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Title: Determining the PTE and formulating a Title V permitting strategy for a bulk gasoline terminal

Abstract

Bulk gasoline terminals may take operational restrictions and maintain operational flexibility while avoiding requirements of Title III and Title V of the Clean Air Act Amendments (CAA-A). Title V establishes a federally enforceable renewable operating permit program for major sources. Title III regulates Hazardous Air Pollutants (HAPs) to reduce emissions from all sources to a degree sufficient to protect the public by using Maximum Achievable Control Technology (MACT) standards achieved in practice within the industry. Volatile Organic Compounds (VOCs) and HAPs are emitted from storage tanks, loading operations, and components at gasoline terminals. To calculate the potential to emit (PTE) and assess regulation applicability, maximum facility throughputs should be determined by physical limitations of the loadrack. Loadrack throughputs can be correlated to storage tanks throughputs based on type of tank and the highest volatility product stored in that tank. Component emissions should be based on continuous service of the highest volatility product. To avoid recordkeeping and reporting requirements of Title III and/or Title V, VOC and HAP emissions may be restricted to below thresholds determined by the region`s ozone attainment status by limiting loadrack throughput and/or by meeting higher control equipment efficiencies. However, careful consideration must be given to operationalmore » flexibility and the potential future expansion of the facility.« less

Authors:
;  [1]
  1. TRC Environmental Corporation, Windsor, CT (United States)
Publication Date:
OSTI Identifier:
617931
Report Number(s):
CONF-9609223-
TRN: 98:002008-0017
Resource Type:
Conference
Resource Relation:
Conference: Conference on emission inventory: key to planning, permits, compliance and reporting, New Orleans, LA (United States), 4-6 Sep 1996; Other Information: PBD: 1996; Related Information: Is Part Of The emission inventory: Key to planning, permits, compliance, and reporting; PB: 1047 p.
Country of Publication:
United States
Language:
English
Subject:
02 PETROLEUM; POLLUTION CONTROL EQUIPMENT; GASOLINE; ORGANIC COMPOUNDS; OZONE; REPORTING REQUIREMENTS; STANDARDS; VOLATILITY; AIR POLLUTION; LICENSES

Citation Formats

Wilder, A.A., and Turner, R.S. Determining the PTE and formulating a Title V permitting strategy for a bulk gasoline terminal. United States: N. p., 1996. Web.
Wilder, A.A., & Turner, R.S. Determining the PTE and formulating a Title V permitting strategy for a bulk gasoline terminal. United States.
Wilder, A.A., and Turner, R.S. Tue . "Determining the PTE and formulating a Title V permitting strategy for a bulk gasoline terminal". United States. doi:.
@article{osti_617931,
title = {Determining the PTE and formulating a Title V permitting strategy for a bulk gasoline terminal},
author = {Wilder, A.A. and Turner, R.S.},
abstractNote = {Bulk gasoline terminals may take operational restrictions and maintain operational flexibility while avoiding requirements of Title III and Title V of the Clean Air Act Amendments (CAA-A). Title V establishes a federally enforceable renewable operating permit program for major sources. Title III regulates Hazardous Air Pollutants (HAPs) to reduce emissions from all sources to a degree sufficient to protect the public by using Maximum Achievable Control Technology (MACT) standards achieved in practice within the industry. Volatile Organic Compounds (VOCs) and HAPs are emitted from storage tanks, loading operations, and components at gasoline terminals. To calculate the potential to emit (PTE) and assess regulation applicability, maximum facility throughputs should be determined by physical limitations of the loadrack. Loadrack throughputs can be correlated to storage tanks throughputs based on type of tank and the highest volatility product stored in that tank. Component emissions should be based on continuous service of the highest volatility product. To avoid recordkeeping and reporting requirements of Title III and/or Title V, VOC and HAP emissions may be restricted to below thresholds determined by the region`s ozone attainment status by limiting loadrack throughput and/or by meeting higher control equipment efficiencies. However, careful consideration must be given to operational flexibility and the potential future expansion of the facility.},
doi = {},
journal = {},
number = ,
volume = ,
place = {United States},
year = {Tue Dec 31 00:00:00 EST 1996},
month = {Tue Dec 31 00:00:00 EST 1996}
}

