WORKSHOP ON VOC EMISSIONS FROM GASOLINE MARKETING SOURCES PRESENTED BY PAcIFIc ENVIRONMENTAL SERVICES, INC. DURHAM, NORTH CAROLINA (919) 493-3536 AND. PE! ASSOCIATES, INC. DURHAM, NORTH CAROLINA (919) 688-6338 SPONSORED 3Y UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I JFK FEDERAL BUILDING BOSTON, MASSACHUSETTS 02203 AUGUST 20-21, 1986 LEXINGTON, MASSACHUSETTS I ------- OVERVIEW OF CTG AND STATE REGULATIONS BACV ROUND - GASOLINE MARKETING ------- OVER I&I OF CTG AND STATE REGULATIOFE ------- SLIDE 1 VOC VOLATILE ORGANIC COMPOUNDS SLIDE 2 VOC WORKSHOP OVERVIEW • Purpose • Scope • Format SLIDE 3 WORKSHOP PURPOSE Provide open format that will lead to interactive dialogues among agency representatives about VOC enforcement issues ------- SLIDE 4 WORKSHOP SCOPE • VOC source categories • VOC control methods • Inspection techniques • Enforcement issues SLIDE 5 WORKSHOP FORMAT • Industry and regulation overview • Discussions on VOC compliance problems • Informal — contribute your ideas any time SLIDE 6 VOC WORKSHOP TOPICS COVERED: • Gasoline Marketing • Incineration • Drycleaning • VOC Detection Instruments • Degreasing • Drycleaning Inspections • Carbon Adsorbers • Can Manufacturing • Surface Coating Inspections ------- SLIDE 7 voc TM A volatile orgahic compound (VOC) is any organic compound that, when released to the atmosphere, can remain long enough to participate in photo-chemical reactions... almost all organics which can be consi- dered VOC have vapor pressures greater than 0.1 mm Hg at 20°C and 760 mm Hg.” SLIDE 8 VOC PROBLEM 30 Million Tons Mobile sources — 40% AU other sources — 60% SLIDE 9 EPA Issues CTGs ------- SLIDE 10 CTG • Working document • Guidance to states SLIDE 11 GROUP I CTG SOURCE CATEGORIES • Gasoline loading terminals • Miscellaneous refinery • Gasoline bulk plants sources • Service stations — Stage 1 • Cutback asphalt • Fixed roof petroleum tatii • Solvent metal cleaning SLIDE 12 GROUP I CTG SOURCE CATEGORIES (continued) SURFACE COATING OF: • Cans • Metal furniture • Metal coils • Magnet wire • Paper products • Large appliances • Automobile and light trucks ------- SLIDE 13 GROUP II CTG SOURCE CATEGORIES • Leaks from petroleum refineries • Miscellaneous metal parts surface coating • Surface coating of flat wood paneling • Vegetable oil processing SLIDE 14 GROUP II SOURCE CATEGORIES (continued) • Rubber tire manufacture • External floating roof petroleum tanks • Graphic arts • Perchloroethylene dry cleaning • Gasoline truck leaks and vapor collection ------- SLIDE 15 GROUP III: CONTROL TECHNIQUES GUIDELINES SOURCE CATEGORIES STORAGE, TRANSPORTATION AND MARKETING OF VOC • Oil and gas production and processing 1. Fugitive VOC: oil and gas production 2. Fugitive VOC: natural gas and gasoline process- ing plants • Bulk terminals — volatile organic liquid loading into railcars • Bulk plants — volative organic liquid storage SLIDE 16 GROUP III: CONTROL TECHNIQUES GUIDELINES SOURCE CATEGORIES (continued) INDUSTRIAL PROCESSES • Organic chemical manutacture 1. Fugitive VOC, SOCMI 2. Air Oxidation, SOCMI INDUSTRIAL SURFACE COATING • Fabric Printing NONINDUSTRIAL SURFACE COATING • Architectural coatings ------- SLIDE 17 GROUP III: CONTROL TECHNIQUES GUIDELINES SOURCE CATEGORIES (continued) OTHER SOLVENT USE • Drycleaning — petroleum solvent systems • Graphic arts — letterpress printing and offset printing OTHER MISCELLANEOUS SOURCES • Waste solvent recovery processes SLIDE 18 REGULATIONS AFFECTING EXISTING SOURCES EXAMPLES: • SIP—RACT • Federal, state, and local permit systems SLIDE 19 RACT REASONABLY AVAILABLE CONTROL TECHNOLOGY • Reasonably available technology • Considers cost ------- SLIDE 20 REGULATIONS AFFECTING NEW SOURCE CONSTRUCTION NEW SOURCE REVIEW (NSR) • Process for reviewing new sources SLIDE 21 PSD PREVENTION OF SIGNIFICANT DtTtRIORATION • EPA policy applied to new sources in an attainment area SLIDE 22 NSPS NEW SOURCE PERFORMANCE STANDARDS • Promulgated for various source categories • Specify emission limitations • Can be found in CFR ------- SLIDE 23 BACT BEST AVAILABLE CONTROL TECHNOLOGY • Best technology available • Considers cost and energy requirements SLIDE 24 LAER LOWEST ACHIEVABLE EMISSION RATE • Control devices to achieve lowest possible emission rate • Required for sources in nonattainment areas SLIDE 25 CONTROLLED TRADING • Offset policy • Bubble policy • Banking emissions ------- SLIDE 26 OFFSET POLICY • Required for new sources in nonattainment areas • “Trade-off” of emissions SLIDE 27 VOC OFFSET EXISTING SOURCE NEW SOURCE 420 LBS/HR 100 LBS/HR 300 LBS/HR SLIDE 28 BUBBLE POLICY ------- SLIDE 29 BANKING EMISSIONS SLiDE 30 STATE REGULATIONS AND PERMITS CAN VARY FROM CTG AND MODEL REGULATION ------- BACKGROUND — GASOLINE MARKETING ------- = Storage = Transport Wholesale Distribution Level Consumer Gasoline Distribution in the U.S. ------- EPA DEFINITIONS BULK TERMINAL — RECEIVES PRODUCT BY PIPELINE, SHIP, OR BARGE ac’,Oc ’c BULK PLANT — RECEIVES PRODUCT BY TRUCK AND HAS DAILY THROUGHPUT LESS THAN 20,000 GALLONS/DAY ------- COMPONENTS OF THE GASOLINE MARKETING CHAIN REFINERIES 300 TERMINALS 1,800 BULK PLANTS 21,000 SERVICE STATiONS 170,000 OTHER FINAL OUTLETS 240,000 TANK TRUCKS 60,000 BARGES 3,200 TANKERS 140 ------- TERMINALS AND BULK PLANTS TERMINALS BULK PLANTS ------- SERVICE STATION POPULATION 1982 147,000 1980 158,540 1975 189,480 1972 226,459 ------- ESTIMATES OF 1982 SERVICE STATION POPULATtON Public Outlets (i.e, service stations and convenience stores) 210,875 “Privat&’ Outlets Govermient (Federal, military, State, local) 85,450 Miscellaneous (auto rental, utilities, others) 94,530 Trucking and Local Service 21,900 Taxis 5,380 School Buses 3,070 Total 421,125 ------- Table 2-2. EXN PLE: CHEMICAL COMPOSITION OF GASOLINE VAPORS 3 Vol% Wt.% Air 58.1 37.6 Propane 0.6 0.6 Iso—Butane 2.9 3.8 Butene 3.2 4.0 N—Butane 17.4 22.5 Iso-Pentane 7.7 12.4 Pentene 5.1 8.0 N—Pentane 2.0 3.1 Hexane 3.0 8.0 100.0 100.0 ------- Gasoline From Pipeline. Ship, or Barge Example of Gasoline Loading at Bulk Terminals Vapor to Collection System or Atmosphere Floating Roof Gasoline Top or Bottom Tank Storage Tanks Pumps Loading Racks Trucks ------- VAPOR EMISSI HATCH COVER TANK TRUCK COMPARTMENT HATCH COVER TANK TRUCK COMPARTMENT TANK TRUCK COMPARTMENT GASOLINE CASE 1. SPLASH LOADING METHOD VAPOR EMISSIONS VAP fi EASE 2. SUBMERGED FILL PIPE VAPOR VENT TO RECOVERY OR ATMOSPHERE CASE 3. BOTTOM LOADING Figure 4—6. Gasoline Tank Truck Loading Methods ------- PETROLEUM LIQUIDS Double-Deck Floating Roof I U I I I I I I ------- UNCONTROLLED EMISSIONS FROM A TYPICAL BULK GASOLINE TERMINAL Tons/year Loading Racks - Submerged Loading 220 - Top Splash Loading 5 0 - Balance Service 330 Storage Tanks - Fixed-Roof Tanks working losses 1.50 breathing losses 40 - Floating-Roof Tanks working losses 0.1 storage losses 40 ------- T uek Tx *ctor Trailer Pumpa Storage Tanks Loading Rack Scharritlc Of T Loading Bulk Plant ------- A TYPICAL TOP—LOADING RACK ------- THIEF HATCH VENT NOZZLE SUBMERGED FILL OR DRAINAGE) Figure 2—2. Typical Fixed Roof Tank MANHOLE 2-6 ------- EMISSIIONS FROM A TYPICAL BULK PLANT LOADING STORAGE EMISSIONS TANKS 5.000 GAL/DAY FACILITY 9 TONS/YR. 9 TONS/YR. ------- A. STRAIGHT TRUCK 9. SEMITRAILER C. STRAIGHT TRUCK AND FULL TRAILER D. SEMITRAILER AND FULL TRAILER Figure 4—5. Types of Tank Trucks ------- RUBBER BOOT OR COVER VENT VALVE .OVERFILL SENSOR DOME LID SEAL OV ERTIJRN (VAPOR RETURN) RAIL CLAMPS TANK SHELL BASE RING GASKET Figure 3—6. Major Tank Truck Leakage Sources ------- 8TA6 S TAIIIC STAGE II Of UNDflIGROIJND TANK VEHICLE ------- TYPICAL EMISSIONS FROM GASOLINE SERVICE STATIONS STAGE I STAGE II TYPICAL 5O OOO GAL/MONTH SERVICE STATION 2.2 TONS/YR. 2.7 TONS/YR. ------- STAGE I CONTROL TECHNOLOGY STORAGE TANKS REVIE d OF BUU< GASOLINE TERMINAL NSPS (SU& PRT XX) STAGE Il/ONBOARD CONTROVERSY ------- STAGE I CONTROL TEO NOLOGY ------- VAPOR OLLEC11ON EM VIAPOR PROCESSING TEM T ANK TRUCK UQJID LQØDING V APOR PRC ESSOR ------- VAPOR COLLECTION SYSTEMS • TOP LOADING VAPOR RECOVERY • TOP TIGHT • BOTTOM LOADING ------- TOP LOADING VAPOR RECOVERY ------- VAPOR RETURN LINE I VAPOR FREE I AIR VENTED TO I ATMOSPHERE —0 - PRODUCT FROM LOADING TERMINAL STORAGE TANK ------- a SCHEMATIC DIAGRAM SHOWING NYDU INCORPORATION INTO A TYPICAL GASOLINE LOADING SYSTEM. MAIN BURNER VAPOR LINER AIR SEAL ARRESTOR GENERAL CONFIGURATION MAO NYDU VAPOR DISPOSAL UNIT MAO Vapor Disposal Unit (NVDU) National Air Oil Burner Company ------- IIYDROTECH ADSORPTION-ABSORPTION GASOLINE RECOVERY SYSTEM AIR VENT GASOLINE SUPPLY PUMP INLET VACUUM PUMP Adsorption-Absorption Vapor Recovery System Ilydrotech Engineering, Inc. ------- CONDENSEII AIR I ’ It — EVAPORATOR. INTERCHANGER f II I.. I F CHILLED BRINE STORAGE RESERVOIR J I . J AIRVAPOR MIXTURE DISCHARGE FROM UNIT 2 I RECOVERED GASOLINE CONDENSED WATER VAPOR Source: Edwards Engineering Corp., Pompton Plains, N.J. AIRCOOLED REFRIGERATION UNIT DEFROST BRINE STORAGE RESERVOIR -.4 .