903R83004
U.S. EPA Region III
Regional Center for Environmental
Information
1650 Arch Street (3PM52)
Philadelphia, PA 19103
VAPOR CONTROLS FOR
BARGE LOADING OF GASOLINE
by
PEDCo Environmental, Inc.
1006 N. Bowen Road
Arlington, Texas 76012
Contract No. 68-02-3512
Task Order No. 43
Project Officer
Eileen Glen
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION III
PHILADELPHIA, PENNSYLVANIA 19106
December 1983 ' > Fn-ircnmental
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CONTENTS
Figures iii
Tables iv
Summary v
1. Introduction 1
1.1 Sources and Amounts of Emissions 1
2. Emission Control Techniques 4
2.1 Refrigeration 4
2.2 Absorption 6
2.3 Incineration 8
2.4 Carbon Adsorption 10
2.5 Control System Reliability 10
3. Cost Analysis 13
3.1 Model Loading Rates 13
3.2 Assumptions 13
3.3 Capital Investment 14
3.4 Annual Operating Costs 14
3.5 Cost-Effectiveness 18
3.6 Economic Impact of Controls 18
4. Regulatory Analysis 20
4.1 Draft Regulation 20
4.2 Regulation in Other Areas 22
4.3 Fire and Explosion Hazards 23
4.4 Compliance and Monitoring Techniques 24
References 25
Appendices
A State of California Air Resources Board Resolution 78-59 A-l
B Santa Barbara County Air Pollution Control District Rule 327 B-l
C Compliance Test Method and Monitoring Techniques - Tank
Truck Loading Terminals EPA Report No. EPA-450/2-77-026 C-l
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FIGURES
Number Page
1 Refrigeration Vapor Recovery Unit 5
2 Absorption Vapor Recovery Units 7
3 Incineration Vapor Control Unit 9
4 Carbon Adsorption Unit 11
5 Barge-Mounted Refrigeration Vapor Recovery Unit 12
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TABLES
Number Page
1 VOC Emission Sources and Factors for Gasoline Barges 2
2 Capital Investment Costs for Gasoline Barge Loading Vapor
Control Systems 15
3 Annual Costs and Cost-Effectiveness for Vapor Control
Systems 16
4 Economic Effect of Gasoline Barge Vapor Control Systems
on Gasoline Prices 19
i v
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SUMMARY
Barges are commonly used for the bulk shipment of gasoline from coastal
refineries to metropolitan storage terminals. The loading of barges at refin-
eries is a source of uncontrolled volatile organic compound (VOC) emissions.
Vapor-control systems such as refrigeration, absorption, incineration, or
adsorption can be employed to reduce such emissions. Control efficiencies are
80 to 95 percent for refrigeration, 70 to 92 percent for absorption, 98 to 99
percent for incineration, and 99 percent for adsorption. The refrigeration,
absorption, and adsorption systems also recover gasoline, which makes these
control systems economically attractive.
Currently, one carbon adsorption unit is used for the loading of benzene
into barges and several are used for the unloading of gasoline from barges.
The barge loading operation is in Corpus Christi, Texas. The economic analy-
sis of costs indicates that carbon adsorption is a cost-effective VOC control
method. For carbon adsorption, the estimated credit is from $0.45 per 1000
gallons of gasoline loaded.
Currently, the only on-barge control system used is refrigeration. A
barge-mounted, refrigerated vapor control unit is being installed for crude
oil loading operations in Santa Barbara County, California, and will be in
operation in the near future. Santa Barbara County is the only area that
requires barge loading vapor controls. Economic analysis of projected costs
of gasoline truck loading at bulk terminals indicates that on-barge refrig-
eration is also cost-effective. For on-barge refrigeration, the estimated
credit is $0.10 cents per 1000 gallons of gasoline loaded. Costs of other
control methods vary up to $0.72 per 1000 gallons of gasoline loaded.
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1. INTRODUCTION
During the past several years, the Office of Air Quality Planning and
Standards (OAQPS) of the U.S. Environmental Protection Agency (EPA) has devel-
oped a series of Control Techniques Guidelines (CTGs) for volatile organic
compounds (VOC) to assist state and local agencies in developing regulations
for VOC control. Although the CTGs cover major VOC source categories from an
overall nationwide perspective, several VOC source categories that are not
covered by these CTG documents are major contributors to the ozone problem
within given areas.
Air pollution control agencies in the Philadelphia Air Quality Control
Region (AQCR) have asked for guidance in determining whether VOC controls are
available for non-CTG sources and for information to assist them in developing
appropriate regulations. One such VOC source is the loading of gasoline
barges.
1.1 SOURCES AND AMOUNTS OF EMISSIONS
The Philadelphia area is the site of several petroleum refineries and
also a transportation hub for shipping. Thus, the handling of petroleum
products such as gasoline is a potentially large source of VOC emissions in
the area. Barges are frequently used for intracoastal transport of gasoline.
Table 1 shows emission sources and factors for loading gasoline barges. The
range of hydrocarbon emission factors far exceeds the differences in emission
factors for inland waterway barges, ocean barges, and ships. The average
emission factors cited in AP-42 for ships and ocean barges are lower than for
inland waterway barges, but the average emission factor for barges falls into
all three ranges. Because most of the gasoline is for domestic use, it is
appropriate to use the inland waterways emission factors.
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TABLE 1. VOC EMISSION SOURCES AND
FACTORS FOR GASOLINE BARGES
Emission source
Barge condition
Emission factor
Barge loading
Barge transit
Cleaned and vapor-free
Uncleaned - dedicated
service
Average condition
Average
1.2 lb/103 gal transferred
4.0 lb/103 gal transferred
4.0 lb/103 gal transferred
3.0 Ib/wk per 103 gal
transferred
Emissions depend on the condition of the barge at the time of loading.
Barge breathing emissions during transit are relatively small when compared
with loading losses. In this document, an emission factor of 4.0 Ib per 1000
gallons of gasoline transferred was used because gasoline barges are normally
dedicated to one service and thus do not have to be cleaned after each load.
Gasoline barges range in capacity from 10,000 to 50,000 barrels. Accord-
ing to the literature, the average barge capacity is 20,000 barrels (840,000
gallons).2'3'4 Loading rates may vary from 1000 to 4200 gallons per minute
per barge.2'3'4 Thus, for an average 20,000-barrel barge, loading can take
from 3 to 14 hours.
Although facilities for gasoline barge loading are not standardized, they
do have features. Terminals are normally multipurpose facilities that are
adjacent to or part of a refinery, and they are owned by the refinery. The
docks where the barges are loaded may also be used by ships and are often used
to load other liquid petroleum products. It is assumed that the terminals use
submerged fill pipes for loading to avoid unnecessary splashing and to reduce
emissions. Because the docks use dedicated lines for various products, they
tend to be crowded with piping, valves, loading arms, and connecting hoses.
Crowding is particularly evident at older facilities where expansion has
encroached on available space. Unless the demand for a specific product is
very great, a dock usually is equipped to unload one barge at a time. It
might be possible to unload a kerosene barge and an unleaded gasoline barge
simultaneously, but not two unleaded gasoline barges.
