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OAR Box 1672 

Prepped by Charmelle Mathews 

Document, Number: 

Docket Number: 

-B-4 

A-98-13 

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

MEMORANDUM 

TO: Steve Shedd 

U.S. EPA/OAQPS/ESD/WCPG - -

FROM: GregLaFlam J^ :' 

Pacific Environmental Services, Inc. (PES) c -

DATE: August 13, 1998 ~~ 

P:\N819 

SUBJECT: P-MACT Existing Source Control Levels Weighting 

This memorandum presents additional rationale for the current control levels summarized in Section 5 ofthe document, "Presumptive MACT for Organic Liquids (non-Gasoline) 

Distribution Facilities," June 9,1998. As stated in that document, the P-MACT determinations were derived from a comprehensive review ofthe current Federal, State, and local 

regulations applicable to emission sources found in the organic liquids distribution (OLD) 

industry. Table 1 summarizes the P-MACT levels from the June 9th document. 

The P-MACT control levels for existing sources were determined using a two-step 

process. The first step was to obtain copies of rules from individual States and regulated 

local districts for the emission sources of concern and group the similar rules together in 

terms of stringency. As an example of this grouping, the requirements affecting storage 

vessels were placed into groups of similar tank size and liquid vapor pressure cutoff. The 

second step was to use the gathered information to try to determine what the current 

practices are for the best controlled 6 to 12 percent of the industry. To make this determination, the Independent Liquid Terminals Association (ILTA) membership directory was 

consulted to determine the national distribution of HAP liquid terminals by State. The 

Petroleum Supply Americas (PSA) and Petroleum Terminal Encyclopedia (PTE) were used 

to determine the national distribution of pipeline facilities by State. 

Some of the identified regulations cover only a specific region or urban area within a 

particular State. In such cases, the percentage value derived for the State by using the ILTA 

directory or the PSA and PTE was adjusted to estimate the percentage of industry covered by 

the specific regulation or regulations. In cases where the percentage has been estimated in 

such a manner, it is noted within this memo by the use of parentheses to show the original 

statewide figure as well as the estimated percentage for the regulated area. 

The following information is a description, by emission source, ofthe rationale for the 

P-MACT existing source control levels for the Organic Liquids Distribution NESHAP. 
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Memo to Steve Shedd 

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TABLE 1. SUMMARY OF P-MACT DETERMINATIONS FOR 

ORGANIC LIQUIDS DISTRIBUTION SOURCES 

BASED ON FEDERAL, STATE, AND LOCAL AIR POLLUTION RULES 

Emission Source 

P-MACT 

New Sources Existing Sources 

I. STORAGE VESSELS 

A. Fixed Roof Tanks, 

low vapor pressure liquids 

B. Fixed Roof Tanks, high vapor 

pressure liquids 

C. Top Loaded Tanks 

D. External Floating Roof Tanks 

(General) 

E. External Floating Roof Tanks 

(Welded) 

> 10k gallons and > 1.9 psia, or 

> 20k gallons and > 1.5 psia, or 

> 40k gallons and > 0.15 psia: 

Floating roof, or closed vent system controlled at 95% by weight; 

> 11 psia: 

Pressure tank with no detectable 

emissions (NDE) or 95 % control 

by weight. No floating roofs. 

<40k gallons and > 0.5 psia: 

Install a permanent submerged fill 

pipe or perform bottom loading. 

> 10k gallons and > 1.9 psia, or 

> 20k gallons and > 1.5 psia, or 

> 40k gallons and > 0.15 psia: 

Specified roof seal and fittings 

requirements (see Section 5.1.2.1). 

> 20k gallons and > 1.5 psia, ox 

> 40k gallons and > 0.5 psia: 

Floating roof, or closed vent system 

controlled at 95% by weight. 

>25k gallons and > 11 psia: 

Pressure tank with NDE, or 95% control by weight. No floating roofs. 

> 580 gallons - 40k gallons and >1.5 

psia: 

Install a permanent submerged fill 

pipe or perform bottom loading. 

