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PAGE 1 DATE December 6, 2012 CHECKED BY:

PROCESSED BY: Connie Yee Johnny Pan

PERMIT TO OPERATE- NO PERMIT TO CONSTRUCT

COMPANY NAME, LOCATION ADDRESS
Ultramar Inc.Facility ID. 800026 2402 E. Anaheim Street Wilmington CA 90744-4081

EQUIPMENT DESCRIPTION
Section D of the Ultramars Facility Permit: Additions to equipment description and conditions are underlined.
Equipment ID No. Connected To
RECLAIM Source Type/ Monitoring Unit

Emissions and Requirements

Conditions

Process 13: OIL/WATER SEPARATION

System 3: VACUUM TRUCK CLEANOUT

SUMP, 83-ME-4, VACUUM TRUCK CLEANOUT/UNLOADING, FIXED COVER, 1,362 GALS; WIDTH: 11 FT; DEPTH: 9 FT 11 IN; LENGTH: 17 FT
A/N: 423686 DX

S13.7

BENZENE: (10) 40CFR 61 Subpart FF #1,12-4-2003]; HAP: (10) 40CFR 61 Subpart CC #2,6-232003]; [VOC]: 500 PPMV (8) 40CFR 61 Subpart FF,12-42003]

SYSTEM CONDITIONS: S13.7 All devices under this system are subject to the applicable requirements of the following rules or regulations: Contaminant VOC VOC VOC Rule District Rule 40CFR60, Subpart 40CFR60, Subpart Rule/Subpart 1176 QQQ FF

[RULE 1176, 9-13-1996; 40CFR60, Subpart QQQ, 10-17-2000; 40CFR60, Subpart FF, 12-42003] [Systems subject to this condition: Process 13, System 1]

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COMPLIANCE RECORD REVIEW A check of the AQMD Compliance Database shows that the facility has received three Notices to Comply and 22 Notices of Violation since January 1, 2010. None of the NCs or NOVs apply to the sump. BACKGROUND Ultramar, Inc. (Valero Wilmington) is a refinery in the city of Wilmington. The facility is a NOx and SOx RECLAIM facility.
Table 1 lists the applications submitted to permit an existing sump: Table 1 AQMD Applications Submitted A/N
Date Submitted December 12, 2003 January 22, 2009

Equipment

Device ID Dx n/a

Requested Action

Previous A/N Permit # Status n/a n/a

423686 495049

Sump, Vacuum truck cleanout/unloading Title V Facility Permit Amendment

Permit existing sump 83-ME-4 RECLAIM (Title V) Facility Permit Amendment

FEE EVALUTION:
The fees paid for the applications are as follows: Table 2 Application Fees A/N
423686

Equipment
Sump, Vacuum truck cleanout/unloading, 83-ME-4 50% Penalty

BCAT 000582 n/a 555009

Type 30 n/a 85

Status 21 n/a 21

Fee Schedule

Fees Required, $ $1,411.74 $705.87 $1,187.63 $3,305.24

Fees Paid, $ $1,411.74 $705.87 $843.80 $2,961.41

B n/a n/a

495049

RECALIM (Title V) Facility Permit Amendment* Total

A/N 495049 was submitted in early 2009 before Ultramar was issued a Title V facility. Therefore, Ultramar submitted only a RECLAIM Facility Permit Revision application. HISTORY The sump is an existing piece of equipment that has never been permitted. Therefore, there is no permit history. This sump has been in use at the refinery for over 10 years. Ultramar submitted this application for permit after the refinery was issued a Notice to Comply (NTC) C66987 on December 1, 2003 for

