EPA-450/2-77-035
December 1977
(OAQPS No, 1.2-085)
GUIDELINE SERIES
CONTROL OF VOLATILE
ORGANIC EMISSIONS
FROM BULK
GASOLINE PLANTS
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/2-77-035
(OAQPS No. 1.2-085)
CONTROL OF VOLATILE
ORGANIC EMISSIONS
FROM
BULK GASOLINE PLANTS
Emissions Standards and Engineering Division
Chemical and Petroleum Branch
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1977
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OAQPS GUIDELINE SERIES
The guideline series of reports is being issued by the Office of Air Quality
Planning and Standards (OAQPS) to provide information to state and local
air pollution control agencies; for example, to provide guidance on the
acquisition and processing of air quality data and on the planning and
analysis requisite for the maintenance of air quality. Reports published in
this series will be available - as supplies permit - from the Library Services
Office (MD-35) , U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina 27711; or, for a nominal fee, from the National
Technical Information Service, 5285 Port Royal Road, Springfield, Virginia
22161.
Publication No. EPA-450/2-77-035
(OAQPS No. 1.2-085)
u
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TABLE OF CONTENTS
Page
Chapter 1.0 Introduction and Summary 1-1
1.1 Need to Regulate Bulk Plants 1-2
1.2 Sources and Controls of Volatile Organic Compounds
From Bulk Plants 1-2
1.3 Regulatory Approach 1-3
Chapter 2.0 Source and Types of Emissions 2-1
2.1 Industry Description •. 2-1
2.2 Bulk Plant Facilities and Emissions 2-1
•
2.3 Summary 2-8
2.4 References 2-11
Chapter 3.0 Emission Control Techniques 3-1
3.1 Types of Control Techniques 3-1
3.2 Control Alternatives 3-4
3.3 Summary 3-5
3.4 References 3-8
Chapter 4.0 Cost Analysis .- 4-1
4.1 Introduction 4-1
4.2 Control of Emissions 4-4
4.3 References 4-11
Chapter 5.0 Effects of Applying the Technology 5-1
5.1 Impact of Control Techniques on Hydrocarbon Emissions ... 5-1
iii
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Page
5.2 Other Impacts 5-2
Chapter 6.0 Enforcement Aspects 6-1
6.1 Affected Facility 6-1
6.2 Standard Format 6-1
6.3 Determining Compliance 6-3
iv
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LIST OF TABLES
Page
Table 2-1 Uncontrolled VOC Emissions From a Small Bulk Plant 2-10
Table 3-1 Air Pollution Impacts of Control Alternatives on
Typical Plant 3-7
Tab!e 4-1 Parameters of Model PI ants 4-3
Table 4-2 Cost Estimates 4-6
Table 4-3 Colorado Bulk Plant Costs 4-10
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LIST OF FIGURES
Page
Figure 2-1 Gasoline Tank Truck Loading Methods 2-6
Figure 3-1 Vapor Balance System 3-3
Figure 3-2 Typical Bulk Gasoline Plant Configurations 3-6
Figure 4-1 Cost Effectiveness 4-8
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ABBREVIATIONS AND CONVERSION FACTORS
EPA policy is to express all measurements in agency documents
in metric units. Listed below are abbreviations and conversion factors
for British equivalents of metric units.
Abbreviations
1 - liters
kg - kilograms
m tons - metric tons
m - meters
cm - centimeters
kg/103! - kilograms/thousand
liters
Pa - Pascals
Conversion Factor
liters X .26 = gallons
gallon X 3.79 = liters
kilograms X 2.203
pounds X .454
metric tons X 1.1
tons X .907
pounds
kilograms
tons
metric tons
meters X 3.28 = feet
centimeters X .394 * inches
kg/10,! X 8.33 =
lb/!0Jgal X .12 =
lb/10ga!
kg/!0J!
oz/in X 431 = Pascals
Frequently used measurements in this document are:
76,000 1
19,000 1
15,000 1
15 cm
6 oz/in2
20,000 gallons
5,000 gallons
4,000 gallons
6 inches
2600 Pascals
54 kg/day ^ 120 Ib/day
3 kg/day ^ 6.6 Ib/day
1.6 kg/103l ^ 13 lb/103 gal
1.4 kg/103! ^ 12 lb/103 gal
0.6 kg/10!
5 lb/!0 gal
vii
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1.0 INTRODUCTION AND SUWARY
This document is related to the control of volatile organic
compounds (VOC) from bulk plants with daily throughputs of 76,000
liters of gasoline or less. The techniques discussed herein are
less complex and less costly than those which are applicable to bulk
gasoline terminals. (See Control of Hydrocarbons from Tank Truck
Gasoline Loading Terminals, EPA-450/2-77-026). VOC emitted during
filling of account trucks and storage tanks are primarily C. and C5
paraffins and olefins which are photochemically reactive (precursors
to oxidants).
Methodology described in this document represents the presumptive
norm or reasonably available control technology (RACT) that can be
applied to existing bulk plants. RACT is defined as the lowest emission
limit that a particular source is capable of meeting by the application
of control technology that is reasonably available considering technological
and economic feasibility. It may require technology that has been applied
to similar, but not necessarily identical, source categories. It is not
intended that extensive research and development be conducted before a
given control technology can be applied to the source. This does not,
however, preclude requiring a short-term evaluation program to permit the
application of a given technology to a particular source. This latter
effort is an appropriate technology-forcing aspect of RACT.
1-1
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1.1 NEED TO REGULATE BULK PLANTS
Control techniques guidelines concerning RACT are being prepared
for those industries that emit significant quantities of air pollutants in
areas of the country where National Ambient Air Quality Standards (NAAOS)
are not being attained. Gasoline bulk plants are a significant source
of VOC.
Annual nationwide emissions from bulk plants are estimated to be
180,000 metric tons (70,000 metric tons from account trucks and 110,000
metric tons from storage tanks). This represents one percent of total
VOC emissions from stationary sources.
1.2 SOURCES AND CONTROL OF VOLATILE ORGANIC COMPOUNDS FROM BULK PLANTS
At bulk plants vapors are displaced to the atmosphere from the filling
of account trucks and storage tanks. Additional VOC emissions are traceable
to "breathing" and "drainage" losses from storage tanks. Three levels of
increasingly more effective VOC control are applicable to bulk plants.
They are:
Alternative I - Submerged filling of account trucks (either
top-submerged or bottom fill).
Alternative II - Alternative I plus vapor balance (displacement)
system to control VOC displaced by gasoline
delivery to the storage tank.
Alternative III - Alternative II plus vapor balance system to
control VOC displaced.by filling account trucks.
