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PAGES 22 APPL. NO. 465213 - 465216 PROCESSED BY: Jon Uhl/Connie Johnny Pan Yee
COMPANY NAME, LOCATION ADDRESS: Ultramar Inc, SCAQMD ID # 800026 2402 E. Anaheim Street Wilmington CA 90744
EQUIPMENT DESCRIPTION: Additions to the equipment description are underlined. Modified conditions are underlined. Deletions to the equipment description and conditions are noted in strikeouts. Section D of Ultramars Facility Permit, ID# 800026
Equipment ID No. Connected To Source Type/ Monitoring Unit Emissions And Requirements Conditions
Process 14 : STORAGE TANKS System 2: EXTERNAL FLOATING ROOF TANKS STORAGE TANK, EXTERNAL FLOATING ROOF, 94-TK-9001, CRUDE OIL, WELDED SHELL, 300,000 BBL; DIAMETER: 221 FT, HEIGHT: 48 FEET WITH A/N: 271656 465213 FLOATING ROOF, PONTOON PRIMARY SEAL, WIPER TYPE, TUBE TYPE, MECHANICAL SHOE SECONDARY SEAL, RIM MOUNTED, WIPER TYPE STORAGE TANK, EXTERNAL FLOATING ROOF, 94-TK-9002, WELDED SHELL, 300,000 BBL; DIAMETER: 221 FT, HEIGHT: 48 FEET WITH A/N: 262831 465214 FLOATING ROOF, PONTOON PRIMARY SEAL, MECHANICAL SHOE, FLEXA-SEAL SECONDARY SEAL, RIM MOUNTED, WIPER TYPE, (B467) (B468) (B464) (B465) D255 HAP: (10) [40CFR 63 SUBPART CC, #2,#3A, 5-252001 6-23-2003]
(B466) D256 HAP: (10) [40CFR 63 SUBPART CC, #2,#3A, 6525-2001 6-23-2003] B22.7, C1.2, H23.7
(B469)
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Equipment
ID No.
Connected To
Conditions
Process 14 : STORAGE TANKS FLEX-A-SEAL STORAGE TANK, EXTERNAL FLOATING ROOF, 94-TK-9007, CRUDE OIL, WELDED SHELL, 250,000 BBL; DIAMETER: 201 FT 6 IN, HEIGHT: 48 FEET WITH A/N: 483995 465215 FLOATING ROOF, PONTOON PRIMARY SEAL, LIQUID MOUNTED SECONDARY SEAL, RIM MOUNTED, WIPER TYPE GUIDEPOLE, GASKETED COVER, WITH FLOAT, SLEEVE, WIPER, SLOTTED STORAGE TANK, EXTERNAL FLOATING ROOF, 94-TK-9009, CRUDE OIL, WELDED SHELL, 250,000 BBL; DIAMETER: 201 FT 6 IN, HEIGHT: 48 FEET WITH A/N: 229846 465216 FLOATING ROOF, PONTOON PRIMARY SEAL, CATEGORY A, MECHANICAL SHOE SECONDARY SEAL, CATEGORY A, RIM MOUNTED, WIPER TYPE (B488) (B489) (B490) (B482) (B483) (B484) (B1614) D261 HAP: (10) [40CFR 63 SUBPART CC, #2,#3A5-252001 6-23-2003]
D263
C1.21, H23.7
CONDITIONS: The following permit conditions shall apply to these storage tanks in order to comply with all applicable District, State, and Federal standards. Additions and deletions to the conditions are noted in underlines and strikeouts, respectively. PROCESS CONDITIONS P13.1 All devices under this process are subject to the applicable requirements of the following rules or regulations: Contaminant Benzene Rule 40CFR61, SUBPART Rule/Subpart FF
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[Processes tied to this condition: P1, P2, P3, P4, P5, P7, P8, P9, P10, P11, P12, P14] [40CFR 61 Subpart FF, 12-04-2003] SYSTEM CONDITIONS S13.5 All devices under this system are subject to the applicable requirements of the following rules or regulations: Contaminant VOC VOC VOC Rule District Rule District Rule District Rule Rule/Subpart 463 1149 1178
[Systems tied to this condition: P14-S1, 2, 7] [RULE 1149, 07-14-1995; RULE 1149, 5-2-2008; RULE 1178, 4-7-2006; RULE 463, 5-6-2005] DEVICE CONDITIONS B. Material/Fuel Type Limits B22.7 The operator shall not use this equipment with materials having a(n) true vapor pressure of 11 psia or greater under actual operating conditions.
