Biographical Information William J. Bruscino, P.E., Principal - - PDF document

Workshop D

Air P Air Permitting … In rmitting … Invaluable Guidance luable Guidance

• n Ho
• n How t

w to Establish P Establish Potential t ntial to Emit Emit (PTE) f (PTE) for Y r Your F ur Facility cility Wednesda dnesday, July 25, 20 July 25, 2018 1 p.m. t 1 p.m. to 2:30 p.m. 2:30 p.m.

Biographical Information

William J. Bruscino, P.E., Principal Consultant, Trinity Consultants 110 Polaris Parkway, Suite 200, Westerville, Ohio 43082 614.433.0733 bbruscino@trinityconsultants.com

• Mr. Bruscino manages air quality permitting and compliance services for industries such as refining,

chemical manufacturing upstream and midstream oil and gas, and general manufacturing. His experience includes Title V and PSD permitting in EPA Regions IV, V, and VI as well as compliance assessments and implementation projects. Mr. Bruscino has also assisted multiple facilities in establishing Title V and minor source air compliance programs including environmental management information system (EMIS) implementations. More specifically, he has audited and developed regulatory compliance programs for facilities operating a few emergency engines to corporate entities managing hundreds of engines. Mr. Bruscino currently manages Trinity’s Columbus, Ohio office and is a member

• f the Air & Waste Management Association. He received a Bachelor’s degree in chemical engineering

from the University of Cincinnati and holds a Professional Engineering license in the State of Ohio. Andrew R. Dunagan, Senior Consultant, Trinity Consultants Inc. 110 Polaris Parkway, Suite 200, Westerville, OH 43082 (614) 433-0733 adunagan@trinityconsultants.com

• Mr. Andrew Dunagan serves as a Senior Consultant in Trinity’s Columbus, Ohio office. He started his

career with Trinity Consultants in 2012 after graduating from The Ohio State University with a B.S. in Chemical Engineering. Among other topics, his experience includes a wide-range of synthetic organic chemical manufacturing industry (SOCMI) support (e.g., MON, HON, RCRA, BWON, NSPS SOCMI regulations, M21 inspections, and general wastewater requirements), Title V compliance management, periodic reporting, air dispersion modeling, air emission inventory development, Spill Prevention, Control, and Countermeasure (SPCC)/Storm Water Pollution Prevention Plan (SWPPP) development, toxic release inventory reporting (TRI), and extensive Leak Detection and Repair (LDAR) support. He has experience serving the oil and gas, chemical manufacturing, steel, surface coating, roofing and asphalt, lime, glass recycling, and glass manufacturing industries. Michael E. Hopkins, P.E., Assistant Chief, Permitting, Division of Air Pollution Control Ohio EPA, P.O. Box 1049, Columbus, OH 43216-0149 (614) 644-2270 FAX: (614) 644-3681 mike.hopkins@epa.ohio.gov Michael Hopkins has been with the Ohio EPA since 1980. He is currently the Assistant Chief, Permitting

• f the Ohio EPA. His duties include the review and final approval for all air pollution permit-to-install,

permit-to-install and operate, and Title V permitting in the State, the development of technical support for air pollution control regulations, litigation support, MACT program support, Tax Program support and general air pollution planning activities. He has been in this position since April 2003. Before this assignment, he was in charge of the Air Quality Modeling and Planning Section with similar duties as above from August 1993 through April 2003. Prior to that assignment, he was in charge of the engineering section of the Ohio EPA Central District Office air program. The engineering section is responsible for reviewing air pollution permit-to-install and permit-to-operate applications for compliance with air pollution regulations, facility inspections, complaint investigations, enforcement case development, policy and rule development, the Emissions Inventory Program, and other related duties in the central Ohio area.

• Mr. Hopkins earned his Bachelor’s degree in environmental engineering from the Pennsylvania State
• University. He is a licensed Professional Engineer in the State of Ohio. He is a member of the Air and

Waste Management Association, the National Society of Professional Engineers and the Ohio Society of Professional Engineers.