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The gasoline loading pumps are normally in the storage tank farm area of
a refinery. To prevent mixing of leaded and unleaded gasoline stocks, separ-
ate storage and transfer facilities are used for each grade. After the barge
is moored at the dock for loading, the cargo loading hose is lifted into place
and bolted to the loading manifold and dock piping. The barge operator opens
the loading manifold valves and the barge compartment caps. Opening the
compartment caps permits release of displaced vapors and manual gauging of the
gasoline level. Loading is started by gravity feed to ensure that the valves
along the flow path are open. The loading pump is then started. As the com-
partment fills, manual gauging continues. When the compartment is almost
full, the barge operaion alerts the onshore operator to reduce the flow rate
and to begin shutting the valves in the supply line. When the shoreside
valves are closed, residual gasoline in the connecting line is drained to the
barge before it is disconnected. Gasoline and air are displaced through the
open hatch during filling. At the average gasoline loading rates, uncon-
trolled VOC emissions range from 480 to 960 Ib/h. Therefore, for a barge
loading terminal with an annual capacity of six million barrels per year, VOC
emissions may total 504 tons per year. Although some refineries considered
this information proprietary, a telephone survey of the refineries in the AQCR
found that barge usage ranged from zero to four million barrels per year.
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2. EMISSION CONTROL TECHNIQUES
Because a barge loading facility is similar in many respects to a bulk
terminal where gasoline trucks are loaded, the control methods will be simi-
lar, except that the systems must be much larger to accommodate the higher
gasoline transfer rates at barge loading facilities. Several systems could be
used to control VOC emissions from gasoline barge loading operations.
2.1 REFRIGERATION2
A refrigeration vapor-recovery system recovers displaced gasoline vapors
by condensation at cryogenic temperatures and atmospheric pressure. Figure 1
is a flow diagram of a refrigeration vapor-recovery system.
The vapors collected from the various gasoline-loading operations are
routed into one of two identical vapor-processing trains. A dehydrator first
cools the gasoline vapors to a temperature of 25° to 35°F by direct contact
with finned tube cooling coils. A major portion of the moisture and a small
portion of the heavier hydrocarbons in the vapors are condensed in the dehy-
drator. Vapors then flow from the dehydrator to the condenser, where they are
cooled to a temperature of -80° to -100°F and most of the remaining gasoline
vapors are condensed. Methane, which cannot be condensed at -100°F, is vented
from the condenser along with the treated air.
Water and oil condensates collected in the dehydrator are separated in a
gravity oil-water separator. The water is routed to wastewater treatment, and
the recovered organic material goes to storage. The product recovered by the
refrigeration vapor recovery unit is a mixture consisting mainly of propane,
butanes, and pentanes. Because of their high vapor pressures, these recovered
products must be stored and handled in closed pressurized systems. Recovered
product is pumped regularly from storage back to the refinery.
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1
GASOLINE
i DADINC M.
VAPORS
OIL-WATER
jLrAKAlOR
1
OIL/WATER''
CONDENSATE c^
DEHYDRATOR CONDENSER
25°F TO 35UF -80UF TO -10
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SEPARATION
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rnunruc«Tc ^UOTFB Tn nKPfKfil
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^ CONDENSED *" Tn RFFTNFRY
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ODUCT
•> VENTED ATP
GE
AT I ON
,, M. VFNTFD AIR
NSED
)UCT^^
^NfTFl^Fri ^. PRODUCT RETURNED
PRODUCT TO REFINERY
v^TORAGE^
Figure 1. Refrigeration vapor recovery unit.
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Refrigeration for the dehydrator and condenser is supplied by a two-stage
refrigeration unit. A large volume of cold coolant is stored in the system to
supply instantaneous cooling capacity on demand.
Two vapor-processing trains are used so that one train can be defrosted
without interruption of the vapor processing. The cold air vented from the
condenser creates a moisture plume in cold or humid weather. To avoid the
formation of plumes, some designs incorporate air reheat by the use of waste
heat from the refrigeration unit.
The control efficiency for this system is estimated to be 80 to 93 per-
cent.4 The efficiency varies according to the methane content of the vapor.
An average control efficiency for truck loading at bulk terminals is reported
to be 87 percent5; thus, we have used that figure to estimate the efficiency
of refrigeration control for barge loading.
2.2 ABSORPTION2
The absorption vapor-recovery unit absorbs hydrocarbons from gasoline
vapors into a lean oil stream from the refinery. Figure 2 presents two lean
oil absorption systems.
One proposed lean oil absorption system operates at low pressure and
ambient temperature. Gasoline-loading vapors are compressed to 20 psig by a
blower or liquid ring compressor. The compressed vapors then contact a lean-
oil stream in a packed-bed absorber, where hydrocarbons are absorbed by the
lean oil. Projected flow rates are 500 barrels/h of lean oil per 1000 acfm of
vapor. Purified air is vented from the absorber unless methane is present in
the vapors. Methane cannot be absorbed; it passes through the column and is
vented with the treated air.
The lean oil source is cat-cracker feed from the refinery. A one-month
supply of lean oil is stored at the vapor recovery site. Rich oil laden with
absorbed light hydrocarbons is recycled to the lean oil storage tanks until
the vapor pressure of the lean oil is too high for effective absorption. When
this occurs, the enriched oil is returned to the refinery, and the lean oil
storage tanks are replenished with fresh cat-cracker feed.
As a means of avoiding some of the potential safety problems associated
with blowers and compressors, a second type of lean oil absorption system has
been proposed, which uses air eductors for the primary motive force. Because
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air eductors produce a slight vacuum in the lean oil absorber, effective
absorption requires low temperatures. The lean oil is cooled to 40°F by
refrigeration. Lean oil flow rates for the refrigerated absorption vapor
recovery unit have been estimated at 200 barrels/n per 1000 acfm vapor.
Some absorber designs call for constant lean oil flow rates that exceed
the flow rate required for effective hydrocarbon recovery at maximum loading
rates. Other absorber designs include instrumentation and control systems for
regulating lean oil flow rates with demand to conserve energy.
The efficiency of this control system (71 to 92 percent5) is a function
of the amount of methane in the gasoline vapors. A system efficiency of 87
percent, based on tank truck operations,5 was used for the evaluations.
2.3 INCINERATION2
The incineration vapor-control unit eliminates gasoline loading vapors by
burning them. The flow diagram of a typical incineration vapor-control unit
is shown in Figure 3.
Gasoline vapors from marine loading operations are drawn through a flame
arrester and a saturator. In the saturator, gasoline vapors are enriched with
hydrocarbons through contact with recirculating gasoline product so that the
vapor concentration exceeds the upper explosive limit. Some systems use
propane instead of gasoline as the enrichment source.
The enriched or saturated vapor is conveyed by blower to a knockout drum,
where condensates are allowed to settle. From the knockout drum, the gasoline
vapors enter an incinerator or flare after passing through a water seal. In
the incinerator or flare, combustion air is mixed with the gasoline vapors to
bring them back into the combustible range before they are burned.
Incinerators require sophisticated instrumentation and control systems
for maintenance of proper fuel-to-air ratios for all gasoline vapor flow rates
and concentrations. Most incineration units are equipped with oxygen analy-
zers, hydrocarbon analyzers, and temperature sensors for the control of satur-
ator operation and combustion air flow rates.
The efficiency of incinerators for the control of gasoline loading vapors
is well over 99 percent. Hydrocarbon concentrations in the flue gas vented
from incineration units are well below I percent by volume. We have used a 99
percent efficiency for our incinerator evaluation.
