3ja tr* / *A "W tfii
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                FINAL  REPORT
     ECONOMIC ANALYSIS OF VAPOR RECOVERY
        SYSTEMS ON SMALL BULK PLANTS
                Prepared for
    U.S.  ENVIRONMENTAL PROTECTION  AGENCY
        Division of Stationary Source
            Office of Enforcement
            Washington, D.C. 20460
                    by

     R.  J.  Bryan, W.  Jacobson,  A.  Kokin,
          R.  Sakaida  and M.  M.  Yamada
Contract No.  68-01-3156, Task Order No.  24
       Project Officer:   John R.  Busik
       Environmental  Protection Agency
              September, 1976

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      This report has been reviewed by the Environmental Protection
Agency and approved for publication.  Approval does not signify
that the contents necessarily reflect the views and policies of the
Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.

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                         TABLE OF CONTENTS

Chapter                                                      Page

  1.       INTRODUCTION	 1-1

          1.1   PROJECT BACKGROUND AND SCOPE	 1-1

  2.       SUMMARY	2-1

          2.1   COST SUMMARY 	2-1
          2.2   FINANCIAL IMPACT 	 2-1
          2.3   RECOMMENDATIONS 	 2-2

  3.       BULK PLANT OPERATIONS 	 3-1

          3.1   BRIEF HISTORY 	 3-1
          3.2   GENERAL INDUSTRY DESCRIPTION	 3-1
          3.3   OWNERSHIP AND OPERATION 	 3-3
          3.4   TYPICAL BULK PLANT AND OPERATION 	 3-4
          3.5   INDUSTRY TRENDS 	 3-7

               A.  NUMBER OF BULK PLANTS 	 3-7
               B.  PROFITABILITY 	 3-7
               C.  DISPOSAL OF COMMISSION AGENT OPERATED
                   BULK PLANTS BY MAJOR OIL FIRMS	 3-8
               D.  KEYLOCK 	 3-8
               E.  STORAGE CAPACITY 	 3-8
          3.6   VAPOR RECOVERY REGULATIONS 	 3-9
          3.7   OTHER FACTORS AFFECTING BULK PLANTS 	 3-9

               A.  OSHA REQUIREMENTS	 3-9
               B.  FEA REGULATIONS  	 4-1
               C.  MISCELLANEOUS 	 4-1
  4.       HYDROCARBON CONTROL AT BULK PLANTS 	 4-1

          4.1   CONTROL TECHNOLOGY 	 4-1

               4.1.1  FILLING LOSSES  	 4-1
               4.1.2  BREATHING LOSSES 	 4-2

          4.2  INITIAL COSTS 	 4-3
               4.2.1  TRUCK-TRAILER TRANSPORT  	 4-3
               4.2.2  PLANT COSTS 	 4-5
               4.2.3  DELIVERY TRUCKS 	 4-8
               4.2.4  INSTALLATION COSTS BASED ON
                      PLANT THROUGHPUT 	 4-8
          4.3  OPERATING AND MAINTENANCE COSTS 	 4-9

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                     TABLE OF CONTENTS (Cont'd.)

Chapter                                                      Page

   5.      PROJECT APPROACH AND METHODOLOGY	 5-1

          5.1  QUESTIONS ABOUT BULK PLANTS TO BE ANSWERED  .. 5-1
               5.1.1  SELECTION OF STUDY AREAS  	 5-1
               5.1.2  PHYSICAL DESCRIPTION OF PLANTS  	 5-2
               5.1.3  BULK PLANT OPERATIONS  	 5-2
               5.1.4  COST OF VAPOR RECOVERY 	 5-2
               5.1.5  FINANCIAL IMPACT OF  VAPOR RECOVERY  ... 5-3

          5.2  INFORMATION REQUESTED  	 5-3
               5.2.1  INFORMATION REQUESTED  FROM THE
                      MAJOR OIL COMPANIES  	 5-3
               5.2.2  INFORMATION REQUESTED  FROM INDIVIDUAL
                      BULK PLANT OPERATORS 	 5-4

          5.3  SOURCES OF DATA  	 5-4
          5.4  DATA GATHERING  	 5-5
               5.4.1  USE OF A QUESTIONNAIRE 	 5-5
               5.4.2  PROBLEMS ENCOUNTERED IN OBTAINING
                      RESPONSES 	 5-5

          5.5  SUMMARY OF RESPONSES TO QUESTIONS 	 5-6
               5.5.1  EXPENDITURE LIMITATIONS FOR
                      BULK PLANT OPERATORS 	 5-6
               5.5.2  FINANCIAL INFORMATION  	 5-8
               5.5.3  ADDITIONAL COMMENTS  BY OPERATORS  	 5-10
               5.5.4  CLASSIFICATION  OF  BULK PLANTS	 5-10
               5.5.5  NUMBER OF DELIVERY TRUCKS	 6-1

   6.     MARKET ANALYSIS OF BULK PLANTS	 6-1
   7.     FINANCIAL ANALYSIS  	 7-1

          7.1  FINANCIAL DATA  AND STATISTICS 	 7-1
          7.2  FINANCIAL STATEMENT SUMMARY 	 7-8
          7.3  INVESTMENT IN VAPOR RECOVERY  SYSTEMS  	 7-9
          7.4  SOURCES OF CAPITAL  	 7-9
          7.5  ANALYSES OF FINANCIAL  CAPABILITY  	 7-11
          7.6  DETERMINATION OF LOAN  LIMITS  	 7-17

   8.     GLOSSARY  	 7-20

 REFERENCES  	 7-21

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                     TABLE OF CONTENTS (Cont'd)

APPENDICES
     A     QUESTIONNAIRES	  A-l
     B     LIST OF CONTACTS 	 B-l
     C     COMMENTS ON PROPOSED AMENDMENTS TO SAN
           FRANCISCO, CALIFORNIA BAY AREA AIR
           POLLUTION CONTROL DISTRICT REGULATIONS 	 C-l
     D     SUMMARY OF EMISSION INVENTORY AND COST
           ANALYSIS BY MISSOURI DEPARTMENT OF
           NATURAL RESOURCES  	D-l
     E     GUIDELINES FOR OBTAINING AIR POLLUTION
           CONTROL LOANS  	E-l


                           LIST OF TABLES

Table

4.1        INSTALLATION COSTS OF VAPOR BALANCE SYSTEMS  	 4-4

5.1        SUMMARY OF BULK PLANT OPERATORS RESPONSES TO
           QUESTION ABOUT THE MAXIMUM AFFORDABLE COST
           OF VAPOR RECOVERY	 5-7
5.2        SUMMARY OF FINANCIAL DATA OBTAINED  FROM
           INDIVIDUAL BULK PLANT OPERATORS 	 5-9

7.1        BALANCE SHEET  AND INCOME STATEMENT  FACTORS
           FOR WHOLESALERS OF PETROLEUM PRODUCTS 	 7-3

7.2        RATIO  ANALYSIS FOR WHOLESALERS OF
           PETROLEUM PRODUCTS  	 7-4

7.3        DEFINITION OF  RATIOS  	 7-5
7.4        PRO FORMA BALANCE SHEETS AND INCOME STATEMENTS
           FOR BULK PLANTS OF VARIOUS SIZE ASSETS  	 7-12

7.5        TOTAL  DEBT/NET WORTH  RATIOS  FOR TYPICAL  FIRMS
           OF VARIOUS ASSET  SIZES  AND EXPENDITURE  LEVELS  .... 7-13

7.6        ACCEPTABLE LOAN AMOUNTS BY FACTOR  	 7-19

                          LIST  OF  FIGURES

2.1        MAXIMUM DAILY  GASOLINE  THROUGHPUT  HISTOGRAM	 2-3

3.1        APPLICABLE GASOLINE DISTRIBUTION NETWORK 	 3-2
                                m

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                            PREFACE
      The purpose of this report is to provide economic data and
analysis to aid the Environmental  Protection Agency in assessing
the feasibility and reasonable applicability of vapor recovery
systems on bulk plants.   Other factors which should be used in
assessing feasibility and reasonable applicability may be mentioned
in this report but are not fully analyzed.

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1.    INTRODUCTION
     1.1  PROJECT BACKGROUND AND SCOPE
       In specific air quality control regions, Environmental Pro-
 tection Agency  (EPA) regulations for the storage of petroleum
 products and the transfer of gasoline require bulk plants to con-
 trol hydrocarbon emissions from their operations.  Vapor recovery
 devices are to  be installed and operated so that ninety percent,
 by weight, of organic compounds in the vapors displaced from tanks
 during transfer operations will be recovered rather than released
 to the atmosphere.  State implementation plans have included regu-
 lations that parallel these requirements, but in some cases, exempt
 or allow for local exemption of small bulk plants.  These exemp-
 tions have been generally based on the anticipated economic impact
 of these regulations.
        In response to a request from the EPA, Division of Stationary
 Source Enforcement (DSSE), Pacific Environmental Services, Inc. (PES)
 conducted a preliminary investigation of the economic impact of
 vapor recovery  systems on small bulk plants.  The purpose was to aid
 the DSSE in assessing the economic feasibility and reasonable appli-
 cability of vapor recovery systems on bulk plants.
        The scope of the five week effort was as follows:
             (A)  Select typical petroleum distribution areas
                  based on a brief survey of distribution
                  channels in the United States
             (B)  Define typical types of small bulk plants
                  and applicable vapor recovery equipment
             (C)  Define the total costs of typical vapor
                  recovery equipment
             (D)  Determine the financial profile of typical
                  bulk plants
             (E)  Estimate the long and short term economic
                  effects of control equipment
                                                                            1-1

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2.    SUMMARY

     2.1  COST SUMMARY

       The installation of vapor recovery on bulk plant facilities

 will cost an average of

                1)   for an incoming truck trailer transport,
                    if required
                                 $5000

                2)   for filling of storage tanks  at small  bulk plants
                                 $3600

                3)   for filling of storage tanks  at small  bulk plants
                    and the filling of transportable tanks from such
                    storage tanks

                         a)  if a loading rack does not have  to be
                             modified  to permit bottom loading
                                           $7900

                         b)  if a loading rack has  to be modified
                             substantially,  particularly to permit
                             bottom loading
                                           $41500

                4)   for an outgoing delivery truck
                                 $4400/truck

        These data  are exclusively for vapor balance systems,  which

 are the majority of actual installations.   Operating costs are not

 well established.


      2.2  FINANCIAL IMPACT

        PES financial  analysis  concluded that the critical  financial

 factor was the ability to obtain funds  for  initial  investment.

 Analysis indicates the smallest size  operation which could qualify

 for the loans needed  to obtain $30,000  for  vapor recovery  equipment

 was a throughput of about 3.8  x 10  liters/yr. (10  gal/yr).   This

 throughput level is consistent with what a  spokesman for  one  of the
                                                                             2-1

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major oil companies stated was the minimum throughput for a pro-
fitable bulk plant.
       In Figure 2-1, a histogram of maximum daily throughputs
for plants in surveyed areas of California and Colorado is given.
Fifty-one percent of these plants have maximum throughputs of less
than or equal to 3.8 x 10  liters/yr. (10  gal./yr.).  These are
the plants which our survey shows will not be able to cope vnth a
$30,000 expenditure.  Treating the information gathered in this
survey as representative of bulk plants throughout the country, it
appears that at least half of the small bulk olants in the country
wouTd not be able to continue to operate if this magnitude of
financial burden were to be placed on them.  This could presage
the closure of approximately 10,000 plants across the country.

     2.3  RECOMMENDATIONS
       This cursory survey indicated wide ranges in types of bulk
plant operations, in types of vapor recovery installations, in the
cost of these installations and in the regulations affecting vapor
recovery requirements for the several areas of concern.
       There is not yet a complete inventory of all bulk  plants
in the geographical areas affected.  There is also some uncertainty
as to the-compliance status of bulk plants in these numerous  loca-
tions.  More intensive discussions with the regulating agencies and
some field inspections are needed to prepare this type of industry
summary.
       Bulk plants in this survey were found to have throughputs
varying from less  than  1900 liters/day  (500 gal./day)  to  more  than
9500 liters/day  (25,000 gal./day).  Their vapor recovery  may  con-
sist of simple  submerged  filling  of  tanks or trucks  to vapor
balance systems with such secondary recovery systems as refrigera-
                                                                           2-2

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                                                         FIGURE 2-1
UJ
ca
5Q_ Maximum Daily Gasoline Throughput Histogram
56-
52-
48-
44-
40-
36-
32-
28-
HJ
20-
16-
12-
8-
4-















































2 46 8 10 12 14 16 18 20 - Gallons/Day xlO;3
7.6 15.1 22.7 30.3 37.9 45.4 53.0 60.6 68.1 75.7 - Liters/Day xl(T3
 I
 CO
                                                     Gasoline Throughput

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tion or combustion.  Also, bottom loading and underground storage
were found to be becoming more prevalent throughout the industry.

       The most important question to answer is the most difficult
and definitely needs substantial  consideration separate from the
limited scope of work of this project:   to what extent will  con-
trolling hydrocarbon emissions from small bulk plants reduce the
photochemical oxidant levels in surrounding areas?  Supplementary
information received from the San Francisco Bay Area and the
State of Missouri estimated reductions  in emissions resulting
from changes in the present strategy in these two areas.  Appendix C
contains comments on proposed amendments to the San Francisco Area
regulations.  Adoption of the proposed amendments summarized on
page C-7will reduce organic emissions  by approximately 664  metric
tons/yr0(730 tons/year)0  The State of Missouri calculates their
proposed strategy of requiring a vapor balance system for incoming
loads to a bulk plant having a throughput of greater than 1.1 x 10
liters/mo.(300,000 gal/mo.)would reduce hydrocarbons emitted from
bulk plants in the St. Louis area by 44.6% from 617 metric tons/yr.
(679 short tons/yrj to 342 metric tons/yr0(376 short ton/yr«,)»  The
total hydrocarbon emissions in the St.  Louis metropolitan area were
approximated at 110909 metric tons/year (122000 tons/yr,,). (See
Appendix D).  These two limited examples are intended only to
indicate the critical lack of information and the need for other
studies to be made to determine the impact of vapor control
strategies on the oxidant levels in the numerous areas of concern.
       How many plants will close because of the expense of  attempt-
ing to comply with vapor recovery regulations?  Is there a specific
limit of gasoline throughput or storage capacity any other measure
below which vapor recovery can be waived.  There will be plant clo-
sures regardless of what vapor control strategy is adopted,   the
                                                                         2-4

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 average  cost  of  adopting  storage  tanks  so  vapors  will  not  be  vented
 to the atmosphere when  an incoming  gasoline  shipment  is  unloaded
 was  found  in  this survey  to  be about  $4,000.   Even  though  this  is
 a  relatively  low cost,  there are  going  to  be  firms  which will need
 to spend much more than this  and  may  not be able  to afford it.
 Overall, the  installation of a vapor  balance  system for  receiving
 shipments  at  a bulk plant appears to  be a  reasonable,  feasible
 recommendation.
       The cost  of equipping  loading  racks and delivery  trucks  has
 been  indicated to be prohibitive  to approximately half of the bulk
 plant operations.   The uifficulties presented  by  the closing of this
 many  plants could have a  serious  impact on the availability of gaso-
 line  to small commercial  establishments and to agri-businesses.
       Secondary vapor recovery will add even more to the cost
 burden of  bulk plant opeation.  Secondary systems appear to add
 little to  transfer recovery efficiency while incurring cost,
 energy consumption, and safety penalties.
       At  this time the impact of proposed exemptions of bulk plants
 having a throughput of less than a specified amount is unclear.
 Such a regulation could encourage a  plant  owner to try to
operate several  small  facilities  rather  than  one  larger one in order
to circumvent  existing  regulations.   It  also may  encourage  service
stations  to be supplied  by bulk  plants in  order to be  exempt  from
regulations.  Although  some adverse  reactions  have been seen  in
California, no large scale trend  has  been  detected.
       Primarily because the  cost of vapor recovery would be  a
small  increment of the  cost of building  a  new  facility, it  is
quite feasible to require  new bulk plants  to  install  vapor
recovery  on both  incoming  and outgoing loads  during the original
construction.
                                                                         2-5

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30   BULK PLANT OPERATIONS
     3.1  BRIEF HISTORY
       Bulk plants at one time were a major link in the wholesale
distribution of gasoline and petroleum products (Ref0 6 and 7).
Forty years ago, bulk plants received gasoline by rail tank cars
(Ref. 11) shipped from relatively few refineries or terminals.
For example, an operator in San Diego County at one time' received
gasoline by rail from San Francisco.  From the bulk plant, the
majority of the gasoline went to retailers (service stations).
     3.2  GENERAL INDUSTRY DESCRIPTION
       Today, the rail delivery of gasoline has nearly disappeared
even though many bulk plants are still located near railroads
Typical  delivery of gasoline to the bulk plant is by tanker trailer.
This shift, in transport has allowed larger accounts not located near
the railroad to receive deliveries direct from a pipeline terminal
or a refinery.  This is especially true for gasoline retailers
(service stations).
       Thus, today the bulk plant is primarily a specialty petro-
leum products wholesaler/retailer providing the service of customer
delivery to those small accounts that 1) find it inconvenient to
bring small tanks to a large outlet, 2) have fixed storage tanks of
low capacity or 3) desire quick delivery due to highly variable
demand.   In addition, bulk plants may provide high delivery rate
equipment to those customers who bring tanks in to be filled.
       Figure 3-1 presents a schematic of that portion of the
                                                                           3-1

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                                       REFINERY
                                          BULK
                                          PLANT
                                              A
                                       V
                                      SMALL VOLUME
                                      ACCOUNTS
                                      AGRICULTURAL
                                      COMMERCIAL
                                      RETAIL
                                                            -r
                                                             i
                                                             i
                                                             i
                                                             i
                                                            &
  TERMINAL
                                                                                 V
      V
LARGE VOLUME
ACCOUNTS
RETAIL
COMMERCIAL
AGRICULTURAL
      A
  CUSTOMER
  PICK-UP
                                                                              o
                                    Typical  delivery route of truck-trailer
                                    Typical  delivery route of account truck
                                    Typical  transaction with  consumer coming to supplier
                                    Final  Product Usage
                                  Figure 3-1   APPLICABLE GASOLINE DISTRIBUTION NETWORK
CM

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gasoline distribution network most directly related to bulk plants.
The major competition for bulk plants is direct bulk sales from
the refinery or terminal.  Some advantages of a bulk plant over
direct bulk sales are 1)  closer proximity to customer 2) faster
response to variable customer demand 3) ability to use smaller
trucks able to reach off-road customer locations, and 4) ability
to store and supply other petroleum and related products required
by customer.  Some disadvantages of a bulk plant compared to direct
sales are 1) higher capital costs, 2) increased labor involved in
transfer, storage and filling of account trucks, and 3) small
account truck size may hinder ability to deliver to higher demand
accounts.
       A second potential source of competition for bulk plants is
large retail outlets.  Some advantages of a bulk plant over a
retail outlet are 1) convenience or necessity of "home" delivery,
2) higher delivery flowrate capability for bulk deliveries, 3)
a potential wholesale price and 4) a potential  lack of road taxes.
Disadvantages of bulk plants over a larger retail outlet include:
1) high capital costs, 2) increased labor costs for account truck
filling and transporting gasoline to site and 3) inability to service
user vehicles.

