UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
10O CALIFORNIA STREET
SAN FRANCISCO, CALIFORNIA 94111
File PEA 4-4-9
LA 76-5
Paktank Pacific Company
500 E. Carson Plaza Drive, Suite 221
Carson CA 90746
Attention: Melvin B. Yates
General Manager
Dear Mr. Yates:
Enclosed is the{Ambient Air Quality Impact Report for
Paktank Pacific Company's proposed construction of an 8.62
million barrel petroleum and petroleum product storage terminal
and related facilities on Terminal Island, Los Angeles Harbor,
Los Angeles, California.!
On the basis of information submitted by Paktank Pacific
Company and the current air quality in the Metropolitan Los•
Angeles Air Quality Control Region, EPA has tentatively deter-
mined that the proposed project is a significant source of
hydrocarbon (HC) emissions and will result in an interference
with the attainment of the National Ambient Air Quality Standard
for photochemical oxidants in the Metropolitan Los Angeles Air
Quality Control Region. EPA, therefore, intends to deny approval
for this project as proposed.
A copy of the Impact Report is available for public inspec-
tion at the EPA Regional Office, 100 California Street, San
Francisco; EPA Region IX Contact Office, 300 North Los Angeles
Street, Room 2032, Los Angeles; and the Southern California
APCD, 350 West Mission Boulevard, Pomona.
A public notice in the local newpapers will announce
this project, SPA's proposed action, and the above mentioned
locations where the Ambient Air Quality Impact Report is avail-
able. Comments on this proposed action may be submitted to
the EPA San Francisco Regional Office, ATTN: Air Programs
Branch, for a period of thirty (30) days following the date
of this public notice. Unless substantive new information
is forthcoming, a final decision on the proposed action will
be made within 30 days from the close of the public comment
period. Should we find a significant degree of public
controversy with respect to the proposed action, EPA may hold
a public hearing.
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16269
Should you have any questions concerning this matter,
please contact Mr. Frank Covington, Director of the Air &
Hazardous Materials Division at (415)556-0217.
Since'rely,
-•£'>.
Paul"t»e Falco,vJr.
Regional Administrator
cc: Southern California APCpv Pomona
Attn: Jeb Stuart L/
California Air Resources Board, Sacramento
Attn: William Lewis
EPA Region IX Contact Office, Los Angeles
South Coast Regional Commission, CZC, Long Beach
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File PEA 4-4-9
LA 76-5
AMBIENT AIR QUALITY IMPACT REPORT
I. Applicant
Paktank Pacific Company
500 E. Carson Plaza Drive, Suite 221
Carson, California 90746
II. Project Location
This project is proposed to be located on Terminal
Island, Los Angeles Harbor, Los Angeles, California.
The proposed site has an area of 80 acres and is currently
part of Reeves Field, an abandoned Naval Air Station.
III. Project Description
Paktank Pacific Company is proposing to construct a
bulk storage terminal for petroleum and petroleum products
The project consists of 49 storage tanks with a total
capacity of 8.62 million barrels, associated equipment
(including two boilers) on the storage facility site,
modifications to a berthing facility, and new pipelines
from the berthing facility to the tankage area. The
storage tanks can be further described as indicated in
Table I.
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TABLE I
PROPOSED STORAGE TANKS
Product Type of Number of
Stored Tank Tanks
Gasoline Floating Roof
Subtotal
Crude Oil Floating Roof
Subtotal
No. 6 Fuel Oil Cone Roof
Subtotal
No. 2 Fuel Oil Cone Roof
Subtotal
Turbine Fuel Cone Roof
Chemicals Cone Roof
TOTAL
6
2
8
4
4
8
6
4
.10
2
4
8
14
1
JL
49
Tank Dimensions
Diameter(ft) Height(ft)
106
168
206
246
168
184
142
95
67
106
60
64
64
64
64
64
64
64
64
64
64
48
Tank Volume Total
(BBLs) Volume(BBLs
100,000
250,000
380,000
500,000
250,000
300,000
180,000
80,000
40,000
100,000
25,000
600,000
500,000
1,100,000
1,520,000
2,000,000
3,520,000
1,500,000
1,200,000
2,700,000
360,000
320,000
320,000
1,000,000
100,000
200,000
8,620,000
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IV. Expected Emissions from the Project
A, Hydrocarbons (HC)
The principal air contaminants from the proposed
facility are evaporative losses of hydrocarbons from
the storage tanks. Based on information submitted
by Paktarik Pacific Company (via their application,
the project draft EIR and air quality assessment,
and supplemental information requested by EPA)
emissions of HC from the storage tanks at the facility
(as proposed) have been computed. Table II below
summarizes those calculations.