Account truck emissions (splash fill) can be reduced by about 60 percent
through the use of submerged fill techniques (Alternative I). Vapor
balance systems provide an additional 90 percent reduction in emissions
1-2
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from truck and storage tank loading (Alternative III). Vapor balance
is a simple technique wherein displaced vapors from account trucks are
transferred to storage tanks and subsequently to the transport trucks
that deliver gasoline to the bulk plant. Collected vapors are recovered
or oxidized at the terminal where the transport trailer is filled.
Capital costs for a top-submerged balance system at a 76,000 liter
per day bulk plant are $3,500. Top-submerged and bottom fill at the
same size plant have capital costs of $730 and $12,110, respectively.
Cost effectiveness is $40 credit for top-submerged fill balance systems,
$130 credit for top-submerged fill only, and $20 credit for bottom fill
(figures are in terms of dollars per 1000 kilograms of hydrocarbon removed).
1.3 REGULATORY APPROACH
Regulations should be written in terms of operating procedures and
equipment specifications rather than emission limits. It is extremely
difficult to quantify emissions from a bulk plant using conventional
source testing procedures. Visual observation and the use of portable
hydrocarbon detectors will be required to ensure that liquid and vapor
leaks are minimized and that proper control equipment is in use.
In designing bulk plant regulations consideration should be given
to their compatibility with Stage I service station regulations. For
example, truck filling vapor control technology is most effective for
plants which deliver to accounts covered by Stage I. Trucks which
deliver to "non-exempt accounts"* return to the bulk plant with rich
*Under Transportation Control Plans and some State and local regulations,
operators are required to equip certain gasoline storage tanks with vapor
recovery systems. Existing tanks of less than 2000 gallon capacity and
certain new tanks are typically exempted, e.g., Transportation Control Plans
for the National Capital Interstate AQCR, December 6, 1973 (38 FR 33719). For
tanks that are not exempted, the vapor-laden delivery vessel is to be refilled
only at facilities equipped with a vapor recovery system or equivalent which
recovers at least 90 percent by weight of displaced VOC.
1-3
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vapor concentrations in the empty compartments. VOC losses on filling
are potentially two or more times greater than from trucks servicing
exempt accounts. Bulk plants serving non-exempt accounts tend to be
larger than average while many of those delivering to exempt accounts
are extremely small.
For some areas it may be reasonable to apply the most effective
control alternative (III) to all bulk plants regardless of size and
customers serviced. However, in many AQCR's, the less effective and
less costly alternative (II) may be the appropriate strategy for small
plants; their smaller throughputs and lesser truck filling emission rates
tend to render balance systems less cost effective than at larger bulk
plants. In addition, the economic impact of incremental control costs
(Alternative III over II) is likely to be severe for many small independent
bulk plants. Though it is not possible to characterize precisely the plant
size cutoff for potentially severe economic effects, this is likely to
occur in the range of 15,000 liters per day or less gasoline throughput.
Therefore, where determining the level of control to require for small
bulk plants, consideration should be given to potential economic impacts
as well as retrofit difficulty and the status of accounts vis-a-vis
Stage I regulations.
Cost information presented in Chapter 4 will assist States in making
determinations of economic feasibility. Much of the information presented
herein is based on recent experience in the Denver (Colorado) area.
Capital costs in particular are markedly lower than had been projected by
other sources. It is our opinion that the costs listed in Chapter 4 are
representative of the type of equipment that will be installed in typical
bulk plants across the nation.
1-4
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2.0 SOURCE AND TYPES OF EMISSIONS
2.1 INDUSTRY DESCRIPTION
Bulk gasoline loading plants are typically secondary distribution
facilities which receive gasoline from bulk terminals by trailer trans-
ports, store it in above-ground storage tanks, and subsequently
dispense it via account trucks to local farms, businesses, and
service stations. A typical bulk plant has a throughput of 15,000 liters
of gasoline per day with storage capacity of about 189,000 liters of
gasoline. EPA defines the bulk plant as having a throughput
of less than 76,000 liters of gasoline per day averaged over the work
days in one year.
The 1972 Census of Business indicates that there were 23,367 bulk
plants in the U.S. having 7,948,500 liters of bulk capacity or less for
all fuels. Compared with the 1967 census, the 1972 data show an 11
percent decline in the number of bulk plants; economic factors appear
to be the reason for this decline. The cost of bulk plant related labor
and capital are eliminated if the bulk terminals can deliver directly to
the account. There is a trend in the industry to deliver directly
from bulk gasoline terminals to customers.
2.2 BULK PLANT FACILITIES AND EMISSIONS
This section discusses typical bulk plant facilities and
2-1
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emissions resulting from operation of these facilities. The
facility sizes and typical emission factors used in this section are
2 3
based on a survey of 385 bulk gasoline plants prepared for the EPA. '
The areas surveyed include: San Diego, San Joaquin Valley (California),
Denver, Baltimore/Washington, D.C. and Houston/Galveston areas.
2.2.1 Bulk Plant Facilities
Facilities include: (1) tanks for gasoline storage; (2) loading
racks; and (3) incoming and outgoing tank trucks. All three are emission
points within the plant.
2.2.1.1 Gasoline Storage
Above-ground storage facilities account for approximately 65 percent
of the plants surveyed and underground for 30 percent; 5 percent use both
types.
Above-ground tanks are usually cylindrical with domed ends (vertical
or horizontal axis). Because storage tanks found at bulk plants are
relatively small, the use of floating roof tanks is not common. Typical
capacities of bulk plant storage tanks range from 50,000 to 75.000 liters.
The number of gasoline tanks per plant varies between one and eight with an
average of three, resulting in a storage capacity of 50,000 to 600,000 liters.
Similar tanks are also used to store other petroleum products, including
diesel fuel, kerosene, lubricants, and fuel oils. Underground storage
tanks tend to be more prevalent in large cities; most are of 38,000 liter
capacity. Three underground gasoline tanks are an average number per plant.
2-2
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2.2.1.2 Loading Racks -
A typical loading rack includes shut-off valves, meters, relief
valves, electrical grounding, lighting, by-pass plumbing, and loading
arms. Loading may be by bottom fill, top splash, submerged fill pipe
through hatches or by dry connections on the tops of trucks. Top-filling
is used in 90 percent of the surveyed plants; 75 percent are using top-
submerged filling rather than top-splash filling. Bottom filling is
used in only 10 percent of the surveyed plants although an industry trend
toward bottom-filling was noted. A typical plant has one rack with an
average gasoline pumping rate of 490 liters per minute.
2.2.1.3 Tank Trucks ^ .
Truck-trailer transports supply bulk plants with gasoline while
account (bobtail) trucks deliver gasoline to bulk plant customers. Truck-
trailer transports have four to six compartments and deliver approximately
34,000 liters of one grade gasoline to the bulk plant. Most commonly,
truck-trailer transports are owned by oil companies or commercial carriers;
such vehicles are not devoted solely to bulk plant service. Bulk plants
typically average two account trucks each. Account trucks average four
compartments and a total capacity of 7,200 liters. Account trucks are almost
always owned by the plant operators, even when the plant is owned by a
refiner.
