liters (19,815 gallons) used fo r storage of gasoline.

Rule 1173
Fugitive Emissions of Volatile Organic Compounds, w as adopted in 1989 and was recently amended in 1994. Its purpose is to control VOC lea ks from valves, fittings, pumps, compressors, pressure relief devices, diaphragms, hatches, sight glasses and meters at refineries, chemical plants, oil and gas production fields, natural gas processing plants and pipeline transfer stations. Rule 1173 does not address refinery storage tanks, or the pressure relief/vacuum vents associated
with them.



### Development Process of Proposed Rule 1178 In 1999, the District settled a litigation initiate d by three environmental organizations, the Natural Resources Defense Council (NRDC), the Coali tion for Clean Air and Communities for a Better Environment (CBE) for failing to implement t he 1994 AQMP. The settlement agreement, which was incorporated in the 1999 AQMP amendments, commits the District to develop and implement several stationary source control measure s and achieve a specific level of emission reductions within a specific time frame. Several o f these control measures are designed to further reduce fugitive emissions from refineries.

In an effort to support implementation of the contr ol measures applicable to refineries and/or identify new control options not identified in the AQMP control measures or existing rules, the settlement agreement also committed the District to further study fugitive emissions from tanks and pressure relief devices (PRDs) operated by refi neries. More specifically, the commitment

directed the District to further refine current emi ssion inventories applicable to tanks and PRDs, including atmospheric PRDs and release events. The District was also required to identify and evaluate potential control options, including those identified by the Bay Area AQMD during the development of amendments to Regulation 8 - Organic Compounds; Rule 5 - Storage of Organic Liquids; and proceed with amendments to existing ru les and/or the development of new rules in the event the studies identify meaningful emission reduction potentials and technologically
feasible and cost-effective controls.

To fulfill its commitment to further study fugitive emissions from storage tanks and PRDs operated by refineries, District staff worked close ly with refineries and environmental organizations and developed two survey questionnair es. The first survey focused on obtaining information on storage tanks and the second survey focused on PRDs. Based on information submitted to the District following the first surve y, it has been concluded that meaningfulChapter 1 – Background Final taff Re port

Proposed Rule 1178 3 December 11, 2001 emission reductions do exist and that the control s trategies applicable to these sources are technically feasible and cost effective. Therefore , the District has decided to proceed with a rulemaking process as outlined in the settlement ag reement.



### Affected Industries Control Measure FUG-05 focuses on reducing VOC emis sions from the higher emitting petroleum facilities, other than coating and solven t operations. District Control Measure FUG05 calls for a reduction of 3 tpd VOC under three p hases. The Proposed Rule 1178 will implement the first phase of the Control Measure FU G-05 by focusing in further reducing emissions from storage tanks at petroleum facilitie s with annual VOC emissions of more than 40,000 lbs (20 tons). The Proposed Rule 1178 will partially implement portions of the Control
Measure FUG-03 and FUG-04 which have no emission re duction commitments.

Table 1-1 summarizes the annual emissions reported for the 1996-1997 emission inventory year for the top 91 highest emitting facilities in the D istrict. Table 1-1 shows the emissions in four emission groups and details the contribution of fug itive, tank, process and combustion emissions to total emissions for petroleum facilities as well as non-petroleum facilities. As shown in Table 1-1, the emissions from storage tanks at petroleum facilities contribute about 90% of the total emissions from storage tanks. Petroleum facilities in Table 1-1 include petroleum refineries (SIC 2911), facilities primarily engaged in the producti on, refining, storage, transfer or distribution of crude petroleum or petroleum products (SIC 1311), p etroleum bulk stations and terminals (SIC 5171), and related industries.

While Table 1-1 relies on information submitted to the District as part of the 1996-1997 Annual Emissions Reporting process, in assessing the emiss ion inventory and potential reductions from tank operated by the petroleum refineries subject t o the Proposed Rule 1178, staff has relied on the information submitted as part of the recently c onducted tank study attached in Appendix F of this draft staff report.Chapter 1 – Background Final taff Re port

Proposed Rule 1178 4 December 11, 2001 Table 1-1 - Emissions Summary based on 1996-97 Annu al Emission Reports, excluding

Forms B3/B3UGroup Cut
Point (tpy) No. of Facilities Fugitive

(tpy) Tank

(tpy) Process

(tpy) Combustion

(tpy) Total Emissions

(tpy)PetroleumOthersPetroleumOthersPetroleumOthersPetroleumOthersPetroleumOthersPetroleumOthers

I >150 10 2 2,584.43 0 820.98 0 463.66 956.88 1,184 .44 2.87 5,053.50 959.75

II >100 -
150 1 6 47.21 14.96 6.25 2.04 0.56 571.02 75.17 92.67 1 29.19 680.69

III >50 -
100 7 8 420.26 3.15 34.5 86.35 0.01 343.14 37.02 136.31 491.8 568.96

IV >20 -
50 19 38 286.24 74.59 196.54 63.48 22.25 520.41 36.54 544.77 541.58 1,203.26

Total 37 54 3,338.14 92.7 1,058.28 151.87 486.48 2 ,391.46 1,333.17 776.62 6,216.06 3,412.65Chapter 2 – Emissions Inventory Final Staff Repor t

Proposed Rule 1178 5 December 11, 2001 

## Chapter 2 – Emissions Inventory

The inventory of storage tanks and storage tank emi ssions for eight major petroleum refineries (SIC 2911) is summarized in Table 2-1 and Table 2-3 , respectively. This information is taken from a tank study attached in Appendix F of this st aff report. For 3 2 0 petroleum facilities other than petroleum refineries, staff has relied on the information submitted as part of the 1999-2000 Annual Emissions Reporting process. The inventory o f storage tanks and storage tank emissions
for the 3 2 0 petroleum facilities (SIC 1311, 5171 and others) a re summarized in Table 2-2 and 2- 4, respectively.

Table 2-1 – Overall Tank Inventory from Petroleum R efineries

Refinery Fixed Roof External Floating Roof Internal

Floating Roof Domed External

Floating Roof Total

1 55 50 4 0 109

2 68 111 13 0 192

3 92 13 1 1 107

4 45 66 1 2 114

5 3 29 2 0 34

6 4 87 0 4 95

7 10 27 0 0 37

8 31 0 14 0 45

Total 308 383 35 7 733
Note: The storage tank inventory at other three sm all petroleum refineries is estimated to be about 2 2 fixed roof tanks, 27 external floating roof tanks, and 3 internal floating roof tanks. Total storage tank i nventory for
petroleum refineries is therefore approximately 785 tanks

.

Table 2-2 – Overall Tank Inventory from Non-Refiner y Petroleum
Facilities

Facility Fixed Roof External

Floating Roof Internal

Floating Roof Domed External

Floating Roof Total

1 0 5 10 0 15

2 2 11 23 0 36

3 0 21 0 0 21

4 2 8 0 0 10

5 2 10 0 0 12

6 8 11 31 0 50

7 7 4 6 0 17

8 0 2 18 0 20

9 2 8 0 0 10

10 76 6 27 0 109Chapter 2 – Emissions Inventory Final Staff Repor t

Proposed Rule 1178 6 December 11, 2001

Table 2-2 – Overall Tank Inventory from Non-Refiner y Petroleum Facilities (Continued)

Facility Fixed Roof External

Floating Roof Internal

Floating Roof Domed External

Floating Roof Total

11 0 24 6 0 30

12 14 14 1 7 36

13 15 0 0 0 15

14 5 0 0 0 5

15 3 0 0 0 3

16 10 0 0 0 10

17 2 8 5 0 15

18 0 5 7 0 12

19 0 2 1 0 3

20 3 0 0 0 3

21 5 0 0 0 5

22 0 2 7 0 9

23 2 0 0 0 2

24 25 0 0 0 25

25 4 0 0 0 4

26 12 0 0 0 12

27 11 0 0 0 11

28 21 0 0 0 21

29 21 0 0 0 21

30 5 0 0 0 5

31 1 2 1 0 4

32 75 0 20 0 95

33 2 0 0 0 2

34 1 0 0 0 1

Total 3 33 08 1 43 39 16 3 1 7 6 46 15Chapter 2 – Emissions Inventory Final Staff Repor t

Proposed Rule 1178 7 December 11, 2001

Table 2-3 – Overall Emission Inventory for Tanks at Petroleum Refineries

Refinery Fixed

Roof (tpy) External

Floating Roof (tpy) Internal

Floating Roof (tpy) Domed

External Floating Roof (tpy) Total

(tpy)

1 50.97 56.50 9.96 0 117.44

2 28.47 174.19 2.70 0 205.36

3 27.45 64.87 0.73 1.05 94.10

4 12.39 85.21 1.72 1.22 100.54

5 0.58 24.45 0.31 0 25.34

6 0.10 26.24 0 1.08 27.42

7 0.43 19.73 0 0 20.16

8 0.30 0 5.30 0 5.6

Total 1 20.69 451.19 20.72 3.35 595.95(Note)
Note: The storage tank emission inventory at other three small petroleum refineries is estimated to b e about 18.46 tpy from their 99-00 inventory. Total storage tank emission inventory for the petroleum
refineries is therefore approximately 614.41tpy

.

Table 2-4 – Overall Emission Inventory for Tanks at Non-Refinery
Petroleum Facilities

Facility Fixed

Roof (tpy) External

Floating Roof (tpy) Internal

Floating Roof (tpy) Domed

External Floating Roof (tpy) Total

(tpy)

1 0.00 10.43 40.01 0 50.43

2 5.31 5.83 43.56 0 54.71

3 0.00 45.52 0.00 0 45.52

4 2.92 31.38 0.00 0 34.30

5 0.24 20.93 0.00 0 21.17

6 0.35 43.74 19.84 0 63.92

7 8.92 8.53 6.01 0 23.47

8 0.00 0.56 21.75 0 22.31

9 0.43 23.29 0.00 0 23.72

10 18 .91 28.11 106.61 0 153.62Chapter 2 – Emissions Inventory Final Staff Repor t

Proposed Rule 1178 8 December 11, 2001

Table 2-4 – Overall Emission Inventory for Tanks at Non-Refinery Petroleum Facilities (continued) Refinery Fixed

Roof (tpy) External

Floating Roof (tpy) Internal

Floating Roof (tpy) Domed

External Floating Roof (tpy) Total

(tpy)

11 0.00 13.20 1.29 0.00 14.50

12 3.03 6.18 0.07 0.00 9.28

13 0.88 0.00 0.00 0.00 0.88

14 0.62 0.00 0.00 0.00 0.62

15 2.39 0.00 0.00 0.00 2.39

16 13.40 0.00 0.00 0.00 13.40

17 2.41 3.79 12.94 0.00 19.14

18 0.00 0.20 2.89 0.00 3.09

19 0.00 5.28 2.05 0.00 7.33

20 0.33 0.00 0.00 0.00 0.33

21 1.45 0.00 0.00 0.00 1.45

22 0.00 5.86 7.32 0.00 13.18

23 0.30 0.00 0.00 0.00 0.30

24 7.13 0.00 0.00 0.00 7.13

25 0.41 0.00 0.00 0.00 0.41

26 2.91 0.00 0.00 0.00 2.91

27 0.92 0.00 0.00 0.00 0.92

28 5.44 0.00 0.00 0.00 5.44

29 1.02 0.00 0.00 0.00 1.02

30 0.55 0.00 0.00 0.00 0.55

31 0.46 5.68 3.18 0.00 9.32

32 5.64 0.00 4.75 0.00 10.39

33 3.59 0.00 0.00 0.00 3.59

34 0. 0 33 0.00 0.00 0.00 0. 0 33

Total 8 6 5

. 37 74 2 58 47 .5 1 5 2 72 67

. 27 04 0.00 6 17 00

. 15 33

As shown in Table 2-5, the total inventory of stora ge tanks subject to the Proposed Rule 1178 is

about 1,4 31 00 storage tanks with a total annual emission of 1,2 32 15 tons per year (3.3 7 2 tons per day)

.Chapter 2 – Emissions Inventory Final Staff Repor t

Proposed Rule 1178 9 December 11, 2001

Table 2-5 – Summary of Tank Inventory and Emissions from Tanks

Fixed Roof External Floating Roof Internal

Floating Roof Domed

External Floating Roof Total

No of Tank 6 6 3 8 5 53 49 201 199 14 1,4 31 00

Emissions 207.06

206.43 tpy 7 28 17

. 16 2

tpy 2 92 87

. 99 76

tpy 3.35 tpy 1,2 31 14

. 56 7

4 tpyChapter 3 – Control Technology Final Staff Repor t

Proposed Rule 1178 10 December 11, 2001 

## Chapter 3 – Control Technology

Rim Seal Systems

Floating roof tanks are equipped with a rim seal sy stem to minimize evaporation losses around the rim. Chapters 4 and 5 of the tank study attach ed to Appendix F of this report provide:

• A description of a rim seal system for floating roo f tanks;

• An inventory of the existing rim seal systems for s torage tanks in the District; and

• A comparison in rim seal losses between different t ypes of rim seal systems.

The tank study in Appendix F of this report shows t hat the most effective rim seal system in controlling evaporative losses around the tank rim of a welded tank consists of a mechanical shoe or liquid-mounted primary seal and rim-mounted secondary seal. For a riveted tank, the most effective control system is a mechanical shoe vapor mounted primary seal and a rimmounted secondary seal. As shown in Table 4-5 of t his study, a best rim seal system can reduce evaporative losses by 51% to 85%.



### Deck Fittings

The external and internal floating roof tanks are e quipped with fittings that penetrate the decks and serve operational functions. Deck fittings can be a source of evaporative losses when they require openings in the deck. Chapters 4 and 5 of the tank study in Appendix F of this report provide:

• A description of the deck fittings of floating roof tanks;

• An inventory of the existing deck fittings for the storage tanks in the District; and

• A comparison in deck fitting losses between differe nt types of deck fittings.

The tank study in Appendix F of this report shows t hat the most effective control option for deck fittings is to:

• Provide each access hatch and each gauge float well with a cover that is gasketed and bolted which is closed at all times except when the hatch or well must be opened for access;

• Equip each gauge hatch/sample well and each ladder well with a gasketed cover which is closed at all times except when the hatch or well m ust be open for access;

• Gasket each rim vent and each vacuum breaker;

• Provide each roof drain that empties into the store d liquid and each sample pipe or well with
a slotted membrane fabric cover that covers at leas t 90 percent of the area of the opening;

• Equip each unslotted guide pole well with a sliding cover that is gasketed and have a flexible fabric sleeve seal or wiper; andChapter 3 – Control Technology Final Staff Repor t

Proposed Rule 1178 11 December 11, 2001 • Equip each slotted guide pole well with a gasketed sliding cover, a flexible fabric sleeve seal and wiper, and/or a gasketed float.

The inventory of deck fittings in Appendix F shows that about:

• 50% of the deck fittings for storage tanks in the D istrict operated by refineries are currently equipped with gasketed covers;

• 50% of unslotted guidepoles for storage tanks in th e District operated by refineries are equipped with sliding gasketed covers, sleeves and wipers; and

• 50% of slotted guidepoles for storage tanks in the District operated by refineries are equipped with sliding gasketed covers, sleeve seals, wipers, and gasketed floats.

As shown in Table 4-8 of the tank study in Appendix F, in general, providing gasketed and/or bolted covers can reduce evaporative losses through the deck fittings from 3% to 98%.



### Domed External Floating Roof Tanks

A domed roof is a fully triangulated structure typi cally made of aluminum that is self-supporting from its periphery. A domed roof can further reduc e evaporative losses from external floating roof tanks by:

• Acting as a wind barrier and eliminating evaporativ e losses caused by wind effects; and

• Eliminating evaporative losses caused by supporting columns. Standard internal floating roof tanks need support columns for their fixed con ed roof. Geodesic domes are selfsupported structures thus greatly reducing the numb er of openings for support columns, and the evaporative losses associated with these openin gs.

There are many other benefits to cover a petroleum storage tank with an aluminum geodesic
dome. Some of the benefits are:

• Keeping rain from entering into the tank and possib ly contaminating the product;

• Preventing corrosion of the steel roof by eliminati ng standing water;

• Eliminating the need for disposal of contaminated w ater from the roof; and

• Protecting the existing rim seals from environmenta l hazards.

The aluminum domed roof is almost a maintenance-fre e structure, can be built on the ground and lifted into place, and can be installed without tak ing the tank out-of-service. Chapter 6 of the tank study in Appendix F provides a comparison in r im losses and deck fitting losses of external floating roof tanks and domed external floating roo f tanks. As shown in Table 6-3 of this study, retrofitting external floating roof tanks with dome d roofs can reduce the rim-seal losses by 80%, and the deck-fitting losses by 50%.Chapter 3 – Control Technology Final Staff Repor t

Proposed Rule 1178 12 December 11, 2001 

### Internal Floating Roof Tanks

Converting an existing fixed roof tank currently ve nted to the atmosphere to an internal floating roof tank can further reduces evaporative losses. Table 5-5 and 5-6 of the tank study in Appendix F provides a comparison in rim seal losses , deck fitting losses, withdrawal losses, and

total losses of fixed roof tanks and internal float ing roof tanks. As shown in Table 5-6 of this study, converting fixed roof tanks to internal floa ting roof tanks can reduce working losses by 95%, breathing losses by 90%, and total losses by 9 4%.



### Vapor Recovery or Vapor Control Systems

Venting fixed roof tanks to a vapor recovery system or a vapor control system is a control option for fixed roof tanks. Several types of vapor recov ery system can be used, including vapor/liquid absorption, vapor compression, vapor cooling, vapor /solid adsorption, or a combination of these. Thermal oxidation such as venting to process heater s or flaring is another method to control

emissions from fixed roof tanks. The overall contr ol efficiencies of vapor control or vapor recovery systems are reported to be as high as 90% to 99%. (Reference: Control Techniques for Volatile Organic Compound Emissions from Stationary Sources. EPA, 1994.).



### Pressure Vacuum Vents

Low leakage pressure vacuum vents at 500 ppm measur ed in accordance with EPA Method 21 are currently available in the market. One example is the Protectoseal’s PIN-TECH pressure vacuum vents which have a unique buckling pin techn ology to hold the vents closed and minimize leakage up to the relief set point. The p erformance of the PIN-TECH pressure vacuum
vents have been verified under the U.S. EPA Environ mental Technology Verification Program. (Manufacturer’s Catalog and Web Site of Protectosea l, 2000). A good maintenance program can also help to keep pressure vacuum vents at a leakag e rate of 500 ppm.Chapter 4 – Proposed Rule 1173.1 Final Staff Report

Proposed Rule 1178 13 December 11, 2001 

## Chapter 4 – Proposed Rule 1178

Highlights of the Proposed Rule 1178 are:



### Applicability

The purpose of the Proposed Rule 1178 is to further reduce emissions of volatile organic compounds (VOCs) from storage tanks at petroleum fa cilities. The rule applies to all storage tanks that have design capacity equal to or greater than 75,000 liters (19,815 gallons), are used to store organic liquids with a true vapor pressure gr eater than 5 mm Hg (0.1 psi) absolute under actual storage conditions, and are located at any p etroleum facility that emits more than 40,000 pounds (20 tons) per year of VOC in any emission in ventory year beginning in year 1999 2000

.



### Definitions

• Terminology such as “storage tanks” and “petroleum facilities” that is used in the applicability section of the Proposed Rule 1178 is defined for clarity.

• Terminology such as “mechanical shoe primary seal”, “resilient-filled primary seal”, “secondary seal”, “liquid-mounted seal”, “vapor-mou nted seal”, “access hatch”, “slottted and unslotted guidepole”, “pole float”, “pole sleeve”, “pole wiper”, “rim seal”, “vacuum breaker” that is used in the requirements section of the Pro posed Rule 1178 is defined for clarity.

• Terminology such as “exempt compounds” that has bee n defined in Rule 102 is referred to by citing reference to Rule 102.



### Requirements

Facilities with Annual Emissions > 20 tons for Emis sion Inventory Year 2000

External Floating Roof Tanks Containing Materials With TVP <3psia

The following three requirements are proposed for external float ing roof tanks :

• By July 1, 2002 J uly 1, 2003 , each deck fitting/well will be equipped with cove r that is gasketed/bolted, or with sleeve and wiper to reduce evaporative losses. Specifically:

 Each access hatch and gauge float well will be equi pped with a cover that is gasketed and bolted. The cover shall be closed at all times, wi th no visible gaps, except when the hatch or well must be opened for access.

 Each gauge hatch/sample well will be equipped with a cover that is gasketed. The cover shall be closed at all times, with no visible gaps, except when the hatch or well must be opened for access.

 Each rim vent, vacuum breaker and roof leg will be gasketed.Chapter 4 – Proposed Rule 1173.1 Final Staff Report

Proposed Rule 1178 14 December 11, 2001  Rim vents will be closed at all times when the roof is floating; and will be set to open only when the roof is being floated off the roof le g supports or when the pressure beneath

the rim seal exceeds the manufacturer's recommended setting.

 Vacuum breakers will be closed at all times when th e roof is floating; and will be set to open only when the roof is being floated off or is being landed on the roof leg supports.

 Each open floating roof drain will be equipped with a slotted membrane fabric cover that covers at least 90 percent of the area of the openi ng.

 Each unslotted guidepole well will be equipped with a gasketed sliding cover and a flexible fabric sleeve or wiper. In addition, each unslotted guidepole will be equipped with a gasketed cover at the end of the pole. The cover will be closed at all times except when gauging or sampling.

 Each slotted guidepole will be equipped with a gask eted cover, a pole wiper and a pole sleeve. The pole sleeve will be extended into the stored liquid. Each slotted guidepole with a pole float will be equipped with a gasketed cover, a pole wiper, and a pole float wiper. The wiper or seal of the pole float will be at or above the height of the pole wiper. The gasketed cover of each slotted guidepole will b e in place over the guidepole opening at all times except when the cover must be opened f or access. The pole float will be floating within the guidepole at all times except w hen it must be removed for access to the stored liquid or when the tank is empty.

• By July 1, 2003, external floating roof tanks will be equipped with a rim seal system that consists of two seals. The primary seal will be me chanical shoe or liquid mounted for

welded tanks and mechanical shoe for riveted tanks. The secondary seal will be rim mounted. The rim seal system will cover the annula r space between the external floating roof and the wall of the storage tank in a continuo us fashion.

External Floating Roof Tanks Containing Materials W ith TVP ≥ 3psia

By January 1, 2006 2008 , external floating roof tanks containing materials having true vapor pressure greater than or equal to 3 psia will be eq uipped with domed roofs , upgraded rim seals and deck fittings to reduce evaporative losses.

Internal Floating Roof Tanks

At the next time the tank is scheduled for emptying and degassing but no later than January 1, 2007, each deck fitting/well of an internal floatin g roof tank will be equipped with cover that is gasketed/bolted, or with sleeve and wiper to reduce evaporative losses. Specifically:

• Each fixed roof support column and well will be equ ipped with a sliding cover that is gasketed or flexible fabric sleeves.

• Each ladder well will be equipped with a cover that is gasketed. The cover will be closed at all times, with no visible gaps, except when the we ll must be opened for access.Chapter 4 – Proposed Rule 1173.1 Final Staff Report

Proposed Rule 1178 15 December 11, 2001 • Other deck fittings will meet the same specificatio ns as external floating roof tanks.

Fixed Roof Tanks

• Currently nineteen fixed roof tanks in the District operated by the refineries and fifty-one operated by the non refineries containing materials with true vapor pressure greater than or equal to 0.1 psia are vented directly to the atmosp here. By January 1, 2007, the 70 fixed roof tanks must be equipped with a closed vent system, a nd the vapors displaced from these tanks must be vented to a vapor control system or a vapor recovery system. The vapor recovery or vapor control system shall hav e ing at least an overall recovery efficiency or control efficiency of 95% ; or a fuel gas system . The operator is allowed to comply with this requirement by converting their fixed roof tanks to internal floating roof tanks or external floating roof tanks

.

• By January 1, 2007, the pressure-vacuum vents of al l tanks subject to this Proposed Rule 1178 are required to:

 Have a set point set to within 10% of the maximum a llowable working pressure of the roof or at least 0.5 psig to reduce breathing losse s.

 Be maintained in a vapor tight condition, that is l ess than 500 ppm measured by EPA Method 21, at all times except when the operating p ressure of the fixed roof tank exceeds the manufacturer’s recommended setting.

Facilities with Annual Emissions > 20 tons for Any Emission Inventory Year Subsequent to
2000:

These facilities will have one year to comply with the requirements for external floating roof tanks containing materials with TVP < 3psia; six ye ars to comply with the doming requirements for external floating roof tanks containing materia ls with TVP ≥ 3psia; and five years to comply with the requirements for fixed roof tanks and inte rnal floating roof tanks after becoming subject to the rule, respectively.



### Other Requirements

Test Methods and Procedures

• Test Method for determining 0.1 psia true vapor pre ssure of organic liquids.

The test method for determining the 0.1 psi true va por pressure for rule applicability does not directly measure vapor pressure, but uses surrogate test methods. The surrogate test methods are to be used in determining applicability and not an actual measurement for vapor pressure. The surrogates consist of flash point for ambient t emperature tanks and distillation temperature at 10% recovery for heated tanks. The reason for this is to address a long standing difficulty in measuring low vapor pressure s in that there are no accurate and reasonably cost effective methods known. This prob lem has been compounded over time as vapor pressure thresholds and limits decrease with increased rule stringency. For tanks Formatted: Bullets and NumberingChapter 4 – Proposed Rule 1173.1 Final Staff Report

Proposed Rule 1178 16 December 11, 2001 storing organic liquids at ambient temperature, the flash point method was chosen as a low cost, well established method that is quite capaple in discerning between petroleum products.

The 100 o F flash point was chosen as to mimic the exemption of the products that were excluded from the inventory and cost effectiveness analyses. Most tanks containing diesel and kerosene were excluded from these analyses. AS TM Method D86 is to be used for heated tank contents due to its flexibility in bein g able to adjust its applicability limit to the tank contents storage temperature. Actual storage temperature is measured at the time of sampling. This temperature can be taken from near the top of the tank even if stratified liquid temperatures exist as to represent the liqui ds that would most influence the emissions.