     3.3 OWNERSHIP AND OPERATION
       Although operation and ownership of bulk plants include
cooperatives and salaried employees,  the independent jobber and com-
mission agent are the predominant types.  The typical  independent
jobber owns the equipment and structures at his bulk plant, the
inventory and rolling stock.  He contracts directly with the oil
company to secure his gasoline at the most advantageous price and
then sells the  gasoline to his customer at terms he and the cus-
tomer negotiate.   He may market a nationally known brand of gaso-
line and related products, but he may market under his own brand.
                                                                         3-3

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A significant number of jobbers also own more than one plant and
service station.  A typical commission agent does not own the land,
structures or equipment at the bulk plant, but operates it*for a
major integrated oil company.  He will generally own his account
trucks and may contract with customers, but he operates within the
framework of the contract with the major oil company wliich is
supplying his products.

     3.4  TYPICAL BULK PLANT AND OPERATION
       The description of a typical bulk plant is based primarily
on a survey and inventory of plants in the Denver, Colorado and
San Diego and San Joaquin valley areas of California.  Census data
(Ref. 1) indicate that this description is generally valid for
other parts of the  country as well.
       In surveying bulk plant operations, only 3 of 167 responding
were found with throughputs greater than 19,000,000 liters/year
(5,000,000 gal./year),  Assuming working hours to be 5 days a
week, 50 weeks a year, this means  the overwhelming majority of bulk
plants have a daily throughput of  less than 75,700 liters/day
(20,000 gal./day).  Thus, for purposes of this study, a small bulk
plant will be considered to be a wholesale distributor of  less  than
75,7000 liters/day  (20,000 gal./day).  Thus, for purposes  of this
study, a small bulk plant will be  considered to be a wholesale
distributor of  less than 75,7000 liters of gasoline each day.   It
should also again be emphasized  that  all bulk plants surveyed
received product solely by truck.
       The majority of bulk  plants are  located in or near  towns
or small cities.  Storage  at  a typical  small bulk plant consists
of about five old,  above ground,  fixed  roof  storage  tanks  of approxi'
mately 49,000 to 76,000  liter  {13,000 to 20,000  gallon) capacity.
Tanks  are generally painted  white  or  silver, 3.2 meter  in  diameter
                                                                          3-4

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and 6.1 to 8.8 meter high (10H- ft and 20 to 30 ft).   Only about
three storage tanks are used to store gasoline, however.   The
remainder of the tanks, and drum storage, are used to store other
petroleum products, such as diesel fuel, fuel oil, kerosene, weed
oil, LPG and lubricants.  Underground storage tanks  and above
ground horizontal tanks, however, represent   significant minorities.
Underground tanks tended to be more prevalent in the larger cities,
were newer and smaller in capacity, typically 38,000 liter
(10,000 gallon) capacity.  Census data (Ref. 1) indicate that the
storage capacity for non-gasoline products, such as  fuel  oils, is
higher in other areas of the country, but that a major portion of
the business is still gasoline.
       Products are generally pumped into and out of storage tanks
with the same pump, typically at 380 liters/min (100 gpm), through
a total length of approximately 30 meters (100 ft) of 5.1 to 7.6 cm
(2 to 3 in) pipe.  Often incoming loads are delivered after normal
business hours.  Generally each transport will deliver about
34,000 liters (9,000 gal) of one grade of gasoline.   Frequency of
incoming loads for each grade of gasoline stored may vary consider-
ably based upon seasonal agricultural demand.
       Outgoing loads are generally delivered from one top loading
rack to the account trucks.  Truck capacities are generally 3800
to 7600 liters (1000 to 2000 gal.) with 4 compartments.  Account
trucks may load several times a day.  Contents of each compartment
vary with demand, but not all compartments will normally contain
gasoline.  In addition to truck deliveries, some accounts may
bring their small tanks or drums to the plant for refilling.
As shown in Figure 2.1 at 89% of the bulk plants gasoline through-
puts are under 38,000 liters/day (10,000 gallons/day) and at 50%,
the throughput is less than 15,000 liters/day (4,000 gallons/day).
                                                                           3-5

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       Data gathered in this survey indicate 60%, on the average,
of bulk plant sales gallonage is to agricultural  accounts whose
storage is all in tanks of no more than 550 gallons.  Since the
550 gallon storage tank is currently exempt from vapor recovery
regulations, it is important to know how much of a bulk plant's
sales are to this type account.  Bulk plants in the more urban-
ized Denver area sell slightly less gallonage--43%--to these small
accounts, but this is still a significant portion of their
business.  On the average, 20% of the gallonage a bulk plant
delivers is sold to service stations.  The remainder of bulk
plant accounts are with commercial establishments and agri-
cultural accounts with larger storage tanks.  The owners were
reluctant to describe accounts in specific detail.
       Other typical activities pertinent to vapor control emissions
include:  periodic measuring of tank level and temperature by
opening hatch and using plumb bob, thermometer and measuring tape
or stick; verification that incoming tanker trailer is empty after
delivery by opening truck hatch for visual inspection; priming of
pumps and elimination of air in lines by venting lines to the
atmosphere and flowing until gasoline appears at the vent; some
spillage; "as required" maintenance of pumps, dry breaks, hoses
and valves resulting in questionable containment of vapor and
some leakage from  liquid components.
       The "as required" maintenance is derived from on-site
inspections and the phone survey  results.  Results include: 1) only
two operators indicated any maintenance had ever been performed on
pressure vacuum relief valves, 2) visible gasoline leakage from
shut-off valves and quick disconnects, 3) rusted and painted-over
condition of typical pressure vacuum valves, 4) hydrocarbon odors
when on the tops  of  tanks, 5} an  observed loose vapor hose fitting,
and 6)  stained areas on the ground where leakage and/or  spills
have occurred.
                                                                          3-6

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     3.5  INDUSTRY  TRENDS
       A.   Number of Bulk  Plants
       Gasoline bulk plants  appear to be  diminishing  in  importance
in the marketing sector of the  petroleum  industry.  This conclusion
is reached based upon:  1)  Reference 1  (1972 Census  Data) versus
Reference  8 (1975 Survey By  National  Petroleum News)  showing a loss
of nearly  2,000 bulk plants  nationwide in a few years,  2) Reference  4
(Arco Actions)  and  3) Bulk plants  recently closed during survey  in
San Diego, San  Joaquin  Valley and  Denver  AQCR's. Reasons for this
decline are varied, but appear  to  be related to economic factors.
       These economic factors appear to be a result of  the extra cost to
transfer gasoline from truck to a  storage tank and  then  back to  another
truck.  Economies of labor and  capital are derived  if the initial  tank
truck can  deliver directly to an account.  In addition,  traditional
customers  may be declining.   Small service stations are  being replaced
(or eliminated, per Reference 8) by larger outlets  serviced from a
terminal or refinery. Many agricultural accounts now  primarily depend
upon diesel fuel burning and electrically powered equipment.  (Refer-
ence 2).  Typical agricultural  accounts are now large.   For example, a
typical San Joaquin Valley farm is 1500 acres, Reference 2, and  may
be able to obtain deliveries from  a terminal or refinery.
       B.   Profitability
       There appears to be a decrease in  profitability  in bulk plants.
This conclusion is  based upon 1)  statements by independent operators
during survey, and  2) difficulty in selling bulk plants as a going
business (Reference 10).  The reasons for this decline  are also varied,
but again appear to be related  to  economic factors.  Economic factors
may include: 1) a shift in profit  emphasis by major oil  companies from
expanding sales to  maximizing the  profit  per gallon,  2) an increase
in wholesale prices, especially to independent jobbers,  (One independ-
ent operator claimed the wholesale price  he paid for gasoline was
                                                                           3-7

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within one cent per gallon of retail gasoline price in the area)  and (3
competition from reduced margin self service stations.
       C.  Disposal of Commission Agent Operated Bulk Plants by
             Major Oil Firms
       Reference 4, as well as survey results, show a larger decline
in major oil company-owned bulk plants than the overall decline.
Typical disposal (Reference 10) involves offering the plant at a
reasonable price to the commission agent.  If agent elects not to pur-
chase the plant, plant is generally dismantled and the land is sold.
Again, economic factors appear to be responsible for disposal by major
oil companies.
       D.  Keylock
       A small number of  bulk plants surveyed were planning to install
Keylock Systems.  This conversion to a specialty, "self-service" retail
outlet yields  a very  low  cost margin potential but customers must be
able  to pick up the product.  The fate of  Keylock Systems again appears
to  be economics related,  that  is, whether  the price difference will
attract a sufficient  number of customers to pick up the product.
       E.  Storage Capacity
       Short term  reasons to maintain or expand bulk  plants are 1)  the
desire to  increase emergency fuel storage  capabilities should  an oil
embargo  or  other  shortage occur  and 2)  initial  establishment of no-lead
distribution.   No-lead  gasoline  demand may initially  be for small
 quantities,  also  a temporary lack of separate pipelines may  lead
 to  distribution through  existing bulk plants.   These  conclusions are
 based on  1)  survey results,  2) observed  tank  truck deliveries  of no-lead
 to  terminals,  and  3)  salvaging,  if  possible,  and moving of  storage
 tanks from closed  bulk plants  (Reference 10).   These  counter  trends,
 however,  do  not appear to strongly  influence the  fate of  bulk  plants.
                                                                            3-8

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      3.6   VAPOR RECOVERY REGULATIONS
        EPA,  state  and local air pollution regulations  are not  always
 consistent with respect to bulk plants.  For  specified AQCR's,  EPA
 presently  requires bulk plant  control of emissions  for incoming,  out-
 going  and  customer deliveries** Exemptions  are  limited.  Present
 California ARE regulations, however modify  exemptions.*  Local  county
 APCD's may further modify these regulations.  Bulk  plant operators
 surveyed  in  California were generally confused  about  1)  status  (exempt
 or  non-exempt), 2) whether they must comply with  state or federal regu-
 lations,  and 3} future changes.
        Some  bulk  plants owned  primarily by  major  oil  companies  have
 installed  or are  planning to  install vapor  recovery in locations  where
 bulk plant could  have been partially exempt from  vapor control  regula-
 tions. These are generally major renovations costing in the order of
 $100,000.  Renovations in the  cases of  three  particular  plants  in
 central California have included:  1) installing a vapor  balance system
 for incoming loads,  2) replacing  existing above ground tanks with new
 underground  tanks, 3) converting  loading rack to  bottom  loading,  4) re-
 plumbing  the facility, usually with larger  diameter piping,  5)  making
 certain spill control and other regulations are complied with,  and 6) con-
 verting all  trucks to bottom  loading with vapor recovery.

      3.7   OTHER FACTORS AFFECTING BULK  PLANTS
        A.  OSHA Requirements
        OSHA  spill  prevention  requirements requires  draining  and diking of
 aboveground  storage  tanks.  Associated  requirements include  explosion
 proof pump motors, safe walking and working surface and  additional safety
 equipment  for personnel and facilities  to comply  with  the Occupational
 Safety and Health Act (Reference  3).  The additional  expense of even very
 low cost  vapor recovery equipment can be the  "straw that breaks the
 camel's back."
 *Title 40, Part 52 of the Code of Federal  Regulations
**Suggested Vapor Recovery 'Rules Approved April  17,  1975
                                                                          3-9

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       B.   FEA Regulations
       Federal Energy Administration (FEA)  regulations can also
have a strong impact on the future of bulk  plant operations.
Title 10,  § 211.9 of the Code of Federal  Regulations (1976 edition)
requires the FEA must approve of any changes in gasoline supply to
"all wholesale purchaser-resellers and all  wholesale purchase-consumers"
except where there is mutual  consent of the supplier and wholesale
purchaser to terminate the relationship.   Discussions with the FEA
(Reference 5) indicated changes to individual  wholesalers are gener-
ally approved as long as the total supply to a region is not signifi-
cantly affected.  These regulations appear to promote the status quo
relationship between the supplier and the wholesaler, but their effec-
tiveness is unclear.
       C.   Miscellaneous
       Bulk plant operators are active politically (Reference 12)
and are involved with the appropriate regulatory agencies to mini-
mize the impact of regulations including any vapor control strategy.
This activity is in conjunction with the strong desire of small farmers
to maintain low fuel costs.  Other miscellaneous factors noted by
operators during the survey included: 1) fire code regulations, 2) theft
and 3) availability of insurance at reasonable rates.

4.   HYDROCARBON CONTROL AT BULK PLANTS
     4.1  CONTROL TECHNOLOGY
          4.1.1  Filling Losses
       Neglecting spillage, two major sources of loss of gasoline
vapor during transfer are: 1) venting to the atmosphere the volume
of gases (air and hydrocarbons) displaced by the entering liquid
and 2) filling in a manner which creates turbulence (splash loading)
thereby resulting in increased vaporization rates and liquid droplet
entrainment in the vapor space.
                                                                          4-1

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       Among current methods of eliminating venting losses during
filling, the most common is the installation of vapor transfer lines
between the vapor spaces of a tank being filled and one being emptied.
This permits vapor balancing between the two tanks.  In addition to
minimizing hydrocarbon losses this procedure tends to minimize air
input into the tank being emptied.
       Other methods of controlling emissions involve processing or
vacuum assisted collection of vapors, in conjunction with a balance
system.  However, very little application of these methods to bulk
plants has been found.  This is generally due to high cost, safety
problems and operating problems.  At the time of the survey, only one
out of ten bulk plants in San Diego County had an operating secondary
system, and it did not recover any gasoline.  Impact of these other
methods will, therefore not be considered further.
       Submerged filling of gasoline therefore, is the common method
of reducing turbulence and minimizing vaporization of droplet entrain-
ment.  It is also the recommended safety practice of the National Fire
Protection Association (Reference 9) and NIOSH (Reference 3).  The costs  to
install submerged fill tubes on bulk plant tanks and trucks are gener-
ally small enough to be insignificant.  Many facilities have already
installed these drop tubes and some customers have done so as well.
Therefore, only the impact of vapor balance systems for incoming and
outgoing loads will be considered.
          4.1.2  Breathing Losses
       Storage tanks are subject  to evaporation or standing losses due
to volatility of the material stored, type and condition of the tank
and its appendages and prevailing meteorological conditions.  The
simplest methods for reducing these breathing "losses are to 1) inspect
and repair leaks in the tank and  fittings, 2) paint the tank with
silver or white paint where possible, 3) assure that vent valves do not
                                                                          4-2

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leak and, 4)  set the pressure and vacuum relief settings to minimize
breathing.   The broader the bank for the vent valve settings,  the
lower will  be the breathing losses.
       Another method for preventing vapor loss is to install  vapor
recovery equipment at the vent valve.   For vapor recovery, the vented
vapor must be able to be condensed and recycled to the tank or be
collected and regenerated.  For prevention of pollution only,  the
vapors can be combusted or collected and disposed of in some approved
manner.
       Regulations do not generally require specific control of breathing
losses.  No further consideration will therefore be given to these
control methods.

     4.2  INITIAL COSTS
          4.2.1  Truck-Trailer Transport
       Cost estimates for installing vapor recovery and bottom loading
on a supply truck and trailer range from $1,000 to $1,600 per compart-
ment, with the total cost ranging from $3,500 to $10,000.  The most
commonly quoted cost was $5,000 (Table 4.1), which would be for four
compartments at $1,250 per compartment.  Generally, trucks originally
designed for top loading are also modified to allow for bottom loading
at the time vapor recovery system is installed.  This is probably
responsible for the higher quotes received from operators, since addi-
tion of vapor recovery only is estimated to cost about $2,400.
       The truck delivering to the bulk plant is frequently owned by
the major oil company who supplies gasoline to the plant or is a
commercial carrier.  The transport, regardless of its ownership may
also often be used to haul other products which may also need to have
a vapor control system.  For these reasons, the cost of installing
vapor  recovery on a truck trailer transport is not being included as
                                                                          4-3

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                        Table  4.1   INSTALLATION COSTS OF  VAPOR BALANCE  SYSTEMS ($  x 10"3)
"^\^
DATA SOURCE ^^^^

Jobber
Major Oil Co.
Contractor ' '
PLANT THRUPUT IN
(LITERS/DAY (GAL/OAY)
3,800 (1000)
15,100 (4000}
76,000 (20,000)
INCOMING TANK/TRAILER
Vapor Recovery and
Bottom Loading
Low. Ave. High
3.5 5.0 6.5
0.6 5.1 10.0

Not applicable
Not applicable
Not applicable
BULK PLANTS
Vapor Recovery for Vapor Recovery for Vapor Recovery and
Incoming Load Both in & Out Loads Bottom Loading Rack
Low Ave. High Low Ave. High Low Ave. High
0.65 3.4 8.0 6.4 7.3 9.0 24 4,1.8 85
0.6 4.3 7.6 	 21 44.8 55
0.2 3.6 18.0 6.0 9.0 11.5 4.5 19.7 33
(21.5) (27.3)

3.6 7.9 41.5
3.6 7.9 41.5
3.6 7.9 41.5
DELIVERY TRUCK
Vapor Recovery and
Bottom Loading
Low Ave. High
2.0 4.3 9.0
3.5 4.6 6.0
Z.5 4.8 7.5

4.4<2>
8.8
26.4
(1) values in  parentheses  from omitting  $4.5K data, which was minor conversion of modern top loading facility to bottom loading
(2)  1  truck for 3,800 1/d  thruput, 2 trucks for 15,100 1/d and 5 trucks for 76,000 1/d thrjput

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part of the cost the typical  bulk  plants  will  need  to  bear  to  equip
their facilities with the  necessary vapor control system.