29th Annual Conference on Air & Water Permits – Environmental Permitting in Ohio

Workshop D – Best Practices in Air Permitting & Compliance – PTE and Tanks Focus

July 24, 2019

Potential to Emit

Workshop D July 24, 2019

Michael Hopkins, P.E. Assistant Chief, Permitting Division of Air Pollution Control 614‐644‐3611 Mike.hopkins@epa.ohio.gov

Topics

• Multiple PTE Definitions
• Unique PTE Calculations
• PTE Guidance Memos

3

MULTIPLE PTE DEFINITIONS

Multiple PTE Definitions

• Different rules have different PTE definitions
• Must review the PTE definition for the rule
• Unique PTEs

– De Minimis (OAC rule 3745‐15‐05(A)(6)) – NSR rules (3745‐31‐01(BBBBB)) – SB 265 for <10 ton BAT (ORC 3704.03(T); OAC 3745‐31‐05(A)(3)(ii)) – Title V (3745‐77‐01) – MACT (40 CFR 63.2)

5

De Minimis

• OAC rule 3745‐15‐05(A)(6))
• Based on 24‐hour and Annual
• Don’t count control unless integral
• Operate equipment at max rated capacity
• Calculate:

– 24‐hour for each criteria (10 lb/day) – Combined similar source annual PTE (25 ton/yr) – Annual PTE for combined HAPs (1 ton/yr)

6

NSR Rules

• 3745‐31‐01(BBBBB)
• Applies to PSD, NNSR, netting, syn minor
• Use physical and operational design
• Include control equipment (assuming will be
• r is required in permit)

– Note: some states do not include control equipment

7

NSR Rules

• Include federally enforceable or legally and

practically enforceable by the state rule limits

• Include synthetic minor limits assuming they

were established w a comment period

• Don’t count secondary emissions

(construction or other emissions from non emissions units.)

<10 ton/yr BAT Exemption PTE

• ORC 3704.03(T); OAC 3745‐31‐05(A)(3)(ii)
• Calculation to determine if you qualify for the

<10 ton/yr BAT exemption

• Installed or modified after August 3, 2006
• Use equipment capacity
• 24 hr/day; 365 day/yr operation
• Include the use of controls

9

Title V

• 3745‐77‐01(DD)
• Emissions unit by emissions unit PTE totaled

to get facility‐wide calculation

• Use physical and operation maximum design

capacity

• Utilize federally enforceable rules

10

Title V

• Calculate uncontrolled emissions unless the

controlled emissions were established w a comment period and are federally enforceable

• r state legally and practically enforceable

– See EG #80 Title V section for a detailed explanation

• Use federally enforceable or state legally and

practically enforceable restrictions

Title V

• Listed uncontrolled fugitives

must be included

• Exclude secondary

emissions (construction or non emissions unit emissions)

• EG #61 <20% presumed

inherent physical limitation 12

This Photo by Unknown Author is licensed under CC BY‐SA‐NC

Presumed Inherent Physical Limitation

• Calculate actual emissions – not PTE
• Actual emissions < 20% of each of the TV

thresholds?

– 100 ton/yr each criteria – 25 ton/yr individual or combined HAP

• If so, facility can be non‐Title V
• Notify Ohio EPA contact
• Keep actual records

MACT

• Annual emissions
• Use physical and operational maximum design

capacity

• Calculating annual individual HAP and annual

combined HAPs

• After controls
• Use federally and state legally and practically

enforceable limits 14

What about fed PSD/NNSR Rules?

• Federal PSD (40 CFR 52.21) and NNSR (40 CFR

51, Appendix S) do not apply in Ohio

• Ohio’s NSR program is fully approved
• Use Ohio’s NSR rules instead

– OAC 3745‐31‐01 – OAC 3745‐31‐10 through 20 PSD – OAC 3745‐31‐21 through 27 NNSR

• Use Ohio PTE definitions (similar to fed)

15

Guidance on This?

• Ohio EPA Engineering Guide #80, “How should

PTE be calculated for determining the applicability of De Minimis Status, BAT, Senate Bill 265 BAT Exemption, Title V, Maximum Achievable Control Technology, Prevention of Significant Deterioration and Non‐Attainment New Source Review?” 16

Fed/State Enforceable BAT?

• What about BAT in permits that don’t go

draft? Can the limits be used to limit PTE?

• If they have appropriate state legally and

practically enforceable limits ‐‐‐ YES

• BAT rule is in the federally approved Ohio SIP

17

Fed/State Enforceable BAT?