The reason for the different test method for heated tank contents is that both vapor pressure and emissions increase with storage temperature, pa rticularly at the upper liquid layer

interface.

• Test Method for determining 3 psia true vapor press ure of organic liquids.

For measuring true vapor pressure for applicability of the 3 psia requirements, the referenced nomographs are currently located in Chapter 7 of EP A AP-42. For organic liquids stored at above ambient temperatures, actual storage temperat ure is measured at the time of sampling. This temperature can also be taken from near the to p of the tank even if stratified liquid temperatures exist as to represent the liquids that would most influence the emissions. If, for example, as with sludge samples, the viscosity of t he sample is sufficiently high so that it cannot be poured into the Method D323 vapor pressur e apparatus, then it may be assumed that the vapor pressure is less than 3 psia.

In addition, the District Laboratory Approval Progr am requirements will generally apply to the source test methods only and when testing for t he control device efficiency requirements.

Monitoring Requirements

• External Floating Roof Tank s

 The rim seal system will be inspected by a certifie d person on a semiannual basis, and each time the tank is emptied and degassed, followi ng the same procedures as specified
in District Rule 463.

 The deck fittings will be inspected by a certified person on a semiannual basis, and each time the tank is emptied and degassed, following th e same procedures as specified in
District Rule 463.

• Domed External Floating Roof Tank and Internal Floa ting Roof Tanks

 Visually inspect the rim seal system and roof openi ngs using LEL on a semiannual basis.

 Perform gap measurement of rim seal at least once every ten years and when the tank is emptied or degassed but no less than once every ten years.

 Perform EPA Method 21 and gap measurements of deck fittings at least once every ten

years and when the tank is emptied or degassed but no less than once every ten years

. Formatted: Bullets and NumberingChapter 4 – Proposed Rule 1173.1 Final Staff Report

Proposed Rule 1178 17 December 11, 2001 • Fixed Roof Tanks

 Conduct annual source testing and weekly monitoring operating parameters to ensure 95% control efficiency.

 Vapor tight conditions shall be determined using Me thod 21 on a quarterly basis.

 Engineering data sheet is used to determine complia nce with pressure-vacuum valve set point.

Maintenance Requirements

Any tank that does not comply with any provision of this rule, except the provisions related to pressure vacuum vents, will be brought into complia nce within 72 hours of the determination of non-compliance. This is a current requirement in D istrict Rule 463.

Record Keeping and Reporting Requirements

The operator will follow the record keeping and rep orting requirements in District Rule 463, except that all records of operator inspection and repair will be kept at the facility for a period of 5 years and be made available to the Executive Offi cer upon request.

Additional Tank Requirements

The tanks in this rule are also required to comply with the requirements in Rule 463 such as gap requirements, PV vents setting, deck fittings requi rements, or concentration of organic vapor space above internal floating roofs.

Annual Status Report

On or before each compliance date, the operator who is required to install a domed roof on external floating roof tanks must submit an annual status report to the District. The plan will include information such as a list of storage tanks subject to the requirement, a general description of each tank, a description of the comp liance method chosen for each tank, and an estimated compliance date for each tank.Chapter 5 – Emissions Reduction Final Staff Report

Proposed Rule 1178 18 December 11, 2001 

## Chapter 5 – Emission Reductions

Chapters 3 through 7 of the tank study in Appendix F of this draft staff report contain

information on control efficiencies of the control options recommended for this Proposed Rule

1178. The emission reduction estimates for each co ntrol option are described below and are

summarized in Table 5-1.



### Upgrading Rim Seals

Table 4-5 of the tank study in Appendix F of this r eport provides information on percent reduction associated with each existing rim seal sy stem installed on external floating roof tanks. For example, replacing a rim seal system equipped w ith only mechanical shoe primary seal with a rim seal system equipped with mechanical shoe pri mary seal and rim-mounted secondary seal will provide about 85% reduction in rim seal losses

.

Table B-1 of Appendix B of this report contains the total rim seal losses associated with each type of rim seal system. The emission reductions i n Table B-1 are estimated based on the following equation:

ER rimseal = 

# Σ

i 

# ( E rimseal, i

x PR rimseal, i ) (Equation 5-1)

Where:

ER rimseal = Total estimated emission reductions associated w ith upgrading rim seals

E rimseal, i = Reported emissions associated with rim seal typ e i

PR rimseal, i = Percent reduction associated with rim seal type i

As shown in Appendix B and summarized in Table 5-1, the total emission reductions that would be achieved by replacing existing rim seal systems with the best rim seal systems is estimated about 2.55 tons per year for petroleum refineries. For facilities that are not petroleum refineries, the estimated reduction is about 1.46 tons per year

.



### Upgrading Roof Fittings

Table 4-8 of the tank study in Appendix F of this r eport provides a percent reduction associated with each existing deck fitting installed on extern al floating roof tanks. As an example, installing pole wiper and sleeve for a slotted guid epole/sample well will reduce deck-fitting losses by 93%.

Table B-4 of Appendix B of this report contains the deck fitting losses from external and internal floating roof tanks located at the eight local petr oleum refineries. The emission reductions associated with deck fittings are estimated as foll ows:

ER deckfitting

= 

# Σ

i (E deckfitting, i x APR deckfitting, i ) (Equation 5-2)Chapter 5 – Emissions Reduction Final Staff Report

Proposed Rule 1178 19 December 11, 2001 Where:

ER deckfitting = Total emission reductions associated with upgrad ing deck fittings

E deckfitting, i = Total reported emissions for storage tank type i (i = 1 for external floating roof tanks and i = 2 for internal floating roof tanks)

APR deckfitting, i = Average percent reduction for storage tank type i

= 

# Σ j (N deckfitting, j x PR deckfitting, j ) / N (Equation 5-3)

Where:

N deckfitting, j = Number of deck fittings type j

PR deckfitting, j = Percent reduction associated with deck fittings t ype j

N = Total number of deck fittings for storage tank type i

As shown in Tables B-2 and B-3, the average percent reductions for external floating roof tanks and internal floating roof tanks are 7.49% and 18.9 3% respectively. As shown in Appendix B and summarized in Table 5-1, the total emission red uctions that would be achieved by upgrading existing deck fittings are estimated to be approxim ately 18.95 tons per year for petroleum refineries. For facilities that are not petroleum r efineries, the estimated reduction is about 46.80
tons per year.



### Domed Roofs

Table 6-3 of the tank study in Appendix F shows tha t using a domed roof can achieve an average reduction of 79% for rim-seal losses, and 47% for d eck fitting losses. As shown in Section B-3 of Appendix B Table B

- 5 and summarized in Table 5-1, installing domed roof s on external floating roof tanks containing materials with true vapor pressures of 3 psia or greater , excluding crude oil tanks, will result in an emission reduction of 222.48 189.47 tons per year for 11 refineries, and 151.10 134.74 tons per year for non-petroleum refineries. 4



### Internal Floating Roof Tanks, Vapor Control or Vapo r Recovery Systems

Converting an existing fixed roof tank to an intern al floating roof tank or venting the vapors to a vapor control/vapor recovery system will further re duce evaporative losses from the fixed roof

4 Doming 28 crude oil tanks at refineries and 18 crud e oil tanks at non-refineries would result in an em ission reduction of 17.94 tpy and 6.12 tpy, respectively. As shown in the co st effectiveness section in Chapter 6, the cost eff ectiveness factor of doming crude oil tanks would be approximately $62,000 per ton VOC reduced. Because of the high cost effectiv eness factor, crude oil tanks shall be exempt from the doming requirements of the PR1178.Chapter 5 – Emissions Reduction Final Staff Report

Proposed Rule 1178 20 December 11, 2001 tanks that are currently vented to the atmosphere. Table 3-3 of the tank study in Appendix F shows that 133 fixed roof tanks are currently vente d to the atmosphere. The emissions
associated with these fixed roof tanks are 86.94 to ns per year. Out of the 133 fixed roof tanks vented to the atmosphere, there are 19 tanks contai ning materials having true vapor pressure greater than 0.1 psia from Refinery #1, 2, and 3. The emissions from these 19 tanks are 38.47 tons per year. Venting these tanks to a vapor cont rol system or a vapor recovery system, or converting these tanks to internal floating roof ta nks or external floating roof tanks with primary and secondary seals will reduce the emissions from these tanks by at le ast 95%. The emission
reductions that would be achieved are about 36.55 t ons per year for petroleum refineries. For facilities that are not petroleum refineries, there are 51 tanks currently vented to the atmosphere containing materials having true vapor pressure gre ater than 0.1 psia. The estimated reduction is about 26.16 tons per year as shown in Table 5-1.



### Pressure Vacuum Vents

Low leakage pressure vacuum vents at 500 ppm or les s measured in accordance with EPA Method 21 are currently available in the market and can significantly reduce emissions associated with pressure vacuum vents. Chapter 7 o f the tank study in Appendix F of this report provides several sources of information that can be used to estimate the emission inventory for pressure vacuum vents. Depending on assumptions us ed, the emission inventory from pressure vacuum vents potentially can be significant. District staff has used a factor of 0.1 tons per year per vent to estimate the emission reductions associ ated with pressure vacuum vents. Testing to verify this factor was done as described in Section B-5 of Appendix B.Chapter 5 – Emissions Reduction Final Staff Report

Proposed Rule 1178 21 December 11, 2001

Table 5-1 – Control Options and Emission Reduction Estimates

Tank Type Control Option No of Tank Effected Emission Reducti on Estimates

External Floating

Roof

Tanks Upgrading Rim Seals – Using 1) mechanical or

liquid-mounted primary seals and rim-mounted secondary seals for welded tanks and 2) mechanical shoe primary seals and rim-mounted secondary seals for riveted tanks. 9

(6 from refineries, and 3 from non refineries) 4.01 tpy (0.01 tpd)

(2.55 tpy from refineries, and 1.46 tpy from non-refineries )

External

and

Internal Floating

Roof

Tanks Upgrading Deck Fittings – Using 1) bolted and

gasketed components such as access hatches, gauge float wells, rim vents etc. 2) slotted guidepoles/wells with gaskested sliding covers, floats, pole sleeves, and pole wipers; or 3) unslotted guidepoles with gasketed sliding covers and pole wipers. 65.75 tpy (0.18 tpd)

(18.95 tpy from refineries, and 46.80tpy from nonrefineries)

External Floating

Roof

Tanks Installing Domed or Fixed Roofs – On external

floating roof tanks containing materials with TVP

> ≥ 3 psia , excluding crude oil tanks

. 241 195 5

( 146 118 from refineries, and 95 77 from non-refineries) 348.27 324.21 tpy ( 0.95 0.89 tpd)

( 0.207.41 189.47 tpy
from refineries and
140.86 134.74 tpy from non-refineries)

Fixed

Roof

Tanks Venting to vapor control system or vapor

recovery system or converting to internal floating roof tanks. 70

(19 from refineries and
51 from nonrefineries) 62.71 tpy (0.17 tpd)

(36.55 tpy from

refineries and 26.16tpy from nonrefineries)

Fixed

Roof

Tanks Maintaining pressure vacuum vents to achieve

500 ppm leakage rate. 532

(308 from refineries

and 224 from nonrefineries) 53.20 tpy (0.15 tpd)

TOTAL 533.94 tpy (1.46 tpd) including doming crude

oil tanks

509.88 tpy (1.40 tpd) excluding doming crude
oil tanks

5 The current 1999-2000 inventory submitted showed th at there were 28 crude oil tanks located at refiner ies and 18 at nonrefineries. The emission reductions associated wit h these tanks were estimated to be 17.94 tpy and 6. 12 tpy, respectively.Chapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 22 December 11, 2001 

## Chapter 6 – Cost and Cost Effectiveness Analysis

Cost Information

Upgrading Rim Seals

Several refineries provided District staff with cos t information for upgrading existing rim seal systems. In addition to the information provided b y the refineries, District staff has gathered cost information from two manufacturers of primary and s econdary seals. The cost is provided in
Table 6-1.

Table 6-1 - Cost for Upgrading Rim Seals

Refinery or Manufacturer Replacing Rule 463 Rim Seal
B/C with A Replacing with “tight fitting” seal (Note (a))

Refinery #1 $1,500 per foot $1,500 per foot

Refinery #3 $40,000 per tank (Note (b)) No data

Refinery #5 $135 per foot $115 per foot

Manufacturer #1 Materials: $57 per foot for primary , $74 per foot for secondary.

Installation: $64 per foot for installation cost in cluding removal of existing seals and installing new primary and se condary seals. (Note (c))

Manufacturer #2 Materials: $45 per foot for primary , $25 per foot for secondary.

Installation: $28 per foot for primary, $13 per foo t for secondary, $19 per foot removal existing seals.

Note: (a) Tight fitting seals are seals that provi de tight fitting with no gaps more than 1/8 inch wi de between the seal and the tank shell. (b) For primary seal only. Do not have data on secondary seal. (c) Replacing se als can be performed with tanks remaining in-service.

Upgrading Deck Fittings
Several refineries provided District staff with cos t information for upgrading deck fittings. Upgrading deck fittings means installing gaskets, s eals, pole sleeves, pole wipers and/or covers for deck fittings on internal and external floating roof tanks. The cost information provided by

the refineries is summarized in Table 6-2.Chapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 23 December 11, 2001 Table 6-2 - Cost for Upgrading Deck Fittings

Refinery For slotted and unslotted

guidepoles and wells For other deck fittings

1 $4,500 per fitting $500 per fitting

3 $10,000 (Note (a)) $60 per each leg cover (Note ( b))

5 $2,400 - $6,000 per tank (Note c)) $850 per tank

Note: (a) Including installation costs. (b) Assumi ng 24 legs per tank. (c) $2,400 for gaskets, float s and wipers; $6,000 for pole sleeves.

Domed Roofs

Several refineries provided District staff with cos t information for installing a domed roof on external floating roof tanks. The information is s ummarized in Table 6-3. In addition to the information provided by the refineries, District st aff has gathered cost information from three manufacturers of geodesic domed roofs. The cost is provided in Figure 6-1.

Table 6-3 - Cost for Geodesic Domed Roofs

Refinery Cos t

3 $200,000 per 120 ft tank

5 $19,700 (25 ft diameter tank) to $746,600 (218 ft d iameter tank) (Note (a))

Note: (a) This cost does not include cost of emptyi ng, purging and refloating the tank.

Internal Floating Roof Tanks

There are 19 fixed roof tanks at refineries and 51 at non-refineries currently vented to the atmosphere. Several refineries provided District st aff with cost information for converting a fixed roof tank to an internal floating roof tank. The information provided by the refineries , and gathered by District staff from a manufacturer is are summarized in Table 6-4.

Table 6-4 - Cost for Internal Floating Roof Tanks

Refinery Cost

1 $1,100 per diameter foot (Note (a))

3 $100,000 per tank

5 $25 per square foot

Manufacturer $42 K for 3 0 ft dia meter tank ; $58 K for 50 ft dia meter ; $71 K for

60 ft diameter; $125K for 120 ft diameter; $201K fo r 150 ft diameter; and $315K for 200 ft diameter tank.

Note: (a) Does not include costs associated with ta king tank out-of-service, degassing, and cleaning t he tank.Chapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 24 December 11, 2001

Figure 6-1- Cost of Domed Roofs for External Floati ng Roof Tanks

Vapor Control and Vapor Recovery System

There are 19 fixed roof tanks at refineries and 51 at non-refineries currently vented to the atmosphere. In lieu of converting the fixed roof t anks to internal floating roof tanks, the operator may choose to vent the vapor losses from these fixe d roof tanks to a vapor control system or a vapor recovery system. An existing vapor control o r vapor recovery system on site may be able to carry the additional load. In this scenario, th e cost effectiveness of this control option is negligible. The cost effectiveness however could v ary significantly with each individual scenario depending on the location of the tanks, th e size of the existing compressors, and the types of vapor control or vapor recovery system the facility would choose to use. Because of that reason, to evaluate the cost effectiveness for the entire Proposed Rule 1178, District staff

would use the cost effectivess derived for internal floating roof tanks.

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000

59 91 117 120 133 139 143 150 218

Tank Diameter (ft)Cost As Installed ($)

Manufacturer #1 Manufacturer #2 Manufacturer #3Chapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 25 December 11, 2001 Pressure Vacuum Vents
Several refineries and manufacturers have provided District staff with cost information as shown in Table 6-5 for installing pressure vacuum vents t hat meet 500 ppm limit.

Table 6-5 - Cost for Pressure-Vacuum Vents

Refinery/Manufacturer Cost

3 $7,000 to $10,000 for each PV vent depending on siz e

5 $2,500 for each 4” to 6” PV vent

Manufacturers $350 to $10,000 for each PV vent depending on size



### Cost Effectiveness Analysis

District staff has estimated a cost effectiveness f actor for the Proposed Rule 1178. The cost effectiveness for the Proposed Rule 1178 is shown i n Table 6-6. Scenario 1 Staff Proposal (Scenario 1) reflects the impacts of implementing the requireme nts of the Proposed Rule 1178. Specifically, Scenario 1 considered the impacts of:

• Upgrading rim seals and deck fittings on all intern al and external floating roof tanks containing materials with true vapor pressures > 0. 1 psia;

• Installing domed roofs on all external floating roo f tanks containing materials with true vapor

pressures > ≥ 3 psia , excluding crude oil tanks ;

• Converting fixed roof tanks containing materials wi th true vapor pressures > 0.1 psia currently vented to the atmosphere to internal floa ting roof tanks; and

• Maintaining all pressure vacuum vents to meet 500 p pm standard.

The cost effectiveness factor was based on the foll owing assumptions:

Upgrading Rim Seals

• Number of tanks having primary seals that need upgr ading was 3. Number of tanks having secondary seals that need upgrading was 9.

• Average tank diameter was 127 ft for the universe o f tanks in this category.

• Average cost per linear foot of primary seal was $1 07, and secondary seal was $98, as

installed.

• Sales taxes were calculated as 8% cost of rim seals

.

• Capital cost included cost of rim seals as installe d and sale tax.Chapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 26 December 11, 2001 • Annual maintenance cost was estimated based on an a ssumption that it takes one man to work on one tank for 8 hours at a labor rate of $30 /hour.

• Product savings were estimated based on $200/ton em issions. The $200/ton was derived based on an estimated product cost of $0.5 per gall on and a liquid density of 5 lbs/gal for gasoline.

• Annual operating cost included annual maintenance c ost and product savings.

• Total present worth was determined based on discoun ted cash flow method with an assumption of 4% real interest rate, and a 10 year average life of the rim seal system.

• Total emission reduction for this control option wa s approximately 4.01 tpy.

Upgrading Deck Fittings

• Number of guidepoles that need upgrading was 274, n umber of other fittings that need upgrading was 6,281 for external floating roof tank s. For internal floating roof tanks, the numbers were 172 for guidepoles and 1,057 for other fittings.

• Cost of upgrading a guidepole was $10,000 including installation cost.

• Cost of upgrading other fittings was $500 per fitti ng with an installation cost equal to 10% of the cost of upgrading each fitting.

• Sales taxes were calculated as 8% cost of fittings.

• Capital cost included cost of upgrading fittings, g uidepoles, installation costs, and taxes

• Annual maintenance cost was estimated based on an a ssumption that it takes one man to work on one tank for 8 hours at a labor rate of $30 /hour.

• Product savings were estimated based on $200/ton em issions. The $200/ton was derived based on an estimated product cost of $0.5 per gall on and a liquid density of 5 lbs/gal for gasoline.

• Annual operating cost included annual maintenance c ost and product savings.

• Total present worth was determined based on discoun ted cash flow method with an assumption of 4% real interest rate, and a 10 year average life of gaskets, wipers etc. for the roof fittings.

• Total emission reduction for this control option wa s approximately 25.31 tpy from external floating roof tanks, and 40.44 tpy from internal fl oating roof tanks.Chapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 27 December 11, 2001

Table 6-6 – Cost Effectiveness and Incremental Cost Effectiveness Estimates ($/ton VOC reduced) for Proposed Rule 117 8Scenario External Floating Roof Tanks Internal Floating Roof Tanks Fixed Roof Tanks

Upgrading Rim Seals Upgrading

Deck Fittings Installing

Domed
Roofs Upgrading

Rim Seals Upgrading

Deck Fittings Converting

to IFRTs PV VentsStaff Proposal (Scenario 1) Description Control Up to 0.1 psia Control All Control Up to 3 psia

, excluding
crude oil tanks No Control Control All Control Up to 0.1 psia Control Up

to 0.1 psia

No of Tanks/Fittings 9 6,555 241 195

(Note 7) 0 1,229 70 532

Emi
Reduction tpy 4.01 25.31 3 48 24 .2 7 1 0 40.44 62.71 53.20

Present
Worth Value $ 529,388 6,625,884 84,094,145 59 ,292,230 0 2,417,583 15,140,237 2,070,970

Cost
Effectiveness
Factor for
Individual
Control Option $/ton 13,202 26,179 12,073 9,144

(Note 1, 2, 3) 0 5,978 12,072 3,893

Overall Cost
Effectiveness Factor $/ton 11,473 9,583 (Note 4, 5)The Most Stringent Proposal (Scenario 2) Description Control All Control All Control All Control All Control All Control All Control All

No of Tanks/Fittings 66 7,539 526 198 1,393 296 532

Emi
Reduction tpy 11.67 25.31 365.69 14.14 40.44 142.00 53.20

Present Worth Value $ 3,034,926 7,339,174 158,917,205 172,734,311 6,863,178 2,657,283 64,356,360 2,070,970

Cost
Effectiveness
Factor for
Individual
Control Option $/ton 26,006 28,997 21,728 23,618 (Note 1, 2, 3) 48,537 6,571 22,661 3,893

Overall Cost
Effectiveness Factor $/ton 19,855 21,536 (Note 4, 5)

Incremental
Cost
Effectiveness Factor $/ton 113,375 121,330 (Note 4, 6)Chapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 28 December 11, 2001 Note:

1. For Staff Proposal (Scenario 1), the cost effective ness of $9,144 per ton VOC reduced represents the d oming of 195 external floating roof tanks containing materials with TVP ≥ 3 psia at refineries and non-refineries, excluding crude oil tanks. For the most stringent proposal (Scenario 2), the cost effectiveness of $23,618 per ton VOC reduced repres ents the doming of 526 external floating roof tanks containing materia ls with TVP ≥ 3 psia at refineries and non-refineries, including crude oil tanks. The cost effectiveness for tanks containing crude oils was estimated about $62,000 per ton VOC reduced.

2. For doming, the cost effectiveness in Staff Proposa l (Scenario 1) and the most stringent proposal (Sce nario 2) includes cost of domed roofs as installed, cost for obtaining per mits, project management cost, loss-of-use cost, an nual maintenance cost, annual insurance and property taxes, annual emissio n savings, product savings, and self-inspection sav ings.

3. The risk of having fire on domed external floating roof tanks and internal floating roof tanks is lowe r than on external floating roof tanks. However, an extreme worst cas e scenario would include fire suppression system on all domed external floating roof tanks. District staff had performed an analysis including the cost of installing a fire suppression system and maintenance costs associated with such system. For Staff Proposal (Scenario 1), the cost effectivenes s factor for this extreme worst case analysis is $11,332 per ton VOC reduced in comparison to $9,144 per ton VOC reduce d where the cost of fire suppression is not included. For the most stringent proposal (Scenario 2), the cost effective ness factor for this extreme worst case analysis is $28,850 per ton VOC reduced in comparison to $23,618 per ton VOC reduce d where the cost of fire suppression is not included.

4. Under the extreme worst case scenario where the cos t of fire suppression system is included, the overa ll cost effectiveness factor is $10,974 per ton VOC reduced for Staff Pro posal (Scenario 1) in comparison to $9,583 per ton VOC reduced where the cost of fire suppression is not included. For the most stringent proposal (Scenario 2), the overa ll cost effectiveness factor is $24,468 per ton reduced in comparison to $21,536 per ton VOC reduced where the cost of fire suppres sion is not
included. The incremental cost effectiveness facto r is $138,220 per ton VOC reduced for the extreme w orst case scenario in comparison to $121,330 per ton VOC reduced where th e cost of fire suppression is not included.

5. The overall cost estimate factor is calculated as f ollows: [(2 x Sum of All Present Worth Values of t he Control Options that Have 10-Year Life) + (Sum of All Present Worth Valu es of the Control Options that Have 20-Year Life)] / [(Emission Reductions Provided by All Control Options) * 20 Ye ars]

6. The incremental cost effectiveness factor is calcul ated as follows: [Total Present Worth Values of All Control Options in the most stringent proposal (Scenario 2) - Total Presen t Worth Values of All Control Options in Staff Prop osal (Scenario 1)] / [Total Emission Reductions from the most stringent proposal (Scenario 2) - Total Emission Reductions f rom Staff Proposal (Scenario 1)]

7. The count of 195 tanks includes 10 tanks at small r efiners, refer to Table B-6 of Appendix B

Internal Floating Roofs

• Number of fixed roof tanks that need to be converte d was 19 tanks at refineries and 51 tanks

at non-refineries with tank diameters from 30 ft to 120 ft.

• Total cost as installed for the 70 tanks with vario us tank diameters was $10,728,421 . This cost includes the costs of double wiper primary and secondary rim seal systems.

• Sales taxes, freight, engineering, and installation costs were included in total cost as installed.

• A cost for not being able to use the tanks during t he construction of the internal floating roofs were estimated as 40% of equipment cost, based on d ata provided for dome roof installation.

• Annual maintenance cost was estimated at 3% equipme nt cost.

• Annual insurance was estimated at 1% capital cost. Formatted: Bullets and NumberingChapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 29 December 11, 2001 • Product savings were estimated based on $200/ton em issions. The $200/ton was derived based on an estimated product cost of $0.5 per gall on and a liquid density of 5 lbs/gal for gasoline.

• Annual operating cost included annual maintenance c ost, annual insurance and product savings.

• Total present worth was determined based on discoun ted cash flow method with an assumption of 4% real interest rate, and a 20 year average life of the internal floating roofs.

• Total emission reduction for this control option wa s approximately 62.71 tpy.

