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Technical Support Document, Permit Number: 12300070-101 Page 1 of 9
Technical Support Document for
Draft Air Emission Permit No. 12300070-101 This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit. 1. General information
1.1 Applicant and stationary source location Table 1. Applicant and source address
Applicant/Address Stationary source/Address (SIC Code: 4613 - Refined Petroleum Pipelines)
Teri Holmes 1 Williams Center MD 27 Tulsa, Oklahoma 74172
Magellan Pipeline Co LP - Saint Paul Terminal 2451 W County Road C Roseville, MN 55113
Contact: Teri Holmes Phone: 918-574-7131
1.2 Facility description
Magellan Pipeline Company, L.P., owns and operates a liquid petroleum bulk storage terminal and interstate pipeline facility in Roseville, Minnesota. The facility consists of storage tanks, electric pumps stations, two tank truck loading racks with vapor collection systems and vapor combustion units (VCUs), and insignificant emission units. The terminal receives and transports petroleum and biofuel products to other terminals through an interstate pipeline distribution network. Volatile organic compounds (VOCs) are the primary pollutant emitted from the facility, including volatile hazardous air pollutants (HAPs). Most VOCs and HAPs emissions are the two truck loading racks’ emissions that are collected but uncombusted by the two VCUs, with a smaller percentage of emissions going uncollected from the loading racks. Additional emissions are from storage tank standing and working losses; tank floating roof landing events; and fugitive emissions from valves, pumps, and flanges.
1.3 Description of the activities allowed by this permit action This permit action is Part 70 Reissuance.
1.4 Description of notifications and applications included in this action
Table 2. Notifications and applications included in this action
Date received Application/Notification type and description 07/06/2010 Part 70 Reissuance (IND20100001)
11/3/2008 Part 70 Permit Reopening – an initial notification for 40 CFR pt. 63, subp. BBBBBB (IND20080001)
Technical Support Document, Permit Number: 12300070-101 Page 2 of 9
1.5 Facility emissions
Table 3. Total facility potential to emit summary
PM tpy
PM10 tpy
PM2.5 tpy
SO2 tpy
NOx tpy
CO tpy
CO2e tpy
VOC tpy
Single HAP tpy
All HAPs tpy
Total facility limited potential emissions 0.012 0.009 0.003 0.001 28.2 70.3 190 306 4.88 15.9 Total facility actual emissions (2015) 0.00 0.00 0.00 0.00 10.1 25.4 * 101 *
*Not reported in Minnesota emission inventory. Table 4. Facility classification
Classification Major Synthetic minor/area Minor/Area New Source Review X Part 70 X Part 63 X
1.6 Changes to permit
The permit does not authorize any specific modifications, however, the MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action: · The permit has been updated to reflect current MPCA templates and standard citation formatting. · The TK/EU, CE, SV, and GP identifiers have been updated to EQUI, TREA, STRU, and COMG, respectively,
to reflect MPCA’s current permitting practice. · Some requirements have been reordered to help with clarity (i.e., similar requirements are grouped). · Data on the site’s Aboveground Storage Tanks (ASTs), VCUs, stacks, and buildings has been updated
based on the 2015 permit reissuance application, 2017 site visit, and 2017 supplemental information. · Performance testing frequency for Tank Truck Bottom Load MPL with Vapor Combustor Control has
been changed from previous 60 month frequency to 36 month frequency. · New Source Performance Standard (NSPS) for Storage Vessels for Petroleum Liquids (40 CFR pt. 60,
subp. Ka) requirements that had applied to EQUI 38, 40, 69, 77, and 80 (TK020, TK027, TK019, TK029, and TK032, respectively) in previous GP001 have been broken out to each individual tank for easier compliance.
· NESHAP for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities (40 CFR pt. 63, subp. BBBBBB) requirements have been incorporated into this permit for COMG 3, which includes the loading racks (EQUI 19 and 20), VCUs (TREA 6 and 7), and all ASTs containing gasoline.
· TREA 6 and 7 (formerly CE001 and CE002) were changed from flares to other control equipment to better characterize the control equipment.
· The ASTs potential to emit was updated with new numbers from TankESP (done using Reid Vapor Pressure (RVP) 13 gasoline since the facility noticed an upward trend in annualized RVP of the gasoline). See section 3.1.2 for more information on TankESP. To accurately permit the facility for emissions, AST capacities and the RVP were modified in TankESP and the facility submitted revised emissions data.
· Floating roof landing emissions were incorporated into the AST potential. · Railcar, butane, and biodiesel off-loading stations were added as insignificant activities under Minn. R.
7007.1300, subps. 4 and 3(I). Railcar and butane off-loading were started prior to the first pt. 70 permit reissuance but were not accounted for. Biodiesel off-loading was installed in 2005, considered to be insignificant at the time, and added as an insignificant activity.
Technical Support Document, Permit Number: 12300070-101 Page 3 of 9
· Tank 951 was removed from the insignificant activities because it is permanently decommissioned. · Tank 904 was removed from the insignificant activities because its potential to emit VOCs is greater than
2,000 pounds per year, so it is considered an emission unit. · Portable water treatment equipment, including, but not limited to, air stripper, carbon filter units, and
chemical/biological units, was removed from the insignificant activities list because it is no longer on site.
· SIC code 5171 (Petroleum Bulk Stations and Terminals) was removed from permit. Magellan Pipeline Company, L.P., determined that because they do not own the product, they are not a 5171 facility.
2. Regulatory and/or statutory basis
2.1 New source review (NSR)
The facility is an existing major source under New Source Review regulations (40 CFR § 52.21), because it is one of the 28 listed source categories for NSR with potential VOCs exceeding 100 tpy. Even if the facility were not a listed source category it would be a major source with potential VOCs exceeding 250 tpy. No changes are authorized by this permit.
2.2 Part 70 permit program The facility is a major source under the Part 70 permit program.
2.3 New source performance standards (NSPS) The facility is subject to Standards of Performance for Bulk Gasoline Terminals (40 CFR pt. 60, subp. XX). The VCUs are used to meet 40 CFR pt. 60, subp. XX, and were previously described as flares. However, the VCUs operate different than flares, so they are not subject to the flare requirements in 40 CFR pt. 60, subp. A (General Requirements). This is detailed in Attachment 4, a U.S. Environmental Protection Agency (EPA) Applicability Determination Letter. Flare-specific requirements were removed from the VCUs and their emission unit types were changed from flares to other control equipment. While the EPA Applicability Determination Letter states that VCUs operate more similarly to thermal oxidizers than flares, due to their monitoring parameters VCUs are a unique type of control that is best categorized as other control equipment. Five ASTs at the facility (EQUI 38, 40, 69, 77, and 80) are also subject to Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced after May 18, 1978, and prior to July 23, 1984 (40 CFR pt. 60, subp. Ka). See Table 6 for the rationale of applying 40 CFR pt. 60, supb. XX to the facility and 40 CFR pt. 60, subp. Ka to the five ASTs.
2.4 National emission standards for hazardous air pollutants (NESHAP) The facility is an existing area source of HAPs and is subject to 40 CFR pt. 63, subp. BBBBBB (NESHAP for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities) because it is a pipeline distribution bulk terminal as defined in 40 CFR § 63.11081(a)(1). All 22 gasoline-storing ASTs at the facility, the 2 loading racks (EQUI 19 and 20), and the 2 VCUs (TREA 6 and 7) are subject to the requirements relating to this NESHAP, so the requirements are listed under COMG 3.
2.5 Compliance assurance monitoring (CAM) Table 5 below lists the sources subject to CAM, the control equipment used, whether the source is a large or other pollutant specific emission unit (PSEU), and the pollutants triggering CAM.
Technical Support Document, Permit Number: 12300070-101 Page 4 of 9
Table 5. CAM summary
Unit Control CAM applicability Pollutant EQUI 19 TREA 6 VCU Other VOC EQUI 20 TREA 7 VCU Other VOC
For other PSEUs (not large), records must be made at a minimum of once per 24 hours. See Attachment 3 to this document for the CAM plan submitted by the applicant for their first permit reissuance in 2002.
2.6 Minnesota State Rules The facility is not subject to Minnesota Standards of Performance. Table 6. Regulatory overview of facility
Subject item* Applicable regulations Rationale COMG 3 - Aboveground Storage Tanks storing gasoline, loading racks transferring gasoline, and VCUs controlling gasoline off-gassing
40 CFR pt. 63, subp. BBBBBB NESHAP for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities. This facility distributes liquid petroleum products through a distribution bulk terminal.
· The facility is an area source of HAPs. · The facility is defined as a bulk gasoline terminal that is
not subject to the control requirements of 40 CFR pt. 63, subp. R or subp. CC.
· The facility has a gasoline throughput of >250,000 gal/day.
· 22 of the tanks are >75 ft3: o 21 have internal floating roofs. o One is a surge tank.
EQUI 19 and EQUI 20 - Loading-Unloading Equipment
40 CFR pt. 60, subp. XX
NSPS for Bulk Gasoline Terminals. This facility is a bulk gasoline terminal which delivers liquid product into gasoline tank trucks via loading racks. · The facility is defined as a bulk gasoline terminal. · The facility has a gasoline throughput of > 75,700
liters/day (19,998 gal/day). · The construction or refurbishment of the VCUs did not
commence prior to December 17, 1980. EQUI 38, EQUI 40, EQUI 69, EQUI 77, EQUI 80 - Aboveground Storage Tanks
40 CFR pt. 60, subp. Ka NSPS for Petroleum Liquids for which construction, reconstruction, or modification commenced after May 18, 1978, and prior to July 23, 1984. · The ASTs each have a storage capacity >40,000 gallons
that is used to store petroleum liquids. · The ASTs were modified after May 18, 1978, and prior to
July 23, 1984 (1981 when floating roofs were installed). · The ASTs had a physical change between May 18, 1978,
and July 23, 1984, that resulted in an increase in the emission rate of VOCs to the atmosphere (the subsequent storage of petroleum liquids with a higher true vapor pressure than originally stored).
Technical Support Document, Permit Number: 12300070-101 Page 5 of 9
Subject item* Applicable regulations Rationale TREA 6 and TREA 7 - 099-Other
40 CFR pt. 64 CAM for two ‘other’ PSEUs. · The facility is required to have a part 70 permit. · The facility is a major source of VOCs. · The PSEUs use control devices to achieve compliance with
the TOC emission limit. · The PSEUs have potential pre-control device emissions of
VOCs that are greater than 100% of the major source threshold for a NSR listed source category (100 tpy).
· The PSEUs have potential post-control device emissions of VOCs that are less than 100% of the major source threshold for a NSR listed source category (100 tpy).
*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).
3. Technical information 3.1 Calculations of potential to emit (PTE)
Attachment 1 to this TSD contains PTE calculations of the Facility, which contain detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. The PTE calculations have been updated since the previous permit issuance. Emission equations, emission rates, and known physical properties are generally based on AP-42 Chapter 5.2, Transportation and Marketing of Petroleum Liquids, and Chapter 7.1, Organic Liquid Storage Tanks. Emission factors are cited within the attached calculation spreadsheets.
3.1.1 Tank Truck Bottom Loadings w/vapor collection and combustion controls
Evaporative emissions during the loading process are the primary source of VOC losses at the facility. 3.1.1.1 PTE calculations for VOC emissions from distillate loading at the loading racks incorporated the
vapor collection efficiency and assumed zero percent combustion efficiency for worst-case scenario emissions.
3.1.1.2 Emissions from ethanol loading are estimated as if it were gasoline, since gasoline is more volatile. PTE calculations for VOC emissions from gasoline and ethanol loading at the loading racks incorporated the vapor collection efficiency and, rather than a combustion efficiency, the enforceable emission limit from the NSPS for Bulk Gasoline Terminals (35 mg VOC per liter of gasoline loaded). This is a valid assumption because the loading rack systems shut down if the continuous monitoring equipment read measurements that exceed the federally enforceable limit.
3.1.2 Storage Tank Emission Calculations and Tank Roof Landing Emission Calculations
The previous PTE from ASTs was calculated using TANKS version 4.0. The PTE from the ASTs was updated using Tank Emissions Software Program (TankESP). TankESP applies the methodology of Chapter 7.1 of AP-42, Organic Liquid Storage Tanks. In TankESP it was assumed that gasoline had a vapor pressure of RVP 13 and that distillate fuels are jet kerosene. In 2007 EPA storage tank PTE calculations were updated to include the air emissions that result when floating roof landings are resting on roof landings. Accordingly, the facility’s PTE calculations were updated to include the emissions from the ASTs that have floating roofs (EQUI 38, 40, 41, 49, 50, 51, 52, 53, 54, 55, 56, 58, 59, 60, 61, 62, 63, 64, 65, 69, 77, 80). Floating roofs generally decrease emissions from ASTs by eliminating the interface between the stored liquid and ambient air (where evaporation occurs). Each AST with a floating roof has internal roof landing “legs” that keep the floating roof off the bottom if the AST is nearly empty. If the liquid level is lowered below the height of the floating roof landings, the roof will rest on the landings, rather than on the liquid, limiting the control efficiency of the floating roof. Emissions that occur during this period are referred to as floating roof landing emissions. The floating roof landing emissions were generated from TankESP, checked against calculations that used
Technical Support Document, Permit Number: 12300070-101 Page 6 of 9
equations from AP-42 Chapter 7.1, and combined with the standing and working loss emissions from the affected ASTs. The calculated PTE with TankESP and floating roof landing emissions is higher; therefore, the AST PTE summary was updated to reflect the increase in potential emissions. PTE calculations for additive tanks that qualify as insignificant activities were also updated.
3.1.3 Fugitive VOC Emission Calculations The VOC emissions were calculated using the Marketing Terminal Average Emission Factors from EPA Protocol for Equipment Leak Emission Estimates, EPA-453R/-95-017, November 1995, Table 2-3.
3.1.4 Hazardous Air Pollutants (HAP) Emission Calculations
HAP emission calculations were based on the HAP (specifically 2,2,4-trimethylpentane, benzene, ethyl benzene, hexane, toluene, and xylenes) content of gasoline vapors in Gasoline Distribution Industry (Stage I) - Background Information for Proposed Standards, November 1994 (EPA-453/R-94-002a). The HAP destruction efficiency of the vapor collection/destruction system is assumed to be equivalent to the VOC destruction efficiency. This is a reasonable assumption according to Control Technologies for HAP, EPA (625/6-91/014, June 1991).
3.2 Monitoring
In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. Table 7 summarizes the monitoring requirements. In evaluating the monitoring included in the permit, the MPCA considered the following:
· the likelihood of the facility violating the applicable requirements; · whether add-on controls are necessary to meet the emission limits; · the variability of emissions over time; · the type of monitoring, process, maintenance, or control equipment data already available for the
emission unit; · the technical and economic feasibility of possible periodic monitoring methods; and · the kind of monitoring found on similar units elsewhere.
Table 7 summarizes the monitoring requirements.
Technical Support Document, Permit Number: 12300070-101 Page 7 of 9
Table 7. Monitoring
Subject Item* Requirement (basis)
What is the monitoring? Why is this monitoring adequate?
EQUI 19, EQUI 20 Total Organic Compounds <= 35 milligrams per liter of gasoline loaded. Gauge pressure in delivery tank <= 4,500 pascals (NSPS, subp. XX)
Monthly leak inspections. Periodic TOC performance testing. Monitoring the gauge pressure to be less than 450 mm of water in the delivery tank on a continuous basis.
Monitoring the gauge pressure, recordkeeping (leak repairs and corrective actions), O&M records, and periodic TOC testing are indicators to have reasonable assurance of compliance.
TREA 6, TREA 7 Emissions shall not be vented to a VCU without its assist air blower on, vapor valve open, and pilot flame lit. (CAM)
Daily monitoring, monthly leak inspections, semi-annual VCU inspections, and annual calibrations. Periodic TOC performance testing.
The NSPS monitoring requirements of 40 CFR pt. 60, subp. XX, in addition to monitoring associated with 40 CFR pt. 63, subp. BBBBBB, and 40 CFR pt. 64 help to ensure compliance with the limits. Periodic TOC testing and recordkeeping (inspections, leak repairs, corrective actions, and O&M) are required to support compliance with NSPS and CAM requirements.
*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).
3.3 Performance Testing Requirements Previous permits required performance testing and set the performance test frequency at 60-month intervals. All tests performed since the last reissuance were in compliance. The results of the most recent performance testing were reviewed to inform this permit action. The testing results were reported in RE: Notice of Compliance for August 21-22, 2012, Performance Test on EU001 (Tank Truck Bottom Load MPL w/Vapor Combustor Control) and EU002 (Tank Truck Bottom Load – Flint Hills Resources (FHR) w/Vapor Combustor Control) Pursuant to Air Emission Permit Number 12300070-004; and Test Plan Approval Letter dated August 8, 2012. Table 8 contains the date of the most recent performance test with available data, TOC limits for each stack, the results from the testing, the percentage of the limit, and the performance test interval assigned (based on the percentage). The Permittee will conduct performance tests in August 2017. Since the data from the tests is not available at the time of notice, it was not used to inform this permit action. Table 8. 2012 Stack Testing Data
Unit Test Date Limit
(mg TOC/L gasoline loaded) Test Result
(mg/L) % of Limit
Performance Test Intervals (months)
EQUI 19 (TREA 6) 22 Aug 2012 35 30.1 86% 36 EQUI 20 (TREA 7) 21 Aug 2012 35 10.9 31% 60
Technical Support Document, Permit Number: 12300070-101 Page 8 of 9
3.4 Insignificant activities Magellan Pipeline Co LP - St Paul Terminal has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. It is our belief that IAs listed in Appendix A to the permit are associated with inconsequential environmental impacts and present little potential for violations of generally applicable requirements; therefore, no additional periodic monitoring will be required. Table 9 documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 1 of this TSD for PTE information for the insignificant activities. Table 9. Insignificant activities
Insignificant activity General applicable emission limit Discussion
Fuel Use: space heaters fueled by kerosene, natural gas, or propane, less than 420,000 Btu/hr
PM <= 0.4 lb/MMBtu Opacity <= 20% with exceptions (Minn. R. 7011.0510)
For this unit, based on the fuels used and EPA published emissions factors, it is highly unlikely that it could violate the applicable requirements. No monitoring warranted. There is one natural gas furnace (203,000 Btu/hr).
Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(G)
PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0715)
These are small, intermittent operations that typically do not have any emissions. It is highly unlikely that they could violate the applicable requirements. No monitoring warranted.
Individual units with potential emissions less than 2000 lb/year of certain pollutants
PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0715)
There are 22 fuel bulk additive storage tanks (2 @ ~500 gal, 1 @ 750 gal, 6 @ ~1,000 gal, 3 @ ~2,000 gal, 1 @ 3,000 gal, 2 @ ~4,000 gal, 4 @ ~6,000 gal, 1 @ 8,000 gal, 1 @ 10,000 gal, 1 @ ~12,000 gal), 2 biofuel storage tanks (128,490 gal each), and biodiesel unloading. Based on the fuels stored and unloaded, it is highly unlikely that the units could violate the applicable requirements. See PTE calculations for justification of VOC < 2,000 lb/yr. No monitoring warranted.
Fugitive dust emissions from unpaved entrance roads and parking lots
Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R. 7011.0150)
The Facility is located in the Metro area and has paved parking lots and a few unpaved private roads. Nearly all surfaces are currently paved. There is minimal vehicle traffic on unpaved roads. No monitoring warranted.
Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source
PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0710/0715)
While painting operations have the potential to emit particulate matter, these particular activities are not associated with production, so they occur infrequently and outdoors. Testing or monitoring is not feasible.
Individual units with potential or actual emissions meeting the criteria in Minn. R. 7007.1300, subp. 4(A)-(D)
Opacity <= 20% (Minn. R. 7011.0105)
There is ethanol, railcar, and butane offloading. Based on fuel type, it is highly unlikely that the units could violate the applicable requirements. See PTE calculations for justification of VOC < 2.28 lb/hr PTE or VOC < 1 ton/yr actual, and HAP < 1 ton/yr actual. No monitoring warranted.
Technical Support Document, Permit Number: 12300070-101 Page 9 of 9
3.5 Permit organization The only item that deviates from MPCA Tempo Guidance for ordering and grouping of requirements is the listing of certain applicable requirements at the group level even though they apply at the individual unit. Specifically: 40 CFR pt. 63, subp. BBBBBB, is listed at COMG 3. In general, requirements that apply to individual pieces of equipment should be tracked at the unit level and should not be listed at a group. The main reason is if there were noncompliance with a requirement by one unit within the group, the computer system would say the whole group was out of compliance. For this case, the gasoline storage and loading equipment (COMG 3) are subject to monitoring, maintenance, and recordkeeping requirements that apply to all gasoline-loading equipment. If monitoring, maintenance, and/or recordkeeping are found to be noncompliant, it is likely that the noncompliance will have affected all gasoline-loading equipment rather than an individual unit. It is unlikely that the MPCA would need to track noncompliance with the requirements at the individual unit level, so the permit team decided that a group was an acceptable way to include these requirements.
3.6 Comments received This Section will be completed after the referenced review periods.
4. Permit fee assessment This permit action is the reissuance of an individual Part 70 permit with no rolled-in applications; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1. The permit reopening to incorporate a new NESHAP is not a chargeable activity (i.e., the standard was not triggered by the modifications requested in the permit applications – it falls under a permit reopening being incorporated in the reissuance).
5. Conclusion Based on the information provided by Magellan Pipeline Co LP - Saint Paul Terminal the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 12300070-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Laura Lyons (permit engineer)
Adriane Lenshek (peer reviewer) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support) Brent Rohne (enforcement) Curtis Stock (stack testing)
TEMPO360 Activities: Part 70 Reissuance (IND20100001)
Attachments: 1. PTE summary calculation spreadsheets 2. Subject item inventory and facility requirements 3. Compliance Assurance Monitoring (CAM) plan 4. EPA VCU Applicability Determination
Magellan Pipeline Company, L.P. - St. Paul Terminal MPL Loading Rack Data
Throughput and Loading InformationPotential Rack Throughput (1000 gallons/year) 840,960
Potential Gasoline Throughput (1000 gallons/year)1 420,480
Potential Kerosene Throughput (1000 gallons/year)1 420,480
No. of Spots at Loading Rack 4
Percent of Loading that is Balanced 100%
Percent of Loading that is Normal (not balanced) 0%
Physical PropertiesTemperature of Bulk Liquid Loaded (oF)2
44.70
Saturation Factor (S) 1.00
Molecular Weight of Gasoline RVP 13 vapors362.00
Molecular Weight of Kerosene Vapors4130.00
Avg. True Vapor Pressure of Gasoline RVP 13 (psia)35.2100
Avg. True Vapor Pressure of Kerosene (psia)5 0.0049
Vapor Control SpecificationsVapor Control Type VCU
Distillate Emissions considered uncontrolled (no destruction--worst case) 0.000Vapor Collection Efficiency6
0.987
Emission Limits--VCUEnforceable limit7 for gasoline loading (mg-VOC/liter-loaded) 35.00
Sources:
2. TanksESP program, noted in header portion of print-out
3. AP-42 Table 7.1-2. Properties of Gasoline RVP 13
4. AP-42 Table 7.1-2. Properties of Jet kerosene5. TanksESP program, based on ATVP for kerosene and distillate at Tbulk
6. EPA AP-42 page 5.2-6
7. 40 Code of Federal Regulations subpart XX [60.502(b)]
1. Total throughput is for 4 LR spots, 2 for gasoline and 2 for kerosene. Maximum throughput for eithersubstance is half of total.
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - MPL Loading Rack
Loading Loss Factor: LL = 12.46*SPM/T 1
Gasoline &
Ethanol 2 DistillateSaturation Factor S 1.00 1.00 Gasoline Distillate TotalLoading Temperature T, (oR) 504.37 504.37 2,2,4 Trimethylpentane 0.008 0.666 0.026 0.692Avg. True Vapor Pressure P (psia) 5.2100 0.0049 Benzene 0.009 0.749 0.030 0.779Vapor Molecular Weight M 62.00 130.00 Ethyl Benzene 0.001 0.083 0.003 0.087Loading Loss Factor LL (lb/1000-gal) 7.980 0.016 Hexane 0.016 1.332 0.053 1.384
Toluene 0.013 1.082 0.043 1.125Potential Uncontrolled VOC Emissions = LL*Q Total Xylenes 0.005 0.416 0.017 0.433
Gasoline &
Ethanol 2 Distillate Totals Total HAP 0.052 4.327 0.172 4.499Throughput Q, (1000-gal/yr) 420,480 420,480
lb/yr 3,355,394 6,617 3,362,011ton/yr 1,678 3 1,681
Gasoline &
Ethanol 2 Distillate TotalsVapor Collection Efficiency 0.987 0.987Estimate VCU Stack Emissions Using 1. Combustion Efficiency, or2. Emission Limit? 2 1Quantity of Vapor Collected (tpy) 1,655.89 3.27
Vapor Combustion Efficiency 3 N/A 0.000Enforceable Emission Limit (mg/l) 35.000 N/AUncaptured VOC Emissions (ton/yr) 21.810 0.043 21.85Uncombusted VOC Emissions (ton/yr) 61.409 3.265 64.67Total VOC Emissions (ton/yr) 83.219 3.308 86.53Uncombusted VOC Emissions (lb/hr) 14.020 0.746 14.77Total VOC Emissions (lb/hr) 19.000 0.755 19.76
NOx Emission factor (mg/l burned)4
NOx Emissions (ton/yr) 7.018 7.018 14.04NOx Emissions (lb/hr) 1.602 1.602 3.20
CO Emission factor (mg/l burned)4
CO Emissions (ton/yr) 17.545 17.545 35.09CO Emissions (lb/hr) 4.006 4.006 8.01
NOTES1. Loading Loss Factor equation from AP-42 Chapter 5, Section 2: Transportation and Marketing of Petroleum Liquids, page 5.2-4.2. Because ethanol is blended with gasoline upon loading, emissions from ethanol loading are estimated as if it were gasoline.3. For gasoline, uncombusted VOC is estimated as 35 mg VOC per liter gasoline loaded. Therefore, vapor-combustion efficiency is N/A.4. Source of NOx and CO Emission factors: manufacturer's specifications.
HAP Emissions (ton/yr)
4
10
Potential Controlled VOC and Combustion Emissions
Fraction of VOCHazardous Air Pollutant
Magellan Pipeline Company, L.P. - St. Paul Terminal FHR Loading Rack Data
Throughput and Loading InformationPotential Rack Throughput (1000 gallons/year) 840,960
Potential Gasoline Throughput (1000 gallons/year)1 420,480
Potential Kerosene Throughput (1000 gallons/year)1 420,480
No. of Spots at Loading Rack 4
Percent of Loading that is Balanced 100%
Percent of Loading that is Normal (not balanced) 0%
Physical PropertiesTemperature of Bulk Liquid Loaded (oF)2
44.70
Saturation Factor (S) 1.00
Molecular Weight of Gasoline RVP 13 vapors362.00
Molecular Weight of Kerosene Vapors4130.00
Avg. True Vapor Pressure of Gasoline RVP 13 (psia)35.2100
Avg. True Vapor Pressure of Kerosene (psia)5 0.0049
Vapor Control SpecificationsVapor Control Type VCU
Distillate Emissions considered uncontrolled (no destruction--worst case) 0.000Vapor Collection Efficiency6
0.987
Emission Limits--VCUEnforceable limit7 for gasoline loading (mg-VOC/liter-loaded) 35.00
Sources:
2. TanksESP program, noted in header portion of print-out
3. AP-42 Table 7.1-2. Properties of Gasoline RVP 13
4. AP-42 Table 7.1-2. Properties of Jet kerosene5. TanksESP program, based on ATVP for kerosene and distillate at Tbulk
6. EPA AP-42 page 5.2-6
7. 40 Code of Federal Regulations subpart XX [60.502(b)]
1. Total throughput is for 4 LR spots, 2 for gasoline and 2 for kerosene. Maximum throughput for eithersubstance is half of total.