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operating equipment without a permit. Therefore, this application was submitted in response to the NTC. The contents from this sump are piped to existing crude oil draw-off sump 83-SMP-3, currently permitted in the wastewater treatment system (A/N 458073, Process 13, System 1). PROCESS DESCRIPTION: Ultramar Refinery operates a vacuum truck cleanout/unloading sump, 83-ME-4. Ultramar utilizes several vacuum trucks for various types of operation. These types of operation include transfer of various products and by-products from one location to another within the refinery or another location, collection of tank bottom solids and water, and other vacuum truck operations. Vacuum trucks containing residue products/sludge need to be washed before using them to transport other products. To cleanout the trucks, the vacuum trucks are filled with wash water. This wash out water and any material unloaded from the vacuum trucks is then sent to vacuum truck cleanout/unloading sump, 83-ME-4. The sump contents from sump 83-ME-4 are eventually piped to the crude tank draw off sump, 83-SMP-3 (D399), which is permitted within the refinerys wastewater system (A/N 458073, Process 13, System 1). As the wash water from vacuum truck enters sump 83-ME-4, the wash water is simultaneously filled into the wastewater system by gravity. The sump is covered with a fixed roof so only a minimal amount of emissions should be emitted. It contains two compartments. The sump is not vented to the atmosphere. The first compartment consists of the hatch where the contents of the vacuum truck is unloaded. The second compartment is equipped with a gooseneck pipe with a water seal that acts a pressure relief valve in case the pressure builds up in the sump. The pipe is located on south east corner of sump. The gooseneck pipe is 3 inches in diameter and has a height of approximately 7 feet 4 inches from the top of the sump to the top of the pipe. The height from the bottom of the water seal to opening of the pipe where the water fills the water seal is about 12 inches. This water height should be enough to keep any vapors from escaping. Water is generally added twice per week during the operators rounds. The contents in the second compartment drains by gravity into the refinerys wastewater system. See the diagram below of the sump.

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Sump 83-ME-4 is a covered, sealed, and equipped with a hatch. The hatch is only opened when a vacuum truck drives up and unloads its contents into the sump. Sump 83-ME-4 measures 17 feet long, 11 feet wide, and 9 feet 10 inches deep. It is made of concrete, situated mostly below grade, and covered by a steel plate. According to the refinery, the annual throughput is approximately 5.2 million gallons per year.

EMISSIONS: As noted above in the project description, Ultramar operates an existing effluent sump, 95-SMP-5 equipped with a water seal, fixed roof cover, and hatch to collect the wash water (wastewater) from the vacuum trucks. The emission increase is 0.119 lbs/day.

Sump Type of Cover Width Depth Length Surface Area

95-SMP-5 Fixed 11 feet 11.83 feet 17 feet 187 feet2

Emission Factor for Sump (Source: District's AER Form R5): 1.8 lb/year per square foot of surface area

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As the water enters the sump, the contents of the sump is simultaneously sent to the another sump within the waste water system. Sump 83-ME-4 is covered by a fixed roof so a minimal amount of emissions should be emitted into the atmosphere. The fixed roof cover is assumed to have a 90% control efficiency. VOC Emission from 95-SMP-2 = 1.8 lb/year/ft2*187 ft2*yr/12 mos*1mo/30 days *(1-90%) = 0.09 lbs/day

In addition, the sump contains one hatch which normally remains closed. The hatch is only removed so the hose can be connected from the vacuum truck to the vacuum trucks to collect the wash water. VOC emissions for the hatch are estimated by multiplying the total number of each fugitive component type by an appropriate emission factor. Emissions from fugitive components are calculated using the CAPCOA-revised 1995 EPA Correlation Equations (Table IV-3a from AQMD Guidelines for Fugitive Emissions Calculations, June 2003). As seen in the detailed fugitive VOC emission calculations, which are contained in Appendix A, the fugitive VOC emissions is 0.025 lb/day (9.09 lbs/year). Total VOC Emission Increase = (0.09 + 0.025) lbs/day = 0.119 lbs/day The total VOC emissions estimated to be 0.119 lb/day. RULE EVLAUATION:
PART 1 SCAQMD REGULATIONS

