United States ' "~ EPA-340/1-80-013a
Environmental Protection Office of General Enforcement July 1980
Agency Washington DC 20460
Stationary Source Enforcement Series
Development of VOC
Compliance Monitoring
and Enforcement
Strategies: The Wholesale
Gasoline Marketing
ChainVolume II
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EPA-340/1 -80-013a
Development of VOC Compliance
Monitoring and Enforcement
Strategies: The Wholesale Gasoline
Marketing ChainVolume II
by
Richard L Goen and Richard A. Ferguson
SRI International
333 Ravenswood Avenue
Menlo Park, CA 94025
Contract No. 68-01 -4137
TaskNos. 11 and 14
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of General Enforcement
Division of Stationary Source Enforcement
Washington, DC 20460
July 1980
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CONTENTS
LIST OF ILLUSTRATIONS v
LIST OF TABLES vii
ABSTRACT ix
ACKNOWLEDGMENTS xi
I DESCRIPTION OF THE GASOLINE MARKETING CHAIN 1
Flow of Gasoline 1
Components of the Gasoline Marketing Chain 3
Petroleum Terminals 3
Petroleum Bulk Plants 4
Service Stations 4
Other Gasoline Outlets 5
Transportation Components 5
II INVENTORY OF COMPONENTS OF THE GASOLINE MARKETING CHAIN .... 7
Terminals, Bulk Plants, and Service Stations 7
Components Categorized by Oxidant Attainment Status 7
Storage Tanks 8
Gasoline Storage Capacity 10
Gasoline Throughput 12
Transportation Components 14
Number of Companies Operating Bulk Plants and Terminals .... 14
III HYDROCARBON EMISSIONS AND EMISSION CONTROL 17
Rail and Truck 17
Tankers and Barges 18
Terminals 19
Bulk Plants 21
Service Stations 22
Total VOC Emissions 23
IV HYDROCARBON EMISSION REGULATIONS 25
Federal Regulatory Requirements 26
Status of State Regulations 28
Sources Covered by State and Local Regulations 30
States with Controls on Terminals and Bulk Plants 30
Other Federal Agency Regulations 34
111
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CONTENTS (Continued)
APPENDICES
A GASOLINE MARKETING CHAIN DATA . A-l
B METHODOLOGY AND SOURCES OF DATA FOR
THE GASOLINE MARKETING CHAIN B-l
C STATE HYDROCARBON EMISSION REGULATIONS C-l
iv
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ILLUSTRATIONS
1 Gasoline Flow in the United States 2
2 Terminals, Bulk Plants, and Service Stations by EPA Region ... 9
3 Terminals and Bulk Plants by EPA Region and Oxidant Status ... 9
4 Gasoline Storage Capacity of Terminals
and Bulk Plants by EPA Region - 11
5 Gasoline Storage Capacity of Terminals and Bulk Plants
by Oxidant Status and EPA Region . .» 11
6 Gasoline Throughput for Terminals, Bulk Plants, Service
Stations, and Other Outlets in 1978 by EPA Region 13
7 Gasoline Throughput for Terminals and Bulk Plants in 1978 by
Oxidant Status and EPA Region 13
8 Petroleum Product Pipeline Length and
Pump Stations by EPA Region 15
9 Gasoline Tank Trucks by EPA Region 15
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TABLES
1 Principal Interregional Shipments of Gasoline in 1977
2 Gasoline Storage Tanks for Service Stations,
Bulk Plants, and Terminals
3 Distribution of Bulk Plants and Terminals
by Gasoline Storage Capacity 10
4 Distribution of Bulk Plants and Terminals
by Daily Gasoline Throughput 12
5 Number of Companies Operating Terminals 16
6 Number of Companies Operating Bulk Plants 16
7 VOC Emissions from Gasoline Storage Tanks at Terminals .... 20
8 Total VOC Emissions by Source 24
9 Status of State VOC Regulations by EPA Region 29
10 Number of States with Any Existing Regulations
Pertaining to Each Type of Source 31
11 Increase in Number of States with Storage
and Transfer Controls 32
12 Number of States with Controls on Terminals
and Bulk Plants, by EPA Region 33
A-l Bulk Plants and Terminals by State and Oxidant Status .... A-2
A-2 Motor Gasoline Storage Capacity for Bulk Plants and
Terminals in 1972 by State and Oxidant Status A-5
A-3 Gasoline Throughput for Terminals, Bulk Plants,
and Outlets in 1978 by State A-8
A-4 Gasoline Throughput for Bulk Plants and Terminals
in 1978 by State and Oxidant Status A-ll
A-5 Petroleum Product Pipeline Length and Number
of Pump Stations by State A-14
A-6 Terminals and Bulk Plants Operated by Oil Companies A-17
vii
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TABLES (Continued)
A-7 Products Pipeline Companies A-20
C-l States with Regulations Pertaining
to Each Type of Source C-3
C-2 Changes in State Cutoffs for Application of
Storage and Transfer Controls C-5
C-3 Changes in State Controls on Terminals C-8
C-4 Changes in State Transfer Controls on Bulk Plants C-10
C-5 Summary of State Hydrocarbon Regulations
Relating to Storage and Transfer C-12
viii
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ABSTRACT
This study addresses the development of compliance monitoring and
enforcement strategies for one major source category of VOC emissions
the gasoline marketing chain. The study draws on the enforcement
practices of agencies with several years of experience in implementing
VOC rules for the gasoline marketing chain to suggest a framework for
the use of state and local agencies in developing appropriate compliance
strategies geared to local conditions. Rather than providing technical
assistance on particular control techniques, the report highlights the
factors that agencies should consider in deploying their enforcement
resources. Volume I of the study presents the results of pur survey of
experienced agencies as well as the framework for development of compli-
ance strategies. Volume II provides technical detail on the components
of the gasoline marketing chain, the emission sources -and control tech-
niques , and the status of state emission regulations applicable to the
chain.
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ACKNOWLEDGMENTS
Undertaking a study covering a broad spectrum of specific subjects
such as this one requires individuals with diverse kinds of expertise to
work together in addressing the overall questions. Work on this study
was greatly facilitated by the following individuals on the SRI project
team.
The regulatory analysis was conducted by Richard A. Ferguson,
Manager of SRI's Regulatory Analysis and Management Program (RAMP). The
survey of regulations was conducted by Perrin Quarles, of Perrin Quarles
Associates. Carl A. Trexel and Claudia Grill from the SRI Energy Center
participated in collecting information on the gasoline marketing chain.
Dr. Edward M. Listen from the SRI Atmospheric Sciences Laboratory
developed information on emissions and emission controls. Harold R.
Winslow, Jr., also from RAMP and Susan H. Russell from the SRI Center
for Quantitative Social Sciences designed the procedures and format for
conducting the interviews with enforcement agency staff. Those who con-
ducted the interviews and interpreted and analyzed the results besides
myself were Mr. Winslow, Mr. Ferguson, Mr. Quarles, Dr. Listen, and Mr.
Roy L. Hays from the Center for Resource and Environmental Systems Stud-
ies. Finally, we wish to acknowledge the thoughtful critique and sug-
gestions for improving the final version of this report made by Ms.
Elizabeth H. Terakin from RAMP.
Beyond the resources of the SRI project team, much of the informa-
tion on inspection and enfocement practices presented in Volume I came
from interviews with staff of state and local air pollution control
agencies, as well as EPA Regional Offices. We are especially grateful
to these individuals who agreed to be interviewed and who provided us
with insights and information on the topic that was otherwise unobtain-
able. In keeping with our assurances to interview respondents, we have
not attributed any information in this report to specific agencies or
individuals.
Richard L. Goen, Project Leader
Center for Resource and
Environmental Systems Studies
xi
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I DESCRIPTION OF THE GASOLINE MARKETING CHAIN*
Flow of Gasoline
Total gasoline use in the United States in 1978 was 443 billion
liters. Of this amount, 433 billion liters were produced by domestic
refineries and 10 billion liters were imported.
Figure 1 identifies the components of the gasoline marketing chain
and illustrates the flow of gasoline among these components,. From the
refineries, nearly two-thirds of the gasoline is transported by pipe-
line, tanker, or barge to terminals that store the gasoline in large
tanks for further distribution. Small quantities of gasoline are trans-
ported by truck or rail to the terminals. Approximately one-third is
transported by tank-truck directly to the service stations and other
retail or private outlets, or to bulk plants for further distribution.
Much of the gasoline received by the terminals, particularly the
marine and pipeline terminals, is transported by pipeline or barge to
other terminals. The rest is transported by tank-truck, either directly
to service stations or other outlets, or to bulk plants for further dis-
tribution. From the bulk plants the gasoline is transported by tank-
truck to the service stations and other outlets.
Most gasoline is consumed in the same region in which it is pro-
duced. However, large quantities of gasoline are shipped from Texas and
Louisiana to the East Coast and Midwest, as shown in Table 1. These
shipments amount to approximately 25% of the gasoline produced in the
United States. The Colonial pipeline, running from Houston through the
southern and East Coast states to New Jersey, accounts for most of these
shipments. Shipments by tanker and barge from the Gulf Coast to the
East Coast are also large. Smaller amounts are shipped to the Midwest
through a network of pipelines, and by barge up the Mississippi and Ohio
Rivers.
Appendix A presents a detailed tabular description of the gasoline
marketing chain. Appendix B describes the methodology and sources for
data for information in Chapters I and II.
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IMPORTS
TANKER
10
210
TANK-
TRUCK
REFINERIES
TANKER OR BARGE 85
PIPELINE 190
15
290
TRUCK OR
RAIL
TERMINALS
TRANSFERS BETWEEN
TERMINALS
»
WATER 40
PIPELINE 150
TRUCK 7
TANK-
TRUCK
90
BULK PLANTS
58
TANK-
TRUCK
148
. 340
103
SERVICE
STATIONS
OTHER
OUTLETS
143
TANK-
TRUCK
85
FIGURE 1. GASOLINE FLOW IN THE UNITED STATES IN 1978 (109 liters)
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Table 1
PRINCIPAL INTERREGIONAL SHIPMENTS OF
GASOLINE IN 1977 (10? liters)
From Texas-Louisiana to; Pipeline Tanker and Barge Total
East Coast 66 28 94
Midwest 1_3 _5_ 18
Total 79 33 112
Components of the Gasoline Marketing Chain
Petroleum Terminals
Petroleum terminals are large facilities for the wholesale market-
ing of gasoline, kerosene, and fuel oil. They receive these petroleum
products from refineries or other terminals, mostly by pipeline, tanker,
or barge, and store the products in large tanks. Marine and pipeline
terminals distribute products mostly to other terminals. Tank truck
loading terminals distribute products by tank truck to bulk plants,
retail outlets or final consumers.
The Bureau of the Census distinguishes terminals from bulk plants
on the basis of storage capacity and the transportation mode by which
products are received. By their definition, terminals include (1) fa-
cilities having total bulk storage capacity of 7.9 million liters or
more, and (2) facilities of smaller capacity receiving their products
primarily by tanker, barge, or pipeline. On the other hand, EPA dis-
tinguishes gasoline terminals from gasoline bulk plants on the basis of
gasoline throughput, with terminals defined as facilities with more than
76,000 liters daily throughput. The two definitions are reasonably con-
sistent, because most terminals (by Bureau of Census definition) have
daily throughputs of more than 76,000 liters of gasoline, while most
bulk plants are well below that throughput level.
The terminal gasoline storage tanks are large, aboveground, cylin-
drical tanks, with a vertical axis. Some tanks have fixed roofs and
some have floating roofs that rest on the surface of the gasoline and
rise and fall with the level of gasoline in the tank. The tanks may
hold different products according to variations in demand and storage
requirements (e.g., gasoline in the summer and fuel oil in the winter).
The configuration of the terminals differs depending on the modes
of transportation for receipt and shipment of products. Products are
received from tankers or barges through loading hoses or steel pipe
gantries connecting to the terminal manifolds and then transferred
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through a network of pipes to the storage tanks. For loading products
onto water carriers, this process is reversed. The connections to the
storage tanks are at the bottom. Pumps in the terminals move the pro-
ducts through the pipes. Pumps aboard ship are used for loading and
unloading tankers. For terminals that receive products by pipeline, the
products are pumped through a network of pipes from the connection to
the pipeline to the storage tanks, or the reverse for shipment of pro-
ducts from the terminal by pipeline. The mixture of products at the
interface between batches of different products in the pipeline is
directed to a slop tank from which the mix may be sold directly or
reprocessed. During loading into tank trucks, the products are trans-
ferred through the pipes to a loading rack where hoses or pipes are con-
nected to the tank trucks.
Petroleum Bulk Plants
Petroleum bulk plants are facilities for the wholesale marketing of
gasoline, kerosene, and fuel oil. After receiving these petroleum pro-
ducts from refineries or terminals, primarily by tank truck, bulk plants
store the products in tanks until distribution by tank truck to retail
outlets or final consumers.
Bulk plants, according to the Bureau of Census definition, have
bulk storage capacity of less than 7.9 million liters, and by EPA
definition, a daily gasoline throughput of no more than 76,000 liters.
Perhaps 5 to 10% of the bulk plants do not carry gasoline. However,
that reduction may be offset by under-reporting of the number of bulk
plants, because the census figures include only bulk plants with payroll.
Although most bulk plants have above ground storage tanks, many have
underground tanks. Aboveground tanks are usually cylindrical with domed
ends, and have either a vertical or horizontal axis. The use of float-
ing roofs is not common.
Products received are generally transferred from the tank truck
directly to the storage tank. Products are transferred by pipes from
the storage tanks to a loading rack where the tank trucks are filled.
Service Stations
Service stations receive gasoline by tank truck from terminals or
bulk plants or directly from refineries, and store the gasoline in un-
derground tanks. Gasoline service stations, as defined by the Bureau of
Census, are establishments primarily selling gasoline and automotive
lubricants.
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Other Gasoline Outlets
Other outlets also sell gasoline to consumers, but are not defined
as service stations because they are not primarily engaged in selling
gasoline and automotive lubricants. These include convenience stores
that carry a relatively small line of high-turnover food and other con-
sumer items as well as gasoline, marinas, parking garages, and rural
"Mom and Pop" businesses that sell gasoline more as a convenience to
their customers than as a major source of income.