20k-40k gallons and > 1.5 psia, or 

> 40k gallons and > 0.5 psia: 

Specified roof seal and fittings requirements (see Section 5.1.2.1). 

Tanks of welded construction and < 4 psia: 

No secondary seal required if specified primary seals in use (see Section 

5.1.2.2). 

II. LIQUID TRANSFER 

A. Loading Racks, > 20k gallons 

loaded per day at entire facility 

averaged over a rolling thirty-day 

period 

> 0.5 psia: 10 mg/liter emission 

limit; 

>1.5psia: 10 mg/liter emission 

limit or 98% emission reduction. 

>0.5 psia: 90% emission reduction. 

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TABLE 1 (Concluded) 

Emission Source 

P-MACT 

New Sources Existing Sources 

II. LIQUID TRANSFER (Cont) 

B. Cargo Tank Leakage DOT test or EPA Method 27." DOT test, possibly EPA Method 27." 

UI. EQUIPMENT LEAKS 

Pumps, Valves, and Flanges Detailed industry leak check practice data needed to make a determination; see Section 5.1.5. 

IV. WASTEWATER TREATMENT AND CONTROL 

A. Wastewater Storage Tanks 

B. Individual Drain Systems 

C. Oil-Water Separators 

>20k: Fixed roof required 

>20k and >1.9 psia or 

>40k and >0.75 psia: 

Fixed roof and 95% control by 

weight. 

Vapor suppression on individual 

drain system openings. 

Fixed roof and 95% control by 

weight or a floating roof. 

Detailed industry wastewater treatment technology data needed to make 

a determination; see Section 5.1.4. 

V. BLENDING 

Blending Operations Detailed industry data required to make a determination; see Section 5.1.6. 

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 Further industry information is needed in order to determine prevalence of cargo tank testing and the relative 

stringency of DOT tests and the EPA's Method 27 (vapor tightness) testing. 

1.1 Fixed Roof Storage Tanks 

Low Vapor Pressure Liquids 

The P-MACT determination for existing low vapor pressure storage tanks was 

developed from the regulations ofthe following States, which affect approximately 12 percent 

ofthe OLD source category. The existing source P-MACT was derived from several 

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California rules including the South Coast, Bay Area, Ventura, San Joaquin, El Dorado, Kern, 

Placer, and Santa Barbara Districts, along with the Chicago area and Colorado regulations. 

According to the ILTA directory, California represents 9.6 percent ofthe total ILTA 

membership facility tankage. The California rules do not represent the entire State; however, 

the rules for these heavily populated regions are assumed to affect 9 (out of a possible 9.6) 

percent of all the facilities. Illinois represents 8.3 percent ofthe industry. The Chicago area is 

assumed to represent one-third of Illinois, which is 2.8 percent. Colorado represents 0.3 

percent ofthe industry. The total of these areas, therefore, represents about 12.1 percent ofthe 

industry. 

Using a similar approach, approximately 10.5 percent ofthe pipeline facilities industry 

is affected by these regulations, as follows: 

1. California - 6.5 (of 7) percent, 

2. Illinois-Chicago - 3 percent, and 

3. Colorado -1 percent. 

High Vapor Pressure Liquids 

The high vapor pressure liquid storage existing source control levels were derived from 

California's Ventura, El Dorado, Bay Area, Placer, and Santa Barbara area rules, along with 

the Colorado and Texas regulations. From the ILTA directory, these rules affect approximately 20 percent ofthe independent terminals industry. The percentages are as follows: 

1. California - 4 (of 9.6) percent, 

2. Colorado - 0.3 percent, and 

3. Texas -16 percent. 

From the ILTA directory, these rules affect approximately 12 percent ofthe pipeline 

facilities in the country. The percentages are as follows: 

1. California - 2.4 (of 7.0) percent, 

2. Colorado -1 percent, and 

3. Texas - 9.1 percent. 

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Top Loaded Storage Tanks 

The top loaded storage tank existing source control levels were derived from California's Bay Area, Placer, and San Diego area rules along with the Oklahoma, Kentucky, 

