TO:	EPA Docket No. EPA-HQ-OAR-2003-0146

		

FROM:	Bob Lucas, EPA/SPPD 

DATE:	July 27, 2007

SUBJECT:	Gasoline Loading Racks:  Control Options and Impact Estimates 

I.	Purpose

This memorandum documents the methodology used to identify the control
options and estimate the costs and environmental impacts for gasoline
loading rack control options. 

II.	Background

Section 112(f) of the Clean Air Act Amendments (CAA) directs the U.S.
Environmental Protection Agency (EPA) to assess source categories
regulated under Section 112(d) of the CAA and determine whether any
human health or environmental risks remain from the continued emissions
of hazardous air pollutants (HAPs) following implementation of maximum
achievable control technology (MACT) standards.  The CAA further states
that if the MACT standards do not reduce lifetime excess cancer risk to
the most exposed individual to less than one in one million, EPA must
set additional standards to protect human health and the environment, in
accordance with the interpretation set forth in the Benzene NESHAP. 
Additionally, the EPA is required to review these technology-based
standards and to revise them “as necessary (taking into account
developments in practices, processes and control technologies)” no
less frequently than every 8 years, under CAA section 112(d)(6).  The
Refinery MACT 1 (40 CFR Part 63 Subpart CC) was promulgated over 8 years
ago and is now being reviewed.   

III.	Summary of Existing Refinery MACT 1 Storage Vessel Control
Requirements

Refinery MACT 1, subpart CC requires gasoline loading racks located
within a gasoline terminal that is above a certain size to meet the
control requirements specified in part 63 subpart R, which references
requirements in 63.502 of 40 CFR part 60, subpart XX (Standards of
Performance for Bulk Gasoline Terminals).  Refinery MACT 1 defines Group
1 gasoline loading rack as: 

as any gasoline loading rack classified under Standard Industrial
Classification code 2911 that is located within a bulk gasoline terminal
that has a gasoline throughput greater than 75,700 liters per day
[20,000 gallons per day].  Gasoline throughput shall be the maximum
calculated design throughput for the terminal as may be limited by
compliance with enforceable conditions under Federal, State, or local
law and discovered by the Administrator and any other person.

Group 1 gasoline loading rack emissions must not exceed 10 milligrams of
total organic compounds per liter of gasoline loaded.

IV.	Identification of Control Options

Control options for gasoline loading racks at bulk gasoline terminals
with lower daily throughput cutoff values were reviewed.  Two gasoline
loading rack control options were identified.

  

Option 1:  limit emissions from gasoline loading racks located at a bulk
gasoline terminal that has a throughput greater than 56,780 liters per
day (15,000 gallons per day) to 10 milligrams of total organic compounds
per liter of gasoline loaded.

Option 2:  limit emissions from gasoline loading racks located at a bulk
gasoline terminal that has a throughput greater than 37,850 liters per
day (10,000 gallons per day) to 10 milligrams of total organic compounds
per liter of gasoline loaded.

V.	Impact Estimates for Model Gasoline Loading Racks

Model Plant Gasoline Loading Racks 

Model plants for loading rack controls from the proposal BID for Stage I
gasoline distribution were used to estimate control costs.  The model
plants from the proposal BID for Stage I ranged in size from 100,000
gal/day to 1,000,000 gal/day and were significantly larger than the
throughputs in the options for this analysis.  The smallest model plant
from the Stage I analysis was selected, for upgrade of gasoline loading
rack controls (Model Plant 1, Table 5-3 for Bulk Gasoline Terminal Model
Plant Parameters) to simulate gasoline loading operations at Refinery
MACT 1 sources that would be subject to the control options.  Rough
estimates were made to scale the costs for Model Plant 1 to 2006 costs
and to the 15,000 gal/day and the 10,000 gal/day throughputs
(represented by Model Plant A at 17,000 gal/day and Model Plant B at
12,000 gal/day throughput, respectively)

Model Plant Baseline Emissions 

Baseline emissions were estimated using AP-42 emissions factors for bulk
terminals with gasoline throughputs of 17,000 gal/day and 12,000
gal/day.  Using equation 1 from section 5.2 of AP-42, the loading loss
was estimated to be 6.77 lb VOC/1000 gal loaded, based on a saturation
factor of 0.6 (assumed submerged loading and dedicated normal service
for tanker trucks or railcars), a vapor pressure of 7.4 psia based on
gasoline with RVP 10, molecular weight of 68 lb/lb mole, and temperature
of 80ºF.  Based on average refinery waste stream compositions (Refinery
MACT 1), the HAP emissions were assumed to be 10.8 percent of the total
VOC emissions.  Baseline emissions for both VOC and HAP for Options 1
and 2 are shown in Table 1.