In addition to retail gasoline outlets, many private gasoline-
dispensing facilities are maintained by governmental, commercial, indus-
trial, and agricultural consumers for their own fleet operations.
Transportation Components
Gasoline is transported by pipeline, tanker, barge, tank truck, and
rail tank car, as described below:
PipelinesPetroleum products move through a products pipeline
in a continuous flow, pushed by huge pumps and compressors. Pump sta-
tions are spaced at intervals along the line. Different products are
moved through the pipeline in batches, although the largest products
pipeline (Colonial) now has a separate line for gasoline. Storage ca-
pacity must be available at both ends of the line and at the input and
offtake points in between to even out variations of supply and demand.
Water CarriersCommon tank barges for inland waterways have
capacities of 1.1 to 3.8 million liters of gasoline. Flotillas of these
barges are pushed by towboats or pulled by tugboats. On the other hand,
ocean-going barges are larger, varying in size from 7,500 to 35,000
deadweight tons (dwt) (9 to 40 million liters). Self-propelled coastal
tankers of 26,000 dwt (30 million liters), 35,000 dwt (40 million
liters), and 60,000 dwt (69 million liters), are important in the trans-
portation of petroleum along U.S. coasts.
Tank TrucksGasoline is delivered to bulk plants, service
stations, and other retail and private outlets by tank truck. Straight
tank trucks (single units with one tank) have a capacity of about 9,800
to 12,000 liters. Semi-trailers and truck-trailers have 'two tanks with
a total capacity up to 34,000 liters.
Rail Tank CarsThe amount of gasoline transported by rail is
very minor, less than 1.5 billion liters per year. Twenty years ago,
tank cars held approximately 38,000 liters but in the 1960s larger cars
were introduced. Today, the recommended tank car for gasoline has a
capacity of 100,000 liters.
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II INVENTORY OF COMPONENTS OF THE GASOLINE MARKETING CHAIN
Terminals, Bulk Plants, and Service Stations
Figure 2 shows the estimated 1978 inventory of terminals, bulk
plants, and service stations by EPA Region. An inventory of terminals
and bulk plants by state is given in Appendix A. The Region totals have
been rounded for presentation in Figure 2, to avoid indicating greater
accuracy than the estimates warrant.
The number of service stations declined from 226,000 in 1972 to
171,000 in 1978, and this trend is expected to continue. The number of
terminals and bulk plants have also been declining as indicated in the
following tabulation:
1967 1972 Estimated 1978
Terminals 2,701 1,925 1,800
Bulk plants 26,338 23,367 21,000
Total 29,039 25,292 22,800
A continuing phase-out of the smaller facilities is expected. The num-
ber of terminals is small enough to permit all of them to be inspected,
at least occasionally. Bulk plants, however, are ten times more numer-
ous. Regular inspections of such a large number of facilities may re-
quire excessive effort relative to the reduction in emissions achieved,
except perhaps in Regions I and II, which have only about twice as many
bulk plants as terminals.
There are approximately 240,000 other outlets for gasoline in ad-
dition to the service stations. These include retail establishments
that are not service stations, and facilities maintained by govern-
mental, commercial, industrial, and agricultural consumers for their own
fleet operations.
Components Categorized by Oxidant Attainment Status
Reducing VOC emissions is more important in areas that are not in
attainment with the oxidant standards. The enforcement effort re-
quirements may be affected by how many of the emission sources are in
nonattainment areas.
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In January 1979, the oxidant standard was changed from 0.08 ppm to
0.12 ppm. Figure 3 gives the numbers of bulk plants and terminals in
attainment areas and nonattainment areas under the new standard by EPA
Region. The data do not permit separating bulk plants and terminals, but
the terminals are found primarily in urban counties, while bulk plants
are located primarily in rural counties. Since controls may not be re-
quired on bulk plants in rural nonattainment areas, the number of facil-
ities requiring enforcement effort is less than the 7,000 facilities in
nonattainment areas.
Storage Tanks
Service stations generally have three storage tanks for gasoline
one for leaded regular, one for unleaded, and one for premium. Some
larger stations may have one or two more tanks. An average of three and
one half tanks per station is assumed in this report.
Bulk plants usually have only two tanks for gasolineone for
leaded regular, and one for unleadedand distribute premium obtained
directly from the tanks of their supplier. The larger bulk plants may
have three or more tanks for gasoline, so the average number is about
three.
Typical distribution terminals have four or five gasoline storage
tanks, while large marine and pipeline terminals may have more than
five. We assume an average of five gasoline storage tanks for terminals,
The total estimated numbers of gasoline storage tanks in these
facilities in the United States are given in Table 2.
Table 2
GASOLINE STORAGE TANKS FOR
SERVICE STATIONS, BULK PLANTS, AND TERMINALS
Average
Number
Establishments of Tanks Total Tanks
Service Stations 171,000 3.5 600,000*
Bulk Plants 21,000 3 63,000
Terminals 1,800 5 9,000
Total 193,800 671,000
*Rounded
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TERMINALS
BULK PLANTS
SERVICE STATIONS
FIGURE 2. TERMINALS, BULK PLANTS,AND SERVICE STATIONS BY EPA REGION
ATTAINMENT 3,200
NONATTAINMENT 650
TOTAL
ATTAINMENT 16,000
NONATTAINMENT 7,000
FIGURE 3. TERMINALS AND BULK PLANTS BY EPA REGION AND OXIDANT STATUS
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Gasoline Storage Capacity
Figure 4 gives the gasoline storage capacity for terminals and bulk
plants by EPA Region. The data are for 1972, but we estimate that lit-
tle change has occurred since that time. The terminals account for 85%
of the storage capacity.
Figure 5 gives the gasoline storage capacity of terminals and bulk
plants combined, by oxidant status. Gasoline storage capacity is more
heavily concentrated in nonattainment areas than is the number of facil-
ities, because the terminals, with most of the storage capacity, are
concentrated in the large urban areas, most of which are nonattainment
areas. The nonattainment areas have 73% of the storage capacity.
The distribution of bulk plants and terminals by gasoline storage
capacity and by daily gasoline throughput may be an important considera-
tion in developing enforcement strategies, because some regulations
apply only to facilities with capacities or throughputs above, certain
levels. Also, priorities for enforcement effort may be based on storage
capacity or throughput, since emissions tend to be proportional to those
factors.
Table 3 shows the percent of bulk plants and terminals in each
range of gasoline storage capacity. The storage capacity of bulk plants
generally ranges from 100,000 to 200,000 liters. The average bulk plant
has a capacity of about 230,000 liters. Terminal capacity typically
ranges from 4 to 25 million liters with the average being about 13.6
million liters.
Table 3
DISTRIBUTION OF BULK PLANTS AND TERMINALS
BY GASOLINE STORAGE CAPACITY
Gasoline Storage
Capacity (103 liters) Establishments (%)
Bulk Plants
< 100 21
100-200 59
200-400 12
> 400 8
100
Terminals
< 2,000 7
2,000-4,000 12
4,000-10,000 26
10,000-25,000 43
> 25,000 12
100
10
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TOTAL
TERMINALS 24,200
BULK PLANTS 4,?oo
FIGURE 4. GASOLINE STORAGE CAPACITY OF TERMINALS AND BULK
PLANTS BY EPA REGION (106 liters)
TOTAL
ATTAINMENT 7,800
NONATTAINMENT 21,000
FIGURE 5. GASOLINE STORAGE CAPACITY OF TERMINALS AND BULK
PLANTS BY OXIDANT STATUS AND EPA REGION (106 liters)
11
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Gasoline Throughput
Hydrocarbon emissions within the gasoline marketing chain are
largely proportional to the quantities of gasoline transferred from one
container to another. Hence, gasoline throughput is a useful indicator
of potential emissions. The estimated throughput of gasoline in 1978
for terminals, bulk plants, service stations, and other outlets by EPA
Region is shown in >. igure 6. Appendix A gives throughput by state. The
443 billion liters of throughput for the outlets represents total final
consumption. The estimated 497 billion liters of throughput for the
terminals is larger than total consumption because of the transfer be-
tween terminals. The throughput of the bulk plants accounts for only
14% of the total throughput of all of these facilities.
Figure 7 gives the combined gasoline throughput of terminals and
bulk plants by Region and oxidant status. Appendix A gives the through-
put by oxidant status and state.
Table 4 shows the percent of bulk plants and terminals in each
range of daily gasoline throughput. Most bulk plants have throughputs
below 40,000 liters per day, while terminal throughput generally, ranges
between 100,000 and 1,200,000 liters per day. The average daily
throughputs are 20,000 and 750,000 liters for bulk plants and terminals,
respectively.
Table 4
DISTRIBUTION OF BULK PLANTS AND
TERMINALS BY DAILY GASOLINE THROUGHPUT
Daily Gasoline
Throughput (10 liters) Establishments (%)
Bulk Plants
< 10 22
10-20 50
20-40 19
> 40 9
100
Terminals
< 100 5
100-400 35
400-1,200 46
> 1,200 _14
100
12
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TERMINALS
BULK PLANTS
SERVICE STATIONS
AND OTHER
OUTLETS
TERMINALS
BULK PLANTS
SERVICE STATIONS
AND OTHER
OUTLETS
FIGURE 6. GASOLINE THROUGHPUT FOR TERMINALS, BULK PLANTS,
SERVICE STATIONS, AND OTHER OUTLETS IN 1978 BY EPA
REGION (106 liters)
TOTAL
ATTAINMENT 176
NONATTAINMENT 469
FIGURE 7. GASOLINE THROUGHPUT FOR TERMINALS AND BULK PLANTS
IN 1978 BY OXIDANT STATUS AND EPA REGION (106 liters)
13
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Transportation Components
Gasoline is transported by pipelines, barges, tankers, tank trucks,
and rail cars as follows:
o Pipelines
Figure 8 lists the kilometers of petroleum product pipeline
and the numbers of pump stations on those pipelines by EPA
Region.
o Water Carriers
Approximately 3,200 tank barges are used for U.S. domestic
transportation, primarily for the transportation of petroleum
and petroleum products. Gasoline constitutes the major por-
tion of these shipments. Approximately 140 U.S. tankers are
used in domestic transportation.
o Tank Trucks
The number of tank trucks in the United States of the type
used for gasoline (general purpose, nonpressure and low pres-
sure) is approximately 60,000. Most, though not all, of these
are used for gasoline. The estimated distribution of these
trucks by EPA Region is given in Figure 9. (The tank trucks
were distributed by region in proportion to the gasoline
throughput of bulk plants and outlets shown in Figure 6, the
components of the chain that receive gasoline almost entirely
by tank truck.)
o Rail Cars
Although there are approximately 120,000 rail petroleum tank
cars in the 'United States, most of these rail tank cars are
seldom used for gasoline in view of the very limited amount of
gasoline shipped by rail.
Number of Companies Operating Bulk Plants and Terminals
Many companies operate a number of bulk plants and terminals. Some
enforcement strategies could be directed at the companies rather than at
the individual establishments, thus reducing the required number of con-
tacts. Therefore, information about the number of companies operating
such facilities may be needed to indicate possible enforcement strat-
egies and effort.
14
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LENGTH
PUMP STATIONS
TOTAL
LENGTH 130,800
PUMP STATIONS 705
FIGURE 8. PETROLEUM PRODUCT PIPELINE LENGTH AND
PUMP STATIONS BY EPA REGION
TOTAL 60,000
FIGURE 9. GASOLINE TANK TRUCKS BY EPA REGION
15
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As indicated in Table 5, the 1,800 terminals are operated by fewer
than 245 companies. A substantial proportion of the bulk plants are
operated by 90 oil companies (Table 6). However, 70% of the bulk plants
are operated by jobbers (independent dealers who obtain petroleum pro-
ducts from refineries or terminals and sell to service stations and
other outlets). Some jobbers operate more than one bulk plant, but most
operate only a singl«_ plant.
Table 5
NUMBER OF COMPANIES OPERATING TERMINALS
Type of Company Number of Companies Number of Terminals
Oil 70 1,300
Pipeline and
marine terminal 125 450
Jobber 50 5£
Total 245 1,800
Table 6
NUMBER OF COMPANIES OPERATING BULK PLANTS
Type of Company Number of Companies Number of Bulk Plants
Oil company 90 6,000
Jobber NA 15,000
Total NA 21,000
16
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Ill HYDROCARBON EMISSIONS AND EMISSION CONTROLS
Rail and Truck
The emissions from rail cars and tank trucks are primarily from
vapors displaced during the loading or unloading of gasoline. Any
liquid leaks are fixed immediately because of the extreme hazard.
The uncontrolled VOC emission factors given in AP-42* for loading
and unloading of tank cars and trucks are:
mg/liter transferred
Splash loading 1490
Submerged loading 490
Unloading 250
These factors appear reasonable based on SRI experience.
In submerged loading, the gasoline is injected below the surface of
the gasoline already in the tank, while in splash loading the inlet is
above the surface of the gasoline. Submerged loading is already preva-
lent and has substantially lower emissions than splash loading.
The next major step in controlling emissions from loading tank
trucks is to collect the vapors displaced from the trucks. At terminals
or refineries the vapors collected from the trucks are recovered (con-
verted back to liquid gasoline) or oxidized (burned). These control
systems can reduce emissons by more than 98% or to approximately 10 mg/
liter loaded (submerged loading) into the truck. At bulk plants the
vapors from the trucks are transferred to the storage tank from which
the truck is being filled. Subsequently, these vapors are transferred
to the trucks that fill the storag'e tanks for return to a terminal or
refinery where the vapors are recovered or oxidized. These vapor
balance systems can reduce emissions by 95% or to 25 mg/liter loaded
(submerged loading) into the trucks when the equipment is in good
operating condition. The sources of leaks in these vapor collection
systems are bad seals on the trucks.
*Environmental Protection Agency, "Compilation of Air Pollutant Emission
Factors" (third edition), Research Triangle Park, North Carolina (August
1977).
17
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Very little gasoline is moved by rail. However, the same control
methods used on trucks are applicable to rail cars.
Tankers and Barges
The emissions from tankers and barges at marine terminals are
primarily from vapor displaced during loading, and some evaporation
during unloading. Also, small losses, from leaking flanges and valves
occur, but these leaks are repaired as soon as they are discovered.