• See Question 28 from the Feb. 7, 2014 BAT

guidance

– https://www.epa.ohio.gov/dapc/sb265

• Synthetic minor restrictions must still go draft

UNIQUE PTE CALCULATIONS

19

Degreasers and Cold Cleaners

• Rules have control

equipment requirements

• No rule emission

limits

• PTE based on usage
• f solvent minus

solvent disposed

This Photo by Unknown Author is licensed under CC BY

20

Degreasers and Cold Cleaners

• Application asks for:

– Solvent name – Maximum gallons used / yr – Solvent density lb/gal – Solvent disposed of (gallon/yr) – Solvent content of the waste (% by volume)

21

Degreasers and Cold Cleaners

22

Printing Lines

• Variables: line speed,

# colors, % coverage, VOC content, fountain solution, etc.

• EG #68
• Base on inherit press

capacity and historic material usage

https://epa.ohio.gov/dapc/engineer/eguides#125933907‐table‐

• f‐engineering‐guides

23

Printing Lines

• Acceptable assumptions listed in guide

– 95% ink OC retained in the web – 100% fountain solution emitted – % clean‐up solvent emitted

• VP <10mm hg, assume 50% emitted
• VP >=10 mm hg, assume all emitted
• EG has several forms to aid in calculations
• Worked with the Printing Industry of Ohio to

develop 24

Coating Operations

• Lots of variables: line speed,

VOC content, part size, paint thickness, thinners

• Can’t assume paint gun open

24/7

• EG #45 defines approach

– https://epa.ohio.gov/Portals/27/ engineer/eguides/GUIDE45.pdf

25

Coating Operations

• Operating scenario that results in the most

coating/solvent used

• Maximum practical speed for which

acceptable parts can be painted

• Assume 24/365 operation unless restricted
• EG #45 has calculation methods

26

Hazardous Air Pollutants for Coating Operations

• Mixture of solvents/HAPs in paints
• Each solvent/HAP has its own density
• Often use multiple coatings
• PTE of individual HAPs and combined HAPs

needed 27

Hazardous Air Pollutants for Coating Operations

• Too many variables to establish HAP usage

restriction

• How is this done?
• PTE is calculated based on maximum expected

usage

• Similar to coatings… use highest HAP emitting
• perating mode

Hazardous Air Pollutants for Coating Operations

• Calculate highest hourly;

them multiply by 24 hr/day, 365 day/yr

• Result is ton/yr for Individual

HAPS and Combined HAPs

• Good thing we have

spreadsheets! 29

This Photo by Unknown Author is licensed under CC BY‐NC

Paint and Body Shops PBR

• Qualify for PBR – don’t need to do PTE calc.
• Meet qualifying criteria

– <= two booths; <50 jobs/week; <3,000 gal/yr coatings, solvents etc; vent sys.; type spray gun; exhaust fan/stack

• Submit request to be covered by PBR
• https://epa.ohio.gov/portals/41/sb/publicatio

ns/AutobodyPBRGuide.pdf 30

PTE GUIDANCE MEMOS

PTE Guidance Memos

• June 13, 1989 Hunt/Seitz memo, “Guidance
• n Limiting Potential to Emit in New Source

Permitting”

• January 22, 1996 Seitz memo, “Release of

Interim Policy an [SIC] Federal Enforceability

• f Limitations on Potential to Emit”

32

PTE Guidance Memos

• January 25, 1995 Stein memo, “Guidance an

Enforceability Requirements for Limiting Potential to Emit through SIP and §112 Rules and General Permits”

• August 29, 1996 Seitz memo, “Clarification of

Methodology for Calculating Potential to Emit (PTE) for Batch Chemical Production Operations” 33

PTE Guidance Memos

• April 14, 1998, Seitz memo, “Potential to Emit

(PTE) Guidance for Specific Source Categories”

• January 25, 1996 Seitz memo, “Options for

Limiting the Potential to Emit (PTE) of a Stationary Source Under Section 112 and Title V of the Clean Air Act (Act)” 34

PTE Guidance Memos

• Ohio EPA Engineering Guide #61, “What is

Ohio EPA's policy for limiting the potential to emit (PTE) of air contaminant emissions at a facility for purposes of avoiding federal permitting?”

• Ohio EPA Engineering Guide #45, “Calculating

Potential to Emit for Coating Lines” 35

PTE Guidance Memos

• Ohio EPA Engineering Guide #4, “Should
• rganic compounds such as methane, ethane,

1,1,1‐trichloroethane, methylene chloride and trichorotrifluoroethane be excluded when calculating “potential to emit” (PTE) in order to determine the applicability of OAC rule 3745‐21‐07 or OAC rule 3745‐21‐09? 36

Need Help?

• Guidance:

– https://epa.ohio.gov/dapc/engineer/eguides – https://www.epa.gov/nsr/new‐source‐review‐ policy‐and‐guidance‐document‐index – http://ohioepa.custhelp.com/app/home

• Permit‐Specific

– Consultant – District Office or local air agency permit contact – OCAPP

37

Potential to Emit Example

How fast did you drive here?

Evan Klein, Road and Track http://www.roadandtrack.com/car‐culture/a25775/almost‐infamous‐2015‐lamborghini‐huracan/

How fast did you drive here?