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - FHR Loading Rack
Loading Loss Factor: LL = 12.46*SPM/T 1
Gasoline &
Ethanol 2 DistillateSaturation Factor S 1.00 1.00 Gasoline Distillate TotalLoading Temperature T, (oR) 504.37 504.37 2,2,4 Trimethylpentane 0.008 0.666 0.026 0.692Avg. True Vapor Pressure P (psia) 5.2100 0.0049 Benzene 0.009 0.749 0.030 0.779Vapor Molecular Weight M 62.00 130.00 Ethyl Benzene 0.001 0.083 0.003 0.087Loading Loss Factor LL (lb/1000-gal) 7.980 0.016 Hexane 0.016 1.332 0.053 1.384
Toluene 0.013 1.082 0.043 1.125Potential Uncontrolled VOC Emissions = LL*Q Total Xylenes 0.005 0.416 0.017 0.433
Gasoline &
Ethanol 2 Distillate Totals Total HAP 0.052 4.327 0.172 4.499Throughput Q, (1000-gal/yr) 420,480 420,480
lb/yr 3,355,394 6,617 3,362,011ton/yr 1,678 3 1,681
Potential Controlled VOC and Combustion EmissionsGasoline &
Ethanol 2 Distillate TotalsVapor Collection Efficiency 0.987 0.987Estimate VCU Stack Emissions Using 1. Combustion Efficiency, or 2. Emission Limit? 2 1Quantity of Vapor Collected (tpy) 1,655.89 3.27
Vapor Combustion Efficiency 3 N/A 0.000Enforceable Emission Limit (mg/l) 35.000 N/AUncaptured VOC Emissions (ton/yr) 21.810 0.043 21.85Uncombusted VOC Emissions (ton/yr) 61.409 3.265 64.67Total VOC Emissions (ton/yr) 83.219 3.308 86.53Uncombusted VOC Emissions (lb/hr) 14.020 0.746 14.77Total VOC Emissions (lb/hr) 19.000 0.755 19.76
NOx Emission factor (mg/l burned)4
NOx Emissions (ton/yr) 7.018 7.018 14.04NOx Emissions (lb/hr) 1.602 1.602 3.20
CO Emission factor (mg/l burned)4
CO Emissions (ton/yr) 17.545 17.545 35.09CO Emissions (lb/hr) 4.006 4.006 8.01
NOTES1. Loading Loss Factor equation from AP-42 Chapter 5, Section 2: Transportation and Marketing of Petroleum Liquids, page 5.2-4.2. Because ethanol is blended with gasoline upon loading, emissions from ethanol loading are estimated as if it were gasoline.3. For gasoline, uncombusted VOC is estimated as 35 mg VOC per liter gasoline loaded. Therefore, vapor-combustion efficiency is N/A.4. Source of NOx and CO Emission factors: manufacturer's specifications.
4
10
Hazardous Air PollutantFraction of VOC
HAP Emissions (ton/yr)
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - MPL and FHR VCUs pilot light fuel
Operating Hours per Year
Fuel Usage per VCU
Natural Gas Emission Factors
hrs/yr scf/hr1 lb/MMscf2,3,4,5,6 lb/hr/VCU tpy/VCU lb/hr tpyNOx 100 0.02 0.08 0.04 0.16CO 84 0.02 0.07 0.03 0.13CO2 120000 22 95 43 189N2O 2.2 0.00 0.00 0.00 0.00CH4 2.3 0.00 0.00 0.00 0.00CO2e 120713 22 95 43 190PM 7.6 0.00 0.01 0.00 0.01
PM10 5.7 0.00 0.00 0.00 0.01PM2.5 1.9 0.00 0.00 0.00 0.00SO2 0.6 0.00 0.00 0.00 0.00VOC 5.5 0.00 0.00 0.00 0.01
Benzene 0.0021 0.00 0.00 0.00 0.00Hexane 1.8 0.00 0.00 0.00 0.00Toluene 0.0034 0.00 0.00 0.00 0.00
Total HAP 11.3 0.00 0.01 0.00 0.02
NOTES
Pollutant
VCU PTEVCUs Total PTE
(2 VCUs)
3. Source of CO2 EF: AP-42 Table 1.4-2: assumes approximately 100% conversion of fuel carbon to CO2.
8,760 180
6. Source of Benzene, Hexane, Toluene, and Total HAPs from AP-42 Table 1.4-3: Emission Factors for SpeciatedOrganic Compounds from Natural Gas Combustion.
5. CO2e EF calculated using the following equation: (CO2 EF) + (N2O EF)*(N2O global warming potential (GWP)) +(CH4 EF)*(CH4 GWP). Source of GWPs: 40 CFR pt. 98, subp. A, table A-1, Global Warming Potentials.
1. The pilot light fuel rate is 1-3 scf/min (manufacturer's specification), so assumed 3 scfm, or 180 scf/hr for 1 VCU.
2. Source of NOx and CO emission factors (EFs): AP-42 Table 1.4-1: Emission Factors for Nitrogen Oxides (NOx)and Carbon Monoxide (CO) from Natural Gas Combustion.
4. Source of N2O, CH4, PM, SO2, and VOC EFs: AP-42 Table 1.4-2: Emission Factors for Criteria Pollutants andGreenhouse Gases from Natural Gas Combustion.
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Tanks Details
(lb/yr) (ton/yr) (lb/yr) (ton/yr) (lb/yr) (ton/yr) (lb/yr) (lb/hr) (ton/yr)
EQUI 49 425 (Rel TK 001 Gasoline 210,000 2 420,000 1,151 48 1,675.04 0.84 2.40 0.00 0.00 1,677.44 0.19 0.84EQUI 50 509 TK 002 Gasoline 420,420 104 43,723,680 119,791 4,991 2,726.51 1.36 171.80 0.09 285.83 0.14 3,184.14 0.36 1.59EQUI 51 510 TK 004 Gasoline 418,950 104 43,570,800 119,372 4,974 2,726.51 1.36 171.20 0.09 285.83 0.20 3,305.83 0.38 1.65EQUI 52 646 TK 003 Gasoline 656,712 104 68,298,048 187,118 7,797 3,281.14 1.64 214.68 0.11 408.13 0.14 3,781.65 0.43 1.89EQUI 53 649 TK 005 Gasoline 772,044 104 80,292,576 219,980 9,166 2,968.27 1.48 252.39 0.13 408.13 0.20 3,628.78 0.41 1.81EQUI 54 650 TK 006 Gasoline 772,380 104 80,327,520 220,075 9,170 2,999.17 1.50 252.50 0.13 408.13 0.20 3,659.80 0.42 1.83EQUI 55 717 TK 007 Gasoline 1,129,842 104 117,503,568 321,928 13,414 4,120.82 2.06 284.12 0.14 355.31 0.18 4,760.25 0.54 2.38EQUI 56 718 TK 008 Gasoline 1,128,204 104 117,333,216 321,461 13,394 4,120.82 2.06 283.71 0.14 355.31 0.18 4,759.84 0.54 2.38EQUI 58 719 TK 009 Gasoline 1,129,022 104 117,418,288 321,694 13,404 4,120.82 2.06 283.91 0.14 355.31 0.18 4,760.05 0.54 2.38EQUI 59 720 TK 010 Gasoline 1,130,094 104 117,529,776 321,999 13,417 4,120.82 2.06 284.18 0.14 355.31 0.18 4,760.32 0.54 2.38EQUI 60 743 TK 011 Gasoline 1,115,100 104 115,970,400 317,727 13,239 4,120.82 2.06 280.41 0.14 355.31 0.18 4,756.54 0.54 2.38EQUI 61 745 TK 012 Gasoline 1,444,674 104 150,246,096 411,633 17,151 3,649.79 1.82 290.03 0.15 905.48 0.45 4,845.30 0.55 2.42EQUI 62 805 TK 013 Gasoline 3,013,668 104 313,421,472 858,689 35,779 5,958.69 2.98 492.59 0.25 1,939.17 0.97 8,390.45 0.96 4.20EQUI 63 806 TK 014 Gasoline 2,972,004 104 309,088,416 846,818 35,284 6,131.74 3.07 485.78 0.24 1,866.60 0.93 8,484.12 0.97 4.24EQUI 64 807 TK 015 Gasoline 3,013,752 104 313,430,208 858,713 35,780 6,008.11 3.00 492.61 0.25 1,866.60 0.93 8,367.32 0.96 4.18EQUI 65 808 TK 016 Gasoline 3,014,424 104 313,500,096 858,904 35,788 6,131.74 3.07 492.72 0.25 1,866.60 0.93 8,491.06 0.97 4.25EQUI 66 809 TK 017 Jet Kerosene 3,297,420 104 342,931,680 939,539 39,147 378.78 0.19 2,525.74 1.26 0.00 2,904.52 0.33 1.45EQUI 67 810 TK 018 Jet Kerosene 3,296,244 104 342,809,376 939,204 39,133 378.78 0.19 2,525.40 1.26 0.00 2,904.18 0.33 1.45EQUI 69 813 TK 019 Gasoline 3,042,060 104 316,374,240 866,779 36,116 19,330.64 9.67 547.37 0.27 1,866.60 0.93 21,744.62 2.48 10.87EQUI 38 814 TK 020 Gasoline 3,041,766 104 316,343,664 866,695 36,112 15,563.67 7.78 524.53 0.26 1,866.60 0.93 17,954.80 2.05 8.98EQUI 70 815 TK 021 Jet Kerosene 3,299,352 104 343,132,608 940,089 39,170 378.78 0.19 2,526.30 1.26 0.00 2,905.08 0.33 1.45EQUI 71 816 TK 022 Jet Kerosene 3,299,856 104 343,185,024 940,233 39,176 378.78 0.19 2,526.45 1.26 0.00 2,905.22 0.33 1.45EQUI 72 817 TK 023 Jet Kerosene 3,299,394 104 343,136,976 940,101 39,171 378.78 0.19 2,526.31 1.26 0.00 2,905.09 0.33 1.45EQUI 73 818 TK 024 Jet Kerosene 3,304,056 104 343,621,824 941,430 39,226 378.78 0.19 2,527.66 1.26 0.00 2,906.44 0.33 1.45EQUI 74 819 TK 025 Jet Kerosene 3,304,098 104 343,626,192 941,442 39,227 378.78 0.19 2,527.67 1.26 0.00 2,906.45 0.33 1.45EQUI 75 820 TK 026 Jet Kerosene 3,219,132 104 334,789,728 917,232 38,218 378.78 0.19 2,503.05 1.25 0.00 2,881.83 0.33 1.44EQUI 40 822 TK 027 Gasoline 3,042,564 104 316,426,656 866,922 36,122 21,244.73 10.62 570.26 0.29 1,866.60 0.93 23,681.59 2.70 11.84EQUI 41 823 TK 028 Gasoline 3,047,436 104 316,933,344 868,311 36,180 15,870.42 7.94 571.17 0.29 1,866.60 0.93 18,308.19 2.09 9.15EQUI 77 824 TK 029 Gasoline 3,042,942 104 316,465,968 867,030 36,126 21,244.73 10.62 570.33 0.29 1,866.60 0.93 23,681.66 2.70 11.84EQUI 78 825 TK 030 Jet Kerosene 3,304,308 104 343,648,032 941,501 39,229 378.78 0.19 2,527.74 1.26 0.00 2,906.51 0.33 1.45EQUI 79 826 TK 031 Jet Kerosene 3,303,846 104 343,599,984 941,370 39,224 378.78 0.19 2,527.60 1.26 0.00 2,906.38 0.33 1.45EQUI 80 827 TK 032 Gasoline 3,299,352 104 343,132,608 940,089 39,170 15,807.67 7.90 618.39 0.31 1,866.60 0.93 18,292.66 2.09 9.15EQUI 81 828 TK 033 Jet Kerosene 3,298,596 104 343,053,984 939,874 39,161 378.78 0.19 2,526.08 1.26 0.00 2,904.86 0.33 1.45EQUI 82 904 TK 034 Denatured Ethanol 195,216 104 20,302,464 55,623 2,318 1,815.70 0.91 11,886.22 5.94 0.00 13,701.92 1.56 6.85
Totals 179,904.93 89.95 47,793.28 23.90 23,216.65 11.61 250,914.86 28.64 125.46
Note: 1. AST standing and working losses (lb/yr) generated from the Tank Emissions Software Program (TankESP) using 2016 data. TankESP summary sheet included for reference. TankESP applies AP-42, Chap 7.1 methodology.
2. AST floating roof landing losses (lb/yr) generated from TankESP and checked against calculations that used equations from AP-42, Chapter 7.1 .
Annual (gal/yr)
Average Daily
(gal/day)
Average Hourly (gal/hr)
Standing Loss 1 Working Loss 1Floating Roof
Landings Loss 2Potential Annual
Turnovers
Potential Throughput
Subject Item ID
Tank No.
Emission Point
Most Volatile Product Stored
Capacity(gal)
VOC Emissions
Total
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Tanks Summary
HAP Fractions of VOC
(lb/yr) (ton/yr)
2,2,4 trimethyl pentane Benzene
Ethyl Benzene Hexane Toluene
Total Xylenes
Total HAP Pollutant
Fraction of VOC
EQUI 49 425 TK 001 1,677.44 0.84 0.0067 0.0075 0.0008 0.0134 0.0109 0.0042 0.0436 2,2,4 Trimethylpentan 0.008EQUI 50 509 TK 002 3,184.14 1.59 0.0127 0.0143 0.0016 0.0255 0.0207 0.0080 0.0828 Benzene 0.009EQUI 51 510 TK 004 3,305.83 1.65 0.0132 0.0149 0.0017 0.0264 0.0215 0.0083 0.0860 Ethyl Benzene 0.001EQUI 52 646 TK 003 3,781.65 1.89 0.0151 0.0170 0.0019 0.0303 0.0246 0.0095 0.0983 Hexane 0.016EQUI 53 649 TK 005 3,628.78 1.81 0.0145 0.0163 0.0018 0.0290 0.0236 0.0091 0.0943 Toluene 0.013EQUI 54 650 TK 006 3,659.80 1.83 0.0146 0.0165 0.0018 0.0293 0.0238 0.0091 0.0952 Total Xylenes 0.005EQUI 55 717 TK 007 4,760.25 2.38 0.0190 0.0214 0.0024 0.0381 0.0309 0.0119 0.1238EQUI 56 718 TK 008 4,759.84 2.38 0.0190 0.0214 0.0024 0.0381 0.0309 0.0119 0.1238EQUI 58 719 TK 009 4,760.05 2.38 0.0190 0.0214 0.0024 0.0381 0.0309 0.0119 0.1238EQUI 59 720 TK 010 4,760.32 2.38 0.0190 0.0214 0.0024 0.0381 0.0309 0.0119 0.1238EQUI 60 743 TK 011 4,756.54 2.38 0.0190 0.0214 0.0024 0.0381 0.0309 0.0119 0.1237EQUI 61 745 TK 012 4,845.30 2.42 0.0194 0.0218 0.0024 0.0388 0.0315 0.0121 0.1260EQUI 62 805 TK 013 8,390.45 4.20 0.0336 0.0378 0.0042 0.0671 0.0545 0.0210 0.2182EQUI 63 806 TK 014 8,484.12 4.24 0.0339 0.0382 0.0042 0.0679 0.0551 0.0212 0.2206EQUI 64 807 TK 015 8,367.32 4.18 0.0335 0.0377 0.0042 0.0669 0.0544 0.0209 0.2176EQUI 65 808 TK 016 8,491.06 4.25 0.0340 0.0382 0.0042 0.0679 0.0552 0.0212 0.2208EQUI 66 809 TK 017 2,904.52 1.45 0.0116 0.0131 0.0015 0.0232 0.0189 0.0073 0.0755EQUI 67 810 TK 018 2,904.18 1.45 0.0116 0.0131 0.0015 0.0232 0.0189 0.0073 0.0755EQUI 69 813 TK 019 21,744.62 10.87 0.0870 0.0979 0.0109 0.1740 0.1413 0.0544 0.5654EQUI 38 814 TK 020 17,954.80 8.98 0.0718 0.0808 0.0090 0.1436 0.1167 0.0449 0.4668EQUI 70 815 TK 021 2,905.08 1.45 0.0116 0.0131 0.0015 0.0232 0.0189 0.0073 0.0755EQUI 71 816 TK 022 2,905.22 1.45 0.0116 0.0131 0.0015 0.0232 0.0189 0.0073 0.0755EQUI 72 817 TK 023 2,905.09 1.45 0.0116 0.0131 0.0015 0.0232 0.0189 0.0073 0.0755EQUI 73 818 TK 024 2,906.44 1.45 0.0116 0.0131 0.0015 0.0233 0.0189 0.0073 0.0756EQUI 74 819 TK 025 2,906.45 1.45 0.0116 0.0131 0.0015 0.0233 0.0189 0.0073 0.0756EQUI 75 820 TK 026 2,881.83 1.44 0.0115 0.0130 0.0014 0.0231 0.0187 0.0072 0.0749EQUI 40 822 TK 027 23,681.59 11.84 0.0947 0.1066 0.0118 0.1895 0.1539 0.0592 0.6157EQUI 41 823 TK 028 18,308.19 9.15 0.0732 0.0824 0.0092 0.1465 0.1190 0.0458 0.4760EQUI 77 824 TK 029 23,681.66 11.84 0.0947 0.1066 0.0118 0.1895 0.1539 0.0592 0.6157EQUI 78 825 TK 030 2,906.51 1.45 0.0116 0.0131 0.0015 0.0233 0.0189 0.0073 0.0756EQUI 79 826 TK 031 2,906.38 1.45 0.0116 0.0131 0.0015 0.0233 0.0189 0.0073 0.0756EQUI 80 827 TK 032 18,292.66 9.15 0.0732 0.0823 0.0091 0.1463 0.1189 0.0457 0.4756EQUI 81 828 TK 033 2,904.86 1.45 0.0116 0.0131 0.0015 0.0232 0.0189 0.0073 0.0755EQUI 82 904 TK 034 13,701.92 6.85 0.0548 0.0617 0.0069 0.1096 0.0891 0.0343 0.3562
Totals 250,914.86 125.46 1.0037 1.1291 0.1255 2.0073 1.6309 0.6273 6.5238
VOC Hazardous Air Pollutants (ton/yr)
Tank No.
Emission PointSI ID
STORAGE TANK EMISSIONS ESTIMATES - Summary Report
Company: Magellan Pipeline Co Location: MINNEAPOLIS-MN
Days Estimated Total
Estimated Period Year Avg. Conditions
This Period TemD (°F) delta T Insolation Wind Speed
Is this a this
Month Estimated Losses VRU
Efficiency Does this include a
Emissions This Month
VRU Efficiency
Emissions This Month ANNUAL 2016
Avg. Conditions This Period 44.71 18.99 1170.00 10.56 | Is this a
this Month This Month
VRU Efficiency
Does this include a
Emissions This Month
VRU Efficiency
Emissions This Month
Return to lnput_Service Liquid Temp Avg Landing Cleaning Standing Workinq normal Tank from tank Total Tank Diam. RVP Throughout Bulk Surface TVP Loss this Tank If Floatinq Roof Landinq operations Cleaning Tank cleaninq VOCs ID No. (feet) Tank Tvoe Product (psi) (gallons) (deq F) (deq F) (psia) Event (davs) Standinq Idle Refillinq (%1 Event Cleaninq (%) (lbs) 425 33.00 domed EFRT Gasoline RVP X.XX 13 420,000 not spec'd 46.30 5.3760 No 0 1,675.04 2.40 0.00% No 0 0.00% 1,677.44 444 27.00 FRT(no floating roof) Kerosene/Jet A 13,363,038 not spec'd 46.30 0.0052 No 0 14.82 99.54 0.00% No 0 0.00% 114.35 445 27.00 FRT(no floating roof) Kerosene/Jet A 13,363,038 not spec'd 46.30 0.0052 No 0 14.82 99.54 0.00% No 0 0.00% 114.35 509 48.00 domed EFRT Gasoline RVP X.XX 13 43,723,680 not spec'd 46.30 5.3760 No 0 2,726.51 171.80 0.00% No 0 0.00% 2,898.31 510 48.00 domed EFRT Gasoline RVP X.XX 13 43,570,800 not spec'd 46.30 5.3760 No 0 2,726.51 171.20 0.00% No 0 0.00% 2,897.70 646 60.00 domed EFRT Gasoline RVP X.XX 13 68,298,048 not spec'd 46.30 5.3760 No 0 3,281.14 214.68 0.00% No 0 0.00% 3,495.82 649 60.00 domed EFRT Gasoline RVP X.XX 13 80,292,576 not spec'd 46.30 5.3760 No 0 2,968.27 252.39 0.00% No 0 0.00% 3,220.65 650 60.00 domed EFRT Gasoline RVP X.XX 13 80,327,520 not spec'd 46.30 5.3760 No 0 2,999.17 . 252.50 0.00% No 0 0.00% 3,251.67 717 78.00 domed EFRT Gasoline RVP X.XX 13 117,503,568 not spec'd 46.30 5.3760 No 0 4,120.82 284.12 0.00% No 0 0.00% 4,404.94 718 78.00 domed EFRT Gasoline RVP X.XX 13 117,333,216 not spec'd 46.30 5.3760 No 0 4,120.82 283.71 0.00% No 0 0.00% 4,404.53 719 78.00 domed EFRT Gasoline RVP X.XX 13 117,418,288 not spec'd 46.30 5.3760 No 0 4,120.82 283.91 0.00% No 0 0.00% 4,404.74 720 78.00 domed EFRT Gasoline RVP X.XX 13 117,529,776 not spec'd 46.30 5.3760 No 0 4,120.82 284.18 0.00% No 0 0.00% 4,405.01 743 78.00 domed EFRT Gasoline RVP X.XX 13 115,970,400 not spec'd 46.30 5.3760 No 0 4,120.82 280.41 0.00% No 0 0.00% 4,401.23 745 82.00 domed EFRT Natural Gasoline 14 150,246,096 not spec'd 46.30 5.7374 No 0 3,649.79 290.03 0.00% No 0 0.00% 3,939.82 805 120.00 domed EFRT Gasoline RVP X.XX 13 313,421,472 not spec'd 46.30 5.3760 No 0 5,958.69 492.59 0.00% No 0 0.00% 6,451.28 806 120.00 domed EFRT Gasoline RVP X.XX 13 309,088,416 not spec'd 46.30 5.3760 No 0 6,131.74 485.78 0.00% No 0 0.00% 6,617.52 807 120.00 domed EFRT Gasoline RVP X.XX 13 313,430,208 not spec'd 46.30 5.3760 No 0 6,008.11 492.61 0.00% No 0 0.00% 6,500.72 808 120.00 domed EFRT Gasoline RVP X.XX 13 313,500,096 not spec'd 46.30 5.3760 No 0 6,131.74 492.72 0.00% No 0 0.00% 6,624.46 809 120.00 FRT(no floating roof) Kerosene/Jet A 342,931,680 not spec'd 46.30 0.0052 No 0 378.78 2,525.74 0.00% No 0 0.00% 2,904.52 810 120.00 FRT(no floating roof) Kerosene/Jet A 342,809,376 not spec'd 46.30 0.0052 No 0 378.78 2,525.40 0.00% No 0 0.00% 2,904.18 813 120.00 cone-roof tank w/IFR Gasoline RVP X.XX 13 316,374,240 not spec'd 46.30 5.3760 No 0 19,330.64 547.37 0.00% No 0 0.00% 19,878.02 814 120.00 cone-roof tank w/IFR Gasoline RVP X.XX 13 316,343,664 not spec'd 46.30 5.3760 No 0 15,563.67 524.53 0.00% No 0 0.00% 16,088.20 815 120.00 FRT(no floating roof) Kerosene/Jet A 343,132,608 not spec'd 46.30 0.0052 No 0 378.78 2,526.30 0.00% No 0 0.00% 2,905.08 816 120.00 FRT(no floating roof) Kerosene/Jet A 343,185,024 not spec'd 46.30 0.0052 No 0 378.78 2,526.45 0.00% No 0 0.00% 2,905.22
817 120.00 FRT(no floating roof) Kerosene/Jet A 343,136,976 not spec'd 46.30 0.0052 No 0 378.78 2,526.31 0.00% No 0 0.00% 2,905.09
818 120.00 FRT(no floating roof) Kerosene/Jet A 343,621,824 not spec'd 46.30 0.0052 No 0 378.78 2,527.66 0.00% No 0 0.00% 2,906.44 819 120.00 FRT(no floating roof) Kerosene/Jet A 343,626,192 not spec'd 46.30 0.0052 No 0 378.78 2,527.67 0.00% No 0 0.00% 2,906.45
820 120.00 FRT(no floating roof) Kerosene/Jet A 334,789,728 not spec'd 46.30 0.0052 No 0 378.78 2,503.05 0.00% No 0 0.00% 2,881.83
822 120.00 cone-roof tank w/IFR Gasoline RVP X.XX 13 316,426,656 not spec'd 46.30 5.3760 No 0 21,244.73 570.26 0.00% No 0 0.00% 21,814.99 823 120.00 cone-roof tank w/IFR Gasoline RVP X.XX 13 316,933,344 not spec'd 46.30 5.3760 No 0 15,870.42 571.17 0.00% No 0 0.00% 16,441.59
824 120.00 cone-roof tank w/IFR Gasoline RVP X.XX 13 316,465,968 not spec'd 46.30 5.3760 No 0 21,244.73 570.33 0.00% No 0 0.00% 21,815.06
825 120.00 FRT(no floating roof) Kerosene/Jet A 343,648,032 not spec'd 46.30 0.0052 No 0 378.78 2,527.74 0.00% No 0 0.00% 2,906.51
826 120.00 FRT(no floating roof) Kerosene/Jet A 343,599,984 not spec'd 46.30 0.0052 No 0 378.78 2,527.60 0.00% No 0 0.00% 2,906.38
827 120.00 cone-roof tank w/IFR Gasoline RVP X.XX 13 343,132,608 not spec'd 46.30 5.3760 No 0 15,807.67 618.39 0.00% No 0 0.00% 16,426.06
828 120.00 FRT(no floating roof) Kerosene/Jet A 343,053,984 not spec'd 46.30 0.0052 No 0 378.78 2,526.08 0.00% No 0 0.00% 2,904.86
file: MN-MINNEAPOLIS, TankESP updated fittings 2017 and RVP 13 PTE; sheet: TankSummaries
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Additives Tanks Details
(lb/yr) (ton/yr) (lb/yr) (ton/yr) (lb/yr) (ton/yr) (lb/hr)
210-444 Jet Kerosene 128,491 104 13,363,038 36,611 1,525 14.82 0.007 99.54 0.050 114.35 0.057 0.013210-445 Jet Kerosene 128,491 104 13,363,038 36,611 1,525 14.82 0.007 99.54 0.050 114.35 0.057 0.013210-130 Fuel Additives 6,000 12 72,000.00 197.26 8.22 88.50 0.044 133.59 0.067 222.09 0.111 0.025210-080 Fuel Additives 1,981 12 23,772.00 65.13 2.71 30.23 0.015 44.11 0.022 74.33 0.037 0.008210-160 Fuel Additives 2,005 12 24,060.00 65.92 2.75 30.23 0.015 44.64 0.022 74.87 0.037 0.009210-132 Fuel Additives 6,000 12 72,000.00 197.26 8.22 88.50 0.044 133.59 0.067 222.09 0.111 0.025210-133 Fuel Additives 1,026 12 12,312.00 33.73 1.41 16.32 0.008 22.84 0.011 39.17 0.020 0.004210-010 Fuel Additives 1,030 12 12,360.00 33.86 1.41 16.32 0.008 22.93 0.011 39.26 0.020 0.004210-138 Fuel Additives 6,000 12 72,000.00 197.26 8.22 88.50 0.044 133.59 0.067 222.09 0.111 0.025210-134 Fuel Additives 1,002 12 12,024.00 32.94 1.37 15.44 0.008 22.31 0.011 37.75 0.019 0.004210-021 Fuel Additives 4,000 12 48,000.00 131.51 5.48 60.38 0.030 89.06 0.045 149.44 0.075 0.017210-135 Fuel Additives 1,003 12 12,036.00 32.98 1.37 15.44 0.008 22.33 0.011 37.77 0.019 0.004210-040 Fuel Additives 1,003 12 12,036.00 32.98 1.37 15.44 0.008 22.33 0.011 37.77 0.019 0.004383-060 Fuel Additives 11,980 12 143,760.00 393.86 16.41 172.48 0.086 266.74 0.133 439.21 0.220 0.050383-080 Fuel Additives 8,000 12 96,000.00 263.01 10.96 114.54 0.057 178.12 0.089 292.66 0.146 0.033383-110 Fuel Additives 4,136 12 49,632.00 135.98 5.67 60.10 0.030 92.09 0.046 152.19 0.076 0.017383-061 Fuel Additives 5,987 12 71,844.00 196.83 8.20 86.67 0.043 133.30 0.067 219.97 0.110 0.025383-065 Fuel Additives 2,005 12 24,060.00 65.92 2.75 29.22 0.015 44.64 0.022 73.86 0.037 0.008383-062 Fuel Additives 1,026 12 12,312.00 33.73 1.41 15.90 0.008 22.84 0.011 38.75 0.019 0.004383-064 Fuel Additives 519 12 6,228.00 17.06 0.71 8.31 0.004 11.56 0.006 19.87 0.010 0.002383-133 Fuel Additives 750 12 9,000.00 24.66 1.03 11.69 0.006 16.70 0.008 28.39 0.014 0.003383-135 Fuel Additives 550 12 6,600.00 18.08 0.75 8.92 0.004 12.25 0.006 21.17 0.011 0.002383-138 Fuel Additives 10,000 12 120,000.00 328.77 13.70 145.53 0.073 222.65 0.111 368.18 0.184 0.042383-160 Fuel Additives 3,000 12 36,000.00 98.63 4.11 44.46 0.022 66.80 0.033 111.26 0.056 0.013
Totals 1,192.752 0.596 1,958.10 0.979 3,150.85 1.575 0.360
Note:
Per Minn. R. 7007.1300, subp. 3(I), the following tanks qualify as insignificant activites. 1
1. Minn. R. 7007.1300, subp. 3(I)(2): Individual emission units at a stationary source qualify as insignificant activities if each of which have a potential to emit VOCs (including hazardous air pollutant-containing VOCs) in amounts less than 2,000 pounds per year.