2.2.2 Emission Sources
Vapors can escape from fixed roof storage tanks and tank trucks
even when there is no transfer activity. Temperature induced pressure
2-3
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differentials can expel vapor-laden air or induce fresh air into
the tank. The vapor escaping under these conditions is referred to as a
"breathing loss." Liquid transfer forces air-hydrocarbon vapors out
during filling (filling losses) of the tank and ingests air during
draining (draining losses). The draining and filling losses combined are
called "working losses." Miscellaneous or fugitive loss sources can
also occur from pressure-vacuum valves, shut-off valves, truck hatches,
piping, and pumping seals.
2.2.2.1 Breathing Losses -
Factors affecting breathing or standing losses for fixed roof tanks
and tank trucks include ullage and volatility of the gasoline stored,
type and condition of tanks and appendages, and meteorological
conditions. If there are no leaks or direct openings, then temperature
fluctuations are the major cause of breathing losses. As the temperature
of the liquid rises, the vapor pressure increases and evaporation takes
place. When overall pressure in the gas space increases and exceeds the
vent pressure set point (usually 2.6 x 10 Pascals), a mixture of air
and hydrocarbons is discharged into the atmosphere. As the temperature
decreases, gases partially condense and contract, and fresh air is drawn
into the vapor space. This permits additional hydrocarbons to vaporize
resulting in a positive pressure. Since hydrocarbons are emitted,
but generally not drawn back into the tanks, a continued loss of hydro-
carbons results from the daily changes in ambient temperature.
2-4
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2.2.2.2 Working Losses -
Working losses, generated during liquid transfer, can be divided
into filling and draining losses. A filling loss occurs when the liquid
transferred into the receiving vessel displaces an equal volume of air
saturated or nearly saturated with hydrocarbons, venting to the
atmosphere. A draining loss occurs when the transferred liquid is
replaced by an equal volume of air. Subsequently hydrocarbons vaporize
and saturate the air causing a 20 to 40 percent increase in volume;
excess air saturated with hydrocarbons is vented.
The quantity of hydrocarbon emission is a function of the "volume
displaced and the fraction of hydrocarbon contained in the displaced
gases. For gasoline of a given Reid vapor pressure, the quantity of
hydrocarbon increases with temperature. However, the relative temperatures
of the tank and delivered gasoline may cause a positive or negative vapor
growth which is more pronounced under splash than submerged filling.
The two basic types of gasoline loading into truck tanks are
4
presented in Figure 2-1. In the splash filling method, the fill pipe
dispensing the gasoline is only partially lowered into the truck tank.
Significant turbulence and vapor-liquid contact occurs during splash
filling resulting in high levels of vapor generation and loss. If the
turbulence is high enough, liquid droplets will be entrained in the vented
2-5
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VAKOA EMUfOttt
VAPORS
Gasoline ;
vapors
/ Gasoline
-^•- -MATCH COVtR
•-• . . PRODUCT :
Tank truck compartment
1 .
3PLA3H LOADING Uf THOO
VAPOH EVMaiONS
VAPOA3
- FILL
0)
c
0
I/I
— MATCH coven
Tank truck compartment
Case 2. suauEnoso FILL PIPS
VAPOR VENT
TO RECOVERY
on ATMOSPHERE
HATCH CvOSEU
\
V >•
VAPORS
PBOOUCT
Tank truck compartment
Gasoline
FILL t'ir-1
Case 3. BOTTOM LOAOINO
Figure 2-1. Gasoline Tank Truck Loading Methods
2-6
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vapors. A second method is submerged filling either with a submerged
fill pipe or bottom filling. In the top submerged fill pipe method, the fill
pipe descends to within 15 centimeters of the bottom of the truck tank.
In the bottom filling method, the fixed fill pipe enters the truck tank
from the bottom. Submerged filling significantly reduces liquid turbulence
and vapor-liquid contact, resulting in much lower hydrocarbon losses than
encountered during splash filling.
2.2.2.3 Miscellaneous Losses -
Miscellaneous losses are highly variable from one bulk plant to
another; these losses are usually the result of poor operating and
maintenance procedures.
Some causes of miscellaneous losses are:
1) Cracks in seals and improper connections which cause partial
venting of hydrocarbon vapors and liquid leakage.
2) High fill rates which cause higher vapor generation rates
and pressures.
3) Improper setting of gasoline fill meters, residual gasoline
in the tank truck compartment, and apparent shut-off valve failure
which cause truck tank overfills.
4) Careless hooking up of liquid lines and top loading nozzles.
5) Truck cleaning.
6) Defective or maladjusted pressure-vacuum relief valves.
2.2.2.4 Emission Factors -
Emission factors used in this section are calculated from
2-7
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ideal gas laws or from formulas contained in "Compilation of Air Pollutant
Emission Factors."4 Affecting parameters for storage tank losses are from
"Study of Gasoline Vapor Emission Controls of Small Bulk Plants."5 Un-
controlled emissions from each source will be considered separately.
Tank Truck Losses
Uncontrolled filling losses are estimated to be 1.4 kg/103 liters
of gasoline loaded by the splash fill method and 0.6 kg/10 liters of
gasoline loaded by the submerged fill method. For a typical gasoline
plant with an average throughput of 15,000 liters of gasoline per day,
the estimated uncontrolled filling losses with splash fill are 21 kg/day
or 9 kg/day with submerged fill. Breathing losses in tank trucks are
highly variable; besides temperature variations they are affected by
settings of pressure-vacuum relief valves.
Storage Tank Losses
For 15,000 liter/day bulk gasoline plants, the uncontrolled
breathing loss is estimated to be 3 kg/day per tank,7 the draining loss
.46 kg/1000 1 and the filling loss 1.15 kg/1000 liters loaded. For a
typical plant with three tanks, uncontrolled breathing and working losses
are approximately 9 kg/day and 24 kg/day, respectively.
2.3 SUMMARY
A tyjsical gasoline_p_lant has a throughput .of 15,000 liters of gasoline
per day with bulk storage capacity of about 189,000 liters of gasoline.
Estimated uncontrolled emissions from a 15,000 liter per day bulk gasoline
2-8
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plant are approximately 15,500 kg/yr or 54 kg/day. VOC emissions from
each source are shown in Table 2-1. Losses from tank truck breathing,
tank truck leakage or other miscellaneous sources are highly variable
and are not included in the table.
2-9
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Table 2-1. UNCONTROLLED VOC EMISSIONS
FROM A SMALL BULK PLANT
Annual
Working Day
Throughput
Storage Tank
(above-ground fixed roof)
(3 storage tanks)
Breathing losses (3 kg/day
per tank)
Working losses (1.6 kg/103!)
Draining (.46 kg/103!)