SPEED LIMIT

35

SPEED LIMIT

65

SPEED LIMIT

25

SPEED LIMIT

35

EXIT

Distance D (mi) Speed R (mi/hr) Time T (hr) 17.5 35.0 0.5 195.0 65.0 3.0 17.5 35.0 0.5 12.5 25.0 0.5 242.5 53.9 4.5 Distance (mi) Emission Factor (g/mi) CO Emissions (lbs) 17.5 6.400 0.247 195.0 9.500 4.084 17.5 6.400 0.247 12.5 6.300 0.174 242.5 9.061 4.8 lb/yr At 4.5 hr/yr Potential Emissions => 9,250 lb/yr At 8,760 hrs/yr 4.6 tpy At 8,760 hrs/yr

What is the potential to emit (PTE)?

SPEED LIMIT

40

SPEED LIMIT

80

SPEED LIMIT

35

SPEED LIMIT

40

EXIT

How fast did you drive here?

Distance D (mi) Speed R (mi/hr) Time T (hr) 17.5 40.0 0.4 195.0 80.0 2.4 17.5 40.0 0.4 12.5 35.0 0.4 242.5 66.1 3.7

What is the potential to emit (PTE)?

Distance (mi) Emission Factor (g/mi) CO Emissions (lbs) 17.5 6.900 0.266 195.0 16.000 6.878 17.5 6.900 0.266 12.5 6.400 0.176 242.5 15.138 7.6 lb/yr At 3.7 hr/yr Potential Emissions => 18,112 lb/yr At 8,760 hrs/yr 9.1 tpy At 8,760 hrs/yr

Evan Klein, Road and Track http://www.roadandtrack.com/car‐culture/a25775/almost‐infamous‐2015‐lamborghini‐huracan/

SPEED LIMIT

180

SPEED LIMIT

180

SPEED LIMIT

180

SPEED LIMIT

180

EXIT

How fast did you drive here?

Distance D (mi) Speed R (mi/hr) Time T (hr) 17.5 180.0 0.1 195.0 180.0 1.1 17.5 180.0 0.1 12.5 180.0 0.1 242.5 180.0 1.3

What is the potential to emit (PTE)?

Distance (mi) Emission Factor (g/mi) CO Emissions (lbs) 17.5 60.00 2.315 195.0 60.00 25.794 17.5 60.00 2.315 12.5 60.00 1.653 242.5 60.00 32.1 lb/yr At 1.3 hr/yr Potential Emissions => 208,576 lb/yr At 8,760 hrs/yr 104.3 tpy At 8,760 hrs/yr

General Provisions PTE Definition

Per 3745‐15‐05(A)

Potential to emit or potential emissions shall mean the amount of emissions of an air contaminant which would be emitted from a source during a 24-hour calendar day or calendar year basis, whichever is applicable, if that source were operated without the use of air pollution control equipment unless such control equipment is, aside from air pollution control requirements, necessary for the facility to produce its normal product or is integral to the normal operation of the source. Potential emissions shall be based on maximum rated capacity.

Permit to Install PTE Definition

Per 3745‐31‐01(VVVV)

Potential to emit means the maximum capacity of an emissions unit or stationary source to emit an air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the emissions unit or stationary source to emit an air pollutant, which includes any federally regulated air pollutant, including air pollution control equipment and restrictions on hours

• f operation or on the type or amount of material combusted, stored or processed,

shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable or legally and practicably enforceable by the state. Secondary emissions do not count in determining the potential to emit of a stationary source.

Title V Permit PTE Definition

Per 3745‐77‐01(CC)

Potential to emit means the maximum capacity of a stationary source to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of

• peration or on the type or amount of material combusted, stored, or processed,

shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable or legally and practicably enforceable by the state. Secondary emissions do not count in determining the potential to emit of a stationary source.

How fast did you drive here?

