organic liquids distribution (non-gasoline) mact summary

7. What are the testing and initial compliance requirements under this rule?

In order to determine the applicability of this rule to individual operations, a facility must evaluate each OLD operation as to whether any of the distributed liquids contain less than 5 percent HAP by weight.  Liquids containing less than 5 percent HAP by weight do not meet the definition of an organic liquid under the final rule. The facility may use EPA Method 311 (40 CFR Part 63, Appendix A) or other methods approved by the Administrator for this determination.  Other means, such as the use of material safety data sheets or certified product data sheets, may also be used for determining the HAP.  However, if the results of an analysis by EPA Method 311 (or other approved test method) are different from the HAP content determined by these other means, the EPA Method 311 (or other approved test method) results will govern compliance determinations.

If a facility uses control devices to comply with this rule, the devices will be subject to a performance test to demonstrate initial compliance with the emission limits, except that a design evaluation, conducted according to 40 CFR Part 63 Subpart SS, may be used for non flare control devices. The test methods applicable to control devices include EPA Methods 18, 25, and 25A of 40 CFR Part 60, Appendix A, and EPA Method 316 of 40 CFR Part 63, Appendix A, depending on the constituents of the gas stream being controlled and the format of the standard (organic HAP or TOC) the facility selects for its compliance demonstration. Floating roof tanks are subject to visual and seal gap inspections to determine initial compliance with the tank work practice standards. For the LDAR program for equipment components, EPA Method 21 of 40 CFR Part 60, Appendix A, is applicable.

Initial compliance with the emission limits for storage tanks and transfer racks consists of demonstrating that the control device achieves the required 95 or 98 percent control efficiency for organic HAP (or TOC, if used as a documented surrogate) or 20 ppmv exhaust concentration for combustion devices. The required percentage control efficiency must be applied to the Table 1 (Subpart EEEE of Part 63) HAP concentration found at the inlet to the control device.

Work practice standards apply to storage tanks, transfer racks, transport vehicles, and equipment components. The facility must perform a visual inspection before filling internal floating roof tanks. They must also conduct a measurement of seal gaps for external floating roof tanks within 90 days after filling. For transfer racks, the facility must ensure that vapor balancing systems or equipment for routing emissions to a fuel gas system or back to a process are properly designed and operated.

For transport vehicles, a facility must perform vapor tightness testing for vehicles that they own and maintain documentation for all affected vehicles certifying that they are vapor-tight. Finally, for the equipment LDAR program, the facility must identify which 40 CFR Part 63 Subpart they are complying with and keep a record identifying the selected subpart.