          4.2.2  Plant Costs
       Gasoline storage capacity at bulk  plants surveyed has  ranged
from 22,700 to 492,100 liters (6,000 to 130,000 gallons).   The largest
tank located held 151,400  liters (40,000  gallons);  most hold  49,200
to 75,700 liters (13,000 to 20,000 gallons).   The majority  of tanks  are
presently above ground with underground tanks  of typically  37,900 liters
(10,000 gallons) capacity  located primarily in the  largest  cities.
Several costs may be involved within the  plant including the  installa-
tion of:
            1.  Vapor recovery for incoming loads
            2.  Vapor recovery for incoming and outgoing loads
            3.  Other modifications, such as bottom loading
       Cost estimates for installing vapor return for incoming loads
have ranged from a few hundred dollars for purchase of pipes, fittings
and self installation to $18,000.  An average estimate for self installa-
tion is $1,500 and for contractor installation an estimated average range
of  $3,400  to  $4,300 depending on the source of information (Table 2.1).
       Only a few data points were obtained for costs of installing
vapor  recovery for both incoming and outgoing loads without also con-
verting to bottom loading but indications are that average costs will
be  approximately $4,000 higher than for  installation of vapor recovery
systems on incoming  loads alone. (Table  4.1)
       The great majority of data  indicated that if vapor recovery
were  required for outgoing (loading of account trucks) transfers,
account trucks would  be converted  from top loading to bottom  loading.
This  conversion  generally requires  a complete  replacement of  the load-
 ing rack  (buried piping, meters, fittings, pumps, electrical  controls,
and interlocks).
                                                                           4-5

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        Estimated  installation  costs of plant vapor recovery and bottom
 loading systems for  incoming and outgoing loads range from $4,500 to
 $85,000.   The most common  costs ranged from $30,000 to $50,000.  This
 extremely  wide range of  cost estimates reflects the considerable
 differences  among bulk plants.  Some of the variations between installa-
 tions  which  can affect cost of vapor recovery are as follows: 1) number
 of  tanks,  2)  location of tanks, i.e., above or below ground, 3) amount
 of  pipeline  between  tanks  and  loading rack which would need to be re-
 placed or  moved,  4)  modifications  to the loading rack required or
 desires, e.g. conversion from  top  loading to bottom loading  , 5) avail-
 ability and  cost  of  contractors and labor force, 6) amount of ancillary
 work  to be done,  e.g., excavation, repaving, pump purchases.
        Thus,  although the  cost data does not appear to strongly corre-
 late  with  plant characteristics of throughput or size, certain factors
 have  become  apparent.
        Age of the facility generally increases modification costs.
 Tanks  would  normally be  above  ground for older plants and require
 longer vapor transfer lines.   These older tanks may also require sealing
 of  leaks to  permit operation of vapor transfer and modifications to the
'structure  to permit  installation of pipes and fittings required for
 vapor conservation systems.  More  modifications and modernization would
 probably also be  required  at the truck loading and unloading racks,
 leading to higher costs  for older  bulk plants.
        The plant  modification  which critically affects the cost of
 outgoing vapor  recovery  systems is the conversion of loading racks to
 bottom loading  for outgoing trucks.  Integration with customer and
 supplier vapor  recovery  requirements, improved vapor recovery efficiency,
 and costs  similar to top load  vapor recovery systems are reasons given
 for this bottom loading  capability.  One manufacturer has stopped pro-
 duction of vapor  recovery  equipment for top loading installations
 (EMCO Wheaton top loading  vapor recovery loader - E293).  The apparent
                                                                           4-6

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cost of this plant modification is  upwards of $20,000 which includes
renovation of the loading rack.  A  typical low cost conversion was
accomplished for $4,500 at a relatively modern (approximately 8 years
old) facility with underground tanks where minimal  modification
(essentially only attachment of an  extension hose)  was made to the top
loading rack.
       Whether to include the cost  of bottom loading conversion in
the cost of vapor recovery is open  to question.  In addition to the
aforementioned reasons related to vapor recovery, other valid reasons
to install bottom loading exist.  Independent of vapor recovery, these
reasons include: 1) safety—the potential  for falls is eliminated, 2)
reduced labor costs—operator is not required to climb to the top of
the truck to open and close hatches, 3) versatility—allows the loading
of account trucks at bottom loading terminals, and  4) increased flow-
rate—potentially reduced loading and unloading times from modernized
equipment and enlarged pipe diameter.
       Another plant modification which has been made in a number of
plants at the same time vapor recovery was installed was relocating
the storage tanks underground.  This could cost an additional $25,000
to $40,000 depending on the number of tanks.  Installation of under-
ground storage does not appear to be related to compliance with vapor
recovery  requirements and will not be included in vapor recovery costs.
       Estimates of initial costs for contractor installations at the
plant are somewhat higher for the major oil companies as compared to
the jobbers.  This higher cost for the major oil companies appears to
be the result of installing systems with more controls and versatility
than that put in by jobbers, the hiring of larger contractors to
install systems in all plants within a given region and possible pay-
ment of travel and per diem as the contractor moves from plant to
plant.  The smaller jobbers also tend to do by themselves what they
can do to decrease costs.
                                                                            4-7

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        For  the  purpose  of  this  study,  the full cost of converting
to  bottom loading will  be  included  in  the cost of vapor control.
The reasons for this  inclusion  are:  1)  conversion to bottom loading
at  small throughput  (under 11,400 liters/day) bulk plants surveyed
occurred only when required by  vapor recovery regulations, and 2)
a majority  of plants  will  convert to bottom  loading when required
to  install  vapor recovery  systems to control losses from loading
outgoing delivery trucks.   Future studies may be able to refine
the actual  vapor recovery  cost  to include only a portion of the
bottom  loading  modification costs.

          4.2.3  Delivery Trucks
       For  small bulk plants, typical account trucks  have a  capacity
of approximately 4,500 liters (1,200 gallons) which deliver  to accounts.
Cost estimates to install vapor return on these delivery trucks have
ranged from $2,000 to $9,000, with the average cost about $4,400.   As
in the case of delivery transports,   higher costs are  associated with
the conversion of the truck from top loading to bottom loading.

          4.2.4  Installation Costs   Based on Plant Throughput
       Plant costs for  the  installation of vapor balance systems
have been assumed to  be similar for  plants of various sizes; thus
average costs were used regardless of throughput as shown in Table 4.1.
Gasoline throughputs  of 3,800, 15,100 and 76,000 liters per day were
assumed to  require one, two and five delivery trucks, respectively.
This is based on survey results of 1.4 trucks for gasoline throughputs
of  1-7,600  liters (1.2  trucks for Denver AQCR), 2.1 trucks typical
overall average  and 5.2 trucks for plants with gasoline throughputs
above 60,600 liters.  From data obtained thus far, an average cost
for plant conversion  to vapor recovery and bottom loading would be
$41,500 plus $4,400 per truck.  A point of comparison is an estimate
by Mr. Maple (FEA) of $50,000 to $80,000 for conversion of a plant
with 1.9 to 3.8  million liters/yr (0.5 to 1  million gals/yr) through-
put and three trucks  to meet EPA and OSHA requirements (Reference 5).
                                                                         4-8

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     4.3  OPERATING AND MAINTENANCE COSTS
       Only a few bulk plant operators have had long term experience
with vapor recovery systems.  Thus cost information is limited
Maintenance costs for vapor balance and bottom loading are generally
expected to be minimal since major additions are in the form of fixed
piping and valves.  Transfer hoses and mating fittings will  require
replacement.   Installation of automated controls for loading and un-
loading of gasoline may impose additional maintenance requirements.
       Operating costs were not directly obtainable.  However, 13 of
25 bulk plant operators who had their equipment modified and one major
oil company representative have indicated an increase in time required
to transfer gasoline.  This estimated increase in time ranged from 10%
to 100%.  Some operators reported a decrease in time required to trans-
fer gasoline due to upgrading of the transfer platform, pumping station
and line sizes.
       Based upon their experience with balance systems in service
stations, one major oil company estimated the annual costs of a balance
system in a bulk plant to be apportioned as follows:
          Expenditure                Annual Cost of Operation
   Interest (8 years at 10%)                    6.2%  of initial system cost
   Depreciation                                12.5
   Property taxes                               2.5
   Maintenance                                  3.0
                                               24.2% of initial system cost
       A California operator, with sales of 5.7 x 10  liters gasoline/
year (1.5 x 10  gallons/year), estimated his costs were 15% of gross.  In-
stalling a vapor balance system on his facility will initially cost
$45,000.  If the annual cost of this system is approximately one-fourth
the initial costs, his total expenses will increase to 16.5% of gross.
                                                                           4-9

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       Thus, although miscellaneous costs for vapor recovery may be
very significant, it appears that the primary impact is directly
related to the initial cost.  The conclusion is based on, 1) low
maintenance required for piping, 2) trend to replace low flow rate
equipment and lines when vapor recovery is installed, and 3) no
observed change in accounts served per truck.  Therefore, miscellaneous
costs, except those directly related to initial costs, will  be ignored.

5.   PROJECT APPROACH AND METHODOLOGY
     5.1  QUESTIONS ABOUT BULK PLANTS TO BE ANSWERED
          5.1.1  Selection of Study Areas
       Eighteen geographical areas across the country are presently
affected by the promulgation of regulations requiring bulk plant
operations to use vapor recovery systems for better control  of hydro-
carbon emissions.  These include the air quality control regions
surrounding Los Angeles and the Sacramento and the San Joaquin
Valleys in California; Denver, Colorado; Washington, D.C.; Baltimore,
Maryland; Boston, Massachusetts; New York City, New York; Philadelphia
and Pittsburgh, Pennsylvania; Dallas-Fort Worth, Houston-Galveston,
San Antonio, Austin and El Paso, Texas; Marion County, Indiana; and
San Diego County and the San Francisco Bay area, California.
       Inquiries were made in all these areas to first determine
exactly what is required in each area and then to find out which bulk
plants were affected.  In doing this, P. Roberts of the Texas State
Agency said public hearings are just now being held to discuss pro-
posed regulations in Texas and for this reason no bulk plant had yet
taken any action to modify a facility.  Only one plant in Maryland
areas of interest has installed a vapor balance system, according to
a survey provided by D. Andrew of the state agency.  No plants meet-
ing the definition of receiving product solely by truck were idenfi-
fied in Boston and Connecticut areas by'the air pollution control
                                                                          5-1

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agencies concerned with these areas.  No response was received from
the New York and New Jersey agencies.  These portions of the country
were omitted from further investigations because of the sparseness
of information.

          5.1.2  Physical Description of Plants
       An adequate physical description of a bulk plant included the
number and capacity of storage tanks, whether they are above or below
ground, the number and capacity of trucks, and the type of loading used.
The vapor recovery system would be described by type, manufacturer
and installer.  Bulk plant owners and operators were the sources of
information.

          5.1.3  Bulk Plant Operations
       Questions to be answered concerning a bulk plant's operation
focused on sales, expenses and profits.  Gasoline throughputs, margins,
operating expenses, gross or net profits, net worths, original invest-
ments, break even points, and associated revenue sources were all
information requested from the operators and owners.

          5.1.4  Cost of Vapor Recovery
       It was planned to try to determine the cost of buying and
installing each increment of equipment required in the plant and
the cost of modifying trucks.  Among operating and maintenance
costs were included changes in taxes, insurance and in the time
required to load or deliver product.
       Cost data were obtained from owners and operators, equipment
manufacturers and contractors.
                                                                          5-2

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          5.1.5  Financial  Impact of Vapor Recovery
       The financial impact of installing vapor recovery on specific
bulk plants was examined by seeking information from the operators
on costs, income, assets and debts.  The owners were asked for their
own evaluation of what each could afford.  An attempt was also made
to learn how the bulk plant owners' actions would affect customers.
       Because of the anticipated difficulty of obtaining information
on a sufficient number of individual plants, financial statements
were created for seven hypothetical, but probable operations, based
upon summary data published by Robert Morris Associates for bulk
petroleum wholesalers.  An  estimation of the financial impact of
vapor recovery expenses in  excess of $30,000 by each of the seven
firms could then be made.  The results and a detailed description
of the evaluating process is in Section 7.

     5.2  INFORMATION REQUESTED
          5.2.1  Information Requested From the Major Oil Companies
       The first task was to determine how each company managed bulk
plant operations.  As was stated earlier, an oil company may choose
to distribute gasoline through commission agents or through independ-
ent jobbers or both.  Nationwide 58% of the bulk plants are operated
by independent jobbers (Reference 8).  Here a topic of considerable
importance was a company's  policy concerning future bulk plant opera-
tions.  Questions were asked about the number of plants owned and
supplied and any plans to close or sell plants or expand operations
or make major modifications to existing facilities.
       Cost information was requested, as was information on how the
cost burden would be shared.
       Financial data desired included margins, profit rates, income,
assets, expenses, debt structure and rate of return on investments.
                                                                           5-3

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       Questions on the economic impact centered on learning what
factors influenced decisions to install vapor recovery at any given
plant and on learning what effects plant closures would have on the
distribution system and the consumer.

          5.2.2  Information Requested From Individual Bulk Plant
                   Operators
       Both distributors and jobbers were contacted.   A brief descrip-
tion of the plant and the vapor recovery system installed were obtain-
ed as introductory information.
       In gathering cost data, an effort was made to separate installa-
tion costs, maintenance costs and operating costs.
       Financial data similar to that requested from the major com-
panies were also sought from the independent jobbers.
       The economic impact focused on what each individual  could
afford, how he could finance the equipment and what would happen to
him and his customers if he were unable to stay in business.

     5.3  SOURCES OF DATA
       Phone contacts were the principal means of interviewing people
throughout the industry.  Written communications and some personal
interviews supplemented the data gathering portion of this task.
Agencies, associations and others contacted included:
               1.  Various state and local air pollution control
                     agencies (11)
               2.  Industry associations (8)
               3.  Major oil company representatives (16)
               4.  Bulk plant operators (50)
               5.  Miscellaneous state and federal agency
                     representatives (5)
               6.  Principals involved in an Arco-bulk plant
                     operators suit (3)
                                                                           5-4

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A list of the pertinent contacts is presented as Appendix B.
       Literature searches were conducted at University of Cali-
fornia at Los Angeles Graduate School  of Management library and
the Public Affairs Library.  Among information sources used were the
1975 statistics compilation of Robert  Morris Associates, Standard and
Poor's business index, and financial summaries of individual  companies
compiled by Dun and Bradstreet.

     5.4  DATA GATHERING
          5.4.1  Use of a Questionnaire
       Two questionnaires were prepared for use with the majority of
verbal discussions:  one is directed toward the individual operator;
the other, toward the major oil company who markets through consignees
or distributors.  A sample copy of each is given in Appendix A.

          5.4.2  Problems Encountered in Obtaining Responses
       In telephone communications with the major oil companies,
several were reluctant to give more than the most general information.
Written requests were more productive, although the time constraints
of this task made it somewhat difficult to receive a response  in time
for inclusion  in this report.  A personal meeting with two representa-
tives enabled  PES staff to obtain answers to most questions and to be
offered additional, future assistance by one company.
       Overall, any generalizations or conclusions derived from data
supplied by  the major oil companies are based on the replies of only
a minimum number of divisions and companies.
       The bulk plant operators were contacted  solely by  telephone.
Understandably, several did not want to discuss their financial
situation.
                                                                          5-5

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       Primarily because most systems have been installed in 1976,
very few operators were able to make a reasonable estimate of how
maintenance and operating costs have changed as a direct result of
vapor recovery installations.
       Quite often operators reported the total cost of all plant and
truck changes made at the time vapor recovery systems were installed.
There is a problem in determining the need for such associated plant
changes as installing tanks underground, buying new trucks instead  of
modifying older ones and installing bottom loading facilities.

     5.5  SUMMARY OF RESPONSES TO QUESTIONS
          5.5.1  Expenditure Limitations for Bulk Plant Operators
       Asking the hypothetical question "what is reasonable cost of
vapor recovery equipment" resulted in very few answers.  The smallest
operators are willing to consider $1,000 or $2,000 and maybe even
$3,000.  The larger operators will consider up to $20,000.
       Asking the hypothetical question "if vapor recovery initially
cost $20,000 and operating  costs increased 20%, could you  stay in
business," over one-third emphatically stated they would have to
close and over 15% had  serious doubts as to their fate.  These
responses are tabulated  in  Table 5-1 and show that not one independ-
ent jobber who sold 23  x 10 liters  (6 million gallons) annually or
less of gasoline  felt that  they would remain open if vapor recovery
systems cost $30,000.   Thus, even very large throughput bulk  plants
would be subject  to financial  hardship.  The maximum expendable cost
for operators handling  3.8  x 10  liters (one million gallons) of
gasoline annually was $20,000.  One  operator was already disposing
of his plant saying that the costs were too high.
       Excluded  from  this  table are  three  plants at which  a major
integrated oil  company  had  installed recovery  systems.
                                                                            5-6

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       Table 5.1   SUMMARY  OF BULK PLANT OPERATORS RESPONSES TO
    QUESTION ABOUT THE MAXIMUM AFFORDABLE COST OF VAPOR RECOVERY
    Gasoline Throughput
IP6 liters/yr (IP6 gal/yr)
Cost of Vapor Recovery System
0.95
1.9
2.7
3.8
3.8
3.8
5.3
5.7
5.7
6.4
6.8
7.6
7.6
7.6
11.4
18.9
22.7
22.7
22.7
64
95
(0.25)
(0.5)
(0.7)
(1-0)
(1.0)
(1.0)
(1.4)
(1.5)
(1.5)
(1.7)
(1.8)
(2.0)
(2.0)
(2.0)
(3.0)
(5.0)
(6.0)
(6.0)
(6.0)
(17.0)
(25.0)
Will Close
Plant
20
20
20
10
Can
Spend
($ X 10-3)
$10
-
_
                                            20
                                            30
                          20
                          10
                          20
                          20
                                             Closing (Too Expensive)
                                                               10 to 20
                                            30
                                            30
                                            20
                                            20
                                            30
                                            30
                                            20

                                            20
                          20
                          10
                          20
                          10
                          20

                          30
                          30+
                                                                            5-7

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       Most operators who replied that they would have to close said
they would go into some other petroleum industry such as selling
gasoline retail or continue to sell other petroleum products wholesale.
A few said they would retire.  Their customers would have to find
new supplies on their own initiative.  This would probably mean find-
ing another bulk plant to deliver to him.  Arranging for delivery
directly from a terminal could be difficult because 1) the distance
from the terminal to the customer could be great enough that the
delivery charges could be prohibitive and 2) the customer might not have
enough storage to be able to receive a portion of a load from a trans-
port, making direct delivery even more uneconomic.
       The major oil companies are paying for installing vapor
recovery only on the portions of bulk plants they own.  Thus, all
plant modifications will be made for a consignee, but the consignee
will need to install vapor recovery for his own trucks.  An independent
jobber will have to assume all costs himself.  This potentially could
affect over 12,000 bulk plants throughout the country.
       No surveyed operator feels he will be able to pass on the costs
of vapor recovery to his customer.  He has to remain competitive to
keep his accounts, so he can't raise his prices.  Even if every one in
an area were affected and a price increase would be possible, the opera-
tors seem very unsure as to what they are able to do within the frame-
work of the current price control programs and regulations.

          5.5.2  Financial Information
       Among the fiscal data requested were market value of the facil-
ity, original investment assets, annual sales, margins, profit, ex-
penses and debts.  Most operators were either reluctant to divulge all
this information or they did not have it readily available.
       The responses, summarized in Table 5.2, cover a very broad
spectrum.  The small sample size also limits the conclusions which
can be made based on data obtained from the individual bulk plants.
                                                                         5-8

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                 Table 5.2  SUMMARY OF FINANCIAL DATA OBTAINED FROM

                           INDIVIDUAL BULK PLANT OPERATORS
Sales
lil lion
.iters/yr..
7.6
1.4*
15.1*

7.6*
5.3
3.6*
8.5*
2.7*
5.1*
2.7*
2.7
6.8*
6.4(x)
(*)

(x)
5.5*
5.5*
5.5*
5.5*
9.5*
4.1
8.9
2.7*
8.2
4.6

4.6
Million
gal/yrv
2
.4
4

2
1.4
3.6
2.2
.7
4
6
6
1.8
17



1.4
1.4
1.4
1.4
2.5
1.5
5
.7*
3
25.

25. *

$/yr.
430,000




700,000*


360,000*
2,000,000
3,000,000
3,000,000

9,000,000
2,300,000

4,000,000
500,000*
500,000*
500,000*
500,000*
900,000*
720,000*
2,250,000
350,000*
1,500,000*
12,000,000

12,000,000
Margin

(t/Liter
.90
.92
.79
.72
.95-1.3
1.1

1.3
1.3
1.1
.26-. 79
1 .8 max

.99
1.3


1.1

1.6-1.8

.79-. 92
1.2
1.3
1.3





U/gal.)
3.4
3.5
3.0
2.75
3.6-5
4.2

4.8
.5
.4
1-3
.7 max

3.75
5


4

6-7

3-3.5
4.5
5
5-7.5


2.5-3
9%
Costs/vr.


$ 58,000*




$105,000*



SI 56, 000*
$180,000*
$360,000

$460,000





$ 70,000*


$108,000*





$10,000,000
Profit/yr.


$10,000

0
0

$22,400net


$14,400*
4,000*
0
30,000

$769,000 gr
$458,000 gr
32,000 net
$160,000 net





$ 21,600*


18% gross
3 1/2 (t/gal
gross
$ 90,000 net*
i
Net Worth)






<$300,000
<$290,000




<$250,000'



$194,000

$524,000









>$1 ,000,000

<$3,000,000
(x) Costs & Profits of selling other petroleum products may be included in
    data obtained.
*   Calculated from other information given.
                                                                                    5-9

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          5.5.3  Additional Comments by Operators
       Numerous operators are complaining about "spit back"  when
deliveries are made to customers with submerged fill  tubes.   "Spit
back," which is spillage from the fill port while the tank is being
filled, has been described as occurring, 1) continuously, 2) only
in hot weather, 3) only when the fill pipe outlet is  very close to
the bottom, 4) only when the fill pipe diameter is rather small, 5)
only during the last minutes of filling, or 6) only when shutting off
the nozzle.  Several accidents, ranging from the driver being splashed
to a major fire, have resulted.  Estimates of the amount spilled, the
seriousness of the problem and methods used to minimize the problem
are now being evaluated by at least one regulatory agency, the
California Air Resources Board.

