EPA 340/1-77-010
APRIL 1977
Stationary Source Enforcement Series
STAGE I VAPOR RECOVERY AND
SMALL BULK PLANTS IN
WASHINGTON. D.C.,
BALTIMORE, MD.,
AND
HOUSTON/GALVESTON. TX.
1
ynglg
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Enforcement
Office of General Enforcement
Washington, D.C. 20460
-------
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 Environ-
mental Protection Agency, nor does mention of trade names or commer-
cial products constitute endorsement or recommendation for use.
-------
FINAL REPORT
EFFECTS OF STAGE I VAPOR RECOVERY REGULATIONS ON SMALL
BULK PLANTS AND ON AIR QUALITY IN THE WASHINGTON, D.C.,
BALTIMORE, MD. AND HOU.STON/GALVESTON, TX. AREAS
By
R.J. Bryan, M.M. Yamada and R.L. Norton
Project Officer: John R. Busik
Contract No. 68-01-3156, Task Order No. 28
Prepared for:
U.S. Environmental Protection Agency
Division of Stationary Source Enforcement
Washington, D.C.
March 1977
-------
The Stationary Source Enforcement Series of reports
is issued by the Office of Enforcement, U.S. Environ-
mental Protection Agency, to report enforcement related
data of interest. Copies of this report are available
free of charge to Federal employees, current E.P.A. con-
tractors and grantees, and non-profit organizations -
as supplies permit - from the Air Pollution Technical
Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina 27711 or may
be obtained, for a nominal cost, from the National
Technical Information Service, 5285 Port Royal Road,
Springfield, Virginia 22151.
-------
TABLE OF CONTENTS
Section Page
I. PROJECT BACKGROUND AND SCOPE 1-1
II. SUMMARY II-l
III. BULK PLANT OPERATION III-l
A. INTRODUCTION TO THE INDUSTRY AND OVERALL
CHANGES IN THE INDUSTRY III-l
B. BULK PLANTS IN BALTIMORE AND NATIONAL
CAPITAL AQCRs III-3
C. BULK PLANTS IN THE HOUSTON/GALVESTON AREA . I11-11
IV. HYDROCARBON EMISSIONS CONTROL AT BULK PLANTS . . IV-1
A. HYDROCARBON EMISSIONS CONTROL REGULATIONS . IV-1
B. SOURCES OF EMISSIONS ASSOCIATED WITH
HANDLING OF GASOLINE IV-S
C. EMISSION CONTROL TECHNOLOGY IV-7
D. EMISSIONS ESTIMATES IV-15
E. DIRECT COSTS OF EMISSION CONTROL SYSTEMS . . IV-29
V. PROJECT APPROACH AND METHODOLOGY V-l
A. INFORMATION SOUGHT ABOUT BULK PLANTS .... V-l
B. SOURCES OF DATA V-3
C. DATA GATHERING IN THE FIELD V-3
VI. FINANCIAL ANALYSIS VI-V
APPENDIX A. INVENTORY OF GASOLINE BULK PLANTS IN AIR
QUALITY CONTROL REGIONS A-l
APPENDIX B. VAPOR RECOVERY REGULATIONS EFFECTIVE IN
BALTIMORE AQCR AND NATIONAL CAPITAL AQCR ... B-l
APPENDIX C. VAPOR RECOVERY REGULATIONS EFFECTIVE IN
HOUSTON/GALVESTON AQCR ..... C-l
APPENDIX D. QUESTIONNAIRE USED IN FIELD SURVEY D-l
APPENDIX E. LIST OF FIRMS AND PEOPLE CONTACTED E-l
APPENDIX F. FINANCIAL ANALYSIS F-l
-------
TABLE OF CONTENTS (continued)
LIST OF FIGURES
Figure Page
1. APPLICABLE GASOLINE DISTRIBUTION NETWORK .... 111-14
2. LOCATION AND NUMBER OF GASOLINE BULK PLANTS
IN BALTIMORE AND NATIONAL CAPITAL AIR QUALTIY
CONTROL REGIONS 111-15
3. AVERAGE DAILY GASOLINE THROUGHPUT DATA FROM
STATES OF MARYLAND AND VIRGINIA . 111-19
4. AVERAGE DAILY GASOLINE THROUGHPUT PES SURVEY
DATA FOR MARYLAND AND VIRGINIA 111-20
5. AVERAGE DAILY GASOLINE THROUGHPUT TO DIFFERENT
TYPES OF CUSTOMERS (DATA FROM STATE OF MARY-
LAND SURVEY II1-2-1
6. AVERAGE DAILY GASOLINE THROUGHPUT TO DIFFERENT
TYPES OF CUSTOMERS (BULK PLANTS INTERVIEWED BY
PES) 111-22
7. RELATIONSHIP BETWEEN TOTAL RACK THROUGHPUT OF
GASOLINE AND VOLUME DISTRIBUTED TO NON-EXEMPT
ACCOUNTS (BASED ON DATA FROM STATE OF MARYLAND
SURVEY) .111-23
8, LOCATION OF BULK PLANTS IN THE HOUSTON/
GALVESTON AREA 111-24
9. AVERAGE DAILY GASOLINE THROUGHPUT PES SURVEY
DATA FOR HOUSTON/GALVESTON, TEXAS II1-27
10. DIAGRAM OF LOADING RACK AND TRUCK MODIFICATIONS
TO RECOVER GASOLINE VAPORS DURING DELIVERY TRUCK
FILLING OPERATIONS BEING INSTALLED IN HOUSTON/
GALVESTON PLANTS IV-13
LIST OF TABLES
Table Page
II-l SUMMARY OF SMALL GASOLINE BULK PLANT
OPERATIONS . . II-2
11-2 ESTIMATED NUMBER OF PLANTS TO BE AFFECTED BY
VAPOR RECOVERY REGULATIONS AND PROBABLE
COMPLIANCE II-6
III-l BULK PLANT GASOLINE - MD. AREAS III - IV .... II1-16
II1-2 BULK PETROLEUM PLANTS - VIRGINIA AQCR 7 .... II1-17
ii
-------
TABLE OF CONTENTS (continued)
LIST OF TABLES (cont)
Page
BULK PLANTS IN BALTIMORE/WASHINGTON D.C,
AREAS INTERVIEWED BY PES 111-18
II1-4 SUMMARY OF DATA OBTAINED ON BULK PLANTS IN
HOUSTON/GALVESTON AREA 111-25
IV-1 GASOLINE DISTRIBUTION IN BALTIMORE AND
WASHINGTON, D.C. AREAS: 1975 ESTIMATE IV-16
IV-2 HYDROCARBON EMISSIONS FROM BULK PLANTS RELATED
TO NUMBER OF BULK PLANTS WITH VAPOR CONTROL . , IV-23
IV-3 SUMMARY OF DECREASE IN EMISSIONS FROM BULK
PLANTS IN HOUSTON/GALVESTON AREA AS FACILITIES
COMPLY WITH HYDROCARBON VAPOR RECOVERY
REGULATIONS IV-28
iii
-------
I. PROJECT BACKGROUND AND SCOPE
Environmental Protection Agency (EPA) regulations for the
storage and transfer of gasoline require bulk plants in certain
specified air quality control regions to control hydrocarbon
emissions from their operations. Vapor recovery systems are to
be installed and operated in a manner that will prevent release
to the atmosphere of no less than 90 percent by weight of organic
compounds in vapors generated during gasoline transfer operations.
Individual states have submitted control strategies in State
Implementation Plans and enacted laws which frequently provide
for the exemption of small bulk plants from hydrocarbon emissions
control regulations. Conditions for granting these exemptions
are not uniform among the states, e.g., throughput limits oftfcn
differ. The rationale for allowing exemptions has generally been
based on the anticipated adverse economic impact to the industry
or on the estimated minor contribution of bulk emissions to the
area wide hydrocarbon/oxidant levels.
In order to determine whether Federal vapor recovery regu-
lations need revision, the Division of Stationary Source Enforcement
(DSSE) contracted with Pacific Environmental Services, Inc. (PES) to
perform a preliminary investigation of the impact of vapor recovery
regulations on small bulk plants. This first study focused on bulk
plants in the San Joaquin Valley and San Diego California areas and
the Denver, Colorado area. The results of this task, reported in
"Economic Analysis of Vapor Recovery Systems on Small Bulk Plants,"
describe the following aspects of gasoline bulk plants.
1. Average gasoline throughput and range of
throughputs.
2. Average cost of installing bottom loading vapor balance
systems on the bulk plant tanks, loading rack
and trucks.
3. Financial profiles of classes of bulk plants.
4. Short term economic impact of installing vapor
control equipment.
1-1
-------
This current study is a similar survey of bulk plant operations
in the specific areas surrounding Baltimore, Md. and Washington,
D.C, and Houston/Galveston, Tx, It is being performed to determine
whether the descriptive, market and economic data presented in the
earlier report can be adequately applied to other areas of the
country. Therefore the tasks to be completed are quite similar:
•
1. Provide an inventory of bulk plants.
2. Describe facilities and vapor recovery
equipment at the bulk plants.
3. Classify these bulk plants by through-
put.
4. Determine types of customers and
volume dispensed to non-exempt accounts,
agricultural accounts and accounts with
small tanks.
5. Determine the financial profile of typical
bulk plants.
6. Estimate the long and short term economic
effects of installing and maintaining
vapor recovery equipment, particularly
with respect to the number of anticipated
plant closures or plant start-ups.
7. Estimate emissions from bulk plant opera-
tions and the decrease in emissions if
controls are adopted.
All information obtained in these tasks is to serve as a basis
to determine if there is a specific gasoline throughput
below which gasoline bulk plants should not be required to install
vapor recovery systems for incoming or outgoing gasoline shipments.
1-2
-------
II. SUMMARY
Inventories of gasoline bulk plants were generated for the
Baltimore and National Capital AQCRs (56 plants) and for the
Houston/Galveston AQCR (70 plants), Similarities between these
plants and facilities in the San Diego and San Joaquin Valley
areas of California and the Denver, Colorado area, which were
inventoried by PES in an earlier study (1), were examined by
comparing storage capacity, number of delivery trucks, gasoline
throughput, volume of other products and services, types of cus-
tomers, vapor recovery system costs and their financial impact.
A comparison of plant operations in these four areas is given in
Table II-l.
A typical bulk plant, covered in this inventory, would be a
wholesale gasoline distributor who receives his supply solely by
truck and has an average plant throughput of about 5,000 gallons
(20,000 1.) per day. The bulk plant provides direct product
delivery to the customer and is usally located in or near a small
town rather than in a large urban area. Although bulk plants fre-
quently market petroleum distillates other than gasoline, this study
has been limited to the gasoline marketing segment of the industry.
Hydrocarbon emissions from such plants are associated with (1) trans-
fer of gasoline from the delivery trailer to storage tanks at the
bulk plant, (2) breathing losses from daily temperature changes
at the storage tank, (3) transfer of gasoline from the storage
tank to the bulk plant delivery truck, and (4) miscellaneous events
such as spillage and leakage at valves, hatches and piping joints.
Emission controls are designed to recover the vapors displaced from
the empty storage tank and return them to the delivery trailer or
to recover the vapor displaced from the empty bulk plant delivery
truck and return them to the plant storage tank. Breathing losses
can be reduced by using pressurized tanks.
II-l
-------
Table Hrl. SUMMARY OF SMALL GASOLINE BULK PLANT OPERATIONS
Areas
San Ziega/ian Joa-
quin Valley Areas
Cenver Area
Salt'rore/
Vjsfcir.gton, Q^r.
Area
Houston/
Salveston Area
No. of
Bulk
Plants
218
45
56
70
Gasoline Storage Tanks
Average
Gasoline
Throughput
Liters/day*
21.400
19.200
16.500
•»'•"
31.600
Ave.
No. of
Tanks
3.2
3.5
3:0
,04-
£5 '
I Plants
with
Aboveground
Storage
66
79
45
". 80 ^
X Plants
with
Underground
Storage
28 :
21
• 55
. 20
Ave.
Storage
Capacity
LUersa
183
142
192
182
". Plants
with Vapor
Recovery
on Incontng
Loads
18
• 37
75
Outgoing Loads
XTop
loading
90
96
90
1 Bottoa
Loadl ng
. 10
4
10
Ave.
Ho. of
Trucks
2.2
2.T
2.0
S Plants
with
Submerged
Filling
74
67
34
1 Plants
with Vapor
Recovery
9 :
0
46
Customers Accounts
t Throusnput
Agricultural
64
46
~2S
» Throughput
Seall
Tanks c
~77
79
~50
l«ters/3.7854 • jallons
bS£rer;«d fill pipes In the trucks and not on the loading racks. If only
properly equipped trucks are used to haul gasoline, then submerged filling
tecoxs a core effective pollution reducing technique
than 7.800 1. (2.000 9*1} capacity. Including agricultural tanks
ro
-------
Although bulk plant optr«t1ons are basically quite similar
in these several areas of tht county, there are some noteworthy
regional differences.
First, the average daily gasoline throughput at a bulk plant
in Houston/Galveston is significantly greater than in other parts
of the country. Also, more of that gasoline is going to non-exempt
accounts. This increases the potential amount of emissions a given
uncontrolled plant could generate during routine operations.
In all areas studied, most of the gasoline is delivered from
the bulk plant to accounts with small tanks, i.e., less than 2000
gal capacity (7600 1.). Also, 1n all areas, a reasonably large
portion of that gasoline reaches agricultural users. One reason
so much gasoline dispensed through bulk plants does go to small
accounts is that customers with larger tanks, which would be non-
exempt, are able to receive delfveries directly from transports
which have been loaded at terminals.
Average storage capacity in the Denver area is less, which
means more frequent deliveries. It should also be noted that only
a few plants have installed vapor controls for incoming gasoline
shipments in this area.
The amount of underground storage around Baltimore and Washing-
ton, D.C. is substantial. This is an effective means of reducing
tank breathing losses. Also, plants in the eastern United States
deal much more heavily in distillates because so many people use #2
fuel oil for heating.
Only in sections of California and around Houston/Galveston
has there been substantial progress in controlling hydrocarbons
emitted when bulk plants receive transport deliveries of gasoline.
Efforts to recover vapors when small delivery trucks are filled have
been minimal except near Houston/Galveston.
II-3
-------
The average cost to install a vapor balance system to recover
hydrocarbons from deliveries to the bulk plants was found to be
$3,500. This corresponds with data previously reported (1, 2).
The cost and equipment requirements to recover hydrocarbons from
the filling of delivery trucks at the bulk plant loading rack have
not yet been suitably resolved. This is primarily because two
distinct, different vapor recovery systems are being installed:
top loading vapor recovery systems and bottom loading vapor recovery
systems.
The equipment being used in the Houston/Galveston area for
major oil company owned bulk plants appears to demonstrate that
top loading vapor recovery equipment is feasible, effective and
affordable. The average cost of adapting a loading rack and an out-
going delivery truck at plants surveyed in this study was $7,000.
(Details are provided in Section IV. To substantiate these data,
additional, more detailed investigations of the cost, equipment
requirements and system efficiency of top loading vapor recovery
systems are underway).
Bottom loading vapor recovery systems will bt substantially
more expensive than top loading systems. The only facility contacted
in this study which had installed a bottom loading system provided
these costs for work done in 1974:
1} converting the loading rack
$21,000
2) converting two small delivery trucks
$10,500
Bulk plants are paricularly interested in a bottom loading system
because, even though the initial expense can be much greater than a
top loading system, modernizing the loading operation makes it simpler,
safer, faster and thereby potentially more profitable.
II-4
-------
If the bulk plant is found to be responsible for installing
vapor recovery devices on his customers' non-exempt tanks, the
operator could, at an average cost of $400 per tank, need to spend as
much as $20,000; whereas, a customer would be unlikely to have to
spend more than $2,000.
Sufficient data on operating and maintenance costs were not
available for any meaningful discussion.
The financial impact of vapor recovery regulations on a small
bulk plant depends primarily on the ability of the owner to obtain
funds for the initial investment in equipment. Analysis indicates
the smallest size operation which could qualify for the loans needed
to purchase and install a top loading vapor balance system which
costs $10,000 for trucks, tanks and loading rack would have to have
an annual throughput of 600,000 gallons (2,300,000 liters). This
study showed that 40% of the plants in the Baltimore and National
Capital AQCRs and 6% of the plants in the Houston/Galveston AQCR
have throughputs below this level. An earlier study performed by
PES showed that 25% of the plants in the San Diego, San Joaquin
Valley and Denver AQCRs also have annual throughputs below 600,000
gallons (2,300,000 liters), A spokesman for a major oil company
stated 1,000,000 gallons/year (3,800,000 liters/year) throughput
should be the minimum gasoline sales volume before a bulk plant
could be considered profitable. Owners with business volumes between
these two numbers are going to have to make a business judgement
about how compliance with vapor recovery regulations will affect
them economically. Bulk plant operators interviewed in this study
were asked what cost levels would constitute undue economic hard-
ships and thereby cause them to either close their bulk plant or
discontinue bulk plant gasoline sales. Based upon these responses,
Table II-2 was prepared. As can be seen, those facilities with
daily throughputs of less than 4,000 gal. (15,000 1.), which is
equivalent to an annual throughput of less than 1,040,000 gal.
II-5
-------
(3,940,000 1.), would be those most likely to not be able to cope
with the economic stress imposed on them as a result of installing
vapor recovery. An overall closure rate of 25% is quite possible.
II-6
-------
Table II-2.
ESTIMATED NUMBER OF PLANTS TO BE AFFECTED BY VAPOR RECOVERY REGULATIONS AND
PROBABLE COMPLIANCE
i
r~
Type of facili-
ty affected by
throughput level
> 20, 000 gal /mo.
>4,000 gal /day
>6,000 gal /day
>2,000 gal /day
to non-exempt
accounts
> 20, 000 gal /mo
>4,000 gal/day
>6,000 gal /day
>2,000 gal /day
to non-exempt
accounts
Number of Plants
Required to
comply
70
54
43
32
45
25
15
14
Already in Compliance
Phases I & II
Houston/Gal ves;
22
22
20
6
Phase I only
ton AQCR
47
42
33
11
Not in full compliance
Probably
would close
16
0-8
0
0-2
Baltimore and National Capital AQCRs
1
0
0
1
18
14
8
14
11-16.
2-6
0
0
Probably3
would comply
32
24-32
23
24-26
28-33
19-23
15
14
'Phases I and II
-------
III. BULK PLANT OPERATION
A. INTRODUCTION TO THE INDUSTRY AND OVERALL CHANGES IN THE
INDUSTRY
An industry overview has been presented in previous reports
(1, 2); therefore, only a brief summary will be given here.
A small bulk plant has been considered to be a wholesale
gasoline distributor who receives his supply solely by truck and
has an average plant throughput of less than 20,000 gal/day
(76,000 I/day). Although the bulk plants frequently also market
distillates, agricultural supplies or automotive supplies, this
study has been intentionally limited to examine only the gasoline
distributing segment of the bulk plant industry. Figure 1 is a
schematic of the gasoline distribution network which relates to
bulk plants. The bulk plant functions primarily to provide the
service of direct product delivery to the customer. With very
few exceptions bulk plants and their customers are located in or
near smaller cities and towns, quite removed from dense metropolitan
areas * The marketing technique of major concern in this study
involves four steps: 1) gasoline is transported from the terminal
to the bulk plant in trailers of 8,000 gal, (30,000 Incapacity;
2) the gasoline is transferred from the trailer to storage tanks
at the bulk plant; 3) gasoline is pumped through a loading rack
into compartmented delivery trucks of 1000 to 3*000 gal. (4,000 to
12,000 1.) total capacity; 4) these smaller trucks then deliver
to the customers'tanks. Deliveries from small trucks are generally
made to customers who have, 1) tanks with a capacity between 125 and
2,000 gal (500 to 7,600 1.); 2) variable demand and require prompt
delivery and 3) tanks located away from improved roadways or in
other limited access areas.
Locations and numbers of bulk plants in the three AQCRs of interest
are shown in Figures 2 and 8
III-l
-------
Typical customers who would receive these smaller volumes of
gasoline include farms, "Mom and Pop" type service stations, and
commercial accounts such as vehicle fleet operators.
A consumer with a high volume throughput and storage tanks
large enough to accommodate a major portion of a 8,000 gal (30,000
1.) load of gasoline may buy directly from the terminal or he may
place an order with a bulk plant. In the Baltimore/Washington, D.C.
areas, the majority of independent jobbers owned a large transport.
This allows the bulk plant operator greater latitude in scheduling
when, where and how much gasoline could be delivered either to the
bulk plant or to customers. For example, a school bus fleet owner
with a 4,000 gal (15,000 1.) tank could probably not get a major
oil company owned transport to make about a 50 mile (80 km.) round
trip from the terminal to deliver only a portion of the transport
capacity at a time most convenient to the customer. If this customer
places an order with the bulk plant, the bulk plant could transport
a full load of product from the terminal, deliver directly to this
customer and perhaps one or two others who are nearby to empty the
transport. Thus, it is possible for the independent bulk plant opera-
tor to completely bypass the bulk plant storage and loading facilities.
In this study a significant amount of gasoline was found to be
distributed in this manner to account with large tanks, e.g., service
stations or fleet operators. The bulk plant operators have been
aggressively acting to increase the amount of gasoline sold by direct
haul from the terminal to the customer. Direct hauling of gasoline
is more profitable because the cost of two transfer operations are
eliminated. Also, the operators believe they may be able to comply
with current state requirements to refill vapor laden delivery vessels
only at facilities equipped with a vapor recovery system by bypassing
the bulk plant and hauling direct from the major terminal which is
equipped with vapor recovery.
III-2
-------
Gasoline bulk plants are diminishing in importance as a
major method of marketing gasoline. Comparing 1972 Census Data
(8) with the 1975 and 1976 National Petroleum News marketing
surveys ( 9,10) indicates a closure of approximately 3,700 bulk
plants nationwide in these four years. Of the 1810 plants which
closed between 1975 and 1976, almost all were affiliated with major
oil companies. Commission agent operated bulk plants are frequently
offered for sale to the agent. If the operator does not elect to
purchase the plant and become an independent jobber, the facility will
generally be completely dismantled.
Reduced profitability in gasoline sales has been a uni-.
versa! complaint of bulk plant operators. The most frequently
heard comments were, 1) gasoline allotments have not increased
in the past few years; 2) the purchase price of gasoline at the
terminal has increased; 3) delivery and operating costs have
increased; 4) gross margins have remained the same; 5) competi-
tion effectively prevents price increases; 6) discount price
self service stations are retailing gasoline at nearly the same
price a bulk plant must charge; 7) the cost of complying with
spill prevention and control regulations and vapor recovery control
requirements has resulted in varying degrees of hardship to the
operators and 8).FEA regulations -- 10 CFR 212.93A and B and 10
CFR 205.D ~ effectively prohibit passing along any non-product
cost, such as vapor recovery, to the customer.
B. BULK PLANTS IN BALTIMORE AND NATIONAL CAPITAL AQCRs
1. Description of Bulk Plants Surveyed
Names and addresses of all bulk plants within the Baltimore
and National Capital AQCRs are given in Appendix A. Their locations
are shown in Figure 2, a map of both AQCRs.
Both the Maryland Bureau of Air Quality and Noise Control
and the Virginia State Air Pollution Control Board have compiled
III-3
-------
descriptions of all bulk plants listing, 1) the plant gasoline
throughput; 2) numbers and types of tanks; and 3) numbers and types
of trucks. The Maryland list, shown in Table II.I-1, is based on 1974
data and also indicates the percentage of gasoline distributed to
exempt customers. The Virginia list, shown in Table 111-2 is based
on data gathered in 1972, although it was published in a February
1975 emissions data report. PES has prepared a similar summary,.
presented in Table III-3 of information obtained from personal inter-
views with bulk plant operators in these areas. Combining and
comparing these three summaries, several statements about through-
put, customers and emissions can be made.
Two histograms, Figures 3 and 4, have been prepared to show
the average daily gasoline throughput for the bulk plants in the
two AQCRs. Figure 3 is based on data from Maryland and Virginia
and Figure 4 is based upon PES survey data. Comparisons among
these data and the previously reported data (1) are tabulated
below:
Gasoline
Throughput
4,000 gal /day
<(15,000 I/day)
10,000 gal/day
<(38,000 I/day)
Percentage of Bulk Plants
Maryland & Virginia
56%
92%
PES
57%
89%
Reference 1
51%
89%
III-4
-------
Since the original of Table III-2 contained company names, a direct
comparison of changes in throughput and storage was possible. Ten
plants were contacted and all responded. As of 1972 the total
throughput at these plants was 15,455,000 gal/year (58,500,000 1/yr)
and their gasoline storage was 393,000 gal. (1,500,000 1.) The new
data provided PES show their total throughput has decreased by
34% to 10,224,000. gal/year (38,700,000 l/year)although their
gasoline storage capacity has increased by 24,000. gallons. (91?QQQ 1.1
The largest bulk plant operation has decreased its yearly throughput
from 5,400,000 gal (20,000,QQQ 1.1 to 4,500,000 gal, (17,000,0001,1
Assuming a plant operates five days a week, 52 weeks a year, this
particular facility has decreased its average daily throughput
from 21,000 gal (79,000 l.)to 17,000 gal, (66,000 1,) One plant which
had a 1972 throughput of 1,600,000 gal (6,000,000 1). and a storage
capacity of 34,000 gal (129,000 1.) has closed. Comments by former
competitors suggested it was too far from the majority of its custo-
mers, so its transportation costs were inordinately high. Even
excluding this plant, a 25% decrease in gasoline throughput in Virginia
is still evident,
In Maryland, the average annual gasoline throughput appears to
have increased. In 1974, 37 plants delivered 39,000,000 gal (148,000 1.)
through their loading racks; 28 plants "in 1975 delivered
32,000,000 gal (120,000,000 1.). Extrapolating the gallonage through 28
plants to the expected throughput for 37 plants suggests an average increase
in gasoline volume of 7%.
III-5
-------
Gasoline storage capacity at a typical plant in the Baltimore-
Washington, D.C. area will consist of a 20,000 gal. (76,000 1.)
storage tank for each grade of gasoline—regular, premium and
unleaded. Excluding one plant with two above ground tanks each
with a 120,000 gal (450,000 1.) capacity, the amount of gasoline
stored in below ground tanks is about 5% greater than that stored
in above ground tanks. Generally the size range in above ground
tanks is 10,000 to 30,000 gal (38,000 to 114,000 1.) capacity. For
underground tanks, the capacities vary from 6,000 to 20,000 gal.
(23,000 to 76,000 1.). Storage capacity for distillates depends
primarily on the marketing emphasis of a particular plant; therefore,
it may range from 0 upwards. The largest storage facility could
accommodate 1,900,000 gal. (7,000,000 1.) of fuel oils, kerosene
and diesel fuel. Overall, the plants surveyed sold about 6 x 10
gal/year (22 x 106 I/year) of distillates. This is one and one-half
times their total gasoline sales and two and one-half times the
sales of gasoline through the bulk plant.
Pumping rates are between 100 and 300 gal/min (380 and 1,140
1/min) with the majority having 200 gal/min (760 1/min) pumps. The
account trucks have capacities of 1,000 to 3,000 gal (3,800 to
11,400 1.) and may have up to five compartments. The typical bulk
plant will have two of these trucks for gasoline deliveries. Plants
with high volumes of distillates may have as many as six other small
trucks, but the operators generally prefer to dedicate a truck for
gasoline. This reduces problems with contamination and cleaning and
it also reduces the possible number of trucks which might need to be
equipped with vapor recovery equipment.
Only 10 of the 28 plants surveyed had installed a vapor balance
system on their storage tanks to return vapors to the transports when
III-6
-------
gasoline was received. (This has often been referred to as Phase
I of a vapor recovery program). Only one plant has modified the
loading rack and the small delivery trucks to recover vapors
generated during the loading or unloading of gasoline of these
small trucks. (This would be Phase II of the vapor recovery program).
A detailed discussion of this vapor recovery installation appears
in Section IV.
Questions asked customers included:
1. the amount of gasoline sold to farm accounts
2. the size of tanks at farm accounts
3. the amount of gasoline sold to customers
with tanks of less than 2,000 gal. (7,800 1.)
capaci ty
4. the number of new tanks installed since
January 1, 1973
5. what vapor control techniques customers
have already installed.
As was stated earlier, Maryland had already asked bulk plants
about their annual sales to farm accounts and to customers with
tanks smaller than 2,000 gal. (7,800 1.). The data summary obtained
has been included as Table III-l. A histogram of the average daily
gasoline throughput to different types of accounts has been pre-
pared from this summary and is shown in Figure 5. Figure 6 is the
same type histogram prepared from responses made by bulk.pi ants
contacted by PES.
Based upon the Maryland data, a daily average of 4,400 gal.
(16,700 1.) are delivered to farm accounts and 1.18,000 gal.
(447,000 1.) to small tanks, leaving 73,000 gal, (276,000 1.) to be
delivered to other accounts, all of which will be treated here as
non-exempt accounts.
III-7
-------
Bulk plant operators stated tanks on farms are all small:
275 gal and 550 gal (1,000 1. and 2,100 1.) were the most common
sizes mentioned." No one spoke of a farm tank larger than 1,000 gal.
(3,800 1.). Therefore, in interpreting the two histograms, the left
one third of each graph is incorporated into the middle segment.
One of the first correlations attempted was comparing the through-
put to non-exempt accounts with the total bulk plant throughput.
In Figure 7, the total throughput of each bulk plant in Maryland
is plotted against its throughput to non-exempt accounts, The
histograms showed a substantial percentage of plants -- 65% in
the Maryland study, 74% in the PES survey --. dispensing less than
1,000 gal/day (3,800 I/day) to non-exempt accounts. This graph
shows' these plants have a wide range in total gasoline throughput
— up to nearly 12,000 gal/day (44,000 I/day). The clustering of
points underscores the fact that the traditional marketing emphasis
of a large number of bulk plants has been deliberately focused on
the use and servicing of small tanks. The larger throughput plants
may also make an effort to deliver gasoline to large accounts directly
from the terminal.
The 13 plants in Maryland delivering more than 1,000 gal/day
(3,800 I/day) to non-exempt accounts are less easily grouped. The
average total daily throughput ranges from 3,500 gal to 10,000 gal.
(13,000 1. to 39,000 1.) and the average daily throughput to non-
exempt accounts ranges from 1,000 to 4,300 gal. (3,800 to 16,000 1.).
The differences between the graphs in Figures 5 and 6 warrant
some discussion. There are really three sets of data, obtained
for three different years. It is very possible that businesses
have changed considerably in only a short time. The decrease in
throughput for Virginia bulk plants, discussed earlier, could cause
several changes in graphs of gasoline distribution. The PES data
do support the speculation put forth earlier that smaller bulk plants
selectively service customers with small tanks.
III-8
-------
The number of new tanks installed since January 1, 1973 is
not known with any degree of certainty. The majority of dealers
stated they had not installed any new tanks because of unfavorable
market conditions. One of the larger distributors stated he had
installed 40 new tanks, all of which were,to the best of his know-
ledge, in compliance with current Virginia State regulations. It
also appears that only about nine or ten large accounts with
existing tanks having a capacity of 2,000 gal (7,600 1.) or more
have installed submerged fill pipes and vapor return lines on their
tanks. Four of these accounts were definitely identified as ser-
vice stations.
2. Operational Changes in Bulk Plants
Within the past year seven bulk plants have been sold by
two major oil companies. With one exception, the commission
agent bought the plant he had been operating. Two purchase prices
disclosed were $65,000 and $45,000. The asking price for a plant
which was closed and partially dismantled about two years ago is
$60,000, according to a former competitor.
