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APPENDIX B STATUS OF STATE AND LOCAL VAPOR CONTROL REQUIREMENTS AFFECTING MARITIME OPERATIONS A survey sheet was sent to 62 state and local environmental or air pollution control agencies in an effort to assemble an inventory of stipulations that affect hydrocarbon emissions from tankships and tank barge liquid transfer operations in U.S. coastal, river, and lake ports. A copy of the survey sheet is attached as Figure B-1. Thirty-seven responses were received including 26 from states, 7 from counties and districts, and 3 from cities. One county agency responded that its state has jurisdiction. Table B-1 summarizes the responses. Responses or summaries are also included for the key ques- tions in the survey. Results may be summarized as follows: 1. Out of 36 agencies, only 4 have regulations that require con- trols: Bay Area Air Quality Management District, California; Florida Department of Environmental Regulation; State of Michigan Department of Natural Resources; and Wayne County Department of Health operating under Michigan state regulations. However, Florida and Wayne County apparent- ly have no facilities to which the rules currently apply. Michigan has made no determination as to the applicability of their regulations to any ship and barge operations in their state. Note that responses were not received from San Diego or Santa Barbara air quality agencies in California. 2. Six authorities, Alaska, Bay Area, South Coast, Ohio, Michigan, and Puget Sound, have required or have rules that require controls under new source permitting: vapor return, incineration, submerged fill, and limit on throughput. Thirty said they have not required and have no rules to require hydrocarbon emission controls for ships and barges as part of a new source review program. 3. Compliance has not been determined by Alaska, Michigan, and Bay Area while Ohio and Puget Sound report compliance with vapor incinera- tion and throughput limits, respectively. 4. Alaska, Michigan, Bay Area, Ohio, and Puget Sound indicate no enforcement actions have been taken. 5. Fourteen of the responding agencies said they had considered con- trolling hydrocarbon emissions from ships and barges while 21 said they had not. Some of the reasons given for dropping consideration are inter- ference with interstate commerce, absence of regulations elsewhere, not cost-effective, insufficient data, safety concerns, unfair competition 152

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153 NATIONAL RESEARCH COUNCIL COMMISSION ON' ENGINEE~.NG AND TECHNICAL SYSTEMS 2103 Constitution Avenue Washington. D C 20418 MARINE JOAAD NAME OF RESPONDENT 1~ OF RESPONDENT NAME OF ORf~NIZAlION TE~ONE Now ALL Responders TELEPHONE (XT2) 33~3119 TELEX ~t0~22~9 O - CE LOCATOR O5EPH HE`IRY eUTLDl~G 215T 5lREFr ,~ PB~VAM~ AVE.~.E. ~' w SURVEY OF SIAIE AND LOLL R=1IR~ AFF~C1ING HYD~ON EMISSIONS FOCI SHIP AND HE LIQUID TRANSOM OPERATIONS 1. Mat specific stipulations does your jurisdiction have that apply to hydrocarbon emissions freon ship and barge liquid transfer ~ orations? Describe the laws, rules, regulations, ord m ances, permits, licenses, or fees including a description of control measures required. Please provide a copy of related documents. 2. Has your jurisdiction required control of hytbxx~dbon emissions from ships and barges as part of a new source review program? If so, please describe the requirements. Please Respond If You Have Answered Affirmatively Above 3. How have the stipulations been complied with? Describe emission control procedures/vapor recovery installations. Provide cost information and comment on cperat~ng history if known. The Nahor~at Research Council ~5 the pnnc~pal OpErdhng agency of the Nationd! Academy of Sciences and the National Academy of Eng'~en~g to see', government and other orgar~'zahons FIGURE B-1 Survey of state and local requirements affecting hydrocarbon emissions from ship and barge liquid transfer operations.