The emission factors given in AP-42 for loading and unloading
gasoline in marine vessels are:
mg/liter transferred
Loading 350
Unloading 300
These factors probably represent maximum values and so are far larger
than would be found in deep tanks. In a relatively still tank, the VOC
concentration in the vapor space varies directly with depth. Thus, the
hydrocarbon concentration in the air being displaced during loading
varies greatly. Only the last few feet of vapor above the liquid sur-
face approach saturation. The emission factors should therefore be a
strong function of the depth of the tanks.
Emission controls have not been used for marine loading of gaso-.
line. Controlling emissions from this source is more difficult than for
tank trucks because of the much higher filling rates, the existence of
VOC vapor concentrations within the explosive range, and the wide varia-
tions in the vapor concentration. Because of the high filling rates
(e.g., 130,000 liter/min), the capacity of a vapor recovery system would
have to be very high, which would be very expensive. The vapor concen-
tration varies from virtually pure air to saturated vapor, and the con-
centration can change very rapidly as the tank filling is completed.
Incineration systems require complex controls to maintain proper air-to-
fuel mixtures. Flame arresters are required to prevent flame propaga-
tion back through the vapor collection system, and the reliability of
flame or detonation arresters is uncertain. Another problem in the de-
sign of marine emissions control systems is avoiding overfill, with the
attendant risk of fire. At the present time, the level of gasoline in
the tank is checked visually through open hatches. In a sealed system,
this would be difficult to do.
The control systems under consideration for marine operations would
collect the vapors from the vessel and convey the vapors to a shoreside
unit for recovery or incineration. Experimental control systems util-
izing refrigeration (for vapor recovery) or incineration currently in
18
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operation should help to define the installation and operational prob-
lems and show what control efficiency is possible.
The marine control systems will vary substantially because of site-
specific factors such as the size and shape of the dock and its loca-
tion. Standard fittings on many different types of vessels will be
necessary. This variation in the control systems will probably lead to
enforcement problems; inspectors will have to be familiar with each in-
stallation.
VOC emissions during transit (430 mg/week per liter transported)
may be greater than the loading and unloading emissions. However, the
transit emissions are spread over the coastal and inland waterways.
Terminals
There are two types of emissions from terminals: operational and
accidental emissions. The accidental emissions are from piping and
pumping leaks, which can be controlled by good maintenance.
The emissions from normal operation of the terminals include (1)
working losses from filling and draining the fixed roof storage tanks
(filling displaces vapor, and draining draws in air that subsequently
vaporizes VOC with attendant increase in volume and venting); (2)
breathing losses for fixed roof tanks associated with expansion and
contraction of the vapor due to temperature changes, and (3) standing
storage losses for floating roof tanks at the seal between the roof and
the tank wall. (Emission factors for loading and unloading the tank
trucks were given previously.) Table 7 presents the uncontrolled VOC
emission factors from AP-42 for terminal storage tanks.
It has recently been found that these emissions are highly depen-
dent on the wind and on the way in which the tank vapor space (fixed
roof and covered floating roof) is vented. It appears that minor modi-
fications of the vent systems can reduce the emission factors, especial-
ly on covered floating-roof tanks.
Vapor control at terminals involves the collection of vapor from
the trucks and fixed roof tanks as they are filled. This vapor is then
processed to prevent it from being vented.
Three major technologies are used for processing the vapor at
terminals:
o Refrigeration
o Adsorption/absorption
o Incineration.
19
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Table 7
VOC EMISSIONS FROM GASOLINE STORAGE TANKS AT TERMINALS
mg/liter Throughput
Fixed roof
Working losses 1,080
Breathing losses 480*
Total 1,560
Floating roof
Standing storage
losses 70+
*Based on a storage emission factor of 9.6g/year per liter
storage capacity and an assumed 20 liter annual
throughput/liter storage capacity.
+Based on a storage emission factor of 1.4g/year/liter
storage capacity and an assumed 20 liter annual
throughput/liter storage capacity.
Source: SRI International.
20
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At the present time, refrigeration systems are the most common. If pro-
perly sized, installed, and maintained, these systems are capable of
98+% recovery efficiency (except for methane) or a controlled loss of
approximately 25 mg/liter loaded into fixed roof tanks (not applicable
to uncovered floating roof tanks). Their major problem is their com-
plexity and need for specially trained maintenance personnel. The ad-
sorption/ absorption systems are also capable of 98+% recovery effi-
ciency if properly sized, installed, and maintained. The manufacturers
of these units claim that they have significantly lower maintenance and
operating costs than refrigeration systems. Both types of units are
tested for proper operation by testing the concentration of the vapors
being vented from the processing unit and checking for leaks. The in-
cineration units are tested by analyzing the effluent gases from the
burner. An experienced inspector could probably detect a poorly
operating system by the look of the flame.
Bulk Plants
The emission sources at bulk plants are similar to those for ter-
minals, except that the storage tanks at bulk plants are generally
fixed-roof. The emissions include the working losses from filling and
draining the storage tanks and truckj, and the breathing losses from the
storage tanks. The uncontrolled VOC emissions from the fixed-roof
storage tanks are:
mg/liter throughput
Working losses
Breathing losses
Total
*9.6g/year/liter storage capacity; 40-liter annual
throughput/liter storage capacity.
Vapor control for bulk plants relies on a vapor balance system and
returning the hydrocarbon vapors to some other location for processing.
A vapor balance system operates by transferring vapors displaced from
the receiving tank to the tank being unloaded. When trucks are filled
at the bulk plant, the vapor from the trucks is transferred to the stor-
age tank. When the storage tank is filled, the vapor from the storage
tank is transferred to the truck that is filling the storage tank. That
truck returns the vapor to the terminal or refinery that supplies the
gasoline, where the vapor is processed. Breathing losses in the storage
tanks can be reduced by increasing the release pressure in the pressure
release valves.
21
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When the vapor balance system is operating properly, working loss
emissions should be reduced by more than 95%, or to less than 60 mg/
liter transferred. There will be some additional vent losses when the
temperature changes rapidly, or when gasoline with a different vapor
pressure is loaded into the tank, but these occurrences are usually of
short duration. The breathing losses in the storage tanks can be re-
duced by 70% with a 108 kPa (1 psi) setting on the pressure release
valve.
Service Stations
The two major sources of uncontrolled emissions at service stations
are the vapor displaced during the filling of vehicle fuel tanks and
during filling of the station storage tanks. The uncontrolled emission
factors factors given in AP-42 are:
mg/liter transferred
Vehicle displacement losses 1,300
Spillage 80
Submerged fill of storage
tanks 900
These factors are reasonable in view of SRI's experience with current
equipment.
The emissions from filling service station storage tanks can be
controlled by vapor balance systems. These systems are usually 95+%
efficient, assuming that they are well maintained, so the losses during
a drop (submerged filling) are less than 60 mg/liter. The sources of
excess loss are bad seals on the trucks or on the hose fittings or drop
tubes at the station. These sources can be detected with leak detectors
and corrected with proper maintenance.
The control of gasoline vapors displaced during the filling of
storage tanks is referred to as Stage I controls, while the control of
emissions from vehicle fuel tanks as they are fueled is called Stage II
control. Emissions can be controlled during fueling either by returning
the vapors to the storage tank or by capturing the vapors on board the
vehicle. Two different technologies can be used to return the vapors to
the storage tank: balance systems and vacuum-assist systems.
Balance systems use special nozzles that make a vapor-tight seal
with the vehicle fill-neck. The vapor is displaced back to the under-
ground tank (through a second hose) by the liquid entering the vehicle
tank. A properly operating balance system can recover more than 90% of
the vehicle vapors.
22
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The vacuum-assist systems utilize a looser fitting nozzle and a
vacuum pump or aspirator to suck the vapors into the vapor hose. A pro-
perly operating vacuum-assist system can recover more than 95% of the
vehicle vapors. Therefore, with either of these systems the controlled
loss at service stations will be less than 60 rag/liter transferred.
Several of the balance and vacuum-assist systems have now been certified
for use in California. The major problems with the systems involve the
maintenance of the face seal on the balance nozzles and the vapor
hoses. Instead of returning the vapor to the storage tank, use of a
canister aboard the vehicles to capture the vapor is now being con-
sidered.
In our opinion, the service stations will represent the most diffi-
cult enforcement problem in the gasoline marketing chain, because of the
large number of stations involved and the low level of maintenance that
we have observed on existing systems.
Total VOC Emissions
Table 8 shows the total VOC emissions from each source in the gaso-
line marketing chain. These emissions were calculated using the emis-
sions factors given in the preceding sections of this chapter and the
gasoline flows shown in Figure 1. For the emissions from storage tanks
at terminals, we assumed that one-third were fixed-roof and two-thirds
were floating-roof. Submerged loading of storage tanks predominates for
both terminals and bulk plants, although some underground tanks at bulk
plants may use splash loading. Both submerged loading and splash load-
ing are widely used for filling tank trucks and storage tanks at service
stations and other outlets. Because we do not know the proportions of
each type of loading, we calculated the emissions for all splash loading
or all submerged loading -to indicate the possible range and to illus-
trate the reduction in emissions attainable with submerged loading.
Because information was not available for the effectiveness of con-
trols for tankers and barges, we did not change the figures for uncon-
trolled emissions (i.e., assumed no controls). The emissions given for
tankers and barges are those resulting from loading and unloading at the
terminals, and do not include emissions that occur in transit.
The uncontrolled emissions given for trucks at bulk plants include
35,000 metric tons resulting from the unloading of trucks delivering
gasoline to the bulk plants, while the balance is from loading the
account trucks that deliver gasoline to the bulk plant's customers.
23
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Table 8
TOTAL VOC EMISSIONS BY SOURCE
(10^ metric tons per year)
Uncontrolled
Submerged Loading Except
Splash Loading of Trucks
& Tanks at Service Submerged
Stations & Other Outlets Loading Controlled
Terminals
Storage tanks 280 280 25
Trucks 510 160 5
Tankers & barges 50_ 5jO 5£
Total 840 490 80
Bulk Plants
Storage tanks 200 200 20
Trucks 260 110 _5
Total 460 310 25
Service Stations
Storage tanks 470 300 20
Vehicle fueling 480 480 2_5
Total 950 780 45
Other Outlets
Storage tanks 140 90 5
Vehicle fueling 150 150 _5_
Total 290 240 10
. Totals 2,540 1,820 160
Source: SRI International
24
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IV HYDROCARBON EMISSION REGULATIONS
In this chapter, state regulations affecting components of the gas-
oline marketing chain are reviewed and summarized by EPA region*, to
provide the background needed to formulate enforcement strategies. The
analysis illustrates the increased magnitude of the enforcement effort
required to obtain compliance with new 1979 gasoline vapor emission
rules. Older state regulations are contrasted with the more stringent
and comprehensive requirements under the 1977 Clean Air Act Amendments
for reasonably available control technology (RACT) at existing sources.
The contrast highlights changes in the number and type of regulated
sources (applicability), the nature of the control requirements imposed
on a given source (specificity), and the adequacy of the rules as the
bases for inspection and enforcement.
Second, the analysis identifies those states that have had experi-
ence enforcing rules similar to the new RACT requirements. The control
agencies in such states are more likely to have developed practical ap-
proaches to enforcing the installation and maintenance of RACT at gaso-
line storage and loading facilities. We used this information to select
which states to survey for state and local compliance strategies.
Third, the analysis identified other Federal regulations adminis-
tered by other agencies whose compliance programs also affect gasoline
facilities. These suggest areas of potential interagency cooperation
and possible reduction in the burden of inspections on industry.**
These data can help test the utility of the model regulations de-
veloped by EPA for use by the states in SIP revisions. The detailed
breakdown of regulatory requirements might also be used to develop new
model regulatory provisions that ease the inspector's job and offer a
greater credible threat of enforcement.
The regulatory data and analysis are not intended for direct appli-
cation in actual enforcement proceedings where specific sources in spe-
cific states are involved, however. Such action and policy governing
such actions should be predicated on a case-specific legal review of
Regulations in each state are described in greater detail in
Appendix C.
An interesting example of effective interagency cooperation occurs
at the state level. In California, the State Air Resources Board has
transferred funds to the State Fire Marshal, who then inspects and
certifies gasoline tank trucks on behalf of both agencies.
25
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the current provisions in the jurisdiction of interest, and not on the
50 state survey of provisions set out for other purposes here.
The text of the many existing state and local regulations has been
compiled in six volumes of working papers. Detailed information on the
applicability of the published regulations obtained from state and local
officials is also included in the volumes. A set of these working pa-
pers has been provided to the EPA Task Manager.
Federal Regulatory Requirements
Last year's state rules on gasoline vapor emissions and new 1979
vapor regulations are significantly different. The disparity has been
created by provisions in the Clean Air Act Amendments of 1977, which are
intended to speed attainment of the national ambient oxidant standard in
each control region. The Amendments require each state containing any
area in violation of the national ambient oxidant standard to adopt and
submit in 1979 a revised SIP to meet the oxidant standard by 1982, with
possible extension to 1987. As a minimum, the plan should contain le-
gally enforceable requirements that existing sources of volatile organic
compound (VOC) emissions (such as gasoline vapor) begin to employ RACT
to reduce those emissions. For example, at least 36 states now specify
vapor control systems for existing bulk gasoline terminals in nonattain-
ment areas statewide, while only 11 states did so in 1978.
EPA has grouped these VOC sources into 15 categories. For each
category, the agency has issuedor will soon issuea Control Techni-
ques Guideline (CTG) that describes, but does not mandate, specific con-
trol equipment and techniques suited to sources with given technical and
economic characteristics. A state is free to adopt rules applying some
or all of these EPA RACT requirements to sources in its jurisdiction, so
.long as the SIP demonstrates that the state's approach will in fact at-
tain the national ambient standard in increments of reasonable further
progress by the 1982 deadline.
In addition to the CTG, EPA has prepared for each source category a
model regulation incorporating RACT. Although these model regulations
are not binding on the states, they offer a convenient framework or
checklist of RACT requirements in language that describes the control
techniques flexibly yet enforceably.
