United States
            Environmental Protection
            Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/3-80-038b
August 1983
            Air
SEPA
Bulk
Terminals—
Background
Information for
Promulgated
Standards
Final
EIS

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                           EPA-450/3-80-038b
Bulk Gasoline Terminals—
 Background Information
              for
 Promulgated Standards
     Emission Standards and Engineering Division
     U.S. ENVIRONMENTAL PROTECTION AGENCY
        Office of Air, Noise, and Radiation
     Office of Air Quality Planning and Standards
     Research Triangle Park, North Carolina 27711

             August 1983

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This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air
Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or recommendation for use. Copies of this report are
available through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, N.C. 27711, or from the National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.
                               Publication No. EPA-450/3-80-038b

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                         ENVIRONMENTAL PROTECTION AGENCY

                              Background Information
                                    and Final
                          Environmental Impact Statement
                           for Bulk Gasoline Terminals

                                   Prepared by:
 ,,// / Jack R. Farmer      /                                         (Date)
/    Director, Emission Standards and Engineering Division
     U.S. Environmental Protection Agency
     Research Triangle Park, NC  27711

     1.   The promulgated standards of performance will  limit emissions of
          VOC from new, modified, and reconstructed bulk gasoline terminals.
          Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended,
          directs the Administrator to establish standards of performance
          for any category of new stationary source of air pollution that
          ". . . causes or contributes significantly to  air pollution which
          may reasonably be anticipated to endanger public health or welfare."

     2.   Copies of this document have been sent to the  following Federal
          Departments: Labor, Health and Human Services, Defense, Transportation,
          Agriculture, Commerce, Interior, and Energy; the National  Science
          Foundation; the Council on Environmental Quality; members  of the
          State and Territorial Air Pollution Program Administrators; the
          Association of Local Air Pollution Control Officials; EPA  Regional
          Administrators; and to other interested parties.

     3.   For additional information contact:

          Mr. James F. Durham
          Chemicals and Petroleum Branch (MD-13)
          U.S. Environmental Protection Agency
          Research Triangle Park, NC  27711
          telephone:  (919) 541-5671

     4.   Copies of this document may be obtained from:

          U.S. EPA Library  (MD-35)
          Research Triangle Park, NC  27711

          National Technical Information Service
          5285 Port Royal Road
          Springfield, VA  22161
                                          m

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                           TABLE OF CONTENTS

Title

1.0  SUMMARY	       1-1
     1.1  Summary of Changes Since Proposal	       1-1
     1.2  Summary of Impacts of Promulgated Action 	       1-4
          1.2.1  Alternatives to Promulgated Action	       1-4
          1.2.2  Environmental  Impacts of Promulgated
                 Action	       1-5
          1.2.3  Energy and Economic Impacts of Promulgated
                 Action	       1-5
     1.3  References	       1-8
2.0  SUMMARY OF PUBLIC COMMENTS	       2-1
     2.1  General Issues	       2-1
          2.1.1  Need for the Standard	       2-1
          2.1.2  Designation of Effective Date of
                 the Standard	       2-11
          2.1.3  Definition of a Bulk Gasoline Terminal.  .  .       2-12
          2.1.4  Executive Order 12291 	       2-14
          2.1.5  Other Comments	       2-16
     2.2  Designation of Affected Facility 	       2-18
     2.3  Modification and Reconstruction	       2-19
          2.3.1  SIP Conversions	       2-19
          2.3.2  Interpretation of Reconstruction	       2-24
          2.3.3  Interpretation of Modification	       2-30
     2.4  Environmental Impacts	       2-31
          2.4.1  Calculation of Emission Reductions	       2-31
          2.4.2  Emission Factors	       2-32
          2.4.3  Calculated Emission Reductions	       2-37
          2.4.4  Emission Impact in Clean Areas	       2-37
          2.4.5  Impact of Tank Truck Testing	       2-39
     2.5  Economic Impacts 	       2-39
          2.5.1  Underestimation of Industry Costs 	       2-39
          2.5.2  Economic Incentive to Control
                 Emissions	,	       2-42
          2.5.3  Vapor Processor Costs 	       2-44

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                           Table of Contents
Title                                                        Page
     2.5.4     Costs Associated with Emission Limit.  .  .  .   2-50
     2.5.5     Other Terminal Costs	   ,?-M
     2.5.6     Tank Truck Costs	   2-53
     2.5.7     Ability to Pass  Through Control  Costs  .  .  .   2-55
2.6  Emission Control Technology 	   2-56
     2.6.1     State-of-the-Art Equipment	   2-56
     2.6.2     Test Data Presentation	   2-57
     2.6.3     Adequate Demonstration of Technology   .  .  .   2-60
     2.6.4     Test Data Calculations	   2-62
     2..6.5     Equipment Operation Under  Variable
               Conditions	   2-63
     2.6.6     Additional Test  Data	   2-64
     2.6.7     Carbon Adsorption (CA) Control
               Technology	   2-64
     2.6.8     Refrigeration  (REF) Control  Technology.  .  .   2-72
     2.6.9     Thermal Oxidation (TO) Control
               Technology	   2-73
     2.6.10    General Control  Technology	   2-74
2.7  Selection of  Emission  Limit 	   2-76
     2.7.1     Stringency of  Emission Limit	   2-76
     2.7.2     Alternate Suggested Emission Limit	   2-77
     2.7.3     Efficiency Equivalent  of Mass
               Standard	   2-78
2.8  Test Methods  and Monitoring	   2-79
     2.8.1     Details of Test  Methods	   2-80
     2.8.2     Methods of Testing	   2-84
     2.8.3     Continuous Monitoring  	   2-86
2.9  Tank Truck  Controls	   2-92
     2.9.1     Restricting  Loadings  to  Vapor-Tight
               Trucks	   2-92
     2.9.2     Suggested Alternatives	   2-96
     2.9.3     Administrative Burden  	   2-102
     2.9.4     Tank Truck Population  Impacted  by
               the Standard	   2-102
     2.9.5     Economic Burden	   2-105

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                           Table of Contents
Title                                                       Page
2.10  Legal  Considerations   	  2-107
      2.10.1  Tank Trucks Not Stationary Sources 	  2-107
      2.10.2  Loading Restrictions by Terminal Operators  .  2-111
      2.10.3  Setting of an Operational Standard 	  2-112
      2.10.4  Setting of an Equipment Standard 	  2-114
2.11  References	2-115
APPENDIX A - EMISSION SOURCE TEST DATA	   A-l
      A.I  Introduction	   A-2
      A.2  Summary of Additional Test Activity	   A-2
APPENDIX B - COST AND ECONOMIC IMPACTS	   B-l
     B.I  Introduction	   B-2
     B.2  Current Control Cost Estimates 	   B-2
          B.2.1  Model Plant Costs 	   B-2
          B.2.2  Nationwide Control Costs  	   B-10
     B.3  Economic Impact Analysis 	   B-16
     B.4  Socioeconomic and Inflationary Impacts 	   B-23
          B.4.1  Executive Order 12291 	   B-24
          B.4.2  Fifth-Year Annualized Costs 	   B-24
          B.4.3  Inflationary Impacts	   B-24
          B.4.4  Other Impacts	   B-25
     B.5  Regulatory Flexibility Analysis	   B-25
     B.6  References	   B-28
                                  vn

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                            LIST OF TABLES


Title                                                            Page


2-1  List of Commenters on the Proposed Standards of
     Performance for Bulk Gasoline Terminals   	    2-2

2-2  VOC Emission Reductions at Model Plants Under the
     Regulatory Alternatives (Mg/yr)  	    2-34

2-3  Nationwide Air Quality Impacts of Regulatory Alternatives
     on Bulk Terminal  Industry	    2-35

2-4  Vapor Return Line Pressures During Loading  	    2-58

A-l  Bulk Terminal Emission Test Data Summary	    A-3

B-l  Estimated Control Costs - New and Existing
     Bulk Terminals, Bottom Loaded, No SIP  Control	    B-3

B-2  Estimated Control Costs - Existing Bulk Terminals,
     Top Loaded, No SIP Control	    B-4

B-3  Cost Effectiveness for Various Bulk  Terminal
     Model Plant Cases	    B-13

B-4  Five-Year Nationwide Costs to Bulk Terminal  Industry  .  .    B-14

B-5  Debt Service Coverage Ratio for New  Facilities  	    B-17

B-6  Debt Service Coverage Ratio, Existing  Facility—
     Baseline	    B-18

B-7  Debt Service Coverage Ratio, Existing  Facility--
     Bottom Loaded, No SIP Control   	    B-19

B-8  Debt Service Coverage Ratio, Existing  Facility—
     Top Loaded, No SIP Control	    B-20

B-9  Maximum Percentage Price  Increases,  Cost  Pass-Through:
     New Facilities,  Existing  Facilities  (Bottom Load),  and
     Existing Facilities  (Top  Load)  	    B-21

B-10 After-Controls, After-Tax Return on  Investment: New
     Facilities, Existing Facilities  (Bottom Load),  and
     Existing Facilities  (Top  Load)  	    B-22
                                    vm

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                             1.0  SUMMARY

     On December 17,  1980,  the Environmental Protection Agency  (EPA)
proposed standards  of performance for bulk gasoline terminals
(45 FR 83126)  under authority of Section 111 of the Clean Air Act.
Public comments were  requested on the proposal  in the Federal Register.
There were 40  commenters consisting mainly of terminal owners and
operators, trade associations, State and local  air pollution control
agencies, and  control equipment suppliers.  Three U.S. Government
agencies also  commented on the proposed standards.  The comments that
were submitted, along with responses to these comments, are  summarized
in this document.  The summary of comments and responses serves  as  the
basis for the  revisions made to the standards between proposal  and
promulgation.
1.1  SUMMARY OF CHANGES SINCE PROPOSAL
     Several changes  of varying importance have been made  to the
standards since proposal.  Most of the changes were made in  response
to comments, but some of them were made for the sake  of clarity or
consistency.  One of the most significant of the  changes dealt  with
proposed Section 60.502(d), which required  loadings of gasoline tank
trucks  to be restricted to vapor-tight tanks only, as evidenced by  an
annual  vapor tightness test.  Most of the comments on this requirement
were concerned  about the terminal operator's apparent liability for
the condition of tank trucks owned by other parties.  Several  commenters
felt that terminals would have  to provide extra personnel  at the
loading  racks to enforce this restriction (see Section 2.9.1 of this
document).  Section  60.502(d)  (now 60.502(e)) was expanded to  clearly
delineate the terminal owner or operator's  responsibilities  and to
clarify  that on-the-spot monitoring  of product loadings would  not  be
necessary.  A terminal operator need only compare a tank  identification
                                 1-1

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number against the file of vapor tightness documentation within 2 weeks
after a loading of that tank took place.  The terminal owner or operator
would have to notify tank truck owners or operators  loading nonvapor-tight
tanks that reloading of the tank would not be allowed until the vapor-
tightness documentation was received by the  terminal.  The  terminal
owner or operator would then be required to  take  steps to prevent
loading into each such nonvapor-tight  tank.  Thus the final standard
clarifies that a terminal owner or operator  can comply with this part
of the standard by cross-checking files and  does  not have to observe
truck  loading 24 hours per day.
     One paragraph about  facilities  with existing vapor  processing
equipment was added  to Section 60.502.  The  Agency has concluded that
it is  quite  costly in  light of the  resulting emission  reduction  for an
owner  whose  existing facility becomes  subject to  NSPS  (e.g., through
modification or reconstruction) to meet 35 mg/liter when  the facility
already has  a system capable of meeting 80 mg/liter, but  not 35 mg/liter.
For  these reasons, EPA has added Section 60.502(c),  which permits
affected facilities  with  such vapor  control  equipment  to  meet  80 mg/liter
if construction or substantial rebuilding  (i.e.,  "refurbishment")  of
that equipment commenced  before the  proposal date, December 17,  1980.
This is based on the Administrator's judgment that best  demonstrated
technology  (BDT) for these facilities  is no  further control, while  BDT
for  facilities with  vapor processing systems on which  construction  or
refurbishment commenced after proposal  is  the replacement or add-on
technology  that would  enable the facility  to achieve 35  mg/liter.
     Several commenters objected to  the requirement for  excess emissions
reports and  to using an average monitored  value as the  basis for an
excess emissions determination (see  Section  2.8.3 of this document).
Section 60.504, Monitoring of Operations,  has been reserved pending
the  development and  promulgation of  performance specifications for
continuous  monitoring  devices.  Therefore,  specific comments  concerning
the  proposed continuous monitoring  requirements cannot be addressed at
this time.   The Agency is currently  investigating several  types  of
simple, low-cost monitors for various  types  of  vapor processors.
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Alter specifications have been selected, they will be proposed in a
separate action in the Federal Register for public comment.
     Two paragraphs of Section 60.505 requiring recordkeeping have
been modified,  and two new paragraphs have been added.  Both tank
truck vapor tightness documentation and monthly leak inspection records
must still  be kept on file at the terminal, but inspection records
must now be kept for 2 years.  New paragraph (d) of this section adds
a 2-year recordkeeping requirement for the notifications now required
under Section 60.502(e), and new paragraph (f) of this section adds a
3-year recordkeeping requirement for the costs for determining a
refurbished vapor processing system.
     One paragraph in Section 60.500 was deleted and another added.
Since the continuous monitoring section has been reserved, the proposed
Section 50.500(c), releasing the affected facility from the require-
ments of 60.504 until monitoring specifications had been developed,
has been deleted.  A new Section 60.500(c) has been added to change
the applicability date from the date of proposal to the date of
promulgation for existing facilities which commenced a component
replacement program before the promulgation date in order to comply
with State or local bulk terminal regulations.  Such facilities are
not subject to the standards by means of the reconstruction provisions
of 40 CFR 60.15.  Section' 60.506 was added in response to commenters'
concerns about the burden of accumulating records of replacements at
an existing source, over its lifetime, for the purpose of determining
reconstruction.  The section also states that no records are required
for small normal maintenance components that are routinely replaced
and are a small part of the total cost.
     The terminology used in the emission limits of the regulation has
been changed since proposal.  The emission limits are now expressed in
terms of "total organic compounds" (TOC's) rather than VOC's (VOC's
are the proportion of the organic compounds that is regarded as photo-
chemically reactive).  This change does not affect the stringency of
the standards,  but it does better reflect the intent of the standards
and the data base and test procedures used in establishing the standards,
The standards are intended to reduce emission of VOC's through the
application of BDT (considering costs and other impacts), and the

                                1-3

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emission limits in the standards are selected to reflect the performance
of BDT.  However, the best demonstrated technologies applicable to
bulk terminals do not selectively control VOC's, but rather all of the
organic compounds contained in gasoline vapors.  Furthermore, the
emission limits are based on test data and test procedures that measure
TOC, and the test methods used to determine compliance with the standards
measure TOC.  Therefore, to reflect accurately the performance of the
control technologies selected as BDT and to be consistent with the
data base and test methods on which the emission limits are based, the
emission limits in the proposed standards should have been expressed
in  tenns of total organic compounds, and the promulgated emission
limits are expressed in those terms.  Since the methane and ethane
content is relatively small, the option to subtract this from measured
TOC emissions using approved methods is retained.
     Five definitions in Section 60.501 of the regulation were changed,
and two were added.  In response to industry comments (see Section 2.1.3
of  this document), a size cutoff by gasoline throughput was added to
the definition of "bulk gasoline terminal" (only facilities handling
more than 76,700 liters, or 20,000 gallons, per day will be covered),
to  clarify that smaller facilities (bulk plants) served by ship or
barge  will not be covered by these standards.  Also, the word  "wholesale"
has been removed because the throughput cutoff should exclude  retail
outlets (service stations) from possible applicability.
     The definition for VOC is  replaced by a definition of TOC to be
consistent with  the basis on which the emission limits were selected.
     The wording of the definitions for  "continuous vapor processing
system" and "intermittent vapor processing system" was changed slightly
to  make the two terms consistent.  The meanings of these terms remain
the same.
     The term  "loading rack" was modified to include only the  components
whose  replacement might be considered in a determination of construction,
modification, or reconstruction.  The change does not affect the basic
meaning of the term or the designation of affected facility.   Definitions
for "existing vapor processing  system" and "refurbishment" were added
to  clarify which processing systems would be required to meet  the less
stringent limit of 80 mg/liter.
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     Three paragraphs in Section 60.502 were modified.  In paragraph  (f),
the word "recovery" was changed to "collection" to more precisely
define the equipment contained on tank trucks.
     The phrase "during product loading" was added in paragraph (i),
to clarify that the delivery tank pressure limitation applies only
while the tank is being filled at the terminal.
     In proposed paragraph (i) (now 60.502(j)), the requirement to
"visually" inspect the liquid and vapor handling systems on a monthly
basis elicited a comment that vapor leaks are not effectively "seen"
during an inspection (see Section 2.8.2).  The  word "visually" has
been deleted to clarify that the inspection may be made without instruments,
but that any of the senses may be used in detecting vapor or liquid
leaks.
1.2  SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1  Alternatives to Promulgated Action
     The regulatory alternatives are discussed  in Chapter 6 of the
Background Information Document for the proposed standards, "Bulk
Gasoline Terminals - Background Information for Proposed Standards,"
EPA-450/3-80-038a [hereinafter referred to as BID, Volume I] (III-B-1).
These regulatory alternatives reflect the different levels of emission
control from which is selected the approach that represents the best
demonstrated technology of continuous emission  reduction, considering
costs, nonair quality health, and environmental and economic impacts
for bulk gasoline terminals.  These alternatives remain the same.
1.2.2  Environmental Impacts of Promulgated Action
     The estimated environmental impacts of the proposed standards
were discussed in Chapter 7 of BID, Volume I.  Changes in these estimates
have been made since proposal, due to a reconsideration of one of the
emission factors used to calculate emission reductions under the
standards (see Section 2.4.2) and due to limiting of emissions to
80 mg/liter for existing vapor processing systems.  Nationwide VOC
emissions from affected bulk terminals will decrease by 5,700 Mg/year,
or about 68 percent, from baseline SIP levels in the fifth year following
promulgation of the standards.  This emissions  decrease will result in
a reduction of ambient air concentrations of volatile organic compounds
in the vicinity of new, modified, and reconstructed bulk gasoline
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terminals.  Only very few thermal oxidation systems are expected to be
installed, and so emissions of CO and NO  from these systems will be
                                        /\
negligible.
     The water pollution impact will be minimal because water is not
used as a direct control medium in any of the control technologies
considered for the standard.  Refrigeration type control systems
discharge a small amount of condensed water from which recovered
gasoline has been decanted.  This minimal quantity of water will enter
the terminal's drainage system and is not expected to represent a
significant percentage of the total discharge of the terminal.
     Carbon adsorption type control systems could produce a small
amount of solid waste if the activated carbon had to be replaced (due
to fouling or excessive pulverization and consequent reduction in
working capacity) during the life of the system.  The extreme worst-case
waste production is estimated at about 50,000 kg (55 tons) per year,
which represents a minimal solid waste impact.
1.2.3  Energy and Economic Impacts of Promulgated Action
     The estimated energy impacts of the proposed standards were
discussed in Chapter 7 of BID, Volume I.  The assumption that 25 percent
of all affected terminals would  install thermal oxidation systems
(which recover no gasoline/energy equivalent) is considered extremely
conservative, based on the updated cost estimates summarized in Tables B-l
and B-2 of Appendix B.  These tables indicate that TO systems may be
less cost-competitive than formerly estimated, even  for the smallest
terminals.  Nonetheless, the previous estimated net  energy savings in
the fifth year of the standards  has been reduced from 9 million to
7 million liters of gasoline equivalent, due mostly  to the emission
factor correction discussed in Section 2.4.2.
     The estimated cost and economic impacts of the  proposed standards
were discussed in Chapter 8 of BID, Volume I.  Since proposal, cost
estimates have been updated in terms of first quarter 1981 dollars,
and are presented in Section B.2.1 of this document.  Most net annual-
ized control costs have increased over previous estimates for all
model plant sizes.  This is due  primarily to the effects of inflation
on most cost elements, a higher  assumed interest rate on borrowed
capital, and the addition of continuous monitoring costs.  The major

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compensating cost factor lowering net costs is the updated wholesale
gasoline price, $0.29  per liter instead of the previous $0.17 per
liter.
     As discussed in Section B.2.2 of Appendix B, the nationwide total
capital investment for the terminal  industry in the first five years
is estimated at $10.8  million,  or 45 percent of the estimate made
previously.   The net annualized cost to the terminal  industry in the
fifth year will be $1.6 million, again 45 percent of the previous
estimate.   One reason  for the decrease in the cost estimates for the
terminal industry was  a change  in the assumption concerning the number
of terminals converting previously top loading racks to bottom loading
which were not linked  to vapor recovery regulations.   Since in these
cases the top-to-bottom loading conversions are the replacements which
cause application of New Source Performance Standards (NSPS), the cost
of these conversions will  not be attributable to the standards.  After
a re-evaluation of the information supplied in Section 114 letter
responses, the previous estimate of 25 top-to-bottom loading conver-
sions directly attributable to the standards was lowered to three terminals.
It was estimated in these three cases that the top-to-bottom loading
conversions would be performed  after the facility becomes an affected
facility and would be  in an effort to comply with the NSPS.  Another
reason for the decrease was the elimination of the costs associated
with add-on controls or replacement for the 10 existing vapor processing
systems assumed in the previous estimates.
     The for-hire tank truck industry will incur a total capital
investment in the first five years of $1.4 million.  It is estimated
that the total annualized cost in the fifth year will be $0.9 million.
     The economic impact analysis presented in Section B.3 updates the
previous analysis contained in Section 8.4 of BID, Volume I.  The
general conclusions of the previous analysis are still considered
valid.  None of the model  plant terminals will encounter a debt service
coverage problem, nor will the maximum price increase necessary to
maintain pre-control profit rates be excessive.  The worst case would
require a 0.48 percent gasoline price increase for a 380,000 liter
per day (Model Plant 1) existing top loading facility.  The return-on-
investment (ROI) results still  support the conclusion that essentially

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no growth in the number of 380,000 liter per day terminals will  take
place because both pre-control  and after-control ROI's do not meet the
acceptable level.  The position of new terminals in the 950,000 liter
per day category (Model Plant 2) has improved, such that they now
remain attractive after-controls investments, even without complete
cost pass-through.
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1.3  REFERENCES


III-B-lh Bulk  Gasoline  Terminals  -  Background  Information for Proposed
         Standards.   Draft  EIS.   Publication No.  EPA-450/3-80-038a.
         December  1980.
      number  corresponds to the docket  item number  in  Docket  No.  A-79-52,
                                1-9

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                    2.0  SUMMARY OF PUBLIC COMMENTS

     The list of commenters,  their affiliations, and the EPA docket
number assigned to each of their comments are shown in Table 2-1.
(Comment letters identified in this table are not repeated in the
references section of this chapter.)  Forty-two letters contained
comments, and six people testified at both public hearings on the
proposed standards and Volume I of the the Background Information
Document.  The significant comments have been combined into the
following 10 major areas:
     1.   General Issues
     2.   Designation of Affected Facility
     3.   Modification and Reconstruction
     4.   Environmental Impacts
     5.   Economic Impacts
     6.   Emission Control Technology
     7.   Selection of Emission Limit
     8.   Test Methods and Monitoring
     9.   Tank Truck Controls
     10.  Legal Considerations
     The comments, issues, and their responses  are  discussed  in  the
following sections of this chapter.  A summary  of the changes made to
the standards since proposal  is included  in Section 1.1 of Chapter 1.
2.1  GENERAL ISSUES
2.1.1   Need for the Standard
     Comment:  Several commenters recommended that  the proposed  standards
be cancelled and that Alternative I, no  additional  regulation,  be  adopted.
Instead, the State implementation plans  (SIP's) should be  relied upon
to control VOC emissions from bulk  gasoline terminals.  Also,  it was
argued  that Stage I and Stage II controls are unfair  and  not  cost-effective,
                                2-1

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       TABLE 2-1.   LIST OF COMMENTERS ON THE PROPOSED STANDARDS
              OF PERFORMANCE FOR BULK GASOLINE TERMINALS
I tern Number in
Docket A-79-52

IV-F-1
IV-F-2,  IV-D-20, IV-D-43
       • a
IV-F-3,  IV-D-46
IV-F-4
 IV-F-5,  IV-D-53
 IV-F-6,   IV-D-44
 IV-E-19
 Commenter and Affiliation

Public Hearing transcript
Environmental Research Center
Research Triangle Park, N.C.
January 21, 1981

Mr. Lem McManness
Marathon Oil Company
Findlay, Ohio  45840

Mr. B.S. DiGiovanni
ARCO Petroleum Products Company
515 South  Flower Street
Los Angeles, California  90051

Public Hearing transcript
EPA/Beaunit Complex
Research Triangle Park, N.C.
January 28,  1981

Mr. Ray C.  Edwards
Edwards Engineering Corporation
101 Alexander Avenue
Pompton Plains, New Jersey   07444

Mr. Clifford J. Harvison
National Tank Truck Carriers,  Inc.
1616  P  Street, N.W.
Washington,  D.C.  20036

Post-Proposal Industry Meeting
to Hear Comments on the  Proposed
Standard.   Industry representatives
were:

Lem McManness,
   Marathon Oil Company
B.S.  DiGiovanni,
   ARCO  Petroleum Products  Company
Byron Stoddard,
   Shell Oil  Company
C.E.  Henderson,
   Amoco Oil  Company
Charles W. Dougherty,
   Texaco,  Incorporated
Edward  J.  Karkalik,
   Standard Oil  Company of Ohio
                                 2-2

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       TABLE  2-1.   LIST  OF  COMMENTERS  ON  THE  PROPOSED  STANDARDS
         OF  PERFORMANCE  FOR BULK  GASOLINE  TERMINALS  (Continued)


Item Number  in
Docket A-79-52                            Commenter  and Affiliation

IV-D-1                                 Mr.  R.W.  Bogan
                                       GATX  Terminals Corporation
                                       120 South Riverside  Plaza
                                       Chicago,  Illinois  60606

IV-D-3                                 Mr.  Francis  R.  Perry
                                       State of  California
                                       Air  Resources  Board
                                       1102  Q Street
                                       P.O.  Box  2815
                                       Sacramento,  California  95812

IV-D-4                                 Mr.  Robert  Denyszyn
                                       Scott Environmental  Technology, Inc.
                                       Plumsteadville,  Pennsylvania  18949

IV-D-5                                 Mr.  Albert  B.  Rosenbaum, III
                                       National  Tank  Truck  Carriers, Inc.
                                       1616  P Street, N.W.
                                       Washington,  D.C.   20036

IV-D-6                                 Mr.  W.R.  Riedel
                                       United States  Coast  Guard
                                       Department  of  Transportation
                                       Washington,  D.C.   20593

IV-D-7                                 Mr.  Jack  M.  Heinemann
                                       Federal  Energy Regulatory Commission
                                       Washington,  D.C.   20426

IV-D-8                                 Ms.  Barbara J. Faulkner
                                       National  Oil  Jobbers Council
                                        1707 H Street, N.W., llth Floor
                                       Washington,  D.C.   20006

IV-D-9                                 Mr.  Charles  L. Miller
                                       Texas City  Refining, Inc.
                                       P.O.  Box  1271
                                       Texas City,  Texas   77590

IV-D-10                                Mr.  A.D.  Davis
                                       Transgulf Pipeline Company
                                       P.O.  Box  44
                                       Winter Park,  Florida  32790
                                2-3

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       TABLE 2-1.   LIST OF COMMENTERS ON THE PROPOSED STANDARDS
         OF PERFORMANCE FOR BULK GASOLINE TERMINALS (Continued)


Item Number in
Docket A-79-52                           Commenter and Affiliation

IV-D-11                                 Mr. William R. Deutsch
                                        Illinois Petroleum Marketers Assoc.
                                        P.O. Box 1508
                                        112 West Cook Street
                                        Springfield,  Illinois  62705

IV-D-12                                 Mr. Norwood K. Talbert
                                        AGWAY,  Inc.
                                        P.O. Box 4933
                                        Syracuse, New York   13221

IV-D-13                                 Mr. John Prokop
                                         Independent Liquid Terminals Assoc.
                                         101 15th Street,  N.W.
                                        Washington, D.C.  20005

IV-D-14                                 Mr. E.P. Mampe
                                         Crown  Central Petroleum  Corporation
                                         P.O. Box 1168
                                         Baltimore, Maryland   21203

IV-D-16                                 Mr. Martin A. Snith
                                         Pacific Resources,  Inc.
                                         PRI Tower,  733  Bishop  Street
                                         P.O. Box 3379
                                         Honolulu, Hawaii  96842

IV-D-17                                 Mr. Barnard  R.  McEntire
                                         Air Pollution Control  District
                                         County of San Diego
                                         9150 Chesapeake Drive
                                         San Diego,  California  92123

IV-D-18                                  Mr. Dave Fellers
                                         Texas  Oil Marketers  Association
                                         701 W. 15th Street
                                         Austin, Texas   78701

IV-D-19                                  Mr. Willard T.  Young
                                         Texas  Eastern Transmission  Corporation
                                         P.O. Box 2521
                                         Houston, Texas   77001
                                 2-4

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       TABLE 2-1.   LIST OF COMMENTERS ON THE PROPOSED STANDARDS
         OF PERFORMANCE FOR BULK GASOLINE TERMINALS (Continued)

I ten Number in
Docket A-79-52                           Conimenter and Affiliation

1V-D-23                                 Mr.  J.S.  Trout
                                        Mr.  I.D.  Currdn
                                        Exxon Company, USA
                                        P.O. Box  2180
                                        Houston,  Texas  77001

IV-D-24,  IV-D-41                        Mr.  C.E.  Henderson
                                        Amoco Oil  Company
                                        200  East  Randolph Drive
                                        P.O. Box  6110A
                                        Chicago,  Illinois  60680

IV-D-25                                 Mr.  J.J.  Moon
                                        Phillips  Petroleum Company
                                        Bartlesville, Oklahoma  74004

IV-U-26                                 Mr.  C.T.  Sawyer
                                        American  Petroleum Institute
                                        2101 L Street, N.W.
                                        Washington, D.C.  20037

IV-D-27                                 Mr.  Leonard P. Steuart, II
                                        Independent Fuel Terminal Operators
                                          Association
                                        1700 Pennsylvania Avenue, N.W.
                                        Suite 300
                                        Washington, D.C.  20006

 IV-D-28                                 Mr.  Michael J. Duffy
                                        Ashland Oil,  Inc.
                                        P.O. Box 391
                                        Ashland,  Kentucky   41101

 IV-D-29                                 Ms.  Susan  R.  Kauffman
                                        Union Oil  Company of California
                                        Union Oil  Center, Box  7600
                                        Los  Angeles,  California  90051

 IV-D-30, IV-D-40                        Mr.  A.G.  Smith
                                        Shell Oil  Company
                                        One Shell  Plaza
                                        P.O. Box 4320
                                        Houston,  Texas   77210

 IV-D-31                                 Mr.  R.W.  Kreutzen
                                        Chevron U.S.A.,  Inc.
                                        P.O. Box 3069
                                        San Francisco,  California   94119
                                 2-5

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       TABLE 2-1.  LIST OF COMMENTERS ON THE PROPOSED STANDARDS
         OF PERFORMANCE FOR BULK GASOLINE TERMINALS (Concluded)
Item Number in
Docket A-79-52

IV-D-32
IV-D-33
IV-D-34
IV-D-35
IV-D-36
1V-D-37, IV-D-38, IV-D-42
IV-D-39
IV-D-45
 Commenter and Affiliation

Mr. Darrell D. LaRue
Diamond Shamrock Corporation
P.O. Box 631
Amarillo, Texas  79173

Mr. J.W. Drake
Kerr-McGee Corporation
Kerr-McGee Center
Oklahoma City, Oklahoma  73125
Mr. R.A. Nichols
R.A. Nichols Engineering
519 Iris Avenue
Corona Del Mar, California
                                                                     92625
Mr. Michael D. Graves
Hall, Estill, Hardwick, et. al
4100 Bank of Oklahoma Tower
Tulsa, Oklahoma  74172

Mr. James C. McGill
McGill, Incorporated
5800 West 68th Street
P.O. Box 9667
Tulsa, Oklahoma  74107

Mr. E.J. Karkalik
Standard Oil Company of Ohio
Midland Building
Cleveland, Ohio  44115

Mr. James F. McAvoy
State of Ohio Environmental
  Protection Agency
Box 1049, 361 E. Broad St.
Columbus, Ohio  43216

Ms. Lynne R. Harris
Department of Health & Human
  Services (NIOSH)
5600 Fishers Lane
Rockville, Maryland  20857
 These documents are transcripts  submitted  by  commenters  at  the
 public hearing and are essentially  identical  to  their oral  testimonies.
                                 2-6

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and the amount of pollution controlled is minimal.  One commenter
further questioned the need for the standards since gasoline demand  is
projected to remain stable or decline in the future, so that emissions
from new, modified, or reconstructed sources would not be expected to
present any greater environmental  hazard (IV-D-18, IV-D-24, IV-D-26,
IV-D-28, IV-D-41, IV-E-19, IV-F-4, IV-F-6).
     Four comnenters felt that the additional emission reduction
achieved under Alternative IV (35 nig/liter from processor plus vapor-
tight tank trucks) as opposed to Alternative II (80 mg/liter from
processor plus vapor-tight tank trucks) would be insignificant.  The
control limit of 80 mg/liter required by many SIP's has already reduced
VOC emissions by 90 percent; the proposed 35 mg/liter limit would  reduce
nationwide bulk terminal VOC emissions by the year 1985 by only an addi-
tional 0.0058 percent (IV-D-19, IV-D-20, IV-D-30, IV-F-1, IV-F-2).
Another commenter pointed out that Alternative  IV would reduce nation-
wide emissions by only an additional 0.9 percent over the reductions
resulting from SIP's (Alternative I).  Also, the reduction of  6,620 Mg/yr
due to this alternative would represent only 0.04 percent of the current
15 million Mg/yr nationwide VOC emissions from  all sources.  Due to
these small reductions, it is apparent that  standards have been proposed
simply because they are "technically feasible."  Thus, EPA has not
demonstrated, as required by Section 111, that  new terminals will  present
a  significant air pollution problem  (IV-D-26).
      Response:  The Agency proposed  these standards of performance under
the authority of Section  111 of the  Clean Air Act  (42 U.S.C.  7411) as
amended.  Section  lll(b)(l) requires the Administrator to establish
standards of  performance  for categories  of  new, modified, or  reconstructed
stationary sources which  in the Administrator's judgment  cause or  con-
tribute  significantly to  air pollution which may  reasonably  be anticipated
to  endanger public health  or welfare.
      The Agency's  listing  of Petroleum Transportation and Marketing
23rd  on  the Priority List (1-2) required under  Section  lll(f)
(40 CFR  60.16, 44  FR 49222, August  21,  1979) reflects the Administrator's
determination that this source  category  contributes  significantly  to air
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pollution.  Before arriving at  this decision,  the  Administrator
considered the projected rate of growth  in  the number  of  facilities  in
this industry, the emission rates  at  uncontrolled  facilities,  and  the
emissions allowed under typical SIP's.   EPA used the emissions forecasts
in BID, Volume I, and  cited by  the commenters, in  analyzing  these  factors,
and the Administrator  has  found no sound  reason to alter  the conclusions
based on  that analysis.
     It is important to note  that  VOC is  emitted by a  wide variety of
source categories.  The emissions  contribution from many  categories
with VOC  emissions that appear  small  in  comparison with the  total  VOC
emitted by all source  categories  is nonetheless significant  to ozone
formation.  This  is because  failure to control these sources to the
level achievable  by the best  demonstrated technology would serve to
undermine the Congressionally mandated effort to prevent  further
deterioration of  air quality  caused by additional  ozone formation.
     Under Section  111, EPA  is  required  to set standards  of performance
for those subcategories  (within listed categories) for which the Agency
can  identify  a  best demonstrated  system of continuous  emission reduction,
considering costs ("best  demonstrated technology").  As explained at
proposal  and  elsewhere in  this  document, the Agency has identified as
best demonstrated technology  for  the bulk gasoline terminal  industry a
combination of  capture and control measures aimed  at reducing VOC emis-
sions during  loading  (see  Section 2.10.3).  For this reason,  EPA  is
required  under  Section 111 to promulgate standards for the bulk terminals
subcategory.
     The  Agency  accounted  for the projected demand for gasoline in the
coming years  in  estimating the  emission reduction achievable  through
the  NSPS.  Despite a  leveling off or reduction in gasoline demand, the
new, modified,  and reconstructed   sources in this  subcategory  will continue
to be  an  important source of VOC   emissions.
     Standards  of performance have other benefits in addition to  achieving
reductions  in emissions  beyond  those required  by  a typical SIP.   They
establish a degree of  national  uniformity, which  precludes situations  in
which  some  States may  attract new  industries  as a result  of having relaxed
                                 2-8

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air pollution standards relative to other States.  Further,  standards
of performance provide documentation which reduces uncertainty  in
case-by-case determinations of best available control technology
(BACT) for facilities located in attainment areas, and  lowest achievable
emission rates (LAER) for facilities located in nonattainment areas.
This documentation includes identification and comprehensive analysis
of alternative emission control  technologies, development of associated
costs, an evaluation and verification of applicable emission test
methods, and identification of specific emission limits achievable
with alternate technologies.  The costs are provided for an  economic
analysis that reveals the affordability of controls in  an unbiased
study of the economic impact of controls on an industry.
     The rulemaking process that implements a performance standard
assures adequate technical review and promotes participation of repre-
sentatives of the industry being considered for regulation,  government,
and the public affected by that industry's emissions.   The  resultant
regulation represents a balance in which government resources are
applied in a well publicized national forum to reach a  decision on  a
pollution emission level that allows for a dynamic economy  and  a
healthful environment.
     As stated above, the standards reflect application of  the  best
demonstrated technology for new, modified, and reconstructed sources
in this subcategory.  While technical feasibility  is a  fundamental
criterion for standard-setting, EPA considered additional factors,
including cost,  energy  requirements, and other impacts, before  arriving
at the final standard.  Based upon  these factors,  the Agency selected
at proposal  a control alternative which reflects Alternative IV.   As
explained in Section  2.3.1, the Agency  has revised the  standard  in
response to  these and other comments; the  standards  are now based  on  a
control alternative which  reflects  a combination of  Alternatives  II
and  IV.
      Comment:  One conunenter  indicated  that  the  States  are  already
using the proposed standards as a new guideline  for  construction
permit  conditions.  This was said to constitute  needless  hardship  and
was given as a reason for withdrawal of the  proposal  (IV-E-19^1.
                                 2-9

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     Response:  Section 111 does not indicate that the existence of
independent State standard-setting authority is a proper basis  for
foregoing or postponing establishment of Federal NSPS.  States  are
free under Section 116 of the Act to establish more  stringent emission
limits than those established under Section  111 or 112, or  those
necessary to maintain the NAAQS under Section 110.   Consequently,  it
is possible that new sources may  in some cases be subject  to  1 im i'catinns
more stringent than standards of  performance under Section  111.
     Despite these considerations, all  States recognize that  a  proposed
standard of performance for new sources  is not considered  a final  rule
until  it has been promulgated.  Once the Administrator has  considered
all public comments, a proposed standard may undergo certain  modifica-
tions  in the  time period  preceding promulgation of the final  performance
standard.  Only  after the standard has  been  promulgated do the  standards
of performance become effective for all  new  or modified bulk  gasoline
terminals.

     Comment:  One commenter  stated that,  because  of Prevention of
Significant Deterioration  (PSD) regulations  which  apply essentially
the SIP  level of control  to new or modified  sources  in  attainment
areas, controls  proposed  under  the NSPS will  already be  largely in
place  (IV-D-1).  Also, existing and new sources  in  nonattainment
areas  would be adequately controlled  by SIP  requirements.   In attainment
areas, PSD requirements would deal with any  shifting of  emissions from
one  area of the  country to  another  (IV-D-24,  IV-E-19).
      Response:   The  typical SIP including  provisions for  bulk gasoline
terminal emissions will be  guided by  the two control techniques guide-
lines  (CTG) documents  (II-A-18,  II-A-32) discussed  on page 3-21 of BID,
Volume I.  The NSPS  requirements, reflecting the  best control systems
and  considering  costs  and other impacts, will  result in  additional
emission reduction over the estimated  SIP "baseline" level.  The
provisions of the  PSD  regulations were  not included  in the baseline
analysis because at  this  time it  is  unclear  how the  PSD requirements
will  be  interpreted  in different  areas.  Congress demonstrated its
concern  about this potential  variability by  requiring EPA to establish
nationally uniform minimum standards  as a floor underlying the requirements
                                 2-10

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established in the case-by-case PSD and nonattainment  area  new  source
reviews.  In addition to achieving further reductions  in  emissions
beyond those required by a typical SIP, standards of performance
establish the degree of national uniformity sought by  Congress  for
control of new, modified, and reconstructed facilities.
2.1.2  Designation of Effective Date of the Standard
     Comment:  One commenter requested that EPA provide  its  "customary
leeway" between the promulgation date and the date the regulation
becomes effective (IV-D-12).
     Response:  While the commenter did not elaborate  on  his  reference
to "customary leeway," the Administrator has not traditionally  provided
leeway between the promulgation date and the date the  regulation
becomes effective.  Section lll(b)(l)(B) of the Clean  Air Act states
"standards of performance . . . shall become effective upon  promulgation."
As stated in Section lll(e) of  the Act, "after the effective  date  on
which  the standard has been promulgated, it shall be unlawful  for  any
owner  or operator of a new or modified source to operate  such source
in violation of the standard of performance applicable to such  source."
     Comment:  One commenter stated that the current applicability
date of December  17, 1980, would  cause disruption in the  compliance
schedules of terminals working  to comply with the requirements  of
SIP's.  A revised date of January 7, 1982, was suggested, in  order to
allow  current efforts to be completed  (IV-D-23).  Another commenter
felt that a phase-in period should exist between the promulgation  date
and the effective date of the standards, to avoid construction  delays
which  could result from  the present arrangement (IV-D-32).
     Response:  The Administrator believes that some doubt  was  introduced
in the preamble to the proposed standards  as to the  application of the
reconstruction provisions to existing facilities undergoing  programs
of component replacement due to State and  local bulk terminal regulations.
Consequently, owners and operators making  plans to  install  control
systems at  these  facilities may have been  misled to  believe that
stricter NSPS  requirements might  not apply,  ^or this  reason, the
Administrator  has changed the applicability date for facilities in
this situation from  the  date of proposal to the date of  promulgation.
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Under Section 60.500(c), any component replacement  program  commenced
(as defined In Section 60.2) before the  promulgation  date,  and  determined
by the Administrator to be necessitated  by  State  or local bulk  terminal
regulations, will not subject a bulk  terminal  facility  to the NSPS  by
means of the reconstruction provisions.   However, component replacement
programs commenced after the promulgation date, regardless  of mandated
requirements, will be considered  under the  reconstruction provisions  of
40 CFR 60.15.  A more complete discussion of  this  issue can be  found  in
Section 2.3.1 of this document.
2.1.3  Definition of a Bulk Gasoline  Terminal
     Six commenters  recommended that  changes  to the definition  of a
bulk gasoline terminal would make its meaning  and applicability clearer.
     Comment:  Two commenters suggested  that  the  CTG limitation of
throughput  greater than 20,000 gallons per  day be incorporated  into
the definition of a  bulk gasoline terminal  so that  bulk plants  which
are served  by ship or barge are excluded from the standard  (IV-D-26,
IV-D-30).   Another commenter  suggested that terminals with  a throughput
of  less than  250,000 gallons  per  day  be  exempt from the regulation,
since  the  costs  of installing vapor recovery  equipment at  such  a
facility would far outweigh the environmental  benefits (IV-D-16).
Another commenter recommended that the Administrator exempt as  nonmajor
sources, facilities  that have less than  200,000 gallons per day throughput.
Marginal or small operators cannot invest the additional  capital
necessary  to  install a  vapor  collection  system,  leading to  the  prolonged
life  of old,  less efficient gasoline  truck  loading  facilities  (IV-D-33).
      Response:   To clarify the  intended  applicability of the NSPS,  a
definition  of bulk terminal dependent upon  a  throughput cutoff  has
been  included in §60.501.   The  purpose  of this definition  is to exclude
the  smaller bulk plant.  With  this intention, a bulk terminal  has been
defined to  have  a gasoline throughput greater than 75,700  liters per
day.   The  gasoline throughput shall be  the  maximum calculated  design
throughput  as may be limited  by  compliance  with an enforceable  condition
under  Federal, State,  or  local  law.  Reference to an enforceable
condition  allows a source  to  limit its maximum design throughput by
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limiting its hours of operation, or any other operating parameter.
The only requirements are that this limitation be a part of  an  enforceable
document and the source maintain compliance with it.  This document
could be issued by any government entity as long as it was discoverable
by both EPA and any citizen as contemplated in Section 304 of  the
Clean Air Act.   By obtaining such documentation, which would reflect  a
source's maximum expected actual throughput, ambiguities as  to  how one
would determine throughput are eliminated.   For example, a bulk  plant
which receives  gasoline by barge, with a statement (documented  in an
enforceable permit) that it will not exceed a throughput of  15,140 liters/
day (4,000 gal/day), could not be misconstrued as a bulk terminal.
     Since proposal of these standards, the costs of installing  vapor
recovery equipment for smaller terminals have been re-examined  in
light of additional information supplied by commenters.  The revised
cost impact estimates are presented in Section B.2 of Appendix  B.
These revised cost and economic impacts do not indicate an adverse
impact on even the smallest model plant (380,000 liters/day, or
100,000 gallons/day).  Therefore, incorporating a throughput cutoff of
200,000 or 250,000 gallons/day  is not warranted.