TABLE II
COMPUTED TOTAL HYDROCARBON EMISSIONS FROM THE STORAGE TANKS
Total Computed
Product Stored Number of Tanks Emissions (tons/yr)
Gasoline 8 164.2
Crude Oil 8 115.3
No. 6 Fuel Oil 10 3.6
No. 2 Fuel Oil and
Turbine Fuel 15 22.0
Chemicals 8 negligible
TOTAL 49 305.1
These emissions were estimated utilizing EPA
Document No. AP-421 and the data submitted by
Paktank Pacific. The equations in AP-42 are quite
sensitive to the vapor pressure values used. For
this project, this sensitivity is of particular
importance in the emission calculations for the
No. 2 and No. 6 fuel oil storage tanks. No actual
data was available for the types of fuel oil and
storage temperatures expected for the proposed
facility. Estimates of the vapor pressure para-
meters were made using the API Technical Data Book
based upon the average characteristics of similar
materials. Thus, the emissions could be somewhat
greater or lesser depending on the actual properties
of the material stored.
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B. Other Emissions
Under the New Source Reviev; regulations (40 CFR
52.233), EPA must reviex«; proposed construction and
modification projects for their effect on the attain-
ment or maintenance of the National Ambient Air Quality
Standards (see Section VI-A following). For the Paktank
Pacific project, emissions of criteria pollutants from
sources other than the storage tanks result from two
boilers to be used to heat the high viscosity fuel
oils. These boilers will be fired by No. 2 fuel oil
(or natural gas if available). Design load emissions
and operating emissions (approximately 60% of design
emissions) are summarized in Table III below:
TABLE III
CALCULATED EMISSIONS
FROM THE PROPOSED BOILERS (TON/YEAR)
Total
NOy SO2 Particulates HC CO
Design load emissions
Operating emissions
48.7
29.2
38.2
22.9
14.0
8.4
1.8
1.1
2.4
1.4
V. Meteorology
The Metropolitan Los Angeles Air Quality Control Region
has a "mediterranean" climate, with long, hot, dry summers
and short, cool, mild winters. The coastal sections of the
AQCR have generally more moderate temperatures than the
inland portions due to the direct influences of the mari-
time climate (particularly the ocean onshore breezes).
Among those meteorological factors which influence air
quality are the following: wind speed and direction,
amount of sunlight available, and thermal stability.
Wind speeds in the Los Angeles area are generally low
(19,74 annual average of 5.4 mph) with little seasonal
variability. The typical daily wind pattern is a
morning sea breeze and a night-time land breeze. The
annual percentage of possible _sunshine is usually over
70% (72% in 1974).
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In addition, the Los Angeles area is subject to almost
daily thermal inversions. These occur in the morning
hours approximately 90% of the time. The overall average
of surface inversions is eleven (11) days per month; higher
inversions, but less than 2500 feet above sea level, occur
on the average of 22 days per month. These inversions,
combined with low wind speeds and the geographical features
surrounding the Los Angeles area, limit the vertical and
horizontal dispersion of air pollutants and make the AQCR
particularly prone to high level air pollutant concentrations.
VI. . Current Air Quality Considerations
A. Ambient Air Quality
In 1971 the Environmental Protection Agency (EPA)
established the National Ambient Air Quality Standards
(NAAQS)2 to safeguard the health and welfare of the
people of the United States. Two levels of standards
were developed: a) primary ambient air quality
standards are those which, based on air quality
criteria and allowing an adequate margin of safety,
are requisite to protect the public health, and
b) secondary standards are those which, based on air
quality criteria, are requisite to protect the public
welfare from any known or anticipated adverse effects
associated with the presence of air pollutants in the
ambient air. The National Ambient Air Quality Standards
are listed in Table IV.
