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Organic
Liquids Distribution – Maximum
Achievable Control Technology
February
3, 2004 – EPA's
final rule was published in the Federal Register.
It was initially released by EPA five months earlier – on August
25, 2003 (see below). The
rule promulgates national emission standards for hazardous air pollutants
(NESHAP) for new and existing organic liquids distribution (OLD)
(non-gasoline) operations. The
compliance date for all existing affected sources, including storage
terminals, refineries, crude oil pipeline stations, and various
manufacturing operations, is February 5, 2007.
The rule is commonly referred to as the “OLD MACT” rule due to
its requirement that the applicable emission standards reflect the use of
maximum achievable control technology (MACT).
Download
Final Rule (PDF)
January 22, 2004
– ILTA
held a workshop in New Orleans summarizing the regulatory requirements of
the NESHAP for Organic Liquid Distribution (Non-Gasoline), 40 CFR 63
Subpart EEEE, as applicable to bulk liquid terminal owners and operators.
The session focused on applicability determinations, exemptions,
control requirements, inspections, monitoring, testing, recordkeeping, and
reporting. Trinity
Consultants, Inc. conducted the workshop, which was available at no cost
to ILTA terminal member companies. Terminal
members may request documents from that workshop by clicking on this link.
August 25, 2003
– EPA
issued the final OLD MACT rule. It
was immediately made available to the public through EPA’s Web site,
document room and other routine document distribution procedures, but it
was not published in the Federal Register until February 3, 2004.
The rule reduces emissions of toxic air pollutants from facilities
that distribute organic liquids other than gasoline. Toxic air pollutants, also known as air toxics, are those
pollutants known or suspected to cause cancer or other serious health and
environmental problems. Organic
liquid distribution takes place at liquid terminal facilities, organic
chemical manufacturing facilities, petroleum refineries, crude oil
pipeline pumping and breakout stations, and other industrial facilities.
EPA estimates that the final rule will affect approximately 380 facilities
that distribute organic liquids.
In
general, the rule requires more stringent emission controls and work
practices for storage tanks, transfer racks, other transfer operations,
transport vehicles while being loaded, equipment components with the
potential to leak (such as valves, pumps, fittings and sampling
connections), and the filling of containers.
Fortunately, most crude oil and chemical terminals covered by the
rule do not face a set of imminent compliance due dates.
Here are the deadlines:
- Existing
operations – For existing operations subject to the OLD MACT
requirements, terminals must comply within three years from the date
the rule is published in the Federal Register.
The compliance date is February 5, 2007.
- Floating
roof tanks – An exception to the three-year deadline applies to
floating roof storage tanks that do not initially meet the equipment
standard for storage tanks in the final rule.
These tanks must be in compliance following their next
degassing and cleaning, or by 10 years from February 3, 2004.
If the first degassing and cleaning activity occurs during the
three years following the Federal Register publication date of
February 3, 2004, the compliance deadline is three years after that
date.
- Existing
facilities not initially covered – If a terminal increases its HAP
emissions, or increases the potential to emit such that it becomes a
major source of HAP and thus becomes subject to the OLD MACT rule, it
must comply within three years after the date it becomes a major
source.
- New
and reconstructed facilities – Emission sources from new and
reconstructed operations must be in compliance with OLD MACT
requirements on February 3, 2004.
New or reconstructed operations that commence construction or
reconstruction after that date must comply upon startup.
Operations subject to the OLD MACT rule are defined as
“new” if their construction commenced after April 2, 2002, at a
site where there were no existing OLD MACT operations.
An operation subject to the OLD MACT rule is defined as
“reconstructed” if it commenced operation after April 2, 2002, at
a site where there was an existing OLD MACT operation.
- Exceptions
for new and reconstructed facilities –
(1) If an emission source in a new or reconstructed operation
would not have been required to be controlled under the proposed rule
but is required to be controlled under the final rule, the emission
source must be in compliance by three years from February 3, 2004.
(2) If an emission source in a new or reconstructed operation
would have been subject to a less stringent control requirement under
the proposed rule than applies under the final rule, the emission
source must be in compliance with the final rule’s requirement by
three years from February 3, 2004.
In the interim, the emission source must comply with the less
stringent control requirement as proposed.
The
OLD MACT rule regulates hazardous air pollutants from storage terminals,
refineries, crude oil pipeline stations, and various manufacturing
operations. The rule covers all crude oils downstream of the first point
of custody transfer. It does
not cover gasoline, kerosene, diesel fuel, and heavier distillate oils and
fuel oils, asphalt, hazardous waste, and wastewater.
Background Information on the Rule (May 31, 2002)
EPA’s
proposed rule on national emission standards for hazardous air pollutants
for non-gasoline organic liquids distribution (OLD) operations was
published in the Federal Register on April 2, 2002 (67 FR 15674).
The proposed standards, to be implemented at bulk liquid storage
terminals, refineries, crude oil pipeline stations, and various
manufacturing facilities, would implement section 112 of the Clean Air
Act. OLD operations at plant
sites will be required to meet hazardous air pollutant emission standards
reflecting the application of maximum achievable control technology (MACT).
The
proposed standards would affect OLD activities which, taken together, are
considered to be a facility. The
regulated liquids consists of those that contain 5 percent by weight or
more of any of the 69 organic hazardous air pollutant (HAP) compounds
listed in Table 1 of the proposed rule, as well as all crude oil except
black oil. Examples of some
of the primary pollutants emitted from OLD operations are benzene,
ethylbenzene, toluene, vinyl chloride, and xylenes.
Only those OLD operations at "major source" facilities or
plant sites would be regulated.
The
rule will regulate the transfer of organic liquids into fixed-roof or
floating roof tanks and the storage of such liquids in tanks.
The rule will also regulate the transfer of organic liquids into
cargo tanks (tank trucks or railcars) at transfer racks, and the transfer
of such liquids through pumps, piping, valves, and other equipment that
may potentially leak. For
storage tanks, there would be two options for limitations on emissions:
installation of a closed vent system and control device with a specified
control efficiency; or installation of a properly constructed floating
roof. For transfer racks a
vapor collection system and control device would have to be installed and
continuously monitored. A
work practice standard would apply to cargo tanks loading at a controlled
rack. A work practice
standard would also apply to any equipment used to handle organic liquids
for at least 300 hours per year. The
standard would involve regular instrument monitoring for leaks and repair
of leaking equipment.
ILTA’s
Comments on the Proposed Rule
On
May 31, 2002, ILTA filed comments on the proposed rule.
The comments were the product of ILTA’s OLD MACT working group,
which consisted of 10 ILTA terminal member companies.
The group identified 12 issues of special concern to terminal
companies, provided technical input, and assisted in the drafting of the
comments.
One
of the high priority issues for ILTA relates to emission controls for
transfer racks operating at a low vapor pressure.
In its comments, ILTA urged EPA to modify the rule to include a
vapor pressure cutoff of 1.5 psia for the applicability of controls for
transfer operations. ILTA
noted that otherwise, emission controls would apply under certain
conditions where there would be no need for controls.
In
commenting on another high priority issue, ILTA stated that the rule
should allow storage tank upgrades to be conducted the next time tanks are
emptied and degassed, or within 10 years, but not within three years as
proposed in the rule. ILTA
noted that emptying tanks out-of-cycle to meet the three-year deadline
would produce emissions exceeding the total emission reductions ultimately
resulting from the required alterations.
Download
ILTA’s May 31, 2002 Comments (PDF)
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