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PERMIT MEMORANDUM No. 2005-025-TVR DRAFT
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM September 25, 2006
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division
THROUGH: Kendal Stegmann, Supervising Attorney, Air Quality Division
THROUGH: Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits Section
THROUGH: Rhonda Jeffries, Environmental Program Manager
THROUGH: Peer Review, David Pollard, Regional Office at Tulsa
FROM: Herb Neumann, Regional Office at Tulsa
SUBJECT: Evaluation of Permit Application No. 2005-025-TVR
Magellan Pipeline Company, L.P.
West Tulsa Terminal
2120 S. 33 W. Avenue, Tulsa, Tulsa County
NW/4 Section 15, T19N, R12E (36.133° N, 96.034° W)
I. INTRODUCTION
Magellan Pipeline Company, L.P., requests renewal of their Part 70 (Title V) operating permit for their West Tulsa Terminal (SIC 4613, NAICS 48691). The permit expired April 4, 2006, but the renewal application was received October 6, 2005, in compliance with the 180-day renewal requirement. Magellan has been authorized to operate the Terminal as a major source under Permit No. 98-022-TV, issued March 29, 2001, and modified by Permit No. 98-022-TV (M-2), issued March 31, 2003. With the application for renewal, Magellan requests revisions to be incorporated into the permit. These requested revisions are addressed or noted at the appropriate point in the Memorandum and/or Specific Conditions.
II. PROCESS DESCRIPTION
The Terminal is a liquid petroleum products terminal consisting of vertical aboveground storage tanks, a four-spot loading rack and flare, a two-spot loading rack, and ancillary equipment. The Terminal receives liquid petroleum products via pipeline. Products are stored in aboveground tanks prior to loading into transport trucks. Floating roof tanks and a loading rack vapor combustion unit are used to control emissions from high vapor pressure products. The loading rack has a vapor recovery system that feeds collected vapors to a vapor combustor (or flare). The vapor combustor has a pilot flame that uses natural gas. An automatic interlock device shuts down the loading operation if the combustor malfunctions. During emergency events, products can also be directed from the incoming pipeline to a floating roof relief tank. These products are then pumped back into the outgoing pipeline when outgoing pipeline capacity permits. All pumps are powered by electricity.
Older parts of the facility date from 1931 while the four-spot rack was constructed in 1994. Most of the equipment at the facility was constructed before state or federal air pollution rules and regulations were promulgated and is considered to be grandfathered. Permits issued by DEQ and predecessor agencies before 1998 were subsumed by the initial Part 70 permit and a brief description of each may be found in the Process Description section of the memorandum supporting that initial permit.
The facility may have gasoline, jet fuel, natural gasoline, or various distillates in storage at any given time and in any given tank. However, the fixed roof tanks store only diesel or jet fuel, liquids with extremely low vapor pressures.
III. EQUIPMENT
All emissions units (EUs) at this facility are listed in the following emission unit groups (EUGs). Grandfathered units are identified as such.
EUG 1 Loading Rack
A four-spot rack for loading transports and a vapor combustion unit (VCU) for destruction of captured vapor, with all equipment constructed in 1994. The flare exhausts through an 8¢4² diameter opening at 45 feet above grade.
EUG 2 Loading Rack (Grandfathered)
A two-spot rack for loading transports with low-vapor pressure liquids only (JP-8) constructed in 1970.
EUG 3 Permitted Tanks
The permit modification that authorized the construction of EU #33 identified the new tank as T3502, but Magellan naming conventions identify it as T7003. This change in nomenclature has been made throughout this memorandum and in the Specific Conditions. All floating roof tanks store RVP 13 gasoline, except tank T116, which stores natural gasoline
EU # / Tank # / Type / Capacity / Diameter / Const. / Emission(bbl) / (ft) / Date / Limits?
