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Part 1. National Emission Standards for Hazardous Air Pollutants (NESHAPS)
The September 19, 1995 federal register contained the final rule of 40 CFR 63, Subpart Y concerning NESHAPS for marine tank vessel loading operations. This is a summary of the rules including important compliance dates. The final rule also addresses standards specifically for the Valdez Marine Terminal (VMT) source in Alaska, but they are not summarized here. The rule requires certain new and existing marine tank vessel loading operations to control air emissions of volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) using reasonably available control technology (RACT). Additionally, this rule requires all new major sources and certain existing major sources to control HAPs emissions using maximum achievable control technology (MACT). The effective date of this rule was September 19, 1995.
Applicability The following table summarizes the applicability requirements for new and existing sources subject to the MACT standards.
The rule does not apply to the following marine tank vessel loading operations:
In addition, several other types of operations have exemptions from specific MACT control standards as shown in the table below. Exemption from certain control standards does not automatically result in exemption from other portions of this rule such as recordkeeping and reporting.
Compliance Date Existing major sources with emissions of 10 tons/yr of any single HAP or 25 tons/yr of total HAPs from marine vessel loading operations must comply with the provisions no later than September 19, 1999. If an existing source increases its emissions after September 19, 1999 to above 10 tons/yr of any single HAP or 25 tons/yr of total HAPs, it must comply with the MACT standards within 3 years following the increase in emissions. A new source that has an initial startup date on or before September 19, 1999 must be in compliance no later than September 19, 1999. A new source that has an initial startup date after September 19, 1999 must comply with the provisions immediately upon startup. MACT Standards Existing major sources with single HAP emissions of 10 tons/yr or total HAP emissions of 25 tons/yr and all new sources are required to equip the terminal with a vapor collection system. This system must be designed to collect HAP vapors displaced during marine loading operations and to prevent HAP vapors collected at one loading berth from passing through another loading berth to the atmosphere. Only marine tank vessels that are vapor-tight and compatible to the terminal's vapor collection system are allowed to be loaded. If the marine vessel's vapor tightness cannot be documented, then a leak test can be performed during the normal loading operation. The results from the test should be documented prior to the departure of the vessel. Existing major sources (except offshore loading terminals) with single HAP emissions of 10 tons/yr or total HAP emissions of 25 tons/yr are required to reduce HAP emissions by 97 weight percent. New sources (except offshore loading terminals), however, must reduce HAP emissions by 98 weight percent. New major offshore loading terminals are required to reduce HAP emissions by 95 weight percent.
Applicability The following table summarizes the applicability requirements for new and existing sources subject to the RACT standards.
The rule does not apply to the following marine tank vessel loading operations:
In addition, loading where emissions are reduced by a vapor balancing system is exempt from 40 CFR 63.562(e)(3) and (4). RACT Compliance Date Existing and new sources with an initial startup date on or before September 19, 1998 were required to be in compliance with the provisions pertaining to the RACT standards no later than September 19, 1998. A new source with an initial startup date after September 19, 1998 must be in compliance immediately upon startup. If a source with a throughput of less than 10,000,000 bbl/yr gasoline or 200,000,000 bbl/yr crude oil increases its throughput so that it exceeds that limit, it must be in compliance within 3 years following the exceedance of the threshold level. Sources that are subject to the RACT standards may apply for approval from the administrator for an extension of the compliance date of up to 1 year if they can demonstrate that the additional time is necessary for installation of the control device. RACT Standard All sources with throughputs greater than 10,000,000 bbl/yr of gasoline or 200,000,000 bbl/yr of crude oil are required to equip the terminal with a vapor collection system that is designed to collect VOC vapors displaced during marine loading operations and to prevent VOC vapors collected at one loading berth from passing through another loading berth to the atmosphere. These sources with an initial startup date on or before September 19, 1998 were required to provide proof to the agency, no later than September 19, 1997, that they have commenced construction of the vapor collection system. Only marine tank vessels that are vapor-tight and compatible to the terminal's vapor collection system are allowed to be loaded. If the marine tank vessel's vapor tightness cannot be documented, then a leak test can be performed during the normal loading operation. The results from the test should be documented prior to the departure of the vessel. Sources that are subject to the standard are required to reduce VOC emissions from marine loading operations by 98 weight percent when using a combustion device or by 95 weight percent when using a recovery device. Compliance can also be shown by reducing gasoline loading emissions to an outlet VOC concentration of less than or equal to 1000 ppmv. The following notification, testing, recordkeeping, and reporting requirements are identical for both the MACT and RACT rule. Notification Sources subject to this rule are required to meet notification requirements. Sources with initial startup prior to the effective date of September 19, 1995 were required to notify the administrator in writing that the source is subject to the relevant standard no later than September 19, 1996. Sources with startup after September 19, 1995 but before the compliance date (September 19, 1998 for sources subject to the RACT rule and September 19, 1999 for sources subject to the MACT rule) must notify the administrator in writing that the source is subject to the standard no later than 365 days after initial startup or 120 days after initial startup, whichever occurs before notification of the initial performance test. For sources that are intended to be constructed or reconstructed, the initial notification should be submitted as soon as practicable before the construction or reconstruction is planned to commence. Additional notification requirements for newly constructed or reconstructed sources include notification of the date when construction or reconstruction was commenced no later than 30 days after such date, notification of the anticipated date of initial startup between 30 and 60 days before such date, and notification of the actual date of startup within 15 calendar days after that date. Sources subject to this rule must submit notification of an initial performance test at least 60 days before the performance test is conducted to allow for review and approval of the site-specific test plan. Testing Sources that are subject to this rule are required to conduct an initial performance test within 180 days after the compliance date. In this performance test, sources subject to the MACT and/or RACT standards are required to determine the reduction of HAP emissions and/or VOC emissions for all combustion or recovery devices other than flares. If a flare is used as the combustion device, determination of compliance is established if a pilot flame is present in the flare. Recordkeeping Sources subject to this rule are required to keep documentation on file that shows current vapor tightness testing results of each vessel loaded. Updates to this file should be made at least once per year. Records of all measurements, calculations, and other relevant documentation that were used to identify materials that are exempted from this rule must be kept. In addition, records should be kept for 5 years of all emissions calculation determining annual HAPs emissions. If a leak in the vapor collection system or control device is detected, the source must record the date of the inspection, the findings, the leak determination method, and what corrective actions were taken to repair the leak. These records should be maintained for 5 years. Reporting Within 30 days following the end of each calendar year, a report of all excess emissions or exceedances of process or control system parameters is required. The frequency of this report may be increased to semi-annual if the source experiences excess emissions.
If you have any questions or would like additional information, please call Joerg Windolph, P.E. at 512-255-9999 or email jwindolph@waid.com .
(Prepared November 10, 1995)
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