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154 FIGURE B- 1 continued . 4. Have you had to enforce any of the above stipulations (contrasted with voluntary compliance)? Please list the nature of the actions, whether the actions were against vessels or termin21s, and the nature of the chum. ALL Others 5. Has your jurisdiction considered controlling hydrocarbon emissions from ships and barges? Describe the proposals and their status. ALL Respondents 6. Other comments. Respond by October 31 to: Charles A. Eookman Committee on Control and Recovery of Hydrc carbon Vapors from Ships and Barges Marine Board, Room JH 702 National Research Council 2101 Constitution Avenue Washington, DC 20418

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158 from unregulated terminals, need for a national standard, need for Coast Guard approval, and federal/state concerns. The Pennsylvania state program provided a copy of a draft regulation and support documentation. The regulation calls for displaced gasoline vapors from barge loading to be directed to a system where at least 80 percent, by weight of the organic compounds in the vapor, are recovered or destroyed. 6. Nine agencies provided comments on various aspects of ship and barge hydrocarbon controls ranging from support for federal control to willingness to comply with Environmental Protection Agency (EPA) require- ments to continuing with requirements at the state level. A vast majority of state and local agencies responding to the survey have no regulations that apply to ship and barge loading operations. Most agencies have not considered such controls and those that have appear to be waiting for action at the federal level. SUMMARY OF AFFIRMATIVE RESPONSES TO QUESTIONS 1 AND 2 1. What specific stipulations does your jurisdiction have that apply to hydrocarbon emissions from ship and barge liquid transfer operations? Describe the laws, rules, regulations, ordinances, permits, licenses, or fees including a description of control measures required. Please provide a copy of related documents. 2. Has your jurisdiction required control of hydrocarbon emissions from ships and barges as part of a new source review program? If so, please describe the requirements. Alaska A Prevention of Significant Deterioration (PSD) permit was issued to Alyeska (pipeline service facilities) requiring vapor control from tank- er loading us ing vapor return to loading station. Vapor recovery was installed but has not been inspected or enforced by the state or EPA. Copies of regulations were not provided. South Coast Air Quality Management District Control of hydrocarbon emissions from ships or barges has been required as part of its New Source Review (NSR) program. The district's NSR rule (regulation XIII) requires that all new sources be equipped with Best Available Control Technology (BACT). This would require hydrocarbon controls on new liquid transfer operations from ships and barges.

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159 Bay Area Air Quality Management District Marine operations are covered under new source review requirements in district regulation 2, rule 2-2-208 under the definition of a station- ary source. The definition reads in part: In addition, in cases where all or part of a station- ary source is a facility used to load cargo onto or unload cargo from cargo carriers, other than motor vehi- cles, the tAir Pollution Control Officer] shall consider such carriers to be parts of the stationary source Accordingly, all emissions from such carriers (excluding motor vehicles) while operating within the District and within the California Coastal waters adjacent to the Air Basin shall include those that result from the purging or other method of venting vapors; and from the loading, unloading, storage, processing, and transfer of cargo. However, emissions from the operation of the carriers' engines shall be considered only while such carriers are operating within the District. In 1987, the district granted a request by an oil refiner to control loading emissions voluntarily (banking the emissions thus abated for use in offsetting emissions from future expansions). In the same year, a major integrated oil company applied for permits to employ vapor control in a refinery and a crude oil lightening operation, also with the aim of banking the emissions-abatement credit. Florida State rules governing hydrocarbon emissions from these sources are described in rule 17-2.620, General Pollutant Emission Limiting Standards, as follows: (1) Volatile organic compounds emissions or organic solvents emissions. (a) No person shall store, pump, handle, process, load, unload, or use in any process or installation volatile organic compounds or organic solvents with- out applying known and existing vapor emission con- trol devices or systems deemed necessary and ordered by the Department. (2) Objectionable Odor Prohibited--No person shall cause, suffer, allow, or permit the discharge of air pollutants which cause or contribute to an objectionable odor. Rule 17-2.650~1~(f) 9 and 10 apply to bulk gasoline plants and bulk gasoline terminals.