Filling (1.15 kg/!03l)
Tank Truck (splash filling)
Filling losses (1.4 kg/103l)
Total Uncontrolled
Emissions
4,290,000 liters
2,600
6,900
6,000
15,500
15,000 liters
9
24
21
54
^
* Using 286 working days per year.
^-^o
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2.4 REFERENCES
1. U.S. Department of Commerce, Bureau of Census, 1972 Census of
Wholesale Trade, subject series, "Petroleum Bulk Stations and Terminals,"
#WL 72-5-2, U.S. Government Printing Office, Washington, D.C., page 2-155.
2. "Study of Gasoline Vapor Emissions Controls at Small Bulk
Plants," Pacific Environmental Services, Inc., U.S. EPA Region VIII
Report, EPA Contract No. 68-01-3156, Task Order No. 5, October, 1976.
3. "Effects of Stage I Vapor Recovery Regulations on Small Bulk
Plants and on Air Quality in the Washington, D.C., Baltimore, Md., and
Houston/Galveston, Texas Areas," U.S. EPA, DSSE, EPA Contract No. 68-01-3156,
Task Order No. 28, March, 1977.
4. "Supplement No. 7 for Compilation of Air Pollutant Emission
Factors," Second Edition, U.S. EPA, Office of Air Quality Planning and
Standards, April, 1977.
5. Reference 2.
6. Reference 4.
7. Reference 2.
2-11
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3.0 EMISSION CONTROL TECHNOLOGY
Control of breathing, working, and miscellaneous losses resulting
from storage and handling of gasoline at bulk plants can be accomplished
through submerged fill, balance systems, vapor processing systems, and
control of truck loading leaks. Vapor processing systems have not been
applied to bulk plants, but have been used to recover hydrocarbon vapors
at bulk terminals during truck loading.
3.1 TYPES OF CONTROL TECHNIQUES
This document considers effectiveness and costs of three control
techniques, i.e. submerged fill, balance or displacement systems, and
leak prevention (control of tank truck loading leaks). Vapor recovery
and oxidation systems, while technically feasible, have not been employed
at bulk plants.
3.1.1 Submerged Loading
One method of reducing vapors generated during the loading of tank
trucks is by using submerged fill. By changing from top-solash to sub-
merged fill, HC vapors generated by loading tank trucks can be reduced
from 1.4 to 0.6 kg/10 liter transferred (a 58 percent reduction).
Submerged fill decreases turbulence, evaporation, and eliminates
liquid entrainment.
3.1.2 Balance System
The displacement, or vapor balance system operates by transferring
vapors displaced from the receiving tank to the tank being unloaded. A
3-1
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vapor line between the truck and storage tanks essentially creates a
closed system permitting the vapor spaces of the two tanks to balance
with each other. Figure 3-1 shows a typical flow scheme of a vapor
balance system.
Vapor balancing of incoming transport trucks displaces vapor from
storage tanks to truck compartments; emissions are ultimately treated
at the terminal with a secondary recovery/control system. EPA sponsored
source tests at two bulk plants have shown that an efficiency greater
than 90 percent is attainable with vapor balancing of transport trucks
2
and storage tanks.
Vapor balancing of storage tanks and account trucks also reduces
2
account truck filling losses by 90 percent or greater efficiency.
Also, balance systems on account truck filling virtually eliminate
drainage losses from storage tanks, since displaced air is saturated
or nearly saturated with hydrocarbons. The efficiency attainable in
loading account trucks is strongly affected by tightness of the truck
compartments, i.e. condition of hatches and seals, and on care exercised
in making connections.
3.1.3 Vapor Recovery and Oxidation Processing Systems
Vapor recovery and oxidation systems can be used to process vapors
displaced from the storage tanks and the tank trucks during filling.
These systems have been broadly applied to bulk terminal truck loading
losses but have not been applied in bulk plants - probably due to costs.
x
Combinations of compression, refrigeration and absorption systems can
recover 90 to 93 percent of displaced VOC while incineration will destroy
over 98 percent.
3-2
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TRANSPORT UNLOADING
ACCOUNT TRUCK LOADING
CO
I
CO
Vapor Line
Pressure-Vacuum Relief Valve/
Pressure-Vacuum
Relief valve
Gasoline
Storage
Tank
- Vapor Line
Pressure-Vacuum
Relief Valve
Pump
^Gasoline Line
Gasoline Line , Pump
Figure 3-1. VAPOR BALANCE SYSTEM
(bottom fill)
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3.1.4 Leak Prevention
Proper maintenance, operation, and good housekeeping is required
to assure effective collection of vapors at bulk plants. EPA source
tests have shown that from 30 to 70 percent of vapors generated, during
tank truck loadings at vapor recovery bulk terminals, were vented to
4
the atmosphere. Tank truck leakage was also observed during EPA
sponsored emission tests at two bulk plants employing vapor balance to
control hydrocarbon emissions.
3.2 CONTROL ALTERNATIVES
The control alternative considered are:
I Submerged filling.
II Submerged filling account trucks
with vapor balancing of transport
trucks and storage tanks.
Ill Submerged filling account trucks
with vapor balancing of storage
tanks, account and transport trucks.
Figure 3-2 shows these control alternatives along with estimated
reductions from an uncontrolled 15,000 liter per day plant. In
Alternatives II and III a leak-free system is assumed such that the only
VOC emissions considered are breathing, drainage and displacement losses.
Losses are itemized in Table 3-1. Submerged fill is seen to provide a
22 percent VOC reduction from the base case; Alternative II and III yield
54 and 77 percent respectively. For the total balance system
(Alternative III), the daily reduction in emissions is 41.5 kg. Only
24.5 kg of the total is realized as a product recovery credit by the bulk
plant operator; the other 12 kg is recovered at the terminal.
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3.3 SUMMARY
1. By changing from top-splash to submerged filling,'hydrocarbon
vapors from account truck loading can be reduced by 58 oercpnt.
2. A vapor balance system can control vapor emissions during un-
loading and loading of tank trucks with an efficiency greater than 90
percent.
3. Vapor processing technology has been broadly applied to bulk
terminal truck loading emissions and is capable of handling the smaller
emission rates from bulk plants. Such systems would be expected to reduce
VOC emissions by 90 percent or more if applied to storage tanks and account
trucks.
4. Proper maintenance, operation, and good housekeeping is required
to prevent leaks and assure effective collection of VOC emissions when balance
systems are installed. To maintain high efficiencies tank trucks, storage
tanks and all piping must be vapor tight.
3-5
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Figure 3-2. TYPICAL BULK GASOLINE PLANT CONFIGURATIONS
Throughput - 15,000 liters/day -- 3 storage tanks
Base Case Emissions - 54 kg/day (top splash fill, no control)
Alternative I - Submerged filling.