Rule 212

Standards for Approving Permits

November 14, 1997

This sump is not considered a significant project. In accordance with Rule 219(c), a significant project is a new or modified facility in which: (1) the new or modified permit unit is located within 1000 feet of a school; (2) the new or modified facility has on-site emission increases exceeding the daily maximum specified in subdivision (g); or (3) the new or modified permit unit has an increased cancer risk greater than, or equal to, one in a million (1 x 10-6) during a lifetime of 70 years or pose a risk of nuisance. A public notice is not required since the permit unit is not located within 1000 feet of a school, the emissions from this project will not exceed the daily maximums specified in subdivision (g), and the permit unit will not result in a cancer risk greater than, or equal to, one in a million (1 x 10-6).

Rule 401

Visible Emissions Visible emissions are not expected under normal operating conditions.

November 9, 2001

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Rule 402

Nuisance Nuisance complaints associated are not expected under normal operating conditions.

May 7, 1976

Rule 464

Wastewater Separators

December 7, 1990

This rule regulates wastewater separators and does not apply to the sump. The sump is not a wastewater separator since it is not used to separate petroleum -derived compounds from wastewater.

Rule 1123

Refinery Process Turnarounds

December 7, 1990

Ultramar operates under procedures to ensure compliance with Rule 1123 vessel depressuring and recordkeeping requirement during process unit turnarounds. Compliance is expected.

Rule 1173

Fugitive Emissions of Volatile Organic Compounds

February 6, 2009

The sump does not have a valve, fitting, pump, compressor, pressure relief device, diaphragm, sight-glass, and meter in VOC service. It does have one hatch to collect the washwater from the vacuum trucks. Although hatches are defined as fugitive components in Rule 1173(c)(4), the sump (and hatch) handle fluids with a VOC content of 10% by weight or less. In accordance with Rule 1176(l)(1)(D)-Exemptions, the rule does not apply to components handling fluids with a VOC content greater than 10% by weight. Therefore, the hatch is exempt from Rule 1173. There are no other fugitive components associated with the sump.

Rule 1176

Sumps and Wastewater Separators

September 13, 1996

This rule applies to wastewater systems and associated control equipment located at petroleum refineries such as Ultramar. (e)(1) (e)(2) (A) The sump will be provided with one of the following: n/a(i) A floating cover equipped with seals. (ii) A fixed cover, equipped with a closed vent system vented to an APC device as specified in paragraph (e)(6). The contents from the sump is Wastewater System Emissions. This wastewater treatment system is expected to continue to meet the 500 ppm limit in Rule 1176. Sumps and Wastewater Separators.

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Rule 1176

Sumps and Wastewater SeparatorsSeptember 13, 1996 routed to a the refinerys wastewater system, which is a closed vent system, and controlled by a water seal to prevent emissions into the atmosphere. n/a (iii) Any other alternate control measure which is demonstrated by the facility operator to be equivalent to, or more effective in reducing VOC emissions than the requirements of clauses (e)(2)(A)(i) or (e)(2)(A)(ii), and approved in writing by the Executive Officer.

(B) A fixed sump covers shall meet all of the following requirements: (i) The cover material shall be impermeable to VOCs, and free from holes, tears, or openings. n/a n/a (ii) Drains on covers shall be provided with a slotted membrane fabric cover, or equivalent, over at least 90 percent of the open area. (iii) Gauging or sampling openings on the separator shall be covered. (iv) Hatches on covers shall be kept closed and free of gaps, except when opened for active inspection, maintenance, sampling, or repair. (v) The perimeter of a cover, except for a floating cover, shall form a seal free of gaps with the foundation to which it is attached. (vi) A floating cover shall be designed and maintained so that the gap between the separator or sump wall and the seal does not exceed 1/8 inch for a cumulative length of 97 percent of the perimeter of the separator. No gap between the wall and the seal shall exceed 1/2 inch.

n/a

(e)(3) (e)(4) (e)(5) (e)(6)