-- , I -J L I I I I -J JY Refrigeration System ------- BACK PRESSURE VALVE COMPRESSOR FIRST STAGE COMPRESSOR SECOND STAGE HEAT EXCHANGER LIQUID LEVEL CONTROL PUMP FLAME ARRESTOR SATURATOR SCRUBBER FLASH TANK ABSORBER Compression Refrigeration Adsorption Unit by Trico-Superior, Inc. BPV C-i C-2 E LLC P SKID LIMITS ____ FA V-i V-2 V-4 ------- INTERNAL BLADDER PRESSURE VACUUM RELIEF VALVE INTERCOOLER CONDENSER 2 CONDENSER 1 CONDENSATE VAPOR TANK VENT TO ATMOSPHERE RECOVERED LIQUID TO STORAGE UNDERGROUND SATURATOR TANK LEGEND ATMOSPHERIC AIR RECOVERED GASOL INE HYDROCARBON VAPORS Schematic Diagram of GESCO CRC Vapor Recovery System ------- ABSORPTION PROCESS SPONI( OIL ioouai LIQ4T IN S TO STORA GASOLINE FEED TO EVAPORATOR (nON STORAGE) I t 4 I I t 4 Lean 011 AbsorptIon Ingersoll -Rand Southwest Industrial ------- VAPOR PROCESSING SYSTEMS EMISSIONS mg/liter EFFICIENCY CARBON ADSORPTION (CA) 2.7—92.6 91 —99.5 THERMAL OXIDIZER (TO) 1.4—107.0 87-99.8 REFRIGERATiON (REF) 25.3—103.0 77—98 COMPRESSiON—REFRIGERATION—ABSORPTION (C RA) 41.5—91.0 61—95 COMPRESSION—REFRiGERATION—CONDENSATION (CRC) 48.4—55.9 87—93 LEAN OIL ABSORPTION (LOA) 73.0—130.0 74—86 ------- BULK TERMINAL COSTS (4TH QUARTER 1982 DOLLARS) 100,000 gal/day CA TO REF AVERAGE Capital Costs Control Unit Cost 136 115 143 131 Installation Cost 116 98 122 112 Rack Conversion 0 0 0 0 Truck V.R. Cost 10 10 10 10 Total capital cost 261 222 274 252 Annual Costs Electricity 6.6 3.0 19.1 9.6 Propane -- 3.0 -- 1.0 Carbon Replacement 1.2 -- -- 0.4 Maintenance 6.0 5.2 6.3 5.8 Operating Labor 5.4 5.4 5.4 5.4 Truck Testing 1.4 1.4 1.4 1.3 Direct Operating Costs 20.6 17.9 32.1 23.5 Capital Charges 42.5 36.2 44.6 41.1 Tues and Insurance 10.4 8.9 11.0 10.1 Gasoline Rec. Credit 28.2 0.0 28.2 18.8 Net Annualized Costa 45.3 63.0 59.5 55.9 Total VOC Controlled 65.2 65.2 65.2 65.2 ------- Pressure Vacuum Valve Dotted Line— Vapor Return Line Double Line— Liquid Line Truck Tractor Trailer U fl (Not afl of the Vapor Return Line and Liquid Line are shown) (Catwalk for Storage Tanks not shown) SCHEMATIC OF TOP LOADING BULK PLANT EQUIPPED WITH VAPOR RECOVERY Loading Rack Pumps Storage Tanks ------- HALANC TO TliANSPO8T BALANCE TO STORAGE TRANSPORT TRUCK UNLOADING ACCOUNT TRUCK LOADING Vi por Gasoline StoraUs Tank Gasoline Line Gasoline Line Vapor Balance Systems at Bulk Gasoline Plants ------- Hatch Cover Lift Cylinder Truck Tank Shell Drop Tube (a) TOP LOADING VAPOR HEAD SYSTEM Top Loading Flexible Compatible Vapor Tight Adapters Permanent Submer9ed Fill Pipe Vapor Line Vapor Connector (b) TOP TIGHT LOADING SYSTEM ------- Lv VtI’fl Adjustable for tank ullage ZN2B RECEIVER Components for Wiggins Tank Wagon Vapor Balance System’ Gravity off load I ZZ9B NOZZLE with Automatic Shut Oft ------- ESTIMATED VAPOR RECOVERY COSTS AT SMALL BULK PL.AMTS 2 Vapor Recovery System Vapor Recovery Loading Racksa Vapor Recovery Incoming Loads Tank Truck Vapor Recoveryb Total Top Loading Vapor Recovery Arms Top Tight System Wiggins System Bottom Loading $32,000 8,200 8,700 21,600 $4,200 2,900 4,200 4,200 $2,200 4,200 $38,400 11,100 12,900 30,000 aEstimated for a bulk plant with one loading rack, with three top loading areas. bEstimated for one four-compartment tank truck. ------- 11 Truck Trailer Transport Bulk Tank Vents-i ’ Co—ax Vapor Return Line Liquid Line ______ - —- L9 i - I- - Vent Line Underground Storage Tanks ------- SERVICE STATION STAGE I CAPITAL AND NET ANNUALIZED COST ESTINATES (4th Quarter 1982 Dollars) Capital Coat and $1,698 Installation Annualized Coats Maintenance (3 ) $51 Taxes, Insurance $68 and G & A (4 ’c) Capita]. Charges $223 (t3.1 ) Annualized Coat $342 Recovery Credit NA Net Annualized Cost $342 Coat Effectiveness, $/Mg NP1 (18.950 liters/mo.) $1,380 MP2 (75,800 liters/mo.) $345 NP3 (132,650 liters/mo.) $197 NP4 (246,350 liters/mo.) $106 MP5 (701,150 liters/mo.) $37 ------- VAPOR RECOVERY SYSTEM USING OVERTURN RAIL (Courtesy of the Heil Company) ------- TANK TRUCK VAPOR RECOVERY COSTS • ADDITION OF VAPOR RECOVERY $2400/TANK • BOTTOM LOADING CONVERSIONS $4000/TANK • ANNUAL MAINTENANCE $1600/TANK • ANNUAL LEAK TIGHT TEST $ 150/TANK ------- STORAGE TANP ------- SLIDE 1 STORAGE TANKS _________________ Fixed Roof Floating Roof Pressure RACT All Tanks 40,000 gal @ v.p. 1.5 psia RACT (For Fixed Roofs) Internal Floating Cover SLIDE 2 SLIDE 3 SLIDE 4 FiXED ROOF TANK WITH INTERNAL FLOATING COVER ------- SLIDE S CONTACT INTERNAL FLOATING ROOF COLIPII WALL SLIDE 6 NON-CONTACT INTERNAL FLOATING ROOF s5 ------- SLIDE 7 SLIDE 8 SLIDE 9 RACT (for External Floating Roofs) secondary rlm.mounted seal covering the primary seal EXTERNAL FLOATING ROOF TANK p ’ r POMOOfl Dou Oc TYPES OF EXTERNAL FLOATING ROOFS ------- SLIDE TO INTERNAL FLOATING ROOF TANK SEALS Resilient Foam-Filled Seals Wiper Seals RESILIENT FOAM-FILLED SEAL (VAPOR-MOUNTED) Tank wall Contact internal floatina : :,: %V I ,......., /(aluminuin sandwi cPip apel / Resilient foam-filled seal • RESILIENT FOAM-FILLED SEAL (LIQUID-MOUNTED) S SLIDE 11 roof roof) SLIDE 12 Resilient foam—filled seal Contact internal floetina roof (Dan-type steel roof) Tank wafl ------- SLIDE 13 ELASTOMERIC WIPER SEAL Non-contact internal floating roof EXTERNAL FLOATING ROOF TANK PRIMARY SEALS • Metal I Ic Shoe Seals • Liquid-Filled Seals • Resilient Foam Log Seals Elastomeric wiper seal seal ring Tank wall Pontoon SLIDE 14 SLIDE 15 METALLIC SHOE SEAL ------- SLIDE 16 LIQUID-FILLED SEAL WITH WEATHER SHIELD Metallic Weather Tank i1 Shie1d Scuff Band Floating roof Liquid filli tube - - SLIDE 17 RESILIENT FOAM-FILLED SEAL WITH WEATHER SHIELD Metallic Weather 4 Floatinq roof Sea1 fabric Resilient foam : ::r space ------- SLIDE 1.8 RESILIENT FOAM-FILLED SEAL WITH WEATHER SHIELD SLIDE 19 coMwy IWR $•aI ------- SLIDE 20 “SWEATING TANK - LIQUID IS COLD AND AIR IS WARM AND MOIST” Tank wal Cl i Weather SEcoNDARY-rIPE SEAL SLIDE 21 “STORAGE TANK WITH EXTERNAL FLOATING ROOF” SLIDE 22 ------- SLIDE 23 “INSPECTORS APPROACHING EXTERNAL FLOATING ROOF” SLIDE 24 “PONTOON TYPE OF EXTERNAL FLOATING ROOF” SLIDE 25 “PONTOON TYPE OF EXTERNAL FLOATING ROOF” ------- SLIDE 26 SLIDE 27 SLIDE 28 TM PAN TYPE OF EXTERNAL FLOATING ROOF” “CENTER DRAIN TM “GUIDE ROD TO KEEP ROOF FROM ROTATING” ------- SLIDE 29 “GUIDE ROD TO KEEP ROOF FROM ROTATING° “WEATHER SHIELD REMOVED TO SHOW SHOE OF PRIMARY SEAL” SLIDE 30 ------- SLIDE 31 SLIDE 32 “ROOF LEG SUPPORT” “LIQUID LEVEL GAUGE” ------- SLIDE 33 SLIDE 34 SLIDE 35 “INSPECTOR PULLING BACK THE SECONDARY SEAL” ,. ‘F r “SECONDARY SEAL HAS FALLEN INSPECTOR IS CHECKING FOR LEAKS WITH CATALYTIC COMBUSTION ANALYZER’ “SECONDARY SEAL PULLED BACK SHOWING PRIMARY SEAL” ------- SLIDE 36 “INSPECTOR MEASURING SECONDARY SEAL GAP WITH GAUGE” STORAGE TANKS Enforcement Problems: • Internal floating roofs • Many tanks • Gap measurements • Vapor pressures STORAGE TANK INSPECTiON FORM INSPECTOR: SOURCE: RECORDS: TANK: TANK CONTENTS: VAPOR CONTROL EXPLOS1 METER READ I NGS: Name, date, time, ambient temperature Name, address, plant contact Maintenance, yearly inspections, date of last inspection Capacity, % full, dimensions, color, contents, ID number, records, design Average monthly vapor pressure, maxi- mum temperature, temperature and vapor pressure during inspection Type, description, capacity SLIDE 37 SLIDE 38 Location, % scale ------- SLIDE 39 STORAGE TANK INSPECTION CHECKLIST LEVEL 1 Examine Records for: • 6-month seal inspection through roof • Cover and seal inspection when tank is empty • If no vapor recovery system-records of average monthly storage temper- ature and true vapor pressure SLIDE 40 STORAGE TANK INSPECTION CHECKLIST LEVEL 2 All Level 1 items: • Examine internal floating roofs through inspection hatch • Examine floating roof seals for vis- ible gaps • All openings equipped with lids except stub drain • All lids closed ------- STORAGE TANK PUBLICATIONS 1. Control of VOC from Petroleum Storage in External Floating Roof Tanks. U.S. Environmental Protection Agency. Research Triangle Park, N.C. EPA— 450/2-78-047. 