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TABLE IV
NATIONAL AMBIENT AIR QUALITY STANDARDS2
Contaminant
Sulfur Oxides (SOX):
Particulate Matter:
Carbon Monoxide (CO):
Oxidants (Ox):
Hydrocarbons (HC)
(Non-Methane)
Primary
80 ug/m3 (0.03 ppm)
annual arithmetic mean;
and
365 ug/m3 (0.14 ppm)
24 hr concentration*
75 ug/m3 annual geo-
metric mean; and
260 ug/m3 24 hr
concentration*
10 mg/m3 (9 ppm) max
8 hr concentration*;
and
40 mg/m3 (35 ppm) max
1 hr concentration*
160 ug/m3 (0.08 ppm) max
1 hr concentration*
160 ug/m3 (0.24 ppm) max
3 hr (6 to 9 AM)
concentration*
Nitrogen Dioxide (N02): 100 ug/m3 (0.05 ppm)
annual arithmetic mean
Secondary
1,300 ug/m3 (0.5 ppm)
3 hr concentration*
60 ug/m3 annual geo-
metric mean; and
150 ug/m3 24 hr
concentration*
Same
Same
Same
Same
Same
^Maximum value not to be exceeded more than once per year
Note: The hydrocarbons standard is for use as a guide in developing
implementation plans to achieve oxidant standards.
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As indicated in the 1974 Annual Report3 of the Los
Angeles County Air Pollution Control District
(currently the Southern California APCD, Los Angeles
Zone) and supported by California Air Resources Board
data, Los Angeles County is not currently meeting
the NAAQS for any pollutant except sulfur oxides
(SOX). As summarized in Table V, the number of days
each year on which the NAAQS for oxidants and hydro-
carbons were exceeded remained relatively constant over
the last three years.
TABLE V
DAYS ON WHICH THE NAAQS FOR OXIDANT AND HYDROCARBONS
WERE EXCEEDED (BY YEAR) IN LOS ANGELES COUNTY
Pollutant 1972 1973 1974
Oxidant 226 196 237
Non-Methane Hydrocarbons* 364 362 355
*The hydrocarbons standard is for use as a guide in developing
an SIP to achieve the oxidant standard.
For the criteria pollutants carbon monoxide (CO),
nitrogen dioxide (N02), and particulate matter,
similar but less extensive patterns exist for days
exceeding the NAAQS in Los Angeles County.
In summary, then, Los Angeles County can be
characterized as having extreme difficulty in
attaining the NAAQS for the criteria pollutants
mentioned above. Of particular concern is the
oxidant standard because, as will be discussed
further in Section VII, HC and NOX emissions are
precursors to the formation of photochemical
oxidants.
B. Current Emissions in Los Angeles County
The Southern California APCD, Los Angeles Zone, in
their 1974 Annual Report3 summarized emissions of
air pollutants in Los Angeles County. In order to
demonstrate the magnitude of the current emissions
and air quality problems, the data is further summarized
in Table VI below (also included is a summary of
emissions from the proposed Paktank Pacific project).
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TABLE VI
1974 EMISSIONS IN LOS ANGELES COUNTY (TON/YR)
iource Category Total HC NQX Particulates S02 C0_
'etroleum Related Industry
)ther Stationary Sources
71,200
135,000
10,900
84,000
1,800
18,200
29,200
54,800
*
1,800
Fatal Stationary Sources 205,200 94,900 20,000 84,000 1,800
Baseline Powered Vehicles
)ther
fatal
Fatal
Transportation
Transportation
Sources
Sources
290
12
302
509
,000
,800
,800
,000
248
21
259
364
,100
,800
,900
,800
12,800
9,100
21,900
41,900
10
5
16
100
,900
,500
,400
,400
2,258,
73,
2,331,
2,332,
000
000
000
800
*No value given in report referenced.
Paktank Pacific Project
Storage Tanks 305.1
Boilers 1.8 48.7 14.0 38.2 2A_
Total 306.9 48.7 14.0 38.2 2.4
Although the projected emissions from the Paktank
Pacific project seem relatively small compared to
the total emissions in Los Angeles County, it must
be remembered that ambient air concentrations of
these pollutants (as well as photochemical oxidants)
greatly exceed the NAAQS. The Paktank Pacific pro-
ject, as proposed, is a major stationary source of
criteria pollutants (particulary hydrocarbon emissions)
and would be expected to have adverse local and region-
wide ambient air quality effects.