8
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2.4 CARBON ADSORPTION6
Gasoline loading vapors are adsorbed on activated carbon and are removed
from the carbon by vacuum stripping. The gasoline vapors are recovered by
absorption in gasoline from the bulk storage tank. The adsorber has two
carbon beds. During operation, one bed is loaded while the other bed is being
stripped. The carbon adsorption unit currently in use for benzene loading has
a capacity in excess of 7100 barrels/h. The units used in barge unloading of
gasoline have capacities ranging between 2840 to 7100 barrels/h. The units
are shore-mounted and can be used for the unloading of any type of vessel.
The system manufacturer chose vacuum stripping in preference to steam strip-
ping because it eliminates the need for stainless steel construction in the
recovery system. Figure 4 is a flow diagram of the unit.
The manufacturer warrants 97.5 percent recovery of gasoline vapor, but
claims that better than 99 percent recovery is obtained. The systems current-
ly in use are working well. Maximum VOC emissions have been 30 milligrams per
liter loaded, whereas the EPA standard is a maximum of 35 milligrams per liter
(personal communication from D. Buxton, McGill, Inc., November 30, 1983).
2.5 CONTROL SYSTEM RELIABILITY
All of the control systems discussed have been successfully used and
tested in tank-truck gasoline-loading terminals.5 Except for the carbon
adsorption unit, none has been used to control gasoline vapors from barges. A
skid-mounted refrigeration unit has recently been installed on a barge in
Santa Barbara to condense VOC from crude oil loading. Although it has not yet
been operated, the refrigeration unit is guaranteed to operate at a minimum
efficiency of 90 'percent (personal communication from J. English, Santa Bar-
bara County Air Pollution Control Board, December 1, 1982). The manufacturer
states that 95 to 99 percent VOC recovery will be realized at vapor concentra-
tions ranging from 5 to 20 volume percent (personal communication from
B. Collett, Chapman Engineering Company, December 6, 1982). Figure 5 is a
drawing of this control system.
10
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AIR
VENT
CARBON
ADSORPTION
BEDS
INLET
VAPOR
AIR RECYCLE
VACUUM PUMP
GASOLINE
SUDPLY
PU'.'P
ABSORBER
SEPARATOR
FUf.'P
GASOLINE
RETURN
Figure 4. Carbon adsorption unit.
11
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3. COST ANALYSIS
This section presents an economic analysis of vapor control systems for
gasoline barge loading.
3.1 MODEL LOADING RATES
Barge loading rates vary from 1000 to 4200 gallons per minute.2'4 Prac-
tice in the industry, however, is to state loading rates in terms of barrels
per hour. Since a petroleum barrel contains 42 gallons, the model plant
loading rates in barrels per hour are as follows:
Small terminal 1400 barrels/h for 1 barge berth
Medium terminal 3000 barrels/h for 1 barge berth
Large terminal 6000 barrels/h for 2 barge berths
Ship terminal loading rates, which are higher than those for barge termi-
nals, typically range from 5,000 to 10,000 barrels per hour.2
3.2 ASSUMPTIONS
The capital and annual operating costs for the vapor control systems are
based on several assumptions:
1. Model terminal sizes are representative of those in the Philadelphia
AQCR.
2. Barge terminal loading facilities are used 2000 hours per year.
Daily usage rates for barge terminals range from zero to 24 hours.
Terminals unload barges as quickly as possible to free the barges
for service. Two thousand hours per year is a conservative esti-
mate; however, if the utilization rate proved to be higher, the
already favorable economics for vapor recovery would be improved.
3. Cost data for vapor control systems at gasoline tank-truck loading
terminals can be used to project barge-loading vapor control costs;
4. Capital investment costs and operating costs can be updated to
September 1982 by use of the Plant Cost Index of Chemical Engineer-
ing magazine.
13
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5. Utility costs for the operation of each vapor control system can be
updated to September 1982 by use of the appropriate ratio of unit
costs from U.S. Department of Energy magazine, Monthly Energy Re-
view.
6. Annual credits for recovered gasoline are based on the September
1982 wholesale gasoline price.
3.3 CAPITAL INVESTMENT
The required investment for a vapor control system varies with the barge
loading rate, the physical layout of the barge terminal, and the type of vapor
recovery system. The costs in Table 2 for onshore installations include
equipment, piping, instrumentation, and all installation charges. They have
been developed from cost data for gasoline tank truck loading terminals and
vendor quotations8 (personal communication from D. Buxton, McGill, Inc.,
March 9, 1983). Site-specific requirements may cause actual costs to vary
from the cited figures by as much as 30 percent.
3.4 ANNUAL OPERATING COSTS
Table 3 presents the estimated annual costs for the various vapor control
systems. These costs include direct operating costs, capital recovery
charges, and gasoline recovery credits.
The direct operating costs include costs for utilities and system main-
tenance. Costs for utilities were based on the September 1982 commercial
rates of $0.0484/kWh7 for electricity and $3.28 per 1000 cubic feet2 for
natural gas. The power consumption was adjusted for refrigeration and absorp-
tion vapor-control systems and the fuel consumption of incineration systems at
gasoline tank-truck loading terminals to barge loading terminals by the ratio
of their loading rates.4 The power consumption for adsorption units was esti-
mated from the motor horsepower, and it was assumed that the absorption strip-
per would use the same power as an absorption recovery unit.
System maintenance costs were estimated as a percentage of the capital
investment costs: 3 percent for refrigeration, adsorption, and absorption
systems and 2 percent for incinerator systems5 (personal communication from
D. Buxton, McGill, Inc., March 9, 1983).
14
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TABLE 2. CAPITAL INVESTMENT COSTS FOR VAPOR
CONTROL SYSTEMS FOR GASOLINE BARGE LOADING
(September 1982 dollars)
Barge terminal Number of
loading rate, barge
barrels/h berths
A. Onshore installation
1400 1
3000 2
6000 2
B. On-barge installation
1400 1
Type of vapor control systemc
Refri-
geration
517,000
Absorp- Incinera- Adsorp-
tion tion tion
587,000 422,000
853,000 1,017,000 690,000
320,000
380,000
1,170,000 1,486,000 898,000 485,000
282,000
NOTES:
b
Investment costs include charges of $110,000 per barge for required vapor
collection equipment upon the barge (Reference 2).
Values agree within 20 percent with updated values developed by Pullman-
Kellogg, Inc. (Reference 4).
'Skid-mounted unit at a unit cost of $250,000 f.o.b. factory (personal com-
munication from B. Collett, Chapman Engineering Company, December 6, 1982).
15
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TABLE 3. ANNUAL COSTS AND
COST-EFFECTIVENESS OF VAPOR CONTROL SYSTEMS
(September 1982 dollars)
Barge loading rate, barrels/h
Refrigeration (Onshore)
1,400
3,000
6,000
b
No. barge berths
Control efficiency, percent
Controlled emissions, tons/yr
Gasoline recovered, 103 gal/yr
Annual costs
Utilities3
Maintenance
Capital charges"
Gasoline recovery credit1"
Net cost (credit)
Cost-effectiveness, $/ton
VOC controlled
Refrigeration (On-barge)
No. barge berths
Control efficiency, percent
Controlled emissions, tons/yr
Gasoline recovered, 103 gal/yr
Annual costs
Utilities6
Maintenance
Capital charges"
Gasoline recovery credit1"
Net cost (credit)
Cost-effectiveness, $/ton VOC
control led
Absorption
No. barge berths
Control efficiency, percent
Controlled emissions, tons/yr
Gasoline recovered, 103 gal/yr
Annual costs
Utilities3
Maintenance ,
Capital charges
Gasoline recovery credit
Net cost (credit)
Cost-effectiveness, $/ton
VOC controlled
b
1
87
204.6
73.2
11,900
15,500
88,600 ,
(76,100)
39,900
195
1
87
204.6
73.2
7,500
8,500
48,400 .