2. Control of VOC from Petroleum Storage in Fixed R of Tanks. U.S. Environ- mental Protection Agency. Research Triangle Park, N.C. EPA-450/2-77— 036. 3. Control of Volatile Organic Compoynd Emissions from Volatile Liquid Stor- age in Floating and Fixed-Roof Tanks. U.S. Environmental Protection Agency. Research Triangle Park, N.C. Preliminary Draft. January 1981. ------- SUBPART XX — BULK GASOLLNE TERMINALS ------- NSPS REVtEt SUBPART X ( - Bulk Gasoline Termina1s t. Introduction 11. Description of Standards A. Applicability B. Emission Limits C. Tank Truck Requirements 0. Pressure Requirements E. Reporting and Recordkeeping F. Reconstructlon III. Ne VOC Test Met iods A. Reference Methods 2A 23. B. Reference Methods 25A, 25B C. Reference Method 27 D. Test Procedures IV. Discussions ------- BULK TERMINAL NSPS APPLICABILITY O LOADING RACKS WHICH DELIVER PRODUCT INTO GASOLINE TANK TRUCKS’ O NE’ J MODIFIED P OR RECONSTRUCTED TERMINALS WHICH COMMENCED CONSTRUCTION AFTER DECEMBER 17 , 1980. O RECONSTRUCTIONS, WHICH STARTED BEFORE AUGUST 18 1983 PERFORMED IN ORDER TO COMPLY WITH STATE REGULATIONS WELI. NOT HE CONSIDERED UNDER THIS STANDARD. 3 Z—2 ------- BULK TER MINAL NSPS EIIISSION LIMITS O AFFECTED TERMINALS WITH NEW VAPOR PROCESSING 35 MG/LITER Eg60.502(afl o AF crED TERMINALS WITH EXISTING VAPOR PROCESSING SYSTEMS 80 MG/LITER C 60.502(c)] ------- BULK TERMINAL NSPS TANK TRUCK REQUIREMENTS ( 6O.5O2(E) o LOADtNGS MUST BE LIMITED TO VAPOR-TIGHT GASOLINE TANK TRUCKS o PROCEDURES TO BE USED BY TERMINAL OPERATOR OBTAIN VAPOR TIGHTNESS DOCUMENTATION REQUIRE THAT TANK I.D. NUMBER FOR EACH LOADING SE RECORDED CROSS CHECK TANK I.D. WITH DOCUMENTATION ON FILE - NOTIF’f TANK TRUCK OPERATOR IF TRUCK LOADED WITHOUT DOCUMENTATION ON FILE — TAKE STEPS TO ASSURE NONVAPORTIGHT TRUCK DOES NOT REL.OAD AT TERMINAL 312 -4 ------- BULK TERMINAL NSPS PRESSURE REQUIREIIENTS C 6Q.5O2(H)(r)( )] o BACKPRESSURE AT TANK TRUCK SHOULD NOT EXC!! kSO MM WATER a No TERMINAL PRESSURE RELIEF VENTS SHALL OPEN BEFORE 450 MM WATER o CHECK VAPOR LINE FOR LEAKS ONCE PER MONTH 312-5 ------- BULK TERMINAL NSPS REPORTING AND RECORDKEEPING KEEP ON FILE: O TANK TRUCK DOCUMENTATION UPDATED ONCE/YEAR o MONTHLY LEAK INSPECTIONS REPORTS o NOTIFICATIONS OF LOADINGS OF NON—VAPOR TIGHT TRUCKS O RECORDS OF ALL REPLACEMENTS OR ADDITIONS TO VAPOR PROCESSING SYSTEM 312—6 ------- BULK IERPIINAL NSPS RECONSTRUCTI ON o SPECIFIED “NORMAL” MAINT!NANC! tTE ’1S ‘4lLL NOT COUNT TOWARD RECONSTRUCTION o “FIXED CAPITAL COST” FOR DETERMINING RECONSTRUCTION IS BASED on 2-YEAR PERIOD 312-7 ------- ASSOCLAT WITh PROPOSE EUU< 1 INPL ST PDS • MethcdsZA,2B • Mettiods 2 A 253 3 2-8 ------- R - 1cE FLOW RATE ME CDS (1E HaD2A • AU.. DUCrS ND PIPES • DIPEC W’flINUAL MEASURE MEtHODS • V PCR INC IN ATDR HAUST INDIRE.ME4SURE 1!’1T * QV!INES R E ME11 ODS • CARE N AltIl ‘AT LAL EALAN E 312-g ------- VOC CONCENTRATION MEASUREMENT REFERENCE METHOD ZSA • FLAME IONIZATION ANALYZER • DIRECT EXTRACTION • CONTINUOUS MEASUREMENT REFERENCE METhOD 25B • SAI’IE AS 25A • NON—OISPERSIVE INFRARED ANALYZER 312-10 ------- VAPCP tNC NERA1 EXHAIJSTVCLUM! (METhCO 22) Ctj1UT ; . V SEMEN 1 •vCC CZNT Afl i (M ThCO U. 1cr4T ATTCN cM r cQ tc CC t4 MET C t ; I • INLaT uEASUREM N?3 VC cN NT ATT 1 (MeT Ic Z R ICUJM M T.4CQ 12—1i ------- TANK TRUCK TEST METHODS • CTG • REFERENCE METHOD 27 312-12 ------- STAGE Il/ONBOARD CONTROVERSY ------- ------- Figure 1A. SChEMATIC DIAGRAM OF HANIIWDED IIALANCE SYSTEM Figure lB. SCIIFWtTIC DIAGRAM OF NON-HAt I IFO [ D [ Ij BALAtICI? SYSTEM UrL$ $aIIIIs it a iioiiuG S.flCATIWII ________ VUI U IIMU — — — III) Isi LINE$ ------- 4 - 5. FLEXIBLE RUBBER BOOT (CUT AWAY VIEW) 6. NOULE BODY 7. VAPOR hOSE 8. PRODUCT HOSE 1. VEhICLE FILLNECV 2. NOZZLE SPOUT 3. IWBUER FACEPLATE 4. VAPOR PATCH Balance Systeni Vapor Recovery Nozzle ------- VAPOR SCREZN Sourca: Re jacket Division of Wei1 McLain Co. ,Inc., Davenpcrt,Iowa ‘I I VAPOR 14EC ( VALVE z = PRESZURE TAP AND TUBING S11€AR JOINT Aspirat r-Ass1 St £ystam ------- TO ATM VENT + VAPOR COLLECTION ________ VAPOR LINE __ — LI UI LINE Oir ct Incineration Syst3rn ------- AVERAGE CAPITAL COSTS FOR VAPOR RECOVERY SYST 1Sa Mumber of Dispensers Vapor Balance System Vac .zum—Assist Hybrid System System 2 $4,300 $9,800 $5,200 3 4,500 10,500 5,600 6 6,300 12,200 8,500 9 7,900 14,000 10,600 12 9,600 16,300 13,200 15 11,600 18,900 16,100 E5T 1ATES OF ANNUAL 0&1 COSTS FOR VAPOR RECOVERY S’fSTE!IS Number of Nozzles Balance Vacuum -Assist’ Hybrid 2 $270 $425 $270 3 330 4.60 320 6 510 550 450 9 590 650 590 12 870 750 720 15 1,050 840 360 Source: EPA estimates ------- PURGE CONTROL CARBURETOR GASOLINE GASOLINE TANK NOZZLE GA $ OLINE VAPORS CARBON CANISTER STORAGE ------- P uI. P P MCCPCAT1CN5 CTA Y SEAL RCTAR’i’ SV .L / 1 AP :cc MCD tPCAi CN RC1A ’ SEAL / L!AC ic”r ------- Table I Cast astimates For 0rt-Boar Svstarn PINTO CAPRICE Charcoal @ $1.25/ # $3.58 $4.96 Canister arid Valves 2.00 2.50 Tank. Modifications 0.50 0.50 Hoses arid Tubing 1.72 1.57 Assembling and Installing @ $20/hr 1.50 1.50 SubTotal $9.30 $11.03 Manufactures Overhead of 8O 7.44 8.82 Total $16.74 $19.85 ------- VOC DEFECTION INSTRUMENTS AND INSPETION SAFElY TIPS FIELD INSPECTION TECHNIQUES ------- VOC DETECTION INSTRUMENtS AND INSPECTION SPFEtY TIPS ------- SLIDE •L “VOC EMISSION FROM PUMP SEAL DRAIN” “ ICC EMISSION FROM VALVE” “FLANGE t ’ Possible Leah Areas SLIDE 2 SLIDE 3 SLIDE 4 SIMPLE MECHANICAL SEAL ------- SLIDE 5 GLOBE VALVE Possible Leak Areas “SCREENING OF VALVE FLANGE” “MONITORING SURVEY LOG SHEET” “GAS CYLINDER” SLIDE 6 SLIDE 7 SLIDE 8 SLIDE 9 “GAS CYLINDER READY FOR SHIPPING” ------- SLIDE TO “SCREENING OF COMPRESSOR” SLIDE 11 “LEAKING SAMPLE VALVE” SLIDE 12 “SCREENING OF VALVE BANK” SLIDE 13 FLAME IONIZATION DETECTOR (FID) PRINCIPLE OF OPERATION The sample stream ‘ss introduced into a hydrogen flame. Upon combustion In the flame, organic compounds produce ions which are collected at an electrode. The resultant current flow Is measured with an electrometer. ------- SLIDE 14 DIAGRAM OF A R.AME IONIZA11ON DETECTOR (AD) SAMPLE OUTLET I GN I TER BASE BURNER JET Supply 5MP h INLET ------- SLIDE 15 VOC ANALYZER USING RD DETECTOR ELECTROMETER/ AMPLIFIER STRIPCHART RECORDER (OPTIONAL) PANEL-MOUNTED OR HAND-HELD METER _______ .