Extrapolating the data obtained by PES to all bulk plants
in the Baltimore/Washington, D.C. area, delivery volumes from
bulk plants have increased by 7%, while delivery volumes directly
from the terminal to the customer, by the bulk plant operator in
his own transport trailer, have increased by 123%. Increased sales
to non-exempt customers account for both increases. This now means
nearly half the gasoline now sold by bulk plants is transported
directly from the terminal to the customer and never passes through
the bulk plant. The implications of direct haul deliveries have been
discussed in Part A of this section. Operators often discussed the
possibility of transporting even more gasoline directly to the cust-
omers should they be required to spend substantial amounts of money
for vapor control equipment or other plant modifications which would
reduce the profitability of their operation. As stated earlier,
direct delivery of gasoline from the terminal to the customer is less
111-9
-------
expensive than transferring gasoline into storage tanks at the bulk
plant and then reloading it into smaller trucks for customer delivery.
3. Expected Operational Changes Related to Vapor Recovery
As stated earlier, only 10 of 28 plants surveyed had installed
a vapor balance system on their storage tanks to return vapors to
the transports when gasoline was received. Five plants have through-
puts low enough to be exempt from current Maryland and Virginia
State regulations. However, it is imperative to realize that all
these facilities are subject to Federal regulations.
In an attempt to assess the economic impact of the investment
in vapor recovery systems by bulk plants, the hypothetical question
was asked, based upon financial and cost data presented in Reference
1, "If a vapor recovery system were to cost you $10,000 ($20,00,
$30,000) initially and 20% of that for annual maintenance, would you
continue to sell gasoline?" Of the 20 who responded, 5 said they
would stop selling gasoline either altogether or they would not
dispense any through the bulk plant if an initial expense of $10,000
were required; 6 said they would take the same action if $20,000
were needed; 2 said $30,000 was the limit. The remainder are people
who just recently bought plants and some very large firms: they
intend to do whatever is necessary to succeed in their businesses.
It should be noted that a sufficient market for direct haul
sales exists for bulk plant operators to seriously consider elimina-
ting rack sales of gasoline rather than install vapor control equip-
ment. A small volume Of customers would most probably have to find
another bulk plant willing to deliver to him should his current
supplier elect to deal only in direct hauling from the terminal.
111-10
-------
C. BULK PLANTS IN THE HQUSTON/GALVESTON AREA
1. Description of Bulk Plants Surveyed
PES has compiled a list of the bulk plants in nine counties
within the Houston/Galveston AQCR which are affected by vapor
recovery regulations in Appendix A. The locations of these bulk
plants are shown in Figure 8.
Since there was no previous bulk plant inventory PES had to
locate all the bulk plants in the area of concern. A total of
sixty-five to seventy-four bulk plants were operating in the
area. The range is given because nine operations could not be found
or verified as bulk plants. Table II1-4 gives a summary of the
data obtained by PES through interviews with thirty-one bulk plant
operators. The summary includes data on gasoline throughput, type
and capacity of storage tanks, percentage of exempt accounts, type
of vapor recovery installed and number of account trucks,
The average gasoline throughput at the bulk plants was 8,350
gal/day (31,600 I/day). A histogram depicting the distribution of
gasoline through the bulk plants surveyed is shown in Figure 9.
Gasoline throughputs were found to range from 2,300 gal/day (8,600
I/day) to 21,600 gal/day (81,700 I/day). The total annual through-
put of gasoline for the bulk plants in the Houston/Galveston area
was approximately 152,000,000 gal/year (575,000,000 I/year).
According to the PES survey approximately 80% of the bulk
plants had aboveground tanks. The average aboveground storage
capacity was approximately 48,000 gal (182,000 1.) stored in three
t
to four storage tanks. Aboveground storage tank sizes ranged from
1,000 gal (3,800 1.) to 42,000 gal (159,000 1.) with most,tanks in
the range of 14,000 to 17,000 gal (53,000 to 64,000 1.). The
average storage capcity for bulk plants with underground tanks was
26,000 gal (98,000 1.) in two to three storage tanks. The size
ranges of underground storage tanks observed was 1,000 gal (3,800 1.)
III-ll
-------
to 18,000 gal (68,000 1.) and the average tank was 10,000 gal
(38,000 1.). In only one case did a bulk plant have storage
for gasoline above and below ground. One bulk plant operator
planned to change all his aboveground tanks to underground tanks.
He felt that this would eliminate spillage problems and ease the
installation of vapor recovery.
PES found that 75% of the bulk plants in the affected areas
had already installed Phase I vapor recovery for incoming loads
to the plant. In all cases this consisted of vapor balance systems.
In a majority of these plants, the vapor recovery was installed by
a major oil company since over 70% of all the bulk plants were
associated, either as a consignee or a distributor, with a major
oil company. This large percentage of vapor recovery installations
was a consequence of the original date for compliance with the
applicable regulations of January 1, 1977. The date for compliance
has now been delayed to May 31, 1977. This was announced in
Federal Register, 41_, 56642, December 29, 1976 .
Pumping rates were much lower than those found in the Mary-
land and Virginia areas. Pumping rates ranged from 40 gal/min to
180 gal/min (150 1/min to 680 1/min) with the majority of plants
having pumping rates less than 100 gal/min (380 1/min). The
average pumping rate for the plants surveyed was 75 gal/min (285 1/min)
The account trucks owned by the plant operators ranged in size from
1,000 to 4,000 gal (3,800 1. to 15,100 1.). The average bulk plant
surveyed had two account trucks. It was also found that 68% of
the bulk plant operators had installed vapor recovery on at least
one account truck. The equipment installed generally consisted of
a manifolded vapor return line, a permanent submerged fill pipe and
overfill protection.
The average percentage of exempt accounts — tanks less than
2,000 gal (7,600 1.) and farm accounts -- served by the bulk plants
in the Houston/Galveston area was 67%. Since these accounts were
111-12
-------
smaller than the non-exempt accounts, only about 50% of the
gasoline throughput was to the exempt accounts. In some cases
the bulk plant was used to service only exempt accounts with the
non-exempt accounts being serviced directly from the terminal,
bypassing the bulk plant. For example, one bulk plant operator
had a throughput of gasoline at his plant of 5,000 gal/day
(18,900 I/day) serving only exempt accounts. This operator then
delivered an additional 27,300 gal/day (103,300 I/day) directly
from the terminal to non-exempt accounts. Most of the non-exempt
accounts had installed only recovery for incoming loads, again,
because of the required date for compliance with Texas state gaso-
line vapor control regulations,
Over 90% of the bulk plants in the area incorporated top
loading for account trucks on their loading racks. There was
one plant that had both top and bottom loading, the top loading
for filling account trucks and the bottom loading for filling
large tanker trucks. Vapor recovery controls were installed on the
loading racks in 36% of the plants. The vapor recovery installation
consisted of vapor tight connections similar to those expected in
bottom loading vapor recovery installations. A more detailed
description of this vapor recovery installation can be found in
Section IV.
2. Operational Changes in Bulk Plants
Twelve bulk plants in the Houston/Galveston area have already
closed or are closing as of January 1, 1977. Two operators stated
they were closing specifically as a result of the cost of attempting
to comply with the vapor recovery regulations. One other plant
relocated operations to a county which was not affected by vapor
recovery regulations in order to avoid installing the necessary
equipment to control hydrocarbon emissions.
111-13
-------
REFINERY
TERMINAL
V
"T
I
i
.Y
BULK
PLANT
\/
LARGE VOLUME
ACCOUNTS
RETAIL
COMMERCIAL
AGRICULTURAL
-o
s
— "
V
SMALL VOLUME
ACCOUNTS
AGRICULTURAL
COMMERCIAL
RETAIL
CUSTOMER
PICK-UP
->- Typical delivery route of truck-trailer
-*- Typical delivery route of account truck
-*- Typical transaction with consumer coming to supplier
Fin.al Product Usage
Figure 1 APPLICABLE GASOLINE DISTRIBUTION NETWORK
-------
Figure 2. LOCATION AND NUMBER OF GASOLINE BULK PLANTS IN BALTI-
MORE AND NATIONAL CAPITAL AIR QUALITY CONTROL REGIONS
^
-..-• i , A C-— -/*>,. ;.,zv.. '»-o ffr^ >N*-*xjy-»
-: 4MT9^ i ' «V
•, . ..-7^-
'^^ :>^^f- . \,<'n.,^^c\,^-
^^'4?^v%fsfc^:'- Hj^C%r"--^^:
;^c ]£T$£ »^ -rr-.-^
Legend: O Location of Bulk Plants
5 Number of plants within a town
111-15
-------
Table HI-1
z, 2?
300,000
9(50,000
see zos*
3 04,3 707
V?o ooo
£>(, ceo
73V
zaz.
/ •SCO QC6
I -Sbl
Z 3CL, OOO
02 Z.
/fit
£ 71? 2*7
6 *V£
54^ 5-
000 .
7<>o ooa
5cV coo
Z. ses 4&z
._.. / 266 COO .
/ /3t ooo
Vi" OOO
/ 03i"« t-O
ceo
coo
/ (a '/$ Ooo
2. ocs oca
Source, Marj
|'53«!
. foo} ooo .
.-.../,(!, J"/,1?'/^
—. 200 336L
J' 000 !
' '77 3S7 . :...
./ 5"ao aoo
/i 9f V.
/ Oaa'
. 5S7
•VS1
2 OV6 -JIV3
/ V£4
OOO
/ao ooo
/3Z OOO
ooo
/ 5"o O c c o
/ <& ?« f 74 : . .
•36? Z/7 :
/ O6CJ OOO ...
and Bujreau of
_.75..
60
90.
67
(bo
/O.
<3o
. , VS".
/£»
2
2V
3r
. f
' so.:
2.0
ir ' Qua
ZlXXn
' ' A:
..:97..^._
! 9S ; ! j :]
/oo
._ , ^-:
/oo
/oo
s- .;;
• 1- 70 •;;
.—J-. 95". ..:...
aa
7 /
V!!.1 5- M:1
i /oo
95-..i.-.:
..,., */.:.:.
! • 7/ :..;;:
! • •
ity and Noise
3'
.*.
Z :
..£ .
:3 :
. z .:
3
Z .
2.
3
3 .
Z
3.-.
3
J
G ...
V
2.
- z.
: z.
• s-
. y
ohtrol
; l> 2
y 2
Q/2-»o<5
/Jlot/C
•4t>e \
;"£ictoi*j
c;/j/»i;c
2 X'AtVC * 3
SctawJ <5n.'HOC fi)
I . '
. ; -oi
z.
7
_ . £
/
. 2. .
3
.... Z. ..
Q
. .2 .
/
. . 3 .
/ '
/
3
. ./ .
2
IT
a
i
i
i.
i
i
3
i
2
1
Z.
3
3
y
z.
s~
•z.
fLIVCf.f f
/
1
. . 3 .
yr
y
3
... .'if
V
. a .
V
. . / ..
3
- 3 .
V .
4
5
V
cf
2
z.
3
f
<*
5"
Tr
/
«•
2
\=?
•*r
3
2.
V
T.
%, punr frf rztJLO
/OO
/O o :
/ce •
/co ;
/Co
/so :
05
/oo '
/oa i
/co :
/oo .
/CO
/ C. 0
. / -j o : . .
/c c° '
/so
-V
/C 0
XOO
/CO
/CO
/OO
/CO
/oc
/ 9O
y ..
/CJ
/<3
/<3O
/CO
/cc.
/£tf
/Cxi, . ,
/i'O
-------
Table IIU2
Virginia ARCR 7
BULK PETROLEUM PLANTS - CY 1972 (M GALS)
TPB Gasoline Distillate
Company0 'f Area Thruput
S66
866
866
866
866
555
865
866
866
655
866
866
342
453
656
1704
4925
235
1600
1680
2400
372
"420
1232
3000
600
232
5400
780
828
Stor. Thruput
34
25
15
34
30
40
20
40
37
25
20
19C
90°
30C
19C
932
292
744
744
105
2400
417
212
. 27
6192
u
400b
480
160
Stor.
44
55
45
45
40
40
30
90
32
87
b
30
. NA.C
M08
NA°
35
Notes
a - Submerged fill loading racks; others are splash fill.
b - Estimated.
c - Underground; others are above ground.
d - Exempt from control (under 26,000 gallons.)
e - None of these sources have the potential to emit 100 tons.
f - Company names deleted to protect confidentiality of information.
Source, Virginia State Air Pollution Control Board
SHEET 7
111-17
-------
Table III-3. BULK PLANTS IN BALTIMORE/WASHINGTON D.C, AREAS INTERVIEWED BY PES
PLANT
THROUGUPUT
Gal /Day
15,400
700
700
3,200
4,500
10,800
i,:oo
2,700
4,800
2,000
6,800
5,800
3,600
1,900
3,000
1,250
7,700
4,800
17,300
900
1,500
1,500
1,900
8,000
5,500
1,000
8,300
I/Day
58,000
2,600
2,600
12,000
17,000
41 ,000
6,000
10,000
18,000
7,500
26,000
22,000
14,000
7,300
11,000
4,700
29,000
18,000
66,000
3,300
5,500
5,800
7,300
30,000
21 ,000
3,900
32,000
RACK SAI FS
FARMS
%
0
75
0
75
?
25
95
3
75
?
15
75
75
78
65
10
5
30
?
80
25
85
70
5
50
75
50
SMALL TANKS
%
70
85
60
100
97
71
99
20
95
?
25
95
75
99
100
95
90
30
75
80
45
99
90
50
100
99
99
GASOL
TANKS,
Numberd
2U
2U, 2A
6U
3U
3U
3A
2U
4A
4A
'2U
3A
2A, 1U
3A
1U.3A
2U
3U
2A
2U
3U
1A.1U
2U.1A
2A.1U
2A
2A
3U
5A
3A
NE ' STORAGE
CAPACITY,
THOUSAND
Gal
40
41
34
22
34
61
30
80
80
24
5V
58
45
50 .
40
26
240
30
90
35
50
34
20
40
90
69
45
1
151
155
129
83
129
231
114
303
303
91
193
219
170
190
151
98
908
114
341
133
189
129
76
151
341
261
170
VAPOR .
RECOVERY0
+
—
_
_
+
_
—
+. !
_
_
_
+
_
—
+
+
_
+
•f
+ .
^
_
_
_
_
_
+
ACCOUNT
TRUCKSC
Number
2
3S
IS
IS
IS
5S
IS
2*
4S
1
5
1
IS
2S
IS
IS
4S
3S
IS
IS
1
2S
3S
1
2
4S
2S
I
_-J
00
Tanks less than 2,000 gal capacity (7600 1)
^Vapor recovery systems for control of incoming loads, + = yes, - = no; for control of outgoing loads, ! = yes
^All plants surveyed, except one marked with asterisk, used only top-loading account trucks. S: submerged filling
U = underground tanks; A = aboveground tanks
-------
Figure 3. AVERAGE DAILY GASOLINE THROUGHPUT DATA FROM STATES
OF MARYLAND AND VIRGINIA
20 -
15
Bulk Plants in Virginia area
CO
-------
Figure 4. AVERAGE DAILY GASOLINE THROUGHPUT PES SURVEY DATA FOR
MARYLAND AND VIRGINIA
CO
Q.
CQ
i.
01
5 10
2
8
4
15
6
23
8
30
10
38
12
45
14
53
16
61
18
61
20
76
lO^GPD
10 LPD
PO
o
"Gasoline Throughput
-------
Figure 5. AVERAGE DAILY GASOLINE THROUGHPUT TO DIFFERENT TYPES OF CUSTOMERS (DATA FROM
STATE OF MARYLAND SURVEY
20-
c
<•
OL.
CQ
i.
0)
10
Farm
Accounts
Accounts with Tanks
7800 1.
( 2000 gal
Non-exempt Accounts
-3
11
6
23.
3
11
6
23
9
34
3
11
6
23
10JGPD
103LPD
i
ro
Gasoline Throughput
-------
Figure 6. AVERAGE DAILY GASOLINE THROUGHPUT TO DIFFERENT TYPES OF CUSTOMERS (BULK PLANTS
INTERVIEWED BY PES)
-------
Figure 7. RELATIONSHIP BETWEEN TOTAL RACK THROUGHPUT Of GASOLINE AND VOLUME
DISTRIBUTED TO NON-EXEMPT ACCOUNTS (BASED ON DATA FROM STATE OF
MARYLAND SURVEY)
Non-exempt throughput >1000
o
u
o
I
c
o
Q.
2000
7600
o
O
Q.
CD
1000
-3800
o
Vt
(S
200
Non-exempt throughput <1000
760
2
8
•4
15
6
23
8
30
10
38
12
45
14
53
16
61
18 20
68 76
Total Gasoline Throughput
103 GPD
103 LPD
-------
Figure 8. LOCATION OF BULK PLANTS IN THE HOUSTON/GALVESTON AREA
I ^^•-r~\("W.anc£>'7 ft' "^^i?"'/-^ ,'^»"»». ^T-""-' » -
fe«$g£ V" ^^^? ^^fei^N/gfSS^
&^^^^'^^^ "^-%'5T;
^^U^MSr5 *$$&$ w^ S-. ?Mfe%-
^^'tPiP''If ^^ ^" r^5^WTA&"« ^^JS^H^W^r®™1^
^ i' aS^f^T^'fe"i
U9-J K^UcKKi.Wrfl* I
&:~TS^^w
, CvJtAU--isi.J
••'' -•'.ONT''^'1—
ga-1
-------
Table II1-4. SUMMARY OF DATA OBTAINED ON BULK PLANTS
IN HOUSTON/GALVESTON AREA
Plant Throughout
Gal /Day
3,200
5,700
18,200
9,100
7,600
11,400
11,400
11,400
9,100
6,400
6,800
4,500
7,400
9,100
3,200
4,500
2,300
8,300
11,400
3,200
3,400
5,000
3,000
L/Day
12,100
21,500
68,800
34,400
28,800
43,000
43,000
43,000
34,400
24,100
25,800
17,200
28,000
34,400
12,100
17,200
8,600
31 ,500
43,000
12,100
12,900
18,900
11,200
Exempt Accounts
Farm
%
60
60
10
20
-
40
40
50
5
70
25
50
25
1
2
5
-
33
10
50
80
25
80
Non-Farm
Tanks
%
40
40
90
10
-
20
40
40
85
29
40
30
65
20
2
0
-
-
80
48
20
75
20
Storage Tanks
Tanks
No.
.3Aa
3A
4A
3A
4A
3A
4A
5A
4A
3A
3A
3Uf
3U
3U
.2U
2U
2U
3A
3A
3A
2A
3A
2A
Capacity
Thousand
Gal
29
38
50
51
-
55
48
60
50
36
50
24
30
26
36
20
20
38
42
52
35
47
56
L
110
143
190
193
'-
208
182
227
190
136
190
91
114
98
136
76
76
143
159
197
132
178
212
Vapor
Recovery
Ic
I, IId, III
I, II, III
-
I, II, III
I, III
I, II, III
I, II, III
I, III
I, II, III
III
I, III
I, II, III
I
None
-
None
I, III
I
None
I, III
None
Account
Trucks
Number
3
2
2Se
3 S
2
2 S
2
3 S
2 S
2
3S
2
3
2 S
1
2
-
2
2
1
1
1
1
ro
-------
Table II1-4
(continued). SUMMARY OF DATA OBTAINED ON BULK PLANTS
IN HOUSTON/GALVESTON AREA
Plant Throughput
Sal/Day
•7,700
19,000
12,500
2,300
21 ,600
;4,500
:7,300
18,200
L/Oay
29,200
"71,900
i 47,300
, 8,600
; 81,700
17,200
27,500
: 68,800
Exempt Accounts
Farm ;
;.: %
5
;
,- 5
33 v
15
40
40
•'.
Non-Farm
Tanks
*•
15
-
30 ;
67
25
0
0
:
Storage Tanks
Tanks
No.
4A
- -•'••-••••
5A
3U, 6A
4A
4A.
3A
4A
Capacity
Thousand
Gal
63
-
70
17
53
52
36
56
L
238
-
265
64
201
197
136
212
Vapor
Recovery,
; i, in ;
i, ii, in
\_ i, ii, in
None
I, III
I, II
I, III
Account
Trucks
Number
2
• •• -
3 S
1
3
2
2
-
A - Aboveground tank
III = Vapor Recovery installed on at least one account truck
CI = Phase I Vapor control
il - Phase II Vapor control
s» = Submerged fill
f '
U = Underground tank
i
ro
-------
20,
Figure 9 AVERAGE DAILY GASOLINE THROUGHPUT
PES SURVEY DATA FOR HOUSTON/GALVESTON, TEXAS
15
to
-p
c
(O
S-
O)
JD
10
2
8
15
.
€
23
1
£
30
1C
38
12
45
V
52
16 1*
t 61 6£
2C
\ 76
[3
22 XIO^GPD
83 XI 0 LPD
Gasoline Throughput
-------
IV. HYDROCARBON EMISSIONS CONTROL AT BULK PLANTS
A. HYDROCARBON EMISSIONS CONTROL REGULATIONS
1. Maryland and Virginia Regulations
Copies of the sections of the State Implementation Plan and
state regulations which apply to bulk plant operations in the
Baltimore and Washington, D.C. areas are given in Appendix &.
Included in the Baltimore Intrastate AQCR are the counties
of Harford, Baltimore, Carroll, Howard, and Anne Arundel. The
National Capital Interstate AQCR includes Prince Georges and
Montgomery counties in Maryland and Alexandria, Fairfax, Loudoun
and Prince William counties in Virginia.
Federally approved State Implementation Plans for Maryland
and Virginia require gasoline transfer vapor control in the Balti-
more and National Capital AQCRs. In essence all facilities trans-
ferring gasoline from a delivery vessel into a stationary storage
container with a capacity greater than 250 gal (950 1.) are to pre-
vent release to the atmosphere of no less than 90% by weight of
organics in the displaced vapors. Then the vapor-laden delivery
vessel may be refilled only at facilities with an equally effective
vapor recovery system. The regulations do not apply to 1) stationary
containers having a capacity less than 550 gal (2,100 1.) used
exclusively for fueling implements of husbandry, 2) any container
having a capacity less than 2,000 gal (7,600 1.) installed prior
to the promulgation of the regulation, 3) transfers made to floating
roof storage tanks (or equivalent). Nor do they apply to any stationary
container at any facility in the affected areas of Maryland where the
monthly average throughput exceeds 20,000 gal (76,000 1,) and is sub-
ject to Maryland regulations 10.03.38.04J(2)(e) (1) and (2) and
10.03.39.04J(2)(e)(l) and (2). The date for final compliance in
both Maryland and in Virginia is May 31, 1977.
IV-1
-------
The aforementioned sections of Maryland State Regulations
require bulk plants having a monthly throughput of 20,000 to
50,000 gal (76,000 to 189,000 1.) to install a vapor balance or
similar system to recover vapors from loading into existing
stationary tanks of capacity less than 40,000 gal (.150,000 1.) by
May 31, 1977, However, these sections do not discuss the vapor laden
delivery vessel.
The commonwealth of Virginia "Regulations for the Control and
Abatement of Air Pollution" Section 4.52(e) also differs from the
Virginia SIP. A critical difference is in the phrase no gasoline shall
be transferred from any delivery vessel into any stationary storage
container with a capacity greater than 2,000 gal (7.600 1.) unless
it is equipped with a submerged fill pipe and a prescribed vapor
recovery system. Specific exemptions are granted to facilities
whose average monthly gasoline throughput is less than 20,000 gal
(76,000 1.) and all stationary storage containers used predominantly
for refueling mobile farm equipment, as well as transfers to floating
roof tanks (or equivalent).
2. Texas Regulations
The Texas SIP regulations are applicable to the following
counties in the Houston/Galveston area: Brazoria, Chambers, Fort
Bend, Galveston, Harris, Liberty, Matogorda, Montogomery and Waller.
These regulations require that by May 31, 1977 no gasoline shall be
transferred from a delivery vessel into any stationary container
with a capacity greater than 1,000 gal (3,800 1.) unless it is
equipped with a submerged fill pipe and the vapors displaced from
the storage tank during filling operations are processed by a system
that prevents the release of no less than 90 percent by weight of
the total hydrocarbon compounds. The vapor laden delivery vessel
can be refilled only at facilities having equally effective vapor
recovery systems. Exemptions to the Texas SIP regulations include
IV-2
-------
those for storage tanks used for the storage of gasoline on a farm
or for farming purposes, for storage tanks having a capacity less
than 2,000 gal (7,600 1.) installed prior to November 3, 1973, and
for storage tanks with floating roofs or equivalent.
The State of Texas Regulation V, which deals with hydrocarbons,
radically differs from the Texas SIP regulations in that it is appli-
cable only to Brazoria, Galveston, Harris, Matagorda and Montgomery
counties in the Houston/Galveston area. Regulation V also incorporates
an exemption for bulk plants that have a throughput of less than 20,000
gal (76,000 1.) per day. This would permit approximately 97% of the
plants in the area to not install vapor recovery equipment, Copies
of the Texas SIP and State of Texas regulations can be found in
Appendix C.
These several differences between Federally approved SIP Regu-
lations and separate State Regulations must be resolved before a
successful vapor control strategy can be implemented.
B. SOURCES OF EMISSIONS ASSOCIATED WITH HANDLING OF GASOLINE
Vapor can escape from storage tanks, even when there is no
transfer activity, because of changes in temperature of the tank
wall and stored materials which vary the pressure in the vapor
space. Variation forces vapor-laden air out of the tank and
aspirates fresh air into the vapor space, allowing further vapori-
zation of gasoline into that space. The amounts of vapor escaping
under these conditions are referred to as "breathing losses."
Losses of vapors due to liquid transfer are referred to as "working
losses" or'""transfer losses." The liquid transfer forces air-
hydrocarbon vapors out during filling of the tank and ingests air
(promoting evaporation) during draining. Miscellaneous or fugitive
losses are primarily related to spillage and leakage during gasoline
handling.
IV-3
-------
1- Breathing Losses
Factors affecting breathing or standing losses for fixed
roof tanks include the amount and volatility of the gasoline
stored, type and condition of tanks and appendages, and the pre-
vailing meteorological conditions, If there are no leaks or
direct openings, temperature fluctuation is the major cause of
breathing losses. As the temperature of the liquid rises, the
vapor pressure increases and evaporation takes place. The over-
all pressure in the gas space increases and when the vent pressure
set point is exceeded, a mixture of air and hydrocarbons is dis-
charged into the air. As the temperature decreases, gases partially
condense, contract, and fresh air is drawn into the vapor space.
This permits additional hydrocarbons to vaporize. Since hydro-
carbons are emitted, but generally not drawn back into the tanks,
a continued loss of hydrocarbon results from the daily changes in
ambient temperature.
2. Working Losses
The principal cause of vapor loss during liquid transfer is
displacement of the gas (air laden with hydrocarbon vapors) in the
vapor space by the liquid entering the tank. Other causes include
the entrainment of liquid droplets in the displaced gas and post-
withdrawal pressure increase caused by evaporation.
Certain operating conditions can increase or decrease these
vapor losses. Splash loading in which gasoline is dumped onto the
surface of the liquid causes turbulence which increases evaporation
rates and entrainment of droplets in the vapor being displaced.
A short interval between emptying and filling of storage tanks
can decrease losses by minimizing the time allowed for evaporation.
Also, storage tanks can be emptied in increments over a period of
several days or can be emptied in one operation prior to refilling,
with resultant differences in vapor loss.
IV-4
-------
Assuming no controls, each time a gasoline tank is filled,
the vapors above the liquid surface are emitted to the atmosphere.
The quantity of hydrocarbon vapors emitted is a function of the
volume displaced, type of loading, temperature and the degree of
saturation of the vapor space with gasoline vapors. At any given
temperature, the amount of vapor in the vapor space cannot exceed
a limit imposed by the saturation pressure corresponding to that
temperature. This limit, however, increases as the temperature
increases.
In a quiescent state, the approach to saturation and pressure
increase of a vapor space with gasoline vapors is a slow process.
Since hydrocarbon vapors are heavier than air and diffusion is
slow, a saturated blanket of vapor initially forms over the liquid
surface, decreasing the driving force for further vaporization. Also,
with evaporation of the lighter hydrocarbon molecules, the tendency
of the components in the stagnant surface to vaporize decreases.
Thus, the degree of saturation in the overall gas space of a tank
can be decreased by minimizing liquid surface and vapor space mixing
during the filling operation.
Splash loading not only creates liquid droplets which can be
entrained in the outgoing effluent and exposes fresh liquid surfaces,
but results in mixing of the vapor space as well. This mixing of the
vapors disturbs the saturated blanket near the liquid surface,
increasing the driving force for further vaporization. Hydrocarbon
emissions under splash filling conditions can significantly exceed
that calculated by assuming saturation C6).
Another factor which can affect the quantity of hydrocarbons
emitted is the interval between drainage and filling. When a tank
is drained and immediately refilled, the air drawn into the tank
during draining may be expelled with relatively little hydrocarbon
content. In a tank allowed to sit after draining, the air drawn
IV-5
-------
into the vapor space becomes saturated with hydrocarbons, thus,
increasing pressure Cand emissions) and resulting in the maximum
loss of vapor during refilling.
Another operational procedure which may increase losses is
the small sequential withdrawals of gasoline from a storage tank
over a period of several days rather than one continuous large
withdrawal. After a small withdrawal, the post-transfer emissions
caused by evaporation tend to be high in hydrocarbons since little
air is ingested during the withdrawal. After a large withdrawal,
the initial post transfer emissions are low in hydrocarbons since
large amounts of air are ingested during the withdrawal.
3. Miscellaneous Losses
Miscellaneous losses have been found to be highly variable.
These losses include spillage, liquid and vapor leakage and opera-
tional losses which occur when opening tank hatches for visual
inspection or measuring liquid levels with dip sticks. Leakage
can occur and has been observed at dry breaks, pressure vacuum
valves, hatches, manholes, pump seals, shut-off valves and piping
joints. It has been visually observed that some spillage (on the
order of half liter) occurs when connecting and disconnecting
transfer lines. Visible liquid leakage at dry breaks (few milli-
liters of gasoline) was observed from the connections after trans-
fer. Opening of hatches generally does not occur during transfer,
although several operators report they will open the hatches of
an empty truck to verify that they have received all the gasoline
expected,
IV-6
-------
C. EMISSION CONTROL TECHNOLOGY
1. 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 venting losses are to (1) inspect
and repair leaks in the tank and fittings, (2) paint the tank with
white paint where possible, (3) assure that vent valves do not leak
and (4) set the pressure and vacuum relief settings to minimize
breathing. The broader the band 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 con-
trol methods.
2. Working Losses
Excluding spillage, the 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 which results in in-
creased vaporization rates and liquid droplet entrainment in the
vapor space.
The most common current methods of reducing working losses are
to use submerged filling for the loading of gasoline and to install a
vapor balance system between the vapor spaces of the tanks connected
during the gasoline transfer.
IV-7
-------
a- Submerged Fill
Submerged fill is the introduction of liquid gasoline into
the tank being filled with the transfer line outlet being below
the liquid surface. This is compared to splash loading, where
the transfer line outlet is at the top of the tank. Submerged
filling minimizes droplet entrainment, added vaporization and
turbulence. If a fill port is located at the tank top, submerged
fill is accomplished by either extending the nozzle (commonly
referred to as stingers) or permanently attaching to the fill
port a pipe extending to within 6 inches (.15 cm) of the tank
bottom. This permanent installation is commonly referred to as
a drop tube.
Aboveground storage tanks normally include submerged fill.
Submerged fill for underground storage tanks can be accomplished
by attaching a pipe to the fill port. These installations are
common on underground tanks in surveyed areas.
