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

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OVERVIEW OF CTG AND STATE REGULATIONS
BACV ROUND - GASOLINE MARKETING

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OVER I&I OF CTG AND STATE REGULATIOFE

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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SLIDE 29
BANKING
EMISSIONS
SLiDE 30
STATE REGULATIONS AND PERMITS
CAN VARY FROM CTG AND MODEL
REGULATION

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BACKGROUND — GASOLINE MARKETING

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= Storage
= Transport
Wholesale
Distribution
Level
Consumer
Gasoline Distribution in the U.S.

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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

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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

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TERMINALS AND BULK PLANTS
TERMINALS
BULK PLANTS

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SERVICE STATION POPULATION
1982 147,000
1980 158,540
1975 189,480
1972 226,459

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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

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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

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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

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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

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PETROLEUM LIQUIDS
Double-Deck Floating Roof
I U
I I
I
I
I I

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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

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T uek Tx *ctor Trailer
Pumpa
Storage Tanks
Loading Rack
Scharritlc Of T Loading Bulk Plant

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A TYPICAL TOP—LOADING RACK

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THIEF HATCH
VENT
NOZZLE
SUBMERGED FILL
OR DRAINAGE)
Figure 2—2.
Typical Fixed Roof Tank
MANHOLE
2-6

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EMISSIIONS FROM A TYPICAL BULK PLANT
LOADING STORAGE
EMISSIONS TANKS
5.000 GAL/DAY
FACILITY 9 TONS/YR. 9 TONS/YR.

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A. STRAIGHT TRUCK
9. SEMITRAILER
C. STRAIGHT TRUCK AND FULL TRAILER
D. SEMITRAILER AND FULL TRAILER
Figure 4—5.
Types of Tank Trucks

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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

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8TA6 S
TAIIIC
STAGE II
Of UNDflIGROIJND TANK
VEHICLE

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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.

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STAGE I CONTROL TECHNOLOGY
STORAGE TANKS
REVIE d OF BUU< GASOLINE TERMINAL NSPS (SU& PRT XX)
STAGE Il/ONBOARD CONTROVERSY

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STAGE I CONTROL TEO NOLOGY

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VAPOR
OLLEC11ON
EM
VIAPOR
PROCESSING
TEM
T ANK
TRUCK
UQJID
LQØDING
V APOR
PRC ESSOR

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VAPOR COLLECTION SYSTEMS
• TOP LOADING VAPOR RECOVERY
• TOP TIGHT
• BOTTOM LOADING

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TOP LOADING VAPOR RECOVERY

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VAPOR RETURN LINE
I VAPOR FREE
I AIR VENTED TO
I ATMOSPHERE
—0 -
PRODUCT FROM
LOADING TERMINAL
STORAGE TANK

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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

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IIYDROTECH ADSORPTION-ABSORPTION GASOLINE RECOVERY SYSTEM
AIR VENT
GASOLINE
SUPPLY
PUMP
INLET
VACUUM PUMP
Adsorption-Absorption Vapor Recovery System Ilydrotech Engineering, Inc.

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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.

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11
Truck Trailer Transport Bulk Tank Vents-i ’
Co—ax
Vapor Return Line
Liquid Line ______
- —- L9 i - I- -
Vent Line
Underground Storage Tanks

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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

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VAPOR RECOVERY SYSTEM USING OVERTURN RAIL
(Courtesy of the Heil Company)

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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

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STORAGE TANP

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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

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SLIDE S
CONTACT INTERNAL FLOATING ROOF
COLIPII
WALL
SLIDE 6
NON-CONTACT INTERNAL FLOATING ROOF
s5

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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

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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

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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

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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

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SLIDE 1.8
RESILIENT FOAM-FILLED SEAL
WITH WEATHER SHIELD
SLIDE 19
coMwy IWR $•aI

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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

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SLIDE 23
“INSPECTORS APPROACHING EXTERNAL
FLOATING ROOF”
SLIDE 24
“PONTOON TYPE OF EXTERNAL
FLOATING ROOF”
SLIDE 25
“PONTOON TYPE OF EXTERNAL
FLOATING ROOF”

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SLIDE 26
SLIDE 27
SLIDE 28
TM PAN TYPE OF EXTERNAL FLOATING ROOF”
“CENTER DRAIN TM
“GUIDE ROD TO KEEP ROOF FROM ROTATING”

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SLIDE 29
“GUIDE ROD TO KEEP ROOF FROM ROTATING°
“WEATHER SHIELD REMOVED TO SHOW
SHOE OF PRIMARY SEAL”
SLIDE 30

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SLIDE 31
SLIDE 32
“ROOF LEG SUPPORT”
“LIQUID LEVEL GAUGE”

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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”

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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

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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

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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.

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SUBPART XX — BULK GASOLLNE TERMINALS

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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

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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

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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)]

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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

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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

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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

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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

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ASSOCLAT WITh PROPOSE EUU< 1 INPL ST PDS
• MethcdsZA,2B
• Mettiods 2 A 253
3 2-8

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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

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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

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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

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TANK TRUCK TEST METHODS
• CTG
• REFERENCE METHOD 27
312-12

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STAGE Il/ONBOARD
CONTROVERSY

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-------
Figure 1A.
SChEMATIC DIAGRAM OF
HANIIWDED IIALANCE
SYSTEM
Figure lB.
SCIIFWtTIC DIAGRAM OF
NON-HAt I IFO [ D [ Ij BALAtICI?
SYSTEM
UrL$ $aIIIIs it a iioiiuG S.flCATIWII
________ VUI U IIMU
— — — III) Isi LINE$

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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

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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

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TO ATM
VENT
+
VAPOR COLLECTION
________ VAPOR LINE
__ — LI UI LINE
Oir ct Incineration Syst3rn

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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

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PURGE
CONTROL
CARBURETOR
GASOLINE
GASOLINE TANK NOZZLE
GA $ OLINE
VAPORS
CARBON
CANISTER
STORAGE

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P uI. P P MCCPCAT1CN5
CTA Y SEAL
RCTAR’i’ SV .L
/
1 AP :cc
MCD tPCAi CN
RC1A ’ SEAL
/
L!AC ic”r

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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

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VOC DEFECTION INSTRUMENTS AND INSPETION
SAFElY TIPS
FIELD INSPECTION TECHNIQUES

-------
VOC DETECTION INSTRUMENtS
AND INSPECTION SPFEtY TIPS

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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

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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”

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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.

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SLIDE 14
DIAGRAM OF A R.AME
IONIZA11ON DETECTOR (AD)
SAMPLE
OUTLET
I GN I TER
BASE
BURNER
JET
Supply
5MP h
INLET

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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

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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”

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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”

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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

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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”

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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.

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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”

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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.

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SLIDE 43
DIAGRAM OF DISPERSIVE
INFRARED (IR) DETECTOR
CII
VAR I ABLE
FILTER
SLF
PREAl PLIFII
IMARY MIRROR
SLIDE 44
“B IOPAK”

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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

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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.

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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)

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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

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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

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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

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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

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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).

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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

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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

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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”

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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”

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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

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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

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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

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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.

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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

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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—

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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—

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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

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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..

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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—

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TN4K T JcK P SSU /VAQiUM TEST

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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,

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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.

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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.

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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.

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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.

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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.

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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.

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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(

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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

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TANK TRUCK INSPECT IONS

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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.

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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.

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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.

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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

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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)

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