     Comment:  One commenter advised that by adding the phrase  "from  a
refinery" to the end of the definition of a bulk gasoline terminal,
certain marine bulk plants of low throughput would be excluded  from
the standards  (IV-D-29, IV-F-1).  Another commenter recommended  that
the definition of  a bulk gasoline terminal  be revised to exclude
refinery facilities which receive gasoline by "pipeline"  (IV-D-30).
     Response:  It  is unnecessary to include "from a refinery"  in the
revised definition  of a terminal.  The throughput limitation,  which
has been added to  the definition, will serve to exclude from the
standards certain  marine bulk plants of low throughput, which  receive
their gasoline by  ship or barge.  Also, if the phrase  "from  a  refinery"
were added,  it is  possible that certain terminal facilities  may be
inadvertently  excluded from the standards, particularly any  terminals
which may not  receive gasoline  from a  refinery.
     Gasoline  terminals at refineries  load gasoline into tank  trucks
from loading racks.  This operation is identical to operations  at

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conventional terminals and is  intended to  be  covered  by  these  standards.
Therefore, any new or modified bulk gasoline  terminal  of sufficient
throughput which receives gasoline by  "pipeline,"  regardless of  location,
will be affected by the standards.

     Comment:  One commenter stated that many terminals  handling
gasoline for others are not wholesale  outlets,  since  they do not own
the gasoline, whereas the proposed regulation defines bulk gasoline
terminals to include only wholesale outlets  (IV-D-13).
     Response:   It was not EPA's  intent  in the proposed  standards to
exclude typical  terminals from the regulation which may  not be classified
as  wholesale outlets.  While some terminals,  as the commenter  points
out, are  not "wholesale" outlets  since they  do not own the gasoline,
they nonetheless perform the gasoline  transfer operations.  The sole
intent of  including the term  "wholesale"  in  the definition at  proposal
was to distinguish the facilities from large retail service stations
which may  receive gasoline by  pipeline.   The facility described by the
commenter  is clearly  not a  retail outlet  and the intent was to cover
this type  of facility.  With the  addition of a throughput cutoff and
with the  retention of  the mode-of-delivery definition, EPA believes
that retail  outlets will  be  excluded.   Therefore, the term "wholesale"
 is  considered  unnecessary  and  is  deleted  from the definition.
2.1.4   Executive Order 12291
     Comment:   Three  commenters stated that the proposed standards
violate  the Executive Order  12291 criteria for priority-setting,
evidentiary support,  and  rational decision-making.  This opinion is
based  generally on what  they  felt was  EPA's failure to demonstrate  an
adequate  and  favorable cost-benefit situation  (IV-D-18,  IV-D-26,
 IV-D-31).
     The  commenters  stated  that  the general  requirements for  Federal
regulations set forth in  Executive Order 12291 stress the need  for  an
analysis  of the incremental  benefits to society derived  from  the
 incremental  costs involved  in  choosing the more stringent emission
 limit  (35 mg/liter  versus  80 mg/liter).  They  cited Section 2 of the
Order  which,  in part,  requires the following:
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          "(b)   Regulatory action shall  not be undertaken unless the
     potential  benefits  to society for the regulation outweigh the
     potential  costs to  society;
           (c)   Regulatory objectives shall be chosen to maximize the
     net benefits  to society;
           (d)   Among alternative approaches to any given regulatory
     objective,  the alternative involving the least net cost to society
     shall  be chosen; and
           (e)   Agencies shall  set regulatory priorities with the aim
     of maximizing the aggregate net benefits to society. . ."
The commenters  noted that Section 2(d) of the Order requires that EPA
consider the incremental cost  of selecting a 35 mg/liter limit rather
than an 80 mg/liter limit in light of alternative methods of controlling
VOC emissions.   This latter analysis was claimed to be entirely lacking
in the BID (IV-D-31).
     Response:   The original economic analysis in BID, Volume I revealed
fifth-year net annualized costs of $6.0 million ($5.3 million for the
bulk terminal industry and $0.7 for the for-hire tank trucks), which
is well below the $100 million criterion  (BID, Volume I, Section 8.5.1),
which would classify this as a major regulation and would mandate an
in-depth cost-benefit analysis.  The revised economic analysis
(Section B.3 of Appendix B) supports this  conclusion, with  the net
cost to industry in the fifth  year now estimated to be $2.5 million.
     Nevertheless, the Agency has undertaken a comprehensive economic
analysis of the regulatory alternatives.   In addition, the  Agency has
carefully considered both the emission reduction and  costs  associated
with each of four regulatory alternatives  on both an  average and an
incremental basis.  Among the alternatives  considered were  the 35 mg/
liter and 80 mg/liter emission  limits addressed by the commenters.  As
shown  in Chapter 8 of BID, Volume I, the  Agency considered  these costs
and benefits in connection with  140 combinations of facility classifi-
cation, regulatory alternative, model plant  size, and vapor control
unit type.
     The Agency has  responded in Section  2.5 to specific comments on
the cost analysis presented in  BID,  Volume  I.  Based  on  its  consideration
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of these comments and EPA's projection of  the  impact  of  each  alternative,
the Agency has concluded that the  alternative  chosen--35 mg/liter  and
loading only into vapor-tight trucks—represents  the  regulatory  alter-
native that would result in the greatest emission  reduction  achievable
at reasonable cost for new vapor processing  systems.   Furthermore,  as
discussed in Section 2.3.1, affected  facilities with  existing vapor
control systems installed under SIP programs will  be  required to meet
an emission limit of 80 mg/liter [§60.502(c)j.   In most  cases, this is
the limit for which such systems are  being designed,  and so  replace-
ment or upgrading of the system should be  unnecessary under  NSPS.
This requirement eliminates many of the concerns  expressed by the
commenters about the incremental costs and emission reductions of  an
80 mg/liter versus 35 mg/liter  limit, because  the  expense of replacing
or upgrading an existing vapor  processor which is  performing to  its
design level will not be incurred  by  most  owners  and  operators of
modified or reconstructed facilities  which are already being controlled
under  SIP's.  Thus, EPA  has undertaken analyses and selected an  alterna-
tive that in the Agency's judgment responds  to the intent of the
requirements of Executive Order  12291, to  the  extent permitted by  law,
and is permitted under the  strict  requirements of Section 111.
2.1.5  Other Comments
     Comment:   One commenter  felt  that,  as a result of the proposed
rule,  the States would require  all bulk  plants and service stations to
install  a vapor recovery balance system  (IV-D-11).
     Response:  The performance standard  for bulk gasoline terminals
does not limit  emissions from either  bulk  plants  or service  stations
by requiring the installation of vapor  recovery systems  at either  of
these  types of  facilities.  As  discussed  in  the preamble to  the  proposed
regulation, the promulgated standards of  performance limit TOC emissions
(and hence, VOC emissions)  from  each  affected  facility on which  construction,
modification, or reconstruction  commenced  after December 17, 1980.
The affected facility is the  total of all  the  loading racks  at a bulk
gasoline terminal which  deliver  either gasoline into any delivery  tank
truck  or some other liquid  product into  trucks which have loaded
gasoline on the immediately previous  load.

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     Many States  require under separate regulatory action that  service
stations and bulk plants Install  balance systems to Unit VOC emissions
in nonattainment  areas.   Balance systems are used at gasoline bulk
plants and service stations to limit VOC emissions by exchanging
vapors for delivered product through the use of vapor piping.   However,
the regulatory action of this standard is totally independent of  State
actions.
     Comment:  One commenter was concerned about the proper  delegation
of the enforcement responsibility for the NSPS standard.  This  commenter
recommended that the city or county where a bulk gasoline terminal  is
located be entrusted with the enforcement of the standard, since  they
may already have the responsibility for enforcing State  regulations.
This would relieve terminal owners/operators and the States  from
complying with differing regulations that possibly duplicate enforcement
efforts  (IV-D-32).
      Response:   The  proper  delegation of the enforcement responsibility
for the  NSPS  standard is outlined  in Section  lll(c)(l)  of  the Clean
Air Act.  Once a performance  standard has been  promulgated,  each  State
may develop  and  submit  to  the Administrator a  procedure for  implementing
and enforcing standards  of  performance  for  new  sources  located  in each
State.   If  the Administrator  determines  that  the  State  procedure  is
adequate, authority  to  implement  and  enforce  such  standards  will  be
delegated to  that  particular  State.
      Comment: Another  commenter  thought that  the  proposal  would  have
a substantial impact on many  small  businessmen  and  should thus  be
 revised to  conform to the  intent  of the Regulatory  Flexibility Act
 (IV-D-5).
      Response:   The Regulatory  Flexibility  Act  (RFA)  does not by its
 terms apply to regulations  proposed prior  to  January 1, 1981.  Consequently,
 the Act does not impose any requirements in the Agency's development
 of the bulk gasoline terminal  NSPS.   Uith  regard  to  totally new bulk
 terminals,  it is projected that even  in the absence  of additional
 regulation  there will  be little growth  among  smaller terminals.
 However, most of the existing terminals which become affected due  to
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modification or reconstruction  are  likely  to  be  of  the  smaller sizes.
Therefore, the Agency has  considered  the economic  impact  of  the standards
on relatively small  terminals  and  carriers,  and  the economic analysis
has since been reviewed  in reference  to  the  RFA  with the  results
presented in Appendix B.5.   The criteria necessitating  a  full-scale
regulatory flexibility analysis were  reviewed for  the small  business
sector of this industry.   Because  of  the unlikelihood of  significant
differential impacts on  either  the  large or  small  terminal  and tank
truck business sectors resulting from these  standards,  the in-depth
Regulatory Flexibility Analysis was not  indicated  to be necessary.
2.2  DESIGNATION  OF  AFFECTED FACILITY
     Comment:  One  commenter stated that the purpose of NSPS is violated
by designating the  affected facility  to  include  more than just the
specific  new or modified facility.   He pointed out that the benefits
to air quality would  probably occur anyway,  due  to the technology
involved  (IV-D-1).
     Response:   In  choosing the affected facility, the Agency decides
which piece  or group of  equipment is  the appropriate unit for separate
emission  standards  in  the particular industrial  context involved.  The
Agency does  this  by  examining the situation  in light of the terms and
purpose  of  Section  111 of the Clean Air Act.  The purpose of Section 111
is to minimize emissions by application  of the best demonstrated
control  technology  at all new and modified sources (considering cost,
other health  and  environmental  effects,  and  energy requirements).   In
some cases  a narrower designation of the affected facility may be
appropriate,  because it  ensures that new emission sources within
plants will  be  brought under the coverage of the standards as  they  are
 installed.   However,  if  the Agency concludes that a broader designation
would result in  greater  emission reduction,  and that consideration  of
the other relevant  statutory factors (technical  feasibility, cost,
energy,  and  other environmental impacts) reveals that choosing a
broader  designation  would be reasonable, then the Agency may choose
 the broader designation.
     While  selection of  a narrower designation of  affected  facility
 results  in  greater emission reduction by earlier coverage of  replacement

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equipment, It appears a broader designation would  result  in  greater
emission reduction in the bulk gasoline terminal industry.   EPA  projects
that if loading rack replacements do occur, they will  involve  major
changes in the rack system (such as conversion  from top to  bottom
loading) arid will involve most or all of the racks at  the  terminal
rather than just one rack.  Through modification and reconstruction,
the broader designation of the affected facility will  result in  the
application of the standards to more loading racks and therefore will
result in greater emission reduction.
     The Agency requested comments specifically concerning  this  issue
at proposal, to verify whether the environmental and economic  impacts
of alternative affected facility designations,  as  projected  by the
Agency, are accurate.  The Agency also requested specific  information
and data which would permit an evaluation of these impacts.  This has
been the only written comment to specifically address  this  issue which
was received by the Agency during the public comment period.   Comments
were also received from six industry representatives who  stated  at  a
meeting with EPA that they had no objection to  the proposed  designation
of the affected facility  (IV-E-19).  Since the  conclusions  about emis-
sion reductions and costs have not changed for  this facility designation,
EPA has retained the total racks designation of the affected facility.
2.3  MODIFICATION AND RECONSTRUCTION
2.3.1  SIP Conversions
     Comment:  Several commenters were concerned that  conversions now
being made to terminals to satisfy SIP control  requirements, such as
top-to-bottom  loading conversions and  installation of  vapor control
equipment, could subject  these terminals to more stringent NSPS  require-
ments.  It was suggested  by some of  the commenters that  the economic
impact on the  industry would  be great  and  that  these conversions
should be exempted from the reconstruction provisions  of  40 CFR  60.15
(IV-D-14, IV-D-25, IV-D-26, IV-D-28, IV-F-1,  IV-F-2).
     Response:  The  section entitled "Impacts of Regulatory Alternatives"
in the preamble to the proposed standards  discussed the  environmental,
cost,  and economic impacts on bulk terminal facilities complying with
the requirements of  those standards.   Included  in  the  discussion were
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impacts on new, modified, and reconstructed facilities.  The impacts
estimated for the standards did not include any reconstructions resulting
from application of State or local air pollution requirements.  However,
as several commenters pointed out, a large number of terminal facilities
that the Agency did not project as affected could indeed become subject
to the standards in the process of complying with such requirements.
Thus, the preamble discussion suggested that existing facilities
commencing component replacement  in response to State or local requirements
would not be subject to 40 CFR 60.15.
     The Agency believes that this suggestion  introduced some doubt  as
to the otherwise straightforward  application of the reconstruction
provisions to existing facilities undergoing such changes.   Consequently,
owners and operators making plans to install control systems at these
facilities may have been misled to believe that stricter NSPS requirements
might not apply, and may therefore not have considered the stricter
NSPS requirements when designing  their systems.
     For this reason, the Administrator has determined that  any facility
that has commenced substantial component  replacement in response  to
state or local emission standards after the applicability date (the
proposal date—December 17, 1980) but prior to the date of promulgation
will not be  subject to these requirements by operation of the reconstruction
provisions of 40 CFR 60.15.  Under Section 60.500(c), any component
replacement  program commenced (as defined in Section 60.2) before the
promulgation date, and determined by the  Administrator to be necessitated
by State or  local bulk terminal regulations, will not subject a bulk
terminal facility to the NSPS by  means of the  reconstruction provisions.
     It should be noted, however, that 40 CFR  60.15 applies  by straightforward
application  to any existing facility undergoing component replacement.
Neither the  language nor the purposes of  that  provision and  the definition
of "new source" in Section 111 supports exemptions based on  the owner's
intent in performing construction on the  facility.
     Because this preamble corrects the misimpression that Section 60.15
does not apply to facilities undergoing SIP component replacement, the
Agency is applying that provision to SIP  component replacement programs
commenced after the promulgation  date.  Of course, owners or operators
performing reconstruction for other purposes,  or modifications or new

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construction for any purpose, are still governed by the  applicability
date of December 17, 1980, contained in Section 60.500(b).

     Comment:  Several  comnienters stated that the number of  facilities
affected by the modification and reconstruction provisions was  greatly
underestimated by EPA.   EPA had estimated that 110 terminals would  be
subject to the proposed regulation within the next 10 years:   10 new
terminals and 100 modified or reconstructed terminals.   This estimate
was claimed to be inaccurate since 30 States will require at least
some terminals within their jurisdictions to control TOC emissions  to
80 ing/liter.  Control of TOC emissions to 80 mg/liter will require
top-to-bottom loading conversions and vapor recovery installation.
These operational changes will usually constitute a "reconstruction"
of the terminal, thereby subjecting the terminal to EPA's proposed
regulation (IV-D-23, IV-D-26, IV-D-35, IV-D-37, IV-E-19, IV-F-1,
IV-F-3).
     One commenter estimated that from 250 to 800 reconstructions
could be performed in the next 10 years, and stated that EPA's  inclusion
of so many existing sources because of SIP conversions was an  invasion
of the State and local  sphere of regulation and thus beyond  EPA's
statutory authority (IV-D-26).  Another commenter stated that  as many
as 25 percent of his company's existing terminals could  be impacted in
the next 10 years (IV-F-1, IV-F-3).
     Response:  As stated in the previous response, §60.500(c)  changes
the applicability date from the proposal date to the promulgation date
for gasoline loading rack component replacement programs that  were
commenced prior to the promulgation date for the purposes of meeting
State or local regulations.  Since most State or local regulation-
related component replacement programs at terminals will have  commenced
by the promulgation date, the change in the applicability date,  in
effect, excludes these terminals from the standards.  The commenters
included these State or local regulation-related changes in  their
determinations; therefore, the number of affected facilities estimated
by the commenters is much too high.  EPA considers its estimate of
110 new, modified, or reconstt uct<.:n tenrinals still to be accurate.
As stated in Section 8.1.2 of BID, Volume I, the estimate of 10 new

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facilities and 100 modified or reconstructed facilities was  based
primarily on information obtained from oil companies  through  responses
to Section 114 letter requests (II-D-118,  II-D-121,  II-D-122,  II-D-124,
II-D-125, II-D-127-138).  This was  supplemented  by  telephone  conver-
sations with several control  agencies, oil companies,  and  terminal
construction engineering firms (II-E-34-38,  II-E-41-44,  II-E-46-49,
II-E-51,  II-E-79,  II-E-93).

     Comment:  One  comnenter  felt that  if the  proposed standards
further  limited  allowable  VOC emissions  from 80  mg/liter  to  35 mg/liter
of gasoline  loaded,  then 30 of his  59 plants would  experience "immediate
operational  constraints,"  since  they  are equipped with vapor processing
units  of  the compression-refrigeration-absorption  (CRA)  or lean oil
absorption  (LOA)  type,  which  EPA data  indicate cannot meet the 35  mg/liter
limit  (IV-D-30).
     Response:   The existing  facilities  described  by the commenter
would  not be subject to the standards  unless modification or recon-
struction "commenced"  after the  proposal date  of December 17, 1980.
Any  such  work  commenced prior to the  proposal  date  would not apply
under  these  standards.  However,  programs of  construction, modification,
or reconstruction would subject  a  terminal owner or operator to the
requirements of  the standards,  as  stated in  §60.500(b) of the regulation.
Further,  §60.502(c) of  the proposed regulation established an emission
limit  of 35  mg/liter to be applied  to all such facilities.  Included
in this  group of facilities were those  which had previously installed
vapor  collection and processing  systems under  SIP requirements, such
as those referred to by the  commenter.   EPA estimates that 20 such
facilities  will  become  affected  by NSPS through modification or
reconstruction in the first  5 years in  which the standards are in
effect.   Of  these 20 facilities, 10 are likely to have vapor control
systems  which already meet a  35  mg/liter limit (CA, TO, and some REF
systems).  The remaining 10  systems should be  attaining the 80 mg/liter
limit  required under most  State  plans.
     One paragraph about facilities with existing vapor processing
equipment was added to Section 60.502.   The Agency has concluded that
it  is  quite  costly in light of the resulting emission reduction for an

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owner whose existing facility becomes subject to NSPS  (e.g.,  through
modification or reconstruction) to meet 35 ing/liter when the  facility
already has a system capable of meeting 80 nig/liter, but not  35 mg/liter.
In the Administrator's judgment, however, it is unreasonably  costly to
require such a facility to install the add-on technology that will
achieve 35 mg/liter only if the facility began constructing or substantially
rebuilding (i.e., "refurbishing") the control system before receiving
notice December 17, 1980, that BDT for those facilities, were they
later to come under NSPS, would likely be equipment capable of meeting
35 mg/1iter.
     By contrast, EPA considers it reasonable to apply the 35 mg/liter
limit to a facility whose owner commenced construction or refurbishment
of d control system not capable of meeting 35 mg/liter despite having
received this notice.  It is reasonable to expect such an owner to
avoid the high cost of going from 80 mg/liter to 35 mg/liter  simply by
constructing or refurbishing the facility's control system with technology
that would meet EPA's 35 mg/liter limit and make later retrofit unnecessary.
This is reasonable to require even of facilities with existing control
systems constructed or refurbished after December 17,  1980, for the
purpose of meeting an 80 mg/liter State limit.
     For these reasons, EPA has added Section 60.502(c), which permits
affected facilities with such vapor control equipment to meet 80  mg/liter
if construction or substantial  rebuilding  (i.e., "refurbishment") of
that equipment commenced before the proposal date, December 17, 1980.
This is based on the Administrator's judgment that BDT for these
facilities is no further control, while BDT for facilities with vapor
processing systems on which construction or refurbishment commenced
after proposal is the replacement or add-on technology that would enable
the  facility to achieve 35 mg/liter.
     Definitions for  "existing  vapor processing system"  and "refurbishment"
were added to the regulation to  indicate that if in any  2-year period
following  the date the facility  becomes an  affected facility  the  fixed
capital cost of improvements or  changes to  an existing vapor  processing
system exceeds 50 percent of the  cost of a  comparable  entirely new
vapor processing system, the altered vapor  processing  system  must then
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meet the 35 mg/liter  limit.   Consequently,  refurbishment  applies  only
to those systems which become extensively  altered  over this  period.
2.3.2   Interpretation of  Reconstruction
     Comment:  One commenter  felt  that the reconstruction provisions
are contrary to  law,  because  the  provisions apply  to converted  facilities
from which emissions  have not increased.   An example of the  potential
misapplication of these  provisions was provided:   conversion from top
to bottom  loading, in which emissions would be expected to decrease.
The consideration of  this situation under  reconstruction was said to
be contrary  to the legislative  intent  of  Section  111.   Further, the
commenter  suggested  that the  reconstruction provisions be deleted from
this and all other NSPS.   If  this  is not  done, a  thorough legal analysis
in support of  EPA's  authority to  regulate  reconstructed sources under
40 CFR  60.15 should  be  published,  as required by  Executive Order 12291,
Section 4(a) (IV-D-31).
     Response:   Since in enacting  Section  111 Congress did not define
the term "construction," the  question  arose whether NSPS would apply
to facilities  being  rebuilt.  Noncoverage  of such  facilities would
have produced  the  incongruity that NSPS  would apply to completely new
facilities,  but  not  to  facilities  that were essentially new because
they had undergone  reconstruction  of much  of their component equipment.
This would have  undermined Congress's  intent under Section 111 to
require strict control  of emissions as  the Nation's industrial base  is
replaced.
     EPA promulgated the reconstruction  provisions in  1975, after
notice  and opportunity  for public comment  (40 FR 58420, December 16,  1975),
to fulfill this  intent  of Congress.  Since this turnover  in the  industrial
base may occur  independently  of whether  emissions from the rebuilt
sources have increased,  the reconstruction provisions  do  not focus on
whether the  changes  that render a source essentially new  also  result
in  increased emissions.
     Congress  did  not attempt to  overrule  EPA's previous  promulgation
of Section 60.15 in  passing the Clean  Air Act Amendments  of 1977.
This indicates  that  Congress  viewed the  reconstruction provisions'
focus  on component  replacement, rather than emissions  level, as  con-
sistent with Section 111.  See, e.g.,  Red  Lion Broadcasting Co.  v. FCC,
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395 U.S.  367 (1969); NLRB v. Bell Aerospace Division, 416 U.S.  267
(1974).  Nor has any Court questioned the Agency's authority to  subject
reconstructed sources to new source performance standards.   In  fact,
in ASARCo v. EPA, 578 F. 2d 319, 328 n.31 (D.C. Cir.  1978),  the  D.C.
Circuit suggested that the reconstruction provisions  may not go  far
enough toward preventing possible abuses by owners seeking to avoid
NSPS by perpetuating the useful  lives of their existing facilities
indefinitely.
     Finally, coverage under §60.15 of loading rack conversions  comports
well with the intent underlying Section 111.  Conversion from top to
bottom loading may involve replacement of much existing equipment with
new equipment.  In such cases, the conversion may transform  the  existing
set of racks into an essentially new set of racks.  A key goal  of
Section 111 is to enhance air quality over the long term and maximize
the potential for long-term growth by minimizing emissions through
application of the best demonstrated technology to new emission  sources,
concurrent with the turnover of  the Nation's  industrial base.   If
owners are permitted to replace most of the equipment in their  existing
sets of racks without applying the best demonstrated  technology, they
will be installing new equipment without minimizing emissions and
maximizing the potential for long-term industrial growth, as Congress
sought in enacting Section 111.  For this reason, NSPS coverage of
sets of racks that undergo substantial component replacement through
conversion accords with Section  111, even where some  decrease in
emissions results from the conversion.
     As discussed in Section 2.3.1, facilities undergoing reconstruction
which  have an existing vapor control system will be  required to meet
the 80 mg/liter limit under which they were previously operating.   In
addition to this requirement,  the other provisions  of §60.502 will
apply, including the physical  requirements  on the vapor  collection
system which may not apply under many State regulations.  Also, the
tank  truck vapor tightness  requirements will  apply  to these  facilities.

     Comment:  Commenters stated that the reconstruction  provisions
should apply only to projects  in nonattainment areas  or  areas where
there  is a  risk of significant  deterioration  (IV-D-23,  IV-D-30).

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     Response:  In enacting Section 111, Congress sought  to  require
the best demonstrated level of control at all new sources, irrespective
of the air quality at the  location of the site.  Only by  assuring a
minimum level of control at new sources in all areas would two key
purposes underlying Section 111 be advanced -- enhancing  air quality
in all areas by requiring  application of the  best technology as the
Nation's industrial base is replaced, and preventing States  from
relaxing environmental standards below the best demonstrated level of
control to attract industry.

     Comment:  Several commenters stated that the interpretation of
"reconstruction" in the background information document  (BID, Volume  I)
and preamble is an unwarranted extension of EPA's past procedure in
defining this provision and is not consistent with  the intent of the
Clean Air Act.  Reconstruction, as defined in Section 60.15(d), may
apply only to a project which  in total meets  the 50 percent  capital
cost level and not to an accumulation of expenditures which  occurs
over an unlimited time period.   Under the present  interpretation of
reconstruction every existing  loading rack, including those  in attain-
ment areas, would, through ordinary maintenance and replacement of
components, become a new source long  before the end of its useful
life.  The commenters said that bulk  gasoline terminals  were subject
to constantly changing market  conditions, resulting in the need for
constant equipment upgrading in order to remain competitive  and provide
new services using state-of-the art  loading equipment.   The  use of
cumulative costs would be  a tremendous administrative burden on the
industry and EPA, and could have a negative effect  on emission reductions
by discouraging replacement of worn-out or defective components of
certain loading facilities, even where such work would bring about
reduced emissions.  In particular, costly and overly burdensome
recordkeeping and accounting procedures would be necessary to determine
when the 50 percent total  replacement cost level had been exceeded,
the cost of which was not  addressed  in BID, Volume  I (IV-D-20, IV-D-23,
IV-D-24, IV-D-25, IV-D-26, IV-D-30,  IV-D-31,  IV-D-37, IV-D-41, IV-E-19).
     Response:  As stated  above, EPA  promulgated the reconstruction
provisions because failure to  require best control  at sources that
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have become essentially new through extensive component  replacement
would have undermined Congress's intent that best technology  be  applied
as the Nation's industrial base is replaced.  Failure to cover facilities
thdt have undergone extensive component replacement over a long  period
of time similarly postpones the enhancement of air quality Congress
sought under Section 111.   The D.C. Circuit recognized this when  it
expressed concern in the ASARCo case that, absent a provision for
aggregating replacement expenditures i;over the years," owners could
evade the reconstruction provisions by continually replacing  obsolete
or worn-out equipment.   578 F.2d 319, 328 n.31 (D.C. Cir. 1978).
     Section 60.15 currently defines "reconstruction" as the  replacement
of components of an existing facility to such an extent that  "the
fixed capital cost of the new components" exceeds 50 percent  of  the
"fixed capital cost" that would be required to construct a comparable
entirely new facility and EPA determines that it is technologically
and economically feasible to meet the applicable NSPS.   Subsection  (d)
indicates that the "new components" whose cost would be  counted  toward
the 50 percent threshold include those components the owner "proposes
to replace."  It is unclear under this wording whether a
reconstruction has occurred in the case of an owner who  first seeks  to
replace components of an existing facility at a cost equal to 30  percent
of the cost of an entirely new facility and then, shortly after  commencing
or completing those replacements, seeks to replace an additional  30  percent.
Specifically, it is uncertain whether the owner should be deemed  to  have
made two distinct "proposals," or  instead a single proposal.
     For example, assume that a terminal owner converts  one of three
top  loading positions to bottom loading, and six months  later converts
another loading rack to bottom loading.   If the two conversions  were
interpreted as separate "proposals" under Section 60.15, neither would
likely exceed the 50 percent replacement cost threshold.  Under  this
general interpretation, owners could avoid NSPS coverage under
Section 60.15 simply by characterizing their replacement projects  as
distinct  "proposals," even where the component replacement  is completed
within a relatively short period of time.
     EPA did  not intend,  in promulgating  the reconstruction provisions,
that the term  "propose" exclude from NSPS coverage facilities undergoing

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this type of extensive component replacement.   Failure  to  cover  these
sources serves to underline Congress's  intent  that  air  quality be
enhanced over the long term by  applying  best demonstrated  technology
with the turnover in the Nation's  industrial base.
     To eliminate the ambiguity  in  the  current wording  of  Section  60.15
and further the intent underlying  Section  111  (as described  above),
the Agency is clarifying the meaning  of "proposed"  component replacements
in Section 60.15.  Specifically, the  Agency  is interpreting  "proposed"
replacement components under Section  60.15 to  include  components which
are replaced  pursuant to all continuous programs  of component replacement
which  commence .(but  are not necessarily completed)  within  the period
of  time  determined by the  Agency to be  appropriate  for the individual
NSPS  involved.  The  Agency is  selecting a 2-year  period as the appro-
priate period for  purposes of  the  bulk  gasoline terminal  NSPS
(Section 60.506(b)).  Thus, the Agency  will  count toward  the 50  percent
reconstruction  threshold the  "fixed capital  cost" of all  depreciable
components  (except those described above)  replaced  pursuant  to all
continuous  programs  of  reconstruction which commence within  any  2-year
period following  proposal  of  these standards.   In the Administrator's
judgment,  the 2-year period  provides  a  reasonable,  objective method of
determining whether  an  owner  of bulk gasoline  terminal  facilities  is
actually "proposing" extensive component replacement,  within the
Agency's original  intent  in  promulgating Section  60.15.
      EPA realizes  that  the bulk gasoline terminal industry is constantly
changing;  however, the  Agency  believes  that this  2-year limit will
assure that the owner would  have to make a substantial change to the
facility to reach  the 50  percent threshold.
      The administrative effort to  keep  the required records  should not
be  a  burden on the industry.   The  recordkeeping required  under a cumu-
lative basis  interpretation  of reconstruction  is  the same as the
recordkeeping that would  be  required under a strictly project-by-
project  basis interpretation.   In  either case, the dollar amount of
the component replacement  taking place  at the  affected facility must
be  determined and  recorded.   Once  this  dollar  amount has  been determined
for each change or conversion, the additional  requirement of keeping
this  information  on  file  at  the terminal does  not appear to be an
excessive  burden.
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     Section 60.15 defines the "fixed capital  cost" of replacement
components as the capital  needed to provide all "depreciable" components.
By excluding nondepreciable components from consideration in calculating
component replacement costs, this definition excludes many components
that are replaced frequently to keep the plant in proper working
order.   There may, however, be some depreciable components that are
replaced frequently for similar purposes.  In the Agency's judgment,
maintaining records of the repair or replacement of these items may
constitute an unnecessary burden.  Moreover, the Agency does not
consider the replacement of these items an element of the turnover in
the life of the facility concerning Congress when it enacted Section  111.
Therefore, in accordance with 40 CFR 60.15(g), these standards
(Section 60.506) exempt certain frequently replaced components, whether
depreciable or nondepreciable, from consideration in applying the
reconstruction provisions to bulk gasoline terminal facilities.  The
costs of these components will not be considered in calculating either
the "fixed capital cost of the new components" or the "fixed capital
cost that would be required to construct a comparable entirely new
facility" under Section 60.15.   In the Agency's judgment, these items
are pump seals, loading arm gaskets and swivels, coupler gaskets,
overfill sensors, vapor hoses, and grounding cables.

     Comment:  One commenter requested a clarification of the third
review criterion used in determining a reconstruction, which is stated
in the preamble to the proposed regulation:  "(3) The extent to which
the components being replaced cause or contribute to the emissions
from the facility."  This commenter felt that the term "reconstruction"
should apply only  if a conversion results  in an increase in emissions
(IV-D-29).
     Response:  An existing facility undergoes a "reconstruction,"
under 40 CFR 60.15, when  (1) the fixed capital cost of its new components
exceeds 50 percent of the fixed  capital  cost required to construct a
comparable entirely new facility, and  (2)  it is technologically and
economically feasible to meet the applicable standards.  According tc
§60.15(a), the determination of  reconstruction is made irrespective  of
any change  in  the  emission  rate  occasioned  by  the  component replacement.

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This is because applying NSPS to sources which  have  undergone  extensive
component replacement fulfills Congress's  intent  to  enhance  air  quality
by requiring best demonstrated control  as  the Nation's  industrial  base
is replaced.
     The review criteria in  Section  60.15(f) guide the  Administrator's
determination of technological and economic  feasibility.   The  third
criterion,  the extent to which the components "cause or contribute to
the emissions from  the  facility", relates  to the  replaced  components'
role in the  facility, not  the emission  change caused by the  replacement.
This criterion provides the  Administrator  discretion to exclude  from
the reconstruction  calculation replacement of components not considered
to play an  important  role  in producing  emissions.   However,  this is
only one of the factors guiding  the  determination.   Thus,  regardless
of the outcome of  this  examination,  the Administrator retains  discretion
under  the other criteria to  find that compliance  by  an  extensively
rebuilt facility  is technologically  and economically feasible.  The
Administrator's decision under Section  60.15(f) is  not  affected  by
whether any actual  change  in emission rate has  occurred.
     Comment:  Another  commenter was not clear  as to whether the
definition  of  a reconstruction would affect all bulk stations,
terminals,  and/or  service  stations  (IV-D-11).
      Response:  The standards  for bulk  gasoline terminals, and the
reconstruction provisions  associated with the  standards, apply only to
bulk  terminals which commence construction, reconstruction,  or modifi-
cation  after the  proposal  date  of December 17,  1980.  No requirements
or  controls are  imposed on bulk  stations or service stations by these
standards  (see Section  2.1.5).
2.3.3   Interpretation of Modification
      Comment:   Five commenters  felt that the interpretation of
 "modification" in  the preamble  and  BID, Volume I, is overly broad
because  it  may include  altered  facilities from which the overall
emissions  have not increased.   A clarification should be made so that
replacement of needed components that improve loading efficiencies
would  not  be considered "modifications" unless  they resulted  in an
increase  in the  average daily emissions.  For example, the  replacement
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of worn-out pumps with new higher capacity pumps would  allow  faster
loading, increasing the emissions per tank truckload on  a  kg/hour
basis during peak periods, but not on a mg/liter basis,  which  is  the
measurement of the standard.  In fact, the number of tank  trucks
loaded during a day would not necessarily increase due  to  a faster
loading rate.
     The present interpretation of a "modification" would  penalize
industry for undertaking cost-saving expansions in terminal throughput
capacity without increasing total VOC emission rates.   It  is  believed
that this mandate is beyond the statutory authority of  EPA and  is an
impermissible attempt by EPA to apply the proposed standards  to additional
facilities  (IV-D-23, IV-D-24, IV-D-26, IV-D-31, IV-D-32,  IV-D-41).
     Response:  Section 60.14(e)(2) was purposely included in  the
General Provisions to exclude from consideration under  the modification
provisions  increases in emissions due to relatively small  changes.   If
a change increases production capacity and yet does not result  in a
"capital expenditure" as defined in the definitions in  the General
Provisions, the change would not be considered a modification.
2.4  ENVIRONMENTAL IMPACTS
2.4.1   Calculation of Emission Reductions
     Comment:  One commenter claimed that the analysis  of  emission
reductions  in nonattainment areas assumed that the benefits would
represent the difference between a 35 mg/liter level of control  and a
current uncontrolled emissions situation.  Actually, most  terminals in
those  areas are being or will be controlled  to 80 mg/liter or better
by  SIP regulations.  Thus,  presented estimates of VOC  reductions  are
inaccurate  (IV-D-13).
      Response:  The assumption used  in analyzing  potential emission
reductions  in areas which had not attained the National Ambient Air
Quality Standards  (NAAQS) for ozone  is stated on  pages  7-1 and  7-3 of
BID,  Volume I:
      "The category of terminals  in the nonattainment areas includes
      new, modified, and reconstructed terminals.  The  air pollution
      impact of the regulatory alternatives on these terminals is  the
      least  because they will  already  be controlled by  State  air pollution
      regulations  (see Section 3.3, Baseline  Emissions)."

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As pointed out in Section 3.3.3, Calculation of Baseline  Emission
Level, an assumption of  emissions  equivalent to 80  nig/liter  from  vapor
processors, plus  10 percent  leakage  (96 mg/liter) from  tank  trucks,
was used to calculate emission  reductions  in nonattainment areas.
2.4.2  Emission  Factors
     Several comments were  received  concerning the  emission  factors
used in the emissions calculations.
     Comment:  One commenter claimed  that  it  is  incorrect to use  the
emission factor  of 960 mg/liter for  all calculations  of emissions  in
attainment  areas.  Use of  this  emission factor  is  premised on the
incorrect assumption  that  all  deliveries  in attainment  areas are  to
facilities  with  vapor balance systems.   In most  instances the normal
service,  submerged fill  emission factor of 600 mg/liter,  is  the proper
factor for  calculating emissions in  attainment  areas.  Page  8-46  and
Tables 8-17,  8-25, and 8-26 of BID,  Volume I  were  cited as illustrations
of  inappropriate applications of these emission  factors.   This commenter
felt  that environmental  benefits of  the  proposed  standards,  including
the  estimated  quantity of  VOC controlled  during  loading,  are overstated
when  the  emission factor used is higher  than  warranted.  EPA's calculations
predict  a  greater benefit  to the environment by  the imposition of the
proposed  standards  than  would actually occur.   In  addition,  the cost-benefit
analysis  was  said to  be  inaccurate since  the environmental  benefit per
dollar  spent  is  also  overstated (IV-D-31).
      Another  commenter  felt that the current emission levels had  been
overstated.  Trucks  returning from service stations without  vapor
balance  carry vapors  which average only about 20 percent of  maximum
saturation  levels.   Since  there is no requirement for Stage  I vapor
controls,  the amount  of  vapor recoverable  is quite small, and the
correct  emission factor  for uncontrolled  trucks  is 336 mg/liter,
 instead  of  600 mg/liter.  This commenter also stated that there is  no
splash  fill loading  being  practiced, except for that accompanying top
 loading  with  vapor recovery.  The saturation is claimed  to  reach
 115 percent in summer,  instead of the 150  percent which  the  emission
factor  of 1,440 mg/liter represents  (IV-D-34).
      Another  commenter stated that the emission factor assumed for
bottom  loading in balance service should have been 850 mg/liter,

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instead of 960 mg/liter.  As a result, this commenter feels that  the
assumed emission levels are unrealistically high, distorting emission
inventories, efficiencies, and cost/benefit ratios (IV-D-23).  A
second commenter suggested that, based on performance test data,  the
correct factor for this type of service is 1,080 mg/liter (IV-D-3).
     Response:  These comments address two specific topics:   the
application of emission factors in attainment areas, and the accuracy
of the factors which were used to calculate emissions.
     EPA agrees that the emission factor which should have been applied
in the case of attainment areas is the factor for normal submerged
loading, 600 mg/liter, instead of the balance service factor of
960 mg/liter.  A lowering of this factor from 960 mg/liter to 600 mg/
liter reduces the quantities of recovered gasoline shown in the cited
tables.  However, the values which were given in Tables 8-17, 8-25,
and 8-26 are appropriate for areas where the full SIP level  of control
is in effect; i.e., all nonattainment areas and some attainment areas.
The primary impact of the reconsideration of this emission factor is
on the estimated control costs for the model  plants in attainment
areas, because reducing the quantity of recovered gasoline reduces  the
recovery cost credits in the calculation of net annualized costs.   The
total volume of gasoline recovered was overstated by 60 percent;
however, in re-evaluating the wholesale unit cost of the recovered
gasoline, it was determined that the cost was understated by 65 percent.
The net result was a slight increase in the cost credit for recovered
product.  These revised cost impacts are discussed in Section B.2.1 of
Appendix B.  The calculated emission reductions under the regulatory
alternatives presented in Tables 7-1 and 7-2 of BID, Volume I are also
affected by the reconsidered emission factor.  Estimated nationwide
emission reductions under Alternative IV have decreased by 9.4 percent
from baseline levels, from a 6,620 Mg/yr reduction to a 6,000 Mg/yr
reduction in the fifth year.  Tables 2-2 and 2-3 in this document
present the revised emission reduction figures for the regulatory
alternatives.  Energy impacts are also affected by this change, as
well as by the revised control system electrical consumption data.
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                      Table 2-2.
VOC EMISSION REDUCTIONS AT MODEL PLANTS UNDER THE
   REGULATORY ALTERNATIVES (Mg/yr)

Model Plant
(liters/day)
SIP-Controlled Area
380,000
950,000
1,900,000
3,800,000
Mo SIP Control -
Submerged Fill
380,000
950,000
1,900,000
3,800,000
No SIP Control-
Splash Fill
380,000
950,000
1,900,000
3,800,000
Basel ine
Emissions
23
57
114
227
78
194
388
775
186
465
930
1,860
Alternative II
Emissions
23
57
114
227
18
45
90
180

45
90
180
VOC
Reduction
0
0
0
0
60
149
298
595
168
420
840
1,680
Alternat
ive III
VOC
Emissions Reduction
17
42
85
169
28
69
139
278
28
69
139
278
6
15
29
58
50
125
249
497
158
396
791
1,582
Alternative IV
Emissions
17
42
85
169
12
31
61
123
12
31
61
123
voc a
Reduction
6
15
29
58
66
163
327
652
174
434
869
1,737
i
CO
       VOC  Reduction = Emissions  reduction  from  baseline  emissions.