Bottom loaded trucks by definition include submerged
filling. Top loaded trucks utilize an extension such as a pipe
or flexible hose facility loading arm. The extension may be
permanently attached if the loading arm can be raised sufficiently
to clear the trucks. No development is necessary except for
customer tanks. The major problem encountered, spitback from cus-
tomer tanks, can be overcome by inserting a long tube-like nozzle
(a stinger) through the filling pipe.
Submerged filling can reduce working losses to a significant
degree and is easily adapted to an underground storage tank, or top-
loading truck. As mentioned earlier, submerged fill is an integral
feature with bottom-loading trucks and aboveground tanks. The
system has no significant effect on breathing losses. Cost of
IV-8
-------
conversion is extremely low and applicability to bulk plant opera-
tions is good. In top-loading facilities a nozzle extension is
the only addition necessary to provide for subsurface loading of
the account trucks. For underground storage tanks, a pipe is
normally affixed inside so that the discharge occurs near the
bottom.
Submerged filling of customer tanks can be accomplished with
either nozzle extension or a permanently attached drop tube. Some
difficulties have occurred with the installation and use of per-
manent drop tubes. One problem is "spit back." "Spit back" is
the return flow and spillage of gasoline at the fill port during
transfer. This appears to be primarily related to the smaller fill
port and drop tube sizes in customer tanks, compared to service
station tanks, and the lack of a coupling at the fill port inter-
face. Use of a nozzle extension with or without a permanently
installed drop tube or a coupling should solve the "spit back"
problem.
Another difficulty with the use of submerged filling with
customer tanks is the variety of fill ports. Fill ports vary in
diameter, type and accessibility. The problem can be likened to
the variety of vehicle fuel tank interfaces. The total costs to
adapt to this number and variety of customer tank interfaces may
be significant. In addition, operators indicate submerged fill
hardware is not available for some configurations.
One question which arises is the actual usage of submerged
fill when the system is installed. For instance, if a top loading
rack or "drop tube" cannot be permanently attached, due to inade-
quate truck clearance, the driver has a little incentive to attach
the drop tube prior to each filling of the account truck.
Similarity a driver may not bother using a variety of detachable
"stingers" during the customer tank filling.
IV-9
-------
b. Balance System
Probably the most common vapor recovery system currently in
use is the vapor balance system. Efficiency is good for the
control of working losses, but not significant fn controlling
breathing losses. A pipeline between the vapor spaces of the
truck and storage tanks essentially creates a closed system per-
mitting the vapor spaces of the tank being filled and the tank
being emptied to balance with each other. The net effect of the
system is to transfer vapor displaced by liquid into the tank in
which draining of the liquid creates additional vapor space.
This prevents the compression and expansion of vapor spaces which
would otherwise occur in a filling operation. If a system is
leak tight, very little or no air is drawn into the system and
venting due to compression also is reduced substantially. The
system is applicable to underground and aboveground storage
facilities equipped with either bottom or top loading.
Typical facility modifications involved adding aboveground
piping from the incoming truck unloading area to a manifold inter-
connected with all gasoline storage tanks. The vapor return pip-
ing is generally 2 to 3 inches (5 to 8 cm) in nominal diameter
and it is sloped on horizontal runs to drain any condensate.
The no-lead tank may have special protection against contamination
from leaded gasoline vapors. Non-metallic piping may be used if
local codes allow.
IV-10
-------
The vapor return line entry into the storage tank may require
(1) attachment of a metal plate which can be drilled and tapped or
welded onto, (2) drilling and tapping or welding onto an existing
appendage, (3) using an existing port, or (4) teeing off an
existing vent line piping. The older the tank, the less likely
an existing port or vent line will be available for use. Older
riveted tank material may not be easily weldable,
The most common problem noted was leakage. Old tank hatches,
valves, seals, manholes and sealing surfaces may require significant
repair or replacement to affect a seal. In addition, even if only
a replacement component is required, the lack of spare parts for
discontinued models may require special orders further increasing
costs. If costs to an individual bulk plant owner begin approaching
the high end of the range of costs for this modification ($10,000),
the owner may investigate replacement and possible relocation of
storage tanks underground.
Instaflation of a balance system to the loading rack to return
vapors from the account truck to the storage tank has been compli-
cated in many instances by including a conversion of the loading
rack from top loading to bottom loading. There is no requirement
in the Federal vapor recovery regulations to include this particular
modification.
Top loading vapor recovery installations observed in the Houston/
Galveston area warrant special attention because of their simplicity,
apparent effectiveness and corresponding low cost: Because these
installations require minimal conversion of the top loading rack, the
total cost for the Phase I and Phase II vapor recovery installation
and the conversion of one account truck for submerged fill and vapor
recovery would cost approximately $10,000. This amount is considerably
less than costs quoted for bottom loading systems.
IV-11
-------
The Phase I vapor recovery system consisted of installing
vapor return piping to each storage tank handling gasoline and
a vapor return dry break coupler to prevent vapors escaping from
the system when the return line was not connected.
The Phase II vapor recovery piping to the loading rack branches
off the Phase I vapor return line and runs to the loading rack,
The piping to the loading rack is usually placed underground to
minimize problems with truck traffic. At the loading rack, a
flexible hose is attached to the vapor return line and then a dry
break or vapor tight fitting is affixed to the hose. Again, this
is to eliminate vapor losses to the atmosphere when the return
line is not connected.
The top loading rack is then modified to enable the vapor
tight delivery of gasoline to the account truck. The existing
fittings on the loading arm are removed and a vapor tight connector,
(0)
similar to the OPW Kamlockv ' fitting is attached, If the loading
arm is unable to move in both horizontal and vertical planes for
exact alignment with the compatible coupler on the account truck a
flexible hose is used for this purpose. One end of the hose is
attached to the loading arm and the coupler is attached to the other
end, thereby providing a flexible connection similar to that on the vapor
return hose.
The conversion of the account truck is the last segment of
the vapor recovery system installation. The modifications required
are performed on each compartment of the account truck. The vapor
return line installation involves welding a pipe into each compart-
ment and then joining all pipes together in a manifold (See Figure
10). This manifold line leads to a compatible fitting for the
flexible vapor return line at the loading rack, A hole is drilled
into each compartment and a submerged fill pipe is permanently
attached. To the top of this submerged fill pipe is attached the
compatible vapor tight connector for the top loading arm. A cap is
IV-12
-------
Permanent sub-
merged-fill pipe
Top loading arm
Compatible leak tight fittings
Liquid
level
indicator
Manifolded vapor
return line
Figure 10.
DIAGRAM OF LOADING RACK AND TRUCK
MODIFICATIONS TO RECOVER GASOLINE VAPORS
DURING DELIVERY TRUCK FILLING OPERATIONS
BEING INSTALLED IN HOUSTON/GALVESTON PLANTS
onnector for loading rack
flexible vapor return hose
-------
fixed over this connector when it Is not in use to eliminate the
leakage of vapors to the entrance of dirt or other impurities.
The last item to be installed in a compartment is the overfill
protection. At the plants visited a graduated rod with a float
at the base designed to rise with the level of the gasoline was
being used. Graduations of the rod could then be calibrated to
indicate the amount of gasoline in the compartment. This type of
overfill protection was critized by many of the bulk plant opera-
tors interviewed. They stated that the rod would often stick and give
inaccurate results. Many of them therefore had little confidence in
this type overfill protection system. Other than this complaint,
the bulk plant operators interviewed did not state any operational
problems.
If a conversion of the loading rack from top loading and bottom
loading is included in the total modification, it should be empha-
sized that the work is being done to modernize the facility and
speed up and simplify loading procedures, not because it is neces-
sary in order to provide a sufficiently effective vapor recovery
system. In Maryland and Virginia, only one plant has become involved
with this phase of vapor recovery. This particular facility elected
to convert to bottom loading mainly because they considered the
installation costs to be competitive and the system to be simpler
and safer to operate. The conversion, performed in 1974, required
complete dismantling of the loading rack and installation of meters,
valves, hoses, couplers, and accessory equipment for three product
lines.
IV-14
-------
D. EMISSIONS ESTIMATES
1. Baltimore and Washington, D.C. Areas
Both Maryland and Virginia have prepared estimates of hydro-
carbon emissions in the AQCRs of concern (3, 4, 5). Because the
years upon which these emissions inventories were based differ,
and the calculation techniques also differed, current gasoline
distribution throughout the two AQCRs will only be an estimate.
Comparisons will be based on extrapolating 1971 and 1972 data to
1975 using the total gasoline consumption in Maryland for 1971
g
and 1975: in 1971 1.3 x 10 gallons of gasoline were consumed in
the eight Maryland counties of interest; in 1975 1.5 x 109 gallons
were consumed? The difference between these two numbers will be
used as the overall growth rate, that is, 4.4% per year.
The table below summarizes the initial data provided on gaso-
line distribution.
^•v. Data
P^^-V« Source
1000 gal. ^^\.
(1000 1.) ^\^
Terminal
Bulk Plants
Service Stations
Maryland
1971
1,860,000
(7,040,000)
Included
with termi-
nals
1,390,000
(5,260,000)
D.C.
1971
102,000
(386,000)
0
(0)
237,000
(897,000)
Virginia
1972
1,220,000
(4,620,000)
24,800
(93,900)
449,000
(1,700,000)
Applying an annual growth rate of 4.4% to all these figures
•
indiscriminately will introduce some error: for example, it has
been stated earlier that bulk plant throughputs in Virginia have
declined substantially. Still, the comparison is useful. Table IV-1
therefore summarizes the PES estimate of how gasoline is distribu-
ted throughout these two AQCRs.
*In metric units, these volumes are 4.9 x 109 liters and 5.7 x 109
liters, respectively
IV-15
-------
Table IV-1. GASOLINE DISTRIBUTION IN BALTIMORE AND WASHINGTON, D.C.
AREAS: 1975 ESTIMATE
^•^ Area
Gasoline
Throughputs.
1 ,000 Gal ^N.
(1,0001.) \v^
Terfnl rials
Bulk Plants
Service Stations
Baltimore
AQCR
2,170,000
(8,210,000)
32,100
(122,000)
960,000
(3,630,000)
Montgomery &
Prince George's
Counties
0
(0)
8,800
(33,300)
690,000
(2,610,000)
District of
Columbia
122,000
(462,000)
0
(0)
282,000
(1,067,000)
Virginia
1,390,000
(5,260,000)
28,200
(107,000)
510,000
(1,930,000)
National
Capital AQCR
1,512,000
(5,724,000)
28,200
(107,000)
• 792,000
(3,000,000)
Emissions from gasoline storage and handling were reported by
counties for 1971 (4). They are summarized here for each AQCR.
Baltimore AQCR
National Capitol AQCR
15,300 tons/year
(13,900 metric tons/year)
15,000 tons/year
(13,600 metric tons/year)
The Maryland 1975 Emissions Inventory (5) indicates hydrocar-
bons emitted from gasoline storage and handling have decreased in
the Baltimore area to 11,200 ton/year (10,200 metric tons/year) and
in Montgomery and Prince George's counties from 5,200 tons/year
(4,700 metric tons/year) to 4,100 tons/year (3,700 metric tons/year.)
Using the changes in Baltimore area counties as typical of the
entire Washington, D.C. area the emissions there for 1975 are esti-
mated at 11,000 ton/year (10,000 metric tons/year).
The Virginia emissions report (3) estimated the specific con-
tribution of bulk plants to hydrocarbon emissions from gasoline
storage and handling. In 1972, bulk plants were calculated to contri-
bute 207 tons/year (188 metric tons/year). The Council of Govern-
ments in Washington, D.C. prepared their own inventory for 1973 in
which the Virginia bulk plants were considered responsible for 69%
of the emissions from all bulk plants in the AQCR, Thus, in 1972,
IV-16
-------
bulk plants in the National Capitol AQCR emitted 299 tons of hydro-
carbons (271 metric tons).
Because the PES survey of Virginia plants found their through-
put had decreased since 1972, their emissions will also have decreased.
For the purpose of comparing 1972 Virginia data with 1974 Maryland
data, PES is going to assume that 1974 Virginia bulk plant throughputs
remained at the levels tabulated for 1972,
As a result of recent revisions to emission factors for gasoline
marketing operations in "Compilation of Air Pollutant Emission Factors"
and a proportioning of these factors for use with bulk plant operations (2)_,
the 1972 emissions recalculated. Then estimates of current emissions and
future emissions, assuming various control strategies, can be made and
compared with past situations.
The following emissions factors were applied:
Fixed roof storage tanks; breathing loss
working loss
Floating roof storage
tanks;
Truck loading loss;
Miscellaneous
breathing loss
working loss
splash fill
submerged fill
balance system
(90& efficiency^
6.7 Ibs/day/tank
9.7 lbs/day/1000 gal,
.078 lbs/day/1000 gal.
storage
,023 lb/1000 gal. through-
put
14.0 lb/1000 gal throughput
5.8 lb/1000 gal throughput
.96 lb/1000 gal throughput
3.2 lb/1000 gal throughput
IV-17
-------
The Commonwealth of Virginia used the following data to
calculate hydrocarbon emissions for 1972:
Gasoline storage 320,000 gallons (1,210,000 liters)
Number of aboveground
fixed roof storage
tanks (PES estimate) 22
Working losses based on 18,168,000 gal/yr (68,770,000 1/yr)
Splash loaded gasoline 13,113,000 gal/yr (49,640,000 1/yr)
Submerged fill loaded
gasoline 12,295,000 gal/yr (46,540,000 1/yr)
Emissions from bulk plants in the Virginia portion of the
National Capital AQCR for 1972 are classified as follows:
Gasoline storage 26.9 tons (24.4 metric tons)
Distillate storage 2.9 (2.6)
Gasoline Handling 215,6 (195.5)
Distillate Handling 8.1 (7.3)
Miscellaneous 41.0 (37.2.)
294.5 tons (267.0 metric tons)
Emissions from bulk plants in the several Maryland counties of
interest were calculated using the following data obtained for 1974:
Number of aboveground fixed roof tanks 49
Gasoline storage in floating roof tanks 240,000 gal.
(908,000 1.)
Working losses based on 39,190,000 gal/yr
. , nu T (148,300,000 1/yr
Throughput at plants with Phase I
vapor recovery 1,100,000 gal/yr.
(4 290,000 1/yr)
Splash loaded gasoline (PES estimate) is!39o!o00 gal/yr
(69,610,000 1/yr)
Submerged fill loaded gasoline 20,800,000 gal/yr
(PES estimate) (78,740,000 1/yr)
IV-18
-------
Emissions from bulk plants in Maryland for 1974 are
classified as follows:
Gasoline storage
Gasoline handling
Miscellaneous
Distillate storage j
Distillate handling'
63.3 tons
374.3
62.7
15 est.
515 tons
57.4 metric tons
339.5
56.9
14 est.
468 metric tons
In order to estimate what portion of these bulk plant
emissions occur around Baltimore, PES intends to assume that the
number of plants near Baltimore is directly related to their con-
tribution of hydrocarbons. Thus 34/43 of the 515 tons/year or 407 tons/
year (369 metric tons/year) are emitted by bulk plants in the Baltimore AQCR.
Likewise, 9/43 of the 515 tons/year plus 295 tons/year from Virginia
bulk plants or 403 tons/year (366 metric tonsVyear) are emitted by bulk
plants in the National Capital AQCR.
The results of this plant survey also provide sufficient
data to estimate current emissions. The one assumption which must
be used is that the sample is a representative proportion of the
whole. Data needed for calculating emissions are summarized below:
Number of Operating Bulk
Plants
Number Surveyed
Number of aboveground fixed
roof storage tanks at
visited plants
Gasoline storage in floating
roof tanks
Working losses based on through-
put
Throughput at plants with
Phase I vapor recovery
Splash loaded gasoline
Affected Counties in
Virginia
13
8
15
11,380,000 gal/yr
(43,100,000 1/yr)
8,140,000 gal/yr
(30,800,000 1/yr)
8,000 gal/day
(30,000 I/day)
Submerged fill loaded gasoline 35,800 gal/day
(136,000 I/day)
Affected Counties in
Maryland
43
20
27
240,000 gal
(908,000 1.)
21,600,000 gal/yr
(81,800,000 1/yr)
8,460,000 gal/yr
(32,000,000 1/yr)
37,500 gal/day
(142,000 I/day
45,700 gal/day
(173,000 I/day)
IV-19
-------
Emissions from these 28 bulk plants surveyed can be categorized as
follows:
Virginia Maryland
Gasoline storage 18.3 tons/yr 33.0 tons/yr
Gasoline handling 70.0 170.5
Miscellaneous 18.2 34.6
106,5 tons/yr 238.1 tons/year
Applying a ratio of the number of operating plants to the
number of plants surveyed,present emissions can be estimated as
follows:
Virginia Maryland
Gasoline storage 29.7 tons/yr 72.9 tons/yr
Gasoline handling 113.8 376.9
Miscellaneous 29.7 76.5
Distillate storage
and Handling (Est.) 11 15
184 tons/yr 541 tons/yr
Proportioning the Maryland emissions between the Baltimore
and Washington, D.C. areas directly in accordance with the number
of plants -- 34 near Baltimore, 9 near Washington, D.C. — current
bulk plant emissions are estimated to be:
•Baltimore AQCR 428 tons/year (388 metric tons/yr)
National Capital AQCR 297 tons/year (270 metric tons/yr)
The decrease in throughputs in Virginia bulk plants from the time
of the Virginia state survey to the time of the PES survey is
responsible for the difference between the two emission estimates
These emission estimates do not include area wide emissions
produced by filling of the customer's tanks. This survey
IV-2Q
-------
found 74% of gasoline being delivered to tanks of less than 7,600 1.
(2,000 gal) capacity. Presently these tanks do not have to have
any vapor control device, even a submerged fill pipe. The table
below shows the current estimated emissions from filling customer
tanks assuming small tanks have uncontrolled splash filling and the
larger tanks have submerged filling capability.
Annual throughput using
splash fill
Annual throughput using
submerged fill
Emissions from splash filling
Emissions from submerged
filling
Total emissions in area from
customer delivery
Affected Maryland
Counties
27,220,000 gal
(103,000,000 1.)
9,560,000 gal
(36,190,000 1.)
191 tons/year
(174 metric tons/^
28 tons/yr
(25 metric tons/yr)
219 tons/year
(199 metric tons/yr)
Affected Virginia
Counties
20,900,000 gal
79,110,000 1.)
7;340,000 gal
(27,780,000 1.)
146 tons/year
(132 metric
21 tons/yr
(19 metric tons/yr)
167 tons/year
(151 metric tons/yr)
At this time there is not sufficient data to estimate the breathing
losses of customer tanks. Also, there is no current requirements to
attempt to control this emission source.
The estimates of 428 tons hydrocarbons year from bulk plants
and 276 tons/year from filling consumers' tanks in the Baltimore
area and 297 tons hydrocarbon/year from bulk plants and 110 tons/year
from filling consumers' tanks in the Washington, D.C. area will be
used in further estimates of how much reduction in emissions is
possible with various control strategies.
Current Maryland and Virginia state regulations* exempt bulk plants
having an average monthly throughput of less than 20,000 gal (76,000
K-) from all vapor control requirements. A total of four plants
with a combined monthly throughput of 63,000 gal (2, 400, 000 1.) would
be involved. Thus, if these regulations were enforced emissions
would decrease to the following amounts:
*See appendix B
IV-21
-------
AQCR
Emissions
Baltimore
Tons/yr (kkg/yr)
National Capital
Tons/yr (kkg/yr)
Gasoline storage
Gasoline handling
Miscellaneous
Distillate handling and
storage (estimate)
Total
57,6 (52.2)
38,0 (34.5)
60.5 (54.9)
14 (13)
170 (154)
45.0 (40.8)
29.1 (26.4)
45.7 (41.4)
12 (11)
132 020)
As a result of using vapor balance systems to recover 90% of the
hydrocarbons emitted miscellaneous losses would also decrease, but
at this point no means of preparing a reasonable estimate appears
to be available. Thus, by allowing the states to retain present
requirements, emissions would be reduced in the Baltimore AQCR by
at least 258 tons/year (234 metric tons/year) and in the National
Capital AQCR, by at least 165 tons/year (150 metric tons/year).
Enforcement of the Federally approved SIP regulations would
result in the four previously mentioned plants also having to install
vapor recovery systems on their facilities. Emissions from gasoline
handling would be reduced by 2.5 tons/yr (2.3 kkg/yr) in the Baltimore
area and by 1.8 tons/year (1.6 kkg/yr) in the Washington D.C. area.
As more plants install the appropriate vapor recovery control
systems, the reduction in hydrocarbon emissions will, of course, be
more noticeable. Table IV-2 provides a comparison of how the various
size bulk plants affect hydrocarbon emissions in the two AQCRs. In
calculating these estimates plants with vapor recovery already in-
stalled have been assumed to keep the system operating at a 90%
efficiency level and all exempt plants have at least submerged
filling of their trucks.
IV-22
-------
Table IV-2. HYDROCARBON EMISSIONS FROM BULK PLANTS RELATED TO
NUMBER OF BULK PLANTS WITH VAPOR CONTROL
Type of plant complying with
vapor recovery regulations
(facility throughput)
.All
>20,000 gal/mo (76,000 1/mo)
>20,000 gal/day (7,600 I/day]
>-4,000 gal /day (15,000 I/day)
>:6,000 gal /day (.23,000 I/day)
>8,000 gal/day (30,000 I/day)
>JO,000 gal/day (38,000 I/day)
£1,000 gal/day (3,800 I/day] to
non-exempt customers
>2,000 gal/day (7,600 I/day) to
non-exempt customers
Area wide
tons/year (metric tons/year)
Baltimore
168(152)
170(154)
192 (174)
213 (193)
244 (221)
287 (260)
287 (260)
267 (242)'
267 (242)
National Capital
,130(118)
'132 (120)
154 U4-Q)
159 (144)
167 (151)
209 (190)
209 (190)
169 (153)
169 (153)
If all customers with tanks of less than 2,000 tal (7,800 1.)
capacity were required to install submerged fill tube and all cus-
tomers with larger tanks, to install vapor balance systems, the area
wide hydrocarbon emissions resulting from customer deliveries would
decrease to 84 tons/year (76 metric tons/year) in the Baltimore AQCR
and to 65 tons/year (59 metric tons/year) in the National Capital
AQCR.
In summary, if the current Federally approved SIP control strategy,
which is also the strictest, is stringently applied, the emissions gene-
rated by bulk plant operations would be as shown below:
Emission
Source
AQCR
Baltimore
tons/year (metric tons/yr)
National Capital
tons/year (metric tons/yr.)
Operations at bulk
plants physical
location
Deliveries to cus-
tomers over entire
area
Total hydrocarbon
emissions
168 (152)
84 (76)
252 (228)
130 (118)
65 (59)
195 (177)
IV-23
-------
2. jjQMtpn/Galveston, Texas Area
Emission estimates for the bulk plants in the Houston/
Galveston area have been calculated for uncontrolled sources, for
emissions from bulk plants with current vapor recovery controls,
and emissions from bulk plants with potential control under the
existing Texas SIP regulations. For estimating uncontrolled
emissions, it was assumed that no vapor recovery equipment was
installed and that all tank fillings and transfers to account
trucks were by splash filling. This would amount to the worst
case emissions. For the purposes of these calculations, the
average annual throughput of gasoline through each bulk plant
was 2,203,000 gal (8,338,000 1.], based upon the PES bulk plant
sample. Also for the purposes of these calculations, seventy
bulk plants were assumed to be operating in the area. This
number was arrived at by including five of the nine unvarified
plants and deleting four operations which PES believes are not
operating bulk plants.
The uncontrolled emissions from the bulk plants in the
Houston/Galveston area are:
Breathing losses from aboveground tanks -
236 tons/year (214 metric tons/year)
Working losses from all bulk plant storage tanks -
737 tons/year (668 metric tons/year)
Transfer losses from filling account trucks -
1063 tons/year (964 metric tons/year)
Transfer losses from filling account's storage tanks -
1063 tons/year (964 metric tons/year)
Miscellaneous losses -
243 tons/year (220 metric tons/year)
Total uncontrolled hydrocarbon emissions -
3342 tons/year (3031 metric tons/year)
IV-24
-------
The emission factors used for these emission estimates are the
same as those listed in the previous section on Baltimore and
National Capital regions.
The total projected hydrocarbon emissions for the Houston/
Galveston area (11) for 1977, base year 1971, are 314,853 tons/
year (285,572 metric tons/year). The projected hydrocarbon
emissions from gasoline marketing sources are 20,803 tons/year
(18,868 metric tons/year). This indicates that 6.6% of the total
hydrocarbon emissions originate from gasoline marketing sources
and based upon PES estimates, 16.1% of the gasoline marketing
emissions originate from bulk plants.
The total amount of gasoline consumed in the nine affected
counties amounted to approximately 2.8 billion gallons (10.6
billion liters) in 1976. This information was derived from fuel
tax records and information on vehicle population in the nine
counties (12). The total amount of gasoline which passed through
the bulk plants was approximately 154 million gallons (583'million
liters) or about 5.5% of the total gasoline consumed,
To determine current emissions from bulk plants, data on
Phase I and Phase II controls installed were obtained from the
PES bulk plant survey. From this data, it was found that 75%
of all the bulk plants had installed Phase I vapor recovery.
Phase II controls were installed at 36% of all the bulk plants.
Vapor recovery had been installed on at least one truck at 68%
of the facilities. For calculation purposes, it was assumed,
since most bulk plants had one truck with vapor recovery and one
without, that the deliveries which went to exempt accounts, i.e.,
farm accounts and tanks less than 2,000 gal (7.6QQ 1,), were made
with the delivery truck which had no vapor recovery. From the
PES survey, the average bulk plant delivered 50% of its gasoline
— 67% of its accounts -- to exempt accounts. An efficiency of
90% for the Phase I and Phase II controls was used.
IV-25
-------
The hydrocarbon emission estimates for the bulk plants
in the Houston/Galveston area incorporating current vapor recovery
control installations are:
Breathing losses from aboveground tanks -
236 tons/year (214 metric tons/year)
Working losses from all bulk plant storage tanks -
239 tons/year C217 metric tons/year)
Transfer losses from filling account trucks -
791 tons/year (718 metric tons/year)
Transfer losses from filling account's storage tanks -
638 tons/year (579 metric tons/year)
Miscellaneous losses -
243 tons/year (220 metric tons/year)
Total hydrocarbon emissions incorporating current control
practices -
2148 tons/year (1948 metric tons/year)
Under current control practices, a 67.5% reduction in working losses,
a 25.6% reduction in transfer losses involving account trucks and a
40% reduction in transfer losses involving account tanks served have
been accomplished. This is an overall hydrocarbon emission reduction
of 35.7% representing 1,194 tons/year (1,083 metric tons/year) from
all bulk plant emission sources.
To determine the amount of potential reduction of the hydro-
carbon emissions, the vapor recovery and emission controls as
outlined in the Texas SIP regulations were extrapolated for the
gasoline throughput used above. This would mean that Phase I con-
trols would be installed on all bulk plants, Phase II controls on
the racks would be used on all non-exempt deliveries and submerged
fill pipes would be installed on all non-exempt tanks. The SIP
regulations, as written, do not require any controls to limit
storage tank breating losses and miscellaneous losses (i.e.,
spillage) so these emissions levels do not vary.
IV-26
-------
The hydrocarbon emission estimates for the bulk plants in
the Houston/Galveston area incorporating potential vapor recovery
controls are:
Breathing losses from aboveground tanks -
236 tons/year (214 metric tons/year)
Working losses from all bulk plant storage tanks -
74 tons/year (67 metric tons/year)
Transfer losses from filling account trucks -
585 tons/year (530 metric tons/year)
Transfer losses from filling account's storage tanks -
585 tons/year (530 metric tons/year)
Miscellaneous losses -
243 tons/year (220 metric tons/year)
Total hydrocarbon emissions incorporating potential
emission controls under Texas SIP regulations -
1723 tons/year (1562 metric tons/year)
Under potential control strategies presented in the Texas SIP
regulations, a 90% reduction in hydrocarbon working losses from
bulk plant storage tanks and a 45% reduction of transfer losses
to both account trucks and account tankage could be experienced.
This would yield an overall bulk plant emissions reduction of
48.5% or 1620 tons/year (1469 metric tons/year). If it is assumed
that all deliveries made from the bulk plant would require Phase
II controls, not just non-exempt deliveries, a further reduction
in bulk plant emissions would occur. The overall bulk plant hydro-
carbon emissions would then be reduced to 1244 tons/year (1128
metric tons/year). This would then indicate an overall emissions
reduction of 63% or 2098 tons/year (1903 metric tons/year).
The effects of various selected increments of compliance with
vapor recovery regulations on the hydrocarbon emissions from bulk
plants in the Houston/Galveston area are summarized in Table IV-3. The
current Texas SIP regulations have exemptions relating to deliveries
to farm accounts and tanks of less than 2,000 gal. capacity (7,600 1.)
IV-27
-------
Table IV-3. SUMMARY OF DECREASE IN EMISSIONS FROM BULK PLANTS IN HOUSTON/GALVESTON AREA AS FACILITIES
COMPLY WITH HYDROCARBON VAPOR RECOVERY REGULATIONS
Facility Description
Vapor recovery on all bulk
plant operations and account
tanks
Total compliance with current,
approved SIP Regulations.
Total Gasoline Throughput
>20,000 Gal/Mo.
Total Gasoline Throughput
>4,000 Gal/Day
Throughput to Non-Exempt
Accounts >2,000 Gal /Day
Throughput to Non-Exempt
Accounts >2,000 Gal /Day or
Total Gasoline Throughput
>4,000 Gal/Day
Total Gasoline Throughput
>8,000 Gal/Day
Total Gasoline Throughput
>8,000 Gal/Day or Throughput
to Non-Exempt Accounts >2,000
Gal /Day
Total Gasoline Throughput
> 12, 000 Gal /Day
Total Gasoline Throughput
>12,000 Gal/Day or Throughput
to Non- Exempt Accounts
>2,000 Gal/Day
Total Gasoline Throughput
>20,000 Gal/Dayd
No Plants in Compliance
of
Plants
Affprtprf
n t t ci> Leu
70
70
70
54
36
34
29
20
11
9
2
0
EMISSION ESTIMATE
TOTAL
T/Yrb
765
1723
1723
2095
2499
2566
2678
2872
3084
3132
3294
3342
MT/Yrc
' 693
1563
1563
1900
2266
2326
2428
2604
2796
2840
2986
3030
Breathing
Losses
From Above
Ground Tanks
T/Yr
236
236
236
236
236
236
236
236
236
236
236
236
MT/Yr
-214
214
214
214
214
214
214
214
214
214
214
214
Working
Losses from
All Storage
Tanks
T/Yr
74
74
74
226
392
419
465
545
631
651
717
737
MT/Yr
67
67
67
206
356
380
422
494
572
590
650
668
Transfer Losses To
Account Trucks
T/Yr
106
585 a
585
695
814
834
867
924
987
1001
1049
1063
MT/yr
96
531
531
630
738
756
786
838
895
908
951
964
Account Tanks
T/Yr
106
585
585
695
814
834
867
924
987
1001
1049
1063
MT/yr
96
531
531
630
738
756
786
838
895
908
951
964
Miscellaneous
Losses
T/Yr
243
243
243
243
243
243
243
243
243
243
243
243
MT/Yr
220
220
220
220
220
220
220
220
220
220
220
220
alt is assumed that deliveries to exempt accounts are done with trucks without vapor recovery
£ bT/Yr = Tons/Years
cMT/Yr = Metric Tons/Year
CO
dCurrent Texas State Regulation V incorporates this exemption
-------
Over 70% of the bulk plants have already installed Phase I vapor
control systems and over 30% have installed Phase II control systems
in order to comply with these regulations.