Sewer Lines. No new sewer lines are installed in this sump. The contents of this sump (83-ME-4) are piped to the sump (83-SMP-3, D999) in the refinerys wastewater system. Process Drains. No new process drains are installed in this sump. Junction Boxes. No new junction boxes are installed in this sump. APC Devices shall meet one of the following requirements: (A)An APC device receiving vapors from a closed vent system with a control efficiency of 95% by weight or greater; (B)The outlet of the APC shall not emit VOC emissions greater than 500 ppm; or (C) An APC device or other alternate system that collects vapors through a closed vent system and subsequently controls the vapors in a device and determined to have either a control efficiency of 95% by weight or greater or VOC emissions less than 500 ppm.

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Rule 1176

Sumps and Wastewater Separators

September 13, 1996

The emissions are controlled by the fixed roof cover, a water seal with about 12 inches of water, and the refinerys wastewater system. The water collected in the sump 83 -ME-4 is gravity fed underground to an existing sump (SMP-3) in the refinery wastewater system (Permitted under A/N 458073). The sump is monitored at least monthly for VOC emissions. Ultramar provided the monthly monitoring data of the sump from October 2011 to September 2012. During this 12 month period, the emissions were only above 500 ppm on March 12, 2012 when a leak was detected in the hatch. Additional Requirements for drain system components (DSCs) at Petroleum Refineries. For the DSCs in the wastewater system, Ultramar complies with the control requirements of this paragraph according to subparagraphs (e)(7)(A): Control of Repeat Emitting DSCs. The refinery is required to inspect, monitor, and maintain the wastewater system, closed vent system, and all DSCs according to the schedule outlined in the Table 2 of the rule. Ultramar submits quarterly reports to the District with the information required in (g)(2)(B). Inspection, Monitoring and Maintenance Requirements. The sump is monitored at least monthly for VOC emissions. Ultramar provided the monthly monitoring data of the sump from October 2011 to September 2012. During this 12 month period, the emissions were only above 500 ppm on March 12, 2012 when there was a leak in the hatch. Ultramar repaired the hatch that day and re-monitored the emissions which were found to be well below 500 ppm (24 ppm).

(e)(7)

(f)

REG XIII

New Source Review

May 10, 1996 (Application deem complete date: 2012)

The sump will not result in a significant emission increase. The sump results in an emission increase of 0.119 lbs VOC/day. Therefore, the requirements of Regulation XIII should not apply to this sump. 1303(a) Best Available Control Technology (BACT): BACT is not required since the sump emissions are less than 1 lb/day. 1303(b) The net emission increase from the sump is only 0.119 lb/day of VOC. Since the emission increase is less than 0.5 lbs/day, the requirements of this paragraph (modeling, offsets, sensitive zone requirements, facility compliance, major polluting facilities) do not apply.

Rule 1401

New Source Review of Toxic Air Contaminants

September 10, 2010 (Application deem complete date: 2012)

In accordance with Rule 1401(f)(1), the maximum individual cancer risk (MICR) and cancer burden from the new permit unit shall be calculated on an annual basis from:

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Rule 1401

New Source Review of Toxic Air Contaminants

September 10, 2010 (Application deem complete date: 2012)

(a)(1)(A), the maximum rated capacity; (a)(1)(B), the maximum possible annual hours of operation; (a)(1)(C), the maximum annual emissions; and (a)(1)(D), the physical characteristics of the materials processed In accordance with Rule 1401(a)(2), the chronic HI from a new permit unit shall be calculated on an annual average basis from: (a)(2)(A), the maximum rated capacity; (a)(2)(B), the annual average hours of operation; (a)(2)(C), the annual average emissions; and (a)(2)(D), the physical characteristics of the materials processed In accordance with Rule 1401(a)(4), the acute HI from a new permit unit shall be calculated on a maximum hourly basis from: (a)(4)(A), the maximum rated capacity; (a)(4)(B), the maximum hourly emissions; and (a)(4)(C), the physical characteristics of the materials processed The MICR and HIA and HIC for both off-site worker and residential receptors are shown below in Table 3. The Tier 2 Screening Risk Assessments are shown in Appendix B. All the calculated MICR and HIs for the each target organ were below the Rule 1401 risk thresholds. Therefore, the proposed modification complies with Rule 1401. Table 3 - Rule 1401 Emissions and Summary Air Toxic Emissions Toxic Air Contaminant Emissions, lbs/year