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                                 Table  2-3.   NATIONWIDE AIR QUALITY  IMPACTS  OF  REGULATORY
                                            ALTERNATIVES ON  BULK TERMINAL  INDUSTRY
                                                                                     VOC Emissions,  Mg/Yr
                                                   	)J)86 Alternatives	1_991      __ 	

                              1980      Baseline                               Promulgated3                             Promulgated3
                            Emissions    Emissions       II      111       IV      Standard     II        111       IV      Standard
    Total  emissions
    from bulk
    gasoline terminals        341,900     140,000     134,900   135,200   134,000   134,300     129,800   130,400   128,000   128,600
rv>
^  Emission reductions
en  from baseline
    emissions                                          5,100     4,800    6,000     5,700      10,200    9,600    12,000    11,400

    Percent reduction
    from baseline
    emissions                                             3.6       3.4       4.3      4.1         7.3       6.9       8.6        0.1

    Percent Reduction
    for new, modified,
    and reconstructed
    terminals                                            62        58       73        68          62       58        73        68
     3Promulgated standard is a combination of Alternatives 11 (for existing vapor processing systems) and  IV  (for new vapor processing systems)

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The estimated nationwide net energy savings  in the fifth year  has  been
reduced from 9 million to 7 million liters  (56,600 to  47,200 barrels)
of gasoline equivalent.
     All of the emission factors used  to  estimate current  and  future
emission levels were those contained  in AP-42, Compilation of  Air  Pol-
lutant Emission Factors  (II-A-9).  This document  reports the most
current available data which has been  considered  by  the Agency in
establishing emission factors  for  use  in  estimating  emissions.  Data
from the EPA bulk terminal tests have  been  analyzed  to allow a com-
parison with the AP-42 emission  factors.   In 118  loadings  of tank
trucks  in  balance service, and 123 loadings in normal  service, the
current emission factors of  960  mg/liter  and 600  mg/liter, respectively,
were corroborated  (IV-J-17).
     Contacts with  State agencies  and  industry have  indicated  that a
small  amount of splash  loading of  gasoline  is still  practiced  in some
attainment areas, but  it  is  generally confined  to the smaller  oil  com-
panies  (II-E-68,  II-E-69,  II-E-126,  II-E-127).   The  estimate  of 10 percent
splash  loading  in  areas  with no bulk  terminal vapor  recovery  regulations
is  considered  reasonable.  The emission  factor  of 1,440 mg/liter for
splash  loading  is given  in AP-42.   Insufficient  data from  terminal
tests  are  currently available  to determine  whether a revision  should
be  considered  for  the  splash loading  emission factor.  However, the
150 percent saturation  factor for top splash loading is based  on tests
of  38  tank loadings performed  at various  times  of the year in  several
geographical  locations  (IV-J-15).   The difference between the satura-
tion factor used  to derive the AP-42 emission factor and  the  saturation
factor claimed  by  the  commenter may result from liquid droplet or mist
carryover  in these  test runs.
     The  fact  that  two  comnienters  suggested changes, one  upward and
one downward,  to  the emission  factor for balance service  loading
 indicates  that  there may be  considerable variation in the vapor
concentrations  emitted  during  this type of loading.   In EPA tests,
emissions  from  118  individual  tank trucks  in this service ranged from
37  mg/liter to  4,400 mg/liter, averaging 930 mg/liter.  Of these
loadings,  50 percent were  less than 850 mg/liter and 27 percent were
more than  1,080 mg/liter.   Many of the trucks in these terminal tests

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had serious vapor leaks, which may have caused some emissions  to  be
lower than expected.  Generally, the higher values were associated
with higher ambient temperatures.  Data supplied by the commenter
suggesting 1,080 mg/liter were for bulk drops to underground  tanks in
southern California, where tank temperatures averaged about 33 degrees
F  (IV-J-6, IV-E-11).  In light of this information, the current emission
factors in AP-42 are considered at this time to represent a reasonable
national average.
2.4.3  Calculated Emission Reductions
     Comment:  One commenter stated that the actual average performance
of the control systems in EPA tests was better than the level  assumed
for nonattainmerit area baseline emission calculations.  Because of
this, the calculated emission reduction is erroneous, with Alternative I
achieving emissions of about 85 percent of that projected for
Alternative II or IV (IV-D-1).
     Response:   It is not practical to determine precisely the average
emission level from all  of the vapor processors operating under a
particular regulatory emission limit.  For the purpose of calculating
potential emission reductions in a particular area, it is assumed that
the emission  limit represents the average actual emissions, since
vapor processors could emit up to this amount and still meet  applicable
standards.  For  this reason, the emission limit of the alternative is
used for calculating impacts.
2.4.4  Emission  Impact in Clean Areas
     Comment:  One commenter argued that controlling  terminals in the
States where  no  control  regulations are required would not appreciably
improve the already clean air which is present at the source  and
downstream, since these terminals are  located in remote, low-density
population areas.  The controls would  raise distribution costs:   first,
to pay for the installation and capital recovery of equipment  in  small
terminals, and second, to pay for the  higher downtime and maintenance
costs associated with maintaining equipment in areas  remote from  service
repair facilities (IV-D-34).
     Response:   Section 111 requires EPA to promulgate uniform new
source performance standards for subcategories of new sources, where-
ever located, within source categories that the Administrator  has
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determined are "significant contributors."   Under  Section  111,  these
standards must require  control  equivalent  to that  achievable  by the
best systems of emission  reduction  ("best  demonstrated  technology").
Congress  believed  that  this would  serve  to prevent new  pollution prob-
lems and  assure that  air  quality  is  enhanced over  the long term.
Technology-based standards  under  Section 111 thus  complement, rather
than conform to, the  air  quality-based  requirements of  other  sections
of  the  Clean Air Act.
     As discussed  in  Section  2.1.1,  EPA  has determined  that emissions
from the  petroleum transportation  and marketing industry contribute
significantly  to air  pollution  that may  reasonably be anticipated to
endanger  public health  or welfare.   Accordingly,  under  Section 111 the
Agency  is required to set nationally uniform minimum standards for all
industry  subcategories  within this category for which the Agency can
identify  best  demonstrated  technology,  including  bulk gasoline terminals.
      It should further be noted that emissions from a 950,000 liter/day
submerged loading  terminal  would  be reduced under the standard from
approximately  194  Mg/year to 31 Mg/year, or 84 percent, in an area
without SIP  control requirements.   In the Agency's view, foregoing
this  level  of  reduction would permit the type of new pollution problems
Congress  sought to prevent.
     The  promulgated  standards will increase costs to most of the
 affected  bulk  terminals,  as indicated by the revised cost analysis
 summarized in  Tables  B-l through B-3 of Appendix B.  The  larger  facilities
 should  be able to  realize a net cost savings due to the greater  product
 recovery when  using vapor recovery equipment.  While some terminals in
 "remote" areas may experience higher costs  than other terminals,  the
magnitude of this  cost difference is not likely to be great  enough to
 seriously affect  the ability of such terminals to comply with the
 standards.   For example,  if maintenance costs at a small  terminal
doubled,  the net  annualized cost of control would  increase by only
 about  11 percent   (Table B-l).  If the terminal formerly used top
 loading and was converted to bottom  loading as a  result of the  standards,
 this percentage increase would be reduced  to about 4 percent (Table B-2).
 The costs of control  to these example terminals would  remain reasonable.
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However, small, remote terminals would not be profitable even  in
pre-control circumstances unless maintenance and repair services  were
available at a reasonable cost.
     Section 2.5 and Appendix B discuss the updated costs as well  as
the economic impacts of the standards on small terminals.
2.4.5  Impact of Tank Truck Testing
     Comment:  One commenter thought that the effluent from the pre-test
cleaning of tank truck compartments would have "definite negative
environmental consequences" (IV-F-4, IV-F-6).
     Response:  This commenter felt that 175 gallons of effluent
composed of water, caustic-based cleaning compounds, and petroleum
residue would be created during the tank cleaning necessary before
each test for vapor tightness.  Method 27 does not require a thorough
soap-and-water cleaning as suggested by this commenter.  The tank
compartments must be emptied of all liquid, and then purged of all
volatile vapors by any safe, acceptable method (such as carrying  a
load of nonvolatile fuel or flushing with ambient air).  Only  in  an
unusual case, where a noncompatible fuel or chemical was carried  in  a
tank truck which was being converted to gasoline service at the time
of the testing, would such liquid cleaning be necessary.  Since these
cases are  infrequent and since the volume of effluent  is small, the
impact of  any such instances would be negligible.
2.5  ECONOMIC  IMPACTS
2.5.1  Underestimation of  Industry Costs
     Comment:  One commenter stated that the  "reasonably accurate cost
estimate"  required to demonstrate that the proposed standards  are
achievable  at  reasonable costs had not been presented  because:   (a)  it
is not  reasonable to assume that control equipment designed to meet
35 my/liter  could be purchased and operated for  the same costs  as for
current equipment meeting  80 mg/liter, and  (b) the number of affected
facilities  expected  in  10 years had been seriously underestimated,
primarily  because of facilities affected due  to  SIP conversion  (IV-D-26).
     Response:  Many control  systems being  installed under SIP  programs
are  capable  of controlling emissions below the NSPS limit of 35 mg/liter.
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Test data have shown that, in their normal operating mode,  carbon
adsorption (CA) arid thermal oxidation  (TO) units  can consistently
operate well below the 35 mg/liter limit  (II-A-4,  II-A-17,  II-A-23,
II-A-24, II-A-26, II-A-37, II-A-50, IV-D-54,  IV-D-55,  IV-D-56,  IV-D-57).
Therefore, for CA and TO units  there  are  no  additional  costs  involved
in meeting 35 mg/liter versus meeting  80  mg/liter.   Current carbon
systems are designed for levels below  35  mg/liter (IV-D-36, IV-E-20).
     Test results on current  refrigeration  (REF)  systems  show that
only some of  the units meet the 35 mg/liter  limit.   However,  it should
be remembered that most of these systems  were installed to  meet an
80 mg/liter standard.  Conversations  with the major manufacturer of
these  systems  indicate that adjustments  to  operating parameters can be
made which will  increase  the  control  efficiency (IV-E-32).   Such
adjustments would  increase electrical  costs  (claims by the  manufacturer
of  as  much  as  50 percent  increase).   The assumption that costs would
not  increase  in  the  case  of CA  and  TO units  in order to meet  35 mg/liter
is  still  considered  valid.  However,  since it appears  that  the REF
technology  could  be  used  to meet the  standard, at somewhat  increased
capital  and  operating  cost levels from the average current  system'(as
much  as 25  percent  increase  in  capital cost and 50 percent  increase in
energy costs  (see  Section 2.5.3)),  and since a large segment of industry
 is  using  this form of  control  (approximately 25 percent of  existing
units  are refrigeration  units), the potential cost impact  to industry
 if  current  use patterns  are  maintained has been examined.  Section 2.5.3
discusses the additional  costs  associated with REF units designed to
meet the 35 mg/liter limit.   Section B.2.1 of Appendix B examines the
 updated industry costs.
      As pointed  out in Section  2.3.1, §60.500(c) changes the applicability
date for a  terminal  which commenced a loading rack component replacement
 program prior to the promulgation date for the purpose of  meeting
 State or local  regulations.   This change in applicability  dates excludes
 the vast majority  of these terminals from the standards.   The  estimate
 of  55 facilities affected in  the first five years, based on  industry
 response to Section 114 letters, is still considered appropriate.
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     Comment:  One commenter stated that EPA's estimate of  both  the
number of systems requiring replacement by the industry and the  cost
of replacement were too low.  His estimate was a $28 million  nationwide
capital cost over a 5-year period, as opposed to the $25.3 million
estimated by EPA (IV-D-30).
     Response:  The nationwide cost estimates presented in Table  8-40
of BID, Volume I represented the best estimates possible using  infor-
mation from all segments of the bulk terminal industry.  The  principal
unknowns in calculating total  costs included factors such as  decisions
made by individual owners and operators as affected by a highly  volatile
market situation.  EPA recognizes that only si ightly. different  assump-
tions  could lead to a nationwide capital cost estimate of $28 million,
or 10  percent higher than previous estimates.
     Since  it is not the intent of the Agency to cover under
reconstruction provisions the facilities which are converted  in  order
to comply with SIP regulations, the estimate of 55 facilities affected
in five years is still believed to represent a reasonable approximation,
based  on Section 114 letter responses.  The current declining market
situation could serve to decrease this number because of fewer  terminal
expansions.  The updated industry costs have been used to recalculate
the  nationwide cost impact, with the costs of purchasing arid  operating
continuous  monitors now  included in these estimates, even though
monitors are not required by the standards at this time.  By  1986,
industry will spend about $12.2 million in capital investment,  and  the
net  annualized cost in the  fifth year will be $2.5 million.   The
capital and annualized costs have decreased since the original  evaluation
mainly because of  re-analysis of top-to-bottom loading conversion
costs  and because  the promulgated regulation no longer contains  a
requirement for  the upgrading,  replacement, or the addition of  add-on
controls for existing vapor processing  systems.   In the previous
analysis, the  costs for  the top-to-bottom loading conversions were
attributed  to  the  standards for  all  top loading terminals  in  the
nationwide  cost  determination.   However,  in  the revised evaluation,
the  cost of top-to-bottom  loading conversions not coupled with  vapor
control, which would  cause  the  facility to  become affected  through  the
reconstruction  provisions,  were  not  included  in  costs  associated with

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the standards.  These costs would be  incurred  by  the  terminal  owner
regardless of the standards since the  conversion  was  performed voluntarily.
Sections B.2.1 and B.2.2 of Appendix  B discuss the  revised  costs  and
the assumptions used in calculating nationwide impacts.

     Comment:  Another cominenter claimed  that  "the  economic analysis
for the 80 mg/liter standard  underestimated  the cost  by  25  percent;
thus the analysis for the  35  mg/liter standard may  incur comparable
error"  (IV-D-19).
     Response:  The economic  impacts  of Regulatory  Alternatives II,
III, and  IV were  analyzed  using  the most up-to-date information available
at  the  time the .analysis was  made.  Since proposal  of the standards,
costs have been updated so that  the  impact of  Alternative IV could be
reassessed.   In re-evaluating all  cases involved with Alternative IV,
it  was  found  that the cost per unit of emission reduction for the
addition  of  add-on  controls to existing vapor  processors or the replacement
of  existing  vapor processors  was unreasonable.  For this reason and
because it  is not considered  reasonable to require upgrading, add-on
controls, or  replacement  for  these vapor processors,  the final standards
have  been revised to  allow existing  vapor processors  to meet an 80 mg/liter
emission  limit instead  of  the 35 mg/liter limit.  The remainder of the
costs  associated  with  Alternative IV, upon re-evaluation were found to
be  reasonable.   No  specific details  clarifying the assertions of the
cominenter were given  and  the  re-evaluation of the costs was felt to be
thorough  and accurate.   The revised costs are presented in Section B.2
of Appendix  B.
2.5.2  Economic Incentive to Control   Emissions
      Comment:  One  commenter felt that the proposal  is unnecessary
since,  due  to rising  gasoline costs  and the trend toward larger termi-
nals,  the industry  will  have  an ever-increasing financial  incentive to
 install vapor recovery  equipment (IV-D-26).  Another commenter felt
 that,  if  the statement  that the proposed standards would result in a
 net energy  savings  were correct, then  the economic incentive  alone
would be  sufficient for industry to respond without  the need  for
 regulatory  action (IV-D-12).
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     Response:   A review of the net annualized costs to various model
plants and to the industry as a whole, as summarized in Appendix  B  and
Section 1.2.3,  shows that bulk terminals would in most instances  incur
some positive net costs.  Only among the larger terminals would net
savings be expected, and even among these facilities, the cost of
planning, designing, purchasing, and installing vapor recovery equip-
ment, might be sufficient to outweigh economic incentives and convince
owners not to expend such effort.  Also, while there may be cost
savings, the incentive may not be so great as to warrant controlling
emissons since greater  investment opportunities exist elsewhere.   In
promulgating this NSPS, the Administrator is establishing minimum
nationally uniform standards reflecting the best demonstrated tech-
nology, as required by  Section 111.  If the trend toward large terminals
results in an ever-increasing financial incentive to install vapor
recovery equipment, the cost and economic impacts attributable to the
standards will  be reduced.

     Comment:  One commenter pointed out that even the small cost per
gallon  to comply with the standards would be sufficient to discourage
a terminal owner or operator from performing modifications at a terminal,
The ultimate result of  discouraging investment in present terminals
could  be  the closing of some terminals with the net  result of fewer
terminals, increasing truck movement of products, and increasing
overall pollution  (IV-D-12).
      Response:  The results of both the original and revised economic
analyses  showed that for the two smallest model plants the standards
could,  in the worst case, have a significant negative impact on
profitability in the unlikely absence  of  complete control cost pass-
through.  The original  analysis  on  existing facilities showed that
both  the  380,000 liter/day  and 950,000 liter/day terminals would
encounter ROI's of  less than 11  percent,  taken to be the minimum
acceptable level (Section 8.4.1.2.1 of BID, Volume  I).  The  revised
analysis  (Section  B.3  of this document)  indicates that only  the
380,000 liter/day  top-loaded facility  will experience a significant
decrease  in  profitability with  a post-control  ROI range of  7.7 to
8.0 percent.  The  950,000  liter/day terminal will still maintain  a
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marginal profitability  level with  a  post-control  ROI  range of 10.6 to
11.0 percent.  However,  the  preceding  impacts  are worst-case scenarios
and are very unlikely  to occur.   Since the price increase necessary to
offset  the control  costs is  less  than  0.5 percent, the most likely
scenario will  involve  an impact with most of the control  costs passed
through and very  little cost absorption.   Under this  scenario no
existing terminals  are expected  to close.  The industry profile did
forecast a trend  away  from new small bulk terminals to larger terminals;
however, this  is  a  result of ongoing technological advances and economies
of  scale, and  of  a  changing  market situation.   This trend is not
expected to  be accelerated by the implementation of the standards.
2.5.3   Vapor  Processor Costs
     Comment:   One  cominenter claimed that the EPA estimate of the unit
purchase cost  for a carbon adsorption  (CA) vapor recovery system is
low by  about  4 percent, while the installation cost is underestimated
by  40  percent (if the  facility has bottom loading) or by at  least
320 percent  (if the facility must convert from top to bottom loading).
Purchase  and  installation costs of the CA units were presented by this
cominenter  on  a per-facility basis (IV-D-37, IV-D-38,  IV-E-19).  Another
commenter  submitted cost data indicating typical vapor recovery and
bottom loading expenditures of $254,000  and $805,000 per terminal
 (2  racks),  respectively  (IV-E-19).
      Response:  Most carbon adsorption units  are  currently being
 produced  by two manufacturers.  The purchase  costs used  in the cost
 analysis  were received  from the one major manufacturer at  the time the
 analysis  was performed  (mid-1979).  Since proposal, estimated costs
 have been updated through contacts  with  both  manufacturers  (IV-E-20,
 IV-E-36),  and are presented in Section B.2.1  of  Appendix B.  Current
 average CA unit prices  are  lower  than the previously presented prices
 by 20, 16,  12, and 7 percent, respectively, for  Model  Plants 1,  2, 3,
 and 4.
      The average cost  of  installing a vapor processor  was  estimated  as
 85 percent of the initial purchase  price of the  unit,  based  on  14  actual
 installations.  Values  used to compute the  average installation  cost
 ranged from 37 percent  to 147 percent.   Since no trend in  this  percentage
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as a function of purchase cost or unit type was noted, a single value
representing the average was selected.  Consequently, some unit
installation costs will be higher and some lower than those presented
in the analysis.  As shown in Table 8-20 of BID, Volume  I, the cost
elements considered in this figure included such items as engineering
and approvals, pad, piping, electrical, condensate tank, and other
elements concerned directly with the processing system.  Loading  rack
conversion costs were presented as separate cost elements (BID, Volume  I,
Tables 3-32 through 8-34).  Data on 13 installations submitted by the
first commenter indicated average costs of $192,100 for  the vapor
processor, $220,400 for processor installation, and $142,000 for minor
loading rack modifications (half were already bottom loading and the
remainder were modified rather than rebuilt).  Processor installation
costs are seen to average about 115 percent of the purchase price of
the processor, which is consistent with the range of values considered
in deriving EPA's 85 percent figure.  The second commenter submitted
data showing that the typical installation cost for a refrigeration
unit at his terminals was $90,000, or 55 percent of the  $165,000
purchase price.  Again, this percentage falls within the range of
values considered previously by the Agency.
     The cost of loading rack conversions varies widely  throughout the
industry.  In converting racks from top to bottom loading, a terminal
may incur expenses for design and planning work, demolition, loading
rack equipment, delivery pumps, piping, electrical service, fire
protection, concrete drive and drainage, office and canopy structures,
and a host of other miscellaneous equipment and expenses.  The total
sum spent for such work  is largely dependent on the previous condition
of the terminal and the current requirements and preferences of the
terminal owner.  Recent contacts with construction contractors who
have experience with loading rack conversion work indicate that EPA's
previous estimate of $160,000 (BID, Volume I, page 8-53) is toward the
low end of the current cost range for such conversion work (IV-E-33,
IV-E-39).  To reflect these cost changes, the estimate for the conversion
cost for a loading rack  is increased to $200,000, and is incorporated
in Table B-2 of Appendix B.   In the absence of  a more detailed breakdown
of the commenter's data,  EPA must presume that  the higher cost figures

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reported by the commenter include the cost  of  several  aspects  of
conversion not attributable to these standards.

     Comment:  Two commenters stated that operating  (electrical)  costs
presented for some vapor  recovery systems are  in  error.   One  of  them
forecasted that refrigeration systems designed to meet the proposed
35 mg/liter  limit would require  25  percent  more capital  investment and
cost about 5U percent  more  for electric  power  than systems designed  to
meet 80 mg/liter  (IV-E-19,  IV-F-1,  IV-F-3).  The  other commenter
stated  that  instead  of the  refrigeration unit  consuming  twice as  much
power as a comparable  carbon  adsorption  unit,  as  presented in BID,
Volume  I,  the refrigeration unit actually requires 50 to 60 percent  of
the power  consumed by  carbon  adsorption.  This commenter also felt
that estimates  of  electrical  costs  should be based on field data, and
not only on  manufacturers'  claims  (IV-D-53,  IV-F-1).
     Response:  Operating costs  for all  control technologies discussed
 in  BID,  Volume  I  were  calculated using  electrical consumption data
 supplied  by  the system manufacturers.   The refrigeration  (REF) unit
 purchase  cost  and electrical  consumption figures collected in 1979
 applied to systems used  to achieve the SIP limit of 80 mg/liter.  The
 data have  subsequently been reassessed using more current costs.
     The  manufacturer  of  essentially all of the current REF units was
 contacted  to obtain  present purchase and operating figures which would
 be  reflected for  a system to meet the emission limit  of 35 mg/liter
 (IV-E-32,  IV-J-8).  Unit models were selected  for application to  the
 four model plants, based  on the parameter suggested by the manufacturer,
 peak hourly product loading.  For example, Model  Plant 2  is estimated
 to have a peak hourly loading of 290,000 liters  per hour  (76,500  gal/hr).
 The selected REF unit has a peak hourly capacity  of 380,000  liters/hr
 (100,000 gal/hr)  in the operating mode  which  limits emissions to
 40 mg/liter (considered equivalent to 35 mg/liter for costing purposes).
 The corresponding daily capacity of this unit  according to the manufacturer
 is  3,800,000 liters/day  (1,000,000 GPD), or 4  times the model plant's
 daily  throughput.  Units  for the other  model  plants were  specified
 with a similar amount of excess capacity, so  that cost estimates  would
 be conservative.   The price of  this unit is $138,150, and  it  operates

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at an average of 88.4 kilowatts of power.  Annual power costs  have
been calculated as before, assuming 12 hours per day and 340 days
per year of operation, and a utility cost of $0.06 per kilowatt-hour
($21,640 per year for this model plant).  The purchase price is  19  percent
lower than the previous price of $170,000 used in BID, Volume  I, and
the power cost is 6 percent higher than the previous figure  (Tables 8-19,
8-31, and 8-34 of BID, Volume I).  This manufacturer has indicated
that improvements to the technology are still being made, which  are
expected to increase efficiency and reduce costs (IV-E-3).
     Another reason stated by this manufacturer for reduced  prices  was
that units in the past had been greatly oversized with respect to
actual requirements (IV-F-1).  Further, the new generation of  units
being most widely marketed (and different from the units previously
costed) is characterized by lower capital costs (IV-E-32).  The  unit
purchase and electrical operating costs reported in BID, Volume  I were
not simply increased by 25 and 50 percent, respectively, as  suggested
by the first commenter in order to estimate current costs of the more
efficient units.  Because of the factors noted above, the previously
reported costs would not represent a reliable cost baseline.   Instead,
actual prices and power requirements provided by the manufacturer for
units specified to meet 40 mg/liter were used to evaluate the  impacts
of the standard (IV-J-8).  The updated costs are presented in  Section B.2.1
of Appendix B.  EPA considers the updated costs, presented in  Tables B-l
and B-2 for refrigeration systems designed to meet 35 mg/liter,  to  be
reasonable.
     In order to assess the cost impact of Regulatory Alternative II
(emission limit of 80 mg/liter), the purchase price and electrical
operating costs of REF units specified to achieve 80 mg/liter  were
examined using the manufacturer's current specifications (IV-J-8).
These specifications  indicate that while unit purchase cost  is higher
when a larger unit is specified, the electrical costs of achieving  a
limit near 35 mg/liter may actually be lower.  However, the  relationship
of these costs changes as different sized units are selected to  provide
various levels of reserve capacity.  Based on this analysis, the
figures claimed by the first commenter were assumed to constitute a
worst-case cost scenario  to  a  REF unit user.  The purchase costs of

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units meeting 80 mg/liter were taken directly  from  the  price  list,  but
electrical costs used in the assessment were calculated as  50 percent
higher than the costs for 40 mg/liter  systems.   This  assumption  introduces
a measure of conservatism into the cost analysis  of Alternative  II,
but does not have a major effect  on  the net  annualized  costs.
     Field data on power costs for REF units are  scarce because  most
users do not measure the individual  electrical  consumption  for the
units themselves.  One  terminal owner  whose  unit  was  tested at 97.5 percent
control efficiency (achieving 35  mg/liter) reported a consumption of
38,600 kW-hr per month  at his 875,000  GPD terminal  (IV-D-47).   The
equivalent annual cost  of $27,800 compares well  with  the Model  Plant 3
and 4 costs of  $21,600  and  $28,600,  respectively, presented in Appendix B.
The unit manufacturer estimated the  electrical  operating cost for
equipment achieving 35  mg/liter as $0.0000226  per liter of  gasoline
transferred  (IV-F-3).   Based on this figure, annual power costs  for
Model Plants 1,  2, 3, and 4 would be $2,900, $7,300,  $14,600, and
$29,200,  respectively.   While these  figures  compare with the Appendix  B
estimates for the larger terminals,  they  are significantly  lower for
the  small terminals.  Thus, the presented annualized  costs  for small
terminals selecting  REF units may be conservative,  and the  cost impact
may  be  overestimated.   Current  estimates, however,  are considered to
represent sufficiently  accurate  averages  for the purpose of determining
cost  impacts.
      The  power  costs  for current  carbon  adsorption (CA) units were
calculated  in the same  manner  as  those for REF units, based on infor-
mation  supplied by  the  two  major  CA  unit  manufacturers (IV-D-51,
 IV-E-20,  IV-E-36).   The following table  shows  the comparative requirements
 for  the  two  types  of  systems:
                                               Average for CA Units
Model
1
2
3
4
Plant
Operating
(Hours per


REF Unit
78.2 (12)
88.4 (12)
88.4 (12)
117 (12)
from Two Manufacturers
23 (14)
32 (15)
37 (20)
63 (22)

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As mentioned earlier, the REF units have been specified with  considerable
reserve capacity, so that the power figures may be conservative  with
respect to the model plants.  Annual electrical costs for  REF units
are calculated to be 189, 119, 43, and 1 percent higher than  the
average costs for CA units, for Model  Plants 1, 2, 3, and  4,  respectively
(Tables B-l and B-2).  Section B.2.1 of Appendix B presents a summary
of these costs.
     Field data on CA system electrical costs also have not been
gathered by most users.  Two operators have recently reported monthly
costs of about $500-900 for smaller units and $1200 for larger units
(IV-E-40,  IV-E-42).  These costs correlate well with Appendix B  estimates
for the small terminals, but are somewhat lower than estimates for  the
larger terminals.

     Comment:  One commenter indicated that the average maintenance
expense for a carbon adsorption (CA) vapor recovery system was
underestimated by 50 percent.  He estimated that the average  annual
maintenance cost per terminal is at least $13,300, which does not
include daily preventative maintenance checks (IV-D-37, IV-E-19).
     Response:  As discussed on page 8-45 of BID, Volume I, the  amount
spent by terminals for maintenance  is dependent on many factors  (such
as whether union labor rates are in effect, maintenance performed by
in-house personnel versus outside contract service, etc.)-  Most of
the costs  submitted by the commenter applied to new units  in  operation
less than  one year, and were extrapolated to calculate annual costs.
Several operating problems, many of them resulting from extreme  winter
conditions, were described.  These  problems, some of which have  been
remedied,  undoubtedly contributed to the $13,300 annual average  calcu-
lated cost reported by the commenter.  These costs ranged  from 3.5  to
11.9 percent of  the equipment purchase cost, averaging 7.1 percent.
While many users have not  accumulated  maintenance cost estimates
because  their  units  are  quite new  (IV-E-41,  IV-E-42), one  operator
estimated  annual maintenance  of CA  systems to  be 3 percent of the
purchase price  (IV-E-40).   One CA unit manufacturer estimated this
cost as  about  2  percent  of  the purchase  price  of the equipment  (IV-D-36,
IV-D-51).  The estimate  presented  in BID,  Volume  I, 4 percent of

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purchase cost, is considered representative of CA units  nationwide,
based on the information considered prior to  proposal  of the  standards,
and on more recent industry estimates.
2.5.4  Costs Associated with Emission Limit
     Comment:  One commenter felt that  the achievability of the  35 mg/liter
limit has not been adequately demonstrated, taking  into  consideration
the cost of achieving the  limit  (IV-D-26).  Two  other commenters
expressed the opinion that the proposed 35 mg/liter standard  is  based
on a calculated  cost-effectiveness which does not  reflect true costs
and emission  reductions.   One pointed out  that EPA  estimated  a cost-
effectiveness of  $632 per  ton of VOC controlled  for an 80 mg/liter
limitation, whereas  State  experience under  SIPs  has shown a cost-
effectiveness of  $1,200 per  ton  of VOC  controlled  at an  80 mg/liter
standard.   The  incremental cost  of achieving  a 35  mg/liter standard
seems unreasonable  considering the small net  improvement in  air quality
(IV-D-25,  IV-D-31).
      Response:   The  cost-effectiveness  figures presented in  Table 8-40
of BID,  Volume  I  were  based  on the most current information  available
on actual  costs  of  vapor  control system installations as reported to
EPA.  The  figures apply to a nationwide distribution of regulatory
coverage,  and take  into  account  a mix  of terminal  sizes, processor
types,  and necessary terminal  conversion work.  The commenter did not
supply  a breakdown  of  costs  to  support  the $l,200/ton figure, but in a
followup conversation  (IV-E-52), it was learned that the figure was
based on 12 installations at his own company of CA systems at medium-size
terminals  (about 625,000  liters/day).   For each case, the cost to
 convert the loading racks from  top to bottom loading was included.
      Since the commenter  did not supply a detailed cost  breakdown, the
 cost elements contributing to the higher cost-effectiveness  cannot be
 identified.  However,  since all  of the commenter's terminals  required
major loading rack conversion work,  this is  considered  to be  the most
 likely  reason for the difference.  As shown  in Tables 8-29 and  8-32 of
 BID, Volume I,  the cost-effectiveness for an existing bottom  loading
Model Plant 2 terminal  installing a CA unit  is estimated to  be  $0.12/kg,
while the cost-effectiveness for a top  loading terminal  which must
 convert to bottom loading is about $0.52/kg.  Thus,  the  commenter's
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costs may be biased toward the high end of the cost range.   It  should
be remembered that since the figure of $632/ton represented  a national
average, individual cases will likely be higher or lower.
     The estimated costs of control for the standards have been
re-evaluated and are presented in Table B-4 of Appendix B.   Revised
cost-effectiveness figures are presented in Table B-3 of Appendix B.
The Agency believes that these figures demonstrate that the  costs
associated with the selected alternative are reasonable, and the
intent of the Clean Air Act is satisfied.   Discussions about the
environmental impacts of the standard are  contained in Section  2.4.
2.5.5  Other Terminal Costs
     Comment:  One commenter pointed out that EPA's estimate of "operating
labor" at $3,400 per year for each affected terminal, to ensure that
only vapor-tight gasoline tank trucks use  the facility, totally ignores
the operating practice of the gasoline bulk terminal  industry.  The
"real world" cost of operating labor alone to comply with the proposed
standards would be $37,889,180 per year by 1990 (assuming EPA's 110 affected
terminals), which far exceeds anything considered by EPA in  the rulemaking.
These costs not only would be certain to drive many independent terminals
out of business, but demonstrate that the  proposed standards are not
cost-effective  (IV-D-35).
     Response:  As pointed out on pages 8-43 and 8-45 of BID, Volume  I,
the operating labor cost considered in the tables reflected  the daily
unit inspections and the monthly system leak inspection.  Estimated to
average one hour per day, the annual cost  at $10 per hour would be
$3,400.  To reflect labor rate increases in the past two years, the
hourly rate has been increased to $15 per hour in the revised costs
presented in Section B.2.1 of Appendix B,  producing a per-terminal
cost of $5,100  per year.  The cost to 110 terminals over 10  years
would be about  $0.56 million.
     The commenter presumed that at least two extra personnel,  to
check the vapor tightness documentation of tank trucks as they  enter
the  terminal, and  to check hose connections, would be required  at each
affected terminal.  These extra personnel  are not in fact required
under the regulation, and will not be needed to carry out the provisions
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of the regulation.  Section 2.9.1 discusses  the  question  of additional
personnel and tank truck vapor  tightness.

     Comment:  One commenter  stated  that  vapor processor  energy consumption
calculations  introduced  a major error  into  BID,  Volume I.  The energy
consumed at the generating  station  should have been used  in the calculations
to avoid an overstatement of  net energy recovery.   Overall  energy
consumption was underestimated  by  a factor  of 10 (IV-D-23).
      Response:  The net  energy  consumption  of a model  plant is calculated
by subtracting energy  equivalent of the amount of recovered product
from  the energy required by the plant  to control emissions  to the
level  of the  standard.  The national energy impact on the industry
represents  the total  net consumption of all  terminals affected under
NSPS.   If  the energy  consumed at the generating station to produce the
electricity for  the  terminal  were used in the calculations, the amount
of  energy  saved which  would have been  spent to produce the gasoline at
the  refinery  would have to  be calculated to make comparisons on an
equivalent basis.  A comparison of costs and credits on such a basis
 is  considered neither logical nor practical by the Agency.

      Comment:  One commenter felt that there would be no economic
 benefit to an emission limit more stringent than 80 mg/liter because
 the  operating costs would become excessive  in relation to  the value of
 the  recovered product (IV-F-1).
      Response:   The emission limit  of 35 mg/liter was selected for new
 vapor processing systems to  reflect the  performance of the best  available
 control systems  as required  by  Section 111  of the Clean Air Act,  and
 not necessarily  to assure that  each facility  operator realizes the
 maximum return due to recovered product.  For some systems, the  operating
 cost of an 80 mg/liter system may  be  less than  the cost  to operate the
 more efficient systems achieving 35 mg/liter.   However,  the Agency's
 concern in evaluating alternative  emission  limits  is with  the  economic
 impact of each particular alternative  on the  industry and  on  individual
 plants.  The economic analysis  was  thoroughly reviewed and showed that
 attainment of the limit would  not  result in an  unreasonable cost or
 economic burden for those affected  facilities  installing new  vapor

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processing systems.  The review of costs and other factors  did  indicate
that the costs for replacing or adding additional control onto  an
existing control  device may be unreasonable.  For this  reason,  affected
facilities with existing control  devices are required to meet an
81) mg/liter limit  instead of a 35 mg/liter limit.  The  costs of complying
with the regulation have been updated, the economic  impact  has  been
re-examined, and these assessments are presented in Appendix B.
2.5.6  Tank Truck Costs
     Comment:  One commenter questioned the estimated costs for
retrofitting and testing tank trucks.  He estimated the retrofit cost
for a four-compartment trailer to be $8,800, instead of the $6,400
given in the preamble.  In addition, some costs associated with the
vapor tightness testing were not considered, including  cleaning,
purging, and reinspection and hydrostatic retesting of  tanks.   Loss  of
revenue due to the tank downtime caused by testing was  also cited  as a
missing cost element  (IV-F-4, IV-F-6).  A second commenter  questioned
EPA's cost estimate of $400 per compartment for tank truck  vapor
recovery conversions.  This commenter also felt that the proposed
regulations would  create undue economic hardship and paperwork  for
those bulk plants  which operate a small number of tank  trucks.
Particularly significant are tank truck conversion costs and the
revenue lost as a  result of the time required to take tank  trucks  out
of operation  (at least one day) for  testing (IV-D-11).
     Response:  Estimated costs were presented in BID,  Volume I, for
conversion of  top  loading trucks to  bottom loading,  addition of vapor
recovery provisions to new and older tank trucks, and for the annual
vapor tightness test  for delivery tanks.  Conversion to bottom  loading
was estimated  at $4,000 (page 8-63), vapor recovery  at  $1,600 for  new
trucks  (page 8-39) and $2,400 for the average older  truck (page 8-63),
and the vapor  tightness test at $150  (page 8-46).  These costs  have
been re-evaluated  through contacts with companies which perform tank
truck conversion work  (IV-E-22, IV-E-23, IV-E-24, IV-E-25,  IV-E-26).
     In the  cost re-evaluation in Appendix B, several costs have been
revised.   Conversion  shops have indicated that the cost for bottom
loading and  vapor  recovery  retrofitting ranges from  $6,400  to $8,000
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for pre-1967 tank trucks, from  $4,800  to  $7,200  for  1967-75  tank
trucks, and from  $4,400  to  $4,800  for  tank  trucks  manufactured after
1975.  Thus, the  previous estimate of  $6,400 still represents an
accurate  average  cost  for the overall  population.   However,  the estimates
of  $1,600 and  $2,400 for vapor recovery addition to new and  older
trucks, respectively,  have  been increased to $2,000 and $3,000, based
on  updated  cost  information.   The  cost for incorporating vapor recovery
provisions  is  revised  to $500 and  $750 per compartment for new and
older  tank  trucks,  respectively.   The  actual cost for the annual  vapor
tightness testing is still  estimated to be $150, but a cost impact for
loss of revenue  due to downtime has been included in the testing cost.
Data submitted by the  first commenter  indicate a downtime cost per day
of  $300  (IV-D-44);  this has been added to the cost of a test, which
would  take approximately one full  day  to perform  if a tank truck firm
had the test  performed by  an independent shop.  The added cost to
terminals,  which generally  have the facilities to perform their own
testing,  would be the  one-half day cost of $150.  The revised annual
testing costs  are thus $450 for tank truck firms  and $300 for bulk
terminals.
     The  smaller businesses will generally be most affected financially
by  this  regulation.  Although the original economic analysis  found
that both the 380,000  and 950,000 liter/day terminals would encounter
 ROI's  of  less than 11  percent, the final impact on these plants will
be  minimal since most  of the control costs can be passed through  in
 the form  of higher rates (see Section 2.5.6).  The economic  impacts
 are re-examined  in Section B.3 of Appendix B.
      The  regulation imposes  no direct paperwork requirements  on operators
 of bulk plants which receive gasoline  in their  own tank trucks from
 bulk terminals.   However, since a verification  of each  truck's vapor
 tightness must be  kept  on file at the  affected  terminal  (§60.505(a)),
 the tank  truck owner would have to  supply  test  documentation  for  these
 tank trucks annually.    This  paperwork would be minimal, especially  for
 operators of a small number  of tank trucks.