2. AST standing and working losses (lb/yr) generated from TankESP (applying AP-42 Chapter 7.1 methodology). TankESP summary sheet included for reference.
Tank No.Most Volatile Product Stored
Potential
Annual Turnove
rs
VOC Emissions
Capacity
(gal)Annual(gal/yr)
Average Daily
(gal/day)
Average Hourly(gal/hr)
Standing Loss 2Working/
Re-filling Loss 2 Total
Potential Throughput
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Additives Tanks Summary
HAP Fractions of VOC
(lb/yr) (ton/yr)
2,2,4 trimethyl pentane Benzene
Ethyl Benzene Hexane Toluene
Total Xylenes
Total HAP Pollutant
Fraction of VOC
210-444 114.35 0.06 0.000 0.001 0.0001 0.0009 0.0007 0.0003 0.003 2,2,4 Trimethylpentan 0.008210-445 114.35 0.06 0.000 0.001 0.0001 0.0009 0.0007 0.0003 0.003 Benzene 0.009210-130 222.09 0.11 0.0009 0.001 0.0001 0.0018 0.0014 0.0006 0.006 Ethyl Benzene 0.001210-080 74.33 0.04 0.0003 0.000 0.0000 0.0006 0.0005 0.0002 0.002 Hexane 0.016210-160 74.87 0.04 0.0003 0.000 0.0000 0.0006 0.0005 0.0002 0.002 Toluene 0.013210-132 222.09 0.11 0.0009 0.001 0.0001 0.0018 0.0014 0.0006 0.006 Total Xylenes 0.005210-133 39.17 0.02 0.0002 0.000 0.0000 0.0003 0.0003 0.0001 0.001210-010 39.26 0.02 0.0002 0.000 0.0000 0.0003 0.0003 0.0001 0.001210-138 222.09 0.11 0.0009 0.001 0.0001 0.0018 0.0014 0.0006 0.006210-134 37.75 0.02 0.0002 0.000 0.0000 0.0003 0.0002 0.0001 0.001210-021 149.44 0.07 0.0006 0.001 0.0001 0.0012 0.0010 0.0004 0.004210-135 37.77 0.02 0.0002 0.000 0.0000 0.0003 0.0002 0.0001 0.001210-040 37.77 0.02 0.0002 0.000 0.0000 0.0003 0.0002 0.0001 0.001383-060 439.21 0.22 0.0018 0.002 0.0002 0.0035 0.0029 0.0011 0.011383-080 292.66 0.15 0.0012 0.001 0.0001 0.0023 0.0019 0.0007 0.008383-110 152.19 0.08 0.0006 0.001 0.0001 0.0012 0.0010 0.0004 0.004383-061 219.97 0.11 0.0009 0.001 0.0001 0.0018 0.0014 0.0005 0.006383-065 73.86 0.04 0.0003 0.000 0.0000 0.0006 0.0005 0.0002 0.002383-062 38.75 0.02 0.0002 0.000 0.0000 0.0003 0.0003 0.0001 0.001383-064 19.87 0.01 0.0001 0.000 0.0000 0.0002 0.0001 0.0000 0.001383-133 28.39 0.01 0.0001 0.000 0.0000 0.0002 0.0002 0.0001 0.001383-135 21.17 0.01 0.0001 0.000 0.0000 0.0002 0.0001 0.0001 0.001383-138 368.18 0.18 0.0015 0.002 0.0002 0.0029 0.0024 0.0009 0.010383-160 111.26 0.06 0.0004 0.001 0.0001 0.0009 0.0007 0.0003 0.003
Totals 3,150.85 1.58 0.0126 0.0142 0.0016 0.0252 0.0205 0.0079 0.082
Note:
Tank No.
VOC Hazardous Air Pollutants (ton/yr)
Per Minn. R. 7007.1300, subp. 3(I), the following tanks qualify as insignificant activites. 1
1. Minn. R. 7007.1300, subp. 3(I)(2): Individual emission units at a stationary source qualify as insignificant activities if each of which have a potential to emit VOCs (including hazardous air pollutant-containing VOCs) in amounts less than 2,000 pounds per year.
STORAGE TANK EMISSIONS ESTIMATES - Summary ReportCompany: Magellan Pipeline Co. Location: MINNEAPOLIS-MN Total
Days Days Estimated EstimatedPeriod Year Avg. Conditions Temp (oF) delta T Insolation Wind Speed this this VRU Does this Emissions VRU Emissions
ANNUAL 2012 This Period 44.71 18.99 1170.00 10.56 Is this a Month Month Efficiency include a This Month Efficiency This Month
Avg Landing in this Cleaning Standing Working normal Tank from tank TotalTank Diam. RVP Throughput Bulk Surface TVP Loss Service this Tank operations Cleaning Tank cleaning VOCsID No. (feet) Tank Type Product (psi) (gallons) (deg F) (deg F) (psia) Event (days) (days) Standing Idle Refilling (%) Event Cleaning (%) (lbs)
Return to Input_Service Liquid Temp
This MonthEstimated Losses
If Floating Roof Landing
file: MN-MINNEAPOLIS_TankESP.xlsm; sheet: TankSummaries
ID No. (feet) Tank Type Product (psi) (gallons) (deg F) (deg F) (psia) Event (days) (days) Standing Idle Refilling (%) Event Cleaning (%) (lbs)133 6.42 horizontal tank Jet naphtha (JP-4) 9,000 not spec'd 46.3 0.94 No 365 0 11.69 16.70 0.00% No 0 0.00% 28.39135 5.60 horizontal tank Jet naphtha (JP-4) 6,600 not spec'd 46.3 0.94 No 365 0 8.92 12.25 0.00% No 0 0.00% 21.16138 16.58 horizontal tank Jet naphtha (JP-4) 120,000 not spec'd 46.3 0.94 No 365 0 145.53 222.65 0.00% No 0 0.00% 368.18160 10.40 horizontal tank Jet naphtha (JP-4) 36,000 not spec'd 46.3 0.94 No 365 0 44.46 66.80 0.00% No 0 0.00% 111.26
file: MN-MINNEAPOLIS_TankESP.xlsm; sheet: TankSummaries
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Railcar Loading Rack
Loading Loss Factor: LL = 12.46*SPM/T 2
Fuel Oil
Saturation Factor, S 3 0.60
Avg. True Vapor Pressure, P (psia) 0.0039Vapor Molecular Weight, M 4 (lb/lb-mole 130Loading Temperature, T (oF) 44.7Loading Loss Factor, LL (lb/1000-gal) 0.008
Throughput and Loading InformationPotential Rack Throughput (1000-gal/yr) 126,000
% of Loading that is Balanced 0%
% of Loading that is Normal (not balance 100%Vapor Control Type NoneEnforceable limit for gasoline loading None
lb/yr 947
lb/hr 0.11ton/yr 0.47
2,2,4 Trimethylpentane 0.008 0.004Benzene 0.009 0.004Ethyl Benzene 0.001 0.000Hexane 0.016 0.008Toluene 0.013 0.006Total Xylenes 0.005 0.002
0.025
Note:
2. Loading Loss Factor equation from AP-42 Chapter 5.2: Transportation of Petroleum Liquids, pg 5.2-4.
3. Source: EPA AP-42 Table 5.2-1
4. Source: AP-42 Table 7.1-2. Properties of Jet kerosene
1. Minn. R. 7007.1300, subp. 4: An emission unit at a stationary source qualifies as an insignificant activity in an initial part 70 permit if it has potential emissions of less than 2.28 pounds per hour or actual emissions of less than 1 ton per year for VOCs, and combined HAP actual emissions of less than 1 ton per year.
Per Minn. R. 7007.1300, subp. 4, on-site railcar loading qualifies as an insignificant activity. 1
Potential Uncontrolled VOC Emissions = LL*Q
PollutantFraction of
VOCHAP Emissions
(ton/yr)
Total HAP
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Ethanol UnloadingPer Minn. R. 7007.1300, subp. 4, on-site ethanol unloading qualifies as an insignificant activity. 1
Loading Loss Factor: LL = 12.46*SPM/T 2
0.60
0.9421
46.38
46.30.65
Annual Ethanol Throughput, QEthanol Units
16.00 inches1.33 feet8.00 feet
11.17 ft3
55.71 gallon8 1000-gallon
840,960 1000-gallon/year84,096 1000-gallon/year10,512 EtOH trucks/year
586 1000-gallon/year
lb/yr 378lb/hr 0.04
ton/yr 0.19
HAP Fractions of VOCPollutant Gas Fraction of VOC Ethanol 8 HAP (ton/yr)
2,2,4 Trimethylpentane 0.008 0.00016 3.024E-05Benzene 0.009 0.00018 3.402E-05Ethyl Benzene 0.001 0.00002 3.781E-06Hexane 0.016 0.00032 6.049E-05Toluene 0.013 0.00026 4.915E-05Total Xylenes 0.005 0.00010 1.890E-05
0.0002
Notes:
2. Loading Loss Factor equation from AP-42 Chapter 5.2: Transportation & Marketing of Petroleum Liquids, pg 5.2-4.
3. Source: EPA AP-42 Table 5.2-1.
1. Minn. R. 7007.1300, subp. 4: An emission unit at a stationary source qualifies as an insignificant activity in an initial part 70 permit if it has potential emissions of less than 2.28 pounds per hour or actual emissions of less than 1 ton per year for VOCs, and combined HAP actual emissions of less than 1 ton per year.
Potential Uncontrolled VOC Emissions = LL*Q
Annual Ethanol unloading limit (assume 10% of gasoline limit)Annual maximum number of Ethanol unloading trucks per yearQ
8. Denatured ethanol includes up to 2% gasoline as denaturant; therefore, potential HAP fractions are 2% gasoline HAP fractions.
7. Volume loaded is calculated as the unloading pipe volume multiplied by 2/3, due to the assumption that only 2/3 of the pipe is filled with emissions for loading loss due to engineering design.
6. Loading temperature is the liquid surface temperature. Most of the PTE used bulk temperature, but since the ethanol is from a tank truck, it is assumed it's warmer than product from a pipeline or AST.
5. Molecular weight is for denatured ehtanol that includes up to 2% gasoline as denaturant.
4. Denatured ethanol assumed to have be RVP 3.7, which was used to extrapolate the TVP at the designated temp.
Vapor Molecular Weight, M (lb/lb-mole) 5Avg. True Vapor Pressure, P (psia) 4Saturation Factor, S 3
Total HAP
Unloading pipe diameter
Unloading pipe lengthUnloading pipe volumeevent 7
Maximum unloading tanker volumeAnnual Gasoline loading limit (sum of 2 LR)
Loading Loss Factor, LL (lb/1000-gal)Loading Temperature, T (oF) 6
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Butane Unloading, Sampling, and System Maintenance
Butane Unloading Emissions per Station
V = Hose volume (ft3) / D = Density of Butane (lb/gal) / EA = Events per Year
Pipe Diameter
Unloading Pipe Length
Butane Density
PTE
(in) (ft) (ft3) (gal) (lb/gal) (ton/yr)Butane Truck Unloading 2 1.50 0.03 0.245 5.06 500 0.31
Butane Sample Tee Purging Emissions per Station
V = Tee volume (ft3)
Butane Density PTE
(ft3) (gal) (lb/gal) (ton/yr)Butane Sample Tee Purging 0.0177 0.132 5.06 0.5 4380 1.46
Butane Routine Maintenance Emissions per Station
Pipe Diameter
Pipe LengthButane Density
PTE
(in) (ft) (ft3) (gal) (lb/gal) (ton/yr)Butane System Routine Maintenan 2 20.00 0.44 3.264 5.06 6 0.05
Summary of Potential VOC Emissions for Three (3) Butane Unloading Stations(lb/hr)
Truck Unloading
Sample Tee Purging
Maintenance Total Total
Butane Station #1 0.31 0.00 0.05 0.36 0.082Butane Station #2 0.31 0.00 0.05 0.36 0.082Butane Station #3 0.31 0.00 0.05 0.36 0.082
Totals 1.08 0.246
Note:
2. Unloading volume lost per event assumes all liquid between the shut-off valve and coupler evaporates. Butane vaporizes almost instantaneously.
Pipe Volume 2Service
Events per Year
1. Minn. R. 7007.1300, subp. 4: An emission unit at a stationary source qualifies as an insignificant activity in an initial part 70 permit if it has potential emissions of less than 2.28 pounds per hour or actual emissions of less than 1 ton per year for VOCs, and combined HAP actual emissions of less than 1 ton per year.
Emissions Source
Potential VOC Emissions (ton/yr)
Emission Source
Per Minn. R. 7007.1300, subp. 4, on-site butane unloading, routine maintenance, and sample purging qualify as an insignificant a
Emission Source
Unloading Pipe Volume 2Unloading Events per
Year
Potential emissions from sample-tee purging are estimated using the equation: Maximum Annual Emissions = V*D*E A , where
Potential emissions from butane unloading are estimated using the equation: Maximum Annual Emissions = V*D*E A , where
Emission Source
Purged Sample Tee Tubing Volume Purges per
hourPurges per
year
Potential emissions from system maintenace are estimated using the equation: Maximum Hourly Emissions = V*D*E A , where
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Biodiesel Unloading
Bio-diesel Unloading Emissions
V = Volume Emitted per Disconnect (gal/event) / D = Density of Biodiesel Fuel (lb/gal) / E = Events per Year
Emission Source
Unloading Volume
(gal/event) 2Density(lb/gal)
Events per year
Potential to Emit(lb/yr)
Potential to Emit(ton/yr)
HAP PTE (ton/yr)
Biodiesel Truck Unloading 0.001302083 7.00 200 1.82 0.0009 4.74E-05
Note:
Per Minn. R. 7007.1300, subp. 3(I), biodiesel unloading qualifies as an insignificant activity. 1
Potential emissions from bio-diesel unloading are estimated using the equation: Maximum Hourly Emissions = V*D*E , where
1. Minn. R. 7007.1300, subp. 3(I)(2): Individual emission units at a stationary source qualify as insignificant activities if each of which have a potential to emit VOCs (including hazardous air pollutant-containing VOCs) in amounts less than 2,000 pounds per year.
2. Unloading volume lost per event assumes all liquid between the shut-off valve and coupler evaporates. Most of biodiesel gets soaked up by sorbent pads, but for worst case scenario, it is assumed it all vaporizes.
Magellan Pipeline Company, L.P. - St. Paul Terminal Potential to Emit - Equipment Fugitives
Item
Estimated No. at
Facility
VOC Emission
Factor 1
(lb/hr/component)
VOC Emissions
(lb/hr)
VOC Emissions
(ton/yr)Pump Seals (Liquid) 204 1.19E-03 0.243 1.06Flange Sets 7,594 1.80E-05 0.137 0.60Loading Rack Valves (Vapor) 24 2.90E-05 0.001 0.00Loading Rack Valves (Liquid) 364 9.50E-05 0.035 0.15Other Valves (Liquid) 1,914 2.90E-04 0.555 2.43Open-ended lines (gas) 0 6.70E-03 0 0.00
Total 0.970 4.25
Note:
Hazardous Air PollutantFraction of
VOC
Potential HAP Emissions (ton/yr)
2,2,4 Trimethylpentane 0.008 0.034Benzene 0.009 0.038Ethyl Benzene 0.001 0.004Hexane 0.016 0.068Toluene 0.013 0.055Total Xylenes 0.005 0.021
Total HAP 0.221
1. All emission factors taken from Table 2-3 of EPA Bulletin 453/R-95-017, Protocol for Equipment Leak Emission Estimates, November 1995.
Magellan Pipeline Company, L.P. - St. Paul Terminal
Potential to Emit - Facility Totals (ton/yr)
Insignificant Activity
Tanks(ton/yr)
Railcar Loading
Rack(ton/yr)
Ethanol Unloading
(ton/yr)
Butane Unloading
(ton/yr)
Biodiesel Unloading
(ton/yr)
Equipment Fugitives(ton/yr)
Total Emissions
(ton/yr)VOC 86.53 86.53 0.01 125.46 1.58 0.47 0.19 1.08 0.00 4.25 306Total Particulates NA NA 0.01 NA NA NA NA NA NA NA 0.012PM-10 NA NA 0.01 NA NA NA NA NA NA NA 0.009PM-2.5 NA NA 0.00 NA NA NA NA NA NA NA 0.003SO2 NA NA 0.00 NA NA NA NA NA NA NA 0.001CO 35.09 35.09 0.13 NA NA NA NA NA NA NA 70.3NOx 14.04 14.04 0.16 NA NA NA NA NA NA NA 28.2CO2e NA NA 190 NA NA NA NA NA NA NA 1902,2,4 Trimethylpentan 0.69 0.69 NA 1.00 0.013 0.004 0.000 NA 0.000 0.034 2.4Benzene 0.78 0.78 0.00 1.13 0.014 0.004 0.000 NA 0.000 0.038 2.7Ethyl Benzene 0.09 0.09 NA 0.13 0.002 0.000 0.000 NA 0.000 0.004 0.30Hexane 1.38 1.38 0.00 2.01 0.025 0.008 0.000 NA 0.000 0.068 4.88Toluene 1.12 1.12 0.00 1.63 0.020 0.006 0.000 NA 0.000 0.055 4.0Total Xylenes 0.43 0.43 NA 0.63 0.008 0.002 0.000 NA 0.000 0.021 1.5Total HAP 4.50 4.50 0.02 6.52 0.08 0.02 0.00 0.00 0.00 0.22 15.9
Potential to Emit - Facility Totals (lb/hr)
Insignificant Activity
Tanks(lb/hr)
Railcar Loading
Rack(lb/hr)
Ethanol Unloading
(lb/hr)
Butane Unloading
(lb/hr)
Bio-diesel Unloading
(lb/hr)
Equipment Fugitives
(lb/hr)
VOC 19.76 19.76 0.00 28.64 0.36 0.11 0.04 0.25 0.00 0.97 69.88CO 8.01 8.01 0.03 NA NA NA NA NA NA NA 16.05NOx 3.20 3.20 0.04 NA NA NA NA NA NA NA 6.45Total HAP 1.03 1.03 0.00 1.49 0.02 0.01 0.00 0.00 0.00 0.05 3.62
Total Emissions
(lb/hr)
Pollutant
MPL Loading
Rack(ton/yr)
FHR Loading
Rack(ton/yr)
Storage Tanks
(ton/yr)
Insignificant emissions sources
Pollutant
MPL Loading
Rack(lb/hr)
FHR Loading
Rack(lb/hr)
Storage Tanks(lb/hr)
Insignificant emissions sources
VCUs pilot flame
(ton/yr)
VCUs pilot flame
(ton/yr)
Agency Interest Name Subject Item ID SI Designation and Description
Magellan Pipeline CoLP - Saint PaulTerminal
ACTV3NullAll IA's
AISI1869NullNull
COMG3NullUnits Subject to NESHAP BBBBBB
EQUI19EU001Tank Truck Bottom Load - MPLw/Vapor Combustor Control
EQUI20EU002Tank Truck Bottom Load - Flint HillsResources (FHR) w/Vapor Combus..
EQUI38TK020Gasoline / 3,041,766 gallons / Tank814
EQUI40TK027Gasoline / 3,042,564 gallons / Tank822
EQUI41TK028Gasoline / 3,154,032 gallons / Tank823
EQUI49TK001Gasoline / 236,628 gallons / Tank425
EQUI50TK002Ethanol / 420,420 gallons / Tank509
EQUI51TK004Gasoline / 418,950 gallons / Tank510
EQUI52 TK003Ethanol / 656,712 gallons / Tank646
List of SIs
Agency Interest: Magellan Pipeline Co LP - Saint PaulTerminalAgency Interest ID: 1869Activity: IND20100001 (Part 70 Reissuance)
Details for:SI Category: NoneSI Type: All
Agency Interest Name Subject Item ID SI Designation and DescriptionMagellan Pipeline CoLP - Saint PaulTerminal
EQUI51
TK004Gasoline / 418,950 gallons / Tank510
EQUI52TK003Ethanol / 656,712 gallons / Tank646
EQUI53TK005Gasoline / 772,044 gallons / Tank649
EQUI54TK006Gasoline / 804,090 gallons / Tank650
EQUI55TK007Fuel Oil #2 / 1,129,842 gallons /Tank 717
EQUI56TK008Gasoline / 1,128,204 gallons / Tank718
EQUI58TK009Gasoline / 1,152,648 gallons / Tank719
EQUI59TK010Gasoline / 1,130,094 gallons / Tank720
EQUI60TK011Gasoline / 1,115,100 gallons / Tank743
EQUI61TK012Gasoline / 1,444,674 gallons / Tank745
EQUI62TK013Gasoline / 3,013,668 gallons / Tank805
EQUI63TK014Gasoline / 2,972,004 gallons / Tank806
EQUI64 TK015Gasoline / 3,013,752 gallons / Tank807
List of SIs
Agency Interest: Magellan Pipeline Co LP - Saint PaulTerminalAgency Interest ID: 1869Activity: IND20100001 (Part 70 Reissuance)
Details for:SI Category: NoneSI Type: All
Agency Interest Name Subject Item ID SI Designation and DescriptionMagellan Pipeline CoLP - Saint PaulTerminal
EQUI63
TK014Gasoline / 2,972,004 gallons / Tank806
EQUI64TK015Gasoline / 3,013,752 gallons / Tank807
EQUI65TK016Gasoline / 3,014,424 gallons / Tank808
EQUI66TK017Fuel Oil #2 / 3,297,420 gallons /Tank 809
EQUI67TK018Fuel Oil #2 / 3,296,244 gallons /Tank 810
EQUI69TK019Ethanol / 3,042,060 gallons / Tank813
EQUI70TK021Fuel Oil #2 / 3,299,310 gallons /Tank 815
EQUI71TK022Fuel Oil #2 / 3,299,856 gallons /Tank 816
EQUI72TK023Fuel Oil #2 / 3,299,394 gallons /Tank 817
EQUI73TK024Fuel Oil #2 / 3,304,056 gallons /Tank 818
EQUI74TK025Jet kerosene / 3,304,098 gallons /Tank 819
EQUI75TK026Fuel Oil #2 / 3,219,132 gallons /Tank 820
EQUI77 TK029Gasoline / 3,042,942 gallons / Tank824
List of SIs
Agency Interest: Magellan Pipeline Co LP - Saint PaulTerminalAgency Interest ID: 1869Activity: IND20100001 (Part 70 Reissuance)
Details for:SI Category: NoneSI Type: All
Agency Interest Name Subject Item ID SI Designation and DescriptionMagellan Pipeline CoLP - Saint PaulTerminal
EQUI75
TK026Fuel Oil #2 / 3,219,132 gallons /Tank 820
EQUI77TK029Gasoline / 3,042,942 gallons / Tank824
EQUI78TK030Jet kerosene / 3,304,308 gallons /Tank 825
EQUI79TK031Fuel Oil #2 / 3,303,846 gallons /Tank 826
EQUI80TK032Gasoline / 3,299,352 gallons / Tank827
EQUI81TK033Fuel Oil #2 / 3,298,596 gallons /Tank 828
EQUI82TK034Ethanol / 208,950 gallons / Tank904
FUGI1FS001Valves, Pump Seals, Flanges &Connectors.