Distance D (mi) Speed R (mi/hr) Time T (hr) 17.5 180.0 0.1 195.0 180.0 1.1 17.5 180.0 0.1 12.5 180.0 0.1 242.5 180.0 1.3 Distance D (mi) Speed R (mi/hr) Time T (hr) 17.5 40.0 0.4 195.0 80.0 2.4 17.5 40.0 0.4 12.5 35.0 0.4 242.5 66.1 3.7 Distance D (mi) Speed R (mi/hr) Time T (hr) 17.5 35.0 0.5 195.0 65.0 3.0 17.5 35.0 0.5 12.5 25.0 0.5 242.5 53.9 4.5 Distance (mi) Emission Factor (g/mi) CO Emissions (lbs) 17.5 6.400 0.247 195.0 9.500 4.084 17.5 6.400 0.247 12.5 6.300 0.174 242.5 9.061 4.8 lb/yr At 4.5 hr/yr Potential Emissions => 9,250 lb/yr At 8,760 hrs/yr 4.6 tpy At 8,760 hrs/yr Distance (mi) Emission Factor (g/mi) CO Emissions (lbs) 17.5 6.900 0.266 195.0 16.000 6.878 17.5 6.900 0.266 12.5 6.400 0.176 242.5 15.138 7.6 lb/yr At 4.5 hr/yr Potential Emissions => 18,112 lb/yr At 8,760 hrs/yr 9.1 tpy At 8,760 hrs/yr Distance (mi) Emission Factor (g/mi) CO Emissions (lbs) 17.5 60.00 2.315 195.0 60.00 25.794 17.5 60.00 2.315 12.5 60.00 1.653 242.5 60.00 32.1 lb/yr At 4 Potential Emissions => 208,576 lb/yr At 8 104.3 tpy At 8

What is the potential to emit (PTE)?

Potential to Emit

• Maximum capacity to emit
• May be limited by:

 Physical and operational limits  Air pollution control equipment  Restricted hours of operation  Type or amount of material combusted, stored,

• r processed
• Limitations must be enforceable

Enforceable Limitations - How?

• Two qualifiers

 Operating and/or emission limits in an air

permit undergoing public notice

 Appropriate testing, monitoring &

recordkeeping to ensure compliance can be demonstrated

How to Calculate PTE

• 1. Conduct a facility‐wide inventory of emission

sources

• 2. Identify any legally enforceable

limitations

• 3. Choose emission calculation

methodologies

• 4. Gather necessary process data
• 5. Calculate PTE for each emission source
• 6. Calculate total site‐wide PTE for the facility

Importance of Source Classification

• First question in determining

applicability to air regulations and/or permitting requirements: “What is my source classification?”

• Key concepts to understand to answer:

 Meaning of term “source”  Distinguish between source classification

based on

♦ date of construction/modification ♦ emissions

Multiple Uses of Term “Source”

• Different criteria for different regulatory

programs

• Need to understand the underlying

regulation or permitting program being considered

 In context of air permitting programs, “source”

typically refers to the facility

 In context of particular air regulations (e.g., NSPS,

NESHAP), “source” typically refers to specific subset of equipment at a facility

Source Classification with Respect to Construction Date

• Source classification tiers for facilities,

processes, or individual emission units:

 New Source  Existing Source, Not Grandfathered  Existing Source, Grandfathered

• Each regulatory program will have its own

criteria for defining these classifications

• Key date is generally when regulation is

proposed

Source Classification with Respect to Emissions

• Three general source classification tiers for

facilities as a whole:

 Major  Synthetic Minor  True Minor

• Each regulatory program can have its own

thresholds

• “Potential to Emit” compared to thresholds

“True Minor” Source

• Source’s Potential To Emit is less than the

major source threshold, even without any federally enforceable limits on emissions and/or operations

 Sometimes referred to as a “natural minor”

“Synthetic Minor” Source

• Actual emissions are less than major

source levels but Potential to Emit is greater than major source levels

• A synthetic minor source is one that has

chosen to reduce its PTE to minor source levels from major source levels by accepting enforceable limits on emissions and/or operations

Major Source

• Source’s PTE exceeds major source

thresholds

• Source can not or chooses not to propose

limits on emissions and/or operations to reduce its PTE

Estimating Emissions from Storage Tanks

Estimating Emissions from Storage Tanks

• EPA publishes emissions factors and

equations for estimating storage tank emissions in AP‐42 Chapter 7.1.

 There are changes pending for this document.

• EPA developed a software tool to apply

these emission factors, the last version of which is TANKS 4.09D.

 There are multiple known problems with this

software, and it is no longer supported by EPA.

TANKS 4.09D Not Supported

TANKS 4.09D Risk

• EPA has given fair notice.
• EPA Enforcement has held:

 Reliance on TANKS 4.09D is not an effective

defense,

 Even if the State Agency approved its use.

• EPA says to use a tool that applies the AP‐

42 equations correctly.

TANKS 4.09D Programming Errors

• Monthly emissions estimates are

incorrect.

• Modeling of insulated tanks.
• Modeling of stock temperature warmer

than ambient in an uninsulated tank.

• Determination of true vapor pressure for

temperatures greater than 100 F.

Monthly Emissions Issues

• TANKS 4.09D uses the annual average liquid bulk

temperature when performing monthly calculations.

