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The Slotted Guidepole Agreement

Rob Ferry the TGB partnership Hillsborough, NC tgb@mindspring.com

The STERPP
Storage Tank Emission Reduction Partnership Program
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Guidepole Through a Floating Roof


Guidepole

Guidepole Deck Fitting Guidepole Floating roof deck


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Guidepole Deck Fitting


Guidepole Deck cover (sliding-shown cutaway) Pole wiper Roller assembly (optional)

Rim Deck cover gasket

Floating roof deck


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What Controls are Acceptable?


1. Pole Float (w/cover gasket/pole wiper). 2. Alternate Technology Equal to Option 1. 3. Pole Sleeve (w/cover gasket/pole wiper). 4. Internal Sleeve (blocking all slots). 5. Solid Guidepole (no slots). 6. Flexible Enclosure (slinky). 7. Covered EFRT (no add-on controls). 8. Removal from (regulated matl) Service.

STERPP Option 1: Pole Float


Slotted guidepole Pole wiper Deck cover (sliding) Rim Deck cover gasket

Wiper/seal on pole float rim Rim Pole float Liquid surface Opening through the deck Floating roof deck Bottom of the float
Dotted lines under the sliding cover show an alternate location for the pole wiper.

STERPP Option 2: Alternates


Any slotted guidepole control device with emission factor equal to Option 1 or lower. Any combination of deck fitting controls with equal or lower combined emission factor as if subject to Kb and STERPP. API Test Methods are an accepted basis for demonstrating equivalency.
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STERPP Option 3: Pole Sleeve


Slotted guidepole Pole wiper Deck cover (sliding) Rim Deck cover gasket

Pole sleeve Liquid surface Opening through the deck

Rim Floating roof deck Bottom of the sleeve


Dotted lines show an alternate location for attachment of the pole sleeve.

STERPP Option 4:
Slotted guidepole Pole wiper Deck cover (sliding) Internal sleeve

Internal Sleeve
Cover (hatch) at the top of the pole Rim Deck cover gasket

Cover (hatch) at the top of the guidepole (shown partially open) Internal sleeve

Rim Floating roof deck

Liquid surface Opening through the deck

The internal sleeve extends the entire length of the guidepole, thereby blocking flow through the slots. 9

STERPP Option 5: Solid Guidepole


Solid guidepole (unslotted) Cover (hatch) at the top of the guidepole (shown partially open) No slots above the liquid level for vapors to enter the guidepole Liquid surface at the lowest operating level

Slots, if any, only located below the liquid level

Bottom of the guidepole Bottom of the tank

Solid guidepole means a guidepole or gaugepole that does not have slots or holes through the wall of the pole at or above the level of the floating roof when it is at its lowest operating level.

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STERPP Option 6: Flexible Enclosure


Cover (hatch) at the top of the guidepole (shown partially open)

Flexible enclosure

Flexible enclosure: A flexible device that completely encloses the slotted guidepole and eliminates the hydrocarbon vapor emission pathway from inside the tank through the guidepole slots to the outside air.

Rim Liquid surface Opening through the deck 11 Floating roof deck

STERPP Option 7: Covered EFRT

The tank was built as an external floating-roof tank, and was subsequently covered with a fixed roof.

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STERPP Option 8: Removal from Service


Rather than upgrade the slotted guidepole; remove the tank from regulated matl service.
The tank may still be used, but only to store liquid stocks with true vapor pressure < the Ka/Kb cutoffs.

Surrender (revise) operating permits to show that this tank is not to store regulated material.
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To Get a Copy of the FR Notice


Download the Final Notice of the STERPP:
www.access.gpo.gov/su_docs/fedreg/a000413c. html Listing April 13, 2000 Federal Register Notices Scroll to Environmental Protection Agency Find the STERPP under Notices

65 FR 19891 (April 13, 2000)


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