STRU1SV001Stack/Vent
STRU2SV002Stack/Vent
STRU4NullTerminal Office
STRU5NullShop/Lab
STRU6 NullRail & Ethanol Controls
List of SIs
Agency Interest: Magellan Pipeline Co LP - Saint PaulTerminalAgency Interest ID: 1869Activity: IND20100001 (Part 70 Reissuance)
Details for:SI Category: NoneSI Type: All
Agency Interest Name Subject Item ID SI Designation and DescriptionMagellan Pipeline CoLP - Saint PaulTerminal
STRU5NullShop/Lab
STRU6NullRail & Ethanol Controls
STRU7NullWarehouse
STRU8NullRack Canopy
STRU9NullRail Canopy
STRU10NullStation
STRU11NullChange Room
STRU12NullPump Shelter
STRU13NullMPL Additive
STRU14NullFHR Additive
STRU15NullPreCard
STRU16NullStorage (Blue)
STRU17 NullStorage (Tan)
List of SIs
Agency Interest: Magellan Pipeline Co LP - Saint PaulTerminalAgency Interest ID: 1869Activity: IND20100001 (Part 70 Reissuance)
Details for:SI Category: NoneSI Type: All
Agency Interest Name Subject Item ID SI Designation and DescriptionMagellan Pipeline CoLP - Saint PaulTerminal
STRU16NullStorage (Blue)
STRU17NullStorage (Tan)
STRU18NullTech Shop - Terminal
STRU19NullMPL Driver Building
STRU20NullFHR Driver Building
STRU21NullBiodiesel Offload
TFAC112300070Magellan Pipeline Co LP - St Paul
TREA6CE001Vapor Combustion Unit (VCU)
TREA7CE002Vapor Combustion Unit (VCU)
List of SIs
Agency Interest: Magellan Pipeline Co LP - Saint PaulTerminalAgency Interest ID: 1869Activity: IND20100001 (Part 70 Reissuance)
Details for:SI Category: NoneSI Type: All
Agency Interest Na.. Activity ID Subject Ite..Subject Item Type Description Subject Item ID SI Designation and Description Status Desc..Sub Attribute Description
Magellan Pipeline CoLP - Saint PaulTerminal
IND20100001 Activity Insignificant Air Emissions Activity ACTV3 NullAll IA's
Active /Existing
Minn. R. 7007.1300, subp. 3(A)
Minn. R. 7007.1300, subp. 3(G)
Minn. R. 7007.1300, subp. 3(I)
Minn. R. 7007.1300, subp. 3(J)
Minn. R. 7007.1300, subp. 3(K)
Minn. R. 7007.1300, subp. 4
Insignificant air emissions activity
Agency Interest: Magellan Pipeline Co LP - Saint Paul TerminalAgency Interest ID: 1869Activity: IND20100001 (Part 70 Reissuance)
Details for:SI Category: ActivitySI Type: Insignificant Air Emissions Activity
Agency Interest Name Subject Item ID SI Designation and Description Group Member ID (padded)
Magellan Pipeline CoLP - Saint PaulTerminal
COMG3 NullUnits Subject to NESHAP BBBBBB
EQUI19
EQUI20
EQUI38
EQUI40
EQUI41
EQUI49
EQUI50
EQUI51
EQUI52
EQUI53
EQUI54
EQUI55
EQUI56
EQUI58
EQUI59
EQUI60
Component Group (Members)
Agency Interest: Magellan Pipeline Co LP - Saint Paul TerminalAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: Component GroupSI Type: Air Component Group
Agency Interest Name Subject Item ID SI Designation and Description Group Member ID (padded)Magellan Pipeline CoLP - Saint PaulTerminal
COMG3 NullUnits Subject to NESHAP BBBBBB
EQUI59
EQUI60
EQUI61
EQUI62
EQUI63
EQUI64
EQUI65
EQUI69
EQUI77
EQUI80
TREA6
TREA7
Component Group (Members)
Agency Interest: Magellan Pipeline Co LP - Saint Paul TerminalAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: Component GroupSI Type: Air Component Group
Subject ItemCategory Description
Subject Item TypeDescription Subject Item ID
Subject ItemDesignation Subject Item Description Pollutant
Potential (lbs/hr)
Unrestricted Potential
(tons/yr)
Potential Limited
(tons/yr)
Actual Emissions
(tons/yr)
Equipment Aboveground StorageTank
EQUI38 TK020 Gasoline / 3,041,766gallons / Tank 814
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI40 TK027 Gasoline / 3,042,564gallons / Tank 822
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI41 TK028 Gasoline / 3,154,032gallons / Tank 823
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI49 TK001 Gasoline / 236,628 gallons/ Tank 425
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI50 TK002 Ethanol / 420,420 gallons/ Tank 509
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI51 TK004 Gasoline / 418,950 gallons/ Tank 510
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI52 TK003 Ethanol / 656,712 gallons/ Tank 646
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI53 TK005 Gasoline / 772,044 gallons/ Tank 649
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI54 TK006 Gasoline / 804,090 gallons/ Tank 650
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI55 TK007 Fuel Oil #2 / 1,129,842gallons / Tank 717
2,2,4-trimethylpentane
Benzene
0.04498.9770.11670.14360.0090.08080.0718
0.04498.9770.11670.14360.0090.08080.0718
0.01022.05
0.02660.03280.0020.01840.0164
0.059211.8410.15390.18950.01180.10660.0947
0.059211.8410.15390.18950.01180.10660.0947
0.01352.7030.03510.04330.00270.02430.0216
0.04589.1540.1190.14650.00920.08240.0732
0.04589.1540.1190.14650.00920.08240.0732
0.01042.09
0.02720.03340.00210.01880.0167
0.00420.8390.01090.01340.00080.00750.0067
0.00420.8390.01090.01340.00080.00750.0067
0.0010.1910.00250.00310.00020.00170.0015
0.0081.5920.02070.02550.00160.01430.0127
0.0081.5920.02070.02550.00160.01430.0127
0.00180.3630.00470.00580.00040.00330.0029
0.00831.6530.02150.02640.00170.01490.0132
0.00831.6530.02150.02640.00170.01490.0132
0.00190.3770.00490.0060.00040.00340.003
0.00951.8910.02460.03030.00190.0170.0151
0.00951.8910.02460.03030.00190.0170.0151
0.00220.4320.00560.00690.00040.00390.0035
0.00911.8140.02360.0290.00180.01630.0145
0.00911.8140.02360.0290.00180.01630.0145
0.00210.4140.00540.00660.00040.00370.0033
0.00911.83
0.02380.02930.00180.01650.0146
0.00911.83
0.02380.02930.00180.01650.0146
0.00210.4180.00540.00670.00040.00380.0033
0.0190.0190.0043
PTE by subject item
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: AllSI Type: All
Subject ItemCategory Description
Subject Item TypeDescription Subject Item ID
Subject ItemDesignation Subject Item Description Pollutant
Potential (lbs/hr)
Unrestricted Potential
(tons/yr)
Potential Limited
(tons/yr)
Actual Emissions
(tons/yr)
Equipment Aboveground StorageTank
EQUI55 TK007 Fuel Oil #2 / 1,129,842gallons / Tank 717
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI56 TK008 Gasoline / 1,128,204gallons / Tank 718
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI58 TK009 Gasoline / 1,152,648gallons / Tank 719
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI59 TK010 Gasoline / 1,130,094gallons / Tank 720
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI60 TK011 Gasoline / 1,115,100gallons / Tank 743
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI61 TK012 Gasoline / 1,444,674gallons / Tank 745
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI62 TK013 Gasoline / 3,013,668gallons / Tank 805
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI63 TK014 Gasoline / 2,972,004gallons / Tank 806
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI64 TK015 Gasoline / 3,013,752gallons / Tank 807
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI65 TK016 Gasoline / 3,014,424gallons / Tank 808
2,2,4-trimethylpentane
Benzene
Ethylbenzene
0.01192.38
0.03090.03810.00240.0214
0.01192.38
0.03090.03810.00240.0214
0.00270.5430.00710.00870.00050.0049
0.01192.38
0.03090.03810.00240.02140.019
0.01192.38
0.03090.03810.00240.02140.019
0.00270.5430.00710.00870.00050.00490.0043
0.01192.38
0.03090.03810.00240.02140.019
0.01192.38
0.03090.03810.00240.02140.019
0.00270.5430.00710.00870.00050.00490.0043
0.01192.38
0.03090.03810.00240.02140.019
0.01192.38
0.03090.03810.00240.02140.019
0.00270.5430.00710.00870.00050.00490.0043
0.01192.3780.03090.03810.00240.02140.019
0.01192.3780.03090.03810.00240.02140.019
0.00270.5430.00710.00870.00050.00490.0043
0.01212.4230.03150.03880.00240.02180.0194
0.01212.4230.03150.03880.00240.02180.0194
0.00280.5530.00720.00880.00060.0050.0044
0.0214.1950.05450.06710.00420.03780.0336
0.0214.1950.05450.06710.00420.03780.0336
0.00480.9580.01250.01530.0010.00860.0077
0.02124.2420.05510.06790.00420.03820.0339
0.02124.2420.05510.06790.00420.03820.0339
0.00480.9690.01260.01550.0010.00870.0077
0.02094.1840.05440.06690.00420.03770.0335
0.02094.1840.05440.06690.00420.03770.0335
0.00480.9550.01240.01530.0010.00860.0076
0.03820.034
0.03820.034
0.00870.0078
PTE by subject item
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: AllSI Type: All
Subject ItemCategory Description
Subject Item TypeDescription Subject Item ID
Subject ItemDesignation Subject Item Description Pollutant
Potential (lbs/hr)
Unrestricted Potential
(tons/yr)
Potential Limited
(tons/yr)
Actual Emissions
(tons/yr)
Equipment Aboveground StorageTank
EQUI65 TK016 Gasoline / 3,014,424gallons / Tank 808
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI66 TK017 Fuel Oil #2 / 3,297,420gallons / Tank 809
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI67 TK018 Fuel Oil #2 / 3,296,244gallons / Tank 810
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI69 TK019 Ethanol / 3,042,060gallons / Tank 813
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI70 TK021 Fuel Oil #2 / 3,299,310gallons / Tank 815
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI71 TK022 Fuel Oil #2 / 3,299,856gallons / Tank 816
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI72 TK023 Fuel Oil #2 / 3,299,394gallons / Tank 817
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI73 TK024 Fuel Oil #2 / 3,304,056gallons / Tank 818
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI74 TK025 Jet kerosene / 3,304,098gallons / Tank 819
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI75 TK026 Fuel Oil #2 / 3,219,132gallons / Tank 820
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
0.02124.2460.05520.06790.0042
0.02124.2460.05520.06790.0042
0.00480.9690.01260.01550.001
0.00731.4520.01890.02320.00150.01310.0116
0.00731.4520.01890.02320.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.00731.4520.01890.02320.00150.01310.0116
0.00731.4520.01890.02320.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.054410.8720.14130.1740.01090.09790.087
0.054410.8720.14130.1740.01090.09790.087
0.01242.4820.03230.03970.00250.02230.0199
0.00731.4530.01890.02320.00150.01310.0116
0.00731.4530.01890.02320.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.00731.4530.01890.02320.00150.01310.0116
0.00731.4530.01890.02320.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.00731.4530.01890.02320.00150.01310.0116
0.00731.4530.01890.02320.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.00731.4530.01890.02330.00150.01310.0116
0.00731.4530.01890.02330.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.00731.4530.01890.02330.00150.01310.0116
0.00731.4530.01890.02330.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.00140.0130.0115
0.00140.0130.0115
0.00030.0030.0026
PTE by subject item
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: AllSI Type: All
Subject ItemCategory Description
Subject Item TypeDescription Subject Item ID
Subject ItemDesignation Subject Item Description Pollutant
Potential (lbs/hr)
Unrestricted Potential
(tons/yr)
Potential Limited
(tons/yr)
Actual Emissions
(tons/yr)
Equipment Aboveground StorageTank
EQUI75 TK026 Fuel Oil #2 / 3,219,132gallons / Tank 820
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI77 TK029 Gasoline / 3,042,942gallons / Tank 824
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI78 TK030 Jet kerosene / 3,304,308gallons / Tank 825
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI79 TK031 Fuel Oil #2 / 3,303,846gallons / Tank 826
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI80 TK032 Gasoline / 3,299,352gallons / Tank 827
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI81 TK033 Fuel Oil #2 / 3,298,596gallons / Tank 828
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI82 TK034 Ethanol / 208,950 gallons/ Tank 904
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
Loading-UnloadingEquipment
EQUI19 EU001 Tank Truck Bottom Load -MPL w/Vapor CombustorControl
2,2,4-trimethylpentane
Benzene
Carbon Monoxide
Ethylbenzene
Hexane
Nitrogen Oxides
Toluene
Volatile Organic Compoun..
Xylenes, Total
EQUI20 EU002 Tank Truck Bottom Load -Flint Hills Resources (FHR)w/Vapor CombustorControl
2,2,4-trimethylpentane
Benzene
Carbon Monoxide
Ethylbenzene
Hexane
Nitrogen Oxides
Toluene
Volatile Organic Compoun..
Xylenes, Total
2,2,4-trimethylpentane
0.00721.4410.01870.0231
0.00721.4410.01870.0231
0.00160.3290.00430.0053
0.059211.8410.15390.18950.01180.10660.0947
0.059211.8410.15390.18950.01180.10660.0947
0.01352.7030.03510.04330.00270.02430.0216
0.00731.4530.01890.02330.00150.01310.0116
0.00731.4530.01890.02330.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.00731.4530.01890.02330.00150.01310.0116
0.00731.4530.01890.02330.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.04579.1460.11890.14630.00910.08230.0732
0.04579.1460.11890.14630.00910.08230.0732
0.01042.0880.02710.03340.00210.01880.0167
0.00731.4520.01890.02320.00150.01310.0116
0.00731.4520.01890.02320.00150.01310.0116
0.00170.3320.00430.00530.00030.0030.0027
0.03436.8510.08910.10960.00690.06170.0548
0.03436.8510.08910.10960.00690.06170.0548
0.00781.5640.02030.0250.00160.01410.0125
0.4326486.52731.1248614.036311.384440.0865335.09070.778750.6922
8.405031,681.00621.8530714.0363126.896091.6810135.090715.1290513.44804
0.0987819.75510.256823.20640.316080.019768.0160.17780.158
0.4326486.52731.1248614.03631.384440.0865335.09070.778750.69222
8.405031,681.00621.8530714.036326.896091.6810135.090715.1290513.44804
0.0987819.75510.256823.206
0.316080.019768.0160.17780.15804
PTE by subject item
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: AllSI Type: All
Subject ItemCategory Description
Subject Item TypeDescription Subject Item ID
Subject ItemDesignation Subject Item Description Pollutant
Potential (lbs/hr)
Unrestricted Potential
(tons/yr)
Potential Limited
(tons/yr)
Actual Emissions
(tons/yr)
EquipmentLoading-UnloadingEquipment EQUI20 EU002
Tank Truck Bottom Load -Flint Hills Resources (FHR)w/Vapor CombustorControl Xylenes, Total
Fugitive Equipment Leaks FUGI1 FS001 Valves, Pump Seals,Flanges & Connectors.
2,2,4-trimethylpentane
Benzene
Ethylbenzene
Hexane
Toluene
Volatile Organic Compoun..
Xylenes, Total
Treatment 099-Other TREA6 CE001 Vapor Combustion Unit(VCU)
Benzene
Carbon Dioxide
Carbon Dioxide Equivalent
Carbon Monoxide
HAPs - Total
Hexane
Methane
Nitrogen Oxides
Nitrous Oxide
Particulate Matter
PM < 2.5 micron
PM < 10 micron
Sulfur Dioxide
Toluene
Volatile Organic Compoun..
TREA7 CE002 Vapor Combustion Unit(VCU)
Benzene
Carbon Dioxide
Carbon Dioxide Equivalent
Carbon Monoxide
HAPs - Total
Hexane
Methane
Nitrogen Oxides
Nitrous Oxide
Particulate Matter
PM < 2.5 micron
PM < 10 micron
Sulfur Dioxide
Toluene
Volatile Organic Compoun..
0.021244.247670.055220.067960.004250.038230.03398
0.021244.247670.055220.067960.004250.038230.03398
0.004850.969790.012610.015520.000970.008730.00776
0.00432.68e-060.00050.00450.00150.006
0.0017340.07880.001810.0014190.008890.066295.1794.61
1.65e-06
0.00432.68e-060.00050.00450.00150.006
0.0017340.07880.001810.0014190.008890.066295.1794.61
1.65e-06
0.0016.12e-070.00010.0010.00030.0014
0.0003960.018
0.000410.0003240.002030.015121.72821.6
3.78e-07
0.00432.68e-060.00050.00450.00150.006
0.0017340.07880.001810.001420.008890.066295.1794.61
1.65e-06
0.00432.68e-060.00050.00450.00150.006
0.0017340.07880.001810.001420.008890.066295.1794.61
1.65e-06
0.0016.12e-070.00010.0010.00030.0014
0.0003960.018
0.000410.0003240.002030.015121.72821.6
3.78e-07
PTE by subject item
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: AllSI Type: All
Subject ItemCategoryDescription
Subject Item TypeDescription Subject Item ID SI Designation and Description Relationship
Related SubjectItem ID % Flow
Related Subject ItemType Description
Start Date (RelatedSubject Item)
End Date (RelatedSubject Item)
Equipment Loading-UnloadingEquipment
EQUI19 EU001Tank Truck Bottom Load - MPLw/Vapor Combustor Control
is controlledby
TREA6 100 099-Other 1/12/1998 Null
sends to STRU1 100 Stack/Vent 1/12/1998 Null
EQUI20 EU002Tank Truck Bottom Load - Flint HillsResources (FHR) w/Vapor CombustorControl
is controlledby
TREA7 100 099-Other 1/12/1998 Null
sends to STRU2 100 Stack/Vent 1/12/1998 Null
SI - SI relationships
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: EquipmentSI Type: Loading-Unloading Equipment
Subject ItemTypeDescription Subject Item ID SI Designation and Description Capacity (gal)Substance Stored
ColumnDiameter (ft)
Number ofColumns Deck Type
InteriorDiameter (ft)
InteriorHeight (ft)
MaximumTrue VaporPressure(psia)
ConstructionType Seal Type Support Type
AbovegroundStorage Tank
EQUI38TK020Gasoline / 3,041,766 gallons / T..
3041766Gasoline Blends(E1-E49)
1 16Bolted, detailsnot specified
120 40 11InternalFloating Roof
Resilient; vapormounted primary only
Column, constructiontype not specified
EQUI40TK027Gasoline / 3,042,564 gallons / T..
3042564Gasoline Blends(E1-E49)
1 16Bolted, detailsnot specified
120 40 11InternalFloating Roof
Resilient; vapormounted primary only
Column, constructiontype not specified
EQUI41TK028Gasoline / 3,154,032 gallons / T..
3154032Gasoline Blends(E1-E49)
1 16 Welded 120 40 11InternalFloating Roof
Mechanical; primaryseal only
Column, constructiontype not specified
EQUI49TK001Gasoline / 236,628 gallons / Tan..
236628Gasoline Blends(E1-E49)
Null Null Welded 33 37 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI50TK002Ethanol / 420,420 gallons / Tan..
420420 Other Null Null Welded 48 35 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI51TK004Gasoline / 418,950 gallons / Tan..
418950Gasoline Blends(E1-E49)
Null Null Welded 48 35 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI52TK003Ethanol / 656,712 gallons / Tan..
656712 Other Null Null Welded 60 35 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI53TK005Gasoline / 772,044 gallons / Tan..
772044Gasoline Blends(E1-E49)
Null Null Welded 60 40 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI54TK006Gasoline / 804,090 gallons / Tan..
804090Gasoline Blends(E1-E49)
Null Null Welded 60 40 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI55TK007Fuel Oil #2 / 1,129,842 gallons /..
1129842 Other Null Null Welded 78 35 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI56TK008Gasoline / 1,128,204 gallons / T..
1128204Gasoline Blends(E1-E49)
Null Null Welded 78 35 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI58TK009Gasoline / 1,152,648 gallons / T..
1152648Gasoline Blends(E1-E49)
Null Null Welded 78 35 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI59TK010Gasoline / 1,130,094 gallons / T..
1130094Gasoline Blends(E1-E49)
Null Null Welded 78 35 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI60TK011Gasoline / 1,115,100 gallons / T..
1115100Gasoline Blends(E1-E49)
Null Null Welded 78 35 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI61TK012Gasoline / 1,444,674 gallons / T..
1444674Gasoline Blends(E1-E49)
Null Null Welded 82 40 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI62TK013Gasoline / 3,013,668 gallons / T..
3013668Gasoline Blends(E1-E49)
Null Null Welded 120 40 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI63TK014Gasoline / 2,972,004 gallons / T..
2972004Gasoline Blends(E1-E49)
Null Null Welded 120 40 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI64TK015Gasoline / 3,013,752 gallons / T..
3013752Gasoline Blends(E1-E49)
Null Null Welded 120 40 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI65TK016Gasoline / 3,014,424 gallons / T..
3014424Gasoline Blends(E1-E49)
Null Null Welded 120 40 11InternalFloating Roof
Mechanical; primaryseal only
Self, fixed roof w/ointernal columns
EQUI66TK017Fuel Oil #2 / 3,297,420 gallons /..
3297420 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI67TK018Fuel Oil #2 / 3,296,244 gallons /..
3296244 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI69TK019Ethanol / 3,042,060 gallons / Ta..
3042060 Other 1 11Bolted, detailsnot specified
120 40 11InternalFloating Roof
Resilient; vapormounted primary only
Column, constructiontype not specified
EQUI70TK021Fuel Oil #2 / 3,299,310 gallons /..
3299310 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI71TK022Fuel Oil #2 / 3,299,856 gallons /..
3299856 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI72TK023Fuel Oil #2 / 3,299,394 gallons /..
3299394 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI73TK024Fuel Oil #2 / 3,304,056 gallons /..
3304056 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI74TK025Jet kerosene / 3,304,098 gallon..
3304098Jet Fuel(unspecified)
Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI75TK026Fuel Oil #2 / 3,219,132 gallons /..
3219132 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI77TK029Gasoline / 3,042,942 gallons / T..
3042942Gasoline Blends(E1-E49)
1 16Bolted, detailsnot specified
120 40 11InternalFloating Roof
Resilient; vapormounted primary only
Column, constructiontype not specified
EQUI78TK030Jet kerosene / 3,304,308 gallon..
3304308Jet Fuel(unspecified)
Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI79TK031Fuel Oil #2 / 3,303,846 gallons /..
3303846 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI80TK032Gasoline / 3,299,352 gallons / T..
3299352Gasoline Blends(E1-E49)
1 16 Welded 120 40 11InternalFloating Roof
Mechanical; primaryseal only
Column, constructiontype not specified
EQUI81TK033Fuel Oil #2 / 3,298,596 gallons /..
3298596 Other Null Null Null 120 40 0.1 Fixed Roof Null Null
EQUI82TK034Ethanol / 208,950 gallons / Tan..
208950Ethanol (EthylAlcohol)
Null Null Null 41 27 11 Other Null Null
Aboveground Storage Tanks, General
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: EquipmentSI Type: Aboveground Storage Tank
Subject ItemTypeDescription Subject Item ID SI Designation and Description Manufacturer Model
Max DesignCapacity
Max DesignCapacityUnits(numerator)
Max DesignCapacity Units(denominator) Material
ConstructionStart Date
OperationStart Date
ModificationDate
Loading-UnloadingEquipment
EQUI19EU001Tank Truck Bottom Load - MPL w/VaporCombustor Control
John Zink GV-ZTOF-8500-296000 gallons hours Diesel Fuel 12/12/1994 5/23/1995 Null
EQUI20EU002Tank Truck Bottom Load - Flint HillsResources (FHR) w/Vapor Combustor Cont..
John Zink GV-ZTOF-8500-296000 gallons hours Diesel Fuel 5/16/1994 1/9/1995 Null
Emission Units 1
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: NoneSI Type: Loading-Unloading Equipment
Subject Item TypeDescription Subject Item ID SI Designation and Description Install Year Pollutants Emitted
Equipment Leaks FUGI1FS001Valves, Pump Seals, Flanges & Connectors.
1940 Volatile Organic Compounds
Fugitive Sources
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: FugitiveSI Type: Equipment Leaks
Subject ItemTypeDescription Subject Item ID SI Designation and Description Height
Units(height) Length
Units(length) Width
Units(width)
Building STRU4NullTerminal Office
15 feet 105 feet 40 feet
STRU5NullShop/Lab
21 feet 87 feet 28 feet
STRU6NullRail & Ethanol Controls
10 feet 36 feet 24 feet
STRU7NullWarehouse
10 feet 110 feet 36 feet
STRU8NullRack Canopy
20 feet 106 feet 50 feet
STRU9NullRail Canopy
21 feet 78 feet 55 feet
STRU10NullStation
12 feet 40 feet 20 feet
STRU11NullChange Room
12 feet 20 feet 20 feet
STRU12NullPump Shelter
10 feet 20 feet 15 feet
STRU13NullMPL Additive
10 feet 24 feet 12 feet
STRU14NullFHR Additive
10 feet 24 feet 12 feet
STRU15NullPreCard
7 feet 10 feet 12 feet
STRU16NullStorage (Blue)
14 feet 40 feet 30 feet
STRU17NullStorage (Tan)
10 feet 20 feet 16 feet
STRU18NullTech Shop - Terminal
10 feet 20 feet 16 feet
STRU19NullMPL Driver Building
10 feet 40 feet 12 feet
STRU20NullFHR Driver Building
10 feet 35 feet 12 feet
STRU21NullBiodiesel Offload
8 feet 6 feet 4 feet
Buildings, General
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: StructureSI Type: Building
Subject ItemTypeDescription Subject Item ID SI Designation and Description
Stack Height(feet)
StackDiameter(feet)
Stack Length(feet)
Stack Width(feet)
Stack Flow Rate(cubic ft/min)
DischargeTemperature(°F)
FlowRate/TempInformationSource Discharge Direction
Stack/Vent STRU1SV001Stack/Vent
45 7.5 Null Null 1136 1400 EstimateUpwards with no cap onstack/vent
STRU2SV002Stack/Vent
45 7.5 Null Null 1136 1400 EstimateUpwards with no cap onstack/vent
Stack/Vent, General
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: StructureSI Type: Stack/Vent
Subject ItemTypeDescription Subject Item ID SI Designation and Description Manufacturer Model
InstallationStart Date
PollutantControlled
CaptureEfficiency(%)
Destruction CollectEfficiency (%)
Subject toCAM?
Large orOther PSEU?
EfficiencyBasis
Otheroperatingparameters?