C. Allov/able Emissions of Non-Methane Hydrocarbons and
Nitrogen Oxides
Based on information obtained from the California
Air Resources Board4 regarding emissions inventories
and ambient air quality measurements for 1973 in the
Metropolitan Los Angeles-AQCR and Los Angeles County
and using a simple roll-back model,- allowable emissions
of non-methane hydrocarbons and nitrogen oxides have
been estimated for these two geographical areas. This
information has been developed (and summarized below)
in order to demonstrate the magnitude of the current
problem and the difficulty of obtaining the NAAQS
for these pollutants.
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Emissions (ton/year)
Total Non-Methane Nitrogen
Hydrocarbons Hydrocarbons Oxides
Metropolitan Los Angeles AQCR
1973 Emission Inventory 662,800 626,700 525,600
Allowable Emissions —- 100,400 355,100
Los Angeles County
(Portion in Met LA AQCR)
1973 Emissions Inventory 475,600 455,900 361,300
Allowable Emissions — 73,000 244,200
Therefore, it is apparent that, in order to attain
the NAAQS for the respective criteria pollutants
above, extensive reductions in pollutant emissions
must be made. These desired emissions levels can
only be obtained by both reducing emissions from
existing sources and limiting new emissions.
VII. Impact of the Project on Ambient Air Quality
As is well known and documented, reactive hydrocarbons
and nitrogen oxides emitted to the atmosphere, in the
presence of sunlight, undergo a chemical reaction to
form photochemical oxidants. This end product is the
result of a very complex series of reactions and is
generally referred to as "smog." Based on the information
summarized in the preceeding sections of this report,
EPA concludes that increases in hydrocarbon emissions
in the Los Angeles area (particularly of the magnitude
proposed by Paktank Pacific Company) will have a direct
adverse impact on the attainment of the National
Ambient Air Quality Standard for oxidant in the Metro-
politan Los Angeles AQCR.
Also of concern to EPA is the cumulative impact on air
quality of all new proposed petroleum industry related
development in the Los Angeles Harbor/Long Beach Harbor
area. This development is expected to include at least
eleven large projects (primarily petroleum product storage
facilities), in addition to the Paktank Pacific project.
This review included considerations of the air quality
impacts of the total expected development. In addition,
it should be noted that each of the projects individually
is subject to the New Source Review regulations and
cumulative impacts on air quality, both locally and
regionally, will be considered in future analyses.
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VIII. Alternatives Considered
During the evaluation of the Paktank Pacific project
for this report, several alternative actions were con-
sidered for their effect on ambient air quality and/or
on reducing emissions from the project. The following
is a summary of the alternatives which were considered:
A. The "No Project" Alternative.
The primary advantage of this alternative is the
prevention of a significant stationary source of
hydrocarbon emissions in the Los Angeles Harbor
area and the resultant negative effects on the
ambient air quality in the Metropolitan Los Angeles
AQCR. The probable resultant of the "No Project"
alternative would be either: a) the future con-
struction of a similar large scale facility in
some other area (see Section VIII - B below) or b)
the possible construction of smaller storage
facilities in a more dispersed pattern, probably
at sites where the product being stored would be
used as fuel. Because large storage tanks are
generally more efficient than smaller tanks in
terms of controlling evaporative hydrocarbon
emissions, centralized storage may be a preferred
alternative over dispersed smaller tank storage.
In the case of the Paktank Pacific project, as
proposed, if it is assumed that the entire 8.62
million barrels of storage capacity would be
needed in the Metropolitan Los Angeles AQCR and
(in the absence of the Paktank Pacific project)
would be made up entirely of smaller tanks than
those proposed by Paktank Pacific, hydrocarbon
emissions would probably be greater with the
smaller tanks assuming current state-of-the-art
control technology. EPA questions both these
assumptions for the following reasons: a) only
3.7 million of the proposed 8.62 million barrels
of storage are proposed for fuel oil storage
(the most likely product requiring on site storage),
b) on site storage at the larger customers might
be of a similar tank size to_ that proposed by
Paktank Pacific, and c) hydrocarbon emissions from
fuel oil storage are much less than those for crude
oil and gasoline storage.