• “will NOT adequately account for monthly

variations.”

• “should NOT be used for determining max

monthly TVP”

• “users should not rely on the TANKS model for

accurately determining monthly emissions in general”

• Rather, use AP‐42 Chapter 7.1.

Modeling of Insulated Tanks

• For the “heated tank” option, TANKS 4.09D

guidance says assume liquid surface temp is constant and equal to liquid bulk temp, but this assumption would be reasonable only for fully (roof and shell) insulated tanks.

• Requires the breather vent settings set equal

to zero, thus not accounting for actual vent settings.

• Thus the “heated tank” option is really only

for fully insulated tanks with open vents.

Hot Stock, Not Fully Insulated

• TANKS 4.09D does not accommodate user entry
• f elevated liquid bulk temperature for floating‐

roof tanks.

• For fixed‐roof tanks, TANKS 4.09D requires

designating the tank as heated, and then imposes assumptions applicable only to fully insulated tanks (as noted above).

• Bottom line – TANKS 4.09D does not properly

accommodate or model uninsulated tanks that store liquid at elevated temperatures.

TVP Above 100oF Using Option 1

• TANKS has multiple options for determining TVP.
• Option 1 has TVP values at 10oF increments from

40oF to 100oF.

 TVP values at temperatures in this range are interpolated

from the given values.

 However, for temperatures above this range, the TVP value

at 100oF is used, regardless of the actual temperature.

• Users tend to use the TANKS default No. 6 Oil as a

surrogate for heavy refined streams.

 But these streams are often stored at greater than 100oF,  And TANKS uses Option 1 to determine TVP for No. 6 Oil.

Fixed-Roof Tank Working Loss

• TANKS uses the following out‐of‐date equation for

fixed‐roof tank working loss:

• The 0.0010 constant has a hard‐wired value for

temperature of 63oF.

• The more general, current form of the equation has

vapor density as a variable, and temperature as a variable in the determination of vapor density.

• Thus TANKS 4.09D has a built‐in bias for fixed‐roof

tank working loss at any temperature other than 63oF.

L M P Q K K

W V

VA

N P

0 0010

.

EPA’s AP-42

Compilation of Air Pollutant Emission Factors

• Volume I: Stationary Point & Area Sources.
• Section 7.1 – Organic Liquid Storage Tanks.
• Fifth Edition, Supplement D – September ’97.

 Routine Standing & Working Losses

for Floating- and Fixed-Roof Tanks.

 2006 Rev added Floating Roof Landing Losses.

• July 25, 2018–Revisions Proposed.

 Including Tank Cleaning Losses.

(methodology was published by API Nov. 2007)

What Other Changes To AP-42

Are Proposed?

• Adjustments to temperature equations.

 Would impact estimated emissions for all tanks.

• Guidance for tanks storing hot stocks.

 Including fully or partially insulated tanks.

• Lots of editing for clarity and correctness.

 Including retiring certain approximations where

more accurate equations are provided.

• And more . . .

Detailed Review of Storage Tanks and Path Forward

Proposed Equations

Coefficients to 1 significant figure Consistent 0.5 default H/D ratio

(current 0.45 to 2.0)

Differentiate by tank type Add clarifying language (KE)

Temperature

Comparison – Uninsulated Fixed-Roof Tank Liquid Surface Temperature

Current Equation

Proposed Equations Hs/D as a Variable: Hs/D equal to 0.5:

Comparison – Uninsulated Fixed-Roof Tank Liquid Surface Temperature

Example – Fixed vs Floating Roof

Liquid Surface Temperature

Draft new equations for:

 Fixed-roof tank (uninsulated):

TLA = 0.4 T

AA + 0.6 TB + 0.005 α I

 Internal floating-roof tank:

TLA = 0.3 T

AA + 0.7 TB + 0.004 α I

 External floating-roof tank (steel pontoon deck):

TLA = 0.7 T

AA + 0.3 TB + 0.008 αRI

 External floating-roof tank (double deck):

TLA = 0.3 T

AA + 0.7 TB + 0.009 αRI

74

Paint Solar Absorptance

“Good” “Poor”

Example – Fixed-Roof Tank

60’ 48’

Diesel

Port Arthur, Texas Throughput (bbl/yr) 600,000 Annual Average Temperature (°F) 68.44 Average Daily Insolation (Btu/ft2∙day) 1,443.85

HS/D Reflective Condition Annual Emissions (lbs) % Difference Current Equations:

default good 879 n/a

Example – Fixed-Roof Tank

when TB ~ 69° F (ambient)