Domed Roofs

• Number of tanks that need domed roofs was 146 at re fineries and 95 at non-refineries with
tank diameters from 30 ft to 260 ft. Excluding 46 crude oil tanks, the total number of tanks
that need domed roofs was 195.

• Total cost as installed for the 241 tanks with vari ous tank diameters was $49,780,993. Excluding 46 crude oil tanks, the cost as installed was $33,594,943. The costs provided by Manufacturer #1 include tank surveys, engineering d esign and drawings stamped by professional engineers registered in California, ma terials, fabrication, sales taxes, freight, site unloading materials and handling, insurance, and co mplete installation with appropriate license. The costs include at least 10% contingenc y for unusual work such as modification of tank platforms.

• Sales taxes at 8% and freight were included in the cost as installed as provided by the three

manufacturers of domed roofs.

• Cost for permit application was estimated based on a unit cost of $2,115 per application. Note that when applications for doming were to be s ubmitted as a group, cost for permit processing could be reduced.

• Project management was estimated as 5% of equipment cost.

• Capital cost included cost of equipment cost, sale taxes

, and freight , and project
management

.

• It was assumed that domed roofs were installed whil e the tanks were still. A cost for not being able to use the tanks during the construction of the domed roofs was estimated based on the days of construction provided by the manufac turers, and a lease rate for storage of 1.5 cents per barrels per day provided by the refinerie s. The assumption that construction of a domed roof occurs in 24 hours a day, 7 days a week may overestimate the real cost because the construction of the domed roof typically occurs in 8 hours a day and 5 days a week.

• Annual maintenance cost was estimated at 1% equipme nt cost. Formatted: Bullets and NumberingChapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 30 December 11, 2001 • Annual insurance and property tax was estimated at 1 2 % capital cost. It should be noted that this was a conservative estimate because depreciati on was not taken into account.

• Product savings were estimated based on $200/ton em issions. The $200/ton was derived based on an estimated product cost of $0.5 per gall on and a liquid density of 5 lbs/gal for gasoline.

• Annual emission savings were estimated at $819.11 p er ton emissions.

• Inspection savings were estimated assuming that the inspection for rim seals and deck fittings on external floating roof tanks was reduced with th e installation of domed roofs. It was based on 8 hr/day for 3 tanks at $30 per hour.

• Annual operating cost included annual maintenance c ost, annual insurance , annual emission savings, inspection savings and product savings. Note that savings resulting from other benefits of installing domed roofs such as protecti ng the products from contamination, or reducing the costs of replacing rim seals system we re not included.

• Total present worth was determined based on discoun ted cash flow method with an assumption of 4% real interest rate, and a 20 year average life of the domed roofs.

• Total emission reduction for this control option wa s approximately 348.27 324.21 tpy excluding crude oil tanks

.

Pressure Vacuum Vents

• The emission reduction from PV vents was approximat ely 0.1 tpy per vent.

• Annual maintenance cost was estimated at $500 per v ent.

• Product savings were estimated based on $200/ton em issions. The $200/ton was derived based on an estimated product cost of $0.5 per gall on and a liquid density of 5 lbs/gal for gasoline.

• Annual operating cost included annual maintenance c ost and product savings.

• Total present worth was determined based on discoun ted cash flow method with an assumption of 4% real interest rate, and a 10 year average life of a PV vent.

The overall cost effectiveness factor for Scenario 1 Staff Proposal (Scenario 1) was estimated to be $ 11,473 9,583 /ton VOC reduced. The cost effectiveness factor in Table 6-6 shows that the Proposed Rule 1178 is cost effective.



### Incremental Cost Effectiveness Analysis

To determine the incremental cost effectiveness of the most a more stringent control scenario, required under state law, staff has also considered Scenario 2 the most stringent proposal Formatted: Bullets and NumberingChapter 6 – Cost and Cost Effectiveness Analysis Final Staff Report

Proposed Rule 1178 31 December 11, 2001 (Scenario 2) . Specifically, Scenario 2 the most stringent proposal (Scenario 2) reflects the impacts of implementing the following technically f easible control strategies:

• Upgrading rim seals and deck fittings on all intern al and external floating roof tanks;

• Installing domed roofs on all external floating roo f tanks;

• Converting all fixed roof tanks currently vented to the atmosphere to internal floating roof tanks; and

• Maintaining all pressure vacuum vents with vents th at meet the 500 ppm leak standard.

The cost effectiveness for Scenario 2 the most stringent proposal (Scenario 2) was approximately $ 19,855 21,536 per

/ ton VOC reduced, and the incremental cost effective ness of Scenario 2 the most stringent proposal (Scenario 2) compared to Scenario 1 Staff Proposal (Scenario 1) is approximately $ 113,375 121,330 per / ton VOC reduced.Impact Assessment Final Staff Report

Proposed Rule 1178 32 December 11, 2001 

## Chapter 7 – Impact Assessment

Environmental Impact Assessment

Pursuant to the California Environmental Quality Ac t (CEQA) and AQMD Rule 110, appropriate CEQA documentation has been prepared fo r proposed Rule 1178 and is currently
circulated for review. Comments received will be a ddressed when evaluating the potential for adverse environmental impacts from the proposal, an d will be incorporated into the final
document for PR1178.



### Socioeconomic Assessment

A socioeconomic assessment is included as addendum to this staff draft staff r eport.

. will be incorporated into the final document for PR1178.



### Disruption of Production

As shown in Attachment Appendix D, in November, District staff has analyzed the issue of removing storage capacity as a result of the requir ement to install domes on existing external floating roof tanks. Separate analyses have been c onducted for refineries and non-refineries, and for the capacity removal potential as well as the t ank removal potential. The number of tanks and potential domed tanks in Table D-1 and Table D- 2 of Appendix D includes crude oil tanks.



### Refineries

 Tank Removal Percentage
As shown in Table D-1 of Appendix Attachment D, the total number of external floating roof tanks at seven major refineries is 383 , including crude oil tanks . The number of potential domed tanks at these refineries is about 136 tanks in a p eriod of four years. Each year, the 7 refineries are expected to dome 34 tanks, or on average each r efinery is expected to dome 5 tanks. The potential tank removal is therefore approximately ( 34 tanks/383 tanks) = 9% during the doming period.

The doming period varies according to the tank's si ze, which is approximately about 11 days for a 70 ft diameter tank, 25 days for a 150 ft diamete r tank, to a maximum of 63 days for a 260 ft

diameter tank. About 80% of tanks in the refinerie s required doming are in the group of tanks that have diameter of about 150 ft; 10% of tanks ha ve less than 100 ft diameter; and 10% of tanks have diameter more than 200 ft. The average doming period is approximately about 30 days (i.e. (25 days * 0.8) + (11 days * 0.1) + (63 days * 0.1). In that 30 days (8% of the entire 365 days), it is expected that the refineries will loose about 10% of the external floating roof

tanks (Figure D-4) at the site for doming. When all types of tanks ar e considered, including fixed roof tanks, external floating roof tanks, and internal floating roof tanks, the tank removal percentage drops to 5% (Figure D-3)

.Impact Assessment Final Staff Report

Proposed Rule 1178 33 December 11, 2001 Refineries indicated that tanks at refineries were usually removed for routine maintenance following a schedule specified under API 653, "Tank Inspection, Repair, Alteration, and Reconstruction". A typical inspection schedule for tank bottoms recommended in API 653 is between 10 to 20 years depending on whether or not the corrosion rate of the tank bottom is known. Assuming that an average routine maintenanc e schedule is 15 years and that all types of tanks would be removed at the same rate, then appro ximately 26 external floating roof tanks (383 total external floating roof tanks / 15 year = 26 t anks/year) are expected to be removed from service in any one year for the 7 refineries for ro utine maintenance. If the doming schedule of the PR1178 was expanded to 6 years, the average dom ing rate would become 23 tanks/year, which is less than the average rate of removal tank s for routine maintenance.

In December, upon recommendations received from ind ustry, District staff has proposed to exempt crude oil tanks from the doming requirements , and provide an implementation period of 6 years instead of 4 years. When these two factors are taken into the analysis, the tank removal percentage drops from 10% (Figure D-4) to 6% (Table D-3)

.

 Capacity Removal Percentage In November, a A n analysis has been done for capacity removal by lo oking at the capacity of all

the tanks at the refineries. During the four year perio d to dome these external floating roof tanks, approximately 1.13% (on average) (Figure D-1) of the total storage capacity could be taken out of service at any one time when the capacity of all the types of tanks at refineries are considered. The loss of capacity ranges from 0.12% to 2.15% for the 7 refineries. When capacity of only external floating roof tanks are considered, the av erage capacity removal percentage is 1.66 (Figure D-2).

In December, upon recommendations received from ind ustry, District staff has proposed to exempt crude oil tanks from the doming requirements , and provide an implementation period of 6 years instead of 4 years. When these two factors are taken into the analysis, the capacity removal percentage drops from 1.66% (Figure D-2) to 0.6% (Table D-3)

.



### Non-refineries

 Tank Removal Percentage Staff’s analysis of non-refineries (tank farms and loading racks) indicates a greater percentage of lost tank capacity. During the four year period to dome these external floating roof tanks, approximately 10% (on average) (Figure D-7) of the total tanks could be taken out of service at any one time when all types of tanks are considered . The percentage will increase to 2 0 1 % when only external floating roof tanks are considered (Figure D-8) . The tank removal percentage ranges from 3% to 25% for the 14 non-refineries.

In December, upon recommendations received from ind ustry, District staff has proposed to exempt crude oil tanks from the doming requirements , and provide an implementation period of 6 years instead of 4 years. When these two factors are taken into the analysis, the tank removal percentage drops from 21% (Figure D-8) to 14% (Table D-4)

.Impact Assessment Final Staff Report

Proposed Rule 1178 34 December 11, 2001  Capacity Removal Percentage Staff’s analysis of non-refineries (tank farms and loading racks) indicates a slightly greater percentage of lost storage tank capacity. During t he four year period to dome these external floating roof tanks, approximately 1.33% (on averag e) (Figure D-5) of the total storage capacity

of all tanks could be taken out of service at any one time. The loss of capacity ranges from

0.14% to 3.27% for the 14 non-refineries. The percentage will increase to 2.47% (Figure D-6) when only external floating roof tanks are consider ed.

In December, upon recommendations received from ind ustry, District staff has proposed to exempt crude oil tanks from the doming requirements , and provide an implementation period of 6 years instead of 4 years. When these two factors are taken into the analysis, the capacity removal percentage drops from 2.47% (Figure D-6) to 1.67%.



### Gasoline Cost Impact to Consumer

Implementation of PR1178 would result in an expendi ture of approximately $86 million (i.e. the total present worth values estimated for all contro l strategies in Staff Proposal (Scenario 1) of Table 6-6). The amount of gasoline dispensing in t he District is about 6 billion gallons per year (Reference: Staff Report of Amended Rule 461 - "Gas oline Transfer and Dispensing", April 14, 2000). If the cost of implementing the PR1178 is p assed on to the consumers, the consumers are expected to pay an increase of approximately 0.23 cents per gallon in gasoline cost during the six years of Phase I of the rule, or an increase of 0.07 cents per gallon if the cost is amortized over the 20-year life of the project.

With a similar approach, the control strategy of do ming as suggested in the PR1178 would result in an expenditure of approximately $59 million; thi s is approximately equivalent to an increase of 0.16 cents in gasoline cost during the six year s of Phase I of the rule, or an increase of 0.05 cents per gallon if the cost is amortized over the 20-year life of the project.



### Comparative Analysis

Under the Health and Safety Code Section 40727.2, t he District is required to compare and analyze this Proposed Rule 1178 with existing state or federal regulations. This analysis is attached in the Appendix E of this Draft Staff Repo rt.



### Draft Findings Required by the California Health an d Safety Code

Under the Health and Safety Code Section 40727, the District’s Governing Board is required to make findings of necessity, autho rity, clarity, consistency, nonduplication, and ref erence before adopting a rule, such as Proposed Rule 1178.Impact Assessment Final Staff Report

Proposed Rule 1178 35 December 11, 2001 Necessity: The District’s Governing Board has determined that a need exists to adopt Proposed Rule 1178 to implement control measure FUG03, FUG04 , and FUG05 in the 1999 AQMP.

Authority: The District obtains its authority to adopt, amend or repeal rules and regulations from Sections 39002, 40000, 40001, 40440, 40702, an d 41508 of the California Health and Safety Code.

Clarity: The District’s Gover ning Board finds and determines that Proposed Rule 1178 as proposed to be adopted is written or displayed so t hat its meaning can be easily understood by the persons directly affected by it.

Consistency: The District’s Governing Board has determined that the Proposed Rule 1178 as proposed to be adopted is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, or state or federal regu lations.

Nonduplication: The District’s Governing Board has determined that the Proposed Rule 1178 as proposed to be adopted does not impose the same requirements as any existing state or federal regulation.

Reference

– In adopting this proposed rule, the AQMD Governing Board references the following statutes, which AQMD hereby implem ents, interprets or makes specific. Health and Safety Code Sections 40000, 40001, 40440, and 40727

.Comments and Responses Final Staff Report

Proposed Rule 1178 36 December 11, 2001 

## Chapter 8 – Comments and Responses

The following summarizes verbal and written comment s received on and after the Public Workshop for PR1178.



### Applicability

1-1 Comment

It is proposed that the applicability of the rule t o a facility be based on that facility having
exceeded a threshold of 20 tons of VOC emissions in any reporting year beginning in 1999. We believe that there are certain aspects of this applicability threshold that should be either clarified or changed. We submit that it is not reasonable for a facility to become subject to the rule by virtue of a one-year anomaly in emissions – especially in light of the potential need to temporarily increase throughp ut at one facility when tanks are taken off line at another facility in order to install co ntrols mandated by this rule. Such unintended (and, we submit, punitive) consequences would be avoided if the applicability of the rule were based on exceeding the 20 ton/year threshold for five consecutive years.

Response
In 1999, the District settled litigation initiated by three environmental organizations, the Natural Resources Defense Council (NRDC), the Coali tion for Clean Air, and the Communities for a Better Environment (CBE) for fail ing to implement the 1994 AQMP. The settlement agreement, which was incorporated in the 1999 AQMP amendments, in part, commits the AQMD to further study fugitive em issions from tanks and pressure relief devices (PRDs) operated by refineries and pr oceed with amendments to existing rules and/or the development of new rules in the ev ent the study(ies) identify meaningful emission reduction potentials and technologically f easible and cost-effective controls. Also, AQMD Control Measure FUG-05 - Further Emissio n Reductions from Large Fugitive VOC Sources focuses on reducing fugitive emissions from the top 100 VOCemitting facilities. The top VOC-emitting faciliti es targeted in this control measure consist mainly of petroleum facilities that emit 20 tons or more per year, and this is not expected to change significantly from year to year. In addition, PR1178 is designed to implement the first phase of FUG-05. With respect to those facilities that trigger the applicability of PR1178 in the future due to an inc rease in throughput and emission and to accommodate the facility that takes tanks off-li ne to comply with the PR1178, staff is proposing an extended compliance schedule and the o ption to either dome or accept a permit condition for the facility's external floati ng roof tanks that may become subject to the rule (Subparagraph (d)(2)(B) and (d)(2)(C) of P R 1178).

1-2 Comment

The applicability determination should include a re view of several years, rather than one year. As we understand it, once a facility is incl uded it cannot be removed. The factors

that contribute to our facilities’ emission invento ry include tanks, fugitives and loading racks. The emissions from the loading racks can fl uctuate from year to year depending

on the results of the source test data. It is our understanding that the purpose of this ruleComments and Responses Final Staff Report

Proposed Rule 1178 37 December 11, 2001 is to reduce emissions from storage tanks, therefor e, we would suggest that the applicability be based on emissions from the aboveg round storage tanks exclusively over a five year period. We suggest consideration that if in a five year period the facility consistently has aboveground storage tank emissions of 20 tons or greater, then the facility would be included in 1173.1. (1178)

Response

Please refer to the Response to Comment 1-1. In ad dition, please note that PR1178 is implementing Phase I of the Control Measure FUG-05. Focuses on further reducing emissions from storage tanks operated by petroleum facilities in Phase II and Phase III will focus on other emission sources within the top VOC emission sources. Emission reductions of 1.47 tons per day of VOC based on a u niverse of facilities reporting total VOC emissions of 20 tons per year or greater. To l ower the applicability threshold by looking only at tank emissions would require greate r emission reductions from other fugitive sources at petroleum facilities to meet th e goals of Control Measure FUG-05 and would leave out a number of high emitting VOC facil ities.

1-3 Comment

We understand that the 20-ton hurdle to identify ta nks that are subject to the new rule was

selected because it limited the number of facilitie s affected at this time. This is an inadequate justification. We recommend the hurdle be tied directly to tank emissions at a facility. The contribution of emissions from tanks may not correlate with entire facility emissions. A selection criteria of 10 tons per year of VOC from tank emissions, borrowing the 10 tons from the definition of a majo r source in the SCAQMD, is a recommended alternative to identify whether a facil ity is in the program or out of the

program.

Response

Please refer to Responses to Comment 1-1 and 1-2. In addition, the definition of a major source is based on total facility emissions and not limited to a specific equipment categoty within a facility.

1-4 Comment

Use AQMD Rule 463 applicability standards. While we appreciate the simplicity of the language (tanks greater than 19,815 gallons storing organic liquids with a TVP greater than 0.1 psia) the Rule establishes another distinc t layer of complexity in determining which rules apply to which tanks. We currently hav e tanks regulated by MACT, NSPS, NESHAP and AQMD Rule 463. For the sake of consiste ncy with Rule 463, which was often indicated by District staff as a goal in deve loping the proposed Rule, we would appreciate similar language for tank applicability. That is, for tanks larger than 39,630Comments and Responses Final Staff Report

Proposed Rule 1178 38 December 11, 2001 gallons the triggering TVP would be ≥ 0.5 psia and for tanks greater than 19,815 gallons the triggering TVP would be ≥ 1.5 psia [Rule 463(c)].

Response

The purpose of this proposed rule is to “further” ( emphasis added) reduce volatile organic compounds emissions from storage tanks located at p etroleum facilities. To use Rule 463 applicability standards would not achieve the emiss ion reduction goals associated with the Control Measure FUG-05 (see Response to Comment 1-1 and 1-2).

1-5 Comment

As written, the Rule has no provisions for faciliti es that may come into the program late. A facility with just under 20 tons/year emissions w ill not be subject to the Rule. If either through growth or changes in correlation equations for emissions, the facility later exceeds the 20 tons/year, what time frame will they be subject to for implementing the
Rule?

Response

Staff has added rule language to address this issue . Please refer to PR1178 (d)(5).

1-6 Comment

Rule applicability is based on vapor pressure, howe ver vapor pressure can vary for the same product over the course of the year, depending on temperature, etc. Will the true vapor pressure be based on an annual average or bas ed on the highest vapor pressure at some maximum temperature? The use of a maximum vap or pressure from a single measurement could cause tanks normally exempt to be captured by the rule.

Response

Staff has included rule language to clarify that ru le applicability for doming will be based on the true vapor pressure at average storage tempe rature of 7 5 0 degrees F.

1-7 Comment

A facility has overall VOC emissions greater than 2 0 tpy and is included in the program. Later on the facility reduces its emissions below t he 20 tpy limit. Will the facility be removed from the program?

Response

Once it is established that a facility has satisfie d the criteria to be included in the program, the facility will not be removed from the program.Comments and Responses Final Staff Report

Proposed Rule 1178 39 December 11, 2001 1-8 Comment

Oil and gas producers are required to report emissi ons for unpermitted equipment such as well heads and well cellars. To quantify the emiss ions from these sources very conservative default emission factors (provided by the District) were used. Will the District provide us with a list of all applicable f acilities and will facilities be allowed to go back and revise these emissions?

Response

Regulation 3 allows a facility to use source testin g or other reliable information to revise the emissions reported to the District. In additio n, Rule 1178 staff report will include a list of all facilities initially included in the pr ogram. That is based on reported emissions

to the District.

1-9 Comment

Replace the compliance plan with a requirement to s ubmit a notification of compliance status report at each milestone in the compliance s chedule.

Response Staff has amended rule language to address this iss ue by requiring an annual status report. Please refer to PR1178 (d)(2)( E G ).

1-10 Comment
The proposed Rule, while claiming credit for AQMP c ontrol measures FUG-03, FUG-04, and FUG-05, has an approach, which often displaces the overall goal of reducing emissions. For example, the reduction claimed in t he Rule based on seal location (vaporvs. liquid-mounted) has no technical argument which supports a reduction in emissions. The Vapor Tight Condition as defined in the Rule al so has no emission reduction benefit.

We recommend the District to reconsider their focus in these areas since real emission reductions from them are suspect. Response

The issue regarding the terminology used to describ e the types of primary and secondary seals has been clarified and incorporated into prop osed rule language. Staff disagrees with the comment that the vapor tight condition (re quirement) has no emission reduction benefit. The purpose of establishing a fugitive le ak level of 500 PPM VOC is to reduce emissions through increased monitoring and maintena nce. Staff has inspected, monitored, tested, and analyzed several roof openin gs associated with storage tanks and measured VOC concentrations in excess of 100,000 PP M, which was equivalent to an emission rate of approximately 9 pounds per hour. A qualitative assessment (based on the “dirt” build-up) was that some of the roof openings had not been maintained in quite some time. In addition, measuring for the vapor ti ght condition (as per EPA Method 21) provides operators with an alternative to measuring gaps for gaskets and/or seals, etc..Comments and Responses Final Staff Report

Proposed Rule 1178 40 December 11, 2001 

### Definitions

2.1 Comment

The definition of guidepole needs to be more broadl y applicable. The definition should be revised as follows: The Guidepole is an anti-rot ation device that is fixed to the top and the bottom of the tank, passing through a well that is equipped with a sliding cover. The guidepole may be used to prevent adverse movement of the roof and s ubsequent damage to the roof fittings and rim seals, or as access fo r level gauging or sampling of the liquid stock. The guidepole can be solid or equipped with slots or holes for gauging purposes.

Response

District staff has considered the recommendation, h owever the word "may be" creates uncertainty in the definition, therefore will not b e used. The definition has been revised to incorporate the comm ents above.

2.2 Comment

In the definition of Liquid-Mounted Primary Seal, t he reference to mechanical shoe seal should be deleted, since a mechanical shoe seal is distinctly separate from either liquidmounted or vapor-mounted rim seal and each type of seal is assigned a separate and specific emission factor by the U.S. EPA in the Tan ks 4.0 software for estimating
emissions. The definition should read as follows: Liquid Mounted Primary Seal is a primary seal that is mounted in full contact with t he liquid in the annular space between the tank shell and the floating roof.

Response

The definition has been revised to incorporate the comments above.

2.3 Comment

In the definition of Vapor-Mounted Primary Seal, th e reference to mechanical shoe seal should be deleted, since a mechanical shoe seal is distinctly separate from either a vapormounted or a liquid-mounted rim seal and each type of seal is assigned a separate and specific emission factor by the U.S. EPA in the Tan ks 4.0 software for estimating
emissions. The definition should read as follows: Vapor-Mounted Primary Seal is a primary seal that does not come in contact with the liquid in the annular space between the tank shell and the floating roof.

Response

The definition has been revised to incorporate the comments above.Comments and Responses Final Staff Report

Proposed Rule 1178 41 December 11, 2001 2.4 Comment

The Pole Float definition should have broader appli cability and should read as follows: Pole Float is device located inside a guidepole, wh ich floats on the surface of the stored liquid and may be used to indicate the liquid level inside the tank.

Response

District staff has considered the recommendation, h owever the word "may be" creates uncertainty in the definition, therefore will not b e used. The definition has been revised to incorporate the comments above.

2-5 Comment

The definition of Pole Sleeve should be revised to incorporate a typographical error and
should read as follows: Pole Sleeve is a device th at extends from either the cover or the rim of an opening in a floating roof deck to the ou ter surface of a pole that passes through the opening.

Response

The definition has been revised to incorporate the comment above.

2-6 Comment

The definition of Pole Wiper should be revised to i ncorporate a typographical error and should read as follows: Pole Wiper is a seal that extends from either the cover or the rim of an opening in a floating roof deck to the outer surface of a pole that passes through the opening.

Response

The definition has been revised to incorporate the comment above.

2-7 Comment

The definition of Visible Gap should be revised to read as follows: Visible Gap is a gap of more than 1/8 inch between any gasket or seal an d the opening that it is intended to

seal.

Response

The definition has been revised to incorporate the comment above.

2-8 CommentComments and Responses Final Staff Report

Proposed Rule 1178 42 December 11, 2001 The Roof Drain definition should be revised to indi cate that the open roof type of drain is typically used only during emergency.

Response

The definition has been revised to incorporate the comment above.

2-9 Comment

The Gauge Hatch/Sample Port definition should be re vised to replace "self-closing" cover with "closing" and should be revised as follows: G auge Hatch/Sample Port is an opening in the roof that provides access for gauging or sam pling. The gauge hatch/sample port is usually equipped with a closing cover or a funnel a nd slit-fabric seal to cover the opening.

Response

The definition has been revised to incorporate the comment above.

2-10 Comment

The definition of Pressure-Vacuum Vent should be re vised to include the safety features to prevent tank damage and should be revised as fol lows: Pressure-Vacuum Vent is a safety device designed to prevent damage to the tank and to mini mize emissions due to breathing effects.

Response

District staff has considered the recommendation, h owever the word "safety device" creates uncertainty in the definition, therefore wi ll not be used. The definition has been revised to incorporate the comment above.

2-11 Comment

The definition of Primary Seal should be revised as follows: Primary Seal is a seal mounted below a secondary seal of a rim seal system . A primary seal, which slides in contact with the floating roof tank shell, can be m echanical shoe, resilient filled or wiper
type.

Response

The definition will have "is" in place of "slides". The definition has been r evised to incorporate the comment above.Comments and Responses Final Staff Report

Proposed Rule 1178 43 December 11, 2001 2-12 Comment

The definition for Resilient Filled Primary Seal sh ould be revised as follows: Resilient Filled Primary Seal is an envelope filled with resi lient foam (non-metallic polyurethane) mounted at the rim of the floating roof that makes contact with the shell. A resilient filled nonmetallic primary seal can be liquid-mount ed or vapor-mounted.