[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 1303(b)(2)-Offset, 12-6-2002] [Devices subject to this condition: D252, D256, D271, D272, D273]
B22.9
The operator shall not use this equipment with materials having a(n) true vapor pressure of 7.3 psia or greater under actual operating conditions. To verify compliance with this condition, the operator shall sample the materials stored once per month to determine the true vapor pressure. The true vapor pressure shall be determined using ASTM Method D-323 for Reid vapor pressure or other equivalent District-approved method and converted to true vapor pressure using applicable nomographs or equations in EPA AP-42 or District and EPA approved nomographs.
[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 1303(b)(2)-Offset, 12-6-2002] [Devices subject to this condition: D261]
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C1.2
The operator shall limit the number of turnovers to no more than 42 in any one year.
[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 1303(b)(2)-Offset, 12-6-2002] [Devices subject to this condition: D255, D256]
C1.21
The operator shall limit the number of turnovers to no more than 475 in any one year.
[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 1303(b)(2)-Offset, 12-6-2002] [Devices subject to this condition: D263]
C1.40
The operator shall limit the throughput to no more than 620,000 barrel(s) in any one calendar month. The operator shall comply with the following throughput measurement practices. The operator shall calculate the throughput, in barrels, by the following equation: 0. 14 x D x D x L, where D is the diameter of the tank in feet based on the tank strapping chart and L is the total vertical one-way roof travel in feet per month. The operator shall install and maintain an automatic tank level gauge (ATLG) and recorder to continuously record the vertical movement of the roof. For the purpose of this condition, continuous recording is defined as once per hour. The operator shall calculate the total one-way roof movement, in feet, on a daily and monthly basis. The ATLG installed shall be verified once per quarter by comparing against a manual tank level measurement. If the ATLG differs from the manual tank level measurement by more than 1.0 inch or 0. 8%, whichever is greater, the ATLG shall be repaired and put back into service within 10 days. While the ATLG is being repaired, the throughput shall be determined by the hourly tank level data averaged from the previous 30 days prior to the discovery of the discrepancy. In the event of a failure or routine maintenance of the ATLG, the ATLG shall be repaired (if necessary) and put back into service within 10 days of the time that the ATLG failed or was removed from service for maintenance. While the ATLG is being repaired or maintained, the throughput shall be determined by the hourly tank level data averaged from the previous 30 days prior to time that the ATLG went out of service. [RULE 1303(b)(2)-Offset, 5-10-1996; RULE 1303(b)(2)-Offset, 12-6-2002]
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D. D90.10
Monitoring/Testing Requirements The operator shall periodically monitor the vapor pressure of the material stored in this storage tank according to the following specifications: The operator shall determine the true vapor pressure by one of the following methods: 1) record the tank contents and temperature once per month and use the organic liquid storage tank figure 7.1 series in AP-42; 2) sample and test the material stored, 3) derive the vapor pressure using engineering calculations, or 4) maintain on file a copy of the Material Safety Data Sheet (MSDS) of the material stored. Records of materials stored and vapor pressure of the material stored, and their MSDS if applicable, shall be retained for a period of five years and made available to the Executive Officer upon request. [RULE 1303(b)(2)-Offset, 5-10-1996; RULE 1303(b)(2)-Offset, 12-6-2002] [Devices subject to this condition: D217, D218, D221, D252, D256, D259, D260, D262, D264, D272, D273, D274, D307, D309]
H. Applicable Rules H23.7 This equipment is subject to the applicable requirements of the following rules or regulations: Contaminant VOC Rule 40CFR60, SUBPART Rule/Subpart K
[Devices tied to this condition: D255, D256, D257, D258, D259, D260, D261, D262, D263, D264, D265, D266] [40CFR 60 Subpart K, 05-05-1989]
COMPLIANCE WITH PERMIT CONDITIONS - RECORDS: Device [D255] - Storage Tank 94-TK-9001 Conditions S13.5: The Rule 463 and Rule 1178 tank inspection report dated 5-2-12 is included in Attachment 2. No compliance issues are noted. Monthly records of the commodity stored in this tank (crude oil) and the true vapor pressure (TVP = 1.50 to 4.97 psia) are included in Attachment 1.
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Condition C1.2:
The throughput limit is 42 turnovers (12,600,000 bbl) in any one calendar year. Ultramar submitted throughput records showing 27.32 turnovers (8,196,368 bbl) from July 2011 to June 2012. Throughput records are included in Attachment 1.