Each SIP is "officially" submitted to EPA when the governor certi-
fies that the SIP rules have been properly enacted or revised by the
state and are effective as written. EPA must review the SIP and approve
or disapprove it either in whole or in part insofar as EPA judges
the plan to be adequate or inadequate for achieving and maintaining am-
bient air standards. To the extent that defects in the plan threaten
reasonable progress toward attainment, EPA issues its own regulations
for sources in the state to remedy the defects, at least until the state
officially revises its plan.
26
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As a practical matter, many states first submit draft versions of
new rules and provisions to EPA. This gives EPA an opportunity both to
guide state planners informally toward an acceptable approach and to re-
fine EPA's own SIP review procedures. These procedures typically in-
clude a comparison between the proposed SIP provisions and the relevant
CTG and/or model regulation. If the SIP provisions include RACT and
appear to be practically enforceable, and the aggregate controls amount
to reasonable further progress toward meeting the ambient standard, EPA
can approve the SIP.
Among the 15 categories, 5 cover the components in the gasoline
marketing chain:
o Petroleum liquid storage
o Gasoline loading terminals
o Bulk gasoline plants
o Tank trucks
o Service stations (Stage I).
This chapter focuses only on the gasoline storage and loading controls
suggested in the first four categories of CTGs and model regulations
published as of December 1978.
The control techniques suggested by EPA for storage tanks fall into
two groups, one set being "reasonable" for tanks larger than 152,000
liters,* and the other intended for stationary tanks of 950 liters or
more. Large tanks should be equipped with internal or external floating
roofs with appropriate seals and bleeder vents. Reasonable alternative
controls include vapor recovery systems or gas incineration systems.
All tanks, beginning with those as small as 950 liters, should be
equipped with submerged or bottom fill pipes to avoid excess vapor loss
from splash loading.
The CTG for bulk terminals recommends that a vapor collection and
recovery system be required for facilities with average daily throughput
of more than 76,000 liters.** Either a 90% (by weight) recovery effi-
ciency standard or an emission limit of 80 mg/liter processed is said to
be reasonable for condensation or adsorption systems. Gas collection/
incineration systems are also acceptable alternatives. Vapor tightness
requirements on fittings and lines are viewed as economical and enforce-
able here, as are certain work practices and prohibitions.
The CTG for bulk plants describes a significantly wider and more
detailed range of control alternatives. Because these facilities are
usually much smaller than terminals and more sensitive to modest varia-
tions in control economics, the greater detail in the CTG offers the
*Most tanks at terminals are larger than that size, but few tanks at
bulk plants are that large.
-Jr-Jr
Covers most terminals, but excludes most bulk plants.
27
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states a wider variety of RACT packages to adopt. As a baseline, gener-
ally bulk plants with a daily throughput of less than 15,000 liters per
day are exempt from any control (except the relevant storage tank re-
quirement usually the submerged fill pipe rule for tanks larger than
950 liters). EPA has further suggested that new RACT requirements need
not be applied in order to win SIP approval for small bulk plants in
rural areas. Howeve*., for urban bulk plants with throughput between
15,000 and 76,000 liters per day, the CTG sets out three major alterna-
tives:
o I. Submerged or bottom fill of trucks
o II. Alternative I plus vapor balance on the storage-tank fill
o III. Alternative II plus vapor balance on the truck fill, as
well.
In contrast to the guidelines for terminals, the guidelines for
bulk plants specify equipment requirements without specific limits on
emissions or percent reductions in emissions.
Tank trucks come under consideration in the CTGs for trucks, bulk
plants, and terminals. Suggested RACT for trucks consists of general
vapor tightness requirements at the vents, hatches, and fittings of the
truck. Maintenance and compliance test procedures are also set forth in
the tank truck CTG.
Status of State Regulations
Table 9 summarizes the status of the SIP revision process as it
relates to VOC emission controls to meet the oxidant standard. Seven
states do not have any non-attainment areas and therefore need not apply
RACT to existing sources. However, new sources seeking permits to build
and operate must meet New Source Performance Standards (NSPS), which
generally call for best demonstrated control technology and usually
specify an emission limitation. To date, NSPS exist only for large pet-
roleum liquid storage tanks; however, EPA will soon be promulgating NSPS
for new bulk terminals and plants. These standards can be expected to
require most or all of the tightest controls suggested in the CTGs des-
cribing RACT.
Of the 43 states with nonattainment areas, agency staff from 6
states told us in October 1978 that they would probably not follow the
CTGs or-incorporate new RACT requirements in their gasoline marketing
chain. Still other state agency staff indicated uncertainty as to how
to use the CTGs. We believe these comments illustrate the difficul-
ties faced by states in planning and enforcing gasoline vapor controls
at sources if they have had little prior experience in doing so. The
comments underscore the importance of finding and communicating the suc-
cessful enforcement strategies employed in those states with prior VOC
regulatory experience.
28
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Table 9
STATUS OF STATE VOC REGULATIONS BY EPA REGION
States With
States
States With Official
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
States
In Region
6
2
5
8
6
5
4
6
4
Jt
50
Nonatt ainment
Areas
6
2
5
7
6
5
4
2
3
_3
43
Intending to
Meet RACT
5
2
3
7
6
4
4
2
2
_£
37
SIPs Containing VOC
Revisions Submitted *
2
0
4
5
0
4
0
2
1
_!_
19
As of 17 May 1979
The table also shows that 19 states have officially submitted SIPs
containing revised VOC regulations; actually approximately 34 states had
sent at least one draft VOC proposal to office of Air Quality Planning
and Standards for informal review and comment, as of May 1979.
29
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Sources Covered by State and Local Regulations
Table 10 shows the number of states with existing regulations for
each component of the gasoline marketing chain. Only a few state air
agencies regulate ships, barges, rail, and pipelines. Most regulate
terminals. The data in the table are based on telephone discussions
with state control agency officials in October 1978. For terminals,
bulk plants, and tank trucks, the table also shows the relatively few
states where the regulations apply to: (1) both storage and loading,
(2) both existing and new sources, and (3) more than one locality in the
state. These data are based on our examination of the text of the
existing state regulations. More detailed notes on coverage may be
found in the tables of Appendix C.
With the new SIPs, many more states are incorporating storage and
transfer controls in their regulations. The storage controls require
floating roofs or vapor recovery on storage tanks of some minimum capa-
city. The transfer controls require emission controls when transferring
gasoline from one container to another, for facilities with some minimum
throughput. Although 20 states formerly had storage controls, 39 states
include such controls in their new SIPs. Four of the 20 states reduced
the minimum tank capacity to which their storage controls apply. The
number of states with transfer controls for bulk plants increased from 4
to 28 with the new SIPs, in many cases through a reduction in the mini-
mum throughput to which the controls apply into the throughput range
that includes bulk plants. The number of states with transfer controls
for terminals increased from 15 to 39.
States with Controls on Terminals and Bulk Plants
RACT for terminals and bulk plants consists of vapor collection and
disposal systems with numerical performance standards for terminals, and
vapor balance with submerged fill for bulk plants. Table 11 shows the
increase in the number of states with storage and transfer controls
while Table 12 shows the increase in the number of states writing RACT
(or RACT-like) provisions into their statutes and regulations in their
new SIPs.
Although only 11 states specified vapor control systems for termi-
nals under their former rules, and only eight states included numerical
standards such as 90% recovery or 80 mg/liter (or both) 36 states
do so in their new SIPs. Similarly dramatic increases appear in the
number of states adopting RACT for bulk plants. The states requiring
vapor balance increased from 6 to 29, while the states with a
requirement for submerged or bottom fill in their transfer regulations
increased from 9 to 28. Nearly all states have historically required
submerged fill on stationary tanks greater than a few hundred gallons in
size; the regula- tions referred to here cover bulk plant tanks and
trucks specifically during the loading process.
30
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Table 10
NUMBER OF STATES WITH ANY EXISTING REGULATIONS PERTAINING TO EACH TYPE OF SOURCE
States
Region
1
II
III
IV
V
VI
VII
VIII
IX
X
Total
In Region
6
2
5
8
6
5
4
6
4
4
50
Terminals*
3( 3)
2( 0)
4( 2)
4( 3)
5( 3)
3( 2)
2( 0)
6( 1)
3( 1)
2( 0)
32(15)
Bulk Plants*
2(0)
2(0)
4(1)
4(2)
2(0)
1(0)
2(0)
2(1)
2(1)
0(0)
21(5)
Tank Trui
0(0)
2(0)
2(1)
1(1)
1(0)
2(1)
1(0)
1(1)
2(1)
0(0)
12(5)
Ship, Barge,
or Rail
0
0
0
0
0
1
0
1
1
_0
3
Service
Other
Pipelines Stations Gasoline Outlets
0
0
0
0
0
1
0
0
1
_0
2
1
1
2
0
2
3
1
2
2
_0
14
1
1
1
0
1
3
0
2
2
_0
11
*Number in parentheses () indicates the number of states with regulations applying to both storage and loading, both
existing and new sources, and to more than one locality. Few states have requirements that comprehensive.
-------
Table 11
-*
INCREASE IN 1.JMBER OF STATES WITH STORAGE AND TRANSFER CONTROLS
Transfer Controls
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
States
6
2
5
8
6
5
4
6
4
_4
50
Storage
Former
2
0
4
3
4
2
0
2
3
jO
20
Controls
New SIP
6
2
5
7
4
4
2
2
4
_3
39
Bulk
Former
1
0
1
0
0
0
0
1
1
_0
4
Plants
New SIP
3
2
2
6
4
4
2
1
2
_2^
28
Terminals
Former
3
0
2
3
3
2
0
1
1
_0
15
New SIP
6
2
3
7
4
4
2
3
3
_2
36
32
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Tahlp 12
NUMBER OF STATES WITH CONTROLS ON TERMINALS
AND BULK PLANTS, BY EPA REGION
Terminals
Bulk Plants
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
States
6
2
5
a
6
5
4
6
4
4
Vapor Control
Former Rule
2
0
- 3
1
2
1
0
1
1
0
Systems
New SIP
6
2
4
7
4
4
2
2
3
2
Numerical
Former Rule
1
0
2
1
2
0
0
1
1
0
Standard
New SIP
5
1
2
7
3
4
2
2
3
2
Vapor Balance
Former Rule New
0
0
2
1
I
0
0
I
1
0
SIP
2
2
3
7
4
2
1
2
3
3
Submerged or
Former Rule
1
0
2
1
1
1
0
1
2
0
Bottom Fill
New SIP
2
2
3
6
3
4
1
2
3
3
Total
It
36
31
29
28
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Those states that had RACT-like provisions on the books prior to
the 1979 SIP revisions can be identified by examining Table C-5 in
Appendix C. California's provisions are most similar to RACT. In rough
order of decreasing similarity to RACT, and judging solely by the lan-
guage of their rules, the states are:
Region State
IX California
I Connecticut
Massachusetts
V Illinois
Ohio
III District of Columbia
Virginia (Region 7)
VIII Colorado (Denver)
IV Kentucky
VI Texas
Louisiana
Other Federal Agency Regulations
In the Department of Labor, the Occupational Health and Safety Ad-
ministration (OSHA) regulates hydrocarbon storage and transporting
facilities in its regulations on "flammable and combustible liquids."
Among the facilities regulated are storage tanks; pipes, valves, and
fittings; containers and portable tanks; bulk plants; and service sta-
tions. These regulations are clearly designed for safety purposes, how-
ever, and it is not certain how many of the requirements would overlap
with EPA RACT guidelines. Typical of the requirements are those relat-
ing to equipment design (for durability and to prevent pressure build-up,
although there are also requirements to prevent leakage) and facility
siting. A spokesman at OSHA indicated that the regulations generally
follow National Fire Protection Agency standard no. 30. He also indica-
ted that OSHA's jurisdiction is confined to facility site locations and
does not extend to transportation between sites.
In the Department of Transportation, the Office of Hazardous Mater-
ials regulates the transportation by truck and pipeline of hazardous
materials in its "General Requirements for Shipments and Packaging,"
which provides for the regulation for flammable, combustible, and pyro-
phoric liquids." These regulations apply in part to limits on loading
volume and container seals. Another part, "Preparation of Hazardous
Materials for Transportation," contains regulations that govern the
design of packages used for transportation of hazardous materials.
34
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Other regulations may also be applicable. However, as in the case with
OSHA regulations, the primary focus is to ensure safety; thus, emission
in the nature of venting to reduce pressure buildup would probably be
permitted under safe conditions, even if the venting were into the at-
mosphere.
The U.S. Coast Guard regulates tank vessels used for the carriage
of flammable or combustible liquid cargo. These regulations apply in
part to the design, operation, and inspection of tank vessels transport-
ing flammable or combustible liquids in waters subject to the naviga-
tional servitude. The purpose of such regulation is to ensure safety.
(These regulations apply only to U.S. flagships, which are the only ves-
sels authorized to transport petroleum within the United States.
Foreign vessels, which are not subject to these regulations, may carry
petroleum into and out of the country.) The transferring of petroleum
products from vessel to onshore facities is also regulated but again,
the main concern appears to be safety and water pollution. A spokesman
for the Coast Guard indicated that little coordination with EPA has
taken place in the past. He also indicated, however, that a program has
begun to develop the engineering for vapor recovery systems with the
EPA; a seminar on the subject was held during the first week in December
1978 in Washington.
A spokesman for the Federal Railroad Administration said that the
railroads only regulate the transportation of the liquids and not the
storage. These regulations are pertinent, however, because they relate
to design, as well as how the petroleum is loaded and how it is handled.
The spokesman added that the railroads have coordinated very little with
the EPA.
35
-------
-------
Appendix A
GASOLINE MARKETING CHAIN DATA
This appendix gives data on the gasoline marketing chain at the
state level, grouped by EPA Region. The similar figures in Chapter II
are regional summaries of the state-level tables in this appendix. Data
on oil companies operating bulk plants and terminals and on product
pipeline companies are also given in this appendix.