Other operatingparametersdescription
099-Other TREA6CE001Vapor Combustion Unit (VCU)
John Zink GT-ZTO..1/1/1990Volatile OrganicCompounds
98.7 92 Yes Other Test data No Null
TREA7CE002Vapor Combustion Unit (VCU)
John Zink GT-ZTO..1/1/1994Volatile OrganicCompounds
98.7 97 Yes Other Test data No Null
Other Control Equipment
Agency Interest: NoneAgency Interest ID: 1869Activity: None (Part 70 Reissuance)
Details for:SI Category: TreatmentSI Type: 099-Other
Subject Item ID Seq. # Requirement Citation
TFAC 1
(12300070) 1
Permit Appendix: This permit contains an appendix as listed in the permit Table of Contents. The
Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities and General
Applicable Requirements. Minn. R. 7007.0800, subp. 2
TFAC 1
(12300070) 2
PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this
permit shall be deemed compliance with the specific provision of the applicable requirement identified in
the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100,
subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable
requirements, any person (including the Permittee) may also use other credible evidence to establish
compliance or noncompliance with applicable requirements.
This permit shall not alter or affect the liability of the Permittee for any violation of applicable
requirements prior to or at the time of permit issuance. Minn. R. 7007.1800, (A)(2)
TFAC 1
(12300070) 3
These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists
that a proposed project, analyzed using the actual‐to‐projected‐actual (ATPA) test (either by itself or as
part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may
result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no
RP that the proposed project could result in a SEI, these requirements do not apply to that project. The
Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP
occurs only within the meaning of Sec on 52.21(r)(6)(vi)(b).
Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP
that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still
be required by Minn. R. 7007.1150 ‐ 7007.1500.
Minn. R. 7007.0800, subp. 2,
Title I Condition: 40 CFR
52.21(r)(6) and Minn. R.
7007.3000
TFAC 1
(12300070) 5
Preconstruction Documentation ‐‐ Before beginning actual construction on a project, the Permittee shall
document the following:
1. Project descrip on
2. Iden fica on of any emission unit whose emissions of an NSR pollutant could be affected
3. Pre‐change potential emissions of any affected existing emission unit, and the projected post‐change
poten al emissions of any affected exis ng or new emission unit.
4. A description of the applicability test used to determine that the project is not a major modification for
any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the
amount of emissions excluded due to increases not associated with the modification and that the
emission unit could have accommodated during the baseline period, an explanation of why the amounts
were excluded, and any creditable contemporaneous increases and decreases that were considered in the
determina on.
The Permittee shall maintain records of this documentation.
Minn. R. 7007.0800, subps. 4‐5,
Minn. R. 7007.1200, subp. 4,
Title I Condition: 40 CFR
52.21(r)(6) and Minn. R.
7007.3000
TFAC 1
(12300070) 9
The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a
result of the project and that were analyzed using the ATPA test, and the potential emissions of any
regulated NSR pollutant that could increase as a result of the project and that were analyzed using
potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of
the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant,
in tons per year on a calendar year basis, for a period of 5 years following resumption of regular
operations after the change, or for a period of 10 years following resumption of regular operations after
the change if the project increases the design capacity of or potential to emit of any unit associated with
the project.
Minn. R. 7007.0800, subps. 4‐5,
Title I Condition: 40 CFR
52.21(r)(6) and Minn. R.
7007.3000
TFAC 1
(12300070) 10
The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in
hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions
by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the
Agency within 60 days a er the end of the year in which the exceedances occur. The report shall contain:
a. The name and ID number of the Facility, and the name and telephone number of the Facility contact
person.
b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid
test) for each pollutant for which the preconstruction projection and significant emissions increase are
exceeded
c. Any other information, such as an explanation as to why the summed emissions differ from the
preconstruction projection.
Minn. R. 7007.0800, subps. 4‐5,
Title I Condition: 40 CFR
52.21(r)(6) and Minn. R.
7007.3000
Subject Item ID Seq. # Requirement Citation
TFAC 1
(12300070) 11
The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR
pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance
shall be demonstrated upon written request by the MPCA.
Minn. R. 7007.0100, subp. 7(A),
7(L), & 7(M), Minn. R.
7007.0800, subp. 4, Minn. R.
7007.0800, subps. 1‐2, Minn. R.
7009.0010‐7009.0080, Minn.
Stat. 116.07, subd. 4a, Minn.
Stat. 116.07, subd. 9
TFAC 1
(12300070) 12
Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would
otherwise violate a federal or state air pollution control rule, without reducing the total amount of
pollutant emitted. Minn. R. 7011.0020
TFAC 1
(12300070) 16
Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding
process equipment and emission units are operated.
Minn. R. 7007.0800, subp. 16(J),
Minn. R. 7007.0800, subp. 2
TFAC 1
(12300070) 17
Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for
all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control
equipment and control practices and shall include a preventative maintenance program for the
equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to
be taken to restore the equipment and practices to proper operation to meet applicable permit
conditions, a description of the employee training program for proper operation and maintenance of the
control equipment and practices, and the records kept to demonstrate plan implementation.
Minn. R. 7007.0800, subp. 14,
Minn. R. 7007.0800, subp. 16(J)
TFAC 1
(12300070) 18
Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all
practical steps to modify operations to reduce the emission of any regulated air pollutant. The
Commissioner may require feasible and practical modifications in the operation to reduce emissions of air
pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process
or control equipment shall be permitted to operate. Minn. R. 7019.1000, subp. 4
TFAC 1
(12300070) 19
Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a
manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all
other requirements listed in Minn. R. 7011.0150. Minn. R. 7011.0150
TFAC 1
(12300070) 20
Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080
at all times during the operation of any emission units. This is a state only requirement and is not
enforceable by the EPA Administrator or citizens under the Clean Air Act. Minn. R. 7030.0010‐7030.0080
TFAC 1
(12300070) 21
Inspections: The Permittee shall comply with the inspection procedures and requirements as found in
Minn. R. 7007.0800, subp. 9(A). Minn. R. 7007.0800, subp. 9(A)
TFAC 1
(12300070) 22 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16
TFAC 1
(12300070) 23
Emergency Provisions: The affirmative defense of emergency shall be demonstrated through properly
signed, contemporaneous operating logs and other relevant data in accordance with Minn. R. 7007.1850. Minn. R. 7007.1850
TFAC 1
(12300070) 24
Monitoring Equipment Calibra on ‐ The Permi ee shall either:
1. Calibrate or replace required monitoring equipment every 12 months; or
2. Calibrate at the frequency stated in the manufacturer's specifica ons.
For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted,
and any corrective action that resulted. The Permittee shall include the calibration frequencies,
procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any
requirements applying to continuous emission monitors are listed separately in this permit. Minn. R. 7007.0800, subp. 4(D)
TFAC 1
(12300070) 25
Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or
control equipment connected to that process is not necessary during periods when the process is
shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span
adjustments. If monitoring records are required, they should reflect any such periods of process shutdown
or checks of the monitoring system. Minn. R. 7007.0800, subp. 4(D)
TFAC 1
(12300070) 26
Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit,
for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which
must be retained at this location include all calibration and maintenance records, all original recordings
for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must
conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Minn. R. 7007.0800, subp. 5(C)
TFAC 1
(12300070) 27
Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R.
7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2),
including records of the emissions resulting from those changes. Minn. R. 7007.0800, subp. 5(B)
Subject Item ID Seq. # Requirement Citation
TFAC 1
(12300070) 28
If the Permittee determines that no permit amendment or agency notification is required prior to making
a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For
expiring permits, these records shall be kept for a period of five years from the date the change was made
or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the
current calendar year of operation and may be kept at the stationary source or office of the stationary
source for all other years. The records may be maintained in either electronic or paper format. Minn. R. 7007.1200, subp. 4
TFAC 1
(12300070) 29
Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless
otherwise noted in this permit. Minn. R. ch. 7017
TFAC 1
(12300070) 33
Performance Test No fica ons and Submi als:
Performance Test No fica on and Plan: due 30 days before each Performance Test
Performance Test Pre‐test Mee ng: due 7 days before each Performance Test
Performance Test Report: due 45 days a er each Performance Test
The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner.
Minn. R. 7017.2017, Minn. R.
7017.2030, subps. 1‐4, Minn. R.
7017.2035, subps. 1‐2
TFAC 1
(12300070) 36
Limits set as a result of a performance test (conducted before or after permit issuance) apply until
superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval.
Preliminary approval is based on formal review of a subsequent performance test on the same unit as
specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment
incorporating the change. Minn. R. 7017.2025, subp. 3
TFAC 1
(12300070) 37
The Permittee shall submit an application for permit reissuance : Due 180 calendar days before Permit
Expiration Date. Minn. R. 7007.0400, subp. 2
TFAC 1
(12300070) 38
Application for Permit Amendment: If a permit amendment is needed, submit an application in
accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates
vary, depending on the type of amendment needed.
Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years
remaining in the permit term, the Permittee shall file an application for an amendment within nine
months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3.
Minn. R. 7007.0400, subp. 3,
Minn. R. 7007.1150 ‐ 7007.1500
TFAC 1
(12300070) 39
Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a
permit by no more than 120 days, provided the proposed deadline extension meets the requirements of
Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt.
60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions
and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). Minn. R. 7007.1400, subp. 1(H)
TFAC 1
(12300070) 40
Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of
any control equipment or process equipment if the shutdown would cause any increase in the emissions
of any regulated air pollutant. If the owner or operator does not have advance knowledge of the
shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown.
However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R.
7019.1000, subp. 3.
At the time of notification, the owner or operator shall inform the Commissioner of the cause of the
shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the
shutdown is over. Minn. R. 7019.1000, subp. 3
TFAC 1
(12300070) 41
Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour
duration of any control equipment or process equipment if the breakdown causes any increase in the
emissions of any regulated air pollutant. The 24‐hour time period starts when the breakdown was
discovered or reasonably should have been discovered by the owner or operator. However, notification is
not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.
At the time of notification or as soon as possible thereafter, the owner or operator shall inform the
Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall
notify the Commissioner when the breakdown is over. Minn. R. 7019.1000, subp. 2
TFAC 1
(12300070) 42
Notification of Deviations Endangering Human Health or the Environment: As soon as possible after
discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation
from permit conditions which could endanger human health or the environment. Minn. R. 7019.1000, subp. 1
Subject Item ID Seq. # Requirement Citation
TFAC 1
(12300070) 43
Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days
of discovery, notify the Commissioner in writing of any deviation from permit conditions which could
endanger human health or the environment. Include the following informa on in this wri en descrip on:
1. the cause of the devia on;
2. the exact dates of the period of the devia on, if the devia on has been corrected;
3. whether or not the devia on has been corrected;
4. the an cipated me by which the devia on is expected to be corrected, if not yet corrected; and
5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7019.1000, subp. 1
TFAC 1
(12300070) 45
The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and
July The first semiannual report submitted by the Permittee shall cover the calendar half‐year in which the
permit is issued. The first report of each calendar year covers January 1 ‐ June 30. The second report of
each calendar year covers July 1 ‐ December 31. If no deviations have occurred, the Permittee shall submit
the report stating no deviations.
Minn. R. 7007.0800, subp.
6(A)(2)
TFAC 1
(12300070) 47
The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the
previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the
Commissioner. This report covers all deviations experienced during the calendar year. Minn. R. 7007.0800, subp. 6(C)
TFAC 1
(12300070) 48
Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance.
Submit in a format specified by the Commissioner. Minn. R. 7019.3000‐7019.3100
TFAC 1
(12300070) 49 Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R. 7002.0005‐7002.0095
COMG 3
1
This facility meets the definition of an existing bulk gasoline terminal: a gasoline storage and distribution
facility that receives gasoline by pipeline and has a gasoline throughput of 20,000 gallons per day or
greater. Gasoline throughput shall be the maximum calculated design throughput as defined at 40 CFR
Section 63.11100. The Permittee shall comply with the following standards in 40 CFR pt. 63, subp.
BBBBBB.
40 CFR 63.11081(a)(1), 40 CFR
63.11082(d)
COMG 3
2
40 CFR pt. 63, subp. BBBBBB is an Applicable Requirement under Minn. R. 7007.0100, subp. 7(D);
however, this standard is not delegated to MPCA. Minn. R. 7007.0100, subp. 7(D)
COMG 3
3
For each gasoline storage tank with a capacity of greater than or equal to 75 cubic meters, the Permittee
must:
(1) Equip each internal floating roof gasoline storage tank according to the requirements in 40 CFR Section
60.112b(a)(1), except for the secondary seal requirements under 40 CFR Section 60.112b(a)(1)(ii)(B) and
the requirements in 40 CFR Sec on 60.112b(a)(1)(iv) through (ix); AND
(2) Equip each external floating roof gasoline storage tank according to the requirements in 40 CFR Section
60.112b(a)(2), except that the requirements of 40 CFR Section 60.112b(a)(2)(ii) shall only be required if
such storage tank does not currently meet the requirements of 40 CFR Sec on 60.112b(a)(2)(i); OR
(3) Equip and operate each internal and external floating roof gasoline storage tank according to the
applicable requirements in 40 CFR Section 63.1063(a)(1) and (b), except for the secondary seal
requirements under 40 CFR Section 63.1063(a)(1)(I)(C) and (D), and equip each external floating roof
gasoline storage tank according to the requirements of 40 CFR Section 63.1063(a)(2) if such storage tank
does not currently meet the requirements of 40 CFR Sec on 63.1063(a)(1).
For any gasoline storage tanks with a capacity of greater than or equal to 75 cubic meters equipped with
floating roofs that do not meet the requirements of 40 CFR Section 63.11087(a), the Permittee shall
ensure that the storage tanks are in compliance at the first degassing and cleaning activity after January
10, 2011, or by January 10, 2018, whichever is first. The Permittee shall submit final verification of control
equipment for affected tanks prior to January 10, 2018.
40 CFR 63.11087(a), 40 CFR
63.11087(b)
COMG 3
4
For each gasoline surge control tank, the Permittee shall equip each with a fixed roof that is mounted to
the tank in a stationary manner and with a pressure/vacuum vent with a positive cracking pressure of no
less than 0.50 inches of water. Maintain all openings in a closed position at all times when not in use. 40 CFR 63.11087(a)
Subject Item ID Seq. # Requirement Citation
COMG 3
5
For all gasoline loading rack(s), the Permi ee shall:
(a) Equip the loading rack(s) with a vapor collection system designed to collect the TOC vapors displaced
from cargo tanks during product loading;
(b) Reduce emissions of TOC to less than or equal to 80 mg/l of gasoline loaded into gasoline cargo tanks
at the loading rack;
(c) Design and operate the vapor collection system to prevent any TOC vapors collected at one loading
rack from passing to another loading rack; and
(d) Limit the loading of gasoline into gasoline cargo tanks that are vapor tight using the procedures
specified in 40 CFR Section 60.502(e) through (j). For the purposes of this item, the term "tank truck" as
used in 40 CFR Section 60.502(e) through (j) means "cargo tank" as defined in 40 CFR Section 63.11100. 40 CFR 63.11088(a)
COMG 3
7
Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or
process to conceal an emission that would otherwise constitute noncompliance with a relevant standard.
Such concealment includes, but is not limited to:
(1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a
pollutant in the effluent discharged to the atmosphere; or
(2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions.
40 CFR 63.4(b), Minn. R.
7011.7000
COMG 3
8
Proper Operation and Maintenance: At all times, including periods of startup, shutdown and malfunction,
the Permittee shall operate and maintain the emission units subject to NESHAP BBBBBB and its associated
air pollution control and monitoring equipment in a manner consistent with safety and good air pollution
control practices for minimizing emissions at least to the levels required by all relevant standards.
Determination of whether such operation and maintenance procedures are being used will be based on
information available to the Administrator, which may include, but is not limited to, monitoring results,
review of operation and maintenance procedures, review of operation and maintenance records, and
inspection of the source.
40 CFR 63.11085(a), 40 CFR
63.6(e)(1)(i), Minn. R.
7011.7000
COMG 3
9
The Permittee shall:
(1) Operate the vapor processing system in a manner not to exceed or not to go below, as appropriate,
the operating parameter value for the parameters described in 40 CFR Section 63.11092(b)(1).
(2) Operation of the vapor processing system in a manner exceeding or going below the operating
parameter value, as appropriate, shall constitute a violation of the emission standard in 40 CFR Section
63.11088(a), except as specified in 40 CFR Section 63.11092(d)(4). 40 CFR 63.11092(d)(1) and (3)
COMG 3
10
Each loading rack's thermal oxidation system pilot flame shall be monitored using a heat‐sensing device,
such as a thermocouple, installed in proximity to the pilot light to indicate the presence of a flame. The
heat‐sensing device shall send a positive parameter value to indicate that the pilot flame is on, or a
negative parameter value to indicate that the pilot flame is off.
40 CFR 63.11088(d), 40 CFR
63.11092(a), 40 CFR
63.11092(b)(1)(iii)(B)(1)
COMG 3
12
The Permittee shall determine an operating parameter value based on the parameter data monitored
during the performance test, supplemented by engineering assessments and the manufacturer's
recommenda ons.
The Permittee shall Provide for the Administrator's approval the rationale for the selected operating
parameter value, monitoring frequency, and averaging time, including data and calculations used to
develop the value and a description of why the value, monitoring frequency, and averaging time
demonstrate continuous compliance with the emission standard in 40 CFR Section 63.11088(a). 40 CFR 63.11092(b)(3) and (4)
COMG 3
13
Monthly Leak Inspections: The Permittee shall perform a monthly leak inspection of all equipment in
gasoline service, as defined in 40 CFR Section 63.11100. For this inspection, detection methods
incorpora ng sight, sound, and smell are acceptable.
40 CFR Section 63.11100 defines 'in gasoline service' as a piece of equipment used in a system that
transfers gasoline or gasoline vapors and 'monthly' as once per calendar month at regular intervals of no
less than 28 days and no more than 35 days.
40 CFR 63.11089(a), 40 CFR
63.11100
COMG 3
14
For each gasoline storage tank equipped with an internal floating roof, the Permittee must perform
inspec ons of the floa ng roof system according to:
‐ the requirements of Section 60.113b(a) if complying with option 2(b) in Table 1 of 40 CFR pt. 63, subp.
BBBBBB; OR
‐ the requirements of Section 60.1063(c)(1) if complying with option 2(d) in Table 1 of 40 CFR pt. 63, subp.
BBBBBB. 40 CFR 63.11092(e)(1)
COMG 3
16
For all gasoline loading rack(s), the Permittee shall install, calibrate, certify, operate, and maintain,
according to the manufacturer's specifications, a continuous monitoring system (CMS) while gasoline
vapors are displaced to the vapor processor systems.
40 CFR 63.11088(d), 40 CFR
63.11092(b)
COMG 3
17 Malfunctions shall be corrected as soon as practicable after their occurrence.
40 CFR 63.6(e)(1)(ii), Minn. R.
7011.7000
Subject Item ID Seq. # Requirement Citation
COMG 3
18
For the monitoring and inspection, as required under 40 CFR Section 63.11092(b)(1)(iii)(B)(2),
malfunctions that are discovered shall not constitute a violation of the emission standard in 40 CFR
Section 63.11088(a) if corrective actions as described in the monitoring and inspection plan are followed.
The Permi ee must:
(i) Ini ate correc ve ac on to determine the cause of the problem within 1 hour;
(ii) Ini ate correc ve ac on to fix the problem within 24 hours;
(iii) Complete all corrective actions needed to fix the problem as soon as practicable consistent with good
air pollu on control prac ces for minimizing emissions;
(iv) Minimize periods of start‐up, shutdown, or malfunc on; and
(v) Take any necessary corrective actions to restore normal operation and prevent the recurrence of the
cause of the problem. 40 CFR 63.11092(d)(4)
COMG 3
19
Leak Inspection Recordkeeping: A log book shall be used and shall be signed by the Permittee at the
completion of each inspection. A section of the log book shall contain a list, summary description, or
diagram(s) showing the location of all equipment in gasoline service at the facility. 40 CFR 63.11089(b)
COMG 3
20
The Permittee shall prepare and maintain a record describing the types, identification numbers, and
locations of all equipment in gasoline service. 40 CFR 63.11094(d)
COMG 3
21
The Permi ee shall record in the log book for each leak that is detected the informa on specified below:
(1) The equipment type and iden fica on number.
(2) The nature of the leak (i.e. vapor or liquid) and the method of detec on (i.e. sight, sound, or smell).
(3) The date the leak was detected and the date of each a empt to repair the leak.
(4) Repair methods applied in each a empt to repair the leak.
(5) A statement of: Repair Delayed and the reason for the delay if the leak is not repaired within 15
calendar days a er discovery of the leak.
(6) The expected date of successful repair of the leak if the leak is not repaired within 15 days.
(7) The date of successful repair of the leak. 40 CFR 63.11094(e)
COMG 3
22
Each detection of a liquid or vapor leak shall be recorded in the log book. When a leak is detected, an
initial attempt at repair shall be made as soon as practicable but no later than 5 calendar days after the
leak is detected. Repair or replacement of leaking equipment shall be completed within 15 calendar days
after detection of each leak, except as provided in the requirement listed below (referring to 40 CFR
Section 63.11089(d)). 40 CFR 63.11089(c)
COMG 3
23
The Permi ee shall:
(1) Keep an up‐to‐date, readily accessible record of the continuous monitoring data required under 40 CFR
Section 63.11092(b). This record shall indicate the time intervals during which loadings of gasoline cargo
tanks have occurred or, alternatively, shall record the operating parameter data only during such loadings.
The date and me of day shall also be indicated at reasonable intervals on this record.
(3) Keep an up‐to‐date, readily accessible copy of the monitoring and inspection plan required under 40
CFR Sec on 63.11092(b)(1)(iii)(B)(2).
(4) Keep an up‐to‐date, readily accessible record of all system malfunctions, as specified in 40 CFR Section
63.11092(b)(1)(iii)(B)(2)(v).
40 CFR 63.11088(f), 40 CFR
63.11094(f)(1), (3), and (4)
Subject Item ID Seq. # Requirement Citation
COMG 3
25
The Permittee shall maintain a monitoring and inspection plan that describes the Permittee's approach for
meeting the following requirements. If any monitoring and inspection procedures change, the Permittee
shall submit to the Administrator the updated approach for mee ng the following requirements:
1) The Permittee shall equip TREA 6 and TREA 7 to automatically prevent gasoline loading operations at
EQUI 19 and EQUI 20 from starting up at any time that the pilot flame is absent. TREA 6 and TREA 7 shall
also automatically shutdown loading operations if the pilot flame goes out during loading, and TREA 6 and
TREA 7 shall not allow loading to resume un l the pilot flame is present.
2) The Permittee shall verify, during each day of operation of EQUI 19, EQUI 20, TREA 6 and TREA 7, the
proper operation of the assist‐air blower, the vapor line valve, and the emergency shutdown system.
Verification shall be through visual observation or through an automated alarm or shutdown system that
monitors and records system operation. A manual or electronic record of the start and end of a shutdown
event may be used.
3) The Permittee shall perform semi‐annual preventive maintenance inspections of EQUI 19, EQUI20, TREA
6, and TREA 7, including the automated alarm or shutdown system for those units so equipped, according
to the recommenda ons of the manufacturer of the system.
4) The monitoring and inspection plan shall specify conditions that would be considered malfunctions of
EQUI 19, EQUI 20, TREA 6, and/or TREA 7 during the inspections or automated monitoring performed
under 40 CFR Section 63.11092(b)(1)(iii)(B)(2)(ii) and (iii), describe specific corrective actions that will be
taken to correct any malfunction, and define what the Permittee would consider to be a timely repair for
each poten al malfunc on.
5) The Permittee shall document any malfunction of EQUI 19, EQUI 20, TREA 6 or TREA 7, as defined in the
monitoring and inspection plan, and any activation of the automated alarm or shutdown system with a
written entry into a log book or other permanent form of record. Such record shall also include a
description of the corrective action taken and whether such corrective actions were taken in a timely
manner, as defined in the monitoring and inspection plan, as well as an estimate of the amount of
gasoline loaded during the period of the malfunction.
40 CFR 63.11088(d), 40 CFR
63.11092(a), 40 CFR
63.11092(b)(1)(iii)(B)(2)
COMG 3
26
The Permittee shall keep records of the test results for each gasoline cargo tank loading at the facility as
specified below:
(1) Annual cer fica on tes ng performed under 40 CFR Sec on 63.11092(f)(1).
(2) The documentation file shall be kept up‐to‐date for each gasoline cargo tank loading at the facility. The
documentation for each test shall include the information specified in 40 CFR Section 63.11094(b)(2).
40 CFR 63.11088(f), 40 CFR
63.11094(b)
COMG 3
27
As an alternative to keeping records of each gasoline cargo tank test result at the terminal, as required in
40 CFR Sec on 63.11094(b), the Permi ee may comply with the requirements of paragraph 1 or 2, below:
(1) An electronic copy of each record is instantly available at the terminal, and the electronic copy of each
record shall be an exact duplicate image of the original paper record with certifying signatures. If this
option is chosen, the Permittee shall notify the Administrator in writing that the terminal using this
alterna ve in compliance with 40 CFR Sec on 63.11094(c)(1).
(2) For facilities that use a terminal automation system (TAS) to prevent gasoline cargo tanks that do not
have valid cargo tank vapor tightness documentation from loading (e.g., via a card lock‐out system), a
copy of the documentation is made available (e.g., via facsimile) for inspection by the Administrator's
delegated representatives during the course of a site visit, or within a mutually agreeable time frame. The
copy of each record shall be an exact duplicate image of the original paper record with certifying
signatures. If this option is chosen, the Permittee shall notify the Administrator in writing that the terminal
using this alternative in compliance with 40 CFR Section 63.11094(c)(2).
40 CFR 63.11088(f), 40 CFR
63.11094(c)
COMG 3
28
The Permi ee shall keep the following records:
1) Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or
the air pollu on control and monitoring equipment.
2) Records of actions taken during periods of malfunction to minimize emissions in accordance with 40
CFR Section 63.11085(a), including corrective actions to restore malfunctioning process and air pollution
control and monitoring equipment to its normal or usual manner of operation. 40 CFR 63.11094(g)
Subject Item ID Seq. # Requirement Citation
COMG 3
30
The Permi ee shall maintain, at a minimum, the following informa on in the files:
1) the occurrence and duration of each startup, shutdown, or malfunction of operation when the startup
or shutdown causes the source to exceed any applicable emission limitation in the relevant emission
standards;
2) the occurrence and duration of each malfunction of operation (i.e., process equipment) or the required
air pollu on control and monitoring equipment;
3) all maintenance performed on the air pollu on control and monitoring equipment;
4) actions taken during periods of startup, shutdown, and malfunction when such actions are different
from the procedures specified in the affected source's startup, shutdown, and malfunction plan (SSMP). In
this case, the Permittee shall report this action within 2 days of occurrence and follow by a written
no fica on within 7 days of occurrence;
5) all information necessary to demonstrate conformance with the affected source's SSMP and actions
taken in accordance with SSMP;
6) each period during which a con nuous monitoring system (CMS) is malfunc oning or inopera ve;
7) all required measurements needed to demonstrate compliance with a relevant standard;
8) all results of performance test, CMS performance evaluations, and opacity and visible emission
observa ons;
9) all measurements as may be necessary to determine the conditions of performance tests and
performance evalua ons;
10) all CMS calibra on checks;
11) all adjustments and maintenance performed on CMS;
12) any information demonstrating whether a source is meeting the requirements for a waiver of record
keeping or repor ng requirements under this part;
13) All emission levels relative to the criterion for obtaining permission to use an alternative to the relative
accuracy test, if the source has been granted such permission under 40 CFR 63.8(f)(6); and
14) all documentation supporting initial notifications and notifications of compliance status.