Response

The definition has been revised to incorporate the comment above.

2-13 Comment

The definition of Rim Mounted Secondary Seal should be revised to exclude the portion that references the purpose of the secondary seal a s an additional evaporative loss control device that compensates for defects in the primary seal fabric in emission losses.

Response

The definition of Rim Mounted Secondary Seal has be en revised.

2-14 Comment

The definition of Rim Seal System should be revised as follows: Rim Seal System is a closure device between the shell of the storage tan k and the floating roof edge. A rim seal may consist of two seals, one above the other. The lower seal is referred to as the primary seal and the upper seal is referred to as t he secondary seal.

Response

The Rim Seal System definition has been revised to incorporate the comment above

2-15 Comment

The definition of Rim Vent should be revised as fol lows: Rim Vent is a device consisting of a weighted-pallet that rests on a valve seat. R im vents are used to release any excess pressure or vacuum present in the vapor pocket betw een the seal and the rim area of a floating roof tank.

Response

The definition of Rim Vent has been revised to inco rporate the comment.Comments and Responses Final Staff Report

Proposed Rule 1178 44 December 11, 2001 2-16 Comment

The definition of Roof Leg should be revised as fol lows: Roof Leg is a device that holds the floating roof at a predetermined distance from the tank bottom to allow for tank cleaning or repair. There are two types of roof le gs, adjustable or fixed. Fixed roof legs are attached to the floating roof or to hangers sus pended from the roof, whereas adjustable legs pass through a well or sleeve, and penetrate the roof.

Response

The definition of Roof Leg has been revised to inco rporate the comment.

2-17 Comment

Provide definitions for the terms “welded” and “riv eted” tanks. The Rule is making a
distinction between welded tanks and riveted tanks. We would appreciate defining language because we have tanks in service with both riveted and welded sections. However, we propose that the seal standard be consi stent with riveted tanks because of potential damage rivets can have on seals.

Response

Staff has revised proposed rule language to elimina te the distinction between welded and

riveted tanks.

2-18 Comment

Clarify the intention of the term “roof covers” in section (g)(3). The term “roof covers”

found in this section was meant to be “covers for r oof fittings” according to District staff at the Workshop for PR 1178 on September 5, 2001.

Response
Staff has revised proposed rule language to incorpo rate this comment.



### External Floating Roof Tanks

3-1 Comment

There should be language included in the rule that allows the use of alternative materials that meet the same performance standard as the VOC impervious sock used to cover or plug the adjustable roof legs when the roof of the tank is floating.

Response

Rule language has been added to incorporate this co mment. Please refer to clause (d)(1)(A)(iii). Gasket is allowed in place of sock

.Comments and Responses Final Staff Report

Proposed Rule 1178 45 December 11, 2001 3-2 Comment

Under the requirements section of PR1178, it is req uired that the primary seal be liquid mounted for welded tanks and vapor mounted for rive ted tanks. This is not consistent with the draft staff report, which identifies vapor -mounted seal only as an option for riveted tanks although vapor mounted seals are not allowed under Rule 463. A correction should be made to require mechanical shoe seals for both welded and riveted tanks which are required to extend into the liquid per Rule 463

.
Response

Rule language has been modified to incorporate this comment. Please refer to clause (d)(1)(B)(i).

3-3 Comment

The definition of vapor tight condition for Rule 11 78 (portable hydrocarbon analyzer reading of 500 ppm expressed as methane above backg round), is more stringent when compared to the definition expressed in Rule 463 wh ich requires that the limit be 1000 ppm expressed as methane above background.

Response

The purpose of this proposed rule is to further red uce VOC emissions from storage tanks located at petroleum facilities. To only use Rule 463 requirements and standards would not achieve the emission reduction goals associated with the SIP Settlement Agreement and Control Measure FUG-05. The vapor tight defini tion of 500 ppm will be applicable to the deck fitting seals of external floating roof tanks and to the, piping, valves, vents and openings of fixed roof tanks. This requirement will also be applicable to pressure
relief vents associated with these fixed roof tanks

.Comments and Responses Final Staff Report

Proposed Rule 1178 46 December 11, 2001 3-4 Comment
Delete the references to ‘vapor tight’ and ‘visible gaps.’ As noted at paragraphs (d)(1)(C), (d)(2)(B), and (d)(3)(C) and (D), the va por tight requirement is inappropriate for floating roof tanks. Additionally, as noted at paragraph (d)(1)(B)(iii), rim seals are allowed a specified amount of gap that is greater t han the no visible gap definition would allow. These phrases should therefore be deleted s o that this paragraph reads as follows:

(3) The operator shall repair, or replace any pipi ng, valves, vents, seals, gaskets, or roof

covers that are found to have defects or do not mee t all the requirements of this rule before filling or refilling the storage tank, or wi thin 72 hours after the inspection

whichever occurs first.

Response

Proposed rule language has been modified to require vapor tight condition measurements (as per EPA Method 21) for roof openings and rim se als for floating roof tanks. Operators can either

measure gaps or measure for vapor tight condition for roof openings. The draft proposed rule language requiring no visib le gaps for the primary and secondary on external floating roof tanks has been removed. Compliance with rim seal requirements shall be determined only through gap m easurements, as specified in the proposed rule which are consistent with Rule 463.

3-5 Comment
Delete the requirement for a "vapor tight condition ". A vapor tight condition is defined in paragraph (c)(38) as resulting in readings on a portable hydrocarbon analyzer of less than 500 parts per million (PPM), expressed as meth ane, above background. Testing for leaks with an organic vapor analyzer (OVA) or other portable hydrocarbon analyzer is not an appropriate monitoring method for floating r oofs. This testing to determine a socalled "vapor tight condition" is appropriate for c losed piping systems that route vapors to an emission control system, but is not a meaning ful measure of whether a floating roof is in compliance with the specified equipment stand ard. There is no technical basis for asserting that compliance with OVA monitoring would reduce the rate of emissions past a floating roof and, in fact, the District does not claim any reduction in emissions associated with this proposed provision. Furthermo re, entry onto the floating roof in order to perform this monitoring has significant sa fety concerns.

A requirement to perform OVA monitoring of internal floating roofs would, then, divert resources to an activity that has no associated env ironmental benefit while involving significant costs and safety considerations. This is not an appropriate outcome, and

therefore paragraph (d)(2)(B) should be deleted in its entire ty

.
Response

Proposed rule language has been modified to require vapor tight condition measurements (as per EPA Method 21) for roof openings and rim se als for internal floating roof tanks. Operators can either

measure gaps or measure for vapor tight condition for roof openings.Comments and Responses Final Staff Report

Proposed Rule 1178 47 December 11, 2001 Compliance with rim seal requirements shall be dete rmined only through gap

measurements.

3-6 Comment
Delete emission reduction claimed for liquid-mounte d rim seals.

Response

Staff has amended the preliminary draft staff repor t to incorporate this comment.

3-7 Comment

Allow for mechanical shoe primary seals without vap or- or liquid-mounted distinction. We point out that the mechanical shoe seal is a dis tinct category of seal for purposes of both EPA rule compliance and emissions estimating r egardless of where the seal fabric is attached [ liquid mounted – in contact with the liquid; vapor mounted – upper surface of the roof.] In addition, under AQMD Rule 463, mecha nical shoe seals are considered Category A type (see Attachment A). Accordingly, w e have been installing this type of seal throughout the Carson and Wilmington plants (s ee Figure 1 in Attachment A). In fact, with an estimated 82 tanks to be impacted by this provision of the Rule alone, we predict the seal requirement, as worded, to be as b urdensome, if not more so than installing domes on external floating roof tanks. W ithout some compromise on this issue, the proposed compliance dates would be impossible t o satisfy and far from cost effective.

Response Staff has revised proposed rule language to incorpo rate this comment.

3-8 Comment

Clarify what is meant by the term “openings.” This section declares rather generically that openings in the roof are to be kept in a vapor tight condition. The logical question follows: will allowable seal gaps be considered “op enings”? We would hope not because the 500 ppmv limit would most certainly be exceeded through allowable seal gaps. Furthermore, entry onto the floating roof in order to perform the monitoring has significant safety concerns

Response

Staff has revised proposed rule language to define the term roof openings. Rim seals are not included in the definition of roof openings. Co mpliance with rim seal requirements shall be determined only through gap measurements.Comments and Responses Final Staff Report

Proposed Rule 1178 48 December 11, 2001 3-9 Comment
Remove performance based requirement as defined by vapor tightness. We appreciate

the 41-item definition section. We can tell much w ork went into developing this list. We would, however, ask the District to reconsider the VAPOR TIGHT CONDITION as outlined in the Rule [ a condition that exists when the reading on an OVA is less than 500 ppmv, expressed as methane, above background. ] We accept that it was the intention of the District to include this provision as a way to ease the burden of inspections (in lieu of seal gap measurements). However, this provision cr eates uncertainty concerning potential enforcement activity and has no associate d environmental benefit. Imagine the burden we would face if, five years from now, we ha ve tanks with upgraded deck fittings and rim seals and newly installed domes [i,e., in t otal compliance with all hardware specifications of the Rule] and yet, are still not satisfying the Vapor Tight Condition. What further improvements are available to us? We recommend the District include clear and definitive language in the Rule of option s available to refineries that find themselves in such a predicament.

Response

Please refer to Response to Comment 3-5. Proposed rule language has been modified to require vapor tight condition measurements (as per EPA Method 21) for roof openings (deck fittings) for fixed roof tanks. The operator s can either measure gaps or measure for vapor tight condition for roof openings for both do med and internal floating roof tanks. Compliance with rim seal requirements shall be dete rmined only through gap measurements. Please note that staff has inspected from several roof openings at one refinery (with a quarterly inspection and maintenan ce program) and measured VOC
levels at 50 PPM or less.

3-10 Comment

Remove requirement to bolt covers on gauge float we lls. We expect an enormous impact from the requirement to bolt covers on gauge float wells in addition to the placement of gaskets. The gauge float wells on our tanks do not have the side flange necessary to bolt the covers. We would be required to weld this flan ge onto the well in order to satisfy this Rule requirement. For safety reasons associated wi th welding (hot-work) we are required to empty the tank. Furthermore, the bolting requir ement of the Rule would require us to hire additional operators. Our procedure would hav e an operator at the base of the tank and another on top of the tank while a third, addit ional operator descends onto the floating roof to unbolt the gauge well. Depending on the stored liquid, the third operator descending on the roof may require respiratory equi pment. These safety concerns, the additional staff, and the fact that an estimated 89 tanks are to be captured by the Rule presents enormous concerns for us. The requirement to gasket these gauge float wells is consistent with 40 CFR 60, Subpart Kb. Bolting exceeds the federal requirements and is unattainable in the proposed compliance time frame of the Rule (July 1, 2002).Comments and Responses Final Staff Report

Proposed Rule 1178 49 December 11, 2001 Response

Staff is reviewing this issue and will work with in dustry to develop appropriate rule language.

3-11 Comment
Allow 10 years to upgrade existing internal floatin g roofs. The performance of any work on an internal floating roof requires entry into th e tank. For obvious safety reasons, modifications to internal floating roofs generally require that the tank be emptied and degassed. The U.S. EPA has consistently determined during its own rulemaking that the marginal emission reductions that result from the u pgrade of existing IFRs do not warrant emptying and degassing the tank to achieve them. U .S. EPA regulations allow up to ten

years 6 for the upgrade of existing internal floating roof s, in order to allow most upgrades to be performed when the tank has been taken out of service for a regularly scheduled inspection. Revise the schedule to state that the internal floa ting roof shall be equipped as specified the next time that the tank is emptied and degassed, but in any case within 10

years. 1 e.g., Refinery MACT [40 CFR Part 63, Subpart CC, S ection 63.640, paragraph (h)(4)]; the HON [40 CFR Part 63, Subpart G, Sectio n 63.119, paragraphs (b)(3)(iv) & (b)(5)(viii)].

Response

Staff has revised proposed rule language to extend the compliance period from July 1, 2002 to “the next time an internal floating roof ta nk is scheduled for emptying and degassing, but no later than January 1, 2007.” Staf f believes that five years is a sufficient amount of time to address these upgrades required f or internal floating roof tanks.

3-12 Comment A key advantage to IFRTs is increased usable tank c apacity from operating the floating roof at a higher level, closer to the fixed roof wi thout interference from the secondary seal. However, with the secondary seal still intac t, tank fill capacity is lost when the fixed dome is installed. Federal regulations (40 C FR 60, Subpart Kb) require only a single liquid-mounted primary seal or mechanical sh oe for an IFRT. Therefore, we recommend language in the Rule that would exempt ta nks from having their secondary seals installed if a dome installation were require d. The Rule revision should also include language that would support the removal of the seco ndary seal, as an option, if a dome installation were required.

ResponseComments and Responses Final Staff Report

Proposed Rule 1178 50 December 11, 2001 All of the external floating roof tanks containing materials >3psia currently have primary and secondary seals. District staff view the remov al of secondary seals on external floating roof tanks is a step back from the current level of control. Therefore, District staff does not agree with the comment that the rule should exempt tanks from having their secondary seals installed, or should include language that would support the removal of secondary seals if a dome installation w ere required. District staff has performed a cost effectiveness analysis for install ing secondary seals on existing internal floating roof tanks, and because it was not cost ef fective, District staff did not recommend to upgrade the rim seal systems of intern al floating roof tanks. Regarding the issue of loosing tank capacity by installing domed roofs, District staff understands that

domed roofs can be installed with sidewalls so that they will not reduce tank capacity, and the budget prices provided by the manufacturers allow for this addition.

3-13 Comment

Do not specify any monitoring requirement for an IF RT that would require entry into the tank while it contains organic liquids. Entry onto the floating roof of an IFRT poses significant safety concerns related to confined spa ce entry, and it is unnecessary for adequately monitoring the condition of the internal floating roof. The existing inspection and monitoring procedures specified in AQMD Rule 46 3 have been effective, and they

should continue to be the standard for internal flo ating roofs (including any external floating roofs that have been converted to internal floating roofs by the installation of an aluminum dome fixed roof). WSPA strongly opposes a ny provision that would require personnel to enter an IFRT while the tank contains organic liquids.

Response

The proposed rule language has been revised to requ ire visual and LEL inspections semiannually. In addition to these semiannual insp ections, District staff recommended the facilities to perform a complete gap measuremen t of rim seal systems and deck fittings once every 10 years or any time the tanks are emptied and degassed. Note that Federal rule 40CFRPart 63 Subpart WWW and Bay Area Rule require a full inspection of rim seal system and deck fitting once every 10 year s.



### Domed External Floating Roof Tanks

4-1 Comment

If external domes must be installed, the peripheral , top and circulation vents must remain

open.

Response

District staff agrees with the comment, and has rev ised the language of the proposed rule appropriately.Comments and Responses Final Staff Report

Proposed Rule 1178 51 December 11, 2001 4-2 Comment

The requirement to immediately prepare and submit a compliance plan for installing domes imposes an undue burden that has no environme ntal benefit.

Response

District staff agrees with the comment. Therefore, staff has replaced the requirement of submitting a compliance plan with a requirement of submitting a status report at each milestone in the compliance schedule. The status r eport would include status of all tanks subject to the domed roof requirements, and the ope rator would provide an estimated compliance date for the tanks that have not yet com plied with the requirements.

4-3 Comment

Bay Area AQMD did not require the installation of d omed roof tanks to control

emissions.

Response

The 1999 Settlement Agreement required the AQMD to review the Bay Area AQMD storage tank rules as well as other potential contr ol options not incorporated into the Bay Area rule and consider any appropriate requirements during our rule development. Therefore, the AQMD is not limited to the scope and requirements of the Bay Area AQMD rules. AQMD analysis demonstrated that the in stallation of domes on external floating roof tanks is a cost effective method to r educe VOC emissions.

4-4 Comment

Industry is concerned that covering their external floating roof tanks with domes will require a different fire suppression system than th e one that they currently use for external floating roof tanks. This is due to the f act that they feel there is a need for a fire suppression system designed to work within the conf ines of the domed space.

Response

Internal Floating Roof Tanks generally have reduced fire risks when compared to External Floating Roof Tanks (EFRTs) and the use of fixed fire suppression systems is often not mandatory (Reference: Footnote 1 of Appen dix H of Addendum 2 of API 650, Draft Release on September 2001). Information prov ided by a dome manufacturer also indicates that over 80 percent of tank fires occur on EFRTs due to the fact that the rim seal area and pontoons may be exposed to lightning and external fire sources such as nearby flares.Comments and Responses Final Staff Report

Proposed Rule 1178 52 December 11, 2001 Despite the fact noted above, each facility will be required to meet the Fire Department Codes of the City in which they are located and may be required to install a fire suppression system. However, each facility will ha ve to be evaluated on an individual basis. In addition, there are facilities to which this rule applies that do have aluminum domes in place with fire suppression systems.

4-5 Comment Support the API Standard 650 specifying domed roof tanks to freely vent. As with internal floating roof tanks, the function of the “ domed” roof on external floaters is not to act as a vapor barrier, but to block the wind. Acc ordingly, we strongly advocates Rule language that supports the API Standard 650 positio n specifying that such tanks freely vent to atmosphere for safety reasons. From our me eting with AQMD staff on September 20 th , it was made clear to us that the API consideratio n is the District’s intent. We recommend definitive language on this issue in a ny future Rule revision. Response Staff has revised proposed rule language to incorpo rate this comment.

4-6 Comment

According to some construction companies, domed roo fs may be installed while the tank remains in-service. If any part of the dome instal lation is hot-work, the tank must be emptied and removed from service. The cost associa ted with this will add to the equipment cost. Therefore, a refinery strongly adv ocates an average cost of approximately $310,000 per dome.

Response The equipment cost that District staff received fro m the manufacturers vary with tank size, as shown in Figure 6-1 of the Draft Staff Rep ort. District staff has recently added the "loss-of-use" cost, which is about 40% of the e quipment cost on top of the costs that

the District received from the manufacturers. The total cost is about $300,000 for a 150 ft diameter tank, $74,000 for a 50 ft diameter tan k, and $1.75 million for a 260 ft diameter tank. Instead of using an average cost, D istrict staff has estimated costs for each

of the tanks that will be domed.

4-7 Comment A refinery has different types of domed roofs on ex ternal floating roof tanks. The difference is found in the peripheral venting desig n of the dome and often how high off the tank the roof stands. Since we have every inten tion to capture bids on any new construction, revised Rule language should offer gu idance on design specifications. Response

Design specifications for domed roof tanks are list ed in API Standard 650, Appendix G.Comments and Responses Final Staff Report

Proposed Rule 1178 53 December 11, 2001 

### Schedule of Installing Domed Roofs

5-1 Comment

Industry believes that the District did not conside r the complexity of scheduling tank outages and securing offsite storage, which will be expected to be in high demand during the compliance period and therefore there is a good possibility that a disruption of refinery production would lead to increased fuel co sts. In addition, since the District also failed to take logistics issues into consideration, the schedule for coming into compliance with Rule 1178 may be not be achievable or realisti c.

Response

Staff is sensitive to the removal of storage capaci ty as a result of installing domes on existing external floating roof tanks and the impac t it may have on the supply of gasoline and other fuels. As a result, in November, staff is propos ed ing to extend the compliance schedule to January 1, 2006. Facilities will now would be required to dome 25% of their external floating roof tanks at the end of each of the four compliance years starting from 2002 through 2006. In addition, facilities will would have the option to accept a permit condition not to store liquids with true vapor pres sure greater than 3 psia rather than complying with the doming requirement of the propos ed rule. An analysis of the storage tank capacity indicates that over the four year per iod to dome these tanks, on average, approximately 1.13% and 1.33% of the total storage capacity could be taken out of service at any one time at the refineries and non-r efineries (tank farms and loading racks), respectively. Since the requirement of doming tank s varies with each facility, staff will
continue to work with the facilities to minimize th e impact of taking these tanks out of

service. In December, responding to the feedback received fr om industry, staff is now proposing to expand the doming period to 6 years an d exclude 46 crude oil tanks from the doming requirements due to the poor cost effectiven ess. The exclusion of the crude oil tanks and expansion of the doming schedule from 4 y ears to 6 years is expected to alleviate the industry's concern about the doming schedule.

5-2 Comment

The schedule of installing dome is unattainable. I ssues related to 1) inability to meet the deadline for state mandated RFG Phase III requireme nts, 2) disruption to product deliveries and refinery production during tank outa ges, 3) product compatability that may require tank clearing/cleaning, 4) adequate storage capacity under excessive demand during the compliance period have not been adequate ly addressed. One affected facility proposed a ten-year period for doming.

Response

District staff is sensitive to the loss of storage capacity and the potential disruption to deliver products to the consumer. Please refer to Comment 5-1 and note that:Comments and Responses Final Staff Report

Proposed Rule 1178 54 December 11, 2001  The deadline for state mandated RFG Phase III requi rements is January 1, 2003. The compliance schedule for domed roofs has been extend ed to January 1, 2006. With the revised schedule, 75% of the tanks will be domed af ter the RFG Phase III requirements are in effect. Therefore, installing domed roofs is certainly not a cause for inability to meet the state mandated RFG Phase III requirements.

 District staff has done an analysis (Appendix D) to show that all of the affected
facilities would be able to utilize more than 95% o f the total tank capacity at their facility during the doming period. Doming therefor e is not expected to cause a disruption to product deliveries or refinery produc tion; and the facility is expected to have adequate storage capacity, even without leasin g, during this doming period.

 Domed roofs can be installed on top of an external floating roof, therefore tank clearing/cleaning/degassing is not a necessity.

 In addition, there is excess tank capacity that can be and is being leased from utility companies and Port of Los Angeles and Long Beach.

Acknowledging that each facility may face a unique situation, District staff is openly seeking and awaiting input from the facilities that may be disproportionately impacted by the schedule of installing domed roofs. With respe ct to the ten-year long compliance schedule, knowing the working capacity of major man ufacturers who fabricate domes in Southern California, a ten-year period for doming 2 41 external floating roof tanks was unnecessarily long. In December, responding to the feedback received f rom industry, staff is now proposing to expand the doming period from 4 years to 6 years and exclude 46 crude oil tanks from the doming requirements. T his is expected to alleviate the industry's concern about the doming schedule.

5-3 Comment

Although two fabricators of domed roofs who current ly fabricate and install geodomes in Southern California have indicated that they believ e they can provide the necessary manpower and materials to implement the proposed ru le within the three-year time frame, industry does not believe the schedule is ac hievable and realistic.

Response

District staff has estimated about 241 external flo ating roof tanks need to be retrofitted with domed roofs to achieve approximately 1 tpd emi ssion reductions. Regarding the capacity of fabricating and installing geodesic dom es, District staff has received the same information from the manufacturers as the industry. One manufacturer has indicated to District staff that they currently fabricate and in stall domes at a rate of 100 domes per year, which means that the 241 tanks could be handl ed by one manufacturer in less than three years. However, understanding the complexity associated with the scheduling and tank storage capacity removal issues, District staf f is proposing to extend the compliance schedule to four years. In addition, District staf f is seeking input from all impacted facilities, especially from those who may be dispro portional impacted regarding theirComments and Responses Final Staff Report

Proposed Rule 1178 55 December 11, 2001 schedules of installing domes. In December, responding to the feedback received fr om industry, staff is now proposing to expand the domi ng period to 6 years and exclude 46 crude oil tanks from the doming requirements. This is expected to alleviate the industry's concern about the doming schedule.

5-4 Comment

The industry strongly encourages the District to wo rk with the California Energy Commission (CEC) to poll/survey all impacted facili ties about this proposed rule. The CEC can help assess the potential impact of this ru le on the overall petroleum supply picture to the District.

Response

District staff is working closely with the CEC to m inimizing the product impact on the supply of petroleum products caused by removing sto rage tank capacity to implement this
rule.

5-5 Comment

The industry anticipates that the construction of d omes will take from one to three months per tank, depending on the tank size. All t he refineries will be competing for a limited number of constructors that can provide dom es. The industry strongly

recommends the District bifurcate the rule and dela y doming until the industry can sort out the implementation schedule that will not adver sely impact the supply of gasoline.

Response

Dome manufacturers have provided the District staff with the number of construction days needed for each tank that would be potentially domed. The number of days vary depending on the tank size from District staff is w orking closely with the CEC to minimizing the products impact on the supply of pet roleum products caused by removing storage tank capacity to implement this rule.



### Fixed Roof Tanks

6-1 Comment

The control efficiency of carbon adsorbers used to control emissions from fixed roof tanks and portable tanks is only 95 percent as oppo sed to 98 percent required by the rule. Also, since these tanks are used on an as needed ba sis, it is not feasible to vent them to anything other than carbon-type controls.

ResponseComments and Responses Final Staff Report

Proposed Rule 1178 56 December 11, 2001 The rule language has been modified to reflect that the control efficiency requirement of carbon adsorbers is 95 percent and that venting por table tanks to carbon adsorbers that meet the same efficiency is sufficient control.

6-2 Comment

It would be almost impossible for an oil and gas pr oduction facility with vapor recovery that is combined with a facility fuel gas/sales gas system, to demonstrate compliance with the 98% control efficiency requirement.

Response

The rule has been modified to include language that requires the facility operator to operate and maintain the tank roof, fittings, pipin g and valves connecting the (fixed roof) tank to the vapor recovery compressors in accordanc e with Rule 1173 and PR1178.

6-3 Comment

Requiring the pressure-vacuum vents on fixed roof t anks to be set within 10 percent of the maximum allowable working pressure of the roof is unreasonable since each tank’s setting is unique as specified by API 650.

Response

This is current requirement of Rule 463 and Bay Are a Rule.

6-4 Comment

The industry recommended District staff to drop the 98% control efficiency required for fixed roof tanks vented to fuel gas system. The de mand on compressors by venting to vapor recovery systems with a 98% control efficienc y would undoubtedly exceed our current capacity. Any increase to compressor capac ity would incur huge hardware and piping costs throughout the refinery, would contrac t permitting issues and will likely trigger federal regulations. This would add consid erable costs not contemplated in the proposed Rule.