Table A-l gives the estimated 1978 inventory of bulk plants and
terminals by state and by oxidant attainment status. The numbers of
bulk plants and terminals in each state were rounded to avoid indicating
greater accuracy than the estimates warrant. Table A-2 gives the
gasoline storage capacity of bulk plants and terminals by state and by
oxidant attainment status. Table A-3 presents the gasoline throughput
by state for terminals, bulk plants, and service stations and other
outlets. Table A-4 gives the gasoline throughput for bulk plants and
terminals by oxidant status and state. Table A-5 presents the miles of
petroleum product pipelines and the numbers of pump stations on those
pipelines by state. Because of rounding, the totals sometimes vary
slightly from the sums of the numbers in the tables. The Regional
totals in these tables were rounded for presentation in Chapter II.
Table A-6 identifies the oil companies that operate terminals or
bulk plants, and the numbers of those facilities operated by each com-
pany. Table A-7 identifies the petroleum product pipeline companies.
Most of these pipeline companies operate terminals in conjunction with
their pipelines.
A-l
-------
Table A-l
BULK PLANTS AND TERMINALS BY STATE AND OXIDANT STATUS
(1978)
Bulk Plants and Terminals
EPA Region
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region Total
Bulk
Plants
55
105
90
50
15
40
355
Terminals
55
30
35
3
15
10
148
Attainment
Areas
0
20
0
7
0
J)
27
Non-
attainment
Areas
110
115
125
46
30
50
476
Total
110
135
125
53
30
50
503
Region II
New Jersey 130
New York 430
Region Total 560
Region III
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region Total 1,223
70
200
270
30
3
120
530
390
150
8
4
40
100
60
20
0
0
232
29
0
79
0
399
153
660
200
630
830
200
630
830
9
7
81
630
51
17
38
7
160
630
450
170
795
1,455
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region Total
3,535
40
65
45
25
15
60
30
40
320
3,235
75
178
80
0
76
32
50
129
630
3,855
A-2
-------
Table A-l (Continued)
EPA Region
Bulk
Plants
Terminals
Bulk Plants and Terminals
Attainment
Areas
Non-
attainment
Areas
Total
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region Total
4,860
60
50
65
20
75
55
325
3,109
2,076
5,185
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region Total
3,685
5
30
10
10
60
115
3,161
18
180
18
84
339
639
3,800
Region VII
Iowa
Kansas
Missouri
Nebraska
Region Total
2,680
25
10
25
1CI
70
937
512
671
383
2,503
68
48
114
17
247
1,005
560
785
400
2,750
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region Total
1,720
10
5
1
3
3
_4
26
107
13
0
0
40
0
310
295
461
413
133
134
1,586
160
1,746
A-3
-------
Table A-l (Concluded)
Bulk Plants and Terminals
EPA Region
Region IX
Arizona
California
Hawaii
Nevada
Bulk
Plants
175
920
10
65
Non-
Attainment attainment
Terminals
10
100
20
10
Areas
121
135
30
48
Areas
64
885
0
27
Total
185
1,015
30
75
Region Total
1,170
140
334
976
1,310
Region X
Alaska
Idaho
Oregon
Washington
Region Total
,S. TOTAL
30
265
355
410
1,060
20,848
50
10
25
60
145
1,791
80
275
278
373
1,006
15,621
0
0
102
97
199
7,018
80
275
380
470
1,205
22,639
A-4
-------
Table A-2
MOTOR GASOLINE STORAGE CAPACITY FOR BULK PLANTS AND TERMINALS
IN 1972 BY STATE AND OXIDANT STATUS (106 liters)
Bulk Plants and Terminals
EPA Region
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region Total
Bulk
Plants
134
Terminals
12
28
65
16
3
11
452
430
457
37
257
120
1,753
Attainment
Areas
0
80
0
1
0
_0
81
Non-
attainment
Area
1,805
Total
464
379
521
52
259
130
464
459
521
53
259
130
1,886
Region II
New Jersey
New York
Region Total
740
99
839
3,351
0
0
1,980
2,210
4,190
4,190
Region III
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region Total
9
1
33
105
78
34
28
5
533
1,066
866
148
259
2,646
13
0
61
9
654
131
23
5
505
1,171
290
51
36
5
565
1,171
944
182
860
2,045
2,904
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region Total
98
108
111
88
104
148
64
80
802
232
195
506
129
0
827
307
53
364
1,370
307
386
266
201
222
681
597
1,565
813
514
266
1,027
529
734
5,244
2249
3,797
6,047
A-5
-------
Table A-2 (Continued)
Bulk Plants and Terminals
EPA Region
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region Total
Bulk
Plants
194
111
124
127
125
155
835
Terminals
Attainment
Areas
Non-
attainment
Area
Total
5,133
1,329
4,639
5,967
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region Total
76
90
33
87
359
645
1,728
72
155
72
93
581
975
1,399
2,373
Region VII
Iowa
Kansas
Missouri
Nebraska
Region Total
153
88
171
59
471
1,074
283
184
417
107
991
188
101
259
5
553
1,544
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region Total
62
47
63
67
22
31
81
58
6
20
20
26
294
212
45
98
70
87
27
58
384
98
8
0
0
15
0
121
143
105
70
87
42
58
505
A-6
-------
Table A-2 (Concluded)
Region Total
U.S. TOTAL
Bulk Plants and Terminals
EPA Region
Region IX
Arizona
California
Hawaii
Nevada
Region Total
Region X
Alaska
Idaho
Oregon
Washington
Bulk
Plants
44
190
3
12
248
4
49
71
75
Non-
Attainment attainment
Terminals
147
1,392
139
88
1,766
143
87
418
614
Areas
23
48
142
8
221
148
136
84
387
Area
167
1,534
0
92
1,793
0
0
406
302
Total
190
1,581
142
100
2,014
148
136
489
689
200
4,725
1,263
24,168
755
7,844
708
21,049
1,463
28,893
A-7
-------
Table A-3
GASOLINE THROUGHPUT FOR TERMINALS, BULK PLANTS, AND OUTLETS IN
1978, BY STATE (109 Liters)
Service Stations
EPA Region Terminals Bulk Plants and Other Outlets Total
Region I
Connecticut 10 * 6 16
Maine 91 2 12
Massachusetts 92 9 21
New Hampshire 1 * 23
Rhode Island 6 * 27
Vermont _3 * 1 4
Region Total 38 4 22 64
Region II
New Jersey 22 22 14 58
New York 45 _4 24 73
Region Total 67 26 38 131
Region III
Delaware * * 1 2
District of Columbia * * 18
Maryland 11 1 8 20
Pennsylvania 22 4 20 46
Virginia 19 2 11 32
West Virginia _1 I _2 §.
Region Total 56 9 44 114
Region IV
Alabama 10 3 8 22
Florida 31 4 18 53
Georgia 15 3 12 30
Kentucky 9 3 8 19
Mississippi 33 5 11
North Carolina 18 5 12 35
South Carolina 10 2 6 18
Tennessee 14 _3 _10 26
Region Total 109 27 79 215
A-8
-------
Table A-3 (Continued)
EPA Region
Terminals Bulk Plants
Service Stations
and Other Outlets
Total
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region Total
25
20
20
5
21
16
106
6
3
4
3
4
_5
26
22
11
19
9
21
91
53
35
43
17
46
30
224
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region Total
1
5
2
2
23
33
2
3
1
2
U
19
5
8
3
8
_33
57
8
16
6
12
67
109
Region VII
Iowa
Kansas
Missouri
Nebraska
Region Total
6
4
10
20
5
3
5
_2
14
7
6
11
28
18
12
26
_6
62
A-9
-------
Table A-3 (Concluded)
EPA Region
Terminals Bulk Plants
Service Stations
and Other Outlets
Total
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region Total
Region IX
Arizona
California
Hawaii
Nevada
Region Total
Region X
Alaska
Idaho
Oregon
Washington
Region Total
U.S. TOTAL
1
1
*
*
3
29
3
_2
36
3
2
9
26
497
2
2
2
2
1
1
2
6
2
2
_3
6
148
6
2
2
2
3
_2
16
5
44
1
_2
53
1
2
5
8
9
4
3
4
4
_3
27
9
79
4
_4
97
4
5
16
23
16
443
48
1,088
*Less than 0.5 x 10? liters
A-10
-------
Table A-4
GASOLINE THROUGHPUT FOR BULK PLANTS AND TERMINALS
IN 1978 BY STATE AND OXIDANT STATUS (10? LITERS)
EPA Region Attainment Areas Nonattainment Areas Total
Region I
Connecticut 0 10 10
Maine 2 8 10
Massachusetts 0 12 12
New Hampshire Oil
Rhode Island 066
Vermont 0 3 3
Region Total 2 40 42
Region II
New Jersey 0 44 44
New York <) 4_9 49
Region Total 0 93 93
Region III
Delaware * * *
District of Columbia 0 * *
Maryland 2 11 13
Pennsylvania 0 26 26
Virginia 15 6 21
West Virginia 314
Region Total 20 45 65
Region IV
Alabama 5 8 13
Florida 5 30 35
Georgia 11 7 18
Kentucky 3 9 12
Mississippi 0 66
North Carolina 19 5 23
South Carolina 7 5 12
Tennessee __!_ 15^ 16
Region Total 51 84 135
A-ll
-------
Table A-4 (Continued)
EPA Region Attainment Areas Nonattainment Areas Total
Region V
Illinois 6 25 31
Indiana 9 14 24
Michigan 4 20 24
Minnesota 459
Ohio 1 24 25
Wisconsin _5_ 16 20
Region Total 30 103 132
Region VI
Arkansas 2 23
Louisiana 358
New Mexico 223
Oklahoma 224
Texas 11 ii I4.
Region Total 21 31 52
Region VII
Iowa 6 4 11
Kansas 426
Missouri 9 6 15
Nebraska _1 _*. _1
Region Total 22 12 34
Region VIII
Colorado 1 2 3
Montana 2*2
North Dakota 202
South Dakota 202
Utah 1*1
Wyoming 1_ () _1
Region Total 9 3 11
A-12
-------
Table A-4 (Concluded)
EPA Region Attainment Areas Nonattainment Areas Total
Region IX
Arizona * 44
California 1 34 35
Hawaii 303
Nevada * 2 2
Region Total 5 39 44
Region X
Alaska 303
Idaho 303
Oregon 2 9 11
Washington 9 7 ^6
Region Total 17 16 33
U.S. TOTAL 176 469 645
*Less than 0.5 x 109 liters
A-13
-------
Table A-5
PETROLEUM PRODUCT PIPELINE LENGTH
AND NUMBER OF PUMP STATIONS BY STATE
EPA Region Length (km) Pump Stations
Region I
Connecticut 151 2
Maine 201 1
Massachusetts 389 4
New Hampshire 0 0
Rhode Island 27 3
Vermont 0 ' _0
Region Total 769 10
Region II
New Jersey 795 3
New York 1,797 _9
Region Total 2,592 12
Region III
Delaware 5 0
Maryland and
District of Columbia 352 3
Pennsylvania 6,455 38
Virginia 1,326 11
West Virginia 685 _0
Region Total 8,824 52
Region IV
Alabama 2,354 15
Florida 378 1
Georgia 3,257 24
Kentucky 159 0
Mississippi 2,407 10
North Carolina 1,442 11
South Carolina 1,075 6
Tennessee 764 _5_
Region Total 11,836 72
A-14
-------
Table A-5 (Continued)
EPA REGION Length (km) Pump Stations
Region V
Illinois 6,302 34
Indiana 4,338 28
Michigan 2,426 14
Minnesota 2', 328 16
Ohio 6,014 30
Wisconsin 747 3_
Region Total 22,156 125
Region VI
Arkansas 1,762 12
Louisiana 4,541 22
New Mexico 2,732 16
Oklahoma 7,572 42
Texas 22,735 134
Region Total 39,342 226
Region VII
Iowa 7,303 18
Kansas 10,867 48
Missouri 6,158 22
Nebraska 3,749 1_3
Region Total 28,077 101
Region VIII
Colorado 1,558 16
Montana 1,496 9
North Dakota 798 4
South Dakota 1,033 9
Utah 492 3
Wyoming 2,257 .15
Region Total 7,635 56
A-15
-------
Table A-5 (Concluded)
EPA REGION Length (km) Pump Stations
Region IX
Arizona 1,556 8
California 4,600 20
Hawaii 0 0
Nevada 442 _!_
Region Total 6,598 29
Region X
Washington 1,147 7
Oregon 666 1
Idaho 1,018 7
Alaska 145 _0
Region Total 2,977 15
U.S. TOTAL 130,806 698
A-16
-------
Table A-6
TERMINALS AND BULK PLANTS OPERATED BY OIL COMPANIES
Major Oil Companies
Amoco Oil Company
Atlantic Richfield Company
Chevron U.S.A. Inc.
Exxon Company U.S.A.
Gulf Oil Company U.S.
Mobile Oil Corp.
Shell Oil Corp.
Texaco Inc.
Subtotal
Terminals
99
59
114
90
123
117
40
n/a
642
Bulk Plants
3,857
Semi-Major Oil Companies
Ashland Oil Company
Cities Service Oil Company
Continental Oil Company
Diamond Shamrock Oil & Gas Company
Getty Refining & Marketing Company
Kerr-McGee Corporation
Marathon Oil Company
Murphy Oil Corporation
Phillips Petroleum Company
Standard Oil Company (Ohio)
Sunmark Industries
Tenneco Oil Company
Union Oil Company of California
Subtotal
50
37
74
9
14
3
41
26
35
33
60
16
81
479
1,411
Independent Oil Companies
Ada Resources Inc.
Agway Petroleum Corporation
American Petrofina Inc.
Amos Post Inc.
Arkla Chemical Corporation
Asamera Oil (U.S.) Inc.