Total Emissions 42 kg/day
Reductions from Base 12 kg/day
Working loss
24 kg/day
Breathing loss
* 3 kg/day/tank
oo
Trans
Truck
In
OO 0
J L
Working
i
i
i
port Storage Account
Tank Truck
loss
9 kg/day
h
o
Alternative II - Submerged filling
with vapor balancing of transport
trucks and storage tanks.
Total Emissions
Reduction from Base
Reduction from Alt.
25 kg/day
29 kg/day
17 kg/day
Working loss
7 kg/day
Breathing loss
3 kg/day/tank
1 * •
1
1
oo
Tra
Tru
oo
nsport
ck
n
O
4 *
-i i I
J L
We
)rking
i
loss
k9 kg/day
. n
Oo
o
Storage Account
Tank Truck
Working loss
3.5 kg/day
Breathing loss
3 kg/day/tank
Alternative III
Total Emissions
Reduction from Base
Reduction from Alt.
Reduction from Alt.
Submerged filling
ng of storage
transport trucks.
12.5 kg/day
41.5 kg/day
II 13 kg/day
Tr
Tr
i
I
i
h
oo o
,l i!
J L
I
1
t
, . n
5o
O'
ansport Storage Account
jck Tank Truck
3-6
Liquid
Vapor
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Table 3-1. AIR POLLUTION IMPACT OF CONTROL ALTERNATIVES ON TYPICAL PLANT
(15,000 liters per day throughput operating 2B6 days/year)
Control
Alternatives *
1. Base Case •
Uncontrolled
(splash loadfng)
2. Alternative I -
Bottom or top sub-
merged loading of
account truck.
3. Alternative II -
Bottom or top sub-
merged loading with
vapor balance of
transport trucks
and storage tanks.
4. Alternative III •
Bottom* or top sub-
merged loading with
vapor balance of
storage tanks.
transport and
account trucks.
Storage Tank Losses
l " "*
Breathing'
kg/day
9
9
9
9
pr'lindB''*
kg/day
7
7
7
3.5
kg/ 1000 1
0.46
0.46
0.46
0.23
Filling"
kg/day
17
17
0
0
kg/1000 1
1.15
1.15
0
0
Total
kg/day
33
33
16
12.5
Account Truck
Losses
Loading
kg/day
21
9
9
0
kq/1000 1
1.4
0.6
0.6
0
Total Bulk
Plant Losses
kg/day
54 .
42
m tpn
15.4
12.0
25 7.1
12.5
3.6
Reduction from
Uncontrolled
Plant
kg/day
„
1?
29
41.5
m ton/ VGA i
__•
3.4
8.3
11.9
Assume no leaks
1 Three fixed roof above-ground storage tanks (3.2 x 8 meters)
2 Assuming 20 percent HC concentration in account trucks
3 Assuming ideal gas laws
-------
3.4 REFERENCES
1. "Supplement No. 7 For Compilation of Air Pollutant Emissions
Factors,"- Second Edition, U.S. EPA, Library Services, MD-35, Research
Triangle Park, N.C. 27711, April 1977.
2. "Compliance Analysis of Small Bulk Plants," U.S. EPA,
Enforcement Division, Region VIII, Contract No. 68-01-3156, Task
Order No. 17, October, 1976.
3. Reference 2.
4. "Control of Hydrocarbons From Tank Truck Gasoline Loading
-Terminals," Guideline series, EPA-450/2-77-026, U.S. EPA, Office of Air
Quality Planning and Standards, October, 1977.
5. Reference 2.
3-8
-------
4.0 COST ANALYSIS
4.1 INTRODUCTION
4.1.1 Purpose
The purpose of this chapter is to present estimated costs for control
of hydrocarbon emissions from the transfer and storage of gasoline at gasoline
bulk plants.
4.1.2 Scope
Control costs have been developed for the three control alternatives
described in Chapter 3, namely, I - conversion to submerged filling of
account trucks, II - conversion to submerged filling of account trucks
with vapor balance of transport trucks and storage tanks, and III -
conversion to submerged filling of account trucks with
vapor balance of account trucks, transport trucks and storage tanks.
Costs associated with prevention of accidental emissions such as spillage are
not included. Costs for applying controls to existing plants are included,
but costs for new plants are not included.
4.1.3 Use of Model Plants
Two model plants are used. The 15,000 liter per day throughput model
represents the smaller bulk plants and consists of three storage tanks, one
loading rack with three arms, and two account trucks, each with four compart-
ments. The 76,000 liter per day model represents the larger bulk plants and
consists of the same equipment as the smaller model, with two additional
account trucks.
The process for which costs are estimated includes two emission points:
emissions during transfer from transport trucks to storage tanks and emissions
during transfer from storage tanks to delivery (account) trucks. Although
4-1
-------
any actual plant will have costs which differ from the model plants, the
model is an average which reflects the extreme variability of actual costs.
As such, the model plant is a more accurate estimate than any single actual
plant cost.
4.1.4 Bases for Capital and Annualized Cost Estimates
Capital costs include hardware, freight, installation, and sales tax.
For conversion to the top-submerged fill technique, the estimate is based
on costs of extender piping, swing joints, connecting materials and fittings,
freight and tax, and installation labor for a plant with one three-armed
loading rack, as shown in Table 4-1. For conversion to the bottom fill tech-
nique, the estimate is based on a major overhaul of existing pumps, product
flow lines, and the concrete pad (which together comprise what is commonly
called the loading rack) at an average cost of $1700; in addition to the
2
conversion of two trucks, each at a cost of $2600. For vapor balance systems,
the estimate is based on actual purchase data from permit applications of
45 bulk plants in Colorado during 1976 and 1977. This data was part of a larger
inventory of about 250 bulk plants in the Denver (Colorado) and San Joaquin
Valley (California) areas. Data from the Colorado plants are considered a
more accurate representation of cost than the larger sample, which was con-
ducted primarily by telephone and short personal interviews with bulk plant-
owners, and which consisted of estimates of potential purchases rather than
actual records of purchase prices.
Annualized costs consist of (1) operating costs, i;e., labor, utilities,
and maintenance, (2) capital charges, i.e., interest, taxes, insurance, and
4-2
-------
Table 4-1. PARAMETERS OF MODEL PLANTS
1. Throughput
2. Loading Racks
3. Storage Tanks
4. Account Trucks
5. Compartments per Account Truck
6. Value of Gasoline
7. Density of Gasoline
8. Emissions
a. Uncontrolled
b. Control Alternative I
c. Control Alternative II
d. Control Alternative III
9. Working Days per Year
10. Maintenance (% of capital cost)'
Small Model
15,000 liters/day
1
3
2
4
$0.10 per liter
0.739 kg/liter
54 kg/day
42 kg/day
25 kg/day
12.5 kg/day
286
3
11. Capital Charges (% of capital cost)b 17.17
Large Model
76,000 liters/day
1
3
4
4
$0.10 per liter
0.739 kg/liter
274 kg/day
213 kg/day
127 kg/day
63 kg/day
286
3
17.17
Pacific Environmental Services, Inc., Evaluation of TOP Loading Vapor Balance
Systems for Small Bulk Plants. Contract No. 68-01-4140, Task Order No. 9,
June, 1977, p. V-3.