Response

Since the MACT standards in the Federal Regulations does not require 98% control efficiency for fuel gas system, District staff will not make 98% control efficiency a requirement for fixed roof tanks that are vented to fuel gas system.

6-5 Comment

Converting a fixed roof tank to an internal floater would remove the tank from service for upwards of three months and would contract similar permitting issues and trigger federalComments and Responses Final Staff Report

Proposed Rule 1178 57 December 11, 2001 regulations. The cost to install an internal float ing roof, while typically more cost effective than vapor recovery systems, would exceed the cost of a typical tank turnaround, which are currently around $300,000.

Response

District staff has added a "loss-of-use" cost appro ximately equal to 40% of equipment
cost in order to determine the cost effectiveness f or internal floating roof tanks. In addition, District staff has extended the complianc e date for this control strategy to January 1, 2007 to allow the facilities sufficient time for scheduling should they choose
to convert the fixed roof tanks to internal floatin g roof tanks.

6-6 Comment

Rule language has pressure-vacuum vents specified t o be set within 10% of the maximum allowable working pressure of the roof or at least 0.5 psig. The industry is concerned with limitations implied in referencing t he 0.5 psig because the true set pressure will be dependent on the type of tank. To be consistent with Rule 463 and with further language found in the Rule [(k)(1)(D)], no minimum set pressure is mandated.

Response

This is the current requirement in Bay Area rule. The rule language allows the industry to choose between a set point within 10% of the max imum allowable working pressure of

the roof or

at least 0.5 psig.

6-7 Comment

PR1173.1 (1178) specifies that fixed-roof tanks lar ger than 19,815 gallons containing organic liquids with a TVP greater than 0.1 psia sh all be equipped with controls. These tanks may be equipped with an internal floating roo f or may be routed to an emission control system, but the more cost-effective option would typically be the installation of an internal floating roof. While WSPA acknowledges that there are merits to the concept of installing internal floating roofs, this is a pa rticularly complex item. In addition to the

need to determine cost effectiveness as a function of the various pertinent parameters, there are inspection and fire safety issues involve d. WSPA believes that the complexity of this measure cannot be adequately addressed in a simple comment letter, and thus WSPA suggests the discussion of these issues in mor e detail with staff

.
Response

District staff will continue meeting with the indus try to discuss this issue.

6-8 CommentComments and Responses Final Staff Report

Proposed Rule 1178 58 December 11, 2001 Where vapors from an emission point are routed to a fuel gas system, the U.S. EPA regards such vapors as having never left the proces s. The U.S. EPA typically exempts such emission points from the applicability of the rule, thereby avoiding the application of control efficiency determinations to process equ ipment. This same principle should be invoked by PR 1173.1. Stipulate that storage tanks routed to a fuel gas system are exempt from the requirements of this rule, for exam ple, Refinery MACT [40 CFR Part 63, Subpart CC, Section 63.640, paragraph (d)(5).

Response

The rule language has been revised to incorporate t his comment.



### Operator Inspection

7-1 Comment

Will Method 21 certification be included as part of a revised inspector tank certification under Rule 463 or under the certification training required under Rule 1176?

Response

A completion certificate will be offered by attendi ng CARB Fugitive Emissions Operator Training Course #395. The course could be synchron ized with the Rule 463 certification class offered by AQMD.

7-2 Comment

Under Rule 463, entry is not required to conduct vi sual inspections of the tank seals and to take LEL readings for in-service internal floati ng roof tanks. Therefore, this requirement should be removed.

Response

Visual inspections and LEL readings are required to be conducted semiannually. Gap measurement of the rim seal system, gap measurement of the deck fittings or Method 21 measurement are required once every ten years or wh enever the tank is emptied or degassed.

7-3 Comment

Since inspections for Rule 463 and PR1178 will be c onducted at the same time, can the written report required for tanks determined to be in violation of Rule 463, be modified and submitted to meet the compliance requirements o f PR1178?

ResponseComments and Responses Final Staff Report

Proposed Rule 1178 59 December 11, 2001 Inspection procedures and Compliance Report Form fo r PR1178 have been modeled after Rule 463, have been developed and included as Attac hment A of PR1178.

7-4 Comment

The rule requires that there be inspection of domed roof tanks and internal floating roof tanks using EPA Method 21, which requires that the probe on the hydrocarbon analyzer be placed within one centimeter of the fugitive sou rce. There are safety concerns regarding personnel entering the confined space bet ween the floating roof and the dome.
It is recommended that the District not deviate fro m the inspection criteria specified in

Rule 463.

Response

The rule has been revised to incorporate this comme nt. Inspection requirements for internal floating roof tanks and domed external flo ating roof tanks will be in accordance with the requirements specified in Rule 463.

7-5 Comment
Provide access to an extended repair period. We ra ise the issue of the 72-hour provision to establish compliance on a needed repair. The ad ditional hardware needed to inspect and, possibly repair, will likely challenge the 72- hour limit. Based on our current experience at satisfying the 72-hour compliance per iod of Rule 463, we recommend language that would support a repair exceeding 72 h ours. For example, gaining entry into a confined space will result in additional tim e needed to affect repairs.

Response

Staff believes that the requirement to repair withi n 72 hours is appropriate and consistent
with Rule 463. Since staff has received comment on this issue from only one facility, it does not appear to be an industry-wide problem and may be more appropriately addressed on a case by case basis through the varia nce process.

7-6 Comment

Testing for leaks with an organic vapor analyzer (O VA) or other portable hydrocarbon analyzer is not an appropriate monitoring method fo r floating roof tanks. This testing to determine a so-called "vapor tight condition" is ap propriate for closed piping systems that route vapors to an emission control system, but is not a meaningful measure of whether a floating roof tank is in compliance with the specif ied equipment standard, nor is it appropriate for fixed-roof tanks that are not route d to an emission control system. In order to have the requirement for vapor tight press ure-vacuum vents apply only to the tanks for which they are appropriate, paragraphs (d )(3)(C) and (D) should be renumbered as paragraphs (d)(3)(A)(iv) and (v).Comments and Responses Final Staff Report

Proposed Rule 1178 60 December 11, 2001 Response

Some deck fittings on floating roof tanks are confi gured such that gap measurements are not feasible. In this situation, monitoring with O VA is an appropriate method to detect leaks. The fixed roof tanks subject to PR1178 are all routed to vapor control, therefore vapor-tight condition is an appropriate requirement . District staff has renumbered the paragraphs as suggested by the industry to eliminat e confusion.



### Test Methods and Procedures

8-1 Comment

There should be a listing of specifically defined p roducts that would be exempt from the rule including, diesel, jet fuel, gas oil, fuel oil and asphalt.

Response

These generalized terminologies for ranges of petro leum fractions do not necessarily represent the emissions characteristics for tank co ntents which may vary on both an inter and intra-refinery/facility basis. Additionally, p roduct blendstocks and many of the

intermediate refined streams often use these termin ologies despite the fact that they are not, in themselves, saleable products that meet fin al product specifications. Furthermore, the terminology for the tank contents does not take into account actual storage conditions such as temperature. Because of this, the rule mus t therefore rely on a measurement that can act as a surrogate for potential emissions for determining applicability. True vapor pressure (TVP) is the criterion that the Tanks 4 so ftware, developed by EPA and API,

uses to determine tank content emissions characteri stics. The Tanks 4 software along with information submitted by the affected faciliti es was used to perform the cost effectiveness analysis of the rule. Due to difficu lties in measuring very low TVPs, ASTM Methods D-86 and D-93, for non-heated and heat ed tank contents respectively will be used to determine if a product should be ex empt from the requirements of the rule. Furthermore, since the flash point threshold for organic liquids that are stored at ambient temperatures has been revised and set at 10 0 degree F, listing specifically defined products as exempt products is no longer ne cessary.

8-2 Comment

Flash point is not a proper surrogate for vapor pre ssure and it is recommended that either a single method be specified such as ASTM Method D- 86 which is proposed in this rule or that there be a list of compounds and their spec ified vapor pressures as in Rule 463.

Response

Although flash point is not a proper surrogate for higher vapor pressures, the method for determining flash point is far superior to the meth od for determining vapor pressure in terms of precision and accuracy for the types of pr oducts near the proposed 0.1 psi TVPComments and Responses Final Staff Report

Proposed Rule 1178 61 December 11, 2001 threshold for rule applicability. Both refinery an d District members of the working group have raised the issue of the difficulty of determin ing low vapor pressures. To resolve this issue, the flash point test method was chosen as a test method that has the capability of discerning between product types and petroleum frac tions near the 0.1 psi TVP threshold

that was used in the cost effective ness analysis of the rule. An addition to the precisio n and accuracy considerations, the flash point method was also considered to have advantages with respect to cost and ease of analysi s since the analysis is considered to be very inexpensive and since most or all affected fac ilities have current capabilities to run the analysis in-house.

8-3 Comment

ASTM Method D-86 is unreliable for crude oil sample s and the District should specify or develop an alternative method (such as District Met hod 304-91), which is suitable for use at oil and gas production facilities. The difficul ty in de-watering many crude oil samples often leads to either aborted or compromised ASTM M ethod D-86 test results.

Response

It is understood that water will, in effect, be tre ated as a VOC by the ASTM D-86 approach. The rule language as been changed so tha t the ASTM D-86 approach applies to tanks with heated contents only which are not ex pected to have significant water

content. District staff is considered Proposed Rule 1178 will exempt crude oil tanks from the doming equirements. I n essence Therefore , ASTM Method D-86 would not be used

for crude oils.

8-4 Comment

The applicability criteria for materials included i n this rule is based on true vapor pressure, which can vary with temperature. Will th e true vapor pressure measurement be based on an annual average or on the highest vapor pressure at some maximum temperature?

Response

The advantage of the TVP approach is that it mimics actual emission characteristics in

that both TVP and actual emissions increase as a fu nction of temperature. Recognizing, however, TVP variations due to diurnal and/or seaso nal variations in ambient temperature may create an uncertainty with respect to the numbe r of external floating roof tanks that will be subject to the doming requirement of the pr oposed rule, staff is proposing the
TVP to be measured at 7 5 0 degree F.

8-5 CommentComments and Responses Final Staff Report

Proposed Rule 1178 62 December 11, 2001 Since ASTM Method D86 is a volumetric method, the r ule applicability should be based on a 10% volume recovered as opposed to the 10% mas s recovered in the draft rule.

Response
The rule language has been revised to specify 10% v olume recovered as opposed to the

10% mass recovered for the ASTM method used to dete rmine rule applicability.

8-6 Comment

Asphalt plants that do not produce gasoline, jet fu el or diesel and do not have any complicated processing units normally associated wi th larger refineries such as hydrotreating, coking or thermal cracking should be exem pted from the rule.

Response

Given the variety of hydrocarbons present in crudes , even facilities that produce exclusively asphalts from crudes cannot be exempted specifically from the rule due to the potential for emissions of the light ends in the cr udes. Additionally, since these asphalt plants typically store heated products, there is a potential to overheat the product to the point where the 0.1 psi TVP as determined in the ru le can be exceeded. Provided, however, that the tank contents fall under the 0.1 psi TVP as determined by the test methods as applicable in the rule, specific tanks w ithin asphalt plants can be exempt from the requirements of the rule.

8-7 Comment

Kerosene, diesel, and all heavier products should b e exempt from the rule because the TVP is below 0.1 psi.

Response

The flash point applicability limit has been revise d to 100 degree F. This revision will exempt many of the materials stored such as diesel and heavier products with TVP below 0.1 psi.

8-8 Comment

ASTM 5191 as a test method for the 3 psi threshold may not be applicable to crude samples.

Response

The District welcomes suggestions for test methods for determining vapor pressures for the 3 psi threshold. District staff recommends ASTM Method D

- 2889 for true vaporComments and Responses Final Staff Report

Proposed Rule 1178 63 December 11, 2001 pressure or ASTM Method D-323 for Reid Vapor Pressure and conve rted to TVP using AP42 or other approved nomographs.

8-9 Comment

The language in the test method section for multipl e test methods needs to be explained.

Response

The language regarding multiple test methods was bo rrowed from Rule 1132 and would apply to source tests for control systems only. Ea ch sentence was intended to remedy two problems that are often encountered. The cause of both of the problems is that some

of these test methods will bias the emissions low i n certain applications. The first sentence is designed to give the District the autho rity to prevent the use of a low biasing

test method when the District evaluates source test protocols. This has proven to be difficult when rules specify several test methods. The second sentence is designed to address the problem that when a violation is detect ed, Notices of Violations potentially cannot be issued because failure by all of the test methods cited in the rule cannot be proven. Both sentences are therefore needed in ord er to make the rule enforceable.

8-10 Comment

The procedures for refinery laboratories to receive LAP approval and sampling

authorization should be clarified.

Response

PR1178 cites both District source test methods (e.g . SCAQMD Method 25.1) for testing control device efficiency, and non-source test meth ods (e.g. EPA Method 21 and ASTM Method D-93) for performing inspections and determi ning rule applicability. PR1178 also states that the LAP approval is required only for those methods where a LAP approval process exists. The LAP process primarily applies to source test methods. Additionally, Rule 304 states that testing shall be conducted by the District or an independent laboratory. This is interpreted to app ly to the source test methods. For the non-source test methods, the testing may be conduct ed by the refinery and reported as under reporting and recordkeeping requirements. Cu rrently, since there is no existing LAP process for the non-source test methods, the re fineries may conduct this testing without LAP approval. It should be noted, however, that the District also has the option to perform testing and issue notices of violations based on its test results.

8-11 Comment

Must the tank content sampling comply with ASTM D-4 057, Manual Sampling of

Petroleum and Petroleum Products.Comments and Responses Final Staff Report

Proposed Rule 1178 64 December 11, 2001 Response

The samples must be obtained in a manner which is r epresentative of the tank contents as with respect to the intention of the rule. ASTM Me thod D-4057 will generally apply as the standard for sampling petroleum products and is cited in many other ASTM methods of analysis.

8-12 Comment

District should explicitly exempt asphalt and aspha lt like material from the rule since cracking may occur during the ASTM Method D-86 anal ysis causing a bias in the test
results.

Response

ASTM Method D-86 states that the distillation is de emed as completed once sample decomposition is encountered. The remaining non-di stilled portion of the sample is
considered as residual and not counted in the 10% r ecovery as specified in PR1178. The effect of cracking of the samples at high temperatu res is, therefore, not considered to bias
the test results which are based on the volume reco vered.

8-13 Comment

Use a true vapor pressure test method for 3 psia th reshold. The proposed Rule, as written, is unclear which test method should be use d to verify the 3 psia threshold for

dome installations. A more traditional vapor pressure test method could be applied and We recommend ASTM D-5191 [good for determining vapo r pressures from 1 to 18 psia]

or ASTM D-323.

Response

Staff has reviewed this issue and revised proposed rule language that states that ASTM

Met hod D

- 2889 should be used to determine true vapor pressur e, and ASTM Method D323 should be used to determine Reid vapor pressure and AP-42 or District approved nomographs to convert to true vapor pressure.



### Exemption

9-1 Comment

Since pressure vessels have pressure relief devices (PRDs) that vent to the atmosphere under very high-pressure scenarios, exemptions for these vessels should specify a range of operation for PRDs.

ResponseComments and Responses Final Staff Report

Proposed Rule 1178 65 December 11, 2001 This section of the rule has been modified to incor porate the comment.

9-2 Comment
Exempt tank sampling systems for vapor tightness. We have several sampling systems along various tank shells that could become a chall enge to keep in a vapor tight condition as defined in the Rule. We solicit language from t he District that would exempt such systems because they are not actually part of the t ank or tank shell.

Response

Vapor tight conditions are applicable only to roof openings and as a monitoring option for rim seals. The definition for roof openings do es not include tank sampling systems. Therefore, tank sampling systems are exempt by defi nition.

9-3 Comment

Exempt liquids not containing a majority of Volatil e Organic Compounds. We have encountered situations where the vapor pressure fro m the top layer of a liquid [e.g., oil on water] triggers Rule 463 even though a representati ve sample of the liquid clearly is not VOC containing material. For example, we include s torm/waste water tanks in our Rule 463 program due to the potential for this oily film to develop on top of the liquid which may have a high enough vapor pressure. We request the District to offer guidance through Rule language on how to deal with this type of situation.

Response

Staff is reviewing this issue and will work with in dustry to develop appropriate rule language.



### Emission Reductions and Cost Effectiveness Analysis

10-1 Comment

If this rule includes portable tanks that are stati onary, their emissions and cost impact should be included in the draft staff report.

Response

Permits for portable storage tanks storing liquids with high vapor pressure materials require venting to carbon canisters. Therefore, th is type of storage tanks should comply with the requirements of fixed roof storage tanks u nder paragraph (d)(4). Furthermore, since most of these tanks are already permitting wi th carbon adsorbers, no additional costs are anticipated. Furthermore, costs for retr ofitting with carbon canisters are expected to be significantly lower than costs for r etrofitting with internal floating roofs toComments and Responses Final Staff Report

Proposed Rule 1178 66 December 11, 2001 achieve same amount of emission reductions. Theref ore, the cost effectiveness factor for tanks with carbon canister is expected to be smalle r than the cost effectiveness factor derived for internal floating roof tanks.

10-2 Comment

The requirement of installing dome roofs would impo se burden on sources that are already subject to highly effective controls. The external floating roof tanks that would be affected by this provision would have already ac hieved control efficiencies greater
than 95% before the installation of a fixed roof.

Response

Additional control of VOC emissions is technically and economically feasible and needed to achieve state and federal air quality sta ndards for Ozone and PM. District staff has estimated that installing domed roofs would red uce deck fitting losses by 47%, rim seal losses by 79%, and VOC emissions by 0.95 tpd a fter full implementation. After excluding the emission reductions from crude oil ta nks, the total emission reductions would be about 0.89 tpd.

10-3 Comment

District staff has overestimated and double counted incremental emission reductions for

domes.

Response

Since the external floating roof tanks containing m aterials with TVP >3 psia currently are equipped with mechanical shoe primary seals and rim -mounted secondary, there is no emission reductions associated with upgrading rim s eal systems for domed tanks. The emission reductions associated with upgrading deck fittings for external floating roof tanks are small, approximately 25.31 tpy for all 52 6 external floating roof tanks. Nevertheless, to be conservative in the incremental cost effectiveness estimation for domed roofs, District staff has deducted the whole 25.31 tpy from the 373.59 tpy

emission reductions for domed roofs to obtain the i ncremental emission reductions of 348.27 tpy (0.95 tpd) for domed roofs. Please refe r to Appendix B of Draft Staff Report

for further information. After excluding the emission reductions from crud e oil tanks, the total emission reductions would be about 0.89 tpd.

10-4 Comment

The requirement of dome roofs would impose enormous capital expenditures for a small potential emissions benefit, resulting in an estima ted cost effectiveness factor of approximately $30,000 per ton VOC reduced. This co st effectiveness factor was based on a preliminary analysis of 195 external floating roof tanks potentially subject to the domed roof requirements at six affected refineries in the basin.Comments and Responses Final Staff Report

Proposed Rule 1178 67 December 11, 2001 Response

The cost effectiveness analysis used to estimate th e $30,000 per ton VOC reduced was not based on a Discounted Cash Flow (DCF) Method, w hich is the methodology that

District staff would use to determine cost effectiv eness factor for a proposed rule and AQMP since 1995. In addition, the number of 195 ex ternal floating roof tanks may include tanks containing organic liquids with true vapor pressures (TVP) lower than 3 psia at average storage temperatures. These tanks would provide smaller amount of emission reductions at the same cost of installing domes compared to the tanks containing materials at higher TVPs. The high cost effectiveness factors for tanks containing low TVP materials push the overall cost effectiveness factor upward. Using the DCF approach and the emission inventory provide d by the refineries, District staff estimated about 137 external floating roof tanks th at would be affected at six refineries, and estimated a cost effectiveness of about $12,000 per ton VOC reduced

. Further excluding crude oil tanks from doming would bring t he overall cost effectiveness factor down to approximately $9,583 per ton VOC reduced.

10-5 Comment

Recommend the District to follow a well defined met hod of segregating each control technology and evaluate the cost effectiveness base d on its own merits.

Response

The cost effectiveness of each control measure as w ell as the cost effectiveness of the entire Proposed Rule 1178 were presented in Table 6 -6 of the Preliminary Draft Staff Report.

10-6 Comment

One refinery estimated emission reductions of 33.56 tpy for doming 30 tanks at a cost effectiveness factor of $33,650 per ton. To derive this cost effectiveness factor, the refinery included labor costs for its own refinery, contingency, and leased storage expenditures on top of the vendor quotes for domes. This refinery then compared $33,650 per ton with a cost effectiveness factor of $13,500 per ton for District Architectural Coatings Rule 1113, and a cost effect iveness factor of $19,00 per ton for

BACT to conclude that domed roofs would not be a co st effective control measure.

Response
Even though this refinery seemed to estimate correc t emission reductions for doming 30 tanks using EPA TANK 4.0 program, this refinery had used a different methodology than the Discounted Cash Flow (DCF) Method that District staff would use to estimate a cost

effectiveness factor for a control measure since 19 95. It is therefore inaccurate and misleading to compare the cost effectiveness factor of $33,650 per ton derived by this refinery with the cost effectiveness factors of $13 ,500 per ton for Rule 1113, and $19,000Comments and Responses Final Staff Report

Proposed Rule 1178 68 December 11, 2001 per ton for BACT derived following the DCF methodol ogy. In addition, incorporating additional contingency and in-house labor costs, wh ich could vary significantly between the refineries, may be warranted for budgeting purp oses but are inappropriate for cost effectiveness calculations. Staff's analysis and q uotes received from vendors already account for such contingencies. Additional conting encies would bias the cost effectiveness factor unnecessarily high. Furthermo re, District staff has factored in a

“loss-of-use” cost which was estimated based on a l easing cost for temporary storage at all affected facilities regardless of the fact that some facilities may not actually have to lease temporary storage, and re-estimated the cost effectiveness for domes to arrive at a cost effectiveness factor of $12,103 per ton using the DCF methodology. At $12,103 per ton, doming is a cost effective control measure. Further excluding crude oil tanks from doming would bring the overall cost effectiveness f actor down to approximately $9,583 per ton VOC reduced.

10-7 Comment

Recommend the District to 1) follow a cost effectiv e methodology adopted by U.S. EPA Office of Air Quality Planning and Standards (OAQPS ), and 2) use an interest rate of 7%
to determine cost effectiveness factor.

Response

District staff acknowledges the recommendation. Co st effectiveness analysis is a tool to generate a cost effectiveness factor for a control measure. By comparing the cost

effectiveness factors of several control measures w ith each others, one can acquire knowledge about the costs of each control measure r elating to their effectiveness in controlling a particular pollutant. It is necessar y to compare cost effectiveness factors of different control measures derived using the same m ethodology and the same assumptions. District staff has been using Discoun ted Cash Flow Method with a 4% real

interest rate to determine cost effectiveness facto r for numerous proposed rules since
1995.

10-8 Comment

Because of the disproportionate hardship to small r efiners, a separate cost effectiveness analysis addressing the unique situation of small r efiners is necessary. Small refiners should be provided additional time to comply with t he rule requirements.

Response

A small refiner could potentially be a major source of pollution. The cost of control measures and the cost effectiveness analysis are ne utral with respect to the size of facilities impacted and, therefore, separate cost-e ffectiveness analysis is not warranted more appropriate. However, the District will condu ct a thorough socioeconomic analysis to more accurately quantify the cost impacts on var ious segments of the local economy.Comments and Responses Final Staff Report

Proposed Rule 1178 69 December 11, 2001 With respect to the compliance schedule, District s taff's goal is to arrive at a compliance schedule that is fair and equitable to all impacted facilities, small or large.

10-9 Comment

District has grossly underestimated the cost of con verting fixed roof tanks to internal floating roof tanks or venting them to vapor recove ry. The costs for venting vapors from storage tanks to vapor recovery are extremely high.

