the TGB partnership

September 2, 2005

1325 Farmview Road

Hillsborough, NC 27278
Phone: 919-644-8250
FAX: 919-644-8252
e-mail: Rob.Ferry@TGBpartnership.com

EPA Emission Factors for

Tank Truck Loading
prepared by Rob Ferry
Overview
When tank trucks are loaded at a bulk gasoline terminal, the vapors displaced from the cargo tanks are
routed to vapor control devices. The emissions associated with this control technology are partly due to
leakage from the tank truck during the loading process, and partly due to any inefficiency of the vapor
control device. The control device efficiency is typically expressed as a percent reduction in the
concentration of vapors. The additional emissions that occur as leakage from the tank truck may be
expressed as an adjustment to the overall control efficiency, or may be calculated separately by applying
emission factors.
The United States Environmental Protection Agency (EPA), during the promulgation of the MACT rule for
the gasoline distribution industry1, developed revised emission factors for leakage from tank trucks during
loading at bulk gasoline terminals. The development of the revised factors is documented in Appendix A
of the rules final background information document (BID Volume II)2.
BID Volume II presents an equation for calculating the volume of leakage as a function of the leaktightness
of the trucks cargo tank. EPA then solved the equation for selected scenarios in order to obtain emission
factors. One of the scenarios evaluated was for tank trucks that are subject to the California pressure decay
limit of 1-inch of water column over a 5-minute period, from an initial pressure of 18 inches of water
column (now required nationwide of facilities that are subject to the gasoline distribution MACT rule). The
leak rate that was determined for the loading of tank trucks that pass the 1-inch pressure decay limit was
3.3 milligrams of emissions for every liter of gasoline that is loaded into the truck (3.3 mg/liter).
EPA relied on data from the Bay Area Air Quality Management District to determine a failure rate of 3.8
percent for tank trucks tested to the 1-inch pressure decay limit. A weighted average emission factor was
then calculated, based on a leak rate of about 121 mg/liter for the 3.8 percent of tank trucks that fail the test
and a leak rate of 3.3 mg/liter for the tank trucks that pass the test. The resulting weighted-average
emission factor that EPA determined for tank trucks that are subject to the 1-inch pressure decay limit is 8
mg/liter.
Using this same methodology, EPA determined a weighted-average emission factor of 13 mg/liter for tank
trucks that are subject to a 3-inch pressure decay limit (as required by the NSPS for bulk gasoline
terminals3).
It would be useful to present the equations used by EPA in a general manner, so that emission factors for
tank trucks during loading could be calculated for situations where facility-specific data are available.

National Emission Standards for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout
Stations), 40 CFR Part 63 Subpart R.
2
Gasoline Distribution Industry (Stage I) Background Information for Promulgated Standards, EPA-453/R-94002b, November 1994.
3
U.S. Environmental Protection Agency, Standards of Performance for Bulk Gasoline Terminals, 40 CFR Part 60,
Subpart XX.

Emission Factor for Tank Trucks During Loading

page 2 of 4

EPA Calculations
BID Volume II uses the following equation:
T P f

V L = 0.5V 1
tp
Pi

where:
VL = volume of leakage (liters),

= capacity volume of the cargo tank (liters),

= total time for loading (minutes),

= V/R,

= loading rate (liters/minute),

tp

= time limit for pressure test (minutes),

Pf = final pressure for test (inches H2O absolute), and

Pi = initial pressure for test (inches H2O absolute).
EPA then divided the volume of leakage (VL) by the capacity volume of the cargo tank (V), in order to
express leakage as a ratio of the volume loaded. This resulted in the following form of the equation:
VL
V 1 Pf
= 0.5 1
V
Pi
R t p
The following values were selected by EPA as being representative for the scenario of a tank truck just
passing the 1-inch pressure decay test:
V

= 32,200 liters,

= 2,270 lpm,

tp

= 5 minutes,

Pf = 424 inches H2O absolute (17 inches H2O gauge plus atmospheric pressure of 407 inches
H2O absolute), and
Pi = 425 inches H2O absolute (18 inches H2O gauge plus atmospheric pressure of 407 inches
H2O absolute).
Substituting these values yields the following:

VL
32,200 1 424
= 0.5
1
= 0.0033
V
2,270 5 425
This means that the volume of leakage as a fraction of the volume loaded is equal to 0.0033, or 0.33
percent. EPA then multiplied this volume fraction by the density of vapors, assuming that the vapor space
was saturated. EPA used a value of 1,014 mg/liter for the density of vapors, and thus calculated a leak rate
of (0.0033)(1,014 mg/liter) = 3.3 mg/liter.
Introducing a variable, WV , as the density of vapors, we may rewrite our equation as follows:
VL
V 1
WV = 0.5
V
R t p

P f
1
WV

P
i

V
The term L WV is the leak rate, or emission factor, in terms of milligrams per liter loaded. Lets define

V
a variable LL to represent the emission factor, such that:

Emission Factor for Tank Trucks During Loading

LL =

VL
V 1
WV = 0.5
V
R t p

page 3 of 4

P f
1
WV

Pi

and then:
V 1
L L = 0.5
R t p

P f
1
WV

Pi

For the pressure decay limit of 1-inch of water column over a 5-minute period, from an initial pressure of
18 inches of water column, the following values would be constants:
tp

= 5 minutes,

Pf = 424 inches H2O absolute (17 inches H2O gauge plus atmospheric pressure of 407 inches
H2O absolute), and
Pi = 425 inches H2O absolute (18 inches H2O gauge plus atmospheric pressure of 407 inches
H2O absolute).

The density of vapors, WV , is a function of the partial vapor pressure, temperature, and molecular weight of
the vapors. EPA used a constant value of 1,014 mg/liter as representative for gasoline at bulk gasoline
terminals in the United States.
Conclusion
EPA has developed emission factors of 8 mg/liter for estimating leakage during loading from tank trucks
that are subject to a 1-inch pressure decay test, and 13 mg/liter for tank trucks that are subject to a 3-inch
pressure decay test. These emission factors were determined as weighted averages of the emission rates for
tank trucks that pass the 1-inch pressure decay test, and tank trucks that do not pass the test, as summarized
in the following table:

Pressure decay limit

(wc loss over 5 min.)
1-inch
3-inch

Passing
leak rate
3.3 mg/L
10 mg/L

Failing
leak rate
121 mg/L
121 mg/L

Percent
failure
3.8 %
3.1 %

Weighted average
emission factor
8 mg/L
13 mg/L

The method used by EPA to determine these leak rates is presented above in a general expression that
could be adapted to specific scenarios. Any such facility-specific determination, however, should also
account for the portion of the tank trucks served by that facility that fail the pressure decay test.
Alternatively
These emissions may be accounted for in the overall reduction efficiency of the collection system and
control device, as described in section 5.2.2.1.1 of EPAs AP-42 document4. The emission factor of 8
mg/liter is 0.8 percent of the saturated vapor density of 1,014 mg/liter. The capture efficiency is therefore
99.2 percent. In order to obtain the overall reduction efficiency, the efficiency of the control device would
be multiplied by 0.992.

Compilation of Air Pollution Emission Factors Volume I: Stationary Point and Area Sources, EPA Report AP-42,
Fifth Edition, January 1995; and notice of proposed change to section 5.2, December 15, 1995.

Emission Factor for Tank Trucks During Loading

page 4 of 4

Derivation of the 1,014 mg/liter value for saturated gasoline vapor density

The EPA-value of 1,014 mg/liter for the saturated vapor density incorporates assumed values for the
variables in the filling loss equation, as demonstrated below:
Density is equal to mass divided by volume.
Mass of vapors = n MV
At equilibrium, from the Ideal Gas Law
n
P
=
; and thus:
V RT

PM V
mass nM V
Density =
=
=

V
RT
volume
where: R

psia ft 3

= the ideal gas constant (rather than the loading rate) = 10.731
o

lb
mole
R

Density =

P MV
10.731 T

133.7 ft 3

1,000 gallons

S P MV
pounds
= 12.46
; this is Equation 1 from AP-42 5.2
Density
T
1,000 gallons
If values of S = 1, P = 5.35 psia, MV = 66, and T = 520oR (60oF) are used, the resulting emission factor is
approximately 8.46 (pounds/1,000 gallons), or 1,014 mg/liter matching the value used by EPA.