40 CFR 63.10(b)(2), Minn. R.
7019.0100, subp. 2(B)
COMG 3
31
Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form
suitable and readily available for expedi ous inspec on and review.
The files should be retained for at least 5 years following the date of each occurrence, measurement,
maintenance, corrective action, report, or record. Only the most recent two years of information must be
kept on site.
40 CFR 63.10(b)(1), Minn. R.
7019.0100, subp. 2(B)
COMG 3
32
The Permittee shall keep records as specified in 40 CFR Section 63.1065. The Permittee shall keep records
as specified in 40 CFR Section 63.1065(a) for as long as liquid is stored and 63.1065(b)‐(d) for at least 5
years.
40 CFR 63.1065, 40 CFR
63.11094(a)
COMG 3
33
For performance tests performed after the initial test required by 40 CFR Section 63.11092(a), the
Permittee shall document the reasons for any change in the operating parameter value since the previous
performance test. 40 CFR 63.11092(c)
COMG 3
34
For each performance test conducted under 40 CFR Section 63.11092(a)(1), the Permittee shall determine
a monitored operating parameter value for the vapor processing system using the procedures specified
below. During the performance test, the Permittee shall continuously record the operating parameter as
specified below. 40 CFR 63.11092(b)
COMG 3
35
The annual certification test for each gasoline cargo tank shall consist of the test methods specified in 40
CFR Section 63.11092(f)(1) or (2). Facilities that are also subject to 40 CFR pt. 60, subp. XX may elect, after
notification to the MPCA, to comply with 40 CFR Section 63.11092(f)(1) or (2). 40 CFR 63.11092(f)
COMG 3
37
Delay of Equipment Leak Repair: Delay of repair of leaking equipment will be allowed if the repair is not
feasible within 15 days. The Permittee shall provide in the semiannual Excess Emissions Report specified in
40 CFR Section 63.11095(b), the reason(s) why the repair was not feasible and the date each repair was
completed. 40 CFR 63.11089(d)
Subject Item ID Seq. # Requirement Citation
COMG 3
38
The Permittee shall submit a semiannual excess emissions (EER) report to the Administrator with the
Semiannual Deviations Report listed in this permit. Excess emissions events, and the information to be
included in the excess emissions report, are as follows:
(1) Each instance of a non‐vapor‐tight gasoline cargo tank loading at the facility in which the Permittee
failed to take steps to assure that such cargo tank would not be reloaded at the facility before vapor
ghtness documenta on for that cargo tank was obtained.
(2) Each reloading of a non‐vapor‐tight gasoline cargo tank at the facility before vapor tightness
documentation for that cargo tank is obtained by the facility in accordance with 40 CFR Section
63.11094(b).
(3) Each exceedance or failure to maintain, as appropriate, the monitored operating parameter value
determined under 40 CFR Section 63.11092(b). The report shall include the monitoring data for the days
on which exceedances or failures to maintain have occurred, and a description and timing of the steps
taken to repair or perform maintenance on the vapor collec on and processing systems or the CMS.
(4) Each instance in which malfunctions discovered during the monitoring and inspections required under
40 CFR Section 63.11092(b)(1)(i)(B)(2) and (iii)(B)(2) were not resolved according to the necessary
corrective actions described in the monitoring and inspection plan. The report shall include a description
of the malfunc on and the ming of the steps taken to correct the malfunc on.
(5) For each occurrence of an equipment leak for which no repair attempt was made within 5 days or for
which repair was not completed within 15 days a er detec on:
(i) The date on which the leak was detected;
(ii) The date of each a empt to repair the leak;
(iii) The reasons for the delay of repair; and
(iv) The date of successful repair. 40 CFR 63.11095(b)
COMG 3
39
The Permittee shall submit a semiannual report including the number, duration, and a brief description of
each type of malfunction which occurred during the reporting period and which caused or may have
caused any applicable emission limitation to be exceeded. The report must also include a description of
actions taken by the Permittee during a malfunction to minimize emissions in accordance with 40 CFR
Section 63.11085(a), including actions taken to correct a malfunction. The report may be submitted as a
part of the semiannual compliance report. 40 CFR 63.11095(d)
COMG 3
40
The Permittee shall also include the following in the Semiannual Deviations Report (listed elsewhere in
this permit), as applicable:
1) For storage vessels complying with option 2(a), 2(b), or 2(c) in Table 1 of 40 CFR pt. 63, subp. BBBBBB,
the information specified in 40 CFR Section 60.115b(a), 60.115b(b), or 60.115b(c), depending upon the
control equipment installed, or, if you are complying with option 2(d) in Table 1 of 40 CFR pt. 63, subp.
BBBBBB, the informa on specified in 40 CFR Sec on 63.1066;
2) For loading racks, each loading of a gasoline cargo tank for which vapor tightness documentation had
not been previously obtained by the facility;
3) For equipment leak inspections, the number of equipment leaks not repaired within 15 days after
detec on; and
4) For storage vessels complying with 40 CFR Section 63.11087(b) after January 10, 2011, the storage
vessel’s Notice of Compliance Status Information can be included in the next semi‐annual compliance
report in lieu of filing a separate Notification of Compliance Status report under 40 CFR Section 63.11093.
40 CFR 63.11087(e), 40 CFR
63.11089(g), 40 CFR
63.11095(a)
COMG 3
41
After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63,
equipment added (or a process change) to an affected source that is within the scope of the definition of
affected source under the relevant standard must be considered part of the affected source and subject to
all provisions of the relevant standard established for that affected source.
40 CFR 63.5(b), Minn. R.
7011.7000
COMG 3
44
Prior to construction or reconstruction of a major‐emitting "affected source" under the promulgated
MACT standards, the Permittee must apply for and obtain an air emission permit.
40 CFR 63.5(b)(3)& Minn. R.
7011.7000
EQUI 19
(EU001) 1 Total Organic Compounds <= 35 milligrams per liter of gasoline loaded.
40 CFR 60.502(b), Minn. R.
7011.1550
EQUI 19
(EU001) 2
The Permittee shall operate and maintain EQUI 19's vapor collection system such that it achieves an
overall capture efficiency for Total Organic Compounds >= 98.7 percent capture efficiency.
Minn. R. 7007.0800,
subps.2&14
EQUI 19
(EU001) 3
Design Requirement: The vapor collection and liquid loading equipment shall be designed and operated to
prevent gauge pressure in the delivery tank from exceeding 4,500 pascals (450 mm of water) during
product loading. This level is not to be exceeded when measured by the procedures specified in 40 CFR
Section 60.503(d).
40 CFR 60.502(h), 40 CFR 64.3,
Minn. R. 7011.1550, Minn. R.
7017.0200
EQUI 19
(EU001) 4
Gauge Pressure Requirement: No pressure‐vacuum vent in the bulk gasoline terminal's vapor collection
system shall begin to open at a system pressure less than 4,500 pascals (450 mm of water).
40 CFR 60.502(i), 40 CFR 64.3,
Minn. R. 7011.1550, Minn. R.
7017.0200
Subject Item ID Seq. # Requirement Citation
EQUI 19
(EU001) 5
Loadings: Loadings of liquid product into gasoline tank trucks shall be limited to vapor‐tight gasoline tank
trucks using the following procedures. The Permi ee shall:
1. Obtain the vapor tightness documentation described in 40 CFR Section 60.505(b) for each gasoline tank
truck which is to be loaded at the facility.
2. Require the tank identification number to be recorded as each gasoline tank truck is loaded at the
facility.
3. Cross‐check each tank identification number with the file of tank vapor tightness documentation within
2 weeks a er the corresponding tank is loaded.
4. Notify the owner or operator of each nonvapor‐tight gasoline tank truck loaded at the facility within 1
week a er the documenta on cross‐check (in #3) has occurred.
5. Take steps assuring that the non‐vapor‐tight gasoline tank truck will not be reloaded at the facility until
vapor ghtness documenta on for that tank is obtained.
6. Alternate procedures may be used upon application to, and approval by, the Administrator.
40 CFR 60.502(e), Minn. R.
7011.1550
EQUI 19
(EU001) 6
The Permittee shall operate the vapor combustion unit (VCU, TREA 6) during loading to control emissions
from the Bottom Loading Rack (EQUI 19). The Permittee shall document periods of non‐operation of the
control equipment. Minn. R. 7007.0800, subp. 14
EQUI 19
(EU001) 7
Operation Requirement: The Permittee shall act to assure that loadings of gasoline tank trucks at the
facility are made only into tanks equipped with vapor collection equipment that is compatible with the
terminal's vapor collection system.
40 CFR 60.502(f), Minn. R.
7011.1550
EQUI 19
(EU001) 8
Operation Requirement: The Permittee shall act to assure that the terminal's and the tank truck's vapor
collection systems are connected during each loading of a gasoline tank truck at the affected facility. This
includes training drivers in the hookup procedures and posting visible reminder signs at the affected
loading racks.
40 CFR 60.502(g), Minn. R.
7011.1550
EQUI 19
(EU001) 9
Operation Requirement: At all times, including periods of startup, shutdown, and malfunction, owners
and operators shall maintain and operate any affected facility including associated air pollution control
equipment in a matter consistent with good air pollution control practice for minimizing emissions.
Determination of whether acceptable operating and maintenance procedures are being used will be
based on information which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection.
40 CFR 60.11(d), Minn. R.
7017.2015
EQUI 19
(EU001) 10
Operation and Maintenance (O & M) Plan: The Permittee shall operate and maintain the VCU in
accordance with the facility O & M Plan and the control equipment manufacturer's specifications. The
Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.
40 CFR 64.8, Minn. R.
7007.0800, subp. 14, Minn. R.
7017.0200
EQUI 19
(EU001) 11
Monthly Inspections: Each calendar month the vapor collection system, the vapor processing system, and
each loading rack handling gasoline shall be inspected during the loading of gasoline tank trucks for total
organic compounds liquid or vapor leaks. For purposes of this requirement, detection methods
incorporating sight, sound, or smell are acceptable.
40 CFR 60.502(j), 40 CFR 64.7,
Minn. R. 7011.1550, Minn. R.
7017.0200
EQUI 19
(EU001) 13
Semiannual Inspections: The Permittee shall inspect the VCU at least semiannual and shall maintain a
written record of the inspection and any action resulting from the inspection.
40 CFR 64.3(b)(4), Minn. R.
7007.0800, subp. 14, Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200
EQUI 19
(EU001) 14
Total Organic Compounds : The Permittee shall conduct a performance test : Due before 09/06/2020
every 36 months to verify the emission factor of total organic compounds (mg/l) and pressure according
to 40 CFR 60.502(h). All subsequent tests are due by the end of each 36‐month period following that date.
Compliance with 40 CFR 60.502(b) shall be determined by complying with 40 CFR 60.503(b)‐(c) and 40 CFR
63.11092(a)(1)(i), and compliance with 40 CFR 60.502(h) shall be determined by complying with 40 CFR
60.503(d). Performance tests required under this condition were completed on November 18, 2002,
September 6, 2007, and August 22, 2012. The performance test shall be conducted at worst case
conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 25A or 25B, or other
method approved by MPCA in the performance test plan approval.
Testing conducted during the 60 days prior to the performance test due date satisfies the performance
test due date, and will not reset the test due date for future tes ng as required:
1. by this permit;
2. by the most recently approved Performance Test Frequency Plan; or
3. within a No ce of Compliance le er.
Testing conducted more than two months prior to the performance test due date satisfies this test due
date requirement and will reset the performance test due date.
40 CFR 60.503(a), 40 CFR
60.8(a), 40 CFR 64.3(c), Minn. R.
7011.1550, Minn. R. 7017.0200,
Minn. R. 7017.2015, Minn. R.
7017.2020, subp. 1
EQUI 19
(EU001) 15
Leak Repairs: Each detection of a leak shall be recorded and the source of the leak repaired within 15
calendar days after it is detected.
40 CFR 60.502(j), 40 CFR 64.7,
Minn. R. 7011.1550, Minn. R.
7017.0200
Subject Item ID Seq. # Requirement Citation
EQUI 19
(EU001) 16
Corrective Actions: If the gauge pressure in the delivery tank exceeds 4,500 pascals (450 mm of water)
during product loading, the Permittee shall take corrective action as soon as possible according to the
control equipment manufacturer's specifications and the facility operation and maintenance plan. The
Permittee shall keep a log of all corrective actions taken with records entered upon completion of each
corrective action.
40 CFR 64.7(d)(1), Minn. R.
7017.0200
EQUI 19
(EU001) 17
Recordkeeping: The documentation file for each gasoline tank truck shall be updated at least once per
year to reflect current test results as determined by Method 27 or equivalent method approved by MPCA.
Trucks tested in accordance with 40 CFR Section 63.425(a) are considered to meet this requirement. This
documenta on shall include, as a minimum, the following informa on:
1. Test title: Gasoline Delivery Tank Pressure Test ‐EPA Reference Method 27 (or equivalent approved by
MPCA).
2. Tank owner and address.
3. Tank iden fica on number.
4. Tes ng loca on.
5. Date of test.
6. Tester name and signature.
7. Witnessing inspector, if any: Name, signature, and affilia on.
8. Test results: Actual pressure change in 5 minutes, mm of water (average for 2 runs).
40 CFR 60.505(b), Minn. R.
7011.1550
EQUI 19
(EU001) 18
Recordkeeping: The tank truck vapor tightness documentation required under 40 CFR 60.502(e)(1) shall be
kept on file at the terminal in a permanent form available for inspection.
40 CFR 60.505(a), Minn. R.
7011.1550
EQUI 19
(EU001) 19
Inspection Recordkeeping: A record of each monthly leak inspection required under 40 CFR 60.502(j) shall
be kept on file at the terminal for at least five (5) years and shall include, at a minimum, the following
informa on:
1. Date of inspec on.
2. Findings (may indicated no leaks discovered; or loca on, nature, and severity of each leak).
3. Leak determina on method.
4. Correc ve ac on (date each leak repaired, reasons for any repair interval >15 days).
5. Inspector name and signature.
40 CFR 60.505(c), Minn. R.
7007.0800, subp. 5, Minn. R.
7011.1550
EQUI 19
(EU001) 20
Recordkeeping of Notifications: The Permittee shall keep documentation of all notifications required
under 40 CFR Section 60.502(e)(4) on file at the terminal for at least five (5) years.
40 CFR 60.505(d), Minn. R.
7011.1550
EQUI 19
(EU001) 21
Component Recordkeeping: The Permittee shall keep records of all replacements or additions of
components performed on an existing vapor processing system on site for at least five (5) years.
40 CFR 60.505(f), Minn. R.
7011.1550
EQUI 19
(EU001) 22
Recordkeeping: The Permittee shall maintain records of the occurrence and duration of each startup,
shutdown, or malfunction of the VCU.
40 CFR 60.7(b), Minn. R.
7019.0100, subp. 1
EQUI 19
(EU001) 29
Performance Test No fica ons and Submi als;
Performance Test No fica on (wri en): due 30 days before each Performance Test,
Performance Test Plan: due 30 days before each Performance Test,
Performance Test Pre‐Test Mee ng: due 7 day before each Performance Test,
Performance Test Report: due 45 days a er each Performance Test,
Performance Test Report ‐ Microfiche Copy or CD: due 105 day after each Performance Test.
Minn. R. 7017.2030, Minn. R.
7017.2035, subp. 1, Minn. R.
7017.2035, subp. 2
EQUI 19
(EU001) 30
Corrective Actions Reporting: All situations warranting corrective actions are deviations, the Permittee
shall report the deviations in the semiannual deviations report as required in the total facility section of
this permit.
40 CFR 64.9(a)(2)(i), Minn. R.
7017.0200
EQUI 20
(EU002) 1 Total Organic Compounds <= 35 milligrams per liter of gasoline loaded.
40 CFR 60.502(b), Minn. R.
7011.1550
EQUI 20
(EU002) 2
The Permittee shall operate and maintain EQUI 20's vapor collection system such that it achieves an
overall capture efficiency for Total Organic Compounds >= 98.7 percent capture efficiency.
Minn. R. 7007.0800,
subps.2&14
EQUI 20
(EU002) 3
Design Requirement: The vapor collection and liquid loading equipment shall be designed and operated to
prevent gauge pressure in the delivery tank from exceeding 4,500 pascals (450 mm of water) during
product loading. This level is not to be exceeded when measured by the procedures specified in 40 CFR
Section 60.503(d).
40 CFR 60.502(h), 40 CFR 64.3,
Minn. R. 7011.1550, Minn. R.
7017.0200
EQUI 20
(EU002) 4
Gauge Pressure Requirement: No pressure‐vacuum vent in the bulk gasoline terminal's vapor collection
system shall begin to open at a system pressure less than 4,500 pascals (450 mm of water).
40 CFR 60.502(i), 40 CFR 64.3,
Minn. R. 7011.1550, Minn. R.
7017.0200
Subject Item ID Seq. # Requirement Citation
EQUI 20
(EU002) 5
Loadings: Loadings of liquid product into gasoline tank trucks shall be limited to vapor‐tight gasoline tank
trucks using the following procedures. The Permi ee shall:
1. Obtain the vapor tightness documentation described in 40 CFR Section 60.505(b) for each gasoline tank
truck which is to be loaded at the facility.
2. Require the tank identification number to be recorded as each gasoline tank truck is loaded at the
facility.
3. Cross‐check each tank identification number with the file of tank vapor tightness documentation within
2 weeks a er the corresponding tank is loaded.
4. Notify the owner or operator of each nonvapor‐tight gasoline tank truck loaded at the facility within 1
week a er the documenta on cross‐check (in #3) has occurred.
5. Take steps assuring that the nonvapor‐tight gasoline tank truck will not be reloaded at the facility until
vapor ghtness documenta on for that tank is obtained.
6. Alternate procedures may be used upon application to, and approval by, the Administrator.
40 CFR 60.502(e), Minn. R.
7011.1550
EQUI 20
(EU002) 6
The Permittee shall operate the vapor combustion unit (VCU, TREA 7) during loading to control emissions
from the Bottom Loading Rack (EQUI 20). The Permittee shall document periods of non‐operation of the
control equipment. Minn. R. 7007.0800, subp. 14
EQUI 20
(EU002) 7
Operation Requirement: The Permittee shall act to assure that loadings of gasoline tank trucks at the
facility are made only into tanks equipped with vapor collection equipment that is compatible with the
terminal's vapor collection system.
40 CFR 60.502(f), Minn. R.
7011.1550
EQUI 20
(EU002) 8
Operation Requirement: The Permittee shall act to assure that the terminal's and the tank truck's vapor
collection systems are connected during each loading of a gasoline tank truck at the affected facility. This
includes training drivers in the hookup procedures and posting visible reminder signs at the affected
loading racks.
40 CFR 60.502(g), Minn. R.
7011.1550
EQUI 20
(EU002) 9
Operation Requirement: At all times, including periods of startup, shutdown, and malfunction, owners
and operators shall maintain and operate any affected facility including associated air pollution control
equipment in a matter consistent with good air pollution control practice for minimizing emissions.
Determination of whether acceptable operating and maintenance procedures are being used will be
based on information which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection.
40 CFR 60.11(d), Minn. R.
7017.2015
EQUI 20
(EU002) 10
Operation and Maintenance (O & M) Plan: The Permittee shall operate and maintain the VCU in
accordance with the facility O & M Plan and the control equipment manufacturer's specifications. The
Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.
40 CFR 64.8, Minn. R.
7007.0800, subp. 14, Minn. R.
7017.0200
EQUI 20
(EU002) 11
Monthly Inspections: Each calendar month, the vapor collection system, the vapor processing system, and
each loading rack handling gasoline shall be inspected during the loading of gasoline tank trucks for total
organic compounds liquid or vapor leaks. For purposes of this requirement, detection methods
incorporating sight, sound, or smell are acceptable.
40 CFR 60.502(j), 40 CFR 64.7,
Minn. R. 7011.1550, Minn. R.
7017.0200
EQUI 20
(EU002) 13
Semiannual Inspection: The Permittee shall inspect the VCU at least semiannual and shall maintain a
written record of the inspection and any action resulting from the inspection.
40 CFR 64.3(b)(4), Minn. R.
7007.0800, subp. 14, Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200
EQUI 20
(EU002) 14
Total Organic Compounds : The Permittee shall conduct a performance test : Due before 09/07/2022
every 60 months to verify the emission factor of total organic compounds (mg/l) and pressure according
to 40 CFR 60.502(h). All subsequent tests are due by the end of each 60‐month period following that date.
Compliance with 40 CFR 60.502(b) shall be determined by complying with 40 CFR 60.503(b)‐(c) and 40 CFR
63.11092(a)(1)(i), and compliance with 40 CFR 60.502(h) shall be determined by complying with 40 CFR
60.503(d). Performance tests required under this condition were completed on November 18, 2002,
September 7, 2007, and August 21, 2012. The performance test shall be conducted at worst case
conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 25A or 25B, or other
method approved by MPCA in the performance test plan approval.
Testing conducted during the 60 days prior to the performance test due date satisfies the performance
test due date, and will not reset the test due date for future tes ng as required:
1. by this permit;
2. by the most recently approved Performance Test Frequency Plan; or
3. within a No ce of Compliance le er.
Testing conducted more than two months prior to the performance test due date satisfies this test due
date requirement and will reset the performance test due date.
40 CFR 60.503(a), 40 CFR
60.8(a), 40 CFR 64.3(c), Minn. R.
7011.1550, Minn. R. 7017.0200,
Minn. R. 7017.2015, Minn. R.
7017.2020, subp. 1
EQUI 20
(EU002) 15
Leak Repairs: Each detection of a leak shall be recorded and the source of the leak repaired within 15
calendar days after it is detected.
40 CFR 60.502(j), 40 CFR 64.7,
Minn. R. 7011.1550, Minn. R.
7017.0200
Subject Item ID Seq. # Requirement Citation
EQUI 20
(EU002) 16
Corrective Actions: If the gauge pressure in the delivery tank exceeds 4,500 pascals (450 mm of water)
during product loading, the Permittee shall take corrective action as soon as possible according to the
control equipment manufacturer's specifications and the facility operation and maintenance plan. The
Permittee shall keep a log of all corrective actions taken with records entered upon completion of each
corrective action.
40 CFR 64.7(d)(1), Minn. R.
7017.0200
EQUI 20
(EU002) 17
Recordkeeping: The documentation file for each gasoline tank truck shall be updated at least once per
year to reflect current test results as determined by Method 27 or equivalent method approved by MPCA.
Trucks tested in accordance with 40 CFR Section 63.425(e) are considered to meet this requirement. This
documenta on shall include, as a minimum, the following informa on:
1. Test title: Gasoline Delivery Tank Pressure Test ‐EPA Reference Method 27 (or equivalent approved by
MPCA).
2. Tank owner and address.
3. Tank iden fica on number.
4. Tes ng loca on.
5. Date of test.
6. Tester name and signature.
7. Witnessing inspector, if any: Name, signature, and affilia on.
8. Test results: Actual pressure change in 5 minutes, mm of water (average for 2 runs).
40 CFR 60.505(b), Minn. R.
7011.1550
EQUI 20
(EU002) 18
Recordkeeping: The tank truck vapor tightness documentation required under 40 CFR 60.502(e)(1) shall be
kept on file at the terminal in a permanent form available for inspection.
40 CFR 60.505(a), Minn. R.
7011.1550
EQUI 20
(EU002) 19
Inspection Recordkeeping: A record of each monthly leak inspection required under 40 CFR 60.502(j) shall
be kept on file at the terminal for at least five (5) years and shall include, at a minimum, the following
informa on:
1. Date of inspec on.
2. Findings (may indicate no leaks discovered; or loca on, nature, and severity of each leak).
3. Leak determina on method.
4. Correc ve ac on (date each leak repaired, reasons for any repair interval >15 days).
5. Inspector name and signature.
40 CFR 60.505(c), Minn. R.
7007.0800, subp. 5, Minn. R.
7011.1550
EQUI 20
(EU002) 20
Recordkeeping of Notifications: The Permittee shall keep documentation of all notifications required
under 40 CFR Section 60.502(e)(4) on file at the terminal for at least five (5) years.
40 CFR 60.505(d), Minn. R.
7011.1550
EQUI 20
(EU002) 21
Component Recordkeeping: The Permittee shall keep records of all replacements or additions of
components performed on an existing vapor processing system on site for at least five (5) years.
40 CFR 60.505(f), Minn. R.
7011.1550
EQUI 20
(EU002) 22
Recordkeeping: The Permittee shall maintain records of the occurrence and duration of each startup,
shutdown, or malfunction of the VCU.
40 CFR 60.7(b), Minn. R.
7019.0100, subp. 1
EQUI 20
(EU002) 29
Performance Test No fica ons and Submi als;
Performance Test No fica on (wri en): due 30 days before each Performance Test,
Performance Test Plan: due 30 days before each Performance Test,
Performance Test Pre‐Test Mee ng: due 7 day before each Performance Test,
Performance Test Report: due 45 days a er each Performance Test,
Performance Test Report ‐ Microfiche Copy or CD: due 105 day after each Performance Test.
Minn. R. 7017.2030, Minn. R.
7017.2035, subp. 1, Minn. R.
7017.2035, subp. 2
EQUI 20
(EU002) 30
Corrective Actions Reporting: All situations warranting corrective actions are deviations, the Permittee
shall report the deviations in the semiannual deviations report as required in the total facility section of
this permit.
40 CFR 64.9(a)(2)(i), Minn. R.
7017.0200
EQUI 38
(TK020) 1
Equip the storage vessels with a fixed roof with an internal floating type cover equipped with a continuous
closure device between the tank wall and the cover edge. The cover is to be floating at all times (i.e., off
the leg supports) except during initial fill and when the tank is completely emptied and subsequently
refilled. The process of emptying and refilling when the cover is resting on the leg supports shall be
continuous and shall be accomplished as rapidly as possible. Each opening in the cover except for
automatic bleeder vents and the rim space vents is to provide a projection below the liquid surface. Each
opening in the cover except for automatic bleeder vents, rim space vents, stub drains and leg sleeves is to
be equipped with a cover, seal, or lid which is to be maintained in a closed position at all times (i.e., no
visible gap) except when the device is in actual use. Automatic bleeder vents are to be closed at all times
when the cover is floating except when the cover is being floated off or is being landed on the leg
supports. Rim vents are to be set to open only when the cover is being floated off the leg supports or at
the manufacturer's recommended setting.
40 CFR 60.112a(a)(2), Minn. R.
7011.1520(B)
EQUI 38
(TK020) 2
At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate EQUI 38, including associated air pollution control equipment, in a
manner consistent with good air pollution control practice for minimizing emissions. Determination of
whether acceptable operating and maintenance procedures are being used will be based on information
which may include, but is not limited to, monitoring results, review of operating and maintenance
procedures, and inspection of the source.