Response

There are two options to further control emissions from fixed roof tanks containing liquids with true vapor pressures between 0.5 psia and 0.1 psia, either the emissions would be vented to vapor recovery, or the fixed roo f tanks would be converted to internal floating roof tanks. The costs associated with ven ting the emissions to vapor recovery would vary significantly from scenarios to scenario s. To obtain one representative cost effectiveness factor for this control option, Distr ict staff has estimated cost effectiveness factor for internal floating roof tanks. The cost effectiveness in the Preliminary Draft Staff Report has been revised to include costs asso ciated with "loss-of-use" with the understanding that the tanks could not be used duri ng the installation of the internal floating roofs. District staff is in the process o f verifying the costs with manufacturers, and will update the cost effectiveness factor if ne cessaryAppendix A Final Staff Report

Proposed Rule 1178 A- 1 December 11, 2001 

## Appendix A - List of Affected Facilities

Table A-1 - List of Affected Facilities

Type SIC Fac ID Name City Refinery 2911 800012 BP Arco Carson Refinery 2911 800030 Chevron Products Co. El Segund o Refinery 2911 800370 Equilon Enterprises, LLC Wilmi ngton Refinery 2911 800089 Exxon Mobil Torrance Refinery 2911 800362 Tosco Refining Co., Carson Car son Refinery 2911 800363 Tosco Refining Co., Wilmington Wilmington Refinery 2911 800026 Ultramar Wilmington Refinery 2911 800264 Edgington Oil Long Beach Refinery 2911 800373 Cenco Santa Fe Springs Refinery 2911 800183 Paramount Petroleum Corp. Para mount Refinery 2911 800393 Valero Wilmington Asphalt Plt. Wilmington Non-refinery 4226 65381 SFPP, LLP., Unit No. 01 Carson Non-refinery 4226 65382 SFPP, LLP.'s Colton Terminal Bloomington Non-refinery 4613 111814 Tosco Refining Co/Torrance Tank Farm To rrance Non-refinery 5171 117560 Equilon Enterprises, LLC--Mormon Island Wilmington Non-refinery 5171 800015 BP Arco Vinvale Terminal South Gate Non-refinery 4226 800057 Kinder Morgan (GATX) Carson Non-refinery 5171 800198 Ultramar Inc. Wilmington Non-refinery 5171 800286 BP Arco Hathaway Signal Hill Signal Hil l Non-refinery 5171 800365 Tosco Refining Co./LA Terminal, East Lo s Angeles Non-refinery 5171 800372 Equilon Enterprises, LLC Carson Non-refinery 5171 800052 BP Arco Terminal Serv., Four Corners Lo ng Beach Non-refinery 5171 800051 BP Arco E. Hynes, Four Corners Long Bea ch

Non

- refiner y 1311 104012 AERA Energy Hunt. Beach Non-refinery 1311 104015 AERA Energy Yorba Linda Non-refinery 1311 104017 AERA Energy Hunt. Beach Non-refinery 1311 119907 Berry Petroleum Co. Santa Clarita Non-refinery 5171 800022 CalNev Bloomington Non-refinery 5171 800272 Chemoil Terminals Corp. Carson

Non

- refinery 5171 116931 Equilon Signal Hill Signal Hill Non-refinery 1311 87806 Global Oil Co. Wilmington Non-refinery 1311 100844 Medallion California Properties Newhall Non-refinery 5171 800079 Petro Diamond Long Beach Non-refinery 1311 93073 Saba Petroleum Placentia Non-refinery 1311 83753 Stocker Resources Inc. L.A. Non-refinery 1311 101977 Signal Hill Petroleum Long Beach

Non

- refinery 1311 83509 The Termo Co. Castaic Non-refinery 1311 116488 Texaco Exploration and Production Co. S . Fe Springs Non-refinery 1311 800325 Tidelands Oil Production Co. Long Beach Non-refinery 1311 68112 Tidelands Oil Production Co. Long Beach Non-refinery 1311 109018 Torch Operating Co. Brea

Non

- refinery 5171 800364 Tosco Colton Terminal Bloomington Non refinery 1311 800330 Thums Long Beach Co. Long Beach Non refinery 1311 49863 Texaco Exploration and Production Seal Beach Non-refinery 4226 110924 Westway Terminal Co. San PedroAppendix A Final Staff Report

Proposed Rule 1178 A- 2 December 11, 2001 Table A-2 - Tank Emissions by SIC Code

SIC # Facilities Tank Emissions (tpy) % of Total

2911 11 614.41 50.58

1311 14 37.58 3.09

4226 4 179.45 14.77

4613 1 45.52 3.75

5171 11 337.77 27.81

Total 41 1214.73 100Appendix B Final Staff Report

Proposed Rule1178 B-1 December 11, 2001 

## Appendix B - Emission Reductions

Section B-1: Estimates of Emission Reductions for Upgrading Rim

Seals

Table B-1 – Emission Reduction Estimates for Upgrad ing Rim Seal Systems of All External Floating Roof Tanks at Petroleum Refineries - Scena rio 2 in Table 6-6

Refinery No of

Tank Tank

Shell Primary Seal Secondary Seal Rim L oss Initial (E rimseal) (tpy) Percent

Reduction (PR rimseal) (%) Reduction

(ER rimseal) (tpy)

1 2 Riveted Mechanical Shoe None 0.08 78.09 0.06

1 13 Riveted Mechanical Shoe Rim

- mounted 17.79 0.00 0.00

1 5 Welded Mechanical Shoe None 1.38 85.00 1.17

1 30 Welded Mechanical Shoe Rim

- mounted 19.40 0.00 0.00

2 1 Riveted Mechanical Shoe None 1.77 85.00 1.51

2 6 Riveted Mechanical Shoe Rim

- mounted 4.54 0.00 0.00

2 79 Welded Mechanical Shoe Rim

- mounted 48.31 0.00 0.00

3 1 Riveted Mechanical Shoe None 0.07 78.09 0.05

3 1 Welded Liquid

- mounted Rim

- mounted 0.72 0.00 0.00

3 11 Welded Mechanical Shoe Rim

- mounted 12.57 0.00 0.00

4 17 Riveted Mechanical Shoe Rim

- mounted 22.33 0.00 0.00

4 7 Welded Liquid

- mounted None 0.03 51.00 0.02

4 4 Welded Liquid

- mounted Rim

- mounted 0.22 0.00 0.00

4 9 Welded Mechanical Shoe None 0.18 85.00 0.15

4 29 Welded Mechanical Shoe Rim

- mounted 24.84 0.00 0.00

5 10 Riveted Mechanical Shoe Rim

- mounted 11.96 0.00 0.00

5 4 Welded Liquid

- mounted Rim

- mounted 1.27 0.00 0 .00

5 15 Welded Mechanical Shoe Rim

- mounted 4.64 0.00 0.00

6 6 Riveted Mechanical Shoe None 0.04 78.09 0.03

6 14 Riveted Mechanical Shoe Rim

- mounted 1.81 0.00 0.00

6 1 Welded Liquid

- mounted None 0.17 51.00 0.09

6 2 Welded Liquid

- mounted Rim

- mounted 0. 29 0.00 0.00

6 26 Welded Mechanical Shoe None 5.07 85.00 4.31

6 39 Welded Mechanical Shoe Rim

- mounted 12.45 0.00 0.00

6 3 Welded Mechanical Shoe Shoe

- mounted 0.05 57.00 0.03

7 21 Welded Liquid

- mounted Rim

- mounted 3.89 0.00 0.00

7 6 Welded Mechanical S hoe Rim

- mounted 5.81 0.00 0.00

Total 383 Total (tpy) 7.42 Total (tpd),
ER rimseal 0.02

Note: For each type of rim seal type i, ER rimseal, i = E rimseal, i * PR rimseal, i. For example, 0. 06 tpy = 0.08 tpy * 0.78 for riveted tanks with mechanical shoe p rimary seal.Appendix B Final Staff Report

Proposed Rule1178 B-2 December 11, 2001 Table B-2 – Emission Reduction Estimates for Upgrad ing Rim Seal Systems of External Floating Roof Tanks Containing Materials > 0.1 psia at Petroleum Refineries
- Scenario 1 in Table 6-6

Refinery No of Tank Tank
Shell Primary Seal S econdary
Seal Rim Loss Initial

(E rimseal) (tpy) Percent

Reduction (PR rimseal) (%) Reduction

(ER rimseal) (tpy)

1 11 Riveted Mechanical Shoe Rim

- mounted 17.79 0.00 0.00

1 5 Welded Mechanical Shoe None 1.38 85.00 1.17

1 28 Welded Mechanical Shoe Rim

- mou nted 19.40 0.00 0.00

2 1 Riveted Mechanical Shoe None 1.77 78.09 1.38

2 6 Riveted Mechanical Shoe Rim

- mounted 4.54 0.00 0.00

2 79 Welded Mechanical Shoe Rim

- mounted 48.31 0.00 0.00

3 1 Welded Liquid

- mounted Rim

- mounted 0.72 0.00 0.00

3 11 Welded Mecha nical Shoe Rim

- mounted 12.57 0.00 0.00

4 15 Riveted Mechanical Shoe Rim

- mounted 22.32 0.00 0.00

4 2 Welded Liquid

- mounted Rim

- mounted 0.22 0.00 0.00

4 20 Welded Mechanical Shoe Rim

- mounted 24.82 0.00 0.00

5 10 Riveted Mechanical Shoe Rim

- mounted 11.96 0.00 0.00

5 4 Welded Liquid

- mounted Rim

- mounted 1.27 0.00 0.00

5 14 Welded Mechanical Shoe Rim

- mounted 4.64 0.00 0.00

6 0 Riveted Mechanical Shoe None 0.00 78.09 0.00

6 14 Riveted Mechanical Shoe Rim

- mounted 1.81 0.00 0.00

6 0 Welded Liquid

- mounted No ne 0.00 51.00 0.00

6 2 Welded Liquid

- mounted Rim

- mounted 0.29 0.00 0.00

6 0 Welded Mechanical Shoe None 0.00 85.00 0.00

6 39 Welded Mechanical Shoe Rim

- mounted 12.45 0.00 0.00

6 0 Welded Mechanical Shoe Shoe

- mounted 0.00 57.00 0.00

7 12 Welded Liquid

- mounted Rim

- mounted 3.85 0.00 0.00

7 5 Welded Mechanical Shoe Rim

- mounted 5.80 0.00 0.00

TOTAL 279.00 TOTAL (tpy) 195.92 2.55

TOTAL (tpd) 0.01

Note: For each type of rim seal type i, ER rimseal, i = E rimseal, i * PR rimseal, i. For example, 1. 17 tpy = 1.38 tpy * 0.85 for welded tanks with only mechanic al shoe primary seal.



### Estimate of Emission Reductions From Upgrading Rim Seals of External Floating Roof Tanks for Table 5-1 and Scenario 1 Staff Proposal (Scenario 1) in
Table 6-6

From Table B-2, emission reduction at 7 petroleum r efineries = 2.55 tpy

From Table 2-4, 2-5, and 2-6:
Emissions from EFRTs at 7 petroleum refineries = 45 1.19 tpy
Emissions from EFRTs at non petroleum refineries = 218.32 + 40.19 = 258.51 tpy
Emission reduction at non-petroleum refineries = 2. 55 x (258.51/451.19)= 1.46
tpy

Total emission reduction from rim seals = 2.55 + 1. 46 = 4.01 tpy = 0.01 tpdAppendix B Final Staff Report

Proposed Rule1178 B-3 December 11, 2001 

### Estimate of Emission Reductions From Upgrading Rim Seals of External Floating Roof Tanks for Scenario 2 in Table 6-6

From Table B-1, emission reduction at 7 petroleum r efineries = 7.42 tpy for approximately 61 external floating roof tanks

From Table 2-4, 2-5, and 2-6:
Emissions from EFRTs at 7 petroleum refineries = 45 1.19 tpy
Emissions from EFRTs at non petroleum refineries = 218.32 + 40.19 = 258.51 tpy
Emission reduction at non-petroleum refineries = 7. 42 x (258.51/451.19) = 4.25 tpy for approximately (61 x ((99+234)/308)) = 66 ta nks

Total emission reduction from rim seals = 7.42 + 4. 25 = 11.67 tpy = 0.03 tpd for approximately (61 + 66 = 127) tanks



### Estimate of Emission Reductions From Upgrading Rim Seals of Internal Floating Roof Tanks for Scenario 2 in Table 6-6

Emission reduction for 35 internal floating roof ta nks at petroleum refineries = 1 tpy

From Table 2-4, 2-5, and 2-6:
Emissions from IFRTs at petroleum refineries = 20.7 2 tpy
Emissions from IFRTs at non petroleum refineries = 237.78 + 34.49 = 272.27 tpy
Emission reduction at non-petroleum refineries = 1 x (272.27/20.72) = 13.14 tpy for approximately 163 tanks

Total emission reduction from rim seals = 1 + 13.14 = 14.14 tpy = 0.04 tpd for approximately (35 + 163 = 198) tanksAppendix B Final Staff Report

Proposed Rule1178 B-4 December 11, 2001 

## Section B-2: Estimates of Emission Reductions for Upgrading Deck Fittings

Table B-3 – Average Percent Reduction for External Floating Roof Tanks

Dec k Fitting Type Deck Covering Type Total Quantity (N) PercentageR

eduction (PR deck fitting,j) Average

percentage reduction for deck fitting type j
Access Hatch (24

- in. Diam.) Bolted Cover, Gasketed 459 0.00 0.00

Access Hatch (24

- in. Diam.) Unbolted Cover, Gasketed 1 97.62 0.01

Access Hatch (24

- in. Diam.) Unbolted Cover, Ungasketed 42 97.76 0.26

Automatic Gauge Float Well Bolted Cover, Gasketed 33 0.00 0.00

Automatic Gauge Float Well Unbolted Cover, Gasketed 29 91.83 0.17

Automatic Gauge Float Well Unbo lted Cover, Ungasketed 222 93.32 1.33

Column Well (24

- in. Diam.) Pipe Col.

- Sliding Cover, Gask. 1 60.00 0.00

Gauge

- Hatch/Sample Well (8

- in. Diam.) Weighted Mech. Actuation, Gask. 357 0.00 0.00

Gauge

- Hatch/Sample Well (8

- in. Diam.) Weighted Mech. Actuati on, Ungask. 46 75.86 0.22

Rim Vent (6

- in. Diameter) Weighted Mech. Actuation, Gask. 136 0.00 0.00

Rim Vent (6

- in. Diameter) Weighted Mech. Actuation, Ungask. 23 86.71 0.13

Roof Drain (3

- in. Diameter) 90% Closed 266 0.00 0.00

Roof Drain (3

- in. Dia meter) Open 38 39.31 0.11

Roof Leg (3

- in. Diameter) Adjustable, Center Area, Gasketed 3322 0.00 0.00

Roof Leg (3

- in. Diameter) Adjustable, Center Area, Sock 2,382 0.00 0.00

Roof Leg (3

- in. Diameter) Adjustable, Center Area, Ungasketed 687 54.96 2.40

Ro of Leg (3

- in. Diameter) Adjustable, Double

- Deck Roofs 1560 0.00 0.00

Roof Leg (3

- in. Diameter) Adjustable, Pontoon Area, Gasketed 2838 0.00 0.00

Roof Leg (3

- in. Diameter) Adjustable, Pontoon Area, Sock 1,512 0.00 0.00

Roof Leg (3

- in. Diameter) Adjustabl e, Pontoon Area, Ungasketed 446 56.07 1.59

Roof Leg (3

- in. Diameter) Fixed 257 0.00 0.00

Roof Leg or Hanger Well Adjustable 117 100.00 0.74

Sample Pipe or Well (24

- in. Diam.) Slit Fabric Seal 10% Open 73 0.00 0.00

Slotted Guide

- Pole/Sample Well Gask Sl iding Covr, w. Float,Sleeve,Wiper 50 0.00 0.00

Slotted Guide

- Pole/Sample Well Gask. Sliding Cover, w. Float 3 93.50 0.02

Slotted Guide

- Pole/Sample Well Gask. Sliding Cover, w. Float, Wiper 17 64.70 0.07

Slotted Guide

- Pole/Sample Well Gask. Sliding Cover , w. Pole Sleeve 3 87.37 0.02

Slotted Guide

- Pole/Sample Well Gask. Sliding Cover, w. Pole Wiper 25 88.73 0.14

Slotted Guide

- Pole/Sample Well Gask. Sliding Cover, w/o Float 3 97.83 0.02

Stub Drain (1

- in Diameter) 52 0.00 0.00

Unslotted Guide

- Pole Well Gasketed Sliding Cover 12 93.05 0.07

Unslotted Guide

- Pole Well Gasketed Sliding Cover, w. Sleeve 52 0.00 0.17

Unslotted Guide

- Pole Well Gasketed sliding Cover, w. Wiper 111 0.00 0.00

Unslotted Guide

- Pole Well Ungasketed Sliding Cover 19 97.92 0.12

Unsl otted Guide

- Pole Well Ungasketed Sliding Cover, w. Sleeve 2 65.80 0.01

Vacuum Breaker (10

- in. Diam.) Weighted Mech. Actuation, Gask. 329 0.00 0.00

Vacuum Breaker (10

- in. Diam.) Weighted Mech. Actuation, Ungask. 56 5.47 0.02

TOTAL 15,581 APR = 7.49Appendix B Final Staff Report

Proposed Rule1178 B-5 December 11, 2001

Table B-4 – Average Percent Reduction for Internal Floating Roof Tanks

Deck Fitting Type Deck Covering Type Total Quantity (N) Percentage

Reduction (PR deck fitting,j) Average

percentage reduction
for deck fitting type j
Access Hatch (24

- in. Diam.) Bolted Cover, Gasketed 27 0.00 0.00

Access Hatch (24

- in. Diam.) Unbolted cover, Gasketed 2 94.84 0.19

Access Hatch (24

- in. Diam.) Unbolted Cover, Ungasketed 27 95.56 2.61

Automatic Gauge Float Well Bolted Cover, Gasketed 4 0.00 0.00

Automatic Gauge Float Wel l Unbolted Cover, Gasketed 2 34.88 0.07

Automatic Gauge Float Well Unbolted Cover, Ungasketed 22 80.00 1.78

Column Well (24

- in. Diam.) Built

- Up Col.

- Sliding Cover, Ungask. 84 78.72 6.69

Column Well (24

- in. Diam.) Pipe Col.

- Sliding Cover, Gask. 10 60.00 0.61

Gauge

- Hatch/Sample Well (8

- in. Diam.) Weighted Mech. Actuation, Gask. 26 0.00 0.00

Gauge

- Hatch/Sample Well (8

- in. Diam.) Weighted Mech. Actuation, Ungask. 3 79.58 0.24

Ladder Well (36

- in. Diam.) Sliding Cover, Gasketed 1 0.00 0.00

Ladder Well (36

- in. Diam.) Sliding Cover, Ungasketed 21 26.32 0.56

Roof Leg or Hanger Well Adjustable 541 0.00 0.00

Roof Leg (3

- in. Diameter) Adjustable, Center Area, Gasketed 8 0.00 0.00

Roof Leg (3

- in. Diameter) Adjustable, Pontoon Area, Gasketed 7 7.64 0.05

Roof Le g (3

- in. Diameter) Adjustable, Pontoon Area, Ungasketed 130 39.95 5.25

Sample Pipe or Well (24

- in. Diam.) Slit Fabric Seal 10% Open 21 0.00 0.00

Slotted Guide

- Pole/Sample Well Gask. Sliding Cover, w. Float 2 93.50 0.19

Slotted Guide

- Pole/Sample Well Gas k. Sliding Cover, w. Float, Wiper 1 64.70 0.07

Stub Drain (1

- in Diameter) 4 0.00 0.00

Unslotted Guide

- Pole Well Gasketed Sliding Cover 6 65.60 0.40

Unslotted Guide

- Pole Well Gasketed sliding Cover, w. Wiper 1 0.00 0.00

Vacuum Breaker (10

- in. Diam.) W eighted Mech. Actuation, Gask. 28 0.00 0.00

Vacuum Breaker (10

- in. Diam.) Weighted Mech. Actuation, Ungask. 11 20.51 0.23

TOTAL 989 APR = 18.93Appendix B Final Staff Report

Proposed Rule1178 B-6 December 11, 2001

Table B-5 – Emission Reduction Estimates for Upgrad ing Deck Fittings

Refinery No of

Tank Tank Type Deck F itting Loss (tpy) Deck Seam

Loss (tpy)

1 2 External Floating Roof Tank 0.0026755

1 13 External Floating Roof Tank 3.4874672

1 5 External Floating Roof Tank 0.1364386

1 30 External Floating Roof Tank 8.2205859

2 1 External Floating Roof T ank 1.6102257

2 8 External Floating Roof Tank 4.3981815

2 6 External Floating Roof Tank 1.8265909

2 96 External Floating Roof Tank 90.232071

2 1 External Floating Roof Tank 0.0446179

3 1 External Floating Roof Tank 0.0294418

3 1 Ext ernal Floating Roof Tank 6.2114569

3 11 External Floating Roof Tank 45.237567

4 17 External Floating Roof Tank 13.015572

4 7 External Floating Roof Tank 0.0263542

4 4 External Floating Roof Tank 0.8067324

4 9 External Floating Roof Tank 0.0369583

4 29 External Floating Roof Tank 21.410112

5 10 External Floating Roof Tank 2.4841894

5 4 External Floating Roof Tank 1.1072569

5 15 External Floating Roof Tank 1.8550396

6 6 External Floating Roof Tank 0.0022938

6 14 Ext ernal Floating Roof Tank 0.8029719

6 1 External Floating Roof Tank 0.0550625

6 2 External Floating Roof Tank 0.2703203

6 26 External Floating Roof Tank 0.3850399

6 39 External Floating Roof Tank 5.256555

6 3 External Floating Roof Tank 0.0078232

7 21 External Floating Roof Tank 3.764789

7 6 External Floating Roof Tank 2.0835597

Total 388 214.81 Average Percentage
Reduction =
7.49 Fitting Losses

= 16.09 tpy (0.05 tpd)

1 1 Internal Floating Roof Tank 8.2548613

1 3 Intern al Floating Roof Tank 1.0202083

2 4 Internal Floating Roof Tank 0.1080575 0.23

2 3 Internal Floating Roof Tank 0.339611 0.29

2 3 Internal Floating Roof Tank 0.52812 0.05

2 3 Internal Floating Roof Tank 0.1614993 0.08

8 14 Internal Floating Roof Tank 2.2675

3 1 Internal Floating Roof Tank 0.6639829 0.05

4 1 Internal Floating Roof Tank 0.9563761

5 2 Internal Floating Roof Tank 0.0981258

Total 35 14.40 0.7 Average Percentage
Reduction =
18.93 Fitting Losses

= 2.86 tpy (0.01 tpd)Appendix B Final Staff Report

Proposed Rule1178 B-7 December 11, 2001 

### Estimate of Emission Reductions from Upgrading Deck Fittings in Table 5-1
and Both Scenarios 1 and 2 in Table 6-6

• From Table B-5, emission reduction for EFRTs at 7 p etroleum refineries = 16.09 tpy

From Table 2-4, 2-5, and 2-6:
Emissions from EFRTs at 7 petroleum refineries = 45 1.19 tpy
Emissions from EFRTs at non petroleum refineries = 218.32 + 40.19 = 258.51 tpy
Emission reduction at non-petroleum refineries = 16 .09 x (258.51/451.19) = 9.22 tpy
Total emission reduction from deck fittings on EFRT s = 16.09 + 9.22 = 25.31 tpy

• From Table B-5, emission reduction for IFRTs at 7 p etroleum refineries = 2.86 tpy

From Table 2-4, 2-5, and 2-6:
Emissions from IFRTs at 7 petroleum refineries = 20 .72 tpy
Emissions from IFRTs at non petroleum refineries = 237.78 + 34.49 = 272.27 tpy
Emission reduction at non-petroleum refineries = 2. 86 x (272.27/20.72) = 37.58 tpy
Total emission reduction from deck fittings on IFRT s = 2.86 + 37.58 = 40.44 tpy

• Total emission from deck fittings on all floating r oof tanks at petroleum refineries = 16.09 +
2.86 = 18.95 tpy

or 0.05 tpd

Total emission reduction from deck fittings on all floating roof tanks at non petroleum facilities = 9.22 + 37.58 = 46.80 tpy or 0.13 tpd

Total emission reduction from deck fittings = 18.95 + 46.80 = 65.75 tpy or 0.18 tpdAppendix B Final Staff Report

Proposed Rule1178 B-8 December 11, 2001 

## Section B-3: Estimates of Emission Reductions for Domes

Table B-6 – Potential Domed External Floating Roof Tanks with TVP >3psia

and Estimated Emission Reductions (Note 3 and Note 4) Facility No

of Tanks Emissions

(tpy) Emi Reduction (tpy) Refinery #1 28 44.88 31.98 Refinery #2 47 127.82 76.47 Refinery #3 8 53.52 28.61 Refinery #4 28 73.89 48.49 Refinery #5 8 17.21 12.41 Refinery #6 3 5.70 3.98 Refinery #7 14 14.83 9.95

Other small

refineries 10 16.89 (Note 1) 10.59 (Note 1)

Non Refineries 95 240.90 151.10 (Note 2)

Total 241 595.64 (tpy) 1.63 (tpd) 373.58 (tpy) 1.02 (tpd)
Note: 1) Assume emissions and emission reductions of small refineries are about 5% of total emissions and emission reductions from other major refineries. 2) Emission reductions at non petroleum refineries = (emission reductions at 7 re fineries) x (emissions at non refineries/emissions at 7 refineries) = 211.89 tpy x (240.90/337.83) = 151 .10 tpy. 3) The 373.58 tpy (1.02 tpd) reduction

shown in this table would be further reduced down t o 324.21 tpy (0.89 tpd) as shown in the paragraphs below to remove the potential of double counting e mission reductions associated with deck fittings, and emission reductions associated with doming crud e oil tanks. 4) The number of potential domed
tanks would be further reduced to 195 to exclude 46 crude oil tanks from doming requirements.



### Estimate of Emission Reductions From Installing Dom ed Roofs on External Floating Roof Tanks Containing Organic Liquids with TVP > ≥ 

### 3 psia in Table

5-1 and Scenario 1 Staff Proposal (Scenario 1) inTable 6-6

Total emission reductions from upgrading deck fitti ngs of all 526 EFRTs = 25.31 tpy. To be conservative in the cost effectiveness analys is, it is assumed that total emission reductions from upgrading deck fittings of 241 EFRT s containing materials having

TVP > ≥ 3 psia are 25.31 tpy.

Total emissions reductions from retrofitting with d omes after upgrading all deck fittings of 241 EFRTs = 373.58 tpy - 25.31 tpy = 348.27 tpy = 0.95 tpd.

Total emissions reductions from retrofitting extern al floating roof tanks, excluding crude oil tanks, with domes = 348.27 tpy - 24.06 tpy = 324.21 tpy = 0.89 tpd

.Appendix B Final Staff Report

Proposed Rule1178 B-9 December 11, 2001 

### Estimate of Emission Reductions From Installing Dom ed Roofs on All External Floating Roof Tanks for Scenario 2 in Table 6-6

Total emission reductions from retrofitting with do mes at 7 refineries = 222 tpy. Total emissions reductions from retrofitting with d omes at 3 small refineries = (222 tpy x 5% = 11 tpy.

Total emission reductions from retrofitting with do mes at non-refineries = 222 x (240.90/337.83) = 158 tpy.

Total emission reductions with domes = 222 + 11 + 1 58 = 391 tpy

Total emission reductions from retrofitting with do mes after upgrading all deck fittings = 391 tpy - 25.31 tpy = 365.69 tpy.