Condition H23.7: The tank inspection and reporting requirements for 40CFR Part 60 Subpart K and 40CFR Part 63 Subpart CC are met by the Rule 463 and Rule 1178 tank inspection report dated 52-12 (included in Attachment 2). No compliance issues are noted. Monthly records of the commodity stored in this tank (crude oil) and the true vapor pressure (TVP = 1.50 to 4.97 psia) are included in Attachment 1. Device [D256] - Storage Tank 94-TK-9002 Conditions S13.5: The Rule 463 and Rule 1178 tank inspection report dated 6-11-2012 is included in Attachment 2. No compliance issues are noted. Monthly records of the commodity stored in this tank (crude oil) and the true vapor pressure (TVP = 1.68 to 4.49 psia) are included in Attachment 1. Condition B22.7: The true vapor pressure (TVP) limit is 11 psia. Ultramar submitted monthly TVP records showing a maximum TVP of 4.49 psia for July 2011 through June 2012. TVP records are included in Attachment 1. Condition C1.2: The throughput limit is 42 turnovers (12,600,000 bbl) in any one calendar year. Ultramar submitted throughput records showing 27.78 turnovers (8,332,770 bbl) from July 2011 to June 2012. Throughput records are included in Attachment 1.
Condition H23.7: The tank inspection and reporting requirements for 40CFR Part 60 Subpart K and 40CFR Part 63 Subpart CC are met by the Rule 463 and Rule 1178 tank inspection report dated 611-2012 (included in Attachment 2). No compliance issues are noted. Monthly records of the commodity stored in this tank (crude oil) and the true vapor pressure (TVP = 1.68 to 4.49 psia) are included in Attachment 1. Device [D261] - Storage Tank 94-TK-9007 Conditions S13.5: The Rule 463 and Rule 1178 tank inspection report dated 5-1-12 is included in Attachment 2. No compliance issues are noted. Monthly records of the commodity stored in this tank (crude oil) and the true vapor pressure (TVP = 1.13 to 5.33 psia) are included in Attachment 1. Condition B22.9: The true vapor pressure (TVP) limit is 7.3 psia. Ultramar submitted monthly TVP records showing a maximum TVP of 5.33 psia for July 2011 through June 2012. TVP records are included in Attachment 1. Condition C1.40: The throughput limit is 620,000 bbl in any one calendar month. Ultramar submitted throughput records showing the maximum throughput was 552,610 bbl/month (May 2012). Throughput records are included in Attachment 1. The automatic level gauge (ATLG) must be verified once per quarter against a manual tank level measurement. Ultramar submitted monthly manual tank level measurements. The
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maximum error was 1/2, which is less than the maximum error of 1 allowed. The manual tank level measurements are included in Attachment 4. Condition H23.7: The tank inspection and reporting requirements for 40CFR Part 60 Subpart K and 40CFR Part 63 Subpart CC are met by the Rule 463 and Rule 1178 tank inspection report dated 5/5/08 (included in Attachment 2). No compliance issues are noted. Monthly records of the commodity stored in this tank (crude oil) and the true vapor pressure (TVP = 1.13 to 4.91 psia) are included in Attachment 1. Device [D263] - Storage Tank 94-TK-9009 Conditions S13.5: The Rule 463 and Rule 1178 tank inspection report dated 5-8-2012 is included in Attachment 2. No compliance issues are noted. Monthly records of the commodity stored in this tank (crude oil) and the true vapor pressure (TVP = 0.85 to 6.24 psia) are included in Attachment 1. Condition C1.2: The throughput limit is 475 turnovers (118,750,000 bbl) in any one calendar year. Ultramar submitted throughput records showing 16.82 turnovers (4,205,544 bbl) from July 2011 to June 2012. Throughput records are included in Attachment 1.
Condition H23.7: The tank inspection and reporting requirements for 40CFR Part 60 Subpart K and 40CFR Part 63 Subpart CC are met by the Rule 463 and Rule 1178 tank inspection report dated 58-2012 (included in Attachment 2). No compliance issues are noted. Monthly records of the commodity stored in this tank (crude oil) and the true vapor pressure (TVP = 0.85 to 6.24 psia) are included in Attachment 1.
