>From: "Bill Glushko" <billglushko@hotmail.com>
>To: billglushko@hotmail.com
>CC: jfields@argentinc.com
>Subject: EOTT PL Tanks (compliance) database
>Date: Thu, 28 Jun 2001 17:11:35 -0500
>
>Latest tank list.
>99% complete, unless you request otherwise.
>
>Note that this list includes tanks that are still standing,
>regardless of whether they are inactive or permanently out of
>service.
>
>There are 8 sites which are affected by Texas annual inspection
>fees, with a cost of $58,000. (but possibly, after checking the
>tank strapping tables, might reduce to $51,000.) These fees would
>be due by 11/01 each year if the tank was operated during the
>previous Fiscal Year (Sep 1-Aug 31).
>
>The Teams told me that electric pumps are the norm at EOTT PL tank
>farms.  Crane has a Title V permit, but there were no combustion
>sources that would cause another site to exceed 100 TPY.
>
>The Texas tanks subject to NSPS K, Ka, or Kb are subject to an
>emissions fee, unless they are subject to an inspection fee and it
is >higher.
>
>In Texas, E&P facilities, crude oil and refined product pipelines, natural
>gas and LPG are regulated by the Railroad Commission.
>However, TNRCC has jurisdiction over the petroleum bulk stations.
>SIC code for a petroleum bulk station is 5171; for a crude pipeline
>is 4612. SIC 5171 either as a primary or secondary code is correct,
>and it generates a TNRCC inspection fee for 8 of the sites.
>Designating a 5171 code and/or paying an inspection fee will get the
>facility more attention from the state inspectors.  The need to document (2
>years recordkeeping required) tank seal inspections becomes critical.
>
>For TNRCC inspectors in south and east Texas, seal inspections
>on petroleum storage tanks with floating>roofs have been an item of
>interest for some time.  There is even a >requirement to notify the local
>environmental agency 30 days in >advance of refilling a floating roof tank
>or measuring the seal gap.  It is likely that >the EOTT stations have not
>been inspected because of the changes >in ownership, use of only 4612 SIC
>code, no TNRCC account number >assigned and no inspection/emissions fee
>paid.  But, sometime sooner than later, the inspector will come, and you
>want to be ready.
>
>Larry, I am very familiar with what is required with your crude
>stations and am finalizing a memo which will specify exactly what is
>needed. I recommend you move forward with the sugggested changes. With
>regard to the seal inspections... I can do them, or I can show you what
>you'll need for 100% compliance. Let me know.  Thanks!
- Bill Glushko 281 953-1014
>Argent
>
>

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 - EOTT PL Tks 6-27.xls