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Bulk Gasoline Terminals
December 1998

                    Technical Disclaimer

References to abatement equipment technologies are not intended to represent minimum or
maximum levels of Best Available Control Technology (BACT).  Determinations of BACT are
made on a case-by-case basis as part of the New Source Review of permit applications.  BACT
determinations are always subject to adjustment in consideration of specific process
requirements and recent developments in abatement technology.  Additionally, specific health
effects concerns may indicate stricter abatement than required by the BACT determination.

The represented calculation methods are intended as an aid in the completion of an acceptable
submittal; alternate calculation methods may be equally acceptable if they are based on and
adequately demonstrate sound engineering assumptions or data.

The enclosed regulations are applicable as of the publication date of this package, but are
subject to revision during the application preparation and review period.  It is the responsibility
of applicants to remain abreast of regulation developments which may affect their industries.


Loading Racks

     1.    Emissions from loading racks handling compounds with a true vapor pressure of 0.5
           psia or greater should be routed to a control device with a control efficiency of 98
           percent control or greater.  Compounds with vapor pressures less than 0.5 psia may
           require control depending on the off-site impacts.  BACT guidelines for controlling
           gasoline terminal loading emissions can be met by utilizing an enclosed flare/vapor
           combustor or elevated flare with minimum 98 percent VOC destruction efficiency, or a
           regenerative Carbon Adsorption System (CAS) with maximum 0.09 lb VOC/1000
           gallons of gasoline loaded.  The flare destruction efficiency applies to the collected
           uncontrolled emissions which are routed to the flare, and the CAS factor applies to the
           CAS vent.  Chapter 115 and MACT requirements may be more stringent than BACT. 
           For additional details, see Air Permit Technical Guidance for Chemical Sources: Flares
           and Vapor Oxidizers and Technical Guidance Package for Chemical Sources, Carbon
           Adsorption Systems.

       Lean Oil Adsorption is not considered BACT for gasoline terminals because it tends to
       be unreliable and inefficient.

     2.    Uncollected loading emissions, or loading losses, occur during truck loading
           operations and are usually the major source of any off-site impact problems.  These are
           leaks from tank truck vapor connections, the vapor collection header, seams in the
           tank truck, etc.  BACT requires vapor-tightness or leak testing the tank truck on an
           annual basis as specified in NSPS Subpart XX.  Tank truck owners should provide
           certification of the tank truck testing.  With annual testing it is assumed that there will
           be a 1.3 percent loss at the truck, with the remaining 98.7 percent being routed to the
           control device.  This is in accordance with the latest TNRCC guidance memorandum
           on Collection Efficiency for Gasoline Terminal Racks.  With vacuum loading, the
           vapor recovery lines are under vacuum.  Air may leak into the line but VOCs will not
           leak out, so the collection efficiency is considered to be 100 percent, and there are no
           uncollected loading losses.

  B. Fugitive Emission Program

     The AVO fugitive monitoring program is considered BACT for a bulk gasoline terminal
     LDAR program.

  C. Storage Tanks

     BACT for gasoline product storage tanks containing products having a vapor pressure at
     maximum storage temperature of 0.5 psia or greater and having a storage capacity of
     25,000 gallons or more is considered to be:

     1.    Fixed roof tanks with their vents routed to an abatement device such as a flare.

     2.    Internal floating roof tanks with liquid-mounted primary seal, mechanical shoe primary
           seal, or vapor-mounted primary seal and rim-mounted secondary seal.

     3.    External floating roof tanks with liquid-mounted or mechanical shoe primary seal and
           rim-mounted secondary seal.

     Floating roof seals should be inspected annually.

     New tanks should be painted white.

     Fixed roof tanks may be used for the storage of products having a capacity of less than
     25,000 gallons or for products having a true vapor pressure of less than 0.5 psia at
     maximum storage temperature.