(76,100)
(11,700)
(57)
1
87
204.6
73.2
7,700
17,600
100,700 .
(76,100)°
49,900
2
87
438.5
156.9
25,500
25,600
146,300
(163,200)
34,200
78
2
87
438.5
156.9
16,600
30,500
174,400
(163,200)
58,300
2
87
877.0
313.8
51,200
35,100
200,600
(326,400)
(39,500)
(45)
2
87
877.0
313.8
33,100
44,600
254,800
(326,400)
6,100
244
133
16
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TABLE 3. (continued)
Inci neration
Barge loading rate, barrels/h
1,400
3,000
6,000
No. barge berths
Control efficiency, percent
Controlled emissions, tons/yr
Gasoline recovered, 103 gal/yr
Annual costs
Utilities3
Maintenance ,
Capital charges
Gasoline recovery credit
Net cost (credit)
Cost-effectiveness, $/ton
VOC controlled
Carbon Adsorption
No. barge berths
Control efficiency, percent
Controlled emissions, tons/yr
Gasoline recovered, 103 gal/yr
Annual costs
Utilities
Maintenance ,
Capital charges
Gasoline recovery credit
Net cost (credit)
Cost-effectiveness, $/ton
VOC controlled
c
1
99
232.8
Nil
4,400
8,400
72,400
Nil
85,200
366
1
99
232.8
83.3
11,700
9,600
54,900
(86,600)
(10,400)
2
99
499.0
Nil
9,500
13,800
118,300
Nil
141,600
284
2
99
499.0
178.5
22,600
11,400
65,200
(185,600)
(86,400)
2
99
997.9
Nil
19,000
18,000
154,000
Nil
191,000
191
2
99
997.9
357.1
45,000
14,600
83,200
(371,400)
(228,600)
(45)
(173)
(229)
Updated and adjusted costs based upon Reference 8.
k
Estimated as 17.147 percent of capital investment.
cGas-oline recovered is priced as $1.04 per gallon with a specific gravity of
0.67.
Parentheses indicate a financial credit.
£1
Personal communication from B. Collett, Chapman Engineering Company, Decem-
ber 6, 1982.
17
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Capital charges, which are the indirect costs associated with the opera-
tion of the various systems, include a capital recovery charge and an allow-
ance for property taxes, insurance, and administrative costs. The annual
capital recovery charge, based on a 15-year life2 and a 10 percent interest
rate, is 13.1 percent of the capital investment.8 The allowance for taxes,
insurance, and administrative costs is 4 percent of the capital investment.2
Gasoline recovery credits apply to the refrigeration, absorption, and
adsorption control -methods because these systems recover condensed gasoline
vapors. The gasoline credit was based on the September 1982 wholesale gaso-
line price of $1.04 per gallon (personal communication from-T. Elsass, Tresler
Products, Division of Ashland Oil Company, December 20, 1982). The gasoline
recovered is equal to the amount of gasoline controlled by the systems. No
gasoline recovery credits are involved with the use of incineration systems.
3.5 COST-EFFECTIVENESS
The cost-effectiveness of the control system is determined by dividing
the annual costs for each system by the annual amount of VOC removed. Table 3
shows that on-barge refrigeration and carbon adsorption have negative control
costs because credits for recovered gasoline are greater than the capital and
operating costs of the control system. Costs of the other control options
range from $7 to $366/ton of VOC controlled.
3.6 ECONOMIC IMPACT OF CONTROLS
The costs of installing and operating a vapor-control system for gasoline
barge loading would be passed on to consumers. The gasoline price increase
for each vapor control system was determined by dividing the annual operating
cost by the annual gasoline loading throughput. Table 4 shows a possible
nega'tive cost increase; however, the cost data developed and used in this cost
analysis are not based on actual operation of a barge-loading vapor-control
system. The main purpose of this financial analysis is to demonstrate the
technical and economic feasibility of vapor-control systems for such loading
operations. The operations of carbon adsorbers on gasoline barge loading and
the Santa Barbara on-barge refrigeration unit should be monitored to compare
actual performance with vendor claims.
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TABLE 4. ECONOMIC EFFECT ON USING VAPOR CONTROL
SYSTEMS DURING THE LOADING OF GASOLINE BARGES
Control system
Refrigeration
On-barge
Onshore
Absorption - onshore
Incineration - onshore
Adsorption - onshore
Annual volume3
loaded, 106 gal/yr
118
118
252
504
118
252
504
118
252
504
118
252
504
Annual cost, Sept.
1982 dollars
(ll,700)b
39,900
34,200
(39,800)
49,900
58,300
6,100
85,200
141,600
191,000
(10,400)
(86,400)
(228,600)
Added cost
(credit)
cents/103 gal
(10)
34
14
(8)
42
23
1
72
56
38
(9)
(34)
(45)
Annual volume based on 2000 hours operation.
Parentheses indicate a profit for system operation.
Based on average hydrocarbon emission factors for gasoline loading opera-
tions cited in AP-42,1 emissions per 1000 gallons of gasoline transferred are
lower for ships and ocean-going barges. Although potential hydrocarbon emis-
sions would be lower, the scale of operations would be greater. This would
allow the use of larger-capacity control devices. As shown in Table 3, this
would have a very favorable impact on the economics of control. For a barge
loading rate of 6000 barrrels/h, a negative annual control cost of $80,000
would result, even if the gasoline recovery credit were reduced by 49 percent.
(The average emission factor for ships is 60 percent of the average emission
factor for barges.) It might also be feasible to use an adsorber with a
larger loading capacity, which would improve the economics.
19
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4. REGULATORY ANALYSIS
This section contains a proposed draft regulation for VOC controls at
barge gasoline-loading terminals, a discussion of compliance monitoring tech-
niques, and a description of potential problem areas.
4.1 DRAFT REGULATION
The draft regulation on VOC control of barge gasoline-loading terminals
in the Philadelphia AQCR is as follows:
CONTROL OF EVAPORATIVE LOSSES FROM THE LOADING OF GASOLINE BARGES
A. Definitions
1. "Barge" means any tank vessel not equipped with means of self-
propulsion.
2. "Marine terminal" means all permanent facilities used in whole or in
part to load gasoline into cargo vessels for bulk transport.
B. Applicability
The provisions of this Regulation shall apply to the loading of gasoline
into barges from any marine terminal.
C. Coast Guard Rules
Nothing in this Regulation shall be construed as superseding or conflict-
ing with applicable United States Coast Guard regulations. Any person who
believes that any provision of this Federal rule supersedes or conflicts with
United States Coast Guard Regulations shall submit documentation to the Con-
trol Officer a minimum of 60 days prior to the scheduled compliance date for
that provision.
