Bill, presented below is a summary of the Midland EOTT tank compliance 
status verified by fax and telephone with the teams.  This information is 98% 
complete until actual onsite verification occurs, which is set up for the 
month of August. I plan on visiting each team and tank in the Midland 
Region.  However, until the site visits are completed, this should give you a 
good idea of the status of the EOTT pipeline tanks stand with respect to air 
compliance.  

1. Tank compliance database, general.  The database, which included 366 tanks 
at the onset, has been reduced to 106 EOTT P/L tanks.  Tanks operated by EOTT 
Trucking; non-EOTT tanks;  tanks sold, removed, duplicated, or otherwise 
listed in error, were removed (and saved in another file).  Of the 106 tanks 
listed, 80 are active, 12 are inactive, 10 are permanently out-of-service, 
and 4 are abandoned in place.

 
2. Permit issues. 
Federal

a. Title V permit concerns do not appear to be a problem.  Electric pumps are 
the norm  at EOTT tank farms, so site emissions are exclusively from the 
tanks and do not exceed 100 TPY.  (Only Crane Station has a Title V permit).  
This statement is based on &worst case8 calculations using EPA TANKS 4.0 
which indicated that in a:

5,000 bbl fixed roof tank:  3.6 MM bbls of RVP 5 crude throughput  (i.e., 720 
turnovers) produced annual emissions of 48 tons (2 tpy breathing loss, 46 tpy 
working loss). 

55,000 bbl EFR tank:  14.0 MM bbls of RVP 5 crude throughput  (i.e., 255 
turnovers) produced annual emissions of 9 tons (6 tpy breathing loss, 3 tpy 
working loss). 

55,000 bbl fixed roof tank:  14.0 MM bbls of RVP 5 crude throughput  (i.e., 
255 turnovers) produced annual emissions of 4 tons (1 tpy breathing loss, 3 
tpy working loss). 


State 

b. State permit concerns do not appear to be a problem.  Sixty-three (63) of 
the 106 tanks were constructed before 1971 (and not modified or 
reconstructed). These tanks are grandfathered and require no permit as long 
as throughputs do not significantly change.  

All of the EOTT Texas tanks of any size constructed/modified/reconstructed 
after 1971 and equipped with a floating roof are exempt under Standard 
Exemption 86, currently known as Permit-by-Rule 106.478.   None of the tanks 
store material with a true vapor pressure above 11.0 psia, and total actual 
VOC emissions authorized under exemption from any site does not exceed the 30 
TAC 106.4 limit of 25 tpy.   No registration for the exemption is necessary, 
since the tanks are not located in a nonattainment county for ozone.

New Mexico,s permitting program for petroleum storage tanks is being 
developed but,  currently, there are no requirements. Therefore, all EOTT 
tanks in New Mexico meet state permit requirements.  However, when finalized, 
the control requirements for tanks in New Mexico will not be more stringent 
than the federal NSPS Subpart Kb.  Therefore, a tank equipped with a floating 
roof would be authorized to store petroleum product with a true vapor 
pressure up to 11.0 psia.   Only the four fixed roof tanks at Maljamar and 
the one at Loco Hills could be affected. 

4. Recordkeeping and inspection issues.  The grandfathered tanks have no 
requirements. For tanks subject to NSPS Subpart K, only capacity data is 
required.  Tanks subject to Ka and Kb require inspection, repairs if 
warranted, and recordkeeping.  

Note: Especially for some of the older tanks, neither a manufacturer,s 
identification plate or 
strapping table is available.  I would suggest that we pursue a records 
search of old EOTT files to verify construction dates.  I dont know where to 
start on this.

5. Specific compliance/requirements summary.  The tabled information 
identifies the following:

Federal
- 2 tanks (McElroy 58005, Loco Hills 4602) may not be meeting NSPS control 
requirements
- 4 tanks (Maljamar 1519-1522)  may not be meeting NSPS control requirements

(All are cone tanks,  subject to Ka/Kb.  Based on a capacity > 472 bbls and 
product true vapor pressure > 2.18 psia, the tanks require a floating roof or 
closed vent system);

- 28 tanks at 18 sites are subject to NSPS K/Ka/Kb inspection and/or 
recordkeeping requirements:
K (recordkeeping of tank capacity, dimensions only):
Foster 787, 790 
Quito-Hendrick 58044
Sands 15089A
Lynch 1511;

Ka/Kb (inspection & recordkeeping):
  Burger 58018 (if returned to active status)
China Grove 56007-56010
  Garden City 56003
Haskell, N. 58509 (if returned to active status)
Haskell, S.  58023 (and 58022, if returned to active status)
  McAfee 1523
  McElroy 58005
  Midland 1516
  Scurry 1517
  Wildfire 1524
  Livingston-Ridge 68414
  Loco Hills 4602, 68417, 68418
  Maljamar 1519-1522
  Sonora 1515 (if returned to active status)
Thomas 68413

State

- Crane Station has an emissions potential > 100 tpy and is therefore 
required to remit a TNRCC emissions fee, due by 11/1 each year: 
 

 10 sites are subject to an NSPS Subpart (i.e., K, Ka, Kb) and are therefore 
required to remit a  TNRCC emissions fee, due by 11/1 each year: 
China Grove, Foster, Garden City, Haskell S., McAfee, McElroy, Midland, 
Quito-Hendrick, Scurry, Wildfire;

- 8 sites need a TNRCC account number from the Regional office: China Grove,  
Haskell S., McAfee, McElroy, Midland, Quito-Hendrick, 
Scurry, Wildfire; 
I have initiated the request to the TNRCC for account number for the above 
sites
 
- 4 additional sites which, if returned to active status, need a TNRCC 
account number and are subject to a TNRCC emissions fee, due by 11/1:
Burger, Haskell N., Sands, Sonora;

- 3 sites that are not subject to a TNRCC emissions fee, but paid one last 
year:
Adair, Hendrick, Ozona.

6. Specific inspection requirements: Primary and secondary seal inspections. 
 See Attachment A for list of tanks affected. 
 API Standard 653-based  &In-service8 inspection checklist.
 Internal/External Floating Roof Inspection Report checklists.
 Sketch and Calculation for Perimeter Seal Gap Measurement.


Comprehensive &Out-of-service8 inspections are performed after the tank is 
cleaned and should 
be budgeted at approximately $5000. each.  This will include a thorough floor 
scan but will not include required repairs.   

 



ATTACHMENT A

IFR/EFR Storage Tanks
Seal Inspections



For the tanks equipped with a floating roof and subject to Ka or Kb, the 
following requirements apply:

- Tanks with an IFR (internal floating roof) require an internal inspection 
every 5 years
(however, the interval can be extended to every 10 years if an annual visual 
inspection is performed):

Burger 58018 (if returned to service)
China Grove 56007-56010
Garden City 56003
Haskell S. 58023 (and 58022, if returned to service)
McAfee 1523
Midland 1516
Scurry 1517
Wildfire 1524
Livingston Ridge 68414 
  Loco Hills 66417, 66418
  Thomas 68413



- Tanks with an EFR (external float. roof) require measurement of the gap 
between the shell wall and the primary seal every 5 years, and between the 
shell wall and the secondary seal  annually:

Foster 787, 790
Quito-Hendrick 58044
Lynch 1511
Sonora 1515 (if returned to service)