## Section B-4: Emission Reductions for Retrofitting Fixed Roof Tanks with Floating Roofs or Vapor Recovery Systems

Table B-7 – Fixed Roof Tanks with TVP >0.1psia Curr ently Vented to the Atmosphere

Facility No

of Tanks Emissions

(tpy) Emi Reduction at

95% Control Efficiency (tpy) Refinery #1 6 26.19 24.88 Refinery #2 9 6.46 6.14 Refinery #3 4 5.82 5.53

Non Refineries 51 26.16

Total 70 62.71 (tpy) 0.17 (tpd)



### Estimate of Emission Reductions From Converting Fix ed Roof Tanks to Internal Floating Roof Tanks in Table 5-1 and Scenario 1 Staff Proposal (Scenario 1) in Table 6-6

From Table 2-4, 2-5, and 2-6:
Emissions from fixed roof tanks at petroleum refine ries = 120.69 tpy
Emissions from fixed roof tanks at non petroleum re fineries = 37.08 + 49.29 = 86.37 tpy

From Table B-6:Appendix B Final Staff Report

Proposed Rule1178 B-10 December 11, 2001 Emission reduction at petroleum refineries = 36.55 tpy Emission reduction at non petroleum refineries = 36 .55 x (86.37/120.69) = 26.16 tpy



### Estimate of Emission Reductions From Converting Fix ed Roof Tanks to Internal Floating Roof Tanks in Scenario 2 in Table 6-6

From Table 2-4, 2-5, and 2-6:
Emissions from fixed roof tanks at petroleum refine ries = 120.69 tpy
Emissions from fixed roof tanks at non petroleum re fineries = 37.08 + 49.29 = 86.37 tpy

Emission reduction from 133 fixed roof tanks at pet roleum refineries = 83 tpy
Emission reduction at non petroleum refineries = 83 x (86.37/120.69) = 59 tpy



## Section B-5: Emission Reductions and Source Testin g for PressureVacuum Vents

Leakage rates from PV vents are reported in "Use of Pressure-Vacuum Vent Valves For Atmospheric Pressure Tanks To Reduce Evaporation Lo ss", API Bulletin #2521, September 1966. From this document, leakage rate is reported as less than 0.5 cft/hr for vents 6 inches in size or smaller, or 5 cft/hr for vents 8 inches in size or larger. Assuming vapor density of 0.1 lbs/cft, the leakage rates are estimated to be 0.05 lbs/hr (0.22 tpy) for vents 6 inches in size or smaller, or 0.5 lbs/hr (2.2 tpy) for vents 8 inches in size or larger. As an estimate for emission reductions from PV vents, District staff used a fac tor of 0.10 tpy per PV vents regardless of size and type. In order to verify the assumption used t o estimate the emission reductions associated with PV vents, District staff conducted emissions s ampling at two locations in the District. The testing and results are described below.

The testing consisted of measuring VOC emissions on three separate PV valves for 30 minutes each. The PV valves were located on fixed roof petr oleum storage tanks connected to vapor

recovery. Screening values were also measured before and afte r sampling by EPA Method 21

. The relationship between measured emissions and scr eening value can be used to check the validity of existing emission factors and for corre lating PV valve emissions. The results of the testing are summarized below.

The PV valves sampled did not appear to be damaged and no leaks from the casing were noticed using the portable TVA. It appeared that the emiss ions were attributed to the valves not being properly seated. There was a noticeable amount of d irt and dust on and around the PV valve as observed by the District source test team at facili ty A. At facility B, the PV valve was relatively clean as compared to facility A.Appendix B Final Staff Report

Proposed Rule1178 B-11 December 11, 2001 Table B-8 - VOC Emissions from Fixed Roof Petroleum Storage Tanks

Tank # PV Valve EPA Method 21 Screening Value (PPM) Emissions

(lbs/hr)

Facility A, Oriente Crude Varac – 12 inch >100,000 9.81

Facility A, Oriente Crude Protectoseal – 8 inch >100,000 2.52

Facility B, Naphtha Varac – 8 inch 325 0.0051

Note: Emissions are 42.96 tpy, 11.04 tpy and 0.02 tpy respectively for 24 hrs/day, 365 days/yr.

Both facilities have numerous tanks that store petr oleum products including crude oil, naptha, diesel, and gasoline. The tanks tested all were fix ed roof tanks containing Oriente crude oil, and naphtha having vapor pressures between 2 and 5 psi. The fixed roof storage tanks sampled contained multiple 8” and 12” PV valves set for 3⁄4 o z./sq. in. (.0625 psi) pressure and vacuum. For each storage tank, the testing was performed on one PV valve. One of the storage tanks contained Varac 12” PV valves set for 3⁄4 oz. pressur e/vacuum. The second storage tank had Protectoseal 8” PV valves set for 3⁄4 oz. pressure/va cuum. The final PV valve sampled was a Varac 8” PV valve set for 3⁄4 oz. pressure/vacuum. Th ese tests were conducted in accordance with applicable SCAQMD and EPA test methodologies. Both storage tanks were tested under normal operating conditions.

For fugitive emissions from the storage tanks, a pr ocedure analogous to the "Vacuum Method"

from the EPA Protocol for Equipment Leaks Estimates was employed. The PV valves on the tops of the storage tanks were identified as potent ial sources of fugitive emissions. For each test, a wood framed plastic tent was placed over the PV v alve and attached with adhesive tape to the tank roof to isolate it from the surroundings. The pressure inside of the enclosure relative to

ambient was not lower than -0.01 inches water colum n as measured by a calibrated electronic manometer during testing. Since the tent covered th e entire PV valve, any emissions from the pressure side and from the vacuum side of the valve were tested simultaneously.

The emissions of VOC were continuously withdrawn fr om the enclosure with either a manually or battery operated blower to draw air through the system. To prevent an explosion, the manually operated blower was used when it was determined tha t emissions were at the chemical’s LEL. Air was allowed to enter the tent through an openin g in the tent located on its upwind side. The flow rate, concentration, and mass emissions from t he PV valves were measured at the blower outlet duct using SCAQMD Methods 1.1, 2.1, and 25.3.

A portable flame ionization detector (FID) was used during sampling and screening the PV valves, monitoring duct concentration, monitoring b ackground levels and checking for tent fugitive emissions. While these portable FID readin gs were not used in calculating emissions, the

values that were recorded are located in the field notes. The specifics of each sampling andAppendix B Final Staff Report

Proposed Rule1178 B-12 December 11, 2001 analytical method employed are given in the section s that follow. In addition, the start and end

times of each test run were recorded.Appendix C Final Staff Report

Proposed Rule1178 C-1 December 11, 2001 

## Appendix C - Cost Effectiveness Analysis

Section C-1: Domed External Floating Roof Tanks

Scenario 1 Staff Proposal (Scenario 1) (Control EFRTs with

TVP > ≥ 3 psia

, excluding crude oil
tanks ) Scenario 2 The most

stringent proposal (Scenario 2) (Control
All EFRTs , including
crude oil tanks )

Tank Diameter ft 30 - 260 30 - 260

No of tanks 241 195 (146 refineries
and 95 non

- refineries) 526 (383 refineries and
143 non

- refineries)

Emission Reduction tpy 348.27 324.21 365.69

CAPITAL COST

Equipment Cost As Installed Including Taxes and Freight $ 49,780,99 3 33,594,943 108,650,632

Tax (8% Equipm.Cost) Permit Cost ($2,115.04 per application) $ 0 412,433 0 1,112,511

Freight (3.8% Equipm.Cost) Project Management (5% Equip. Cost) $ 0 1,679,747 0 5,432,532

Loss of Use (Based on a lease rate of 1.5 cents/barrels-day) $ 19,129,568 11,041,053 19,129,568 13,445,036

Total Capital Cost (Equipment Cost As Installed Including Taxes and Freight + Loss of Use) $ 68,910,561 46,728,176 127,780,200 128,640,711

ANNUAL OPERATING COST

Annual Maintenance Cost (1% Equipm.Cost) $/yr 4 97,810 335,949 1,086,506

Annual Insurance and Property Taxes ( 1 2 % Capital Cost) $/yr 689,106 934,564 1,277,802 2,572,814

Annual Emission Savings ($819.11/ton) $/yr 265,564 299,540

Product Savings at $200/ton $/yr 69,654 64,842 73,138

Inspection Savings $/yr 15,600 42,080

Total Annual Operating Cost With Product Savings (Annual Maintenance + Insurance - Annual Emission Savings - Product Savings - Inspection Savings ) $/yr 1,117,262 924,507 2,291,170 3,244,562

PRESENT WORTH VALUEAppendix C Final Staff Report

Proposed Rule1178 C-2 December 11, 2001 With Product Savings $ 8 4,094,145 59,292,230 158,917,205 172,734,311

COST EFFECTIVENESS FACTOR

With Product Savings (PWV / (EmiReductionx20)) $/ton 12,073 9,144 21,728 23,618Appendix C Final Staff Report

Proposed Rule1178 C-3 December 11, 2001 

## Section C-2: Rim Seal Systems

Scenario 1 Staff Proposal (Scenario 1) Scenario 2 The most

stringent proposal (Scenario 2)

Primary
Seals Secondary

Seals Primary

Seals Secondary

Seals

True Vapor Pressure of Materials Stored >0.1psia >0.1psia All All

Tank Diameter ft 127 127 127 127

Tank Circumference ft 399 399 399 399

No of Tanks 3 9 3 66

CAPITAL COST

Cost of Rim Seals Per Linear Foot As Installed $/ft 107 98 107 98

Total Cost of Rim Seals $ 128,074 351,903 128,074 2 ,580,623

Tax (8% Cost of Rim Seals) $ 10,246 28,152 10,246 2 06,450

Total Capital Cost (Cost of Rim Seals As Installed+ Tax) $ 138,319 380,055 138,319 2,787,073

ANNUAL OPERATING COST

Annual Maintenance Cost (8hr/day at $30/hr for 1 tank for secondary seals) $/yr 0 2,160 0 15,840

Product Savings at $200/ton $/yr 802 2,334

Total Annual Operating Cost With Product Savings (Annual Maintenance - Product Savings) $/yr 1,358 13,506

PRESENT WORTH VALUE

With Product Savings (assuming 10 years life and 4% interest rate; PWV = Capital Cost + (8.11*Annual Operating Cost)) $ 529,388 3,034,926

COST EFFECTIVENESS FACTOR

Emi Reduction tpy 4 12

With Product Savings (PWV / (EmiReductionx10)) $/ton 13,202 26,006Appendix C Final Staff Report

Proposed Rule1178 C-4 December 11, 2001 

## Section C-3: Deck Fittings for External Floating Ro of Tanks

Scenario 1 Staff Proposal (Scenario 1) - External

Floating Roof Tanks

Type of Fittings O ther Fittings Guidepoles All

No of Fittings Need to Be Upgraded 6,281 274 6,555

Emissions Reduction tpy 25.31

CAPITAL COST

Cost of Upgrading Per Fitting $ 500 10,000

Cost of Upgrading All Fitting $ 3,140,500 2,740,000 5,880,500

Tax (8% Cost of Upgrading Fittings) $ 251,240 219,2 00 470,440

Percentage to Determine Installation Cost (A%) % 10 0

Installation (A% Cost of Upgrading Fittings) $ 314, 050 0 314,050

Total Capital Cost (Cost of Upgrading Fittings + Ta x + Installation) $ 3,705,790 2,959,200 6,664,990

ANNUAL OPERATING COST

Annual Maintenance Cost (8hr/day, $30/hr) $/yr 240

Product Savings at $200/ton $/yr 5,062

Total Annual Operating Cost With Product Savings (Annual Maintenance - Product Savings) $/yr -4,822

PRESENT WORTH VALUE

With Product Savings $ 6,625,884

COST EFFECTIVENESS FACTOR

With Product Savings (PWV / (EmiReductionx10)) $/ton 26,179Appendix C Final Staff Report

Proposed Rule1178 C-5 December 11, 2001 

## Section C-3 (continued)

Scenario 2 The most stringent proposal (Scenario 2) - External Floating Roof Tanks

Type of Fittings Others Guidepoles All

No of Fittings Need to Be Upgraded 7,252 287 7,539

Emissions Reduction tpy 25.31

CAPITAL COST

Cost of Upgrading Per Fitting $ 500 10,000

Cost of Upgrading All Fitting $ 3,626,000 2,870,000 6,496,000

Tax (8% Cost of Upgrading Fittings) $ 290,080 229,6 00 519,680

Percentage to Determine Installation Cost (A%) % 10 0

Installation (A% Cost of Upgrading Fittings) $ 362, 600 0 362,600

Total Capital Cost (Cost of Upgrading Fittings + Ta x + Installation) $ 4,278,680 3,099,600 7,378,280

ANNUAL OPERATING COST

Annual Maintenance Cost (8hr/day, $30/hr) $/yr 240

Product Savings at $200/ton $/yr 5,062

Total Annual Operating Cost With Product Savings (Annual Maintenance - Product Savings) $/yr -4,822

PRESENT WORTH VALUE

With Product Savings $ 7,339,174

COST EFFECTIVENESS FACTOR

With Product Savings (PWV / (EmiReductionx10)) $/ton 28,997Appendix C Final Staff Report

Proposed Rule1178 C-6 December 11, 2001 

## Section C-4: Deck Fittings for Internal Floating Ro of Tanks

Scenario 1 Staff Proposal (Scenario 1) - Internal Floating Roof Tanks

Type of Fittings Other Fittings

Guidepoles All

No of Fittings Need to Be Upgraded 1,057 172 1,229

Emissions Reduction tpy 40.44

CAPITAL COST

Cost of Upgrading Per Fitting $ 500 10,000

Cost of Upgrading All Fitting $ 528,500 1,720,000 2 ,248,500

Tax (8% Cost of Upgrading Fittings) $ 42,280 137,60 0 179,880

Percentage to Determine Installation Cost (A%) % 10 0

Installation (A% Cost of Upgrading Fittings) $ 52,8 50 0 52,850

Total Capital Cost (Cost of Upgrading Fittings + Ta x + Installation) $ 623,630 1,857,600 2,481,230

ANNUAL OPERATING COST

Annual Maintenance Cost (8hr/day, $30/hr) $/yr 240

Product Savings at $200/ton $/yr 8,088

Tota l Annual Operating Cost With Product Savings (Annual Maintenance - Product Savings) $/yr -7,848

PRESENT WORTH VALUE

With Product Savings $ 2,417,583

COST EFFECTIVENESS FACTOR

With Product Savings (PWV / (EmiReductionx10)) $/ton 5,978Appendix C Final Staff Report

Proposed Rule1178 C-7 December 11, 2001 

## Section C-4 (continued)

Scenario 2 The most stringent proposal (Scenario 2) - Internal Floating Roof Tanks

Type of Fittings Others Guidepoles All

No of Fittings Need to Be Upgraded 1,207 186 1,393

Emissions Reduction tpy 40.44

CAPITAL COST

Cost of Upgrading Per Fitting $ 500 10,000

Cost of Upgrading All Fitting $ 603,500 1,860,000 2 ,463,500

Tax (8% Cost of Upgrading Fittings) $ 48,280 148,80 0 197,080

Percentage to Determine Installation Cost (A%) % 10 0

Installation (A% Cost of Upgrading Fittings) $ 60,3 50 0 60,350

Total Capital Cost (Cost of Upgrading Fittings + Ta x + Installation) $ 712,130 2,008,800 2,720,930

ANNUAL OPERATING COST

Annual Maintenance Cost (8hr/day, $30/hr) $/yr 240

Product Savings at $200/ton $/yr 8,088

Total Annual Operating Cost With Product Savings (Annual Maintenance - Product Savings) $/yr -7,848

PRESENT WORTH VALUE

With Product Savings $ 2,657,283

COST EFFECTIVENESS FACTOR

With Product Savings (PWV / (EmiReductionx10)) $/ton 6,571Appendix C Final Staff Report

Proposed Rule1178 C-8 December 11, 2001 

## Section C-5: Internal Floating Roof Tanks

Scenario 1 Staff Proposal (Scenario 1) Scenario 2 The

most stringent proposal (Scenario 2)

No of tanks 70 296

Emissions Reduction tpy 62.71 142

CAPITAL COST

Equipment Cost As Installed Including Taxes, Freigh t, Engineering and Installation $ 7,663,158 32,404,211

Loss of Use (40% Equipm Cost) $ 3,065,263 12,961,68 4

Total Capital Cost (Equipment Cost + Tax + Freight + Engineering + Installation + Loss of Use) $ 10,728,421 45,365,895

ANNUAL OPERATING COST

Annual Maintenance Cost (3% Equipm.Cost) $/yr 229,8 95 972,126

Annual Insurance (1% Capital Cost) $/yr 107,284 453 ,659

Product Savings at $200/ton $/yr 12,542 28,400

Total Annual Operating Cost With Product Savings (Annual Maintenance + Insurance - Product Savings) $/yr 324,637 1,397,385

PRESENT WORTH VALUE

With Product Savings (assuming 20 years life and 4% interest rate; PWV = Capital Cost + (13.59*Annual Operating Cost)) $ 15,140,237 64,356,360

COST EFFECTIVENESS FACTOR

With Product Savings (PWV / (EmiReductionx20)) $/t on 12,072 22,661Appendix C Final Staff Report

Proposed Rule1178 C-9 December 11, 2001 

## Section C-6: Pressure-Vacuum Vents

Scenario 1 Staff Proposal (Scenario 1) Scenario 2 The most

stringent proposal (Scenario 2)

No of PV Vents 532 532

Emissions Reduction Per PV Vents tpy 0.10 0.10

Emissions Reduction tpy 53.20 53.20

CAPITAL COST

Total Capital Cost (Total Cost of PV Vents + Tax + Installation) $ 0 0

ANNUAL OPERATING COST

Annual Maintenance Cost ($500 per PV vents) $/yr 26 6,000 266,000

Product Savings at $200/ton $/yr 10,640 10,640

Total Annual Operating Cost With Product Savings (Annual Maintenance - Product Savings) $/yr 255,360 255,360

PRESENT WORTH VALUE

With Product Savings (assuming 10 years life and 4% interest rate; PWV = capital cost + (8.11*annual operating cost)) $ 2,070,970 2,070,970

COST EFFECTIVENESS FACTOR

With Product Savings (PWV / (EmiReductionx10)) $/ton 3,893 3,893Appendix DFinal Staff ReportProposed Rule 1178D-1December 11, 2001Appendix D - Impact Study on Doming of External Floating Roof TanksTable D-1: Tank Removal and Capacity Removal At Refineries Based on Doming Including Crude Oil TanksRefineryNo ofEFRTsCapacity ofEFRTsNo ofIFRTsCapacityof IFRTsNo ofFRTsCapacity ofFRTsTotal No ofTanks(includingexistingDomedEFRTs)TotalTankCapacityNo ofPotentialDomedEFRTsTank % (4 Yearsof ConstructionUsing ExternalFloating RoofTanks)Capacity % (4Years ofConstructionUsing Capacity ofExternal FloatingRoof Tanks)Tank % (4Years ofConstructionUsing AllTanks)Capacity % (4Years ofConstructionUsing Capacityof All Tanks)NextVext(millionbarrels)NintVint(millionbarrels)NfixVfix (millionbarrels)NtotalVtotal(millionbarrels)Ndomed(Ndomed/(4*Next)((Sum (Vdomed*D) / (Vext *365 *4))*100(Ndomed/(4*Ntotal)((Sum (Vdomed*D) / (Vtotal *365* 4))*1001504.6840.70556.2210911.602814 2.13 6 0.86211117.53130.38680.0019217.924711 1.56 6 1.523131.1410.00924.971076.11815 1.58 2 0.294665.1710.16453.401148.732811 1.80 6 1.075294.2320.1630.24344.6287 2.05 6 1.886876.4700.0040.28956.7531 0.13 1 0.127272.8700.00100.26373.131413 2.34 9 2.1538342.09211.3927715.3668858.851369 5AVG10 1.66 5 1.13Note: Next = Number of external floating roof tanks, Vext = Capacity of external floating roof tanks,Nint = Number of internal floating roof tanks, Vint = Capacity of internal floating roof tanks, Nfix= Number of fixed rooftanks, Vfix = Capacity of fixed roof tanks, Ndomed= Number of potential domed roof tanks, Vdomed = Capacity of domed roof tanks, D = number of days forconstruction of domed roofs.Appendix D Final Staff Report

Proposed Rule 1178 D-2 December 11, 2001 

### Figure D-1: Capacity Removal At Refineries Based on Doming - Considering All Types of Tanks And Including Crude Oil Tanks



# Capacity Removal (All Tanks)

0.00 0.50 1.00 1.50 2.00 2.50

1 2 3 4 5 6 7 

## Refinery

4 Years Plan Average = 1.13Appendix D Final Staff Report

Proposed Rule 1178 D-3 December 11, 2001 

### Figure D-2: Capacity Removal At Refineries Based on Doming - Considering All External Floating Roof Tanks and Including Crude Oil Tanks



# Capacity Rem oval (EFR Ts O nly)

0.00 0.50 1.00 1.50 2.00 2.50

1 2 3 4 5 6 7 

### R efineryCapacity Removal (%)

4 Y ears P lan Avg = 1.66Appendix D Final Staff Report

Proposed Rule 1178 D-4 December 11, 2001 

### Figure D-3: Tank Removal At Refineries Based on Dom ing - Considering All Types of Tanks And Including Crude Oil Tanks



# Tank Removal (All Tanks)

0 1 2 3 4 5 6 7 8 9 10

1 2 3 4 5 6 7 

### RefineryTank Removal (%)

Tank Removal Avg Tank Removal = 5%Appendix D Final Staff Report

Proposed Rule 1178 D-5 December 11, 2001 

### Figure D-4: Tank Removal At Refineries Based on Dom ing - Considering All External Floating Roof Tanks and Including Crude Oil Tanks



## Tank Removal (EFRTs Only)

0 5 10 15 20 25 30

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 

### Non-RefineryTank Removal (%)

Tank Removal Avg Tank Removal = 21%Appendix DFinal Staff ReportProposed Rule 1178D-6December 11, 2001Table D-2: Tank Removal and Capacity Removal At Non-Refineries Based on Doming Including Crude Oil TanksFacilityNo ofEFRTsCapacity ofEFRTsNo ofIFRTsCapacity ofIFRTsNo ofFRTsCapacity ofFRTsTotal Noof TanksTotal TankCapacityNo ofPotentialDomedEFRTsCapacity ofPotential DomedEFRTsTank % (4 Years ofConstruction UsingExternal FloatingRoof Tanks)Capacity % (4 Yearsof ConstructionUsing Capacity ofExternal FloatingRoof Tanks)Tank % (4Years ofConstructionUsing AllTanks)Capacity % (4Years ofConstruction UsingCapacity of AllTanks)NextVext (millionbarrels)NintVint (millionbarrels)NfixVfix (millionbarrels)NtotalVtotal(millionbarrels)NdomedVdomed (millionbarrels)(Ndomed/(4*Next))((Sum (Vdome *D) /(Vext *365 * 4))*100(Ndomed/(4*Ntotal))((Sum (Vdome *D) /(Vtotal *365 *4))*1005100.9900.0020.06121.0590.94 23 2.87 19 2.72820.20181.0000.00201.2020.20 25 2.19 3 0.3711241.9060.1000.00302.00151.43 16 2.89 13 2.741920.0210.0400.0030.0520.02 25 2.60 17 0.80480.3600.0020.16100.5160.35 19 2.68 15 1.861060.23272.24761.011093.4840.23 17 3.38 1 0.222220.2270.2600.0090.4820.22 25 2.81 6 1.28740.2760.5770.15170.9820.13 13 0.52 3 0.143120.0510.0410.0340.1220.05 25 132110.28230.6820.03361.0490.32 20 0.87 6 0.24150.21100.6000.00150.8150.21 25 3.09 8 0.806111.31312.9981.10505.41110.56 25 1.60 6 0.391780.3750.2520.09150.7170.08 22 2.26 12 1.18980.0900.0020.03100.1170.09 22 4.27 18 3.273212.1000.0000.00212.10161.60 19 2.55 19 2.551248.591358.771022.6436120.0499note6.42 20 7AVG 21 2.47 10 1.33Note: Next = Number of external floating roof tanks, Vext = Capacity of external floating roof tanks,Nint = Number of internal floating roof tanks, Vint = Capacity of internal floating rooftanks, Nfix = Number of fixed roof tanks, Vfix = Capacity of fixed roof tanks, Ndomed = Number of potential domed roof tanks, Vdomed = Capacity of domedroof tanks, D = number ofdays for construction of domed roofs.This number (99) included several tanks that arealready domed.Appendix D Final Staff Report

Proposed Rule 1178 D-7 December 11, 2001 

### Figure D-5: Capacity Removal At NonRefineries Based on Doming - Considering All Types of Tanks And Including Crude Oil Tanks



## C ap acity R em o val (A ll Tan ks)

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50

5 8 11 1 9 4 10 2 2 7 3 1 2 1 6 17 9 3 

### N on-R efineryCapacity Removal (%)

C a pa city R em o val A vg C a pa city R e m oval = 1 .3 3 %Appendix D Final Staff Report

Proposed Rule 1178 D-8 December 11, 2001 

### Figure D-6: Capacity Removal At NonRefineries Based on Doming - Considering Only External Floating Roof Tanks And Including Cru de Oil Tanks



## Capacity Rem oval (EFRTs O nly)

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50 4.00 4.50

5 8 11 19 4 10 22 7 31 2 1 6 17 9 3 

### Non-R efineryCapacity Removal (%)

C apacity R em oval Avg Capacity R em oval = 2.47%Appendix D Final Staff Report

Proposed Rule 1178 D-9 December 11, 2001 

### Figure D-7: Tank Removal At Non-Refineries Based on Doming - Considering All Types of Tanks And Including Crude Oil Tanks



# Tank Removal (All Tanks)

0 2 4 6 8 10 12 14 16 18 20

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 

### Non-RefineryTank Removal (%)

Tank Rem oval

Avg Tank Rem oval = 10%Appendix D Final Staff Report

Proposed Rule 1178 D-10 December 11, 2001 

### Figure D-8: Tank Removal At Non-Refineries Based on Doming - Considering Only External Floating Roof Tanks And Including rud e Oil Tanks