D. Emissions From Loading Gasoline
1. No person shall cause or allow the loading of gasoline into gasoline
barges from any marine terminal unless the gasoline vapors displaced
20
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from the barge during loading are directed to a system where at
least 80 percent by weight of the organic compounds in the vapor are
recovered or destroyed.
2. The owner or operator of any marine terminal used to load gasoline
into gasoline barges, or the owner or operator of such vessel, shall
demonstrate to the satisfaction of the Control Officer, by emission
tests, engineering evaluations, or other means of reasonable preci-
sion and accuracy that:
a. The control practices or equipment selected to achieve compli-
ance will reduce the organic compounds in the vapor to the
extent required by section D.I; and
b. There is a reliable method for determining the effectiveness of
such control practices or equipment on a routine basis.
E. Recordkeeping
1. The owner or operator of any marine terminal shall keep operating records
regarding the gasoline barge loading activities for that terminal. These
records shall be maintained at the respective marine terminals and shall
be made available to the Control Officer upon request. They shall in-
clude, but are not limited to:
a. The dates for each loading event, the identification of the barge
being loaded, the company immediately responsible for the operation
of the barge, and the legal owner of the barge;
b. The amount of gasoline loaded into each barge; and
c. A written document, signed by both the person responsible for the
operation of the barge and the person responsible for the operation
of the marine terminal, attesting to the fact that their respective
portions of the organic vapor control system, as required by section
D.I of this regulation, were operated as designed during each load-
ing event.
F. Compliance Schedule
1. Any owner or operator subject to the provisions of this Regulation
shall comply with the following increments of progress following
adoption of the Regulation and promulgation of safety criteria for
organic vapor control systems by the United States Coast Guard:
a. Within 12 months, submit final control system plans to the
United States Coast Guard for approval.
b. Within 24 months, submit to the Control Officer a final system
control plan that describes the steps that will be taken to
achieve compliance with the provisions of this regulation.
Such plans shall include specific statements that:
21
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1. All barges loaded from the terminal shall have a designed
system that is compatible with that of the terminal;
2. The barge operators are aware of the design and operation-
al requirements of the marine terminal; and
3. Terminal operators will not service a barge that is in-
compatible with the recovery system.
c. Within 30 months, negotiate and sign all necessary contracts or
issue purchase orders for securing an emission control system.
The proposed equipment installation schedule shall be provided
to the Control Officer at this time.
d. Within 54 months, complete installation of emission control
equipment.
e. By July 1, 1987, assure final compliance with the provisions of
this Regulation.
2. Nonavailability of specific emission control equipment or of a
specific emission control system or a specific method for achieving
compliance with any provision of this regulation shall not consti-
tute relief from such provision if other types of control equipment,
systems, or methods acceptable to the control officer are available.
3. Any gasoline barge or marine terminal operating after July 1, 1987,
shall be operated in full compliance with the provisions of this
Regulation.
4.2 REGULATION IN OTHER AREAS
Recognizing the need for reducing VOC emissions from marine vessels, the
California Air Resources Board passed resolution 78-59 on November 16, 1978.
This resolution is attached as Appendix A.
In 1978, Santa Barbara County, California, adopted Rule 327 to regulate
VOC emissions from marine vessels. The current rule, presented in Appendix B,
establishes a schedule requiring final compliance with emission regulations by
July 1, 1985. As of now, with only 2h years remaining to achieve compliance,
no control systems other than the barge-mounted refrigeration unit have been
planned. In light of this deadline, the control agencies in California expect
that the affected companies to be submitting control system applications in
the near future (personal communication from J. English, Santa Barbara County
Air Pollution Control Board, December 1, 1982).
22
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The U.S. Coast Guard requires an inert gas blanketing system for a self-
propelled vessel with a dead weight displacement, of 20,000 tons (or greater)
and built after 1979. The vessel also must have a high-capacity washing
machine for cleaning products off the sides of the vessel. The Coast Guard
has no requirement, however, for an inert gas system for either a carbon
adsorber or a loading/unloading system. According to a personal communication
from Petty Officer Dillon, U.S. Coast Guard, on September 27, 1983, the inert
gas blanketing requirement does not apply to barges in any location.
Coast Guard regulations state that all barges must be inspected every two
years. The applicable regulations are published in the Code of Federal Regu-
lations. The citations are:
1. For manned barges, 33 CFR §§155-156; 46 CFR §§30-40; and
2. For unmanned barges, 46 CFR §151.
4.3 FIRE AND EXPLOSION HAZARDS
As for any installation handling gasoline, safeguards are required to
prevent fires and explosions from occurring either on the barge or in the on-
shore vapor control units. Because vapor concentrations may be in the explo-
sion range for gasoline, special system requirements must be met to prevent
static electricity discharges and sparking. Those special requirements in-
clude:
1. Explosion-proof electric equipment and wiring;
2. Spark-proof blowers or conductors; and
3. Equipment grounding devices.
The spread of fire from barge to terminal or terminal to barge must be
guarded against by flame arresters and water seal drums for isolation of
system components.
Provisions of the safety criteria established by the U.S. Coast Guard
will govern the design of any vapor control system that is used.
23
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4.4 COMPLIANCE AND MONITORING TECHNIQUES
Manufacturer certification for barge vapor control systems is the pre-
ferred compliance demonstration technique. This certification could be based
on the performance of similar systems at gasoline tank-truck loading termi-
nals. According to the carbon adsorber manufacturer (personal communication
from D. Buxton, McGill, Inc., March 23, 1983), cited recovery efficiencies for
this document are based on emission test results on 10 operating units.
Because only two systems (out of 330) are used for barge vapor recovery, the
manufacturer considers operating characteristics to be nearly identical for
tank truck and barge loading terminals. Hence, system efficiencies are inter-
changeable for the two applications. These compliance techniques are pre-
sented in Appendix C and can be suitably modified for use in controlling
emissions from gasoline barge loading.
24
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REFERENCES
1. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emis-
sion Factors. AP-42, July 1979. pp. 4.4-7 and 4.4-10.
2. Burklin, C. E., et al. Background Information on Hydrocarbon Emissions
From Marine Terminal Operations, Volume 1. EPA-450/3-76-038a, 1976.
3. Engineering Science, Inc. Summary of Technical Information for Selected
Volatile Organic Compound Source Categories. Arcadia, California.
EPA-400/3-81-007, May 1981. p. 4-3.
4. Gee, D., and W. M. Talbert. Control Technology Evaluation for Gasoline
Loading of Barges. EPA-600/2-79-069, March 1979.
5. U.S. Environmental Protection Agency. Control of Hydrocarbons from Tank
Truck Gasoline Loading Terminals. Emission Standards and Engineering
Division, Chemical and Petroleum Branch, Research Triangle Park, North
Carolina. EPA-450/2-77-026, October 1977.
6. McGill, Inc. The McGill Adsorption/Absorption Gasoline Vapor Recovery
System. Sales brochure. Tulsa, Oklahoma. 1980.
7. U.S. Department of Energy. Monthly Energy Review, July 1982, p. 90.
8. Neveril, R. B. Capital and Operating Costs of Selected Air Pollution
Control Systems. EPA-450/5-80-002, December 1978.