E. DIRECT COSTS OF EMISSION CONTROL SYSTEMS
Initial costs of hydrocarbon control systems are reviewed in
the sequential order in which gasoline is received and then trans-
ferred from bulk plants: incoming transfer, storage, outgoing
transfer and operating and maintenance costs,
1. Modification of Incoming Transports
Because a gasoline transport may be owned by a major oil
company or a common carrier or it could be used to deliver other
highly volatile organic materials the cost of installing gasoline
vapor recovery equipment on a transport can not be considered a
necessary portion of a bulk plants direct expense,
Cost estimates for installing vapor recovery and bottom
loading on a supply transport have been obtained for general
information. They range from $1000 to $1800 per compartment, with
the total cost depending on the truck configuration. The most
common truck design has three or four compartments, and the average
conversion price per compartment is $1200, so the total cost is
$3600 to $4800. The most expensive conversion cost quoted by any
operator was $8000.
Trucks originally designed for top loading are generally being
modified to provide for bottom loading and vapor recovery at the
same time. Bottom loading of transports is frequently cited as
necessary in order to be compatible with loading facilities at the
particular terminal supplying the bulk plant. However, a terminal
may also supply bulk plants located outside the affected AQCRs, so
that some terminals have maintained top loading facilities with vapor
recovery capability.
IV-29
-------
2. Submerged Fill Installation
A common requirement for filling storage tanks is that the
discharge opening be within 6 in (.15 cm] of the tank bottom.
Underground tanks therefore need to be equipped with a submerged
fill pipe or drop tube such as OPW 61-T. The cost of this hard-
ware is minimal and installation is quite simple.
3. Balance System Installation Costs
The balance system is the most common method of controlling
emissions from filling and emptying storage tanks. The table below
summarizes the initial cost data obtained for installations in
Baltimore/Washington, D.C. and Houston/Galveston.
Initial Cost of Vapor Balance System at Bulk Plant
for Incoming Loads
Area
Baltimore/Washington
Houston/Galveston
Type of installation
Aboveground tanks
Underground tanks
Operator installed
Contractor installed
Initial cost includes hardware and installation. Typical hardware
for aboveground tanks includes piping, fittings, supports, pressure-
vacuum (PV) valves, liquid traps, paint, disconnects, seals and
gaskets. Typical installation work includes draining the tank,
assembling piping and supports, breaking into existing tank top
or vent, painting, leak testing, replacing PV valve, replacing
seals and occasionally repairing leaks by welding tanks or covers.
Miscellaneous costs include permit fees, inspection, insurance,
Number of
Contacts
17
5
Low
.8
.6
Costs ($1000)
Average High
3.6 10
2.9
5
17
4
5
3
.6
1.5
.6
1.3
3.6
2.7
1.5
4.0
10
3.6
3.5
10
IV-30
-------
temporary barricades and cleanup. Costs listed do not include
facility down-time, contract negotiation time, design and drafting,
and time to obtain financing.
If underground tanks require only a coaxial fitting such as
Emco Wheaton F-298, a typical installed cost is $600. A small
diameter fill port, side fill, PV vent requirements, leaks,
concrete work and overfill protection can raise the cost signi-
ficantly. However, the cost of installing a balance system on an
underground tank is generally lower than the installation on an
aboveground tank.
In about 30% of the cases studied, the operators performed
the installations. Although some direct labor costs were included
in the estimate, costs generally represent only hardware costs.
These installation costs will not be included in the average cost
of a control system for incoming loads because of: (1) general
lack of associated labor costs, (2) discrimination against those
not able to install by themselves.
If a typical bulk plant with aboveground storage tanks is
used as a base, the average and range of costs derived from major
oil companies, contractors and operators is fairly consistent with
the average cost being about $3000. The overall range was $600
to $7000.
Very detailed data on Phase I vapor recovery costs were
obtained from a representative of an independent oil company which
presently operates seven bulk plants within the Baltimore and
National Capital AQCRs. Equipping their transports with vapor
recovery has averaged $3500/truck. Installing a balance system
to comply with Phase I has cost between $1300 and $7000. The
highest cost resulted from having to run piping an unusually long
distance to connect all storage tanks.
IV-3T
-------
The technique this company is using to equip storage tanks
with vapor recovery devices is quite interesting. All modifica-
tions are being installed in the manhole covers of aboveground
tanks. Essentially a ball vent valve (Universal Valve Co. #37,
with a three inch float) a combination vent gauge hatch (McDonald
925-U) are installed in the manhole cover, then a tight seal
coupler is attached to the ball vent valve line. This then pro-
vides a means of manifolding together however many tanks are
needed.
4. Outgoing Gasoline Transfer Control Costs
Data from both this study and previous work (1) indicate a
significant difference in the cost of Installing a top loading
vapor recovery system compared with a bottom loading vapor recovery
system. The industry has generally emphasized the conversion of
top loading racks to bottom loading racks. This has resulted in
the reporting of costs which are biased toward the more expensive
system.
In conducting this study, over a third of the facilities
visited in the Houston/Galveston area were found to have installed
a top loading vapor balance system on their loading racks and
smaller delivery trucks. (The details of this system have been
given in Section III), Four major oil companies who have used this
approach provided reasonably detailed cost data: 1) modifying
the loading rack—necessary piping, fittings and hoses—will cost
approximately $3000 to $5000; 2) adapting the account trucks-
submerged fill tubes, fittings and overfill protection—will cost
between $2000 and $4000. Therefore, for the installation of
Phase I and Phase II vapor recovery at the bulk plant and the modi-
fication of one account truck, the total cost to the bulk plant
would be between $8000 and $12000.
Only one East Coast firm interviewed had obtained a bid
(of $13000) for a top loading Phase II vapor recovery installations.
IV-32
-------
Because top loading vapor recovery appears to be a less expensive
means of controlling hydrocarbon vapors from bulk plant outgoing
transfer operations and because cost data are sparse, an in-depth
study of installation costs, system design and efficiency appears
warranted.
With regard to bottom loading vapor recovery systems, only
one plant in the Baltimore AQCR had installed this equipment.
In 1974 this plant totally replaced its loading rack. The equip-
ment cost then was $12000 and the labor cost was $9000. Allowing
for an annual cost increase of 10%, this same installation would
probably now cost about $28000. The only other bulk plant in the
Baltimore area which had considered a similar installation had
received a bid of $24000, The difficulty in interpreting this
quote, and most others for bottom loading system, is establishing
how much was spent in modernizing the facility and how much was
spent in order to comply with vapor control regulations.
Very little more was learned about the possibility of con-
verting from top loading to bottom loading. If the conversion
can be accomplished by removing the loading arms at the level of
the rack and replacing them with flexible connecting hoses, the
cost would be between $8,000 and $14,000, depending upon the
need for new meters, electrical controls, etc, A completely
new loading rack for three grades of gasoline was estimated at
$19,000.
IV-33
-------
5. Modification of Account Trucks
As mentioned above, oil companies in Texas who have used
an approach of installing vapor tight connections on top loading
account trucks have spent $2,000 to $4,000 per truck.
Those few operators who planned to continue top loading
with such vapor recovery systems as OPW V-63-F estimated instal-
ling vapor recovery on their account trucks would average $2,500
per truck.
Operators who converted their small trucks to bottom loading
and installed vapor recovery spent from $3,000 to $6,000, depending
upon the existing design of the truck.
6. Cost of Vapor Recovery Equipment on Customer Tanks
The first problem encountered is that of who is responsible
for any modifications which may be needed -- the supplier or the user.
At this time, it seems to depend totally on the individual opera--
tor's business judgment. The costs are generally $200 to $600 per
tank, so for a bulk plant servicing say 50 non-exempt tanks, the
total cost would be quite substantial. On the other hand, a user
would probably not have more than three non-exempt tanks, which
would involve a maximum expenditure of about $2,000.
7. 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 small. Transfer hoses and mating fittings will
require replacement. Installation of automatic controls for loading
and unloading of gasoline may impose additional maintenance require-
ments. No direct information on operating costs was available,
Based upon 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:
IV-34
-------
Percent of initial system cost
Interest (8 years at 10%) 6,2
Depreciation 12.5
Property taxes 2.5
Maintenance 3.0
24.2
Thus, if a bulk plant installs a vapor recovery system for an
initial cost of $10,000 the operator may expect to spend nearly
$2,500 a year to operate and properly maintain the equipment.
Any increase in facility value should increase assessments,
thereby increasing taxes. The amount will vary with tax rates
and assessments.
Possible increases in insurance rates due to vapor balancing
have not been resolved. To date, insurance companies have not
indicated a change in rate due to any change in risk category.
Although information on these miscellaneous costs is limited,
it appears that; (1) operating of maintenance costs for vapor
recovery may be significant and (2) the primary impact is directly
related to the initial cost.
IV-35
-------
V. PROJECT APPROACH AND METHODOLOGY
A. INFORMATION SOUGHT ABOUT BULK PLANTS
1. Inventory of Bulk Plants
An inventory of petroleum bulk plants for the National
Capital, Baltimore and Houston/Galveston AQCRs was prepared from
information obtained by contacting the several governmental regu-
latory agencies concerned and has been presented in Section III.
The agencies contacted include Region III and Region VI office of
the EPA, Maryland State Department of Health and Mental Hygiene,
District of Columbia Department of Environmental Services, Virginia
State Air Pollution Control Board, Texas Air Control Board, Harris
County Pollution Control Department, Galveston County Health Dis-
trict and City of Houston Department of Public Health, In addi-
tion, various industry associations, including (1) Texas Oil
Marketers Association, (2) Maryland Oil Jobbers Council, (3) Virginia
Petroleum Jobbers Association, and major integrated oil companies
were also contacted. Local business and even telephone directories
were used to supplement the inventory. Telephone, and personal
inquiries were made to gather these data.
2. Physical Description of Plants
An adequate physical description of a bulk plant included the
number and capacity of storage tanks, whether they were 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.
V-l
-------
3. Bulk Plant Operations
Questions to be answered concerning a bulk plant's operation
focused on sales, expenses and profits. Total gasoline throughput
at the bulk plants, the amount of gasoline transported directly from
the terminal to the customer, and estimates of the amount of gasoline
sold to agricultural accounts and accounts having tanks of less than
2,000 gal (.7.600 1.), i.e., exempt accounts, were all information
requested from the operators and owner. In addition, to better
assess the financial impact of vapor recovery installations on these
bulk plants, operators were questioned about annual sales, sales of
other products, margins, operating expenses, gross or net profits,
total assets, net worths, long term market, value of the facility
and future of the business.
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 contracts.
5. Financial Impact of Vapor Recovery
The financial impact of installing vapor recovery on specific
bulk plants was examined by seeking fiscal data from the operators
about annual sales, expenses, margins, profits, assets, debts,
original investment and current market value. 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.
V-2
-------
Because only a relatively small amount of detailed financial
information was available from individual plants, financial state-
ments 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 $10,000 by each of the seven
firms could then be made. The results and a detailed description
of the evaluating process is in Section VI . This approach also
reduced the problems of correlating businesses with substantial
variabilities in sales, profits, rates of return, etc.
B. SOURCES OF DATA
Personal interviews were the principal means of interviewing
people throughout the industry. Written communications and phone
contacts supplemented the data gathering portion of this task.
Agencies, individual and associations contacted included:
1. Various state and local air pollution
control agencies (11)
2. Bulk plant operators (59)
3. Industry associations (3 )
4. Major oil company representatives (10)
5. Miscellaneous Federal and state agency
representatives (5 )
Data obtained for preceding studies (1, 2) were used again
as background information for this task.
C. DATA GATHERING IN THE FIELD
State and local governmental agencies were contacted to obtain
information about air pollution control regulations applicable to
bulk plants, the total gasoline consumption in each AQCR and the dis-
tribution market share for bulk plants, hydrocarbon emission
V-3
-------
estimates, plant inventories and an overview of the agency's
perspective of bulk plants.
Industry associations were notified of the intended work.
At least one made a substantial effort to help by discussing the
project in their monthly newsletter and informing members of
planned interviews.
A standardized group of questions was prepared for inter-
viewing bulk plant operators. A sample copy is shown in Appendix D.
Almost all bulk plant operators were contacted on facilities,
throughputs and customers were available. Financial information
was more sparse, but almost all operators readily discussed how
vapor recovery would affect them.
A list of all contacts is available in Appendix E.
V-4
-------
VI. FINANCIAL ANALYSIS
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.
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. In addition,
the bulk plant operator may sometimes be able to purchase product
from his supplier at a reduced price to enable him to supply gasoline
to a particular group of customers at a given price.
In an earlier study (1) PES carried out a financial analysis
of small gasoline bulk plants. Data gathered in this current study
have generally agreed with the data from the earlier study, and
indicate that the first financial analysis is still valid. The
Market Analysis and Financial Analysis sections from reference (1)
are reproduced in Appendix F of this report for the convenience of
VI-1
-------
the reader. The analysis showed that the critical financial factor
was the ability of the plant owner to obtain funds for the initial
investment in vapor recovery equipment of approximately $10,000.
Plants with annual throughputs less than 600,000 gallons (2,300,
000 liters) are unlikely to qualify for loans. Firms with assets
between $50,000 and $750,000 were considered from the point of view
of their debt structure, working capital position and profitability
of the enterprise. Small Business Administration and Pollution
Control Financing Authority loans were considered along with con-
ventional bank loans. Tax incentives were evaluated and found to
be of minor assistance unless the firm is enjoying profits.
VI-2
-------
APPENDIX A
INVENTORY OF GASOLINE BULK PLANTS IN AIR
QUALITY CONTROL REGIONS SURVEYED
-------
GASOLINE BULK PLANTS IN BALTIMORE AND
NATIONAL CAPITAL AIR QUALITY CONTROL REGIONS
MARYLAND
BALTIMORE COUNTY
Amoco
Clark Oil Company
Ewbank-Walsh Oil Co,
Amoco
Wilhelm Oil Service
Town: Owings Mills
Street: 75 Gwynns Mill Court
Phone: 655-4228
Town: Phoenix
Street: 2815 Merrymens Mills Road
Phone:666-2280
Street: 6923 Ebenezer Road
Phone: 335-5220
Town: Cockeysville
Street: 10825 Beaver Dam Road
Phone: 666-2270
Town: RandalIstown
Street: 9502 Liberty Road
Phone: 922-6666
CARROLL COUNTY
S.L. Bare
Southern States Co-op
Carroll Petroleum Service
Eagle Oil Company
Town: Nestminster
Street: 8 Sullivan Avenue
Phone: 848-4080
Town: Westminster
Street: 121 John Street
Phone: 848-9420
Town: Westminster
Street: 229 East Green Street
Phone: 848-4610
-------
CARROLL COUNTY (continued)
S. Lease Warner
Palmer Petroleum
S.H. Tevis and Son
A.E. Wright and Son
Walsh Fuel & Supply Co,
Greenmount Fuel Company
Town: Westminster
Street: 509 Old Westminster Pike
Phone: 848-4477
Town: Westminster
Street: 80 John Street
Phone: 848-8600
Town: Westminster
Street: 82 John Street
Phone: 848-4433
Town: Westminster
Street: 732 Spring Mills School Road
Phone 848-7686
Town: Hampstead
Phone: 374-9081
374-4167
374-4865
374-4473
HARFORD COUNTY
B.P. Oil
Grier Oil Company
Amoco
Corbin Fuel Company
Town: Aberdeen
Street: 607 Old Philadelphia Road
Town: Aberdeen
Street: North Philadelphia Road
Phone; 272-2060
Town: Bel Air
Street; 501 North Main Street
Phone: 838-7333
879-9474
Town: Bel Air
Street: 33 Ellendale Street
Phone: 838-3590
-------
HARFORD COUNTY (continued)
Southern States Co-op Inc.
Bel Air Petroleum'Service
Bay Oil Company
Friendly Oil Company
J. Lawson Gilbert Dist.
Holter's Incorporated
Kurtz and Kahoe Oil
Whiteford Oil
Heaps Oil Company
Town: Bel Air
Street: 423 Rock Spring Avenue
Phone: 838-5600
Town: Havre de Grace
Street: 2110 Pulaski Highway
Phone: 939-1010
Town: Havre de Grace
Street: US Route 40 West from Havre de Grace
Phone: 939-3300
Town: Havre de Grace
Street: Water Street
Phone: 939-2424
Street: 901 Pulaski Highway
Phone: 676-0600
Town: Forest Hill
Street: 322 Bynum Road
Phone: 838-6910
879-2655
Town: Whiteford
Phone: 452-5660
Town; Cardiff
Phone: 452-8383
HOWARD COUNTY
Southern States Co-op Inc.
Town: Ellicott City
Street: 10065 Baltimore National Pike
-------
MONTGOMERY COUNTY
Stup and Costello
Southern States Co-op Inc.
Gaithersburg Petroleum
Services
ATco Oil Co.
Wash Petroleum Products
G.D. Armstrong Company
Town: Gaithersburg
Street: 465 East Diamond Ave.
Phone: 926-0115
Town: Gaithersburg
Street: 8 South Summit Avenue
Phone: 926-2600
948-3100
Town: Rockville
Street: 14915 Southlawn Lane
Town: Kenwood
Street: 5450 Butler Road
Phone: OL4-1274
Town: Laytonsvilie
Phone; 948-1902
PRINCE GEORGE'S COUNTY
Amoco
Early Petroleum Services
Berwyn Fuel Incorporated
Upper Marlboro Co-op
(Southern States)
ANNE ARUNDEL COUNTY
Amoco
Town; Landover
Street: Ardwick and Ardmore Roads
Town; Brandywine
Town: Laurel
Street: 101 Laurel Avenue
Town: Upper Marlboro
Street; 15510 Marlboro Pike
Town: Annapolis
Street: 308 First Street
Phone: 263-2307
-------
ANNE ARUNDEL COUNTY (continued)
Southern Maryland Oil Co.
Eastern Petroleum Corporation
Annapolis Utilities
Hardesty and Monroe
R.S. Lei ten Company
Town: Annapolis
Street: 2023 Bestgate Road
Phone: 267-8629
Town: Annapolis
Street: 7 Hudson Street
Phone: 263-0222
Town: Annapolis
Street: 1829 George Street (office)
Phone: 268-5055
Town: Edgewater
Phone: 956-2414
269-5584 (from Baltimore)
Town: Edgewater
Phone: 261-4041
VIRGINIA
ALEXANDRIA CITY
Fannon Petroleum Co,
FAIRFAX COUNTY
Quarles-Robertson Oil, Inc.
Southern States Co-op Inc,
Town: Alexandria
Street: 1308 Duke
Phone; 836-1133
Town: Fairfax
Street: 8902 Lee Highway
Phone: 573-5800
Town; Fai rfax
Street: 3590 Chain Bridge Road
Phone: 273-2345
-------
FAIRFAX COUNTY (continued)
Northern Virginia Oil
Potomac Oil
Town: Vienna
Street: 344 Mill
Phone: 938-6834
Town: Springfield
Street: 7101 Wimsett
Phone; 941-4500
LOUDOUN COUNTY
Southern States Co-op, Inc.
Leesburg Oil Co. Inc.
Community Oil Co.
Blankenship Oil Corp.
Hatcher-Wynkoop Oil Co. Inc.
Moorcones, Inc.
Thompson Oil Co., Inc.
Middleburg Oil Corp.
Town: Leesburg
Street:Near Catoctin Circle,
Phone: 777-2431
Town: Leesburg
Street: Near Catoctin Circle
Phone: 777-3002
Town: Leesburg
Street: 58 S. Wirt St.
Phone; 777-2092
Town: Leesburg
Street: Harrison Street
Phone: 777-4131
Town: Leesburg
Street; 45 S, Catoctin Circle
Phone: 777-1184
Town: Purcellville
Street: Route 7 East
Phone; 338-7186
Town: Purcellville
Street: 21st and 0 Street
Phone: 338-7196
Town: Middleburg
Street: Federal
Phone: 687-6326
-------
GASOLINE BULK PLANTS IN HOUSTON/GALVESTON AREAS
BRAZORIA COUNTY
D.D. Clark Oil Co.
Gulf Oil
Lion Oil Co.
Mobil Oil Co.
Phillips 66
Continental Oil Co.*
Exxon
Town: Alvin
Street: 4502 Hwy 35
Contact: D.D, Clark
Telephone: (713) 331-3631
Town: Alvin
Street: South Street
Telephone; (713) 331-3445
Town: Alvin
Street: 2411 1/2 South Gordon
Telephone: (713) 331-4255
Town: Alvin
Street: 308 N. Taylor
Contact: George Warfield
Telephone: (713) 331-4101
Town: Alvin
Street: Hwy 6 & Hwy 35 Bypass
Contact: George Monteau
Telephone: (713) 585-4431
Town: Angel ton
Street: E. Hwy 35
Telephone: (713) 849-7565
Town: Angel ton
Street 227 S. Front
Contact: Ben Magness
Telephone: (713) 393-1010
(713) 849-7122
-------
BRAZORIA COUNTY (continued)
Farmers Oil Co.
(Mobil Distributor)
Texaco
Merrills Phillips 66*
Texaco*
Vickers V (Mobil)*
Wruck Oil Co.
(Texaco Distributor)
Furnace Todd Consignee, Inc.
Phillips
Town: Angel ton
Street: 139 S. Front
Contact: Brian Steves
Telephone: (713) 849-5501
Town: Angel ton
Street: 215 S. Front
Contact: R.B. Stewart
Telephone: (713) 849-7471
Town: Brazosport
Street: 1912 Brazosport Blvd.
Telephone: (713) 233-5031
Town: Brazosport
Street: 629 E. 2nd
Telephone: (713) 233-5275
Town: Brazosport
Street: Park Avenue
Telephone: (713) 233-3291
Town: Damon
Street: 211 Mulcahy
Telephone: (713) 742-3223
Town: Manvel
Street: W. Hwy 6
Telephone: (713) 489-8132
Town: Pearl and
Street: 2222 North Main
Contact; E,E, Martin
Telephone: (713) 485-1402
-------
CHAMBERS COUNTY
Enderli Oil Co.
Edmunds Oil Co.
Exxon
Gulf Oil
FORT BEND COUNTY
Exxon
Gulf Oil
Mobil Oil
Stavinoha Petrol Supply
Town: Mount Bell view
Contact: Larry Enderli
Telephone: (713) 427-4416
Town: Winnie
Contact; Mr. Edmunds
Telephone: (713) 296-2106
(713) 296-2345
Town: Winnie
Contact: Mr. Miguez
Telephone: (.713) 296-2041
Town: Winnie
Contact: Pat McGowan
Telephone: (713) 296-2312
Town: Katy
Street; Hwy 90 [Business)
Contact: Arthur Miller
Telephone; (713) 371-2613
(713) 371-2703
Town: Katy
Street: 5601 1st
Contact: D,G. Thompson
Telephone; (713) 371-3121
Town: Katy
Street: 5610 1st
Contact: Van Scoggins
Telephone: (713) 371-2266
Town: Needville
Street: 10003 FM Rd. 360
Telephone; (713) 793-6105
-------
FORT BEND COUNTY
ARCO
Blase Oil Co.
Exxon
Gulf Oil
Mobil Oil
Exxon
GALVESTON COUNTY
Gulf Oil
Town: Richmond
Street: Austin St.
Town: Rosenburg
Street: 1023 Ave. H
Telephone: (713) 232-3831
Town: Rosenburg
Street: 2317 Avenue F
Contact; Mr, Bernhausen
Telephone: (713) 342-4511
Town: Rosenburg
Street; 1417 Avenue G
Contact: Mr. Krolcyzk
Telephone: (713) 342-2162
Town: Rosenburg
Street; 2290 Avenue F
Contact: Clarence Foss
Telephone: (713) 342-2211
Town; Sugar Land
Street: 406 Imperial
Contact: Janice Armstrong
Telephone: (713) 494-2224
Town: Galveston
Street; 1802 Water
Contact: Roland Kuhn
Telephone: (713) 763-6466
(713) 488-3326
-------
GALVESTON COUNTY (continued)
Mobil Oil
HARRIS COUNTY
Enderli Oil Co.
(Phillips)
Exxon*
Gulf Oil
Texaco
Bay Oil Co.
Glaw Oil Co.
Harco Oil Co.
Town: Galveston
Street: 1202 Water
Telephone: (713) 765-5517
Town: Baytown
Street: 1300 N, Alexander
Contact: Larry Enderli
Telephone; (713) 427-4416
Town: Baytown
Telephone: (713) 422-2273
Town: Baytown
Street: 810 N. Main
Contact: Mr. Barrow
Telephone: (713) 427-4017
Town: Baytown
Street: 2700 N. Main
Contact: Dennis Trigg
Telephone: (713) 427-0576
Town: Houston
Street: 408 Jensen
Contact: Harvey Smith Jr.
Telephone: (713) 228-6388
Town; Houston
Street: 4010 McKinney
Contact: Bill Glaw
Telephone: (713) 222-8391
Town: Houston
Street: 3601 McKinney
Contact: Oliver Pearson
Telephone; (713) 236-1331
-------
HARRIS COUNTY (continued)
Harris County Oil Co.
Springer Oil Co.
Star-Tex Oil Co.
Texas Gulf Gas Corp.
Tomnrie Mines Oil Co.
Lindsay Oil Co. of Texas*
Apache Oil Co.*
Dickson Oil Co.*
(Gulf Oil)
Town: Houston
Street: 3325 W 11th
Contact: George Franklow Jr.
Telephone: (713) 861-8115
Town: Houston
Street: 642 W. Gulf Bank
Contact; Jim Springer
Telephone: (713) 447-6328
Town: Houston
Street: 5708 Harvey Wilson
Contact; Bob Harron
Telephone: (713) 675-6506
Town; Houston
Street: 6734 Winton
Telephone: (713) 747-6113
Town: Houston
Street: 7701 Almeda
Contact: Carl Shtro
Telephone: (713) 747-4440
Town: Humble
Street: 6606 FM Rd. 1960
Telephone: (713) 444-3038
Town: Pasadena
Street: 2709 Dewberry
Telephone; (713) 946-5785
Town: Pasadena
Street: 4830 Red Bluff
Telephone: (713) 487-1318
-------
HARRIS COUNTY (continued)
Herbert H, Bishop*
(Texaco)
Exxon
Town: Pasadena
Street: 1004 E, Pasadena Frwy
Telephone: (713) 447-3589
Town: Tomball
Contact: Mr, Nichol
Telephone: (713) 351-1871
LIBERTY COUNTY
Cleveland Oil Co.
Gulf Oil Co.
Harris Petroleum Co.
(Shell)
McMahon Oil Co.
(Conoco)
Texaco
Exxon
Town: Cleveland
Street; 324 San Jacinto
Telephone: (713) 592-3961
Town: Cleveland
Street: Hwy 321
Telephone: (713) 592-5891
Town: Cleveland
Street; 340 San Jacinto
Telephone: (713) 592-8012
(713) 592-8161
Town: Cleveland
Street: 315 S. Washington
Telephone: (713) 592-3531
Town: Cleveland
Street: 332 San Jacinto
Contact: Mr. Pursley or Mr. Keeland
Telephone: (713) 592-3831
Town; Dayton
Street: 112 Bryan
Contact: J.B. Sterling
Telephone: (713) 258-2633
-------
LIBERTY COUNTY (continued)
Lowe Oil Co.
ARCO
Gulf Oil
Mobil Oil
Texaco
Town: Dayton
Street: 306 Lowe
Contact: Vern Lowe
Telephone: (713) 258-2245
Town: Liberty
Street: Old Beaumont Hwy
Telephone: (713) 336-3131
Town: Liberty
Street; 500 W. Hwy 90
Contact: John Herbert
Telephone: (.713) 336-5232
Town: Liberty
Street: 504 W, Hwy 90
Contact: Mr. Silhavy
Telephone: (713) 336-3332
Town: Liberty
Street: 105 Crockett
Telephone: (713) 336-3892
MATAGORDA COUNTY
Evans Oil Co.
Exxon
Town: Bay City
Street: 2300 7th (Hwy 60)
Contact: Mr, Evans
Telephone: (713) 245-2981
Town: Bay City
Street; Hwy 60
Contact: Mike Pruit
Telephone; (713) 245-2201
-------
MATAGORDA COUNTY (continued)
Gulf Oil
Hurley Oil Co.
(Phillips)
Savco
(Shamrock)
Speedway Oil Co.
Texaco
Town: Bay City
Street; 2705 Avenue F
Contact: Bob Brown
Telephone: (713) 245-2901
Town: Bay City
Street: West Columbia Hwy
Contact: Frank Hurley
Telephone: (713) 245-2462
Town: Bay City
Street: 2617 Avenue C
Contact: Jim Kovar
Telephone; (713) 245-9161
Town; Bay City
Street: 2300 7th (Hwy 60)
Contact; J.D, Berryman
Telephone: (713) 245-4844
Town: Bay City
Street: 1821 Avenue C
Contact: Eddie Nedbalek
Telephone; (713) 245-4891
MONTGOMERY COUNTY
Carco Oil Co,
Exxon
Town; Conroe
Street: 108 E. Davis
Telephone; (713) 756-2229
Town: Conroe
Street: 103 N, First
Contact; John Stubbs
T°i*ohone: (713) 756-4020
-------
MONTGOMERY COUNTY (continued)
Gulf Oil
Russ Clantan Oil Co.
Texaco
Town: Conroe
Street: 123 Avenue A
Contact: T.C, Brannon
Telephone: (713) 756-2214
Town: Conroe
Street: 715 Dallas
Contact: Russ Clanton
Telephone: (713) 756-3521
Town: Conroe
Street: Hwy 45
Contact: Bill Pursley
Telephone; (713) 756-4469
WALLER COUNTY
Calhoun Distributing Co.
Exxon
Texaco
Town: Hempstead
Street: 1502 St, Mary's St,
Contact: Gerald Calhoun
Telephone: (713) 826-2235
Town: Hempstead
Street: 1446 St. Mary's St.
Contact: J.C. Hicks
Telephone: (713) 826-2231
Town: Hempstead
Street: 1346 St, Mary's St.
Contact: Roy Cook
Telephone: (713) 826-3340
*Plants which could not be located or verified as bulk plants
-------
APPENDIX B
VAPOR RECOVERY REGULATIONS EFFECTIVE IN BALTIMORE AQCR
AND NATIONAL CAPITAL AQCR
-------
Maryland State Department of Health and Mental Hygiene
'201 W. Preston Street
Baltimore, Maryland 21201
(As Amended through June 17, 1975)
10.03.38 Regulations Governing the Control of Air Pollution in Area III*
Pursuant to the authority conferred upon the Secretary of Health and Mental
Hygiene by Article 43, Section 697, Annotated Code of Maryland, 1957 Edition, and
Supplement, the following regulations governing the control of air pollution in
Area III are hereby established as requirements of the Department of Health and
Mental Hygiene.
Baltimore Metropolitan Area comprising Baltimore City and Anne Arundel, Baltimore,
Carroll, Htrford and Howard Counties.