COMPLIANCE RECORD REVIEW: A check of the AQMD Compliance Database shows that the facility has received three Notices to Comply and 21 Notices of Violation since January 1, 2010. None of the NCs or NOVs apply to the storage tanks submitted for a change of condition. BACKGROUND: Ultramar, Inc. is a refinery in the city of Wilmington. The facility is a NOx and SOx RECLAIM facility. These four applications apply to external floating roof storage tanks located at the refinery. Table 1 lists the four change of condition applications received from Ultramar to change the tank classification from the Group 2 category to the Group 1 category under 40CFR 63 Subpart CC for four existing external floating roof storage tanks containing crude oil: 94-TK-9001, 94-TK-9002, 94-TK-9007, 94-TK-9009. Table 1 AQMD Applications Submitted A/N
Date Submitted
Equipment
Device ID
Requested Action
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PAGES 22 APPL. NO. 465213 - 465216 PROCESSED BY: Jon Uhl/Connie Yee Requested Action
A/N
Date Submitted
February 6, 2007
Equipment
Device ID
D255
465213
MASTER APPLICATION
Change from Group 2 to Group 1 category under 40CFR 63 Subpart CC Change from Group 2 to Group 1 category under 40CFR 63 Subpart CC Change from Group 2 to Group 1 category under 40CFR 63 Subpart CC Change from Group 2 to Group 1 category under 40CFR 63 Subpart CC
RECLAIM Facility Permit Amendment
465214
February 6, 2007
D256
465215
February 6, 2007
D261
465216
Storage Tank, 94-TK-9009 with External Floating Roof RECLAIM Facility Permit Amendment
D263
495049
n/a
FEE EVALUTION: The fees paid for the applications are as follows: Table 2 Application Fees Paid A/N
465213 465214 465215 465216 495049
Equipment
Storage Tank, 94-TK-9001 with External Floating Roof Storage Tank, 94-TK-9002 with External Floating Roof Storage Tank, 94-TK-9007 with External Floating Roof Storage Tank, 94-TK-9009 with External Floating Roof RECLAIM Facility Permit Amendment
Type 66 66 66 66 85
Status 21 21 21 21 21
Fee Schedule
C C C C n/a
Total
PERMIT CHANGES REQUESTED: Ultramar submitted application 465213 listed in Table 1 to: Change crude oil storage tank 94-TK-9001 from Group 2 to Group 1 category under 40CFR 63 Subpart CC. As a matter of corporate policy, Ultramar wishes to permit all their crude oil storage tanks as Group 1 to simplify their permit compliance requirements. In addition, the quantity of HAPs emitted
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from the tanks is directly related to the composition of the constituents in the crude oil and crude vapor. Ultramar has noted that a wider range of crude oils are now available for refining. To provide flexibility in the variety of crude oils stored, Ultramar has chosen to reclassify the tank to a Group 1 designation. Remove the reference to Tube-type primary seal. This is apparently a typographical error in the permit. The primary seal was changed from tube-type to wiper-type in 1992 (see A/N 271656), but both types were listed on the equipment description. The equipment description should only list a wiper-type primary seal.
There are no physical changes in the equipment, nor any change in the method of operation. Ultramar submitted application 465214 listed in Table 1 to: Change crude oil storage tank 94-TK-9002 from Group 2 to Group 1 category under 40CFR 63 Subpart CC. As a matter of corporate policy, Ultramar wishes to permit all their crude oil storage tanks as Group 1 to simplify their permit compliance requirements. In addition, the quantity of HAPs emitted from the tanks is directly related to the composition of the constituents in the crude oil and crude vapor. Ultramar has noted that a wider range of crude oils are now available for refining. To provide flexibility in the variety of crude oils stored, Ultramar has chosen to reclassify the tank to a Group 1 designation. Change the primary and secondary seal description from Flex-a-seal to Wiper Type. Flex-a-seal is a specific brand name for a wiper type seal from one manufacturer. Wiper Type is the generic description for this type of seal. Description change only; not an equipment modification.
There are no physical changes in the equipment, nor any change in the method of operation. Ultramar submitted application 465215 listed in Table 1 to: Change crude oil storage tank 94-TK-9007 from Group 2 to Group 1 category under 40CFR 63 Subpart CC. As a matter of corporate policy, Ultramar wishes to permit all their crude oil storage tanks as Group 1 to simplify their permit compliance requirements. In addition, the quantity of HAPs emitted from the tanks is directly related to the composition of the constituents in the crude oil and crude vapor. Ultramar has noted that a wider range of crude oils are now available for refining. To provide flexibility in the variety of crude oils stored, Ultramar has chosen to reclassify the tank to a Group 1 designation.