Beacon Oil Company
Campbell Oil Company
CENEX
Charter Marketing Company
Clark Oil & Refining Corporation
0
13
13
2
0
1
3
0
7
1
11
11
144
0
2
3
0
0
2
0
0
0
A-17
-------
Table A-6 (Continued)
Terminals Bulk Plants
Independent Oil Companies (Continued)
Colonial Oil Industries Inc. 2 2
Colonial Service Stations Inc. 1 0
Consumer Petroleum Company 0 1
Cook & Cooley Inc. 1 0
De Blois Oil Company 0 4
Derby Refining Company 1 0
Elm City Filing Stations Inc. 1 2
Englefield Oil Company 0 8
Etna Oil Company 1 1
PCX Inc. 0 17
Don Foster Oil Company 0 3
Giant Industries Inc. 1 0
Gresham Petroleum Company 0 1
Guttman Oil Company 1 1
Harris Enterprises Inc. 0 4
Harrell Petroleum Company & Osage Oil Co. 0 3
High Point Oil Company 0 16
Angus J. Hines Inc. 0 3
Barney Holland Oil Company 0 1
Horn Distributing Company Inc. 0 1
Hotchkiss Oil Company Inc. 2 2
Kellam Distributing Company Inc. 0 6
Kelley Williamson Company 0 9
Kent Oil Company 1 1
Kicks poo Oil Company Inc. 0 2
Kimber-Allen Petroleum Corporation 0 1
Lehigh Oil Company Inc. 3 2
Lion Oil Division of Tosco Corporation 5 20
Martin Oil Service Inc. 0 1
McDowell Oil Service Inc. 0 1
McLeieer Oil Inc. 0 5
Meade Oil Co. 0 1
Merril Truax Inc. 0 4
Midland Cooperatives Inc. 3 272
The Miller Oil Company 1 3
Montour Auto Service Company 2 2
Naph-Sol Refining Company 3 34
National Oil & Gas Inc. 0 8
Newell Oil Co. Inc. 0 3
R. B. Newman Fuel Corporation 1 1
Orlean Oil Company 0 3
Curtis Parker Oil Company Inc. 0 3
A-18
-------
Table A-6 (Concluded)
Independent Oil Companies (Continued)
Parker Oil Company Inc.
Pennzoil Company
Petroleum Marketeers Inc.
Piasa Motor Fuels Inc.
Plateau Inc.
Port Oil Company
Power Test Corporation
Powerine Oil Company
Pride of Texas Oil Company Inc.
Pride Oil Company
Publix Oil Company
Pugh Oil
Quaker State Oil Refining Corporation
Quality Oil Company
Reinhardt Oil Corporation
Rich Distributors Inc.
Ryan-DeWitt Corporation
Santee Oil Company
Shelby Petroleum Corporation
The Sico Company
Sigmor Corporation
Smith-Shafter Oil Company
SMO Inc.
Southern Union Ref. Company
Southland Oil Company
J. D. Street & Company Inc.
Tanner Oil Company
Tesoro Petroleum Corporation
Texas City Refining Inc.
Thunderbird Petroleum Inc.
Time Oil Co.
Total Petroleum Inc.
Trenton Oil Co. Inc.
Tresler Oil Company
United Refining Company
Webaco Oil Company Inc.
J. H. Williams Oil Company
Subtotal
Terminals
1
6
1
0
2
0
3
5
0
0
2
2
4
0
0
1
0
0
0
1
1
0
1
1
1
3
1
3
1
0
8
5
1
3
4
1
0
194
Bulk Plants
10
8
11
4
4
3
0
0
1
1
0
2
8
7
5
0
4
4
1
13
n/ a
1
12
0
0
0
0
4
0
9
0
8
1
7
38
6
3
796
TOTAL
1,315
6,064
A-19
-------
Table A-7
PRODUCTS PIPELINE COMPANIES
Allegheny Pipeline Co.
American Liberty Pipe Line Co.
American Oil Co.
Apco Products Pipe Line Co.
Arbuckle Pipe Line Co.
ARCO Pipe Line Co.
Ashland Oil & Refining Co.
Atlantic Pipe Line Co.
Badger Pipe Line Co.
Bayou Pipe Line System
Black Mesa Pipeline, Inc.
Buckeye Pipe Line Co.
Bureau of Mines (Dept. of the Interior)
Calnev Pipe Line Co.
CENEX Pipeline Co.
ChampZin Petroleum Co.
Chaparral Pipeline
Cherokee Pipe Line Co.
Chevron Pipe Line Co.
Cheyenne Pipeline Co.
Cities Service Oil Co.
Cities Service Pipe Line Co.
Coastal States Gas Producing Co.
Cochin Pipe Lines Ltd.
Collins Pipeline Co.
Colonial Pipeline Co.
Continental Pipe Line Co.
Derby Refining Co.
Diamond Shamrock Oil & Gas Co.
Dixie Pipeline Co.
El Paso Natural Gas Co.
Emerald Pipe Line Co.
Everglades Pipe Line Co.
Getty Pipe Co.
Gulf Central Pipeline Co.
Gulf Oil Corp.
Gulf Oil Canada Ltd.
Harbor Products System
Humble Pipe Line Co.
Hydrocarbon Transportation, Inc.
A-20
-------
Table A-7 (Continued)
Imperial Oil Enterprises Ltd.
Indiana Farm Bureau Coop. Assn., Inc.
Inland Corp.
Jet Lines, Inc.
Kaneb Pipe Line Co.
Kerr-McGee Corp.
Laurel Pipe Line Co.
Marathon Pipe Line Co.
Medicine Bow Products Pipeline System
Mesquite Products Pipe Line
Miami Valley Corp.
Mid-America Pipeline Co.
Mobil Pipe Line Co.
National Coop. Refinery Assn. (NCRA)
National Pipeline Co.
Natioral Transmission Corp.
Northern Michigan Pipeline Co.
Okan Pipeline Co.
Okla., Miss. River Products Line, Inc. (OMR)
Olympic Pipe Line Co.
Petroleum Transmission Co.
Phillips Pipe Line Co.
Pioneer Pipe Line Co.
Planatation Pipe Line Co.
Pure Transportation Co.
River Pipeline Co.
San Diego Pipeline Co.
Santa Fe Pipeline Co.
Seadrift Pipeline Corp.
Service Pipe Line Co.
Shell Oil Co.
Shell Pipe Line Corp.
Shoshone Pipelines, Ltd.
Skelly Oil Co.
Sohio Pipe Line Co.
Southern Pacific Pipe Lines, Inc.
Southwest Transmission Corp.
Standard Oil Co. of California (Socal)
Standard Transmission Corp.
A-21
-------
Table A-7 (Concluded)
Sun-Canadian Pipe Line Co. Ltd.
Sun Pipe Line Co.
Tenneco Oil Co.
Texaco-Cities Service Pipe Line Co.
Texas Eastern Transmission Corp. (T.E.T.)
Texas Eastman Co.
Texas Pipe Line
Trans-Northern Pipe Line Co.
Trans-Ohio Pipeline Co.
Trust Pipe Line Co.
Tuloma Gas Products
United Refining Co.
Wabash Pipe Line Co.
Wanda Petroleum Co.
Warren Petroleum Corp.
West Emerald Pipe Line Co.
West Shore Pipe Line Co.
Williams Brothers Pipe Line Co.
Wolverine Pipe Line Co.
Wyco Pipe Line Co.
Yellowstone Pipe Line Co.
A-22
-------
Appendix B
METHODOLOGY AND SOURCES OF DATA FOR THE GASOLINE MARKETING CHAIN
Gasoline Flow
Gasoline consumption in 1977 was 428 billion liters (Federal High-
way Administration as reported in National Petroleum News, 1978b). The
increase in consumption between the first half of 1977 and the first
half of 1978 was 3.4% (Energy Information Administration, 1978b,
1978c). Extrapolating that rate of increase to all of 1978 gives a
total gasoline consumption of 443 billion liters. (Because aviation
gasoline is only 0.5% of total gasoline, we have disregarded the dis-
tinction between motor gasoline and aviation gasoline.) Imports provide
approximately 10 billion liters (Energy Information Administration,
1978b, 1978c), while the refineries produce 433 billion liters.
The Bureau of Census (1975) reports gallon sales of gasoline to
retailers and consumers by bulk stations and terminals in 1972. Adjust-
ing these figures for establishments not reporting gallon sales and ap-
plying the percentages of total 1972 gasoline consumption that these
gallon sales represent to the 1978 total gasoline consumption gives 210
billion liters delivered to retailers and consumers from terminals, and
148 billion liters from bulk plants. The remaining 85 billion liters of
gasoline consumption must then come directly from the refineries.
That leaves 348 billion liters going from the refineries to the
terminals and bulk plants. The 348 billion liters was allocated between
bulk plants and terminals, and by transportation mode to the terminals,
on a judgmental basis.
The total shipments of gasoline by pipeline in 1977 were approxi-
mately 340 billion liters (Energy Information Administration, 1978b).
Gasoline shipments by water were approximately 121 billion liters (Corps
of Engineers, 1975). The gasoline shipments by pipeline and water car-
riers between terminals (mostly from pipeline and marine terminals to
distribution terminals) were calculated as the differences between those
totals and the estimated shipments from refineries to terminals.
The data on shipments of gasoline from the Texas-Louisiana area to
the East Coast and Midwest are from the Energy Information Adminis-
tration (1978b).
The volume of gasoline sold by service stations is based on data on
such sales for 1977 (Energy Information Administration, 1978d)
extrapolated to the 1978 consumption level.
B-l
-------
Inventory of Terminals, Bulk Plants, and Service Stations
The 1972 Census of Wholesale Trade (Bureau of the Census, 1975)
gives the number of bulk plants and terminals separately by state, and
the number of bulk plants and terminals combined by county. Data from
the 1977 census will not be available until mid or late 1979. We esti-
mated the number of bulk plants and terminals in 1978 from data in
National Petroleum News (1978), data on pipeline terminals from the Oil
and Gas Journal (1970), and extrapolation to 1978 of the rate of change
in the numbers by region between 1967 (Bureau of Census, 1970) and 1975.
The figures on the number of service stations by state in 1978 are
estimates from National Petroleum News (1978a), which were based on an
estimate by the Department of Commerce (1978) of the total number of
service stations in the United States. The estimate of 240,000
gasoline-dispensing facilities other than service stations is from Mawn
(1978).
Oxidant Attainment Status
We classified the gasoline chain components by oxidant status using
a list from EPA of the counties not meeting the national ambient air
standards for one or more pollutants, dated 23 April 1979.
The census (Bureau of the Census, 1974-1975, 1975) gives the number
and gasoline storage capacity of bulk plants and terminals combined, and
the number of service stations by county. We determined the 1972 num-
bers for each category of county, and prorated those nunbers to the es-
timated state totals for 1978.
Gasoline Storage Capacity of Bulk Plants and Terminals
The census (Bureau of the Census 1970, 1975) gives the gasoline
storage capacity of bulk plants and terminals in 1967 and 1972 separate-
ly by state. The 6% rate of increase in storage capacity between 1967
and 1972 was much less than the 30% rate of increase in gasoline con-
sumption (from 288 billion to 375 billion liters; Bureau of Mines, 1968,
1973). Because the 18% rate of increase in gasoline consumption between
1972 and 1978 is only about half the rate of increase between 1967 and
1972, we estimate only a 3% increase in storage capacity between 1972
and 1978. For the purposes of this report, a 3% change is insignifi-
cant, and for simplicity we have left the 1972 data unchanged.
The census (Bureau of the Census, 1970, 1975) also gives the number
of terminals and bulk plants combined in each size range of total stor-
age capacity for all products. We estimated the number of terminals and
bulk plants in each storage capacity size range in 1978, based on the
percent changes in the numbers of facilities in each size range between
1967 and 1972. We estimated the gasoline storage capacity size ranges
associated with each total storage capacity size range for all products,
B-2
-------
based on the gasoline storage capacity as a percent of the total product
storage capacity in each storage size range in 1972.
Gasoline Throughput of Terminals, Bulk Plants, Service Stations, and
Other Outlets
The gasoline throughput by state for service stations and other
gasoline outlets is based on gasoline consumption in 1977 (National
Pecroleum News, 1978b), prorated to the estimated national consumption
of 443 x 109 liters in 1978.
We estimated gasoline throughput for bulk plants and terminals by
apportioning the estimated total national throughput in proportion to
gasoline storage capacity. This procedure slightly overestimates the
throughput in urban nonattainment areas, and underestimates the through-
put in attainment areas and other rural areas, because terminals, which
have a lower ratio of throughput-to-storage capacity than bulk plants,
are concentrated more in the urban nonattainment areas.
The number of bulk plants and terminals in each gasoline throughput
size range was estimated from the estimated nunber of facilities in each
gasoline storage capacity size range. Because the census does not give
storage capacity size range data for terminals and bulk plants separate-
ly, we used a gasoline storage capacity of more than 3.8 million liters
to represent terminals, and less than 3.8 million liters to represent
bulk plants. Extrapolating from the change in gasoline storage capacity
between 1967 and 1972, the estimated gasoline storage capacity of ter-
minals and bulk plants is 26 billion and 3.4 billion liters, respective-
ly. Based on the total annual gasoline throughputs for terminals (497
billion liters) and bulk plants (148 billion liters) and the estimated
total gasoline storage capacities for each category of facility, the
average annual gasoline throughputs of terminals and bulk plants are 19
liters and 43 liters per liter of gasoline storage, respectively. Ap-
plying these factors to the gasoline storage capacity size ranges gives
the estimated gasoline throughput size ranges.
Transportation
The petroleum product pipeline mileage by state is from the Energy
Information Administration (1978a). The pump stations on these pipe-
lines were counted from a pipeline map (Oil and Gas Journal, 1970).
The number of tank barges used to ship petroleum and petroleum
products is from the American Waterways Operators, Inc. (1973). The
number of tankers in domestic trade is from the Bureau of Census
(1977). Sizes of water carriers are from American Waterways Operators,
Inc. (1973) and the U.S. Senate (1977).
The number of general purpose, non- and low-pressure tank trucks is
from the National Petroleum Council (1967). (This number excludes dry
B-3
-------
bulk, chemical, food, and sanitary trucks.) The data do not show how
many of these tank trucks are used to transport gasoline, but we expect
that most of them are. The National Petroleum Council is just beginning
a new survey of petroleum transportation capacities. We have used the
1967 figure (rounded) for general purpose tank trucks to represent
gasoline tank trucks. The number of tank trucks used for gasoline will
have grown since 1967, but not all general purpose tank trucks are used
for gasoline.
The number of railroad tank cars (rounded) is from the Interstate
Commerce Commission (1976). The data do not indicate how many of these
are used for gasoline, but in view of the very limited use of rail to
transport gasoline, the number of tank cars used for that purpose must
be quite small. The quantity of gasoline transported by rail is from
the Department of Transportation (1976).
