P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

$ JW U-B-13 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 19 of 132 
MEMORANDUM 

/-^S-13 

3C-B-1 3 

TO: Martha Smith OAQPS/ESD/WCPG 

FROM: Bernd Haneke and Greg LaFlam, PES, Inc. 

DATE: October 28,1999 

SUBJECT: Equipment Leak Rules for SIC 42 in OLD Data base 

Purpose 

At the October 5,1999 EPA Roundtable Meeting, GATX Terminals Corporation 

requested that the EPA analyze its data base to determine the predominant equipment leak 

standards in use at for-hire terminals. Usha Mehra, representing GATX, stated that it was her 

understanding that most for-hire terminals are only subject to sight, sound, and smell equipment 

leak detection methods. PES has analyzed the information submitted by for-hire terminals and 

is hereby providing the results and conclusions of this analysis. 

Results 

The OLD non-confidential data base was queried for all Standard Industry Code (SIC) 

code 4226 facilities that reported equipment leak rules in support of their leak detection and 

repair (LDAR) programs. It is believed that the majority of for-hire terminals fall under this SIC 

code. The data base contains information on 18 facilities, providing a variety of State and 

Federal rules and regulations (see Table 1). Some facilities reported multiple equipment leak 

regulations. 

Based on this analysis, approximately 66 percent ofthe facilities are currently monitoring 

their equipment using an instrument-based approach. Various facilities also reported that they 

use a combination of sight, sound, and smell and instrument monitoring. 

Conclusion 

The results of this analysis indicate that while sight, sound, and smell is used at for-hire 

terminals, it does not appear to be the predominant method for identifying equipment leaks at 

these facilities. 

/ 
P.3 

Memo on Equipment Leak Rules 

October 28,1999 

Page 2 

Table 1. Summary of Equipment Leak Rules Reported by For-Hire Terminals 

Rule/Regulation Rule Name Instrument or 

sight, sound, 

smell 

. Number of 

Occurrences1 

Federal Equipment Standards/Rules 

40 CFR 63 subpart R 

40 CFR 61 subpart V 

40 CFR 61 subpart J 

40 CFR 60 subpart XX 

Gasoline Distribution NESHAP 

Equipment Leaks (Fugitive Emission 

Sources) NESHAP 

Equipment Leaks of Benzene 

NSPS for Bulk Gasoline Facilities 

Sight, sound, 

smell 

Instrument 

Instrument 

Sight, sound, 

smell 

6 

5 

3 

1 

State Equipment Standards/Rules 

TNRCC 30 TAC Chapter 

115 

SCAQMD Rule 1173 

LAC 33 III 51 Section 5171 

(has been repealed, see 

Section 2122) 

NJDEP, Title 7, Chapt. 27 

Subchapter 16 

Control of Air Pollution from Volatile 

Organic Compounds, Transfer Operations 

South Coast Air Quality Management 

District, Fugitive Emissions of VOC 

Louisiana Air Code Regulations, Control 

of Emission of Organic Compounds 

Control and Prohibition of Air Pollution by 

VOC 

Instrument, 

sight, sound, 

smell 

Sight, sound, 

smell 

Instrument 

Instrument 

6 

2 

1 

1 

' 

"Although there were only 18 facilities that reported information, some facilities reported more than one applicable 

rule. Some facilities also reported incomplete information regarding their equipment leak rules.