3 / T116 / IFR / 2,000 / 24 / 1995 / Yes
17 / T1009 / IFR / 88,000 / 120 / 1976 / No
27 / T1504 / IFR / 134,800 / 150 / 1978 / No
29 / T2001 / IFR / 175,000 / 190 / 1976 / Yes
30 / T3501 / Fixed Roof / 343,500 / 229 / 1980 / Yes
33 / T7003 / IFR / 660,000 / 284 / 2003 / Yes
EUG 4 Grandfathered Tanks
All fixed roof tanks store jet kerosene. All floating roof tanks store RVP 13 gasoline.
EU # / Tank # / Type / Capacity / Diameter / Const. /(bbl) / (ft) / Date /
4 / T590 / IFR / 14,100 / 48 / 1971
5 / T591 / IFR / 14,100 / 48 / 1971
6 / T601 / IFR* / 13,750 / 60 / 1931
7 / T602 / IFR* / 13,750 / 60 / 1931
8 / T603 / IFR* / 14,740 / 60 / 1931
9 / T604 / IFR* / 13,720 / 60 / 1931
10 / T605 / IFR* / 13,710 / 60 / 1931
11 / T606 / IFR* / 14,740 / 60 / 1931
12 / T652 / IFR* / 18,000 / 60 / 1937
13 / T653 / IFR* / 18,000 / 60 / 1937
14 / T833 / IFR / 74,000 / 110 / 1971
15 / T834 / IFR / 72,500 / 110 / 1971
16 / T835 / Fixed roof / 78,800 / 110 / 1971
18 / T1205 / IFR / 109,600 / 134 / 1971
19 / T1206 / IFR / 108,900 / 134 / 1971
20 / T1207 / Fixed roof / 116,400 / 134 / 1971
21 / T1208 / Fixed roof / 116,400 / 134 / 1971
22 / T1326 / IFR* / 34,800 / 85 / 1950
23 / T1327 / IFR* / 34,700 / 85 / 1950
24 / T1328 / IFR* / 34,700 / 85 / 1950
25 / T1329 / IFR* / 34,800 / 85 / 1950
26 / T1330 / IFR* / 34,800 / 85 / 1950
28 / T1505 / IFR / 137,300 / 150 / 1971
31 / T910-1 / Fixed roof / 1,000 / 20 / 1937
32** / T224 / Pressure vessel / 1,190 / 10 / 1994
* These tanks were originally EFR tanks. The addition of external geodesic dome roofs during the period 1986-1988, decreasing emissions, did not subject these tanks to NSPS, regardless of the date of addition.
** This pressure vessel does not require permitting. It is listed here only for completeness.
EUG 5 Fugitives
This Group contains most of the ancillary equipment and includes emissions from pump seals, valves, flanges, and other such sources.
EUG Plantwide – Entire Facility
This EUG is established to cover all rules or regulations which apply to the facility as a whole.
Insignificant Sources
Permittee identified petroleum product additive tanks and Tank #T910-1, used for emergency pipeline relief, as insignificant sources in their initial Title V application. They also requested that site and groundwater remediation, tank cleaning and maintenance painting be considered as insignificant sources. All of these were accepted by DEQ as insignificant except for maintenance painting, which is a trivial source. The facility also has a cold degreasing station, which is an insignificant source requiring recordkeeping to show that usage does not exceed 60 gallons per month per station.
The application for renewal requested that a number of additional activities be considered, including a used oil tank, a 300-gallon diesel fuel tank for fueling on-site vehicles, meter provers, sumps, natural gasoline unloading, butane unloading, and an oil/water separator.
IV. EMISSIONS
Potential emissions have been updated from the previous operating permit.