25
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APPENDIX A
STATE OF CALIFORNIA AIR
RESOURCES BOARD RESOLUTION 78-59
A-l
-------
Resolution 78-59
November 16, 1978
WHEREAS, marine vessel operations in California Coastal Waters
account for substantial quantities of air pollutants;
WHEREAS, the California Health and Safety Code and the federal
Clean Air Act Amendments of 1977 require extraordinary efforts
to achieve the state and federal ambient air quality standards
throughout California;
WHEREAS, the California Air Resources Board recognizes the need
to reduce air pollution in a cost-effective fashion that will
minimize economic hardships;
NOW, THEREFORE, BE IT RESOLVED, that the Air Resources Board
adopts in principle the Model Rule for the Control of Sulfur
Oxides and Organic Ga-s Emissions from Marine Vessel Operations;
BE IT FURTHER RESOLVED, that the Board instructs its staff to
schedule a formal Workshop no later than March 1979 to examine
remaining technical and economic questions concerning the Model
Rule;
BE IT FURTHER RESOLVED, that the Board instructs the staff to
modify the rule to specifically:
(1) Provide that U.S.-flag vessels will not suffer undue
discrimination;
(2) insure that normal bunker operations will not be
subject to the vapor recovery requirements of the Rule;
(3) eliminate any portions of the Rule which would put
California ports at a significant er .iomic disadvantage
when compared to other west coast ports;
(4) assure that any systems used for emissions control
will not jeopardize vessel safety;
BE IT FURTHER RESOLVED, that the Board directs the staff to
determine the availability and cost of low-sulfur bunker fuel;
BE IT FURTHER RESOLVED, that the Board instructs the Executive
Officer, following the formal Workshop, to reschedule considera-
tion of the Model Rule before the Board.
-------
BE IT FURTHER RESOLVED, that the Board instructs the Executive
Officer to confer with the U.S. Environmental Protection Agency,
U.S. Coast Guard, International Marine Consultive Organization
and other appropriate organizations to determine whether an
acceptable international control program can be developed in
lieu of the proposed Model Rule.
I certify that the above is a true
and correct copy of Resolution 78-59
as passed by the Air Resources Board.
-------
APPENDIX B
SANTA BARBARA COUNTY AIR
POLLUTION CONTROL DISTRICT RULE 327
3-1
-------
RULE 327. ORGANIC LIQUID CARGO VESSEL LOADING.
A. Definitions.
1. "Barge" means any tank vessel not equipped
with means of self-propulsion.
2. "Marine Terminal" means all permanent facilities
used in whole or in part to load organic liquid cargo into
organic liquid cargo vessels, excepting existing barge
loading facilities as long as their annual throughput, as
cf the adoption of this Ruler does not increase.
3. "Organic Liquid Cargo" means organic liquid
loaded into a vessel to be transported from one location
:o another location as a commodity.
4. "Organic Liquid Cargo Vessel" means any tanker,
freighter, barge, vessel, boat or ship used for the bulk
•.ransport of more than 250 barrels of organic liquid cargo.
B. Applicability,
The provisions of this Rule shall apply to the loading
*i organic liquid cargo into organic liquid cargo vessels
•res any marine terminal.
C. Coast Guard Rules.
Nothing in this Rule shall be construed as superseding
'" "-nflicting with United States Coast Guard Regulations.
Irt-r -
'• j-erson who believes that any provision of this Rule super-
•.., •
~*3 °r conflicts with United States Coast Guard Regulations
"*•- submit documentation to the Control Officer a minimum
,» ,
'• cays prior to the scheduled compliance date for that
-338-
-------
D. Emissions from Loading Organic Liquid.
1. No person shall load or allow the loading of
organic liquid cargo into any organic liquid cargo vessel
from any marine terminal unless the weight of non-methane
organic vapors emitted during loading is reduced by the
application of the best control technology available at the
time specified in the final control plan submitted to the
Control Officer. ';
i*
2. The owner or operator of any marine terminal
used to load any organic liquid cargo into any organic liquid
cargo vessel, or the owner or operator of such vessel, shall
- ,<-
" v "-
demonstrate, to the satisfaction of the Control Officer, by
en-ission tests, engineering evaluation, or other means of
reasonable precision and accuracy that: "*,
a. The control practices or equipment selected
to achieve compliance will reduce the organic vapor emission*
to the extent required by section B.I; and
b. There is a reliable methodology for deters-ia"
ing the effectiveness of such control practices or equipment
.: ;*£;.' :r-
on a routine basis. "~t""•-'
^f-.?'-.''•
E. Record Keeping.
1. The owner or operator of any marine terminal
shall keep operating records regarding the loading ac
for that terminal. These records shall be maintained at
respective marine terminals and shall be made available to
the Control Officer upon request. These records shall
but are not limited to: ,
-339-
-------
a. The date(s) of each loading event, the name
of the vessel being loaded, the company immediately responsible
for the operation of the vessel and the legal owner of the
vessel;
b. The type and amount of organic liquid cargo
loaded into each vessel; and
~"~ c. A written document signed by both the person
responsible for the operation of the vessel and the person
responsible for the operation of the marine terminal which
attests to the fact that their respective portions of the
organic vapor control system, required by section B.I of this
Pule, was operating as designed during each loading event.
F. Compliance Schedule.
1. Any owner or operator subject to the provisions
of this Rule shall comply with the following increments of
progress following the promulgation of safety criteria for
organic vapor emission control systems by the United States
Coast Guard,
a. Within 12 months - submit final control
system plans to the United States Coast Guard for approval.
b. Within 24 months - submit a final control
plan which describes the steps that will be taken to achieve
compliance with the provisions of this Rule to the Control
Officer. Such control plans shall include specific informa-
tional statements that:
1) All vessels loading through this terminal
shall have a designed system which is compatible with that of
the terminal; and
-340-
-------
2) The vessel operators are aware of the
design and operational requirements of the marine terminal;
and
3) Terminal operators will not service a
vessel which is not compatible with their recovery system.
c. Within 30 months - negotiate and sign all
necessary contracts for emission control systems or issue
orders for the purchase of component parts to accomplish
emission control. The proposed schedule of equipment installa-
tion by vessel name and terminal location shall be provided
. w
to the Control Officer at this time.
d. Within 54 months - complete construction or
installation of emission control equipment.
e. By July 1, 1985 assure final compliance
with the provisions of this Rule.
2. The non-availability of specific emission control
equipment or of a specific emission control system or method
to be used for the purpose of achieving compliance with any
provision of this Rule shall not constitute relief from such
1 *,
provision if other types of emission control equipment,
systems, or methods acceptable to the Control Officer arc-
available.
3. Any organic liquid cargo vessel or marine term-
inal, operating after July 1, 1985, shall be operated in *a**
compliance with the provisions of this Rule.
-341-
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APPENDIX C
COMPLIANCE TEST METHOD AND MONITORING
TECHNIQUES - TANK TRUCK LOADING TERMINALS
EPA REPORT NO. EPA-450/2-77-026
C-l
-------
6.0 COMPLIANCE TEST METHOD AND MONITORING TECHNIQUES
6.1 COMPLIANCE TEST METHOD
The recommended compliance test method as detailed in Appendix A
can be used to determine emissions from bulk terminal gasoline vapor control
equipment under conditions of loading leak-free tank trucks and trailers,
and leak-free operation of the vapor collection arid processing systems.