‘ SAMPLE INTAKE PART I CLE “CENTURY SYSTEMS’ OVA-108 - A TYPE OF FID” HYDROGEN SUPPLY FLAME HOUSING GNITER ALARM SAMPLE FILTER FLOW METER SLIDE 16 ------- SLIDE 17 t1 SCREENING OF VALVE FLANGE” SLIDE 18 “SCREENING OF VALVE FLANGE” SLIDE 19 “SCREENING OF PNEUMATIC VALVE STEM” SLIDE 20 “SCREENING OF PUMP SEAL” SLIDE 21 “SCREENING OF SAMPLE VALVE” SLIDE 22 “SCREENING OF VALVE BANK” ------- SLIDE 23 “SCREENING OF PUMP SEAL” SLIDE 24 “ANALYTICAL INSTRUMENT DEVELOPMENT, INC. (AIDS), MODEL 712 — A TYPE OF FID” SLIDE 25 “AIDS PROBE” SLIDE 26 “TOP OF AIDS” SLIDE 27 “AIDS EMISSION CONCENTRATION DISPLAY” ------- SLIDE 28 PHOTOIONIZATION DETECTOR (PID) PRINCIPLE OF OPERATION Ions are produced by an ultraviolet radiation source rather than a flame. The ions are collected at an electrode and the resultant current flow is measured with an electrometer. SLIDE 29 DIAGRAM OF PHOTOIONIZATION DETECTOR (PlO) LAMP NiGH- ___________________ VOLTAGE COMTACT LAMP COLLECTION r b 0 R IONIZATION ’ CHAMEER SAMPLE I NLET ------- SLIDE 30 VOC ANALYZER USING PID DETECTOR ELECTROMETER/ “HNU SYSTEMS’ P1—101 — A TYPE OF P 10” P1 D HOUSING ELECTRODE SAMPLE INTAKE FILTER CHARCOAL El LTER I LUll ON AIR INTAKE SLIDE 31 SLIDE 32 “HNU EMISSION CONCENTRATION DISPLAY” ------- SLIDE 33 “HNU AND PERIFERALS” SLIDE 34 “SCREENING OF PACKING GLANL” SLIDE 35 “SCREENING OF PUMP SEAL WITH HNU” SLIDE 36 “SCREENING OF VALVE” SLIDE 37 CATALYTIC COMBUSTION DETECTOR PRINCIPLE OF OPERATION This system usel a dual “hot-wire” cell in which one of the wires is coated with a catalyst to promote oxidation (combustion) of organic compounds present in the sample stream. The heat released during the com- bustion process results in a resistance change in the coated wire when compared to the reference wire. This imbalance produces a signal which is related to the VOC con- centratlon. ------- SLIDE 38 SAMPLE SLIDE 39 DIAGRAM OF A CATALYflC COMBUSTION DETECTOR CELL SA$PI E OUTLET INLET CATALYTI F I LAMENT TO WHEATSTONE ‘BRI DGE “BACHARACH INSTRUMENTS’ TIV SNIFFER - A TYPE OF CATALYTIC COMBUSTION DEVICE” ------- SLIDE 40 “TLV SNIFFER” SLIDE 41 “TLV SNIFFER” SLIDE 42 DISPERSIVE INFRARED ADSORPTION (IR) PRINCIPLE OF OPERATION A dispersive IR detector involves a direct adsorbance measurement at a particular wavelength selected by a filter or grating monochrometer. ------- SLIDE 43 DIAGRAM OF DISPERSIVE INFRARED (IR) DETECTOR CII VAR I ABLE FILTER SLF PREAl PLIFII IMARY MIRROR SLIDE 44 “B IOPAK” ------- SLIDE 45 INSPECTION SAFETY TIPS SLICE 46 THE INSPECTOR SHOULD • Identify Potential Hazards • Take Appropriate Precautions SLIDE 47 SAFETY PROBLEMS • Physical Injury • Potentially Explosive Areas • Electrical Shock • Exposure to Harmful Chemicals • Fire and Pollutants • Exposure to Heal and Cold SLIDE 48 PERSONAL PROTECTIVE EQUIPMENT • Hard Hat • Ear Plugs • Safety Glasses • Long-Sleeved Shuts • Steel-Toed Shoes • BioPak ------- SLIDE 49 FID SAFETY CONSIDERATIONS • User should consult manufacturer’s literature. • Primary concern is possibility for explosion. • Operator should make sure that flame arrest- ors are properly installed. SLIDE 50 P lO SAFETY CONSIDERATiONS • Electrical system has potential to create sparks which could Initiate an explosion. • Any maintenance or repair work must be performed away from potential sources of VOC contamination. SLIDE 51 CCA SAFETY CONSIDERATIONS • Possibility for explosion. • Servicing and maintenance procedures should not be performed In ar area where high VOC levels might be present SLIDE 52 IR DEViCE SAFETY CONSIDERATIONS • Electrical system has potential to create sparks which could initiate an explosion. • Any maintenance or repair work must be performed away from potential sources of VOC contamination. ------- FIELD INSPECTION TECHNIQUES ------- SLIDE 1 PREINSPECT 1ON SLIDE 2 • Check source files • Understand vapor controls • Determine level of effort • Know regulations • Review inspection procedures • Contact source with date, available records, required- operating data, and safety requirements. • Notify other agencies • Obtain appropriate check lists • Calibrate equipmenl SLIDE 3 EQUIPMENT CHECKLiST FOR INSPECTION OF GASOLINE MARKETING ELEMENTS • General purpose • For leak checking and rough check for vapor recovery unit • For vapor balance tests • For level 3 source test GENERAL PURPOSE • Inspection forms and checkhsts • Tape measure • Camera • Thermometer (0-120°F) • Flashlight • Safety gear • Probes (to insert between tank seals and wall) • Chalk (for gapping distances on tank wall) • Container for gasoline sample (optional) ------- SLIDE 4 FOR LEAK CHECKING AND ROUGH CHECK OF VAPOR RECOVERY UNIT • Combustible gas detector or sonic detector (dual range; 0-100°h LEL pentane, 0-100% V pentane) SLIDE 5 FOR VAPOR BALANCE TESTS • Plastic bags for vents or tank truck domes • Tape to seal bags SLIDE 6 SAFETY AND CREDENTIALS ------- SLIDE 1 SLIDE 2 INSPECTION TECHNIQUES Levels of effort • Equipment requirements • Check list FIRST LEVEL OF EFFORT SLIDE 3 INPUT 1. 2 manhours 2. Average inspector 3. Tape measure, camera 4. (Desirable option: combus- tible gas detector) OUTPUT 1. Work practices OK 2. No gross physical defects. 3. If 1. and 2., then 8 00 /a probable capture efficiency. 4. Determine if Level 2 or 3 required SECOND LEVEL OF EFFORT INPUT 1. 2 to 8 manhours 2. More technically expenenced inspector 3. Bilevel combustible gas detector 4. Examine site records 5. Inspect floating roof tanks 6. Check for broken pipe connectors OUTPUT 1. Leak tight 2. If 1. and Level 1 O.K., 95% probable capture efficiency 3. Required records O.K. 4. Determine whether a Level 3 inspection is needed includ- ing vapor control system tests 5. Floating roof seals defect free ------- SLIDE 4 THIRD LEVEL OF EFFORT INPUT OUTPUT 1. 150 manhours minimum 1. Level 3 regulations (90% 2. 3-man team minimum efficient, 80 mg/i) 3. Possible specialists (crafts) 2. Proof of process efficiency 3. Greatest threat of sanction or cost (to the source) to prove compliance SLIDE 5 FOR LEVEL 3 SOURCE TEST (Vapor Recovery UnIt) General • All items for Level 1 and 2 inspections • Barometer • Tools and fittings to connect test equip- ment to vapor recovery unit: 1. Drill 2. Tubing connectors and adapters 3. Tubing, polyethylene and vinyl 4. Wrenches, channel-lock, other assorted tools 5. Stopwatch SLIDE 6 FOR LEVEL 3 SOURCE TEST (Vapor Recovery Unit) At Vapor Collection Test Point • Gas volume meter, sized for maximum possible flow • Thermocouple (0 1 500 F) with recorder • Inclined manometer (0-10” water) or calibrated pressure transducer • Total hydrocarbon analyzer (FID or NDIR: 1-100% by volume as propane with recorder) • (Optional) Bag samp’er with pump for GC samples ------- SLIDE 7 FOR LEVEL 3 SOURCE TEST (Vapor Recovery Unit) At Vapor Recovery Unit Vent • Gas volume meter, sized for maximum possible flow • Thermocouple (0-150°F) with recorder • Inclined manometer (0-10” water) or calibrated pressure transducer (if gas meter pressure not equal to barometric) • Total hydrocarbon analyzer (FID or NDIR: 1-20% by volume as propane for vapor recovery: 0-1000 ppm as propane for incineration) with recorder • (Optional) Bag sampler with pump for GC samples SLIDE 8 TEST OF A VAPOR RECOVERY SYSTEN SLIDE 9 INSTALLING TEST EQUIPPiENT” SLIDE 10 VAPOR RECOVERY SYST TEST EUIP ENT ------- SLIDE 11 “DRY GAS METER ON INLET” SLIDE 12 GENERAL INFORMATION GASOLINE BULK PLANTS INSPECTOR: Name, date, time, ambient temperature. SOURCE. Name, address, plant contact. FACILITY: Description, how refueled, capacity WORK SCHEDULE Hours per day, shifts, hours per year. TANKS: Capacity, type roof, contents. LOADING RACK: Number, type loading, capacity. % full. VAPOR CONTROL: Type, capacity SLIDE 13 TANK TRUCK DESCRIPTION INSPECTOR: Name, date, time, ambient temperature. TRUCK: General (owner, license/ID, where inspected, driver’s name). Type (straight, semi, full trailer, number of compartments). Capacity (each compartment, contents). ------- SLIDE 14 GASOLINE TANK TRUCK INSPECTION CHECKLIST LEVEL I • Check certifications and verify sub- merged fill • Smelt, listen, and look for visible signs of vapor teaks • Check for warped or damaged lids and gaskets • Verify valve closures work smoothly • Inspeci gaskets, hoses, and con- nections in vapor recovery system for damage SLIDE 15 “LEAK CERTIFICATION AND TANK NAME PLATE” SLIDE 16 GASOLINE TANK TRUCK INSPECTION CHECKLIST LEVEL 2 All Level 1 inspection items: • Use combustible vapor detector around all potential sources. • Perform dome cover plastic bag test (San Diego Method) SLIDE 17 GASOLINE TANK TRUCK INSPECTION CHECKLIST LEVEL 3 All Level 1 and 2 items: • Perform California Air Resources Board leak test on the gasoline tanks ------- SLIDE 18 ursa iuvmi uu AIR UNTIl ATM 0$ PiE If 3 LOASING TERMINAl. $TSN1IE TAlE W I LOC*TI S PRODUCT PROM I. C*s J DtsPt sLI m 1. T T Et T* c .ucti T T IWT 3. _ I1 ItS? JU? SLIDE 19 1. VENT 7. ‘ “ett 3. (‘ISSION RECOVER’ P7P NG,Oy(Dyuvi RAILS 1. Oviir ILL SENSOR S. PV O $H(JTQrF RECEPTACLE 6. ENISSION CONTROL JTLET 7. DECTOR Wfl .( S. VAIV . LI JID U 10. tNITOLD Crss .