Ownership of Terminals and Bulk Plants
The data on the numbers of bulk plants and terminals operated by
oil companies are from National Petroleum News (1978a). The list of
products pipeline companies is from the Oil and Gas Journal (1970).
B-4
-------
BIBLIOGRAPHY, APPENDIX B
American Waterways Operators, Inc., Big Load Afloat; U.S. Domestic Water
Transportation Resources, Washington, D.C. (1973).
Bureau of the Census, "Census of Business, 1967, Wholesale Trade:
Petroleum Bulk Stations and Terminals," BC67-WS6, Washington, D.C.
(1970).
, "Census of Retail Trade, 1972, Area Series," RC72-A,
Washington, D.C. (1974-1975).
, "Census of Wholesale Trade, 1972, Subject Series, Petroleum
Bulk Stations and Terminals," WC72-S-2, Washington, D.C. (1975).
, "Statistical Abstract of the United States: 1977,"
Washington, D.C. (1977).
Bureau of Mines, "Petroleum Statement, Monthly: December 1967,"
Washington, D.C. (1968).
, "Petroleum Statement, Monthly: December 1972," Washington,
D.C. (1973).
Corps of Engineers, "Waterborne Commerce of the United States,"
Washington, D.C. (1975).
Department of Commerce, "Franchising in the Economy: 1976-1978,"
Washington, D.C. (January 1978).
Department of Transportation, "Energy Statistics," DOT-TSC-OST-76-30,
Washington, D.C. (August 1976).
Energy Information Administration, "Crude Oil and Refined Products
Pipeline Mileage in the United States," Triennial Reports, Washington,
D.C. (January 1978a).
, "Petroleum Statement, Monthly: December 1977 and June
1978," Washington, D.C. (May 1978b and October 1978c).
, "Petroleum Market Shares: April 1978," Washington, D.C.
(September 1978d).
Interstate Commerce Commission, "Transport Statistics in the United
States for 1976, Part 4, Private Car Lines," Washington, D.C. (1976).
B-5
-------
Mawn, P. E., "The Economic Impact of Vapor Recovery Regulations on the
Service Station Industry," EPA-450/3-78-029, Environmental Protecion
Agency, Research Triangle Park, North Carolina (July 1978).
National Petroleum Council," U.S. Petroleum and Gas Transportation
Capacities" (September 1967).
National Petroleum News Factbook Issue, Mid-June 1978, McGraw-Hill, New
York (1978a).
National Petroleum News, McGraw-Hill, New York (September 1978b).
Oil and Gas Journal, Petroleum Publishing Company, Tulsa, Oklahoma
(October 12, 1970).
U.S. Senate, "National Energy Transportation," Publication No. 95-15,
Washington, D.C. (May 1977).
B-6
-------
Appendix C
STATE HYDROCARBON EMISSION REGULATIONS
This appendix summarizes the HC regulations of each state. The
regional summaries of state regulations in Chapter II are based on the
data in this appendix.
Siimmary of State Regulations
Table C-l shows those states that have existing regulations per-
taining to each type of source. Table C-2 shows the changes between the
former regulations and the new State Implementation Plans (SIPs) in the
storage capacity or throughput cutoff for storage and transfer con-
trols on existing sources. The Control Technique Guidelines (CTGs)
recommend that storage controls be applied to tanks with storage capa-
city greater than 40,000 gal, that bulk plant transfer controls be ap-
plied to facilities with daily throughput greater than 4,000 gal, and
that transfer controls for terminals be applied to facilities with daily
throughput greater than 20,000 gal.*
Table C-3 shows those states that had substantial controls on ex-
isting terminals, the types of those controls, and those states that
have added or changed the controls in their new SIPs. Terminal controls
largely consist of either vapor control systems (VCS) or vapor recovery
systems (VRS).
A VCS designates any system that prevents release of vapors to the
atmosphere, whereas a VRS is a VCS that converts the vapor to gasoline.
In the former regulations, seven states required only submerged or bot-
tom fill for the tank trucks, and not vapor control. For bulk plants,
the principal controls are submerged or bottom fill for the tank trucks,
and a vapor balance system to collect vapors displaced from the storage
tanks and tank trucks. Table C-4 shows those states that had such con-
trols under the former transfer regulations and those states that in-
clude such controls in their new SIPs.
The state regulations promulgated earlier are generally given in
terms of storage controls and transfer controls, rather than specifi-
cally addressing terminals or bulk plants. Table C-5 shows the former
state storage and transfer controls for each principal type of reason-
ably available control technology (RACT) option identified in the model
regulations developed by EPA for 1979 SIP revisions. Several controls
are noted along a horizontal line in the table. They are generally al-
ternatives, not multiple requirements. For storage controls, the model
*We use English units instead of metric units in this Appendix in those
cases where regulations are stated in English units.
C-l
-------
RACT regulations specify submerged fill for stationary tanks of 250 gal
or more and floating roofs for tanks greater than 40,000 gal that
contain petroleum liquids with vapor pressure greater than 1.5 psi but
less than 11 psi. Alternatives to a floating roof include VCS (or
VRS), incineration, or other approved equipment. For transfer controls,
the elements of RACT in the model regulations include: submerged or
bottom fill of tank trucks; vapor control (or recovery) systems or other
approved equipment for facilities with daily throughput greater than
20,000 gal; and vapor balance systems for facilities with daily
throughput between 4,000 and 20,000 gal. The model regulations also
contain leak prohibitions and work practices (e.g., no open dumping of
gasoline). Table C-5 indicates how closely the former state regulations
matched the RACT requirements.
Not shown in Table C-5 is the common specification of 95 to 97%
submerged fill. Nor does the table show the common prohibition of using
floating roof tanks to control liquids with vapor pressure higLer than
11 or 12 psi.
Method
We began by excerpting the regulations for each state pertaining to
HC emissions from the BNA Environmental Reporter* as of October 1978.
We then interviewed state officials by telephone to obtain their inter-
pretations of each state's regulations and plans to conform with the new
RACT guidelines.
We summarized the state regulations and then identified the regu-
lations that corresponded with the elements of the EPA model regulations
or CTGs. Because the resulting tables proved more detailed than neces-
sary, the most important features of RACT were selected and existing
state rules similar to those features were noted.
We also obtained information on the new SIP submittals by visits to
OAQPS in Durham, North Carolina, and by telephone calls to state offi-
cials. The main requirements of these new 1979 SIP revisions are shown
in Tables C-2 to C-4.
*The Bureau of National Affairs, Inc., "Environmental Reporter, State
Air Laws" (various dates).
C-2
-------
Table C-l
STATES WITH REGULATIONS PERTAINING TO EACH TYPE OF SOURCE
Ship
Ter- Bulk Tank Barge
EPA Region minals
Region I
Connec-
ticut Xa
Maine
Massachu-
setts Xa
New
Hamp-
shire
Rhode
Island Xa
Vermont
Region II
New Jersey X
New York X
Region III
Delaware X
District
of Columbia Xa
Maryland X
Pennsylvania Xa
Virginia Xa
W. Virginia
Region IV
Alabama xa
Florida
Georgia
Kentucky Xa
Mississippi
N. Carolina Xa
S. Carolina
Tennessee X
Plants
X
X
X
X
X
Xa
X
X
xa
xa
xa
X
X
Trucks
X
X
xa
X
xa
xa
Pipe
Line
Service
Stations
Other
Gasoline
Outlets
X
X
X
X
C-3
-------
Table C-l (Concluded)
EPA Region
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Ter-
minals
Xa
Xa
X
Xa
X
Ship
Bulk Tank Barge Pipe
Plants Trucks Rail Line
X X
X
Service
Stations
X
X
Other
Gasoline
Outlets
X
Region VI
Arkans as
Louisiana
New Mexico
Oklahoma
Texas
Region VII
xa
aApplies only to designated local ties.
C-4
X
X
X
X
Iowa
Kansas
Missouri
Nebraska
Region VIII
Colorado
Montana
N. Dakota
S. Dakota
Utah
Wyoming
Region IX
Arizona
California
Hawaii
Nevada
Region X
Alaska
Idaho
Oregon
Was hi ngt on
XXX X
X X
Xa Xa Xa X X
XX X
X
X
X
X
X X X X X
Xa Xa Xa XX
X
X
X
X
X
X
X
-------
Table C-2
CHANGES IN STATE CUTOFFS a FOR APPLICATION OF STORAGE AND TRANSFER CONTROLS
Storage Controls:
Minimum Storage
Capacity (10 gal)
Former
EPA Region Rule
Region I
Connec-
ticut
Maine
Massachu-
setts
New
Hamp-
shire
Rhode
Island
Vermont
Region II
New Jersey
New York
Region III
Delaware
District
of Columbia
Maryland
Pennsylvania
Virginia
W. Virginia
Region IV
Alabama
Florida
Geor gi a
Kentucky
Mississippi
N. Carolina
S'. Carolina
Tennessee
40
40
b
b
_ _
40
40
40
40
60
40
50
New
SIP
40
39
40
40
40
40
35
40
40
40
40
40
b
40
40
42
40
40
37
40
40
Transfer Controls:
Minimum (Maximum) Daily
Throughput (10 gal)
Bulk Plants Terminals
Former New
Rule SIP
Former New
Rule SIP
4 (10) 10 10
20
(20) 20 20
20
(40) (20) 40 20
20
15
40
20
b (40)
(20)
(20)
(20) b
20
20
100C 50
2 (20)
(20)
(20)
(20)
20
20
40
b
20
100C
20
d
f
20
20
20
C-5
-------
Table C-2 (Continued)
Storage Controls:
Minimum Storage
Capacity (10 gal)
EPA Region
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Former
Rule
40
40
40
65
New
SIP
40
40
b
40
40
Region VI
Arkans as
Louisiana 50
New Mexico
Oklahoma
Texas 25
Region VII
Iowa
Kans as
Missouri
Nebraska
Region VIII
Colorado 40
Montana 65
N. Dakota
S. Dakota
Utah
Wyoming
Region IX
Arizona 65
California 40
Hawaii 40
Nevada
37
10
40
b
25
40
40
0.55
40
65
40
40
40
Transfer Controls:
Minimum (Maximum) Daily
Throughput (10 gal)
Bulk Plants
Former
Rule
^,
(20)
New
SIP
e
g
b
e,4
h
(23)
(20)
(20)
b
4 (20)
100C
2 (20)
h
b
Terminals
Former
Rule
40
40
40
«»
H^
40
20
20
New
SIP
f
i
b
f
f
23
20
20
b
20
20
20
f
b
3.4
(20)
20
i
20
C-6
-------
Table C-2 (Concluded)
EPA Region
Region X
Alaska
Idaho
Oregon
Washington
Storage Controls:
Minimum Storage
Capacity (10 gal)
Former
Rule
New
SIP
40
37
40
Transfer Controls:
Minimum (Maximum) Daily
Throughput (10 gal)
Bulk Plants
Former New
Rule SIP
h
e
Terminals
Former New
Rule SIP
f
j
Cutoff shown only if it applies to existing as well as new sources.
^Uncertain.
cMinimum emissions (tons per year).
"Loaded by ship or pipeline.
eReceives by truck.
^Receives by pipeline.
SLess than 5 x 106 gal/y.
"Receives from terminal.
^ore than 5 x 106 gal/y.
^Receives 40% from truck.
C-7
-------
EPA Region
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region II
New Jersey
New York
Region III
Delaware
District
of Columbia
Maryland
Pennsylvania
Virginia
W. Virginia
Region IV
Alabama
Florida
Geor gi a
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Table C-3
CHANGES IN STATE CONTROLS ON TERMINALS
Former Rule New SIP
VCS
VRSC90Z)
SF, BF
SF, white paint
VB, VRS (90Z)
VR
VR (90Z)
SF, BF
VB, BRS (90Z)
SF
VRS (85Z)
SF, BF
VB, VRS (90Z)
VRS (80 mg/liter)
SF, VRS (80 mg/liter)
VRS
VRS (80 mg/liter)
VRS (80 mg/liter)
VRS (80 mg/liter)
VCS (sliding scale)
VCS
VRS (90Z, 80 mg/liter)
VRS (90Z)
VRS
U
D
VCS
SF, VCS (80 mg/liter)
VCS (80 mg/liter)
VCS (90Z, 80 mg/liter)
VCS (80 mg/liter)
VCS (80 mg/liter)
VCS (80 mg/liter)
VCS (80 mg/liter)
VCS
U
VCS (90Z, 0.7 lb/103
gal)
U
VCS (0.67 lb/103 gal)
VCS (80 mg/liter)
C-8
-------
Table C-3 (Concluded)
Region VI
Arkans as
Louisiana
New Mexico
Oklahoma
Texas
Region VII
Iowa
Kansas
Missouri
Nebraska
Region VIII
Colorado
Montana
N. Dakota
S. Dakota
Utah
Wyoming
Region IX
Arizona
California
Hawaii
Nevada
Region X
Alaska
Idaho
Oregon
Washington
Former Rule
SF, BF (95%)
SF, VRS
New SIP
SF, VCS (80 mg/liter)
VCS (90%, 80 mg/liter)
VCS (90%, 1.24 lb/103
gal)
U
VCS (0.67 lb/103 gal)
VCS (0.67 lb/103 gal)
SF, VRS (0.5 gm/gal)
VB, VCS (1.24 lb/103 gal) VRS (80 mg/liter)
U
SF
VCS (0.64 lb/103 gal)
VCS (90%)
VR (0.9 lb/103 gal) VR (0.9 lb/103 gal)
SF
SF, VCS (90%)
VCS (90%, 80 mg/liter)
SF, BF, VRS (90%, 80
mg/liter)
Legend:
VCS = Vapor control system
VRS = Vapor recovery system
SF = Submerged fill
BF = Bottom fill
VB
90%
80 mg/liter
U
Vapor balance
90% by weight
recovery efficiency
Permissible emission
per unit throughput
Uncertain or
conflicting data
C-9
-------
Table C-4
CHANGES IN STATE TRANSFER CONTROLS a ON BULK PLANTS
Submerged/Bottom Fill Vapor Balance
EPA Region Former Rule New SIP Former Rule New SIP
Region I
Connecticut X X
Maine -
Massachusetts X X
New Hampshire
Rhode Island X X X
Vermont
Region II
New Jersey ~ X ' X
New York X -- X
Region III
Delaware X X
District
of Columbia X XXX
Maryland
Pennsylvania X X
Virginia X b X b
W. Virginia
Region IV
Alabama X X X
Florida ~ X X
Georgia X
Kentucky XXX
Mississippi
North Carolina X X
South Carolina X X
Tennessee X X
Region V
Illinois X X -- X
Indiana b b
Michigan X X
Minnesota b b
Ohio XX X
Wisconsin X
C-10
-------
Table C-4 (Concluded)
EPA Region
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region VII
Iowa
Kans as
Missouri
Nebraska
Region VIII
Colorado
Montana
N. Dakota
S. Dakota
Utah
Wyoming
Region IX
Arizona
California
Hawaii
Nevada
Region X
Alaska
Idaho
Oregon
Washington
Submerged/Bottom Fill Vapor Balance
Former Rule New SIP Former Rule New SIP
X
X X
V »
b b
X ~ X
X
X
X
b
X
X
X
X
X
X
b
X
X
X
X
X
Excludes submerged fill pipe requirement usually keyed to stationary tanks
greater than 250 gal. Most states have such a requirement.