      Comment:  Another  commenter  stated  that, due to the  limited
 financial resources of  the independent tank truck owner,  such owners
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would be unable to comply with the vapor tightness  requirements  of the
regulation.  As a result, the small business tunk truck  owner  would be
refused access to an affected bulk terminal  (IV-D-18).
     Response:  The original economic analysis  in BID, Volume  I
(Section 8.4) used the debt service coverage analysis  to assess  whether
firms can meet the increased annual debt service costs under controls.
The debt service coverage ratio  is defined as a firm's cash flow
divided by  its current maturity  of long-term debt.   If this ratio is
2.0 or higher, debt service coverage is considered  to  be healthy, but
if it is less than 1.0 the annual debt service  costs cannot be met and
the firm will find its access to capital markets restricted.
     The original economic analysis suggested f» decrease in the  debt
service coverage ratio from the  range of 2.1 to 2.4 to the range of
1.7 to 2.2.  This decrease does  represent a  slight  increase  in lender
risk, but not enough to  affect the capital financing capability  of the
independent  tank trucking firms.   Therefore, access to  capital  markets
for financing air pollution control measures would  not be impaired by
the regulation.
2.5.7  Ability to Pass Through Control Costs
     Comment:  Two commenters stated that the costs of tank truck
control cannot be easily passed  through to the  consumer  by common
carriers  (IV-D-11, IV-F-4,  IV-F-6).  One of  them further stated  that
the proposed rule would  "tend to eliminate"  bulk plant operations.
These smaller operators  could not  remain competitive with major  oil
companies,  since control costs would have to be absorbed and  the
profit margin reduced  (IV-D-11).   One commenter stated that EPA  has
failed to  recognize that pipeline  companies  may be  legally unable to
pass through costs.  Most pipeline companies are common  carriers whose
rates are  regulated by the  Federal Energy  Regulatory Commission   (FERC).
To pass through  a  cost,  the company must  publish a  new tariff with
FERC.  A  pipeline  tariff may  be  denied, suspended,  or  modified,  and  it
may take years before  an increased tariff  rate  is  fully  in effect.
EPA must  consider  this tariff process  in  its economic  analysis of the
proposed  regulation  (IV-D-35).
      Response:   According  to  the Motor  Carriers Act of 1980,  Section  II,
49 U.S.C.  10708,  the  tank  truck  operators  are  allowed  to  increase
                                 2-55

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their rates by 10 percent per year without any  restrictions,  and
beyond the 10 percent per year level with the  provision  of  protest  by
customers and a followup investigation  by the  Interstate Commerce
Commission (IV-E-46).  The cost pass-through analysis  from  the  original
economic analysis in BID, Volume  I revealed  a  range  of necessary  rate
increases from 0.6 to 3.0 percent.   This range  of  values is substan-
tially less than the unrestricted  10 percent per year  limit;  therefore,
no regulatory-related rate problems  of  cost  pass-through are  forecasted
for  the  independent  tank truck  industry.
      Pipeline companies must  apply for  rate  increases  with  the  FERC.
According  to  the  FERC,  the average processing  time for an application
to  increase their rates  is 10 to  12  months.   However,  the pipeline
company  is allowed  to  increase  its rates,  subject  to refund,  5  months
after the  application  date.   Any  divergence  from the average processing
time is  usually  due  to  inaccurate presentation and documentation of
the  increased operating  costs (IV-E-45).   Based on these findings,  no
unfair economic  hardship would  be created  for the  pipeline industry.
      The original economic analysis  found  no significant impact resulting
from the proposed standards  even  when  complete control cost absorption
was  assumed,  and  no  plant  closures resulting from  the standards were
forecast.  The  industry profile did  forecast a trend away from  new
small bulk terminals to larger terminals;  however, this trend is not
expected to  be  accelerated  by the implementation of the regulation.
2.6  EMISSION CONTROL  TECHNOLOGY
2.6.1  State-of-the-Art Equipment
      Comment:   One  commenter stated that the EPA test data presented
 in  the BID do not represent  the present state-of-the-art in vapor
 recovery equipment  (IV-D-53,  IV-F-1).
      Response:   Most EPA-sponsored  testing of vapor control systems at
 bulk terminals  was  performed between November  1973 and  October 1978.
Test sites and  vapor processors were selected to represent the various
 control  technologies which were being widely used to  control loading
 rack VOC emissions.   At the beginning of the standards  development in
 November 1978,  the  data from these  tests constituted  most  of the
 available information on the performance of these systems.  Since

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these tests were performed, the state-of-the-art in the reliability
and collection efficiency of processors has advanced considerably.
Test results on newer systems are being evaluated as they  become
available, and all of the most recent information has been  considered
in drafting the final rule.  Data received after proposal  on  over
40 days of testing on CA, TO, and REF control systems indicate  that
all test results, except for one of the REF tests, are below  the
proposed limit of 35 nig/liter.  These results are summarized  in
Appendix A.
2.6.2  Test Data Presentation
     Comment:  This commenter also felt that the data presentation
should indicate the actual volume of air-vapor mixture which  passed
through the processing units during testing, as well as the system
backpressure contributing to vapor leakage (IV-D-53, IV-F-1).
     Response:  The EPA test data presentation in BID, Volume I,
(Tables 4-1 and C-l) indicated the approximate daily gasoline through-
put of each terminal test site, in order to provide an indication of
the capacity of each vapor processor.  The actual volume of air-vapor
mixture passing through the processor depends on the actual product
throughput during the test period, any vapor growth or shrinkage  in
the vapor return  line, and the amount of system leakage, primarily  at
the tank trucks.  The volume of vapor returned from loading per volume
of liquid  loaded  ((V/L)  ), the potential volume of vapor returned,  if
no leakage occurred, per volume of liquid loaded ((V/L)  ),  and  the
ratio of these parameters  (F factor) are presented in Table C-l,  and
indicate the effect of the abovementioned variables on the processed
volume, relative  to the  amount of product actually loaded  during  the
test.  This  information  is considered sufficiently detailed to  allow
evaluation of control system performance.
     During each  test (except Test No. 4) the average static  pressure
in the vapor return line near the tank truck was recorded  for each
loading.  Table  2-4 summarizes the backpressure data recorded in  the
EPA-sponsored emission tests and  presents data obtained  after proposal
from six tests performed  in  California.  The test numbers  for the
EPA-sponsored tests  in Table 2-4  correspond  to the test  numbers assigned
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TABLE 2-4.  VAPOR RETURN LINE PRESSURES DURING LOADING'

Test No. Type of
(Reference) Unit
Lowest
Pressure
(mm H20)
Highest
Pressure
(mm H20)
Mean
Value
(mm H20)
No. of
Readings
EPA-Sponsored Tests
1 (II-A-17)
2 (II-A-26)
3 (II-A-37)
4 (II-A-4)
5 (II-A-24)
6 (II-A-50)
7 (II-A-23)
8 (Il-A-5)
9 (II-A-10)
10 (II-A-14)
11 (II-A-40)
12 (II-A-41)
13 (II-A-43)
14 (H-A-6)
15 (II-A-11)
16 (II-A-28)
17 (II-A-29)
18 (II-A-42)
19 (II-A-38)
20 (II-A-27)
21 (II-A-39)
22 (II-A-25)
Tests Received
1 (IV-J-16)
2 (IV-J-2)
3 (IV-J-3)
4 (IV-J-4)
5 (IV-J-1)
6 (IV-J-5)
CA
CAC
CA
TOC
TO
TO
TOC
REF
REF
REF
REF
REF
REF
CRAC
CRAC
CRAC
CRAC
CRAC
CRAC
CRCC
CRCC
LOA
After
CA
CA
CA
REF
REF
TO
229
107
36
d
51
30
25
25
5
28
8
20
8
15
64
30
20
127
25
33
38
18
Proposal
254
305
127
51
97
51
386
218
107
d
165
330
178
241
64
307
76
193
165
419
140
132
127
470
236
343
371
279

533
610e
483
305
208
178
318
183
56
d
119
152
97
66
25
124
33
81
46
117
107
74
76
236
84
104
175
124

417
381
333
85
142
125
29
20
40
d
37
30
52
24
38
39
41
46
56
20
43
54
19
59
65
38
34
33

12
7
21
9
11
14
                       2-58

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  TABLE  2-4.   VAPOR  RETURN  LINE  PRESSURES  DURING LOADING3 (Concluded)
 Average gauge pressure at loading  rack during tank filling.

 CA - Carbon Adsorption
 TU - Thermal  Oxidation
 REF - Refrigeration
 CRA - Compression-Refrigeration-Absorption
 CRC - Compression-Refrigeration-Condensation
 LOA - Lean Oil Absorption
c
 Vapor holder in collection system.

 Pressures not measured in this test.
r\
 Highest value occurred during the  simultaneous loading of two
 compartments.
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in Tables 4-1 and C-l of BID, Volume I.  The mean value  of  pressure
for 21 of the 22 EPA-sponsored tests ranged from  25  to  318  mm  of water
(1.0 to 12.5 inches of water), averaging 112 mm of water (4.4  inches
of water) pressure.  The required collection system  maximum pressure
of 450 mm of water was exceeded during  only two tank truck  loadings  in
one test of a CRA type unit  (Test No.  18).  For the  California data,
the backpressure for the CA  systems was consistently higher than  that
of the REF and TO systems.   A total of  8 of the 40  truck loadings
tested exceeded  the 450 mm of water pressure value.   It was determined
that a majority  of these cases  took place  at a terminal  where  the  high
backpressure was due to faulty  check  valves  in the  vapor line  more so
than the type of control device  (IV-E-54).  This  emphasizes the fact
that since this  pressure  is  measured  close to  a  loading tank truck,
the backpressure includes  pressure  drop contributions from the number
of  arms  loading  at one  time  and  from  variables in the collection
system  itself  (such  as  length  and  diameter of  piping, elbows and
joints,  liquid  traps,  and  in-line  valving),  as well  as from the pro-
cessor.   Even though these  carbon  adsorption  backpressures were higher
than  for other  systems,  the  data  illustrated  that a properly designed
vapor  collection system  in  conjunction with  a  CA vapor processor can
operate  below  the  450  mm  of  water  limit.
      The emission  test  reports  (reference  numbers in Table 2-4) provide
more  detailed  information  on processed volumes and  system backpressure.
2.6.3   Adequate Demonstration  of  Technology
      Comment:   Several  commenters  remarked that the technology to
achieve the  standard has  not been  demonstrated, because only a few
short-term tests were  performed.   These commenters  stressed the necessity
 for data on  continuous performance, and on the ability of the systems
 to achieve the limit over the long term (IV-D-19, IV-D-20,  IV-D-26,
 IV-D-53, IV-E-19,  IV-F-1,  IV-F-3).
      Response:   Although vapor recovery at bulk terminals  has been
 used  in California for over 20 years,  the current generation of control
 units has been  in operation only since about  1977.   Most EPA testing
 was performed between  November 1973 and October  1978, and  thus represents
 the performance primarily of older systems (Section 2.6.1).  The  types
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of control  systems which represented the newest technologies  and  with
the consistently lowest TOC mass emission rates were selected as  the
best demonstrated technology, and the emission limit was based  on
these systems.
     Since the beginning of the standards development, the Agency has
sought the most recent results of tests performed by oil companies  and
State agencies, in order to collect the best possible data base.
Since all of the tested systems were installed in response to SIP
limitations at or near 80 mg/liter, oil company and system manufacturer
technical representatives were consulted in order to determine  the
assumed design conditions for the installed systems and the collection
potential of the various control technologies.  Emission test results
on several  CA units tested between 1979 and 1981 representing over
30 days of testing have been received from four State agencies  and  one
control system manufacturer (IV-D-49, IV-D-54, IV-D-55, IV-D-56,
IV-D-57, IV-J-2, IV-J-3).  Outlet TOC mass emissions measured in  these
tests ranged from 0.34 to 17.9 mg/liter, with 28 of the daily test
values below 10 mg/liter.  Three REF units owned by a single oil
company in two States were tested in 1980 and 1981 (IV-B-2, IV-D-55,
IV-J-4).  Daily average emissions in these tests were 21.9, 22.6, and
41.8 nig/liter.  These results support the observation that current  REF
units vary with respect to the 35 mg/liter limit, with some units
above and some units below the limit.  The apparent reason for  this is
that the control settings (compressor cut-in set point) can serve as a
thermostat to maintain a desired range of condenser temperatures,
which means that a range of emission levels is possible from a  parti-
cular unit (IV-E-32).  Recent tests by two State agencies on straight
TO and compression-oxidation hybrid systems yielded daily average
emissions of 0.20 and 0.22 mg/liter for the TO systems (IV-D-55)  and
0.22 mg/liter for the hybrid system (IV-J-5).  The hybrid system  is
capable of some degree of gasoline recovery; however, this has  not
been adequately quantified (see Section 2.6.9).
     Even though these recently obtained test reports did not follow
the EPA procedures exactly, the Agency feels that these data demonstrate
the ability of the new systems to meet 35 mg/liter and finds no basis
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for these commenters'  apprehension about  the  eventual  inability  of  the
best control systems to achieve  the  required  emission  limit.   As is
the case with all complex mechanical  systems,  adequate routine maintenance
and occasional component replacement are  necessary  if  design  performance
levels are  to be maintained.   However,  no specific  components or sub-
systems of  the best systems  have been identified  which cannot be
maintained  so that adequate  system performance is achieved  over  an
extended period.  Terminal operators and  control  system manufacturers
were contacted to determine  the  extent  and the cost involved  in
performing  normal maintenance  on th^ processing units  necessary  to
maintain the  units  in  proper operating  condition.  These costs have
been incorporated  into  the cost  and  economic impacts contained in
Chapter  8  of  BID,  Volume  I,  and  Appendix  B of this  document.
2.6.4  Test Data  Calculations
     Comment:  One  commenter stated  that  the presented test data have
gross  errors  so  large  that  a comparison of control  systems  is impossible.
Much of  the error in  the  "Processor  VOC Emissions" column of Table  4-1
of BID,  Volume  I,  was  attributed to  the "complicated" EPA calculation
method (IV-D-34).
      Response:   The data  presented by EPA are not in error.  EPA's
calculation procedures are  direct and not based on assumptions or
 indirect calculation  of a parameter.  There are differences between
EPA's  and  the commenter's results because the procedure used by the
cornmenter  includes assumptions which are not appropriate for this
application.
      For example, in  the  EPA procedure the outlet volume is measured
directly,  whereas the  commenter determines the volume  indirectly from
other  measured  parameters.   The differences in the results for  thermal
 oxidizers  occur because the commenter's equation assumes an air balance
which  does not  account for the dilution air that is necessary to the
 operation  of this control device.   Furthermore,  the commenter's emission
 values are obtained from a single calculation using average parameter
values for the  entire 4-  to 10-hour  test period.  EPA's results, on
 the other  hand,  are obtained using  specific values for each 5-  to
 20-minute  test  interval.
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2.6.5  Equipment Operation Under Variable Conditions
     Comment:  Two commenters stated that it has not been shown that
the proposed standards are achievable under sll the variable operating
conditions that may be present throughout the industry (IV-D-26,
IV-D-28).
     Response:  These commenters did not iuer.tify any specific variable
operating conditions which they felt may affect emission levels, nor
was any technical information included with the comments.  The typical
performance test on bulk terminal  control systems does nor measure
operating parameters and their possible effect on emissions, because
generally all that is required in these tests is the outlet mass
emissions or control efficiency average over several hours.  However,
EPA collected data in its test program and has identified the following
variables as having a possible effect on the mass emission level or
control efficiency of the control  technologies considered capable of
achieving the emission limit of the standard:
     1.  Gasoline composition.  Gasolines with different Reid vapor
pressures (RVP) are marketed in different seasons of the year, in
order to maintain approximately constant actual vapor pressure as mean
ambient temperatures change.  For example, in Southern California, the
mean average RVP is approximately 8.4 in summer, but is increased to
11.2 in winter  (II-D-149).  Under winter conditions, therefore, mass
emissions may be higher for some systems because of increased light
ends in the inlet vapors.  If CA and REF units are sized with sufficient
collection area to meet the emission limit in winter, emissions in
summer will then be well below the limit.  TO systems are often designed
to handle saturated streams stored in vapor holders, and should not be
affected by the variable RVP.  EPA tests and the tests in Appendix A
show that the emission limit was achieved at various times of year and
therefore under various gasoline compositions.
     2.  Inlet TOC concentration.  Both CA and REF systems have been
tested under a  range of inlet concentrations returned from tank trucks
(Appendix A and BID, Volume I, Appendix C), and theoretical estimations
and analyses have indicated that these systems will collect efficiently
throughout a range of concentrations (IV-A-2, IV-D-38).  Efficiencies,
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in fact, are likely to increase with increasing  inlet  concentration
(Section 2.6.8).  TO systems are easily designed to  handle  saturated
inlet streams.
     3.  Peak loading levels.  Most control  systems  are  designed  for
peak loading hours at a terminal, rather  than  daily  throughput,  because
of the fluctuation in loading activity  throughout  the  day.   Thus,  a
properly sized unit can handle peak periods,  and should  have improved
performance during the remainder of the day.   As pointed out in
Section D.3.1 of BID, Volume  I,  it  is  recommended  that testing  be
conducted during the 6-hour period  in  which  the  highest  throughput
normally occurs; at least  300,000 liters  of  gasoline must be loaded  in
order for the test to be valid.  Therefore,  the  test results considered
valid by the Agency reflect representative normal  operation at  a
terminal during periods of the highest input to  the  unit.
     The conclusion can be drawn that  the operational  variables  at a
terminal are merely design variables which affect  the  selection  and
sizing  of the vapor processor.   No  variables have  been identified
which  would  prevent the standard from  being  met  on a consistent  basis.
2.6.6   Additional  Test Data
     Comment:   Three  commenters  felt  that no change  in current  emission
limits  should be considered until  additional data  on system performance
have been obtained  (IV-D-53,  IV-E-19,  IV-F-1,  IV-F-3).
     Response:  The Agency has  carefully  considered  test results on
six  control  technologies  tested  between 1976 and 1981  at about  60 bulk
terminals.   These  results  are presented and  discussed  in Appendix C of
BID, Volume  I,  and Appendix A of this  document.   These data are considered
sufficient  to adequately  evaluate  the  performance  of currently  available
types  of control  systems.
2.6.7   Carbon Adsorption  (CA) Control  Technology
     Comment:   Two commenters felt  that the  CA system  might have
difficulty meeting even an 80 nig/liter standard  under the Stage I
situation of richer  vapor  mixtures  returned  to the unit  (IV-F-1,
IV-F-2,  IV-E-19).
     Response:  Theoretical  projections of the performance of both
carbon  adsorption  and  refrigeration systems  indicate that increasingly

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more concentrated inlet streams will be collected with increasing
efficiency (IV-A-2,  IV-D-38, IV-E-36).  Test data are insufficient  to
determine the exact relationship of these two parameters, but some  EPA
tests indicate that the CA type system is capable of high collection
efficiency and low outlet emissions under inlet concentrations higher
than the 35 percent, as propane, expected in Stage I areas.  In Test
No. 1 of BID, Volume I, daily average inlet concentrations of 60.4  and
48.8 percent as propane were accompanied by control efficiencies
exceeding 99 percent, and by outlet mass emissions of 8.5 and 3.9 mg/liter,
respectively.  In Test No. 3, concentrations of 45.0 and 40.1 percent
were controlled at over 98 percent efficiency, with outlet emissions
of 11.0 and 9.7 mg/liter, respectively.  Another test performed in
California, where Stage I controls and vapor-tight tank truck requirements
are in effect, indicated that the emissions from a CA system were less
than 12 mg/liter with an inlet concentration of over 40 percent (II-D-149).
These data indicate that the 35 mg/liter emission limit can be achieved
by properly operated CA units throughout the range of inlet concentrations
which may be encountered at terminals affected by these standards.
     Thus, no basis has been found which indicates the inability of
carbon adsorption to control the higher concentration vapor streams
expected in Stage I areas to the outlet emission rate required by the
standards.

     Comment:  One commenter felt that EPA should not have omitted
test data considered unrepresentative of CA system performance in its
evaluation of the system, because these data represented normal conditions.
The commenter believes these data indicate a rapid deterioration in
system efficiency for the carbon adsorption technology.  Further, the
CA technology is capable of only marginally achieving 80 mg/liter
consistently  (IV-D-34).  A second commenter agreed that adequate data
on the control efficiency deterioration of CA units after a period  of
operation have not been collected (IV-D-29).
     Response:  As discussed in Appendix C  (Sections C.3.1 and C.3.3)
of BID, Volume I, two test days were omitted from  the CA system tech-
nology evaluation because of abnormal system and terminal operations,
as explained  in  the  test  reports.

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     In Test No. 1, the system was quite new, having been installed
about 5 months before the test.  The bed switching timer had been set
to accommodate a low-volume lean stream  (primarily fuel oil loading).
During testing, a higher volume, rich stream was  processed by the
unit, due to increased gasoline business.  This  led  to  bed breakthrough
on the first test day, and resulting high emissions  of  92.6 mg/liter
(II-D-41).  Each time that loading started, the  carbon  unit switched
to the same carbon bed regardless of whether the  regeneration cycle
had been completed.  Since one carbon bed was repeatedly exposed  to
the inlet vapor stream without adequate  regeneration,  system performance
on the first test day is not  considered  to represent the capability  of
this technology to control emissions.  The timer  was adjusted on  the
morning of the  second test day, and emissions on  the second and third
test days were  very  low  (8.5  mg/liter and  3.5 mg/liter, respectively).
Emissions on the first two days of Test  No.  3,  performed at the same
terminal as Test No.  1,  were  also very  low  (11.0 mg/liter  and 9.7 mg/liter),
indicating the  ability of this system to maintain high collection
efficiency after 17  months.   The  schedule  at this terminal calls  for
str gered tank  truck loadings, with half-hour  intervals between  loadings,
and the CA unit had  been sized to handle the resulting vapor  loading
(ID,000 gallons in 15 minutes).   On the  third  test day, the design
capacity of the unit was intentionally  exceeded  by loading  two  trucks
simultaneously.  This produced the  expected  reduction  in collection
efficiency  and  increase  in  emissions  (63.4 mg/liter).   Thus,  the  third
test  day  is not considered  representative  of system performance under
normal  conditions  at this terminal,  and  the  data were  not  used  in
assessing the  performance capabilities  of  this  technology.
      Therefore, since the first  occurrence of  high emissions  was  due
to  a  system maladjustment and the second occurrence was due to
purposefully  exceeding  the  design requirements  in order to observe the
results,  these  test  results  do not  indicate  performance of the CA
technology  under representative  conditions and  should  not  be  included
when  evaluating the  capability of this  technology to meet a specified
emission  limit.
      Any  of the control  technologies  can be expected to undergo some
degree of deterioration  throughout  their operating  lives.   As discussed

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in Section 2.6.3, this deterioration in control efficiency  should  be
able to be controlled through regular adjustment, repair, and  replace-
ment of worn or broken components.  As long as the critical  operating
parameters of a system are maintained within the recommended limits,
control efficiency should be relatively consistent.   In the  case  of  CA
units, these parameters include bed vacuum and adsorption cycle time,
which depend on pumps, valves, and electrical components.   Both vacuum
and cycle time can be easily checked on a periodic basis to  spot  trouble
areas.
     The activated carbon itself has the potential to lose  some of its
working capacity through fouling or partial pulverization during  bed
repressurization.  However, EPA is not aware of any total carbon
replacements performed for these reasons in the five years  since  CA
units were first commercially installed at bulk terminals.   While  the
guarantee on the carbon from one unit manufacturer is 3 years  (II-D-84,
II-E-75), industry sources indicate that an assumption of a  10-year
lifetime is reasonable (II-E-94, II-E-99, IV-E-29).   For the purpose
of costing potential carbon replacements, the 10-year period assumed
in the original cost analysis (BID, Volume I) has been retained.
Existing units have shown the ability to maintain the necessary working
capacity over several years of operation.
     Data from recent performance tests on newer CA units indicate
that most units limit emissions initially to well below 35  mg/liter
(see Table A-l of Appendix A).  Considerable deterioration  would  have
to occur before the 35 mg/liter li.nit was exceeded.

     Comment:  Two commenters referred to the high level of collection
system backpressure with CA units, which can lead to  excessive vapor
leakage from the system  (IV-D-53, IV-F-1, IV-F-2, IV-F-4).
     Response:  As discussed  in Section 2.6.2, recent test  data did
indicate some higher backpressures with CA systems.   However,  the data
also  indicated that a properly designed collection system  in conjunction
with CA systems  could operate below the 450 mm of water  limit  specified
in the regulation.   It should be  emphasized  that  the  backpressure
depends upon the design  of the  complete system, which includes not
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only the vapor processor but also vapor piping, valving,  knockout  tanks,
and flame arresters.

     Comment:  Two commenters discussed the  phenomenon  of aspiration
in CA units.  One claimed it is possible  for TOC  vapors to bypass
control through aspiration of some vapors  into  the  product being
returned to the storage tank, and that this  may be  occurring  in some
systems.  He recommended installation of  an  in-line sight glass in
these systems to observe the returned product  (IV-F-4,  IV-D-53).   The
second commenter stated that such aspiration would  not  be possible,
saying that vapor transfer by a centrifugal  pump  would  constitute
"extraordinary ope'ration" (IV-D-36).
     Response:  The Agency recognizes the potential  for circumvention
of the standards by routing vapors around a  control  unit, but this
practice has not been  observed  in any EPA tests.   As discussed in
Appendix C  of BID,  Volume I, an air  balance  analysis in Test  No.  3 did
not reveal  any significant reduction  in  the  air stream  at the CA
processor exhaust when compared to the processor  inlet.  It is considered
highly unlikely that aspiration occurs,  due  to  the capabilities of the
centrifugal  pumps which return  liquid gasoline  from the separator  tank
back to  the storage tank.  These  pumps would not  operate properly  on  a
liquid stream containing an appreciable  percentage of vapor (IV-D-15,
IV-E-10).
     Although the installation  of  in-line sight glasses may help  to
determine whether aspiration  is occurring, EPA does not wish  to make
this a  requirement  of  the standard.   Based on  technical and engineering
considerations, it  is  highly  unlikely that the  aspiration described by
the commenter occurs,  and therefore,  EPA feels  that this would be  an
unnecessary requirement.  As  stated  in Section 60.12 of the General
Provisions,  EPA does not allow  circumvention of the standards by  any
means.

     Comment:  Three commenters referred  to  carbon bed  temperature
excursions  at several  CA unit installations  during the  summer of  1980.
Due to the  resulting extended shutdowns,  one commenter  felt that  doubt
had been cast on the ability  of currently designed systems to consis-
tently maintain high efficiency (IV-D-23, IV-D-53, IV-E-19, IV-F-1,
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IV-F-4).  Another commenter pointed out that through the  institution
of certain design and operational measures, the overheating  problem
had been solved, with no units having problems since the  original  few
incidents had occurred (IV-D-36).
     Response:  In conversations and correspondence with  two carbon
system manufacturers, a major supplier of activated carbon,  and oil
industry representatives,  the apparent reasons for the incidents of
carbon bed overheating were discussed (IV-D-36, IV-D-48,  IV-D-49,
IV-E-18, IV-E-19, IV-E-20, IV-E-29, IV-E-30, IV-E-40, IV-E-43).  Six
occurrences of carbon bed  overheating were brought to the attention of
EPA.  These discussions indicated that the overheating incidents were
primarily the result of improper flow distribution and improper startup
procedures resulting in the insufficient preloading of the virgin
carbon in some new, larger units.  Precautionary measures to prevent
overheating would include  (1) complete conditioning of the virgin
carbon to ensure that an adequate heel has been placed on the carbon
to minimize subsequent high adsorption heat releases, and (2) sizing
the unit to maintain proper vapor velocity and flow distribution
through the carbon beds (IV-D-49).
     In a report of a test program performed by one manufacturer
(IV-D-49), it was determined that the carbon bed temperature excursions
were due to oxidation reactions of some of the hydrocarbons  in the
gasoline vapors.  In these tests, bed temperatures of 750°F were
measured during a temperature excursion event.  It was determined,
however, that these reactions do not take place until the bed temperature
has increased to a certain level.  This threshold temperature where
oxidation reactions begin to occur depends upon the type  of  carbon in
the bed.  Two types of carbon are used by the carbon system  manu-
facturers, wood-based carbon and coal-based carbon.  Onset of reactions
in wood-based carbon occurs at bed temperatures around 250°F and in
coal-based carbon at around 450°F.  The report indicates  that the
conditions favoring temperature excursions include (1) large carbon
beds which inhibit heat dissipation,  (2) high ambient temperatures,
(3) poor vapor distribution and/or low vapor velocities through the
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beds, (4) high concentrations  of  hydrocarbon  vapor  in  the  inlet  air
stream, and  (5) long carbon  bed adsorption  periods  without proper
regeneration.
     One manufacturer who  uses wood-based  carbon  has  now  incorporated
cooling coils  in  the carbon  bed design  to  aid in  heat  dissipation
(IV-D-49,  IV-E-20).  The  cooling  coils  circulate  the  cool  gasoline
from storage which  is already  brought to  the  unit for  the  vapor  absorption
cycle.  Another manufacturer considered using cooling  coils but  could
not  get them to perform to his satisfaction (IV-E-30). This manufacturer
feels  the  problem can be  eliminated  by  specifying coal-based carbon
and  carefully  employing proper startup procedures for  presaturating
the  carbon beds  (IV-D-36,  IV-E-30).   Nevertheless,  bed cooling options,
using  a water-glycol  solution, are being  offered  on current units.
      Industry  representatives have addressed  the  carbon bed overheating
 issue  by  incorporating  emergency  shutdown measures and bed cooling
devices  on the new systems (IV-E-19).  It appears that these measures
 could  produce  cost increases of up to $20,000 for carbon  systems (up
 to 15  percent  of  unit cost).  Two other oil industry representatives
 indicated that on any new carbon  system ordered  (and possibly retrofit
 to existing systems), they will specify cooling  provisions and additional
 temperature sensors (IV-E-40, IV-E-43).
      Since only six temperature excursion occurrences have been  identified
 in the approximately 200 operating carbon systems, EPA does not  believe
 that this is a widespread problem.   EPA agrees with the manufacturers
 and with industry representatives that an effort should be made  to
 carefully follow the recommended startup and operational   procedures  to
 minimize the conditions which may promote temperature excursions.
 Since one manufacturer of CA  units now uses  cooling coils  in  all  new
 units, the cost of the cooling coils has already been incorporated
 into the new unit costs developed for  CA units in  Section  2.5.3  and
 Appendix B.

      Comment:  One commenter  stated  that there are still  operating
 problems to be worked out with the CA  systems  (IV-D-19).   Another
 comiiienter expressed concern that only  the CA control  technology  has
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shown the potential  to consistently achieve the 35 mg/liter standard,
and that this technology is still in the developmental stages  (IV-D-25).
     Response:  The first carbon adsorption system for bulk terminal
vapor recovery was installed in November of 1976, and today the market
is shared by two manufacturers with approximately 200 units in operation.
Most types of vapor processors can be considered to be under develop-
ment in the sense that continual design improvements are being made.
Other technologies have shown the ability or the potential to meet  the
proposed standard.  Test results on the TO system have consistently
been below the 35 mg/liter limit.  Several test results for REF systems
have been below or near the standard limit and have indicated the
potential for the system to meet the 35 mg/liter standard.
     The first commenter did not specify any particular operating
problems, but EPA is not at this time aware of any major operational
problems with carbon adsorption systems.  Previous difficulties which
have occurred with CA systems have involved vacuum valve actuators  and
vacuum pump glycol seals (IV-D-37, IV-E-43).  Currently, the terminal
industry and equipment manufacturers are working to solve these equipment
problems, and have made progress toward reducing the maintenance and
repair needed by system components (IV-E-53).

     Comment:  Five commenters indicated that the CA system tests were
performed on small units at small terminals, and do not represent even
average size terminals.  They felt that data on smaller systems may
not  indicate the performance of the large systems  (IV-D-19, IV-D-26,
IV-D-34, IV-D-53, IV-E-19, IV-F-1, IV-F-2,  IV-F-3).
     Response:  As described in Section C.3 of BID, Volume  I,  EPA Test
Nos. 1, 2, and 3 on CA systems were performed at two terminals having
daily gasoline throughputs of approximately 200,000 and 300,000 liters
(Model Plant 1).  The other CA system referred to  in Section C.I.3  of
BID, Volume I, was sized to process 950,000 liters per day  (Model
Plant 2), although the daily average throughput  is approximately
230,000 liters (II-D-149).  Daily average emissions in these four
tests were 2.7, 5.4,  1.8, 2.8,  3.9, 11.0, 9.7, and 12.0 mg/liter,
respectively.  More recent tests  have  been  performed  on  CA  units
(Section 2.6.3) at terminals  of  various sizes.   Table  A-l of  Appendix  A
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shows the results of these tests, including the volume of product
loaded during each test.  Emissions well below 35 mg/liter were measured
throughout the size range of  terminals which will be  affected  by  the
standards.
     These commenters  provided  no supporting rationale or test data
suggesting that  the Agency's  conclusions regarding  the capabilities of
the  carbon adsorption  control technology at larger  terminals  are  inac-
curate.   Nor  is  EPA aware of  process  reasons that CA  technology cannot
achieve  35 mg/liter at such  terminals.
2.6.8   Refrigeration  (REF)  Control  Technology
     Comment:   One  commenter  felt that  the  proposed 35 mg/liter limit
is  too  stringent for  most  control systems,  including  currently available
REF  systems.   While  REF systems can be  designed  to  meet  this  limit, it
may  not  be  economically practical  (IV-D-23).   Another commenter stated
that,  based  on experience  with  current  REF  units,  the ability of  such
units  to achieve a  35 mg/liter  limit may  depend  on  the  time of year or
time of day  at which  a unit is  tested (IV-D-17).   A third  commenter
stated  that  only one  of his four REF units  tested  in California had
demonstrated  emissions below 35 mg/liter  (IV-E-19).
      Response:  Some  types  of currently available  vapor processors,
most of which are designed  to achieve an  emission  limitation of at
 least  80 mg/liter,  may not be able  to meet  the 35  mg/liter emission
 limit.   The emission  limit of the proposed  standards was selected  to
 reflect the performance of the best control  systems, which test data
 showed to be the CA and TO technologies.   The most current refrigeration
 systems have generally been operated to meet the 80 mg/liter  limit and
 have achieved 35 mg/liter in only some instances,  with most units
 slightly above the 35 mg/liter limit.  These units can be specified
 and operated to meet 35 mg/liter, at increased capital and operating
 costs over most current units, according to a principal manufacturer
 of  REF units  (II-E-74, II-E-85, IV-D-53,  IV-E-3, IV-E-32, IV-F-1,
 IV-F-4).  A recently completed EPA-sponsored program used a computer
 model  to simulate a refrigeration vapor recovery system (IV-A-2).
 This computer model indicated  that the 35 mg/liter limit is achievable
 by  a refrigeration system cooling vapors to -100°F.  Some systems
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currently operating in the field indicate condenser temperatures  as
low as -120°F (IV-B-4), which should allow a vapor temperature of
-100°F to be achieved.  The costs to purchase and operate REF units
which will achieve the limit of the standard are affordable by the
terminals which will be affected by the standards.  Section 2.5.3
discusses the estimated costs associated with refrigeration units
installed to meet the 35 mg/liter emission limit.
     Current REF units may exhibit variable capabilities with respect
to the 35 mg/liter  limit, and the factors affecting system performance
can include seasonal variations  (weather and gasoline composition)  as
well as terminal loading schedules.  However, as pointed out above,
these systems in the field are sized and operated to comply with  an
80 mg/liter limit.  Recent tests on newer REF units indicate that an
increasing number of units are controlling emissions below 35 mg/liter
(IV-D-55, IV-E-38,  IV-J-4).  Thus, even though most current REF units
are not operated to achieve 35 mg/liter, the Agency does not consider
this technology invalidated for  application under this  regulation.
2.6.9  Thermal Oxidation  (TO) Control Technology
     Comment:  Three commenters  felt that the proposed  emission limit
encouraged the use  of TO units,  which do not recover any product, and
this implied endorsement  is inconsistent with the Nation's energy
conservation policy (IV-D-23, IV-D-25,  IV-D-26).  Another commenter
felt that only TO systems could  consistently meet a 35  mg/liter standard
(IV-D-34).
     Response:  Test data have indicated that CA and some REF systems
can also meet the 35 mg/liter limit, so the TO system is not the  only
system considered under  the standard.   Furthermore, the cost analysis
presented in Appendix B  indicates that  in most cases TO systems may
not be cost-competitive with CA  and  REF systems when the value  of
recovered product is considered  (see Section B.2.1).  In addition to
economic  considerations,  the trend  toward larger  terminals  (consolidation
as well as new construction) will tend  to limit  installations of  TO
systems,  since product  recovery  cost credits make  CA and REF systems
more attractive at  larger terminals  (Tables  B-l  and  B-2).
     An  alternative approach to  straight  thermal  oxidation  involves a
 "hybrid"  system composed of  a  compression-aftercooler  stage,  followed
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by a burner section.  These systems achieve the high control efficiency
of the thermal oxidation technique (99+ percent) while recovering some
of the vapors displaced during loading (II-B-59, IV-J-5).  The actual
pr^di-ct recovery efficiency of these systems has not been evaluated.
2.6.10  General Control Technology
     Comment:  One commenter  believed that most types of control units
could achieve an 80 mg/liter  limit, although some marginally.  The
commenter felt there would be problems with attempting to meet 80 mg/liter
in areas without Stage  I controls  (IV-D^34).
     Response:  Much of the EPA  testing of vapor processors  performed
to date has  been in areas without  Stage I controls, with most processors
meeting the  80 mg/liter limit contained in SIP's.  The best  systems
have the ability to achieve 35 mg/liter under  various levels of  inlet
VOC concentration, from nonStage I levels  (about 15 percent  by volume)
to Stage I levels  (about 35 percent by volume)  (see Sections 2.6.5 and
2.6.7).

     Comment:   Several  commenters  objected to  the  requirement in
proposed §60.502(b), for a system  design which  would  prevent vapor
flow from one rack to  another.   These  commenters interpreted this
requirement  as  necessitating  the installation  of check valves in the
vapor  collection  system.   Reasons  for  opposition included:   (a)  the
requirement  constitutes an equipment standard,  contrary  to  Section  111,
(b) malfunctioning  valves  can cause  excessive  backpressure,  leading  to
leakage, (c)  all  tank  trucks  should  be  vapor-tight,  so the  requirement
is  unnecessary,  and  (d) check valves are  ineffective  in  low pressure
drop vapor applications  (IV-D-23,  IV-D-25,  IV-D-26,  IV-E-19).
     Response:   Section 60,502(d)  does  not  specify the use  of check
valves  in the collection  system, to  avoid  imposing a  particular  equipment
standard.  Rather,  §60.502(d) requires  that  the system be designed  in
any manner adequate  to prevent  TOC vapors  collected  at one  loading
rack from passing  to  another  loading rack.   The requirement was  included
in  the  standard  because of past  observations  of excessive vapor  leakage
from tank trucks  which were connected  to  the  collection  system,  but
not loading  product.   This potential crossover of  flow between  racks
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is prevented in current systems observed during visits by EPA, generally
through the use of check valves or similar devices  (II-B-54,  II-B-55,
II-B-56,  II-B-57,  II-B-58,  II-B-59, II-B-61, IV-B-6).  In some cases
all  tank  trucks are required to hook up to the terminal's vapor collection
system, and since  all  tank  trucks loading at a terminal nay not be
vapor-tight (such  as dedicated diesel  transports),  tank truck vapor
tightness alone cannot be relied on for vapor containment in  the
collection system.  Also, losses due to vapors short-circuiting the
system by escaping through  open vapor recovery connectors at  idle
loading rack positions could be eliminated.
     Malfunctioning valves  can significantly increase backpressure at
the tank  truck.  However, in recent terminal visits, terminal managers
stated that the valves used in their vapor collection systems were not
high maintenance items and  did not malfunction often (IV-B-6).  Also,
since these valve  devices have been used successfully in many of the
terminals visited, EPA believes that they are effective in  loading
rack applications.

     Comment:  Two commenters questioned the need for the requirements
in §60.502(h) and  (i), which set limits on the gauge pressure in the
delivery tank and  on the opening pressure of the system P-V vents.
One recommended a  pressure limit of 7,000 pascals (700 mm of  water)
instead of  the proposed 4,500 pascals (450 mm of water), to correspond
to the design relieving pressure for tank trucks  (IV-D-36).   The other
felt that these two sections of  the regulation deal with engineering
details and should be  left to the design engineer working with performance
specifications (IV-D-12).
     Response:  The pressure limit of 4,500 pascals corresponds to  the
pressure  limit at which the tank trucks are tested  using Method 27.
Specifying  a pressure  of greater than 4,500 pascals would subject  the
tank to a pressure beyond the level at which  it has proven  to be
vapor-tight and could  possibly cause a  leak.  Department of Trans-
portation requirements  indicate  that the relief vents  are supposed  to
be full open at 7,000  pascals, but  in fact  the spring-loaded  valves
begin  to  open  at  a  lower pressure.  The 4,500 pascal  limit  is the
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maximum pressure level the tank relief vents have been found to sustain
prior to beginning to open (II-A-41) and, therefore, was selected as
the limit for testing tanks for pressure integrity.
     There are many engineering details that must be considered in
achieving this backpressure stipulation, such as pressure drop across
the processor, pipe diameter, length of pipe run, and other flow
restriction devices.  All the engineering details to meet the 4,500 pascal
limit are left to the system designers.

     Comment:  One commenter stated that, since a terminal's vapor
collection system may receive vapors from sources other than loading
racks,  §60.502(6) should  be revised to read:
     "Emissions  from  the  gasoline  loading racks shall not contribute
     more than 35 milligrams of VOC per liter of gasoline loaded  to
     the bulk gasoline terminal's  vapor collection  system"  (IV-D-12).