Benzene Toluene Xylene (-o, -m, -p isomers) Ethyl benzene Hexane (n-) Hydrogen sulfide Methyl tertiary-butyl ether Phenol Propylene Naphthalene
Risk Summary Equipment Scenario MICR

4.30 x 10-05 1.40 x 10-04 2.53 x 10-04 4.75 x 10-05 8.89 x 10-05 1.43 x 10-03 2.64 x 10-05 8.52 x 10-05 3.43 x 10-06 5.54 x 10-05

HIAcute, HIA

HIChronic, HIC

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Rule 1401

New Source Review of Toxic Air Contaminants

September 10, 2010 (Application deem complete date: 2012)

Sump 83-ME-3 Worker Residential Maximum Risk Rule 1401 Risk Thresholds

5.32x10-13 3.50x10-7 2.72x10-12 3.50x10-7 2.72x10-12 3.50x10-7 1 x10-6 1 Pass Pass

1.24x10-7 1.24x10-7 1.24x10-7 1 Pass

Federal NSR for toxics does not apply since this is not considered a reconstruction per 40CFR63, Subpart A, 63.2.

Regulation XX Rule 2005

RECLAIM

May 6, 2005

There is no emission increase of any NOx or SOx air contaminant from this sump.

Regulation XXX

Title V

March 16, 2001

Ultramar is a designated as a Title V facility. Ultramars Title V permit became effective on May 29, 2009. Therefore, the facility is now subject to the requirements of Regulation XXX. This application is considered a DeMinimis Significant Permit Revision as defined in Rule 3000 and subject to 45 day review by EPA. An application is a De Minimis Significant Permit Revision [Rule 3000(b)(7)] if the Title V permit revision where the cumulative emission increases of non-RECLAIM pollutants or hazardous air pollutants (HAP) from the permit revisions during the term of the permit are not greater than any of the emission threshold levels listed below:

De Minimis Emission Threshold Level DE MINIMIS Daily Maximum Air Contaminant Pounds Per Day
HAP VOC NOx PM-10 SOx CO 30 30 40 30 60 220

The cumulative emission increase since March 2012 is as follows:

Air Contaminant

Prior revisions, lbs/day

This revision, lbs/day

Total, lbs/day

Threshold level, lbs/day

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Regulation XXX

Title V

March 16, 2001

VOC CO

3.918 48

0.119 0

4.037 48

30 220

A De Minimis Significant Permit Revision shall also meet the requirements of clauses (b)(15)(A)(i), (ii), (iii), (iv), (vii), (viii) and (ix) of Rule 3000.
3000 (b)(15)(A)(i)

This revision does not require or change a case-by-case evaluation of: reasonably available control technology (RACT) pursuant to Title I of the federal Clean Air Act; or maximum achievable control technology (MACT) pursuant to 40 CFR Part 63, Subpart B. This revision does not violate a regulatory requirement. This revision does not require any significant change in monitoring terms or conditions in the permit. This revision does not require relaxation of any recordkeeping, or reporting requirement, or term, or condition in the permit. This revision does not result in an increase of GHG emissions of > 75,000 tpy CO 2e. This revision does not establish or change a permit condition that the facility has assumed to avoid an applicable requirement. This revision is not an installation of a new permit unit subject to a New Source Performance Standard (NSPS) pursuant to 40 CFR Part 60, or a National Emission Standard for Hazardous Air Pollutants (NESHAP) pursuant to 40 CFR Part 61 or 40 CFR Part 63.

