Title V Compliance The Bay Area Experience. Rob Ferry the TGB partnership Hillsborough, NC

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Philippa Hutchinson
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1 Title V Compliance The Bay Area Experience Rob Ferry the TGB partnership Hillsborough, NC Rob.Ferry@TGBpartnership.com

2 Title V Permitting So Many Permits So Little Time Dozens of potential regulatory scenarios. And hundreds of paths by which a tank may get there. Permit info preferably specific to each tank. For the permit to be a meaningful list of requirements. Develop standard permits for each case. A standard set of permit templates would be helpful. Then match each tank to the right standard. But applicability determination can be overwhelming.

3 San Francisco Bay Area Story Cooperation Eases the Pain Standard BAAQMD format for all refineries. Everybody uses same format to record the required info. Collectively develop standard templates. Tables of permit data specific to each regulatory scenario. District approves the templates up front. Facilities then have pre-approved permit templates. Match each tank to the correct template. While the process has been enormously simplified, this last step is still overwhelming.

4 Applicability Determination Which Template to Assign a Tank To? Which EPA rule(s) apply to a given tank? More than a dozen federal rules apply to storage tanks. Which local rule requirements apply? And which combination of local/federal requirements? Subject to controls, or just recordkeeping? Or even controls under one rule, just records under another. EFRT, IFRT, routed to control device, other? The potential number of scenarios becomes overwhelming. Solution: simplify and automate.

5 Simplify the Problem Find Scenarios to Eliminate Bay Area refinery tanks were not subject to: Benzene Storage NESHAP, The HON, or Refinery MACT new source requirements. Federal rules remaining to consider: NSPS K, Ka, and Kb, Refinery MACT (existing sources). [BWON & NSPS QQQ in wastewater module].

6 Automate the Process Of Assigning Tanks to Templates Though reduced, problem is still complex. 30 templates remained after rule elimination. A couple of hundred potential paths remain. Electronic decision tree automates assignment. This tool also facilitates the approval process. District approves the electronic tool upfront. Refineries use the tool for template assignment. District uses the tool to confirm.

7 How it Works Select period in which tank was built. From a menu defined by effective dates of the rules. Select tank capacity / liquid properties. From a table specific to the selected time period. Select category of control option. EFRT / IFRT / Routed to Control Device. The tool returns a tank-specific template. The template lists the specific provisions of the rules that apply to that tank. If an IFRT, only IFRT provisions; if only subject to recordkeeping, then only the applicable recordkeeping provisions, etc.

8 Hypothetical Case Storage Tank Example Construction commenced: April 15, 1983 Tank capacity: 100,000 bbl (4.2 MM gal.) Liquid HAP content: 3.5% Stock true vapor pressure: 1.8 psia. Category of Control Option: IFRT

9 First Step Construction Period When was the tank built, or most recently modified or reconstructed? On or after: But prior to: Go to page: 1) January 4, ) January 4, 1967 June 12, ) June 12, 1973 March 9, ) March 9, 1974 January 9, ) January 9, 1976 May 19, ) May 19, 1978 July 24, ) July 24,

10 Second Step Select Select Cluster Link Based on Capacity, HAP %, TVP Tanks built on or after May 19, 1978 but prior to July 24, Capacity (gallons) < < < 10,000 10,000 < < 20,000 20,000 < < 40,000 40,000 < < 47,000 47,000 < 47,000 < Stored Liquid HAP < 4% HAP > 4% Gasoline cluster 0 cluster 14 cluster 16 per TVP per TVP per TVP per TVP Other, with TVP (psia) of: below below below below TVP < 0.5 cluster 0 cluster 0 cluster 1b cluster 1b cluster 1b cluster 1b cluster 1b 0.5 < TVP, & TVP < 1.5 cluster 0 cluster 2 cluster 10 cluster 10 cluster 11 cluster 11 cluster < TVP, & TVP < 11. cluster 0 cluster 2 cluster 16 cluster 11 cluster 20 cluster 20 cluster < TVP cluster 0 cluster 5 cluster 13 cluster 13 cluster 22 cluster 22 cluster 28

11 Third Step Select Select Control Device CLUSTER 20 BAAQMD requirement: External floating roof. Federal EPA requirement: NSPS Subpart Ka; external floating roof. Select a template from the menu below, unless instead of an external floating roof, the tank is controlled with: An internal floating roof use Cluster 21, or A fixed roof routed to a control device use Cluster 22. Template Menu Table IV: all applicable provisions. Table VII: applicable limits & compliance monitoring. Table IX-A: non-applicable provisions.

12 This Is It! CLUSTER 21 BAAQMD requirement: Internal floating roof. Federal EPA requirement: NSPS Subpart Ka; internal floating roof. Select a template from the menu below. Template Menu Table IV: all applicable provisions. Table VII: applicable limits & compliance monitoring. Table IX-A: non-applicable provisions. Side-by-side comparison: the control requirements of Regulation 8-5 are more stringent than those of NSPS Subpart Ka except for some ambiguity with respect to guidepole requirements. Table IX-B: To facilitate uniformity of requirements among the floating-roof tanks at a facility, the requirements of NSPS Subpart Ka and BAAQMD 8-5 may be subsumed into a synthesized set of most stringent requirements that includes the recordkeeping and reporting requirements specified in Refinery MACT. The subsumed provisions are listed in Table IX-B.

13 Cluster 21 Cluster 21 reached via Cluster 20 (EFRT). From the table specific to the given time period. Subject to IFRT requirements of: BAAQMD Regulation 8 Rule 5, and NSPS Subpart Ka. Template includes five tables. Table IV (applicable provisions) critical for permit. Table VII useful for compliance checklist. Other tables are for permit shield purposes.

14 Adaptations for Future Use Title V permit renewals. But switch out local rule for use in other jurisdictions. Serious streamlining. To really get to the single set of requirements result. Smart task management. Combine the decision tree with a database. Automatic prompt of inspection/reporting deadlines. Keep track on a tank-by by-tank basis. We re creating this for a refinery now in another jurisdiction.

15 TankCOP* Compliance Optimization Program Determines rule applicability. As in the Title V Permit electronic decision tree. Determines inspection/reporting deadlines. Tracks: Specific to each individual tank. Completed inspections (& associated events), Liquid service changes, and Tank construction events. Recalculates applicability & deadlines. * TGB trade name.

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