J. Hydrocarbons Prom Other Than Fuel Burning Equipment.
(1) Definitions for purposes of these regulations:
-------
-10-
a. "Architectural Coating" shall mean any coating used for resi-
dential, commercial or industrial buildings and their appur-
tenances ,
b. "Motor Vehicle Fuel" shall mean motor vehicle fuel as defined
in Article 56, Section 135(b) of the Annotated Code of Mary-
land.
c, "Organic Material" shall mean chemical compounds of carbon
excluding carbon monoxide, carbon dioxide, carbonic acid,
metallic carbonates, metallic carbides and ammonium carbonates.
d. "Organic Solvent" shall mean any organic material which is
liquid at standard conditions and which is used as a dissolver,
viscosity reducer or cleaning agent.
e. "Photochemically Reactive Organic Solvent" shall mean any
organic solvent with an aggregate of more than 20% of its
total volume composed of the chemical compounds classified
below or which exceeds any of the following individuals per-
centage composition limitations referred to the total volume
of solvent;
(1) A combination of hydrocarbons, alcohols, aldehydes, esters
or ketonee any of which has an olefinic or cyclo-olefinic
type of unsaturation: 5%.
(2) A combination of aromatic compounds with eight or more
carbon atoms to the molecule except ethylbenzene: 8%,
(3) A combination of ethylbenzene, ketones having branched
hydrocarbon structures or toluene: 20%.
Whenever any organic solvent or any constituent of an organic
solvent may be classified from its chemical structure into
more than one of the above groups or organic compounds, it
shall be considered as a member of the most reactive chemical
group, that is, that group having the least allowable percent
of the total volume of solvents.
For architectural coatings only, the volume of water con-
tained in the solvent may be used to compute the total volume
of the solvent in determining percentages of photochemically
reactive organic solvents.
£• "Reid Vapor Pressure" shall mean the absolute pressure in pounds
per square inch determined at 100°F and v/1 = 4 (ratio of vapor
volume to liquid volume, as defined in ASIM designation D 323-58)
by using apparatus and procedures as standardized under the auspices
of the American Society for Testing and Materials.
g. "True Vapor Pressure" shall mean the absolute pressure in
pounds per square inch determined at storage conditions.
Storage conditions shall be taken as the average monthly temp-
erature. If the storage is subject to solar and ambient heat
gain only, the temperature shall be taken as the average monthly
temperature to a maximum average of 7801-' (average storage temp-
erature for May through September). True vapor pressure shall
be determined by measurement at the storage conditions or by the
use of a nomograph, published by the Coordinating Research
Council and included with these regulations as Figure 1, relating
true vapor pressure to Reid Vapor Pressure and storage temperature.
-------
-11-
h. "Vapor Balance Line" shall mean any connection closed to
the atmosphere between the vapor space of two storage con-
tainers that will allow the vapors to be displaced as the
liquid is transferred from one tank to the other.
i, "Photochetnically Reactive Organic Materials" shall include
any of the following:
(1) Hydrocarbons, alcohols, aldehydes, esters or ketones
any of which has an olefinic or cyclo-olefinic type
unsaturation,
(2) Aromatic compounds with 7 or more carbon atoms,
(3) Ketones having branched hydrocarbon structure,
(4) Motor vehicle fuel with a true vapor pressure greater
than 1.5 psia at 78<>F,
(5) Organic solvents which have been in direct contact with
flame in the presence of oxygen,
(6) Compounds emitted from a process in which organic solvents
are baked, heat cured or heat polymerized in the presence
of oxygen.
(2) Organic Material.
a* After January 1, 1973, a person shall not cause
or permit organic material having a true vapor pressure in
the range of 1.5 to 11 psi inclusive to be placed, stored or
held in any existing stationary tank reservior with a capacity
of greater than 65,000 gallons, or in any new stationary tank
reservior with a capacity of greater than 40,000 gallons unless
the tank is equipped with one or more of the following organic
material vapor control devices, properly installed, well-main-
tained and in operating condition.
(1) A floating roof resting on the surface of the liquid con-
tents equipped with a closure seal, or seals, to close the
space between the roof edge and tank wall, and in addition,
all tank gauging and sampling devices shall be gas-tight
except when in use, or
(2) A pressure tank system maintaining a pressure at all times
so as to prevent organic material loss to the atmosphere, or
(3) A vapor recovery system capable of collecting the organic
materials emitted from the tank and disposing of these
emissions so as to prevent their emission to the atmosphere,
and in addition, all tank gauging and sampling devices shall
be gas-tight except when in use, or
(4) Other equipment equal or greater in efficiency to those
devices listed above, and approved by the Department.
b. After January 1, 1973, a person shall not cause or
permit organic materials having a true vapor pressure greater
than 11 psi to be placed, stored or held in any existing
stationary tank reservior with a capacity of greater than 65;000
gallons, or in any new stationary tank reservior with a capacity
greater than 40,000 gallons unless equipped with one of the fol-
lowing organic material vapor control devices properly installed,
well-maintained and in operating condition:
(1) A pressure tank system maintaining a pressure at all
times so as to prevent organic material loss to the
atmosphere, or
-------
-12-
(2) A vapor recovery system capable of collecting the organic
materials emitted from the tank and disposing of these
emissions so as to prevent their emission to the atmosphere,
and in addition, all tank gauging and sampling devices shall
be gas-tight except when in use, or
(3) Other equipment equal or greater in efficiency to those
devices listed above, and approved by the Department.
c. After January 1, 1974, a person shall not cause or
permit organic material with a true vapor pressure of 1.5 psi
or greater to be loaded into any tank truck, tank trailer or other
contrivance from any existing loading system on any premise at
which the total daily throughput (1/300 of actual annual through-
put) exceeds 40,000 gallons or from any new loading system on
any premise at which the total daily throughput exceeds 20,000
gallons unless the loading system is equipped with a vapor re-
covery system that is properly installed, we11-maintained and in
operation and has been approved by the Department. Additions to,
or modifications or alterations of existing loading systems
which increase the total daily throughput at a premise to more
than 40,000 gallons shall require such a vapor recovery system
for the entire loading system. All loading connections on the
vapor lines shall be equipped with fittings which shall be vapor
tight and will automatically and immediately close upon dis-
connection so as to prevent release of organic material from
these fittings. The provisions of this paragraph shall not
apply to the loading of motor vehicle fuel tanks.
d. After January 1, 1974, a person shall not cause or .
permit any motor vehicle fuel with a true vapor pressure of 1,5
psi or greater to be loaded from a tank truck or trailer or
other contrivance into a stationary tank having a capacity greater
than 5,000 gallons, but less than 40,000 gallons and installed
after January 1, 1973, unless the loading system is equipped
with a vapor balance line or equally effective vapor discharge
control system approved by the Department. Components of the
vapor balance line consisting of a vapor space connection on
the tank and a compatible vapor return line on the truck shall
be installed by the following dates:
Tank connection January 1, 1973
Truck vapor return line January I, 1974
e. Motor Vehicle Fuel.
(1) After May 31, 1975, a person shall not cause or permit
any motor vehicle fuel with a true vapor pressure of 1.5
psi or greater to be loaded into an existing stationary
tank having a capacity of less than 40,000 gallons unless
the loading system is equipped with a vapor balance line
or equally effective vapor discharge control system approved
by the Department at a premise where the monthly average
throughput (1/12 of the sum total, throughput for the pro-
ceeding twelve months) exceeds 50,000 gallons per month.
The owner or operator of any premise subject to these re-
quirements shall submit to the Department by January 2, 1974,
the following information:
-------
-13-
location of premise
Sum total throughput for the proceeding twelve months
Schedule for:
Negotiation of construction contract
Start of construction
Completion of construction
(2) After May 31, 1977^ a person shall not cause or permit any
motor vehicle fuel with a true vapor pressure of 1.5 psi
or greater to be loaded into an existing stationary tank
having a capacity of less than 40,000 gallons unless the
loading system ia equipped with a vapor balance line or
equally effective vapor discharge control system capable of
a minimum of 90 percent control of the emission approved
by the Department at a premise where the monthly average
throughput exceeds 20,000 gallons per month.
(3) A person shall not cause or permit any motor vehicle fuel
tank to be filled with motor vehicle fuel with a true vapor
pressure of 1.5 psi or greater from a premise where station-
airy tanks are equipped with vapor balance lines, unless
a vapor collecting system, approved by the Department, is
installed and in good operating condition. This part shall
become effective 18 months after the Department has approved
two or more such vapor collection systems.
(3) Organic Solvents.
a* A person shall not cause or permit the discharge of any emissions
of organic materials in any one day from any installation or
building, erected on or after May 12, 1972, in which any organic
solvent or solvent containing material is in direct contact with
a flame, or is baked, heat cured, or heat polymerized in the pre-
sence of oxygen in excess of 15 pounds per day unless the dis-
charge is reduced by 85 percent or more overall. The correspond-
ing limit for such installations erected before May 12, 1972,
shall be 200 pounds per day unless reduced by 85 percent
or more overall.
b. A person shall not cause or permit the discharge of any emissions
of photochemically reactive solvent in any one day from any
installation or building erected on or after May 12, 1972, not
specifically defined in paragraph (3)a above, used for employing,
apPlv» evaporating, drying, processing or manufacturing
any such s-olvent or material containing such solvent, in excess
of'40 pounds per day unless the discharge is reduced by 85 per-
cent or more overall. The corresponding limit for installations
erected before May 12, 1972, shall be 200 pounds per day unless
reduced by 85 percent or more overall. Exceptions to this pro-
vision shall include the operating of tar heaters, coke ovens
and air ventilating systems evacuating spaces in which the solvent
concentration is lower than the TLV for human exposure as defined
by the American Conference of Governmental Industrial llygienints.
c» A person incinerating, adsorbing or otherwise processing organic
materials pursuant to this rule, shall provide, properly install
and maintain in calibration, in good working order and in oper-
ation devices as specified in the authority to construct or the
permit to operate, or as specified by the Department for indicating
s^roi temperatures, pressures, rates of flow or other operating conditions
necessary to determine the degree and effectiveness of air pol-
lution control.
-------
Maryland state Department of iicaltn ami Mental Hygiene
^Ul west I'rcston Street
ualtimore, I'Jaryland ^12ui
(AS Amended through June L7 , 197$)
Regulations Governing the Control of *o.r Pollution in Area iV*
pursuant to tue autnon.ty conferred upon the secretary o£ Health and Mental.
Hygiene oy Article 4o, ^ection 697, Annotated Code oi: Marylanu, 19!>7 Ivdition, anu
supplement, the following regulations governing the control ot air pollution in
Area JLV are hereby established as requirements of the Department of lle<*lth and
Mental Hygiene.
.01 CONTROL ANu i'ROItliiUION OF OfEN FIRliS
A. General. A person shall not cause or permit an open fire
except as provided in subsections .ulli, .ulC, ana .ulu.
u. Control ufficer May Authorise Certain upen Fires. The Control Officer
may, upon receipt ot an application made on forms provided by the De-
partment or local £;.re control agency, j.ssue or approve a permit in
writing allowing an open fire provided all of the following conditions
are met:
Tne Control Officer is satisfied tnat there is no practical al-
ternate metnod to dispose of the material to be burned or to
conduct tne desired activity.
A hazardous condition or air pollution or nuisance will not be
created,
Burning snail not be done within iuu yards of one or more occupied
buildings or a neaviiy travelled public roadway.
Fire control laws or regulations of other governiaentai agencies will
not be violated.
(;>; Materials will not be burned which produce dense smoke when burned,
including but not limited to tires and roofing material.
(6; sucn otner conditions as the Contrul Officer may impose to uiini-
mi/.e ere tion ot smoke, to prevent nuisances ana air pollution,
and to protect the health, safety, comfort, anu property of any
persons snail be satisfied,
(7; The material to be burned shall have originated on the premises
on wnicn it is to be burned.
(«; inceptions. Methods off disposal by burning acceptable to the
uepartuient may be approved for use when distance limitations can-
not be met,
(J. Puolic officers iiay Authorise Certain Fires, Public officers, in the
performance ot their official duties, may set an open fire or give
periuitision for an open fire, with concurrence of the control officer,
provided all reasonable means are employed to minimise smoke anu it the
fire is necessary for one or more of the following reasons or purposes:
"Washington irtetropolitan Area comprising Montgomery anu frince George's Counties.
-------
J. Hydrocarbons frou other tnun Kuril Burning Equipment,
(.1) uefinitions for purposes of tnese regulations:
a, "/ircnitecturai Coating" shall mean any coating used tor resi-
dential, commercial or industrial buiiuings anu their appur-
tenances,
u, "rjotor Venicie Fuel" shall uiei^n motor venicie fuel aa defined
in rftTticle ^6, .Section lo^CbJ ot tne Annotated Code ot nary-
c. "Organic ratenai" sh-ii uie-n cnemieai couipounus of carbon
excluding caruun monoxide, caroon dioxide, carbonic ucia,
metallic carbonates, metallic carbides anu ammonium carbonates.
U, "organic solvent" sn-ii mean any organic material wnicn is
liquid at atanuaru conuitiono anu v?nich la Uoeu as u uissoiver,
viscosity reuucer or cleaning agent,
e« "x-notocnewic-iiy Reactive I'rganic Solvent" sn^ii ue^n any
organic solvent with an aggregate of more than /U% OE its
total volume couipoaeu of the cheuiicai cuupuutids ci
oeiuw or wnica exceeus any of tne toiiowing inuiviau^i
centage composition limitation^ referred to the total volume
ot solvent:
n couioinution ot hydrocaroons, alcohols, aidehyues, esters
or ketones any of which n«.a an oletinic or cycio-olef inic
tyijes ot unaaturation: iW
/» combination ot aromatic compounds v/ittx eignt or more
carDon atoms to tne molecule eiccept ethyioen^ene: oVi.
*\. comumatiun ot ettiyiDen^ene, icetunes n^ving orancneu
hyurocaroon structures or toxuene: -iu/j,
ivnenever any organic solvent or any constituent ot an organic
solvent may De class if ieu from ita cne»uicai structure into
more tn.^n one on tfte aoove gruupa or organic compounua, it
ahull oe considered as a mewDer ut the most ruactive chemical
group, tn^t ID, tuat group n«ving the itiast uiiowaDie i^ercent
ot tne total volume ot solvents,
I/or architectural costings oniy, tne volume ot water con-
taineu in tue solvent m^.y oe used to compute the total volume
or tne solvent in determining percentages ut pnotoche'«icany
reactive organic solvents.
"Rexu Vapor JTiswaur^" ali^n u«un tne ausoiute pressure in pounus
per ayuure j.nch ueterwineu at iuu«f ana v/i = 4 (ratio ot vapor
volume to H-4U1U volume, aa uetineu in uolVi designation u j^joa;
uy u-ing apparatus and proceuures as stan-uaru i*eu unuer the
auspices ot tne nu*ericah society tor Testing anu mtericxio.
"True Va^or rresauri." anoli me-n tne aosoiute pressure in
pounus i^er square men determined at storage* conuitions.
storage con-itxons an«ii oe tafcen as tne average montniy temp-
er^ture, it tne storage is suoject to aoi«r ana awuient heat
gain oniy, tue temperature sru.ii oe taicen as the average montniy
temperature to a maximum average ot 7w°F (average storage te«p-
erature tor iuy tnrougn i>eptemDer;. True v«por pressure siuui
oe uetermmeu uy measurement at tne utor^e conuitiun^ or uy tue
use or a nouiogr-pn, pubiianeu oy tue cooruinutmg iieae«rcu
council and inciu^ea witn tnese regulations <»a t-'igure i, relating
true vapor pressure to Jteid vapor pressu^-e and storage temperature*
-------
-II-
h. "Vapor Balance Line" shall mean any connection closed to
the atmsophere between the vapor space of two storage con-
tainers that will allow the vapors to be displaced as the
liquid is transferred from one tank to the other.
i. "Photochemically Reactive Organic Materials" shall include
any o£ the following:
()) Hydrocarbons, alcohols, aldehydes, eaters or ketones
any of which has an olefinic or cyclo-clefini.c type
unsaturatlon,
(2) Aromatic compounds with 7 or more carbon atoms,
(3) Ketones having branched hydrocarbon structure,
(4) Motor vehicle fuel with a true vapor pressure greater
than 1.5 psia at 78op,
(5) Organic solvents which have been in direct contact
with flame in the presence of oxygen,
(6) Compounds emitted from a process in which organic solvents
are baked, heat cured or heat polymerized in the presence
of oxygen.
(2) Organic Material.
a. After January 1, 1973, a person shall not cause
or permit organic material having a true vapor pressure in
the range of 1.5 to 11 psi inclusive to be placed, stored or
held in any existing stationary tank reservior with a capacity
of greater than 65,000 gallons, or in any new stationary tank
reservior with a capacity of greater than 40,000 gallons unless
the tank is equipped with one or more of the following organic
material vapor control devices, properly installed, well-main-
tained and in operating condition.
(1) A floating roof resting on the surface of the liquid con-
tents equipped with a closure seal, or seals, to close
the space between the roof edge and tank wall, and in
addition, all tank gauging and sampling devices shall
be gas-tight except when in use, or
(2) A pressure tank system maintaining a pressure at all
times so as to prevent organic material loss to the
atmosphere, or
(3) A vapor recovery system capable of collecting the organic
materials emitted from the tank and disposing of these
emissions so as to prevent their emission to the atmos-
phere, and in addition, all tank gauging and sampling
devices shall be gas-tight except when in use, or
(4) Other equipment equal or greater in efficiency to those
devices listed above, and approved by the Department.
b. After January 1, 1973, a person shall not cause
or permit organic materials having a true vapor pressure greater
than 11 psi to be placed, stored or held in any existing
stationary tank reservior with a capacity of greater than
65,000 gallons, or in any new stationary tank reservior
with a capacity greater than 40,000 gallons unless equipped
with one of the following organic material vapor control
devices properly installed, we11-maintained and in operating
condition:
(1) A pressure tank system maintaining a pressure at all
times so as to prevent organic material loss to the
atmosphere, or
-------
-12-
(2) A vapor recovery system capable of: collecting the organic
materials emitted from the tank and disposing of these
emissions so as to prevent their emission to the atmosphere,
and in addition, all tank gauging and .sampling devices shall
be fjas-tiftht except who.n in use, or
(3) other uquipinent <-.qu.il or j'.re.iter in efficiency l:o those
devices listed above, and approved by the Department.
c. After January 1, 1974, a person shall not cause or
permit organic material with a true vapor pressure ot 1.5 psi or
greater to be loaded into any tank truck, tank trailer or other
contrivance from any existing loading system on any premise at
which the total daily throughput (1/300 of actual annual through-
put) exceeds 40,000 gallons or from any new loading system on
any premise at which the total daily throughput exceeds 20,000
gallons unless the loading system is equipped with a vapor re-
covery system that is properly installed, well-maintained and in
operation and has been approved by the Department. Additions to,
or modificiations or alterations of existing loading systems
which increase the total daily throughput at a premise to more
than 40,000 gallons shall require such a vapor recovery system
for the entire loading system. All loading connections on the
vapor lines shall be equipped'with fittings which shall be vapor
tight and will automatically and immediately close upon dis-
connection so as to prevent release of organic material from
these fittings. The provisions of this paragraph shall not
apply to the loading of motor vehicle fuel tanks.
d. After January 1, 1974, a person shall not cause or
permit any motor vehicle fuel with a true vapor pressure of 1,5
psi or greater to be loaded from a tank truck or trailer or other
contrivance into a stationary tank having a capacity greater
than 5,000 gallons, but less than 40,000 gallons and installed
after January 1, 1973, unless the loading system is equipped
with a vapor balance line or equally effective vapor discharge
control system approved by the Department. Components of the
vapor balance line consisting of a vapor space connection on
the tank and a compatible vapor return line on the truck shall
be installed by the following dates:
Tank connection January 1, 1973
_Truck vapor return line January 1, 1974
c. Motor Vehcile Fuel.
(1) After May 31, 1975, a person shall not cause or permit
any motor vehicle fuel with a true vapor pressure of 1.5
psi or greater to be loaded into an existing stationary
tank having a capacity of less than 40,000 gallons unless
the loading system is equipped with a vapor balance line
or equally effective vapor discharge control system approved
by the Department at a premise where the monthly average
throughput (1/12 of the sum total throughput for the pre-
ceeding twelve months) exceeds 50,000 gallons per month.
The owner or operator of any premise subject to these re-
quirements shall submit to the Department by January 2, 1974,
the following information:
-------
-13-
Location of premise
Sum total throughput for the preceeding twelve months
Schedule for:
Negotiation of construction contract
Start of construction
Completion of construction
(2) ALter May 31, 1977, a person shall not cause or permit any
motor vehicle fuel with a true vapor pressure of 1,5 psi
or greater to be loaded into an existing stationary tank
having a capacity of less than 40,000 gallons unless the
loading system is equipped with a vapor balance line or
equally effective vapor discharge control system capable of
a minimum of 90 percent control of the emission approved
by the Department at a premise where the monthly average
throughput exceeds 20,000 gallons per month,
(3) A person shall not cause or permit any motor vehicle fuel
tank to be filled with motor vehicle fuel with a true vapor
pressure of 1.5 psi or greater from a premise where station-
ary tanks are equipped with vapor balance lines, unless
a vapor collecting system, approved by the Department,
is installed and in good operating condition. This part
shall become effective 18 months after the Department has
approved two or more such vapor collection systems.
(3) Organic Solvents.
a. A person shall not cause or permit the discharge of any emissions
of organic materials in any one day from any installation or
building, erected on or after May 12, 1972, in which any organic
solvent or solvent containing material is in direct contact with
a flaire, or is baked, heat-cured, or heat polymerized in the
presence of oxygen in excess of 15 pounds per day unless the
discharge is reduced by 85 percent or more overall. The cor-
responding limit for such installations erected before May 12,
1972, shall be 200 pounds per day unless reduced by 85
percent or more overall.
b, A person shall not cause or permit the discharge of any emis-
sions of photochemically reactive solvent in any one day from
any installation or building erected on or after May 12, 1972,
.not specifically defined in paragraph (3)a above, used for em-
ploying, applying, evaporating, drying, processing or manu-
facturing any such solvent or material containing such solvent,
in excess of 40 pounds per day unless the discharge is reduced
by 85 percent or more overall. The corresponding limit for
installations erected before May 12, 1972, shall be 200 pounds
per day unless reduced by 85 percent or more overall. Exceptions
to this provision shall include the operation of tar heaters,
coke ovens and air ventilating systems evacuating spaces in
which the solvent concentration is lower than the TLV for human
exposure as defined by the American Conference of Governmental
Industrial Ilygienists.
c, A person incinerating, adsorbing or otherwise processing organic
materials pursuant to this rule shall provide, properly install
and maintain in calibration, in good working order and in oper-
ation devices as specified in the authority to construct or the
permit to operate, or as specified by the Department for indicating
temperatures, pressures, rates of flow or other operating conditions
necessary to determine the degree and effectiveness of air pol-
lution control.
-------
125:2306
FEDERAL REGULATIONS
March 1. 1974. each submit to the Ad-
ministrator a compliance schedule which
shall be subject to the Administrator's
approval and which .shall include, at a
minimum, copies of all relevant sources
of authority for the program of traffic
flow improvements, a signed statement
by the Governor of Maryland, the Mayor
of Baltimore or their designces, identify-
ing the sources of funding for the pro-
gram, and a complete list of specific
projects and their estimated initiation
and completion dates. All projects neces-
sary to the pollution reduction benefits
claimed in the State plan must be com-
pleted by May 31, 1977. On or before
May 1, 1974, the State of Maryland and
the City of Baltimore shall submit to
the Administrator legally adopted regu-
lations providing for .completion of the
projects in accordance with the com-
pliance schedule.
(2) The State of Maryland and the
City of Baltimore shall in the com-
pliance schedule required pursuant to
this paragraph. Indicate for each project
In the traffic management program
the increase anticipated in average an-
nual daily traffic volume within twenty
years of project completion on the
road or highway In question because of
the project. No project shall be approved
by the Administrator if the air
pollution benefits in terms of speeding
traffic flow will be negated by increased
traffic volume.
g 52.1081 Control strategy i Carbon
monoxide and photochemical 'oxi-
dant* (hydrocarbons).
(a) With respect to the transportation
control plan for the National Capital re-
gion submitted by the State, the require-
ments of 551.14
(3) (1) of this chapter are also not met, In
whole or in part, for inspection/main-
tenance, heavy duty retrofit, and re-
stricted vehicle use during predicted
stagnations referred to in §52.1073(e),
and the traffic flow improvement pro-
gram referred to § 52.1073(d).
(d) The requirements of § 51.14(c) of
this chapter are not met with respect to
the restrictions on vehicle use during
predicted stagnations disapproved in
§ 52.1073(e). Maryland has not demon-
strated the .availability of a reliable
method or system for predicting air epi-
sodes. The requirements of 8 51.-
14(c) of this chapter are also not met
with respect to gasoline vapor controls
to the extent that Maryland proposes to
exempt stations with a throughput of.
less than 20,000 gallons/month.
[41 FR 26901, June 30, 1976]
§ 52.1082 Rules and regulations.
(a) The requirements of § 51.22 of
this chapter are not met for the Na-
tional Capital Interstate Region because
regulations necessary to implement pro-
posed stationary control measures for
gas handling and dry cleaning losses
have not been adopted. Substitute regula-
tions are promulgated in §§ 52.1086,
52.1087, and 52.1088.
(b) The requirements of § 51.22 of this
chapter are not met for the Metropoli-
tan Baltimore Intrnstate Region because
adopted regulations to implement pro-
posed stationary control measures re-
ferred to in J 52.1073(d) establishing an
"emission freeze" were not submitted,
and adopted regulations to control gas
handling and dry cleaning emissions,
measures referred to in $ 52.1073(d),
were not submitted in time to be ap-
proved prior to this promulgation. Sub-
stitute regulations for gas handling and
dry cleaning emissions tire promulgated
in 5852.1101. 52.1102, and 52.1107. The
gasoline vapor recovery regulations as
promulgated specify a 90 percent reduc-
tion in emissions, thus curing the delect
noted in paragraph (d) of § 52.1081. A
substitute regulation for the emission
freeze is promulgated in { 52.1112.
§ 52.1083 Resources.
The requirements of § 51.20 of this
chapter are not met for the Metropolitan
Baltimore intrastate' region or she
Maryland portion of the National Capi-
tal interstate region because the plan
does not include a discussion of the ade-
quacy of existing State resources and
does not say whether any additional
State resources, including projections
for 5 years, will be required to carry out
any of the proposed transportation con-
trol measures..
§ 52.1084 Intergovernmental coopera-
tion.
(a) The requirements of § 51.21 of this
chapter are not met because local agen-
cies and their responsibilities in carry-
ing out transportation control measures
are not adequately identified.
§ 52.1085
[Reserved, 40 FR 16845, April 15, 197il]
§"52.1086 Gasoline transfer vapor con-
trol.
(a) "Gasoline" means any .petroleum
distillate having a Reid vapor press'ore
of 4 pounds or greater.
(b) This section is applicable in the.
Maryland portion of the National Capi-
tal Interstate AQCR.
(c) No person shall transfer gasoline
from any delivery vessel into any sta-
tionary storage container with a capac-
ity greater than 250 gallons unless ;he
displaced vapors from the storage con-
tainer are processed by a system that
prevents release to the atmosphere of no
less than 90 percent by weight of organic
compounds in said vapors displaced from
the stationary container location.
(1) The vapor recovery portion of the
system shall include one or more of the
following:
(i) A vapor-tight return line from the
storage container to the delivery vessel
and a system that will ensure that the
vapor return line is connected before
gasoline can be transferred into tie
container.
(ii) Refrigeration-condensation sys-
Environment Reporter
ISac. 52.1086(cHl)(!))]
18
-------
APPROVAL OF PLANS
S-313
125^2307
tern or equivalent designed to recover no
less than 90 percent by weight of the
organic compounds in the displaced
vapor.
(2) If a "vapor-tight vapor return"
system Is used to meet the requirements
of this section, the system shall be so
constructed as to be readily adapted to
retrofit with an adsorption system, re-
frigeration-condensation system, or
equivalent vapor removal system, and so
constructed as to anticipate compliance
with 5 52.1087 of this chapter.
(3) The vapor-laden delivery vessel
shall be subject to the following condi-
tions:
(1) The delivery vessel must be so de-
signed and maintained as to be vapor-
tight at all times.
(11) The vapor-laden delivery vessel
may be refilled only at facilities equipped
with a vapor recovery system or the
equivalent, which can recover at least 90
percent by weight of the organic com-
pounds in the vapors displaced from the
delivery vessel during refilling.
(ill) Gasoline storage compartments
of 1,000 gallons or less In gasoline de-
livery vehicles presently in use on the
promulgation date of this regulation will
not be required to be retrofitted with a
vapor return system until January 1,
.
• (d) The provisions of paragraph (c)
of this section shall not apply to the
following:
(1) Stationary containers having a
capacity less than 550 gallons used ex-
clusively for the fueling of implements
of husbandry.
(2) Any container having a capacity
less than 2,000 gallons installed prior to
promulgation of this section.
(3) Transfers made to storage tanks
equipped with floating roofs or their
equivalent.
(4) Any stationary container at any
facility where the monthly average
throughput (A of the total throughput
for the proceeding twelve months) ex-
ceeds 20,000 callons per month and
which is subject to Maryland regulation
10.03.39.04J(2) (e) (1) and (2).
[41 FR 26901, June 30, 1976)
(e) Every owner or operator of a sta-
tionary storage container or delivery ves-
sel subject to this section shall comply
with the following compliance schedule:
(1) June 1, 1974-Submit to the Ad-
ministrator a final control plan, which
describes at a minimum the steps which
will be taken by the source to achieve
compliance with the provisions of para-
graph (c) of this section.
[39 FR 4880, February 8, 1974]
(2) March 1, 1975 - Negotiate and sign
all necessary contracts for emission control
systems, or issue orders for the purchase of
component parts to accomplish emission con-
trol.
[39 FR 4880, February 8, 1974; 39 FR
41252, November 26, 1974)
(3) May 1, 1975 - Initiate on-sitc con-
struction or installation of emission control
equipment.
[39 FR 41252, November 26, 1974]
(4) February 1, 1976—Complete on-
site construction or installation of emis-
sion control equipment.
r.5) May 31, 1977. Assure final com-
pliance with the provisions of paragraph
(c) of this section.
(6) Any owner or operator of sources
subject to the compliance schedule in
this paragraph shall certify to the Ad-
ministrator, within 5 days after the
deadline for each increment of progress,
whether or not the required increment of
progress has been met.
(f) Paragraph (e) of this section shall
not apply:
(1) To a source which is presently in
compliance with the provisions of para-
graph (c) of this section and which has
certified such compliance to the .Admin-
istrator by June 1, 1974. The Administrator
may request whatever supporting information
he considers necessary foi proper certifica-
tion.
[39 FR 4880, February 8, 1974)
(2) To a source for which a-compliance
schedule is adopted by the State and ap-
proved by the Administrator.
(3) To a source whose owner or opera-
tor submits to the Administrator, by June
8-20-76
Copyright ® 1976 by The Bureou of Notional Affairs, Inc. (Sac. 52.1086(0(3)1
19
-------
125:2308
FEDERAL REGULATION
I 1974, a proposed alternative schedule.
No such schedule may provide for
compliance after March 1, 1976. Any such
schedule shall provide for certifica-
tion to the Administrator, within 5 clays
(vfter the deadline for each increment
therein, as to whether or not that incre-
ment has been met. If promulgated by
the Administrator, such schedule "shall
satisfy the requirements of this para-
graph for the affected source.
[39 FR 4880, February 8, 1974]
(g) Nothing in this section shall pre-
clude the Administrator from promul-
gating a separate schedule for any
source to which- the application of the
compliance schedule in paragraph (e)
of this section fails to satisfy the re-
quirements of § 51.15 (b) and (c) of this
chapter.