%sct ; P1a r •f TiM ?r k ------- SLIDE 20 “TRUCK LOADING RACK” SLIDE 21 SUBMERGED Fill TRUCK LOADING RACK SLIDE 22 “LOCAL. INSPECTORS APPROACHING GASOLINE TERMINAL” SLIDE 23 “VALVES” SLIDE 24 “VAPOR RECOVERY HOSE” SLIDE 25 “VAPOR RECOVERY HOSE” SLIDE 26 “INSPECTOR CHECKING HOSE FOR LEAKS” ------- SLIDE 27 “POCKET VALVE” SLIDE 28 “VAPOR LINE IN MIDDLE OF TRUCK” SLIDE 29 “SCUFF RINGS ON VAPOR LiNE” SLIDE 30 “INSPECTOR CHECKING FILL LINE FOR LEAKS” SLIDE 31 “CLOSE—UP OF FILL LINE” SLIDE 32 “TOP LOADING RACK WITH VAPOR RECOVERY” SLIDE 33 “OPERATOR CONNECTING LOADING ARMS” ------- SLIDE 34 “HATCH COVER GASKET” SLIDE 35 “HATCH COVERS WITH VAPOR RECOVERY COLLECTION SYSTEM AND LIQUID LEVEL SENSORS” SLIDE 36 ‘LOADING ARMS ATTACHED TO TRUCK” SLIDE 37 “SCREENING OF TOP LOADING OPERATION” SLIDE 38 “EXPLOSIMETER” SLIDE 39 STORAGE TANKS Enforcement Problems: • Internal floating roofs • Many Ian s • Gap measurements • Vapor pressures ------- TANK TRUCK LEAI(AGE ------- TRUCK LEAKA EMISSIONS ------- P OCE OR rAtdsc rrnjcx OUTLET LIAKAGI U$53ON3 EMI 1ON$ Tank Truck Loading YNK u JIo VAPON Service Station Stage I Delivery ------- BOOT COVER VENT VAL’1t OVERFILL SENSOR COME LEO SEAL 0’! ERTURN VAPOR RETURN RAIL CLAMPS SHELL BASE RING GASKET Ma4or Tank Truck Leakage Sources ------- P FOS PI ID PROIJLGATED TANK TRUCK LEAKAGE GULATIG4S ------- Connecticut Tank Truck Regulations Section 2 Subsection (b) of Section 22a—174-20 of the Regulations of Connecticut State Agencies is amended by the addition of subdivisions (b)(l1) through (b)(14) inclusive as follows: (NEW) ( b)(l1 ) On and after July 1, 1985, no person who owns or operates a tank truck that carries gasoline and recieves the gasoline from a loading facility subject to the provisions of subdivisions (b)(l) or (b)(2) or delivers the gasoline to a dispensing facility subject to the provisions of subdivisions (b)(5) or (b)(6) shall cause or permit the tank truck to be loaded or unloaded unless the tank truck: (A) is tested annually between March 1, and June 30; (3) sustains a pressure change of no more three (3) inches of water in five (5) minutes when pressurized to a gauge pressure of eighteen (18) inches of water or when evacuated to a gauge pressure of six (6) inches of water during the testing; (C) displays a stencil near the U.S. Department of Transportation markings required by Title 49 Code of Federal Regulations Part 177.824 which shows the initials DEP and the date of the last test. (b)(12) The owner or operator of any tank truck which fails to meet the requirements oS subparagraph (b)(ll)(3) shall repair and retest the tank truck within fifteen (15) days. (b)(13) No person shall perform a test required by subdivision(b)(l1) unless: (A) the Department’s Air Compliance Unit is notfied at least we t -four (24-)---—hours-- - in advance of the time and ‘ location of the test; (3) the test is performed in accordace with Method 27 as shown in the Federal Register of December 20, 1980 on page 83152 (45 FR 83152) or in an other manner approved by the Commissioner in writting. (b)(14) Notwithstanding the provisions of subdivisions (b)(11) through (b)(13) inclusive, the Commissioner may accept equivalent test performed in the states of Massachusetts, New Jersey or New York. ------- THE COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OP ENVIRONMENTAL QUALITY ENGINEERING DIVISION OF AIR QUALITY CONTROL ONE WINTER STREET BOSTON, MASSACHUSETTS 02108 PROPOSED AMENDMENT OF REGULATION 310 CMR 7.00 and 7.02 ___ FOR THE CONTROL OF AIR POLLUTION IN THE BERXSRIRE AIR POLLUTION CONTROL DISTRICT PIONEER VALLkY AIR POLLUTION CONTROL DISTRICT MERRIMACK VALLEY AIR POLLUTION CONTROL DISTRICT METROPOLITAN BOSTON AIR POLLUTION CONTROL DISTRICT CENTRAL MASSACHUSETTS AIR POLLUTION CONTROL DISTRICT SOUTHEASTERN MASSACHUSETTS AIR POLLUTION CONTROL DISTRICT REGULATORY AUTHORITY: M.GIL. c. 111, SectIon 1L 2A_1Z 2D PROPOSED, MARCH 198k ------- BACKGROUND The Clean Air Act as amended by Congress in August, 1977, •required each state to determine its compliance with the health and welfare—related National Ambient Air Quality Standards for the criteria pollutants. States with ambient air quality levels that violate federally—established standards of any of these pollutants are required to revise their State Implementation Plan and adopt strategies to attain and maintain the standards. The 1977 Amendments also changed the deadline for compliance with air quality standards for many of the criteria pollutants. In the case of ozone and carbon monoxide, the amendments allowed extensions until December 31, 1987, provided certain requirements were met; Massachusetts received such an extension in 1979. One of the extension requirements is the Commonwealth’s adoption of regulations requiring Reasonably Available Control Technology (RACT) on sources emitting volatile organic compounds. Recommended control requirements are presented in a series of documents — Control Technique Guidelines (CTG) — published by the U.S. Environmental Protection Agency. According to the CTGs, the recommended levels of control represent “presumptive norms” which can be achieved by the application of RACT. RACT is defined as the lowest emission limit that a particular source can meet y applying control equipment that is reasonably available, considering technological and economic feasibility. One of the CTG source categories is leaks from gasoline tank trucks and vapor recovery systems. Massachusetts has regulated emissions from gasoline bulk plants, gasoline terminals, and gasoline dispensing facilities (i.e. service stations) and the tank trucks servicing them for a number of years. Massachusetts is now proposing to adopt a regulation to further control emissions from gasoline tank trucks, in compliance with EPA requirements. The proposed regulation reflects EPA guidance on RACT. THE REGULATON The Department’s regulations currently require that a minimum of 90% of total emissions from certain gasoline loading racks to tank trucks (310 CMR 7.02(12)a4 and 7.02(12)a5 and from specified tank trucks to stationary tanks (310 CMR 7.02(12)b 2) be captured. To control these emissions, the vapors being emitted from the tank truck or the stationary tank must be captured. —1— ------- The proposed amendment would require that tank trucks be tested and certified (during the months of March through June) annually to assure they do not leak. The certification will expire on July 1 of the year following the test. AU. tests shall be made by, or under the direction of a person qualified by training and/or experience in the field of air pollution testing or tank truck maintenance and testing. The tests may be administered by the owner or operator of the tank truck. During the test, the tank should sustain a pressure change of no more than 3 in. of H 2 0 in 5 minutes when pressurized to a gauge pressure of 18 in. of }120 or evacuated to a gauge pressure of 6 in. of H 2 0. After passing the certification test, the owner or operator of the tank truck should stencil the letters DEQE and the date (DEQE—date) the tank truck passed the test on the side of the tank. The Department will accept certifications from the New York Department of Environmental Conservation and the Connecticut Department of Environmental Protection as satisfying the requirements of this regulation. The Department will measure emissions from tank trucks at the terminals with a combustible gas detector to determine if the tanks are leaking. ECONOMIC AND ENERGY IMPACTS Based on data from the U.S. Environmental Protection Agency (EPA), there are approximately 700 tank trucks in the Commonwealth that will be subject to this Regulation. Based on emission information from EPA, it is estimated that implementation of the certification program will reduce volatile organic compound emissions by over 2100 tons per ye r. This is a savings of 680,000 gallons per year of gasoline. The cost of program is calculated to be: Initial cost — 700 tank trucks X k compartments/truck X $500—1000/compartznent $1,L 0O,00O — $2,800,000. Cost to perform annual vapor tightness testing including one—half day downtime — $300/truck X 700 trucks $210,000/year Savings due to reduced gasoline emissions — 680,000 