40 CFR 60.11(d), Minn. R.
7017.2015
EQUI 38
(TK020) 3
Maintain a record of the petroleum liquid stored, the period of storage, and the maximum true vapor
pressure of that liquid during the respective storage period.
40 CFR 60.115a(a), Minn. R.
7011.1520(B)
Subject Item ID Seq. # Requirement Citation
EQUI 38
(TK020) 4
Maintain a file of each type of petroleum liquid stored, of the typical Reid vapor pressure of each type of
petroleum liquid stored, of the dates of storage and withdrawals, and of the date on which the storage
vessel is empty. Determine and record by the 15th of the month for the previous month the average
monthly storage temperature and true vapor pressure of the petroleum liquid stored at such temperature
if the petroleum liquid has a true vapor pressure, as stored, greater than 470 mm Hg (9.1 psia).
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 1
EQUI 38
(TK020) 5
Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.
40 CFR 60.7(b), Minn. R.
7019.0100, subp. 1
EQUI 38
(TK020) 6
Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records
for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two
years.
40 CFR 60.7(f), Minn. R.
7007.0800, subp. 5(C), Minn. R.
7019.0100, subp. 1
EQUI 38
(TK020) 7
Available data on the typical Reid vapor pressure and the maximum expected storage temperature of the
stored product may be used to determine the maximum true vapor pressure from nomographs contained
in API Bulletin 2517, unless the Administrator specifically requests that the liquid be sampled, the actual
storage temperature determined, and the Reid vapor pressure determined from the sample(s).
40 CFR 60.115a(b), Minn. R.
7011.1520(B)
EQUI 38
(TK020) 8
The true vapor pressure of each type of crude oil with a Reid vapor pressure less than 13.8 kPa (2.0 psia)
or whose physical properties preclude determination by the recommended method is to be determined
from available data and recorded if the estimated true vapor pressure is greater than 6.9 kPa (1.0 psia).
40 CFR 60.115a(c), Minn. R.
7011.1520(B)
EQUI 38
(TK020) 9
The average monthly storage temperature is an arithmetic average calculated for each calendar month, or
portion thereof if storage is for less than a month, from bulk liquid storage temperatures determined at
least once every seven days.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 2
EQUI 38
(TK020) 10
The true vapor pressure shall be determined by the procedure in American Petroleum Institute Bulletin
2517. This procedure is dependent upon determination of the storage temperature and the Reid vapor
pressure, which requires sampling of the petroleum liquids in the storage vessels. Unless the agency or
the commissioner requires in specific cases that the stored petroleum liquid be sampled, the true vapor
pressure may be determined by using the average monthly storage temperature and the typical Reid
vapor pressure. For those liquids for which certified specifications limiting the Reid vapor pressure exist,
that Reid vapor pressure may be used. For other liquids, supporting analytical data must be made
available on request of the agency or the commissioner when typical Reid vapor pressure is used.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 3
EQUI 38
(TK020) 11
The following are exempt from the requirements of 40 CFR Sec on 60.115a:
1. Each owner or operator of each storage vessel storing a petroleum liquid with a Reid vapor pressure of
less than 6.9 kPa (1.0 psia) provided the maximum true vapor pressure does not exceed 6.9 kPa (1.0 psia).
2. The owner or operator of each storage vessel equipped with a vapor recovery and return or disposal
system in accordance with the requirements of 40 CFR Section 60.112a(a)(3) and (b), or a closed vent
system and control device meeting the specifications of 40 CFR Section 65.42(b)(4), (b)(5), or (c).
40 CFR 60.115a(d)(1)‐(2), Minn.
R. 7011.1520(B)
EQUI 38
(TK020) 12
No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use
of which conceals an emission which would otherwise constitute a violation of an applicable standard.
40 CFR 60.12, Minn. R.
7011.0050
EQUI 38
(TK020) 13
The Permittee shall submit a notification of any physical or operational change which increases emission
rate: due 60 days (or as soon as practical) before the change is commenced.
40 CFR 60.7(a)(4), Minn. R.
7019.0100, subp. 1
Subject Item ID Seq. # Requirement Citation
EQUI 40
(TK027) 1
Equip the storage vessels with a fixed roof with an internal floating type cover equipped with a continuous
closure device between the tank wall and the cover edge. The cover is to be floating at all times (i.e., off
the leg supports) except during initial fill and when the tank is completely emptied and subsequently
refilled. The process of emptying and refilling when the cover is resting on the leg supports shall be
continuous and shall be accomplished as rapidly as possible. Each opening in the cover except for
automatic bleeder vents and the rim space vents is to provide a projection below the liquid surface. Each
opening in the cover except for automatic bleeder vents, rim space vents, stub drains and leg sleeves is to
be equipped with a cover, seal, or lid which is to be maintained in a closed position at all times (i.e., no
visible gap) except when the device is in actual use. Automatic bleeder vents are to be closed at all times
when the cover is floating except when the cover is being floated off or is being landed on the leg
supports. Rim vents are to be set to open only when the cover is being floated off the leg supports or at
the manufacturer's recommended setting.
40 CFR 60.112a(a)(2), Minn. R.
7011.1520(B)
EQUI 40
(TK027) 2
At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate EQUI 40, including associated air pollution control equipment, in a
manner consistent with good air pollution control practice for minimizing emissions. Determination of
whether acceptable operating and maintenance procedures are being used will be based on information
which may include, but is not limited to, monitoring results, review of operating and maintenance
procedures, and inspection of the source.
40 CFR 60.11(d), Minn. R.
7017.2015
EQUI 40
(TK027) 3
Maintain a record of the petroleum liquid stored, the period of storage, and the maximum true vapor
pressure of that liquid during the respective storage period.
40 CFR 60.115a(a), Minn. R.
7011.1520(B)
EQUI 40
(TK027) 4
Maintain a file of each type of petroleum liquid stored, of the typical Reid vapor pressure of each type of
petroleum liquid stored, of the dates of storage and withdrawals, and of the date on which the storage
vessel is empty. Determine and record by the 15th of the month for the previous month the average
monthly storage temperature and true vapor pressure of the petroleum liquid stored at such temperature
if the petroleum liquid has a true vapor pressure, as stored, greater than 470 mm Hg (9.1 psia).
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 1
EQUI 40
(TK027) 5
Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.
40 CFR 60.7(b), Minn. R.
7019.0100, subp. 1
EQUI 40
(TK027) 6
Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records
for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two
years.
40 CFR 60.7(f), Minn. R.
7007.0800, subp. 5(C), Minn. R.
7019.0100, subp. 1
EQUI 40
(TK027) 7
Available data on the typical Reid vapor pressure and the maximum expected storage temperature of the
stored product may be used to determine the maximum true vapor pressure from nomographs contained
in API Bulletin 2517, unless the Administrator specifically requests that the liquid be sampled, the actual
storage temperature determined, and the Reid vapor pressure determined from the sample(s).
40 CFR 60.115a(b), Minn. R.
7011.1520(B)
EQUI 40
(TK027) 8
The true vapor pressure of each type of crude oil with a Reid vapor pressure less than 13.8 kPa (2.0 psia)
or whose physical properties preclude determination by the recommended method is to be determined
from available data and recorded if the estimated true vapor pressure is greater than 6.9 kPa (1.0 psia).
40 CFR 60.115a(c), Minn. R.
7011.1520(B)
EQUI 40
(TK027) 9
The average monthly storage temperature is an arithmetic average calculated for each calendar month, or
portion thereof if storage is for less than a month, from bulk liquid storage temperatures determined at
least once every seven days.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 2
EQUI 40
(TK027) 10
The true vapor pressure shall be determined by the procedure in American Petroleum Institute Bulletin
2517. This procedure is dependent upon determination of the storage temperature and the Reid vapor
pressure, which requires sampling of the petroleum liquids in the storage vessels. Unless the agency or
the commissioner requires in specific cases that the stored petroleum liquid be sampled, the true vapor
pressure may be determined by using the average monthly storage temperature and the typical Reid
vapor pressure. For those liquids for which certified specifications limiting the Reid vapor pressure exist,
that Reid vapor pressure may be used. For other liquids, supporting analytical data must be made
available on request of the agency or the commissioner when typical Reid vapor pressure is used.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 3
Subject Item ID Seq. # Requirement Citation
EQUI 40
(TK027) 11
The following are exempt from the requirements of 40 CFR Sec on 60.115a:
1. Each owner or operator of each storage vessel storing a petroleum liquid with a Reid vapor pressure of
less than 6.9 kPa (1.0 psia) provided the maximum true vapor pressure does not exceed 6.9 kPa (1.0 psia).
2. The owner or operator of each storage vessel equipped with a vapor recovery and return or disposal
system in accordance with the requirements of 40 CFR Section 60.112a(a)(3) and (b), or a closed vent
system and control device meeting the specifications of 40 CFR Section 65.42(b)(4), (b)(5), or (c).
40 CFR 60.115a(d)(1)‐(2), Minn.
R. 7011.1520(B)
EQUI 40
(TK027) 12
No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use
of which conceals an emission which would otherwise constitute a violation of an applicable standard.
40 CFR 60.12, Minn. R.
7011.0050
EQUI 40
(TK027) 13
The Permittee shall submit a notification of any physical or operational change which increases emission
rate: due 60 days (or as soon as practical) before the change is commenced.
40 CFR 60.7(a)(4), Minn. R.
7019.0100, subp. 1
EQUI 69
(TK019) 1
Equip the storage vessels with a fixed roof with an internal floating type cover equipped with a continuous
closure device between the tank wall and the cover edge. The cover is to be floating at all times (i.e., off
the leg supports) except during initial fill and when the tank is completely emptied and subsequently
refilled. The process of emptying and refilling when the cover is resting on the leg supports shall be
continuous and shall be accomplished as rapidly as possible. Each opening in the cover except for
automatic bleeder vents and the rim space vents is to provide a projection below the liquid surface. Each
opening in the cover except for automatic bleeder vents, rim space vents, stub drains and leg sleeves is to
be equipped with a cover, seal, or lid which is to be maintained in a closed position at all times (i.e., no
visible gap) except when the device is in actual use. Automatic bleeder vents are to be closed at all times
when the cover is floating except when the cover is being floated off or is being landed on the leg
supports. Rim vents are to be set to open only when the cover is being floated off the leg supports or at
the manufacturer's recommended setting.
40 CFR 60.112a(a)(2), Minn. R.
7011.1520(B)
EQUI 69
(TK019) 2
At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate EQUI 69, including associated air pollution control equipment, in a
manner consistent with good air pollution control practice for minimizing emissions. Determination of
whether acceptable operating and maintenance procedures are being used will be based on information
which may include, but is not limited to, monitoring results, review of operating and maintenance
procedures, and inspection of the source.
40 CFR 60.11(d), Minn. R.
7017.2015
EQUI 69
(TK019) 3
Maintain a record of the petroleum liquid stored, the period of storage, and the maximum true vapor
pressure of that liquid during the respective storage period.
40 CFR 60.115a(a), Minn. R.
7011.1520(B)
EQUI 69
(TK019) 4
Maintain a file of each type of petroleum liquid stored, of the typical Reid vapor pressure of each type of
petroleum liquid stored, of the dates of storage and withdrawals, and of the date on which the storage
vessel is empty. Determine and record by the 15th of the month for the previous month the average
monthly storage temperature and true vapor pressure of the petroleum liquid stored at such temperature
if the petroleum liquid has a true vapor pressure, as stored, greater than 470 mm Hg (9.1 psia).
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 1
EQUI 69
(TK019) 5
Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.
40 CFR 60.7(b), Minn. R.
7019.0100, subp. 1
EQUI 69
(TK019) 6
Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records
for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two
years.
40 CFR 60.7(f), Minn. R.
7007.0800, subp. 5(C), Minn. R.
7019.0100, subp. 1
EQUI 69
(TK019) 7
Available data on the typical Reid vapor pressure and the maximum expected storage temperature of the
stored product may be used to determine the maximum true vapor pressure from nomographs contained
in API Bulletin 2517, unless the Administrator specifically requests that the liquid be sampled, the actual
storage temperature determined, and the Reid vapor pressure determined from the sample(s).
40 CFR 60.115a(b), Minn. R.
7011.1520(B)
EQUI 69
(TK019) 8
The true vapor pressure of each type of crude oil with a Reid vapor pressure less than 13.8 kPa (2.0 psia)
or whose physical properties preclude determination by the recommended method is to be determined
from available data and recorded if the estimated true vapor pressure is greater than 6.9 kPa (1.0 psia).
40 CFR 60.115a(c), Minn. R.
7011.1520(B)
EQUI 69
(TK019) 9
The average monthly storage temperature is an arithmetic average calculated for each calendar month, or
portion thereof if storage is for less than a month, from bulk liquid storage temperatures determined at
least once every seven days.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 2
Subject Item ID Seq. # Requirement Citation
EQUI 69
(TK019) 10
The true vapor pressure shall be determined by the procedure in American Petroleum Institute Bulletin
2517. This procedure is dependent upon determination of the storage temperature and the Reid vapor
pressure, which requires sampling of the petroleum liquids in the storage vessels. Unless the agency or
the commissioner requires in specific cases that the stored petroleum liquid be sampled, the true vapor
pressure may be determined by using the average monthly storage temperature and the typical Reid
vapor pressure. For those liquids for which certified specifications limiting the Reid vapor pressure exist,
that Reid vapor pressure may be used. For other liquids, supporting analytical data must be made
available on request of the agency or the commissioner when typical Reid vapor pressure is used.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 3
EQUI 69
(TK019) 11
The following are exempt from the requirements of 40 CFR Sec on 60.115a:
1. Each owner or operator of each storage vessel storing a petroleum liquid with a Reid vapor pressure of
less than 6.9 kPa (1.0 psia) provided the maximum true vapor pressure does not exceed 6.9 kPa (1.0 psia).
2. The owner or operator of each storage vessel equipped with a vapor recovery and return or disposal
system in accordance with the requirements of 40 CFR Section 60.112a(a)(3) and (b), or a closed vent
system and control device meeting the specifications of 40 CFR Section 65.42(b)(4), (b)(5), or (c).
40 CFR 60.115a(d)(1)‐(2), Minn.
R. 7011.1520(B)
EQUI 69
(TK019) 12
No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use
of which conceals an emission which would otherwise constitute a violation of an applicable standard.
40 CFR 60.12, Minn. R.
7011.0050
EQUI 69
(TK019) 13
The Permittee shall submit a notification of any physical or operational change which increases emission
rate: due 60 days (or as soon as practical) before the change is commenced.
40 CFR 60.7(a)(4), Minn. R.
7019.0100, subp. 1
EQUI 77
(TK029) 1
Equip the storage vessels with a fixed roof with an internal floating type cover equipped with a continuous
closure device between the tank wall and the cover edge. The cover is to be floating at all times (i.e., off
the leg supports) except during initial fill and when the tank is completely emptied and subsequently
refilled. The process of emptying and refilling when the cover is resting on the leg supports shall be
continuous and shall be accomplished as rapidly as possible. Each opening in the cover except for
automatic bleeder vents and the rim space vents is to provide a projection below the liquid surface. Each
opening in the cover except for automatic bleeder vents, rim space vents, stub drains and leg sleeves is to
be equipped with a cover, seal, or lid which is to be maintained in a closed position at all times (i.e., no
visible gap) except when the device is in actual use. Automatic bleeder vents are to be closed at all times
when the cover is floating except when the cover is being floated off or is being landed on the leg
supports. Rim vents are to be set to open only when the cover is being floated off the leg supports or at
the manufacturer's recommended setting.
40 CFR 60.112a(a)(2), Minn. R.
7011.1520(B)
EQUI 77
(TK029) 2
At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate EQUI 77, including associated air pollution control equipment, in a
manner consistent with good air pollution control practice for minimizing emissions. Determination of
whether acceptable operating and maintenance procedures are being used will be based on information
which may include, but is not limited to, monitoring results, review of operating and maintenance
procedures, and inspection of the source.
40 CFR 60.11(d), Minn. R.
7017.2015
EQUI 77
(TK029) 3
Maintain a record of the petroleum liquid stored, the period of storage, and the maximum true vapor
pressure of that liquid during the respective storage period.
40 CFR 60.115a(a), Minn. R.
7011.1520(B)
EQUI 77
(TK029) 4
Maintain a file of each type of petroleum liquid stored, of the typical Reid vapor pressure of each type of
petroleum liquid stored, of the dates of storage and withdrawals, and of the date on which the storage
vessel is empty. Determine and record by the 15th of the month for the previous month the average
monthly storage temperature and true vapor pressure of the petroleum liquid stored at such temperature
if the petroleum liquid has a true vapor pressure, as stored, greater than 470 mm Hg (9.1 psia).
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 1
EQUI 77
(TK029) 5
Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.
40 CFR 60.7(b), Minn. R.
7019.0100, subp. 1
EQUI 77
(TK029) 6
Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records
for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two
years.
40 CFR 60.7(f), Minn. R.
7007.0800, subp. 5(C), Minn. R.
7019.0100, subp. 1
Subject Item ID Seq. # Requirement Citation
EQUI 77
(TK029) 7
Available data on the typical Reid vapor pressure and the maximum expected storage temperature of the
stored product may be used to determine the maximum true vapor pressure from nomographs contained
in API Bulletin 2517, unless the Administrator specifically requests that the liquid be sampled, the actual
storage temperature determined, and the Reid vapor pressure determined from the sample(s).
40 CFR 60.115a(b), Minn. R.
7011.1520(B)
EQUI 77
(TK029) 8
The true vapor pressure of each type of crude oil with a Reid vapor pressure less than 13.8 kPa (2.0 psia)
or whose physical properties preclude determination by the recommended method is to be determined
from available data and recorded if the estimated true vapor pressure is greater than 6.9 kPa (1.0 psia).
40 CFR 60.115a(c), Minn. R.
7011.1520(B)
EQUI 77
(TK029) 9
The average monthly storage temperature is an arithmetic average calculated for each calendar month, or
portion thereof if storage is for less than a month, from bulk liquid storage temperatures determined at
least once every seven days.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 2
EQUI 77
(TK029) 10
The true vapor pressure shall be determined by the procedure in American Petroleum Institute Bulletin
2517. This procedure is dependent upon determination of the storage temperature and the Reid vapor
pressure, which requires sampling of the petroleum liquids in the storage vessels. Unless the agency or
the commissioner requires in specific cases that the stored petroleum liquid be sampled, the true vapor
pressure may be determined by using the average monthly storage temperature and the typical Reid
vapor pressure. For those liquids for which certified specifications limiting the Reid vapor pressure exist,
that Reid vapor pressure may be used. For other liquids, supporting analytical data must be made
available on request of the agency or the commissioner when typical Reid vapor pressure is used.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 3
EQUI 77
(TK029) 11
The following are exempt from the requirements of 40 CFR Sec on 60.115a:
1. Each owner or operator of each storage vessel storing a petroleum liquid with a Reid vapor pressure of
less than 6.9 kPa (1.0 psia) provided the maximum true vapor pressure does not exceed 6.9 kPa (1.0 psia).
2. The owner or operator of each storage vessel equipped with a vapor recovery and return or disposal
system in accordance with the requirements of 40 CFR Section 60.112a(a)(3) and (b), or a closed vent
system and control device meeting the specifications of 40 CFR Section 65.42(b)(4), (b)(5), or (c).
40 CFR 60.115a(d)(1)‐(2), Minn.
R. 7011.1520(B)
EQUI 77
(TK029) 12
No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use
of which conceals an emission which would otherwise constitute a violation of an applicable standard.
40 CFR 60.12, Minn. R.
7011.0050
EQUI 77
(TK029) 13
The Permittee shall submit a notification of any physical or operational change which increases emission
rate: due 60 days (or as soon as practical) before the change is commenced.
40 CFR 60.7(a)(4), Minn. R.
7019.0100, subp. 1
EQUI 80
(TK032) 1
Equip the storage vessels with a fixed roof with an internal floating type cover equipped with a continuous
closure device between the tank wall and the cover edge. The cover is to be floating at all times (i.e., off
the leg supports) except during initial fill and when the tank is completely emptied and subsequently
refilled. The process of emptying and refilling when the cover is resting on the leg supports shall be
continuous and shall be accomplished as rapidly as possible. Each opening in the cover except for
automatic bleeder vents and the rim space vents is to provide a projection below the liquid surface. Each
opening in the cover except for automatic bleeder vents, rim space vents, stub drains and leg sleeves is to
be equipped with a cover, seal, or lid which is to be maintained in a closed position at all times (i.e., no
visible gap) except when the device is in actual use. Automatic bleeder vents are to be closed at all times
when the cover is floating except when the cover is being floated off or is being landed on the leg
supports. Rim vents are to be set to open only when the cover is being floated off the leg supports or at
the manufacturer's recommended setting.
40 CFR 60.112a(a)(2), Minn. R.
7011.1520(B)
EQUI 80
(TK032) 2
At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate EQUI 80, including associated air pollution control equipment, in a
manner consistent with good air pollution control practice for minimizing emissions. Determination of
whether acceptable operating and maintenance procedures are being used will be based on information
which may include, but is not limited to, monitoring results, review of operating and maintenance
procedures, and inspection of the source.
40 CFR 60.11(d), Minn. R.
7017.2015
EQUI 80
(TK032) 3
Maintain a record of the petroleum liquid stored, the period of storage, and the maximum true vapor
pressure of that liquid during the respective storage period.
40 CFR 60.115a(a), Minn. R.
7011.1520(B)
Subject Item ID Seq. # Requirement Citation
EQUI 80
(TK032) 4
Maintain a file of each type of petroleum liquid stored, of the typical Reid vapor pressure of each type of
petroleum liquid stored, of the dates of storage and withdrawals, and of the date on which the storage
vessel is empty. Determine and record by the 15th of the month for the previous month the average
monthly storage temperature and true vapor pressure of the petroleum liquid stored at such temperature
if the petroleum liquid has a true vapor pressure, as stored, greater than 470 mm Hg (9.1 psia).
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 1
EQUI 80
(TK032) 5
Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.
40 CFR 60.7(b), Minn. R.
7019.0100, subp. 1
EQUI 80
(TK032) 6
Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records
for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two
years.
40 CFR 60.7(f), Minn. R.
7007.0800, subp. 5(C), Minn. R.
7019.0100, subp. 1
EQUI 80
(TK032) 7
Available data on the typical Reid vapor pressure and the maximum expected storage temperature of the
stored product may be used to determine the maximum true vapor pressure from nomographs contained
in API Bulletin 2517, unless the Administrator specifically requests that the liquid be sampled, the actual
storage temperature determined, and the Reid vapor pressure determined from the sample(s).
40 CFR 60.115a(b), Minn. R.
7011.1520(B)
EQUI 80
(TK032) 8
The true vapor pressure of each type of crude oil with a Reid vapor pressure less than 13.8 kPa (2.0 psia)
or whose physical properties preclude determination by the recommended method is to be determined
from available data and recorded if the estimated true vapor pressure is greater than 6.9 kPa (1.0 psia).
40 CFR 60.115a(c), Minn. R.
7011.1520(B)
EQUI 80
(TK032) 9
The average monthly storage temperature is an arithmetic average calculated for each calendar month, or
portion thereof if storage is for less than a month, from bulk liquid storage temperatures determined at
least once every seven days.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 2
EQUI 80
(TK032) 10
The true vapor pressure shall be determined by the procedure in American Petroleum Institute Bulletin
2517. This procedure is dependent upon determination of the storage temperature and the Reid vapor
pressure, which requires sampling of the petroleum liquids in the storage vessels. Unless the agency or
the commissioner requires in specific cases that the stored petroleum liquid be sampled, the true vapor
pressure may be determined by using the average monthly storage temperature and the typical Reid
vapor pressure. For those liquids for which certified specifications limiting the Reid vapor pressure exist,
that Reid vapor pressure may be used. For other liquids, supporting analytical data must be made
available on request of the agency or the commissioner when typical Reid vapor pressure is used.
This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the
Clean Air Act. Minn. R. 7011.1510, subp. 3
EQUI 80
(TK032) 11
The following are exempt from the requirements of 40 CFR Sec on 60.115a:
1. Each owner or operator of each storage vessel storing a petroleum liquid with a Reid vapor pressure of
less than 6.9 kPa (1.0 psia) provided the maximum true vapor pressure does not exceed 6.9 kPa (1.0 psia).
2. The owner or operator of each storage vessel equipped with a vapor recovery and return or disposal
system in accordance with the requirements of 40 CFR Section 60.112a(a)(3) and (b), or a closed vent
system and control device meeting the specifications of 40 CFR Section 65.42(b)(4), (b)(5), or (c).
40 CFR 60.115a(d)(1)‐(2), Minn.
R. 7011.1520(B)
EQUI 80
(TK032) 12
No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use
of which conceals an emission which would otherwise constitute a violation of an applicable standard.
40 CFR 60.12, Minn. R.
7011.0050
EQUI 80
(TK032) 13
The Permittee shall submit a notification of any physical or operational change which increases emission
rate: due 60 days (or as soon as practical) before the change is commenced.
40 CFR 60.7(a)(4), Minn. R.
7019.0100, subp. 1
TREA 6
(CE001) 11
Operating Scenario 1: The Vapor Combustion Unit (VCU) shall be operated with the assist air blower on,
the MOV (vapor valve) open, and a pilot flame present at all times when emissions may be vented to TREA
6. If emissions vent to TREA 6 when any of the above conditions are not occurring, it shall be considered
an excursion as defined by 40 CFR pt. 64.1.
40 CFR 64.3(a)(2), Minn. R.
7007.0800, subp. 11, Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200, Title I Condition:
Avoid major modification under
40 CFR 52.21(b)(1)(i) and Minn.
R. 7007.3000
Subject Item ID Seq. # Requirement Citation
TREA 6
(CE001) 12
Operating Scenario 2: The VCU shall be operated with the MOV (vapor valve) in the closed position as
demonstrated by the indicator on the unit when no emissions are venting to TREA 6. If the MOV is in an
open position when emissions are not venting to TREA 6, it shall be considered an excursion as defined by
40 CFR pt. 64.1.
40 CFR 64.3(a)(2), Minn. R.
7007.0800, subp. 11, Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200, Title I Condition:
Avoid major modification under
40 CFR 52.21(b)(1)(i) and Minn.
R. 7007.3000
TREA 6
(CE001) 13
The Permittee shall vent emissions from EQUI 19 to a VCU that meets the requirements of TREA 6
whenever EQUI 19 operates, and operate and maintain TREA 6 at all times that any emissions are vented
to TREA 6. The Permittee shall document periods of non‐operation of the control equipment TREA 6
whenever EQUI 19 is operating.
Title I Condition: Avoid major
modification under 40 CFR
52.21(b)(1)(i) and Minn. R.
7007.3000
TREA 6
(CE001) 20
The Permittee shall operate and maintain the VCU in accordance with the Operation and Maintenance (O
& M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA
staff.
40 CFR 64.8, Minn. R.
7007.0800, subp. 14, Minn. R.