          5.5.4  Classification of Bulk Plants
       In order to perform the needed economic analysis, an attempt
was made  to determine a means of classifying similar bulk plants
and of defining a typical operation based on these responses.  In
this section, the various scenes for  classifying plants are described
and the reasons for selecting or discarding a particular scheme is
given.
                    a.  Ownership of  the Plant
       A  plant may be owned  by a major oil company or a small business-
man.  The financial capability of the major oil  company to  install
vapor recovery systems  on  its plants  is not in doubt.  The  capability
of  the independent  is.  To use ownership as a  basis  for regulation is
discriminatory; a major oil  company  cannot be  required to install
vapor  recovery on one of  its plants  if  an  identical  plant,  independently
owned, is exempt.
                                                                             5-10

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                    b.  Gasoline Throughput
       The owner's financial  ability—cash flow, profits,  net assets--
general ly increases significantly with throughput, while the cost per
gallon on vapor control  equipment decreases.
       Figure 2-1 presents a histogram of maximum daily gasoline
throughputs for California and Colorado areas sampled.   These data
were primarily obtained by a telephone survey of owners or operators.
Based upon these data, three gasoline throughputs will  be  assumed as
typical for purposes of this analysis: 3,800 liters/day (1,000 gallons/
day) is a small throughput, 15,140 liters/day (4,000 gallons/day) is
an average throughput and 75,700 liters/day (20,000 gallons/day) is a
large throughput.
       The corresponding differences in equipment is primarily in the
number of account delivery trucks.  A typical small throughput plant
will have one truck, an average throughput plant, two trucks, and a
large plant, six trucks.  Most of the other differences, such as
changes in storage capacity plant size, and size of trucks, do not
appear to be significant.  It should be noted that the large plants
tend to have newer equipment, which tends to lower cost for vapor
recovery equipment.  Also, they tend to have a smaller percentage of
small agricultural customers.
                    c.  Location
       Some localities regulate the location or size of storage tanks
or gasoline trucks.  Boulder, Colorado, for example, limits the size
of trucks within the city limits.  Thus zoning and other restrictions,
land values, railroad access, and customer location have tended to
restrict bulk plants to areas outside of major metropolitan city
limits.
                                                                           5-11

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                    d.  The Type of Customer
       Some plants claimed to have 100% agricultural  accounts;  others
claimed 100% commercial accounts.   However, the large proportion  of
survey respondents indicated that plants have a varying  mixture of
account types.  Requiring vapor recovery on bulk plants  serving any
particular category of customers—agricultural, commercial,  service
stations, new tanks over 950 liters (250 gallons), agricultural tanks
over 2,080 liters (550 gallons), or existing tanks over  7,570 liters
(2,000 gallons)--would affect most bulk plants.
                    e.  Type of Storage
       Plants with underground storage tended to be more modern than
above ground facilities.  Connecting a coaxial type gasoline delivery
and vapor return fitting (to recover vapors during incoming  load
transfer) to a mating adaptor and drop tube (such as Emco-Wheaton
P/N 298) is generally significantly less costly on below ground tanks
when compared to typical above ground installations.   However,  if an
underground tank is old, has an inadequate port size, leaks, and  is
deeply buried under concrete in difficult terrain, costs may dictate
abondonment of the tank.  Thus, even though average costs for install-
ing vapor recovery are  lower for underground tanks than  above ground,
the range of costs and  the maximum costs that the majority of opera-
tors would be required  to expend is generally similar.  Also, it
would be discriminatory to enforce separate control regulations for
underground tanks and for above ground tanks.
                    f.  Assets or Property Values
       The larger operators tend to have greater assets  and property
values and better financial capabilities.  However, there is a wide
range of assets for small and large operators and they do overlap
significantly.  As stated earlier, the facilities—area and equip-
ment—required to operate a bulk plant do not vary much with
                                                                          5-12

-------
throughput;  storage is required for each grade of gasoline and a
loading rack is necessary,  so that only the number of trucks will
vary.
                    g.   Storage Capacity
       The larger operator tends to have a larger storage capacity,
but again the range of numbers is too wide to provide a useful
classification.

          5.5.5  Number of Delivery Trucks
       Larger operations generally have more trucks, up to eight
among surveyed plants, but this still does not appear to be a
judicious way of indicating a plant's economic status, due to overlap
and ease of changing the indicator, such as taking trucks out of
service, or using larger capacity trucks.

6.   MARKET ANALYSIS OF BULK PLANTS
       Bulk plants operate in market environments that vary in
competition due to the make up of their respective customer sets.
These markets range from being virtually monopolistic to being
highly competitive.  Consequently, a bulk plant operator must
react in a manner that is sensitive to his environment while con-
sidering the range of alternatives available to his customers.
       Both bulk plant operators and their customers are prepared
to modify  their actions to take advantage of changing market con-
ditions.   The operators will seek to raise prices and curtail ser-
vices in order to maintain or  increase profit margins.  On  the other
hand, their customers will seek to obtain special services  and
lower prices for gasoline.  The degree of existing competition will
be the major determinant in resolving  this conflict.
                                                                          6-1

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       A principal aspect of the bulk plant business  that appears
to be self-evident is that the field lacks consistency.   As  implied
previously, there are several owner/operator situations  within  the
industry.   Additionally, competition is increasing from  other methods
of marketing gasoline.  These methods include direct  dealers and
pipeline facilities.
       For any particular operator, there are relevant factors  that
affect his business and have a major influence on its conduct.  These
factors will certainly include the following:
              t  Relationship with his supplier
              t  Efficiency of his plant
              •  Size of his customers
              •  Distance traveled to his customers
              •  Extent of direct competition
              t  Governmental regulations
       These factors will affect both his gross profits  and  net pro-
fits.  For example, if the operator's customers are relatively  dis-
tant his delivery costs will be high.  If he has many small  customers,
costs per delivery will be higher than if he had a few large customers,
       Bulk plant suppliers may not sell gasoline to  all of  their
customers at the same price.  According to industry practice, ah
operator will be able to purchase product from his supplier  at  a
lower price if he incurs higher than normal expenses  in  servicing
his customers.  In a sense, the operator is being subsidized by
his supplier in order to sell gasoline to a particular group of
customers at a given price.
       During this study, the question has been raised of independent
operators receiving subsidies for other situations beyond their con-
trol , such as the installation of vapor recovery equipment.   The
almost universal response from both operators and suppliers  was that
a lump sum type of assistance could not be expected.
                                                                         6-2

-------
       The operators seem to be left with three possible alterna-
tives: 1) either absorb the added costs, 2)  seek lower supply prices,
or 3) raise delivery prices.  An increase in the price of gasoline
raises the further question of an accompanying decrease in demand
and the possible substitutions available to  consumers seeking to
purchase gasoline at lower prices.
       Economically, direct supply is viable only for individual
customers located relatively short distances from refineries.  If
long distances must be traveled for any deliveries, costs will  begin
to escalate rapidly for individual  small users.  Large users, those
with at least 30,000 liter (8,000 gallon) tanks, are likely to deal
with direct bulk sellers or hire trucks to provide deliveries from
the refinery to his facility, bypassing the  bulk plant.

7.   FINANCIAL ANALYSIS
     7.1  FINANCIAL DATA AND STATISTICS
       Determining the financial structure and capability of typical
bulk plants is a very difficult matter.  Many of these firms are in
businesses other than just the wholesale marketing of gasoline.  They
sometimes own gasoline stations and sell tires, batteries and acces-
sories (TBA) in addition to gasoline and other petroleum products.
It is also quite difficult to define what one means by typical  in
terms of location, customer set, sales volume, additional lines of
business, profitability and asset value.
       Many firms, both large and small are  reluctant to freely dis-
perse their annual financial data.   Nevertheless, sources for this
information are available through Dun and Bradstreet and Robert
Morris Associates (RMA).  The former provides banks, insurance
companies and other institutions with financial data, corporate his-
tories and ratings for numerous companies.  PES has obtained several
of these reports for firms in the bulk plant business.
                                                                          7-1

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       Robert Morris Associates is a service that publishes  summary
data for groups of companies within most Standard Industrial  Classi-
fication (SIC) codes.  For the bulk plant industry, SIC code  5171  was
selected which is defined as follows:
              "Establishments primarily engaged in wholesaling
               petroleum products, including liquified petroleum
               gas, from bulk liquid storage facilities."  *
       RMA has collected financial data for 153 firms within  this
classification.  As indicated above, the companies included  in  this
listing are often in other related businesses in addition  to  the
operation of bulk plants.  RMA has published data for companies
grouped according to their asset value.  The groups consists  of 18
companies with assets under $250,000, sixty-seven companies with
assets of between $250,000 and $1,000,000, and fifty-nine  firms with
assets of between $1,000,000 and $10,000,000.  In addition,  signifi-
cant ratios by statistical quartile have been computed for the  com-.
panies within each asset grouping.  These statistics are presented
in Tables 7.1 and 7.2.
       The ratios calculated in Table 7.2 are defined in Table  7.3.
These ratios are commonly used to assess the financial capability
and health of firms as compared to other organizations in  the same
industry.
       Three numbers are depicted for each ratio in Table  7.2.
These values represent the quartile points in each case.  For
example, if a group had 19 members, then the quartile points  would
define the values of the fifth, tenth and fifteenth members.   It
is clear from this discussion that management of any company  in a
given industry will attempt to keep their ratios away from the
lowest quartile of any group as this might tend to indicate  weak-
ness.  By having this type of data, management is able to  measure
its performance against others in the same industry.
 Robert Morris Associates - Statement Studies, 1975
                                                                           7-2

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      The following is a list of  agencies,  associations  and  firms
contacted:
         1.   Air Pollution Control Agencies
             D.   Andrew, Maryland State Bureau of Air  Quality  and
                 Noise Control, Baltimore,  Md.
             P.  Venturini,  California  Air  Resources  Board,
                   Sacramento,  Ca.
             Mr.  Sodher, New York State Department of  Environmental
               Conservation,  Albany, N.Y.
             J.  Eichler, Department of Environmental Protection,
                  Hartford,  Ct.
             L.  Gorry,  New  Jersey Bureau of Air Pollution Control,
                  Trenton,  N.J.
             J.  Haasis,  Missouri  Department of Natural Resources,
                  Jefferson City, Mo.
             R. Nishimura   Orange County Air Pollution Control District,
                  Santa Ana,  Ca.
             P.  Roberts, Texas  Air Control  Board,  Austin, Tx.
             Mr.  Talbert,  Bay Area Air Pollution Control District,
                  San Francisco,  Ca.
             	,  Department of Environmental  Resources,
                  Commonwealth  of Pennsylvania, Harrisburg,  Pa.
             	,  Indianapolis Department of Public  Works,
                  Indianapolis,  In.
                 	,  Bureau of  Air Quality Control,  Boston,  Ma.
         2.   Industry associations
             F.  Bertetta,  Jr.,  Pacific Oil Conference,  So.  San
                  Francisco,  Ca.
                                                                           B-l

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    R. Cavin,  Society  of  Independent Gasoline Marketers of
         America,  St.  Louis, Mo.
    C. Houton, National Oil Jobbers Council, Washington, D.C.
    F. Meeda,  Empire   State Petroleum Assn., Inc., New York, N.Y.
    K. Peeler, Texas Oil  Marketers Assn., Midland, Tx.
    D. Schroeder,  Maryland Petroleum Assn., Annapolis, Md.
    D. Southers, American Petroleum Institute, Washington, D.C.
    J. Zinkand, Pennsylvania Petroleum Assn., Inc., Harrisburg, Pa.

 3.  Major Oil  Company  Representatives
    W. Barnard, Jr., Standard Oil Company of California,
       Sacramento,  Ca.
    C. Bowers, AMOCO,  Inc., Kansas City, Kansas
    Z. Brown,  Texaco,  Inc., Los Angeles, Ca.
    I. Cameron, Phillips  Petroleum Company, San Mateo, Ca.
    S. Cloughlin and R. Dahlheira, ARCO, Inc., Chicago, 111,
    G. Diets,  Standard Oil Company of California, Long Beach, Ca.
    Q. Eisle,  Exxon Company, U.S.A., Los Angeles, Ca.
    E. Grundy, Gulf Oil,  Houston, Texas
    Mr. Hopper, ARCO, Inc., Los Angeles, Ca.
    W. Littlebridge, AMOCO, Inc., Denver, Co.
    D. McKeague, Union Oil Company of California, Los Angeles, Ca.
    W. Milne, Conoco, Inc., Denver, Co.
    J. St.  Germain, AMOCO, Inc., Baltimore, Md.
    B. Stoddard, Shell Oil, Houston, Texas
    Mr.  Warwick,  ARCO, Inc.,  Los Angeles, Ca.
    R. Wilson, Indiana Farm Bureau Cooperative Association,
       Incianapolis, Inc.
4.   Bulk Plant Operators
    B. Ballow, Beacon-Ballow,  Reedly,  Ca.
    Mr. Barrington, Union Oil,  Los Banos,  Ca.
    F. Bertetta,  Jr.,  Olympia  Oil Co.,  So.  San  Francisco,  Ca.
    J. Calleri, Calleri Oil,  San Leandro,  Ca.
    Mr. Gifford,  Gifford Oil,  Lindsay,  Ca.
    B. Graves,  Orange Belt & Supply,  Lindsay,  Ca.  and Woodlake,  Ca,
    Mr. Greene, Greene Bros.,  Brighton,  Co.

                                                                B-2

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I. Harness, Harness and Sons, Dinuba, Ca.
Mr. Hohensaelt, Red Triangle, Fresno, Ca.
G. Kehm, Kehm Oil, Pittsburgh, Pa.
K. Koht, Salinas Valley Oil Co., Santa Rosa, Ca.
E. Kroesche, Inland Oil, Escondido, Ca.
A. Laughton, Texaco, Merced, Ca.
D. Looraan, Shell Oil, Ventura, Ca.
D. Martin, Martin Oil, Fresno, Ca.
Mr. McCoy, Currie Bros Oil, Fresno, Ca.
D. Murray, Murray Petroleum Co., Bakersfield
R. Perkes, Purmax, Lindsay, Ca.
P. Petersen, ARCO., Inc., Wasco, Ca.
Mr. Porter, Porter Oil, Beaumont, Texas
C. Purcell, Shell Oil, Pasadena, Texas
E. Pettit, Navy Oil Co., Bakersfield, Ca.
Mr. Quinn, Mobil Oil, Tulare, Ca.
T. Reese, Marion County Farm Bureau, Indianapolis, Ind.
S. Rohrers, Anaheim, Ca.
D. Rose, Visalia, Ca.
F. Ross, J. Griggs, Exeter, Ca.
Mr. Salas, Salas Oil, Denver, Co.
L. Sawyer, Shell Oil, Van Nuys, Ca.
P. Schwartz, Schwartz Oil, Valencia, Ca.
Mr. Seals, Union Oil, Merced, Ca.
B. Shuster, Shuster Oil and Chemical, Escondido, Ca.
J. Silveira, Fresno, Ca.
E. Tait, E.D. Tait Petrol Distr., Pixley, Ca.
H. Weiss, Union Oil, Turlock, Ca.
Flint Tex Oil, Columbus, Texas
Pocahontas, Inc., Salisbury, Maryland
Siebert Oil, Fresno, Ca.
                                                                B-3

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      Many other operators were contacted, but because they either
did not wish to discuss their operations provided no pertinent infor-
mation or had no experience with vapor recovery, they are omitted from
this list.
      Other contacts included 1) request for Dun and Bradstreet
reports of several bulk plants; 2) the San Diego County Assessor's
Office; 3) the Internal Revenue Service; 4) the California Pollution
Board Authority; 5) the Small Business Administration; 6) the Federal
Energy Administration and 7) Economists with Tait and Associates.
                                                                           B-4

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            APPENDIX C

COMMENTS ON PROPOSED AMENDMENTS TO SAN
FRANCISCO, CALIFORNIA BAY AREA AIR
POLLUTION CONTROL DISTRICT REGULATIONS

-------
         BAY AREA AIR POLLUTION CONTROL DISTRICT
                    939 Ellis Street
             San Francisco, California 94109

                                       October 9, 1975

TO:       CHAIRMAN JELAVICH AND MEMBERS
          OF THE BOARD OF DIRECTORS

FROM:     AIR POLLUTION CONTROL OFFICER

SUBJECT:  REPORT ON SMALL BULK TERMINALS - BOARD REFERRAL
          SEPTEMBER 17, 1975

INTRODUCTION  .

At the September 17, 1975 Board meeting, the staff was
requested to provide a report outlining the exemptions in
existing regulations for small bulk terminals, and
estimates on the emissions from such terminals, along
with estimates on the cost of control of such emissions.

A bulk loading plant or facility essentially consists of
a number of storage tanks which store petroleum products
to be used for subsequent shipment to local customers.
Most of the gasoline dispensed in the Bay area is dis-
pensed from bulk terminals at major refinery facilities,
with ultimate destination of gasoline stored for service
stations in the Bay area.  These are referred to as major
bulk loeding facilities.  There are a number of smaller
facilities which store petroleum products for resale to
farmers, smaller commercial and industrial accounts, con-
tractors and a relatively few service stations.

Information available to the District in September of 1975
indicated that about 93% of the gasoline dispensed in the
Bay area came from the larger bulk terminals associated
with the major refineries, and about 2% was handled by
small bulk loading facilities.

EXISTING REGULATORY CONTROL ON GASOLINE VAPORS

Regulation 3 of the District adopted in 1967 required that
organic gas emissions from facilities which load more than
25,000 gallons per day of organic liquids be equipped
with vapor recovery systems to reduce such emissions by at
least 90
-------
Regulation 2 exempted service stations which are serviced
from bulk terminals of less than 25,000 gallons per day
throughput from installing vapor recovery equipment.
(Section 1302.22b)  In addition, the recent amendment by
the Board to the vapor recovery requirements at service
stations exempted trucks which receive gasoline from bulk
terminals of less than 25,000 gallons per day throughput
from vapor recovery requirements on the truck.  (Section
1302.21b)  The exemptions in Regulation 2 concerning vapor
recovery at service stations and for trucks served by the
smaller bulk terminals were designed to be consistent with
the earlier regulatory requirements in Regulation 3 for
such small bulk terminals.  That is, the need to control
vapors from facilities being served by the smaller loading
terminals appeared to be inconsistent with the lack of
regulatory controls at the small bulk loading facilities.
The basic reason was that there would be no reduction in
emissions if vapors collected at the service station were
emitted at the bulk terminal which was exempted, .from the
90% recovery requirement.  For service stations which were
served by major terminals which were required to have 90%
vapor recovery controls, the vapors returned to the
delivery truck during a "drop" would be collected at the
terminal.