(h> Any gasoline dispensing facility
subject to this section which Installs a
storage tank after the effective date of
thlH section shall comply with the re-
quirements of paragraph (c> of this sec-
tion by May 31, 1977, and prior to that
dale snail comply with paragraph (e) of
this section as far as possible. Any facil-
ity subject to this section which installs
a storage tank after May 31, 1977. shall
coraply with the requirements of para-
grs.ph (c> of this section at the time of
installation.
[41 FR 26901, June 30, 1976]
§ 51!.1087 Control of evaporative losses
from the filling of vehicular tanks.
(a) "Gasoline" means any petroleum
distillate having a Reid vapor pressure
of «i pounds or greater.
CD) This section Is applicable in the
Maryland portion of the National
Capital Interstate AQCR.
dj) A person shall not transfer
gas aline to an automotive fuel tank from
a gasoline dispensing system unless the
transfer is made through a fill nozzle
desr.gned to:
(!) Prevent discharge of hydrocarbon
vapors to the atmosphere from either
the vehicle filler neck or dispensing
nozzle;
(2) Direct vapor displaced from the
automotive fuel tank to a system where-
in at least 90 percent by weight of the
orgimic compounds in displaced vapors
are recovered; and
C!) Prevent automotive fuel tank
overfills or spillage on fill nozzle discon-
nect.
(<1> The system referred to in para-
graph (c) of this section may consist
of e, vapor-tight return line from the fill
noz:de-filler neck Interface to the dis-
pensing tank or to an adsorption, ab-
sorption, incineration, refrigeration-
condensation system or its equivalent.
(e) Components of the systems rc^
quired by 5 52.1086 may be used
for compliance with paragraph (c) of
this section.
(f) If it Is demonstrated to the sati--
faction of the Administrator that it is
impractical to comply with the provi-
sions of paragraph (c) of this section as
a result of vehicle fill neck configura-
tion, location, or other desipTi features of
a class of vehicles, the provisions of this
section shall not apply to such vehicles.
However, in no case shall such config-
uration exempt any gasoline dispensing
''acility from installing and using in the
most effective manner a system required
oy paragraph (c) of this section.
(g) Every owner or operator of a
gasoline dispensing system subject to
this section shall comply with the fol-
lowing compliance schedule.
(1) January 1, 1975-Submit to the
Administrator a final control plan.
which describes at a minimum the steps
which will be taken by the source to
achieve compliance with the provisions
of paragraph (c) of this section.
[39 FR 4880, Feoruary 8, 1974; 39 FR
21049, June 18, 1974]
(Deferred, 40 FR 1127, January 6, 1975]
(2) March 1, 1975-Negotiate and sign
all necessary contracts for emission con-
trol systems, or issue orders for the pur-
chase of component parts to accomplish
emission control.
[39 FR 4880, February 8, 1974; 39 FR
21049, June 18, 1974]
[Deferred, 40 FR 1127, January 6, 1975]
(3) May 1, 1975-Initiate on - site
construction or installation of emission
control equipment.
[Deterred, 40 FR 1127, January 6, 1975]
(4) May 1, 1977—Complete on-site
construction installation of emission con-
trol equipment or process modification.
(5) May 31, 1977—Assure final com-
pliance with the provisions of paragraph
(c) of this section.
(6) Any owner or operator of sources
subject to the 'compliance schedule in
this paragraph shall certify to the Ad-
ministrator, within 5 days after the dead-
line for each Increment of progress,
whether or not the required Increment of
progress has been met.
(h) Paragraph (g) of this section shall
not apply:
(1) To a source which is presently-in
compliance with the provisions of para-
graph (c) of this section and which has
certified such compliance to the Admin-
istrator by January 1, 1975. The Ad-
ministrator may request whatever sup-
porting information he considers neces-
sary for proper certification.
[39 FR 4880, February 8, 1974? 39 FR
21049, June 18, 1974]
< 2) To a source for which a com pliancc
schedule is adopted by the State and ap-
proved by the Administrator.
(3) To a source whose owner or opera-
tor submits to the Administrator, by
June 1, 1974, a proposed alternative
schedule. No such schedule may provide
for compliance after May 31, 1977. Any
such schedule shall provide for certifica-
tion .to the Administrator, within 5 days
after the deadline for each increment
therein, as to whether or not that incre-
ment has been met. If promulgated by
the Administrator, such schedule shall
satisfy the requirements of this para-
graph for the affected source.
[39 FR 4880, February 8, 1974]
(i) Nothing in this section shall pre-
clude the Administrator from promul-
gating a separate schedule for any source
to which the application of the compli-
ance schedule' in paragraph (g) of this
section fails to satisfy the requirements
of § 51.15 (b) and (c) of this chapter.
(j) Any gasoline dispensing facility
subject to this section which installs a
gasoline dispensing system after the ef-
fective date of this section shall comply
with the requirements of paragraph (c)
of this section by May 31, 1977. and prior
to that date shall comply with paragraph
(g) of this section as far as possible. Any
facility subject to this section which in-
stalls a gasoline dispensing system after
May 31, 1977, shall comply with the re-
quirements of paragraph (c) of this sec-
tion at the time of installation.
§ 52.1088 Control of dry cleaning sol-
vent evaporation.
(a) Definitions:
(1) "Dry cleaning operation" means
that process by which an organic solvent
is used in the commercial cleaning of
garments and other fabric materials.
(2) "Organic solvents" means organic
materials, including diluents and thin-
ners, which are liquids at standard con-
ditions and which are used as dissolvers,
viscosity reducers, or cleaning agents.
(3) "Photochemically reactive solvent"
means any solvent with an aggregate of
more than 20 percent of its total volume
composed of the chemical compounds
classified below or which exceeds any of
the following individual percentage com-
position limitations, as applied to the
total volume of solvent.
(i) A combination of hydrocarbons,
Environmont Reporter (Sec. 52.1088(a)(3)li)]
20
-------
APPROVAL OF PLANS : MARYLAND
S-313
125:2317
periodic Inspection and maintenance of
vehicles) for emissions testing at the
time of device Installation or some other
positive assurance that the device is in-
stalled and operating correctly.
(c) After May 31. 1977, the Slate shall
not resistor or allow to operate on its
streets or highways any vehicle that does
not comply with the applicable standards
and procedures adopted pursuant to
paragraph (d) of this section.
.
[41 FR 26901, June 30, 1976]
(e) Every owner or operator of a sta-
tionary storage container or delivery ves-
sel subject to this section shall comply
with the following compliance schedule:
(1) June 1, 1974. Submit to the Ad-
ministrator a final control plan, which
describes at a minimum the steps which
will be taken by the source to achieve
compliance with the provisions of para-
graph (c) of this section.
[39 FR 4880, February 8, 1974)
(2) March J, 1975. Negotiate and sign all
necessary contracts for emission control
systems, or issue orders tor the purchase of
component parts to accomplish emission con-
trol.
(39 FR 4880, February 8, 1974; 39 VR
412S2, November 26, 19741
(3) May I, 1975. Initiate on-site construc-
tion or installation of emission control equip-
ment.
[39 FR 41252, November 26, 1974]
(4) February 1,1976. Complete on-site
construction or installation of'emissiot-
control equipment.
<5) May 31, 1977. Assure final compli-
ance with the provisions of paragraph
vc) of this section.
[41 FR 26901, June 30, 1976]
(6) Any owner or operator of sources
subject to the compliance schedule in
this paragraph shall certify to the Ad-
ministrator, within 5 dnys nfter the dead-
line for each increment of progress.
whether or not the renuircd increment
of progress has been met.
if) Para graph (e) of this section shah
not apply
(1) To a source which is presently in
compliance with the provisions of para-
graph (c) of this section and which has
certified such compliance to the Admin-
istrator by June 1, 1974. The Administrator
may request whatever supporting information
lie considers necessary lor proper certifica-
tion.
[39 FR 4880, February 8, 1974]
(2) To a source for which a compli-
ance schedule is adopted by the State
and approved by the Administrator.
(3) To a source whose owner or opera-
tor submits to the Administrator, by
June 1, 1974, a proposed alternative
schedule. No such schedule may provide
for compliance after March 1, 1976. Any
such schedule shall provide for certifi-
cation to the Administrator within 5
days after the deadline for each incre-
ment therein, as to whether or not that
increment has been met. If promulgated
by the Administrator, such schedule
shall satisfy the requirements of this
paragraph for the affected source.
[39 FR 4880, February 8, 1974]
(g) Nothing in this section shall pre-
clude the Administrator from promul-
gating1 a separate schedule for any source
to which the application of the compli-
ance schedule in paragraph (e) of this
section fails to satisfy the requirements
of ! 61.15(b) and (c) of this chapter.
(h> Any gasoline dispensing facility
subject ro this section which installs a
storage tank after the effective date of
this section shall comply with the re-
quirements of paragraph (c) of this sec-
tion by May 31, 1977, and prior to that
date shall comply with paragraph (e)
of this section as far as possible. Any
facility subject to this section which in-
stalls a storage tank after May 31, 1977,
shall comply with the requirements of
paragraph tc> of this section at the time
of installation.
(41 FR 26901, June 30, 1976]
j 52.1102 'Control of evaporative' IOMCI
from the filling of vehicular tank*.
(a) Definitions:
(1) "Gasoline" means any petroleum
8-20-76
Copyright © 1976 by The Bureau of National Affairs, Inc. [S«c. B2.1102(a)(1)J 21
-------
RECEIVED MOV 1 5
REGULATIONS
FOR THE
CONTROL AND ABATEMENT
OF
AIR POLLUTION
THIS BOOKLET CONTAINS ONE OR MORE RE-
VISIONS (AS INDICATED BELOW) TO THE REGU-
LATIONS FOR THE CONTROL AND ABATEMENT
OF AIR POLLUTION (DATED: AUGUST 9, 1975).
THE REVISION(S) IS DESIGNED TO BE POSTED
TO THE BASIC BOOK BY PAGE SUBSTITUTION.
WHEN MORE THAN ONE REVISION IS EN-
CLOSED, THEY SHOULD BE POSTED IN NUMERI-
CAL SEQUENCE TO MAINTAIN BOOK IN-
TEGRITY.
STATE AIR POLLUTION CONTROL BOARD
ROOM 1106, NINTH STREET OFFICE BUILDING
RICHMOND, VIRGINIA 23219
REVISION 3
June 11. 1976
-------
4.52 HYDROCARBON EMISSIONS
(a) General
This section shall apply to stationary sources in AQCR 7 only.
(b) Effluent Water Separators
(1) No owner or other person shall use any compartment of any single or multiple
compartment equipment designed to separate water from gasoline or other photochemically reac-
tive volatile organic compounds which compartment receives effluent water containing 200 gallons
a day or more of gasoline or other photochemically reactive volatile organic compounds from any
equipment processing, refining, treating, storing or handling gasoline or other photochemically
reactive volatile organic compounds unless such compartment is equipped with one of the following
vapor loss control devices except when gauging or sampling is taking place:
(i) A solid cover with all openings sealed and totally enclosing the liquid contents
of that compartment.
(ii) A floating pontoon or double-deck type cover, equipped with closure seals to
enclose any space between the cover's edge and compartment wall.
(Hi) A vapor recovery system which reduces the emission of all organic compound
gases into the atmosphere by at least 90 percent by weight.
(iv) Any system of an efficiency equal to or greater than paragraphs (b)(l)(i), (ii) or (iii)
of this section if approved by the Board.
(2) Paragraph (b)(l) of this section shall not apply to any effluent water separator used
exclusively in conjunction with production of crude oil, if the water fraction of the oil-water effluent
entering the separator contains less than 5 parts per million hydrogen sulfide, organic sulfides or a com-
bination thereof. •
(c) Storage of Volatile Organic Compounds
No owner or other person shall place, store or hold in any stationary tank, reservoir or other
container of more than 40,000 gallons capacity any volatile organic compound, unless such tank, reservoir
or other container is a pressure tank maintaining working pressure sufficient at all times to prevent vapor
or gas loss to the atmosphere, or is designed and equipped with one of the following vapor loss control
devices, properly installed, in good working order and in operation:
(1) A floating roof, consisting of a pontoon type or double-deck type roof, resting on the
surface of the liquid contents and equipped with a closure seal, or seals, to close the space between the
roof edge and tank wall. The control equipment provided for in this paragraph shall not be used if the vola-
tile organic compound has vapor pressure greater than 11.1 pounds per square inch absolute under actual
average storage conditions. All tank gauging and sampling devices shall be gastight except when gauging
or sampling is taking place.
(2) A vapor recovery or vapor loss control system, which reduces the emission of organic
compounds into the atmosphere by at least 90 percent by weight. All tank gauging and sampling devices
shall be gastight except when gauging or sampling is taking place.
(3) Other equipment of equal efficiency, provided such equipment is approved by the Board.
(d) Bulk Loading of Volatile Organic Compounds
(1) No owner or other person shall load volatile organic compounds into any tank truck,
trailer or railroad tank car from any loading facility unless the loading facility is equipped with a vapor
collection and disposal system or its equivalent approved by the Board.
(2) Loading shall be accomplished in such a manner that all displaced vapor and air will be
vented only to the vapor collection system. Measures shall be taken to prevent liquid drainage from the
loading device when it is not in use or to accomplish substantially complete drainage before the loading
device is disconnected.
(3) The vapor disposal portion of the vapor collection and disposal system shall consist of one
of the following:
53
-------
REVISION 3
June 11, 1976
(i) An absorber system or condensation system which processes all vapors and recovers
at least 90 percent by weight of the vapors and gases from the equipment being controlled.
(ii) A vapor handling system which directs all vapors to a fuel gas system.
(iii) Any system of an efficiency equal to or greater than paragraphs (d)(3)(i) or (ii) of
this section if approved by the Board.
(4) Paragraph (d)(l) of this section shall apply only to the loading of volatile organic com-
pounds at loading facilities from which 20,000 gallons or more of such compounds are loaded per working
day, based on a 12-month average.
(e) Gasoline Transfer Vapor Control
(1) No owner or other person shall transfer gasoline from any delivery vessel into any
stationary storage container with a capacity greater than 2,000 gallons unless such container is equipped
with a submerged fill pipe and unless the displaced vapors from the storage container are processed by a
system that prevents release to the atmosphere of no less than 90 percent by weight of organic compounds
in said vapors displaced from the stationary container location. The vapor recovery portion of the system
shall include one or both of the following:
(i) A vapor-tight vapor return line from the storage container to the delivery vessel
which shall be connected before gasoline is transferred into the container.
(ii) An absorption system or condensation system or the equivalent which processes
and recovers no less than 90 percent by weight of organic compounds in the displaced vapor.
(2) The vapor-laden delivery vessel may be refilled only at facilities equipped for 90 percent
vapor recovery in accordance with paragraph (d)(3) of this section. The delivery vessel shall be so de-
signed and maintained as to be vapor-tight at all times. For purposes of this sub-paragraph, vapor tight
shall mean capable of holding an initial 4 oz (6.9 inHzO) vacuum for 5 minutes without dropping below
2.5 oz (4.3 inH2O).
(3) The provisions of paragraphs (e)(l) and (e)(2) of this section shall not apply to the
following:
(i) Facilities whose total average gasoline through-put is less than 20,000 gallons per
month based on a 12-month average of bulk receipts.
(ii) Stationary storage containers used predominantly for refueling of mobile farm
equipment.
(iii) Transfer made to storage tanks equipped with floating roofs or their equivalent.
(4) The provisions of paragraphs (e)(l) and (e)(2) of this section shall be effective on
March 1, 1976, except that gasoline storage compartments of 1000 gallons or less in gasoline delivery
vehicles in use on February 3, 1974, will not be required to be retrofitted with a vapor return system until
January 1, 1977. Owners claiming exemption from this section under paragraph (e)(3)(i) of this section
shall submit a record of their monthly bulk receipts to the Board for the 12-month periods ending Decem-
ber 31, 1974, December 31, 1975 and thereafter if requested.
(0 Evaporation Losses From the Filling of Vehicular Tanks
(1) No owner or other person shall transfer gasoline to an automotive fuel tank from gasoline
dispensing systems unless the transfer is made through a fill nozzle designed to:
(i) Prevent discharge to the atmosphere of vapors containing organic compounds from
either the vehicle filler neck or dispensing nozzle.
(ii) Direct vapor displaced from the automotive fuel tank to a system wherein at least 90
percent by weight of the organic compounds in the displaced vapors are recovered.
(iii) Prevent automotive fuel tank overfills or spillage on fill nozzle disconnect.
(2) The system referred to in paragraph (0(1) of this section may consist of a vapor-tight
vapor return line from the fill nozzle filler neck interface to the dispensing tank or to an adsorption, absorp-
tion, incineration, refrigeration-condensation system or the equivalent. Components of the systems
required by paragraph (e) of this section may be used for compliance with paragraph (f)( 1) of this section.
54
-------
REVISION 3
June 11, 1976
(3) The provisions of paragraph (0(1) of this section shall not apply to the following:
(i) Gasoline transfers to pro-1971 model year automobiles or to other vehicles not
required to be equipped with fuel evaporative emission control systems under 40 CFR Part 85.
(ii) Facilities whose total average gasoline through-put is less than 20,000 gallons per
month, based on a 12-month average of bulk receipts.
(4) The provisions of paragraph (0(0 of this section shall be effective 18 months after the
Board has approved such systems as described in paragraph (0(2) of this section. Owners claiming
exemption from this section under paragraph (0(3)(ii) of this section shall submit a record of their monthly
bulk receipts to the Board for the 12-month period ending January 31, 1976, and January 31, 1977, and
thereafter if requested.
(g) Submerged Fill-Storage Vessel
No owner or other person shall place, store or hold in any stationary storage vessel of more
than 2,000 gallons capacity, any volatile organic compound unless such vessel is equipped to be filled
through a submerged fill pipe or is a pressure tank or is fitted with a system as described in paragraph
(c) (2) of this section.
(h) Pumps and Compressors
All pumps and compressors handling volatile organic compounds shall have mechanical
seals or other equipment of equal efficiency for purpose of air pollution control as approved by the Board.
(i) Waste Gas Disposal
(I) No owner or other person shall emit a photochemically reactive organic compound from
any plant producing ethylene for chemical feed stock, or utilizing ethylene as raw material, into the
atmosphere in excess of40 pounds per day unless the waste gas stream is properly burned at 1300°F for
0.3 seconds or greater in a direct-flame afterburner or removed by other methods of comparable efficiency.
(2) No owner or other person shall emit continuously gases of photochemically reactive
volatile organic compounds to the atmosphere in excess of 40 pounds per day from a vapor blowdown
system unless these gases are burned by smokeless flares, or an equally effective control device as ap-
proved by the Board. This section is not intended to apply to accidental, emergency or other infrequent
emissions of these gases, needed for safe operation of equipment and processes.
(j) Liquid Organic Compounds
(1) No owner or other person shall discharge more than 15 pounds of organic compounds into
the atmosphere in any one day from any article, machine, equipment or other contrivance in which any
liquid organic compound comes into contact with flame or is baked, heat-cured or heat-polymerized, in
the presence of oxygen unless such a discharge represents an overall reduction of 85 percent or greater.
(2) No owner or other person shall discharge more than 40 pounds of organic compounds
into the atmosphere in any one day from any article, machine, equipment or other contrivance used under
conditions other than described in paragraph (j)0) of this section, for employing, applying, evaporating
or drying any photochemically reactive liquid organic compounds, or material containing such compound,
unless all organic compounds discharged from such article, machine, equipment or other contrivance have
been reduced by at least 85 percent overall. The limitations prescribed in this paragraph shall not apply to
any complying industrial surface, coating, which means any paint, lacquer, varnish, ink, adhesive or other
surface coating material which emits to the atmosphere organic compounds which are not photochemically
reactive. In determining percentages for waterbase paints, the quantity of water shall be in the calculation
of percentage.
(3) Any series of articles, machines, equipment or other contrivances designed for processing
a continuously moving sheet, web, strip or wire which is subject to any combination of operations de-
scribed in paragraph (j)( I) or (j)(2) of this section involving any photochemically reactive liquid organic
compound or material containing such compound, shall be subject to compliance with paragraph (j)(2)
of this section. Where only non-photochemically reactive liquid organic compounds are employed or ap-
plied, and where any portion or portions of said series of articles, machines, equipment or other con-
55
-------
trivanccs involving operations described in paragraph (j)(0 of 'hi-s section said portions shall be collec-
tively subject to compliance with paragraph (j)(l) of this section.
(4) Emissions of organic compounds to the atmosphere from the cleanup with photochemi-
cally reactive liquid organic compounds of any article, machine, equipment or other contrivances de-
scribed in paragraph (j)(l), (j)(2) or (j)(3) of this section shall be included with the other emissions of
organic compounds from that article, machine, equipment or other contrivances for determining com-
pliance with this section.
(5) Emissions of organic compounds to the atmosphere as a result of spontaneously con-
tinuing the drying of products for the first 12 hours after their removal from any article, machine, equip-
ment or other contrivance described in paragraph (j)(l), (j)(2) or (j)(3) of this section shall be included
with other emissions of organic compounds from that article, machine, equipment or other contrivance,
for determining compliance with this section.
(6) Emissions of organic compounds into the atmosphere required to be controlled by para-
graph (j)(l), (j)(2) or (j)(3) of this section shall be reduced by:
(i) Incineration, provided that 90 percent or more of the carbon in the organic compound
being incinerated is oxidized to carbon dioxide, or
(ii) Absorption, or
|iii) Processing in a manner determined by the Board to be not less effective than para-
graphs (j)(6)(i) or (ii) of this section.
(7) ATI owner incinerating, adsorbing or otherwise processing organic compounds pursuant
to this section shall provide, properly installed, calibrated, maintained and operated, devices as specified
by the Board, for indicating temperature, pressure, rate of flow or other operating conditions necessary to
determine the degree and effectiveness of air pollution control methods.
(8) Any owner using liquid organic compounds or any materials containing liquid organic-
compounds shall upon request supply the Board in the manner and form prescribed by it, written evidence
of the chemical compositions, physical properties and amount consumed for each liquid organic com-
pound used.
(9) The provision of paragraph (j) of this section shall not apply to:
(i) The transport or storage of liquid organic compounds or materials containing liquid
organic compounds.
(ii) The use of equipment for which other requirements are specified by paragraph (b),
(c), (d). (e), (f) or (g) of this section or which are exempt from air pollution control requirements by said
paragraphs.
(iii) The spraying or application with other equipment of insecticides, pesticides or
herbicides.
(iv) The employment, application, evaporation or drying of saturated halogenated/w/ro-
carhdns or perchlorcthylcne.
(v) Development or research laboratory operation involving the use of photochemically
reactive liquid organic compounds.
(vi) The use of any material, in any article, machine, equipment or other contrivance
described in paragraph (j)(l), (j)<2)' (JX3) or Ci)(4) of this section if:
a The volatile content of such material consists only of water and liquid organic
compounds t and
/> The liquid organic compounds comprise not more than 20 percent of said volatile
content, and
c The volatile content is not photochemically reactive.
(10) Notwithstanding the above provisions, after May 31, 1974, no owner or other person
shall cause, suffer, allow or permit the use of any photochemically reactive liquid organic compound for
the purpose of drycleaning of clothing or household items.
56
-------
125:4906
APPROVAL OF PLANS: VIRGINIA
FEDERAL REGULATIONS
Bourn
I 'ilwi <'ump Corp
I .S. (iyiisuia C'o
l>0
1 .S. N'l.ry Public Works Center..
1 .*. l-lywood
riilrrrslfy of Virginia
Vnurlm Hmilluro Co
Ylill|:lin-llns«cU Furniture Co
\ iridnla Asphalt ('riving Co
Vjrplnui Foundry Co
Viiginla IIoli.-o Furniture Corp...
Vlieiiiki 1.1m* Co
Virginia Woodworking Co
XV. S. FroyCo
Washington W«i ring Co
W»nv»r Fertilizer Co.
Wfbl) Furniture Co
WeblitoCorp
WetlTnco Corp. (Chomlciil riant).
William UyrU Motor Ilotol
WondprfcnU Corp
L«c«Uoo
Franklin
Balttlllo
do
Norfolk-
South Hoslon..
Ch irlotlcsvlllo.
Oalaj
do
Itlvcrton
Itoannko .
Atkins
Klmballum
Bristol
Cluarbrook
FrlM
Norfolk
Oatai
Koanokc
Covlntfton
Klohniond
(ialai
Iteedvtlle
StaU
rqralnUon(j)
involved
1.02, 4.03, 4.)(i).
4.04.0. 40101
4.02
4.01
4.07
4.04
4.M.01(b)(0)
4.02
4.02,4.01....
4.02, 4.04.01
.
4.04.0ljb>(3>.
4!w.oVfbV(ll)""
4.04.4.07
4.03.01,4.02.01...
4.03....
4.04
I) ate of
Adoption
. Juno 17, 1074
Juno HO, 1U74
Juno 27,1071
Jan. 0,1075
Juno 20, 1"74
Sept. 5,11174
Juno 19, i;i74
Jan. 8, 1075
Juno 20, l',C4
Jan. 7, 1070
Juno 20, If 74
Juno 19,1074
Juno 21,1074
Nov. 1. 1974
Juno 28, 1074
Oct. 30,1071
Juno 27,1074
.....do
July 1. 1074
Oct. 30,1074
June 25. 1974
EfTrclln
dale
do...
do
do. . .
. ...do.
. ...do.
. ...do.
. ...do.
. ...do.
do
do
do
do
do
d»
do
(In
do
do
do
do
do
Hnal
compllunrt
ditto
June 30, 1075
Apr. 30. 1075
3nn» 30, 1'.'7S
Mar. 30, Ki7.'i
Juno 30, 1V7.1
Apr. 3d. W7S
Muy »i, 1'J7S
Juno 30.1075
Apr. M. 11173
June 30. IMS
Apr. 30, 197 5
Jun* 30,1073
Do.
Juno 30,1075
Apr. 30,1074
Juno !M),1'.>7S
Do.
Do.
June 15,1073
June 30.1073
Mar. 15,1075
June 30, 107»
§ 52.2136 Rules anil regulations.
(a) The requirements of § 51.22 are not
met because regulations have not been
adopted and submitted for the stationary
source measures aimed at reducing gaso-
line handling and dry cleaning losses.
Substitute regulations are promulgated
In Si 52.2438, 52.2439, and 52.2440.
§ 52.2437 [Reserved, 40 FR 16845. April 8,
1975 J
§ 52.2438
irol.
Caroline transfer vapor con-
"Gasoline" means any petroleum
distillate having a Reid vapor pressure
of 4 pounds or greater.
^/ No person shall transfer gasoline
from any delivery vessel into any station-
ary storage container with a capacity
greater than 250 gallons unless the dis-
placed vapors from the storage container
[40 FR 33450, August 8, 1975]
are processed by a system that prevents
release to the atmosphere of no less thai.
90 percent by weight of organic com-
pounds in said vapors displaced from the
stationary container location.
(1) The vapor recovery portion of the
system shall Include one or more of the
following:
(1) A vapor tight return line from the
storage container to the delivery vessel
and a system that will ensure that the
vapor return line Is connected before
gasoline can be transferred into the con-
tainer.
(11) Refrigeration-condensation sys-
tem or equivalent designed to recover no
less than 90 'percent by weight of the or-
ganic compounds in the displaced vapor.
(2) If a "vapor-tight vapor return"
system Is used to meet the requirements
of this section, the system shall be so
constructed as to be readily adapted to
retrofit with an adsorption system,
refrigeration-condensation system, or
equivalent vapor removal system, and so
constructed as to anticipate compliance
with § 52.2439.
(3) The vapor-laden delivery vessel
shall be subject to the following condi-
tions:
(i) The delivery vessel must be so de-
signed and maintained as to be vapor-
tight at all times.
(11) The vapor-laden delivery vessel
may be refilled only at facilities equipped
with vapor recovery systems or the equiv-
alent, which can recover at least 90 per-
cent by weight of the organic compounds
In the vapors displaced from the delivery
vessel during refilling.
(ill) Gasoline storage compartments
of one thousand gallons or less in gaso-
line delivery vehicles presently In use on
the promulgation date of this regulation
will not be required to be retrofitted with
a vapor return system until January 1,
1977.
(d) The provisions of paragraph (e) of
this section shall not apply to the fol-
lowing:
Environment Reporter
[Sec. 52.2438(d))
208
-------
APPROVAL OF PLANS
S-281
125:4907
(1) Stationary containers having a
capacity less than 550 gallons used ex-
clusively for the fueling of implements of
husbandry.
(2) Any container having a rapacity
less than 2,000 Rations installed prior to
promulgation of this .section.
(3) Transfers made to storage tanks
equipped with floating roofs or their
equivalent.
(e) Every owner or operator of a sta-
tionary storage container or delivery ves-
sel subject to this section shall comply
with the following compliance schedule:
(1) June 1, 1974 -Submit to the Ad-
ministrator a final control plan, which
describes at a minimum the steps which
will be taken by the source to achieve
compliance with the provision.1? of para-
graph (c) o_f this section.
[39 FR 4880, February 8, 1974|
(2) May 1, 1975 - Negotiate and si?n all
necessary contracts for emission control
systems, or issue orders for the purchase of
component parts to jcconiplish emission con-
trol.
(39 FR 4880, February 8, 1974; 39 FR
41252, November 26. 1974|
(3) May 1, 1975 - Initiate on-sile con-
struction or installation of emission control
equipment.
[39 FR 41252, November 26, 1974J
(4) February 1, 1976—Complete on-
Slte construction or installation of emis-
sion control equipment.
(5.' March 1, 1976—Assure final com-
pliance with the provisions of paragraph
of this section.
(6) Any owner or operator of sources
subject to the compliance schedule in
this paragraph shall certify to the Ad-
ministrator, within 5 days after the dead-
line for each increment of progress,
whether or not the required increment of
progress has been met.
(f) Paragraph (e) of this section shall
not apply:
(1) To a source which is presently in
compliance with the provisions of para-
graph (c) of this section and which has
certified such compliance to the Adminis-
trator by June 31, 1974. The Administrator
may request whatever supporting information
he considers necessary for proper certi-
fication.
[39 FR 4880, February 8, 1974]
(2) To a source for which a compliance
schedule is adopted by the State and ap-
proved by the Administrator.
(3) To a source whose owner or op-
erator submits to the Administrator, by
June 31, 1974, a proposed alternative
(schedule. No such schedule may i>ro-
•vide for compliance after March 1, 1976.
Any such schedule shall provide for cer-
tification to the Administrator, within 5
days after the deadline for each Incre-
ment therein, as to whether or not that
increment has been met. If promulgated
by the Administrator, such schedule shall
satisfy the requirements of this para-
graph for the affected source,
[39 PR. 4880. February 8, 1974)
Nothing in this section shall pre-
clude the Administrator from promul-
gating a separate schedule for any source
to which the application of the compli-
ance schedule in paragraph (e) of this
section fails to satisfy the requirements
of § 51.15 (b) and (c) of this chapter.
(h) Any gasoline dispensing facility
subject to this section which installs a
storage tank after the effective date of
tliis section shall comply with the re-
quirements of paragraph (c) of this sec-
tion by March I. 1976, and prior to that
date shall comply with paragraph (e) of
this section as far as possible. Any facil-
ity subject to this section which installs
a storage tank after March 1, 1976, shall
comply with the requirements of para-
graph (c) of this section at the time of
installation.
§ 52.2439 Control of evaporative losses
from the filling of vehicular tanks.
(a) "Gasoline" means any petroleum
distillate having a Reid vapor pressure of
4 pounds or greater.
(b) This section is applicable in the
Virginia portion of the National Capital
Interstate AQCR.