(b)(15)(A)(ii) (b)(15)(A)(iii)

(b)(15)(A)(iv)

(b)(15)(A)(vii) (b)(15)(A)(viii)

(b)(15)(A)(ix)

A De Minimis Significant Permit Revision is subject to a 45-day EPA review, Rule 3003(j), and not subject to public participation requirements, Rule 3006(b).

PART 2

STATE REGULATIONS

California Environmental Quality Act (CEQA) The operation of the sump is not a significant project.

PART 3

FEDERAL REGULATIONS

Regulation IX: Standards of Performance for New Stationary Sources (NSPS)

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40 CFR Part 60 Subpart GGG

Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries

60.590

This sump should not trigger NSPS Subpart GGG applicability. The sump does not construct or modify a process unit or compressor, which are the affected facilities regulated under Subpart GGG. The sump does not qualify as a process unit because it does not produce intermediate or final products from petroleum, unfinished petroleum derivatives, or other intermediates. [40CFR 60.591]

40 CFR Part 60 Subpart QQQ

Standards of Performance for VOC Emissions from Petroleum Refinery Wastewater Systems Applicability and designation of affected facility. The provisions of this subpart apply to the wastewater system located at the refinery for which construction, modification, or reconstruction commences. Although the Ultramars wastewater system itself is subject to Subpart QQQ, the sump, however, should not trigger NSPS Subpart QQQ applicability. The sump is not a construction, reconstruction, or modification of an individual drain system (IDS), oil-water separator, or aggregate facility, which are the affected facilities regulated under Subpart QQQ. The sump, 83-ME-4, is not an oilwater separator because it is not used to separate oil from water. [40CFR 60.691]

60.690

60.698

Reporting requirements. Since the wastewater system consists of oil/water separators, individual drain systems, induced gas floatation units, and other additional support equipment, Ultramar is required to inspect when a water seal is dry or otherwise breached, when a drain cap or plug is missing or improperly installed, or when cracks, gaps, or other problems are identified that resulted in VOC emissions, including information about the repairs or corrective action taken as required under 60.698. In the refinerys semi-annual Periodic Monitoring & Exception Report to EPA for the reporting period January 1 through June 30, 2012, Ultramar reported the following: Monthly Inspections: There were 9 drains identified with of dry or breached water seals. Corrective Actions: Added water to drains to restore water seals. Semiannual Inspections: There were no components (caps, plugs, covers, etc.) identified with improper seals.

40CFR Part 61 Subpart FF 61.340

National Emission Standard for Benzene Waste Operations

Since Ultramar is a petroleum refinery, the facility is subject to the requirements of Subpart FF. Ultramars total annual benzene quantity for the year 2010 was reported to EPA as follows: Year Total Annual Benzene

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40CFR Part 61 Subpart FF

National Emission Standard for Benzene Waste Operations

2010 61.342

Quantity (Mg/yr) 42.8

To comply with the general standards (61.342), Subpart FF contains several different options that a facility may use to manage and treat the facility waste if the total annual benzene quantity from the facility waste is greater than or equal to 10 Mg/yr. The options are: 61.342(c): waste management and treatment requirements for facilities at which the total annual benzene quantity from the facility waste is equal to or greater than 10 Mg/yr. 61.342(d): an alternative to requirements under 61.342(c) 61.342(e): an alternative to the requirements under 61.342(c) and (d) 61.342(f): off-site treatment option as an alternative to 61.242(c)(1)(i); this option is not available to facilities complying under 61.342(e).