Table 1.  Model Plant Emissions Impacts of Refinery Gasoline Loading
Rack Control Options

Model Plants	VOC Baseline emissions, ton/yr	VOC Emission Reduction from
Baseline, ton/yr	HAP Baseline emissions, ton/yr	HAP Emission Reduction
from Baseline, ton/yr

Model Plant A:  Throughput 17,000 gal/day	20.99	19.94	2.27	2.15

Model Plant B:  Throughput 12,000 gal/day	14.82	14.08	1.60	1.52



Model Plant Emissions Reductions

Emissions reductions for control of emissions from gasoline loading
racks were estimated based on control with a thermal oxidizer achieving
an efficiency of 95 percent.  The emissions reductions for VOC and HAP
are shown in Table 1.

Model Plant Control Costs 

Control costs were taken from the proposal BID for Stage I gasoline
distribution (Model Plant 1, Table 7-11 for Bulk Terminal Loading Rack
Costs – Upgrade of 80 mg/l to 10 mg/L Unit).  As the cost estimates
were originally developed in 1990, the costs were escalated to 2006
dollars using the Chemical Engineering Plant Cost Index (CEPCI).  The
average CEPCI in 1990 was 357.6; the average CEPCI in 2006 was 499.6. 
The costs were also scaled based on equipment size using the following
relationship:, 

 				Eqn 1

	Where: 

			C2 = cost of equipment having size Q2

			C1 = cost of equipment having size Q1

			Q2 = size of equipment E2

			Q1 = size of equipment E1

Annual operating costs were roughly escalated to 2006 dollars and also
scaled for the equipment size (i.e., 17,000 gal/day and 12,000 gal/day
throughputs).  The model plant control costs for Option 1 were
considered to be average costs per bulk gasoline terminal.

Control costs for Option 2 were estimated using the same approach and
costs are shown in Table 2.

Table 2.  Model Plant Capital and Annual Costs for Thermal Oxidizer
Control of Refinery Gasoline Loading Rack

Costs	Thermal Oxidizer, 1990 $	Thermal Oxidizer, 2006 $	Model Plant A: 
Thermal Oxidizer, scaled to smaller unit (17,000 gal /100,000 gal) a
Model Plant B:  Thermal Oxidizer, scaled to smaller unit (12,000 gal
/100,000 gal) a

Capital costs b

Unit purchase cost	108,000	151,000	52,100	42,300

Unit installation cost	92,000	128,000	44,300	35,900

TCI	200,000	279,000	96,400	78,200

Annual costs 

Electricity c	1,000	1,280	444	360

Pilot gas d	7,300	19,600	6,780	5,500

Maintenance e	3,500	4,890	1,690	1,370

Operation labor f	6,800	16,400	5,670	4,600

Capital recovery g	32.5	45,500	15,700	12,800

Taxes, insurance, and administration h	8,000	11,200	3,860	3,130

TAC	59,100	98,900	34,100	27,700

a  The costs were also scaled based on equipment size using equation
1.3, 4

b  Rough estimates of capital costs were made to escalate the 1990 costs
to 2006 costs based on CEPCI of 357.6 for 1990 and 499.6 for 2006.

c  Electricity usage was not reported for model plant 1 in the proposal
BID for Stage I and neither was the unit cost for electricity in 1990. 
As an alternative, the costs were scaled based on a ratio of unit costs
for 1990 to unit costs for 2006.  Electricity costs were $0.0474/kWhr in
1990 and were $0.0609/kWhr in 2006., 

d  Annual pilot gas (i.e., natural gas) usage was not reported for model
plant 1 in the proposal BID for Stage I.  As an alternative, the costs
were scaled based on a ratio of unit costs for 1990 to unit costs for
2006.  Natural gas costs were $2.93/1000 ft3 in 1990 and were $7.88/1000
ft3 in 2006.,   

e  Maintenance hours and labor rates were not reported in the proposal
BID for Stage I.  The maintenance costs were roughly escalated using a
ratio of the CEPCI for 1990 and 2006.

f  Operating labor is 1 hr/day for 340 day/yr and the operator labor
rate is $48.26/hr.

g  The capital recovery costs were estimated as 0.163 of capital costs. 
The CRF is based on interest rate of 10 percent and equipment life of 10
years.

h  Taxes, insurance, and administration costs are 4 percent of capital
costs.



Model Plant Emissions Reductions and Control Cost Impacts

The model plant impacts are summarized in Table 3.  The cost
effectiveness of throughput cutoffs for Option 1 at 15,000 gal/day and
for Option 2 at 10,000 gal/day are $15,900/ton of HAP and $18,200/ton of
HAP, respectively.

Table 3.  Model Plant Impacts of Refinery Gasoline Loading Rack Control
Options

Model Plants	Total Capital Investment, $	Total Annualized Costs, $	HAP
Emission Reduction from Baseline, tons	Total Cost Effectiveness for 
HAP, $/ton HAP

Model Plant A:  Throughput 17,000 gal/day	$96,400	$34,100	2.15
$15,900/ton HAP

Model Plant B:  Throughput 12,000 gal/day	$78,200	$27,700	1.52
$18,200/ton HAP



Technical Memorandum – Gasoline Loading Racks:  Control Options and
Impact Estimates

July 27, 2007

Page   PAGE  5 

Technical Memorandum

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