     Response:   The standards apply only to  loading operations at bulk
terminals.  Section 60.502(b) and  (c)  limit  emissions from  the vapor
collection  system  "due to the loading  of liquid product into gasoline
tank trucks."  This wording is specific to the contribution from
loading racks, and does  not include, for example, storage tank emissions
during  product delivery.  However,  the terminal operator  is free  to
route  emissions  from  other sources  if  he so  chooses.
2.7  SELECTION OF  EMISSION LIMIT
2.7.1   Stringency  of  Emission Limit
     Comment:  One commenter  stated that the proposed emission limit
of 35  mg/liter appears to be  overly stringent, since only carbon
adsorption  and thermal oxidation  type  processing units would be  likely
to meet the standard  (IV-D-3).  Another commenter felt that the  proposed
limit  is unnecessarily stringent,  and  it would be  "arbitrary and
capricious" to impose the limit.   The  commenter felt that millions  of
dollars would be wasted  due to the abandonment of RACT  (80  mg/liter)
controls already in place.  An 80  mg/liter  limit was recommended  for
the standards (IV-D-33).
     Response:   Standards of  performance, in the form of  numerical
emission limits, are  intended to  reflect the degree of emission

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limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction,
taking into consideration the cost of achieving such emission  reduction,
any nonair quality health and environmental impacts, and energy
requirements.
     As discussed in Sections 2.6.3 and 2.6.4, test data indicate  that
systems other than the CA and TO systems can meet the 35 nig/liter
limit.  Carbon adsorption vapor processors manufactured by both of the
major suppliers have demonstrated the capability to regularly  achieve
emission levels below 35 mg/liter.  Also, thermal oxidation units  have
shown the capability to achieve 35 mg/liter, although some TO  systems
may require a vapor holder to reliably achieve this limit.  Compression-
oxidation hybrid systems have been found to achieve the same high
control efficiencies as the straight TO systems.  In addition, test
data and the manufacturer's claims suggest that REF systems can be
designed and operated to meet 35 mg/liter.
     Based on a number of emission tests, EPA has identified carbon
adsorption and thermal oxidation as the best demonstrated technologies
for controlling vapors from gasoline loading racks.  Section 111
requires EPA to set numerical emission limits achievable through
application of the best demonstrated technology (considering the
statutory factors), even  if by doing so the Agency precludes the use
of less effective systems.  Owners are nonetheless free to use any
technology that will achieve the limit.
     The third response in Section 2.3.1 discusses new regulation
Section 60.502(c) which allows control systems already in place to
continue meeting an 80 mg/liter standard.  This will prevent the
abandonment  of current controls and will save the money referred  to  by
the second commenter.  However, the 35 mg/liter limit  is reasonable
and attainable for newly  constructed facilities, for facilities without
current controls which are voluntarily modified or reconstructed,  and
for facilities with refurbished vapor control systems.
2.7.2  Alternate Suggested Emission Limit
     Comment:  One commenter stated that mass emission rates  from  REF
and CRA units vary with  inlet  temperature,  humidity, and  gasoline
volatility.  Thus, while  refrigeration  type  systems would  probably

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meet the proposed 35 mg/liter  limit for most of  the year,  a  limit  of
55 mg/liter  is more realistic  and  is achievable  on a year-round  basis
(IV-D-17).
     Response:   No data  to  support the  recommended 55  mg/liter standard
were received  from the commenter.   EPA  agrees  that mass  emission rates
from many  types  of processors  may  vary  with  operating  and  environmental
conditions.  While CRA units  have  not shown  the  ability  to consistently
achieve  35 mg/liter under any  of  the  conditions  at which they were
tested,  REF units  appear likely  to achieve the limit  under widely
variable conditions  (see Section  2.6.5).   The  major manufacturer of
REF systems has  stated that they  can  be specified and  operated to
achieve  the 35 mg/liter  limit (Section  2.6.8).  Test  data show that
many of  the most current REF unit installations  are  controlling emissions
below  35 mg/liter (Section 2.6.8).
      Nonetheless,  test  data show that best demonstrated  technology,
 the basis for the standard of performance, consists  of the carbon
 adsorption and thermal  oxidation technologies, which  are currently
 achieving the limit under the varying conditions mentioned by the
 cominenter.
 2.7.3  Efficiency Equivalent of Mass  Standard
      Comment:   One commenter stated that an 80 mg/liter standard is
 nearly equivalent to a 95 percent efficiency standard, particularly in
 areas such as Southern California, where Stage  I controls are in
 effect.    Thus, the statement on page 3-22 of BID, Volume  I, that the
 80 nig/liter and 90 percent efficiency standards  can be considered
 essentially equivalent,   is not valid (IV-D-34).
      Response:  The efficiency which is equivalent to a particular
 mass emission rate depends on the  inlet mass  loading  to the vapor
 processor.  The inlet mass concentration  is a variable  quantity which
 depends on  such factors  as atmospheric conditions, the  type of  loading
 done at a terminal, and  whether vapor balancing  was performed prior to
 loading the tank truck.    In vapor balance (Stage I) service,  the
 Agency's  estimated inlet loading  of 960 mg/liter (II-A-9) would have
 to be controlled at (960-80)/960  = 91.7 percent  in order  for  an 80 mg/liter
 standard  to be met.  The commenter's assumed  control  efficiency of

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95 percent presumes an inlet loading of 80/(1-0.95)  =  1,600 mg/liter,
which is considerably higher than the values measured  in  tests.   Since
all control  processors were evaluated on their ability  to maintain
outlet mass emissions within certain limits, the  issue  of control
efficiency is not relevant to this particular standard.   The  Agency's
rationale for selecting various emission factors  is  discussed in  the
response to similar comments contained  in Section  2.4.2.
2.8  TEST METHODS AND MONITORING
     EPA has been investigating alternative ways  of  reducing  monitoring,
recordkeeping, and reporting burdens on bulk terminal  owners  and
operators.  The goal  is to reduce all recordkeeping  and reporting that
is not essential to ensuring the proper operation  and  maintenance of
the control system.   After reviewing the requirements  in  the  proposal,
EPA determined that monitoring and the  compilation of  monitoring  data
are essential for both the owner or operator and  EPA to ensure proper
operation and maintenance.  The owner or operator  of an affected
facility would need monitoring information compiled  in  a  usable form
to determine when adjustments to the control system  are needed to
ensure that it  is performing at its intended effectiveness  level.  EPA
is therefore requiring only the additional step  of filing the information
in an accessible location.  Because EPA judges that  monitoring and
recordkeeping are essential for proper  operation  and maintenance,
these requirements have not been changed since proposal.  It was judged,
however,  that reporting of terminal monitoring data  is not  essential
to EPA.   Therefore, the reporting requirements have  been  removed  since
proposal.   In addition, when States are delegated the  authority to
enforce  these standards,  they may prefer either  not  to have reporting
or to have  reporting  on a different schedule than EPA  proposed.  A
State,  however,  is free at any time to  impose  its own  reporting
requirements  in  conjunction with this regulation.
     At  this  time, no monitoring specifications  have been developed to
meet the requirements of  the proposed  §60.504.   To avoid confusion,
the  monitoring  requirements  of §60.504  have  been reserved and will  be
reproposed  along with performance  specifications at a later date in
the  Federal  Register.  Section 2.8.3  of this  document has been included
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to respond, as much as possible at this time, to the comments received
concerning the continuous monitoring section.
2.8.1  Details of Test Methods
     Comment:  One commenter felt that the details of test instrument
calibration should not be specified in the test methods.  A statement
requiring all instruments used  in the test to be appropriate for  the
intended use and calibrated according to applicable standards was
suggested  (IV-D-23).
     Response:  The calibration requirements of the test methods  are
the minimum required  to  assure  accurate and precise data.  As the data
from the tests will be used to  determine compliance of  the control
system, it is imperative that the test methods be completely definitive
and repeatable.  The  specific calibration and test procedures of  the
methods for this regulation satisfy this need.  As with all EPA methods,
alternative measurement  systems and calibration procedures may be used
upon prior approval from the Administrator.

     Comment:  Two  commenters addressed the calibration meters required
in Method  2A.  One  stated that  spirometers or wet test  meters of
sufficient size  to  calibrate large  turbine meters are not  readily
available  (IV-F-1).   The other  asked whether the calibration requirement
of a spirometer  or  liquid displacement meter is consistent with the
expected meter capacity  which will  be  required for the  tests, and what
alternate  references  may be considered approvable by the Administrator
(IV-D-39).
     Response:   Turbine  meters  used  in previous Agency  tests reported
in the  proposed  standards were  calibrated according  to  the procedures
specified  in  Method 2A.   Since  that  time, larger  volume control devices
have been  installed or are  in development that require  much  larger
volume  measurement  devices.  The  commenters  are correct that spirometers
or other calibration  meters of  this  capacity are  not readily available.
As an alternative,  the Agency has  revised Method  2A  to  include wind
tunnel  calibration  against  a standard  pi tot  as an acceptable procedure
for  large  volume gas  meters.
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     Comment:   One commenter recommended that turbine meters not be
specified in the test methods for the measurement of the exhaust
volume from chilled brine and cascade refrigeration systems.  Tests
have indicated discrepancies between measured and calculated volumes
due to icing problems and an increase in lubricating oil viscosity due
to very low stack exhaust temperatures (IV-D-17).  Another commenter
inquired why the applicability of Method 2A was limited to the temperature
range of 0 to 50 degrees Celsius, and asked what alternatives were
available if the temperature during testing were below 0 degrees (C)
(IV-D-39).
     Response:  The applicable temperature range of Method 2A is
specified to avoid the freezing and viscosity variability problems
mentioned by the first commenter.  If extremely low exhaust temperatures
are encountered, one acceptable alternative procedure is to extend the
stack or duct using duct material or hose so that the exhaust gas is
warmed by the ambient air to a more acceptable level.  Agency tests
have shown the turbine meter to be applicable for measuring the exhaust
of refrigeration systems, provided the proper precautions discussed
above are taken toward preventing significant freezing or change in
meter calibration.

     Comment:  One commenter felt that alternative methods to Method 2A
should be allowed for measuring volume at the exhaust vent, since
there are existing systems that are not readily adaptable to Method 2A
measurements without substantial rework (IV-D-33).
     Response:  A total volume measurement method, as specified in
Method 2A, is necessary for these sources because of the highly variable
flow rates and the long test periods.  The Agency is aware that some
control devices have been installed which have reverse flow in the
exhaust stack and/or large diameter stacks, both of which require
modifications to the measurement systems.  To date, adding adapters to
existing exhaust stacks has proved satisfactory in allowing the use of
total flow meters for these sources.  In particular, for a control
device with a larger diameter exhaust stack, the modification may
include use of a reducing flange or a manifold system with multiple
meters in parallel.  For a control device with reverse flow in the

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exhaust stack, pressure-vacuum adapter valves and bypass plumbing may
be used.  These temporary testing adapters are practical, do not
involve substantial rework, and have been used routinely in State
compliance testing programs.

     Comment:  One commenter questioned why the calibration gas for
test instruments was limited to propane or butane, and whether the
balance gas  (air,  synthetic air, or N2) made any difference in the
calibration  standards  (IV-D-39).
     Response:  Section 60.503(c)(2) specifies use of either propane
or butane as  calibration  gases as the carbon numbers for these gases
correspond to the  carbon  numbers found for most emission gases.
Additionally,  these calibration gases are readily available, and
National Bureau of Standards calibration gases for certification
purposes are  also  available.  The use of air or nitrogen as the balance
gas  should have no significant effect on the calibration values.

     Comment:  The same commenter suggested changing the definition  of
Calibration  Drift  in Section 2.5 of Method 25A to read:
     "The difference in the measurement system response  to  a mid-level
     value calibration gas  before and after a stated period of operation
     during  which  no unscheduled maintenance, repair or  adjustment
     took place"   (IV-D-39).
     Response:  This change has been made to Method 25A  to  allow  the
determination of drift in the same  range as the measurement.

     Comment: This commenter also  requested  the  reason  why the sample
probe  sample hole  size of 4 mm in diameter was specified  in Section  3.2
of Method 25A (IV-D-39).
     Response:  Tests  the Agency has conducted in the  laboratory  have
shown  that sample  hole diameters of 4 mm or smaller are  required  for
multihole rake-type probes  to assure equal flows  through  all  sample
holes.  This applies for  sample flow rates of about 1  liter per minute
or less, typically required for flame ionization  detectors.   Larger
sample  hole  sizes  may  be  required to deliver greater sample volumes.
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     Comment:  Another commenter claimed that the statement  in  Section  4
of Method 25A, that the cylinder gas pressure for organic species  is
limited by the critical  pressure of the organic material, is  incorrect.
Instead, the final  pressure depends on the material 's vapor  pressure
and its final concentration when pressurized.  The same commenter
stated that the utilization of stainless steel cylinders for  storage
of calibration gas  mixtures, as referred to in the same section, is
unnecessary, and increases the cost of such gases to the end  user
(IV-D-4).
     Response:  Revisions to Method 25A have been made to incorporate
both of these comments.

     Comment:  One  commenter recommeded that the effects of  nonisothermal
testing of tank trucks should be discussed in Section 4.3 of  Method 27,
instead of stating  that delivery tanks should be protected from direct
sunlight during testing.   The following wording was suggested:
     "Every effort  should be made to ensure that the test is  conducted
     under isothermal  conditions.  The tanks should be allowed to
     equilibrate in the test environment.  Tanks should be protected
     from extreme environmental variability, such as, direct  sunlight."
This commenter further stated that, if the tank leaks, the pressure
would never stabilize  after closing the shutoff valve (IV-D-39).
     Another commenter recommended that the specification requiring
tank truck vapor tightness testing be limited to a performance speci-
fication to permit  all acceptable methods.  Alternatively, in addition
to the specific gas pressure methods, the commenter suggested  that  EPA
approve and publish the submitted water test method as an alternate
acceptable method.   A detailed discussion and text of the water test
method were submitted  with this comment (IV-D-23).
     Response:  The first commenter is correct in stating that the
purpose of protecting  the tank from direct sunlight during testing is
to minimize the effects of changing temperature.  Method 27  has been
revised to reflect  this and to explain the importance of having stable
conditions inside the tank prior to and during testing.
     The commenter is further correct in that, if a large leak exists,
the initial test pressure (in this case, 18 inches of water)  cannot be
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maintained for more than an instant.  However, if a small, slow  leak
exists, the pressure does not decrease quickly.  Instead, the  pressure
nay vary around the 18-inch level due to unstable conditions  in  the
tank (as mentioned above), or due to lag time  in the response  of the
pressure measurement device.  Thus, the pressure inside  the  tank may
require readjustment prior to testing in order to have a  reliable
steady initial pressure.
     The "water test method" submitted by the  second commenter is
essentially equivalent to the procedure specified in Method  27.
Revisions  to  Method 27 have been made to incorporate this alternative.

     Comment:  .One commenter stated the concern that, due to a lag
time of several minutes  in the  response of measuring instruments, the
TOC concentrations recorded at  the  exhaust of  the vapor  processor
during testing could be  matched  to  the inappropriate volume  measurements
in the calculation of mass emissions (IV-F-1).
     Response:  A response time  determination  procedure  has  been added
to Methods 25A and 25B and the  regulation has  been  revised to direct
the tester to correlate  volume  and  concentration measurements accounting
for the response  time.

     Comment: This commenter also  asked whether the assumption in
Section 1.1 of Method 2B, that  the  amount of  auxiliary fuel  used in
gasoline  vapor incinerators is  negligible, is  consistent with test
data  (IV-D-39).
     Response:  The auxiliary fuel  for gasoline terminal  incinerators
is used only  to ignite the pilot burner; it is not  needed to sustain
combustion of the gasoline vapors.  At terminals tested  by EPA, the
amount of  auxiliary fuel  for the pilot is indeed negligible  when
compared  to the large volumes of vapors processed.   If there is a
question as to the validity of  this assumption at a particular terminal,
one can refer to  the terminal's  records to compare  the amount of
auxiliary  fuel used over several months relative to the  gasoline
throughput.
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2.8.2  Methods of Testing
     Comment:  One commenter stated that the proposed visual  inspection
of the loading racks and vapor control  system, means nothing  with
regard to vapor leaks (IV-D-12).
     Response:  The purpose of the requirement for a monthly  inspection
of the loading racks and vapor collection and processing systems is to
ensure that the benefits of the control  system are not lost due to
large liquid or vapor leaks.  While small vapor leaks may go  undetected,
larger leaks can generally be detected  through sight, sound,  or smell
during an inspection.  An inspection procedure involving the  use of a
combustible gas detector was considered  for this requirement, but
since the same results of finding and repairing large leaks could be
accomplished using a method of sight, sound, or smell, the instru-
mentation approach was not selected.  A  particular terminal operator
may decide to use improved methods to detect smaller leaks, and such
procedures are not discouraged by the Agency.
     The word "visual" in the inspection requirement in §60.502(j) of
the regulation was deleted to clarify that the operator may use sight,
hearing, or other means to detect large  leaks.

     Comment:  One commenter suggested  that, in order to determine
whether a vapor recovery system was operating as guaranteed,  EPA
should strive to set a test basis which  would evaluate each system in
terms of its particular design criteria.  The use of a vapor  generator
was recommended to produce design conditions for testing (IV-D-36).
     Response:  While a test basis that would evaluate a control
system in terms of its particular design or guaranteed conditions may
be required when the use of a specific control system is indicated, it
is not appropriate in the case of a numerical emission limit, which
may be met by whatever control system the owner or operator of an
affected facility selects.  Also, to implement the commenter's suggestion
would require detailed knowledge of each control system that  could be
used to meet the standard.  This would be impractical due to  the
variety of control systems now manufactured for controlling VOC emissions
from bulk gasoline terminals and the continuing changes and improvements

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being made by the air pollution control vendors.  Such a requirement
is also unnecessary since the test methods and procedures specified in
the regulation are adequate to be applied to any kind of control
system that could meet the standard.  Additionally, as required by
§60.8(c) of the General Provisions, compliance with the numerical
emission limit is determined by a performance test conducted during
representative performance at the affected facility.  The evaluation
of specific control systems in terms of their particular design conditions,
while not discouraged by the Agency, is left up to the individual
vendors and purchasers of the control systems.

     Comment:  The same commenter expressed support for the proposed
6-hour performance test period, as  long as the test period represents
peak loading conditions.  Since this commenter's carbon adsorption
control units are designed around a 4-hour peak loading profile,  it
was  felt that the 6-hour test performed during a period of peak loading
activity should be a valid indicator of system performance (IV-D-36).
     Response:  While the performance  test may or may not represent
peak loading conditions, the test is to be run under conditions specified
by the Administrator based on representative performance of the affected
facility  (40 CFR 60.8(c)).  Additionally, to ensure that adequate data
are  obtained to constitute a valid  performance test, a minimum  gasoline
throughput of 300,000  liters during the test is required in the regulation.
2.8.3  Continuous Monitoring
     Comment:  One commenter felt he saw  a contradiction in two statements
in the preamble to the proposed regulation.  One statement says that
extremely accurate measurements with monitors would not  be required  to
determine exact outlet emissions; the  other says that the average
concentration or parameter value measured during the performance  test
would become the limit for the quarterly  reports of excess emissions.
The  contradiction, according to the commenter,  lies in basing  excess
emissions reports on numbers which  are not precise  (IV-D-29,  IV-F-1).
     Response:  The records of the  continuous monitors,  kept  on file
at the terminal, should provide enforcement agencies with sufficient
means of ensuring that the control  devices are properly maintained  and
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operated on a continuous basis.
     The intent of monitoring is to identify control equipment whose
operation and/or maintenance may be preventing the standard from  being
achieved.  Records of monitoring results are not used to determine
compliance with the numerical emission limit.  According to 40 CFR 60.11(a),
compliance with the standards of performance is to be determined  only
by performance tests, unless otherwise specified in the standard.
Therefore, since the concentration or parameter value would not be
used for a determination of compliance with the numerical emission
limit, it is not important that the value be precise.  Such information,
however, can be used as an indicator of proper operation and maintenance
of the control system when compared with the value of the same parameter
obtained during the performance test.
     EPA believes that changes in TOC concentration or parameters from
those measured during a performance test are good indicators for  an
owner or operator to use to ensure good operation and maintenance and
for an enforcement agency to use to determine whether an owner or
operator is in violation of the §60.11(d) requirement to "maintain and
operate any affected facility including associated air pollution
control equipment in a manner consistent with good air pollution
control practice for minimizing emissions."  Periods of excursions or
reductions of the measured value (depending on the control device) as
determined by the continuous monitors may also indicate to an enforcement
agency the need to conduct a performance test to determine compliance
with the numerical emission limit.

     Comment:  Four commenters felt that reports of excess emissions
should consist of periods when the numerical emission limit was actually
indicated to have been exceeded.  Two of them felt that, instead  of
the average value measured during the performance test, the VOC (now
TOC) concentration necessary to cause the standard to be exceeded
should be reported (IV-D-3, IV-D-20).  Others agreed that such reports
should indicate violations of the standard, but opposed the application
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of continuous monitoring and excess emissions reports to bulk terminals
(IV-D-29, IV-D-32, IV-F-1).  The fourth commenter pointed out that due
to the expected degradation of units in service, most operators would
be faced with the burden of filing excess emissions reports even on
units which are operating within the standard (IV-D-26).
     Response:  As pointed out in the preamble to the proposed regulation,
there are presently no demonstrated continuous monitoring systems
commercially available which monitor vapor processor exhaust TOC
emissions at bulk terminals in the units of the standard (mg/liter).
If continuous monitors which reliably record emissions  in units of the
standard are developed, such monitors will likely be quite complex and
expensive.  EPA is investigating simple, low-cost continuous monitors
which record exhaust TOC concentration and processor operating parameters
(such as temperature recorders).  Thus, data recorded by the available
monitors do not permit a determination as to whether the numerical
standard has been exceeded.  Also, as discussed above,  continuous
monitoring records are not used to make determinations  of compliance
with the emission limit.

     Comment:  One commenter felt that a fixed outlet VOC concentration
level could be set as a limit for the continuous monitor in REF systems,
based on curves of vapor processor control efficiency under various
inlet concentrations (IV-F-4).
     Response:  Since a format  in terms of mass units (milligrams  of
TOC emitted per liter of gasoline loaded into tank  trucks) has been
selected, there is no single value of TOC concentration associated
with the numerical emission limit.  The mass emissions  are calculated
using both the TOC concentration and gas volume data collected during
a performance test.  Various types of vapor  processors, all operating
at the  level of the standard, may exhaust different TOC concentrations.
For example, carbon adsorption and thermal oxidation units operating
at 35 mg/liter may emit lower concentrations than  refrigeration units
meeting 35 mg/liter, because the introduction of outside air into  CA
and TO  systems increases the volumetric flow rate.  Thus, the mass
standard in mg/liter is composed of a range  of TOC  concentrations,
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depending on the flow rates through various processors.   If  a TOC
concentration limit based on inlet concentration were set for REF
systems, then the inlet concentration would have to be known in  order
to select the appropriate concentration limit.  However,  EPA testing
at bulk terminals indicates that the TOC concentration returned  from
tank trucks is highly variable among regions, among terminals, and
even among individual trucks in the same type of service  at  a particular
terminal.  Thus, it would be extremely difficult to assign a single
inlet concentration to a given REF unit in order to determine the
concentration limit for that processor.
     Beyond the question of TOC concentration alone, however, several
commenters seemed to have difficulty with the idea of using the  "average
value" of a measured parameter as the number of significance in  determining
"excess emissions."  EPA recognizes that any reported values in  excess
of the average value recorded during a performance test do not necessarily
indicate violations of the standard.  Several commenters  pointed out
that normal equipment degradation over time may lead to a natural
shift in the monitored value.  The plant owners and operators have the
option of repeating the performance test, thereby establishing a new
monitoring value, if they feel some change has occurred to the control
device and the numerical emission limit can still be met.

     Comment:  Several commenters questioned the advisability of
continuous monitoring, one of them suggesting the alternative of
frequent visual checks of operating parameters to determine  proper
system operation (IV-D-31).  Another felt that a "monitoring-by-people"
approach, supplemented by appropriate gauges and indicators, would
assure that performance parameters of a processing unit would be
observed and fine-tuned as necessary.  This commenter took the position
that no single instrument or group thereof is an appropriate mechanism
for the requisite management of a vapor processing system (IV-E-19).
Two other commenters felt that existing gauges supplied on some  vapor
processors should be considered for use as monitors of performance,
instead of add-on instruments (IV-E-19).  Also, the calculation  of
"average value" is extremely complex and beyond the capabilities of
regular terminal personnel (IV-D-26).  One commenter was  concerned
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about the availability of adequate monitors and about the criteria
used for monitor certification (IV-D-29), while a second commenter
said that the type of monitors referred to in the proposed regulation
have shown poor reliability in refinery applications in California
(IV-D-19).  Two commenters argued that personnel qualified to properly
maintain monitors are not available at bulk terminals.  The necessary
instrumentation would require constant calibration and maintenance,
and this would represent a significant manpower and cost burden,
without compensating benefit  (IV-D-25, IV-F-1).
     Response:  Discussions concerning the availability, reliability,
complexity, maintenance, and  cost of continuous monitoring systems  are
inappropriate at this time because monitoring specifications have not
been finalized.  EPA is  investigating several types of monitors  and
developing monitoring specifications that are appropriate for application
at  bulk gasoline terminals.   In selecting these specifications,  EPA
will consider the reliability and usefulness of these monitors as well
as  the cost and difficulty of maintaining them.  After the specifications
have been selected, they will be  proposed in a  separate action in the
Federal Register for public comment.  Section 60.504, Monitoring of
Operations, has been reserved at  this time, so  that monitoring requirements
and performance specifications can be added at  a later date.
     Continuous monitoring of the performance of bulk terminal vapor
processors is considered essential to help ensure  that the standard is
being achieved on a continuous basis.  Many of  the alternate methods
suggested by commenters  for accomplishing this  end have a great  deal
of  merit as supplemental measures.  Frequent visual checks are already
being performed at most  controlled terminals (many of them record
operating parameters on  daily logs), and this practice is encouraged.
However, such checks are generally performed only  once per day,  and
often at times when the  processor does not happen  to  be operating,
such as when tank trucks are  not  loading.  The  parameters recorded  may
not indicate system performance,  for example, during  peak  loading
periods, when its performance is  most critical.  Therefore, visual
checks should be considered an important, but supplemental, means of
tracking a system's operation.  The commenter suggesting a "monitoring-
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by-people" approach advocates a weekly checklist similar to the  one
described above,  and a subsequent comparison of parameter values with
the ranges suggested by the manufacturer (IV-E-12).  Again, such
periodic checks would be useful  in terns of proper maintenance of  the
system, but may be too limited to provide sufficient information about
the system's likely emission level.  Continuous monitoring instruments
cannot by themselves lead to the proper operation and management of  a
vapor processor.   However, data from several properly selected instruments
is believed to be the best means of monitoring processor performance
over a period of time.  More detailed information, such as that collected
on checklists, should be used by the terminal  in its maintenance
program.
     EPA acknowledges that exhaust TOC concentration is only one of
several parameters of operation which influence the amount of TOC
emitted from a control device.  Ideally, a terminal owner or operator
would monitor all parameters which influence emissions and then enter
values for these parameters into a formula in order to calculate emis-
sions.  However,  it would be burdensome for the owner or operator  to
be required to collect this much data and perform such calculations  on
a continuous basis.  At a bulk terminal  there are too many parameters
which are necessary to calculate mass emissions for continuous monitoring
of all of them (using simple, currently available monitors) to be
practical.  Therefore, a form of monitoring which indicates whether
the control unit is being properly operated and maintained is considered
an effective means of minimizing emissions over an extended period.
EPA believes that in most cases the best way to demonstrate proper
operation and maintenance is to monitor only one parameter which
directly influences the actual emission rate from the processor.
     As stated in the preamble to the proposed standards, it is  possible
that monitoring systems included with a processor may be substituted
for an add-on system, with the approval  of the Administrator.  Many
processors currently being installed have parameter monitors which may
be suitable for this purpose.  Some unit manufacturers are developing
more sophisticated monitoring packages for use with their equipment
(IV-D-36, IV-D-53).
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     Comment:  One commenter indicated that proposed Section  60.500(c),
which states that the provisions for monitoring of operations will  not
apply until performance specifications are promulgated, makes  it  very
difficult  (for a terminal owner or operator) to apply effective budget
and planning principles (IV-D-12).  Several other commenters  objected
to the inclusion of pending provisions for monitoring in  the  proposed
regulation.  One recommended that such provisions not be  included
until a system which would not be capital-intensive, operationally
complex, or require excessive maintenance has  been developed  (IV-E-19).
     Response:  By including the general requirements for monitoring
systems in  the- standards at the time of proposal, the Agency  intended
to make planning and budgeting more straightforward  for owners  and
operators.   However, because the monitoring specifications are  not
available  at promulgation, the continuous monitoring section  of the
standards  has been reserved.  The monitoring requirements and specifications
will be proposed in the Federal Register' at a  later  date  and  comments
will be requested at that time.
2.9  TANK  TRUCK CONTROLS
     Approximately 20 commenters objected  to the mechanism for assuring
that loadings of gasoline tank trucks  be restricted  to  vapor-tight
vehicles.   These comments are summarized in the  following sections.
2.9.1  Restricting Loadings to Vapor-Tight Trucks
     Comment:  Several  commenters felt that the  terminal  owner or
operator should not have any responsibility for  the  vapor-tight status
of for-hire  tank trucks.  It was felt  that the terminal operator
should not be required  to police the testing and use of tank  trucks
which are  owned by others.  A common carrier would  be  free to send  an
unauthorized tank truck to an unattended terminal,  without the knowledge
of the terminal operator, and the ensuing  liability  of  the terminal
operator would be inappropriate  (IV-D-1, IV-D-9,  IV-D-10, IV-D-12,
IV-D-13, IV-D-20, IV-D-24, IV-D-26,  IV-D-27,  IV-D-28,  IV-D-29, IV-D-30,
IV-D-32, IV-D-33, IV-D-37, IV-E-19,  IV---1,  IV-F-2,  IV-F-3, IV-F-6).
Furthermore, several commenters felt that  requiring  the terminal
operator to restrict loadings to vapor-tight trucks  would require
manning the terminal 24 hours per day.   It was felt  that  this would
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impede the trend toward more efficient, automated terminals  (IV-D-9,
IV-D-24, IV-D-25,  IV-D-26, IV-D-27, IV-D-28, IV-D-32, IV-D-33,  IV-D-35,
IV-D-41, IV-E-19).
     Response:  Fugitive VOC emissions from tank trucks which occur
during loading can  be a significant emission source.  It is estimated
that on the average, nonvapor-tight tanks lose an average of 30 percent
of the potential vapor transferred, through leaks in dome covers and
pressure-vacuum vents.  By requiring the tanks which handle gasoline
to pass an annual  vapor tightness test, the average vapor loss due to
leakage during the  year between tests can be reduced to about 10 percent
of the potential vapors transferred (II-I-69).  Oil  industry represen-
tatives also have agreed that fugitive losses from tank trucks can be
a significant problem and should be controlled (IV-E-19, IV-F-3).
Fugitive VOC losses from tank trucks not only increase the pollution
problem but decrease the amount of liquid that can be recovered in
vapor recovery equipment.  The terminal owner or operator could lose
as much as $2 in recovered product per loading into nonvapor-tight
trucks.  For a small 380,000 liter/day (100,000 gallon/day) terminal
this could represent a daily loss of over $25.  For a large 3,800,000 liter/
day (1,000,000 gallon/day) terminal the losses could be over $250/day.
     To reflect the best demonstrated technology in controlling tank
truck leakage, the  standards require that the loading of product into
gasoline tank trucks be into vapor-tight tanks only.  A vapor-tight
tank is defined as  one that has passed a vapor tightness test within
the preceding year.  EPA Method 27 outlines the annual vapor tightness
test.  This test would reduce average fugitive VOC losses from tank
trucks by 67 percent (from 30 percent to 10 percent average vapor
loss).
     The objections from the terminal industry arise concerning the
responsibility for  assuring loadings are into vapor-tight tanks.  The
industry feels the  responsibility should be on the tank truck operator
instead of the terminal operator.  However, for the responsibility
under NSPS to be on the tank truck operator, the tank truck would have
to be part of the affected facility.  As discussed in BID, Volume I
and the preamble to the proposed standards, the feasibility  of  including
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the tank truck in the affected facility was reviewed.  The first case
considered both the tank truck and the terminal as separate affected
facilities under the standards.  This would lead to difficulties
associated with enforcing two standards governing a single polluting
operation.  For example, provisions would have to be made for  the
problem of NSPS applicability when an existing tank was  loaded  at  a
new terminal.  The second case considered the  truck tank and the
terminal as a single affected facility under one standard.  Again,  it
would be unreasonable to attempt to regulate a hybrid  and changeable
affected facility that would exist only during a loading operation  and
would frequently have more than one owner.  It was felt, therefore,
that the best approach to controlling fugitive tank truck leakage  was
by applying NSPS controls only to bulk terminals, and  permitting
NSPS-covered terminals to load only into truck-mounted tanks that  have
passed  a vapor tightness test.  Since tank trucks load primarily with
equipment owned by the terminal owner, and on  the property of  the
terminal owner, EPA believes it is reasonable  to presume for the
purpose of this regulation that these owners can exercise sufficient
control over the source to justify making them responsible for the
emissions therefrom.
     As stated in the preamble to the proposed regulation, it  was  not
intended that terminal personnel should man the racks  24 hours per
day, or observe the loading of every tank truck to verify that each
truck had passed an annual vapor tightness test.  EPA  felt that requiring
documentation on file that gasoline tank trucks operating out  of  the
terminal had passed a vapor tightness test would provide a sufficient
means of promoting loadings into vapor-tight tanks.   Industry  opposition
is centered around the liability placed on the terminal  owner  for
trucks  he does not own.  At unmanned, automated terminals, the terminal
operator is usually not present and cannot determine which trucks  are
loading.  EPA realizes these  limitations but believes  that the vapor
tightness requirement is necessary for the standards to  be effective.
     Changes to the vapor tightness requirement have been incorporated
into the promulgated regulation to clarify that the  standards  do  not
require the terminal operator to man the racks on a  24-hour  basis.  At
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terminals, even automated computer-billed terminals, some hard  copy
manifest is given to the driver of a for-hire tank truck to verify the
date and the type and amount of product loaded.  The driver keeps this
copy for his own records and often a copy is returned to the terminal
to cross-check the computer billing.  In several cases it has been
observed that the truck or tank identification number is logged on
this hard copy manifest (IV-B-6).   These records are used for billing
purposes and would allow the terminal owner to identify the truck
driver if he desired to do so in the future.  The Agency has incor-
porated into the final  regulation  a requirement that the terminal
owner obtain the tank identification number of all gasoline tank
trucks operating at affected facilities.  The owner is further  required
to periodically cross-check the tank identification with the vapor
tightness documentation on file at the terminal.  This cross-checking
is required within 2 weeks of the  loading.  Since the identification
numbers would be supplied to the terminal by the tank truck company,
and the tank truck company would be identified on the billing manifest
at the time of loading, cross-checking of identification numbers
should be rapid and should not represent an excessive burden on the
terminal operator.
     If the terminal discovers that an unauthorized tank truck  has
received gasoline, the terminal operator is required to notify  the
tank owner, indicating that only vapor-tight trucks may load gasoline
at the NSPS-covered terminal.  This notification would have to  be
documented and kept on file at the terminal.  The terminal operator
would then have to take steps to assure that the unauthorized tank
truck does not reload at the terminal until the required vapor  tight-
ness documentation had been provided.  Methods available to the terminal
owner or operator for achieving this could include revocation of
loading privileges, or contractual agreements between the terminal
owner or operator and the truck owner or operator.  However, the
regulation does not specify any particular methods, to allow the
terminal owner or operator the flexibility to meet the requirements
with minimum disruption to the terminal operations.  As specified in
Section lll(h)(3) of the Clean Air Act, the regulation provides that
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if the terminal  owner, after notice and opportunity for public hearing,
"establishes to  the satisfaction of the Administrator that an alterna-
tive means of emission limitation will achieve a reduction in emissions  ...
at least equivalent to the reduction in emissions of such air pollutant"
achieved under these vapor-tight tank truck requirements, the Administrator
"shall permit the use of such alternatives ...."  Thus, the terminal
owner is free, with EPA approval under Section lll(h)(3), to develop a
different strategy for controlling such fugitive emissions.

     Comment:  Two commenters stated that access cards at automated
terminals are not issued for a specific vehicle, so that loadings of
particular delivery tanks could not be monitored (IV-D-24, IV-D-29,
IV-E-19).
     Response:  EPA realizes that the access cards at these terminals
are not issued by vehicle, but are issued by company and by driver.
However, the method for limiting loadings to vapor-tight trucks does
not require on-the-spot monitoring or lock-out by the computer access
equipment.  All  that  is required is that the terminal operator obtain
the tank identification number of each truck loading at the facility
on a particular day.  Cross-checking against the vapor tightness data
on file could be done at a time more convenient to the terminal operator.
2.9.2  Suggested Alternatives
     Several commenters suggested alternatives to the section of the
regulation dealing with tank trucks, either in the wording of the
regulation or an alternate approach.  These alternatives are discussed
in this section.

     Comment:  One commenter felt that the owner of an affected facility
should be required to "clearly advise" tank truck operators of the
requirements, with actual  responsibility for compliance on the operators
of the trucks (IV-D-1).
     Response:  EPA agrees that as a terminal becomes affected by the
regulation, the owner or operator of the facility should notify those
tank truck firms that operate out of that facility of the requirements
for vapor recovery equipment and vapor tightness.  The terminal owner
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or operator would have to notify tank truck owners in order to comply
with the requirement under §60.502(e)(l) to obtain vapor tightness
documentation.  Therefore, a separate requirement for terminal owners
to advise truck operators of the terminal's equipment and operational
requirements is not considered necessary.  Operators of the trucks
cannot be made responsible for compliance,  since the tank truck is not
part of the affected facility.  Truck operators will, however, have  to
install the proper equipment and have their trucks tested for vapor
tightness, in order to load at any affected terminal.  Reasons for not
including the tank truck in the affected facility were discussed in
Section 2.9.1.

     Comment:  Another commenter suggested  a system of vehicle inspection
stickers to enforce the vapor tightness provisions (IV-F-1, IV-F-2).
     Response:  It is possible that the use of stickers may expedite
the day-to-day, spot checking of tanks for  vapor tightness, as shown
in the system used in California.  However, since this type of checking
may impose an unreasonable burden on the terminal operator, and is
impractical at unattended terminal operations, it has not been made  a
part of the regulation.  EPA feels that the system of obtaining tank
identification numbers and cross-checking against vapor tightness
documentation will accomplish the objective of limiting tank truck
fugitive VOC emissions during loading.

     Comment:  Another commenter felt that  it was reasonable to require
the owner or operator to request written documentation of vapor tightness,
but that he should not be held responsible  for the completeness or
accuracy of the documentation (IV-F-1, IV-F-3).
     Response:  The intent of keeping the vapor tightness documentation
on file at the terminal is not to require the terminal operator to
observe the tests or verify the test results for those trucks he does
not own.   In the regulation, §60.505(b) describes the minimum information
that the terminal operator should accept as documentation that a tank
truck has passed the vapor tightness test.
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     Comment:  One conmenter suggested revisions to proposed Sections 60.502(d),
(e), and (f) of the regulation, which would require the terminal owner
or operator to "implement a program designed to" restrict loadings to
vapor-tight tank trucks with compatible vapor recovery equipment, and
require connection of the truck's and the terminal's collection systems
during each loading (IV-D-10).
     Response:  Allowing the terminal operator to simply "implement a
program" to restrict loadings to vapor-tight trucks would require that
the Administrator review all programs on a case-by-case basis to
determine adequacy.  Under this approach, no guidelines for an accept-
able program would be available to the owner or operator.  Changes
made to the regulation represent a program which is reasonable, but
which still allows the terminal to use any method which EPA judges
equivalent under the terms of Section lll(h)(3), as described in
Section 2.9.1 of this document.  This will permit flexibility in com-
plying with these requirements while reducing the case-by-case determinations
necessary by the Administrator.

     Comment:  One commenter stated that the independent tank truck
operator would be restricted in his business because his access to
regulated terminals would be limited, and he could not operate at
various terminals because they would not have vapor tightness docu-
mentation for his tank trucks on file at the terminal.  The commenter
proposed as an alternate scheme that tank truck operators carry the
documentation and be responsible for connecting vapor collection
equipment during loading.  Terminal operators would only have to train
drivers in the hookup procedures (IV-D-9).
     Response:  Having the tank truck operator carry the documentation
as the only means of vapor tightness verification would require the
terminal operator to review the information before each loading.  This
would be impossible at unmanned automated terminals, and such a require-
ment would be a burden on both the terminal and truck operators.  At
most terminals, the truck driver performs all the loadings at the
racks and is responsible for performing these operations within the
operating rules of the terminal, with terminal operators training
drivers in the loading procedures.

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     Tank truck owners can alleviate any possible restriction on  the
number of terminals at which their trucks may load by sending documen-
tation to all  affected terminals at which their trucks might conceivably
load in the coming year.   For manned terminals, this documentation
could be provided at the  initial loading at each individual terminal.
This one-time  filing of information would be much more practical  than
having to present documentation at each loading.

     Comment:   Another commenter felt that the regulation should  make
clear that a terminal  owner or operator would not be required to  test
for-hire tank  trucks for  compliance, nor to keep documentation on such
trucks at the  terminal.  He suggested the following revised Section 60.505(a)
          "The owner or operator of each bulk gasoline terminal,  prior
          to loading gasoline into a tank truck, shall request the
          tank truck driver to provide a certificate indicating the
          tank truck meets all EPA requirements and testing to qualify
          as a vapor-tight gasoline tank truck" (IV-D-13).

     Response:  As indicated in the response to the previous comment,
a requirement  for the tank truck driver to present vapor tightness
documentation  before each loading would necessitate that the terminal
be manned at all  times.  This would not be feasible at the state-of-the-
art automated  terminals.   By requiring that the driver record the tank
I.D. number at the time of loading, the terminal operator can verify
the vapor-tight truck loadings at a time when the terminal office is
manned.  As currently phrased, the regulation makes clear that the
terminal operator is not  required to test trucks for compliance,  but
only to keep documentation on file, record tank truck identification
numbers, cross-check identification numbers, and make the specified
notifications  (§§60.502(e) and 60.505(a)).

     Comment:   One commenter felt that an extensive file would have to
be checked to  verify each tank truck's status before each product
loading.  A suggested alternate approach is to require the owner  of
each fleet or  truck which may use an affected terminal to file an
annual certification that all trucks used have been proved vapor-tight,
with this file being maintained only at the central office which
controls each  terminal complex  (IV-D-23).

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     Response:  The intent of the proposed regulation was not to
require that the data file be checked prior to each loading.  The
final  regulation requires the vapor tightness documentation to be
obtained from the truck owner or operator and to be kept on file at
the terminal.  It is possible that in some cases a terminal operator
may be permitted to keep the documentation file at a location other
than the affected terminal, especially in the case of unmanned terminals.
This file will be checked against the tank identification numbers
recorded for tank truck loadings within a time limit of 2 weeks.   The
commenter's alternative would be impractical, since the terminal owner
would be unable to verify whether only the vapor-tight trucks operated
by a particular firm are loading at the affected facility.