'Capital recovery factor for 15-year equipment life and 10 percent interest
is 13.17 percent of capital, to which is added 4 percent for taxes, insurance,
and administration.
4-3
-------
administration, and (3) gasoline credit for recovery of gasoline as a salable
product. Operating costs are negligible for conversions to top-submerged or
bottom fill techniques, and are limited to maintenance costs for vapor balance
equipment, which is estimated to be 3% of the installed capital cost. Capital
costs are computed using a capital recovery factor based on a 10% interest
rate during a fifteen-year equipment life, plus a 4% charge to cover taxes-,
insurance, and administration. Gasoline credit is a reduction to annualized
costs by the amount of gasoline retained for sale by not being emitted as
vapor. The credit is calculated by multiplying the controlled emissions
by $.10 per liter, as shown in Table 4-2.
4.2 CONTROL OF EMISSIONS FROM UNLOADING AND LOADING AT GASOLINE BULK PLANTS
4.2.1 Model Plant Parameters
Table 4-1 shows the physical parameters of the two model plants. It is
assumed that the larger plant uses two additional account trucks for its
increased throughput, even though the increased throughput might possibly be
handled by increased frequency of trips with the same number of account
trucks. In computing emission reductions for the large model plant,
the emission reductions for the small model plant were multiplied by
the size ratio of 76,000 liters per day divided by 15,000 liters per
day.
4-4
-------
4.2.2 Control Costs
Shown in Table 4-2 are cost estimates for the three control alternatives
and for the two model plants. The table begins with estimates of installed
capital costs, identifies annualized operating costs, and concludes with a
cost-effectiveness ratio which relates the net annualized cost to the annual
emission reduction for each control alternative. As mentioned in Section
4.1.4, the estimates for vapor balance systems are averages from actual
purchase costs. Estimates for bottom loading conversion originated as part
of the larger inventory discussed in Section 4.1.4.
The net annualized cost is the sum of the operating costs and capital
charges, less gasoline credit. For the smaller model plant, the net
annualized cost ranges from a $330 credit with conversion to top-submerged
fill technique under Control Alternative I to a $1,150 cost for bottom
loading under Control Alternative III. For the larger model plant, net
annual cost ranges from a $2,340 credit with conversion to top-submerged
fill technique under Control Alternative III to a $10 cost with bottom-
loading Control Alternative II. As Table 4-2 shows, top-submerged
loading is less costly than bottom-loading for both models and for all
control alternatives. This results from the relatively large average cost
of converting to bottom loading of $2600 per account truck and $1700 per
loading rack.
Capital costs for conversion to top-submerged fill technique are the
same for the smaller and the larger model bulk plants. Differences
in total cost among the three control alternatives arise from
cost components other than conversion to the top-submerged fill technique.
The first difference is in vaoor recovery eauioment reauired
4-5
-------
Table 4- a. COST ESTIMATES FOR CONTROL OF HYDROCARBON EMISSIONS FROM THE TRANSFER AND STORAGE OF GASOLINE AT GASOLINE BULK PLANTS
(IN THOUSANDS OF 1976 DOLLARS)
Conversion Cost
Vapor Balance Cost
Installed Capital4
Direct Operating Costs0
Capital Charges
Gasoline Cred1td
Net Annual Cost/(cred1t)
(bntrolled Emissions6
(In units of 1000 Kg)
Cost/(cred1t) per Kg
(In units of $/Kg)
CONTROL ALTERNATIVE I
Conversion to Bottom or Top-
Submerged Loading of Account
Truck
Bottom
'Loadingfl/day)
15.000 76.000
6.91 "TTHT
TOT 12.11
0 0
1.18 2.08
(0.46) (2.35)
0.72 (0.27)
3.43 17.38
0.21 (0.02)
Top-Submerged
Loadlnq (I/day)
15.000 76.000
0.73 -JOT"
..-
Oj3b 1T73b
0 0
0.13 0.13
(0.46) (2.35)
(0.33) (2.22)
3.43 17.38
(0.10) (0.13)
CONTROL ALTERNATIVE II
Conversion to Bottom or Top-
Submerged Loading of Account
Truck, with Vapor Balance of
Transport Trucks & Storage Tanks
Bottom
Loadlnq (I/day)
15,000 76,000
6.91 "TOT
1.40 1.40
8.31 13.51
0.04 0.04
1.42 2.32
(0.46) (2.35)
1.0 0.01
8.29 42.00
0,12 0.00
Top- Submerged
Loadlnq (I/day)
15.000 76.000
"OF TTTT
1.40 1.40
2.13 2.13
0.04 0.04
0.37 0.37
(0.46) (2.35)
(0.05) (1.94)
8.29 42.00
(0.01) (0.05)
CONTROL ALTERNATIVE III
Conversion to Bottom or Top-
Submerged Loading of Account
Trucks with Vapor Balance of
Both Account Trucks & Transport
Trucks and Storage Tanks
Bottom
Loadlnq (I/day)
15.000 76.000
6.91 12 "11
2.80 2.80
9.71 14.91
0.08 0.08
1.67 2.56
(0.60) (3.03)
1.15 (0.39)
11.87 60.14
0.10 (0.01)
Tcv-Submerged
Loadlnq (I/day)
IS .000 76.000
2.80 2.80
3.53 3.53
0.08 0.08
0,61 0.61
(0.60) (3.03)
.09 (2.34)
11.87 60.14
0.01 (0.04)
aA11 Installed capital costs, except for note b, below, are from the survey Indicated In reference 1, supplemented by certain truck conversion
costs from the analysis Indicated In reference 2. The cost of each control alternative Includes the cost of exactly those components which are s
stated In the title of the control alternative. For example, control alternatives II and III Include the vapor balance equipment costs indicated
plus the costs of bottom or top-submerged loading, as Indicated In the titles.