Conference:
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  • Now that some state regulatory agencies are reviewing Title V permit applications and issuing permits, evaluation of the process can be made in comparison with the original goals of the Title V permitting program. In addition, assessment of the terms and conditions that are being incorporated into permits, the nature of draft permits that are issued to facilities for comment, and the extent and type of negotiation that have been conducted with agencies to develop successful Title V permits, will be helpful for facilities that are currently undergoing application review. In working with a Fortune 500 surface coating company, fourteenmore » Title V permit applications were developed and submitted for plants located in Maryland, Pennsylvania, Ohio, New Jersey, Illinois, Georgia, West Virginia, Wisconsin, Indiana and southern California. Draft permits have been issued for several of the plants, and differences in the terms and conditions, testing requirements, and permit format and structure have been noted between states. One of the issued permits required modification, and the process was one of the first for this state agency.« less
  • The Clean Air Act of 1990 (CAA) mandated that all facilities classified as major were to obtain a Federal Title V operating permit. In addition, any facility, either major or minor, which emits certain chemicals or compounds above a specific single quantity limit or a total aggregate limit are subject to Title III requirements and are required to obtain a Title V permit as well. The problem with obtaining a Title V permit for Title III substances is there is limited data, at least for the utilities sources, on emission factors and emission rates for many of the Title IIImore » listed chemical compounds. In addition, the emission data that exists is very conservative, and if used, would show the facilities to be significant emitters of hazardous air emissions, while actual emissions are significantly less. This could lead a facility to applying for a Title V permit unnecessarily, a time consuming process at best. In Iowa, facilities submitted the first Title V permit applications in 1994. The Iowa Department of Natural Resources is currently in the process of reviewing the submittals prior to issuing operating permits. Title III has not been addressed at all in the submittals and therefore will not be included in this round of finished permits that are to be issued. The outcome of this is that the Title V permits will have to be opened and amended to include the applicable Title III operating conditions and constraints. This paper will examine the areas where Title III and Title V collide and the potential permitting and enforcement issues that will have to be faced by the facilities that operate under these permits. This paper is based on the opinions of two of the three responsible parties (facilities and consultants) that are dealing with the potential permitting and enforcement wreckage before the collision occurs.« less
  • The status of the Clean Air Act Operating Permits Program as of March 2, 1995 is outlined. By November 15, 1993, operating permits programs were to have been submitted by all states and territories consistent with the Federal Operating Permits Program regulations. Submittals were required from 56 states, including the District of Columbia and Territories. In many cases, local programs are responsible for developing and implementing the operating permits programs for their areas of jurisdiction. Steps in the approval process are listed. Under the Clean Air Act, EPA is to implement sanctions by May 15, 1995 in those situations wheremore » a complete operating permit program has not been submitted for EPA review.« less
  • Pursuant to the passage of the Clean Air Act Amendments of 1990, the US Environmental Protection Agency has promulgated what are known as Title V permitting requirements for major sources of air pollutants, including pipeline operations. In contrast to most existing air permitting programs, the new Title V regulations will require periodic certification of compliance with applicable air regulations. In the same way that water dischargers report their own discharge violations to regulatory agencies pursuant to the NPDES permitting system, Title V permittees must implement an acceptable monitoring program and similarly report violations of permit conditions or applicable air regulations.more » Only those facilities whose potential emissions are less than or can be controlled to be less than certain regulatory limits will be exempt from standard Title V permitting. If a facility`s throughput or the concentration levels of certain volatile toxic levels in a particular crude or natural gas were to exceed corresponding regulatory limits, then the facility could be in violation. If an operator were to expand a field, then the changes in the gathering system and emission levels could constitute a violation. Constraints on operations can be avoided by careful strategizing of an operator`s Title V permit application.« less
  • In the 1990 amendments to the Federal Clean Air Act, Congress required facilities that met certain requirements to apply for a permit to operate all air pollutant-emitting sources at the facility. This program has become known as Title V, or the Federal Operating Permit program. This presentation will focus on an option that could be pursued by any facility to meet the qualifications that would exempt it from having to make an application for a federal operating permit by qualifying as what has become known as a ``synthetic minor`` source.