There are no physical changes in the equipment, nor any change in the method of operation. Ultramar submitted application 465216 listed in Table 1 to: Change crude oil storage tank 94-TK-9009 from Group 2 to Group 1 category under 40CFR 63 Subpart CC. As a matter of corporate policy, Ultramar wishes to permit all their crude oil storage tanks as Group 1 to simplify their permit compliance requirements. In addition, the quantity of HAPs emitted from the tanks is directly related to the composition of the constituents in the crude oil and crude vapor. Ultramar has noted that a wider range of crude oils are now available for refining. To provide flexibility in the variety of crude oils stored, Ultramar has chosen to reclassify the tank to a Group 1
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designation. There are no physical changes in the equipment, nor any change in the method of operation. Table 3 Storage Tank Specifications
External Floating Roof Tank 94-TK-9001 (D255) A/N 465213 Tank Dimensions Diameter, feet Volume, gallons (barrels) Throughput, barrels per year Turnovers Paint Characteristics Internal Shell Condition Shell Color/Shade Shell Condition Tank Construction and RimSeal System Construction: Primary Seal: Secondary Seal: Liquid Contents Mixture/Component Roof Characteristics Type Deck Fittings/Status 221.0 12,600,000 (300,000) 12,600,000 42 Light Rust White/White Good External Floating Roof Tank 94-TK-9002 (D256) A/N 465214 221.0 12,600,000 (300,000) 12,600,000 42 Light Rust White/White Good
Welded Mechanical Shoe Wiper Type, Rim-Mounted Crude Oil, max vapor pressure: 11 psia Pontoon
1-Access Hatch (24-in Dia.)/Bolted Cover, Gasketed 1-Gauge-Hatch/Sample Well (8-in Dia.)/Weighted Mech. Actuation, Gasketed 64-Roof Leg (3-in Dia.)/Adjustable, Pontoon Area, Sock 105-Roof Leg (3-in Dia.)/Adjustable, Center Area, Sock 1-Unslotted Guidepole Well/Gasketed Sliding Cover with Wiper 2-Vacuum Breaker (10 in Dia.)/ Weighted Mech. Actuation, Gasketed
Pontoon
1-Access Hatch (24-in Dia.)/Bolted Cover, Gasketed 1-Gauge-Hatch/Sample Well (8-in Dia.)/Weighted Mech. Actuation, Gasketed 64-Roof Leg (3-in Dia.)/Adjustable, Pontoon Area, Sock 105-Roof Leg (3-in Dia.)/Adjustable, Center Area, Sock 1-Unslotted Guidepole Well/Gasketed Sliding Cover 2-Vacuum Breaker (10 in Dia.)/ Weighted Mech. Actuation, Gasketed
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Welded Liquid Mounted Rim Mounted, Wiper Type Crude Oil, max vapor pressure: 7.3 psia Pontoon
1-Access Hatch (24-in Dia.)/Bolted Cover, Gasketed 1-Gauge-Hatch/Sample Well (8-in Dia.)/Weighted Mech. Actuation, Gasketed 30-Roof Leg (3-in Dia.)/Adjustable, Pontoon Area, Sock 105-Roof Leg (3-in Dia.)/Adjustable, Center Area, Sock 1-Slotted Guidepole /Gasketed Cover, Float, Sleeve, Wiper 2-Vacuum Breaker (10 in Dia.)/ Weighted Mech. Actuation, Gasketed
Pontoon
1-Access Hatch (24-in Dia.)/Bolted Cover, Gasketed 1-Gauge-Hatch/Sample Well (8-in Dia.)/Weighted Mech. Actuation, Gasketed 30-Roof Leg (3-in Dia.)/Adjustable, Pontoon Area, Sock 105-Roof Leg (3-in Dia.)/Adjustable, Center Area, Sock 1-Unslotted Guidepole Well/Gasketed Sliding Cover 2-Vacuum Breaker (10 in Dia.)/ Weighted Mech. Actuation, Gasketed
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EMISSIONS: There are no physical changes in the equipment, nor any change in the method of operation. No change in emissions is expected. RULES EVALUATION: PART 1 Rule 212 SCAQMD REGULATIONS November 14, 1997
The proposed change of condition meets all criteria in Rule 212 for permit approval. The change of conditions is expected to allow operation of this storage tank without emitting air contaminants in violation of Division 26 of the State Health and Safety Code or in violation of AQMDs rules and regulations. The change of conditions for this storage tank does not constitute a significant project because (1) the modified permit unit are not located within 1000 feet of a school; (2) the emissions increase does not exceed the daily maximum specified in subdivision (g) of this rule (30 lbs/day); and (3) the modified permit unit does not have an increased cancer risk greater than, or equal to, one in a million (1x 10-6) during a lifetime of 70 years or pose a risk of nuisance.
Rule 402
Nuisance Nuisance complaints are not expected under normal operating conditions.
May 7, 1976
Rule 463
May 6, 2005
This rule applies to any above-ground tank with capacity 19,815 gallons or greater for storing organic liquids. 463(c) Tank Roof Requirements. Tanks 94-TK-9001 & 94-TK-9002 are 300,000 bbl external floating roof tanks storing crude oil with a true vapor pressure greater than 0.5 psia. Tanks 94-TK-9007 & 94-TK-9009 are 250,000 bbl external floating roof tanks storing crude oil with a true vapor pressure greater than 0.5 psia. All four tanks are subject to the vapor controls requirements of Rule 463(c)(1) . External Floating Roof. All four external floating roof tanks are required to be equipped with the vapor control devices specified Rule 463(c)(1). These tanks are equipped with a pontoon type cover that rests on the surface of the organic liquid stored and are equipped with both a primary and a secondary seal between the tank shell and roof edge. Compliance is expected with proper inspection and maintenance practices. Other Performance Requirements.