gallons of gasoline/year X $1.10/gallon. $7L 8,00Q/year Not including initial cost, this represents an annual savings of $538 ,000. —2— ------- 310 CMR: ARTMENT OF ENVIRONMENTAL c. aLITY ENGINEERING Legefl4 Please Note The Department is proposing certain additions to its Air Pollution Control Regulations concerning motor vehicle fuel tank trucks. The bulk of the existing regulations dealing with motor vehicle fuel loading racks and dispensing facilities are reproduced here for the reviewer’s information. These regulations are not applicable to the transfer of diesel fuel. Proposed additions to the.r’egulatioris are identified as those words contained in double brackets [ C Li. Proposed deletions to th& regulations are contained within the symbols << >>. Definitions: [ C Tank Truck means a truck or trailer equipped with a storage tank and used for the transport of motor vehicle fuel from sources of supply to stationary tanks. fl 310 CMR 7.02(12)(a ) 4. Any person owning, leasing or controlling a loading rack with an average daily throughput (1/300 of the actual annual throughput) equal to or greater than 20,000 gal .ons which transfers organic material with a true vapor pressure of 1.5 psi or greater at 6o°F into tank trucks, trailers, or other contrivances shall transfer by means of submerged fill and install a vapor recovery system which shall attain a minimum of 90% capture of total emiss ions as determined by the Department, that has been approved by the Department in writing in accordance with the provisions of 310 CNR 7.02(2). The provisions of 310 CMR 7.02(12)(a)’ shall not apply to the loading of motor vehicle fuel tanks. 5. CM, MB, MV, PV, SM. On and after July 1, 1980, any person owning, leasing, or controlling a facility with an average daily throughput (1/300 of the actual annual throughput) less than 20,000 gallons which stores and transfers organic material with a true vapor pressure of 1.5 psi or greater at 600 P. into tank trucks, trailers, or other contrivances shall transfer by means of submerged fill, and shall install a system, which shall attain a minimum of 90% capture of total emissions as determined b7 the Department from storage and transfer operations, that has been approved by the Department in accordance with the provisions of 310 CMR 7.02(2). The provisions of this section shall not apply to (1) the loading of motor vehicle fuel tanks and (2) Dukes and Nantucket Counties. [ [ 6. Any person owning, leasing or controlling a facility subject to 310 CMR 7.02(12)(a) 1 or 7.02(12)(a)5 shall: —3— ------- 310 CMR: DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING a. riot allow any tank truck to be filled with a motor vehicle fuel with a true vapor pressure greater than 1.5 psi. at 60°F at the facility unless notified by the tank truck owner or operator that the tank truck is in compliance with the requirements of 310 CMR 7.02(12)(o)1; and b. submit an annual report to the Department by February 15 of each year covering the period January 1 to December 31 of the previous year, arid showing for each tank truck which delivered or picked up motor vehicle fuel with a true vapor pressure gr’eater than 1.5 psi at 600P at such facility, such tank truck owner’s or operator’s name and the license number of the tank truck. The first report will be due February 15, 1986, and shall cover the period July 1 to December 31, 1985. fl (b) Distribution of Motor Vehicle Fuel 1. Any person owning, leasing or controlling a stationary tank having a capacity greater than 250 gallons but less than 40,000 gallons into which motor vehicle fuel with a true vapor pressure of greater than 1.5 psi at 60°F is transferred from tank truck, trailer, or other contrivances shall be equipped with a system for submerged fill which has been approved by the Department. 2. CM, MB: MV, PV, SM. On or after July 1, 1980, no person shall cause, suffer, allow or permit the transfer of motor vehicle fuel having a true vapor pressure equal to or greater than 1.5 psi at 600F from any delivery vessel to a fuel handling facility having a stationary tank capacity equal to or greater than 2000 gallons unless the displaced vapors are processed by a system that has been approved by the Department in accordance with provisions of 310 C ffi 7.02(2) and which prevents release to the atmosphere of no less than 90 percent by weight of organic materials in said vapors. The provisions of 310 CMR 7.02(12)(b) shall not apply to: a. stationary tanks having a capacity less than 550 gallons equipped with submerged fill lines, used exclusively for the fueling of implements of husbandry. b. stationary tanks equipped with floating roofs or their equivalent. << 3. For the purpose of 310 CMR 7.02(12)(a) and 7.02(12(b) any emission or efficiency testing required by the Department shall be in accordance with methods approved D7 the Department under the provisions of 310 CMR 7.13.>> [ [ (c\ Motor Vehicles Fuel Tank Trucks . On and arter July 1, I9 5, no person owning, leasing, or controlling a tank truck that carries motor vet jcie fuel with a true vapor pressure of greater than ------- 310 CMR: DEPARTMENT OP ENVIRONMENTAL QUALITY ENGINEERING from a facility subject to 310 C!’ 7.02(12)(a)14 or 7 .02(12)(a)5 or delivers the fuel to a facility subject to the requirements of 310 CMR 7.02(12)(b)2 shall allow the tank truck to be filled or emptied unless the tank truck: a. is tested annually during the months of March through June; b. sustains a pressure change of no more than 3 in. of R 2 0 in five minutes when pressurized to a gauge pressure of 18 in. of H20 or when evacuated to a gauge pressure of 6 in. of H 2 0 during the testing; c. is repaired by the owner or operator arid retes.ted within 15 days of testing if it does riot meet the criteria of 310 CMR 7.02(12)(c)lb; d. displays a stencil near the Department of Transportation Certification plate required by 49 CPR 118.340—lob, which (1) shows the initials DEQE and the date that the tank truck last passed the test (“DEQE date ); and (2) shows that the test approval expires July 1 of the year following the test. 2. The owner or operator of a vapor recovery system or tank truck subject to 310 CMR 7.02(12)(a)( 1 4), 7.02(12)(a 5, 7.02(12)(b)2 or 7.02(12)(c)1 shall design and operate the vapor recovery system and the loading of equipment in a manner that prevents: a. gauge pressure from exceeding 18 in. of H 2 0 and vacuum pressure from exceeding 6 In. of H 2 0 in the tank truck; b. a reading equal to or greater than 100 percent of the lower explosive limit (LEL, measured as propane) at one inch from all points of the perimeter of a potential leak source during loading or unloading operations at the loading rack or stationary tank; c. avoidable visible liquid leaks during loading or unloading operations at the loading rack or stationary tank. 3. The owner or operator of a tank truck subject to 310 CMR 7.02(12)(c) must: a. notify the Department in writing of the date and location of a certification test at least seven days before the anticipated test date; and b. within 15 days, repair and retest a vapor recovery system or tank truck that exceeds the limits in .310 CNR 7.02(12)(c)1 or 7.02(12)(c)2. 4. The Department may, at any time, measure emissions or oack pressure from a tarnc truck, or vapor recovery system to determine comp .iance with the requirements of 310 CMR 7.02(12)(c)1 or 7.02(12)(c)2.. ------- 310 CMR: DEPARTMENT OP ENVIRONTIENTAL QUALITY ENGINEERING 5. The Department may 1 upon written notice modify the testing frequency of 310 CMR 7.02(12)(c)].a. 6. The owner or operator of a source subject to 310 CMR 7.02(12)(c)1 shall maintain records of aJJ. certification testing and repairs for at least two years. 