EUG 1 (4 bay loading rack)
Loading rack losses are handled as either controlled or uncontrolled. Uncontrolled losses are based on the 98.7% capture efficiency attached to the tank trucks, all of which must have pressure inspection stickers before they may use the facility. This efficiency estimate is found in the Background Information Document (BID) for the Gasoline Distribution NESHAP promulgated in November 1994. The BID is published as EPA-453/R-94-002b, and relies on methodology developed in NSPS Subpart XX (Bulk Gasoline Terminals). Loading emission factors are determined by using equations and factors found in AP-42 (1/95). Equation 1 from Section 5.2 states that the loading loss for petroleum liquids is given by LL = 12.46 ´ S ´ P ´ M ¸ T, where the loss is in pounds per 103 gallons. Using a saturation factor of 1.0, a true vapor pressure of 7.2397 psia, a molecular weight of 62, and an ambient temperature of 60.31°F yield an emission factor of 10.749 lbs/103 gals. The vapor destruction system is considered to emit a conservatively high 35 mg of VOC per liter (35 mg/L) of gasoline loaded, which is the Subpart XX standard, and to have an efficiency of 98% with respect to all VOC from all other product emissions, except for the 1.3% losses mentioned above. The initial Title V permit memorandum showed historic loading in proportions of approximately 78% gasoline and 22% diesel. The permit authorized 20 MMBBL total loading per year and all loading was assumed to be gasoline to yield the conservatively highest emission estimates. Results of these calculations follow. Note that the column titled “Controlled Emissions” reflects the application of the 35 mg/L factor to total throughput, while the “Uncontrolled Emissions” column contains the 1.3% of LL not captured.
Product / ThroughputMMBBL/yr / Controlled Emissions / Uncontrolled Emissions / Total VOC (TPY)Gasoline / 20 / 122.68 / 58.69 / 181.37
The VCU gas pilot emits pollutants for which emission factors from Tables 1.4-1 & 2 of AP-42 (3/98) were used in the memorandum associated with the initial Title V permit. The gas pilot is rated at 54 SCFH and continuous use was conservatively assumed. PM and SO2 emissions were deemed to be negligible. VOC emissions are negligible compared with those identified above. The VCU itself consumes vapors from the rack. Making the conservatively high assumptions that all of the vapor collected at the rack is gasoline, that gasoline has heating value of 20,300 BTU per pound, and that all of it is combusted at the flare, yields a total vapor heat content of 116,616 MMBTU/year. Table 13.5-1 of AP-42 (9/91) gives emission factors for NOx, CO and “soot.” Because this is a smokeless flare, the soot or PM factor is effectively zero.
EmissionsSource / Pollutant / Emission factor / Lb/hr / TPY
Pilot / NOx / 100 lb/MMCF / 0.01 / 0.02
CO / 84 lb/MMCF / .01 / 0.02
Flare / NOX / 0.37 lb/MMBTU / 4.92 / 21.57
CO / 0.068 lb/MMBTU / 0.90 / 3.96
Permittee has obtained emission factors from the manufacturer of the flare and calculates the following emissions, which are used in the tabulation of results for the facility, since they are conservatively higher than the preceding calculations.
Pollutant / Factor / Throughput / EmissionsCO / 0.0835 lb/103 gal / 96,000 gph, 8.4 × 108 gpy / 8.02 lb/hr, 35.1 TPY
NOX / 0.0334 lb/103 gal / 3.21 lb/hr, 14.0 TPY
EUG 2 (Two bay loading rack)
This rack loads only JP-8, which is military fuel oil with a true vapor pressure of 0.0088 psia. Equation 1 from Section 5.2 of AP-42 (1/95) states that the loading loss for petroleum liquids is given by LL = 12.46 ´ S ´ P ´ M ¸ T, where the loss is in pounds per 103 gallons. Using a saturation factor of 1.0, a molecular weight of 130 and an ambient temperature of 60.31°F yield an emission factor of 0.0274 lbs/103 gals. The facility assumes an upper limit of 1,000,000 barrels per year at this rack, giving annual emissions of 0.575 tons of VOC. Assuming that the rack is capable of loading 8,000 gallons into each of three trucks at each of the two spots in an hour yields VOC emissions of 1.32 lbs/hr.