463(c)(1)
463(d)
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May 6, 2005
The tanks are greater than 19,815 gallons and do not store gasoline. Therefore, this paragraph does not apply. The external floating roof shall float on the organic liquid at all times (i.e., free of the roof leg supports) except when the tanks are being completely emptied for cleaning, or repair. These external floating roof tanks do not store gasoline. Therefore, this paragraph does not apply. These tanks will not store organic liquids having a true vapor pressure of 11 psia (569 mm Hg) or greater under actual storage conditions. These tanks have stored crude oil for the past 10 years and records show TVP < 11 psia. Replacement seals on the tank will only be chosen from the current list of seals approved by District. The crude oil stored in this tank should continue to be in compliance with the vapor pressure limit. Compliance with Rule 463 is expected with proper recordkeeping and inspections.
463(d)(3) 463(d)(4)
463(d)(5) 463(d)(6)
Rule 1149
The tanks will continue to be subject to the tank cleaning and degassing requirements of this rule. Compliance is expected.
April 7, 2006
Applicability. This rule applies to all aboveground storage tanks with capacity greater than 19,818 gallons and used to store organic liquids with true vapor pressure greater than 0.1 psi and located at any petroleum facility emitting more than 20 tons per year of VOC in any emission inventory year starting with emission inventory year 2000. These four tanks store crude oil with a TVP greater than 0.1 psia and are therefore subject to Rule 1178. External Floating Roof Tanks. For tanks containing organic liquids with a true vapor pressure less than 3 psia for the emission inventory year 2000, the tank shall be equipped with the fittings specified in this paragraph. These four tanks store crude oil with a TVP which may exceed 3 psia. Since the tank stores liquids greater than 3 psia (crude oil), the tank is not subject to the fittings requirements of Rule 1178(d)(1).
1178(d)(1)
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Rule 1178
April 7, 2006
1178(d)(2)
Domed External Floating Roof Tanks. For tanks containing organic liquids greater than 3 psia for the emission inventory year 2000, a dome roof is required to be installed. Rule 1178(j)(7) provides an exemption from the doming requirements of paragraph (d)(2)(A) and (d)(2)(B) if the tank is permitted to contain more than 97% by volume crude oil and complies with all the remaining applicable requirements of this rule.
Specifications: Contains more than 97%vol crude oil? Maximum vapor pressure: psia
1178(d)(2)(D)
94-TK-9001 [D255]
94-TK-9002 [D256]
94-TK-9007 [D261]
94-TK-2009 [D263]
Yes 11.0
Yes 11.0
Yes 7.3
Yes 11.0
The external floating roof tank has been equipped with all roof openings in accordance with the specifications listed in subparagraph (d)(1)(A):
94-TK-9001 [D255] 94-TK-9002 [D256] 94-TK-9007 [D261] 94-TK-2009 [D263]
Specifications: (i) Equip each access hatch and gauge float well with a cover that is gasketed and bolted. The cover shall be closed at all times, with no visible gaps, except when the hatch or well must be opened for access. (ii) Equip each gauge hatch/sample well with a cover that is gasketed. The cover shall be closed at all times, with no visible gaps, except when the hatch or well must be opened for access. (iii) Gasket or cover each adjustable roof leg with a VOC impervious sock at all times when the roof is floating. (iv) Gasket each rim vent. Rim vents shall be closed at all times, with no visible gaps, when the roof is floating; and shall be set to open only when the roof is being floated off the roof leg supports or when the pressure beneath the rim seal exceeds the manufacturer's recommended setting
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
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Rule 1178
April 7, 2006
94-TK-2009 [D263]
Specifications: (v) Gasket each vacuum breaker. Vacuum breakers shall be closed at all times, with no visible gaps, when the roof is floating; and shall be set to open only when the roof is being floated off or is being landed on the roof leg supports. (vi) Equip each open floating roof drain with a slotted membrane fabric cover or other device with an equivalent control efficiency that covers at least 90 percent of the area of the opening. (vii) Equip each unslotted guidepole well with a gasketed sliding cover and a flexible fabric sleeve or wiper (viii) Equip each unslotted guidepole with a gasketed cover at the end of the pole. The cover shall be closed at all times, with no visible gaps, except when gauging or sampling. (ix) Equip each slotted guidepole with a gasketed cover, a pole wiper and a pole sleeve. The pole sleeve shall be extended into the stored liquid (x) Equip each slotted guidepole having a pole float with a gasketed cover, a pole wiper, and a pole float wiper. The wiper or seal of the pole float shall be at or above the height of the pole wiper. (xi) Cover each slotted guidepole opening with a gasketed cover at all times, with no visible gaps, except when the cover must be opened for access.