7. Copies of all records and reports required under this section shall i mediate1y be made available to the Department upon verbal or written request, at any reasonable time. 8. At the discretion of the Department, the requirements for testing and marking motor vehicle fuel tank trucks subject to 310 CMR 7.01(12)(c) may be satisfied if the vehicle undergoes equivalent certification in Connecticut or New York. (d) For the purpose of 310 CMR 7.02(12)(a), 7.02(12)(b), and 7.01(].2)(c) any emission or efficiency testing required by the Department shall be in accordance with methods approved by the Department unde•r the provisions of 310 CMR 7.13 3] Engr •14 —6— ------- TN4K T JcK P SSU /VAQiUM TEST ------- METHOD 27 DETERtIINATI ON OF VAPOR TIGHTNESS OF GASOLINE DELIVER f TANK USING PRESSURE-VACUUM TEST 1. Applicability and Principle 1.1 Applicability. This method is applicable for the determination of vapor tightness of a gasoline delivery tank which is equipped with vapor collection equipment. 1.2 Principle. Pressure and vacuum are applied alternately to the compartments of a gasoline delivery tank and the change in pressure or vacuum is recorded after a specified period of time. 2. DefInitions and Nomenclature 2.1 Gasoline. Any petroleum distillate or petroleum distillate/ alcohol blend having a Reid vapor pressure of 27.6 kilopascals or greater which is used as a ftiel for Internal combustion engines. 2.2 DelIvery tank. Any container, Including associated pipes and fittings, that Is attached to or forms a part of any truck, trailer, or railcar used for the transport of gasoline. 2.3 Compartment. A liquid—tight division of a delivery tank. 2.4 Delivery tank vapor collection equipment. Any piping, hoses, and devices on the delivery tank used to collect and route gasoline vapors either from the tank to a bulk terminal vapor control system or from a bulk plant or service station Into the tank. 2.5 Time period of the pressure or vacuum test Ct). The time period of the test, as specified in the appropriate regulation, during which the change in pressure or vacuum is monitored; in ninutes. 2.6 Initial pressure (P 1 ). The pressure applied to the delivery tank at the beginning of the static pressure test, as specified in the appropriate regulation, in mn H 2 0, ------- 2.7 Initial vacuum (Vi). The vacuum applied to the delivery tank at the beginning of the static vacuum test, as specified in the appropriate regulation, in mm H 2 0. 2.8 Allowable pressure change ( p). The allowable amount of decrease in pressure during the static pressure test, within the time period t, as specified In the appropriate regulation, in mm 1420. 2.9 Allowable vacuum change (a v). The allowable amount of decrease in vacuum during the static vacuum test, within the time period t, as specified in the appropriate regulation, in mm H 2 0. 3. Apparatus 3.1. Pressure source. Pump or compressed gas cylinder of air or inert gas sufficient to pressurize the delivery tank to 500 mm H 2 0 above atmospheric pressure. 3.2 Regulator. Low pressure regulator for controlling pressurization of the delivery tank. 3.3 Vacuum source. Vacuum pump capable of evacuating the delivery tank to 250 mm 1120 below atmospheric pressure. 3.4 Pressure-vacuum supply hose. 3.5 Manometer. Liquid manometer, or equivalent instrument, capable of measuring up to 500 mm 1420 gauge pressure with ±2.5 mm 1120 precision. 3.6 Pressure-vacuum relief valves. The test apparatus shall be equipped with an in—line pressure—vacuum relief valve set to activate at 675 mm above atmospheric pressure or 250 mm 1420 below atmospheric pressure, with a capacity equal to the pressurizing or evacuating pumps. ------- 3.7 Test cap for vapor recovery hose. This cap shall have a tap for manometer connection and a fitting with shut-off valve for connection to the pressure—vacuum supply hose. 3.8 Caps for liquid delivery hoses. 4. Pretest Preparations 4.1 Summary. Testing problems may occur due to the presence of volatile vapors and/or temperature fluctuations inside the delivery tank. Under these conditions 1 it is often difficult to obtain a stable initial pressure at the beginning of a test, and erroneous test results may occur. To help prevent this, it is recommended that, prior to testing, volatile vapors be removed from the tank and the temperature inside the tank be allowed to stabilize. Because It is not always possible to attain completely these pretest conditions a provision to ensure reproducible results Is Included. The difference In results for two consecutive runs must meet the criterion in Sections 5.2.5 and 5.3.5. 4.Z nptying of tank. The delivery tank shall be nptied of all ii quid. 4.3 Purging of vapor. As nuch as possible, the delivery tank shall be purged of all volatile vapors by any safe, acceptable method. ie method is to carry a load of non—volatile liquid fuel, such as diesel or heating oil, Immediately prior to the test, thus flushing out all the volatile gasoline vapors. A second method is to remove the volatile vapors by blowing ambient air into each tank compartment for at least 20 minutes. This second method is usually not as effective and often causes stabilization problems, requiring a much longer time for stabilization during the testing. ------- 4.4 Temperature stabilization. As much as possible, the test shall be conducted under isothermal conditions. The temperature of the delivery tank should be allowed to equilibrate in the test environment. During the test, the tank should be protected from extreme environmental and temperature variability, such as direct sunlight. 5. Test Procedure 5.]. Preparations. 5.1.1 Open and close each dome cover. 5.1.2 Connect static electrical ground connections to tank. Attach the liquid delivery and vapor return hoses, remove the liquid delivery elbows, and plug the liquid delivery fittings. (Note: The purpose of testing the liquid delivery hoses is to detect tears or holes that would allow liquid leakage during a delivery. Liquid delivery hoses are not considered to be possible sources of vapor leakage, and thus, do not have to be attached for a vapor leakage test. Instead, a liquid delivery hose could be either visually Inspected, or filled with water to detect any liquid leakage.) 5.1.3 Attach the test cap to the end of the vapor recovery hose. 5.1.4 Connect the pressurevacuum supply hose and the pressure— vacuum relief valve to the shut .off valve. Attach a manometer to the pressure tap. 5.1.5 Connect compartments of the tank internally to each other if possible. If not possible, each compartment must be tested separately, as if it were an individual delivery tank. 5.2 Pressure test. 5.2.], Connect the pressure source to the pressure—vacuum supply hose. ------- 5.2.2 Open the shut—off valve in the vapor recovery hose cap. Applying air pressure slowly, pressurize the tank to P 1 , the initial pressure specified In the regulation. 5.2.3 Close the shut—off valve and allow the pressure in the tank to stabilize, adjusting the pressure if necessary to maintain pressure of P 1 . When the pressure stabilizes, record the time and initial pressure. 5.2.4 At the end of t minutes, record the time and final pressure. 5.2.5 Repeat steps 5.2.2 through 5.2.4 until the change in pressure for two consecutive runs agrees within ±12.5 mm H 2 0. Calculate the arithmetic average of the two results. 5.2.6. Compare the average measured change In pressure to the allowable pressure change, p, as specified In the regulation. If the delivery tank does not satisfy the vapor tightness criterion specified in the regulation, repair the sources of leakage, and repeat the pressure test until the criterion is met. 5.2.7 DIsconnect the pressure source from the pressure—vacuum supply hose, and slowly open the shut—off valve to bring the tank to atmospheric pressure. 5.3 Vacuum test. 5.3.1 Connect the vacuum source to the pressure—vacuum supply hose. 5.3.2 Open the shut—off valve in the vapor recovery hose cap. Slowly evacuate the tafik to V , the Initial vacuum specified in the regulation. ------- 5.33 Close the shut—off valve and allow the pressure in the tank to stabilize, adjusting the pressure if necessary to riaintain a vacuum of V . When the pressure stabilizes, record the time and Initial vacuum. 5.3.4 At the end of t minutes, record the time and final vacuum. 5.3.5 Repeat steps S.3.2 through 5.3.4 until the change in vacuum for two consecutive runs agrees within ±12.5 mm H 2 0. Calculate the arithmetic average of the two results. 