CONTROL OF EMISSIONS AT SMALL BULK TERMINALS

The question has been raised as to the emissions and
cost of control at small bulk loading facilities.   In
order to assess the magnitude of the overall problem of
emissions from small bulk plants, it was necessary to
ascertain with greater precision the number of such plants
in the District.  Information was compiled in the past
month from four sources available in the District.   That
is, from a computer. printout from the registration system
data bank maintained by the Enforcement Division,  two sum-
maries prepared by the Enforcement Division, and a current
questionnaire survey made by the Engineering Division.   A
list of the small petroleum bull; loading facilities and the
volume of gasoline pumped per day at each in the nine
counties is attached.   The list indicates that there are
164 small bulk plants in the District,  with a total of
255,647 gallons per day throughput, representing 4.26% of
the total gasoline throughput for the Bay area.   There are
however a significant number of extremely small  bulk plants
included in the attached list.   With a  cut-off of  less than
500 gallons per day,  the total  number of bulk plants which
might be affected by regulatory changes would amount to 129.
In addition,  there are 36 listings for  which no  throughput
data is available, which could  reduce the number of facil-
ities affected even further.   Our present estimate  is that
approximately 150 facilities are involved.
                                                            C-2

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A small bulk plant differs in many basic features from a
major bulk plant,  and while there are many variations,
these differences  can be summarized as shown in the
following table.
Receive product


Storage tanks


Loading rack




Trucks used for
MAJOR BULK PLANT

Pipe line, barge or
tanker

Floating roof or
equivalent

Vapor recovtry
loading arm, top
and/or bottom
loading

5-10,000 gallons
equipped for vapor
recovery; gravity
drop
Customers
Mainly service
stations but some
large commercial
accounts
SMALL BULK PLANT

tank truck or rail
car

Open vents or pressure/
vacuum relief valves

Splash or partial
submerged fill;
open venting
500-5000 gallons;
may have 300-1000
gallon compartments
for several different
products (gasoline,
diesel, oil, etc.)

Pressure pumps and
long hoses on reels

Farmers, smaller
commercial and
industrial accounts.
Drive-in bulk accounts,
contractors, a few
service stations.
SOURCES OF EMISSIONS AT SMALL BULK TERMINALS

The control problems at small bulk plants consist  of at least
three separate emission points:

   1.  Emissions from storage tank filling

   2.  Emissions from delivery truck loading

   3.  Emissions from filling customers tanks.

In essence, these emission sources are no different than the
emission sources associated with major bulk loading terminals,
except for the quantity of gasoline handled.  Each of these
areas will be discussed separately.

EMISSIONS FROM STORAGE TANK FILLING

Generally speaking, a small bulk plant has above ground storage
tanks of about 20,000 to 100,000 gallons capacity for each
product.  These tanks are usually filled by pumping from large
tank trucks or rail cars.  The average throughput for small
                                                             C-3

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bulk plants is about 40,000 gallons of gasoline per month,
although it can be considerably higher in certain individual
instances (up to 750,000 gallons per month).

From a control point of view, emissions from storage tank
filling could be controlled in much the same fashion as
emissions from service station tanks.  That is, the require-
ment of vapor return lines to the delivery truck or rail car
would return the vapors to the delivery vehicle for pro-
cessing later.  Large tank trucks are presently equipped for
vapor recovery and the vapors are returned to the major bulk
plants, which has equipment for processing the vapor further.
Small delivery trucks are not so equipped.

The cost of vapor return equipment for the delivery of fuel
to the storage tanks of small bulk plants appears to be
technically feasible, and estimates are that the cost would
be in the same range as for service stations, that is, about
$3,000 to $10,000 per storage tank.  In general, construction
problems would be less difficult than at service stations
because most of the tanks are above ground.  The total
emissions from this source is on the order of 0.9 tons per
day from all of the small bulk loading facilities in the Bay
area.

LOADING RACK CONTROL
The processing of vapors at the small bulk terminal returned
by delivery trucks v:ould require the installation of secon-
dary recovery systons , such as are now required for the large
bulk loading racks.  This would require the use of vapor
recovery loading arjns, or other vapor recovery processing
units.  Such units, which are now available, are scaled for
the 25,000 gallons per day and greater facility.  The cost
of such systems is in the range of $150,000 and higher,
depending upon the throughput.  The smaller bulk loading
racks would require smaller capacity recovery systems, v;hich
appear to be technically feasible and costs would probably
be in the $10,000 to  $15., 000 range, depending upon through-
put.  The emission,  from this source is on the order of 1.3
tons per day in the Bay area.

DELIVERY TRUCK CONTROL

The control of vapors, which are emitted upon delivery of
fuel to the customers of small bulk loading racks, may be
the most difficult phase of small bulk terminal control.
A major problem with  the smaller truck used by these bulk
loading installations is that many of them are equipped with
pumps, whereas the large truck delivery is mainly by gravity
drop.  The small trucks generally have hose reels and very
long hoses to access remote and difficult fill operations.
A vapor return hose would be required together with a
special vapor recovery nozzle.  It is difficult to estimate
                                                            C-4

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the costs, as we arc not familiar with any such installations,
but based on available data, it could be in the range of  $5,000
to $15,000 per truck.  In addition to the installation of
specialized equipment on the delivery vehicle, it would be
necessary for the customer  (farmer, contractor, etc.) to
install the necessary hardware on his storage tank to accommo-
date the vapor return line of the delivery vehicle.  Since
most of these tanks are above ground, the cost of such equip-
ment should not exceed approximately $100 per tank.

The emissions from this source are estimated to be on the
order of 1.5 tons por day for the entire Bay area.

The following table summarizes the information discussed  rtbove.

SUMMARY OF EMISSIONS AND COST ESTIMATES FOR CONTROL AT SMALL
BULK LOADIMG FACILITIES AND DELIVERIES THEREFROM	

                       Estimated          Estimated Cost
Source                 Emissions          Per Facility
                          T/D

Filling storage tanks     0.9             $3,000 - $10,000

Filling delivery          1.3             $10,000 - $15,000
trucks (Loading Rack
recovery)

Filling customers         1.5             ($5,000 - $15,000
tanks                                     (for truck equipment
                                          ($100 for custor.ieir
                                          (tank equipment
              TOTAL       3.7

For 129 small bulk loading facilities in the Bay area, which
would be subject to such controls, the following total cost
estimates are presented:

Filling Storage Tanks             $387,000 to $1,290,000
Filling Delivery Trucks           $1,290,000 to $1,935,000
   (Loading Rack Recovery)
Filling Customers Tcinks
                       Trucks     Number of trucks not known
                                     at this time
                    Customers     Number of tanks not known
                                     at this time

For comparison purposes relative to the emissions from
gasoline marketing in the Bay area, the following data is
presented in summary form:
                                                             C-5'

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Source

Small bulk
terminals

Major bulk
terminals
           Gallons/Day
             Pumped
              255,000
            6,000,000
                     Total Emissions
                          T/D
                          3.7
                         75
A break down of the number of facilities and county distri-
bution is shown in the following table:
                       SUMMARY
                 SMALL BULK PLANT DATA

County
ALAMEDA
CONTRA
COSTA
MARIN
NAPA
SAN
FRANCISCO
SAN
MATEO
SANTA
CLARA
SOLANO
SONOMA

Plants
35

26
7
15

8

18

23
11
21
Less Than
500
Gal/Day
8

12
3
4

3

1

2
8
2
Total
Gal/Day
47,145

40,529
10,050
40,653

1,117

17,048

25,860
6,829
66,416
Organic
Emissions
Tons/Day
.6836

.5876
.146
.589

.016

.247

.375
.099
.963
   TOTAL
164
35
255,647
3.7
The Board has indicated that it wished to study the informa-
tion, which is currently available, relative to the emissions
and the feasibility of control at small bulk loading facilities
and trucks which serve these facilities.  The staff will be
pleased to respond to any questions the Board may have.
DJC:MF:tmc
                                                           C-6

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             BAY AREA AIR POLLUTION CONTROL DISTRICT
                        939 Ellis Street
                 San Francisco, California 94109
                                                   January 14, 1976
TO:       CHAIRMAN WILLIAM R. JELAVICH AND MEMBERS OP THE
          BOARD OP DIRECTORS

FROM:     AIR POLLUTION CONTROL OFFICER

SUBJECT:  PROPOSED AMENDMENTS TO REGULATIONS 2 AND 3 CONCERNING
          BULK LOADING TERMINALS AND THE REDUCTION OF EMISSIONS
          THEREFROM
     The Board of Directors hns directed the staff to propose amendments
to District regulations which would further limit the emissions of
organic compounds from Bulk Loading Terminals.  At the present time,
Regulation 5 requires 90% recovery of vapors emanating.from Bulk Loading
Terminals of greater than 25,000 gallon per day throughput  (Regulation
3, Section 3102.2).   Regulation 2, Section 1302.22 b, exempts storage
tanks from the vapor recovery requirements of Section 1302.2 if they
arc served by bulk loading terminals which process less than 25,000
gallons per day.
     Vapors cf gasoline are emitted to the atmosphere during the mar-
keting of gasoline at the following sources:

     (1) The filling of storage tanks at small (less than
         25,000 gallons per day throughput) bulk loading
         facilities.

     (2) The filling of transportable tanks from such storage
         facilities.

     (3) The filling of tanks at service stations and other
         end-users by these delivery trucks.

     Controls presently exist for recovery of vapors from the larger
(grcater than 25,000 gallons  per day throughput)  bulk loading ter-
minals, the transportable tankers which deliver product to service
stations, and the  service station tanks served by these transportable
tankers.

     In order to further limit the emissions  of organic vapors from
smaller bulk loading terminals, the transportable tankers which deliver
product to end-user,  and the  storage tanks of the end-user, a series of
existing regulations  could  be amended.

     The staff proposes a scries of such amendments to Regulations 2
and 3 to accomplish further reduction in emissions from activities
associated wjth gasoline marketing from smaller bulk loading terminals.
These amendments arc designed to accomplish the following:
                                                                C-7

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     (1)  For the filling of storage tanks of greater than 1,000
          barrels (42,000 gallons),  no change from the present
          requirement  of a floating  roof (Regulation 3, Sections
          3102.4 and 3102.5).

     (2)  For the filling of storage tanks of a size between
          2,000 gallons  and 42,000  gallons (1,000 barrels), a
          new requirement for a vapor balance system to control
          emissions  resulting from  the filling of such tanks.

     (3)  For the filling of tanks  smaller than 2,000 gallons,
          the requirement of submerged fill.

     (4)  For the filling of transportable containers (tankers)
          from bulk  loading plants  processing more than 25,000
          gallons per  day, no change from the present require-
          ment of 90%  control (Regulation 3,  Section 3102.2).

     (5)  For the filling of transportable containers (tankers)
          froiTi bulk  loading plants  processing between 2,500 and
          25,000 gallons per day,  the requirement of a vapor
          balance system for such  loading of  tankers.

     (6)  For the filling of transportable containers (tankers)
          from bulk  loading facilities processing less than
          2,500 gallons  per day,  the requirement of a submerged
          fill pipe.

     (7)  For the filling of storage tanks at end-users (i.e.
          service stations) serviced by bulk  loading terminals
          processing more than 25,000 gallons per day, no change
          from present regulatory  requirements of 90% control
          (Regulation  2, Section  1302.2).

     (8)  For the filling of storage tanks at end-users (i.e.
          service stations) serviced by bulk  plants of between
          2,500 and  25,000 gallons  per day throughput, the
          requirement  of 90% control.

     (9)  For the filling of storage tanks at end-users serviced
          from bulk  plants of less  than 2,500 gallons per day
          throughput,  or serviced  by bulk distributors who
          deliver less than 2,500  gallons per day, the require-
          ment of a  submerged fill  pipe.

     Adoption of the proposed amendments to Regulations 2 and 3 to
accomplish the above will result  in  the following:

     (1)  Reduction  of organic emissions by approximately
          ?. tons per day.
                                                                 C-8

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     (2)  Approximately  35  facilities  in the Bay Area may be
          affected.

     (3)  Estimated  cost of control to achieve the above
          reduction  would be approximately $500,000, involving
          the installation  of vapor balance systems.

     Attached are  the  recommended changes to Regulations 2 and 3 which
would accomplish  these reductions.

     The staff recommends that these amendments be adopted.
DJC:MF:j d
Attachments
                                                                C-9

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                      PROPOSED  AMENDMENTS  TO
                            REGULATION  3

                    (Organic Storage  Tanks)
       § 3102  Compliance with any of sections  3102.1  through 3102.6 shall, be
              deemed to be in compliance with Section 3101. Showing  of such
       compliance by the person responsible for an organic gas emission shall include
       applicable portions nnd/or calculation procedures contained in AIM Bulletin
       25 M, "Evaporation Loss from Tank Cars, Tank Trucks and Marine Vessels,"
       in API Bulletin 2517,  "Evaporation Loss from Floating Roof  Tanks," and
       in API Bulletin 2518, "Evaporation Loss from Fixed Roof Tanks."
       § 3102.1   Srg^mc- gas :icc Fcac-tw'«y->!jfe.nU;ii (Jiaa-5-W- sJulLrooi cxfccd. tiial j-:iJc.at n-LiiclLe einU-t&d-jf- the Unk-wwc-fiJItd tiicouyJiJU5uljJU.cj:gCiJ fijj pi.pc.


   3102.1   ORGAN 1C GAS  EMISSIONS  FROM  THE  FILLING OP  A
             SWiTONARY  STORAGE  TA.MK  OF  LJ:SS THAN  2 , OOP
GALLONS  CAPACITY ^ND  CONTAINING  0RGANIC  LIQUIDS  ivITM' A
VAPOR  PRESSURE  GREATER  THAN  1,5  PS IA  UNDER  ACTUAL  STORAGE
               SMALL  NOT  EXCEED THAT AMOUNT  OF' ORGANIC GAS
               raTnw                                  E  s A^ITTTQTJI D ,
WOULD E'MIT  IF  EQUIPPED KITH A  SUBMERGED  PILL  PIPE.

  -3102.11 OR CAN 1C  GAS  EMISSIONS  PROM  THE FILLING OF  A
ST AT I ON ARY "STORAGE  TANK  Ov  CAPACITY GREATER THAN OR  EQUAL
T0~2~, 0 00  GALLONS  DDT  LESS THAN OR  EQUAL _TO__12_> 0 00  GALLONS
         TATN ] NG ORGANIC LIQUIDS vaTTTTrYAPOR PI^TB s u JIE
                      ~?S1A  UND~R ACTTJAT~STORAGE  CON D ITT07TS ' SHALL
                      AMOU N T OP ORGAN' 1 C  GAS EMISSION  IvI 1 1 CH  THE
               CONTAIiNlNlTTH E S Ai- 1 JTT1 QUID  WOULD  ETTrr~lT
                      VAPOR  BALANCE  SYSTEM  IN  GOOD  CONUnTON.
        §3102.-!  Organic gas emissions from a stationary storage tank which has a
                 storage capacity  greater than  1,000 barrels, and  which contains
        organic liquid having a vapor pressure under actual storage conditions greater.
        than  1.5  ps-a but ct]ual to  or less than 11 psia and a head  space reactivity
        grrater than  5%, shall not exceed lli.it amount of organic gas emission which
        the same lank, containing the same organic liquid, "would emit if equipped
        willi a floating roof in good condition. Such org.-mic gns emissions shall he
        calculated according to API Bulletin 2517, "Evaporation Loss from Floating
        Kocf Tanks." or shall be calculated by applicable procedures acceptable to the
        Control Officer where API Bulletin 2517  procedures arc not valid.
        § M02.5  Organic gas emissions  from a  stationary storage tank which has
                storage capacity greater than  1,000 barrels and which contains
        organic liquid having a vapor pressure under actual storage conditions gtcatcr
        than 11.0 psin and .1 hc;i%, shall not exceed
        that amount of organic gas emission which the same tank, containing the same
        organic lU)md, wouKl emit  if it were storing an organic liquid of  11  psia
        vapor pressure  and were equipped with a floating roof in good condition.
        Such organic  gas cim'sbion shall be calculated according to AIM Hullclin 2517,
                                                                                C-10

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              PROPOSED  AMENDMENTS TO  REGULATION 3


                    (BULK LOADING FACILITIES)
         § 3102.2  Organic £as-cmissio»s-eakiJ:Ue4.,ifr » l\1000-j;:iIk>tis-]»<>r-r;«lp[Klar-tl;iy of-argaiMC-lutuuli;
         frftcickflporprcssHreurertOF t-lwrt-4 sruU-heud-spacc cejcm'uy.iye>tri. llu.
         inhr transport-able containers iifi^F-liisfl-WQ flnJloas.r:ijV)dLiJ alui'lJ be. tcJucrtl liv
         at1fa5f907o-of UifMncimr rtut^vunld-bc cmirtfcd- nrtlionl-rotttrols.- (-
         Ojtolmri; 1971 -J

         § 3102.3  -Organ ic-jyis -CHii'swoiK -from- a JacLlily- lr)nLiK;_ bcl^tcca. SOT),
                            Jiciul -sp;u:c. tcyaivuy..^ciiji-t Jim V;I ai
              containers Jafgcp Wisn- M-gaUoru e opacity, dull uoi ^irccJ jftit. otuonu(

        •w+ikh woirld- be-emiHcxf-iPlJie conwmers were fiUod^UrongJ^i-spljjwcjcd Jil
3102.2  ORGANIC GAS EMISSIONS  FROM THE FILLING OF
                             Aj..\Ti;Rs QJ- GKh'.'rn-TTTHTgr'.ioo GALLONS
CAPACITY WITH  ORGANIC 'LIQUIDS  1JAVING  VAPOR PRESSURES GREATER
THAN i 5 PBTA.  AT BULK  PLANTS  LOAJJING MORJ- THAN zs,ooo
GATLOTTSTER cAi^Nii^nriiAY~TNTo  SUCH TRANSPORTABLE CONTAINERS ,
SToarc^inrEiJucTnrirY AT  LEAST 90% OF THE AMOUNT THAT  ivoaLD
BE  EMITTED WITHOUT CONTROLS.