(c) A person shall not transfer gaso-
line to an automotive fuel tank from a
gasoline dispensing system unless the
transfer is made through a flll nozzle de-
signed to:
(1) Prevent discharge of hydrocarbon
vapors to the atmosphere from either the
vehicle filler neck or dispensing nozzle;
(2) Direct vapor displaced from the
automotive fuel tank to a system where-
in at least 90 percent by weight of the
organic compounds in displaced vapors
are recovered; and
(3> t-revent automotive luel tank
overfills or spillage on fill nozzle discon-
nect.
(d) The system referred to in para-
graph (c) of this section may consist of
a vapor-tight return line from the flll
nozzle-filler neck interface to the dis-
pensing tank or to an adsorption, ab-
sorption, incineration, refrigeration-con-
densation system or its equivalent.
(e) Components of the systems re-
quired by § 52.2439 may be used for com-
pliance with paragraph (c) of this sec-
tion.
(f) If it is demonstrated to the satis-
faction of the Administrator that it is
impractical to comply with the provisions
of paragraph (c) of this section as a re-
sult of vehicle fill neck configuration,
location, or other design features of a
class of vehicles, the provisions of this
section shall not apply to such vehicles.
However, in no case shall such config-
uration exempt any gasoline dispensing
facility from installing and using in the
most effective manner a system required
by paragraph (c) of this section.
(g) Every owner or operator of a cas-
oline dispensing system subject to this
section shall comply with the following1
compliance schedule:
(1) June I, 1974-Submit to the Adminis-
trator a final control plan, which describes at
a minimum the steps which will be taken by
the source to acnieve compliance with the
provisions of paragraph (c) of this section.
(39 FR 4880, February 8, 1974)
[Deferred, 40 FR 1127, January 6, 1975]
(2) November 1, I 974-Ncgotiate and si«n
all necessary contracts for emission control
systems, or issue orders for the purchase of
component parts to accomplish cnu'ssiou con-
tro1' [39 FR 4880, February 8, 1974]
[Deferred, 40 FR 1127, January 6, 1975]
<3) January 1, 1975—Initiate on-site
construction or installation of emission
control equipment,
[Deferred, 40 FR 1127, January 6, 1975]
(4) May l, 1977—complete on-site con-
struction installation of emission con-
trol equipment or process modification.
(5) May 31. 1977—Assure final com-
pliance with the provisions of paragraph
(c) of this section.
(6) Any owner or operator of sources
•subject to the compliance schedule in this
paragraph shall certify to the Adminis-
trator, within 5 days alter the deadline
for each increment of prograss, whether
or not the required increment of prog-
ress has been met.
(h) Paragraph (g) of this section shall
not apply:
<1) To a source which Is presently Jn
compliance with the provisions of para-
graph (c) of this section and which has
certified such compliance to the Admin-
istrator by June 31, 1974. Die Administrator
may request whatever supporting inforniation
he considers necessary for proper certification.
[39 FR4880, February 8, 1974J
(2) To a source for which a compliance
schedule is adopted by the State and
approved by the Administrator.
(3) To a source whose owner or opera-
tor submits to the Administrator, by
June 31, 1974, a proposed allernativc
schedule. No. such schedule may provide for
compliance after May 31, 1977. Any such
12-19-75
Copyright C 1975 by The Bureau of National Affairs, Inc.
[Sec. 52.2439(h)(3)l
209
-------
APPENDIX C
VAPOR RECOVERY REGULATIONS EFFECTIVE
IN HOUSTON/GALVESTON AQCR
-------
REGULATION V
CONTROL OF AIR POLLUTION FROM
VOLATILE CARBON COMPOUNDS
Rule 501. Regulation V shall apply only in the following counties:
Aransas, Bexar, Brazoria/ Calhoun, Dallas, El Paso,
Galveston, Harris, Jefferson, Matagorda, Montgomery,
Nueces, Orange, San Patricio, Travis and Victoria.
Rule 502. Storage of Volatile Carbon Compounds.
502.1 No person shall place, store, or hold in any stationary tank,
reservoir, or other container of more than 25,000 gallons
capacity any volatile carbon compounds unless such tank,
reservoir, or other container is a pressure tank capable of
maintaining working pressures sufficient at all times to
prevent vapor or gas loss to the atmosphere or is designed
and equipped with one of the following vapor loss control
devices:
502.11 A floating roof, consisting of a pontoon type,
double deck type roof, or internal floating
cover, which will rest on the surface of the
liquid contents and be equipped with a closure
seal or seals to close the space between the
roof edge and tank wall. This control equipment
shall not be permitted if the volatile carbon
compounds have a vapor pressure of 11.0 pounds
per square inch absolute or greater under actual
storage conditions. All tank gauging and sampling
devices shall be gas-tight except when gauging or
sampling is taking place.
502.12 A vapor recovery system which reduces the emissions
such that the aggregate partial pressure of all
volatile carbon compound vapors in vent gases or
other material emitted to the atmosphere will not
exceed a level of 1.5 psia.
502.2 No person shall place, store, or hold in any new stationary
storage vessel of more than 1,000 gallons capacity, any
volatile carbon compound unless such vessel is equipped
with a permanent submerged fill pipe or is a pressure tank
as described in 502.1 or is fitted with a vapor recovery
system as described in 502.12.
V-l
-------
502.3 Crude oil or condensate storage containers are exempt from
Rule 502.
Rule 503.
503.1
503.2
Rule 504.
504.1
Volatile Carbon Compounds Loading and Unloading Facilities.
No person shall permit the loading or unloading of volatile
carbon compounds from any loading facility having 20,000
gallons or more throughput per day, averaged over any 30-day
period, unless such facility is equipped with a vapor recovery
system which reduces the emissions such that the aggregate
partial pressure of all volatile carbon compound vapors in
vent gases or other material emitted to the atmosphere will
not exceed a level of 1.5 psia.
When loading or unloading is effected through the hatches of
a tank truck or trailer or railroad tank car with a loading
arm equipped with a vapor collecting adaptor, then pneumatic,
hydraulic, or other mechanical means shall be provided to
force a vapor-tight seal between the adaptor and the hatch.
A means shall be provided to prevent liquid drainage from
the loading device when it is removed from the hatch of any
tank truck, trailer or railroad tank car, to accomplish
complete drainage before such removal. When loading or
unloading is effected through means other than hatches, all
loading and vapor lines shall be equipped with fittings which
make vapor-tight connections and which close automatically
when disconnected or equipped to permit residual volatile
carbon compounds in the loading line to discharge into a
recovery or disposal system after loading is complete.
All loading or unloading facilities for crude oil or
condensate and for ships and barges are exempt from Rule 503.
Volatile Carbon Compound - Water Separation.
No person shall use any compartment of any single or multiple
compartment volatile carbon compound water separator which
compartment receives 200 gallons or more of volatile carbon
compounds a day from any equipment which is processing, re-
fining, treating, storing, or handling volatile carbon com-
pounds unless such compartment is controlled in one of the
following ways:
504.11 The compartment has all openings sealed and totally
encloses the liquid contents. All gauging and
sampling devices shall be gas-tight except when
gauging or sampling is taking place.
-------
APPROVAL OF PLANS
S-281
125:4603
§ 52.2282 Public lirarinps.
(a) The requirements of § 51.4 of this
chapter nre not met because principal
portions of the revised plan were not
made available to the public for inspec-
tion and comment prior to the hearing.
§ 52.2283 Control of volatile carbon
compounds*
(a) The requirements of Texas Air
Control Board Regulation V are Incor-
porated herein by reference and Rule 501
of that Regulation is amended to in-
clude (in addition to those counties
named therein) Bell, McLennan, Hardin,
and Tarrant Counties in Texas.
(b) Except as provided in paragraph
(c) of this section, the owner or opera-
tor of a source subject to paragraph (a)
of this section shall comply with the in-
crements contained in the following com-
pliance schedule.
(1) Contracts for emission control
systems or process modifications must be
awarded or orders must be issued for
the purchase of component parts to ac-
complish emission control or process
modification not later than March 31,
1974.
(2) Initiation of on-site construction
or Installation of emission control equip-
ment or process change must begin not
later than July 31,1974.
(3) On-slte construction or Installa-
tion of emission control equipment or
process modification must be completed
not later than March 31. 1975.
(4) Final compliance is to be achieved
not later than May 31,1975.
(5) Any owner or operator of station-
ary sources subject to the compliance
schedule in this paragraph shall certify
to the Administrator, within five days
after the deadline for each increment
of progress, whether or not the required
increment of progress has been met.
• (c) Paragraph (b) of this section
shall not apply:
(1) To a source which is presently In
compliance with paragraph (a) of this
section and which has certified such
compliance to the Administrator by De-
cember 1, 1973. The Administrator may
request whatever supporting information
he considers necessary for proper
certification.
(2) To a source for which a compliance
schedule Is adopted by the State and
approved by the Administrator.
(3) To a source whose owner or opera-
tor submits to the Administrator, by De-
cember 1, 1973 a proposed alternative
schedule. No such schedule may provide
for compliance after May 31. 1975. If ap-
proval is promulgated by the Adminis-
trator, such schedule shall satisfy the
requirements of tills section for the af-
fected source.
(d) Nothing in this section shall pre-
clude the Administrator from promul-
gating a separate schedule for any source
to which the application of the com-
pliance schedule in paragraph (b) of this
section fails to satisfy the requirements
of § 51.15 (b) and (c) of this chapter.
§ 52.2281 Control of dogroasing opera-
tions.
(a) Definitions:
(1) "Decreasing" means the operation
of using an organic solvent as a surface
cleaning agency.
(2) "Organic solvents" Include dilu-
ents and thlnners and are defined as
organic materials which are liquid at
standard conditions and which are used
as dissolvers, viscosity reducers, or clean-
ing agents.
(3) "Organic material" means a
chemical compound of carbon excluding
carbon monoxide, carbon dioxide, car-
bonic acid, metallic carbides, metallic
carbonates, and ammonium carbonate.
(4) "Photochemically reactive sol-
vent" means any solvent with an aggre-
gate of more than 20 percent of its total
volume composed of the chemical com-
pounds classified below, or which ex-
ceeds any of the following individual
percentage composition limitations, as
referred to the total volume of solvent.
(1) A combination of hydrocarbons,
alcohols, aldehydes, esters, ethers, or
ketones having an oleflnic or cyclooleflnic
type of unsaturation: 5 percent.
(ii) A combination of aromatic com-
pounds with 8 or more carbon atoms to
the molecule except ethylebenzene: 8
percent.
(Ill) A combination of ethylbenzene,
ketones having branched hydrocarbon
structures, trichloroethylene, or tolu-
ence: 20 percent.
(b) This section is applicable in The
Houston-Galveston and San Antonio
Intrastate Air Quality Control Regions
in the State of Texas.
Cc) The following are exempt from
the requirements of paragraph (d) of
this section.
(1) Degreasing operations which emit
less than 3 pounds per hour and less than
15 pounds per day of uncontrolled or-
ganic materials.
(2) Degreasing operations which use
perchloroethylene, 1, 1,1-trl-chloroeth-
ane, or saturated 'haloRcnated hydro-
carbons as an organic solvent.
(d) No person shall use for degrcnsiiiR
any photochcmically reactive solvent
unless the uncontrolled orgnnic emis-
sions from such operation are controlled.
at least 85 percent overall.
(e) Any owner or operator of a de-
creasing operation who elects to switch
use of solvents to one or more of the
solvents exempt under paragraph (c) (2)
of this section shall specify intent to the
Administrator no later than January 1,
1974. Such a solvent switch shall be
made no later than May 31, 1974.
(f) Except as provided in paragraph
Xg) of this section the owner or operator
of any degreasing operation subject to
the requirements of paragraph (d) of
this section shall comply with the follow-
ing compliance schedule:
(1) January 1, 1974—Submit to the
Administrator a final control plan which
describes at a minimum, steps which will
be taken by the owner or operator to
achieve compliance with the require-
ments of paragraph (d) of tills section.
(2) March 1,1974—Negotiate and sign
all necessary contracts for emission con-
trol systems or process modifications, or
issue orders for the purchase of compo-
nent parts to accomplish emission control
or process modification.
(3) July 1, 1974—Initiate on-site con-
struction or installation of emission con-
trol equipment or process modification.
(4) May 1, 1975—Complete on-site
construction or installation of emission
control equipment or process modifica-
tion.
(5) May 31, 1975—Achieve final com-
pliance with the requirements of para-
graph (d) of this section.
(6) Any owner or operator of a de-
greasing operation subject to the com-
pliance schedule in this paragraph shall
certify to the Administrator within five
days after the deadline for each incre-
ment of progress, whether or not the
required Increment of progress has been
met.
(g) Paragraph (f) of this section shall
not apply to:
'(!•) A degreasing operation which is
presently in compliance with the require-
ments of paragraph (d) of this section
and which has certified such compliance
to the Administrator by January 1, 1974.
The Administrator may request whatever
supporting Information he considers
necessary for proper certification.
(2) A degreasing operation for which
a compliance schedule is adopted by the
12-19-75
Copyright © 1975 by The Bureau of National Affairs, Inc. [Sec. 52.2284(g)(2))
181
-------
125:4604
FEDERAL REGULATIONS
State and approved by the Adminis-
trator.
(3) A degreasing operation whose
owner or operator submits to the Admin-
istrator, by January 1. 1974. a proposed
alternative schedule. No such schedule
may provide for compliance after May 31,
1975. If promulgated by the Administra-
tor, such schedule shall satisfy the re-
quirements of this section for the
affected degrcasing operation.
(h) Nothing in this section shall pre-
vent the Administrator from promulgat-
ing a separate schedule tor any degreas-
Ing operation to which the application
of the compliance schedule in paragraph
(f) of this section fails to satisfy the
requirements of § 51.15 (b) and (c) of
this chapter.
(1) Any person subject to this regula-
ton who begins a degreasing operation
after the effective date of this regulation
shall comply with the requirements of
paragraphs (c), (d), and (e) of this sec-
tion. Any degreasing operation subject
to this regulation which begins opera-
tion after May 31, 1975, shall "comply
with the requirements of paragraphs (c)
.and (d) of this section at the time such
operation begins.
§ 52.2285 Control of evaporative losses
from the filling of storage vessels by
1976.
(a) Definitions:
(1) "Gasoline" means any petroleum
distillate having a Reid vapor pressure
of four pounds or greater.
(2) "Storage vessel" means any sta-
tionary vessel of more than 1,000 gallons
(3,800 liters) capacity.
(b) This section is applicable within
the Houston-Galveston, Dallas-Port
Worth, and San Antonio Intrastate Air
Quality Control Regions in Texas.
(c) No person shall transfer gasoline
from any delivery vessel into any station-
ary storage container with a capacity
greater than 1,000 gallons unless such
container is equipped with a submerged
fill pipe and unless the displaced vapors
from the storage container are processed
by a system that prevents release to the
atmosphere of no less than 90 percent
by weight of organic compounds in said
vapors displaced from the stationary
container location.
(1) The vapor recovery portion of the
system shall include one or more of the
following:
-------
APPROVAL OF PLANS
S-281
125:4605
(b) This section Is applicable within
the Austin-Waco Intrastatc and the
Texas portion of the El Paso-La,s Cruces-
Alamagordo Interstate Air Quality Con-
trol Rceions in the State of Texas.
(c) No person shall transfer gasoline
from any delivery vessel into any station-
ary storage container with a capacity
greater than 1,000 gallons unless such
container Is equipped with a submerged
fill pjpe and unless the displaced vapors
from the storage container are processed
by a system that prevents release to the
atmosphere of no less than 90 percent by
weight of organic compounds in said vap-
ors displaced from the stationary con-
tainer location.
(1) The vapor recovery portion of the
system shall include one or more of the
following:
li) A vapor-tight return line from the
storage container to the delivery vessel
and a system that will ensure that the
vapor return line is connected before
gasoline can be transferred into the con-
tainer.
(ii) Refrigeration-condensation sys-
tem or equivalent designed to recover no
less than DO percent by weight of the
organic compounds in the displaced
vapor.
(2) If a "vapor-tight vapor return"
system is used to meet the requirements
of this section, the system shall be so
constructed as to be readily added on to
retrofit with an adsorption system,
refrigeration-condensation system, or
equivalent vapor removal system, and so
constructed as to anticipate compliance
with 5 52,2288.
(3) The vapor-laden delivery vessel
shall be subject to the following condi-
tions:
(1) The. delivery vessel must be so de-
signed and maintained as to be vapor-
tight at all times.
(11) The vapor-laden delivery vessel
may be refilled only at facilities equipped
with a .vapor recovery system or the
equivalent, which can recover at least 90
percent by weight of the organic com-
pounds in the vapors displaced from the
delivery vessel during refilling.
(ill) Gasoline storage compartments of
one thousand gallons or less in gasoline
delivery vehicles presently in use on the
promulgation date of this regulation will
not be required to be retrofitted with a
vapor return system until January 1.
1076.
(d) The provisions of paragraph (c) of
this section shall not apply to the fol-
lowing:
(1) Stationary containers used exclu-
sively for the fueling of implements of
husbandry.
(2) Any container having a capacity
less than 2,000 gallons installed prior to
promulgation of this section.
(3) Transfers made to storage tanks
equipped with floating; roofs or their
equivalent.
(e) Except as provided in paragraph
(f) of this section, the owner or operator
of a source subject to paragraph (c) of
this section shall comply with the incre-
ments contained in the following com-
pliance schedule:
(1) Contracts for emission control sys-
tems or process modifications must be
awarded or orders must be issued for the
purchase of component parts to accom-
plish emission control or process modi-
fication not later than July 1, 1974.
[39 FR 4880, February 8, 1974]
(2) Initiation of on-site construction or
installation of emission control equip-
ment or process change must begin not
later than September 1, 1974.
[39 FR 4880, February 8, 1974]
(3) On-site construction or installa-
tion of emission control equipment or
process modification must be completed
not later than April 30, 1975.
[39FR4880, February 8, 1974]
(4).Final compliance Is to be achieved
not later than May 31,1975.
(5) Any owner or operator of station-
ary sources subject to the compliance
schedule In this paragraph shall certify
to the Administrator, within, five days
after the deadline for each increment of
progress, whether or not the required In-
crement of progress has been met.
(f) Paragraph (e) of this section shall
not apply:
(1) To a source which is presently in
compliance with paragraph (c) of this
section and which has certified such
compliance to the Administrator by May 1,
1974. The Administrator may request what-
ever supporting information he considers
necessary for proper certification.
[39 FR 4880, February 8, 1974]
(2) To a source for which a compliance
schedule is adopted by the State and ap-
proved by the Administrator.
(3) To a source whose owner or opera-
tor submits to the Administrator by May 1,
1974, a proposed alternative schedule. No
such schedule may provide for compliance
after May 31, 1975. If approval is promul-
gated by the Administrator, such schedule
shall satisfy the requirements of this section
for the affected source.
[39 FR 4880, February 8, 1974]
(g) Nothing in this section shall pre-
clude the Administrator from promul-
gating a separate schedule for airy source
to which the application of the compli-
ance schedule in paragraph (e) of this
section fails to satisfy the requirements
of § 51.15 (b) and (c) of this chapter.
(h) Any gasoline dispensing facility
subject to this regulation which installs
a storage tank after the effective date of
this regulation shall comply with the re-
quirements of paragraphs (c) and (e) of
this section. A facility subject to this
regulation which installs a storage tank
after May 31, 1975 shall comply with the
requirements of paragraph (c) of this
section at the time of installation.
§ 52.2287 Ship and barge loading and
unloading facilities.
(a) Rule 503.2 of the Texas Air Con-
trol Board Regulation V as incorporated
by reference on May 31, 1972 (37 PR
10842) is amended to read: "All loading
and unloading facilities for crude oil or
condensate are exempt from Rule 503."
This amendment eliminates an exemp-
tion for ships and barges.
(b) This section Is applicable to ships
and barges which use the port facilities
within the Houston-Galves'ton Intrastate
Region.
(c) Except as provided in paragraph
(d) of this section, the owner or opera-
tor of a source subject to paragraph (a)
of this section shall comply with the in-
crements contained in the following
compliance schedule.
ISubparagraphs (1) through (3) suspended
40 FR 18437, April 28, 1975; Subparagraph
(4) suspended, 40 FR 24185, June 5, 1975]
(1) Contracts for emission control sys-
tems or process modifications not later
than March 31, 1974.
(2) Initiation of on-site construction
or installation of emission control equip-
ment or process change must begin not
later than July 31,1974.
(3) On-site construction or installa-
tion of emission control equipment or
process modification must be completed
not later than March 31,1975.
(4) Final compliance is to be achieved
not later than May 31,5975.
(5) Any owner or operator of station-
ary sources subject to the compliance
schedule in this paragraph shall certify
to the Administrator, within five days
after the deadline for each increment
of progress, whether or not the required
increment of progress has been met.
12-19-75
Copyright © 1975 by The Bureau of National Affairs, Inc.
(Sec. 52.2287(c)(5)J 183
-------
1078
ENVIRONMENT REPORTER
Environmental Protection Accncy. Region VI,
1201 Elm Street. Dallas, Texas 70270.
Environment*! Protection Apcncy. Houston
Fnclltty, CC08 Hornwood, IIox\ston, Texas
77030.
Environmental Protection A(jcncy, Public In-
formation Reference Unit. Room 2922, EPA
Library. 401 "M" Street, SW.. Washington,
D.C. 20160.
City of San Antonio, Main Library, Business
and Science Department, 203 South St.
Marys. San Antonio. Texas 78205.
In addition, the complete record will
be available for public inspection at the
Dallas. Texas and Washington, D.C.
locations.
This notice of proposed rulemaking Is
Issued under the authority of sections
110(c) and 301 (a) of the Clean Air Act
(42 U.S.C. 1857c-5(c) and 1857g).
Dated": October 21. 197G.
JOHN C. WHITE,
Regional Administrator, Region VI,
Environmental Protection Agency.
It Is proposed to amend Subpart SS,
Texas, of Part 52 of Chapter I. Title 40,
of the Code of Federal Regulations as
follows:
1. Section 52.2270, paragraph (c), Is
amended to add item (9) as follows:
§ 52.2270 Identification of Dun.
(C) • * *
19) Revisions to Texas Air Control
Board (TACB) Regulation IV (Control
' of Air Pollution from Motor Vehicles)
were adopted by the TACB on October 30,
1973 and submitted by the Governor on
December 11, 1973.
2. Section 52.2272 is revised to read as
follows:
g 52.2272 Extensions.
(a) The Administrator hereby extends
the attainment dates for the national
standards for photochemical oxidants
(hydrocarbons) to May 31, 1077, in the
following Air Quality Control Regions as
defined in Part 81 of this chapter: Aus-
tin-Waco, Corpus Christt-Victoria, Met-
ropolitan Dallas- Port Worth. Metropoli-
tan Houston-Oalveston, Metropolitan
San Antonio Intrastatc, the Texas por-
tion of the El Paso-Las Cruecs-Alamo-
gordo Interstate, and the Texas portion
of the Southern Louisiana-Southeast
Texas Interstate.
3. Section 52.2275 is revised to read as
follows:
g 52.2275 Control Slrnt<: I'liolo-
clicmiriil OxiclunU (hydrocarbons).
(a) The requirements'of ?51.14fa) of
this chapter tire not met since the plan
EUbmittcd by the State does not provide
the decree of hydrocarbon emission re-
duction necessary to attain and maintain
the national ambient air finality stand-
ard for photochemical oxidants (hydro-
carbons) as expeditiously as practicable
in the following air quality control re-
gions: Austin-Waco, Corpus ChrisU-Vic-
toria, Metropolitan Dallas-Fort Worth,
Metropolitan IIouston-Galvcston, and
Metropolitan San Antonio Intrastate
Regions; the Texas portions of the El
Paso-Lns Cruccs-Alnmonordo and South-
cm Louisiana-Southeast Texas Inter-
state Regions.
§ 32.2279 [Amended)
4. In 5 52.2279, the attainment date
table is amended, by revising the last
column "Photochemical oxidants (hydro-
carbons)" to read as follows with the
corresponding first column "Air quality
control region";
Air Duality control rt-eiou
I'liotorhomicul
oxlikiuts
(hydrocarbons)
Ablloiit-Wiehltt. Falls Itilra- ••• (a).
stale.
Aumillo-I,ul>bock Intrastafc... ••• Do.
Austm-Wnco Intrnstule **' May 31,10T7.
Jlrownsvillo-Lnrpdolnlrastnte., *** (a).
Corpus Chrisil-Vlctorla Inlra- •••„.. May 31, 1577.
slillt1.
Midlimcl - Odessa - San Angclo "• (a).
Imrosiatc.
Metropolitan Houston-Calve:- •"..., May31,1977.
tor. liitroslal*.
Mc'ropjlilan Dallas-Fort Woilh ••• Do.
Intr.ulate.
Mutro|>oUtan San Antonio In- •".... Do.
trastato.
Southern Loufelana-Southcsal ••• Do.
Trans Interstate.
El Piiso - Las Craves • Aljnun ••• I>o.
Kordo Interstate.
Shrovi'porl • Tmartano • Tyler "•— (n).
5. In ! 52.2283 paragraphs (a) and (c)
are revised to read as follows:-
§ 52.2283 Control of volmilc rnrlion
compounds.
(a) All requirements of Texas Air Con-
trol Board Regulation V (as adopted on
April 10, 1973) shall apply in Hardin and
Tarrant Counties in Texas. The said Reg-
ulation has already been approved as a
requirement of the applicable implemen-
tation plan for the counties specifically
named therein.
• • * • •
ic) Paragraph (b) of this section shall
not apply to the owner or operator of:
(1) A source which is presently In
compliance with paragraph (a) of this
section and which has certified such com-
pliance to the Regional Administrator by
December 1, 1973. The Regional Admin-
istrator may request whatever support-
ing information he considers necessary
for proper certification.
(2) A source for which a compliance
schedule is adopted by the State and ap-
proved by the Administrator.
(3) A source whose owner or operator
receives approval from the Administra-
tor, by December 1, 1973 of a proposed
alternative schedule. No such schedule
may provide for compliance after May 31,
1975. If approval is promulgated by the
Administrator, such schedule shall sat-
isfy the requirements of this section for
the affected source.
6. Section 52.2285 Is revised to read as
follows:
§ 52.22i!5 Control of rv4t|ior;ilivc los*c»
from llic lillins of (jjiMilinc Morale
VCSM-IS in llic llouMoii ninl Sim An-
tonio nrrn».
(a) Definitions. (1) "Gasoline" means
any petroleum distillate having a Reid
vapor pressure of 4 pounds or greater
which is produced for use as a motor
fuel nnd is commonly called Gasoline.
(2) "Storase container" means any
stationary vessel of more than 1.000 gal-
lons (3,785 liters) capacity. Stationary
vessels include portable vessels placed
temporarily at a location; e.g., tanks on
skids.
(3) "Owner" means the owner of the
gasoline storage container(s).
(4) "Operator" means the person who
is directly responsible for the operation
of the gasoline storage container(s),
whether the person be a lessee or an
agent of the owner.
(5) "Delivery Vessel" means tank
trucks and tank trailers used for the
delivery of gasoline.
(6) "Source" means both storage con-
tainers and delivery vessels.
(b) This section is applicable to the
following counties in Texas: Harris. Gal-
veston, Brazoria, Port Bend. Waller,
Montgomery. Liberty. Chambers, Mata-
gorda, Bexar, Comal, and Guadalupe.
(c) No person shall transfer or permit
the transfer of gasoline from any deliv-
ery vessel into any stationary storage
container with a capacity greater than
1,000 gallons (3.785 liters) unless such
container is equipped with a submerged
nil pipe and unless the displaced vapors
from the storage container are processed
by a system that prevents release to the
atmosphere of no less than 90 percent by
weight of total hydrocarbon compounds
in said vapors.
(1) The vapor recovery system shall
include one or more of the following:
(i) A vapor-tight line from the stor-
ace container to the delivery vessel and
a system that will ensure that the vapor
return line is connected before gasoline
can be transferred Into the container.
(11) Other equipment that prevents
release to the atmosphere of no less than
90 percent by weight .of the total hydro-
carbon compounds in the displaced vapor
provided that approval of the proposed
design, installation, and operation is ob-
tained from the Regional Administrator
prior to start of construction.
12) The vapor recovery system shall be
so constructed that it will be compatible
with a vapor recovery system, which may
be installed later, to recover vapors dis-
placed by the filling of motor vehicle
tanks.
(3) The vapor-laden delivery vessel
shall meet the following requirements:
(I) The delivery vessel must be so de-
signed and maintained as to be vapor*
tight at all times.
(ii) If nny gasoline storage compart-
ment of n vapor-laden delivery vessel la
refilled in one of the counties listed in
paragraph (b) of this section, it shall be
refilled only at a facility which Is equlp-
Envlronmen* Reporter
-------
CURRENT DEVELOPMENTS
,1079
pcd with a vapor recovery system, or the
equivalent, which prevents rclco.se to the
atmosphere of at least 90 percent by
wcicht of the total hydrocarbon com-
pounds iu the vapor displaced from the
delivery vessel during refilling.
(Ill) Gasoline stonvKC compartments
of one thousand rrallom or less In gaso-
llnc delivery vessels presently in use on
November C, 1973 will not be required to
be retrofitted with a vapor return system
until J.inunry I. 1977.
•td> The pronsiui:.* Of paragraph (c)
of this section shall not apply to the fol-
lowing:
(1) Storage containers used for the-
stornpe of gasoline "used on a farm for
farming purposes," as that expression Is
used in the Internal Revenue Code. 26
U.S.C. 6420.
(2) Any container having a capacity
less than 2,000 Gallons (7571 liters) in-
stalled prior to November 6, 1973.
(3) Transfers made to storage con-
tainers equipped with floating roofs or
their equivalent.
(e) Except ns provided In paragraph
(f) of this section, the owner or operator
of a source subject to paragraph (c) of
this section shall comply with the in-
crements contained in the following com-
pliance schedule:
(1) Contracts for emission control
systems or process modifications must
be awarded or orders must be issued for
the purchase of component parts to ac-
complish emission control or process
modification no later than March 31,
1975.
(2) Initiation of on-slte construction
or Installation cf emission control equip-
ment or process change must begin no
later than July 1.1975.
(3) On-site construction or Installation
of emission control equipment or process
modification must be completed no later
than June 30,1976."
(4) Final compliance is to be achieved
no later than August 31, 1976.
(6) Any owner or operator of sources
subject to the compliance schedule in
this paragraph shall certify in writing
to the Regional Administrator whether
or not the required increment of progress
has been met, The certification shall be
submitted within five days after the
deadlines for each increment. The cer-
tification shall include the name(s) and
street addrcss(es) of the facility (facili-
ties) for which the certification applies.
and the datc(s) the increments) of
progress was (were) met—if met. The
Regional Administrator may request
whatever supporting information he con-
siders necessary for proper certification.
-------
APPENDIX D
QUESTIONNAIRE USED IN FIELD SURVEY
-------
SMALL BULK PLANT EVALUATION
1. Owner Operator
Address
Contact Phone ( )
2a. Gasoline throughput ''''... gallons/month
2b. Grades of gasoline
3a. Other products sold
3b. Percentage of business selling gasoline
4. Underground tanks - number
Capacities
5. Aboveground tanks - number
Capacities
6. Top loading
Bottom loading
Submerged fill )_
7. Supply vehicles owned by
Number
Capacity
Frequency of delivery
8. Delivery vehicles owned by
Number
Capacity
Time to fill
9. Fugitive emissions
-------
11. Vapor Recovery. Delivery Vehicle
Date Installed .__: By whom_
Cost .