HS/D Reflective Condition Annual Emissions (lbs) % Difference Current Equations:

default good 879 n/a

Proposed Equations:

variable new 851 –3.1% default new 847 –3.6% default average 890 +1.2% variable average 888 +1.1%

Example – Fixed-Roof Tank

when TB = 80° F

HS/D Reflective Condition Annual Emissions (lbs) % Difference Current Equations:

default good 1,060 n/a

HS/D Reflective Condition Annual Emissions (lbs) % Difference Current Equations:

default good 1,060 n/a

Proposed Equations:

variable new 1,039 –1.9% default new 1,029 –2.8% default average 1,073 +1.3% variable average 1,077 +1.6%

Example – Fixed-Roof Tank

Impact of Proposed Revisions

“New” Paint + Proposed Equations “Average” Paint + Proposed Equations

> <

“Good” Paint + Current Equations “Good” Paint + Current Equations EMISSIONS OF… EMISSIONS OF…

150’ 48’

Crude Oil

Example – External Floating-Roof Tank

Port Arthur, Texas Reid Vapor Pressure (psi) 7 Throughput (bbl/yr) 3,000,000 Annual Average Temperature (°F) 68.44 Average Daily Insolation (Btu/ft2∙day) 1,443.85 Average Wind Speed (mph) 9.64

Steel pontoon‐type deck with mechanical‐shoe seal with rim‐mounted secondary seal type

Example – External Floating-Roof Tank

when TB ~ 70° F (ambient)

HS/D Reflective Condition Annual Emissions (lbs) % Difference Current Equations:

default good 3,019 n/a

HS/D Reflective Condition Annual Emissions (lbs) % Difference Current Equations:

default good 3,019 n/a

Proposed Equations:

variable new 3,047 +1.0% default new 3,045 +0.9% default average 3,103 +2.8% variable average 3,107 +2.9%

Example – External Floating-Roof Tank

when TB = 80° F

HS/D Reflective Condition Annual Emissions (lbs) % Difference Current Equations:

default good 3,359 n/a

1 If the liquid bulk temperature is known (from measurements or process knowledge),

then the equation for calculating liquid surface temperature is not dependent on the H/D ratio of the tank for an external floating‐roof tank.

HS/D Reflective Condition Annual Emissions (lbs) % Difference Current Equations:

default good 3,359 n/a

Proposed Equations:1

n/a new 3,195 –4.9% n/a average 3,245 –3.4%

Example – External Floating-Roof Tank

Impact of Proposed Revisions

Assumed Temperature Basis Estimated Emissions using Proposed Equations are… Ambient slightly higher compared to estimated emissions using Current Equations. Elevated slightly lower compared to estimated emissions using Current Equations.

Example – External Floating-Roof Tank

Impact of Proposed Revisions

In both cases, the reason is the greater rate of heat transfer through the EFR than through an enclosed headspace. Air Emissions

Driven by liquid surface temperature.

A fixed roof shades the floating roof. EFRTs have direct heat transfer through the floating roof.

Guidance for Hot Stocks

• Liquid bulk temperature may be elevated

by:

 Stock being heated in the tank,  Stock being heated external to the tank and

circulated through the tank, or

 Tank receiving hot stock from a process unit.

• Additional issues are whether the tank is:

 Insulated, and  Maintained at a constant temperature.

Liquid Surface Temperature

Hot Stocks – Not Insulated

• AP‐42 Eq.1‐26 for TLA:

TLA = 0.44 TAA + 0.56 TB + 0.0079 α I

 TLA is a weighted average between ambient air and

liquid bulk temperatures;

 Use measured TB if the stock is known to be

warmer than ambient (not Eq.1-28 to estimate TB from ambient).

 Should also be applied to TLA for floating-roof tanks.

NOTE: Revisions to coefficients proposed.

86

Heated FRTs – Not Insulated

Breathing Losses Still Occur

• Breathing loss from AP‐42 7.1 Eq.1‐4:

LS = 365 KE [HVO (pi/4) D 2] KS WV

• Vapor space expansion factor KE from

Eq.1‐7:

KE = (ΔTV / TLA) + (ΔPV – ΔPB) / (PA – PVA)

• Breathing loss is estimated from KE:

 TB relatively constant over the course of a day,  TLA calculated from TAA and measured TB,  ΔTV from ΔTA (vapor space Δ drives breathing).

87

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Liquid bulk temperature, TB.