Direct measurements of volume and concentration of vapor processor emissions
are made to calculate the total mass of vented hydrocarbons. This total
mass emitted is divided by the total volume of liquid gasoline loaded
during the test period to determine the mass emission factor.
To insure that the vapor collection and processor are operating under
leak-free conditions, qualitative monitoring should be conducted using a
combustible gas indicator to indicate any leakage from the tank truck or
trailer carqo compartments and all equipment associated with the control
system. Any incidence of direct hydrocarbon leakage would indicate that
corrective actions are required prior to further compliance testing.
The test period specification is intended to allow inclusion of the
typical daily variation in loading frequency in each repetition and three
repetitions are specified in order to include the normal day-to-day variations
in loading frequency.
For terminals employing intermittent vapor processing systems, each
test repetition must include at least one fully automatic operating cycle
of the vapor processing unit.
6-1
-------
This procedure is applicable to determining hydrocarbon emission
rates from systems serving tank truck or trailer loading only. For
those facilities employing a single control system to process vapors
generated from both tank truck and trailer loading and fixed roof
storage tank filling, no storage tank filling may occur during the
duration of test repetition.
Source testing may not be required after initial compliance
testing or if preconstruction review indicates the equipment will
achieve compliance. In such cases, the performance parameters of the
vapor control system would be checked and compared with compliance
tests of other installations using the same system design.
6.2 MONITORING TECHNIQUES
The vapor collection system and associated vapor control
equipment must be designed so that under maximum instantaneous loading
rates, the tank truck pressure relief valves will not vent.
An intermittent monitoring approach is recommended. In this
type of program, a portable hydrocarbon analyzer would be used to
determine the processing unit exhaust hydrocarbon concentration and a
combustible gas indicator would be used to detect any incidence of leaks
from the cargo tanks and vapor collection lines at specified intervals.
Such a procedure would require the establishment of a control
equipment exhaust concentration level at which the compliance with a
mass emission factor regulation is assured.
6-2
-------
There are currently available instruments that have a dual range of
0-100 percent LEL and 0-100 percent by volume of hydrocarbons as propane.
The cost of this type instrument is approximately $500. A disadvantage
of this type instrument is that the accuracy of the measurements at 4 to 5
percent hydrocarbon level is about +_ 20 percent. This may not provide
the precision necessary to differentiate between complying and non-
complying operation. It would, however, detect gross deviations from
design operation. An additional disadvantage is that comparative
calibrations would be necessary to relate the monitoring results to the
reference test procedure concentration measurements.
Portable hydrocarbon analyzers based on FID or NDIR principles are
also available at costs ranging from $1500-$4000. These instruments
have the advantage of being the most precise measurement techniques
available. Also, since these techniques are used for hydrocarbon
measurements in the reference procedure, no comparative testing is
necessary to establish relative accuracy of the monitoring technique.
For leak monitoring alone, many versions of combustible gas
indicators with 0-100 percent LEL spans are available. The cost of this
type of unit would range from $200 to $500 depending on the particular
vendor and instrument features.
In addition to the use of instruments monitoring control equipment
process variables ( principally temperature and pressure) can give a good
indication of performance. The primary variables of interest and the
approximate values that would indicate acceptable performance are listed
on page 3-1.
6-3
-------
6.3 AFFECTED FACILITY
In developing terminal regulations, it is suggested that the
affected facility be defined as the tank truck gasoline loading
stations and appurtenant equipment necessary to load the tank truck
compartments.
6.4 STANDARD FORMAT
It is recommended that the following provisions be written
into the tank truck gasoline terminal loading regulations.
1. Gasoline is not to be discarded in sewers or stored in
open containers or handled in any other manner that would result
in evaporation.
2. The allowable mass emissions of hydrocarbons from control
equipment are to be 80 milligrams per liter or less of gasoline
loaded.
3. Pressure in the vapor collection lines should not exceed
tank truck pressure relief valve settings.
Test procedures for determining allowable hydrocarbon
emissions are detailed in Appendix A.
6-4
-------
APPENDIX A
A.I EMISSION TEST PROCEDURE FOR TANK TRUCK GASOLINE LOADING TERMINALS
Hydrocarbon mass emissions are determined directly using flow meters
and hydrocarbon analysers. The volume of liquid gasoline dispensed is
determined by calculation based on the metered quantity of gasoline at the
loading rack. Test results are expressed in milligrams of hydrocarbons
emitted per liter of gasoline transferred.
A.2 APPLICABILITY
This method is applicable to determining hydrocarbon emission rates
at tank truck gasoline loading terminals employing vapor balance collection
systems and either continuous or intermittent vapor processing devices.
This method is applicable to motor tank truck and trailer loading only.
A.3 DEFINITIONS
3.1 Tank Truck Gasoline Terminal
A primary distribution point for delivering gasoline to bulk plants,
service stations, and other distribution points, where the total gasoline
throughput is greater than 76,000 liters/day.
3.2 Loading Rack
An aggregation or combination of gasoline loading equipment arranged
so that all loading outlets in the combination can be connected to a tank
truck or trailer parked in a specified loading space.
3.3 Vapor Balance Collection System
A-'
-------
A vapor transport system which uses direct displacement by the liquid
loaded to force vapors from the tank truck or trailer into the recovery
system.
3.4 Continuous Vapor Processing Device
A hydrocarbon vapor control system that treats vapors from tank trucks
or trailers on a demand basis without intermediate accumulation.
3.5 Intermittent Vapor Processing_Deyice
A hydrocarbon vapor control system that employs an intermediate vapor
holder to accumulate recovered vapors from tank trucks or trailers. The
processing unit treats the accumulated vapors only during automatically
controlled cycles.
A.4 SUMMARY OF THE METHOD
This method describes the test conditions and test procedures to be
followed in determining the emissions from systems installed to control
hydrocarbon vapors resulting from tank truck and trailer loading operations
at bulk terminals. Under this procedure, direct measurements are made to
calculate the hydrocarbon mass exhausted from the vapor processing equipment.
All possible sources of leaks are qualitatively checked to insure that no
unprocessed vapors are emitted to the atmosphere. The results are expressed
in terms of mass hydrocarbons emitted per unit volume of gasoline transferred.
Emissions are determined on a total hydrocarbon basis. If methane is present
in the vapors returned from the tank trucks or trailers, provisions are
included for conversion to a total non-methane hydrocarbon basis.
A.5 TEST SCOPE AND CONDITIONS APPLICABLE TO TEST
5.1 Test Period
The elapsed time during which the test is performed shall not be less
A-2
-------
than three 8-hour test repetitions.
5.2 Terminal Status During Test Period
The test procedure is designed to measure control system performance
under conditions of normal operation. Normal operation will vary from
terminal-to-terminal and from day-to-day. Therefore, no specific criteria
can be set forth to define normal operation. The following guidelines are
provided to assist in determining normal operation.
5.2.1 Closing of Loading Racks
During the test period, all loading racks shall be open for each product
line which is controlled by the system under test. Simultaneous use of more
than one loading rack shall occur to the extent that such use would normally
occur.
5.2.2 Simultaneous use of more than one dispenser on each loading rack
shall occur to the extent that such use would normally occur.
5.2.3 Dispensing rates shall be set at the maximum rate at which the
equipment is designed to be operated. Automatic product dispensers are
to be used according to normal operating practices.
