6.4 Gasoline Bulk Plant Storage Tanks

Categories 62 and 63

6.4.1 Introduction

Categories 62 and 63 cover organic emissions (TOG and ROG) from the storage of organic liquids in tanks at bulk plant and terminals. The emissions are due to breathing and working losses. Breathing loss is the expulsion of vapor from tank due to vapor expansion and contraction of the liquid in the tanks. Working loss occurs when vapor is displaced during tank loading operations and when air drawn into the tank during unloading operations.

6.4.2 Methodologies

Point Sources are operations that emit air pollution into the atmosphere at a fixed location within a facility, for which the Air District has issued a permit to operate, e.g. refinery cooling towers. These could also be a collection of similar equipment / sources located across multiple facilities, e.g. reciprocating engines.

During the permit to operate (PTO) issuance process, the BAAQMD collects information from the operating facility and/or determines from published literature, e.g. EPA’s AP-42, characteristics of a source including maximum throughput, emission factors for emitted pollutants, and control factors associated with downstream abatement devices. These characteristics are then stored for future use in the BAAQMD’s internal database. Facilities that hold a permit to operate are required to renew this permit periodically (this period varies based on facility and source type). Upon renewal, the facilities are requested to provide any updates to source characteristics as well as the source throughput for the last 12 months. This throughput, in combination with the emission factors and controls factors stored in the internal database, are used to estimate annual emissions at the source level. These source level emissions are then sorted and aggregated into categories.

Further speciation and quality assurance of emissions are performed as a part of the inventory process. The BAAQMD staff also perform a systematic crosswalk between CEPAM’s source category classification (Emission Inventory Code - EICs) and the District’s source category classification (category identification number - cat_ids), which ensures consistency in the annual emissions reporting process (CEIDARS) to California Air Resources Board. The last part of the inventory development process includes forecasting and back casting, and aggregation into sub-sectors and sectors for documentation purposes. For those years where no data is available, emissions data are backcasted to year-1990, as well as forecasted to year-2040 using either interpolation or another mathematical approach (see Trends section). Finally, emissions trends spanning from year 1990-2040 for each category and pollutant are evaluated for anomalies that are then investigated and addressed.

Categories 62 and 63, Gasoline Bulk Plant Storage Tanks, breathing and working, respectively, are considered point source categories and follow the above methodology for emissions estimates.

Sources in categories 62 and 63 are subject to District Rule 8-5 (Storage of Organic Liquids). Those located at bulk plants are subject to District Rule 8-39 (Gasoline Bulk Plants).

Rule 8-5 was first implemented in 1992 with additional amendments made in 1993, 1999, 2002 and 2006. Each amendment to the rule resulted in reductions in emissions with the final amendment in 2006 estimated to reduce emissions from external roof tanks by approximately 2% when peak implementation is met. This can be seen when looking at the average TOG emissions per source for 2006 vs 2015. In 2006 the average emissions are 1.8 lb/day/source vs 1.6 lb/day/source in 2015 of TOG.

Rule 8-39, Gasoline Bulk Plants was adopted in 1987 and subsequently amended in 1994 and 2009. The 2009 amendments include a requirement to minimize the release of organic compounds during maintenance and repair operations, and a reduction in the allowable backpressure in new vapor recovery system piping.

In 2020 and 2021, two of the five petroleum refineries in the Bay Area submitted permit applications to modify the facility operation to process alternative feedstocks with the intention of producing “renewable” products. On November 03, 2021, the Regulation 8 Rule 5 171 and Rule 39 Gasoline Bulk Plants and Gasoline Delivery Vehicles 172 were amended to ensure that the facilities that produce fuels and other products from non-petroleum feedstocks remain subject to and in compliance with the same emission standards and rule requirements.

For these categories, the ROG to TOG ratio is 1:1.

6.4.3 Changes in Methodology

No major changes in methodology were made in this version of the base year emissions inventory.

6.4.4 Emissions

A summary of emissions by category, county, and year are available via the associated data dashboard for this inventory publication.

6.4.6 Uncertainties

The estimated emissions for categories 62 and 63 are largely based on five petroleum refineries in the Bay Area. Any uncertainty in the emissions estimates at these facilities contribute to an increased uncertainty of the point source emissions.

6.4.7 Contact

Author: Michael Nguyen

Reviewer: Ariana Husain

Last Update: November 06, 2023

6.4.8 References & Footnotes