p.1 

OAR Box 1706 

Prepped by Ollie Stewart 

Document Number: 

5) IV-C-2 

Docket Number: 

A-98-13 

Printed 10/8/2008 10:25:07 AM Sheet 5 of 142 
P.2 

Meardon, Kenneth 

MM3 

From: 

Sent: 

To: 

Cc: 

Subject: 

Meardon, Kenneth 

Thursday, May 29, 2003 4:45 PM 

'ritterk@api.org' 

hustvedt.ken@epamail.epa.gov; smith.martha@epamail.epa.gov 

Information on OLD 

May 29, 2003 

Ms. Ritter: 

Attached are files that the US EPA asked me to forward to you concerning the Organic Liquids Distribution NESHAP. The 

files reflect current EPA staff level thinking on what the final rule might look like. 

If you have any questions concerning the attached files, please contact either Martha Smith or K.C. Hustvedt at EPA. 

Kenneth R. Meardon 

Pacific Environmental Services, Inc. 

919-941-0333 

krmeardon@mactec.com 

transfer racks - DLD tanks summary OLD public 

5-21.wpd (16... 052203.wpd (... /erview.wpd (12 KB 

I 

• 8 vr.3 

EPA AIR DOCKET 
Table 1. Tliroughput and HAP Content Ranges- Transfer Racks (May 21, 2003) 

Transfer 

Operation 

Annual 

Throughput 

(gallons) 

<800,000 

800,000 to 

7million 

> 7 million 

< 1 % HAP 

Controlled 

0 

0 

3 

Total 

0 

2 

6 

1 to <5% HAP 

Controlled 

0 

1 

4 

Total 

2 

4 

5 

5 to <25% HAP 

Controlled 

2 

2 

6 

Total 

5 

8 

13 

25 to <50% HAP 

Controlled 

1 

0 

2 

Total 

1 

3 

4 

50 to <75% HAP 

Controlled 

0 

1 

4 

Total 

0 

1 

4 

75 to <98% HAP 

Controlled 

0 

0 

5 

Total 

3 

5 

7 

>98% 

Controlled 

1 

8 

29 

Total 

4 

28 

39 

5^ 

This analysis excludes liquids with total vapor pressures less than 0.1 psia and with HAP contents less than 0.1 wt %. Some liquids are 

excluded based on the total vapor pressure exclusion, but none on the HAP content exclusion (i.e., all are above 0.1 wt %). 
P.4 

STORAGE TANKS PROMULGATION FLOOR ANALYSIS 

May 21, 2003 

Capacity 

(gallons) 

<5,000 

5,000 to <10,000 

10,000 to <20,000 

20,000 to <40,000 

>40,000 

Vapor Pressure Range 

(partial pressure of HAP) 

all 

<0.1 

0.1 to<4.0 

>4.0 

<0.1 

0.1 to<4.0 

>4.0 

<0.1 

0.1 to<1.9 

1.9 to <4.0 

>4.0 

<0.1 

0.1 to<0.75 

0.75 to <1.9 

1.9 to <4.0 

>4.0 

Counts 

Controlled 

0 

0 

2 

1 

0 

2 

1 

1 

1 

0 

2 

93 

158 

46 

112 

15 

Total 

31 

18 

19 

2 

10 

26 

2 

13 

16 

7 

2 

188 

199 

76 

116 

19 

' •? 
OLD MACT Staff Recommendations 

May 21, 2003 

^ = 

TOPIC PROPOSAL DRAFT FINAL RULE 

Facility applicability 

Organic liquid 

throughput cutoff 

Facilities with less than 7.29 million gallons of Organic 

Liquids exempt 

No facility-wide throughput cutoff 

Definition of Organic Liquid 

List of organic HAP 

in Table 1 of rule 

Organic Liquid 

definition 

"Black Oil" 

Exemption for 

Crude Oil 

Listed 69 HAP 

Liquids containing 5 or more weight percent ofthe 

Table 1 HAP 

Exempted Black Oil, which is crude oil less than an 

API gravity (40°) and gas to oil ratio (31 ftVgal) cutoffs 

as defined in the Oil and Gas MACT 

List all 98 HAP identified in the OLD survey (with individual 

glycol ethers identified) 

Liquids containing 0.1 or more weight percent of the Table 1 

HAP and with total organic vapor pressures greater than 0.1 psi. 

Considering approaches to justify raising the weight percent 

HAP cutoff to 1 to 5 percent 

Black Oil definition is deleted. Crude oil is subject to the same 

requirements as other organic liquids 

Emission Point Standards 

Emission points 

subject to other 

MACT standards 

Storage tanks 

Transfer Racks 

Not clear. Excluded either emission points subject to or 

controlled by another MACT 

Tanks subject to control based on the HON vapor 

pressure and size cutoffs and on total vapor pressure of 

stored liquid 

Loading positions with annual organic liquid transfers 

of 3.12 million gallons or more subject to 95 percent 

control requirement 

Emission points subject to another MACT standard would be 

excluded 

Tanks subject to control based on size and partial pressure ofthe 

HAP. Values determined by OLD database and beyond floor 

considerations 

Loading racks subject to control based on facility rack 

throughput and HAP content. Values determined by the OLD 

database and beyond floor considerations. Affected racks 

subject to 98 percent emission reduction requirement. 
TOPIC 

Equipment Leaks 

Containers 

Wastewater 

PROPOSAL 

Reference existing MACT standards to apply to 

equipment with 5 percent or greater Table 1 HAP 

No additional requirements 

No additional requirements 

DRAFT FINAL RULE 

No change 

Existing - no change 

New - control large containers 

No change 

VJ\ 

TJ