7017.0200
TREA 6
(CE001) 21
Monitoring Equipment: The Permittee shall install and maintain a thermocouple or equivalent device on
TREA 6 to detect the presence of a flame as required by this permit. The monitoring equipment must be
installed, in use, and properly maintained whenever operation of the monitored control equipment is
required. This includes, but is not limited to, maintaining necessary parts for routine repairs.
40 CFR 64.7(b), Minn. R.
7007.0800, subp. 14, Minn. R.
7007.0800, subp. 4, Minn. R.
7017.0200
TREA 6
(CE001) 23
Daily Monitoring: At least once during every 24‐hour period the Permittee shall verify that control and
monitoring equipment is operating properly. For Operating Scenario 1, the Permittee shall verify that all
three operating conditions are being met; for Operating Scenario 2, the Permittee shall verify that the
MOV indicator shows that it is closed. The Permittee shall maintain a written record of the daily
verifications.
40 CFR 64.3(c), Minn. R.
7017.0200, Title I Condition:
Avoid major modification under
40 CFR 52.21(b)(1)(i) and Minn.
R. 7007.3000
TREA 6
(CE001) 17610
Recordkeeping of daily monitoring: At least once during every 24‐hour period the Permittee shall record
the following:
1. The time, date, and results of the daily verification,
2. The applicable Operating Scenario (whether or not emissions are being vented to the VCU), and
3. Whether or not there was an excursion for the Operating Scenario.
40 CFR 64.3(b)(4), Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200, Title I Condition:
Avoid major modification under
40 CFR 52.51(b)(1)(i) and Minn.
R. 7007.3000
TREA 6
(CE001) 17615
Semi‐Annual Inspections: At least once per calendar half‐year, the Permittee shall inspect all of the control
equipment internal and external system components, including but not limited to the automated alarm or
shutdown system and the electrical systems. Inspections shall be separated by at least 120 days. The
Permittee shall maintain a written record of the inspection and any action resulting from the inspection.
40 CFR 64.3, Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200
TREA 6
(CE001) 18740
Annual Calibration: The Permittee shall calibrate or replace the thermocouple at least once every 12
months and shall maintain a written record of the calibration and any action resulting from the calibration
or replacement.
40 CFR 64.3, Minn. R.
7007.0800, subp. 14, Minn. R.
7007.0800, subp. 5, Minn. R.
7017.0200
TREA 6
(CE001) 18760
Continued operation: Except for monitoring malfunctions, associated repairs, and required quality
assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall
collect data at all required intervals) at all times that the pollutant‐specific emissions unit is operating.
Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or
control activities shall not be used for purposes of this part, including data averages and calculations, or
fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden,
infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures
that are caused in part by poor maintenance or careless operation are not malfunctions.
40 CFR 64.7(c), Minn. R.
7017.0200
TREA 6
(CE001) 18770
Corrective Actions: the Permittee shall take corrective action as soon as possible if any of the following
occur:
1. The air assist blower is not on during loading opera ons,
2. The presence of a flame is not detected during loading opera ons,
3. The MOV is open when no emissions are being vented to it, or
4. The VCU or any of its components are found to need repair during the inspec ons.
Corrective actions shall turn on the air assist blower, return the flame presence, close the MOV, and/or
include completion of necessary repairs identified during the inspection, as applicable. Corrective actions
include, but are not limited to, those outlined in the O & M Plan for the VCU. The Permittee shall keep a
record of the type and date of any corrective action taken, whether it was taken in a timely manner, and
an estimate of the amount of fuel loaded during the period of malfunction.
40 CFR 64.7(d), Minn. R.
7007.0800, subp. 14, Minn. R.
7007.0800, subp. 5, Minn. R.
7017.0200
Subject Item ID Seq. # Requirement Citation
TREA 6
(CE001) 18780
Response to excursions: Upon detecting an excursion, the Permittee shall restore operation of the VCU to
its normal or usual manner of operation as expeditiously as practicable in accordance with good air
pollution control practices for minimizing emissions. The response shall include minimizing the period of
any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal
operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial
inspection and evaluation, recording that operations returned to normal without operator action, or any
necessary follow‐up actions to return operation to within the designated condition, or below the
applicable emission limitation or standard, as applicable.
40 CFR 64.7(d)(1), Minn. R.
7007.0800, subp. 14, Minn. R.
7017.0200
TREA 6
(CE001) 18800
Determination of whether the Permittee has used acceptable procedures in response to an excursion or
exceedance will be based on information available, which may include but is not limited to, monitoring
results, review of operation and maintenance procedures and records, and inspection of the control
device, associated capture system, and the process.
40 CFR 64.7(d)(2), Minn. R.
7007.0800, subp. 14, Minn. R.
7017.0200
TREA 6
(CE001) 18810
Recordkeeping Requirement: The Permittee shall maintain written records of the presence of the flame;
days of start up and shutdown of the VCU; any malfunction of and related corrective actions for the VCU;
performance tests; calibration checks; adjustments and maintenance; inspections; and all other
information in permanent form, suitable for inspection for at least five years following the date of such
measurements, maintenance, and records.
40 CFR 60.7(b), 40 CFR 64.9(b),
Minn. R. 7017.0200, Minn. R.
7019.0100, subp. 1
TREA 6
(CE001) 18830
The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions
taken, and other supporting information required to be maintained. The Permittee may maintain records
on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that
the use of such alternative media allows for expeditious inspection and review, and does not conflict with
other applicable recordkeeping requirements.
40 CFR 64.9(b), Minn. R.
7017.0200
TREA 6
(CE001) 18840
As required by 40 CFR Section 64.9(a)(2), for the Semi‐Annual Deviations Report required by this permit
and/or the Notification of Deviations Endangering Human Health and the Environment required by this
permit, as applicable, the Permittee shall include the following related to the monitoring identified as
required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or
exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number,
duration, and cause for monitor downtime incidents.
40 CFR 64.9(a)(2), Minn. R.
7017.0200
TREA 6
(CE001) 18900
Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an
emission limitation or standard for which the monitoring did not provide an indication of an excursion or
exceedance while providing valid data, or the results of compliance or performance testing document a
need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if
necessary, submit a permit amendment application to address the necessary monitoring change.
40 CFR 64.7(e), Minn. R.
7017.0200
TREA 6
(CE001) 18901
If the Permittee replaces TREA 6, the replacement control must meet or exceed the control efficiency
requirements of TREA 6 as well as comply with all other requirements of TREA 6. Prior to making such a
change, the Permi ee shall apply for and obtain the appropriate permit amendment, as applicable.
If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the
Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the
commencement/start of replacement.
Title I Condition: Avoid major
modification under 40 CFR
52.21(b)(1)(i) and Minn. R.
7007.3000
TREA 6
(CE001) 18902
Quality Improvement Plan (QIP): Based on the results of a determination made under 40 CFR 64.7(d)(2),
the Commissioner may require the Permittee to develop and implement a QIP in accordance with 40 CFR
64.8(b).
40 CFR 64.8(a), Minn. R.
7017.0200
TREA 7
(CE002) 11
Operating Scenario 1: The Vapor Combustion Unit (VCU) shall be operated with the assist air blower on,
the MOV (vapor valve) open, and a pilot flame present at all times when emissions may be vented to TREA
7. If emissions vent to TREA 7 when any of the above conditions are not occurring, it shall be considered
an excursion as defined by 40 CFR pt. 64.1.
40 CFR 64.3(a)(2), Minn. R.
7007.0800, subp. 11, Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200, Title I Condition:
Avoid major modification under
40 CFR 52.21(b)(1)(i) and Minn.
R. 7007.3000
TREA 7
(CE002) 12
Operating Scenario 2: The VCU shall be operated with the MOV (vapor valve) in the closed position as
demonstrated by the indicator on the unit when no emissions are venting to TREA 7. If the MOV is in an
open position when emissions are not venting to TREA 7, it shall be considered an excursion as defined by
40 CFR pt. 64.1.
40 CFR 64.3(a)(2), Minn. R.
7007.0800, subp. 11, Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200, Title I Condition:
Avoid major modification under
40 CFR 52.21(b)(1)(i) and Minn.
R. 7007.3000
Subject Item ID Seq. # Requirement Citation
TREA 7
(CE002) 13
The Permittee shall vent emissions from EQUI 20 to a VCU that meets the requirements of TREA 7
whenever EQUI 20 operates, and operate and maintain TREA 7 at all times that any emissions are vented
to TREA 7. The Permittee shall document periods of non‐operation of the control equipment TREA 7
whenever EQUI 20 is operating.
Title I Condition: Avoid major
modification under 40 CFR
52.21(b)(1)(i) and Minn. R.
7007.3000
TREA 7
(CE002) 20
The Permittee shall operate and maintain the VCU in accordance with the Operation and Maintenance (O
& M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA
staff.
40 CFR 64.8, Minn. R.
7007.0800, subp. 14, Minn. R.
7017.0200
TREA 7
(CE002) 21
Monitoring Equipment: The Permittee shall install and maintain a thermocouple or equivalent device on
TREA 7 to detect the presence of a flame as required by this permit. The monitoring equipment must be
installed, in use, and properly maintained whenever operation of the monitored control equipment is
required. This includes, but is not limited to, maintaining necessary parts for routine repairs.
40 CFR 64.7(b), Minn. R.
7007.0800, subp. 14, Minn. R.
7007.0800, subp. 4, Minn. R.
7017.0200
TREA 7
(CE002) 23
Daily Monitoring: At least once during every 24‐hour period the Permittee shall verify that control and
monitoring equipment is operating properly. For Operating Scenario 1, the Permittee shall verify that all
three operating conditions are being met; for Operating Scenario 2, the Permittee shall verify that the
MOV indicator shows that it is closed. The Permittee shall maintain a written record of the daily
verifications.
40 CFR 64.3(c), Minn. R.
7017.0200, Title I Condition:
Avoid major modification under
40 CFR 52.21(b)(1)(i) and Minn.
R. 7007.3000
TREA 7
(CE002) 17610
Recordkeeping of daily monitoring: At least once during every 24‐hour period the Permittee shall record
the following:
1. The time, date, and results of the daily verification,
2. The applicable Operating Scenario (whether or not emissions are being vented to the VCU), and
3. Whether or not there was an excursion for the Operating Scenario.
40 CFR 64.3(b)(4), Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200, Title I Condition:
Avoid major modification under
40 CFR 52.51(b)(1)(i) and Minn.
R. 7007.3000
TREA 7
(CE002) 17615
Semi‐Annual Inspections: At least once per calendar half‐year, the Permittee shall inspect all of the control
equipment internal and external system components, including but not limited to the automated alarm or
shutdown system and the electrical systems. Inspections shall be separated by at least 120 days. The
Permittee shall maintain a written record of the inspection and any action resulting from the inspection.
40 CFR 64.3, Minn. R.
7007.0800, subps. 4‐5, Minn. R.
7017.0200
TREA 7
(CE002) 18740
Annual Calibration: The Permittee shall calibrate or replace the thermocouple at least once every 12
months and shall maintain a written record of the calibration and any action resulting from the calibration
or replacement.
40 CFR 64.3, Minn. R.
7007.0800, subp. 14, Minn. R.
7007.0800, subp. 5, Minn. R.
7017.0200
TREA 7
(CE002) 18760
Continued operation: Except for monitoring malfunctions, associated repairs, and required quality
assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall
collect data at all required intervals) at all times that the pollutant‐specific emissions unit is operating.
Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or
control activities shall not be used for purposes of this part, including data averages and calculations, or
fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden,
infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures
that are caused in part by poor maintenance or careless operation are not malfunctions.
40 CFR 64.7(c), Minn. R.
7017.0200
TREA 7
(CE002) 18770
Corrective Actions: the Permittee shall take corrective action as soon as possible if any of the following
occur:
1. The air assist blower is not on during loading opera ons,
2. The presence of a flame is not detected during loading opera ons,
3. The MOV is open when no emissions are being vented to it, or
4. The VCU or any of its components are found to need repair during the inspec ons.
Corrective actions shall turn on the air assist blower, return the flame presence, close the MOV, and/or
include completion of necessary repairs identified during the inspection, as applicable. Corrective actions
include, but are not limited to, those outlined in the O & M Plan for the VCU. The Permittee shall keep a
record of the type and date of any corrective action taken, whether it was taken in a timely manner, and
an estimate of the amount of fuel loaded during the period of malfunction.
40 CFR 64.7(d), Minn. R.
7007.0800, subp. 14, Minn. R.
7007.0800, subp. 5, Minn. R.
7017.0200
TREA 7
(CE002) 18780
Response to excursions: Upon detecting an excursion, the Permittee shall restore operation of the VCU to
its normal or usual manner of operation as expeditiously as practicable in accordance with good air
pollution control practices for minimizing emissions. The response shall include minimizing the period of
any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal
operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial
inspection and evaluation, recording that operations returned to normal without operator action, or any
necessary follow‐up actions to return operation to within the designated condition, or below the
applicable emission limitation or standard, as applicable.
40 CFR 64.7(d)(1), Minn. R.
7007.0800, subp. 14, Minn. R.
7017.0200
Subject Item ID Seq. # Requirement Citation
TREA 7
(CE002) 18800
Determination of whether the Permittee has used acceptable procedures in response to an excursion or
exceedance will be based on information available, which may include but is not limited to, monitoring
results, review of operation and maintenance procedures and records, and inspection of the control
device, associated capture system, and the process.
40 CFR 64.7(d)(2), Minn. R.
7007.0800, subp. 14, Minn. R.
7017.0200
TREA 7
(CE002) 18810
Recordkeeping Requirement: The Permittee shall maintain written records of the presence of the flame;
days of start up and shutdown of the VCU; any malfunction of and related corrective actions for the VCU;
performance tests; calibration checks; adjustments and maintenance; inspections; and all other
information in permanent form, suitable for inspection for at least five years following the date of such
measurements, maintenance, and records.
40 CFR 60.7(b), 40 CFR 64.9(b),
Minn. R. 7017.0200, Minn. R.
7019.0100, subp. 1
TREA 7
(CE002) 18830
The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions
taken, and other supporting information required to be maintained. The Permittee may maintain records
on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that
the use of such alternative media allows for expeditious inspection and review, and does not conflict with
other applicable recordkeeping requirements.
40 CFR 64.9(b), Minn. R.
7017.0200
TREA 7
(CE002) 18840
As required by 40 CFR Section 64.9(a)(2), for the Semi‐Annual Deviations Report required by this permit
and/or the Notification of Deviations Endangering Human Health and the Environment required by this
permit, as applicable, the Permittee shall include the following related to the monitoring identified as
required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or
exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number,
duration, and cause for monitor downtime incidents.
40 CFR 64.9(a)(2), Minn. R.
7017.0200
TREA 7
(CE002) 18900
Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an
emission limitation or standard for which the monitoring did not provide an indication of an excursion or
exceedance while providing valid data, or the results of compliance or performance testing document a
need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if
necessary, submit a permit amendment application to address the necessary monitoring change.
40 CFR 64.7(e), Minn. R.
7017.0200
TREA 7
(CE002) 18901
If the Permittee replaces TREA 7, the replacement control must meet or exceed the control efficiency
requirements of TREA 7 as well as comply with all other requirements of TREA 7. Prior to making such a
change, the Permi ee shall apply for and obtain the appropriate permit amendment, as applicable.
If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the
Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the
commencement/start of replacement.
Title I Condition: Avoid major
modification under 40 CFR
52.21(b)(1)(i) and Minn. R.
7007.3000
TREA 7
(CE002) 18902
Quality Improvement Plan (QIP): Based on the results of a determination made under 40 CFR 64.7(d)(2),
the Commissioner may require the Permittee to develop and implement a QIP in accordance with 40 CFR
64.8(b).
40 CFR 64.8(a), Minn. R.
7017.0200
COMPLIANCE ASSURANCE MONITORING PLAN
Vapor Combustion Unit for VOC Control: Magellan Pipeline Company, L.P. - St. Paul Terminal
1. Background a. Emissions Unit
Description: MPL Loading Rack, Flint Hills Resources (FHR) Loading Rack Identification: Stack Number 001, Stack Number 002 Stack Designation: Vapor Combustion Unit MPCA Facility Number: 12300070 Facility: Magellan Pipeline Company, L.P. - St. Paul Terminal
b. Applicable Regulation, Emission Limit and Monitoring Requirements Regulation No.: 40 CFR Part 60, Subpart XX Regulated Pollutant: Total Organic Compounds Emission Limit: 35 milligrams of TOC per liter of gasoline loaded Monitoring Requirements: Monthly inspection of vapor collection system, vapor processing system, and each loading rack managing gasoline for TOC liquid or vapor leaks. Detection methods incorporating sight, sound, or smell are acceptable.
Regulation No.: Permit Regulated Pollutant: Total Organic Compounds Emission Limit: 35 milligrams of TOC per liter of gasoline loaded Monitoring Requirements:
• Monthly inspection. • The Permittee shall conduct all necessary maintenance and make all
necessary attempts to keep all air pollution monitoring equipment in pro per operating condition at all times.
• Required submittal of an Operation and Maintenance Plan.
c. Control Technology: Vapor Combustion Unit
2. Monitoring Approach • The primary vapor combustion unit parameters to be included in the prop osed monitoring
approach are outlined in Table 1. • The parameters and ranges included in Table I are thos e recommended by the equipment
manufacturer. • The vapor combustion unit systems are continuously monitored for status and alarm
information at the loading rack controller. • The occurrence of any of the monitored alarms will cause the truck loading system to shut
down, allowing those transports which arc in the process of loading to finish, but not allow any additional loading until the alarm has been cleared.
• All routine maintenance, malfunctions, and unintended shutdowns of the vapor control system will be documented on the VCU Startup, Shutdown, Maintenance, and Malfunction Log.
• Maintenance shall be performed in a manner taking into consideration the manufacturer's recommendations.
• If any system component is found to be faulty during routine maintenance, it will be repaired in an exp editious manner. All repairs will be reported in the shutdown and maintenance report.
• Additional inspections will be conducted in accordance to the requirements of 40 CFR Part 60, Subpart XX.
3. Data Availability • Monitoring of the parameters will be done on a continual basis while the equipment is
operated. Due to the design of the monitoring and alarm system, the information is not recorded, only a no tification supplied by way of an alarm when an operational parameter is exceeded.
TABLE 1 - MONITORING APPROACH - MAGELLAN LOADING RACK VAPOR COlViBUSTION UNIT Indicator 1 indicator 2 Indicator 3 indicator 4 Indicator 5 indicator 6 Indicator 7 indicator 8
1 Indicator Liquid Seal Level Blower Failure First Stage Flame Arrester High Temp
Second Stage Flame Arrester High Temp
Pilot Gas Pressure Emergency Shutdown
Pilot Flame Fa&re
Power Failure
Measurement Approach
Float Breaker Thermocouple Thermocouple Pressure Gauge Float Fire Eyes Indicator to PLC
2. Indicator Range High and Low Level loss of coil on starter or motor failure
ISO cleg. F 160 deg.F High: above 10 psi Low: below 1.5 psi
High Condensate Tank Level
Mo Flame No Power
3. Performance Criteria
A. Data Representatives
The sensor supplies direct measurement of the liauid level.
Tha sensor supplies direct information on the blower operational status.
The sensor supplies direct information on the associated temperature.
The sans or supplies direct information on the associated temperature.
The sensor supplies direct measurement of pilot gas pressure.
The sensor supplies direct measurement of the liquid seal.
The sensor supplies direct information on the associated temperature.
The sensor supplies direct status of sower supply.
B. Verification of Operational Status Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable
C. QA'QC Practices and
Criteria
VCU maintenance activities wifl be conducted on a semiannual basts, taking into account manufacturer's recommendations. Visual inspections will occur on a weekly basis.
VCU maintenance activities will be conducted on a semi-annual basis, taking into account manufacturer's recommendations. Visual inspections will occur on a weekly basis.
VCU maintenance activities wifl be conducted on a semiannual basis, taking into account manufacturer's recommendations. Visual inspections will occur on a weekly basis.
VCU maintenance activities will be conducted on a semi-annual basis, taking into account manufacturer's recommendations. Visual inspections wifl occur on a weekly basis.
VCU maintenance activities will be conducted on a semiannual basis, taking into account manufacturer's recommend at ion s. Visual inspections will occur on a weekly basis.
VCU maintenance activities will be conducted on a semi-annual basis, taking into account manufacturer's recommendations. Visual inspections will occur on a weekly basis.
VCU maintenance activities wtfl be conducted on a semi-annual basis, taking into account manufacturer's recommendation s. Visual inspections wii! occur on a weekly basis.
VCU maintenance activities will be conducted on a semi-annual basis, taking into account manufacturer's recommendation s. Visual inspections will occur on a weekly basis.
D. Monitoring Frequency Continuous Continuous Continuous Continuous Continuous Continuous Continuous Continuous
Data Collection Procedure
Alarm screen at loading rack controller.
Alarm screen at loading rack controller
Alarm screen at loading rack controller.
Alarm screen at loading rack controller
Alarm screen at loading rack coniroitei.
Alarm screen at loading rack controller
Alarm screen at loading rack controller.
Alarm screen at leading rack controller.
Average Period No average is taken. No average is
taken. No average is taken. No average 5$
taken. Mo average is taken. No average is
taken, No average >s taken.
No average is taken.
T
TABLE 1 • MONITORING APPROACH - FLINT HILLS RESOURCES (FUR) LOADiNG RACK VAPOR COMBUSTION UNIT indicator 1 lndica;or 2 Indicator 3 Indicator 4 Indicator 5 indicator 5 Indicator ? indicator 8
i. indicator Liquid Sea! Level Blower Failure First Stage Flame Arrester High Tenp
Second Stage Flame Arrester High Tern a
Pilot Gas Prassyrs emergency Shutdown
Pilot Flame Failure
Power Failure
ri/seasnreiwt Approach
Fin at Breaker Thermocouple Thermocouple Pressure Gauge rioat Flam© Rod indicator to PLC
2. indicator Range High ar.c Low level Loss Of coil on starter ormoEOr failure
160 (Jeg. F *50 iieg F High: above 10 psi Low: be tow 1.5 psi
Nigh Condensate Tank Level
No Flame No Power
3. Performance Criteria
A, Data Representatives
Trie sensor supplies direct measurement of the liquid level
The sensor supplies direct .reformation on the slower operatic-sal status
The sensor supplies direc: information on tha associated temperature.
The sensor supplies direct info in at ion on tiie associated temperature.
Ti'e sensor supplies direct measurement of pilot gas pressure.
The sensor supplies direct measurement c-t the liquid sea!.
The sensor supplies d red information on she associated •eroperatye.
Tie sensor supplies direct status of power supply.
B, Verification of Operational Status Net applicable Not applicable Not applicable Not applicable Not applicable Moi acotscable Not applicable Not applicable
C QA/QC Practices anc
criteria
VCU ma ntenarsce acivtsies will be conducted on a semiannual basis, taking into asceun: manufacturer's recommendations. Visual inspections win ocsuroo s weekly basis.
VCU maintenance activities will be conducted on a semi-annual oasis, taking into account manufacturer's recommendations, visual msp&3tlcr*s will occur on a weekly basis.
VCU maintenance activities will be conducted on a semiannual bas.s, taking into accourt manufacturer's recoiRmendasicns. vsual inspections will occur on a weekly basis.
VCU maintenance activities will be conducted on a semi-annual oasis, taking ;n1c account manufacturer's recommend stiofts. visual inspections will occur on a weekly basis.
VCU maintenance activities wil be conducted on a semiannual basis, taking into account manufacturer's recoro mentations. Visual inspections wi occur on a weekly basis.
VCU maintenance activities will be conducted on a semi-ennual basis, taking into account manufacturer's 'ecommendations. Visual inspections win occur on a weekly basis
VCU maintenance activities will be conducted on a semi-annual basis, takhg into account niarutscturer's recommend at) or s visual inspections will occur on a vae-dy basis.
vcu maintenance activities will be conducted on a semi-annual basis, taking into account manufacturer's recommendation s. Vsual inspections will CK-C-Uf o n a weekly basis.
D Monitoring Frequency Continuous Continuous Continuous Continuous Continuous Continuous Continuous Continuous
Data Collection Procedure
Alarm screen st loedsrtg tzcM c ontroller.
Alarm screen a: oading rack controller.
Alafra scresrt al loading rack controller.
Alarm screen at ioBcing rack controller.
Alarm screen at loading rack controller.
Alarm screen at ioading rack contra ler.
Alarn screen at loading rack controller,
A'arm screen at loading rack controller.
Average Period Nr. average is taken. Mo average is
:aken.. No average is taken. Mo average is
taken. No average is taken. No average is
taken. No ave'age is taken.
No average is taken.
r
ATTACHMENT 4:
U.S. Environmental Protection Agency (EPA) Vapor Combustion Unit (VCU) Applicability Determination
U.S. Environmental Protection Agency Applicability Determination Index
Control Number: M020005
Category: MACT EPA Office: Region 1 Date: 06/18/2002 Title: Gasoline Vapor Combustion Unit Recipient: Douglas L. McVay Author: Michael P. Kenyon
Subparts: Part 63, R, Gasoline Distribution Facilities
References: 63.427
Abstract:
Q. Would EPA classify the John Zink Gasoline Vapor Combustion Unit as a thermal oxidization system or a flare?
A. In previous applicability determinations for similar units, EPA has determined that these types of units should be classified as thermal oxidation systems. Therefore, these units are subject to the temperature monitoring requirements of 40 CFR Section 63.427(a)(3). EPA had only intended for the flare monitoring requirements of 40 CFR Section 63.427(a)(4) to apply to open flame flares.
Letter:
June 18, 2002
Douglas L. McVay Associate Supervisor Engineering Office of Air Resources Rhode Island Department of Environmental Management 235 Promenade Street Providence, Rhode Island 02908-5767
Dear Mr. McVay:
The U.S. Environmental Protection Agency (EPA) has reviewed your letter dated April 25, 2002 regarding ExxonMobil's bulk gasoline terminal in East Providence, RI. ExxonMobil's bulk gasoline terminal is subject to 40 CFR Part 63 Subpart R, the national emission standard for hazardous air pollutants for gasoline distribution facilities. You requested a determination as to how EPA would classify the John Zink Gasoline Vapor Combustion Unit. This letter provides you with a written applicability determination.
In previous applicability determinations for similar units, EPA has determined that these types of units should be classified as thermal oxidation systems. Therefore, these units are subject to the temperature monitoring requirements of Section 63.427(a)(3). EPA had only intended for the flare monitoring requirements of Section 63.427(a)(4) to apply to open flame flares.
Although the facility is subject to the temperature monitoring requirements of Section 63.427(a)(3), the facility may apply for alternative monitoring under Section 63.8(4)(i). The facility should send any alternative monitoring requests to:
Denny Dart, Senior Enforcement Coordinator U.S. EPA New England One Congress Street Suite 1100 (CAP) Boston, MA 02114-2023
This applicability determination does not relieve ExxonMobil of responsibility for complying fully with any and all applicable federal, state and local laws, regulations and permits.
If you have any questions about this determination or need further assistance, please contact Susan Lancey of my staff at (617) 918-1656.
Sincerely,
Michael P. Kenyon, Chief Air Programs Branch
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