Catalogue E - 12/72, Revised 9/74, Emco Wheaton, Inc., Price List D, E-10/76. Based on the use of extender pipes and loading arms, cost estimates are: •
Piping cost (48" x 4") ($71.00) + Swing joint (4") ($128.50) = $199.50 + Tax and Freight (119.50 x .07) ($13.96)+ Labor (3 man-hrs x $10) ($30.00) =
a total of $243.46. The typical plant has one rack with three arms: 3 x 243.46 = $730.38 por plant.
cPacific Environmental Services, Inc., Final Report: Economic Analysis of Vapor Recovery Systems on Small Bulk Plants. September, 1976, p. 4-2, and
Pacific Environmental Services, Inc., Evaluation of Top Loading Vapor Balance Systems for Small Bulk Plants, Contract No. 68-01-4140, Task Order No. 9,
June 1977. p. V-3. Direct operating costs are estimated to be 3 percent of installed capital cost. For control alternatives II and III, the 3 percent
is applied only to the vapor balance equipment cost, since the top-submerged and bottom-loading conversions are considered to have negligible mainte-
nance and thus negligible operating costs. ;
Computed as follows: Emission reduction credited to bulk plant In Kg per day x 286 working days per'year x 1.353 K x $.10 per liter. For the 15,000
liter/day plant: Control Alternative I: 12 x 286 x 1.353 x $.10 = $464.35; Control Alternative II: Kg
12 x 286 x 1.353 x $.10 = $464.35; Control Alternative III: 15.5 x 286 x 1.353 x $.10 = $599.78. For the 76.000 liter/day plant: corresponding
costs x 76
IS
Computed as follows: Total Emission Reduction in Kg per day x 286 working days. For the 15,000 liter/day plant: Control Alternative I: 12 x 286 -
3432; Control Alternative II: 29 x 286 * 8294; Control Alternative ill: 41.5 x 286 = 11.869. For the 76,000 liter/day plant: corresponding
costs x 76
T5
-------
for each control alternative. Secondly, for the larger model
plant, two additional trucks have to be converted to bottom fill.
The installed capital cost estimates for vapor balance systems
of $1400 for Control Alternative II and $2800 for Control Alternative'III,
shown in Table 4-2, are believed to be the most likely estimates for the
model plants under consideration. It is possible, however, that actual
control costs will vary from these estimates. Based upon information from
the California Air Resources Board, it is estimated that installed capital
costs for vapor balance for the model plants may vary from $1000 to $4200
for Control Alternative II and from $2000 to $8400 for Control Alternative III.4
4.2.3 Cost-Effectivenesses
Comparisons of the ratio of net annualized cost to controlled emissions
are shown in Table 4-2 as cost/(credit) per kilogram of hydrocarbon emissions
reduced. Since the ratio is cost divided by results, instead of vice-versa,
low numbers are better than high numbers. Additionally, Figure 4-1 shows a
graphical comparison of the cost-effectivenesses. For purposes of preparing
the curves in Figure 4-1, an intermediate model plant with three delivery
trucks and a throughput of 45,420 liters per day was used.
Several relationships are visible in Figure 4-1. First, the cost-
effectiveness of each control alternative improves with increasing throughput.
Secondly, the top-submerged option of each control alternative is more cost-
effective than any control alternative using the bottom-fill option. Also,
the top-submerged options remain in the same order of cost-effectiveness,
regardless of throughput. Third, when the bottom-fill option is used,
4-7
-------
Figure 4-1. Cost-Effectiveness of VOC Control
Alternatives at Bulk Plants
00
-a
0)
.>
o
I
o
en
o
o
•a
OJ
o
.2
.1
-.1
-.2
10
20
30 40 50 60
Throughput In Thousands of Liters Per Day
70
80
Legend
B - Conversion'to Bottom-fill
T = Conversion to Top-fill
1 = Control Alternative I
2 = Control Alternative II
3 = Control Alternative III
-------
throughput is a determining factor: Below 45,000 liters per day Control
Alternative I is the most cost-effective, but above this throughput Control
Alternative II is the most cost-effective of the three alternatives. Similarly,
above 62,000 liters per day Control Alternative III becomes more cost effective
than Control Alternative I. Looking back from Figure 4-1 to Table 4-2 it is
clear that while capital costs for bottom loading increase in going from
Control Alternative I through Control Alternative II to Control Alternative III,
the cost-effectiveness of the three alternatives improves, but the same pro-
gression through the control alternative using top-submerged loading results
in worsening cost-effectiveness.
4.2.4 Source of Cost Information
The data shown in Table 4-3 is the basis for the cost estimates
shown in Table 4-2. The data originated from permit applications
recorded in the Colorado Air Pollution Control Division in October, 1976.
In relating these data to the three control options, it was necessary to
use averages. The estimate of $2600 for the conversion of a truck to
bottom loading, as stated in Section 4.1.4, originated in an earlier
study, indicated in reference 2. The purpose of Table 4-3 is to indicate
the range of the values used as the basis for estimates.
4-9
-------
Table 4-3. COLORADO BULK PLANT COSTS
A. Costs of Truck and Rack Conversions
Throughput
(litres/day)
0 - 15,140
15,141 - 37,850
37,851 and higher
No. of
Plants
21
20
4
B.
Inbound
Recovery
Only
Avg. $1,266
High $2,200
Low 300
Avg. $1,513
High $5,000
Low 250
Avg. $1,000
High $1 ,000
Low $1 ,000
Cost Breakdown
For Delivery
to Vapor
Recovery Customers
Avg.
High
Low
Avg.
High
Low
Avg.
High
Low
$2,800
$4,000
$1 ,600
$3,490
$5,000
$2,700
$4,500
$5,000
$4,000
1. To convert tanks to return vapors during in-bound loading of bulk plant
(all 45 plants affected):
Average: $1,100 per plant ($300 per tank)
2. To add long loading arms to plants serving only exempt accounts:
Average: $807 for telescoping sleeve assembly
(Approximately 3 installed)
Most installed long tubes on existing loading arms at $45 each.
Approximately 75 installed. Most plants already had long tubes.
3. To modify loading racks to accommodate vapor recovery of out-bound loading
to trucks delivering to controlled accounts:
a. For bottom loading system for trucks that can also load at terminals
(large nozzles):
Average: $2,000 (3 plants affected)
b. For bottom loading with a Wiggins System (small nozzle):
Average: $1,000 (5 plants affected)
4. To modify delivery trucks filling at bulk plant and delivering to controlled
accounts:
a. Large nozzle system: $1,000 per compartment (usually four to five per vehicle)
b. Wiggins System: $900 - $1,500 per vehicle.
4-10
-------
4.3 REFERENCES
1. Joseph, David, (U.S. Environmental Protection Agency Regional
Office VIII) and Mark Parsons (Air Pollution Control Division, Colorado
Department of Health), Records of Permit Applications, Air Pollution
Control Division, Colorado Department of Health, October 17, 1977.
2. Economic Analysis of Vapor Recovery Systems on Small Bulk
Plants. U.S. EPA, DSSE, Contract No. 68-01-3156, Task Order No. 24,
September, 1976, p. 4-3.
3. Study of Gasoline Vapor Emission Controls, Contract No.
68-01-3156, Task Order 15, U.S. Environmental Protection Agency,
Region VIII, Pacific Environmental Services, Inc., December, 1976, p. 2-1.
4. Simeroth, Dean, California Air Resources Board, November 23, 1977.
4-11
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5.0 EFFECTS OF APPLYING THE TECHNOLOGY
Air pollution impacts and other environmental consequences of applying
control technology presented in Chapter 3 are discussed in this chapter.
