Bulk Liquid Storage Terminals
April 1995

TNRCC Rule 116.111(3) in Regulation VI requires that Best Available Control Technology
(BACT) be applied to all facilities that must obtain a permit.  Applicants are required to propose
BACT for every affected source at the facility.  The BACT guidelines shown below are principally
a minimum level of control that would be required for that particular source and/or compound.

A.   Storage Tanks

Control of emissions from storage tanks is based on the vapor pressure of the compound stored. 
Compounds with a vapor pressure  of 0.5 psia and above at maximum storage temperature are
required to be stored in a floating roof tank (internal or external) with an approved seal system or
a fixed roof tank vented to a control device.  Compounds that have a vapor pressure below 0.5
psia at maximum storage temperature may be stored in a fixed roof tank as long as there are no
adverse health impacts (as determined by the Toxicology and Risk Assessment Section of the
TNRCC) associated with the emissions.  Additional controls and/or operational restrictions may
be required to provide for acceptable impacts.  Relief valves installed on pressure vessels for high
vapor pressure compounds should be routed to a flare or equipped with a rupture disk and
employ a pressure gauge to monitor disk integrity.

Please refer to technical guidance document on storage tanks for detailed BACT information.

B.   Loading Operations

Control of emissions from truck and railcar loading operations is based on the vapor pressure of
the compound loaded.  Loading controls are required for compounds with a vapor pressure of 0.5
psia or greater at maximum loading temperature.  Compounds that have a vapor pressure below
0.5 psia at maximum loading temperature may be uncontrolled as long as there are no adverse
impacts associated with the emissions.  Additional controls and/or operational restrictions may be
required to provide for acceptable impacts.

Ship and barge loading operations are not subject to BACT review.  However, emissions from
ship and barge loading will be reviewed for acceptable impacts.  Controls and/or operational
restrictions may be required on ship and/or barge loading operations to provide for acceptable
impacts.  

Please refer to the technical guidance document on loading operations for detailed BACT
information.       
          
C.   Fugitive Emissions

Several Leak Detection and Repair (LDAR) programs are  available to satisfy the BACT
requirement for terminals.  These include 28M, 28RCT, 28VHP, and 28MID.  Terminals will be
required to implement one of the aforementioned programs depending on the amount of annual
emissions and the associated emissions' impact. 

Please refer to the technical guidance document on fugitives for detailed information on the
LDAR programs.