# Tank Removal (EFRTs Only)

0 5 10 15 20 25 30

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 

## Non-RefineryTank Removal (%)

Tank Removal Avg Tank Removal = 21%Appendix DFinal Staff ReportProposed Rule 1178D-11December 11, 2001Table D-3: Tank Removal and Capacity Removal At Refineries Based on Doming Excluding Crude Oil TanksFacility NameNo ofEFRTsNo ofCrudeTanksNo of EFRTsExcludingCrudeTanksEFRTsCrude TanksEFRTs ExcludingCrude TanksNo ofPotentialDomedEFRTsNo ofPotentialDomedEFRTsExcludingCrudeTank % (4 YearsofConstructionUsing ExternalFloating RoofTanks includingcrude tanks)Tank % (6Years ofConstructionUsing ExternalFloating RoofTanks,excludingcrude tanks)Capacity % (4Years ofConstructionUsing Capacityof ExternalFloating RoofTanks)Capacity % (6Years ofConstructionUsing Capacity ofExternal FloatingRoof Tanksexcluding crudetanks)NextNcrudeNext,nocrudeVext (gals)Vcrude (gals)Vext,nocrude(gals)NdomedNdomed, nocrude(Ndomed/(4*Next)(Ndomed,nocrude/(6*Next, nocrude)((Sum (Vdomed*D) / (Vext *365* 4))*100((Sum(Vdomed,nocrude*D) / (Vext,nocrude*365 * 6))*1001 50 743196,697,634 52,837,344143,860,29028211482.130.892 111 7104736,394,000 104,819,400631,574,60047401161.560.453 13 01347,964,000 047,964,0008815101.580.944 66 363216,976,410 14,253,372202,723,03828251171.800.995 29 623177,521,449 83,563,20093,958,24982712.050.096 87 087271,716,018 0271,716,01833110.130.077 27 522120,540,000 50,400,00070,140,0001491372.340.73TOTAL383 2835513610895AVG1061.660.59Appendix DFinal Staff ReportProposed Rule 1178D-12December 11, 2001Table D-4: Tank Removal and Capacity Removal At Non-Refineries Based on Doming Excluding Crude Oil TanksFacilityNo ofEFRTsNo ofCrudeTanksNo ofEFRTsExvludingCrudeTanksEFRTsCrudeTanksEFRTs ExcludingCrude TanksNo ofPotentialDomedEFRTsNo ofPotentialDomedEFRTsExcludingCrude TanksTank % (4Years ofConstructionUsing ExternalFloating RoofTanks)Tank % (6Years ofConstructionUsing ExternalFloating RoofTanks,ExcludingCrude Tanks)Capacity % (4Years ofConstructionUsing Capacityof ExternalFloating RoofTanks)Capacity % (6 Yearsof ConstructionUsing Capacity ofExternal FloatingRoof Tanks,Excluding CrudeTanks)NextNcrudeNext,nocrudeVext (gals)Vcrude(gals)Vext,no crude(gals)NdomedNdomed,nocrude(Ndomed/(4*Next))(Ndomed/(6*Next,no crude))((Sum (Vdome*D) / (Vext *365* 4))*100((Sum(Vdome,nocrude *D)/ (Vext *365 * 6))*10051001041,606,000041,606,0009923152.871.9182028,400,00008,400,0002225172.191.46112471779,766,00063,188,58016,577,4201581682.892.4219202684,6000684,6002225172.601.74480814,998,800014,998,8006619132.681.78106069,704,37009,704,3704417113.382.25222029,156,00009,156,0002225172.811.87740411,256,000011,256,000221380.520.35312022,070,00002,070,00022251721101111,739,000011,739,0009920140.870.5815058,799,00008,799,0005525173.092.066112955,104,0006,553,68048,550,32011925171.600.971780815,552,000015,552,0007722152.261.5198083,584,00003,584,0007722154.272.8532141788,200,00020,531,28067,668,720161219122.551.6612413(Note)11199(Note)8613AVG21142.471.67Note: These numbers include several tanks that arealready domed.Appendix E Final Staff Report

Proposed Rule 1178 E-1 December 11, 2001 

# Appendix E - Comparative Analysis

Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

Applicability

PR 1178 R.463 40CFR60 BAAQMD

Above ground storage tanks at petroleum facilities emitting 20tpy or more as of inventory year 1999, equal to or greater than 19,815 gallons, that are used to store petroleum liquids with a vapor pressure of 0.1 psia or greater. Storage tanks from 19,815 gallons to 39,630 gallons containing organic liquids with a vapor pressure of 1.5 psia or greater.

Storage tanks from 39,630 gallons containing organic liquids with a vapor pressure of 0.5 psia or greater.

Storage tanks from 251 gal to 19,815 gal storing gasoline. Subpart K Storage tanks from 40,000 gallons to 65,000 gallons built after 3/8/74, but before 5/19/78, containing petroleum liquids with a vapor pressure of 1.5 psia to 11.1 psia.

Storage tanks from 40,000 gallons to 65,000 gallons built after 3/8/74, but before 5/19/78, containing petroleum liquids with a vapor pressure of 1.5 psia to 11.1 psia.

Storage tanks from 65,000 gallons built after 6/11/73 but before 5/19/78, containing petroleum liquids with a true vapor pressure of 1.5 psia up to 11.1 psia.

Subpart Ka Storage tanks from 40,000 gallons built after 5/18/78 and prior to 7/23/84, containing petroleum liquids with a true vapor pressure of 1.5 psia up to 11.1 psia.

Subpart Kb Storage tanks built after 7/23/84, containing volatile organic liquids (including petroleum liquids) from 19,185 gallons up to 39,889 gallons with a vapor pressure between 4 psia and 11.1 psia and storage tanks greater than 39,889 gal with a maximum vapor pressure between 0.75 psia and 11.1 psia. Storage Tanks between 9906 gallons and 19,813 gallons storing a liquid with a true vapor pressure greater than 1.5 psia.

Storage Tanks between 19,813 gallons and 39,626 gallons storing a liquid with true vapor pressure greater than 1.5 psia.

Storage Tanks with a capacity less than or equal to 39,626 gallons storing a liquid with a true vapor pressure greater than 0.5 psia.

Storage Tanks with capacity equal to or greater than 39,626 gallons with a true vapor pressure greater than 0.5 psia.

Gasoline Storage Tanks less than or equal to 19,813 gallons.

Storage tanks with a true vapor pressure greater than 11 psia.Appendix E Final Staff Report

Proposed Rule 1178 E-2 December 11, 2001 Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAA QMD Regulation 8, Rule 5

External Floating Roof Tank Requirements (Seals/Gaps)

PR 1178 R.463 40CFR60 BAAQMD

Rim seal system consisting of two seals, covering the annular space between the floating roof and the tank wall in a continuous fashion.

Liquid mounted primary seals for both welded and riveted tanks.

Secondary seals shall be rimmounted.

Rim seal system to cover the annular space between the floating roof and the wall in a continuous fashion.

Primary Seal Gaps between the tank shell and the primary seal shall not exceed 1.3 cm (1/2 in.) for a cumulative length of 30% of the tank circumference and 0.32 cm (1/8 in.) for 60% of the tank circumference.

No gap b/w the tank shell and the primary seal shall exceed 3.8 cm (1-1/2 in.).

No continuous gap b/w the tank shell and the primary seal shall exceed 10% of the tank circumference.

Mechanical shoe primary seals shall be installed so that one end of the shoe extends into the stored liquid and the other end extends a minimum vertical distance of 61 cm (24 in.) above the stored organic liquid.

Secondary Seal Gaps between the tank shell and the secondary seal shall not exceed 0.32 cm (1/8 in.) for a cumulative length of 95% of the tank circumference. No gap between the tank shell and the secondary seal shall exceed 1.3 cm (1/2 in.).

The secondary seal shall be installed in a way that permits the insertion of probes up to 3.8 cm (1-1/2 in.) in width to measure gaps in the primary seal. Two seals, one above the other.

Metallic shoe-type primary seals installed on or after August 1, 1977 shall be installed so that one end of the shoe extends into the stored organic liquid and the other end extends a minimum vertical distance of 61 centimeters (24 inches) above the stored organic liquid surface.

No specification for other types of primary seals.

(Gap requirements for primary and secondary seals same as Proposed Rule 1178).

Secondary seals shall not be attached to the primary seal.

Both seals may be removed for preventive maintenance upon notification of the E.O. for a period of up to 72 hours.

There shall be no holes, tears or openings in the secondary seal or in the primary seal envelope surrounding the annular vapor space enclosed by the roof edge, seal fabric, and secondary seal. Subpart K No seal specs. Given

Subpart Ka

The closure device has to consist of 2 seals, one above the other. The floating roof has to be floating on the liquid at all times, except during emptying or refilling.

The primary seal can either be a metallic shoe seal, a liquid-mounted or a vapor mounted seal.

For tanks with metallic shoe, one end of the metallic shoe is to extend into the stored liquid and the other end is to extend a minimum vertical distance of 61 cm (24 in) above the stored liquid surface.

There are to be no holes, tears, or other openings in the shoe, seal fabric, or seal envelope

The secondary seal type is not specified.

Subpart Kb

The closure device consists of 2-seals, one above the other. The floating roof has to float on the liquid at all times, except during emptying or refilling.

Primary seals may be metallic shoe or liquid mounted. Secondary seals must cover the annular space between the rim and the tank wall in a continuous fashion. Primary and secondary seals need to meet certain gap criteria.

There are to be no holes, tears, or other openings in the shoe, seal fabric, or seal envelope. An external floating roof tank shall be equipped with a primary and secondary seal.

Primary Seal The primary seal fabric shall have no holes, tears or other openings, which would allow the emission of organic vapors.

The primary seal may be liquid-mounted or may be of the metallic shoe type.

Metallic shoe type seals shall be installed so that one end of the shoe extends a minimum vertical distance of 61 cm (24 in.).

For welded tanks, no gap between the tank shell and the primary seal shall exceed 3.8 cm (1-1/2 in.);

No continuous gap greater than 0.32 cm (1/8 in.) shall exceed 10% of the circumference of the tank.

The cumulative length of all primary seal gaps exceeding 1.3 cm (1/2 in.) shall not be more than 10% of the circumference.

The cumulative length of all primary seal gaps exceeding 0.32 cm (1/8 in.) shall not be more than 40% of the circumference.

For riveted

tanks, no gap between the tank shell and the primary seal shall exceed 6.4 cm (2-1/2 in). The cumulative length of all primary seal gaps exceeding 3.8 cm (1-1/2 in.) shall not be more than 10% of the circumference.

Secondary Seals The secondary seal shall allow easy insertion of probes. up to 3.8 cm (1- 1/2 in.) in width in order to measure gaps in the primary seal.Appendix E Final Staff Report

Proposed Rule 1178 E-3 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

External Floating Roof Tank Requirements (Seals/Gap s continued)

PR 1178 R.463 40CFR60 BAAQMD

The shall be no holes, tears or openings in the secondary seal or in the primary seal envelope surrounding the annular vapor space enclosed by the roof edge, seal fabric and the secondary seal. For welded tanks, no gap between the tank shell and the secondary seal shall exceed 1/3 cm (1/2 in.). The cumulative length of all secondary seal gaps exceeding 0.32 cm (1/2 in.) shall not be more than 5% of the circumference of the tank.

For welded

external floating roof tanks with seals installed after 9/4/85, no gap between the tank shell and the secondary seal shall exceed 1.5 mm (0.06 in.). The cumulative length of all secondary seal gaps exceeding 0.5 mm (0.02 in.) shall be no more than 5% of the circumference of the tank, excluding gaps less than 5 cm (1.79 in.) from vertical weld

seams.

For riveted tanks, the secondary seal shall consist of at least two sealing surfaces, such that the sealing surfaces prevent the emission of organic compounds around the rivets. Serrated surfaces are allowed if the length of the serration does not exceed 15.2 cm (6 in.). No gap between the tank shell and the secondary seal shall exceed 1.3 cm (1/2 in.). The cumulative length of all secondary seal gaps exceeding 0.32 cm (1/8 in.) shall be not more than 5% of the circumference.Appendix E Final Staff Report

Proposed Rule 1178 E-4 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

External Floating Roof Tank Requirements (Fittings)

PR 1178 R.463 40CFR60 BAAQMD

Access hatches, gauge float.

wells shall be equipped with covers that are gasketed and bolted, with no visible gaps.

Gauge hatch/sample wells shall be equipped with covers that are gasketed and bolted, with no visible gaps.

Adjustable roof legs wells shall be equipped with gaskets or the legs shall be covered with VOC impervious socks whenever the roof is floating.

Floating roof rim vents and vacuum breakers shall be gasketed and closed at all times except when the tank roof is floated off or landed on its leg supports.

Unslotted guidepoles shall be equipped with gasketed covers at the end of the poles. The covers shall be closed at all times, with no visible gaps, except when sampling.

Unslotted guidepole wells shall be equipped with gasketed sliding covers and flexible fabric sleeves or wipers.

Slotted guidepoles shall be equipped with a gasketed cover, a pole wiper and a pole sleeve that extends into the liquid. All openings in the roof except

Pressure-vacuum valves, shall provide a projection below the liquid surface to prevent belching, escape, or entrainment of organic liquid, and shall be equipped with a cover, seal or lid. The cover, seal, or lid shall at all times be in a closed position, with no visible gaps, except when the device or appurtenance is in use. Except for the pressure vacuum valves, all openings shall meet the following conditions:

The opening shall provide a projection below the liquid surface to prevent belching of liquid and reduce escaping of organic vapors.

The view ports and other openings, except floating roof legs, shall be equipped with a gasketed cover, seal or lid, which shall remain in a closed position at all times, except when the opening is in use. Effective 6/1/93, view ports and other openings, except floating roof legs shall be equipped with a gasketed cover, seal or lid.

For inaccessible openings on internal floating roof tanks, there shall be no visible gaps as viewed from the fixed roof manway, except when the opening is in use.

Pressure-vacuum valves shall be set to within 10% of the maximum allowable working pressure of the roof or at least 25 mm Hg (0.5 psig) and shall be properly installed, maintained, and in good operating order and shall remain in a gas tight condition (10,000 ppm, as methane), above background, except when the operating pressure exceeds the valve set pressure.

Solid sampling and gauge wells shall be equipped with a cover, seal or lid, which shall be in a closed position with no gap exceeding 0.32 cm (1/8 in.) except when in use.Appendix E Final Staff Report

Proposed Rule 1178 E-5 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

External Floating Roof Tank Requirements (Fittings cont'd)

PR 1178 R.463 40CFR60 BAAQMD

Roof drains shall be equipped with a slotted membrane fabric that covers at least 90% of the Opening Roof drains shall be equipped with a slotted membrane fabric that covers at least 90% of the opening Subpart Ka

Roof drains to be equipped with slotted fabric membranes covering at least 90% of the opening.

Subpart Kb

Roof drains to be equipped with slotted fabric membranes covering at least 90% of the opening. As of 6/1/2000, the well on an EFRT shall be equipped with the following: a sliding cover, well gasket, pole sleeve, pole wiper and an internal float and float wiper designed to minimize the gap between the float and the well, provided that the gap shall in no case exceed 1/2 in. or shall be equipped with a well gasket, a zero gap pole wiper seal and a pole sleeve that projects below the liquid surface.

Any emergency roof drain shall be provided with a slotted membrane fabric cover, or equivalent, that covers at least 90% of the area of the opening.Appendix E Final Staff Report

Proposed Rule 1178 E-6 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

Internal Floating Roof Tanks

PR 1178 R.463 40CFR60 BAAQMD

As of 7/1/2002:

-same requirements for roof fittings as external floating roof

tanks.

-support columns and wells shall be equipped with sliding covers that are gasketed or with flexible
fabric sleeves.

As of 7/1/2003, tanks shall be in a vapor tight condition (500 ppm per Method 21). May have a single seal or primary/secondary seals.

Tanks built or modified prior to June 1, 1984
allowed 50%LEL in the vapor space, those built after this date may have only 30% LEL.

All fittings and opening shall be gasketed and

controlled. Subpart Ka Each opening in the cover except for automatic bleeder vents, rim space vents, stub drains and leg sleeves is to be equipped with a cover, seal,
or lid which is to be

maintained in a closed position at all times (i.e., no visible gap) except when the

device is in actual use.

Each opening in the cover except for automatic bleeder vents and the rim space vents is to provide a projection below the liquid surface.

Subpart Kb May have single foam or liquid filled liquid mounted seal, a mechanical shoe seal
or double seal of which the primary may be vapor

mounted.

Each opening in the cover except for automatic bleeder vents, rim space vents, stub drains and leg sleeves is to be equipped with a cover, seal,
or lid which is to be

maintained in a closed position at all times (i.e., no visible gap) except when the
device is in actual use.

Each opening in the cover except for automatic bleeder vents and the rim space vents is to provide a projection below the liquid surface The internal floating roof

shall be either :

(a) A liquid mounted primary seal, mounted in
full contact with the liquid in the annular space b/w the tank shell and the floating roof or

(b) A vapor mounted primary and secondary

seal.

Metallic shoe-type seals

shall be installed so that

one end of the shoe

extends into the stored liquid and the other end

extends a minimum
vertical distance of 18

inches above the stored liquid surface.

For welded external floating roof tanks installed after 2/1/93, no gap b/w the tank shell and secondary seal shall exceed 1.5 mm (0.06 in.).Appendix E Final Staff Report

Proposed Rule 1178 E-7 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

Fixed Roof Tanks

PR 1178 R.463 40CFR60 BAAQMD

Control system shall have 98% efficiency by weight.

Any tank gauging or sampling
device on a tank vented to the vapor recovery system shall be equipped with a vapor-tight cover
which shall be closed at all times except during gauging or sampling.
The roof of such tank shall be properly maintained to be vapor tight (500 ppm), with no holes, tears or uncovered openings.

After July 1, 2004, PVV's on fixed

roof tanks shall be maintained in a vapor tight condition except when tank pressure exceeds recommended settings. The vapor recovery system shall have an efficiency of at least 95 percent by weight



### .

Any tank gauging or sampling device on a tank vented to the vapor recovery system shall be equipped with a vapor-tight cover
which shall be closed at all times except during gauging or sampling. The roof of such tank shall be properly maintained to be vapor tight with no holes, tears or uncovered openings.

All piping, valves and fittings shall be constructedand maintained in a vaportight condition (1,000 ppm),
in accordance with requirements of other

District rules for such equipment. Subpart Ka A vapor recovery system
which collects all VOC vapors and gases discharged from the storage vessel, and a vapor return or disposal system which is designed to process such VOC vapors and gases so as to reduce

their emission to the atmosphere by at least 95 percent by weight



### .

Subpart Kb A closed vent system and control device meeting the following specifications:

(i) The closed vent system shall be designed to collect all VOC vapors and gases discharged from the storage vessel and operated with no

detectable emissions as indicated by an instrument reading of less than 500 ppm above background and visual inspectionsAppendix E Final Staff Report

Proposed Rule 1178 E-8 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

Inspection and Maintenance Requirements

PR 1178 R.463 40CFR60 BAAQMD

Semiannual inspections of primary and secondary seals
and each time the tank is emptied and degassed done by certified person.

All piping, valves, pressurevacuum valves and other openings shall be inspected
on an annual basis and each time the tank is emptied and degassed.

All defects shall be repaired within 72 hours or prior to putting the tank back in
service. Semiannual inspections of primary and secondary seals
and each time the tank is emptied and degassed done by certified person

All defects shall be repaired within 72 hours or prior to putting the tank back in
service Subpart K Records of products stored, period of storage and maximum vapor pressure of the liquid stored.

Subpart Ka Records of products stored, period of storage and maximum vapor pressure of the liquid stored.

Subpart Kb Measurements of gaps
between the tank wall and the primary seal (seal gaps) shall be performed during the hydrostatic testing of the vessel or within 60 days of
the initial fill with VOL and at least once every 5 years

thereafter.

Measurements of gaps
between the tank wall and the secondary seal shall be performed within 60 days of
the initial fill with VOL and at least once per year

thereafter. 

### Primary Seal Inspection

For welded EFRTs with seals
installed after 9/4/85 and

welded IFRTs with seals installed after 2/1/93, the seal shall be inspected for compliance by the operator once every 10 years.

After 12/1/93, once every 10 years, for IFRTs.

Once every 5 years for all

other tanks.



### Secondary Seal Inspection

For welded EFRTs with seals

installed after 9/4/85 and

welded IFRTs with seals installed after 2/1/93, the seal shall be inspected for compliance by the operator once every 10 years.

After 12/1/93, once every 10 years, for IFRTs.

Annually for all other tanks.

The primary and secondary

seals of all IFRTs shall be visually inspected for holes, tears, or other openings in the
seal fabric which allow the emission of organic vapors.Appendix E Final Staff Report

Proposed Rule 1178 E-9 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

Record Keeping and Reporting

PR 1178 R.463 40CFR60 BAAQMD

Inspection reports filled out on District approved forms and
mailed to the District within 5 working days or 120 hours if
violations are found.

Records to be kept for 5 years Inspection reports filled out on District approved forms and
mailed to the District within 5 working days or 120 hours if
violations are found.

Records to be kept for 3 years Subpart Kb
Inspection reports of floating

roof tanks submitted within 30 days.

For fixed roof tanks vented to
vapor recovery a report an operating plan shall be kept, indicating the parameter

monitored.

For fixed roofs vented to a flare or incinerator a report shall be submitted indicating any period of pilot flame out
within 6 months of initial start-up and on a semi-annual

basis thereafter

Records to be kept for a minimum of 2 years. An accurate record of liquids stored and their
true vapor pressure ranges of such liquids

shall be maintained.

For primary seals, certification of actual gap

measurements shall be submitted upon

installation of such primary seal, replacement of such seal or prior to installation of secondary seals, and at least every 5 years following such

installation or replacement, unless the secondary seal is for:

An Internal Floating Roof Tank (IFRT) or a welded floating roof tank installed after 9/4/85 (for External Floating Roof Tanks - EFRTs) and after 2/1/93 (for IFRTs), respectively. Then it shall be done every 10

years.

For secondary seals,

EFRT - Annual certification of gap

measurement. Time
interval between

certification not to
exceed 15 months.

IFRT - At least once every 10 years.Appendix E Final Staff Report

Proposed Rule 1178 E-10 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

Test Methods

PR 1178 R.463 40CFR60 BAAQMD

For VOC leaks EPA Method 21

Efficiency of a vapor recovery system shall be determined according to EPA Methods 25 or 25A; District Method 25.1 or 25.3.

Vapor pressure determination of liquids stored determined byflash point (ASTM Method D93) and 10% evaporation (ASTM Method D86). For VOC leaks EPA Method 21.

Efficiency of a vapor recovery system shall be determined according to SCAQMD Test Method 501.1 for the determination of total organic compound emissions. EPA Methods 25 or 25A may be used, as applicable, in place of SCAQMD Test Method 25.1 specified in Method 501.1.

The Reid vapor pressure specified in paragraph (b)(3) and the Reid vapor pressure used in determining the true vapor pressure limit specified in paragraph (d)(5) shall be determined according to ASTM D-323-82 or California Code of Regulations, Title 13, Section 2297 Subpart Ka The true vapor pressure of materials stored is determined using available data on typical Reid Vapor Pressure from API Bulletin 2517 and maximum expected storage temperature

Subpart Kb Vapor Pressure of crude and distillates is determined from nomographs in API Bulletin 2517 or ASTM Method D2879-83 or is calculated or measured by an equivalent method. For VOC leaks: EPA Method 21.

RVP: Manual of Procedures; Vol. III, Lab. Method 13

Analysis of Samples, Total Vapor Pressure: Vol. IV, Lab. Method 28

Determination of Emissions:

Manual of Procedures,

Vol. IV, ST-4

Vol. IV, ST-7Appendix E Final Staff Report

Proposed Rule 1178 E-11 December 11, 2001 

### Comparison of PR 1178 with Rule 463 and 40CFR60 K, Ka and Kb and BAAQMD Regulation 8, Rule 5

Rule Exemptions

PR 1178 R.463 40CFR60 BAAQMD

1. Pressurized storage tanks designed to operate in excess of 15 psig without any emissions to the atmosphere under emergency conditions.

2. Domed external floating roof tanks installed prior to 1/1/02 shall be exempt from rim seal system and other doming requirements outlined in this rule.

3. Facilities with an emissions cap equal to or less than 40,000 pounds (20 tons) per year of VOC shall be exempt from the requirements of the rule.

4. External floating roof tanks with permit conditions limiting the true vapor pressure of the stored organic liquids in the tanks to 3 psia or lower shall be exempt from the doming requirements of the rule.

5. Portable Baker tanks storing liquids with true vapor pressure of between 0.1 and 0.5 psia and equipped with carbon canisters meeting the 50 ppmv outlet concentration shall be exempt from performance testing, provided the operator conducts periodic EPA Method 21 measurement to ensure the 50 ppmv system standard is maintained. Oil production tanks with a capacity of between 19,815 gallons and 42,008 gallons, which have a properly maintained vapor-tight roof and are equipped with a pressure-vacuum valve, which is set to within 10% of the maximum allowable working pressure of the tank, are exempt from the control requirements of the rule when:

1. The liquid contents do not comply with paragraph (b) only when heated for shipment, and such heating occurs for no more than 48 hrs. and not more than once in any 20-day period or the tank has a monthly average throughput of no more than 30 barrels of oil per day and was constructed prior to 6/1/84.

2. Tanks being brought into compliance within the 72-hr period from the determination of non-compliance. Subpart K Storage vessels for petroleum or condensate stored, processed, and/or treated at a drilling and production facility prior to custody transfer.

Subpart Ka Petroleum liquid storage vessels with a capacity of less than 420,000 gallons used for petroleum or condensate stored, processed, or treated prior to custody transfer is exempt from the requirements of this subpart.

Subpart Kb 1. Vessels at coke oven byproduct plants

2. Pressure vessels designed to operate in excess of 204.9 kPa and without emissions to the atmosphere.

3. Vessels permanently attached to mobile vehicles such as trucks, railcars, barges or ships.

4. Vessels with a design capacity less than or equal to 1589.874 cubic meters (420,045 gallons) used for petroleum or condensate stored, processed, or treated prior to custody transfer.

5. Vessels located at bulk storage plants.

6. Storage vessels located at gasoline service stations.

7. Vessels used to store beverage alcohol 1. Underground gasoline storage tanks at gasoline dispensing facilities are exempt from this rule.

2. The rule does not apply to tanks storing organic liquids with a true vapor pressure of less than or equal to 0.5 psia as determined by the test methods outlined in the rule.