     Comment:  One commenter offered the suggestion that State regulations
would be the best vehicle for enforcement of tank vapor tightness, and
stated that enforcement penalties on truck operators in California
lead to an effective system in that State (IV-F-1, IV-F-3).  Two
commenters felt that in areas with no SIP coverage, the controls on
tank trucks would not be effective, because of the variety  of schedules
and equipment in those areas.  Both agreed that many truck  drivers
might be inclined to circumvent the requirements if there were no
direct penalties, and that SIP regulation would be a more  effective
means of control than NSPS (IV-F-1).
     Response:  Section 111 requires that NSPS reflect application of
best demonstrated technology for new, modified, and reconstructed
terminals in both attainment and nonattainment areas.  The  Agency  has
determined that the CTG vapor tightness requirements reflect application
of such technology to tank trucks.  Therefore, this NSPS extends the
CTG level of control to affected facilities in attainment  areas  that
may not be controlled by the States, thereby ensuring control to
minimum national levels at all new, modified, and reconstructed  facilities,
The various schedules of tank truck deliveries in nonSIP areas should
not affect the effectiveness of vapor tightness controls in these
areas.  Once a tank truck owner had installed vapor collection equipment
and tested a tank truck for vapor tightness, he would be free to
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follow any delivery schedule compatible with local business patterns
with no disruption resulting from the standards.  The tank truck's
equipment would have to be compatible with the terminal's, as  in  all
instances, so that loading and vapor recovery could be accomplished.
Such equipment requirements are not unusual, and would be similar to
the requirements on tank trucks loading at terminals in SIP-controlled
areas.
     As stated before,  since the tank truck is not part of the affected
facility, the regulation can directly apply only to the terminal.   EPA
believes that adherence to the logging and notification method of
compliance specified in the regulation will reduce the level of gasoline
loadings into nonvapor-tight trucks.

     Comment:  One commenter proposed an alternative to the tank  vapor
tightness program, in which a fan would be installed in the vapor
collection system to draw air-vapor mixture out of the tank trucks
during product loading.  This would make tank vapor tightness unnecessary,
because large positive pressures, causing leakage, would not be created
in the tank (IV-C-9, IV-F-1).
     Response:  EPA did not select the commenter's proposed alternative
to the tank truck vapor tightness requirement since no system of  this
type has been installed or demonstrated at a commercial bulk gasoline
terminal.

     Comment:  Another commenter suggested an alternative which would
require that the owner or operator of the terminal maintain files
documenting gasoline tank trucks that are authorized to load at that
facility, and that gasoline tank truck owners or operators not load
unauthorized or incompatibly equipped gasoline tank trucks at  the
facility.  The documentation file could include a contractual  requirement
that the gasoline tank truck owner would not present for loading  any
unauthorized or incompatible units.  Violations of the contract could
subject the owner to revocation of the provisions of the contract,
such as loss of loading privileges for his gasoline fleet (IV-D-24,
IV-D-41).
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     Response:  EPA does not choose to specify requirements for or
restrict any contractual agreement between the tank truck operator and
the terminal operator.  However, enforcement of contractual provisions
between the terminal and tank truck operators may be an effective
method of assuring that the terminal operator obtains the correct tank
truck identification numbers and prevents a nonvapor-tight truck from
loading a second time.  Also, contract enforcement may form part of  a
compliance strategy different from that specified in the standards.
As discussed in Section 2.9.1 above, terminal owners may use methods
of compliance different from that specified by EPA if, after notice
and opportunity for public hearing, the Administrator determines that
the alternative method would result in emission reduction at least
equivalent to that resulting from adherence to the compliance method
specified in the regulation.  The Administrator must review and determine
the equivalency of any alternative approaches on a case-by-case basis,
in accordance with Section lll(h)(3) of the Clean Air Act.
2.9.3  Administrative Burden
     Comment:  One commenter felt that an administrative burden would
be created by a requirement to  keep vapor tightness documentation for
as many as 400 to 500 transport trucks using a given terminal  (IV-F-1,
IV-F-2).  Several other commenters generally argued that the tank
truck controls would represent  an administrative burden, as well as
being costly and inequitable (IV-D-12, IV-D-27, IV-E-19).
     Response:  The testing and maintenance of tank trucks for vapor
tightness has been shown to have a significant effect in reducing
total emissions during loading  (Section 2.9.1).  Thus, this procedure
has a very important function in bulk terminal VOC emissions limitation.
The administrative burden of keeping the documentation on file would
be minimal since the information would in most cases be supplied by
the owner of for-hire tank trucks and the terminal would simply file
the data.  As discussed in Section 2.9.1, cross-checking these files
with tank identification numbers logged during loading should  be a
simple process and should not represent an excessive burden.
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2.9.4  Tank Truck Population Impacted By The Standard
     Comment:  One commenter said that the total population of  tank
semi-trailers in gasoline service had been seriously underestimated  in
BID, Volume I, and hence the economic impact of controls on the  tank
truck industry had not been fully considered.  He further stated  that
for-hire or common carriers cannot dedicate particular tank trucks to
particular terminals so that regulatory coverage of a terminal  could
impact all common carriers in the same area (IV-F-4, IV-F-6).
     Response:  The economic impact on the for-hire tank truck  industry
is performed on an individual firm basis rather than a nationwide
basis.  Only tank trucks in attainment areas will be impacted by  the
standards since the tank truck requirements are identical to SIP
requirements being implemented in nonattainment areas.  Since the
standards affect only about 7 percent of all terminals in attainment
areas, it seems very unlikely that all tank trucks in attainment  areas
would be affected.  Or, looking at it in another way, it seems  unlikely
that, if a trucking firm operated out of 100 terminals, it would
convert all trucks to the NSPS requirements if only 7 of these  terminals
became affected facilities.  However, for purposes of the economic
impact analysis to determine if these individual trucking firms  could
afford the NSPS requirements, the following assumptions were made:
(1) for trucking firms in the smallest two firm sizes (operating
2 tank vehicles and 7 tank vehicles, respectively), it was assumed
that all tank vehicles would be converted to meet the NSPS requirements,
and (2) for trucking firms in the two largest firm sizes (operating
30 tank vehicles and 100 tank vehicles, respectively), it was assumed
that 50 percent of the tank vehicles would be converted to meet  the
NSPS requirements.  EPA believes these assumptions are realistic  in
determining the worst case economic impact on each model firm.   As
discussed in Section 8.4.2 of BID, Volume I, the economic analysis
using these worst case assumptions showed a small impact on the  for-hire
tank truck industry.
     Many attempts have been made by several organizations to estimate
the total national tank truck population.  An analysis by the Tank
Trailer Manufacturer Association (TTMA) in  1979 concluded that  there
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are about 80,000 liquid petroleum tank trailers in service.  The
analysis indicated that government and industry estimates at that  time
ranged from 70,000 to 132,000.  The estimate of 100,000 tank vehicles
in flammable liquid service made in Section 8.1.3.2 of BID, Volume I
is still considered a reasonable figure, in light of the unavailability
of exact population data.  The estimate of 85,000 gasoline tank vehicles
taken from an EPA survey is considered conservative, considering the
variety of petroleum products which are not normally transported in
gasoline tank trucks.  The commenter does not explain his contention
that  "it is safe to assume that virtually every one of those (petroleum
service) trailers finds its way into gasoline service at one time  or
another."  EPA does not agree with this assumption.
      As stated in the Arthur D. Little (ADL) report (II-A-47),  tank
wagons  (at bulk plants) usually have tank capacities between 2,000 and
4,000 gallons, whereas transports (at bulk terminals) usually  have
capacities between 8,000 and 9,000 gallons.  Bureau of the Census  data
were  used to estimate the percentage of liquid tank vehicles having a
capacity greater than 4,000 gallons (15,140 liters).  This percentage
was found to be 31 percent, indicating that there are approximately
26,300  gasoline tank trucks in operation at bulk terminals.  This  is
consistent with the ADL statement that, in 1978, there were an  estimated
29,200  gasoline tank trailers in operation at bulk terminals.   The
45,000  semi-trailers which the commenter says are operated by  National
Oil Jobbers Council (NOJC) members transport all petroleum products
between all marketing distribution points.
      The percentage of the 26,300 bulk terminal tank trucks which  will
require conversion to bottom loading or vapor recovery as a result of
the standards can only be estimated roughly.  The tank trucks  in
nonattainment areas, approximately 72 percent of the total, or 18,900,
are expected to be regulated under SIP's.  This leaves about  7,400 tank
trucks  potentially eligible for retrofit under the standards  (in
attainment areas).  The percentage of affected existing facilities in
these areas by 1986 is expected to be 7.1 percent, so that approximately
525 tank trucks will be affected in the first 5 years.  Assuming the
number  of terminal-owned tank trucks at each model plant as shown  in
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Table 6-2 of BID, Volume I, the remaining number of for-hire trucks
would be 370, or 70 percent of the total.  This is consistent with the
ADL statement that most gasoline transports are owned by common  carriers
and not by terminal operators.  Thus, the total number of for-hire
gasoline tank trucks operating at bulk terminals can be estimated to
be 70 percent of 26,300, or 18,400,  and the number of affected for-hire
trucks would be about 2 percent of this total.
     While many more tank trucks are likely to be retrofitted for
bottom loading during the first 5 years, these conversions will  be
performed for reasons of safety, modernization, and fleet utilization
flexibility.  In addition, State vapor recovery regulations in most
areas will tend to encourage bottom-loaded, vapor recovery-equipped
tank trucks to become the industry standard.
2.9.5  Economic Burden
     Comment:  One commenter felt that the impact on oil  jobbers, who
would be indirectly affected because loadings of gasoline tank trucks
would be restricted to those which had passed an annual  vapor tightness
test, would be minimal.  The commenter also stated that the costs
associated with this test would not be excessive (IV-D-8).
     Response:  EPA has examined the costs of the vapor tightness test
and found them to be reasonable.  The analyses in Section 2.5 and
Appendix B support this comment.

     Comment:  One commenter pointed out that tank trucks would  require
adapters in order to load at several terminals having different  vapor
recovery systems.  In this situation the independent for-hire truck
operator could not be competitive with trucking companies operating
with larger fleets of trucks.  This commenter also assumed that  any
gasoline tank truck loading at an affected facility would deliver only
to those service stations or bulk plants with vapor control systems.
The commenter questioned what the requirements on tank trucks would be
for those which loaded alternately between affected and unaffected
facilities.  This commenter further questioned whether tank trucks
would be required to install overfill protection.  It was suggested
that further studies on the for-hire motor carriers be initiated,
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which should include additional data obtained from State associations
and their members, and should verify the accuracy of  1977 data  relative
to today's market situation (IV-D-11).
     Response:  An economic analysis was performed for each model  tank
truck firm size and the results were presented  in BID, Volume  I.   The
analysis indicated only a minor economic impact on the smaller  independent
for-hire truck firms.  The regulation will apply only to the  loading
of gasoline tank trucks at new, modified, or reconstructed bulk gasoline
terminals.  The NSPS does not apply to tank truck unloading or  loading
operations at bulk plants or unloading operations at  service  stations,
nor do  the standards specifically require overfill protection.   However,
the tank truck operator would have to comply, as at any terminal,  with
the loading requirements of that individual terminal.  If a terminal
requires overfill protection, as most bottom-loading  terminals  do,
then the tank truck operator would have to install overfill protection
in order to load at that terminal.
     Since independent trucking firms are able  to operate in  SIP-controlled
areas where the same types of adapters would be required for  loading
and vapor recovery systems, EPA does not feel that the requirement for
adapters is an excessive burden on the independent tank truck  operator.
Since the independent typically operates out of several terminals  with
a variety of equipment and procedures, the need for several adapters
should  not be unusually burdensome for these truck owners.  Oil  company
representatives have informed EPA that common carriers do not  require
a large assortment of adapters to load product, because such  equipment
is manufactured according to the specifications of the American Petroleum
Institute (API) (IV-E-19, VI-J-21).
     As stated in previous responses, the control of  fugitive  leakage
emissions from tank trucks is very important to achieving meaningful
reductions in bulk terminal overall emissions.  A typical leaking
truck may lose 30 percent of its displaced vapors through worn  or
defective equipment, or 288 mg/liter in fugitive losses.  This  amounts
to over eight times the emissions from a state-of-the-art vapor processor.
Considering the importance of controlling these emissions, EPA  believes
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it is reasonable to set standards that effectively require independent
tank truck owners that typically service a variety of terminals to
load only into vapor-tight trucks at NSPS-covered facilities.
     Additional  data gathering and consideration of costs to the
for-hire tank truck industry have been undertaken since proposal.  The
cost and economic impacts are discussed in Sections 2.5.5 and 2.5.6,
and in Sections  B.2.2 and B.3 of Appendix B.
2.10  LEGAL CONSIDERATIONS
2.10.1  Tank Trucks Not Stationary Sources
     Comment:  Several commenters questioned EPA's legal authority to
impose restrictions, i.e., retrofitting and vapor tightness testing,
on gasoline tank trucks.   Two of the commenters felt that, since tank
trucks do not fall within the definition of a "stationary" source,
they may not be  regulated under Section 111 (IV-D-20, IV-D-35, IV-F-4,
IV-F-6).  One comtnenter expressed the opinion that tank trucks are
neither "major"  nor "stationary" sources, and that the proposed controls
on tank trucks constitute ultra vires requirements.  These requirements
were characterized as "arbitrary and capricious," and said to constitute
"the taking of private property without cause, compensation, or due
process" (IV-D-33).  Another commenter stated that the proposed standard
usurps State regulatory functions by imposing an extra layer of Federal
regulation on top of effective State rules, and by "artificially"
treating tank trucks as stationary sources subject to the standards
(IV-D-26).
     One commenter stated that EPA has no authority to promulgate NSPS
which control emissions from mobile sources directly or indirectly.
He does feel, however, that it is reasonable to require a terminal
owner or operator to request written vapor tightness verification from
tank truck operators (IV-F-1, IV-F-3).  Another commenter stated that
EPA has no authority to directly regulate tank trucks under Section  111,
and EPA cannot do indirectly what it cannot do directly (citing Brown v.  EPA,
566 F.2d 665 (9th Cir. 1977)) (IV-D-35).
     Response:  For purposes of this NSPS, the stationary source, or
affected facility, is the total of all bulk terminal loading racks
loading liquid product into gasoline tank trucks.  Those loading racks

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are essential to carrying out  the activity known as product  loading.
While product loading involves both the affected facility and mobile
equipment, including the  tank  truck,  it is clearly a  stationary  activity,
since it requires no movement  from the affected facility site.   Among
the pollutants created  by product loading are  vapors  forced  from the
tank truck as a direct  result  of the  pumping of liquid  product into
the tank truck.  Since  escape  of these vapors  is caused by  stationary
activities at a stationary  facility,  they are  "stationary source"
emissions  subject to  regulation  under Section  111 --  even though the
tank trucks  from which  they escape during that activity have the
capability to move.
     As  indicated above,  the tank  truck  is  not included in  the designation
of  the  "affected facility"  under these standards.  The  standards place
responsibility  on the  terminal  owner  only,  requiring  the owner to
restrict loadings to  vapor-tight tank trucks  equipped with  compatible
vapor collection equipment.  The regulation  would  not directly require
either  new or  old tank  trucks  to be vapor-tight  or  equipped  with
certain  types  of hardware.   (See next comment  and  response.)
      Section lll(a)(2)  defines "stationary  source"  as any  "building,
structure, facility,  or installation  which  emits  or may emit any air
pollutant."   EPA  identifies the "stationary  source" as  certain specified
stationary equipment  (termed the "affected  facility") that  "emits" a
pollutant.   In  the  Administrator's  view,  stationary equipment "emits"
a pollutant  if it  causes that pollutant  to  enter the  atmosphere.
EPA's  authority to  define the term "emits"  in  this  way  derives from
Section 301  of the  Act, as  interpreted  in  the  cases  fi-ee,  e.g.,  Alabama Power
v.  Costle, 636 F.2d 323  (D.C.  Cir.  1979)).   In accordance with this provision,
the Agency is  interpreting  the term "emits"  broadly,  to serve the
broad  purposes  of  Section 111 (described  in  the  text  below).
      In  the  Administrator's view,  affected  facility  emissions subject
to regulation  under Section 111 include  all  pollutants  that enter the
atmosphere as  a result of the stationary  industrial activities at the
affected facility,  even those that enter the atmosphere after contacting
equipment with  mobility.  Stated differently,  the test  for  whether
emissions  are  "stationary source"  emissions  subject  to  regulation
under Section  111 is  whether the emissions  are caused by  a  stationary
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facility during activities  that  require no movement  from  the facility,
not whether the emissions escape to  the atmosphere without  touching
equipment having the capability  to move.
     Interpreting  "stationary source" emissions to include emissions
resulting from stationary activities  in which both the affected facility
and some mobile equipment take part serves the intent of the  statute.
Congress enacted Section 111 for the  "overriding purpose" of  "preventing]
new pollution problems."  S. Rep. No. 91-1196, 1970 J_eg_. Hist, at 416.
The Senate Report  states that Section 111 seeks to attain this goal by
requiring control  of new commercial  and industrial establishments "to
the maximum practicable degree regardless of their ... industrial
operations."  Id.   Similarly, the Report states that  "maximum use of
available means of preventing and controlling air pollution is essential"
to the attainment  of the goals of Section 111.  Id.  The legislative
history thus indicates  that  Congress  intended Section 111 to  address
emissions from all  stationary operations at industrial establishments
when the Agency can identify the maximum practicable degree of control
for these emissions.  To interpret Section lll(a)(2) so that  emissions
resulting from certain  stationary activities involving the stationary
source would not constitute  "stationary source" emissions simply
because those emissions pass through  some equipment with the  capability
to move would be incompatible with that intent.
     The Ninth Circuit  Court of Appeals case cited by the commenter
casts no doubt on  EPA's authority to  regulate these vapors as emissions
from the loading rack.   That case stands for the proposition  that
under the Clean Air Act, as  amended in 1977, a State highway  is not an
"indirect source"  of pollution simply by virtue of the State's failure
to adopt an inspection  and maintenance program to control pollutants
emitted by automobiles  that  travel on those highways.  The decision
turns primarily on the  legislative history of Section 110.  The Court
in no way implied  that  when  pollutants escape as a direct result of a
stationary activity at  an industrial  unit, those pollutants are not
"stationary source" emissions within  the intent of Section 111.
     The Agency recognizes that promulgation of standards regulating
loading racks as "stationary sources" may significantly affect tank
truck owners and other segments of the Petroleum Transportation and
Marketing industry.  That standards within an agency's statutory
authority indirectly affect  nonregulated entities, however, does not
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in itself diminish the authority to set the standards.  Nothing in the
statute or its history indicates that, in the case at hand, the indirect
impact of loading rack standards on certain tank truck owners deprives
the Agency of its clear authority to set these new source performance
standards.  Nor does the case cited by the commenter suggest that
otherwise valid regulation of "stationary sources" is rendered invalid
simply because the regulation indirectly affects other segments of the
industry  involved.
      In fact, it  is  likely that most NSPS's based  in whole or in part
on process changes affect industries other than that to which the
standards directly apply.  The standards for  electric utility steam
generators (40 CFR 60.40a-49a), for instance, significantly affect
several other industries.  Those standards are based on a combination
of scrubbing and  coal  washing.  For this reason, they will affect
vitally the coal-washing and  scrubbing industries.  Similarly, the
NSPS's for different coating  application industries (e.g., the metal
furniture industry), based typically on use of low-solvent coatings,
will  undoubtedly  affect manufacturers of low-solvent coatings, high-
solvent coatings, and  coating application equipment.
      The  impact  on tank trucks of a requirement that certain bulk
terminals load only  into vapor-tight trucks equipped with compatible
equipment does not differ in  kind from the indirect impacts resulting
from  these other  new source  performance standards.  Bulk terminals
deal  extensively  with  delivery vehicles.  As  a result,  it  is to  be
expected  that regulation of  bulk terminals would affect delivery
vehicles  in  some  manner, particularly in connection with the most
significant  activity at bulk  terminals — product  loading.   It was  not
Congress's intent that because of this effect EPA  may not set bulk
terminal  emission standards  otherwise authorized by Section  111.
      Nor  does the potential  effect on tank truck owners amount to a
denial of due process  or an  unconstitutional  taking of  property.
Because the commenter  did not elaborate on the specific bases for
these claims of  unconstitutionality, the Agency can respond only
generally.  The  Clean  Air Act reflects a congressional  determination
that  air  pollution has a substantial effect on interstate commerce  and
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therefore may be regulated by Congress (and, through proper delegation,
EPA) under the commerce clause.   District of Columbia v. Train,  521  F.2d
971, 980 (D.C. Cir. 1975).  It is unreasonable to suggest that  regulation
of emissions forced from the tank truck during loading bears no  rational
relationship to protection of public health and welfare, and thus
violates the due process clause of the Fifth Amendment.  There  is a
rational relationship between escape of these vapors and the public
health and welfare, because these emissions contribute to ozone  formation.
Sierra Club v. EPA, 540 F.2d 1114, 1139 (D.C. Cir. 1976).  There is
also a proper legislative purpose underlying the requirements aimed  at
controlling these emissions.  Moreover, the means the Agency has
chosen, as discussed above, are reasonable and appropriate.  Id., at
1139 n.80 (citing Heart of Atlanta Motel, Inc. v. United States,
379 U.S. 241, 258-59 (1964)).
     Nor do these standards transgress the takings prohibition  in the
Constitution.  Given the substantial  public interest in preserving
clean air, tight restrictions may constitutionally be imposed on
private property.  South Terminal Corp. v. EPA. 504 F.2d 646, 678-80
(1st Cir. 1974).  While this NSPS indirectly limits the uses of  tank
trucks, the limitation is not so extreme as to constitute an appro-
priation of the vehicles.  Sierra Club v. EPA, supra, at 1140.   This
regulation affects only one of the tank truck uses available to  the
truck owner — loading at affected facilities.  The right to use
nonvapor-tight tank trucks at other facilities is neither extinguished
nor transferred to someone else.
2.10.2  Loading Restrictions by Terminal Operators
     Comment:  One commenter claimed that EPA does not have the  authority
to confer upon terminals the police power of a government to inspect,
control, regulate, and certify the equipment (tank trucks) owned by
other private commercial corporations and taxpayers, or to require
terminals to undertake and perform the tasks and responsibilities of
EPA.  A terminal operator could be subject to lawsuits by tank  truck
operators if the proposed restrictions on tank truck loadings were
carried out (I-V-D-13).
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     Response:  In requiring terminal owners to restrict loading at
affected facilities to vapor-tight trucks with compatible vapor collection
equipment, EPA is not attempting to confer government police power on
terminal owners.  Rather, the Agency is requiring terminal owners to
exercise control over loading activities conducted at their facilities.
These requirements are based on the assumption that because loading is
carried out with equipment largely owned by the terminal owners, with
the owners' permission and on their property, it is reasonable to
charge  these  owners with responsibility for the emissions that result
from loading.
     Thus, in accordance with Section 111, EPA is requiring terminal
owners  to take certain steps to assure that VOC emissions from activities
reasonably considered to be under the owners' control are reduced to
the level reflecting application of the best system of continuous
emission  reduction.  Nothing in the statute indicates that EPA lacks
authority to  establish such standards that may effectively require
owners  to exercise some control over the activities of persons using
the owners' facilities.
     As described earlier in Section 2.9.1, the promulgated regulation
specifies a method of compliance that would permit terminal owners to
meet the  standards without manning the affected racks on a 24-hour
basis.  The revised compliance requirements will limit the owner's
responsibility under the promulgated standards.
     The  Agency cannot determine how the promulgated  requirements will
result  in lawsuits by tank truck operators against terminal owners.
The commenter did not provide an explanation and the  Agency is not
aware of  the  basis for the commenter's suggestion.  Therefore, EPA
does not  at this time consider it appropriate to speculate about the
legal problems that might arise between terminal and  tank truck owners.
2.10.3  Setting of an Operational Standard
     Comment:  One commenter stated  that the requirements on terminal
owners  and operators to control the access of gasoline tank trucks is
a  "work practice" or "operational" standard, which may be promulgated
only instead  of standards of performance, according to Section lll(b)(l)
arid (2) of the Clean Air Act.  Since a standard of performance has
been set, the operational standard is inappropriate  (IV-D-35).
                               2-112

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     Response:   Under Section 111, the standards EPA sets must reflect
application of  the best demonstrated technological  system of continuous
emission reduction to the affected facility.  The Agency has determined
that the best demonstrated system for controlling VOC emitted during
tank truck loading is the combination of the following actions:  restricting
loading to vapor-tight tank trucks; collecting the vapors that can be
captured by installing a vapor collection system and connecting the
system during loading; and controlling emissions from the vapor collection
system with an  adsorber, an oxidizer, or some other acceptable system.
     The Agency has determined that even after applying this system at
loading racks,  it is both technologically and economically impracticable
to measure total  organic compound emissions from the loading process
for the purpose of comparing the amount of emissions to a numerical
emission limit.  This is because residual fugitive (leakage) emissions
from vapor-tight trucks still escape directly to the atmosphere and
are not captured by the vapor collection system.  Section lll(h)
permits EPA to  set work practice and equipment standards "instead of"
a standard of performance for those sources for which it would not be
feasible to prescribe and enforce a standard of performance.  The
statute states  that prescribing such a standard is not feasible where
the measurement is technologically or economically impracticable.
Accordingly, the Agency is including in this regulation a work practice
standard ained  at controlling emissions from leaks and similar emission
sources during  loading.  This would require that loading be restricted
to vapor-tight  trucks.
     Complementing this requirement are additional  equipment and
operational requirements assuring the effectiveness of the vapor
tightness standards.  Specifically, these requirements seek to minimize
the chance that those vapors not able to escape through leaks in the
vapor-tight tank are emitted through a number of other potential
escape routes in the loading system.  These standards require that:
(1) each loading rack be equipped with a vapor collection system
designed to collect the vapors displaced from the tank truck during
loading; (2) gasoline loadings into tank trucks be limited to those
equipped with compatible vapor collection equipment; (3) the racks'
                               2-113

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vapor collection system be designed to prevent any vapors collected at
one loading rack from passing to another loading rack; (4) the two
vapor collection systems be connected during each loading of a gasoline
tank truck; (5) the vapor collection and liquid loading equipment be
designed and operated to prevent excess gauge pressure during loading;
(6) the terminal's vapor collection system be designed so that no
pressure-vacuum vent begins to open below the specified cutoff pressure;
and (7) the collection and loading equipment be inspected for leaks at
certain times during loading.
     The primary result of these steps is that most vapors will become
centralized in the terminal's vapor collection system.  Only from this
source  is  it technologically and economically practicable to measure
TOC emissions.. The Agency has established a standard of performance
for vapors collected by the vapor collection system because it is
feasible to prescribe and enforce such a standard for these emissions.
     In sum, the Agency is setting equipment and work practice standards
"instead of" a standard of performance to control those fugitive emis-
sions for  which measurement is impracticable.  EPA is establishing  a
standard of performance for those emissions for which measurement is
practicable.  This action accords with the language of Section lll(h)
and Congress's intent that, where feasible, the Agency establish
emission limitations.
2.10.4  Setting of an Equipment Standard
     Comment:  One commenter felt that, since  it is not desirable to
burn collected vapors, the carbon adsorption system was being proposed
as  the  only control technology to achieve the  standard.  This was said
to  constitute an equipment standard which is contrary to the requirements
of  Section lll(h)  (IV-D-31).
     Response:  Section 111 requires  EPA to set standards achievable
through application of the best demonstrated technology.  Even if the
statutory  factors pointed to selection of only one technology as the
best demonstrated technology for controlling the vapors collected by
the vapor  collection system, the emission limit based on that technology
would not  constitute a standard requiring the  use of  particular equipment
(for which a Section lll(h) finding would be necessary).  Rather, a
                                2-114

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standard based on the use of one technology would still  permit source
owners to use any system of  continuous  emission reduction capable of
meeting the limit; e.g., one that may  not have  been demonstrated for
use by the entire industry,  but which  is  demonstrated for use at a
particular type of source.   Furthermore,  owners are free under the
standard of performance  to apply for technology waivers  under Section lll(j)
to obtain EPA approval  to use certain  innovative technologies to meet
the numerical 1imit.
     In any event, the Agency has determined that for this industry,
two technologies—oxidation  and carbon  adsorption—are the best demon-
strated technology.   While in some cases  a source owner  may prefer not
to use oxidation, in  the Agency's judgment both technologies  are
adequately demonstrated, considering adverse impacts.
                               2-115

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2.11  REFERENCES

I-2b      U.S. Environmental  Protection Agency.  Priority list and
          additions to the list of categories of stationary sources,
          final rule.  Washington, D.C.  Office of the Federal Register.
          August 21, 1979.

II-A-4    Amoco Oil Company.   Demonstration of Reduced Hydrocarbon
          Emissions from Gasoline Loading Terminals.  U.S. Environmental
          Protection Agency.   Publication No. EPA-650/2-75-042.  June
          1975.  51 p.

II-A-5    Betz Environmental  Engineers, Incorporated.  Emissions from
          Gasoline Transfer Operations at Exxon Company, USA, Baytown
          Terminal, Baytown, Texas.  U.S. Environmental Protection
          Agency.  Research Triangle Park, N.C.  EMB Report. No. 75-GAS-8.
          September 1975.  75 p.

II-A-6    Betz Environmental  Engineers, Incorporated.  Emissions from
          Gasoline Transfer Operations at Exxon Company, USA, Philadelphia
          Terminal, Philadelphia, Pennsylvania.  U.S. Environmental
          Protection Agency.  Research Triangle Park, N.C.  EMB Report
          No.  75-GAS-10.  September 1975.  91 p.

II-A-9    Compilation of Air Pollution Emission Factors, Transportation
          and  Marketing of Petroleum Liqu-ids.  U.S. Environmental
          Protection Agency.  Publication No. AP-42.  February 1976.

II-A-10   Betz Environmental Engineers, Incorporated.  Gasoline Vapor
          Recovery Efficiency Testing at Bulk Transfer Terminals
          Performed at Diamond Shamrock, Incorporated, Terminal, Denver,
          Colorado.  U.S. Environmental Protection Agency.  Research
          Triangle Park, N.C.  Contract No. 68-02-1407, Task  12.
          Project No. 76-GAS-16.  September 1976.  98 p.

II-A-11   Betz Environmental Engineers, Incorporated.  Gasoline Vapor
          Recovery Efficiency Testing at Bulk Transfer Terminals Performed
          at Pasco-Denver Products Terminal.  U.S.  Environmental
          Protection Agency.  Research Triangle Park, N.C.  Contract
          No.  68-02-1407.  Project No. 76-GAS-17.   September  1976.
          97 p.

II-A-14   Betz Environmental  Engineers, Incorporated.  Gasoline Vapor
          Recovery Efficiency Testing at Bulk Transfer Terminals
          Performed at the Texaco Terminal, Westville, New Jersey.
          U.S. Environmental Protection Agency.  Research Triangle
          Park, N.C.  EMB Report No. 77-GAS-18.  November 1976.  87 p.
 These numbers correspond to the docket item number  in Docket  No.  A-79-52.
                               2-116

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II-A-17    Scott  Environmental  Technology,  Incorporated.   Gasoline
          Vapor  Recovery  Efficiency  Testing  Performed at the Phillips
          Fuel Company  Bulk  Loading  Terminal,  Hackensack, New Jersey.
          U.S. Environmental  Protection  Agency.   Research Triangle
          Park,  N.C.   EMB Report  No.  77-GAS-19.   October 1977.  47 p.

II-A-18    Polglase, W., et al.  Control  of Hydrocarbons  from Tank
          Truck  Gasoline  Loading  Terminals.   U.S.  Environmental  Protection
          Agency.   Publication No.  EPA-450/2-77-026.   October 1977.

II-A-23    The Research  Corporation  of New  England.   Report on Performance
          Test of  Vapor Control System at  the  Amoco  Terminal, Baltimore,
          Maryland.   U.S. Environmental  Protection Agency.   Philadelphia,
          Pennsylvania.   Contract No. 68-01-4145, Task 12.   September
          1978.   133  p.

II-A-24    The Research  Corporation  of New  England.   Report on Performance
          Test of  Vapor Control System at  Belvoir Terminal,  Newington,
          Virginia.   U.S. Environmental  Protection Agency.   Philadelphia,
          Pennsylvania.   Contract No. 68-01-4145.  September 1978.
          105 p.

II-A-25    The Research  Corporation  of New  England.   Report on Performance
          of Vapor Control  System at  Boron Terminal,  Coraopolis,
          Pennsylvania.   U.S.  Environmental  Protection Agency.
          Philadelphia, Pennsylvania.  Contract  No.   68-01-4145,  Task
          12. September  1978.  104  p.

II-A-26    The Research  Corporation  of New  England.   Report on Performance
          Test of  Vapor Control System at  British Petroleum  Terminal,
          Finksburg,  Maryland.  U.S.  Environmental Protection Agency.
          Philadelphia, Pennsylvania.  Contract  No.  68-01-4145,  Task 12.
          September 1978.  69  p.

II-A-27    The Research  Corporation  of New  England.   Report on Performance
          Test of  Vapor Control System at  the  Combined Citgo, Gulf,
          Texaco,  and Amoco  Terminals, Fairfax,  Virginia.  U.S.
          Environmental Protection  Agency.  Philadelphia, Pennsylvania.
          Contract No.  68-01-4145,  Task  12.   September 1978.  117 p.

II-A-28    The Research  Corporation  of New  England.   Report on Performance
          Test of  Vapor Control System at  Crown  Central  Terminal,
          Baltimore,  Maryland.  U.S.  Environmental Protection Agency.
          Philadelphia, Pennsylvania.  Contract  No.  68-01-4145,  Task
          12. September  1978.  125  p.

II-A-29    The Research  Corporation  of New  England.   Report on Performance
          Test of  Vapor Control System at  Texaco Terminal,  Coraopolis,
          Pennsylvania.   U.S.  Environmental  Protection Agency.
          Philadelphia, Pennsylvania.  Contract  No.  68-01-4145,  Task 12.
          September 1978.  80 p.
                               2-117

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II-A-32   Shedd, S.A., et al.   Control  of VOC Leaks from Gasoline Tank
          Trucks and Vapor Collection Systems.  U.S. Environmental
          Protection Agency.   Publication No. EPA-450/2-78-051.
          December 1978.

II-A-37   The Research Corporation of New England.  Report on Performance
          Test of HydroTech Carbon Bed Vapor Control System at Phillips
          Fuel Oil Terminal,  Hackensack, New Jersey.  U.S. Environmental
          Protection Agency.   New York, N.Y.  Contract No. 68-01-4145,
          Task 12.  April 1979.  215 p.

II-A-38   The Research Corporation of New England.  Report on Performance
          Test of Parker Hannifin, CRA Vapor Control System at Mobil
          Terminal, Paulsboro, New Jersey.  U.S. Environmental Protection
          Agency.  New York,  N.Y.  Contract No. 68-01-4145, Task 36.
          April 1979.  212 p.

II-A-39   The Research Corporation of New England.  Report on Performance
          of Gesco, CRC Vapor Control System at Sunoco Terminal,
          Newark, New Jersey.   U.S. Environmental Protection Agency.
          New York, N.Y.   Contract No. 68-01-4145, Task 36.  April
          1979.   141 p.

II-A-40   The Research Corporation of New England.  Report on Performance
          Test of Tenney Refrigeration Vapor Control System at Amerada
          Hess Terminal, Pennsauken, New-Jersey.  U.S. Environmental
          Protection Agency.   New York, N.Y.  Contract No. 68-01-4145,
          Task 36.  April 1979.  175 p.

II-A-41   The Research Corporation of New England.  Report on Performance
          Test of Tenney Refrigeration Vapor Control Systems at Exxon
          Terminal, Paulsboro, New Jersey.  U.S. Environmental Protection
          Agency.  New York,  N.Y.  Contract No. 68-01-4145, Task 36.
          April 1979.  185 p.

II-A-42   The Research Corporation of New England.  Report of Performance
          Test of Trico-Superior CRA Vapor Control  System at ARCO
          Terminal, Woodbury, New Jersey.  U.S. Environmental Protection
          Agency.  New York,  N.Y.  Contract No. 68-01-4145, Task 36.
          April 1979.  231 p.

II-A-43   The Research Corporation of New England.  Report on Performance
          Test of Edwards Refrigeration Vapor Control System at Tenneco
          Terminal, Newark, New Jersey.  U.S. Environmental Protection
          Agency.  New York,  N.Y.  Contract No. 68-01-4145, Task 36.
          April 1979.  171 p.

II-A-47   McCarthy, R.J.  Economic Impact of Vapor  Control Regulations
          on Bulk Storage Industry.  Arthur D. Little, Inc.  Publication
          No. EPA-450/5-80-001.  June 1979.
                               2-118

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II-A-50   Scott Environmental  Technology,  Inc.   Gasoline Vapor and
          Benzene  Control  Efficiency of Chevron Loading Terminal,
          Perth Amboy,  New Jersey.   U.S.  Environmental  Protection
          Agency.   Research Triangle Park,  N.C.  EMB No. 78-BEZ-5.
          May 1970.   166  p.

II-B-46   Memorandum  from Polglase,  W., Environmental  Protection
          Agency (CPDD),  to Helms,  G.T.,  Environmental  Protection
          Agency (CPDD).   September 19, 1979.   Summary of SIP VOC
          regulations.

II-B-54   Memorandum  from Norton,  R.L., Pacific Environmental Services,
          Incorporated  to Shedd,  S.,  Environmental  Protection Agency.
          August 22,  1980.  Trip  report to  Aminoil  terminal  in Stockton,
          Cal iform'a.

II-B-55   Memorandum  from Norton,  R.L., Pacific Environmental Services,
          Incorporated,  to Shedd,  S.,  Environmental  Protection Agency.
          August 22,  1980.  Trip  report to  Union Oil  terminal in Los
          Angeles,  California.

II-B-56   Memorandum  from Norton,  R.L., Pacific Environmental Services,
          Incorporated,  to Shedd,  S.,  Environmental  Protection Agency.
          August 22,  1980.  Trip  report to  Aminoil  terminal  in West
          Sacramento, California.

II-B-57   Memorandum  from Norton,  R.L., Pacific Environmental Services,
          Incorporated,  to Shedd,  S.,  Environmental  Protection Agency.
          August 22,  1980.  Trip  report to  Shell  Oil  terminal in Los
          Angeles,  California.

II-B-58   Memorandum  from Norton,  R.L., Pacific Environmental Services,
          Incorporated,  to Shedd,  S.,  Environmental  Protection Agency.
          August 22,  1980.  Trip  report to  SOHIO terminal  in Cuyahoga
          Heights  and Niles,  Ohio.

II-B-59   Memorandum  from Norton,  R.L., Pacific Environmental Services,
          Incorporated,  to Shedd,  S.,  Environmental  Protection Agency.
          August 22,  1980.  Trip  report to  STC  Corporation in Stockton,
          California.

II-B-61   Memorandum  from Norton,  R.L., Pacific Environmental Services,
          Incorporated,  to Shedd,  S.,  Environmental  Protection Agency.
          August 22,  1980.  Trip  report to  ARCO terminal in  Stockton,
          California.

II-D-41   Letter and  attachment from McGill,  G.,  HydroTech Engineering,
          Inc., to Shedd, S.,  Environmental  Protection Agency.  July 6,
          1977.  Comments on EPA  test of carbon adsorption unit.
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II-D-84   Letter from McGill, J.C., HydroTech Engineering, to Kleeberg,
          C.F.,  Environmental Protection Agency.   November 3, 1978.
          Comments on carbon adsorption units and carbon life.

II-D-118  Letter and attachments from McLaughlin, W.F., Husky Oil
          Company, to Goodwin, D.R., Environmental  Protection Agency.
          June 5, 1979.  Response to Section 114 letter on terminals.

II-D-121  Letter and attachments from Crane, R.E.,  Triangle Refineries,
          Incorporated, to Goodwin, D.R., Environmental Protection Agency.
          June 18, 1979.  Response to Section 114 letter on terminals.

II-D-122  Letter and attachments from McGirr, J.J., F.L. Roberts and
          Company, to Goodwin, D.R., Environmental  Protection Agency.
          June 21, 1979.  Response to Section 114 letter on terminals.

II-D-124  Letter and attachments from Woodard, D.E., Standard Oil Company
          (Ind.), to Goodwin, D.R., Environmental Protection Agency.
          June'25, 1979.  Response to Section 114 letter on terminals.

II-D-125  Same as Docket Item No. II-D-124 (Confidential information).

II-D-127  Letter and attachments from Karkalik, K.J., Standard Oil of
          Ohio,  to Goodwin, D.R., Environmental Protection Agency.
          July 5, 1979.  Response to Section 114 letter on terminals.

II-D-128  Letter and attachments from Bond, F.K., ARCO Petroleum
          Products, to Goodwin, D.R., Environmental Protection Agency.
          July 6, 1979.  Response to Section 114 letter on terminals.

II-D-129  Same as Docket Item No. II-D-128 (Confidential information).

II-D-130  Letter and attachments from Hooper, L.R., Marathon Oil
          Company, to Goodwin, D.R., Environmental  Protection Agency.
          July 13, 1979.  Response to Section 114 letter on terminals.

II-D-131  Letter and attachments from Martin, D.P., Gulf Oil Company,
          to Goodwin, D.R., Environmental Protection Agency.  July 24,
          1979.   Response to Section 114 letter on terminals.

II-D-132  Letter and attachments from Beall, F.J., Texaco, Incorporated,
          to Goodwin, D.R., Environmental Protection Agency.  July 30,
          1979.   Response to Section 114 letter on terminals.

II-D-133  Same as Docket Item No. II-D-132 (Confidential information).

II-D-134  Letter and attachments from Weber, G.H., Chevron U.S.A.,
          Incorporated, to Goodwin, D.R., Environmental Protection
          Agency.  August 9, 1979.  Response to Section 114 letter
          on terminals.
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II-D-135  Letter and  attachments  from  Richardson,  O.K.,  Mobil  Oil
          Company,  to Goodwin,  D.R.,  Environmental  Protection  Agency.
          August 14,  1979.   Response  to  Section 114 letter on  terminals.

II-D-136  Letter and  attachments  from  Sparveri, A.J.,  Automatic Comfort,
          Corporation,  to  Goodwin,  D.R.,  Environmental  Protection  Agency.
          August 16,  1979.   Response to  Section 114 letter on  terninals.

II-D-137  Same as Docket  Item  No.  II-D-136 (Confidential  information).

II-D-138  Letter and  attachments  from  Ada, A.E.,  Exxon  Corporation, to
          Goodwin,  D.R.,  Environmental Protection  Agency.   September 5,
          1979.   Response  to Section  114  letter on  terminals.

