UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	March 24, 2008

SUBJECT:	Technical Support Document - Maryland; Reasonable Available
Control Technology Requirements for Marine Vessel and Barge Loading

			

FROM:	Gobeail McKinley, Biologist

Air Quality Planning Branch /s/

TO:		File EPA-R03-OAR-2007-1120

		          

THRU: 	Cristina Fernandez, Branch Chief 

Air Quality Planning Branch /s/

A.  BACKGROUND

On October 24, 2007, the Maryland Department of Environment (MDE)
submitted a revision to its state implementation plan (SIP).  The SIP
revision (Maryland SIP #07-12) includes amendments to Regulation .01 and
adoption of new Regulation .08 under COMAR 26.11.13 Control of Gasoline
and Volatile Organic Compound Storage and Handling.  This adoption
controls emissions of Volatile Organic Compounds (VOCs) throughout the
state.  MDE submitted these SIP revision requests pursuant to the
reasonable available control technology (RACT) requirements of sections
182 and 184 of the Clean Air Act (CAA).  The EPA has developed a Maximum
Achievable Control Technology (MACT) standard for barge loading (40 CFR
Part 63 Subpart Y).  However, the liquid throughput threshold requiring
controls is very high.  Therefore, it is necessary to develop RACT
requirements for this activity.  Maryland has adopted VOC regulations
for the amendments and new regulation to establish RACT requirements for
marine vessel and barge loading.

A marine vessel is defined as any tank ship or barge that transports
VOCs in bulk as cargo.  Marine tank vessel loading operations are
facilities that load and unload liquid commodities (e.g., crude oil,
gasoline, jet fuel, kerosene, toluene, alcohols, fuel oil Numbers 2 and
6, some chemicals, and groups of solvents or petrochemical products,
etc.) in bulk.  Due to the increased demand for ethanol which is blended
with gasoline, there is a renewed interest in transferring liquid
products from stationary storage tanks into marine vessels or barges for
further distribution.  During marine tank vessel and barge loading
operations, emissions result as the liquid that is being loaded into the
vessel displaces vapors from the vessel's tank.  VOC vapors are released
from the vent of the barge in quantities that may be significant and
contribute to ground level ozone.  VOC emissions, together with nitrogen
oxides are precursors to the formation of ground level ozone.  Ground
level ozone, one of the principal components of smog, is a serious air
pollutant that harms human health and the environment. High levels of
ozone can damage the respiratory system and cause breathing problems,
throat irritation, coughing, chest pains, and greater susceptibility to
respiratory infection.  High levels of ozone also cause serious damage
to forests and agricultural crops, resulting in economic losses to
logging and farming operations.  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r
1 

For the transfer of gasoline, about 3 tons of VOC are discharged into
the air for a barge having a 2 million gallon capacity.  The 3 tons of
emissions are usually discharge within a 24-hour period. Typically, a
barge is retrofitted with a connection for a vapor return line that
captures the VOCs.  The captured vapors are transferred through the
return line into an efficient control device for collection or
destruction.  In Maryland, there is no requirement to install a control
device for the collective vapors. 

B.    SEQ CHAPTER \h \r 1 EPA REQUIREMENTS

This SIP revision was submitted pursuant to the RACT requirements of the
CAA.

RACT is the lowest emission limit that a particular source is capable of
meeting by the application of the control technology that is reasonably
available considering technological and economic feasibility.  Maryland
is located in the Ozone Transport Region (OTR) that was statutorily
created by section 184 of the CAA.  Section 184(b)(1)(B) of the CAA
requires States to implement RACT regulations on all VOC sources that
have the potential to emit 50 tons per year (TPY) or more.  In addition,
section 182(b)(2) requires States to implement RACT regulations on all
“major” sources of VOC in moderate or above ozone nonattainment
areas.  Major VOC sources are those with the potential to emit at least
100 TPY in moderate areas, 50 TPY in serious areas, and 25 TPY in severe
areas.  

Maryland is in the OTR and the State is required to implement RACT
regulations for all sources with the potential to emit 50 TPY or more,
throughout the State.  In Maryland's severe ozone nonattainment areas,
RACT is required for all VOC sources with the potential to emit 25 TPY
or more.  

STATE SUBMITTAL

Maryland’s amendments and new regulation establish RACT requirements
for marine vessel and barging loading.  The new definition amended in
.01 of COMAR 26.11.13 is marine vessel which is defined as any tank ship
or barge that transports VOCs in bulk as cargo. 

The proposed new regulation .08 of COMAR 26.11.13 requires the following
applicability: (1) in Allegheny, Caroline, Dorchester, Garrett, Kent,
Queen Anne’s, St. Mary’s, Somerset, Talbot, Washington, Wicomico, or
Worchester counties, the requirements of this regulation apply to the
transfer of VOCs from a stationary storage tank into a marine vessel if
the total emissions from all marine vessel loading at the premises
during a calendar year are equal to or exceed 50 tons; (2) in Baltimore
City or Anne Arundel, Baltimore, Calvert, Carroll, Cecil, Charles,
Frederick, Harford, Howard, Montgomery, or Prince George’s counties,
the requirements of this regulation apply to the transfer of VOCs from a
stationary storage tank into a marine vessel if the total emissions from
all marine vessel loading at the premises during a calendar year are
equal to or exceed 25 tons; (3) the proposed new regulation applies to
all transfers of any amount of VOCs, except fuel oils, from stationary
storage tank into a marine vessel. 

The transfer of VOCs into a marine vessel subject to this regulation is
prohibited unless: (1) the marine vessel is equipped with a vapor return
line; and the vapor is vented into an air pollution control device that
is demonstrated to recover or destroy at least 90 percent of the
captured vapor; (2) the vapor control system shall be constructed,
operated, and maintained so that VOC vapor leaks are minimized during
the transfer of VOCs into a marine vessel; (3)VOCs may not be
transferred into a marine vessel unless the vessel has been leak tested
or pressure tested within the past 2 years using the Coast Guard
requirements at 33 CFR Section 156.150.

The owner and operator of a premises subject to this regulation shall
record and maintain the following information: the date and time when
each marine vessel commenced and completed the loading of VOCs;
identification of the product that was loaded into the marine vessel and
the total volume loaded; and the date the date when each marine vessel
used was leak tested or pressure tested.  The records shall be
maintained for a period of less than 5 years and made available to the
Department upon request and to members of the public subject to the
provisions of the Maryland Public Information Act, State Government
Article.

C.  EPA EVALUATION: 

Maryland’s amendment to Regulation .01 and adoption of new Regulation
.08 under COMAR 26.11.13 Control of Gasoline and Volatile Organic
Compound Storage and Handling adequately describes the sources,
operators, and owners as well as the RACT requirements. Based on the
technically feasibility of the cost of controls, EPA believes that a
reduction level of 90 percent would be reasonable for marine vessel and
barge loading.  For sources that require controls, these amendments have
an estimated emissions reduction potential of 2.7 tons of VOCs for each
2,000,000 gallon barge that is loaded in Maryland. 

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

  SEQ CHAPTER \h \r 1 The new and amended VOC RACT regulations submitted
by the state of Maryland as SIP revisions on October 24, 2007 strengthen
Maryland's SIP.  The revisions will result in the reduction of VOC
emissions from the affected sources.  EPA approval of this SIP revision
is recommended. 

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