88

Hot Stock - but

Tank Not Insulated

Ambient air temperature, TA Vapor space has thermal exchange with ambient air; thus diurnal temperature cycle occurs even though TB is relatively constant (whether heated or not). Liquid surface temperature, TL

Heated FRTs – Only Shell Insulated

Breathing Losses Still Occur

• Insulating the shell helps keep stock

hot, but:

 Vapor space still has thermal exchange with

ambient air through the tank roof.

• May be most appropriate to model as

not insulated, if only shell is insulated.

 NOTE: Separate equations proposed for

“partially insulated” tanks, with a fall back of modeling as not insulated.

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Heated FRTs – Only Shell Insulated

Breathing Losses Still Occur

Thermal exchange with ambient; ΔTV will still occur. Insulated shell; helps maintain elevated TB.

Partially Insulated Tank:

ΔTV = 0.6 ΔTA + 0.02 αR I

Heated FRTs – Fully Insulated

Constant Temperature

If the liquid bulk temperature is nearly constant, then so is the vapor space temperature, and ΔTV = 0.

Liquid bulk temperature, TB

Liquid surface temperature, TL No thermal exchange with ambient, and: TB = TL = TV

Vapor space temperature, TV

Example – Heated Tanks (Hot Stock)

60’ 48’

Diesel

Port Arthur, Texas Estimate Emissions for February Capacity (gallons) 1,000,000 Tank Type Fixed Roof

Example – Heated Tanks (Hot Stock)

Cases Bulk Temp (°F) Surface Temp (°F) Throughput (gallons) Insulated Y/N Case 1 54.4 55.9 1,000,000 No Case 2 100 81.4 1,000,000 No Case 3 100 100 1,000,000 Yes Case 4 100 81.4 500,000 No Case 5 100 100 500,000 Yes

Scenarios

Fully Insulated: Cases 3 and 5 Uninsulated: Cases 1, 2, and 4

Example – Heated Tanks (Hot Stock)

Cases Bulk Temp (°F) Surface Temp (°F) Throughput (gallons) Insulated Y/N Working Emissions (lbs) Standing Emissions (lbs) Total Emissions (lbs) Case 1 54.4 55.9 1,000,000 No 18 9 27 Case 2 100 81.4 1,000,000 No 38 18 57 Case 3 100 100 1,000,000 Yes 64 ‐‐ 64 Case 4 100 81.4 500,000 No 19 18 37 Case 5 100 100 500,000 Yes 32 ‐‐ 32

Results

Fully Insulated: Cases 3 and 5 Uninsulated: Cases 1, 2, and 4

Hotter stock has higher emissions.

Cases Bulk Temp (°F) Surface Temp (°F) Throughput (gallons) Insulated Y/N Working Emissions (lbs) Standing Emissions (lbs) Total Emissions (lbs) Case 1 54.4 55.9 1,000,000 No 18 9 27 Case 2 100 81.4 1,000,000 No 38 18 57 Case 3 100 100 1,000,000 Yes 64 ‐‐ 64 Case 4 100 81.4 500,000 No 19 18 37 Case 5 100 100 500,000 Yes 32 ‐‐ 32

Example – Heated Tanks (Hot Stock)

Results

Fully Insulated: Cases 3 and 5 Uninsulated: Cases 1, 2, and 4

Insulated tank has higher emissions at 12 TOs/yr.

Cases Bulk Temp (°F) Surface Temp (°F) Throughput (gallons) Insulated Y/N Working Emissions (lbs) Standing Emissions (lbs) Total Emissions (lbs) Case 1 54.4 55.9 1,000,000 No 18 9 27 Case 2 100 81.4 1,000,000 No 38 18 57 Case 3 100 100 1,000,000 Yes 64 ‐‐ 64 Case 4 100 81.4 500,000 No 19 18 37 Case 5 100 100 500,000 Yes 32 ‐‐ 32

Example – Heated Tanks (Hot Stock)

Results

Fully Insulated: Cases 3 and 5 Uninsulated: Cases 1, 2, and 4

Uninsulated tank has higher emissions at 5 Turnovers/yr. Emissions from fully insulated tanks are throughput dependent.

Permitting Implications

Do you have accurate storage temperatures for warm products? Are your material properties and vapor pressures representative of actual material stored? Have you defined your monthly/annual throughput properly? Are you accounting properly for cleaning/landing losses? Due diligence  Reconciliation

Questions?

Bill Bruscino Trinity –Columbus (614) 433-0733 bbruscino@ trinityconsultants.com Andrew Dunagan Trinity - Columbus

(614) 433-0733

adunagan@ trinityconsultants.com Mike Hopkins Assistant Chief, Permitting Ohio EP A DAPC (614) 644-3611 Mike.Hopkins@ epa.ohio.gov