3102.21 ORGANIC GAS EMISSIONS  FROM THE FILLING OF
         TRANSPORTABLE CONTAINERS OF GREATER THAN 100 GALLONS
CAPACITY KITH  ORGANIC LIQUIDS  HAVING  VAPOR PRESSURES GREATER
THATfT. 5'TSJA;  AT BULK  PLANTS  LOADINTTAT 'LEAST 2,500 GALLONS
              DAY BUT- NOT  MOKE  THAN 25,000 GALLONS "  " "
      Fi'O SUCH TRANSPORTABLE CONTAINERS,  SHALL  NOT KXCEiiD THAT
      T~TvTirCl^ IVQULiTlJE HMITTED  IF  THE ORGANIC  GAS HAilSSIQNS
      CONTROLLED  BY~A VAPOR BALANCE SYSTEM.
3102.3  ORGANIC  GAS EMISSIONS  FROM THE- FILLING OF
                        CONTAINERS  OF GREATER THAN" 100  GALLONS
CAPACITY V.iTll ORGANIC LTQ7U1D5 HAVING VAPUITTT&SS'JRES  GREATER"
THAN  1.5 PSIA. AT  BULK  PLANTS LOADING LESS THAN 2,500  GALLONS
PER CALENDAR DAY  INTO SUCH TRANSPORTABLE  CONTAINERS,  SHALL  NOT
      ~~        ivmrcn  WOULD  BH  LMrrTEb n- THE COMT       ' —
WE lib'  FILLED THROUGH A SUBMERGED  FILL PIPE.
                                                                        C-ll

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                  PROPOSED AMENDMENTS TO
                     REGULATION 5

                     (DEFINITIONS)
2006.1  BULK PLANT MEANS ANY FACILITY WHICH RECEIVES
        ITQtJID ORGAN1CS, STORES THE LIQUID IN STATIONARY
STORAGE TANKS
       AMD LOADS
      CONTAINERS
                         FROM THOSE STORAGE TANKS  INTO
                         FOR FURTHER DISTRIBUTION.
TRANSPORTABLE
2043.1
VAPOR BALANCE SYSTEM MEMS A SYSTEM
OF TWO Oil MOKE TANKS ViHiTW- THE VAPtTH
                                            CONSISTING
                                             SPACES
INTER-CONNECTED
F1TOTT
 ONE TO
TTorrnn
                IN SUCH A
                OTHER THE
KAY THAT WHEN
VAPOR MOVES
  LIQUID IS TRANSFERRED
I-ROM THE TANK RECEIVING
           IVHICIP
    THE
THE
                        01- THE
                  FRO?.
                                                       THF
       IS REMOVED THUS  BALANCING (OU EQUALIZING) THE PRESSURE
IN THE VAPOR S'PACE OF THE INTERCONNECTED TANKS.
                                                            C-12

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                               PROPOSED AMENDMENTS  TO  REGULATION  2

                                 VAPOR  RECOVERY FROM STORAGE  TANKS
                     § 1302.22 The Air Pollution Control Officer shall not deny an authority
                     to operate for containers, reservoirs or tanks used exclusively for:
                     (a) The storage of gasoline having a capacity cqua4 to or less than 2000
                     gallons and with a throughput of 6000 gallons per month or less,
Delete
Add
       (b) The storage of gasoline serviced from bulk terminals of less than
       25,000 gallons per day throughput. Such tanks shall comply with the vapor
       recovery requirements of § 1302.2 within 90 days of a change in service
       which results in deliveries from bulk terminals of 25,000 gallons per day
       throughput or more.
        (b)   THE  STORAGE OF  GASOLINE WHEN  SUPPLIED  FROM
              BULK DISTRIBUTORS  OF  LESS  THAN 2,500  GALLONS  PER
        CALENDAR  DAY THROUGHPUT OR FROM BULK PLANTS OF LESS
        THAN  2,500 GALLONS  PER  CALENDAR DAY THROUGHPUT.  SUCH
        TANKS SHALL COMPLY  WITH THE VAPOR  RECOVERY REQUIREMENTS
        OF  $1302.2 WITHIN 90 DAYS  OF A  CHANGE  IN  SERVICE WHICH
        RESULTS IN DELIVERIES FROM BULK DISTRIBUTORS  OR BULK
        PLANTS OF 2,500 GALLONS PER CALENDAR DAY  THROUGHPUT  OR MORE.


                    (c) The storage of gasoline in structures which the Air Pollution Control
                    Officer has determined  that severe and unusual construction  problems
                    wottld prevent the inslaJl.ition of equipment lo meet the vapor recovery
                    requirements specified in Section  1302.2. Such unusual construction prob-
                    lems include but are not limited to tanks with offset fill lines, tnnks located in
                    the basements of office buildings or under roadways.
                    (d) The storage of gasoline and  whose operation will cease on  or before
                    July 1, 1975 upon presentation of adequate supporting documents to the
                    Air Pollution Control Officer. This exemption from the vapor recovery
                    requirements specified in 1302.2  shall not apply  if the operation ceases
                    prior  lo July  1, 1975 and recommences operation after July 1,  1975.
                    f/ldofiicd fmtc IS, 1974 ; June 37,197-f.J
 Add

         (e)   THE  STORAGE OF GASOLINE IN STORAGE TANKS USED
               EXCLUSIVELY FOR THE  FUELING OF IMPLEMENTS OF
         HUSBANDRY.
                                                                              C-13

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                         PROPOSED AMENDMENTS TO  REGULATION 2

                                   DEFINITIONS



Add

     2013.1  BULK DISTRIBUTOR MEANS ANY PERSON WHICH RECEIVES
             ORGANIC LIQUIDS FROM A BULK PLANT AND  DELIVERS
     THOSE ORGANIC LIQUIDS TO STATIONARY STORAGE TANKS.


     2013.2  BULK PLANT MEANS ANY FACILITY WHICH RECEIVES
             ORGANIC LIQUIDS, STORES  THE LIQUID  IN  STATIONARY
     STORAGE TANKS, AND LOADS FROM THOSE STORAGE TANKS  INTO
     TRANSPORTABLE CONTAINERS FOR FURTHER DISTRIBUTION.
     2013.3  QUANTITY PER CALENDAR DAY MEANS  THE QUANTITY PER
             CALENDAR YEAR DIVIDED~fcY 365.
                                                                C-14

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                              PROPOSED AMENDMENTS TO REGULATION 2

                                   GASOLINE DELIVERY VEHICLES
1302.21  n)        Ho person  shall  store gasoline in or  otherwise use or
            operate any  gasoline"  delivery vehicle u'scd for the delivery
            of gasoline  for the servicing of motor vehicles unless he
            shall first  have obtained written authorization for such
            operation  from  the Air Pollution Control Officer.  The Air
            Pollution  Control Officer sJiall not: deny authorization for
            such use or  operation if such vehicle is designed and
            maintained to be vapor-tight and if sucli vehicle is equipped
            with a system to recover at least 90S of the  gasoline vapors
            displaced  during the  transfer of gasoline  from the vehicle
            to storage tanks used to service motor vehicles.  Any person
            who delivers or authorizes the delivery of gasoline to storage
            tanks without the proper connection of the vapor recovery
            system to  the storage tank shall, be: deemed to be in .violation
            of this Section.
        b)   ----- jSaseline-deiiver^verhiTrfres- ser vrccd - soiciiy -i/roiir •toxrl-lr ~ "
                      & £ - ies s- tba«~ -2-5-,-(KX>- -gr%-i-3ro-rr» -pes - *3 ay
                    -Six em- the - if ecjm.r-Rwerrbs- trir -Or3-G-2r21 i a)- -
    b)       GASOLINE DELIVERY VEHICLES  SERVICED  SOLELY  FROM BULK PLANTS
        OF LESS THAN 2,500  GALLONS  PER_ CALENDAR DAY  THROUGHPUT AND
        GASOLINE DELIVERY VEHICLES  OWNED AND  OPERATED  BY BULK DISTRIBUTORS
        OF LESS THAN 2,500  GALLONS  PER CALENDAR DAY  THROUGHPUT ARE
        EXEMPTED FROM THE REQUIREMENTS OF  1302.21 (a).
                                                                     C-15

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           APPENDIX D

SUMMARY OF EMISSION INVENTORY AND
   COST ANALYSIS BY MISSOURI
 DEPARTMENT OF NATURAL RESOURCES

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                        PROPOSED REGULATION XXI

           SUMMARY OF EMISSION INVENTORY AND COST ANALYSIS
In trying to draft a workable Regulation XXI the Air Quality staff
realized that an accurate emission inventory needed to be assembled
for the St. Louis Area.  Through the cooperation and information
supplied by the petroleum industry, that inventory has been completed
along with a cost/benefit analysis.  The following is a summary of
those results.

Total hydrocarbon (HC) emissions for the St. Louis Metropolitan Area
have been approximated at 122,000 tons per year (TPY) of which 81,500
tons is from mobile sources and 40,500 is from point and area sources.
With the existing level of control the gasoline marketing industry
contributes 9769 TPY or 8% of the total.  Requiring only submerged
filling at all facilities would reduce emissions to 8713 TPY or a
0.86% reduction.  Although the cost/benefit is $125 per ton of HC
controlled, the emission reduction is not very substantial.  Various
alternatives that were analyzed were:

    A - Exempt all bulk plants  -^300,000 gallons per month  (gpm)
    B - Exempt all bulk plants  -300,000 gpm from Section D only
    C - Exempt all bulk plants  ^300,000 gpm from Section C only
    D - No exemptions


It was determined that strategy C had the best (lowest) cost/benefit
ratio while still giving a substantial HC reduction.  Emissions would
be reduced by 3.64% with a cost/benefit ratio of $1362/ton of HC
controlled.  Maximum control (Strategy D) would give a 3.72% reduction
(0.08% reduction over C) at a cost/benefit of $1584/ton.

To obtain an idea of what this figure means, a cost/benefit was
performed on installing an electrostatic precipitator to
control particulates from a power plant.  The example was the
Chamois Power Plant where ESP costs were $2,000,000 to collect an
additional 7205 TPY of particulates.  This corresponds to $277/ton
of pollutant controlled.  Thus we see that this regulation costs about
six times as much per ton of pollutant reduced.

Based on the accumulated data,  a fourth draft of the regulation
has been prepared.  The changes are:

    1.  Section A.3. - The words "all" and "prevent" were replaced
        by "the" and "limit" to avoid any implication of 100% efficiency.

    2.  Section B.I. - The psia limit was raised to 1.8 to exempt Benzene,

    3.  Section C.2.a. -..Raising the emission limitation from 0.4 to
        0.5 gram per gallon was made to account for the ranges of
        inlet concentrations to the vapor recovery unit.  This would
        represent an 88-92% efficiency on the unit.
                                                                    D-l

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4.  Section C.3. - This was an addition to provide for the
    exemption of the small loading facilities that are expensive
    to control and produce small emission reductions.  This is
    what is referred to as Strategy C.  However, all new facilities
    must comply with the regulation.

5.  Section D.l.c.(2) - This addition helped to further clarify
    the regulation's applicability.

6.  Section D.2.d. - This addition was necessary due to the
    exemption given to the small loading facilities.

7.  Section E.I. - Compliance dates were extended due to slow
    delivery times for equipment.
                                                                 D-2

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                         EMISSION INVENTORY


                           Bulk Terminals

Number:  9

Tanks:  42
    Floating or lifter roof - 38
    Fixed roof              -  4

Throughput:  702,608,376 gallons per year (gpy)
    Trucks - 671,226,372 gpy
    Barges -  31,382,004 gpy

Emissions:  Tons/year (tpy)

    Uncontrolled  Existing Control. Submerged Fill Only  Full Vapor Recovery
                                                        .4 gm/gal  .5 gm/gal
       10,105          2,307            2,048              754        828


Note:  Not readily seen in the above figures is an emission elimination
at the bulk terminal when loading each vapor laden tank truck.  The
tank truck full of vapors prevents the emission of vapors that would
ordinarily occur when gasoline is loaded into an empty truck, therefore,
there is almost a double savings.
                            Bulk Plants

Number:   42

Throughput:  51,800,796
    All  bulk plants reporting had average monthly throughputs of
    less than or equal to 300,000 gallons.

Emissions:  (tpy)

    Uncontrolled  Existing Control    A      B      C      D
        791            679           575    491    376    281

    A -  Exempt plants ^300,000 gallons per month (gpm) from
        Sections C & D if trucks are filled with submerged fill pipe.

    B -  Exempt plants  ^300,000 gpm from Section D.

    C -  Exempt plants  ^300,000 gpm from Section C if trucks are
        filled with a submerged fill pipe.

    D -  No exemptions.
                                                                    D-3

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                             Service Stations

    *Number:  Approximately 1500

    *Throughput:  Approximately 600,000,000 gallons/year

    Emissions:  (tpy)

        Uncontrolled  Existing Control  Submerged Fill Only  Vapor Balance
            7050            6783               6090              4119

    *We did not have a very complete response as to number of stations
    and gasoline throughput.  These numbers were picked based upon vehicle
    miles traveled, population, and information supplied by the oil industry.
                              Total Emissions

                                Submerged
        Uncontrolled  Existing  Fill Only   ABC    Full Vapor Recovery

Terminals  10,105       2307      2048     828  828  828
Plants        791        679       575     575  491  376
Stations    7.050       6783      6090    4119 4119 4119
           17,946       9769      8713    5522 5438 5323

    Total hydrocarbon emissions for the St. Louis Metropolitan Area are
    approximately 122,000 tons/year of which 81,500 tons is from mobile
    sources and 40,500 tons is from point and area sources.
                    Emission Reduction (120.000 tpy total)

                          % of total      From  (TFY)     To  (TPY)    % Reduction

    Existing Contribution    8.0           9769           9769           0
    Submerged Fill Only      7.14          9769           8713          .86
    A                        4.52          9769           5522         3.48
    E                        4.45          9769           5438         3.55
    C                        4.36          9769           5323         3.64
    D                        4.28          9769           5228         3.72
    Changing from 0.4
       to 0.5 gm/gallon                     754            828         0.06
                                                                         D-4

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                            COST ANALYSIS


Terminals:

    9 vapor recovery units @$250,000                  $2,300,000
    4 floating roof retrofits @$30,000                   120.000
                                           TOTAL      $2,420,000


Bulk Plants (42)

    To comply with Section D - $2000/plant            $   84,000
    To comply with Section C -
              $15,000/plant (vapor balance)              630,000
                4,000/truck (100 trucks)                 400.000
                                           TOTAL      $1,114,000


Service Stations (1500)

    1500 stations d>$2500/station                      $3,750,000


Trucks (200)

    Cost to convert trucks                            $1,000,000


               COST/BENEFIT OF VARIOUS. ALTERNATIVES

1.  Require only submerged fill

    Cost ($)       Benefit (tons HC)       Cost/Benefit
    131,800             1056                 $125/ton
                                                or
                                             $.47/gal
2.  Exemption A

    Cost ($)       Benefit (tons HC)       Cost/Benefit
    2,420,000           4247                 $1688/ton
    3,750,000                                    or
    1.000.000                                $6.33/gal
    7,170,000

3.  Exemption B

    Cost ($)       Benefit (tons HC)       Cost/Benefit
    2,420,000           543;8               $1507/ton
      630,000                                  or
      400,000                              $5.65/gal.
    3,750,000
    1.000.000
    8,200,000

                                                                     D-5

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Exemption C

Cost ($)
2,420,000
   84,000
3,750,000
1.000.000
7,254,000

Exemption D

Cost ($)
2,420,000
   84,000
  630,000
  400,000
3,750,000
1.000.000
8,284,000
Benefit (tons HC)
     5323
Cost/Benefit
  $1362/ton
                              or
                          $5.10/gal
Benefit (tons HC)
     5228
Cost/Benefit
  $1584/ton
      or
  $5.94/gal
                                                                D-6

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i TECHNICAL REPORT DATA
{P'.esfe read Instructions on the reverse before completing)
T. R=?ORT NO. 2.
EPA 340/1-77-013
.-!. TITLE AND SUBTITLE
Economic Analysis of Vapor Recovery
Systems on Small Bulk Plants
j'. AUTHORtS)
a. PERFORMING ORGANIZATION NAME AND ADDRESS
Pacific Environmental Services, Inc.
1930 14th Street
Santa Monica, CA 90404
i
! 12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Division of Stationary Source Enforcement
Washington, D.C. 20460
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
September 1976
S. PERFORMING ORGANIZATION CODE
3. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-3156, Task 24
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
IE. SU?PLSM = NTARY NOTES
Project Officer: Mr. John Busik
(202) 755-2560
;••;. A35T.SACT
This study was conducted to provide economic data and analysis to aid
the Environmental Protection Agency in assessing the feasibility and
reasonable applicability of vapor recovery systems (particularly
bottom-loading} on bulk plants. Other factors which should be used
in assessing feasibility and reasonable applicability may be mentioned
1 in this -report but are not fully analyzed.
                           KEY WORDS AND DOCUMENT ANALYSIS
              DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C. COS AT I field/Croup
Air Pollution
Gasoline Bulk  Terminals
Vapor  Balancing
Vapor  Recovery
Air Pollution Control
Stationary  Sources
Organic Vapors
Organic Vapors
':.- D:Srr.l3UTIO.N STATEMENT
 Release:   Unlimited
 Available free  from DSSE/EPA as
 .supplies oerrr.it
                                        19. SECURITY CLASS (This Report)
                                        Unclassified
                        21. NO. OP PAGES
                                        2C. SECURITY CLASS I This page I
                                        Unclassified
                        22. PP.iCS.
  Form 2220-) JSev. 4-77)  PREVIOUS EDITION is OBSOLETE

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      The following is a list of agencies,  associations  and firms
contacted:
         1.   Air Pollution Control Agencies
             D.   Andrew,  Maryland State Bureau of Air Quality and
                 Noise Control,  Baltimore,  Md.
             P.  Venturini,  California Air Resources  Board,
                   Sacramento,  Ca.
             Mr.  Sodher,  New York State Department of Environmental
               Conservation,  Albany,  N.Y.
             J.  Eichler,  Department of Environmental Protection,
                  Hartford,  Ct.
             L.  Gorry,  New  Jersey Bureau of Air Pollution Control,
                  Trenton,  N.J.
             J.  Haasis,  Missouri Department of  Natural Resources,
                  Jefferson City, Mo.
             R. Nishimura   Orange County Air Pollution Control District,
                  Santa Ana,  Ca.
             P.  Roberts,  Texas  Air Control  Board,  Austin, Tx.
             Mr.  Talbert,  Bay Area Air Pollution Control District,
                  San Francisco, Ca.
             	,  Department  of Environmental Resources,
                  Commonwealth  of Pennsylvania, Harrisburg,  Pa.
             	,  Indianapolis Department of Public Works,
                  Indianapolis,  In.
                 	,  Bureau of  Air Quality  Control,  Boston, Ma.
         2.   Industry associations
             F.  Bertetta,  Jr.,  Pacific Oil Conference,  So.  San
                  Francisco,  Ca.
                                                                           B-l

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    R. Cavin, Society of Independent Gasoline Marketers of
         America, St. Louis, Mo.
    C. Houton, National Oil Jobbers Council, Washington, D.C.
    F. Meeda, Empire  State Petroleum Assn., Inc., New York, N.Y.
    K. Peeler, Texas Oil Marketers Assn., Midland, Tx.
    D. Schroeder, Maryland Petroleum Assn., Annapolis, Md.
    D. Southers, American Petroleum Institute, Washington, D.C.
    J. Zinkand, Pennsylvania Petroleum Assn., Inc., Harrisburg, Pa.

3.  Major Oil Company Representatives
    W. Barnard, Jr., Standard Oil Company of California,
       Sacramento,  Ca.
    C. Bowers, AMOCO, Inc., Kansas City, Kansas
    Z. Brown, Texaco, Inc., Los Angeles, Ca.
    I. Cameron, Phillips Petroleum Company, San Mateo, Ca.
    S. Cloughlin and R. Dahlheim, ARCO, Inc., Chicago, 111,
    G. Diets, Standard Oil Company of California, Long Beach, Ca.
    Q. Eisle, Exxon Company, U.S.A., Los Angeles, Ca.
    E. Grundy, Gulf Oil, Houston, Texas
    Mr. Hopper, ARCO,. Inc., Los Angeles, Ca.
    W. Littlebridge, AMOCO, Inc., Denver, Co.
    D. McKeague, Union Oil Company of California, Los Angeles, Ca.
    W. Milne, Conoco, Inc., Denver, Co.
    J. St. Germain, AMOCO, Inc., Baltimore, Md.
    B. Stoddard, Shell Oil, Houston, Texas
    Mr.  Warwick, ARCO, Inc., Los Angeles, Ca.
    R. Wilson, Indiana Farm Bureau Cooperative Association,
       Incianapolis, Inc.
4.  Bulk Plant Operators
    B. Ballow, Beacon-Ballow, Reedly,  Ca.
    Mr. Barrington, Union Oil,  Los Banos, Ca.
    F. Bertetta, Jr., Olympia Oil Co.,  So. San  Francisco,  Ca.
    J. Calleri,  Calleri Oil,  San Leandro, Ca.
    Mr. Gifford, Gifford Oil, Lindsay,  Ca.
    B. Graves, Orange Belt & Supply,  Lindsay, Ca. and Woodlake,  Ca,
    Mr. Greene,  Greene Bros., Brighton,  Co.