Ultramar elected to comply with the alternative compliance option 61.342(e), which is also known as the 6BQ compliance option. 61.342(e)(2) requires all wastes with a water content of 10% or greater (aqueous waste) to comply with the wastewater provisions in the subsequent paragraphs. In 61.342(e)(2)(i), the sum of all benzene quantity of aqueous waste must be equal to or less than 6.0 Mg/yr. Therefore, the 6BQ compliance option requires Ultramar to manage the benzene quantity for all aqueous waste to less than 6.0 Mg/yr. In checking the Subpart FF annual reports submitted to EPA, we found the benzene quantity for the aqueous waste to be as follows:

Year

Total Annual Benzene Quantity from Aqueous Waste (Mg/yr) 2.5

2010

Therefore, Ultramar complies with the general requirements of Subpart FF. The total annual benzene quantification and information required to document compliance with the alternative requirements of 61.342(e) are submitted to EPA annually in accordance with the reporting requirements of 61.357.

Regulation X: National Emission Standards for Hazardous Air Pollutants (NESHAPS) 40 CFR Part 63 Subpart CC 63.640 National Emission Standards for Hazardous Air Pollutant from Petroleum Refineries Applicability and designation of affected source. This subpart pertains to tanks, fugitive

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40 CFR Part 63 Subpart CC

National Emission Standards for Hazardous Air Pollutant from Petroleum Refineries equipment leaks, and wastewater systems as well as other emission points. This sump is subject to the inspection, maintenance, and recordkeeping requirements of 40.CFR63 Subpart CC. This sump and several existing tanks and sumps within the wastewater treatment system have been identified as Subpart CC, Group 2 emission points. The refinery complies with the Group 2 wastewater provisions by complying with 40 CFR 61 Subpart FF [61.342(c)(2)]

RECOMMENDATION: Issue Permit to Operate-No Permit to Construct to the following application with the conditions listed in the Conditions Section.

A/N 423686 495049

Equipment Vacuum Truck/Unloading Sump RECLAIM Facility Permit Amendment

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Appendices

A. Fugitive Emissions

B. Rule 1401 Tier 2 Screening Risk Assessment

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Appendix A: Fugitive Component Count Sump 83-ME-3 (A/N 423686)

Process Unit:
Correlation Equation (CE) Factor (500 ppm) Emissions before modification based on 500 ppm Correlation Equation Factor (lbs/year)

Source Unit

Service

No. of Components before Modification (1)

No. of Components after Modification (2)

Correlation Equation Factor 500 ppm Screening Value (lbs/year)

Emissions after modification based on 500 ppm Correlation Equation Factor (lbs/year)

Valves

Sealed Bellows
SCAQMD Approved I&M Program

All Gas / Vapor Light Liquid (4) Heavy Liquid (5) > 8 inches Light Liquid (4) Light Liquid (4)

0 0 0 0 0 0 0

0 0 0 0 0 0 0

0.00 4.55 4.55 4.55 4.55

0 0.00 0.00 0 0

0 0 0 0 0 0 0

Pumps

Sealless Type
Double Mechanical Seals or Equivalent Seals Single Mechanical Seals

46.83

Heavy Liquid (5) Gas / Vapor All All All All All

0 0 0 0 0 0

0 0 0 0 0 0

46.83 9.09 6.99 2.86 9.09 9.09 -

0 0 0 0 0 0

Compressors
Flanges (ANSI 16.5-1988)

Connectors Pressure Relief Valves Process Drains with PTrap or Seal Pot
Other (including fittings, hatches, sight-glasses, and meters)

9.09

9.09

Total Emissions

lb/year lbs/day

9.09 0.025 9.09

Emission Increase

lbs/year lbs/day

0.025

-1 -2 -3 -4

-5

Any component currently installed prior to the modification. Any component to be removed due to modification. (Reserved) Light liquid and gas/liquid streams: Liquid or gas/liquid stream with a vapor pressure greater than that of kerosene (>0.1 psia @ 100F or 689 Pa @ 38C), based on the most volatile class present at 20% by volume. - used single mechanical seal EF Heavy Liquid: streams with a vapor pressure equal to or less than that of kerosene (< 0.1 psia @ 100F or 689 Pa @ 38C), based on the most volatile class present at 20% by volume.