5.1 IMPACT OF CONTROL TECHNIQUES ON HYDROCARBON EMISSIONS
To determine the actual emission reductions that would occur as a
result of using each technique, it is necessary to estimate the reduction
in air pollution the technique would effect beyond that which would other-
wise be achieved by existing State or local regulations.
A number of States have developed regulations based on the recommendations
of Appendix B of 40 CFR. For facilities with throughputs less than 20,000
gal/day (76,000 I/day), approximately 20 States required control of storage
tanks (typically submerged fill) and only four States required control of
loading facilities in 1975.
In 1973 and 1974, EPA promulgated regulations which affected gasoline
bulk plants in 16 Air Quality Control Regions (AQCR's). Known as Stage I
service station regulations, they required 90 percent control of VOC
displaced during the filling of stationary storage tanks. They applied
to all existing storage tanks of greater than 2000 gallon capacity. As
an adjunct, they required that where vapor balance systems were employed
(non-exempt accounts), the tank truck could be refilled only at facilities
equipped to recover 90 percent or more of the displaced vapor. Most small
bulk plants are believed to deliver only to exempt customers with tanks smaller
than 2000 gallons; thus, these small bulk plants would not be required to
5-1
-------
install vapor control equipment if Stage I regulations were in force in
that area. There are few data available which relate bulk plant through-
put to size of customer tankage. Nonetheless, in the Denver (Colorado)
area only 9 of 45 bulk plants were found to service "non-exempt accounts."
The other 36 delivered gasoline only to accounts which were exempt from
Stage I regulations because of tank size.
Table 3-1 lists emission factors and emissions for the uncontrolled
plant and for the three control alternatives. For the typical bulk plant
of 15,000 liters per day throughput, plant emissions can be reduced by
11.9 metric tons per year with a total (Alternative III) vapor balance
system.
5.2 OTHER IMPACTS
EPA has examined secondary air impacts of applying control techniques
to bulk plants and has also studied water pollution, solid waste, and
energy impacts. There are no secondary air pollutants (as from power
plants) since the applicable control technology does not consume energy.
Neither are there significant adverse effects from either submerged fill,
bottom loading, or vapor balance systems.
While the control systems handle flammable vapors, they do not
present a safety hazard since vapor concentrations are greater than the
upper explosive limit (too rich to burn). In many instances, they will be
more safe to operate than existing uncontrolled bulk plants.
5-2
-------
6.0 ENFORCEMENT ASPECTS
The purpose of this chapter is to define the affected facility to
which the regulation will apply, to select the appropriate regulatory
format, and to consider techniques that can be used to determine
compliance with regulations.
6.1 AFFECTED FACILITY
A bulk plant is any facility loading gasoline into account trucks
at 76,000 liters or less per day. This throughput distinguishes bulk
plants from bulk terminals which are appreciably larger and employ
different types of loading and storage facilities and different types
of vapor control technology. The affected facility encompasses the unloading,
loading, and storage facilities.
Account and transport trucks are included in the affected facility
because: (1) the truck is the source of VOC vapors in a loading
operation, (2) during loading the truck is physically connected to
the facility, and (3) leaks from the truck can adversely affect the
collection efficiency of the overall control system.
Storage tanks were included in the affected facility because:
(1) they are significant sources in the plant, and (2) storage tanks
must be vapor tight for the balance system to be effective.
6.2 STANDARD FORMAT
It would be impractical to apply a mass emission limit (kg/hr) or
recovery efficiency (percent) for either Alternative I, II, or III.
6-1
-------
Mass emissions will vary depending on the hydrocarbon concentration in the
truck which may vary between 5 and 40 percent by volume depending on
temperature, RVP, operating practices, and whether or not the vapors
displaced from service station storage tanks (Stage I) were collected
in the tank truck. Therefore, it is recommended that the standard format
include equipment specifications and operating procedures as follows:
For top-submerged and bottom-fill (Alternatives I. II. and III)
1. The fill pipe is to extend to within 15 centimeters of the bottom
of the account truck during top-submerged filling operations. The fill
pipe is to extend to within 15 centimeters of the bottom of storage tanks
during gasoline filling operations. Any bottom fill is acceptable if the
inlet is flush with the tank bottom.
2. Gasoline is not to be spilled, discarded in sewers, or stored
in open containers or handled in any other manner that would result in
evaporation.
For balance system (Alternatives II and III)
1. Hatches of account trucks are not to be opened at any time
during loading operations.
2. There are to be no leaks in the tank trucks' pressure Vacuum
relief valves and hatch covers, nor truck tanks or storage tanks or
associated vapor return lines during loading or unloading operations.
3. Pressure relief valves on storage vessels and tank trucks are
to be set to release at the highest possible pressure (in accordance
with State or local fire codes, or the National Fire Prevention
Association guidelines).
6-2
-------
6.3 DETERMINING COMPLIANCE AND MONITORING
Determining compliance with Alternative I (bottom fill or top-submerged
fill) will require only visual inspection to ensure minimal spillage of
gasoline and proper installation of loading arm or bottom loading couples.
Compliance and monitoring procedures for Alternatives II and III
(balance system) will be published at a later date. Compliance procedures
under review include:
(1) Equipment specifications with qualitative leak checks using
an explosimeter or combustible gas indicator calibrated on a 0-100
percent LEL (lower explosive limit, pentane) range.
(2) A rough quantitative test wherein the volume of air/hydrocarbon
vented from the storage tank is measured and related to the volume of
gasoline transferred.
(3) A quantitative full-scale test of the system employing flow
meters and flame ionization detectors.
6-3
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
FPA-450/2-77-n35
2.
3. RECIPIENT'S ACCESSIOWNO.
4. TITLE AND SUBTITLE
Control of Volatile Organic
Gasoline Plants
Emissions From Bulk
5. REPORT DATE
Oerember. 1977
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Stephen A. Shedd,
Neil Efird, SASD
8. PERFORMING ORGANIZATION REPORT NO.
ESED
OAQPS No. 1.2-085
9. PERFORMING ORGANIZATION NAME AND AOORESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND AOORESS
13. TYPE OF REPORT AND P6RIOD COVERED
14. SPONSORING AGENCY CODE
13. SUPPLEMENTARY NOTES
16. ABSTRACT
This report provides the necessary guidance for development of
regulations to limit emissions of volatile organic compounds (VOC) from
gasoline bulk plants. This guidance includes emission estimates, costs,
environmental effects and enforcement; for the development of reasonable
available control technology (RACT).
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Regulatory Guidance
Gasoline Loading
Vapor Balancing
Hir Pollution Control
Stationary Sources
Drganic Vapors
18. DISTRIBUTIQN STATEMENT
Unlimited
19. SECURITY CLASS (This Report!
Unclassified
21. NO. OF PAGES
47
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 222O-1 (9-73)
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