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In any event, any new construction of petroleum
and petroleum product storage facilities would
also come under the New Source Review program
and would undergo a review similar to EPA's
analysis of the proposed Paktank Pacific project.
B. Alternative Sites.
This alternative, from an air quality point of view,
can be divided into two categories: 1) alternate
sites within the Metropolitan Los Angeles AQCR and
2) alternate sites outside of the AQCR. In the
first case, it seems likely that our conclusions
regarding the effect on ambient air quality would
be the same due to the likely input of similar
factors for size of source, emissions from the
source, and existing ambient air quality. In the
second, an entirely new review would be required
in order to make a determination regarding the
effects of the proposed project using existing air
quality in the new site AQCR as an input.
The preceding discussion of alternative sites has
not dealt with other factors such as need for the
project, economic considerations, transportation
availability, nearness to sources of product, etc.
C. Alternative Emission Control Technology
As indicated in Table I, the Paktank Pacific project
is a mix of fixed roof and floating roof tanks. The
possibility of requiring alternative storage techno-
logy was reviewed. Specific considerations were:
1) requiring floating roof technology for all storage
tanks and 2) requiring the use of a facility-wide
vapor recovery system. The computed emissions from
the project as proposed by Paktank Pacific and esti-
mated emissions (using AP-42 and data submitted by
Paktank Pacific) resulting from the two alternative
schemes are compared in Table VII below:
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TABLE VII
ESTIMATED TOTAL HC EMISSIONS FROM ALTERNATIVE STORAGE TANK TECHNOLOGIES (TON/YEAR)*
Product Number of Paktank Pacific Co.
Stored Tanks Project as Proposed
Gasoline
Crude Oil
No. 6 Fuel Oil
No. 2 Fuel Oil
and Turbine Fuel
Chemicals
Total '
8
8
10
15
8
49
164
115
3
22
305
.2
.3
.6
.0
.1
Utilizing
Roofs on
164
115
0
1
281
Utilizing Vapor
Floating Recovery Exclusively
all Tanks (95% efficiency assumed)
.2
.3
.3
.9
.7
118
91
0
1
211
.5
.2
.2
.1
__
.0
*These estimates do not include emissions from the proposed on-site boilers
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The disadvantages of using floating roof storage
tanks for the fuel oil tanks include added cost
and operating problems involved with using a
floating roof tank for a high viscosity material
which will be stored at an elevated temperature in
an insulated tan]:. Vapor recovery systems have
the folloxving disadvantages: high first cost plus
much greater operating costs, natural gas blanketing
requires material Xv7ith limited availability,
potential fire hazards, and equipment operation
problems.
However, the crucial item is that even with the
best case above, the hydrocarbon emissions are
still in excess of 200 tons/year and the facility
would still be a significant source of HC emissions.
In addition, modifying the storage technology does
not reduce emissions of the other criteria pollutants
from the facility boilers,
IX. Conclusions and Proposed Action
Based on the information submitted by Paktank Pacific
Company and that developed by EPA (as discussed above),
EPA concludes that construction of the Paktank Pacific
Company storage terminal as proposed would result in
significant emissions of criteria pollutants (particularly
hydrocarbons) and would interfere in the attainment of
the National Ambient Air Quality Standard for oxidants
in the Metropolitan Los Angeles AQCR. Therefore, the
Environmental Protection Agency intends to deny the
application of Paktank Pacific Company for an Authority
to Construct under EPA's authority as promulgated in 40
CFR 52.233 (g).
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References
1. Compilation of Air Pollutant Emission Factors, AP-42,
Second Edition, U.S. Environmental Protection Agency,
April, 1973.
2. Federal Register, Vol. 36, Number 84, April 30, 1971
(40 CFR 50) .
3. Air Quality and Meteorology, 1974 Annual Report, County
of Los Angeles Air Pollution Control District, 1974.
4. California Air Resources Board, personal communications
with California ARE staff members, on 11/18/75 and 11/19/75,
5. Draft Environmental Impact Report, Paktank Pacific
Company, Oil Storage Terminal Island, Los Angeles
Harbor.
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