5.3.6 Compare the average measured change in vacuum to the allowable, vacuum change, v, as specified in the regulation. If the delivery tank does not satisfy the vapor tightness criterion specified in the regulation, repair the sources of leakage, and repeat the vacuum test until the criterion is met. 5.3.7 Disconnect the vacuum source from the pressure—vacuum supply hose, and slowly open the shut—off valve to bring the tank to atmospheric pressure. 5.4 Post—test clean—up. Disconnect all test equipnent and return the delivery tank to its pretest condition. 6. Alternative Procedures 6.1 The pumping of water into the’ bottom of a delivery tank is an acceptable alternative to the pressure source described above. Likewise, the draining of water out of the bottom of a delivery tank may be substituted for the vacuum source. note that some of the specific step—by—step procedures in the method must be altered slightly to accommodate these different pressure and vacuum sources. ------- 6.2 Techniques other than specified above may be used for purging and pressurizing a delivery tank, if prior approv l is obtained from the Administrator. Such approval will be based upon demonstrated equivalency with the above method. ------- GASOLINE TANK TRUCK INSPECTION CHECKLIST, LEAKAGE TEST, CARl) PROCEDURE key Inspection Point RACI Requirements inspection Procedure Quick Key Inspection Findings Check last load diesel or LASI fuel oil if last load gasoline, purge PURGE Kavlmui. pressure change In Move to sheltered area SIIELUR five minutes is as follows; Close all ei Iernal openings, SEAL cap hoses Pressure: Open internal valves to mani- lank truck or 4,500 to 3.150 Pascals (old compartments together traIler (lB to 15 in. water) Connect manometer I IAI IIIIEIIR Pressuriie to 18 inches P$1ESSURL Vacuim. ; water (stable) -1,500 to -150 Pascals Monitor leak rate 5 mm LEAK RARE (-6 to -3 In. water) Evacuate to -6 inches water VACIIIH (stable) Monitor leak rate 5 am LEAK AM( ------- GASOL.INE DELSIVERY TANK PRESSURE/VACUUN TEST I — a a — i Tank Owner (Print) Test Date I I a a — — I(naae) Test Organization (Print) I I I(addresa) I(neae) I I I I (address) I I (telephone no.) I I I aaeaCeCaeaaaeaaaeaaeaeaaaeaeeCaae ee I I ITank I.D. Muaber I(t.lephen. no.) I I -——-aaa—————-————-aa—a———————————a—— I ——-———————————-——a—--——————————-—aaa ITeat Observed by Air Pollution Inspector yea r io I I — I — — C 55 I I Sign4.ture of Inspector I Agency I I I I I eCeeaeeCeeee aCaa CC_c_as SCeaCCCC CC — Test Results I I I C 5 5 5a CC 5CC 5C CCC_CC__________ I I Pressure Test I Vecuua Test I I Ceeeeaea seee ceaea I eeaeec I I I I I Test ii Test 21 I Teat ii Test 21 I CCeCeee sCeeeeeeaaeCe I C CC CCCaSCea 5e CCe e CC 5eC I I I llnitisi . Pressure, li 2 OI I llnitial Vecuun, “H 2 0 I I I I I I CSCaCC CCCC S SCC CaeCa IFinal Pressure, “H 2 0 I I IFina.]. Vacuua. “H 2 0 I I I aaee C eaee CCeeeCCCCCaCeaaaCCa I ——— — I Test Duration, am. I I Teat Duration, mm. I I I I ——s——— CCeCCCCC SCCCCCC I CCCC Pressure Change, “H 2 0 I I IVacuua Change, “H 2 0 I I I I SCeaeaeCeeeCaaeaaaC I I ——— I CCCCCC CCCCCCSC I eeae CCCC SC Avg. Pressure Change, “H 2 0 lAvg. Vacuum Change, 1 •H 2 0 I CCCCCCCa SC SCC CCCCCCCCC I CCCCCCCSCCSC SCC C__CC_C__C I IPerson Performing Test (Print) Signature I I— I I I I CCCCC SCCC__CCC__________C____C___________C_______Ca_______C___C_________ I ------- TANK TRUCK INSPECT IONS ------- GASOLINE VAPOR LEAK DETECTION PROCEDURE BY COMBUSTIBLE GAS DETECTOR 1. PRINCIPLE A combustible gas detector is used to indicate any incidence of leakage from gasoline truck tanks and vapor control systems. This qualitative monitoring procedure is an enforcement tool to confirm the continuing existence of leak-tight conditions. 2. APPLICABILITY This method is applicable to determining the leak-tightness of gasoline truck tanks during loading without taking the truck tank out of service. The method is applicable only if the vapor control system does riot create back-pressure in excess of the pressure limits of the truck, tank compliance leak test. For vapor control systems, this method is applicable to determining leak-tightness at any time. 3. DEFINITtONS 3.1 Truck tank . Any container, including associated pipes and fittings, that is used for the transport of gasoline. 3.2 Truck tank vacor collection ecuioment . Any piping, hoses, and devices on the truck tank used to collect and route the gasoline vapors in the tank to the bulk termThal, bulk plant, or service station vapor control system. 3.3 Vapor control system . Any piping, hoses, equipment, and devices at the bulk terminal, bulk plant, or service station, which is used to collect, store, and/or process gasoline vapors. ------- 4. APPARATUS AND SPECIFICATIONS 41 Manometer . Liquid manometer, or equivalent, capable of measuring up to 6250 pascals (25 inches H 2 0) gauge pressure with 25 pascals (0.1 inch H 2 0) precision. 4.2 Combustible gas detector . A portable hydrocarbon gas analyzer with associated sampling line and probe. 4.2.1 Safety. Certified as safe for operation in explosive atmospheres. 4.2.a Range. Minimum range of 0—100 percent of the lower explosive limit (LEL) as propane. 4.2.3 Probe diameter. Sampling probe internal diameter of O.625an (1/4. inch). 4.2.4 Probe length. Probe sampling line of sufficient length for easy maneuverability during testing. 4.2.5 Response time.. Response time for full-scale def1ect ion of less than 3 seconds for detector with sampling line and probe attached. 5. TEST PROCEDURE 5.1 Pressure . Place a pressure tap in the terminal, plant, or service station vapor control system, as close as possible to the connection with the truck tank. Record the pressure periodically during testing. 5.2 Calibration . Calibrate the combustible gas detector with 2.2 per- cent propane by volume in air for 100 percent LEL res onse. ------- 5.3 Monitoring procedure . Ouring loading or unloading, check the periphery of all potential sources of leakage of the truck tank and of the terminal, plant, or service station vapor collection system with a combustible gas detector. 5.3.1 Probe distance. The probe inlet shall be 2.5 cm from the potential leak source. 5.3.2 Probe movement. Move the probe slowly (2.0 cm/second). If there is any meter deflection at a potential leak source, move the probe to locate the point of highest meter response. 5.3.3 Probe position. As much as possible, the probe inlet shall be positioned in the path of (parallel to) the vapor flow from a leak. 5.3.4 Wind. Attempt as much as possible to block the wind from the area being monitored. 5.4. Recor 1ng . Record the highest detector reading and location for each incidence of leakage. ------- GASOLINE TANK TRUCK INSPECTION ChECKLIST ICey Inspection Point RACI Requirements lnspect’ n Procedure Quick Key Inspection Findings link truck or trailer 1 All tank fittings (Keys 2-1 Submersed or bottom Certificate of Inspection OK Verify loading port or tube wIthin sli inches o( tank bottom CIRIIFICAJI 00110K FIt -I. . No Leak greater then 1001 tEL 2 c from source during loading or unload- leg look for vapors (like heat waves or their shadow SnIff for gasoline odor Listen for hiss of leeks feel for vapor breeze on fingers Check with combustible vapor detector ill around p01cc- leak source at 2.5 cm dis lance VAPOR lEAKS LEAK DElICt 2 Dome covers Visual check: Lid or base ring not wirped or damaged Gaskelt clean and Intact Attachments light COVER 3 Pressure/vacuum vents Valve closures work smoothly P/V VENt Vapor collection piping Cover bolts tight lubber boots and hoses undamaged Gaskets undamaged VAPOR LINES . S iransfer hoses Noses undamaged Proper coupler connections ILaslets undamaged 1111515 4 Overfill sensors SENSOR 1 lank welds WILDS ------- GASOLINE TANK TRUCK INSPECTION FO I Terminal Date Tank Owner Tank 1.0. No. Inspector Agency Signature CaIPAR1MENT (Front to Rear) Comments 1 2 3 4 5 Previous Product V.R. Used (Y/N) % LEL Readings: o Dome Cover o PY Vent o Vent Valve Cover o Overfill Sensor o Other (speci fy) Bottom Load Vapor Recovery Coupler LEL) ------- |