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160 The state has not required control on ships and barges as part of its new source review program because "this situation has not come up as of this date." Puget Sound Air Pollution Control Agency Although this agency has regulations that require vapor recovery at gasoline loading terminals, such controls have not been required for barge loading of gasoline. The agency says that it has limited the annu- al amount of gasoline loaded into barges from a modified oil refinery. State of Michigan Department of Natural Resources This agency has regulations governing gasoline transfer to both existing and new delivery vessels. Rule 608 requires that, for loading of gasoline into existing delivery vessels at loading facilities han- dling less than 5 million gallons per year, the delivery vessel must be controlled with a vapor balance system (90 percent efficiency) if the loading facility is located in a designated area, or equipped with a submerged fill pipe if it is located in any other area of the state. Rule 609 requires that, for loading of any organic compound with a true vapor pressure of more than 1.5 psia into any existing delivery vessels at loading facilities handling 5 million or more gallons per year, the delivery vessel must be controlled with a vapor recovery system (emis- sions not to exceed 0.7 pounds per 1,000 gallons loaded) if the loading facility is located in an ozone nonattainment area, or equipped with a submerged fill pipe if it is located in any other area of the state. Loading of gasoline from a stationary vessel into any new delivery vessel in facilities having a throughput of less than 5 million gallons per year is regulated under rule 705. In designated areas, a vapor balance system is required that will return not less than 90 percent by weight of the displaced gasoline vapor from the delivery vessel to the stationary vessel. In other areas, submerged fill equipment is required. Rule 706 applies to loading of new delivery vessels with organic compounds having a true vapor pressure of more than 1.5 psia at loading facilities handling 5 million or more gallons per year. Emis- sions in this instance shall not exceed 0.7 pounds of organic vapor per 1,000 gallons of organic compounds loaded if the facility is located in an ozone nonattainment area. In other areas, submerged fill equipment is required. This latter rule would apply to gasoline transfers. Wayne County, Detroit, Michigan This agency enforces Michigan Air Pollution Control Commission General Rules. The agency has not required controls under these rules.

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161 RESPONSES TO QUESTION 5 5. Has your jurisdiction considered controlling hydrocarbon amis- sions from ships and barges? Describe the proposals and their status. California In June 1984, the California Air Resources Board presented to the California Legislature the Report to the California Legislature on Air Pollutant Emissions from Marine Vessels. I have attached a copy of that report for your information. Bay Area Air Quality Management District, California Yes. Require control of gasoline and crude oil and petroleum pro- ducts with a vapor pressure of greater than 1.5 psia true to a level abated by vapor recovery. South Coast Air Quality Management District, California Our rules development group considered controlling hydrocarbon emis- sions by (1) vapor balance systems, (2) carbon absorption, and (3) incin- eration as part of an overall revision of rule 462, which addresses land-based bulk liquid transfers. They determined that requiring such controls on ships or barges would not be cost-effective, considering the amount of emissions and the cost of installing the above controls. No such provision was added to rule 462. Connecticut Yes, at one time. We dropped it from consideration because of inter- ference with interstate commerce. Illinois At the first hearing in this matter on October 24, 1986 [of a gener- ic rule for hydrocarbon emission control], the Illinois Environmental Protection Agency presented a proposal which excluded barge loading from applicability. This was done in light of the absence of such regula- tions elsewhere and current policy, and the understanding that poten- tially affected parties would present factual testimony demonstrating that further control measures should not be mandated in Illinois.

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162 Jefferson County, Louisville, Kentucky Yes, many years ago. We had insufficient data upon which to regu- late and did not. No current additional action is pending. L~ . Oulslana Yes. We have considered this, but these controls were thought to be too expensive and potentially dangerous unless required nationwide. Maryland Yes. A regulation was proposed that would have required collection of all vapors displaced in barge or ship loading operations, and recov- ery or destruction of those vapors. These proposals were dropped due to industry concerns regarding competition from uncontrolled terminals and safety. I. . : ~ solpc Wayne County, Detroit, Michigan and/or barges handling volatile organic compounds were involved in transfer operations in Wayne County, the emissions from such operations would be regulated [by this agency under Michigan Air Pollution Control Commission General Rules]. Ohio We are currently evaluating the feasibility of requiring hydrocarbon emission controls for a barge loading facility near Cleves, Ohio. Although the facility is currently shut down, it may be subject to Reasonably Available Control Technology requirements as a Noncontrol Techniques Guideline source should it be restarted in the near future. Pennsylvania The bureau drafted regulations and circulated them to affected par- ties. The bureau received many comments that indicated a need to resolve federal/state concerns. The bureau has suspended work on this regulation until this issue is resolved. Enclosed is a copy of the draft regulation and support documentation for your records. Philadelphia, Pennsylvania Not formally or specifically. The control of hydrocarbon emissions from ships and barges may be considered if the federal EPA recommends it and publishes control technology guidances.