EUG 3 and EUG 4
The following criteria were specified to determine the potential to emit (PTE) for these EUGs for the renewal application.
All fixed roof tanks store jet kerosene and all floating roof tanks store RVP 13 gasoline, except tank T116, which stores natural gasoline. Relief tank T910-1 experiences two turnovers per year, the rack tanks (T601, T602, T603, T604, T605, T652, and T653) experience 175 turnovers per year, and all other tanks experience 104 turnovers per year. Additionally, T7003 was identified in the Tanks 3.1 information supplied with the application to construct the tank as having diameter of 64 feet. This datum was corrected in information supplied during initial inspection of the tank prior to filling. The initial estimate also used natural gasoline, with average vapor pressure 7.73 psia, while this renewal application uses RVP 13 gasoline, with average vapor pressure 7.24 psia. Tanks 4.0 is used throughout.
EUG 3 (Permitted tanks)
Tank # / Contents / VOC Emissions (TPY)Current / Initial TV / Change
T116 / Natural gasoline / 2.17 / 1.46 / 0.71
T1009 / RVP 13 gasoline / 4.99 / 4.74 / 0.25
T1504 / RVP 13 gasoline / 17.19 / 10.78 / 6.41
T2001 / RVP 13 gasoline / 21.29 / 10.71 / 10.58
T3501 / Jet kerosene / 11.14 / 11.04 / 0.10
T7003 / RVP 13 gasoline / 27.88 / 8.29 / 19.59
Totals / 84.66 / 47.02 / 37.64
EUG 4 (Grandfathered tanks)
Tanks 3.1 was used to calculate emissions from each tank, assuming contents with the highest permitted vapor pressure and 104 turnovers per year. Emissions are assumed to be continuous.
Tank # / Contents / VOC Emissions (TPY) /Current / Initial TV / Change /
T590 / RVP 13 gasoline / 4.08 / 3.31 / 0.77
T591 / RVP 13 gasoline / 4.08 / 3.31 / 0.77
T601 / RVP 13 gasoline / 0.93 / 0.82 / 0.11
T602 / RVP 13 gasoline / 0.93 / 0.82 / 0.11
T603 / RVP 13 gasoline / 4.07 / 3.82 / 0.25
T604 / RVP 13 gasoline / 4.06 / 3.81 / 0.25
T605 / RVP 13 gasoline / 0.93 / 0.82 / 0.11
T606 / RVP 13 gasoline / 4.07 / 3.82 / 0.25
T652 / RVP 13 gasoline / 0.82 / 0.69 / 0.13
T653 / RVP 13 gasoline / 0.83 / 0.69 / 0.14
T833 / RVP 13 gasoline / 7.83 / 7.47 / 0.36
T834 / RVP 13 gasoline / 11.53 / 5.87 / 5.66
T835 / Jet kerosene / 2.54 / 3.15 / (.59)
T1205 / RVP 13 gasoline / 9.40 / 9.61 / (.21)
T1206 / RVP 13 gasoline / 9.40 / 8.97 / 0.43
T1207 / Jet kerosene / 3.76 / 3.75 / 0.01
T1208 / Jet kerosene / 3.76 / 4.67 / (.91)
T1326 / RVP 13 gasoline / 3.33 / 3.17 / 0.16
T1327 / RVP 13 gasoline / 0.96 / 0.90 / 0.06
T1328 / RVP 13 gasoline / 0.96 / 0.90 / 0.06
T1329 / RVP 13 gasoline / 0.96 / 0.90 / 0.06
T1330 / RVP 13 gasoline / 3.33 / 3.17 / 0.16
T1505 / RVP 13 gasoline / 6.39 / 7.33 / (.94)
T910-1 / RVP 13 gasoline / 2.72 / * / 2.72
Totals / 91.67 / 81.77 / 9.90
* Not evaluated in the initial Title V permit analysis.