Louisiana, and Illinois-Ozone Federal (40 CFR 52.741, subpart 0) regulations. From the 

ILTA directory, these rules affect approximately 15 percent ofthe independent terminals 

industry. The percentages are as follows: 

1. California - 4.5 (of 9.6) percent, 

2. Louisiana - 6.9 percent, 

3. Oklahoma - 0.6 percent, 

4. Kentucky - 0.8 percent, and 

5. Illinois (Federal) - 2.8 percent. 

From the ILTA directory, these rules affect approximately 10 percent ofthe pipeline 

facilities in the country. The percentages are as follows: 

1. California - 3.5 (of 9.6) percent, 

2. Louisiana-1.7 percent, 

3. Oklahoma-1.9percent, 

4. Kentucky - 0.9 percent, and 

5. Illinois (Federal) - 2.0 percent. 

1.2 External Floating Roof Tanks 

The P-MACT tank size and vapor pressure cutoff control levels for general external 

roof tanks are derived from the same regulations as the low vapor pressure storage tank 

requirements. 

EFRT. Welded Construction 

The secondary seal exemption for existing external floating roof tanks of welded 

construction is found in the Control Techniques Guidelines (CTG) for the Storage of Petroleum Liquids in External Floating Roof tanks, and is reflected in the Indiana, South Carolina, 

Washington, Maryland, Louisiana, and Texas regulations. Using the ILTA directory, these 

rules affect approximately 28 percent ofthe independent terminals industry. The percentages 

are as follows: 

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1. Indiana - 2.3 percent, 

2. Louisiana - 6.9 percent, 

3. South Carolina - 0.8 percent, 

4. Washington-1.0percent, 

5. Maryland -1.6 percent, and 

6. Texas -16 percent. 

From the ILTA directory, these rules affect approximately 19 percent ofthe pipeline 

facilities in the country. The percentages are as follows: 

1. Indiana-3.5 percent, 

2. Louisiana-1.7 percent, 

3. South Carolina - 2.0 percent, 

4. Washington-1.4percent, 

5. Maryland -1.3 percent, and 

6. Texas - 9.1 percent. 

1.3 Liquid Transfer Operations (Loading Racks) 

The existing source control levels for liquid transfer operations are developed from the 

California and Texas regulations. Using the ILTA directory, these rules affect approximately 

23 percent ofthe independent terminals industry. The percentages and control levels are listed 

below: 

1. Texas (>0.5 psia, >20k/day: 90% control) -16 percent, and 

2. California-7.5 (of 9.6) percent 

Bay Area 

South Coast 

San Joaquin 

Kern County 

Ventura County 

Mojave 

El Dorado 

(>0.5 psia, >6 million gal: 21 mg/L) 

(>1.5 psia, >20k gal/day: 10 mg/L) 

(>4k gal/day: 90%) 

(>1.5 psia, >20k gal/day: 10 mg/L) 

(>1.5 psia, >4k gal/day: 95%) 

(>1.5 psia, >20k gal/day: 10 mg/L) 

(>1.5 psia, >4k gal/day: 95%) 

(>1.5 psia, >20k gal/day: 90%) 

(>0.5psia, > 150k gal/year: 90%) 

(>1.5 psia, >5 million gal/year: 95%) 

(>1.5 psia, >5 million gal/year: 10 mg/L). 

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From the ILTA directory, these rules affect approximately 15 percent ofthe pipeline 

facilities in the country. The percentages are as follows: 

1. Texas - 9.1 percent, and 

2. California - 6.5 (of 7.0) percent. 

1.4 Other Sources 

Detailed industry information is needed in order to determine control levels for cargo 

tank leakage, wastewater operations, and blending operations. Few State regulations are 

known to regulate these particular emission sources as they apply to the OLD industry. 

Responses to the industry survey sent out by the EPA in April 1998 are expected to provide 

useful information for making MACT floor determinations for the range of HAP emission 

sources in this industry. 

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