^Uncertain or conflicting data.
C-ll
-------
Table 0-5
SUMMARY OF STATE HYDROCARBON REGULATIONS RELATING TO STORAGE AND TRANSFER
Storage Controls
Transfer Controls
4*
M
0
4J
g
O
k!
o
o
et
U>
c
9
c
o
rt
«
H
t a i
V t- S
b > *i i* P. u
0 O (1 *- «l -*4 41
t-t U
o o
£ ^ 5
**" 2.*!'"" I. i
w
«
E
£' S .i
0 « ;) u «
«-* ^^ > en I*.
Region I
Connecticut1 X.0,000 N RN
> 250
N N
R2 N R2 M
. .
M>\3-HO *
> w in u, OD p>
> 10, 000
M fl * u
« O I-
« k. Ob
-> a- 3 e.
Ma ine
None
O
I
Massachusetts >40,000
>250
New Hampshire
Rhode Island3 >40,000 X RX
>250
> 20,000
None
> 40, 000 X X X
90Z
Vermont
None
X « Applies to all sources and facilities
N * Applies to new sources only, i.e., after effective date of regulations
C * Applies to exist ing sources only, i.e., in place or in process of construction or substantial mod ification
as of date of regulations' effectiveness.
R a Restricted application.
* - Applies only to designated localities
Supersetipt numbers refer to footnotes at end of table.
-------
Table C-5 (Continued)
O
Storage Controls
Transfer Controls
c
) bo
Region II
NPW Jersey4 > 2,000
> 10,000,
varies
by VP
>1,000
and
VP >I3
psi
\f V
0 4->
« >. ~>
M > OS
Paint
white
90Z
98*
Vessel
> 2,000 gal
capac ity
-- Vapor tight N
except for
pressure re-
lief
New York
None
None
Region III
Delaware5 >40,0005 N
None
District of >'<0,000
Columbi a
Loading
Into >250
gal capa-
city vessel
Pre-1974
<2,000 gal
. capaci ty
90%
90Z
Maryland
>40,000
-------
Table C-5 (Continued)
O
I
Storage Controls
"o *o c
£ o o «
U £ .-4 C «
C M -O *J W 3 ^
? * s t & g * II
«t ti t-> B u M *°
.5 SS |s S | | 8 S^
Pennsylvania >M>,000
Virginia8 ><0,000
West Virginia
B
M *>
o *»
&- »
X*
X*
O M
X*
None
f*
o
U
Transfer Controls
U>t-&
OOW-r<
(x u jr D
-
> 20, 000 X*
90Z >20,000 X*
< 20, 000 -- X7 *
into>?,000
gal capa-
city
vessel'
X*
None
9051
90Z
.* .C .V. t.
«O I. ni
0> M C >
Region IV
Alabana10
> 60 ,000 N E* H E* H E* N E*
> 11,000 N E* -- ME* Hi IE*
>50,000
N E* N E* N E*
lnto>!,000 HE* N E* ME*
gal capa-
city vessel
95Z
95X
HE* N E*
N E*
Florida
None
Georgia
Kentucky 12
500 to
40,000
>M),000
None
-- N E* M E*
HE* N E*
> 20, 000
N E*
N E* N E* N E*
DOS N E* N E*
Misa L9a ippi
Hone
None
-------
Table C-5 (Continued)
O
I
North Carolina
South Tirol ina
Tennessee '*
Region V
Illinois
Indiana15
Mich igan
Minnesota1*
Ohio"
Wise on sin2*
Storage Controls
0 O C
v* o o
U OS -r4
V C W V *J
N O QC V) >> V C
- * O C W I. M V
t/1 e -^ « W ^ £
X -* O " w -r« OO B ~* tt * V
C w O-M O U O. u JS - .C D £
« M «>. r-< c <«V 3-^ucr u
H ^ C> OT [< v-t >K Mb«OUJ O
>')0,000 X -- X X
None
>40,000 N2 N N
>40,000 XX X -- X --
>250 X X X X
>40,000 N E* N E* N E* N E*
> 250 N E* N E* N E*
None
2,000 to E17 E E
65,000
>65,000 -- E18 E E
2,000 to N17 N N N
40,000
>40,000 N18/ N N
> 65, 000 N E* N20 E N E* N E*
>500 N E* -- N E* N E*
>40,000 N N17 N -- N
>l,000 N N N N N
Transfer Controls
V in
0 o >
<*j MM O.«£^H u a. o-uj=3 £ ^3-<^ O « vtiutr u u-< QJM
90Z > 20, 000 X -- -- -- X -- X
None
None
85Z >40,000 -- X|(l -- -- -- X1*
85Z
?40,000 N E* NUE* N E* -- -- N14E* ----- N g*
None
None
90Z > 40, 000 N E* -- -- N E* N E* N E* -- 90Z N E*
? 40, 000 N N N -- N
^40,000 -- -- N
-------
Tattle C-5 (Continued)
Storage Controls
Transfer Com rol s
41
N
IA
a t
CO
Region VI
Arkansas
Louisiana > 40, 000
> 50, 000
>250
n
1 N«w Mexico >250
^ >65,000
Oklahoma > 40, 000
>250
Texas >25,000
>t,000
Vapor Control
System
JFloating Roof
N N17
E E17
E E
N
N N17
N N
X* X ' 7*
X*
« >~ v c
t* t< 60 V
* 41 t. i
C M > «l » P. *4
^ o o i *j ^, *
u D- 0 Jr>X3 £
C 3-HUCT *j
(-4 > PC U) l>4 O Id O
None
N -- N
E E
X X X
E E
N N
N N
N N N
X* ~ X*
X* X* X*
(Effectiveness!
1
35Z
asz
rt 11
O u
»4 r- > C
O.'x 0«i feTl^c
« 000 MMV
oo-o B k B » i
3 ^ MftiW O »* fe > »4 (V. M
JZ 0» *1 iV, S * O W u O* M 1*4
P ;> «« «o n. « > > a o u) o ui
None __
> 20, 000 N N N N
> 40, 000 E E E E
N ~ -- N
> 40, 000 N N N -- 90X
< 40, 000 N
> 20, 000 -- X* X*
Transfer -- X22* ~ X22*
into>l ,000
gal capa-
city veaael
i |L"k
i (Prohibitions
, Work
1 Practices
N N
E E
N E N E
N N
N
X
Region VII
Iowa
Kansas
Missouri
> 40,000 H N
None
None
None
None
None
-------
Table C-5 (Continued)
Storage Controls
Trans fer Cont rols
O
I
M
r-t **4
O O C
v. o o
N O to a > «) C
.2 0 C V. I. M «>
t/i B ' w v u 0
_*d* O»J W -^ OO 0 _ 01 -H 41
5 « S" ?, ° c f « a - £ 5- £
H --? > i" I" "-1 > n: u, o u O
Nebraska None
Region VIII
Colorado23 >40,000 X X17 X X
Montana26 >65,000 R27X R X R X R X
>250 R X -- R X
North Dakota >65,000 N N N N
South Dakota >40,000 N N N
Utah >40,000 N -- N N
Wyoming > 65, 000 N' N N
Region IX
Arizona > 65, 000 XX ----- x --
< 65, 000 -- -- -- N N
California28 >40,000 X X17 X X X
>250 -- X X
--» ** m
&>. OOltjulIXc "HI
'S'S "BV- B'""' C f> "
O O u B * u ooo 4i--< at J^jr^y
U P^-- >ww:U. tf) >>oc otn o w ^JD-30u
None
> 20, 000 X X X -- 1.2'< It./ X X
1,000 gal
<20, 00024 XX X25 x25 1.15 It./
1 ,000 gal
None
>20,000 N N N -- N
None
None
None
y V X
>5 million X ----- X X -- 0.9 It./ X X
gal/yrar 1,000 g,i 1
Other -- X -- -- -- -- 951
-------
Table C-5 (Concluded)
O
00
Hawaii
Nevada
Region X
Alaska
Idaho
Oregon
Washington
Storage Controls Trans (c-r Cant rol s
«
rt
H
to
ll
> 40, 000
>250
>W>,000
< 40, 000
> 40, 000
> 40, 000
i z z x |V«por Control
' |Sy«ten
z x ,
I | [Floating Roof
{] ] | [incineration
3 (Vapor
1 1 Z X r
i i Recovery
N17 N
N" --' N
None
W r-t 4*
O U
V l« -' C I
StJ 44 ^ n
P ^^ C T) -H r- «J >
V t*ELt< u g? fr.««> O l.b>^P- ^>
Jr-tW-^ W « O<-« O*>Br-« 44 O OOtt-H «
»i fa o S o_ ja_ £i * * m M K J»._ " * « o S o
X None -
N -- -- "*
N -- X -- -- -- X
None
N ~ None
H None
None
-------
Table C-5
FOOTNOTES
REGION I
1. Does not apply to storage facilities existing or under construction
on 6/1/72.
2. Does not apply to storage vessels of < 1,000 gal installed before
6/1/72, nor underground storage vessels installed before 6/1/72
with offset fill lines.
3. Full compliance required by 1/1/77.
4. Effective 5/31/77 for permits issued since 6/1/72. Applicability
of storage controls on tanks >10,000 gal depends on vapor pressure,
5. Sources built or modified as of 8/17/71.
6. Does not apply to drilling sites or production facilities.
7. Must also include vapor processing at 90% effectiveness.
8. Applies only to Air Quality Control Region 7.
9. Exclusions: transfers into farm equipment, and into tanks with
floating roofs
10. Applies to existing facilities in Mobile and all new facilities.
11. New tanks: permanent submerged fill; existing tanks in Mobile Co.:
portable or permanent submerged fill.
12. New: on or after 4/9/72; existing: rules apply only to Priority 1
sources; does not apply to drilling and production facilities.
13. On or after 4/12/76; does not apply to drilling and production.
14. Applies only if discharge >8 Ib/hr.
15. Applies to all sources in priority areas.
16. Pre-1969 - no regulations; 1969-73 - existing source regulations
? post-1973 - new source regulations apply.
17. Floating roof not allowed if VP>11.1 psi.
18. Floating roof not allowed if VP >12.5 psi.
C-19
-------
19. A new source is defined as one built after 1/1/74; regulations
apply to existing sources only in Priority 1 areas.
20. Pontoon roof o.k. only if VP<12.5 psia; internal floating roof
approved as other equipment.
21. Does not apply to underground tanks with throughput < twice volume,
nor to tanks with VP <1.5 psia.
22. Both submerged fill and vapor recovery required.
23. Storage regulations apply to all designated air pollution control
areas; transfer regulations apply only to Denver-Metro Pollution
Control Area.
24. Need not comply with regulations governing facilities with > 20,000
gal throughput/day if loading is done only into tanks < 550 gal or
pre-1973 tanks <2,000 gal.
25. Must be submerged fill plus vapor balance or vapor recovery. Rule
covers existing sources loading into vessels >2,000 gal; new
sources into vessels >550 gal.
26. Does not apply to tanks used for implements of husbandry, nor to
production of crude.
27. Does not apply to tanks <2,000 gal installed before 6/30/71, nor
underground tanks with fill line between fill connection and tank
offset.
28. Does not apply to tanks used for filling of implements of husbandry.
C-20
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-340/1-80-013A
4. TITLE AND SUBTITLE
Development of VOC Compliance Monitoring and Enforce-
ment Strategies: The Wholesale Gasoline Marketing
ChainVolume II
7. AUTHOR(S)
Richard L. Goen and Richard A. Ferguson
3. RECIPIENT'S ACCESSIOI*NO.
5. REPORT DATE
July 1980
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
CRESS 115
9. PERFORMING ORG "\NIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
SRI International
333 Ravenswood Avenue
Menlo Park, CA 94025
11. CONTRACT/GRANT NO.
68-01-4137, Tasks 11 and 14
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Division of Stationary Source Enforcement
Washington, DC 20460
13. TYPE OF REPORT AND PERIOD COVERED
Task Final 9/78--7/80
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This study addresses the development of compliance monitoring and enforcement
strategies for one major source category of VOC emissionsthe gasoline marketing
chain. The study draws on the enforcement practices of agencies with several
years of experience in implementing VOC rules for the gasoline marketing chain to
suggest a framework for the use of state and local agencies in developing appropriate
compliance strategies geared to local conditions. Rather than providing technical
assistance on particular control techniques, the report highlights the factors that
agencies should consider in deploying their enforcement resources. Volume I of the
study presents the results of our survey of experienced agencies as well as the
framework for development of compliance strategies. Volume II provides technical
detail on the components of the gasoline marketing chain, the emission sources and
control techniques, and the status of state emission regulations applicable to the
chain.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Gasoline
Air pollution control equipment
Organic compounds
Regulations
Inspection
Storage tanks
Fuel storage
b.IDENTIFIERS/OPEN ENDED TERMS
Volatile organic compouni
Enforcement of regulations
Gasoline terminals and
bulk plants
Air emissions from gasol
c. COSATl Held/Group
Is 21/04
.ne
18. DISTRIBUTION STATEMENT
Release to public
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
97
20. SECURITY CLASS (This page I
Unclassified
22. PRICE
EPA Form 222G-. ;«-73>
-------
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