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163 Texas In late 1972 and early 1973, the Texas Air Control Board proposed rules to control volatile organic compound emissions from various sources in the Gulf Coast area. These proposed rules included require- ments for the control of emissions from ship and barge loading as well as the loading of trucks and railroad tank cars. Following the public participation process, the board deleted the proposed requirement for control of loading of marine vessels based on the view that the regula- tior~ of such vessels should be centralized in the U.S. Coast Guard. A study of vessel emissions control has recently been completed by the legislatively mandated Clean Air Study Committee. The committee has recommended that the Texas legislature adopt a resolution to Congress supporting national control should the results of the current National Research Council study indicated that such control is feasible and advisable. Houston, Texas Yes, prefer national standard. Puget Sound, Washington Yes. Barge loading of gasoline is a major source of volatile organ- ic compound emissions in our jurisdiction and we considered adopting vapor recovery requirements. However, we found that the Coast Guard has not approved vapor recovery systems for barges. Since the institutional obstacles were too great, we dropped the idea. RESPONSES TO QUESTION 6: OTHER COMMENTS Alabama When a new source of volatile organic compound (VOC) emissions from barge or ship loading operations applies for an air permit, the state is required by federal regulations to determine the Best Available Control Technology or Lowest Achievable Emission Rate for that source. Control of VOC emissions at a barge dock is not impossible, just not practical. It would be easier to have a vessel built for vapor control and approved by the Coast Guard rather than retrofit existing vessels that may use the dock. It is not the state's interest to conflict with federal mari- time safety, but to comply with the U.S. Environmental Protection Agency's requirements of new source review and, in cases like this, we would have to address maritime dock vapor control. Anchorage, Alaska The only problems have been with visible emissions.

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164 Bay Area Air Quality Management District, California Please keep us informed. TOSCO Oil Company at Martinez, California is proposing vapor recovery on gasoline loading onto ships and barges in order to provide emissions reduction credit. [Now in operation; see Summary of Affirmative Responses to Questions 1 and 2.] Connecticut Hydrocarbon emissions from barge loading is substantial and should be controlled at the federal level. Emissions from such operations in New Jersey are approximately equal to 10 percent of our entire hydrocar- bon emissions from all sources in our state. Technology for controlling these emissions is either available or able to be developed. We will gladly support any efforts you make in establishing a program for the control of these emissions. Kentucky If the EPA issues guidance to control ship or large liquid transfer operations, then Kentucky will follow EPA guidance. Le OUTS lalla Programs such as offsets in urban nonattainment areas, prevention of significant deterioration, and national emission standards for hazardous air pollutants may require reductions beyond the current regulations. A company in Louisiana had to control its liquid transfer for ships and barges for acrylonitrile (a hazardous air pollutant). We have some per- mits where ship and barge liquid transfer controls were proposed as reductions for offsets (not sure any were actually built). Maryland A national regulation of barge and ship loading vapor emissions is the only viable option because the barges and ships must have stan- dardized fittings to mate with all terminals. Furthermore, national coverage eliminates the potential competition from uncontrolled facili- ties with lower handling costs. Texas The loading of toxic, odorous, or flammable liquids is often con- trolled by a permit applicant due to safety or other requirements. The staff would seek to ensure that a permit transaction would not result in vessel emissions that would lead to adverse health effects or nuisance

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165 Conditions prohibited by the Texas Clean Air Act as a condition of air pollution. Puget Sound, Washington If barge-loading vapor recovery was found to be technically feasible and safe, we would seriously consider requiring it.