Yes
Yes
Yes
Yes
Yes
Yes
N/A
Yes
Yes
Yes
N/A
Yes
N/A
N/A
Yes
N/A
N/A
N/A
Yes
N/A
N/A
N/A
Yes
N/A
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Rule 1178
April 7, 2006
94-TK-2009 [D263]
Specifications: (xii) Maintain the pole float in a condition such that it floats within the guidepole at all times except when it must be removed for sampling or when the tank is empty. (xiii) Except for vacuum breakers and rim vents, ensure that each opening in the external floating roof shall provide a projection below the liquid surface. (xiv) Except for vacuum breakers, rim vents, roof drains, and leg sleeves, equip all other openings in the roof with a gasketed cover or seal which is closed at all times, with no visible gaps, except when the cover or seal must be opened for access. Subparagraph (d)(1)(B) Specifications: (i) The primary seal shall be a mechanical shoe or liquid mounted. (ii) The secondary seal shall be rim mounted and shall not be attached to the primary seal.
N/A
N/A
Yes
N/A
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Mechanical Shoe
Yes
Mechanical Shoe
Yes
Liquid mounted
Yes
Mechanical Shoe
Yes
Yes
Yes
Yes
REG XIII
These tanks were subject to New Source Review when they were constructed. These applications propose no increase in crude oil throughput or vapor pressure; therefore, no increase in emissions. 1303(a) Best Available Control Technology (BACT). No increase in emissions; therefore, no BACT requirements. The tanks are all already equipped with primary and secondary seals. The storage tanks have only stored crude oil for over 10 years now.
1303(b)
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Rule 1401
March 4, 2005
These applications propose no increase in crude oil throughput or vapor pressure; therefore, no increase in emissions and no increase in the MICR and HIA and HIC for both off-site worker and residential receptors. Federal NSR for toxics does not apply since this is not considered a reconstruction per 40CFR63, Subpart A, 63.2.
Regulation XX
RECLAIM
May 6, 2005
Ultramar has been designated as a RECLAIM facility. These crude oil storage tanks do not emit NOx or SOx; therefore, RECLAIM requirements do not apply to these applications.
Regulation XXX
Title V
Ultramar is a designated as a Title V facility. Ultramars Title V permit became effective on May 29, 2009. Therefore, the facility is now subject to the requirements of Regulation XXX. This application is considered a Minor Permit Revision as defined in Rule 3000 and subject to 45 day review by EPA. PART 2 STATE REGULATIONS
California Environmental Quality Act (CEQA) This proposed change of condition is not a significant project.
PART 3
FEDERAL REGULATIONS
Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978
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Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 This tank is currently subject to 40 CFR 60 Subpart K. This tank currently complies with tank design/control requirements of Subpart K. 40CFR Part 60 Subpart Kb applies to storage vessels for which construction, reconstruction, or modification commenced after July 23, 1984. In order for a modification to occur under NSPS, there must be a pound per hour (lb/hr) increase in emissions to the atmosphere as a result of physical or operational changes. There is no increase in emissions; this tank is not subject to Subpart Kb. These applications for change of condition will subject the storage tanks to 40CFR Part 63 Subpart CC as Group 1 storage vessels. Per 63.640(n)(5), a Subpart CC Group 1 storage vessel that is also subject to the provisions of 40CFR Part 60 Subpart K is required to comply only with the provisions of Subpart CC.
National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries
In accordance with 63.641 Definitions. of 40CFR Part 63 Subpart CC, a Group 1 storage vessel means a storage vessel at an existing source that has a design capacity > 46,758 gallons (1,113 barrels) and stored-liquid maximum true vapor pressure > 1.5 psia and stored-liquid annual average true vapor > 1.2 psia and annual average HAP liquid concentration > 4 percent by weight total organic HAP. A Group 2 storage vessel means a storage vessel that does not meet the definition of a Group 1 storage vessel. In Ultramars case, the Subpart CC storage vessel group designation is based on the stored-liquid annual average HAP liquid concentration. Crude oil storage tanks 94-TK9001, 94-TK-9002, 94-TK-9007, and 94-TK-9009 are currently tagged as Subpart CC Group 2 storage vessels because the crude oil stored is < 4 % by weight total organic HAP. Ultramar requested a change of condition to tag these four tanks as 40CFR Part 63 Subpart CC Group 1 storage vessels, based on their concern that the weight percent of total organic HAP may exceed the Group 2 limitation of 4%wt HAP maximum at some point in the future since there are a variety of crude oils now available for refining. Section J of the current facility permit specifies that the operator shall not reclassify a Group 2 emission point to a Group 1 emission point without first obtaining a valid permit from the AQMD. Since the average annual HAP liquid concentration can only be determined after the fact, and the control, inspection, recordkeeping and reporting requirements are more restrictive for Group 1 storage vessels than Group 2 storage vessels, imposing the Group1 storage vessel requirements is the more conservative designation for air quality purposes.