II-D-149  Letter and  attachments  from  Perry,  F.R.,  California  Air
          Resources Board,  to  Farmer,  J.R.,  Environmental  Protection
          Agency.  November 30,  1979.  Comments on  draft BID Volume I
          and  four  test reports.

II-E-34   Telecon.   Norton, R.L.,  Pacific Environmental  Services,
          Incorporated, with Pitruzello,  V.,  EPA Region  II,  February 6,
          1979.   Information on  new terminal  development in  Region II.

II-E-35   Telecon.   Collins, F.,  EPA Region  IV, with Norton, R.L.,
          Pacific Environmental  Services, Incorporated.   February  6,
          1979.   Information on  new terminals in Florida.

II-E-36   Telecon.   Norton, R.L.,  Pacific Environmental  Services,
          Incorporated, with Ikalainen,  B.,  EPA Region  I,  February 6,
          1979.   Information on  new terminals in Region  I.

II-E-37   Telecon.   Thayil, B.,  EPA Region V, with  Norton, R.L.,
          Pacific Environmental  Services, Incorporated.   February  7,
          1979.   Information on  new terminals in Region  V.

II-E-38   Telecon.   Sydmore, J.,  EPA  Region  III, with  Norton,  R.L.,
          Pacific Environmental  Services, Incorporated.   February  9,
          1979.   Information on  new terminals in Region  III.

II-E-41   Telecon.   Davidson,  I.W., Getty Oil, with Norton,  R.L.,
          Pacific Environmental  Services, Incorporated.   February  12,
          1979.   Information on  new terminal  construction.

II-E-42   Telecon.   Norton, R.L.,  Pacific Environmental  Services,
          Incorporated, with Yee,  D.,  EPA Region IX, February 12,
          1979.   Information on  new terminals in Region IX.

II-E-43   Telecon.   Norton, R.L.,  Pacific Environmental  Services,
          Incorporated, with Potter,  G.,  Exxon Company,  U.S.A.
          February 12, 1979.  Information on new terminal  construction.
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II-E-44   Telecon.  Norton, R.L., Pacific Environmental  Services,
          Incorporated, with Hooper, M., EPA Region X.  February 14,
          1979.  Information on new terminals in Region  X.

II-E-46   Telecon.  Wright, G., EPA Region VII, with Norton, R.L.,
          Pacific Environmental Services, Incorporated.   February 15,
          1979.  Information on new terminals in Region  VII.

II-E-47   Telecon.  Perry, A.W., Union Oil Company, with Norton, R.L.,
          Pacific Environmental Services, Incorporated.   February 15,
          1979.  Information on new terminal construction.

II-E-48   Telecon.  Wheeler, D., EPA Region VII, with Norton, R.L.,
          Pacific Environmental Services, Incorporated.   February 20,
          1979.  Information on new terminals in Region  VII.

II-E-49   Telecon.  Dougherty, C., Texaco, Incorporated, with Norton,
          R.L., Pacific Environmental Services, Incorporated.  March 1,
          1979.   Information on new terminal construction.

II-E-51   Teleconl  Norton, R.L., Pacific Environmental  Services,
          Incorporated, with Ruffing, J., Allegheny County BAPC.
          April 2, 1979.   Information on new terminals in Allegheny
          County.

II-E-68   Telecon.  Norton, R.L., Pacific Environmental  Services,
          Incorporated, with Bolsted, J., Montana Air Quality Board.
          June 7, 1979.   Information on method of loading at uncontrolled
          terminals.

II-E-69   Telecon.  Norton, R.L., Pacific Environmental  Services,
          Incorporated, with Anderson, A., Georgia Department of
          Natural Resources.   June 7, 1979.  Information on SIP coverage
          of terminals in  Georgia.

II-E-74   Telecon.  Edwards, R.C., Edwards Engineering,  with LaFlam,
          G.A., Pacific Environmental Services, Incorporated.  July  2,
          1979.   Information on costs and performance of refrigeration
          units.

II-E-75   Telecon.  Schmidt, E., Edwards Engineering, with LaFlam,
          G.A., Pacific Environmental Services, Incorporated.  July  3,
          1979.   Information on costs of carbon adsorption units.

II-E-79   Telecon.  LaFlam, G.A., Pacific Environmental  Services,
          Incorporated, with Welpe, B., Hunn Corporation.  July 11,
          1979.  Cost  information on installation of  vapor control
          systems.

II-E-85   Telecon.  Edwards, R., Edwards Engineering, with LaFlam,
          G.A., Pacific Environmental Services, Incorporated.  August 21,
          1979.  Information on capabilities of refrigeration units.
                               2-122

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II-E-93   Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Malek,  B.,  Petrochem Cons.,  Incorporated.
          October  16,  1979.   Provided  corrections to Section 114
          letter.

II-E-94   Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Maxwell,  S.,  HydroTech  Engineering.
          October  18,  1979.   Information on costs of carbon adsorption
          add-on units.

II-E-99   Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Schmidt,  E.,  HydroTech  Engineering.
          November  7,  1979.   Information on costs of carbon
          replacement  for  carbon  adsorption systems.

II-E-126  Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Beall,  F.J.,  Texaco, Incorporated.
          January  18,  1980.   Information on use  of open  splash  loading.

II-E-127  Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Percy,  A.W.,  Union  Oil  Company.   January 18,
          1980.   Information on use  of open splash loading.

II-I-69   Norton,  R.L.   Monitoring Procedures  for Fugitive  Hydrocarbon
          Emissions  from Gasoline  Tank Truck Loading.   Paper at  APCA
          73rd meeting,  Montreal,  Quebec.   June  22,  1980.

IV-A-2    Battye, W.,  et al.  Control  of Hydrocarbon Emissions  from
          Gasoline  Loading  by Refrigeration Systems.  U.S.  Environmental
          Protection Agency.  Publication  No.  EPA-600/7-81-121.
          July 1981.

IV-B-2    Memorandum from  Norton,  R.L.,  Pacific  Environmental  Services,
          Incorporated,  to  Shedd,  S.,  Environmental  Protection  Agency.
          March 23,  1981.   Trip report of  March  9, 1981, meeting with
          Bay Area  Air Quality Management  District regarding Edwards
          refrigeration  source test.

IV-B-4    Memorandum from  Norton,  R.L.,  Pacific  Environmental  Services,
          Incorporated,  to  Shedd,  S.,  Environmental  Protection  Agency.
          March 23,  1981.   Trip report to  ARCO terminal  for monitoring
          testing.

IV-B-6    Memorandum from  Norton,  R.L.,  Pacific  Environmental  Services,
          Incorporated,  to  Docket  A-79-52.   April 28,  1981.  Trip
          reports  to BP, Texaco,  and AMOCO terminals.

IV-C-9    Letter and attachments  from  LaFlam,  G.A.,  Pacific Environmental
          Services,  Incorporated,  to Smith, W.S., Entropy  Environmentalists,
          February  19, 1981.  Summary  of meeting held  February 9,
          1981, regarding  vapor recovery at bulk terminals.
                               2-123

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IV-D-15   Letter from Bierck, R.C., Dean Brothers Pumps, Incorporated,
          to Shedd, S.A.,  Environmental  Protection Agency.   February 18,
          1981.  Information on pump performance.

IV-D-47   Letter and attachments from McDaniel, R.R., Southern Pacific
          Pipe Lines, to LaFlam, G.A., Pacific Environmental Services,
          Incorporated.  April 2, 1981.   Information on operating data
          for vapor recovery units.

IV-D-48   Letter and attachments from Bossi, F.R., Calgon Corporation,
          to LaFlam, G.A., Pacific Environmental  Services,  Incorporated.
          April 8, 1981.  Information on various control technologies.

IV-D-49   Letter and attachments from Kaitschuck, J., John  Zink Company,
          to LaFlam, G.A., Pacific Environmental  Services,  Incorporated.
          April 15, 1981.   Information on carbon adsorption unit.

IV-D-51   Letter and attachments from Schmidt, E.L., McGill, Incorporated,
          to Norton, R.L., Pacific Environmental  Services,  Incorporated.
          April 30, 1981.   Information on prices and power consumption
          for vapor processors.

IV-D-54   Letter and attachments from Surla, E., Indiana State Board
          of Health, to Gschwandtner, K.C., Pacific Environmental
          Services, Incorporated.  March 30, 1981.  Performance and
          compliance test results.

IV-D-55   Letter and attachments from St. Louis, R., Pennsylvania
          Department of Environmental Resources, to Gschwandtner,
          K.C., Pacific Environmental Services,  Incorporated.  May 27,
          1981.  Performance and compliance test results.

IV-D-56   Letter and attachments from Weinberg,  B.D., Ohio Environmental
          Protection Agency, to Gschwandtner, K.C., Pacific Environmental
          Services, Incorporated.  June 4, 1981.  Performance and
          compliance test results.

IV-D-57   Letter and attachments from St. Louis, R., Pennsylvania
          Department of Environmental Resources, to Gschwandtner,
          K.C., Pacific Environmental Services,  Incorporated.  June 12,
          1981.  Performance and compliance test results.

IV-E-3    Telecon.  LaFlam, G.A., Pacific Environmental Services,
          Incorporated, with Edwards, R., Edwards Engineering Corporation.
          February 23, 1981.  Information on refrigeration units.

IV-E-10   Telecon.  LaFlam, G.A., Pacific Environmental Services,
          Incorporated, with Bierck, R., Dean Brothers  Pumps, Incorporated,
          March 4, 1981.  Information on Dean Brothers  pumps.
                               2-124

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IV-E-11   Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Perry,  F.R.,  California Air Resources
          Board.   March  6,  1981.   Information  on  bottom  loading vapor
          balance  emission  factor.

IV-E-12   Telecon.   Norton,  R.L.,  Pacific  Environmental  Services,
          Incorporated,  to  Stoddard,  B., Shell  Oil  Company.   March 18,
          1981.   Clarification  of  Shell  comment on  recommended control
          unit monitoring program.

IV-E-18   Telecon.   Bossi,  F.R., Calgon  Corporation, with LaFlam,
          G.A.,  Pacific  Environmental  Services, Incorporated.
          April  3,  1981.  Information  on overheating of  carbon adsorption
          units.

IV-E-20   Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Kaitschuck, J., John Zink Company.
          April  14,  1981.   Information on  carbon  adsorption  units.

IV-E-22   Telecon.   Gschwandtner,  K.C.,  Pacific Environmental  Services,
          Incorporated,  with Todd,  J., Heil  Company.  April  14, 1981.
          Information  on tank truck  conversion  costs.

IV-E-23   Telecon.   Gschwandtner,  K.C.,  Pacific Environmental  Services,
          Incorporated,  with Mr. Glidden,  Tennile Company.   April 15,
          1981.   Information on tank truck conversion costs.

IV-E-24   Telecon.   Gschwandtner,  K.C.,  Pacific Environmental  Services,
          Incorporated,  with Hemphill, R., Fruehauf Corporation.
          April  20,  1981.   Information on  tank  truck conversion costs.

IV-E-25   Telecon.   Gschwandtner,  K.C.,  Pacific Environmental  Services,
          Incorporated,  with Botkin,  L., Fruehauf Corporation.
          April  20,  1981.   Information on  tank  truck conversion costs.

IV-E-26   Telecon.   Gschwandtner,  K.C.,  Pacific Environmental  Services,
          Incorporated,  with Ritterbush, J., J  &  L  Tanks.  April  20,
          1981.   Information on tank truck conversion costs.

IV-E-29   Telecon.   Zanitsch, R.,  Calgon Corporation, with  LaFlam,
          G.A.,  Pacific  Environmental  Services, Incorporated.   April
          22,  1981.  Information on  carbon  adsorption units.

IV-E-30   Telecon.   Norton,  R.L.,  Pacific  Environmental  Services,
          Incorporated,  with McGill, J., McGill,  Incorporated.   April
          23,  1981.   Information on  carbon adsorption units.

IV-E-32   Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Edwards,  R.,  Edwards Engineering Company.
          April  28,  1981.   Information on  refrigeration  units.

IV-E-33   Telecon.   LaFlam,  G.A.,  Pacific  Environmental  Services,
          Incorporated,  with Welpe,  B.,  Hunn Corporation.  April  29,
          1981.   Information on cost of  loading rack conversions.

                               2-125

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IV-E-36   Telecon.  Schmidt, E., McGill, Incorporated, with Norton,
          R.L., Pacific Environmental  Services, Incorporated.
          April 30, 1981.  Information on carbon adsorption units.

IV-E-38   Telecon.  Lowery, E., ARCO,  with LaFlam, G.A., Pacific
          Environmental Services, Incorporated.  May 5, 1981.  Information
          on maintenance and electrical costs of Edwards DE Model
          refrigeration unit.

IV-E-39   Telecon.  LaFlam, G.A., Pacific Environmental Services,
          Incorporated, with Ottoson,  R.S., Ray Construction Company,
          Incorporated.  May 6, 1981.   Information on design and costs
          associated with loading rack conversions.

IV-E-40   Telecon.  LaFlam, G.A., Pacific Environmental Services,
          Incorporated, with Ogden, J., Union Oil Company.  May 7,
          1981.   Information on maintenance costs of carbon adsorption
          units.

IV-E-41   Telecon.  Norton, R.L., Pacific Environmental Services,
          Incorporated, with Stahl, R., AMOCO Oil Company.  May 7,
          1981.   Information on maintenance costs of carbon adsorption
          units.

IV-E-42   Telecon.  Norton, R.L., Pacific Environmental Services,
          Incorporated, with Dale, A., Phillips Petroleum Company.
          May  8,  1981.   Information on operating and maintenance costs
          of carbon adsorption units.

IV-E-43   Telecon.  Norton, R.L., Pacific Environmental Services,
          Incorporated, with Durbin, R., AMOCO Research.  May 11,
          1981.   Information on sight  glasses  installed on carbon
          adsorption units.

IV-E-45   Telecon.  Deardorff, K., JACA Corporation, with Moorehead,
          A.,  Federal  Energy Regulatory Commission.  May 19, 1981.
          Information  on price pass through for pipelines.

IV-E-46   Telecon.  Deardorff, K., JACA Corporation, with Sado, J.,
          Interstate Commerce  Commission.  May 19, 1981.  Information
          on price pass through for independent tank truckers.

IV-E-52   Telecon.  Lorden, J., Phillips Petroleum Company, with LaFlam,
          G.,  Pacific  Environmental Services,  Incorporated.  September 22,
          1981.   Cost-effectiveness of SIP controls at  bulk terminals.

IV-E-53   Telecon.  Durbin, R., AMOCO  Research, with LaFlam, G.,
          Pacific Environmental Services, Incorporated.  September 28,
          1981.   Field experience and  technical problems with carbon
          adsorption units.

IV-E-54   Telecon.  Norton, R.L., Pacific Environmental Services,
          Incorporated, with Jones, K., California Air  Resources
          Board.  November 5,  1981.  Discussion of bulk terminal
          tests.
                               2-126

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IV-J-1    California Air Resources  Board.   Certification Evaluation
          Report No.  C-9-021  of  Edwards  Vapor Recovery Unit.   May 1979.

IV-J-2    California Air Resources  Board.   Certification Evaluation
          Report No.  C-9-072  of  McGill  Vapor Recovery Unit.   May 1980.

IV-J-3    California Air Resources  Board.   Certification Evaluation
          Report No.  C-9-073  of  McGill  Vapor Recovery Unit.   May 1980.

IV-J-4    California Air Resources  Board.   Certification Evaluation
          Report No.  C-80-034 of Edwards  Vapor Recovery Unit.   June
          1980.

IV-J-5    California Air Resources  Board.   Certification Evaluation
          Report No.  C-9-058  of  Hirt Vapor  Recovery Unit.   August
          1980.

IV-J-6    California Air Resources  Board  (CARB)  proceedings  on vapor
          recovery  consultation  meeting.  March  17, 1978.   CARB staff
          report on public  hearing  to revise suggested vapor  recovery
          rules. July  27,  1978.

IV-J-8    Edwards Engineering Corporation.   Hydrocarbon vapor recovery
          units  price list.   January 1,  1981.

IV-J-10   Marketplace at a  Glance.   National  Petroleum News.   73(4).
          April  1981.

IV-J-15   API  Bulletin  on Evaporation Loss  from  Tank Cars,  Tank Trucks,
          and  Marine Vessels.  American  Petroleum  Institute.   API
          Bulletin   2514.  November 1959.

IV-J-16   California Air Resources  Board.   Certification Evaluation
          Report No.  C-80-047 of McGill  Vapor Recovery Unit.   June 1980.

IV-J-17   LaFlam, G.A.,  Osbourn,  S.,  and  Norton, R.L.   Documentation
          for  AP-42 Emission  Factors: Section 4.4  Transportation
          and  Marketing  of  Petroleum Liquids.   U.S. Environmental
          Protection Agency.   Research  Triangle  Park,  N.C.  May 1982.

IV-J-21   Bottom Loading and  Vapor  Recovery for  MC-306 Tank Motor
          Vehicles.  American Petroleum  Institute.  API RP  1004.
          September 1,  1977.
                               2-127

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       APPENDIX A





EMISSION SOURCE TEST DATA
         A-l

-------
                APPENDIX A - EMISSION SOURCE TEST DATA

A.I  INTRODUCTION
     A major group of the comments received after proposal of the
standards questioned the adequacy of the emission test data which
served as the basis for the selected emission limit of 35 milligrams
of TOC per liter of gasoline loaded.  Commenters claimed that:  state-of-
the-art control equipment was not represented in the testing  (Section 2.6.1);
the systems selected as best available technology have not been adequately
demonstrated (Section 2.6.3); certain technologies show marginal
performance or have operating problems which make them unsuitable
choices (Sections 2.6.7, 2.6.8, and 2.6.10); and additional test data
should be collected (Section 2.6.6).
     Although the test data presented at the time of proposal are
considered adequate to support the selected limit, the Agency has
continued to collect results of recent testing in order to obtain the
largest possible data base.  The intent was to review these recent
tests of the current generation of vapor processors in order  to verify
their performance under a broader range of operating conditions.
Additional test data on the carbon adsorption, refrigeration, and
thermal oxidation type systems were obtained from State pollution
control agencies, oil companies, and a control unit manufacturer.
Section A.2 presents these data and discusses the results  in  terms  of
the 35 mg/liter emission limit.
A.2  SUMMARY OF ADDITIONAL TEST ACTIVITY
     Results of tests performed between 1979 and 1981 to demonstrate
compliance with SIP requirements are presented in Table A-l.  These
test results were not available to EPA until after Appendix C of BID,
                                A-2

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Table A-l.  BULK TERMINAL EMISSION TEST DATA SUMMARY
Test
ID No.
1
la
~\
i.
3
4
5
6
71
31
91
10
11
12
13
14
15
16
17
18
19
20
21
22i
23
24
25
26
271
23
29
30
31
32
33
34
35
36
37
38
39
Test
Date
6/6/79
9/21/79
4/29-30/80"1
5/21-22/80"1
7/8/80
7/9/80
7/10/80
7/80
8/80
9/80
9/16/80
9/17/80
9/17/80
9/22/80
9/26/80
9/29/80
10/1/80
10/1/80
10/2/80
10/3/80
10/6/80
10/10/80
10/80
11/12/80
11/13/80
11/14/80
12/9/80
1/6/81
1/8/81
2/2/81
2/6/81
2/11/81
1/22/81
2/04/81
5/29-30/80m
3/26/81
2/19-20/811"
5/13-14/80m
12/16/80
1/20/81
Control
Unit3
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
REF
REF
REF
T0k
' TO
TO
Volume
Loaded .
(liters)0
100.5506
n
701,650s
2,469,900s
421, 5009
439, 2009
375, ISO9
h
h
h
243,200e
132.5006
194,100e
124,800s
488,200s
1,223,200s
387,700s
223,600s
367,150s
728,150s
834,850s
63,900s
h
172,200s
265,350s
174,900s
202,500s
443,200e
165,800s
102,950s
184,700s
136, 6509
613,000s
306,950s
784,550s
1,006,000s
1,288,200s
2,353,700s
205,200s
162, 5509
Inlet
CC
41. 7f
h
h
h
h
3.3
3.0
14.0
5.7
6.3
23.6
20.1
11.1
6.74
8.37
4.86
6.63
h
h
6.22
5.93
8.0
6.4
h
h
h
h
h
19.2
27.7
22.8
20.0
19.7
30.2
h
h
h
h
h
h
Outlet
Cc
0.64f
0.30
0.30
0.30
0.24
0.15
0.19
h
h
h
0.05
0.01
0.02
0.05
0.25
0.86
0.19
0.17
2.25
0.39
0.12
0.13
h
0.44
0.51
0.50
0.51
h
0.10
0.05
0.05
0.05
0.05
0.05
1.40
1.75
1.45J
2 ppm
Negl.
Negl.
Control
Efficiency
(percent)
99.0
90.3
h
h
h
95.6
94.0
h
h
h
99.6
99.9
99.8
99.3
97.3
83.2
97.3
h
h
94.1
98.0
98.5
h
h
h
h
h
h
99.5
99.9
99.8
99.8
99.8
99.9
h
h
h
99
h
h
Processor
Emissions .
(ng/1iterr
5.9
h
6.9
7.9
6.0
6.2
7.9
5.9
4.2
8.4
1.2
0.34
0.42
0.66
4.5
15.6
6.3
1.8
17.9
11.0
2.3
5.0
13.1
4.8
5.6
4.5
7.7
1.7
7.5
1.6
1.6
5.2
1.5
1.2
21.9
22.6
41.8
1.2
0.-20
0.22
Docket
Item
Reference
IV-D-54
IV-D-54
IV-J-2
IV-J-3
IV-D-56
IV-D-56
IV-D-56
IV-D-38
IV-D-38
IV-D-38
IV-D-49
IV-D-49
IV-0-49
IV-D-56
IV-D-38,56
IV-D-56
IV-D-38,56
IV-D-GO
IV-D-60
IV-D-38,56
IV-D-56
IV-D-56
IV-D-38
IV-D-57
IV-D-57
IV-D-57
IV-D-60
IV-D-55
IV-D-60
IV-D-60
IV-D-60
IV-D-60
IV-D-60
IV-D-57, 60
IV-J-4
IV-D-57
IV-B-2
IV-J-5
IV-D-60
IV-D-57
                      A-3

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                          NOTES FOR TABLE A-l
aCA  - Carbon Adsorption.
 REF - Refrigeration.
 TO  - Thermal Oxidation.


 Total volume of all products or gasoline only actually loaded during
 test period.


GVolume percent TOC concentration as propane, except as noted.


 Mass emissions in terms of gasoline volume loaded where known;
 otherwise, in terms of all products loaded.


eTotal products loaded, or not determinable from test report.


 Weight percent of total hydrocarbons.


^Volume of gasoline loaded.


hNo data.


^o test report available.


^Volume percent TOC concentration as butane.

\,
 Compression-oxidation  type system.


m24-hour test.
                                A-4

-------
Volume I (Emission Source Test Data) was prepared.   Thus,  the results
could not be considered as background information  for  the  proposed
standards.   While these data were not used to determine  the emission
limit which represents the performance of the best  available systems,
they have served as additional information against  which  to compare
and evaluate the selected limit.
     None of these recent tests was performed by  EPA,  and  only the
test reports are available as information sources.   Details regarding
test methods, conditions at the terminals, and methods of  calculation
are often incomplete.  However, enough information  is  presented  for
most of the test results to be evaluated in terms  of the  test methods
and procedures developed for use by new sources under  the  NSPS.   For
many of the tests, results were adjusted to correspond to  the NSPS
reporting criteria.  All throughputs in Table A-l  are  reported as the
volume of gasoline loaded during the test, where  this  information was
available,  and emission levels are reported in terns of  this quantity.
Thus, some of the data in Table A-l differ from the values  contained
in the test reports.
     The following subsections contain brief discussions  of the  tests
in Table A-l, including an evaluation of the reliability  of the  data.
A more detailed evaluation has been prepared by EPA's  Emission Measurement
Branch (IV-B-10).
A.2.1  Test Data Evaluation
     Some of the test reports indicate only slight  deviations from the
NSPS test procedures (which are a combination of Methods  2A, 2B,  21, 25A,
25B, and 27), and thus the results are considered  essentially acceptable.
However, in other cases, very different test procedures  were used,
introducing a bias and uncertainty regarding several of  the measured
and calculated results.  Where possible, the extent of bias was  estimated,
and a determination was made as to the applicability of  the tests as
supporting information.  The individual tests are  discussed briefly in
the following subsections, grouped according to the party which  performed
the tests,  since each party used the same testing  approach  for all of
its tests.
     A.2.1.1  Tests by Firm A.  Firm A conducted  terminal  test nos. 4,
5, 6, 13, 14, 15, 16, 19, 20, and 21 on CA units  at eight terminals

                                A-5

-------
during the summer and fall of 1980 (test nos. 4, 5, and 6 were conducted
at the same terminal on consecutive days).  Deviations from the NSPS
procedures probably introduced a certain amount of bias into the
results.
     Since no information about the terminal and processor operating
conditions is given in the reports, it is impossible to determine the
representativeness  of the testing or the relative load on the processor
during testing.  Gasoline throughput in test nos. 13 and 21 was
considerably less than the recommended 300,000 liters.  Each test was
conducted for 8 hours.
      In measuring outlet TOC concentrations, instrument calibrations
were  performed less frequently than recommended, reducing confidence
in  the accuracy of  the measurements.  Reduction of strip chart data
included  time periods when no loading was taking place, which would
tend  to bias the results  low.  Outlet volumes were determined using
nonstandard methods.
      The  reports for  these tests are well-documented and contain
sufficient  information to allow thorough report evaluations.  In spite
of  probable  low biases in reported results,  if the outlet concentration
were  determined correctly, the mass emission rate from all of these CA
systems would likely  be below 35 mg/liter.
      A.2.1.2  Tests by Firm  B.  Firm B conducted test nos. 27, 28, 29,
30, 31, 32,  and 33  on CA  systems at seven terminals during January and
February  of  1981.   Deviations from NSPS procedure and lack of detailed
documentation reduce  confidence in these test results.
      Insufficient  information is provided to determine the
representativeness  of the terminal and processor operation during
testing.  Several  tests  (four out of seven)  do not satisfy the 300,000  liter
minimum throughput  requirement.  Documentation is not sufficient to
determine whether Method  25B calibration  procedures were used.  Also,
no-loading  periods  were apparently averaged  into the time averages of
outlet TOC concentration, biasing the results low.
      An air-balance procedure was used to determine the outlet gas
volume used  in calculating the mass emission rate.  This nonstandard
procedure is not comparable  to the recommended method (2A), and the
results are questionable.

                                A-6

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     Reported outlet emissions range between 1.2 and 7.5 ing/liter.
Even if the reported outlet TOC concentration values (0.05 percent)
were low by a factor of 10 to 20, the outlet emissions in these tests
would still most likely be below 35 mg/liter.
     A.2.1.3  Tests by Firm C.  Firm C conducted test nos. 1, 17, 18,
23, 24, 25, 26, 38, and 39 at nine terminals.  The first seven tests
were on CA type units; test nos. 38 and 39 were on TO type units.  As
in the tests discussed previously, several deviations from NSPS procedures
and reference methods lead to uncertainties regarding the accuracy of
the reported test results.
     Since no information is provided about the terminal  or vapor
processor operations during the tests, the representativeness of the
testing cannot be determined.  Most of the 1-day tests did not meet
the throughput criterion, but the combined throughputs during the
3-day test (test nos. 23, 24, and 25) and the 2-day test (test nos. 17
and 18) constitute a sufficient business volume for a meaningful  test.
     The methods used to measure outlet volume are not documented, and
so the values cannot be accepted as accurate.  Concentration values
are similarly unacceptable because of the apparent large deviations
from recommended procedures.  However, if the concentration values are
accepted as accurate within ±100 percent, all of the tests except test
no. 18 would probably demonstrate compliance with the 35 mg/liter
limit.
     A.2.1.4  Tests by Firm D.  Four bulk terminal vapor processors
were tested by Firm D: two CA units (test nos. 2 and 3),  one REF unit
(test no. 34), and one TO unit (test no. 37).  These tests were conducted
to determine compliance with the California limit of 0.6 lb/1000 gallons
(72 mg/liter).  The description given of the terminal and processor
operations allows an evaluation to be made regarding the represen-
tativeness of the testing.  The written procedure of the California
Air Resources Board (CARB), which is similar to the NSPS procedure,
was followed in these tests.
     All four tests exceed the 300,000 liter throughput criterion.
However, the tests were conducted for 24 hours, and the low business
volume hours were included, probably biasing the results low.  Also,
the instrument specifications and the calibration procedure, which are

                                A-7

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not as strict as the recommended procedure, reduce confidence in the
results.  Finally, mass emissions were calculated using 24-hour average
values, instead of the 5-ninute averages specified in the NSPS procedure.
This would usually bias the results low.
     Mass emission rates in all tests were considerably below the
35 mg/liter  limit, and even with some low bias accounted for, test
nos. 2, 3, and 37 would still likely meet this limit.
     A.2.1.5  Other Tests.  Test no. la was conducted by Firm E on a
CA unit.  This test was an efficiency test, and emissions in units of
mg/liter  were not determined.  The test was short-term (3.5 hours,
with 41 minutes of loading time), and an air-balance procedure was
used.   However, if outlet TOC concentrations were measured correctly.
the processor would probably meet the 35 mg/liter limit.
     Test nos. 10, 11, and 12 were conducted by Firm F on a CA unit at
one terminal.  These three 1-day tests  (9, 5, and 8 hours, respectively)
are well-documented, allowing a thorough evaluation of the results to
be made.  The NSPS procedure was generally followed, and the results
are considered acceptable.  However, reported outlet TOC concentrations
are considered to be too low, since they are below the lowest detectable
limit  of  the Horiba PIR-2000 NDIR detector used to measure outlet
concentration.  The processor would likely meet the limit of 35 mg/liter,
even  if true concentrations were 0.5 to 1.0 percent, an increase of
10 to  20  fold above the reported outlet concentrations.
     Test no. 35 was performed by Firm  F on a dual refrigeration unit.
The test  procedure is  generally similar to the NSPS procedures, although
detailed  calibration documentation  is not  provided.  The results are
considered acceptable, with the processor  shown to be attaining the
35 mg/liter  1imit.
     Test no. 36 was performed by Firm  G on a dual refrigeration
system.   Although documentation is  not  complete, the CARB procedure
was most  likely followed, and so the results can be marginally accepted.
This processor slightly exceeded the 35 mg/liter limit.
     The  results for test nos. 7, 8, 9, and 22 were received by EPA in
tabular form, without  any test reports  or  supporting documentation.
Since  no  documentation is presently available to EPA, the results  of
these  four tests, all  of which indicated emissions below 35 mg/liter

                                A-8

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for CA systems, are not acceptable as supporting  information  for  the
emission limit of the new source standards.
A.3  CONCLUSIONS
     The nominal emission results reported to the States  in these
tests are seen to be considerably below the limit of 35 mg/liter.
Lven after a consideration of the low bias which  appears  to exist  in
most tests,  the results most likely still  substantiate the selected
limit.  As in the tests performed by EPA and reported in  Appendix  C of
BID, Volume I, these recent State tests were performed on vapor processors
designed to comply with State limits of 72 to 80 mg/liter.  State-of-
the-art CA and TO processors designed for State limits routinely
achieve emission levels below 35 mg/liter.  Manufacturers' claims  and
theoretical  analyses indicate that REF processors can be  designed,
sized, and operated for improved performance over currently installed
systems.  Many current REF systems are achieving the 35 mg/liter
1imit.
                                A-9

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A.4  REFERENCES

IV-B-2    Memorandum  from Norton,  R.L.,  Pacific  Environmental  Services,
          Incorporated,  to  Shedd,  S.,  Environmental  Protection Agency.
          March  23,  1981.   Trip  report of March  9,  1981,  meeting with
          Bay Area Air  Quality Management District  regarding Edwards
          refrigeration  source test.

IV-B-10   Memorandum  from Mclaughlin,  N.D.,  Emission Measurement Branch,
          EPA,  to Ajax,  R.L.,  and  Colyer, R.,  Standards Development Branch,
          EPA.   February 19,  1982.   Review of  Terminal  Test Reports.

IV-D-38   Letter and  attachments from  Karkalik,  E.J., The Standard Oil
          Company of  Ohio,  to  Colyer,  R., Environmental Protection
          Agency.  March 13,  1981.   SOHIO comments  and enclosed exhibit
          emission test reports.

IV-D-49   Letter and  attachments from  Kaitschuck,  J., John Zink Company,
          to LaFlam,  G.A.,  Pacific Environmental Services, Incorporated.
          April  15,  1981.   Information on carbon adsorption unit.

IV-D-54   Letter and  attachments from  Surla,  E., Indiana State Board
          of Health,  to Gschwandtner,  K.C.,  Pacific Environmental
          Services,  Incorporated.   March 30,  1981.   Performance and
          compliance test results.

IV-D-55   Letter and attachments from  St. Louis, R., Pennsylvania
          Department of Environmental  Resources, to Gschwandtner, K.C.,
          Pacific  Environmental  Services, Incorporated.  May 27, 1981.
          Performance and compliance test results.

IV-D-56   Letter and attachments from  Weinberg,  B.D., Ohio Environmental
          Protection Agency,  to  Gschwandtner,  K.C., Pacific Environmental
          Services,  Incorporated.   June 4, 1981.  Performance and
          compliance test results.

IV-D-57   Letter and attachments from  St. Louis, R., Pennsylvania
          Department of Environmental  Resources, to Gschwandtner, K.C.,
          Pacific  Environmental  Services, Incorporated.  June 12,
          1981.  Performance and compliance test results.

IV-D-60   Letter and attachments from  St. Louis, R., Pennsylvania
          Department of Environmental  Resources, to Gschwandtner, K.C.,
          Pacific  Environmental  Services, Incorporated.  July 16,
          1981.  Performance test reports.

IV-J-2    California Air Resources Board.  Certification Evaluation
          Report No.  C-9-072 of  McGill Vapor Recovery Unit.  May 1980.


  These numbers  correspond to the docket  item number  in Docket
  No. A-79-52.

                                 A-10

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IV-J-3    California  Air Resources  Board.   Certification Evaluation
          Report No.  C-9-073 of McGill  Vapor Recovery Unit.  May 1980,

IV-J-4    California  Air Resources  Board.   Certification Evaluation
          Report No.  C-80-034 of Edwards  Vapor Recovery Unit.   June
          1980.
IV-J-5    California  Air Resources  Board.   Certification Evaluation
          Report  No.  C-9-058 of Hirt Vapor Recovery Unit.   August
          1980.
                                A-ll

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       APPENDIX B





COST AND ECONOMIC IMPACTS
         B-l

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                APPENDIX B - COST AND ECONOMIC  IMPACTS

B.I  INTRODUCTION
     Both cost and economic analyses of various regulatory alternatives
were presented in Sections 8.2 and 8.4 of BID,  Volume I.  Most of the
cost estimates were made in 1979, and all costs were converted to
the equivalent of mid-1979 dollars, generally using the  "Chemical
Engineering Plant Cost Index."  This was necessary so that all costs
could be compared on the basis of monetary units of equal value.
     When the regulation was proposed in December 1980,  several  commenters
remarked that many of the costs were out-of-date and/or  underestimated.
Principal among these were vapor processor purchase, installation,
operating, and maintenance costs (see Section 2.5.3 of this document);
loading  rack and tank truck conversion and testing costs  (Sections  2.5.3,
2.5.4, and 2.5.5); and total costs to industry  (Section  2.5.1).   It is
clear that costs estimated during a particular  time period are likely
to appear low at some later period, especially  during highly  inflationary
times.   In order to respond to the comments  concerning costs, all of
the principal cost figures were re-evaluated  in order to  retain  the
ability  to make valid cost comparisons.  Section B.2 presents updated
control  costs, and Section B.3 discusses the  effect which these  costs
have on  industry economic  impacts.
B.2  CURRENT CONTROL COST ESTIMATES
B.2.1  Model Plant Costs
     Tables 8-31 and 8-34 of BID, Volume I,  were revised  to produce
two new  tables containing current control costs for the  four  model
plants.  Table B-l presents the costs to comply with the standards  for
new and  existing bottom-loaded terminals in  areas with no SIP regulation.
While the costs to an existing facility  affected by the  standards may
be slightly more than to a new facility, the  higher costs are presented
and presumed to apply in both cases.  Table  B-2 presents  costs for  an
existing top-loaded terminal in an area with  no SIP control.  This
type of  terminal would incur additional  costs over a bottom-loaded
                                 B-2

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Table B-l.   ESTIMATED CONTROL COSTS -  NEW  AND  EXISTING  BULK  TERMINALS
                     BOTTOM LOADED, NO SIP CONTROL
               (Thousands of First Quarter 1981  Dollars)









CO
1
CO










.Q^soJ !_'!§. Throughput:
Vapor Processing Uni t:

Capital Investment
Uni t Purchase Cost
Urii t Installation Cost
Continuous Monitor
Truck Vapor Recovery Cost
Annual Operating Costs
Electricity
Propane (Pilot)1
Carbon Replacement
Maintenance
Operating Labor
Compl iance Cost
Subtotal (Direct Operating Cost)
Truck Maintenance
Capital Charges^
Gasoline Recovery (Credit)''
Net Annual ized Cost
Total VOC Controlled (Mg/yr)'
f.ost-t tfect iveness ($/kg)
380,000 //day
CAa T0l) REFC


128 108 134
109 91.8 114
13.0 15.0 13.0
9.0 9.0 9.0
6.6 3.0 19.1
	 3.0 	
1.2 	 	
5.7 4.9 6.0
5.1 5.1 5.1
5.7 6.2 5.7
24.3 22.2 35.9
0.9 0.9 0.9
61.5 52.2 64.2
(28.2) -- (28.2)
58.5 75.3 72.8
65.2 65.2 65.2
0.90 1.15 1.12
950,000 //day
CAd T0b REFC


155 118 138
132 100 117
13.0 15.0 13.0
18.0 18.0 18.0
9.8 7.7 21.6
5.4 	
1.8 	
7.0 5.5 6.3
5.1 5.1 5.1
5.7 6.2 5.7
29.4 29 . 9 38 . 7
1.8 1.8 1.8
76.2 59.0 68.2
(70.6) -- (70.6)
36.8 90.7 38.1
163 163 163
0.23 0.56 0.23
1,900,000 //day
CAd 10b RCFC


163 118 138
139 100 117
13.0 15.0 13.0
27.0 27.0 27.0
15.1 14.3 21.6
	 9.9 	
1.8 	 	
7.3 5.5 6.3
5.1 5.1 5.1
5.7 6.2 5.7
35.0 41.0 38.7
2.7 2.7 2.7
82.2 61.2 70.5
(141) -- (Ml)
-21.1 105 -29.1
326 326 326
U) 0.32 (s)
3,800,000 //day
CAd mb RtFC


210 122 1/6
179 104 150
13.0 15.0 13.0
60.0 60.0 60.0
28.3 27.3 28.6
	 13.0 	
9.4 5.9 8.0
5.1 5.1 5.1
5.7 6.2 5.7
50.6 57.5 4/4
6.0 6.0 6.0
112 71.5 96.5
(282) -- (2H/)
-113 1 i'j -M2
652 652 652
(s) 0.21 (s)

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                          Table B-2.  ESTIMATED CONTROL COSTS - EXISTING BULK TERMINALS
                                            TOP LOADED, NO SIP CONTROL
                                     (Thousands of First Quarter 1981 Dollars)
DO
Gasoline Throughput:
Vapor Processing Unit:
._ _ .
Capital 1 lives tment
Unit I'urthase Cost
Uni t Instal In t ion Cost
Continuous Moni tor
Rack Conversion Cost
[ruck Conversion Cosl^
Annual Operating Costs
Electricity1'
Propane (Pilot)1
Carbon Replacement^
Maintenance
Opera tint) tabor
Compl iance Cost
Subtotal (Direct Opera tiny Cost)
[ruck Maintenance
Capital Charges''
Gasoline Recovery (Credit)^
Net Annual ized Cost
Total VOC Controlled (Mg/yr)'
Cost-Effectiveness ($/kg)
300,000 //day
CAa T0b REFC

128 100 134
109 91.0 114
13.0 15.0 13.0
400 400 400
19.2 19.2 19.2
6.6 3.0 19.1
3.0 	
1.2 — 	
5.7 4.9 6.0
5.1 5.1 5.1
5.7 6.2 5.7
24.3 22.2 35.9
0.9 0.9 0.9
164 155 167
(20.2) -- (28.2)
161 178 176
65.2 65.2 65.2
2.47 2.73 2.69
950,000 //day
CAa T0b REFC

155 118 138
132 100 117
13.0 15.0 13.0
600 600 600
38.4 38.4 38.4
9.8 7.7 21.6
5.4 	
1.8 	
7.0 5.5 6.3
5.1 5.1 5.1
5.7 6.2 5.7
29.4 29.9 38.7
1.8 1.8 1.8
231 214 223
(70.6) -- (70.6)
192 246 193
163 163 163
1.18 1.51 1.18
1,900,000 //day
CAa TO5 REFC

163 118 138
139 100 117
13.0 15.0 13.0
600 600 600
57.6 57.6 57.6
15.1 14.3 21.6
	 9.9 	
1.8 	 	
7.3 5.5 6.3
5.1 5.1 5.1
5.7 6.2 5.7
35.0 41.0 30.7
2.7 2.7 2.7
240 219 220
(141) -- (141)
137 263 128
326 326 326
0.42 0.81 0.39
3,800.000 //day
CAa T0b RFFC

210 122 1/6
179 104 150
13.0 15.0 13.0
800 800 000
128 120 120
28.3 27.3 28.6
	 13.0 	
2.1 	 	
9.4 5.9 8.0
5.1 5.1 5.1
5.7 6.2 5.7
50.6 57.5 47.4
6.0 6.0 6.0
329 288 314
(282) -- (282)
104 352 85.4
652 652 652
0.16 0.54 0.13

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                     NOTES FOR TABLES B-l AND B-2


aCarbon Adsorption Unit.

 Thermal  Oxidation Unit.

c
 Refrigeration Unit.
Includes one performance test plus  $5,000 equipment cost.


Cost of installing vapor collection eq
loading tank trucks,  $3,000 per truck.
eCost of installing vapor collection equipment on existing bottom
 Cost of converting top loading racks to bottom loading and vapor
 recovery, $200,000 per rack.

9Cost of retrofitting existing top loading tank trucks with bottom
 loading and vapor collection  equipment, $6,400 per tank truck.


 Electricity costs are based on average consumption rates reported by
 manufacturers.

Propane for pilot burner estimated at 12.5 liters per hour, at $0.18 per
 liter.

^Estimated activated carbon replacement period is 10 years, at $3.85 per
 kilogram carbon cost.

u
 Estimated as 4 percent of unit purchase cost, plus annual rack vapor
 collection maintenance of $200 per rack and $200 per terminal.