Bottom or Top Load
Operating Problems
12. Vapor Recovery Storage Tank/incoming loads
Date Installed ________ By whom ________
Cost '
Operating Problems
13. Vapor Recovery, Storage Tank/Loading Rack (Delivery)
Installed By whom _ _
Installation Cost » Operating Cost
Maintenance Cost
Operating Problems
14. Vapor Recovery, Delivery Vehicle
Installed By whom _
Installation Cost Operating Cost
Maintenance Cost
Operating Problems
15. % Deliveries to Exempt Customers
Type of Exemption: Agricultural_
Small Tanks Size_
Other
Of Non-exemt customers, what vapor control techniques are being
used
-2-
-------
16. Assume vapor recovery will initially cost $20,000 and operating
costs increase 20%.
a) Would you stay in business
b) Could you obtain loan Down payment required
c) Comments
Bepeat for $10,000 $30,000
17. What could you sell your trucks, facility, accounts receivable and
good will for $ .
What did you originally invest $ .
18. Present margin
Annual sales $_ Gallons
Profits $
Debts $
19. Debt-equity or debt-total assets ratio
Rate of return on total assets or net worth_
Break even point
Assessed valuation
20. Comments - Closures, Competitors, bottom loading, etc.
-3-
-------
APPENDIX E
LIST OF FIRMS AND PEOPLE CONTACTED
-------
The following is a list of governmental agencies, industry
associations and firms contacted:
1. Governmental Agencies
D. Andrew, Maryland State Bureau of Air Quality
and Noise Control, Baltimore, Md.
C. Carr, Region III, U.S.E.P.A., Philadelphia, Pa.,
D. Gaston and J. Alexander, Jr., Virginia State
Air Pollution Control Board, Falls Church, Va.
S. Krause, Council of Governments, Washington, D.C.
D. Wambsgans, District of Columbia Bureau of Air
and Water Quality Control, Washington, D.C.
0. Cabra, EPA, Region VI, Dallas, Texas
R. Brown, EPA, Region VI, Dallas, Texas
R. Anderson, Texas Air Control Board, Houston, Texas
K. Wade, Texas Air Control Board, Austin, Texas
C. Miller, Harris County Pollution Control Dept.
Houston, Texas
L. Randell, Fuels Tax Division, Texas State Con-
trollers Office, Austin, Texas
Staff, City of Houston Pollution Control Division,
Houston, Texas
2. Industry Associations
S. McCully, Jr., Maryland Oil Jobbers Council,
Camp Springs, Md.
E. Catterton, Virginia Petroleum Jobbers Association.,
Richmond, Va.
P. Dudley and H. Smith, Jr., Texas Oil Marketers
Association, Austin, Texas
3. Bulk Plant Operators
A. Lawless III, Rockville, Md.
D. Bare, Westminster, Md,
P. Johnson, Havre de Grace, Md.
Mr. Clark, Phoenix, Md.
-------
3. Bulk Plant Operators (continued)
Mr. Corbin, Bel Air, Md.
J. Coulter", Bel Air, Md.
J. McCanney, Westminster, Md.
D. Hawkland, Havre de Grace, Md,
J. Gilbert, Havre de Grace, Md,
W. Carroll, Aberdeen, Md.
E. Palmer, Westminster, Md.
H. Schwarzschild, Owings Mill, Md.
C. Biles, Gaithersburg, Md,
R. Peterson, Westminster, Md.
W. Walsh, Hampstead, Md.
W. Wilhelm, Randallstown, Md.
J. Hawkins, Westminister, Md.
R. Jackson, Annapolis, Md.
R. Fairbanks, Edgewater, Md.
F. Hollifield, Annapolis, Md.
0. Hall, Leesburg, Va.
Mr. Hawkins, Alexandria, Va.
0. Oyler, Leesburg, Va.
Mr. Rose, Middleburg, Va.
F. Moorcones, Purcellville, Va,
R. Robertson, Fairfax, Va.
J. Cooper, Purcellville, Va.
W. Holtzman, Mt. Jackson, Va.
D.D. Clark, Alvin, Texas
G. Warfield, Alvin, Texas
G. Monteau, Alvin, Texas
B. Magness, Angelton, Texas
R.B. Stewart, Angelton, Texas
Mr. Miguez, Winnie, Texas
Pat McGowan, Winnie, Texas
D.G. Thompson, Katy, Texas
-------
3. Bulk Plant Operators (continued)
Mr. Bernhausen, Rosenburg, Texas
Mr. Krolcyzk, Rosenburg, Texas
C. Foss, Rosenburg, Texas
J. Armstrong, Sugar Land, Texas
R. Kuhn, Galveston, Texas
L. Enderli, Baytown, Texas
Mr. Barrow, Baytown, Texas
D. Trigg, Baytown, Texas
H. Smith, Jr., Houston, Texas
B. Glaw, Houston, Texas
J. Herbert, Liberty, Texas
Mr. Silhavy, Liberty, Texas
Mr. Evans, Bay City, Texas
J. Kovar, Bay City, Texas
J.D. Berryman, Bay City, Texas
E.Nedbalek Bay City, Texas
J. Stubbs, Conroe, Texas
T.C. Brannon, Conroe, Texas
R. Clanton, Conroe, Texas
B. Pursley, Conroe, Texas
J.C. Hicks, Hempstead, Texas
4. Major Oil Company Contacts
Pepper Massengale, Mobil Oil Co., Houston, Texas
Pat Cotton, Ada Oil Co., Houston, Texas
Clarence Hysmith, Exxon Co., Houston, Texas
E.W. Berry, Exxon Co., Houston, Texas
Lee Kleypas, Exxon Co., Dallas, Texas
E.E. Carroll, Texaco Oil Co., Houston, Texas
R. Page, Southern States Cooperative, Inc.,
Richmond, Va.
George Johnson, Gulf Oil Corporation, Houston, Texas
J.L. Golueke, Amoco, Inc., Baltimore, Maryland
D.L. Adams, Friendly Oil Co,, Inc. Havre de Grace, Maryland
-------
5. Other interested parties
M. Miller, U.S., FEA, Los Angeles, California
W. Moore, Emco Wheaton, Conneaut, Ohio
J. Parks, OPW, Cincinnati, Ohio
J. Barnes, Huddleston Equipment Co. Los Angeles,
California
Andrews Mfg. Co., Dayton, New Jersey
-------
APPENDIX F
FINANCIAL ANALYSIS
-------
FINANCIAL ANALYSIS EXCERPTED FROM "ECONOMIC
ANALYSIS OF VAPOR RECOVERY SYSTEMS ON SMALL
BULK PLANTS"
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
-------
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:
• Relationship with his supplier
• Efficiency of his plant
• Size of his customers
• Distance traveled to his customers
t Extent of direct competition
• 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, an
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 opera-tor 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 8,000 gallon (30,00.0 li;terl 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
-------
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 consist 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
-------
Table 7.1 BALANCE SHEET
AND INCOME STATEMENT FACTORS
FOR WHOLESALERS OF PETROLEUM PRODUCTS
ASSET SIZE
NUMBER OF STATEMENTS
ASSETS
Cash
Marketable Securities
Receivables Net
Inventory Net
All Other Current
Total Current
Fixed Assets Net
All Other Non-Current
Total
LIABILITIES
Due to Banks-Short term
Due to Trade
Income Taxes
Current Maturities LT Debt
All Other Current
Total Current Debt
Non- Current Debt. Unsub.
Total Unsubordinated Debt
Subordinated Debt
Tangible Net Worth
Total
INCOME DATA
Net Sales
Cost of Sales
Gross Profit
All Other Expense Net
Profit Before Taxes
WHOLESALERS OF - PETROLEUM
PRODUCTS
77 STATEMENTS
ENDED ON OR ABOUT JUNE 30, 1974
76 STATEMENTS
ENDED ON OR ABOUT DECEMBER 31, 1974
Under
$250K
13
%
10.4
.0
27.6
25.0
1.8
64.8
28.5
6.7
100.0
3.2
18.6
2.6
4.1
19.7
48.3
10.4
58.8
.0
41.2
100.0
100.0
82.6
17.4
13.9
3.5
$250K &
Less Than
$1MM
67
%
10.8
1.7
27.7
17.3
1.8
59.4
33.2
7.5
100.00
4.9
20.0
4.5
4.7
8.0
42.1
17.7
59.8
.9
39.4
100.0
100.0
81.9
18.1
14.8
3.3
$1MM &
Less Than
$10MM
59
%
14.1
.5
23.6
19.0
1.8
59.0
34.4
6.6
100.0
3.8
23.0
5.6
3.6
10.1
46.2
16.5
62.7
.4
36.8
100.0
100.0
84.5
15.5
10.6
4.8
Alt
nl 1
Sizes
153
%
9.7
1.7
24.4
18.3
1.2
55.4
38.4
6.2
100.0
3.9
22.3
4.0
3.7
8.4
42.2
18.1
60.3
.3
39.4
100.0
100.0
78.4
21.6
14.8
6.8
7-3
-------
Table 7.2 RATIO ANALYSIS FOR WHOLESALERS OF PETROLEUM PRODUCTS
Based on 153 statements ending during calendar year
1974
Asset
Size
RATIOS
RATIOS
Quick
Current
Fixed/
Worth
Debt/
Worth
% Profit
Bef. Taxes/
Worth
% Profit
Bef. Taxes/
Tot. Assets
Under
$250M
18
1.0
.8
.5
1.7
1.5
1.1
.3
.7
1.0
.7
1.3
2.7
85.8
28.5
6.6
25.5
16.4
3.8
$250 and
less than
$1MM
67
1.2
.9
.7
1.8
1.4
1.0
.4
.8
1.4
.8
1.5
2.9
50.3
35.2
19.3
18.4
11.4
7.0
$IMM and
less than
$10MM
59
1.2
.9
.6
2.0
1.3
1.0
.5
.9
2.0
.9
1.6
3.3
60.3
33.3
23.0
18.4
12.9
7.4
All
Sizes
153
K2
.9
.6
1.8
1.4
1.0
.5
.8
1,6
.8
1.6
3.1
60.7
35.2
20.3
19.2
12.9
7.2
The three values in each box represent the quartile points
for each ratio and asset size.
7-4
-------
Table 7.3 DEFINITION OF RATIOS
QUICK RATIO
Method of Computation; The total of cash, short-term marketable
securities and net receivables for the industry composite was
divided by the total of current liabilities.
Result; The ratio measures short-term liquidity available to
meet current debt.
Principle; Also known as the "acid test" or "liquidity" ratio,
it is of particular benefit to short-term creditors, as it
expresses the extent to which cash and those assets most
readily convertible into cash can meet the demands of current
liabilities. Any value of less than 1 to 1 implies a re-
ciprocal "dependency" on inventory or other current assets to
liquidate short term debts.
CURRENT RATIO
Method of Computation; The total of current assets for the in-
dustry composite was divided by the total of current liabili-
ties.
Result; The ratio is one measure of the ability of the in-
dustry to meet its current debt.
Principle; In comparing an individual company to the industry,
a higher current ratio indicates that more current assets
are free from debt claims of creditors and prompter payment
can be expected.
FIXED/WORTH
Method of Computation; The net fixed assets (plant & equipment
less reserve for depreciation) for the industry was divided
by the tangible net worth.
7-5
-------
Table 7.3 Definition of Ratios con't.
Result: The ratio expresses the proportion between investment
in capital assets (plant and equipment) and the owners'
capital.
Principle: The higher the ratio, the less owners' capital is
available for working capital. The lower this ratio, the
more liquid is the net worth and the more effective owners'
capital is as a liquidating protection to creditors. The
presence of substantial leased fixed assets—off the balance
sheet—may deceptively lower the ratio.
DEBT/WORTH
Method of Computation; The total debt for the industry composite
was divided by the tangible net worth.
Result: The ratio expresses the relationship between capital
contributed by creditors to owners' capital—"what is owed to
what is owned."
Principle: Total assets or resources represent the entire
capital at the disposal of a given company and consist
of net worth or owners' capital, and creditor capital —
that provided by those outside the business for temporary
use. The proportion existing between debt and worth—or
leverage—records the debt pressure. The lower the ratio,
the easier the pressure and the greater the protection
for creditors.
PROFITS BEFORE TAXES/WORTH
Method of Computation; The amount of net profit before taxes
was divided by the tangible net worth.
7-6
-------
Table 7.3 Definition of Ratios con't.
Result: The ratio expresses the relationship between the owners'
share of operations before taxes for the year and the capital
>
already contributed by the owners.
Principle; Capital is usually invested in a company in the
anticipation of a return on that investment--!'n the form
of a profit. This hope of a profit is the attraction for
original and new capital. The higher the profit before
taxes to worth, the greater is the probability of making
appreciable addition to owners'
capital after payment of dividends and taxes.
PROFITS BEFORE TAXES/TOTAL ASSETS
Method of Computation; The amount of net profit before taxes
of the industry were divided by the total assets for the in-
dustry.
Result; The ratio expresses the owners' share of the year's
operations before taxes related to the resources contributed
by both owners and creditors.
Principle; The relationship indicates the net profitability of
the use of all resources of the business.
7-7
-------
7.2 FINANCIAL STATEMENT SUMMARY
Each industry tends to exhibit different types of financial
statements. For example, the firms in one industry may have a
large percentage of fixed assets while another industry may show
more current assets. On the liability side as well, firms within
an industry will show similarities and will tend to differ in the
degree of various elements. Consequently, it is extremely diffi-
cult to compare firms in various industries. The common practice
is to assess how any given firm in an industry compares to the
averages and standards developed for that industry.
By reviewing the data for the balance sheets and income
statements given in Table 7.1, some general statements can be made
about the data summarized for the industry. Most of the data shown
is representative of firms with at least $250,000 in assets. The
smaller companies have a greater percentage of current assets than
the larger firms with differences appearing primarily in a higher
percentage of fixed assets in inventories and a low percentage of
assets. On the liability side of the balance sheet, a reasonably
large disparity between the smaller and bigger firms is apparent
in the percentage of non-current debt. This fact reflects the
greater difficulty in most industries of small firms to obtain
long term debt.
One further point should be made regarding financial data
on balance sheets. According to generally accepted accounting
principles, fixed assets always reflect historical cost rather than
their current market values. Therefore, the balance sheet of a
company may not truly reflect the actual financial capability of the
firm. For example, a small bulk plant may have been purchased
thirty years ago and the recorded land value will reflect its
actual cost at that time. In the intervening period, the market
value of the land may have increased substantially but the firm's
7-8
-------
balance sheet and accounting records will continue to carry this
asset at its original cost.
7.3 INVESTMENT IN VAPOR RECOVERY SYSTEMS
The approach to be taken in the following discussion will
be to assess the impact of several expenditure levels for vapor
recovery equipment on firms of various asset values and sales.
As can be expected, within each group of companies, an irregular
ability to accept costs of a given amount will be exhibited.
The PES approach will be to evaluate the impact of varying expendi-
tures on average firms of several sizes (as represented by data
in Table 5.1) and assess the new quartile position of this firm
(as represented by the data in Table 5.2). If any expenditure
causes the firm to show drastic and unfavorable changes in parti-
cular ratios, it can be concluded that the expenditure will have
an adverse effect on the enterprise. This is due to the fact
that such changes indicate the probable existence of strains on
the financial capabilities of the firm in such areas as availa-
bility of capital, profitability and borrowing potential.
The analysis described below will concentrate on firms with
assets of between $50,000 and $750,000, and will be concerned
principally with the debt structure, working capital position
and profitability of an enterprise. These firms can be expected to
require an investment of at least $10,000 for installation of a top
loading vapor balance at plant sites and for modification of their
delivery trucks. Although it is recognized that some plants may
need to convert their own transports, this $5,000 expenditure
(approximate) is not being included as a cost of installing vapor
recovery equipment. Also, plants which elect to convert to bottom
loading at a cost in excess of $30,000 will be considered as volun-
tarily making this expenditure as a facility modernization.
7-9
-------
7.4 SOURCES OF CAPITAL
Most companies in the asset range being considered will be
unable to raise the needed capital internally and will have to
seek outside sources of funds. The most likely organizations
available to provide this assistance will be banks. Other assist-
ance may be expected from the Small Business Administration (SBA)
and the Pollution Control Financing Authority (PCFA) in most states.
The latter have been organized to provide low interest loans to
industry in order to purchase and install pollution control equip-
ment. However, only in the State of California has this organiza-
tion been specifically attempting to assist small businesses.
On June 4, 1976 President Ford signed Senate Bill 2498 into
law (Public Law 94305) which provides the SBA with the capability
to guarantee contracts that the California PCFA has with businesses
including loan agreements. These contracts are then used as
security to sell tax exempt bonds primarily to banks who make loans
to firms needing to install pollution control equipment at reduced
rates. If this program proves successful, it will probably be
expanded to other sections of the ocuntry.
When a potential borrower seeks a loan, he must demonstrate
to his bank that he possesses the capacity to repay the principal
and interest in a reasonable time period. If he cannot demonstrate
this fact, neither the SBA nor the PCFA can grant him a loan. His
credit worthiness is determined solely by his bank.
In most usual circumstances, banks will make equipment
loans for a period of three to five years at the prevailing rate
of interest. This rate is presently about 11%, however, it is
subject to change depending on the size of the loan, the type of
equipment and the credit worthiness of the borrower. If the loan
applicant qualifies under SBA or PCFA criteria, he could obtain
a loan for eight or more years at an interest rate that is three
or four percent below the prevailing rate.
Recently, the SBA has also recognized the special hardships
that can be created for small businesses in meeting air pollution
7-10
-------
regulations. Accordingly, a program of air pollution control loans
has been instituted. Further information pertaining to this pro-
gram, was provided in Reference 1.
7.5 ANALYSES OF FINANCIAL CAPABILITY
In order to assess the financial capability of typical small
firms in the industry, seven pro-forma balance sheets and income
statements have been created for enterprises with selected levels
of assets and sales. These statements, as shown in Table 7.4 ,
represent companies with assets ranging from $50,000 to $750,000
and with total annual sales between $150,000 and $2,500,000. These
statements were developed from the data provided in Tables 7.1 and
7.2.
From these data, ratios for total debt/net worth of the
seven typical companies have been generated assuming different levels
of vapor recovery expenditures. These new ratios are shown in
Table 7.5 for two cases. In the first case the loan is made for 80%
of the designated amount - a 20% down payment being required. The
second case shows 100% financing available, because of guarantees
by the SBA or the California PCFA. When the debt/net worth ratio
reaches the 2.5 area, it indicates that the firm is maintaining a
high proportion of debt. At this point creditors of this company
will begin to become concerned about its credit worthiness. Any
additional borrowing will become extremely difficult unless the
debt/net worth ratio can be reduced. For this reason a ratio of 2.2
will be considered as a desirable maximum.
Working capital must also be considered in order to assess
the capability of an enterprise to make a down payment, if necessary,
and continue in operation while paying off the loan. Quite clearly,
all working capital cannot be diverted to loan purposes. For this
exercise let us assume that 50% of working capital can be diverted.
7-11
-------
Table 7-4, PRO FORMA BALANCE SHEETS AND INCOME
STATEMENTS FOR BULK PLANTS OF VARIOUS SIZE ASSETS
ro
ASSET SIZE $50,000 $100,000 $150,000 $200,000
BALANCE SHEETS
Assets
Cash 5,200 10,400 15,600 20,800
Marketable Securities
Receivable Net 13,800 27,600 41,400 55,200
Inventory Net 12,500 25,000 37,500 50,000
Other Current Assets 900 1,800 2,700 3,600
Total Current Assets 32,400 64,800 97,200 129,600
Fixed Assets Net 14,250 28,500 42,750 57,000
Other Non-Current Assets 3,350 6,700 10,050 13,400
TOTAL ASSETS 50,000 100,000 150,000 200,000
LIABILITIES
Accounts Payable 9,300 18,600 27,900 37,200
Short Term Bank Loans 1,600 3,200 4,800 6,400
Income Taxes Payable 1,300 2,600 3,900 5,200
Current Maturities - Long 2,050 4,100 6,150 8,200
Term Debt
Other Current Liabilities 9,850 19,700 29,550 39,400
TOTAL CURRENT LIABILITIES 24,150 48,300 72,450 96,600
Non-Current Debt- 5,200 10,400 15,600 20,800
Unsubordinated
Subordinated Debt
TOTAL LIABILITIES 29,400 58,800 88,200 117,600
TANGIBLE NET WORTH 20,600 41,200 61,800 82,400
TOTAL LIABILITIES & 50,000 100,000 150,000 200,000
NET WORTH
INCOME STATEMENTS
Net Sales 150,000 300,000 500,000 700,000
Cost of Sales 123,900 247,800 413,000 578,200
Gross Profit 126,100 52,200 87,000 121,800
Other Expenses 20,850 41,700 69,500 97,300
Profit Before Taxes 5,250 10,500 17,500 24,500
Taxes 1,155 2,310 3,850 5,390
Net Profit 4,095 8,190 13,560 13,110
$300,000
$500,000
$750,000
32,400
5,100
83,100
51,900
5,400
178,200
99,600
22,500
300,000
60,000
14,700
13,500
14,100
24,000
126,300
53,100
2,700
181,800
118,200
300,000
1,000,000
819,000
181,000
148,000
33,000
7,260
25,740
54,000
8,500
138,500
86,500
9,000
297,000
166,000
37,500
500,000
100,000
24,500
22,500
23,500
40,000
210,500
88,500
4,500
303,000
197,000
500,000
1,600,000
1,310,400
289,600
236,800
52,800
12,344
40,456
81 ,000
12,750
207,750
129,750
13,500
445,500
249,000
56,250
750,000
150,000
36,750
33,750
35,250
60,000
315,750
132,750
6,750
454,500
295,500
750,000
2,500,000
2,047,500
452,500
370,000
82,500
26,600
55,900
-------
Table 7.5 TOTAL DEBT/NET WORTH RATIOS FOR TYPICAL FIRMS OF VARIOUS ASSET SIZES AND EXPENDITURE LEVELS
Bank Loans @ 80% of Expenditure (20% Down Payment)
"\^^ ASSETS
EXPENDITURE^^^
$0
10K
20K
30K
50K
75K
TOOK
125K
$50K
1.3
1.8
2.2
2.6
3.4
$100K
1.3
1.6
1.8
2.0
2.4
2.9
3.4
$150K
1.3
1.6
1.6
1.8
2.1
2.4
2.7
3.0
$200K
1.3
1.5
1.7
1,7
1.9
2.2
2.4
2.6
$300K
1.5
1.6
1.6
1,7
1.9
2.0
2,2
2.4
$500K
1.5
1.6
1.6
1.7
1.7
1.8
1.9
2.0
$750K
1.5
1.6
1.5
1.6
1-7
1,7
1.8
1.9
Down Payment
$2K
$4K
$6K
$10K
$15K
$20K
$25K
SBA and PCFA Loans @ 100% of Expenditure
^~^\^ ASSETS
EXPENDITURE^^.
$0
10K
20K
30K
50K
75K
100K
125K
$50K
1.3
1.9
2.4
2.9
3.9
$100K
1.3
1.7
1.9
2.2
2.6
3.3
3.9
$150K
1.3
1.6
1.8
1.9
2.3
2.6
3.1
3.4
$200K
1.3
1.5
1.7
1.8
2.0
2.3
2.6
2.9
$300K
1.5
1.6
1.7
1.8
2.0
2.2
2.4
2.6
$500K
1.5
1.6
1.6
1.7
1.8
1.9
2.0
2.2
$750K
1.5
1.6
1.6
1.6
1.7
1.8
1.9
2.0
i
-------
Many organizations are likely to find this amount too high and could
result in causing them cash flow difficulties. Nevertheless, 50%
appears to be a reasonable jumping off point.
With this factor in mind, one can estimate the maximum loan
a firm can undertake based solely on working capital from banks or
through the SBA or PCFA for the seven typical companies as follows:
50% of
Working Maximum Maximum SBA
Capital Bank Loan or PCFA Loan
$ 50,000 $ 4,125 $ 0 $ 25,000
100,000 8,250 15,000 50,000
150,000 13,375 30,000 75,000
200,000 16,500 35,000 IOC,000
300,000 25,950 60,000 150,000
500,000 43,250 100,000 150,000
750,000 64,875 150,000 150,000
Since a minimum of $10,000 is considered necessary for
installation of a complete vapor recovery system for incoming and out-
going loads, any acceptable loan below this amount is shown as zero.
Additionally, SBA and PCFA loans of larger amounts can be supported
since they may not require down payments, and are to be repayed
over longer time periods at lower interest rates.
Finally, profitability must be considered since the enter-
prise must generate the earnings to replenish working capital and
make loan payments. Realistically, no lender will be confident in
making a loan unless principal and interest payments are covered by
the potential earnings of the enterprise. Accordingly, the firm's
net income will determine the amount of loan that may be granted.
Under usual circumstances, an investment in plant and equip-
ment is made in order to replace worn out facilities, modernize
7-14
-------
the establishment, or improve operating efficiencies. The result
of this type of investment is reasonably expected to be increased
profitability. It is these higher profits that are then used to
repay the principal and interest of any loan undertaken for the
purpose of making this investment. In the case of vapor recovery,
this scenario cannot be expected. Rather, any debt incurred for
the purpose of meeting vapor recovery regulations will have to be
honored from non-rising profits.
The profits of any business are used to provide a return to
its owners and for reinvestment in the business. Consequently, it
is unreasonable to expect that all of the profits of the business
should be employed for vapor recovery purposes. Every company must
constantly reinvest in its plant and equipment in order to maintain
adequate operations.
Again, let us assume that no more than 50% of after tax
profits can be utilized for loan repayment. This procedure provides
for a minimum level of profits to be used for purposes unrelated to
the vapor recovery installation.
Given this background, the maximum loans that can be expected
for the seven typical companies are as follows:
50% of
Asset After Tax SBA or
$ize Profits Bank Loan PCFA Loan
$ 50,000 $ 2,000 $ 0 $ 0
100,000 4,000 15,0000 20,000
150,000 6,800 30,000 35,000
200,000 9,500 45,000 60,000
300,000 12,750 60,000 75,000
500,000 20,000 90,000 120,000
750,000 28,000 125,000 150,000
7-15
-------
These estimates have been based solely on the amount that can be
repaid from previous year's profits and do not include the effect
of any special tax incentives.
Tax incentives may have a significant impact for many com-
panies contemplating a vapor recovery investment. In this connec-
tion, the Internal Revenue Code includes special provisions for
firms, and especially small businesses purchasing and installing
certified pollution control facilities. In addition to all interest
payments being deductible expenses for tax purposes, Section 169 of
the code permits a rapid write-off of such certified investments.
Under this regulation a company may choose to depreciate its newly
acquired facility over a sixty-month period instead of over its use-
ful life. Employing the straight-line depreciation method, 20% of
the cost of this investment could be deductible for five years.
Sections 46 and 50 of the code deal with the subject of
investment tax credits. Under the 1975 provision, all businesses
may credit 10% of the cost of equipment with a depreciable life of
at least seven years to their actual tax liability. Lesser per-
centages may be created for equipment depreciated over a minimum
period of three years to a maximum of six years. The purpose of
this regulation is to provide businesses with added incentives to
purchase equipment.
Finally, Sections 179 of the code furnishes small business
with an additional, opportunity to reduce their taxes. It permits
an added first year bonus depreciation allowance equal to 20% of
the purchase price of the equipment.
Accordingly, a small business will be able to deduct its
interest expense plus almost 50% of the purchase and installation price
of certified pollution control equipment, depending on the depre-
ciation method used. Other businesses will be able to deduct 30%
plus interest charges.
7-16
-------
The primary benefit resulting from these incentives will
be a reduction in the tax burden on the affected companies. Con-
sequently, firms with little or no profits will accrue only minor
assistance from these regulations. For firms enjoying profits,
they will benefit from sharply reduced tax expenses and an increased
cash flow. The latter will provide additional security to financial
institutions contemplating loans to the firm and may result in the
business being able to spend larger sums on pollution control equip-
ment.
7.6 DETERMINATION OF LOAN LIMITS
In order to be eligible for a loan, a company must be able
to demonstrate that its financial structure is able to absorb addi-
tional borrowing, that it possesses the working capital to make
the required down payment and pay the associated fees, and that it
has the earnings capacity to maintain its financial capability and
retire the loan. These aspects have been considered above for our
typical companies in relation to various size loans. We can now
combine the results above and determine approximately the maximum
amount each size firm can be expected to borrow.
This estimate has been calculated by computing the minimum
acceptable loan amount for each size company and then choosing the
smallest amount in each group. The data resulting from this pro-
cedure are shown in Table 7.6. The amount that can be borrowed
for each asset group is then equal to the smallest value in that
group as follows:
7-17
-------
$ 50,000
100,000
150,000
200,000
300,000
500,000
750,000
$
Net Sales
Dollars
150,000
300,000
500,000
700,000
1,100,000
1,600,000
2,500,000
80%
Bank Loan
$ 0
15,000
30,000
35,000
60,000
90,000
125,000
100% SBA or
PCFA Loan
$ 0
20,000
35,000
60,000
75,000
120,000
150,000
It should be reemphasized that these amounts reflect estimated
maximum investments for the typical firms based on the specified
assumptions. These assumptions are believed to reasonably reflect
the real world situation, but they are susceptible to ^interpretations.
7-18
-------
Table 7.6 ACCEPTABLE LOAN AMOUNTS BY FACTOR
80% - Bank Loan
^\^ FACTOR
SIZE ^^\^^
K$
50K
100K
150K
200K
300K
500K
750K
Debt
K$
20K
40K
60K
75K
TOOK
150K
150K
Working
Capital
K$
0
15K
30K
35K
60K
100K
150K
Profitability
30 K
45K
60K
90K
125K
100% - SBA or PCFA Loan
"""^^^ FACTOR
ASSET***^.
SIZE ^*\^
ft ^-
K$
50K
100K
150K
200K
300K
500K
750K
Debt
K$
15K
30K
45K
70K
75K
125K
150K
Working
Capital
25K
50K
75K
TOOK
150K
150K
150K
Profitability
0
20K
35K
60K
75K
120K
150K
7-19
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA 340/1-77-010
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Effects of Stage I Vapor Recovery Regulations on Small
Bulk Plants and on Air Quality in the Washington, D.C.,
Baltimore, MD, and Houston/Galveston, TX, Areas
5. REPORT DATE
March 1977
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Pacific Environmental Services, Inc.
1930 14th Street
Santa Monica, CA 90404
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-3156 Task 28
12. SPONSORING AGENCY NAME AND ADDRESS
Division of Stationary Source Enforcement
U.S. Environmental Protection Agency
Washington,B.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
. SPONSORING AGE
14,
i AGENCY CODE
15. SUPPLEMENTARY NOTES
EPA Contact: Mr. John Busik
(202) 755-2560
IB. ABSTRACT
This study surveyed bulk plant operations in areas surrounding Baltimore, MD,
Washington, D.C., and Houston/Galveston, TX. It was performed to determine whether
the descriptive, market and economic data presented in an earlier report
adequately applied to other areas of the country. For these specific locations
data was obtained to:l)Provide an inventory of bulk plants and classify these plants
by thoughput. 2) Describe facilities and vapor recovery equipment at the bulk plants.
3)Determine types of customers and volume dispensed to non-exempt accounts,
agriculture accounts and accounts with small tanks.
4)Financial profile of typical bulk plants.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air Pollution
Gasoline Bulk Terminals
Vapor Balancing
Vapor Recovery
Air Pollution Control
Stationary Sources
Organic Vapors
8. DISTRIBUTION STATEMENT
Release: Unlimited
Available free from DSSE/EPA while
supply lasts
19. SECURITY CLASS (ThisReport)
unclassified
21. NO. OF PAGES
the
20. SECURITY CLASS (Thispage)
unclassified
22. PRICE
EPA Form 2220-1 (9-73)
------- |