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National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries
These four tanks currently comply with the 40CFR Part 63 Subpart CC Group 1 storage vessel requirements for VOC emission control (mechanical shoe primary seal plus a rim mounted, double weld wiper secondary seal) and the inspection, recordkeeping and reporting requirements through compliance with District Rules 463, 1149 and 1178. Ultramar included these four tanks as 40CFR 63.464 Storage Vessels, Group 1 in their Periodic Monitoring and Exception Reports to the EPA since 2007. See Attachment 2. Continued compliance with the requirements of 40CFR Part 63 Subpart CC for Group 1 storage vessels is expected.
CONCLUSION: Based on the above evaluation, it recommended that the following be issued: A/N 465213
MASTER APPLICATION
Recommendation Issue Permits to Operate Revise Ultramar facility permit (ID 800026) to show the administrative changes to the tank seal descriptions and the change in conditions from 40CFR Part 63 Subpart CC Group 2 storage vessels to Group 1 storage vessels. Approve Revision Application
List of Attachments
1. Tank throughput and vapor pressure records, July 2011 to June 2012 2. MACT Semi-Annual Report for Period January 1 through June 30, 2012 Rule 463 & Rule 1178 Tank Inspection Report , May/June 2012
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Attachment 1. Tank throughput and vapor pressure records, July 2011 to June 2012
Tank Capacity Limit Monthly Throughput Month-Year Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Total
94-TK-9001 300,000 42
94-TK-9002 300,000 42
bbls 830,940 869,820 634,024 758,145 681,211 577,265 277,858 453,123 841,511 691,212 797,385 783,874 8,196,368
turnovers 2.77 2.90 2.11 2.53 2.27 1.92 0.93 1.51 2.81 2.30 2.66 2.61 27.32
bbls 900,873 745,914 740,236 789,358 687,126 691,122 294,676 353,172 762,957 822,007 784,732 760,597 8,332,770
turnovers 3.00 2.49 2.47 2.63 2.29 2.30 0.98 1.18 2.54 2.74 2.62 2.54 27.78
bbls 374,078 274,041 265,648 379,303 418,860 302,330 77,871 144,342 486,505 528,818 552,610 362,579 4,166,985
turnovers 1.50 1.10 1.06 1.52 1.68 1.21 0.31 0.58 1.95 2.12 2.21 1.45 16.67
bbls 269,409 425,709 348,033 262,432 291,901 481,499 173,773 138,691 425,104 402,835 425,465 560,693 4,205,544
turnovers 1.08 1.70 1.39 1.05 1.17 1.93 0.70 0.55 1.70 1.61 1.70 2.24 16.82
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Tank Number
Monthly Vapor Pressure, psia, and Contents July 2011 4.18 Crude Aug 2011 4.31 Crude 4.49 Crude 1.73 Crude 1.71 Crude
Sept 2011
Oct 2011 3.18 Crude 2.88 Crude 3.98 Crude 4.60 Crude
Nov 2011 2.74 Crude 3.28 Crude 3.97 Crude 4.55 Crude
Dec 2011 3.85 Crude 3.58 Crude 3.78 Crude 4.04 Crude
Jan 2012 2.20 Crude 2.14 Crude 4.91 Crude 4.41 Crude
Feb 2012 2.15 Crude 2.17 Crude 3.40 Crude 1.94 Crude
Mar 2012 4.97 Crude 3.08 Crude 3.25 Crude 6.24 Crude
Apr 2012 1.87 Crude 2.28 Crude 1.53 Crude 3.33 Crude
May 2012
June 2012
94-TK9001
94-TK9002
TVP<11 psia
3.70 Crude
94-TK9007
TVP<7.3 psia
1.13 Crude
94-TK9009
TVP<11 psia
0.85 Crude
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Attachment 2. MACT Semi-Annual Report for Period January 1 through June 30, 2012 Rule 463 & Rule 1178 Tank Inspection Report, May/June 2012