 Daily system inspections at 1 hour per day, plus a monthly inspection
 for liquid and vapor leaks in the vapor collection and processing
 systems.


mlncludes capital charges on continuous monitor investment plus
 $2,500 annual operating cost.


nCost to perform annual vapor tightness testing, including one-half
 day downtime, $300 per truck.

^Total capital investment (less monitor) x (capital recovery factor +
 0.04), where interest rate = 17 percent, equipment economic life =
 10 years.
                                B-5

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               NOTES FOR TABLES B-l AND B-2 (Concluded)

^Amount recovered per year, at $0.29 per liter.

rDifference between uncontrolled submerged fill loading and NSPS level
 of control.

sCost-effectiveness not calculated because net annualized cost is a negative
 quantity  (cost credit).
                                 B-6

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terminal  to convert its loading racks and tank trucks  to  a  bottom-
loading configuration, which is a substantial additional  cost.
     Control  unit purchase and installation costs are  the same  in  both
tables.  Current purchase costs have been obtained from manufacturers
for carbon adsorption (CA) (IV-D-51, IV-E-20, IV-E-36), refrigeration
(REF)  (IV-E-3, IV-E-32, IV-J-8),  and thermal oxidation  (TO)  type units
(IV-E-35,  IV-E-37).  Prices for CA and TO units represent the average
for two manufacturers, and REF prices represent a single manufacturer.
While the average price of TO units has risen 15 percent, CA and REF
prices have decreased 13 and 17 percent, respectively,  from  previously
reported values.  The estimate of installation cost as  85 percent  of
purchase cost has been retained (see Section 2.5.3).  The cost  of
continuous monitors has been added to the tables, using the  reference
costs for Compliance Option 2 in Table 8-38 of BID, Volume  I.
     The costs for converting tank trucks and loading  racks  to  a
bottom loading/vapor recovery configuration were reassessed  through
contacts with companies currently performing these conversions  (see
Section 2.5.5) (IV-E-22, IV-E-24, IV-E-25,  IV-E-26).  While  costs  vary
for trucks of different configurations, the previous cost of $6,400 for
a bottom loading/vapor recovery tank truck  conversion still  represents
a good average for Table B-2.  The cost of  adding vapor recovery
provisions alone has increased from $1,600  and $2,400  (cost  adder  on
new tank truck and conversion cost on older truck, respectively) to
$2,000 and $3,000.  The higher value of $3,000 has been used for both
new and existing terminal cases in Table B-l.  The costs  associated
with loading rack conversions are highly variable, depending on the
level  of work to be done.  The costs attributable to the  standard  must
represent the basic conversion which is necessary for  compliance with
the standard to be achieved.  It is often in a terminal's interest to
perform general modernization and equipment replacement during  a rack
conversion project.  This may include costs for improvements in concrete
driveways, drainage systems, fire protection, or structures.  Contacts
with construction contractors involved in recent projects of this  type
indicate that the previous estimate of $160,000 per rack  conversion
                                B-7

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may represent the low end of the range for a basic conversion  (IV-E-33,
IV-E-39).  To reflect this increase, a cost of  $200,000 has been
assumed for Table B-2.
     Electrical operating costs were re-evaluated by contacting
manufacturers and users of CA  (IV-E-20,  IV-E-40,  IV-E-42), REF (IV-D-47,
IV-E-32,  IV-E-38, IV-J-8), and TO units  (IV-E-35, IV-E-37).  Annual
power costs for Tables B-l and B-2 were  calculated using  the manufacturers'
reported  unit power  consumption, daily operating  schedules for each
type of unit, 340 days of operation, and  power  cost of $0.06 per
kilowatt-hour  (see Section 2.5.3).   Calculated  costs are  generally
confirmed by the costs reported by users,  but considerable variability
may be  expected  in individual  cases  due  to unit control settings,
terminal  schedules,  and climatic conditions.  The cost of propane  used
for the  pilot burners of TO  units has  been raised from $0.12 per  liter
to the  current  price of $0.18  per liter.   The price of activated
carbon  has  increased from  $3.30 per  kilogram  to $3.85 per kilogram
 (IV-E-30).  The  cost of maintaining  a  vapor processor  is  quite variable,
but user input  indicates that  this  cost  can be  represented quite  well
as 4 percent of  the  unit purchase cost (see Section 2.5.3).  This
percentage  is  unchanged for  CA and TO  units,  but represents  a  considerable
reduction from  the previous  value of 8 percent  assumed for REF units.
Newer  generation  units  appear  to have  lower maintenance  requirements
than the brine  systems which make up a considerable percentage of the
existing population  of  refrigeration units.   The additional  rack  vapor
recovery maintenance cost  of $200 per  rack annually, plus $200 per
facility has been  retained  unchanged.   The level  of operating  labor
required to perform  daily  unit checks  and a monthly  leak  inspection is
assumed to  remain  valid, but the hourly rate  has been  increased from
$10 per labor-hour to $15  per  labor-hour to cover the  expected inflation
rate over the  next several years  as  well  as  the possibility  of more
technically oriented personnel  being employed  to check  continuous
monitors.  The  annual  compliance cost  in both  tables  represents Compliance
Option  2 in Table  8-38 of  BID, Volume  I.   The  total direct  operating
costs  for the model  plants  are generally higher than  the  previous
values  presented  in  BID, Volume  I,  primarily  due to higher  electrical
consumption and  the  addition of  compliance costs.

                                 B-8

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     Tank truck maintenance costs, representing the annual vapor
tightness test, have been increased from $150 to $300 per truck,  to
include the estimated one-half day of lost revenue due to transport
downtime during the test.  Capital charges on the initial investnent
have been re-calculated to account for a higher interest rate.  If the
rate is 17 percent, then for an equipment economic life of 10 years
the capital recovery factor (Table 8-22 of BID, Volume I) would be
0.21.  Adding property taxes,  insurance, and administrative costs of
0.04, the capital  charges total 25 percent of the total capital cost.
Capital charges on the continuous monitors are included separately
under the compliance cost.  The gasoline recovery cost credits are
calculated as before, using revised values of gasoline price and  total
gasoline recovered.  The nationwide average wholesale price for regular
leaded gasoline during first quarter 1981 was approximately $0.29 per
liter (IV-J-10).  The gasoline recovery rates in Table 8-25 of BID,
Volume I, were mistakenly based on an uncontrolled emission factor of
960 nig/liter in areas with no SIP regulation of gasoline loading  at
bulk terminals.  If the correct emission factor of 600 mg/liter (submerged
loading, normal service) is used, the recovery rate is:
600 mg/liter - (0.10)(600 mg/liter) - 35 mg/liter = 505 mg/liter,
or 39 percent lower than the previous figure of 829 mg/liter.  The
recovery cost credits entered in Tables B-l and B-2 are thus $28,200,
$70,600, $141,000, and $282,000, which average only 4 to 5 percent
higher than the previous estimates.  Because of the lowered emission
factor referred to above, the total annual VOC controlled has been
reduced by 39 percent for all  model plants.
     Most net annualized costs presented in Tables B-l and B-2 have
increased from the previously presented values.  Annualized costs for
CA and REF installations at previously bottom-loaded terminals are
22 and 14 percent higher, respectively, than before for Model Plants  1
and 2.  These costs remain negative for Model Plants 3 and 4, indicating
that terminals in this size range  (greater than 1,400,000 liters/day
throughput) installing CA or REP units would realize a net income from
the installation.  New annual costs for TO installations, however,
have increased an average of 61 percent in the cost re-evaluation,
                                6-9

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causing them to appear less competitive for all model plant sizes.   In
particular, whereas the TO installation previously involved the lowest
net annualized cost for Model Plant 1, the revised estimates  indicate
the TO installation to involve net costs which are 29 and 3 percent
higher, respectively, than CA and REF  installations.  All net  annual-
ized costs shown in Table B-2 for top-loaded terminals affected by the
regulation are higher than previous estimates.  Section B.3 discusses
the economic  impact considerations of  the revised cost estimates.
     The  compression-oxidation systems discussed on  page 4-12  of  BID,
Volume I, have not been  included  in the revised tables because the
gasoline  recovery  rate has not been determined (IV-E-27).  One system
tested recently in California showed  over 99 percent control  efficiency
(emissions less than  1.2 mg/liter), and it was estimated that  22  gallons
were recovered during a  gasoline  throughput of 2.3 million liters  in
24 hours  (IV-J-5).   Preliminary estimates indicate that the net cost
for this  system would be higher than  for .any of the  three units shown
in the tables.
B.2.2  Nationwide  Control Costs
     The  cost impacts on the bulk terminal  and for-hire tank  truck
industries have been  re-calculated based on the updated model  plant
and tank  truck costs  discussed  in Sections  2.5 and B.2.1.  Several
changes have  been  made to the calculations.
     Based on industry responses  to Section 114  letter requests for
information,  it is estimated that five new  bulk terminals will be
built  in  the  first five  years of  the  standard  (Table 8-12 of  BID,
Volume I).  As noted  on  page 3-26 of  BID, Volume  I,  approximately
71 percent of the  nationwide gasoline loading  at  existing terminals
will be controlled to the level recommended by the terminal CTG.   This
implies that  about 71 percent,  or three of  the five  new terminals,  are
likely to be  constructed  in  areas already requiring  emission  control
to the 80 mg/liter limit.  Since  the  NSPS will require an emission
limitation to 35 mg/liter, there  may  be added  costs  associated with
achieving this limit  as  compared  to the SIP limit  of 80 mg/liter.
Although  these added  costs are  likely only  in  the  case of refrige-
ration recovery systems  (since  current CA and  TO  units can meet the
                                 B-10

-------
lower limit),  they have been accounted for in the case of all  t'nree  of
these terminals to assess worst case costs.  The costs of installing
and operating  continuous monitors, outlined in Tables B-l and  8-2,
have also been included for these terminals.   The remaining two terminals
in areas with  no SIP control will incur the full costs summarized  in
Table B-l.   One Model Plant 2 and one Model Plant 3 have been  assumed
for these terminals (the largest terminals are expected in SlP-controlled
areas,  which are generally associated with the higher-demand urban
areas).  The previous analysis was based on the incorrect assumption
that all five  new terminals would incur the full control costs of  the
standard.
     It was assumed that, since all  state-of-the-art CA and TO units
are considered capable of meeting the 35 mg/liter limit, the REF unit
would be the typical choice of a terminal  owner intending to comply
with an 80 mg/liter limit.  The costs for a REF system meeting
35 mg/liter were presented in Table B-l.  Purchase prices of $128,000
and $134,000 for Model Plant 3 and 4 size units meeting 80 mg/liter
were obtained  from the manufacturer's current price list (IV-J-8).
The lower prices of the less efficient units  created lower installa-
tion, electricity, and maintenance costs,  as  well as lower capital
charges than for the units meeting 35 mg/liter.  Electrical  costs  for
the 80 mg/liter units were assumed to be 50 percent less than  these
costs for the  35 mg/liter units, as suggested by the manufacturer
(IV-E-32).  The gasoline recovery cost credit for units controlling  to
35 mg/liter is greater, which tends to offset the increased purchase
and operating  costs of these units.  In fact, for the Model  Plant  3
size terminal  in this situation, the net annualized cost is $1,000
less for the 35 mg/liter system than for the 80 mg/liter system.   All
net costs remain negative, however, indicating that more money would
be made from recovered product than would be spent to operate  the
control system.
     All terminals replacing or adding onto existing systems to meet
the NSPS limit were assumed to be represented by Model Plant 2 for the
purpose of the calculations.  The assumptions used to derive Tables  8-35
and 8-36 of BID, Volume I, were retained, but updated costs corresponding
to those in Table B-l were substituted.

                                B-ll

-------
     The cost per unit of emission reduction was also reviewed for
each of the cases associated with the standard.  These costs are shown
in Table B-3.  The cost per unit emission reduction was considered
excessive for cases 3a and 3b.  Based upon these costs and the fact
that EPA does not feel it is reasonable to require costly add-on
controls or replacements of recently installed equipment at bulk
gasoline terminals, EPA decided that existing control devices meeting
80 mg/liter would not require additional emission reduction.
     The previous cost analysis also assumed that 25 of the 30 modified
or reconstructed terminals in attainment areas would become affected
facilities due to loading rack conversions and would incur the costs
summarized in Table 8-34 of BID, Volume I (new Table B-2), because
conversion of these previously top loading racks to bottom loading
would  be required to meet the emission  limit of the standard.  However,
since  no SIP requirements led to the conversions and because the
loading rack conversion was the item that triggered the reconstruction
provisions of the standards, the cost impact of the conversions them-
selves will not  be attributable to the  standard, and so the costs
summarized in Table B-l will apply.  Only 5 of the 30 modified or
reconstructed terminals in attainment areas in the first 5 years
would  become affected facilities for reasons other than top to bottom
loading conversions.  However, it is estimated that two of these
terminals will already use bottom loading, leaving three terminals
which  will incur the full costs shown in Table B-2.  Based on the
distribution of  terminal sizes (Table 8-4 of BID, Volume I), two of
these  terminals will be of Model Plant  1 size and one terminal will  be
of Model Plant 2 size.
     Table 8-4 presents the number and  sizes of the terminals expected
to incur control costs as a result of the standard, as well as the
per-facility costs as shown in Tables B-l and B-2.  The costs associated
with CA, TO, and REF installations were averaged for Model Plant 1,
whereas only CA and REF costs were averaged for Model Plants 2 and 3.
The incremental costs of meeting 35 mg/liter instead of 80 mg/liter,
and the costs of continuous monitors applied to existing control
systems, both not contained in Tables B-l and B-2, were derived using
the assumptions described above.

                                B-12

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                     Table B-3.  COST EFFECTIVENESS FOR VARIOUS BULK TERMINAL MODEL  PLANT CASES

Case8
1
2
3a
3b
4
TOTALb

Quantity
13
2
-
_
-
Model
Plant 1
($/Mg)c
1100
2600



15

Quantity
8
1
5
5
-
Model
Plant 2
($/Mg)c
340
1300
6000
4300

19
Model
Plant 3
Quantity ($/Mg)c
8 (s)d
-

_
1 (s)d
9
Model
Plant 4
Quantity ($/Mg)c
e
-
-
_
2 450
2
CO
I
         Case 1:  New, modified, or reconstructed terminals in areas unaffected by SIP regulations  (Table  B-l)
         Case 2:  Modified or reconstructed terminals requiring bottom loading conversion  (Table  B-2).
         Case 3a: Terminals replacing an existing SIP-level (80 mg/liter) control system.
         Case 3b: Terminals adding onto an existing SIP-level  (80 mg/liter) control system.
         Case 4:  New terminals installing NSPS-level equipment instead of SIP-level equipment  (CRA or
                  REF units only).
         Remaining 10 of the 55 affected terminals will have previously installed equipment which meets
         35 mg/1iter.
        GCost effectiveness is the average of the control devices.  TO included in averages for Model
         Plants  1 and 2, excluded in average for Model Plants  3 and 4.
         (s) = cost savings.
        e"-" = no affected terminals assumed in this model plant size.

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                            TABLE B-4.   FIVE-YEAR  NATIONWIDE COSTS  TO  BULK TERMINAL  INDUSTRY

                                           (Thousand  of  First  Quarter  1981  Dollars)
CO
Bulk Terminals
Case3 Model Plant
1
1 2
3
1
2 2
2
Affected
No. of Occurences
13
8
8
2
1
10

3
•4 4
TOTALS
1
2
45b
Capital Investment
Investment/Terminal
251
302
319
661
922
13C
Total
3,260
2,420
2,550
1,320
922
130

18.0
78.0
18.0
156
10,776
Net
Cost/Terminal
68.9
37.5
-25.1
172
193
5.7C
Annual ized Cost
Total Net Cost/Year
896
300
-201
344
193
57

-1.0
13.0
-1.0
26.0
1,614
                  "Case 1:
                  Case 2:
                  Case 3:
                  Case 4:
New, modified, or reconstructed terminals  in areas unaffected by SIP  regulations (Table B-l).
Modified  or reconstructed  terminals requiring bottom loading conversion  (Table B-2).
Terminals with existing  SIP-level  (80 mg/liter) control systems.
New terminals install inn NSPS-level equipment instead of SIP-level  equipment.
                  Remaining 10 of the 55 affected terminals  will have previously installed  equipment which  meets 35 my/liter.

                 °No replacement or add-on contra1  are required for existing vapor processing systems under  the promulgated
                  standard.  Only costs associated with the  facilities would be fr>r continuous monitors.

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     Table B-4 shows a nationwide total  capital  investment for the
terminal  industry in the first 5 years of $10.8 million, or
45 percent of the previous estimate.   The net annualized cost in the
fifth year will  be $1.6 million, or 45 percent of the former figure.
     The costs to the for-hire tank truck industry have increased
slightly in the cost impacts re-evaluation.   As stated in Section 2.9.4,
approximately 370 for-hire tank trucks will  require conversion due to
the standard.  Of these, 35 will require both bottom loading and vapor
recovery retrofitting, at $6,400 per tank truck, and 285 will require
only the addition of vapor recovery equipment, at $3,000 per tank
truck (Section 2.5.5).  The capital and annualized costs are calculated
as in Sections 8.2.5.1 and 8.2.5.2 of BID, Volume I.   The total  capital
investment in the first 5 years will  be:

     (85 tank trucks) x ($6,400/tank truck)  = $544,000, plus
     (285 tank trucks) x ($3,000/tank truck) = $855,000,

which totals $1.4 million.  The annualized cost in the fifth year will
consist of capital charges and the costs of  maintenance and testing.
Assuming an interest rate of 17 percent and  an equipment life of
12 years, capital charges will total:

          ($1.4 million) x (24 percent) = $336,000/yr.

With maintenance costs at $1,000 per year and testing at $450 per
year, the total  annualized cost for 370 tank trucks in the fifth year
wi 11 be:

     370 x ($l,000/yr + $450/yr) + $336,000/yr = $0.9 million.

     In summary, the total capital investment required by both the
bulk terminal and for-hire tank truck industries in the first 5 years
of the standard will be $12.2 mill ion.  The annualized cost for
both industries in the fifth year will be $2.5 million.  Section B.3
                                B-15

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discusses the changes to the economic impact analysis resulting from
the revised cost estimates.
B.3  ECONOMIC IMPACT ANALYSIS
     Tables 8-43 through 3-53 of BID, Volume I, were revised to account
for the current control costs presented in Section B.2.1, the current
price of leaded regular gasoline, and a current level of investment
costs.  All monetary values in this section are specified in first quar-
ter 1981 dollars; older values not updated through direct contacts were
converted using the  "Chemical Engineering Plant Index"  (IV-J-14).  Except
for these three changes, all of the assumptions used in the calculations
in BID, Volume I, remain the same.
     The change in1 the price of leaded regular gasoline from $0.17 per
liter to $0.29 per liter impacts the results presented  in Tables B-5
through B-10 either  indirectly as a change in after-tax profits or directly
in the calculation of a maximum percentage price increase (see
Sections 8.4.1.2.1 and 8.4.1.2.2 of BID, Volume I).  The change in
total investment costs impacts the results in all the tables except
Table B-9, either indirectly through a change in CMLTD  and depre-
ciation or directly  in the calculation of ROI (see Sections 8.4.1.2.1.
and 8.4.1.2.2.2 of BID, Volume I).
      It is not necessary to thoroughly explain and examine each of the
individual Tables B-5 through B-10 since the methodology and results
are similar to those in the original economic analysis.  In general,
the revised debt service coverage ratios are much higher for all
regulatory alternatives and all model plants.  The revised ROI's are
also  considerably higher for new facilities but only slightly higher
for existing facilities.   The revised maximum percentage price  increases
presented  in Table B-9 are  in addition slightly higher  for all  model
plants  (for comparison purposes see Tables 8-45 and  8-52 of BID, Volume  I).
      The general conclusions presented in Sections 8.4.1.2.4 and 8.4.1.3.5
of BID, Volume I, are  thoroughly supported by the results in Tables B-5
through B-10.  None  of the model plants will encounter  a debt service
coverage problem, nor will  the maximum price increase necessary to
maintain pre-control profit  rates be excessive.  The worst possible
case  is a  necessary  0.48 percent price increase for  a 380,000 liter/day
existing top-loading facility.

                                B-16

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DO
I
                                 Table  B-5.   DEBT  SERVICE COVERAGE  RATIO  FOR  NEW FACILITIES
                                                  (Monetary  Values in  $000 1981)

380,000 lyday 950,000 1/dAy

Basel ine Facility
Total Investment
Long-Term Debt (LTD)
Current Maturity LTD
(CMLTD)
Depreciable Assets
After-Tax Profit
Depreciation
Cash Flow (CH)
CF t CMLTD
Controlled Facil i ty
Total Investment*1
LTDb
CMLTDC
After-Tax Profit^
Depreciation^
Cash Flow
CF i CMLTD

CA TO

2,900
1,160
116

1,887
303
180
483
4.2

3,159 3,232
1,419 1,492
142 149
271 262
206 213
477 4/b
3.4 3.2

REF CA TO REF

4,500
1,800
180

2,942
758
284
1,042
5.8

3,170 4,818 4,751 4,786
1,430 2,118 2,051 2,086
143 212 205 209
264 738 709 737
207 316 309 313
471 1.054 1,018 1,050
3.3 5.0 5.0 5.0

1,900,000 I/day
CA TO REF

6,600
2,640
264

4,222
1,517
395
1,912
7.2

6,942 6,860 6,895 1
2,777 2.744 2,758
278 274 276
1,528 1,460 1,533
429 421 425
1.957 1,881 1,958
7.0 6.9 7.1

3,800,000 I/day
CA TO REF

10,900
4,360
436

7.0/5
J.OJ5
706
2,741
8.6

1,362 11,201 11,299
4,822 4.661 4.759
482 466 476
3.096 2,%2 J.106
752 736 746
3.8-1H J.69U 3.8bZ
8.0 7.9 8.1
                Baseline investment plus capital control  costs.
                Baseline LTD plus capital control costs.
               CO.IO x ITD.
                Baseline after-tax profit minus  [(1-tax rate) x annualized control costs].
               ebaseline depreciation  plus (0.10 x control capital  costs).

-------
    Table B-6.   DEBT  SERVICE  COVERAGE  RATIO,  EXISTING  FACILITY  —  BASELINE
                        (Monetary  Values  in  $000  1981)


Existing Facility
Total Investment3
Long-Term Debt (LTD)
Current Maturity LTD
(CMLTD)
Depreciable Assets
After-Tax Profitb
Depreciation
Cash Flow (CF)
CF - CMLTD
380,000
I/day
1,960
780
78
1 ,280
303
128
431
5.5
950,000
I/ day
3,050
1 ,220
122
1 ,990
758
199
957
7.8
1 ,900,000
I/ day
4,470
1,790
179
3,260
1,517
326
1,843
10.3
3,800,000
I/ day
7,380
2,950
295
4,810
3,035
481
3,516
11.9

aTable 8-47  values from BID, Volume I  adjusted  to  reflect 1976 cost levels using
 M&S equipment cost index (IV-J-Hj.


 Calculated using $0.29 per liter wholesale price for leaded regular gasoline.
 This assumes an average retail  price of $0.356 per liter  ($1.347 per gallon)
 for leaded regular as of the first quarter of 1981.
                                    B-18

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DO


UD
              Table B-7.   DEBT SERVICE COVERAGE  RATIO,  EXISTING  FACILITY-BOTTOM LOADED,  NO SIP  CONTROL
                                                (Monetary  Values  in $000 1981)
.

Total Investment
LTOb
CMLTOC
After-Tax Profits'1
Depreciation6
Cash Flow (CF)
CF i CMLTD

380
CA
2,219
888
89
271
154
425
4.0

,000 I/day
TO
2,292
917
92
262
161
423
4.6

REF
2,230
892
89
264
155
419
4.7

950
CA
3,368
1,347
135
738
231
969
7.2

,000 I/day
TO
3,301
1.320
132
709
224
933
7.1

REF
3,336
1.334
133
737
228
965
7.3

1,900
CA
4.812
1.925
193
1,528
360
1,888
9.8

,000 I/ day
TO
4,730
1,892
189
1.460
352
1.812
9.6

REF
4,765
1.906
191
1.533
356
l ,«ay
9.9
3,800,000 I/Jay
CA
7.842
3,137
314
3.096
527
3,o23
11.5
TO
7.681
3.072
307
iJ.962
bll
3.47J
11.3
REF
7,779
3.112
311
3,106
521
3,fa^/
11.7

               dBaseline  investment plus capital  control costs.

                Baseline  III) plus capital  control  costs.

               C0.10 x LTD.

                Baseline  after-tax profit minus [(1-tax rate) x annual 1 zed control costs).

               eBaseline  depreciation plus (0.10  x control  capital  costs).

-------
CO
 I
PO
o.
                    Table B-8.   DEBT SERVICE  COVERAGE RATIO,  EXISTING FACILITY-TOP LOADED,  NO SIP  CONTROL
                                                   (Monetary Values in  $000 1981)


Total Investment
LTD6
CMLTDC
After-Tax Profitsd
Depreciation6
Cash Flow (CF)
CF * CMLTD

380
CA
2,629
1,449
145
216
195
411
2.8


, JO I/day
TO
2,594
1,414
141
207
191
398
2.8
REF
2,640
1,460
146
208
196
404
2.8



950,000 I/day
CA
3,988
2,158
216
654
293
947
4.4
TO
3,921
2,091
209
625
286
911
4.4
REF
3,956
2,126
213
654
290
944
4.4



1 .900,000 I/day
CA
5,443
2,763
276
1,443
388
1,831
6.6
TO
5,361
2.6H1
268
1,375
380
1,755
6.5
REF
5,396
2,716
272
1,448
384
1,832
6.7

iti!
CA
8.710
4,280
428
2,979
614
3,593
8.4
30,000 1,
TO
8,549
4,119
412
2,845
MB
3.443
8.4

REF
8,647
4,217
422
2,989
608
3,597
0.5

               aBaseline investment plus capital control costs.


                Baseline LTD plus capita) control costs.


               C0.10 x LTD.


                Baseline after-tax profit minus [(1-tax rate)  x annualized control costs].


                Baseline depreciation plus (0.10 x control capital costs).

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I
ro
                               Table  B-9.   MAXIMUM PERCENTAGE  PRICE  INCREASES, COST PASS-THROUGH:

                     NEW FACILITIES,  EXISTING FACILITIES (BOTTOM LOAD), AND  EXISTING FACILITIES (TOP  LOAD)

                                                                (Percent)
                                          380,000 I/day        9SO.OOO I/day        li 900,000 1/da^        liMMi^OO J
                                         CA    TO   REF     CA    TO    REF      CA~    TO'   REF"     CA     TO    REF
                 New and Existing Fact-    .16    .20    .19     .04    .10    .04      (.01)"  .06   (.02)"    (.03)"  .04   (.03)'
OT                 lities (Bottom load)
                 Existing Facilities      .43    .48    .47     .20    .26    .21       .07    .14    .07       .03    .09    .02
                   (Top Load)
                 d( )  indicates control cost savings,  which may result in price  reductions.

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 Table  B-10.  AFTER-CONTROLS, AFTER-TAX RETURN ON INVESTMENT:  NEW FACILITIES, EXISTING
                        FACILITIES  (BOTTOM LOAD), AND EXISTING FACILITIES  (TOP  LOAD)
                                              (Percent)
 (Bottom Loaded)
                          380.000 I/day         950.000 I/day        1.900.000 I/day        3.800.000 I/day
                         CA    TO    REF      CA     TO   REF      CA     TO   .REF       CA     TO   REF
New Facility
  Baseline                     10.4                16.8                  23.0                  27.8
  After-Control           8.6    U.I   8.3     15.3   14.9  15.4    22.0    21.3   22.2     27.2    26.4  27.5

Existing Facility
  Baseline                     15.0                15.0                  15.0                  15.0
  After-Control          11.9   11.7  11.5     13.7   13.4  14.0    14.6    14.0   14.7     15.0    14.4   15.0

Existing Facility
  (Top Loaded)
   Baseline                    15.0                15.0                  15.0                  15.0
   After-Control          8.0    7.8   7.7     10.9   10.6  11.0    13.0    12.5   13.1     13. 8    13.3   13.9

-------
     The conclusions based on the ROI analysis are also the same with
the exception of a new 950,000 liter/day facility.  The conclusion
based on the original  ROI analysis stated that "terminals in the
950,000 liter/day category, marginally attractive before controls,
would have to pass through most of the control costs to remain attractive.
The ROI results from Table B-10 suggest that a new 950,000 liter/day
facility will be marginally attractive for both the baseline and
after-control cases since the 15 percent ROI criterion is maintained.
The ROI results still  support the conclusion that growth in the form
of 380,000 liter/day bulk terminals will not take place because both
pre-control  and after-control ROI's do not meet the 15 percent condition.
The 380,000 liter/day existing terminal will still encounter an ROI of
less than 11 percent,  the minimum acceptable return, but the
950,000 liter/day existing terminal now maintains a marginal ROI level
of between 10.6 and 11.0 percent.
     The economic impacts on the for-hire tank truck industry are
slightly higher as a result of the revised costs; however, the basic
conclusions from the original analysis remain intact.  Revised rates
of return on transportation investment decrease slightly to a range
of 3.N9 to 11.0 percent for Scenario 1, and a range of 2.8 to 10.2 percent
for Scenario 2.  These results further support the original  conclusion
that the viability of the three largest firms could become threatened
with the imposition of any of the regulatory alternatives in the unlikely
event that control costs are totally absorbed.  If, however, the control
costs are fully passed through to the consumer in the form of higher
prices, gasoline prices would increase by a maximum of 0.02 to
0.08 percent.  As discussed in Section 2.5.7, tank truck firms are
expected to be able to pass through their costs of control.  Finally,
the firm's ability to meet debt service costs is maintained since the
values calculated in the revised debt service coverage analysis remain
the same as those presented in Table 8-59 of BID, Volume I.
B.4  SOCIOECONOMIC AND INFLATIONARY IMPACTS
     Section B.3 presented the revisions to the original economic
analysis for the bulk terminal and for-hire tank truck industries.
This section will review the results of the original Socioeconomic and
                                B-23

-------
Inflationary Impacts section (Section 8.5 of BID, Volume I) with
respect to the directives of Executive Order 12291 and the updated
scenario presented in Section B.3,  to determine whether the results
and conclusions of the original  analysis have changed.
B.4.1  Executive Order 12291
     According to the directives of Executive Order 12291, a "major
rule" means any regulation with the potential to result in:
     •    an annual  effect on the economy of $100 million or more,
     •    a major increase in costs or prices for consumers, individual
          industries, Federal, State, or local government agencies, or
          geographic regions, or
     •    significant adverse effects on competition, employment,
          investment, productivity, innovation, or on the ability of
          the United States-based enterprises to compete with foreign-
          based enterprises in domestic or export markets.
     The following sections evaluate these criteria in relation to the
promulgated action.
B.4.2  Fifth-Year Annualized Costs
     Section B.2.2 recalculated fifth-year annual ized costs to be
$1.6 million for the bulk terminal  industry  and $0.9 million for the
for-hire tank truck  industry.  The total of  $2.5 million  is well
within the  $100 million  level; thus, no major impact  is indicated
according to this criterion.
B.4.3  Inflationary  Impacts
     In Section B.3  it was determined that the worst  case  impact the
regulatory  alternative would have on the price of gasoline, via the
bulk terminal  industry,  was 0.48 percent.  In Section 8.4.2.2.2 of
BID, Volume I,  it was also determined that the worst  case  impact the
regulatory  alternative would have on the price of gasoline, via the
for-hire tank truck  industry, was 0.07  percent.  The  total worst case
impact on the price  of gasoline from both  industries  is 0.55 percent.
Since a rise  in the  price of gasoline by 0.55 percent cannot be con-
sidered a major price or cost increase, no major economic  impact is
indicated according  to this criterion.
                                B-24

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B.4.4.  Other Impacts
     The regulatory alternative will not curtail a businessman's
opportunity to enter the gasoline terminal  market.  Sufficient ROI's
are available to make it attractive to build large terminals in both
pre-control and post-control  situations.  At the other extreme a small
businessman is already limited by the lower returns from small facilities
in a pre-control situation.   For smaller existing terminals low ROI's
may make closure a necessary alternative; however, few facilities
will find themselves in a position of being unable to pass along most
of the control costs.  Therefore, employment impacts and adverse
effects on the regional economies will be negligible.
     Finally, foreign trade and the balance of payments should not be
influenced by the standard,  since bulk terminals export and import
relatively small amounts of gasoline.  No major impact is indicated
according to this criterion.
B.5  REGULATORY FLEXIBILITY ANALYSIS
     The Regulatory Flexibility Act of 1980 (RFA) requires that
differential impacts on small businesses resulting from all Federal
regulations be identified and analyzed.  The definition of a small
business in the bulk terminal industry (SIC 5171), according to the
criterion to qualify for SBA loans, is a firm with less than $22 million
in annual receipts (IV-E-47).  Approximately 50 to 60 percent of the
bulk terminal industry can be considered as small businesses
according to this criterion  (IV-J-13).  In the for-hire tank truck
industry (SICs 4212, 4213, and 4214) a small business is defined as a
firm with less than $6.5 to $7 million in annual receipts (IV-E-47).
Approximately 60 percent of the for-hire tank truck industry can be
considered as small businesses according to this criterion (IV-J-12).
The RFA further stipulates that the analysis must be prepared if
20 percent of the small businesses are significantly affected.
     As described in Section B.2.2, five new terminals are expected to
be constructed in the first five years, and approximately 50 facilities
will become affected through modification or reconstruction.  Of the
55 affected facilities, 15 facilities, a 27 percent share, can be
                                B-25

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considered small business entities (assuming Model Plant 1 approximates
a small  business), and so the 20 percent criterion is exceeded.
     Only the modified and reconstructed category of the affected
facilities need be examined for significant impact since the five new
terminals are all medium to large sized plants.  New small facilities
are considered not economically feasible (based on stand-alone economics),
with or without imposition of the promulgated standards.  The 15 affected
facilities considered to be small business entities will be impacted
according to the costs presented in Table B-2 for top-loaded, existing
bulk terminals.  The analysis presented in Section B.3 concluded that
a significant impact for small business entities  (assumed to be Model
Plant 1) would occur only under the worst-case assumption of complete
cost absorption.  Under a more likely scenario, further analysis revealed
no significant impact.  This conclusion was based on the more realistic
assumption that most of the costs will be passed  through with very
little cost absorption affecting the ROI.  Small  terminals in remote
areas will be at the same disadvantage with respect  to  parts and
service access as they were prior to the standards,  but this should
not affect their ability to comply with the standards at a reasonable
cost.  Since the impact on small bulk terminal businesses is not
expected  to be significant, no Regulatory Flexibility Analysis  is
required  for this industry sector.
     Thirty-four model firms  in  the for-hire  tank truck industry are
expected  to be affected by 1985.  Twenty-three of these affected firms
are expected to  be small business entities, representing a 68 percent
share, which exceeds the 20 percent criterion.
     The  potential exists for a  significant impact  to occur  in  a
worst-case scenario  if control costs are completely  absorbed.   The
results from the  return-on-transportation investment (ROTI)  analysis,
Section 8.4.2.2.1 of BID, Volume  I, not only  suggested  a significant
worst-case impact, but that the  impacts are more  severe for  the largest
model trucking  firms.  The decrease for the worst-case  situation in
the ROTI's range  from 9.6 and 55.6 percent.   A more  likely scenario was
analyzed  and no  significant economic impact was found.  This scenario
was based on the  realistic assumption that most of  the  control  costs
                                 B-26

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will be passed through with very little cost absorption affecting the
ROTI.  Even under complete cost pass-through the price of gasoline
increases at most, by 0.03 percent.   Since the impact on small independent
tank truck firms is not expected to be significant, no Regulatory
Flexibility Analysis is required for this industry sector.
                                B-27

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B.6  REFERENCES

IV-D-51   Letter and attachments from Schmidt, E.L., McGill,  Incorporated,
          to Norton, R.L., Pacific Environmental Services,  Incorporated.
          April 30, 1981.  Information on prices and power  consumption
          for vapor processors.

IV-E-3    Telecon.  LaFlam, G.A., Pacific Environmental Services,
          Incorporated, with Edwards, R., Edwards Engineering Corporation.
          February 23, 1981.   Information on  refrigeration  units.

IV-E-20   Telecon.  LaFlam, G.A., Pacific Environmental Services,
          Incorporated, with Kaitschuck, J.,  John Zink Company.
          April 14, 1981.  Information on carbon adsorption units.

IV-E-22   Telecon.  Gschwandtner, K.C.,  Pacific Environmental Services,
          Incorporated, with Todd, J., Heil Company.  April 14,  1981.
          Information on  tank  truck  conversion  costs.

IV-E-24   Telecon.  Gschwandtner, K.C.,  Pacific Environmental Services,
          Incorporated, with Hemphill, R.,  Fruehauf  Corporation.
          April 20, 1981.  Information on tank  truck conversion  costs.

IV-E-25   Telecon.  Gschwandtner, K.C.,  Pacific Environmental Services,
          Incorporated, with Botkin,  L., Fruehauf Corporation.   April  20,
          1981.   Information on  tank truck  conversion  costs.

IV-E-26   Telecon.  Gschwandtner, K.C.,  Pacific Environmental Services,
          Incorporated, with Ritterbush, J.,  J  & L  Tanks.   April  20,
          1981.   Information on  tank truck  conversion  costs.

IV-E-27   Telecon.  LaFlam, G.A., Pacific  Environmental  Services,
          Incorporated, with Kirkland, J.,  Hirt Combustion  Engineering.
          April 20, 1981.   Information on  cost  of compression-oxidation
          vapor control units.

IV-E-30   Telecon.  Norton, R.L., Pacific  Environmental  Services,
          Incorporated, with McGill, J., McGill,  Incorporated.   April
          23,  1981.   Information on  carbon  adsorption  units.

IV-E-32   Telecon.  LaFlam, G.A., Pacific  Environmental  Services,
          Incorporated, with Edwards,  R.,  Edwards  Engineering Company.
          April 28, 1981.   Information on  refrigeration  units.

IV-E-33   Telecon.  LaFlam, G.A., Pacific  Environmental  Services,
          Incorporated, with Welpe,  B.,  Hunn  Corporation.   April 29,
          1981.   Information on  cost of  loading rack conversions.
  These  numbers  correspond  to  the docket item number in Docket No. A-79-52.
                                 B-28

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IV-E-35   Telecon.   LaFlam,  G.A.,  Pacific Environmental  Services,
          Incorporated,  with Bitter!ich,  G.,  National Airoil Burner
          Company.   April  30,  1981.   Information on cost of thermal
          oxidizer  units.

IV-E-36   Telecon.   Schmidt, E.,  McGill,  Incorporated, with Norton,
          R.L.,  Pacific  Environmental  Services,  Incorporated.   April 30,
          1981.   Information on  carbon adsorption units.

IV-E-37   Telecon.   Guischard,  C.,  AER Corporation, with LaFlan, G.A.,
          Pacific Environmental  Services, Incorporated.   May 4, 1981.
          Information  on cost of  thermal  oxidizer units.

IV-E-38   Telecon.   Lowery,  E.,  ARCO,  with LaFlam, G.A., Pacific
          Environmental  Services,  Incorporated,   flay 5,  1981.   Information
          on maintenance and electrical  costs of Edwards DE Model
          refrigeration  unit.

IV-E-39   Telecon.   LaFlam,  G.A.,  Pacific Environmental  Services,
          Incorporated,  with Ottoson,  R.S.,  Ray  Construction Company,
          Incorporated.   May 6,  1981.   Information on design and costs
          associated with  loading  rack conversions.

IV-E-47   Telecon.   Cryer,  C.,  JACA Corporation, with Sheirik, K.,
          Small  Business Association.   June 17,  1981.  Size criteria
          for small  businesses.

IV-J-5    California Air Resources  Board.  Certification Evaluation
          Report No. C-9-058 of  Hirt Vapor Recovery Unit.  August
          1980.

IV-J-8    Edwards Engineering Corporation.  Hydrocarbon vapor recovery
          units  price  list.   January 1,  1981.

IV-J-12   American  Trucking  Associations, Incorporated.   1978 Motor
          Carrier Annual Report—Financial and Operating Statistics.
          Washington,  D.C.   1979.   812 p.

IV-J-13   Robert Morris  Associates.   Annual  Statement Studies.  1980.
          p. 217.

IV-J-14   Chemical  Engineering.   McGraw-Hill, Inc.  May 18, 1981.  p. 7.
                                B-29

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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before cornz'.cnm::
1 REPORT NO
EPA-450/3-80-038b
2. >3. RECIPIENT'S ACCESSION NO.
4 TITLE AND SUBTITLE
Sulk Gasoline Terminals - Background Information for
Promulgated Standards
7 AUTHOR(S)
5. REPORT OATE
August 1933
6. PERFORMING ORGANIZATION CODE
8 PERFORMING ORGANIZATION REPORT NC
9 °E3FORMING ORGANIZATION NAME AND ADDRESS . TO. PROGRAM ELEMENT NO.
Offirp nf Air Quality PlApm'nn and Stan Hard-;
  U.S.  Environmental  Protection Agency
  Research  Triangle Park, NC  27711
                                                           ,11. CONTRACT/GRANT NO.
               68-02-3060
12. SPONSORING AGENCY NAME AND ADDRESS
  OAA  for  Air Quality Planning and  Standards
  Office of Air,  Noise, and Radiation
  U.S.  Environmental  Protection Agency
  Research Triangle Park, NC  27711
             13. TYPE OF REPORT AND PERIOD COVEREC
             14. SPONSORING AGENCY CODE
               EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT

       Standards of performance to  control  volatile organic  compound emissions from
  new,  modified, and reconstructed  bulk  gasoline terminal  loading  racks are being
  promulgated under the authority of  Section  111 of the Clean  Air  Act.   This document
  contains a detailed summary of the  public comments on the  proposed standards
  (45  FR  83126), responses to these comments  and a summary of  the  changes to the
  proposed standards.
17.
                               KEY WORDS AND DOCUMENT ANALYSIS
a.
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                           c. COSATi f-ieid/Group
  Air Pollution
  Pollution Control
  Standards of Performance
  Bulk Gasoline Terminals
  VOC
 Air Pollution  Control
    13b
  Unlimi ted
19. SECURITY CLASS (This Reponi
 Unclassified
I 21. NO. OF PAGES
i      136
                                             I 20. SECURITY CLASS ,'This page;
                                             i  Unclassified
                           |22. PRICS
."PA Form 2220-1 (Rev. 4-771   PREVIOUS  EDITION is OSSOLE'E

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