                                                                B-2

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I. Harness, Harness and Sons, Dinuba, Ca.
Mr. Hohensaelt, Red Triangle, Fresno, Ca.
G. Kehm, Kehm Oil, Pittsburgh, Pa.
K. Koht, Salinas Valley Oil Co., Santa Rosa, Ca.
E. Kroesche, Inland Oil, Escondido, Ca.
A. Laughton, Texaco, Merced, Ca.
D. Looman, Shell Oil, Ventura, Ca.
D. Martin, Martin Oil, Fresno, Ca.
Mr. McCoy, Currie Bros Oil, Fresno, Ca.
D. Murray, Murray Petroleum Co., Bakersfield
R. Perkes, Purmax, Lindsay, Ca.
P. Petersen, ARCO., Inc., Wasco, Ca.
Mr. Porter, Porter Oil, Beaumont, Texas
C. Purcell, Shell Oil, Pasadena, Texas
E. Pettit, Navy Oil Co., Bakersfield, Ca.
Mr. Quinn, Mobil Oil, Tulare, Ca.
T. Reese, Marion County Farm Bureau, Indianapolis, Ind.
S. Rohrers, Anaheim, Ca.
D. Rose, Visalia, Ca.
F. Ross, J. Griggs, Exeter, Ca.
Mr. Salas, Salas Oil, Denver, Co.
L. Sawyer, Shell Oil, Van Nuys, Ca.
P. Schwartz, Schwartz Oil, Valencia, Ca.
Mr. Seals, Union Oil, Merced, Ca.
B. Shuster, Shuster Oil and Chemical, Escondido, Ca.
J. Silveira, Fresno, Ca.
E. Tait, E.D. Tait Petrol Distr., Pixley, Ca.
H. Weiss, Union Oil, Turlock, Ca.
Flint Tex Oil, Columbus, Texas
Pocahontas, Inc., Salisbury, Maryland
Siebert Oil, Fresno, Ca.
                                                               B-3

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      Many other operators were contacted, but because they either
did not wish to discuss their operations provided no pertinent infor-
mation or had no experience with vapor recovery, they are omitted from
this list.
      Other contacts included 1) request for Dun and Bradstreet
reports of several bulk plants; 2) the San Diego County Assessor's
Office; 3) the Internal Revenue Service; 4) the California Pollution
Board Authority; 5) the Small Business Administration; 6) the Federal
Energy Administration and 7) Economists with Tait and Associates.
                                                                           B-4

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            APPENDIX C

COMMENTS ON PROPOSED AMENDMENTS TO SAN
FRANCISCO, CALIFORNIA BAY AREA AIR
POLLUTION CONTROL DISTRICT REGULATIONS

-------
         BAY AREA AIR POLLUTION CONTROL DISTRICT
                    939 Ellis Street
             San Francisco, California 94109
                                       October 9, 1975
TO:       CHAIRMAN JEtAVICH AND MEMBERS
          OF THE BOARD OF DIRECTORS

FROM:     AIR POLLUTION CONTROL OFFICER

SUBJECT:  REPORT ON SMALL BULK TERMINALS
          SEPTEMBER 17, 1975
- BOARD REFERRAL
INTRODUCTION

At the September 17, 1975 Board meeting, the staff was
requested to provide a report outlining the exemptions in
existing regulations for small bulk terminals, and
estimates on the emissions from such terminals, along
with estimates on the cost of control of such emissions.

A bulk loading plant or facility essentially consists of
a number of storage tanks which store petroleum products
to be used for subsequent shipment to local customers.
Most of the gasoline dispensed in the Bay area is dis-
pensed from bulk terminals at major refinery facilities,
with ultimate destination of gasoline stored for service
stations in the Bay area.  These are referred to as major
bulk loading facilities.  There are a number of smaller
facilities which store petroleum products for resale to
farmers, smaller commercial and industrial accounts, con-
tractors and a relatively few service stations.

Information available to the District in September of 1975
indicated that about 93% of the gasoline dispensed in the
Bay area came from the larger bulk terminals associated
with the major refineries, and about 2% was handled by
small bulk loading facilities.

EXISTING REGULATORY CONTROL ON GASOLINE VAPORS

Regulation 3 of the District adopted in 1967 required that
organic gas emissions from facilities which load more than
25,000 gallons per day of organic liquids be equipped
with vapor recovery systems to reduce such emissions by at
least 90S.  (Section 3102.2)  In addition, Regulation 3
required that organic gas emissions from facilities loading
between 500 and 25,000 gallons per day of organic liquids
be controlled by the installation of submerged fill pipes.
(Section 3102.3)
                                                             C-l

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Regulation 2 exempted service stations which are serviced
from bulk terminals of less than 25,000 gallons per day
throughput from installing vapor recovery equipment.
(Section 1302.22b)  In addition, the recent amendment by
the Board to the vapor recovery requirements at service
stations exempted trucks which receive gasoline from bulk
terminals of less than 25,000 gallons per day throughput
from vapor recovery requirements on the truck.  (Section
1302.21b)  The. exemptions in Regulation 2 concerning vapor
recovery at service stations and for trucks served by the
smaller bulk terminals were designed to be consistent with
the earlier regulatory requirements in Regulation 3 for
such small bulk terminals.  That is, the need to control
vapors from facilities being served by the smaller loading
terminals appeared to be inconsistent with the lack of
regulatory controls at the small bulk loading facilities.
The basic reason was that there would be no reduction in
emissions if vapors collected at the service station were
emitted at the bulk terminal which was exempted, .from the
90% recovery requirement.  For service stations which were
served by major terminals which were required to have 90%
vapor recovery controls, the vapors returned to the
delivery truck during a "drop" v/ould be collected at the
terminal.

CONTROL OF EMISSIONS AT SMALL BULK TERMINALS

The question has been raised as to the emissions and
cost of control at small bulk loading facilities.   In
order to assess the magnitude of the overall problem of
emissions from small bulk plants, it was necessary to
ascertain with greater precision the number of such plants
in the District.  Information was compiled in the past
month from four sources available in the- District.  That
is, from a computer. printout from the registration system
data bank maintained by the Enforcement Division,  two sum-
maries prepared by the Enforcement Division, and a current
questionnaire survey made by the Engineering Division.  A
list of the small petroleum bulk loading facilities and the
volume of gasoline pumped per day at each in the nine
counties is attached.  The list indicates that there are
164 small bulk plants in the District, with a total of
255,647 gallons per day throughput, representing 4.26% of
the total gasoline throughput.for the Bay area.  There are
however a significant number of extremely small bulk plants
included in the attached list.   With a cut-off of less than
500 gallons per day, the total number of bulk plants which
might be affected by regulatory changes would amount to 129.
In addition, there are 36 listings for which no throughput
data is available, which could reduce the number of facil-
ities affected even further.  Our present estimate is that
approximately 150 facilities are involved.
                                                            C-2

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A small bulk plant differs in many basic features from a
major bulk plant,  and while there are many variations,
these differences  can be summarized as shown in the
following table.
Receive product


Storage tanks


Loading rack




Trucks used for
MAJOR BULK PLANT

Pipe line, barge or
tanker

Floating roof or
equivalent

Vapor recovery
loading arm, top
and/or bottom
loading

5-10,000 gallons
equipped for vapor
recovery; gravity
drop
Customers
Mainly service
stations but some
large commercial
accounts
SMALL BULK PLANT

tank truck or rail
car

Open vents or pressure/
vacuum relief valves

Splash or partial
submerged fill;
open venting
500-5000 gallons;
may have 300-1000
gallon compartments
for several different-
products  (gasoline,
•diesel, oil, etc.)

Pressure pumps and
long hoses on reels

Farmers, smaller
commercial and
industrial accounts.
Drive-in bulk accounts,
contractors, a few
service stations.
SOURCES OF EMISSIONS AT SMALL BULK TEP^MINALS

The control problems at small bulk plants consist  of at least
three separate emission points:

   1.  Emissions from storage tank filling

   2.  Emissions from delivery truck loading

   3.  Emissions from filling customers tanks.

In essence, these emission sources are no different than the
emission sources associated with major bulk loading terminals,
except for the quantity of gasoline handled.  Each of these
areas will be discussed separately.

EMISSIONS FROM STORAGE TANK FILLING

Generally speaking,  a small bulk plant has above ground storage
tanks of about 20,000 to 100,000 gallons capacity for each
product.  These tanks are usually filled by pumping from large
tank trucks or rail  cars.  The average throughput for small
                                                             C-3

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bulk plants is about 40,000 gallons of gasoline per month,
although it can be considerably higher in certain individual
instances  (up to 750,000 gallons per month).

From a control point of view, emissions from storage tank
filling could be controlled in much the same fashion as
emissions  from service station tanks.  That is, the require-
ment of vapor return lines to the delivery truck or rail car
would return the vapors to the delivery vehicle for pro-
cessing later.  Large tank trucks are presently equipped for
vapor recovery and the vapors are returned to the major bulk
plants, which has equipment for processing the vapor further.
Small delivery trucks are not so equipped.

The cost of vapor return equipment for the delivery of fuel
to the storage tanks of small bulk plants appears to be
technically feasible, and estimates are that the cost would
be in the  same range as for service stations, that is, about
$3,000 to  $10,000 per storage tank.  In general, construction
problems would be less difficult than at service stations
because most of the tanks are above ground.  The total
emissions  from this source is on the order of 0.9 tons per
day from all of the small bulk loading facilities in the Bay
area.

LOADING RACK CONTROL

The processing of vapors at the small bulk terminal returned
by delivery trucks would require the installation of secon-
dary recovery systens, such as are now required for the large
bulk loading racks.  This would require the use of vapor
recovery loading arms, or other vapor recovery processing
units.  Such units, which are now available, are scaled for
the 25,000 gallons per day and greater facility.  The cost
of such systems is in the range of $150,000 and higher,
depending  upon the throughput.  The smaller bulk loading
racks would require smaller capacity recovery systems, which
appear to be technically feasible and costs would probably
be in the  $10,000 to $15.,000 range, depending upon through-
put.  The  emission,  from this source is on the order of 1.3
tons per day in the Bay area.

DELIVERY TRUCK CONTROL

The control of vapors, which are emitted upon delivery of
fuel to the customers of small bulk loading racks, may be
the most difficult phase of small bulk terminal control.
A major problem with the smaller truck used by these bulk
loading installations is that many of them are equipped with
pumps, whereas the large truck delivery is mainly by gravity
drop.  The small trucks generally have hose reels and very
long hoses to access remote and difficult fill operations.
A vapor return hose would be required together with a
special vapor recovery nozzle.  It is difficult to estimate
                                                            C-4

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the costs, as we are not familiar with any such installations,
but based on available data, it could be in the range of  $5,000
to $15,000 per truck.  In addition to the installation of
specialized equipment on the delivery vehicle, it would be
necessary for the customer  (farmer, contractor, etc.) to
install the necessary hardware on his storage tank to accommo-
date the vapor return line of the delivery vehicle.  Since
most of these tanks are above ground, the cost of such equip-
ment should not exceed approximately $100 per tank.

The emissions from this source are estimated to be on the
order of 1.5 tons per day for the entire Bay area.

The following table summarizes the information discussed tibove.

SUMMARY OF EMISSIONS AND COST ESTIMATES FOR CONTROL AT SMALL
BULK LOADING FACILITIES AND DELIVERIES THEREFROM	

                       Estimated          Estimated Cost
Source                 Emissions          Per Facility
                          T/D

Filling storage tanks     0.9             $3,000 - $10,000

Filling delivery          1.3             $10,000 - $15,000
trucks (Loading Rack
recovery)

Filling customers         1.5             ($5,000 - $15,000
tanks                                     (for truck equipment
                                          ($100 for customer
                                          (tank equipment
              TOTAL       3.7

For 129 small bulk loading facilities in the Bay area, which
would be subject to such controls, the follov;ing total cost
estimates are presented:

Filling Storage Tanks             $387,000 to $1,290,000
Filling Delivery Trucks           $1,290,000 to $1,935,000
  (Loading Rack Recovery)
Filling Customers Tar.3cs
                       Trucks     Number of trucks not known
                                     at this time
                    Customers     Number of tanks not known
                                     at this time

For comparison purposes relative to the emissions from
gasoline marketing in the  Bay area, the following data is
presented in summary form:
                                                             C-5

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Source

Small bulk
terminals

Major bulk
terminals
Gallons/Day
  Pumped
   255,000
 6,000,000
           Total Emissions
                T/D
                3.7
               75
A break down of the number of facilities and county distri-
bution is shown in the following table:

                       SUMMARY
                 SMALL BULK PLANT DATA

County
ALAMEDA
CONTRA
COSTA
MARIN
NAPA
SAN
FRANCISCO
SAN
MATED
SANTA
CLARA
SOLANO
SONOMA

Plants
35

26
7
15

8

18

23
11
21
Less Than
500
Gal/Day
8

12
3
4

3

1

2
8
2
Total
Gal/Day
47,145

40,529
10,050
40,653

1,117

17,048

25,860
6,829
66,416
Organic
Emissions
Tons/Day
.6836

.5876
.146
.589

.016

.247

.375
.099
.963
   TOTAL   164
 35
255,647
3.7
The Board has indicated that it wished to study the informa-
tion, which is currently available, relative to the emissions
and the feasibility of control at small bulk loading facilities
and trucks which serve these facilities.  The staff will be
pleased to respond to any questions the Board may have.
DJC:MF:tmc
                                                           C-6

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             BAY AREA AIR POLLUTION CONTROL DISTRICT
                        939 Ellis Street
                 San Francisco, California 94109
                                                   January 14, 1976
TO:       CHAIRMAN WILLIAM R.  JELAVICH AND MEMBERS OP THE
          BOARD OP DIRECTORS

FROM:     AIR POLLUTION CONTROL OFFICER

SUBJECT:  PROPOSED AMENDMENTS  TO REGULATIONS 2 AND 3 CONCERNING
          BULK LOADING TERMINALS AND THE REDUCTION OF EMISSIONS
          THEREFROM
     The Board of Directors  has directed the staff to propose amendments
to District regulations  which would further limit the emissions of
organic compounds from Bulk  Loading Terminals.   At the present time,
Regulation 5 requires 905  recovery of vapors emanating.from Bulk Loading
Terminals of greater than  25,000 gallon per day throughput (Regulation
3, Section 3102.2).   Regulation 2, Section 1302.22. b, exempts storage-
tanks from the vapor recovery requirements of Section 1302.2 if they
arc served by bulk loading terminals which process less -than 25,000
gallons per day.

     Vapors of gasoline  are  emitted to the atmosphere during the mar-
keting of gasoline at the  following sources:

     (1) The filling of  storage tanks at small (less than
         25,000 gallons  per  day throughput) bulk loading
         facilities.

     (2) The filling of  transportable tanks from such storage
         facilities.

     (3) The filling of  tanks at service stations and other
         end-users by these  delivery trucks.

     Controls presently  exist for recovery of vapors from the larger
(greater than 25,000 gallons per day throughput) bulk loading ter-
minals, the transportable  tankers which deliver product
stations, and the service  station tanks served by these
tankers.
to service
transportable
     In order to further limit the emissions of organic vapors from
smaller bulk loading terminals,  the transportable tankers which deliver
product to end-user, and the  storage tanks of the end-user, a series of
existing regulations could  be  amended.

     The staff proposes  a series of such amendments to Regulations 2
and 3 to accomplish  further reduction in emissions from activities
associated with gasoline marketing from smaller bulk loading terminals.
These amendments are designed  to accomplish the following:

                                                                C-7

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     (1)  For the filling of storage tanks of greater than 1,000
          barrels (42,000 gallons), no change from the present
          requirement of a floating roof (Regulation 3., Sections
          3102.4 and 3102.5).

     (2)  For the filling of storage tanks of a size between
          2,000 gallons and 42,000 gallons (1,000 barrels), a
          new requirement for a vapor balance system to control
          emissions resulting from the filling of such tanks.

     (3)  For the filling of tanks smaller than 2,000 gallons,
          the requirement of submerged fill.

     (4)  For the filling of transportable containers (tankers)
          from bulk loading plants processing more than 25,000
          gallons per day, no change from the present require-
          ment of 901 control (Regulation 3,  Section 3102.2).

     (5)  For the filling of transportable containers (tankers)
          from bulk loading plants processing between 2,500 and
          25,000 gallons per day, the requirement of a vapor
          balance system for such loading of tankers.

     (6)  For the filling of transportable containers (tankers)
          from bulk loading facilities processing less than
          2,500 gallons per day, the requirement of a submerged
          fill pipe.

     (7)  For the filling of storage tanks at end-users (i.e.
          service stations) serviced by bulk loading terminals
          processing more than 25,000 gallons per day, no change
          from present regulatory requirements of 901 control
          (Regulation 2, Section 1302.2).

     (8)  For the filling of storage tanks at end-users (i.e.
          service stations) serviced by bulk plants of between
          2,500 and 25,000 gallons per day throughput, the
          requirement of 90% control.

     (9)  For the filling of storage tanks at end-users serviced
          from bulk plants of less than 2,500 gallons per day
          throughput, or serviced by bulk distributors who
          deliver less than 2,500 gallons per clay, the require-
          ment of a submerged fill pipe.

     Adoption of the proposed amendments  to Regulations 2 and 3 to
accomplish the above will result in the following:

     (1)  Reduction of organic emissions  by approximately
          2 tons per day.
                                                                 C-8

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     (2)  Approximately  35  facilities  in the Bay Area may be
          affected.

     (3)  Estimated  cost of control  to achieve the above
          reduction  would be approximately $500,000, involving
          the installation  of vapor  balance systems.

     Attached are  the  recommended changes to Regulations 2 and 3 which
would accomplish  these reductions.

     The staff recommends that these amendments be adopted.
DJC:MF:j d
Attachments
                                                                C-9

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                     PROPOSED AMENDMENTS  TO
                            REGULATION  3

                    (Organic  Storage Tanks)
       53102  Compliance with any of sections 3102.1 through 3102.6 shall be
              deemed to be in compliance with Section 3101.  Showing of such
       compliance by the person responsible for an organic gas emission shall include
       applicable portions and/or c.ilculalion procedures contained in API Bulletin
       2514, "Evaporation Loss from Tank Cars, Tank Trucks and M.irinc Vessels,"
       in API Bulletin 2517, "Evaporation Loss from Floating Roof "Tanks," and
       in API Bulletin  2518, "Evaporation Loss from Fixed Roof Tanks."
       § 3102.1  Organic- gas -emissions rfrom-a-sMtionai^- -stow^c-tank-of .equal-to £>i-
               Jcss than- !-,900-l)Br-fdsrW[i.i«.-ih'-aHd-L«HtairjiR«i.urgaiiic-lu]itLI» u'liLa,
       vapor pressure grerU«--Jl*in -1 ,$ -psia. uiidtr-afujaJstocaj^rcomlittoy-':: diubirhcad-
      ^pacorea«iVuy-jjfraU:uLhan-5^sJialLiioi exceed. dial j-:"ijc..-ii n-Lidi_.JE  TANK,  CUNT A J KING  THE  SAME  LIQUID ,
WOULD EMIT  IF EQUIPPED WITH A  SUBMERGED FILL  PIPE.