5.3 Vapor Control System Status During Tests
Applicable operating parameters shall be monitored to demonstrate that
the processing unit is operating at design levels. For intermittent vapor
processing units employing a vapor holder, each test repetition shall include
at least one fully automatic operation cycle of the vapor holder and processing
device. Tank trucks shall be essentially leak free as determined by EPA Mobile
Source Enforcement Division.
A.6 BASIC MEASUREMENTS AND EQUIPMENT REQUIRED
6.1 Basic measurements required for evaluation of emissions' from gasoline
bulk loading terminals are described below. The various sampling points
A-3
-------
are numbered in Figure 1.
Sample Point Measurements Necessary
1. Gasoline dispensers - Amount dispensed
2. Vapor Return Line - Leak check all fittings
3. Processing unit exhaust - Temperature of vapors exhausted
- Press.of vapors exhausted
- Volume of vapors exhausted
- HC concentration of vapors
*
- Gas chromatograph analysis of HC
- Leak check all fittings and vents
6.2 The equipment required for the basic measurements are listed below:
Sample_Point Equipment and Specifications
2 1 portable combustible gas detector,
(0-100% LEL)
3 1 flexible thermocouple with recorder
1 gas volume meter, appropriately sized
for exhaust flow rate and range
1 total hydrocarbon analyzer with recorder;
(FID or NDIR type, equipped to read out
0-10% by volume hydrocarbons as propane
for vapor recovery processing device; or,
0-10,000 ppmv HC as propane for incin-
eration processing devices)
1 portable combustible gas detector (0-100%
LEL)
Miscellaneous 1 barometer
1 GC/FID w^olumn to separate C, - C-,
alkanes
*
Required if methane is present in recovered vapors
•*
Required if methane is present in recovered vapors or if incineration is
the vapor processing technique.
A-4
-------
A.7 TEST PROCEDURES
7.1 Preparation for testing includes:
7.1.1 Install an appropriately sized gas meter on the exhaust vent of
the vapor processing device. A gas volume meter can be used at the exhaust
of most vapor recovery processing devices. For those where size restrictions
preclude the use of a volume meter; or when incineration is used for vapor
processing, a gas flow rate meter (orifice, pitot tube annubar, etc.) is
necessary. At the meter inlet, install a thermocouple with recorder. Install
a tap at the volume meter outlet. Attach a sample line for a total hydro-
carbon analyzer (0-10% as propane) to this tap. If the meter pressure is
different than barometric pressure, install a second tap at the meter outlet
and attach an appropriate manometer for pressure measurement. If methane
analysis is required, install a third tap for connection to a constant volume
*
sample pump/evacuated bag assembly.
7.1.2 Calibrate and span all instruments as outlined in Section 9.
7.2 Measurements and data required for evaluating the system emissions
include:
7.2.1 At the beginning and end of each test repetition, record the volume
readings on each product dispenser on each loading rack served by the system
under test.
7.2.2 At the beginning of each test repetition and each two hours thereafter,
record the ambient temperature and the barometric pressure.
7.2.3 For intermittent processing units employing a vapor holder, the unit
shall be manually started and allowed to process vapors in the holder until
the lower automatic cut-off is reached. This cycle should be performed
immediately prior to the beginning of the test repetition before reading in
7.2.1 are taken. No loading shall be in progress during this manual cycle.
Described in Method 3, Federal Register, V36, n247, December 23, 1971.
A-5
-------
7 2.4 For each cycle of the processing unit during each test repetition,
record the processor start and stop time, the initial and final gas meter
readings, and the average vapor temperature, pressure and hydrocarbon
concentration. If a flow rate meter is used, record flow meter readouts
continuously during the cycle. If required, extract a sample continuously
during each cycle for chromatographic analysis for specific hydrocarbons.
7.2.5 For each tank truck or trailer loading during the test period, check
all fittings and seals on the tanker compartments with the combustible gas
detector. Record the maximum combustible gas reading for any incidents of
leakage of hydrocarbon vapors. Explore the entire periphery of the potential
ieak source with the sample hose inlet 1 cm away from the interface.
7.2.6 During each test period, monitor all possible sources of leaks in
the vapor collection and processing system with the combustible gas indicator,
Record the location and combustible gas reading for any incidents of leakage.
7.2.7 For intermittent systems, the processing unit shall be manually
started and allowed to process vapors in the holder until the lower automatic
shut-off is reached at the end of each test repetition. Record the data in
7.2.4 for this manual cycle. No loading shall be in progress during this
manual cycle.
A.8 CALCULATIONS
8.1 Terminology
T = Ambient temperature (°C)
a
P, = Barometric pressure (mm Hg)
= Total volume of liquid dispensed from all controlled
racks during the test period (liters)
V
= Volume of air-hydrocarbon mixture exhausted from the
processing unit (M )
A-6
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V = Normalized volume of air-hydrocarbon mixture exhausted,
es NM3 @ 20°C, 760 mmHg
C = Volume fraction of hydrocarbons in exhausted mixture
(volume % as C3H,Q/100, corrected for methane content
if required
T - Temperature at processing unit exhaust (°C)
Pe = Pressure at processing unit exhaust (mm Hg abs)
(M/L) = Mass of hydrocarbons exhausted from the processing unit
per volume of liquid loaded, (mg/1 )
8.2 Processing Unit Emissions
Calculate the following results for each period of processing unit
operation:
8.2.1 Volume of air-hydrocarbon mixture exhausted from the processing
unit:
Ve = Vef - Ve.,or (m3)
V = totalized volume from flow rate and time records.
8.2.2 Normalized volume of exhausted mixture:
V = (0.3858 °K/mmHg) VePe NM3 @ 20°C, 760 mmHg
es Te* 273.2
8.2.3 Mass of hydrocarbons exhausted from the processing unit:
'
mgC3H8 ( }
8.3 Average Processing Unit Emissions
8.3.1 Average mass of hydrocarbons emitted per volume of gasoline loaded:
(M/L)_ = ^ (mg/liter)
~Lt
A. 9 CALIBRATIONS
9.1 Flow Meters
Use standard methods and equipment which have been approved by the
A-7
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Administrator to calibrate the gas meters.
9.2 Temperature^ Recording Instruments
Calibrate prior to the test period and following the test period using
an ice bath (0°C) and a known reference temperature source of about 35°C.
Baily during the test period, use an accurate reference to measure the
ambient temperature and compare the ambient temperature reading of all
other instruments to this value.
9.3 Total hydrocarbon analyzer
Follow the manufacturer's instructions concerning warm-up and adjust-
ments. Prior to and immediately after the emission test, perform a
comprehensive laboratory calibration on each analyzer used. Calibration
gases should be propane in nitrogen prepared gravimetrically with mass
quantities of approximately 100 percent propane. A calibration curve
shall be provided using a minimum of five prepared standards in the range
of concentrations expected during testing.
For each repetition, zero with zero gas (3 ppm C) and span with 70%
propane for instruments used in the vapor return lines and with 10%
propane for instruments used at the control device exhaust.
The zero and span procedure shall be performed at least once prior to
the first test measurement, once during the middle of the run, and once
following the final test measurement for each run.
Conditions in calibration gas cylinders must be kept such that con-
densation of propane does not occur. A safety factor of 2 for pressure and
temperature is recommended.
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