   3102.11  ORGANIC GAS EMISSIONS  FROM THE  FILLING OF A
STAT IONARY  STORAGE TANK  Qi:  CAPACITY  GREATER THAN OR EQUAL
TO 2~,000  GALLONS  CUT  LESS THAN  OR EQUAL TO /1 2 ,000  GALLONS
AlTirroT-ri'ATNTTTri  ORGANIC LIQUIDS  WITH  A VAPOR  PRESSURE
GREATER •jT7ATT~IT5~~FSiA UNDER ACTUAL STORAGE COXMJTTTON'S ' SHALL
ROT" EXCEED  THAT AMOUNT OF ORGANIC GAS EMISSION  WHICH  THE
SAME  TANK    coNTOTTTNirTHE SAMJTTTOIIID ,  KOULD  EMIT  IT
EQUlPTIiD  WITH A VAPOR BALANCE  SYSl'EM IN GOOD  CONDTITON.
        §3102.4  Organic gas emissions from a stationary storage tank which has a
            _    storage capacity greater than  1,000 barrels, and which  contains
        Organic liquid having a vapor pressure under actual storage conditions greater.
        than 1.5 psia but  equal to or less than 1 1 psia and a head space reactivity
        greater than 5%, shall not exceed tli.il amount of organic gas emission which
        the same tank, conlaining the same organic liquid, "would emit if equipped
        villi a  floating roof in good condicion? Such organic gas emissions shall be
        calculated according lo API Bulletin 2517, "Evaporation  Loss from Floating
        Roof Tanks," or shall be calculated by applicable procedures acceptable to the
        Control Officer where API Bulletin 2517 procedures arc not valid.
        § *102.5  Organic g;is emissions from a stationary storage tank which has
                storage  capacity greater than 1,000 bancls and which contains
        organic liquid having a vapor pressure under actual storage conditions greater
        than 11.0 psia and a head space reactivity greater th.m •>%, shall not exceed
        that amount of organic gas emission which the same tank, containing (he same
        Organic liquid,  would  emit if  it wt-rc storing an organic liquid of 11 psia
        vapor pressure  and were equipped with a floating roof in good condition.
        Such organic gas emission shall be calculated according to  API Bulletin 2517.
                                                                             C-10

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              PROPOSED  AMENDMENTS TO  REGULATION  3

                   (BULK LOADING FACILITIES)
         § 3102.2  Organic .gas-cflws*ioiJS-calfi>J:Uc+l-OR. a J-itfiwl- from A -fiKility-
                merc-dtan •25,000-^rtHot-iS' pcr-ralefufar-tkiy of. Hr^anic-lupi
         »Jlctdvflj*>r pressure f-teMct J-l'wn-4 »rx]-,i-li«;uJ-spacc icjcitruy.jyc.ilec Uun_i%
         tnhrlransporkihlt: t'Onbi inert; 4.1 ri0%-of Tlifnmoimrrtut -would -be cinitttcd
         Orlolnrf,
         § 3102.3 -Organic-gas -emissions -ffom- a JacUiiy- lojiliiij:_ bcL\vxcn_ SQfi.
                            Jicittl -sp:icc LCuaiviiy..;:JciLCL tJiarC i'.'I Iiifa Lr:ini-
             fc 
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                  PROPOSED AMENDMENTS TO
                     REGULATION 3


                     (DEFINITIONS)
2006.1  BULK PLANT MEANS ANY FACILITY WHICH RECEIVES
        ITQUID ORGANICS. STORES Till: LIQUUTTN STATIONARY
STORAGE TANKS, AMD LOADS FROM TMOSIJ STORAGE TANKS TNTO
•TRANSPORTABLE coTPTATflEKij J-OR FURTHER DISTRIBUTION:	
2043.1  VAPOR BALANCE SYSTEM
        DFTWO OR
INTER-CONNECTED
FKOR
       TANAS
         MEANS
         WE KIT
A SYSTEM
THE VAPOR
                                CONSISTING
                                 SPACES
IN SUCH A KAY THAT
 ONE TO
TTQunn
WHEN LIQUID
   PROTi
                           IS TRANSFERRED
THE
THE"
OTHER
TTTE
  THE
VATDTT
VAPOR MOVES
    inn
THE
THE TANK
TANK RECEIVING
M wi-ucir
                                           THF
LIQUID IS REMOVED THUS  BALANCING (OR EQUALIZING)  THETRESSURE
IN THE VAPOR SPACE OF THE  INTERCONNECTED TANKS.
                                                            C-12

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                              PROPOSED  AMENDMENTS TO REGULATION 2

                                 VAPOR RECOVERY  FROM STORAGE TANKS
                     § 1302.22  The Air Pollution Control Officer shall not deny an authority
                     to operate for containers, reservoirs or tanks used exclusively for:
                     (a) The storage of gasoline having a capacity equal to or less than 2000
                     gallons and with a throughput of 6000 gallons per month or less.
Delete
Add
       (b) The storage of gasoline sen-iced from bulk terminals of less than
       25,000 gallons per day throughput. Such tanks shall comply with the vapor
       recovery requirements of § 1302.2 within 90 days of a change in service
       which results in deliveries from bulk terminals of 25,000 gallons per day
       throughput or more.
        (b)   THE  STORAGE OF GASOLINE WHEN  SUPPLIED  FROM
              BULK DISTRIBUTORS  OF  LESS  THAN 2,500  GALLONS  PER
        CALENDAR~DAY THROUGHPUT OR FROM BULK PLANTS OF LESS
        THAN 2,500 GALLONS  PER  CALENDAR DAY THROUGHPUT.   SUCH
        TANKS SHALL COMPLY  WITH THE VAPOR  RECOVERY REQUIREMENTS
        OF  $1302.2 WITHIN 90 DAYS  OF A  CHANGE  IN  SERVICE  WHICH
        RESULTS  IN DELIVERIES FROM BULK DISTRIBUTORS.  OR BULK
        PLANTS OF 2,500 GALLONS PER CALENDAR DAY  THROUGHPUT  OR MORE.


                    (c) The storage of gasoline in structures which the Air Pollution Control
                    Officer has determined that severe and unusual construction problems
                    would prevent the installation of equipment to meet the vapor recovery
                    requirements  specified in Section 1302.2. Such unusual construction prob-
                    lems include but arc not limited to tanks with offset fill lines, tanks located in
                    the basements of office buildings or under roadways.
                    (d) The storage of  gasoline and whose operation will cease on or before
                    July  1, 1975  upon presentation of adequate  supporting documents  to  the
                    Air Pollution Control Officer. This exemption from the vapor recovery
                    requirements specified in 1302.2 shall not apply if the operation ceases
                    prior to July 1, 1975  and recommences operation  after July 1, 1975.
                    (Adopted June 12,1974; June 37,197-1.)
  Add

         (e)  THE STORAGE OF GASOLINE  IN STORAGE  TANKS USED
               EXCLUSIVELY FOR THE FUELING  OF IMPLEMENTS OF
         HUSBANDRY.                                                           c_]3

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                         PROPOSED AMENDMENTS TO REGULATION 2

                                    DEFINITIONS
Add
     2013.1  BULK DISTRIBUTOR MEANS ANY PERSON WHICH RECEIVES
             ORGANIC LIQUIDS FROM A BULK PLANT AND DELIVERS
     THOSE ORGANIC LIQUIDS TO STATIONARY STORAGE TANKS.
     2013.2  BULK PLANT MEANS ANY FACILITY WHICH RECEIVES
             ORGANIC LIQUIDS, STORES THE LIQUID IN STATIONARY
     STORAGE TANKS, AisT) LOADS FROM THOSE STORAGE TANKS INTO
     TRANSPORTABLE CONTAINERS FOR FURTHER DISTRIBUTION.
     2013.3  QUANTITY PER CALENDAR DAY MEANS THE QUANTITY PER
             CALENDAR YEAR DIVIDED fcY 365.
                                                                C-14

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                              PROPOSED AMENDMENTS TO REGUIJVTION 2

                                   GASOLINE DELIVERY VEHICLES
1302*21  a)        Ho person  shall  store gasoline in or otherwise use or
            operate any gasoline'  delivery vehicle u'scd  for the delivery
            of gasoline for the servicing of inotor vehicles unless he
            shall first have obtained written authorization for such
            operation  from  the Air  Pollution Control Officer.   The Air
            Pollution  Control Officer shall not deny authorization for
            such  use or operation if  such vehicle is designed  and
            maintained to be vapor-tight and if such vehicle is equipped
            with  a system to recover  at least 905 of the  gasoline vapors
            displaced  during the  transfer of gasoline from the vehicle
            to storage tanks used to  service motor vehicles.  Any person
            v/ho delivers or authorizes the delivery of  gasoline to storage
            tanks without the proper  connection of. the  vapor recovery
            system to  the storage tank shall, be deemed  to be in violation
            of this Section.
        b)   ----- jSasolitte-deldver^verhi-crJres- ser \rrccd ~ sorLciy -f-ruitf
                   i & -e £ - ie B K- fehan- -2-5-, -(KM)- -g-ft-t^oivsr -^e :•? - 13 ay- tiwertxj*K>«rfe- -
                   -£ rem-fehe- 5reqwiren7enijs- -onr -3r3-
    b)       GASOLINE DELIVERY VEHICLES SERVICED SOLELY FROM  BULK PLANTS
        OF LESS THAN 2,500  GALLONS PER CALENDAR DAY THROUGHPUT  AND
        GASOLINE DELIVERY VEHICLES OWNED AND OPERATED BY  BULK DISTRIBUTORS
        OF LESS THAN 2,500  GALLONS PER CALENDAR DAY THROUGHPUT  ARE
        EXEMPTED FROM THE REQUIREMENTS OF  1302.21  (a).
                                                                     C-15

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           APPENDIX D

SUMMARY OF EMISSION INVENTORY AND
   COST ANALYSIS BY MISSOURI
 DEPARTMENT OF NATURAL RESOURCES

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                        PROPOSED REGULATION XXI

           SUMMARY OF EMISSION INVENTORY AND COST ANALYSIS
In trying to draft a workable Regulation XXI the Air Quality staff
realized that an accurate emission inventory needed to be assembled
for the St. Louis Area.  Through the cooperation and information
supplied by the petroleum- industry, that inventory has been completed
along with a cost/benefit analysis.  The following is a summary of
those results.

Total hydrocarbon (HC) emissions for the St. Louis Metropolitan Area
have been approximated at 122,000 tons per year (TPY) of which 81,500
tons is from mobile sources and 40,500 is from point and area sources.
With the existing level of control the gasoline marketing industry
contributes 9769 TPY or 8% of the total.  Requiring only submerged
filling at all facilities would reduce emissions to 8713 TPY or a'
0.86% reduction.  Although the cost/benefit is $125 per ton of HC
controlled, the emission reduction is not very substantial.  Various
alternatives that were analyzed were:

    A - Exempt all bulk plants'  -^300,000 gallons per month (gpm)
    B - Exempt all bulk plants  ^300,000 gpm from Section D only
    C - Exempt all bulk plants  ^300,000 gpm from Section C only
    D - No exemptions


It was determined that strategy C had the best (lowest) cost/benefit
ratio while still giving a substantial KC reduction.  Emissions would
be reduced by 3.64% with a cost/benefit ratio of $1362/ton of KC
controlled.  Maximum control (Strategy D) would give a 3.72% reduction
(0.08% reduction over C) at a cost/benefit of $1584/ton.

To obtain an idea of what this figure means, a cost/benefit was
performed on installing an electrostatic precipitator to
control particulates from a power plant. 'The example was the
Chamois Power Plant where ESP costs were $2,000,000 to collect an
additional 7205 TPY of particulates.  This corresponds to $277/ton
of pollutant controlled.  Thus we see that this regulation costs about
six times as much per ton of pollutant reduced.

Based on the accumulated data, a fourth draft of the regulation
has been prepared.  The changes are:

    1.  Section A.3. - The words "all" and "prevent" were replaced
        by "the" and "limit" to avoid any implication of 100% efficiency.

    2.  Section B.I. - The psia limit was raised to 1.8 to exempt Benzene

    3.  Section C.2.a. -.Raising the emission limitation from 0.4 to
        0.5 gram per gallon was made to account for the ranges of
        inlet concentrations to the vapor recovery unit.  This would
        represent an 88-92% efficiency on the unit.
                                                                    D-l

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4.  Section C.3. - This was an addition to provide for the
    exemption of the small loading facilities that are expensive
    to control and produce small emission reductions.  This is
    what is referred to as Strategy C.  However, all new facilities
    must comply with the regulation.

5.  Section D.l.c.(2) - This addition helped to further clarify
    the regulation's applicability.

6.  Section D.2.d. - This addition was necessary due to the
    exemption given to the small loading facilities.

7.  Section E.I. - Compliance dates were extended due to slow
    delivery times for equipment.
                                                                D-2

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                         EMISSION INVENTORY


                           Bulk Terminals

Number:  9

Tanks:  42
    Floating or lifter roof - 38
    Fixed roof              -  4

Throughput:  702,608,376 gallons per year (gpy)
    Trucks - 671,226,372 gpy
    Barges -  31,382,004 gpy

Emissions:  Tons/year (tpy)

    Uncontrolled  Existing Control. Submerged Fill Only  Full Vapor Recovery
                                                        .4 gm/gal  .5 gin/gal
       10,105          2,307            2,048              754        828


Note:  Not readily seen in the above figures is an emission elimination
at the bulk terminal when loading each vapor laden tank truck.  The
tank truck full of vapors prevents the emission of vapors that would
ordinarily occur when gasoline is loaded into an empty truck, therefore,
there is almost a double savings.
                            Bulk Plants

Number:   42

Throughput:  51,800,796
    All  bulk plants reporting had average monthly throughputs of
    less than or equal to 300,000 gallons.

Emissions:  (tpy)

    Uncontrolled  Existing Control    A      B      C      D
        791            679           575    491    376    281

    A -  Exempt plants ^300,000 gallons per month (gpm) from
        Sections C & D if trucks are filled with submerged fill pipe.

    B -  Exempt plants  ^300,000 gpm from Section D.

    C -  Exempt plants  ^300,000 gpm from Section C if trucks are
        filled with a submerged fill pipe.

    D -  No exemptions.
                                                                    D-3

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                         Service Stations

*Number:  Approximately 1500

*Throughput:  Approximately 600,000,000 gallons/year

Emissions:  (tpy)

    Uncontrolled  Existing Control  Submerged Fill Only  Vapor Balance
        7050            6783               6090              4119

*We did not have a very complete response as to number of stations
and gasoline throughput.  These numbers were picked based upon vehicle
miles traveled, population, and information supplied by the oil industry.
                          Total Emissions
                            Submerged
    Uncontrolled  Existing  Fill Only
                                            A
                             B
                                                       Full Vapor Recovery
Terminals  10,105
Plants        791
Stations    7.050
           17,946
    2307
     679
    6783
    9769
                                       828  828  828
                                       575  491  376
                                      4119 4119 4119
                                      5522 5438 5323
Total hydrocarbon emissions for the St. Louis Metropolitan Area are
approximately 122,000 tons/year of which 81,500 tons is from mobile
sources and 40,500 tons is from point and area sources.
Emission Reduction (120.000 tpy total)

      % of total     From. (TFY)     To (TPY)
Existing Contribution    8.0
Submerged Fill Only      7.14
A                        4.52
E                        4.45
C                        4.36
D                        4.28
Changing from 0.4
   to 0.5 gm/gallon
                                           9769
                                           9769
                                           9769
                                           9769
                                           9769
                                           9769

                                            754
                                      9769
                                      8713
                                      5522
                                      5438
                                      5323
                                      5228

                                       828
                                                                % Reduction

                                                                     0
                                                                    .86
                                                                   3.48
                                                                   3.55
                                                                   3.64
                                                                   3.72

                                                                   0.06
                                                                    D-4

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                            COST ANALYSIS
Terminals:

    9 vapor recovery units d>$250,000                   $2,300,000
    4 floating roof retrofits @>$30,000                    120.000

                                           TOTAL       $2,420,000


Bulk Plants (42)

    To comply with Section D - $2000/plant             $   84,000
    To comply with Section C -
              $15,000/plant (vapor balance)               630,000
                4,000/truck (100 trucks)                  400.000

                                           TOTAL       $1,114,000


Service Stations (1500)

    1500 stations @>$2500/station                       $3,750,000


Trucks (200)

    Cost to convert trucks                             $1,000,000


               COST/BENEFIT OF VARIOUS. ALTERNATIVES

1.  Require only submerged fill

    Cost ($)       Benefit (tons HC)       Cost/B€=nefit
    131,800             1056                 $125/ton
                                                or
                                             $.47/gal
2.  Exemption A

    Cost ($)       Benefit (tons HC)       Cost/Benefit
    2,420,000           4247                 $1688/ton
    3,750,000                                    or
    1.000.000                                $6.33/gal
    7,170,000

3.  Exemption B

    Cost ($)       Benefit (tons HC)       Cost/Benefit
    2,420,000           543;8               $1507/ton
      630,000                                  or
      400,000                              $5.65/gal.
    3,750,000
    1.000.000
    8,200,000
                                                                     D-5

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4.  Exemption C

    Cost ($)       Benefit (tons HC)       Cost/Benefit
    2,420,000           5323                 $1362/ton
       84,000                                    or
    3,750,000                                $5.10/gal
    1.000.000
    7,254,000

5.  Exemption D

    Cost ($)       Benefit (tons HC)       Cost/Benefit
    2,420,000           5228                 $1584/ton
       84,000                                    or
      630,000                                $5.94/gal
      400,000
    3,750,000
    1.000.000
    8,284,000
                                                                    D-6

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                               TECHNICAL REPORT DATA
                        (Please read Instructions on the reverse before completing)
|'i. REPORT NO.
! EPA 340/1-77-013
                3. RECIPIENT'S ACCESSION NO.
,-:. TITLE AND SUBTITLE
j Economic Analysis  of.Vapor Recovery
! Systems on Small Bulk Plants
                5. REPORT DATE
                 September 1976
                6. PERFORMING ORGANIZATION CODE
 T. -MJTHOHIS)
                                                    3. PERFORMING ORGANIZATION R«ORT NO.
•3. PERFORMING ORGANIZATION NAME AND ADDRESS
 Pacific Environmental Services,
 1930  14th Street
 Santa Monica, CA   90404
                10. PROGRAM ELEMENT NO.
Inc.
                1 1. CONTRACT/GRANT NO.
I
                                                      68-01-3156, Task  24
! 12. SPONSORING AGENCY NAME AND ADDRESS
| U.S.  Environmental Protection Agency
i Division of Stationary Source Enforcement
i Washington, Q.C.   20460
                13. TYPE OF REPORT AND PERIOD COVERED
                  Final Report
                14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
  Project Officer:   Mr. John Busik
      (202) 755-2560
 ;•;. A3STSACT
  This study was conducted  to provide economic data  and analysis  to aid
  the Environmental Protection Agency in assessing the feasibility and
  reasonable applicability  of vapor recovery systems (particularly
  bottom-loading} on bulk plants.  Other factors which should be  used
  in assessing feasibility  and reasonable applicability may be mentioned
  in this report but are not fully analyzed.
1-7.
                            KEY WORDS AND DOCUMENT ANALYSIS
                DESCRIPTORS
     b.IDENTIFIERS/OPEN ENDED TERMS
                                                                c. COSATI Field/Croup
  Air Pollution
  Gasoline Bulk Terminals
  Vapor  Balancing
)  Vapor  Recovery
     Air Pollution Control
     Stationary Sources
     Organic Vapors
     Organic Vapors
ii';.- D:Srr,i3OTio.N STATEMENT
S  Release:   Unlimited
!  Available  free from DSSE/EPA as
!  .supplies PGrrr.it
                                         19. SECURITY CLASS (This ReporrJ
                                         Unclassified
                            21. NO. OF PAGES
                                         2C. SECURITY CLASS (This page J
                                         Unclassified
                            2K. PRICE
 EPA Form 2220-1 JSev. 4-77)   PREVIOUS EDITION is ODSO'-ETE

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